Embed Size (px)
Citation preview
William Paty~ Chairma.,, Board of Land and Natural Resources P.O. Bo:< 621 Honolulu, HI 96809 January 1990
Dear Mr. Paty, A 8: 2 2 We hereby pet.i:tion the Board of Land and Natural Resources tQ.withdraw our properties from the Geothermal Resource Subzones;~'"'_RSJ'.-anct 1~· establ~sh a 2.5 ~ilometer_buffer zone from a~y geothermal a J~-~~E~~CrS author1ty to w1thdraw· 1s pursuant to Sect1on 13-184-10, ~~MA~Ift and withdrawal of existing subzones.
Enclosed herein is a detailed "Document for Withdrawal from Geothermal Subzones". This process started with my notice of intent to withdraw sent to you on March 22, 1989. From that date to this, this application has become the project of the Kapoho Community Association with its board of directors and members being principally responsible fo~ soliciting requests for withdrawal from the Kapoho GRS. A preliminary list of landowners and their parcels was then submitted to your department. on August 8, 1989~ Landowners frOtll the Kamaili GRS;. have!' requested to be'· included in thi!f applicat:ian. We are submitting their names and parcels along with those landowners from the Kapoho GRS.
The Kapoho Community Association has also acted as agent for the writing and review of this Document for Withdrawal. This action has not been undertaken lightly. The principal authors have taken enormous energy and countless drafts, with help and input from a long list of authorities, to really look at the effects Geothermal Development would have on our community and our properties. This has meant looking critically at the well field development impacts and the power plant development impacts which are expected to occur.
As landowners within the GRS, the attached list of petioners of 61 landowners with 74 parcels totaling 785 acres, have a special interest in land use activity in and around the subzone areas. We have a personal and legal right to insure that our health, safety, and economic interests are not violated. Any further development within 2.5 km of any petitioners' property will cause direct adverse impact on their health and property rights and cannot be allowed to happen.
Removal of petitioners' land from the GRS and establishment of a buffer or significant impact area, is the proper and equitable method open to the BLNR to remedy the faulty inclusion of these parcels in the first place. To do less will result in inverse condemnation of property and loss of constitutional guarantees to health and environmental quality.
Kapoho has changed since the GRS was originally adopted. There are more people and more economic devlopment here. And also the body of knowledge on the negative impacts of geothermal development has grown enormously. There will simply have to be other areas and other methods sought to solve the State's energy problems.
The petitioners feel the Document to Withdraw more than adequately meets the tests set forth for the BLNR to approve this application.
-1-
William Paty ..:..::inuary , 1990
Further, there are no active geothermal development activities that have a bearing on, withdrawal of any petitioners property at this time.
Please inform us as to our responsibilities regarding further withdrawal procedures. Kapoho Community Association will be happy to answer any questions about the application to withdraw prior to a public hearing and principals will be available for any public hearing scheduled in Hilos
Sine§~
Delan As Perry~r Kapoho Community Association P.O. Box 537 Pahoa, HI 96778 965-8699
-2-
WIT~ IIIPLltANI'S I JW.ARY 5, 1"' fm.I£R.IAL. IESllRI 9!Zil£S
!.1st Nue First ltaft Mlil r.!ddrm TH lb-eage Land Use Resident
Richardson John W. ~ Pukihae St. 11512 Hilo 1721 1/2/&/17 31.59 residential, banana 2 Kiriaty Aurahat&Susann Box 1338, Pahoa, 1718 112/1911 1.22 residential, ag 4 ~is on Julie, Jeff rT2 Box 5828, Pahoa 1~119118 1.25 rtsidential 4 Kawa.Jski .Tales J. Box 1~, Pahoa, 1718 1121Ct/78 1.48 rts ident ial 4 Brunner-Hm Sally RF2, Box DC$1 1 Pahoa, 90nB 1/C/lt/74 1.48 rts ident ial 4 !Wison Julie, Jeff rT2 Box 58281 Pahoa 11VCfl/17 1.25 residential #filler Jeannie Box 14f21 Pahoa, 90778 1/3/1~& 24 residential, ag 3 ~eiros Alice Box f27, Pahoa, 113/lM 24 ag 4 Perez Carlos D. Box 584 Kurtist~n 907&8 113111813 21.118 Logan Donie Box 1~, Pahoa, 90778 1/3/1/9 21.529 open • Roubique RaJ~ 13-781 Mila& St. Pahoa, $778 1/3/1~9 2'-111 fruit trees 1 Logan Donie Box 1&32, Pahoa, 9£,778 113m111 1 resident ia! 1 Taji&1 Olson Karla, Jon Box 8&1 1 Pahoa, 9£,718 1/3/45138 1.25 residential 3 Hashiro Stanley 328& Kanekopa Pl, Hono, $81& 113/45~ 1.1 • Perry Ted 15-2£8@ 1.1i St,Pahoa 113/45~4 172 • Mlrtinovich A., &F. Aim Box 88, Pahoa, 1778 1/3/4&/49 1· residential, ag 4 Dunphy John Box 159241 Honolulu, 90815 113/4&/83 1 open • Fujioka DaY id, To1iko 831L.wlw St, Hono,$~1 1/3/46/Be 1 • Guz&n Terence I Darnette 98-1356 IB Nola St Pearl City HI 907~ 1/3/46/~ 1 e Let Christopher 385 II. 72 ST. NY, NY 1@@23 12121 1/3/4&/85 1 Yokoyua Yoshio H-7 ,Kichijoji-Hoocho, ll!sashi no-s hi, 1/3/4&/11 1 ag • Yokoyua, cont Tokyo, Japan 113/46/11 llodjeska Paul Box 12731 Pahoa, 90778 1/411/45 4. 95 ag 5 Ch~ Enterprises 1Jle KUJ!Jkoa St, Hilo, $721 1/411/42 5.559 rat~~
Cortini Ctcilia 215 Ca)'llga St, Fulton, NY, 1~9 1/4/115 2@ ag ll!ranaka Jay 137 KauNJJa Dr, Hila, 90721 1/4/1/47 17.891 guaya 2 ll"ada Glenn H. 1129 lfagno!ia Av 117 Gardena CA ~47 1/4/1/48 7.Kl1 ril!l
Pe!Ty De Jan, Jennifer Box 537, Pahoa, 96778 1/411159 2£.1&7 1 i xed orchard Perry De Ian, Jennifer Box 537, Pahoa, 90778 1/411~1 &.8 residential, ag & Wo~ Arthur, Daisy 94& &th Ave, Hono, 9081& 1/411/3B 11.117 ra~~~ • Bettencourt George 6. RR2 Box 3888, Pahoa, HI. 1778 1M1~7 110 ag,1111ts,citrus 7 Latxlers Ja~es J. Box ~1, Pahoa, 9£,178 11V217& 5I ag, llllts, papayas 1 l1 Shaughnessy Keith RIU Box 4850, Pahoa, 90 nB 1/4~/49 2.387 ra~~
Ri~er Richard 1129 LDIMr lfain St. Stte7,lla.ilukll, 90793 1/4/3/1 ~.8 ag Pouerenk Gregory Box 1588 Pahoa, IJI77 B 11415/7 5 Aq Cheethal Clin1 Jo)tf Box 1513, Pahoa, %778 1/415~4 7 ag,•oodNork,res Pouerenk Deborah Box 11& 7 Pahoa 1/4/7/4 1 Residential Pouerenk Gregory Box 1SS8 Pahoa 1/4/7~ 1 Pouerenk Albert, Theresa 33322 Astoria St Dana pt Ca 1/4/7/11 4.3 Aq Karge lfax rr1 Box 3598, Pahoa 1/4/M 11.29 Salzer R.ll. RF2 Box 3780, Pahoa, HI. 1778 1/V91.5 1.5 residential 2 lfans fie Jd Charles F. RR1, Box 3&51, Pahoa, 96778 1/V9~ 1 residential 1 Bell Barbara Box 1311, Pahoa 90718 1/4/121.5 11.&59 residential, 1ind a 4 Mmhese Katherine Box 19171 Pahoa 96 77 8 1tMm 2.5 residential 3 MlrkhaJ Stmn 1778 lla.iooenue, Hilo, 9D728 1/MM 2~ resident iaJ 1
-Rankin LGn Box 117&, Pahoa, 90778 1/4112/3 1.5 residential, ag e Rankin Lon Box 117&, Pahoa, 90n8 1/41121' 2 residential, ag 3 Date Ja~rs 4&~ Kalahi St, Kaneohe, 1744 1/4114fl 2. 193 papaya • Date Jafts 4&-26@ Kalahi St, Kaneohe, $744 1/4/14/8 2. 193 pajla ya Date Jms 4&--2£>8 Kalahi St, Kaneohf, ~744 1/4/1515 14.415 pajla ya • Cohen Eric, Diane Box 9&8, Pahoa, 96778 1/4115/8 3 residential,banana 3 H!dtke Richard & Jane Box 9J7 Pahoa HI ~778 1/4115/1 7.25 residentai, ag 4 Spoede Rarxiall L Box 1591, Pahoa, 'IJ778 1/411&/7 ~.2 ag 2 JaYier Fernando Box 1414, Pahoa 1/411&/2 3 resident iai, ag 5 Frink,llillia.JS IIi ll iu 1 Robert Box TIC, Kurtist~n, 907&0 1/4/17 ~ t 84 Yacant • DnuPr•nll Deborah , Gregory Box 1588 Pahoa 1/4/17/11 7.5 A;
Last ltalf First Mlft lfij '""'~l'fSS T.f\1 lk.Tfqf LaJJd Use hsident
P011erenk16ado lngory,LIII"T'aill! box 1588 Pahoa lA/17/4 ' residential, q Sarhanis Alx!1'fll J. lox 1729 Pahoa, HI '1718 lA/17" 4.3 residential, q 1 Cohen Rudolf lox 1724, Pahoa tAm" 4 residntial, binw""' 4 HlJi Jay,Car•l"' lox 14461 Pahoa, '1718 tAmlle 3 guava far1 3 lrarthaller Chris 229 Atlantic St, rtlfinrrYille, lhg•n,971U lA/28~ 1.13 11 I lleek Denald, .Mib lox 721, Pahoa tAmt4 2.8 residential, pastlll"t 2 Richardson L)'lln P. lox 663, Kurtist1111n, '1768 1A/2V7 2 a;, flliage 2 Klein Henry Box 1474, Pihoa 1A/Wl& 1.5 residential, fruit 2 Doh .lues 4&-268 Kalahi St, IW!fohe, '1744 tAm" 11. &53 papa )'i I K.wbata lfisakazu &3& Elepaio St Honolulu HI '181& tt4m/3 17.734 ag I Perry Delan,Jennifer lox 53'1, Pahoa, '177 8 1Am~r~ 15.119 lired orchard Kallabata lllsakazu &3& Elepaio St. lmnolulu, '181& tAml2 1&.5.£ q I C1 Hara..JM ir Eileen Box mr,, Pahoa, '1718 1Ate8~ 4.18 residential, ag RuderRII Russell lox 1411, Pahoa, '1718 1/41281117 3.44 residential, ag 1 Spe~ar Virginia RR- Box 4118, Pahoa, '1718 lA/7211& ,,333 residential, q I Jones Richard lor 2192, Pahoa, '1718 1A/911~ 1 residential ' Laughlin Dave Box m, Pihoa, '1718 1/4191/3 1 residential, q ' Elson Usa Box 1521 Pahoa, '1718 lM/41 Jr. residential, q 4 Schneider Scott l Box 21!i, Pahoa, '1718 1,11/9 E.29 q 2
/
l\-u.,w1a.m_ ~ lht.SCIM l(i n~ -~"ex 'o 2> e PMoo,... I ffL C\(0( 78
;Jo.m.OA \!owaish ~C)( t~~i-'
fh"D"- 1 Hi q b "17e
~~ B(~Mmtfl·-~
r3 CK (pa_c, \
P a.hco. 1 \1i C\.& 1"'1 ~
~n\.e. tv\-Llle.Av '8~ w.s~ P~a., lk llb 17~
Q~ M.eLL.ivos B£1". 'S;}.. 7
Po..h.cr.., m etc.. 77~
CaAtos D. Pe.ftl::
SOf<. Ss4-KUAb:s.hJ~J4.\-t q&7C,()
.VO"l\ie-~~ So..<~~~
1)llhoo..; -tti q" 7 7B
'e.o.O.p~ Ro...J,i~UA.. 1.3 -7 ~ l t--t a1o..nt.a. Sl- 1
Pahoa 1 4ti qc. 7 76
~ta... 1 o-j imo... 'Jor'\ (} \s l)-t>.
eox. e101
~ieb.n~ ~~a.s~-o :3 2.E:lb Ka..nekop~ pJ..,
~\Wu. 1 t{i q b~ \ .(,
{ed fe.Yr~ \~-:2.(..~<0 4U S\-. Polrtoa, Hi q 6 '1 i t;
A • Ma.v-nhov\·Jv r:=. A~t:\.1 So,.-:.Se
Pa.Aoo.../ +It q" '17B
Se>hV\. o~h~ Box ISCl;tlf-
.J.lnl'lDtul"'-, tti. CJf:.~lb"
Vo.vfd t \orni ko +='ujtoka.. Boo t..o.wda.\Ve. st. \h!Yt.olu!\.1. 1 Hi C( (:,~::d
1 eY-e.t'lce. 't Do.v-t~.e. Gu.~vn.a.t'\1 qe, .. ,aS'b wta Nolo.. Sf-.
l'ea.-t c..·~ ... ltL q "7~2...
'< osh,t0 Yoko~Cl..l'l"\a..... .«.t-Lf.-7 t< ich.'~oj i. - H-r>"'"ch.o M usa.shlno,sh.i. {ok~CIJ ::>a..pa."'-'
l='a.u..l lvloc!J'e.ska... \3o )< l.:ti 3
Pono~1 ~ q"'11~
t.hoUJ ~h.~Yp-l'ses \ooo Kv..~u.koa.... ·st-. ~lo, Hi. ltb7.J..O
ee.~at'o.. C-D,.-ti"i 2.\5 CAju.jo.. S-h
PuJ-lon .. t-t 'f \'ooG.~
OCU) MuYa.n o.k.o..\.31' Ka\.l.rnO . .I'la.. Or, -t\iU,, \-({ q ~ 7 .::lO
~lett "" CJkada... \6-l-9 Mo..1 "olt~ ltv· -ttl 7
&artie.~ a., CA q OlA7
J\~v.r \ l:Xt~J UJo~ C\ A.\~ (.,'".Y Ave.
H-oVlo\.""lu 1 ~ qbt;t"
C:re..org e. Ba tlC2..t'- co llr't R.'R.~ . E'>o,tc. ~000 \'£thoo..J t-\i. <\617~
6 ames l&Je.rs ~ a;q Ps.hoa..J Hi Cl67"ZS
K~i\-h. D' Sha.u.9k.l1.eG<>j ~v:ll
eox +sse P4h.oa.; Hi q<-178
r.t\'chard Rive..-\\2~ Lower Vlain. S\-. :=~ \" • to-r w a.'t\uki.A.., ~ 9!.. 793
gre_9or~ Pommerenk.
So><~~~ Pa.hoo., tn C\c.. 77e,
c..li~a. \ JOjC..'Z C~u.tha.l'\'\. Bo>< \sl~ 'P ~hoa. J {-H. qc_ 77e,
1\l b2r-t1 1'h..cu~es.a. Po~
a.aa.t:l. ~r~ a. Oa.tt<t.. P.r. 1 C.Pt
0-'·- •.. .... . ---
~.w .9a.\4V"' Z~.z. BCI< 3760
• '10a.,ttL % 11e
C...na.rles F. IY'Ians~<z.ld ~IZ \ Box 3G.bl> Pah.ca J rH CJCa 7 7'8
Ba.rbar-a.. Bel\ Bo/C \31 o'. Pa\t.oa.; Hi. '9'=-778
Ka-\-h{lri~ t"lar chcz.s(l. Bo><:\9()7 Pahoa, ltl ~fO 77~
StQ.v~ 1"\ark.haWL.. \'176 Wa(ai'I.~J..£n.ue Ave..
~i\o, Hi. 9b 12.~
Lol'\. Ran.kil"\. Bo,c \07C:,
Pahoa, tti. '!>to? 7<8
'Ja~s D~ .ttc.. -2G:.C \<a\ah\. 9\-.
Ka Ylfl.C> 'ncz, tl-l. S>'=:. 744
\:: r 1'c., ~ Dian.L Coh..<Z.'n..
Gox 9<.:.0 Pa.hoa, \ti 9lc 7'1 ~
~ic.har¢ ~ ra'r\ll \tad+k~ Bcx 9?1'7
Pa~, '-Itt. 9c. 7 7E;
~avu\a\\ Spcerl~Z r . \S~o 'Pahoa, tti 9~ 778
'Fczrnawic ~a.v~ Bo)( \.L.\ \1' ?ano~, ittt 9 ~ '7 -ze
'vyi \l i a:M :n-i n k.Rcb<Zrk willidms. ~ex 37C:.
Kv..rtistt>wn) 1h 9fo ?CoO
1\:ndre.w SaY'~ ( s IOox IC.::t9
Pa.h..oa.) th:- 9'=>17S
R u.d.o\ f Co ha-t\. B~ 17l4 Pa.h.oa-J t\i 9 fo 77 e
:r~ t Carol~~~ Sox\~
P .3-hoa, -\ti 9C:. 17 '0
Chr1'& \Y\~1'-ha.\\Q:r 2l. ~ A +lal'\h:c.. 9-. Mc.Y\(1'\nvi\\e., C:>Yegon. 9?
Ocha.ld. ~ J"Llnk.c Wefl. ks So;c 7.2...\
?a.hDa1 \+t ~'=:. '17€;,
\...~n" 'P · "R,~yJ sorw Box G,(..~ .
l<.W"'tcsrol0\'\.1 tti 9fo 7f.oO
\-\-0\':j K \ei"'" eo.x 1'+'14 Po.hoo..
1 Hi. 9 b 77~
Masaka.a u. ka.wabAt-a. C..o<. Elepaio S\-.
tro~t.olLI-ll.\., 1\i 9~'b I G:.
Ei \Ut'\. 0' \-\-oYa.-I.Jeir SoJ<: I I~C.
p ahCJC) 1 -i\1. ~ ff e,
~\A.SS(z ll l<u..d.<lr rna..Y\.
'OQ.K. I'"+' I 0 Pakoa, -fu: 9C.. 77'0
Yl~(rt(a. Spenc.a:r R.~
&x 4ClB Pa.h.cl~, ttL 9fo 77S
Rl'chaYd So~s 'Bot< 2.()9 2..
'Pahoa; \-\1.. 9fo 17S
'D~vq. \....aush\.ln.. l?>G')( 112. P a.h.o a.) ttL <:>"' 77 e
lisa ElseY\
Bcx\s-J..O
Pa\wa, m 9b 77B
c..hns~ he.r L<2lZ. o05' w. 12 :iY N"f ) N'< l 0023
J'l..l} ie ~ ~(2-\*- AddisoY\. ft~2 aCP' soA.e Pa.\t.oaJ tti. CJf> 778
3elln 1f'e.r tDekn Per-rt:J "Bt~>G 537 Ptth o~J Ht:. 4v11f
SECTION 1 SECTION 2 SECTION 3 SECTION 4 SECTION 5 SECTION 6 SECTION 7 SECTION 8 SECTION 9 SECTION 10 SECTION 11 SECTION 12
SECTION 13
Attachment 1-A
Attachment 2-A
Attachment 3-A
Attachment 3-B
Attachment 3-C
Attachment 4-A
Attachment 5-A
Attachment 6-A
Attachment 7-A Attachment 7-B Attachment 7-C Attachment 8-A
Attachment 9-A
Attachment 10-A
Attachment 10-B
Attachment 10-C
Attachment 10-D Attachment 10-E,
10-F, 10-G
TABLE OF CONTENTS
PAGE NO. STATEMENT OF PURPOSE 1-1 BUFFER ZONE 2-1 NOTIFICATION OF SUBZONE DESIGNATION 3-1 AIR QUALITY IMPACTS 4-1 NOISE IMPACTS 5-1 GROUNDWATER IMPACTS 6-1 PROPERTY VALUES COMPARISON 7-1 AGRICULTURAL IMPACTS 8-1 COMPATIBILITY 9-1 GEOLOGIC HAZARDS 10-1 STATE POLICY 11-1 CONCLUSION /:) . .. , ATTACHMENTS AND CORRESPONDENCE
DBED May 21, 1986 letter, Ref. No. 2284, Summary of the HGP-A generating plant forced outages Addendum to Air Quality Modeling, Puna Geothermal Ventures Authority to Construct application, June 7, 1989 March 28, 1989 letter to DLNR from the Kapoho Community Association.
to to to to to to to to to to to -lo
May 24, 1989 letter to Richard & Jane Hedtke from DLNR. November 19, 1984 letter to Jean Willhite regarding withdrawal of private property Table 20, Health Effects of Hydrogen Sulfide on Humans Hawaii Tribune Herald article, MayS, 1981, 7-day week approved for geothermal work Compilation of Failure Data and Fault Tree Analysis, Project Report, Miller & Zimmerman, 1982 Supporting data for property value survey Letter from area realtor Seller's Real Property Disclosure Statement Effects of Continuous H2S Fumigation on Crop and Forest Plants, Thompson & Kats, 1978 Viewpoint article Hawaii Tribune Herald, Geothermal Health Report Questioned, Westlake, June 18, 1982 Figure 10, C-107, Percentage of ground covered by lava flows, 1954- 1984. Figure 12, C-107,. Zones of Relative Risk from Volcanic Hazards Figure 9, C-107, Summary of Kilauea's eruptive history USGS 1945 map of volcanic vents News articles, Stillwater, Nevada, geothermal well rupture of January/February 1989.
i
1-11 2-2 3-5 4-10 5-2 6-3 7-4 8-4 9-3 10-3 11-2 I :2. '2.
Attachment 11-A
Attachment 13-A
Attachment 13-B
Attachment 13-C
Attachment 13-E
Appendix A-1
Appendix A-2
Appendix A-3 Appendix A-4 Appendi:< A-5
Appendix A-6
Apft'td'" a~ 2 SECTION 14 SECTION 15
Gec..~ .. ,..;ermal Development Policy -.~,.,.· an Isolated State: The Case of Hawaii (Kamins, 1975) 3/22/89 letter to DLNR from Delan Perry, requesting withdrawal 5/19/89 letter to Delan Perry from DLNR, re: info necessary to process request for withdrawal 4/24/89 Letter to Delan Perry from DLNR, forwarding TMK and map of Kapoho GRS 9/15/89 letter to Barbara Bell from DLNR acknowledging receipt of application and list of property owners
Figure 7, Evaluation of Impacts on Potential GRS Areas; Proposal for Designation of GRS Kapoho Section of the LERZ subzone boundaries overlaid on Tax Key Map Kamaili Subzone map Resource Probability Map Chemical Composite of well effluent, PGV application, p. 3-24 BACT analysis by Goddard & Godd~rd Engineering for PGV 25 MW project, July 31, 1989 JA.f'lef'k Gherl'l.Ul) .J"Wie ~, ~~~~ BIBLIOGRAPHY DEFINITIONS
ii
14-1 15-1
STATEMENT OF PURPOSE SECTION 1
The purpose of this application is to withdraw 74 parcels of land comprising 785 acres from the Geothermal Resource Subzone and to establish a 2.5 km buffer zone from any geothermal activity as defined by HRS 205-5.1.
The authority to withdraw is pursuant to Section 13-184-10, Rules of the DLNR, which states that:
·~edification of the boundaries or the withdrawal of an existing designated geothermal resource subzone may be initiated by the Board or by any property owner, State mining lease applicant, geothermal mining lessee, or person with an interest in real property that is within the designated subzone. The procedure for modifying the boundaries or withdrawal of an existing designated geothermal resource subzone shall be conducted pursuant to the provisions of Chapter 91, HRS. The Board shall withdraw a designation only upon finding by a preponderance of the evidence that the area is no longer suited for designation: provided, however, that within an existing subzone with active geothermal development activities, the area may not be modified or withdrawn. An environmental impact statement as defined under Chapter 343, HRS, shall not be requi~ed in assessing any modification of the boL.lndar ies or wi thdrawa 1 o·f SLlbzones."
The applicants intend to show that geothermal development, including exploration, is inappropriate and incompatable with residential and agricultural zoning in Kapoho and Kamaili. The areas designated for those subzones were never appropriate for this type of heavy industrial use. Too many people live, work, and enjoy recreation in and around the Resource Subzone. The Kapoho Section of the Kilauea Lower East Rift has a particularly high population which geothermal development will severely impact. Planning decisions were made.within the area, prior to geothermal development, for residential and agricultural use. Building permits are still being issued for both of these first priority uses.
At the May 22, 1984 public hearing for the draft rules and regulations for the designation and regulation of the GRS, Tom Okamura, Chairman of the House Energy, Ecology, and Environmental Protection Committee testified that:
With respect to the Board's assessment procedure for designating subzones described in this section 4, implied limitation on information which the Board will utilize, I think requires some revision. I agree with the Board that expensive and extensive data gathering which is not pertinent to the designation of the subzones should be avoided. I also believe, however, that the present language of the rules and regulations, which states that the Board may base its assesment on currently only available public information, could cause to be overlooked some very important and relevant data.
I strongly believe that the Board should utilize all information which may be available to it. Information which may prove pertinent to the Board's assessment should not be overlooked merely because it is not "currently available public information."
1-1
The applicants of this proposal agree in principle with Representative Okamura's assessment.
The proposed geothermal resource areas were evaluated on the basis of potential and real impacts which may occur within each of these areas. Based on available information evaluations were made of geologic hazards, social impacts, environmental impacts, compatibility of development, and economic impacts. (Proposal p.8) This evaluation process was made on the basis of expert knowledge and available information obtained at that time (1984).
Since 1984 additional information has been compiled and spec1t~c projects have been detailed to substantiate the applicants' contention that the adverse impacts of geothermal development will outweigh the benefits to the state.
Thus the applicants seek to exercise their rights under 184-10 to withdraw their properties from the GRS and consequently to disallow any activities specific to geothermal development on or near their proper··ties.
LEGAL AUTHORITY
Act 296, SLH 1983, gave the BLNR the responsibility for designating Geothermal Resource Subzones in the State of Hawaii. The purpose of the act was to provide a policy to assist in the location of geothermal development in areas of lowest potential environmental impact. The Legislature also recognized the potential inherent conflict in land uses and assigned the Board the responsibility to assess land use compatibility with geothermal development and to find an acceptable balance BEFORE the designation of a subzone. As outlined in this application, we feel that a buffer zone is necessary to safeguard the health and property of neighboring landowners against geothermal hazards and other adverse effects.
The original administration of Act 296 for the use of subzones for exploration, production, and distribution, governed by Title 13-184-12 provided for the contested case hearing pursuant to Chapter 91 of HRS. effective August 16, 1984. Act 187 SLH 1986, added the provision of mediation to that of the contested case in applications for geothermal development activities within a conservation district. HRS Chapter 205 was amended by Act 378 SLH 1987 to delete this provision of HRS Chapter 91 (Hawaii Administrative Procedures Act) for a contested case hearing SPECIFICALLY for geothermal permit proceedings. Therefore the assumption in 1984 that residents and landowners would have the right to due process in contesting GRS designation decisions no longer holds true.
ADDRESSING THE 1984 CRITERIA
The Board has requested the applicants to address the six criteria that were used to establish the subzones in 1984. For the purpose of this section references will be made to:
PROPOSAL: "Proposal for Designating Geothermal Resource Subzones by the Board of Land and Natural Resources, July 1984"
1-2
REPORT: "A Report on the Geothermal Resource Subzones for Designation by the Board of Land and Natural Resources, Division of Water and Land Development, Honolulu, Hawaii, August 1984"
The purpose of the PROPOSAL was to pL!bl ish for- r-eview by tht=~ pub 1 tc and to r-eceive comments at the scheduled public hear-ings.
The purpose infDI'-mation
of the REPORT was to assess the cur-r-ently available at that time to deter-mine the existence of and the impacts
of geother-mal r-esour-ces in Hawaii.
Examination of seven ar-eas r-elative to social, economic~ envir-onmental, geologic, and compatibility of land uses reveals several impacts that may r-esult fr-om the explor-ation, development and production of geother-mal r-esour-ces for- electr-ic power- pr-oduction.
Since 1984 additional infor-mation has been compiled and specific pr-ojects have been detailed to substantiate this pr-oposal's contention that the area is no longer- suited to geother-mal development.
Statements made fr-om the then "cur-r-ently available infor-mation" will t)E~
r-efuted to point out that subsequent information leaves the Pr-oposal and Repor-t deficient in their- assessments of various cr-iteria for suitability of geother-mal development within the Kapoho Subzone.
Pursuant to the testimonies presented at the Middle East Rift Suozone Contested Case Hear-ing of November 13, 1985, several questions wer-e raised regarding the validity of the cr-iter-ia, the DLNR circulars prepar-ed by Bay Vee of Environmental Capital Management Inc., and the size at the subzones.
In the MER contested case hearings, the Volcano Community Association's intent was to show that:
1. Development tor exploration and/or- production would have significant adverse affect on the quality of life, nature of the community and lifestyle of the applicants.
2. The socio-economic and other studies done by the DLNR pursuant to Act 296 were inadequate for failure to consider a full development scenario, e.g. 500 megawatts, instead of only the 25-50 megawatt scenc:tr-io.
3. The DLNR acted unreasonably and inappropriately and improper-ly followed legal cr-iter-ia in proposing and designating the geothermal SL!bzones.
The Kapoho Community Association and its landowner applicants support the conclusions and information pr-esented in those hear-ings and provide to the BLNR the following information in suppor-t of this withdrawal application.
1-3
A. THE AREA NO LO~ER HAS ANY SUFFICIFNT POl~~TIAL FOR GEOTHERMAL RESOURCE DEVELOPMENT.
Sufficient potential was based on a qualitative interpretation of regional surveys and available exploratory drilling data. Tne Technical Committee identified seven high temperature and five low temperature potential geothermal resource areas.
In the September 27, 1984 response to Planning Director Sidney Fuke, the BLNR stated that "the Statewide Geothermal Resource assessment was conducted purely on technical information and without regard to any specific district boundary or special land use designation such as the National Park."
The Geothermal Resource Technical Committee was charged with the responsibility tn review available information and recommend areas in the State where geothermal resources might be available for electrical po:r~er (:_;jenel~ation (C--10:3, p. iii). "It should be noted tha.t. tl·v?r-e !f.li:3.'5
some disagreement between technical members as to the importance placed on certain data and to the area encircled within the probabi 1 i ty lines. After '::;orne deba.te a. h.QMPF;;_pM I SF.;. :,.,as reac heel whe1~e
equal weight would be given to all positive data and the probability areas mapped would be below the 7000 foot elevation due to limits of cu.rrent drilling technoloqy" (C--103, F'. B-41).
SEE APPENDIX A-4
Seismic Studies on Kilauea Volcano, Hawaii (November 1978), stated:
"Geotherma.l reser·voirs are char<:l.c:terize-!d by hiqh seisrnici ty a.nd in some cases hypocenters of microearthquakes are useful in delineating a fault or fault zone in which hot water travels to the surface (Ward 1972). Consequently, in support of the Hawaii Geothermal Project, a microearthquake survey was conducted during three weeks in August and September 1974, in an area of the east rift zone on Kilauea that other studies had considered promisinq (eg Abbott 1975; Klein and Kauahikaua 1975).
"After the success·ful drilling of HGP-A it was noted that a cluster of shallow earthquakes in the vicinity of the well could possibly be related to geothermal activity. The hypocenter pattern based on crustal model by Broyles et al (1978), which became available after drilling had commenced, further emphasized the isolation of the events near the well site from the other events.
"The seismicity of Puna ca.n be' applied to in a negative sense. The lack of activity indicates that Kapoho is not likely to be despite the recent activity there."
geothermal prospectinq in the Kapoho region
a geothermal reservoir
It is completely different to say that the a.rea has "su.·f·f.icient potential" for DE~iEUJF'MENT o·f the resoul~ce. I..Jntil there is a.n adequa.t.e a.nd "suf·ficient" bLtffer- zone of a. 2.5 km minimum l<:1ndowners a.nd residents would be put in an expendable position. In describing "sufficient paten tia.l" it is nE'cessary to ta.ke in to account t.ha t. the proposed withdrawing areas never had sufficient potential because any geothermal development would have conflicted with then current land u.se =
1-4
Additionally, evidenc~ hai not yet been presenteL to show conclusively th.e:•t thE' i':\r··ea hc.'ls ''•::;u·f·ficit-~nt. pote11tia.l "'' The:' ~:sui:J:'.onr:l bou.nd,;:.,,·-.ie:.::; ,,,!f.':!l"e
arbitrarily drawn from benchmark to benchmark showing lack of planning for compatibility with other land uses.
PERMEABILITY
In the Proposal it was determined that there is a greater than 90% chance of finding a high temperature resource at depths greater than 3 km. Permeability is a primary factor of significance in assessing the ... geothermal resource (C-103 p.B-35). There was discussion by the Geothermal Resource Technical Committee of directional drilling of {~<::;hid<~- ~--Jo. i.. in a. 1'-~-!\IE direction to "locatE? a. zone of permea,b.ility." Drilled to a depth of 8000' the resource is hot (543F) but lacks a permeable reservoir. Lanipuna 1 reported to have a temperature of 685F also has a problem of low permeability. These wells have been plugged and suspended becau'3e of this absence of a permeable reservoir. High temperature is not the only parameter for assessing potential. Of the seven deep wells drilled, all have high temperatures (>125 C) but not all have adequate permeability (C-103, p. B-40).
B. THERE IS NO KNOWN OR LIKELY PROSPECT FOR . THE UTILIZATION OF GEOTHERMAL RESOURCES FOR ELECTRICAL ENERGY PRODUCTION.
In the Proposal, the Kilauea LERZ was considered a good prospect for utilization ''based upon prior permit applications and developer activity.'' It was assumed that the community accepted geothermal development and that the developers considered the resource safe for utilization adjacent to residential areas.
A 1300 ppm H2S (PGV Application Amendment 1989) (v. 1950 ppm H2S PGV EIS 1987) reservoir may have sufficient potential, however, because of high heat, pressure and acidity which pose engineering problems with metal fatigue and corrosion, utilizing the resource may prove to be hazardous and require intensive maintenance and replacement of components.
The HELCO bi-annual HGP-A Technical Progress Report and monthly Operating Figures lists the hours not in operation, during which time the well is vented through the rock muffler in hours:minutes;
M-::>.r '82 - Aug '82 f:3ept '82 Feb '83 Mar '83 ALtg '83 Sept '83 Feb '84 Mar '84 Aug '84 Sept '84 Feb '85 t1ar '85 Aug '85 Sept '85 F(=b . ~:36
SEE ATTACHMENT 1-A
600:55 111:26 699:14 :3'56: 06 75:26
248:03 68:27
445:02
Dec .Jan .Jan
'87 '88 '89
402~03
Dec '88 694;00 Feb '89 68:00
The HGPA, has encountered increased difficulties in remaining on-line due mainly to the failure of the abatement systems, clogging of the pipes with silica, and corrosion of all the equipment. Unabated venting on the Labor Day weekend resulted in several families being evacuated out of the area with the assistance of the County's Civil
1-5
DE~ ·f e. r·, =· Ff!
,,,H::' e k s D -f time.
a.g;:·:2ncy, In mel in t:F.:n ::1ncf2
~!i::::ptembE'r· .1. c?U9 fr.Jh.i.lF! \f~'=n+:.ir·,q
the HGPA ~dS off line for unabated a great portion of tha.t
In addition, the electrical transmission system o-f the Biq Idsland is subject to numerous outages. Localized outages as well as island wide outages are experienced with great frequency. Geothermal plants would be required to go off-line and emit steam through their emerqency steam release facility (rock muffler), abating H2S by approximately 95%.
en2.2J2..S.£;.i:_~_fp ,~ U. ·t. .. LlJ :z. '~ t .\.QJJ__ a,~ §!_l i mj._:!; !:.~ d- b v __ .t.E r- h n i c_s, 1 an~:t_Jr.:.§J:_;..tl·::?, n i ~..sJ_ ?J.:?J_..t:.-~J;j.OJJ.2 for·· __ :t,l-:le 21.bC:l. t_emr=>n t 9..L~m)..ssiqns ·-· The DOH ( 11/ 1/89) letter
written in response to the PGV informational meeting comments revealed:
r··es pon se i:l:2 ~
There are no suitable abatement equipment control or chemical treatment methods that have been demonstrated to be effective and safe. During the venting operations, there is insufficient time for chemic a l n~.ac t.ion=:. to ta.ke place.
r-esponse 'i:l:.10 : The remote control and/or automatic well valve technology has been researched by the Department of Health and is being considered. It should be noted that computer controls and automatic well valve shut-ins have been used at the Geysers in lieu of chemical abatement of steam during emergency steam releases. These systems allow relatively rapid (within ten minutes or so) shut-in of unabated steam flow. The applicant has not proposed such a rapid shut in for the wells, since casing problems with some of the initial wells in the area is thought to be due to the thermal effects of rapid shut-in of the wells. The presence of a cooler temperature groundwater regime above the geothermal reservoir dictates that prudence and extra time be used in shutting in the wells. With this time constraint, automatic controls may not be necessary or practical at the PGV power plant site.
response #1:3 The unabated venting of a well for 4 or more hours is considered standard industry practice for wellbore cleaning. The venting of a well for 4 hours is the estimated time necessary to ensure that all the rock particles are cleared from the wellbore. It should be noted that a previous well drilled, which was not vertically vented caused damage (butterfly valve cut out) to the well equipment during the flow testing operations.
Thermal Power Co. in its evaluations of the venting of the KS-1, KS-2 and KS-1A wells determined that because of the engineering and technical problems caused by the iron sulfide particulate matter from below the 4000' strata~ "mechanical solutions for abatinq of venting is detrimental to the technical aspect~; of the well." Abrasive solids in the flow stream erode abatement and flow testing equipment, therefore open venting utilizing windspeed is considered acceptable.
The KS-2 rig test of March 30-31, 1982 required approximately 33 hours o·f air li·ftinq thr-ough the 4" drill pipe to initiate ·flow. The te<:;t
1-6
was terminated after rlowing for 1-1/4 hours bec~~se of erosion in the flow line by particulate matter associated with the producing fluid.
On October 2 ~, 1982, the Kapoho State 1 well had an uncontrolled blow out when a pipe broke. The Civil Defense Agency brought in a helicopter to fan the hot steam and toxic gases away from the work area to permit the repair to be made.
Silica deposition within an injection well may cause it to become plugged (Report p. 15) and ''silica deposits will be removed periodically and disposed of in an environmentally acceptable manner.'' Silica tests of the HGPA brines by Brewer Analytical Lab (1989):
% fresh weight 12.9 %dry matter 87.17 mg/1 500
Silica content is about 380 mg/1 at the well head, but higher, perhaps 700 mg/1 at certain depths (Humme et al 1979).
During well testing, PGV proposes to pond the fluids at 45 gal/min for a 90,000 lb/hr well for 20 days of te~ting, resulting in 1,296,000 gallons of geothermal fluids to be ponded. (v. 150,000 lb/hr Thermal Power EIS)
In practice at HGPA it has been shown that the silica ponds were not purged, or even kept within the designated areas and were not removed, but just bulldozed.
Geothermal power plants are subject to lawsuits in areas close to residential development (Puna Speaks vs. Hodel et al 1983; Layton, et al vs Yankee Caithness Joint Venture, Nevada, 1989; Towne vs. Far West Electrical Energy Fund, Nevada, 1987).
C. POTENTIAL GEOLOGIC HAZARDS TO GEOTHERMAL PRODUCTION OR USE EXIST IN THE AREA.
The Kilauea East Rift Zone is one of the most seismically active regions in the world. The USGS (Volcanic Hazards on the Island of Hawaii, 1974) rates the Kilauea ERZ as Zone F--"zone of highest risk; includes summit areas and major rift zones of Kilauea and Mauna Lea Volcanoes. Land within zone F has a historic and recent prehistoric record of active volcanic vents, formation of craters, ground cracking and subsidence, and burial by lava flews. Narrow coastal zones on parts of Kilauea and Mauna Loa are also designated as zone F because they lie within belts of frequently active faults in which the land is subject to cracking, abrupt subsidence, and possible inundation by locally generated tsunamis.'' See section on Geologic Hazards.
D. ADVERSE ENVIRONMENTAL OR SOCIAL IMPACT WOULD RESULT FROM THE DEVELOPMENT OF GEOTHERMAL RESOURCES WITHIN THE AREA.
AESTHETICS
Both the 1984 Report and Proposal, Figure 7, "Evaluation of Impacts on Potential Geothermal Resource Subzone Areas", rated impacts on scenic and aesthetic values among the most significant for the Kilauea LERZ. Although these have significant value and will require the same level of scrutiny in permitting procedures, the mediation sessions so far held did not provide enough time for discussion of these impacts.
1-7
FLORA AND FAUNA
The Report states that development may have potential negative impact on native birds~ including many of which are endangered. The potential for environmental impact on the flora and fauna of the resource areas was assessed using a forest categorization system, based on the US Fish and Wildlife Service vegetation type mapping. Areas not covered by the categorization system included the Lower Puna area.
SOCIAL IMPACTS
The Proposal's Figure 7, (p-12), indicates that there would be no impact expected for health concerns. The Health issue is not discussed in the text on P-13 for significant or moderate impacts.
SEE APPENDIX A
The "Assessment of Geothermal Development Impact on Aboriginal Hawaiians", February 1982, conducted survey questions with responses to "I.Alha.t 1.-.: ind of change would geotherma.l deve 1 Dpmen t bring about on the physica.l environment (noise, ai1~ quality, visual) of F'uni:~.7" Out of the 25::::: n?spon~'3es, !:.~6 said it was "=-lightly bad" a.nd 1.14· sC:~.id it was "very bad''. Attitudes towards the effects of geothermal development were perceived as negative by the respondents.
"The Puna Community Survey", a study conducted for the DPED and Hawaii County Planning Department by SMS Survey Inc~ completed in April 1982~ r-eported l~esponden ts of Kapoho to I<C:!.l C:l.pC:I.na as "suspicious o·f it"; o:~.nd
that it would affect the rural character of the area. Affected respondents mentioned negative effects such as health problems and sme 11.
The environmental and social impacts which needed greater depth of investigation in designating the subzones and which posed major problems in mediation proceedings, include but are not limited to:
He.::\lth Air Quality ~~ater Qu.ality Noise Incompatibility with Lifestyle, Culture and Community Setting Buffer Zones Agricultural Effects Geological Hazards Property Devaluation Due Process Violations
Each of these issues are addressed in following sections.
E. THE DEVELOPMENT AND UTILIZATION OF GEOTHERMAL RESOURCES WOULD NOT BE COMPATIBLE WITH OTHER ALLOWED USES IN THE AREA AND THE SURROUNDING LANDS.
DLNR Circular C-106, Environmental Impact Analysis of Potential Geothermal Resource Areas, Oct. 1984~ states that in conservation di str ic ts, "on 1 y when the benet i t.s of the proposed use are deterrrd.nE~d
to bE• greater than any .irnpac t on the 1 C:l.nd, wi 11 the use be perrni tted." Act 151, SLH 1984 amended HRS 205-5.1 to require that within
1-8
. .:::\ q r- :.i. c 1...1. 1 t:.u. r·· a. 1 , :--· :_w e:d. e:1. n d u r- b <0.n cl is; t.r- i c t s t h <0. t " t.'f-i'e ch:=s- i. r- f.-'~ c! :..:. ~;:."~ s l--'!0'-..:.1 d not have unr-easonable adver-se hea.lth, environmentdl, orsocio-economic effects on r-esidents or- surrounding pr-operty ... (and) there are re.ason<0.ble measures avail<0.ble to mitigate the unreasonable ,E!d'-.·'er·s€·? effects".
Cir-cular C-106 states that ''In addressing land use compatibility, several assumptions must be made":
AMBIENT AIR QUALITY ~ill not be affected since it is expected that current abatement technology will be fully utilized in compliance with proposed State Department of Health air quality standards for geothermal development.
Proposed County of Hawaii NOISE Guidelines of 45 decibels at night and 55 decibels by da.y will be complied with. It is also assumed that the County of Maui will adopt similar noise guidelines in reference to geothermal activities.
Geothermal facility siting will be adjusted to avoid ENDANGERED plants and significant ARCHAEOLOGICAL or
HISTORICAL sites.
VISUAL impacts will be minimized by adjusting the location of the site, the alignment of structures so as to present the smallest possible aspect and by blending structures with surroundings by painting appropriately and by use of non-reflective, light absorbent materials and textur-es and by shielding facilities fr-om veiw by locating behind a puu or hill, or by placement in a forested area.
Impacts will be further minimized by use of BUFFER ZONES surrounding geothermal facilities.
The Kapoho section of the Kilauea Lower East Rift Zone GRS is predominantly utilized for agriculture. Major residential subdivisions in and adjacent to the LERZ include Nanawale Estates, Kaniahiku, Kapoho Beachlots and Kapoho Vacationland. Agricultural subdivisions includ~ Leilani Estates, Lanipuna Gardens, Nanawale Farmlots, Papaya Farmlots, and Chow Farmlots. Within a one mile radius of the proposed SOH 1 site, there are about 61 homes, with at least 54 more in the near vicinity. Within a one mile radius of the proposed SOH 2 site there are at least 78 lots, 26 homes, 57 residents and 19 agricultural enterprises. Within the five majo~ subdivisions that will be most affected, there are 7000 lots, 838 homes, and 2100 residents. (SOH hearing 4/11/89 p. 49, 5/9/89 testimony, p. 60)
The issues of land use compatibility and property values are addressed in following sections.
F. GEOTHERMAL DEVELOPMENT IN THE AREA, ON BALANCE, IS NOT IN THE BEST INTEREST OF THE COUNTY OR THE STATE.
The original evaluation of impacts for the designation of the subzones in 1984 did not go beyond those of 25 MWs of power production for all Big Island geothermal subzone designations. In the court transcript
.t--9
of the MER hearings of 11/13/85, Manabu "" Tagomori of the responded to attorney Kenneth Kupchak~
Q What figures did you establish for needs in the forseeable future for geothermal development?
A The number that we arrived at was 25 MW for that impact study for the social and economic studies.
Q And where did you believe those 25 MW were going to be used?
A I believe that was the number needed for the Island of Hawaii
Q It's your Division's conclusion, that the Big Island electricity needs are fairly stable and that the demand tor geothermal electricity may be somewhat limited on the island, is that right?
Further testimony by Bay Vee responding to questions of Wendell Ing~
representing the Volcano Community Association:·
Q Do you you \AJer,-.-=
consider that there would be much greater difference if to consider a more full scale geothermal development
A The answer would be yes, the difference between 20 and 30 and 250 MW would have an effect.
Q Regarding Circular C-114 on the proposed MER subzone which you reviewed earlier today but you said you did not work on, in terms of that survey of social and economic impact, would you feel that was likewise valid for only up to 20 to 30 MW in your professional opinion?
A Well I think based on the assumptions that were given that Mr. Tagomori gave, that was a two step process and that there would be ample time to look at the effects of these things further on down the line, as I recall, the Act 296 says that this is a process in which this is to be done every 5 years~ the subzones.
SEE ATTACHMENT 3-B
"It was admitted in informational meetings that the economic assessment of geothermal subzones was faulty and the predicted impacts were based on 20-30 MW development scenarios. Yet the subzones are designated so they can accommodate 200-300 MW". (Hawaii Tribune Herald 9/11/84 reprinted from Malama Energy Column, Hawaii Sierra Club newspaper)
.The statement that geothermal development within the subzone will provide additional jobs, was made on page 14 of the Proposal. The Report refuted this assessment one month later by saying ''the overall assessment is that a 20-30 MW power plant will have some economic impact on a statewide and countywide basis, but the impact would probab 1 y not be sign if ica.n t."
1-10
The PGV 25 MW projec{ will require 100 constructi~n jobs some of which will be met by importation of skilled labor from mainland areas. The 23 slated operation and maintenance positions do not represent a substantial economic gain to the district.
Kapoho is considered Hawaii's fruit and flower basket. The displacing of agricultural production and employment is not in the best interest of the County or State. Within a one square mile of the proposed SOH 2 site there are 23 papaya growers with 302.5 acres in production, and an estimated 400 acres lying fallow, six banana growers with approximately 65 acres in production, three macadamia nut orchards, three citrus orchards and several vanda orchid farms. All of these enterprises employ in excess of one hundred people. Much of Kapoho is in papaya cultivation with an employment estimate of one person/three acres. (SOH hearing 4/11/89 p. 62)
In an interview conducted in July 1989 Senator Richard Matsuura agreed with a comment by Senator Andy Levin to the effect that while Puna residents would bear the brunt of any impacts geothermal might have, they would derive little benefit from it, especially if much of the energy generated is exported.
At a recent Renewable Energy Conference in Honolulu~ Dr. Amory Lovins energy consultant for the Colorado based Rocky Mountain Institute, stated that if all the monies the State of Hawaii had spent on geothermal research and development had been spent on conservation on Oahu, 500 MW of electricity could have been saved (HTH 11/12/89). Community estimates of that sum are somewhere between $65 and $70 million.
The subzone designation should have given the developer guidelines and rights to safeguard their investments. Discussion of the acceptance of projects is put off to a later date after substantial investments have been made. These concerns were addressed in the SOH public hearings (4/11/89 Transcript p. 37)~ when the Planning Commission Chair asked, "So they l,•muld h·3.Ve no trouble if a.t the time that they would W<!.<.nt to build a well head (for production) that we would not allow it in area no. 2 (SOH 2)?"
Patrick Takahashi project sta·tes:
( 3/25/89)' Director of HNEI~ in defense of the SOH
"The worry from certain members o·f t.he community, however, <"l.S I understand it, is that if Dr. Olson detects promising evidence, then developers will feel encouraged to drill a production well at a nearby location. I would hope that State and County permitting and approval processes would at that time protect those deserving of consideration . .... a scientific slim hole might well serve to dissuade further drilling in the area indicated. Then the residential and agricultural cr.1mmunity would feel mor-e secure abou.t their ·futLU~e."
The local community concern is that substantial investments are being made before impacts are assessed. Permits are being granted before air standards are adopted and before enforcement and compliance programs are promulgated.
1-11
SECTION 2
BUFFER ZONE
The buffer applicants'
zone is property
defined as the line and any
distance between geothermal activity.
each
The applicants request a 2.5 km (1.5 mile) buffer zone to extend from the boundaries of each property listed in this application to any and all geothermal activity. The buffer zone represents the area of maximum impacts. Noise impacts are likely to be above County standards during mud drilling at 3500 feet. Air quality impacts are l~kely to be greater at 2.5 km based on computer modeling.
SEE ATTACHMENT 2-A
Adding the Geothermal Subzone designation to existing agricultural zones can easily result in geothermal industrial development taking precedence over agricultural and residential usage. Therefore~ the applicants in an effort to protect farmland and residential areas, must have a buffer zone.
In addressing land use compatibility issues, several assumptions were made, including that impacts would be further minimized by the use of buffer zones around geothermal facilities. (C 106,p. 50).
"Development of sites in the Lower East Rift Zones ... may impact existing communities in terms of noise and aesthetics . The provision of a buffer zone will help to mitigate such impacts (C-106,p.54)."
In Puna Geothermal Ventures GRP permit application it is stated that the proposed project will occupy about 5% of the 500 acres leased by the project. The remaining acreage will provide a buffer zone between the project and the residences. Because well pad locations are dispersed throughout the 500 acre project lease, adverse effects would be felt by residents immediately outside of and in proximity to the source of noise and venting emissions with prevailing wind patterns. The Applicant's concern is that well-pad E, the proposed production well site and well-pad F, the proposed reinjection well site are less than 1000 feet from the nearest residences and would provide no buffer zone. The provision of the remainder of the 500 acre project is inadequate to be defined as a buffer zone.
A buffer zone activities and
mLlSt be property
provided between geothermal development lines as detailed in the following text.
PRECEDENCE
Precedence for buffer zones have previously been granted to requesting parties. In the "Environmental Impact Analysis of Potential Geothermal Resource Areas", DLNR Circular C-106, 1984, the assumption was made that "impacts will be further minimized by use of buffer zones surrounding geothermal facilities."
The DLNR drilling regulations provide for a 100'set-back to the parcel property line for discovery, production or injection wells (13-183-69).
2-1
-----·-.--
In delineating ~ne boundaries of the GRS 1~r the Haleakala Southwest Rift, the Makena Resort Property owned by Seibu Hawaii was granted a buffer of more than 2-1/2 miles from the subzone boundary.
The boundaries of the Kapoho Subzone allott~d a 2000' buffer for the Nanawale Forest Reserve.
The Kilauea Middle East Rift Subzone designation provides tor a 2500~ buffer zone to the Kirkendall property at Kaohe Homesteads.
The use of a 2000 foot setback was proposed situated near the Volcanoes National Park, Natural designated Forest Reserves.
fer those areas Area Reserves~ and
The Kahauale'a permit granted to Campbell Estate's True/Mid Pacific application would have allowed the nearest geothermal well to come as close as one fourth mile and the nearest geothermal plant to come as close as one mile of the Volcano National Park boundary. Park officials felt that those distances were inadequate and therefore opposed the project. Their opposition was a major factor in the land exchange between Campbell Estate and the State of Hawaii, resulting in the acquisition of Tract 22~ which provided them a buffer zone greater than one mile from any geothermal development.
In an August 23, 1984 letter to the BLNR from the Planning Director of the County of Hawaii it was noted that 11 a 2000 foot butter zone is proposed for sensitive environmental areas and sensitive forest areas. Is a simi 1 ar buffer being suggested for other 11 sensitive" s:i. tua t:i.CHIS such as residences, farms, recreational areas, wilderness areas, urban Ltses, etc.?"
The September 27 ~ 1984 rep 1 y stated that 11 it has been lSLl<;JgE~stecl
that the appropriate government agency (BLNR for Conservation districts and County Planning Commission for Urban, Rural and Agricultural districts) will conduct its own site specific assessment and implement necessarry buffers on a case-by-case basis •••• In the examination of potential impacts on the existing lifestyle, culture, and community in the area, the use of buffer zones, strategic siting and mitigation measures is expected to eliminate or minimize any adverse effects due to geothermal development."
CONCLUSION
There is no standard buffer zone regarding geothermal development. The applicants pray for a 2.5 km buffer zone as a MINIMUM standard provided by the DLNR~ which is necessary for residential and agricultural pre-existing uses to live compatibly with geothermal exploration and development. A 2.5 km buffer would greatly lessen the conflicts of degradation of air quality , noise, health, agricultural, and property value impacts. Therefore, developers and the community alike would be secure in the knowledge of a pre-determined buffer zone.
2-2
' ,t;/
NOTIFICATION OF SUBZONE DESIGNATION SECTION 3
Notification by publication in a newspaper is not sufficient to notify resident and non-resident property owners that would be directly affected by the designation of geothermal resource subzones. The fact that Chapter 205-5.2 was amended by Act 124, SLH 1986 to include property owners and co-owners through notification by mail within the area proposed for subzone designation and to owners within 1000 feet of the GRS designation substantiates the applicants statement that the statuatory requirements prior were deficient.
·-The notification of property owners as required by Chapter 205-5.2 should now be extended to all property owners who have a right, even after the fact, to be notified of the subzone designation of their interest in property. Non-resident property owners were at a serious disadvantage as they would have been unlikely to have subscribed to the publications in which the notices appeared. Not all residents subscribed to a newspaper of statewide and/or island circulation as well.
SEE ATTACHMENT 3A, 3B
The Department's assessment and designation of GRS areas began with the Geothermal Resources Technical Committee's call for information by a public notice which was printed only in the HSB (printed April 16 & 18~ 1984) and not in any Big Island or Maui newspaper where the intended subzones were being proposed.
No specific plat maps or list of tax map keys had ever accompanied the public hearing notices and procedures that would indicate to landowners their parcel was included in the designation.
An informational and public participation meeting, and a public hearing for the proposed rules and regulations were held in May~ 1984. Maps were shown outlining areas with the most likely prospects for geothermal development. Landowners of these areas were not identified, and proposed boundaries were not to be discussed until the August hearings. Criticism of not having enough notice about the meeting by a Volcano community group was leveled at the DLNR staff. Bob C~uck explained that the Department would try to get the notices about the formal hearings out sooner, but they knew that the hearings would take place in August.
Notice of the May 22, 1984 hearing for the proposed Rules for the designation and regulation of . Geothermal Resource Subzones was published in the Hawaii Tribune Herald and in the Honolulu Star Bulletin on 4/26/84. On May 21, a reminder was published in the HSB colLlmn entitled, "It's Up to YeLl". It was reported that the hea.ring was sparsely attended. Minutes of the Big Island hearing show that 18 persons signed the attendance sheet. "With the e:·:ception of R<~p.
Andy Levin and Nelson Ho all testimonies were general in nature and did not specifically address the proposed rules ••• Rep. Levin's major concerns were in the following areas: (1) suggested we draft rules vdth descriptive language since Act 296 is a pC!or law; (2) ".:wal.iable in formation 11 should provide ·for new and deve 1 oping itl'forma tion; ( 3) the seven criteria for designation should not be applied equally but weighted towards social and environmental concerns." He ·further·
3-1
------···-···- ·-·· ----···--------·· . . ··-····-·-···-·-··-············--·---·······-· ·- ..
remarked that, fhe State's proposed ru. :s and regulations for Geothermal Resource Subzone designations have shortcomings and inconsistencies. Private citizens should be included in those having the right to request withdrawal of an area from subzone designation."
The attached letter from a landowner requesting her land be withdrawn from the proposed subzone, indicated that the enabling legislation did not provide for the type of "spot zoning" requested. In reply the Chairman indicated to the landowner that it would be inappropriate to honor the request.
The Administrative Rules for the Designation and Regulation of GRS, was ~dopted on August 24, 1984. The reply from the DLNR was dated November 19, 1984. Therefore Section 184-10 did allow for landowner initiated withdrawal from the GRS at the time the Board received the landowner's letter of September 28, 1984.
SEE ATTACHMENT 3-C
A second informational meeting was held on May 29, 1984 at the University of Hawaii at Hila Campus Center. Reports on social and environmental impacts were presented as well as economics, geologic hazards, land use compatibility, and patenti~l ·far utilization.
The July 10, 1984 public informational meeting was with the Puna Community Council at the Leilani Estates langhouse to discuss the subzone designation process. The applicants of this proposal were not members of the PCC or the Leilani Estates Community Association or represented by them. This was an informational meeting for a select group and could nat be considered public in the same sense that the informational and participation meetings at the Campus Center were.
On July 18, 1984) a notice of public hearing was published in the Honolulu Star-Bulletin (p. D-12) an the designation and regulation of geothermal resource subzanes, for August 7, 8, and 9 with information relating the time and place. This notice appeared once on that date. There was no such hearing notice published in the Hawaii Tribune Herald far the August hearing dates.
The statuatory requirements for public hearings for the designation and regulation as mandated by Section 205-5.2, the Departments Administrative Rule for the DLNR, Chapter 13-184 amended~ requires that public notices be published on three separate days in a newspaper of general circulation statewide and in the county in which the hearing is to be held.
The notice of public hearing for the August 7, 8, and 9 designation process was not published an three separate days. Furthermore, on August 1, an article was published in the Honolulu Advertiser (p.B-6) which stated. "The Board ne:-:t week wi 11 hold public hec:.~rings on the Proposal as ·a preliminary step to designate the sites as geothermal resource subzanes. The Land Board public hearing schedule will be as fallows:
August 7 August 8 August 8 August 9
?p.m. 9a.m. ?p.m. ?p.m.
Pahoa Schaal Cafeteria Hila State Office Conference Room Hawaii Volcanoes Park Visitor Center Kula Elementary Schaal, Kula, Maui 3-2
After- it had bf:!<, r1 indicated in May that fo""''"!!'al ht~ar-ings would be held in August and wer-e published in a notice of public hear-ing in the Honolulu Star--Bulletin and in an ar-ticle in the Honolulu Adver-tiser- forthe August 7, 8, and 9 dates, the hear-ings wer-e not held. Instead, at a sparsely attended public hearing on August 1 to amend the administrative rules, the hearings were announced rescheduled from August to September 11 and 12, 1984. This was only one week pr-ior to the or-iginally scheduled hear-ings. The r-escheduling notices wer-e published in the Hawaii Tr-ibune Herald and the Honolulu Star--Bulletin just two and thr-ee days befor-e the or-iginal August dates, cr-eating conflict and confusion without adequate timely information.
Notification for- the August 1 hear-ing on r-egulations was published once on July 11, Tr-ibune Herald and the Honolulu Star--Bulletin.
amending the rules and 1984 in both the Hawaii
In the Rules and Regulations pr-oposed by the DLNR in May areas descr-ibed as having "least envir-onmental impact" wer·e to be <::;ubzom-:d for- geother-mal development. That language was changed at the August hear-ing to "areas having an acceptable balance" of the seven critf.=i~i-:,.1
named by Act 296. And instead of social and environmental impacts h.:~ving to be "minimal" in pr-oposed subzoruo::s, the wor-ding was changed to state that social and envir-onmental impacts "need only be consider-ed." Significant impacts on native plants and animals were expected to occur in the pr-oposed areas.
On August 7, 1984, the day the Pahoa hearing was to be held, the BLNR announced the rescheduling in a small article in the Hawaii Tr-ibun~= Her-ald (p. 18) that stated: "The hear-ings, originally scheduled for- August ar-e now scheduled for- 7 p.m. September 11 at the Pahoa Elementary School Cafeter-ia, 9 a.m. September- 12 at the UH Hila Campus Center, and 7 p.m. September- 12 at the Visitor- Center Auditor-ium of the Hawaii Volcanoes 1\la tiona 1 Par-k."
The notification pr-ocess for- the public hear-ing at which t~stimony could be given was not done in a manner- that the public could follow. The PROPOSAL was published for review by the public and to r-eceive comments at the scheduled public hearings. It was published in July, 1984 and summar-ized the results of a statewide assessment of potential r-esource ar-eas. The evaluation of impacts did not adequately assess moderate to significant impacts shown in Figure 7.
SEE ATTACHMENT 13-E
Ther-e was only one standard bordered for-m for- the public hearing notice in the Honolulu Star- Bulletin for- the original August 7, 8 and 9 dates. The August 1 rescheduling for September did not give enough of a cancellation per-iod for the or-iginal August dates. On August 4~ 6, 13, 15, and 21 in the Honolulu-Star- Bulletin and Hawaii Tribune-Herald the notices of rescheduled public hearing were published. The two additional r-escheduling notices above and beyond the thr-ee required may have been an attempt to rectify the situation, but fell shor-t of the need for- an initial clear understanding by the public in regar-d to the for-mal public hearings.
3-3
Over three mofr,hs had passed between ~~e May meetings and the rescheduled public hearings for September 11 and 12, 1984. Landowners were nat identified and property owners could not have determined if indeed they were included in or affected by the proposed subzanes. No list of tax key or plat maps were prepared to assist the landowners in determining if their parcel was included in or adjacent to the subzone area. Boundaries were drawn benchmark to benchmark without regard to existing uses~ subdivisions~ and private property lines.
At the September 12 rescheduled hearing in Hila, the refrain from proponents was that the Big Island should quit studying and get on with development. A statement made at the hearing was that the reason there were not more people speaking against the proposal was that the procedures were so designed to discourage public input, that opponents felt participation was of little purpose. The notification procedures that were allowed to prevail at the time had directly contributed to the lack of public participation, as the hearing notices were conflicting and not timely. The Board was urged by proponents to "proceed as rapidly as possible" in approving the subzones.
On November 17, 1984, only six months from the introduction of the proposal to the people of Hawaii, the BLNR approved three sites for geothermal development on the Big Island including 5,405 acres in the Kamaili section and 5,211 acres in the Kapoho section of the Lower East Rift Zone. On Maui, the Haleakala Southwest Rift Zone subzone was approved, though it's boundaries were changed to accomodate Seibu Hawaii, a resort development.
The public hearing notification procedure employed in the Geothermal Resource Subzone designation process was conflicting, inadequate, not proceeded with in a timely manner, created confusion, and did not serve the interests of the resident and non-resident property owners within and adjacent to the subzone designated areas. This situation could be rectified by retroactively notifying by mail all property owners as mandated by Chapter 205-5.2, and declare a moritorium on further exploration, development, and permitting until public hearing procedures have been re-opened to satisfy legal remedies to landowners.
3-4
DATE PUBLISHED DATE ~aBMITTED PUBLICATION FORM ~~ NOTIFICATION PURPOSE
Apr-il 16 Apr-il 10,1984 HSB Public .Notice, (1ssist in and 18,1984 r-equest for- assessment
wr-itten info by May 21
!"'lay 4' 1984 Apr-il ~JO, 1984 HTH Notice of F'Ltblic Discus~:;
for- May 29 In for-ma. tiona 1 Su.bzone Meeting Desiqnc.'l.tion
1"1ay 22,1984 May 21,1984 HSB Its Up To You F\ev iew pr-opo' for May ~,.,
.,;,..,:... Column Rules and F~ei_
July .10,1984 July 10 ·for HTH Volcano Views Puna Communi July 10,1984 Column Council 1'1E·et
July 11,1984 July 11 for- HSB Notice of Public Amend Rules ALtg. 1' 1984 Hearing Regulations
July 11,1984 ,July 6 for- HTH Notice of Public Amend Rul ~=s Aug.1,1984 Hearing F\egLtlations
,July 18 July 12 for HSB 1\lotice of Public SLtbzone Desi' for Aug 7,8, Hear-ing nation and 9
August 4,6,13 Aug.2 for HSB Notice of Resched- SLtbzone Desi 15 and 21 Sept.10,11,12 Ltled Hear-ing nation
1984
August. 5,6,13 Aug.2 for HTH Notice of Resched- SLtbzone Desi• 15 and 21 Sept.10,11,12 Ltled Hear·ing n<:.\ tion
1984
November- 17, HSB,HA Ar-ticle Subzones 1984 Appr-oved
3-5
-~----~---~---- ----~ -----~---~- --~---------------
SECTION 4 AIR QUALITY IMPACTS
The F~epor-t ( F'. 37) states th.::-1. t "geother-ma 1 deve 1 opmen ts in Ho:\wai i w.i 11 be r-equired to have abatement systems that meet the pr-oposed State Depar-tment of Health air- quality standar-ds''. Yet no standards for H2S have ever been adopted and the pr-oposed ambient air quality standard of 139 ug/m3 (0.10 ppm) is geared for developer's criter-ia r-ather than concern for health effects. Under- the minimum requirements of pr-esent law, the ATC does not r-equir-e H2S emissions to be regulated by the DOH~ and the per-mit can be issued without abatement conditions. ~rhe Califor-nia Ambient Air- Quality Standar-d is 42 ug/m3 (0.03 ppm). This is inter-pr-eted as an exceed of the standar-d if the concentr-ation exceeds 25 ppb.
Dr-. Wilson Goddar-d, consultant to the Kapoho Community Association, r-epor-b?d that .• "Since the Puna geother-ma 1 r-esoLtr-ce has a. hyd,~ogen sulfidE?. concentr-ation of 1300 ppm which aver-ages 6 times higher- than the Geysers aver-age and the ar-ea is one of extr-eme geological instability~ health and safety r-isks due to hydr-ogen sulfide air- emissions ar-e substantially incr-eased for- the local r-esidents. Our- emphasis in the following findings is to show that the PGV pr-oposals ar-e not accepted and demonstr-ated BACT."
SEE APPENDIX A-6
In the PROPOSAL, the gener-al impacts would be in the areas of AirQuality (smell) and aesthetics (visual). These impacts ar-e expected to be moder-ate.
Air- quality involves much mor-e than jLtst "smell" of Hydr-ocJEHI SLtlfidc:=. Environmental r-isks ar-e also due to atmospher-ic emissions of non-condensable gases fr-om the development and oper-ation of geothermal wells and power- plants. Hydr-ogen Sulfide and par-ticulate sulphate from the atmospher-ic oxidation of Hydr-ogen sulfide, benzene, mer-cury and r-adon ar-e consider-ed to be the mor-e significant non-condensing gases fr-om a health standpoint. (C-106,pp 15-16)
Exposur-e to atmospher-ic concentr-ations of these chemicals pose potential hazar-ds to the public and occupational health to wor-ker-s. In addition, exposur-e to H28 and toxic chemicals contained in abatement systems also pose an occupational hazar-d for- health. (C-106~p 16)
Air quality can be related to the specific development procedur-es that occur at the project site:
a) INADVERTENT RELEASES DURING DRILLING
Episodes of steam, unabated, occur- as a r-esult of r-eser-voir- pr-essur-e over-coming the pr-essur-e of the dr-illing mud and will be allowed for a 10 minute dur-ation without the benefit of favor-able windspeed factor-s taken into consider-ation. The PGV pr-oject application claims this will pr-oduce H2S emissions of 7 lbs or- less dur-ing any one event (PGV GRP Amendment p. 3-19). But if a well is found to have 120 lbs/hr- H2S, a 10 minute r-elease could emit 20 lbs/event and exceed pr-oposed air- quality standar-ds.
ADVERTENT RELEASES DURING DRILLING.
Rig test #5 of the KS-1 well (11/10/81, 7290') was conducted with well 4-1
shut in "Passed achieved 1983) :
and r-emote actuator- for- 10" Ser-ies 600 master- v.::\lve r·igged u.p. maximum tr-ansient wellhead condition of 1129 psig and 567 F and stabilized flow rates as follows (Well Activity Summary~
Time(Hour-s) 1655
Total Mass Flow Rate(lbs/hr-) 15.1,000
WHP(psig) 947 645 181
WHT(F) 546 500 :::::c;::::;
17.14 199,100 1745 242,000
"Flow was stable without ·fluid sur-ges The PGV application does not addr-ess emissions can only be estimated to be with flow r-ate of 242,000 lb/hr-.
b) WELL BLEEDS/FLARING.
or- r-ock." these adver-tent r-eleases~ and thus up to 320 lb/hr- H2S when unabated,
Valve pr-essures would have to be per-iodically r-eleased by the bleeding of the valve or- the bur-ning of the gas cap on any well held on standby until the meteor-ological conditions are considered favor-able for- the venting of the well bor-e. The burning pr-ocedure produces sulfurdio>:ide gas.
c) UNABATED VENTING.
Unabated venting of the well bor-e emits a 1000 foot plume of fluid and steam dir-ectly into the atmospher-e for a per-iod of four- hour-s or more when meteor-ological conditions are expected to be favorable. The PGV pr-oduction wells are expected to pr-oduce 55,000 - 90,000 lbs/hr- of steam at a pr-essur-e of 200 psig and te~per-atur-e of 387F at the wellhead, as well as 14,000 - 22,000 lbs/hr- of br-ine, with 50- 120 lbs/hr- H2S. At full flow venting the maximum emissions would then be be 120 lbs/hr- of H2S plus an undeter-mined amount of ether chemical emissions for each of the pr-edicted four- hour-s of venting.
The Ther-mal Power- EIS 1987 (p. 5-16) states that ''two per-iods of up to 4 hour-s each ar-e u~ually necessar-y for- well venting. H2S emissions cannot be contr-olled and ar-e estimated at 292.5 lb/hr-, based on 150,000 lb/hr steam flow and 1950 ppm(w) steam H2S cocentr-ation. H2S emission rates during well venting ar-e specifically exempted fr-om meeting the proposed State emission limits, pr-ovided the State Dir-ector- of Health is in·for-med and the public is notified."
This specific exemption still constitutes a health and nuisance hazard.
UNCONTROLLED EMISSIONS
Uncontr-olled Emissions/Wells caused by blowouts can dischar-ge steam and associated pollutants at r-ates equivalent to full pr-oduction levels (55,000 and mor-e lb/hr- steam) with no abatement. At pr-esent a wild well near- PG&E units #5&6 at the Geyser-s Wild Hor-se ar-ea emits some 306,000 lb/yr- H2S or- 8.2% of the Geyser's total (WFF 1987, p. 6-38)
COMPUTER MODELING
Impacts of H2S and particulate matter from the pr-oposed PGV pr-oject wer-e assessed using the EPA dispersion model COMPLEX I. The Complex Ter-rain Team at the Chicago Workshop en Air- Quality Models, February
4-2
1980, formulated the COMPLEX I air quality dispersion model (PGV ATC PP p. III-7).
According to the PGV ATC application (p. IV-4, Power Plant), the conclusion given in the COMPLEX I report (AMI, 1989) results for well venting and pipeline cleanout estimated unacceptably high H2S concentrations during stable nightime conditions and low wind speeds at distant receptors with relatively high elevations (2 to 2.5 km west-southwest of the plant). For wellpad E this resulted in a maximum concentration of 336 ug/m3 H2S, 47.8 ug/m3 PM, and 95.7 ug/m3 TSP in Leilani Estates near the intersection of Kahukai/Alapai/Mcku streets. With moderate windspeeds (>4 m/s) and daytime stability classes (A-D), the highest concentrations were much lower and occurred at lower terrain near the east property boundary. This resulted in a concentration of 77 ug/m3 H2S, 11.0 ug/m3 PM, and 22.0 ug/m3 TSP in Pohoiki Bay Estates.
SEE ATTACHMENT 2-A
The Industrial Source Complex Short Term ISCST model was used to assess contributions to ambient concentrations in low terrain near the PGV property boundary. ISCST is suitable for terrain with elevations below the lowest emission height.
The ISCST modeling, with a 1 m/s windspeed and stability class F (stable), resulted in a maximum 1 hour average H2S concentration of 235.8 ug/m3 (170 ppb) at a distance of 2.4 km (2 km east from moisture
separator) from wellpad E, in the Oneloa area. When restricted to daytime stability class C (slightly unstable) and windspeeds at 5.8 m/s, the highest 1 hour H2S concentration from wellpad E venting was 120.4 ug/m3 (86 ppb) and occurred at a distance of 0.6 km (1 km SSE from moisture separator) from wellpad E, about the middle of S. Hinalo Street in Lanipuna Gardens.
''In the case of sources that operated for periods less than 24 hours, the impact (for COMPLEX I) was estimated by dividing the 1-hour estimate by an appropriate factor. For example, for well venting, which is anticipated to occur for periods of no more than 4 hours, the 1-hour maximum estimate was divided by six to provide an estimate of the maximum 24-hour average'' (PGV ATC Power Plant p. II-1).
These computer models were used to estimate maximum concentrations from wellpad E and F activities using meteorological data from the Woods station for October 1982 to September 1983 and show unacceptably high concentrations within 2.5 km of the source during worst case scenarios.
d) WELL TESTING
The emissions of H2S during well testing periods, even with abatement to 95% of 120 lb/hr H2S (1300 ppm H2S in well flow rate of 55-90,000 lb/hr) will be substantial, up to 6 lbs for each hour the well is tested. In the PGV EIS (1987, p.5-18) flow testing estimated emissions per well equal 14.6 lb/hr (1.84 g/s, 47 ug/m3, 0.034 ppmw), based on 1950 ppm H2S and 150,000 lb/hr well.
In the application for PGV a period of 20 days is slated for the well testing period, continuously or intermittently. During well testing~
4-3
------------ ----------------------------------·
meteorological conditions are less controllable , as indicated in the EAL Corp. Technical Progress Report 5/1/82 - 6/30/82 Hawaii Geothermal Generator Project, when windspeeds were recorded between 2 to 5 m during the Thermal Power KS2 flow test in 4/82. The HGP-A well was flow tested for approximately 40 days at its maximum run.
The KS-1 flow test of 8/4-6/82 resulted in an average total mass flow of 250,000 lb/hr using the James Method, and was not stabilized since the testing was restricted to daylight hours only.
e) PIPELINE CLEANOUT.
Prior to the start up of the power plant, the steam gathering system must be cleaned out which is accomplished by passing the steam from wells through the pipeline and venting it unabated directly to the atmosphere.
The Thermal Power EIS p. 5-25 states that total suspended particulates will be 43.1 lb/hr, and H2S will be 292.5 lb/hr during pipeline cleanout at one hour per pipeline, with a wellfield containing 6 pipeline headers and will require cleanouts totalling 6 hours. Cleanouts occur prior to completion of the wellfield distribution system and are exempted from proposed H2S standards.
The PGV Application Amendment, p. 3-29, states that approximately 3000' of pipeline corridor will be needed to connect the 6 wellpads to power plant site. The PGV ATC application states that pipeline cleanout impacts increase with higher wind speed because of effects on plume rise. Impacts are more sensitive to wind speed effects on plume rise than are well venting because of very low simulated emission height for pipeline cleanout.
Pipeline cleanout is expected to occur during favorable meteorological conditions with windspeed greater than 4 m/s. The PGV plant will need approximately 675,000 lbs/hr of steam to produce 28 MW of electricity. It this total amount of steam were put on line to the plant at the same time, emissions could exceed 375 lbs/hr H2S. The PGV ATC P.P.(p. III-1) ~;tates · that "the estimated H2S emission rate is 195 lb/hr (24.6 g/!:;), .:md the time per event is appro:-:imately 1/2 hour."
f) ISOPENTANE
The maximum release from conditions is expected to isopentane, one third of emissions from mechanical gal/year, not to exceed 0.4
an Ormat Energy Convertor unit during upset be 2500 lbs of the working fluid,
the contents of the DEC unit. Fugitive seals on each DEC unit will be 60 lb/h~ total from all DEC units (9.6 lb/day)
The American Lung Association (November 15, 1989), questioned the DOH proposed ATC permit stating ''other documents in the docket (ATC A-834), specifically, the air permits from Imperial County, California, for apparently similar plants built by the same applicant were limited to 7-8 lb/da total. Should not Hawaii be imposing equally stringent emission limitations?"
Pentane is not a criteria pollutant and no significance has been extablished for it.
4-4
g) UPSET OF OPERATIONS
During operational upset, such as a failure of the electrical transmission line(s) out of the power plant. or some incident, such as an an electrical outage, that tripped all the steam turbines and DEC units (eg. December 11, 1988), or a complete upset of the geothermal fluid injection system, or if pressure in the steam lines exceeded design set points, steam would be released through the steam release facility. When the entire power plant is shut down, this emergency steam release facility will be used to release steam, treated with sodium hydroxide (NaOH) to remove 96% H2S through a rock muffler (for ~noise abatement) while the wellfield production rate is being reduced to 50% full flow. After this reduction, the power plant will emit less that 2% of full flow uncontrolled H2S (98%) until normal operation is resumed. At 96% abatement of full flow up to 4.8 lbs/hr/well or 52 ppm (5200 ppb) H2S plus up to 100% of all other emissions would be released, possibly during the worst meteorological conditions such as those during Dept. of Health's burning bans and possibly during volcanic eruption periods. At 50% full flow H2S would be emitted at up to 2.4 lbs/hr/well.
SEE ATTACHMENT 1-A
METEOROLOGICAL CONDITIONS
Meteorological considerations in the Report include that the winds in the Hawaiian Islands are very important in geothermal operations because of their effect on emissions and noise. Yet the daily records of wind direction and windspeed from the weather station at Cape Kumukahi in Kapoho were never tabulated or utilized in making more accurate wind predictions. Temperature inversion measurements have not been taken for site-specific data. The analysis for wind direction for the Report was based on the few wind summaries along the rift zone and interpolation drawn from existing data collected on other parts of the island. Due to the limited amount of available data, earlier written articles were also utilized in the study of the wind patterns over the rift zone.
(C-106 p. ix) While tradewinds are prevalent, both tradewind temperature inversions and ground temperature inversions affect the movement of air in and over the GRS. Climatological elements deemed important in geothermal rift zones include rainfall, temperature, winds, trade wind inversions, and ground temperature inversions. (WFF) The distribution of atmospheric pollutants from their sources to the receptor areas and their paths of travel and concentration are dependent on the wind flow regime and the pollutants vertical and horizontal dispersion-- depends on state of atmospheric stability.
Meteorological conditions may not be guaranteed safe for the duration of the 4 hour period of open venting. Geothermal developers in the PGV mediation sessions for the Geothermal Resource Permit application identified the need to vent to clean the well bore within two weeks of completion of the drilling phase, compromising the BEST meteorological conditions. Although the PGV ATC application's modeling assessment by Neal (1989) states that the best windspeeds for well cleanout venting are in excess of 8 m/s (18 mph), the highest one hour average windspeed encountered at the Woods meteorological station in Kapoho was 6.7 m/s (15 mph) in 1982-1983.
4-5
HEALTH IMPACTS
Health complaints registered with the Hawaii County Planning Department from residents near the HGPA and Thermal Power wells have consisted of:
burning nasal passages mucous discharges of eyes, nose constant headaches burning eyes screaming noise bronchitis respiratory problems asthma attacks ear infections burning rubber smell
In response to the Kahauale'a EIS, Dr. Janette Sherman, physician and member of the EPA Advisory Committee for the Toxic Substances Control Act, addressed chemicals that will be present in the ambient air, including mercury, arsenic, selenium, H2S, hydrogen selenite, and sulphur dio:·:ide. "Because of the e>:istence of at least two known carcinogens, arsenic and selenium, as well as a co-carcinogen, sulphur dioxide, I conclude that within a reasonable degree of medical certainty that there will be an increased risk of cancer to most workers and residents of the area ..•. There will be adverse health effects to workers and residents in the area , including effects to the central nervous system, respiratory system, gastro-intestinal system, kidneys, peripheral nerves, etc. (with) ... effects augumented on the following groups:
Children The elderly People already sick with a variety of chronic diseases Pregnant women Men anticipating fathering children."
SEE APPENDIX B-2
SPECIFIC CHEMICALS OF CONCERN
The following are some of the chemical components present in the brine, condensate and non-condensable gases in the Hawaii reservoir.
SEE APPENDIX A-5
The Draft EIR of the West Ford Flat Power Plant Project prepared for the County of Lake, California, in 12/87, outlines that environmental health effects of air pollutants are determined by the concentration to which the individual is exposed, individual susceptibility, the mixture of compounds, and the duration of exposure. (p. 6-28}
HYDROGEN SULFIDE
Emission effects vary by age groups. Those with enhanced sensitivity to H2S poisoning are those with eye or respiratory tract problems or anemia, those who have consumed alcohol within 24 hours of exposure, those who have psychiatric problems, infants, and those who have been previously exposed to H2S.
The level and frequency of odor which would annoy individuals varies, and it is often not only the concentration level but the change in concentration which arouses public intolerance.
4-6
Layton et al 1981 concludes that an ambient level of 0.03 ppm (30 ppb) hourly average (6x higher than the instantaneous threshhold value) would result in odor nuisance problems, partly because elevated excursions during an hour could be particularly annoying.
ACID RAIN H2S sulfur- compoLtnd reaction time about 18 h(::>urs.
releases in geothermal steam may increase atmospheric levels (mostly sulfate) associated with acid rains. The in the atmosphere of H2S to 802 has been estimated at
ODOR THRESHHOLD .0081ppm (Amore et al 1983); increased ~eurasthenic effects (fatigue, dizziness, nausea) with long term exposure above 0.1 ppm. Eye irritation threshhold at 10 ppm. Inhalation irritation threshhold 50-100 ppm. Sense of smell stops 1~0 ppm. Fatal 700 ppm. Damage to sensitive plants more than 0.30 ppm (Thompson, 1976); 40 ppm for 5 hours (McCallan et al 1936).
SEE ATTACHMENT 4-A Health Effects of H2S on Humans
CARBON DIOXIDE
C02-- Carbon Dioxide 2% in air can stimulate human respiration. Not considered hazardous when adequate oxygen present. Odor threshhold 74,000 ppm (Amoore et al 1983)
NITROGEN
N2-- Nitrogen- no known hazard from its increased presence in ambient
SULFUR DIOXIDE
802-- Sulfur Dioxide- annual concentrations of 0.05 ppm (130 ug/m3) lead to increased frequency of respiratory illness. The threshhold for increased chronic bronchitis in adults and increased acute lower respiratory disease in children is 95- 200 ug/m3 (Amoore et al 1983). Irritation threshhold more than 3ppm (Case et al 1977); increased airway resistance in humans and other animals 1-10 ppm (2600-26,000 ug/m3). More than 400 ppm caused death; 0.3 ppm for 8 hours is toxic to plants (Gauch, et al 1954).
It is now known that the conversion of H2S to 502 occurs in 12-18 hours. Because of limited dilution and dispersion due to meteorological conditions, this conversion can produce more immediate effects than previously thought. Therefore, under the wet conditions and high incidence of rainfall in the Puna District, S02 would precipitate before the prevailing winds would take the H2S out to sea.
See also "Adverse Effects on Agriculture"
ARSENIC
AS-- Arsenic- All forms of arsenic are toxic at various levels; some are potentially carcinogenic (Lee and Fraumeni, 1969; Tseng et al 1968; Sander 1975; NIOSH 1975). Arsenic compounds are known to be corrosive to skin and are identified as a carcinogen. Prolonged contact can cause skin irritation, with mucous membranes the more sensitive to irritation. Fluids containing arsenic levels of 5 mg/1 are considered toxic. Odor threshhold 0.50 ppm. The fatal dose is 70-180 ug/m3.
4-7
The presence of arsenic in geothermal fluids can cause negative health effects including skin cancer if fluids are allowed to contaminate surface or groundwaters (C-106~ p. 26). Unlined sump ponds are proposed to contain the 45 gal/min flow rate during well testing.
BORON
8--boron- Data related to humans are limited. Several forms of boron are irritants to skin and mucouse membranes. Boron particulate fallout damages plants (malloch et al 1976; Sharp 1976). Irrigation water with 10-100 ppm boron content is to:·:ic to plants. See "f~dverse Effects on
·-(4gricul tLtre". MERCURY
Hg--mercury- The human lung absorbs 75-85 % at concentrations. Inhalation produces many adverse effects. Mercury may also be absorbed through the skin or by ingestion. Elimination is slow, resulting in long term effects which are only partially reversible. Children appear to be especially susceptible. Methylmercury (Ch3Hg+), the most toxic form, may cause growth deformities. Inhalation of 100 ug/m3 can cause chronic mercury poisoning;of 1200 8500 ug/m3 can cause acute poisoning. Occupation exposure to 10-30 ug/m3 of elemental mercury may cause slight anemia, hupothyroidism, and increased excitability. Prolonged exposure may cause neurologic disorders. Mercury is toxic to plants in the ppb range over several days.
The ambient level of mercury, whether in the oxidized form or in reduced form, is high at all areas where there are surface volcanic manifestations in Hawaii. During flashing at HGP-A, the airborne mercury content varied from 7 to 18.8 ug/m3 (Humme et al, 1979).
(C-106 p.24) Mercury concentrations in the East Rift zone are regulated by the inflow of trade winds from the ocean where mercury l~vels are low. (p.3-82 PGV application) All mercury in the brine is emitted with the steam Hg= 0.001 - <0.05 ppmw brine content (PGV p. 3-24)
The Army Corps of Engineers in response to the EIS for the Hawaii Geothermal Project (February 24~ 1978) stated: "There is only brie·f mention in the Environmental Setting portion of the EIS regarding the ambient atmospheric mercury levels in the Puna rift zone. We feel that this existing condition, unrelated to the geothermal well, may create a significant health hazard and may make the area an undesirable location tor prolonged human occupation. Any increase in mercury levels as a result of well operation may increase the hazard, regardless of the extent to which ambient levels fluctuate naturally. Considered together with the recency of lava flows in the area, it is clear that the risks associated with geothermal development and associated population growth in Puna should be stated clearly and evaluated."
RADON 222
Radon-222 -- Adverse health effects, including lung cancer~ may result from inhalation of Radon-222 and its short-lived, alpha-particle emitting daughters (BEIR, 1972). There is at present no known level of exposure to radiation below which NO biological damage occurs (Kester~ 1980). High radon emissions are associated with volcanic and geothermal development areas (C-106 p.30)
4-8
liadon 222 is 749-3010 pci/1
present in steam portion of the fluid in amounts from (PGV, 1987), steam flow rate of 90,000 lbs/hour.
SULPHATES
Sulphates-- 804- Taste/odor threshold 700 ug/m3. Irritation threshold 350-2000 ug/m3. 10-3000 ug/m3 can cause illness. Brief exposure to 700-5000 ug/m3 sulfuric acid mist (H2S04) resulted in increased airway resistance. (WFF 1987 p. 6-32)
PARTICULATE MATTER
Particulate Matter -- TSP- The health effects of suspended particulate rna tter depends on partie le size and chemical compostion. "No e:.'"l' fee: ts" threshold 100 ug/m3. Morbidity threshold 300-375 ug/m3. Mortality threshold 200-750 ug/m3. Particles larger than 0.5-2 um diameter are usually trapped in the upper respiratory system and cleared in a few minutes. Smaller particles may remain in the body for months or years (Case et all 1977). Epidemiological studies suggest that the inhalation of particulate sulfates rather than sulfur dioxide is a primary source of risk associated with long term, low level exposure to polluted air.
CUMULATIVE EMISSIONS
In the absence of volcanic activity, sulfur dioxide values are low. However, during an eruption, concentrations due to volcanic activity can exceed human health and plant impact values for days at a time (c-106 p. 20) •
Elementary mercury mercury content of (c-106, p. 21)
vapor was measured and an increase in particulate samples of the January 1983 eruption was noted.
The impact of volcanic emissions on the atmospheric radon content were seen by noting the higher values measured at the site closest to the eruptions at Kahauale'a. High radon emissions are associated with volcanic and geothermal development areas (c-106, p.29).
Sulfate particulate material and under certain conditions, heavy metals contained in particulate matter can be related to volcanic emissions (c-106 p. 28).
Geot~lermal
created by center at activity in 1983.
development would compound the adverse air impacts that are volcanic activity in the East Rift Zone. The information
the Hawaii Volcanoes National Park states that eruption the east rift zone has been constant since January 3,
CONCLUSION
Consideration must be given to the effect of the natural volcanic emissions in conjunction with emissions from development projects. This has not been adequately assessed in terms of overall air quality degradation. Numerous burning bans have been issued on the Big Island since the eruption of Puu 0'0 began on January 3, 1982, indicating that unfavorable wind dispersion conditions with scheduled or unscheduled venting would create severe air impacts. Computer modeling for PGV conclude unacceptably high concentrations of emissions within 2.4 km
4-9
... -------~------
of the project. Well field development activities such as venting and pipeline clean-out will exceed proposed ambient air standards. Off-line time with abated venting through the rock muffler may be substantial~ depending on the ability and future scheduling of the utility company to upgrade the electrical transmission system.
4-10
SECTION 5 NOISE IMPACTS
Noise is a major concern to residents within and adjacent to the geothermal resource subzones containing planned residential and agricultural subdivisions. In the Report's discussion of the Kapoho Section boLtndar ies, the western boundary abuts Lei 1 ani, "a spar-se 1 y populated subdivision''. In 1989 there was an estimated population of 800 people, according to the May estimate from the Leilani Community Association. By Puna standards, this is not a sparsely populated subdivision anymore.
~The Report (p. 16)states that During the initial phases of field development, persons in the immediate vicinity of a geothermal site may be exposed to noise levels varying from 40-125 decibels, depending on the distance from the well site. High noise levels are produced during well drilling, production testing~ and bleeding. Drill rig noises vary from 60-98 decibels with a muffler. Initial venting noise varies from 90 to 125 decibels which may be mitigated using a stack pipe insulator or cyclone muffler. Periodic operation venting noise is about 50 decibels using a pumice filled muffler. While most operations can be effectively muffled by acoustical baffleing and rock mufflers~ some emit unavoidable noise (Pg. 16 Report). Noise levels will vary with weather conditions and topography (Pg. 17 Report).
During well testing of the Kapoho State 1 Well Activity Summary 1983, "noise levels from the twin cyclone silencer e>:ce(?ded nighttime environmental limits •••• This type of system is designed for a liquid dominated resource."
Technology exists, including shut down time and use of cyclonic separators for drill rigs, which should abate noise to acceptable levels. The SOH and PGV projects propose to drill 24 hours a day with the explanation that the well's integrity would be compromised by evening shut down, and so would not be feasible.
Drilling logs of the seven deep wells show that shut down times can be used to mitigate noise impacts:
Completion Date
HGP-A 6/22/76 HGP-A well
vJork.over 10/18/79 Ashida 1 10/29/80 Lanipuna 1 5/25/81 KS-1 11/12/81
KS-2 4/2/82 LanipLtna 1 sidetrack 6/21/83
Lanipuna 6 6/1/84 KS-1A 9/3/85
Drilling Depth Days NA 6455'
32 <99 8300'
<105 8048' 65 729(1'
56 8005'
24 6271' <101 4956'
58 6505'
Shut down time
2 week holiday~ 11 days intermittent
1 weekend all weekends some weekends nights to 102', weekends
to 915' weekends to 1315'
all weekends N.A. Repair of rig 3 days
In May of 1981, a seven day week for drilling was approved by the Hawaii County Planning Commission based on information from developers that five day a week drilling is riskier and more costly.
SEE ATTACHMENT 5-A 5-1
........ ·-···--·--···· ............................... --~- ..................... -·-·· ........................... _____________ .
In i='GVs well-bore cyclonic as the of the
pr-opos~· 25 1'1W pr-oj ec '1:, noise "'~batement technology for venting periods has not been found to be practical. The
separ-ator- which is BACT, was not considered to be pr-actical, erosion of it's pipes had occur-r-ed as a r-esul'l: of the velocity venting of the par-ticulates fr-om the well bore.
In a letter- fr-om Thermal Power- Co to the Planning Dir-ector- (August 1985) it was stated that:
The attempt to "modify the steam collection and test abatement equipment" was a conceptual rather than a physical/mechanical one •••• The "research" conducted in evaluation alternatives to verticle venting consisted of a series of in-house discussions. As indicated previously, the three alternatives ultimately considered were 1) redundant capacity, 2) reduced flow, and 3) modified venting •••• There was and is no formal analytical laboratory type of report.
'::·~· .......... '
The County of Hawaii Planning Depar-tment has issued a set of noise guidelines to pr-ovide proper- contr-ol and monitor-ing of geother-mal-r-elated noise impacts with str-icter- standar-ds than those prevailing for Oahu and State-wide. These were based on lower existing ambient noise levels for- the island of Oahu. (Pg. 28 Repor-t)
The County of Hawaii geothermal noise guidelines state that a gener-al noise level of 55 dBA dur-ing the daytime and 45 at night may not be exceeded at existing r-esidential r-eceptor-s which may be impacted. (P.17 report) The r-eport assumes that the geother-mal development activities pr-oposed within the designated GRS would follow these guidelines therefor-e noise impacts would not be of concern.
However-, in the Mediator's Report for PGVs 25 MW project, August 21, 1989 (P. 53) County noise level guidelines will be waived for-noise emissions dur-ing the dr-illing of wellpads E and F because the developer-, Puna Geothermal Ventures, has stated that they will not be able to meet these guidelines at these points.
In the Proposal, Figure 7 on page 12 omitted noise as a basis of evaluation for significant impacts for- the Lower East Rift Zone.
Dur-ing the mediation sessions for- both the SOH and PGV applications noise was a major concern. The subject r-equir-ed a considerable amount of time r-elative to other issues to be mediated.
The Rr:!port and Proposal in 1984, which stated tha·t "advanced technology in geothermal r-eser-voir- development such as emission contr-ol systems reduces the concer-ns for- pL!bl ic health and sa·fety in the Kilauea LEf\:Z" (p.xi), was not adequate at the time to assess the effects of noise level impacts to r-esidents within and adjacent to the Kapoho GRS.
Subsequent information made available thr-ough PGVs 25 MW permit application for a development project indicate that noise is indeed a significant impact for evaluation. County Guidelines cannot be met and the technology that exists to mitigate noise cannot be practically utilized in the Hawaii development field within the Kapoho section of Lower East Rift Zone Subzone.
5-2
SECTION 6 GROUNDWATER IMPACTS
Two Pahoa battery wells, drilled in 1960 and 1963 with chlorides of 2-27 ppm, supply 566 customers (June 1989), with a 900,000 gal/day normal capacity and a 2 million gal/day maximum capacity.
The Kapoho Crater well system at elevation 38' supplies the Kapoho Beach Lots and Kapoho Vacationland farmlots subdivisions. Green Lake, located inside the Crater appears to be in the East Rift Zone dike confined water complex, plus an aquifer perched on ash beds. The present well qualifies under Federal and State potability
··requirements.
The Allison well and the Kapoho Airstrip well have been irregularly used~ but have potential for providing irrigation water to the adjacent agricultural lands. Both wells have good irrigation quality and borderline potability quality. The Malama Ki well was drilled to provide irrigation for the UH Experiment Station where crop production tests are conducted. This well was found to have chlorides in the 2200-6600 ppm range and thus is not in use.
Studies being conducted Coordinating Committee at most crops tolerate 500 2600 ppm with no adverse
under direction of the Governor's Ag Kapua Farms on the Big Island show that ppm and some crops tolerate chlorides up to
effects.
THERE IS SIGNIFICANT POTENTIAL FOR CONTAMINATION BY GEOTHERMAL DEVELOPMENT OF THE GROUNDWATER RESOURCE.
"BecaLtse of difficLtlties in identifying production well failure, the potential for adversely impacting associated ground-water systems is relatively high. Failure of a well casing can range from a minor fracture to a complete collapse. Discharge can be very limited or can constitute the total flow of the well, resulting in ~ blowout condition. Indications of casing failure can be as obvious as a visual discharge at the surface or as subtle as a change in the chemical constitutents of the fluid. Other indicators of casing failure include a reduction in flow or temperature, change in the steam/water ratio, or inclusion of sand or other formation material in the production fluid. Failure of the cement between the casing and the formation is usually associated with casing failures. This can allow the geothermal fluid to migrate along the well bore and enter a formation different from that in which the original failure occurred.''(Miller et al 1982)
SEE ATTACHMENT 6-A
Casing failures have already been reported at the KS-1, KS-2, and HGPA wells. Kapoho State 1, located at wellpad A, has casing leaks at 670' (groundwater table), 900-940', 1040-1080', parted casing from 226-233', and a split casing from 362-363'. Kapoho State 2, located at wellpad B, has a casing leak at 1040-1050'. HGPA was found to have cement bond failures and a gas cap forming while the well was suspended and a workover of the well was done in 1979 to secure the casing, resulting in an over 80% bonding.
The DLNR Circular C-106 states that "groLmdwater will not be advei~sely affected because geothermal wells are drilled past the ground water
6-1
aqui·fer throw] h
and ir1"'·"' addition, surface c.:H:;inr~·"" wi 11 a competent subsurface formation below the
be set and cemented basal lens."
However, the competent fqrmation may not exist. The HGPA Well Completion Report of september 1976 states that ''the highly fracturud character of most of the cores is noteworthy. Even cores that appear quite solid as they emerge from the core barrel may fall apart on handling. This characteristic was worrisome during drilling, because of the possibility that the fractured material might cave into the hole, and the caving possibility remains, particularly after the mud is removed from the hole."
·-ThE~ proposed injection site at Well pad F, with its "optim<:d drilling targets" will most likely be directed toward Lanipuna 6, drilled in 1984 by Barnwell Industries. The drilling history and geology of L-6 (Geothermex, 1984) is a series of continual lost circulation zones, 11 cement plug backs, and two unintentional sidetracks, one at 1460' and one at 1763' which persisted even with plug backs. This well was spudded on 2/22/84 and shut in and suspended on 9/20/84, drilled to a total depth of 4956' with total lost circulation at 4340'.
The drilling history of L-6 indicates numerous lava tubes exist in that underlying strata, tubes that from an industry standpoint appear to provide economical and technological injection capabilities, but from a regulatory standpoint pose many problems with monitoring of the effluent. The lost circulation zones are areas of stress in cement bonds of the casings.
The Drilling Log of the KS-1 well located at wellpad A records lost circulation zone in the groundwater from 706- 1226' after many repeated attempts with mud and LCM. "Received permission from State of Hawaii representative to forgo running logs due to LC conditions; ran 13-3/8" cc::\sing." This well is currently shut in and has a cE..::ment pluq at 1750'. The KS-1 has only a 2 string casing. The KS--1A well drilled in 1985 has a 3 string casing, a design improvement incorporated for reasons of safety to help prevent well blow outs and casing failures.
"The Geochemistry of the HGPA geothermal well," (Thomas, 1987), states "the presence of only slightly brackish water at 2 km dt=pths sugge<.:-:;b.'?d that some mechanism asociated with the rift zone was responsible for r2;.:c lusion of seawater from the interior of the geothermal res<~rvo:i.r."
There is some conflict as to the depth of the freshwater zone within the diked reservoir that appears to be located near the HGPA. Two km would indicate a depth of over 6000', and this diked water could be as valLiable a resource as the geothermal steam. It is "well" vJOrth providing every protection that is technologically available.
The F'GV UIC application ( p. 27) states that "overlying th(~
high-temperature geothermal reservoir is a relatively impermeable layer of capping rock, generally at depths of between 4000 and 2500 feet below the surface, although both the upper and lower boundaries are variable and dependent upon the local permeability (fractures). A zone of groundwater extends from the top of the caprock to the water table, approximately 600 feet below the surface. The water in this area of the LERZ is chemically and thermally influenced by natural leaka.ge of geothermal fluids throLtgh the caprock."
6-2
F'rimary "leakagt..; into this groLuldwater ~oneis hec:1t ( b.:=mper.3.t.Lwe increase). To determine what other leakages have occured is difficult due to the nature of information being "NA" not avai 1 ab 1 e fot~
geothermal wells drilled in the area.
The Report (p. 11) states that drilling activity may use 2000 barrels of water per day per well. The PGV application (p. 3-19) states that expected water usage during drilling will be 30,000 gallons per day, for the preparation of new drilling fluid, vashing of the rig and other uses. During periods of drought, residential and agricultural needs for water hauling will increase and cause conflict with water ~tandpipe and trucking capabilities and availability.
The November 28, 1989 Hawaii Tribune Herald article states that the dry times have left many East Hawaii residents who rely on catchment water scrambling for additional water sources. William Sewake of the DWS said that the aquifers supplying county water through wells are "huge" and so far unaffected by the lack of rainfall. "lJI~OLllld~'>l<::<.ter- i~;
a pretty reliable source'', he said. Demand on spigots placed in various areas to provide lead-free water for those residents with catchments contaminated by lead leached by volcanic emissions from roofing and plumbing materials has increased, he said. In the past two weeks the draw from those spigots has gone from 15,000 gallons s a week to mbre than 50,000 gallons a week.
This estimation does not include the withdrawal of water from standpipes currently being used by True Geothermal for drilling use.
Energy Self Sufficiency for the Big Island of Hawaii , a report by SRI International, January 1980, stated the concern that:
Subsurface conditions on the Puna Rift and possibly in other areas of Hawaii due to the porous nature of the basaltic rocks are far from the normal and may require regulatory caution until the best method of protecting subsurface water is developed.
This report also recommended that a state or county authorized dump site be developed for the disposal of drilling mud, sludge and other waste materials. DLNR Circular C-106 states ''subsurface disposal of geothermal fulids by re-injection would be allowed only under controlled conditions, and alternate safe disposal methods should be developed.
A Department of Planning and Economic Development contract in July 1981, "Geothermal Energy for Haw<:~oii" reiterates that cont~<.mination o·f surface or groundwater by geothermal operations is of substantial concern to regulatory agencies.
The Applicants see the need for the protection of this unique water resource, possibly the purest and largest on the Big Island, in light of the present and future demands for residential, agricultural and recreational development this reservoir could supply. Geothermal development judging from past cement failures, could severly compromise basal reservoir water quality.
6-3
.. ··---- ··------------ ··-------------------·----
SECTION 7 PROPERTY VALUES COMPARISON
This study was done to assess the effect of the HGP-A well siting on property values. The plats chosen for comparison show clearly that prices, number of sales and desirability of ownership have fallen dramatically since HGP-A has been in operation. It appears that it took some years for the general public to catch on that living by a geothermal well was not a healthy and joyful experience. Property values are an important representation of the investment community members have made in and adjacent to the Kapoho Geothermal Resource -Subzone. This study, representing an assessment of values related to the HGP-A well is an indication of the effect further Geothermal development will have on all areas in any GRS if further development is allowed to proceed in a similar manner. Also shown is a pronounced unwillingness to reside within one mile of the well as shown by the occupancy rates.
The areas stLtdied are all in Section 1 ' District ' ,_,II The chosen plats are 45 and 46, 44 and 29, and 11 and 16. Plats 45 i':\rl rj LJ-6 a.t·-e Lanipuna Gardens, plats 29 and 44 are in the lower section o·f Leildni Estates. Plat
Lots r-ates
being refer
11 is
compared to the
IIRII denoting raw land
SEE ATTACHMENT 7-A
appro:·: ima te 1 y 2 miles awc:1y from th~= V.Jell.
are one acre, raw land, unless noted. Occupancy colLtmn on the printout titled "Haw/Hou~;e" with and "H" standing tor a house.
Comparisons could be made to other subdivisions in Puna, such as Hawaiian Paradise Park, which also has one acre lots. However, this subdivision is closer to Hila, and above the East Rift. It became apparent that the differences just between upper Leilani Estates and lower Leilani and Lanipuna Gardens were enough to show a consistent and pervasive degradation of property values.
Lanipuna Gardens is such a good example for this study because it is the closest subdivision, less than 1/4 mile, to the HGP-A facility, is a full-service subdivision and few people want to live there. In 1981, when HGP-A had been in operation for about 1-1/2 years, 53 out of the existing 89 lots in plat 46 sold for an average of $16,822. In the years 1982 to the present there have been a total of 32 sales for an average of $13,299. These prices have not gone up as one would expect with a subdivision with paved roads, county water, electricity and phone lines •. The average price for- a lot from 1987 to 1989 was $10,769.28. Based on 7 sales in the last 2-1/2 years, this represents a 36% drop in sales price from 1981 to the late 1980's. The Lanipuna figures show that nobody wants those lots at any price, and it is common knowledge. They just don't sell. The numbers only verify what the public already knew. The occupancy rate is 4%.
Plat 45, also Lanipuna Gardens, has 30 lots with 10 sales since 1979. Since there are so few sales the average prices are not as meaningful as the occupancy rate. Nobody lives there, occupancy 0%. Plat 29, in lower Leilani has 27 lots. In the past 11 years there have been 10 sales, one included 3 parcels, for a total of 12 lots. From 1980 to 1983 the average price was $8500. The prices in 1988 and 1989 are consistently between $4500 and $5500. This represents a 42%
7-1
-------------------------------------· ·--·····-··-···
dn:-Jp. They are assessed by the COLlnty at $7526. Thes€~ pt~Op 1 t2 a.re pay:i.ng tal·:es on a higher va 1 Lle than their propet~ty could ,~E'c\s;on 2. L1l y sell
F'lat with The drop
·for·. The1~e is one house making the occupancy rate 3u4%u
44 is also very close to the well. There are 65 parcels 26 sales in 11 years. The average price in 1980 was $8314.28.
average price in 1988 and 1989 is $5375. This represents a 35.3% in the last 8 1/2 years. The occupancy rate is 4.6%
CONTROLS
~ Plat 11 was chosen as a control because it is approximately 2 miles from the well It is in the same subdivision as Plats 29 and 44 and have paved roads, electric, and phone lines. Compared to Lanipuna Gardens with county water it cannot be argued that upper Leilani is a "better" subdivision and these higher occupancy rates and higher average prices are warranted for any reason other than their non-proximity to the HGP-A well compared to plats 44-46 and 29.
Plat 11 has average price 1987-1989 was probably more as many people
83 lots. There were 21 sales in the last 11 years. The in 1980-1982 was $12566. The average price from $15025, an increase of 16;4%. The occupance rate is interesting. It is 27%. This is approxima~ely 7 times
live in the lower Leilani and Lanipuna areas.
This Real
in ·formation was Estate offices
gathered from the
from the wire service available to Bureau of Conveyances in Honolulu~
Hi:IWii\i i.
DBED's 500 MW REVIEW
In DBED'S 500 MW Review dated March 1989, an analysis was done in Appendix D on "Effects of Geothermal Development on Property Values and Sales". The analysis states that "the discussions with knowledgeable Realtors were considered to be the most reliable." (sources of information in a market with many factors) In section III it states, "Among realtors who are familiar with property sales in Puna, a near unanimous consensus exists that the HGP-A well and geothermal power plant have produced a strongly adverse affect on surrounding property values and sales. According to these Realtors, the overwhelming factor affecting property values and sales is the too-frequent emission and high level of hydrogen sulfide which has the noxious smell of rotten eggs."
The ana 1 ysis goes on to say, "For a 11 a·f ·fee ted pr·operties, the general opinion is that property values are about one-half to three-quarters of what they would normally be."
SEE ATTACHMENT 7-B
ASSESSMENTS ON REAL PROPERTY FROM THE COUNTY OF HAWAII
The County assessments in Leilani Estates seem to be the same whether the property is in the lower or upper area. Assessments now are $5000 per one acre of raw land there. In 1985 they were $10,200, a drop of more than 50%. DBED's analysis claims that "Many, bL1.t not c:dl, Puna parct:~ls lost v.-:~lue dLlring the early and mid 1980's." Within t.he
7-2
scope of value of all properties in Puna in those years, this was not the case in Leilani Estates. The prices have risen steadily in upper Leilani and fallen steadily in lower Leilani. It is a well planned subdivision, in a scenic area with mature ohia trees, has good roads and is considered by many to be a not-too-difficult commute to Hila if neces:;ary.
The assessments in Lanipuna Gardens have net changed lately (plats 45 and 46) because of the extremely small number of sales in the last few years. However, the sales prices have definitely dropped and since assessments are tied to sales of usually two years earlier, the a.ssessmen ts are e:·: pee ted to go down. There is a feeling amcm(J ;n::my residents and Realtors that if the County can warrant keeping assessed values high, by the lack of sales activity, they can then collect more taxes.
PUNA GEOTHERMAL VENTURE APPLICATION AMENDMENT
In the Geothermal Resource Permit Application Amendment for the Puna Geothermal Venture Project dated Mo:\rch 1989, 3-124, it states, "A stu.dy of the impact of the HGF'-A facility on housing values in the vicinity of the site found that the odor of H2S emissions from the HGP-A facility could decrease housing values of residences within 0.5 miles of the power plant site by as much as 50 to 70 percent.
REALTORS DISCLOSURE STATEMENT
Many realtors have complained that when potential buyers are told the answers to specific questions on the Sellers Real Property Disclosure Statement (Single-Family Residences and Vacant Land) the buyers solution is to avoid any properties in a Geothermal Resource Subzone because it is believed to be "possibly dangerous". This form is required whenever a transaction takes place with an Association of Realtors realtor. The first question which disturbs buyers ·is 2.e. "(-il~e thel~e any known to>: ic substc.'l.nce:; in the sci 1, the water supp 1 y or the air?'' The answer is yes. H2S as well as mercury, arsenic, boron, lead, radon, and silica, are known toxins. The other difficult questions are 6. a. and b. "Do yoLt e:-: perience any e:·:cessi Vf'= noise at this property?" and "Is there any industry 01~ opel~ation in your community which is considered to be controversial and/or possibly d~-:i!nger-ous?" The geotherma 1 industry is considered to be controversial and therefore dangerous to anyone contemplating capital investment. Realtors and the rest of the public have no answers to questions of buyers such as ''What's going to happen in this area?" "Is there a possibility that my property will be condemne<:j?" "Is this a reasonably safe investment?" This is happen in<;) every day in Realtor's offices in Puna in 1989.
SEE ATTACHMENT 7-C CONCLUSION
This study shows that there is a distinct difference between occupancy rates in lower L~ilani Estates subdivision and the upper part of the subdivision which is further from the well. Also shown is that from the early 1980's to the late 1980's the prices around the well have fallen between 35% and 42%. This study concurs with Realtors in the area that property values have fallen significantly. Combined
7-3
with an almost seven fold difference in occupancy rates (from 4% to 27%) it is obvious that there are major unaddressed problems with the co-existence of residential and geothermal development.
Additional subdivision activity in proven or promising areas would likely increase environmental problems and land use conflicts. Consequently further parcelization and additional subdivision activity in the primary geothermal resource area should be avoided. The potential number and severity of future conflicts could be reduced 1t land use planning, zoning, and subdivision reviews are taken now to limit the future growth of agriculture and residences in the ~eothermal development areas. Conversely, existing and proposed uses can be protected by approving this withdrawal application.
7-4
SECTION 8 AGRICULTURAL IMPACTS
EXISTING USES
The land in the Kapoho Geothermal Resource Subzone has been cultivated for centuries, first by a large population of Hawaiians for subsistence, and in the last century, in economically important crops of cattle and sugar until the mid 1960s and since then for orchard and floriculture. For decades, an extensive railroad system linked the rich sugar lands of Kapoho to the Keaau mill. The incipient papaya industry developed primarily in the KGRS.
The ,~epor-t "Agricultural Lands of Importance to the State of Hawaii", contracted by the State Legislature, identified papaya lands as a special land use which must be protected. The special qualities that make much of Kapoho the highest quality papaya area in the state are:
1. Good mixture of fine soil particles and rocky underlayment with excellent drainage capacity,
2. Consistent and well distributed moderate natural rainfall, 3. High levels of sunlight (temperature), 4. Excellent infrastructure of cinder covered roads, 5. Mostly gently sloping ground where run off and pending are limited~
and; 6. Relatively inexpensive land that can be purchased or leased
with the revenues produced by the crop.
In addition, Kapoho the state that has destructive virus is fields, but has for Kapoho-Opihikao fields.
to Opihikao is the only papaya growing area in not encountered the papaya mosaic virus. This
found in Oahu fields, Kauai fields, and Panaewa some reason not been able to survive in the
The high quality of Kapoho's land can be seen by the nearly 100% cultivation of the area that has for decades been designated and planted in agricultural crops • Even areas of the 1955 and. 1960 flows are being used. The older lands are intensively cultivated crop after crop. Today, the lands of the KGRS raise over 1/3 of the state's papaya, a $14 million a year industry, over 5% of the State's bananas. a $4 million a year industry, the majority of the state's vandas, as well as economically significant amounts of other nursery, flower, macadamia nut, citrus, and pineapple crops.
The effects of geothermal development and emissions on vegetation and crops have been studied and demonstrated elsewhere.
Thompson and Kats ,1977 "Effects of Continuous H2S Fumigation on Crop and Forest Plants", U.C. Riverside, Statewide Air Pollution Research Center assessed the direct short term phytotoxic effects of H2S on certain plants, but not the accompanying conversion to 502 and soil acidification. Plants fumigated by H2S showed injuries in differing amounts based on:
a. species- some much more susceptible b. age- young tissue much more susceptible c. soil moisture- drier much more susceptible
8-1
,,. d. H2S concentration- higher levels more susceptible e. speed of growth- rapid growing more susceptible
The report further points out that part of the effect of exposure is due to the uptake of sulfur by plant tissue.
SEE ATTACHMENT 8-A
California Energy Commission's "Cumulative Biological Impacts of the Geysers Geothermal Development", 1981, Staff Report of California Energy Commission, assessed the chronic low level effects of the Geysers emissions in local vegetation. Veg~?tation losse~:; 1·-Jen.= species specific to a long list of California's native trees. The emissions were low in H2S, but the effects were due primarily to geothermally generated acid rain and particularly Boron salts in the steam mists. Boron concentrations of emissions have been increasing over time and been found to be in the immediate vicinity as well as transported over " considerable distances". This st.udy ;:.d~'5Cl
notes H2S may cause changes in species composition in the natural vegetation due to uneven stresses on different species.
The findings also note that conversion of H2S to more phytotoxic 802 gas occurs in less than 12 hours and thus because of limited dilution and dispersion can produce more concentrated effects than previously thOLU;J ht.
This new information on the conversion rate of H2S to S02 indicates a reaction time of 12-18. hours instead of 48 hours. Under the humid, moist, high rainfall, windward areas of the GRS, 502 would precipitate out as sulfuric acid much closer and much more concentrated than formerly assumed.
Such acid rain effects have been broadly noted and under less concentrated situations than can be expected to accrue in the areas of geothermal development, have lead to chronic acidification and resulting disruption of natural soil chemistry resulting in death of many plant species. While in a farm setting, soil acidification can be countered by increased liming, productivity will still be negatively affected. Partic~larly, with the addition of Boron, accompanied by H2S in Hawaii's geothermal emissions on top of volcanic emissions of 802, the very delicate and difficult to balance Calcium-magnesium-boron complex will lower crop yields and increase costs.
in Kilauea fluids are reported (D. Thomas B, Kilauea .MER Geothermal Subzone Contested Case
mg/kg of fluid, about half that reported (Kahaualea Geysers, and so are environmentally comparable.
Boron concentrations testimony, Exhibit Hearing) to be 1.58 EIS, table 5-3) for
Malloch et al (1979) concluded that boron caused most of the vegetation stress and damage measured over 6% (247 ac) of the total leasehold area of PGandE Units 1 - 11 as of 1979. Boric acid was one of two primary constituents measured in the drift from cooling towers. The boron concentration measured in droplets at PGandE Unit 11 by ESC (1977) ranged from 56 to 125 PPM. The Geysers Vegetation Stress Monitoring Study sponsored by PGandE measured boron deposition rates at Unit 18 with a low of 0.381 lb/ac-yr and a high of 17.7 lb/ac-yr, with considerable variation observed over the 7 year program.
8-2
The magnitude of water vapor from the Geysers geothermal steam emission locally increases air temperature , cloudiness and relative humidity. Increased air temperature and relative humidity has been shown to be responsible for fungal disease and branch die off in black oaks near PGandE Unit 13 cooling tower (PGandE, 1986, WFF).
However, the most serious effect of geothermal emissions is likely to be the direct phytotoxic effects of sulfuric acid rain hitting delicate flowers, foliage, and fruit destined for the blemish tree fresh market. Spotted orchids, anthuriums, papayas and other directly consumed products are unmarketable perhaps for many months "f..ollowing every incident of open Ltnabated venting. Flower dr·op a.nd tissue discoloration in the tomato, macadamia nut and coffee industries in Ka'u and Kona has been directly tied to the same emission components as would be expected in the downwind plume of any well field. The Kona tomato industry has been forced to go to greenhouses primarily due to volcanic emissions. Hawaii Agricultural Statistics Service Reports in 1989 for Avocados, Coffee, and Macadamia nuts all list volcanic (geothermal) emissions as responsible for some degree of crop loss. The Sugar industry at Pahala and Hutchinson plantations attribute reduced crop yields to increased sulfur and acidification due to volcanic emissions.
The volcanic dispersal of Pele's hair in 1984 during an eruption of Puu O'o caused a significant loss to the agricultural industry all over Puna and Hilo, both in crop production and value, with losses of expected yields in papaya and in banana for several months following the emission of those particles.
Open unabated venting of wells in agricultural areas would likely produce similar effects to production yields and marketabilty of crops in the plume area.
In California, water contamination by waste products from geothermal operations has been blamed for infertility and stillbirths in cattle at Maynard Freeman's ranch. University of San Francisco scientists have found unusually high levels of copper, lead, boron, strontium, zinc, titanium and manganese accumulating in the tissues of rodents and fish in the Geysers area. Geothermal wastes in the Geysers area are ter·med 11 hazardous waste 11
•
Thus, the known effects of the chemicals contained in geothermal emissions and their break down products include: 1. the phytotoxic effects of H2S and S02; 2. acidification of soils, and the resultant imbalances caused in the
delicate soil chemistry of KGRS soils; tissue absorbtion and related toxic effects of foliar applied emissions of sulfur and boron. Some elements are toxic at very low rates such as boron on papayas and sulfur on bananas. Some of these effects are unknown at this time but deserve further study.
While the chemical emissions themselves especially under venting, blowout, and downed transmission line and power plant systems not reinjecting can cause crop damage, other effects of siting geothermal power development in this highly developed agricultural area include:
8-3
·,~ -'"" 1. Potential direct loss of land use due to acreage removed from
cultivation for well pads, power plants, pipe line corridors (i.e. Puna Geothermal Venture's 25 MW = 500 acres).
2. Fugitive emission, venting and other emission releases, resulting in H2S ambient levels to reach above the odor threshold of 5 ppb will result in further difficulty in obtaining agricultural employees due to the significant nuisance and headaches of smelly rotten eggs 40 hours per week.
The low elevation lands found in the KGRS are irreplaceable to the papaya, banana, flower, and tropical fruit industry of today and in the ft:.tture.
The conflict for land use is direct as well as indirect with nuisance to workers, depressed land valuation to farm investors, increased cultivation costs to offset acidification, and potential phytotoxic effects on Hawaiian crops raised for their fresh market perfection. Flowers damaged by 802 and H2S will be unsaleable as foliage and may cause deflowering of papayas and spotting on fresh market fruit.
8-4
COMPATABILITY
During a public hearing for an application to of Integrated Resources on 4/20/89 into the residents testified that noise is driving pollution is threatening resident health, plummeting in the neighborhood surrounding plant in Pohoiki.
SECTION 9
add the Pohoiki property Kapoho GRS, several people from their homes, and property values are
the experimental HGP-A
Senator Richard Matsuura acknowledged during a Honolulu conference on r~newable energy development in July, 1989~ that problems with the State's 2.2MW HGP-A power plant, described as a rusty. foul-smelling eyesore, have left many residents reluctant to support larger scale geothermal development. He said ''That was a demonstration plant and perh.:."'ps it should have been shut down long ago."
Puna residents who have long complained States's 2.2 MW HGP-A facility in Pohoiki, large-scale development.
about the impact of the express alarm at plans for
In April 1982 , over seven years ago, at a County sponsored geothermal health complaint meeting, 200 lower Puna residents aired a variety of health problems caused by geothermal emissions siting sinus problems~ respiratory ailments, chronic colds, coughs and flus, migrain headaches, stress, tension and nightmares, ear , throat and eye irritations and still other illnesses, including fetal birth defects. (See Wayne Westlake editorial)
SEE ATTACHMENT 9-A
On July 18, 1989, at the County Planning Commission hearing on the Puna Geothermal Ventures permit application, even the supporters of the 25MW project suggest that HGP-A be closed down.
On September 4, 1989, Labor Day, ten families were evacuated from the area around the HGP-A due to excessive emissions caused by the failure of the abatement system.
The Planning Commission had asked the NELH to respond to complaints involving noise and emissions at the plant and to outline what it has done to alleviate the problems. In the absence of a suitable response, two panel members stated that they would consider moving to revoke the special permit under which the plant operates.
On September 28, 2989 the Civil Defense Administrator reported that:
''I find it difficult to understand and impossible to accept the present operating procedures in regards to the incidents of elevated H2S releases from the HGP-A well. This is especially true for the three incidents that occurred in the monthy of September 1989. Residents affected by the H2S who filed complaints seemed to be treated more as a nuisance and/or habitual complainers than as people who were truly affected by H2S levels two, three, four and five times higher than average and for several hours before corrective measures were taken. The initial detection of unabated or higher than normal emission of H2S surely must be from other than the residents feeling and reporting the effects o·f those emissions."
9-1
"The bottom line is that residents must be assured that measures will be taken by the responsible agencies to protect them from elevated and prolonged exposure to H2S, which can produce a number of physiological and behavioral responses whose combined effect~ are yet unknown."
During that time of excessive emissions in September and October, a nearby resident reported that the fenceline monitor was intentionally disconnected and recording much lower H2S levels.
The Planning Director on October 23, 1989 added that:
"'coupled unusual unabated
with an inadequate communication and notification network for operational situations, recent occurrences of partially or unabated releases of H2S have created a continuing nuisance
situation to surrounding Puna Communities. On a case by case, individual basis, potential health impacts may have also been generated as well."
During the year 1982 when numerous complaints were being registered, DOH public meetings held, and a court action filed against the HGP-A~ the State could have assessed the compatibility of this development by determining what impacts were occuring on the health of the neighborin~ residents. Instead, the operators of the plant chose to move the monitoring locations to register lower readings of H2S emissions. In 1982 the data registered 4000-7000 ppb inside the stack above the rock muffler during abated venting, the expected emission level for 92-95% abatement. By 1989 monitoring data became "mare sophisticated" and registered 14 ppb during unabated venting, with "spikes" of 25 ppb.
The HGP-A has been the only example of geothermal development in Hawaii, where emissions of 1300 ppm hydrogen sulfide gas (H2S) alone are among the highest in the world, comparable only to the Wild Horse area of the Geysers fields in California. Coso 175ppm during unabated well testing (Coso BLM NWC #1, ATC, 1988); average concentration of 220 ppm at Burmah Oil field development in Sonoma County (Burmah Oil and Gas Co., Aidlin-Gouvea Leasehold, draft EIR, 1976); 660 ppm PG&E Unit #13, Geysers, maximum concentration ( Burmah EIR); Iceland 1.5 ppm, Wairakei 1 ppm, Salton Sea 16 ppm, Geysers 33 ppm (Kahaualea EIS); NW Geysers 1710 ppm, Central Geysers 662 ppm, SE Geysers 116 ppm (Geothermal Resource & Transmission Element, Lake County General Plan, Vol. 1, Draft 7/12/88); Stillwater 3ppm, Steamboat 10ppm (NEPD, 1989).
Abatement of H2S in Hawaii has been extremely costly and corrosive, resulting in failures of the system on a rapidly increasing scale. Since July 1989 alone, the system has failed at least six times for a number of 13 days, and encountered at least two power outages. The rock muffler, the only back up system at HGP-A, when working efficiently releases H2S gas at about 60 ppm, an exposure level which causes fatigue, dizziness, nausea, eye irritation, inhalation irritation and damage to sensitive plants.
Circular C-108 of the DLNR, Geothermal Technology, 1984, recognized that a geothermal plant is expected to be off line S-10% of the time, or about one month out of the year, with up to 95% abatement.
SEE ATTACHMENT 1-A and SECTION 1 p. 1-S
9-2
The HGP-A facility has failed to demonstrate that geothermal development can be compatible with existing uses in this area in the Kapoho section of the Lower East Rift Subzone, and strongly contradicts a 1984 report. In 'Geothermal Resource Subzones for Designation by the Board of Land and Natural Resources' dated August 1984, it was stated that ''The existing HGP-A facility demonstrates that with careful planning, geothermal development can be compatible with existing uses in this area.'' The actual result of the HGP-A experiment was its forced closure by the Planning Director in December 1989. Prior to that it was unclear who had the responsibility and the legal authority to enforce the violations and close down the plant.
The State Legislature recognized this potential inherent conflict in land use in Act 296, SLH 1983. There it had assigned responsibility to the Board to assess land use compatibility with geothermal development and to find an acceptable balance before the designation of a geothermal resource subzone. The applicants find that the present boundaries fail to protect the residential and agricultural uses.
9-3
SECTION 10 GEOLOGIC HAZARDS
"·'"' t
The hazards that could be caused by strong earthquakes and by lava flows to a well or power plant facility would result in a long recovery time and be unacceptable to both a neighboring community and the utility company. The community may have to bear the costs of venting while relief wells are being drilled or roads are being built to access the power plant area. The utility company may have to provide sufficient reserve capacity for their consumers by overloading generation from their other power facilities (C-107 p.2).
·-The Kilauea East Rift Zone has had numerous eruptions since 1750. Historic lava flows have occurred in Kilauea"s Lower ERZ in 1750, 1790, 1840, 1955, and 1960, and in the Upper ERZ in 1840, 1922, 1923, and almost every year from 1961 to 1989. According to the Report, "erLtptions are e:·:pt-:cted to occur within this ar·ea in the future but the precise time and place is unpredictable.'' If 30 years is the assumed life of a geothermal power plant, attachment Figure 10 suggests the probability that sites may be threatened by burial during their lifetime, as based on Kilauea's history 1954-1984 p. 30, C-103). Figure 12 (C-107) defines zones of relative risk from lava flow burials increasing from A through F on the map. Most of the Kapoho and Kamaili subzones are contained in the F category, of the highest risk.
SEE ATTACHMENT 10-A, 10-B, 10-C, 10-D
Most earthquakes in Hawaii are volcanic in nature, resulting from the vibration of near surface magma movements. They usually cause little direct damage. Larger earthquakes tend to be tetanic, resulting from the movement of large rock bodies. Of concern is the volcanic or tetanic subsidence which usually occurs on or about active rift zones. Subsidence and cracking may also be associated with tetanic earthquakes. Collapsing lava tubes and pit craters can result in severe localized subsidence. Pit craters usually occur within a summit or rift zone of a volcano. Fragile, near surface lava tubes are subject to collapse from heavy surface activity.
Earthquakes having a magnitude of 6.0 or greater should be taken into consideration. The Geothermal Resource Technical Committee agreed while earthquakes are a definite hazard, it would be extremely difficult to accurately predict their occurrence or potential damage (GRTC meeting No.7, C-103, 9/84). The most recent earthquake was of a 6.3 Richter centered near Kalapana on 6/25/89, resulting in significant earth cracking near Kehena. The 7.2 earthquake of November 25, 1975 was centered off the Kalapana coast and resulted in major subsidence at Halape in the National Park and significant subsidence along the south Puna coastline.
The 1:~eport further states that "groLlnd cracking close to a WE?ll bone might open up an alternate path for the steam and cause its loss from the well. If the crack is close to the surface, steam could escape and vent its way to the surface. In the latter event, a cement plug poured from the intercepting directional drill hole may seal the leak." i:~t
the uncapped well in the Wild Horse area of the Geysers, where there was a landslide and the well bore casing was sheared off, all attempts to date have failed, cement plug operations have failed, and the well
10-1
produces unabated venting to the atmosphere, ( lAJFF p. 6-::::;s)
306,000 lbs./year H2S~
On 1/12/89 a well being drilled at the Stillwater Geothermal I Project, developed by Ormat Energy Systems, blew out. A combined team effort worked 24 hours a day. The primary objective was to place 2
good cement plug as deep as possible. On 2/7/89 the well was plugged at 937 ft. RKB. Weather problems delayed equipment delivery by 6 to 8 days. Although this is a liquid dominated system with problems more related to wetland contamination, unabated venting occurred for a total of 26 days • ..
SEE ATTACHMENTS 10-E, 10-F, 10-G
Wells in the Nevada area average about 1000' deep. Here in Hawaii~ the wells are 6500'-8000' deep and require not only overseas shipping time for supplies but longer drilling time to reach depth. Our community may have to bear with unabated venting for at least 45 days~ and recovery time could be significantly longer, while relief wells are being drilled. (SEE NOISE p. 5-1). The HGP-A drilling records indicated the constant worry of well bore cave-ins due to the highly fractured character of the rock (SEE GROUNDWATER p. 6-2)
The mitigation for geologic hazards includes (Report): keep the power plant as far outside the rift zone as possible since volcanic activity is concentrated there, e.g. lava flows, tubes, cracking, subsidence, pit craters, grabens, and swelling. Puna Geothermal Ventures proposes their power plant be located on the rift zone, surrounded by volcanic puus, with primary well pads drilled on the 1955 lava flow. C-103 states that while elevated ground should be considered for power plant locations, evidence indicates that selection of high ground is not entirely safe from inundation by lava. Power Plants may not be practical more than 1 mile from the source well.
According to C-107 plants include:
(p. 6-8), damage that would likely occur to power
1. the precise effect the lava's heat would have on the well head mechanisms is not known;
2. Thick a'a flows would probably disrupt surface piping; and 3. Power plants should be constructed to withstand an earthquake of
7.5 on the Richter scale.
Testimony at the MER contested case hearings by Manabu Tagomori representing DOWALD, on September 26, 1985, emphasized that:
"Decentr-alized facilities, constructed lava diversion to mitigate the hazard nothing can eliminate the
strategic siting, and prudently platfor-ms and barriers can be expected r-isk fr-om future flows. However
substantial hazard from lava flows. "
The Report states on page 18 that "adequate spacing between developments should be maintained so that one eruption would not likely endanger more than one development." Puna Geothermal Ventures has leased over 12,000 acres in the Kapoho area, some in the subzone and some outside of it. This would be near their presently proposed development. These leases represent the developers options for
10-2
encroachment into adjoining development areas in direct conflict with the Report's assumptions that adequate spacing would be maintained between developments.
It is generally assumed that the resource developers will bear the risks of loss associated with their activities. However, it the utility owns the power plant, as in the recent 50% negotiations of PGV by Hawaiian Electric Inc, there may be some question as to whether the investors or the rate payers will bear the risks of loss. This assumption of risk would be reflected in the cost of electricity from geothermal plants. It may be better that this cost be 'up front' rather than be delayed and possibly deferred to rate payers in the event of a catastrophe. In the past, instances of hazard losses were recovered by the utility from rate revenues (C-107, p. 8)(i.e. Hilo Tsunami) .
Policy regarding assigning clarifying risks of loss may be implemented by imposing conditions to be met by development investors prior to the granting of a geothermal resource permit by the State or the County. In the granting of the GRP 87-1 to Puna Geothermal Ventures, the County Planning Commission did not impose or attach any conditions to be met by the development interest in regard to assumption of risk.
At the August 2, 1984 public hearing on amendments to the 1983 legislative act, Manabu Tagomori of the DLNR remarked that, " The geologic hazards did not play much of a role in our decision ••• We had to choose an area of high potential for energy ••• we had to get close to the rift zone." (HTH August 2, 1984)
SEE APPENDIX A-4
10-3
--------------------------------- ·--··-·----·
SECTION 11 POLICY
"Geothermal Development Policy for an Isolated State: The Case of Hawaii" (RM Kamins, UH, Proceedings on the Second United Natio~s symposium on the development and use of Geothermal Resources. S6n Francisco, 20-29 May 1975) states that the Hawaii state government is considering what actions should be taken to encourage and also regulate the resource should it become economically useful.
l~e state government began to formulate a public policy on geothermal development for Hawaii. In 1974 the Legislature acted to establish a legal regime for the potential resource. By Act 241 it defined gE?othermal resources as "mineral" thereby placing t:hf:m unc-h?r· a. reservation on behalf of the Hawaii government. There was a gentlemen's agreement to defer the legal contest of ownership and it is assumed that the courts may take up this matter at a later date.
Discussions between the state and county governments established a rationale for government action in geothermal development, a basic policy to guide the decisions thrust upon the DLNR by proposals to drill exploratory wells on two of the islands in the State. The kinds of considerations which the state government would have in formulating its geothermal policy were the purpose of the paper by Kamins, and to sketch models of action available to the state for affectuating that policy.
SEE ATTACHMENT 11-A
Policy models were distinguished in ~he paper such as minimal state intervention, joint venture, government monopoly, and private operation with government support and private operation for State objectives.
The policy eventually description of private objectives:
selected by the State of operation with government
Hawaii fit the support for State
To maximize production while minimizing state control, the state would accommodate all reasonable and mutually supportive efforts by private enterprise to develop the geothermal ressources, as by:
1. Expediting drilling by cutting all corners in granting access to public lands (and helping to get access to private lands, if necessary using its power to compel entry), minimizing environmental impact statements, and giving all assurances possible under the law that successful drillers would have production rights for long periods of time.
2. Direct subsidies: paying part of the costs of drilling development; minimizing or waiving royalty payments for geothermal wells; giving special tax benefits to drillers/producers.
3. Indirect subsidies: providing access roads, water supply~ and other infrastructure needs of a geothermal field, regulating electric rates so that the benefits of geothermal power are shared between developer and utility
11-1
company and not passed back to consumers in lower rates. (this is done at The Geysers, California, where the Pacific Gas and Electric Company pays the geothermal-steam supplier at a rate tied to the price of fuel oil.)
1. Access to public lands, and helping to get access to private lands, has been accomplished by the land swap with Campbell Estate and the issuance of mining leases to large private landowners interests. The designation of the Lower East Rift Subzone in 1984 and the Middle East Rift Subzone in 1985 was the State's implementation of providing access to large areas with 11 potential resource probabi 1 i ties, 11 d!~ai'Jn
benchmark to benchmark.
Environmental impact statements have been minimized through provisions in Chapter 205-5.2, and Chapter 200. Subject to Title 13, Chapt 184, 13-18-7 an EIS as defined under HRS 343 shall not be required in assessing any area proposed for designation as a GRS. Previous to subzone designation, geothermal development in the East Rift Zone would have required General Plan Amendment procedures and the preparation of an EIS.
All assurances were drillers would have mining leases for a as was issued by the leases.
given (8/16/84 HRS 205-5.2) that successful production rights for a long time by issuing period of 65 years, at the cost of $1/acre/year, State of Hawaii for the R-1, R-2, and R-3 mining
2. Direct subsidies have been in a $3 million taxpayer contribution in the SOH exploratory drilling program and discussion of the possibility of waiving royalty payments. Royalty payments can be waived by the State to stimulate private industry investment. By newspaper artie 1 e of 11ay 29, 1985, HTH, 11 Governor Ar i yo:.; hi yes terd<.'\y signed into law a bill to allow the waiver of royalty payments from developers as a way to encourage development, 11 with such gr.::mting of a waiver relegated to the BLNR.
3. Indirect subsidies have been provided through infrastructure of the use of county roads (#130, Kaohe Homestead Road) to the lease areas and police protection. The PUC may regulate electric rates so the benefits of geothermal power are shared between developer and utility company, rather than passed back to the consumer in lower rates.
The policy the in the position adverse impacts.
State has adopted places neighboring landowners of subsidizing the developments by absorbing the
Recent involvement of the State has resulted in the County's issuance of GRP 87-1 (PGV) subject to Condition 51 which states that:
Prior to the issuance of the first building/construction permit under this GRP by the County of Hawaii, the State of Hawaii and the permittee shall each contribute towards a Geothermal Asset Fund or other appropriate existing fund for the purposes of geothermal impact mitigation efforts within the District of Puna •••• The State's initial annual contribution to the Fund shall be the net revenues derived
11-2
from the resources generated by the HGP-A well, or a similar amount from other State funding sources ••.. In the event that future enabling legislation provides for a percentage of the State's geothermal royalties to be allocated to the County •.• said royalties may also be deposited to the fund •••• expenditure of assets ... first priority of distribution for temporary or permanent relocation of those property owners who are found, in accordance with criteria established in the rules, to be adversely impacted by the activities authorized
~ new policy needs to be implemented which recognizes the adverse impacts and potential hazards of geothermal development on surrounding properties. Adequate buffer zones were not established when the subzones were designated and are required at this ~1me tor the protection of neighboring landowners. In the event that developers challenge the ownership of the mineral rights and the payment of royalties, the State may not be in a position to assist those who will be adversely impacted.
11-3
From t.he bo•J.nd<~r ies Lt:::;r::=~,. A
1 c;;::>+ a.nd ''" (:0 ,~ (·2 l'l C) t ma.ndated
SECTION 12
cnNCLIIS I ON
foregoing Sections it should be clear why the designated GRS fail to protect the existing agricultural and residential
2.5 km buffer zone is being requested for the following
f.)urinq the review and design8tion of the GRS 1n
1985 by the Board, landowners within the proposed areas notified. Statutory requirements for those public hearings
by HRS 205-5.2 were inadequately followed and did not provide property owners opportunity to review and comment on the proposals.
2 • 6.;i..c ___ .2J:.\:~~JLt::L_ .. l.L!.'u.':?.:,~;.J;.::..l • E ;-: p o s u. ,, .. e? t: o a t: m o ~5 p h (:? r i c c D n c F.:: n t r ;:, t .i or"! ~3 D f chemicals within the resource pose potential hazards to the public and to the occupational health of workers. Some of these chemicals include hydrogen sulfide (H2S), sulfur dioxide (502), mercury, arsenic, boron, radon 222, sulphates, particulate matter, and those used for operation and abatement including isopentane and caustic soda (sodium hydroxide). Computer plume modeling done for the Puna Geothermal Venture project showed worst case scenarios of unacceptable air emission concentrations occuring at a distance of 2.4 km from the wellpad. Cumulative impacts of geothermal emissions and volcanic emissions could create severe air impacts. Well ven~1ng and pipeline cleanout would exceed proposed ambient air standards. Off-line time with abated venting through the rock muffler may be substantial depending on the ability and future scheduling of the utility company to upgrade its electrical gt"'.i.d system.
:::::. l'~oJ.£~e Im~:Ja.r-ts Noise fl~om dt~iJling, fie?J.d development i:Hid operation and maintenance will be significant. County noise guidelines cannot be met for drilling~ venting and testing within at least a 3500' distance from the source.
4. §.roh!.n.9water: Impacts. c:Jeother·mal well c21.sin(:j ·fa .. i.lur-es, as h.3.'v'e been reported at the KS-1, KS-2 and HEJP-A, will affect future abilities of landowners to utilize the groundwater under their properties for agricultural and residential use.
5.. F'rOJ:.;).f:.?rty Values. A study contra.cted I:Jy ·the I<CA w=:>.s done t:o assess the effect of the HGP-A well siting on property values and occupancy rates. It concludes that from the early 1980s to the late 1980s, the prices around HGP-A have fallen between 35% to 42%. It concur-s wtih the DBED 500 i"1W f':t:PVif":'J"' !i"l3.rch 19891 which sta.te·::; t1·1at 11 ·for a.ll a f fee ted propel~ ties, the generc.:d opinion is that propt:::rty values are about one-half to three-fourths of what they would normally be. 11 The occupancy rates of an a.lmost seven-fold dif·ferenc:e ( ·fn:Jm 4~1.,
to 27%) between tax map plats close to the well and those farther away show a pronounced unwillingness to reside within one mile of the well.
6. 6.£.1.r::.i. ... <;.ul.t.ul~c.u_jmpacj;.§_ . The conflict for land u~;e .is dir .. r::,)ct <"1.:5
well as indirect with nuisance to workers, depressed land valuation to farm investors. increased cultivation costs to offset acidification, and potential phytotoxic effects on Hawaiian crops raised for their fresh market perfection.
12-1
7 ~ C:l~~.f:.~~lg~~1.:.i._<;__LJ..SL~~r.:.~;t;?..'~~ :; ·rh,:= i(npa.c t c)·f 1.3.\fEt ·f lcJ~··:t cj ~::.tr-c•r1q ~=~~J--·t~i· .. ,qL.t,:?.kt:?:::.
to a well or power plant facility would result 1n a l~ng recov?ry time a~d be unacceptable to both the neighboring community and the utility company. The community may have to be3r the costs of unabated venting while relief wells are being drilled or roads are being built to access the power plant facility. These relief wells may take about 45 days to drill, may be subject to overseas shipping of supplies, and may trigger emergency evacuation procedures for those with 2.5 km. The utility company may have to provide sufficient reserve capacity for its consumers by overloading generation from its other power facilities.
Without a development
buffer zone neighboring parcels subsidize geothermal by absorbing the adverse impacts of excessive noise and
air emissions.
The applicants by seeking withdrawal are relinquishing their rights to develop their property for geothermal electrical energy production. They are making a positive statement that Kapoho should remain the agricultural fruit and flower basket of the State and that the uses permitted under the land use zoning preceeding the GRS is preferred.
A buffer zone is essential no rights of neighbors uses already permitted.
to protect withdrawn parcels. It takes away to continue the agricultural and residential
We feel we have satisfactorily addressed the DLNR's six criteria for withdrawal set forth in detail in this preceeding itatement of purpose. The economic and environmental costs of geothermal development in Kapoho will far outweigh any benefit. Certainly, the benefit to property owners would be negative. The impacts to those within 2.5 km could be substantial and could force evacuation and relocation on a temporary and possibly permanent basis.
We hope the conclusion of the BLNR will be the same. We ask for approval of withdrawal of all these 74 parcels and for the granting ot a protective buffer of 2.5 km.
12-2
GfORGf IC. AHIYO!it
Ref. No. 2284 ,_ •• .~-. ....... ······- A,..{ijj
IN·IIJ V.£ [~~~~~~ 11 '" <NU·;v IJI'il~"·t 4
ktSI:AI<CH fiNO lCOr~ Nlt\11~1) lJi·,o~01'
Ms. Mary Miho Finley P.O. Box 367 Volcano, Hawaii 96785
Dear Ms. finley:
Mdy 21, 1986 C!IICL~ AtMII'<ISli<AiiVf ~Wd.$ Lttld
INIC.:M"loUN L~I.Cl
Attached is a sunmary of the HGP-A geothermal generating plant's forced outages since early 1982 that you requested at the May 16 Geothermal Advisory Cournittee Meeting and also indicated in Mr. Lesperance's office shortly thereafter.
I must en1phasize that for a number of reasons it would be erroneous to draw conclusions about future commercial geothermal plants from the HGP-A data. HGP-A was designed as a demonstration plant and 1t was not intended to be operated for more than a few years. It went on line after some start-up problems in the spring of 1982. In 1985 a decision by the Government owners was 111ade to continue its operation until a commercial geothermi11 plant cam~ on line. For purposes of planning equipment upgrade and accomplishing deferred maintenance, an additional five years life, i.e., to about 1990, was targeted. Because it was a demonstration plant and the first-of-a-kind, utilizing the unique Kapoho Reservoir geothermal resources, the operation and maintenance has been a learning experience. finally, in order to minimize operating costs so as to reduc~ a severe debt incurred with start-up problems. the Government owners have not had an on-site owner's representative.
In spite of the above, less-than-optimal conditions, the plant has performed quite well in terms of percentage of the t'ime on line. Note that some of the plant off line incidents were attributed to problems with the utility's transmission and distribution system. Some of the off line periods were not unschedul~d. For instance, there were the following overhaul p~riods that were scheduled months in advance:
.
7/31/83 to B/15/83 9/17/84 to 9/21/84 9/3/85 to 9/18/85
351 hours:27 minutes 76 hours:56 minutes
359 hours:56 minutes
In addition, there were shorter off line periods such as the ones that occurred on August 14 and 15, 1985, and January 30, 1986, that while not scheduled Jn the sense of an overhaul, were of the nature that there was so~e d~yree of flexibility in determining exactly when to take the plant off line.
' The report for the period March 1982 to August 1982 is ~.little
dlfficult to read. You might call Norman Uchida at HELCO to ask lf you can look at HELCO's flle copy which I believe should be more leg1ble.
TY/GOL:stk
At tactunen t
cc: William Coops, RCUH Jack Huizingh, NELH Frank Kennedy. H£LCO
Sincerely,
~~ Mttu·,.;, h Takeshi Yoshihara
Energy Program Administrator
A'l'TACHMEN'f 1-A
-------------
II. ISCST Modeling
The Industrial Source Complex Short Term (ISCST) model was used to assess
contributions to ambient concentrations in low terrain near the PGV property
boundary. ISCST is suitable for terrain with elevations below the lowest
emission height. For this application, ISCST was used in the flat-terrain mode,
i.e., source and receptor ground-level elevations were not used. Receptors were
located at 21 points on the property line boundary and at three distances (1.0
km, 1.5 km, and 2.0 km) for each of 36 azimuth directions in a polar coordinate
grid centered at the moisture separatqr at the power plant (UTM coordinates
301.51 km E, 2155.36 km N). This is the same receptor configuration used for
near field modeling, i.e., modeling of terrain close to the property boundary
where elevations are close to the source emission height, described in the
earlier Thermal Power Company Application for Authority to Construct (PGV, 1987).
This application also uses the same meteorological data base used in the 1987
application (PGV, 1987) and in the COMPLEX I model assessment, i.e., "Woods"
meteorological data collected during the periodUctober, 1982 through September,
1983. These data include stability classes based on Sigma Theta using methods
described in EPA guidelines (USEPA, 1986, 1987).
The same source data used for COMPLEX I modeling is also used, except that·
the pipeline cleanout emi~sion rate is based on a 20-minute release at 150,000 ~ - ..
lb/hour instead of a 30-minute release. Source data are summarized in Table 1.
ISCST results are presented in Tables 2-8. In these tables, receptor
locations are given as x (east-west) and y (north-south) distances from the
moisture separator at the power plant.
Table 2 gives maximum 1-hour average H2S concentrations for wellfield
operations at Wellpads E and F, and pipeline cleanout at the power plant moisture
separator. Table 2 results are from ISCST using the original meteorological
ATTACHMENT 2-A
Table 1
Source Data Used for Modeling
Emission Rate Stack Stack Stack Stack (g/s) Height Temperature Diameter Velocity Duration
Source ~ ~ TSP (m) ( 'K) (m) (m/s) (hours) ---~fllFIELD SOURCES
Dr 1111ng o.a81 0.1261 0.911 4.6 373 0.3 90.0 <11
Venting 14.76 12.61 25.22 4.5 379 0.203 485.0 4
Testing 0.74 0.18 0.18 5.9 373 1.85 7.0 240
Pipe line Fugtt lves 0.009 0.0001 0.0001 3.7 373 0.75 1.0 8760
Pipeline 0.102 0.102 Cleanout 8.20 1.0 373 0.75 72.0 1/3
POYER PLANT SOURCES
Fugitive Emissions 0.003 3.7 373 16.85 1.0 8760
Emergency 3.73 1.08 1.08 5.7 373 4.70 7.0 24 Steam (first hour) (first hour) (first hour) Release
1.87 0.54 0.54 3.5 (SOX (SOX (SOX (SOX
reduction) reduction) reduction) reduction)
!Hourly emission rates for well drilling are the total emissions during a well drilling event, divided by 1 hour.
2Hourly HzS eml~slon rates for pipeline cleanout ~re based on 24.59 g/s (195 lb/hr) for a maximum time period of 20 minutes. PM10 and TSP emission rates were calculated In the same way.
Uellpad E
1-Hour Average Uell field u2s Concentration Location
Cugtm3> X
Source !!at --1!!!L
Uell 1 58 -290 Drilling 2 57 -290
Uell 1 2361 2000 Venting 2 2361 2000
Uell Flow 1 22 ·290 Testing 2 20 ·290
Pipeline 1 113 340 Cleanout 2 113 340 Fuglt ive 1 8 ·290 Emissions 2 8 -290
y Cm>
-670 ·670
0 0
-670 -670
-610 -610 ·670 ·670
Table 2
ISCST Estimates of Maximum 1-Hour HzS Concentrations from Yellpad Operations
Uellpad F
1-hour Average Uellffeld HzS Concentration
Source !.!!!t <ustm3>
Uell 1 54 Drill Ins 2 54
Uell 1 2361
Venting 2 2331
Uell Flow 1 19 Testing 2 18
Pipet ine 1 113 Cleanout 2 113 Fugitive 1 9 Emissions 2 9
1rhese values wilt not occur because well venting wilt be restricted to daytime with wind speed ~4 mts.
Source: Aerometric Monitoring Inc.
Location X y
(m) -'.!!!L
0 -750 0 ·750
1732 1000 347 1970
0 -750 342 ·940
340 -610 340 -610 340 ·610 340 ·610
(See Table 4).
data, i.e., unmodified for daytime wind speeds C!: 4 m/s. The highest 1-hour
estimate was 236 ~g/m3 for venting at Wellpad E and occurred at a distance of
2 km from the power plant {-2.5 km ENE from Wellpad E). Results for Wellpad F
were similar. For pipeline cleanout, the maximum estimate was 113 ~g/m3 and
occurred on the property boundary -0.7 km SSE from the moisture separator. Table
3 gives particulate concentration estimates from Wellpad E operations and
pipeline cleanout. The highest 24-hour PM10 and TSP concentrations were from
well venting. Other source contributions were very small.
As described in the COMPLEX I model report, a modified meteorological data
set was used to test the hypothesis that restriction· of venting and pipeline
cleanout to daytime periods with wind speeds greater than 4 m/s would reduce
resulting concentrations to levels below ambient standards. This modification
is described on pages IV-4 and IV-5 of the COMPLEX I report {AMI, 1989). Results
from ISCST using the modified meteorological data are shown in Table 4.
Restricting venting to daytime conditions with wind speeds greater than 4 m/s
reduced the maximum 1-hour average H2S contribution 120.4 ~g/m3 • There was no
change for pipeline cleanout from the results shown in Tables 2 and 3. Pipeline
cleanout emissions are released at a very low height {emission height = 1 m) and
the maximum estimate of 113 ~g/m3 occurred with a wind speed of 6. 7 m/s {15 mph) ..
(The implications of high wind speeds on downwind concentration estimates are
discussed in Section IV of this addendum). The estimate of 113 ~g/m3 is for
source data given for pipeline cleanout in Table 1, based on a flow rate of
150,000 lb/hour for 20 minutes. Higher flow rates may be used, with the effect
that, because of corresponding variations in exit parameters, downwind
concentrations estimated by ISCST are yet lower.
ISCST estimates of contributions to ambient H2S and particulate
concentrations resulting from power plant operations (fugitive emissions,
Table 3
ISCST Estf.ates of Maximum Particulate Concentrations from Uellpad E Operations
24•Hour Average Annual Average4
PH10 TSP Locatfo!J PM10 TSP Location Uellfield Conc:entr!tfon Conc:en!:(•t I on X y Conc:en~atlon Conc:e~ratf on X y ~ Rank Cug/m > Cug/m > Cm) Cm> Cus/m > Cug/m ) (m) -1!!!L
Uell 1 1 0.3 2.5 ·290 ·670 Dr itt lng 2 0.3 2.5 ·290 ·670
Uell 2 1 33.6 67.1 2000 0 Venting 2 33.6 67.1 2000 0
Uelt Flow 1 1.6 1.6 ·500 ·866 0.18 0.18 ·500 -866 Testing 2 1.5 1.6 -290 -670 0.18 0.18 ·643 -766
Plpellne3 1 0.1 0.1 340 ·610 Cleanout 2 0.1 0.1 340 -610
Fugitive 1 <0.1 <0.1 -290 -670 <0.1 <0.1 -290 -670 Emissions 2 <0.1 <0.1 -290 -670 <0.1 <0.1 -590 -680
124-hour average for well drilling calculated as 1-hour average divided by 24 (maxi nun tIme period "' 1 hour).
224-hour average for welt venting calculated as 1·hour average divided by 6 (maximum time period"' 4 hours). Uell venting Impacts are much less when restricted to daytime venting with wind speed ~4 m/s. ·
324-hour average for pipeline cleanout calculated as 1-hour average divided by 24 (maximum time period • 1 hour)
4Annual average for welt drilling, well venting and pipeline cleanout were not calculated because operation periods are less than 1 day.
Source: Aerometrlc Monitoring Inc.
Maximum 1-Hour H2s Concentration
(ugtm3l
Venting, We llpad E ~
1 120.4
2 112.4
Venting, We llpad F
Rank
114.1
2 111.9
Table 4
ISCST Estimates of Maximum H2s and Particulate Concentrations from Well Venting when Restricted to Daytime, Wind Speed ~ 4 m/s
Maximum 24-Hour Maximum 24-Hour PH10 Concentration TSP Concentration
(ug/m3l (ug/m3)
17.1 34.3
16.0 32.0
I
16.2 32.5
15.9 31.9
X y (m) (m)
-174 -985
-960 -280
0 -1000
0 -1000
emergency steam release) are given in Table 5. The hi9hest contribution to 1-
hour H2S concentrations was 14 ~g/m3 for emergency steam release during the first
hour of an event.
ISCST results from combined cases, the same cases considered in the COMPLEX
I analysis, are shown in Table 5, 6, and 7. Estimates given in these tables
for Cases 1, 2, and 4 are upper limits based on maximum estimates from individual
sources, summarized in previous tables. The combined contribution from Case 3
sources was estimated by running ISCST separately using the modified (daytime,
wind speeds~ 4 m/s) meteorological-data set, as this group is dominated by well
venting. The maximum contribution to 1-hour H2S concentrations was 120.6 ~g/m3 ,
with venting at Wellpad E. This is only 0.2 ~g/m3 greater than the estimate for
Wellpad E venting alone. The maximum contributions to 24-hour average PM10 and
TSP concentrations were also for Case 3 and were 17 ~g/m3 and 34 ~g/m3 ,
respectively, as shown in Table 7.
ISCST results are summarized in Table 8. The highest contribution to 1-
hour average H2S concentrations was 120.6 pg/m3, which resulted from Case 3 with
venting at Wellpad E. This is 18.4 pg/m3 below the proposed Hawaii standard of
139 pg/m3• The second-highest contribution to 1-hour average H2S concentrations
was 114.1 pg/m3, which resulted from Case 3 with venting at Wellpad F.· The
highest estimated 24-hour average PM10 contribution was 17 pg/m3 (Case 3, venting
at Wellpad E) and the highest 24-hour average TSP contribution was 34 ~g/m3 (Case
3, venting at Wellpad E). These are both considerably below ambient particulate
standards.
.·
Mr. William Paty Department of Land P.o. Box 373 Honolulu, Hawaii
Dear Mr. Pa tyz
and Natural Resources
r.:arch
We would like to express our regret that written notification was not provided to affected property owners of the public hearing scheduled for August 7, 1984 at thG· Pahoa High School, or any subsequent public hearings, held in regard to Geothermal Subzone Designation Areas.
The response to this public hearing would have been greater had all property owners,resident and non-resident, been notified by mail.
Under Chapter 91, Adminsitrative Procedure (91-9.5) Notification of hearingzservice (a) Unless otherwise provided by law, all parties shall be given written notice of hearing by registered or certified mail with return receipt requested at least 15 days before the hearing.(b) Unless otherwise provided by law, if service by registered or certified mail is not made because of the refusal to accept service or the board and it's agents have not been able to ascertain the address of the party after reasonable and diligent inquiry, the notice of hearing may be given to the party by publication at least once in each of two successive weeks in a newspaper of general circulation. The last published notice shall appear at least 15 days prior to the date of the hearing.
Does "Unless otherwise provided by law" mean that an amendment or law has replaced these Administrative Procedures under Chapter 91 (91-9.5)?
Recently property owners affected received a notice of public hearing by mail in regard to Geothermal Resource Permit (GRP 89-1). Under provisions of Rule 12(12-5) Hearing and Notification (c) Promptly after the Planning Director fixes a date for the public hearing the applicant shall mail a notice of hearing to owners of interests in properties as shovm on the current real property rolls at the Real Property Tax Office, within a minimum of 300 feet of the perimeter boundary of the property for which the permit is being requested.
The provisions of both of these respective Rules provide for notification by mail. Does not the State and it's agencies have the same access to the real property tax rolls as the County to "Ascertain the address of the party after reason<J.ble and diligent inquiry"?
Not every property owner,resident ar non-resident, su~scribes to the newspaper. We feel that it would have been more f'orthrL~ht · for all affected property owners to be contacted by mail in cr-Jer to hear contested cases from resident and non-resident o~ners.
·-vhy did the Board not follow the provisions mandated in sE;cti ons (a) and (b) of Chapter 91 ( 91-9. 5) Hawaii Revised St~1 tutes
-------------------ATTACHMENT 3-A
for Notification of Hearinga service, for the puLllc hearinf held August 7, 1984 at the Pahoa High School?
Under the provisions of Chapter 205 (205-5.2) Designation of areas as geothermal subzones (a) Beginning in 1983, the Board of Land and Natural Resources shall conduct a county by county assesment of areas with ~eothermal potential for the purpose of designating geothermal subzones. This assesment shall be revised or updated at the discretion of the board, but at least once each five years beginning in 1988.
Was an assesment revised or updated in 1988, and if so,what are the particulars as to the date, time, and place of this assesment at that ti~e? ·
Any answers to these questions would be helpfu .. to us in assesing our own situation in regard to these matters. Thank you for your attention.
Sincerely yours:
Kapoho Community Assoc. Jane· Hedtke,secretary.
J i'·j . ,;
~ .. :v:.t ... L. (.J.~' /1-rlj _., ( /. r ·-1/-r-1~·
p.o. Pox. 137 fa.Aoa-; 1/tiwt-ii 9t-1/3
JOHN WAIHEE
OVERNOR OF HAWAII
STATE OF HAWAII
DEPARTMENT OF LAND AND NATURAL RESOURCES
Mr. & Mrs. Richard Hedtke P.O. Box 937 Pahoa, Hawaii 96778
Dear Mr. & Mrs. Hedtke:
P. 0. SOX 621
HONOLULU. HAWAII 96809
MAY 2 4 i989
WILLIAM W. PATY, CHAIRPERSON
BOARD OF LAND AND NATURAL RESOURCES
LIBERT K. LANDGRAF
DEPUTY
AQUACULTURE DEVELOPMENT PROGRAM
AQUATIC RESOURCES CONSERVATION AND
ENVIRONMENTAL AFFAIRS CONSERVATION AND
RESOURCES ENFORCEMENT CONVEYANCES FORESTRY AND WILDLIFE LAND MANAGEMENT STATE PARKS WATER AND LAND DEVELOPMENT
Thank you for your letters of March 20 and 28, 1989, concerning the designation of geothermal resource subzones. The following is in direct response to your questions concerning requirements for notification of public hearings:
1) Prior to the holding of the public hearings and the designation of geothermal resource subzones by the Board of Land and Natural Resources, several public information and participation meetings were conducted by the Department on the Island of Hawaii. Following are the dates and places of these meeting:
May 8, 1984 ....................... Hilo, Hawaii May 29, 1984 ...................... Hilo, Hawaii July 10, 1984 ..................... Pahoa. Hawaii July 11, 1984 ..................... Volcano, Hawaii
2) Statutory public hearing notice requirements for subzone designations prior to 1986, required that public notice be published on three separate days in a newspaper of general circulation statewide and in the county in which the hearing is to be held. Following are the dates and newspapers in which the notices of public hearings were published:
August 4, 6, 13, 15, and 21, 1984 August 5, 6, 13, 15, and 21, 1984
Honolulu Star-Bulletin Hawaii Tribune Herald
3) During 1986, Chapter 205, HRS, was amended and now requires that in addition to the publication requirements described in item (2) above, copies of the notice shall be mailed to all owners of record of real estate within the proposed GRS area. and to those owners within 1000 feet of the area proposed for designation as a geothermal resource subzone.
4) Your reference to Section 91-9.5, HRS, entitled "Notification of hearing; service" pertains to written notice for contested case hearings and does not apply to the subzone designation process.
ATTACHMEN1' 3-B
Mr. & Mrs. Richard Hedtke -2-MAY 2 4 l989
5) In regard to the County Geothermal Resource Permit (Rule 12), the requirement for written notification from the Planning Department to landowners within 300 feet of the boundary of tl)e property for which the permit is being requested, is a direct result of the same legislative action which amended Chapter 205, HRS, as described in item (3).
6) To date, the Board of Land and Natural Resources has not revised or updated its county-by-county assessment of potential geothermal resource areas. The Department will be conducting a review of the earlier statewide assessment as provided by Chapter 205, HRS, and will make a recommendation to the Board of any revisions, if required.
We hope the above answers your questions on the designation of geothermal resource subzones. Should you have any questions, please contact Manabu Tagomori at 548-7533.
,.. =~R~E R. ARJYC"£.1"11
STATE OF HAWAII
DEPARTMENT OF LAND AND NATURAL RESOURCES
~Is • Jean B • Willhite P. 0. Box 1310 Pahoa, Hawaii 96778
Dear I.ls. Willhite:
P. 0. BOX 621
HONOLULU. HAWAII 96809
tfOV 1 9 1984
SUSUMU ONO, CHAIRMAN
BOARD OF LAND & NATURAL AESOUACES
EDGAR A. HAMASU
DEPUTY TO THE CHAIRMAN
DIVISIONS: AQUACULTURE DEVELOPMENT
PROGRAM AOUATIC RESOURCES CONSERVATION AND
RESOURCES ENFORCEMENT CONVEYANCES FORESTRY AND WILDLIFE LAND MANAGEMENT STATE PARKS WATER AND LAND DEVELOPMENT
On September 28, 1984 we received your letter regarding the proposed designation of the Kilauea lower east rift geothermal subzone. You requested that your land be withdrawn from the proposed subzone.
The geothermal subzone designation process is designed to identify broad areas of land where potential geothermal development may be considered. Th<3 enabling legislation, which provided the framework for the designation process, doe.:; not provide for the type of spot zoning you requested. Therefore,· it would be inappropriate to honor your request that your land be removed from the proposed Kilauea lower east rift subzone.
However, as a surface landowner, no geothermal development can occur on your land without your consent. Consequently, the designation will not permit any activity on your land that you do not expressly approve.
In addition, any request to develop geothermal facilities in the proposed Kilauea lower east rift subzone must receive approval from Hawaii County since this entire area is zoned agricultural. The County is currently drafting pro?osed rules pertaining to Geothermal Resource Permits. Accordingly, any decisions regarding development of this area must go through the County. You may wish to contact the County Planning Office if you have any questions or comments regarding these permits.
Thank you for your interest in this matter • •
Very truly yours,
p~ fu'suMuoNo
Chairperson of the Board
ATTACHMENT 3-C
I
a I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
GODDARD & GODL .D ENGINEERING - ENVIRONMEl\-''AL STUDIES Page 65
TABLE 20
HEALTH EFFECTS OF HYDROGEN SULFIDE ON HUMANS
Concentration Effects
0.020 to 0.039 0.028 to 0.055 Harmful effects on adults and the growth of young organisms especially infants~
0.070 0.098
0.086
Affects light sensitivity of the eye.
0.12 Increased incidence of mental depression, dizziness and blurred vision.
0.32 0.45 Increased incidence of nausea, loss of sleep shortness of breath and headaches following chronic exposure.
0.71 to 7.1 1.0 to 10 Increased incidence of decreased corneal reflex (convergence and divergence) after chronic exposure.
7.1 to 50 10 to 70 Irritation of conjunctiva, fatigue, loss of appetite and insomnia after chronic exposure.
10 to 15 14 to 21 Conjunctival and corneal inflammation, "threshold of irritation" according to Gurinov.
50 to 107 70 to 150 Irritation to eyes, i.e., conjunctivitis and keratitis with photophobia, after several hours of exposure •.
50 to 100 70 to 140 Sub-acute poisoning, mild conjunctivitis and mild respiratory tract irritation after one hour exposure.
100 140 Slight symptoms may appear after several hours.
--------------
ATTACHMENT 4-A
Reference
Glebova c.b. Loginova (1957)
Tuan c.b. Meyer (1978)
Schieler c.b. IIEQ (1974)
u.s. Public Health (1964) c.b. IIEQ (1974)
Rubin and Arief (1945), Lewey (1938) c.b. IIEQ (1974)
Barthelmy (1938) Masure (1950), Ahlborg (1952), c. b. IIEQ ( 197 4)
Butrin, Arkhangels' kii c.b. Gurinov (1952)
Deveze (1957), Beasley (1963), Nyman ( 19 54 ) , c.b. IIEQ (1974)
Yant (1930) c.b. Moyer (1978)
Fairhall (1957) c.b. Moyer (1978)
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
GODDARD & GODD~ ENGINEERING - ENVIRONMENT. STUDIES Page 66
TABLE 20 (Continued)
HEALTH EFFECTS OF HYDROGEN SULFIDE ON HUMANS
Concentration Effects
100 140 Paralyzes the olfactory nerve.
70 to 150 98 to 210 Slight symptoms after several hours exposure.
107 to 210 150 TO 300 Slight systemic symptoms after many hours of exposure; possible hemorrhage and death within 48 hours.
150 210 Olfactory paralysis almost immediately.
160 225 Olfactory paralysis.
160 225 Irritation to respiratory tract and eyes within 1 hour, becoming more severe with longer exposure, i.e., conjunctivitis, bronchitis and keratitis with photophobia.
170 to 300 238 to 420 Maximum concentration that can be inhaled for one hour without serious consequences.
200 to 300 280 to 420 Sub-acute poisoning, marked conjunctivitis and respiratory tract irritation after one hour exposure.
210 to 360 300 to 500 Nervous system depression.
210 to 360 300 to 500 Slight systemic symptoms within 4 to 8 hours, hemorrhage and death within 48 hours.
Reference
Poda (1966)
Henderson & Haggard (1943) c.b. Moyer
Henderson & Haggard (1943), Haggard (1925), c.b. IIEQ (1974)
Evans (1967) c.b. DWR (1978)
IIEQ (1974)
Nyman ( 19 54 ) , Ahlberg (1952), Mitchell and Yant (1925), Carson (1963) c.b. IIEQ
(1974) I DWR (1~
Henderson & Haggard (1943) c.b. Moyer (1978).
Yant(1930) c.b. Moyer (1978)
Ahlborg (1952) c.b. IIEQ (1974)
Henderson & Haggard (1943), Haggard (1925), Mitchell & Yant (1925) c.b., IIEQ (1974)
GODDARD & GODDA.w, ENGINEERING - ENVIRONMEN'h ·4• STUDIES Page 67
TABLE 20 (Continued)
HEALTH EFFECTS OF HYDROGEN SULFIDE ON HUMANS
Concentration Effects
210 to 360 300 to 500 Irritation to respiratory tract, eyes and loss of smell within 30 minutes becoming more severe with longer exposure; photophobia and dypsnea (difficult breathing) within 4 hours, possible pulmonary edema.
360 to 500 500 to 700 Slight systemic symptoms within 4 hours, hemorrhage and death within 8 hours.
360 to 500 500 to 700 Irritation to respiratory tract and eyes and loss of sense of smell within 30 minutes; dypsnea, conjunctivitis and keratitis with photophobia within 1 hour. Possible pulmonary edema.
400 to 700 560 to 1,000 Dangerous exposure after 30 to 60 minutes exposure.
600 840 Fatal after 30 minutes.
500 to 640 700 to 900 Slight systemic symptoms within 1 hour, i.e. headache, dizziness; unconsciousness and death within 4 to 8 hours.
500 to 640 700 to 900 Serious irritation to respiratory tract and eyes within 30 minutes, i.e., coughing, bronchitis, pharyngitis, dypsnea, possible pulmonary edema, photophobia, conjunctivitis and keratitis.
500 to 700 700 to 1,000 Sub-acute poisoning, dangerous in 30 minutes to 1 hour.
Reference
Haggard (1925), Breysse (1961), Mitchell & Yant (1925), c.b. IIEQ (1974)
Henderson & Haggard (1943), Mitchell & Yant (1925) c.b. IIEQ (1974)
Haggard (1925), Breysse (1961), Mitchell & Yant (1925) c.b., IIEQ (1974)
Henderson & Haggard (1943) c.b., Moyer (1978)
Henderson & Haggard (1943) c.b. Moyer (1978)
Henderson & Haggard (1943), Mitchell & Yant (1925) c.b. IIEQ (1974)
Haggard (1925), Breysse (1961), Mitchell & Yant (1925) I IIEQ (1974)
Yant (1930) c.b. Moyer (1978)
GODDARD & GODD.L .J ENGINEERING - ENVIRONMENJ..,I{'L STUDIES Page 68
TABLE 20 (Continued)
HEALTH EFFECTS OF HYDROGEN SULFIDE ON HUMANS
Concentration Effects
640 to 1,000 900 to 1,400 Systemic effects predominate over local irritation effects. Systemic symp~oms within 30 minutes, collapse, asphyxia and death within 1 hour.
710 to 1,500 1,000 to 2,100 Lethal to man.
700 to 1,000 1,000 to 1,400 Possible acute poisoning, rapid unconsciousness, death.
700 to 900 1,000 to 1,300 Rapidly produces unconsciousness, cessation of respiration and death.
1,000 1,400 Rapidly fatal.
1,000 to 2,000 1,400 to 2,800 Acute poisoning, rapid unconsciousness, death in a few minutes.
1,000 to 2,000 1,400 to 2,800 Systemic effects predominate over local irritant effects. Immediate systemic symptoms, i.e., stimulation of respiratory (hypernea), followed by respiration inactivity (apnea) collapse, asphyzia and death within 30 minutes.
2,000 to above 2,800 to above Systemic effects predominate over local irritant effects. Paralysis of respiratory center; immediate death.
Reference
Henderson & Haggard (1943), Mitchell & Yant (1925), Simpson & Simpson (1971) c.b. IIEQ (1974)
Gurinov (1952)
Yant (1930) c.b. Moyer (1978)
Poda (1966)
Fairhall (1957) c.b., Moyer (1978)
Yant (1930) c.b. Moyer (1978)
Patty (1963) c.b. Haggard (1925) Haggard & Henderson (1922) c.b. IIEQ (1974)
Haggard (1925) Yant (1930) c.b. IIEQ (1974)
. i . ~~ · ..
By Frankie Stapleton .... .. : Trib..-Hcnld ... a wrl..,.
The Hawaii . County Plarinlng Commission voted Its apprOval ThUrsday of. seven~day-a-week geothermal drilling operations, on·· the condition . that· the· planning dir_ector can shu~ · .down geothermal operations if :noise-level guidelines are not.being met. ·
The . commission·. alSo ·accepted geothermal noise-level gUidelines drawn up by the Planning Department staff that de\·elopers claim are much more· stringent than exiSting federal or state standards. However, the planning staff's report adopts federal criteria as the basis for the county's guidelines.
The PlaMing Department staff recommended the commission approve the continuous drilling operations based on information from developers that fiveday-a-week· drilling Is riskier and more costly. ·
Thermal Power-Dillingham Corp. had requested release f~;"om a fivMays-a·weeW drilling restriction on two explorator} wells it plans to sink near the HGP.A well at Pohoiki.
"Loss of control or well.blow-<~ut Is the most serious hazard presented by repeated interruptions of the dynamic drilling process," planning staffer Brian Nishimura told the commissioners. He said five-day-a-week drilling operations would extend the drilling time necessary to 28 weeks, as . opposed to 20 weeks of WJinterrupted drilling.
Other conditions imposed on ThermalDillingham included the publication of a telephone number in case of noise or odor complaints, and that an employee be available at the drillsite 2• hours a day to respond to any such complaints.
A noise monitoring program, carried out three times a week by an independent analyst, was another condition imposed on the applicant.
Planning Director Sidney Fuke said the noise guidelines drawn up by his staff "are
· aimed at reducing the level of subjectivity" and apply to all geothermal activities, including drilling, exploration and operations.
"These noise guidelines are intended to provide the Planning Department with the necessary guidance to review and assess
r 1 bsntn:
'•'''
. :;· :.{··; ~ ';.:;. :;·:· ;. 'i .~. ' geothermal operations on a.·casHpeclflc basis to. determine whether· a significant noise nuisance exlsts"or-not," the commissioners were told; . :, . . .. .. ··
"Based on this reView, should the Planning Director find that the acceptable noise leyels are being exceeded and that
. the residents. are being signlficanUy adversely impacted by that noise, he can then Invoke {IlOre stringent noise mitigative procedureS or devices; or cease further geothermal activity." ··· · ·· .
Noting the qUiet acoustical enViroiunent of the district surrounding the island's center of geothermal exploration, and conditions which cause sound .waves to bounce around the· area, the county guidelines set the general noiSe. level of 55 decibels for daytime hours and 45 decibels be tween 7 p.m. and. 7 a.m., as measured at affected residences. ·(See accompanying chart for comparable noise source~.) ·
A l!klecibel increase in the general noise level lasting not more than two minutes within any 20-minute time· frame is also provided for in the guidelines.
However, .. Rebecca Bee.mer, spokeswoman for Thermal~Dillingham, said her company can't promise it will comply with the guidelines, which she called "most stringent," 100 percent of the time. :.
She also revealed . that · the Dieselelectric drilling rig equipped with special noise abatement mufflers, which ·TI!ermal-DillinghB.m said in its request for the change in drilling operations it would be using here; "has not been secured." .
Audrey Zubaty, a member of the Puna Speaks organization and a Leilani Estates resident, urged'the commissioners to deny the request for seveniiay-a-week geothermal drilling, claiming the 200 homes In the Leilani subdivision are in an "undeclared industrial zone."
She asked for air, water and noise pollution standards to be. ilpplemented on the county level, 'noting that state law allows for that.
"The county allowed the development of Leilani Estates knowing water would not be provided;" Zilbaty said, pointing out that Depadment of Health;\vater • .standards apply only to public drinking and well water.
She called for the adoption of local water standards to protect those dependent on
,_, , .•. ,
,·.
Typical noise level comparisons Ev.ryday nOIM Oeclbela
= • Medium jet engine (ctose) .,.;160!
11501 Air raid siren .. !140j ·
Level at which nolae 11..~ 130 ~ · beeomea painful ,..§' "§ Jackhammer .,. ~ ~
§.120~ Loud automobile hom .,. ~ ~
Loud thunder .. ~110~ Jet airliners .,. § ~
Garbage truek .,. ~100~
Heavy city trat1ie; &~lbway, § § elevated, and railroad trains .,. §. 90 ~
Inside motor bu~ .,. ~ 5
•• d:l!rttt· t
.·
Busy offa ... ~so~A; cu-....~r-<1. (' • ,.·,·"' Average street lrat1ie at earner .,. § § .l • , ..
Vacuum cleaner .,. ~ 70 ~ .:1.' ..,.__' .t I '- <·
= Normal speech .,. ;; 60 ~
Quiet residential neighborhood .,. ~ § Average home ... §..50~
Suburban ~ving room .,. ~ . ~
§.4Q.§ PubliC ~blary .,. § ~
::3Q.§ Bedroom et night ... ~ ~
Whisper ... ~ 20-§ Broadcasting studio .,. § §
~10~ Thrdhold of hearing ~~ 0 l'
.... ... J:.( - ~'
water catchment from "acid rain, hydrogen sulfide, mercury and other heavy trace metals including radio-active rad9n" that she said could result from geothermal operations In the area.
A nurse who is a Kalapana resident, Marilyn Richardson, said the provision allowing higher noise levels for two minutes In any 20 minutes could mean six minutes In any hour.
"That could really disturb a night of sleep," she said, adding that more homes are being built near the geothermal sites every day.
I
i
l
GEOTFIERMAL SYSTEM FAILURES: IMPLICATIONS
·FOR GROUND-WATER MONITORING
The ground-water quality impact of geothermal energy system's has yet to be determined. This article offers a discussion of these systems and the reasons for their failure as they relate to · future monitoring.
0y Forest L. Miller Jr. and oouglas E. Zimmerman
A U.S. Environmental Protection ~rncy grant to assess standard and innovative ground-water monitoring techniques and systems applied to geothermal energy development Impacts on associated ~round-water systems is currently underway. The research effort Is directed toward Integrating monitorIng techniques, legal constraints. production system fault-tree analysis and comprehensive solute transport and geochemical models. Anticipated results Will provide means to assess site-specific ground-water geothermal systems and to identifY the optimum monitoring methodology and network design to detect
I ground-water quality impacts. The models Will allow an evaluation of potential worst-case Impacts on the ground-water system.
Information on approximately 80
I geothermal energy system failures was compiled and reviewed during the course of this study. Failures
• have ranged from minor leaks in
I pipes and valves to uncontrollable discharge from wells resulting in the release of large quantities of geothennal fluid. Statistical analysis of the data collected provides a comparison of(ailure rates for different componentS of a geothermal development. Bdth a review of worldWide geothermal' well- and plant-failure data and a failure analysis utilizing fault-tree techniques to assess the r~oaJ points of ground-water moni-
.ng efforts are presented In this article.
Background
sian of geothermal energy to electricity Is In a transitional stage of development. The conversion can be performed In a cost -effective manner and the types of equipment necessary to operate safely and consistently are known, but the operating experience accumulated to date Is insufficient to assist in estimating failure rates With reasonable precision. Operating experience in the United States is limited to the Geysers Known Geothermal Resource Area(KGRA)which Is located 180km north of San Francisco. California This KGRA Is a vapor-dominated system as opposed to the more common liquid-dominated systems. some of which are being developed elsewhere in the United States. The most active areas of geothermal development In the United States are currently the Imperial Valley of California and sites In northern Nevada Internationally. power production at a significant scale from liquid-dominated reservoirs is on line at Cerro Prieto, Mexico, Wairakel, New Zealand. and several sites In Japan.
A number of technologies are available for the conversion of geothermal energy to electricity. The selection of the power conversion unit is controlled primarily by the chemical and temperature characteristics of the geothermal reserj.roir.
Generally there are two basic types of systems. The flash system allows the geothermal fluid to flash to steam. which Is then used to drive the turbine. The binary system utilizes a secondary fluid. such as freon or isobutane. which Is heated by the geothermal fluid to drive the turbine. Both systems are somewhat similar In that they require prod uctlon wells.
The technology for the conver- a system of pipes and valves for
moving fluid from the wells to the plant, a power conversion UAit. and in most cases. Injection wells for disposal of spent fluids.
Failure Data The high temperature. pressure
and chemical compost Uon of geothermal fluids are conducive to equipment failure (Table 1 ). A geothermal reservoir Is usually located in an active geologic environment containing faults and fractures which Increase the difficulty of drilling and the possibility of adverse environmental impact.
Detailed data on geothermal system failures are generally not available. The best-documented failures have been those associated With wells. Unfortunately. even these data are often lacking in such important Items as discharge rates. detection method and cause offailure. Failure data on equipment such as surface piping and energy conversion components are also limited (Sung et al. 1980; Summers et al. 1980).
On the basis of failure data collected. a review of geothermal site plans. and consideration of possible fluid release points. the folloWing components were considered for failure analysis:
• wells • wellhead assembly • surface equipment • disposal system.
Production Wells Well failure can occur In two dis
tinctly different operational modes. Failure can occur during the drilling of the well or during geothermal fluid production. To control the movement of formation fluids around the
f~"'"': 6:-" .... \.H\ ...J,~..H-..:_ ~1>/\o.~ :·H'·'\:J ~" (vi -·-
'Sf~.N~ fit~ \1:1.') f'J-='· d. ATTACHMENT 6-A GWMR/Spring 1982 23
I
I ·I
I
:J I
!
I
·I
:I: : .j
.. l
ij j. • !
' i.
.. \.)UL.::t-'Uio. U.i .. iU •. llo\o"-UU1..4""""t:'tUV'"'"•.....,•U6
tng and production. the 11-borc size is reduced with deptf~·'•'ll each reduction in hole diameter, the bore Is cased and cemented. An example of the casing and cementing of wells at Walrakei, New Zealand, is shown In Figure 1. Numerous tools and techniques exist for physically locating and defl ning the type and severity of casing failures. but only a modest amount of data concerning the actual cause of the failure can be acquired when the failure occurs hundreds of meters or more below ground level.
Failures during drilling operations can result in uncontrolled discharge from the well bore. This condition, known as a blowout. is of particular concern as uncontrolled discharge can last a significant length of time. The costs and difficulty of repairs are high. Blowout of a well is possible when the formation fluid pressure exceeds the pressure of the drilling fluid In the well bore. This condition can occur in zones of lost circulation. where the formation being drilled is either very permeable. has an extensive fracture or fault system or is cavernous. Blowout preventers which seal against the drill pipe in theeventofaslgntficant pressure drop are required safety equipment during the drilling of geothermal wells.
Many individuals from both private and governmental sectors believe.that drilling equipment and technology currently in use have proven sufficient to prevent well blowouts. The incentive to prevent this type of failure Is borne by the geothermal developer because of the high costs of drilling operations and subsequent costs of controlling a well blowout. A typical well at the Geysers KGRA costs between $825.000 and $1.6 million to drill and complete.
Because of difficulties in identifYing production well failure. the potential for adversely impacting associated ground-water systems is relatively high. Failure of a well casing can range from a minor fracture to:, a complete collapse. Discharge cah be very limited or can constitute the total flow of the well, resulting In a blowout conditton.lndications of casing failure can be as obvious as visual discharge at the surface or as subtle as a change in the chemical constituents of the fluid. Other Indicators of casing failure Include a reduction In flow or temperature, change tn the steam/water ratio, or Inclusion of sand or other formation
24 GWMR/Spring 1982
Initial Condition R~lting Failure
Mechanism Possible Failure
Point High temperature 1. Thermally Induced
stress All components-Well casing problems most severe 2. Thermal cycling
Poor quality fluids 1. Corrosion All components 2. Scale 3.Abrasion 4. Dissolved gases
Geologic environment 1. Drilling and cementIng problems associated with lost circulation zones·
Well casing
f-!igh pressure 1. Pressure induced stress
All components
Present stage of development
1. Inadequate All components materials
2. Inadequate design and workmanship
3. Lack of operating experience
Natural disasters or accidents
1. Landslides All components 2. Earthquakes 3. Accidents as a
result of personnel error
4. Vandalism or terrorism
material in the production fluid. Failure of the cement between the casing and the formation Is usually associated with casing failures. This can allow the geothermal fluid to migrate along the well bore and enter a formation different from that In which the original failure occurred.
A number of interrelated factors may contrtbute to casing failure:
• thermal stresses or thermal cycling
• inadequate cementing of the casing
• corrosion. The folloWing scenario describes the interrelationships of these factors:
During the drilling of a well, formations are encountered that are highly permeable. -When the well Is cased and ceml!nted. a poor cement bond betwien the casing and the formation 1s achieved In these zones. allowing the casing to differentially expand and contract The well ts completed and put Into production. The casing ts subjected to high temperature varlaUons causing thermal stresses. (The term thermal cycling is used to describe the expansion and contraction of the
casing as it is alternately put on production and then shut In as energy requirements or maintenance ofthe.well or power plant dictate.) The casing subsequentlv falls in the zone where the cement bondtspoorduetothethennru stresses associated with production. Failure can occur very early In the life of a well or can occur much later when the casing Is further weakened by both corrosion and thermal cycling. Analysts of casing failures in the
geothermal fields of Italy revealed that failures were more likely to occur after large temperature variations and that the lower part of the ~ casing string was more likely to fall (Cignt et al, 1975).
Again. the difficulty in Identifying the exact causes of casing failure should be recognized. Due to the limited amount of data that can be collected, It is dUTicult to precisely ' determine the cause of failure. During the time of data collection for this report both the literature collected and discussions with government and private operators have stressed the rapid technological improvements in both drilling and cementing techniques by the geo-
1-llCfllla.l llldUSLIJ'· lJaLa trom Lilt:
. .·. ~·.bllfornla Division of Oil and Gas • tdlratc there have been no serious
:~ 11 -oblcms with geothermal well drill· -. qn that state since 1975.lndlca-la
11cios are strong that Improved tech
nology has decreased failure rates 111 0 ewly constructed wells. As more ctala Is compiled. It may be possible 10 \'('rt(v this hypothesis and to identlf\' wells that are more likely to fall
l ~:their age.
)0
as ent Jr 1t al C·
ly •r Is
~ ) e I ~ I e I
I
1
wellhead Assembly The basis for separation of the
\\t·llhead assembly from other com-ponents of the piping system is the
11rntial for uncontrolled discharge ~ 1 he event of failure. The wellhead assembly typically consists of several ,-ai\'es which are used to regulate floW from the well. In the event of failure of other surface equipment, these valves could be closed to stop flow from the well. Failure of these ,a),·es to close due to either corrosion or scale would then result In uncontrolled discharge. Uncontrolled discharge related to wellhead failure also occurs If the enUre wellhead becomes separated from the well casing. This happened at Cerro Prieto. Mexico, but could have been avoided by proper Installation of the wellhead assembly.
Surlace Equipment In contrast to the difficulty in
identifying and repalrtng a well failure. failure of surface equipment is relatively easy to detect and repair. Costs of repair are relatively low and, generally. technically straightforward.
All components of the piping system are susceptible to failure as a result of corrosion. abrasion or scale formation. Dissolved gases. par· tlcularly H2S. also contribute to failure. Thermal stress and thermal cycling of above-ground pipes is not as significant a problem. U-shaped sections of pipe are routinely Installed in the line to allow for thermal expansion. Corrosion and abrasion_fan be expected to be higher WJlere the flow impinges directly on the pipe surface. as at an elbow whete a directional change in flow occurS.
Data on failure of surface equipment have come mainly from the r ~vsers KGRA. The principal failure . .nts of the surface equipment have not been associated with the major components found In the power plants but with the pipes and \'alves which transmit fluid between these components. Generally the fail-
~ 8" Safety Valve
Bleeder Valve
24.38m 18" OD Conductor Casing
13-3/8" OD Surface Casing
Cement Grout
8-5/8" OD Intermediate
12-1/4" Hole Casing
6-5/8" OD Slotted 7-5/8" Hole Production Casing
(O~n)
670.56m Hot Water
Figure 1. Typical casing design at Wairakei, New Zealand. (after De11erding. 1980).
ures have been detected and repaired withln60 minutes. Unfortunately. data from the Geysers is very atypical. This is adcysteam reservoir which does not require flashing and the injected condensate has total dissolved solids values that range from 300 to 1,000 mg/L In contrast to this are sues In the Imperial Valley where brines are produced with total dissolved solids as high as 300,000 mg/1.
Numerous studies have been conducted on corrosion. abrasion and scale formation rates at specific geothermal sites, but extrapolation of these data Into failure rates is
limited because of the experimental nature, limited time period and wide variation In fluid chemistries during these studies. Corrosion studies of various metal alloys in the Imperial Valley have shown that steels containing either molybdenum or chromium and molybdenum withstand corrosion better than the carbon steel pipes most commonly used (McCright et al, 1980). Because of the lack of operating experience in the United States. estimates of failure rates for surface equipment are based on data from nuclear power plants.
GWMR/Spring 1982 25
I
i ; I! I ; I
I I\
!J •
'j il -I
. I I: :I I I
j l :1 il
!I !
,, •'
.!
Disposal Systems I ' Current methods for disposal CJ...,,
geothermal fluids consist of either Injecting the fluid back Into the geothermal reservoir or disposing of the fluid on the surface (Table 2). Injection of spent geothermal fluids
Table :.'.. Uisposai .MeUlQCi"' at lieoU1enna.1 :::,1Les
Percent Site Injected Percent Surface Disposal Larderello,Italy 20 80 to surface streams I
rauurt . Data
' ~~~~ and Zlr
111ost fa or no dt
Is considerably more difficult and costly than surface disposal but It minimizes the adverse environmental Impact on ground water and surface water. It also prolongs the production life of the geothermal reservoir and prevents land subsidence. For these reasons, Injection studies have been conducted or are ongoing at most sites.
Injection of fluids at the Geysers KGRA has been-very successful due largely to the low total dissolved solids of the fluid. Of the total steam produced at the Geysers KGRA. 20 percent ts Injected and the remainder Is lost by evaporation In the coolIng towers. Estimates of fluid Injection at a llquld dominated reservoir uttllztng a flash-type system are as high as 87 percent of the total fluid produced (Table 3). Injection tests with fluids of poor quality In the Imperial Valley of California have met with severe scaling and plugging problems. Failure rates In both the piping components and the wells of an Injection system as a result of scale formation are likely to be higher than the same components used In the production system because equillbrium conditions have been disturbed by the reduction In temperature. A potentially serious problem with injection systems Is the mixing of fluids from a number of production wells. The formation of precipitates can increase greatly when fluids with different chemical
Wairaket. New Zealand 0 Otak.e. Japan 100 Hatchobaru. Japan 100 Cerro Prieto. Mexico 0
Ahauchapan. EI Salvador 30
Geysers, USA 100
compost tions and temperatures are rritxed. Individual production wells at Cerro Prieto. Mexico, have produced fluids with different chemistries and temperatures resulting In scale formation severe enough to force abandonment of the wells.
Injection offlutds into a geothermal reservoir ts done at depths either above or below the main reservoir to prevent cooling of the main reservoir. At the Geysers. Injection Is done at depths below the main reserwir and as far as possible from existing production wells. The wells used for injection are generally production wells which were poor producers. Failure during drilling of an injection well can occur in the same manner described for a production well. Since these wells are completed In zones of high temperature they are susceptible to failure by the same mechanisms described for production wells but temperature variations probably do not reach the extremes encountered in production wells. thus failures caused by ther~ cycling could be lower In injec_.
100 to Waikato RJver None None 100 to evaporation ponds and Sea of Cortez 70 discharged thru 86km long canal to ocean
None
tion wells. Problems with scaling are more Intense in injection wells and therefore failure rates by this mechanism could be higher than for i)roduction wells.
Potential Fluid Release Rates Failureofwellcaslngandsurface
pipes can result In discharges that range from very minor amounts to the total flow of the well. Production and Injection flow rates vary Widely between different geothermal reservoirs. Table 4 lists maximum known flow rates at KGRAs In the United States. These numbers represent the highest probable discharge rate in a production well blowout Data for Injection well flow rates are rather limited but generally the rates given are higher than those for production wells. The Injection rates given in Table 4 represent rates during Injection tests and do not necessarily represent the maximum Injection rate possible.
Table 3. Estimates of Geothermal Wastes From Existing Power Plants l I
Gas Wastes , I %gas/ steam \\1 T/yr x 10
1977 Fluid Production Rates1bl Total Power Plant Output. Reservoir Reservoir Well flow Condensate I<· I Dissolved Solids
Location MWe Type I a I Temp.'C T/MWh T/yr x 106 T/MWh T/yr X 106 ppm T/yr X 10:1
The Geysers. 600''11 4.651'
11 0.8 273 ·• 520 DS 200 7.5 4.2 1.7 7.74 USA
Larderello. 420 OS 220 8.9 32.7 1.3 4.78 NA NA 5 1640 Italy
WaJrakel. j l93 FS 260 44.8 75.7 1.8 1.47 4.400""1 333
New Zealand I 20.000"'1 Cerro Ptieto. 75 FS 270 31.5 20.7 1.3 0.854 414
2.2 333
1.2 49.7 Mexico
Hatctwbaru. 50 FS 290 20 8.76 0.8 0.350 4.700"'1 41.2 0.3 5.26 n
(aJ DS"' dry steam: FS" flashed steam. lbl Tonne/MWh = 1.000 kg/MWh. Yearly rates of 8.760 hr/yr assume continuous weU flow. lei Condensate flow vanes \\1th weather conditions. ldl TDS at the Geysers In condensate. It vartes from 300 to 1.000 ppm with weather conditions. (el TDS of wellhead fluids. At Cerro Ptieto. fluids In the evaporator pond have about 75.000 TDS.
From Defferding. 1980.
26 GWMR/Spring 1982
released ushlng ManY o cause o 11on ma rxpertei ures to releases rcsulte failures.
Fori 111aJ-4.d blew ou adequat 1echnlq lhC well present! In 1976. was est steam.' well nu zeaJanc drilled i fluid no casing t atadep probabl• tngarm to move dlschar rnately~ ber 19£ drilled i break.s uncont mated~
Fault-·. The
tree m en~rgy
both tl which geother sites of isconv• oftherr ally ide ureswc Forexa lng USI
could t meter occur piping conver: mons taken: wouldJ the pip piping Thepr•
------------------k ...... ·-~···~":atu-..~·--~·~d'~-~~,~··-~····•&~~-.-.~.-.. -.~~--~------·--~-..-~-. · -·· - ·r-ttstc wr zrmn · e err rr anc~·wm •• .,
., ~()-;;; ;n-~~r~ than 80 .failures rablc 5) were compiled during the
''~urse of this Investigation (Miller
1d Zimmerman. 1980). Although
I tT105t failure reports provided little (If no detail on the amount of fluid rt'lcased. they were valuable In estabushlng potential release points.
'
a,tarl\' of the failures occurred be~n1se of Inadequate well construe
! 110n materials or lack of operating I experience. The most difficult fail-
ures to control and the largest rt'lcases of geothermal fluid have rl'sulled from production well
- I {,dlures. For Instance. well numberTher-
('
d
0
n ly r· n
~ I .e I
~ l ~ I ~- ~ ·ty i n !
I J
I
X 10 (
3 '·
0
3
9.7
o.26
I l
mal-4.drilledat the Geysers In 1957, bleW out duriflg drilling due to lnadrquate casing and cementing 1tchnlques. Attempts at controlling lhe well have failed and the well Is presently discharging to the surface. In }976. the uncontrolled discharge was estimated at 80,000 kg/hr of steam. A casing break occurred in well number 26 at Walrakei. New 7.ealand. in April1960. The well was drilled in 1954 and had produced Ould normally up to the time of the casing failure. The failure occurred at a depth of 183m. Due to flaws and probable deterioration of the cementJog around the casing. flow was able to move upward and laterally. F1ow discharged at the surface approxlmately240m from the well. In Novem· ber 1960. well 26A was deviation drilled into well26 below the casing break. stopping the discharge. Total uncontrolled discharge was estimated at 6.17 x I 05 tons.
Fault-Tree Methodology The purpose of applying fault
tree methodology to geothermal energy development Is to Identify both the possible failure modes which would result In release of geothermal fluid and the possible sites of failure (Barlow et al. 1975 ).It is convenient to treat as a unl t parts of the mechanisms that are structurally Identical or parts In which fall· ures woul~·lead to a common effect. For examp e. the above-surface pipIng used t move geothermal fluid could be cOnsidered on a meter-bymeter basls since a failure could occur at any point. However. the piping from production wells to the l'Qnversion plant Is designed to com-
.on specifications and measures taken at any point to confine a leak would probably be taken throughout thepipingsystem.so the production piping can be considered as a unit. The production piping and Injection
Reported Flow Rates of Injection\'' .,sin the Uruwu bl.alts
KGRA
Production Well
tons/hr Salinity
Injection .Well 1/s
Salton Sea. CA Westmorland, CA Brawley.CA Heber,CA East Mesa. CA Beowawe. NV Roosevelt Hot Sprtngs. liT Valles Caldera. NM Raft River. 10
227 263
32 200 336 680 454
23
250.000-330.000 20.000- 70,000
100.000 14.000 2.500 1.400 7.800 6.000
Iss•• 14
Geysers.CA 68. 79 76 38 Niland, CA
• Average flow rate ••Estimated value
Table 5. SummaryofReported Failures From Geothennal Sites in the U.S., Mexico and New Zealand
Failure Point Drilling fatlure Production well Production wellhead · Surface piping Injection wellhead Injection well
piping would be considered separately since there are likely to be more corrosion problems in the production piping than in the injection piping while the reverse is true with respect to scaling. The energy conversion system would be considered as a unit since a failure in this system could result in release of fluid to the floor of the building and remedial action would be the same. A fault-tree figure (Figure 2) can be used to provide an overview of the system.
For demonstration purposes. the · fault-tree methodology will be applied to a modified conceptual design of a double flash geothermal development presented by Sung et al. 1980. The modified design con· ststs of 28 vertically drilled production wells with 12,200m of associated· production piping which will deliver the geothermal fluid to the power plant located 300m from tile edge of the well field. The system utilizes 15vertlcallydrilled Injection wells which requires 8.800m of ill~tlon piping.
For the purposes of this example. the energy conversion system will be placed on the Roosevelt Hot Springs KGRA. near Milford, Utah. This Is a liquid-dominated system
Number of Failures 3
28 3
49 I
None reported
with a depth to the top of the reservoir of 820m. We assume that wells drilled in this development will average 900m In depth. The principal ground-water reservoir In the Milford area Is the unconsolidated valley-fill alluvium. Well logs reveal that this material is between 60 and 150m thick In the KGRA and It is assumed that each well passes through a vertically unconfined aquifer. A1, 110m in thickness. Logging of well DH 14-2 revealed a cold water entry zone. between 200 and 230m. which will be treated as if it were a confined aquifer. ~· of potential importance as a source of domestic or agricultural water.
For convenience we assume that distribution oflocatlon ofweU casing failure Is Independent of depth. We further assume that an aquifer Is only contaminated If the failure occurs within the aquifer. Therefore. if there Is a casing failure in the zone of aquifer~ the probability (p) of contaminating aquifer A2 Is 1. If the failure occurs elsewhere. the probability of contaminating aquifer ~is zero. The probability of contaminating aquifer A2• given that the well has failed. is the ratio of the thickness of the aquifer to the depth of the well. 30/900, or .03. Likewise.
GWMR/Spring 1982 27
i I'
l: !
I
I' :I :.
I I
I I I
I
1
' I
l . the probability of com Jnating aquifer A1• given a failure 1n the well. Is 110/900,or.12.Theprobabilltyof not contaminating aquifer A;_ by one or more of the 28 production wells In a given calendar year Is p28•
where 1-p Is the product of the probability that A;_ will be contaminated given a failure (.03) and the probability that a 900m well Will faJl In a year. Data from the Wairakel field Indicates that the probability of a 900m production weU failing In a calendar year Is about .0 14. Therefore. theprobabilitythatagtven well Will fafllnacalendaryearand that it will contaminate aquifer ~ Is .00042. The probability of one or more production well failures In a calendar year which contaminates aquifer~ is 1-.9995828 or .0 1. This analysis Is tentative and further work Is required to refine the estimated probabllltyoffailureofa well. By Identical logic. the probabiUty of failure In a calendar year of at least one Injection weD which impacts aquifer A:!Js .006.
Using the above reasoning. the probability of contaminating aquifer A1 duringacalendaryearbyproductlon weD failure Is estimated to be .05 and the probability of contaminating A1 by failure of an Injection well ts estimated to be .02. Injection of geothermal fluid Is not done at Walrakei and probabtlltles computed assume the same life expectancy of Injection wells as for production wells.
Probabilities of failure of aboveground components were estimated by Sung et al. 1980. from data compiled in the Reactor Safety Study of 1975 (also knownasWASH-1400or the Rasmussen Report). They estimated that theprobabllityofamajor wellhead rupture In this geothermal energy conversion design during the 40-year design life is .008. Further, they indicate. "Minor leaks are to be expected. Each gasket In the system would be expected to fall at least once during the assumed 40-
~ year design life." If we assume that · the probability of a major wellhead j failure Is constant over Ume. then
1 the probabtllty of a particular well! head falling In a given calendar year
Is estimated to be .000005. the probability of there being at least one production wellhead failure in a calendar year Is estimated to be .OOOl.and theprobabllttyofatleast one Injection wellhead failure in a calendar year Is estimated to be .00007.
If the probability of fallure of plptngts 1 x l0" 10/hr/300m(Sungetal.
28 GWMR/Spring 1982
s:=s C' u a zm c · r:s ,_. 1ft ·•M•t· t'SWMs ti4~M *
Source Release of fluid due to
Casing failure in region of lower confined aquifer~
Casing failure in region of upper unconfined aquifer A1
Malfunction of production valvi~
Break in surface piping
Failure in the power plant
Break in surface piping
-
Malfunction of injection valving
Casing failure in region of upper unconfined aquifer A1
Casing failure in region of lower confined aquifer~
Release To the geothermal reservoir area
F1QUI8 2. Prototype fault·tree for a geothermal energy conversion system.
1980) then the probabill ty ofat least one failure lil12.200m of production piping In a calendar year Is .00004 while the probabtUty of at least one failure In 8.800m of injection piping during a calendar year ts .00003. These numbers are applicable to piping in a nuclear reactor. butlt to more stringent specifications than geothermal piping. and the estimated probabilities of failure may be too low. On the other hand. the stresses may not be as severe.
The probability of a major failure of the conversion system during Its 40-year design life Is estimated by
Sung. et al. to be .001. Makin!-!: tht' assumption that these failures art' distributed uniformly over the -tOyear Ufettme. the probablllty of fail· ure In a calendar year ts esumatt-d to be .00003.
Fault-Tree Summary Whfle It is important to acquirt'
more failure data. Including data on faflures of the same types of equip· ment in similar environments. It IS unlikely that this wtlllead to ~.us· factory precision of estimates ot tail· ure rates soon because conversion
.'1 o.f heat from geothermal fluids to~
'electricity is a relatively recent""' ' a,c,Uvity. Because of that. determina-
• tion of reasonable coefficients of variation for the small probabilities of failure estimated In Table 6 are unlikely until considerable operating experience has been acquired. Table 6 does demonstrate in a relative sense that the highest proba-
' bility of failure is associated with wells. Since well failures are difficult to detect. can involve large volumes of fluid and can directly impact ground-water resources. the focal points for ground-water monitoring should involve both production and injection wells. lvingl
ter
reo
Acknowledgments The authors wish to acknowiedg~
support under Grant No. RB06457 from the U.S. Environmental Protection Agency. Environmental Monitoring and Support Laboratory. Las Vegas, Nevada: Roy Evans, project officer. The authors would also like to thank John Hess for his help In vartous aspects of this project.
References Barlow. R. J. Fussell and N. Slngpur
walla. 1975. Reliabilltyand faulttree analysts. Society for Industrial and Applied Mathematics, Philadelphia. Pennsylvania.
Cignl, u.. F. Fabbri and A. Giovannoni. 1975. Advancement in cementation techniques In the Italian geothermal wells. Proceeding Second UN Symposium on the Development and Use of Geothermal Resources. San Francisco, California.
Defferdlng, L. (editor). 1980. State-
-of-the-artofllqutd waste disposal
I for geothermal energy systems: 1979. U.S. Dept. of Energy publication no. DOE/EV-0083.
1 McCright. R. W. Freyand, G. Tardiff. 1980. Localized corrosion of steels -the ·
art -tOfail· tted
. tire
.l oil f Llip· it IS
~tiS• I fall· ;ioll
I
In geothermal steam/brine mixtures. :Geothermal Resources CounctJ Transactions. v. 4.
Miller, F. <¥1d D. Zimmerman. 1980. Compllhtion of failure data and fault-tr~e analysts for geothermal energy conversion systems.
· Desert Research Institute. Project No. 41071.
1ummers. K. S. Gherine and C . Chen. 1980. Methodology to evaluate the potential for grounc;lwater contamination from geothermal fluid release. U.S. EPA PUblication no. EPA-600/7-80-117.
"Falale 6. Relative Annual Prob::Wilities of Failure of Major Components of a Dou......., Flash Geothermal
Conversion System
p Cause .01 .05 .0001 .00004 .00003 .00003 .00007 .02 .006
Production well failure contaminating aquifer Az. Production well failure contaminating aquifer A1 Production wellhead failure (major) Production piping failure (major) Failure In conversion system (major) Injection piping failure (major) Injection wellhead failure (major) Injection well failure contaminating aquifer A1 Injection well failure contaminating aquifer Az.
Sung, R, W. Murphy, J. Reitzel. L. Leventhal. W. Goodwin and L. Friedman. 1980. Surface containment for geothermal brines. U.S. EPA publication no. EPA-600/7 -80-Q24.
Biographical Sketch
Forest Maler is a research pro-fessor at the Desert Research Institute, University of Nevada. He received.aBSandMSfromPurdue University and a Ph.D. from North Carolina State University, aU in statistics. By profession he is a consulting statistician, with research interests in spatial analysis, reliability of complex systems and model evaluation.
Douglas Zimmerman is a research associate at the Desert Research Institute, University of Nevada. He received his BS in geologyfromSanDiego State University in 1975. His primary pro-
fessional emphasis has been in the design, construction and testing of monitoring and production wells.
GWMR/Spring 1982 29
GEDT/£RIAL PRLPERTY ms&IENr SUBZlll WITHlRAIW. IR>Llr.ATIIJI
PLAT PARCEL IDEl&: IRI\Ill.S M1TE Y74 Y79 Y.!l YBl Y82 Y83 y~ Ylfi ya; Y87 YBB Y89 ------------- ----------~ 2 1.13 R 33811 15M ~· 3 1 R 33811 15181 ~ 4 1 R 33M 15a 46 5 1 R 15018 46 7 1.54 R 278 12588 46 8 1.46 R 21518 12588 ~ 13 1 R &E115 15M ~ 14 1 R 1sa 46 15 1 R 15M ~ 16 1 R 15M 46 17 1.13 R 15181 158 ~ 18 1 R 158 -~ 19 1 R 158 -~ 21 1 R 1sa 7518 ~ 22 1 R 15018 46 23 1 R 13681 46 24 1 R 17611 ~ 25 1 R 13611 ~ 29 1 R 15M ~ 38 1.13 R 1-~ 31 1.13 R 258 ~ 33 1.12 R 16711 ~ 34 1.13 R 16711 ~ 35 1.12 R 16711 46 36 1.13 R 16711 ~ J7 1.13 R 16711 1-~ 38 1.13 R 16711 1-~ 39 1.12 R 16711 15M ~ 41 1.13 R 1- 13418 ~ 41 1.12 R 1-1-~ 42 1.12 R 1-~ 43 1.12 R 1-46 " 1.13 R 13681 ~ ~ 1.12 R 1-~ ~ 1.12 R tsa ~ 47 1.12 R 1-~ 48 1.12 R 1-~ 49 1 R 1- 1-~ 58 1 R 1-~ 51 1 H21. 41. 21258 59581 ~ 52 6 R 21258 ~ 53 1.12 R 1-~ 54 1 R 1-~ 55 1 R 1-~ 56 1 R 1-~ 57 1 R 1-~ 58 1 R 1-~ 59 1 R 1-~ 68 l R 158 ~ 61 1 H J75ll u• ~ 62 1 R 1-~ 63 1 R 1-~ 64 1 R 1-~ 65 1 R 1-~ 66 1.13 R 15M ~ 67 1.15 R 1-
Avwhntenf 1 .. A
PLAT PARCEL 1(10£ RAI lfDE M7I'E Y74 Y79 .y~ YBl Yl2 Y83 Y84 Ylfi ya; YIJT YBB Y89 --- ---- -- -- --
o\6 &8 1.18 R 15081 o\6 &9 1.14 R 14181 11181 o\6 71 1.18 R 14181 11581 o\6 71 1.17 R 13811 o\6 72 1.19 R 15811 o\6 73 1.19 R 17S81 15081 4& 74 1.09 R 17181 15811 4& 75 1.09 R o\6 7& 1.31 R 12581 4& 77 1 R 1!581 15081 4& 78 1 R 18581 15811 1- l&J!i 4& 79 1 R 15811 4& ~ 1 R 23811 26811 4& 81 1 R 15811 4& 12 1 R 1!581 15811 4& 83 1 R 19811 15811 45 1 1.1& R 19111 45 2 1.12 R 19581 45 3 1.19 R 22581 45 4 1 R 17181 45 5 1 R 17181 45 & 1 R 45 7 l.i1 R 17. 45 8 1.12 R 17011 45 9 1.15 R 45 11 1.12 R 45 11 1 R 17011 45 12 1 R 17181 45 13 1 R 17111 15811 45 14 1 R 45 15 1 R 17. 45 1& 1 R 17181 45 17 1 R 17811 45 18 1 H. 15811 15511 45 19 1 17. 45 21 1 17811 45 21 1 45 22 1 17811 1- 1-45 23 1.18 17011 45 24 3.72 ~ 25 1.15 1-~ 25 us u• 45 2& 1 45 27 1 17. 45 28 1 17181 45 29 1 17. 45 31 1.25 1- 3511 13181
" 1 1.12
" 2 1.14
" 3 1.1
" 4 l.i9
" 5 1.14
" & 1.11
" 7 1
" 8 1
" 9 1
" 11 1 -" 11 1 H4&&81
" 12 1 H 2118 u•
" 13 1.11 R -
PLAT PARCEL m& RAI 1/flE M1I'E '(74 'f79 Y8t Y81 Y.!2 YB3 y~ Y.fi Y!l YET YBB Y89 ----
44 14 R 44 15 R 44 1& R 44 17 R 7SI8 44 18 1 R &3M 44 19 1 R 44 2t 1 R 44 21 1 R 44 22 1 R 44 23 1 R -44 24 1 R 44 25 1 R - 5811 44 26 1 R 44 27 1 R 7511 44 28 1 R 44 29 1 R 44 38 1 R 44 31 1 R 44 32 1 R 44 33 1 R 44 34 1 R 44 35 1 R 44 36 1 R 68 44 J7 1 R 44 38 1 R 44 39 1 R 4511 44 ~ 1 R 328 44 41 1 R 7511 44 42 1 R 11511 44 43 1 R 128 44 44 1 R 44 45 1 R 44 46 1 R 44 47 1 44 48 1 44 49 1 44 58 1 44 51 1 44 52 1 44 53 1 44 54 1 44 55 1 1- 11M 44 56 1 11 118 44 57 1 44 58 1 44 59 1.19 -44 61 1.13 44 &1 1.16 44 62 1.15 44 63 1 44 " 1 -44 &5 1 38111 1- 45111 44 111 AY&. 1- &U4 1- 171&7 5511 Iiiii - 5581 -29 • 1 R IS$ 3158 3m 3441 4128 5366 18732 18732 11732 ~15 9736 7526 29 1 1.12 R 45811 29 2 1 R 4511 29 3 1.11 R -29 4 1 R -29 5 1 R -
PLAT PARCEL 
PLAT PARCEL RE&: RAW\Hl!i MJTE r Y19 Yll Y81 Ylf Y83 y~ YBS Y' YIJ1 Y88 Y89 ---- --" -- _,, .,.;!.
11 36 1 R 11 31 1 R 1M 11 38 1.1 R 11 39 1.29 R 11 ~ 1 R 11 41 1 H 59111 11 42 1 H 32511 9333 4M 11 43 1 H12211 9333 178 11 44 1 H49B 9333 ~
11 45 1 R 1&811 121111 11 ~ 1 R 11 47 1 H 21281 26581 11 48 1 R 11 49 1 R 14881 11 5I 1 R 11 51 1 H 38111 21111 11 52 1 R 11 53 1 R 11 54 1 R 11 ss 1 H 44111 11 S6 1 H 55681 11 57 1 R 11 58 1 H 37518 11 59 1 R 11 68 1 H 47211 75111 11 61 1 R 6711 11 62 1 R -11 63 1 R 1-11 " 1 R 11 65 1 R 11 66 1 R 11 67 1 R 11 68 1.16 R 1-11 69 1.1 R 11 78 1.12 R 7511 11 71 1.16 H 41411 11 72 1.16 R 11 73 1.16 H29411 11 74 1.16 R 11 7S 1.14 R 11 76 1.14 R 11 77 1.14 R 11 18 1.39 H 33511 11 79 1.36 R 12a 11 II 1.65 R 14111 11 81 1.35 H 1£,. -11 [f 1.14 HW!II 428111 ::. 11 83 1 R 11 111 R AV6. 11625 1• 1a 11511 1- 9758 - 8911 17866 16 • 1 R mss 2811 3269 3269 3~ 5118 11211 11211 1BI 68 £i3 16 1 1 R 1-16 2 1 H 11111 95818 85818 16 3 1 H39411 39518 16 4 1 R 16 5 1 H S13fJ8 35188 16 6 1 R -16 7 1 R 16 8 1 H41111 16 9 1 H S2fiJ8 PAIR1 36818 47511 16 11 1 R PAIR 36818 47511
PLAT PARCEL 1m& IRI llmi M1TE Y79 YIJI YBl YB2 Y83 y~ Y85 Yl!l YBB Y89 .,, -..:....c·L -------- -- -- --
16 11 1 H59708 16 12 1 H 53381 16 13 1 R 16 14 1 R 168t!l 16 15 1 R 1&818 16 16 1 R -16 17 1 R 16 18 1 R 16 19 1 R 16 2t 1 R 16 21 1 R 16 22 1 R 13811 16 23 1 R 16 24 1 R 16 25 1 R 16 26 1 R 16 27 1 R 16 28 1 R 6811 16 28 1 R 9588 16 29 1 R 16 38 1 R 16 31 1 H 48481 16 32 1 H 287tl 16 33 1 R 16 34 1 R 16 108 R AV6. 8581 -1- 77'!i -16 181 AYG. 46 • 1 AS!ISS 3849 3418 3411 4331 7579 13895 13895 13895 12516 12516 46 1 1.48 23711 15811 46 6 1.11 46 7 1.54 46 8 1.46 21511 12581 46 9 1 46 11 1 46 11 1 14£81 46 12 1 46 181 1 AY6. 21666 16!!2 15811 1- 13125 1- 163oti 45 • 1 AS!ISS 3849 3411 3411 4331 7579 13895 13895 13895 12516 12516 45 108 1 AY6.
" • ASSESS 2al 32(,9 32(,9 3923 5181 11211 11211 11211 58 9253
29 181 R AV6. 11181 - 4511 -4511 - 4758
A INK HAWAII REALTY
----~-...... ~~------------------808-966-7 464
January 9, 1990
To Whom It May Concern:
Subject: Geothermal Sub-Zones/Puna District Relationship to land values Professional Disclosures
To Whom It May Concern:
P.O. Box 429 Keaau, HI 96749 Keaau Town Center
I have been asked to comment on the effect that Geothermal Sub-zones in the lower Puna area, especially the Pohoiki/Kapoho area, have had on adjacent land values on or in proximity to the Geothermal well. I make these comments from my expertise as a Real Estate Broker in the Puna District for ten years and as a resident of Leilani Estates since 1983.
The adjacent subdivisions closest to the Pohoiki(HPGA well) are Leilani Estates, Lanipuna Gardnes, Pohoiki Bay Estates, and the upper plats of Kapoho. These areas have decreased in property value since the construction of the well and the best way to validate this would be to examine the County of Hawaii's Real Property Tax Assessments for the past ten years. These show a decline in the assessed values given by the County of Hawaii, Real Property Tax Division. Real Estate sales in these areas have declined and the market value has fallen by as much as forty percent. (These figures were presented by myself at the State mediation process last summer but were not entered into the State Report????)
It is mandatory that Realtors disclose to a prospective buyer the locations of these Geothermal sub-zones, and in doing so, buyers often ask questions about the effect that this designation has on land values in this area. The answer is clearly that prices have declined. If either a Realtor or a Buyer needs information at the County or State level in regards to these Sub-zones or Geothermal related questions, there is only inadequate information available and a somewhat reluctant atitude to give out the information. One of the best examples of this would be for a buyer to go to the Planning Department and ask questions about the SOH expermiental drilling holes. The answer would be that they are experimental but this is hardly an adequate reply for a developer or someone buying a home in the area! What are the long term plans if these holes have feasible geothermal energy. No one seems to want to answer this questions at either the state of county levels?
In closing, if a potential investor or home buyer were to look at the manner in which these sub-zones were created, I doubt they would purchase property in the area as the sub-zone designation is in violation of owners' private property rights. It is quite clear to myself , and to others, that Geothermal development has a definite negative effect on property values and will continue to do so in the future.
Respectfully Yours; Erik Bi~ Principal Broker ~~~
SELLER'S REAL PROPERTY DISCLOSURE STATEMENT Single-Family Residences and Vacant Land
Paga1 of 2 REALTOR'
PROPERTYADDRESS __________________________________________________ ~-----------
SELLER'SNAME ______________________ ~------------------------------------------------Single-Family Residence __ Vacant Land __
TO THE BEST OF MY KNOWLEDGE, WHICH IS THAT OF A LAYMAN AND NOT OF AN EXPERT, THE CONDITION OF THIS PROPERTY IS AS INDICATED
BELOW:
1. BUILDINGS AND OTHER IMPROVEMENTS a What Ia the approximate age of the home? ____ Do you have the house plana? ____ Will they be transferred to the buyer? ___ _
Who were the architect and builder?
b. Whalls the age of the roof of the main building and all other buildings?
Ia there a continuing warranty In effect? If so, give nama and address of warrantor and length of lime remaining -------
c. Does any part of the building or buildings leak? If so, please explain In full --------------------
Have you ever had any leaks repaired? If so, please explain, and alate by whom and whether a continuing warranty lain effect ---~.
d. Haa there been prior termite and/or dry rot damage? ____ If so, please explain --------------------
e. Have there been any additions and/or structural changes or remodeling, including, but not limited to. electrical and plumbing work? _____ II so,
please explain, and alate by whom the work was done and whether continuing warranties are available --------------
Were all necessary permits obtained?---- If not, please explain -------------------------
I. Have there been any problema Involving the foundation, lawn or plants, sprinklers, walla, fences, pool or equipment?---- If so, please
explain -------------------------------------------------------------------------------------Are any plants to be removed? ___ _
g. Does the main house have gutters on all sides? What type?----- Condition?
h. Are all the bullt·lns and appliances to be Included In the sale owned by Seller? If not, who Ia the owner and will the buill· ins remain?
2. LAND
a Does the property have any filled ground? ____ If so, Is the house built on filled or unstable ground?----
b. Is there any known slippage In the neighborhood? If so, please explain ---------------------
c. Do you know of any past or present settling or soli movement problema on the property or on adjacent properties? ____ II so, have they resulted
In any structural damage? What was the extent of the damage? -------------------------
---------------------------------------If ao, was It repaired? ___ _ d. Do you know of any past or present drainage problem on your property or adjacent properties? ____ Does water ever stand on the property?
----If so, please explain ---------------------------------------
3. Are there any known toxic substances In the sol~ the water supply, or the air?----- II so, please explain -----------
f. Are you aware of any encroachments on the boundaries of this property?----- If so, please explain-------------
Are all survey pins visible?---- Who owns the walla and fences on the property?
Are you aware of any encroachments onto any adjoining property---- If so. please explain
g. Whatls the current zonlngolthe property? ____ Have you applied for a change of zoning? ____ When? ____ What Is the status of
the application? h. What Is the flood zone or tsunami zone claaalflcatlon? ____ Is flood Insurance required? ____ Arf! building or rebuilding restrictions in
effect as a result of the hazard designation? If so, please expialn
L Has earthquake damage occurred to thla property or In the neighborhood?---- Waa It repaired?---- Please explain
~ Ia this property In a volcano hazard area?---- If so, Ia Insurance available? __ .;.__ Any Insurance restrictions?----
3. UTILITIES a. ta the prop~r:y !egslly conne;:;t"~ tu l~;t j:.lubllc aewflr ilna7 li not, please explain
11 property Is on cesspool, septic tank or other sanitation system, where Ia It located?
b. Are any utility assessments (sewer, street lighting, other) existing or contemplated? ____ II so, please explain
c. What type of plumbing pipe material Ia used In thla property? Describe any pipe replacement ________________________ ..._ _ _;_ ____________ _
d. Have there been any problems with the plumbing (Including solar system, septic tank. or other), electrical, water and/or gas?---- If so,
please explain
e. What Ia the size of ttie water heater? When was it Installed? Solar system? ____ When Installed? How
many panels? Continuing Warranty? From whom?
I. What Ia the source of the water supply? If catchment, what Is the cistern or tank size? ____ Age? Construction?
----Type of pump? Any leaks? If so, please explain--------------------
g. What Is the approximate age of the electrlcalsystem? ____ Type of wlrlng? ____ Multlbreaker? ____ Fuse system? ___ _
New wiring? ____ Any problems with the wiring? ____ If so, please. explain
Outdoor wiring?---- Existing 220V service?----
h. If the property hill an alternative power system, Is there a generator?---- Type?---- Capacity?---- Age?----
Photovoltalc? Output? Age?----
ATTACHMENT 7-C Buyer's Initials Seller's Initials
,. '
. ., \· .. ·
Sl~gi .. F~~~~Y ~·aald.ncea and Vacant Lend Pllge 2 of 2 pegaa ·
4. TITLE
1 a. Do you have a clear legal title to thla property?----
b. Do you own real property adJacent to. acroaa the street from. or In the same 1ubdlvlalon aalhl1 property? ____ lflo, plea at explain
c. II the property part of a mandatory community asaoclatlon? ----Will association documents be provided to buyers? ----
d. Is an Interest In such common elements as roads, parka or common areas, or recreational facilities Included with this property?----" ao,
please explain e. Ia the property currently under leaae to a tenant? ____ expiration date? ____ Does the tenant have an option to extend the lease? If ao,
until wh•n? ___ _
f. Do you know of easements. licenses. restrictive covenants. bdundary disputes. or third· party claims affecting this property (rights of other people lo
Interfere with the use of this property or adJoining property In any way?---- If so, please explain
g. Ia there any litigation, existing or contemplated, Involving this property, or against Its owners or developers? If so, please explain __ _
h. Are there any delinquent taxes (Income, real property, buslneaa·related, or other) that might Involve this property? If so, please explain
If property Ia leasehold: Haalae purchase been voluntarily offered?.....;.. ___ Whatara Ita Ierma and deadlines?
Has a condemnation ault been flied? When? Are you a part of the suit?---- How much deposit have you paid and
when? How much deposit Is owed and when?
Number and status of the lUll?----------------------------------------11 there a court data? Which Ia the law firm representing the owners In the condemnation suit? -------------From whom may a buyer obtain further Information? ________________________________ _
5. PENDINO CHANOES
1. Do you know of any action, passed or contemplated (road widening, zoning change, rights of way, or other), that might affect this property? ___ _
If ao. please explain
b. Are you aware of any pending real estate development In this area (condominiums, cluster or planned unit developments, subdivisions or commercial,
education, religious, Industrial uses, for examplel? If 110, please explain
8. QUIET ENJOYMENT • a. Do you experience any excessive noise at this property (airplanes. animals, traffic, neighbors, schoolsl? ---- If so, please explain
b. Is there any Industry or operation In your community which Ia considered to be controversial and/or possibly dangarous? ____ ll so. please
explain -------------------------------------------------------c. Are you aware of any notorloualncldenta In the social history of thla.property? ____ II ao. please explain -----------
7. NEWLY CONSTRUCTED RESIDENCES OR ADDITIONS _..,......-- ... ··
1. Has the property or addition received a Certificate of Completlon? ____ When was Public Notice flled? ____ What material, labor and/or
builder continuing warranties exist? ---------- Will copies of continuing warranties be provided to buyer? -------------
b. If property Ia Incomplete:
Ia there a completion bond?---- What amount?---- Issued by? ------Held by? ------Copy available lor buyer?---- Are lunda for completion held In a trust fund?---- Where? ___ Who may authorize their release?
Ia there construction Insurance on the uncompleted property?---- Issued by? ------ Copy available for buyer?----
c. Who are the developers of the property? ----------------------------------------
Contractor? ------------------------ Subcontractors? lnvaalora? ---------------------------Architect? Development Lender?
d. Are the builders and developers of the property memberl of the Homebuilders Association, Building Industry Association, or any other professional
building association? Name
PLEASE MAKE FURTHER EXPLANATIONS OR ADD ANY OTHER INFORMATION HERE
·------------------------------------------------------------------------------I. REVERSIONARY OR SURRENDER CLAUSE \
Is there a reversionary or surrender clause In the lease? ---- If so, please explain
I. DISCLOSURE
My broker, . -~ :~:~ ----------------has advised me that It Is advlsablll to make known any fact, defect or condition, pas I or present,
relating to my property that a buyer might want and/or need to know. Other lhan listed above, !hera are no facts. delects or conditions known to me.
THIS STATEMENT IS A DISCLOSURE O.F THE CONDITION OF THE PROPERTY BASED ON MY LAYMAN'S OBSERVATION OF VISIBLE. ACCESSIBLE
AREAS, DOCUMENTS. AND CONDITIONS AND IS NOT A WARRANTY OF ANY KIND BY MYSELF OR MY AGENT AND IS NOT A SUBSTITUTE FOR ANY
EXPERT INSPECTIONS OR WARRANTIES THAT THE BUYER MAY WISH TO OBTAIN.
I have received a copy of this compleled Sailer's Real Property Disclosure Slatament, which lncludes_....;;2;......_ pages or the reverse of this shael lam
aware lhla Information may be made available to prospective buyers.
Signature of Owner Signature of Owner
bate Date
Signature of Other Owners and Datea
Buyer's Initials
Standard Form Copyright 1987, Hawaii Aaaoclatlon of Realtors RR102
-··---·--:::-~----~-----------------------~-~
" ~ . ··, ... . ,._
Rep!inted from ENVJRON~ENTAL .SCIEN.CE & TEC~NOLOGY, V.ol..l2, Page 550, May 1978 Copyr1ght @ 1978 b! the Ame~Jcan Chemace.l Socaety and repnnted by perm1ss1on of the copyright owner
Effects of Continuous H2S Fumigation on Crop and Forest Plants
C. Ray Thompson• and Gerrit Kats
University of California, Statewide Air Pollution Research Center, Riverside, Calif. 92521
• Continuous fumigation of alfalfa (Medicago sativa L), Thompson seedless grapes (Vitis vinifera), lettuce (Lactuca sativa), sugar beets (Beta vulgaris), California buckeye (Aesculus califomica), ponderosa pine (Pinus ponderosa), and Douglas flr (Pseudotsuga menziesii) with 3000 parts per · billion (ppb) H2S in greenhouses caused leaf lesions, defolia· tion, reduced growth, and death of sensitive species. Three hundred ppb caused lesser but similar effects. Sulfur accu· mulated in leaves depending upon dosage. Faster growing plants accUmulated sulfur more rapidly. Lower levels of H~. 30 ppb and sometimes 100 ppb, caused significant stimulation in growth of lettuce, sugar beets, and alfalfa. The stimulation occuried at certain times of year and may be influenced by temperature and/or humidity.
Hydrogen sulfide is a malodorous gas emitted from many industrial and biological processes. It is highly toxic to man (I), but its effects on vegetation have received scant attention. Two high concentration short· term fumigation studies rep· resent the major works done-with this compound. McCallan et al. (2) fumigated 29 species of vegetation in greenhouses with 20-400 ppm H2S for 5 h during the middle ofthe day. A wide difference in degree of injury was observed. No effect was seen on eight species at 400 ppm, while some plants were in· jured by less than 40 ppm. Young tissue was most sensitive. Increasing temperature caused a rapid increase in injury.
Benedict and Breen (3) fumigated 10 common weed species with a number of air pollutants including H2S. They used 100-500 ppm for 4 h, and the fumigations were done on plants 3 and 6 weeks of age. They observed that the younger plants were more susceptible and that drier soil caused plants to show much more injury.
These short· term studies used H~ concentrations at least one order of magnitude higher than other compounds such as so2. fluorides, and ozone which are normally encountered in polluted air; yet, the degrees of injury to vegetation were comparable. As a result, it has been assumed by investigators that the amounts which occur near industrial emitters or from
Procedure
Fumigations. Continuous, uniform fumigations were conducted in four greenhouses glazed with translucent cor·
. rugated fiberglass (Glassteel, Duarte, Calif.). All greenhouses were equipped with activated charcoal fllters on air intake and exhaust to exclude ambient pollutants and avoid CrOSS COD·
tamination. Temperatures were maintained within 3 °C of ambient during bot weather with evaporative coolers. During cool weather, inside and outside temperatures were the same. Hydrogen sulfide diluted with nitrogen was injected into the carbon·flltered, incoming air stream to proviae the required concentrations of fumigant. H~ was monitored with a Phillips Model1900 H2S analyzer.
Two fumigation procedures were employed. In the flrst series of experiments during 1975, alfalfa (Medicago sativa L), Thompson seedless grapes (Vitis uin.ifera), ponderosa pine (Pinus ponderosa), and California buckeye (Aesculus californica) were exposed to concentrations of 0, 30, 300, and 3000 parts per billion (ppb) of H~. Lower pollution levels (0, 30, 100, and 300 ppb) were used in the second •umigation se· ries during 1976 which involved alfalfa, lett1.~.ce (Lactuca sa· tiva), sugar beets (Beta vulgaris), Douglas flr (Pseudotsuga memiesii), and a second set of Thompson seedless grapes.
Materials. All species of plants were grown in 28·L pots except lettuce and Douglas flr which were grown in 20- and 7-L pots, respectively. A soil mix consisting of peat moss, redwood shavings, and silt {1-1-1) was used to which salts were added at the following rates, in kg/m3 of mix: single super phosphate, LS; KNOa, 0.15; K~04, 0.15; dolomitic limestone, 2.2; and oyster shell lime, 0.90. Copper, Zn, Mn, and Fe were added at 30, 30, 15, and 15 ppm, respectively. The plant.<~ were irrigated with one·half strength Hoagland's solution twice weekly. Tap water was used when additional irrigations were needed. Plant species, varieties used, and duration of treat· ments are summarized in Table I.
All data, where replicated, were analyzed statistically by an analysis ofvariance and a multiple·range test (7). '
Results
natural sources cause minor impacts. Thus, oxidized sulfur, Effects of Continuous B 2S Fumigation on AlCalfa. as S02, is much more toxic at high concentrations on a molar During 1975 when fumigation levels were 0, 30, 300, and 3000 basis than H2S, but at low levels it can overcome sulfur defi· ppb H~, green alfalfa showed white marginal leaf lesions on ciency and serve as a fertilizer (4...0). No controlled studies mature leaves within 5 days at the highest level of H~. To have been done to find out what the effects of long·term, determine yield, the plants were cut at 28-35·day intervals ambient levels ofH2S may be on vegetation. Because devel- depending upon growth rate and development. Growth was opment of geothermal energy can cause emissions of consid· reduced during the first growing period at both 300 and 3000 erable amounts of H~. the present study wu designed to ppb H~ with Hayden (Table ll). The highest level reduced assess its effects on several crop and forest species which grow growth of Eldorado, and a trend was shown at 300 ppb. No near sources of geothermal energy. _______ effect O_!l~wtb was caused by 30 ppb. During the subsequent
ATTACHMENT 8-A 550 Environmental Science & Technology
)
f I I
I•
140
130
cr ~ 120 z .q: w ...J 110 (.)
..... 0 I- 100 z w ~ 90 w a.. 0 80 ...J w ~
70
0 30 ppb
[j 100 ppb
Jll300ppb
. .. , ... ~ ........ .................
~L._ ~
~ ~ ~ ~ ~ ~ ~~
6QLL~~~~.y~~~~~~~my~~~~~~~~~ 5/7 5126 6/20 7/14 813 8/26 9121 IQ/13
CUTTING DATES
Figure 1. EHect of increasing levels of H~ on fresh weight of alfalfa
growth period, most of the plants died at 3000 ppb, and growth was reduced in both varieties at 300 ppb. Composite single samples of dried tissue from these two cuttings were analyzed for total sulfur and showed graduated accumulation corresponding to the levels of H2S in the different atmospheres. Third and fourth cuttings showed the same reduction in growth at 300 ppb H2S but no statistical effect at 30 ppb.
During 1976, fumigation at 3000 ppb was discontinued, and a treatment at 100 ppb H2S was added in an attempt to determine more precisely the amount of H2S which caused reduced growth in this crop. Yield responses to concentration of fumigant are shown in Figure 1 where the yields at the various concentrations are expressed in percent of the yield of plants grown in charcoal filtered air. The results showed that 300-ppb H2S caused significantly reduced yields in all cuttings except August 3 and September 21, while 100 ppb had no statistical effect on yield. The lowest level, 30 ppb, significantly increased yields in the late summer, August 3, August 26, and September 21, of 136,118, and 132%, respectively, of the alfalfa grown in carbon-flltered air. Thus, continuous fumigation with H~ at 3000 and 300. ppb caused foliar injury and reduced growth. At 100 ppb neither of these effect:& occurred, and v.ith 30 ppb a significant growth stimulation during summer was observed.
Effects on Grapes. The immediate effect of the 3000 ppb level on grapes was similar to that seen on alfalfa in 1975. White to yellow lesions, which later turned brown, appeared on leaves. Defoliation began to occur after about 4 weeks at the highest level and within several more days almost all leaves were lost. However, the plants were not killed but continued growth of canes and put out small chlorotic leaves until the exposure was terminated. The 300 ppb level caused lesser but similar, readily observable injury. No foliar effects were seen at the 30 ppb level.
Cane length was reduced at the highest H~ level as compared to the other treatments, but less die back occurred at 30 and 300 ppb H~ (Table III). Total dry weight of cane was reduced to one-half with 300 ppb as compared to the control or 30 ppb, but the total length was the same statistical'ty, showing that the H~ caused a thin spindly growth of canes. With 3000 ppb the cane length was about one-half the control, but weight was one-fourth, showing the same effect. Composite leaf samples were analyzed for total sulfur and showed
Table I. Species , ,, Varieties of Plants and Trealrt;~ents
• 1 D•r• Pl-.1 • of
Pl.nt ...... H81• lumlga-apeclee VatletJ Sa•- ....... wasla lion
Alfalfa Eldorado 1975 32 4 28-35 Alfalfa Hayden 1975 32 4 28-35 Alfalfa Hayden .1976 80 8 28-35 Grapes Thompson 1975 10 1 117
seedless Grapes Thompson 1976 5 1 145.
seedless P.pine 1975 5 1 76 Ca. buckeye .1975 5 1 117 Sugar beet Hollyhyb. 1975 15 1 134 Sugar beet Hollyhyb. 1976 1~ 1 123 Lettuce Dark green 1976 27 1 59
Boston Lettuce Dark green 1976 27 1 88
Boston Lettuce Dark green 1976 27 1 96
Boston D. fir 1976 10 1 246
Table 11. Effects of Continuous H2S Fumigation on Growth and Sulfur Accumulation In Alfalfa•
AHaHa warlaty Eldotado Haldan
Aw Total Aw Total clrJ s clrJ s wtl •• wtl ..
Hz$. pot, so ... pot, so ... ppb II "" II ""
Cutting 1#1 0 52y 1.03 52x 0.92 13 Aug 1975 30 51 y 1.23 52 X 1.36
300 42y 2.45 32 y 2 .. 44 3000 16 z 4.85 11 z 5.20,
Cutting 1#2 0 45y 0.94 46y 1.00 9 Sept 1975 30 46 y 1.10 43y 1.29
300 31z 3.00 28z 3.41
• Values followed by different letters are diHIIf'enl at the 1% level.
Table Ill. Effects of Increasing Levels of H2S on Cane Length, Dead Length, and Dry Weight of Thompson Seedless Grapes•
Total Total Dead Total ... " .....
HzS, Iangiii, langllt. "' clrJ wt. so .. In ppb em em Dead II .... _""
0 1252.9 y 191.3 z 15.5z 145.0 X 0.78 30 1160.0y 212.4 z 18.7 z 143.1 X 1.26
300 1090.1 y 572.1 X 53.3x 72.5y 3.33 3000 673.5z 422.2y 63.1 y 38.0z 4.50
• Values followed by dlffllf'ent letters are diffllf'ent at the 1% level.
Table IV. Effects of Increasing Levels of H2S on Leaf and Cane Weights of Grapes•
LaawH c ..... H2S• Frwt. Dry wt. Frwt. Dry wt. ppb II It II II
0 265.6a 78.6a 267.2a 123.8 a 30 375.6 b 97.0a 251.8 a 115.8 ab
100 298.4b 80.6a 219.6 a 86.0 be 300 260.4a 57.0b 152.0 b 62.8c
• Values followed by different letters are different at the 5% level.
Volume 12, Number 5, May 1978 551 /
.,.
I
I , i
I I .. ~~
' ' ..
-- ----·--------
ar:l.l.Jmulations in grape leaves similar to those in alfalfa. "'Significant increase of fresh leaf weight was induced with
JO and 100 ppb H:zS over the controls with the same numerical trend in dry weight (Table IV) in 1976. Fresh weight of canes was reduced significantly by 300 ppb, and dry weight with both 300 and 100 ppb. Thus, H 2S caused severe foliar injury and defoliation at 3000 and 300 ppb but was not lethal as it was to alfalfa. The stimulation in fresh weight or leaves with the lower levels of H:zS was similar to the effect observed with fresh weight of alfalfa in summer.
Effects on Ponderosa Pine. Little effect of fumigation was observed for~ weeks, but later at the 3000 ppb H~ level a progressive tip bum was observed with defoliation after 10 weeks of exposure. With 300 ppb, tip burn occurred after 8 weeks. No visible effect was caused by 30 ppb. Needle analyses showed that the pines accumulated much less sulfur than the other species, 0.96, 1.23, 1.11, and 1.65% as sulfate in plants receiving 0, 30, 300, and 3000 ppb, respectively, probably because the rate of growth is so slow.
Needle counts showed that the average number of needles remaining in the fust and second whorls were statistically equal in all treatments, but in the third whorl significantly greater drop occurred in treatments receiving 300 and 3000 ppb H2S and the fourth whorl was lost completely.
Effects on California Buckeye. The buckeye proved quite resistant to the effects of H:zS. At the 3000 ppb level, a bronzing of the leaves occurred after 4 weeks exposure with less at 300 ppb and none at the lowest level. Some defoliation occurred at the highest level after 8 weeks expoSure. Total sulfur analysis of leaves showed 1.02, 2.49, 4.40, and 5.54% sulfate on a dry weight basis in plants receiving 0, 30, 300, and 3000 ppb, respectively.
Effects on Sugar Beets. Beets were grown, harvested, and analyzed for fresh and dry weight of leaves, percent total sulfur, fresh weight of roots, and percent sugar. Results with individual beets (Table V) showed that 30 ppb H:zS stimulated fresh weight of leaves and roots 41 and 51%, respectively. A numerical trend occurred with 100 ppb, but 300 ppb inhibited
Table V. Yield of Leaves, Roots, and Sugar Content of Sugar Beets Exposed to Increasing Levels of H2 S •
lndhrlclual t..ela, lea-
H~. Fresh wt,. Dry wt,. "' ppb I • ........ 0 149.6 be 19.8 be 0.66
30 210.5 a 25.2b 0.93 100 200.8ab 23.3b 1.33 300 127.6 c 15.2c 1.88
lncflyklual beela, root.
Hz$, Freshwl, "' "' ppb II Sugar Suit ale
0 291.3 be 19.3a 0.05 30 440.6a 18.3 a 0.06
100 370.7 ab 18.2a 0.08 300 219.6 c 15.8 b 0.12
Total, 3 beetalpol
Leav" Roota, H,S, Freshwt, Dr7wt. ......... ppb • • I
0 1242.0 c 126.2 c 643.4 be 30 2037.6a 194.0 a 881.0 ab
100 1874.8 ab 176.8ab 1034.2 a 300 1640.8 abc 137.0bc 502.2c
• Values follo:-ed by diHerenlletters 818 different at the 5% level.
Table VI. EHects of Increasing Levels of H2S on Ftesh Weight, Diameter, and Sulfur Content of Dark ~reea Boston Head Lettuce a
Freall :&uiiiW H;zS, wt, Dlam, .. ppb • em :sa.
0 104.4 X 26.9x 10.71 30 167.7 y 29.9y 10..82
100 97.3x 25.5x 11.30 300 34.7z 19.9z • 11.77
• ValUes having diflerenlletters are different at the 1 'lit level. Growtiperlod 3/13/76-5/10/76. .
these two responses significantly as compared io the stimulated growth and also reduced sugar content in roota. A nonsignificant numerical increase in dry weight ofleaws was also seen at 30 and 100 ppb. The average total sulfur coatent as sulfate showed a regular but small accumulatiom in leaves and roots corresponding to treatment. Leaves had mruch more ·sulflir per unit weight than roots.
Statistical analyses for· the 1976 crop of sugar ~.lets were done on the total of 3 beets per pot as opposed to eiraluating single beets as in the fust aop. These results (Table V) sbowed that leaf growth was stimulated significantly by both 30 and 100 ppb H:zS. Root weight was significantly greater in 100 ppb H~ than in the control atmosphere but was statistically the same in the 30 and 300 ppb H~.
Beets grown in carbon-flltered air were attacked by powdery mildew and required immediate spray treatment for control. The H:zS fumigated beets showed little of the fungus indicating that the H2S may have been acting as a fungal growth inhibitor.
Effects on Lettuce. Results with the fust lettuce crop (Table VI) showed a large stimulation in growth with 30 ppb H2S, but reduced growth at the highest level. Dried samples of the lettuce were analyzed for total sulfur and show that additional sulfur accumulated in leaves in direct relationship to the H~ in the atmosphere. Limited organoleptic tests of flavor of lettuce from control and fumigated treatments showed no differences.
Because of the large increase in yield shown in the treatment with 30 ppb H:zS, a second crop of lettuce was grown to confirm the original observations. The crop was grown similarly, but the greenhouse temperatures were highe.- than be
. fore, August 12-November 8, 1976. The pronounced growth stimulation at 30 ppb observed previously was absent in this series. Reduced growth with 300 ppb H2S, howevu, was" observed as before.
The experiment was done a third time during a cooler period, October 20, 1976-January 4, 1977. This trial showed a st.atiistically significant increase in fresh weight, dry weight, and head diameter with 30 and 100 ppb H2S over the plants gro.wn in carbon-flltered air. Reduction in fresh and dry weight occurred with 300 ppb H~. The magnitude of growth stimulation was less than in the original t>"':perimenL The reason for the above discrepancies in growtn stimulation response is Dot clear. Differences in growing temperatures may be im· plica ted.
Effects on Douglas Fir. Color of the Douglas ru foilage was not affected by 30 ppb H:zS. All needles remained bright green with no "tip burn". A slight burn was observed with 100 ppb H~. but 300 ppb caused very extensive foliar injury. This species showed overt injury to the pollutant more clearly than all other plants tested. Growth measurements showed that 300 ppb H~ caused reduction in growth and dry weight but at 100 ppb these effects were insignificant.
Discussion
These results indicate that continuous fumigation of plants with 300 or 3000 ppb H:§ causes leaf lesions, defoliation, and reduced growth, the dosage and severity of injury being correlated. Sulfur derived from H:zS accumulates in plant tissues, the amount again dependmg upon the degree of exposure. Rapidly growing crop plants such as grapes, alfalfa, and lettuce were injured more than slower growing California buckeye and ponderosa pine and also had a more rapid accumulation of sulfur. Douglas fu was much more sensitive than ponderosa pine to foliar injury. Sugar beets seemed to be more resistant to H:§ than the other rapidly growing crop species studied.
Use of continuous, unvarying fumigation levels for exposing plant species may be unrealistic when compared to the exposures experienced by vegetation in the field, where the vagaries of wind, convection, etc., cause varying dilution effects. However, because H:zS is relatively low in "acute" toxicity (3, 4 ), the total dosage, i.e., time X concentration, may be more important in determining effects than short-term, higherthan-average concentration.
The pronounced stimulation of growth with alfalfa, sugar beets, and lettuce at low dosages of H:§, i.e., 30-100 ppb, seems to be a real effect at certain times of year. The magnitude of this stimulation may be affected by environmental factors such as day length, temperature, or humidity. This response may involve a fertilizing effect despite the inclusion of soluble sulfate in the fertilizer mix in an amount usually
·,
. . ---·-·- ·-~·- . -··
conside~ed adetr".~ for maximum plant groy,-th. A simil.:.r -- · • grov.(th stimulating effect was observed by Thomas et al. (4),~ Faller (5), and Cowling and Lockyer (6) with low levels of S02• . •
. However, the response here may have been greater because H:§ had less acute toxicity or a higher threshold at which acute injury occurred.
Acknowledgment
The authors acknowledge the technical review of this study by F. M. Shropshire and the experimental qssistance of R. W. LennoL
Literature Cited
(1) Stem, A., "Air Pollution", Vol Ili, p 660, Academic Press, New York, N.Y., 1968. · - .
(2) McCallfn, S.E.A., Haruel, A., Wilcoxon, F., Contrib. Boyce Thompson Jnst., 8,189-97 (1936). . .
(3) Benedict, H. M., Breen, W. H., "The Use of Weeds as a Means of Evaluating yegetation Damage Caused by Air Pollution", Proc. 3rd Nat. Air Pollut. Symp., pp 18-20, Pasadena, Calif. Apr. 1955. •
(4) ~mas. M. D., Hendricks, R. H., Collier, T. R., Hill, G. R., P. Phys1ol., 18, 34t.-71 (1943).
(5) Faller, N., Sulphur lnst. J., 6, [).-7 (1970). (6) Cowling, D. W., Lockyer, D. R., J. Exp. Bot., 27, 411-17
(1976). -' (7) Snedecor, G. W., Cochran, W. G., "Statistical Methods" 6th ed.,
p 253, Iowa Univ. Presa. Ames, Iowa, 1967. . ' _
Rece~ued /or reuiew June 13, 1977. Accepted October 25, 1971. Financzalsupport from NSF-RANN Grant No. 75-15711 .
. ' '
.... ; .... ,
------------------------
-·-··-------.
Geothermal health report questioned . ~ IB :s-~ 8d-
. · · ;;_----~--------- . is difficult to believe that geothermal hot By Wayne.- K. Westlake.- . ·vl·ew.--pOl.flt springs are popular as health spas in three
countries· and also believe that in Puna, the H a recently released state geothermal geothermal well is a source of illness.
development group report is any in- World experience does not point toward dication, Hawaii may be on the verge of a · illness." major new international tourist boom. As geothermal health complaints meeting. WHAT we have developing here is a more and more geothermal development One after another, resident after resident classic confrontation between the will of takes place here, tourists from all over the .· rose to the podium to air a wide variety of the people and the will of the state globe may soon. be fiqcking to Hawaii to personal health complaints caused by government-industrial complex. Both
:·inhale geothe~ . emissions, to ·drink geothermal emissions. sides feel the other side is unaware or , spent geothermal: fluids and to bathe in Complaints included sinus problems,.· insensitive to their needs. The people want p-_·geThotheermarep~lr_t,effibuey·· mntsem.:,bers. of the .. H. GP-A. respiratory ailments, chronic colds, a clean and health environment while l coughs and flus, migrane headaches, government-industry wants energy self-
Development .~roup responsible for the stress, tension and nightmares, ear, throat sufficiency and increased profits. ·The HGP-A geothermal well in Puna, · has and eye irritations and still other illnesses, people want a moratorium on further concluded · that the "alleged". health ·.One resident had to hav~ his face · geothermal development while the complaints expressed by residents· in the ·.rearranged by. surgery to restructure his government-industrial complex wants to vicinity can be attributed to the pollens, sinus cavities. Was his problem caused by proceed post-haste with commolds and fungi found in the rainforests : ~llen? One lady gave birth to a baby with mercialization. nearby. . fetal lung damage. Was her problem One resident at the Pahoa health
How a select panel made up of Hawaii's caused by fungi? One woman's young . complaints meeting urged the County of "energy shogun," a founding father of ' daughter. suffers from S4:!rious ear in- Hawaii to "stop, don't let anymore wells in geothermal development in Hawaii, and a fections and no longer r~ponds to an- or it will kill everyone down here. The
. Hawaii county director of. research and tibiotics. Is her problem due to rainforest effects are real," he said. "For us there is development could possibly come ~p with 1 · molds? . . . . . no more talk-the ultimatum is there. an objective, unbiased and· independent The state response disputing the health People are dying and something ha.S to be conclusion is debatable. Nevertheless, the . complaints lodged by residents in Puna done."
, report concludes: "Puna is rich in pollens · would be · laughable· if not for the Both sides hope to resolve the issue which cause allergies. In addition, Puna is · seriousness of t..'le citizen's complaints. As . peacefully, Government arid industry an area of ·high rainfall and has much it is, the report is an insult to anyone's representatives have quietly proposed higher than average concentrations of intelligenee and its authors, Kono, Shupe negotiations while people of Puna have
, mold and fungi which_ are. frequently and Kearns, appear to be out of touch with retained several attorneys to represent ~·associated with respiratory and· reality. Even industry representatives ·. them. Opposition to. geothermal . :pulmonary ·allergic reactions. There-· is have quietly confided that the report is a development .is clearly organized and : ~WI no reason to believe that. the HGP·A r "disgrace." growing. Where this movement will lead is ·.:well caused the health problems which : _ Yet the authors defend their conclusions a matter of conjecture, but in light of the
were reported." . · by pointing to geothermal experience in government coverup of health problems This cOnclusion flies right into the face of other areas of the world: "In other parts of associated with geothermal emissions,
wbat residents in conununities surroun· the world ... people flock to geothermal there is a growing feeling among residents ding the well have been alleging for hot springs to smell the discharges, drink here on the Big Island that a showdown is months ...;. geothetinal emissions are the sulfur water, and bathe in geothermal . inevitable. ·making them ill,· and Sometimes very· ·effluent in order to become healthy. (Wayne K. Westlake is a resident of seriously. 'l'wo months ago, 200 residents Balneology _;.the therapeutic use of baths Volcano. Viewpoint articles do not
I. of lower Puna crowded Into Pahoa School · - is a major aspect of geothermal use in necessarily reflect the editorial position of I auditorium for a county sponsored Japan,theSovietUnionandHungary ... It the newspaper.)
...__ ___ ·- . ..::. ~-
ATTACHMRNT-9:..::-A----
--·-·---·--------------------~
~ -60-
so-
8
so-
40-
;o -
10 -
+ 8
'
' + 2.
Km south of rift zone axis
0
j 0
Kilauea Lower East Rift Zone
2.
Kilauea Upper East Rift Zone
6 8
Km north of rift zone axis
Figure 10. Percentage of ground covered by lava flows, from 1954 to 1984. as it varies with distance north and south of Kilauea's east rift zone axis. "If 30 years is the assumed life of a geoth~l"!ll_~ power plant. these figures suggest the probaQillty th_~t site.s_ may be threatened by burial during their lifetime, as based__o_l1 __ Kilauea's history from 1954 to 1984.
ATTACHMENT 10-A
F
KOHALA
QUNTAIN
0 WAih'.(A B
·ATTACHMENT -10-B
:0 0 10 ~Ill' a o&.=:'J ..._-:-...J ... ~~---==---:.:...:..~.:~--~-:.:-_-:·_-:··..:)
--- ------Physical boundary bet~een volc~n0~
---------------Approximate judemental boundary
betwePn zones of relative risk
OF REh4TIVE RISK FROM VOLCANO HAZARDS
---·--------------------------------
.TrHA.8erU~ttlefte
ET, .. c._,..,..
10 - 110 ,,. ......
0- 10 ,, •.•. ~.
liii!III1 TrH D etUIItiOfta
B TrH I etUIItiOfta
9t.__..__.. __ ...;;.u. Kill.
r::::J Yo~r lawa tlowa
Oo~ertawaflowa
Figure 9. Summary of Kilauea's eruption history during the last 1500 years. (Holcomb, 1980)
--- --~ -- ---ATTACHMENT 10-C
.· / / . ~· " ..
j·l ' 30'
I'
.~· .. .· . s~~.'~;a·:_·.o~l.·~.ee~:,~h~p;s. Flsl~ and Y·/ildrle Servic~ and the ruplure~'.:well .. :
~URtur,~d wen au.:Jslling poisons near Stillwater (Qe,·\~{~ ~~~~K- · HIU J/\N 2 G 1989 ..
B Don \ etter/Oazeno.Journol . ann plans to clean up the dascharge, he
Nevada's top environmental cffici:l! is G What the long-terrn . 80~.s. Geological Survey ;esls showed considering sanclious ngainst a Sparks· consequences of liltS Will U1e nuld from the well contains hi~h based COmpany fOIIIlWirJg the eruption bo we really don It COrJCentralions Of boron and QfSeOIC, of a geothermal well that is spilling con- ...... , The tesls showed U1e water's boron laminated water nenr the Stillwater know. ' levels are 18 times higher than drink· Wiidllfe Manngement 1\rl'n. 1 lug-water st•mdatds and arsenic levels
Meanwhile, U.S. f'ish and Wildlife R.cn Anglin · four Urnes higher. Boron Is particularly Service oHicinls are looking for ways to U.S. fls·h a.ld Wl!dllfa Service ·harmful to plant liCe In the wellan~s, keep wildlife clear or the well, located Ron Anglin, the Fish and Wlldhfe one mile frorn the refuge. Hiologisls Service's manager at Stillwater, said. have diverted the steaming (luid away dfr:chnrg~ c:· nn r3timated !B million so far, no wildlife deaths have been from the area's remaining healthy wet- g.li!ons of ccnL1minntcd water. attributed to the well discharge. lands as eflorls arc made tc cap the "Th:! com:1any discharged pollutants Doug Miller, manager of project failed well. ln:J U1e wnl:!rS or the sl'lte U1at con- · development for Ormat, said the c~m-
Lew Dodgion, director or li::J State t.1ined hiGh crmccntrations of saline, . · pnny is attempting to cap the erupting Division of Environrncntnl Protection, bo:-on · and other contaminants Into well and drill a second well nearby to said Wednesday his olfice is preparing ne~rby pond3 that contained water of a relieve the discharge. The well was a notice of violation against Onnat Sys- m'.!ch better fJUnlity," Dodgion said. being drilled to re-Inject spent geother· tern Inc. or Sparks in the wnkc of the ·~he st.-:te'f. nction will require Ormot Jan. 12 occident whicl& ha:: cnw:ed the to file 11 deL:iled report on Ulo Incident
___ ....:., ___ ,J ___ • _______ ....;... ________ _
fotillwater. from pa9e 1C mal fluids from the 11 rr.eg:~wntt pow•·r· plant due to go into operation in March.
,_, ... 'workers were Injured in tho drill· lr. :cident which sent a plume of r.luid J()\) .eel into U1e air. The J.!cyscr has smr:e subsided though the current rlisch:une has been 'estimated by wildliic officials at 4,000 gaUons a day.
Water has been the linchpin or prob· lems at Stillwater.
The Lahontan Valley once had 33,000 acres of viable wetlands, but in recent
.. , ~ rs ha·; sl: :unit tn les~ than G,OOO acrt:'S be· ·:un? of drought ::nd reduction..<! in the :tn:ouJ.t ,,( \':ater running ofi of Fallon C:a :ns. TiH! \':atcr Stillwater r.cts is laced wi\11 n:1turalty occurring toxins such as boron, ar:.cn!c, selenium and lead.
tlow, even more contnminated water Is pourinr' cnto the wildlife area.
• 'Th~ ueci!llon I had to m:tke wns to fhul n wny to do the lenst E'nvironment.,l dnmagc to the wetlands and to U1e whole aren out there, ·• Anglin said.
Ulologists and Ormut workers have dh·crted the hot water away from wet· lands at the Canva~back Gun Club and onto a barren portion of the wildlife area.
AT.fACHMENT 10-E
See STILlWATER, poge 2C
APPENDIX A
..
G~~!h~ .. r~~tP!~n~50; health complaints di~,li)if~1i~~fJ 3y Stephanie Ward/Gazene-Journal other complaints of illness from Pleasant They found they weren't. complaints to the departmt>nt from Pleas-
The Caithness Power Company Inc. was fined $i50 by the Washoe District Board of Health Wednesday for causing a rotten-egg smell in the air around the Pleasant Valley area.
The company also agreed to install special gas-scrubbing equipment thZll officials said should cut down on odors from me plant by next month.
But the health department dismissed 21
61 I l
ti1\
Valley residents, who claimed emissions · The department said the highest hydro- ant Valley residents, was caused by natu-from the plant were giving them nose- gen sulfide reading of Caithness was well ral gasses from three pruduction wells. blet:ds and allergy-type iilnesses. below the state standard, and a Desert The company was gin:n two fines ior
Carl Cahill, the district's director of Research Institute sample of particulates obnoxious odors - one for $250 and lhe environmental health, said in a report to emitted was also at a low level. other for $500. the board that health officials met with a The 12.5-megawatt plant, the second in "It is just hke a traffic ticket," said number of local agencies, conducted tests the Steamboat Springs area, supplies Schumacher. "We hate to pay the fine but and consult~ a number of other geother- 12,500 households with energy, said Ste- we did make the odor." mal comparues to see if these kinds of ill· phen Schumacher, vice president of oper- To clear up Ule problem, the company nesses are associated with geoUu::rmal ations for the company. is installing $70,000 worth of equipment power production. The odor, which prompted more than 40 that would ease the smell.
~e.,"'t!~(ll~~een from geothe~!Pft! ~:11 B~on YeHer/Gazett!NoumaJ · The state this week issued Ormat a "No· wildlife de th h b STILLWATER, Nev.- Environmental
· damage from an out-of-control geothermal well has been negligible at the nearby Stillwater Wildlife Management Area, federal wildlife officials said Tuesday.
State environmental officials say the water coming out of the well was of Jesser quality than that in ponds and irrigation ditches where the well-water first gushed after the Jan. 12 accident, a potential violation of state law.
Geothermal plant developers Ormat Systems hie. of Sparks say they can cap the well by the end of this week. The state has given the company until Monday to sloP. the flow.
~ 'Spurting well ~ > n ::I: :z: t:r.l 2: ~
i I
'From page 1C ·
!that we do not want geothermal water in the area. That is the official policy of the U.S. Fish and Wildlife Service and the state Department of Wildlife."
Water problems have plagued the man-1-" agement area for the last three decades, ? ~rticuJarly during the past three years · ~ f drought. Approximately 18,000 birds
nd 10 million fish have perished in the tillwater wetlands due to diseases, conminants and decreased water ~upplies,
according to biologists. · Ormat officiais contend the water spill
ing out of their well is of no worse quality than surface water found in the area.
'"There needs to be a detailed study to· detei-mine what imF.cts, if any, have occurred out. here,' said Doug Miller, project manager for Ormat.
By the time the hot geothermal water reaches the management area, the
"fi di f II d . . a s ave een m ng o a ~ge vJolahon and ord~r:• observed," said Ron Anglin, manager of that could subject the company to Clvll the 200,000-acre wildlife area that penalties of up to $25,000 a day. Ormat has includes the 24 20Q-acre Stillwater Wild-
. 30 days to appeal the finding to the state life Refuge. ' ·Environmental Commission and submit a report explaining the cause of the well blowout and an investigation plan assessing effects on water:quality, wildlife and wildlife habitat.
Fluid from the well, located 3~ miles south of the management area, initially flowed into nearby ponds and ditches. But within 24 hours of the blowout workers began to divert the water to a barren portion of the wildlife management area east of Fallon.
water's temperature ·has fallen, officials . said. However, the water also carries the
dissolved minerals naturally found in the area. Initial tests by the U.S. Fish and Wildlife Service show the well water contains levels of arsenic and boron higher than the surrounding water. These ele
. ments are potentially harmful to plants and wildlife.
Miller said much of the surface water in the area already contains the kinds of minerals found in geothermal probes and that water from the uncontroJJed well should not create "pandemonium and hysteria." · · ·
Lew Dodgion, director of the state Division of Environmental Protection, said he expects Ormat officials to file an answer to his order. If they don't, the state will me a civil lawsuit against the company, . he said.
"The well discharge initially did not go· Into the drylands, but into ponds and ditches, and the quality in U10se waters was better," Dodg10n said. "These waters do have quality standards, and the geoth-
Orma t workers and wildlife biologists diverted the flow away from the refuge and the Canvasback Duck Club, where some of the Lahontan Valley's healthiest wetlands remain. ·
"I thi~ Ormat has been extremely coo~erahve and we have no complaints agamst the company's actions " Anglin · said. "But our position as managers of the · Stillwater Wildlife Management Area is
See SPURTING, page 2C
erma) fluids did exceed those standards."
Russ Fields, director of the state Department of Minerals, said the Ormat incident is the largest geothermal well blowout in state history: He said Ormat followed all prescribed precautions when drilling the re-injection well - used to put spent geothermal fluids back underground.
"At his point, we can say that Ormat took all the proper precautions and followed an the procedures that we require in our regulatioru:<," Fields said.
Ormat encountered high-pressure fluids sooner than expected, he said, and the water escaped around the outside of the drill casings.
Ormat is attempting t~ cap the flow with an adjacent relief well, angling into and eventuaJJy intercepting the rene,ga~ well 700 and 800 feet below ground. This strategy avoids pressure problems near the surface that could hamper the capping attempt, Miller said.
1~1! FEB 9 1989 ----.:.. Officials stop runaway · ·well near Still~ ___ a,~r~: \:\ c;. ~0 \\,lo..~:t ...... C\., 'l: ~~ · Officials from Ormat Energy System Inc. Wednesday said they have capped an out-of-control geothermal well near the Stillwater Wildlife Management Area southeast of Fallon.
Ormat project engineer Doug Mille! said cold weather initially hampered the capping effort on the well, which erupted Jan. 12. Drilling crews had hoped to intercept and cap the well b) the end of last week.
"Right now, we are cautiously optimistic," Miller said of the capping, which occurred late Tuesda;
' afternoon. Crews intercepted the runaway well 700 to 900 feet below thr surface and used cold water, mud an< a cement cap to stop the flow, he saiC:
Geothermal water from the well ha been diverted to a barren portion of the wildlife management area, away from federal wildlife refuge lands am wetlands maintained by the Canvasback Duck Club. Bielogists sa: the water has not caused aay visible environmental damage. ·
Last week, the state issuid Ormat " "finding of alleged violation and order" that could subject the compan. to civil penalties of up to $25,000 a day. State environmental officials say the water coming out of the well at a rate of 2,000 gallons to 4,000 gallor( . minute was of Jesser quality than u ... i in ponds and irrigation ditches where the well water first gushed.
l 11LKMAL ULVI.IUI'MLNI I'(ILICY IOK I lAWAII 2 1117
1 CLjuuc that the benefits whi~:h accrue over time (su~:h liS
~liUIUngupen space and reducing dependence on oil imports) cle: rcdu..:ed to pre\ent value by appropriate time discounting, · "' wuuld be the recurring costs, such as the exemption uf land wh1ch would otherwise be subject to taxation.
SuKe many uf the valuations entering into the cost-benefit illliiiY'I' must be gross approximalions of the actual values, wlm:h •m: beth:r represented by a range of estimated cash Yi1h1es lhilll by a single figure, the policy makers are likely "' he 111lluen~:cd by factors which do not enter into the '"'''IY"' at illl. Cilution or enthusiasm for new technolo~y wuuld he une su~:h fa..:tor; optimism ur pessimism about th~· future uf 011 supplies would be another. A third would h~· polt,·y m••l..er's altitudes tuward "ovcrnment intervention 111 e"'lllllllllK develupment in Hawaii, whether it ill desirable hu the slate lu lake an iniliative in that development or wa11 fur private .industry to do the work. Also, opinion il\ lu htlW well the operalionll of public utility companies 111 the stale serve the public welfare may affect decisiuns ..:tln..:erning the dcvelopnu:nt and application of "eothcrmal po•wer. Fur e ~~.ample. if policy-makerlli were perlluaded that ..:ust \avtng\ from "eothermal power would not be passed un hy the ch:..:tric companies to cuosumers, then they might f •• vur a larger role for the slate, exte~ding to distribution ul the Jltlwer LJcnved hom geothermal resoun.:es.
POliCY MODELS
Stille cuntrollie'i at the end of a broad 'ipectrum of possihh: rules uf the Hawa1i government in geothermal devclopnu:nl, Jcpcnd111-' nn 1ts puhcy ohjective' ;md id~:olugiCill prefer· ences. Wathm thilt range, the,e, models can be distinguished.
Minimal Stale Intervention
Th1s mudel. which would abo attempt to maximi1.e output, · would limit Stale action 10 what i' re'luired by law. but even thi' is ~:onsidemble. Under Act 241 of 1974, the stale guvernmcnt i!> sh:ward for the people of Hawaii with respect Ill geothermal resources and the Department of Land and Nut ural Rc:suur~:e!> is delegated the responsibility for carrying uut thut !>lewardship-to see that it ill not wasted hut e llplmted in the public interest (however I hat may be anterp1etedl. 1o !>el and collect royalty payments for the use uf 1hc publi~ly owned resour~c:. and ~:arry out its ulher responsibilities as particulari:ted in the next section uf this paper. Similarly, the State Environmental Quality Cummis\ion must. under the law, ensure thai the environmental impa~:t uf geothermal development is acceptable, uml the Public Utilities Cummissiun must regulate rates churged by a 1eothermal steam company if it is set up "'a puhlic utility enterprise.-ln ~ny case, the PUC woul~ be ~on~erned with the dfecls of geothermal power on the c'""· prufil\, and rates of an electric company ~sing the power.
PriwAie Operat~on, Cowernment Support
Tu maximit.e production while minimizing stale control, the slate would accommodate all reasonable and mutually Sllflpurttve efforts by private enterprise to dc:velop the l(l"Uthermal resouu;es, ashy; D
1·. \fiCdtllng dulling hy cullintt all corner'! in gmnling
a~:ccss to puhlic lands (and helping to get acceslli to private lands, if nece!>!iary using ih power to compel entry), mini· mizing environmental impact statements, and giving all assurances possible under the law thai successful drillers would have production rights for long periods of time. 2. Direct subsidies: paying part of the costs of drilling development; minimizing or waiving royalty payments for geothermal wells; giving special tax benefits to drillers/producers. 3. Indirect subsidies: providing access roads, water supply, and other infrastructure needs of a geothermal field, regulat· ing electric rates so that the benefits of geothermal puwer are shared between developer and utility company amJ not passed hack lo cqnsull)ers in lower rates. (This is done al The Geysers, California, where the Pacific Gas and Electric Company pays the geothermal-steam supplier at a rate: tied to the price of fuel oil.)
Priwate Operation for State Objectives
The means just listed above could be used to accomplish ends desired by the state government by making the granting
·of permission to drill, the granting of subsidies or loans. ami so on conditional on ihe geothermal development being curried out in a manner which would further those ends. For example, if the purpose of the state is to disperse population, it would support proposals to develop geothermal resources on the neighbor islands but nul on Oahu. If its purpose is to reduce electric bills, it would suppilrl development likely tu produce electricity and ensure that m&~rket furces or rate regulation achieved this purpo~oe. If the stale puts a high priority on environmental protection, the environment;,! impact statement would be held to a demanding slandilrd of explicitness. If it wants 10 maximize production over time. the state would ensure lhill the resource hild been adequately identified before permitting production drilling, thul 1£COiher01al waters are reinjected arter use. and so forth.
Joint Venture
Since drilling and geothermal resource development are highly risky and costly, private enterprise may not develop the: resource to an optimal point to achieve public purposes .l>et by the: stale, such as creation of employment. reduction of dependence on oil, and population decongestion. Thi' possibility. in fact, is what would provide justification for the direct and indirect subsidization considered above.
Another approach is for the local government to enter intu" joint venture with one or more private firms, furni!ihing some of the cupital, technical knowledge and expertise and other necessary rc:sl\urces, sharing in the mamagenu:nt, perhap!i, and commensurately sharing in the profib (or losses) of the geothermal enterprise.
The joint venture might encompass the entire operation, from drilling to production of electricity of by-products of geothermal waters and minerals, or it might provide for " division of labor. One division would be for the '>llllc to drill and produce the steam and then sell the steam to the Hawaii Electric Light Company, or other private firm. Alternatively. a private firm could drill and produce (steam. dcclru.:ily. distilled w;11cr. ur uthcr hy-pruductsl lind '"'II its production to the stale ur county acuvernment fm dl\lrtllu· ti~m. Hawau County, fur C:Xillllple, might want tu buy
ATTACHMENT 11-A
Mr. William Paty, Director
KAPOHO GROWN PO Box 537
Pahoa, Hawaii 96778 808-965-8699
Department of Land and Natural Resources 1151 Punchbowl Street, RM. 110 Honolulu 96f:ll3
1'1an: h 22, 1989
RE: NOTICE OF INTENT TO SEEK WITHDRAWAL OF TMK 3-1-4-1:61 FROM GEOTHERMAL SUBZONE AS PROVIDED IN HRS SECTION 13-184-10.
Dear Chairman Paty,
I intend to have my property in Kapoho, Hawaii TMK 1-4-1:61 withdrawn from the Geothermal Resource Subzone. This parcel is in an agricultural and residential use. Development of any potential geothermal resource would: 1) disrupt and corrupt present agricultural and residential usage, 2) cause economic losses, 3) threaten health of residents, employees, and crops, 4) threaten contamination of the groundwater reservoir, 5) disrupt the social environment of our rural community, 6) detrimentally affect the State's supply of tropical fruit and fruit
products, foliage, and nuts, and 7) be incompatable with existing land uses.
I also request establishment of a buffer zone to prevent unmitigatable environmental and economic problems associated with development of the geothermal resource.
I hereby request initiation of a withdrawal procedure and will provide any additional information on request.
Please advise me if this letter meets your requirements set forth in HRS Section 13-184-10. Please also be informed that there will be additional parcels seeking to be withdrawn under this petition.
Sincerely,
Delan Armstrong Perry
cc: Lon Rankin, President,Kapoho Community Association
,__ ____ .
JOHN WAIHEI:
GOVERNOR Of HAWAU WILLIAM W. PATY, CHAIRPERSON
BOARD OF L.AND AND HAlUftAL At:~UACE::.
LIBERT K. LANDGRAf
OtiPuTY
AOUACULTUHE OE\IELOPMtNl I'UOCRAM
STATE OF HAWAII DEPARTMENT OF LAND AND NATURAL RESOURCES
DIVISION OF WATER AND LAND DEVEL.DPMENT
AQUATIC RESOURCES CON~ER,ATION ANO
ENVIHONMt.NTAL AffAihS CONSER,ATION ANO
R(SOURCES ENfORClM.ONI CON,EVANCcS
P. o. aox 373 FORESTRY ANO WILOLifE LANO MANAGEMENT STAff PAHKS
HONOLULU, HAWAII 96809 WATER ANO LAND OEVI:lO~MENT
Mr. Delan A. Perry Kapoho Grown P.O. Box 537 Pahoa, Hawaii 96778
Dear Mr. Delan:
May 19, 1989
As a follow up to our recent meeting and your letter of March 22, 1989, requesting the withdrawal of your propeny from the existing Kilauea Lower East Rift Geothermal Resource Subzone (GRS), listed below are the necessary information rt:quired in order to evaluate and process your request:
1) Name and address of all landowners requesting withdrawal of their propeny, the tax map key and acreage of their land parcel, and a map showing the affected propeny if available.
2) In addition, each landowner shall file a written basis for his request including evidence that:
a) The area no longer has any sufficient potential for geothermal resource development;
b) There is no known or likely prospect for the utilization of geothermal resources for electrical energy production;
c) Potential geologic hazards to geothermal production or use exist in the area;
d) Adverse environmental or social impact would result from the development of geothermal resources within the area;
e) The development and utilization of geothermal resources would not be compatible with other allowed uses in the area and the surrounding lands; and
t) Geothermal development in the area, on balance, is not in the best interest of the county or the State.
ATTACHMENT 13-B
•
Mr. Delan A. Perry -2- May 19, 1989
Upon the receipt of the above-requested information and review by our Department, a public hearing before the Board of Land and Natural Resow·ces will be scheduled to receive testimony on the request to modify th~ existing subzone. A legal notice of the public hearing will be published in a daily paper and also mhlled to all landowners requesting withdrawal of their property. Additional written testimony may be filed with the Department within 15 days following the close of the public hearing.
In accordance with Administrative Rules, Chapter 13-184, the Board of Land and Natural Resources "shall modify or withdraw a designation only upon finding by a preponderance of the evidence that the area is no longer suited for designation; provided, however, that within an existing subzone with active geothem1al development activities, the area may not be modified or withdrawn".
Should you have any questions, pie
DN:dh
*••
•OHN WAIHEE
.RNOR OF HAWAII
STATE OF HAWAII DEPARTMENT OF LAND AND NATURAL RESOURCES
REF:WL-KO
Mr. Delan A. Perry Kapoho Grown P.O. Box 537
P. 0. BOX 621
HONOLULU, HAWAII 96809
APR 2 4 1989
WILLIAM W. PATY, CHAIRPERSON
BOARD OF LAND AND NATURAL RESOURCES
LIBERT K. LANDGRAF
DEPUTY
AQUACULTURE DEVELOPMENT PROGRAM
AQUATIC RESOURCES CONSERVATION AND
ENVIRONMENTAL AFFAIRS CONSERVATION AND
RESOURCES ENFORCEMENT CONVEYANCES FORESTRY AND WILDLIFE LAND MANAGEMENT STATE PARKS WATER AND LAND DEVELOPMENT
T s is to acknowledge the receipt of your letter dated March 20, 1989, requesting information on the Kilauea Lower East Rift Geothermal Resource Subzones ( GRS).
As requested, please find a copy of the map which designates the boundary of the Kapoho Section of the Kilauea Lower East Rift GRS. The GRS area includes, but is not limited to, the attached listing of Tax Map Keys located in the subzone.
Should you have any questions, please contact Manabu Tagomori at 548-7533.
Very truly yours,
Attach.
ATTACHMENT 13-C
KILAUEA LOWER EAST RIFT (KAPOHO SECTION)
GEOTHERMAL RESOURCE SUBZONE
Island of Hawaii
State of Hawaii
BOARD OF LAND AND NATURAL RESOURCES
May 1986
• 5 '*
Legal Authority
rmm r 0 r 'C a ·nrn ttr* '1' nor a
KILAUEA LOWER EAST RIFT (Kapoho Section) GEOTHERMAL RESOURCE SUBZONE
en
Pursuant to Sections 205-5.1 and 205-5.2, Hawaii Revised Statutes, as amended by Act 151, Session Laws of Hawaii 1984; and Title 13, Chapter 184, Administrative Rules, as amended; the Board of Land and Natural Resources, State of Hawaii, has designated the Kilauea Lower, East Rift (Kapoho Section), Island of Hawaii, as a Geothermal Resource Subzone (GRS).
Location
The subzone area is designated on the attached map identified as the Kilauea Lower East Rift (Kapoho Section) Geothermal Resource Subzone. The subzone area contains approximately 5, 636 acres, more or less, and is located west of Leilani Estates and extends eastward to Cape Kumukahi. The GRS subzone area includes the following Tax Map Keys (TMK):
Tax Map Keys
TMK 1-4-01: Portions of 10, 21, 26-28, 31-33, 40, 46, 54, 55, 56, 63, 66-69, 81 TMK 1-4-01: 13, 41, 50, 51, 52, 53, 59, 60, 64, 65, 70 and 72 TMK 1-4-02: 2, 10, 11, 18, 27, 31, 32, 34, 37, 40, 41, 44-46, 65, 67, 68, 72,
80, 86, and 87 TMK 1-4-02: Portion of 71 TMK 1-4-05: 1, 2, 4, 22, 23, 25, 26, 29 and 31 TMK 1-4-05: Portion of 18 TMK 1-4-06: 1-2, 8-13, 15, and 16 TMK 1-4-07: 2-7 TMK 1-4-08: 1-5 TMK 1-4-09: 2-9 TMK 1-4-12: 1-7 TMK 1-4-13: 1-7 TMK 1-4-14: 1-15 TMK 1-4-15: 1-10 TMK 1-4-16: 1-13 TMK 1-4-17: 1-13 TMK 1-4-18: 1-14 TMK 1-4-19: 1-13 TMK 1-4-20: 1-12 TMK 1-4-21: 1-9 TMK 1-4-22: 1-16 TMK 1-4-23: 1-7 TMK 1-4-24: 1-7, and 10-12 TMK 1-4-78: Portions of 1-9
Total: Approximately 5, 636 acres, more or less.
-
The attached map defining the boundaries of the designated subzone is adapted from the U.S. Geological Survey topographic maps - Pahoa North, Pahoa South, and Kapoho Quadrangles.
Questions regarding the GRS and requests for information may be directed to the Division of Water and Land Development, Department of Land and Natural Resources, Room 227, Kalanimoku Building, 1151 Punchbowl Street, Honolulu, Hawaii 96813 (telephone 548-7539).
..
KILAUEA LOWER EAST RIFT (KAPOHO SECTION)
GEOTHERMAL RESOURCE SUBZONE
Island of Hawaii
JOHN WAIHEE
VERNOR OF HAWAII
STATE OF HAWAII DEPARTMENT OF LAND AND NATURAL RESOURCES
REF:WL-KO
Ms. Barbara Bell
P. 0. BOX 621
HONOLULU, HAWAII 96809
SEP I 5 1989
Kapoho Community Association P.o-. Box 553 Pahoa, Hawaii 96778
Dear Ms. Bell:
WILLIAM W. PATY, CHAIRPERSON
BOARD OF LAND AND NATURAL RESOURCES
DEPUTIES
LIBERT K. LANDGRAF MANABU TAGOMORI
RUSSELL N. FUKUMOTO
AQUACULTURE DEVELOPMENT PROGRAM
AQUATIC RESOURCES CONSERVATION AND
ENVIRONMENTAL AFFAIRS CONSERVATION AND
RESOURCES ENFORCEMENT CONVEYANCES FORESTRY AND WI LOLl FE LAND MANAGEMENT STATE PARKS WATER AND LAND DEVELOPMENT
This is to acknowledge receipt of your application and list of property owners requesting withdrawal from the Kapoho and Kamaili Geothermal Resource Sub zones.
Your multi-party request will be reviewed and processed accordingly. In conjunction with our review, please submit the supplemental information referenced in your letter at your earliest convenience.
Should you have any questions, please contact Manabu Tagomori, Deputy Director, at 548-7533.
ATTACHMENT 13-E
\
)
Basis for Evaluation
Figure 7. EVALUATION OF IMPACTS ON POTENTIAL GEOTHERMAL RESOURCE SUBZONE AREAS
Kilauea East Lower Upper
Island of Hawaii Kilauea
Southwest Mauna Loa South\rest
Mauna Loa Northeast
Hualalai Northwest
Island of Maui Haleakala Haleakala
East Southwest =================================================================================================================================:~~==========;-=========== Potentials for Production +90% +90% +90% 35i: 35% 35% 25% 25%
Prospects for Utilization good good uncertain uncertain uncertain uncertain uncertain good .....
-----------------------------------------------------------------------------------------·----------------------------------------·-------------------------Geologic Hazards Impacts
Lava Flows Pyroclastic Fallout Ground Cracks Ground Subsidence Earthquakes
' Tsunami
Social Impacts Health Noise Lifestyle, Culture, Community Setting Aesthetics
Environmental Impacts Meteorology . Surface Water Ground Water Air Quality Flora and Fauna Water Quality
\ 1 . r
Culture and Archaeological Values Scenic and Aesthetic Values Recreational Values
Compatibility of Development State Land Use Districts County Zoning Surrounding Areas Present Land Uses
Economic Impacts Public Revenue Sources Public Service Costs Employment Housing
X
X
.x
X
X
X
X
X X
X
X
XX
X
XX
X
X
X
X
X
X
X
XX
X
X
X
/
x.
X
XX
X
XX
X
X
X
XX
X
XX
X
X X
XX
X
XX
X
XX
X
X
X X
XX
X
XX
X
X
-----------------------------------------------------------------------------------------------------------------------------------------------------------Key:
+90i.=greater than 90% 35% .. 35% or less 25%=25% or less x=moderate impact expected xxasignificant impact expected
APPENDIX A·-1
·"'--
. \ ~· i :
' '"\, i i .
--
ri
• • ·-. ..._
" ',
....
•
/
...... ,. ... c .. -r•••• ... , H I .,.,..
• .. L
• . '
I
(
•• .. ;. . • \
' . ~
~ • ' • . • . \ •
,... . .... ... . /
--·
I ,.-( I ' ll 1/ ~
' 'I _r ........... .._ rl / ~ ..•
_.... .
i
' r ... .. t :,
~:~ I
.................
p u t. c.
,J
• f''
I
I
I
I
I
I
0~ ........ 1/~2 ________ ~ ..___ _____ ........... MILES
0 11.=...2 __ ~
rFigureVI~ ~-----~~~~ KILOMETERS
i KAMAILI SUBZONE SHOWING KNOWN AND POTENTIAL SITE AREAS
I ..... CJ1 ..... I
- ·---- -- •- ,,,._. w_,.._, ___ , ____ ·--------------------------.~~~~.'
l,:r~~;,t~'$;'.~t;j EXISTING SUBZONE
PRO?OSEO SUBZONE
- 90%- PER-:ENT PROBABILITY OF GEOTHERMAL POTENTIAL
J -- -' I ..._-' {
NORTH
~==~0~~-2~~~4~ .... 6 SCALE IN MILE
Figure 39. KILAUEA t1I DOLE EAST RIFT
GEOTHER~1AL RESOUI<CE SUBZOUE
AS PROPOSED
Is 1 and of Haw a i i
• • • Puna Geothermal Venture Project Geothermal Resource Permit Application Amendment
Table 3-5. Composite Geothermal Fluid Chemical Composition
Element
Na K Ca Mg Fe Mn B Br I F Li Cl NH so3(bl Hq As s'c:~ Total Alkalinity HC03
co3
Si02 TSS TDS'dl pH Conductivity
(mhOS/em) Density
600 123
40 1
<1 <1
4 40
<20
Brine ~a~ Cppmw>
- 10,000 2,700
920 2 8.4 8.5
11 80
0.2 0.9 1 9
925 - 21,000 <0.01 - 0.10 9.2 24
<0.001- <0.05 0. 09 - 0. 4 5 100
SlO 0 0
420 70
2,500 S5
18
1,500
- 35,000 5.5
3,100 - 67,000 1.03
Steam Condensa te<-1
Cppmw>
0.17 0.1 0.1
<0.1 0.05
<0.5
<0.01 <2
0.12 13
<0.01
<10 0 0 0.7
15 3.5
120
Composite data from three wells on the PGV site (KS-1, KS-1A, and KS-2) and the HGP-A well.
'81Wellhead pressure = 155 psig; Wellhead temperature • 36a•F (b'concentration high due to oxidation of s· to so .. ~e'concentration low due to oxidation of s· to so,. ~TDS = Total Dissolved Solids
3-24 APPEND IX. R -s-D902201D.840
-' -----------------------------------------
. ) .
GODDARD & GODDARD ENGINEERING - ENVIROllHENTAL STUDIES
Wilson B. Goddard, Ph.D. Chief Research Engineer
Christine B. Goddard, M.A. Manager, Environmental Planner
6870 Frontage Road, Lucerne, CA 954,58-8504 (707) 274-2171 Voice & FAX
ATTENTIOlJ: Peter Adler, Mediator Alternative Dispute Resolution Program
Jane Hedtke, Secretary or R~presentative Kapoho Conununity hse•:>ciation P.O. Box 553 Pahoa, HI 96778
July 31, 1989
Dear Peter:
We have been retained by the Eapoho Community hssociation to re\rievr the env·ironmental impacts of the f·una Geothermal Project. In this reg~rd vle have been supplying guidance and information to the Ka.pc.ho members. The .information that we ha,re supplied has been gained by the 30 years of experience at The Geysers and at other geothe~~al developments in California..
Enclosed for reference and BACT considerations are the rules and regulations applying to geothermal emissions from the Lake County Air Quality Management District. These rules constitute the demonstration of BACT emission limits. Air emissions abo"~e these limits .must be C•)nsidered UOT BF .. CT.
Since the Puna geothermal resource has a hydrogen sulfide concentration of 1, 300 ppm -v.1hich averages 6 times higher than The Geysers average and the area is one of extreme geological instability, health and saftey risks due to hydrogen sulfide air effiission are substantially increased for the local residents.
Our emphasis in the following fi~dings is to ~how that the Puna. Geothermal Ventures proposals are not accepted and demonstrated BJ...CT.
-- --------------·----APPENDIX A-6 f: -,,
':~. l
Proposed Puna Geot.hermal Ventures BACT
o Air en'lission limit.s are not BACT
It is st.ated on page 1 Appendi>: A c,f the Puna Geothermal Venture A'I'C that BACT is defined as "an emissions limitation based on the maximum degree of reduction for a pollutant which would be emitted from any proposed stationary source or modification which t.he director on a case-by-case basis, taking int.o account energy, enYironmental, and economic impacts and other costs, determines is achievable for t.hat source or modification through application of production processes c•r available met.hods, systems, and techniques".
BACT has been demonst.rated at The Geysers and implemented through the Lake County Air Quality .Management Dist.rict Rules and Regulations which are enclosed.
Air Emissions - Hydrogen Sulfide
The BACT has been demonstrated in Califc>rnia to be a hydrogen sulfide eJTdssion limit of 5 lb per million pounds of st.eam released.
Each well during ~drillinvs proposed by ORMAT to be allowed to vent period at c,f hydrogen sulfide per 5 to l~s for each event. The wells are estimated to flow from~o ~ lb/hr of steam. The concentration.. of hydrc,gen sulf~ae ~ed to t.h~-t-traosphere during a 7.5 minute release at 72,500 lb/hr flow is 155 'imes BACT of 5 lb of hydrogen sulfide per 1 million lb of s eam released. Indiv·idual sources are restricted by LCAQHD t.o nc' greater than 150 ppm total sulfur compounds expressed at hydrogen sulfide, Rule 421. These hydrogen sulfide
.!releases can be chemically abat.ed as is done routinely at The ~e:ysers, ~ Air Emissions - Particulates
It has been proposed in the Puna Geothermal venture t.o allo\~ 4 hour full venting c,f wells witJwut the use of cyclc•nic separators. This unabat.ed \~enting is prc•posed to allow particulates to be cleared from the well bore. The estimated venting rate fc,r particulates during well cleanout is 200 · lb/hr (tv.'ice t.he LCAQMD BACT). The LCAQHD Rule 421.1 A and B for part.iculate emissions is an emission limit c,f 100 lb/hr per source and at no time is t.he Califc,rnia Ambient Air Qualit.y St.andard of 50 ug/m3 fc,r a 24 hour average to be e>:ceeded duriJ any phase c,f t.he gectthermal development. These emissions CCQ!_.' abated and silenced t.hrc,ugh the use c,f a@clonic separatO) ~ drawing of which is enclosed. Particulate and hydrogen sulfi~ oemissiCins are abatE!d by chemical injection into the cyclonic separat.or during the venting opE!ration.
j
o :Noise emission 1inaits are not. BACT
BACT for gEtot.hermal deYelopment. in Lake County California is to maint.ain project related noise levels below an Ldn of 55 at the closest residences.
The Puna proposes unmuffled well venting for up to 4 hours which are estimated to produce noise levels of 125 dBa at 50 ft and 83 dBa up t.o c1ne mile away (page 3-100 ATC). Figure 3-22, page 3-103 of the ATC shows 22 residences under 1 mile from the project. This is an extremely high noise level which will surpass county, state and federal cc1des and recommendations.
It is recommended that a cyclonic separator with water and chemical injections be used for noise, particulate and hydrogen sulfide during \\•ell bore venting. Further, all combined noise levels should be maintained below an Ldn of 55 as has been demcmstrated in Lake County, California geothermal developl!"aent and operatiorJs.
Further information and clarification of the air and noise emission limitations may be obt.ained from Robert L. Reynolds, Air and Noise Pollution Ccmtrol and Officer for the LCAQMD at (707) 26 3-7000. since t.hese e.mission limitat.ions are in pract.ice they must be considered as BACT.
Sincerely. ' : '") 0 1 /). I)
~A~ Wilson B. Goddard, Ph.D. Principal
Enclosure: Geothermal Rules LCAQMD and Cyclcmic Separator Schematic
_-,
... ....
A-30 Honolulu Star·Buffetin Thursday, October 28, 1982
;.oGeothermal-~ ,.·
;
1~nhealthy, : \Poctor. Says·' '~ \ 1! By Llewellyn Stone Thompson
, • Biu loland COTT1Pspondelu
liiLO - Geothermal emissions could cause health problellll, J)OS&ibly even eaneer, Ill Puna residents wlthlll 10 to 15 yean If the emissions are not--fl!lly. a bat~ a ,med1cal doetor told the state Boird 01 Land and Natural Resourees yesterday. .
"I'm not saying you shouldn't have geothermal. but you better be jolly well sure ~ control it before you let them go ahead," Dr. Janette Sherman testified.
But under ei'OSI examination. Sherman wu unable to say what level of emissions would be needed to cause Uiness.
Sherman. who described herself u a toxicologist and caneer speelalist with prac:ticel in Detroit and on Maul, wu a wltnesa for the Volcano Community Assoc:lation and others who oppose geothermal development on Campbell Estate lands in the upper Puna dil-trirt. . '
The Land Board eurrenUy II conducttna a court-like hearing on Campbell Estate's request to develop 250 meeawatta of geothennal electricity on Ita 22,000 acres of conservatloa designated lands in upper PuDL · · · · · The hearing be&an Monday and the estate hu been presenting Ita cue first. ShenDSII wu allowed to testify yesterday, before the estate had rlnished calling Ita witnesses, lJe. rause she had to return Immediately to the Mainland.· - - -·· .... ··-"""-···•=-"T-
IN HER TESTIMONY, Sherman warned o1 the health dangers posed by mercurY. mercury compounds, anenac:. selenaum, selenium compounds, hydrogen sulfide, sulfur dloldcle ·and radon. all expected to be found In or produced by geothermal emissions. abe llid.
JllereurY Is a '"general body poison," Sherman testified. Arsenic and selenium are known cancer<auslng agents. while 8Uifur dioxidE' is a "co-careinogen" that eausea cocer when combllled with other aubstaacea; slie said. •
The smelly gas, hydrogen sulfide, II "not just a nulsanee," sbe told the board. The gu interferes with the· body'l ability to c:any oxygen so the body compensates by produe> in~ more red blood eelll, abe said.
The increued red blood cell count leads to "'sludging of the blood." wbleh can cause heart attacks, she testified. . ·
Even if hydrogen sulfide emissions are only at nuisance levels, "we have to question wby we should ask anybody to live where It slinks," jhe said.
THE V ARlO US emissions. in comblnaUoll "ith one another, multiply their effects so that '"the likelihood of caneer Is markedly inrreased." Sherman testified. • Since most houses In· the Puna district get thPlr water from rain runoff from rooftoJll, those water .supplies "wu• aU be poUuted," abe said. ' . · · ' ·'
Campbell Estate attorney BenJamin Mat· 'ubara asked Sherman several Urnes what h·\·el of emissions would be required to produce health problema.
"'I'm not going to give you numben today," •he said. The levels on any clven day are not important since the, poisons aceumulate Ill the environment and In the body, Sherman laid.
The toxina should be controlled 10 that g~ thermal plants do not put any more toxic. substances Into the environment than already exilo't, she said.
APPENDIX B -1
•
o ... ., ... . _ ............. .,. .. .. ......... --... 4alll ........... .... l.ltll
Hr. Sus- O.o
JAI'Ct:Tn: l.t. Sllt'lcaiAN, M: ll. IHIUif~ NIIIM"IHI'
.............
bl!p.rt-t of LIIWI IA4 -.aur•l les011rUJ P.O. ltta 621 lkollolutu. Ill 96809
Pen Hr. Olltl:
h; lila lllNulllt• GeoU .. rul PnJect l~!•lron••hl terut St•t•••t
~tO lilt& Ill. ........ , ..... ......... .,.. -·IJHIII
I II••• rewlewe4 portloas of the llk1uale"1 Geothenaal Project lawlr~t•l l.,•ct Stll ... at. IS .ell as 144ltlaaal c..-eats ..... • Ute utter. .b a fhlfslcl•• M4 1 ...,...r ol tile (avlrM• -•••1 Pratectlaa Ayeacr•s Adwlsorr c ... tttee for the loalc Subst;ances Coatral Act. I ll1ve 1 ....... r af cOACirns about taalc .~l•sluas. wklcll I ltellewe will repres .. t slt~lllcMt 14verse he1ltll ~fleets to persoas working and living Ia the area.
It Is •r tt~~denlM41ag tiNt _, • warletr of dlnaluh Mltte4 lroa Uoe ye11tlte.-..n .. ens. thll the fo11o..lag clonoluh .. I,U t.. jlr~~I:RI Ia tile lllloltlll .tr;
Mercury Arsenic Sele•l-llydru!)en sulfide llrdro<Je• ule~tlte Sull'!'•tr 418alole
I "''' address ea'~ of these c~lc•ls as to their health effects ln a bdel .. nner. l'l~:au! underU.nd ll••l all of U~e oplnluns ue '"I'I'Urtell bJ voi••IMous scientific 4au. II , .... Mbh a for .. l blbllogupl•r Ia \u1•110rt ul tltese coaclusl~~ns, ple•s• let • taow.
"lll(UIIf
"ercurr h a gen~:ral body polsrm, and aller absorption It circulates i• lloe bl~~tul and 15 storl:ll lA the llnr. UdneJSo spleea an4 bone.
Jhe lah•uale"a Ceolherul Project :!!!!!ua..J!~ ._..t~=-e_,2.._ ___ _
llle cltlef a4verse effect Is upcMI tile c .. tr•l aerwG~t5 srst-. Ue .. al•l -.rcurr results lA aeuro-psrcblalrlc 41sor~rs ...... org .. lc .. ,., .. ,., ,eaposure results Ia seasorlaotor 41ullllltlu. Altllouyh lwltll effects ore ll•llar. the cu.aoa eapressluo Is trcAQr. 11~ aeuro-psrchl•trlc signs Include. lasa.nla, e.ullonal lnst•blllty "''"depressive .. ods • lrrlt1blllt1 an4 eaecesslve sllraess. Hercur1 c~s a4wer51lf eflcct the SUa IS well IS tile CUliiiiGitS ltCIIIorMIS Of the IIOUtll. Ud tile tuL ,.4 latestlaes. resultlat Ia colitis. stoaitltls. tloglwiLis ultll loosealog of the teetll. Hercurr a4versly effecls the tldaers. resulting Ia lou of 11"-• Ia tile uri•• ullll secoadarr llrpoprot .. •l•. an4 progreuhe tl•er failure. · .•
usnnc Arsealc lias beea 1 laowa Clrclaogea slace IBtJ. It Is 1 well loow.. polsoa. ~lch. wltlt chronic eaposure ( to continuing low ldwel•) , ... ~ result Ia L111 foll ... lng signs an4 spt~lons:
SUa; hrperkeratosls (tlllctealag of the stla ef the p•l.s aod soles) pl~alatiOA (4arteal•t of the stla) ecze•a ldry. scaling, ltd•lng) ~II•• large blisters) ,.teen white lines acrou nalls
(yes: conjunctivitis (red. llchln~) ede .. of the lids hwelllnyJ
lllr04t: drraus loOifSI!IICU
nervous s,ue•: hudach~s 11Uftlbnen of the ll•bs
Hose; perfor•tlon of u.e se,., ...
Gasttulnlestln•l: sp•s•s dlarrhu nausea vu.lllny
Muscles: spas•s
lllood: aneala decr~:•sed wltlle cells
Cener•l: ..... ts. l.t l~ue
!~
I I I I
I
•
...
Tlo~ KdiMor.t ,,. • a Grot h"nwal Project ~U_!1~~_l2_8l_,_I'~!JI! .::.1 ____ _
SU£NIIIt
Although selenlua has been found to be en essentl•l atnera1 In huaan ~tochealstry, body burdens In excess of 14.6 allllgr..s averAge, can
. result In sl'.)ftlflnttt toxicity. Additionally, there ere sl'.)ftl flnnt d1ta llnllluJ eacess selt!lllua with u11cer lnducttllft. (lposure to hydro91!11 selenlde, Which occurs when selenlua reacts with acid water, results Itt •garltc• hreath, nausea, dlrllness and lassitude. [JI! and nasal lrrltatlllft also occur. (xposure to eapert ... tal IRI .. ls In eacess of 10 parts per atlllon has proven fatal. Selenlua toalclty Includes ce~~tral nen- .rfects (11enowsneu, .--IHn, and conwlslons). Selenlua expo~ure results Jn liver• spleen and bone .. rrow d.aage (reflected 111 ~t~eala). Itt 11vestocl consualng se1enlua at levels or 100 - I ,000 parU per all lion, a s111droat called •talllld shggers• • has been produced -"I cit Includes loss of vis I on, weakness of the Hllbs •nd respiratory failure. Chronic hu.an lntoalcatlon Includes: discolored and ~reared teeth, stln erruptlans, gastro-Intestinal disorders, 1nd loss of hair and nails.
llvestuct foraging on pl.nts containing 1bout 25 parts per a1111on of selenlua developed prohleas with loss of vlta11ty, loss of hair. stt>rlllty, atroplly of the hooves, la~~eness, aneala and necrosis of u.- liver.
Selenlu• has resulted In loss of fertility •nd congenital d~fects I• offspring.
IIYORIIG£N SUtr Ill£
llyolrogPn sulfide Is bnlh ;n Irritant and an uphy•hnt. low conc~ntratlons, (approal .. tely 20- 1~0 parts per allllon) result In Irritation of the eyes. ltlgher conCt'ntratlons rl!sult In Irritation nf the respiratory tract, lncloutlng pul1110narr edema (fluid In the lungs) • H the exl'o\ure coni inue\ lon<J eno":Jh and Is high enough. There Is evidence tloat the .elton occurs heuu\e hydrogen sulfide conhlnes with aolsture on loody surfdccs to fonw sui furousacld as well u sod I,. sui fide, a lnown c•ustlc agent. '(caustic, •eanlng, 1cttng lite lye).
llydroqen -.ul fl•le also results In centr•l n~rvnus system ~rrects~ a thirty •in.,te ~·ro~ure to SOD parts per •llllon, resulted In hudo~che, d lulneu, erci lrment, staqqerlng galt, IS well .s diarrhea, urinary disorders, b~ondoial pneu•onll.
Chronic low l"vel l>nhunln!J re~ults In bt'ad•cht's, lnflo~•d ion of the eyt'S •n<f t'y~lids, diqesthl' dislurb•nces, loss of weight. and general delollltr.
The hhduale'l teolloenw•l rruject June l, 1 '182 J~:~:IJ!:.....:!4 ____ _
HfOROGlN SELlHIOE
As with hydrogen sulfide, the odor of hydrogen selenlde In concentr•tlons below 1 part per alii ton, dlsappe1rs r1pldly because of olfActory f1ti9Ue. Thus, there Is no depend•hle warning to worlers eaposed to tr• ... lly
"Increasing aaounts of these two chealcels. Therefore, they be<aae - accustoaed to It, and the toalclty t1les It toll before they are aware
of the eaposure.
SUlPHUR DIOIIDE
In •ht atr or fogs, sulphur dioxide cOIIblnes with water to fora sulfurous acid, and Is then slowly oaldlle4 to sulfuric ;cld. Obwlous1y, this chealcll Is eatreaely corrosive te the sltn, eyes, nose, throat ••4 pul_u, .. ..,ranes. Conce~~trdlons or froa 6 - 12 parts per ....... cause l ... dl1te Irritation of the nose 111d throat.
Chronic eaposure to sulphur dloalde results In bronchial constriction, chronic cough, s~toas sl•llar to •1st~· and •bronchitis•, IS well 11 Increase I~ alrw1y reslst~nce (lncrtlse In the effort of breathing).
Of even greater concern than the above aenttoned effects, Is the f1ct that sulphur dloalde has bt'en proven to be 1 ~o-c1rclnoge!, that ae1ns that conblned vlth tnown carcl.ugens, It lncre•ses the lltelthood ef cancer foraatlon Itt IS addltlwe or eaponentl•l factor.
The finding th1t the water froa the test wells has 111 acidic nature (~I of l), lndlc1tes that chealcals such as 1rsenlc, lll!rcury 1nd selt>nlu. will have tncre1sed upt1te 111 the body. Addltlon•lly, It IndicAtes th1t stea• resulting froa tt~ well viii Increase the acid rain fall•out, not only In the 1djacent area, hut In tht' at~sphere In general. Additionally. water does run down hill. lhls .cldic water will carry with It a nu.ber or che•lcals, Including those discussed 1bove, resulting In poll~lon of the down hill roct, soli, and ultl•alely the ocean surrounding the area.
It Is •r understanding fro. the environmental Impact stateeent that there Is 1 shifting Mind pattern In the 1rea, gt>nt'rally blowing toward the south and southeast .t night, 1nd the southwest during the d1ytiae. Obviously,. ill of the airborne contaminants would be spread ov~r all of ·the uus, and beuuse of the Increased rainfall, would tend to be suspended In the water, fogs and mist, therebr gaining easy entry Into the lungs and bodies of res I dents 1nd workers of the area.
Oecause of the ulstence of at le.sl two lnnwn carclnngens, arsenic and selent .... as well as a co·c•rclnogen, sulphur dloaide, I concludo! llo01l
t:O
I .1:-
111&' t:.ala•u•lf' 1 5 Ceut~f'll41 Projec1 ~-1 •. -'.~lll .. !'~~ .~ Mltlalo 1 re•sua•lale •vreo of .. ~tc•l cert1latr, thit there Mill ., .. ione•,etl rhl of c .. ccr to ..,,, Marlen ..., re514eoU of u .. uoe.
11« .. 51 of tile ea15t .. ce of '- tollc IIIMIIOCtl flo ecWitloo to tile .c•rciAQ9Polc .. ~ lalrt~ olefeca ceu51 •a4 effecls) I c• COAclude l~t Mltlalo • re•5ua•lale 41gree of .. tllc•l cera•l•lr tlaet ,.,,. •Ill .. 1t1ver~e lle•llla effe~ts to ..rlers ea4 resloleats lo , .. 1re1, locludlag effeLts to tile ceotr•l oervous srst~. resplr•torr SJSle•, g1stro· latestl••l srst .. , lltiAers. p~rlp~r~l oerves, etc.
It siNMIItl .. •olentoo4 t~t 111 ... nGAs are suaptlble to toalc efrects of tlae5e c~lc•ls, laewever, the effects are 1u,.ented oo the foiiOMing groups;
Chlltlreo ..... ,.,.,, People elreedr sick wit~ • varletr of chroolc dlse•s•s ..... ,. ... -Mea .. alclpltlng fathering c•lldrco
l•c:la of tile ... ,. discussed c~lc•ls ••• 1 set of to•lc effects. lo 1.11!!11tlalll.Uw.. ll un be eapec:tc4 tll.t ta.. eflcns 1111Ul lie gruter .... ol sre•ler v•rletr.
for rour lnfof'll4t ion, I •• ·lllc:1udh•9 1 c:opr of •r c:urrlc:ul,.. vlho. I would be a·llll•t to dhcuu .. , of theu .. uen willa J11U It 111 •••rruprl•te ll-. As •otl1111ed eotrllcr I •• vllllng to sup;><~rl Uoese l011C:I•,ioo5 wllk ~llallo9r•pklc: sources, ~ver, II tl .. Is of ess111c:o lo )'1111, I SU9CJCtil tk•l ruu ulolllo • Cllllpulerlled printout fro. • Hlc:ttliflc: Uburr uf )'ltur douln.
If ••r of t~ls requires In)' A441tlon•l lnfo,..lton •nd/or c1Arlflcitlon, plc:•~c: feel lrt:e tu "'"l"cl 1111:.
Ve[»)trulr roun, )
. ---,~«-I.U".It-rO..~aL..__. t_...:!~ll lie II. Slu,nu.ut; H.ll. AI'P---
JII5:jooh CC; llle rawirOMiat•l l)tt~lllr t ... lnlon: SSO ll•let.wlli St., ll01
llunnlulu. Ill 91ollll 1
l'u11• Gelllloe•••l Co .. alllee: 1'.0. Boa l10, Vuluno, Ill 9618!i llendeiiY. h1y, Alliii'IIC:}': 209 .:lncu•le Sl., 12, Ullo, Ill 96120
JANETTE D. (IIICELOWI Slt£RMAN. M.D.
Oflko ' , ...... _ Suite 101'· )100 Wuodwud Avenue, Oelrolt. Ulc:hi!JilA UlOt unt ell-lilt
Ul MArket Slreot, W.tlulu. M•ul. ll•••ll UJtl CUll IU·SIJJ
EDUCATION AND DECREES;
I Hi-lt" (p.rt·li••l
Western MkN!Jift Univenlty, K•l-.a-. utchlg.n O.S. (lUll f.lolj...-s In Oiolugy ••MJ Cl-lllry
Mkltlg;~n S111o University, E11t hnslng, Mlchlg.n Cou••n ••KI l.lilhc••tics
W•yne Stele Unlvenllr Sce-1 ol Uedklno, Detroit, MiLhig~n M.D. (IU•t
POST CRADUATE TRAINING;
I tilt· I tiS
J1nuary IUJ to Dece~~tber ltU
J•nuoary "" 10 o .. ce ... ber .,,,
ISJO to .. resent
EXPERIENCE:
,,S!
ltSJ
lt55·19U
w-en's llosplt•l, Detroit, Mlchlg.n Internship, with rotAtions through Receiving •nd Children's lluspll•b
Olvblon of Reillrch, SJAII Uosph•l of Detroit Detroit. t.tichig•n
N•llon•l lnilllules of llullh Reseuch Tnlnee Liabur•lurr .an<J Clinlul Rc~c...-clt ul Oi.abctc, Llcllllus
Delrolt Cenenl llospll;al (Receiving Unnch) W•yne SUole Univcnily. llctroil, Llichl!).tn
Senior Resident In lntern•l Uc<Jiclne
Veuly post-gr,uJuale counes ;and c.:.nleren-u In lnlern.al Mcdidne. Oc:c:.op•lion•l •nd Envirun~~~cnt•l lle•llh
Atomic Ener!)y Commlsilon R;a<lbtlon L•bonaory University of C•lifurnl•, Oerkeler, C.tlfornl•
R•dlology r.tonllor
U.S. N•vy R•dlologlnl Defense hbontory llunter·~ Polnl, s .. n fr•ncliCU, Cothfurnl•
Rese•rc:h on lherm•l •11d ndiilllun burns, •nd ICUiot bloo<l lou
Oeplrlotant of llor&ic..,.lawe, Mlchlg•n Sa••• Unlvcnltr. Ellil Lllnslng, f.tichlgo~n
Anlll)'llul Chemhl
l
iiW
tJj
I VI
.,~. ,,~,
,, .. , .• TUne
1!70 to Present
"10 ""d on·going
llt•pdrhncnl ol l'hy•lulugy and J'hdnuacology r.tidoi!J•"' Sidle University, F.ost lansing, ll.lichi')an
C.ul ah•oq>llnn studies, ulllhlng Isotopes and analytical du·mislry Stuoli"s on lnoluclion of lulallon In animals wllh tranquilizers
llC!parlmC!nl of Political Science Mid•i!t••n Stale University, Enl lansing, Mll;higan
r.t .. u-allcs"and ~tatlsllcs of collected data
llr.p.,tment of Physiology and Pharmacology Wdyr>e Slah' llnlvurslly School of Medicine Pctroil, Michigan Malheonatics and st;ollsllul ~nalysis of ultrilcenlrlfuge and diUusiun study dilla on prothrombin and ~uto-prothrombi') C
Department of Anesthesiology Wayne Slate llnlvenlly School of Medicine Detroit, Michigan
Clinicill anuihesla. Research ullthlng slop-now renal e•crellon studies of anoxia and hypercarbla • Private practice of Internal Medicine
Research In Occupational ttealth
• lunerlcan Thoraclo Society (MeMber, Planning c-lttee for
Envir-t:ntal and Occupational Health Anetnblyl. l"l Society for Occupational and Envlr-ental Hullh, 11711 American Association for the Advlonc.,..ent of Science, ltJO American Dlabetea Anoclallon, 1961· 10 t.11chigan Diabetes Anoclatlan, lt61·1tJ6 A111erlcan Acad-y of Fa•lly Practice, lt6S• New York Acadetny of Science, 1976· A-rlcan Lung Anodatlon (OOiird of Directors of Southeast
Michigan Divlslonl, ltJJ·Itll American Puhlic llealth Astodatlon, ltlSSoclely for Preventive Oncology, lt77-
IIOSPIT AL STAFFS: - Cnce tlospltal
llarper llospllal
r.t••" MeMorial Hospital
Janelle D. llli!t••lnwl Shern..,n, M.ll.
1"7 to ltJS
ltJD to I!U
l97l to 1976
ltn and· on· going
IIlii to lt77
lt1S
1975 and Current
• lleparlment ol II.IH!idne, Sinal llosphal of Detroit Detroit, Michig3n
Physical diotgnosis for onedlcal students and clinical leaching rounds of residents and lnl'l!rns
Crace llospltotl, Detroit, Michigan
Clinical leaching .ldlal>etes) to residenh and Interns
Der:'arlment nf labor Education, School for Workers, Umverslly of Whconsln, Mildlson, Wi~consin, Ceorge Hagglund, Ph.D.
Adjunct Anoclate Professor. teuher and consultant In occupational medicine and todcology
llarvard University, W.E. Upjuhn Institute for Emplupoenl Research, Washlnylnn, D.C.
Medical Co~sullant In Occupotllonal lle;olth !:tudy
LeCturer In Occupational Medicine at:
University of Indiana, Bloc:lllllngton, Indiana
University of Alat.a.a, Blrllllngha111, Ala~a
University of W. VIrginia, Morgantown, W. VIrginia
University of California, San Francisco, California
Michigan Stat~ University. Ear.t Lansing, Michigan
Unlverstly of AlabaMa, Mobile, Alaba-
llebrew University, Jerusal-. Israel
Unlver•lty of Michigan, Ann Arbor, follchlgan
University of Texas, Calveston, Texas
Speaker at a variety of Educational, Hearth Professional, and Unlo:' Labor ~eetlngs regarding occupational diseases.
The Cooperative Prl111ary Care Preceptorshb Progra111 Schools of Medicine for University of MlcNsian Wayne State University and Michigan State University
T~chlng of 111edlclne to atudentsln oflke practice selling
Testl-ny, U.S. Congreul-1 Sub·C-'ttee on Hearing and Noh;e
Clinical Assistant Professor, Department .of Oncology Wayne State University, Detroit, Mkhlgiln
. '*'\
J•ow:llc lL tlii!J•·a.••I~IICI,.,.,I, M.U.
ISJI au IHO
... , ..... '"'.uut"U
ltlt ISII
Con••oll<ml lo fnvlr-cnl•l l'rulection Aucncy "" Pe•llcklu'• lh ... n t:Ucca. Munilorluu llr<NKh .
a.&u11oloer ul 16 a••nun A~11bury c-auee, U.S. fnvlr-enl•l t•ruh:cliun A94=ncy for lualc Suln.l•nc• Control Ac:t
Clwlf'Jl•r~ olllbk Auaa-cnl Su&o-Cro•op. ltJJ·Itlt. McMilMr. C•ninuyt~n C:Oroup. lUJ ... ,•••nl,
P•dfic Ulcwedlul Ruurch Center Univcnlly of ll•w.dl. tlono!ulu
RncMch In bklod dyw:rnla• iiiKI pnlkld••
I
· ..
•
- -
BIBLIOGRAPHY
1. Proposal Proposal for Designation of Geothermal Resource Subzones by the Board of Land and Natural Resources, 1984;
2. Report : A Report on Geothermal Resource Subzones for Designation by the Board of Land and Natural Resources~ August 1984.
3. ~ Circular C-103 Statewide Geothermal Resource Assessment, DLNR, September 1984.
4. Circular C-106 : Environmental Impact Analysis of Potential Geothermal Resource Areas, DLNR~ October 1984.
5. Circular C-107 : Geologic Hazards Impact Analysis of Potential Geothermal Resource Areas, DLNR, September 1984.
o. Geothermal Resource Permit Application Amendment tor the Puna Geothermal Venture Project~ March 1989.
7. Puna Geothermal Venture Project, Environmental Impact Statement, submitted by Thermal Power Company~ prepared by Flour Technology November 1987.
8. Application tor Authority to Construct Permit for the Puna Geothermal Project Power Plant, March 1989, prepared by Environmental Management Associates~ Inc.
9. Application for Authority to Construct Permit for the Puna Geothermal Venture Project Wellfield, March 1989, prepared by Environmental Management Associates, Inc.
10. West Ford Flat Power Plant Project, Draft Supplemental Environmental Impact Report, December 1987, prepared by Nolte and Assoc.
11. Geothermal Resource & Transmission Element of the Lake County General Plan, Volume 1, draft, 7/12/88.
12. COSO Bureau of Land Management, NWC #1, Authority to Construct, 1988.
13. Mediation of Geothermal Resource Permit Application 87-1, a Final Report Submitted to the Hawaii County Planning Commission, August 21, 1989, Program on Alternative Dispute Resolution.
14. Geothermal Development Policy for an Isolated State~ the Case of Hawaii, Roger M. Kamins, 1975.
15. Assessment Hawaiians,
of Geotherma~
1982. Development Impact on Aboriginal
16. Puna Community Survey, April 1982, prepared by S&M Survey Inc.
17. Cumulative Biological opment 1981, Staff
Impacts of the Geysers Geothermal DevelReport of California Energy Commission.
18. Middle East Rift, Contested Case Hearing, Court Transcript of
November 13, 1985; Testimony for DOWALD G.S. No 9/26/85-5.
19. Thompson & Kats 1977, Effects of Continuous H2S Fumigation on Crops and Forest Plants.
20. Honolulu Star Bulletin
21. Hawaii Tribune Herald
22. Act 296, SLH 1983, signed into law on 6/14/83 directs the BLNR to designate geothermal resource subzones and provides seven
~assessment criteria.
23. Act 151~ SLH 1984, signed into law on 5/25/84 clarifies the rights of lessees holding geothermal mining leases issued by the state or geothermal developers holding exploratory and/or development permits from either the state or county goverment by declaring those areas a GRS for the duration of the lease.
24. Act 378, SLH 1987, July 7, 1987, provides that in applications for geothermal development activities, mediation procedures replace contested case hearing procedures.
25. Chapter 205, HRS, Land Use, Geothermal Resource Subzones.
26. Chapter 343, HRS, Environmental Impact Statements.
27. Title 13, Chapter 184, DLNR Administrative Rules for the Designation and Regulation of Geothermal Resource Subzones.
MER ERZ I<EI~Z
LEF<Z HTH HSB WWF EIR H2S ppb .• ppm ug/m~.::.
pci/l 802 PGV F'GV EIS ?n-c OEC UNIT
GF:S HGP-A
DEFINITIONS
Middle East Rift Zone East Rift Zone Kilauea.East Rift Zone Lower East Rift Zone Hawaii Tribune Herald Honolulu Star Bulletin West Ford Flat Power Plant Project, Geysers Environemental Impact Review Hydrogen Sulfide parts per billion parts per million microgram per cubic meter picocuries per liter (radon) Sulfur dio:dde Puna Geothermal Venture Thermal Power Environmental Impact Statement Authority to Construct Ormat Energy Converter Units, operates on heat energy of the geothermal fluid to vaporize the organic working fluid (isopentane) Geothermal Resource Subzone Hawaii Geothermal Project-Abbot
