April 10, 2013

The Honorable Neil Abercrombie
Governor, State of Hawaii
Executive Chambers, State Capitol
Honolulu, Hawaii 96813

Jared Blumenfeld
EPA Regional Administrator
U.S. EPA Region 9
75 Hawthorne Street
San Francisco, CA, 94105

Re: 272 Citizens concerned about local geothermal energy practices.

Dear Governor Neil Abercrombie and Jared Blumenfeld:

In Puna, Hawaii, at 3:53pm on Wednesday, March 13, 2013, Puna Geothermal Venture (PGV) and the surrounding community experienced an emergency venting of hazardous geothermal fluids into the atmosphere. As explained by PGV’s Mike Kaleikini and Hawaiian Electric Light Company (HELCO) President, Jay Ignacio, the release was the result of failed transmission lines that forced the plant into emergency shut down. To protect the plant from overpressure damage, we are told 125,000 pounds of geothermal brine components were vented to the atmosphere over a period of 15 to 20 minutes This is at least the 60th reported release we’ve experienced in the last 20 years. Only now, many of us are learning that this type of industrial pollution is occurring with little or no government oversight.

For two decades, the community at large has been depending on the Department of Health, Civil Defense and other authorities to ensure the health and safety of the residents and schools around PGV’s geothermal plant. During those years, many of us had hoped the plant would be a benefit that would reduce electricity costs and eliminate dependence on foreign oil. While we have yet to see those benefits materialize, recent events have revealed many startling problems with geothermal practices here in Hawaii. We are seeing that a “hands off” approach to regulation has done much to erode the public trust in the government’s ability to safeguard Hawaii’s citizens and environment.

NO CLEAR EMERGENCY RESPONSE PLAN, NO WARNING FOR RESIDENTS

During the March 13 emergency venting, despite Hawaii County Civil Defense (HCCD) identifying hydrogen sulfide (H2S) levels exceeding action levels of 1ppm (1000 parts per billion), it failed to initiate its own emergency response plan guidelines. There appears to have been little coordinated effort to inform the public and the schools or to prevent citizens from entering high exposure areas. No door-to-door notification was made even in residential areas known to have high levels of contamination. Despite 7 schools and hundreds of residences in the immediate area, and despite the EPA making numerous safety recommendations, including the development of a site-specific community evacuation plan, there is still no clear geothermal emergency response plan in place.

DEPARTMENT OF HEALTH, MISSING IN ACTION

The Department of Health is the primary regulatory agency for emissions and monitoring when such a release happens. The DOH’s absence throughout the recent event, and its aftermath, is a clear failure of it duties to the community. DOH was unreachable during the entire venting episode and declined invitations to an important community briefing about the accident. On March 13, many in the community reported a sudden onset of problems ranging from bloody noses and headaches, to nausea and in two cases, fishpond die-offs. To this day, DOH has provided no clear emergency contact list. Due to a conspicuous lack of DOH involvement, the local Puna Pono Alliance has been distributing forms so residents can report their symptoms. They will be supplying DOH with those reports, but many in the community are worried to find that DOH, the primary agency charged with investigating such matters, is not handling this responsibility itself. If they lack staff and resources to perform their oversight duties, they must make it known to the public and to the EPA immediately.

INADEQUATE REGULATION AND OVERSIGHT

The DOH appears to be largely reliant on PGV to monitor itself but this monitoring is clearly deficient in safeguarding the public. This was demonstrated during the March 13 incident. Civil Defense Director, Darryl Oliveira, confirmed that an HCCD emergency response team had hydrogen sulfide (H2S) readings of 1,000ppb and 3,000ppb in residential neighborhoods outside the plant. These readings suggest that the regulatory limit of a 25ppb hourly average was exceeded but without a comprehensive monitoring system in place, and with DOH’s reliance on PGV to self-report, there is no promise of enforcement. Civil Defense’s readings are over 100 times higher than the highest readings from onsite PGV monitors which came in at 19ppb and 27ppb. PGV’s Mike Kaleikini says they had a reading of zero at the source of emission because of a vertical venting trajectory. Emergency response monitoring alone does not provide data about peak contamination levels and duration in the communities where effluents eventually fall. Community based monitors are required.

In terms of monitoring and enforcement, we have witnessed an undeniable pattern of regulatory capture, the phenomenon that prevented the regulators from stopping the chain of events that caused the BP oil spill. Loose attitudes towards environmental safeguards suggest that a culture of industry self-monitoring and lax oversight will be the model going forward as plans for geothermal expansion proceed. Recent efforts to “fast track” state legislation likes Acts 97 and 55, are paving the way for even less oversight as plans for geothermal exploration in West Hawaii, Oahu and Maui come to light. We are reporting from ground zero that listening to industry lobbyists, a few industry funded academics or uninformed environmentalists is an unbalanced policy that only creates the illusion of due diligence.

“CLEAN, SAFE AND SUSTAINABLE”?

The March 13 hydrogen sulfide readings dispel geothermal energy’s “emissions free” myth and shows that their H2S abatement system is not entirely effective. It is important to note that there are many more contaminants that are not being monitored or regulated. Heavy metals and other precipitates from caustic soda that is injected into the Emergency Steam Relief Facility are likely released into the environment. If PGV applies too much caustic soda in an effort to bring hydrogen sulfide content down, it runs a serious risk of exposing the surrounding community to aerosolized heavy metals. Since many nearby residents are dependent on rain catchment systems, a regular application of toxic heavy metals to their rooftops may already be a serious health hazard. PGV has represented that they do not test for heavy metal content, because it is not required by the Department of Health. We have to ask: Is there an ongoing source of contamination that is going unmonitored and unreported? Who is protecting the public, the air, the land and the precious freshwater aquifer from these contaminants? We feel that the current monitoring system does little more than to express contempt for the environment and citizens’ health while supporting the prevailing myth that geothermal energy in Hawaii is “safe, clean and sustainable.”

PGV injects 4.2 million gallons a day of heavily polluted geothermal brine through the water table with no independent analysis of potential contamination and migration to surrounding ground waters. Can an energy resource be called sustainable without verification that it is not contaminating a massive freshwater aquifer? In its 1994 Puna groundwater study (Water Resources Investigations Report 94-4028), the U.S. Geological Survey recommended an ongoing ground water monitoring program “throughout the development of geothermal resources.” Nearly 20 years later, this recommendation continues to be ignored. We ask that the EPA and all relevant agencies begin independent and comprehensive monitoring of the freshwater aquifer and air before any further geothermal drilling and development is permitted.

At 7pm on Wednesday, April 2nd 2013, there was another release at PGV. PGV reports, “We experienced a condensate pump failure at around 7 PM tonight. Gasket and bolt failure resulted in geothermal condensate leak for about 15 minutes before our guys isolated the pump and stopped all leakage.” Though they donned HazMat gear, and many in the community reported the distinct sewer smell of H2S, PGV is claiming no release of contaminants. This time Civil Defense was not notified and, therefore, no accurate, unbiased monitoring was done in the community. It was left to community members to notify one another. At this point, it appears we are entirely dependent on the plant to self-report. We shouldn’t have to explain to you how this is a conflict of interests.

HAWAII’S FUTURE

Reportedly, 20 new geothermal companies are waiting to break ground in Puna, and UH Hilo’s Dr. Don Thomas is exploring for geothermal resources on neighbor islands. In this context, it is important to re-emphasize that the March 13 emergency venting was triggered by failed transmission lines. Future plants will be subject to the same grid weaknesses, the same maintenance circumstances and therefore, simultaneously triggered to release for the same reason. If a single plant is freely exceeding 25ppb regulatory limits at 3000 ppb of H2S during what PGV calls a “best case scenario” well shutdown, what will the future landscape look like with multiple plants simultaneously suffering these “successful” shutdowns? How will these repeated H2S releases affect the communities living in and around the new power plants? What will this mean to the pristine rainforests and aquifers? Are we on a path to making Puna uninhabitable? Will Puna be “the canary in the coalmine” for other parts of Hawaii?

This is not a question of being pro- or anti-geothermal energy. This is about doing it right and making it safe. This is about not poisoning people and the environment based on an unsubstantiated promise of sustainability and energy security. In two decades, geothermal has only increased our electricity bills and subjected us to extremely hazardous conditions. Before we further embrace this volatile energy resource, we must learn more about it’s unique application in Hawaii and how it affects human life and other precious resources.

To earn back the public trust, the Governor’s office, the EPA, HCCD and DOH, must take immediate action to investigate these issues and overhaul the monitoring plan, enforcement structures and the emergency response plan. We ask you to resurrect the sense of civic duty required to remedy this overt failure of oversight. Until the EPA and Hawaii government authorities can fulfill their obligation to safeguard life and land with a single geothermal plant, we citizens of Hawaii, insist that you institute an immediate moratorium on all future geothermal development and exploratory drilling.

Sincerely and with aloha,

272 Concerned Citizens (Names have been withheld but can be provided upon request)