(BIVN) – Continued drilling of injection wells at the site of the Hū Honua Bioenergy facility in Pepeʻekeo is sparking concern in and around the Hāmākua community, but a top plant official says the activity is occurring in accordance with existing permits.

Hū Honua president Warren Lee confirmed that there has been a change in the contractor doing the work. Water Resources International, WRI, has replaced Alpha Drilling. Lee said WRI is finishing up drilling on site for work that has already been permitted.

The activity is occurring as Hū Honua is applying to deepen the injection wells that are already on-site.

On June 21, 2019, the Hawai‘i Department of Health (DOH) said it received a revised Underground Injection Control (UIC) application from Hū Honua, proposing to deepen its the three injection wells to 800 feet. In June 2018, the health department approved the construction of the three wells up to 400 feet.

The DOH is taking comments on whether it should grant a modification of the approval-to-construct the injection wells to 800 feet, as requested. If granted, Hū Honua would still need a separate permit to operate the wells.

An image from the Hū Honua application shows the location if the UIC wells.

An image from the Hū Honua application shows the location if the UIC wells.

According to the Hū Honua application:

After Well No. 1 had been drilled to its permit-approved 400-foot depth, a disposal test was run on February 1, 2019 to determine its capacity with a build-up in the well of no more than 80 feet. That capacity was determined to be 2950 gallons per minute (GPM). The HHB plant requires the combined capacity of its three disposal wells be 15,000 GPM (21.6 MGD). At a minimum, each of the wells would have to have a capacity of 5,000 GPM. Capacities of 7,500 GPM would be far more preferable so that the 15,000 GPM plant disposal requirement could be met with two wells while the third was off line for maintenance and/or rehabilitation. Clearly, far greater capacity than can be provided at 400-foot well depths and gravity delivery is required.

Hū Honua’s requested well section modifications include the following changes and additions:

• The well depths would be increased from 400 to 800 feet;
• Louvered casing, which was not included in the original well design, would be installed; and
• Water would be delivered into the well with a drop pipe.

The application also notes County water concerns:

The County Department of Water Supply (DWS) has expressed its concern about the plant’s disposal activities adversely impacting its Kulaimano (Pepeekeo) Well, identified as State No. 5006-001. The DWS well is located a little over a mile away from the HHB wells. There are two wells situated almost midway between the HHB wells and the DWS well. They are identified as Well Nos. 5005-001 and -007 and both are owned by HHB. They provide excellent locations to monitor the effects of HHB operations on groundwater upslope of the HHB site and one or both will be monitored during testing of the HHB wells and after they are put into operation.

from Hū Honua application, Figure 4. Preliminary Sewalt Simulation Results

Meanwhile, a July 10, 2019 Hū Honua Bioenergy, LLC “Status Report” filing with the Hawaiʻi Public Utilities Commission in the reopened Docket No. 2017-0122 provides more information. 

On May 10, 2019, the Hawaiʻi Supreme Court ruled the PUC failed to expressly consider the reduction of greenhouse gas emissions in its decision-making, vacated the PUC’s approval of the Hū Honua / HELCO Amended PPA, and remanded the matter back to the PUC. 

Logs were already being trucked to the Hū Honua facility in Pepeʻekeo when the Supreme Court issued its ruling, further delaying the project, (image from video by David Corrigan)

Hū Honua says the construction of the project is approximately 95% complete. Hū Honua notes that when it comes to its amended Power Purchase Agreement with HELCO, the “Guaranteed Milestone and Reporting Milestone” deadlines do not begin to run until “the date upon which the PUC Approval of Amendment Order becomes a nonappealable order”, which means “Hu Honua still has several months following a non-appealable order to meet its respective Guaranteed and Reporting Milestones.”

Hū Honua’s failure to meet certain milestones led to the termination of its original PPA with HELCO back in January 2016.

Hū Honua also reported:

Test fire of the facility (for commercial operations) will is expected to occur following completion of construction activities and will include the turbine cooling water system and testing/commissioning of systems to support the test fire in the 4th quarter of 2019. Emissions Testing is expected to commence at or around the time commercial operations begins in December 2019.

Hū Honua notes that, along with the modification of the three (3) underground injection control wells, the company still needs to complete a 4th salt water/brackish water supply well, test service wells #1 and #2, and test various of pumps and boilers.

Hū Honua also lists the permits that are still being reviewed by different government agencies. The following is from Hū Honua’s PUC status report:

• Modification of the ATC for the three UlC wells. Technically, not a permit, but approval by the DOH SDWB is required prior to deepening the UlC wells from 400 feet to 800 feet in order to accommodate the 21.6 MGD required by the cooling water system.
• NPDES Industrial Permit Authorizing Discharges of Storm Water Associated with Industrial Activities under HAR § 11-55, Appendix B. is pending review by the DOH Clean Water Branch (“CWB”). This permit application was initially submitted to DOH CWB on July 5, 2018. The Permit may be issued upon submission of the Storm Water Pollution Control Program and 30-day notice of start of operations. This is currently on hold until closer to facility start-up.
• Mauka Water Supply Well Permit pending review by DLNR CWRM. Drilling of Well #1 completed, pump installed, and testing completion expected in July 2019. Then test data will be submitted to DLNR CWRM prior to operation. Drilling of Well #2 completed, pump installed, and testing was completed in March 2019. Driller to submit test data to DLNR CWRM prior to operation.
• County Building Construction Permits including Service Water/Fire Tank Structure; Boiler and Turbine Buildings Electrical Bid Fuel Yard; Elevator Pit, Blow Down Tank, Flash Tank, Cooling Water Pipe Support, Closed Loop Heat Exchanger, Low Pressure Feed Water Heater Support Foundations; Foundations for Bio-diesel Storage Tank; Biodiesel Tank; Building Pads; Maintenance Building Shell; Chipper Building; Chip Storage Building: HVAC for the Upper Switching Station; Fire Protection; and StepUp Transformer Control Room. Such work has proceeded based on County courtesy inspections and 3rd party inspections.

A public comment submitted to the PUC by Claudia Rohr, a Hawaiʻi Island resident who has actively opposed the Hū Honua project, makes four points in response to the July 10th status report. Rohr writes: 

(1) Hu Honua fails to disclose a requirement to amend SMA 221 to include a weigh station and storage for thirty days worth of fuel located off-site and possibly a Special Permit. In evidence of this I attach communications between the Hawaiʻi County Planning Director and Hu Honua dated December 27, 2017.

(2) Moreover, Hu Honua fails to disclose that it has not secured a final permit to operate its boiler.

(3) Nor has Hu Honua fails to disclose that it has not obtained approval of their Greenhouse Gas Reduction Plan and an application to renew its Covered Source Permit, which expired in 2016.

(4) Moreover, Hu Honua has failed to disclose that it may be required to obtain an incidental take license for killing coral and live rock with its thermal wastewater, or reduce its operating capacity to avoid killing the bottom biological community in order to obtain a permit to operate its Underground Injection Control Wells (“UlC”) to manage thermal wastewater. This lower capacity affects average MW hours a year and would impact the proposed rate structure that has a high fixed rate, low variable rate, a risk to consumers.

“Since Hu Honua misrepresented the state of things last time, the PUC should scrutinize Hu Honua’s representations this time,” Rohr wrote.

Rohr is also suing Hū Honua and the state to force the bioenergy company to comply with state environmental policy law, and prepare an environmental impact statement for the project.