SENATOR RUSSELL RUDERMAN RAISES CONCERNS OF PUNA GEOTHERMAL VENTURE REOPENING AFTER KĪLAUEA ERUPTION
Senator Russell E. Ruderman wrote a letter to Governor David Ige regarding the concerns of his district on the reopening of the Puna Geothermal Venture with little consideration to the post lava flow conditions of the area, and surrounding neighborhoods and farms.
A copy of this letter was sent to DLNR, OEQC, DOH, DOD, CD, USGS and HVO and is seen below.
Aloha Governor Ige,
Following the 2018 eruption, there now exists in Puna an unprecedented situation involving the reopening of PGV’s geothermal plant. Since the entire situation has changed due to the 2018 lava flow, new analyses are required to evaluate the oversight needed.
The Department of Health (DOH) and the Department of Land and Natural Resources (DLNR) have not shown an interest in freshly reviewing the changed situation. While I understand the hesitance to address something so large and difficult to compartmentalize, I represent constituents who ask me every day about these concerns. I would like to respond with something substantive to address their questions.
At present, their impression is that there has been inadequate attention paid by your administration’s departments to the changed situation as PGV prepares to come back online. Unfortunately, I am finding it difficult to alleviate their concerns or offer to them any explanation as to what they perceive is a lack of transparency in the permitting process.
The extreme changes do not fit into any established category, yet there is a clear need for a review of oversight and safety monitoring. I am therefore asking these questions of several agencies. The normal silo-based style of government oversight does not address this situation, so I am asking the entirety of related agencies to review the situation. In some cases, I will address a question to a particular agency, but I ask all relevant agencies to become aware of the situation and respond.
DLNR / Office of Environmental Quality Control (OEQC):
• Normally a new EIS is triggered by a company’s new actions. In this case, the natural world around the plant has changed. There is no clear answer to who should be triggering the new EIS. Perhaps there is someone who sees the whole picture here, who can understand the need for a new, or at least updated, EIS based on the changes. Isn’t a Supplemental EIS in order at the least, before putting the community at risk?
• The underground geological situation is drastically changed. Did DLNR consider the changes due to lava in awarding new drilling permits? In what way did DLNR consider the new conditions?
• The roads in the area were severely damaged, and many roads remain closed. This changes the evacuation situation. Was this considered in awarding new permits? If so, in what way was this taken into consideration?
DLNR, DOD, Civil Defense (CD):
• Have all emergency and normal water supply sources been restored? • Has testing been done to ensure that water discharge and injection before eruption remains a safe option after the eruption, considering possibly changed underground hydrographic structure? Has testing been done to confirm the assumption? • Changes underground to the geothermal reservoir are evident (exact extent of downhole damage to KS-14 and 16 from the magma intrusion at depth is unknown). What needs to be done to reestablish a baseline and institute any needed new safety precautions?
• During the eruption, lava covered three well heads (KS-5, 6 and 11). Have metallurgic and physical damages to the well head been documented and repaired? Is testing required?
• Virtually all the trees, shrubbery and forests that were in the area are now gone. This results in noise and toxic fumes traveling much farther than before the eruption. Was this taken into consideration in awarding new Air Quality permits? In the noise monitoring? In what way was this considered?
• Terrain, communications, transportation, ecology, and demographics have changed at the plant and the area surrounding the plant. Emergency procedure and hazard planning assumptions need to be updated as a consequence of changed demographics and changed road and emergency service availability.
• Does the changed situation require a review and update to plant procedures? Emergency planning, reporting, monitoring?
County CD, DOD:
• Have County and PGV emergency procedures been updated to account for changed demographics, changed road network, and changed topography? Have those changed procedures been approved by State and Local authorities? Is there an emergency response plan? DOH, OEQC:
• Has the DOH air sampling plan been updated to reflect changed topography? Have nuisance noise procedures been updated to reflect changed topography? Has noise testing been conducted or is it planned?
United States Geological Survey (USGS), Hawaii Volcano Observatory (HVO), DOD, DLNR:
• As major changes have been made, does PGV need to do a risk assessment update to the US EPA?
• Have the quantities and locations of fluid re-injection over the last 30 years at PGV regarding its effects on the underground rock structure been analyzed? In what way was this analyzed? Was recent science regarding fluid re-injection's effects on nearby earthquakes and ground faults taken into account? What was the result of the analysis?
Mahalo for your attention to this matter. I look forward to the responses from the relevant departments and agencies under your administration.