Loading...
HomeMy WebLinkAboutCOM 0825.062 2012-2014 Page 1 of 1 Murashige, Laura From: Alyson.K.Yim @hawaii.gov Sent: Thursday, November 08, 2012 9:17 AM - To: counciltestimony @co.hawaii.hi.us Cc: william.j.aila @hawaii.gov; Susan.N.Richey @hawaii.gov; Carty.S.Chang @hawaii.gov; Cameron.B.Black @dbedt.hawaii.gov; AGill @dbedt.hawaii.gov Subject: DLNR Testimony re: Bill 292 on Nov 9 2012 Hawaii Council Agenda Attachments: DLNR Testimony - Bill#292.PDF Aloha- On behalf of William Aila, Jr., Chairperson of the Board of Land and Natural Resources, I am transmitting DLNR's testimony regarding Bill 292 which is scheduled for final reading at the November 9, 2012 Hawaii Council hearing. Thank you. Alyson Yim State of Hawaii Department of Land and Natural Resources Engineering Division ph: (808) 587-0259/fax: (808) 587-0283 email: alyson.k.yim @hawaii.gov Comm. No. 8a S• (O Z Ref.To: /, C ru . c1 Ref. Date NOV 0 9 ZMM1"c 11/8/2012 WILLIAM J,AILA,JR. NEIL ABERCROMBIE ;'S s'�- -h4- BOARD OE LAND Caro TIJ AL RESOURCES .-iGOVERNOR OF HAWAII '�� ID S D 1�� COMMISSION ON WATER RESOURCE MANAGFAfEM `1;1D. " ESTHER KIA'AINA �__.,,,,Ai '1(47 [{r; FIRST DEPUTY OF�AanTi�' ',v I � I�� •`�; WILLIAM M.TAM •ri. �, DEPUTY DIRECTOR-WATER .4", AQUATIC RESOURCES I .W. BOATING AND OCEAN RECREATION ,r -'-�:®' ,�aq�',• BUREAU OF CONVEYANCES _ BOATING ON WATER RESOURCE MANAGEMENT �1^'-`-'--' CONSERVATION AND COASTAL LANDS CONSERVATION AND RESOURCES ENFORCEMENT >,• 4 STATE OF HAWAII ENGINEERING ��y 1A#Im(' DEPARTMENT OF LAND AND NATURAL RESOURCES HISTORIC PRESERVATION -p(r�' KAHOOIAWE OLAIAD RESERVE COSORSSION LAND POST OFFICE BOX 62I STATE PARRS HONOLULU,HAWAII 96809 NOV 8 2012 Hawaii County Council c/o Office of the County Clerk 25 Aupuni Street Hilo,Hawaii 96720 Dear Chair Yagong and Council Members: County of Hawaii Bill No. 292—Relating to Geothermal Drilling The Department of Land and Natural Resources(DLNR)is tasked with the management of geothermal resources and its development to ensure its continued viability for future generations. Geothermal resources development in the State of Hawaii is a priority and has contributed to energy diversification. Bill No. 292 proposes to limit the drilling of geothermal wells that occur within a mile of a residence to between the hours of 7 a.m. and 7 p.m. DLNR opposes Bill No. 292 as restrictions on night time drilling could increase the risk for groundwater contamination and blow-outs. Repeated interruption of drilling operations for extended periods of time is unprecedented in the industry and could contribute to unintended consequences that could impact the public safety and our geothermal and water resources. We wish to share with you information prepared by GeothermEx,DLNR's independent geothermal consultant. The first memo identifies potential public safety impacts that may occur if geothermal well drilling was restricted from the industry standard 24/7 operations. The second memo addresses time and cost impacts that drilling restrictions could also incite. We recognize that noise may be construed as a public nuisance and one of the main reasons for the Hawaii County Council to consider this measure. If noise is the primary concern,we recommend that additional mitigative measures be implemented in lieu of restricting drilling operations at night. We believe this would be a reasonable balance that addresses the concerns of those living in close proximity, while not increasing the risk to public safety or our resources. Thank you for the opportunity to comment. Sincerely, WILLIAM J. AILA, JR. Chairperson Attachments c: DBEDT Geotherm Ex 3260 BLUME DRIVE,SUITE 220 RICHMOND,CALIFORNIA 94806 USA A Schlumberger Company PHONE: (510)527-9876 FAX: (510)527-8164 www.geothermex.com MEMORANDUM To: Carty Chang Date: 31 October 2012 Chief Engineer Department of Land and Natural Resources State of Hawaii carty.s.chang @hawaii.gov cc: Cameron Black Hawaii State Energy Office Department of Business, Economic Development&Tourism State of Hawaii Cameron.B.Black @dbedt.hawaii.gov From: James Lovekin and Eduardo Granados Subject: Safety Aspects of Restrictions on Night-Time Drilling of Geothermal Wells Introduction GeothermEx has prepared this memo to summarize the ways in which restrictions on night- time geothermal drilling could affect the safety of drilling operations. Fundamentally,shutting down drilling operations at night would cause repeated interruptions in the circulation of drilling fluids, and it would extend the period of time in which the wellbore is exposed to drilling fluids without having casing installed. There are three consequences of this that could create adverse conditions for safety: (1) thermal cycling of the well casing; (2) a build-up of gas pressures in the wellhead; and (3) loss of integrity of the wellbore wall. These three topics will be discussed in greater detail below. Thermal Cycling As a geothermal well is drilled, a sequence of pipes(casing strings) are cemented at successively greater depths to help keep the shallow underground aquifers from being contaminated, seal up the upper parts of the well and protect the formation from pressures that could lead to fracturing. By the time a well is completed, there are several concentric strings of casing at the surface,with cement in between each string and in the annulus between the outer casing and the formation. Each casing string is susceptible to thermal expansion when it gets hot, and thermal contraction as it cools. The cement around the pipes helps control this expansion and contraction by binding the concentric casing strings to each other and to the surrounding formation. The cement also prevents the unwanted migration of fluids from the geothermal Page 1 of 3 G eother 1� 3260 BLUME DRIVE,SUITE 220 {. RICHMOND,CALIFORNIA 94806 USA A Schlumberger Company PHONE (510)527-9876 FAX: (510)527-8184 www.geothermex.com reservoir to shallower formations through annular spaces outside the casing strings. In the normal operation of a geothermal well, casings are exposed to periodic cycles of heating and cooling(for example,when a production well is put on line and when it is shut in). These cycles are relatively infrequent, and well-cemented casing strings are designed to accommodate this. However, repeated thermal cycling of a well during drilling can lead to cracking of the cement sheaths around the casing strings. This renders the cement less effective in controlling expansion and contraction. It can also make the cement sheaths prone to leakage of geothermal fluids to zones nearer the surface. Once pathways for fluid flow through the broken cement sheath outside the casing strings are established, they can become progressively worse over time. This can lead to contamination of shallow groundwater aquifers, and in extreme cases,can lead to discharges of geothermal fluids to the atmosphere around the wellhead and from areas at some distance from the well. The odds of this happening are difficult to predict,and the incidence of such leakages is low- in large part because geothermal drilling operations put a premium on keeping circulation going (even when the bits are not penetrating new formation), in order to keep thermal cycling to a minimum. However,an enforced regimen of shutting down drilling operations at night would increase the frequency of thermal cycling and correspondingly increase the safety risk of groundwater contamination and blow-outs. Build-up of Gas Pressures In normal drilling operations,gases that are present in the formation (either in solution or as gas pockets)will typically enter the wellbore in small amounts and be continuously circulated out of the hole by the drilling fluids. Once circulation stops for a period of several hours, these gases can migrate to the top of the wellbore and accumulate in the wellhead. Because they originate in high-pressure zones at depth, these gases actually remain at high pressures as they rise in the well, resulting in an increase in pressure at the wellhead. The higher wellhead pressure, in combination with the hydrostatic pressure of drilling fluids and natural liquid-phase fluids in the well, can exert pressures at the bottom-most casing string that are much higher than just the weight of the liquid-phase column alone. This can lead to fracturing of the formation and flow of drilling fluids or geothermal fluids into unintended zones. Depending on natural zones of weakness,these fluids can break through to shallower intervals, and again there is some risk of a breach to the surface, even at some distance from the wellbore. This is a separate phenomenon from leakages induced by thermal cycling, but the safety consequences of groundwater contamination and well blowout are much the same. Loss of Integrity of Welibore Wall Drilling fluids(often referred to as drilling mud)are designed to coat the wall of freshly drilled hole with a "mud-cake" that seals off small fractures and pore spaces to prevent seepage of drilling fluids into the formation. The formation typically contains certain amounts of clay Page 2 of 3 G a>{"` therm Ex 3260 BLUME DRIVE,SUITE 220 `.L/ 1� RICHMOND,CALIFORNIA 94806 USA A Schlumberger Company PHONE: (510)527-9876 FAX: (510)527-8164 www.geothermex.com minerals (all the more common in rocks that have been altered by high-temperature geothermal fluids),that can swell on exposure to waters of different chemistry than natural formation fluids. It is commonly recognized that the longer the formation is exposed to drilling fluids(even in conditions where circulation is maintained),the more susceptible the formation is to sloughing. To the extent that night-time drilling restrictions increase the overall duration of drilling, this loss of formation integrity can lead to a higher incidence of getting drilling tubulars stuck in the hole. This not only increases the duration and cost of the drilling operation, it also increases the likelihood that some form of uncontrolled flow to the surface will occur, due to the intense use of pressure containment equipment such as blow-out preventers("BOPs") at the wellhead. The loss of wellbore integrity at depth also contributes in some degree to the possibility that geothermal fluids will channel and break through to shallower horizons, thereby compounding the risks of groundwater contamination and blowouts from thermal cycling and gas-pressure build-up. Page 3 of 3 Geotherm Ex 3260 BLUME DRIVE,SUITE 220 RICHMOND,CALIFORNIA 94806 USA A Schlumberger Company PHONE: (510)5274878 FAX (510)527-8184 www.geothermex.com MEMORANDUM To: Carty Chang Date: 12 October 2012 Chief Engineer Department of Land and Natural Resources State of Hawaii carty.s.chang @hawaii.gov cc: Cameron Black Hawaii State Energy Office Department of Business, Economic Development&Tourism State of Hawaii Cameron.B.Black @dbedt.hawaii.gov From: James Lovekin and Eduardo Granados Subject: Potential Effects of Restrictions on Night-Time Drilling of Geothermal Wells Per your request, GeothermEx has investigated questions posed by the Department of Business, Economic, Development and Tourism (DBEDT) regarding the potential effects of restrictions on night-time drilling of geothermal wells. We have considered this topic from the point of view of the additional time and costs that restrictions on night-time drilling would incur. We have also conducted a brief literature search to locate references related to this topic. GeothermEx estimates that a well drilled with 12-hour restrictions at night will take about three times as long to drill as a well without such restrictions. The reason is that,when drilling operations are shut down,safety requires that the drilling bit be pulled out of the hole. This process can take several hours, depending on the depth of the hole. At the start of drilling operations the next day,the bit must be run back into the hole,which can also take several hours. The net effect is that the nominal 12-hour drilling day would get reduced to only about 8 hours of effective drilling. Furthermore, hole stability would likely be jeopardized during the shut-down period due to the additional exposure time of the formation to drilling mud,which can result in de-stabilization of the wellbore wall,especially in hydrothermally altered geothermal zones. Thus,the estimate of 8 hours of effective drilling out or a nominal 12-hour drilling day is probably optimistic, since it doesn't account for extra time to recover from hole stability problems. The tables and diagrams in Appendix A show a breakdown of drilling time and cost for a typical Page 1 of 2 G eotherrn Ex 3260 BLUME DRIVE,SUITE 220 RICHMOND,CAUFORNIA 94806 USA A Schlumberger Company PHONE: (510)527-9878 FAX (510)527-8164 www.geothemtex.com 6,000-foot geothermal well drilled in the mainland US, both as it would normally be drilled (without time restrictions) and for a hypothetical case with 12-hour drilling restrictions at night. The ratio of drilling duration for restricted vs unrestricted wells is estimated at three-to-one,for the reasons discussed above. The illustrative drilling costs for these two cases are not necessarily indicative of actual drilling costs in Hawaii—actual drilling costs depend on a variety of factors, including geologic conditions and rig availability—but the cost ratio of the two cases can be considered representative to a first approximation for a range of drilling conditions, including those typical of Hawaii. This example shows that a well drilled with 12-hour night- time restrictions can be expected to cost roughly twice as much as a well without such restrictions. Appendix B includes an Excel worksheet of references GeothermEx has located in our brief literature search. We are unaware of any jurisdiction worldwide that has placed a blanket prohibition on drilling at night. There are instances of oil fields in urban areas(such as Long Beach,California)where extensive sound-proofing and camouflage have been employed to allow drilling and well-maintenance activities to continue in close proximity to human habitation. In the Long Beach example,there are night-time restrictions on certain drilling- related activities (such as hammering on pipe or the racking of pipe). However, even at Long Beach, the regulations allow for "on-bottom" drilling to continue around the clock. Sound- proofing and light-shielding technologies exist that allow drilling activities to be compatible with rural and touristic environments as well-for example, in the Lardarello area of Italy(Lazzarotto and Sabatelli, 2005). The need for such technologies should be assessed based on site-specific conditions, because noise-proofing and light shielding equipment also add to the cost of drilling. However, they may be appropriate in some settings in Hawaii,and they would have much less cost impact than a prohibition on night-time drilling. Page 2 of 2 G eothe rm E) 3260 BLUME DRIVE,SUITE 220 ` RICHMOND,CALIFORNIA 94806 USA A Schlumberger Company PHONE: (510)527-9876 FAX: (510)527-8164 www.geothermex.com APPENDIX A Drilling Costs With and Without Night-Time Restrictions 00N. MC 0 hhM00 0) N y00 (OMM00�p000IC) NN � ' 00p0pt00MMS00000ONC`0') M X- () N CO CDCr) V N �O) O) W > � � NNtiNMN0) G0 (00 OH��- - of N(M M CH�T0R6909 09 0 69 f9 0 E 0 ✓ o 0 O O ( r•-•(00 0(0 0 0 C00 0(0 0 0 7�0 CO 0 a) 8pp0 (0 (0 p0 t00 (00 _ 0, 1000CD 10 ° 00000000 j"' _ O M - r N OyC N000 N6„, 69;0;6969 • ▪ C N 0 • V a o000000 $ oggg C 0 000 'E 4► CO COCONNN ((0000000 G C o 2 � 000 (00) . NM 'Tr � Nt O a 7 CO c• o = 0CDNrONrC° N VO . 0 Q (/) 0 "ID RS C U) 0 U N C E I • c U (1) ; m ✓ E 0) � 1— a0 •y � z U) r� M > tC C rU) 8 b 0M ?0 _ _ V C C N c C C0 E $ E y E L to. H 0.2 8OO ``"••• Gp op .N C33N Y,� O. vNf° `0 - f6f° _ C) zE coi Rig Working Under Unrestricted Time Cost Curve for Production / Injection Wells Generic Case - Mainland US 0 1 2 1000 - 3 \ - 4 2000 — 5 13000 - - - EXPLANATION 6 4000 1. Prepare Pad and Mobilize Equipment 2. Drill 26" Hole to 800 ft 3. Set and Cement 20" Casing 4. Drill 17-1/2 Hole to 2,000 ft 5. Set and Cement 13-3/8" Casing 6. Drill 12-1/4" Hole to 6,000 ft 5000 - 7. Set and Hang 9-5/8" Slotted Liner 8. Test and Log Well 9. Demobilize Equipment 6000 — 7 8 9 1 1 I I I 0 1,000,000 2,000,000 3,000,000 4,000,000 Cost(US$) Geothermex, Inc. 2012 Rig Working Under Unrestricted Time Time Curve for Production / Injection Wells Generic Case - Mainland US 1 3 1000 2000 .. . . . . p 3000 a� 0 4000 _ _ - i EXPLANATION 1. Drill 26" Hole to 800 ft 2. Set and Cement 20" Casing 5000 3. Drill 17-1/2" Hole to 2,000 ft 4. Set and Cement 13-3/8" Casing 5. Drill 12-1/4" Hole to 6,000 ft 6. Set and Hang 9-5/8" Slotted Liner 7. Log and Test Well 8. Demobilize Rig 6000 . . . 678 0 5 10 15 20 25 30 35 40 45 50 Time (Days) GeothermEx, Inc. 2012 OOC') c•) M1- f'. N- 000 ON CD O0101 cp. CO COCDNNN � O 00MMMQ a, 0 N 0C) co C ' IZ UtnVI ODCnC°. Cr) o) M mN � N0)i1- rn0) C') C`O CO CD > CO o co.o .- f� 01 N CO c7 CD C 4- •- � MMC7000�pprn O 69.69 V3 69 Cfl fA CH CA CA CA 0 E Q C.) pp p OOC700M00O700 e0 CD CZ 0T- �Sjo CS U CCO ti C ip CN- N C Op �- N N CNp 6C V I... 4 13 c a) o 0 0 S 0 0 0 0 0 0 0 0 '.5 a) ao0 0 $ o8p0pSop0p Cl) 'c G .0C70O0NNNCOCOCCO000 a) N 1 c a) 2 C O T- N N 0 COD CCOO `-- N- r C./ a c CZ 0 go QOC° COMNCOM SCD " O - C 0 Ca v C cv a) 2 m 0 I 4_, o N 0 N CCOU 0 13 o U 0 E Z' C 0 V L as f'� Q o N O C>U 0 G 8 b QQ M > 0 CD _ _ d v — N — C CD o 0 0 c o C C4 0 = C�`o CO E a `Q au a y w d E12. 2 a 0 , 00 , BOO6 •N 0.N co +a - as % , d p ' ' '= E Ctl C 17 y � N C C 7 N 0_ 00 ; 0U) c 0u) U) 0 z .- N I)C ' 0 CD is OD CO Cost Curve for Production / Injection Wells Drilling Rig Working Under Restricted Time Generic Case - Mainland US 1 2 1000 3 . 4 2000 5 3000 - Q a) 6 4000 EXPLANATION 1. Prepare Pad and Mobilize Equipment } 2 Drill 26" Hole to 800 ft 3. Set and Cement 20"Casing 4. Drill 17-1/2" Hole to 2,000 ft 5000 5. Set and Cement 13-3/8" Casing 6. Drill 12-1/4" Hole to 6,000 ft 7. Set and Hang 9-5/8" Slotted Liner 8. Test and Log Well 9. Demobilize Equipment 6000 __ 78 9 0 2,000,000 4,000,000 6,000,000 8,000,000 Cost (US$) Geothermex, Inc. 2012 Time Curve for Production / Injection Wells Drilling Rig Working Under Restricted Time Generic Case - Mainland US 0 ,. . . , 1000 „_,,.....,_.r,_„,,,._,,......:., -- -- -- -=1, - --- 2000 . , : 4 p 3000 , 0 , 4000 , , „ „ . CPLAIIATIIO}N 1 1. Drill 26” Hole to 800 ft 2. Set and Cement20" Casing 5000 3. Drill 17,-112" F161646-2,000 ft 4. Set andzCement'F1'3.3/8" Casing ' 5. Drill 1241%4" Hole to 6,000 ft r ,A 6. Set and'Mang}925/,,8':' Slotted Liner 7. Log and Test�Well $. Demobilize R�g4 � k c} 6000 .: ; : ' :6 7, 8 1111111 II III 1111 111111 11111111111111�1 �111111111 Ill 11111111 _II 1 Ill 111 111111 Llll `1 1111111111111_11111111'111111111_ 0 10 20 30 40 50 60 70 80 90 100 110 120 130 140 Time (Days) GeothermEx, Inc. 2012 VV( eothe mi y 3260 BLUME DRIVE,SUITE 220 \� RICHMOND,CALIFORNIA 94806 USA A Schlumberger Company PHONE: (510)527-9876 FAX: (510)527-8164 www.geothermex.com APPENDIX B Preliminary Literature Review of Night-Time Drilling Restrictions a - o a u Y Y To (RS C = ±-' oa -O U a C O p ra CO H C O CO C 7 0 C H CO C a) 'O C C to Y H 3 C u V N t a o >: c O i 1a QS �u v O c 'ua-. 0 .+ a v y c 0 w N C 3 Q on O E i 0 4_. CO O co Y O v O O a ;o a a v L uy ` l a c = co o 0 (raj NO c = N - 2 aij ,n ' I u n. -c c •O C 1] ` 7 L a 0 V U O i C .5 as .ac C oO o O O •U L N o o O a, C u ry .a.• c CV > .-. va, ? E N a) oo ■ Y v ? a0 C u 'c N c 0 Ur a ao a O -a a •= 4.; m t0 = ' a C L a0 L O '4 -0 CO ` O C O 0 •O E a0 U U 1 C a o 0 ., C �• �. O -0 Q ON a C an�O N JO O - ''' ED a C -0 C C L 0 C +' w .c C O c � � v _ _ a z aim a� E v0 c° > `L o ap v o= p - c so -0 o f 'an E o cp o D o CO a °" ?• 2 p �+a C c a i,OD 0 c 0 c v °0 '= v C a m o c Q j c -o a -E «: -, •p 3 o m C Li c m 3 .c 3 ,L ao c E -a, Qq�� v E .0J v. O =m‘n a N U 0 c 'r''yLj C C C v z` a O o a .0 ,� ,�' .t ,� '^ c ., ? L �•.-_- a p a a N E ra ro E ro a o a ., 'c m e �' ° v W d " 2 L v E 2 a E a Ec" toC '" > m ;? caov In 'an ;3 > 'o as o co u = O a . - a '� a 0 u E a .n p 0, •.- v, c 0 ro a ti to Q c2 Q Q v = E ra = o 1-- L :7 c 0 O = o O Z a co Q w to Q E E CO o 3 a La c c 0. C ..• a o co -0 E m y 0. .� c c a 0. 1 -a =D 1a O 3 ,s L 0. L a v Ka a Y a c c a 1 E g o c o u o o p c z 'u c ,: t u oo p c '00 0 y I- I=a 0 O •c a ° E v E n1 v- na °C1 p o � a °' ° 0 0 I% 0 ON U N(a u u 40 ra N ¢I o O co l7 m LL1 Oat ma ` O a p c Q cc E ro `z1 a0 0 d ro 0 N v IV tj C N L 11 5 0 0 w 3 U 0 (D a �c Q J J - 4-1 Ln d N C .._ a ° E v 't . C N 0 .2 v c a 0 0o n o a ao c 3 .o A o m a o ^' a a c Y Z IN • V a N C tV Q 9 o E 'U N N 1` _ d c a -0 T c O r° U 4 • c c o _ c c E � a a, N E t E ;' n E E 0 m a, 3 o v r° 0 ,. o 3 c a CO - r- M L '.0 (7 OL C — C N (Y . In as • C c ■G C C -O C N 0 E U 0 r0 N - c a, O y o `° `^ o m a a o a L a 0 _C c a L] v o ra-cs.c x 00 U M H 'O ro (Jr C a N C E • m L > n u E c' 0 t 3 o o• -- E N o0 6 ou • ° E co 0 ro Y O N cis c E O V o 0 Q L ca m ., c 0 '0 ^.' 0 ! a`_, - co s v u > Ou 0 rd o io v +` L O c E .@.• . o o c •a _ 'E 3 u E _ r u o o o < o C• u U c tea, m Y 03 v u v 0 1—N° c o C7 ,a c L a .. ra C u o o a o 3u 0 Y C N a33i a u u v E u 3c o in •c 73 3 c ^ E 3 c a 3 3 33 c� 1 3 L' 3 1 a 3 Z. a ° m p 3 a 3 3 3 3 u 3 n 3 4 3 3 L a V t V V V E V ra V V L' oat t :p t c r r 31.r L ., L t L ra - L . L r,t L L L .0 0 .0 0) .0 .0