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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
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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
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