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HomeMy WebLinkAboutCOM 0092.001 2014-2016DENNIS "FRESH" ONISHI Council Member District 3 HAWAII COUNTY COUNCIL County of Hawaii 25 Aupuni Street, Hilo, Hawaii 96720 PHONE: (808) 961 -8396 FAX: (808) 961 -8912 EMAIL: donishifauCO.halvaii.hi.1ls January 30, 2015 Dru Mamo Kanuha, Council Chair . And Members of the Hawaii County Council 25 Aupuni Street Hilo, Hawaii 96720 ", Re: Resolution No. 58 -15 Dear Chair Kanuha and Members of the Council: Enclosed for your information and review are the following PGV Permits: 1. GRP 2 2001 - County Geothermal Resource Permit 2. County permit approved by Mayor Harry Kim to allow PGV to expand up to 60 MW. 2. POO Approval — 28 Wells etc. - DLNR approval to drill up to 28 geothermal wells (14 additional wells plus the original 14 wells) to allow geothermal energy expansion up to 60 MW. 3. NSP 15Dec09 - DOH Clean Air Branch Noncovered Source Permit (NSP) expired in 2014. This permit regulates air quality (emissions, noise, etc.) 4. State UIC Permit - DOH Safe Drinking Water Branch Underground Injection Control (UIC) permit. Regulates use of geothermal injection wells. 5. UIC Federal Apr 06 - EPA Region 9, Clean Water Branch Underground Injection Control (UIC) permit. Regulates use of geothermal injection wells. These documents relate to Resolution 58 -15, on the February 4, 2015 Council agenda. S. cerely, Dennis "Fresh" Onishi DO /de Comm. No. 9a, Ref. To: Hawai `i County is an Equal Opportunity Provider and Employer. Ref. 1 ate 94444f U 13 Harry Kith Mayor CERTIFIED MAIL 7000 0600 0024 2904 6488 FES 0 6 2001 Mr. Barry T. Mizuno Puna Geothermal Venture P.O. Box 30 Pahoa,HI 96778 Dear Mr. Mizuno: County of Hawaii PLANNING COM01ISSION 25 Aupuni Street, Room 109 • Hilo, Hawaii 96720 -4252 (808) 961 -8288 • Fax (808) 961 -8742 Geothermal Resource Permit (GRP 2) Applicant: Puna Geothermal Venture Request: Amendment to Permit Tax Map Key: 1- 4- 1:portion 2, 3. portion 19 and 58 The Planning Commission at its duly held public hearing on January 19, 2000, voted to approve the request for an amendment to Geothermal Resource Permit No. 2 (GRP 2) to allow an increase of generation of electrical power up to 60 MW of electrical capacity, and amendments to related conditions. The property is located on the eastern portion of the Kilauea East Rift Zone, Kapoho Section of the Geothermal Resource Subzone. The project site is located near the junction of the Pahoa - Kapoho and Pahoa - Pohoiki Roads, and adjacent to (north) Lanipuna Gardens Subdivision, Kapoho, Puna, Hawaii. Approval of this request is based on the following: Puna Geothermal Venture (PGV) is requesting the amendment to the permit to develop and operate a 60 MW geothermal power project consisting of multiple power generating units, up to 30 geothermal wells drilled within the subject property, brine and steam pipelines, pollution control equipment, steam separators, production and injection wells, related wellfield equipment, holding ponds, switch yards, office buildings, workshops, control buildings, access roads, and auxiliary facilities such as air compressors, and fire protection equipment, all in a manner consistent with applicable Mr. Barry T. Mizuno Page 2 regulatory standards and permits utilizing new technology and Equipment upgrades. PGV is also requesting the amendments to incorporate regulatory standards and permit requirements that have been promulgated and issued since the permit was originally approved. When GRP No. 2 was approved in 1989, the Island of Hawaii consumed a peak of 130 MW of electrical energy. Consumption since then has steadily increased to a peak of 170 MW in 1999. With the anticipated growth of the Island population, it is expected that the peak requirement will increase approximately 3 -4 MW each year. On October 3, 1989, the Planning Commission approved GRP No. 2 (87 -1) for the Puna Geothermal Venture Project, described as generating 25 MW of electrical energy from geothermal fluids produced from the Puna Geothermal field. The project consisted of the following: • ten (10) integrated back - pressure steam turbines and air- cooled binary cycle turbine power generating modules; • up to 30 geothermal wells drilled from six (6) wellpads; • brine and steam pipelines; • pollution control equipment; • a brine surge tank and holding pond; • a switchyard; • an office, warehouse, workshop, and control buildings • access roads; and • auxiliary facilities such as air compressors and fire protection equipment. The project was approved subject to 50 conditions (the permit indicates 51; however, due to a numbering error, there are actually 50 conditions). The applicant is requesting that 21 of the 50 conditions be amended. The primary reason for the amendments is to incorporate regulatory standards and permit requirements that have been promulgated and issued since the permit was originally approved in 1989. Of the 21 amendments requested, the majority (12) are necessary to incorporate current regulatory standards (Condition Nos. 6, 7, 10, 16 -19, 21 -24, and part of 39), three pertain to the Geothermal Asset Fund (Condition Nos. 29, 40 and 51), one is proposed to be deleted because the condition is no longer relevant (Condition No. 13), and five relate to proposed uses (Condition Nos. 1, 4, 15, 17, 48 and 49). However, the Planning Commission recommends that Condition Nos. 29, portion of 39, 40 and 51 pertaining to the Mr. Barry T. Mizuno Page 3 Geothermal Asset Fund be retained as stated in the permit. The Planning Commission also recommends that Condition Nos. 48 and 49 pertaining to Final Plan Approval and commence construction be retained but clarified to reflect the requested amendment. In accordance with Section 205- 5.1(e), Hawaii Revised Statutes, and Section 12 -6 of the Planning Commission Rule 12, the approval of the amendments is based upon the following findings: The proposed geothermal development activities would not have unreasonable adverse health, environmental, or socio - economic effects on residents or surrounding properties. PGV has been in operation since 1989, and occupies approximately 25 acres within a 500 -acre project area located in the Kapoho Section of the Kilauea Lower East Rift Geothermal Resource Subzone. Each drill site is engineered to support the drilling equipment to keep drilling effluent contained on site, separate from any natural drainage. Each well pad has drilling mud pits, and sumps with sloped walls are used to temporarily store drilling wastes. The high porosity of the volcanic soils and rock in the site area results in rapid downward percolation of rainwater. Concrete pads and berms contain possible spills in areas where chemicals are handled. Catch basins, culverts, ditches, and berms are provided for drainage control. There are no surface streams or ponds in the vicinity of the drill sites, and groundwater is protected by cementing casing into the hole to depths below sea level. The project provides a dependable source of electricity and reduces Hawaii's dependency on imported fuel for greater energy self - sufficiency. PGV has been a reliable source of alternative energy since 1989, and also provides employment opportunities for residents, leading to positive personal income and public revenues. The applicant has taken measures to protect the environment, such as clearing vegetation to prevent fires, incorporating a landscaping program to minimize soil erosion around the perimeter of the property, cementing production and injection well casings into the ground to depths below sea level, well below the potable water table. In addition, the site is several miles from the ocean, therefore, there is no impact to marine life. PGV has developed strict operating, environmental, and safety procedures to ensure the facility is operating safely and in compliance with regulations. An Environmental/Safety Manager is on site to monitor the facility and to ensure that environmental compliance is maintained. The applicant has developed an Emergency Response Plan, which outlines procedures for dealing with any potential emergencies. The applicant has established an internal Incident Command System, and four incident commanders have been trained to coordinate mitigation response as required in an emergency. PGV has also interfaced with the County Police, Fire, Hazardous Materials emergency responder to coordinate training and to familiarize these outside responders with the facility. Mr. Barry T. Mizuno Page 4 The development of the facility has resulted in a number of positive socio- economic impacts on the Island of Hawaii, including 1) the elimination of rolling blackouts, 2) public awareness of the project through contributions and participation in community activities, 3) financial contributions to the Reading is Fundamental Program at Keonepoko School, and 4) payment of royalties to the State of Hawaii in excess of $3 million, which is distributed to the County of Hawaii and the Office of Hawaiian Affairs (OHA). This project supports the following goals and policies of the General Plan: Energy Element * Strive towards energy self - sufficiency for Hawaii County. * Establish the Big Island as a demonstration community for the development and use of natural energy resources. * The County shall encourage the development of alternate energy resources. * The County shall strive to assure a sufficient supply of energy to support present and future demands. * The County shall encourage the development of geothermal resources to meet the energy needs of the County of Hawaii. The economic benefits and security implications of reducing Hawaii's dependence on imported fuels for energy production have been recognized for a long period of time at all levels of government. This has resulted in a general policy of support for alternative energy research and development. Economic Element * Provide residents with opportunities to improve their quality of life. * Economic development and improvement shall be in balance with the physical and social environments of the island of Hawaii. * The County of Hawaii shall strive for diversity and stability in its economic system. * The County shall provide an economic environment which allows new, expanded, or improved economic opportunities that are compatible with the County's natural and social environment. Mr. Barry T. Mizuno Page 5 The County of Hawaii shall strive for an economic climate which provides its residents an opportunity for choice of occupation. Land Use Element * Designate and allocate land uses in appropriate proportions and mix and in keeping with the social, cultural and physical environments of the County. * The County shall encourage the development and maintenance of communities meeting the needs of its residents in balance with the physical and social environment. The proposed geothermal development activities would not unreasonably burden public agencies to provide roads and streets, sewers, water, drainage, school improvements, and police and fire protection. The existing project and proposed amendments have a negligible impact on public infrastructure and services. There are approximately 30 employees on the site, and no additional County services will be required. The employees are mostly Big Island residents, and the increased production . capabilities will not require additional personnel, therefore adverse housing impacts are not anticipated. Traffic may increase slightly during construction phases, but the added vehicles do not significantly add to the existing high traffic levels at the intersection of Pahoa - Kapoho Road and Pahoa- Pohoiki Road. No additional infrastructure is necessary to accommodate the applicant's request, since the proposed use will be confined to the existing facility, and the applicant is requesting the amendments to incorporate regulatory standards and permit requirements that have been promulgated and issued since the permit was originally approved in 1989. There are reasonable measures available to mitigate the unreasonable adverse effects or burdens referred to above. Mitigation measures have been established to ensure the integrity of the geothermal wells. Hydrogen Sulfide (H2S) monitors are located in three locations at the project site. Emergency procedures have been established for dealing with any potential emergencies. Although the project is located more than 2,000 feet from Lanipuna Gardens and Pohoiki Bay Estates, and more than 3,400 feet from Leilani Estates, there are residences within a half -mile of the project site. Due to the relative proximity of the residences to the project area, the applicant has employed the most effective air and noise emission measures available, following strict standards of the Department of Health. The applicant has been and will continue to comply with all applicable regulations regarding environmental monitoring. PGV currently utilizes three geothermal injection wells (KS -IA, KS -3 and KS -4) with a pending application for an additional well. All steam, brine and condensate generated from production wells are injected into these three injection wells at a depth of Mr. Barry T. Mizuno Page 6 between 3,900 and 7,300 feet. These three wells are authorized and permitted by the State Department of Health's Safe Drinking Branch. PGV also holds the State Underground Injection Permit (UH -1529) authorizing the operation of the injection wells. Air emissions are monitored by the use of H2S and particulate matter devices. In the event the H2S concentrations exceed the ambient air standard of 25 ppb on an hourly average basis (regulated by the State Department of Health Clean Air Branch), PGV has developed written safety procedures to mitigate any adverse health effects to the community. At the request of the State Department of Health, a monitoring station has been established at the western property boundary to monitor fugitive emissions to this area. The facility is currently permitted as a Noncovered Source Facility. The Geothermal Compliance Specialist from the State Department Health is on site daily to monitor compliance with emission standards. Noise emissions are controlled by the use of noise abatement materials and sound engineering controls. PGV is operating with a noise permit issued by the State Department of Health Noise and Radiation Branch. PGV is classified as a Class C facility, which allows the facility to operate at a maximum level of 70 dBA, measured 24 hours a day at the property boundary. Noise is monitored by use of noise microphone devices installed at the property boundaries at Monitoring Stations A and B. An alarm system is installed in the Control Room for early detection to allow prompt action if required. The noise alarm setpoint for early warning detection is set at 65 dBA. The measurements obtained at the monitoring stations have all been within the parameters of health, workplace and other standards relating to short or long term exposure to H2S or noise levels. Drilling muds and other wastes not reinjected are disposed of pursuant to the State Department of Solid Waste regulations. Sewage disposal is by cesspool, in accordance with the State Department of Health rules. In the original Geothermal Resource Permit, the permittee agreed "not exceed a general noise level of 55 dBA during the daytime [lam to 7pm] and 45 dBA at night [7pm to 7 am] measured at the nearest residence." This general noise level could be exceeded by up to 10 dBA, but not for more than 10% of the time within any 20 minute period. There was also an exception for periods of venting and drilling. These standards applied only until noise regulations were adopted by the State or County. Because the DOH adopted regulations in 1996, those now apply, and the permittee is allowed to emit up to 70dBA, 24 hours per day. This is unreasonably. loud and the Planning Commission believes that nearby residents are justified in seeking a stricter standard. It is also understandable that they did not expect that noise standards would be so drastically relaxed, after the permittee made representations that the noise levels would not exceed 55/45 dBA. The permittee's noise monitoring records show that it has generally run below 55dBA during the day, but because it is a baseload facility, and runs 24 hours per day, it is not much quieter at night. While the facility itself does not greatly vary from hour to Mr. Barry T. Mizuno Page 7 hour in the amount of noise it emits (except for unusual events, such as steam leaks), atmospheric and wind conditions significantly affect the noise levels in the community, and to some extent, also affect the readings at the monitors. The permittee has stated that it does not expect its increase in power generation to result in a significant increase in noise, but wants some regulatory leeway in the setting of standards. The permittee also believes that it should not be regulated more strictly than other facilities in the agricultural district. The residents have asked that the noise levels not increase, and want the permittee to seek ways to reduce the noise impact from the facility. For these reasons, the Commission recommends that the permittee hire a qualified engineering consultant to review the present operations, as well as to advise on engineering the Best Applicable Control Technology (BACT) into new equipment to be installed at the plant. The proposed noise levels have generally been achieved by the permittee during the January-June 2000 period. They are not meant to imply that these are levels which are "desireable" in an area like this. They have been set at a level which the facility should be able to meet, in recognition of the fact that it provides an important community benefit, and is legally operating under a much more lenient standard. At the same time, the BACT requirement means that feasible noise reduction measures must be implemented, unless the facility substantially complies with residential noise standards. The Department does not wish to mislead the community about the purposes and level of its enforcement of the noise condition. Its role is to ensure that the facility generally runs within the permitted levels. It may spot -check the data it receives from the permittee for reliability, and it may require actual measurements of noise levels at residences, but it does not have the capability to respond to individual complaints on a daily basis. With regards to liability, the Commission recommends that the permittee shall keep in force a general liability policy with limits of not less than $25 million per occurrence, and shall furnish the Planning Department with a certificate of insurance annually. The Planning Director has withdrawn the previous recommendation that the Geothermal Asset Fund be capped at $1,000,000. It became clear from the mediation that no one is happy with the present Geothermal Asset Fund. The surrounding community is fiustrated that only $1,800 in claims have been paid from the fund. The permittee is unhappy that it contributes $50,000 annually to a fund that has not been put to any practical use. The Director notes that the present rules make the Planning Commission function like an insurance claims manager, a role completely unlike its other responsibilities. There is, however, nothing close to a consensus about what to do about Mr. Barry T. Mizuno Page 8 the Fund. The Fund is a major opportunity, and the Planning Department plans to hold further discussions with the affected community about its use. A change in the rules for the fund does not have to be tied to this permit. The rules can be changed at any time. At present, however, because there is no agreement, and because the annual contribution was a result of the prior mediation, the Department does not support any reduction in the amount contributed by the permittee. The Department is willing to consider the suggestion of some community members that the opportunity for owners to participate in a voluntary buy -out program be re- opened, and perhaps expanded to a wider geographical area, and perhaps include some who built after the original permit was granted, but this requires further study, and it does not have to be tied to this permit. The Planning Commission is comfortable with H2S levels presently set by the State Department of Health, but to ensure that these are kept, Condition No. 17 is amended so that the permittee will not ask to increase the levels. Based on the above, the request to amend Geothermal Resource Permit No. 2 (87 -1) is consistent with the criteria contained in Section 12 -6 of the Planning Commission Rule 12 and Chapter 205- 5.1(e), Hawaii Revised Statutes, and the following conditions are hereby amended and renumbered accordingly (material to be deleted is bracketed, material to be added is underscored). 1. The Geothermal Resource Permit grants approval for those uses and improvements described in the "Geothermal Resource Permit Application Amendment for the Puna Geothermal Venture Project," dated March 1989, except as amended, modified, or conditioned by this Geothermal Resource Permit. Except as otherwise described in this permit, no other uses are authorized by this permit[,]_ The following uses are allowed under this Geothermal Resource Permit: turbines, generators, air coolers fans, air compressors, diesel driven pumps and motors, production wells, injection wells, steam separators and accumulators, electrical transformers, control valves, rock mufflers, l3_S abatement equipment, welding machines, drilling rigs and awdliaa eq.uipmeaL designed and operated for the generation of up to 60 MW of geothermal power and any proposed other uses of the geothermal resource or improvements to the land, whether to be conducted by the permittee or a third - party under contract to, or other agreement with, the permittee, shall be subject to prior review and approval, consistent with the applicable Rules of Practice and Procedure of the Hawaii County Planning Commission. The Planning Director may, upon written request of the permittee, approve deviations from the project layout and uses permitted under this Geothermal Resource Permit if such amendments are consistent with the uses permitted and conditions of this Geothermal Resource Permit. No action pursuant to any such request for deviation by the permittee shall be taken without the written approval of the Planning Director. Amendments to the Geothermal Resource Permit and its Mr. Barry T. Mizuno Page 9 conditions may be granted pursuant to Article 12 -9 of the Rules of Practice and Procedure of the County of Hawaii Planning Commission. 2. The permittee, its successors, or assigns shall be responsible for complying with all of the stated conditions of approval of this Geothermal Resource Permit. Should the Planning Director determine that there is noncompliance with the Geothermal Resource Permit or its conditions, the permittee may be subject to enforcement of the Geothermal Resource Permit conditions and penalties pursuant to Sections 12 -10 and 12 -11 of Rule 12 of the Rules of Practice and Procedure of the County of Hawaii Planning Commission. 3. The permittee shall grant unrestricted access to the subject property(ies) to authorized governmental representatives or to consultants or contractors hired by governmental agencies for inspection, enforcement, or monitoring of activities subject to or authorized by this Geothermal Resource Permit. A designated employee shall be available at all times for purposes of supplying information and responses deemed necessary by the authorized governmental representative in connection with such work. 4. During the [period] periods of construction [of the project,) or during the drilling or testing of any well, the permittee shall submit a weekly written status report to the Planning Department which shall include: a. A brief description of the work undertaken during the previous week under the Geothermal Resource Permit; b. A description of the work being proposed during the next week under the Geothermal Resource Permit; and C. Any other information that the Planning Department may reasonably require whit;h addresses the immediate environmental and regulatory concerns of the County of Hawaii or the requirements of the Geothermal Resource Permit. 5. The permittee shall submit a written semiannual status report to the Planning Department by February 15 (covering the preceding period of July 1 through December 31) and August 15 (covering the preceding period of January 1 through June 30) of each year. The status report shall include, but not be limited to: a. A brief summary of work undertaken during the current reporting period under the Geothermal Resource Permit; Mr. Barry T. Mizuno Page 10 b. A brief summary of work being proposed over the next reporting period under the Geothermal Resource Permit; C. The results and analysis of all environmental monitoring activities undertaken as required by this Geothermal Resource Permit; d. A log of any complaints received by the project and the responses thereto; and Any other information that the Planning Department may reasonably require which addresses the environmental and regulatory concerns of the County of Hawaii or the requirements of the Geothermal Resource Permit. 6. If any environmental monitoring data collected as required under this Geothermal Resource Permit indicates [that] the project operations are creating, or have the immediate potential of creating, excessive health or environmental effects not otherwise permitted by this Geothermal Resource Permit, the permittee shall [submit such data to the Planning Department within 48 hours of its identification.] comply with the State of Hawaii Clean Air Branch Noncovered Source Permit ( SP) reporting requirements, and provide immediate notice to the Department of Health, provide immediate notice to the Planning Director and provide a copy of any repodUs to the Planning Department simultaneously with the Department of Health. 7. The permittee shall comply with the Clean Air Branch, Safe Drinking Water Branch, and Department of Noise and Radiation Branch of the Department of Health's recordkeeping requirements. The permittee shall maintain [a record] records in a permanent form suitable for inspection, regarding noise, hydrogen sulfide emissions, equipment upsets, and any other sampling or analytical results, and shall make such record available on request to the Planning Director or his designee. [The record shall include: a. Occurrence and duration of any start-up, shut -down, and operation mode of each geothermal well and/or facility; b. Performance testing, evaluation, calibration checks, and adjustment and maintenance of the continuous monitor(s) that have been installed; and C. All measurements reported in units compatible with applicable standards/guidelines.] 8. Prior to the commencement of any grubbing or grading activity, the permittee shall: Mr. Barry T. Mizuno Page 11 a. Submit a metes and bounds description of all lands to be disturbed including but not limited to all roadways, well pads, steam gathering system corridors, injection system corridors, power plant site, and transmission line corridors to Planning Director; b. Mark the boundaries of these sites to be disturbed in the field; and C. Comply with all requirements of Chapter 10 Erosion and Sedimentation Control, Hawaii County Code (the County grading ordinance). 9. No construction or transportation equipment shall be permitted beyond the prescribed boundaries of the areas to be disturbed. 10. Prior to commencing any geothermal well drilling, testing, production, or injection activity approved under this Geothermal Resource Permit, the permittee shall submit [to, and secure the approval of, the Planning Director of] a hydrologic monitoring program to the State Safe Drinking Water Branch. Semi - annual testing shall.be performed in accordance with the Hydrological Monitoring Program (HMP) which is described in the Hawaii State Underground Injection Control (L!IC) permit. In addition thereto testing of the same wells shall be done within three (3) months after the permittee submits its Well Completion Report to the Department of Land and Natural Resources and after any event that may cause permittee's activities to contaminate the ground water. All data and reports submitted to the Safe Drinking Water Branch shall be submitted to the Planning Director. [The program shall, at a minimum, provide for the quarterly monitoring of water levels and appropriate chemical species from existing wells completed within the shallow aquifer in those areas downgradient of the project area, including the Green Lake water supply, as well as from a well located within the project boundary and completed within the shallow aquifer. The monitoring, sampling, and analysis protocols shall be clearly defined in the program submitted to and approved by the Planning Director. The monitoring and sampling shall be conducted by a qualified contractor, and the samples analyzed by a qualified laboratory, selected by the permittee but subject to the approval of the Planning Director. The selected contractor and laboratory shall operate under contract to, and shall be funded by the permittee. The program shall monitor the shallow groundwater immediately prior to, and during, all periods of well drilling, testing, production, and injection activity approved under this Geothermal Resource Permit. The data obtained shall be submitted to the Planning Director in accordance with the requirements contained in this Geothermal Resource Permit for submittal of all collected environmental monitoring data. The County shall make random checks of the ground water supply no less than every two months.] Mr. Barry T. Mizuno Page 12 11. If pollution of the shallow ground water is demonstrated to be occurring from the project construction, operation or maintenance activities as determined by the Planning Director in consultation with the Department of Water Supply and the Department of Land and Natural Resources, the permittee shall immediately take those measures necessary to eliminate the source of the pollution meeting with the approval of the affected agencies. If any geothermal production or injection well demonstrates that the integrity of the well casing is lost such that the shallow groundwaters are being, or may immediately be polluted by the production or injection activity of that well, the permittee shall, as quickly as practical consistent with safety and prudent operating practices, cease the production or injection activity for that well, and the activity not resume for that well until adequate casing integrity is restored to the satisfaction of the Department of Land and Natural Resources. 113. In the event the Department of Water Supply determines that the existing Green Lake county water source becomes contaminated by the permittee's geothermal wellfield system, the permittee shall immediately provide alternative(s) to the water supply, including the hauling of water if necessary as a temporary alternative, which meet the approval of the County's Department of Water Supply and the State Department of Health. 14.112. Only nonhazardous drilling mud additives, as recognized on the "California Department of Health Services Drilling Mud Additives Use in Nonhazardous Drilling Muds and Fluids" list, shall be used during the drilling of the geothermal wells, and which list shall be on file with the County Planning Department. [15.]13. All drilling mud solids and drill cuttings shall be discharged to and contained within [the well pad sump] an impermeable containment area. A disposal site or sites approved by the State Department of Health, prior to any disposal activity covered by this permit, shall be provided for sump containment contents and other waste materials to be disposed of from the drilling activity. All sumps /ponds /containments shall [be purged in a manner meeting with] have the approval of the State Department of Health. In the event there are no DOH requirements, the applicant and the Planning Department shall request for guidelines from the DOH for the purging of sumps and ponds. Said guidelines shall be available to the community. [16.] -4. All geothermal brines, steam condensate, and noncondensible gases produced during [normal] project operations shall be [injected into the geothermal reservoir] disposed of in accordance with the State Department of Health and Federal Underground Injection Control permit requirements. Mr. Barry T. Mizuno Page 13 [17.]-15 Prior to commencing any activity approved under this Geothermal Resource Permit on the project site, the permittee shall submit an air quality and meteorological monitoring program to, and secure the approval of, [the Planning Director of an air quality and meteorological monitoring program. The program shall include provisions for installation, calibration, maintenance and operation of recording instruments to measure air contaminant concentrations, the specific elements to monitored, the number of stations involved, and frequency of sampling and reporting. The Planning Director shall review and approve the submitted monitoring plan in consultation with and concurrence of the State Department of Health. The monitoring and sampling shall be conducted by a qualified contractor, and the samples analyzed by a qualified laboratory, selected by the permittee but subject to the approval of the Planning Director. The selected contractor and laboratory shall operate under contract to, and shall be funded by the permittee. The program shall monitor the air quality immediately prior to, and during, all periods of well drilling, testing, production, and injection activity approved under this Geothermal Resource Permit. The data obtained shall be submitted to the Planning Director in accordance with the requirements contained in this Geothermal Resource Permit for submittal of all collected environmental monitoring data.] the State Department of Health Clean Air Branch, and shall comply with all NSP requirements and standards. All data and reports provided to the Clean Air Branch pursuant to the NSP shall be made available to the Planning Director for inspection. [18.]16. The permittee shall apply "Best Available Control Technology" (BACT). as defined in Hawaii Administrative Rules 11- 60.1 -1 (as amended), and as applicable under Federal and State regulations and permits, for air emissions to all aspects of the project to minimize air quality impacts. BACT means the maximum degree of control for air quality concerns taking into account what is known to be practical and economically viable. BACT for each aspect of the project shall be [determined by the Planning Director in consultation with other appropriate governmental agencies involved in the control or regulation of air quality from geothermal development projects. Such determination shall be made prior to issuance of any construction permit for that aspect of the project. BACT shall be subject to review by the Planning Director every five years, commencing with the date of approval of the Geothermal Resource Permit for the wellfield operations, and with the date of full power plant operation for the power plant.] in accordance with applicable Federal and State regulations. [19.]17. The permittee shall control all project emissions of hydrogen sulfide during [normal] power plant operation [so that the increase in the ambient hydrogen sulfide concentration due to these project emissions shall not exceed 5 ppb at or beyond the project boundary] in accordance with the State Department of Health Clean Air Branch regulations and NSP requirements. The permittee Mr. Barry T. Mizuno Page 14 shall comply with all provisions of the applicable NSP and shall not request any increase in the levels of hydrogen sulfide allowed under the existing NSF. If the allowed levels of hydrogen sulfide are increased from those allowed under the present NSP the permittee shall continue to meet the standards i the present NSP. [20.] 18. With regard to air emissions, the permittee shall submit to the County Civil Defense and the Planning Department a map and accompanying text that describes predetermined "worst case" impacted areas. [21.]1. [Prior to commencing any activity approved under this Geothermal Resource Permit on the project site, the permittee shall submit to, and secure the approval of, the Planning Director of a noise monitoring program designed to adequately ensure project compliance with the noise impact limitations contained in this Geothermal Resource Permit. The program shall include the monitoring of noise immediately prior to and during all periods of activity approved under this Geothermal Resource Permit. The monitoring and sampling shall be conducted by a qualified contractor, and the samples analyzed by a qualified laboratory, selected by the permittee but subject to the approval of the Planning Director. The selected contractor and laboratory shall operate under contract to, and shall be funded by the permittee. This program should also allow the correlation of any complaints of noise from the public with the level of measured noise, the meteorological conditions, and the type of operations which occurred at the site. The data obtained shall be submitted to the Planning Director in accordance with the requirements contained in this Geothermal Resource Permit for submittal of all collected environmental monitoring data.] The permittee shall hire a qualified engineering consultant to study noise from its existing and proposed operations. The scope of work shall include: a. Determination of sound levels in the surrounding community due to the permittee's operations, and correlation of those sound levels to levels recorded at the monitoring sites on permittee's property. I Identification of specific sources of noise from the plant site. C. Recommendation and evaluation of noise abatement methods, including possible tree planting and/or berm construction, engineering design sketches and specifications and /or catalog cut sheets, and cost estimates for the determination of feasibility and best available control technology. Mr. Barry T. Mizuno Page 15 d. Study of other ambient noise in the community and at the permittee's monitoring stations to determine the effect of ambient noise on the monitoring system. e Preparation of a final report and recommended noise abatement procedures. L The consultant shall meet at least twice with nearby residents and with the Planning_ Director as required The consultant's final report and recommendations shall be a public document available to the Planning Director and the gener public. [22.]M The permittee shall apply `Best Available Control Technology" (BACT) for noise emissions to all aspects of the project to minimize project noise. BACT means the maximum degree of noise control [for noise concerns] taking into account what is [known to be] practical and economically [viable] reasonable. BACT [for each aspect of the project] shall be determined by the Planning Director [in consultation with other appropriate governmental agencies involved in the control or regulation of noise from geothermal development projects. Such determination shall be made prior to issuance of any construction permit for that aspect of the project. BACT shall be subject to review by the Planning Director every five years, commencing with the date of approval of the Geothermal Resource Permit for the wellfield operations, and with the date of full power plant operation for the power plant.] upon the recommendations of the noise consultant. [23.]21. The permittee shall [notify the Planning Department and] comply with the State Department of Health Clean Air Branch (ASP) permit notice requirements prior to any geothermal well and pipeline cleanout utilizing geothermal steam. Permittee shall also mail notice seventy -two (72) hours prior to activities to the Planning Director and to any resident of the District of Puna who submits their name and address to the permittee requesting such notification. In addition thereto any resident within 3500 feet of the permittee's project boundary who has previously requested such notice, shall be notified at least [twenty-four (24) hours in advance of the open venting of each geothermal well and pipeline cleanout and] 14 days before commencement of drilling. [Initial notification to residents shall be made in writing, offering the opportunity to be placed on the notification list. Any other person may request to be on the list. The permittee shall notify the Planning Department immediately prior to the open venting of any geothermal well and pipeline cleanout. The permittee shall notify the Planning Department following completion of each geothermal well, prior to the demobilization of the drilling rig.] Mr. Barry T. Mizuno Page 16 [24.]22 [Until such time as noise regulations are adopted by the State or County, the permittee shall comply with the following guidelines which shall be enforced by the Planning Department: a. During power plant and wellfield operations, the permittee shall not exceed a general noise level of 55 dBA during daytime and 45 dBA at night at the current nearest residence. For the purposes of these guidelines, "night" is defined as the hours between 7:00 p.m. and 7:00 a.m.; b. The allowable noise levels may be exceeded by a maximum of 10 dBA; however, in any event, the generally allowed noise level should not be exceeded more than 10 percent of the time within any 20- minute period, and the permittee shall conduct all operations so as to minimize the occurrence, frequency, and duration of this impact noise; C. The noise level guidelines specified above shall be waived only for the specified duration of authorized open geothermal well venting from all wells, steam pipeline cleanout periods, and the drilling and testing of wells from well pads E and F. During these authorized periods, BACT shall be applied. In addition, during the drilling and testing of wells from well pads E and F, the permittee shall meet a general noise level of 55 dBA during the day and 50 dBA during the night at the current nearest residence; and d. For the purposes of these noise conditions, the "nearest residence" is hereby defined as: For three years following the date of granting of the Geothermal Resource Permit, that permanently occupied dwelling nearest the applicable noise emission point as of the date of the granting of this permit; for all following years, that permanently occupied dwelling nearest the applicable noise emission point. e. Sound level measurements shall be conducted using standard procedures with sound level meters using the "A" weighting and "slow" meter response unless otherwise stated.] The permittee shall report average noise levels for each hour, and shall report a daily average and a monthly average. Except as allowed below: a. The average for any month shall not exceed 54 dBA; b. The average for any day shall not exceed 57 dBA; Mr. Barry T. Mizuno Page 17 C. The average for any hour shall not exceed 62 dBA; d. The average for any five- minute period shall not exceed 68 dBA. The allowable noise levels may be exceeded, at each monitoring station by no more than 3 dBA for the following periods: rive months per year for the monthly average; rive days per month for the daily average; and rive hours per month for the hourly average. During specified steam pipeline cleanout periods, construction, and testing of wells, BACT shall be applied and the allowed noise levels may be exceeded by not more than 5 dBA. During specified periods of drilling, the permittee shall comply with Department of health's noise rules and permit requirements. Averaging shall be done in a manner consistent with the reporting of noise data by the permittee in the January4une 2000 period. The monthly average shall be the arithmetic mean of the daily averages. The daily average shall be the arithmetic mean of the hourly averages. The new allowable noise installation of any additional Noise levels shall be levels measured shall take effect six months after the generating equipment. at the present monitoring stations A and B, which shall be averaged separately, and not combined. The location of the monitoring stations may be changed with the approval of the Planning Director, if recommended by the noise consultant, to make the noise level at the monitoring stations more reliably correlate with the noise levels at the nearby residences. If the location is changed, the allowed levels maybe adjusted accordingly. Data from periods in which the amounts of noise from sources noise monitoring includes significant other than the permittee's operations, such as agricultural operations, rain. The Director. using the recommendations wind, and traffic, shall be excluded. of the consultant, shall establish standard adjustments for the effects of ambient noise on the data reported from the monitoring stations. For example, if the consultant determines that atypical daily average of 51 dBA would be 49 dBA eliminating the effect of ambient noise, the lower figure shall be considered the actual noise level. The Director, using the recommendation of the consultant, shall establish Mr. Barry T. Mizuno Page 18 standard adjustments for the difference between the data reported from the monitoring stations and the noise levels due to the permittee's geothermal operations at the most affected residences, so that the allowed noise levels are not exceeded at the residences which are, on the average, the most affected by noise. The purpose of the standard adjustments is to ensure that the allowed noise levels experienced at residences due to the permittee's geothermal operations are not exceeded. Sound level measurements shall be conducted using standard procedures with sound level meters using the "A" weighting and "slow" meter response unless otherwise stated. The method of measurement shall follow H.A.R. §11-46 -9. The permittee shall have an alarm system which alerts staff if the noise level exceeds 68 dBA for more than 5 minute average. The permittee shall record and respond to all complaints of excessive noise and forward a record of such complaints to the Planning Director monthly, along with monitoring records showing the noise levels recorded at the time of the complaint. All noise monitoring records shall be furnished monthly to the Planning Director. The permittee shall explain any exceedances of the authorized noise levels. Before any enforcement action is taken on violations the permittee shall be given a reasonable opportunity to cure any violations. An exceedance shall not be considered a violation unless the measured noise level is more than 3 dBA above the ambient or background noise level. Der H.A.R. &11- 46(9) (0 and (h1. The permittee shall be conclusively deemed to be using BACT, and be in compliance with all noise standards, if the noise level solely due to its geothermal operations, at the most affected residences, substantially complies with the current State Department of Health standards for "Class A" (residential) districts. For the purposes of this paragraph, the permittee substantially complies with the standards if: a. The average hourly noise levels do not exceed 55 dBA during the day (7:00 a.m. to 10:00 p.m.) and 45 dBA at night (10 :00 p.m. to 7:00 a.m.) more than 10% of the time with the day and night hours separately considered, and b. During those hours when the noise levels are exceeded, the average exceedance is not more than 5 dBA, and the averagg Mr. Barry T. Mizuno Page 19 hourly noise level never exceeds 60 dBA days and 55 dBA nights. Periods of steam pipeline cleanout, construction, well drilling, and highly unusual events shall be excluded and the standard adjustments referred to above shall apply, If the consultant determines that a significant reduction in noise levels can be achieved at a reasonable cost by a vegetative screen and/or earthen berm, the permittee shall set aside an area or areas for such a screen and /or berm The location of the vegetative screen and/or earthen berm, if recommended, shall be agreed upon between the Planning Director and the permitter. and shall not unduly interfere with the permittee's power transmission easements, access, and other aspects of the permittee's operations, and maX be relocated for operational reasons to an equivalent location. The Geothermal Asset Fund may used for the cost of planting and maintaining the vegetative screen and/or constructing the earthen berm. For the purposes of this paragraph, a "significant reduction" means one of 3 dBA or more. [25.]23. Pursuant to Article 12 -8 of the Rules of Practice and Procedure of the County of Hawaii Planning Commission, prior to initiating construction of the project, the permittee shall submit the following to the Planning Director: a. Copies of approved permits and other applicable approvals for the project from other county, state, or federal agencies as applicable; b. Final plans or provisions for monitoring environmental effects of the project as required by this Geothermal Resource Permit or otherwise required to ensure compliance with County rules and the rules of the State Department of Health and Board of Land and Natural Resources and other permit - issuing agencies; C. A final plan of action to deal with emergency situations which may threaten the health, safety, and welfare of the employees and other persons in the vicinity of the proposed project site; and d. A final site plan and elevations of proposed temporary and/or permanent structures for the project. 126.]24. Prior to commencing any activity approved under this Geothermal Resource Permit on the project site, the permittee shall submit to, and secure the approval of, the Hawaii County Civil Defense Director a final plan of action to deal with emergency situations which may threaten the health, safety, and welfare of the Mr. Barry T. Mizuno Page 20 employees and other persons in the vicinity of the proposed.project site. The plan shall include but not be limited to, the following elements: a. A description of the project facilities and operations, with site plans identifying areas of potential hazards, such as high pressure piping and the presence, storage and transportation of flammable or hazardous materials, such as lubrication or fuel oil, isopentane, hydrogen sulfide, and sodium hydroxide; b. A description of emergency services available off -site to respond to any emergency; C. A description of the current onsite chain of command and responsibilities of project personnel in the event of an emergency; and d. A description of potential project emergency situations, such as loss of well control, chemical spills, hydrogen sulfide exposure, pipeline rupture, fires, contaminated solids, etc. identifying: (i) technical data on the nature of the hazard (for example, the concentrations of hydrogen sulfide in the various areas and the hazard associated with these concentrations, the corrosive characteristics of the abatement chemicals), or any data regarding the possible aerial extent of each potential emergency situation; (ii) the warning systems (such as hydrogen sulfide detectors) used to alert personnel of the hazard; (iii) the location and use of equipment used to control the hazard (such as fire protection equipment or isolation valves) or repair hazardous equipment (such as welding equipment or casing sleeves), and safety equipment for personnel (such as respiratory packs), including identification of the personnel trained in the use of that equipment; and (iv) provisions for the monitoring, detection, and inspection of wells and plant facilities for the prevention of emergency situations. e. Provisions to address natural hazards (such as lava flows, earthquakes, and storms) that identify warning systems, control options, steps for securing and shutting down the facility, personnel evacuation, and notification to appropriate agencies; Mr. Barry T. Mizuno Page 21 f. The location and capabilities of available medical services and facilities and plans for treating and transporting injured persons; g. Evacuation plans, including meeting points, personnel rosters, and escape routes; h. Training requirements for personnel, including procedures for emergency shutdown, handling of emergency equipment, spill prevention, first aid and rescue, fire fighting procedures, and evacuation training; Provisions for periodic emergency preparedness drills for personnel; Detailed procedures to be used to facilitate coordination with appropriate federal, state, and county officials during and after any emergency situation; and k. Procedures to be used to identify and inform all residents within applicable distances of the project of the possible emergency situations, warnings, and responses in advance of commencement of project operations and the methods by which all individuals affected by a given emergency will be notified and evacuated, as necessary. Copies of the emergency plan shall be made available to the public by the applicant. [27.]25, Reports and records of emergency situations shall be submitted to the Planning Department upon occurrence of such emergencies. [28.]26. Within 48 hours after an earthquake registering 6 or above on the Richter Scale and/or within 48 hours after an eruption has occurred, all wells within 10 kilometers of the epicenter or eruptive center, shall be examined for any physical changes which would alter its downhole integrity. A report of this examination shall be filed with the Planning Department within 48 hours of the examination. [29.]27. In the event the Hawaii County Civil Defense Agency determines that an emergency situation resulted from the permitted geothermal activity, the permittee shall bear all costs of evacuation. The Hawaii County Civil Defense Agency shall be responsible for public and media notification and evacuation of members of the public in the event the Agency deems such action necessary as a result of an emergency situation. [30.]28 Prior to the commencement of any surface disturbing activity, the permittee shall conduct an archaeological survey of those areas planned for surface disturbance Mr. Barry T. Mizuno Page 22 not previously surveyed and submit the results of this survey to the Planning Department for review and approval. [31]21. If construction activities expose any cultural remains, the permittee shall immediately cease work in the area of the cultural remains and contact the Planning Department and the State Historic Preservation Office. As appropriate, a qualified archaeologist shall be retained by the permittee to implement any necessary mitigation measures and monitor further work. Work in the affected area shall not resume until such time that clearance is obtained from the Planning Department. [32.]M The lighting used shall not interfere with the operations at the observatories located on Mauna Kea. To meet this requirement, the permittee shall comply with the requirements of Chapter 14, Article 9 of the Hawaii County Code, relating to outdoor lighting. [33.]31. All lights shall beat a minimum level consistent with the safety of operations and shall be shielded or directed away from surrounding residential or populated areas and not interfere with important biological resources in the area. [34.]32.,, The permittee shall submit to, and secure the approval of the Planning Director of a detailed landscaping and siting plan. The siting plan shall show plan and elevational views of all proposed temporary and/or permanent structures for the project. The plan shall also show the site topography, natural features and proposed berms, planting schedules, tree sizes, heights (actual size of trees to be planted), type of irrigation system, etc. Installation of approved landscaping improvements shall be commenced within three weeks from the completion of construction of each well pad, access road, or other facility. The plan shall also include: a. A landscaping maintenance program; b. A line -of -sight analysis, being especially sensitive to views from surrounding residences, of the view planes from the site property lines, from the intersection of Leilani Avenue and the Pahoa - Pohoiki Road, for the intersection of the proposed access road and the Pahoa - Kapoho Road, from the intersection of Lauone Street and Hinalo Street in Lanipuna Gardens, and the intersection of the Kapoho - Kalapana Road and the access road to Vacationland; and To the extent possible, the well sites and power plant shall be landscaped and sited to reflect the existing agricultural character of the area, and utilize native plantings. Mr. Barry T. Mizuno Page 23 [35.]33 To the extent compatible with engineering and aesthetic considerations, all exterior surfaces shall be rough texture, with no reflective metal, and no reflective glass surfaces oriented toward surrounding residential or populated areas within line of sight. The exterior of all project structures, including fluid conveyance pipelines, shall be painted in colors so as to blend in with the surrounding environment. [36.]34. The permittee shall submit and secure approval of a revegetation/site reclamation plan meeting with the approval of the Planning Director in consultation with the Forestry Division of the Department of Land and Natural Resources. When construction is completed on any individual project site, or if the project area is abandoned, all denuded areas on and around the project site shall be revegetated in accordance with this plan. Said plan shall include appropriate security to assure its implementation in a timely manner. [37.]3. The permittee shall obtain and maintain those bonds required for project operations by the rules and regulations of the Board of Land and Natural Resources and the Department of Health. [38.]x,. The permittee shall obtain and maintain builder's risk and comprehensive liability insurance for project construction and operation activities, with a limit of not less than $25 million per occurrence. [39.]32. In accordance with community notification requirements of the State Department of Health Noncovered Source Permit (NSPI, the [The] permittee shall notify each resident household within a radius of 3500 feet from any geothermal well at least twenty four (24) hours prior to[, and again the morning of,] any planned venting of [that well] a geothermal well. Each resident within this radius of 3500 feet shall be offered the opportunity to voluntarily leave the area during the well venting. The cost of such voluntary leaving, up to a maximum of $100.00 per resident or $200.00 per household, whichever is lesser, shall be borne by the permittee. Upon adequate demonstration [to the permittee] that any such resident is unable to pursue his normal, legitimate employment or business activity as a result of such voluntary leaving, the permittee shall reimburse that resident for that one day's lost income, in an amount not greater than $150.00. [40.]38. Upon adequate demonstration to the permittee that any adverse alteration of the quality of the water has occurred as a result of venting to the atmosphere, the permittee shall immediately rinse the water catchment system and replace the stored water of any water catchment system within a radius of 3500 feet of any well. Upon adequate demonstration to the permittee that any agricultural crop Mr. Barry T. Mizuno Page 24 damage resulted directly from any of the permittee's well venting operations, the permittee shall also provide compensation to the owner of agricultural operations located within a radius of 3500 feet of that well. In either situation, compensation will only be considered if the agricultural crops and water catchment system are inventoried and registered with the permittee prior to the venting. Other requests shall be considered by permittee on a case -by -case basis. [41.]3 The permittee shall establish and publish a telephone number for use by local individuals for the lodging of complaints or inquiries regarding status of operations. A designated representative of the permittee shall be available, 24 hours a day, to respond to any local complaints or inquiries. [42.]40. Large vehicle deliveries to the project site shall be limited to daylight hours. For the purposes of this condition, daylight hours is defined as the hours between 7:00 a.m. and 7:00 p.m. This condition shall not apply for vehicles responding to emergencies. [43.]43. An extension of time for the performance of conditions within the permit may be granted by the Planning Director upon the following circumstances: 1) the non- performance is the result of conditions that could not have been foreseen or are beyond the control of the applicants, successors, or assigns and that are not the result of their fault or negligence; 2) granting of the time extension would not be contrary to the General Plan or Zoning Code; 3) granting of the time extension would not be contrary to the original reasons for the granting of the Geothermal Resource Permit; and 4) the time extension granted shall be for a period not to exceed one (1) year and 5) if the applicant should require an additional extension of time, the Planning Director shall submit the applicant's request to the Planning Commission for appropriate action. [44.]42. All other applicable rules, regulations, and requirements, including those of the State Department of Health and the State Department of Land and Natural Resources shall be complied with. [45.]43. The permittee shall obtain, and comply with the provisions of, permits to drill, modify use or abandon, as appropriate, from the State Board of Land and Natural Resources for each geothermal well approved under this Geothermal Resource Permit. [46.] The permittee shall obtain and comply with the provisions of, Underground Injection Control Permits, as appropriate, from the State Department of Health for all geothermal injection wells approved under this Geothermal Resource Permit. A copy of the UIC Permit and any conditions shall be available in the County Planning Department. Mr. Barry T. Mizuno Page 25 [47.]45. The permittee shall obtain, and comply with the provisions of, Authorities to Construct and Permits to Operate from the State Department of Health for all applicable project operations approved under this Geothermal Resource Permit. [48.]46. The permittee shall secure [all necessary approvals and clearances including] EiRal Plan Approval pursuant to Chapter 25 of the Hawaii County Code, [within one (1) year from the effective date of the Geothermal Resource Permit] prior to each incremental increase in power production. [49.]42. Construction shall commence within [one (1) year] two (2) years from the date of receipt of Final Plan Approval for each incremental increase in power production. [50.]48. The permittee shall submit a written semiannual status report to the Planning Commission on the permittee's best efforts to address /comply with the "Other Agreements and Recommendations" as contained in Section 5 of the final report on "Mediation of Geothermal Resource Permit Application 87 -1" dated August 21, 1989, and in Section 5 "Final Report" dated December 30, 2000, on the mediation of the proposed amendments to conditions contained in the "Application For Amendment to Geothermal Resource Permit regarding but not limited to the collateral agreements and commitments the permittee made during the mediation process, and which the permittee considers to be contractual obligations subject to the issuance of a satisfactory Geothermal Resource Permit. This status report shall be submitted by February 15 (covering the preceding period of July 1 through December 31) and August 15 (covering the preceding period of January 1 through June 30) of each year. [51.]49. Prior to the issuance of the first building/construction permit under this Geothermal Resources Permit (GRP) by the County of Hawaii, the State of Hawaii and the permittee shall each contribute towards a Geothermal Asset Fund or other appropriate existing fund for the purposes of geothermal impact mitigation efforts within the District of Puna. The permittee's initial contribution to the f and shall be a sum of $60,00, due within thirty (30) days after the effective date of this GRP permit, and annual sums of $50,000 due on or before the anniversary date of this GRP permit over a period of eight (8) consecutive years thereafter for a total of $460,000. Annual contributions thereafter shall be determined between the permittee and the State of Hawaii or $50,000 annually, whichever is greater. The State's initial annual contribution to the Geothermal Asset Fund shall be the net revenues derived from the resources generated by the HGP -A Well, or a similar amount from other State funding sources less any allocations entitled to the Office of Hawaiian Affairs and operations and maintenance costs. In the event that future enabling legislation provides for a percentage of the State's geothermal royalties to be allocated to the County, upon Mr. Barry T. Mizuno Page 26 concurrence with the County Council, said royalties may also be deposited to the fund. The administration and expenditure of assets from this Geothermal Asset Fund shall be in accordance with rules, regulations, and procedures developed for that purpose by the County in accordance with Chapter 91, Hawaii Revised StaAutes, and with participation of Puna residents or representatives thereof, which shall include, but not be limited to, provisions and criteria to enable the first priority of distribution for temporary or permanent relocation of those property owners who are found, in accordance with criteria established in the rules, to be adversely impacted by the activities authorized, provided that such relief is applied for within a period of one (1) year of the impact. A priority list of impact mitigation projects may be established by the County Council or agency designated by the Council in conjunction with Puna residents or designated representatives thereof, with the exception of upgrading existing subdivisions in the Puna District to current subdivision standards and specifications of the County of Hawaii. Should any other district(s) of the County of Hawaii be proved to be negatively impacted by activities authorized under this or any other subsequent GRP, that district shall receive a pro rata share of the fund assets as may be determined by the County Council or agency designated by the Council with expenditures to follow a prioritized schedule determined as outlined above. The rights granted to the permittee shall not be conditioned upon any contribution or further participation by the State in the fund nor with respect to the creation, management, and operation of the fund other than set forth above. 51 Upon termination of the operations or abandonment of any portion of the affected site, the land shall be graded to blend with he surrounding areas and revegetated Further, the site shall be left in a nonhazardous condition A plan for compliance with this condition shall be submitted to the Planning Director for review and approval within ninety (9-0Ldays from the date of termination or abandonment. and upon completion of the plan, notice of completion shall be given to the Planning_ Director. This approval does not, however, sanction the specific plans submitted with the application as they may be subject to change given specific code and regulatory requirements of the affected agencies. Mr. Barry T. Mizuno Page 27 Should you have any questions, please contact Alice Kawaha of the Planning Department at 961 -8288. Sincerely, Geraldine M. Giffin, Chairman Planning Commission LpgvM2pc cc: Department of Public Works Department of Water Supply County Real Property Tax Division Department of Land and Natural Resources Kazu Hayashida, Director/DOT- Highways, Honolulu Department of Health Civil Defense Agency Department of Business, Economic Development & Tourism Mr. Jack Dean Ms. Annie Szvetecz Mr. Robert Kochy Mr. Al Dettweiler Diane and Steve Moynihan Jennifer and Delan Perry Mr. Steve Philips Ms. Aurora Martinovich Ms. Kate T. Harrison Ms. Paula Z. Helfrich Mr. Donald M. Thomas Mr. Gene Thomas Ms. Athena Peanut Ms. Luana Jones Ms. Marlene Dykema & Mr. Jim Rice Ms. Rene Siracusa Colin Love, Esq. R. Ben Tsukazaki, Esq. 4 LINDA LINGLE GOVERNOR OF HAWAII t L and Hags STATE OF HAWAII DEPARTMENT OF LAND AND NATURAL RESOURCES Of ENGINEERING DIVISION PO BOX 373 HONOLULU, HAWAII 96809 JAN 17 2006 Mr. Barry T. Mizuno, Owner's Representative Puna Geothermal Venture Post Office Box 30 14 -3860 Kapoho Pahoa Road Pahoa, Hawaii 96778 Dear Mr. Mizuno: PETER T. YOUNG CHAIRPERSON BOARD OF LAND AND NATURAL RESOURCES' COMMISSION ON WATER RESOURCE MANAGEMENT ROBERTK.MASUDA DEPUTY DIRECTOR -LAND DEAN NAKANO ACING DEPUTY DIRECIOk . WATER AQUATIC RESOURCES BOATING AND OCEAN RECREATION BUREAU OF CONVEYANCES COMMISSION ON WATER RESOURCE MANAGEMENT CONSERVATION AND COASTAL LANDS CONSERVATION AND RESOURCES. ENFORCEMENT ENGINEERING FORESTRY AND WILDLIFE HISTORIC PRESERVATION KAHOOLAWE ISLAND RESERVE COMMISSION LAND STATE PARKS Amendment to Plan of Operation for Puna Geothermal Venture, Geothermal Resources Minins Lease R -2. Kapoho, Puna, Hawaii At its regular meeting held January 13, 2006, the Board of Land and Natural Resources (BLNR) approved Puna Geothermal Venture's (PGV's) request for amendment to the Plan of Operation for the development of fourteen (14) additional geothermal wells for future expansion to 60 megawatts of power for the geothermal project on Geothermal Resources Mining Lease R -2. Approval is subject to PGV's compliance with all applicable statutes, ordinances, rules and regulations of the Federal, State and County governments, and other terms and conditions that may be prescribed by the Chairperson of the BLNR. A copy of the approval is attached for your use and information. If you have any questions, please call me at 587 -0230. Sincerely, ERIC T. HIRANO Chief Engineer Enclosure STATE OF HAWAII DEPARTMENT OF LAND AND NATURAL RESOURCES Engineering Division Honolulu, Hawaii January 13, 2006 Board of Land and Natural Resources State of Hawaii Honolulu, Hawaii Approval of Amendment to the Plan of Operation for Puna Geothermal Venture, Geothermal Resources Mining Lease R -2, Kapoho, Puna, Hawaii As required by Geothermal Resources Mining Lease R -2 (GRML R -2) and Chapter 13 -183, Hawaii Administrative Rules, Puna Geothermal Venture (PGV), sublessee, has submitted for Board of Land and Natural Resources approval a request for amendment to the Plan of Operation for the development of fourteen (14) additional geothermal wells for future expansion to 60 megawatts (MW) of power. The request encompasses the designation of fourteen (14) additional wells, well sites to accommodate the additional wells, and a potential site for additional power generating equipment. PGV currently has approval in the Plan of Operation for 14 geothermal wells to supply the Hawaii Electric Light Company (HELLO) with up to 30 MW of power. It is the intent of PGV to provide ( HELCO with additional output to meet HELCO's needs up to 60 MW, which PGV is permitted under the County of Hawaii Geothermal Resource Permit. PGV is presently in negotiation with HELCO to provide an additional 8 MW of electricity by the end of 2007. RECOMMENDATION: That the Board of Land and Natural Resources approve the amendment to the Plan of Operation submitted by Puna Geothermal Venture for fourteen (14) additional geothermal, wells and future expansion to 60 MW of power for the geothermal project on GRML R -2, subject to the following conditions: 1. That Puna Geothermal Venture comply with all applicable statutes, ordinances, rules and regulations of the Federal, State, and County governments. 2. Other terms and conditions as may be prescribed by the Chairperson. Attachment Respectfully submitted, `� ;;, � ` ERIC T. HIRANO Chief Engineer ;Proved by the Board of Land b Natural RONUMN at the Mee ing held dt -- r L ITEM L -1 'Post Office Box 30 �t 11VA 14-38W Kapoho Pahoa Rd. GEORFiER UN VfNf13RE Pahoa. Hawaii 96778 Telephone (808) 965 -6233 Facsimile (808) 965 -7254 November 17, 2045 HAWAf l Mr. Peter Young Department of Land and Natural Resources State of Hawaii P.O. Box 621 Honolulu, HI 96809 SUBJECT: PLAN OF OPERATION MODIFICATION Dear Mr. Young: Puna Geothermal Venture (PGV) hereby requests a modification to the Plan of Operation. Currently, PGV has approval in the Plan of Operation for the development of fourteen (14) geothermal wells. These 14 wells have been designated to supply the existing power plant with the production and injection resources required to fulfill the 30- megawatt contract with the utility. PGV has recently completed the re- drilling of existing production well Kapoho State 10 (KS -10) and the drilling of a new production well Kapoho State 6 (KS -6). Both of these wells are in service and supplying the power plant with steam to ensure the stability of power generation. Presently Kapoho State 13 (KS -13) is near completion. The intent is to utilize KS -13 for injection purposes. For future expansion to 60 megawatts, PGV requests approval for an additional 14 geothermal development wells. These additional wells will supply production and injection resources required for expansion to 60 megawatts. PGV respectfully requests approval from the Department of Land and Natural Resources (DLNR) for the designation of 14 additional wells, well sites to accommodate the additional wells, and a potential site for additional power generating equipment. Additionally, PGV seeks to amend the plan of operation to reference 60 megawatts of output and the additional power generating equipment needed to achieve 60 megawatts. PGV is currently in negotiations with Hawaiian Electric Light Company ( HELCO) to provide an additional 8 megawatts of electricity by the end of 2007. It is the intent of PGV to provide HELLO with additional output to match their needs up to the 60 megawatts, which we are currently permitted under the County of Hawaii Geothermal Resource Permit. T: 1BTMICQRRESAUnDLNR\DRILL(NG\05i I17P00mod4.doc We certify drat this dog; m=9 and all its are M 10CUMG and oatgkk. pmt m HAR 11.60.14. A Hawaii Partnership Mr. Peter Young November 18, 2005 Page 2 Attached please find a map (Figure 1) showing the 14 additional wells, their projected well sites and a potential power plant site. Table 1 designates the name and location of each well. The exact wellhead coordinates have not been finalized at this time. The wellhead coordinates will be submitted to DLNR as part of the drilling permit application prior to the commencement of drilling. Should you have any questions, please do not hesitate to call me at (808) 965 -6233. Sincerely, airy T. Mizuno Owner's Represen cc: Eric Tanaka, DLNR Enclosures: Figure 1 Table 1 T:187U\CORMt OU7NDLNRIQRILLING1051 i t7POpmod Aoc We ca* OW this dooms t and all atmckmmts are true, accurate, and cOMIele. Pursuu+t to HAR t t -W.1.4. rn 0 3 It Mp 0 3 It i PGV WELL LAYOUT FUTURE EXPANSION - - _ - - ------------ - ---------- .- ._... - ....... TABLE 1 Comments: _� 11111 Comments: CERTIFIED MAIL 09 -1073E CAB RETURN RECEIPT REQUESTED File No. 0008 -09 (7009 0960 0000 3852 6131) Mr. Michael L. Kaleikini Plant Manager Puna Geothermal Venture P.O. Box 30 Pahoa, Hawaii 96778 Dear Mr. Kaleikini: Subject: Noncovered Source Permit (NSP) No. 0008 -02 -N Application for Renewal No. 0008 -09 Puna Geothermal Venture 41 MW (Nominal) Geothermal Power Plant, Wellfield, and Geothermal Exploratory/Developmental Wells Located at 14 -3860 Kapoho - Pahoa Road, Pahoa, HI 96778 Date of Expiration: December 14, 2014 The subject Noncovered Source Permit is issued in accordance with--Hawaii Administrative Rules, Title 11, Chapter 60.1. The issuance of this permit is based on the plans, specifications, and information that you submitted as part of your renewal application dated September 18, 2009. This permit shall supersede Noncovered Source Permit (NSP) No. 0008 -02 -N issued on December 27, 2004 and amended on April 22, 2005 and August 17, 2006 in its entirety. A receipt for the application filing fee of $100.00 is enclosed. The Noncovered Source Permit is issued subject to the conditions /requirements set forth in the following Attachments: Attachment I: Attachment IIA: Attachment IIB: Attachment III: Attachment IV: Standard Conditions Special Conditions: Power Plant Special Conditions: Wellfield and Geothermal Exploratory/Developmental Wells Annual Fee Requirements Annual Emissions Reporting Requirements The following forms are enclosed for your use and submittal as required: Annual Fee Form Monitoring Report Form: Operating Hours Monitoring /Annual Emissions Report Form: Fuel Consumption RECEIVED DEC 1 8 2009 •�� ✓' 95y s ty ' +i LINDA LINGLE ` CHIYOME L FUKINO, M.D. GOVERNOR OF HAWAII .1 g1 j1 EA DIRECTOR OF HEALTH STATE OF HAWAII DEPARTMENT OF HEALTH In reply, please refer to: P.O. Box 3378 File: HONOLULU, HAWAII 96801 -3378 December 15, 2009 CERTIFIED MAIL 09 -1073E CAB RETURN RECEIPT REQUESTED File No. 0008 -09 (7009 0960 0000 3852 6131) Mr. Michael L. Kaleikini Plant Manager Puna Geothermal Venture P.O. Box 30 Pahoa, Hawaii 96778 Dear Mr. Kaleikini: Subject: Noncovered Source Permit (NSP) No. 0008 -02 -N Application for Renewal No. 0008 -09 Puna Geothermal Venture 41 MW (Nominal) Geothermal Power Plant, Wellfield, and Geothermal Exploratory/Developmental Wells Located at 14 -3860 Kapoho - Pahoa Road, Pahoa, HI 96778 Date of Expiration: December 14, 2014 The subject Noncovered Source Permit is issued in accordance with--Hawaii Administrative Rules, Title 11, Chapter 60.1. The issuance of this permit is based on the plans, specifications, and information that you submitted as part of your renewal application dated September 18, 2009. This permit shall supersede Noncovered Source Permit (NSP) No. 0008 -02 -N issued on December 27, 2004 and amended on April 22, 2005 and August 17, 2006 in its entirety. A receipt for the application filing fee of $100.00 is enclosed. The Noncovered Source Permit is issued subject to the conditions /requirements set forth in the following Attachments: Attachment I: Attachment IIA: Attachment IIB: Attachment III: Attachment IV: Standard Conditions Special Conditions: Power Plant Special Conditions: Wellfield and Geothermal Exploratory/Developmental Wells Annual Fee Requirements Annual Emissions Reporting Requirements The following forms are enclosed for your use and submittal as required: Annual Fee Form Monitoring Report Form: Operating Hours Monitoring /Annual Emissions Report Form: Fuel Consumption A Mr. Michael L. Kaleikini December 15, 2009 Page 2 This permit, (a) shall not in any manner affect the title of the premises upon which the equipment is to be located, (b) does not release the permittee from any liability for any loss due to personal injury or property damage caused by, resulting from or arising out of the design, installation, maintenance, or operation of the equipment, and (c) in no manner implies or suggests that the Department of Health, or its officers, agents, or employees, assumes any liability, directly or indirectly, for any loss due to personal injury or property damage caused by, resulting from or arising out of the design, installation, maintenance, or operation of the equipment. Sincerely, THOMAS E. ARIZUMI, P.E., CHIEF Environmental Management Division DL:smk Enclosures c: Ed Yamamoto, EHS -Hilo CAB Monitoring Section • C � 1. This permit, or a copy thereof, shall be maintained at or near the source and shall be made available for inspection upon request. The permit shall not be willfully defaced, altered, forged, counterfeited, or falsified. 2. This permit is not transferable whether by operation of law or otherwise, from person to person, from place to place, or from one piece of equipment to another without the approval of the Department of Health, except as provided in HAR, Section 11- 60.1 -69. 3. A request for transfer from person to person shall be made on forms furnished by the Department of Health. 4. In the event of any changes in control or ownership of the facilities to be constructed or modified, this permit shall be binding on all subsequent owners and operators. The permittee shall notify the succeeding owner and operator of the existence of this permit and its conditions by letter. 5. The facility covered by this permit shall be constructed and operated in accordance with the application, and any information submitted as part of the application, for the Noncovered Source Perm_ it. There shall be no deviation unless additional or revised plans are submitted to and-approved by the Departmentof Health. -- -- 6. This permit (a) does not release the permittee from compliance with other applicable statutes of the State of Hawaii, or with applicable local laws, regulations, or ordinances, and (b) shall not constitute, nor be construed to be an approval of the design of the noncovered source. 7. The permittee shall comply with all the terms and conditions of this permit. Any permit noncompliance constitutes a violation of HAR, Chapter 11 -60.1 and is grounds for enforcement action; for permit termination, suspension, reopening, or amendment; or for denial of a permit renewal application. 8. If any term or condition of this permit becomes invalid as a result of a challenge to a portion of this permit, the other terms and conditions of this permit shall not be affected and shall remain valid. 9. The permittee shall not use as a defense in an enforcement action that it would have been necessary to halt or reduce the permitted activity to maintain compliance with the terms and conditions of this permit. f 1 NSP No. 0008-02-N AttachmentWl Page 2 of 4 Issuance Date: December 15, ;2009 ,,Expiration: Date: DecemberA4, 2014'` 10. This permit may be terminated, suspended, reopened, or amended for cause pursuant to HAR, Sections 11- 60.1 -10 and 11- 60.1 -72, and HRS, Chapter 34213 -27, after affording the permittee an opportunity for a hearing in accordance with HRS, Chapter 91. 11. The filing of a request by the permittee for the termination, suspension, reopening, or amendment of this permit, or of a notification of planned changes or anticipated noncompliance does not stay any permit condition. 12. This permit does not convey any property rights of any sort, or any exclusive privilege. 13. The permittee shall notify the Department of Health in writing of the following dates: a. The anticipated date of initial start-up for each emission unit of a new source or modification not less than thirty (30) days or more than sixty (60) days prior to such date; b. The actual date of construction commencement within fifteen (15) days after such date; and c. The actual date of start-up within fifteen (15) days after such date. 14. The permittee shall furnish, in a timely manner, any information or records requested in writing by the Department of Health to determine whether cause exists for terminating, suspending, reopening, or amending this permit, or to determine compliance with this permit. Upon request, the permittee shall also furnish to the Department of Health copies of records required to be kept by the permittee. For information claimed to be confidential, the permittee shall furnish such records to the Department of Health =with a= claim -of - confidentiality. 15. The permittee shall notify the Department of Health in writing, of the intent to shut down air pollution control equipment for necessary scheduled maintenance at least twenty -four (24) hours prior to the planned shutdown. The submittal of this notice shall not be a defense to an enforcement action. The notice shall include the following: a. Identification of the specific equipment to be taken out of service, as well as its location and permit number; b. The expected length of time that the air pollution control equipment will be out of service; c. The nature and quantity of emissions of air pollutants likely to be emitted during the shutdown period; d. Measures such as the use of off -shift labor and equipment that will be taken to minimize the length of the shutdown period; and e. The reasons why it would be impossible or impractical to shut down the source operation during the maintenance period. 16. In the event any emission unit, air pollution control equipment, or related equipment malfunctions or breaks down in such a manner as to cause the emission of air pollutants in violation of Chapter 11 -60.1 or this permit, the permittee shall immediately notify the NSP No. 0008 -02 -N Attachment 'I "Page 3 of 4 Issuance Date: December 15, 2009 Ex iration Date: December 14 2014 Department of Health of the malfunction or breakdown, unless the protection of personnel or public health or safety demands immediate attention to the malfunction or breakdown and makes such notification infeasible. In the latter case, the notice shall be provided as soon as practicable. Within five (5) working days of this initial notification, the permittee shall also submit, in writing, the following information: a. Identification of each affected emission point and each emission limit exceeded; b. Magnitude of the excess emissions; c. Time and duration of the excess emissions; d. Identity of the process or control equipment causing the excess emissions; e. Cause and nature of the excess emissions; f. Description of the steps taken to remedy the situation, prevent a recurrence, limit the excessive emissions, and assure that the breakdown does not interfere with the attainment and maintenance of the National Ambient Air Quality Standards and state ambient air quality standards; g. Documentation that the equipment or process was at all times maintained and operated in a manner consistent with good practice for minimizing emissions; and h. A statement that the excess emissions are not part of a recurring pattern indicative of inadequate design, operation, or maintenance. The submittal of these notices shall not be a defense to an enforcement action. 17. The permittee may request confidential treatment of any records in accordance with HAR, Section 11- 60.1 -14. 18. This permit shall become invalid with respect to the authorized construction if construction is not commenced as follows: a. Construction shall be commenced within twelve (12) months after the permit takes effect, shall not be discontinued for a period of twelve (12) months or more, and shall be completed within a reasonable time. b. For phased construction projects, each phase shall commence construction within twelve (12) months of the projected and approved commencement dates in the permit. This provision shall be applicable only if the projected and approved commencement dates of each construction phase are defined in Attachment ll, Special Conditions of this permit. 19. The Department of Health may extend the time periods specified in Standard Condition No. 18 upon a satisfactory showing that an extension is justified. Requests for an extension shall be submitted in writing to the Department of Health. 20. The permittee shall submit fees in accordance with HAR, Subchapter 6 of Chapter 11 -60.1. 21. All certifications shall be in accordance with HAR, Section 11- 60.1 -4. NSP No. 0008 -02 -N Attachment 1 Page, 4 of 4 Issuance Date: December 15,, 2009; Expiration Date: December 14, 2014 22. The permittee shall allow the Director of Health, the Regional Administrator for the U.S. EPA and /or an authorized representative, upon presentation of credentials or other documents required by law: a. To enter the premises where a source is located or emission - related activity is conducted, or where records must be kept under the conditions of this permit and inspect at reasonable times all facilities, equipment, including monitoring and air pollution control equipment, practices, operations, or records covered under the terms and conditions of this permit and request copies of records or copy records required by this permit; and b. To sample or monitor at reasonable times substances or parameters to assure compliance with this permit or applicable requirements of HAR, Chapter 11 -60.1. 23. Within thirty (30) days of the permanent discontinuance of the construction, modification, relocation, or operation of the facility covered by this permit, the discontinuance shall be reported in writing to the Department of Health by a responsible official of the facility. 24. Application for permit renewal shall be submitted a minimum of sixty (60) days prior to the permit expiration on forms furnished by the Department of Health. 25. Any document (including reports) required to be submitted by this permit shall be certified as being true, accurate and complete by a responsible official in accordance with HAR, Sections 11- 60.1 -1 and 11- 60.1 -4, and shall be mailed to the following address: Clean Air Branch Environmental Management Division Hawaii Department of Health 919 Ala Moana Boulevard, Room 203 Honolulu, HI 96814 26. To determine compliance with submittal deadlines for time - sensitive documents, the postmark date of the document shall be used. If the document was hand - delivered, the date received ("stamped") at the Clean Air Branch shall be used to determine the submittal date. POWER PLAN FRED SOURCE PERI 2009 ExE Section A. Equipment Description. 1. A 41 MW (Nominal) Geothermal Power Plant including the following equipment and associated appurtenances: a. Ten (10) integrated back pressure steam turbine and air cooled binary cycle turbine /generator modules. Ormat Energy Converter (OEC) or equivalent; b. Noncondensible gas (NCG) compressor units; C. Vapor Recovery Unit (VRU); d. Sulfa -Treat System (two abatement reactor vessels); e. Emergency Steam Release Facility (ESRF) I. Rock Muffler(s) ii. Sodium Hydroxide (NaOH) or equivalent chemical storage tank(s); f. Portable H2S Abatement System; g. Two (2) Integrated Two Level Units (ITLU); and h. Vapor Recovery Maintenance Unit (VRMU). 2. The permittee shall permanently attach an_ identification tag or nameplate--on each_ piece of equipment which identifies the model number, serial number or I.D. number and manufacturer. The identification tag or name plate shall be attached to the equipment in a conspicuous position. Section B. Emission and Operational Limitations, and /or Standards. 1. The permit conditions prescribed herein may at any time be revised by the Department of Health to conform to any Federal or State promulgated air quality rules on geothermal facilities. 2. Fugitive pentane emissions from the turbine /generator modules shall not exceed 10,000 ppm from any seal, flange, valve or any other fugitive emission point. The permittee shall take immediate corrective actions upon identifying any pentane emissions in excess of 10,000 ppm when measured at the component interface. 3. The total pentane emissions from the facility shall not exceed 300 pounds per day calculated as a quarterly average. Pentane emissions are from fugitive sources and the vapor recovery unit (VRU) and /or the vapor recovery maintenance unit (VRMU). 4. No major maintenance or overhaul resulting in the purging to the atmosphere of the turbine /generator modules shall be allowed without the operation of a vapor recovery NSP No. 0008 -02 -N Attachment 11A Page 2 of 7 Issuance Date: December 15,;2009 Expiration Date: December' 14 2014 unit (VRU) and /or the vapor recovery maintenance unit (VRMU) with a minimum recovery efficiency of 95.0 percent. During normal power plant operations, all purging of noncondensible gases to the atmosphere or the release of pentane from the turbine /generator modules to the atmosphere shall be directed through the vapor recovery unit (VRU) and /or the vapor recovery maintenance unit (VRMU). The vapor recovery unit and vapor recovery maintenance unit (VRMU) shall be maintained in accordance with the manufacturer's operational specifications (i.e., temperature, pressure, etc.). 5. The emergency steam release facility (ESRF) shall be maintained and be fully operational. The rock muffler(s) in service shall be capable of handling 100 percent of the total actual power plant steam flow. 6. The emergency steam release facility (ESRF) shall only be utilized under one or more of the following conditions: a. Failure of the electrical transmission line(s) out of the power plant or some incident that tripped all the steam turbine/generator modules; b. Complete upset of the geothermal fluid injection system; C. Pressure in the steam lines exceed safety design set points; d. Any upset situation which would otherwise result in a release of unabated steam to the atmosphere; e. Testing of the emergency steam release facility (ESRF); or f. Maintenance performed on steam release valve NV4204. 7. The emergency steam release facility (ESRF) shall be equipped and maintained at all times with a minimum of 3000 gallons of sodium hydroxide. The chemical abatement system shall operate automatically when steam is released through the rock muffler(s). A minimum sodium hydroxide treatment mole ratio of 4 to 1 (NaOH /H2S) shall be used. If the duration of the steam release is greater than 15 minutes, the permittee shall monitor the perimeter of the rock muffler(s) using portable hydrogen sulfide analyzers. Upon utilizing the emergency steam release facility (ESRF), the permittee shall take immediate action to the extent practical to reduce the steam flow and perform the necessary corrective actions. The steam flow rate shall be reduced, as a minimum, to 50 percent of full flow within four (4) hours after initiating the use of the emergency steam release facility (ESRF). 8. In the event of any operational upset, equipment failure or malfunction which may allow an increase in the emissions of hydrogen sulfide, particulate matter or pentane, the permittee shall apply appropriate measures to control and minimize any air emissions and take immediate steps to correct the condition. 9. The combined emissions of hydrogen sulfide from the geothermal power plant and associated wellfield, including periods of operational upsets, equipment failure or malfunctions shall not cause or contribute to an exceedance of the hydrogen sulfide NSP No. 0008-02-N Attachment IIA Page 3 of 7 Issuance Date: becember -15, 2009 _Expiration Date: December 14, 2014 ambient level of 10 ppb on a twenty- four -hour rolling average or 25 ppb on a one -hour average at or beyond the project boundary. Should any of the air quality monitoring stations indicate a hydrogen sulfide ambient concentration greater than 10 ppb on a twenty- four -hour rolling average or 25 ppb on a one -hour average, the permittee shall take immediate action terminating, within two (2) hours of the exceedance, all power plant activities not associated with normal power plant operations but contributing to hydrogen sulfide emissions. Following the reduction in power plant emissions, if the monitoring stations still indicate hydrogen sulfide ambient concentrations in excess of 10 ppb on a twenty- four -four rolling average or 25 ppb on a one -hour average, the permittee shall curtail the power plant operations, unless the permittee can conclusively show to the Department of Health that the power plant operations and emissions are not contributing any impact to the monitoring site. If the hydrogen sulfide ambient concentration is below 10 ppb on a twenty- four -hour rolling average and 25 ppb on a one -hour average after the power plant emissions have been reduced, the permittee shall maintain the emissions at this reduced level until such time the Department of Health is assured that the resumption of full activity shall not result in another exceedance of the hydrogen sulfide ambient level of 10 ppb on a twenty- four -hour rolling average or 25 ppb on a one -hour average. 10. During those periods of normal power plant and normal wellfield operations, the combined emissions of hydrogen sulfide from the geothermal power plant and associated wellfield shall not cause an increase in the hydrogen sulfide ambient concentration in excess of 5 ppb (above background) on a one -hour average at or beyond the project boundary as monitored at any of the air quality monitoring stations and so i enti -6 in t e monthly monifonng report As used in this contexf; =a power plant plant operation is a power plant which is operating without any pipeline cleanouts, upsets, equipment failure, malfunction or which is otherwise operating normally. A normal wellfield operation is a wellfield in which no well drilling, flow testing, or abated well cleanouts are occurring and where the completed well are not experiencing any equipment failure or malfunction and are either shut -in, being used as an injection well, or connected to a sound geothermal resource distribution system. 11. During periods of regularly scheduled maintenance, sodium hydroxide or an equivalent chemical shall be used to abate any hydrogen sulfide emissions. Chemicals equivalent to sodium hydroxide shall obtain prior written approval from the Department of Health before use. 12. The unabated cleanout of a pipeline utilizing the geothermal steam is prohibited. If the geothermal steam is used in the pipeline cleanout, the geothermal steam shall be directed through the hydrogen sulfide abatement equipment. The permittee shall utilize a cyclonic muffler or other equivalent device designed to minimize particulate and brine aerosol emissions, and direct venting into the vertical direction. In no case shall any abated pipeline cleanout coincide with any abated well cleanout, well drilling which opens new hole, or well flow testing operations or commence if the emergency steam release facility (ESRF) is being utilized by the power plant. If emergency steam releases from the power plant occur during any pipeline cleanout, the pipeline cleanout operations NSR No 0008 -02 -N Attachment][A ;Page 4 of 7 Issuance Date: December, 15, 2009 Expiration Date: December 14, 2014 shall be terminated as quickly as practical. Each pipeline cleanout shall not exceed 20 minutes in duration and shall occur only in the daytime. 13. In the event of an equipment malfunction or upset condition which results in a situation where the geothermal injection well(s) are not capable of handling the total geothermal resource being utilized by the power plant, the power plant production and associated geothermal resource being used shall be immediately reduced according to the handling of the injection well(s) or completely shut down. 14. The Sulfa -Treat System shall be operated continuously to abate fugitive H2S emissions from the steam turbines. The Sulfa -Treat System shall be maintained and operated in accordance with the manufacturer's operational specifications. Section C. Monitoring and Recordkeeping. Monitoring for fugitive pentane shall be conducted in accordance with Method 21 of 40 CFR Part 60, Appendix A, including monitoring at the component interface. The permittee shall perform monitoring on all fugitive pentane emission points, as a minimum, on a monthly basis. The permittee shall keep on file at the facility a monitoring plan showing the locations in the facility where fugitive pentane emissions are monitored. 2. Records shall be maintained on all incidents resulting in the release of pentane to the atmosphere, including -the purging of noncondensible gases from the turbine /generator modules, the maintenance and overhaul of the turbine /generator modules, vapor recovery unit (VRU) and vapor recovery maintenance unit (VRMU), equipment malfunctions, usage of the vapor recovery unit (VRU) and vapor recovery maintenance unit (VRMU) with hours of operation, and all fugitive emission measurements greater than 10,000 ppm and the corrective measures taken. In addition to estimating the amount of pentane emitted from each incident, records shall also include information on the date and quantity of pentane received from the supplier and the corresponding pentane tank level reading. The above records shall be recorded on a quarterly basis to calculate the average daily emissions. 3. The following data shall be recorded during periods in which the hydrogen sulfide abatement system is operating at the emergency steam release facility (ESRF): a. The operating times of the ESRF; b. The injection rate of sodium hydroxide; C. The quantity of sodium hydroxide remaining in the abatement equipment storage tanks; and d. The hydrogen sulfide readings from the portable H2S analyzers in accordance with Special Condition No. B.7 of Attachment IIA. NSP ,No. :0008 -02 =N Attachment IIA "Pager5 of 7 , Issuance Date: December y15- 2009 Ex iratlori 'DateY December 14, 2014` 4. The permittee shall operate and maintain a minimum of three (3) meteorological monitoring stations, three (3) ambient air quality monitoring stations for hydrogen sulfide and one (1) PM10 monitor. The PM10 monitor shall only be operated during drilling operations, flow testing, and well cleanouts. The permittee shall maintain a file of all measurements collected from and performed on the ambient air monitoring stations, including the monitoring system performance evaluations; calibration checks; and adjustments and maintenance performed on the system or devices. The measured data shall meet U.S. EPA capture requirements and quality assurance guidelines. As a minimum, a quality assurance check shall be conducted on each monitoring station every- other -day. The three (3) ambient air quality monitoring stations shall be equipped with emergency backup power in the event of power disruptions to the monitoring stations. The permittee shall also maintain a spare hydrogen sulfide analyzer for the ambient air quality monitoring stations. 5. At the discretion of the Department of Health, the permittee may at any time be required to install, operate, and maintain additional ambient air quality and meteorological monitoring stations, but only after due notice to the permittee on the reasons for the proposed change and providing the permittee an opportunity to respond within seven (7) working days. 6. The Department of Health may at any time with reasonable cause, request the permittee to measure and record the hydrogen sulfide and pentane emissions at any specified point source location in the power plant. 7. All records shall be true, accurate and maintained in a permanent form suitable for inspection, retained for a minimum of three (3) years following the date of such records, and made available to the Department of Health or their representatives upon request. Section D. Reporting and Notification Requirements. The ambient air quality monitoring stations shall be equipped with an alarm or acceptable equivalent system that is designed to page and notify the permittee or a government agency on a twenty -four hour basis of ambient hydrogen sulfide concentrations in excess of 10 ppb on a twenty -four hour average and 25 ppb on a one - hour average. The permittee shall immediately notify the Department of Health and the Hilo District Health Office of any exceedance above 10 ppb on a twenty -four hour rolling average and 25 ppb on a one -hour average. One (1) copy of the air quality monitoring and meteorological data files shall be submitted on an annual basis to the Department of Health. The data files shall be in ASCII format that can be utilized by a personal computer for ready extraction of data. NSF No: 0008 -02 -N Attachment 11A Page ,6 of 7 Issuance Date: December 15, 2009 Expiration Date: ,December 14 2014 The verified air quality monitoring and meteorological data shall be summarized and submitted monthly in writing to the Department of Health. The monthly data report shall also include a monthly summary with the following information: highest value, the date /time the highest value occurred, monthly average, data recovery ( %), number of exceedances, date the exceedance occurred, and the corrective actions taken. Additional information on the monitoring stations and on the data collected shall be submitted upon request by the Department of Health. Both the annual data file and monthly summary shall be submitted to the Department of Health within sixty (60) days following the end of each respective time period. The permittee shall provide computer access for the ambient air quality monitoring stations through telecommunication lines to the Department of Health. The computer access shall allow the downloading of the current and the previous 24 -hour raw hydrogen sulfide ambient air quality and meteorological data. 2. The permittee shall submit a written report to the Department of Health within five (5) working days of the occurrence of Special Condition No. B.9 of Attachment IIA. The report shall include the date, time and duration of the exceedance(s), the status of all project operations during the exceedance, the estimated project emissions and any other emission sources that may have contributed to the exceedance, and all corrective measures and actions taken to reduce project emissions to a minimum. Compliance with this notification provision shall not excuse or otherwise constitute a defense for any violation(s) of this permit, law, rule or order. 3. The permittee shall immediately notify the Department of Health of any operational upsets, equipment failure or malfunction which results in the emission of hydrogen sulfide, particulate matter or pentane in violation of HAIR Chapter 11 -60.1 or this permit. In addition, a written report shall be submitted to the Department of Health within five (5) working days of occurrence. The report shall include a description of the malfunctioning equipment or abnormal operation, the date of the initial failure, the estimated resultant emissions, time and duration of the event, and the methods utilized to restore normal operations. Compliance with this notification provision shall not excuse or otherwise constitute a defense for any violation(s) of this permit, law, rule or order which results from the operational upset, equipment failure or malfunction. 4. Prior to any abated pipeline cleanout utilizing geothermal steam, the Department of Health must be informed in writing, a minimum of two (2) working days prior to commencement and so concur. The public shall be notified a minimum of 24 -hr in advance by notices in the newspapers of general circulation in Hawaii County. In addition, the permittee shall make a reasonable effort to notify all residents living within 3,500 feet of the permittee's property boundary a minimum of 24 -hrs in advance of any abated pipeline cleanout utilizing geothermal steam. 5. The records and any supporting information required in Attachment IIA, Special Condition No. C.2, including any assumptions and calculations used to determine the amount of pentane emissions and descriptions of pentane transfers, shall be submitted NSP No. , 0008 -02 -N Attachment IlA Page 7 of 7 Issuance'DaW December 15, 2009 Expiration-Date: Dec6inber'14, 2014 to the Department of Health on a quarterly basis. These records shall be submitted to the Department of Health within thirty (30) days following the end of each quarter. 6. Notification and reporting pertaining to the following events shall be done in accordance with Attachment I, Standard Condition Nos. 13, 15, 16 and 23, respectively. a. Anticipated date of initial start -up, actual date of construction commencement, and actual date of start -up; b. Intent to shut down air pollution control equipment for necessary scheduled maintenance; C. Emissions of air pollutants in violation of HAR, Chapter 11 -60.1 or this permit, and d. Permanent discontinuance of construction, modification, relocation, or operation of the facility covered by this permit. 7. The permittee shall notify the Department of Health in the event the ESRF has operated more than 15 minutes in duration in accordance with Special Condition No. B.7 of Attachment IIA. Section E. Testing Requirements. 1. Prior to the commencement of any abated pipeline cleanout utilizing the geothermal steam, the permittee shall submit to, and receive the approval of, the Department of Health a sampling and testing protocol, identifying the analytical procedures and methodologies to be used and the constituents to be measured, which shall seek to physically and chemically characterize the particulate and aerosol emissions and corresponding ambient concentrations from these operations. Each collected sample shall be submitted to a qualified laboratory for analyses within five (5) working days after the sample is collected. The permittee shall submit a copy of the results of the analyses to the Department of Health within five (5) working days after receiving the results from the qualified laboratory. The Department of Health may at any time require the permittee to analyze for additional constituents or perform more frequent testing. Section F. Agency Notification. Any document (including reports) required to be submitted by this permit shall be done in accordance with Attachment I, Standard Condition No. 25. Section A. Equipment Description. 1. This permit encompasses the following equipment and related appurtenances: a. Pad A Wellfield: Production Wells KS -9 and KS -10, Injection Wells KS -1A, KS -11 and KS -13, and associated equipment; b. Pad E Wellfield: Production Wells KS-4, KS -5 and KS -6, Injection Well KS -3, and associated equipment; C. Fourteen (14) Geothermal Exploratory/Developmental Wells; d. Drilling rig no. 1 (Rig 51): i. Three (3) 877 hp diesel engine drives, Waukesha model L5792, serial nos. 363805, 363806, and 363807; and ii. Two (2) 435 hp diesel engine generators, Caterpillar model D353, serial nos. 46B09273 and 461309281; iii. One (1) 1205 hp diesel engine for Top Drive unit, Detroit Diesel serial no. T28091 UNIT568, engine no. 5362003945; e. Drilling rig no. -2 (Spencer Harris_Dril ling _Rig):___ _ I. Two (2) 300 hp diesel engine drives, Caterpillar model D334, serial nos. 9213-3036 and 9213-3841; and ii. One (1) 400 hp diesel engine for air compressor, Caterpillar model 3406- 8, serial no. 6T60750. f. Portable HZS Abatement System. 2. The permittee shall permanently attach an identification tag or nameplate on each piece of equipment which identifies the model number, serial number or I.D. number and manufacturer. The identification tag or name plate shall be attached to the equipment in a conspicuous position. Section B. Emission and Operational Limitations. and /or Standards. 1. The permit conditions prescribed herein may at any time be revised by the Department of Health to conform to any Federal or State promulgated air quality rules on geothermal facilities. 2. The construction of fourteen (14) geothermal exploratory/developmental wells are to be drilled in TMK: 1 -4 -01: 2, 1 -4 -01: 3, 1 -4 -01: 58 and 1 -4 -01: 19, Kilauea Lower East Rift Zone, Puna, Hawaii. NSP N9. 0008-02-N' - -- Attachment 1113 0. age�2 of 12 Issuance'Date: December 15, 2009 Expiration Date: 'December 14, 2014 3. This permit does not authorize any of the geothermal exploratory/developmental wells to be connected to and become part of a distribution system which supplies geothermal resource to a power plant or facility, or any well to be used as an injection well for the geothermal resource unless the permittee has obtained all other applicable federal, state or local operating permits. 4. No geothermal exploratory/developmental wells (i.e., wellhead cellar) shall be located within 600 feet of the property boundary. If any federal, state or county permit or order stipulates a distance greater than 600 feet in which no geothermal wells (i.e., wellhead cellars) can be located, the greater distance shall so apply. 5. The reworking of any geothermal well covered under this Noncovered Source Permit is prohibited, unless prior written approval is obtained from the Department of Health. "Reworking" is meant to include recompletion of a well; deepening or redrilling (side- tracking) of a well; or other repairs, maintenance or modifications below the casing head. Such activities commonly involve a drilling rig. If the reworking of any geothermal well is considered necessary, the permittee shall submit a written request to the Department of Health which shall include, as a minimum, a justification for the reworking, procedures and equipment involved, hydrogen sulfide abatement procedures and the estimated emissions. The approval for the reworking of any geothermal well does not relieve the permittee from compliance with all applicable conditions of this Noncovered Source Permit, including all provisions related to well drilling, flow testing and abated well cleanout. 6. Unless prior written approval is obtained from the Department of He— ith,-each geothermal well shall be shut -in or otherwise prevented from discharging to the atmosphere in accordance with appropriate standards of operation and maintenance and at no time be placed on continuous or standby bleed status at the wellhead or anywhere in the distribution pipeline upon completion of flow testing operations. If the release of any accumulated wellhead gas or any other geothermal fluid is considered necessary, the permittee must submit a written request to the Department of Health which shall include, as a minimum, a justification for the required release, estimated duration of the release, estimated amount of hydrogen sulfide emissions, and a description of the abatement system. The release of any accumulated wellhead gas or any other geothermal fluid shall be directed through a hydrogen sulfide abatement system prior to being discharged to the atmosphere. If a request to release any accumulated wellhead gas or any other geothermal fluid is approved by the Department of Health, the approval may be subject to further conditions. 7. Flaring of excess hydrogen sulfide gas from the completed wells is prohibited without the approval of the Department of Health. If flaring of the excess gas is considered necessary, the permittee must submit a written request to the Department of Health which shall include as a minimum the proposed date, time and approximate duration of the flaring episode, the current and expected well head pressure, the estimated hydrogen sulfide concentration in the well gas, the estimated emission rates for hydrogen sulfide and sulfur dioxide, an air quality impact analysis for sulfur dioxide, the NSP No. 0008 -02 -N Attachment llB Page 3 of 12 Issuance Date: December, 15,;2009' Expiration Date::December 14, 2014 probable cause of excess gas buildup, and an assessment of any abatement alternatives. If a request to flare excess gas is approved as necessary by the Department of Health, the approval may be subject to specified conditions. These conditions may include, but are not limited to, provisions requiring the permittee to install, operate, and maintain sulfur dioxide ambient monitors and to submit to the Department of Health after the flaring event a report on the times flaring actually occurred, the sulfur dioxide emissions determined through either direct or indirect measurements, and any problems encountered during the flaring process. 8. Hydrogen sulfide abatement equipment with a minimum of 3,000 gallons of sodium hydroxide or an equivalent chemical shall be on the property prior to the initiation of drilling, abated well cleanout and flow testing operations. Chemical storage tanks shall be maintained with sodium hydroxide or an equivalent chemical at all times with no less than a three -day operating supply. Chemicals equivalent to sodium hydroxide shall obtain prior written approval from the Department of Health before use. 9. During well drilling, flow testing and abated well cleanout operations, the permittee shall utilize hydrogen sulfide abatement equipment. The hydrogen sulfide abatement equipment shall consist of a cyclonic muffler or other equivalent device designed to minimize particulate and brine aerosol emissions, and direct venting into a vertical direction. A minimum sodium hydroxide treatment mole ratio of 4 to 1 (NaOH /H2S) will be used initially and the abatement efficiency monitored. The optimum mole ratios will be determined during the hydrogen sulfide abatement operations. A specific chemical treatment plan shall be submitted to the Department of Health prior to the commencement of drilling, flow testing and abated well cleanout operations. A copy of the plan shall be maintained at the site at all times and supervisory personnel shall be aware of its provisions at all times. 10. During well drilling operations, the release of any geothermal steam shall be diverted to the hydrogen sulfide abatement equipment or action immediately taken to shut -in the well. In no case shall the cumulative steam releases from the well drilling operations result in total abated hydrogen sulfide emissions of five (5.0) pounds per hour or more. If the cumulative steam releases from the well drilling operations result in total abated hydrogen sulfide emissions of five (5.0) pounds per hour or more, the permittee shall take immediate action to shut -in the wells. 11. During flow testing and abated well cleanout operations, the permittee shall utilize hydrogen sulfide abatement. If the abated hydrogen sulfide emission rate increases to five (5.0) pounds per hour or more, or if any steam is released through the power plant emergency steam release facility, the permittee shall cease operations and shut -in the well. The problem shall be corrected before testing or cleanout operations can continue. NSP9 No: 0008 -02 -N Attachment I Page 4 of 12 Issuance Date: December 15, 2009 Expiration' Date: "December 14, 2014 During periods of flow testing, abated well cleanouts, and well equipment failure or malfunction which result in hydrogen sulfide ambient air concentrations exceeding the specified limits in Attachment IIB, Special Condition No. B.15, the permittee shall apply appropriate measures to control and minimize any air emissions and take immediate steps to correct the condition. If the well equipment in question cannot be repaired within twenty-four (24) hours of the occurrence, the permittee shall cease operations and shut -in the well in accordance with Attachment IIB, Special Condition No. B.15. 12. The unabated venting of a geothermal well is prohibited. During abated well cleanout and flow testing operations, the geothermal resource shall be directed through the hydrogen sulfide abatement equipment. Flow testing and abated well cleanout operations shall be conducted only during the daytime and performed for no more than a total of four (4) hours. In no case shall any abated well cleanout coincide with any pipeline cleanouts, well drilling which opens new holes, or well flow testing operations, or commence if the power plant emergency steam release facility is being utilized. If emergency steam releases from the power plant occur during any abated well cleanout, the well cleanout operations shall be terminated as quickly as practical. 13. The permittee shall install a control system acceptable to the Department of Health for the throttling of steam flow and the soft shut -in on each development well prior to the well being connected to a resource distribution system. 14. To prevent well blowouts, the permittee shall employ good drilling practices -with proper- blowout prevention equipment and experienced personnel in the drilling of the exploratory/developmental wells. Drilling supervisors shall be certified in blowout prevention at a minimum of once every two years by a certified trainer. 15. The combined emissions of hydrogen sulfide from the geothermal power plant and associated wellfield, including periods of operational upsets, equipment failure or malfunctions shall not cause or contribute to an exceedance of the hydrogen sulfide ambient level of 10 ppb on a twenty- four -hour rolling average or 25 ppb on a one -hour average at or beyond the project boundary. Should any of the air quality monitoring stations indicate a hydrogen sulfide ambient air concentration greater than 10 ppb on a twenty- four -hour rolling average or 25 ppb on a one -hour average, the permittee shall cease all well drilling, flow testing, and abated well cleanout operations, and shall shut -in those wells experiencing equipment failure or malfunction which result in emissions of hydrogen sulfide. The affected wellfield construction activities shall be allowed to proceed only after the permittee has satisfactorily demonstrated to the Department of Health that the contributions from the well drilling, well flow testing, abated well cleanout operations or well equipment repair will not result in or contribute to the exceedance of the hydrogen sulfide ambient concentration of 10 ppb on a twenty- four -hour rolling average or 25 ppb on a one -hour average. NSP' No: 0008 -02 -N Attachment 11113 Page 5 of 12 Issuance -Date: December 15, 2009 ,Expiration Date: December 14, 2014 16. During those periods of normal power plant and normal wellfield operations, the combined emissions of hydrogen sulfide from the geothermal power plant and associated wellfield shall not cause an increase in the hydrogen sulfide ambient concentration in excess of 5 ppb (above background) on a one -hour average at or beyond the project boundary as monitored at any of the air quality monitoring stations and so identified in the monthly monitoring report. As used in this context, a normal power plant operation is a power plant which is operating without any pipeline cleanouts, upsets, equipment failure, malfunction or which is otherwise operating normally. A normal wellfield operation is a wellfield in which no well drilling, flow testing, or abated well cleanout are occurring and where the completed wells are not experiencing any equipment failure or malfunction and are either shut -in, being used as an injection well, or connected to a sound geothermal resource distribution system. 17. The permittee shall have wind socks placed at two opposite edges of the drill site and on the drill floor. 18. The permittee shall maintain a 24 -hour telephone service to accept calls concerning this permit. This telephone number must be operational prior to commencement of drilling operations. 19. The three (3) 877 hp, two (2) 435 hp and one (1) 1205 hp diesel engines for drilling rig no. 1, and the two (2) 300 hp and one (1) 400 hp diesel engines for drilling rig no. 2 shall be fired only on fuel no. 2 with a maximum sulfur content not to exceed 0.5 percent by weight. 20. The total combined fuel usage of all nine (9) diesel engines shall not exceed 250,000 gallons in any rolling twelve (12) month period. 21. The total hours of operation for each of the two (2) 300 hp and one (1) 400 hp diesel engines for drilling rig no. 2 shall not exceed 720 hours in any rolling twelve (12) month period. 22. For any six (6) minute averaging period, the exhaust from each of the diesel engines shall not exhibit visible emissions of twenty (20) percent opacity or greater, except as follows: during start-up, shutdown, or equipment breakdown, each of the diesel engines may exhibit visible emissions greater than twenty (20) percent opacity but not exceeding sixty (60) percent opacity for a period aggregating not more than six (6) minutes in any sixty (60) minutes. Section C. Monitoring and Recordkeeping. The permittee shall operate and maintain a minimum of three (3) meteorological monitoring stations, three (3) ambient air quality monitoring stations for hydrogen sulfide and one (1) PM,o monitor. The monitoring stations required in Attachment IIA, Special Condition No. CA shall be used towards fulfilling this requirement. NSP No. , 0008 -02 -N 'Attachment, 111113 Page °6 of.12 issuance'Date: December 15, 2009 Ex iration. Date: December 14, 2014 2. At the discretion of the Department of Health, the permittee may at any time be required to install, operate, and maintain additional ambient air quality and meteorological monitoring stations, but only after due notice to the permittee on the reasons for the proposed change and providing the permittee an opportunity to respond within seven (7) working days. 3. The permittee shall monitor the hydrogen sulfide concentration and emission rate during drilling, flow testing and abated well cleanout operations. 4. During well drilling operations, records of each steam release associated with upsets, equipment failures or malfunctions shall be maintained and include as a minimum, the date, time and duration of steam release, the resultant hydrogen sulfide emissions, chemical injection rate, steam flow rate, and any corrective measures taken. 5. The permittee shall operate and maintain a non - resetting fuel metering system for the permanent recording of the total gallons of fuel consumed by the nine (9) diesel engines associated with the drilling rigs for the purpose of the fuel limitation specified in Attachment 1113, Special Condition No. B.20. The permittee shall maintain records on a monthly and rolling twelve (12) month basis on the total amount (gallons) of fuel oil consumed by the nine (9) diesel engines. The installation of any new non - resetting meters or the replacement of any existing non - resetting meters shall be designed to accommodate a minimum of five (5) years of equipment operation, considering any operational limitations, before the meter returns to a zero reading. 6. The permittee shall operate and maintain non - resetting hour meter(s) for the permanent recording of the total hours of operation for each of the two (2) 300 hp and one (1) 400 hp diesel engines for drilling rig no. 2 for the purpose of the hour limitation specified in Attachment 1113, Special Condition No. B.21. The permittee shall maintain records on the total hours of operation for each of the three (3) diesel engines on a monthly and rolling twelve (12) month basis. The installation of any new non - resetting meters or the replacement of any existing non - resetting meters shall be designed to accommodate a minimum of five (5) years of equipment operation, considering any operational limitations, before the meter returns to a zero reading. 7. The permittee shall keep invoices of fuel deliveries for the diesel engines identifying the delivery dates and the type and amount of fuel received. Include with the records copies of the supplier's certificate of analysis showing the sulfur content of the fuel delivered. 8. The permittee shall keep a log identifying the diesel engines used for drilling a well and for the removal of fill or other materials from wells. 9. All records shall be true, accurate and maintained in a permanent form suitable for inspection, retained for a minimum of three (3) years following the date of such records, and made available to the Department of Health or their representatives upon request. NSP ;No. 0008 =02 =N Attachment 1 o Page�Tof 12' Issuance Date: December 15,,2009. Expiration Date: December 14,:201A Section D. Reporting and Notification Requirements. 1. A written plan must be submitted to and approval obtained from the Department of Health at least thirty (30) calendar days prior to the commencement of construction of each well. The Department of Health shall act on the approval in a timely manner provided all required and requested information have been submitted. Each plan shall include a drawing identifying the well location, the property boundary, access roads approaching and traversing the property, the location of the nearest residence, the locations of the ambient air quality monitoring stations, and hydrogen sulfide abatement procedures. The status of all previous constructed wells shall be provided including a clear description of the measures taken to shut -in the well. The Department of Health may at any time request for additional information. 2. The permittee shall notify the Department of Health in writing at least two (2) working days prior to the commencement, and within two (2) working days after the completion of the drilling, abated well cleanout, and flow testing operations, for each geothermal well. The Department of Health must concur before the permittee can commence operations. 3. Prior to any drilling, flow testing or abated well cleanout operation, the public shall be notified a minimum of 24 hours in advance by notices in the newspapers of general circulation in Hawaii County. In addition, the permittee shall make a reasonable effort to notify all residents living within 3,500 feet of the permittee's property boundary a minimum of 24 hours in advance of each drilling, flow testing or abated well cleanout operation. - - - - 4. In the event of a well blowout, the permittee shall immediately proceed with measures to kill or gain control of the well and notify the Department of Health. The permittee shall submit to the Department of Health a written report within five (5) working days of the blowout. The report shall include, as a minimum, the probable cause of the blowout, the actions that have or will be taken, the estimated time before the well was controlled or is expected to be controlled, an analysis of the air quality impact from any unabated emissions, and a monitoring plan to determine the actual air quality impact resulting from the blowout. A status report shall be submitted to the Department of Health on a daily basis until such time the control of the well is established. 5. The permittee shall orally notify the Department of Health when an abnormality or a situation occurs that could result in an exceedance of the state ambient air quality standards, or has resulted in a hydrogen sulfide measurement of 25 ppb or more (one - hour average) at any of the ambient air quality monitoring stations, or if not properly resolved, may threaten the health or safety of persons in the vicinity of the project site. Notification shall be provided immediately, unless the protection of personnel or public health or safety demands immediate attention to the abnormality or situation and makes such notification infeasible. In the latter case, the oral notice shall be provided as soon as practicable. 7- N"SP 'M - 0008 -02 -N- Attachment IIB Page 8 of 12 Assuance Date: December 15, 2009 Ex iration Date: December 14,-,2014 6. The Department of Health shall be immediately notified in accordance with Attachment IIB, Special Condition No. B.10, if the cumulative steam releases from either or both well drilling operations result in total abated hydrogen sulfide emissions of five (5.0) pounds per hour or more. 7. The Department of Health shall be immediately notified in accordance with Attachment IIB, Special Condition No. B.11, if during flow testing or abated well cleanout operations, the abated hydrogen sulfide emission rate increases to five (5.0) pounds per hour or more, or if any steam is released through the power plant emergency steam release facility (ESRF). During periods of flow testing, abated well cleanouts, and well equipment failure or malfunction which result in hydrogen sulfide ambient air concentrations exceeding the specified limits in Attachment IIB, Special Condition No. B.15, the Department of Health shall be immediately notified. Within five (5) working days of the occurrence, a report shall be submitted to the Department of Health. The report shall include a description of the equipment failure or malfunction, the date of the initial failure, the estimated resultant emissions, time and duration of the event, and the repairs conducted to restore normal operations. Compliance with this notification provision shall not excuse or otherwise constitute a defense for any violation(s) of this permit, law, rule, or order which results from the well equipment failure or malfunction. B. The daily records specified in-Attachment I113; Special Conditions Nos. -E 1 =b:i., ii:,- and - iii: -- shall be reported daily to the Department of Health by telephone or facsimile no later than noon of the following work day. The Department of Health may at any time request additional data or revise the frequency of this daily reporting requirement. 9. Notification and reporting pertaining to the following events shall be done in accordance with Attachment I, Standard Condition Nos. 15, 16 and 23, respectively: a. Intent to shut down air pollution control equipment for necessary scheduled maintenance; b. Emissions of air pollutants in violation of HAR, Chapter 11 -60.1 or this permit; and C. Permanent discontinuance of construction, modification, relocation, or operation of the facility covered by this permit. 10. The permittee shall submit the following written report to the Department of Health. The report shall be submitted within thirty (30) days after the completion of each well and include the following: a. The monthly and rolling twelve (12) month fuel consumption records for the total combined fuel usage of all nine (9) diesel engines of the drilling rigs; and NSP No. 0008 -02 -N Attachment I)IB ;Page 9 of 12 Issuance Date: December 15;_2009 Expiration: Date: December 14, 2014 b. The maximum sulfur content (percent by weight) of the fuel oil no. 2 fired in the diesel engines of the drilling rigs. C. The total hours of operation for each of the two (2) 300 hp and one (1) 400 hp diesel engines of drilling rig no. 2. The enclosed Monitoring/Annual Emissions Report Form - Fuel Consumption shall be used for reporting Special Condition Nos. 10.a and 10.b and the Monitoring Report Form - Operating Hours shall be used for reporting Special Condition No. 10.c. 11. Annual emission reports for the diesel engines shall be submitted to the Department of Health on the Monitoring/Annual Emissions Report Form - Fuel Consumption, in accordance with Attachment IV, Annual Emissions Reporting Requirements. Upon the written request of the permittee, the deadline for the reporting of annual emissions may be extended, if the Department of Health determines that reasonable justification exists for the extension. Section E. Testing Requirements. The permittee shall conduct wet chemical tests for the determination of the hydrogen sulfide concentrations during periods of drilling, flow testing and abated well cleanout operations where geothermal steam is directed to the hydrogen sulfide abatement equipment. a. These tests shall be conducted during the following periods: L At least once every six (6) hours per 24 -hr period during periods of drilling operations. Additional wet chemical tests shall be required if previous results indicate a +10 percent fluctuation in the hydrogen sulfide concentration; and ii. At least twice during the four hours per day for abated well cleanouts and flow testing operations. b. The following data shall be recorded at these times: L The hydrogen sulfide concentration (ppm) upstream from the chemical injection system; ii. The injection rate of sodium hydroxide; iii. The hydrogen sulfide concentration (ppm) downstream, after chemical injection, calculated hydrogen sulfide emission rate (lb /hr) and calculated hydrogen sulfide abatement efficiency (percent); and iv. Daily, the quantity of sodium hydroxide remaining in the abatement equipment storage tanks. NSP No. 0008 -02 -N Attachment 11B Pagel0 of 12 Issuance Date: December 10', 2009 Expiration Date: December 14, 2014 The Department of Health may require additional data to be recorded when significant changes in the resource occurs and when changes are made in the injection rates of sodium hydroxide. The records shall be kept at the well location at all times during the drilling, flow testing and abated well cleanout operations. 2. The permittee shall sample and test the liquid and vapor phases of each geothermal resource well to determine the concentrations of the following constituents in the steam condensate, brine and noncondensible gases: Steam Condensate Benzene Ammonium (Total) Arsenic Lead Cadmium Bicarbonate and Carbonate Sulfates Chlorides Nitrates Boron (Total) Hydrogen Sulfide Brine Benzene Ammonium (Total) Arsenic Lead Cadmium Bicarbonate and Carbonate Sulfates Chlorides Nitrates Boron (Total) Hydrogen Sulfide Noncondensible Gases Benzene Hydrogen Sulfide Ammonia Mercury Vapor Methane Non - Methane Hydrocarbons Vinyl Chloride Fluorides (Total) Mercury (Total) pH Total Dissolved Solids Total Suspended Solids Beryllium Asbestos Vinyl Chloride Radon Radionuclides (gross Alpha and Beta) Fluorides (Total) Mercury (Total) pH Total Dissolved Solids Total Suspended Solids Beryllium Asbestos Vinyl Chloride Radon Radionuclides (gross Alpha and Beta) Carbon Dioxide Arsenic Beryllium Asbestos Radon Radionuclides (gross Alpha and Beta) NSP No. 0008 -02 -N Attachment`IIB Page 11 of 12 =Issuance Date :, December 15, 2009 Expiration Date: December 14, 2014 The sampling and testing of the resource shall be performed once upon experiencing the first steam release, and at least once during abated well cleanout and flow testing operations. During normal operation of each well, the sampling and testing of the resource shall be performed on an annual basis. During the testing of the noncondensible gases, if the hydrogen sulfide concentrations deviates more than +10 percent of the initial well test measurement, the permittee shall repeat the sampling and testing of the resource for the steam condensate, brine and noncondensible gases within the next six (6) months. The permittee shall be required to perform a retest only once after performing an annual resource test. All sampling shall be submitted to a qualified laboratory for analyses within five (5) working days after obtaining the sample. The permittee shall submit a copy of the results of the analyses to the Department of Health within five (5) working days after receiving the results from the qualified laboratory. The Department of Health may at any time require the permittee to analyze for additional constituents or perform more frequent testing. The Department of Health may waive the annual resource testing for a specific constituent upon prior written request of the permittee. Such a request would need to be justified on the grounds that previous testing had shown that constituent to be below detection limits. The annual resource testing may not be waived for more than two consecutive years. 3. At least thirty (30) calendar days prior to performing tests and analyses of the geothermal resource well as required in Attachment 1113, Special Condition No. E.2, the permittee shall submit a written test plan to the Department of Health that describes the test methods, analytical procedures, the constituents to be measured and other parameters that may affect test results and analyses. Such a plan shall conform to U.S. EPA guidelines including quality assurance procedures. A test plan that does not have the approval of the Department of Health may be grounds to invalidate any test and require a retest. 4. Prior to the commencement of any geothermal well drilling, abated well cleanout, or flow testing operations which will result in the release of geothermal steam to the atmosphere, the permittee shall submit to, and receive the approval of, the Department of Health a sampling and testing protocol, identifying the analytical procedures and methodologies to be used and the constituents to be measured, which shall seek to physically and chemically characterize the particulate and aerosol emissions and corresponding ambient concentration from these operations. Each collected sample shall be submitted to a qualified laboratory for analyses within five (5) working days after the sample is collected. The permittee shall submit a copy of the results of the analyses within five (5) working days after receiving the results from the qualified laboratory. The Department of Health may at any time require the permittee to analyze for additional constituents or perform more frequent testing. NSP No. 0008 -02 -N Attachment,1113 Page 12 of 12 Issuance Date: December 15, 2009 Ex iration `Date: December 14, 2014 Section F. Agency Notification. Any document (including reports) required to be submitted by this permit shall be done in accordance with Attachment I, Standard Condition No. 25. ATTACHMENT III: ANNUAL FEE REQUIREMENTS NONCOVERED'SOURCE PERMIT NO. 0008 -02 -N Issuance Date: December - 15.2009, Expiration Date: December 14: 2014'` The following requirements for the submittal of annuai fees° are established pursuant to Hawaii 1. Annual fees shall be paid in full: a. Within sixty (60) days after the end of each calendar year; and b. Within thirty (30) days after the permanent discontinuance of the noncovered source. 2. The permittee shall be assessed $500.00 annually for each valid noncovered source permit held during the prior calendar year, or $42.00 per month for any fraction of the year the noncovered source permit is valid. 3. If any part of the annual fee is not paid within thirty days after the due date, a late payment penalty of five percent of the amount due shall at once accrue and be added thereto. Thereafter, on the first day of each calendar month during which any part of the annual fee or any prior accrued late payment penalty remains unpaid, an additional late payment penalty of five percent of the then unpaid balance shall accrue and be added thereto. 4. The permittee shall complete and submit the attached Annual Fee Form with the required annual fee. Make copies for future use. 5. If any annual fee, including the late payment penalty required by HAR, Chapter 11 -60.1, is not paid in full within thirty days after the due date, the Department of Health may terminate or suspend any or all of the permittee's noncovered source permits, after affording the opportunity for a hearing in accordance with HRS, Chapters 91 and 342B. ATTACHMENT MIS IV: ANNUAL ESIONS REPORTING REQUIREMENTS NONCOVERED SOURCE- °'PERMIT'NO. 0008 -02 -N Issuance.Date: December 15:'2009 -= Expiration Date: December 14, 2014 In accordance with the Hawaii Administrative Rules, Title, 11 Chapter 60.1, A"r Pollution Control, the 1pirmittee shall re ortio the Department of Health'th6- nature and amounts of emissions. 1. Complete the attached form(s): Monitoring /Annual Emission Report Form - Fuel Consumption 2. The reporting period shall be from January 1 to December 31 of each year. All reports shall be submitted to the Department of Health within sixty (60) days after the end of each calendar year and shall be mailed to the following address: Clean Air Branch Environmental Management Division Hawaii Department of Health 919 Ala Moana Boulevard, Room 203 Honolulu, HI 96814 3. The permittee shall retain the information submitted, including all emissions calculations. These records shall be in a permanent form suitable for inspection, retained for a minimum of three (3) years, and made available to the Department of Health upon request. -4: Any information submitted -to the Department -of Health - without a request fog confidentiality - - shall be considered public record. 5. In accordance with HAR, Section 11- 60.1 -14, the permittee may request confidential treatment of specific information, including information concerning secret processes or methods of manufacturing, by submitting a written request to the Director and clearly identifying the specific information that is to be accorded confidential treatment. ANNUAL FEE FORM NONCOVERED`SOURCE PERMIT: NO. 0008-02-N, Issuance Date: December 15. 2009 Expiration; Date: December 14, 2014 (Make Copies for Future Use) For Calendar Year: 1. Company Name: 2. Facility Name (if different from the Company): 3. Mailing Address: City: State: Phone Number: 4. Location of Equipment: 5. Plant Site Manager /Other Contact: Title: Phone Number: Zip Code: Noncovered Source Date of Issuance If Permit Canceled Amount Due Permit Provide Date 0008 -02 -N Total Due: 6. Make check or money order payable to Clean Air Special Fund — NON. Indicate your permit number(s) on all remittance. 7. Mail payment and this form to: Clean Air Branch Environmental Management Division Hawaii Department of Health 919 Ala Moana Boulevard, Room 203 Honolulu, HI 96814 -! i I MONITi OF NONCOVERED'! ;EPORT FORM G °HOURS PERMIT NO. 0008 -02 -N Issuance Date: December'15, 2009 Expiration Date: December 14: 2014 In, accordance with the Hawaii Administrative Rules; Title 11, Chapter 60. 1, Air Pollution Control, (Make copies for future use) For Period: Date: Facility Name: Equipment Location: Equipment Description: Equipment Capacity /Rating (specify units): (Units such as Horsepower, kilowatt, tons /hour, etc.) Serial /ID No.: I certify that I have knowledge of the facts herein set forth, that the same are true, accurate, and complete to the best of my knowledge and belief, and that all information not Identified by me as confidential in nature shall be treated by the Department of Health as public record. Responsible Official (PRINT): TITLE: Responsible Official (Signature): 'MONTH— - DRILL ~ING -RIGzNO:<2-- - DRILLING - _G N0 2 -- ------NOTES OPERATING HOURS QPERATING.HOURS MONTHLY BASIS ROL "LINGy12- MONTH`BASIS HRS.. HRS January , March April May June July August September October November December MONITORING /ANNUAL EMISSIONS REPORT FORM' FUEL CONSUMPTION NONCOVERED "SOURCEzPERMIT NO 0008 -02 -N Issuance Date: December 15.- 2009 Expiration Date: December 14: 2014 In- accordance with the Hawaii Aoministrative�Rules;, Title 11, Chapter 60:9, Air Pollution Control,; the permittee shall report tonthe Department of Health' the following information semi - annually: (Make copies for suture use) For Period: Date: Facility Name' Equipment Location: Equipment Description: Equipment Capacity /Rating (specify units): (Units such as Horsepower, kilowatt, tons /hour, etc.) Serial/ID No.: I certify that I have knowledge of the facts herein set forth, that the same are true, accurate, and complete to the best of my knowledge and belief, and that all information not identified by me as confidential In nature shall be treated by the Department of Health as public record. Responsible Official (PRINT): TITLE Responsible Official (Signature): r STATE OF HAWA[ "A DEPARTMENT OF HEALTH UNDERGROUND INJECTION CONTROL (UIC) i� PERMIT NO. UH-1529 FACILITY IDENTIFICATION NO. 8-2883.01 for PUNA GEOTHERMAL VENTURE Operated By Puna Geothermal Venture PERMIT NO. UH -1529 Part II B. General Conditions . . . . . . . . . . . . . . . . . . . . . . . 15 1. Operating Conditions . . . . . . . . . . . . . . . . . . . . . . 15 2. Permit Issuance . . . . . . . . . . . . . . . . . . . . . . . . 16 3. Permit Modification . . . . . . . . . . . . . . . . . . . . . . 16 4. New Rules and Regulations . . . . . . . . . . . . . . . . . . . 17 5. Investigative and /or Mitigative - action work . . . . . . . . . 17 6. Duty to Mitigate . . . . . . . . . . . . . . . . . . . . . . . . 17 7. Property Rights . . . . . . . . . . . . . . . . . . . . . . . . 17 B. Right of Entry . . . . . . . . . . . . . . . . . . . . . . . . . 17 9. Need to Halt or Reduce an Activity Not a Defense . . . . . . . . 17 10. Penalties . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 11. Severability . . . . . . . . . . . . . . . . . . . . . . . . . . 18 (( Part III A. Other Conditions . . . . . . . . . . . . . . . . . . . . . . . 19 �\ . 1. Hydrolic Monitoring Program . . . . . . . . . . . . . . . . . . 19 2. Program for Mechanical Integrity Testing (MIT) and Monitoring of Injection Wells . . . . . . . . . . . . . . . . . . . . . . . 19 3. Modifications to Monitoring and Reporting . . . . . . . . . . . 19 Injection Well Schematics Figure No. 1, KS -1A . . . . . . . . . . . . . . . . . . . . . . . . 20 Figure No. 2, KS -3 . . . . . . . . . . . . . . . . . . . . . . . . . 21 Figure No. 3, KS -4 . . . . . . . . . . . . . . . . . . . . . . . . . 22 Figure No. 4, KS -11 . . . . . . . . . . . . . . . . . . . . . . . . . 23 Figure No. 5, KS -13 . . . . . . . . . . . . . . . . . . . . . . . . 24 List of Tables Table 1. Chemical Additives Table 2. Type I Sample . Table 3. Type III Sample . Table 4. Type IV Sample . . . . . . . . . . . . . . . . . . . 25 . . . . . . . . . . . . . . . . . . . 26 . . . . . . . . . . . . . . . . . . . . 27 . . . . . . . . . . . . . . . . . . . . 28 PERMIT NO. UH -1529 Issued Feb. 24, 2006 Page 1 of 28 AUTHORIZATION TO OPERATE UNDER THE UNDERGROUND INJECTION CONTROL PROGRAM In compliance with the provisions of the Safe Drinking Water Act, Chapter 340E, Hawai i Revised Statutes (HRS), as amended, and Hawaii Administrative Rules (HAR), Title 11, Chapter 23, Underground Injection Control, as amended; PUNA GEOTHERMAL VENTURE Operated by Puna Geothermal Venture is authorized to operate a Class V, Subclass E, injection well system consisting of five (5) injection wells known as geothermal wells Kapoho State IA (KS -lA) , Kapoho State 3 (KS -3) , Kapoho State 4 (KS -4) , and Kapoho State 11 (KS -11) , and Kapoho State 13 (KS -13): Injection Well No. Located on Well Pad Approx. Well Head Elevation Above Mean Sea Level KS -lA A 617 Feet KS -3 E 618 Feet KS-4 E 618 Feet KS -11 A 617 Feet KS -13 A 618 Feet and having the specifications as listed in Figures No. 1, 2, 3, 4 and 5, respectively; to inject the geothermal fluids consisting of geothermal brine, geothermal steam condensate, and geothermal noncondensible gases which are produced during the operation of the well field and power plant; and the intermittent inclusion of injection supplement water; back into the geothermal reservoir at an interval between the approximate depths of 3,900 feet and 8,100 feet, in reference to the Kelly Bushing; located at the facility's address of 14 -3860 Kapoho Pahoa Road, Pahoa, Hawaii 96778 at Tax Key Number, 3rd Div. 1 -4 -01:2 and 19; at the approximate well pad coordinates: Well Pad A; Latitude 190 28' 49" N and Longitude 154° 53' 35" W; Well Pad 8: Latitude 190 28' 41" N and Longitude 1540 53' 40" W; under Facility Identification Number: 8- 2883.01.1 -5; in accordance with monitoring conditions, and other terms and conditions set forth in Parts I, II, and III hereof. This permit becomes effective upon issuance. This permit and the authorization to operate the five (5) injection wells will expire at midnight, February 23, 2011. Issued on February 24, 2006. / (For) ni rPCtor rrf ✓UPmI t'h ff PART I t, PERMIT NO. UH -1529 Issued Feb. 24, 2006 Page 3 of 28 Certain chemical and /or physical parameters may be specified in this permit with an Action Level, a Regulatory Level, or both. Regulatory Levels shall not be exceeded. Chemical and /or physical parameters with or without specified Action Levels or Regulatory Levels may be subject to revised concentration levels pursuant to changing concerns related to public or environmental health, safety, or relevant laws and regulations. { PART I PERMIT N0. UH -1529 Issued Feb. 24, 2006 Page 5 of 28 The use of injection supplemental water discharged into the injection wells shall be recorded. The recording shall be directly and continuously made to measure the flow of supplemental water. A per -month summary giving the daily amounts of supplemental water used shall be submitted every month to the Department. Chemical additions being used for corrosion, scale, and biofouling control shall be recorded. The record shall account for the daily, weekly, and monthly consumptive amounts of each chemical. A per -month summary giving the monthly consumptive amount of each chemical shall be submitted every month to the Department. (c) Representative grab samples (three types: Types I, III, and IV) of the injectant shall be collected from a collection point to be established by the permittee and approved by the Director. The permittee shall collect and analyze the samples and report the analytical results according to the conditions and the Monitoring and Reporting Schedule of this permit. The collection and analysis of the samples shall be conducted by a laboratory acceptable to the Director. If the laboratory is unable to Cperform the sample collection, the Director may allow the permittee to collect the sample under the direction of the laboratory. All samples shall be collected, transported, preserved, stored, documented, analyzed, and reported in accordance with EPA or EPA equivalent methods or standards, and all such activities shall be performed properly and satisfactorily in order to produce valid samples and analytical results. The falsification, fabrication, tampering, or improper handling and management of the samples, chain -of- custody form, or analytical results shall be a violation of this permit. Methods of analysis shall be as stated herein or approved by the Director. The frequency of sample collection and the type of analyses are as described: Type I Sample: (1) Type I samples shall be collected and analyzed at least once every two months. A monitoring and reporting schedule is attached that outlines the schedule of analyses and reportings. (2) Type I samples shall be analyzed for the test parameters ( listed in Table No. 2. (3) Type I samples shall be collected between the hours of 9 a.m. and 3 p.m. (4) The analytical results (Type I) shall be submitted to the Department and a copy shall be kept on file at the facility. PART I PERMIT NO. UH -1529 Issued Feb. 24, 2006 Page 7 of 28 (d) The collection of Type III and Type IV samples shall be witnessed by departmental personnel unless a waiver to.this condition is granted by the Director. The permittee shall notify the Department at least seven (7) days prior to the date of sample collection for this phase of analysis. Any Type III and Type IV samples that are collected without the acknowledgement and inspection by departmental personnel, unless waived by the Director, will not serve to comply with the monitoring and reporting conditions of this permit. (e) As this condition may be applicable to this permit, whether specified now or specified later under a revision to this permit, every exceeding of an Action Level or Regulatory Level concentration shall prompt an immediate (within five (5) days from the time of knowledge of the initial analytical results) resampling for and reanalysis of the particular exceeding test parameter. If a Risk -Based Corrective Action or an Oily Wastewater - related action level is exceeded, the reanalysis shall be conducted by using the same method. If a TCLP- related action Clevel is exceeded, the reanalysis shall be conducted by using Method 1311: TCLP as described in 40 CFR, Part 261, Appendix II. If a TCLP regulatory level is exceeded, the reanalysis shall be conducted by using the same method. The permittee shall immediately notify the Department of every exceeding and shall submit the original and follow -up analytical results. The Department may impose additional conditions on resampling and reanalysis. (f) A periodic recorded inspection of the injection well system at least once every week shall be conducted by the permittee. The inspection shall include the recordation of the operational status of the injection well system to detect any deterioration of the injection well system and associated operations that might lead to an injection well failure, and provide the opportunity to correct any occurrence of prohibited discharge activity. The person conducting the periodic inspection shall be knowledgeable of what is unlawful disposal of chemical compounds, petroleum products and other hazardous substances into the injection well. If such activities are encountered, the permittee shall take immediate action to alleviate, correct, clean up, and record such disposal incidents. The recorded inspection including any disposal incidents shall be kept at the facility and be made available for inspection by departmental personnel. 5 PART I PERMIT NO. UH -1529 Issued Feb. 24, 2006 Page 9 of 28 2. Accurate, Current, and Representative Information The submission of records, analytical results, recorded inspections, status reports, and any other reportings as specified and required by this permit shall be truthful, accurate, current, and representative of the activity being monitored within the specified time frame for monitoring. The submission of false, inaccurate, noncurrent, and /or unrepresentative records, results, inspections, reports, and any other required information, or the nonsubmission of the required materials, is a violation of this permit. 3. Reporting of Noncompliance of Injectant Concentrations The permittee shall notify the Department of any exceedings of or noncompliance with the concentrations or limitations specified in Part I A. 2. Injection Limitations, as determined by the monitoring and analyses specified in this permit. The notification shall consist of a report that shall include the analytical results and an explanation for the exceeding or noncompliance. The report shall be submitted to the Department within fifteen (15) days of knowledge of the exceeding ( or noncompliance. 4. Emergency Operation (a) In the event of an emergency operation that results in the discharge of geothermal fluids to a holding system, such as a lined .surface impoundment, a daily record of the quantity of fluids being discharged into the holding system shall be kept. The discharge quantity shall be determined by flow measurements of the effluent. (b) The Department shall be notified within 24 hours of any such discharge to a holding system. (c) A summary report of the daily discharges to the holding system for every emergency operation shall be submitted to the Department within 15 days after the end of the emergency operation. (d) The Department shall be notified of the intent to discharge the contents of the holding system into the injection well. Discharge into the injection well shall only occur with the approval of the Director. (e) Discharge of geothermal injectant to a holding system does not preclude the activities of all sampling, analyses, and reporting conditions of this permit. PART I PERMIT NO. UH -1529 Issued Feb. 24, 2006 Page 11 of 28 9. Twenty -Four Hour Reporting Under any of the following conditions, an oral report is required within 24 hours from the time the permittee becomes aware of the circumstances: (a) Monitoring, or other information, which indicates that the injection activity is causing or could cause an endangerment to a USDW; (b) Malfunction of the injection system which.causes or could cause fluid migration into, out of, or between geologic formations via the well bore; (c) Overflow of the injection well; (d) Discharge into the injection well of prohibited chemical compounds, hazardous wastes, or unauthorized substances; (e) Impairment of the injection well including and not limited to a t�- collapsed well casing or well bore, well bore obstruction, lost well, or damage to the well resulting in a loss of use; or (f) Unsafe working or public conditions resulting from the operation of the injection well. A written report shall also be submitted within five (5) days of the time the permittee becomes aware of the circumstances. The written report shall contain a description of the incident and its cause, including exact dates and times, and if the incident has not been mitigated, the anticipated length of time that it is expected to continue; also, planned or accomplished measures to reduce, eliminate and prevent the reoccurrence of the incident. PART II PERMIT NO. UH -1529 Issued Feb. 24, 2006 Page 13 of 28 A. MANAGEMENT CONDITIONS: 1. Change in Discharge All operation of wells authorized herein shall be consistent with the terms and conditions of this permit. The operation of any well identified in this permit at volumes or concentrations in excess of that authorized shall constitute a violation of the permit conditions. Any anticipated facility changes including expansions, production increases, or process modifications which would result in new, different, or increased discharges of injectant shall be reported by submission of a UIC application. If such changes are not expected to violate the injection limitations specified in this permit, such changes may be submitted to the Department in writing instead of a UIC application, whereby the Department will determine if a UIC application would be necessary. Following the written submission of anticipated changes or the submission of a UIC application, this permit may be revoked or modified to specify and limit any injectant not previously authorized by this permit. 2. Signatory Statement All reports or information submitted to the Department pursuant to this permit shall be signed by the permittee. 3. Availability of Reports All reports prepared in accordance with the conditions of this permit shall be available for public inspection, with the approval of the Director, at appropriate offices of the Department. Permit applications, permits, and well operation data shall not be considered confidential. 4. Proper Operation and Maintenance The permittee shall at all times properly operate and maintain all systems of treatment and control, and related appurtenances, which are installed or used by the permittee to operate the injection wells and to achieve compliance with the conditions of this permit. Proper operation and maintenance include and are not limited to sound engineering principles and practices, effective performance, adequate funding, adequate operator staffing and training, adequate laboratory and process controls_, and appropriate quality assurance procedures. Furthermore, effective performance means and is not limited to no contamination of a USDW, no unintended subsurface fluid migration, no injection well overflow, no prohibited discharges, no loss or excessive sedimentation of the injection well, and no creation of unsafe working or public conditions. PART II PERMIT NO. UH -1529 Issued Feb. 24, 2006 Page 15 of 28 B. GENERAL CONDITIONS 1. Operating Conditions (a) No injection well shall be operated, kept, or otherwise utilized without an active UIC permit issued by the Department. (b) No person shall construct, operate, maintain, convert, backfill, seal, abandon or conduct any other injection activity in a manner which allows the movement of fluid containing a contaminant into underground sources of drinking water, if the presence of that contaminant may cause a violation of any primary drinking water rule or may otherwise adversely affect the health of one or more persons. (c) The injection wells shall be operated in such a man ner that they do not violate any of Hawaii Administrative Rules, Title 11, regulating various aspects of water quality and pollution, and Chapter 342, HRS. The rules include: (1) Chapter 11 -20, Potable Water Systems. (2) Chapter 11 -55, Water Pollution Control. (3) Chapter 11 -62, Wastewater Systems. (d) If at any time the Department learns that an injection well may cause a violation of primary drinking water rules, the Director shall order the permittee to take such actions as may be necessary to prevent the violation, including, where required, cessation of operation of the injection well. (e) Notwithstanding any other condition of this section, the Director will issue an order to immediately cease and desist injection upon receipt of factual information that the injectant has caused or is likely to cause imminent and substantial danger to the health of a person or persons due to contamination of a drinking water source. PART II PERMIT NO. VS -1529 Issued Feb. 24, 2006 Page 17 of 28 4. New Rules and Regulations The occurrence of new rules and regulations affecting underground injection, typically occurring as amendments to existing rules and regulations, may require that limitations or conditions within the permit be revised accordingly. Revisions to the permit, depending on the nature of the revision, may occur as a written supplement or an administrative reissuance of the permit, or it may require that the permit be reopened, via an application, before reissuance is accomplished. Existing limitations and conditions within the permit shall not be grounds for superseding new rules and regulations that would otherwise warrant a revision of the permit. The responsibility for knowing about and understanding new, as well as existing, rules and regulations that affect the permit is upon the permittee. 5. Investigative and /or Mitigative- action Work Public health or environmental concerns that may arise from the construction, operation, or management of the injection wells may twarrant appropriate investigative and /or mitigative- action work under the responsibility and at the expense of the permittee. Public health or environmental concerns may result from, but are not limited to, relevant complaints, requirements from other regulatory programs, reevaluations of tests, assessments or projections, unforeseen impacts or reactions, or events or projects that change the environmental setting in which the injection wells operate. The Department may directly bring concerns to the attention of the permittee for required action. If, however, concerns are brought to the attention of the permittee from either an employee, the public, third - party, or another agency, the permittee shall within ten days inform the Department of the concern, upon which investigative and mitigative- action work may transpire and be required. The objective of the investigative and mitigative- action work is to resolve concerns that are valid, relevant, and within the permittee's /facility's responsibility. 6. Duty to Mitigate The permittee shall take all reasonable steps to minimize or correct any adverse impact on the environment resulting from noncompliance with this permit. 7. Property Rights The issuance of this permit does not convey any property rights in either real or personal property, or any exclusive privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor any infringement of Federal, State or local laws or regulations. t` PART III PERMIT NO. UH -1529 Issued Feb. 24, 2006 Page 19 of 28 A. OTHER CONDITIONS: 1. Hydrologic Monitoring Program The permitee shall implement the Hydrologic Monitoring Program (HMP) dated May 1999 or as modified with the written approval of the Director. The HMP is described in Appendix A. Monitoring results shall be submitted within 60 days after the end of the designated monitoring period. 2. Program for Mechanical Integrity Testing and Monitoring of Injection Wells The permittee shall implement the Program for Mechanical Integrity Testing and Monitoring of Injection Wells, dated July 29, 1996, as described in Appendix 8 or as modified with the written approval of the Director. This program shall be implemented for all injection wells, including active, temporarily abandoned (idle) , and injection wells converted to monitoring wells. The permittee shall notify the Department at least forty -five (45) days prior to performing the annual mechanical integrity tests. For mechanical integrity tests resulting from well repair,'the permittee will notify the Department as soon as possible to give the Department the option of witnessing the mechanical integrity tests. Test results, findings, and conclusions shall be submitted within 60 days after the end of the designated monitoring period. 3. Modifications to Monitoring and Reporting This permit herein acknowledges that environmental and , f acility operating conditions affecting the monitoring and reporting conditions of this permit could warrant the Department's reevaluation of permit conditions in order to address changing concerns and to establish relevant analyses. Modifications to the monitoring and reporting conditions, resulting from reevaluations, shall be approved by the Director before implementation. UIC Permit Nc UH-1529 Page 21 of 2E CELLAR: 10FTx 10FTx10FT All depths measured from I KB: 25 ft above ground level 30" CONDUCTOR CEMENTED M 36" HOLE TO SURFACE Mi 10 -4 70 FT 20" W K-55 BT&C CEMENTED 1030' TO SURFACE WHOLE 1030 FT CEMENT YY- i -Y-ii 17 -112" HOLE 13-318"61# K-55 NEW VAM CEMENTED 2209' TO SURFACE 2209 FT 61 JTS 7' 29# L-80 NEW VAM LINER ON TOP OF 33 iTs r 290 L-80 BT&C LINER CEMENTED 3724' TO SURFACE 5'230 N-80 SLH C HANGDOWN LINER SURFACE TO 3806' 12 -1/4' HOLE 9-5/8' 47# C-90 NEW VAM CEMENTED 3897' TO 1972' TIED BACK AND CEMENTED TO SURFACE LINER HANGER Q 376T 3897 FT 7' 29# L-80 BT&C SLOTTED LINER I i I HUNG UNCEMENTED 6853-3767' 8-112" HOLE 6895' MD 6835 FT MD 6823' VD 6764 FT VD FROM: FISH LEFT IN HOLE: 511' OF 6-112" DCs, MONEL, 8-112' BIT 7406'TMD 7316'TVD PUNA GEOTHERMAL VENTURE KS-3 CASING SCHEMATIC AFTER AUGUST 1999 REWORK R. H. DENTON 1129/00 FIGURE 2 � l r _ All depths we measured from KB elevation, 27 R above ground level FROM: Puma Geothermal Ventutre Well KS-21 RD Schematic of Well Completion 304nch Contlrlebr Pipe fomented at 75 ft 22- tnoh,10B.5 bm casing cemented at 1,002 R 164leh, 97 *0 css6g cc wtedst2,102ft ♦ — ♦_ 93164tck T-95,47 ER[ hang4um finer from surface to 3,200 R -4— SMI -arch, L -00, 36 M finer hug from 4,1921L VWwrlow opened on the original 11.314 - �— inch, 65 Will casing at 4.422 R Uner blank from 4,192 to 4,425 ft, perforated from 4 42510 6,405 ft ♦— Bottom of 6-5/5-inch Iner at 6,405 R f Top of the tish at 6,439 ft 14 WeII T.D. = 7.950 R FIGURE 4 UIC Permit No, UH -1529 Page 23 of 28 PERMIT NO. UH -1529 Issued Feb. 24, 2006 Page 25 of 28 TABLE NO. 1 CHEMICAL ADDITIVES PRODUCT NAME AND FUNCTION CHEMICAL INGREDIENT Amersite (R)2 Sodium Bisulfite Corrosion Inhibitor Wrico Oxy 11 Sodium Sulfite Corrosion Inhibitor Ethylanediamine Tetraacetic Acid Sodium Salt WPD 11 -306 (Tm) Dimethyldioctylammnonium Chloride Corrosion Inhibitor Soya Amine Polyethoxylate Cyclohexylamine West R -322 Polyamideamine Acetate Corrosion Inhibitor POE (15) Tallow Amine Midland 203 Sodium Metabisulfite Oxygen Scavenger Cobalt Compounds Millsperse (R) 802 Poly (Maleic Acid) Anti - scalant Sodium Hydroxide Sodium Hydroxide pH Adjustor and H2S Abator Drew 11 -480, Soya Amine Polyethoxylate Corrosion Inhibitor Royal Purple Synthetic Lubricant Barrier Fluid Catalyzed Sulfite Sodium Sulfite, Benzoic Acid Oxygen Scavenger Drew 11 -575 Sodium Chloride Anti - Scalant Phosphoric Acid Derivative Biosperse 250, Magnesium Nitrate, Cupric Nitrate Microbiocide Magnesium Chloride �. 2- Methyl -4- Isothiazolin -3 -One 5- Chloro- 2- Methly- Isothiazolin -3 -One Sulfuric Acid Sulfuric Acid Anti - Scalant TABLE NO. 3 TEST PARAMETERS FOR TYPE III SAMPLE Parameter Ignitability Corrosivity Reactivity Inorganics: arsenic barium cadmium chromium lead mercury selenium silver Organics: benzene carbon tetrachloride chlorobenzene chloroform o- cresol m- cresol p- cresol 1,4- dichlorobenzene 1,2- dichloroethane 1,1- dichloroethylene 2,4- dinitrotoluene hexachlorobenzene hexachloro -1,3- butadiene hexachloroethane methyl ethyl ketone nitrobenzene pyridine tetrachloroethylene trichloroethylene 2,4,5 - trichlorophenol 2,4,6 - trichlorophenol vinyl chloride Regulatory Level (mg /1) 5.0 100.0 1.0 5.0 5.0 0.2 1.0 5.0 0.5 0.5 100.0 6.0 200.0 200.0 200.0 7.5 0.5 0.7 0.13 0.13 0.5 3.0 200.0 2.0 5.0 0.7 0.5 400.0 2.0 0.2 PERMIT NO. UH -1529 Issued Feb. 24, 2006 Page 27 of 28 Method As described in 40 CFR (1998) : Part 261.21 Part 261.22 Part 261.23 Method 1311 (TCLP), with appropriate methods of analyses contained in SW -846 I 1311 TABLE NO. 3 TEST PARAMETERS FOR TYPE III SAMPLE Parameter Ignitability Corrosivity Reactivity Inorganics: arsenic barium cadmium chromium lead mercury selenium silver Organics: benzene carbon tetrachloride chlorobenzene chloroform o- cresol m- cresol p- cresol 1,4- dichlorobenzene 1,2- dichloroethane 1,1- dichloroethylene 2, 4-dinitro toluene hexachlorobenzene hexachloro -1,3-butadiene hexachloroethane methyl ethyl ketone nitrobenzene Pyridine tetrachloroethylene tri.chloroethylene 2, 4, 5 -trichlorophenol 2,4,6- trichlorophenol vinyl, chloride Reaulatory Level (ma /1) PERMIT NO. YIH -1529 Issued March 28, 2003 Page 26 of 27 Method As described in 40 CFjt (1.998)- Part 261.21 Part 261.22 Part 261.23 Method 1311 (TCLP), 5.0 with appropriate 100.0 methods of analyses 1.0 contained in SW -846 5.0 5.0 0.2 1.0 5.0 I 1311 0.5 0.5 i 100.0 6.0 200.0 200.0 I 200.0 7.5 0.5 0.7 0.13 0.13 0.5 f 3.0 200.0 2.0 5.0 0.7 t! 0.5 400.0 2.0 0.2 PERMIT NO. UH -1529 Issued March 28, 2003 Page 27 of 27 TABLE NO. 4 TEST PARP_;1ETERS FOR TYPE IV SAMPLE Parameter Method Volatile Organics 524/624/8240/8260 Benzene Bromodichloromethane Bromoform Bromomethane Carbon Tetrachloride Chlorobenzene Chloroethane C 2- Chloroethylvinyl ether Chloroform Chloromethane bibromochloromethane 1,2- Dichlorobenzene 1,3- Dichlorobenzene 1,4- Dichlorobenzene 1,1- Dichloroethane 1,2- Dichloroethane 1,1 Dichloroethylene trans- 1,2- Dichloroethene 1,2- Dichloropropane cis -1,3- Dichloropropene trans -1,3- Dichloropropene Ethyl benzene Methylene chloride 1,1,2,2- Tetrachloroethane Tetrachloroethene Toluene 1,1,1 - Trichloroethane 1,1,2 - Trichloroethane Trichloroethene Trichlorofluoromethane Vinyl Chloride APPENDIX A PUNA GEOTHERMAL VENTURE HYDROLOGIC MONITORING PROGRAM December 2005 Sampling Locations: The following wells will be monitored. Well Name Elevation (MSL) Total Depth (feet) MW -1 610 720 MW -2 588 646 MW -3 (standby for MW -1) 610 720 Frequency: Regular sampling shall occur twice a year, once in January and once in July. Water Level Measurements: Prior to bailing the well and sampling, water level measurements will be taken and recorded. The permittee can use an Echo Meter or similar device, or an electronic direct contact detection probe with a calibrated cable /tape for direct measurement at the top of the well casing. Calibrated cable /tape length shall be sufficient to measure water levels in the deepest wells. The metering device shall be equipped with an audible signal and light to indicate water level contact. Quality Assurance / Quality Control: Quality assurance /quality control procedures will be in compliance with standards of practice for similar programs relative to the acquisition, reduction, verification, and validation of the site data. At each location, standardized equipment cleaning will be conducted prior to obtaining each sample. Prior to ground water sampling, the well will be bailed at least three times the wellbore volume. All samples will be taken and field analyses conducted in accordance with standard protocols approved by the EPA. An EPA Page 1 of 2 APPENDIX B PUNA GEOTHERMAL VENTURE PROGRAM FOR MECHANICAL INTEGRITY TESTING AND MONITORING OF INJECTION WELLS July 29, 1996 1. INTRODUCTION 1.1 Background Pursuant to Underground Injection Control (UIC) Permit No. HI596002, the U.S. Environmental Protection Agency requires that Puna Geothermal Venture (PGV) comply with this Testing and Monitoring Program (TMP) for injection wells. Monitoring and testing provisions in this TMP are similar in most respects to those in the "Casing Monitoring Program," April 26, 1993 version, which is referenced by title in PGV's current UIC Permit No. UH -1529. (The Casing Monitoring Program related to Hawaii UIC Permit No. UH -1529 was originally dated 11/21/1991 and amended later dated 4/26/1993.) It is anticipated that this same TMP will be approved and adopted by the Hawaii Department of Health as a replacement for the 1993 "Casing Monitoring-Program." Revisions to testing and monitoring provisions in the 1993 "Casing Monitoring Program" have been made as a result of a joint, review of PGV's injection well monitoring and testing involving EPA, BLM (as advisor to EPA), HDOH and PGV. The purpose of these revisions is to better accomplish the goal of protecting the. groundwater aquifer under the PGV project site, which is considered to be a USDW. The principle changes in the monitoring and testing procedures are as follows: • As described in Section 3.1 of this TMP for wells in injection service, the annulus nitrogen pressure wil-1 be -- maintained to keep the nitrogen /water interface at a depth of at least 2000 ft. Page 1 of 7 Remedial actions required to restore mechanical integrity are also described. 1.3 Scope This TMP covers all injection wells on the 500 -acre PGV site. 2. TESTING DURING DRILLING AND COMPLETION 2.1 Pressure Testing During Drilling Each injection well is completed with three lasing strings (not including the 30 -inch conductor pipe) cemented to the surface (Figure 1). Upon completion of cementing each casing string and prior to drilling out the cement shoe, the casing well be pressure tested. The DLNR will be notified at least 24 hours before each test for the opportunity to witness it. The test will consist of pressurizing the casing with water or drilling mud to a specified test pressure and monitoring the pressure for 30 `. minutes..with the well shut -in. The minimum casing test pressure shall be approximately one -third of the internal yield pressure rating, provided that the test pressure shall not be less than 600 psig nor greater than 2500 psig. In cases where combination strings or liners are involved, the above test-pressures shall apply to the lowest pressure -rated casing. The pressure drop during the 30- minute period shall not exceed 10% of the test pressure. In the event of a pressure loss exceeding the above criterion, one or more of the following diagnostic methods will be used to locate the leak: - Temperature log while injecting - Shut -in temperature survey - Casing inspection logs with multi -arm caliper and /or magnetic inspection tools - Pressure testing with a packer(s) on drillpipe - Other applicable - methods After identification of the point of leakage, a cement squeeze job will be performed and the casing retested. Page 3 of 7 2.3.1 Shut in well and run magnetic and multi -arm casing inspection logging tools to locate the leak and to evaluate the casing condition. 2.3.2 Rig up workover rig on well. Run packer(s) on drillpipe and pressure test to confirm suspected leaking interval. 2.3.3 Execute cement squeeze job to seal casing leak or stop interzonal flows behind casing. 2.3.4 Perform casing pressure test and other diagnostic tests as necessary to confirm success of the remedial work. If good, move rig off well and return well to injection service. 2.3.5 In the event of major casing failure, a cemented liner may be installed through the +t damaged.interval. 2.3.6 Prior to drilling out the liner shoe, the liner will be pressure tested as described in Section 2.1. 2.3.7 If mechanical integrity cannot be restored satisfactorily, the well will be plugged and abandoned. 3.. MONITORING AND TESTING AFTER WELL IS PLACED IN SERVICE 3.1 Continuous Monitoring During Routine Injection Operations During routine injection well operations, including brief periods when well(s) may be temporarily out of service, the following conditions will be maintained: 3.1.1 A continuous recording of the following parameters will be maintained for each well: • Injection wellhead pressure, • Annulus (nitrogen) pressure, and • Injection flow rate. Page 5 of 7 Integrity of the cement (external mechanical integrity) will be checked during each workover by one or more of the following procedures: 3.2.3 One or more shut -in static temperature surveys will be run. Shut -in time will be at least 12 hours, or longer if necessary to obtain meaningful results. or 3.2.4 Other logs or surveys.may be run,. at the discretion of PGV, if static temperature surveys are not definitive. 3.3 Restoration of Mechanical Integrity or Abandonment In the event that the diagnostic procedures indicate a loss of mechanical integrity, remedial or abandonment procedures will be carried out as specified in Section 2.3. Page 7 of 7 C-- H C•� b m n w C? 7r O x w N w w 0 x w 10 O �:I, O b O Al O a� A. b w x O x w r- r- a b a z ❑ e mO 0 °rn a n ❑ o x a � � N ❑ 2S M� N N ❑ A ❑ O ❑N O �< N T N El ❑ ❑ ❑ O G') a -�� - z OUI - -i � �rn A �W O \ Al O P b �yN1 1 to RY1 ♦T P T N y 9 N a- 4 \s O 2 Z � o a E V^ T2 'y ❑ � V Q` Tl N 4 4 �G N� O r rn L. p N tO ❑ W —A ❑ W ® N to ❑N ❑N O ®O � ❑� 0 ❑ W O O � c R E a 3 f y �O r Lp ❑ t0 C OI 0 rn ❑J C-- H C•� b m n w C? 7r O x w N w w 0 x w 10 O �:I, O b O Al O a� A. b w x O x w r- r- a b a z U.S. Environmental Protection Agency, Region 9 UNDERGROUND INJECTION CONTROL (UIC) INDIVIDUAL PERMIT Class V Injection Permit No. HI596002 Issued to: Puna Geothermal Venture (owner and operator) 14 -3860 Kapoho Pahoa Road Pahoa, Hawaii 96778 1 TABLE OF CONTENTS Page PART I. JURISDICTION AND AUTHORIZATION TO OPERATE .......... 4 PART II. SPECIFIC PERMIT CONDITIONS A. LOCATION OF EXISTING AND PROPOSED INJECTION WELLS..6 1. Existing Injection Well Locations- 2, Proposed Injection Well Locations B. WELL CONSTRUCTION AND RELATED CONDITIONS ........... 7 1. New Wells and Conversions 2. Casing and Cementing 3. Tubing 4. Injection Interval 5. Monitoring Devices '6. Proposed Changes and Workovers C. CORRECTIVE ACTION .... .............................10 1. Area of Review 2. Corrective Action D. WELL OPERATION ....... .............................10 1. Mechanical Integrity 2. Injection Pressure Limitation 3. Injection Rate Limitation 4. Injection Fluid Limitation 5. Upset Conditions E. MONITORING, RECORDKEEPING, AND REPORTING OF RESULTS........... .............................12 1. Hydrologic Monitoring Program 2. Program for Mechanical Integrity Testing and Monitoring of Injection Wells 3. Injection Fluid Monitoring Program 4. Monitoring Information 5. Calibration of Monitoring Equipment 6. Automatic Alarms and Shut -Off Devices 7. Recordkeeping 8. Accurate, Current, and Representative Information 9. Reporting 10. Modifications to Monitoring and Reporting 11. Additional Monitoring and Reporting 12. Twenty -Four Hour Reporting 13. Reporting of Noncompliance of Permit Limitations F. PLUGGING AND ABANDONMENT ....... ...................17 1. Notice of Plugging and Abandonment 2. Plugging and Abandonment Plan 3. Plugging and Abandonment Report 4. Well Closure G. FINANCIAL RESPONSIBILITY ........................... 18 1. Demonstration of Financial Responsibility 2. Insolvency of Financial Institution PART III. GENERAL PERMIT CONDITIONS A. EFFECT OF PERMIT ...... .............................19 B. PERMIT ACTIONS ........ .............................20 1. Modification, Revocation, Reissuance, and- Termination 2. Transfer of Permits C. SEVERABILITY .... ............................... ...21 D. CONFIDENTIALITY ............................. .....21 E. GENERAL DUTIES AND REQUIREMENTS ....................21 1. Duty to Comply 2. Penalties for Violations of Permit Conditions 3. Need to Halt or Reduce Activity not a Defense 4. Duty to Mitigate S. Proper Operation and Maintenance 6. Duty to Provide Information 7. Inspection and Entry 8. Records of the Permit Application 9. Availability of Reports 10. Signatory Requirements 11. Reporting of Changes and Noncompliance 12. Continuation of Expiring Permits 13. Required Immediate and Followup Notification of Non- permitted Releases PART IV. APPENDICES ........... .............................24 APPENDIX A - Injection Well Schematics APPENDIX B - Existing and Proposed Well Pad Locations APPENDIX C - Approved Changes and Workovers APPENDIX D - Casing Monitoring Program APPENDIX E - Injection Pressure Limitations for New Wells APPENDIX F - Chemical Additives APPENDIX G - Hydrologic Monitoring Program APPENDIX H - Chemical and Physical Analysis Plan for Injectate Testing APPENDIX I - Plugging and Abandonment Plan APPENDIX J - Definitions APPENDIX K - Modifications 3 PART I. JURISDICTION AND AUTHORIZATION TO OPERATE The U.S. Environmental Protection Agency (EPA) issues its UIC Permit pursuant to its authority under the Safe Drinking Water Act (SDWA), as amended, and implementing regulations at Title 40 of the Code of Federal Regulations, Parts 124, 144, 146, 147, and 148. Pursuant to its permitting authority, the EPA hereby authorizes Puna Geothermal Venture (owner and operator) 14 -3860 Kapoho Pahoa Road Pahoa, Hawaii 96778 to operate four existing Class V geothermal injection wells (the term "well" shall refer to an injection well unless otherwise stated), known as geothermal wells Kapoho State lA (KS -1A), Kapoho State 3 (KS -3), Kapoho State 4 (KS -4), and Kapoho State 11 (KS -11): and having the specifications as listed in Figure No. 1, Figure No. 2, Figure No. 3, and Figure 4, respectively, of Appendix A-- Injection Well Schematics; to inject geothermal fluids consisting of.geothermal brine, geothermal steam condensate, and geothermal noncondensible gases that are produced during the operation of the well field and power plant; chemical additions for process system and well casing biofouling, corrosion, and scale control; and the intermittent injection of supplement water back into the geothermal reservoir at an interval between the approximate depths of 3,900 feet and 7,300 feet (in reference to the Kelly Bushing, or KB, which is 25 feet above the top of cellar), located at the facility's address of 14 -3860 Kapoho Pahoa Road, Pahoa, Hawaii, 96778; at Tax Key Number, 3rd Div. 1 -4 -01:2 and 19; at the approximate well pad coordinates: Well Pad A: Latitude 19 28' 49" N and Longitude 154 53' 35" W; Well Pad E: Latitude 19 28' 41" N and Longitude 154 53' 40" W; in accordance with monitoring requirements and other conditions set forth in Parts I, II, III and IV hereof. Approximate Injection Operational Located on Well Head Elevation Well No. Status Well Pad Above Mean Sea Level KS--lA Primary Injector A 618 feet KS -3 Primary Injector E 617 feet KS -4 Primary Injector E 617 feet KS -11 Primary Injector A 618 feet and having the specifications as listed in Figure No. 1, Figure No. 2, Figure No. 3, and Figure 4, respectively, of Appendix A-- Injection Well Schematics; to inject geothermal fluids consisting of.geothermal brine, geothermal steam condensate, and geothermal noncondensible gases that are produced during the operation of the well field and power plant; chemical additions for process system and well casing biofouling, corrosion, and scale control; and the intermittent injection of supplement water back into the geothermal reservoir at an interval between the approximate depths of 3,900 feet and 7,300 feet (in reference to the Kelly Bushing, or KB, which is 25 feet above the top of cellar), located at the facility's address of 14 -3860 Kapoho Pahoa Road, Pahoa, Hawaii, 96778; at Tax Key Number, 3rd Div. 1 -4 -01:2 and 19; at the approximate well pad coordinates: Well Pad A: Latitude 19 28' 49" N and Longitude 154 53' 35" W; Well Pad E: Latitude 19 28' 41" N and Longitude 154 53' 40" W; in accordance with monitoring requirements and other conditions set forth in Parts I, II, III and IV hereof. The EPA authorizes the operation of the four (4) existing Class V geothermal injection wells, and the construction and operation of up to six (6) new Class V geothermal injection wells, contingent on the conditions of this permit being met. As specified in Part II.A.2 of this permit, the location of new injection wells will be included in Appendix B-- Existing and Proposed Well Locations. All conditions set forth herein refer to Title 40 Parts 124, 144, 146, and 148 of the Code of Federal Regulations. This permit consists of 23 pages in addition to appendices and includes all items listed in the Table of Contents. Further, this permit is based upon representations made by the permittee and on other information contained in the administrative record. It is the responsibility of the permittee to read and understand all provisions of this permit. This permit is issued by the EPA for a period of ten (10) years unless terminated under the conditions set forth in Part III, Section B of this permit. This permit is issued on APR 11 2036 and becomes effective on MAY 1 6 26og v, AlExi trauss, Director Water vision, U.S. EPA Region 9 61 PART II. SPECIFIC PERMIT CONDITIONS A. LOCATION OF EXISTING AND PROPOSED INJECTION WELLS 1. Existing Infection Well Locations The permittee currently operates four (4) Class V injection wells known as geothermal wells, Kapoho State lA (KS -lA), Kapoho State 3 (KS -3), Kapoho State 4 (KS -4), and Kapoho State 11 (KS -11). Injection Status Located Approx. Wellhead Well No. on Elevation Well Pad Above Mean Sea Level KS -lA Primary A 618 feet Injector KS -3 Primary A 618 feet Injector KS -4 Primary E 617 feet Injector KS -11 primary E 617 feet Injector The wells are located at the facility's address of 14 -3860 Kapoho Pahoa Road, Pahoa, Hawaii 96778; at Tax Key Number, 3rd Div. 1 -4 -01:2 and 19; at the approximate well pad coordinates: Well Pad A: Latitude 19° 28' 49" N and Longitude 154° 53' 35" W; Well Pad E: Latitude 190 28' 41" N and Longitude 154° 53' 40" W; 2. Proposed Injection Well Locations a. The permittee is authorized by the EPA to operate the four (4) existing geothermal injecton wells, and construct and operate up to six (6) new geothermal injection wells, contingent on the conditions of this permit being met. The new wells will be located on the well pads within the property boundary delineated in Appendix B, and will be set back at least 600 feet from the property boundary. b. At least sixty (60) days prior to spudding a new well, EPA shall receive from the permittee: 1) the latitude and longitude of the new well(s), and 2) a map similar to the one in Appendix B with the location of the existing and new wells. 9 B. WELL CONSTRUCTION AND RELATED CONDITIONS 1. New Wells and Conversions a. The permittee shall give advance notice of at least sixty (60) days to the EPA prior to spudding a new injection well or non - injection well (e.g. developmental, production, exploration) well. The permittee shall give advance notice of at least sixty (60) days to the EPA of the conversion of a non - injection well to an injection.well. b. A new well or a non - injection well converted to an injection well may not commence injection until: i) construction is complete and the permittee has submitted a notice of completion of construction to the EPA through certified mail; and ii) the EPA has received and reviewed the well information in II.B.1.c and finds it is in compliance with the conditions of the permit. Injection into a new or converted well is prohibited until the permittee shows to the satisfaction of the EPA under §146.6 that the well has mechanical integrity. If the EPA elects to inspect the well, the EPA will notify the permittee of this within 13 days of the date of the notice in II.B.6.b.i, and will include a reasonable time period in which it will inspect the well. Review of the well will be based on the information in II.B.6.c. C. The permittee shall provide EPA with the following information for new and converted wells: i. The latitude and longitude and well pad of the well and a map similar to the one in Appendix B with the location of the existing and new wells [for new wells, this information shall be received at least sixty (60) days prior to spudding the well] ; ii. A schematic diagram showing the total depth of the well, and the depths of casing, tubing, and slotted liners for Appendix A; iii. The lithologic log and injectivity test results; iv. All mechanical integrity test results, including the results of a static temperature test and pressure test; and V. A plugging and abandonment plan on Form 7520 -14 to be included in Appendix I. d. It is recommended that the permittee notify the emergency responders (County Civil Defense, Fire Department and Police Department) at least fourteen (14) days prior to drilling any new injection or non - injection well. It is also recommended that PGV keep an updated emergency response plan. 7 2. Casino and Cementing The specifications in Figures No. 1, No. 2, No. 3 and No. 4 in Appendix A, apply to injection wells KS -lA, KS -3, KS -4, and KS -11, respectively. New injection wells will be drilled according to the construction plans submitted in Attachment L of the application: Changes to the construction plans during construction are considered minor modifications provided that the permittee notifies and receives approval from EPA, and that the changes comply with the requirements of 40 CFR § §144 and 146 (40 CFR §144.41(f)). Within sixty (60)-days of* completing the construction of a well, the well schematic will be provided to the EPA to be included in Appendix A. All existing and new wells shall be cased and cemented to prevent the movement of fluids behind the casing and the casing shall be maintained until the plugging and abandonment of the well. 3. Tubing Injection tubing (hangdown liner) will be utilized within the longstring casing and will extend to the depths indicated on the well schematics. The casing /tubing annulus of all existing and proposed injection wells will be filled with nitrogen gas down to a depth of at least 2,000 feet (KB) or 1,975 (below ground surface or BGS). The depth of the fluid level in the annulus shall be measured using a sonic device. 4. Injection Intervals For each well, injection into the intended zones will be through the open borehole, with or without a slotted (perforated) liner, below the cemented solid casing. Alteration of the injection perforations and other rework operations must be properly reported using EPA Form 7520 -12 in Appendix C-- Approved Changes and Workover Plans and Sample Forms. Injection between the outermost casing and the well bore is prohibited. The injection interval of the proposed well will be at a depth so as not to cause the migration of injected fluids into Underground Sources of Drinking Water (USDW) . 5. Monitorina Devices Pursuant to 40 CFR § §144.51(h) and 144.52(a)(9) in order to prevent the migration of injected fluids into a USDW and adequately characterize the injectate, the operator shall maintain, in accurate and good operating condition, the following: a. A sampling port on the injection -line between the injection common header and an active injection well for the purpose of obtaining representative samples of the injected fluids; b.i. An injection pressure indicator and a continuously - recording injection pressure recorder on the injectate line immediately upstream of each well; M. ii. a local indicator and a remote pressure transmitter on the combined flow injection line that provides information directly to the control room at the plant; and iii. an injection pressure switch that triggers a computer printout in the control room; C. A continuously recording pressure recorder at each well to measure annular nitrogen pressure; d.i. A flow metering orifice on the injection line immediately upstream of each well; ii. a flow transmitter at each well that provides information directly to the control room of the plant; iii. a flow totalizer on the injection line immediately upstream of each well; and iv. a flow transmitter on the combined flow injection line that provides information directly to the control room of the plant; e.i. A temperature indicator located on the injection line immediately upstream of each well; and ii. a local indicator and a remote temperature transmitter on the combined flow injection line that provides information directly to the control room at the plant; and f. A device on the line between the Emergency Steam Release Facility (ESRF) and the combined flow injection line for measuring the quantity of supplemental water going to the wells. g. A sonic device shall be used to measure the fluid level in the annulus of the injection wells. 6. Proposed Chances and Workovers The permittee shall give advance notice of at least sixty (60) days to the EPA of any significant physical alterations to the wells. Any changes in the well construction will require prior approval of the EPA and either a major or minor permit modification under the requirements of 40 CFR § §144:39 and 144.41. In addition, the permittee shall provide a workover report containing all records of well workovers, or other subsequent test data to the EPA within sixty (60) days of completion of the activity. Appendix C contains a sample of the appropriate reporting form for the workover report. Mechanical integrity testing shall be performed within thirty (30) days of the completion of any workovers or alterations. Mechanical integrity shall be demonstrated to EPA prior to resuming or commencing injection activities, following in accordance with Part II.D.1 of this permit. W C. CORRECTIVE ACTION 1. Area_ of Review a. The area of review (AOR) shall consist of the aggregate of one - fourth (1/4) mile radii that extend beyond the edge of each well pad as identified in Appendix B b. Unless corrective action has been taken, the construction of a new injection well or conversion to an injection well is prohibited within the area of review until all abandoned, improperly sealed, or improperly completed wells that are located within the AOR and penetrate the injection zone are properly plugged and abandoned by the appropriate party. 2. Corrective Action The drilling of a new injection well or conversion to an injection well is prohibited within a one - fourth (1/4) mile of Scientific Observation Hole #1 (SOH -1) until the internal and external mechanical integrity of SOH -1 has been demonstrated to the EPA by some party. D. WELL OPERATION 1. Mechanical Integrity a. All injection wells, including active, temporarily abandoned, and injection wells no longer serving their original function (e.g. injection wells used for monitoring purposes) must have and maintain mechanical integrity consistent with 40 CFR §146.8. The permittee must show that there are no significant leaks in the casing and tubing and that there is no significant fluid movement into a USDW through channels adjacent to the injection wellbore. b. In addition, an annulus pressure increase or decrease of more than ten (10) percent in five (5) hours constitutes a significant leak, unless it occurs during the normal shut -in of a well for repairs, wellhead changeout, annual maintenance outage, or other normal operation and maintenance situations. When an annulus pressure increase or decrease of more than ten (10) percent in five (5) hours occurs or at any time the gas /fluid interface cannot be maintained at a depth of at least 2,000 feet KB (1,975 feet BGS), as measured by a sonic device such as an Echo Meter, then the permittee is required to inspect the wellhead for leaks, repair any wellhead leaks found, and resume monitoring. If either one of the aforementioned conditions persists, then the permittee is required to shut in and secure the well, submit an action plan for locating and repairing the leak, repair the leak, and satisfactorily demonstrate to EPA mechanical integrity before returning to operations. The tests and monitoring data that show that the well has had its mechanical integrity restored shall be sent to the EPA. 10 C. If a lack of mechanical integrity and /or significant leaks are detected and confirmed in two or more injection wells, flow into these two or more wells will be stopped, and if necessary, the control operator will reduce the incoming flow from the production well(s). If all injection wells incur mechanical integrity failures and /or significant leaks at the same time, all injection wells shall be shut in. 2. Injection Pressure Limitation a. Injection pressure shall not exceed the fr- acture pressure of the receiving formation, nor the injection pressures for the individual wells as listed below. Maximum Injection Wellhead Well Pressure (psic) KS -1A 500 KS -3 500 KS -4 500 KS -11 1,040 The permittee shall supply the maximum injection wellhead pressure limitation for a new well to the EPA to be included in Appendix E-- Injection Pressure Limitations for New Wells. b. All piping, valves and facilities associated with injection operations shall meet or exceed API standards for the injection pressure and shall be maintained in a safe and leak --free condition. 3. Injection Rate Limitation The injection rate shall not cause an exceedance of the injection pressure limitation in Part II.D.2.a. Should the maximum injection rate increase to a point where it appears that the maximum injection pressure limitation will be exceeded, then the EPA will reconsider setting maximum injection rate limitations. 4. Injection Fluid Limitation a. Injectant in this permit is limited to geothermal fluids, supplemental water, and chemical additions for process system and well casing biofouling, corrosion, and scale control. b. Geothermal fluids consist of geothermal brine, geothermal steam condensate, and geothermal noncondensible gases. C. Supplement water may consist of steam turbine seal water, rinsate from the water softener system, sulfatreat heat exchanger cooling water, raw /quench water, production well bleed system, abatement fluids, sulfatreat system vacuum pump seal water, condensate from the sulfatreat system, periodic produced drilling fluids, and fluids from the plant water storage tank and the emergency steam release facility (ESRF). Some of these fluids may contain the additives listed in 11 Appendix F-- Chemical Additives. d. Chemical additives for process system and well casing biofouling, corrosion, scale control and tracers must be in accordance with the Chemical Additives list in Appendix F. The permittee shall notify the EPA of any new chemical additive prior to its use and shall provide the EPA with a copy of its Material Safety Data Sheet (MSDS). e. To inject fluids other than those described in paragraphs a -c above, the permittee must receive written approval from the EPA. 5. Upset Conditions In the event of an upset of facility operations where the injection wells cannot be used, injectate shall not be discharged on the ground. Additionally, there shall be no overflow of fluids from the Emergency Steam Release Facility (ESRF) to the ground. The permittee shall contact the EPA and other appropriate federal, state, and local agencies as specified in this permit (Parts III.E.11 and 13). E. MONITORING, RECORDKEEPING, AND REPORTING OF RESULTS 1. Hydrologic Monitoring Program The permittee shall implement the Hydrologic Monitoring Program dated December 2005, in Appendix G, or as modified with the written approval of the EPA. 2. Program for Mechanical Integrity Testing and Monitorina of Injection Wells a. The permittee shall implement the Program for Mechanical Integrity Testing and Monitoring of Injection Wells, dated July 29, 1996, in Appendix D or as modified with the written approval of the EPA. This program shall be implemented for all injection wells, including active, temporarily abandoned (idle), and injection wells converted to monitoring wells. b. The permittee shall notify the EPA at least sixty (60) days prior to performing the annual mechanical integrity tests. For mechanical integrity tests resulting from well repair, the permittee will notify the EPA as soon as possible to give the EPA the option of witnessing the mechanical integrity tests. C. Annual mechanical integrity tests for all wells shall be conducted sequentially with in the same test period to enable EPA to witness them. d. In addition, a continuous recording of the injection wellhead pressure, injection rate, and annulus pressure shall be maintained. Injection wellhead pressure, injection rate and annulus pressure -shall be visually checked daily. 12 Pressure recordings shall be documented on a graphical chart, such as a strip chart or circular chart, that shows the relationship between pressure and elapsed time. The pressure recordings shall be maintained whether or not the injection well is in use. The pressure recordings shall distinguish between the time periods of use and nonuse, if any. A summary report that contains the daily maximum injection pressure shall be submitted to the EPA quarterly. Any increase or decrease in the annulus pressure of ten (10) percent or greater over a continuous five (5)-hour period or any rise in the gas /brine interface above 2,000 feet KB (1,975 feet�BGS) in the tubing /casing annulus shall be reported within twenty - four (24) hours to the EPA, and in the monthly report with an explanation. 3. Iniection Fluid Monitoring Program a. The permittee shall comply with the analytical and reporting conditions of the facility's Chemical and Physical Analysis Plan For Injectate Testing in Appendix H, or as amended with written approval the EPA. b. The permittee shall utilize the applicable analytical methods described in Tables IA -IE of 40 CFR §136.3, or in Appendix III of 40 CFR §261, or in certain circumstances, other methods that have been approved by the EPA. C. Samples and measurements taken for the purpose of monitoring shall be representative of the monitored activity. Injectate fluid samples shall be taken at the injection line sampling port between the injection common header and injection well KS -lA or any active injection well. Injectate gas samples shall be taken from the noncondensible gas line prior to mixing with the injectate fluid flow. d. The following shall be monitored daily: quantity of total injectate, quantity of geofluids, quantity of supplemental water, chemical additions, and injectate temperature. e. Under applicable conditions, the EPA shall have the right to order and direct the permittee to collect, analyze and report on special or unscheduled samples of the injectate. Applicable conditions consist of, but are not limited to, accidental discharges, malicious discharges, and undefined discharges into the injection well. The permittee is required to maintain records of the sample collection and analysis in conformance with Part II.E.4 of this permit. 4. Monitoring Information Records of any monitoring activity required under this permit shall include: a. The date, exact place, and time of sampling or field measurements; 13 b. The name of the individual(s) who performed the sampling or measurements; C. The exact sampling method(s) used to take samples; d. The date(s) laboratory analyses were performed; e. The name of the'individual(s) who performed the analyses; f. The analytical techniques or methods used by laboratory personnel; ' g. The results of such analyses, including reporting units; and h. Chain of custody records. 5. Calibration of Monitoring Equipment All monitoring and recording equipment shall be calibrated on a regular basis. The permittee shall submit to the EPA a one- time report describing the calibration procedures and the frequency at which the equipment will be calibrated. 6. Automatic Alarms and Shut -Off Devices a. Injection pressure shall be monitored in the control room and an automatic computer printout system shall be maintained so as to notify operators when the injection pressure switch in the combined flow injection line has been activated. b. The pressure switch on the combined flow injection line and the relief valves on the individual injection'wells shall be maintained in good working order and shall be set so as to not cause an exceedance of the maximum injection wellhead pressure limitations for the individual wells in Part II.D.2(a), or the fracture pressure of the formation, which ever is less. C. The two manual block values on each injection and production well shall be maintained in good working order. 1. Recordkeeping a. The permittee shall retain records concerning:- i. The origin, physical properties, and chemical composition of all injected fluids until three (3) years after the well has been plugged and abandoned in accordance with the Plugging and Abandonment Plans shown in Appendix I; and ii. All monitoring information, including all calibration and maintenance records and recordings used for continuous monitoring and copies of all reports required by this permit, shall be maintained by the permittee for a period of at least five (5) years from the date of the sample, measurement, or 14 report until the well had been plugged and abandoned. b. The permittee shall continue to retain such records after the retention periods specified in paragraph (a) unless it delivers the records to the EPA or obtains written approval from the EPA to discard the records. C. The permittee shall maintain copies (or originals) of all pertinent observation records available for inspection at the facility, unless the permittee has archieved the records the EPA or has obtained permission from the EPA to discard'the records. 8. Accurate, Current, and Representative Information The submission of records, analytical results, recorded inspections, status reports, and any other reporting as specified and required by this permit shall be accurate, current, and representative of the activity being monitored within the specified time frame for monitoring. The submission of inaccurate, out - dated, and /or unrepresentative records, results, inspections, reports, and any other required information, or the nonsubmission of the required materials, is a violation of this permit. 9. Reporting The permittee shall submit the following information to the EPA: a. Semiannual groundwater monitoring report and data as required by the Hydrologic Monitoring Program, to be submitted by March 31 and September 30: b. Annual mechanical integrity test results and monitoring data as required by the Program for Mechanical Integrity Testing and Monitoring and Part II.E.2 of this permit. Mechanical integrity test results shall be provided to EPA within sixty (60) days of the tests. C. All records of mechanical integrity test results, monitoring data, workovers, well conversions, logging or other subsequent test data generated by the workover, alteration, or repair of a well as required by Parts II.B.1, II.B.6 and II.D.l. d. The one -time calibration report describing the calibration proceduces and frequency for monitoring equipment as required by Part II.E.5, in addition to calibrations required for the other reports in II.E.9; e. Quarterly injection well performance status reports (hereto refered to as quarterly reports),shall document the performance of the injection wells and shall follow the same format that has been used for the DOH's UIC permit. The reports shall be made by a professional consultant, engineer, 15 or geologist proficient in injection well performance. These reports shall include: i. Daily maximum and average injection pressures; ii. The average daily minimum annulus pressure and calculated minimum annulus pressure required to depress the nitrogen /brine interface below 2,000 feet; iii. Daily average injection rate; iv. Total daily quantity, including the break down of geofluids and supplemental water quantities; V. Daily temperature; vi. Any increase in pressure that has triggered the pressure switch on the combined flow injection line; and vii. Narrative descriptions and explanations of any incidence of noncompliance that has occurred. f. Quarterly reports shall be submitted for the reporting periods by the respective due dates as listed below: Reporting Period Report Due Jan, Feb, Mar May 1 Apr, May, June Aug 1 July, Aug, Sept Nov 1 Oct, Nov, Dec Feb 1 Copies of the quarterly reports, all other reports, monitoring and test results required by this permit shall be submitted to the following address: U.S. Environmental Protection Agency Ground Water Office (WTR -9) 75 Hawthorne St. San Francisco, CA 94105 10. Modifications to Monitoring and Reporting This permit herein acknowledges that environmental and facility operating conditions affecting the monitoring and reporting conditions of this permit, including the Hydrologic Monitoring Program and Casing Monitoring Program, could change. This could warrant the EPA's reevaluation of those conditions in order to address changing concerns and to establish relevant analyses. Modifications to the monitoring and reporting conditions, resulting from reevaluations, shall be approved by the EPA. 11. Additional Monitoring and Reporting If the operation of the injection wells is additionally 16 regulated by other pollution control programs, e.g. Clean Air Act, the adherence to the monitoring and reporting conditions of such other pollution control programs shall not be circumvented by the terms and conditions of this permit. 12. Twenty -Four Hour Reporting The permittee shall report any noncompliance which may endanger health or the environment, including: a. Any monitoring, or other information which. - indicates that any contaminant may cause an endangerment to a USDW; b. Any noncompliance with a permit condition, or malfunction of the injection well system which may cause fluid migration into a USDW or between USDWs; C. Any wellhead leaks or overflows from the ESRF pond. Any information shall be provided orally within 24 hours from the time the permittee becomes aware of the circumstances. A written report shall also be provided within five (5) days of the time the permittee becomes aware of the circumstances. The written report shall contain a description of the noncompliance and its cause, the period of noncompliance, including exact dates and times, and if the noncompliance has not been corrected, the anticipated length of time that it is expected to continue; and steps taken or planned to reduce, eliminate and prevent the reoccurrence of the noncompliance. Oral reports to EPA Ground Water Office shall be made to (415)972 -3525 or (415) 972 -3961. Messages can be left at this number for oral reporting that occurs during evenings, weekends, and holidays. 13. Reporting of Noncompliance of Permit Limitations The permittee shall notify the EPA of any exceedances of or noncompliance with limitations and contained in this permit. Permit limitations in this permit refer to, and are not limited to, injectate pressure, annulus pressure, physical parameters, chemical additives, and scheduled events such as analyses, evaluations, and reports. The notification shall consist of a report that shall include: a description of the noncompliance and its causes; the period of noncompliance, including exact dates and times; and if the noncompliance has not been corrected, then the anticipated time it is expected to continue and the steps taken or planned to reduce, eliminate and prevent reoccurrence of the noncompliance.'-The report shall be submitted to the EPA at the time of the next quarterly monitoring report. F. PLUGGING AND ABANDONMENT 1. Notice of Plugging and Abandonment 17 The permittee shall notify the EPA no later than sixty (60) days before further conversion, workover, or abandonment of a well. The EPA may require that the plugging and abandonment be witnessed by a EPA representative. 2. Plugging and Abandonment Plan The permittee shall abandon the well according to the Plugging and Abandonment Plan in Appendix I, and must also comply with the abandonment conditions required by the State of Hawaii and the County of Hawaii. The permittee shall submit any proposed revision to the method of plugging reflected in the plan no later than sixty (60) days prior to well plugging and abandonment. The EPA reserves the right to change the manner in which a well will be plugged if the well is modified during its permitted life or if the well is not consistent with EPA requirements for construction or mechanical integrity. The EPA may ask the permittee to estimate and to update the estimated plugging cost periodically. Such estimates shall be based upon costs which a third party would incur to plug the well according to the plan. 3. Plugging and Abandonment Report Within sixty (60) days after plugging the well, the permittee shall submit a report on Form 7520 -14 in Appendix I to the EPA. The report shall be certified as accurate by the person who performed the plugging operation, and the report shall consist of either: (1) a statement that the well was plugged in accordance with the plan, or (2) a statement specifying the different procedures followed where actual plugging differed from the plan. 4. Well Closure The permittee shall properly plug and abandon, in accordance with the conditions in Part II.F.1 -3, any well that is determined to be a threat to a USDW, either voluntarily or thereupon notification by the EPA. Any injection well that is used for monitoring shall be properly plugged and abandoned once the monitoring is completed. G. FINANCIAL RESPONSIBILITY 1. Demonstration of Financial Responsibility The permittee is required to maintain financial responsibility and resources to close, plug, and abandon all injection wells, including active, temporarily abandoned (idle), and injection wells no longer serving their original function (e.g. injections wells used for monitoring purposes), as provided in the Plugging and Abandonment Plan. a. The permittee has provided an irrevocable standby letter of credit, No. 00652520001454, dated July 29,2004, and standby trust agreement for the estimated cost of plugging the four 18 existing injection wells which is $800,000. b. Demonstration of financial responsibility must be provided to the EPA when the permit is issued and every year by June 1. C. The EPA can periodically,require the permittee to update the Plugging and Abandonment Plan and /ore the cost associated with it. If the updated estimate indicates that the cost of the plugging and abandonment is more than ten (10) percent greater or less than the most recent estimate, the financial assurance mechanism shall be increased or decreased accordingly. d. Prior to the construction of or conversion to a new injection well, the financial assurance mechanism shall be modified to reflect the cost of plugging the additional well. Should the cost of plugging the well, once it is constructed, vary by more or less than ten (10) percent of the original estimate, then the financial assurance mechanism shall be modified accordingly. 2. Insolvency of Financial Institution The permittee must submit an instrument of financial responsibility acceptable to the EPA within sixty (60) days after either of the following events occur: a. The institution issuing the irrevocable standby letter of credit or financial instrument files for bankruptcy; or b. The authority of the trustee institution to act as trustee, or the authority of the institution issuing the financial instrument is suspended or revoked; or C. The institution issuing the financial instrument lets it lapse or decides not to extend it. PART III. GENERAL CONDITIONS A. EFFECT OF PERMIT The permittee is allowed to engage in underground injection well operation in accordance with the conditions of this permit. The permittee shall not construct, operat.e, modify, maintain, convert, plug, abandon, or conduct any other injection activity in a manner that allows the movement of fluid containing any contaminant into underground sources of drinking water, if the presence of that contaminant may cause a violation of any primary drinking water regulation under 40 CFR Parts 141 and 142 or may otherwise adversely affect the health of persons. Furthermore, any underground injection activity not specifically authorized in this permit is prohibited. Compliance with this permit during its term constitutes compliance for purposes of enforcement with Part C of the Safe Drinking Water Act (SDWA). Such compliance does not constitute a defense to any action brought under Section 19 1431 of the SDWA, or any other common or statutory law other than Part C of the SDWA. Issuance of this permit does not convey property rights of any sort or any exclusive privilege, nor does it authorize any injury to persons or property, any invasion of other private rights, or any infringement of State or local law or regulations. Nothing in this permit shall be construed to relieve the permittee of any duties under applicable regulations. If at any time the EPA learns that an injection well may cause a violation of primary drinking water regulations, the EPA shall order the permittee to take such actions as may be necessary to prevent the violation, including, where required, cessation of operation of the injection well. The EPA will issue an order to immediately cease and desist injection upon receipt of factual information that the injection has caused or is likely to cause imminent and substantial danger to the health of a person or persons due to contamination of a public water supply or underground source of drinking water. B. PERMIT ACTIONS 1. Modification, Revocation, Reissuance, and Termination The EPA may, for cause or upon request from the permittee or any interested person or upon the EPA's initiative, modify, revoke and reissue, or terminate this permit in accordance with applicable jurisdictions under 40 CFR §§ 124.5, 144.12, 144.39, and 144.40. Also, the permit is subject to minor modifications for cause as specified in 40 CFR § 144.41. The filing of a request for a permit modification, revocation and reissuance, or termination, or the notification of planned changes, or anticipated noncompliance on the part of the permittee does not stay the applicability or enforceability of any permit condition. The EPA may also modify, revoke and reissue, or terminate this permit in accordance with any amendments to the SDWA if the amendments have applicability to this permit. 2. Transfer of Permits This permit is not transferable to any person except after one of the following actions has occurred at the discretion of the EPA: automatic transfer under 40 CFR §144.38(b); modification under 40 CFR §124.5 and §144.39, including "minor modification" 40 CFR §144.41; or revocation and reissuance of the permit §124.5 and §144.39. To initiate the process, the permittee shall supply written notice to the EPA sixty (60) days in advance of the proposed transfer date and in compliance with the requirments of 40 CFR §144.38. EPA will notify the permittee if a "major modification" or revocation' and reissuance of the permit is necessary to to change the name of the permittee and incorporate such other requirements as may be neccessary under 40 CFR §124, §144, and §146. 20 C. SEVERABILITY The provisions of this permit are severable, and if any provision of this permit or the application of any provision of this permit to any circumstance is held invalid, the application of such provision to other circumstances and the remainder of this permit shall not be affected thereby. D. CONFIDENTIALITY In accordance with 40 CFR § §2 and 144.5, any information submitted to the EPA pursuant to this permit may be claimed as confidential by the submitter. Any such claim must be asserted at the time of submission by stamping the words "confidential business information" on each page containing such information. If no claim is made at the time of submission, the EPA may make the information available to the public without further notice. E. GENERAL DUTIES AND REQUIREMENTS 1. Duty to ComDIV The permittee shall comply with all applicable UIC Program regulations and conditions of this permit, except to the extent and for the duration such noncompliance is authorized by an emergency permit issued in accordance with 40 CFR § _ 144.34. Any permit noncompliance constitutes a violation of the SDWA and is grounds for enforcement action, permit termination, revocation and reissuance, modification, or for denial of a permit renewal application. 2. Penalties for Violations of Permit Conditions Any person who violates a permit condition is subject to civil penalties, fines, and other enforcement action under the SDWA. Any person who willfully violates permit conditions may be subject to criminal prosecution. 3. Need to Halt or Reduce Activity not a Defense It shall not be a defense, for the permittee in an enforcement action, that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit. 4. DutV to Mitigate The permittee shall take all reasonable steps to minimize and correct any adverse impact on the environment resulting from noncompliance with this permit. 5. Proper Opera ion and Maintenance The permittee shall at all times properly operate and maintain 21 all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit. Proper operation and maintenance includes effective performance, adequate funding, adequate operator staffing and training, and adequate laboratory and process controls, including appropriate quality assurance procedures. This provision requires the operation of backup or auxiliary facilities or similar systems only when necessary to achieve compliance with the conditions of this permit. 6. Duty to Provide Information The permittee shall furnish to the EPA, within the time specified herein, any information which the EPA may request to determine whether cause exists for modifying, revoking and reissuing, or terminating this permit, or to determine compliance with this permit. The permittee shall also furnish to the EPA, upon request, copies of records required to be kept by this permit. 7. Inspection and Entry The permittee shall allow the EPA or authorized representatives, upon the presentation of credentials and other documents as may be required by law, to: a. Enter upon the permittee's premises where a regulated facility or activity is located or conducted, or where records are kept under the conditions of this permit; b. Have access to and copy, at reasonable times, any records that are kept under the conditions of this permit; C. Inspect at reasonable times and photograph any facilities, equipment (including monitoring and control equipment), practices, or operations regulated or required under this permit; and d. Sample or monitor, at reasonable times, for the purposes of assuring permit compliance or as otherwise authorized by the SDWA, any substances or parameters at any location. 8. Records of the Permit Application The permittee shall maintain records of all data required to complete the permit application and any supplemental information submitted with the permit application for a period of five (5) years for EPA from the effective date of this permit. 9. Availability of Reports All reports prepared in accordance with the conditions of this permit shall be available for public inspection at appropriate offices of the EPA. Permit applications, permits, and well 22 operation data shall not be considered confidential. 10. Signatory Requirements All reports or other information requested by the DOH and /or EPA shall be signed and certified by a responsible corporate officer or duly authorized representative according to 40 CFR g 144.32. 11. Reporting of Changes and Noncompliance a. Anticipated Changes and Noncompliance The permittee shall give advance notice, of-at least seven (7) days, to the EPA of any planned changes in the permitted facility or activity which may significantly change any injection well operating characteristics or injection well specifications; or which may result in noncompliance with permit requirements. Changes, modifications or revisions in the operation characteristics or specifications of the injection wells shall not be implemented unless otherwise approved by the EPA. b. Other Noncompliance The permittee shall report all other instances of noncompliance not otherwise reported at the time monitoring reports are 'submitted. The reports shall contain the information listed in Part II. E. of this permit. C. Other Information Where the permittee becomes aware that it failed to submit all relevant facts in permit application, or submitted incorrect information in a permit application or in any report to the EPA, the permittee shall submit such facts or information within two (2) weeks of the time such information becomes known. 12. Continuation of Expiring Permits a. Duty to Reapply If the permittee wishes to continue an activity regulated by this permit after the expiration date of this permit, the permittee must submit a complete application for a new permit to the EPA at least one hundred eighty (180) days before this permit expires. b. Permit Extensions The conditions of an expired permit may continue in force in accordance with 5 United States Code (U.S.C.) 558(c) until the effective date of a new permit, if: i. The permittee has submitted a timely application which is 23 a complete application for a new permit; and ii. The EPA, through no fault of the permittee, does not issue a new permit with an effective date on or before the expiration date of the previous permit. 13. Required Immediate and Followun Notifications of Non-permitted Releases a. Pursuant to the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) Section „103 and /or the Emergency Planning and Community Right To Know Act (EPCRA) Section 304, the permittee will immediately notify the National Response Center (NRC) at (800)424 -8802, the Hawaii State Emergency Response Commission (SERC) and the Hawaii County Local Emergency Planning Committee (LEPC) as soon as it has knowledge that there has been a release into the environment of a reportable quantity of a hazardous or extremely hazardous substance. b. As soon as practicable following a reportable release under EPCRA Section 304, the permittee will submit a written followup report to the SERC and LEPC which conforms to the requirements of that section. PART IV. APPENDICES 24 APPENDIX A INJECTION WELL SCHEMATICS 25 36" HOLE 26" HOLE CEMENT ---� 17 -112' HOLE --� 12 -1/4" HOLE 8 -1/2" HOLE FISH: 5745 -6056' — DCs, MILL, DP, STUB OBSTRUCTION @ 5113' PARTED LINER FIGURE 1 CELLAR: 10 FT x 10 FT x 10 FT —.30' CONDUCTOR CEFiIENTED TO SURFACE 70 FT. 20" 94# H -40 BT &C CEMENTED 137&' TO SURFACE —1376 FT 13 -318" 61 # C -90 VAM CEMENTED 2701' TO SURFACE ��— — 2701 FT 7" 29# -80 NEW VAM LINER CEMENTED 4061' TO SURFACE 3131191 5"23,2# L -80 SLBC HANGDOWN LINER SURFACE TO 3776' 9-518'47* C -90 HYDRIL SEU -GS CEMENTED 4061' TO SURFACE LINER HANGER ® 3895' 4061 FT Eli T' 26# C -90 VAM SLOTTED LINER HUNG UNCEMENTED 6505 -3895' i PUNA GEOTHERMAL VENTURE i KS -1 A CASING SCHEMATIC AFTER MARCH 2001 REWORK 6505' TD R. H. DENTON 9:15101 36' HOLE 26" HOLE – —' CEMENT ---i '17- 112" HOLE 12 -1 /4' HOLE 8 -112" HOLE 6895' MD 6823' VD FISH LEFT IN HOLE: 511' OF 6- 112" DCs, MONEL, 8.112- BIT FIGURE 2 CELLAR: 10 FT x 10 FT x 10 FT GROUND SURFACE All depths measured from KB: 25 ft above ground level 30" CONDUCTOR CEMENTED TO SURFACE 70 FT —20' 94# K -55 BT &C CEMENTED 1030' TO SURFACE F - -1030 FT 13 -318" 61# K -55 NEW VAM CEMENTED 2209' TO SURFACE .— 2209 FT 7406' TIMID 7316' TVD 61 JTS 7" 29# L -80 NEW VAM LINER ON TOP OF 33 JTS 7" 29# L -80 BT &C LINER CEMENTED 3724'TO SURFACE 5" 23# N -80 SLHC HANGDOWN LINER SURFACE TO 3806' 9-518'47# C -90 NEW VAM CEMENTED 3897' TO 1972' TIED BACK AND CEMENTED TO SURFACE LINER HANGER oQ 3767' 3697 FT 7" 29# L -80 BT &C SLOTTED LINER HUNG UNCEMENTED 6853' -3767' 6835 FT MD 5764 FT VD PUMA GEOTHERMAL VENTURE KS -3 CASING SCHEMATIC AFTER AUGUST 1999 REWORK R. H. DENTON 1/29100 FIGURE 3 GROUND SURFACE; 618 FT ASL CELLAR: 10FTx 10FTx10FT All depths measured from KB. 25 ft above ground level 30" CONDUCTOR CEM&TED TO SURFACE 42" HOLE 70 FT 20" 94# K-55 BT&C CEMENTED 1054' TO SURFACE 261, HOLE ---Y 4— 1054 FT n 13.319* 51 # K -55 NEW VAM CEMENTED 2043' TO SURFACE CEMENT 9-518,47# C-90 NEW VAM TIE-BACK CEMENTED 1830' TO SURFACE 17 -112" HOLE :N!i!1 9 -518" LINER HANGER TOP @ 1830' 2043 FT 7' 23# SUMITOMO 22 CHROME VAM ACE HANGDOWN LINER SURFACE TO 3800' 12-1/4* HOLE 9-518"47# C-90 NEW VAM LINER CEMENTED 3930' TO 1860' 9-5/8" 47# x 7" 29# L-80 LINER HANGER @ 3838' 3930 FT tail 7" 28# L-80 BT&C SLOTTED LINER HUNG UNCEMENTED 6791-3838' 6 -112" HOLE i TOP JOINT AND BTM 3 JOINTS BLANK ill PUNA GEOTHERMAL VENTURE CLEANED OUT TO 6241 FT KS-4 CASING SCHEMATIC AFTER AUGUST 1999 CLEAN OUT 6796'TD R. H. DENTON 1129100 AN depths am measured from alevation, 27 ft at ground tevel FIGURE 4 Puna Geothermal Venture Well KS -11 RD Schematic of Well Completion After Workover 30-inch Conductor Pipe cemented at 75 IC- - .— -Inch, 168.5 bfft casing Tienled at 1,002 ft h, 97 bM casing Ned at 2,102 ft 74nch, CR -22, 23 bill hargdown finer hung from surface to 3203 ft _ 9.5I84nch, T-95.47 tblfl casing cemented from surface to 3.290 ft - &SWnch. L -80. 36 lb11t liner hung from 4,192 It Window opened on the original 11-374 - �' inch, 65lbM Casing at 4.422 It. Liner blank horn 4,192 to 4,425 h, Worsted from 4.425 to 6,405 It Bottom of 8 -5t 5-inch liner at 6,405 R Top of the fish at 6,430 ft — Well T.D. = 7,950 h Richmond energy SOM/KeS. Inc. `day. 2004 APPENDIX B EXISTING AND PROPOSED WELL PAD LOCATIONS 26 t�TCk itJMiT ' YD+�RDAWG FOFtF� 6 4�0, � i f iOK•t t •.ire fv.rit /'�' so+r..nr wow: rt / PUU70bb� Q'��ee72 660 ?a L L 80 1 0z NO 1 SAO 2D 74 E? ? PGV PLA. Q 13 -t KS -%% i- • a- it Ks -B 0 o \. -4 600 C20 640 #40F_A 550 ~bad 17 AREA OF REVIEW SCALE IN FEET o soo �000 �soo �000 �soo Puna Geothermal Venture's existing and proposed well pads Ov APPENDIX C APPROVED CHANGES AND WORKOVERS Li � PA NAME AND ADDRESS OF PESMME LOCATE WELL AND OLITLINE UNIT ON SECTION PLAT — MO ACRES Tvrta ArrYOVad. OsCS lrc. ]Oi6 —DD�t. VNrTE.D iTATES EWPkUMMtniAL MUILs =1Kw rwtn�y WASMtNGTON. DC ZDW WELL REWORK RECORD aIAME AND ADDRESS OF CONTRACTOR SURFACE LOCATION DESCRIMON 114 of _114 of _ 114 of _ 114 of sevt Township Mg LOCATE WELL IN TWO DtRECiX)NS FROM NEAREST LINES OF OL&&MR SECTION AND ML UNG t Las st un _1L tram 11"I -00 Of OMW *KUM er4 ft from &nA A Pined s.nan WELL ACTMTY Tout Depth Wore Rework � TYPE OF PERMIT t] Bnns ikr� O buIr U&I E O Enhanor0 ltsewKY Tpvl t �� Rsk Arse D Hydrocarbon SDD�raps M�anber d Walls Lee" Name Dsta Rework ComrBanosd Wall NyerrDsr Dote Rswort Cormorted WELL CASING RECORD — BEFORE REWORK Ce�m Gewnt Mormons As+d or Fracture Sus Dos+'n Sws Tft�s From To Tnatnrnt Rewd WELL CASING RECORD— AFTER REWORK(4tdiceeAdditions and CM sOn J Cas•n GRrrn Menem AM or Frsav+ use Wotn t+eii __ Trw From To TesetnwisRaaon DESCRIBE REWORK OPERATIONS IN DETAIL WARE LINE LOGS. LIST EACH TTPE USE ADDITIONAL SHEETS IF NECESSARY log Typo$ IRTe1„�1e CERMICAnON . 1 certify under the persahy of law that /hove personally axsminsd andsm familiar with the information submitted in this document and all o:Techmants and that based on my inquiry of those individuals immediately responsible for obtaining the information, l balieve that the information is true, accurate, end complete. lam aware that them are signif +cantpenah ;es folsubmhting false informat;on, including the possibility of fine and imprisonment. (fief. 40 CFA 144,32). ttAN+E A►tD OFF�CL+.: T .E foiraaa type or lr+nSJxFF r D•►TE SIGNED IN APPENDIX D CASING MONITORING PROGRAM 28 APPENDIX $ PUNA GEOTHERMAL VENTURE PROGRAM FOR MECHANICAL INTEGRITY TESTING AND MONITORING OF INJECTION WELLS July 29, 1996 . 1. INTRODUCTION 2.1 Background Pursuant to Underground Injection Control (UIC) Permit No. HI596002, the U.S. Environmental Protection Agency requires that Puna Geothermal Venture (PGV) comply with this Testing and Monitoring Program (TMP) for injection wells. Monitoring and testing provisions in this TMP are similar in most respects to those in the "Casing Monitoring Program," April 26, 1993 version, which is referenced by title in PGV's current UIC Permit No. UH -1529. (The Casing Monitoring Program related to Hawaii UIC Permit No. uH -1529 was originally dated 11/21/1991 and amended later dated. 4/26/1993.) It is anticipated that this same TMP will be approved and adopted by the Hawaii Department of Health as a replacement for the 1993 "Casing Monitoring Program." Revisions to testing and monitoring provisions in the 1993 "Casing Monitoring Program" have been made as a result of a joint review of PGV's injection well monitoring and testing involving EPA, BLM (as advisor to EPA), HDOH and PGV. The purpose of these revisions is to better accomplish the goal of protecting the groundwater aquifer under the PGV project site, which is considered to be a USDI4. The principle changes in the monitoring and testing procedures are as follows: As described in Section 3.1 of this TMP for wells in injection_ service, the annulus nitrogen pressure will be maintained to keep the nitrogen/wa_ar interface at a depth of at least 2000 ft. g 1 0 The 1993 CMP requires that the nitrogen /water interface be maintained "more than half way down the annulus." Based on a nominal casing depth of 4000 ft., the two criteria are effectively s= the same. • In accordance with Section 3.2.1, the annual casing pressure test of each well will be done by depressing the water level to 3000 ft. with nitrogen while the well is on injection. Annulus pressure drop exceeding 10% in five hours will be considered indicative of a. leak requiring diagnosis and repair. The 1993 CMP specifies that the pressure test be done by depressing the water level to the shoe of the 9 -5/8 -inch casing with nitrogen (while, by practical necessity, the well is shut in.) An annulus pressure drop exceeding 8% in 30 minutes was considered indicative of a leak requiring diagnosis and repair. The principle difference is the increase in length of the test period from 30 minutes to five hours, which makes the nitrogen pressure test equivalent to a 30- minute test with water. 1.2 Purpose The purpose of this TMP is to specify the observations, tests, drilling operations and , if necessary, remedial actions required to insure that the mechanical integrity of injection well casing and cement is maintained through the drilling, testing and operation of PGV wells_ The cemented and hung casing strings that are used in the PGV wells are designed to prevent contamination of any underground source of drinking water (USDW) by injected fluids. Contamination of the USDW' s might occur if the casing strings are breached due to corrosion or mechanical failure or if there is a failure of the cement to seal the •using /borehole annulus between the casing shoe and the lowermost USDW. The testing and monitoring .program described belo --a is designed to detect and drag_.ose a loss of m?cnan? cal _nteg-;ty ?n the casing or cement. _ =g` - Of Remedial actions required to restore mechanical integrity are also described. 1.3 Scope s= This TMP covers all injection wells on the 500 -acre PGV site. 2. TESTING DURING DRILLING AND COMPLETION 2.1 Pressure Testing During Drilling Each injection well is completed with three casing strings (not including the 30 -inch conductor pipe) cemented to the surface (Figure 1). Upon completion of cementing each casing string and prior to drilling out the cement shoe, the casing well be pressure tested. The DLNR will be notified at least 24 hours before each test for the opportunity to witness it. The test will consist of pressurizing the casing with water or drilling mud to a specified test pressure and monitoring the pressure for 30 minutes with the well shut -in: The minimum casing test pressure shall be approximately one -third of the internal yield pressure rating,- provided that the test pressure shall not be less than 600 prig nor greater than 2500 psig. In cases where combination strings or liners are involved, the above test pressures shall apply to the lowest pressure -rated casing. The pressure drop during the 30- minute period shall not exceed 10% of the test pressure. In the event of a pressure loss exceeding the above criterion, one or amore of the following diagnostic methods will be used to locate the leak: - Temperature log while injecting - Shut -in temperature survey - Casing inspection logs with multi -arm caliper and /or magnetic inspection tools - Pressure test=ing with a packer(s) on drillpipe - Other applicalDle methods After identifica_io.i o_ t he poir*_ of leakaae a cement sglaeeca job -..ill be and the cas -n-* Ct?5r..-_.. After a successful pressure test of each casing string, drilling will proceed to a point at least one foot below the casing shoe, and a pressure leak- off test will be performed to test the integrity of the annular cement. Each test will be perfox-med at a pressure approaching the fracturing pressure of the exposed formation. If there is excessive leak - off, a squeeze cement job will be performed, the cement will be drilled out and the test will be repeated. Drilling will not proceed until: an effective cement seal is established in the casing /borehole annulus above the casing shoe. In some situations, such as the case where there is natural formation permeability immediately below the casing shoe, it may not be practical to prove cement integrity with the pressure test described above. As an alternative, a standard water shutoff test (WSO) may be done above the shoe, or shut -in temperature surveys may be run. 2.2 Logs and Surveys During Injection Testing Upon completion of drilling and prior to installation of the hangdown liner, a water injection test may be performed, if needed, to obtain a preliminary evaluation of the well. During such a test, one or more of the following logs or surveys may be run: - TPS or T/P Logs through the open hole and cased intervals with the-well on injection; or - Shut -in temperature survey(s) before and /or after injection. If any of these logs or surveys indicates a loss of mechanical integrity, the problem will be diagnosed, and repair procedures will be performed in accordance with Section 2.3. 2.3 Casing Repair once a loss of mechanical integrity is identified and approximately located, casing repair procedures will be ipitlated. These procedures may include any or all O-f %hn_ fo11oa ng act? v l..� es Q� 4 2.3.1 Shut in well and run magnetic and multi -arm casing inspection logging tools to locate the leak and to evaluate the casing condition. 2.3.2 Rig up workover rig on well. Run packer(s) on drillpipe and pressure test to confirm suspected leaking interval. 2.3.3 Execute cement squeeze job to seal casing leak or stop interzonal flows behind casing. 2.3.4 Perform casing pressure test and other diagnostic tests as necessary to confirm success of the xemedial work. If good, move rig off well and return well to injection service. 2.3.5 In the event of major casing failure, a cemented liner may be installed through the damaged interval. 2.3.6 Prior to drilling out the liner shoe, the liner will be pressure tested as described in Section 2.1. 2.3.7 If mechanical integrity cannot be restored satisfactorily, the well will be plugged and abandoned. 3. MONITORING AND TESTING AFTER WELL IS PLACED IN SERVICE 3.1 Continuous Monitoring During Routine Injection Operations During routine injection well operations, including brief periods when well(s) may be temporarily out of service, the following conditions will be maintained: 3.1.1 A continuous recording of the following naraii,eters :,ill be ;maintained for each W e 1 1 ,n °ct on .;ellheaa pre---'�r= , en) Dre These parameters shall be recorded on a graphical chart which shows their relationship to elapsed time. Plant operators will take daily readings at each well. 3.1.2 The annular space between the hangdown liner and cemented casing will be pressurized with nitrogen, and the pressure will be monitored and recorded in accordance with Section 3..1. above. The annulus will be repressurized with nitrogen as necessary to maintain the nitrogen /water interface at a depth of 2000 ft KB (1975 ft below ground level) or deeper. some loss of nitrogen pressure is normal, and occasional reprassurization will be required. If the rate of nitrogen pressure decline is such that it is impractical to maintain the required minimum pressure, it will be considered indicative of a leak requiring diagnosis and repair. 3.2 Annual Testing Once annually, tests and surveys will be conducted to verify mechanical integrity of the hangdown liner. The casing and hangdown .liner will be tested for leaks by one of the following procedures, or a combination thereof. 3.2.1 Perform a pump -down test on the annulus between the hangdown liner and the cemented casing. The test will be done with the well on injection at normal operating flow rate and wellhead pressure, or higher. or 3.2.2 If the hangdown Liner is pulled, the casing may be pressure tested above a bridge plug or packer set near the shoe following the basic procedure outlined in Section 2.1. Integrity of the hangdown liner may be ,verified by inspection on the surface, by pressure test ( ,,.'Ji th nitrogen) after i i t s run in the hole, oY b_,: _ TPS jog ai t— t­ e cell on _*iJ ecti o . Integrity of the cement (external mechanical integrity) will be checked during each workover by one or more of the following procedures: 3.2.3 one or more shut -in static temperature surveys will be run. Shut -in time will be at least 12 hours, or longer if necessary to obtain meaningful results. or 3.2.4 Other logs or surveys. may be run. at the discretion of PGV, if static temperature surveys are not definitive. 3.3 Restoration of Mechanical integrity or Abandonment In the event that the diagnostic procedures indicate a loss of mechanical integrity, remedial or abandonment procedures will be carried out as specified in Section 2.3. APPENDIX E INJECTION PRESSURE LIMITATIONS FOR NEW WELLS 29 APPENDIX F CHEMICAL ADDITIVES Note: Some of these products may not currently be used, but are approved for use. Product Name and Function. Chemical Ingredient Amersite (R)2 Sodium Bisulfite Corrosion Inhibitor Wrico Oxy 11 Sodium Sulfite Corrosion Inhibitor Ethylanediamine Tetraacetic Acid Sodium Salt WPD 11 -306 (Tm) Dimethyldioctylammnonium Chloride Corrosion Inhibitor Soya Amine Polyethoxylate Cyclohexylamine West R -322 Polyamideamine Acetate Corrosion Inhibitor POE (15) Tallow Amine Midland 203 Sodium Metabisulfite Oxygen Scavenger Colbalt Compounds Millsperse (R) 802 Poly (Maleic Acid) Anti - scalant Sodium Hydroxide Sodium Hydroxide pH Adjustor and H2S Abator Drew 11 -480, Soya Amine Poly Corrosion Inhibitor Royal Purple Synthetic Lubricant Barrier Fluid Catalyzed Sulfite Sodium Sulfite, Benzoic Acid Oxygen Scavenger Drew 11 -575 Sodium Chloride Anti - Scalant Phosphoric Acid Derivative Biosperse 250, Magnesium Nitrate, Cupric Nitrate Microbiocide Magnesium Chloride 2- Methyl -4- Isothiazolin -3 -One 5- Chloro- 2- Methly- Isothiazolin -3 -One Sulfuric Acid Sulfuric Acid Anti - Scalant 30 APPENDIX G HYDROLOGIC MONITORING PROGRAM 31 PUNA GEOTHERMAL VENTURE HYDROLOGIC MONITORING PROGRAM December 2005 Sampling Locations: The following wells will be monitored. Well Name Elevation WSL) Completion Depth (MSL MW -1 610 -46 MW -2 588 -2 MW -3 (standby) Frequency: Regular sampling shall occur twice a year, once in January and once in July. Water Level Measurements: Prior to bailing or pumping the well and sampling, water level measurements will be taken and recorded. The permittee can use an Echo Meter or similar device, or an electronic direct contact detection probe with a calibrated cable /tape for direct measurement at the top of the well casing. Calibrated cable /tape length shall be sufficient to measure water levels in the deepest wells. The metering device shall be equipped with an audible signal and light to indicate water level contact. Quality Assurance /Quality Control: Quality assurance /quality control procedures will be in compliance with standards of practice for similar programs relative to the acquisition, reduction, verification, and validation of the site data. At each location, standardized equipment cleaning will be conducted prior to obtaining each sample. Prior to ground water sampling, the well will be bailed or pumped at least three times the wellbore volume. All samples will be taken and field analyses conducted in accordance with standard protocols approved by the EPA. An EPA or State of Hawaii certified laboratory will be used to conduct the analyses for samples submitted. Samples will be transferred from the sampling device directly to appropriately prepared containers supplied by the laboratory. Samples will be labeled, stored and transported in a chilled state in insulated containers to the laboratory. In the analyses, detection limits will be used that are below maximum contaminant levels. If they are not, the sampling and analyses will be repeated using the proper detection limits. The contractor will provide a copy of their Quality Assurance program to DOH and EPA for review and approval. Physical and Chemical Parameters: Field analyses will include: - pH - temperature - conductivity - salinity - chloride concentration - water level These measurements will be obtained by using calibrated instruments specifically designed to 1c11r directly measure these physical and chemical parameters within the operational constraints dictated by site conditions. The inorganic (Type I) and organic (Type II and IV) constituents that are to be sampled for are specified in Appendix H. Reporting: Sampling results and measurements will be submitted during the February following the January sampling, and the August following the July sampling. Original laboratory reports will be included with a cover letter. Reporting units shall be specified. The laboratory shall not use text descriptions, such as "Below Regulatory Limits" or `BRL ", in its reporting, but rather, the actual numerical results will be reported. If the actual numerical results are not reported, the sampling and analysis will be redone until numerical results are reported. Further Monitoring: If leakage of the injectate into the USDW is suspected., the ground water sampling may be modified. Depending on the situation, this could include sampling from Malama Ki and GTW -III, sampling for certain analytes and more frequent sampling. 33 APPENDIX H CHEMICAL AND PHYSICAL ANALYSIS PLAN FOR INJECTATE TESTING Type I samples will be collected once every two months starting in January, and Types III and VI samples will be collected twice a year, once in January and once in July. A cooling coil shall be used to properly cool the samples during collection. 34 TABLE NO. 2 TEST PARAMETERS FOR TYPE I SAMPLE P- arameter Method A..Y'senic (As) 6010/206 B-arium (Ba) 6010/208 Boron (B) 200 Ceachium (Cd) 6010/213 Calcium (Ca) 6010/215 C4opper (Cu) 6010/220 Chromium (Cr) 6010/218 I.zon (Fe) 6010/236 L -ead (Pb) 6010/239 Lithium (Li) 6010/7430 Magnesium (Mg) 6010/242 M•enganese (Mn) 6010/243 Mercury (Hg) 7470/245 Nickel (Ni) 6010/200 Pr.-.)tassium (K) 6010/258 S ver (Ag) 6010/272 Sodium (Na) 6010/273 Vanadium (V) 6010/286 Zj.nc (Zn) 6010/289 B_somide 320 Bacarbonate (HCO3) 310 Cz:arbonate (CO3) 310 CE-iloride 325 F= uoride 340 Nitrate (NO3) 352 Ssli.ca (Si02) 370 Sazlfate (SO4) 375 Total Sulfur (S) Various Total Alkalinity 310 Total Dissolved Solids (TDS) 160.1 Tc_,tal Suspended Solids (TSS) 160.2 0--,'-. 1 and Grease 413 or 1664 CUnductivity 120 PERMIT NO. UH -1529 Issued March 28, 2003 Page 25 of 27 Gas Parameter Ammonia (NH3) Argon (Ar) Carbon Dioxide (CO2) Hydrogen (H2) Hydrogen Sulfide (H2S) Methane (CH4) Nitrogen (N2) Oxygen (02) Radon N- Pentane A'_1 methods listed are EP.F or EPA equivalent, unless otherwise noted. TABLE 1q0. 3 TEST PARAMETERS FOR TYPE III SAMPLE Parameter Ignitability Corrosivity Reactivity Inorganics: arsenic barium cadmium chromium lead mercury selenium silver Organics: benzene carbon tetrachloride chlorobenzene chloroform o- cresol m- cresol p- cresol 1,4- dichlorobenzene 1,2- dichloroethane 1,1- dichloroethylene 2,4- dinitrotoluene hexachlorob,enzene hexachloro -1,3- butadiene hexachloroethane methyl ethyl ketone nitrobenzene pyridine tetrachloroethylene trichloroethylene 2,4,5- tricblorophenol 2,4,6- trichlorophenol vinyl chloride Regulatory Level (mq /1) PERMIT NO, iIH -1529 Issued March 28, 2003 Page 26 of 27 Methoa As described in 40 .CF}t (1998); Part 261.21 Part 261.22 Part 261.23 Method 1311 (TCLP), 5.0 with appropriate 100.0 methods of analyses 1.0 contained in SW -846 5.0 i 5.0 i 0.2 i 1.0 i 5.0 i 1 1311 0.5 0.5 100.0 i 6.0 i 200.0 i 200.0 i 200.0 i 7.5 i 0.5 i 0.7 0.13 0.13 i 0.5 i 3.0 i 200.0 2.0 5.0 0.7 0.5 i -00.0 i 2.0 i 0.2 i TABLE No. 4 TEST PA"— *TIETERS FOR TYPE IV SAMPLE Parameter Volatile Organics Benzene Bromodichloromethane Bromoform Bromomethane Carbon Tetrachloride Chlorobenzene Chloroethane 2- Chloroethylvinyl ether Chloroform Chloromethane bibromochloromethane 1,2- Dichlorobenzene 1,3- Dichlorobenzene 1,4- Dichlorobenzene 1,1- Dichloroethane 1,2- Dichloroethane 1,1 Dichloroethylene trans- 1,2- Dichloroethene 1,2- Dichloropropane cis -1,3- Dichloropropene trans -1,3- Dichloropropene ' Ethyl benzene Methylene chloride 1,1,2,2- Tetrachloroethane Tetrachloroethene Toluene 1,1,1 - Trichloroethane 1,1,2 - Trichloroethane Trichloroethene Trichlorofluoromethane Vinyl Chloride PERMIT NO. UH -1529 Issued March 28, 2003 Page 27 of 27 Method 524/624/8240/8260 APPENDIX I PLUGGING AND ABANDONMENT PLAN Upon completion of injection activities the well will be abandoned according to Federal, State and County regulations to ensure protection of Underground Sources of Drinking Water (USDW) . 35 rormAxoxo -v —ar /To zcrsr^.Z +� anoro.ai F:p�t p o .xj- UNITED STATES EI `MFlONRAENTAL NOTECTION AGENCI' r's WA ZI- 41IGTON. aC 20 -60 �E -PA PLUGGING ANt) ABANDONMENT PLAN kME AND ADORESS OF FACILITY >uua Geothermal. Venture .4 -3860 Kapoh.o -pahoa Road lahoa, HI 96778 IV"E AND ADDRESS Of O"ER/OPERA."OR Puna Geothermal Venture P.. O. Box 3 0 Pahoa, HI 96776 LOCATE WELL AND OUTLINE UNIT ON SECTION FLAT -- 640 ACRES N/A N ! ! I I I ! STATE z COUNTY Hawaii PERMIT UMBER i SURFACE LOCATION DESCRIPTION 1/4 of 1/4 of _ 114 of N /,�/4 of Section__ Towneh)p_ • ftnpla LOCATE WELL IN TWO DIFMCMIIS FROM NEAREST LINES OF OUAIRTER SECTION AND DRILLINGUN rr 9W,„9 ft N. and 9919.0 ft E of Kaliu Benchmark ioestiars ft, from INrsI —Una of q"rw •ems+ end —it. from E Uroe► Uerler eeruon I I I I I £ TYPE OF AUTI CR ZA'11t7N Q Individual Permit _ 0 Area Permit O Rut, Number of Wel(a loos* Nam. Xapoho State WELL ACTiVFTY 0 CLASS f M CLASS It 0 Brine Disporeel 13 Enhanc*d 0 H diocorbon Stc give D CLASS 111 -x C.iasS V w *II Number zA I I I { I I s CASING AND TUBING RECORD AFTER PLUGGING left METHOD OF EMPLACEMENT OF CEMENT PUGS OThe "once Method I] the Dump R tlar Method 0 The Two -Piup M *thod 0Other SITE WT(LB /Fn TODEAkINWELLIFTI O SE IM IN WEU (M ODLE SIZE lit 94 0-1376 2 6 t' '.all 61 0 -2200 17 2" 5 47 0 -4061 12 1 4" i(/ �26&29 C3895-6 5 8 CEMENTING TO PLUG AND ABANDON DATA: PLUG 91 PL11G 02 PLUG rr3 MUG " PLUG R6 PLUG 116 PLUG x7 e or Hole or Pips 4% wh;ch Pf" will 6e Pleeed linchesl 8 1/2 _ 7 — 6 - 2 6-184 6.18 4 6.184 6.184 Plh ro avrlom of Tubing or Orl)) Pipe 111•) 4800* 3 510 3 010 2300 15 5 0 170 -Ls or Cement To Be Used (sech clugl 293 4 2 52 28 39 24 illy Volume To Be Pumped (cu. h•) 475 6 8 95 46 153 3 9 ICU1a[ed ToO Of Plug IK•) 13795 134 2640 210 0 11276 0 tesured Too 01 Plug (k teggod tt,) " irry M. (Lb. /Gel.) 15 . 5 15.5 15.5 15.5 15.5 15.5 ae fwm.M or Olt-or Moterrel Cle" 1111 g W d -{- Oil UST ALL OPEN HOLE AND/OR PERFORATEO INTERVALS ATtD INTERVALS WHERE CASING WILL vE VARIED (Reny) From To r)vm To 4061 6505 "i-coC Cori to Plug Wellt -- - _ $1051000 - $150,000 CERTIFICATION 1 certify under the penalty of la >•v chat /have persona fly exarn in e and em familiar WfTh the in fornl atien sub.:,rr:ed in this document and efi arrsr- h.-nents and that, based on my inquiry of those i,ndivicuais 1r,--lediately r_esp, :snsibie for o5ta r1in,R, The information, i fbe /i _eve that the in(ormaron is true, accula:_°. lain a4V-A- e ' L: t there are 31 ^rYl ?iCEr7tO8F�life5 ` J.'SU1Jr^f'r ^y ^r3iSe/nr�r„r °:!J r. ?CIJ1 y :'n' doss ��iry pr f�r.a and ir!.�- /SOC,r78ri. j��f CF , 144.. .. ..• "c AK]0 =. _.�._ _..�:Ild�?ca :. .T .,�'1 y•a`i�—.: •':_ �� �Sia�• °_� N ^ME AND ADORESS OF FACILITY Pupa Geothermal Venture 14-3860 Kapoho- -Pahoa Road fort" /SAD yL ?d. UMU ^l0. .i:13�LY1 +'..� :sff a.•lr• UNITED STATES EKVIRONME`1TAL"uICL-11 NAGE,44,1 WAS►QINGTON, OC 2U150 PLUGGING AND ABANbQNMENT PLAN NAME AND kDD*LM OF OWNER/OPERATOR Puna Geothermal Venture P .O Bo>v. _30 VmhnA _ 141 96778 ra Lv—I STATE COUNTY PERMIT NUM9c; LOCATE WELL AND OUTLINE UNrr ON HT Hawaii SECTION PLAT -- li+IO ACRES NIA SURFACE LOCATION MSCRiPnDN IVA 114 of 1/4 of Section Township_ • FdAng'�_ 1 /d of 114 of __ ____ fJ LOCATE WELL IN TWO DIRECnONS FROM NEAREST UNES OF QUART ER SEC'nON AND DRILUNGaNI T 3s ft N and 9430.2 ft E of Kaliu Benchlt�aLrk I I � I I I Lacetbn tL f,em (N/s1 L)M d wel� e+�ion . end__1t.ftom E Ur+eef wrtereealon TYPE OF AUTHOFIVATION WELL ACTiYRY I I ( I I I O (Tldlviduel Permit D CLASS I w E } a ro C�CAre Permit - D CLASS II O 17 Brine Llieposel E3 Enhanced Recovery I I I I I Number Of We115 0 Hydrocarbon Stof6gs D CLASS 111 x C3.aS5 V I I I I I I Leese NsmeKapoho State Well Number 3 5 CASING AND TUBING RECORD AFTEA PLUGGING M5[HOO OF EMPLACEMENT OF CEMENT PWG5 1e f The EWIsnos Mwthnd SIZE WT(LJI /FT1 TO 6 M WELL" 0 8E UFr lrt WELL(M HOLE SIZE [] The Dump i3e(lor Method 20" 4 0-11130 It I1 The-Two -Plug Method 61 0-2202- �l LJ t71}1eT 17 1 19 y 8" 47 ,r 12 1 1 ,r r T• - 6535 0-3724 CEMVNMNGTO PLUG AND• ABANDON DATA -- 11 PLUG It PLUG a2 PLUG M3 PLUG MA See of Hole or Pipe In whleh P1 Will 64 Placed (;r4has) d 6. Davp,h to 00"-M of Tulslno or Drill Pipe Ih.) 't 7660 -2309 11-330 sacLz al Camern To Be U"d leech v)ual 4 65 28 2 Slurry Volume To 6e pumped leu. h.) 4 In Celeulared Top of Plug )tl.) - 4 , Mesaured Too of Plug ()1 Legged tL} Slurry VA. (Lh. /Gel.) - 5. 5 S T C6menl or Chkw Meloriol Clem 111 ,1 LIST ALL OPEN HOLE ANC /oR PERFORATED INTERVALS AND tNTEItVaLS VYHERE tJ�SINti WILL ESE vARI>:D p+ ear! from To f +orn To - 3897 683 1 TO Prue wells $110,000 — $155,000 ** CERTIFICATION I certify under the pe ^atty of Isw that 1 have Personally examined snd am famif r with the informP(�c subrnr°ted in this dn^_umenr and ail ettachr-lents and rha :, based on my inqu;,-y of those inc"''duc.'s ;rnr^edi3 :ely rLsponsibie for nbtaininy th>? irforms:ion, I believe Thal the infor- sailor, is true. eccurar�• d li^ COmD +d fe, I am aware thst ihefe Are srgr?r7r�6r't penshles {orsuor7rr:rns false inform °tin, ! G' +J^iI,_ n,{ ' ice„ 1 y' Df Ilii4 a r:u if'^�vr ?S.7I':i)$ %ii• 1%�L` '� C�� a. sl'?y Jae: .y �� 5 '•�'+4i;. : Sri Farm A_,, -rraci U,HB No 1t.a0-0G• y't¢ires b 3�' U?itT:D STATES EM ACINMENTAL- OTEC.10ij AGp.yC1' D W SN1t+GTON, DC 20480 JE [_ PLUGGING AND A13ANDONM* ENT PLAN E AND ADDRESS OF FACtUTY a Geothermal Venture X473860 Kapoho -Pahoa Road ?ahoa, HI 96778 NAME AND ADDRESS Of- OWNER/CIPERATOR Puna Geothermal Venture P.O. Box 30 Pahoa, HI 96778 LOCATE WELL "D OUTLINE UNIT ON N/A SECTION PLAT - "0 ACRES STATE HI COUNTY Hawai i ' PERMrT NUM$ER SURFACE LOCATION DESCRIP11GN 1/4 of _114 of 1 NO 11.4 of Section ` To%whship— 1110"01- E �-- -�— r--�-1{ 1 I ( LOCATE WELL IN TWO DiRECMNS FROM KF REST tJNFs OF CIA RT"ER SECTWN AND ORiuING UNrT 2899.0• ft N and 9360.9 ft E of Kalilu Benchmark Loea ►ion _k h,om JN /s: Ume o! yuert "=)on end _N. from E tocilon fI TYPE OF AUTHORl2AT)DN 0lndividual Permit )@ Arsa Permit 0 R.T. Number of Wells Lease Name KapohO State WELL ACrTVrTY ❑ CLASS I d CLASS Il 0 Brine Disposal Q Erwhanced Recovery ElHydi=arbon Storage 0 CLASS III x Class V 4 Wall-Number I I I I I I N I I I I I I { I I f{ f s SING ANO TUBING RECORD AMR PWGGING METHOD OF EMPLACEMENT OF CEMENT PLUGS �I The Balance Method ❑ The Dump Bailee Method 0 The Two -Plug Method DOther , SrZE WTILB /FT) TO BE PLR IN WELL (FIT TO BE LEFT IN MU. fFTI HOLE S&M 0" 94 0-1054 2 11 18" 61 0 -2043 7 - " 5/8" 47 0— 9 'f 7'+ 1 .29 CEMENTING TO PLUG AND ABANDON DATA; PLUG It PLUG R2 PLUG 43 rLMG w t PLUG x6 PLUG MB PLUG r7 Ltd of Note or Pipe in which PSuq_Will Be Placed (inchasl .vttt to Bottom of TuDing of Oflll Pipe (h -i -- 6210* 170 acts of Cement Te 131 Us*d 739 15 56 47 luny Volume To Be Pumped (cu. h.l 1193 18.7 90 77 alcul -md Too el Plug t10 3738 1 7 3 0 954 0 Isasur -d Too of Plug Or tovaed h "► lu" Wt. 1Lb. /Gal.l 15.5 15.5 15.5 15.5 rpe Cement or Cht-r Materiel (Class 1111 xawa L an ^} IIJO%.sillca f io r LUST ALL OPEN MOLE ANO /OR PERFORATED INTERVALS Alto INTERVALS W14CRE CASING WL1L BE VARIED (if any) Prom ad Cost to Plug Wells $125,000 -- $170,000 ** To CERMFICATI O N I cenrify under the penalty o(/-5 w rhar I hays per sonafly examined and d l {arrtifiar with he info r.- na:iar s0On7A,"Qd in This documerrr and alt s rschmen:5 and 1hsr, Lased on my i!ry^L.'1ry of those individuals i- Imedisf ly responsible for oAt °rniny^ rile inforrna?riDn. I believe rll2r the illforrmanti7r; is and comple;a. I air-, aylsra rha' rh_re are signi''f_an' per, -9 iaS (Or 5 infor;- nlrion• tntl�'di- r trTy cf fin!' .'"iRv 1T;17r.SO77.7t �,'7 i. (7 °'r. =:? Cr,7? i .�,,.;• �� Form Approved WAS No. 2040.0012 �+ United Slates l;nvlrohmontal Protection Agency - \`WJEPA Wa9hing(on, OC 20460 PLUGGING AND Ai'3ANDONMEN7 PLAN Monte and Address of Facthly amp and Addre of Ownu Op ator Puna Geothermal G; l Venture Geonesma� denture 14 -3860 Ka oho Pahoa Road 14 -3860 Kapoho Pahoa: Road Pahoa, HI 6778 Pattodr HI 96776 Stott County Sec Permit Nur+tber i Wolf artdOu11lhe Upl1 Op Hawaii. Iiawaii EtI596002 sctllo n Plat • 640 Aires N Surface, Location DezcripUod W 11.2 of __ 114 01 tt4 a(__ 114 of Sacllon _• Township ____ Range Locate wolf In two dtroeltonz Rom nasreat Imes of quortar section end drilling unit + -r--t- - t -r-�t- Lecatlon ___ fl frm (HIS) __- Line of quarter scctlon and _ _ t6 from (EIW) ­ Line of duarlot section. E TYPE OF AUTHOR=41i0H WELL ACTIVITY 11100 11.2 of __ 114 01 tt4 a(__ 114 of Sacllon _• Township ____ Range S LNSS Name We,ll Number ICS -11 - CASINQ AND TUBING RECORD AFTER PLUGGING METHOD OF EMPLACEMENT OF CEMENT PLUGS 912E WT 1LBfFT) TO 6E PUT IN WELL (FT) TO DE LEFT 10 WELL (FT) HOLE SIZE The, Balahc. Method 22 106.5 0.- 00 E]-1 The Dump Salter Method 16 G-2102 0 EJ The, Twa.Plug Method 0 --5061 14 3/4 ❑ olh., O 10 5/8 CEMENTING TO PLUG ANO ABANDON DATA: PLUG 01 1 PLUQ #2 PLUG sa 1 PLUO 94 PLUG dS PLUG 06 PLUG 117 Size of Hole, or PIPS to Whitt, Plug Will Be placed (Incite Locate wolf In two dtroeltonz Rom nasreat Imes of quortar section end drilling unit 10. A479.72 :Et N. and 9601.32 ft E of Kaliul Bench Lecatlon ___ fl frm (HIS) __- Line of quarter scctlon and _ _ t6 from (EIW) ­ Line of duarlot section. E TYPE OF AUTHOR=41i0H WELL ACTIVITY 11100 r-ry 0 Individual Permit E_..l CLASS 1 Area Parmll © CLA99 S Rule a Brtn♦ Dlaposel 1100 Number of Wells ❑ Enhanced Recovery Hydrocarbon Storage Slurry Volume To Be, PwrI Jr.. fl) Q CLASS lif S LNSS Name We,ll Number ICS -11 - CASINQ AND TUBING RECORD AFTER PLUGGING METHOD OF EMPLACEMENT OF CEMENT PLUGS 912E WT 1LBfFT) TO 6E PUT IN WELL (FT) TO DE LEFT 10 WELL (FT) HOLE SIZE The, Balahc. Method 22 106.5 0.- 00 E]-1 The Dump Salter Method 16 G-2102 0 EJ The, Twa.Plug Method 0 --5061 14 3/4 ❑ olh., O 10 5/8 CEMENTING TO PLUG ANO ABANDON DATA: PLUG 01 1 PLUQ #2 PLUG sa 1 PLUO 94 PLUG dS PLUG 06 PLUG 117 Size of Hole, or PIPS to Whitt, Plug Will Be placed (Incite 10.5 5 10. Depth to Bottom of Tufring e, 0,111 Pipe (R 5.900 2#200 11100 1175 Saeka of Ceti»nt To Bo Ueod (oaeh PlugI 115 1100 Slurry Volume To Be, PwrI Jr.. fl) 7,000 6 Colcvlated Tot, or Plug (ft.) 4, 150 2-600 600 900 0 Measured Top of Plug Itt tapped ft.) Slurry Wt. (LDJGkL} Type Comont or Other Material IClns; 111) LIST ALL OPEN HOLE. ANOfOR PERFORATED INTERVALS AND INTMVALS WHERE CASING VALL BE VARICO (it any) To 1 4,3UU I 71JVU I I II noted Cost to Plug Walla $170,000 - $200,000 Certification I zG,Wy wider ((ti pensvy of fav, that I have par52notly ox3mined end am fars+'Itar With tho iltfarm3(l0h submitted th thts docomonl and all oltaehment9 end th Al, bi.ed e, my )nqulry of iheaa InM- Adunl% (ro me dill to ly rasponelb)s for 3t,%;imn3 the in ienn it lot, I Do! a 0.4 the !nlernatlor- le t;L;, at:ut3fj. end corrplcte. 13rh s+vAre that there are algntflcant gen9ttta5 Fo, n•,SmitUn2 lalso Infac•nat:on, Ine!udlrg tho pogs%vIilty of (Ina and Imaris3nmen f. (Ref. d. V;; 133_312) and •DN'165' T!L i :yp: or prin.') S. 'u ro Date digtl:d 5; LL,' Zue= \It,&I i�L�;'�!i; >1 f? �C} cna j/n` ✓, _ y -v .rvi +�fi•7A APPENDIX J DEFINITIONS (a) "Facility or activity" means any UIC "injection well" or any other facility or activity that is subject to regulation under UIC rules. (b) "Fluid" means any material or substance which flows or moves whether in a semisolid, liquid, sludge, gas or any other form or state. (c) "Injection Pressure" means gauge pressure measured at the wellhead. (d) "Injection Well" means a well into which subsurface disposal of fluid or fluids occurs or is intended to occur by means of injection. (e) "Rework" means any recompletion of a well, deepening or redrilling (side - tracking) of a well, or other repairs, maintenance or modifications. Such activities commonly include a drilling rig. (f) "USDW" means "underground source of drinking water" as defined in 40 CFR, Part 144.3. (g) "Well" means a bored, drilled or driven shaft, or a dug hole, whose depth is greater than its widest surface dimension. 36 APPENDIX K MODIFICATIONS 37