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HomeMy WebLinkAboutCOM 0185.000 2014-2016From the office of - Council Member District 4 — Puna Makai MEMORANDUM DATE: March 2, 2015 GREGGORILAGAN 25 Aupuni Street, Hilo, Hawaii 96720 TO: Dru Kanuha, Chair ,�o/' FROM: 6�Greggor Ilagan, Council Member Office: (808) 965-2712 Fax: (808) 965-2707 Email. gilagan@hawaiicounty.gov SUBJECT: I:)iscussion regarding Puna Geothermal Venture's use of Best Available Control. Technology to reduce noise emissions I am requesting a discussion with the Planning Director regarding Puna Geothermal Venture's compliance with Condition No. 20 of Geothermal Resource Permit No. 2, regarding the following requirement: "20. 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 taking into account what is practical and economically reasonable. BACT shall be determined by the Planning Director upon recommendation of the noise consultant." `The discussion will focus on the recommendations of the noise consultant and those Best Available Control Technology measures that have been authorized by the Planning Director, as stated in the attachments. I am requesting that this discussion be placed on the appropriate Committee agenda for March 17. 2015. I estimate that this discussion should take about 30 minutes. GI:ps Att. Hawaii County Is an Equal Opportunity Provider And Employer Comm. No. [ a Ref. To. 5 �- *,.f. outq R 0 Y. Ebisu & Associates Acoustical and Electronic Engineers 112612th Ave., Room 305 + 1 Honolulu, Hawaii 96816 Ph. (8U8) 735-1634 — Fax (808) 732-0409 e-mail: ebisuyassocCaol.com February 11, 2015 Hawaii County Planning Department 101 Pauahi Street, Ste. 3 Hilo, HI 96720 Attention: Mr. Duane Kanuha Planning Director SUBJECT, PUNA GEOTHERMAL VENTURE (PGV) KS -16 DRILLING PROJECT, NOISE MONITORING & MITIGATION EFFORTS Dear Mr. Kanuha: The following letter report contains my findings and recommendations for noise control measures which should be utilized to minimize noise from drilling operations at KS -16, based upon my previous findings, studies, and analysis of prior well drilling experience, and information on well drilling components and related noise abatement measures from PGV. Condition No. 20 of GRP2 states: "20. 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 taking into account what is practical and economically reasonable. BACT shall be determined by the Planning Director upon the recommendation of the noise consultant." While the drilling rig to be used during the KS -16 drilling operation will be identical to that used during the KS -15 and KS -13 operations, the KS -16 drilling operation will more closely resemble that of the KS -13 drilling operations. Both the KS -13 and KS -16 sites are approximately 80 feet lower in elevation than the KS -15 site; the KS -13 and KS -16 sites are relatively closer together; and both the KS -13 and KS -16 drilling operations will have the sound attenuation benefits of sound barrier curtains and numerous other operational enhancements that PGV will be initiating. PGV has considered a number of noise abatement methods, including community input in developing its noise mitigation methods. In locating the site for KS -16, PGV conducted analysis of surrounding terrain and elevations for locating the drilling site. In essence, the existing plant -� E3 2015 13y.._, S922 and wellhead locations, together with natural terrain, will help to buffer and shield noise emissions from drilling operations. Enclosed for your review and information are photographs marked up with the existing locations of all geothermal wells and power plant equipment, see Attachments IA & 1B. Also included are photographs depicting the physical location of the proposed new geothermal well KS -16, see Attachment 2. Please note that the physical location of KS -16 is situated approximately in the middle of existing wellfieid and power plant equipment. To the east of KS -16 lies the original power plant, which is physically about 60 feet higher in elevation than the KS -16 wellhead location. To the north lies Pu'u Pilau, approximately 120 feet in elevation above the KS -16 wellhead location. To the west of KS -16 lies the existing Separation vessels and existing geothermal wells, KS -13, KS -9, KS -10& KS -11. To the south of KS -16 lies geothermal well KS -1A and further south is the 8 MW Expansion facility which came on line in 2012. In addition to the noise attenuation to be accomplished by the physical siting of the well pad, sound attenuation techniques and devices that will be implemented prior to drilling consist of several methods. The first method is an engineering design which calls for the detailed and intentional physical placing of equipment in areas that would reduce impact of noise emissions compared to placing equipment out in any open area. An example would be the location of the Top Drive Units diesel driven motor and Mud Cooling equipment, see Attachment 3. The physical placement of this equipment in between the rig and other stationary equipment will help reduce noise emissions from the Top Drive Unit and Mud Cooling equipment. Another method utilizes the use of noise reducing insulation blankets, physically placed near or around specific noise emission sources. I have recommended to PGV, when installing insulation noise blankets at designated equipment, to extend the blankets above the equipment by four or more feet. Attached are photos of insulation blankets used during drilling activity and explained in further detail in later paragraphs, see Attachments 4A & 4B. Also attached is descriptive information as to the insulating capacity of the blankets, see Attachment 5. In addition to noise mitigation, these blankets will also help with lighting deflection. Additional abatement measures PGV will implement include the installation of wood insulation material on the V -Door, otherwise known as the Beaver Slide to reduce metal to metal contact and thus reduce noise emission at this location. Wood or a comparable material will also be used on the catwalk (location where piping is staged for drilling use) to minimize metal to metal noise. To further reduce noise associated with drilling operations, drilling personnel plan to use their hydro blasting unit or comparable pressure washing unit to clean the drill pipes before use, thus minimizing the need to physically impact the drill pipes with a ten pound sledge hammer. During geothermal well drilling operations the primary sources of noise emissions will originate from several mechanical motors and its associated equipment. First, the drilling rig itself utilizes three diesel engine motors rated at 877 horsepower each. Enclosed are photos of the drilling rig motors and its location, see Attachments 6A and 6B. These motors are used to raise and lower the drilling pipe assembly or steel casing in or out of the different sections of hole sizes. The weight of the drilling pipe assembly or steel casing will determine if one, two or three motors are needed for lifting or lowering of the respective assembly. Initial stages of the drilling operations -2- do not require that all motors be utilized. For noise mitigation, noise insulation blankets will be placed around the engines to significantly reduce noise emissions from these three engines. In addition, specialized mufflers designed specifically for noise mitigation will be used on all three motors. Also attached are photos showing insulation blankets placed around the motors and other areas of the drilling rig, see Attachments 4A & 4B. Second, there are two diesel engine driven generators rated at 435 horsepower each. These generators are used for the electrical needs for the drilling rig, including power supply for all of the auxiliary pumps and motors and includes lighting. For KS -16 noise mitigation efforts, PGV will only use these diesel engine generators as back-up electrical supply. The primary source of electrical supply will come from the Power Plant. Both of these diesel generator engines are located in an enclosed steel housing, which would help reduce noise emissions in the event that we need to use this equipment, see Attachment 7. Third, there will be one 800 horsepower diesel driven engine used for the Top Drive Unit (TDU). The TDU is used for mechanically rotating the drilling piping assembly during periods of actual drilling. Our primary mitigation efforts for the TDU will be the physical placement of this unit. The TDU will be placed between the drill rig and the mud conditioning system, see Attachment 8. Insulation blankets for this area will be used to absorb noise emissions. Fourth, there will be two cementing units that have diesel driven engines rated at 665 horsepower each. These units will only be used for about 12 hours each during the cementing phases of the steel casing. Noise mitigation will consist of physical placement of the equipment and sound insulation blankets. Lastly, there will be auxiliary pumps and motors, along with heavy equipment, such as Gradall Forklifts, Backhoe and a periodic Crane that will make up the remainder of noise emission sources. The auxiliary equipment will also be physically positioned behind or between existing physical structures where possible, and noise insulation blankets will be used where physical placement can't be accomplished. In addition to these abatement efforts, noise monitoring efforts will be conducted during drilling operations as follows: First and foremost, noise will be monitored on a continuous basis at PGV's fixed Monitoring Stations "A" and "B" which is located at the southeasterly and southwesterly perimeter boundaries. A photo showing the physical location of the Monitoring Stations is enclosed, see Attachment 9. In addition to the fixed monitoring, routine noise monitoring will be performed by Plant Operations personnel a minimum of twice per shift, which equates to a minimum of four times per day at locations on PGV's perimeter, close to residential homes. Non -routine noise monitoring will take place during periods where noise emissions warrant additional monitoring or by the request or direction from any applicable regulatory agencies from the County, State or Federal levels. PGV will use the experience and expertise of my engineering company to assist with the monitoring and mitigation of noise associated with the KS -16 project. An initial assessment report was submitted by me to PGV on January 14, 2015. This report discusses the expected noise levels associated with the KS -16 project, see Attachment 10. Insulation blankets alone are - 3 - expected to reduce noise on the order of 8-9 dBA at the noise emission source. In addition to the initial assessment, PGV has contracted my engineering company to gather pre -drilling baseline noise data. The pre -drilling baseline noise data was collected on January 26 and 27 while the rig was not in operation. When the rig becomes operational, additional noise surveys will be performed by me to determine if opportunities for improving noise mitigation can be implemented. Pre -drilling and post -drilling noise surveys for off-site locations include areas where noise complaints have been received by PGV in the past. In conjunction with PGV's plans for routine and non -routine noise monitoring, I will be providing my engineering services to provide recommendations to adjust noise abatement measures at the KS -16 project location to strive for achieving best available control technology activity associated with the KS -16 project. PGV will submit noise monitoring reports and noise complaints to the Planning Department on a weekly basis or as requested by the Planning Department. Reports submitted will include data from PGV's fixed Monitoring Stations, data from PGV's Plant Operations portable monitoring and any reports that are generated by my engineering company. These additional enhancements in conjunction with baseline information previously gathered and analyzed pursuant to Condition Nos. 19 and 22, form the most current BACT recommendation upon which the Planning Director can render a determination pursuant to Condition No. 20. It is my conclusion that the BACT for noise emissions during this phase of the project; the drilling of KS -16, is substantially more than what is minimally practical and economically reasonable to minimize project noise arising from this phase of the project. If you have any questions, please do not hesitate to call me at (808) 735-1634. Sincerel Y c i Ebisu, P.E. -4- r't` lv� . y:. « ■ \� . . . . .. . . ., «:. } 2� . . . < .. � y . .....� . k.= vg © »- - \� Attachment 4A e N dile Control Model UNC -XT -2 77North 9. Street, Noblesville, IN 46060 Outdoor Sound Curtain Toll Free Phone: 888.213.4711 Fax: 317 .774.1911 UNC -XT -2 Exterior Noise BarrierlSound Absorber Composite UNC -XT -2 offers the benefits of both a noise barrier and a sound absorber composite in one product. This UNC product consists of an exterior grade, UV resistant heavy-duty faced quilted fiberglass absorber bonded to a one -pound per sq. ft. reinforced loaded vinyl barrier. The heavy duty facing is a 10 oz. per sq. yd. vinyl coated polyester (VCP) quilted to the sound absorber rather than the standard 4 oz. facing. Individual sound panels can be provided. Standard width is 54" wide and each panel can be supplied with a combination of grommets (and exterior grade velcro) for attachment to your outdoor support. STC 33 Rating, NRC .75 Available facing colors on quilt: gray, tan, black, off-white Available barrier colors: gray, tan, black, blue Applications: Typically used as to reduce noise from construction sites where the product may be subjected to sunlight, rain, snow and winds. May be attached to steel structure, chain link type fences, or installed over wood fencing, on brick or masonry walls of buildings adjacent to a job site, or a noisy piece of machinery. Product Data: Description Vinyl coated polyester facing on 2" quilted fiberglass/ 1 lb-psf reinforced loaded vinyl barrier Nominal thickness 2.00" Temperature range -200 to +180° F Standard width 54" Weight 1.45 Ib-psf Acoustical Performance: Sound Transmission Loss ASTM E-90 & E 413 Sound Absorntion Performance OCTAVE BAND FREQUENCIES (Hz) Product 125 250 500 1000 2000 4000 STC UNC -XT -2 14 20 32 41 42 41 33 ASTM E-90 & E 413 Sound Absorntion Performance ASTM C 423 www.eNoiseControl.co Attachment 5 OCTAVE BAND FREQUENCIES (Hz) Product 125 250 500 1000 2000 4000 NRC UNC -XT -2 .45 .96 .87 .66 .47 .28 .75 ASTM C 423 www.eNoiseControl.co Attachment 5 Rq i] r., 11 . . . . . . . . . . . . . . . . . . . . f A, 14" It I m f A, 14" f �A �L�(It it" Rh ARM. �f �A �L�(It it" Rh ARM. �f J } � ��. lr i'�' y � °} t, y ,fi �+ �� ~�' �4 d 1. Puna Geothermal Venture P.O. Box 30 Pahoa Hawaii 96778 Y. Ebisu & Associates AcOusdpl 8nd C14CUMIC Englneers 112612th An, Room 305 Honolulu, Hawar" 96816 Ph. (BUS) 735-1634- Far (908) 732.6409 Finall: eblswamccad.com Attention: Mr. Ronald Quesada Operations Manager January 14, 2015 Subject: Initial Assessment of Noise Levels During KS -16 Weil Drilling Operations Dear Mr. Quesada: The following leiter report provides my initial findings regarding the expected noise levels during KS -16 well drilling operations at the Puna Geothermal Generating Station. I based my findings on April 2012 measurements during drilling of KS -15 plus calculations of the possible attenuation from sound barrier curtains erected at the drilling rig site. It was also reported that the use of the sound barrier curtains during the more recent KS -13 well drilling operations significantly reduced the number of noise complaints from surrounding residences as compared to those received during KS -15 well drilling operations. While the drilling rig to be used during the KS -16 operations will be identical to that used during the KS -15 and KS -13 operations, the KS -16 drilling operation will more closely resemble that of the KS -13 operations. Both the KS -13 and KS -16 sites are approximately 80 feet lower in elevation than the KS -15 site; the KS -13 and KS -16 sites are relatively close to each other, and both the KS -13 and KS -16 drilling operations will have the sound attenuation benefits of sound barrier curtains. With the sound barrier curtains located on the west and south sides of the KS -16 drilling rig, and with the tops of the barrier curtains being approximately 4 feet taller than the rig motors, the predicted sound attenuation from the barrier curtains are in the order of 8 to 9 dBA. These predictive results tend to correlate with the past observations that the number of noise complaints fell as a result of the use of the sound barrier curtains during KS -13 well drilling operations. I am proposing to visit the site during the KS -16 well drilling operations to measure the effectiveness of the erected sound barrier curtains, and to provide any additional recommendations regarding improving their performance as required. Mise survey measurements will be performed of the KS -16 rig on both sides of the barrier, and at the locations of past complainants. Ya bisu, P.E. Attachment 10 William P. Kenoi Mayor West Hawaii Office 74-5044 Me Keohokalole Hwy Kailua-Kona, Hawail 96740 Phone (808) 323-4770 Fax (808) 327-3563 CERTTIFIED MAIL February 13, 2015 County of Hawaii PLANNING DEPARTMENT Mr. Cliff Townsend, Plant Manager P.O. Box 30 14-3860 Kapoho-Pahoa Road Pahoa, Hawaii 96778 Dear Mr. Townsend: Duane Kanuha Director Bobby Command Deputy Director East Hawaii Office 101 Pauahi Stint, Suite 3 Hilo, Hawaii 96720 Phone (808) %1-8288 Fax (808) 961-8742 SUBJECT: PUNA GEOTHERMAL VENTURE (PGV) KS -16 DRILLING PROJECT DETERMINATION OF BEST AVAILABLE CONTROL TECHNOLOGY (SACT) FOR NOISE EMMISSIONS TO ALL ASPECTS OF THE PROJECT TO MINIMIZE PROJECT NOISE This will acknowledge receipt of a letter report from PGV's noise consultant, Y. Ebisu & Associates dated February 11, 2015. The letter report contains findings and recommendations for noise control measures which should be utilized to minimize noise from drilling operations at KS -16, based upon previous findings, studies and analysis of prior well drilling experience, and information on well drilling components and related noise abatement measures from PGV. The letter report is in compliance with the requirements of Condition No. 20 of Geothermal Resource Permit No. 20 which states: "20. 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 taking into account what is practical and economically reasonable. BACT shall be determined by the Planning Director upon the recommendation of the noise consultant." The noise consultant's report represents that PGV has considered a number of noise abatement methods, and also considered community concerns in developing its noise mitigation methods. PGV also conducted an analysis of the surrounding terrain and elevations for locating the proposed drilling site for KS -16. The resultant drilling site, being approximately 80 feet lower in rye i a toy www.coholannin euLeoin Hawat'i County is 01 Equal Opportunity Provider and Employer of ne(g�Q.hawaii.hi.us Mr. Cliff Townsend, Plant Manager Page 2 February 13, 2015 well fields and power plant equipment, will benefit from siting relative to sound attenuation protocols. PGV's noise consultant has represented that they have conducted a pre -drilling assessment and presented that assessment to PGV and the County in a letter dated January 14, 2015. In addition to the initial assessment, consultant has conducted pre -drilling baseline data collected on January 26 and 27 while the rig was not in operation. When the drilling rig becomes operational, consultant will conduct additional noise surveys to determine if opportunities for improving noise mitigation can be implemented. Pre -drilling and post -drilling noise surveys for off-site locations include areas where noise complaints have been received by PGV in the past. Consultant represents and concludes that the proposed noise attenuation enhancements in conjunction with baseline information previously gathered and analyzed pursuant to Condition Nos. 19 and 22 form the most current BACT recommendation; a recommendation for noise abatement which is substantially more than what is minimally practical and economically reasonable, and upon which the Planning Director can render a determination pursuant to Condition No. 20. Based on the letter report, the Planning Director makes the following determinations with regard to BACT for the drilling of KS -16: 1. Proposed noise attenuation measures and abatement methods for the KS -16 operation will benefit noise effects for other aspects of the overall project operation since the location of the KS -16 drilling site is within the existing power plant facilities and well fields. 2. Noise reducing insulations blankets shall be placed near or around specific noise emission sources and shall extend above the equipment by a minimum of four (4) or more feet. 3. The clustering of equipment shall be implemented wherever possible to reduce individual noise emissions. 4. Wood insulation material shall be used wherever possible to reduce metal to metal noise (i.e. catwalks, V -door or Beaver Slide). 5. Hydro blasting or comparable pressure washing applications shall be used to clean drill pipes or other similar apparatus to substantially reduce metal to metal application (i.e. sledge hammer, etc.). 6. Noise insulation blankets shall be placed around all rig motors or engines in addition to specialized mufflers or other apparatus specifically designed for noise mitigation. Mr. Cliff Townsend, Plant Manager Page 3 February 13, 2015 7. Diesel generators for power to the drilling rig, auxiliary pumps, motors, and lighting shall only be used as back up and not as the primary power source. Primary source of power shall come from the power plant. 8. Noise monitoring efforts shall consist of, but not be limited to, (a) continuous monitoring at PGV's fixed monitoring stations "A" and "B"; (b) routine monitoring will be performed by plant operations personnel a minimum of twice per shift or four times per day at locations on PGV's perimeter; and (c) non -routine monitoring will occur during periods where additional monitoring is warranted or at the request or direction from applicable agencies of the County, State or Federal governments. 9. PGV's noise consultant, Y. Ebisu & Associates, shall be responsible for compliance monitoring of the BACT measures as recommended and determined to be implemented herein. The Director is also aware that operationally, the drilling operation for KS -16, while permitted to be conducted 24/7 per GRP2, will have various phases where drilling will cease while other components of the drilling operation, such as concreting of the well shaft, etc. to be performed, and that PGV will be submitting further information concerning such phases. While not a specific component of BACT, the Director is encouraged that PGV is taking the initiative to consider, to the extent of operational practicality and consideration for the safety and integrity of the drilling operation, such pauses in drilling activity. In conclusion, the Planning Department authorizes the use of the approved BACT for the KS -16 drilling, and looks forward to following up with PGV to ensure that the execution of the stated noise mitigation plans are implemented throughout the duration of the KS -16 drilling project. Sincerely, Duane Kanuha Planning Director ACKNOWLEDGED AND ACCEPTED: Signature Date Mr. Cliff Townsend, Plant Manager Page 4 February 13, 2015 cc: Y. Ebisu & Associates Mayor Corporation Counsel Molly Stebbins Deputy Corporation Counsel William Brilhante Department of Public Works Civil Defense Windward Planning Commission Council Chairman Dru M.-Kanuha and -Hawaii County Council Department of Health Department of Land and Natural Resources Department of Business, Economic Development and Tourism