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HomeMy WebLinkAboutCOM 0062.002 2014-201674"t" Zee 76va RR 2 Box 3317 Pahoa, Hi 96778 email: ttravisl2@mac.com mobile: (757) 639-7364 f c—> County Council County of Hawaii TESTIMONY on Communication 62. Council Members, thank you for the opportunity to submit testimony. One of the threats of the lava flow is that it restricts transportation to and from Puna Geothermal Venture (PGV) and the surrounding community. A second threat is that it poses the danger of placing one of the two transmission lines from PGV out of order for a prolonged period of time. Both of these threats directly impact the validity of the emergency response for casualties at PGV. Threats from the lava flow pose similar challenges in a PGV upset as those faced by Civil Defense during the landfall of Tropical Storm Iselle. A thorough evaluation of lessons learned from Iselle should be done, followed by a thoughtful revision to both the PGV and County portion of emergency response planning. I strongly urge both the Mayor and the County Council to take strong action to address the issues outlined below. In the event of an approaching hurricane, the action required of PGV by Section 8.1.4 of the PGV Emergency Response Plan modified in 2011 is quoted below: 8.1.4 Hurricane Nature of Hazard: Hurricanes with devastating winds (74 miles per hour or more) can cause death, extensive damage to lightly -built buildings and tall structures, uproot trees, snap utility poles, and make destructive missiles of flying debris. However, because of the design and construction of the PGV project, there is little potential for hurricane winds to produce facility emergency situations which could threaten the health, safety, or welfare of the public. Flooding produced by hurricane rainfall and storm surf generated comm. No 6� 'Z Ret . Ref. Date by high wind should not pose a threat to the project facilities since the project site is on high ground. Response Actions: Upon notification or determination, PGV will take the following actions supplemental to those listed at the beginning of Section 8.1: 1. Secure loose objects around project site and, if appropriate, cease drilling or plant operations. 2. Notify the CDA immediately should the hurricane cause a facility emergency situation that could threaten public health and safety. 3. Depending on the size of the hurricane, the power plant may be tripped. (Emphasis added} If so, steam is released through the rock muffler and abatement of hydrogen sulfide should start simultaneously. Respondents to an emergency should approach the site from an upwind direction and have personal monitors and self contained breathing apparatus (SCBA). Notify both CDA and HDOH, Clean Air Branch (Table 3-1), if steam is released to emergency steam release facility. 4. Check water and electrical lines. 5. Switch off electrical power if there is damage to power sources or wiring. 6. Await instructions from CDA. 7. Make other required verbal notifications. The basis of the emergency response plan above is flawed. The emergency steam release facility (ESRF) may protect the plant from damage from loss of load, but automatic protective actions that release hydrogen sulfide can affect the community. It has long been understood that road closures during high winds are inevitable, as such closures have occurred during storms with far less wind speed than a tropical storm. Road closures from lava flows are similarly predictable. Residents who will inevitably be trapped in their homes along the very roads that first responders must use to approach PGV do not have monitoring or protective gear. It is also likely that the road closures that slow resident evacuation will slow first responders from reaching the plant.' It is a fundamental engineering and plant operation principle that built in emergency safety features should not be relied on as the primary safety protection. Therefore, when the probability of plant trip becomes considerable, action should have been taken to protect the plant without reliance on emergency safety features. Reliance on the ESRF to protect the plant and abate the release of hydrogen sulfide into the community creates a situation where a more serious accident becomes inevitable if additional failures occur. I The EPA Review of August 2000 entitled Puna Emergency Response: Report on the Review of Hawai'I County Emergency Operations Plan and Puna Geothermal Venture Emergency Response Plan states, "In particular, the Review Team was concerned about the capability of local responders to carry out a timely response in the PGV facility. Hawai'i County responders need to evaluate their capacity for emergency response and their ability to participate as part of an Incident Command System. The Hawari County Fire Department, Pahoa Substation should work with PGV to gauge the potential severity of an incident" Although on a slower timeline, the lava flow can create challenges similar to the hurricane. Access to the plant and possible evacuation routes will be restricted by road closures. flow.lava • - - t but not effectively - • • - - • . • Inadequate warnft and alarm to the communit • Inadequate staging of resources to allow effective first respons • Inadequate • InadeQuate practice and rehearsal for casualties at PG documents present requirements for County of Hawaii response to emergencies at PGV. The first of these is The County of Hawaii Emergency Operating Procedures [COH EOP] and the second is the County Trifold, "Keeping You Safe In Case Of A Geothermal Plant Incident." Applicable portions of the County of Hawaii Emergency Operating Procedures read: A build-up period will precede some emergencies, providing sufficient time to warn the public and implement prevention measures designed to reduce loss of life, property damage, and effects on the environment... All Hawaii County departments and agencies must be prepared to promptly and effectively respond to any foreseeable emergency, taking all appropriate actions, including requesting and providing mutual aid The Preparedness Phase involves the range of deliberate, critical tasks and activities necessary to build, sustain and improve the operational capability to prevent, protect against, respond to, and recover from incidents_. Preparation includesll� organizing, equipping, training, exercising, evaluating performance (actual and exercise), and then revising the plan based on changes in performance, organization and equipmm .. Exercises provide opportunities to test plans and improve proficiency in a risk-free environment Exercises are the natural extension oftraining and allow departments/agencies to assess and validate proficiency levels, clary and faminarize personnel to roles and responsibilities. According to a County of Hawaii Trifold, "Keeping You Safe In Case Of A Geothermal Plant Incident": if an emergency at the plant causes a release of H2S, our First Responders will monitor the situation. If the concentration of H2S begins to rise, the affected areas will be evacuated before levels become unsafe. The public will be kept informed when any significant event ( ,,UrS.z I The assertion that "H2S is released from active volcanic vents and can be part of ambient air conditions downwind of eruptive activity' is wrong. When present in a gas stream with sulfur dioxide, hydrogen sulfide is rapidly converted to water and sulfur. Almost no hydrogen sulfide is present downstream of eruptive activity. This has been confirmed by the USGS in a briefing given 10 the geothermal public health assessment group in early 2013. If the County had follows the Concept of Operations of the COH EOP, the impact of the toxic release from PGV could be lessoned. Now following problems during Iselle the County has the opportunity to take those actions to address dangers of the lava flow.345 In the four months following Iselle, the County has taken no formal action to evaluate the emergency response to the release from PGV on August 7, 2014. Lessons learned have not been collected and used as a road to improvement. In conclusion, over one hundred people experienced health effects from the toxic release from PGV on August 7. The County of Hawaii's failure to follow the COH EOP and Trifold guidance strongly contributed. Even more distressing is that even after this event, the County has done nothing to evaluate its poor performance or to modify future response for improvement. The time is critical for the County to take this action now before lava or a similar casualty creates challenges similar to those faced with Tropical Storm Iselle. Thank you. /s/ Thomas Lee Travis 3 The County Trifold dealing specifically with PGV casualties is error riddled, conceptually flawed, and impossible to execute under many circumstances. One problematic contributing factor is the few number of samplers, the positioning of the samplers, and the overall lack of knowledge of what the actual H2S level is at various locations during a casualty. The County Trifold states that 9 the plant staff is unable to manage the release, sound levels are excessive, and H2S levels continue to rise and before concentrations reach 10 parts per million, an evacuation notice will be issued. Although these conditions were clearly met during the evening of August 7, the County did not order an evacuation. L Sufficient time was available before Iselle landfall to warn the public and implement measures designed to mitigate the effects of the toxic release expected. For example, the plant could have been ordered shutdown by the County; if decision makers decided to keep It operational despite the overwhelming logic of shutting it down, neighbors to PGV could have been warned of the likelihood of a toxic release, hazardous material units of the Fire Department could have been pre -staged, and crews to keep the roads open could have been put into place. (Some might say doing so would put the Fire Department and road crews in danger, but this argument is silly considering the fact the the County ordered residents to evacuate through the same area). Additionally the Fire Department could have been supplied with the equipment required by the PGV emergency response plan. 5 Releases of 1-12S from PGV can be from numerous locations on the site, can be high or low temperature, can be part of high or low pressure releases, and can be the consequence of maintenance, material failure, or human operational error, plant procedural problems, or plant design issues. As such, the idea that readings will slowly reach an alarm level and then increase gradually is only true in the most general sense. Actually, bubbles of gas can move up and down, left and fight. The measurements available to the County indicating level of 1-12S can vary by several orders of magnitude based on location and time from the incident.