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HomeMy WebLinkAboutCOM 1072.007 2014-2016 PIPSMTC COMA, Murashige,Murashige, Laura From: Sara Steiner <pahoatoday@gmail.com> Sent: Monday, October 03, 2016 11:08 AM To: Council Testimony Subject: Fwd: My Testimonyfor the Oct 4 hearing Attachments: Letter for 4 October 2016 CD Hearing.pdf; PGV- CIVIL Defense Iselle Critique 1 Aug 15.pdf Forwarded from PahoaToday@gmail.com from Thomas Travis who requested I submit his testimony. Sara Steiner Tom o Thomas Travis RR 2 Box 3217 Pahoa, Hi 96778 tau (73,-,C ttravis12@mac.com (757) 639-7364101 ^� • Comm. No. I g Ref. To: Ref. Date OCT 0 4 2016 1 'Nomad lee 7'uwic RR 2 Box 3317 Pahoa, Hi 96778 email: ttravisl2@mac.com mobile: (757) 639-7364 Reference: Comments on Emergency Response during Iselle Honorable Members of the County Council: Below is the Emergency Response Procedure for the County and for PGV in the event of a hurricane: 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 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. If so, steam is released through the rock muffler and abatement of hydrogen sulfide should start simultaneously. 4. Respondents to an emergency should approach the site from an upwind direction and have personal monitors and self contained breathing apparatus (SCBA). 5. Notify both CDA and HDOH, Clean Air Branch (Table 3-1), if steam is released to emergency steam release facility. 6. Check water and electrical lines. 7. Switch off electrical power if there is damage to power sources or wiring. Await instructions from CDA. 8. Make other required verbal notifications. Unabated steam and geothermal toxins were released through pressure relief valves (PRVs). This was not expected. Respondents not only approached from downwind, but they were unable to reach the site of the emergency. Although they may have been equipped with monitoring devices, they did not take samples. Although the response procedure in practice did not work, it has not been changed. Although it is clear that the County as the one who must respond must work with PGV to control the impact of the emergency, the County has repeated said it has no authority to control PGV operations. (Note step seven seems to indicate the County has some authority). No apparent effort has been made to give the County the needed authority. /�/ 74amew 4ee ?nand The Civil Defense Response to Hurricane Iselle The emergency response plan, previously identified as inadequate by both the EPA and the community, but not substantively fixed, proved inadequate. As Tropical Storm Iselle began battering lower Puna on August 7, 2014, Puna Geothermal Venture (PGV) went offline and began a release of geothermal fluids and noxious gas through the plant's emergency steam relief system and other relief mechanisms. The release dumped noxious gas into the community surrounding the geothermal power plant for some time. Residents that were trapped in their homes by the tropical storm reported smelling stronger noxious gas odor than they had ever smelled before. Many developed symptoms that could be associated with exposure to hydrogen sulfide—several people became unconscious or extremely lethargic, dozens developed symptoms consistent with H2S exposure, and two people died shortly after, possibly from complications of the exposure. To understand why the decisions made or not made must immediately be called into focus, we need only to review the upset at PGV on March 13, 2013. On that date with PGV operating near its maximum power, maintenance on one of the two transmission lines and a malfunction on the second caused a loss of load at PGV, forcing the plant to instantly go from near full load to no load. This caused a dangerous over-pressure condition in the power plant, which required the emergency steam relief system to dump geothermal fluid and hydrogen sulfide into the air. Discussions between the US Environmental Protection Agency, the State Department of Health, the County Civil Defense, and the community were held regarding this incident. Anyone who understood the causes of the March 13, 2013 upset cannot help but be perplexed by what happened on August 7, 2014. By not ordering the shutdown of PGV, State and County regulators simply were indifferent to the potential danger to the community or were they were incompetent.Any informed person clearly understood that transmission lines would be lost during a major storm. Anyone with knowledge of what happened on March 13, 2013 knows that grid malfunctions will cause a power producing PGV to release gases to the surrounding community. Anyone with knowledge of lower Puna knows that during even a local storm, fallen trees make access to PGV difficult. Certainly anyone with knowledge of lower Puna knows that evacuation from homes during high winds, if possible, is dangerous. Yet the plant was allowed to operate and no special deployments of emergency personnel or gear were considered or executed. As hydrogen sulfide was pouring into the community, the three PGV perimeter hydrogen sulfide samplers required by the State Department of Health—samplers used to regulate PGV emissions and to allow County emergency response—went out of commission. The Fire Department's Hazardous Material Team was unable to locally sample for noxious gas because the team could get to the area because of dangerous conditions on the road. Although County Civil Defense suggested evacuation for residents feeling discomfort from exposure, such evacuation required use of exactly the same roads that were impassable to the Hazardous Material Team: Many of the issues discussed here have been discussed for many years. Hawaii County Emergency Procedures recommended by the US Environmental Protection Agency in 2000 have not been fully implemented by the County. In 2012, after the Hawaii Island County Council passed an ordinance requiring creation of emergency procedures for PGV and practice of those procedures, the ordinance was vetoed by the mayor who claimed additional procedures and practice were unnecessary. The Geothermal Public Health Assessment Report'a criticism of the State's hydrogen sulfide "monitoring" system have not been addressed by DOH. Although there was no plan that required the plant to be shut down—even though it clearly should have been— with the approach of Hurricane Iselle, two documents contained requirements that should have shaped the County's response to the casualty. Below is an accounting of how the County did against these requirements. The accounting was provided as testimony to the County Council. That testimony is attached. 74mad Zee 7'uw& RR 2 Box 3317 Pahoa, Hi 96778 email: ttravisl2@mac.com mobile: (757) 639-7364 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. The PGV Emergency Response Plan incorrectly allows the plant to operate at power when there is an unacceptable risk of losing electrical load. 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 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.1 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. 1 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 Hawai'i 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. The COH emergency response to Tropical Storm lselle placed residents in unnecessary danger. Similar challenges face COH with a lava flow. Issues identified but not effectively addressed include: • Inadequate warning and alarm to the community • Inadequate staging of resources to allow effective first response • Inadequate options for evacuation • Inadequate practice and rehearsal for casualties at PGV Two 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 includes planning, organizing, equipping, training, exercising, evaluating performance (actual and exercise), and then revising the plan based on changes in performance, organization and equipment. • Exercises provide opportunities to test plans and improve proficiency in a risk-free environment. Exercises are the natural extension of training and allow departments/agencies to assess and validate proficiency levels, clarify and familiarize 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 occurs.2 2 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 to 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 if 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. 4 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 H2S 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 right. The measurements available to the County indicating level of H2S can vary by several orders of magnitude based on location and time from the incident.