Hū Honua Testimony from HAPA
September 20, 2018
Re: Hu Honua NPDES permits
Aloha, My name is Anne Frederick and I am the Executive Director for the Hawaii Alliance for Progressive Action (HAPA). HAPA is a statewide environmental, social and economic justice organization. HAPA engages over 10,000 Hawaii residents annually through its work. Our stated mission is to catalyze community empowerment and systemic change towards valuing ‘aina and people ahead of corporate profit.
We are very concerned about the Hu Honua project and the proposed use of water and land, and greenhouse gas emissions. A project that will release 300,000 tons of greenhouse gases per year and is certainly not renewable or green energy.
Concerns Regarding Underground Injection Control (UIC) wells:
Norris Uehara, the supervisor of the Safe Drinking Water Branch UIC Program, states that Hu Honua’s injection wells are no threat to our drinking water. He rationalizes that our drinking water is protected because the drinking water wells are at least ¼ mile mauka of the injection wells. Because groundwater flows from mauka to makai, there is the assumption that no backward flow would transport the contaminated water uphill, from the injection wells located makai, to mix with the drinking water drawn by wells located mauka. However, Hu Honua never identified the correct aquifer (Hakalau) to the DOH, nor the outer limits of nearby sources of drinking water, nor the outer limits of the water sources drawn from by other potable water wells in the neighborhood. It is not clear that the DOH has sufficient information to issue a permit to operate the UIC wells.
Mr. Uehara’s assurances also contradict a statement based on Warren Lee’s August 21, 2018 letter to Darryl Lum, the Supervising Engineer of the Clean Water Branch of the Dept. of Health. In the letter, Mr. Lee stated that the injected wastewater may be slowed down in reaching the ocean, due to sediment and other geological inconsistencies within the aquifer. One can presume that these sorts of geological obstructions could very well lead to the sort of backward flow that Mr. Uehara said was impossible.
If, as Mr. Uehara asserts, the groundwater is flowing so quickly that no backward flow will take place and thus contaminate our drinking water, then how is it that the groundwater is also moving so slowly that it can cool down sufficiently before reaching the ocean so as not to kill marine life? Please provide an answer to this key question, and provide scientific data to support your answer.
The hazardous chemicals that Hu Honua intends to add to the water before injecting it include morpholine, carbohydrazide and sodium nitrate. All of these chemicals carry manufacturer’s warnings against mixing in waterways or aquatic ecosystems.
According to Mark Gordon, CHMM (Certified Hazardous Materials Manager) Environmental, Health and Safety Manager for JM Decker Group, Hawaii -- The chemical pollution from Hu Honua’s injection wells combined with the heat of the water would be devastating for the nearshore ecosystem and the sensitive marine and other organisms. Hu Honua must reduce the temperature of the heated wastewater before injection to the UIC, as per Hawaii Administrative Rules 11-54-9. What technologies are commonly available for reducing the temperature of thermal pollution like Hu Honua's? The Hawaii Alliance for Progressive Action requests a public hearing under HRS Chapter 91 to address this issue.
In addition, the DOH should determine that Hu Honua’s underground injection control wells will be a point source for which an NPDES permit is available. Hakalau Beach Park and Kolekole State Park are nearby. This proposed plant could threaten public health and access to clean, safe ocean water.
Mr. Gordon goes on to express concern that draining too much water out of the aquifer could affect sustainable use of this water over time. This coincides with very real concerns of residents in the immediate area who draw from wells for their water, and who fear their water will be made inaccessible by industrial-scale consumption. They feel the Department of Health has been heeding only the profit-driven desires of wealthy mainland investors, and not the health-and-safety needs of local people whose taxes support our government agencies. We hope that you hold a public hearing to disavow that belief.
Another serious matter concerning the injection wells is the extremely unstable geology of the cliff, where landslides are common, such as the ones that took place during Hurricane Lane. (See https://www.hakalauhome.com/cliff-failures.html). Given the unstable nature of the cliff, it is an act of sheer negligence to allow for millions of gallons of water per day to be injected only 80 feet from the cliff line. The dangers are even more obvious when one examines the recent studies that show that injection wells cause earthquakes. (See https://www.washingtonpost.com/science/2018/08/30/howenergies-companies-set-off-earthquakes-miles-away-their-waste-dumps/?utm_term=.761374eb7495).
The second NPDES permit I wish to comment on is # S000557, for storm water. Hu Honua’s construction site is in the midst of four miles of public access trails in the scenic Pepeekeo Point area that the community uses for fishing, diving, and various subsistence and recreational activities. The company is currently running stormwater through another landowner’s drainage system, through a culvert under Cane Haul Road, and mingles with stormwater runoff from the coal ash pile. By the time it is discharged with significant force at Outfall 003, it is contaminated. Mitigation is needed to slow the stormwater so pollutants can settle out, and so the cliff and shoreline trail will not erode more. Most importantly, we urge DOH to request that the Hawaii County Planning Department or Commission require an Environmental Assessment (EA) for Outfalls 001 and 004, both of which fall on conservation land owned and managed by the State.
According to an April 4, 2018 letter from Russell Tsuji, Administrator at the Department of Land and Natural Resources, Hu Honua must ask the State for an easement and applicable permits and follow HRS Chapter 343 Environmental Review. An EA is also required for a facility drainage system covered by DOH permit, before DOH makes a decision on a NPDES permit.