Dear Editor,
Schlumberger-Guyana Inc.’s planned construction of a “Source Storage and Calibration Building” facility at 1 Area X Houston, EBD, Georgetown which was given EPA approval only came to the attention of the majority of residents of Houston and surrounding communities through news reports in late April and early May. The EPA’s Notice to the Public dated April 11, 2021 which was subsequently found on its website, did not provide any substantive reasons for how it arrived at this approval and the basis for waiving an EIA. Rather, the notice simply states that “it has been determined that the projects will not significantly affect the environment or human health, and are therefore exempt from the requirement for an EIA.” No further explanation was provided. It is not clear what evidence or information was used to make this determination.
We were/are alarmed to find out that the Schlumberger-Guyana Inc. Source Storage and Calibration facility involves the handling, storage and installation of radioactive sources, and the processing and disposal of hazardous industrial waste, including oil-contaminated materials. It is well-documented that these substances, by their very nature, pose serious risks to the environment and human health. Under Guyana’s Constitution and international human rights treaties, citizens have a right to participate in decision-making and be informed of ‘developments’ which impacts our communities and environment including suitability of location for construction and operation of such a facility, track record of company in handling hazardous waste, mitigation measures and safeguards for securing and disposing of radioactive material and disaster preparedness to name a few. One news report stated in April that construction was 75% completed. Our view is that the EPA’s approval for this facility violates principles of environmental management set out in the Environment Protection Act, including the precautionary principle. Specifically, the Environmental Protection Act dictates that, in performing its functions, the EPA shall make use of current principles of environmental management, including the precautionary principle and the avoidance principle. The “precautionary” principle states that “where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing measures to prevent environmental degradation” (article 4(b), Constitution). The “avoidance” principle states that “it is preferable to avoid environmental damage as it can be impossible or more expensive to repair rather than prevent damage” (article 4(d), Constitution).
It is unclear what information the EPA used to determine that the project would not have a significant effect on the environment or human health. The only information we could find about the possible impacts of Schlumberger’s proposed project in Guyana is in Schlumberger’s own Project Summary on environmental effects. This section only has about 146 words and is overwhelmingly lacking in detail. This section states very briefly that the project will have no environmental effects. The Project Summary does not provide details about the risks associated with radioactive sources, hazardous industrial waste and mitigation measures. Moreover, the Project Summary leaves out key details such as safety measures for the transportation of hazardous waste and radioactive sources, safe disposal from the accumulated hazardous substances, plans in the event of a spill or industrial accidents on site and or in the transportation of these hazardous and radioactive materials from Guyana’s EEZ zone into and along the Demerara River. Neither is there any detailed environmental plan for the containment, mitigation or protection measures for accidental release of such hazardous substances into the environment nor any mention of consequences of risks and endangerment of citizens, communities and environment. International conventions and best practice emphasize the importance of proper regulation and management of radioactive waste, including through environmental assessments before construction of such facilities begins. The Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management, for example, states that Contracting Parties shall take the appropriate steps to ensure that procedures are established and implemented for a proposed radioactive waste management facility to evaluate the safety impact of such a facility on individuals, society and the environment, taking into account possible evolution of the site conditions of disposal facilities after closure. In addition, “before construction of a radioactive waste management facility, a systematic safety assessment and an environmental assessment appropriate to the hazard presented by the facility and covering its operating lifetime shall be carried out.” Radioactive waste management is defined broadly to include all activities, including decommissioning activities in the handling, pretreatment, treatment, conditioning, storage, or disposal of radioactive waste.
Additionally, we do not understand how EPA granted approval for such a facility to be located in a residential area. Guyana’s zoning categories, as we were informed are residential, commercial, residential/commercial and industrial. According to our information, industrial facilities, factories, and harmful storage sites should never be located, constructed, built or operated in a residential area. Schlumberger Guyana Inc, planned construction of a “Source Storage and Calibration Building” facility at 1 Area X Houston, EBD is ‘slam bang’ located in the communities of Houston, Houston Estate, Houston Village/Housing Scheme with close proximity to adjoining communities of McDoom, Agricola, Eccles etc. Houston Nursery and Houston Secondary Schools are just across the road from where this facility is being constructed as are health centres, community centres, faith based places of worship and wells for potable water. The UN World Conference on Human Rights, reaffirms in its Declaration on the Right to Development that “The human person is the central subject of development. The right to development should be fulfilled so as to meet equitably the developmental and environmental needs of present and future generations. The Regional Agreement on Access to Information, Public Participation and Justice in Environmental matters in Latin America and the Caribbean, also known as the “Escazú Agreement “ came into full effect in April, 2021. President Irfaan Ali affirmed Guyana’s commitment to it in his speech on Earth Day, April 22, and stating its importance to the sustainable development of the Region. Escazú guarantees “full and effective implementation of the rights of access to environmental information, public participation and justice” and protects the rights of citizens to live in a healthy environment. In other words, it guarantees access to environmental information, consultation in environmental decision making processes, right to take legal action in cases of environmental damage, promotes and defends the rights of environmental and human rights defenders, indigenous peoples and communities.
Based on the above, we have requested that the EPA conduct a comprehensive Environmental and Social Impact Assessment (ESA) of Schlumberger Guyana Inc.’s “Source Storage and Calibration Building” facility at 1 Area X Houston, EBD. We have also written also to the, Minister of Housing, the Georgetown Mayor & City Council and the Central and Housing Planning Authority to clarify zoning issues surrounding the location of this facility for waste including hazardous waste including radioactive waste and installation of radioactive sources within residential communities.
Sincerely,
Danuta Radzik
Vanda Radzik
