June 1, 2021
-concerns raised over approval of Houston facility without impact study
Even as concerns have been raised by Houston, East Bank Demerara (EBD) residents about approval being granted for the setting up of a waste treatment facility in the village, the Environmental Protection Agency (EPA) has announced that approval was also given to another company for the storage of a radioactive source at Coverden, also on the East Bank.
The Coverden facility is located in the same area that Global Oil Environmental Services (GOES) is hoping to construct a treatment facility for ExxonMobil’s waste under a project that some residents have already questioned.
The EPA announced that the application was screened and it was determined that the project would not “significantly affect the environment” and the company was thus exempted from undertaking an Environmental Impact Assessment, although it did not say what measures were used to determine these findings.
“The industrial radiography equipment will be securely stored away from the public in a well-designed structure and shielding located more than 200m away from the nearest resident. Only suitably trained and qualified personnel will be allowed access to and use of the equipment,” the EPA said of the project, which is being developed by Non-Destructive Testers Limited (Guyana) Inc.
In support of ExxonMobil’s offshore works, the company will be using equipment with a radioactive source. Most of the time it is used in offshore logging equipment.
According to the International Atomic Energy Agency, a sealed radioactive source “is radioactive material that is permanently sealed in a capsule or bonded and in a solid form. The capsule of a sealed radioactive source is designed to prevent the radioactive material from escaping or being released during normal usage and under probable accident conditions.”
The agency notes that in most countries, the use of sealed radioactive sources is regulated and users are required to be properly educated and trained in radiation safety and protection.
“The manufacture of the equipment itself is also regulated, so that radiation doses received by users, bystanders, and patients are tightly controlled. Dose limits for individuals have been adopted by the International Community in the Radiation Protection and Safety of Radiation Sources: International Basic Safety Standards for protecting people and the environment,” it states.
“The major risks from these sources occur when the source is lost, stolen, forgotten, or otherwise outside of regulatory control. These so-called orphan sources (orphan meaning they are no longer under proper control) can pose a significant danger if someone obtains or finds such a source and does not realize that it is radioactive. Injuries or death are possible when a source is found and someone unknowingly takes it home or tries to open it,” it adds.
‘Cradle to Grave’
In Guyana’s case, shielding security or walls that would be used to ensure that the radioactive material is bound within and the transporting to and from the facility have had to be addressed.
It was under former EPA Director Dr Vincent Adams that oil support companies had first expressed interest in storing waste here and storing radioactive material.
When contacted, Dr. Adams said he could recall that “Halliburton had applied for a similar permit” and he had attended a meeting of the Board of the Central Housing and Planning Authority where that company had to give a presentation on how they would handle the sources to ensure no exposure to the public during storage, transportation and use. “Of major concerns were the securing of the sources during storage and transportation so that it won’t get into the wrong hands, or someone breaching the storage facility and getting access to the sources,” he said
It is unclear whether Halliburton was issued the permit. This newspaper has been trying for months to schedule an interview with current EPA Director Sharifah Razack to no avail. Emails have not been replied to and calls to her office have always been met with comments that she was either busy or out of office.
When asked about the general concern of residents about the location and treatment of hazardous waste coming from oil and gas production. Dr. Adams said that he had introduced a ‘cradle to grave’ principle used in the US regulations and set it as a requirement for ExxonMobil to develop and deliver to the EPA for approval.
He told this newspaper that “the cradle to grave principle means that ExxonMobil and not just third party companies would be responsible for the waste and all of its residuals emitted in the air, water, and solids from the time the waste is generated to its final disposition, such as burial.”
Adams had also introduced what he termed the standard principle of having a “waste acceptance criteria” that must be applied by all treatment and/or waste disposal facilities, after approval by the EPA. He set this requirement for ExxonMobil’s main waste manager Tiger Tanks at the time or any other treatment facility to have “waste acceptance criteria” to ensure that their facility has the necessary equipment to treat the waste being handed to them by ExxonMobil.
“This waste acceptance criteria would have required a full analysis of the waste received by them to be sure that it doesn’t exceed the concentrations and capabilities that they are designed to handle. Any waste type or concentrations exceeding that criteria means that the facility is not capable of handling that waste to get it to the required safe treatment levels and therefore has to be rejected.” he said.
“I imposed upon Exxon that they would have to be responsible for all of the waste from the time it is generated (cradle) through treatment and to final disposal (grave) of whatever is left over. They are also responsible for emissions which enter the air, water and soil during treatment,” he had explained.
“There is a rule of chemical law that matter is never destroyed. So, for example, in the case of Incineration when you burn, if you put a pound of waste in, you get a pound back out. However, it comes out in different pieces. Some will go into the air in the form of such contaminants as carbon dioxide and hydrogen sulfide, some in the water, and some in the residual solid ash. The types of emissions in the air, water and soil and their quantities, all depend upon the characteristics of the waste and the equipment treatment capabilities,” he added.
Dr. Adams further explained that “the plan is to send the residual ash from treatment of the waste to the burial ground landfill, so likewise, the landfill should be required to also have waste acceptance criteria approved by the EPA showing that it is designed to suitably accept that type of waste and quantity to store for eternity without any leakage to the environment.” He said that when he left the EPA, “Exxon was in the process of submitting its cradle to grave plan to the EPA, along with the waste acceptance criteria from both Tiger Tank and the municipal landfill and that the landfill had applied for an expansion of its permit so as to be able to accept this new waste from Exxon.”
‘Overwhelmingly lacking’
The notice for the Coverden project comes as Houston residents Danuta and Vanda Radzik raised concerns about the EPA’s approval of a facility for hazardous waste storage involving the same storage of radioactive sources, located in their community and in midst of a residential area.
“We were/are alarmed to find out that the Schlumberger-Guyana Inc. Source Storage and Haliburton facility involves the handling, storage and installation of radioactive sources, and the processing and disposal of hazardous industrial waste, including oil-contaminated materials,” they wrote in a Letter to the Editor, published in the Sunday Stabroek.
The Radziks underscored that it is well-documented that these substances, by their very nature, pose serious risks to the environment and human health.
They also pointed out that the EPA said nothing of how it came to the decision that the project did not warrant an EIA.
“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,” their letter stated.
“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,” it added.
That the planned project is in a residential zone was also highlighted by the Radziks as they called for the EPA to “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.”