Jul 22, 2021 Letters
The Gas-to-Energy Project Summary document was referenced in notices for public engagement on the environmental impact assessment (EIA) for the subject project. The purpose of the document prepared by Esso Exploration & Production Guyana Limited (EEPGL), was to provide technical information to the EPA for project environmental authorisation. The document was the only written source of public information and clearly by itself, lacked sufficient information for public engagement on the project EIA.
The document provided basic high-level information on the construction and installation of an NPS 12-inch diameter offshore and onshore pipeline. A preliminary layout drawing of the Natural Gas Liquid (NGL) plant with some identified process equipment was included. Basic process flow description was provided for NGL plant operations before concluding with seven pages of tables (pages 20-26) which included human and environmental impacts during the life cycle of the project. One can conclude the tables in pages 20-26 to be a qualitative EIA, which would be confusing since the public notices stated the EIA was still to be completed. Tables on pages 20-26 combined the human and environmental impacts from both construction activities and plant operations. The effect was plant operation impacts masked with verbiage skewed to the impacts from construction activities.
What was clearly lacking from the EEPGL document in the pages 20-26 tables, was the basis for human and environmental impacts from plant operations. Such a basis would at a minimum identify and quantify the waste products in the process streams and the methods of disposal. Hydrogen Sulfide (H2S), mercury (Hg) and process waste water are clearly the high consequence waste products that will require effective management. Other chemicals used in the separation process may also require disposal on some frequency during the plant’s operating life cycle. Since the identity and quantity of these waste products and chemicals, as well as the disposal methods were never provided in the technical information, how can the public have confidence that a competent EIA assurance review will be completed.
What production rate was the environmental application been sought for? Table 2.1 of the document stated onshore and offshore pipeline gas flow as 50 MSCFD; however, a maximum permissible pipeline flow of 120 MSCFD was also documented. No production rate for the NGL plant was given. This language would appear to give plant operators the discretion to increase raw gas processing up to 120 MSCFD without revising the environmental permit after an initial flow rate is 50 MSCFD. Surely, this would be unacceptable.
There was a contradiction in the EEPGL document on the removal of H2S from the raw Natural gas. In Table 2.1, describing NGL plant operations, it was stated that propane, butane and pentane+ liquids will be removed from the Natural gas and then the “remaining gas” will be treated before being sent to the power plant. However, later on page 13, it was stated the Natural gas stream received from the FPSO will be treated to remove H2S before separation of hydrocarbon components begins. The latter sequence of processing was more likely to meet Sulphur specifications for the propane, butane and pentane + fuels if the intent is to use these fuels locally. Sulphur will be released to the environment as Sulphur Dioxide (SO2) when the fuels are combusted.
As mentioned before, the EEPGL document, with some exception to water management, does not prescriptively discuss how waste products will be safely disposed. However, from the preliminary NGL plant design, it can be deduced H2S will be removed from the process by amine treating. Once the H2S leaves the amine regenerator, all indications are the H2S will be incinerated, converting the H2S to Sulphur dioxide (SO2). SO2 is less hazardous than H2S, however SO2 is far from benign, known to affect the human respiratory system, impact trees, plants and waterways. Depending on the daily SO2 production, a dispersion analysis may be required to understand the impact area.
Process waste water will contain residual hydrocarbon and may have small quantities of other contaminants such as H2S, mercury and Helium, a radioactive element. The EEPGL document did not provide the gas composition; the quantity of toxic compounds and impurities are unknown. The current contemplation in the EEPGL document was treating process waste water in oil water separators and the ‘clean water’ from the oil separators will be released into detention ponds created primarily to collect rainwater from the plant premises. The question is what will be the specification for the so-called clean water from the oil water separators before releasing into the detention ponds and how will this specification be enforced? Eventually, this water in the detention ponds will be released to the local waterways.
No information was provided on the separation and disposal of mercury from the process stream. Further being contemplated was shipping residual oil waste off-site for disposal. EEPGL expressed concern over Guyana’s waste management capacity to store and treat off site waste. How is this being addressed?
In good conscience, EPA management must address the concerns raised, so that the public would have trust in the agency’s ability to regulate industry and protect the environment.
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