Dec 05, 2021 News
By Davina Baggot
Kaieteur News – Oil giant ExxonMobil has failed to outline in its Environmental Impact Assessment (EIA) for the Yellowtail development, exactly how much waste would be generated and if the present facilities can accommodate same, even though this is a requirement by the regulatory body, the Environmental Protection Agency (EPA).
This is according to Environmentalist, Simone Mangal-Joly. In an invited comment, she said, “The Yellowtail EIA is significantly deficient in many ways. One of those ways is it does not account for how toxic waste brought to shore will be disposed of for the full life of the project. It treats very superficially with amounts of waste versus capacity for treatment and disposal for the lifetime of the project. Basically, it says that the current facilities and Haags Bosch site can handle it for now and new sites will be identified in the future. This is unacceptable.”
Esso Exploration and Production Guyana Limited (EEPGL), a subsidiary of Exxon in its Revised Cradle to Grave Waste Report alluded to systems it has lined up for the treatment and storage of waste; however, the document noted that of the four facilities, there are three that have no definitive startup period.
The planned waste management facilities include a new integrated waste management facility (IWMF) at GYSBI for managing wastes that are generated from offshore operations and is expected to be operational in July 2021. The (Sustainable Environmental Solutions) SES facility will employ various hazardous and non-hazardous waste management technologies, including hot oil thermal desorption, incineration, decanter/centrifuge separation, wastewater treatment, waste shredding, container crusher/baling, and container washing operations.
Secondly in line is an Oilfield Waste Management Services (OWMS) for which a permit application has been submitted to the EPA. The OWMS will be a 5,000 square metres (m2) drilling waste processing plant in the Little Diamond EBD area (located approximately five kilometres (km) south of GYSBI). It will employ thermal desorption separator (hammer mill) technology to treat drilling mud but it is unknown when the plant will become operational.
The third facility for Exxon’s waste management is also still awaiting approval. Environmental Waste Management Services Guyana Inc. (EWMSG) submitted a permit application for the construction and operation of a waste treatment (bioremediation) facility for mud sludge generated from activities in the Oil and Gas sector. The proposed location of the facility is at Friendship, East Bank Demerara. According to a EPA Public Notice issued in December 2020, the operation will involve the development of two treatment ponds lined with High Density Polyethylene (HDPE) Geomembrane liners and contained by 91.4cm high berms. In addition, four existing structures will be repaired and developed into administrative units, laboratories, storage areas, and homes for caretakers. A screen will be constructed to separate the office area from the treatment ponds. “The status of this application is not currently known, and it is also unknown when the EWMSG facility would become operational,” the Cradle to Grave Waste Report said.
The fourth project, which is also yet to become operational will be housed at the Guyana Shore Base Inc. (GYSBI). According to the report, “The non-hazardous wastewater from this washing operation is currently collected and treated in on-site evaporators—there is no discharge of this wastewater. This location is being considered as part of a feasibility assessment for developing a new Protectors Grinding and Pelletizing to exclusively and specifically manage used plastic drill pipe thread protectors that are generated from the pipe handling operations. Pipe thread protectors are designed to protect the critical threads of the steel pipes during storage, handling, and transport, and tens of thousands of these metal reinforced plastic caps will be generated as a result of offshore well installation operations. These used plastic caps will first be subject to grinding to separate the plastic and metal parts, and the plastic will then be melted and pelletized and returned to the original manufacturer as a raw material for the production of new plastic caps. The recovered metal will also be recycled. Although being considered, it is uncertain when this type of facility would move forward at this location.”
Mangal-Joly in her comments to this newspaper was keen to note that in the absence of such provisions, ExxonMobil must address this deficiency in the Yellowtail EIA.
She argued, “This matter should be of concern to all Guyanese. The quantities of toxic and other waste being brought to shore, health, and ecological risks of each of their constituent parts, and how they are treated and disposed of are critical issues, as the toxic waste treatment facilities are in areas where people live, all are high risk for flooding and creating a toxic soup on the coast, and our coastal groundwater aquifers are at risk. We stand to lose a lot. We need to understand the value of what we currently have and risk losing, both in terms of quality of life and health and monetary terms, and to protect ourselves and our valuable natural resources that could be despoiled.”
In fact, she said that the Yellowtail EIA cannot be accepted as it stands, especially since oil was discovered since 2015.
The Environmentalist believes that this approach serves to hide the shore-based impacts, including the cumulative impacts over time, from public scrutiny and from the impact assessment process. Even more importantly, it is in violation of the Environmental Protection Act.
Mangal-Joly insisted, “The Environmental Protection Act does not permit either the EEPGL or the EPA to cherry pick parts of a project for consideration in an EIA and leave out other parts. Section 5(a)(1) of the Environmental Protection Act is clear, the EIA – must address the “physical characteristics of the whole project and land use requirements”. The precise wording of “whole project” is meaningful because if you look at the lessons learned from early EIA processes in the 1990s, there was a lot of skullduggeries whereby some authorities were acting in collusion with companies to fragment a single project into parts that were addressed by different EIA processes to hide the true project impact and/or to expedite approvals. We must keep our eye on when this type of fragmentation is happening here in Guyana.”
In the case of Yellowtail, and all offshore oil and gas activities waste generated offshore is brought to shore. This waste only exists because of the activity offshore. “You can’t arbitrarily cut off the EIA at the point where the waste is brought onshore, you must account for the impacts of all the waste from cradle to grave, over the entire lifetime of the project, including the cumulative effects,” the Environmentalist pointed out.
As such, she said that a proper EIA would address the exact amounts of waste for the life of the project, the capacity and safety of treatment facilities, as well as the capacity and safety of the final resting place or dumpsite for the waste. Mangal-Joly noted that deterring such matters to the future amounts to a failure to meet the basic threshold of an impact assessment.
“The courts have ruled that an EIA cannot defer the quantification and assessment of waste impacts to a future date or dissociate such waste from their original source. So, in terms of our Environmental Protection Act and case law, these matters are not up for debate. To be valid, an EIA must address the waste impacts completely and the current EIA produced by ERM for the Esso, Hess and CNOOC consortium’s Yellowtail project does not meet this threshold,” she contended.
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