ExxonMobil must re-inject oily produced water into wells rather than dump overboard – Environmental activist tells EPA

Mar 20, 2023 News

Fifth oil project…

Kaieteur News – Esso Exploration and Production Guyana Limited (EEPGL), commonly referred to as ExxonMobil Guyana, has submitted an Environmental Impact Assessment (EIA) to the Environmental Protection Agency (EPA) to consider in granting a Permit for its fifth oil project, Uaru- the largest offshore development to date.

The project seeks to develop up to 300,000 barrels of oil per day in the resource rich Stabroek Block.

Following the submission of the EIA to the regulatory agency on January 8, 2023, a 60 days public comments period was triggered, allowing members of the public to make written submissions to the EPA on the document.

Environmental, Citizen and Human Rights Activist, Danuta Radzik

Environmental, Citizen and Human Rights Activist, Danuta Radzik in her submission to the EPA made it clear that the oil company should not be allowed to dump toxic produced water (PW) overboard, but should rather re-inject the liquid into the wells.

Produced water is a liquid that is extracted during the oil production activities. It contains dissolved mineral salts, or may be mixed with organic compounds such as acids, waxes, and mineral oils. It may also be mixed with inorganic metals and byproducts or with trace amounts of heavy metals and naturally-occurring radioactive materials, the US Department of Energy said in a research paper. It is also usually very high in temperature, and can be deadly to marine organisms.

Exxon has opted to treat the produced water rather than re-inject it as the latter has been proven more costly. During the treatment process however, the oil company has subjected itself to standards that best suits its operation, rather than standards that reflect best industry practices.

Flagging these issues, Radzik in her submission explained, “According to the four leading authorities on oil and gas- OSPAR, IFC World Bank, the International Association of Oil and Gas IOGP and The European Commission on Best Available Techniques (Bat) on Upstream Hydrocarbon Exploration and Production, the best, safest, most environmentally sound system for produced water is re-injection back into an appropriate reservoir or well.”

She said that while a number of explanations have been supplied by Exxon for discharging produced water into the marine environment, one of the main reasons cited is cost of reinjection. Other reasons according to Radzik do not seem consistent with the leading authorities’ guidelines.

The Environmental activist argued that the developer is applying to continue its environmentally unsafe methods for dumping PW, as it did in the EIAs submitted to date for the Liza One and Two projects as well as the studies conducted for Payara and Yellowtail- the company’s third and fourth developments respectively.

She pointed out, “On page 67 of Uaru EIA under the heading Technology Alternatives, it says that “EEPGL is using the most appropriate industry proven technologies in developing its project, in terms of well drilling, drilling fluids…and environmental management.” Clearly, this is not the case as there has been no improvement neither any attempt on the part of EEPGL and Uaru’s EIA authors Acorn, to propose, modify or change unsafe and environmentally unsound practices as regards disposal of toxic produced water from FPSO’s into Guyana’s marine environment used in Liza 1, Liza 2 and to be used in Payara and Yellowtail and proposed again in the Uaru project.”

Radzik highlighted that Exxon’s Environmental Impact Statement discloses that some 300,000 barrels per day of produced water or 47,700 m3 per day is to be released daily. She was keen to note that these estimated figures may very well be much higher.

She said, “Uaru’s EIA says that produced water will be treated to meet World Bank Group EHS Guidelines for Offshore Oil & Gas Development 2015; IMO 2004 for in water of 29 mg/L monthly average and 42 mg/L daily maximum. However North East Atlantic OSPAR sets the goal for produced water as follows in oil and gas operations they “should ensure that plans to construct new offshore installations, or to modify substantially existing offshore installations should take as a point of departure the minimization of discharges and… the achievement of zero discharges of oil in produced water.” Additionally, a comparison of offshore operations in Norway in 2012 shows an average of dispersed oil in produced water to be 11.7mg/L. and according to Voldum et al, 2008 current equipment and processes for treating produced water are able to reduce levels to less than 5 mg/L.”

To this end, the activist argued that it is unacceptable for Exxon and its partners to continue to recommend that outdated levels for ratio of oil in water be used in new oil fields.

She said, “We demand that these OSPAR guidelines are made a requirement for Uaru and for any new oil field production coming on stream such as Payara and Yellowtail. If Norway could have achieved 11.7 mg/L dispersed oil in produced water in 2012 why can’t ExxonMobil and EEPGL set standard of zero oil in water as recommended by OSPAR in 2023.”

Radzik has called on the EPA reject Exxon’s plan to release produced water into the aquatic environment and instead put measures in place for re-injection.

• Environmental activist, ExxonMobil, produced water, Radzik, Uaru