Kaieteur News – Residents of Houston, Raphael Singh, Danuta and Vanda Radzik, have urged the Environmental Assessment Board (EAB) to set aside the decision by the Environmental Protection Agency (EPA) to waive an Environmental Impact Assessment (EIA) for a hazardous waste facility to be operated in their neighbourhood, Houston, East Bank Demerara.
An application to operate the facility was made by Schlumberger Guyana Inc. (SLB) one of ExxonMobil’s contractors. It is expected to treat and store hazardous waste near the Demerara River, at the old Gafoors compound in Houston.
The EPA in April this year exempted the project from a thorough impact assessment, a decision which was formally appealed by the three Guyanese. On September 13, 2023, the three-member EAB, chaired by Dr. Mahendar Sharma hosted a Public Hearing at Parc Rayne, Rahaman’s Park, East Bank Demerara (EBD), where the citizens had an opportunity to raise their concerns. This process is mandated by the Environmental Protection Act.
Making presentations to this end were the project developer, the EPA and the appellants.
In their appeal of the waiver, the citizens explained that they have seen their land and properties devalued and now suffer from potential risks of not only radiation exposure, but fears of fires, flooding, chemical spills, unsafe transportation accidents during movement of hazardous wastes which can go on to contaminate drains which run the villages of Houston and McDoom, EBD.
Further, they pointed out that there is potential risk from spills during offloading and on loading of the waste materials to the facility, some of which are highly combustible.
The citizens therefore listed 15 reasons for the EAB to overturn the decision by the EPA for the impact study. Among those, they reasoned, “The EPA has a statutory duty to require an EIA to ensure that any activity which may cause an adverse effect…be assessed before such an activity should be authorized…4(1) (g) of the Act taking into account the “avoidance” and “precautionary” principles and any others.” This was part a of ruling handed down by High Court Judge Nareshwar Harnanan on December 16, 2022 with regards to the said project.
According to the appellants, “The EAB has a duty to ensure and guarantee the substantive and procedural environmental rights enshrined in the Constitution and binding human rights treaties such as Escazu. These rights include: The right to a healthy environment, public participation, access to information and access to justice in environmental matters.”
They therefore noted that both the EPA and the EAB must err on the side that affords the widest possible protection of constitutional rights and refer to the guidance of international human rights bodies in cases of ambiguity.
Furthermore, they shared that, “EPA’s April 16, 2023 Notice does not provide reasons for its determination that the storage and recycling of contaminated water and equipment at the Facility will not significantly impact the environment.”
That Notice from the regulator also failed to explain the reasons for determining that the Facility would not significantly impact the cultural heritage and landscape of what has traditionally been a residential area, the citizens contested.
They believe that the EPA has failed to consider reasonable alternative locations for the Radioactive and Source Storage Facility, its mud plant, workshop and dry bulk facility to areas with fewer risks to communities, schools, residences, the fishing industry, health centres, a congested East Bank Highway.
Singh and the Radziks were keen to note, “While there have been other commercial projects at Houston, the redevelopment of Houston as an industrial base for oil and gas operators is unprecedented and will have significant impacts on the environment, human health, cultural characteristics, geographic area and landscape.”
They told the EAB in a joint presentation, “What we have in Guyana is the cart before the horse. State agencies including the EPA have allowed the oil and gas industry in Guyana to operate largely unfettered in violation of our own environmental laws.”
Furthermore, the citizens said their constitutional right to a healthy environment, public participation, access to information and access to justice in environmental matters must be respected through the necessary baseline surveys, technical expertise, specific protective regulations, transparency, good governance and necessary enforcement for the oil and gas industry.
According to project documents seen by this newspaper, Schlumberger Guyana Inc. (SLB) said it is a registered contractor in Guyana and provides oil field services to the oil and gas industry. Specifically, Schlumberger Guyana Inc. provides upstream services with four primary areas of focus to include well construction, reservoir production systems, digital and integration and reservoir performance.
SLB said radioactive sources are used in the oil and gas industry for well logging and well drilling. The company said they are placed in tools that are lowered into the well, both on the drill string above the drilling bit during the drilling of the well (Well Construction) and on wireline lowered into the already drilled well (Reservoir Performance), in order to determine details of the formations passed through (lithology, porosity, fluid content, etc.). These measurements are of fundamental importance both during the drilling and afterwards to determine the success of the well.
SLB was keen to note that it invented the technology of lowering measuring instruments into wells to evaluate the presence of hydrocarbons. Furthermore, SLB said it has been operating with radioactive sources throughout the world since the early 1950’s and has been in the forefront in assisting regulatory bodies such as the US Nuclear Regulatory Commission in the formulation of regulations and safe operating requirements for the use of ionizing radiation in oil and gas exploration and production.
The EPA in announcing its decision to waive an impact study for the project earlier this year explained that the inventory of radioactive sources submitted with the application has been categorized under Categories 3-5 as per the International Atomic Energy Agency (IAEA) Categorization of Radioactive Sources (No.RS-G-1.9). The EPA said it is important to note that the IAEA has specified that these sources may only pose a potential risk to individuals close to them when they are unshielded, with typical durations ranging from days to weeks.
Furthermore, the EPA said the facility will calibrate and store sealed radioactive sources, meaning the radioactive material is enclosed within a tightly sealed capsule, surrounded by layers of non-radioactive material, and securely affixed to a non-radioactive source, effectively preventing any potential leakage or environmental release of the radioactive material. It said too that proper shielding and distancing can significantly reduce the risk of radiation exposure to the public.
Research by this publication shows that exposure to radioactive waste can cause cancerous growths in humans and genetic damage or mutation to animals and plants. Scientists believe these changes could prevent sustainable procreation.
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