EPA permits issued for Exxon’s projects have not been changed to remove restrictions on flaring

Aug 06, 2022 Letters

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Dear Editor,

In response to an unfortunate letter from former Executive Director of the Environmental Protection Agency (EPA), Dr. Vincent Adams, published this week in the local press, ExxonMobil Guyana provides this response to several inaccurate and misleading statements that Dr. Adams made.

ExxonMobil Guyana and its co-venturers are responsible for their activities in the Stabroek Block as provided by the Petroleum Agreement, the Environmental Protection Act, and other relevant laws, regulations, and environmental permits.  It is not an insurance company that is liable to the Government for these obligations, but ExxonMobil Guyana and its co-venturers.

Rod Henson, as the former President of ExxonMobil Guyana, never signed any document with Dr. Adams, in his capacity as a prior Executive Director of the EPA, committing to ‘unlimited liability coverage comprising of insurance plus parent company guarantee’, as Dr. Adams claimed.  After repeatedly making these claims, it only seems appropriate that Dr. Adams produce the “documents” he claims were signed.

ExxonMobil Guyana reiterates that it maintains full insurance coverage that meets international industry standards for all of its petroleum activities in Guyana. As previously stated, our first priority for all operations is to prevent adverse events by utilising the best technologies, processes, and people in our operations.  In the unlikely situation that an event occurs, we have established response personnel, procedures, and equipment aligned with the principles of the International Convention on Oil Pollution Preparedness, Response and Cooperation (OPRC), the Caribbean Island Oil Pollution Preparedness Response and Cooperation (OPRC), and the National Oil Spill Response Plan of Guyana.  We routinely conduct drills with the Government to ensure readiness.

Additionally, as recently reported in the media, Guyana will soon be the only country in the region (and one of very few countries in the world) with a subsea well capping stack on hand.  This equipment stops or redirects the flow of hydrocarbons, as part of an immediate response to a blowout, allowing time to permanently seal the well.

Neither ExxonMobil, the co-venturers nor their affiliates are involved in the operations in Peru where there was an oil spill earlier this year.  That event illustrated the importance of planning, preparing, and practising for response as we do with the relevant Government agencies in Guyana.

Production rates on the Liza facilities are maintained within safe operating limits at all times. Our Petroleum Agreement requires that the level of production shall be consistent with the maximum efficient rate which conforms to sound reservoir engineering principles in accordance with good international petroleum industry practice.  This requires that we evaluate actual capacities after a facility has been started up.   Any proposed change to safe operating limits is rigorously assessed and reviewed with the EPA and the Ministry of Natural Resources to ensure compliance.

Contrary to what was contended in Dr. Adams’ letter, the EPA permits issued for our projects have not been changed to remove restrictions on flaring. In fact, additional restrictions and fees on flaring were introduced such that flaring above background levels are only permitted under very narrow and clearly defined circumstances.

The modified Liza Phase 1 permit includes specific timelines for detailed instances of flaring, and notification and approval processes, during which the company must justify its reasons for flaring. The EPA reserves the right to reject a request if it finds those reasons to be unjustified. The permit strictly prohibits “routine flaring”, a term which excludes flaring resulting from the full or partial failure of any compressors, which is considered “non-routine flaring”.  The permit specifies that flaring is only permissible during commissioning, start-up, and special circumstances. It also requires the Permit Holder to pay US$50 per tonne of carbon dioxide equivalents (CO2e) emitted as a result of flaring in excess of permitted periods.

Dr. Adams continues to peddle the fallacy that a cut in production during the compressor issues would have eliminated flaring. The only way to have reached zero flaring was a complete shutdown of production. After the recent installation of a new gas compressor on the Liza Destiny FPSO, operations on Destiny and Unity are currently achieving background flare of less than one million standard cubic feet per day during normal operations consistent with their design basis.  Our focus continues to be on safe and reliable operations to deliver maximum value to the government and stakeholders in compliance with our obligations.

ExxonMobil Guyana has been diligent in documenting and reporting all emissions and releases to the EPA as required.  We are proud of, and stand by, our strong safety record as reported. The company has always been open and transparent about the volume of gas being flared and has routinely provided this and other operational information to the government, media, and other stakeholder groups.

To date, emissions of CO2e, resulting from non-routine flaring of gas attracting payments, amounted to 279,537.33 tonnes. ExxonMobil Guyana routinely provides reports to the Government authorities on its operations and earlier this year established a direct electronic data feed to the EPA and Ministry of Natural Resources.  In addition, multiple agencies visit the offshore facilities to inspect and verify the operations.  ExxonMobil Guyana continues to ensure its offshore activities are being conducted in adherence to the highest safety standards, industry best practices, and laws of Guyana.

As stated by ExxonMobil Chairman and CEO Darren Woods, the company is committed to Guyana for the long term. ExxonMobil Guyana has invested billions of dollars in multiple oil and gas projects here.  We are dedicated to avoiding any spill, but should one occur, we are prepared to mitigate and resolve it as quickly and comprehensively as possible.

We remain committed to our partnership with the people and government of Guyana as we continue to responsibly develop the country’s oil and gas resources. ExxonMobil Guyana welcomes dialogue and discussions of the oil and gas industry, and our operations in particular, based on fact and mutual respect. As a Guyanese, I find it incredibly disappointing that an individual who held a position such as Dr. Adams’ would be sharing such blatant mistruths. It begs the question whether he genuinely does not understand the issues or is bent on deliberately misleading.  I also say this because I understand, and appreciate, the culture at ExxonMobil Guyana and that of its leaders.  A key reason our Guyanese employees, including myself, value working at the company, is the ethical, thoughtful, consistent, and socially responsible actions ExxonMobil Guyana takes.  We can already see that these actions are enabling Guyana’s transformation and bringing sustainable prosperity for our people.

Regards

Janelle Persaud

Media and Communications Manager

Public & Government Affairs

Esso Exploration and Production Guyana Limited

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