Concerned citizens respond to EAB upholding EPA decision to exempt hazardous waste facility from EIA

Jun 09, 2024 Letters

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Dear Editor,

On April 24, 2024, the EAB, after seven (7) months of deliberations, finally ruled to uphold the EPA’s exemption of an EIA for Schlumberger Guyana Inc. (SLB) Radioactive Storage and Calibration Facility.

THE EAB in its ruling referred to Schlumberger Guyana Inc (SLB) Environmental Assessment and Management Plan (EAMP). However nowhere on the EPA website is this EAMP available. Neither has this EAMP been shared nor has there be any EAMP stakeholder consultations held with residents or communities situated in the area in which SLB operates as recommended by the EAB in the six weeks since this ruling. As such stakeholders have no access to this document and were never consulted by ACORN or anyone else in reviewing this EAMP. This is not the first time that the EAB in upholding EPA decision over the objections of citizens have referred to documents not available to stakeholders.

Concerns were also expressed in March 2023 that the EPA and the EAB were relying on documents for its decision to exempt EIAs while at the same time refusing to provide these documents to appellants and stakeholders.  This lack of transparency and accountability continues to be deeply concerning and raises questions about the fairness and transparency of the decision-making process of both the EPA and the EAB to make or uphold decision affecting the health, safety and well-being of appellants and stakeholders without their constitutional rights to access to information.

Appellants on September 6 stressed that what was before the EAB and the EPA was not only a radioactive source storage and calibration facility, but rather an integrated “single facility” involving the handling, storage, and processing of not only sealed radioactive sources but hazardous materials, chemicals and hazardous waste from a rapidly expanding oil and gas industry. We reminded the EAB that this type of integrated project is precisely the type of project contemplated in Section 17 of the EPA Act, which mandates the EPA to require a full EIA to identify and assess prospectively the cumulative effects of related activities. The EAB ruling has not responded to this issue.

And while the EAB and the current executive director of the EPA continues to justify the EPA’s power under the Environmental Protection Act to determine if a project warrants an EIA, what the EPA and the EAB fails to acknowledge is EPA’s “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.” Additionally, the lack of expertise and competency within the EPA to make informed decisions are gravely troubling.

At the EAB hearing into Schlumberger Guyana, the EAB Chairman asked the EPA to state qualifications within their agency on radiation competency. This revealed that no EPA staff or resource person had a BS degree or a MS or a PHD and the longest course any EPA person had undertaken was for 1 year and that was their radiation expert, who unfortunately, subsequently died. When then asked if there was other expertise on radiation within Guyana, the EPA’s expert referred to X-ray technicians. Equivalent to comparing chalk and cheese and soliciting surprise from even SLB representatives present. In the face of this lack of expertise and competency on radiation and radiation protection, how can citizens have confidence in the ability of the EPA as Guyana’s regulatory body and the EAB as the EPACT appeal body, to make well informed expert and scientific decisions including exempting SLB’s radioactive and source storage calibration facility from an EIA, thereby impeding citizen’s constitutional right to a safe and healthy environment. We also reject the imposition of an EAMP which has grossly failed to consult or even get any feedback from community-based stakeholders.

The EAB ruling failed to address the more than 12 different technical objections made by appellants. These included the failure to answer the adequacy of 19 source storage pits to hold not only the128 Sealed Radioactive Sources (SRS) but increasing number of SRS as oil and gas production expands with Liza 1, 2 and Payara in production over their safety limits. Neither was any explanations given of the 100 Cobalt 60 pip tags missing in SLBs project summary revised in 2021 and 2023, and the 8 Barium 133 SRS also missing in the 2023 revised report. It is known that the Cobalt 60 is one of the radionuclides which can be used in the manufacture of dirty bombs.

The International Atomic Energy Agency (IAEA) requirement is that all facilities and companies storing and using sealed radioactive sources, (SRS) must keep an updated registry of number, type, movement, lost, disused or spent SRS. The EPA as Guyana’s regulatory agency revealed that they keep a registry but failed to answer any questions about the discrepancies and missing SRS.

Major differences raised as to the purpose of a 300mm trench in the calibration room, which according to the EPA generated 10.44 metric tonnes equivalent to 264.17 gallons in just 2 months in 2022 remains answered. The EPA report was on hazardous wastes so it must be assumed that this referred to 264.17 gallons of hazardous wastewater and we do not known if this was a recurring monthly or bi-monthly.  SLB referenced GWI as its receiving water source in its 2023 revised project summary. This is highly alarming that SLB would be sending its wastewater to GWI. GWI is not a hazardous waste management company or a river into which wastewater or treated effluent can be discharged.

And while the EAB in its ruling has called for baseline monitoring to be conducted as part of Schlumberger Guyana Inc SLB’s permit including monitoring of radiation levels around SLB radioactive and source storage facility to be made public; since the EPA has no specific – safety standards for radiation protection, permissible doses and dose limits, specialized regulations or codes of practice who will be setting these standards and ensuring that independent monitoring is carried out and safe radiation levels are complied with according to international standards.

Yours sincerely,

Danuta Radzik

Vanda Radzik

Raphael Singh

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• Danuta Radzik, Environmental Assessment and Management Plan (EAMP), Raphael Singh, stakeholder, Vanda Radzik

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