Dear Editor,
In September the Environmental Assessment Board held a public hearing into the EPA’s exemption of an EIA for Schlumberger Guyana (SLB). In our presentation on September 6, we 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. We also expressed concern about SLB safety record where between 2002 and 2008 SLB lost two radioactive sources – one on the side of the road, and one on the drill floor of an oil rig, exposed 31 workers to an unshielded well-logging source, failed to keep 13 public radiation doses within the Nuclear Regulatory Commission NRC limits, failed to remain in control of a well-logging source and failed to follow emergency procedures after source was found.
In 2019, a chemical spill occurred at the Lombard Street wharf of GNIC, from a container that belonged to Schlumberger. The EPA announced it would institute a $1M penalty against Schlumberger as SLB never moved the container after GNIC cleared it. In SLB project summaries 1 & 2, which can be accessed on the EPA’s website, SLB says it has 19 storage pits to hold its sealed radioactive sources (SRS). However, SLB project summary 2 (April 2023) lists 128 SRS and project summary 1 (Dec 2020) 149 SRS. A comparison between the two project summaries indicates many differences, of significance is that 100 Cobalt 60 pip tags identified in project summary 1 are completely absent from project summary 2. Cobalt 60 is one of the radionuclides which can be used in the manufacture of dirty bombs. Applicants and other residents need to know how many SRS are currently in use and how many of these pits are being utilized? Are these sealed sources being placed one on top of another so they can fit into the 19 pits? How many SRS would be in use offshore at any one time? And were all the 100 Cobalt 60 Pip Tags lost? None of these questions were answered by SLB at the public hearing.
An international requirement set by the IAEA the International Atomic Energy Agency 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 or SRS type or number. Questions were also asked as to the adequacy of 19 pits to hold an increased number of SRS and perform an increasing number of calibrations as oil exploration, drilling & production expands with Liza 1 & 2 in full production, Payara expected to come on stream shortly followed by Yellowtail and Uaru. In this context, it must be assumed that the use and calibration of sealed radioactive sources will also increase exponentially, most likely, resulting in higher and or more frequent radiation in and surrounding SLB’s calibration facility affecting workers, applicants, and families in surrounding communities, including school children whose vulnerability to radiation levels is at a much lower level than for adults. We also asked for SLB and the EPA to explain how these measurements utilizing SRS during the past 8 months were done, as a Court injunction and cancellation of SLB’s environmental permit for its Radioactive Storage and Calibration was and is still in effect since Dec 16, 2022, and if not SLB, who were doing these ‘essential’ measurements?
Having learnt that there were 2 or 3 others performing these measurements at the hearing, we call on the EPA and SLB to immediately clarify this issue as SLB is the only company in Guyana, as far as we know, who was authorized to store, calibrate, and utilize SRS for the oil & gas industry in Guyana. Queries and concerns were also expressed about extrapolating radiation levels to calculate yearly and hourly radiation doses and levels in SLB’s Source Storage and Calibration facility and perimeter fence based on one day and 3-month readings. This needs a much fuller technical explanation through an independent EIA as well as the availability of frequent monitoring of radiation levels in and around SLB’s Radioactive & Source Storage Facility based on international best practices. SLB is on record that low doses of background radiation are present in everyday life; so why were there so many recordings of M=No radiation in this facility? (Appendix 7, Radiation Monitoring Report). Concern was also expressed about the absence of baseline studies on background radiation levels around SLB’s facility or at GYSBI site or at nearby communities including the Houston School prior to start up, construction and operations. Since the EPA has no specific – safety standards for radiation protection, permissible doses and dose limits, nor specialized regulations or codes of practice, by what means are they exempting SLB from an EIA where such standards must be carefully scrutinized and monitored?
Major differences were also apparent as to the purpose of a 300mm trench in the calibration room, this changed from minor washing of downhole tools to a storage trench for filling a calibration tank and as a secondary containment for this tank. From March – April 2022, SLB generated 10.44 metric tonnes or 10,440 kilograms of ‘Sump Water’ from this 300mm tank according to the EPA. There is no mention of ‘Sump Water’ in SLBs project summaries. SLB referenced GWI as its receiving water source (pg 17 1.10.) It is either that the person writing the project summary does not understand what ‘receiving water’ refers to, or if not, it is highly alarming that SLB would be sending its wastewater to GWI. GWI is not a hazardous waste management company or a river, ocean, stream into which wastewater or treated effluent can be discharged. Previously in summary #1 receiving water was identified as the Demerara River. Another major area of concern raised was SLB’s liquid mud plant. SLB has 32 large tanks labelled on schematics plans in its project summaries as ’mud plant’, a photo was shown of their location, number of these extremely large tanks, four of which are at least 30ft high. SLB’s liquid mud plant is part of SLB’s integrated ‘single facility’ which includes source storage and calibration facility, mud plant, workshop and bulk storage facility. SLB’s in its article –’Designing & Managing Drilling Fluids’ says “chemical properties of drilling fluids are central to the performance and stability of wells and lists these essential chemical substances.” Forty two (42) of these chemical substances safety sheets, for MI Swaco, a SLB company, can be found on EPA’s website in EEPGL’s Comprehensive Waste Management Plan (CWMP). Thirteen (13) of these chemicals & substances are classified by OSHA, NTP & IARC Group 1 as known human carcinogens (cause cancer), 41 out of the 42 chemicals and substances have the following environmental precautions- “these products should not be allowed to enter drains, watercourses or the soil and are not be released to the environment” 25 of these chemicals & substances are classified as IDHL – Immediately Dangerous to Human Life. 21 of these chemical substances are listed as having- Special Hazards i.e. being combustible and having unusual fire and explosion hazards including that dust or fumes may form explosive mixtures in air and suspended dust can present a dust explosion hazard and 7 of these are flammable liquids.
Additionally, according to EEPGL’s CWMP safety sheets ‘water based mud’ is classified as a Drilling Fluid made up of barite, bentonite, silica, crystalline, quartz, sodium hydroxide, calcium hydroxide with risks of acute oral toxicity, acute inhalation toxicity (category 4) , skin corrosion, serious eye damage, carcinogenic, produces hazardous combustion products -carbon oxides (COx), silicon oxide, sodium oxides and according to US State of California Safe Water & Toxic Enforcement Act 1986, this product causes cancer and or reproductive toxicity (US Federal & State Regulations). Guyana’s Pesticides and Toxic Chemicals Control Act Cap.68:09 2007, provides for the formation of a Pesticides and Toxic Chemicals Control Board and establishes requirements for registration, licensing, trade in toxic chemicals and regulates the importation, registration & use of such chemicals. In view of the (IDHL) highly dangerous to human life, cancer forming, highly combustible and dangerous to drains, water courses and soils chemicals; are the necessary requirements, registration, and licensing for importation of Mi Swaco chemicals in effect? Where and under what conditions are these 42 toxics, carcinogenic, highly dangerous to human life, highly combustible and dangerous for release into drains, canals, rives, waterways; chemicals/chemical substances stored, transported, and discharged?
Again, these questions and concerns went unanswered. Other important and relevant issues were raised on SLB’s industrial and hazardous wastes including if and how Naturally Occurring Radioactive Materials (NORM) and Technologically Enhanced Naturally Occurring Radioactive Materials TENORM is being generated and treated. Reasons why EAB must reject exemption of SLB from an EIA was already covered in one of Guyana’s daily newspapers so won’t be repeated here. Space does not permit us to go into further details. The EAB was sent the full power point presentation of these objections. We thank both KN and SN for their coverage of the hearing.
Sincerely,
Danuta Radzik
Vanda Radzik
Raphael Singh