EXXON #$$$^** Mobil & #$$$^** Guyana
I am Ryan #$$$^** Crawford, a kind of social media trend for the Guyanese community in September 2018. Frustration, entitlement, making sense out of the absurdity of our times. As an environmental engineer I wonder what our field misses that we are so many times band aids on bad decisions. While some get to “innovate” with chemicals that suck our income and make their way into our bloodstream unchecked, we get stuck cleaning up the junk in a HAZMAT suit with not enough funding. I wonder how to build public discussions around our health and wellness which indirectly means the water we drink, air we breathe, food we eat, built infrastructure we use, spaces we live, etc. etc.. So, to see Guyanese engaged on social media by a short video clip and Ryan #$$$^** Crawford, I wonder if that’s what’s needed to get even more discussion on EXXON #$$$^** Mobil & #$$$^** Guyana.
In the earlier part of this year, Roweena Ramlall, a University of Guyana student who I met in 2013 while leading the Sagicor Visionaries Challenge on behalf of the Caribbean Science Foundation, alerted me to the public comment period on the Environmental Impact Assessment (EIA) for the Liza Phase 2 development. I used a cover photo of a modeled trajectory of a small oil spill from the report from June 17th until comments closed on August 14th, 2018.
My caption read, “Deepwater Horizon spilled 4.5 million barrels of oil from April 20 to Sep 19, 2010. This model done by ExxonMobil for its EIA for Liza Phase 2 Development project in Guyana assumes 20,000 barrels of oil per day for 30 days to look at where the oil would travel. If the same amount were to spill from Guyana, it would do so for 245 days and not 30. Someone in the oil industry who has worked in the Atlantic region around Guyana could enlighten us as to why the scenarios would be totally different and we would expect a cap in 30 days. 60 days to review the EIA for the LIZA Phase 2 Development Project. Urged by Roweena Ramlall to exercise your civic duty and read the documents. It’s over 700 pages long, so we need to be strategic with ensuring every section is read.”
The EIA document was in a rar file, so I posted the pdfs of the EIA to make it more accessible to persons, like myself, who had difficulty opening the format shared by Guyana’s Environmental Protection Agency.
The week before comments closed, Wayne Forde and Laura George joined me in a virtual “study group” to discuss the EIA. Some of us submitted comments via email to the EPA before the deadline. Below are those submitted by me.
Comments submitted by Maya A. Trotz, Ph.D. to the Environmental Protection Agency of Guyana on “Environmental Impact Assessment Esso Exploration and Production Guyana Limited Liza Phase 2 Development Project.”
I have read the documents provided online for the Liza Phase 2 Development Project in Guyana and hereby would like to officially lodge the following comments:
1. Stakeholder Engagement
a. The project has 2 tiers of engagement, one being information sharing and the other being consultation. A major question is the way in which information is shared and how citizens are prepared to meaningfully participate in consultations and decision-making processes. For example, in terms of indigenous populations, how is the concept of an oil rig and oil spill communicated given this is the first time this activity is being done in Guyana? Which Guyanese have had opportunities to tour similar sized operations in other parts of the world and to speak with communities, like those in the Gulf of Mexico, who have experienced an oil spill? It seems as though the level of preparedness of Guyanese to engage with this EIA etc. does not provide enough background exposure needed to comprehend the extent of the business, its potential impact, and what is needed to consider for quantifying properly the impact on the environment and human life/livelihoods.
b. Given the indigenous populations along the coast rely heavily on the marine environment for livelihood and beliefs etc., is project information translated into their indigenous language? What is their access to the internet given the ExxonMobilGuyana Facebook page is cited as a tool being used to engage citizens? The EIA was available for download from the EPA website or persons could pay the cost of copying. What is the cost and how is this provided to communities/villages ahead of EPA led presentations? Consideration of access to information for diverse Guyanese populations must be addressed properly in engagement plan.
c. Details of the stakeholder engagement sessions and materials shared during those sessions should be made publicly available. The number of attendees per village should be documented and shared as well.
d. How is the project building local capacity in those villages to be resilient to an oil spill?
e. How is the project linking indigenous knowledge into the monitoring and reporting that is required to determine project impacts? How are indigenous populations being paid to participate in this type of critical monitoring over the project’s 20 year production cycle plus the start-up years, some of which have already passed?
f. How are groups like the Amerindian People’s Association integrated into the stakeholder engagement plan and paid for that meaningful engagement?
g. How are the University of Guyana and other educational institutions integrated with working with communities in Guyana, especially indigenous populations to document.
2. General comments on monitoring
a. What facilities exist in Guyana for conducting water quality, marine, air quality, hazardous waste monitoring? It would be good to list those, instruments available in country, detection limits, trained staff etc.. If that capacity is lacking, the project needs to establish it immediately and provide requisite training of Guyanese through partnership with laboratories/researchers familiar with the types of contaminants and phases that require analysis.
b. How does the local Environmental Protection Agency or relevant agency conduct independent chemical analyses and checks on the oil operations at sea and on shore?
3. Sections 2.10.3–2.12.4
a. What are the waste management facilities in Guyana treating?There seems to be an incineration unit of some sort, what are the pollutant levels and how are those being monitored? What equipment or laboratory that is independent of the oil company, is the Guyana EPA using and what are their analytical capabilities? Please be specific and identify the waste facilities in the Caribbean or Guyana that will handle the hazardous waste from the operations. In the event that the Caribbean lacks adequate facilties to handle hazardous wastes, what is proposed to ensure operations meet at least standards used in the US?
b. The chemical inventory list uses very generic terms. A list of actual chemical names and associated MSDSs should be provided. The dispersants are not listed. Those should also be provided along with MSDS information and made available for studies on impact to marine environment.
c. How is the impact of disposing of 265,000 BPD of brine concentrate from desalinization on marine environment determined given studies are non-existent for this area? This research needs to be conducted and appropriate levels of accountability put in place for any damages.
d. Black water disposal will follow MARPOL requirements — at that distance from shore does that mean no treatment will be conducted and it could discharge into the marine environment untreated? Please be specific on what this treatment will look like for a business operating at sea for 365 days x 20 years. Chlorine seems to be the only thing being measured — is the plan to chlorinate sewage directly? That makes little sense.
4. Section 2.1.6
a. The EIA believes that the project will benefit Guyanese through revenue sharing with EEPGL, however says that the extent of this benefit depends on how the government spends its share of income and that this is beyond the scope of EIA. It would make more sense for the EIA to remove this proclamation that the project will benefit Guyanese.
5. Section 9.1.9 (unclear numbering on downloaded document)
a. The FPSO has capacity to store 1,000,000 BOP. Why is this number or something close to it not used for determining impacts of a spill in the event something happens to the storage facility? If it can be discharged in 28 hrs, that’s certainly a lot more than was used to model either the 2,500 BOPD or 20,000 BOPD spill.
b. How are climate or terrorist threats incorporated into vulnerability assessment of systems to damage and therefore unintended releases?
6. Section 9.1.52
a. The simulations of sub surface crude oil spill were done for a 20,000 BOPD condition over 30 days. Given that Deepwater Horizon lasted closer to six months, why was 30 days considered? Also, why only 20,000 BOPD considered? The document states that maximum capacity of FPSO is 300,000 BOPD. Is the subsurface well supplying at a rate of 20,000 BOPD and there are multiple of those? Unclear from document.
b. It would be useful to see simulations for a longer oil spill and the maximum BOPD that can spill from one well.
c. Additionally, what happens if a spill occurs during an active hurricane — the intensity of which are expected to increase under changing climactic conditions. How does the model change for the Caribbean islands under such conditions?
7. Section 9.1.84
a. The document concludes that the risk to benthic species is limited and that the use of dispersants in deep water is “considered unlikely to result in additional harm to benthic species relative to undispersed oil”.
b. References made at the beginning of this section do not cite research conducted later than 2012 that is now dated. A recent study published by Buskey et al. (2016) concludes, “Overall, studies indicate that while the responses of various marine species to oil and dispersants are quite variable, a general picture is emerging that chemical dispersants may be more toxic to some marine organisms than previously thought, and that small oil droplets created by dispersant use and directly consumed by marine organisms are often more toxic than crude oil alone.” Buskey, E.J., H.K. White, and A.J. Esbaugh. 2016. Impact of oil spills on marine life in the Gulf of Mexico: Effects on plankton, nekton, and deep-sea benthos. Oceanography 29(3):174–181, http://dx.doi.org/10.5670/oceanog.2016.81.
c. Additionally, the EIA does not conduct any studies on the particular benthic species found in Guyana’s waters and how they would respond to either the type of oil found there or the particular dispersants included in the spill response plan.
d. Given this discrepancy, the impact from a spill and dispersants should be reevaluated to reflect current literature and appropriate mitigation steps included. Some of these steps should demonstrate the capability of Guyanese to conduct the research studies needed to understand this marine environment and how spilled oil and dispersants could harm it.
e. The same discussion can be applied to other marine life in terms of updating of literature given new studies emerging post Deepwater Horizon in the Gulf of Mexico.
8. Section 9.2.33
a. The document provides no in-depth analysis for the impact of an oil spill on places like Grenada. While it recognizes the importance of the tourism and fisheries economy to the country and the critical role marine habitats, like coral reefs, play in that regard, there is no information on the impact of oil on these areas. Based on modeling results from a 20,000 BOPD for 30 days, there is high probability that oil will reach Tobago and Grenada.
b. It is recommended that studies be conducted on the impact of an oil spill, even one greater than 20,000 BOPD for 30 days, for other Caribbean nations and that stakeholder consultations be conducted there to adequately quantify the economic and environmental impact.
c. Given that the Gulf of Mexico Research Institute was established with a half a billion dollars post Deepwater Horizon to start conducting baseline studies since the oil spill, it would make sense to establish such a Caribbean regional body that co creates knowledge on this area of the Atlantic as the oil is mined.
