Emphasising there will be no production of radioactive waste and no disposal of disused sources within Guyana, the Environmental Protection Agency (EPA) has exempted the proposed operation of the radioactive source storage and calibration facility at Houston, East Bank Demerara from an Environmental Impact Assessment (EIA).
This disclosure was made public in a notice published yesterday in the Guyana Chronicle’s Pepperpot Magazine. It comes months after SLB Guyana, formerly Schlumberger Guyana Inc, filed a new application with the EPA for the operation of a radioactive source storage facility at Lot 1 Area X Houston.
The application was made subsequent to a court ruling by Justice Nareshwar Harnanan. He had ruled that the EPA breached its statutory duty by issuing environmental permits to Schlumberger Guyana Inc and waiving the requirement for an EIA for the construction of a radioactive chemical facility.
In yesterday’s notice, the EPA said the project was evaluated as per section 11(2) of the Environmental Protection Act. It said it took into account “the Project’s Site Verification Report, Environmental Assessment and Management Plan, 2022, Project Summary, the International Atomic Energy Agency Safety Standards, and Security Guidelines, the Application submitted, and further relevant environmental information. Based on this assessment, the EPA has concluded that the environment will not be significantly impacted by the project. Thus, the project is exempted from the requirement for an EIA.”
Providing grounds for waiving the EIA, the agency said disused sources will be returned to their respective manufacturers or suppliers outside of Guyana. It stated too that the current location does not require the transport of the sources along main public thoroughfares. “… All calibrated sources are returned offshore via vessels leaving the port west of the facility. Internal transport reduces the risk of accidents, loss, and public exposure to radiation during transportation,” the notice said.
Further, it explained that the inventory of radioactive sources submitted with the application fell under Categories 3-5 as per the International Atomic Energy Agency (IAEA) Categorization of Radio-active Sources (No.RS-G-1.9). “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,” the EPA said.
To address this concern, the EPA said the facility will calibrate and store sealed radioactive sources 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. Proper shielding and distancing can significantly reduce the risk of radiation exposure to the public, it said.
The operation, EPA indicated, has demonstrated adequate safety and security measures to effectively limit public exposure to radiation in keeping with the IAEA Safety Stand-ards. The source storage pits, the agency explained, are constructed with 300 mm thick reinforced concrete and lined with 7 mm thick carbon steel plates, providing optimal shielding to restrict the movement of radiation waves.
“Results of a radiation assessment at the storage and calibration building indicated an average cumulative annual radiation dose of 0.931 mSv/y within the building, which is within the IAEA public dose rate of 1 mSv/y. Moreover, the assessment has determined that the radiation dose at a distance of 30m from the storage and calibration building is 0.001 mSv/y, which is significantly below the IAEA’s standard for public exposure,” the notice said.
It was noted that air emissions from the facility will be generated by a sole stationary source, a 550kW diesel standby generator, and mobile sources transporting the sealed sources within the facility’s compound, which will release CO, NOx, SOx, and VOCs particulates from the combustion of fuel.
The EPA said that the company has demonstrated using the best available technology, such as spark arrestors, and practices, such as regular preventative and corrective maintenance of engines to reduce emissions. An air quality assessment indicated that the NO, and SO, at the facility were below the World Health Organisation limits for the respective gases.
Additionally, the environmental agency explain-ed, water used in the calibration process to effectively attenuate the ionising radiation will be recycled and reused by the operation and not directly discharged into the local drainage system. The conduct of wipe tests to determine the presence of removable radioactive contamination on the surface of the sealed source will prevent and reduce the likelihood of radioactive material being released into the water.
“In the event of flooding, the concrete and steel pits can withstand corrosive fluids at elevated temperatures of 225 °C and pressures of 20,000 psi. Continuous radiation dose rate measurements are also done along the Source Storage and Calibration Building to assess whether cumulative radiation exposure remains within the required limit,” the agency added.
Yesterday’s notice said that any person who may be affected by the proposed project may lodge an appeal against the agency’s decision (EIA not required) with the Environmental Assessment Board (EAB) within 30 days. Appeals should he addressed to: The Chairman, the Environmental Assessment Board and emailed to eabguvana21@gmail.com
When the company hosted a public engagement back in February, residents including litigants Vanda and Danuta Radzik strongly objected to the presence of the radioactive storage facility.
Contacted yesterday, Vanda Radzik told Stabroek News that they will be speaking with their lawyers and objecting to the EPA’s exemption. She said she could not elaborate on the issue as she had not seen the notice.
During February’s public engagement held at Parc Rayne, Houston by IMEX Inc, which has been conducting consultations on behalf of SLB, residents had made it known that they were neither pleased nor convinced that the explanations given were sound. They said the company’s objective was making money and the explanations were intended to make the company “look good.” The moderator at times found it difficult to manage the strong views of the residents as they spoke over those from the company who attempted to address their concerns.
“I want to tell you, we the residents say X on the operations – we do not want you here,” an agitated resident announced during the question and answer segment. This announcement was greeted by cheers from the dozen residents gathered.
SLB’s in-house attorney Kyle Prescod explained to Stabroek News that a riverine community was suitable since it eliminated the dangers of road transportation. He stated that the pits for the storage of the RA materials are built taking into account proximity to the river. When the sources, which are battery sized, enter the country, they go to the facility for storage in the pits. When required offshore, they would be taken out, calibrated into the tools and sent offshore, he explained.
James Dough Aifken, described as an expert in radioactive materials and a consultant to SLB, explained that at no point was a radioactive source completely out and exposed. During the question and answer segment, he had said that the material is used for powering the drills for offshore exercises. He also stated that the sources were always protected by shields and if ever exposed, it would be during drilling, but even in that phase, once exposed they would be encapsulated and not dispersed.
However, Danuta Radzik had said during the consultation that they were not convinced the operation was safe enough to be in their community. She had pointed out that Schlumberger did not have squeaky clean safety records as a simple Google search had revealed a number of violations and breaches the company had been fined for in the past.
Justice Harnanan, in his December ruling, noted that the EPA had not given reasons for its decision. As a result, the judge ordered the quashing of the environmental permit issued by the EPA on June 9, 2021 in favour of Schlumberger to permit it to construct a radioactive substances and materials storage and calibration facility at Lot 1, Area X, Houston. The judge also declared that the decision by the EPA to not conduct an EIA into the effects of the construction of the facility was illegal, ultra vires, unreasonable, and irrational, for breaching the Environmental Protection Act, Cap.20:05.
During arguments, the EPA said that permission was given for the construction of the facility and not for the operation of a radioactive substances and materials storage and calibration facility. However, the judge ruled that the operation and construction must not be viewed separately. In the court’s view, he said, the EPA cannot treat the operation independent of the construction permit when it is a condition precedent to the functionality of the facility.
The Radziks and Raphael Singh, via court filings, had said that they live near the radioactive facility, which is also in proximity to schools and places of worship. They contended that the EPA’s decision was made without any consultation with residents. They accused the EPA of having arbitrarily made the decision in breach of its statutory duty and contrary to natural justice. They said, too, that it was made in the absence of evidence, was unfair, unlawful and unreasonable, among other things and asked that the court so declare.
