Amid protest by residents of Coverden, East Bank Demerara, over the significant health risk posed by the setting up of a radioactive equipment storage facility in their community, the Environmental Assessment Board (EAB) has set aside a decision by the Environmental Protection Agency (EPA) that no Environmental Impact Assessment (EIA) is required for the project.
Non-Destructive Testers Limited (Guyana) Incorporated is joining with the National Hardware to construct the storage facility at Lots 1-2 Coverden, EBD. After the EPA had decided to waive the requirement for an EIA, the EAB received three formal appeals regarding that decision.
Having allowed due process, and considering all of the concerns, comments, and responses made during the public hearing, the EBA conducted a site visit on July 12, and rendered its decision on Thursday.
The appellants’ presentations outlined arguments that included exposure risk from the scope of activities of the project; risks of exposure of radioactive sources, leading to contamination of the environment; and the impact on lives and livelihoods of the Coverden community. The appellants also expressed concerns regarding the lack of baseline and effective safeguards, and the absence of communication with residents on the scope, impact, and implications of operations.
They questioned the potential impact on residents regarding exposure to radioactive sources, insurance coverage associated with the project, concerns regarding the proximity of the project within a residential area, and the specificity of screening for impacts for a project of this type.
The EPA presented a background to the project, an overview of the screening process results, and key reasons for the decision not to require an EIA. Public feedback following the presentations raised matters regarding the newness of the project area, and the concomitant uncertainties surrounding radioactive materials within the context of a populated community environment; the regulatory framework for a project of this type; and potential health hazards.
Scientific studies needed
The EAB, having thoroughly examined the assessment of the EPA, said that written information regarding the storage of the radioactive sources, and the oral submission of the potential use of these sources, changes the scope of the project.
“The risks which are identified and assessed may likely change, given expanded project scope. The absence of an identified procedure or plan to address exposure prior to project commencement is also noted. The new application of this source within the oil and gas sector, nested within a populated residential community, requires baselines to be established for monitoring, and proximity considerations for safety, without which effective prevention, management, and mitigation of risks would not be possible,” the EAB noted.
It further noted that the sensitivities toward the lives and livelihoods of the Coverden community, regarding the storage and potential use of radioactive sources within close proximity to residences, need to be addressed through scientific studies and effective engagement with the residents of Coverden throughout the process.
Purpose of facility
The developers are seeking to store radioactive sources at the project site. The EPA assessment as part of the Agency’s site verification outlines the use of radioactive sources on-site in its description of the operating process for the facility.
The approvals of the Neighbourhood Democratic Council (NDC) refer to welding and fabrication, as well as storage of X-Ray materials. The EPA and the developer expressed that the facility would be used for storage only, but there is a possibility that this can include the use of the sources.
It was highlighted that the type of risks that would be assessed, monitored, and mitigated would be different in an environment where there is the use of radioactive sources. The assessment of risks for storage, where there is a potential for use of these sources to be added, limits and/or invalidates the effectiveness of any identified mitigation measure.
Proximity to nearby residents
The proposed project location is within a residential community. While international standards on proximity have been shared by the EPA for projects such as these, regarding the specific parameters for the project site, there is no established set of guidelines to define the project structure with regard to safety and best practice in the absence of an EIA.
Baselines for monitoring
The project was presented as one that is new for the scale and type of application, though similar uses currently take place in the health sector.
The project, the EAB, and its application, the EAB said, are new to the oil and gas sector in Guyana, and more so, the embedding of this aspect of its application within a populated community.
Though information is available globally and regionally on a baseline level for monitoring impacts regarding environmental and human health receptors, this information is also needed at the local level, to enable effective monitoring, the Board said.
One example of the lack of baseline relates to groundwater level, which, based on the verification report, could not be confirmed, and is stated as unknown.
Without this, the EAB pointed out, there are inherent uncertainties that would be introduced in preventing, managing, and mitigating direct and indirect risks involved in the project.
Potential risks of exposure
The developer outlined several company-level procedures for mitigating identified risks. However, the EAB said the risks of exposure, and guidelines for treating events of exposure, are less clear. It further said the screening assessment that was completed focused heavily on mitigating risks, and less on preventing risks and treating instances of exposure. While some of this may be addressed as part of an Environmental Management Planning process for projects relating to radioactive sources, it noted, this becomes important for risk assessment, prevention, and exposure plans to be identified before commencement of operations.
The EPA Act requires full stakeholder engagement during an EIA process, and the EAB pointed out that the requirements for the application of a project do not necessitate engagement and feedback as part of the process of application. While this may not pose a significant challenge to projects that are more routine in their application, the EAB highlighted that the storage of radioactive sources within a community environment poses concerns for residents who, because of the lack of engagement, are not adequately informed, aware, or able to discern the potential risks or safeguard measures that may be present for a project of this type.
And while an Environmental Management Plan may provide for some aspects of this to take place, the timing of the engagement becomes of consequence, the Board added.
“Communicating with residents before project implementation: answering questions, clarifying areas of concern, and providing an opportunity to effectively engage with direct stakeholders of the project, is broadly recognised as an important part of the process for new projects, especially ones that involve the storage and possible use of radioactive sources.
“In view of the above, the EAB sets aside the decision of the EPA: that no EIA is required for the Project,” the EAB decision reads.
