According to the provisions of the Petroleum Production Licence (PPL) for the US$10 billion Yellowtail Project, ExxonMobil Guyana is required to conduct an in-depth study on the feasibility of re-injecting produced water. It is expected to do this while ensuring that the base design for the project includes tie-in points and space for produced water injection equipment.
The licence specifically notes that within 30 days of the date of Environmental Permit (April 1, 2022), the licensee must submit to the subject Minister and the Environmental Protection Agency for approval, terms of reference, methodology and work plan (including the schedule of activities) for a study detailing the costs, environmental benefits, and feasibility of implementing a system for the re-injection of produced water, save and except in defined unavoidable situations, as the primary disposal method. The study is expected to consider the effects of discharging produced water into the ocean in a manner that is in-keeping with industry best practice.
The in-depth study is also required to examine the environmental effects of produced water, its chemical additives for the Yellowtail development and the likely potential cumulative environmental effects from existing and future developments.
Furthermore, the licence notes that the study shall not commence without the prior written approval of the Minister.
Within 180 days of the date of the Minister’s approval of the terms of reference and methodology, or such later timeline as directed by the Minister, the licensee shall complete the study’s final report.
During the pendency of the study, the licensee is expected to meet with the Minister and/or his representatives no less than every 30 days, or more frequently on request, to provide an update on the progress of the study, discuss the issues raised by the study and come to an agreement on resolution of issues and/or concerns regarding the study.
Thirty days before completion of the study, the licensee will issue a draft final report to enable the Minister to provide input into the final report. The final report would not be deemed final until approved by the Minister.
Additionally, recommendations contained in the final report which have been approved by the Minister shall be implemented by the Licensee within such timeframe as indicated in the final report.
Finally, the licensee is expected to permit a duly designated representative(s) of the Minister, or the Chief Inspector, to have all access, and shall provide all cooperation and support needed for the collection of treated produced water samples, through the conduct of random sampling or otherwise.
ExxonMobil had come under criticism last year from some local environmental activists because it discharged produced water from the Liza Phase 1 operation into the ocean, which was in keeping with the terms of the permit at the time. Government responded by including in newer permits that there should be tie-in points for re-injection equipment and studies to determine the way forward.
Exxon has noted that its decision to discharge produced water into the ocean is in-keeping with industry best practice.