1. Introduction

2. Executive Summary

3. Sampling Sites

4. Ecological Baseline Study

Under contract to Arc Ecology, on behalf of the United States Working Group for Philippine Bases Cleanup and the People's Task Force for Bases Cleanup, Clearwater Revival Company (CRC) prepared this technical review report of the following document:

Woodward-Clyde, 1997, Environmental Baseline Study, Final Report-Volume I, Executive Summary," prepared for Subic Bay Metropolitan Authority, February.

Woodward-Clyde, 1997, Environmental Baseline Study, Final Report-Volume II, Environmental Quality Survey," prepared for Subic Bay Metropolitan Authority, February.

Woodward-Clyde, 1997, Environmental Baseline Study, Final Report-Volume III, Environmental Quality Survey," prepared for Subic Bay Metropolitan Authority, February.

Woodward-Clyde, 1997, Environmental Baseline Study, Final Report-Volume IV, Ecological Baseline Study," prepared for Subic Bay Metropolitan Authority, March.

The Environmental Baseline Study (EBS) for the Freeport Zone was completed for an area of the former US Navy Subic Bay Military Complex. The EBS consisted of an Environmental Quality Survey (EQS) and an Ecological Baseline Survey.

The purpose of CRC's technical review was to determine if the conclusions of the EBS are technically sound. CRC's reviewed the assessment methods, sampling plans, and risk screening methods used during the EBS for consistency with practices commonly used to perform environmental assessments on industrial property.

It is CRC's opinion that the EBS does not accurately characterize contamination at the Subic Bay Freeport Zone, and the potential for adverse impacts to human health and the environment.

CRC's opinion is based on the following facts:

1. The EBS does not assess all areas of the Freeport Zone, and does not include known environmental hazards such as unexploded ordnance, asbestos, lead-paint, and radioactive materials.
   
2. Site reconnaissance was not performed inside buildings during the EQS.
   
3. The EBS does not adequately characterize historical land-uses and the potential for contamination relying instead on incomplete information.
   
4. In the absence of complete historical information the EBS fails to perform a comprehensive sampling plan. Sample locations were limited to selected sites and sample densities as low as one sample per six acres were used.
   
5. The Sampling plan was technically flawed. Samples were not collected at depths at which contamination would be expected to be found.
   
6. The EQS failed to characterize the extent of soil and groundwater pollution.
   
7. The risk screening results are not reported. The one summary of chemicals of concern does not reference petroleum hydrocarbons.
   
8. The recommendations and cost estimates for remediation and further investigation should be viewed as preliminary. These proposed actions and associated cost figures cannot be accurately determined with the existing investigation data.
   
9. The EQS contains numerous misrepresentations, errors and omissions which undermine the credibility of the conclusions reached within.

It is CRC's opinion that the results of sampling performed during the EBS indicate that existing environmental conditions within the Freeport Zone present an imminent and substantial endangerment to human health and the environment.

CRC's opinion is based on the following facts:

1. The potential for exposure to uncontrolled toxic waste sites identified throughout the Freeport Zone.
2. The potential exposure to unexploded ordnance (UXO) in the Freeport Zone and surrounding Subic Bay waters.
3. The potential presence of methane gas in explosive concentrations near landfill areas and other areas where extensive petroleum contamination is found.
4. The potential presence of toxic gases (such as the vinyl chloride found at Site 40) in landfill areas and other areas where extensive contamination is found.
5. The potential for health impacts to subsistence fisherfolk from the accumulation of toxics in fish and other marine life residing in Subic Bay waters.
6. The potential for health impacts from exposure to hazardous waste in fill used in reclaimed areas.
7. The potential for exposure to asbestos during construction and demolition activities.
8. The potential for health impacts from exposure to unidentified "hot spots."

CRC's comments have been organized into two sections. Section 2.0 specifically addresses Volume I, the Executive Summary and comments on the objectives, scope and limitation of the EQS. Section 2.0 also addresses the site history and site characterization, and how this information was used to evaluate the potential for, and significance of toxic contamination. Section 3.0 addresses the individual findings and recommendations for the 44 sites investigated during the EQS sampling. Section 4.0 addresses the findings and recommendations of the Ecological Baseline Study.

CRC's comments are limited to the first three volumes of the EBS. Volume IV primarily contained the results of fauna and flora surveys, and the results of air and water quality studies that did not deal specifically with toxic materials.