2.1 OBJECTIVES, SCOPE AND LIMITATIONS OF THE EQS
Addressing speculation about contamination.
The stated objective of the EQS is "to address persistent speculation in the media that parts of Subic Bay are seriously contaminated with toxic wastes generated by the former US Navy activities and operations." The source of media speculation is stated to be two reports: (1) "Subic Bay Environmental Risk Assessment and Investigation Program," the World Health Organization Mission Report and (2) "Environmental and Health Impact Report on Known and Potentially Contaminated Sites at Former US Military Bases in the Philippines," prepared by member of the 1994 Positive Legacy Tour.
The EQS evaluation concurs with the speculation in these two referenced reports. About three-quarters of the sites identified in the two referenced reports were included with the 44 sites identified by the EQS as having the greatest potential for contamination. The EQS does not however, collect samples from 14 sites suspected as being contaminated in the two referenced reports.
The EQS also does not indicate that it intends to address speculation about contamination at Subic Bay that is found in a third document prepared by the US Navy. This document is not referenced in the discussion on previous reports of contamination.
Despite statements in the EQS to the contrary, the Freeport Zone is extensively contaminated.
The principle conclusion of the EQS is that: "Despite speculation of significant toxic contamination at Subic Bay in earlier desk top studies, the results of the present sampling and testing program has not identified widespread severe contamination of soils, groundwater, or sediments as a result of former US Navy activities." The results and recommendations of the EQS, however, contradict this conclusion.
The EQS recommended that 24 sites that were speculated to be contaminated, either require remediation, or require further investigation prior to reuse. The EQS estimated a cost of $175-250 million pesos for environmental remediation work at 13 sites. The EQS also recommended that 11 sites be further investigated at an estimated cost of $35 million pesos.
Environmental Baseline was not established.
A stated objective of the EQS is "to develop an environmental baseline to assist SBMA in planning." In establishing an environmental baseline for contamination on a property it is important to sample for not only the hazardous materials that may have been stored, handled and disposed of at a site in the past, but also to sample for materials that may be stored, handled and disposed of at the site in the future. The environmental baseline would therefore establish liability for pre-existing contamination.
The EQS fails in its objective to establish baseline for environmental quality because it did not involve collection of soil and groundwater samples from leased areas where hazardous materials are currently stored and handled by SBMA tenants. It is noted that several SBMA tenants were sophisticated enough to conduct an independent environmental baseline study.
The importance of establishing an environmental baseline is evident in the groundwater monitoring results reported in the EQS for Site 15 - Naval Exchange Compound. The difference in petroleum concentrations in groundwater between the initial and confirmation sampling rounds indicates a release occurred during this time. Petroleum groundwater concentrations had increased up to 1,000 times.
Preliminary Human Health Risk Assessment not performed.
Task 5 of the EQS scope calls for a preliminary human health risk assessment to be performed. No estimate of human health risk has been reported in the EQS. Notably, no air sampling occurred. No models were proposed to estimated soil and groundwater contamination's impact on air quality, particularly, indoor air quality. Human health risks from inhalation of contaminants have not been evaluated.
While inhalation was ignored, the combined effects of soil and groundwater contamination were not evaluated. The EQS states that the additive affects of multiple contaminants were analyzed, but the results of any such analysis has not been presented.
Study limited to developed areas.
While the Freeport Zone consists of 24,000 hectares, the EQS study area "was restricted primarily to 10,000 hectares of developed land" Among the areas for which no sampling is conducted is Redondo Peninsula, Grande Island, housing areas, and the outer parts of Subic Bay waters. These areas were identified as sites of known or potential contamination in previous reports. The EQS also indicates that the potential for contamination exists in these four areas. Underground fuel storage tanks, pesticide use, and PCB transformers are noted as present in housing areas. The potential also exists for lead-based paint, and asbestos to be present in housing areas. The Binictican Filtration Plant (underground storage tank), Dewey High School (oil and PCB spills), the Mt. Santa Rita Radar Station (underground storage tank and PCBs), Grande Island Recreation Activities (fuel storage tanks). and the Redondo Peninsula Live Firing and Training Ranges (UXO, metals and explosive residues), all contain potential environmental concerns which were not investigated during the EQS.
A comprehensive Asbestos survey is needed.
The EQS doesn't address asbestos because "remaining asbestos does not pose an immediate risk to human health at its present state because it is either intact inside buildings, or securely buried in the landfill." Given the amount of construction at the Freeport Zone, a comprehensive asbestos survey is essential in order to control friable asbestos, and minimize exposure to construction workers, SMBA employees, visitors and surrounding communities. The EQS identifies during its site reconnaissance several locations with evidence of construction debris disposal and notes that asbestos may be present. It also reasonable to suspect that asbestos insulation was disposed of and replaced during routine maintenance at the Ship Repair Facility (SRF). No reference to an insulation shop in the SRF is made in the EQS.
A comprehensive survey for UXO is needed.
UXO may be found at Subic Bay due to training ranges, disposal practices for explosives and World War II attacks. The EQS doesn't address unexploded ordnance except (1) to note that the ranges where UXO may be found are accessible to the public who routinely scavenge for recyclable metals; and (2) to recommend that a specialists survey and clean-up program be carried out.
A comprehensive survey for Radioactive Material is needed.
The EQS notes that radioactive materials were handled at the Freeport Zone for medical and engineering sources and no information exists to indicate how these materials were disposed. Radioactive materials were not included in the EQS because "during the life of the base, US Navy regulations imposed strict controls." The EQS goes on to recommend that the former waste disposal area (Site 14) be surveyed by the Philippine Nuclear Research Institute. At US Navy facilities throughout the continental US, radium is found, often in significant quantities, in waste disposal areas and sewer systems due to the lack of controls imposed by the US Navy. The US Navy used radium to illuminate aircraft gauges until the 1960s. Other potential source of radioactive materials that need further investigation included discharges from nuclear-powered vessels in port, and the storage and maintenance of nuclear weapons.
2.2 SITE CHARACTERIZATION
Reclaimed Areas were not sampled.
Contaminated fill may have been used in reclamation projects throughout the Freeport Zone. The EQS indicates that contaminated dredged material has been and continues to be used for fill in low lying areas. Dredged material contaminated by US Navy operations may also have been used as fill in reclaimed areas outside the Freeport Zone.
The EQS does not evaluate contaminant migration in groundwater.
It is a standard practice in evaluating environmental conditions to consider the potential that contaminants in groundwater may migrate from one property to another. Despite the installation of 44 monitoring wells no determination of groundwater flow directions were made during the EQS.
Parcel to parcel migration was identified as the probable reason contamination was detected on Site 34. The source of the contamination was noted as the nearby Boton Tank Farm Annex.
An evaluation of the potential for migration from the parcels identified as contaminated during the EQS should be performed.
Relationship to drinking water supply not established.
The EQS does not provide an evaluation on the potential impacts of hazardous materials on groundwater aquifers used for drinking water in the vicinity of the Freeport Zone. The EQS however has recommended that restrictions be placed on the use of groundwater in the upper 30 meters. The EQS only investigated groundwater to a depth of 5 meters.
Groundwater impact on surface water.
Similarly, the EQS does not evaluate the potential migration of contaminated groundwater to Subic Bay through shoreline seepage and infiltration into storm drains and sewers. Groundwater levels measured in monitoring wells throughout the Freeport Zone are reported to be tidally influence. The human health and environmental impacts of contaminated groundwater entering Subic Bay waters was not evaluated during the EQS.
2.3 SITE HISTORY
Key Sources of Information.
"Some useful information was obtained but the data is difficult to access, because they are uncatalogued, hence, important detail was often unavailable, and the history of waste management practices, spills, and cleanup is incomplete." The historical information while incomplete in content was also incomplete over the entire period of US Navy operations. The documents referenced as key sources of information were produced in 1977 and later.
The site history makes no attempt to determine the potential for contamination in areas where ship repair was performed prior to World War II.
Interviews with individuals knowledgeable with the site.
The results of interviews with former base employees is not provided in the EQS. There is no information on who the interviewed employees are, the years they worked at the navy base, the area of the navy base they worked at and their job responsibilities related to hazardous material management. It is evident that the individuals interviewed during the EQS were not able to provide key details on locations of storage areas, hazardous material types and volumes.
Hazardous Waste Management Program.
Prior to 1981 hazardous waste was disposed of in a landfill or in Subic Bay waters. It is postulated that the fate of contaminants discharged to Subic Bay was "picked up during routine harbor dredging" and "disposed of either in ... the South China Sea, or in land reclamation projects." (EQS p. 4-6). The EQS failed to identify or sample land reclamation project areas which may be impacted by disposal of hazardous wastes in dredged material. The EQS did not recommend further evaluation of potential impacts from ocean disposal of hazardous wastes by the US Navy. The EQS does not recommend controls for dredge spoils from harbor areas which based on EQS sampling have been impacted by US Navy hazardous waste disposal practices.
Underground Storage Tanks.
The EQS stated there are approximately 83 underground storage tank, with details noted in Table 4.2. Table 4.2 only identifies 49 tank locations. "There are more than 100 underground tanks" according to the Executive Summary. Whether the number is 49 or 83 or over 100, many of the listed tank locations were not sampled during the EQS. No information on inventory reconciliation or tank leak testing is provided to support the need to forgo testing near each and every underground tank.
Fuel Distribution System.
No attempt was made to sample fuel distribution line areas despite the fact that these fuel lines were the source of many of the recorded spills. The EQS did sample five existing monitoring wells all located in areas where fuel distribution occurs. These areas included the high-speed refueling area, Coastal Refueling Tank Farm, Boton Valley Fuel Farm, Subic Clark Pump House and the POL Pier Compound. Without exception each monitoring well reported high levels of petroleum in groundwater. The groundwater contamination is indicative of widespread petroleum contamination throughout fuel storage and distribution facilities.
Hazardous Waste Inventory.
Table 4.1, Subic Bay Annual Hazardous Waste Generation, 1980, is the only list of chemicals used at different areas of the Freeport Zone by the US Navy. A comparison of this list, together with the laboratory program (Section 6.5) indicates a number of these chemicals were not sampled for during the EQS.
Many of the hazardous wastes listed in Table 4.1 are described generally instead of by their toxic components. The EQS makes assumption about the toxic components in these wastes and in at least one example these assumptions do not appear to be correct. The text of Section 5.5.2 describes the aircraft maintenance, hangars and fueling activities, stating that some 10,000 gallons of methylene chloride (paint remover and degreasing agent) were generated in 1980. This statement is contradicted by Table 4.1. This table lists 26,629 gallons of methylene chloride being generated at the Cubi Point NAS. In addition to the 26,629 gallons of methylene chloride waste, Table 4.1 indicates that 9,616 gallons of paint remover wastes were also generated.
2.4 POTENTIAL FOR CONTAMINATION
Contrary to statements made in the EQS many areas where hazardous industries and activities were conducted were not paved.
The presence of pavement throughout the Freeport Zone is stated as one reason that significant contamination did not results from US Navy operations. Table 8.10 lists 20 sites of concern together with a statement on whether the site was "paved or unpaved". Only six of the 20 sites were fully paved and at one of these six sites the pavement was not installed until the 1980s (i.e. Deltic Yard). Seven sites had no pavement at all. The remaining 7 sites ranged from 40 to 70 percent paved.
Pavement does not limit the impact of releases.
Many of the sources of contamination are underground tanks, and buried piping, which are present below the ground surfaces. It would be absurd to suggest that paving at these sites reduced the potential for contamination of underlying soils and groundwater.
Contaminants likely accumulate in sewer systems.
Hazardous waste was reportedly discharged via the sewer system to Subic Bay. Hazardous material spills were also reportedly rinsed into storm drains. As a result of these contaminant discharges, toxic material likely accumulated at low points throughout the Freeport Zone's sewer system. These contaminants include heavier than water chemicals such as chlorinated solvents, PCBs, and metallic mercury, as well as solids consisting of metal precipitates from electroplating solutions, and contaminated solids. The sewer system needs to be more fully investigated.
Off-specification fuels, waste oil, and solvents were recycled at the power stations.
According to the EQS, the burning of hazardous wastes helped reduce overall contamination in the Freeport Zone. The disposal of hazardous wastes through incineration have environmental consequences however that were not investigated during the EQS. Likewise the reprocessing of off-specification fuel produces environmental concerns including the generation of liquid and solid hazardous wastes that require management.
Burning of contaminated fuel, solvents and PCBs produces air emissions that may deposit toxic substances in areas downwind from the incinerator source. Metals, polynuclear aromatic hydrocarbons (soot), and dioxin are all bioaccumulative toxic substances that were likely produced and deposited in the surrounding environment by the fuel blending program. No effort has been made during the EQS to sample areas of the Freeport Zone or areas outside the Freeport Zone for these toxic chemicals.
2.5 SAMPLING AND ANALYSIS PROGRAM
Selection of Soil and Groundwater Sampling Sites.
Table 6.1 lists specific sites within five planning areas that were selected for sampling as part of the EQS sampling program. The rationale for not selecting other areas of the Freeport Zone is not explained. The review of the site history, past land use, and historical Navy practices was too vague to rule out contamination in any area of the Freeport Zone. Among the items identified during the site history but not selected as sampling sites are the underground storage tanks, fuel distribution system, sewer system, spill locations, South China Sea disposal area, and reclaimed areas.
Volatile Organic analysis results for soils should be viewed as inconclusive.
A total of 378 surface soil samples (88 percent of all EQS soil samples) were collected from 5 to 18 inches in depth and 51 subsurface samples were collected from depths of 1.5 to 3.0 feet bgs. With few exceptions each of these samples was analyzed for volatile organic compounds and reported to contain non-detectable concentrations.
At shallow depths evaporation of volatile contaminants to the atmosphere is expected to occur, thereby yielding analytical results that are not indicative of the actual contamination that may be present. Samples collected from less than three feet below ground surface are therefore not expected to yield reliable results for volatile organic analysis.
The sample collection method and the sample containers that were used also reduced the likelihood of detecting volatile organic contaminants in soil samples. The samples were collected by a hand trowel which disturbed the soil. The sample was then placed in a glass jar that contained head space and would allow contaminants to evaporate.
Current US EPA methods for collection of soil samples for VOC analysis call for field preservation and sample collection in intact cores (SW-846 method 5035). These practices were not followed during the EQS. VOC losses, which are often orders of magnitude, have been observed in improperly collected and preserved samples. Decisions on the magnitude or absence of contamination can therefore not be made using the soil VOC data collected. Similarly the results of water VOC data may also have been biased by the lack of sample preservation.
Furthermore the laboratory procedure that was used for analysis differed from EPA approved procedures by performing soil sample extraction in methanol. The EPA reference procedure stipulates that only samples containing high levels (greater than 1 mg/kg) of a contaminant should be extracted by methanol.
Volatile organic results are diluted by shallow sample depths, poor sample method, poor sample containers, and poor choice of analytical procedures. All volatile organic sample data should be viewed as inconclusive.
Depth of Soil Samples targeting underground contamination sources.
In general, underground piping is buried at a minimum depth of two feet. In general the depth to the bottom of an underground storage tank is ten to 12 feet below ground surface. Soil samples collected at less than 18 inches in depth would not detect a leak from a pipeline. No soil samples were collected during the EQS at a sufficient depth to detect a leak from an underground storage tank.
Scope of Metals Analysis.
Metals analysis was generally limited to twelve metals: arsenic, barium, cadmium, chromium, copper, lead, manganese, mercury, nickel, selenium, silver, and zinc. A limited number of samples were also analyzed for lithium and tri-butyl tin. The US EPA lists 13 metals as priority pollutant, including the ten metals commonly sampled, and antimony, beryllium, and thallium. These three additional metals have a high likelihood to be presents as contaminants in the Freeport Zone.
For the risk screening criteria used in the EQS (US EPA Region IX Preliminary Remediation Goals) antimony, beryllium and thallium have lower risk threshold concentrations than the ten metals that were commonly sampled.
Aquifer Permeability Tests.
Three variables are needed to solve Darcy's groundwater flow model and estimate potential contaminant migration rates. These variables are the groundwater gradient, the groundwater flow direction, and the aquifer permeability.
The EQS performed slug tests to determine aquifer permeability values for each well. Measurements made by slug tests have limited reliability and are considered accurate within one-to-two orders of magnitude. Aquifer permeability can be estimated with equal reliability from soil types and drilling observations.
Potentiometric gradient and flow direction, on the other hand are difficult to estimate. Values for these parameters are best determined using a precise survey of well locations and groundwater elevation measurements from at least three wells located in close proximity. No estimates of groundwater flow direction or gradient were made during the EQS.
Though the EQS states that slug tests were performed to determine potential for migration no actual potential migration evaluation was performed.
Chlordane analysis was not performed on samples.
Table 6.4.3 lists chlordane as a target chemical, along with other organochlorine pesticides. The results of chlordane analysis are not reported in the EQS with two exceptions, Sites 22 and 23.
For these two sites Chlordane was not reported in the initial analysis, but the results of organochlorine pesticide analysis on the initial soil samples were rejected during validation. The confirmation samples were analyzed for Chlordane. In each case chlordane was detected above the screening level and the two sites were recommended for further evaluation.
Total Petroleum Hydrocarbons.
c The total petroleum analysis reported results in terms of carbon fraction that were then related to the common petroleum product in which the carbon fraction was found.
Gasoline for instance was indicated as consisting of carbons in the C6 to C9 fraction. Gasoline by composition ranges from C4 to C12. Similarly the Kerosene and Jet Field reported as C10 to C14 is composed of hydrocarbons in the C9 to C16 range. Diesel reported as C15 to C28 is composed of C10 to C22. Fuel oils are reported as C29 to C36 and composed of C18 to C36. These results may not be comparable to the screening limits developed by the North Wales Gasoline Station cleanup program that were used during the EQS.
2.6 ANALYSIS RESULTS
Background Metals Concentration.
The EQS reasons that using results of the 430 soil samples to determine background metal concentrations likely "corresponds closely with the range of natural background concentrations" (VOL. I, p 7-2). The stated purpose of the EQS sampling was to target the areas most likely to be contaminated by hazardous materials. Hazardous materials often contained metals. To state that these samples also represent background conditions for metals is contradictory.
The reported metals background ranges are considered to be exaggerated because the data set contains values that are influenced by anthropogenic sources.
Treatment of Manganese as Background metal.
The most common industrial use of manganese is in the manufacturing of steel. The presence of high levels could be associated with the military history of the Freeport Zone. The EQS, however, concludes that manganese is present at naturally high concentrations in both soils and groundwater.
Manganese, like iron, is not soluble in well oxygenated waters. The presence of manganese in groundwater at concentrations in excess of 50 µg/L is an indication of anaerobic conditions. These anaerobic groundwater conditions maybe a result of decaying vegetation is present beneath fill at the site, or be due to degradation of petroleum products or other organic wastes. The manganese levels in groundwater are a symptom of an unhealthy groundwater system.
2.7 DISCUSSION OF RESULTS
Detection limits versus screening limits.
The EQS notes that of the detection limits of PCBs, benzo(a)pyrene, dibenz(a,h)anthracene, dieldrin, vinyl chloride, arsenic, and selenium exceed screening limits. In addition, 1,2-dichloroethane, 1,1-dichloroethylene, heptachlor, heptachlor epoxide, lindane, and 1,2,3-trichloropropane also have screening limits below the detection limits.
Adjustment of screening level for Arsenic. .
Arsenic is reported to be found in soil at relatively high background concentrations ranging from 0 to 18 mg/kg in soils. The 95 percent upper confidence limit concentration for arsenic in all soil samples collected during the EQS was 9.11 mg/kg. These concentrations exceeded arsenic's Region IX PRG for cancer risk of 0.32 mg/kg. The EQS noted, that consistent with EPA guidance the Region IX PRG for non-cancer risk would be used instead. The non-cancer PRG for arsenic is 22 mg/kg.
Despite this arsenic is identified in Table 8.10 as a chemical of concern in soil 17 of the 20 sites, and as a chemical of concern in groundwater at 8 of the 20 sites.
Exposure Pathways not considered during EQS.
Multimedia exposure pathways are not considered in the development of PRGs. The leaching of soil contamination to groundwater, the run-off of contaminated soil to surface waters, the discharge of contaminated groundwater to surface water through shoreline seeps and sewer leaks, and the evaporation of contaminants from soils and groundwater into enclosed spaces all represent significant exposure pathways that have not been evaluated during the EQS. No samples were collected from beneath the foot-prints of buildings despite the presence of vinyl chloride at high concentrations in groundwater in close proximity to buildings (Other 40 - Base Dry Cleaners).
Qualifications of PRG Screening Results.
The use of Region IX screening results are qualified to state that most property uses are commercial or industrial and that the PRG screening values are generally 50 times higher than the residential PRG. The PRGs for lead however, only differ by a factor of 2.5 times. Lead was identified as a chemical of concern in soil at 18 of the 20 sites listed in Table 8.10.
An important qualification of the screening results was overlooked. The Region IX screening values were developed for a 0.5 acre site. They are being used on a site that totals 70,000 acres in area. What is the potential to underestimate the risk?
Presentation of total estimated risk.
The text indicates that "sites with chemical concentration above the PRG were considered as needing further evaluation." (EQS p 8-17). The PRG screening results for screening individual compounds and additive affects were not presented in the EQS. The EQS only lists 22 sites with chemicals of concern above the screening level.
