3.33 SRF33 Sand Blasting Facility Causeway
Scope of analysis was too limited.
Metals were the primary analysis performed on soil samples from Site 33. The limited samples analyzed for TPH and PAHs showed that these chemicals are also a concern at the site. The observation of petroleum oil floating on water in the Inner Basin indicates that hydrocarbon contamination at Site 33 may be impacting Subic Bay.
Cost of remediation may be underestimated.
High levels of metals were found throughout Site 33. The recommended removal and stabilization of soils from Site 33 is estimated to cost $180,000 to 270,000 US dollars based on removal of one meter of soil. Actual costs could be much higher because the EQS has not fully defined the extent of contamination at the site.
3.34 SRF34 - Deltic Yard
Only fresh topsoil was sampled.
"It is reported that the area was bulldozed and replenished with fresh topsoil."37 This action reportedly occurred in 1984 before the facility was paved. The samples collected during the EQS at depths of 0.20 to may 0.38 meters below ground surface may have sampled the "fresh topsoil" and may not represent conditions present in deeper soils.
Gridded soil sample pattern is too large.
Using the 30 to 40 meter distances between soil samples introduces a ten percent probability that a toxic "hot spot" of 1/3 of an acre in size may be overlooked. Given the limited details on site history a larger number of samples would be appropriate.
Migration from the adjacent Boton Tank Farm Annex.
The contamination at Site 34 has been largely attributed to spill of fuels at the Boton Tank Farm Annex. Migration from adjacent parcels needs to be evaluated during the EQS in order to determine whether a facility is potentially impacted. The Tank Annex was not included in the scope of the EQS but has been previously investigated. Site 34 is also located adjacent to Site 25, DRMO yard, and Site 15 NEX taxi facility. Site 15, Site 25, Site 34 and the Boton Tank Farm Annex all have wide-spread petroleum contamination in soils and groundwater.
Severe and widespread contamination is present at the site.
Surface samples identified high levels of petroleum hydrocarbons over the eastern two-thirds of the site. PCBs are also present above screening levels in soils. BTEX, and PAHs were detected in groundwater.
Scope of remediation requirements may be underestimated.
Based on the presence of petroleum contamination this site was recommended for remediation. An estimated 50,000 to 100,000 cubic meters of soil would be removed from the site (and Site 17, Lower MAU) and tested to determine of the waste required stabilization prior to land disposal. Based on the dimensions shown on Figure 34.1, it appears that 4 to 8 meters of soil is being proposed for removal from Site 34. The deepest soil sample collected from the site was at a depth of 1.15 meters. The three groundwater monitoring well borings extended to 3 meters in depth. The basis for the 4 to 8 meter depth of contamination is purely speculative and indicates the need for further detailed investigation of Site 34.
3.35 SRF35 - Building 24 - Sheet Metal and Battery Shop
No rationale for sample locations provided.
The site history provided no information on the locations of hazardous material handling facilities at Site 35. Surface soil samples were collected from six locations around the perimeter of building during the EQS. It may have been more appropriate to collect soil samples from within the foot-print of the building.
Results of volatile organic analysis is inconclusive.
Volatile organics not generally found in surface soil samples.
Potential for contaminant migration to nearby sites.
The potential for contaminant migration to Site 35 was not considered. Site 35 is located in the SRF in close proximity to Site 36, Site 37, Site 38, and Site 39. Similar groundwater contaminants are found on each of these sites.
Metals present in soils well above background levels.
Metal analyses was performed on five of the six surface soil samples collected from the site. Three of the five samples show the presence of lead (121 to 345 mg/kg) and zinc (365 to 1,048 mg/kg) at concentrations well above the background ranges determined for the Freeport Zone. Though these high levels of metals are below human risk screening levels, they represent a potential threat to the marine environment. Site 35 should therefore be investigated in more detail.
3.36 SRF36 - Building 612 - Battery Shop
No information is provided on hazardous materials use, storage and disposal.
The EQS provides no information on the handling and disposal of hazardous materials at Site 36 that could not be reasoned from the site name. Despite conducting interviews with former employees during the EQS, no specific information on hazardous material use and storage areas was determined.
Investigation of indoor building areas was not performed.
The interior of the building may have also housed hazardous materials and contain unsafe levels of lead and potential skin contact hazards. These potential human health hazards were not investigated.
Potential for contaminant migration to nearby sites.
The potential for contaminant migration to Site 36 was not considered. Site 36 is located in the SRF in close proximity to Site 35, Site 37, Site 38, and Site 39. Similar groundwater contaminants are found on each of these sites.
Two of four soil samples taken outside of fenced boundary of site.
Samples were collected from two locations on the South side of Building 612 outside a fence that marked the boundaries of the site operations. No information on possible drainage patterns from the site were provided to indicate that sample locations SS01 and SS02 were located along the run-off path of a potential spill.
Metals exceeded background concentrations.
Samples SS02 contained nickel, copper and zinc, concentrations in excess of estimated background concentrations. These metals have not been related to site operations.
Skin contact hazard not considered during the sampling and risk screening.
No testing of soil pH was performed during the investigation to determine if potential risks of exposure to acid residues in soils existed.
3.37 SRF37 - Building 671 - Plating Shop
No information on site use prior to 1969 is provided.
Building 671 was reportedly constructed in 1969. No information on previous US Navy activities at Site 37 was provided in the EQS. The location of the plating facility that may have existed prior to Building 671 was not provided in the EQS.
No rationale is provided for soil sampling locations.
The soil sample locations do not appear to target the "most likely" areas were contamination might be found. Surface soil samples should have been collected from within the footprint of the plating shop.
Potential for contaminant migration to nearby sites.
The potential for contaminant migration to Site 37 was not considered. Site 37 is located in the SRF in close proximity to Site 35, Site 36, Site 38, and Site 39. Similar groundwater contaminants are found on each of these sites.
Results of volatile organic analysis is inconclusive.
Volatile organics not generally found in surface soil samples.
Chlorinated solvent use.
The soil sample locations were located along three sides of the plating shop which is occupies a portion of the Building 671 Electronic Shop. Chlorinated solvents were identified as a chemical of concern for Building 671, not the plating shop. Sewer lines are a common source of chlorinated solvent contamination in groundwater. It is unclear if MW-1 is located near the sewer line serving Building 671. The potential presence of chlorinated solvents has not been adequately investigated.
Waste accumulation in drain lines.
Liquid hazardous wastes produced by plating operations were disposed of in drains that led to Subic Bay. The environmental problems were apparently severe enough the Navy installed (though it did not operate) a hazardous waste treatment system in 1979. Drain lines from this facility however were not investigated during the EQS to determine if they may still contain waste material resulting from plating operations.
Statement about metal concentrations in groundwater is misleading.
The statement "All of the metals detected had low concentrations..."38 is contradicted by the statement "lead in sample SRF37-MW1-GW1 at 324 µg/L is very high."39 Both manganese (844 µg/L) and lead (324 µg/L) exceeded the Philippine Drinking Water Standards of 500 µg/L and 10 µg/L, respectively.
Source of lead in groundwater warrants further investigation.
The high levels of lead found in groundwater samples from MW1 were not adequate to rule out severe and widespread contamination at this site. Despite these values exceeding the groundwater screening levels, Site 37 was not recommended for remediation or further investigation.
3.38 SRF38 - Building 30 - Foundry
Undocumented site history.
The site history with respect to hazardous materials use and hazardous waste disposal practices is extremely vague. In the absence of historical documentation a higher level of environmental sampling is necessary to properly characterize potential human health and environmental risks posed by Site 38.
Potential for contaminant migration to nearby sites.
The potential for contaminant migration to Site 38 was not considered. Site 38 is located in the SRF in close proximity to Site 35, Site 36, Site 37, and Site 39. Similar groundwater contaminants are found on each of these sites.
No analysis for petroleum hydrocarbons.
No TPH analysis was performed on samples from Site 38. It is reasonable to expect that this foundry stored fuel oil in an underground tank.
High levels of PCBs warrant further investigation.
PCB concentrations of 6.73 ppm were detected in a soil sample from SS01. The source and extent of this soil contamination needs to be further investigated.
Sample locations did not target areas potentially impacted from foundry air emissions.
It is likely that the foundry was a source of air pollution during operation. It is likely that these air emissions contained metals, polynuclear aromatic hydrocarbons and other suspended particulates that were eventually deposited on areas surrounding the operation. The impacts of previous air emissions were not evaluated during the EQS.
Groundwater monitoring well located away from any operations.
The location of the groundwater monitoring well places it at distance from any potential source of groundwater contamination. The monitoring well was located the greatest distance from soil sample SS01 were the highest levels of PCBs were found.
¥ Groundwater sample indicates serious metal contamination.
Five metals were detected in groundwater above Philippine drinking water standards including arsenic, lead, manganese, chromium, and nickel. The site has been recommended for a more detailed evaluation only if the use of the site is changed.
3.39 SRF39 - Building 47 - Hazardous Material Storage Area
Undocumented site history.
The potential for contamination is based on speculation about what may have been stored in the facility instead of interviews with knowledgeable individuals.
Potential for contaminant migration to nearby sites.
The potential for contaminant migration to Site 39 was not considered. Site 39 is located in the SRF in close proximity to Site 35, Site 36, Site 37, and Site 38. Similar groundwater contaminants are found on each of these sites.
Most likely areas of contamination not sampled.
The four soil samples were collected surrounding the storage area rather than beneath it. The depth of soil samples indicates that the detection of volatile organics is very unlikely. The monitoring well appears to be installed to the east of the storage area in the opposite direction of the inferred groundwater flow.
A strong odor and high levels of organics were found in soils in this area.
Three of the five soil samples contained petroleum hydrocarbons at concentrations in excess of 1,000 ppm. The soils were noted to have a "strong hydrocarbon odor and is pitch black in color."40 Further action is needed to address this potential contamination. PAHs were also detected above screening levels in one the soil samples.
High levels of metals in groundwater warrant further investigation.
Arsenic, lead and zinc all exceeded groundwater screening limits. The EQS recommends this site for further investigation only when a change in use occurs. The metals concentrations in groundwater represent a potential threat to the marine environment.
