Technical Assistance Consultant’s Report

This consultant’s report does not necessarily reflect the views of ADB or the Government concerned, and ADB and the Government cannot be held liable for its contents. (For project preparatory technical assistance: All the views expressed herein may not be incorporated into the proposed project’s design.

Project Number: 47144-001 August 2016

REGIONAL: Mitigation of Hazardous Waste Contamination in Urban Areas: Supporting Inclusive Growth (Financed by the Japan Fund for Poverty Reduction)

(Appendix G [1 of 2])

Prepared by Pure Earth Blacksmith Institute New York, USA

For Urban Development and Water Division, SERD, ADB Ministry of Environment and Forestry, Indonesia Department of Environment and Natural Resources, Philippines

Pure Earth

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APPENDIX G

STRATEGIC URBAN REDEVELOPMENT

PLAN, PHILIPPINES

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TABLE OF CONTENTS LIST OF ABBREVIATIONS ...................................................................................................................... 2

LIST OF TABLES ........................................................................................................................................ 4

LIST OF FIGURES ...................................................................................................................................... 5

PURPOSE AND SCOPE OF THIS GUIDEBOOK .................................................................................. 7

I. Introduction ........................................................................................................................................ 8

II. The Urban Redevelopment Concept ............................................................................................... 9

III. Operational Framework .............................................................................................................. 10

IV. Setting-up the Stage for Site-Specific Remediation and Redevelopment ............................ 11

Stakeholder Identification and Analysis ........................................................................................... 11

Capacity Building Workshops, IEC Campaigns, and Alternative Livelihoods Program ......... 13

Policy Review and Agenda Setting ................................................................................................... 17

V. The Ramcar Remediation Plan ....................................................................................................... 20

General Steps ........................................................................................................................................ 20

Step 1: Preliminary Site Assessment .................................................................................................. 21

Site Description ................................................................................................................................. 21

Surrounding land use of the site .................................................................................................... 26

History of operation ......................................................................................................................... 30

Prior assessments and remediation ............................................................................................... 32

Potential Pathways ........................................................................................................................... 37

Step 2: Primary Site Investigation ...................................................................................................... 38

Sources of Contamination: legacy contamination due to ULAB recycling operations .......... 40

Pathways and Routes of Contamination ...................................................................................... 42

Receptors & Health Effects ............................................................................................................. 43

Step 3: Expanded Site Investigation for Potential Remediation .................................................... 46

Step 4: Remedial Design ...................................................................................................................... 47

Remedial Alternatives ..................................................................................................................... 47

General Evaluation and Analysis of Remediation Alternatives ................................................ 52

Key Considerations in Pursuing Remediation of the Pilot Site ................................................. 54

VI. The Ramcar Redevelopment Plan .............................................................................................. 57

The Planning Process ........................................................................................................................... 57

Redevelopment Design Options ........................................................................................................ 58

Community Consultations and the Preferred Redevelopment Option ....................................... 60

Specific Redevelopment Objectives ................................................................................................... 64

Planning Considerations ..................................................................................................................... 65

Location of Contaminated Areas and Level of Contamination ................................................. 65

Linkages and Accessibility .............................................................................................................. 67

Land Use Development ................................................................................................................... 67

Market Requirement ........................................................................................................................ 71

Feasibility of the Redevelopment Plan .............................................................................................. 78

Implementation Strategies, ................................................................................................................. 80

VII. Financing Options ........................................................................................................................ 84

Synthesis: Urban Redevelopment Towards Inclusive Growth ......................................................... 88

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LIST OF ABBREVIATIONS

AFI ABS-CBN Foundation Inc

ADB Asian Development Bank

AAS

BLGF

BLL

BOA

BOD

BPO

CDC

Atomic Adsorption Spectroscopy

Bureau of Local Government Finance

Blood Lead Level

Brownfield Opportunity Area

Biological Oxygen Demand

Business Process Outsourcing

Center for Disease Control

CLUP Comprehensive Land Use Plan

CSR Corporate Social Responsibility

DAO

DBP

DENR Administrative Order

Development Bank of the Philippines

DENR Department of Environment and Natural Resources

DENR-EMB R3

DOF

DOH

DPWH

EIA

EIS

EMB

ENRO

EPA

GEF

FASPO

DENR Environmental Management Bureau Region 3

Department of Finance

Department of Health

Department of Public Works and Highways

Environmental Impact Assessment

Environmental Impact Statement

Environmental Management Bureau

Environment and Natural Resources Office

Environmental Practitioners Association

Global Environment Facility

Foreign Assisted and Special Projects Office

FMSI

HDPE

IEC

IT

LGU

First Metal Specialists Inc.

High Density Polyethylene

Information, Education and Communication

Information Technology

Local Government Unit

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LSI

MDF

MDFO

MMORS

MOA

NGA

NGO

Lead Smelter Inc.

Municipal Development Fund

Municipal Development Fund Office

Marilao-Meycauayan-Obando River System

Memorandum of Agreement

National Government Agency

Non-government Organization

NLRC North Luzon Railway Corporation

OMC Oriental and Motolite Corp.

PBSP

PD

PEZA

Philippines Business for Social Progress

Presidential Decree

Philippine Economic Zone Authority

PNR Philippine National Railroad

PPM

PRI

RA

SMP

SWOT

Parts Per Million

Philippine Recyclers Inc.

Republic Act

Soil Management Plan

Strengths Weaknesses Opportunity Threats

TA

TCLP

Technical Assistance

Toxicity Characteristic Leaching Procedure

THW

TRI

TSD

Toxic and Hazardous Wastes

Toxic Release Inventory

Treater, Storage and Disposal

ULAB

UNDP

USEPA

VAT

NPMCC

WQMA

Used Lead Acid Battery

United Nations Development Program

United States Environmental Protection Agency

Value Added Tax

National Poison Management and Control Center

Water Quality Management Area

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LIST OF TABLES

Table 1. The process in formulating the strategic urban redevelopment plan ................................ 10

Table 2. Top 3 ranked potential alternative livelihood options in Barangays Caingin, Lingunan,

Bancal, and Tugatog ................................................................................................................................. 16

Table 3. Registered Tanneries and Gold Smelting Business Establishments, 2015. ....................... 29

Table 4. RAMCAR Recycling Plants Lead Production per annum (ILMC, 2005) ........................... 31

Table 5. Blood lead levels and median IQ scores of children in Barangay Bancal, 2010 ............... 44

Table 6. Relationship of current socio-economic and health status of households in Barangays

Bancal and Tugatog in relation to THW contamination ..................................................................... 45

Table 7. Estimated Volume of Soil to be Excavated from the Pilot Site

Table 8. Summarized Remediation Alternatives Review ................................................................... 53

Table 9. Summarized Remediation Alternatives Evaluation ............................................................. 54

Table 10. Area of land for each redevelopment option ...................................................................... 59

Table 11. Summary of highlights of the consultation meetings ........................................................ 61

Table 12. Excavation work for the Ramcar redevelopment ............................................................... 66

Table 13. Land use distribution for the planned Ramcar redevelopment ....................................... 69

Table 14. Existing residential projects in Meycauayan City ............................................................... 72

Table 15. Residential development product offering for the Ramcar Site ....................................... 73

Table 16. Commercial establishments near the Ramcar Site .............................................................. 74

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Table 17. Volume of Soil to be Excavated based on the Proposed Ramcar Site Redevelopment

Table 18. A survey of IT and BPO companies in Bulacan province .................................................. 76

Table 19. Commercial development product offering for the Ramcar Site ..................................... 77

Table 20. Particulars of the lifestyle mall and the BPO, IT, government offices ............................. 77

Table 21. Profit and loss for the proposed residential development ................................................ 78

Table 22. Profit and loss of the proposed commercial and institutional development ................. 79

Table 23. Types of Incentives throughout the Remediation-Redevelopment Process……………80 Table 24. Existing Philippine Laws with Provisions for Incentives………………………………...81 Table 25. Financing Wndows under the Muncipal Development Fund…………………………...85

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LIST OF FIGURES

Figure 1. Strategic Urban Redevelopment Framework ........................................................................ 9

Figure 2. Stakeholder matrix for the Ramcar Strategic Urban Redevelopment Plan ..................... 13

Figure 3. Outcomes of the Capacity Building Workshops and IEC Campaign .............................. 14

Figure 4. Consolidated policy development agenda for THW mitigation ...................................... 18

Figure 5. The step-by-step process in remediating THW contaminated sites (Adopted from

Asante-Duah, 1996) .................................................................................................................................. 20

Figure 6. MMORS Water Quality Management Area ......................................................................... 22

Figure 7. Regional location of RAMCAR showing the major tributaries of MMORS ................... 24

Figure 8. Land ownership profile of the site. ....................................................................................... 25

Figure 9. Location of the former ULAB site. ......................................................................................... 26

Figure 10. Frontage along MacArthur Highway (left) and establishments across the road of the

Ramcar Site (right) .................................................................................................................................... 27

Figure 11. Properties to the left side of the Ramcar Site ..................................................................... 27

Figure 12. Figure 9. The Hollywood Suites is 3 lots away from the Ramcar Site (left) where

lightweight and micro establishments can be found next to it (right) ............................................. 28

Figure 13. Establishments across the road of the Ramcar Site ........................................................... 28

Figure 14. Property to the right of Ramcar (right) and the view to the north of commercial

development that is mostly lowrise ....................................................................................................... 28

Figure 15. Land use of surrounding environment of RAMCAR ....................................................... 29

Figure 16. Tanneries and gold smelting establishments near the Meycauayan River ................... 30

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Figure 17. Historical site information .................................................................................................... 32

Figure 18. Scoping work including soil sampling ............................................................................... 32

Figure 19. Lead levels on surface soil surrounding the former ULAB in Meycauayan City ........ 33

Figure 20. Lead levels of soil taken at 0.25 m ....................................................................................... 34

Figure 21. Lead levels of soil taken at 0.50 m ....................................................................................... 34

Figure 22. Removal of battery casing used in the informal settlers’ housing (top) and the IEC

workshop (bottom) .................................................................................................................................. 35

Figure 23. TCLP results of lead in soil collected inside the facility ................................................... 36

Figure 24. Baseline Lead levels on surface soil at the PNR property adjacent to the former ULAB

..................................................................................................................................................................... 37

Figure 25. Decision process used to screen for the chemicals of potential concern in the impacted

environmental matrices ........................................................................................................................... 39

Figure 26. Lead levels on surface soil at PNR property after remediation ...................................... 41

Figure 27. Lead levels on surface soil at the PNR Property in November 2014 .............................. 42

Figure 28. Conceptual diagram of lead contamination in children .................................................. 43

Figure 29. The Ramcar redevelopment planning process .................................................................. 58

Figure 30. Redevelopment options for the Ramcar Site ..................................................................... 59

Figure 31. Total land area of the preferred redevelopment option, the north and south

expansion ................................................................................................................................................... 62

Figure 32. SWOT Analysis of the planned redevelopment concept ................................................. 63

Figure 33. Ramcar redevelopment planning objectives ...................................................................... 64

Figure 34. Activities during the operation of the ULAB facility ....................................................... 65

Figure 35. Areas to be excavated and depth of excavation ................................................................ 66

Figure 36. The planned redevelopment showing the four access points ......................................... 67

Figure 37. Land use development in the site and access points ........................................................ 68

Figure 38. Massing diagram of the planned Ramcar redevelopment (top view) ........................... 70

Figure 39. Massing diagram of the planned Ramcar redevelopment (aerial view from the east) 70

Figure 40. Massing diagram of the planned Ramcar redevelopment (view from MacArthur

Highway) ................................................................................................................................................... 71

Figure 41. Massing diagram of the planned Ramcar redevelopment (south side view) ............... 71

Figure 42. Existing commercial areas near the Ramcar Site ............................................................... 75

Figure 43. Location of IT parks, BPOs, and PEZAs in the region ..................................................... 76

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PURPOSE AND SCOPE OF THIS GUIDEBOOK

Urban land use planning is an important policy and development agenda in urban areas.

Within the framework of a comprehensive and inclusive urban land use plan is environmental

management that needs to take into account the different environmental issues in urban areas,

especially toxic and hazardous waste contamination, as influenced by the wide range of drivers

and pressures of urbanization. Toxic and hazardous waste contamination in urban areas in the

Philippines is especially difficult to control and, throughout history, has inevitably led to

contaminated lands after industries ceased to operate. This guidebook focuses on the

management of contaminated lands in urban areas in the Philippines through remediation and

redevelopment of a selected pilot site in Meycauayan City in Bulacan Province.

Strategic urban redevelopment is the planning for the revitalization of contaminated lands in

urban areas with the aim to deliver social, economic, and environmental benefits from an

otherwise idle and unutilized land. This is coupled with site remediation or the clean-up of

toxic and hazardous waste contaminants from the soil as informed by the potential

redevelopment options. This guidebook details the step-by-step process of the strategic urban

redevelopment plan of a contaminated site in the Philippines, including conceptual and

practical experiences and considerations in designing the redevelopment plan of a former lead

acid battery recycling site in Meycauayan City, Bulacan. This is intended to be a reference

handbook for local government policy makers, different levels of government agencies,

industries, and consultants working on contaminated sites.

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I. Introduction

Urbanization in many municipalities and cities in the Philippines is driven by economic-

oriented development and policy agenda. The phenomenon is interlinked with changes in

market and population dynamics. Urban growth, in particular, is characterized by the

conversion and expansion of land to commercial and industrial uses. Urbanization is primarily

an environmental discourse because of issues in resource extraction and waste volume

discharge resulting to, for instance, toxic and hazardous waste (THW) contamination.

Industrial sources of THW pollution include the untreated discharge of heavy metals from

manufacturing operations, which may pose serious health and environmental impacts. The

Philippines has enacted Republic Act No. 6969 or the ‘Toxic Substances and Hazardous and

Nuclear Wastes Control Act of 1990’. The implementing rules and regulations of this law (DAO

92-29) detail the different involved actors and groups, including their duties and roles, in the

stages of the use of toxic and hazardous substances in industries. It is a good law about the

proper handling and documentation of toxic and hazardous substances during industry

operations, but fails to give strategies on how these regulations could effectively prevent THW

pollution, that is, through enforcement and compliance.

In many cases for industries located in urban areas, there is very low motivation to invest in

proper THW treatment and disposal as evident in the nation-wide identification and

preliminary assessment of contaminated sites done by Blacksmith Institute/ Pure Earth in 2011.

Pure Earth, formerly Blacksmith Institute, has been tasked by the Asian Development Bank

(ADB) and the Department of Environment and Natural Resources (DENR) to undertake the

technical assistance (TA) “Mitigation of Hazardous Wastes Contamination in Urban Areas:

Supporting Inclusive Growth”. The TA generally aims to improve environmental management

of industrial activities in urban areas of the Philippines through urban redevelopment.

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A pilot site was selected to fully implement the strategic urban redevelopment plan and

comprehensively document the institutional, capacity building, and policy dimensions of the

plan. The site identified, known as the Ramcar Site, is located in Meycauayan City in the

province of Bulacan. It is a former lead acid battery recycling facility that operated in the area

for more than 20 years. Soil analyses by various organizations including Pure Earth and the

Environmental Management Bureau (EMB) show levels of lead (Pb) contaminants within the

vicinity of the site. Soil contamination is further confirmed by interviews of former employees

and nearby residents about the industry’s operation from the 1970s to 1990s. While it is

currently a fenced private property divided into parcels with different owners, the fact remains

that when it was closed down, no remediation and clean-up was conducted due to the absence,

during that time, of a policy or regulation to guide the proper closure of facilities that deal with

regulated hazardous materials such as lead.

II. The Urban Redevelopment Concept

Urban redevelopment is a long-term planning process coupled with a scientifically sound and

cost-efficient remediation plan. The strategic urban redevelopment framework follows a

benefit-based concept grounded on the holistic understanding of the dynamics between the

environmental, social, and economic conditions of the idle and contaminated site (Figure 1).

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The framework illustrates how contaminated lands could negatively impact economic

competitiveness, human health, and environmental services. Contaminated lands pose health

risks to the population, disrupting the delivery of better ecosystem services and limiting

economic competitiveness. On the other hand, redeveloping offers improvement towards

favorable environmental, social, and economic conditions emphasizing that investment can be

motivated by targeting a set of desirable benefits. Clean up and redevelopment of contaminated

sites in urban areas help improve the well-being of the people, provide opportunities to

enhance economic growth, and revitalize environmental health. The redevelopment of the site

into dynamic uses can improve public safety, leverage private investment, offer jobs, and

increase local tax base.

Sound assessment of remedial and redevelopment options are informed by inclusive and

participatory consultations with the local government, the community, government agencies,

and private developers. During which consultations, institutional and organizational capacities

are strengthened, policies were formulated to mainstream THW management in urban areas,

and interventions would fit to better serve both the communities’ and the private’s interests.

This guidebook is primarily divided into three main sections: the preliminary remediation plan,

the redevelopment plan, and the financial challenges and financing options. These are the

fundamental components necessary to formulate and implement the strategic urban

redevelopment of the Ramcar Site in Meycauayan City, Bulacan Province. Assessments,

workshops, and campaigns conducted for the remediation, redevelopment, and financing

options were inextricably interrelated and were done simultaneously.

III. Operational Framework

This strategic urban redevelopment plan emphasizes the benefit-based approach to

identifying contaminated sites for remediation and redevelopment. This means that the type of

remediation and redevelopment to be implemented in the site should fit the social, economic,

and governance contexts to ensure cost-effectiveness and sustainability. The framework of this

guidebook details that remediating and redeveloping idle, contaminated lands would enhance

the municipality’s economic growth and enrich the current well-being of the people through a

range of benefits to be derived from a combination of planned improvements in land use. In the

long-term, this range of benefits would significantly contribute in the achievement of the TA’s

target policy and development outcomes: 1) capacity assessment and awareness creation; 2)

strategy and action plan implementation; and 3) community development and institutional

strengthening. These target outcomes can be realized and eventually be implemented by the

relevant stakeholders that should be involved in the strategic urban redevelopment by

conducting a set of carefully selected series of stakeholder engagement activities (Table 7).

Table 1. The process in formulating the strategic urban redevelopment plan

TARGET ACTIVITIES OUTPUT

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OUTCOMES

Capacity

Assessment & Awareness

Creation

Baseline Assessment

Capacity Building

Workshops

Urban Redevelopment

Plan

IEC Campaigns

Strategy & Action Plan

Assessment of Remedial Options Remediation Plan

Policy Review & Agenda Setting Policy Brief Formulation

Community Development

& Institutional

Strengthening

Alternative Livelihoods

Community Meetings

Market and Feasibility

Study

Designing & Redesigning Redevelopment Options

PHASE 1 PHASE 2 PHASE 3

Table 6 shows that the conceptualization process for the strategic urban redevelopment of idle,

contaminated sites, the Ramcar Site in particular, demands a multi-faceted strategy that

synergizes science-based baseline assessment primarily for remediation, political motivations in

implementing redevelopment, and the public and private’s knowledge, attitude, and

perceptions about the impacts of the planned redevelopment. This comprehensive process is

composed of a series of simultaneous activities that were implemented in a two-year time

duration. The process was objective to ensure the quality of the outputs as well as dynamic to

better understand the appropriateness of the redevelopment concepts to the site.

IV. Setting-up the Stage for Site-Specific Remediation and

Redevelopment

Stakeholder Identification and Analysis

Stakeholder identification is important in the beginning of the strategic urban redevelopment

plan. The assessment of baseline information for the formulation of appropriate management

alternatives are essentially determined by the scope of the project’s impacts and the influence of

the key stakeholders. Stakeholder identification for the strategic urban redevelopment of the

Ramcar Site was done, first, by enumerating all the potential key stakeholders across the

different scales of management, namely, in the Ramcar Site, the community, as well as in the

entire Marilao-Meycauayan-Obando River System (MMORS).

In the case of the Ramcar Site, land owners were identified based on the tax declaration

documents provided by the Meycauayan City Assessor’s Office. It was found out that there are

at least seven different private individuals/ families/ companies owning properties within the

delineated Ramcar Site. However, only two of the land owners have responded to the

communications by Pure Earth, while the rest have not showed any interest.

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Community profiling, on the other hand, was done in two barangays in Meycauayan City that

were identified as primary impact zones. These are Barangay Bancal and Barangay Tugatog. A

household survey on the socio-economic and health characteristics was conducted in

coordination with the barangay local governments. It was implemented with the assistance of

volunteer barangay health workers and college students of the Mariano Quinto Alarilla

Polytechnic College as survey enumerators. The analysis of primary data from the household

survey was complemented with secondary information available from the local government

units and related literature. Detailed information about the socio-economic and health profile of

residents in Barangays Bancal and Tugatog are discussed in the chapter on remediation above.

For the purpose of redevelopment, key stakeholders at the community level that were identified

are the informal settlers in Daang Bakal, the small-scale tanneries in Barangay Tugatog, and

property owners near the vicinity of the contaminated land. The informal settlement is located

just outside of the fenced area of the Ramcar Site near the former PNR railroad.

Moreover, to effectively raise awareness and enhance institutional capacities about THW

mitigation, relevant literature on the existing institutional arrangements on THW mitigation in

the Philippines were reviewed. The urban redevelopment strategy determined specific offices

and agencies in the different scales of the government, business organizations, private

treatment, storage, and disposal (TSD) facilities, and others concerned in water quality

management in the MMORS including the members of the Water Quality Management Area

(WQMA) Board.

The complete list of identified stakeholders are illustrated in the stakeholder matrix below.

Stakeholder analysis was guided by the influence-importance matrix in which “influence”

refers to the legitimate power of the stakeholder to affect the outcomes of the proposed strategic

urban redevelopment plan, while “importance”, signifies which interests are important to be

satisfied. Combinations of low and high importance and influence have classified the

stakeholders into four types, namely, context setters, regulators and implementers, receivers,

and the audience. All of these stakeholders were engaged by Pure Earth throughout the

conceptualization and formulation process of the strategic urban redevelopment plan.

INFLUENCE

(context setter)

MMORS WQMA Board

High (regulators and implementers)

Ramcar land owners Developers

Meycauayan City LGU

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IMPORTANCE

EMB Region 3 FASPO

Low

Private TSDs (including the EPA) Bulacan Province LGUs

HLURB DILG

Philippine National Police Bureau of Fire Protection Philippine Coast Guard

High

Informal settlers Property owners surrounding the Ramcar Site

Schools, hospitals, and clinics in Meycauayan City Jewelry Association of the Philippines

Medium and small-scale tanneries

(audience) Low (receivers)

Figure 2. Stakeholder matrix for the Ramcar Strategic Urban Redevelopment Plan

Context setters have high influence but low importance regarding the project, for instance the

MMORS WQMA Board. In this case, it is important to consult the WQMA board for advice and

regularly update its members of the project activities to keep them satisfied. Stakeholders with

high influence and high importance were labeled as regulators and implementers. It is

necessary for the project team to closely collaborate with this type of stakeholders as they would

play a major role in the realization of the strategic urban redevelopment plan. The receivers,

like the WQMA Board, are important to be informed of the project activities. These stakeholders

would likely to receive the primary negative and positive impacts of the proposed

redevelopment in the Ramcar Site. A series of consultation workshops were conducted to

gather information about their opinion and attitude towards the proposed redevelopment.

Lastly, the audience were primarily involved in the project to participate and exchange their

points of view in the series of capacity building workshops and IEC campaign on THW

mitigation.

Capacity Building Workshops, IEC Campaigns, and Alternative Livelihoods

Program

The overall objective of the capacity building workshop was to increase awareness and skills of

environmental regulators, industrial stakeholders and artisanal operators on Toxic and

Hazardous Waste issues in municipalities covered by the MMORS-WQMA for improved

decision-making and better management of THW. Outputs of the workshops were geared

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towards developing plans and policies that integrate sound environmental management with

urban redevelopment and mitigation of hazardous waste exposures in urban environments.

Topics of the training-workshop revolved around 4 thematic areas: 1) policy and project

proposal development; 2) importance of public health and law enforcement on THW

management; 3) use of environmental management tools and land use on THW mitigation; and

4) the role of the private sector in the management of THW. The trainings were held from

September to November 2015 in Clark, Pampanga and Subic, Zambales.

Figure 3. Outcomes of the Capacity Building Workshops and IEC Campaign

Getting the support of DENR-FASPO, EMB region 3 as well as the endorsement from LGU

Meycauayan, the support of Valenzuela City as a member of the technical working group, the

support of the president of the league of the Environment and Natural Resource Officers

(ENROs) and the support of the barangay LGUs was a very crucial step in the conduct of the

project. Partnerships between LGUs, NGAs and Pure Earth that deviate from the funder-

beneficiary mentality common to international NGOs were forged during the training-

workshops. LGUs and NGAs are now more open to transactions such as sharing of data,

Capacity(

Building(and(IEC(

Campaign(on(

THW(Mi7ga7on(

Clarity$of$Pure$Earth's$

role$ Review$of$mandates$of$

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and$scope$of$

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Sense$of$ownership$of$

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Dra\$policies$on$Inter]LGU$

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Consulta^ve$dialogue$with$

Local$Chief$

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conduct of research on the barangay level and conduct of training to key stakeholders (i.e.

informal sector, tanneries, LGUs etc.) with Pure Earth.

Although the pilot site of the ADB project is in Meycauayan, the training involved all the

ENROs of the province of Bulacan, through the league of ENROs. Representatives from San

Jose, Nueva Ecija also attended the workshop. The topic on Emergency Response on THW

proved to be one of the topics that benefitted all of the LGUs. Promising MENROs from San

Jose Del Monte, Obando and Sta Maria were noteworthy for their insights and depth of

commitment in addressing THW contamination in their respective municipalities. San Jose Del

Monte has already included THW in the drafting of their e-code. The training-workshop also

provided an ideal venue to identify promising participants that could champion the advocacy

of mainstreaming THW in local plans.

Aside from the policy makers, the capacity building workshops covered key stakeholders such

as the academe, hospitals, law enforcers and even the private sector. Universities, such as the

Mariano Quinto Alarilla Polytechnic College, have been conducting THW seminars in their

school since the Pure Earth workshop. MQAPC has also been a partner of Pure Earth in

conducting the public health survey in barangay Bancal, Meycauayan. Students of MQAPC

were also taught of the basics of conducting research in the context of the ADB TA project.

The partnership with the Environmental Practitioners Association (EPA), a group of

environmentally compliant TSD facilities in Region 3, proved to be effective in inviting the

private sector to attend the capacity building workshops— taking into consideration that it has

always been a challenge to invite the private sector since their schedules are always full. But

through EPA president Leslie Baun, Pure Earth was able to get the cooperation of these

industries. During the training-workshop, industries were able to share their experiences in

proper disposal and treatment of e-wastes, technical solutions, and technologies. It was also

ideal that the LGUs were also present. LGUs and industries were able to share their experiences

in mitigation and management techniques for THW.

The 4 workshops increased the awareness of LGUs and other stakeholders in mainstreaming

mitigation of THW contamination as well as created a sense of stewardship on the training

outputs such as the draft policies. The knowledge of LGUs on the science (river quality

monitoring and respective field visits to Clark Metro Waste) and actual governance and

institutional context of THW from health, politics and the technical side of THW was improved.

Some LGUs also manifested that they would be reproducing the IEC materials given during the

training for distribution in their respective areas.

The alternative livelihoods program intended to reduce the contribution and exposure to toxic

and hazardous wastes of waste collectors/pickers, informal tanners and other members of the

informal sector by identifying alternative livelihood options. The target beneficiaries were

located in barangays adjacent to the Ramcar Site in Barangays Caingin, Tugatog, and Bancal in

Meycauayan City and Barangay Veinte Reales in Valenzuela City. Training needs assessment

and focus group discussions were conducted with the said target sector groups.

Waste collection/picking is the main source of livelihood of majority of the participants. Other

sources of income include service jobs such as manicure-pedicure, fixing of electronics, laundry

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and house cleaning services and construction jobs. Others are employed in small scale

businesses such as sari-sari stores and leather tanneries. Participants from Caingin collect and

segregate their wastes in the Caingin dumpsite, majority of them are also residing in that area.

There is an estimated number of 20 households living in the Caingin dumpsite and they have

been collecting wastes for 8-11 years now. Wastes are collected twice a week, depending on the

schedule of the dump truck and the participants spend at least 8 hours a day collecting wastes.

The weekly income ranges from Php 300-2,300. Majority of the participants from barangay

Lingunan collect their wastes from the previous Lingunan dumpsite, now a waste transfer

station. They are residing in barangay Veinte Reales, adjacent to the dumpsite. There is an

estimate of 300 families living near the dumpsite. These families rely mostly on waste picking as

their primary source of livelihood. They have been collecting wastes for 11 years already, every

day from 8AM-4PM (dayshift). Their average income in a day is Php 100-1,200.

Role playing games were used to comprehensively demonstrate the basics of operating a

business including the budgeting of finances, procurement of materials needed, and production

of outputs. Potential alternative livelihoods were enumerated then ranked according to a set of

requirements and preference by the participants. The following criteria were considered in

identifying the potential alternative livelihood options: gender appropriateness, capital, labor,

land, available market in the area, and whether trainings or seminars are needed.

The top three identified alternative livelihoods for barangay Caingin are pillow making from

foam, rug making and dishwashing liquid making. Establishing of a junkshop ranked number 1

for barangay Lingunan, followed by small eatery/karinderya and selling of fish balls, barbeque

and other food. Other alternative livelihoods identified were bigasang may ulam, papaya soap

making, recycling of PE bottles, selling of sampaguita/roses, establishing a junkshop, flower

vase making from old newspapers. Junkshop also ranked number 1 for barangays Bancal-

Tugatog as well as the selling of balut and fish, followed by the selling of fish balls, barbeque

and other street snacks and DVD and other accessories business.

Table 2. Top 3 ranked potential alternative livelihood options in Barangays Caingin, Lingunan, Bancal, and Tugatog

Barangay Alternative

Livelihood

Gender Requirements

(L=Low; M=Moderate; H=High) Rank

F M Both Capital Labor Land Market Training/ seminar

Caingin

Pillow making from foam

X H H L H No 1

Rug making X H H L H Yes 2

Dishwashing liquid making

X H H L H Yes 3

Veinte Junkshop X H H H H Yes 1

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Reales Small eatery X H H L H Yes 2

Selling of fishballs, barbeque

X H M L H Yes 3

Bancal and Tugatog

Junkshop X H H H H No 1

Selling of Balut X H L L L No 1

Selling of fish X H L L M Yes 1

Selling of fishballs, barbeque

X H L L L No 2

Selling of DVD and other accessories

X H L L L No 3

The scope of the TA does not include the actual alternative livelihoods, however, the TA looks

for possible networks/organizations that can provide additional technical trainings and

assistance to the said participants for them to be able to start better livelihood options. An

organization was formed among the participants present in the training. The organization

name, and the members of the executive committee consisting of the president, vice-president,

secretary and treasurer were identified. Organizing the informal sector around the proposed

redevelopment site is important for future project communications, information dissemination,

and policy consultations.

Policy Review and Agenda Setting

Consistent policy dialogues were held throughout the planning process to strengthen

regulations and local partnerships needed to implement the plans. Government agencies were

key participants in policy reviews to ensure that the policy framework is reasonable given local

government priorities and resources. The baseline report highlighted several laws being

implemented at the national level on hazardous wastes management. Standards were set to

mitigate potential impacts of anthropogenic activities. It should be noted, however, that the

current THW management procedures do not still include incidents about legacy pollution

(before the EIS was established in the Philippines) or if the company has also closed down.

DENR EMB shared that they are planning to develop protocols and procedures to address

legacy pollution and also the institutionalization of e-permitting procedure or system of THW

generators, transporters and TSDs.

The capacity building workshops and technical working group served as venues for policy dialogues between communities and industries in the pilot locations to validate policy analysis, identify gaps, and formulate policy recommendations and enhancement strategies considering inter-agency policy harmonization. Based on the case study of Blacksmith Institute Philippines (for its technical assistance in the assessment and clean-up of a TSD in Bulacan, Philippines), the following are the identified gaps based on the current policy on toxic and hazard waste management (Blacksmith Institute, 2012):

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• Calculation of the polluter’s fee are only based on BOD and should include hazardous substances being processed and handled by the TSD or transporter or generator;

• Review the permitting system since a company could both be a transporter and treater which could lead to connivance and shortcuts;

• No comprehensive database system for the manifest forms and THW reports at the regional level and rely only on hard copies submitted by industry alone;

• Lack of incentives or pressure for hazardous generators to also comply with the policy and ensure that their hazardous wastes are being treated correctly by their service providers; there should be an extended producer’s responsibility;

• Strict implementation of penalties and follow-through of agreements after post-monitoring of MMTs;

• Lack of appreciation from local officials of the impact of HWM to sustainable urban development as manifested in priority projects and programs including investments. An IEC campaign up to the community level regarding THW impacts can raise awareness and more active participation in its management; and

• The local academe and research institutions are not fully engaged in site assessments and analysis of samples.

Figure 4. Consolidated policy development agenda for THW mitigation

Local$EIA$System$and$Monitoring$

Toxic$Release$Inventory$

Emergency$Response$

Mechanisms$

Taxes,$insurance,$and$fees$

LGU$coopera^on$ Public$behavior$

POLICY(DEVELOPMENT(AGENDA(

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Local EIA system and monitoring: EMB should look at the submitted applications against the CLUP. A Full local EIA for projects and critical areas not covered by the national and regional systems (e.g. some areas are not covered like cemeteries below 5 has). There should be local inventories to serve as baselines in making locators liable. There should be a clear authority of the Mayor to suspend operations or close for violations – this depends on gravity and public clamor. Toxic Release Inventory (TRI): a public database of all commercial establishments should be registered and chemicals used should be listed. LGUs can also have toxic chemicals inventory (any amount you buy should be registered; e.g. dental office buying cyanide should be registered). TRI tracks the management of certain toxic chemicals that may pose a threat to human health and the environment. You can anticipate what types of wastes will be released by company.

Emergency Response Mechanisms: people need to know the dangers, how to deal with it, make resources available, and improve response time. For example, there are smaller types of spills that need to be documented. There should be regular drills in areas with industrial areas for worst case scenarios. Taxes, insurance, fees: Real estate valuation based on risks posed by the zone. There should be higher cost for discharge of effluents; higher fees for disposal of hazardous HH waste. Incentives and insurance - LGU can require insurance for companies that use high amounts of TH chemicals. Rehabilitation and clean-up funds – Pass ordinances that set aside funds for clean-up (disaster fund, for example; DENR does not do clean-up even if it is in the Clean Water Act; LGU can do the clean-up and ask DENR to charge perpetrators to reimburse the fund); charge levies for every plastic bag discharged by stores. LGU cooperation: cooperation among WQMA and non-WQMA areas, watershed management, integrated basin ordinances or management bodies, joint collection and handling mechanisms. Develop sets of presumptions – e.g. if there are industries upstream, there should be presumption that if there is poisoning downstream, industries should be able to prove that they are not the source by showing evidence of discharge, etc. Public behavior-modifying mechanisms: ordinances and programs, public monitoring and reporting (can have incentives for reports from public), clear liabilities. LGUs can look at finding liabilities so they can get back their funds for doing clean-ups. LGUs can sue, including Writ of Kalikasan which includes massive emergencies or spills (encompasses several areas); this is really designed for toxic wastes. You can also get environmental protection order.

Two policy briefs were already drafted to initiate the necessary legislative steps in materializing

these policy recommendations, particularly the inter-LGU cooperation and the mainstreaming

of THW mitigation in local development plans. Local policies in land use and zoning in

Bulacan, particularly in Meycauayan City, were also reviewed to assess the potential

redevelopment concepts applicable to the Ramcar Site.

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V. The Ramcar Remediation Plan

General Steps

Figure 5. The step-by-step process in remediating THW contaminated sites1

$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$1

Asante-Duah, D. (1996). Managing contaminated sites: Problem Diagnosis. New York: John Wiley & Sons, Inc.

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Step 1: Preliminary Site Assessment

The preliminary site assessment documents known and potential presence of contamination in

areas of concern, the characteristics of the contaminants, their potential migration pathways,

and qualitative assessment of the extent of contamination. This consists of understanding the

site’s history through the review of historical records, readily available databases and reports,

and published literature. Data needs include records from the private company, regulatory

agency, local government, and other concerned organizations on site profile, detailed project

design and process, hydrogeology and topography of the site, monitoring reports, preliminary

soil and water contamination analysis, socio-economic and physical characteristics of the

surrounding area, and known environmental hazards such as flooding. Information can also

come from anecdotal reports of practices from former employees, local residents, and key

informants.

It is important during the preliminary site assessment that the scope of the problem be defined

according to the context of the industry’s previous operations to determine the types of

contaminants, exposure pathways, and the contamination levels. Assessment of the socio-

economic profile and land use of the communities surrounding the contaminated land would

provide a better understanding of the risks and the appropriate ways on how to manage it.

This is done together with physical site inspection and basic sampling and analysis such as in

situ tests using a portable equipment to assess the existing contamination levels in surface

water, groundwater from deep wells, and soil within the site’s vicinity. Site inspection includes

field surveys that are necessary before any intrusive exploratory methods in assessing

contaminated sites are to be conducted. Geophysical surveys, for instance, can characterize the

site’s lateral and vertical extent for both lithologic and hydrologic information such as soil

stratification, disturbance in soil formation, buried toxic and hazardous wastes, and

groundwater characteristics. Visual evidence of contamination as well as odors can be done by

trial pitting that guides the selection of sampling sites for laboratory analyses. Auger and

borehole drill are used to collect soil samples for testing to determine the types of contaminants

to be considered for further investigation.

Site Description

The Ramcar Site is located in Meycauayan City in the province of Bulacan, approximately 19

kilometers north of Manila and 22 kilometers south of the provincial capital, Malolos. The city is

situated near the center of the Marilao-Meycauayan-Obando River System (MMORS) Water

Quality Management Area (WQMA) (Figure 6). Meycauayan City is bounded on the east by

Caloocan City, on the west by Obando, on the north by Marilao, and on the south by Valenzuela

City. The landlocked city of Meycauayan comprised 26 barangays with a total land area of 3,210

hectares.

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in MMORS and its relative position in the region’s notable commercial areas. Based on the map,

the Ramcar Site is strategically located near Metro Manila just south of the Subic Bay Freeport

Zone.

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The lead recycling facility operated from 1978 to 2000. It was the site for one of the longest

industrial operations in Meycauayan City. The building that housed the recycling operation has

been demolished, but no remediation and clean- up was conducted since policy or regulation

pertaining to such was inexistent during that time. Although closed, the facility is still being

guarded and is privately owned. The Ramcar Site is composed of 11 different land parcels

forming a contiguous irregularly shaped area of almost 4.0 hectares (Figure 8).

All throughout the project implementation, Pure Earth has consistently attempted to

communicate with all land owners of the site. However, invitations for consultations and

meetings were all denied from all but one property owner. Land owners, particularly the

Leelin/ Ramcar Corporation has not been cooperative in this project’s endeavors making it

more difficult for the project team to do a full-blown site investigation of the scope of THW

contamination. Issues of the other land parcels in the site concern the transfer of land titles to

living relatives who are similarly disinterested to communicate with Pure Earth regarding the

project’s objectives. On the other hand, Pure Earth has been in touched with one owner, the

Philippine Investments, Inc. and with property owners adjacent to the Ramcar Site. They have

been invited in the series of consultation meetings regarding the remediation and

redevelopment of the site and the proposal has been received positively by them.

Figure 8. Land ownership profile of the site.

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Surrounding land use of the site

Within the fenced area of the Ramcar Site, the project site is occupying approximately 34,800

sqm (Figure 9). It only has about 56 meters of road frontage, and at least 200 meters in depth.

The southeastern boundary of the site has a length of 254 meters. It is mostly vacant with

concrete fence defining the boundaries of the entire project site. The only structure remaining is

a shell of a 3-storey building that is visible from the road.

It is situated beside the Philippine National Railways (PNR) former railroad and where a number of informal settlers resided due to the available open space and its proximity to sources of urban employment and services. The site is also prone to flooding where wetlands are located at the back of the property.

Figure 9. Location of the former ULAB site.

On the south of the project site is a warehouse and a 4-storey building. Right beside this

building is the Hollywood Suites and Resort. To the north, there is a dilapidated warehouse.

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The eastern part is bounded by open space. There is a plan to have railroad line near the rear

boundary. Across the street from the property are various establishments such as auto supply

store, tire store, clinic, and a hardware. These are mostly low rise, 2-storey concrete structures.

The other establishments near the site are gas stations, bus terminal, and Puregold which is

national chain of supermarkets. Although the land development along MacArthur Highway is

mostly commercial in nature, the City Assessor’s Office in 2013 has still classified the land

parcels near the road as industrial with a market value of about PhP 1,200 per square meter.

Figure 10. Frontage along MacArthur Highway (left) and establishments across the road of the Ramcar Site (right)

Figure 11. Properties to the left side of the Ramcar Site

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Figure 12. Figure 9. The Hollywood Suites is 3 lots away from the Ramcar Site (left) where lightweight and micro establishments can be found next to it (right)

Figure 13. Establishments across the road of the Ramcar Site

Figure 14. Property to the right of Ramcar (right) and the view to the north of commercial development that is mostly lowrise

Located within the 500-m radius of the Ramcar Site are parts of Barangay Bancal, Tugatog, and

Banga of Meycauayan City and Veinte Reales in Valenzuela City. This area is allocated for

residential and industrial uses based from the Meycauayan City CLUP 1999-2004. However,

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based from field visits, the surrounding environment of RAMCAR is dominated by a mixture of

residential and commercial infrastructures (Figure 15).

Figure 15. Land use of surrounding environment of RAMCAR

In particular interest of this study is the locations of tanneries and gold smelting business

establishments around the Ramcar Site located in Barangay Bancal and Tugatog. Table 3 shows

that there are 12 registered tanneries and gold smelting establishments in the area; 2 are in

Bancal while 10 are in Tugatog. However, the satellite image of the Ramcar Site shows that

there are at least 28 tanneries and gold smelting facilities in the study site (Figure 16). These are

situated on the north and northeast of the Ramcar Site. Many of these facilities are concentrated

within 500 meters of the tributaries of the mainstream Meycauayan River.

Table 3. Registered Tanneries and Gold Smelting Business Establishments, 2015

Barangay Nature of business Classification Category Number of employees

Bancal Buy & sell (leather ) Single Dealer 2

Leather material Single Retailer 5

Tugatog

Manufacturing (leather) Corporation manufacturing 20

Manufacturing (safety footwear & leather processing)

No data Manufacturing No data

Buy & Sell (Trading of Finished Leather)

Single Dealer 1

Leather services Corporation Contractor 16

Manufacturing / trading Single Contractor 2

Leather services Single Retailer 1

Leather services Single Contractor 10

Leather products Single Manufacturer 2

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Leather service Single Contractor 1

Leather services Single Contractor 2 Source: Business Permits and Licensing Office of the City Government of Meycauayan, 2015

Figure 16. Tanneries and gold smelting establishments near the Meycauayan River

History of operation

The Ramcar facility in Meycauayan City operated as a battery and used lead acid battery

recycling for 25 years. In 1997, two of the biggest motor battery manufacturers in the

Philippines - C.C. Unson Company that manufactures Motolite battery, and RAMCAR Inc. that

produces Oriental battery, merged to become Oriental and Motolite Corporation (OMC). OMC

is the industry pioneer and leader in “productivity, capacity and the utilization of modern

battery technology”$(ILMC,$2005). C.C. Unson started as an importer of motor batteries importer

with its main source mainly from States Battery Parts of Seattle, Washington. RAMCAR was

founded in 1919 as an automotive electrical shop in Manila.

In$1991,$Ramcar$through$the$Lead$Smelters$Inc$(LSI),$renamed$Philippine$Recyclers,$Inc.$and$later$

transformed$into$Green$Planet,$bought$out$First$Metal$Specialists,$Inc.$(FMSI)$and$managed$the$battery$

recycling$operations.$$This$ended$the$dependence$of$the$company$to$imported$primary$lead.$$In$

addition,$local$and$international$pressures$for$stricter$transboundary$movement$of$hazardous$wastes$

and$materials$was$put$into$policy,$adopted$in$1989$and$enforced$in$1992$through$the$Basel$Convention$

on$the$Control$of$Transboundary$Movements$of$Hazardous$Wastes$and$Their$Disposal.$Ramcar$

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partnered$with$GNB$Corporation$of$the$United$States$of$America$to$improve$its$production$efficiency$

and$as$a$product$was$able$to$refine$secondary$lead$to$a$purity$of$99.97%$(ILMC,$2005).$

The original used lead acid battery recycling plant was in Gen Luis St. Novaliches, Quezon City

and later moved to Bancal, the Meycauayan site in the 1980s. In 1989, the Meycauayan plant

reached its maximum capacity rate of 12,000 tonnes of lead recovered per annum. The recycling

facility was later transferred to Marilao to cover the increasing demand for soft lead bullion and

hard lead alloys (Table 4).

Table 4. RAMCAR Recycling Plants Lead Production per annum (ILMC, 2005)

Year Lead Production (tonnes/annual) Plant

1981 7,200 Meycauayan Plant

1989 12,000 (maximum capacity) Meycauayan Plant

1990 36,000 Marilao Plant

The Philippine Recyclers, Inc (PRI) became the largest secondary lead smelter in the Philippines.

The company also implemented several Corporate Social Responsibility (CSR) projects such as

Balik Baterya in partnership with Philippine Business for Social Progress (PBSP) and Bantay

Baterya with Bantay Kalikasan of the ABS-CBN Foundation, Inc (AFI). Both programs center on

requesting private companies to donate their ULABs for proper handling and recycling, the

equivalent amount or proceeds of which go to PBSP’s and AFI’s development projects (i.e.

electrification of classrooms, rehabilitation of watersheds). Historical information about the site

operation was identified based on the interview of a former employee (Figure 17).

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Figure 19. Lead levels on surface soil surrounding the former ULAB in Meycauayan City

Lead levels outside the facility decreases as sampling depth increases. This indicates that

contamination outside the wall and near the former railroad is mainly concentrated on the

surface. However, samples collected in front of the facility showed increasing levels of lead with

deeper increments from surface to 0.50 meters (Figures 19, 20, and 21). This is attributed to a

number of highway renovations since 2000 where clean soil has been dumped to elevate the

area due to flooding.

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Figure 20. Lead levels of soil taken at 0.25 m

Figure 21. Lead levels of soil taken at 0.50 m

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A parallel assessment was conducted inside the RAMCAR facility which was facilitated by the

company. Assessment results showed that lead levels after the Toxicity Characteristic Leaching

Procedure (TCLP) range from 254 to 1677 ppm (Figure 23).

Figure 23. TCLP results of lead in soil collected inside the facility

In 2014, within the context of the planned North Luzon Railway Project, Ramcar, in coordination with EMB Region III and based on reconfirmed findings of the 2010 project, implemented remediation just outside of the walled property and only for identified contaminated areas which fall within the North Luzon Railway Corporation (NLRC) property. Figure 24 shows the lead levels on soil surface at the PNR property adjacent to the ULAB that underwent remediation last July 2014. The total area excavated covered 3,800 sq. m. at 0.6 m with an estimated volume of 2,280 m3. The contaminated soil was dumped, secured and covered inside the walled facility of RAMCAR. Clean soil from Newtown, Dulong Bayan, San Jose Del Monte City in Bulacan was used to backfill the site.

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Figure 24. Baseline Lead levels on surface soil at the PNR property adjacent to the former ULAB

Potential Pathways

Based on interviews with local officials and community members, informal settlers in Daang

Bakal (site of a former railroad owned by PNR) who are residing outside the wall retrieved lead

slags and battery materials inside the former facility. These materials were processed informally

and sold to junkshops within the cities of Meycauayan and Valenzuela. Battery casings were

also retrieved inside the former facility and were used for flooring. These activities spread the

lead contaminants and exposed the community members of Daang Bakal through dermal

contact with contaminated soil and water.

Exposure of the community members in Daang Bakal was established in 2010 when the

Department of Health (DOH) and the University of the Philippines – National Poison and

Management Control Center (UP-NPMCC) in partnership with Blacksmith conducted a health

assessment study. Blood Lead Levels (BLL) of children living near the former ULAB site were

collected and analyzed in April – May 2010. Results showed that out of the 76 children ages 6-7

years old, 12 had BBL of more than 10 µg/dL some as high as 65 µg/dL. The Center for Disease

Control (CDC) uses 5µg/dL as the level of concern for a child’s BLL. At 45µg/dL, the CDC

recommends chelation therapy.

Another toxicant, chromium (III and VI), which can be found in tanneries can affect a person

through inhalation, dermal absorption or ingestion of contaminated soil, food and water.

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The adverse effects of lead include developmental delays in children, neurobehavioral damage,

and decrease in perceptual reasoning, working memory indices and processing speed indices.

On the other hand, the effects of hexavalent chromium include chrome ulcers among workers,

asthma, chronic bronchitis, chronic rhinitis and chronic pharyngitis. It also produces allergic

contact dermatitis and kidney/ liver diseases among exposed workers.

Step 2: Primary Site Investigation

The purpose of the primary site investigation is to verify the presence or absence of

contamination. It includes investigation of specific contaminants to determine their

concentration levels and the extent of contamination. Once contamination is verified,

investigation focuses on the contaminant characteristics and their transport properties as well as

the possibility of the spread of contamination from the contaminated site. Site sampling and

analysis were conducted in impacted media to give a more comprehensive understanding of the

nature of contaminant release, cross-media transport, and probable health, economic, and

environmental effects. Primary site investigation also includes the assessment of risks and the

identification of the feasible solutions for potential remediation and redevelopment. Figure 25

shows the decision process to screen chemicals of potential concern in the impacted area.