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Based from the literature and reports provided, it is indeed a dangerous combination to
have two possible sources of highly toxic water pollutants in the area. What puzzles me is that all the
concerns rose on the report by Doc Gab, is most probably not raised during the Environmental
Assessment of the project. All relevant projects prior to implementation should have either Initial
Environmental Examination (Checklist) or an Environmental Impact Statement depending on the
magnitude of the project. Since the copy of their submitted EIA is not available we have yet to know
what they included in the scope. Part of the EIA is to include the assessment of the impact on sites
near the proposed facility.

I am also wondering if it is safe to assume that everything was assessed prior to the
implementation of this project, including the possibility of groundwater contamination, possibility of
mixing of the wastes. Alongside the said impacts should also include the mitigation measures
proposed such as a wastewater system, fencing or a form of barricade to contain waste from the
landfill site. Although based from the recent report of Doc Gab, leachate treatment plant is not
operational and the materials from the previous mine site were even used as soil cover. The risks
involved were also noted on his report such as those rocks may contain mercury in different forms.
Mercury from those rocks could potentially end up in the leachate as well, this will not only entail
greater hazard but will also mean that treatment of the leachate will become more costly due to the
additional pollutants.

Another concern would be is that with its proximity to the former mine site, it will be very
easy to use it as a scapegoat, during instances where hazardous wastes are found to contaminate
the water bodies around the area.

From the report of Gray in 2003, the surroundings of the pit lake are obviously
contaminated with mercury in different forms. The area should have been isolated or fenced to
reduce the risks of the locals and even tourists near the lake.

In the end, the sentiments written here are solely based on the reports provided to us and
are available online. Probably another major reference would be their impact assessment study
which will give us an idea on what they considered prior to approval of DENR. IF they have assessed
concerns raised on the reports and if those risks were mitigated and what mitigation measures were
done. Since they still ended up with the same location (no other location available or the best site
with the least possible impact was chosen all those should be available in their impact assessment),
perhaps the reason why will be available on the EIA.

The letter includes the major concern coming from the Environmental lawyer Atty. Robert Chan.
Based from his claims that Malampaya has been illegaly dumping its wastes in the sea. Two (2)
water analysis samples were referenced, each coming
from different locations. One of them is the sea water
outfall, from experience it seems that this comes from
their wastewater treatment facility, also based from
the results which are complying with the standards as
their discharge. Another location is in the open drain
caisson, I have to start by saying that I’m not very
familiar with petroleum engineering. Although what I
have searched online, a Caisson looks like the image
on the left. It looks like a vortex chamber, usually used
as a separator in the air pollution and wastewater
treatment industry. This equipment is perhaps used
as part of the process to capture the oil in the
industry. With regard to the water analysis of the
Open drain caisson, it is vague where the sample was
located. This equipment however is designed to
contain the wastewater from oil and gas industry, and
is designed to separate the contaminants from the
water. If the water quality is taken from the caisson,
then it is not a discharge. Based from the image it
seems that one cannot really measure from the
discharge of the caisson since it pumps the “Clean
water” directly under the sea where the pollutants
will eventually be diluted. Although it also seems, that
this equipment is not designed to meet the phenol standards, since it is merely a physical separation
process, which is not enough to meet the effluent standards. It is however unclear if the water
coming out of the caisson is part of the scope of the new DENR standards.

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