Department of Environment and Natural Resources

Environmental Management Bureau

MIMAROPA Region

MEMORANDUM

FOR : THE REGIONAL DIRECTOR

EMB MIMAROPA Region

FROM : KARL ALEXANDER R. DAMMAY

Environmental Management Specialist I
Chief EMS – Coron, Palawan

SUBJECT : REPORT ON THE CONDUCT OF AMBIENT WATER AND

EFFLUENT SAMPLING ACTIVITIES, AND LATEST
INSPECTION/VALIDATION AT SUNLIGHT RESORT
LOCATED AT NAGLAYAN ISLAND, BRGY. BALDAT, CULION,
PALAWAN

DATE : 19 OCTOBER 2022

In compliance to the memorandum dated 07 September to conduct latest inspection/validation

and to conduct ambient water and effluent sampling activities at Sunlight Resort located at
Naglayan, Island, Brgy. Baldat, Culion, Palawan. The owner of the establishment based on the
ECC, and available records is Mr. Ricardo Brito.

Findings and Observation:

1. The project has approved Environmental Compliance Certificate (ECC) No. ECC-R4B-
2001-0001dated 27 January 2020.
2. Discharge Permit (DP), DP-R4B-20-05520 dated 17 November 2020 was already
expired last 17 November 2021.
3. The proponent has updated Hazardous Waste Generators ID (HWG ID) OL-GR-R4B-
53-001252 dated 30 July 2020.
4. A Notice of Violation (NOV) for the 23 May 2022 was received by the proponent last
16 June 2022 re: non-compliance to their ECC condition no. 01, 03, 11, 12, and
restriction no. 01, 03, 04, 07, 09.
5. A technical conference was held last 20 June 2022 to discuss the violation in the said
ECC. Stated below are the commitments during the technical conference conducted and
their compliance as of 19 October 2022.
Commitments Remarks
Submission of position paper within ➢ Former PCO, Engr. Cacabelos
ten (10) calendar days submitted position paper last 30
June 2022.
➢ Present PCO, Engr. Oser
submitted supplementary
position paper under IIS no. R4B-
2022-019402.
Mitigating measures.

PENRO Compound, Brgy. Suqui, Calapan City, Oriental Mindoro

Regional Satellite Office: 6th Floor DENR by the Bay Bldg., 1515 Roxas Blvd., Ermita, Manila
Office of the Regional Director: (02) 8536 9786; Administrative and Finance Division: (02) 8536 9786
Environmental Management and Enforcement Division: (02) 8633 2587; Clearance and Permitting Division: (02) 8633 2587
Records Management Unit: (02) 8633 8900
E-mail Address: embmimaropa@emb.gov.ph
Website: www.mimaropa.emb.gov.ph
Rehabilitation plan to address ➢ Engr. Oser submitted a
siltation. rehabilitation plan for their
reclamation project dated 23
September 2022.
Gantt chart. ➢ As of 19 October 2022, no
submitted Gantt Chart.
Submission of laboratory results ➢ Ambient water sampling and
(both ambient and effluent). effluent activities were
conducted last 12 September
2022.
Actual site development plan. ➢ No submitted actual site
development plan
Photographs prior and present ➢ No submitted photographs for
showing development. prior and present.
Clarification from DENR re: tenurial ➢ The proponent set-up a meeting
instrument. with the CENRO office to clarify
tenurial instrument of the project.
Designate accredited Pollution ➢ During the time of inspection, the
Control Officer. Pollution Control Officer (PCO)
of the island resort is Engr. Mark
Raymond Oser and Ms.
Cacabelos already resigned her
position.
➢ No Pollution Control Officer
(PCO) Accreditation was
provided by the new designated
PCO during the time of
inspection. However, Engr. Oser
submitted complete documents
for PCO accreditation last 23
September 2022.
Source of materials used in the ➢ No submitted documents for
project. the source materials used in the
project.
Commitment to submit Engineering ➢ According to Engr. Oser they
Geological and Geohazard Report already request to MGB a copy of
(EGGAR). the submitted EGGAR.
➢ As of 19 October 2022, no
EGGAR was submitted.
Submission of 2017 and latest Marine ➢ Based on the records, former
Biodiversity Assessment. PCO submitted an incomplete
copy of the biodiversity
assessment which is included in
the position paper submitted.
➢ Engr. Oser includes a complete
copy of Biodiversity Assessment
Report in Naglayan on his PCO
accreditation application last 23
September 2022.
 Contract or Memorandum of ➢ No submitted MOA with a TSD
Agreement (MOA) with a Treatment, facility and transporter.
Storage and Disposal (TSD) Facility
and transporter.
Submission of management plan on ➢ As of 19 October 2022, no
hazardous waste. management plan on
hazardous waste was
submitted.
Submission of Environmental ➢ As of 19 October 2022, no
Monitoring Plan (EMoP) and EMoP and EMP was
Environmental Management Plan submitted.
(EMP).
File permit applications. ➢ Engr. Oser requests OPMS
account retrieval, and their
Hazardous Waste Management
System account.
➢ The proponent has Discharge
Permit application under
application no. 96339
➢ The proponent has Permit to
Operate (PTO) application under
application no. 219664.

6. A technical conference was conducted during the time of inspection, 12 September

2022 with the new designated Pollution Control Officer, it was discussed their violation
on the previous inspection and the committed documents that needs to be submitted.
7. Furthermore, the inspection team conducted validation/monitoring. Below are the
findings:
➢ Improper storage and labelling of hazardous wastes near the reclamation
area. Gas tanks are exposed to heat and weather. Other storage of
hazardous waste storage is located at the back of the power plant area of
the project with no proper labelling and containers showing rust. Spills are
also seen in the storage area near the power plant
➢ Based on the findings there are atleast five (5) septic tanks constructed
around the island and one (1) Sewerage Treatment Plant (STP) with no
discharge permits.
➢ No further activities are being conducted in the reclamation area of the
project. According to Engr. Oser, it was estimated that the reclaimed area
is around +/- 500 square meters that will be supposedly use as golf course
area.
➢ There are three (3) 312kw diesel generator sets that are being used to
power the island and one (1) unit of 472 kw diesel generator set for backup.
Based on the available records and during the time of inspection, no
presented valid Permit to Operate.
➢ The STP is located at the mountain top of the island. During the time of
inspection, the STP has no provision of sampling port and no installed
flow meter.
Ambient water sampling
Based on the records of EMB MIMAROPA, there is no official classification of the waterbody
around or near the Naglayan Island. However, based on the observations, and current utilization
of the surrounding waters in the island, class SB waterbody will be use as interim/temporary
classification until such an official waterbody classification is conducted. Based on DAO 2016-
08 the definition of class SB:

1.Fishery Water Class II – Waters suitable for commercial propagation of shellfish

and intended as spawning areas for milkfish (Chanos chanos) and similar species.
2.Tourist Zones – For ecotourism and recreational activities.
3.Recreational Water Class I – Intended for primary contact recreation (bathing,
swimming, skin diving, etc.).

Results of analysis is as follows:

Ambient Stations
Total Suspended Solids (mg/L)
Station Identification September 12, 2022 WQG Remarks
Front of Sun Cafe 24 50 Passed
Front of Malkapuya Cottage 38 50 Passed
Front of Playground <2 50 Passed
North of Docking Port 18 50 Passed
Front of Villa No. 9 & 11 14 50 Passed
Front of Villa No. 59 & 61 16 50 Passed
Front of Mangrove Area 26 50 Passed
Front of Sirakan Villa 26 50 Passed
Front of STP/Cluster Villa 21 50 Passed
Front of Mangrove
Restaurant
30 50 Passed

Phosphate (mg/L)
Station Identification September 12, 2022 WQG Remarks
Front of Sun Cafe 0.030 0.2 Passed
Front of Malkapuya Cottage 0.020 0.2 Passed
Front of Playground 0.030 0.2 Passed
North of Docking Port 0.030 0.2 Passed
Front of Villa No. 9 & 11 0.030 0.2 Passed
Front of Villa No. 59 & 61 0.030 0.2 Passed
Front of Mangrove Area 0.030 0.2 Passed
Front of Sirakan Villa 0.020 0.2 Passed
Front of STP/Cluster Villa 0.020 0.2 Passed
Front of Mangrove
Restaurant
0.040 0.2 Passed
 Nitrate (mg/L)
Station Identification September 12, 2022 WQG Remarks
Front of Sun Cafe 0.04 10 Passed
Front of Malkapuya Cottage <0.02 10 Passed
Front of Playground <0.02 10 Passed
North of Docking Port <0.02 10 Passed
Front of Villa No. 9 & 11 0.03 10 Passed
Front of Villa No. 59 & 61 <0.02 10 Passed
Front of Mangrove Area <0.02 10 Passed
Front of Sirakan Villa 0.02 10 Passed
Front of STP/Cluster Villa 0.02 10 Passed
Front of Mangrove
Restaurant
<0.02 10 Passed

Color
Station Identification September 12, 2022 WQG Remarks
Front of Sun Cafe <5 50 Passed
Front of Malkapuya Cottage <5 50 Passed
Front of Playground <5 50 Passed
North of Docking Port <5 50 Passed
Front of Villa No. 9 & 11 <5 50 Passed
Front of Villa No. 59 & 61 <5 50 Passed
Front of Mangrove Area <5 50 Passed
Front of Sirakan Villa <5 50 Passed
Front of STP/Cluster Villa <5 50 Passed
Front of Mangrove
Restaurant
<5 50 Passed

FC (MPN/100mL)
Station Identification September 12, 2022 WQG Remarks
Front of Sun Cafe 187.20 100 Failed
Front of Malkapuya Cottage 195.60 100 Failed
Front of Playground 179.30 100 Failed
North of Docking Port 261.30 100 Failed
Front of Villa No. 9 & 11 344.80 100 Failed
Front of Villa No. 59 & 61 <1 100 Passed
Front of Mangrove Area <1 100 Passed
 Front of Sirakan Villa 118.70 100 Failed
Front of STP/Cluster Villa 1.00 100 Passed
Front of Mangrove
Restaurant
4.10 100 Passed

Based on the result above, all stations passed the WQG for class SB waterbody in terms of
color, TSS, PO4, and NO3. However, six (6) out of ten (10) stations failed to pass the WQG in
terms of fecal coliform. Presence of fecal coliform in a waterbody indicates water
contamination. This may attribute to the buildings/infrastructures located near the sampling
stations.

Effluent sampling Analysis

During the inspection conducted, one (1) Sewerage Treatment Plant (STP) is constructed and
operational. Below is the result of analysis.

Parameters Result Standard (Class SB) Remarks

Biochemical Oxygen Demand
27mg/L 30mg/L (DAO 2016-08) Passed
(BOD), mg/L
Nitrates (NO3), mg/L 0.9mg/L 20mg/L (DAO 2016-08) Passed
Phosphates (PO4), mg/L 0.72mg/L 2mg/L (DAO 2121-19) Passed
Oil and Grease, mg/L 5mg/L 5mg/L (DAO 2016-08 Passed
Total Suspended Solids, mg/L 47mg/L 70mg/L (DAO 2016-08) Passed

Based on the laboratory analysis all parameters passed the WQG for class SB effluent standard.
However, fecal coliform was not collected due to both bottles and spare bottles were broken.

Recommendation:

Hereby are the recommendations, to wit:

1. Based on the result of analysis on ambient (coastal) source, six (6) stations failed to
meet the WQG for class SB waterbody in terms of fecal coliform. Recommended for
another ambient monitoring/sampling. And conduct of split sampling for effluent.

2. A Notice of Violation (NOV) was issued last 16 June 2022. A supplementary position
paper was already submitted last 23 September 2022. Recommended to conduct
technical conference with the proponent to discuss the findings. And draft
communication letter to the proponent, reiterating to submit the lacking pertaining
documents.

3. Additionally, it is recommended to send/draft communication letter for the proponent

to submit the rehabilitation plan on the reclamation as siltation are already visible
during the time of inspection.

4. Endorsed the report to Philippine Reclamation Authority (PRA) to conduct site

validation and inspection on the reclamation area.

5. Endorsed the report to Mines and Geoscience Bureau – MIMAROPA (MGB-

MIMAROPA) to conduct Geo-hazard Assessment in the location.
Submitted by: Reviewed by:

KARL ALEXANDER R. DAMMAY FOR. EDNA S. VELASCO

EMS I/Chief - EMS Coron Chief, PEMU - Palawan
 Photo documentation

Water sampling in the coastal areas (1) Water sampling in the coastal areas (2)

Water sampling in the coastal areas (3) Effluent sampling (1).

Effluent sampling (2). Labeling of collected effluent sample.

Portion of reclamation in Sunlight Island (1) Portion of reclamation in Sunlight Island (2)

Portion of reclamation showing siltation (1) Portion of reclamation showing tree planted
as part of their rehabilitation.

Meeting and technical conference with Portion of reclamation showing sandbags to

Engr. Mark Raymond Oser. prevent siltation.
Portion of reclamation with approximate +/- Storage of used oil/diesel next to their
500sq.m powerplant.

Used gas tanks exposed to weather. Part of greening program of the island.

Used gas tanks and other tanks exposed to Sample of 5-chambered septic tank.
weather.
1 out of 3, 312kw diesel generator set in the 2 out of 3, 312kw diesel generator set in the
power plant. power plant.

Motorpool area of the project showing other Rusted tanks/drum for the used oil/diesel
waste stored.

The one (1) unit 472kw diesel generator set. Motorpool.