Illegal disposal of toxic industrial waste at Nong Nae, Phanom Sarakham District, Chachoengsao Province

In July 2012, villagers in Tambon Nong Nae requested the police to impound a lorry truck for illegal disposal of toxic industrial waste in a 15-rai size dirt pond (approx. 6 acres) at Tambon Nong Nae, Phanom Sarakham District, Chachoengsao. The company involved in the illegal disposal claimed responsibility before the court and commissioned a consultant firm to treat the polluted water. In addition, the Chachoengsao governor specifically set up a working group to resolve the problem. In November, Love Nong Nae Group contacted Health Impact Assessment Coordinating Unit under the NHCO to voice their concerns on possible health impacts from the illegal toxic disposal.

“Section 5 of the National Health Act B.E.2550 (2007) states „a person shall enjoy the right to live in the healthy environment and environmental conditions. A person shall have the duties in cooperation with State agency in generating the environment and environmental conditions under paragraph 1.‟ In addition, Section 10 indicates that „in the case where there exists an incident affecting health of the public, a State agency having information related to such incident shall expeditiously provide and disclose such information and the protection thereof to the public.‟”

In November 2012, HIA Coordinating Unit held a meeting with concerned villagers to jointly brainstorm existing problems and seek measures to promote public participation in formulating solutions. It also visited the site and found that there were numerous areas in Tambon Nong Nae that risked toxic contamination and serious health impacts. These areas included 2 certified landfills, 1 waste disposal factory, 1 oil recycling factory and numerous dirt ponds with illegal disposal.

In January 2013, HIA Coordinating Unit joined the community to set up an assessment framework. It began with a review on previous government information and visual data based on community‟s statements on existing impacts. The study then reviewed previous significant development projects and changes. It also mapped risks on the community. Village chief and members of Nong Nae Tambon Administrative Organization (TAO) of each village engaged in the assessment. Elders, pig farmers, mango farmers, vegetable gardeners also joined. The assessment discovered the following:

Nong Nae is an important food producing area. It has both agriculture (Pad Riw‟s famous mangoes) and livestocks (pig farms). Its products are sold domestically and exported to other countries. Geographically, Nong Nae is a hilly lowland with slope ascending from the south to the north, ranging 10-40 meters above sea level. It has system of irrigation canals from Tha Lad Irrigational Dyke Project. Bung Krajub Canal is another important canal. The land is dominantly loamy sand with good water infiltration, suitable for farming. In the north and west of Tambon, it is mostly clay with poor water infiltration, suitable for rice cultivation. There are 15 villages, composing of 3,000 households or a population of 9,000. The total area is 45,625 rai. Paddyfileds occupy most of the land. Residential areas, gardening, farming and common land, like a community forest, make up the rest of the area in close ratio. This reflects how locals make a living as the majority of the villagers is rice farmers. The rest are gardeners, other types of farmers and others.
Significant changes in the area began when an outside investor arrived the area to purchase land. He dredged the soil, sold it and deserted the land with dirt ponds. A new investor arrived and purchased the land to build an oil recycling factory and a toxic waste treatment factory. Illegal disposal toxic water and industrial waste in the dirt pond started in 2012.
A report by the Department of Special Investigation (DSI) revealed that illegal disposal of toxic waste occurred in more than one area of Tambon Nong Nae and its adjacent. Areas with hazardous risks on human and domesticated animals were categorized into 3 areas: 1) Industrial waste treatment factory, 2) Landfill with a mix of wastes from Bangkok and industrial wastes, and 3) Dirt ponds where the illegal disposal occurred. Most of these highly risky areas sit upstream while the community stays downstream.
Every house in Nong Nae community uses the water from shallow ponds for drinking, eating, animal feeding and farming. Department of Groundwater Resources found many ponds were contaminated with toxic substances, especially phenol. The contamination spread wide over Nong nae, making the water too toxic for consumption. Some ponds were still drinkable if the drinkers managed to reduce iron and manganese in the water. Test results by Department of Industrial Works and Department of Pollution Control also indicated similar toxic trend.
Toxic contaminants affect domesticated animals and the health of the people. In 2008, many pig farms faced with great loss when the first batch of newborn pigs died out. Miscarriage occurred more frequently; some sows gave birth before the expected time. Newborn pigs were born with deformation. Sows were not eating. Their breast milk were dried up. Growth rate slowed down among small pigs. As a result, some pig farm owners decided to shut their farms down. Vegetables cultivation was also affected. Villagers could not sell as much vegetables as before because consumers were concerned about food safety. There were cases where the villagers had to seek medical help from Nong Nae and Plai Krajab Tambon Health Promotion Hospitals after the illegal disposal of toxic waste in the 15-rai dirt pond. Common symptoms among the affected villagers included dizziness, confusion, burning sensation at the nose, difficulty in breathing and fatigue. Phenol was also detected in some of the villagers‟ blood.

The preliminary study helped frame the research framework, which includes the following issues and/or questions:

Toxic contamination identification testing in the area (Which contaminants are present in the area? How toxic is it? How can it affect the people‟s livelihoods?)
What kind of resolutions needed to ensure a safe environment for the community? (Immediate response measures, water treatment to safeguard a safe water source for the community, seeking systematic treatment and rehabilitation measures)
Mobilize for a declaration on Nong Nae as a pollution control area and a systematic rehabilitation measures.

On 31 March 2013, approximately 100 members of Nong Nae Conservation Group submitted a letter to the prime minister at the Cabinet meeting in Chachoengsao. The group requested the Cabinet to take immediate response on the widespread impacts of illegal disposal of industrial wastes and toxic water on the community livelihoods.

Later, on 15 May 2013, the prime minister delegated the Deputy Secretary-General to the Prime Minister for Political Affairs to investigate on the issue. A meeting was held at Nong Nae Tambon Administrative Organization‟s office with local government agencies and approximately 100 affected villagers attended. Subsequently, the Secretariat of the Prime Minister responded to the community‟s request and assigned the SecretaryGeneral of the National Health Commission (NHC) to investigate the chemical contamination and design a guideline for rehabilitation in the area with Environmental Research and Training Center, Department of Environmental Quality Promotion and Engineering Faculty of Naresuan University.

Consequently, NHC sought for collaboration from Environmental Research and Training Center, Department of Environmental Quality Promotion, Chemistry Department of Kasetsart University and Engineering Faculty of Naresuan University. Water, soil and sediments samples were collected to test for toxic substances. The working group also formulated a guideline for environmental rehabilitation.

Chemical analysis and preliminary findings

Soil samples were collected from the community‟s shallow ponds and areas near the industrial waste disposal site (reported by the community). Additional water and soil samples from a local canal, Tad Noi Canal, were collected as the canal runs through all affected areas. These samples were preliminary tested for organic contaminants. The test found the following contaminants in the samples:

Phenol and phenol derivatives. Phenol is a common precursor. For example, a reaction of phenol and formaldehyde gives phenolic resin, used as coating in electricity system and food cans.
Solvents. Includes cyclohexane, cyclohexanone, cyclohexanol, and tetradecane. Cyclohexane is an industrial solvent. Catalytic oxidation converts cyclohexane into cyclohexanone and cyclohexanol, which are used to make adipic acid and caprolactam, known as precursors to plastics and nylon. Tetradecane is fatsoluble dispersing agent for metal. It is also used to produce colors and color dying.
Compounds in long-chain hydrocarbon. Includes hexadecane (consists of 16 carbon atoms; C-16), octadecane (C-18), nonadecane (C-19), eicosane (C-20), and heptacosane (C-27). These long-chain hydrocarbons are used in engine oil.
Substances used for polymer additives. Detected contaminants include Bisphenol, additives for plastic and epoxy resin; phthalate, plastic additives; caprolactam, precursor to nylon; 3,4-dimethylbenzaldehyde, plastic additives; polyolefin, creates a clear feature in plastic; phthalic anhydride, precursors to plastic, polyester, polyalcohol, colors, dye, insect repellent, leather dye, perfumes and medicines; 2-propanol and 1-chloro-phosphate, used for refractory materials; 1,2-Benzenedicarboxylic acid and bis (2-methylpropyl)ester, used for nitrocellulose; Benzene, 2,4-disocyanato-1-methyl, used for foams and glue; polyurethane Benzotriazole and 4-methyl, used as anti-freezing substances in styrene engines, for synthetic tire and plastic, resin, colors and foam coating.

Exposure to these contaminants, particularly phenol and polymer additives, can cause harmful effects on human body mainly on the reproductive system. They can cause gene mutation and may lead to cancer. Further scrutiny was suggested to improve accuracy of the findings; however, data proved that contamination was a humaninduced effect, not a natural cause.

After the survey, the working group proposed a guideline for toxic rehabilitation in Nong Nae. The guideline was consisted of the following 4 measures: 1. Immediate removal action at potential risky areas 2. Remediation 3. Assessment and preventive measures 4. Have a common goal and promote participation from all stakeholders, especially the affected community

Measure 1: Immediate removal action at potential risky areas, mainly in 2 areas.

Design and set up a phenol treatment system in shallow ponds used for local consumption. The initial assessment drew out 4 treatment options: 1) Natural treatment by allowing phenol and other toxic substances to evaporate or apply air stripping technique; 2) Natural treatment by using bacterial decomposition or engineered bacterial decomposition; 3) Absorption; or 4) Using electrochemical oxidation to decrease toxicity. After taking into account other factors such as water consumption, cost in creating the system, cost in running the project to assess the project‟s feasibility, the most suitable option was absorption . The next suitable option was to apply oxidants to decrease toxicity.
Design and set up a phenol treatment system at the ponds in Manus District where illegal industrial wastewater took place. Engineering Faculty of Naresuan University applied Redox Manipulation, a system that combines electrochemical oxidation system with reduction by iron system, to remove phenol. The result was very satisfying as phenol was removed sharply with no toxic remnant. As this system could be easily developed into a larger-scale, the research team recommended the decision makers to adopt this method to cleanup toxic substances in Manus ponds expeditiously in order to reduce toxic leaks into the environment.

Measure 2: Health and environmental impacts assessment after removal action shall be conducted in all areas, including the 15-rai pond and the ponds in Manus, to determine whether remediation must be implemented. As it is possible that toxic substances, once leaked into the environment, can infiltrate into the soil and groundwater and can possible lead to secondary toxic contamination in the community‟s ponds. Samples around the affected site should be collected. Statistical analysis should be applied to determine possible risks from toxic remnants and further necessary actions. If no risks remain or at an acceptable level, no further action is needed. However, if some toxic remnants still remain, remediation must be implemented to reduce the risks to an acceptable level.

Measure 3: A survey of all possible leak sources in the affected area must be conducted to assess contamination and to prevent future toxic leaks. The Fate and Transport Modelling can be applied to analyze the distance the toxic substances will travel and potential impacts when a leak happens. The model can help visualize impacts if a leak happens today or in 30 years. If there is a possibility that a leak may happen and cause harmful impacts on human health and the environment, removal action and remediation must be implemented immediately to prevent future contamination. This process may be costly but it is not as costly as rehabilitating a contaminated area.

Measure 4: Cooperation is important to resolve the problem. Public participation is crucial. Informed decisions can be made if accurate scientific data is available. Creativity is also important. Information and success stories of rehabilitation projects and preventive measures should be disseminated to national and local government agencies, NGOs and businesses with potential sources of contamination.

By the end of June 2013, HIA Consortium, a network of HIA academics, held a conference at Nong Nae Tambon Health Promotion Hospital to hear the findings from the preliminary survey and rehabilitation guideline proposals. Relevant government agencies and the community were invited to hear the findings. HIA Consortium also visited affected areas, including the pig farmer whose blood is contaminated by phenol, pig farms have high miscarriage rate and well contains phenol.

On 29 July 2013, the findings were presented at “Integrated Research on Monitoring and Remediation Measures for Health and Environmental Impacts of Toxic Contamination Forum” held during the 9th Naresuan Research Conference. In addition, on 5 August 2013, the findings were presented at “Remediation and Rehabilitation Guidelines for Toxic Contamination Incident at Nong Nae, Phanom Sarakham District, Chachoengsao” at Faculty of Medicine, Chulalongkorn University. Relevant government agencies at local and national levels as well as the public, NGOs and toxicity experts attended the forum. The findings would later be submitted during the National Health Commission‟s regular meeting.

However, the findings were not placed on the agenda for the National Health Commission‟s regular meeting. Nonetheless, the Chachoengsao governor used the research and its findings to seek budget for the phenol reduction system, as suggested in Measure 1.The budget was approved and the community now have an electrochemical oxidation system to reduce phenol in their ponds.