Obyan Drum Site, Lot No. 037 L 52 (Naftan Road, Saipan)
The Obyan Drum Site (Lot No. 037 L 52) is located near the southern coast of Saipan, Commonwealth of the Northern Mariana Islands. A Phase I environmental site assessment (ESA) was conducted by Koa Consulting (Koa). The site is located within a plot of private land (former Public Land) consisting of 2,412 square meters (~0.60 acres). This property was part of a CNMI Department of Public Lands (DPL) land exchange and is located just south of the Saipan International Airport, along Naftan Road.
The purpose of the Phase I ESA is to identify, to the extent feasible pursuant to the process prescribed in ASTM International (ASTM) E1527-13, recognized environmental conditions (RECs) in connection with the property. An REC means the presence or likely presence of any hazardous substances or petroleum products in, on, or at a property: (1) due to any release to the environment, (2) under conditions indicative of a release to the environment, or (3) under conditions that pose a material threat of a future release to the environment. The ASTM E1527- 13 practice constitutes all appropriate inquiries (AAIs) for the purpose of Landowner Liability Protections, under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).
The Phase I ESA identified the following de minimis condition in connection with the subject site:
- The four general areas with approximately two dozen corroded metal drums of unknown origin and unconfirmed content.
Based on the findings of this Phase I ESA, including the results of the site reconnaissance, interviews, and records review, Koa Consulting offers the following professional opinion:
- The identified de minimis condition does not have the potential to adversely impact the environmental integrity of the subject site and does not present a material risk of harm to public health or the surrounding environment, therefore no further site investigation is required to address this condition further.
The following recommendations, though not required under the ASTM E 1527-13 standard, are provided as a courtesy to CNMI BECQ and to the land owner:
- It is the professional opinion of Koa that further site investigation following the ASTM Standard Process is not warranted to assess the extent of potential contamination caused by the identified de minimis condition. Federal and/or local Government funds could be utilized to sample and analyze the contents of the corroded drums found on site, in compliance with CNMI and US Hazardous Waste Determination processes. After making this determination, if the contents of the drums do not meet the definition of a hazardous waste, then the contents can be reused in road construction projects as is commonplace throughout the world for older asphalt, or bitumen, products. If a determination does lead to the conclusion that any of the drum contents are a hazardous waste, then CNMI and Federal laws and regulations which govern hazardous waste management and disposal would apply.
- It is Koa’s opinion that the current land owner should bear no financial responsibility for the recommended hazardous waste determination and subsequent clean-up activities with regard to the identified de minimis condition, as this condition most certainly existed at the site prior to transfer of land ownership.
- Koa recommends that, should the land owner decide to access the groundwater resources at their property in the future, then they should coordinate & communicate early and often with the BECQ Drinking Water branch regarding the ongoing PFOA and PFOS assessment and remediation project currently ongoing for some of the supply wells located around the Saipan International Airport.