Risk Assessment Case: Bancolombia

After reading LaGrega's Chapter 14, I decided that the best way to put into context the information contained therein, was to apply it to a very controversial site remediation case going on right now in Colombia. I will describe the case in its entirety, based on the little information made public, and relate it to the different components that make up Risk Assessment as described in the "Quantitative Risk Assessment" chapter.


The case takes place in the port city of Cartagena. In the 1980's the Cotton Growers Federation owned vast areas of land south of the city, and used it as a hazardous waste land disposal area for obsolete pesticides, mainly organophosphates and organchlorines. In the 1990's, the Federation sold the property to the government, which later on sold it to Bancolombia, the largest bank and construction developer in the country. Little did Bancolombia know that when they started developing the land for residential use, it would be faced with an unprecedented site contamination case. This of course, brings about issues of responsible parties and at present none other than the bank has been held responsible for the site remediation.




The contamination was first discovered after nearby communities complained to the environmental authorities of bad odours and air contamination. At this point, little attention was paid to the complaints and the construction of 1,200 houses in the area began. As a result of severe thunderstorms during summer in the Colombian northern coast two years ago, landslides partially uncovered large quantities of obsolete pesticides in plastic containers. As a result of this discovery, the Ministry of Environment (the Colombian equivalent of the US EPA) decided to shut-down further construction and opened a specific case to determine the steps to follow regarding the site remediation.

The case was taken to the Chamber of Representatives by the bank and established a lawsuit against the Colombian Ministry of Territory for assigning the lands for residential development. At this moment, no result has come out of this. The bank, however, argues that the problem would have been avoided if a land assessment study would have been contracted by the government prior to the emission of the building permits, and if the complaints from nearby residents had been attended to on time (http://direccion.camara.gov.co/camara/site/artic/20060623/pags/20060623125302.html). At present, the Ministry of Environment has no rulings or standards regarding Phase I or II Environmental Site Assessment or Transaction Screening.



As a result, the government declared the bank the sole responsible party and excluded the Federation with no regard for the contamination that occurred decades ago or the inadequate hazardous waste management practices carried out by them during the 1980's. The bank then proceeded to contract specialized environmental consulting firms to determine what would be the next step for them. Since the bank is a public corporation, their contracting process is very long and complicated, but they finally decided to divide the site remediation process into two stages: 1) Hire an environmental consulting firm to carry out the entire risk assessment study for the site. For this part, they hired ERM and the assessment is still in process. 2) According to the risk assessment results, contract the most suitable site remediation technology out there to clean up the site. For this section, companies like Tredi and Veolia Environnement are in the process of submitting their offers for thermic desorption services. It has been estimated that the site contains a total of 2 million tons of contaminated soils. Since Colombia ratified the Basel Convention, the soil can only either be exported to Europe or in can be incinerated in-situ. However, for the in-situ option, the machinery would have to be imported into the country first, since that technology is still not widely available. One important issue to keep in mind, is that no consideration, except through ERM's study, has been made to determine the exposure assessment, contaminant transport/transfer/transformation, in order to assess the real extent of the contamination in the area.



Also, one of the most interesting parts of this case is how poorly managed (or who know intelligently managed) the risk communication has been. I am aware of the existence of this case because I work with one of the companies interested in providing the site remediation services to the bank. However, the majority of the population, including those living in nearby areas, are ignorant of the situation and the long process that is taking place to find a solution. The government and the bank have taken special care of the information, I guess in order to avoid public outrage and protect economic and political factors of the situation.





As far as hazard identification, exposure assessment and toxicity assessment are concerned, they to be determined by ERM, including risk characterization. Nonetheless, I am almost sure none of this information will be made public, and will be used only by the bank to make the most adequate and feasible decision. I must also add, that in short, the bank wishes to put this behind as soon and as quietly as possible, in order to maintain their reputation, put an end to the government's pressure, and of course, to sell the houses.

If you wish to read about the resolutions emitted by the Ministry of Environment ordering the bank to take charge of the situation, please click on the links below (I do apologize but they are in Spanish):

http://www1.minambiente.gov.co/prensa/gacetas/2007/febrero/res_0291_190207.pdf


http://www1.minambiente.gov.co/prensa/gacetas/2006/febrero/res_236_080206.pdf