Bolong Fenyo Water Quality Report “High Levels of Phosphate and Carcinogens (Cancer Causing)”


By Mark Chernaik of Reef Analytics

A sample of seawater collected from the Bolong Fenyo Water Reserve on 22 May 2017 was subjected to lab testing and the results were analysed by one of the experts at Reef Analytics. Reef Analytics is a German based Environmental Technology company who conducted a water analysis testing and analysis of the results. The highlights of the testing conducted highlight the high concentration of Phosphate, Arsenate and Arsenic (Carcinogens) which can lead to serious illnesses and cancer.

The analysis and sections of the report are reproduced below and the entire report is available upon request for the general public to view and submit their interpretation for the benefit of the general public. In light of this we also challenge the National Environmental Agency and the Ministry of Environment to make their report available for the general public to scrutinise.

“The result that stands out is the alarmingly high levels of phosphate in the seawater sample.  According to the WB/IFC document I sent earlier (“Environmental, Health, and Safety Guidelines for Fish Processing).”

“Fish processing wastewater has a high organic content, and subsequently a high biochemical oxygen demand (BOD), because of the presence of blood, tissue, and dissolved protein. It also typically has a high content of nitrogen (especially if blood is present) and phosphorus.”

The problem with excess levels of phosphate in aquatic systems (both marine and freshwater) is that phosphate stimulates the growth of bacteria and algae, resulting in deleterious changes in water quality, including depletion of dissolved oxygen, in a process called ‘eutrophication.’  Please see the attached document (Chongprasith, P., Wiliratanadilok, W., & Utoomprurkporm, W. (1999). ASEAN marine water quality criteria for phosphate. ASEAN-Canada CPMS-II Cooperative Programme on Marine Science. Department of Pollution Control, Thailand), which I quote from below:

“2.3 Concentration of Phosphate in the Marine Environment

“In surface waters, phosphate concentrations are usually very low, less than 31 μg/L (Valiela, 1984), primarily due to the uptake of phosphate by algae and bacteria

“Marine environmental monitoring studies conducted in the ASEAN region showed that phosphate concentrations in coastal sea water ranged from below detection limits to 195.92 μg/L and the concentrations found in estuaries were <3.1 – 179.8 μg/L as shown in Table 1. Highest concentrations of phosphate were found in river mouth areas and coastal waters affected by runoff. ….


“The main deleterious effect of phosphate in coastal waters is eutrophication. While phosphate is an essential nutrient required for normal productivity, elevated concentrations can result in an upset of the ecological balance of tropical marine systems. Unlike some other chemicals (e.g., heavy metals), phosphate is not toxic in the usual sense. Rather, it causes ecological changes that can have negative impacts on aquatic systems. Therefore, derivation of an AMEQC for phosphate depends more on information about the biological effects of phosphate, as opposed to its toxicity.  ….

“3.1 General Background on Phosphate

“Phosphate itself is not directly harmful (i.e., toxic) to marine organisms at concentrations found in the marine environment. However, high concentration of phosphates can lead to eutrophication, which is the process that occurs when nutrient levels increase and encourage the over-production of plants and algae.  This process occurs naturally and there are many historical records which report such events long before extensive urban development and the use of artificial fertilisers and detergents. However, anthropogenic nutrient inputs have accelerated this process in many areas.

Conditions favouring eutrophication usually occur during dry seasons when water flows are low, causing nutrient concentrations to rise. …

“3.3.3 Recommended Criteria For Dissolved Reactive Phosphorus

“Australia and Hawaii have marine water quality guidelines for total phosphorus. Australia limits total phosphorus concentrations to 5 μg/L in coastal waters and 10 μg/L in estuarine waters (ANZECC, 1992).  Hawaii has developed separate total phosphorus guidelines for various marine water body types (i.e., estuary, embayments, coastal and oceanic) and seasons (i.e., wet and dry). Guidelines range from 16 μg/L (geometric mean of measured values in open coastal waters during dry season) to 75 μg/L (not to be exceeded more than 2% of the time in embayments during the wet season).

Based on the above information, interim criteria for dissolved reactive phosphorus were derived for estuarine (45 μg/L) and coastal waters (15 μg/L). These criteria are intended to protect coastal waters from eutrophication. Compared to the ambient concentrations of dissolved reactive phosphorus in the ASEAN region, 65% of the maximum and 89% of the minimum concentrations fall below 45 μg/L, while 40% of the maximum and 77% of the minimum concentrations fall below 15 μg/L. The criteria are designated as interim due to the lack of data linking dissolved reactive phosphorus (or even total phosphorus) to eutrophic conditions in the ASEAN tropical marine environment.”

Report # 39461706 of Reef Analytics shows that phosphate levels in the sample of seawater collected from the Bolong Fenyo Wildlife Reserve on 22 May 2017 are starkly higher than maximum levels necessary for the protection of marine aquatic life:

Orthophosphate (PO43−) is a dissolved reactive form of phosphate.

Two results are presented in the report because orthophosphate was measured in the lab by two different methods – photometrically (result = 2429 µg/L) and by Inductively Coupled Plasma Mass Spectrometry (ICP-MS) (result = 9037 µg/L).  Of the two, ICP-MS is the more sensitive method.   At any rate, it is important to point out that an orthophosphate concentration of 9000 µg/L, is 200 times a value deemed necessary to prevent eutrophication in estuarine waters, and 600 times a value deemed necessary to prevent eutrophication in other coastal waters.

Similarly, the concentration of nitrate in the sample of seawater collected from the Bolong Fenyo Reserve on 22 May 2017 is quite high.   Please see the attached document Deocadiz, E., & Montano, N. (1999). ASEAN marine water quality criteria for nitrate/nitrite. ASEAN-Canada CPMS-II. Cooperative programme on Marine Science (CPMS). AMWQC for nitrate/nitrite.), which I quote from below:

“3.4.1 Review of Existing Criteria for Seawater

“Few countries have established criteria for nitrate/nitrite in marine waters. Table 5 summarizes the environmental criteria, guidelines and standards for nitrate/nitrite from Hawaii and the Netherlands. In North America, no criteria have been established for the United States (U.S. EPA, 1993) or for British Columbia (Nagpal, 1995) for marine waters. Australia does not have a single set of guidelines for nitrogen to prevent phytoplankton blooms in estuaries and coastal waters, and recommends that site-specific studies be conducted instead (ANZECC, 1992); for nitrate, concentrations above which adverse effects have been known to occur are: 10 – 100 µg/L NO3-N for estuaries and embayments, and 10 – 60 µg/L NO3-N for coastal waters.  …

“For nitrate, the only available tropical toxicity data were for one chronic study and four acute studies with invertebrates. As with nitrite, the most sensitive EC50 value (1.2 mg/L NO3-N for a 96-h larval development test with T. gratilla) was multiplied by 0.05 to yield a result of 0.06 mg/L NO3-N (60 µg/L NO3-N). This nitrate concentration was also expected to be suitable for protection of coral reef areas from eutrophication.”

Report # 39461706 of Reef Analytics shows that nitrate levels in the sample of seawater collected from the Bolong Fenyo on 22 May 2017 are quite higher than maximum levels necessary for the protection of marine aquatic life.

A value of 1.7 mg/L is equivalent to 1700 µg/L, which is higher than nitrate levels that are toxic to larval stages of fish and nearly 30 times higher than a level deemed necessary for the protection of marine aquatic life.

It is also important to note that the WB/IFC document I sent earlier (“Environmental, Health, and Safety Guidelines for Fish Processing) impose ‘best-practice’ limits on the discharge of pollutants, including nitrogen and phosphorus.

To the extent that the Chinese Golden Lead Company’s Fish Factory in Gunjur is the only significant source of pollution in the Bolong Fenyo Wildlife Reserve, then it is my opinion that the phosphate and nitrate levels in the Reef Analytics report are evidence that the fish factory is causing deleterious impacts to the environment through failure to follow best practices for abating the impact of a fish processing plant. There is a substantial possibility that a harmful algae bloom caused by excessive levels of nutrients released by the factory was the cause of the deep red discoloration of seawater from the wildlife reserve that was observed on 22 May 2017.

The other parameters analyzed in the sample of seawater collected from the Bolong Fenyo Wildlife Reserve on 22 May 2017 are not of much significance from an ecological or toxicological perspective.

Arsenic and Arsenate are also strong carcinogen (cancer causing)”


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