by Robin Kemp

NOTE: This story contains the names of many organic chemicals and other contaminants. Where possible, we have linked the chemical or heavy metal’s name to a plain-language flyer or ATSDR site explaining what the chemical is and how it can affect people, animals, or the environment. Some TOXFAQ flyers are available in Spanish and Vietnamese.

The U.S. Army Corps of Engineers is giving the public until March 26 to comment on its proposal for cleaning up decades of toxic waste that has seeped off base from a landfill on the north side of old Fort Gillem into groundwater in Forest Park.

The notice asking members of the public to e-mail written comments between February 25 and March 26, 2021 was published in the Atlanta Journal-Constitution.

Aerial images from Google Maps showing the general area of the North Landfill on the site of the former Fort Gillem. Tons of contaminated soil have been removed from the area.

According to the draft plan prepared for the Corps by Aptim Federal Services, LLC of Knoxville, TN, the Army has three options:

  • Do nothing: This option is strictly theoretical and serves as a measuring stick for how well the other two methods might work.
  • Monitored Natural Attenuation (MNA) and Institutional Controls (IC): Basically, this means letting nature take its course, prevent people from using the water on base, educate people outside the base about the dangers, and monitor the chemicals in the groundwater.
  • Enhanced Bioremediation with MNA and ICs: Inject microorganisms, vegetable oil, and other substances to help the microorganisms (for example, fungi or bacteria) eat up the contamination and turn it into what the Army calls “innocuous end products.” Scientists have tested this method at an experimental site on an Air Force base in Washington State. However, because the combination of chemicals and the geology of every real-world site is unique, scientists say it’s difficult (if not impossible) to predict how well it will work.

The cleanup method the Army recommends is “enhanced bioremediation with MNA (monitored natural attenuation) and ICs (institutional controls).”

In plain English, that means the Army would squirt a mix of vegetable oil, microbes that eat pollution, a food source like molasses to feed the microbes, and a”buffer” into underground water that flows from the old dump on the north side to the neighborhoods on the other side of the fence.

Here’s how it works: the mixture is injected across the underground water current. The microbes then attack volatile organic chemicals, or VOCs for short, breaking them down into “innocuous end products.”

A diagram of how on-site (in situ) bioremediation might work at the old Fort Gillem FTG-01 North Landfill Area. (Image: EPA Office of Solid Waste and Emergency Response)

Because the levels of contamination are so high, the report says, “a CERCLA §121(c) review will be conducted every five years until the site contamination reaches concentrations that are safe for Unlimited Use and Unrestricted Exposure.” The EPA’s use of the terms “unlimited use” and “unrestricted exposure” are “aspirational”–meaning they’re something to shoot for but not likely attainable.

CERCLA, which stands for Comprehensive Environmental Response, Compensation, and Liability Act, is better known as Superfund. Congress passed the law in 1980, which put a five-year tax on oil and chemical companies. $1.6 billion went into a trust fund, which the government uses to clean up “abandoned or uncontrolled hazardous waste sites.”

Despite the massive amount of contamination, the FTG-01 site is not designated as a Superfund site.


A brief history

In 1979, according to the EPA, the Army had documented “that soil, sediment, surface water, and groundwater have been impacted by buried material” in the FTG-01 North Landfill Area. “Four dissolved-phase groundwater plumes are associated with the [landfill area], three of which have migrated off the former Fort Gillem property into adjacent residential areas.” In addition, the EPA wrote, Conley Creek, Eastern Stream, and Western Stream “contain site-related contaminants, including volatile organic compounds,” that run through the local neighborhoods.

In 1992, according to the EPA, “trichloroethene (TCE) and other contaminants,” including “related volatile organic compounds” were found in neighborhood groundwater.

Since at least 1993, the EPA says, the following chemicals have been documented as seeping up through the soil at the North Landfill Area: dichlorobenzene (acetone), 1,1-dichloroethane, trichlorofluoromethane, vinyl chloride, methylene chloride, ethylbenzene (xylene), trichloroethene, benzene, toluene, xylene, chlorobenzene, trans-1,2-dichloroethene, isopropyltoluene, tetrachloroethene, 1,2-dichloropropane.

In 1994, Georgia Environmental Protection Division listed the known groundwater contaminants at the North Landfill Area. It included every regulated substance on the list. In addition, the soil was found to have lead, arsenic, chloroform, and trichloroethane:

Substances the State of Georgia Environmental Protection Division knew, in 1994, to be in the groundwater and soil at Fort Gillem’s North Landfill Area.

The Army found contamination in private wells outside the base and paid for the people who owned those wells to connect to the county’s water pipes. It also handed out bottled water to Forest Park residents. According to the EPA, levels of trichloroethene, tetrachloroethene, and 1,1,2,2-tetrachloroethane in groundwater plumes outside old Fort Gillem were documented as being “above health-based standards.”

In 2003, soil gas testing near Slate Road and Mallard Road in Conley found 1,2,4-trimethylbenzene, 1,3,5-trimethylbenzene, tetrachloroethene, toluene, ethylbenzene, and xylene, the EPA said.

In 2010, soil samples taken from the North Landfill Area revealed more than a dozen dangerous chemicals, including the banned pesticide DDT, at exponentially higher than Georgia’s Hazardous Site Response Act levels:

The figures EPA cited came from the Final Progress Report North Landfill Area Site Wide Data Evaluation, published in April 2003.

In 2011, “the Army and Georgia EPD discovered a private well in use [on Slate Road], approximately 300 feet north of the Facility boundary,” that was contaminated with trichloroethene and cis-1,2-dichlorochloroethene. The Army paid to hook up that location to county water.

In fiscal year 2012 (in a report printed in 2013), the Gillem Enclave Army Defense Environmental Restoration Program Installation Action Plan noted, “The community has expressed no sufficient, sustained interest in an RAB (Restoration Advisory Board).”

In 2014, the Army did an air study “outside of the former Fort Gillem boundary in areas of known or suspected groundwater contamination. Soil gases collected in August 2014 in residential areas beyond the north boundary of the Site show elevated level of several contaminants….consistent with the contaminants or class of contaminants found on the Fort Gillem property, in various environmental media, during previous investigations of Fort Gillem.”

17 homes were studied. According to the EPA:

  • 9 homes “warrant(ed) prompt mitigation” because the chemicals found in indoor air or crawl spaces “exceed(ed) health-based benchmarks”
    • The limit for 1,2,4-trimethylbenzene, which the National Library of Medicine’s National Center for Biotechnology Information says is associated with nervous system diseases, learning disabilities, and fetal weight, was 14.6 micrograms per cubic meter. Imagine a cube of air just a little less than three feet wide on all sides. The health limit for that chemical is 35 billionths of an ounce. To give you an idea, a single peppermint is less than two-tenths of an ounce. In other words, a tiny speck that you can’t see is enough to make you sick.
  • 6 homes “require monitoring”
  • 2 “require additional evaluation”

When will it be “clean?”

The proposed cleanup process is not a quick fix. The report estimates it would take 15 years–until 2036–to get the site clean enough for commercial or industrial uses. When the Army eventually sells the site to the City of Forest Park through the city’s redevelopment agency, “restrictions prohibiting residential use and groundwater use will be included in the deed transferring the Site.”

However, that 15-year number is not hard and fast. It could take longer if new areas of contamination are discovered. It also could depend on how much contamination is in the water and how quickly the microbes eat them.

And if new regulations or laws are passed about how such sites should be handled, that could lengthen (or shorten) the time that the Army is required to clean up the site. If legislation were to pass that, for example, raised existing safety limits, the cleanup could end sooner but be less effective. Conversely, a law that lowered acceptable limits could require more of the contamination to be cleaned up, but would require a longer treatment and monitoring period. In any case, experts say, some degree of pollution is likely to be there forever.

Will citizens ask questions?

The question is whether the people who live next to the base will take part in the public comment process and let Army and Georgia EPD officials know what their needs and concerns are. Residents do not need to go through local government to take part in the process. While appointed and elected city officials in Forest Park have a major financial interest in transforming Gillem into a new revenue source for the city, they also have a duty to protect their citizens from harm, at least to the extent possible in a neighborhood that may never truly be non-toxic.

Conley has no city government and is in Clayton County; East Conley is in Dekalb County and has a large, active neighborhood association. Similarly, Ellenwood is unincorporated and stretches across Clayton, DeKalb, and Henry Counties. Since the COVID-19 pandemic began, Forest Park has seen its formerly active public participation in council meetings drop to zero or near-zero online since it declared City Hall closed to the public. These situations can make it hard for less-engaged citizens to figure out how to seek help from their local government.

Make your voice heard

If you want to tell the U.S. Army Corps of Engineers what you think about the proposed cleanup effort, you will need to write it down and send it as an e-mail no later than Friday, March 26 to:

Mr. Tom Lineer
Chief, Base Realignment and Closure Field Branch (DAIN-ISE)
U.S. Army
1508 Hood Avenue
Room A-103
Forest Park, GA 30297

Lineer’s e-mail address is thomas.a.lineer.civ@mail.mil and his phone number is (703) 545-2487.

To learn more about how Georgia EPD is involved in the effort, you can contact:

Ms. Kim Hembree
Georgia Department of Natural Resources
Environmental Protection Division
Hazardous Waste Management, Program Manager
2. Martin Luther King Jr. Drive SE
Suite 1054
Atlanta, GA 30334

Hembree’s e-mail is Kim.Hembree@dnr.ga.gov and her phone number is (404) 657-8604.

You also can follow the Fort Gillem Remediation Facebook page, which posted a link to the draft report on February 24 and mentioned the March 26 public comment deadline:

The Tulane Environmental Law Clinic‘s Guide to Environmental Protection in Louisiana offers sample outlines for written and verbal comments, as well as these tips for writing your letter:

  • Do not be intimidated about submitting public comments.
  • As a potentially affected neighbor, you are uniquely qualified to speak about your experience and concerns about industrial activities in your area.
  • The public comment period is an opportunity to create a record that you can use to challenge an unfavorable decision later on.
  • You must write your comments and submit them by the deadline.
  • It is always a bad idea to include rude language or to insult the agency that will be making the decision. Otherwise, there is no right or wrong way to write comments.
  • Your comments do not have to be perfect.
  • Your comment can be one page or many pages.
  • You can raise as many fact-based and legal questions as you like.
  • Your letter can include facts, opinions, questions, and supporting documents that will go into the record.

Do you live near Fort Gillem? Have you experienced any issues with contaminated water, air, or soil coming from Fort Gillem? We’d like to hear from you. E-mail KempWrites@gmail.com or call (404) 547-1171.

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