by Robin Kemp

10:48 a.m.: ADDS institutional controls vs. engineering control definitions

10:35 a.m.: ADDS link to Superfund Community Involvement Handbook, lede graf summarizing story contents

10:18 a.m.: CLARIFIES “remedial action outcome” definition; ADDS 2014 EPA testing/mitigation/cleanup order to Army

2:11 a.m. March 24: Adds video interview

The U.S. Army Corps of Engineers is giving the public until this Friday, March 26 to submit comments on a plan it has to clean up a toxic dump on the north side of Fort Gillem. The final draft of the proposed plan was written by the Knoxville, TN offices of Aptim Federal Services, LLC, a federal contracting company based in Baton Rouge, LA that specializes in decommissioning military bases and nuclear plants, among other things. This story presents basic questions and answers about the contamination, a timeline of events surrounding the FTG-01 site, an interview with an expert who says he may have an alternative cleanup plan not mentioned in the Army’s proposal, and links to important documents about Fort Gillem’s sale and cleanup effort.

What’s down there?

From 1941 to 1980, the Army used the FTG-01 site to get rid of all kinds of toxic materials. According to the draft plan, the Army either buried, or burned and then buried:

  • gas masks
  • medical training supplies
  • petroleum, oils, and lubricants
  • food products
  • rubber
  • miscellaneous chemicals
  • sewage sludge

“After 1980,” the report continues, “sanitary and industrial waste, miscellaneous trash and debris, and construction rubble were not disposed of on Fort Gillem property. Petroleum, oil, and lubricant wastes were collected and disposed through the Defense Logistics Agency, Property Disposal Office.”

Some “miscellaneous chemicals” reported to have been disposed of on base include degreasing agents, X-ray developing chemicals, and pesticides.

The yellow outlines show areas affected by VOCs leaking from Fort Gillem, according to the Army’s cleanup proposal.

Testing since the 1980s has confirmed the presence of numerous known and suspected cancer-causing chemicals and heavy metals (like lead) on the base and surrounding areas. These include TCE (trichloroethane) and cis-1,2-DCE (cis-1,2-dicholoroethene), which “have migrated off post to the north and northwest of FTG-01,” according to the Army, with other VOCs “generally” staying in the groundwater plumes.

Other contaminants detected in four Fort Gillem-related groundwater plumes include trans-1,2 DCE, vinyl chloride, tetrachloride, chloroform, SVOCs, pesticides like dieldrin, and metals like lead and zinc.

The contamination is in the groundwater (underground pockets where water is naturally stored), surface water (like nearby creeks), soil, air, “partially weathered rock, and bedrock zones,” both on and off Fort Gillem.

What the Army is proposing in its 36-page plan is to inject “amendments, including emulsified vegetable oil, a dechlorinating microbial culture, buffer, and microbial nutrients into the aquifer to enhance the biodegradation of VOCs in groundwater.”

According to the proposal, “The amendments will be injected by direct-push technology to create a series of biobarriers and injection grid perpendicular to the direction of groundwater flow “

In plain English

Direct-push technology is used for water sampling and involves drilling into rock or sediment. Industries use it because it minimizes the amount of hazardous waste they would have to clean up by using other methods.

A diagram of what the Army might use to inject microbes into the groundwater at Fort Gillem’s FTG-01 dump site on the north side of the base.

“Direct-push technologies involve the pushing or vibrating of a drive point (bit), screen, and drill rod into sediment or soft rock,” writes Robert G. Maliva, an expert in drilling who works for Schlumberger Ltd. “In DPT, the drill bit, screen, and rod are usually driven using a hydraulic ram supplemented with vehicle weight or high-frequency percussion hammers. In shallow unconsolidated strata, the assembly may be advanced manually using a slide hammer, sledge-hammer, or hammer drill.”

Once the point has been drilled down to the source–in this case, the contaminated aquifer that spreads from the north side of the of Fort Gillem into the neighborhood–the casing on the device is drawn back to expose a screen for water to flow through. One of the problems with the direct-push method, Maliva explains, is that the screen can get clogged up.

Then, the Army proposes to shoot the microbial mixture into the aquifer, where it will eat contaminants called VOCs (volatile organic chemicals) and leave behind what the Army describes as “innocuous end products.”

What happens after injection?

According to the proposed plan, the Army (or its contractor) would monitor the injection sites and see how well it’s going after two years. They also will collect data for five years (an EPA requirement) “to track post-treatment natural attenuation of VOCs in groundwater.” The Army would “restrict” groundwater use for “on-post property.” It also would monitor groundwater both on base and in the surrounding areas until “RAOs (remedial action outcomes) are achieved.”

The report defines RAOs as “medium-specific goals for protecting human health and the environment” that “provide the basis for the identification, detailed analysis, and selection of remedial alternatives.” In other words, they are not final goals.

“Because chemicals remain at the site above concentrations that allow for unlimited use and unrestricted exposure,” the proposal reads, “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 notes that some sites never get to that point, so “institutional controls” (policies and legal documents) and “engineering controls” (things like direct-push machinery) are put in place.

“Institutional controls,” the EPA explains, are “administrative and legal controls that help minimize the potential for human exposure to contamination and/or protect the integrity of the remedy.” Whether such controls are as simple as putting up a sign or a fence or ordering people on base not to use groundwater is unclear.

The Army adds that its cleanup plan “can change in response to public comments or new information”–making the public responsible for researching whether this method is safe and whether other methods might work better.

Are there alternatives?

Dr. Valentine Nzengung, professor of environmental geochemistry at the University of Georgia and CEO of MuniRem Environmental, LLC

Yes, alternative cleanup methods exist–and they could be safer, more effective and less expensive than the Army’s proposal, according to University of Georgia environmental geochemistry professor Dr. Valentine Nzengung, who also is an expert on chemical neutralization of explosives. Although he says he is not familiar with the site conditions–and he wants to see site data that was not included in the Army’s cleanup proposal–he is familiar with the proposed microbial injection method.

Nzengung is also CEO of MuniRem (short for “Munitions Remediation”) Environmental, LLC, a company that specializes in chemical remediation. In 2018, MuniRem won the Atlanta Metro Export Challenge. MuniRem “provides a mature and award-winning technology that utilizes reduction chemistry to instantly neutralize and degrade explosives and chemical warfare agents. MuniRem Reagents are used for decontamination, demilitarization and remediation projects at military sites and private industry sites.”

The Army says the microbes it wants to inject into FTG-01 will break down existing chemicals on site into “innocuous end products.” But one study of a similar microbial injection cleanup listed on PubMed’s 1,1,2-Trichloroethane page found the microbes produced vinyl chloride (also known as chloroethene), which the National Cancer Institute says is “associated with an increased risk of a rare form of liver cancer (hepatic angiosarcoma), as well as brain and lung cancers, lymphoma, and leukemia.” Issues with vinyl chloride are well-known in Southeast Louisiana’s “Cancer Alley”–the area along the Mississippi River between Baton Rouge and New Orleans, where entire towns suffering from cancer–like the historically African-American village of Reveilletown–have been bought up by the chemical companies who polluted them, then wiped off the map.

Nzengung told The Clayton Crescent that, by substituting persulfate and dithionite instead of the microbial mix, and injecting them the same way across the groundwater current, chemical results are “more rapid” and “more aggressive” than microbial results.

“Fort Gillem is a location that is needed for a lot of activities, and there are residential areas around it,” he said. “If we had vinyl chloride form, it would not be a good thing, because it would easily get into basements, it’s a volatile organic compound, so in residential areas or in areas that are close to residential areas, I would go with something that is not likely to form vinyl chloride.”

Complicating matters, Nzengung explained, is the fact that “you have a situation where you have metals and organics. So you have two problems there, well, two groups of contaminants to address. Also, I would like to think that, given the location, you will want to go aggressively. So, you know, bioremediation works, but the chances of failure are high in some cases. I haven’t looked at the geochemistry of the site. I don’t know if reducing conditions already exist or they don’t, but just looking at Fort Gillem and knowing what I know, I would go with a chemical process that can handle both organics and metals.”

Depending on how much oxygen is in the groundwater, he said, “you want to take advantage of those conditions in the remediation process. Trichloroethylene can undergo degradation under aerobic and anaerobic–absence of oxygen–conditions.”

It also depends on how many other bacteria are naturally present on the site. “I know they want to use biodegradation, but with biodegradation, things can go wrong. And they can go wrong when the bacteria fail to establish themselves…over the long term. Because this is not going to happen in five years. So, over that duration of time, those microorganisms, those bacteria get out-competed by indigenous bacteria, they’ve got a problem.”

One of those problems, he said, can be vinyl chloride.

Watch the full interview:

Where is the data?

Nzengung asked whether The Clayton Crescent had seen the data on which the proposal was based and questioned why it was not included in the proposal. We sent an e-mail to Thomas Lineer (the person taking public comments on the Fort Gillem FTG-01 proposed cleanup) on Tuesday, March 23 asking for that data and will report back when we hear something.

What’s an RAO?

RAO stands for “remedial action outcome,” according to the Army’s proposal. Basically, that’s government-speak for “goal.” In this case, the goal is to get the contamination down to levels set by law. Just because the law says a certain amount of pollution is “acceptable” for certain goals does not mean that amount of pollution is safe for humans (or plants, or animals).

Each cleanup goal depends on three things:

  • the medium that is contaminated (in this case, groundwater)
  • how the contamination travels (ingested, breathed, or touched) and where it ends up (for example, someone who lives nearby washing her hands or a construction worker breathing gases and dust while digging)
  • how concentrated the “chemicals of concern,” or COCs, are in the medium (again, for this proposed cleanup, how much of the chemicals are in the groundwater)

The Army has two goals with its FTC-01 cleanup plan:

  • Keep the levels of chemicals at legally-acceptable levels for people to ingest, breathe, or drink–Type 1 for residents, Type 3 for construction and industrial workers on Fort Gillem
  • Keep the groundwater from leaking out

Based on existing data from the site and “field-demonstrated biodegradation rates” (how quickly these chemicals have broken down in past studies), the Army predicts it will reach its goals “in approximately 15 years.”

In other words, the Army thinks it will be at least 2036 before it can get the contamination down to the highest acceptable current legal limits.

A sign at a creek just north of Fort Gillem warns people not to drink or come in contact with the water and to call the U.S. Army Corps of Engineers with any questions. Studies by the Army and others show VOCs and heavy metals have been spreading into the neighborhoods just nporth and south of the base for decades.

Meanwhile, the Army will restrict groundwater use “through deed covenants and groundwater monitoring” on land it controls–such as the Gillem Enclave and the land on which the Park at Fort Gillem Apartments sit. The Army proposes “public education outreach, ” as well as groundwater monitoring and “periodic well surveys” to make sure no one is using the groundwater.

How much exposure is too much?

The Army says it used several hypothetical scenarios to figure out how dangerous the chemicals coming from FTG-01 are to people, both on and off the base. Here’s how.

The U.S. Environmental Protection Agency (EPA) has a list of chemicals and how much people can be exposed to before they face health risks. The EPA uses a scale called a Basic Human Health Risk Assessment (BHHRA), which looks at:

  • What chemicals are present, where, and how concentrated they are (“data evaluation”)
  • Who could be exposed to the chemicals and how, now and in the future (“exposure assessment”)
  • Which chemicals on site could make you sick and how much exposure might cause that sickness (“toxicity assessment”)
  • Whether or not the math adds up to a cancer risk (“risk characterization”)

In 2020, the Army says, a BHHRA study looked at hypothetical exposures for a construction worker on base, a commercial worker on base, and recreational users (adult, youth, and child) off base. In all cases, the groundwater contamination, both on and off base, exceeded EPA limits.

The Army said groundwater contamination exposure results were “inconclusive” off the base “because all residents within or near the plume are on municipal [county] water.” However, that does not take into account the fact that toxic gases rise up from the groundwater, through the soil, and into the air, concentrating inside some buildings.

That’s why, in 2014, the EPA ordered the Army to test areas outside the base, check springs and private wells off base, connect people to county water, hand over all data to the EPA, mitigate bad indoor air, submit plans for fixing the problems–and involve the community according to the Superfund Community Involvement Handbook‘s April 2005 edition.

The Army put in a sub-slab depressurization system there in 2014. At the time, tests found TCE concentrations ten times higher than what was in the air outside. In 2015, the Georgia Department of Public Health investigated air sampling at the Pride and Joy Daycare on the south side of the base,

The Army’s proposal also notes that concentrations of VOCs in wells off the base “exceed EPA standards” and that “the cumulative cancer risk for off-post residential receptors” exceed both EPA risk management and Hazard Index (HI) limits.

In the case of the hypothetical construction worker on base, the risk of cancer “does exceed the threshold level, based upon two TCE concentration in subsurface soil.”

Again, the Army found that result inconclusive because “the exposure pathway for the construction worker was incomplete based upon sample depth, low frequency of screening criteria exceedance, and the addition of amendments to treat residual contamination.”

That description resembles non-hypothetical accounts, included in the proposal, of how workers removed tons of soil from FTG-01 between 1998 and 2019:

TIMELINE

  • 1998: MOU 800 Drum Removal: for about 6 weeks from February to mid-March, searchers found, identified, and collected 61 “drums and containers lying on the surface.” These were “sampled and characterized,” then “disposed of according to applicable local, state, and federal regulations.”
  • 2000: MOU 600 Lead-Contaminated Soil Removal: From August until “early 2001,” crews first began cleaning up “isolated surface soil areas contaminated with lead,” then found “VOC-contaminated soil” and started cleaning that up, too. Then, in mid-November, “(a) burn pit was discovered…at the southern end of the MOU 600 site” outside the boundary of the operation. Field crews found a layer of ash about a foot deep “that contained elevated levels of lead ranging from approximately 10,000 to 25,000 milligrams per kilogram (mg/kg) as measured by x-ray fluorescence.” They started removing the ash, going north, going deeper and deeper, 75 feet wide and 6 feet deep–until December 22. That’s when the Army Corps of Engineers issued a stop-work order: “The excavation appeared to have uncovered an elongated burn pit” with ash “1 foot thick near the surface of the cross section and nearly 3 feet thick at the deeper point.” Crews backfilled the pit “with soil and brush from the initial clearing and grubbing effort.”
  • 2009: Operable Unit A: In March and April, crews removed soil from around two monitoring wells in hopes of limiting the amount of VOCs getting into the groundwater. In March, they’d planned to dig six 4′ x 26′ trenches, eight feet deep, but two of the trenches hit bedrock about 2.5′ to 5.5′ down. “Soils were screened during the excavation with a photoionization detector,” according to the proposal. “There were no detections of VOCs.” In April, they removed and disposed of about 1,136 cubic yards of soil after samples showed “an anomaly.” Crews dug down about 7 feet deep to get more samples. Results “indicated low-level VOC contamination” at the bottom of the hole. The Army poured “an estimated 2,640 pounds of potassium permanganate, which is used in water treatment and organic chemical remediation, into the excavation pits “and covered with clean fill to address residual VOC contamination,” then graded the site “to match the surrounding land surface.”
  • 2009: Operable Unit B: In March, crews removed about 712 cubic yards of “contaminated soil and debris” from a 43’x65′ and two 15’x15′ areas. They uncovered “a large mass of rock” in the larger area “that reduced the volume of excavated material by approximately 30 percent.” The dit and debris “were direct loaded onto off-road dump trucks, hauled to. a designated staging area near the MW-57 area, and stockpiled.” Again, crews took soil samples, added potassium permanganate (2,790 pounds in the big hole; 330 pounds in each of the two small holes), filled the holes, and graded them.
  • 2009: Operable Unit H: In March and April, Shaw excavated about “744 cubic yards of VOC-contaminated soil and debris from OU-H,” including cardboard, IV tubes, needles, flow regulators, “and rusted 5-gallon drum carcasses. Some of the drums had the affixed label ‘TRICHLOROETHYLENE TECH.'” Crews hit bedrock about 5 to 10.5 feet down. Again, they put potassium permanganate in the bottom of the hole (“about 3,969 pounds”), then “backfilled with clean fill material to address residual VOC contamination.”
  • 2009: FTG-01 Groundwater Extraction and Treatment System: In the spring and summer, 20 groundwater extraction wells were put in “on the northern and western boundaries of FTG-01.” The system, which forced air through groundwater to blow out the VOCs in a process called “air stripping,” then sent the water through carbon filters and back into the site, ran from November 2009 to September 2017. It took out “approximately 991 pounds of contaminant mass.”
  • 2010: Operable Unit 1: HGL dug out 1,134 cubic yards of soil from eleven grids from 7 to 12 feet deep. They uncovered “a white powdery material,” XXCC3 impregnate, which was used in uniforms to keep “chemical warfare agents from penetrating clothing.” The white powder also contained carbon tetrachloride and chloroform and spread beyond the excavation site; futher tests found “the white powder was nonhazardous, so the soil and debris from the site was “disposed as nonhazardous.” This time, potassium permanganate was not added to the hole “due to the potential oxidant demand associated with zinc oxide” in the XXCC3. Soil sample tests found “concentrations of carbon tetrachloride, trichloroethene (TCE), tetrachloroethene (PCE), and other VOCs above cleanup criteria.” The crew marked the edges of the 150’x130′ hole “with 10-mil plastic liners…for possible future excavations.”
  • 2012: MU 4C and Additional OU-H IRAs: In August, North Wind dug up 25.1 cubic yards soil from MU 4C and OU-H. None of the samples “indicated hazardous characteristics” but all the soil “was disposed off site, either by incineration (for suspect glass vials) or by transport to a Subtitle D landfill for nonhazardous disposal.” North Wind filled the holes “with clean soil transported from an off-site source.”
  • 2014: The EPA ordered the Army to clean up the site. Read the letter for a detailed list of areas that were investigated.
  • 2016-2019: Time-Critical Removal Action (TCRA): From April 2016 to June 2019, APITM surveyed, sampled, excavated, resampled, and disposed of 103,963 tons of soil and debris offsite “as nonhazardous waste,” although the actions “addressed…VOCs, SVOCs and metals.” The areas dug out were all inside the FTG-01 dump site, including MOU 600 Burn Pit, MOU 600 East, MOU 600 North, MOU 600 West, MU 1A, MU 1E/MU 1F, MU 1H, MU 1I MU 4C, MU 8A, OU-H, OU-I, Sample Area 2, Trench 12, and Trench 40 Area.
A map of vapor intrusion sampling in Winter 2015. The yellow rings, from a study a decade earlier, show roughly where toxic chemicals from FTG-01 had contaminated the groundwater.

According to the proposed plan, the Army says these are the acceptable legal limits for chemicals in the groundwater on and off base. However, the report does not specify whether these levels are set by the EPA or the Georgia DNR–and both entities say their figures are subject to change.

The only difference between levels of permissible exposure for these hypothetical people living outside the base and hypothetical people working on base is tetrachloroethane (TeCA), a solvent that causes cancer. The workers on base are allowed to be exposed to more than four times more TeCA as nearby residents are.

The EPA says several of these chemicals may cause cancer in humans–and NIOSH notes that lab studies have shown they did cause cancer in various lab animals. Detailed information about information about each chemical can be found at PubChem, an online reference guide from the National Library of Medicine’s National Center for Biotechnology Information. You can go to https://pubchem.ncbi.nlm.nih.gov/ and type a chemical in the box to look it up.

Exposure Levels for Hypothetical Neighbors Outside Fort Gillem

Exposure Levels for On-Base Hypothetical Commercial/Industrial Workers

Which chemicals is the Army focusing on cleaning up?

According to the proposal , the cleanup plan “is necessary to address VOCs in groundwater, primarily TCE and cis-1,2-DCE, to protect human health and the environment.”

TCE, according to the National Institute for Occupational Safety and Health, “is a colorless liquid with a chloroform-like odor. Trichloroethylene may cause irritation to the eyes and skin. Exposure to high concentrations can cause dizziness, headaches, sleepiness, confusion, nausea, unconsciousness, liver damage, and even death. Trichloroethylene is a known carcinogen. Workers may be harmed from exposure to trichloroethylene. The level of exposure depends upon the dose, duration, and work being done.”

NIOSH says that cis-1,2-DCE is a “clear, colorless liquid with an ether-like odor” that is “denser than water and insoluble in water.” It irritates the eyes, lungs, and skin, and can paralyze breathing in strong enough concentrations. Lab studies show it can damage human DNA but it is not classified as a carcinogen.

While Fort Gillem is not listed as a Superfund site, it is rated as a 4 on the EPA’s Hazardous Ranking Score Ongoing Site List and has been since August 21, 2012.

Who do I contact with questions or comments?

You have until this Friday, March 26, 2021 to submit written comments specifically about the FTG-01 cleanup plan.The comment period is specifically for you to tell the Army what you think about its cleanup plan, whether you would like to see them use a different approach, and whether you want the Army t hold a public meeting for citizens. E-mail them to Tom Lineer, Chief, Base Realignment and Closure Field Branch (DAIN-ISE), U.S. Army, 1508 Hood Avenue, Room A-103, Forest Park, GA 30297 at thomas.a.lineer.civ@mail.mil. Postal mail must arrive no later than Friday, March 26. Learn more about the proposed plan here.

You can ask Georgia DNR for more information about the site and the proposed cleanup plan. 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.

If you live in the neighborhoods north of Fort Gillem’s border and have questions or concerns about the creeks, call the U.S. Army Corps of Engineers at (855) 912-5130. The Corps has posted at least one sign at a creek just north of the base that reads, “SURFACE WATER POTENTIALLY UNSAFE! To avoid risks…drinking, wading, swimming, or other contact is not recommended.”

Find more information

Read historical minutes (previously available on the City of Forest Park’s old website), which recorded events during the legal preparations and sale of Fort Gillem to Forest Park’s various appointed boards, from the Forest Park/Fort Gillem LRA (2009-2019), Forest Park/Fort Gillem ILRA (2011-2014), Development Authority (May 8, 2014-January 24, 2019), and Urban Redevelopment Authority (April 6, 2014-December 20, 2018), project information, master plan, and URA (December 2017-December 2020) and DA members (December 2017-August 2022). These minutes were captured and stored by the Internet Archive’s Wayback Machine.

Find out from the EPA what the federal legal limits are for various substances in drinking water.

Find out from the Environmental Working Group how VOCs in drinking water can affect your health.

Learn from the American Lung Association how to cut down on VOCs that pollute your air.

You can read government documents related to Fort Gillem at tiny.cc/GillemFOIA, then clicking on each request number to see what records the EPA made public.

Watch a 2014 story from Fox 5 Atlanta on Fort Gillem contamination on the south side of the base:

If you live near Fort Gillem and anyone (human or animal) in your household has developed health issues that you think come from FTG-01 groundwater contamination, please email us your name, address, and tell us what happened. We’ll look into it.

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