"We have considered cleaning up the site for several years because of Lullwater's use as a nature preserve, recreation area, and home of the president, even though between 1990 and 1994 Emory faced no legal sanctions regarding the site," said Kris West, assistant university counsel, who has worked closely with the Office of Environmental Health and Safety on the legal issues regarding the site. "We were faced with a Dec. 31 deadline to submit a compliance status report with the Environmental Protection Division to provide the state with information about the site's conformance with regulations under the Hazardous Site Response Act, and that speeded up the administrative decision to go ahead with the clean up. Because of our plans for remediating the site, we requested an extension of that deadline," said West.
Frank Lisella, director of Environmental Health and Safety, said there is not yet an estimate on the cost of the clean up because the contracted work will be done in three phases. "First, the contractors will review historical data about the site, including topographical, geological and soil and water sampling tests that have been done previously," said Lisella. "Then, they will delineate the sampling they must do to both soil and water to determine the extent of the contamination. Then they will remove and dispose of the chemicals themselves and any contaminated soil." Nearby there is a low-level radioactive waste site that will be investigated and remediated if necessary.
"The work itself will be done almost like an archaeological dig," said Scott Thomaston, chemical safety officer. "They will remove thin layers of soil above the site, probably with a back hoe, until they get to the containers of chemicals. At that point, they have to do a field analysis of each item that they find, because there are different regulations for disposing of each substance. We hope that some of the containers will look like they came right off the shelf and will still have labels on them because of the anaerobic environment in the compacted clay."
The work on the site will be done between January and June 1996. "A small area in the field near the railroad tracks in Lullwater will be fenced off for safety reasons during the remediation process," said Lisella, "but Lullwater will remain open for regular use, and the jogging trail through that area will be open."
Emory administrators became aware of the site during a symposium on the environment in April 1990 when William D. Burbanck, a retired professor of biology, noted that discarded chemicals had been buried in a field in Lullwater in 1974 when the chemistry department was about to move from the Humanities Building into its present quarters. "As was the accepted disposal practice at that time, they dug a couple of trenches and buried the materials. We've heard that Emory students loaded the trucks and actually put the chemicals in the trenches" said Lisella. Although there is no inventory of exactly what was buried, it is assumed that solvents, miscellaneous organics and perhaps 30-50 pounds of mercury were put into the two trenches.
In 1990, Lisella notified the Georgia Department of Natural Resources (DNR) of the site. They were already aware of it and turned the matter over to the Environmental Protection Agency (EPA), which has legal authority over abandoned chemical waste disposal sites. EPA in turn asked their contractor, the NUS Corporation in Tucker, to conduct a site assessment and a risk assessment of the area. A geologist and environmental scientists from the NUS Corporation conducted the site inspection in June 1990 and completed their report to the EPA in September 1990.
In the meantime, Emory had contracted with Don Jacobs, a Decatur ecologist, who inspected the site during July and August 1990 and looked for "disappearance of species, invasion of new species, or expanded species populations, stunted or deformed individuals, reduced reproduction, or shifts in distribution of plant or animal species." He reported no evidence of toxicity, by any indicator, even among highly sensitive creatures such as Dusky Salamanders or the Gambusia affirus minnow that is often used as an indicator of water site quality. He stated the likelihood of toxicity from the site was near non-existent for reasons of terrain, environmental chemical reactions, and dilution.
In November 1990, Emory received a letter from the EPA that reported the assessment found no evidence of contamination or spread of any materials throughout the area or into the ground water. Consequently the EPA assigned a "No Further Remedial Action Planned" (NFRAP) designation to the site. However, the University Senate Committee on the Environment recommended that the Chemical Safety Office survey and monitor the Lullwater site, even though federal and legal requirements regarding this site had been satisfied. Soil and water testing conducted in 1992 showed no contamination on the site.
In 1993, the Hazardous Site Response Act was enacted by the State of Georgia. This act required notification to the Georgia Environmental Protection Division (EPD) of sites that are contaminated with hazardous materials. In May of 1994, Emory filed a Release Notification/ Reporting Form, which placed the Lullwater site on the Hazardous Site Inventory.
It is hoped Emory's clean-up of the site will cause the state to remove it from the list of hazardous sites sometime in 1996.
--Jan Gleason