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Toxic Pollution

Harpeth Conservancy has long been active in efforts to reduce toxic pollution in our waterways. We spearheaded efforts to make sure that Liberty Creek, a tributary of the Harpeth were actively cleaned up.

Background on Liberty Creek and ELMCO

In January 2007, the TN Department of Environment and Conservation (TDEC) confirmed that leaking pipes at Egyptian Lacquer Manufacturing Company (ELMCO) on Eddy Lane, located next to Fort Granger, had contaminated the groundwater, Liberty Creek, and the Harpeth River in downtown Franklin, TN with hazardous chemicals.  Even with some clean-up efforts early on, hazardous chemicals in the groundwater flowed into nearby Liberty Creek in the vicinity behind Battle Ground Academy (BGA) lower school for the ensuing years.  Orange bacteria growth that feeds off the chemicals and active seeps with hazardous chemicals were confirmed in Liberty Creek. 

Bacteria growing off chemicals in Liberty Creek
Chemicals in seeps at Liberty Creek

Harpeth Conservancy has been very involved in identifying the seeps where the hazardous chemicals entered directly into the Harpeth River and funded expert reviews of the proposed clean-up plans.  Harpeth Conservancy expert review highlighted that the second proposed clean up plan:

  1. Allowed for hazardous and carcinogenic chemicals to flow indefinitely into Liberty Creek and the Harpeth daily at levels hundreds of times greater than the EPA’s Maximum Contaminant Levels and did not address the ongoing direct contamination of the Harpeth.  
  2. Did not propose to treat and remove the contamination in the groundwater under public and private property off of the ELMCO property. 
  3. Did not define where the contamination occurred off the ELMCO property, which was required by TDEC before it created a clean up plan. 

Among other efforts, the TN Department of Environment and Conservation (TDEC) held a public information session to gather input on the proposed final Corrective Action Plan by Egyptian Lacquer Manufacturing Company.  The proposal was to let nature takes it course to deal with hazardous chemicals that still contaminate the groundwater on their property years later and that are moving under people’s homes and into Liberty Creek where children can easily play.

Harpeth Conservancy has funded an expert review of the proposed Plan and collected recent field data which has been provided to TDEC.

Key Points of the Expert Review

  • The Corrective Action Plan did not comply with EPA hazardous clean-up requirements such as remediating the contamination that may have migrated away for the original source area and setting clean-up target levels to protect public health and the environment.
  • Lab results from HC's sampling at the main seeps of groundwater into Liberty Creek demonstrated that concentrations of the main hazardous chemical, toluene, remain at high levels that have been consistently found since the beginning. These are well above EPA risk limits to protect public health and the environment.
  • The human and ecological risk assessments in the Plan were not based on updated EPA risk standards. Concentrations levels in Liberty Creek were above these risk standards.
  • Hazardous warning signage and fencing was needed to limit access to Liberty Creek and warn people, especially children, to stay away from the contaminated areas.

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