In January 2008, Atmos Energy Corporation (Atmos) entered into a Settlement Agreement with EPA Region 4 to conduct a time-critical removal action at the location of a former manufactured gas plant (MGP). The MGP operated from 1889 to the mid 1930s, and was owned and operated by predecessor companies to Atmos. The Site is located at the corner of 3rd and Elm Streets in Owensboro, Kentucky, specifically the vacant lot west of the gymnasium of the former Goodloe Elementary School. Atmos acquired the Site from the Fourth Street Baptist Church of Owensboro in March 2008, in order to conduct the removal action.
In December of 2006, the Kentucky Department for Environmental Protection (KDEP) referred the Goodloe Elementary School Site to the EPA Region 4 Emergency Response and Removal Branch (ERRB). A Remedial Site Investigation (SI) was previously conducted by EPA and KDEP in 1984 and disclosed the presence of polynuclear aromatic hydrocarbon (PAHs) in surface soils at the Site. At the time, the Owensboro School Board installed a fence around the west lot to restrict access. The 1984 SI concluded that although PAH contamination existed within the west lot, there was insufficient evidence of a health hazard to require restriction of the west lot.
Due to the lowering of PAH action levels by health professionals since the 1984 SI, EPA and KDEP performed a limited site assessment in September 2006. Nine surface soil samples covering approximately two acres were collected and analyzed during the 2006 site assessment. Of the nine soil samples, one soil sample contained benzo(a)pyrene (BaP) at a concentration of 19 parts per million (ppm). The site assessment also found indications that the fence around the west lot was being breached by neighborhood children in order to access the area for use as a play area.
EPA determined that a time-critical removal action was required to eliminate possible contact with surface soils containing BaP) at a concentration in excess of EPA’s removal action level of 6.2 ppm.
In January of 2007, Atmos Energy agreed to cap the affected soil and to develop a "Removal Action Work Plan" (RAWP), which EPA and KDEP approved in November 2007. This RAWP was incorporated into the January 2008 Settlement Agreement. In February of 2008, Linebach Funkhouser, Inc. (LFI), environmental consultant for Atmos, conducted additional assessment work in accordance with the approved RAWP. The purpose of the work was to develop a final site cover design necessary to satisfy City of Owensboro stormwater runoff requirements as well as KDEP’s more stringent screening levels for BaP. Based on the results of that 2008 assessment, an engineered cap encompassing the entire Site property was developed by LFI and approved by EPA and KDEP. The design was included in LFI’s March 2008 "Confirmation of Engineered Control Coverage Area Report".
The removal action was conducted over the dates of May 19, 2008 through July 18, 2008. A project completion site reconnaissance was conducted with EPA and KDEP officials on August 6, 2008. During this meeting, the EPA On-Scene Coordinator (OSC) determined that the removal action was completed in accordance with the approved RAWP.
In accordance with the approved RAWP, Atmos assumes responsibility to implement and maintain post-removal site controls. KDEP has agreed to monitor Atmos's compliance with post-removal site controls. Details are as provided in the "Removal Action Completion Report" prepared by LFI, and which may be referenced under the Documents tab of this website (www.epaosc.net/goodloeschool).
On Sept. 9, 2009, Atmos filed an Environmental Covenant with the Daviess County Clerk of Court restricting the use of soil and groundwater beneath the Site. The environmental covenant will limit the Site to non-residential use and use of groundwater beneath the site for any purpose will be prohibited. A copy of the Covenant is may be found under the Documents tab of this website.
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