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Manufactured Gas Plant Remediation, Closure and Cost Recovery


A Kirksville, Missouri manufactured gas plant (MGP) was privately operated in the first half of the 20th century. As part of facilities expansion, the MGP site was acquired by A.T. Still University of Health Sciences (ATSU). However, property redevelopment was hindered by a poorly executed remediation conducted by the former MGP site owner, which failed to remove the bulk of the MGP wastes that impacted university property. Foth was retained to remediate the site on an expedited basis and to provide litigation support.

ATSU faced several key challenges:

  • The site was located in the parking lot of this major teaching hospital and in downtown Kirksville.
  • An upcoming MGP waste land ban was driving ATSU to implement remedial actions as soon as possible.
  • Groundwater impacts above drinking water criteria and DNAPL were known to exist on-site.
  • Later, residual soil impacts needed to be addressed to allow construction of a new university building.


To meet the land-ban deadline, Foth completed necessary work in just 16 days, saving an estimated $430,000 in hazardous waste disposal fees. Within that 16 day interval, Missouri Brownfields Voluntary Cleanup Program (B/VCP) enrollment was started and completed; all work plans were prepared, reviewed, and approved by the Missouri Department of Natural Resources (MDNR); and 2,112 tons of hazardous waste and 308 tons of non-hazardous waste were properly excavated, manifested, transported, and disposed at a permitted hazardous waste landfill.

To avoid possible public exposure issues Foth coordinated remedial actions with the City of Kirksville Fire Department and arranged with local fire department officials to provide foam suppression of vapor emissions if certain chemical levels were detected. Possible vapor exposure issues were managed by establishing baseline air monitoring data prior to excavation and taking daily composite samples from continuous air monitoring stations during excavation. This sampling also established that detected benzene levels in outdoor air were not related to the MGP excavation.


Our team demonstrated that groundwater impacts above drinking water standards and residual DNAPL were stable, did not extend off-site, and therefore posed no risk to human health or the environment. This enabled our client to obtain a Letter of Completion from the MDNR for the site by entering a land use restriction into the property deed. The technical support of subsequent legal action provided by Foth resulted in a substantial cost recovery by the University from the former MGP-site owner, which covered the vast majority of the remediation cost.

ATSU contacted Foth to negotiate amendments to the land use restrictions for purposes of constructing the building for ATSU’s Missouri School of Dentistry and Oral Health. After reenrolling the Site in the B/VCP, Foth delineated the extent of shallow soil impact leading to the excavation and off-site disposal of soil impacted above unrestricted use levels. Remediation was conducted concurrent with building design and construction allowing for an on-time opening of ATSU’s new dental school facility. The B/VCP issued a Letter of Completion for the Site redevelopment.

Foth continues to support ATSU with full environmental compliance audits, assisting the university in proactively identifying and addressing compliance issues before they become a problem. Foth has also led the drive to revitalize the university’s hazardous waste management program.



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