U.S. Department of Energy/U.S. General Services Administration - Bannister Federal Complex
EPA ID# MO9890010524
DNR Contact: Don Dicks, 573-751-3553 or 800-361-4827
EPA Contact: Robert Aston, Jr., 913-551-7392 or 800-223-0425
DOE Contact: Sybil Chandler, 816-488-3718
GSA Contact: Kevin Phillips, 816-823-1220
Last Updated: Oct. 1, 2015
- Former Company Name: Allied Corp, Bendix/KC Div.; Allied-Signal Corp.; Bendix Plant; Honeywell FM&T; US DOE KC Plant.
- Type of Facility: Permitted Hazardous Waste Storage and Disposal – closed.
- Wastes of Concern: Volatile organic compounds and polychlorinated biphenyls, or PCBs, and petroleum hydrocarbons.
- Historical Waste Management Methods: Interim status hazardous waste storage and land disposal.
- Location of hard copies of hazardous waste permit application, Part I and Part II Permits, modification requests, reports, etc. and supporting documents:
Permit Deliverables: The U.S. Department of Energy (DOE)/National Nuclear Security Administration (NNSA) and General Services Administration (GSA) submitted to the department and U.S. Environmental Protection Agency (EPA), several documents required to be submitted under their Missouri Hazardous Waste Management Facility Part I Permit, as modified Aug. 24, 2012.
- Revised Community Involvement Plan (CIP and Appendices): Approved with comments in April 2013. (Pursing updates due to contacts being out of date.)
- Description of Current Conditions Report (DCCR): Under review - The draft DCCR is available online on Honeywell's website.
- Updated Long-Term Operation, Maintenance and Monitoring (LTOM&M) Plan: Submitted October 2012, under review. Parts have been approved; applicable to the existing final remedy.
- Indian Creek/Blue River Fate & Transport Draft Report: Submitted July 2015, under review.
- Revised Sampling and Analysis Plan: Approved with conditions in March 2013. Still Current.
- Updated Spill Control/Emergency Plan: Submitted October 2012, under review. Discussing updates with Permittees, since both DOE/NNSA and GSA moved from the complex.
Several of these documents have been made broadly available to the public due to the level of interest regarding activities at the complex. These documents are available solely for informational purposes. The department and EPA are not actively soliciting public comments on these documents. Please be aware that the department and EPA are currently reviewing multiple documents. The agency review and approval process is in various stages for each of these documents and will take considerable time due to the size and scope of these documents.
The department recognizes that some of the electronic files posted on the various websites are quite large, which may result in long download times for individuals with dial-up connections. While we would prefer individuals obtain these documents online, if you have any problems accessing these documents and are interested in obtaining an electronic copy through other means, please contact Don Dicks at the Missouri Department of Natural Resources, Hazardous Waste Program, P.O. Box 176, Jefferson City, MO 65102-0176, by telephone at 573-751-3553 or 800-361-4827 or by email. Please be aware that standard copying charges will apply if a hard copy is requested.
The U.S. Department of Energy-Kansas City Plant is located on about 136 acres of the 300-acre Bannister Federal Complex, located at 2000 E. 95th St. in Kansas City, Missouri. The federal complex is approximately 13 miles south of downtown Kansas City, within the incorporated city limits. The federal complex is bordered on the north by Legacy Park, east by the Blue River and the Blue River Parkway, south by Indian Creek and Bannister Road and west by Troost Ave.
Before World War II, the area of the federal complex was mainly farm land. In 1942, the U.S. Navy built the main manufacturing building at the site. The Department of Defense also built a landfill on part of the property to be used as a disposal site for the federal complex. From 1943 to 1945, Pratt and Whitney Corp. built aircraft engines in the main manufacturing building for the U.S. Navy in support of World War II.
In 1948, the main manufacturing building was declared excess to defense requirements and turned over to the War Assets Administration. The War Assets Administration used the building for a short time as a warehouse and housing for several private and governmental operations. In 1948, the building was transferred to the Department of the Navy, which leased part of the building to Westinghouse Electric Co. From 1948 until their lease was cancelled in 1961, Westinghouse built jet engines at in the main manufacturing building for the U.S. Navy in support of the Korean Conflict.
In 1949, Westinghouse subleased part of the main manufacturing building to Bendix Corp. Bendix was contracted by the Atomic Energy Commission to manufacture electrical, mechanical, plastic and other non-nuclear components of nuclear weapons. From 1984 to 1999, Bendix merged with Allied Corp., who merged with Signal Corp. and became Allied Signal Inc., who bought Honeywell Federal Manufacturing & Technologies LLC.
In 1964, the landfill was closed and the property was transferred to the General Services Administration, or GSA. GSA manages government assets, including government-owned and leased buildings. GSA operated a warehouse in the western part of the building. The Atomic Energy Commission continued operating what is now known as the Kansas City Plant in their part of the building until the Commission was abolished in 1974. In 1975, the Energy Research and Development Administration was created and took custody and control of the Kansas City Plant in 1976. The U.S. Department of Energy, or DOE, was created in 1977 and the Kansas City Plant was included in the new department. DOE continued operating the Kansas City Plant and took ownership of their part of the building. In 2000, DOE created the National Nuclear Security Administration, or NNSA, in part, to strengthen national security and reduce the global threat from weapons of mass destruction.
The Bannister Federal Complex is currently owned by two agencies: DOE/NNSA and GSA. The Kansas City Plant is owned by DOE/NNSA and operated by Honeywell Federal Manufacturing & Technologies LLC. GSA owns the remaining portions of the federal complex. In 2013, DOE/NNSA and Honeywell FM&T moved to the new National Security Campus, located about eight miles south of the federal complex on Botts Road. In 2014, GSA moved to downtown Kansas City on Main St. The U.S. Marine Corps is currently the only tenant at the federal complex, with a long-term lease for the former Internal Revenue Service building on the east side of the federal complex, currently owned by GSA.
The Kansas City Plant previously employed about 2,600 staff at the federal complex and manufactured electrical, mechanical, plastic and other non-nuclear components of nuclear weapons. Acids, alkalines, solvents, acid and alkaline contaminated solid waste, solid debris waste, waste oil, wastewater treatment sludges and toxic metals were stored on site under generator storage requirements until they were either treated at the Kansas City Plant’s industrial wastewater pretreatment facility or shipped off-site to a permitted hazardous waste treatment, storage and disposal facility. The Kansas City Plant previously had six hazardous waste container storage areas and three contingent storage areas. The Kansas City Plant also used small amounts of radioactive materials in products and used conventional, sealed industrial radioactive sources for instrument calibration, radiography and laboratory equipment. These processes occasionally produced mixed waste, which was stored in one area on-site until shipped off site.
Post-Closure and Corrective Action Status
There are three closed hazardous waste management units located at the Kansas City Plant, two lagoons and an underground tank farm. DOE closed the north and south lagoons by removing the contaminated sediment, backfilling with uncontaminated soil and covering with a clay cap, topsoil and vegetation. The underground tank farm consisted of 28 tanks and associated underground piping and stored fuels, coolants and solvents. DOE closed the tank farm by removing all tanks, associated piping, concrete supports and fill to a depth of about 15 feet below ground surface. The area was then backfilled with uncontaminated soil and covered with a clay cap, topsoil and vegetation. The Missouri Department of Natural Resources accepted DOE’s closure report and certification for the hazardous waste management units; however, because of historical release of hazardous waste and hazardous constituents, these areas are required to go through a period of post-closure care. As part of the post-closure care, DOE/NNSA is required to monitor the groundwater and inspect and, if necessary, repair the clay caps.
According to applicable state and federal hazardous waste laws and regulations, all hazardous waste treatment, storage and disposal facilities are required to investigate and clean up releases of hazardous waste and hazardous constituents to the environment at their facility resulting from present and past hazardous waste handling practices. There are two known historical releases of polychlorinated biphenyls, or PCBs, both from Department 26, which produced plastic in the southeast corner of the main manufacturing building. PCBs were used in transformers, other electrical equipment, hydraulic oil, caulking compounds and elastic sealant. In 1969, an expansion joint failed and released approximately 1,500 gallons of PCB oil to a gravel area. About 900 gallons of the PCB oil entered the storm sewer system and was released to Indian Creek through the old 002 Outfall. Despite clean up efforts at the time of the spill, residual PCBs remained in the creek bottom sediments. Shortly after the spill, Indian Creek was rerouted and the PCB contaminated soils that could not be removed were left in place alongside and underneath the box culvert leading to Indian Creek. In 1971, about 1,100 gallons of PCBs were released to the ground outside Department 26, near a storm water drain. Some of the PCBs entered the storm sewer system and released to Indian Creek through the newly installed box culvert near the new 002 Outfall. This area of contamination, known as the 95th Terrace site, is located south of the main manufacturing building in the former Indian Creek channel. The 95th Terrace site is bordered to the south by Indian Creek and is partially located on property owned by the Missouri Department of Transportation.
In 1979, EPA banned PCBs; however, PCB replacement was not required in existing equipment. PCBs are common in cooling systems, transformers, capacitors, electrical equipment, oils, caulking compounds and elastic sealant. DOE replaced the PCB heat transfer piping and oil in 1986; however, materials made before the PCB ban, such as sealant, are still present at the Kansas City Plant and other locations in the federal complex.
Cleanup of the Kansas City Plant began in 1983, but most corrective action activity was initiated in 1989. On June 23, 1989, DOE voluntarily entered into a 3008(h) Corrective Action Administrative Order on Consent with EPA, Docket No. VII-89-H-0026. The order initially listed 35 solid waste management units as possible release sites, including the two closed lagoons and underground tank farm. The order directed the investigation and corrective action activities at the facility until 1999, during which time eight more solid waste management units were identified. Releases from the underground tank farm, a trichloroethylene reclamation facility, a plating building and other industrial practices resulted in soil contamination and groundwater contaminant plumes containing solvents and petroleum products.
On Oct. 6, 1999, the department and EPA issued two hazardous waste permits to DOE for the Kansas City Plant. The department issued a Missouri Hazardous Waste Management Facility Part I Permit and EPA issued a Hazardous and Solid Waste Amendments Part II Permit. These permits transferred the oversight responsibility and authority for the investigation and corrective action activities from EPA to the department. EPA terminated their Order on Dec. 30, 1999, and the corrective action process continued under the Part I Permit.
Many of the solid waste management units on the DOE/NNSA portion of the federal complex were grouped together for further investigation and cleanup, due to their close proximity to each other and the type of contamination. DOE/NNSA is currently performing post-closure, corrective action and long-term stewardship activities for the Kansas City Plant under Missouri’s EPA-authorized hazardous waste program, which is equivalent to the federal Resource Conservation and Recovery Act, or RCRA, with the department providing primary regulatory oversight. The DOE/NNSA parts of the federal complex are in the final remedy operating, maintenance and monitoring stage for all contaminated areas currently under their responsibility. The Kansas City Plant part of the federal complex is restricted to industrial use only and the groundwater cannot be used for any purpose, except investigation and remediation (i.e. no domestic or industrial use). Groundwater is currently treated by an ultraviolet light-hydrogen peroxide system. Groundwater is collected from interceptor wells, building footing tile drains and Outfall 002, treated and discharged to the local sewage treatment plant. As part of the approved final remedy for the 95th Terrace site, NNSA is required to inspect and maintain the box culvert under Bannister Road, the warning signs in the area of Outfall 002 and the protective cage over the concrete chute entering Indian Creek. DOE/NNSA is also required to sample surface water, sediment and fish tissue in Indian Creek and the Blue River for PCBs. These PCB samples were collected in 2005 and 2007 and 2013. The schedule for future sampling is currently being considered.
Until 2012, GSA was performing environmental investigation and cleanup activities on their portion of the federal complex under the Comprehensive Environmental Response, Compensation, and Liability Act, or CERCLA, with EPA providing regulatory oversight. Additional information about that cleanup effort is available on EPA's website. As of Aug. 24, 2012, the department and EPA changed DOE/NNSA's original permits to include the entire federal complex, including the property owned by GSA, under the permits and added GSA as a permittee. Additional information about the GSA-owned portion of the federal complex, including legacy environmental issues, is available on GSA's website.
The landfill, located on the GSA-owned portion of the federal complex, was closed in 1964. The U.S. Army Corps of Engineers is responsible for performing the environmental investigation and cleanup of the landfill under the Formerly Used Defenses Sites Program, with the department providing regulatory oversight. The presence of solvents has been confirmed in the groundwater in the area of the landfill. The U.S. Army Corps of Engineers is continuing their investigation. Additional information about this cleanup effort is available on the department’s Federal Facilities website.
Since DOE/NNSA and GSA relocated their operations, they selected CenterPoint Properties as a preferred partner to redevelop the area of the federal complex west of the railroad tracks. CenterPoint is currently performing various “due diligence” activities at the federal complex to independently evaluate the environmental conditions and support its future decisions regarding property reuse/redevelopment. CenterPoint and its consultants have prepared several “due diligence” sampling work plans. CenterPoint asked the department and EPA to review, comment and approve their work plans, even though CenterPoint is not currently subject to DOE/NNSA’s and GSA’s hazardous waste permits or Missouri State Operating Permit for outfall discharges. This way, the information obtained during the “due diligence” activities will be acceptable for future decision-making purposes related to property redevelopment and additional cleanup, if and when CenterPoint decides to become the owner/operator of the federal complex west of the railroad tracks. If CenterPoint acquires the property and pursues redevelopment, the current approved final remedy will likely be changed and additional cleanup actions will be taken to ensure protection of human health and the environment, given the intended redevelopment uses.
The Kansas City Plant operated the three hazardous waste management units (two lagoons and an underground tank farm) under the interim status portions of the federal and state hazardous waste laws, 40 CFR Part 265 and 10 CSR 25-7.265. When EPA implemented the federal hazardous waste laws under the Resource Conservation and Recovery Act, or RCRA, in 1980, all existing facilities that treated, stored or disposed of hazardous waste in a manner that would necessitate a hazardous waste permit were required to get such a permit. Because of the large number of existing facilities, these facilities were allowed to operate temporarily under “interim status” until they received their permit. DOE decided not to continue the hazardous waste permitting process for active hazardous waste management and to close the units. DOE/NNSA is subject to the permitting requirements of the Missouri Hazardous Waste Management Law and regulations and federal RCRA regulations for post-closure care because hazardous waste remained in place after closure of some units. DOE/NNSA is also subject to the corrective action requirements of the Missouri Hazardous Waste Management Law and regulations and federal Hazardous and Solid Waste Amendments to RCRA due to releases of hazardous waste and hazardous constituents to the environment from additional solid waste management units and areas of concern.
DOE/NNSA is conducting post-closure and corrective action activities at the Kansas City Plant under two hazardous waste permits, one issued by the department and one issued by EPA, both effective Oct. 6, 1999. The department issued the Missouri Hazardous Waste Management Facility Part I Permit. EPA issued the Hazardous and Solid Waste Amendments Part II Permit to cover regulatory requirements Missouri had either not yet adopted or adopted but not yet received EPA authorization. The Part I permit requires DOE/NNSA to perform post-closure care for the three closed hazardous waste management units: the North Lagoon, South Lagoon and Underground Tank Farm, as well as operate, maintain and monitor all corrective action final remedies on the DOE/NNSA part of the federal complex.
On Sept. 29, 2006, the department issued a Part I department-initiated permit modification to DOE/NNSA, requiring the facility to implement the approved final remedy for the 95th Terrace site. On Aug. 24, 2012, the department and EPA issued Part I and Part II Class 3 Permit Modifications to DOE/NNSA and GSA, to combine the separate portions of the federal complex and require DOE/NNSA and GSA to conduct further environmental investigation, monitoring, risk-assessment and, if necessary, additional cleanup at the federal complex under the modified permits. Up to that point, DOE/NNSA and GSA were performing environmental investigation and cleanup activities on their respective portions of the federal complex independently under separate environmental laws. The permits were modified to include the entire federal complex, including the property owned by GSA, under the permits and add GSA as a permittee.
DOE submitted a permit application on April 7, 2009, for renewal of their existing hazardous waste permits. The facility's existing hazardous waste permits expired Oct. 6, 2009; however, state and federal regulations, 40 CFR 270.51, allow the existing hazardous waste permits to continue in effect until the department and EPA issue or deny new hazardous waste permits. The department is currently reviewing the application for completeness.
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