Bannister Federal Complex
Last updated Oct. 16, 2017
The U.S. Department of Energy, National Nuclear Security Administration's (DOE/NNSA's) predecessor began operations at the Kansas City Plant (KCP) in 1949. Prior to 1949, the Department of Defense used the plant as an airplane engine production facility. On-site releases of hazardous materials have resulted in contaminated soil and groundwater. Releases from an underground tank farm, a trichloroethylene reclamation facility, a plating building and various industrial practices performed throughout the site have resulted in large soil and groundwater plumes containing contaminates; including solvents, polychlorinated biphenyls (PCBs) and petroleum products. Although DOE/NNSA has moved, their cleanup responsibilities at the former KCP still remain. Missouri Hazardous Waste Management Facility Part I Permit for KCP was expanded October 2009 to cover the entire Bannister Federal Complex (BFC).
Bannister Federal Complex Public Meeting and Public Hearing
HWP's Permits Section hosted a public meeting and public hearing on Wednesday, May 17, 2017, to discuss a draft hazardous waste permit modification for BFC, which included a proposed final remedy. DOE/NNSA was present to discuss the FOSET for the early transfer of the property to a private owner. The public meeting, followed by the public hearing, was at Center High School, located at 8715 Holmes Road, Kansas City. At the hearing, public comments about the proposed remedy and permit modifications were entered into the official record. Questions voiced at the hearing will be responded to in writing, along with any written comments submitted during the public comment period.
Comments on the FOSET can be made until June 19, 2017, at the link below:
Comments on the permit can be made until June 19, 2017, at the link below:
- MoDNR U.S. Department of Energy/U.S. General Services Administration - Bannister Federal Complex Webpage
Early Transfer Process at the Bannister Federal Complex
The DOE/NNSA has moved out of the KCP portion of the BFC to the National Security Campus (NSC) at Highway 150 and Botts Road, in Kansas City. GSA has moved from its portion of the BFC to an office near Union Station in downtown Kansas City. The BFC is bisected by an active railroad; the Marine Corps has leased the building east of the railroad tracks from the GSA, the property east of the railroad tracks will remain GSA property. The now empty portion of the BFC, located west of the railroad, is undergoing disposition. Federal property can be transferred prior to the completion of all remedial action, through the early transfer process. If the early transfer occurs, the Missouri Hazardous Waste Management Facility Part I Permit will transfer to the new owner for the area west of the railroad tracks, and the General Services Administration (GSA) will remain the permit holder for the area east of the railroad tracks. The transfer will also include a small piece of noncontiguous property; referred to as the “Tower Site” that is not part of the permitted property. The first step, the issuance of a Finding of No Significant Impact (FONSI), was completed in May 2013. In September 2014, DOE/NNSA submitted a report to congress that described “a comprehensive plan, including timelines and cost requirements for the final disposition of the BFC.” The plan has four goals:
- Comply with presidential memorandum – “Disposing of Unneeded Federal Real Estate”
- Attain the best value for the federal government
- Attain the highest level of support from the community
- Position the property to contribute to the economic health of the region
The DOE/NNSA has determined an early transfer, with clean-up responsibilities being transferred to the new owner, would be the best way to address the future of the now vacant portion of the site. CenterPoint Properties was chosen as the preferred developer for the site. The report to congress specified $22 million for CenterPoint to perform due diligence necessary for a demolition and remediation plan. After the proposed early transfer, it is currently estimated that it will take CenterPoint until roughly late 2023 to perform approximately $200 million of demolition, remediation and site civil work with oversight by DOE/NNSA.
Early transfer is a process involving a number of required steps that requires the governor’s approval and ends when the site is cleaned up. DOE/NNSA initiated this process with submission of a Letter of Intent to the governor on Feb. 26, 2015. The most important submittal in the early transfer process is the Covenant Deferral Request (CDR). The CDR package includes a Finding of Suitability for Early Transfer (FOSET). The FOSET includes a description of the site’s current status, an overview of the known contamination present, a brief description of the activities that will be performed following the transfer of the site, including the demolition, remediation and changes to the geography of the site, and finally a plan for the intended future use of the site. The DOE/NNSA has made the complete FOSET available for public review and comment for a minimum period of 30 days; after which, it will be submitted to the governor. The Hazardous Waste's (HWP's) Federal Facilities Section established a Transfer Team to work with DOE/NNSA, GSA, CenterPoint and the U.S. Environmental Protection Agency (EPA) to facilitate the development of the CDR package, including the FOSET. A public notice began for the FOSET on May 5, 2017, and ends June 19, 2017.
Recent Investigative Work
Since being selected as the preferred developer for the BFC, CenterPoint Properties has completed a due diligence investigation that included records review, analysis of existing data and targeted site investigations. The primary goal of the work was to determine the nature and extent of contamination within the property to be transferred to a new owner, and to ensure that the contamination that was previously identified by DOE/NNSA and their contractors encompassed all contamination for the property to be transferred. The focus of the work was the extent of soil and groundwater contamination associated with past industrial activities at the BFC. The work was completed between October 2014 and March 2016.
Due diligence soil sampling was conducted resulting in almost 2,400 soil samples being collected from the BFC and analyzed. In addition, over 70 groundwater samples were collected from wells for the due diligence investigation. The area of Outfall 001 was also investigated. Fifty-five soil, shallow groundwater, surface water and seep samples were collected from Outfall 001.
The Tower Site was also evaluated. Ten soil samples were collected from the top three feet of soil. Compounds detected include naturally-occurring metals, as well as semi-volatile organic compounds, PCBs and total petroleum hydrocarbon-range organics. None of the soil samples collected from the Tower Site exceeded risk-based screening levels.
During the due diligence investigation, all soil samples were analyzed for total uranium and screened in the field for gamma radiation in a grid across the site. Historically, both depleted uranium and metallic uranium were used in manufacturing processes at the BFC. The sampling led to the detection of one golf ball sized piece of depleted uranium, which was removed.
As part of the groundwater sampling, twenty-nine groundwater samples were collected for analysis of radiological parameters; including gross alpha, gross beta, total suspended solids and total dissolved solids. No radiological impacts on groundwater were observed.
Overall, site conditions on portions of the BFC evaluated in the Due Diligence Summary Reports are largely similar to conditions as described by previous site investigations. The data from this due diligence investigation was used to propose remedial actions and calculate screening levels for proposed cleanup levels for the remediation that will occur following the early transfer, if it is approved.
In addition to sampling, CenterPoint Properties has prepared plans for demolition of the buildings, including the BFC Master Demolition Plan and the Bannister Federal Complex Abatement and Demolition Plan Supplements documents. Plans have also been written for the replacement of the stormwater system, water and power lines, and regrading of the site in Site Civil documents and drawings, including detailed safety and health plans for protection of site workers and the public living near the BFC.
Concurrent with demolition and site civil work, CenterPoint has prepared plans for remediation and long-term stewardship of soil and groundwater contamination including the Corrective Measures Report and Technical Memorandum: Proposed Cleanup Levels for On-Site Areas of the Bannister Federal Complex. Soil remediation will include removal and disposal of the most contaminated soil and barrier walls to contain and block groundwater contamination movement. New construction will also include vapor barriers under all new construction to block any vapor intrusion of volatile organic contaminants from soil and groundwater beneath the new buildings.