Bannister Federal Complex
EPA ID# MO9890010524
MoDNR Contact: Mark Hogan, 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: Erin Dries, 816-823-4916
BT&D Contact: Kevin Breslin, 816-769-0180
Last Updated: May 3, 2018
- 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:
BT&D and GSA are currently performing long-term monitoring and maintenance activities and conducting corrective action investigations and remediation activities on their respective portions of the federal complex under a department-issued Missouri Hazardous Waste Management Facility Part I Permit and U.S. Environmental Protection Agency (EPA)-issued Hazardous and Solid Waste Amendments Part II Permit. The status of BT&D and GSA’s post-closure and corrective action activities is described below. The public can review and copy paper copies of all permits, reports and supporting documents at the agency locations above.
Permit Deliverables:The following documents are required to be submitted under the Missouri Hazardous Waste Management Facility Part I Permit, as effective Jan. 22, 2018.
- Revised Community Involvement Plan
- Revised Sampling and Analysis Plan
- Updated Spill Control/Emergency Plan
Additional miscellaneous reports:
- Revised Community Involvement Plan and Appendices, June 2013.
- Description of Current Conditions Report (DCCR), May 2016.
- Updated Long-Term Operation, Maintenance and Monitoring (LTOM&M) Plan, July 2012. (Parts have been approved; applicable to the existing final remedy.)
- Indian Creek/Blue River Fate & Transport Draft Report,March 2016.
- Revised Sampling and Analysis Plan, March 2013.
- Updated Spill Control/Emergency Plan, August 2012.
Quarterly Discharge Monitoring Reports: (Required under their Missouri State Operating Permit, #0004863)
The public can review and copy paper copies of the above reports, as well as other reports and supporting documents, at the agency locations above. The above documents have been made available on this web site due to the level of interest regarding activities at the federal complex. These documents are available for informational purposes only. The department and EPA are not actively soliciting public comments on the documents. The department and EPA continue to review additional documents submitted by BT&D relating to the ongoing demolition and redevelopment of the facility. The agency review and approval process can take a substantial amount of time due to the size and scope of these documents.
The department realizes that some of the electronic files are quite large, which may result in long download times for individuals with slow 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 Mark Hogan 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 Bannister Federal Complex is located on about 307 acres at 1500-2000 E. Bannister Road in Kansas City, Mo, about 13 miles south of downtown Kansas City, within the incorporated city limits. Before World War II, the area of the federal complex was mainly farm land. For a brief period in the early 1920’s, the land was home to an automobile race track. From 1942 until November 2017, the property was a federal government-owned, contractor-operated military installation. 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 1945, the main manufacturing building was declared excess to defense requirements. The building was turned over to the War Assets Administration, who used it for a short time as a warehouse and housing for several private and governmental operations.
In December 1947, the main manufacturing building was transferred to the Department of the Navy. From 1949 to 1961, the Department of the Navy leased part of the building to Westinghouse Electric Co. to build aircraft engines for the U.S. Navy in support of the Korean Conflict. In 1949, Westinghouse subleased a large part of the building to Bendix Corp., who was contracted by the Atomic Energy Commission to manufacture electrical, mechanical, plastic and other non-nuclear components of nuclear weapons. This part of the federal complex became known as the Kansas City Plant and covered about 136 acres of the 307-acre federal complex. In 1961, Westinghouse’s lease was cancelled and that part of the building was transferred to the General Services Administration (GSA). GSA manages government assets, including government-owned and leased buildings.
In 1962, most of the federal complex was transferred to GSA with the agreement that Bendix would continue to operate the Kansas City Plant in their part of the main manufacturing building. GSA operated a warehouse in the western part of the building. The landfill was closed in 1964, and the property transferred to GSA. The Atomic Energy 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. In 1977, the U.S. Department of Energy (DOE) was created and took custody and control of the Kansas City Plant and ownership of their part of the main manufacturing building. In 2000, DOE created the National Nuclear Security Administration (NNSA), in part, to strengthen national security and reduce the global threat from weapons of mass destruction.
Bendix continued to operate the Kansas City Plant throughout the ownership transitions. In 1983, Bendix merged with Allied Corp., who later merged with Signal Corp. and became Allied Signal Inc. In 1999, Allied Signal merged with Honeywell Corp. and adopted the name Honeywell Federal Manufacturing & Technologies LLC. DOE/NNSA continued to contract Honeywell to operate the Kansas City Plant.
The Kansas City Plant has always been used to manufacture electrical, mechanical, plastic and other non-nuclear components of nuclear weapons. This work involved machining, plastic fabrication, plating and electrical and mechanical assembly. A variety of hazardous wastes, such as acids, alkalines, solvents, acid- and alkaline-contaminated solid waste, solid debris waste, waste oil, wastewater treatment sludges and toxic metals, were produced as part of the plant operations. These wastes were stored on the property until they were either treated at the Kansas City Plant’s industrial wastewater pretreatment facility or shipped off-property to a permitted hazardous waste treatment, storage and disposal facility.
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 the property until shipped off-property. Beginning in February 1951, 12-inch long uranium fuel slugs were produced from 10-foot long uranium rod stock. Forty-five thousand slugs were produced from 313,070 pounds of feedstock during a 22-month period. These fuel slugs were made to supply the Savannah River Site in South Carolina and Argonne National Laboratory.
Hazardous waste was stored on-site in containers and tanks in six hazardous waste container storage areas, three contingent storage areas and an underground tank farm. The underground tank farm was installed in 1943, and consisted of 28 tanks and associated underground piping. Twenty-two of the tanks were constructed of steel and the remaining six were concrete. The tanks were used to store solvents, fuels and coolants, which were supplied by nine unloading stations that piped liquids to the tanks through a pump house.
The Kansas City Plant originally used an industrial wastewater system to carry process wastewater to two lagoons located in the northeast corner of the federal complex. The process wastewater included rinse waters, drained water from various operating areas and treated cooling waters. The north lagoon was built in 1962, with the purpose of monitoring the pH until it was within limits to be discharged. If the pH was outside the range, the discharge was recirculated until it fell within the required limits. Effluent from the north lagoon was originally discharged directly into the Blue River. In 1967, state regulations prohibited discharging process wastewaters into rivers. The north lagoon effluent was rerouted, combined with sanitary sewage and monitored for pH levels before being discharged to Kansas City’s sanitary sewer system and publicly owned treatment works. The south lagoon was built in 1975, to handle additional flow when other plant wastewaters were required to be rerouted to the north lagoon.
DOE replaced the lagoons with an industrial wastewater pretreatment facility in 1988. This system treated all process related wastewater generated by production operations at the plant. Part of the wastewater was treated with reverse osmosis and recycled as cooling tower make-up water. By doing this, the plant could avoid using drinking water as cooling water and discharge less wastewater to the sanitary sewer system.
In 2013, DOE/NNSA and Honeywell FM&T moved their operations to a new plant, the National Security Campus, located about eight miles south of the federal complex on Botts Road. In 2014, GSA moved their operations to downtown Kansas City on Main St. At that time the Bannister Federal Complex was owned by both DOE/NNSA and GSA. DOE/NNSA owned the Kansas City Plant and GSA owned the remaining portions of the federal complex, with Union Pacific railroad tracks running north and south across the property. After relocating, DOE/NNSA and GSA selected a private developer to redevelop approximately 225-acre areas of the federal complex west of the Union Pacific railroad tracks, plus two acres off-site of the main complex, totaling about 227 acres. In November 2017, Bannister Transformation & Development LLC (BT&D) took ownership of the 225 acres of the federal complex. GSA owns the remaining 82 acres of the federal complex east of the railroad tracks, including the closed landfill. The U.S. Marine Corps are the only tenants at the federal complex on the GSA-owned portion of the property, under a long-term lease for the former Internal Revenue Service building.
Redevelopment of the 225-acre portion of the federal complex property will be conducted by BT&D. As of February 2018, building demolition is underway, along with installing additional extraction wells and sediment basins. All former buildings will be removed except Building 98, the on-site wastewater pre-treatment facility. The site will then be regraded, new utilities installed, and then be ready for reuse and development. The entire demolition and redevelopment phase is expected to take four to five years.
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 (PCBs) from Department 26, which produced plastic in the southeast corner of the main manufacturing building. PCBs were used in heat transfer fluid during the production process. In 1969, an expansion joint in the process piping failed and released approximately 1,500 gallons of PCB oil to a gravel area east of the building. About 900 gallons of the PCB oil entered the storm sewer system and was released to Indian Creek through the old Outfall 002, later renamed the Abandoned Indian Creak 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 during construction of Bannister Road and the flood control levee (1970-1971). PCB contaminated sediment that was not removed from the“old” Indian Creek channel was buried alongside and underneath the box culvert leading to the new Outfall 002. The second release occurred in 1971, outside Department 26. About 1,100 gallons of PCBs were released to the ground 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 Outfall 002. Again, cleanup was performed.
In 1977, DOE completed an environmental impact assessment of the Kansas City Plant, originally started by the Energy Research and Development Administration. The assessment was required under the National Environmental Policy Act of 1969 (NEPA), to assess the environmental implications of the ongoing operations at the Kansas City Plant.
Voluntary environmental investigation activities at the Kansas City Plant began in the early 1980s, with hydrogeologic investigations, sampling events and assessments in various areas of the facility. In 1982, the first monitoring wells were installed in the underground tank farm area and revealed chlorinated solvents in the groundwater. A preliminary hydrogeologic investigation revealed the underground tank farm area was a source of contamination and determined the soil surrounding the tanks was contaminated. The investigation also concluded the monitoring network in place at that time was not capable of adequately defining the plume of contaminated groundwater. As a result, seven additional monitoring wells were installed in the underground tank farm area during October and November 1984, to help define the contaminated groundwater plume.
In 1985, DOE notified the U.S. Environmental Protection Agency (EPA) of its intent to decommission the north lagoon. Since there was disagreement over the status of the lagoons under the federal Resource Conservation and Recovery Act (RCRA), EPA and DOE entered into a federal facility compliance agreement under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) to begin partial closure of the north lagoon. Sediment from the lagoon, which was known to contain varying concentrations of metals and PCBs, was removed and shipped off-site to a permitted hazardous waste disposal facility.
DOE submitted a RCRA closure plan to EPA for the remainder of the north lagoon closure in 1985, the underground tank farm in 1986, and south lagoon in 1987. During this time, DOE replaced the PCB heat transfer piping and oil from its two heat transfer systems. EPA banned PCBs in 1979; however, PCB replacement was not required in existing equipment. PCBs were used in transformers, other electrical equipment, hydraulic oil, caulking compounds and elastic sealant. Materials made before the PCB ban are still present at the Kansas City Plant and other locations in the federal complex.
Throughout the underground tank farm’s history, there have been some decommissioning events. Some tanks were filled with water, some with sand, while others were drained and cleaned with a high-pressure soap and water sprayer. In 1986, DOE performed a study to identify and evaluate possible remedial alternatives in the underground tank farm area. A pump and treat system, including three extraction wells with an above ground treatment unit was selected as the most efficient remedial design. The extraction wells were installed in February and March 1987.
DOE began final closure of the underground tank farm in August 1987. All tanks, associated piping, concrete supports and soil to a depth of about 15 feet below ground surface were removed. During this same timeframe, DOE also removed contaminated sediment from the south lagoon. The tank farm area and both the north and south lagoons were then backfilled with clean soil and covered with clay caps, topsoil and vegetation. EPA accepted DOE’s closure report and certification for the hazardous waste management units; however, because groundwater contaminated with hazardous constituents remained after closure, these areas were required to go through a period of post-closure care. As part of the post-closure care, DOE was required to monitor the groundwater and maintain the clay caps.
In 1988, approximately 1,600 tons of contaminated material were removed from the 002 raceway, which included the area between the new 002 Outfall and Indian Creek. Residual PCB contamination was covered with clean soil and capped with a replacement concrete raceway. In 1993, approximately 27,210 tons of PCB-contaminated material were removed from the Abandoned Indian Creak Outfall and clean fill was used to restore the area.
Initially, DOE voluntarily performed post-closure, corrective action and long-term stewardship activities for the Kansas City Plant under a 3008(h) Corrective Action Administrative Order on Consent with EPA, Docket No. VII-89-H-0026, with EPA providing regulatory oversight. In 1999, the EPA order was replaced by a department-issued Missouri Hazardous Waste Management Facility Part I Permit and EPA-issued Hazardous and Solid Waste Amendments Part II Permit. These permits transferred the regulatory oversight responsibility and authority for the investigation and corrective action activities from EPA to the department, under Missouri’s RCRA-equivalent hazardous waste program.
By 1999, forty-three solid waste management units were identified at the Kansas City Plant as possible release sites, including the two closed lagoons and underground tank farm. Many of the solid waste management units were grouped together for further investigation and cleanup, due to their close proximity to each other and the type of contamination. The contaminated area located south of the main manufacturing building, in the old Indian Creek channel between the old and new Outfall 002 locations and box culvert, became known as the 95th Terrace site. This site is partially located on property owned by the Missouri Department of Transportation.
In 2003, several catch basins and the new 002 Outfall box culvert were cleaned to remove approximately 8,000 pounds of PCB-contaminated sediments. On Sept. 29, 2006, the department, in coordination with EPA, approved the final remedy for the 95th Terrace site. As part of the final remedy, DOE was required to inspect and, if necessary, repair the box culvert under Bannister Road, place warning signs at Outfall 002 and install a protective cage over the concrete chute entering Indian Creek. DOE was also required to sample surface water, sediment and fish tissue in Indian Creek and the Blue River for PCBs. By 2012, all contaminated areas under DOE’s responsibility were in the final remedy operating, maintenance and monitoring stage. Groundwater was collected from extraction wells, building footing tile drains and low flow from Outfall 002, treated by an ultraviolet light-hydrogen peroxide system and discharged to the local sewage treatment plant. PCB samples were collected from surface water, sediment and fish tissue in Indian Creek and the Blue River in 2005, 2007, 2013 and 2017, and are currently scheduled for every five years.
In 2012, the department and EPA modified DOE’s hazardous waste permits at DOE and GSA’s request. GSA was added to DOE’s permits, as a permittee, and the GSA-owned property was included under the permits, except the closed landfill. Up to this point, GSA had been performing environmental investigation and cleanup activities on their portion of the federal complex under CERCLA, with EPA providing regulatory oversight. Having the entire federal complex under the same environmental law and the same permits allowed the environmental investigations to be better coordinated and sped up the corrective action process. Additional information about GSA’s cleanup efforts under CERCLA is available on EPA's website.
The U.S. Army Corps of Engineers is performing the environmental investigation and cleanup of the closed landfill on the GSA property under the Formerly Used Defense Sites Program, with the department providing regulatory oversight. Solvents have been confirmed in the groundwater in the area of the closed 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.
In 2013, DOE moved their operations to a new plant and vacated the facility. GSA also vacated the facility, moving their operations to downtown Kansas City in 2014. Even though they were not physically located on the property, DOE and GSA continued performing long-term monitoring and maintenance activities and conducting corrective action investigations and remediation activities at the federal complex. In 2015, DOE completed the Indian Creak/Blue River Fate and Transport Study to identify the origin, fate and transport of PCBs within Indian Creek and the Blue River areas. In May 2016, DOE and GSA submitted a Description of Current Conditions Report, or DCCR, presenting all environmental sampling and investigations, interim measures and unit closures conducted up to that point. In June 2016, DOE and GSA performed a baseline risk assessment of the contaminated areas to determine if they exceeded risk levels and to address remaining elements necessary to adequately characterize the site.
During this same time, a private developer, CenterPoint Properties, also performed several “due diligence” activities at the federal complex, including sampling, to independently evaluate the environmental conditions. After relocating their operations, DOE and GSA selected CenterPoint to explore redeveloping 225 acres of the federal complex west of the Union Pacific railroad tracks and an additional two acres off the main property, totaling about 227 acres. Even though CenterPoint’s activities did not fall under DOE and GSA’s hazardous waste permits or Missouri State Operating Permit for outfall discharges, CenterPoint and its consultants asked the department and EPA to review, comment and approve several sampling work plans. By doing this, the information obtained during the “due diligence” activities would be acceptable for future decision-making purposes related to property redevelopment and additional cleanup.
Anticipating CenterPoint would acquire the property, the department, in coordination with EPA, proposed changes to the approved final remedy and additional cleanup actions to ensure continued protection of human health and the environment during demolition and redevelopment of the site. On July 14, 2017, the department, in coordination with EPA, approved a contingent final remedy for the area of the federal complex west of the railroad tracks. These changes became effective Jan. 22, 2018, after the property was transferred to Bannister Transformation & Development LLC (BT&D) through an additional permit modification for change of ownership.
Additional information about the "due diligence" activities and proposed plans for demolition and environmental work to be performed on BT&D-owned areas west of the railroad tracks are available on BT&D's website. GSA-owned areas east of the railroad tracks are still under environmental investigation.
The Kansas City Plant operated the six hazardous waste container storage areas and three contingent storage areas under hazardous waste generator storage requirements. The three hazardous waste management units (two lagoons and an underground tank farm) were operated under the interim status portions of the federal Resource Conservation and Recovery Act (RCRA). In 1980, when EPA implemented the federal hazardous waste laws, 40 CFR Part 265, all existing facilities that treated, stored or disposed of hazardous waste in a manner that would necessitate obtaining a hazardous waste permit were required to notify EPA and apply to get such a permit or close those operations. Because of the large number of existing facilities, Congress set up requirements which allowed these facilities 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. The Kansas City Plant is subject to the permitting requirements of the Missouri Hazardous Waste Management Law and federal Hazardous and Solid Waste Amendments for post-closure care because groundwater contaminated with hazardous constituents remained after closure. The Kansas City Plant is also subject to corrective action because the interim status hazardous waste management units were closed after the effective date of the federal Hazardous and Solid Waste Amendments.
Initially, DOE voluntarily performed post-closure, corrective action and long-term stewardship activities for the Kansas City Plant under a 3008(h) Corrective Action Administrative Order on Consent with EPA, Docket No. VII-89-H-0026, signed June 23, 1989. On Oct. 6, 1999, the EPA order was replaced by a department-issued Missouri Hazardous Waste Management Facility Part I Permit and EPA-issued Hazardous and Solid Waste Amendments Part II Permit.
These permits transferred the regulatory oversight responsibility and authority for the investigation and corrective action activities from EPA to the department, under Missouri’s RCRA-equivalent hazardous waste program. These permits require post-closure care for the three closed hazardous waste management units (two lagoons and an underground tank farm), as well as operating, maintaining and monitoring all corrective action final remedies for the Kansas City Plant.
On Sept. 29, 2006, the department issued a Part I department-initiated permit modification 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 add the GSA-owned portions of the federal complex to the permits and add GSA as a permittee. The modification also required further environmental investigation, monitoring, risk-assessment and, if necessary, additional cleanup at the federal complex. On July 14, 2017, the department issued a contingent Part I department-initiated permit modification to implement the contingent final remedy for the area of the federal complex west of the railroad tracks. These changes became effective Jan. 22, 2018, after the property was transferred to BT&D through an additional permit modification for change of ownership.
The existing hazardous waste permits for the federal complex expired Oct. 6, 2009. Code of State Regulations 10 CSR 25-7.270(1) and Code of 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. On April 7, 2009, DOE submitted a timely permit application to renew the existing hazardous waste permits; therefore, the existing hazardous waste permits remain in effect until the department and EPA issue or deny new permits. Since DOE closed all interim status hazardous waste management units and no longer operates at the property, this permit application is for post-closure and corrective action only. The department is currently reviewing the application.
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