U.S. Department of Energy/U.S. General Services Administration - 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
Last Updated: Dec. 12, 2017
- 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:
The U.S. Department of Energy (DOE)/National Nuclear Security Administration (NNSA) and General Services Administration (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 DOE/NNSA 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: DOE/NNSA and GSA submitted to the department and 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 and Appendices: Approved with comments in April 2013. (Discussing updates due to contacts being out of date.)
- Description of Current Conditions Report (DCCR): Approved May 2017.
- 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: Approved March 2016.
- 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.)
Additional miscellaneous reports:
- Quarterly Discharge Monitoring Report, October 2017 (Required under their Missouri State Operating Permit, #0004863)
The public can review and copy paper copies of the above reports and 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. Please be aware the department and EPA are currently reviewing several documents. 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 a federal government-owned, contractor-operated military installation, located on 307-acres at 1500-2000 E. Bannister Road in Kansas City, Mo. The federal complex is 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. 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. 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 1948, the main manufacturing 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 in the main manufacturing building for the U.S. Navy in support of the Korean Conflict. In 1949, Westinghouse subleased 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 site became known as the Kansas City Plant and covered about 136 acres of the 307-acre federal complex. 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 (GSA). GSA manages government assets, including government-owned and leased buildings. GSA operated a warehouse in the western part of the main manufacturing building. The Atomic Energy Commission continued operating 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. In 1977, the U.S. Department of Energy (DOE) was created 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 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. DOE/NNSA continued to contract Honeywell to operate the Kansas City Plant and manufacture electrical, mechanical, plastic and other non-nuclear components of nuclear weapons.
A variety of hazardous wastes were produced as part of the Kansas City Plant operations. Acids, alkalines, solvents, acid and alkaline contaminated solid waste, solid debris waste, waste oil, wastewater treatment sludges and toxic metals 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 previously operated six hazardous waste container storage areas, three contingent storage areas, two lagoons and an underground tank farm. 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.
The Bannister Federal Complex is currently owned by two federal government agencies: DOE/NNSA and GSA. The Kansas City Plant is owned by DOE/NNSA and was last operated by Honeywell Federal Manufacturing & Technologies LLC. GSA owns the remaining portions of the federal complex, with Union Pacific railroad tracks running north and south across the property. 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, located east of the railroad tracks and currently owned by GSA. Since relocating, DOE/NNSA and GSA selected CenterPoint Properties, a private developer, as a preferred partner to redevelop the area of the federal complex west of the railroad tracks and an additional two acres off the main property, totaling about 227 acres. If the property transfer occurs, GSA will remain the owner of about 82 acres of the federal complex east of the railroad tracks, including the closed landfill.
The Kansas City Plant operated the six hazardous waste container storage areas and three contingent storage areas under generator storage requirements. The three closed hazardous waste management units (two lagoons and underground tank farm) were operated under the federal and state hazardous waste laws. 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 groundwater contaminated with hazardous constituents remained after closure, 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 (PCBs) 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 Outfall 002. 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 Outfall 002. This area of contamination, known as the 95th Terrace site, is located south of the main manufacturing building in the old Indian Creek channel, 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 activities were 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 listed 35 solid waste management units as possible release sites, including the two closed lagoons and underground tank farm. The order directed the environmental investigation and corrective action activities at the plant 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 regulatory oversight responsibility and authority for the investigation and corrective action activities from EPA to the department. EPA terminated the 3008(h) Order on Dec. 30, 1999. 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 (RCRA), with the department providing regulatory oversight.
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. 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 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 collected from interceptor wells, building footing tile drains and Outfall 002, treated by an ultraviolet light-hydrogen peroxide system and discharged to the local sewage treatment plant. As part of the approved final remedy for the 95th Terrace site, DOE/NNSA is required to inspect and, if necessary, repair 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, 2007 and 2013 and are currently scheduled for 2017 and every five years thereafter.
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 (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 Part I and Part II Permits to include the entire federal complex under the permits, including the property owned by GSA, and add GSA as a permittee. The U.S. Army Corps of Engineers is responsible for performing the environmental investigation and cleanup of the closed landfill, located on the GSA-owned portion of the federal complex, under the Formerly Used Defenses 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.
Since DOE/NNSA and GSA relocated their operations, they selected CenterPoint Properties, a private developer, as a preferred partner to explore redeveloping 225-acre areas of the complex west of the Union Pacific railroad tracks, plus two acres off-site of the main complex. CenterPoint performed several “due diligence” activities at the federal complex, including sampling, to independently evaluate the environmental conditions and support its future decisions regarding property reuse/redevelopment. CenterPoint and its consultants asked the department and EPA to review, comment and approve several “due diligence” sampling 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 would be acceptable for future decision-making purposes related to property redevelopment and additional cleanup, if CenterPoint decides to become the owner/operator of the federal complex west of the railroad tracks. Additional information about the "due diligence" activities and proposed plans for demolition and environmental work to be performed if the property is transferred is available on the Bannister Transformation and Development LLC's website.
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 RCRA in 1980, 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, unless the facility chose to 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. DOE/NNSA 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. DOE/NNSA is also subject to the corrective action because they completed closure of the interim status hazardous waste management units after the effective date of the federal Hazardous and Solid Waste Amendments.
DOE/NNSA is currently 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. The Part I permit requires DOE/NNSA to perform post-closure care for the three closed hazardous waste management units (two lagoons and an underground tank farm), as well as operate, maintain and monitor all corrective action final remedies on the DOE/NNSA part of the federal complex. The Part II Permit covers regulatory requirements Missouri had either not yet adopted or adopted but not yet received EPA authorization.
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 under the permits, including the property owned by GSA, and add GSA as a permittee. The modification also required 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. On July 14, 2017, the department approved contingent changes to the current approved remedy and final contingent Part I Permit modification (redline version) in preparation for transferring the federal complex property west of the railroad tracks to a private developer before the facility cleanup is complete*. These changes will become effective if, and only if, the property is transferred to the private developer at a later date. Until that time, the current approved remedy and Part I Permit will remain in effect.
DOE/NNSA submitted a permit application on April 7, 2009, to renew their existing hazardous waste 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 existing hazardous waste permits for the federal complex 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.
*At the same time the department accepted comments on the proposed changes to the current approved remedy and Part I Permit, DOE/NNSA accepted comments on a draft Finding of Suitability for Early Transfer (FOSET), which will be submitted to the Missouri Governor's office to transfer the property to the private redeveloper. Many of the comments the department received did not directly apply to the department’s proposed changes; however, those comments did apply to the FOSET and so were forwarded to DOE/NNSA for review and response. DOE/NNSA’s response to comments on the FOSET and other supporting documents are available on DOE/NNSA's website.
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