Greenfield Environmental Multistate Trust LLC - Kansas City
EPA ID# MOD007128978
MoDNR Contact: Nathan Kraus, PE, 573-751-3154 or 800-361-4827
Facility Contact: Lauri Gorton, PE, 414-732-4514
Last Updated: Feb. 6, 2020
- Former Company Name: Tronox LLC, Kerr-McGee Chemical Corp., Moss American Corp., American Creosote Corp.
- Type of Facility: Former Interim Status Hazardous Waste Disposal – closed.
- Disposal Methods: Land disposal - closed.
- Wastes Handled: Aqueous wastes, contaminated soil, and creosote-rich bottom sediment sludge (K001 listed hazardous waste).
- Location of hard copies of hazardous waste permit application, Part I and Part II Permits, modification requests, reports, etc. and supporting documents:
Final Permit Issued: On Feb. 4, 2020, the department issued a final Missouri Hazardous Waste Management Facility Part I Permit to Greenfield Environmental Multistate Trust LLC for its Kansas City facility. Any parties adversely affected or aggrieved by the department’s decision to issue the Part I Permit, or specific conditions of the Part I Permit, may be entitled to pursue an appeal before the Administrative Hearing Commission by filing a written petition by March 5, 2020, as more fully described on page 9 of the final Part I Permit.
Greenfield has been performing long-term monitoring and maintenance activities and conducting corrective action investigations and remediation activities at the site 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 Greenfield’s post-closure and corrective action activities is described below. Kerr-McGee, the previous owner, submitted a permit application to the department and EPA, to renew and update the hazardous waste permits. Greenfield, who took ownership and operational control of the permitted facility in 2011, replaced Kerr-McGee’s permit application with a new application in June 2019. After a thorough technical review of the permit application and opportunity for public comment on the draft permit, the department issued a final Part I Permit for Greenfield’s Kansas City facility. The final permit requires Greenfield to continue conducting post-closure care for the closed regulated impoundment and corrective action activities. The final permit also shifts oversight responsibility for Greenfield’s investigation and corrective action activities from EPA to the department.
EPA decided not to prepare a Part II Permit, since EPA has no facility-specific conditions beyond those contained in the draft Part I Permit, and Missouri is fully authorized for all permitting, post-closure, and corrective action activities at the facility. EPA will terminate the existing Part II Permit upon the issuance of the Part I Permit. The public can review and copy paper copies of the final Part I Permit, summary and response to comments received during the public comment period and supporting documents at the Kansas City Public Library’s North-East Branch, 6000 Wilson Road, Kansas City, Missouri (during normal business hours) or the agency locations above.
The Greenfield Environmental Multistate Trust LLC Kansas City facility is located on about 111 acres at 2300 Oakland Ave. in Kansas City, Missouri. In 1907, American Creosote Corp. built and began operating a wood treating facility on the property. In 1964, Kerr-McGee Corp. purchased the facility and it became part of Moss American Corp., a wholly owned subsidiary of Kerr-McGee Corp. In 1974, Moss American became the Forest Products Division of Kerr-McGee Chemical Corp., another wholly owned subsidiary of Kerr-McGee Corp.
Both American Creosote and Kerr-McGee pressure treated railroad crossties, switch ties, bridge timbers and lumber, which they sold for commercial use. Both companies used a 70 percent creosote and 30 percent coal-tar solution as the wood preservative. Creosote is a mixture of several residual oils, aromatic hydrocarbons and tars resulting from carbonizing bituminous coal. Dried (seasoned) wood was loaded onto a tram cart and placed in a large high temperature-high pressure cylinder called a retort. The retort was sealed and the wood steamed at high pressure to remove moisture and other wood impurities. A vacuum was then pulled on the retort to withdraw the materials steamed from the wood. The cylinder was then filled with the preservative and pressure was applied to force the preservative into the wood. The pressure was released when the desired amount of creosote had been injected into the wood. A vacuum was then applied to remove the excess preservative from the retort and recycle it back to the work tank. The tram cart was removed from the retort and moved to drying and storage areas located on the facility property. Any creosote drippage (“kick-back”) from the treated wood dropped to the ground beneath the drying areas.
Process wastewater was produced as part of the facility operations. The major sources of wastewater were the cooling water from the treatment process and steam condensate from cleaning the retort. The steam condensate contained some lingering preservative from the retort. American Creosote built a wastewater treatment system on the facility property, which consisted of an oil/water separator and non-engineered surface impoundments (Ponds A and B). The surface area of one impoundment was estimated to be 5,000 square feet with an unknown depth, while the second impoundment had a volume of approximately 15,000 cubic feet. The wastewater was processed through the oil/water separator, where the oil was skimmed from the top of the wastewater and pumped into a holding tank to be recycled back to the production process. The wastewater effluent was discharged to the ponds to let the remaining creosote sludge settle out of the wastewater. If not heated, creosote can thicken and turn into sludge. The wastewater effluent was then discharged off site.
In 1975, Kerr-McGee closed the non-engineered surface impoundments and replaced them with a 365 ft. x 210 ft. engineered surface impoundment, with a maximum capacity of approximately 3.6 million gallons. The impoundment covered an area where a shallow diked depression had been located. This depression had been used as a sedimentation basin for the process water before discharging off site.
In 1981, the U.S. Environmental Protection Agency (EPA) determined both the engineered and non-engineered surface impoundments were hazardous waste management units regulated under the federal Resource Conservation and Recovery Act (RCRA). Sediment sludge produced from treating wastewaters from creosote wood preserving processes is classified as a listed hazardous waste (K001). This waste had collected and was being “stored” in the bottom of Kerr-McGee’s surface impoundments. In April 1983, Kerr-McGee decided to stop their production process and close the engineered surface impoundment; however, Kerr-McGee continued to use the facility as a distribution center for treated wood products.
During 2001, Kerr-McGee went through a corporate restructuring and transferred the Kansas City facility from their Forest Products Division to their Chemical Division, which they merged into Kerr-McGee Chemical Worldwide LLC, a wholly-owned subsidiary of Kerr-McGee. In September 2005, Kerr-McGee renamed their Chemical Division to Tronox Inc., which was spun-off as an independent company in April 2006. In January 2009, Tronox filed for relief under Chapter 11 bankruptcy. Under the 2011 bankruptcy settlement agreement, Tronox transferred all its rights, title and interest with respect to the Kansas City facility to an environmental trust, called the Multistate Environmental Response Trust. Greenfield Environmental Multistate Trust LLC was named the independent, court-appointed Trustee and took ownership and operational control of the property in February 2011. Greenfield Environmental is responsible for owning and managing in trust more than 400 former Tronox/Kerr-McGee sites in 31 states, including this facility. The Kansas City facility is currently inactive, except for ongoing post-closure and corrective action activities.
Kerr-McGee closed the non-engineered surface impoundments (Ponds A and B) before the federal hazardous waste laws and regulations existed. Kerr-McGee closed the engineered surface impoundment in 1988, according to a department-approved closure plan. Before closure, it was estimated the engineered surface impoundment contained about 10,200 cubic feet of K001 hazardous waste sludge and an underlying volume of about 41,500 cubic feet of contaminated soil. As part of the closure, a Deed Notice, filed with the Jackson County Recorder of Deeds on Dec. 6, 1988, was placed in the property chain-of-title in order to inform potential future buyers of the property that the former interim status engineered surface impoundment area was used to manage hazardous waste. The department accepted Kerr-McGee’s closure report and certification in March 1989; however, because hazardous waste remained in the groundwater after closure, this area was required to go through a period of post-closure care. As part of the post-closure care, Kerr-McGee was required to operate and maintain a groundwater monitoring and remediation system, as well as inspect and maintain the cover over the closed impoundment.
According to applicable federal and state 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 several known historical leaks and spills of creosote from ruptured or damaged piping and vessel valves/seals on treating equipment. Another major historical source of creosote contamination at the facility is the kickback that was allowed to drop to the ground beneath the drying areas, resulting in soil staining and contamination.
Before building the engineered surface impoundment, eight exploratory test pits were dug around the border of the proposed impoundment. One or more of these pits, excavated in 1973, indicated the soil was contaminated with creosote to a depth of at least 7 feet. Sixteen historical contamination source areas were identified at the facility, between a 1987 RCRA Facility Assessment Report, the 1992 Part II Permit and the 1994 RCRA Facility Investigation Work Plan. Several interim measures were taken at the site in order to reduce or prevent unacceptable risks to human health and the environment. An interim measure is an action taken to temporarily control the contamination source or path the contamination could take from the source to humans, animals or the environment, such as air, soil, water and food. As an interim measure, Kerr-McGee installed and operated a groundwater and free product pump and treat system and removed and capped contaminated soils. These activities were conducted in coordination with the City of Kansas City’s historical replacement of the 23rd Street overpass and the U.S. Army Corps of Engineers’ historical realignment of the Blue River. Greenfield continued to maintain the interim measures after taking ownership and operational control of the facility.
Greenfield is currently performing a Remedial Action Optimization (RAO) Investigation at the site, to update the environmental conditions, including the extent of residual contamination, and determine what, if any, additional measures are needed beyond the previously implemented interim measures. There are currently 50 monitoring wells, 2 piezometers and 20 recovery wells included in the groundwater monitoring system at the facility. Recent investigations show shallow groundwater continues to be contaminated with facility-related chemicals at levels that could pose a threat to human health and the environment.
In 1981, EPA determined sediment sludge produced from treating wastewaters from creosote wood preserving processes is classified as a listed hazardous waste. When EPA implemented the federal hazardous waste laws under the Resource Conservation and Recovery Act (RCRA) in 1980, all existing facilities that treated, stored or disposed hazardous waste in a way that would require a hazardous waste permit were required to notify EPA and apply for the permit or close those operations. Because of the large number of existing facilities, Congress set up requirements that allowed these facilities to operate temporarily under “interim status”, 40 CFR Part 265, until it received its permit. The Kerr-McGee Kansas City facility was granted interim status. Kerr-McGee later decided to close the engineered surface impoundment, the only hazardous waste management unit operating at the facility. The Kansas City facility 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 hazardous waste remained in place after closure. The facility is also subject to corrective action because the interim status hazardous waste management unit was closed after the effective date of the federal Hazardous and Solid Waste Amendments.
Greenfield currently is performing post-closure and conducting corrective action activities at the site under a department-issued Missouri Hazardous Waste Management Facility Part I Permit, effective Feb. 4, 2020. The Part I Permit was originally issued with an EPA-issued Hazardous and Solid Waste Amendments Part II Permit in 1994. EPA decided not to reissue the Part II Permit in 2020, since EPA has no facility-specific conditions beyond those contained in the draft Part I Permit, and Missouri is fully authorized for all permitting, post-closure and corrective action activities at the facility. The final permit requires Greenfield to continue conducting long-term monitoring and maintenance activities for the closed regulated impoundment and corrective action investigation and remediation activities. The regulated until under the current permit consists of the closed engineered surface impoundment.