Greenfield Environmental Multistate Trust LLC - Springfield
EPA ID# MOD007129406
MoDNR Contact: Nathan Kraus, PE,
573-751-3154 or 800-361-4827
Facility Contact: Lauri Gorton, PE, 414-732-4514
Last Updated: Dec. 4, 2019
- 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:
Draft Permit Prepared: On Nov. 26, 2019, the department prepared a draft Missouri Hazardous Waste Management Facility Part I Permit for the Greenfield Environmental Multistate Trust LLC’s Kansas City facility. The department invites the public to review and offer written comments on the draft Part I Permit until Jan. 10, 2020. The department is holding a public availability session and public meeting about the draft permit at 6 p.m., Thursday, Dec. 19, 2019, at The Foxhole, located at 2350 N. Clifton Ave. in Springfield, Missouri. The department will be available after the public meeting until 8 p.m. This is an opportunity for the public to ask questions, share information, and discuss issues with facility and department staff. If you require special services or accommodations in order to attend the meetings, you can make arrangements by contacting Theresa Doggett at least 72 hours before the meetings at 573-526-8962 or 800-361-4827 or by email. Hearing- and speech-impaired individuals may reach Doggett through Relay Missouri at 800-735-2966. During the public comment period, anyone can request a public meeting or public hearing about the draft permit. For more information, please contact Nathan Kraus, PE, by telephone at 573-751-3154 or 800-361-4827.
Greenfield currently is 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. On Aug. 6, 2012, Greenfield submitted a permit application to the department and EPA to renew and update the existing hazardous waste permits. After a thorough technical review of the permit application, the department prepared a draft Part I Permit for Greenfield’s Springfield facility. The draft permit proposes to require Greenfield to continue conducting post-closure care for the closed regulated impoundment and corrective action activities. 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. According to 40 CFR § 270.51(d), the existing Part II Permit will remain in effect until the department issues a new Part I Permit.
The public can review and copy paper copies of the complete permit application, draft Part I Permit and supporting documents at the Springfield-Greene County Library District’s The Library Station, 2535 N. Kansas Expressway, Springfield, Missouri (during normal business hours) or the agency locations above. Some documents are also available electronically on Greenfield Environmental's website. Comments on the draft permit are more effective if they point out legal or technical issues, or provide information that is not in the record. You may submit written comments on the draft permit online or by mail to Nathan Kraus, PE, Missouri Department of Natural Resources, Waste Management Program, P.O. Box 176, Jefferson City, MO 65102-0176.
Odor Reporting Form
Several residents previously expressed concerns to the department regarding offensive odors periodically in the air near the facility. The department is encouraging everyone who notices these odors to report them so the department and Greenfield Environmental can take steps to locate and address the odor source(s). You may report your odor concerns using the online odor reporting form or by calling Greenfield Environmental at 417-942-0190.
The Greenfield Environmental Multistate Trust LLC Springfield site is located on about 68 acres at 2800 W. High St. in Springfield. In 1907, American Creosote Corp. built and began operating a wood treating facility on the property. This facility was originally located in a rural area. The City of Springfield expanded over the years, with businesses and residential neighborhoods appearing around the facility. In 1965, 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. Kerr-McGee continued operating the wood treating facility until December 2003.
Both American Creosote and Kerr-McGee pressure treated railroad cross-ties, 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. The preservative was shipped to the facility by railcar and unloaded into one of four bulk storage tanks in the tank farm area. Untreated "green" lumber was shipped to the facility by either railcar or truck.
While operating, the facility was divided into an untreated wood storage area, process area and “black tie” storage area. Green lumber was sorted, cut to length and air dried for 8-12 months in the untreated wood storage area. Dried (seasoned) wood was loaded onto a tram cart and placed in one of two large high temperature-high pressure cylinders called retorts. The retort was sealed, filled with the preservative and then pressure was applied to force the preservative into the wood (modified “empty cell” process). 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 held on a drip track to allow for any creosote drippage (“kick-back”) from the treated wood. The drippage was collected and recycled back to the production process. The treated wood was then either loaded directly onto a railcar or truck for shipping or stored in the “black tie” storage area.
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 retorts. The steam condensate contained some lingering preservative from the retorts. American Creosote built a wastewater treatment system on the facility property, which consisted of an oil/water separator and a 2.5-acre lagoon. The original lagoon was built in 1908, and located near the southeast corner of the property. 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 lagoon 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 recycled back to the production process.
Around 1960, American Creosote expanded the lagoon system and built a 0.3-acre lagoon just north of the original lagoon. This lagoon (Lagoon 2) was a sedimentation lagoon, operated in series with the original lagoon. Wastewater effluent from the original lagoon flowed by gravity into Lagoon 2. Wastewater effluent from Lagoon 2 was either recycled back to the production process as cooling water or discharged to a small tertiary pond. It is presumed any overflow from the tertiary pond became part of the surrounding surface water drainage.
In 1973, Kerr-McGee closed the original lagoon and replaced it with a 0.9-acre (800,000-gallon) aeration lagoon (Lagoon 1), located just east of the original lagoon and south of Lagoon 2. In 1976, Kerr-McGee redesigned and expanded Lagoon 2 to approximately 0.6 acres (500,000 gallons) and installed new liners in Lagoons 1 and 2. Kerr-McGee also built a new 1-acre (650,000-gallon) lagoon (Lagoon 3) north of Lagoon 2. Lagoon 3 was operated in series with the two other lagoons. Wastewater from the oil/water separator was pumped to Lagoon 1, where organics were removed through aeration. The treated wastewater effluent flowed by gravity into Lagoon 2 through a concrete flume. Wastewater effluent from Lagoon 2 was either recycled back to the production process as cooling water or discharged to Lagoon 3. Lagoon 3 also collected storm water runoff from the facility. The combined wastewater in Lagoon 3 was discharged to the City of Springfield sewer and publicly-owned treatment works under a wastewater pre-treatment discharge permit with the City of Springfield.
In 1981, the U.S. Environmental Protection Agency (EPA) determined the lagoons 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 lagoons. Kerr-McGee decided to change their production process and close the lagoons. In 1987, Kerr-McGee installed a new cooling tower to replace using the lagoon system for cooling water. Kerr-McGee also upgraded the oil/water separators and storm water collection system, which replaced Lagoon 3. With the upgraded oil/water separators, Kerr-McGee was able to remove enough preservative from the wastewater so they were allowed to discharge the wastewater directly to the city sewer.
In 1988, Kerr-McGee also made several changes to the production process, designed to eliminate potential impacts to the environment. Kerr-McGee installed a concrete containment system in the tank farm area and replaced the drip track with an 18-inch thick, reinforced concrete drip pad. Kick-back drippage collected on the pad was routed to the production process oil/water separators to recover the excess preservative. As part of the tank farm changes and drip pad installation, all pipes were brought above ground and a concrete floor was installed within the existing concrete dikes (walls) to contain any major spills. A new overhead tank car unloading station was also installed to eliminate the potential for catastrophic spills associated with unloading a tank car from the bottom.
During 2001, Kerr-McGee went through a corporate restructuring and transferred the Springfield 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. Active wood treating operations at the facility stopped in December 2003, and Kerr-McGee decommissioned the wood preparation and treatment equipment in 2004. All buildings related to the wood treating operations were demolished with the exception of the maintenance building, large groundwater storage tank and administrative office.
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 Springfield 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 Springfield facility is currently inactive, except for ongoing post-closure and corrective action activities.
In early 1972, Vich Spring, a spring located northeast of the facility, began discharging a dense black substance after moderate to heavy rainfall. EPA sampled both Vich Spring and water and sediment from the Kerr-McGee lagoons. Creosol, a component of creosote, was confirmed in samples from both locations. No corrective measures were taken because the creosote source, and how the creosote traveled from the facility to the spring, was not established. There were also no applicable federal laws that regulated hazardous waste management in existence at that time.
In 1973, Kerr-McGee closed the original lagoon shortly after completing Lagoon 1, and before the federal hazardous waste laws and regulations existed. The lagoon closure included pumping the wastewater to the other lagoons and mixing the bottom sediment sludge with straw and sawdust. The bottom sediment sludge and most of the clearly contaminated soil was removed and stored on facility property in an above ground diked area. The excavated area was backfilled with unimpacted soil from the property.
In 1976, Kerr-McGee encountered continuously wet spots in the basin floor of Lagoon 3 during its construction. In order to lower the local water table, water was pumped from a trench excavated to bedrock just north of Lagoon 2. Kerr-McGee contacted EPA after oil was discovered seeping into the trench below ground level. Kerr-McGee extended the trench to 300 feet long and pumped the water out daily to a creosote reclamation tank. The oil-water mixture was processed through the oil/water separator. The water was discharged to Lagoon 1 and the oil was recycled back into the plant process. The trench was changed to a recovery trench and a pre-cast concrete manhole was installed so the oil-water mixture could still be removed.
Congress passed the Resource Conservation and Recovery Act (RCRA) in 1976, which is the federal law governing hazardous waste management. EPA conducted a groundwater contamination abatement investigation at the facility to evaluate the oil in the trench and determine if there was a connection between Vich Spring and releases originating on the facility property. Sample results showed aromatic hydrocarbons and coal tar derivatives in Vich Spring. The investigation concluded the oil was coming from leaks in the bottom of Lagoon 2. Kerr-McGee redesigned Lagoon 2 and installed new liners in Lagoons 1 and 2. The bottom sediment sludge, which contained a large amount of oil, was mixed with straw and stored on the west side of the facility property in an above ground diked area.
In 1979, Kerr-McGee submitted an operational plan to the Missouri Department of Natural Resources for an experimental land treatment unit to treat creosote-contaminated soil through biological landfarming. The department approved the plan to treat the bottom sediment sludge from the original lagoon in a one-acre landfarm in the northwest corner of the facility property. The landfarm was divided into three experimental plots, which were routinely disked and sampled. One plot was a background plot, where no waste was disposed. The two remaining plots evaluated various application rates of both waste and nutrients. Kerr-McGee applied the sludge yearly from 1979 to 1981.
In 1981, Kerr-McGee installed a groundwater monitoring system and began a groundwater quality assessment, as required by the federal RCRA regulations. The 1984 Groundwater Quality Assessment Plan results indicated there was a black, oily substance in some of the monitoring wells, related to past facility operations. According to the Hazardous and Solid Waste Amendments that Congress passed in 1984, 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.
In October 1984, the department issued an Order to Abate Violations, Order No. HW-84-015, requiring Kerr-McGee to develop a multi-phase groundwater assessment program. The department approved Kerr-McGee’s program in April 1985, which included installing monitoring wells and excavating two inspection trenches. In June 1985, Kerr-McGee installed a 200-foot long inspection trench between Lagoons 2 and 3, which revealed an irregular bedrock surface with creosote oil collecting in low areas. In October 1985, Kerr-McGee installed a 400-foot long inspection trench north of Lagoon 3, that wrapped inside the northeast corner of the facility property boundary. The 1986 Groundwater Corrective Action: Groundwater Quality Assessment Report indicated there were two groundwater contamination plumes; one in the shallow groundwater under the lagoons and the second in a deeper groundwater aquifer under the process area. The inspection trench north of Lagoon 3 was changed to a recovery trench to catch the contaminated groundwater. All collected groundwater was pumped back to the production process through the oil/water separator, treated and discharged to the City of Springfield sewer system.
Under RCRA, the three wastewater lagoons were designated as interim status hazardous waste management storage units. In February 1985, Kerr-McGee submitted a closure plan to the department for the three lagoons, which the department approved in 1986. Active closure of the lagoons began in 1987, and included pumping the wastewater back to the production process through the oil/water separator, treating and discharging to the City of Springfield sewer system. The bottom sediment sludge was processed through a creosote recovery system, which resulted in about 17,000 gallons of creosote recycled back to the production process. Non-recoverable creosote sludge, contaminated soil and piping were removed and disposed off-property at a permitted hazardous waste disposal facility. The excavated lagoons were backfilled with clean soil and covered with clay caps, topsoil and vegetation. A Deed Notice, filed with the Greene County Recorder of Deeds on Sept. 30, 1988, was placed in the property chain-of-title in order to inform potential future buyers of the property that the former lagoon area was used to manage hazardous waste. The department accepted Kerr-McGee’s closure certification for the lagoons in September 1989.
The landfarm was designated as a RCRA interim status hazardous waste treatment unit. Since the creosote in the landfarm did not completely break down to non-hazardous levels, Kerr-McGee submitted a closure plan for the landfarm to the department in July 1989, which the department approved in September 1989. Closure included grading the plots within the 12-inch dikes surrounding the landfarm and covering with vegetation. A Deed Notice, file with the Greene County Recorder of Deeds on March 9, 1990, was placed in the property chain-of-title in order to inform potential future buyers of the property that the former landfarm area was used to manage hazardous waste. The department accepted Kerr-McGee’s closure certification for the landfarm in March 1991.
Because hazardous waste remained in place after closing the former lagoon and landfarm areas, these areas are required to go through a period of post-closure care. As part of the post-closure care, the facility is required to operate and maintain a groundwater monitoring system, as well as inspect and maintain the covers over the closed lagoons and landfarm.
On Oct. 18, 1987, Kerr-McGee entered into a RCRA 3008(a) Consent Order with EPA, Docket No. 87-H-0004, in response to previous groundwater assessments and investigation results and the potential for contaminants to move to the northeast, beyond the facility property boundaries. The Order specified actions to define the nature, migration rate and extent of contamination. On Nov. 17, 1988, Kerr-McGee entered into a 3008(h) Corrective Action Order on Consent with EPA, Docket No. 7-88-H-0019, because Missouri had not yet received final EPA authorization to carry out its corrective action program in place of the federal RCRA corrective action program. This Order specified that Kerr-McGee undertake a program to design, build and operate corrective action technologies to clean up contaminated groundwater originating from the facility. As part of this program, Kerr-McGee was to submit a report about current conditions and activities at the facility.
In 1989, Kerr-McGee submitted a Description of Current Conditions Report, or DCCR, to EPA as required by the Orders. The report presented all environmental sampling and investigations, interim measures and unit closures conducted up to that point. As required by the Orders, Kerr-McGee also performed a RCRA Facility Investigation to define the extent of any contamination both on and off the facility property. On behalf of Kerr-McGee, James L. Grant and Associates Inc. submitted a RCRA Facility Investigation Report to EPA in July 1992. The sample results showed soil and groundwater on the facility property and groundwater in some off-facility property areas were contaminated with creosote constituents. The report identified the contaminant sources as the process area, storage tank area, drip track, the original lagoon and the area where sludge from the original lagoon was temporarily stored after closure. The shallow groundwater contamination plume extended northeast and south, off the facility property. The deeper groundwater contamination plume did not extend off facility property. Contaminated sediments in the Clifton drainage, between Clifton St. and Kearney Ave., were thought to be partly related to past facility operations. Based on these results, the investigation concluded there was enough data to begin evaluating possible corrective action, or cleanup, activities.
At EPA’s request, Kerr-McGee performed a Corrective Measures Study to identify and evaluate possible remedial alternatives for the soil and groundwater contamination. During this time, Kerr-McGee also performed interim measures 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. Interim measures are usually implemented while a facility evaluates possible corrective measures to be taken as a final remedy. As an interim measure, Kerr-McGee changed the surface water drainage pattern near the closed lagoons, removed contaminated soil from the production process areas and installed contaminated groundwater extraction wells in the production process areas and along the northern edge of the original lagoon.
On behalf of Kerr-McGee, James L. Grant and Associates Inc. submitted a Corrective Measures Study Report to EPA in July 1993. The report included Kerr-McGee’s proposed final remedy along with other remedial alternatives. EPA, in coordination with the department, selected the best remedy given known facility-specific environmental conditions at that time. EPA prepared a Statement of Basis that summarized the remedial alternatives and EPA’s basis of support for the proposed final remedy. In August 2002, after the opportunity for public comment, EPA, in coordination with the department, approved the proposed final remedy and issued a Final Remedy Decision. In addition to the interim measures already put in place, the approved final remedy included continued groundwater and surface water monitoring and property activity and use limitations. In September 2002, the department and EPA included the approved final remedy, along with the post-closure requirements for the closed lagoons and landfarm, in Kerr-McGee’s hazardous waste permits. These permits replaced the EPA Orders. Kerr-McGee was required to sample the groundwater twice a year as part of their groundwater monitoring program. This monitoring program was used to make sure the extent of groundwater contamination and the migration rate remained defined, in addition to determining whether the approved final remedy was effective. Contaminated groundwater recovered from the wells and trenches was processed through the oil/water separator, treated and discharged to the City of Springfield sewer system. Recovered preservative was recycled back to the production process until production operations at the facility stopped in 2003. Since then, recovered preservative is stored on-site in a holding tank and then shipped off facility property for reuse in wood treating operations at other locations.
In late 2004, after a heavy rainfall, the City of Springfield notified the department that possible creosote-like material was coming from Woodlawn Spring, a newly-formed spring to the west of Vich Spring and next to the Golden Hills residential subdivision, located north of the facility. During a site visit in January 2005, the department, City of Springfield and Tronox (formerly Kerr-McGee) staff observed a surface water sheen with organic odor coming from a seep on the bank of a drainage ditch in the subdivision. At the department’s request, Tronox investigated the subdivision’s storm water detention basin and a nearby pasture area and sampled yards in the residential area. On behalf of Kerr-McGee, ENSR Corp. submitted the Woodlawn Spring Study Area Investigation Report to the department and EPA in March 2006, with revisions in 2007. All sample results from residential yards indicated there were no health concerns. Chemical fingerprinting of the Woodlawn Spring discharge indicated a mix of contaminants coming from several sources, including weathered creosote, oil tar and residual oil. Areas where weathered creosote was found in sediment were underground or enclosed by a fence. Oil tar in the pasture area and residual oil contamination in Vich Spring sediment were determined to be from sources other than the facility.
Tronox continued monitoring the Woodlawn Spring discharge area until 2009, when Tronox filed for Chapter 11 bankruptcy. In 2011, Greenfield Environmental, as the Permittee, took control of all corrective action activities. From 2011 through 2014, Greenfield Environmental continued operating the groundwater recovery system and performing the required post-closure care of the facility with limited funds initially provided by the Tronox bankruptcy settlement. During this time, the federal court ruled in Tronox’s favor in a fraudulent conveyance lawsuit filed by Tronox against Anadarko Petroleum Corp., the parent company of Kerr-McGee. The lawsuit stemmed from the 2006 spinoff. Following the final settlement agreement in 2015, additional funds became available for Greenfield Environmental to maintain and enhance the previously-selected final remedy, complete additional corrective action investigation work and position the facility for redevelopment. Greenfield Environmental reports directly to its two facility beneficiaries - the United States and the State of Missouri, represented by EPA and the department.
Greenfield Environmental is currently performing a Remedial Action Optimization Investigation to update the environmental conditions, including the extent of residual contamination, and determine whether additional corrective measures are needed to protect human health and the environment. Greenfield Environmental updated the groundwater recovery system by installing a new line from the northeast corner of the facility to the on-property groundwater treatment plant and completed Phase 1 of the investigation in 2016. There are currently 47 monitoring wells on the facility property and 26 monitoring wells off the facility property. Sample results from several monitoring wells in the City of Springfield right-of-way and neighboring properties northeast of the facility showed shallow groundwater is contaminated with facility-related chemicals at levels indicating vapor intrusion was possible in nearby residences. Vapor intrusion refers to the chemical gases coming from contaminated soil or groundwater, moving through the air spaces between the soil particles and entering homes or other buildings through foundation cracks, sumps or drainage systems. This process is similar to the way naturally-occurring radon gas can enter a home.
In December 2016, Greenfield Environmental began a vapor intrusion investigation. Soil vapor, groundwater and sewer gas samples were collected both on and off the facility property. In July and August 2017, indoor air, outdoor air and sub-slab/crawl space samples were collected at a few selected residences northeast of the facility. Naphthalene, the main chemical of concern in air that could be related to contamination at the facility, was found above the action level in indoor air in all homes that were sampled. However, initial sample results indicated vapor intrusion into homes was not occurring from the sub-slab/crawl space. The naphthalene detected in the outdoor air was a likely source of the naphthalene levels in the indoor air. Elevated benzene, toluene, ethylbenzene, xylene and naphthalene levels were also found in certain sewer gas samples in the same neighborhood. The concentrations in sewer gas sampled at the facility were much lower than what was found in the sewer lines downstream of the facility, where other sources could discharge into the City of Springfield sewer system. In December 2017, CH2M, on behalf of Greenfield Environmental, performed confirmatory indoor air sampling and additional investigation into the outdoor naphthalene levels. The Vapor Intrusion investigation will continue until fall 2018 or later.
Kerr-McGee operated the lagoons and landfarm 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 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” until they received their permit or completed clean closure of their regulated hazardous waste management units. Kerr-McGee decided to change their production process and close the units. Kerr-McGee 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 contaminants were released to groundwater from the regulated hazardous waste management units, so these units were unable to achieve “clean” closure. Kerr-McGee is also subject to corrective action for other releases to the environment at the facility because they completed closure of the interim status hazardous waste management units after the effective date of the federal Hazardous and Solid Waste Amendments to RCRA.
From 1987 to 2002, Kerr-McGee performed corrective action activities at the facility under two Orders with EPA, because Missouri had not yet received final EPA authorization for its RCRA-equivalent corrective action program. Greenfield Environmental is currently performing long-term monitoring and maintenance activities and conducting corrective action investigations and remediation activities at the facility under two hazardous waste permits, which replaced the EPA Orders. The department issued a Missouri Hazardous Waste Management Facility Part I Permit. EPA issued a Hazardous and Solid Waste Amendments Part II Permit. Both permits were effective Sept. 25, 2002. These permits required Kerr-McGee, now Greenfield Environmental, to continue performing long-term monitoring and maintenance of the closed lagoon and landfarm areas and operating the groundwater recovery and treatment systems. These permits also transferred regulatory oversight responsibility for the ongoing investigation and corrective action activities from EPA to the department. EPA terminated their 3008(h) Order on Sept. 12, 2003.
On Aug. 6, 2012, Greenfield Environmental, as the new property owner and operator, submitted a permit application to the department and EPA, to renew the existing hazardous waste permits. Since all interim status hazardous waste management units are closed and the facility is no longer operating as a woodtreating facility, the permit application was for post-closure and corrective action only. The existing hazardous waste permits, which expired Sept. 25, 2012, were continued in effect, as allowed by Code of State Regulations 10 CSR 25-7.270(1) and Code of Federal Regulations40 CFR § 270.5, until the department and EPA issue or deny new hazardous waste permits. After a thorough technical review of the permit application, the department prepared a draft Part I Permit for the Greenfield Environmental Multistate Trust LLC’s Kansas City facility, which proposes to require Greenfield to continue conducting post-closure care for the closed regulated impoundment and corrective action activities. The department invites the public to review and offer written comments on the draft Part I Permit during a 45-day public comment period, which began Nov. 25, 2019, and ends Jan. 10, 2020. A public meeting will be held Dec. 19, 2019.
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. According to 40 CFR § 270.51(d), the existing Part II Permit will remain in effect until the department issues a new Part I Permit.