EPA ID# MOD043935048

MoDNR Contact: Tandi Edelman, 573-751-3553 or 800-361-4827
Facility Contact: Jim Vitatoe, 816-210-3566
Last Updated: Aug. 13, 2020

  • Former Company Name: Kansas City International Airport (MCI) Maintenance Base, American Airlines MCI Maintenance and Engineering Base, Trans World Airlines Inc., TWA Airlines LLC.
  • Type of Facility: Hazardous Waste Storage and Disposal - closing.
  • Wastes Handled: Aqueous wastes (treated wastewater).
  • Treatment and Disposal Methods: Land disposal - closed.
  • Location of hard copies of hazardous waste permit application, Part I and Part II Permits, modification requests, reports, etc. and supporting documents:
    • Missouri Department of Natural Resources, Elm Street Conference Center, Jefferson City, Missouri (Submit a Sunshine Request to review or obtain copies of the department’s files).).

Current Activities

Final Permit Issued: On Aug. 13, 2020, the department issued a final Missouri Hazardous Waste Management Facility Part I Permit for the MCI Maintenance and Engineering Base facility. Any parties adversely affected or aggrieved by the department’s decision to issue the final Part I Permit, or by specific conditions of the final Part I Permit, may be entitled to pursue an appeal before the Administrative Hearing Commission by filing a written petition by Sept. 14, 2020, as more fully described on page 5 of the final Part I Permit.

The City of Kansas City has been performing long-term monitoring and maintenanc activities and conducting corrective action investigation 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 the post-closure and corrective action activities is described below. On Feb. 25, 2020, the City of Kansas City submitted a permit application to the department and EPA Region 7 to renew and update their existing hazardous waste permits. 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 the MCI Maintenance and Engineering Base facility. The final permit requires the City of Kansas City to continue performing post-closure care for the closed surface impoundments and landfill, including groundwater monitoring, and corrective action activities at the site. The permit also contains contingent corrective-action conditions that may be exercised if there is a new release to the environment that requires corrective action or if the contaminated media pose a threat due to further migration.

EPA decided not to issue a Part II Permit, since EPA has no site-specific conditions for the facility, beyond those contained in the final 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 and supporting documents at the Mid-Continent Public Library’s Platte City Branch, 2702 N.W. Prairie View Road, Platte City, Missouri (during normal business hours) or the agency location above.

 

The MCI Maintenance and Engineering Base, formerly known as the Kansas City International Airport (MCI) Maintenance Base, is located at 9200 N.W. 112th St. in Kansas City, Missouri. The facility’s original structures were built in 1956, and originally covered about 250 acres leased from the City of Kansas City, Missouri. The facility is owned by the City of Kansas City and previously operated by American Airlines, formerly Trans World Airlines Inc. (TWA). American Airlines/TWA performed a variety of maintenance and overhauling activities on aircraft frames and engines at the site.

Due to the facility’s size and the variety of processes necessary to clean, service and repair various aircraft, facility operations produced a variety of hazardous wastes. Some areas at the facility were used to stage scrap metal and other scrap materials before being picked up by a metals salvage company. These scrap metals included lead-acid batteries and empty steel/plastic drums. EPA conducted an inspection in June 1985 and discovered that TWA was also operating two unpermitted, non-interim status hazardous waste surface impoundments. From 1972 through 1987, the facility used the two surface impoundments as a final step in treating wastewater produced during the maintenance activities. The impoundments treated approximately 400,000 gallons of wastewater per day. The main constituents of the wastewaters were hexavalent chromium, cyanide, oil and grease.

The facility also operated a hazardous waste landfill (Ravine Area) from the early 1960s through 1983, to dispose of a combination of excavated soils, construction debris, industrial waste materials (including spent degreasing solvents and sandblasting oxides) paint strippings and possibly wastewater treatment sludges. TWA, the City of Kansas City, Missouri, and other contractors involved in airport construction projects also used another landfill during the late 1960s-early 1970s, which is located on property owned by the City of Kansas City Missouri, but was not part of the facility’s leased property. The second landfill was used for about five years, mainly for construction debris, demolition waste and disposal of plating/petroleum sludges cleaned out from some lagoons at the site. No records of landfill activities were maintained for this area, so an accurate estimate of the types and quantities of materials disposed of in this area is not possible.

In 1989, EPA issued a 3008(h) Corrective Action Administrative Order on Consent, requiring the facility to conduct an investigation and take corrective measures for the site. Both surface impoundments and landfills have since been closed and capped with uncontaminated soil. EPA accepted the closure report and certification for the hazardous waste management units; however, because hazardous waste remained in place after closure, the areas are also required to go through a period of post-closure care.

The approved final remedy for soil and groundwater contamination is already in place at the facility, which includes a passive interceptor trench between the surface impoundments and Todd Creek. A groundwater monitoring program is used to determine where the contaminated groundwater is located (horizontal and vertical extent of contamination) and how fast the contaminated groundwater is moving (rate of migration) in addition to determining the effectiveness of the corrective action measures implemented at the site. Two Deed Restrictions were placed on parts of the property, one on the surface impoundments area and one for the Ravine Area, in order to inform potential future buyers of the property that these areas of the property have been used to manage hazardous waste and disturbance of the soil is restricted.

The monitoring programs were updated in August 2010, changing from a compliance monitoring to a corrective action monitoring program. The changes to the groundwater monitoring program also included reducing the sampling frequency from twice a year to once a year, changing the indicator parameters being analyzed and changing the number of wells included in the groundwater monitoring program.

TWA operated two unpermitted, non-interim status hazardous waste surface impoundments. On Sept. 29, 1989, TWA voluntarily entered into a 3008(h) Corrective Action Administrative Order on Consent with EPA, Docket No. VII-89-H-0043, because Missouri had not yet received final authorization for the corrective action portion of the federal hazardous waste law. In 1990, TWA closes the two surface impoundments and a landfill, the only hazardous waste management units operating at the facility. The facility is subject to the permitting requirements of the Missouri Hazardous Waste Management Law and federal Hazardous and Solid Waste Amendments to RCRA for long-term monitoring and maintenance activities (post-closure care) because hazardous waste remained in place after closure. The facility is also subject to the corrective action requirements because TWA completed the closure activities after the effective date of the federal Hazardous and Solid Waste Amendments.

On Aug. 7, 1998, 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. The City of Kansas City, as the current property owner, 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, effective Aug. 13, 2020. The Part I Permit was originally issued with an EPA-issued Hazardous and Solid Waste Amendments Part II Permit in 1998, and reissued in 2010. EPA decided not to reissue the Part II Permit in 2020, since EPA had no site-specific conditions for the facility, beyond those contained in the Part I Permit, and Missouri is fully authorized for all permitting, post-closure, corrective action and RAP activities at the facility. The permits require the City of Kansas City to continue performing long-term monitoring and maintenance of the closed surface impoundments and closed landfill and conduct corrective action investigations and remediation activities. The permits also require corrective action in the event there is a new release of hazardous waste to the environment or if the contaminated groundwater poses a threat due to further migration. The regulated units under the current permits consist of the closed surface impoundments and closed landfill.