Bannister Complex

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 its 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 Outfall 002, later renamed the Abandoned Indian Creak Outfall. Despite cleanup 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 PCB release occurred in 1971, outside Department 26. About 1,100 gallons of PCBs were released to the ground near a stormwater 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 contamination source 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 size and location of the contaminated groundwater plume. 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.

In 1986, DOE submitted a RCRA closure plan to EPA for the underground tank farm. 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.

DOE submitted a RCRA closure plan to EPA for the south lagoon in 1987. During the same timeframe as the underground tank farm closure, 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 three 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. 

During the late 1980s, DOE also 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.  

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. 

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. 

Up to this point, DOE was performing post-closure, corrective action and long-term stewardship activities for the Kansas City Plant under RCRA, first under an Order with EPA, which was later replaced by department and EPA-issued hazardous waste permits. GSA was performing environmental investigation and cleanup activities on its portion of the federal complex under CERCLA, with EPA providing regulatory oversight. For information about GSA’s cleanup efforts under CERCLA, visit EPA's Bannister Federal Complex webpage.

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. Having the entire federal complex under the same environmental law (RCRA) and the same permits allowed the environmental investigations to be better coordinated and sped up the corrective action process. The U.S. Army Corps of Engineers is performing the environmental investigation and cleanup of the closed landfill under the Formerly Used Defense Sites (FUDS) program, with the department providing regulatory oversight. For information about this cleanup effort, visit the department's Former Bannister Federal Complex webpage. 

Beginning in 2013, DOE/NNSA and Honeywell FM&T moved its operations to a new plant and vacated the facility. By 2016, GSA also vacated the facility, moving its Region 6 headquarters to downtown Kansas City. 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 former 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. 

In 2016, a private developer, CenterPoint Properties, also performed several “due diligence” activities at the former 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 former federal complex west of the railroad tracks, plus 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. CenterPoint was succeeded by Bannister Transformation & Development LLC (BT&D).

Anticipating BT&D 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 former 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. 

BT&D is in the process of redeveloping the property west of the railroad tracks. BT&D continues to implement the final remedy for that part of the property, as outlined in the 2017 permit modification. Fifty three buildings have been demolished and removed at the site, totaling 3,675,809 square feet of manufacturing, office and warehouse space. BT&D implemented a risk-based soil excavation program and constructed several engineered controls, including three subsurface barrier walls, engineered caps over numerous solid waste management units and a new groundwater control system across the site. The department and BT&D executed an enforceable Environmental Covenant for the permitted property west of the railroad tracks. An Environmental Covenant is a clause listed in the property chain-of-title that notifies, in perpetuity, any potential buyer of the environmental conditions of the property. Covenants also place certain activity and use limitations on the property. BT&D filed the Environmental Covenant with the Jackson County Recorder of Deeds on June 25, 2020, and provided proof of the filing to the department. The covenant restricts the facility property to industrial, warehouse and commercial uses and prohibits groundwater use. For information about the "due diligence" activities and demolition and environmental work performed on BT&D-owned areas, visit BT&D's Bannister Transformation & Development LLC webpage.

By fall 2020, department staff submitted finalized Ready for Anticipated Use (RAU) forms for 3 separate phases on the BT&D property, totaling over 86% of the total BT&D portion of the site. An RAU determination means that area of the property has met cleanup requirements and is ready for redevelopment. Three permit modifications were approved for land transfers, to change operational control and ownership of approximately 188 acres of the permitted property to NP Bannister Industrial LLC and NP Bannister Land Holdings LLC for redevelopment. These properties will remain subject to the Environmental Covenant. All new buildings will be constructed with engineered foundation systems to mitigate vapor intrusion. Long-term operation, monitoring and maintenance will continue. 

As of January 2021, 194.3 acres of the 225-acre BT&D property have met cleanup requirements and are ready for redevelopment. NP Bannister Industrial plans to continue to take ownership of the various phases of the property and facilitate redevelopment. The proposed concept plan for the future of the site is a modern industrial site with seven buildings, ranging from approximately 244,000 square feet to 433,000 square feet. NP Bannister Industrial began construction of Future Building 1 in fall 2020.  Once the property is transformed into its new intended use, it is expected to create more than 1,500 permanent jobs and new economic growth for the surrounding community. The redevelopment phase for the BT&D-owned areas of the property is anticipated to be complete by 2023.