Last Updated
Facility Physical Address

1500-2012 E. Bannister Road
Kansas City, MO 64131
United States

County
Jackson
EPA ID
MO9890010524
MoDNR Contact Name
Bryce Bobbitt
MoDNR Contact Phone
MoDNR Contact toll free number:
MoDNR Contact Email
EPA Contact Name
Robert E. Aston Jr., RG
EPA Contact Phone
EPA Contact Email
Facility Contact(s)
Company
U.S. Department of Energy
Facility Contact Name
Sybil Chandler
Facility Contact Phone Number
Company
U.S. General Services Administration
Facility Contact Name
Eric Gorman
Facility Contact Phone Number
Company
Bannister Transformation & Development LLC
Facility Contact Name
Kevin Breslin
Facility Contact Phone Number

Permanent Hard Copy Location(s)

Location of hard copies of regulatory mechanism(s) and any modifications, reports and other supporting documents.

Missouri Department of Natural Resources, Elm Street Conference Center, Jefferson City, MO 65102 (Submit a Sunshine Law Request to review or obtain copies of the department's files.)

U.S. Environmental Protection Agency, Information Resource Center, 11201 Renner Blvd., Lenexa, Kansas (Call 913-551-7241 to schedule an appointment)

    Background/ History

    The Bannister Complex, formerly the Bannister Federal Complex, is located on about 309 acres at 1500-2012 E. Bannister Road in Kansas City, Missouri. From 1942 until November 2017, the property was a federal government-owned, contractor-operated military installation. From 1942 to 1963, the complex was owned by the Defense Plant Corp., Reconstruction Finance Corp. and the U.S. Department of Navy. The U.S. Navy built the main manufacturing building in 1942. Pratt and Whitney Corp. used the main manufacturing building from 1943 to 1945 to build aircraft engines for the Navy in support of World War II. From 1948 until 1961, Westinghouse Electric Co. built jet engines in the main manufacturing building for the U.S. Navy in support of the conflict in Korea. In 1949, Bendix Corp. subleased part of the building to manufacture non-nuclear components of nuclear weapons for the Atomic Energy Commission (AEC). Bendix merged with Allied Corp., who merged with Signal Corp. and became Allied Signal Inc., who later acquired Honeywell Federal Manufacturing & Technologies LLC. Honeywell was the last operator of what was formerly known as the Kansas City Plant. The AEC was abolished in 1974. In 1975, the Energy Research and Development Administration was created and took custody of the Kansas City Plant until it became part of the U.S. Department of Energy (DOE), which was created in 1977.

    By the late 1970s, the complex was owned by two federal agencies: DOE and the U.S. General Services Administration (GSA). DOE owned the Kansas City Plant, which occupied 136 acres west of the Union Pacific railroad tracks, which run north and south across the property. GSA owned the remaining 164 acres. In 2000, DOE created the National Nuclear Security Administration (NNSA), which became the owner of the Kansas City Plant. The Kansas City Plant continued to manufacture electrical, mechanical, plastic and other non-nuclear components of nuclear weapons at the site. GSA operated a warehouse and its Region 6 administrative headquarters in the western part of the building from the early 1960’s until 2014. 

    Under the federal Resource Conservation and Recovery Act (RCRA), the site is considered a closed hazardous waste storage and disposal facility. From 1942 to 1964, government contractors operated a U.S. Department of Defense landfill on part of the property east of the railroad tracks, as a disposal site for the Bannister Complex. Volatiles have been confirmed in the groundwater at the landfill. On part of the property west of the railroad tracks, the Kansas City Plant operated three hazardous waste management units (two lagoons and an underground tank farm) under the “interim status” portions of RCRA. Releases from the underground tank farm, a trichloroethylene reclamation facility, a plating building and other industrial practices resulted in soil and groundwater contamination. The main contaminants of concern are volatile organic compounds and polychlorinated biphenyls (PCBs).

    Cleanup Summary

    DOE closed the two lagoons and tank farm in the 1980’s, with waste in place. A Deed Notice, signed by the Jackson County Recorder of Deed, was placed on the property in order to inform potential future buyers of the property that portions of the land have been used to manage hazardous waste. The department accepted DOE’s closure report and certification for the hazardous waste management units; however, the site 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. As part of the post-closure care, DOE was required to monitor the groundwater and inspect and, if necessary, repair the clay caps. The facility is also subject to corrective action requirements because DOE completed the closure activities after the effective date of the federal Hazardous and Solid Waste Amendments.  

    From 1989 to 1999, DOE performed corrective action activities for the Kansas City Plant under a 3008(h) Corrective Action Administrative Order on Consent with the U.S. Environmental Protection Agency (EPA). The Order was later replaced by two hazardous waste permits, both effective Oct. 6, 1999. The department issued a Missouri Hazardous Waste Management Facility Part I Permit. EPA issued a Hazardous and Solid Waste Amendments Part II Permit. The permits required DOE to conduct post-closure and corrective action activities at the Kansas City Plant. DOE/NNSA was in the final remedy stage for all contaminated areas under its responsibility, until DOE and GSA requested that DOE’s permits be modified to include the GSA-owned portion of the Bannister Complex. Two additional areas were identified on GSA portion, the Former Landfill and Building 50, which was previously used for manufacturing.

    In 2013 and 2014 respectively, DOE/NNSA and GSA moved its operations to new facilities. In November 2017, Bannister Transformation & Development LLC (BT&D) took ownership of approximately 225-acre areas of the complex west of the railroad tracks that run north to south through the property, plus two acres off-site of the main complex. GSA retained ownership of the remaining 82 acres of the site east of the railroad tracks, including the closed landfill. The U.S. Army Corps of Engineers (USACE) is performing the environmental investigation and cleanup of the landfill under the Formerly Used Defense Sites Program, with the department's Environmental Remediation Program, Federal Facilities Section providing regulatory oversight. For more information about that portion of the site, visit the department's Former Bannister Federal Complex webpage. The department's Waste Management Program, Engineering Section is providing regulatory oversight for the cleanup and redevelopment activities for the rest of the property. BT&D is in the process of redeveloping its portion of the Bannister Complex. All former buildings west of the railroad tracks have been removed and a new building was constructed to house the on-site wastewater pretreatment facility. Several engineered controls were constructed and a new groundwater control system was put in place across the site. The site has been regraded, new utilities installed and is ready for reuse and development. BT&D and GSA are the current “permittees” under the properties hazardous waste permits. An Environmental Covenant was executed for BT&D's portion of the property, restricting the property to industrial, warehouse and commercial uses and prohibiting groundwater use. The redevelopment phase is expected to be complete by 2023.

    Ariel view of the former main manufacturing building at the Bannister Complex.
    An aerial view of the Bannister Federal Complex when under DOE/NNSA operation.

    The Bannister Complex, formerly the Bannister Federal Complex, is located on about 307 acres at 1500-2012 E. Bannister Road in Kansas City, Missouri, about 10 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. For a brief period in the early 1920’s, the land was home to an automobile race track. From 1942 until November 2017, the property was a federal government-owned, contractor-operated military installation. 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 east of the Union Pacific railroad tracks, which run north and south across the property. The landfill was 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 1945, 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 December 1947, the main manufacturing building was transferred to the Department of the Navy. From 1949 to 1961, the Department of the Navy leased part of the building to Westinghouse Electric Co. to build aircraft engines for the U.S. Navy in support of the conflict in Korea. In 1949, Westinghouse subleased a large 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 federal complex became known as the Kansas City Plant and covered about 136 acres of the 307-acre federal complex. Beginning in February 1951, 12-inch long uranium fuel slugs were produced from 10-foot long uranium rod stock. Forty-five thousand slugs were produced from 313,070 pounds of feedstock during a 22-month period. These fuel slugs were made to supply the Savannah River Site in South Carolina and Argonne National Laboratory. 

    In 1961, Westinghouse’s lease was cancelled and that part of the building was transferred to the U.S. General Services Administration (GSA). GSA manages government assets, including government-owned and leased buildings. In 1962, most of the federal complex was transferred to GSA with the agreement that Bendix would continue to operate the Kansas City Plant in its part of the main manufacturing building. GSA operated a warehouse and its Region 6 administrative headquarters in the western part of the building. The landfill was closed in 1964, and that portion of the property was also transferred to GSA. The Atomic Energy 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 took custody and control of the Kansas City Plant and ownership of that part of the main manufacturing building. Bendix continued to operate the Kansas City Plant throughout the ownership transitions.  

    In 1983, Bendix merged with Allied Corp., who later merged with Signal Corp. and became Allied Signal Inc. In 1999, Allied Signal merged with Honeywell Corp. and adopted the name Honeywell Federal Manufacturing & Technologies LLC. 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. 

    In addition to airplane engine manufacturing, the Kansas City Plant has been used to manufacture electrical, mechanical, plastic and other non-nuclear components of nuclear weapons. This work involved machining, plastic fabrication, plating and electrical and mechanical assembly. The Kansas City Plant 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 the property until shipped off-property.

    A variety of hazardous wastes, such as acids, alkalines, solvents, acid- and alkaline-contaminated solid waste, solid debris waste, waste oil, wastewater treatment sludges and toxic metals, were also produced as part of the plant operations. The hazardous waste was stored on-site in containers and tanks in six hazardous waste container storage areas, three contingent storage areas and an underground tank farm. The underground tank farm was installed in 1943, and consisted of 28 tanks and associated underground piping. Twenty-two of the tanks were constructed of steel and the remaining six were concrete. The tanks were used to store solvents, fuels and coolants, which were supplied by nine unloading stations that piped liquids to the tanks through a pump house. The hazardous wastes 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 originally used an industrial wastewater system to carry process wastewater to two lagoons located in the northeast corner of the federal complex. The process wastewater included rinse waters, drained water from various operating areas and treated cooling waters. The north lagoon was built in 1962, with the purpose of monitoring the pH until it was within limits to be discharged. If the pH was outside the range, the discharge was recirculated until it fell within the required limits. Effluent from the north lagoon was originally discharged directly into the Blue River. In 1967, state regulations prohibited discharging process wastewaters into rivers. The north lagoon effluent was rerouted, combined with sanitary sewage and monitored for pH levels before being discharged to Kansas City’s sanitary sewer system and publicly owned treatment works. The south lagoon was built in 1975, to handle additional flow when other plant wastewaters were required to be rerouted to the north lagoon. 

    DOE replaced both lagoons with an industrial wastewater pretreatment facility in 1988. This system treated all process related wastewater generated by production operations at the plant. Part of the wastewater was treated with reverse osmosis and recycled as cooling tower make-up water. By doing this, the plant could avoid using drinking water as cooling water and discharge less wastewater to the sanitary sewer system. 

    Beginning in 2013, DOE/NNSA and Honeywell FM&T moved its operations to a new plant, the National Security Campus, located about eight miles south of the federal complex on Botts Road. By 2016, GSA moved its operations to downtown Kansas City on Main St. At that time the federal complex was owned by both DOE/NNSA and GSA. DOE/NNSA owned the Kansas City Plant and GSA owned the remaining portions of the federal complex. After relocating, DOE/NNSA and GSA selected a private developer to redevelop approximately 225-acre areas of the federal complex west of the Union Pacific railroad tracks, plus two acres off-site of the main complex, totaling about 227 acres. In November 2017, Bannister Transformation & Development LLC (BT&D) took ownership of the 225 acres of the federal complex. GSA owns the remaining 82 acres of the federal complex east of the railroad tracks, including the closed landfill. The U.S. Marine Corps are the only tenants at the federal complex on the GSA-owned portion of the property, under a long-term lease for the former Internal Revenue Service building. 

    BT&D is in the process of redeveloping their portion of the Bannister Complex. All former buildings west of the railroad tracks have been removed and a new building was constructed to house the on-site wastewater pretreatment facility. Several engineered controls were constructed and a new groundwater control system was put in place across the site. The site has been regraded, new utilities installed and is ready for reuse and development. The redevelopment phase is expected to be complete by 2023.

    Backside of a building demolition during site cleanup and redevelopment.
    One of many buildings on the former federal complex property demolished during property redevelopment.

    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.

    When the U.S. Environmental Protection Agency (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 C.F.R. Part 265, until it received its permit. DOE was granted interim status for three hazardous waste management units (two lagoons and an underground tank farm). DOE operated the Kansas City Plant's six hazardous waste container storage areas and three contingent storage areas under hazardous waste generator storage requirements. 

    DOE decided not to continue the hazardous waste permitting process for active hazardous waste management and to close the lagoons and underground tank farm. The Kansas City Plant 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 contaminants were released to groundwater from the regulated hazardous waste management units, so these units were unable to be “clean closed”. The Kansas City Plant is also subject to the corrective action requirements because DOE completed the closure activities after the effective date of the federal Hazardous and Solid Waste Amendments.

    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, because Missouri had not yet received final authorization for the corrective action portion of the federal hazardous waste law. On Oct. 6, 1999, 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. These permits require long-term monitoring and maintenance of the two closed lagoons and closed underground tank farm, as well as operating, maintaining and monitoring all corrective action final remedies for the Kansas City Plant. The approved final remedy for the 95th Terrace site was added on Sept. 29, 2006, through a department-initiated Part I permit modification.

    On Aug. 24, 2012, the GSA-owned portions of the federal complex were added to the permits and GSA was added as a permittee, through a  Part I Class 3 permit modification and Part II Class 3 permit modification. The modification also required further environmental investigation, monitoring, risk-assessment and, if necessary, additional cleanup at the federal complex. The contingent final remedy for the area of the former federal complex west of the railroad tracks was added on July 14, 2017, through a contingent department-initiated Part I permit modification. These changes became effective Jan. 22, 2018, after the property was transferred to BT&D through an additional permit modification for change of ownership. Based on the corrective action completed by BT&D since that permit modification, no further corrective action is deemed necessary for the solid waste management units located on the BT&D portion of the former federal complex.

    The existing hazardous waste permits for the federal complex expired Oct. 6, 2009. DOE submitted a timely permit application on April 7, 2009, to renew the 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 were continued in effect, as allowed by Code of State Regulations 10 CSR 25-7.270(1) and Code of Federal Regulations 40 C.F.R. § 270.51, until the department and EPA issue or deny new hazardous waste permits. The department is currently reviewing the permit application.

    Listed below are the currently effective regulatory mechanism(s) and any modifications, institutional controls and any supporting documents regarding this property that the department currently has available in electronic form. The department realizes some of the electronic files can be quite large, which may result in long download times for individuals with slow internet connections. If you have any problems accessing these documents, please contact the department’s Waste Management Program by telephone at 573-751-5401 or 800-361-4827, or by email at wmp@dnr.mo.gov.

    BT&D has made its "due diligence", demolition and other environmental reports available in electronic form on its website, Bannister Transformation & Development LLC. You can review printed copies of all regulatory agreements, reports and other supporting documents at the department’s Elm Street Conference Center in Jefferson City, Missouri. To review or obtain copies of the department’s files, please submit a Sunshine Law Request.

    Regulatory Agreement

    Regulatory Agreements Regulatory Agreement Note

    Part I

    Effective Date:

    Expiration Date:

    Last Modified Date:

    Modification Effective Date:

    Part II

    Effective Date:

    Expiration Date:

    Last Modified Date:

    Modification Effective Date:

    *The permits have been continued according to 40 C,F,R, § 270.51. A complete permit application for renewal is under technical review.