2300 Oakland Ave.
Kansas City, MO 64129
United States
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.)
Overview
Background/ History
The Greenfield Environmental Multistate Trust LLC - Kansas City site is located on about 111 acres at 2300 Oakland Ave. in Kansas City, Missouri. In 1907, American Creosote Corp. built and began operating a wood treating facility on about 60 acres of the facility property. Kerr-McGee Corp. purchased the facility in 1964, 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. Due to economic reasons, the wood treating operations stopped in April 1983, but the facility continued to operate as a distribution center for treated wood products. During 2001, Kerr-McGee Corp. went through a corporate restructuring and transferred the Kansas City facility from its Forest Products Division to its Chemical Division. Kerr-McGee Corp. then merged its Chemical Division into Kerr-McGee Chemical Worldwide LLC, a wholly-owned subsidiary of Kerr-McGee Corp. In September 2005, Kerr-McGee Corp. renamed its Chemical Division to Tronox Inc., which it spun-off as an independent company in April 2006. In January 2009, Tronox filed for Chapter 11 bankruptcy relief. Under the 2011 bankruptcy settlement agreement, Tronox transferred all its rights, title and interest with respect to the Kansas City facility to an environmental trust, called the Multistate Environmental Response Trust. Greenfield Environmental Multistate Trust LLC was named the independent, court-appointed Trustee and took ownership and operational control of the property in February 2011.
Under the federal Resource Conservation and Recovery Act (RCRA), the site is considered a closed hazardous waste disposal facility. Both American Creosote and Kerr-McGee pressure treated railroad crossties, switch ties, bridge timbers and lumber, which they sold for commercial use. Both companies used a 70 percent creosote and 30 percent coal-tar solution as the wood preservative. Process wastewater produced by the wood preserving process was collected, treated and discharged to a surface impoundment located on the facility property. In 1981, the U.S. Environmental Protection Agency (EPA) determined sediment sludge produced from treating wastewaters from creosote wood preserving processes is a listed hazardous waste (K001). Kerr-McGee was essentially using the surface impoundment for long-term “storage” of its creosote bottom sediment sludge. Kerr-McGee operated the facility under the “interim status” portions of RCRA.
Cleanup Summary
Kerr-McGee closed the engineered surface impoundment in 1988, according to a department-approved closure plan. As part of the closure, a Deed Notice, filed with the Jackson County Recorder of Deeds on Dec. 6, 1988, was placed in the property chain-of-title to notify any potential buyers that the closed engineered surface impoundment area had been used to manage hazardous waste. Kerr-McGee’s Kansas City 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 corrective action requirements because Kerr-McGee completed the closure activities after the effective date of the federal Hazardous and Solid Waste Amendments. Kerr-McGee, and later Tronox, was performing post-closure and corrective action investigation and remediation activities under two hazardous waste permits, both effective in 1994. The department issued a Missouri Hazardous Waste Management Facility Part I Permit. EPA issued a Hazardous and Solid Waste Amendments Part II Permit.
According to applicable federal and state hazardous waste laws and regulations, all hazardous waste treatment, storage and disposal facilities are required to investigate and clean up releases of hazardous waste to the environment at their facility resulting from present and past hazardous waste handling practices. Investigation results showed soil and groundwater on the facility property was contaminated with hazardous wastes related to the former wood treating operations. Kerr-McGee performed several interim measures at the site in order to reduce or prevent unacceptable risks to human health and the environment. The facility property currently is inactive except for ongoing environmental investigation, cleanup and long-term monitoring activities.
The currently effective hazardous waste permit requires Greenfield, as the current property owner, to continue conducting long-term monitoring and maintenance activities for the closed engineered surface impoundment and corrective action investigation and remediation activities. Current corrective action activities at the site include operating and maintaining a groundwater monitoring system and extraction wells and performing a Remedial Action Optimization Investigation to update the environmental conditions at the facility property. When the investigation is complete, it may result in changes and additions to update the proposed final remedy originally outlined in the Corrective Measures Study report. The department and EPA will review the updated remedial measures and select the best remedy given site-specific considerations for each solid waste management unit or area of concern. The public will be invited to review and comment on the proposed final remedy before the department and EPA make a final decision.
Operations
The Greenfield Environmental Multistate Trust LLC, Kansas City site is located on about 111 acres at 2300 Oakland Ave. in Kansas City, Missouri. In 1907, American Creosote Corp. built and began operating a wood treating facility on about 60 acres of the facility property. In 1964, Kerr-McGee Corp. purchased the facility and it became part of Moss American Corp., a wholly owned subsidiary of Kerr-McGee Corp. In 1974, Moss American became the Forest Products Division of Kerr-McGee Chemical Corp., another wholly owned subsidiary of Kerr-McGee Corp.
Both American Creosote and Kerr-McGee pressure treated railroad crossties, switch ties, bridge timbers and lumber, which they sold for commercial use. Both companies used a 70 percent creosote and 30 percent coal-tar solution as the wood preservative. Untreated “green” lumber received at the facility was first sorted by type (species) and grade (quality) of wood, and cut to the appropriate length. The wood was then stacked in a drying yard and air dried for up to 12 months.
Dried (seasoned) wood was loaded onto a tram cart and placed in a large high temperature-high pressure cylinder called a retort. The retort was then sealed and the wood steamed at high pressure to remove moisture and other wood impurities. A vacuum was then placed on the retort to remove the materials steamed from the wood. The cylinder was then filled with the preservative and pressure was applied to force the preservative into the wood. The pressure was released when the desired amount of creosote had been forced into the wood. A vacuum was placed on the retort again to remove the excess preservative from the retort and recycle it back to the work tank. The tram cart was removed from the retort and moved to drying and storage areas located on the facility property. Any creosote drippage, also referred to as “kick-back”, from the treated wood fell to the ground beneath the drying areas.
Process wastewater was produced as part of the facility operations. The major sources of wastewater were the cooling water from the treatment process and steam condensate from cleaning the retort. The steam condensate contained some lingering preservative from the retort. American Creosote built a wastewater treatment system on the facility property. Originally the wastewater treatment system consisted of an oil/ water separator and non-engineered surface impoundments (Ponds A and B). The surface area of one impoundment was estimated to be 5,000 square feet with an unknown depth, while the second impoundment had a volume of approximately 15,000 cubic feet. The wastewater was processed through the oil/ water separator, where the oil was skimmed from the top of the wastewater and pumped into a holding tank to be recycled back to the production process. The wastewater effluent was discharged to the ponds to let the remaining creosote sludge settle out of the wastewater. If not heated, creosote can thicken and turn into sludge. The wastewater effluent was then discharged off site. Sediment sludge produced from treating wastewaters from creosote wood preserving processes is classified as a listed hazardous waste (K001). This waste had collected and was being “stored” in the bottom of Kerr-McGee’s surface impoundments.
In 1975, Kerr-McGee replaced the non-engineered surface impoundments with a 365 foot by 210 foot engineered surface impoundment on the west edge of the facility property. The impoundment had a maximum capacity of approximately 3.6 million gallons and covered an area where a shallow diked depression had been located. This depression had been used as a sedimentation basin for the process water before discharging off site. Due to economic reasons, the wood treating operations stopped in April 1983, but the facility continued to operate as a distribution center for treated wood products. During 2001, Kerr-McGee Corp. went through a corporate restructuring and transferred the Kansas City facility from its Forest Products Division to its Chemical Division. Kerr-McGee Corp. then merged its Chemical Division into Kerr-McGee Chemical Worldwide LLC, a wholly-owned subsidiary of Kerr-McGee Corp.
In September 2005, Kerr-McGee Corp. renamed its Chemical Division to Tronox Inc., which it spun-off as an independent company in April 2006. In January 2009, Tronox filed for Chapter 11 bankruptcy relief. The U.S. Department of Justice, representing EPA, and several state Attorney Generals worked with Tronox on its reorganization plan. Under this plan, Tronox entered into a settlement agreement by which it transferred all its rights, title and interest with respect to the Kansas City facility to an environmental trust, called the Multistate Environmental Response Trust. Greenfield Environmental Multistate Trust LLC was named the independent, court-appointed Trustee and took ownership and operational control of the property on Feb. 14, 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.
Tronox also filed a fraudulent conveyance lawsuit against Anadarko Petroleum Corp., the parent company of Kerr-McGee. The lawsuit stemmed from the 2006 spinoff. The federal court ruled in Tronox’s favor and a final settlement agreement was reached in 2015. The Kansas City facility is currently inactive, except for ongoing environmental investigation, cleanup and long-term monitoring activities, funded by the 2011 bankruptcy settlement and 2015 settlement agreement. Under the federal Resource Conservation and Recovery Act (RCRA), the facility is considered a closed hazardous waste disposal facility.
Closure & Cleanup
According to applicable state and federal hazardous waste laws and regulations, after a hazardous waste treatment, storage and disposal facility stops operating in an area on its property, that area goes through a closure period. During closure, the facility owners and operators remove and clean their equipment, structures and soil. All hazardous waste treatment, storage and disposal facilities are also required to investigate and clean up releases of hazardous waste to the environment at their facility resulting from present and past hazardous waste handling practices. Closure and corrective action investigations and remediation activities can occur at the same time.
In 1973, eight exploratory test pits were dug around the border of the proposed engineered surface impoundment. One or more of these pits indicated the soil was contaminated with creosote to a depth of at least 7 feet. There are also several known historical leaks and spills of creosote from ruptured or damaged piping and vessel valves/ seals on treating equipment.
Kerr-McGee closed the non-engineered surface impoundments (Ponds A and B) in 1975, before the federal Resource Conservation and Recovery Act (RCRA) existed to regulate the company’s hazardous waste management activities. Kerr-McGee submitted a closure plan for the engineered surface impoundment, oil/ water separator and lift station to the department in 1984, which the department approved in 1985. The separator and lift station were not considered to be hazardous waste management units; however, they were closed at the same time as the impoundment.
State and federal hazardous waste laws and regulations require facilities that currently or formerly treat, store or dispose hazardous waste in land-based units such as landfills, surface impoundments, land treatment units and some waste piles, to carry out a groundwater monitoring program to detect and measure releases to the environment from the land-based units. Before November 1986, Kerr-McGee installed a groundwater monitoring system to comply with the groundwater monitoring requirements. Kerr-McGee expanded its groundwater monitoring system in 1987.
Also in 1987, A.T. Kearney, Inc. and Harding Lawson Associates performed a Preliminary Review and Visual Site Inspection for a RCRA Facility Assessment for the facility property, on behalf of the U.S. Environmental Protection Agency (EPA). The assessment was conducted to identify and gather information on actual and potential hazardous waste releases to the environment. The 1987 RCRA Facility Assessment Report identified 13 solid waste management units that were recommended for additional investigation.
Closure of the engineered surface impoundment began in 1988, and included removing the wastewater, sludge and remaining contaminated soil, which was stabilized and shipped off site for disposal. Before closure, it was estimated the impoundment contained about 10,200 cubic feet of K001 hazardous waste sludge and about 41,500 cubic feet of contaminated soil. The impoundment was backfilled with impermeable clay and capped with vegetative cover. Approximately 52,800 gallons of product was recovered from the impoundment and shipped to Kerr-McGee’s Springfield facility for recycling. As part of the closure, a Deed Notice, filed with the Jackson County Recorder of Deeds on Dec. 6, 1988, was placed in the property chain-of-title to notify any potential buyers that the closed engineered surface impoundment area had been used to manage hazardous waste. The department accepted Kerr-McGee’s closure report and certification in March 1989.
Because hazardous waste remained in place after Kerr-McGee closed the engineered surface impoundment, the area is required to go through a post-closure care period. As part of the post-closure care, Kerr-McGee was required to inspect and maintain the cover over the closed impoundment, as well as operate and maintain the groundwater monitoring and recovery system.
At the department’s request, Kerr-McGee submitted a Description of Current Conditions Report for the facility property. The 1992 report presented all known information regarding unit closures and environmental sampling and investigations performed at the facility property up to that point.
Sixteen historical contamination source areas were identified at the facility, between the 1987 RCRA Facility Assessment Report, the Kerr-McGee’s hazardous waste permit application and a 1994 RCRA Facility Investigation Work Plan. Grant Environmental performed the RCRA Facility Investigation to determine if a release actually occurred and, if so, determine the type and amount of waste released, where the waste is located (horizontal and vertical extent of contamination) and how fast the waste is moving (rate of migration). On behalf of Kerr-McGee, Grant Environmental submitted a RCRA Facility Investigation Report to the department and EPA in December 1994. The sample results showed soil and groundwater where contaminated with hazardous wastes related to the former wood treating operations. Based on these results, the investigation concluded that several of the solid waste management units required additional investigation and cleanup, also referred to as corrective action or remediation.
Kerr-McGee performed several interim measures at the facility property in order to reduce or prevent unacceptable risks to human health and the environment. An interim measure is an action taken to temporarily control the contamination source or path the contamination could take from the source to humans, animals or the environment, such as air, soil, water and food. As an interim measure, Kerr-McGee installed and operated a groundwater and free product pump and treat system and removed and capped contaminated soils. These activities were conducted in coordination with the City of Kansas City’s historical replacement of the 23rd Street overpass and the U.S. Army Corps of Engineers’ historical realignment of the Blue River.
At the department’s request, Kerr-McGee performed a Corrective Measures Study to identify and evaluate possible remedial alternatives for the soil and groundwater contamination. Kerr-McGee submitted a Corrective Measures Study Report to the department and EPA in October 1997. The report included Kerr-McGee’s preferred final remedy along with other remedial alternatives. EPA approved the report in June 1998; however, a final remedy was never approved.
After taking ownership and operational control of the facility property in 2011, Greenfield Environmental Multistate Trust LLC continued maintaining the interim measures with limited funds initially provided by the Tronox bankruptcy settlement. Following the fraudulent conveyance lawsuit settlement agreement in 2015, additional funds became available for Greenfield to perform a Remedial Action Optimization Investigation to update the environmental conditions at the facility property. Recent investigations show shallow groundwater continues to be contaminated with hazardous wastes related to the former wood treating operations at levels that could pose a threat to human health and the environment. When the investigation is complete, it may result in changes and additions to update the proposed final remedy originally outlined in the approved Corrective Measures Study report. The department and EPA will review the updated remedial measures and select the best remedy given site-specific considerations for each solid waste management unit or area of concern. The public will be invited to review and comment on the proposed final remedy before the department and EPA make a final decision.
Oversight
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. Kerr-McGee submitted its RCRA Part A Permit Application on Nov. 14, 1980. The Kerr-McGee Kansas City facility was granted interim status.
In 1983, Kerr-McGee decided to stop their production process and close the engineered surface impoundment, the only hazardous waste management unit operating at the facility. Kerr-McGee’s Kansas City 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 Kerr-McGee completed the closure activities after the effective date of the federal Hazardous and Solid Waste Amendments.
Greenfield Environmental Multistate Trust LLC, as the current property owner, currently is performing long-term monitoring and maintenance activities and conducting corrective action investigations and remediation activities at the facility property under a department-issued Missouri Hazardous Waste Management Facility Part I Permit, effective Feb. 4, 2020. The Part I Permit was originally issued with an EPA-issued Hazardous and Solid Waste Amendments Part II Permit in 1994. EPA decided not to reissue the Part II Permit in 2020, since EPA has no facility-specific conditions beyond those contained in the Part I Permit, and Missouri is fully authorized for all permitting, post-closure and corrective action activities at the facility. The Part I Permit requires Greenfield to continue conducting long-term monitoring and maintenance activities for the closed engineered surface impoundment and corrective action investigation and remediation activities. The regulated units under the current permit consists of the closed engineered surface impoundment.
Documents
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.
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 an Open Records/ Sunshine Law Request.
Regulatory Agreement
| Regulatory Agreements | Regulatory Agreement Note |
|---|---|
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Effective Date: Expiration Date: No Part II |
| Other File(s) | Other File Date |
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| Deed Notice |