Site Narrative:
The former Farmland Industries Nitrogen Plant began operations in 1954, producing a wide range of nitrogen-based fertilizers. Early investigations focused on groundwater (GW) and soil impacts related to the northern ponds and storm water runoff from process areas. GW interception trenches were constructed in the late 1970’s. In the 1980’s, the Chrome Reduction System surface impoundment was identified as a hazardous waste management unit subject to regulation under RCRA. This system was taken out of service, and contaminated soil was removed in 1987. A RCRA Facility Assessment was completed in 1990 and identified specific areas where waste had been managed. Perched GW is contaminated with nitrate and appears connected to the deeper Kansas River alluvial aquifer. Private off-site domestic GW wells completed in the alluvial aquifer have been impacted in the past.
Farmland entered into a Consent Order with BER on 1/27/93 and performed site investigation activities. A Corrective Action Plan (CAP) was issued in 1995 to: contain the alluvial aquifer contamination through pumping, contain the overlying perched zone through operation of an interceptor trench, and concentrate contaminated GW using waste plant heat for reuse as feedstock. Operations ceased in 2001 and bankruptcy was filed in 2002. In 2004, the FI Remediation Trust was set up for cleanup activities.
In 2005 a comprehensive Site Characterization was conducted to identify the extent of contaminants. Supplemental investigations were conducted in 2006-2008.
Interim remedial actions implemented at the Site included: Excavation of chrome-contaminated waste catalyst material from the Catalyst Landfill; Excavation of acutely contaminated soils in some small ponds in the northern process area; Improvements to surface water drainage and excavation of some nitrogen-impacted sediments to protect storm water runoff to the Kansas River; Neutralization of acidic GW in the regulated RCRA unit; Enhancements to the current GW management/containment system; Beneficial re-use of nitrogen-impacted GW & stormwater for land application.
A final RAP was submitted on 5/22/09, which included a summary of investigations and remediation activity previously carried out at the Site, identified issues that require further action, evaluated remedial alternatives, identified priorities, and provided cost estimates to implement the proposed remedies. KDHE developed the draft Corrective Action Decision (CAD). A 30-day public comment period was held from 10/26 through 11/25/09, and copies of key site documents were made available for review at the Lawrence Public Library and KDHE offices in Topeka. KDHE held a public meeting to discuss the preferred remedial actions and solicit public participation on 11/9/09. The CAD was signed by the Secretary on 3/3/10.
A new consent order between KDHE and City of Lawrence was signed on 9/28/2010, and a Transition Plan was approved. An EUC was established for the property, and the Remedial Design/Remedial Action Work Plan was approved.
In 2017 the City of Lawrence requested permission from KDHE to cease operation of the groundwater interception trenches in order to perform a Data Gap Study to assess a new path forward for the Site due to a decreased demand for irrigation water, tank condition-issues, and apparent pumping well placement issues. In 2018 KDHE gave authorization to discontinue this operation. GHD performed the Data Gap Study, which was approved by KDHE on 3/6/2020. GHD submitted a Cost Benefit Analysis to KDHE in April 2020, which was approved July 1, 2020. New remedial alternatives are currently in the design process. As of January 2023, remedial alternatives are approved and in place, ESD is complete and in effect. Permit process for demolition of ASTs began in 2022 and continues in 2023.
Early in September 2023, representatives from KDHE - BER and BoW, GHD, and the City of Lawrence met to review and discuss BER's comments on the June 2023 Remedial Design/Remedial Action Plan Addendum and later that month the RD/RAP Addendum was approved. The RD/RAP Addendum is part of Lawrence's master plan to restore the property for use as the new city Municipal Campus. In May 2024, work plans were submitted, reviewed, and approved for the plugging and abandonment of select monitoring wells and for the interceptor trenches and sumps.
Groundwater monitoring continue to the present: the Performance Evaluation Report No. 106 was recently submitted and approved, and the fall sampling event occurred in mid September 2025. |