Phillips Former KC Refinery Site


Site Background

Phillips Refinery Site (Site) is located in Wyandotte County, Kansas City, Kansas, and is within an industrialized area known as the Fairfax Industrial District (FID). The Site is east of Fairfax Trafficway, immediately west of and adjacent to the Missouri River (Figure 1).

Site Location Map showing the former refinery located on the west bank of the Missouri River south of the GM Fairfax assembly plant and north of the Kansas River.

Since the former refinery is in the FID, land use in and around the Site is mostly industrial. The nearest residential area is located about one-half mile west of the southern boundary of the former refinery. This area is topographically up-slope of the Site. Land use to the east of the Site includes a railroad used to access the General Motors Fairfax Assembly Plant (north of the Site), the Missouri River levee, and a small, narrow strip of agricultural land. This farm land is adjacent to the Missouri River (Figure 2).

Map showing the relative positions of areas (from the north end going south) Williams Tank Farm, Inactive Area, Texwood Area, and Active Area.

The Site is organized in the CI/CAS into six geographic, media-based areas:

  • Active Area (120 acres)
  • Inactive Area (118 acres)
  • Texwood Area (12 acres)
  • Williams Tank Farm, now Magellan (20 acres)
  • Missouri River
  • Off-site Groundwater (monitoring wells between the levee and Missouri River)

The refinery was originally constructed by the Kansas City Refining Company in 1904. Phillips acquired the refinery when it merged with Independent Oil in 1930 and operated it until August 1982 when it was closed. At the time of closure, the refinery was capable of refining approximately 90,000 barrels, or 3.78 million gallons, of crude oil per day.

Petroleum products produced at the refinery included: liquefied petroleum gas, automotive gasoline, heating oil, diesel fuels, military and commercial jet fuels, road oils, asphalts, and lubricating oils. The refinery operated several process units including a crude unit, a catalytic cracking unit, a hydrogen fluoride alkylation unit, a reformer unit, a lube oil compounding unit, and a product blending unit. Products were shipped from the refinery via pipelines, railroad tank cars, barges, and trucks.

After ceasing refining operations Phillips razed the processing units and began cleanup of many of the facility's solid waste management units (SWMUs). There are no refinery-related process structures left on Site. In December 1983 Interstate Oil Company (Interstate) purchased approximately 12 acres along the western boundary, including the lube oil compounding unit. Interstate later sold the property to Texaco-Rosewood LLC, generally known as Texwood. In 1986 Williams Brothers Pipeline Company (Williams) purchased approximately 20 acres at the northeast corner of the Site. Williams currently operates a bulk storage facility in this area.

Phillips operates a refined-product storage and distribution terminal (Kansas City Terminal) on 120 acres in the central and southern portions of the former refinery property, known as the "Active Area." The remaining property, about 118 acres in the northern half of the Site known as the "Inactive Area," is largely vacant except for a single warehouse and a fire-safety facility. Neither structure is staffed full time or on a routine basis.

Past Investigations

Past remedial efforts include installing over 100 monitoring wells used to evaluate the nature and extent of light non-aqueous liquids (LNAPL), and installing and operating an LNAPL/groundwater recovery system. This system has extracted and treated approximately 1.6 million gallons of LNAPL and 7.5 billion gallons of contaminated groundwater. The Kansas Department of Health and Environment (KDHE) encouraged Phillips to optimize this aging and poorly functioning recovery system; it was eventually decommissioned in April 2007. Phillips to developed and implemented interim, alternative recovery methods consisting of individual well LNAPL recovery using dedicated pumps, product bailing, and/or absorbent socks; continued groundwater gauging; and continued groundwater quality monitoring (e.g. sample collection and analysis).

Since about 1981 there have been multiple phases of environmental characterization and investigation performed and/or completed:

  • 1982 - Environmental Closure Plan (responding to permit requirements after the former refinery ceased operations)
  • 1984 - Product recovery initiated (and on-going)
  • 1986/1987 and 1996 - KDHE Administrative Orders (Case No. 86-E-128 and Case No. 96-E-0210, respectively)
  • 1992 - PRC Environmental Management, Inc., Resource Conservation and Recovery Act (RCRA), RCRA Facility Assessment (RFA)
  • 1997 - CH2M-Hill, Inc., Comprehensive Investigation
  • 2002 - Initial Draft Corrective Action Study (not approved; KDHE noting that added characterization was needed)
  • 2005 - Supplemental Site Investigation for Groundwater (characterization supporting LNAPL/Groundwater recovery system shut-down, added delineation along the perimeter of the Site, and optimization of LNAPL/Groundwater interim remedial efforts)
  • 2007 - Interim Plans Update
  • 2008 - Spill/Tank 1505 Release Response
  • 2008 - Risk Assessment and Data Gap Investigation (including development and evaluation of risk screening levels first developed in 1996 and updated in 2008/2009)
  • 2013 - Comprehensive Investigation (CI) (approved 7/9/2013)
  • 2015 - Corrective Action Study (Draft) (CAS)
  • 2018 - Revised Draft Corrective Action- Response to Comments (includes the LNAPL Transmissivity Assessment)

The CI collected and summarized investigation data and findings describing the nature/extent and fate/transport of contamination, and the data gathered was also used to develop the Human Health Risk Assessment (HHRA), the Ecological Risk Assessment (ERA), and the CAS. The primary Site concerns consist of isolated pockets of limited mobility LNAPL, residual soil contamination, and dissolved-phase groundwater contamination that exceeds health-based benchmarks.

The purpose of the CAS is to evaluate which remediation technologies are suitably protective of human health and the environment. Specific areas addressed by the CAS include an overview of past work including field investigations and risk assessments; identification of technologies suitable for addressing site-related contamination; the development of clean-up alternatives and determining their effectiveness; implementability; reduction of contaminant toxicity, mobility, or volume; cost; and community and state acceptance. The final CAS outcome is the presentation and eventual selection of a preferred remedial alternative for the Site.

An HHRA was completed for contaminants found in surface soil, subsurface soil, soil gas (vapor), groundwater, and Missouri River surface water. The HHRA evaluated cancer risks (chronic exposure) and noncancer hazard (acute exposure) indices for Site indoor and outdoor workers, Site construction workers, and off-site recreational users of the Missouri River (anglers). The HHRA identified cancer and non-cancer risks for the following media and areas:

  • Groundwater - Active Area
  • Subsurface soil - at a subarea of the Active Area
  • Groundwater - Inactive Area
  • Groundwater - Williams Tank Farm Area
  • Groundwater - Texwood Area
  • Soil Gas - Texwood Area
  • Fish - from the Missouri River

A summary of cancer risks and non-cancer hazards for each exposure area is presented in Table 7-1 of the HHRA, which is linked in the list of documents below.

An ERA was completed for the Inactive Area and the Missouri River. No unacceptable ecological risks were identified for potential ecological receptors located in either of these two areas. A summary of ecological risks can be found in Section 3.8 of the ERA, linked below.

A Draft CAS was submitted originally to the KDHE in June 2014. KDHE reviewed the Draft CAS and provided review comments to Phillips in a March 30, 2016, letter. KDHE also requested a follow-up meeting to discuss and resolve the review comments and to develop a path forward. Part of the response included incorporating the Risk Assessment evaluation of lead levels in the sewer box on-site and the results of the LNAPL transmissivity study into a revised CAS.

Remedial Action Objectives (RAOs) are media-specific remediation goals for protecting human health and the environment. RAOs are developed through evaluation of applicable and relevant and appropriate requirements (ARARs) and To Be Considered (TBC) criteria, considering the results of the CI and human health and ecological risk assessment. The RAOs include:

  • Minimizing the potential for exposure to groundwater through direct contact, and/or ingestion
  • Treating and/or monitoring groundwater quality until cleanup goals are met
  • Minimizing the potential for exposure to lead in sediment at SWMU 12 (sewer cleanout boxes)
  • Minimizing the potential for future vapor intrusion risks (e.g. cross-media transfer between vadose zone soils and future buildings)
  • Providing sufficient data in the near- and long-term to support the establishment and maintenance of environmental use controls, including establishing a contingency plan in the event new releases are discovered from P66 Terminal operations

Cleanup Levels

For groundwater cleanups conducted at sites with [potential] drinking water aquifers, federally established Maximum Contaminant Levels (MCL) are the applicable cleanup goals. Even though groundwater in the immediate vicinity of the Phillips Site is not currently used for potable purposes, it is a potential future source of drinking water. Thus, MCLs and/or KDHE's Tier 2 Levels for Groundwater described in the Risk-Based Standards for Kansas (RSK) Manual are the final remedial goals. KDHE's RSK values for soil (e.g. direct contact) and cross-media (e.g. soil contaminants leaching to groundwater or vapor intrusion) also apply as final cleanup criteria.

Summary of Remedial Alternatives

Through the CAS process, remedial action alternatives are evaluated with respect to their ability to satisfy National Oil and Hazardous Substances Contingency Plan (NCP) criteria which include:

  • protection of human health and the environment
  • compliance with ARARs
  • long-term effectiveness and permanence
  • reduction of toxicity mobility or volume through treatment
  • short-term effectiveness
  • implementability
  • cost

Remedial alternatives are then compared against one another to help identify and select the final alternative. The NCP requires the evaluation of a No Action alternative to serve as a baseline for comparison to other remedial action alternatives. A detailed description of the various remedial action alternatives and the individual and comparative analyses is presented in the CAS, linked in the documents below.

The following four alternatives were developed:

Alternative 1: No Action
The "No Action" alternative includes Environmental Use Controls (EUCs) due to unacceptable risk associated with groundwater use. This alternative is considered a baseline scenario for comparison to other alternatives and includes all previously completed interim actions. The no action alternative is implementable, and its costs are the lowest when compared to other corrective action options. For this Site the no action alternative is considered appropriate provided the EUC is implemented. However, this alternative does not address potential unacceptable risk or hazard associated with vapor intrusion in/or around the Texwood Facility area or possible ingestion of fish from the Missouri River. Neither does the No Action Alternative comply with other remedial alternative evaluation criteria.

Alternative 2: EUCs with Monitored Natural Attenuation
In addition to implementing EUCs at the Site, Alternative 2 adds Monitored Natural Attenuation (MNA) which involves conducting long-term monitoring at the Site with the specific purpose of evaluating natural attenuation. Alternative 2 involves continuing the groundwater sampling, reporting and LNAPL recovery program. Modification of the sampling points, frequency, and parameters (optimization) may take place over time. However, for purposes of this CAS cost estimate, it is assumed that semi-annual sampling and reporting will continue for five years, annual sampling and reporting for 20 years and bi-annual for 15 years thereafter. LNAPL recovery will remain an on-going activity.

Alternative 3: EUCs with MNA for Groundwater; Vapor Intrusion Mitigation (at Texwood facility); Sewer Box(es) Sediment Removal; Groundwater Treatment Pilot Test; and Groundwater Injection Treatment.
Alternative 3 includes those technologies found in Alternative 2 plus the addition of Vapor Intrusion Mitigation (Texwood facility); Solid Waste Management Unit 12 (sewer boxes) Sediment Removal; Groundwater Treatment Pilot testing and, if the pilot test supports implementation, groundwater injection treatment.

Alternative 4: EUCs with Natural Attenuation for Groundwater, Vapor Intrusion Mitigation (at Texwood facility), HHRA and ERA Risk Assessment, and LNAPL Transmissivity Assessment.
Alternative 4 includes EUCs to control future land and groundwater use, an HHRA and ERA that demonstrates no adverse risk, a LNAPL transmissivity assessment demonstrating LNAPL recovery has been completed to the maximum extent practicable, additional vapor intrusion investigation and possible mitigation at Texwood, and adoption of natural attenuation which has been documented by ongoing MNA.

After evaluating and comparing the various alternatives for the Site with consideration of the threshold and balancing criteria specified in the National Contingency Plan, KDHE and Phillips chose Alternative 4 as the preferred remedy for the Site with slight KDHE modification (bullet item No. 5 below). The total present value cost of the preferred remedy is $1,080,120.

Alternative 4 includes:

  • EUCs to control future use
  • a HHRA and ERA that demonstrates acceptable risk (already completed)
  • a LNAPL transmissivity assessment that demonstrates LNAPL recovery has been completed to the maximum extent practicable (already completed)
  • additional vapor intrusion investigation and possible mitigation at Texwood
  • adoption of natural attenuation with Post-CAS Performance Monitoring

Residual contamination on Site creates a potentially unacceptable risk from groundwater use and soil excavation/disturbance activities. Therefore, the purpose of the proposed EUCs is to allow the property owner (or owners) to voluntarily restrict the use of their property thus mitigating risk posed by residual contamination that exceeds KDHE cleanup criteria for unrestricted residential use.

A contingent remedy (aka contingency plan) will become part of an updated Post-CAS groundwater monitoring plan to ensure that remedy implementation is protective of human health and the environment. This plan will lay out Phillips' response to statistically significant changes in groundwater quality in selected groundwater monitoring wells. Since intrusive activities (such as direct push injections) may become part of the contingent remedy, any plan for these or similar activities near the rail sidings and/or levee will require close coordination with the Union Pacific Railroad, the Fairfax Drainage District, and the Corps of Engineers. Some modifications and/or refinements can be made during implementation of the preferred remedy as needed.

KDHE requests public comment on the Draft Corrective Action Decision (CAD) document for the Phillips Former KC Refinery Site, Kansas City, Kansas. This Draft CAD identifies the preferred remedial alternative to address residual soil and groundwater contamination at the Site. KDHE will select a final remedy for the Site after reviewing and considering information submitted during the 45-day public comment period, October 28 through December 15, 2019.

The Draft CAD presents KDHE's preferred alternative for the Site. However, KDHE may modify this alternative or select another response action based on new information or public comments. A copy of the Draft CAD and other site documents will be available for review at the Kansas City Kansas Public Library, Main Branch, 625 Minnesota Ave., Kansas City, Kansas 66101 (telephone No. 913-295-8250). Selected documents related to the Site are also available for review at the KDHE offices in Topeka, Kansas during the public comment period. Public comments on the Draft CAD may be submitted to KDHE in writing during the public comment period at the address listed below. Comments sent by electronic mail must be received by KDHE by 5:00 p.m. on December 15, 2019.

Kansas Department of Health and Environment
Bureau of Environmental Remediation
Attn.: John K. Cook, P.G., Site Restoration Unit
1000 SW Jackson, Suite 410
Topeka, Kansas 66612-1367
(785) 785-296-8986
Email: John.Cook@ks.gov

Additional Information

For additional information, please contact:

  • John Cook, KDHE-BER Project Manager, 785-296-8986

Site Documents