Farmland Remediation



The former Farmland Industries Nitrogen Fertilizer Plant, located at 1608 North 1400 Road in Lawrence, KS operated as a fertilizer manufacturing facility from 1954 until 2001. The facility was expanded and updated throughout its history to provide a variety of fertilizer products, including anhydrous ammonia, nitric acid, granular urea, ammonium nitrate, and urea ammonium nitrate. Wastes generated as a result of plant operations included sludge and wastewater that were released to soil, groundwater, and stormwater on the property.

By 2001, all operations at the facility had ceased due to the economic downturn of the fertilizer market, rising energy costs, and the eventual bankruptcy of Farmland Industries in 2002. In 2004, the Farmland Industries Kansas Remediation Trust was formed and funded to address the environmental impacts at the site.

When the City of Lawrence acquired the 467-acre site in 2010, a commitment was made to perform the required remediation of the property as directed under a Consent Order with the Kansas Department of Health and Environment (KDHE). The primary contaminants of concern are nitrate-nitrogen and ammonia-nitrogen. These contaminants are elevated in soil, sediments, groundwater, and stormwater. To staff’s knowledge, a National Pollutant Discharge Elimination System (NPDES) permit has been maintained for this site since 1972.

Historically, the approved remedial action plan included land applying nitrogen-impacted water from the Farmland site to agricultural land north of the Kansas River via a network of pipelines. This remedial strategy proved unsustainable due to the considerable amount of nitrogen-impacted water collected relative to the lower demand for agricultural land application.

In 2017, the City faced an emergency situation where the collection of nitrogen-impacted water from the Farmland site exceeded the rate of land application causing the City’s containment system to reach full capacity. To alleviate the storage concerns, KDHE approved a one-time, conditional discharge of water to the Kansas River.


Ongoing Farmland Remediation Project

In 2018, the City began the process of reassessing the environmental conditions of the site and hired an experienced environmental consultant to evaluate, select, and implement a long-term sustainable remediation strategy for the Farmland property.

2019 -

Since the initial City Commission approval of the contract with GHD on April 13, 2018, the City and GHD have worked continuously to produce a remediation alternative that may be presented to the Kansas Department of Health and Environment (KDHE). The first step in the approved contract with GHD included site data review and development of an updated conceptual site model. During their development of the static 3D model and detailed review of current systems and monitoring data, GHD and the City identified data gaps and changes to the site conditions, which prevented the completion of the original scope of work as requested. To address these data gaps, the City Staff and GHD prepared a data gap study work plan (PDF) that was submitted to KDHE on November 21, 2018. The plan was approved by KDHE (PDF) on January 23, 2019 and funding for the work plan was approved by the City of Lawrence City Commission at their commission meeting on March 5, 2019.

2020 -

The Data Gap Study was completed and approved by KDHE on March 6, 2020. The Data Gap Study provided GHD the necessary information to complete the Cost-Benefit Analysis (CBA) Report, detailing multiple remediation options for both soil and groundwater at the site.

The CBA report for potential remedial efforts in addition to or in place of groundwater collection for land application was submitted to KDHE Bureau of Environmental Remediation (BER) on April 6, 2020. Comments on the CBA report were received on April 27, 2020 and subsequently addressed. KDHE BER approved the CBA on July 1, 2020.

2021 -

On February 2, 2021, the City commission approved a supplemental agreement to the Engineering Services Agreement with GHD. The next steps included evaluating the findings of the Data Gap Study and remedial options in the CBA report. The City negotiated the next scope of work with GHD that included a pre-design investigation and work plan. The scope of work additionally included installing new monitoring wells, containment wells, and submitting a Current Site Conditions Report with analytical information from the new monitoring wells. Phase one of the alternatives analysis included professional services related to site study, analysis of alternative remediation strategies and regulatory approvals for alternative strategies prepared by GHD. The project scope included data review, existing remediation systems evaluation, and remediation alternative evaluation and recommendation.

In May 2021, GHD began the initial phase of the groundwater monitoring well installation work plan as outlined in the current scope of work. Seventeen new monitoring wells were drilled and developed over a period of approximately four weeks in May and early June. During the third week of June, GHD performed well sampling on all existing (30 wells) and new monitoring wells (17 wells). The City of Lawrence water quality laboratory conducted the analyses of the samples for ammonia-nitrogen and nitrate/nitrite-nitrogen and turned over the results to GHD. On September 30, 2021, GHD finalized the Supplemental Investigation Report and submitted to KDHE BER for review on November 9, 2021.

2022 -

After addressing comments from KDHE BER on January 11, 2022 and meeting with members of KDHE BER on January 26, 2022, the Supplemental Investigation Report was approved by KDHE on February 10, 2022.

Under the terms of the scope of work in Supplemental Agreement No. 2, GHD and the City held a Remedial Alternatives Workshop on February 22, 2022. The goal of this workshop, was to re-evaluate and discuss the remedial alternatives described in the CBA and Supplemental Investigation Report. Members of City staff, GHD, and engineering consultants were invited to contribute their expertise to the workshop.

On April 15, 2022, the City of Lawrence and GHD participated in a virtual meeting with members of KDHE BER and Bureau of Water (BOW) to provide an update on the progress of the remedial efforts and share results of the workshop held on February 22, 2022. During this discussion, KDHE requested a formal request with supporting documentation stating the next steps of the remedial process.

On June 15, 2022, GHD and the City submitted a formal request to KDHE BER and BOW to gain concurrence to the proposed remedial options selected for the former Farmland site. This request included supporting documentation outlining the proposed remedial strategies. The timing of this concurrence was critical to coincide with the planned upgrades to the Kansas River Wastewater Treatment Plant (KRWWTP) that are being designed to meet new nutrient removal requirements established in the current NPDES permit schedule of compliance. One of the proposed options for remediation of the Farmland water is nitrogen side stream removal at the KRWWTP which will be incorporated into the new plant design. Approval from KDHE to the proposed changes to the Farmland remedial alternatives was received in a letter dated July 26, 2022.

In July 2022, KDHE BER began preparation of a draft Explanation of Significant Difference (ESD) for the remedial alternatives at the Farmland site. This document will describe the differences in scope, performance, and cost of the remediation strategy adopted by the current Remedial Action Plan. On October 31, 2022, the City received notification from KDHE BER that the Explanation of Significant Difference for the proposed remedial alternatives at the Farmland site had been signed by the KDHE Secretary and is now considered final.

2023 -

The City and GHD submitted a Remedial Design/Remedial Action Plan Addendum to the Kansas Department of Health and Environment on June 9, 2023. This addendum details the modified work plan with technical specifications and a plan of action for the implementation of the new remedies for the Site. Approval from KDHE to the Remedial Design/Remedial Action Plan Addendum was received by the City on September 27, 2023. With this approval, the City is now authorized to move forward with the implementation of the new remedial strategies.

See below for commonly asked questions, and check back to this webpage as project updates will be posted periodically.

RCRA Permit Modification

In addition to the ongoing remediation efforts for nitrogen contamination on the former Farmland site, the City successfully remediated a portion of the site in 2015. The Resource Conservation and Recovery Act (RCRA) permit, associated with the Chrome Reduction System (CRS) unit, was in post-closure status when the City took ownership of the site. On November 16, 2018, the City of Lawrence submitted a Post Closure Care Completion Certification Report, prepared by GHD. The report shows that the City has successfully completed all of the requirements of post-closure care as prescribed by the monitoring plan, supplemental work plans, and applicable sections of Federal regulations. KDHE BWM accepted this Post Closure Care Report on January 16, 2019 and granted permission for the City to submit a permit modification request for a change in the permit expiration date to allow earlier permit termination. The request was in reference to Parts I and II of the RCRA permit (the Permit, US EPA Permit I.D. KSD 007128507), which identifies post-closure care and monitoring requirements for the former CRS Unit at the former Farmland Nitrogen Facility.

The permit modification request was submitted to KDHE BWM and EPA Region 7 on March 18, 2019. Part I of the permit was allowed to expire on April 1, 2019, as approved by KDHE in  a letter dated April 1, 2019, and the Part II was allowed to expire on May 10, 2019, as approved by the US EPA in a letter dated May 14, 2019.

Both GHD and City staff have committed to involving stakeholders and the community at large throughout the process. See below for commonly asked questions, and check back to this web page, as project updates will be posted periodically.


Reference Information

USGS Nitrate gauge at DeSoto

The City has worked in tandem with the U.S. Geological Survey and other local entities to operate and maintain a nitrate gauge at DeSoto to monitor nitrogen concentrations in the Kansas River. The link below shows the nitrogen load put in the river from the temporary alternative discharge operation in comparison to background levels at different times during the year.

Senate Standing Committee on Utilities Presentation

Frequently Asked Questions