Memorandum

City of Lawrence

City Manager’s Office

TO:	Tom Markus, City Manager
FROM:	Brandon McGuire, Assistant to the City Manager
CC:	Dave Wagner, Utilities Dept. Director; Philip Ciesielski, Utilities Dept. Deputy Director; Matt Bond, Stormwater Engineer; Charles Soules, Public Works Dept. Director
DATE:	August 31, 2017
RE:	Farmland Remediation Project Status Update

At the August 15, 2017 City Commission meeting, the City Manager’s Report addressed growing concerns about the environmental remediation program at the former Farmland Industries Nitrogen Plant site. The program involves the collection of nitrogen infused groundwater, onsite retention of that water, and annual application to farms located north of the Kansas River. The participating farms are served by a distribution line running from the Farmland site directly to the farms.

Nearly all retention capacity at the Farmland site is being utilized, leaving little capacity to pump and store additional groundwater over the next year. Based on the current plan, the only means of drawing down the onsite water levels is to apply the water to participating farms after the fall harvest. The distribution line is thought to serve an insufficient amount of acreage to meet the remediation program’s needs. As a result, water levels cannot be sufficiently drawn down to free enough storage capacity for the next year of groundwater collection at the site. Complicating the issue, Nitrate and Ammonia values in the groundwater being collected have increased. Crop rotations on participating farms, and in one case, a conversion from sod to beans and corn, have reduced the volume of nitrogen that can be applied to those farms based on agronomic rates. Finally, the area has received above average rain fall in the past year, increasing the volume of water being collected and stored onsite.

City staff met with officials from the Environmental Division of the Kansas Department of Health and Environment (KDHE) on August 17, 2017 to discuss the situation. Division Director John Mitchel led the meeting on behalf of KDHE and Utilities Department Director Dave Wagner led the meeting on behalf of the city. KDHE was eager to assist the city as it addresses the immediate challenges and ensure the long-term sustainability of the remediation program.

Following the meeting, the city requested authorization to temporarily shut off the pumping system for a minimum of six (6) months. During this period, city staff will increase the sampling and testing frequency at the monitoring wells from quarterly to monthly to detect any migration of nitrogen away from the property should that occur. The collection and storage system will not collect additional groundwater during the shutoff, although surface water (e.g. rain water) will continue filling the system. The shutoff provides some temporary relief of the immediate concerns about storage capacity as the project team develops long-term solutions. The area did receive an estimated six (6) inches of rain in the last week which noticeably contributed to the storage problem.

City staff is developing, and will submit, a modified annual land application plan to KDHE. The project team is working to expand the number of acres participating in the land application plan by developing agreements with area farmers. The most economical means of transporting water from the Farmland site to participating farms is through the distribution line that runs from the Farmland site. Since there is an insufficient amount of participating acreage directly served by the distribution line water will likely need to be distributed to additional farms by a trucking contractor.

Approximately 10 million gallons will need to be transported by truck as part of this year’s land application plan. Staff is currently making necessary arrangements with farmers in advance of the fall harvest. A request for proposals (RFP) for trucking services will be advertised the first week of September and a contact will be presented for the City Commission’s approval in October.

Trucking water is not thought to be an economically feasible long-term plan. An RFP is being developed to solicit consultant services to assess the program and identify the most sustainable remediation plan. Options may include onsite treatment, construction of distribution infrastructure to directly serve additional farms and/or an underground containment well. As it undertakes the feasibility study, the project team will continue recruiting additional farms to participate in the land application plan. Staff will continue working with KDHE and will submit a monthly status report for the foreseeable future. The City Commission will be apprised as the situation develops.