THE FARMLAND INDUSTRIES, INC. OLD INSECTICIDE PLANT SITE ( THE SITE ) IS LOCATED IN A HEAVILY INDUSTRIALIZED AREA OF ST. JOSEPH, MO, ON THE EASTERN BANK OF THE MISSOURI RIVER. THE THREE-ACRE SITE WAS UTILIZED FOR OVER TWENTY (20) YEARS AS A PESTICIDE FORMULATION FACILITY. AS A RESULT OF THE FORMULATION ACTIVITIES CONDUCTED AT THE SITE, SURFACE SOILS AT THE SITE WERE CONTAMINATED WITH APPROXIMATELY SIXTEEN (16) DIFFERENT PESTICIDES. THE PESTICIDES MOST COMMONLY ENCOUNTERED WERE ALDRIN, DIELDRIN, CHLORDANE, HEPTACHLOR, AND 4,4'-DDT. UNDER THE TERMS OF TWO CONSENT ORDERS, FARMLAND INDUSTRIES, INC. ( FARMLAND ) COMPLETED THE NECESSARY RESPONSE ACTIONS AT THE SITE, INCLUDING THE CONSTRUCTION OF A CAP OVER CONTAMINATED SOILS AT THE SITE. NO FURTHER RESPONSE ACTIONS ARE PLANNED. OPERATION AND MAINTENANCE OF THE CAP WILL BE PERFORMED BY FARMLAND. THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ( EPA ) HAS INCURRED COSTS OF APPROXIMATELY $320,810.00 FOR SITE INVESTIGATIONS, SAMPLING AND ANALYSIS, DEVELOPMENT AND REVIEW OF PLANS, OVERSIGHT OF RESPONSE ACTIONS PERFORMED BY FARMLAND, AND ENFORCEMENT ACTIVITIES. FARMLAND HAS PAID $33,073.10 FOR OVERSIGHT COSTS INCURRED BY EPA. THE PROPOSED CIVIL ACTION WILL SEEK THE RECOVERY OF APPROXIMATELY $287,763.90 IN PAST RESPONSE COSTS FROM FARMLAND, BURLINGTON NORTHERN RAILRO