BFI Missouri City Landfill
EPA ID# MOD000624452
MoDNR Contact: Sushmita Sharma,
573-751-3553 or 800-361-4827
Facility Contact: Cassidy Luebbering, 573-636-1144
Last Updated: Aug. 14, 2017
- Former Company Name: Missouri City Landfill; Browning-Ferris Industries Waste Systems of North America Inc.; Browning-Ferris Industries of Kansas City
- Type of Facility: Hazardous Waste Treatment and Disposal - closed.
- Wastes Handled: Phenoxyacetic acid herbicide wastes, organophosphate pesticide wastes, chrome sludge, paint thinners and strippers and other industrial sludges.
- Treatment and Disposal Methods: Waste fixation/stabilization and land disposal - closed.
- Location of hard copies of hazardous waste permit application, Part I Permit, modification requests, reports, etc. and supporting documents:
Final Permits Issued: On Aug. 14, 2017, the department reissued a final Missouri Hazardous Waste Management Facility Part I Permit for the BFI Missouri City Landfill facility, effective immediately. An approved Remedial Action Plan (RAP) was incorporated into the final Part I Permit. Anyone adversely affected or aggrieved by the department’s decision to reissue the Part I Permit, or specific conditions of the final Part I Permit, may be entitled to pursue an appeal before the Administrative Hearing Commission by filing a written petition by Sept. 13, 2017, as more fully described on page 7 of the final Part I Permit.
BFI Waste Systems of North America LLC (BFINA) has been performing long-term monitoring and corrective action investigation and remediation activities at the facility under a department-issued Missouri Hazardous Waste Management Facility Part I Permit and U.S. Environmental Protection Agency (EPA)-issued Hazardous and Solid Waste Amendments Part II Permit. The status of BFINA’s post-closure and corrective action activities is described below.
On July 30, 2010, BFINA submitted a permit application to the department and EPA, to reissue the Part I and Part II Permits. In July 2013, BFINA also submitted a RAP application to the department and EPA, with revisions in June 2014, to address storage and treatment of hazardous remediation waste at the facility as part of their reissued Part I Permit. The department accepted written comments on the draft Part I Permit during an extended public comment period, which began July 7, 2016, and ended Oct. 18, 2016. The department also held a public meeting about the draft Part I Permit on Sept. 20, 2016. During the public meeting, the department presented an overview of past investigations and remedial activities and discussed the draft Part I Permit, including the RAP provisions. The following materials were presented:
- Agenda (9/19/16)
- Presentation (9/20/16)
- Fact Sheet (9/20/16)
- Frequently Asked Questions (9/20/16) Updated FAQ (10/16)
Following review and response to all public comments, the department made minor changes to the draft Part I Permit and issued a final Part I Permit, which requires BFINA to continue performing long-term monitoring and maintenance of the capped landfill, including groundwater monitoring, and corrective action activities. The final Part I Permit also includes provisions for collecting and storing hazardous remediation waste and treating the waste using an on-site treatment plant before discharging the treated waste to an outfall, which is regulated under a separate permit issued by the department’s Water Protection Program. EPA decided not to reissue the Part II Permit, since EPA has no facility-specific conditions for the facility, beyond those contained in the final Part I Permit, and Missouri is fully authorized for all permitting, post-closure, corrective action and RAP activities at the facility. EPA intends to terminate the existing Part II Permit upon the reissuance of the final Part I Permit.
The public can review and obtain paper copies of the final Part I Permit, summary and response to comments received during the public comment period and supporting documents at the Mid-Continent Public Library’s Liberty Branch, 1000 Kent St., Liberty, Missouri (during normal business hours) or the agency locations above.
The BFI Missouri City Landfill is located at 8501 Stillhouse Road, approximately one mile north of Missouri City and the Missouri River. Before 1972, the property was used for agricultural purposes. In August 1972, Lincoln Brothers Land Inc. began operating a sanitary landfill near the southwest corner of the property. In November 1972, Browning-Ferris Industries (BFI) of Kansas City, who later became BFI Waste Systems of North America Inc. (BFINA), leased the property and continued operating the sanitary landfill.
The sanitary landfill accepted municipal wastes and certain industrial wastes, such as petroleum refining sludges, until 1974. Beginning in October 1974, BFINA separated the industrial wastes and processed them in the Chemical Processing Center, which included a tank farm; one 8,000-gallon vertical absorbents storage silo; three clay-lined surface impoundments, with a total capacity of approximately 1.4 million gallons; and two LiqWaCon™ processing units. The tank farm included three 8,700-gallon railroad tank cars, two 10,000-gallon upright steel tanks and four 6,000-gallon concrete open tanks. Bulk liquid industrial waste was received by tank trucks and temporarily stored in the tanks and surface impoundments before being pumped to the LiqWaCon™ processing units. The impoundments temporarily stored separator sludges, bio-treater waste, wastewater treatment sludge, printing ink waste and metal processing waste.
Over the years, BFINA built several additional hazardous waste disposal cells on the property. In January 1976, BFINA opened a chemical landfill in the south central area of the property to dispose of bulk liquid industrial wastes and containerized hazardous wastes. The chemical landfill was approximately 200 ft x 150 ft x 25 ft deep and contained eight levels separated by compacted soil. Each level was separated into several cells by compacted soil berms, or walls. The chemical landfill received a variety of wastes, including phenoxyacetic acid herbicide wastes (which may contain dioxin), carbyne herbicide wastes, organophosphate pesticide wastes, carbonate-containing wastes, phenol-containing wastes, paint sludges, chrome wastes and various other organic and inorganic sludges. From October 1974 to July 1979, all bulk liquid industrial wastes were fixed by the LiqWaCon™ process or with cement kiln dust and placed in the cells within the chemical landfill. BFINA closed the chemical landfill in July 1979 and covered it with compacted clay soil and topsoil.
From July 1979 to November 1980, wastes fixed by the LiqWaCon™ process were disposed in Gelation Basin No. 1, or “old” gelation basin, located on top of the eastern half of the closed chemical landfill. The LiqWaCon™ treated material was pumped as a slurry from the LiqWaCon™ treatment unit through a shallow open trench to the gelation basin, which was approximately 450 ft x 250 ft x 25 ft deep. The treated residue would spread out and gel within an hour and completely harden within 2 to 3 weeks. BFINA closed Gelation Basin No. 1 in November 1980 and covered it with compacted clay. In December 1980, BFINA opened the 6-acre x 30 ft deep Gelation Basin No. 2, or “new” gelation basin, directly east of Gelation Basin No. 1.
From September 1977 to September 1978, BFINA operated three sludge drying beds on top of the southeast corner of the sanitary landfill, next to the Chemical Processing Center. The sludge drying beds, which were each 24 ft x 50 ft, were used to separate the solids from bulk liquid sludges by filtering the liquids and draining them to the Chemical Processing Center for LiqWaCon™ treatment. The only waste received was a nonhazardous bio-treater waste. The drying bed sludges were placed in bulk sludge disposal trenches. BFINA closed the sludge drying beds in November 1979 by covering them with compacted clay. Concrete slurry was pumped into the drain system to seal the piping and sump.
Between 1977 and 1983, BFINA operated a total of seven bulk sludge disposal trenches in the western portion of the site, with an estimated volume of 200,000 cubic yards. The trenches received industrial wastes, such as drying bed sludges, paint sludges and solids and vacuum and filter press sludges. Sludge trenches 1, 2, A, C, D and E were used to dispose paint and industrial sludges, as approved on an individual basis by the department. Sludge Trench 3 was used to dispose manganese dioxide, which was considered a non-hazardous waste. Sludge Trench B never existed. Between July 1978 and July 1979, BFINA closed sludge trenches 1, 2 and 3 by covering each trench with soil. Between September 1980 and September 1983, sludge trenches A, C, D and E were closed by covering each trench with compacted clay and topsoil.
Although the currently permitted property consists of about 200 acres, only the southern 90 acres were developed for waste management activities. At least 160 million pounds of industrial wastes were disposed on the property. In September 1983, BFINA accepted the last shipment of hazardous wastes. A total of 31 acres had been permitted for sanitary landfill operations; however, only approximately 15 acres were actually developed. While operating, the sanitary landfill received approximately 500,000 cubic yards of waste and expanded northeasterly. BFINA closed the sanitary landfill by covering it with soil.
In 1994 and 1995, Lincoln Brothers Land Inc. failed to pay the taxes on the portion of the property leased by BFINA. Talon Properties Inc. purchased the property from Clay County at public auction in August 1996, and filed a collector’s deed for taxes in October 1998. Lincoln Brothers kept ownership of the land north of the hazardous waste management area. BFINA owned a portion of the waste management area to the south. In November 2003, Talon transferred its ownership of the property to Missouri City Landfill LLC, a subsidiary of Allied Waste Industries Inc. Republic Services Inc. purchased Allied Waste in 2008. The property is currently owned by BFINA and Missouri City Landfill LLC, and operated by BFINA. The facility property is currently inactive except for on-going post-closure and corrective action activities.
According to applicable state and federal hazardous waste laws and regulations, all hazardous waste treatment, storage and disposal facilities are required to investigate and clean up releases of hazardous waste and hazardous constituents to the environment at their facility resulting from present and past hazardous waste handling practices. In 1981, a National Enforcement Investigation Center study was performed at the facility, which included an on- and off-property groundwater and surface water sampling program. Initial investigations confirmed groundwater contamination was present on- and off-property. The main contaminants released to soil, groundwater, sediment and surface water were metals; volatile organic compounds (VOCs); semi-volatile organic compounds; organochlorine pesticides; organophosphorus pesticides; chlorinated herbicides; dioxin/furan compounds; 1,4-dioxane; cyanide and sulfide. In 1982, EPA issued an Order on Consent, Docket No. VII-82-H-0021, requiring BFINA to develop a groundwater/surface water monitoring plan. In January 1984, the department placed the facility on the Registry of Confirmed Abandoned or Uncontrolled Hazardous Waste Disposal Sites in Missouri.
BFINA completed several interim measures at the facility in order to reduce or prevent unacceptable risks to human health and the environment. An interim measure is an action taken to temporarily control the contamination source or path the contamination could take from the source to humans, animals or the environment, such as air, soil, water and food. In July 1981, BFINA installed a 1/4-acre treatment pond south of the closed Sludge Trench D. The pond was designed to collect and oxidize an oily substance found in a shallow, hand-dug well. In July 1982, BFINA opened a storm water retention pond between Gelation Basins No. 1 and No. 2, to collect rainwater from the gelation basin surfaces. Storm water from the retention pond was shipped off-site for treatment and disposal at a permitted facility.
BFINA originally began closure activities at the facility before receiving the department’s approval of their closure plan. BFINA submitted a closure plan to the department in February 1984. After several revisions, the department and EPA approved the closure plan in December 1984. BFINA began implementing the approved closure plan in June 1985, closing each hazardous waste management unit separately, with the waste left in place. Liquid waste was shipped off-site for treatment and disposal. The Chemical Processing Center impoundments, treatment pond and storm water retention basin were backfilled with uncontaminated soil from the property. Following the single unit closures, BFINA installed one multicomponent cap over all the waste management units, collectively called the capped landfill. The department accepted BFINA’s closure report and certification for the capped landfill in February 1988; however, because hazardous waste remained in place after closure, the capped landfill, now known as the BFI Missouri City Landfill, is required to go through a period of post-closure care. As part of the post-closure care, BFINA is required to maintain the final cover on the capped landfill and perform long-term groundwater monitoring.
During the closure process, a leachate and consolidation fluid collection system was installed in the areas of sludge trenches 1, 2 and D and the chemical landfill. The gelation basins were also equipped with consolidation fluid collection systems. A passive gas collection system was installed in the sanitary landfill and gelation basins and consisted of vents installed in collection grids. In April 1988, BFINA began operating an active gas extraction system, consisting of a total of 23 wells, in response to discovering a groundwater monitoring well containing significant amounts of combustible gas, mainly methane. After one month of operation, methane was not detected in the gas monitoring probes. In 2003, the active gas extraction system was taken out of service due to the lack of methane necessary to keep the candlestick flare lit. The gas collection system, while currently inactive, remains operational in the event sufficient methane gas is produced in the future.
BFINA also purchased two “buffer” properties in order to limit accessibility to areas of potential contamination, the property south of the facility in September 1989 and property west of the facility in November 1990.
On January 3, 1989, BFINA voluntarily entered into a 3008(h) Corrective Action Order on Consent with EPA, Docket No. VII-88-H-0024, because Missouri had not yet received final authorization for the corrective action portion of the State’s hazardous waste program. The Order required BFINA to carry out a corrective action program to identify and gather information on actual and potential releases of contamination to the environment, including defining the horizontal and vertical extent of the contamination and identifying and evaluating possible remedial alternatives for the contamination.
In March 1989, EPA performed a Resource Conservation and Recovery Act (RCRA) Facility Assessment for the facility. The assessment was conducted to identify and gather information on actual and potential releases of hazardous waste and hazardous constituents to the environment. The 1989 RCRA Facility Assessment Report identified three areas of concern that were recommended for additional investigation. These areas included the access road to the facility, a ravine bordering the southeast portion of the facility and seeps located in the drainage channel directly north of the closed sanitary landfill.
In response to the assessment, Earth Sciences Consultants Inc. (ESCI), on behalf of BFINA, performed a RCRA Facility Investigation to define the horizontal and vertical extent of any contamination released to the environment. ESCI submitted a RCRA Facility Investigation Report to the department and EPA in January 1992. The sample results showed groundwater and surface water at the facility contaminated with VOCs. Based on these results, EPA requested BFINA perform a Corrective Measures Study.
In response to EPA’s request, ESCI performed a Corrective Measures Study to identify and evaluate possible remedial alternatives for the groundwater and surface water contamination. ESCI submitted a Corrective Measures Study Report to the department and EPA in October 1995. The report included BFINA’s preferred final remedy along with other remedial alternatives. EPA approved the Corrective Measures Study Report in November 1995.
In 1996, BFINA installed a groundwater seep collection trench and sump (#4) in the southeastern portion of the site, to capture groundwater contamination surfacing along a ravine southeast of the fill areas and downhill of the groundwater interceptor trench. In 1998, the department approved decommissioning sumps #1 and #2, which are connected to the groundwater interceptor trench, since no contamination had been detected in the samples. BFINA continues to sample these sumps yearly. If at any time it is discovered that water in these sumps has become hazardous, an assessment will take place to determine the required corrective action necessary.
In 2000, EPA, in coordination with the department, selected the best remedy from the Corrective Measures Study Report, given site-specific considerations. EPA prepared a Statement of Basis, which summarized the remedial alternatives and EPA’s basis of support for the proposed final remedy. The public was invited to review and comment on the proposed final remedy during a 45-day public comment period. On Sept. 29, 2000, EPA, in coordination with the department, approved the proposed final remedy and issued a Final Remedy Decision. The approved final remedy includes continued long-term groundwater monitoring, maintenance and operation of the interim measures already installed at the facility and implementing institutional controls. In December 2000, the department and EPA included the approved final remedy in two hazardous waste permits, issued to BFINA and Talon as the owners and BFINA as the operator. EPA terminated their 3008(h) Corrective Action Order in March 2001.
The institutional controls implemented as part of the approved final remedy are enforceable Environmental Covenants, filed in the chain-of-title for portions of the permitted property. These Environmental Covenants were executed by the department and BFINA and filed with the Clay County Recorder of Deeds on Sept. 24, 2008. The covenants contain certain property activity and use limitations and serve to notify in perpetuity, any potential purchaser of the environmental conditions of the property. The covenants restrict the property to non-residential use and prohibit disturbing the soil and drilling or using shallow groundwater for drinking water. These restrictions help to ensure unacceptable exposure to residual contamination does not occur in the future.
During several sampling events in 2009, several contaminants were detected above federal drinking water standards at specific monitoring points. These results indicated that any one or a combination of the original waste management units may be the contamination source. In February 2010, the department determined the extent of contamination was no longer clearly defined at the facility and further site characterization was necessary.
In July 2010, BFINA notified the department that a release containing VOCs and hydrocarbons was discovered in a stream on the permitted property. In November 2010, BFINA notified the department that a sheen was discovered on surface water a few feet north of the facility’s property line. On behalf of BFINA, Geosyntec Consultants investigated the surface water releases and submitted a Newly-Identified Release Report in July 2011. The report recommended adding wells to further define the waste source location and identified possible remedial alternatives.
In October 2012, the department approved BFINA’s proposed installation of a stream bank interceptor trench along the southeastern side of the facility, to collect the contaminated groundwater before it reached the on-site stream. BFINA finished installing the interceptor trench in May 2013. The collected waste is currently pumped to on-site storage tanks and disposed off-site at a permitted facility. On Aug. 14, 2017, the department reissued BFINA’s Part I Permit, which includes Remedial Action Plan (RAP) provisions to allow BFINA to build an on-site hazardous remediation waste treatment unit. This treatment unit will be used to store and treat collected hazardous remediation waste before discharging the treated waste to an outfall, which is regulated under a separate permit issued by the department’s Water Protection Program.
BFINA previously operated the facility under the interim status portions of the federal and state hazardous waste laws and regulations, 40 CFR Part 265 and 10 CSR 25-7.265. When EPA implemented the federal hazardous waste laws under RCRA in 1980, all existing facilities that treated, stored or disposed of hazardous waste in a manner that would necessitate obtaining a hazardous waste permit were required to notify EPA and apply to get such a permit, unless the facility chose to close those operations. Because of the large number of existing facilities, Congress set up requirements which allowed these facilities to operate temporarily under “interim status” until they received their permit. BFINA decided to close the units.
The BFI Missouri City Landfill is subject to the permitting requirements of the Missouri Hazardous Waste Management Law and federal Hazardous and Solid Waste Amendments for post-closure care because hazardous waste remained in place after closure. The facility is also subject to corrective action because releases to the environment have occurred and BFINA completed closure of the interim status hazardous waste management units after the effective date of the federal Hazardous and Solid Waste Amendments.
BFINA is currently conducting post-closure and corrective action activities under a department-issued Missouri Hazardous Waste Management Facility Part I Permit, which was reissued Aug. 14, 2017. This permit was first issued in 2000, along with an EPA-issued Hazardous and Solid Waste Amendments Part II Permit. The department reissued the Part I Permit; however, EPA decided not to reissue the Part II Permit, since EPA had no facility-specific conditions for the facility, beyond those contained in the reissued Part I Permit, and Missouri is fully authorized for all permitting, post-closure, corrective action and RAP activities at the facility.
The Part I Permit requires BFINA to continue performing long-term monitoring and maintenance of the capped landfill, including groundwater monitoring, and corrective action activities. The Part I Permit includes provisions for collecting hazardous remediation waste, storing and treating the waste using an on-site treatment plant and discharging the treated waste to an outfall, which is regulated under a separate permit issued by the department’s Water Protection Program. The Part I Permit also requires corrective action in the event there is a newly-identified release of hazardous waste or hazardous constituents to the environment or if the contaminated groundwater poses a threat due to further migration.