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The Former Amoco Refinery Cleanup— Where are We and Where are We Going?
The cleanup of the former Amoco refinery is being done as a Resource Conservation and Recovery Act (RCRA) corrective action. The corrective action (or cleanup) process is similar to most cleanups under other Environmental Protection Agency (EPA) programs. The steps in this process are:
- an initial site assessment
- a field investigation
- implementation and evaluation of immediate and long-term cleanup alternatives
The corrective action process is highly flexible because the steps necessary to achieve cleanup at a facility depend on site-specific conditions. The corrective action process should be viewed as the steps necessary to make good cleanup decisions, and not goals in and of themselves. These steps and how they relate to the Amoco site are discussed below. The first step is an initial site assessment, known as the RCRA facility assessment (RFA). During the RFA, existing information is gathered about environmental conditions at the facility. An RFA was completed for the Amoco Sugar Creek Refinery Site on January 12, 1988.
The next step is to conduct a site characterization to determine the type, amount, and location of the pollution. This is called a RCRA facility investigation (RFI). The Amoco site is large and investigating the entire site is a complex process. Different areas on and off the refinery site are being investigated according to priorities agreed upon by BP Amoco, EPA and the Missouri Department of Natural Resources (MDNR). Amoco, EPA and MDNR are using this approach to speed up the cleanup time, allow EPA and MDNR to better focus their staff and resources, and to prioritize the cleanup so that the areas targeted for reuse and redevelopment are cleaned up first.The Crawford process area and creek corridor to the Missouri river are areas that are targeted for earlier redevelopment.
RFI reports will be written for each area that is investigated. The first priority is to complete an RFI for the offsite plume (Norledge area). Currently Amoco is revising the draft RFI report based on comments from EPA and MDNR. The next priority is to complete field investigations in other areas of the site. For 2001 the areas targeted for investigations include: the Crawford process area, the creek corridor to the Missouri River, and the West Bluffs area. Currently, Amoco has submitted field sampling plans for each of these areas. The EPA and MDNR have approved the work plan for the Crawford area and Amoco has conducted the sampling associated with this work plan. The EPA and MDNR have reviewed the work plan for the creek corridor area. Amoco is currently revising this plan based on the review. The EPA and MDNR are currently reviewing the work plan for the West Bluffs area. Once the work plans are approved for each area Amoco will conduct the field work. Current plans calls for Amoco to begin investigating the creek corridor in mid-September followed by the West Bluffs area. Upon completion of the field work Amoco will prepare RFI reports for each area.
Another step in the corrective action process is called Interim Measures (IM) implementation. Interim Measures are short-term actions used to control ongoing risks to human health or the environment while site characterization is underway and before a final remedy is selected. Examples of IM's at the site include:
- fencing of the site,
- extraction wells for removing free-product,
- an interceptor trench for preventing the movement of pollution off the property,
- total fluid extraction wells along the creek and the west bluffs tributary for removing polluted groundwater, and
- enhanced fluid recovery from selected wells in the offsite plume area for removing polluted groundwater from under neighborhood areas.
After each RFI is completed Amoco prepares a Corrective Measures Study (CMS) for each area. The CMS identifies and evaluates different alternatives to clean up the site. Currently Amoco has completed a draft CMS for the offsite plume area and will revise this report based on comments from EPA and MNDR. As RFI's are completed for other areas, Amoco will prepare CMS reports for each of them. When the CMS is complete, EPA and MDNR will summarize the proposed cleanup plan and the findings that support the selected remedy. This summary is called the statement of basis. At that point the public will have the opportunity to comment on the proposed remedy selection decision. There is typically a 45 day period allowed for citizens to give their comments to EPA or MDNR. A public meeting is generally held sometime during this comment period to answer questions about the proposed remedy selection and to take verbal comments. After consideration of any comments, a final remedy selection will be made and long-term cleanup will begin.
If you have questions about the corrective action process for the former Amoco refinery, contact:
Brian McCurren; Missouri Department of Natural Resources; P.O. Box 176; Jefferson City, MO 65102-0176; phone (573) 751-3553; email nrmccub@mail.dnr.state.mo.us.
Or
Bob Aston; EPA Region 7; Air, RCRA and Toxics Division; phone (913) 551-7392; email aston.robert@epamail.epa.gov.
