Sturgess, Steve, MDNR, Missouri Risk-Based Corrective Action Long-Term Stewardship Update, MECC, 2016, Kansas City

1. Missouri Risk-Based Corrective
Action (MRBCA) / Long-Term
Stewardship (LTS) Update
Steve Sturgess
Director
Hazardous Waste Program (HWP)

2. MRBCA Update has Many Moving Parts

3. Need for Risk-Based Target Level
(RBTL) Update
• Existing RBTLs are outdated:
– Developed in 2006
– Not modified in almost 10 years
• Update needed to ensure RBTLs are protective
of public health and based on current science.

4. Need for G
Errors
Consistency
Clarity
Organization
&
Structure
Stakeholder
Discussion
Issues
Revised Guidance
Need for Guidance Revision

5. RBTLs/models/inputs incorporated by
reference into 10 CSR 25-18.010
Rule allows guidance update, limited
RBTL modification
Guidance and RBTL changes
necessitate rule changes
Significance and scope of proposed
changes exceed rule intent
Rulemaking necessary

6. Stakeholder Engagement
• 9/30/15: Stakeholder group (SHG) established.
• SHG has 40 members including environmental
consultants, industry reps, local government
reps, attorneys, REGFROM, and DNR and
DHSS staff.
• SHG has met twice – 12/9/15 and 2/3/16.
• Next meeting planned for 6/9/16.

7. Topics Discussed Include
• RBTL update, including use of EPA regional screening
level methods and inputs.
• Remove RBTLS from rule so they can be updated
regularly without a rulemaking.
• Expedite updating RBTLs for PCE, TCE, cis-1,2-DCE
and VC.
• Vapor intrusion – due to rapidly developing science.
• Various issues related to site characterization and risk
assessment.

8. Vapor Intrusion Guidance
• Based on discussions with stakeholders, we
have formed a Vapor Intrusion subgroup to work
on developing Missouri-specific vapor intrusion
guidance.
• The VI subgroup will meet more regularly than
the larger stakeholder group to develop VI
guidance for inclusion in the revised MRBCA
guidance.
• First VI Subgroup meeting planned for 5/18/16.

9. Future Activities
• Significant remaining issues include cumulative
risk assessment and developing RBTLs for Total
Petroleum Hydrocarbons.
• Once the SHG has addressed all of the
identified issues, department staff will begin
drafting revised guidance.
• Once the guidance revisions are complete and
the VI guidance has been developed, we’ll begin
the rulemaking to make corresponding changes
to the rule and to update the RBTLs.

10. 2016 MRBCA Revision Webpage
• Information regarding the MRBCA guidance
revision, RBTL update, and SHG meeting notes
are available on the department’s website
http://dnr.mo.gov/env/hwp/mrbcaupdate.htm.

11. What is Long-Term Stewardship?
• It is the steps taken to protect the public
from exposure to residual contamination
or waste.

12. Why Do We Need LTS?
• Thousands of sites
• Risk based remediation: clean-up to level
appropriate for future use
• Central repository for sites that have been
investigated or remediated
• Knowing what is there, and what uses are
prohibited, will help everyone make informed
decisions
• Prevent disturbance of material left in place

13. Why Do We Need LTS?
• On-line Missouri Hazardous Substance Site
Locator map of hazardous substance
investigations and cleanups
• Map allows users to conduct searches of sites by
county, city, zip code, address or by site name.
Data can be incorporated into external user’s data
systems.

14. LTS Map Enhancements
• Added a search by site name feature and county
and municipal boundaries (Jan 2016).
• Soon to be renamed Missouri Environmental
Site Tracking and Research Tool (E-START).
It will also include:
– Sites where assessments were conducted
– Sites where USTs/ASTs are/were present

15. Hazardous Waste Program
Mapped Data
SMARS
DATABASE
3437 Sites for Map
997 VCP
609 Federal Facilities
836 Superfund
1 US EPA
754 BA Sites
240 Inactive Sites
RCRA PERMITS
SECTION
DATABASE
103 Sites for Map
TANKS SECTION
DATABASE
16,117 Facilities for
Map

16. Hazardous Substance Investigation
and Cleanup Sites
Active
Long-Term Stewardship
Environmental Notice
Completed
Brownfield Assessment
Inactive VCP (Terminated/Withdrew)

17. Tank Facility Categories
Investigation/Corrective Action is Ongoing or Incomplete
No Further Action Letter Issued With Restriction
No Further Action Letter Issued Prior to 2004 Tanks RBCA
No Further Action Letter Issued Without Restrictions
Operating UST Facilities With No Known Release
Other Reported Petroleum Facilities with No Known Release
Administrative Closure

18. LTS Inspections
• HWP’s LTS Unit conducts inspections of sites where
institutional or physical controls are needed to prevent
exposure to remaining hazards. Currently, inspections
are conducted of BVCP sites.
• Inspections at 75 tank facilities where an AUL was
required will begin July 1, 2016.
• Currently the regional offices inspect the 64 registry
sites. It has been proposed that the LTS unit assume
inspection responsibility for these sites starting in
FY2017.

19. Questions?
Steve Sturgess
Hazardous Waste Program
steve.sturgess@dnr.mo.gov