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

The Missouri Risk-Based Corrective Action (MRBCA) is undergoing an update to revise outdated Risk-Based Target Levels (RBTLs) established in 2006 to better protect public health, necessitating stakeholder engagement and rule changes. A stakeholder group has been formed to address various issues, including the development of vapor intrusion guidelines and the need for consistent updates to the RBTLs. Long-term stewardship measures are being emphasized to manage risks from contamination at thousands of sites, with an online mapping tool available for the public to track hazardous substance sites.

Environment◦
Missouri Risk-Based Corrective Action (MRBCA) / Long-Term Stewardship (LTS) Update Steve Sturgess Director Hazardous Waste Program (HWP)
MRBCA Update has Many Moving Parts
Need for Risk-Based Target Level (RBTL) Update • Existing RBTLs are outdated: – Developed in 2006 – Not modified in almost 10 years • Update needed to ensure RBTLs are protective of public health and based on current science.
Need for G Errors Consistency Clarity Organization & Structure Stakeholder Discussion Issues Revised Guidance Need for Guidance Revision
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
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.
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.
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.
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.
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.
What is Long-Term Stewardship? • It is the steps taken to protect the public from exposure to residual contamination or waste.
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
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.
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
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
Hazardous Substance Investigation and Cleanup Sites Active Long-Term Stewardship Environmental Notice Completed Brownfield Assessment Inactive VCP (Terminated/Withdrew)
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
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.
Questions? Steve Sturgess Hazardous Waste Program steve.sturgess@dnr.mo.gov