Hazardous Waste Program
Tanks Risk-Based Corrective Action Rulemaking Stakeholder Group
Next Meeting | Previous Meetings | Record of 2011 rulemaking efforts
This page is intended to serve as the repository of information related to the development of formal Risk-Based Corrective Action, or RBCA, rules for petroleum underground storage tank sites. Documents relevant to the effort created by the department, stakeholders, and others will be posted to this page.
The Missouri Department of Natural Resources has assembled a stakeholder group to assist with revising the tanks RBCA guidance and developing formal tanks RBCA rules. The rules will determine what specific aspects of the RBCA guidance are required at underground storage tank release sites.
The department initially intended to propose tanks RBCA rules in early 2012. However, for the following reasons, the department asked for and received from the Hazardous Waste Management Commission a one-year extension, until February 2013, to the deadline for proposing the rules:
- The revised RBCA guidance will be incorporated into rule by reference, thus giving certain guidance provisions the force of rule. Because future changes to the guidance will require rulemaking, it is critical to make sure the guidance is clear, accurate and consistent with the rules. The time extension will allow the department time to meet with stakeholders to discuss the necessary revisions to the guidance.
- The Environmental Protection Agency is developing new petroleum vapor intrusion guidance for release in November 2012. Indications are the new guidance will present a process significantly different from what is currently in use. The extension will allow the department time to modify the RBCA guidance and construct the rules to be consistent with the new EPA guidance.
In 2012, the department is planning five stakeholder meetings to discuss the revised guidance, to work with stakeholders to develop final proposed rules, and to solicit stakeholder input on the guidance and rules. The meetings are scheduled as follows:
- April 27, June 15, Aug. 15, Oct. 10, and Nov. 14, 2012. All of the meetings will be held in the Bennett Springs conference room at the department’s offices at 1730 East Elm Street, Jefferson City from 10 a.m. to 3:30 p.m. Stakeholders will be notified of each meeting and the meeting agenda by email.
All documents, information, and stakeholder comments related to the 2012 stakeholder meetings, revision of the tanks RBCA guidance, and rule making efforts will be listed on this webpage.
Revised Guidance Documents
The revised tanks RBCA guidance will be posted below as it becomes available. Changes to the guidance were made using “track changes” so that proposed changes are readily apparent. Substantive changes are annotated. Some minor grammatical changes have been “accepted” in order to direct the reviewer’s attention to the more substantive changes. More extensive grammatical changes are also highlighted, but not annotated.
Prior to each stakeholder meeting, the department will post the draft revised guidance sections to be discussed at the upcoming meeting.
As part of the guidance revision, guidance pertaining to tank closure previously found in Section 4 of the 2004/2005 RBCA guidance has been removed from the RBCA guidance and placed into a separate document titled Tank Closure Guidance (revised Section 4 of the RBCA guidance explains this change). This change was made to clarify that tank closure is a pre-RBCA activity.
- Section 1, 2 and 3 - Section 1 Introduction and Background | Section 2 Overview of MRBCA Process | Section 3 Site Discovery and Initial Response
- Section 2, Figures 2.1 and 2.2 - 2.1 Key Activities | 2.2 MRBCA Process Flowchart
- Section 2, Table 2-1 - Comparison of Risk Assessment Options
- Section 2, Table 2-2 - List of MRBCA Reports
- Section 3, Table 3-1 - Default Target Levels
- Section 4 - UST Closure
- Tank Closure Guidance
- Closure notice
- Closure report forms
- Figure 1-2 - Groundwater Investigation Flowchart
- Table 1-1 - Default Target Levels
- Table 1-2 - Chemicals of Concern
- Table 1-3 - Required Reporting Limits
- Table 1-4 - Soil Concentrations to Determine Need for Groundwater Evaluation
- Section 6
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General Considerations for Risk Assessment
- Section 6, Figures 6.1-6.3 - Flow Chart for Vapor Intrusion; Site Conceptual Model for Domestic Consumption of Groundwater Exposure Pathway Analysis; Determination of Groundwater Target Concentration at POE
- Section 6, Figure 6.4 - Schematic of Leachate Migration from the Soil to a Stream
- Section 6, Figure 6.5 - Procedure for Protection of a Stream Body
- Section 6, Table 6-1 - Allowable COC Concentrations in Surface Water
- Section 6, Table 6-2 - Vapor Concentrations Protective of Explosive Hazards
- Section 7
- Tier 1 Risk Assessment
- Table 7-1 - Tier 1 Risk-Based Target Levels for Residential Land Use
- Table 7-2 - Tier 1 Risk-Based Target Levels for Non-Residential Land Use
- Table 7-3 - Tier 1 Risk-Based Target Levels for Construction Worker
- Table 7-4 - Soil Concentration Protective of Domestic Use of Groundwater (Distance to POE of Zero)
- Table 7-5 - Soil Concentration Protective of Indoor Inhalation of Vapors from Groundwater to Building (Distance to Building of Zero) for Residential Land Use
- Table 7-6 - Soil Concentration Protective of Indoor Inhalation of Vapors from Groundwater to Building (Distance to Building of Zero) for Non-Residential Land Use
- Sections 8-9 - Tier 2 Risk Assessment; Tier 3 Risk Assessment
- Section 10 - Corrective Action Plan
- Section 11 - Public Participation and Notice
- Section 12 - Activity and Use Limitations
- Sections 13-14 - Reporting; References
Other documents
Proprosed structure of the revised Tanks RBCA guidance
Schedule and agenda for 2012 stakeholder meetings
Information pertaining to 2011 rulemaking efforts
All information and documents relevant to the 2011 stakeholder meetings and rule development efforts are available at the link below. The information is and will remain static and serves only as a record of the 2011 rule development efforts.
Record of 2011 rulemaking efforts
Next Meeting
April 27, 2012 - Agenda - Bennett Springs Conference Room, 1730 E. Elm St., Jefferson City, Mo., 10 a.m.--3 p.m.
June 15, 2012
Aug. 15, 2012
Oct. 10, 2012
Nov. 14, 2012