MISSOURI RISK-BASED CORRECTIVE ACTION FOR PETROLEUM STORAGE TANK SITES – APPROPRIATE DOCUMENTS TO BE SEALED BY A REGISTERED GEOLOGIST OR PROFESSIONAL ENGINEER

Hazardous Waste Program fact sheet
07/2014
Division of Environmental Quality Director: Leanne Tippett Mosby
PUB2483

This publication identifies which documents submitted to the Hazardous Waste Program’s Tank Section should contain a registered geologist (RG) or professional engineer (PE) seal.

The Hazardous Waste Program’s Tanks Section receives thousands of documents each year regarding closure or remediation projects at both underground storage tank (UST) and aboveground storage tank (AST) sites.

Far too often, the necessary documents are not completed correctly and this forces the section to send out letters to the parties explaining the following document requirements: Any document making an evaluation of environmental (analytical) data or a conclusion in regards to an assessment of risk to human health and the environment requires a seal by a registered geologist or professional engineer under the Board of Geologist Registration Act.

The result of this back and forth correspondence between section staff and parties can cause delays in closure and remediation activities at tank sites. This publication should provide clarity and help tank closures and remediation projects complete in a timelier manner.

Type of Submittal

Is RG or PE Seal Required?

UST closure report

Only if report includes a tier I risk assessment evaluation or a bedrock assessment.

Suspected release report

No

Site check/system test report

No

Initial hazard abatement report

No

Free product recovery work plan

Usually not, unless plan includes a custom-engineered system.

Free product recovery report

No

Site characterization work plan

No

Certification and registration forms for borings or monitoring wells

No, but forms must be signed by a driller who holds a current, unrestricted monitoring well permit.

A professional seal should accompany any boring log that is used for interpretation unless the RG personally (or someone under their supervision) created the logs or if the logs were stamped by another RG or PE.

Boring logs

No

A professional seal should accompany any boring log used for interpretation unless the RG personally (or someone under their supervision) created the logs or if the logs were stamped by another RG or PE.

Site characterization report

Yes

Soil vapor monitoring work plan

No

Soil vapor monitoring report

Yes

Tier 1 risk assessment

Yes, including addenda, responses, etc., to the risk assessment that includes an evaluation of the data or assessment of risk.

Tier 2 risk assessment

Yes, including addenda, responses, etc., to the risk assessment that includes an evaluation of the data or assessment of risk.

Tier 3 risk assessment work plan

Yes, including addenda, responses, etc., to the risk assessment that includes an evaluation of the data or assessment of risk.

Tier 3 risk assessment

Yes, including addenda, responses, etc., to the risk assessment that includes an evaluation of the data or assessment of risk.

Corrective action plan

Yes

Corrective action report

Yes

Groundwater monitoring work plan

No

Groundwater monitoring report

Yes, if it includes evaluation of the data.

If part of an approved quarterly plan, if data only, then seal is not required.

Plume stability analysis

Yes

Copy of restrictive covenant

No

The department reserves the right to require a seal on any document that provides an evaluation of environmental data or a conclusion in regards to an assessment of risk, in accordance with the Registered Geologist Act.

Disclosure required by Section 640.026, RSMo: Nothing in this document may be used to implement any enforcement action or levy any penalty unless promulgated by rule under chapter 536 or authorized by statute.

For More Information
Missouri Department of Natural Resources
Hazardous Waste Program
P.O. Box 176
Jefferson City, MO 65102-0176
800-361-4827 or 573-751-6822
www.dnr.mo.gov/env/hwp/index.html