The requirements
and standards for cleaning up a petroleum release are set by the Missouri
Department of Natural Resources, (MDNR). State law requires those
standards to be "risk-based," which simply means that the corrective
action requirements must be based on an analysis of the risks posed
by the petroleum to human health and the environment.
On December 29, 2004, Ed Galbraith, Director of the Hazardous Waste Program (HWP), issued a memorandum defining the "New Tier 1 Standards" which can be viewed in its entirety by clicking on this link.
In February
2004, the MDNR published an initial version of a Guidance
Manual which outlines the requirements, MRBCA
Process for Storage Tanks. This replaces three previous guidance
documents - the 1996 Closure Guidance, the 1992 Site Characterization
Guidance and the 1992 Corrective Action Guidance. Standardized forms
for evaluating exposure pathways and analyzing risks are available
at www.dnr.mo.gov/alpd/hwp/rbca-04-form.xls.
The MRBCA
process applies to all media and all regulated petroleum storage tank
sites, both aboveground and underground. Neither the person responsible
for the tanks nor the MDNR can choose the media or sites to which
this process will apply. However. during a transition period when
sites that are close to receiving a No Further Action (NFA) letter
from MDNR owners may complete cleanup under the old guidance. See
"Technical
Memo 1" for transition details.
MDNR
will not require any additional evaluation of sites previously granted
a NFA letter unless new information becomes available indicating the
previous cleanup was incomplete, or there is a new release.
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