Missouri Risk-Based Corrective Action
Risk-Based Remediation Rule Workgroup
Oct. 3, 2006 - Missouri Risk-Based Corrective Action, or MRBCA, Kick-off Event
The MRBCA process was used to obtain a Letter of Completion at the Whitmire Micro-Gen Research Laboratories site. Atul Salhotra, RAM Group, conducted a short tour.
June 28, 2006 - Workgroup Meeting Information
The minutes and attendance are provided here for the June 1, 2006, meeting of the Risk-Based Remediation Rule Workgroup.
June 20, 2006 - Updates to the Technical Guidance
The following sections of the Departmental Risk-Based Corrective Action Technical Guidance have been updated or revised, and they replace the existing versions. These revisions do not constitute substantive or policy changes and most were explained at the last Workgroup meeting on June 1.
An explanation of the revision follows each update. Please note that all new updates are sub-labeled with the date of June 2006, which provides information that it is a later update to the test from April 2006.
Appendix B - This section has been revised to include target levels for total TPH as well as some minor editorial changes.
Appendix E, Tables E-1 to E-3 > - The chemicals in this section has been reorganized so that the VOCs and SVOCs are no longer listed separately. In addition, please note that the toxicity values and the physical and chemical properties for petroleum-related chemicals are now included in this table. This information is based upon the same decisions/hierarchies that were made in the Risk-Based Remediation Rule Workgroup and that apply to all other chemicals in the departmental guidance.
Appendix E, Figure E-3: Figure E-3 - This has been updated to reflect changes brought about by changes in the Water Quality Standards (the mixing zone concept and comparison to acute criteria were dropped for Class C streams). In addition, both Figures E-2 and E-3 were improperly numbered, so their titles were changed.
Figure 2-2 - The MRBCA Process Flowchart was changed to more accurately reflect the broad role of Risk Management in site decisions, which may include clean-up, activity and use limitations, or some combination of both.
Figure 6-2 - This figure was simplified, which should make it easier to read and follow.
June 1, 2006 - Revision to Figure 6-2
Figure 6-2, Domestic Consumption of Groundwater Exposure Pathway Analysis has been revised. The department believes that this revision is in accordance with the policy discussions held in the Risk-Based Remediation Rule Workgroup and the Groundwater Subgroup. The change is to clarify and simplify the chart only and will be discussed at the June 1 Workgroup meeting. If agreed to at the meeting, this revision will be properly formatted and issued as a replacement page in the April version of the Technical Guidance.
May 22, 2006 - Revisions to Appendix B
The department has completed its revision of the Default Target Levels (DTLs) and the Risk-Based Target Levels, to be included as Appendix B in the draft departmental Missouri Risk-Based Corrective Action Technical Guidance. They are presented here for your review and for discussion at the meeting on June 1, 2006. Please keep in mind that these revised target levels were re-calculated based upon discussions and comments that have taken place in the Workgroup over the past year or so.
- Summary of Changes in the Default Target Levels and the Risk-Based Target Levels -- This information is virtually identical to the summary that was posted before the January 2006 meeting. It describes the basis for the changes in a selected suite of 30 common chemicals (non-petroleum) that can be found at a hazardous waste site.
- Summary tables of the revised risk-based target values of the 30 common chemicals. Again, this information was posted before the January meeting, but it is presented here as a "snapshot" version of the changes to Appendix B.
- Revised Appendix B
- A break-out of the petroleum-related chemicals and the changed values that would occur if their target levels were calculated under the same assumptions/input parameters as the chemicals in the departmental guidance
May 12, 2006 - Publication of Technical Bulletin
The Department of Natural Resources has published a Technical Bulletin on Missouri Risk-Based Corrective Action. Please feel free to print and use this information.
April 7, 2006
The revised Risk-Based Corrective Action Technical Guidance Sections (April 2006) and Appendices (April 2006) is available for your use at this time. This version incorporates the changes noted in the March 2006, version posted earlier.
The next step is to calculate revised risk-based target levels using the input parameters in Tables E-4 and E-5 and the equations in Appendix E. We expect these revised values to be complete about mid-May 2006, and they will be incorporated in Appendix B and posted at that time. Development of the risk-based corrective action rules will proceed based on the guidance document.
Workgroup members will receive information on training opportunities, rules timeline, and the next meeting in the near future.
In addition, the department is posting a final response to comments received on the December 2005, version of the guidance.
March 9, 2006: Public Outreach Materials
The Public Outreach Subgroup developed the following set of materials to promote the use of the MRBCA Technical Guidance and risk-based process in Missouri. These materials were posted previous to the January 12, 2006, Workgroup meeting. Workgroup members were given three weeks to review and comment on them. The following documents incorporate the suggested changes. As the Public Outreach Plan is implemented, these materials may yet be revised, but they are an excellent start to promoting risk-based decision- making. Many thanks to Diane Maijer and Kevin Perry for their invaluable assistance on these materials.
- Public Outreach Plan
- Sample Teaser Email
- Generic PowerPoint™ Presentation
- Technical Bulletin
- Sample Newsletter Article
March 9, 2006: Revised Technical Guidance
A revised Risk-Based Corrective Action Technical Guidance Sections (March, 2006) and Appendices is available for your review. Revisions to the guidance reflect comments from both Workgroup members external to the Department of Natural Resources (comments posted below on Feb. 16, 2006) and internal comments from department staff. Changes in the March version are indicated by red type.
Next Step - Review and return comments by March 20, 2006. At the last Workgroup meeting, it was decided to allot a certain period of time for review of the most recent version of the Technical Guidance. If Workgroup members have concerns or comments with this version of the guidance, please make those known to Linda Vogt by March 20, 2006, either by email, telephone, or standard letter.
The department is hopeful that this round of review and comment is our last round of revisions before moving on to the "Rules" phase. As you know, this guidance will be used as the basis for development of Missouri's risk-based rule. However, the rules process also has two rounds of public comment built into it and further review; therefore, we will have opportunities for additional change to the guidance as we move forward in the rules process.
The department is also posting the following responses to comments made from Workgroup members. We thank them for their continued review and interest in the Technical Guidance.
- Response to Roger Walker, REGFORM
- Response to Barton O. Ives, Department of the Army
- Response to Robert Johnson, P.E.
- Response to Keith Piontek, P.E.
- Response to Andrew Bracker, City of Kansas City
Feb. 16, 2006
The department has received comments on the December 2006, draft of the Departmental Risk-Based Corrective Action Technical Guidance. The following Workgroup members provided comments.
- Andrew Bracker, City of Kansas City
- Robert L. Johnson, P.E.
- Keith Piontek, P.E.
- Barton O. Ives, Department of the Army
- Roger Walker, REGFORM
In addition, departmental staff have made numerous comments for consideration in revising the guidance. Comments include those revisions necessitated by changes in water quality regulations.
As noted in our earlier schedule posted on January 23, the department's response to comments will be posted and a revised draft final Departmental Risk-Based Corrective Action Technical Guidance on March 3, 2006. Revisions to the guidance that resulted from this round of comments will be noted in redline. By March 17, workgroup members should have reviewed the posted responses and revisions to the guidance. At that time, we can decide if the draft guidance is complete enough to move forward with it as the basis for our rule or if significant issues remain that need to be resolved. We'll also leave the decision to meet again as a formal workgroup until that time.
Again, thanks very much for your interest and participation in Missouri's risk-based decision-making process. Please call or contact Linda Vogt, if you have any questions or want to discuss any of the comments.
Jan. 23, 2006
The Risk-Based Remediation Rule Workgroup met on Jan. 12, 2006. We are providing a summary of that meeting, which also includes the attendance list. Thank you to everyone who attended - your participation is appreciated.
Members of the Workgroup also requested that department post dates for completion of review of the Technical Guidance and the Public Outreach Plan. Please see below.
- Feb. 4 -- Comments on the Draft Public Outreach Plan and associated materials are due (posted below on Jan. 12).
- Feb. 10 -- Comments on the current draft of the Technical Guidance are due (the most recent version is posted under the icon for Tech Guidance" as well as below. On January 10, we posted the Guidance Sections and on January 12, we posted the Appendices. Please note that the Tanks MRBCA Technical Guidance is a separate document and not part of this review. Tanks Guidance can be found by clicking on the Tanks icon. )
- March 3 -- Departmental response to comments complete and the revised guidance posted
- March 10 -- Revised Draft Public Outreach Plan and associated materials are posted.
- March 17 -- Workgroup members complete review of revised Guidance.
- April 10-14 -- Workgroup meeting held during this week to discuss Revised Guidance and any remaining issues
- May 19 -- Revised DTLs and RBTLs calculated and posted.
- May 26 -- Draft Departmental Missouri Risk-Based Corrective Action Technical Guidance posted.
- June -- Training
Please direct all comments to Linda Vogt at the address and telephone number below. Thank you very much for your participation.
Jan. 12, 2006
The following information is posted on the MRBCA website for review and discussion in the January 12, 2006 meeting of the Risk-Based Remediation Rule Workgroup.
1. The Appendices to the Departmental Risk-Based Corrective Action Technical Guidance have been revised to reflect comments from the Workgroup members and the EPA. Changes to Appendix E reflect the adoption of the RAGS Part E dermal contact information.
In addition, comments have resulted in changes to the Default Target Levels (DTLs) and Tier 1 Risk-Based Target Levels (RBTLs). As requested at the last Workgroup meeting, these changes were summarized and posted on Sept. 18, and opportunity for a comment was provided. On January 10, the department posted a list of 30 chemicals to illustrate and explain the changes in final DTL and RBTL values and the reason(s) for the change.
2. At the last Workgroup meeting, a Public Outreach Subgroup was formed to develop a public outreach plan. This subgroup has developed a significant set of materials for review by the Workgroup. Please note that all of the materials are in "draft" form and not available for use at this time. The attached materials are:
- Public Outreach Plan
- Email teaser
- MRBCA PowerPoint™ presentation
- Newsletter Article
- Technical Bulletin
Jan. 10, 2006
The following information is posted for review and discussion in the Jan. 12, 2006 meeting of the Risk-Based Remediation Rule Workgroup.
- The Technical Guidance has been revised to include the responses to the EPA comments as posted on January 4, 2006. Please note that this version includes only sections that have been revised due to Workgroup comments (those revisions were also posted last August) and to EPA comments, and all of these changes are indicated in red. (Chapter 11 changes are shown in blue.)
- Most people are interested in the final Default Target Levels and Tier 1 Risk-Based Target Levels . Because of numerous revisions, these numbers will also change. The attached tables provide changes in final numbers for numerous pathways for about 30 non-petroleum related chemicals found at hazardous waste sites. (Please note that the status of the petroleum-related chemicals is on the agenda for the meeting.) The tables indicate the change in value, the ratio of change from the February, 2005 version to the January, 2006 version, and the reason for the change. A cover memo to these tables provides more in-depth information. Please feel free to call Linda Vogt 573-751-6998 before our meeting and discuss if you have any questions about these tables.
- DHSS requested several changes to Appendix E. These changes are still being worked through, but we expect to post a revised Appendix E before the meeting.
- A Public Outreach Subgroup has developed a Public Outreach Plan to be discussed at the meeting. This information will also be posted before the meeting.
We hope this information proves helpful to you, and stay tuned for additional postings. Thanks very much for your interest and participation in developing a risk-based remediation process for the State of Missouri!
Jan. 4, 2006
Comments and Responses on August 25 Draft of Departmental Missouri Risk-Based Corrective Action (MBRCA)
- Comment and Response from Department of Health and Senior Services
- Comment and Response from Tom Tunnicliff
- Exposure Frequency for Construction Worker
Oct. 12, 2005
At the August 23, 2005 Risk-Based Remediation Rule Workgroup meeting, John Hoke, Water Protection Program, provided information on changes to Water Quality Standards (WQS). Workgroup members asked that this information, Updates to WQS , and previous information provided by Hoke, WQS and Mixing Zones , be posted on this MRBCA website. Please contact either John Hoke or Linda Vogt if you have questions or concerns about this information.
Sept. 23, 2005
Changes in Tier 1 Risk-Based Target Levels (RBTLs)
Departmental Missouri Risk-Based Corrective Action Technical Guidance
The Department of Natural Resources is posting the following link, Comparison of February 2005 Tier 1 RBTLs with September 2005 Tier 1 RBTLs. It contains three tables which identify 20 chemicals commonly found at hazardous waste sites and their revised Tier 1 Risk-Based Target Levels (RBTLs) for Resident, Non-Resident Worker, and Construction Worker receptors. Revisions in RBTLs are due to changes adopted/discussed at the August 23, 2005 meeting of the Risk-Based Remediation Rule Workgroup. The September 12, 2005 posting below provides complete details on these revisions. The revised equations and input parameters have no effect on some pathways; therefore, only pathways with changes are included in these tables. With the exception of some metals, petroleum-related contaminates are not included in these tables.
Sept. 13, 2005
In the Aug. 23, 2005 meeting, the Missouri Department of Natural Resources (DNR) was asked to compile and post changes that will affect the calculation of Tier 1 risk-based target levels (RBTLs) for the Departmental Missouri Risk-Based Corrective Action Technical Guidance. This linked file contains:
- Lists of Specific Changes
- A table containing the updates in toxicity values, including the addition of perchlorate
- Revised Tables E-1, E-2 and E-3 of the Technical Guidance
- Revised Section E-12, which provides information on the models and equations for calculating target levels.
The department also agreed to post a list of about 20 selected chemicals and revised risk-based target levels brought about by the specific changes noted above. We hope to have that list ready for posting by September 19. We welcome your comments and questions on this information, and would appreciate it if you could provide comments by September 30. Finalizing input values and equations will be a big step toward completion of the Technical Guidance.
Reminder: The department posted a revised Technical Guidance on Aug. 25, 2005. U.S. Environmental Protection Agency (EPA) comments and DNR response were posted on Aug. 14, 2005. We asked for comments from the Workgroup on these items by September 16. However, the EPA has since notified DNR that it will have additional comments on the guidance.
Since the last Workgroup meeting, DNR and EPA have also discussed the establishment of a Memorandum of Agreement (MOA) between the two agencies for implementation of Missouri's risk-based corrective action process, and DNR has sent the EPA a draft MOA for discussion.
Contact Linda Vogt if you have any questions or concerns. Thank you very much for your interest in and assistance with risk-based decision-making in Missouri.
Aug. 25, 2005
Our thanks to everyone who attended the August 23 meeting of the Risk-Based Remediation Rule Workgroup. The Workgroup accomplished quite a bit of work in one day. Here is the attendance list . We agreed to this list of Action Items and Responsibilities .
In addition, the Workgroup reviewed the changes to the draft departmental MRBCA Technical Guidance that were agreed to at the April 23 meeting. Some additional changes were requested, and Workgroup members also requested two weeks to review all of these changes and new language. The revised guidance includes all Sections (including Section 11) and any appendices in which changes were made (including Appendix J). If possible, please provide any comments to Linda Vogt by Friday, Sept. 16, 2005. A telephone call, email, or written correspondence will suffice to the address below.
Please note that this version, dated August 24, does not include any of the changes that may be in the works in response to the USEPA comments. Those proposed changes are noted in the DNR response that was posted below on Aug. 14, 2005. As above, we welcome review and comments on those proposed changes.
Hazardous Waste Program
Missouri Department of Natural Resources
P.O. Box 176
Jefferson City, MO 65102-0176
Aug. 22, 2005
1. Aug. 23, 2005 Meeting Revised Agenda RTF
Because individuals in the past have preferred to work through lunch, the agenda has been revised to include a working lunch. We have also moved some presentations around and provided more detail on agenda topics.
2. The department is posting additional information on the changes to the MRBCA process and Risk-Based Target Levels due to updated toxicity information, the adoption of RAGS E, and the USEPA comments.
Aug. 14, 2005
The following items are being posted for discussion/information for the August 23 Workgroup meeting.
- US EPA Comments and DNR response , Aug. 11, 2005
- Attachment A - Comparison of exposure factors
- Attachment B
- Web link to the Michigan state DEQ and its update system, "Operational Memoranda for the Part 201 and Part 213 Programs".
At the last meeting, the Workgroup requested that the department explore the use of a technical and operational update system such as that used in Michigan. New information added in Appendix A confirms that the department will employ a similar update system once the Technical Guidance is finalized.
Aug. 8, 2005
The department is posting three documents for the Aug. 23, 2005 meeting of the Risk-Based Remediation Rule Workgroup.
NOTE: If these files do not open or print for you, you may need to update your Adobe Reader software to the latest version, available free from the internet. (See above.)
1. Proposed Agenda DOC
Please note that the meeting time has been extended to 4:30 p.m. in order to accommodate all agenda items. Department staff are prepared to stay later if needed. A call-in number is included on the agenda.
2. Changes to the draft MRBCA Technical Guidance (Sections and Appendices).
This revised version dated August, 2005 , incorporates all of the changes approved by the Workgroup at the April 28, 2005 meeting (except those discussed below). Changes are shown in red. We hope to finalize these changes at the August meeting. Revised appendices are here. Appendices to which no changes were made are not posted, but would remain the same as posted in February, 2005 (posted below). Please note that the revised guidance does not include any changes resulting from the USEPA comments. The USEPA comments and the Department's response will be posted and discussed at the August meeting.
However, the revised Guidance does not incorporate two approved changes: the use of the 2004 PRG tables for toxicity values and the incorporation of RAGs Pt. E 2001. Because the incorporation of RAGs E would bring about quite a number of changes in the calculation of risk-based values, Atul Salhotra, of RAM Group, will present these and the toxicity changes at the Workgroup meeting. In addition, because of these changes, the department did not at this time, revise and post Appendices B and E of the Technical Guidance.
Section 11 and Appendix J will be posted separately, pending the results of the meeting of the Activities and Use Limitations (AUL) Subgroup on August 17.
If you have any additions to the agenda or comments/questions about the revised Technical Guidance, please contact Linda Vogt. Thanks for your interest in risk-based corrective action.
May 5, 2005
The department is posting two documents for the Workgroup.
Meeting Summary: 99 KB
The first document provides a Summary of the April 28, 2005 Workgroup meeting, a list of action items from that meeting, and the attendance.
Background Concentrations: 120 KB
The second document defines background concentrations at a site and discusses a methodology for handling them that could be adopted for use in the MRBCA process. In response to requests at the April 28 meeting, the department is posting this document for comments from the Workgroup. If possible, please call or provide comments to Linda Vogt by May 20, 2005.
April 28, 2005 Workgroup Meeting
Revised Meeting Agenda 13 KB
Comments on Technical Guidance 159 KB from U.S. EPA
April 26, 2005 - Information for April 28, 2005 Meeting
Risk-Based Remediation Rule Workgroup Meeting - April 28, 2005 9:00 a.m. to 4:30 p.m.
Department of Natural Resources, Elm Street Conference Center, Roaring River Conference Room
1738 E. Elm Street, Jefferson City, Mo. *** Agenda RTF ***
Purpose: Discuss Workgroup comments on draft Departmental Missouri Risk-Based Corrective Action Technical Guidance.
As a prelude to the meeting of the Risk Based Remediation Rule Workgroup on Thursday, the department is posting the following responses to the comments that we have received on the draft Departmental Missouri Risk-Based Corrective Action Technical Guidance. We hope that these responses have clarified some issues and can serve as a "starting off" point for our discussions on Thursday.
Please remember that we have expanded the meeting time to run from 9:00 a.m. to 4:30 p.m. The department will soon post an agenda with the meeting times, location, topics of discussion, and call-in number.
With respect to the following documents:
All comments from an individual are contained in italics within the document itself. For the commentors below, no comments have been screened out. The specific comment is in italics, and, in general, the departmental response has been placed below the comment.
Response to Comments on Draft Guidance (in alphabetical order):
Response to comments by Mike Alesandrini, St. Louis RCGA -91 KB
Response to comments by Sherry Boldt, B P America Inc. - 249 KB
Response to comments from ESP - 144 KB
Response to comments from Tim Hippensteel, TH Environmental, LLC - 108 KB
Response to comments from Norella Huggins, Hazardous Waste Management Commission - 110 KB
Response to comments from Ruth C. Mannebach, NPN Environmental - 85 KB
Response to comments from Kevin Perry, Regform - 123 KB
Response to comments by Roger Walker, Armstrong Teasdale - 413 KB
Please call Linda Vogt at 573-751-6998 if you have any questions or need further information.
April 7, 2005
Comments have been received on the draft Departmental Risk-Based Corrective Action
We thank everyone for taking the time to comment on the draft Guidance. We've provided the full text of these comments below.
Comments on Draft Guidance, Nine Sets compiled, including in alphabetical order:
Mike Alesandrini, RCGA
Sherry Boldt, British Petroleum
Scott Clardy, Department of Health and Senior Services
Tim Hippensteel, TH Environmental, LLC
Norella Huggins, Hazardous Waste Management Commission
Ruth Mannebach, NPN Environmental
Earl Pabst, Environmental Services Program, Department of Natural Resources
Kevin Perry, Regform
Jeffery Robichaud, USEPA
Comments from Petroleum Storage Tank Insurance Fund Carol Eighmey, PSTIF
Walker Comments RTF Roger Walker, Armstrong Teasdale
Please contact Linda Vogt, 573-751-6998, if you have any questions about these comments.
By previous email correspondence, the department has notified the Workgroup of the following schedule:
April 12: Draft DNR-created punchlist of issues for review by the Risk-Based Remediation Rule Workgroup (Workgroup).
April 28: Convene
the Risk-Based Remediation Rule Workgroup - Please mark your calendars!
9 a.m. to noon, Roaring River Conference Room, 1738 E. Elm Street, Jefferson City, MO.
April: Reconvene the Institutional Controls Subgroup
Feb. 17, 2005
Review and Comment Information on the
Draft “Departmental Missouri Risk-Based Corrective Action (MRBCA) Technical Guidance" (Memo from Robert Geller, Interim Director, Hazardous Waste Program)
Appendix B and CALM Comparison Table (Memo from Robert Geller, Interim Director, Hazardous Waste Program). 68 KB
Appendix B of the Draft “Departmental Missouri Risk-Based Corrective Action (MRBCA) Technical Guidance” presents the draft Default Target Levels (DTLs) and the Tier 1 Risk-based Target Levels for three different vadose zone soil types.
Dec. 16, 2005 - Correspondence with EPA
The Department's Response Letter (Dec. 16, 2005) - U. S. Environmental Protection Agency's (EPA) October 17, 2005, Comment Letter on the Draft Department Missouri Risk-Based Corrective Action (MBRCA) Technical Guidance document.
Dec. 2, 2004 - Timeline and Toxicity Values
Recommendation from Department of Health and Human Services (DHSS) 961 KB
Tier 1 Risk-Based Target Levels for Cadmium XLS and Vinyl Chloride XLS
TCE Hierarchy / Values XLS
Toxicity table (Under revision)
Sept. 15, 2004, Risk-Based Remediation Rule Workgroup, Jefferson City
Aug. 27, 2004
Per the request of the Workgroup at the Aug. 5, 2004 meeting, the Water Protection Program has revised its previous handout DOC
on Water Quality Criteria and chemicals for which aquatic life and human health criteria may be lower than groundwater criteria, and also for which other criteria exist in the absence of specific criteria for groundwater. WQS MRBCA Criteria Version 2 DOC 52 KB
Aug. 5, 2004
Here are the workgroup draft minutes DOC from the Aug. 5, 2004 meeting of the Risk-Based Remediation Rule Workgroup.
In response to specific requests from Workgroup members, the following links to information are provided:
The U.S. EPA sent out a memo titled,
“Human Health Toxicity Values In Superfund Risk Assessments,” OSWER directive 9285.7-53 , December 5, 2003
This memo is located at: http://www.epa.gov/oswer/riskassessment/pdf/hhmemo.pdf.
July 14, 2004 Ecological Screening.
June 9, 2004
June 9, 2004 Workgroup Minutes DOC
At the June 9 Workgroup meeting, participants requested that DNR set up a conference call-in for the following issue:
The Default Target Levels do not include risk to aquatic life, that most specifically, could be found in underground cave systems and that could come into contact with groundwater. The use of the Ecological Risk Assessment Screening Tool at the default level would remedy this problem.
DNR staff will be available to discuss this issue from 1:30 p.m. to 3:30 p.m. Route 66 Room, on Wednesday, July 14, 2004. The call-in number is 573-751-9630. The following DNR staff will be available:
Ed Galbraith, Director of the Hazardous Waste Program
Jim Hull, Director of the Water Protection Program
John Madras, Policy Coordinator, Division of Environmental Quality
Linda Vogt, MRBCA Coordinator, Hazardous Waste Program
Peter Goode, Section Chief, Water Protection Program
John Hoke, Environmental Specialist, Water Protection Program
John Hoke will present the issue for discussion. The Water Protection Program developed a Position Paper for Workgroup review, discussion and agreement.
Remediation Rule Workgroup
April 6, 2004 Update - Linda Vogt
We are moving along on tasks to complete the MRBCA Technical Guidance. It’s time for an update! As always, I welcome your input on any of the subject areas below, and let me know if you have suggestions to improve the information flow.
Vapor Pathway Subgroup:
This group met on March 16. I am setting up a second meeting. At the March meeting, we identified issues, set up committees to research each issue, and planned to reconvene to reach a resolution. At this time, it appears that the resolution of this issue will center on finding Missouri tweaks to the Johnson/Ettinger model. The results of this meeting are linked below. The background information on the vapor pathway debate is also found below. If you do not have the capability to read Microsoft® Word™ or Corel WordPerfect™ formats, you may still be able to open them with other software.
Chemicals Task Group:
This group is working on identifying chemicals and sources of information and reviewing input parameters used to develop Tier 1 levels. We have developed a list, based upon the department’s CALM list and a list from Idaho, and we plan to produce a draft final on April 13. After that list is drafted, I will send an electronic copy to the Workgroup. Results from both of this group’s meetings are linked below.
Institutional Controls Subgroup:
This group ended with several outstanding issues and was not able to complete a final recommendation without reconvening the entire Workgroup. Hot linked below is a copy of the most recent “Activity and Use Limitations Principles,” proposed guidance which was developed by the department in concert with the subgroup convener, Andrew Bracker. However, it has not been truly reviewed or finalized by the subgroup or the workgroup.
In order to move forward, we have made the decision to use the subgroup recommendations and the attached principles to complete a section in the MRBCA Technical Guidance on this issue. Therefore, I would welcome your comments on the principles for use in development of this section. After the draft MRBCA Technical Guidance is sent to you, we also will work with the feedback received then from the entire Risk-Based Remediation Rule Workgroup to complete the guidance on this issue.
I still do not have a hard and fast date when I will get a draft document to you. Its completion is irrevocably tied to settlement of the vapor pathway issue. I’m finding the greatest difficulty to be, not people’s willingness to work, but their schedules. I do expect to be able to produce a complete draft document for your review about a month after we have resolved this issue.
Thanks, many times over, for your interest and participation in this process.
March 15, 2004 General Update - Linda Vogt
If members of our work group find it useful, I plan to periodically update the membership on the work of subgroups and department staff, meetings, and issues. I welcome your input on any of the subject areas below. Because everyone is very busy, I will keep the information short and to the point. Please let me know if you have any questions or suggestions to improve the information flow!
Because the Tanks MRBCA document needed more discussion and the vapor pathway issue remains unsettled, we have been re-evaluating our March 31 projected date to complete a draft for stakeholder review. In short, we can’t meet it and produce a credible or complete document at the same time.
I still want a timeline that gets the departmental MRBCA Technical Guidance available for stakeholder review in late spring and for public review in the fall. I still want a timeline that enables us to get a RBCA rule to the legislature by next year – a RBCA rule that both reflects the best technical judgment available and is agreed to in our stakeholder workgroup. I apologize for the uncertainty on deadlines and hope that you will bear with me until we nail some dates down. However, as you can see from the following news, we are making quite a bit of progress.
MRBCA Technical Guidance Process:
The Hazardous Waste Program (HWP) has put together a small technical review group from the Department of Natural Resources and the Department of Health and Senior Services. Members will review this guidance as we receive it from Mr. Salhotra, RAM Group. The membership of this group is attached. Our job is to review it for technical accuracy, consistency with the policy decisions of the Process Document, and editorial clarity before the guidance is sent to the stakeholder workgroup. Once we have a complete document, I will send that document to all of you and take the time necessary to resolve any issues that arise. My belief is that, by completing an internal review, we will have a better guidance document to present to you and can then more efficiently identify the differences that need to be resolved.
Vapor Pathway Subgroup:
We scheduled a teleconference, planning meeting for March 16. For those interested, the membership of this group and a draft agenda is attached. I will keep you updated on the actions of this subgroup.
Chemicals Task Force:
This group (membership attached) met on March 8 in Jefferson City. We are working on a list of chemicals for which Default Target Levels (DTLs) will be calculated. We are also reviewing toxicity data and information that is available. Specifically, the group:
- Decided to use the hierarchy for toxicity information presented in a recent EPA memo: Human Health Toxicity Values in Superfund Risk Assessments (OSWER Directive 9285.7-53),
- Directed the RAM group to compile a list of chemicals based upon Missouri’s CALM and the Idaho Risk-Based Decision-Making Document,
- Decided to work with the Tanks Section on numerical values for chemicals given in the Tanks MRBCA. If we find that some overriding or major difference occurs, we will take it up with representatives from Tank, and
- Is reviewing the use of subchronic toxicity values.
Our next meeting is on March 29.
Posting of URL as a residence for information: I intend to place some of the most relevant and most recent documents or information at a URL address. This address will be a "blind page” – meaning that DNR will give the Work Group membership an address where this information will reside. You are of course free to give the address out, but it will not have the status of an “official” departmental website because so much of the information there is considered draft or working copies.
Chemical Task Group
Feb. 5, 2004
Table of Contents for Overarching Guidance Document DOC
Response to the Clean Water and Hazardous Waste Management Commissions Resolution DOC
Missouri Revised Statutes Chapter 319 General Safety Requirements Section 319.107
Missouri Revised Statutes Chapter 644 Water Pollution Section 644.143
Oct. 10, 2003
Water Cleanup Procedures
WPCP Cleanup Procedures
10 CSR 20-7.015 and water quality standards 10 CSR 20-7.031
Page of particular interest: 571 KB
Process Document : On June 3, 2003, the Risk-Based Remediation Rule Workgroup finished the Preliminary Draft Process Document, which incorporates the many policy choices that the group made.