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
01/2016
Division of Environmental Quality Director: Leanne Tippett Mosby
PUB2483

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

HWP 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 RG or PE under the Board of Geologist Registration Act.

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 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.

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.