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||
|Division of Environmental Quality Acting Director: Steve Feeler||
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|
|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.