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MDNR and Tank Insurance Fund Propose Different Versions of Risk Based Corrective Action
The Missouri Department of Natural Resources (MDNR) and Petroleum Storage Tank Insurance Fund (PSTIF) have both previously drafted separate sets of proposed rules regarding Risk Based Corrective Action (RBCA) for underground storage tank (UST) sites. These two agencies have disagreed on what the RBCA rules should contain based on stakeholder input.
The MDNR and PSTIF agree on many aspects of the RBCA process, however, there are key issues yet to be agreed upon. For instance, the MDNR require delineation of impact to Default Target Levels (DTLs) or residential risk based target levels. Alternatively, the PSTIF proposes delineation criteria based on land use (residential vs. non-residential) and groundwater use (if used for domestic purposes or not). The agencies also differ on the requirement for Long Term Stewardship (LTS) measures such as the Reasonably Anticipated Future Use (RAFU) of a site, and Activity and Use Limitations (AULs).
In an attempt to reach agreement, the MDNR and PSTIF have engaged an independent party to review the differences in their rules. However, the effort did not resolve the key issue discussed above.
SCI will follow this topic closely and provide updates regarding the eventual outcome. If you have questions, or would like additional information about the RBCA process, please contact me.
Jeff Langston, R.G.
Senior Project Scientist
636-949-8200
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