hazardous waste program overview and update by lamb, david; flippin, kathy; nussbaum, richard;...

David Lamb, Director, Hazardous Waste Program

Kathy Flippin, Chief, Compliance & Enforcement Section

Rich Nussbaum, Chief, Permits Section Chief

Hazardous Waste Program

Overview and Update

Key Program Issues

• HB1251 Implementation

• HB28/650 Implementation

• Tanks Risk Based Corrective Action

(RBCA) Guidance and Rulemaking

• Update to Departmental RBCA –

Risk Based Target Levels (RBTLs)

• Long Term Stewardship (LTS)

HB1251 Implementation

• Statute requires Department to identify rules in

Chapters 3, 4, 5 and 7 of the hazardous waste

regulations that are inconsistent with the

requirements of the law by Dec. 31, 2013

• Rule amendments to address inconsistencies in

the rules need to be in place by Dec. 31, 2015

• After Dec 31, 2015, rules inconsistent with

statute will be null and void to the extent they are

inconsistent

HB1251 Implementation

Other rule changes to be included in

HB1251 rule package:

• Adoption of new federal rules

• Removal of outdated or unnecessary rules

• Container and tank labeling provisions

• Corrections to references throughout all of the

rules referring to rules being removed or

reorganized as a result of rule changes

HB 28/HB650 Hazardous Waste Program Related

Provisions

• Extends the battery fee and the hazardous waste

generator fees until Dec.31, 2018

• Gives the Department the authority to conduct a

comprehensive review of the hazardous waste fee

structure, and outlines process to implement revised

fee structure by rule

• Adds a representative of the petroleum retail

industry to HWMC

HB 28/HB650 Hazardous Waste Program Related

Provisions

• Streamlines some of the requirements of

the hazardous waste permitting process: – Health profiles

– Habitual violator review

– 5-year reviews at land disposal facilities

– Post closure permits

– Transportation route evaluations

Tanks Risk Based Corrective Action

• Three rule amendments approved

by the HWMC on Oct. 17, 2013

• Amendments necessary to allow

use of Risk-Based Corrective Action

(RBCA) guidance after Dec. 31, 2012

• Incorporates into rule by reference

a version of the RBCA guidance

updated in 2013

Tanks RBCA • Some Key Changes to Guidance

– Consolidates previous guidance and

amendments into a streamlined document

– Revises the Risk Based

Target Levels (RBTLs)

– Eliminates soil type specific

RBTLS at Tier 1

– Numerous clarifications to

existing requirements

Tanks RBCA Rulemaking Schedule:

• Nov. 20, 2013 – File amendments with the

Secretary of State (SOS)

• Jan. 2, 2014 – SOS to publish

order of rulemaking in Missouri Register

• Jan. 29, 2014 – SOS to publish rules in Code of

State Regulations

• Feb. 28, 2014 - Rules effective

Departmental RBCA RBTLs

• Working with Department of Health and

Senior Services to develop revised RBTLs

for the Departmental RBCA

• RBTLs have not updated since 2006

• Update will make the RBTLs more

consistent with the Environmental

Protection Agencies Regional Screening

Levels (RSLs)

Long Term Stewardship

• More than 1500 Risked Based Cleanups

completed in Missouri

• Contamination allowed to remain in place

at these sites with Restricted Covenants or

Engineering Controls in place to prevent

exposure

• Tracking of these sites is needed to

ensure that protections remain in place

Long Term Stewardship

• Preparing to update online mapper system

• Map currently only

includes BVCP sites

• Will expand to include

other sites when data ready

• Will expand to include

Superfund, Federal Facilities

and RCRA Corrective Action sites

Hazardous Waste Program –

Compliance & Enforcement Section

November 2013

Heather Peters

Environmental Specialist IV

Angela Oravetz

Environmental Specialist III

Chris Plassmeyer


Daniel Knaebel


Coy King

Environmental Specialist I

Scott Walker


Mike Martin


UST Compliance and Technology Unit

Andrew Reed


Caroline Wainaina


Billie Hainds


David Giarratano


Special Facilities Unit

Evan Bryant


Debra Dieckow


Anthony Pierce


Dennis Hansen

Environmental Specialist

1,000 Hour

Joy Johnson


Mike Struckhoff

Environmental Specialist

500 Hour

Nicole Eby


Hazardous Waste Enforcement Unit

Christi Allee

Office Support Assistant

Kathleen Gregory

Office Support Assistant

Cheryl Heet

Senior Ofice Support Assistant

Administrative Specialist Unit

Debra Sessler

Planner II

Kathy Flippin

Environmental Manager

C & E Section Initiatives or Focus

Activities Since November 2012

• Staff hiring

• “No stricter than” federal reg revisions

• Updates to underground storage tank regs

• Inspection checklist revisions and additions

• Meeting mandates of the 2005 Energy

Policy Act for underground storage tanks

Challenges

• Hiring and retention

• Maintaining and sharing institutional knowledge

• Responding to multiple priorities (public

inquiries, stakeholder communications,

inspection and enforcement core activities)

• Consensus building/public involvement

• Speed of progress/reaction to new laws, rules

and initiatives

Hazardous Waste Program - Permits Section

November 2012 – How We Looked a Year Ago…

Lynn Hartman

Environmental Specialist I/II/III

Heidi Rice


Brenda Irey

Research Analyst I/II

Sabir Vali, P.E.

Environmental Engineer III

Theresa Doggett

Planner II

Jacki Hicks


Outreach, Planning & Stewardship Unit

VACANT

Environmental Engineer I/II

Meagan Prestegard , P.E.


David Walker


Nathan Graessle

Environmental Engineer I /II

Nathan Kraus


Dustin Thoenen


Darleen Groner P.E.

Environmental Engineer IV

Operating Facilities Unit

Maria Bonney


Don Dicks


Sushmita Sharma


VACANT


Bill Fanska, P.E.


Christine Kump-Mitchell. P.E.


VACANT

Environmental Enginee r IV

Corrective Action & Groundwater Unit

Melinda Jones


Sharon Wilde


Administrative Unit

Bruce Stuart, P.E.,R.G.


Senior Technical Advisor

Richard Nussbaum, P.E., R.G.


Hazardous Waste Program - Permits Section

November 2013 – The Changing of the Guard….

Lynn Hartman


Heidi Rice


VACANT

Research Analyst I/II

Sabir Vali, P.E.


Theresa Doggett

Planner II

Jacki Hicks


Outreach, Planning & Stewardship Unit

Jay Liu


Meagan Prestegard , P.E.


David Walker


VACANT


Nathan Kraus


Dustin Thoenen


Acting Unit Chief - Bill Fanska, P.E.

Environmental Engineer IV

Operating Facilities Unit

VACANT


Don Dicks


Sushmita Sharma, P.E.


Jonathan McKinney


Bill Fanska, P.E.


Christine Kump-Mitchell. P.E.


Jalal El-Jayyousi , P.E.

Environmental Enginee r IV

Corrective Action & Groundwater Unit

Melinda Jones


Dee Galbreath


Administrative Unit

Bruce Stuart, P.E.,R.G.


Senior Technical Advisor

Richard Nussbaum, P.E., R.G.


Permits Section New Initiatives Since

November 2012

• Staff hiring

• Permits streamlining HB28/650

• Corrective Action Project LEAN

• LTS database population

Challenges

• Recruitment and retention (especially engineers)

• Consensus building/public involvement

• Speed of progress/reaction to new laws, rules

and initiatives

• Customer Service – balancing work on national

GPRA goals negotiated with EPA and regulated

facility economic development/business needs

(e.g., permit modifications not known at the time

of work plan negotiations with EPA)

Questions?

Hazardous Waste Program

1730 East Elm Street

PO Box 176

Jefferson City, M0 65102

(573) 751-3176

hazardous waste program overview and update by lamb, david; flippin, kathy; nussbaum, richard;...

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