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Polsinelli - Environmental and Natural Resources

April 2013

Missouri to Pilot Reforms to Corrective Action Clean-Up Program


Environmental and Natural Resources Attorneys:


Lucas J. Narducci

Practice Area Chair


Tiffany J. Andersen
John D. Burnside
Barton D. Day
Michael C. Ford
Troy B. Froderman
Maribeth M. Klein
Mitchell J. Klein
Margaret B. LaBianca
Anna "Anya" P.B. Mallett
Anthony W. Merrill
John D. Petersen
Frances R. Sjoberg
Megan H. Tracy
Adam R. Troutwine
Andy Wright
Scott A Young








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Businesses involved in clean-up of environmentally contaminated sites often face a time-consuming and expensive process. The Missouri Department of Natural Resources and the Environmental Protection Agency will pilot reforms to hazardous waste clean-ups that the agencies hope will conclude investigations up to 70% faster.

EPA's Region 7 office will work with the Missouri Department of Natural Resources, Hazardous Waste Management Program to open dialogue between regulators and parties responsible for site clean-up early in the process. Doing so will clarify goals and expectations of clean-up efforts, eliminate redundancies of the clean-up process, and expedite review and approval of supporting documentation. The reforms are aimed at finding efficiencies, eliminating waste and improving production time; which in turn results in savings to both government and individuals tasked with completing and paying for clean-up of sites contaminated with hazardous waste.

The EPA and the Missouri Department of Natural Resources, Hazardous Waste Program administer the corrective action program pursuant to the Resource Conservation and Recovery Act ("RCRA"). These government agencies work with owners or operators of contaminated facilities to investigate and clean up releases of hazardous pollutants into the soil, ground water, surface water, and air. The pilot reforms discussed above are part of the EPA's and Missouri's plan to complete corrective action at 95% of the facilities where it is needed by 2020. The pilot program resulted from a week-long meeting in February, 2013 between EPA Region 7, Missouri Department of Natural Resources and stakeholders. Those involved identified the bottlenecks in the corrective action program, and suggested solutions that will enable clean-ups to be completed in approximately five years, as opposed to the 20 years some clean-ups require to complete. A key component to the program is an initial free exchange of information between regulators and parties responsible for clean-up, followed by a framing meeting during which a Corrective Action Agreement will be reached that clearly defines clean-up levels. Additionally, disputes between regulators and responsible parties will be resolved in an internal, less formal process, avoiding administrative tribunals or the courts and saving substantial time and resources.

Per a March 25, 2013 article in Bloomberg's State Environmental Daily publication, details of the pilot program are being finalized and sites willing to participate in the program are still being selected.

Polsinelli's environmental and natural resources attorneys will continue to monitor reforms to the corrective action clean-up program in Missouri and are available to assist clients confronted with clean-up of environmentally contaminated sites. For more information about environmental clean-up activities, Missouri's reforms to its corrective action clean-up program, or other related issues, please contact an attorney with the firm.

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