# Presentation: 458366

## Case Study

**Case Study**

**Case Study**

## Case Study

**Case Study**

- Site Scenario
- Former commercial property in Northern U.S.
- Abandoned auto parts distribution center
- Built in 1921
- Vehicle fueling
- Vehicle maintenance
- Surrounding area is mixed-use

## Case Study

**Case Study**

- Site Scenario con’t.
- Former owner went bankrupt, leaving property abandoned
- Municipality is considering potential redevelopment and reuse of the property
- Possible multi-family residential housing

## Case Study

**Case Study**

- Phase I ESA Report
- Records review
- State database search yielded no tanks
- Sanborn and aerial maps identified industrial activity from the 1920’s through 1980’s
- Fire Dept. records identified 1,000 gal diesel UST
- Local tax records – industrial usage
- Interviews
- No current owner or occupants interviewed
- Abutting property owner, former owner interviewed
- Regulator interviews performed – no concerns

**Notes:**
Present from HUD reviewers perspective

Rascher – did fire insurance maps in MI 

## Case Study

**Case Study**

- Phase I ESA Report
- On-Site Inspection – performed in January
- Snow-covered ground
- Limited access due to safety concerns
- Identified potential UST location
- Observed stained soil near suspected vehicle maintenance area
- Residential properties nearby – potential exposures

**Notes:**
Present from reviewers perspective

Rascher – did fire insurance maps in MI 

## Case Study

**Case Study**

- Phase I ESA Report
- Data Gaps
- No current owner/occupant interviewed
- Limited site access, snow covered ground - did EP miss other evidence of releases?
- Approx UST location, but no lines or pumps
- Conclusions - RECs
- Old, steel 1,000 gal diesel UST used for fueling trucks
- Stained soil near vehicle maintenance area

## Case Study

**Case Study**

- Phase II ESA Report
- Was a work plan developed
- Did the plan address the RECs?
- Was a CSM presented?
- Appropriate sampling and analytical procedures?
- Utility Review and Geophysical Survey
- Safety
- Refine UST location
- Located lines and pumps

**Notes:**
Iterative nature of assessment – non-intrusive methods first, followed by more intrusive

## Case Study

**Case Study**

- Phase II ESA Report
- Soil sampling
- Location
- Depth – rationale (UST, staining)
- Real-time field screening (test kits, PID)
- Ground water samples
- Monitoring well, temporary wells, direct-push
- Sampling technique
- Free product present?

**Notes:**
Discuss contents of tank

## Case Study

**Case Study**

- Phase II ESA Report
- Analytical testing
- Understand the potential contaminants and regulations/ criteria that drive risk/cleanup
- Petroleum products
- EPH/VPH, TPH, Lead BTEX, VOC
- Solvents from vehicle maintenance, parts washing
- VOCs (MEK, acetone, TCE, TCA)

**Notes:**
Lead - possible gasoline component

## Case Study

**Case Study**

- Phase II ESA Report
- Data Quality
- DQO’s and performance criteria met?
- Data Evaluation
- GPR results identified location of tank and lines – soil samples collected, no contamination

**Notes:**
Discuss contents of tank

## Case Study

**Case Study**

- Phase II ESA Report
- Data Evaluation
- Soil exceeds residential criteria adjacent to UST and in shallow stained area
- Petroleum products detected in ground water, but within acceptable residential limits
- No ground water usage – city water supply
- Consideration of VI pathway – often different criteria than drinking water

**Notes:**
Part 201 Environmental Remediation
Part 213 Leaking Underground Storage Tanks

Types of Closures Under Part 213
The Michigan-specific risk-based corrective action approach utilizes a tiered evaluation to
determine whether site conditions satisfy generic criteria or allow for the utilization of facility specific
data to adjust the generic criteria; or whether site-specific criteria or institutional controls
allow for closure. Closure categories include:
a) Tier 1 residential unrestricted closure
b) Tier 1 commercial or industrial closure with Notice of Corrective Action (NoCA)
c) Tier 2 or 3 residential, commercial, or industrial closure with site-specific criteria
d) Tier 2 or 3 residential, commercial, or industrial closure with institutional controls

## Case Study

**Case Study**

- Remedial Action
- Remedial Plan
- Summarizes site background and conditions
- Contaminated soil - vertical and horizontal limits
- Tank area 20’ long x 10’ wide x 15’ deep
- Maintenance area 10’ long x 10’ wide x 1’ deep
- Soil cleanup goals = residential standards, consider future use
- No impacted ground water
- Remedial approach – excavate and dispose offsite
- Schedule – start after springs rains, 4 day job

**Notes:**
Discuss off-site disposal options

## Case Study

**Case Study**

- Removal
- Site preparation – fencing, erosion control, permits
- Remove/dispose of tank contents and tank
- Excavation to defined limits – dig with backhoe, stockpile on site
- Confirmation sampling/analysis - 6 locations in bottom/sides of excavation, rapid sample analysis
- Testing shows cleanup goals not met – more extensive contamination present on one side of excavation
- Iterative process - additional excavation and confirmation sampling
- Cleanup goals met? Yes

**Notes:**
Permits – Fire department requires tank pull permit and inspection, soil disposal permit, Miss Dig

Stockpile until all soil is removed to acceptable levels

## Case Study

**Case Study**

- Removal
- Transport and dispose soil offsite
- Fire department inspection
- Place clean backfill, compact soil and confirm soil conditions are suitable for future development
- Site restoration – remove waste repaving, seeding, etc.

**Notes:**
Permits – Fire department requires tank pull permit and inspection, soil disposal permit, Miss Dig

Stockpile until all soil is removed to acceptable levels

## Case Study

**Case Study**

- Closure Report
- Prepared and signed by appropriate professional (PE, Licensed Professional)
- Format and content in compliance with state requirements
- Clearly identifies that remedial goals have been met
- Identifies any long term or continuing obligations and who is responsible for them

## Case Study

**Case Study**

- Closeout
- Written approval received by appropriate state and local regulatory authorities
- All institutional controls have been put in place
- Activity and use limitations are consistent with expected future site use and project needs

## Questions ?

**Questions ?**