Remediation and Redevelopment Division recommends reassessment of petroleum vapor intrusion pathway after update to the precluding factors checklists
On January 10, 2023, the Michigan Department of Environment, Great Lakes, and Energy (EGLE), Remediation and Redevelopment Division (RRD) revised the Precluding Factors Assessment Checklists for PVI Separation Distances. The revised Precluding Factors Assessment for the PVI Lateral Inclusion Zone Checklist and the Precluding Factors Assessment for the PVI Vertical Separation Distances Checklist update and clarify the use of both the lateral and vertical distances to appropriately screen out structures and properties from further evaluation of the volatilization to indoor pathway (VIAP) for petroleum releases.
If an Owner or Operator (O/O) previously submitted a Final Assessment Report (FAR) or Closure Report (CR) under Part 213, Leaking Underground Storage Tanks, of the NREPA, and received an insufficient information determination or denial due solely to evaluation of the VIAP, RRD recommends the O/O reevaluate the submittal.
After reevaluation, RRD recommends the O/O revise their FAR or CR to include this updated evaluation and resubmit a revised FAR or CR to the RRD District Office for audit under Part 213 if the following information is true for their submittal:
- the O/O determines that the PVI separation distances would now apply,
- the O/O can demonstrate the VIAP has been adequately evaluated, and
- the O/O can demonstrate any exposure risks will be appropriately addressed as part of the corrective action in the FAR or any exposure risks have been appropriately addressed as part of a corrective action completed for the CR.
Additional information can be found by viewing the webinar Petroleum Vapor Intrusion - Updates to the Lateral Inclusion Zone Checklist and Vertical Separation Checklist.
For questions regarding the Precluding Factors Assessment Checklists for PVI Separation Distances and the VIAP in general, please contact Matt Williams, EGLE, RRD, at 517-881-8641, or Williams13@Michigan.gov.
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