Remediation and Redevelopment Division releases Michigan Risk-Based Corrective Action (MIRBCA) Technical Guidance Document and Report Forms
The Michigan Department of Environment, Great Lakes, and Energy (EGLE), Remediation and Redevelopment Division (RRD) has developed guidance and forms for conducting corrective actions at petroleum leaking underground storage tank (LUST) sites according to the ASTM International Risk-Based Corrective Action (RBCA) process. The Michigan RBCA (MIRBCA) Technical Guidance document provides an RRD-approved method for implementing the RBCA process at petroleum LUST sites that is technically defensible, protective of human health and the environment, and consistent with both applicable ASTM International (ASTM) standards and Part 213, Leaking Underground Storage Tanks, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (Part 213).
It is critical to take time to read and understand the guidance document as it represents a paradigm change in the implementation of corrective actions that aligns with the ASTM RBCA process, as required by Part 213. EGLE provided a four-part webinar training series on the MIRBCA Technical Guidance document and report forms that can be accessed at the Remediation and Risk Management webinar series.
RRD has created a series of report forms to assist users in providing information required under Part 213. The MIRBCA report forms can be downloaded from RRD's LUST webpage. The download link is to a .zip file that contains four separate documents, including: (1) Tier 1 forms, (2) Tier 2 forms, (3) a standardized format for data tables, and (4) instructions for completing the report forms. These forms provide clarity in reporting requirements, provide a means to present a systematic risk-based evaluation of data, and are required for all reports pursuant to Section 21316 of Part 213. An optional computational software package to calculate Tier 2 site-specific target levels has been developed for the MIRBCA program and will be available from a third-party vendor.
RRD will allow a phased-in approach to implementing the MIRBCA process. The MIRBCA Technical Guidance document and Report Forms are available for immediate use but will not be required until October 1, 2025. After October 1, 2025, all reports required by Part 213 (1) must be completed using the MIRBCA Report Forms and Data Tables, and (2) are intended to be submitted electronically using the Remediation Information Data Exchange (RIDE) with the required RIDE submittal form. The RIDE submittal forms for Part 213 reports (i.e., EQP cover sheets) will be available only through the RIDE system. Submittals provided through regular mail, email, and other means without the required RIDE submittal form may not comply with the applicable regulatory requirements to be accepted by the department.
Questions regarding MIRBCA implementation and Part 213 can be directed to Dr. Steve Beukema, Part 213 Program Coordinator, at BeukemaS@michigan.gov, 269-547-0125, or can be sent to EGLE-RRD-MIRBCA@michigan.gov.
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