Appendix C - 2_Memo-Soil_Disposal_at_DTA.pdf
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- Attached to
- R/R Diesel Tank
- Solicitation number
- AEW-0170-0553
- Issued by
- Macomb County, Westland City, Michigan
About this file
This document is a policy memorandum issued by the Department of the Army's Installation Management Command, specifically from the Headquarters of the United States Army Garrison-Detroit Arsenal (USAG-DTA), dated 28 June 2024. The memorandum establishes a comprehensive policy for the disposition of excavated soil at the Detroit Arsenal, applying to all personnel, including tenant organizations, contractors, sub-contractors, and support contractor personnel assigned to or present at the facility. The policy addresses the handling of soil known to contain Per- and Polyfluoroalkyl Substances (PFAS) exceeding Michigan Part 201 Nonresidential Criteria, providing detailed guidelines for soil relocation methods.
The policy outlines three primary methods for soil disposition: transport to a licensed Class II landfill, relocation within the Detroit Arsenal (with specific restrictions for the Centerline Gardens footprint), and off-site relocation to locations other than a licensed landfill. Each method requires comprehensive testing for various contaminants, including PFAS, Michigan 10 metals, Diesel Range Organics (DRO), Gasoline Range Organics (GRO), and other potential pollutants. The document emphasizes strict compliance with Public Act 451 and mandates consultation with the Michigan Department of Environment, Great Lakes and Energy (EGLE) before relocating any potentially contaminated soil, with the primary goal of mitigating risks associated with soil contamination and preventing the spread of hazardous substances.
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DEPARTMENT OF THE ARMY
INSTALLATION MANAGEMENT COMMAND
HEADQUARTERS, UNITED STATES ARMY GARRISION-DETROIT ARSENAL
6501 E. ELEVEN MILE ROAD
DETROIT ARSENAL, MICHIGAN 48397-5000
AMIM-MIG-ZA (200-1d) 28 JUNE 2024
MEMORANDUM FOR ALL Detroit Arsenal (USAG-DTA) Personnel, to include Tenant Organizations, Contractors, Sub-Contractors, and Support Contractor Personnel assigned to or Present for Duty, at the Detroit Arsenal
SUBJECT: Installation Policy 2, Memorandum – Disposition of Excavated Soil at Detroit Arsenal
1. REFERENCES:
a. Army Regulation 200-1 (Environmental Protection and Enhancement), 13 December 2007
b. DoDD 4715.07 (Defense Environmental Restoration Program (DERP)), 31 August 2018
c. DoDM 4715.20 (Defense Environmental Restoration Program Manual), 31 August 2018
d. Policy Memo (Timely Identification and Mitigation of Contaminated Soil at Proposed Construction Sites on Installation Management Command Installations), 29 August 2023
2. PURPOSE. Provide consistent process for the disposition of soil excavated from DTA to mitigate risk of exposure to contaminated soil.
3. APPLICABILITY. This policy applies to all personnel (to include tenant organizations, contractor, sub-contractors, and/or support contractor personnel performing work for or on behalf of the Installation) assigned to or present for duty, on the Detroit Arsenal (DTA). Further, this policy applies to any and all construction projects of any size/scope that produce excess excavated soil that cannot be replaced in the immediate project area.
4. POLICY. Soil at the DTA has been known to contain Per- and Polyfluoroalkyl Substances (PFAS) exceeding Michigan Part 201 Nonresidential Criteria. All soil being relocated at the DTA shall be tested for PFAS prior to being relocated on-site or off-site. Soil displaced from its original position during construction can be relocated using one of the following methods:
a. Transport to a Licensed Class II Landfill:
(1) Inform the landfill that the soil could contain PFAS.
AMIM-MIG-ZA (200-1d) SUBJECT: Policy Memorandum – Disposition of Excavated Soil at Detroit Arsenal
(2) Follow the landfill instructions for waste characterization prior to transporting the soil off-site.
b. Relocate Soil to another Location on the Detroit Arsenal:
(1) If the soil will be placed within the footprint of Centerline Gardens, the soil must first be tested for PFAS, Michigan 10 metals, Diesel Range Organics (DRO) and Gasoline Range Organics (GRO). If the soil contains any concentrations of PFAS, DRO, GRO, or contains a concentration of Michigan 10 metals above the most restrictive Michigan Part 201 residential criteria, do not relocate to Centerline Gardens footprint.
(2) For soil being relocated to locations on the DTA, other than Centerline Gardens, test the soil for PFAS. If the soil does not contain PFAS, the soil may be relocated on-site (apart from Centerline Gardens).
c. Relocate Off-Site to a Location other than a Licensed Class II Landfill:
(1) Refer to Public Act 451, 324.20120c, Relocation of Contaminated Soil.
(2) Follow ALL requirements specified in Public Act 451, 324.20120c.
(3) Ensure the soil has been tested for PFAS, Michigan 10 metals, DRO, GRO, Full Scan SVOCs and VOCs. Disclose the results to the owner of the receiving property before transporting the soil to the site.
(4) Ensure the soil being relocated off-site does not contain a contaminant that would exacerbate existing contamination at the receiving site.
(5) Do not transport contaminated soil to a clean site.
(6) Consult with Michigan Department of Environment, Great Lakes and Energy (EGLE) to discuss the specifics of the relocation plan before relocating any soil that may be considered contaminated.
5. PROPONENT. The proponent for this policy is the Directorate of Public Works, Environmental Division Chief, (AMIM-MIP-E) at (520) 941-8986.
CARRIE MEAD
Garrison Manager
MEAD.CARRIE.ELIZ
ABETH.109770218
Digitally signed by
MEAD.CARRIE.ELIZABETH.10977
02183 Date: 2024.07.01 17:43:18 -04'00'
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