Armory Closure Rep 1-29-2025.r.pdf

MICHIGAN DEPARTMENT OF ENVIRONMENT, GREAT LAKES, AND ENERGY

Remediation and Redevelopment Division

Leaking Underground Storage Tank Closure Report Cover Sheet

☐ NEW ☐ REVISED PER EGLE AUDIT

Instructions:

COMPLETION OF THIS REPORT WITH ALL APPLICABLE INFORMATION IS MANDATORY

pursuant to Part 213, Section 324.21312a of the Leaking Underground Storage Tanks, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Check one of the boxes above to indicate whether this is a new or revised submittal. The Owner/Operator (O/O) and Qualified Underground Storage Tank Consultant (QC) must complete the affidavits on page 2.

Please submit the completed closure report cover sheet and Table of Contents (Form EQP4008) to the appropriate District Office.

Site Information:

Site Name: _____________________________________ Facility ID Number: _________________

Street Address: ___________________________________________________________________

City: ____________________________ ZIP Code: ____________ County: ____________________

Date(s) Release(s) Discovered: _______________________________________________________

Confirmed Release Number(s): _______________________________________________________

O/O Name: _______________________________ O/O Email Address: _______________________

O/O Street Address: ________________________________________________________________

City: ____________________________ State: _________________ ZIP Code: _________________

Contact Person: ___________________________________________________________________

Phone Number: ____________________________ Fax Number: ____________________________

Permission is given for EGLE to contact the Qualified Consultant:

☐ Yes ☐ No

Michigan.gov/EGLE Page 1 of 6 EQP4452 (Rev. 12/2024) https://Michigan.gov/EGLE

Closure Report Information: Answer All Questions (Do Not Leave Blanks)

1. Site Classification (1-5): _____ Previous Site Classification (1-5): _____

Type of RBCA evaluation: ☐ Tier I ☐ Tier II ☐ Tier III

2. Does the report include:

SSTLs developed by the O/O for the VIAP or any other pathway? ☐ Yes ☐ No

The use of the 2020 VIAP Screening Levels (SLs) as SSTLs? ☐ Yes ☐ No

If using VIAP SLs as SSTLs, report includes VIAP Screening Levels Assessment Checklist and supporting documentation.

☐ Yes ☐ No

3. Substance(s) released:

☐Gasoline ☐ Diesel ☐ Ethanol: ☐ E-10 or ☐ E-85

☐ Other If Other: __________________________________________________

4. Has contamination migrated off-site above Residential RBSL? ☐ Yes ☐ No

Residential SSTLs? ☐ Yes ☐ No

If YES, have off-site impacted parties been notified per Section 324.21309a(3) of Part 213?

☐ Yes ☐ No

5. Predominant groundwater flow direction: _________________________________________

Shallowest depth to groundwater: _______________________________________________

6. Is mobile NAPL present: Currently: ☐ Yes ☐ No Previously: ☐ Yes ☐ No

If present, was it recovered? ☐ Yes ☐ No

If recoverable, total gallons recovered since last reported: ___________ To Date: __________

7. Was migrating NAPL present: ☐ Yes ☐ No

If yes, were actions taken to stop the NAPL migration? ☐ Yes ☐ No

Michigan.gov/EGLE Page 2 of 6 EQP4452 (Rev. 12/2024)

8. Since last report: Cubic yards of soil remediated: _________________________________

Gallons of groundwater remediated: _____________________________

Totals to date: Cubic yards of soil remediated: _________________________________

Gallons of groundwater remediated: _____________________________

9. Have explosive hazards and/or acute vapor hazards been identified?

☐ Yes ☐ No

10.Drinking water supply affected?

Currently: ☐ Yes ☐ No Previously: ☐ Yes ☐ No

Indicate type and number of wells affected:

☐ Private Number of wells: ____________

☐ Public Type II/III Number of wells: ____________

☐ Municipal Number of wells: ____________

11.Has the release affected surface water or wetlands? ☐ Yes ☐ No

12.Estimated distance and direction from point of release to nearest:

Private Well: ____________ Municipal Well: ____________

Surface water/wetland: ____________

Is site within a wellhead protection zone? ☐ Yes ☐ No

13.Closure Report based on which type of land use?

☐ Residential ☐ Nonresidential

14.Does the report include a request for:

EGLE approval for GSI Compliance? ☐ Yes ☐ No

Groundwater not in an aquifer determination? ☐ Yes ☐ No

Institutional controls? ☐ Yes ☐ No

Michigan.gov/EGLE Page 3 of 6 EQP4452 (Rev. 12/2024)

15. Institutional Controls:

☐ None ☐ Notice of Corrective Action ☐ Restrictive Covenant ☐ Other

If Other: ____________________________________________________________________

16.What type of Corrective Action was completed? (i.e., Air Sparge/Soil Vapor Extraction;

Monitored Natural Attenuation; Multi-phase Extraction; Excavation; Institutional Controls; etc.):

CLOSURE REPORT AFFIDAVITS: (Must Be Completed Before Submitting Form)

Owner/Operator Affidavit Of Report Completeness:

I attest that the information upon which the closure report is based is complete and true to the best of my knowledge, in accordance with Part 213, Leaking Underground Storage Tanks, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended.

Signature of Owner or Operator/Affidavit Print Name Date

Name of Company (if applicable): ______________________________________________________

Address: _________________________________________________________________________

City: ___________________________ State: _________________ ZIP Code: _________________

Phone Number: ______________________________ Email: _______________________________

Sworn to before me and subscribed in my presence this ______ day of _______________, 20___.

Notary Public Print Name

County of ______________________ My Commission Expires_____________

Acting in the County of _______________________

Michigan.gov/EGLE Page 4 of 6 EQP4452 (Rev. 12/2024)

Qualified Underground Storage Tank Consultant Affidavit Of Closure:

As preparer of the Closure Report, I attest to the fact that the corrective actions detailed in the closure report complies with all applicable requirements under the applicable Risk Based Corrective Action standard and that the information upon which the closure report is based is true and accurate to the best of my knowledge. By signing this form, I certify that I meet the qualified underground storage tank consultant requirements identified in section 324.21325 of Part 213, Leaking Underground Storage Tanks, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Attached is a Certificate of Insurance demonstrating that I have obtained the insurances required by sections 324.21312a(1)(c) and 324.21325.

Signature of Qualified UST Consultant Print Name Date

Name of Company (if applicable): ______________________________________________________

Address: _________________________________________________________________________

City: ___________________________ State: _________________ ZIP Code: _________________

Phone Number: ______________________________ Email: _______________________________

Sworn to before me and subscribed in my presence this ______ day of _______________, 20___.

Notary Public Print Name

County of _______________________________ My Commission Expires______________________

Acting in the County of _______________________

Submission Information:

This form should be submitted to the EGLE Remediation and Redevelopment Division (RRD), unless regulated by another division in which case contact should be made with that division for information on where to provide the form and report. Submittals to RRD can be provided electronically using the Remediation Information Data Exchange (RIDE). For more information on submitting forms electronically using RIDE, please visit EGLE's RIDE Webpage. Hardcopy submittals should not be provided if RIDE is used to upload the submittal. If the submittal is being provided as a hardcopy only, it can be sent to RRD using the following address:

Michigan.gov/EGLE Page 5 of 6 EQP4452 (Rev. 12/2024) https://gcc02.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.michigan.gov%2Fegle%2Fmaps-data%2Fride&data=05%7C02%7CBecseyS%40michigan.gov%7C1fd2016a40dc4ec7367108dd186e632c%7Cd5fb7087377742ad966a892ef47225d1%7C0%7C0%7C638693584559921050%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=JjEPznmxzP37jSLiXzceeXJ7CocBKYKzdIY9Jj%2FWBU4%3D&reserved=0

Michigan Department of Environment, Great Lakes, and Energy Remediation & Redevelopment Division PO Box 30426 Lansing, MI 48909-7926

If you need this information in an alternate format, contact EGLE-Accessibility@Michigan.gov or call 800-662-9278.

EGLE does not discriminate on the basis of race, sex, religion, age, national origin, color, marital status, disability, political beliefs, height, weight, genetic information, or sexual orientation in the administration of any of its programs or activities, and prohibits intimidation and retaliation, as required by applicable laws and regulations.

This form and its contents are subject to the Freedom of Information Act and may be released to the public.

Michigan.gov/EGLE Page 6 of 6 EQP4452 (Rev. 12/2024) mailto:EGLE-Accessibility@Michigan.gov

03/28/2024

Brown & Brown Insurance Services, Inc.

1720 SE 16th Avenue, Suite 301

Ocala FL 34471

Brenda Bouchard AAI, CPIW

(352) 732-5010 (352) 732-5344

Brenda.Bouchard@bbrown.com

Environmental Consulting & Technology, Inc.

7027 SW 24th Ave

Gainesville FL 32607

Lloyd's of London 085202 Hartford Fire Insurance Company 19682 Hartford Insurance Company of the Southeast 38261

24-25

A Professional Liability-$1,000,000 Pollution Liability-$1,000,000

Prof. Liab is Claims Made

ENVP000005424 04/01/2024 04/01/2025

1,000,000 300,000 25,000 1,000,000 2,000,000 2,000,000

Agg applies GL/PL/Poll 2,000,000

B 21UENOL5857 04/01/2024 04/01/2025

1,000,000

A

ENVX000003924 04/01/2024 04/01/2025

5,000,000 5,000,000

C N 21WEOL6HFG 04/01/2024 04/01/2025

1,000,000 1,000,000 1,000,000

B Rented/Leased Equipment

21MSDQ2471 04/01/2024 04/01/2025

Limit $100,000

Sample Certificate Excess Liability policy #ENVX000003922 Effective 1/1/2022-1/1/2023 Limits 10 Million each occurrence Aggregate 10 million

Environmental Consulting & Technology, Inc.

7027 SW 24th Ave

Gainesville FL 32607

SHOULD ANY OF THE ABOVE DESCRIBED POLICIES BE CANCELLED BEFORE

THE EXPIRATION DATE THEREOF, NOTICE WILL BE DELIVERED IN

ACCORDANCE WITH THE POLICY PROVISIONS.

INSURER(S) AFFORDING COVERAGE

INSURER F :

INSURER E :

INSURER D :

INSURER C :

INSURER B :

INSURER A :

NAIC #

NAME:

CONTACT

(A/C, No):

FAX

E-MAIL

ADDRESS:

PRODUCER

(A/C, No, Ext):

PHONE

INSURED

REVISION NUMBER:CERTIFICATE NUMBER:COVERAGES

IMPORTANT: If the certificate holder is an ADDITIONAL INSURED, the policy(ies) must have ADDITIONAL INSURED provisions or be endorsed.

If SUBROGATION IS WAIVED, subject to the terms and conditions of the policy, certain policies may require an endorsement. A statement on this certificate does not confer rights to the certificate holder in lieu of such endorsement(s).

THIS CERTIFICATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER. THIS CERTIFICATE DOES NOT AFFIRMATIVELY OR NEGATIVELY AMEND, EXTEND OR ALTER THE COVERAGE AFFORDED BY THE POLICIES BELOW. THIS CERTIFICATE OF INSURANCE DOES NOT CONSTITUTE A CONTRACT BETWEEN THE ISSUING INSURER(S), AUTHORIZED

REPRESENTATIVE OR PRODUCER, AND THE CERTIFICATE HOLDER.

OTHER:

(Per accident)

(Ea accident)

N / A

SUBR

WVD

ADDL

INSD

THIS IS TO CERTIFY THAT THE POLICIES OF INSURANCE LISTED BELOW HAVE BEEN ISSUED TO THE INSURED NAMED ABOVE FOR THE POLICY PERIOD INDICATED. NOTWITHSTANDING ANY REQUIREMENT, TERM OR CONDITION OF ANY CONTRACT OR OTHER DOCUMENT WITH RESPECT TO WHICH THIS CERTIFICATE MAY BE ISSUED OR MAY PERTAIN, THE INSURANCE AFFORDED BY THE POLICIES DESCRIBED HEREIN IS SUBJECT TO ALL THE TERMS, EXCLUSIONS AND CONDITIONS OF SUCH POLICIES. LIMITS SHOWN MAY HAVE BEEN REDUCED BY PAID CLAIMS.

$PROPERTY DAMAGE

BODILY INJURY (Per accident)

BODILY INJURY (Per person)

COMBINED SINGLE LIMIT

AUTOS ONLY

AUTOSAUTOS ONLY

NON-OWNED

SCHEDULEDOWNED

ANY AUTO

AUTOMOBILE LIABILITY

Y / N

WORKERS COMPENSATION

AND EMPLOYERS' LIABILITY

OFFICER/MEMBER EXCLUDED?

(Mandatory in NH)

DESCRIPTION OF OPERATIONS below If yes, describe under

ANY PROPRIETOR/PARTNER/EXECUTIVE

E.L. DISEASE - POLICY LIMIT

E.L. DISEASE - EA EMPLOYEE

E.L. EACH ACCIDENT

ER

OTH-

STATUTE

PER

LIMITS(MM/DD/YYYY)

POLICY EXP

(MM/DD/YYYY)

POLICY EFF

POLICY NUMBERTYPE OF INSURANCELTR

INSR

DESCRIPTION OF OPERATIONS / LOCATIONS / VEHICLES (ACORD 101, Additional Remarks Schedule, may be attached if more space is required)

EXCESS LIAB

UMBRELLA LIAB $EACH OCCURRENCE

$AGGREGATE

OCCUR

CLAIMS-MADE

DED RETENTION $

$PRODUCTS - COMP/OP AGG

$GENERAL AGGREGATE

$PERSONAL & ADV INJURY

$MED EXP (Any one person)

$EACH OCCURRENCE

DAMAGE TO RENTED

$PREMISES (Ea occurrence)

COMMERCIAL GENERAL LIABILITY

CLAIMS-MADE OCCUR

GEN'L AGGREGATE LIMIT APPLIES PER:

POLICY

PRO-

JECT LOC

CERTIFICATE OF LIABILITY INSURANCE DATE (MM/DD/YYYY)

CANCELLATION

AUTHORIZED REPRESENTATIVE

ACORD 25 (2016/03)

© 1988-2015 ACORD CORPORATION. All rights reserved.

CERTIFICATE HOLDER

The ACORD name and logo are registered marks of ACORD

HIRED

AUTOS ONLY

tkolnes Highlight tkolnes Highlight tkolnes Highlight tkolnes Highlight

Michigan.gov/EGLE Page 1 of 3 EQP4008 (Rev. 9/2022)

MICHIGAN DEPARTMENT OF ENVIRONMENT, GREAT LAKES, AND ENERGY

Remediation and Redevelopment Division

CLOSURE REPORT TABLE OF CONTENTS FORM

INSTRUCTIONS

Utilize the following Table of Contents (TOC) to ensure that all information required by Part 213, Leaking Underground Storage Tanks, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended, is provided in the Closure Report. RBCA is defined in Part 213 as the ASTM standards E 1739-95 (2010), E 2081-00 (2010), and E 2531-06. Information in these standards must be provided, as applicable per site conditions. The Department of Environment, Great Lakes, and Energy (EGLE) may request supporting documentation to the data and conclusions of the Closure Report, which may include information in the ASTM standards referenced above.

Complete the Closure Report cover sheet and pages 1 through 2 of the TOC. The order and format in which the information is provided is at the submitter’s discretion. Each page of the report, including appendices, should be consecutively numbered. The column labeled as “Page(s)” should be completed with the range of page numbers for each section. You may reference previously submitted material by specifying where the information is located within the referenced document. Submit the documentation identified in Section IV, as applicable, if IAR/FAR was not previously submitted or additional site characterization was performed following submittal of FAR.

CLOSURE REPORT TABLE OF CONTENTS (TOC) PAGE(s)

A. SUMMARY OF CORRECTIVE ACTION ACTIVITIES AND

DOCUMENTATION OF THE BASIS FOR CONCLUDING THAT

CORRECTIVE ACTIONS HAVE BEEN COMPLETED

1. Provide a summary of the current and completed corrective actions activities.

2. Identify Chemical(s) of Concern (CoC), their source location(s) and remaining maximum concentrations of CoC in soil and groundwater.

3. Summarize the Non-aqueous Phase Liquid (NAPL) remaining.

4. Identify human and environmental receptor locations that could be impacted (i.e., point(s) of exposure).

5. Identify any complete transport and exposure pathways (e.g., dissolved plume, vapor migration through soils, utilities, etc.).

6. Identify current or potential future use of the site and surrounding land, and of the groundwater, surface water, and sensitive habitats.

7. Provide a final Conceptual Site Model (CSM) / NAPL CSM.

8. Summarize and discuss the risk assessment and RBCA tier evaluation

Michigan.gov/EGLE Page 2 of 3 EQP4008 (Rev. 9/2022)

CLOSURE REPORT TOC PAGE 2 OF 3 PAGE(s)

A. SUMMARY OF CORRECTIVE ACTION ACTIVITIES AND

DOCUMENTATION OF THE BASIS FOR CONCLUDING THAT

CORRECTIVE ACTIONS HAVE BEEN COMPLETED (Continued)

Reference: Part 213 Section 21311a(a) and Section 21312a; ASTM E1739-95 (2010), Section 6.2, Section 6.11 through 6.11.19; and ASTM 2531-06, Section 6.3.

Conceptual Site Models/LCSMs: Part 213, Section 21309a(2)(a), Section 21311a.(1)(c)(ii), and Section 21312a; ASTM 2531-06, Sections 6 and 7; and ASTM E2081-00 (2010), Section 3.2.52

B. CLOSURE VERIFICATION SAMPLING RESULTS

1. Provide a summary of the analytical data and the appropriate RBSL or SSTL used.

2. Provide the following maps and figures:

a. A site map of the location.

b. An extended site map to include nearby parcels and their use, nearby groundwater supply wells, site plan view showing location of structures, ASTs, USTs, buried utilities and conduits, suspected/confirmed sources.

c. Map(s) and cross-sections of the remaining groundwater plume and impacted soil.

d. A groundwater elevation map, including a depiction of the groundwater flow direction (may reference the FAR if unchanged).

e. Map(s) and cross-sections depicting remaining 3-dimensional extent of

NAPL.

Reference: Part 213, Section 21311a(a), and Section 21312a;

ASTM E1739-95 (2010), Section 6.2, Section 6.11 thru 6.11.19;

ASTM 2531-06, Section 6.3, and Section 6.7 thru 6.7.3

C. INSTITUTIONAL CONTROLS

1. Provide an explanation of land or resource use restrictions (i.e., Notice of Corrective Actions, Institutional Controls, Restrictive Covenants, Alternative Mechanisms, Notice of Land Use Restrictions), and how they will prevent or control unacceptable exposures. Provide a copy of the recorded instrument.

2. Provide a copy of the notice and proof of providing the notice to the public directly impacted by the release above a residential RBSL and the proposed corrective action.

Michigan.gov/EGLE Page 3 of 3 EQP4008 (Rev. 9/2022)

CLOSURE REPORT TOC PAGE 3 OF 3 PAGE(s)

C. INSTITUTIONAL CONTROLS (Continued)

Reference: Part 213, Section 21310a, and Section 21312a

D. APPLICABLE IAR/FAR DOCUMENTATION

1. If the IAR/FAR was not previously submitted or additional site characterization was performed following submittal of FAR, then refer to IAR/FAR Tables of Contents and include all relevant information that is not already provided in this closure report.

Reference: Site Description, Assessment and Evaluation: Part 213, Section 21311a(a), and Section 21312a; ASTM E1739-95(2010), Section 6.2, Section 6.5, Section 6.6, and Section 6.11 thru 6.11.19

Corrective Action Activities: Part 213, Section 21309a, Section 21311a(b), Section 21312a; ASTM E1739-95(2010), Section 6.2.2, Section 6.7 thru 6.7.3, Section 6.8 thru 6.83, and Section

6.6 thru 6.9.2

If you need this information in an alternate format, contact EGLE-Accessibility@Michigan.gov or call 800-662-9278.

EGLE does not discriminate on the basis of race, sex, religion, age, national origin, color, marital status, disability, political beliefs, height, weight, genetic information, or sexual orientation in the administration of any of its programs or activities, and prohibits intimidation and retaliation, as required by applicable laws and regulations. Questions or concerns should be directed to the Nondiscrimination Compliance Coordinator at EGLE- NondiscriminationCC@Michigan.gov or 517-249-0906.

This form and its contents are subject to the Freedom of Information Act and may be released to the public.

LUST Closure Report Detroit Olympia Armory

Facility ID # 00037247 January 29, 2025 ectinc.com

A. Summary of Corrective Action Activities and Documentation of the Basis for Concluding that Corrective Actions Have Been Completed

1. Provide a summary of the current and completed corrective actions activities.

The Michigan Department of Military and Veterans Affairs (MDMVA). retained Environmental Consulting & Technology, Inc. (ECT) to conduct corrective action activities pursuant to Part 213 of the Natural Resources and Environmental Protection Act (NREPA), 1994 PA 451, as amended, at the Detroit Olympia Armory facility (hereinafter referred to as “Site”). The Site (Facility ID# 00037247) is located at 3030 McGraw Street, which is in Section 2, T.2S, R.11E, in the City of Detroit, Wayne County, Michigan. A Site Location Map and a map depicting the Site and Surrounding Properties (Figures 1 and 2) are included in Attachment 1.

The Site is managed by the Michigan Army National Guard and is the site of the former Olympia Stadium which was formerly the home of the Detroit Red Wings hockey team. The Site currently serves as a vehicle and equipment storage facility for the Michigan Army National Guard.

The subject underground storage tanks (USTs) were installed in 1993 and removed from the Site in 2024. The regulated substance stored within the USTs at the Site consisted of diesel fuel. Apart from the former USTs, no additional sources or releases have been identified at the Site.

A suspected release was reported to the Michigan Department of Licensing and Regulatory Affairs (LARA) on January 23, 2024, at 12:10 pm. The release was upgraded to a confirmed release (#REL- 0019-24) on February 6, 2024. The suspected release was detected based on a diesel odor noted by the consultant during sample collection after tanks were removed. Two water samples were collected from the excavation pit. The confirmed release was based on analytical results from the water samples collected from water accumulated in the base of the excavation. The presence of non-aqueous phase liquid (NAPL) in the soil or groundwater (i.e., sheen) was not observed during the UST removal efforts.

The residual contents of the USTs were removed prior to the UST removal activities. The USTs and the associated piping were properly cleaned and removed from the ground. The soils staged during removal of the USTs, approximately forty-two tons (estimated twenty-six cubic yards) of potentially impacted soils, were removed and transported to Waste Management Landfill for disposal. Prior to backfilling the UST excavation, 10,800 gallons of groundwater was pumped from the excavation and disposed of at Usher Oil, in Detroit, Michigan. No other actions besides removal of the fluids from the USTs, removal of the UST system, removal of potentially impacted soils, and the Site assessment subsurface evaluation activities described below have been performed at the Site.

The former USTs at the Site are identified below:

Installed Registered Tank ID Armory ID Size (gal) Contents 6/1/93 8/31/93 UTK-066210-15 DMA-236 1,500 diesel 6/1/93 8/31/93 UTK-015930-15 DMA-145 5,000 diesel

It should be noted that in the LARA release report, UST ID UTK-066210-15 is listed as a 15,000-gallon capacity UST. Based on field observations and the information written on the UST, the tank has a capacity of 1,500-gallons. Figure 3, Attachment 1 depicts the former UST tank and piping locations and Site features.

Site Investigation On July 18, 2024, ECT mobilized to the Site to collect soil and groundwater samples to evaluate the extent of residual contamination in the soil and groundwater beneath the Site. Sampling locations were determined based upon the Site logistics/features, accessibility, utility locations, and findings and/or observations made during the progression of the field investigation. During this field operation, soil borings GP-1 through GP-9 were completed. The final boring locations are depicted in Figure 4, Attachment 1.

Continuous soil cores were collected at each boring location to the total depth by the direct push drilling method using a track mounted drill rig. Following the retrieval of each soil sample core, the recovered soils were described and logged by a field scientist in accordance with the Unified Soil Classification System (USCS) and field screened for petroleum vapors using a MiniRAE3000 photoionization detector (PID) equipped with a 10.6 electron-volt lamp.

The total depth of the borings was determined based upon discovered subsurface soil conditions;

specifically, apparent soil permeability characteristics and vertical contaminant distribution, as well as the presence of shallow groundwater. Discrete soil samples were retained at select sample locations for laboratory analyses. Soil samples were collected for evaluation of the horizontal and vertical extent of petroleum impact as well as potential migratory pathways.

A portion of each sample selected for analyses was preserved in the field with methanol in accordance with United States Environmental Protection Agency (U.S. EPA) Method 5035. The soil samples were subsequently placed on ice in a cooler for storage and transportation to the Michigan Department of Environment, Great Lakes, and Energy (EGLE) State Laboratory. The soil samples were submitted under chain-of-custody (COC) documentation for the following analyses:

Volatile Organic Compounds (VOCs) using U.S. EPA Method 8260.

Polynuclear Aromatic Hydrocarbons (PNAs) using U.S. EPA Method 8270.

Diesel Range Organics (DRO) and Oil Range Organics analyses using U.S. EPA Method 8015.

No groundwater was encountered in the soil borings completed surrounding the former UST area and therefore no groundwater samples were collected. Based on field observations and field screening results, no measurable, migrating, or residual NAPL was identified at the Site. Soil boring logs are presented in Attachment 2. A copy of the groundwater analytical report (EGLE lab Work Order 2407187, dated July 29, 2024) is on file at the EGLE Lansing District office and may also be available on the EGLE Remediation Information Data Exchange (RIDE) website.

Documentation of ECT’s corrective action efforts performed in July 2024 are presented in the following report:

Leaking Underground Storage Tank Initial Assessment Report (IAR), dated July 30, 2024.

A copy of the IAR is on file at the EGLE Lansing District office and may also be available on the EGLE RIDE website. The paragraphs below present a summary of the corrective action work activities completed at the Site by ECT following submittal of the July 30, 2024, IAR.

Monitoring Well Installation Dissolved petroleum contaminants were identified within the groundwater samples collected from the excavation. Subsequent to collection of the samples, 10,800 gallons of groundwater were removed from the excavation.

To assess groundwater quality and hydrogeologic conditions within and surrounding the former USTs, four monitoring wells (MW-24-1 through MW-24-4) were proposed to be installed at the Site. On September 19, 2024, ECT mobilized to the Site to conduct the well installation activities. Final well locations and screen placements were based upon observed findings during the investigation, apparent contaminant horizontal/vertical distribution, facility logistics/features, accessibility, and utility locations. The final well locations are depicted in Figure 4, Attachment 1.

Prior to installation of the monitoring wells, continuous soil cores were collected at each location to the total depth using the direct push drilling method. Following the retrieval of each soil core, the soils were described and logged by ECT technical staff in accordance with the USCS and field screened for petroleum vapors using a PID. Discrete soil samples were collected from the boring for monitoring well MW-24-1 for laboratory analysis. The soil samples were collected from 4 to 6 feet (ft) below grade level (bgl) and 6 to 8 ft bgl. A portion (approximately ten grams) of each soil sample selected for laboratory analyses was preserved in the field with methanol in accordance with the U.S. EPA Method 5035. The collected samples were placed on ice in a cooler for storage and subsequent transportation.

The soil samples were submitted to the Contract Laboratory under COC documentation for the EGLE Remediation and Redevelopment (RRD) recommended diesel fuel VOCs (DVOCs) list including benzene, toluene, ethylbenzene, total xylenes, 1,2,4–trimethylbenzene, 1,3,5–trimethylbenzene, sec-butylbenzene, tert-butylbenzene, and n-propylbenzene, and PNAs analyses according to U.S. EPA Methods 8260D and 8270E. A copy of the soil quality analytical report is presented in Attachment 3.

The monitoring wells were installed using a drilling rig equipped with 4 ¼-inch inner diameter hollow stem augers. The wells were constructed using two-inch diameter Schedule 40 polyvinyl chloride (PVC) casings and five-foot long, #10 slotted PVC well screens. As the augers were removed to expose the well screen, pre-sorted filter sand was added to the annular space between the borehole and well screen to approximately one foot above the top of the well screen. Granular bentonite was then added to the annulus of the borehole to minimize/prevent direct communication between the underlying sediment formation and surface.

Each monitoring well was completed as a flush mount installation and secured with a watertight j-plug. Due to the lack of appreciable groundwater within the wells, the wells were not developed. The horizontal location of each well (to the nearest foot) was determined in reference to an existing building(s) and/or other fixed relevant Site features.

Decontamination Procedures/Investigation Derived Waste To reduce the potential for cross-contamination between drilling locations, drilling, and sampling equipment (i.e., hand auger, core samplers, sampling rod, etc.) were properly decontaminated according to industry standards. Similarly, disposable core liners were used to prevent cross-contamination between drilling and sampling locations. Investigation derived waste generated during the drilling/assessment activities was placed into two 55-gallon steel drums and staged on-site pending disposal.

Groundwater Sampling On October 21, 2024, ECT personnel returned to the facility to obtain representative groundwater samples from the newly installed monitoring wells. Prior to collection of the groundwater samples, each well was opened and allowed to equilibrate to atmospheric pressure. Depth-to- NAPL/groundwater measurements were obtained from each well using a bi-phase probe. No measurable NAPL (i.e., > ⅛ inch) was identified within the wells. In addition to the collection of NAPL thickness measurements, the purge water collected during sampling was monitored for the presence of a sheen. No sheen was observed on the purge water collected from the wells.

Groundwater samples were collected using low-flow (i.e., minimal drawdown) sampling procedures.

Disposable/dedicated tubing was used at each location to avoid cross-contamination between sample locations. Apart from monitoring well MW-24-1 (installed within the former UST basin), the wells were pumped dry due to insufficient groundwater production (i.e., wells would not sustain pumping at lowest flow rate). ECT personnel returned to the Site the next day to collect the groundwater samples.

The collected samples were placed in laboratory provided vials/jars and placed on ice in a cooler for preservation and shipment. All groundwater samples were submitted to the Contract Laboratory under COC documentation for DVOCs and PNAs analyses using U.S. EPA Methods 8260D and 8270E.

A copy of the groundwater quality analytical report is presented in Attachment 3. Groundwater sampling field data logs are presented in Attachment 4. Depth-to-NAPL/groundwater measurements from October 21, 2024, are presented in Table 1, Attachment 5.

Site Survey On November 19, 2024, ECT personnel mobilized to the Site to perform a survey to establish top-of-casing (TOC) and ground elevations for each well. Prior to surveying the wells, reference points were inscribed into each monitoring well’s TOC to ensure a common TOC reference elevation is established for future data collection. The well identification number was also placed on the inside collar of each flush mount. The wells were surveyed into a benchmark which was assigned an elevation of 100.00 ft.

The benchmark is the northernmost corner of a concrete pad located by the maintenance building side entrance door located on the north side of the northernmost corner of the building (see Figure 3, Attachment 1).

In addition to performance of the survey, Depth-to-NAPL/groundwater measurements were obtained from each well using a bi-phase probe. No measurable NAPL (i.e., > ⅛ inch) was identified within the wells. Depth-to-NAPL/groundwater measurements from November 19, 2024, are presented in Table 2, Attachment 5.

2. Identify Chemical(s) of Concern (CoC), their source location(s) and remaining maximum concentrations of CoC in soil and groundwater.

Tables 3 and 4, Attachment 5, present a summary of the soil and groundwater analytical results compared to the Part 213 Risked-Based Screening Levels (RBSLs). Site maps depicting the soil and groundwater results are presented as Figures 5 and 6, Attachment 1.

Based on the analytical results, Chemical(s) of Concern (CoC) at the Site include toluene, ethylbenzene, xylenes, 1,2,4-trimethylbenzene, naphthalene, sec-butylbenzene, acenaphthene, benz[a]anthracene, fluorene, 1-methylnaphthalene, 2-methylnaphthalene, chrysene, fluoranthene, phenanthrene, and pyrene.

The LARA UST records under Part 211 of the NREPA indicate two USTs were installed at the property in 1993, which included one 15,000-gallon UST and one 5,000-gallon UST. The two USTs were removed from the ground in 2024. Based upon visual confirmation, the UST capacities are 1,500-gallon and 5,000-gallon. Both USTs on the property were listed as containing diesel fuel. Field observations determined that USTs and piping appeared to be in good condition and the point of the release is undetermined. Figure 3, Attachment 1 depicts the potential source/former UST area.

The residual contents of the USTs were removed prior to the UST removal activities. The USTs and the associated piping were properly cleaned and removed from the ground. The soils staged during removal of the USTs, approximately forty-two tons (estimated twenty-six cubic yards) of potentially impacted soils, were removed for disposal. In addition, 10,800 gallons of groundwater were pumped from the excavation and shipped to a disposal facility.

Analytical results indicate that a remaining source of contamination at the Site includes petroleum impacted soils outside of the excavated area northwest of the former USTs. The extent of residual petroleum contamination is defined on-site. Although petroleum impacted soils have been identified at the Site, the maximum remaining concentrations are below the Part 213 RBSLs for Residential Drinking Water (DW), Groundwater Surface Water Interface (GSI), and the Residential Volatilization to Indoor Air Pathway (VIAP) criteria. Remaining maximum concentrations of the CoC in the soil compared to the Part 213 RBSLs are presented in Table 3, Attachment 5. Remaining maximum concentrations of the CoC in the soil are posted in Figure 5, Attachment 1.

Maximum concentrations of dissolved CoC (see Table 4, Attachment 5) were reported in the water samples collected from the UST excavation. Water encountered during the excavation efforts was removed prior to backfilling. To assess groundwater quality following the remedial activities, monitoring well MW-24-1 was installed within the former UST area, and three additional wells were installed in the native soils surrounding the UST excavation area. Analytical results from the groundwater samples obtained from the wells indicate that dissolved petroleum constituents are present in the groundwater; however, the reported concentrations are below the Part 213 RBSLs for Residential DW, GSI, and the Residential Shallow Groundwater Volatilization (SGW) VIAP criteria.

Remaining maximum concentrations of the CoC in the groundwater compared to the Part 213 RBSLs are presented in Table 4, Attachment 5. Remaining maximum concentrations of the CoC in the groundwater are posted in Figure 6, Attachment 1.

3. Summarize the Non-Aqueous Phase Liquid (NAPL) remaining.

To characterize NAPL at the Site, multiple lines of evidence were reviewed (see Table 5, Attachment 5). In addition, during the July 2024 investigative activities, soil samples collected from the soil borings were submitted for DRO analysis. Soil cores obtained from the soil borings were also screened with a PID and inspected for petroleum odor, staining, and for the presence of NAPL. To assess whether or not mobile or migrating NAPL was present at the Site, monitoring wells were placed within and surrounding the former UST excavation.

No odor, staining, or NAPL was identified in the soil boring cores and samples collected by ECT. No PID readings exceeding one part per million were detected in the soils/cores. No mobile NAPL or sheen was identified on the surface of the groundwater accumulated within the excavation or on the surface of the groundwater purged from monitoring wells. Based on field observations and field screening results, no measurable, mobile (sheen), migrating, or residual NAPL has been identified at the Site.

4. Identify human and environmental receptor locations that could be impacted (i.e., point(s) of exposure).

Potential environmental receptors at this Site include nearby surface waters and wetlands. Site-specific environmental receptors can include discharges to nearby streams, county drains, and any animals, plants and aquatic species associated with the surface water body(s). The nearest surface water feature is the Detroit River located approximately three miles southeast of the Site. It appears that there are no storm drains located near the former UST excavation and no wetland areas were identified within a two mile radius of the Site. A topographical map depicting surface water and surrounding geographical features is presented as Figure 1, Attachment 1. Surrounding Land Usage and On-Site Locations Maps are presented as Figures 2 and 3, Attachment 1.

Potential human receptors include nearby local residences, commercial businesses, utility workers, enclosed structures, utilities, and water supply wells. The nearest off-site residential receptor(s) is residential housing located approximately 280 ft southeast of the Site. The nearest building on-site is a brick and mortar maintenance shop with a concrete slab-on-grade floor. Apart from a buried electric line, it appears that there are underground utilities near the former UST excavation. The buried electric line is located west of the former USTs (Figure 3, Attachment 1).

The Site and surrounding area are supplied by municipal water. Municipal water in the area is supplied by the Great Lakes Water Authority which operates five water treatment facilities that draw water from Lake Huron and the Great Lakes tributary, the Detroit River. The EGLE Water Well Viewer was accessed to determine the location(s) of a nearby wellhead protection area(s) and off-site water wells.

Based on the data, the Site is not located within a delineated wellhead protection area. The nearest known delineated wellhead protection areas are located over thirteen miles northwest of the Site. The nearest off-site water supply well is located approximately 4.2 miles north of the Site. Based on the lack of appreciable groundwater identified within the upper 15 ft bgl surrounding the former UST area, there appears to be no drinking water or GSI receptors in the area. Maps depicting the local wellhead protection areas, area water well locations, and nearby water well logs are included in Attachments 6 and 7.

5. Identify any complete transport and exposure pathways (e.g., dissolved plume, vapor migration through soils, utilities, etc.).

An exposure pathway analysis was performed to determine the relevancy of each exposure pathway with respect to the current Site conditions and risks posed to human health and the environment.

Indoor air inhalation and volatilizing from soil to ambient air appear to be the only relevant exposure pathways for the Site; however, based on ECT’s assessment, there are no unacceptable risks associated with the pathways.

6. Identify current or potential future use of the site and surrounding land, and of the groundwater, surface water, and sensitive habitats.

The Site is in an urban setting with a mixture of residential and commercial properties. The Site itself is currently used as an armory and is managed by the Michigan Army National Guard and serves as a vehicle and equipment storage facility. A Site Location map and a map depicting the Site and Surrounding Properties (Figures 1 and 2) are included in Attachment 1.

The Site sets at an approximate elevation of 620 ft above the North American Vertical Datum 1988.

The Site is mainly flat with surface runoff directed towards local storm drains. The surface area is covered with asphalt and gravel parking areas along with manicured grass areas. A chain link fence encompasses the majority of the Site. The Site’s two buildings include a main building and a maintenance building. No water supply wells were identified on the Site. Water, sewer, and electricity are supplied by the local municipality. Apart from a buried electric line, no underground utilities are located near the former USTs.

The Site is not located within a delineated wellhead protection area. The nearest known delineated wellhead protection areas are located over thirteen miles northwest of the Site. The nearest off-site water supply well is located approximately 4.2 miles north of the Site. The nearest surface water feature is the Detroit River located approximately three miles southeast of the Site. No wetland areas were identified within a two mile radius of the Site.

Groundwater resources in the area are limited. The area is served by municipal water and will likely remain so. Surface water, ecological receptors, and habitats will not likely be affected based on the current property configuration, location, and remaining levels of petroleum contaminants. The land use is currently zoned as B2 (Local Business and Residential District). Under the B2 classification, future land uses may include local businesses and residential housing. The public roadways surrounding the Site are likely to remain public roadways in perpetuity.

7. Provide a final Conceptual Site Model (CSM)/NAPL CSM.

The results of investigations conducted at the Site have provided the basis for a thorough understanding of the Conceptual Site Model. This section presents a summation of the Site geology, hydrogeology, and the location of remaining impacted media.

Hydrogeologic and Geologic Characteristics The Wayne County area geology is characterized by deposits of glacio-lacustrine clay and silt on top of a thick strata of dolomite and limestone bedrock. The uppermost bedrock units in Wayne County consist of Paleozoic sedimentary rock strata of marine origin. According to the bedrock geology map of Wayne County, the Dundee Formation (mostly limestone, with some dolostone) and the Detroit River Group (limestone, dolostone, and some sandstone) underlie the unconsolidated glacial deposits.

The majority of wells within the county are in glacial deposits (67%) while some are installed in bedrock (27%). The general regional bedrock groundwater flow pattern in the area is considered to be from west to east toward the Detroit River.

The Site is in an area of lacustrine clay and silts where groundwater is not used as a source of potable water. The Site and surrounding area are supplied by municipal water drawn from Lake Huron and the Great Lakes tributary, the Detroit River. Based on the EGLE Water Well Viewer and RIDE mapper, the nearest water wells are:

Well ID 82000002584, located 4.2 miles north of the Site at 15150 Oakland Avenue, Highland Park, MI

Well ID 82000002787, located 5.8 miles southwest of the Site at 4650 West Road, Dearborn, MI

It should be noted that Well ID 58000000933 is located two miles north-northwest of the Site according to RIDE mapper; however, the well address is 6300 Fay, Carlton, MI (actual location is 29 miles southwest of the Site) and therefore is not considered the nearest water well.

For water well ID 82000002584, the formation was described as clay to 118 ft bgl, limestone with shale from 118 to 165 ft bgl, and limestone hard from 165 to 210 ft bgl. A 210-foot water well was attempted at this location for industrial use. The driller’s remarks included: “rendered very little water, extremely salty” and “wellhead completion: not completed due to bad water.”

For the water well ID 82000002787, the formation was described as clay to 112 ft bgl, sand to 112.5 ft bgl, and limestone to 126 ft bgl. The water well was installed at this location for household use.

Water wells within the area are completed in the deeper sand/sand and gravel deposits or bedrock.

In addition to the water supply wells, three shallow test wells are located within 3.5 miles of the Site.

A water well location map and copies of area water well records are presented in Attachment 7.

The soils encountered on-site were generally stiff clay starting at one foot bgl and extending to the maximum drilling depth of 15 ft. The surficial soils were generally gravel. Interbedded gravel and clayey sand seams were identified in the upper 10 ft; however, the seams were not identified in every boring at the Site and appear not to be contiguous throughout the study area. Sand was encountered in the borings located within and next to the UST excavation. At MW-24-1, installed within the former excavation, sand was observed to a depth of eight ft bgl where refusal was encountered due to the presence of concrete. It is suspected that the concrete encountered at MW-24-1 is the concrete pad used to anchor the USTs. Outside of the UST excavation, no appreciable groundwater was observed in the cores collected from the soil borings at the Site. Cross-sections depicting the local geology surrounding the former UST vault are presented as Figures 7 and 8, Attachment 1.

Groundwater beneath the Site is not considered present in a sufficient quantity to be categorized as groundwater in an aquifer. Although a complete evaluation of groundwater not in an aquifer was not conducted in accordance with the criteria set forth in the EGLE-RRD Groundwater Not in An Aquifer, June 13, 2023, document, Site specific data supports the conclusion that groundwater beneath the Site is considered not to be present in a sufficient quantity to be categorized as groundwater in an aquifer. This conclusion is supported by the minimal/lack of groundwater recharge observed during collection of groundwater samples from the monitoring wells installed within the soils surrounding the former UST vault. Based on the low flow groundwater sampling logs, groundwater pumping rates as low as 140 milliliters per minute (ml/min) or 0.04 gallons per minute (gpm) were unsustainable. The Site is also located in the area of the State mapped as lacustrine clay and silt (reference EGLE’s GeoWebFace Quaternary Geology Maps).

Although groundwater is present within the excavated area, groundwater within the native soils beneath the Site is considered perched and not in an aquifer. Since removal of the USTs, water from precipitation events has accumulated in the excavated area. This is due to the native clay soils not allowing water to readily pass through the sidewalls. As a result, water accumulates in the excavation and tends to remain there. This hydrogeological feature is referred to as the bathtub effect. As a result, during periods of high seasonal precipitation a relatively shallow groundwater table within the excavated area is present causing a temporary mounding of the groundwater table. Conversely, during periods of low seasonal precipitation the groundwater table within the excavation area will decline.

Four monitoring wells were installed at the Site. One well was placed within the former excavation area and the three remaining wells were installed surrounding the former UST vault. The monitoring wells are screened from 3 to 8 ft bgl within the excavation and from 4 to 9 ft bgl outside of the excavation. The shallowest dept-to-water recorded at the Site was 4.3 ft bgl at MW-24-4.

Depth-to-groundwater measurements were obtained on October 21, 2024, and November 19, 2024.

The groundwater measurement data was plotted and contoured to evaluate groundwater flow direction beneath the study area. The October 2024 data shows mounded groundwater within the former UST excavation with an overall flow direction towards the north-northwest and an average hydraulic gradient of 0.05 ft/ft. The November 2024 data depicts groundwater flow towards the north-northwest with a slight mounding of the groundwater within the former UST excavation and an average hydraulic gradient of 0.035 ft/ft. The resulting contour plots are presented in Figures 9 and 10, Attachment 1.

Based on low flow sampling pumping data, groundwater flow beneath the investigation area is minimal. During the low flow sampling event, sustainable pumping of groundwater within the wells did not exceed a rate of 0.1 gpm (or 378 ml/m). The monitoring wells were evacuated and allowed to recharge overnight for collection of a sample. The data indicates that the shallow formation has a low hydraulic conductivity and does not yield a significant amount of water. As a result, the native formation will inhibit the vertical and horizontal migration of impacted groundwater beneath the Site to a lower aquifer. Groundwater low flow sampling logs are presented in Attachment 4.

Extent of Remaining Soil Impact A Site diagram depicting the soil quality results is presented as Figure 5, Attachment 1. Cross-sections are presented as Figures 7 and 8, Attachment 1.

Petroleum impacted soils remaining at the Site are located northwest of former UST excavation. Based on analytical results, remaining contaminants in the soil are not present at concentrations above the Part 213 RBSLs for Residential DW, GSI, and the Residential Soil VIAP criteria. Soil quality analytical results from the Site investigation efforts are presented in Table 3.

Extent of Remaining Groundwater Impact A Site diagram depicting the groundwater quality results is presented as Figure 6, Attachment 1.

Four monitoring wells were installed at the Site. One well was placed within the former UST excavation and the three remaining wells were…