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Emily Bertolini RRD
Jim Sobieraj, PE David Carstens
Traditional NFA Approach Site Characterization Site-wide Remediation NFA Report Submittal DEQ Approval
Whats Different with a Partial NFA? Limited to area, medium, contaminant Submit NFAs as cleanup is completed
Case Study: Former Numatics Sites
Whos Involved? Are we done yet?
Theres a lot to do!
Arent they done yet?
DEQ
Former Property Owner
Former Owners
Consultant
Current Property Owners
Manage that risk!
Project Obstacles
Ope
ratio
nal H
isto
ry
Different Operations Multiple COCs Small and large sources G
eolo
gic
Sett
ing Different
media Heterogeneity between sites
No
Furt
her A
ctio
n One Goal multiple possible pathways
Case Study: N. Milford Road Facility Numatics operated at
the site from 1956 - 2008 Facility manufactured
air-valve components 76,000 ft2 building
Site History: N. Milford Road Facility Fuel oil USTs Septic System Dry well and infiltration
system Infiltration Pond Discharges to ground
surface
FORMER USTs
FORMER SEPTIC
INFILTRATION POND WASTEWATER
INFILTRATION SYSTEM
Site Investigation: N. Milford Road Facility Major Environmental Concerns Chlorinated solvents (PCE) in onsite soil and
GW, offsite GW Minor Environmental Concerns Mercury released within facility Metals, PAHs, PCBs, and TPH in onsite soil
Site Challenges
How can we address the minor concerns without waiting for cleanup of the PCE plume?
Site Cleanup
Non-VOCs in
Soil
VOCs in Soil PCE Plume
Site Solution
Recognize Challenges
Define a Goal for
Remediation
Divide the Site
Subdivide by COCs and
Media
Define Path for each
Partial NFA
No Further Action for Entire Site
Remediation Strategies Site was divided by
area: onsite and offsite Remediation targeted
specific COCs by area Strategies focused on
incremental NFAs
ONSITE
OFFSITE
Remedial Milestones
Remediation No Further Action 2005 2009: Site Investigation 2014: NFA approved for metals in GW 2009 2013: Onsite Treatment 2015: NFA approved for all COCs in onsite soil 2009 - 20??: Offsite Treatment 2015: NFA pending for VOCs and PAHs in onsite GW 20??: Site Closure for all COCs and media
Remedial Progress Were getting somewhere
Theres still more to do!
Almost done onsite
DEQ
Former Property Owner
Former Owners
Consultant
Current Property Owner
Keep going
Case Study: Former Numatics Sites
Case Study: E. Highland Road Facility Numatics operated at
the site from 1974 - 1996 Facility was used for
precision grinding and honing of stainless steel bars 12,000 ft2 building
Site History: E. Highland Road Facility
FORMER DRY WELLS
SEPTIC
FORMER USTs
Wastewater USTs Septic System Dry wells Transformer release
Site Investigation: E. Highland Road Facility Major Environmental Concerns PCBs in onsite soil VOCs in onsite soil, onsite and offsite GW Freon-113 PCE Trichlorobenzenes (TCBs)
Minor Environmental Concerns Nickel (Ni) and Copper (Cu) in onsite soil and GW
Site Challenges PCE
in GW
How can we address the complex, multiple, overlapping concerns in an organized fashion?
Site Cleanup
Ni/Cu in Soil
PCE in Soil
PCBs in Soil
Freon-113 in GW
TCBs in GW
Ni/Cu in GW
Site Solution
Recognize Challenges
Define a Goal for
Remediation
Defined the Site
Characterized Aquifer Unit
and Clay Zone
Subdivide site by COCs and Media
Define Path for each
Partial NFA
No Further Action for Entire Site
Remediation Strategies IRDC for onsite PCBs
Remediation AS/SVE to address PCE in
soil MIP investigation define
extent of Freon-113 Targeted injections to
address TCBs
FREON-113 INVESTIGATION
AREA AS/SVE SYSTEM
TCB INJECTION AREA
Ni/Cu Area PCB IRDC
Remedial Milestones
Remediation No Further Action 2005 2012: Site Investigation 2013: NFA approved for Freon-113 in GW 2006 2008: IRDC for PCBs in soil 2015: NFA approved for Ni/Cu in soil and GW 2010 2014: VOC treatment in soil 2015: NFA pending for PCE in soil 2013 20??: TCB treatment & monitoring 20??: Site Closure for all COCs and media
Remedial Progress Were getting somewhere
Theres still more to do!
Almost done onsite
DEQ
Former Property Owner
Former Owners
Consultant
Current Property Owner
Keep going.
Not applicable to simple sites Requires continuous adaptation
to closure strategy in response to new data
Potential for increased reporting costs
Pros: Cons: Facilitates administrative focus to
closure Demonstrates value to
responsible party through tangible progress
Potential for reduced cost
Right for Your Site?
Questions?
[email protected]; [email protected] www.michigan.gov/deq
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mailto:[email protected]:[email protected]
Slide Number 1Traditional NFA ApproachWhats Different with a Partial NFA?Case Study: Former Numatics SitesWhos Involved?Project ObstaclesCase Study: N. Milford Road FacilitySite History: N. Milford Road FacilitySite Investigation: N. Milford Road FacilitySite ChallengesSite SolutionRemediation StrategiesRemedial MilestonesRemedial ProgressCase Study: Former Numatics SitesCase Study: E. Highland Road FacilitySite History: E. Highland Road FacilitySite Investigation: E. Highland Road FacilitySite ChallengesSite SolutionRemediation StrategiesRemedial MilestonesRemedial ProgressRight for Your Site?Questions?Contact Us for More Info