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Important changes to Michigan's Part 201 cleanup criteria
became effective September 28, 2012. Among other revisions,
inhalation pathway criteria for both soil and groundwater were made
more stringent for several constituents or have been developed for
some hazardous substances where previously insufficient data was
available to develop criteria.
For example, the TCE criteria have decreased substantially,
including the concentration in groundwater criterion for
volatilization to indoor air, which decreased from 15,000 ppb to
2,200 ppb for residential closures and from 97,000 ppb to 4,900 ppb
for nonresidential closures. These changes potentially could affect
cleanups at many sites throughout Michigan (particularly vapor
intrusion sites), and potentially result in reopeners at sites
where the investigation or even the remedy had been completed.
These more stringent values will be more difficult (and probably
more costly) to achieve.
Revisions also were made to the lead and manganese Final Chronic
Value formulas used to determine hardness-dependent GSI values.
Industry comments suggest, however, that the modeling used may
overestimate the impact on aquatic life. In addition,
groundwater-surface water interface (GSI) criteria also were made
more stringent for several constituents. Finally, the Michigan
Department of Environmental Quality (MDEQ) added a new hazardous
substance, phenytoin, to the Part 201 list of hazardous substances.
Phenytoin is a pharmaceutical used in certain drugs, e.g., certain
types of seizure medications. Thus, pharmacies and other companies
that handle drug disposal for their customers will need to ensure
that proper care is used in disposing of such medication. MDEQ's press release for this action is
available here or you can contact the authors for additional
information.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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