Yes.  Instructions for the MIRBCA forms are available on the Remediation and Redevelopment Division’s (RRD) MIRBCA webpage. 

It is highly recommended that you read the introductory pages to the instructions first.  There are instructions associated with each of the individual forms, and it is recommended to refer to the instructions for each form as you are completing the form (e.g., when completing Form 11, refer to instructions for Form 11).

There is also a recording of a webinar (MIRBCA Tier 1 Forms) on the MIRBCA webpage along with a pdf copy of the webinar slides.

There are two main ways to save the forms as a pdf:  

Print method 1: Using Excel’s print function:

1. Go to the File menu within Excel
2. Navigate to Print
3. Select a print-to-pdf option for the printer
4. Select “print entire notebook” in Settings
5. Select the “print” button
6. Choose a file name and location to save the document

This will generate a pdf document of approximately 1,000 pages.  The MIRBCA forms will be on the beginning pages followed by blank pages.  For the second step, perform the following:

1. Open the PDF document and locate the last page of the MIRBCA forms (e.g., page 68)
2. In the PDF viewer’s print menu, choose a print-to-pdf option for the printer
3. Select the appropriate page range (e.g., page 1-68) that will print all the MIRBCA forms without printing any blank pages
4. Select the print button
5. Choose a file name and location to save the document

Print method 2: Using the MIRBCA forms print function:

1. Navigate to Excel’s print function and select an appropriate print-to-pdf printer
2. Select the PRINT button at the top of the MAIN MENU page in the MIRBCA forms to navigate to the PRINT page of the forms
3. On the PRINT page of the forms, use the buttons in the upper left corner of the page to either select all forms or deselect all forms for printing
4. Alternatively, manually select the desired form(s) by checking the corresponding box adjacent to each form on the page
5. After the desired forms are checked, click the PRINT button in the upper left corner of the page

If printing multiple forms as PDFs, the print functionality will prompt the user to save each form as a separate PDF, potentially resulting in over 70 separate pdf files.

Guidelines for report assembly include:

• Combine all forms, tables, figures, and attachments as a single PDF file.
• Organize the report into sections containing: Forms, Tables, Figures, and Attachments.
• Label all Tables, Figures, and Attachments appropriately.
• Do not include duplicates of Tables, Figures, etc., For example, Figure 2 is referenced on both Form 2 and Form 3 but should be included only one time in the report.
• Do not include blank forms, blank pages, or forms that are not applicable to the site.  Examples include:
• Form 22 is required for a FAR, but if corrective actions did not involve any NAPL removal, do not include Form 22(5) (Corrective Action (NAPL Removal)).
• Form 16 contains multiple pages to address all pathways onsite, offsite, current use, future use, for residential and nonresidential receptors.  Any forms in the Form 16 series that do not have any data should not be included in the report.

The MIRBCA report forms are not required for a SIR. However, the MIRBCA report forms are designed to be cumulative throughout an investigation. 

As additional corrective actions are implemented, the forms should be updated as needed, although there is no requirement to submit the updated forms to EGLE in a SIR. 

Forms likely to be updated as corrective actions are implemented include Form 6 – Chronology of Events, and Form 7 – Comprehensive Summary of Data.  Figures, data tables, and attachments in the SIR should retain the numbering scheme in the MIRBCA Table of Contents. 

There would likely not be a need to include Form 19 – Site Classification, or update the Tier 1 or 2 risk evaluation (Tier 1 Form 16, Tier 2 Form 2-8) in a SIR, unless the contents of a SIR is an updated Tier 1 or Tier 2 risk evaluation report.

In the cover form of the MIRBCA forms (July 2025 version), entering a confirmed release date for a single release in the “Date(s) confirmed release(s) discovered” row results in an incorrect display of the confirmed release date on subsequent forms. 

To fix this, enter some type of punctuation (e.g., comma, period, semi-colon) after the date in the Cover form. 

This will be corrected in Version 1.1 of the forms.

For the purposes of the MIRBCA risk assessment, the right-of-way (ROW) is not considered an offsite property, because chronic exposure (e.g., drinking from a potable well within the ROW or breathing indoor air from a building constructed in the ROW) is highly unlikely. 

The July 2025 version of the MIRBCA forms Executive Summary, Form 1, Form 4(1), and Form 7 will be updated to provide information related to ROW evaluations. 

If using the July 2025 version of the MIRBCA forms, comments in the ADDITIONAL INFORMATION section of the forms may be used for clarification regarding offsite versus ROW impact and data.

If a pathway is complete for current use, the risk must be evaluated based on actual current use. 

Additional context

If the current use of the property is nonresidential, the risk must be evaluated based on nonresidential exposure assumptions—mark the pathway as “complete” for nonresidential and “not complete” for residential receptors, since there would not be any residential exposure.  Conversely, if the current use of the property is residential, mark the pathway as “complete” for residential and “not complete” for nonresidential.  Since the risk decision would be driven by a risk assessment based on residential exposure assumptions, a nonresidential risk assessment is not needed.  If the property is vacant, there are no residential or nonresidential receptors—mark the pathway as not complete for both residential and nonresidential current use. 

All the questions in bold font about pathway completion on Forms 11, 12(1), 12(2), 13(1), 13(2), 13(3), and 14 require a response and should not be omitted. 

Additional context

If the pathway is not complete, mark it “not complete” for both residential and nonresidential.  If the pathway is complete, in general it should be marked “complete” (i.e., “yes”) for either residential or nonresidential, as appropriate, and marked “not complete” (i.e., “no”) for the opposite exposure scenario.  Rarely will it be “complete” for both residential and nonresidential.  An example of this is when two separate properties are impacted and the current use of one property is residential and the current use of another property is nonresidential.  If one property has both residential and nonresidential use, the risk decision will be driven by the residential risk assessment.

No, zoning or other site-specific information cannot be considered for determining whether future exposure will be to residential or nonresidential receptors. 

Additional context

Section 21310a(1) of Part 213 requires that if a risk assessment for future use is based on nonresidential RBSLs or nonresidential SSTLs, there must be a land use restriction that restricts the property to nonresidential use.  This may be either a Notice of Corrective Action (used to restrict land use only) or a Restrictive Covenant (may restrict both land use and resource use).  If the land use for a property is not restricted to nonresidential, the risk assessment for future use must be based on RBSLs or SSTLs that are consistent with residential exposure assumptions.

The pathway should be marked complete for residential future use if a land use restriction is planned but not yet executed.  This is marked on Form 4 and on each applicable pathway form (Forms 11, 12(1), 12(2) 13(2), 13(3)). 

Additional context

For each exposure pathway that is complete for future use, compare the representative concentration to the applicable residential RBSL.  If the representative concentration for future use exceeds the residential RBSL, a potential corrective action to address the unacceptable risk may include the placement of a land use restriction.  This would allow a non-residential risk assessment for future use.  After the land use restriction is executed and recorded on the deed of the property, Form 4 and the applicable pathway form(s) should be updated to indicate nonresidential future land use.  If the representative concentration for future use in a complete exposure pathway does not exceed the nonresidential RBSL and a land use restriction has already been recorded on the deed of the property, no additional corrective actions are required for that exposure pathway.  If the representative concentration for future use exceeds the nonresidential RBSL, either corrective action or a higher tier risk evaluation is required.  

For onsite risk evaluations, mark the pathway as “not complete” for future use for the pathway in question if a resource use restriction has been recorded.  For offsite risk evaluations, the pathway would not be considered complete in the area affected by the resource use restriction.  The pathway should be marked “not complete” if the entire area where the pathway is complete is restricted (in Form 11 for surficial soil pathways and in Form 12 for the VIAP).  For the groundwater protection pathway, the pathway is considered complete outside of the restricted area, so mark the pathway “complete” for offsite, regardless of the presence of a resource use restriction.

Additional context

There is the potential for the surficial soil pathways and the VIAP to be complete early in the stages of corrective actions and later change to “not complete” prior to closure because resource use restrictions were implemented.  If a resource use restriction is implemented, the POE for future use is eliminated within the restricted area, and therefore concentrations within the restricted area should not be considered for determining the representative concentration that is used in a risk evaluation for future use.

It is worth considering whether or not a resource use restriction (or a land use restriction) is required to address an unacceptable risk.  Historic implementation of Part 213 generally required a restrictive covenant if any concentration exceeded a Tier 1 RBSL.  The MIRBCA process is different in two ways:

1.  not all concentrations are compared to RBSLs but only the representative concentration within the exposure domain for the exposure scenario that is evaluated, and
2.  the MIRBCA process allows for Tier 2 and Tier 3 evaluations that could lead to unrestricted residential closures even though Tier 1 RBSLs are exceeded, depending on the nature of the exceedance. 

It is expected with the implementation of MIRBCA that there will be much less reliance on restrictive covenants to achieve closure.

The pathway should be marked as “complete” for future use if a resource use restriction is proposed but not yet implemented. 

Additional context

A resource use restriction (e.g. a drinking water restriction) is a type of corrective action to eliminate the pathway within the restricted area and may be used to eliminate an unacceptable risk.  The same would be true if remediation is proposed but not yet implemented—the pathway would be considered complete and then a risk evaluation based on the representative concentrations should be conducted to determine if the risk is acceptable or unacceptable.  If the risk is unacceptable, corrective actions (such as a restrictive covenant with the appropriate resource use restrictions) may be proposed to address the unacceptable risk.  Alternatively, a higher tier evaluation may be performed to re-evaluate the risk, depending on the nature of the exceedance.

If there is any evidence that the release from the leaking underground storage tank system impacted soil in the upper two feet of the vadose zone, the pathway is considered complete (refer to MIRBCA Section 5 regarding pathway completion and pavement). 

Additional context

First determine if the release from the leaking underground storage tank system has likely impacted the surficial soils.  If the answer is yes, and if there are no available data within the surficial soils to evaluate risk, judgment can be used to select data that would conservatively represent concentrations of COCs within surficial soils.

• For example, if PID readings from surficial soils suggest that soil is impacted from the confirmed release, but analytical data are available only for deeper soils, the deeper soil results may be appropriate to use as a representative concentration if the use of the data can be justified from a risk perspective.
• An example when this would not be justified is if field evidence from surficial soils suggests that surficial soils are highly impacted, however the risk evaluation is based on deeper soil samples that appear to be much less impacted.

In general, the quality and the thickness of the pavement would likely not affect whether exposure to surficial soils occurs considering the exposure assumptions used in calculating the RBSLs. 

Additional context

For direct contact exposure, a receptor is assumed to randomly be exposed to surficial soils within the exposure domain 350 days per year (for residential receptors), and each day of exposure there is an assumed amount of soil that is ingested and absorbed onto the skin.  This is highly unlikely to occur if pavement of any quality or thickness is present.

The MIRBCA process assumes that a water supply well can be installed anywhere in an aquifer (in Tier 1) or at a site-specific location in an aquifer (in Tier 2). 

Additional context

The MIRBCA process requires a demonstration that the risk to a future receptor is acceptable.  Since groundwater can transport chemicals laterally away from the site, the pathway is considered complete so that a risk evaluation can determine if any future risk is acceptable.  It is not uncommon for there to be potentially unacceptable risks at a distance from the site.  If the entire impacted area is restricted, a demonstration must be made that the areas outside of the restriction are protective for future use, and thus the pathway is considered complete outside of the restricted area.

This is in contrast to the direct contact pathway, for example.  In this pathway, there is no transport of the COCs away from the source except for the initial release of COCs into the environment.  Thus, exposure occurs directly where the soils are located, and the area where the pathway must be evaluated is limited to this area.

For the VIAP, the transport of COCs is generally vertical from the source to occupied buildings above the source.  The greatest VIAP risk is generally closest to the source, and VIAP risk decreases with distance from the source. 

The forms were designed from the perspective of a new release and should be simple to complete for new releases. These forms are expected to streamline the reporting and auditing process, resulting in shorter reports that are easier to prepare, transparent reporting expectations, and predictable and consistent audit results. The implementation of MIRBCA is expected to decrease the overall cost of corrective action and reporting at petroleum sites regulated under Part 213.

The forms are designed to be comprehensive, but much of the historic site information may be briefly summarized, as appropriate. The following examples are offered:

Form 6 – Chronology of events

• This can include broad overviews of key historic events, for example:
  • 1998 – 2002 – site investigation and quarterly monitoring
  • 1999 – 2004 – mobile NAPL observed in wells x and y, mobile NAPL recovery via z methodology
  • 2004 – 2015
  • 2008 – site renovation, replacement of USTs
  • The form should also include each activity conducted since the MIRBCA guidance and forms were published. Note that the space allows for a brief description of each event and not a lengthy narrative.

Form 7 – Comprehensive Summary of Data

• This form should provide a comprehensive summary of all the data, to the extent possible.

Form 22(x) – Corrective Actions

• Form 22(8) should provide a list of all institutional controls, restrictions, alternative mechanisms, notice to impacted parties, for all notified properties.
• Corrective actions implemented historically do not necessarily require a form. For example, if USTs were removed in 1994 and some contaminated soil was excavated at that time, it can be briefly summarized in Form 6 without needing Form 22(1). Judgment should be used to determine if a corrective action form is required for historically implemented corrective actions. The purpose of the form is to provide clear and consistent documentation of corrective actions that were implemented or are proposed.

Data Tables

• All data that are considered in the risk evaluation are required to be entered into the data tables. For historic releases, judgment may be used regarding the transfer of data into the MIRBCA Data Tables. Examples are provided below:
  • If groundwater analytical data are available in Excel format, they should be copied into the MIRBCA Data Tables. If historic data are available in pdf only, there would not be a requirement to enter these data into the MIRBCA Data Tables if they are not being considered in the determination of a representative concentration.
  • Some sites may have historic wells that were abandoned or have not been sampled in many years. If the data are no longer relevant for the risk evaluation, these data would not require entry in Table 5 (Groundwater Data), but the wells should be entered in Table 2 (Well Construction), and the information in Table 2 should be consistent with the information in Form 7 – Comprehensive Summary of Data.
• A closure report should include all data for the release. If data are not in the MIRBCA Data Tables format, they can be included along with the Data Tables. For example:
  • Include Data Table 5 – Groundwater Data, and can also include supplemental data for Table 5, which could contain pdf copies of historic groundwater data not used in the risk evaluation. The objective is to include all groundwater data in Table 5, however, formatting of historic data into the MIRBCA data tables format may not be required for all historic data.