The submittal of an Active Vapor Mitigation System (AVMS) design to the Michigan Department of Environment, Great Lakes, and Energy (EGLE) should include information necessary to ensure the proposed system has a reasonable likelihood of effectively mitigating unacceptable exposures for the volatilization to the indoor air pathway (VIAP). This Table of Contents (TOC) may contain information not necessarily critical for the review and approval of the mitigation strategy; however, it is included in the design to ensure that the necessary information is available if approval of the installed system is required in the future.
The obligation of ensuring the designed system is effectively mitigating the unacceptable exposures for the VIAP is that of the person proposing the plan. EGLE’s approval of this plan does not guarantee that it will be effective in mitigating the unacceptable risk, nor that additional response activities are not warranted. The design submittal should provide key design elements, but focus on identifying performance metrics, how and where they are measured, why they are appropriate for the design, and identifying the construction quality assurance and quality control (QA/QC) plan.
Include a description of the overall goal of the AVMS, an understanding and discussion of how the AVMS will function, the specific performance metrics used to verify function, and an outline of the operation, maintenance, and monitoring (OM&M) program.
Coversheet
The cover sheet for the system design submittal should contain the following information:
- Site - Site address with regulatory identifiers (Facility or Site name and ID#).
- Owner - Entity, address, contact information.
- System Designer and/or Environmental Consultant – Entity, address, contact information.
- Building Engineer and/or Architect (if applicable) – Entity, address, contact information.
- Submittal Date