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Independent Closure Process

The Indiana Department of Environmental Management’s State Cleanup Section rolled out the new Independent Closure Process (ICP) on April 15, 2010, with the hope of accelerating investigation, remediation and closure at low-priority sites. Key elements of the ICP are:

In general, low-priority sites are those having only contaminated soil. IDEM estimates that approximately 200 sites are eligible for the ICP. Cleanups at many of these sites have stalled as the agency has redirected its resources to medium- and high-priority sites. IDEM’s hope is that cleanups at low-priority sites that are stagnant will resume without the agency’s direct oversight. It is important to note that the ICP does not relieve RPs or consultants from any existing legal requirements for reporting releases or for site investigation and remediation.

After an ICP cleanup is completed, the RP and consultant submit an ICP Site Closure Form and appropriate supporting closure documents to IDEM for review. The RP and consultant must certify on the Site Closure Form that the cleanup was conducted per RISC to the appropriate closure levels. IDEM estimates that closure determinations will be completed within 60 days after the agency receives the Site Closure Form and documents. IDEM will issue a Completion of ICP letter if the required closure documents are complete and cleanup goals have been achieved. The Completion of ICP letter is similar to an NFA but states that the closure decision was based on RP and consultant certifications.

We believe there are several potential benefits and risks associated with the ICP.

Benefits

Risks

In addition, at any time during investigation or remediation, as new information is collected, a site may be elevated to medium or high priority and will no longer be ICP eligible.


Wilcox provides assistance in evaluating whether sites currently in the State Cleanup program are eligible for, and will benefit from, participation in the ICP.

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