Remediation Closure Guide (RCG)

Public Comments Received

May 6, 2011 – June 20, 2011

  Fred W. Nichols Vice President-Business Development fnichols@astburyenviro.com

The Indiana Department of Environmental Management (IDEM) released a draft version of the Remediation Closure Guide (RCG) on May 6, 2011.  The purpose of this Nonrule Policy Document is to provide guidance for the investigation, remedy selection, and cleanup of contaminated sites.  Public comments were received up until June 20, 2011.  A total of 253 pages of public comments were received, including Astbury Environmental Engineering’s comments, which were submitted through the Midwestern States Environmental Consultants Association (MSECA).  Follow this link to review and/or download the public comments: Remediation Closure Guide Comments.

This far-reaching Nonrule Policy Document embraces all of IDEM’s clean-up programs, including Leaking Underground Storage Tank, State Cleanup, Voluntary Remediation Program, Brownfields, and Resource Conservation and Recovery Act Corrective Action (RCRA).  The RCG describes selected approaches to investigation and risk-based closure of contaminated or potentially contaminated sites administered by these program areas and more consistently applies Indiana Code (IC) 13-25-5-8.5, which is the statutory basis for risk-based cleanups in Indiana.  The RCG particularly emphasizes the development of Conceptual Site Models (CSMs) to facilitate risk-based decisions with respect to investigation and clean up.

The RCG is broken down into 13 sections:

 Section 1: Introduction

 Section 2: Conceptual Site Model (CSM) Development: Presampling

 Section 3: Conceptual Site Model (CSM) Development: Sampling

 Section 4: Conceptual Site Model (CSM) Development: Plume Behavior

 Section 5: Conceptual Site Model (CSM) Development: Vapor

 Section 6: CSM Development: Background and Off-site Sources

 Section 7: Risk Evaluation: Introduction

 Section 8: Risk Evaluation: Soil Direct Contact

 Section 9: Risk Evaluation: Ground Water

 Section 10: Risk Evaluation: Vapor

 Section 11: Risk Evaluation: Ecological and Other Scenarios

 Section 12: Remedy Selection and Implementation

 Section 13: Standard Equations

The sections receiving the most public comments were Section 4 (CSM Plume Behavior) and Sections 5 and 10 (Vapor).  Comments were received from both environmental consultants and industry professionals attesting to the importance of the RCG to both practitioners and the regulated community.  IDEM hopes to have the RCG published for use sometime during the fourth quarter of 2011, though it may be too early to tell whether this schedule will be met.

Please contact either Fred Nichols fnichols@astburyenviro.com or Dr. Jim King jking@astburyenviro.com at 317-472-0999 with any questions regarding the RCG and its application to your projects.  www.astburyenviro.com