By R. Scott Stoldt, CPG, LPG, PG – Technical Director Investigation & Remediation Services Division
Years ago, as part of IDEM’s roll-out of the 2012 Remediation Closure Guide (RCG), a companion guide (the Remediation Program Guide, RPG) was released to provide specific direction in applying the new RCG guide to site closure. Under Section 1.4 of the RPG, a Transition Policy was included to assist with the changeover from the previous Risk Integrated System of Closure (RISC) to RCG. As part of the Transition Policy, a 6-month window was afforded to those parties wishing to pursue closure under the RISC guidance; effectively giving those parties until September 22, 2012 to submit a Corrective Action Plan (CAP) for IDEM approval.
On June 12, 2018 IDEM published an announcement to clarify its position on the Transition Policy for petroleum sites (https://www.in.gov/idem/tanks/files/eltf_announcement_20180612.pdf). The announcement served to explain that any revision or addendum to a CAP after the September 22, 2012 transition date, should have been transitioned to the RCG in accordance with the Transition Policy.
Specifically, IDEM’s announcement states:
“No site should be proceeding under any guidance other than the RCG except under a CAP, CAPA[addendum], [revised]RCAP, or the like which was submitted and approved in accordance with the Transition Policy and which has not been amended in any way after its approval.” [added for clarity]
IDEM further expanded that, unless approved in accordance with the Transition Policy, any Excess Liability Trust Fund claim seeking reimbursement for RISC-related activity incurred after July 31, 2018 (or the next quarterly event) would be denied.
Should you have any questions on how this announcement may affect your site please contact Wilcox at (877) 683-8378 or info@wilcoxenv.com.