By Michael J. Reeder, Hatchett & Hauck LLP
The Indiana Department of Environmental Management (IDEM) is accepting comments on a newly developed Draft Excess Liability Trust Fund (ELTF) Application that will be required for all costs incurred on or after July 1, 2017. The Draft Application incorporates a phase-based format and would require the applicant to identify all phases of work associated with the pay request – whereas, the current version of the ELTF Application requires the applicant to identify the most recent technical determination. The phases listed in the Draft Application include: immediate response; site characterization and corrective action plan development; corrective action plan implementation; groundwater monitoring and remediation system O&M; and closure.
Comments must be submitted to IDEM no later than June 2, 2017 at noon. IDEM will evaluate the comments and make the final version of the Draft Application available by July 1, 2017. Additional information regarding the Draft Application and how to submit comments can be found on IDEM’s website here.
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