EnviroNotes

By Andy Bowman, Partner, Environmental Law Department, Bingham McHale LLP

On July 19, 2007, the Indiana Department of Environmental Management (“IDEM”) published an update to the RISC User’s Guide on its website at www.state.in.us/idem/programs/land/risc/. The IDEM provides Risk Integrated System of Closure or RISC guidance materials for risk-based investigations and closures of contaminated sites in two companion manuals: the RISC User’s Guide and the RISC Technical Guide.

Chapter 2 of the User’s Guide, “RCRA Closure and Corrective Action Program,” has been updated to include a new section describing how the Hazardous Waste Permit Section will issue RCRA Corrective Action Completion Determinations. See Section 2.7.6. In addition the closure criteria have been revised to reflect U.S. EPA guidance.

The IDEM is also working on revisions to the RISC Technical Guide which are expected to be completed in 2008. The revisions are intended to clarify and streamline the Technical Guide and will include the addition of process charts and diagrams. The Technical Guide revisions will be presented to the Solid Waste Management Board as a nonrule policy document.

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