Jun
09
In the past few months, the 21J Board has issued two new policies that provide clarification and guidance on collecting and submitting documentation for the reimbursement of soil excavation and disposal as part of an MCP Response Action.
This action is taken as a result of the fact that, over the past year, the majority of claims involving soil disposal are likely to be initially denied, and then being heard in "conference" i.e. before a panel of 21J Board members for further consideration of the validity of the claims and charges.
These two newest 21J Fund policies can be found here.
The specific documents are:
- Collection and Presentation of Data in Support of Reimbursement: Petroleum-Contaminated Soil: The purpose of this policy, adopted on March 30, 2017, is to provide an acceptable framework for collecting and submitting documentation to demonstrate that soil excavated and disposed of as part of a Response Action is eligible for reimbursement.
- Policy For Reimbursement Of Petroleum Product "Impacted" Soil: On April 26, 2017, the 21J Board revised its policy on the reimbursement of the disposal of "contaminated" soil to include a portion of the related "impacted" soil of up to 25% of the eligible "contaminated" soil tonnage disposed offsite.
When you are contemplating soil excavation at a 21J reimbursable Site, please refer to this guidance in order to maximize cost recovery.
Thank you,
Michael A. Penzo, PG, CPG, LSP
LSP Association President
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