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Independent Closure Process

The Independent Closure Process (ICP) Guidance describes an approach to address investigation and remediation of low priority releases of petroleum and/or petroleum constituents. Its purpose is to provide an efficient method of closure at petroleum releases that pose a low threat to human and environmental health. The ICP Guidance describes a self-completion and certification process that allows persons responsible for the petroleum release to complete investigation, remediation, and site closure without IDEM’s direct oversight.

The requirements for closure approval include:

  • Investigation and/or remediation performed by an environmental consultant following the Remediation Closure Guide (Waste-0046-R2, available on the IDEM Effective Nonrule Policies page).
  • Implementation of institutional controls where applicable.
  • Submittal of complete and accurate closure documentation to IDEM within one year from the time of release discovery. The timeline to achieve closure may be extended to a maximum of three years from the time of discovery if the site has groundwater contamination that requires treatment and/or monitoring to achieve closure goals.

The reduction of direct oversight by IDEM does not relieve the responsible persons or environmental consultants from the legal requirements of reporting releases and conducting investigation and cleanup. IDEM will issue a No Further Action (NFA) status letter to the responsible person when the contamination has been adequately delineated and contaminants have been remediated to land-use appropriate closure levels, and/or institutional controls are implemented to protect human health and environmental receptors.

The ICP Guidance for Nonrule Policy Document [PDF] provides more information.

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