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If excavation activities are conducted during UST removal, prior to an SCR being submitted, do these costs go on the EFS when the CAP is finally submitted?

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No, these costs would be submitted as Phase of Work 1 or 2 costs, whichever is appropriate. Costs on the EFS would only reflect remediation activities. Please note that any excavation activities at a UST removal must be discussed with an OPS reviewer to determine acceptable volumes of contaminated soil to be removed.

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