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?
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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