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Regulatory Update

Using the R2 Guidance in Indiana

Recently, we have used our experience to implement the new Indiana Department of Environmental Management (IDEM) regulatory guidance, called the Risk-Based Closure Guidance (R2). The IDEM R2 guidance is the framework and standards for investigation, site characterization, risk assessments, and closure of contaminated or potentially contaminated sites. Named R2 as it the second revision of the original 2012 Remediation Closure Guide, this guidance became a nonrule policy document (NPD) on July 8, 2022.

What’s Changed

As summarized in IDEM’s December 2022 Remediation Services Bulletin, the key differences in this update are:

  • The addition of five new guides (which mirror R2 terminology) to efficiently make amendments as programs change:
  • State Cleanup Program Guide (Waste-0076-NPD)
  • Voluntary Remediation Program Guide (Waste-0077-NPD)
  • Petroleum Remediation Program Guide (Waste-0082-NPD)
  • RCRA Closure and Corrective Action Program Guide (Waste-0015-NPD)
  • Institutional Controls Program Guide (Waste-0081-NPD)
  • An Institutional Controls (ICs) guide added to achieve risk-based closures using Environmental Restrictive Covenants (ERCs), Environmental Restrictive Ordinances (EROs), and long-term stewardship (LTS).
  • A Soil Management Plan guide was added for projects with an ERC containing soil excavation restrictions.
  • Indiana Brownfields Program guidance was added to the website, which replaces the Federal Programs – Site Investigation, Superfund, and Defense Environmental Restoration Program references.
  • Updated forms are now on the Agency Forms section of IDEM’s website.

Note that the Excess Liability Trust Fund Program will develop its guidance separately. After incorporating the comments received, the final documents were presented to the Environmental Rules Board (ERB) on November 9, 2022.

Have Questions?

Need help or have questions on this guidance? Reach out to us, Jason Shriner ( or Kelly Kuhn, ( if you have further questions regarding the new IDEM R2 guidance, ASTM E1527-21 standard, or other Indiana regulatory questions.

Jason Shriner

Jason Shriner is a project manager with over 17 years of professional experience. Jason specializes in the subsurface investigation of chlorinated solvents, petroleum, and heavy metals and has implemented strategies to reduce the concentration of contaminants for industrial manufacturers, dry cleaners, and gasoline stations. Jason is an experienced Environmental Professional that has conducted due diligence for complex facilities and assists with regulatory compliance reviews. He and his team assist clients with Phase I Environmental Site Assessment (ESA), Limited Compliance Review, Phase II ESA, stormwater permitting and compliance, and environmental testing and corrective action projects. Jason is a Certified Hazardous Materials Manager and holds a BS in Environmental Soil Science from Purdue University.

Kelly Kuhn

Kelly Kuhn is a project manager with over 13 years of professional experience. Kelly specializes in due diligence across all types of property and facilities. She has managed and assisted with the oversight of US EPA Assessment Grants and Revolving Loan Fund Grants in addition to writing grant applications for communities and coalitions of communities. Kelly and her team assist clients with Phase I Environmental Site Assessments (ESAs), Limited Compliance Reviews, Desktop Reviews, Phase II ESAs, stormwater permitting and compliance, and environmental testing and corrective action projects. Kelly holds a BS in Environmental Management from Indiana University.

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