Remediation
Learn to use the Remediation module to manage tasks and costs associated with release remediation.
Written by Jess Hamilton
Updated at July 27th, 2024
Table of Contents
The Remediation module allows consultants, accountants, and other authorized individuals to document and track tasks and costs associated with release remediation. For a shareable PDF version of this resource, click here.
Access the Remediation Module
User Role Permissions for “Remediation - Release”
In order for users to access the Remediation - Release page, their user role must be granted permission.
- Locate the User Role settings in the Administrative Console and click the pencil edit icon.
- In the General tab, locate the Remediation/Cost Tracking section.
- Locate Remediation - Release and check the toggle box in the Access column.
- In addition to granting the user access to view the Remediation - Release page, you can choose to enable the following permissions:
- Add New remediation documentation
- Edit existing remediation documentation
- Delete existing remediation documentation
- Approve releases
- Edit specifically designated “one time entry” fields
- Edit the release number
Locate the “Remediation - Release” Page
Navigate to the desired facility.
In the facility menu on the left side of the screen, click Activities and Remediation - Release.
Add or Edit Remediation
To document remediation for a new release, click Add New.
To update existing documentation, locate it in the list and click the pencil edit icon.
To save changes, scroll to the bottom of the page and click Add New or Update.
Release Information Tab
If you are adding a new release remediation, you will only see the Release Information tab. This tab is essentially a cost sheet, containing basic details and is typically completed by a consultant and an accountant.
Color Key
Some of the fields on the Release Information tab are color coded using the following guidelines:
| Red | One time entry | Once saved, these fields can only be edited by users with specific permissions. |
| Green | Auto-calculated cell | These fields are calculated automatically. Manual entries or edits are not possible. |
| Yellow | Accounting cell | These fields are typically only completed by an accountant. |
Fields that are not highlighted may be populated or edited by anyone with edit access.
Release Information
| Field | Description |
|---|---|
| Release Number |
Specific number
*Requires |
| Release Date |
The date the release occurred
*Requires |
| State Incident Number |
The number the regulatory agency uses in their records to identify the release.
*Requires |
| State Risk Ranking | Some states (i.e. Florida) rank or score their releases, typically for trust fund prioritization purposes. If there is no rank, leave this field blank. |
| Combined Release | If multiple releases are being considered a single release by the “Funding Source” or regulatory agency, check this box. Add a comment in the “Remediation/Change in Cost Notes” section regarding what releases are considered combined, on what date they were combined, etc. |
| [Client] Remediation Contact |
The contact person overseeing/managing the release. This is a required field.
*This dropdown contains “Remediation Consultant” contact types from the Client & Facility Contact Lists |
| Cause of Release | Indicate the cause of the release, if known. Use the Unknown option if applicable. Use the “Remediation/Change in Cost” notes section at the bottom of the module to add commentary and or specifics if needed. |
| Discovery Method | Indicates how the release was discovered. Use the Unknown option if applicable. Use the “Remediation/Change in Cost” notes section at the bottom of the module to add commentary and or specifics, if needed. |
Consultant Information
| Field | Description |
|---|---|
| Consultant Name |
Select the name of the person managing the actual remediation.
*This dropdown contains “Remediation Consultant” contact types from the Client & Facility Contact Lists. |
| Cost Sheet Contractor |
This person is responsible for completing the release page/cost sheet.
*This dropdown contains “Cost Sheet Contractor” contact types from the Client & Facility Contact Lists. |
| Is Site Parked | Parked sites are not actively being worked on, typically due to low trust fund prioritization (i.e., historic Florida releases). Choose Yes, No, or N/A. |
| NFA Date | Date of the letter from the regulatory agency indicating no further action is required for the release. Leave blank if the release does not have an NFA. |
| RP (Legal Entity) for Release | Insert the Responsible Party (legal entity name) for the release. Leave blank if unknown. |
| Consultant Email Address | This field will self-populate based on the selected consultant's contact information. |
| Consultant Phone # | This field will self-populate based on the selected consultant's contact information. |
Release Status
Select one of the following options to describe the Release Status.
| Option | Description |
|---|---|
| Active Unfunded | Open release, no “Funding Source” (trust fund, insurance, etc.) to assist with project costs (AKA cash site or cash release – is (or will be) paying all costs out-of-pocket). |
| Active Direct Pay | Open release, consultant is (or will be) receiving payment directly from a Trust Fund or Insurance. Note “Active Direct Pay” releases may also include releases designated as “Cost Share”. Note Self Funded sites can’t be Active Direct Pay Release Status sites. |
| Active Funded | Open release, is paying consultant, and is (or will be) getting reimbursed from the “Funding Source”. Note “Active Funded” releases may also include releases designated as “Cost Share”. |
| No Further Action (NFA) | Release has been granted a No Further Action determination from the regulatory agency overseeing the cleanup (AKA closed release). |
| Active No Liability (ANL) | Open release where the responsibility to remediate the release is with another party. For example, if your organization acquired a site with a historical release, the prior site owner/occupant may be responsible for obtaining the NFA for the release. |
| Other | If “other” is selected, provide an explanation in the “Project Funding Notes” box at the bottom of the page. |
Funding Information
| Field | Description |
|---|---|
| Funding Source |
Choose the correct option regarding how the cost to remediate the release is handled. “Self funded” means is covering all costs out-of-pocket with no future reimbursement (AKA cash site). A “self funded” site should have a release status of “active unfunded”. If “multiple” is chosen, add a comment in the “project funding notes” box at the bottom of the page. If “other”, add a comment in the “Project Funding Notes” section below. |
| Deductible due to Funding Source |
Out-of-pocket amount due prior to funding source covering future costs. Typically, the deductible for Trust Fund/Insurance sites.
*Requires |
| Remaining Deductible Balance | Auto-calculated field. “Deductible due to Funding Source” minus “Total Spent by” minus “Total Spent by Others” |
| Cost Share |
If a release is partially covered by a funding source (remediation costs typically split between unfunded/funded, usually by a specific percentage) check this box (I.E. Florida SRFA agreements).
NOTE: all cost share sites should be noted as Active Direct Pay or Active Funded.
*Requires |
| Cost Share Percentage | If the “Cost Share” box is checked, insert the percentage the remediation cost must cover (AKA cash cost %) |
| Funding Cap |
The maximum amount the “Funding Source” will reimburse for site remediation.
NOTE: IF THE FUNDING CAP IS NOT REIMBURSED AT 100%, THE FUND CAP VALUE NEEDS TO BE THE TOTAL OF THE REIMBUSRED AMOUNT AND NON-REIMBURSED AMOUNT (WHEN THE COST SHARE BOX IS CHECKED). For example – Michigan legacy sites have 0$ deductible, and the fund will pay 50% of eligible items up to $50k. since the cost share box is checked, the Funding Cap entry on the cost sheet needs to be $100,000
*Requires |
| Site Expected to Exceed Funding Cap? | Auto calculated cell. This box will be checked automatically if “Current Amount Reimbursed by Funding Source” is greater than zero and the ”Current Amount Reimbursed by Funding Source” plus “Estimated Point Forward Cost to Close” is greater than the ”Funding Cap” Or if the “Current Amount Reimbursed by Funding Source” equals zero and the “Total Spent by ” plus the “Total Spend by Others” plus the ”Estimated Point Forward Cost to Close”) is greater than the ”Funding Cap”. |
| Total Spent by [Client] |
Amount which should be based on all invoices that are coded to the release.
*This field should only be completed by Accounting |
| Total Spent by Others |
Insert a zero “0” in this field, unless responsibility to clean up a release was assumed from a prior RP, and that RP spent dollars to clean up the release, then insert the dollars spent that where applied to a “Funding Source” deductible and/or CAP. This value is important when a release is covered by a “Funding Source”, and the prior RP either did work that would count towards a deductible and/or spent some of the “Funding Source” cap dollars.
*Requires |
| Current Amount Reimbursed by Funding Source | If known or obtainable from a “Funding Source” (typically a state database for a trust fund site), insert the dollar amount that has been reimbursed by the “Funding Source” for the release. If this information is not obtainable by a state database or similar source, insert a Zero. |
| Estimated Date of Closure | Insert the anticipated date the NFA will be received for this location. If an NFA has been received, yet there will be post-NFA spend, insert the date upon which all spend will be completed. If the site is parked, or can’t be estimated, assume 5 years from the current date. |
| Remediation System Present? | If a remediation system is present on the site for this release, check this box. If this box is checked, note the type of system in the “Remediation/Change in Cost Notes” section below. |
| Owned by? | Check this box if a remediation system is present on site from this release, and the remediation system is owned by your company. |
| Contamination Migrated Off Site? | Choose the appropriate answer, add comments as needed in the “Remediation/Change in Cost Notes” box below. |
| Water Supply Wells in Area? | Choose the appropriate answer, add comments as needed in the “Remediation/Change in Cost Notes” box below. |
| Directs Cleanup? | Choose the appropriate answer. If the state is dictating cleanup, or if the release is an ANL Release, choose “No.” |
Actual Cost Updated for
Select one of the following options to explain why the remediation page/cost sheet is being updated:
| Option | Description |
|---|---|
| New Release | Initial cost sheet completed for a recently discovered release. |
| Change in Estimate | The cost to close estimate is being changed due to new information (I.E. new drilling/analytical data, the determination that the groundwater ingestion pathway is complete, etc.) that affects the prior cost to close estimate. |
| NFA | Cost to close estimate is being changed due to the release being issued an NFA by the regulatory agency. |
| Normal Course | Cost to close estimate is being reduced due to normal remediation spending, or due to change of cost update being triggered by pre-determined time period since the last cost to close e |
| Acquired Site | Cost to close estimate is being added for a site with an existing release that your company is now responsible to remediate or the prior owner is required to remediate. |
| Other | Cost to close being submitted for a reason not listed above. If this is selected, clarifying information should be added to the “Remediation/Change in Cost Notes” box below. |
Scope of Work
Scope of Work Sub-Section
This Section is for consultant cost projections (future costs) to obtain an NFA for the Release.
ST (Short Term) costs are anticipated projected costs to be incurred in the next 365 days.
LT (Long Term) costs are anticipated projected costs to be incurred beyond 365 days (day 366 to NFA). By definition, if an “Estimated Date of Closure” is less than 1 year away, there can be no LT costs.
The Total Estimated Cost column is auto calculated. These cost to close projections are further broken down into the 7 subgroups below.
Tip: Project management and trust fund package preparation costs should be included in each bucket, as appropriate.
| Subgroup | Description |
|---|---|
| Immediate Corrective Action | Costs would include initial response costs, emergency response activities, possible immediate free product removal, associated reporting. |
| Source Investigation | Costs would include initial site assessment work (borings/wells/GW sampling/reporting). |
| Additional Delineation | Costs would include all projected subsurface assessment costs (both on and off site) beyond the initial source investigation, may include access agreements. |
| Free Product Recovery | Costs would include ongoing free product removal (hand bailing, mobile vac truck events) and associated reporting. |
| Remedial Action Plan (Plan, System, Risk Assessment) | Costs would include RAP development, pilot testing, risk assessment/plume modeling, remediation system installation, electrical costs, permitting costs, remediation system O&M, periodic sampling during the remediation process, etc. |
| Site Monitoring | Costs would typically include extended groundwater monitoring for natural attenuation closures, post-remediation system monitoring, may include confirmatory soil boring installation and soil testing to confirm site conditions at the end of the remediation process plus required reporting. |
| Site Restoration | Costs may include monitoring well abandonment, remediation system removal, remediation system conveyance piping removal or abandonment. |
Estimated Point Forward Cost to Closure Sub-Section
The costs in the sub-section header are auto calculated. They are the ST, LT, and Total costs from the 7 subgroups above summed up.
Additional fields are described as follows.
| Field | Description |
|---|---|
| Accrued Amounts | Accounting provides this amount. This value is the projected cost to close for the release based on prior consultant cost to close projections, minus project spend since the last submitted/approved cost to close estimate (cost sheet). If there is a $25,000 difference between the “ Accrued Amounts” and the “Estimated Point Forward Cost to Close/Total Estimated Cost”, the Scope of Work Costs are required to be adjusted. |
| Potential Total Estimated Cleanup Costs | Auto calculated value. This cost is the “Total Spent by ” plus “Total spent by others” plus “ Accrued Amounts.” |
| Estimated Amount of Cost Share | This value is the Estimated Point Forward Cost to Closure multiplied by the percent of the cost share, and should be provided by Accounting. |
| Estimated Amount Above Funding Cap | Auto calculated value. This is the projected cost for funded sites and is calculated as follows: “Potential Total Estimated Cleanup Costs” minus the “Deductible due to Funding Source” minus the “Funding Cap”. |
| Net Liability |
Auto calculated value. This is the projected net (out-of-pocket cost) expense (going forward) to obtain the NFA for the release.
For any release with the Release Status of Active Unfunded, the Net Liability is the Estimated Point Forward Cost to Closure.
For a release with the Release Status of Active Funded or Active Direct Pay, the Net Liability is the Remaining Deductible balance plus the Estimated Amount of Cost Share plus the Estimated Amount Above Funding Cap. |
Project Notes
The final section in the Release Information tab allows you to provide specific project notes covering the following categories:
Remediation/Change in Cost Notes – High level notes that include pertinent facts that influence project cost or scope.
Project Funding Notes – High level notes regarding Funding Sources, issues, etc.
Other Company Notes – High level general notes about the site, off site issues, real estate/access issues, etc.
These fields should contain information that would be helpful to a reviewer that does not have a day-to-day understanding of the project regarding the cost sheet, and important details that help support the status of the project, particularly the projected cost-to-close numbers.
Tip: All updates to these and other fields are tracked in the History tab, but it is still a best practice to include the date and the name of the person making the comment when any new note is added.
History Tab
The History tab contains a timestamped log of every edit that is made to the release documentation.
Approval Tab
Users with ApproveRelease permissions may click Approve Release. This automatically generates and attaches a Cost Sheet PDF file documenting the current version of the Release Information.
All release approvals are logged in the History tab.
Remediation Rules may be configured to automatically approve changes that meet specific criteria.
E-Files
In the E-files tab, you can choose to attach or remove associated files to the release remediation.
Use Existing - Select a file from the facility's Electronic File Cabinet (E-Files) and attach it to the release remediation.
Upload New File - Select a file from your device to upload and attach to the release remediation. The file will also be added to the facility's Electronic File Cabinet (E-Files).
Remove Linked File - Select a file that has already been attached to the release remediation to remove it. This does not delete the file from the facility's Electronic File Cabinet (E-Files).
Activities
Add or monitor Activities associated with the remediation from this tab.
Remediation Rules can be configured to automatically create an Activity when a new remediation is created, or when specific conditions are met.
Equipment
If your company uses the Equipment Tracking feature, equipment associated with the release remediation may be managed in this tab.