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Axlor Consulting addresses NCP consistency issues, leading to a cost recovery settlement.

Axlor Consulting recently provided expert analysis on consistency with the National Contingency Plan (NCP) as part of a cost recovery action related to cleanup at a port. At issue was claimed cost recovery for past investigation, cleanup, and litigation costs, as well as potential future costs. Principal Gayle Schlea Koch assessed invoices related to millions of dollars of past claimed costs for NCP issues such as accounting accuracy, documentation, proof of payment, public comment, and whether the costs were for response and reasonable and necessary. She also assessed claims for millions of dollars of estimated future costs as they related to NCP requirements. Ms. Koch’s analysis provided key input to the successful settlement of this matter.