Data is entered in ICIS for conclusion credit when the agreement/final order is considered final. An agreement that must go through a public comment period is not considered final until the comment period expires. The agreement could be altered based on comments received. After the public comment period expires, and any changes are made to the agreement based on comments received, the agreement is considered final and should be entered in ICIS for conclusion credit. For instance, if a signed CERCLA agreement for past costs includes a cost compromise, and there is a public comment period, the agreement is not considered final until the comment period expires, and any changes are incorporated.
There are other program situations (i.e., Clean Water Act, Safe Drinking Water Act) which must go through public comment prior to finalizing the final order. OECA has historically consistently said these orders are not considered final or concluded until the public comment period expired.