Gershman, Brickner and Bratton officials anticipate submitting the draft final technical memorandum this week. After incorporating feedback from the U.S. Environmental Protection Agency, GBB is hopeful the District Court of Guam will set a December hearing to end the federal receivership established under the 2008 court order that appointed GBB as the receiver.

The exit timeline is contingent on the USEPA, according to GBB Senior Project Engineer Chris Lund.

"It's called a draft final. That's this week. Then they look at that and they give their comments ... then we incorporate those comments and we provide a final," Lund said.

GBB also anticipates submitting the draft Cessation Certification Letter.

"Depending upon when we get USEPA's comments back on that technical memorandum, we plan on submitting and anticipate ... the second or third week of October, pending my internal review of that letter, making sure that it's got everything it needs to be in there to be submitted."

Lund said the interpretation of the requirements needs to be discussed with legal counsel.

"So, we're doing that. It says ... 'files that certification to USEPA, it doesn't say they accept it, it doesn't say they approve it. But we're certainly going to ... want to get a response out of them to, at the very least, say 'no further comments,'" Lund said.

While some internal discussion on next steps is needed with legal counsel, Lund said the court will eventually be advised and provide input.

GBB attorney Joyce Tang confirmed that a hearing with the court would need to occur and that the court would need to order the receivership to end.

"And then the Consent Decree, ... I don't have the exact language, but it has a sort of provision for one-year following the completion of those tasks. And so that's a matter for Court discretion. And I think that we obviously want to notify the Court once we submit the cessation certification and Chris is accurate in saying that there's no, like, acceptance requirement in the consent decree," Tang said.

Tang said once the court is notified, a hearing "first or second week of December would be appropriate."