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Published byAdela May Modified over 9 years ago
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New NFA Review Process Updates CP Coffee April 13, 2015
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Fourteen NFAs submitted* *As of 4/7/15 **CNS Issued
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Atlas Building First NFA issued Asbestos only remediation INOD sent – minor comments only 83 days submittal to sign-off Fairmont Creamery INOD (8 pg) sent – 7 day response CNS needed by 12/31 – tax abatement 70 days submittal to sign-off CNS’ Issued
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Time Legal group comments Affidavit instructions Submittal vs. issuance dates NFA Template Updates CP develops NFA CP finalizes NFA CP Issues Final NFA NFA Issuance Affidavit Volunteer reviews CP gives NFA to volunteer via transmittal letter Volunteer’s Written Notice of Submittal CP Receives Notice of Submittal CP submits to Agency for CNS NFA Submittal Affidavit
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Risk group comments New tables Include exposure point/MCA data CP suggestions Clearer instructions Better instructions on Table 4.1 Expand asbestos narrative in section 2.3 NFA Template Updates
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Changes made and posted Ver. 3/9/15 http://epa.ohio.gov/portals/30/vap/docs/NFA%20Letter%2 0template%203-9-15.docx http://epa.ohio.gov/portals/30/vap/docs/NFA%20Letter%2 0template%203-9-15.docx Template still subject to change Please provide more input as we go along NFA Template Updates
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After 10 CNS’ issued evaluate entire process Review timelines Sufficient time allowed? INOD/FNOD comments Type and style of comments? NFA submittals Getting needed information? NFA Process Review
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Cinci Die Cast Foundry until 2001 – vacated 2007 Structure razed 2011 Listed six IAs Future use is commercial/industrial New Rule NFA
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Pathways Direct contact – C/I Direct contact – C/E Groundwater – Class B upper zone VI (potential future buildings Developed background demo (As) PSRA – J&E modeling for VI Site facts
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Soil Excavation in IA-1 Soil exceeded saturation – elevated TPH No RMP / O&M needed EC Limit to C/I Prohibition on g.w. extraction Site facts
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Letter generated Eight pages 20 individual comments Comments evenly distributed b/t all reviewers INOD
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Inconsistencies Volunteer name Acreage Clarity required Number of soil samples per IA Possible inappropriate combination of releases to single IA Re-designation of IA Off-property release as IA – table/text revisions INOD Comments
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Potential O&M needed Slab left in place – engineering control or not? More inconsistencies C/E dir. contact w/g.w. listed in section 3.1 not in section 2.5 VOCs listed in five IAs VI pathway only assessed in one IA INOD Comments
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Background Incorrectly listed soil study value in text Clarify which soils being compared – soil type HHRA No std. developed for C/E g.w. – reasonably complete INOD Comments
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Groundwater No POGWMUPUS demo to lower zone Upper zone dirty, therefore POGWMUPUS applies to lower Arsenic value not in Table 4.1 Legal EC comments INOD Comments
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Generated many same (i.e., number and style) comments as past NFA reviews Focused to clarification and consistency revisions All rule based – citations for each INOD Comment Summary
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Re-submit revise executive summary as necessary, and Revise supporting documentation accordingly! Be sure to:
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Questions
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