New NFA Review Process Updates

CP CoffeeApril 13, 2015 

NWDO (2)

Up Town GreenSandusky Cabinets

NEDO (4)

Fairmont Creamery**Eastern Portion Fmr TIP

Fmr Alliance Comm. Hosp.

Parcel B – Harvard Ave

CDO (2)

Atlas Bldg**LC River South

SWDO (6)

Fmr Dayton ElectroplateFmr Cinci Die CastOhio Vet Children’s

HomeFmr Estate Stove

Piqua MPPFord Batavia

Fourteen NFAs submitted*

*As of 4/7/15**CNS Issued

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

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

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

Changes made and posted Ver. 3/9/15 http://

epa.ohio.gov/portals/30/vap/docs/NFA%20Letter%20template%203-9-15.docx

Template still subject to change

Please provide more input as we go along

NFA Template Updates

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

Cinci Die Cast Foundry until 2001 – vacated 2007 Structure razed 2011 Listed six IAs Future use is commercial/industrial

New Rule NFA

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

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

Letter generated

Eight pages

20 individual comments

Comments evenly distributed b/t all reviewers

INOD

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

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

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

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

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

Re-submit revise executive summary as necessary,

and

Revise supporting documentation accordingly!

Be sure to:

Questions