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Voluntary Action Program Updates
Certified Professional Training October 27, 2015
Staffing Changes
• VAP staff in Columbus– Sydney Poole, promoted to lead worker–Brent Goetz, new staff member
• Doug Switzer, DDAGW lead worker
•Marty Cooper (legal), retiring
Roles for Columbus Staff
Pre-CNS Issues
• Sydney Poole (lead worker)– USD requests/verifications– VAP TA issues– MOA-track issues– NFA letter reviews– Guidance/training
• Brent Goetz– VAP TA issues– MOA-track issues– NFA letter reviews
Post-CNS Issues
• Dan Tjoelker (lead worker)– NFA letter audits– CP disciplinary actions– Post-CNS compliance issues
• Emily Patchen– Compliance tracking– Post-CNS compliance issues
WORKLOAD AND NFA LETTER UPDATE
VAP Projects Workload
Audit61 USD Review
2USD Inspec-
tion12
Technical Assistance
141
MOA Track25
O&M Oversight128
RMP Oversight
101
5-year IC Inspection
54
NFA Letter44
Status of NFA Letter Reviews Since Last CP Coffee
11 NFA Letters17 CNS Issued• 8 “old” rules• 9 “new” rules
44 Pending NFA Letters• 22 “old” rules• 22 “new” rules
New Rule NFA Letters
• 34 NFA letters issued – 12 received CNS
• Fastest time to issue CNS – 70 calendar days – 60 days (agency time)
• Slowest time to issue CNS– 250 (or 255) calendar days– 208 days (agency time)
Comparison of “Old” vs “New” NFA Letters
NFA Letter Type
Days to Send INOD
Days to Receive
Addendum
Percent FNOD
Required
Days to Send FNOD
Days to Receive
Addendum
Total Days to Issue CNS (Agency
Time)
Total Days to Issue CNS
(Calendar)
"Old" Style 130 64 49 % 70 52 238 320
"New" Style 69 30 25 % 38 32 134 174
Reduction 61 34 50 % 32 20 104 146
NoNAC Letter
• Notice of No Additional Comments Letter– Notifies CP/Volunteer that addendum has been
accepted– VAP will recommend issuance of CNS (~30 days)– Dual purpose of a “comfort letter”
• Sent only if signed documents are not needed– NERD will be sent instead
VAP RULE CHANGES: CORRECTING ERRORS & OMISSIONS
Considering Corrections & Clarifications
• Cross-referencing errors
• Missing or duplicative text
• Clarify conflicting rule requirements
• Errors in risk standards tables
• Fix typos and citation errors
Early Stakeholder Outreach
• Notice sent out to interested parties & posted to Ohio EPA webpage June 12, 2015
• Concluded July 17, 2015
• Summary of proposed changes presented at last CP Coffee
Previous Training Presentations
Next Steps
• Complete draft rule language– November 2015
• Interested party review of draft rule language– 30 days beginning Nov/Dec 2015
– Business Impact Analysis and Common Sense Initiative Office Review, finalized after conclusion of IP review
Next Steps (continued)
• File with JCARR: January 2015
• JCARR jurisdiction lasts 65 days – Public Hearing 31 to 40 days after filing date
– JCARR Hearing at end of jurisdiction period
• Finalize rules & set effective date– Final file rules with JCARR
– Rules effective spring 2016
VAP RULE CHANGES: POST-CNS REMEDY CHANGES – OAC 3745-300-11(H)
Remedy Revision
• Rule added 8/1/14
• Have since noted conflicting rule language
• Propose clarification of remedy revision process– Resolve timing conflicts between existing and
new O&M Plans, institutional controls, RMPs– Clarify process to maintain compliance
Remedy Revision Notice
• Description of new remedy• Describe any remedy no longer in use• List of “supporting documentation” relied upon to
determine and verify compliance• CP affidavit attesting that the new remedy meets
applicable standards• Compliance with “paper-work” requirements• Request either acknowledgement or
approval from agency
Implementing a New Remedy• Language of O&M Plan/Agreement, institutional
control, or RMP determines what can or cannot be done
• Three basic questions for agency review…– Is new remedy likely to comply with rule requirements and
applicable standards?– How is continued compliance demonstrated?– How is compliance maintained during transition?
Will remedy revision conflict with existing requirements in an O&M
Plan, IC or RMP?
Proposed remedy revision must be sent to agency prior to
implementing new remedy
New remedy should be implemented first, then remedy revision notice sent to agency
Does new remedy require an O&M Plan,
IC or RMP?
Seek agency authorization for new O&M Plan, IC or RMP
Seek agency authorization for new O&M Plan, IC or RMP
Yes
No
No Yes
Process #1
Process #3Process
#2
Process #1 – New remedy doesn’t require an O&M Plan, IC or RMP
Acknowledgment• Volunteer implements new remedy• Agency receives remedy revision
notice• Agency sends acknowledgment
letter to volunteer
Approval• Volunteer implements new remedy• Agency receives remedy revision
notice• Agency reviews supporting
documentation• Agency comments, if necessary,
are addressed• Agency sends approval letter to
volunteer
Process #2 – New remedy requires an O&M Plan, IC or RMP
Acknowledgment• Volunteer implements new remedy• Agency receives remedy revision
notice• Agreement reached on new O&M
Plan, IC or RMP• Agency sends acknowledgment
letter to volunteer
Approval• Volunteer implements new remedy• Agency receives remedy revision
notice• Agency reviews supporting
documentation• Agency comments, if necessary, are
addressed• Agreement reached on new O&M
Plan, IC or RMP• Agency sends approval letter to
volunteer
Process #3 – New remedy conflicts with an existing requirement in an O&M Plan, IC or RMP
Acknowledgment• Agency receives remedy revision
notice• Agreement reached on new O&M
Plan, IC or RMP• Agency sends acknowledgment
letter to volunteer• Volunteer implements new
remedy
Approval• Agency receives remedy revision
notice• Agency reviews supporting
documentation• Agency comments, if necessary, are
addressed• Agreement reached on new O&M
Plan, IC or RMP• Agency sends approval letter to
volunteer• Volunteer implements new remedy
Questions?