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Get the latest updates on MOA-Track documents, simplify forms and processes, and learn about the interim revisions implemented on July 29.
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MOA-Track Updates Certified Professional Training October 27, 2015
MOA-Track documents • Out of date • Have not been revised since July 2010 • Struggle to use the forms under today’s rules • Forms follow old-style NFA letter forms • Time consuming to fill out • Confusing and complex • Goal: Simplify forms and process • Interim step implemented July 29 • Full revision coming
Enter Technical Assistance Public Notice MOA Eligibility Determination Ohio EPA Acknowledgment of Entry START - NOTICE OF ENTRY 1 Signed Volunteer Agreement Document Repository Complete assessment up to but prior to remedial actions – TA as needed Ohio EPA approval of assessment, RAP & remedy documents Complete RAP, remedy documents & public notice 2 YES Is a remedy necessary? Implement Remedy Ohio EPA approval of assessment documents NO FINISH NFA LETTER 3
Interim Revisions • Form #1 updated: Procedures for Participation • Step 1 – Notice of Entry • Forms #2 thru #7 retained • Eligibility form still needs to be updated
Interim Revisions • Step 2 – Investigation Documents and RAP • Phase I, Phase II, ground water, & risk assessment forms eliminated (#8, #13, #14, and #15) • Form #17 replaced with current O&M Plan template • Phase II sampling plan guidance (Form #9) – optional
Step 3 – NFA Letter • What’s Expected? • Same requirements as “Classic VAP” NFA Letter • Same level of review as “Classic VAP” • Already familiar with work, except for actual implementation of remedy • Auditing of MOA-Track NFA Letters • Excluded from random audit • Still subject to discretionary and compliance audits
Next Steps… • Revise eligibility form #7 • Simplify to be more user friendly • Separate forms: Agency vs. Volunteer • Emphasize 3-step process • Overall instructions for MOA-Track • Notice of Entry package • Investigation/RAP package • Time table unknown