NFA Letter Template: Tips and Hints to Reduce Comments CP Annual Training October 27, 2015 Sydney Poole – DERR

General Maintain consistency within document and between Executive Summary and Tables – Begin each NFA letter (also OMP, RMP) with a fresh template, rather than copying previous NFA. – Have a second set of eyes look at the letter. Make sure Section D includes ALL docs relied upon (e.g., asbestos abatement report, BUSTR NFAs)

Identified Areas Section 2.1, Table, Maps Maintain consistency in document and tables Explain any changes in IA designation between Phase 1 and Phase 2. Clearly identify the IAs with their corresponding EU in both text and table. Provide a map of the IA and EU areas. Reminder: Asbestos in a building is not an IA. Asbestos is only an IA if it is released to environmental media.

Phase II Property Assessment Section General Reminder: Sample for COCs expected based on Phase 1.

Ground Water Section 2.5 When ground water meets UPUS: – no need to rely on being in a USD – no need for ground water use restriction – Must demonstrate protection (Section 3.5) Class B – Describe how classified – Yield determination, not being used – Yield + comparison to lower zone – Yield + shallow depth (<15’ bgs)

Ground Water Section 2.5 Note any irregularities in the ground water zones, such as: – Note if top and/or bottom of ground water zone varies across the property. – If confined ground water zone, note that top of water level in well is different than where water encountered during drilling. State the number of rounds of sampling in the text, or ensure figures are clear.

Vapor Intrusion Sampling Section 2.5 Summarize VI sampling methodology – How many rounds – Sample depth (exterior) – Length of sampling (for exposure time) Note: Two rounds of exterior soil gas sampling are recommended for collection when eliminating vapor intrusion as an exposure pathway - (May 2010 VI guidance) – Weather (rain)

Receptors and Pathways Section 3.1 Include all on and off property receptors. Include all potential media (ground water, soil, surface water, sediment) Provide an accurate conceptual site model. Include all ground water pathways, including: Construction, dermal, inhalation. Ground water to surface water – meet OMZA. Reminder: Meeting applicable standards does not render a pathway “Incomplete”

Modeling Section 3.2 Clarify if default or site-specific input parameters were used If site-specific parameters used, explain how they were developed If using a model that is out of the ordinary, include a description of the model and why it was used

Multiple Chemical Adjustment Section 3.3 MCA and pathway summation for each pathway and receptor in each EU or IA is required in most cases. – Exception: you have only one chemical; COC is TPH or lead; or presumptive remedy. Verify that your remedy meets a target risk of 1E-5 and a hazard of 1 for all receptors.

Ecological Risk Assessment Section 3.4 Summarize the progression through the steps of the risk assessment. State whether generic standards are met or if an ecological risk assessment was performed under Rule 9. Reminder: Include surface water and sediments as important ecological resources. – Sediment is only evaluated when it is tied to a surface water body.

Ground Water Protection Weight of Evidence Demonstration Too little – “WoE demonstration performed” Too much – Multiple pages of data and explanation Just right – Briefly summarize lines of evidence in one sentence each, as outlined in OAC (F)(3)(b) or (F)(4)(a)(ii), as necessary.

Section 3.5 – EXAMPLE COCs in upper ground water zone (SVOCs, metals) tend to sorb to soil particles and are not mobile in the subsurface. The contaminant sources on the property are all greater than 75 years old. Site investigations determined that at least 30 feet of unfractured silty clay exists between the upper ground water zone and next expected ground water zone. SeSoil modeling indicates contaminants will not infiltrate to the lower ground water zone.

Remedy Section 4.0 Remedy is needed for any complete pathway that does not meet applicable standards. Be clear about what constitutes a remedy (determining background or 95% UCL determine applicable standards, not a remedy) Describe the remedy and any remedy verification sampling.

Table 4.1 –”Summary” table Better name: “Representative COC concentrations before active remedy completed to achieve applicable standards” Only need to include COCs exceeding applicable standards, not below background or meeting C/I (noted in asterisk below table)

Tables 4.1 & Remedial Activities Example Soil meets Commercial/Industrial GNS Ground Water exceeds UPUS on property, meets at property boundary. Indoor air exceeds applicable standards, Liquid Boot installed.

Table 4.1 IA / EUMediaRepresentative COCs prior to remediation (ug/m 3 ) Applicable Standard (ug/m 3 ) Method Used for Deriving Applicable Standard Method of Achieving Compliance with Applicable Standard IA 3 - Office Indoor Air Toluene50,00022,000Generic Standard Passive barrier

Type of RemedyIA or EU Applies to COCs AddressedPathway(s) Addressed Commercial/Industrial AUL Property wideMetals, TolueneDirect contact with soil by commercial or industrial workers Ground water use restriction Property wideTolueneOn property potable and non- potable use of ground water Passive barrierIA-3TolueneVapor intrusion to indoor air Table 4.2

RMP Section 6.0 Include sentence in text describing area to which RMP applies, and demonstrate C/E standards are met in other areas. If the RMP is only for 2-10’, demonstrate the 0-2’ interval meets applicable standards. Remember that C/I remedy is not a remedy for C/E worker, RMP still needed

Activity and Use Limitations Section 7.0 Describe the delineation of the AUL area, if less than entire property

Modified Residential Properties Note Land Use Control in AUL (7.0), also Phase II (2.5) – note POC on soil table, discuss modified residential and POC in text Receptors & Pathways (3.1) – note modified residential receptor in table & text

Exposure Point Concentration Tables Exposure Point Concentration by media and receptor – follow example tables Clarify what blank table cells represent (not sampled, non-detect, etc.) If non-detects are not included in the table, include footnote in table stating that.

How To Respond Respond to INOD letter as part of addendum, in a point-by-point written narrative response. Include CP affidavit. Update Executive Summary as needed. Work with Legal to update EC, OMA, RMP as needed.

Questions?