My NFA letter Will Be Audited How is the CP Involved? VAP Annual CP Training

Key Points About Audits Statutory requirement and rule ( ) Ohio EPA has the lead VAP selects the NFA letters for audit Review of existing NFA letter information Limited interactions with volunteer, owner, CP or CL(s) Findings shared at the end

VAP/CP Points of Audit Interaction Audit NoticeProperty Walkover Request for InformationOptional Meeting Audit Findings Report Tier II Work Plan & Findings

Audit Notice Audits selected annually Publish list of NFA letters to be audited Send to CPs Individual letters to volunteer, owner, CP, and each CL (following CNS issuance) for each selected property Lead reviewer identified

Property Walkover Access requested through owner CP encouraged to attend Audit team, as available, will attend – Lead reviewer, CO audit coordinator, risk assessor, and/or ground water If CP available review team may ask clarification questions to help with the audit

Ohio EPA Audit Review Review of the NFA and all supporting documents – Confirm that the Property meets applicable standards – Confirm that property conforms to institutional controls – Confirm CL(s) were certified at time of analysis – Confirm CP was certified and evaluate work performed in issuing NFA

Request for Information Review team may identify missing information A written request will be made to CP or CL 30 days to respond Failure to respond may result in: – Permanent revocation of CP or CL license – Revocation of CNS

Optional Meeting Complexity of property Clarifying questions would be helpful VAP may request meeting with CP and volunteer/owner Clarify issues before finalizing audit finding report or pursuing Tier II

Final Audit Report Issued Most audits end here VAP will issue audit findings report Letter to volunteer is signed by Director Report sent to volunteer, owner, CP, and CL(s)

VAP Wants to Conduct a Tier II Tier II = additional sampling to confirm property meets standards Conducted at VAP’s discretion We will provide notice to owner/volunteer and CP Send a draft of audit findings report VAP may request a meeting to discuss reasons for Tier II and scope of audit

Tier II VAP will develop a scope of work, based on conceptual site model Request access from owner Finalize work plan, copy to CP and owner/volunteer Implement investigation Share results with owner/volunteer and CP

Tier II Findings & Actions An audit findings report will be sent out Property confirmed to meet standards, OR Property no longer meets standards – Volunteer/owner now has opportunity to “cure” – CNS revoked if cure not achieved

Summary VAP takes the lead CP will be notified of selected audits and the property walkover CP may be requested to provide additional information CP may be requested to attend optional meeting If applicable, Tier II work plan and findings will be provided Final audit finding report will be provided.

Current Audit Status 125 audits completed 22 audits review complete 38 audits ongoing – 17 last year’s selections – 22 “backlog” (7 pre-2012) Updated Audit Guidance for internal review complete as of 9/25/15. Next up: Develop internal process for selection of discretionary audits

Questions? Contact information: Dan Tjoelker