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Published byLesley Beatrice Collins Modified over 9 years ago
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MOA-Track Updates Certified Professional Training October 27, 2015
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MOA-Track documents Out of date – Have not been revised since July 2010 – Struggle to use the forms under today’s rules Forms follow old-style NFA letter forms – Time consuming to fill out –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
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START - NOTICE OF ENTRY Public Notice Document Repository Enter Technical Assistance Signed Volunteer Agreement Ohio EPA Acknowledgment of Entry MOA Eligibility Determination Complete assessment up to but prior to remedial actions – TA as needed Is a remedy necessary? Complete RAP, remedy documents & public notice Ohio EPA approval of assessment documents NO YES FINISH NFA LETTER Ohio EPA approval of assessment, RAP & remedy documents Implement Remedy 1 2 3
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July 29, 2015 Memo to CPs
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MOA Track Forms
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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
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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
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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
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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
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Questions?
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