Final Remedial Action Completion Report for the ... - Rvaap.org

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Cmt.# Page # Line # A-41 Section 3.0 and Referen- ces A-42 References New Page or Sheet Comment Recommendation Response March 2008. • Shaw will revise the second sentence in Section 2.3.2 to state “BRACD has already contracted for removal of slabs and foundations at LL 2, 3, and 4. BRACD started slab and foundation removal in March 2008.” Several “Final” Shaw deliverables are cited as references, but do not appear to be in REIMS. Please forward these to Pat Ryan at SAIC so that they can be added to REIMS. Noted deliverables that do not appear to be in REIMS include: A)RAWP, Shaw 2007b. B)SHERP, Shaw 2004e. C)Security, Emergency Response, & Contingency Plan, Shaw 2004f. D) Project Coordination Plan, Shaw 2006a. E) Field Sampling Plan Addendum No. 1 …Shaw 2006b. F) QAMP, Shaw 2006d. G)SAP Addendum No. 1…Shaw 2006f. • Ref. 1. Delete “(OEPA)”. • Ref. 3. Delete “the” after “for” in line 7. • All references. Some of the references have titles enclosed by quotation marks, but not all. Revise for consistency. Shaw Environmental, Inc. 33 of 39 Shaw has included electronic versions with the hard copies of all plans and reports submitted to the RVAAP library under this contract so it is unclear as to why they have not been loaded onto the REIMS; however, Shaw will contact Pat Ryan to ensure that all documents are accounted for. • OEPA will be deleted from reference no. 23. • “the” will be deleted after “for” in line 7. • The quotations will be removed from the titles of the references in order to be consistent. • #24 – The year “2004” is
Cmt.# A-43 A-44 A-45 Page # Line # Section 3.1.1, Line 9 Section 3.1.1 Section 3.2.1, lines New Page or Sheet Comment • #24. The year “2004” appears twice in the reference. Delete “-“ after the word “all”. Clarification requested. Although NPDES is an ARAR, isn’t it only necessary to comply with the substantive requirements, not the administrative, e.g., permitting, requirements? Were the NPDES permit and SWPPP, as administrative requirements, necessary? • In line 27, use of the word “proposed” implies that the Shaw Environmental, Inc. 34 of 39 Recommendation Response intended since the reference is listed in the document as “USACE 2004”. “-“ will be deleted after the word “all” in line 9. The NPDES permit and SWPPP were an administrative requirement per the direction of the Mr. Tim Morgan from OHARNG and the RVAAP. In an email dated 3/14/07, Mr. Morgan stated the following: “If you plan to disturb 1 or more acres of earth (combined disturbance for the project) then you'll need coverage under the Ohio EPA general NPDES permit for storm water discharges associated with construction activity. The permit needs to be in the landowners name (BRACD since you are working on their property in the load lines) and all contractors working on the site need to be co-permittees under the landowner permit. The way the OHARNG works this is to require all contractors to develop the Storm Water Pollution Prevention Plan (SWPPP) and submit the Notice of Intent (NOI) for coverage and fee for the government. Coverage is a requirement under state law.” These requirements were further enforced by the RVAAP Facility Manager, USACE COR, Mr. John Jent and the OhioEPA Facility Coordinator, Ms. Eileen Mohr. • Line 27: “Proposed” will be replaced by “baseline”.
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