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

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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”.