xvEPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Publication 9360.3-03
EPA-540/R-94/023
PB93-963421
June 1994
Superfund
SUPERFUND REMOVAL
PROCEDURES
Removal Response Reporting:
POLREPs and OSC Reports
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Publication 9360.3-03
PB93-963421
EPA-540/R-94/023
June 1994
SUPERFUND REMOVAL PROCEDURES
REMOVAL RESPONSE REPORTING:
POLREPs and OSC Reports
u s. E-wlronm^ Protection Agency
Rogion 5, Library (PL-12J)
?7gWest Jackson Bouiarard, 12th Flooi
Chicago, It- oObOA-3590
Office of Emergency and Remedial Response
U.S. Environmental Protection Agency
Washington, DC 20460
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NOTICE
The procedures set out in this document are intended solely for the guidance of
Government personnel. They are not intended nor can they be relied upon to create any
rights enforceable by any party in litigation with the United States. EPA officials may
decide to follow the guidance provided in this document, or to act at variance with the
guidance, based on an analysis of site circumstances. The Agency also reserves the right to
change this guidance at any time without public notice.
KEY TO SYMBOLS
Two types of symbols appear throughout this document to assist readers in obtaining
additional information or to focus attention on specific points.
Bracketed numbers [#] appear in the text and exhibits and correspond to specific references
in Appendix B. This comprehensive reference list includes related guidance documents,
statutes, and regulations which provide more detailed information on Superfund program
policies and procedures.
Some information required for the reports may also be required for the Comprehensive
Environmental Response, Compensation, and Liability Information System (CERCLIS).
This information is denoted by the symbol ® in the POLREP models and the model OSC
Report. This symbol is intended to assist OSCs in identifying items to be entered into
CERCLIS.
n
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This document is part of a ten-volume series of guidance documents collectively titled the
Superfund Removal Procedures. These stand-alone volumes update and replace OSWER
Directive 9360.0-03B, the single-volume Superfund Removal Procedures manual, which was
issued in February 1988.
Each volume in the series is dedicated to a particular aspect of the removal process and
includes a volume-specific Contents, References, and Key Words Index. The series
comprises the following nine procedural volumes:
The Removal Response Decision: Site Discovery to Response Decision
Action Memorandum Guidance [Publication 9360.3-01]
Response Management: Removal Start-up to Close-out
Removal Enforcement Guidance for On-Scene Coordinators [Publication 9360.3-06]
Public Participation Guidance for On-Scene Coordinators: Community Relations
and the Administrative Record [Publication 9360.3-05]
Removal Response Reporting: POLREPs and OSC Reports
Special Requirements
Guidance on the Consideration of ARARs During Removal Actions [Publication
9360.3-02]
State Participation in Federal-Lead Removals
In addition, the series includes an Overview volume containing a comprehensive Table of
Contents, List of Exhibits, Index of Key Words, List of Acronyms, and Glossary, for use as
a quick reference.
111
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One of the most important responsibilities of the On-Scene Coordinator (OSC) is reporting
all removal activities to EPA management and the public. Reporting requirements include
preparing a series of Pollution Reports (POLREPs) and an OSC Report for each removal.
This Removal Response Reporting volume describes how to prepare and distribute
POLREPs and OSC Reports. POLREPs and OSC Reports must meet the Superfund
program policy requirements and, where applicable, the regulatory requirements under
section 300.165 of the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP).
This volume clarifies reporting criteria and informs the preparers of POLREPs and OSC
Reports about the potential users and uses of these reports. This volume will make these
reports more useful by promoting their accurate preparation and timely distribution.
Accurate documentation is critical for cost recovery and overall program management.
Preparation of accurate, complete, and timely reports
is an important part of an OSC's job and critical to the
success of the program.
IV
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CONTENTS
Section I. Pollution Report Guidance 1
Pollution Reports 3
Purpose 3
POLREP Distribution 4
Users and Uses of POLREPs 5
Information Requirements for POLREPs 5
POLREP Format 8
Model Initial POLREP 11
Model Progress/Special POLREP 19
Model Final POLREP 25
POLREP Review Checklist 30
Section II. OSC Report Guidance 33
OSC Reports 35
Purpose 35
Users and Uses of OSC Reports 35
Timeliness of Preparation 37
Format and Information Requirements 37
OSC Report Attachments 40
OSC Report Distribution 40
OSC Report Review Procedures 41
Model OSC Report 43
OSC Report Review Checklist 61
Appendix A - Model Initial and Final POLREP 63
Appendix B - References 69
Appendix C - Key Words Index 71
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EXHIBITS
Exhibit
Number
1 POLREP Outline 10
2 Waste Treatment, Containment, and Disposal 17
3 POLREP Review Checklist 30
4 OSC Report Usage 36
5 Outline of an OSC Report 39
6 Executive Summary of the Removal Activity 45
7 Organization of Response 49
8 Materials and Disposition 52
9 Removal Project Estimated Total Cost Summary 54
10 OSC Report Review Checklist 61
VI
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SECTION I
POLLUTION REPORT GUIDANCE
Pollution Reports (POLREPs) comprise initial, progress, special, and final POLREPs. They
provide factual, operational, and progressive data on an incident or on site activities, and
a current accounting of the total funds allocated for removal activities[l]. POLREPs also
detail the search for potentially responsible parties (PRPs), other enforcement activities, and
measures taken to inform the community of the removal activities. They also inform OSCs
at other sites about innovative approaches to containment, site cleanup, and waste treatment
or disposal which were successful or unsuccessful. POLREPs provide detailed progressive
information on cumulative costs and activities at removal sites. POLREPs are a means of
alerting EPA Headquarters and Regional program management about ongoing removal
activities, cumulative costs, and important or critical events occurring or pending at sites.
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POLLUTION REPORTS
POLLUTION REPORTS
Purpose
Pollution Reports (POLREPs) provide documentation of activities for: removal
activities under the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) of 1980 as amended by the Superfund Amendments and
Reauthorization Act (SARA) of 1986 [2]; oil spill responses under the Oil Pollution
Act (OPA) of 19901; and, in some instances, underground storage tank removals
under the Resource Conservation and Recovery Act (RCRA). Although the
POLREP model presented in this document may be used to write POLREPs for all
three response activities mentioned, the information and examples used in this
volume of the Superfund Removal Procedures (SRP) apply only to CERCLA
removal activities.
The principal function of the POLREP is to inform Regional management, EPA
Headquarters, the Regional Response Team (RRT), the National Response Team
(NRT), and the trustees of affected natural resources regarding:
The source and circumstances of the release
The identity of potentially responsible parties (PRPs)
The removal activities performed
The costs incurred for the removal activities
The impact and potential impact of the release on public health and
welfare, and on the environment
OSCs prepare POLREPs throughout a removal activity, providing factual and timely
reporting of ongoing removal activities and the total costs incurred for most removal
sites. Although the NCP does not require POLREPs for PRP-lead sites, OSCs are
encouraged to prepare POLREPs and keep Regional management, Headquarters,
the NRT, and the RRT informed of activities on site, especially any unusual or
significant incidents. POLREPs are prepared at the initiation and completion of a
removal activity, and at regular intervals in-between. POLREPs should be prepared
daily, weekly, monthly, or as the need arises due to changes at the site, keeping in
mind Regional practices. POLREPs provide detailed information regarding the
initial situation, ongoing removal activities, the next steps to be taken, and the
Responses to oil spills prior to August 18,1990, were funded under Section 311(k) of the Clean Water
Act (CWA). Under Section 2002(b)(2) of the Oil Pollution Act (OPA) of 1990, Section 311(k) was
repealed. In brief, the OPA increases the Federal oil spill fund from $35 million to $1 billion. The
OPA also increases and expands the administrative and civil penalties for discharges of oil. The OPA
establishes stricter requirements (including potential administrative penalties for noncompliance) for the
development of prevention, containment, and cleanup contingency plans for onshore and offshore
facilities.
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POLLUTION REPORTS
breakdown of cumulative project costs. They provide details regarding enforcement
activities, media attention, and measures taken to inform the affected community of
removal activities. The final POLREP for the removal documents that all proposed
tasks have been completed as outlined in the Action Memorandum, thereby
establishing the completion date for the removal. The final POLREP also
summarizes the results achieved by the removal.
The collection of POLREPs for each site is often the best detailed record of removal activities.
POLREP Distribution
POLREPs are sent to the Director of the Emergency Response Division (ERD) at:
• E-Mail EPA 5511, or
• Telefax number (703) 603-9116 or (703) 603-9107
In the event that neither one of these methods of communication is available,
POLREPs may be mailed to:
Director, Emergency Response Division, 5202-G
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
In addition, POLREPs should be distributed to Regional branch/section chiefs and
all agencies or parties participating in the removal activity, as appropriate, including,
but not limited to:
U.S. Coast Guard, telefax number (202) 267-2165
RRT representatives
State representatives
Local/county representatives
U.S. Fish and Wildlife Service
National Oceanic and Atmospheric Administration
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POLLUTION REPORTS
Users and Uses of POLREPs
The primary users of POLREPs are Regional program managers and EPA
Headquarters staff. POLREPs are the primary means for OSCs to notify
Headquarters Regional Coordinators (and all Headquarters personnel) of routine site
progress and important or critical events. OSCs also use POLREPs to inform the
NRT, the RRT, and the trustees of natural resources affected by the release, the
identity of the PRP, the removal activity, the costs, and the effects of the release on
public health, welfare, and the environment.
POLREPs provide a current, cumulative, estimated accounting of the total funds
allocated for the removal activities and of how those funds are spent. Costs reported
in POLREPs assist Regional section chiefs and Regional Coordinators in anticipating
the need to amend Action Memoranda and to request ceiling increases [4].
POLREPs provide information on problems that may require Headquarters support.
The Regional Coordinators emphasize that POLREPs should report not only what
has occurred, but also upcoming events. Headquarters and Regional program
managers use POLREPs for research purposes to assist in defining policy and
developing guidance, and to learn about innovative approaches to hazardous
substance containment, treatment, and disposal. POLREPs may also be used to
report under the Superfund Comprehensive Accomplishments Plan and the Strategic
Planning and Management System. Final POLREPs are important to cost recovery
personnel in the Regions, the Office of Enforcement Compliance Assurance
(formerly the Office of Waste Programs Enforcement), and the Department of
Justice for Statute of Limitations determinations.
Information Requirements for POLREPs
POLREPs should contain only factual information concerning a site. Presenting the
information as objective statements of fact will minimize the possible adverse effects
of negative performance appraisals on cost recovery efforts. In describing the
effectiveness of removal activities, do not make subjective judgments, draw
conclusions which are not fact-based, or discuss the legality of actions or events.
There are four main types of POLREPs: initial, progress, special, and final. After
an initial POLREP, progress POLREPs are prepared intermittently throughout the
removal activity. Special POLREPs document unanticipated developments which
affect the progress or focus of the removal (e.g., flooding, accidents). Final
POLREPs document that all response activities listed in the Action Memorandum
and any addenda are complete. Some response activities require only one POLREP,
which acts as both an initial and final POLREP. Refer to Appendix A for a model
of this type of POLREP. Summaries of the information requirements for each type
of POLREP are presented below.
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POLLUTION REPORTS
Initial POLREPs
An initial POLREP is prepared for each
new removal activity. The information in
an initial POLREP should be clear, precise,
* f '
and as complete as possible. Subsequent
POLREPs need not have as much detail as
the initial POLREP. Readers of later
POLREPs are frequently referred to the
initial POLREP for background and site
information. The initial report should give
the exact site location and coordinates
(latitude/longitude); describe the incident,
including results of the preliminary
assessment (PA) or site inspection; discuss
the status of removal or remedial activities
(including enforcement); verify that the
State has been consulted and discuss any
j
results of that notification; describe the
next steps to be taken; and identify any key
issues or problem areas.
At some sites, a combined site screening
and assessment may be performed which
will address both removal and remedial
requirements. The results of the
assessment and/or site inspection must be
reported in the initial POLREP.
Depending on the circumstances of the
response, initial POLREPs may be written
before the Action Memorandum for the
site has been written and approved for the
Some information that should be in
a POLREP:
The exact site location including site
coordinates (latitude/longitude),
street address (city, county, state),
acreage, and boundaries.
Whether an alternative to land
disposal of wastes was used. Use
care in documenting the rationale and
o
the use of any alternative technology.
Be sure to document which wastes are
returned to a manufacturer or user or
are otherwise recycled.
Contact with news media staff and
with officials at the local, State, or
national level. Document all public
meetings that are held.
All contact with PRPs, including
notice letters, administrative orders,
and all written or oral
communications.
Problems with disposal of wastes.
Unusual occurrences that may have
affected the scope or cost of the
removal action. Discuss inclement
weather, flooding, additional
contaminants found, citizen protests,
etc.
site. If the Action Memorandum has been
written, the initial POLREP should indicate its status, noting when it was written, if
the Action Memorandum was approved, and specifying the project ceiling and
expenditures. A model for an initial POLREP is presented on pages 11 to 16.
In many cases, the initial POLREP is written prior to the completion of the Action Memorandum.
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POLLUTION REPORTS
Progress POLREPs
Progress POLREPs should describe the status of ongoing removal activities; explain
the actions taken since the last POLREP; describe the next steps to be taken; briefly
discuss the key issues and problem areas; and detail current cost information (project
ceiling and expenditures). In addition, progress POLREPs should include other
pertinent (but non-sensitive) information, such as the status of efforts to locate and
obtain cleanup by PRPs, and community relations concerns. In general, progress
POLREPs should contain information on any changes since the previous POLREP.
Progress POLREPs track estimated cumulative project ceiling expenditures.
Regional practices may differ on the frequency of progress POLREPs. However, if
the activity at the site warrants them, routine progress POLREPs generally should
be prepared and submitted to ERD once every week. If there is little to report and
the activities do not change substantially from week to week (e.g., the continued
sampling and removal of hundreds of drums), routine progress POLREPs should be
submitted once a month. Where the situation warrants (e.g., response to a spill
which included the evacuation of nearby residents), submit progress reports on a
more frequent (such as daily) basis. If circumstances warrant delays in submission
of POLREPs, such delays should not be deemed actions at variance with this
guidance. A model for a progress POLREP begins on page 19.
Special POLREPs
Special POLREPs are written when the situation at the site justifies particular
attention. There is no unique format required for a special POLREP. The format
for a progress POLREP may be used; however, the POLREP should carry the
banner "SPECIAL" across the top to alert the reader. Situations that justify
particular attention may include fires, explosions, floods, heightened community or
media attention, and accidents, even where no damage or injury was sustained. (If
there is an accident on site, an OSHA 101 form should be completed, in addition to
reporting the accident in the POLREP.) Special POLREPs should describe the
incident or change in circumstances which warranted special attention; outline the
actions taken in response to the incident; specify any change in scope of work the
incident caused; list any key issues associated with the incident (such as media
attention or demobilization of the contractor); and provide current cost information
(including expenditures associated with the incident). Refer to the model of a
progress/special POLREP on page 19.
Final POLREPs
When a removal has been completed (i.e., when all objectives outlined in the Action
Memorandum and any addenda, including removal and transport of wastes off site,
waste disposal, and demobilization have been accomplished), a final POLREP is
prepared and submitted. The final POLREP is submitted on the action completion
date. It describes the current situation (site conditions at the completion of the
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POLLUTION REPORTS
removal activity); explains the actions taken
since the last POLREP; outlines the next
action(s), if any, to be conducted after the
completion of this response (e.g., remedial
activity or post-removal site control);
presents the results achieved by the removal
activity; and details final costs associated
with the removal activity. A final POLREP
should be precise and detailed because it is
often used by cost recovery personnel in the
Regions, the Office of Enforcement
Compliance Assurance, and the
Department of Justice. A model of a final
POLREP begins on page 25.
Write the final POLREP immediately after the
completion of the removal action.
Confidential and
information that
enforcement efforts.
PRP-sensitive
may hamper
POLREP Format
All POLREPs should be objective,
containing only factual, non-sensitive
information concerning the site, and should
not draw conclusions or make
recommendations. POLREPs must be
concise, generally one to two pages in
length, and should contain only the kinds of
information listed in the models below.
The initial and final POLREPs should be
detailed and complete, while the progress
and special POLREPs may be updates of
the previous POLREP and can refer the
reader to the initial POLREP for more
information, if necessary. The use of the
following models by all ten Regions will
result in nationally consistent and
comprehensive reporting and will make
accessing information from any of the POLREPs easier for all users.
In addition to providing a summary of the site situation and actions taken since the
last POLREP, each POLREP includes a detailed cost accounting of site expenditures,
specifying the project ceiling, the current cost to date, and the amount remaining for
Some information that should not
be in a POLREP:
Uncommon abbreviations. Be
aware that not all readers are familiar
with abbreviations for State agencies,
local computer systems, etc.
Indeterminate measures for
quantities of waste removed from a
site; (e.g., three truckloads of
contaminated soil were removed, or
four dumpsters filled with soil and
debris were trucked off the site).
Unless the volume of such containers
has been indicated, the reader has no
information about the quantity of
waste removed. Use defined
measures of weight and volume
instead.
Chronological descriptions of work
performed, with hour-by-hour, step-
by-step notations. Do not repeat the
site log entries verbatim. The
POLREP should be more concise
than log book accounts.
Unspecified or subjective
complaints about contractor
performance. Such comments are
useful only when they are factual
(e.g., the ERRS contractor did not
have the drum grappler needed to
stage the drums), and not statements
of opinion.
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POLLUTION REPORTS
SPECIFICITY IN RECORDING ACTIONS
For all POLREPs: Be as specific as possible when recording information about
a site. Record the exact location of the site, including site coordinates
(latitude/longitude), street address (city, county, state), acreage, and boundaries.
Use precise measures (or best estimates) of area, volume, or weight.
Indeterminate quantities and undefined references provide little information. Try
to provide quantitative measures when describing:
• Concentrations above "background levels" — indicate the background
levels
• Amounts of stained soil or affected vegetation (e.g., stressed, diseased, or
dead) - estimate the area and volume of contamination
• Number of residents relocated
• Number of individuals or residences provided with alternative water
supplies
• Quantities of solid or liquid wastes removed from the site or treated on
site
the removal activity. Cost data may be supplemented according to Regional cost-
tracking practices, provided the required information is complete.
Exhibit 1 on page 10 provides the standard outline for all POLREPs. The three
model POLREPs that follow address data requirements and provide examples for
each type of POLREP.
Exhibit 2 on page 17 provides detailed information on recording site wastes that
should be listed in the waste matrix. It lists the types of wastestreams, containment,
treatment, and disposal options available to the OSC.
Exhibit 3 on page 30 provides a POLREP review checklist. OSCs should refer to this
checklist to ensure that all POLREPs are complete.
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POLLUTION REPORTS
EXHIBIT 1. POLREP OUTLINE
I. Heading
Date POLREP is written
Subject (site name)
From
To
POLREP Number
II. Background
Site Number
Delivery Order Number
Response Authority
ERNS Number/CERCLIS Number
NPL Status
State Notification
Action Memorandum Status
Start Date
Demobilization Date
Completion Date
III. Site Information
A. Incident Category
B. Site Description
1. Site location
2. Description of threat
C. Preliminary Assessment/Site Inspection Results
IV. Response Information
A. Situation
1. Current situation
2. Removal activities to date
3. Enforcement
B. Planned Removal Activities
C. Next Steps
D. Key Issues
V. Cost Information
VI. Disposition of Wastes
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MODEL INITIAL POLREP
U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION REPORT
Model Initial POLREP
I. HEADING Example:
®2 Date: October 10, 1991
® Subject: Whimperton Wire Company Site, Bobsled, New Jersey
® From: Joan Smith, OSC, U.S. EPA, Region 2, Response and Prevention Branch
To: Robert Watson, Director, ERD
Janet Cohen, Response Operations Branch Chief, Region 2
James Stacks, NJDEP
POLREP No.: POLREP I3
II. BACKGROUND Example:
® Site No.: Q9
Delivery Order No.: N/A
Response Authority: CERCLA, § I04(a)
ERNS No.:4 30691
® CERCLIS No.:5 N/A
® NPL Status: Final NPL
State Notification: NJDEP notified
® Action Memorandum Status: Under preparation
Start Date:6 N/A
Demobilization Date: N/A
Completion Date: N/A
1 A ® denotes information that should be included in CERCLIS.
3 Certain removals may require only one POLREP that becomes both the initial POLREP and the final
POLREP. If this is the case, refer to the model initial and final POLREP hi Appendix A to ensure that
the information requirements for both the initial and the final POLREP are met.
4 Emergency Response Notification System (ERNS) is a national computer database and retrieval system
used to store information on the release of oil and hazardous substances.
5 If the CERCLIS number is available at this stage, use both the CERCLIS and ERNS numbers.
6 The start date is the date of the actual start of the removal and not the date of the preliminary
assessment. The initial POLREP may be written before the Action Memorandum has been written and
approved for the site. If the initial POLREP is written before the actual start of the removal, the start
date should be indicated as N/A.
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MODEL INITIAL POLREP
III. SITE INFORMATION
® A. Incident Category
• Indicate the appropriate CERCLA incident category for the site from
the following list:
Active Production Facility
Inactive Production Facility
Active Waste Management Facility
Inactive Waste Management Facility
Midnight Dump
Transportation-Related
Other (Explain)
Example: CERCLA incident category: Inactive Production Facility
0 B. Site Description
1. Site location
• Briefly describe the site setting, including site coordinates
(latitude/longitude), location (city, county, state), acreage, and
ownership.
Example: The Whimperton Wire Company is located in Bobsled
Township, Hunterdon County, NJ (38°37'57" AT, 75°35'06"
W). The site is a 200-acre abandoned steel manufacturing
facility owned by David A. Whimperton.
• Describe the area (e.g., residential, urban, commercial) and
estimate the threatened population (as identified in the
Preliminary Assessment).
Example: The site borders the Delaware River to the north and Sanders
Creek to the east. The residential community of Bobsled
surrounds the site to the south and west. Approximately 1,450
people reside within a one-mile radius of the site.
• Discuss past and present site activities.
Example: The company operated from 1906 until 1984, and produced
primarily steel wire and cable; in recent years the site also
served a variety of industrial purposes, including a polymer
reclamation facility, a warehouse facility, a repair facility for
trailers, and an equipment storage facility for a construction
company.
2. Description of threat
• Describe the threat to human health or the environment posed
by the site. If the threat is the result of a single incident or
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MODEL INITIAL POLREP
release, describe the incident or release, including the date and
what ensued.
Example: In September 1991, the EPA Region 2 Removal Action Branch
requested that the Region 2 Response and Prevention Branch
conduct a preliminary assessment of the Whimperton Wire
Company site. The request was based in part on requests from
local officials, including the Bobsled Town Fire Marshal, who
had expressed concern that uncontained hazardous substances
at this site presented a potential threat to the local population.
C. Preliminary Assessment/Site Inspection Results
• Briefly discuss the results of the site evaluation.
Example: On September 23, 1991, EPA and the technical assistance contractor
conducted a preliminary assessment to determine the need to remove
hazardous substances from the site. The site was found to contain
approximately 2,100 drums containing unknown liquids and solids, 3
chemical treatment baths in which unknown solutions were present, 59
compressed gas cylinders, 4 chemical laboratories containing various
sized containers, 2 aboveground storage tanks with unknown contents,
stained soil areas, and exposed asbestos insulation on overhead pipes.
IV. RESPONSE INFORMATION
® A. Situation
1. Current situation
• Summarize the current situation on site; include information
pertinent to site conditions, including (but not limited to)
weather, media activity, and unusual incidents.
2. Removal activities to date
• Describe what, if any, removal activities have already been
initiated, including preparation of the Action Memorandum,
whether the OSC invoked the $50K response authority for
emergency situations, any actual site mobilization and the
actions taken, and any community relations activities.
Example: The OSC is currently writing an Action Memorandum for
authorization to begin removal activities. The Action
Memorandum will be submitted to the Regional Administrator
by October 23, 1991.
After the Action Memorandum is signed, the OSC will meet
with Bobsled Township Mayor Brenda Cook and New Jersey
Congressman Bart Wilson to discuss future cleanup activities
for the site.
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MODEL INITIAL POLREP
• Discuss State and local agency involvement, including any
request for EPA assistance; any State or local agency
cooperation in assessing the incident and threats, any "first
responder" or other actions taken by State or other agencies to
protect public health and the environment; and whether State
or other agency personnel remain at the site.
Example: The State (NJDEP) provided historical information on the site
during the assessment phase of the removal. In addition, the
Bobsled Township Fire Department provided a renewable air
supply during the preliminary assessment.
3. Enforcement
• Indicate whether EPA or State enforcement activities have been
initiated.
Example: Nineteen PRPs have been identified and letters notifying them
of potential liability under Section 107(a) of CERCLA are
being prepared by the Removal Enforcement Section.
B. Planned Removal Activities
• If the Action Memorandum has already been prepared, discuss the
planned removal activity as outlined in the Action Memorandum.
Example: Because of the large size of the facility, the site will be divided into four
quadrants and a two-phase removal activity is proposed. Phase 1 will
include immediate site stabilization measures. Drums, aboveground
tanks, and compressed air cylinders will be inspected for integrity,
sampled for analysis, and stored on site while arrangements for
transportation and disposal off site are made. Loose asbestos will be
removed from buildings and containerized on site for disposal. Phase
2 will consist of the off-site (ransport and disposal of materials stored
during Phase 1.
C. Next Steps
• Describe plans for removal activities, including site mobilization,
sampling, and other cleanup activities.
Example: If the Action Memorandum is approved, EPA will mobilize the ERRS
contractor on November 2, 1991, and begin removal activities with the
collection of uncontrolled and uncontained materials.
• Discuss ongoing PRP search or other enforcement activities, as
appropriate.
Example: EPA will meet next week with Personal Investments, Incorporated (PII),
which holds a financial interest in the site as lien-holder. PII is
currently providing security guards for the site on a 24-hour basis.
• Outline any planned meetings with local authorities.
Example: If the Action Memorandum is approved, the OSC will attend a meeting
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MODEL INITIAL POLREP
with Bobsled Township Mayor Brenda Cook and New Jersey
Congressman Bart Wilson on October 26, 1991, to discuss future site
activity.
• Discuss planned community relations activities.
Example: EPA is planning to issue a fact sheet concerning the site and cleanup
activities. This fact sheet will include a telephone number for an EPA
Regional contact who will address questions from concerned residents.
D. Key Issues
• Identify any problem areas.
V. COST INFORMATION
• Provide detailed current cost estimates for the site using the RCMS daily cost
summary. All expenditures relevant to the site should be noted in the
POLREP. OSCs should also indicate any anticipated future funding needs.
NOTE: There are no costs noted in this model initial POLREP,
because the Action Memo is not complete, no costs have been
incurred, and there is no project ceiling7 yet. Only those costs
that can be attributed to the project ceiling should be included.
For an example of cost summary in a model POLREP, please
refer to the Cost Information section in the model progress
POLREP on page 23.
• Include the following statement in all POLREPs where costs are noted:
The above accounting of expenditures is an estimate based on figures known
to the OSC at the time this report was written. The cost accounting provided
in this report does not necessarily represent an exact monetary figure which
the government may include in any claim for cost recovery.
Note: Regional offices should include ceilings for ERRS, TAT/START, or other line items if such
ceilings are maintained. In addition, Regional offices may track other costs not mentioned here
according to Regional practices, provided that the required cost information is included in the Cost
Information section.
7 The project ceiling is the proposed total removal cost as estimated in the Action Memorandum.
15
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MODEL INITIAL POLREP
VI. DISPOSITION OF WASTES
Using the waste disposal matrix below, list the wastestreams identified and
note the medium and quantity affected. For each wastestream, indicate the
planned or actual disposition (e.g., containment, treatment, disposal). See
Exhibit 2 on page 17 for more information on recording site wastes.
Abbreviations may be used in the matrix and clarified in the text of the
POLREP. Keep each individual wastestream separate. See Exhibit 2 for
more information.
Example:
Wastestream
Base neutral
solids
Acids
Medium
Solid
wastes
Liquid
wastes
Quantity
450 cu yd
5, 000 gal
Containment -
Migration
Control
Bulked &
overpacked
Bulked &
overpacked
Treatment
None
None
Disposal
16
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MODEL INITIAL POLREP
EXHIBIT 2. WASTE TREATMENT, CONTAINMENT, AND DISPOSAL
When describing waste treatment, containment, and/or disposal, include the
following information in the waste disposal matrix:
Wastestream:
Medium:
Quantity:
Containment:
Treatment:
Disposal:
Indicate either the specific type of waste, the particular
contaminant(s) of concern, or the general contaminant
category: solvents, acids, base neutral solids, cyanide,
PCBs, heavy metals (specify), dioxins or furans,
halogenated organic compounds, other RCRA-listed
wastes (specify), non-hazardous or de-listed wastes.
Choose from wastewater, liquid wastes, organic sludge,
solid or solidified waste, contaminated soil or debris, or
other medium.
Select volume, area, or weight. Use exact, standard
measurements whenever possible.
Indicate how a wastestream has been contained or how
the migration of contaminants was controlled. This may
include mitigating exposure to hazardous materials
through site security, alternative water supply, relocation
of residents, or temporary removal of materials.
Note the treatment that was used (e.g., precipitation,
neutralization, solidification, fixation, stabilization, etc.),
or "none," if applicable.
Note the type of disposal of the wastestream, if
applicable. Note if disposal was on site or off site;
include specific details such as a company address, city
and state.
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MODEL PROGRESS/SPECIAL POLREP
U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION REPORT
Model Progress/Special POLREP
Maintain consistent information by revising and summarizing previously completed initial or progress
POLREPs. See Exhibit 1 on page 10 for a POLREP outline.
I. HEADING Example:
Date: January 22, 1992
Subject: Whimperton Wire Company Site, Bobsled, New Jersey
0 From: Joan Smith, OSC, U.S. EPA, Re^on 2, Response and Prevention Branch
To: Robert Watson, Director, ERD
Janet Cohen, Response Operations Branch Chief, Region 2
James Stacks, NJDEP
POLREP No.: POLREP 19 [Indicate here if this is a special POLREP.]
II. BACKGROUND Example:
0 Site No.: Q9
Delivery Order No.: 7334-02-063
Response Authority: CERCLA, § W4(a)
ERNS No.: 30691
® CERCLIS No.: NJD987654321
0 NPL Status: Final NPL
State Notification: NJDEP notified
Action Memorandum Status: Approved, October 31, 1991
® Start Date: November 2, 1991
Demobilization Date: N/A
Completion Date: N/A
ill. SITE INFORMATION
Summarize this information from either the initial or most recent POLREP. If
POLREPs are written often for the site (e.g., weekly), this summary may be as short
as one line. If POLREPs are not written at frequent intervals, the summary may be
up to six. lines in length, or more.
Example: The site is an abandoned steel wire and cable manufacturing facility, and was previously
a polymer reclamation facility, located in the residential township of Bobsled, NJ. EPA
discovered drums of unknown liquids and solids, chemical treatment baths, compressed
gas cylinders, chemical labs, and storage tanks with unknown contents. (Refer to
POLREP #1 for more detailed site information.)
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MODEL PROGRESS/SPECIAL POLREP
IV. RESPONSE INFORMATION
® A. Situation
1. Current situation
Summarize the current situation at the site and the status of the
ongoing removal activity, including information pertaining to
site conditions, weather (if pertinent), media activity, and other
relevant factors. In addition, describe any changes in the
situation since the last POLREP.
Example: Work operations have been slowed down this week because of
inclement weather and icy conditions.
If this is a special POLREP, describe the incident or change in
circumstances which necessitated a special POLREP. Describe
any fires, accidents, or other situations of note, since the last
POLREP.
Example: Today the ERRS contractor discovered that Building #22 had
been vandalized and that there was extensive damage. All of
the contractor's heavy equipment which was stored in the
building had been damaged. In addition, hoses to the
emergency shower were cut, and a generator, a power washer,
and a compressor were damaged. Thirty drums containing
flammable liquids were also vandalized. Approximately 1,200
drums containing liquid wastes, including cyanide, are stored
in the building near the equipment. The technical assistance
contractor took photographs of the damage. The OSC ordered
all personnel off the site for demobilization. The township
police and county'sheriff were notified of the damage, and of
the risk in entering the building. As of this date, site activities
have ceased until the police arrest the miscreants and assure
the OSC of safety for all site personnel.
2. Removal activities to date
Describe removal activities undertaken since the last POLREP,
including mobilization, sampling and analysis, waste
containment (at a minimum include the information required
in section VI of the POLREP), and community relations
activities. Describe any fires, accidents, or other situations of
note since the last POLREP.
Example: A 60-foot manlift was rented to investigate on-site buildings
with catwalks. The ERRS contractor discovered nearly 200 5-
gallon containers on the catwalks of buildings in quadrant I.
The ERRS contractor continued to collect drums and cylinders
from the interior of buildings in quadrant I. In addition, the
ERRS contractor completed color-coding the drums. Seven
different wastestreams have been designated. Base neutral
20
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MODEL PROGRESS/SPECIAL POLREP
solids were bulked into 15 rolloff containers of 30 cubic yards
each. Five thousand gallons of acids have been bulked into
55-gallon drums.
• Discuss State and local agency involvement, including any
request for EPA assistance; any State or local agency
cooperation in assessing the incident and threats; any "first
responder" or other actions taken by State or other agencies to
protect public health and the environment; and whether State
or other agency personnel remain at the site. If there has been
no change since the last POLREP, skip this section.
For a special POLREP:
Example: The township police and county sheriff have provided
assistance in preparing reports on the vandalism and
documenting the results of the vandalism.
3. Enforcement
• Indicate whether EPA or State enforcement activities have been
initiated.
Example: Nineteen PRPs have been identified, and notification letters
under Section 107(a) of CERCLA have been sent by the
Removal Enforcement Section.
B. Planned Removal Activities
• Discuss the planned removal activities as outlined in the Action
Memorandum. Summarize the information from the initial POLREP,
unless a subsequent Action Memorandum was written. If there has
been no change since the last POLREP, refer the reader to the initial
POLREP and skip this section.
Example: Phase 1 (site stabilization measures) of the removal activity continues
in all four quadrants of the site. Drums and aboveground tanks are
being sampled and analyzed on site. Loose asbestos from the buildings
will then be removed and containerized on site, pending disposal.
Phase 2 will consist of the off-site transport and disposal of materials
stored during Phase 1.
• If this is a special POLREP, include any additional planned removal
activities as a result of the special situation.
Example: As a result of the vandalism, the OSC is currently preparing a Request
for Ceiling Increase and exemption from the $2 million funding
limitation. This will increase the cost ceiling and will expand the scope
of the removal activity originally outlined in the Action Memorandum.
C. Next Steps
• Describe plans for ongoing removal activity, including waste analysis,
containment, and cleanup; enforcement; planned meetings with local
21
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MODEL PROGRESS/SPECIAL POLREP
or Regional environmental or enforcement agencies; and community
relations activities.
Example: As sampling and analysis of the drums proceeds, drums will be
segregated and color-coded according to wastestream.
Arrangements will be made for a lab pack company to remove lab
packs with known contents for recycling or disposal.
Twenty-four hour site security will continue to be provided by Personal
Investments, Inc., the lien holder.
For a special POLREP:
Example: The OSC will await advice and counsel from EPA management
regarding mobilization of ERRS and continuation of site activities.
D. Key Issues
• Identify any problem areas.
Example: All site personnel were temporarily demobilized due to the vandalism
in Building #22. This necessitated a change in the scope of work. The
delay in completion of the removal, combined with the cost for
additional site security, has raised the costs well beyond the project
ceiling approved in the Action Memo.
• For a special POLREP, identify any problem areas. Indicate if a
change in the scope of the response is required because of the special
situation.
Example: As a result of the vandalism, the OSC is preparing a Request for
Ceiling Increase requesting an emergency exemption from the $2 million
funding limit and a change in the scope of work.
• Discuss measures which could have been taken or are being taken to
avoid future releases or incidents of a similar nature.
Example: With the assistance of the NJ. State Police and the U.S. Marshal, a
revised site safety plan is being prepared. The OSC will meet with FBI
agents to request a Federal investigation of violence and vandalism at
this site in order to better address future site security measures.
V. COST INFORMATION
• Provide detailed current cost information for the site using the RCMS daily
cost summary. The table below lists examples of cost information that OSCs
should provide. To the extent practicable, all expenditures relevant to the site
should be noted in the POLREP. OSCs should also indicate any anticipated
future funding needs.
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MODEL PROGRESS/SPECIAL POLREP
Example:
ERRS Contractor
lAGs
Letter Contracts
Extramural Cleanup Contractor Costs
TAT/START Contractor Costs
CLP Analytical Services
REAC
Intramural Direct Costs (HQ, Regions, ERT)
Intramural Indirect Costs
Total Intramural Costs
TOTAL
® Project Ceiling
® Percent of Project Funds Remaining
Cost To Date
850,195
30,000
N/A
107,000
184,136
$
$
880,195
98,164
N/A
N/A
291,136
1.269.495
1,800,000
29.5%
Individual Regions should note ceilings for ERRS, TAT/START, or other line items if such ceilings are
maintained. In addition, Regional offices may track other costs not mentioned here according to
Regional practices, provided that the required cost information is included in the Cost Information
section.
For a special POLREP:
Example:
ERRS Contractor
TAGs
Letter Contracts
Extramural Cleanup Contractor Costs
TAT/START Contractor Costs
CLP Analytical Services
REAC
Intramural Direct Costs (HQ, Regions, ERT)
Intramural Indirect Costs
Total Intramural Costs
TOTAL
® Project Ceiling
® Percent of Project Funds Remaining
Cost To Date
865,847
35,000
N/A
146,000
201,000
$
$
900,847
117,000
N/A
N/A
347,000
1.364.847
1,800,000
24.2%
NOTE: Because building #22 was vandalized, the OSC is preparing a Request for Ceiling
Increase to obtain an emergency exemption from the $2 million funding limit.
Include the following statement in all POLREPs:
The above accounting of expenditures is an estimate based on figures known
to the OSC at the time this report was written. The cost accounting provided
in this report does not necessarily represent an exact monetary figure which
the government may include in any claim for cost recovery.
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MODEL PROGRESS/SPECIAL POLREP
VI. DISPOSITION OF WASTES
Using the waste disposal matrix below, list the wastestreams identified, and
note the medium and quantity affected. For each wastestream, indicate the
planned or actual disposition (e.g., containment, treatment, or disposal). See
Exhibit 2 on page 17 for more information on recording site wastes.
Abbreviations may be used in the matrix and clarified in the text of the
POLREP. Keep each individual wastestream separate. The matrix should be
cumulative: add incremental figures to the data noted in any previous
POLREP. If a wastestream was removed off site after being contained, delete
the information entered for that wastestream from the containment category
and add it to the disposal category. Containment and disposal should not
both be denoted for the same wastestream. See Exhibit 2 on page 17 for
more information.
Example:
Wastestream
Base neutral
solids
Acids
Medium
Solid
wastes
Liquid
wastes
Quantity
450 cu yd
5, 000 gal
Containment -
Migration
Control
Bulked &
overpacked
Treatment
None
Recycled
Disposal
Everclear Products
Camden, NJ
24
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MODEL FINAL POLREP
U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION REPORT
Model Final POLREP
Maintain consistent information by revising and summarizing previously completed initial or progress
POLREPs. See Exhibit 1 on page 10 for a POLREP outline.
I.
-------
MODEL FINAL POLREP
Note: The response is considered complete when all actions at the site are complete and any wastes sent
off site for treatment and/or disposal have been received at the off-site facility. Indicate the actual date
that the objective of the response (including any off-site treatment or disposal) was achieved. Write the
final POLREP immediately after the removal activity is complete. The date of the final POLREP is the
removal completion date for the Statute of Limitations.
III. SITE INFORMATION
Summarize this information from either the initial or the most recent POLREP.
Example: The site is an abandoned steel wire and cable manufacturing facility, and was previously
a polymer reclamation facility, located in Bobsled, NJ. EPA conducted a preliminary
assessment at the request of the local authorities and discovered drums containing
unknown liquids and solids, chemical treatment baths, chemical labs, and storage tanks
with unknown contents. (Refer to POLREP #1 for more detailed site information.)
IV. RESPONSE INFORMATION
® A. Situation
1. Current situation
• Describe any changes in the situation since the last POLREP.
2. Removal activities to date
• Describe removal activities undertaken since the last POLREP,
including waste containment/disposal (at a minimum include
the information required in section VI of the POLREP), and
community relations activities. Describe any situation of note
since the last POLREP.
Example: On August 31, 1993, the OSC demobilized site security. He
later attended the kick-off public meeting called by remedial
personnel,
• Describe any State or local agency cooperation in assessing the
incident and threats; any action taken by State or other agencies
to protect public health and the environment; and whether any
State or other agency personnel remain at the site.
3. Enforcement
• Indicate the status of EPA or State enforcement activities.
Example: Nineteen PRPs were identified and notification letters under
Section 107(a) of CERCLA were sent by the Removal
Enforcement Section. There was no response.
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MODEL FINAL POLREP
B. Planned Removal Activities
• Discuss the removal activity as outlined in the Action Memorandum.
C. Next Steps
• Describe plans for any further site activity, including any post-removal
site control; waste analysis, containment, and cleanup; enforcement;
planned meetings with local or Regional environmental or enforcement
agencies; and community relations activities.
• Discuss the status of the OSC Report and the expected completion
date. If applicable, indicate any future site activities (e.g., PRP,
remedial, or State).
Example: Preparation of the OSC Report will begin next week and will be
submitted by December 1, 1993.
D. Key Issues
• Identify any problem areas.
• State how the objectives set forth in the Action Memorandum were
achieved through the removal activity. Specifically address any wastes
remaining on site, including those which are contained. Document
how threats to human health and the environment have been reduced
or eliminated.
Example: Access to the site has been restricted by fencing and 24-hour guard
service. Long-term security will now be addressed by the remedial
personnel as they address continued cleanup of this NPL site. All
surface hazardous materials have been shipped off site and no further
surface contamination remains. The remedial staff will also be
addressing groundwater contamination issues.
v. COST INFORMATION
• Provide detailed final cost information for the site using the RCMS daily cost
summary. The table below lists examples of cost information that OSCs
should provide. Individual Regions should also note ceilings for ERRS,
TAT/START, or other line items if such ceilings are maintained. To the
extent practicable, all expenditures relevant to the site should be noted in the
POLREP. Final cost information should be as detailed as possible.
27
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MODEL FINAL POLREP
Example: Cost To Date
ERRS Contractor $ 2,788,444
JAGs 47,000
Letter Contracts N/A
Extramural Cleanup Contractor Costs 2,835,444
TAT/START Contractor Costs 168,353
CLP Analytical Services N/A
REAC N/A
Intramural Direct Costs (HQ. Regions, ERT) 200,000
Intramural Indirect Costs 299,569
Total Intramural Costs 499,569
TOTAL $ 3.503.366
® Project Ceiling $ 3,600,000
® Percent of Project Funds Remaining 2.7%
Include the following statement in all final POLREPs:
The above accounting of expenditures is an estimate based on figures known
to the OSC at the time this report was written. The OSC does not necessarily
receive specific figures on final payments made to any contractor(s). Other
financial data, which the OSC must rely upon, may not be entirely up-to-date.
The cost accounting provided in this report does not necessarily represent an
exact monetary figure which the government may include in any claim for
cost recovery.
VI. DISPOSITION OF WASTES
• Using the waste disposal matrix below, list the wastestreams identified, and
note the medium and quantity affected. For each wastestream, indicate the
planned or actual disposition (e.g., containment, treatment, or disposal). See
Exhibit 2 on page 17 for more information on recording site wastes.
• Abbreviations may be used in the matrix and clarified in the text of the
POLREP. Keep each individual wastestream separate. The matrix should be
cumulative: add incremental figures to data noted in any previous POLREP.
If a wastestream was removed off site after being contained, delete the
information entered for that wastestream from the containment category and
add it to the disposal category. Containment and disposal should not both be
denoted for the same wastestream. See Exhibit 2 on page 17 for more
information.
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MODEL FINAL POLREP
Example:
Wastestream
Base neutral
solids
Acids
Medium
Solid
wastes
Liquid
wastes
Quantity
450 cu yd
5, 000 gal
Containment -
Migration
Control
Treatment
Landfilled
Recycled
Disposal
Chemical Management
Fort Wayne, IN
Everclear Products
Camden, Nf
See Exhibit 3, the POLREP Review Checklist, on the next page.
29
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POLREP REVIEW CHECKLIST
EXHIBIT 3. POLREP REVIEW CHECKLIST
The following checklist has been developed to help OSCs ensure that all
POLREPs are completed correctly. Though the four types of POLREPs
(initial, progress, special, and final) are similar in format, each requires
information specific to it. POLREPs should not include subjective judgments,
draw conclusions which are not fact-based, express unsubstantiated opinions,
or discuss the legality of actions or events. The items marked with an
asterisk (*) are common to all POLREPs.
The completed POLREP has:
Provided the necessary administrative information:
• Dates*
- today's date*
- start date*
- demobilization date
- completion date
Name of the person sending the POLREP*
Names of the persons to whom the report is sent*
Site name*
POLREP number*
Site identification number*
Delivery Order (D.O.) number*
ERNS/CERCLIS numbers*
NPL status*
Response authority*
State notification*
Described the incident thoroughly by including:
• Incident category
• Site description
- coordinates
- location
- acreage
- ownership
- past and present site activities
• Details of the incident or release
- date
- reasons, causes, PRPs
30
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POLREP REVIEW CHECKLIST
EXHIBIT 3. POLREP REVIEW CHECKLIST (Continued)
The completed POLREP has (continued):
Detailed the results of the preliminary assessment/site inspection:
• Contaminants, if known
• Quantity (e.g., number of drums, gallons)
• Nature of the threat
Indicated the status of the Action Memorandum:*
• Approval date, if applicable
• Approval date of ceiling increase and/or exemption, if
applicable
Described the planned and/or completed response activities (as
detailed in the Action Memorandum):*
• Enforcement activities
• State and/or other agency involvement
• Information on the amount and types of wastes which were
contained, treated, and/or removed from the site
• Results achieved
Discussed community relations actions, including planned activities.
Identified problem areas.*
Provided detailed, current cost information for the site:*
• Project ceiling
• Total cost to date
• Percent remaining
Provided accurate, consistent data on site wastes:*
Type/medium
Quantity
Containment/migration control
Treatment
Disposal
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SECTION II
OSC REPORT GUIDANCE
OSC Reports are concise and comprehensive documents that best summarize the removal
activities at a site, the effectiveness of those activities, and the resources committed. OSC
Reports present discussions of removal site problems, views on improvements, or cautions
which need to be shared with the National Response Team (NRT), Regional Response
Team (RRT), and other OSCs. OSC Reports are used by Headquarters and Regional
management to observe the implementation of Superfund regulations and policies in the
field. OSC Reports are available to the public and other agencies for information purposes.
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OSC REPORTS
OSC REPORTS
Purpose
An OSC Report provides a written summary of a removal activity, recording the
situation as it developed, the actions taken, their effectiveness, the resources
committed, and the problems encountered. OSC recommendations are summarized.
The OSC Report is the most concise and comprehensive document pertaining to a
particular site. When completed and distributed according to requirements of the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP), the OSC
Report can serve as the primary vehicle for conveying important information on
technologies used and lessons learned at a site to other OSCs and to Superfund
managers.
Section 300.165 of the NCP requires that within one year of completion of removal
activities at a site, the OSC submit a complete report of the removal activity. EPA
expects, however, that OSC Reports will be written as soon as practicable. Each
OSC Report must follow the standard model discussed in this guidance to ensure
compliance with NCP requirements and consistent reporting procedures.
While the NCP does not specifically require an OSC Report for a PRP-lead site,
preparation of one is common in many Regions. The title of the report may differ
across the Regions, but its general format and content are similar to those of an OSC
Report. The Administrative Order often stipulates that the PRP prepare a Final
Report upon completion of a response. Even if the Order does not specifically
require it, OSCs should encourage the PRP to prepare a Final Report, using the
same format as that required for a Fund-lead removal (excluding inappropriate
sections). It is recommended that OSCs overseeing/monitoring the PRP response
review and approve the Final Report before it is distributed. Final Reports at PRP-
lead sites are important sources of information for historical and research purposes.
The emphasis of the Superfund program is on cross-program coordination,
communication, and integration of expertise and resources to achieve risk reduction
and site cleanup quickly and efficiently. Preparation and distribution of OSC
Reports or Final Reports for both Fund-lead and PRP-lead removal activities will aid
in sharing valuable information across the Regions.
Users and Uses of OSC Reports
OSC Reports serve an important function in the Superfund program. The National
Response Team (NRT) and Regional Response Teams (RRTs) use OSC Reports for
transferring information on technologies used and lessons learned at sites throughout
the national response system, and for developing training programs for OSCs.
Regional Counsel, Department of Justice attorneys, and Regional cost recovery staff
use OSC Reports as a convenient summary of the history of a removal activity when
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OSC REPORTS
EXHIBIT 4. OSC REPORT USAGE
Users of OSC
Reports
Uses of OSC Reports
Information Important
to Users
On-Scene Coordinators
and Regional Program
Management
As a reference tool for questions
on similar site conditions and
activities, and as a historical record
of the removal. To fill out
CERCLIS Removal Information
Forms (CRIFs).
Incident description and details of
removal activities. Chronology of
events. Contaminants and threats.
Treatment or disposal approaches
used or pursued.
Regional Cost Recovery
and Regional Counsel
Staff
Department of Justice
As a historical record of the
removal activity and the results
achieved to support cost recovery.
Incident description and details of
removal activities. Chronology of
events. Treatment or disposal
approaches used or pursued. Results
achieved. Rationale for changes to
scope of work.
Headquarters (EPA)
Program Management
As a tool to evaluate program
policies, guidance, regulations, and
operations. As a reference tool for
responding to inquiries from the
public, Congress, EPA's Inspector
General, and the General
Accounting Office (GAO).
Difficulties encountered.
Recommendations.
Regional Response
Teams
As an advisory or informational
tool. For cross-transfer of
technology between EPA and
USCG.
Treatment or disposal approaches
used or pursued. Impact of incident
on natural resources at the site.
National Response Team
For conveying lessons learned and
developing training efforts for
OSCs.
Effectiveness of the removal and
coordination efforts. Difficulties
encountered. Recommendations.
Local Communities/
Media
As a historical record, for research
and public interest.
Incident description and details of
removal activities, including treatment
or disposal approaches used or
pursued. Results achieved. Rationale
for changes to scope of work.
Potentially Responsible
Parties
As a historical record to prepare
legal defense and as a source for
evidence in legal proceedings.
Incident descriptions and details of
removal activities. Attachments to the
report (maps, correspondence,
pictorial evidence). Treatment or
disposal approaches used or pursued.
Results achieved and costs incurred.
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OSC REPORTS
prosecuting a cost recovery case. Superfund program managers, focusing primarily
on difficulties encountered at sites and on the recommendations of OSCs, use OSC
Reports to evaluate program policies and regulations and to make appropriate
adjustments. Exhibit 4 summarizes the primary uses of OSC Reports, and the
information within OSC Reports that is important to the users.
The value and usefulness of OSC Reports is directly related to their completeness,
quality, and timely distribution. OSCs should be aware of the important role they
serve as preparers of OSC Reports, and ensure that OSC Reports conform to the
guidelines. OSC Reports that do not adequately address all of the information
requirements may result in delayed recognition of technological innovations; more
complex, costly, and time-consuming cost recovery efforts; and extra work searching
for missing data. Ensuring that the information needs of OSC Report users are met
will maximize the value and usefulness of these documents to the Superfund
program.
Timeliness of Preparation
Section 300.165 of the NCP requires OSCs to prepare and submit OSC Reports to
the RRTs within one year from the completion of the removal activity [1], However,
OSC Reports should be completed and submitted as soon as is practicable. For
removals of short duration (i.e., lasting less than 30 days), preparation of OSC
Reports should begin as soon as possible and availability should be within six months
of the date of completion of the removal action.9 By preparing and submitting the
reports in a timely manner, OSCs can facilitate the transfer of current information
to benefit other OSCs and the Superfund program.
Preparation of OSC Reports should be initiated at the onset of the removal action. This strategy will
make it easier to meet the required submission deadline, and contribute to orderly and early report
preparation.
Format and Information Requirements
In compliance with section 300.165 of the NCP, OSC Reports are to strictly follow
the format outlined below, and should briefly cover all of the topics listed. The use
The Preamble to the NCP, Section 300.165 states: "For removals of short duration (e.g., lasting less than
30 days), OSC reports should be available within six months of completion of the removal action
because there is less to report."
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OSC REPORTS
of a uniform and familiar format by all ten Regions will make accessing information
from any OSC Report easier for all users. Because detailed information regarding
day-to-day events at a site may be found in the site file, do not attempt to include or
duplicate all of this information in the OSC Report, but rather summarize and refer
to it. The OSC Report should contain only information listed in the format provided.
References should be made to supplemental documents which may, if necessary, be
placed in an addendum to the Report.
OSC Reports are to contain only factual information concerning the site.
Specifically, in describing the effectiveness of removal activities and in listing the
difficulties encountered, do not make subjective judgments, draw conclusions which
are not fact-based, or discuss the legality of actions or events. Rather, allow readers
to decide for themselves. For example, rather than saying that the cleanup
contractor did a great job, say that the contractor arrived on site with all the proper
equipment and with personnel ready to work; or, rather than saying that the
contractor's performance was unsatisfactory, say that the contractor took three weeks
to obtain the necessary equipment. Presenting the information as objective
statements of fact will minimize any possible adverse effects on cost recovery efforts,
and will indicate to Superfund managers issues that require investigation, evaluation,
or communication to others.
There is no minimum or maximum length requirement for OSC Reports, but they
should be as concise as possible. OSC Reports for relatively routine and low cost
removal activities, such as the removal of a few drums or the building of a fence,
should be especially brief, unless particular attention needs to be brought to any site-
specific issue. For more complex and costly removal activities, especially those
involving communication and coordination among numerous agencies or the use of
an innovative or alternative technology, or where significant natural resource damage
has occurred, OSC Reports should include the level of detail needed to ensure that
other OSCs and the removal personnel will profit from the lessons learned.
In meeting all reporting requirements for OSC Reports, pay particular attention to
the Difficulties Encountered and Recommendations sections, which are valuable to
the national response system. Because they are the focus of OSC Report reviews by
program managers, OSCs' constructive recommendations are most likely to benefit
the Superfund program.
Remember to address all of the outlined information requirements. If an item or
issue is not relevant to the removal conducted, indicate this fact so that the reader
does not make assumptions about why the information is missing.
Exhibit 5 presents the standard outline for OSC Reports.
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OSC REPORTS
EXHIBIT 5. OUTLINE OF AN OSC REPORT
Title Page*
Executive Summary*
I. Summary of Events
A. Site Conditions and Background
1. Initial situation
2. Location of hazardous substance(s)
3. Cause of release or discharge
4. Efforts to obtain response by responsible parties
B. Organization of the Response
C. Injury/Possible Injury to Natural Resources
1. Content and time of notice to natural resource trustees
2. Trustee damage assessment and restoration activities
D. Chronological Narrative of Response Actions
1. Threat abatement actions taken
2. Treatment/disposal/alternative technology approaches
pursued
3. Public information and community relations activities
E. Resources Committed
II. Effectiveness of Removal Actions
A. Actions Taken by PRPs
B. Actions Taken by State and Local Forces
C. Actions Taken by Federal Agencies and Special Teams
D. Actions Taken by Contractors, Private Groups, and Volunteers
III. Difficulties Encountered
A. Items that Affected the Response
B. Issues of Intergovernmental Coordination
C. Difficulties Interpreting, Complying with, or Implementing
Policies and Regulations
IV. Recommendations
A. Means to Prevent a Recurrence of the Discharge or Release
B. Means to Improve Response Actions
C. Proposals for Changes in Regulations and Response Plans
* Suggested for inclusion.
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OSC REPORTS
OSC Report Attachments
The OSC Report should be short and concise. While POLREPs, correspondence,
and Action Memoranda are valuable sources of information, the unnecessary
inclusion of these documents increases the bulk of the OSC Report. To the extent
permissible by Regional practices and procedures, avoid attaching supplemental
documents to the OSC Report. Instead, include a list of these additional documents
and where they can be found (e.g., site file). Where it is necessary to include other
documents, they should be placed in an addendum to the Report.
OSC Report Distribution
As of the date of this document, section 300.165 of the NCP requires OSCs to submit
OSC Reports to the RRTs within one year of the completion of the removal
activity[l]. At the same time, copies of OSC Reports are to be sent to the Secretary
of the NRT and to the Director of ERD.
OSC Reports must be submitted to RRTs, the Secretary of the NRT, and the Director of ERD.
This minimum distribution increases the awareness of program managers and
members of the national response system to issues of concern to OSCs, and prepares
ERD to respond to inquiries from the public, Congress, the Office of the Inspector
General, and the General Accounting Office about actions taken at sites. The
reports should be organized, indexed, and stored in the Region for easy access.
When information about a removal action is of special signiflcance to other OSCs and to the removal
program, use the Cleanup Information (CLU-IN) Bulletin Board System at (301) 589-8366 (formerly
OSWER BBS) for wide and expeditious distribution of this special information, even before the OSC
Report becomes available.
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OSC REPORTS
OSC REPORT REVIEW PROCEDURES
Thorough review procedures will eliminate typographical errors and organizational problems, avoid
unnecessary delays in report distribution, and ensure that the OSC Report addresses the reporting
criteria outlined in the NCP and this document.
Each Region should allot time for adequate review of the OSC Report and adhere
to a consistent review process. In addition to a thorough proofreading for
typographical errors and other minor problems, OSCs should refer to the checklist
provided in Exhibit 10 on page 61 to ensure that the OSC Report meets NCP
requirements. When possible, the OSC Report should be reviewed by people not
involved in the preparation of the document, to provide a fresh perspective and to
help the OSC evaluate its usefulness to other OSCs and Superfund program
managers.
The OSC should give the Office of Regional Counsel an opportunity to review the
OSC Report before it is finalized and distributed. This is especially crucial if the
details of the Report relate to:
• Pending or anticipated civil or criminal litigation
• Possible responsibility of the United States or an agency of the United States
for a release or discharge
A model OSC Report that addresses the regulatory requirements for OSC Reports
is presented on pages 43 to 60. Examples are provided.
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MODEL OSC REPORT
Title Page
[Regional Letterhead]
FEDERAL ON-SCENE COORDINATOR'S REPORT
[Site, NPL Status]
[Location]
[Project Dates]
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
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MODEL OSC REPORT
Executive Summary
Although not required in the NCP, a one-page summary of the response activity is strongly
recommended.
The Executive Summary allows readers to quickly familiarize themselves with the
contents of the report, and provides a place to emphasize trie most significant aspects
of the situation and the actions taken. The contents of the executive summary of a
removal activity should therefore focus on identifying the site and presenting a brief
description of the major aspects of the situation, the mitigative actions, and the
disposal method.
Exhibit 6 on the following page presents the standard outline and example
information for an executive summary of removal activity.
I. SUMMARY OF EVENTS
Ensure that the information contained throughout this section is consistent with the Action
Memorandum, or that deviations in the scope of the response are justified. Where appropriate,
information on the site conditions and background may be abstracted from the Action Memorandum.
A. Site Conditions and Background
010 1. Initial situation
Describe the current and prior uses of the site and the nature
and type of each facility which operated on the site. Indicate
the NPL status of the site.
Example: The Whimperton Wire Company site, listed on the NPL, is an
abandoned steel manufacturing facility which contained
thousands of drums of unknown liquids and solids, bulk
quantities of acids, laboratory chemicals, and other regulated
hazardous materials which were scattered throughout the
approximately 200-acre site. The site was used primarily to
produce steel wire and cable for more than 75 years; in recent
years it has also operated as a polymer reclamation facility, a
10 A ® denotes information which should be included in CERCLIS.
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MODEL OSC REPORT
EXHIBIT 6. EXECUTIVE SUMMARY OF THE REMOVAL ACTIVITY
SITE: Whimperton Wire Company Site
LOCATION: Bobsled, New Jersey
PROJECT DATES: 10/26/91 - 9/1/93
INCIDENT DESCRIPTION: The site, listed on the NPL, is an abandoned steel
manufacturing facility encompassing approximately 200 acres. The company
produced steel wire and cable on site for more than 75 years, with other industrial
activities added in recent years. Soil, ground water and surface water, including the
Delaware River and Sander's Creek, were threatened by more than 2,000
deteriorating drums of unknown liquids and solids, unstable acid baths, compressed
gas cylinders, chemical laboratories, and loose asbestos in on-site buildings. A
laboratory fire on October 17, 1991, in a building housing acids, gases, poisons, and
other hazardous substances alerted the Response and Prevention Branch to the
potential hazards at the site, and accelerated its efforts to begin a CERCLA
§104(a) response. No PRP was found financially viable to undertake a full cleanup
of the site.
ACTIONS: EPA and the technical assistance contractor conducted an
extensive assessment between October 14,1991, and October 27,1991. The ERRS
contractor mobilized on November 2, 1991, and began site preparation and
stabilization. A command post was established in an on-site building, site security
was enhanced, and warning signs were posted along the site perimeter. Bulking
and staging of materials began in November 1991. Laboratory chemicals were
removed from all buildings and catwalk areas, and then separated and labeled. All
drums were staged and tested for compatibility and color coded into 16 separate
wastestreams. Vandalism of equipment and fires on site brought work to a
standstill and made added site security necessary. The ERRS contractor
temporarily demobilized in April 1992 and remobilized in October 1992. Since
November 1992, the ERRS contractor shipped 1,200 overpacked drums for
disposal; 15 roll-offs containing 55-gallon drums of waste acid for disposal; 5,000
gallons of acids for recycling; and 60 gas cylinders were either reclaimed by their
manufacturers or treated on site. Site security continued to be provided until the
remedial personnel procured the services of a contractor.
(Signature')
Joan Smith, OSC
U.S. EPA, Region II
New York, NY
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MODEL OSC REPORT
warehouse facility, and an equipment storage facility for a
construction company.
9 • Describe the site's physical location in terms of exact street
address, coordinates (latitude/longitude), surrounding land use,
local population size, and distance(s) to sensitive populations,
habitats, and natural resources.
Example: The site is located in Bobsled Township, Hunterdon County,
New Jersey (38° 37' 57" N, 75° 35' 06" W) and is bounded
by the Delaware River to the north, Sanders Creek to the east,
and the residential community of Bobsled to the south and
west. Bobsled Township comprises approximately 400
residences with a population of about 1,450.
9 • Briefly describe the history of the incident or release, including
the date of the incident, the type of incident that occurred, and
the facts concerning the discovery of the release.
Example: In September 1991, the Chief of the Removal Action Branch
requested that the Response and Prevention Branch conduct
a preliminary assessment at the Whimperton Wire Company
site. The request was based in part on requests from local
officials, including the Bobsled Township Fire Marshal, who
had expressed concerns that acutely toxic and hazardous
substances were uncontained and uncontrolled at this site and
presented a potential time-critical threat to the local
population.
9 • List the known materials on site and the quantities.
Example: The assessment revealed the presence of more than 2,000
drums, several acids baths, approximately 60 compressed gas
cylinders, several chemical laboratories, and numerous
buildings with asbestos-contaminated pipes. Materials on site
included acids, bases, halogenated and non-halogenated
solvents, heavy metals, oxidizers, and waste oils. Lead
contamination in soil as high as 7,000ppm was also found.
• Describe the threat to human health or the environment posed
by the incident or release. (Refer to information contained in
section III of the Action Memorandum.)
2. Location of hazardous substance(s)
• Specify areas of concern on site, indicating water sources that
were contaminated or threatened. (Note: A map or diagram of
the site may assist in indicating areas of concern on the site. If
a site map is used, include it as the next page in the report.)
Example: Drums, bulk quantities of acids, laboratory chemicals, and
other hazardous materials were located throughout the site.
Particular areas of concern included: four on-site buildings
(#15, #20, #32, #35) containing laboratory chemicals, one
of which was involved in afire on October 17, 1991; a sulfuric
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MODEL OSC REPORT
acid tank and a phosphoric acid tank, both with poor
structural integrity and containing over 2,000 gallons of acid;
and an area of surface soil along the site's southwest property
border that had lead levels as high as 7,000ppm. In addition,
the migration of contamination from the site may have
affected ground water in the area, and contaminated run-off
from the site has entered the Delaware River and Sanders
Creek. The extent of impact has not been determined; results
of sample analyses are pending.
3. Cause of the release or discharge
• Describe the facts concerning the cause or threat of the release
or discharge, and the activities that may have contributed to or
were contributing to the incident.
Example: The on-site fire on October 17, 1991, in building #15 alerted
Response and Prevention Branch personnel to the potential
hazards at the site, and accelerated the completion of the
preliminary assessment and the start of removal activity.
4. Efforts to locate and obtain response by responsible parties
• Describe the actions taken to locate responsible or potentially
responsible parties and to obtain from them a prompt and
proper response.
Example: No financially viable PRP was found that was willing to
undertake a full cleanup. Therefore, no orders pursuant to
Section 106 of CERCLA, as amended by SARA, were issued.
One PRP, Zimmer Container Corp., was issued a Notice
Letter regarding the surface wastes in and around its area of
operations. Zimmer was willing to clean up the portion of
surface wastes that it generated during its lease operations. On
October 29, 1991, Notice Letters pursuant to Section 107(a) of
CERCLA, as amended by SARA, were sent to 19 PRPs,
identified by EPA, inviting participation in the removal activity.
Six replies were received by EPA, but only one PRP,
Whimperton Wire Corp., accepted any responsibility or liability
for hazardous substances at the Whimperton Site. Seven
letters were returned to sender or indicated that the party had
moved and left no forwarding address. Nine potentially
responsible parties were identified by EPA as potentially viable
and were issued Section 104(e) Request for Information letters
on December 18, 1991.
B. Organization of the Response
• For multiple phase removal activities, summarize the activities planned
and conducted during each phase.
Example: The site was divided into four quadrants and the removal activity was
conducted in two phases. Phase 1 was directed towards immediate site
stabilization measures. Phase 2 consisted of bulking, transporting, and
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MODEL OSC REPORT
disposing of materials staged in Phase 1. Exhibit xyz outlines the
agencies or parties which provided response, assessment, or disposal
assistance, and the action(s) each took or the role(s) each served.
Indicate in tabular form the name of specific Federal, State, and/or
local government agencies or parties, and contractors, that provided
response or assessment assistance or disposal. Briefly describe the
actions of these groups, or their roles in protecting public health and
the environment.
Exhibit 7 on the following page shows a sample table for outlining the
organization of the response. The description in this example is
incomplete, but indicates the format and the types of information to
include.
C. Inlury or Possible Injury to Natural Resources
1. Content and time of notice to natural resource trustees
• State the details of any notification provided to natural resource
trustees relating injury or possible injury to natural resources,
and the date of notification.
Example: On October 25, 1991, the OSC sent written notification to the
New Jersey Department of Environmental Protection (NJDEP)
of the potential ground water contamination on site and the
potential surface water contamination of the Delaware River
and Sander's Creek from site run-off.
2. Trustee damage assessment and restoration activities
• Describe damage assessment activities and efforts to replace or
restore damaged natural resources undertaken by Federal or
State trustees.
Example: The NJDEP hired a contractor, Water Resources, Inc., to
determine the extent of contamination to the Delaware River
and Sander's Creek. Water Resources collected sediment and
water samples from both bodies of water along the perimeter
of the site. Results of analyses were not available at the time
of this writing.
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MODEL OSC REPORT
EXHIBIT 7. ORGANIZATION OF RESPONSE
Agencies or
Parties Involved
Contact
Description of
Participation
U.S. EPA - Region 2
Woodbridge Avenue
Raritan Depot, Building 209
Edison, NJ 08837
(212) 434-8079
Joan Smith
Greg Norman
Courtney Barnes
Federal OSC responsible for overall
response oversight and success.
Assisted with project oversight and
control.
U.S. EPA - Region 2
CERCLA Removal Enforcement
Section
One Federal Plaza
New York, NY 65478
(212) 545-7878
Peter Simpson
Issued written Notice Letters and
Request for Information Letters to
potentially responsible parties.
New Jersey Department of
Environmental Protection
312 Westview Lane
Trenton, NJ 08967
(201) 346-7111
Becky Steinberg
Mark Slupek
Provided historical information on the
site and responded to fires at the site.
EnviroTEK, Inc.
Technical Assistance Team
9797 Main Street
Arlington, VA 22209
(703) 986-3452
Ralph Zapatos
Paul George
Provided the OSC with technical
assistance, administrative support,
sampling, photo and site
documentation, site safety, and draft
report preparation.
HazWaste Cleanup Corporation
34 Quincy Street
Philadelphia, PA 57894
(215) 248-2234
Irving Niles
Lois West
Provided personnel and equipment
necessary for removal and conducted
the cleanup. Coordinated shipment
and disposal of materials.
Bobsled Township
Fire Department
Bobsled, NJ 90808
(201) 345-7896
James Steele
Provided renewable air during site
assessment and water for site
decontamination. Also responded to
fires on site.
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MODEL OSC REPORT
Information for the following section should be presented in a concise, narrative summary.
D. Chronological Narrative of Removal Activities
1. Threat abatement actions taken
® • Indicate whether the response was conducted under the
authority of CERCLA, RCRA, or OPA.
Example: This response was conducted under the authority of CERCLA
Section 204(a).
• Describe chronologically the details of any threat abatement
actions taken.
Example: EPA Region 2, supported by the technical assistance
contractor, conducted an extensive site assessment between
October 14, 1991, and October 27, 7991. EPA mobilized the
Emergency and Rapid Response Services (ERRS) contractor,
HazWaste Cleanup Corp., on November 2, 1991. Between that
time and November 12, 1991, the scope of work was focused
on general site preparation, which included establishing a
command post area and enhancing site security. Site security
was enhanced by installing chains and locks on all site
entrance gates, barbed wire in areas where the site fence was
broken or in weakened condition, and warning signs along the
entire site perimeter, as well as in some interior areas of the
site where physical hazards were present.
Building #22 was designated as the laboratory chemical and
drum staging area for the site, and a decontamination trailer
was set up as a support zone for the building. All easy access
points were secured by the installation of doors with locks,
chicken wire, and barbed wire, and by boarding up broken
windows with plywood...
[Description of the site preparation might continue for a few
paragraphs.]
Most of the chemical bulking and staging phase (i.e., Phase 1)
of the project was conducted between November 1991 and
March 1992. It began with the removal of laboratory
chemicals from each building, beginning in Quadrant III and
progressing to Quadrants II, I, and IV, respectively ...
[The remainder of the section describes the rest of the removal
activity in a similar fashion.]
If this is an early-action site, mention the combined site
assessment; if remedial activities are planned or ongoing, report
them here.
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MODEL OSC REPORT
2. Treatment, disposal, or alternative technology approaches
pursued
• State the technology approaches tested and implemented for
on-site treatment or disposal of materials.
Example: The diverse wastestreams, materials, and debris on site were
incinerated, recycled, chemically treated, or disposed of in
RCRA-approved landfills.
• State the materials and quantities disposed of, the method of
disposal, and the location of the disposal facility. Present this
information in tabular form.
Exhibit 8 on the following page provides the tabular format for materials and
their disposition.
• Provide concise but detailed descriptions of available,
innovative, or emerging alternative technologies successfully
used in treating or disposing of materials on site.
Example: No on-site treatment, disposal, or alternative technologies were
pursued at this site.
[Examples of alternative technologies would include in situ
vitrification, biodegradation, solidification, high pressure
solvent extraction, etc.]
3. Public information and community relations activities
• Describe the actions taken to inform the community of the
release and the removal activities completed to solicit or
respond to community concerns.
Example: Prior to mobilization of the cleanup contractor, the OSC
prepared a community relations plan. An initial meeting was
held on October 26, 1991, at the Bobsled Township Mayor's
Office to notify public officials of the proposed site removal
activities and to discuss public notification procedures in the
event of an incident during cleanup operations. Following a
press conference, the local officials and representatives of the
EPA Office of External Affairs performed a door-to-door tour
of residences located along the perimeter of the site to explain
EPA's ongoing removal activities and to answer any questions
concerning local involvement. The OSC also met with local
fire and police officials to discuss general cleanup activities
and contingency plans. Fact sheets were issued to all Bobsled
residents outlining the site hazards andmitigative actions being
conducted.
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MODEL OSC REPORT
EXHIBIT 8. MATERIALS AND DISPOSITION
Material
Crushed empty
drums and
debris
Solid waste
containing
heavy metals
Cyanide and
corrosive
liquid waste
Halogenated
liquid organics
Phosphoric and
sulfuric acids
Elemental
mercury
Amount
5 roll-offs
at 30 cu yd
each
75 55-gal drums,
15 roll-offs
at 30 cu yd
each
120 55-gal
drums
59 55-gal
drums
5,000 gal
liquid
2.8 Ib
Method Location
Landfill Chemical
Management
Fort Wayne, IN
Landfill Chemical
Management
Emelle, AL
Chemical SinoChem, Inc.
treatment Detroit, MI
Incineration Rally Environmental
Services, Inc.
Austin, TX
Recycle Everclear Products
Camden, NJ
Recycle Polymer-Science, Inc.
Harvey, MO
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MODEL OSC REPORT
E. Resources Committed
• Summarize the estimated total project costs, highlighting the categories
below. (Note: Use the Removal Cost Management System [RCMS]
to determine the estimated total project costs.) [5]
Extramural costs:
Regional removal allowance costs (or total cleanup contractor
costs), including costs for Emergency and Rapid Response
Services (ERRS), Regional ERRS, subcontractors, prequalified
vendors and other site-specific contracts, letter contracts, order
services, notices to proceed, and interagency agreements (lAGs)
with other Federal agencies
Technical Assistance Team (TAT)/Superfund Technical
Assessment and Response Team (START) costs
Contract Laboratory Program (CLP) costs
Response Engineering and Analytical Contract (REAC) costs
EPA Intramural costs:
(Note: See the Removal Cost Management Manual for the
formula for calculating intramural direct and indirect costs [6].
Contact the Regional Financial Officer for direct and indirect
cost rates to be used in the formula.)
• Provide the removal project ceiling from the Action Memorandum for
comparison.
• The cost information may be supplemented according to individual
Regional cost tracking, provided that the required information is
complete.
Exhibit 9 on the following page shows an estimated total cost summary for a sample
removal project.
With the expected increase in the number of non-time-critical removal
activities under the early action initiative, there will be a consequent increase
in the number of cost recovery actions subject to the removal Statute of
Limitations (SOL). The SOL for removal activities is three years from a
removal completion, unless remedial activity is initiated within three years of
the completed removal activity. The need for accurate, timely, and complete
cost documentation and reporting of work performed is extremely important
[3]-
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MODEL OSC REPORT
EXHIBIT 9. REMOVAL PROJECT ESTIMATED TOTAL COST SUMMARY
Extramural Costs:
Total Cleanup Contractor Costs
Total TAT/START Costs
Total CLP Costs
Total REAC Costs
EXTRAMURAL SUBTOTAL
Intramural Costs:
EPA Direct Costs
EPA Indirect Costs
INTRAMURAL SUBTOTAL
ESTIMATED TOTAL PROJECT COSTS
PROJECT CEILING
$2,835,444
168,353
0
0
$3,003,797
$200,000
299,569
$499,569
$3,503,366
$3,600,000
II.
EFFECTIVENESS OF REMOVAL ACTIVITIES
The evaluation of the removal action should be objective. The criteria include: timeliness of response,
level of preparedness to respond, appropriateness of actions, whether safety procedures were followed,
whether the PRP contributed to the removal action, and the form and quantity of that contribution.
Only facts should be noted.
A. Actions Taken bv PRPs
Indicate whether the PRP(s) responded to any notice letter(s) and how
cooperative they were in providing information to assist with the
removal.
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MODEL OSC REPORT
Example: Only one PRP, Zimmer Container Corporation, was financially viable
or willing to undertake any cleanup. Zimmer was issued a Notice
Letter on September 19, 1991, regarding the hazardous substances,
debris, and solid waste in and around its area of operations. Zimmer
agreed to clean up the portion of surf ace wastes that it had generated
during its lease operations.
• If the PRP did any portion of the site work, indicate whether the PRP
responded to an administrative order.
Example: Under an Administrative Order, Zimmer Container Corporation
conducted cleanup of its portion of wastes on site.
• For work performed by the PRP(s), cite instances indicating whether
the PRP(s) or their representatives took adequate health and safety
measures, and conformed to the site safety plan.
• Indicate whether the performance of the PRP conflicted with
performance expectations.
Example: Zimmer Container Corporation cleaned up and removed most of the
surface wastes identified by EPA; however, the potential soil
contamination resulting from its welding, spraying, and refurbishing
operations of box trailers is unknown at this time and was not
addressed during the removal activity. This potential contamination
will be addressed in future action by the remedial personnel.
B. Actions by State and Local Agencies
• Indicate whether any role was played or assistance provided by State
or local agencies in the removal. Describe actions of State and local
agencies as first responders, in the preliminary assessment of the site,
and/or in community relations which were either valuable or a
hindrance to the removal activity.
Example: The NJDEP provided historical information on the site during the
assessment phase of the removal. The NJDEP also responded to
incidents involving fires at the site to aid in mitigation actions.
The Bobsled Township Fire Department provided a renewable air
supply during the site assessment. The Fire Department also
coordinated with the ERRS contractor to respond to several site fires
caused by vandals and, for a nominal fee, provided water for the site
decontamination trailer.
The New Jersey State Police (NJSP) responded to several incidents
involving fires and vandalism at the site. However, the OSC's first
request to the NJSP for support was denied because assistance was not
requested through the Bobsled Township Police Department's mutual
aid agreement.
• Indicate whether the State made arrangements for post-removal site
control.
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MODEL OSC REPORT
C. Actions Taken by Federal Agencies and Special Teams
• Indicate whether any role was played or assistance provided by the
U.S. Coast Guard, the Agency for Toxic Substances and Disease
Registry (ATSDR), the Federal Emergency Management Agency
(FEMA), or any other agency during the removal. Describe technical
assistance provided by these agencies.
Example: Upon discovery of vandalized equipment on site, the OSC contacted the
Federal Bureau of Investigation (FBI). The FBI declined to investigate
the matter because of the uncertainty involved with the status of
ownership of the damaged equipment.
EPA's Office of the Inspector General (IG) provided an investigator at
the time of the discovery of the damaged equipment; however, the lack
of a Federal or State agency representative to investigate outside causes
of the vandalism hampered the IG investigation.
• Indicate any participation by the NRT, the RRT, or other teams during
the removal. Describe any assistance they provided in coordinating
with Federal, State, and local agencies and other interested parties,
and in planning the removal activity.
Example: The USCG National Strike Force denied the OSC's request for a site
visit and assistance in the final removal of hazardous materials.
D. Actions Taken by Contractors. Private Groups, and Volunteers
• Review the delivery orders and work performed by the ERRS
contractor (or other cleanup contractor). Indicate whether all
personnel, materials, and equipment were provided as required by the
contract and delivery orders, and whether they were provided within
acceptable time frames.
Example: The EPA ERRS contractor, HazWaste Cleanup Corp., conducted the
cleanup of the site. In addition to performing wastestream staging and
bulking and drum sampling, ERRS coordinated the shipment and
disposal of the materials. Through the ERRS contractor, site security
and utilities support were also provided. The ERRS contractor
provided an on-site mobile laboratory, as well as equipment and
personnel to conduct the field operations.
• Indicate whether health and safety protocols were observed, and
whether applicable safety and environmental laws and regulations were
followed in storage, transportation, treatment, and disposal of wastes.
Cite any violations.
Example: All health and safety protocols and safety and environmental laws were
followed during this removal activity.
• Indicate whether tasks assigned to the technical assistance contractor
were completed in a timely and effective manner.
Example: The EPA technical assistance contractor, EnviroTEK, Inc., provided
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MODEL OSC REPORT
timety assistance in the preliminary assessment of all site buildings, the
development and maintenance of the site safety plan, documentation
of on-site activities, air quality monitoring of all work areas, and
coordination of the disposal and reclamation of abandoned cylinders
and acids.
Describe instances where work performed by volunteers was valuable
to the success of the removal activity or where their presence hindered
site activities.
Example: Volunteers from a local Boy Scout troop assisted in the distribution of
fact sheets to local Bobsled residents.
ill. DIFFICULTIES ENCOUNTERED
Most removal activities encounter some problems. When difficulties arise on site, especially those
involving intergovernmental coordination or compliance with policies and regulations, communicating
these difficulties program-wide will help avoid them at other sites or facilitate their solutions should
they occur.
In this part of the OSC Report, list the items that affected the response, giving careful attention to
issues of intergovernmental communication and coordination, and regulatory and policy interpretation
and compliance. Give each type of difficulty a short title for easy reference.
A. Items That Affected the Response
• Evaluate the efficiency of the removal activity. List technical, naturally
occurring, and uncontrollable items that adversely affected the removal
activity.
Example: Incineration: The high cost of transportation of hazardous waste to an
off-site incinerator (because of community resistance to mobilization of
an on-site incinerator) and the delays due to work stoppage by the
hazardous waste haulers union greatly increased the total removal cost.
Vandalism: Fires and vandalism occurred on several occasions at the
site; some of these incidents hindered site actions and endangered EPA
personnel, cleanup contractors, and the local residents. Because of the
large size of the site, it was difficult to limit access. Site security
through ERRS subcontractors was unsuccessful in most incidents
because security guards could not maintain a constant watch on
perimeter areas. Local authorities were not able to curtail trespassing
and illegal dumping on site and did not have the resources to contend
with these problems.
Union Actions: On March 8, 1992, the Heavy Equipment Operators
and Laborers Union formed a picket line across the site entrance and
disrupted site work for several days. Subcontractors, such as the
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MODEL OSC REPORT
hazardous waste haulers and the site sanitation subcontractor, honored
this line. Even after site work was resumed, physical harassment
against the ERRS contractor personnel hindered site progress on several
occasions. The local community exhibited no concern over the
disruption of removal activities.
Delays: On March 30, 1992, all personnel were demobilized from the
site after vandals caused extensive damage to the heavy equipment and
other operational equipment at the site. Work was delayed until
October 1992, when the cooperation of the Department of Justice and
the U.S. Marshal's Office was obtained in order to provide safer and
more secure working conditions.
B. Issues of Intergovernmental Coordination
• Evaluate communication and coordination efforts among Federal,
State, and local parties and the effect of the efforts on the removal
activity. Cite examples that hindered or disrupted the coordination of
a smooth removal activity.
Example: EPA's ability to request assistance from State and Federal agencies
outside of the RRT framework should be addressed. The role of an
OSC during an emergency response or removal activity is unknown to
those State and Federal agencies that do not have participating
members on the RRT. In addition, the OSC did not know the extent
of assistance which can be requested or provided from other agencies,
as was the case with the FBI.
C. Difficulties Interpreting. Complying With, or Implementing Policies and
Regulations
• Indicate those policies and regulations that in any way affected the
efficient conduct of the removal activity and how they affected the
removal activity.
Example: Threats to health and safety of personnel: EPA lacks formal guidance
or policy on health and safety issues unrelated to standard OSHA or
EPA requirements for hazardous waste activities. The site-specific
health and safety plan did not address the acts of violence perpetrated
by vandals and arsonists. Without such guidance, the OSC can use
only his best judgment as to whether removal activities can safety
continue.
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MODEL OSC REPORT
IV. RECOMMENDATIONS
This part of the OSC Report provides the opportunity for OSCs to share the benefits of their site
experiences. As site managers and implementors of EPA's operating policies and regulations, OSCs are
most qualified to provide valuable feedback from a field perspective to removal program managers on
the effectiveness of these policies and regulations. Through their experience and expertise conducting
removals, OSCs can assist other OSCs and developers of policy by communicating their successes in
conducting particular types of removal actions, using innovative technologies, and by providing
recommendations for the prevention of future discharges and releases.
To ensure the value of OSC Reports to the removal program, all the issues presented below should be
carefully addressed. Give all recommendations a short title for easy reference.
A. Means to Prevent a Recurrence of the Discharge or Release
• Examine the cause of the incident and determine, if possible, what
action(s) could have prevented it. Provide specific recommendations
for how EPA or other Federal or State agencies could act to prevent
similar occurrences.
Example: Routine audits: Audits should be conducted routinely for companies
that are producers or users of large quantities of hazardous substances,
and these companies should be required to routinely dispose of wastes
produced and materials no longer used. Companies that fall into these
categories could be required to carry and maintain liability insurance to
pay for potential environmental damage or threats that result from
operations.
B. Means to Improve Removal Activities
• Provide recommendations from section III of the OSC Report to
address the difficulties encountered during the removal activity. Focus
on improvements to intra-program coordination and on issues that
could have broad application within, or implications for, the Superfund
program.
Example: On-site incineration: The mobilization of an on-site incinerator for the
destruction of wastes would have reduced transportation costs
associated with off-site disposal.
Site security: EPA's effort to provide continuous site security at
hazardous waste sites where local and State authorities are unable to
supplement or support such activities needs to be examined.
• Highlight what actions went well during the removal and provide
specific recommendations so that other OSCs can take advantage of
these experiences.
Example: Multiple OSCs: Using several OSCs, with one lead OSC, to oversee
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MODEL OSC REPORT
different phases of the removal activities can improve complex removal
activities. Because of the numerous tasks undertaken for this action,
more than two OSCs were used at different phases of the removal
activity, which greatly aided in contractor monitoring and in planning
initiatives.
C. Recommendations for New Policy or Regulations, and Changes in
Current Regulations and Response Plans
• Indicate those regulations or policies that hinder rather than promote
the efficient, timely, and safe completion of removal activities. State
the manner(s) in which they hinder operations, and provide
recommendations for their revision.
Example: 1. DOJ support: There should be expedited methods for obtaining
Department of Justice response to criminal activities against EPA
employees or its contractors.
2. MOUorlAG: A Memorandum of Understanding and Interagency
Agreement should be developed between the EPA and the U.S.
Marshal's Office to immediately address threats or potential threats to
EPA employees from outside parties interfering with an approved
Federal removal activity.
3. Guidance: EPA should develop guidance or policy pertaining to the
protection of its employees and contractors under its direction, and
incorporate it by reference in the Federal Regional Contingency Plan.
It is also suggested that a legal determination of Federal property be
made known to OSCs in order to distinguish the threshold for FBI or
other agency involvement.
Exhibit 10 presents an OSC Report Review Checklist which can be used to ensure
that all information requirements have been addressed and that the report is error-
free.
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OSC REPORT REVIEW CHECKLIST
EXHIBIT 10. OSC REPORT REVIEW CHECKLIST
The following checklist has been developed to help ensure that all OSC Reports are
complete. A comprehensive list of topics for inclusion in OSC Reports is provided.
OSCs should compare OSC Reports to the checklist and add their own procedures
if they desire. The OSC Report should not include subjective judgments, draw
conclusions which are not fact-based, express unsubstantiated opinions, or discuss
the legality of actions or events.
The OSC Report has:
Provided an executive summary of the response action (optional).
Described the primary aspects of the site conditions and site background
succinctly and accurately, and includes:
• Initial situation, background, site location, coordinates, and NPL
status
• Location of hazardous substances and areas of concern on site
• Cause of the release or discharge
• Efforts to obtain response by responsible parties (section I.A).
Outlined the organization of the response, indicating agencies, parties,
and contractors that provided assistance, and their action(s) or role(s)
(section I.B).
Indicated the content and date of any notice to natural resource trustees
about injury or possible injury to natural resources (section I.C).
Indicated Federal and State trustee damage assessment activities and
efforts to replace or restore damaged natural resources (section I.C).
Indicated the response authority and described in a chronological
narrative the details of threat abatement actions taken (section I.D).
Stated the technologic approaches tested and implemented, and concisely
described innovative or emerging alternative technologies successfully
used (section I.D).
Stated the materials and quantities disposed of, the method(s) of
disposal, and the location of the disposal facility/facilities (section I.D).
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OSC REPORT REVIEW CHECKLIST
EXHIBIT 10. OSC REPORT REVIEW CHECKLIST (Continued)
The OSC Report has (continued):
Described the public information and community relations activities
performed (section I.D).
Summarized the estimated total project costs and provided the removal
project ceiling for comparison (section I.E).
Provided an objective evaluation of the effectiveness of removal activities,
including:
• Actions taken by PRPs (section II.A)
• Actions taken by State and local agencies (section II.B)
• Actions taken by Federal agencies and special teams (section II.C)
• Actions taken by contractors, private groups, and volunteers
(section II.D).
Listed the difficulties encountered during the response activity, including:
• Technical, naturally occurring, and uncontrollable items that affected
the response (section III.A)
• Issues of intergovernmental coordination (section III.B)
• Difficulties interpreting, complying with, or implementing policies
and regulations (section III.C).
Provided recommendations on means to prevent a recurrence of the
discharge or release (section IV.A).
Provided recommendations on means to improve response activities
(section IV.B).
Provided recommendations or proposals for changes in regulations and
response plans (section IV.C).
Provided a reference list of related or supplemental documents (in lieu
of attachments).
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APPENDIX A. MODEL COMBINED INITIAL AND FINAL POLREP
U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION REPORT
Model Combined Initial and Final POLREP
I. HEADING Example.-
Date: November 4, 1992
® Subject: Elmhurst Dump, Caroline County, New Jersey
® From: Joan Smith, OSC, U.S. EPA, Region 2, Response and Prevention Branch
To: Robert Watson, Director, ERD
Janet Cohen, Response and Operations Branch Chief, Region 2
James Stacks, NJDEP
Local Emergency Planning Committee
POLREP No.: 1 and Final
II. BACKGROUND Example:
® Site No.: Q6
Delivery Order No.: 1234-56-78
Response Authority: CERCLA, § I04(a)
ERNS No.: 30580
® NPL Status: Non-NPL
® CERCLIS No.: N/A
State Notification: - NJDEP notified
Action Memorandum Status: Action Memorandum being prepared
® Start Date: November 2, 1992
Demobilization Date: November 3,1992 .
® Completion Date: November 4,1992
III. SITE INFORMATION
® A. Incident Category
• Indicate the appropriate CERCLA incident category for the site from
the following list:
Active Production Facility
Inactive Production Facility
Active Waste Management Facility
Inactive Waste Management Facility
Midnight Dump
Transportation-Related
Other
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Example: CERCLA incident category: Midnight Dump
© B. Site Description
1. Site description
• Briefly describe the site setting, including coordinates (latitude/
longitude), location (city, county, state), acreage, and ownership.
Example: On November 1, 1992, four sealed but badly damaged boxes
were found by a local resident in a deserted field near
Elmhurst, Caroline County, NJ (39° 49' 57" N, 77° 38' 19"
W). The boxes were soggy, the labels had almost completely
peeled off, and poison symbols were barely visible. Present
ownership of this 40-acre field was under dispute and the last
legal owner could not be immediately located. Well-
established trails through the unsecured field indicated routine
use by residents. The NJDEP, due to the potentially
hazardous contents of the boxes, requested EPA assistance.
• Describe the area (e.g., residential, urban, commercial) and
estimate the threatened population (as identified in the
Preliminary Assessment).
Example: The field where the boxes were found is not cultivated, but the
surrounding fields are irrigated with water from a nearby
stream. The field is in a very rural area of Caroline County,
with a population of fewer than 250 people within a one-mile
radius. Two miles downstream of the site is a small town
(Elmhurst) with a population of approximately 5,000 people.
• Discuss past and present site activities.
Example: The site was formerly a cornfield, and is currently not farmed
due to legal disputes over ownership.
2. Description of threat
• Describe the threat to human health or the environment posed
by the site. If the threat is the result of a single incident or
release, describe the incident or release, including the date and
what ensued.
Example: The barely visible symbols on the labels of the boxes appeared
to indicate that the boxes contained arsenic trioxide - a highly
toxic carcinogen. This posed a potential serious contact/
inhalation threat to passersby. Rain could destroy the
containers, wash the contents into the soil, and/or
contaminate the nearby stream.
C. Preliminary Assessment Results
• Briefly discuss the results of the preliminary assessment, if any.
Example: The boxes appeared to contain the original material. No leakage was
initially observed, but the boxes were deteriorated.
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IV. RESPONSE INFORMATION
® A. Situation
1. Current situation
Summarize the current situation at the site and the status of the
ongoing removal activity, including information pertaining to
site conditions, weather (if pertinent), media activity, and other
relevant factors.
Example: Heavy rain caused muddy conditions which hampered access
to the site. The OSC arrived on scene at 1300 hours on
November 1 and determined the location of the boxes to be SO
feet from the swollen stream flowing nearby. On closer
inspection, the OSC found no other boxes or drums anywhere
near the four identified boxes.
Technical assistance contractor personnel arrived on scene at
1530 hours on November 1 to assist the OSC with the
response activity by collecting soil and water samples for
analysis, and by performing air monitoring.
On verifying the contents of the boxes, the OSC mobilized the
ERRS contractor who arrived on the scene at 1700 hours on
November 1.
2. Removal activity to date
Describe what removal activities have already been initiated,
including preparation of the Action Memorandum, whether the
OSC invoked the $50K response authority, any actual site
mobilization and the actions taken, and any community
relations activities.
Example: The area was immediately fenced off by the ERRS contractor
and warning signs were posted. The boxes were overpacked
and staged within the secured area. After the boxes had
partially dried out, and on closer scrutiny, the contents of the
boxes appeared intact. The OSC with the help of the technical
assistance contractor identified the name of the manufacturer
on the labels, and contacted the manufacturer - Metchem,
Inc., of Trenton, NJ.
Discuss State and local agency involvement, including any
request for EPA assistance; any State or local agency
cooperation in assessing the incident and threats; any "first
responder" or other actions taken by State or other agencies to
protect public health and the environment; and whether State
or other agency personnel remain at the site.
Example: The NJDEP contacted the EPA Duty Officer, and a
representative was present on site from the outset.
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3. Enforcement
Indicate whether EPA or State enforcement actions have been
initiated.
Example: The manufacturer of the arsenic, Metchem, Inc. was contacted
on November 2 and representatives arrived on site on
November 3, 1992, at 1400 hours.
B. Planned Removal Activities
Discuss the removal activity as outlined in the Action Memorandum.
Example: Because of the imminent threat to public health and the environment
posed by the highly toxic and hazardous contents of the damaged boxes,
this site met the criteria of a CERCLA emergency response. Using the
$50K authority, the OSC initiated an immediate response.
The manufacturer will assume responsibility of the secured containers
of hazardous materials. The contents will be repackaged at their factory
for reuse.
C. Next Steps
Describe plans for ongoing removal activity, including waste analysis,
containment, and cleanup; enforcement; planned meetings with local
or Regional environmental or enforcement agencies; and community
relations activities.
Example: Sample analysis results showed no contamination of the soil or
water.
Discuss the status of the OSC Report and the expected completion
date. If applicable, indicate any future site activity (e.g., PRP,
remedial, or State).
Example: The OSC Report is under preparation and is expected to be completed
by November 30, 1992. No further Federal response activities are
anticipated.
D. Key issues
• Identify any problem areas.
• State how the objectives set forth in the Action Memorandum were
achieved through the removal activity. Specifically address any wastes
remaining on site, including those which are contained. Document
how threats to human health and the environment have been reduced
or eliminated.
Example: An Action Memorandum is being prepared. Prompt and immediate
Federal action eliminated a potentially hazardous situation.
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V. COST INFORMATION
Provide detailed final cost information for the site. Below is an example of
cost information that OSCs should provide. Individual Regions should also
note ceilings for ERRS, TAT/START, or other line items if such ceilings are
maintained. To the extent practicable, all expenditures relevant to the site
should be noted in the POLREP. Cost information should be as detailed and
complete as possible.
Example: Cost To Date
ERRS Contractor $ 3,010-
lAGs N/A
Letter Contracts N/A
Extramural Cleanup Contractor Costs 3,010
TAT/START Contractor Costs 1,850
CLP Analytical Services N/A
REAC N/A
Intramural Direct Costs (HQ, Regions, ERT) 1,900
Intramural Indirect Costs 2,150
Total Intramural Costs 4,050
TOTAL $ 8.910
0 Project Ceiling $ 50,000
® Percent of Project Funds Remaining 82.2%
Include the following statement in all final POLREPs:
The above accounting of expenditures is an estimate based on figures known
to the OSC at the time this report was written. The OSC does not necessarily
receive specific figures on final payments made to any contractor(s). Other
financial data which the OSC must rely upon may not be entirely up-to-date.
The cost accounting provided in this report does not necessarily represent an
exact monetary figure which the government may include in any claim for
cost recovery.
VI. DISPOSITION OF WASTES
Using the waste disposal matrix below, list the wastestreams identified, and
note the medium and quantity. For each wastestream, indicate the planned
or actual disposition (e.g., containment, treatment, disposal). See Exhibit 2
on page 17 for more information on recording site wastes.
Abbreviations may be used in the matrix and clarified in the text of the
POLREP. Keep each individual wastestream separate. Containment and
disposal should not both be denoted for the same wastestream. See Exhibit
2 on page 17 for more information.
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Example:
Wastestream
Heavy metal
(arsenic)
Medium
Solid,
contained
in boxes
Quantity
4 boxes,
each 20 Ib
Containment -
Migration
Control
Boxes secured,
area fenced off
Treatment
None
Disposal
Collected by
Metchem, Inc.,
NJ, for reuse
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11
APPENDIX B. REFERENCES
Statutes and Regulations
[1] The National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 55
FR 8666, 40 CFR Part 300, (March 8, 1990)
[2] The Comprehensive Environmental Response, Compensation, and Liability Act of
1980, as amended, 42 U.S.C. sections 9601-9675
Guidance
[3] OSWER Directive 9203.1-05, Volumes 1 - 5, "Superfund Accelerated Cleanup Model
- Interim Guidance," (December 1992)
[4] OSWER Directive 9360.3-01, "Superfund Removal Procedures: Action Memorandum
Guidance," EPA/540/P-90/004 (December 1990)
[5] Removal Cost Management System User's Guide, Version 3.2 (June 1989)
[6] OSWER Directive 9360.0-02B, "Removal Cost Management Manual," (April 1988)
11 Bracketed numbers appear throughout the text and correspond to the references listed in this appendix.
These references maybe consulted for additional information on specific topics affecting the preparation
and content of POLREPs and OSC Reports.
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APPENDIX C. KEY WORDS INDEX
Action Memorandum (AM) iii, 4-7, 10, 11, 13-15, 19, 21, 22,
25, 26, 31, 40, 44, 46, 53, 63, 65, 66, 69
Agency for Toxic Substances and Disease Registry 56
Clean Water Act 3
Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA) 3, 11, 12, 14, 19, 21, 25, 26,
45, 47, 49, 50, 63, 64, 66, 69
Comprehensive Environmental Response, Compensation, and
Liability Information System (CERCLIS) ii, 10, 11, 19, 25, 30, 36, 44, 63
Contract Laboratory Program (CLP) 23, 28, 53, 54, 67
Emergency Response Notification System (ERNS) 10, 11, 19, 25, 30, 63
Environmental Response Team (ERT) 23, 28, 67
Federal Emergency Management Agency 56
Incident Category 10, 12, 30, 63, 64
Interagency Agreement (IAG) 23, 28, 53, 60, 67
Letter Contracts 23, 28, 53, 67
National Oil and Hazardous Substances Pollution
Contingency Plan (NCP) iv, 3, 35, 37, 40, 41, 69
National Priorities List (NPL) 10, 11, 19, 25, 27, 30, 43, 44, 45, 63
National Response Team (NRT) 3, 5, 33, 35, 36, 40, 56
Oil Pollution Act of 1990 3, 50
Potentially Responsible Party (PRP) 1, 3, 5-8, 14, 21, 26, 27, 30
35, 36, 39, 45, 47, 54, 55, 62, 66
Preliminary Assessment (PA) 6, 10, 11-14, 26, 31, 46, 47, 55, 57, 64
Regional Response Team (RRT) 3-5, 33, 35, 36, 40, 56, 58
Removal Cost Management System (RCMS) 15, 22, 27, 53, 69
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Response Engineering Analytical Contract (REAC) 23, 28, 53, 54, 67
Resource Conservation Recovery Act (RCRA) 3, 17, 50, 51
Statute of Limitations 5, 26, 53
Strategic Planning and Management System (SPMS) 5
Superfund Amendments and Reauthorization Act of 1986 (SARA) 3, 47
Superfund Comprehensive Accomplishments Plan (SCAP) 5
United States Coast Guard (USCG) 4, 36, 56
U s Environmental Protection Agency
Region 5, Library (PL-12.n .mFto
77 West Jackson Boulevard, 12th MO
Chicago, IL 60604-3590
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