United States
Environmental Protection
Agency
Office of Solid Waste
and Emergency
Response (OS-510W)
EPA520-F-92-002
August 1992
SEPA Superfund Information Repositories
and Administrative Records
What is Superfund?
i
In 1980, Congress passed the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA Superfund). This Act empowered the U.-S. Environmental Protection Agency (EPA) and the
States to respond to threats of uncontrolled hazardous waste. CERCLA also established a Trust Fund which
EPA could use in emergency situations and at sites where long term remedies are required. The Superfund
process involves site investigations, studies of the feasibility of different technologies, and actual cleanups.
Using enforcement authorities, EPA can compel potentially responsible parties (PRPs) to clean up the site
or pay for the costs. When the PRPs are unwilling or unable to conduct or pay for the cleanup, money from
the Trust Fund may be used. <
INTRODUCTION
Citizens play a central role in the Superfund pro-
gram. EPA considers public input when making site
cleanup decisions, particularly the Agency's selec-
tion of the remedy for the site. This fact sheet
discusses two features of EPA's Superfund Com-
munity Relations Program: the information reposi-
tory and the administrative record.
1. What is an information repository?
An information repository is where current informa-
tion, technical reports, and reference materials re-
garding a Superfund site are stored. EPA or the State
establishes die repository in the community at the
beginning of site studies to provide the public with
easily-accessible information. Repositories are es-
tablished for all sites where cleanup activities are
expected to last for more than 45 days. Typical
repository locations include public libraries or mu-
nicipal offices.
2. What is an administrative record?
The administrative record is a specialized file con-
taining the information which was used to select the
remedy at a Superfund site. Administrative records
contain technical reports specific to each Superfund
site, and key technical and administrative guidance
for cleanups. An administrative record must be
available at every site to encourage public participa-
tion in the remedy selection process. EPA also
maintains an identical copy of the administrative
record at the EPA Regional Office or a State office.
Although agencies may establish more than one
information repository in a community, EPA or the
State typically establishes only one local adminis-
trative record. Since the information repository is
opened first, quite often the administrative record
will be at the same location so that the public can
access both.
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3. When does EPA establish the
information repository?
EPA prefers to establish information repositories
as early in the site cleanup process as possible,
before technical activity begins. The earlier the
repository is established, the greater the opportu-
nity for the public to access information on the
activities at the site. There will be some occasions,
however, when the governmental agencies must
move quickly to address site conditions. Setting up
the information repository may follow those tech-
nical activities.
4. What does the information repository
contain?
The repository contains general information about
EPA, Superfund, and the enforcement program. In
addition, EPA includes fact sheets, maps and other
materials about a particular Superfund site in the
repository and the Community Relations Coordi-
nator (CRC) submits items of interest, such as
newspaper clippings about the site and community
reactions. A description of common documents
can be found on pages 4 through 8 of this fact sheet.
In many situations, the repository contains the
administrative record and its documents as they are
being compiled. Administrative record materials
will be clearly marked.
5. Who maintains the information
repository?
EPA or the State agency leading the cleanup efforts
at the site establishes the information repository.
Generally, the EPA or State CRC takes the lead in
ensuring that appropriate documents are included
in the repository. A local information repository
librarian, who is typically a public librarian, public
school administrator, or local government clerk,
then maintains the repository. This person ensures
that documents are filed promptly in the appropri-
ate part of the repository and maintains the organi-
zation of the repository. The librarian will keep an
index of all information in the administrative record.
EPA or the State, however, and not local librarians,
bear responsibility and liability for the contents of
information repositories and administrative records.
INFORMATION REPOSITORY
WITH ADMINISTRATIVE RECORD
General (e.g. Fact Sheets)
Plus Site-Specific (e.g.
News Clippings, Community
Relations Plan, and some
technical reports)
Superfund Materials
information Repository
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LIBRARY
Community libraries or other public buildings may house information repository,
the administrative record, both. Librarians will choose among these options
according to the best fit for their facility space and other factors.
6. Can I request that additional
information be included in the
information repository?
EPA encourages public input on the contents of the
information repository. Requests for information
to be added to the repository should be addressed
to the CRC, whose name and address is available
in the information repository.
7. Where is the information repository
located?
Information repositories are usually located near
the site in a public building, such as a public library
or school. The primary consideration in choosing
the location is accessibility. Whenever possible,
repositories are located in buildings with photo-
copying facilities, and are accessible for people
with physical handicaps. In some cases, two re-
positories are established for a site. A public
library branch near the site, for example, may be an
appropriate location for the repository. In addi-
tion, the main library, which is typically located in
the center of the community and therefore more
accessible to a larger number of citizens, would be
a second appropriate location.
8. How can I use the information
repository?
Repository information can help members of the
public understand site activities and develop com-
ments on certain documents during public com-
ment periods. Documents subject to public review
include the Remedial Investigation/Feasibility
Study (RI/FS) reports, the Proposed Remedial Ac-
tion Plan, and the Record of Decision (ROD).
These documents are discussed later in this fact
sheet.
The repository also contains technical site informa-
tion, such as sampling analysis reports, and infor-
mation on cleanup alternatives considered at the
site. This information allows members of the
public to understand site conditions and make sub-
stantive comments on the proposed remedial alter-
native, for example. In addition, the information
repository may contain information on the roles
and responsibilities of EPA, the State, or respon-
sible parties.
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9. How does the Information repository
relate to other public involvement
activities regarding the site?
The information repository represents the primary
source of written public information about the site. It
is not, however, the only source. General and site-
specific fact sheets and public meetings also provide
opportunities for citizens to gather information about
the site. In addition, public meetings and other
informal meetings between EPA staff and area resi-
dents provide an opportunity for citizens to commu-
nicate directly with representatives from EPA as well
as State representatives, and other parties engaged in
the site activity. A site Community Relations Plan
(CRP), which is included in the information reposi-
tory, documents Agency efforts to provide opportu-
nities for public involvement. The CRP also docu-
ments and provides a public record of community
concerns about the site.
10. To whom do I address questions
about the material in the information
repository?
The information repository librarian is usually the
most accessible person to whom questions about the
organization and use of the repository may be ad-
dressed. The CRC also is available to help interpret
reports or other relevant issues. Their names, ad-
dresses, and telephone numbers are listed in the CRP
and in fact sheets available in the information reposi-
tory.
STANDARD INFORMATION
REPOSITORY DOCUMENTS
Although the contents of each information reposi-
tory vary depending on the site and phase of site
cleanup, certain documents are found in most reposi-
tories. This section briefly describes some, but
certainly not all the documents that could be in-
cluded.
General Superfund Information
Most information repositories contain introductory
background information on the Superfund program.
This information may include fact sheets and bro-
chures on various aspects of the Superfund program
and the cleanup process. General program informa-
tion provides a context within which the public may
consider site-specific information and explains the
overall Superfund goals.
CERCLA
Copies of CERCLA and RCRA
Information repositories typically contain copies of
the Comprehensive Environmental Response, Com-
pensation, and Liability Act (CERCLA), and the
Resource Conservation and Recovery Act (RCRA).
CERCLA provides the statutory authority for the
Superfund cleanup and enforcement programs,
RCRA is a comprehensive waste management law,
CERCLA and RCRA are complementary laws that
establish waste management and cleanup programs
for past and present disposal practices. These stat-
utes are generally included in repositories to provide
the public with a framework for understanding the
activities at the site.
The National Oil and Hazardous Substances
Pollution Contingency Plan (NCP)
The NCP is the central regulation of Superfund, By
setting forth guidelines and specific procedures that
must be followed, it acts as a blueprint for conducting
Superfund cleanups.
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Hazard Ranking System (HRS) Information
The Hazard Ranking System (HRS) is a method
used by EPA to evaluate potential risks to health
and the environment by the release of hazardous
substances at a site. The HRS produces a site score
(a number between 1 and 100) that is the primary
factor in deciding if a hazardous waste site should
be placed on the National Priorities List (NPL).
The NPL is a list of the most serious uncontrolled
or abandoned hazardous waste sites identified for
possible long-term cleanup, using money from the
Superfund. HRS information includes site investi-
gation reports and site soil, water, and air sampling
data and analysis.
Press Releases
Press releases that are relevant to the
site or the Superfund Program are typi-
cally included in information repositories. Press
releases provide a record of activity at the site, and
may document community concerns and EPA or
State responses.
Cooperative Agreement
In some cases, the State may be conducting cleanup
work at the site. When the State assumes lead
responsibility for cleaning up a Superfund site, the
State's responsibilities are set forth in a Coopera-
tive Agreement with EPA.
EPA
Technical Assistance Grants (TAG)
Brochure and Citizens Handbook
The TAG program is designed to provide grants of
up to $50,000 to eligible groups living near
Superfund sites. The recipient of a TAG award may
hire a Technical Advisor, such as an epidemiolo-
gist, toxicologist, or hydrologist. The Advisor
interprets technical data on the nature of hazards at
the site and the recommended alternatives for
cleanup. Only one TAG is available per Superfund
site. A brochure briefly outlining the TAG program
and announcing the availability of the grant is
included in the repository. Detailed information
about the program and information on how to apply
for a TAG are contained in the Citizens' Handbook.
The Handbook contains detailed information on
the TAG program requirements and instructions on
organizing a community to apply for a grant. For a
copy of the Handbook, or additional information
about the program, contact the CRC.
STANDARD ADMINISTRATIVE
RECORD DOCUMENTS
The administrative record evolves over time, and
documents are added corresponding to site activi-
ties. These documents will be used as the basis for
selecting the removal action or the site remedy.
Until the final decision document is signed, there is
no complete administrative record for a site. The
"administrative record file" refers to the documents
as they are being compiled. The record file must be
made available at or near the site except for emer-
gency removals that last fewer than 30 days. This
section briefly describes some, but certainly not all
the documents that could be included.
Community Relations Plan (CRP)
The Community Relations Plan (CRP) is a docu-
ment prepared by EPA or the State, which describes
the site background; identifies community con-
cerns regarding the site; sets forth a strategy for
addressing those concerns; and identifies opportu-
nities for public involvement regarding the sites.
The CRP also contains names and addresses of
EPA and State contacts. The key planning informa-
tion in the CRP is derived from interviews with
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members of the local community. CRPs are pre-
pared for all Superfund actions lasting longer than
120 days.
Administrative Order on Consent (AOC)
An AOC is a legal agreement between EPA and
Potentially Responsible Parties (PRPs) in which
the PRPs agree to perform or pay for some or all of
the cost of a removal or an RI/FS. AOCs are issued
by EPA, and may also be signed by the State.
Engineering Evaluation/Cost Analysis
(EE/CA)
If a period of at least six months exists before a
removal begins, an EE/CA will be done. The EE/
CA analyzes removal alternatives and their costs
for a site.
Action Memo
An Action Memo provides a concise written record
of the decision selecting a removal action. It
describes the site's history, current activities, and
health and environmental threats. It outlines the
proposed actions and costs, and documents ap-
proval of the removal. An addendum to the Action
Memo sets forth the enforcement strategy. Be-
cause Action Memos are the primary decision
documents to select and authorize removal actions,
they are the critical component of the administra-
tive record. When an Action Memo is signed, the
administrative record for a removal closes.
Remedial Investigation/Feasibility Study
(RI/FS) Work Plan
The RI/FS is a series of investigative and analytical
studies that are usually performed at the same time
to:
• Gather the data necessary to determine the
type and extent of contamination at the site
• Establish goals for cleaning up the site
• Identify and screen cleanup alternatives
• Analyze the technology and costs of the
cleanup alternatives.
The RI/FS work plan sets forth detailed procedures
for conducting the RI/FS, including how and where
sampling will be conducted, treatment alternatives
to be explored, and methodologies for conducting
site studies.
Health Assessment
The health assessment is a study required by
CERCLA that determines the potential risks to
human health posed by the site. Health assessments
are conducted by personnel from the Agency for
Toxic Substances and Disease Registry (ATSDR).
They review environmental sampling data and other
site-related information. The health assessment
determines whether any current or potential health
threat exists. It does this by evaluating the com-
pleteness of the information and considering the
types of contamination present, pathways the con-
tamination might take, and the extent to which the
site area is used by humans and animals.
Risk Assessment
Risk assessments are evaluations performed as part
of the RI/FS to estimate the damage a Superfund
site could cause to health or the environment. As
such, risk assessments help determine the levels of
chemicals that can remain on the site, as well as the
need for action. They also provide a basis for
comparing different cleanup methods.
STOP
Site Sampling Data and Results
Soil, air, and water at Superfund sites may be
sampled and tested for contamination at various
stages of the cleanup process. Information on
sampling activity is typically included in the ad-
ministrative record file and enables the public to
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f
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better understand the nature and extent of contami-
nation at the site. These reports are often highly
technical; other documents such as the RI and FS
reports generally will summarize the information
and provide an analysis of the results.
Remedial Investigation (RI) Report
The RI report includes information on physical and
chemical monitoring studies, the nature and extent
of contamination, potential routes of exposure, and
a baseline assessment of the potential risks to
human health posed by the site. The RI report
generally begins with a brief synopsis of the whole
report.
Feasibility Study (FS) Report
The FS report contains a detailed analysis of the
feasible cleanup alternatives, and supports the
selection of the appropriate cleanup alternative.
The FS report evaluates each of the proposed cleanup
alternatives against criteria such as short and long
term effectiveness, implementability, cost, compli-
ance with State cleanup requirements, and the
effectiveness of the alternative in maintaining pro-
tection of human health and the environment. The
FS report also compares the alternatives being
considered.
Proposed Remedial Action Plan
The Proposed Remedial Action Plan (Proposed
Plan) describes all the cleanup technologies con-
sidered for the site by EPA and identifies the
alternative(s) proposed by EPA to be the best
cleanup method. The Proposed Plan provides the
public with a comparison of cleanup alternatives
considered feasible by EPA.
Public Meeting Transcript and Summaries
CERCLA requires EPA to provide the opportunity
for a public meeting to discuss the site cleanup plan,
and to make a transcript of the meeting available to
the public. At sites where there is a high level of
community interest, public meetings may be held
more frequently to provide the community and
EPA with the opportunity to exchange information
on the site. For these meetings, when no transcript
of the meeting is taken, a meeting summary will be
placed in the information repository. Public meet-
ings also provide the opportunity for members of
the community to express their concerns regarding
the site, and for EPA to respond to those concerns.
Transcripts of public meetings are included in the
information repository as a means of documenting
public involvement in the site cleanup process.
Responsiveness Summary
Responsiveness summaries outline oral and writ-
ten public comments received by EPA during pub-
lic comment periods on key documents, such as the
Proposed Plan, and contain EPA's response to
these comments. As such, they document commu-
nity concerns regarding the cleanup for EPA deci-
sion-makers and are a key part of the Agency's
record of decision.
Record of Decision (ROD)
The ROD is EPA's official decision document that
explains which cleanup alternatives will be used at
Superfund sites. The ROD is based on information
and technical analysis generated during the RI/FS.
The ROD also takes into consideration public com-
ments and community concerns.
U.S. Environmental Protection Agency
I2th F
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POST-DECISION DOCUMENTS
The administrative record normally closes when
the ROD is signed. On occasion, new information
is received on site conditions or the technology
selected, which requires the ROD to be amended or
an explanation of significant differences to be writ-
ten. These materials may be added to the adminis-
trative record file and kept in a post-decisional file.
More documents pertaining to the site will be
generated after the close of the administrative record.
The following documents will be part of the infor-
mation repository:
Remedial Design (RD)
The RD specifies detailed, site-specific procedures
and schedules for conducting the actual remedial
work at the site. The RD may be prepared by EPA,
the State, or the PRPs in cases where PRPs are
conducting site activities. The RD provides the
public with information on activities to be con-
ducted at the site and the schedule for completion of
those activities. After completion of the final
engineering design, a fact sheet will be placed in the
information repository. A public briefing will be
scheduled prior to the initiation of the remedial
action.
Remedial Action (RA)
The RA is the actual construction that follows the
remedial design of the selected cleanup alternative
at a Superfund site.
Consent Decree (CD)
A CD is a legal agreement between EPA, the PRPs,
and sometimes the State, whereby the PRPs con-
sent to perform or pay for all or part of the RD/RA.
The Consent Decree describes the actions for which
PRPs are responsible and is subject to a public
comment period. Consent Decrees are approved
and issued by U.S. District Court judges.
Unilateral Administrative Order (UAO)
A UAO is a legal document issued by EPA direct-
ing PRPs to perform the RD/RA. It sets forth the
liability of the parties for the cleanup, describes
actions to be taken, and subjects the recipients to
penalties and damages for noncompliance. UAOs
may be enforced in court.
United States
Environmental Protection
Agency (OS-510W)
Washington, DC 20460
Official Business
Penalty for Private Use
$300
First Class Mail
Postage and Fees Paid
EPA
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