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a convenient summary of the history of a removal
activity  when 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.

DISTRIBUTION  OF OSC  REPORTS

The NCP now requires that an OSC Report be
submitted to the RRT, the Secretary of the NRT,
and the Director  of the Emergency Response
Division (ERD) within one year of the completion
of the removal activity, or when requested by the
RRT.   EPA expects that OSC Reports will be
written as soon as practicable.  For removals of
short duration, OSC Reports should be submitted
within  six  months  of  the  completion of the
removal activity.

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, or possible responsibility of the United
 States or an agency of the United States  for  a
 release or discharge.
 INFORMATION REQUIREMENTS

 The OSC Report should contain only information
 listed in the format provided by NCP §300.165.
 References  should  be made  to  supplemental
 documents which may be placed in an addendum
 to the Report.  Regional practices on this vary.

 OSC  Reports   should  contain  only  factual
 information  concerning  the  site.    Subjective
 judgments and  conclusions which are not fact-
 based  should  be  avoided.    Presenting  the
 information  as  objective statements of fact will
 minimize  any possible adverse effects on cost
 recovery  efforts,  and  will still  indicate  to
 Superfund   managers  issues   that   require
 investigation, evaluation,  or communication to
 others.
Detailed information regarding day-to-day events
at a site should  not  be included  in  the  OSC
Report. However, it should include the level of
detail  needed  to  ensure  that  readers   will
understand  and profit from it.   In meeting all
reporting   requirements   for   OSC  Reports,
particular   attention  should  be  paid  to the
Difficulties Encountered  and Recommendations
sections.

OSC REPORT FORMAT

OSC Reports follow the format described in the
NCP.  If a section is not relevant to the removal
conducted,  that fact should be indicated. Call Gil
Laskowski  of ERD-RSCB at (703)  603-8719 for
information about a WordPerfect macro package
for preparing  OSC Reports.  The OSC Report
outline is provided in Table 1 on page 3.

FURTHER INFORMATION

For a copy of "Removal  Response Reporting:
POLREPs and OSC Reports" or any other volume
of the SRP manual, contact:

  National Technical Information Service
  5285 Port Royal Road
  Springfield, VA 22161
  Phone:  (703) 487-4650

EPA employees can order a copy by calling the
Superfund  Document Center at (703) 603-8917.
   Notice: The policies set out in this fact sheet
   are not final Agency action, but are intended
   solely as guidance.  They are not intended, nor
   can be 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 fact sheet,
   or to act at variance with the guidance, based
   on  an analysis of  site-specific circumstances.
   The Agency also reserves the right to change
   this guidance at any time without public notice.

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                              Table 1:   OSC Report Outline
Title Page (suggested)

Executive Summary  (suggested)

I      Summary of Events (including project dates and authority to conduct response)

       A.      Site Conditions and Background
               1.      Initial situation, including site location, coordinates, and NPL status
               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, Including State/Local Participation
       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

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