SIMM
oEPA
Protection
DIRECTIVE NUMBER: 9360.2-01 f '
Model Program for Removal Site File Management
APPROVAL DATE: July 1988
EFFECTIVE DATE: July 1988
ORIGINATING OFFICE:
(/FINAL
D DRAFT
STATUS:
T 1
[ 1
[ J
A- Pending OM3 approval
B- Pending AA-OSWER approval
C- For review &/or comment
D- la development or circulating
REFERENCE (other documents):
headquarters
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Wasnugton. OC 20460 ,.. . .. -.-
QSWER Directive initiation Request
Orldnatof Information
Name of Contact Person _ .MatfCooe [Office
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TimFields OS 200
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Teiepncre Coat
3. Title .: - - - .
Model Program for Removal SiteFile Management
«. Summary at Oiroctivo (inctudfi ontt $u«m«nt o« pyrposei
Provides a file structure for on-site file management and REgional file
maintenance for use by OSXC and Regional administrative support staff.
». ntyworoa Sup«rfuni, CEHCLA, SARA
U««cnv«i») I
No
I I Yes What directive (number, title)
5. Does it Supplement Previous OirtctiveW? r~\A ("""1
1 Iy1"- ' 'Yet What directive (number, we)
^ A-SgnedbyAA/OAA [ [ S - Sioned by OfBee Director | I C-forRe«ww 4 Comment [ | 0 - in Development
8. Document to b« distributed to States by Headquarters? I I Y«
TM« fl«qu«at M«*u OSWgf? Qlracttvaa Sy«t«n Format SUndarda.
9. Sgnatura of Lead Offica Directives Coordinator
Richard Hyde
Data
7/18/88
iO. Nama ana Title ol Approving Official "~~"~ iQate
Henry L. Longest II 7/18/88
£PA form 1315-17 (R«v. 5-47) Previous aeitions art oosotata.
OSWER OSWER OSWER O
VE DIRECTIVE DIRECTIVE DIRECTIVE
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OSWER Directive 9360.2-01
MODEL PROGRAM FOR
REMOVAL SITE FILE MANAGEMENT
July, 1988
Office of Solid Waste and Emergency Response
and the
Office of Administration and Resources Management
U.S. Environmental Protection Agency
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MODEL PROGRAM FOR REMOVAL SITE MANAGEMENT
OSWER Directive 9360.2-01
July 1988
Unites States Environmental Protection Agency
Office of Emergency and Remedial Response
Emergency Response Division
Washington D. C. 20460
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OSWER Directive 9360.2-01
NOTICE
Development of this document was funded, wholly or in part, by
the United States Environmental Protection Agency under contract
No. 68-01-7281 to American Management Systems, Inc. It has been
subjected to the Agency's review process and approved for publi-
cation as an EPA document.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. O.C. 20460
JUL (8
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT: Transmittal of OSWER'Directive 9360.2-01; Model Program for
Removal Site File Management
FROM: / J. Winston Porter
4^Assistant Administrate
TO: Regional Administrators
The Model Program for Site File Management is transmitted to you as
OSHER Directive 9360.2-01. This Model Program was developed with Input
from Regional removal program staff. The site file design focuses on
removal actions and provides added management support for On-Scene
Coordinators (OSCs) while providing national consistency 1n removal
site file management.
This model program for site file management provides a file structure
fdr on-site file management and Regional file maintenance for use by
On-Scene Coordinators (OSCs) and Regional administrative support staff.
Specifically, the guidance provides the minimum contents of a site
file kit for use by OSCs and Technical Assistance Team personnel and/or
administrative support staff when establishing a site file. Additionally,
on-site and Regional office removal file management procedures are
recommended as part of this guidance document.
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OSWER Directive 9360.2-01
TABLE OF CONTENTS
1. Overview ..;. 1
2. Site Rle Structure ., 3
3. Site Rle Kit . 8
4. Rle Management Processes 11
5. Supporting the Administrative Record 14
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OSWER-Direetive 9360.2-01
MODEL PROGRAM FOR
REMOVAL SITE FILE MANAGEMENT
1. Overview
Effective file management in the Superfund Emergency Removal
Program requires performance of several important functions, particularly:
Securing necessary file management supplies (e.g., site file kit)
Transporting file materials to the site
Setting up the site file
Completing appropriate documentation in a timely manner
Filing documentation in the site file
Distributing (copies of) appropriate documentation to the regional
office
Replenishing file management supplies
Periodically reviewing the site file (while action is on-going) for
completeness and accuracy
Determining whether site file documents belong in the administrative
record
Distributing (copies of) appropriate documentation to the administra-
tive record.
These functions have typically bean the responsibility of the On-Scene
Coordinator (OSC), with assistance from other EPA Regional staff, contractors
(e.g., TAT) and the USCG Strike Teams. It is critical that each Region clearly
assign responsibility for each of these QSC functions.
The Model Rle Management Program described in this document was
prepared to guide the OSCs, Regional administrative support staff, and other
responsible personnel in performance of good site records management. The
Model Program consists of four parts:
Site File Structure A model for classifying all the documentary
material generated in the course of a removal action.
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OSWER Directive 9360.2-01,
2
Site.Film Kit - A recommended kit containing items necessary to
support structured collection and storage of information at the site.
File Management Processes - A step-by-step review of the stages
of file management for a site. : -
Supporting the Administrative Record- A recommended approach
to ensuring that appropriate site files are placed in the administrative
record.
The remainder of this document presents more information on each of
these four areas.
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OSWER Directive 9360.2-01
3
2. Site File Structure
-*-* - i . A
One of the OSC's important responsibilities during a removal action is to
establish and maintain site files. These files include documentation of all
aspects of the removal '-- technical, contractual, and financial. Good
documentation is vital for proper management of the ongoing removal action
and subsequent cost recovery.
Individual Regions currently use varied site file structures. Some of the
variety stems from the different levels of complexity involved in removal
actions. The individuality of emergency response organizations in the
Regions, and of the OSCs within them, also contributes to the variety of site file
structures.
There are two important guiding principles for the site file structure:
Each Region should have a site file structure that can be used
consistently.
All site file structures in use in the Regions should include the same
minimum set of information.
The minimum set of information* to be included in all site file structures
consists of the following:
Chronology of events and decisions
Entry and exit of personnel and equipment
Contractor work planned/authorized and contractor work
accomplished
Contractor costs
Site conditions, such as weather
Cumulative intramural and extramural project costs.
* Removal Cost Management Manual. Chaptor 5, Exhibit 5-1.
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OSWER Directive 9360.2-01
4
This minimum set of information is generally documented using the following
forms:
;> OSC Log . .... ',..;.
>OLREPS
'. w - ' *
Site Entry/Exit Log
Hot Zone Entry/Exit Log
Work Reports
1900-55S
.Incident Obligation Log.
Since certain Regions already have site file structures that satisfy the
minimum requirements, we do not believe that all Regions should be required to
use the same detailed site file structure. However, each Region must ensure
that:
It adopts a comprehensive, workable site file structure
Its Regional OSCs use the structure consistently.
Exhibit 1 presents the model site file structure which meets the minimum
requirements outlined above and combines aspects of several Regional site file
structures currently in use. This model should be the basis for a file structure in
Regions which have not already developed a satisfactory file structure. The
model structure consists of five major groupings of documentation, each of
which contains a number of specific docurrent types, as follows:
(1) Operational documents are those used in general management of
the removal project. These documents are mainly type-written or computer-
generated and are generally on letter-size (8.5 by 11 inch) paper. Documents
in this category include:
POLREPS
\ \
Action Memos -
Site Safety Plan /
Contractor Workplans
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EXHIBIT 1
MODEL SITE FILE STRUCTURE
1.
2.
3.
4.
5.
roum
Operational
Documents
Legal
Documents
Financial
Documents
Public
Relations
Documents
Technical
Document.
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OSWER Directive 9360.2-01
Contractor Progress Reports
OSC Log Books
" Performance Summaries
: Performance Evaluation Reports
Notice Letters'
Section 106 Orders or Other Enforcement Orders
(2). Legal documents include those issued by a court of law as well
as other binding documents. These documents are mainly type-written and are
generally on letter-size (8.5 by n inch) or legal-size (8.5 by 14 inch) paper.
Examples of legal documents include:
Administrative Orders
Access Agreements
Warranty Deed
Release of Liability
Consent Agreement
(3) Financial documents include 1900-55s, timesheets, travel vouchers,
and other items used to document EPA costs for potential recovery actions.
These documents may be forms filled out by hand or by computer and may
include carbon or tissue copies as backup (e.g., hotel bills). The forms are
generally letter-size, and the backup documentation may be any size. A full list
of financial documents includes:
Procurement Requests
Delivery Orders
1900-553
Timesheets
Travel Vouchers
Contract Invoices
Personnel/Equipment Logs
Daily Work Reports
IG Audit
lAGs Between EPA and Other Federal Agencies
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OSWER Directive 9360.2-01
Subcontracting Justification Documentation
Order for Services Contracts
State Letter Contracts
Many of these originals (e.g., timesheets, travel vouchers, contract invoices)
should be regularly forwarded to the appropriate finance office for processing.
OSCs may wish to include copies of these documents in the site files.
(4) Public relations documents cover interactions with the local
community, the media, public officials, and the public at large. They include
such items as media articles, records of communication, and community
relations plans. These documents may be typewritten or computer-generated
reports on various size paper or they may be originals or copies of newspaper
articles or handwritten notes.
(5) Technical documents are more scientific in nature and may include
sampling and analysis data, investigations, and waste profiles. These docu-
ments may be typewritten or computer-generated and are generally on letter-
size paper. Technical documents also include photographs and maps.
Photographs may be black and white or color, any size from snapshot to
enlargement. Maps may be originals or copies on, usually, oversize stock.
Separate, oversize binders may be needed to store such items.
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OSWER Directive 9360.2-01
8
3. Stt*Fll9Klt
Use of Site File Kits will make it easier for OSCs and Regional
administrative support staff to establish and maintain the necessary site files. In
the Model Program, the Regional office would distribute Site File Kits to OSCs
to maintain for use when they initiate new removal actions. Alternatively,
OSCs may delegate responsibility for the Site File Kits to the Regional
administrative support person or the TAT.
Components of the Site File Kit should be expendable, with each new
site receiving a new, complete kit. The Kit should be streamlined and light,
making it easy for the OSC (or designee) to hand-carry it, along with personal
luggage, to the new site. There should be a single inventory control point in
each Region for the site file kits.
Exhibit 2 illustrates the contents of a sample Site File Kit. It consists of a
sample case (or other sturdy, portable container) which can be outfitted with
pro-labelled folders, blank forms, and basic office supplies. The pre-labelled
folders and blank forms conform to the site file structure established in the
Region or the model site file structure outlined above. In this example, the Kit
contains six folders with the following labels:
Operational Documents
Legal Documents
Financial Documents
Public Relations Documents
Technical Documents
Photographs/Maps
Blank forms include timesheets, travel vouchers, and personnel/equipment
logs.
The Kit also contains office supplies lecessary to "begin business" at
the removal site. Such office supplies may .nciude:
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OSWER Directive 9360.2-01
EXHIBIT 2
SAMPLE SITE FILE KIT
m it
Folders
Blank Fonns
Entry/Exit Lop
Timeshcets
Travel Vouchers
Personal Computer
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.OSWER Directive 9360.2-01
10
Stapler, staples, and staple-puller
Variety of pencils and pencil sharpener
Variety of pens (including felt-tip markers)
Paper clips
Push pins
Masking and transparent tape
Scissors
Inkless stamps (e.g., ORIGINAL, DRAFT)
Post-it notes
Opaquing fluid
Calendar
Document-numbering stamp.
A logical supplement to the Kit is a portable personal computer and a
copy of the Removal Cost Management System software which can be used to
produce reports and analyze data. With a modem, the computer could be used
to transmit computer-generated reports (e.g., POLREPs) to the Regional office
and headquarters. The computer can also be used to access reference
materials stored on diskette. Such reference materials might include:
Statement of Work
Users' manuals
Directory of ERGS contractors
Applicable sections of ERCS contract
Guidance/procedures on invoices, dailies, etc.
EPA phone book (both HQ and Region).
While the sample Site File Kit is fairly inclusive, the OSC may require
some bulky items which would be better purchased near the site. Such items
might include a bulletin board, graphics supplies, 3-ring binders, and blank
video tape.
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OSWER Directive 9360.2-01
11
4. File Management Processes
OSCs have the primary responsibility for maintaining site files while the
removal site is active. OSCs may be assisted in this responsibility by Regional
administrative support staff, TAT and other contractors, and USCG Strike Team
personnel. The OSC (or his/her delegate) must complete the appropriate forms
and reports in a timely fashion and file them according to the site file structure
endorsed by the Region.
Physical location of the various site file components depends on both
the nature of the removal project and the organization of the Regional office. In
general, the OSC must have direct access to complete documentation (either
originals or copies) from the time that a removal action is initiated until the final
OSC report is published.
The major steps involved in site file management follow the life-cycle of
the site-specific removal action:
Project initiation
Short-term actions with no command post
Long-term actions with command post
Preparation of the final OSC report.
Each of these steps is described in greater detail below.
a Project Initiation
When a project begins, the OSC (or delegated person) should
bring a new site file kit to the site when he/she first visits it. The Regional
administrative support person may later bring additional site filing and office
supplies. It is most important, however, that some form of site file kit. even
abbreviated, be available on site at project start.
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OSWER Directive 9360.2-01
14
5. Supporting the Administrative Record
Detailed agency policy and procedures on handling the administrative
record requirements of SARA are issued separately by OWPE. It is
recommended that the Regions establish a regular process for reviewing active
site documents against the current criteria for inclusion in the administrative
record.
The suggested steps in this process are:
The OSC (or designated person) brings all new site documents to the
Regional office on a regular basis for copying and/or storage in
Regional files.
At the same time, the OSC or other Regional staff responsible for file
management reviews the removal action materials for possible
inclusion in the administrative record.
The OSC or other designated Regional staff (or contractors) prepares
copies of selected items for the Region's administrative record and, if
appropriate, the local administrative record maintained on or near the
site.
A flow chart summarizing this process is in Exhibit 3.
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OSWER Directive 9360.2-01
15
EXHIBIT 3
FILE MANAGEMENT TO SUPPORT
THE ADMINISTRATIVE RECORD
Field
Site
Files
Local
Administrative
Record
Yes
Admin. Record
at Regional
Office
Regional Office
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