.inn,,.. States
Environmental Protection
Agency
jnice ot
Solid
P'joiication 9355 0-39F5 j
J-r.e 1992
y PeSoonse
SEBV
Remedial Action Report
Documentation for Operable Unit Completion
Office ot Emergency ana Remedial Response
Hazardous Site Control Division OS • 220W
Quick Reference Fact Sheet
The progress in moving a site toward the ultimate goal of deletion from the NPL typically involves several
operable units or multiple phases of construction over a period of several years. The purpose of the Remedial
Action Report is to document the activities that occur under each specific remedial action operable unit at
a sue. This report provides documentation that a particular operable unit has met us objectives as well as
summary information for subsequent inclusion in the Superfund Site Close Out Report. The report also
serves as an excellent source of lessons learned for project managers and designers of future remedial action
projects.
The Environmental Protection Agency's (EPA) Superfund Comprehensive Accomplishments Plan (SCAP)
and Strategic Targeted Activities for Results System (STARS) define completion of an operable unit
remedial action as: conclusion of construction activities, performance of a final inspection, determination
that the remedy is operational and functional, and preparation of an operable unit Remedial Action Report.
Acceptance of the Remedial Action Report by the Regional Superfund Branch Chief, demonstrates the
formal completion of the operable unit remedial action and completes the requirements for meeting the
target.
Figure 1: Remedial Action Report Elements
introduction
Chronology of Events
Performance Standards and Construction
Quality Control
Construction Activities
Final Inspection
Certification that Remedy is Operational
and Functional
Operation and Maintenance
Summary of Project Costs
CONTENT OF THE REPORT
Figure 1 highlights the essential elements that should
be included in the Remedial Action Report.
Introduction
This section provides a short (approximately I page)
general description of the sue and remedy imple-
mented. Site location and description, history, com-
ponents of the selected remedy, and specific con-
taminants dealt with during the remedial action are
examples of items to address. Sufficient informa-
tion should be provided to permit a reader unfamiliar
with the sue to understand the challenges faced by
those involved in the remedial action.
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Chronology of Events
This section provides a summary of the major
events associated with the remedial action. A sug-
gested starting point is the Regional Administrator's
signature on the Record of Decision or the date the
remedial design assignment was issued.
Pprformance Standards and Construction
Control
This is probably the most important section of the
Remedial Action Report. Performance Standards
are the criteria or requirements that the remedial
action contractor met in completing the project.
Performance Standards include cleanup levels, qual-
ity criteria, and other substantive requirements, or
limitations found in the Record of Decision. Each
Performance Standard should be addressed by pro-
viding the standard, the maximum level permissible,
the results of field sampling, the basis for the deter-
mination that the standard was met (except for Long
Term Remedial Actions), and the location and fre-
quency of the tests.
This section of the Remedial Action Report should
also provide a summary of the implementation of the
construction quality control plan and provide an
assurance that the remedial action is complete. A
table should be included that lists the types of
samples taken and provides a comparison of test
results with the specified standards to be achieved
by the remedial action.
Construction Activities
This section is a narrative description of the con-
struction activities undertaken for the remedial ac-
tion. Quantities excavated* cleanup levels achieved,
and materials and/or equipment used should be
addressed in this section and may be presented in
tabular format in support of the narrative. The name
and specific role of the major design and remedial
action contractors should be provided. Participation'
by other f&aerattigeneies'SUghjas mcJLJ4S. Army!
Corps of Engineers or the: U.£ Bureau.of Reclamiat:
rion should be discussed?
This is also the section where information on les-
sons learned" should be provided. While a major
portion of this narrative will deal with problems
encountered during the construction, successes
should be documented as well. Included in the
discussion of problems should b* th~ options con-
sidered, the process used to select a final solution,
and the causes of any delays encountered. The
discussion of successes should include time or cost
saving measures employed or the use of innovative
solutions to problems encountered.
Final Inspection
This section documents the pre-fmal and final in-
spections conducted by the contracting party and
contractor at the completion of construction of the
operable unit. The section should contain a brief
description of the deficient construction items (punch
list) reported and resolved during the pre-final and
final inspections and a list of attendees at the
inspection(s). The final resolution of all deficient
items should be documented.
Certification that Remedy is Operational and
Functional
For those operable units where the Remedial Action
includes a shakedown period (e.g., operation of a
system for the treatment of leachate or ground wa-
ter), the Remedial Action Report should include a
statement that the work was performed within de-
sired specifications and that the remedy is opera-
tional and functional. For other operable units (e.g.,
the excavation and off-site disposal of contaminated
soil) the certification will be an affirmation that
performance standards have been met The basis for
the determination should also be provided.
Operation and Maintenance
An operation and maintenance plan is required for
virtually all remedial actions. This section should
tdiiscuss the highlights of the operation and mainte-
nance plan, as well as provide insight to potential
problems/concerns.
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Summary CT Oroiect Costs
This section should provide the final costs for the
project and compare them to the original remedial
action estimate. It is required for fund-lead projects
and provided whenever possible for Potentially Re-
sponsible Party lead projects. Presentation of this
i nformation may be in tabular or narrative form. The
need for and cost of any modifications during con-
struction should be noted in this section. If the
project was performed by PRPs, a summary of the
EPA oversight costs should also be appended to the
report.
PREPARATION OF THE REPORT
The Remedial Acnon Report should be prepared by
someone familiar with both the design and construc-
tion ef forts associated with the remedial action. This
familiarity provides the best background to discuss
the successes and difficulties of the project. This
.•oiowiedge is often iimiteo :o just ;wo parties :.~.e
EPA Remerha! Project Manager iRPVH and :he
contr.-cting party for the remedial action (e.g.. the
PRPs. the U.S. Army Corps of Engineers, the State.
or EPA's ARCS contractor). In either case, the
contracting party has had a major role in the imple-
mentation of the project. While the EPA RPM can
and sometimes may prepare the Remedial Action
Report, it is recommended that the contracting party
be tasked to prepare the report as pan of the work
assignment, IAG, or settlement agreement.
Figure 2 is a flow diagram showing the individuals
typically responsible for preparation, review, and
approval of the Remedial Action Report under the
several possible scenarios. For most operable units
the Remedial Action Report should be prepared
within sixty days of the Final Inspection of the
completed construction. However, for systems
requiring a shakedown period, the report should be
drafted at the completion of construction and final-
Figure 2: RA Report Preparation, Review, and Approval
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.zed wiimn sixty days of the detenomauon that the
system is operational and functional. The recom-
mended maximum report length is twe.uy (20)
pages. The Remedial Action Report should be
signed and dated by the preparer and submitted to
the EPA RPM for review and comment. Formal
completion of the Remedial Action as weh as the
Remedial Action Report occurs with the approval of
the report by the Regional Superfund Branch Chief.
A Remedial Acnon Report should be prepared fol-
lowing each operable unit remedial acdon. When
there is more than one operable unit at a site, a Site
Close Out Report (Preliminary, Interim or Final)
snouid be prepared following the successful tn:pie-
mentanon of the final operable unit remedial acaon.
Only one Site Close Out Report should be prepared
for the entire site, regardless of the number of
operable units. The Remedial Acaon Reports for the
individual operable units should be used as die basis
for development of the Site Close Out Report The
preparation of Site Close Out Reports is covered m
Procedures for Completion and Deletion of Na-
tional Priorities List Sites. EPA/540/G-89/002, dated
Apnl, 1989 and subsequent updates.
For additional information on Remedial Action Report preparation please contact:
Office of Emergency and Remedial Response
Hazardous Site Control Division
Design and Construction Management Branch* (OS-220W)
(703) 308-8393
* Call your RD/RA Regional Coordinator
v>EPA
United States
Environmental Protection
Agency
Washington, DC 20460
Official Business
Penalty for Private Use
5300
First-CUss Mail
Postage and Fees Paid
EPA
Permit No. G-35
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