United States
Environmental Protection
Agency
Office of Solid Waste
and Emergency
Response (OS-510W)
EPA520-F-92-001
August 1992
vvEPA Superfund Information Repositories
and Administrative Records:
Introduction for Librarians
What .is Superfund?
In 1980, Congress passed the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA
or Superfund). This Act authorized 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 sites or pay for the costs. When PRPs are unwilling or unable
to conduct or pay for the cleanup, money from the Trust Fund may be used.
INTRODUCTION
Members of the public play a central role in the
Superfund program. EPA considers public input when
making site cleanup decisions, particularly the Agency's
selection of the response action for the site. This fact
sheet discusses two features of EPA's Superfund Com-
munity Relations Program: the information repository
and the administrative record.
1. What is an information repository?
An information repository is where current informa-
tion, technical reports, and reference materials regard-
ing a Superfund site are stored. EPA or the State
establishes the repository in the community at the be-
ginning of site studies to provide the public with easily-
accessible information. Repositories are established for
all sites where cleanup activities are expected to last for
more than 45 days. Typical repository locations include
public libraries or municipal offices.
2. What is an administrative record?
The administrative record is a specialized file contain-
ing the information which was used to select the rem-
edy at a Superfund site. Administrative records contain
technical reports specific to each Superfund site, and
key technical and administrative guidance for clean-
ups. An administrative record must be available at
every site to encourage public participation in the rem-
edy selection process. EPA maintains an identical copy
of the administrative record at the EPA Regional Office
or a State office.
Although agencies may establish more than one infor-
mation repository in a community, EPA or the State
typically establishes only one local administrative
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.
3. When does EPA establish the
information repository?
EPA prefers to establish information repositories as
early in the site cleanup process as possible and before
technical activity begins. The earlier the repository is
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established, the greater the opportunity for the public to
access information on the activities at the site. There
will be some occasions, however, when the governmen-
tal agencies must move quickly to address site condi-
tions Setting up the information repository may follow
those technical 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 re-
pository and the Community Relations Coordinator
(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 5 through 8 of this fact sheet. In many situations,
the repository contains the administrative record and
its documents as they are being compiled Administra-
tive record materials need to be clearly marked.
5. Why should I be an information
repository librarian?
The information repository is one of the best ways to
involve the public in the site cleanup process. Because
you already hold a position as an information source in
the community, you are especially qualified to keep
information for the public Your service in helping EPA
maintain the information repository is invaluable in
facilitating meaningful public involvement in the site
cleanup
6. 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 public accessibility Whenever possible,
repositories are located in buildings with photo-
copying facilities, and are accessible for people with
physical handicaps In some cases, two repositories are
INFORMATION REPOSITORY
WITH ADMINISTRATIVE RECORD
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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Community libraries or other public buildings may house the information
repository, the administrative record, or both. Librarians will choose among
these options according to the best fit for their facility space and other factors.
established for a site. A pubbc library branch near the
site, for example, may be an appropriate location for the
repository. In addition, the mam 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. The actual
repository may be contained on bookshelves, in file
cabinets, or in notebooks
7. From whom do I get information to
put into the information repository?
Most information will be provided by the EPA or the
State CRC. You, as the repository librarian, and other
members of the community, may also identify relevant
newspaper clippings or local publications for inclusion
in the repository. You should confirm the appropriate-
ness of all materials with the CRC before actually plac-
ing them in the repository. The administrative record
has its own index; the Administrative Record Coordi-
nator (ARC) will supply all materials.
8. How do I maintain the repository?
Repository maintenance consists of the same routine
you use to organize files or shelves for the public. It also
involves adding new information from EPA or the
State. Librarians may find it helpful to keep a chrono-
logical log of all information EPA or the State sends. The
agencies, however, and not local librarians, bear ulti-
mate responsibility and liability for the contents of
information repositories and administrative records.
9. How is the information
repository organized?
The repository is organized by the CRC, depending on
the information available. Subject categories include,
for example: general Superfund information, site sam-
pling data and analytical results, legal documents relat-
ing to the site, public involvement records, and infor-
mation on the selected cleanup technology
If the administrative record is included with the infor-
mation repository, documents should be marked as
such and kept separate from the general materials of the
repository. During periods of high interest in the site,
EPA will readily furnish you with extra copies of re-
quested administrative record documents
10. What time commitment is
involved in maintaining the
information repository/
administrative record?
Depend ing upon the reference system currently in place,
it may take a few to several hours to set up the space and
tracking system for these files. Many libraries already
serve as repositories for state or federal agency docu-
ments, so adding another repository may be a familiar
exercise. The time commitment involved in receiving,
logging in and referring library users to the documents
also would vary, depending on the level of community
interest in the site and on phases of site activity. Typi-
cally, ongoing maintenance of the files involves a few
hours per month.
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The overall time-frame for information repositories can
be several years. But during that time, EPA will assist
you with deleting old files so that adding site docu-
ments does not burden your available space
11. What space commitment is involved
in maintaining the information
repository/administrative record?
As with time, space required for the files can vary,
according to the particular site circumstances or com-
plexities Seldom, however, does the space require-
ment exceed that of two file drawers or a standard
library shelf It is best to discuss this question with the
CRC, who may be able to predict the amount of space
you may need.
IIII III H| II I' IIIII |l Ml II INJUN 11 III 11 III l|||||llll fillip II
1 2 3 4 5 6 7 8 9 10 11 12
12. May I add information to the
repository?
The information repository, yes; the administrative
record, no As indicated earlier, you may be in the best
position to identify potentially useful information for
the repository. EPA encourages and appreciates any
ideas you may have for enhancing the effectiveness of
the information repository Because the administrative
record, however, provides documentation for the spe-
cific remedy selected at the site, only EPA or the State
may add or delete information to this file.
13. May library users remove
documents from the repository?
No It is important that the information in the reposi-
tory remain accessible to all members of the community
who may want to use it Therefore, individuals should
not remove documents from the repository for their
personal use In some cases, EPA will provide you with
extra copies of certain documents, such as fact sheets,
which members of the public may take with them
Generally, however, persons wanting their own copy of
the information must either make a copy of the docu-
ment (provided you have a copying machine) or re-
quest a copy from EPA If you notice that documents
are missing, contact your CRC or ARC
STANDARD INFORMATION
REPOSITORY DOCUMENTS
Although the contents of each information repository
vary depending on the site and phase of site cleanup,
certain documents are found in most repositories This
section briefly describes some but certainly not all of the
documents that could be included
General Superfund Information
Most information repositories contain introductory
background information on the Superfund program.
This information may include fact sheets and brochures
on various aspects of the Superfund program and the
cleanup process General program information pro-
vides a context within which the public may consider
site-specific information and explains the overall
Superfund goals
Copies of CERCLA and RCRA
Information repositories typically contain copies of the
Comprehensive Environmental Response, Compensa-
tion, 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 com-
prehensive waste management law CERCLA and
RCRA are complementary laws that establish waste
managementand cleanup programs for past and present
disposal practices These statutes are generally in-
cluded in repositories to provide the public with a
framework for understanding the activities at the site
The National Oil and Hazardous Sub-
stances 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 (MRS)
Information
The Hazard Ranking System (HRS) is a method used by
EPA to evaluate potential risks to health and the envi-
ronment by the release of hazardous substances at a site.
The HRS produces a site score (a number between 1 and
100) which is the primary factor in deciding if a hazard-
ous waste site should be placed on the National Priori-
ties List (NPL). The NPL is a list of the most serious
uncontrolled or abandoned hazardous waste sites iden-
tified for possible long-term cleanup, using money
from the Superfund. HRS information includes site
investigation reports and site soil, water, and air sam-
pling data and analysis.
Press Releases
Press releases that are relevant to the site or
the Superfund Program are typically included
in information repositories. Press releases provide a
record of activity at the site, and may document com-
munity 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 respon-
sibility for cleaning up a Superfund site, the State's
responsibilities are set forth in a Cooperative Agree-
ment 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 epidemiologist, 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 pro-
gram, contact the CRC.
STANDARD ADMINISTRATIVE
RECORD DOCUMENTS
The Administrative Record evolves over time, and docu-
ments are added corresponding to site activities. 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 ad-
ministrative 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 emergency 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 document
prepared by EPA or the state, which describes the site
background; identifies community concerns regarding
the site; sets forth a strategy for addressing those con-
cerns; and identifies opportunities for public involve-
ment regarding the sites. The CRP also contains names
and addresses of EPA and State contacts. The key
planning information in the CRP is derived from inter-
views with members of the local community. CRPs are
prepared for all Superfund actions lasting longer than
120 days.
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Administrative Order on Consent (AOC)
Health Assessment
An AOC is a legal agreement between EPA and Poten-
tially 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 environ-
mental threats. It outlines the proposed actions and
costs, and documents approval of the removal. An
addendum to the Action Memo sets forth the enforce-
ment strategy. Because Action Memos are the primary
decision documents to select and authorize removal
actions, they are the critical component of the adminis-
trative 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 senes 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 sam-
pling will be conducted, treatment alternatives to
be explored, and methodologies for conducting site
studies.
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 environmen-
tal sampling data and other site-related information.
The health assessment determines whether any current
or potential health threat exists. It does this by evaluat-
ing the completeness of the information and consider-
ing the types of contamination present, pathways the
contamination 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.
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 administrative record file and
enables the public to better understand the nature and
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extent of contamination at the site. These reports are
often highly technical; other documents such as the RI
and FS reports generally will summarize the informa-
tion 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 evalu-
ates each of the proposed cleanup alternatives against
criteria such as short and long term effectiveness,
implementabihty, cost, compliance with State cleanup
requirements, and the effectiveness of the alternative in
maintaining protection of human health and the envi-
ronment. 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 considered for
the site by EPA and identifies the alternative(s) pro-
posed 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 opportu-
nity 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 meetings also provide the opportu-
nity 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 written
public comments received by EPA during public com-
ment periods on key documents, such as the Proposed
Plan, and contain EPA's response to these comments.
As such, they document community concerns regard-
ing the cleanup for EPA decision-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 ex-
plains 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 comments
and community co'ncerns. ?
POST-DECISION DOCUMENTS
The administrative record normally closes when the
ROD is signed. On occasion, new information is re-
ceived on site conditions or the technology selected,
which requires the ROD to be amended or an explana-
tion of significant differences to be written. These
materials may be added to the administrative record file
and kept in a post-decisional file.
'More documents pertaining to the site will be generated
after the close of the administrative recordt The follow-
ing documents will be part of the information reposi-
tory:
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Remedial Design (RD)
Consent Decree (CD)
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 activi-
ties. The RD provides the public with information on
activities to be conducted 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 reme-
dial design of the selected cleanup alternative at a
Superfund site.
A CD is a legal agreement between EPA, the PRPs, and
sometimes the State, whereby the PRPs consent to per-
form or pay for all or part of the RD/RA. The Consent
Decree describes the actions for which PRPs are respon-
sible and is subject to a public comment period. Con-
sent Decrees are approved and issued by U.S. District
Court judges
Unilateral Administrative Order (UAO)
A UAO is a legal document issued by EPA directing
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.
xvEPA
United States
Environmental Protection
Agency (OS-510W)
Washington, DC 20460
Official Business
Penalty for Private Use
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EPA
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