The
Administrative Record File contains the documents and information
considered or relied on in the selection of a response action
and in controlling hazardous waste management activities.
At the Savannah River Site, the Administrative Record File
will fulfill the requirements of Section XXXIV, Administrative
Record, of the Federal Facility Agreement (FFA).
An
Administrative Record File for an individual waste unit is
initiated upon the approval by the EPA-IV and the SCDHEC of
an RFI/RI Work Plan. The File is compiled until the decision
of the response action is chosen (the signing of the Record
of Decision). At that time the Administrative Record File
is finalized and is called the Administrative Record for that
waste unit.
An
Administrative Record serves two primary purposes. First,
it is a vehicle for public participation in the selection
of the response action. Section 113(k)(2) of CERCLA provides
the public with an opportunity to participate in a response
decision. The Administrative Record makes available the information
considered or relied on in the selection and provides the
opportunity for public involvement. Without opportunity for
this involvement of interested persons, the limitation of
court review solely to the Administrative Record can be challenged.
Therefore, the Administrative Record will also record the
public participation in the decision process and reflect the
views of members of the public.
The
second purpose of the Administrative Record is concerned with
the presentation of evidence in the event of litigation. Judicial
review of any issue concerning the adequacy of a response
selection is limited to the Administrative Record. Under section
113(j)(2) of CERCLA, the trial court reviewing the selected
response decision is limited the facts as set out in the Administrative
Record. The Courts will not allow the use of discovery, hearings
or additional fact findings unless the Administrative Record
is found to be incomplete or poorly prepared. Provided the
Administrative Record is adequate, the court will limit its
review of the response decision made to the standard of arbitrary
and capricious or otherwise not in accordance with the law.
The Administrative Record should therefore chronicle the response
decision process, whereby a judge could easily follow how
and why a decision was made.
An
Information Repository File contains information and documents
that do not meet the definition of Administrative Record Files
but that contain site and unit information, documents on site
and unit activities, and general information.
Each
entry in the Administrative Record File Index contains the
following information:
- ARF/IRF
Catalog Number
-- A unique number assigned to each document or piece
of information. For those documents that are microfilmed,
the number is stamped on the top of the document to aid
in locating the document on the microfilm.
- Date
-- The date the document or information was issued.
- Document
Number -- Many of the documents published or produced
by the SCDHEC, EPA and SRS are assigned unique numbers.
If no document number has been assigned, it is so indicated
by the entry of a unique sequence number known as the
catalog number. This number is for electronic tracking
only.
- Title
-- The title of the document, or a brief description of
the contents.
- Author
-- The person or party responsible for the issuance or
writing of the document or information
- Author
Affiliation -- The organization that the author works
for or is affiliated with.
- Addressee
-- In most cases this entry will be blank except if the
document is correspondence. The entry, in that case, will
be the individual(s) to whom the correspondence was addressed.
- Addressee
Affiliation -- In most cases this entry will be blank
except if the document is correspondence. The entry in
that case will be the organization(s) to which the Addressee
is affiliated.
- Appx. No.
of Pages -- The approximate number of pages the document
contains.
- Document
Type -- Each document is categorized according to
one of the following types of information:
- Community
Involvement/Relations
- Correspondence
- Draft
RFI/RI Work Plan
- Federal
Facility Agreement
- Final
RFI/RI Work Plan
- Guidance
- Interim
Action Proposed Plan
- Meeting
Minutes
- Proposed
Plan
- Risk Assessment
Document
- Site Evaluation
Report
- Supporting
Document
- Classification
-- The entry will contain one of the three following codes:
- U -- The
information is unclassified and available to the general
public for viewing.
- CP --
The information or document is considered confidential
or privileged. The document may contain sensitive
information and is not available to the general public.
It may be included in an Administrative Record File
as it was used to support the decision making, but
cannot be made publicly available.
