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Preparing the Documentation Record

The information contained in this section is organized into these subsections:

Elements of the Documentation Record

The Task

  • Obtain and Read all site information. Keep clean copies of all references you might use.

  • Take notes and organize them by source or pathway.

  • Keep a running score.

  • Identify sources and significant pathways.

  • Gather maps and diagrams.

  • Identify HRS data gaps.

When you document a site score, you will move back and forth among these tasks.

Keep a Running Score
Back-of-the-envelope scoring will focus your attention on the HRS implications of the information you are gathering.

  • Is a number "at risk" because it lies near a breakpoint on an HRS table? For example, see Table 2-6 of the HRS rule, page 51591.
  • The more important an item of information is to the score, the better the quality of information should be.
  • "Killer" issues are those that can drop the score under 28.50.

The attempt to score the site will also focus attention on what information is still missing.

Gather Maps and Diagrams

  • Refer to Appendix D: Map Specifications For The HRS Documentation Record of the Regional QC Guidance for NPL Candidate Sites.

  • Choose a base map and annotate it with site-specific information (i.e., sources, site boundaries, locations of targets).

  • Present pathway-specific maps (i.e., tax assessor's parcel maps, geological cross-sections, and Wetland Inventory Maps).

  • Insert maps within the text of the documentation record.

  • Aerial photographs may be useful to show historical conditions.

  • Maps should be reproducible, legible, and to scale.

List and Cite References

List only the references you use in the documentation record. (Be sure to use all references that EPA might need to justify listing the site.)

  • Every assertion of fact must be referenced in the documentation record. (Example: Ref. 9, p.43; Ref. 24, p.B-158.)

  • Use a recognized style for the list of references in the documentation record.

  • The HRS rule is always Reference 1 and the Superfund Chemical Data Matrix (SCDM) is always Reference 2.

  • References should be numbered sequentially as they appear in the documentation record.

Identify HRS Data Gaps

Review each HRS factor for completeness of documentation.

Are any data of inadequate quality?

  • Pay particular attention to the significant pathways and to data that are important to the site score.

  • Develop technically accurate rationale when data are questionable.

  • Compare all data to the breakpoints in the HRS tables.

  • Look for conflicting assertions or for differences in the numbers that are reported.

  • Review the analytical data carefully for all critical samples.

  • Do not use inadequate or unsupported data. It only slows the process down.

The identification of data gaps will focus on further information gathering.

Notes on the Final Product

  • Every assertion and fact can be challenged.

  • The HRS score begins at zero and rises as you present evidence that supports a higher score.

  • Every assertion of fact must be referenced and every professional judgement presented with a clear, documented rationale.

  • You are writing for the general public...which includes everyone from local citizens to lawyers to consulting engineers.

  • Weave the facts together into a "story" that states EPA's case for placing the site on the NPL.

  • Most documentation records are written in the WordPerfect format, but PREScore or any other format that presents the information in an understandable and defensible manner is acceptable.

  • Do not include extraneous information that might be challenged.

Common Problem Areas

Summary

  • Read references, organize information, rough out scores, identify data gaps, then develop a plan for closing the data gaps.

  • Watch for eligibility issues that have not been previously caught.

  • Ask for guidance in special cases and work closely with other experienced co-workers.

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