EP 1110-1-19
30 Jun 01
inspections are conducted to determine whether the construction is complete in accordance with
the contract design and specifications. The inspections are generally held between the
contracting party and the construction contractor, although others can be invited. If all the items
observed during the contract pre-final inspection are corrected or are considered insignificant,
the contract pre-final inspection may automatically serve as the contract final inspection.
Otherwise, a contract final inspection will be conducted later by the contracting party to
determine if these items have been corrected and completed in accordance with the RD plans and
specifications. In addition to the pre-final and final inspections, other inspections may be
required prior to completion of the RA. These include Fund-lead, PRP-lead, and Federal facility
(FF)-lead inspections as described below.
(2)
Fund Lead. The NCP requires an additional set of inspections at Fund-financed
sites that will undergo LTRA and/or O&M. During this set of inspections, EPA and the State
concurrently determine the end of the O&F period. After an O&F determination is made, the
remedy enters LTRA or O&M. If convenient, these inspections may be conducted concurrently
with the contract pre-final or final inspection.
(3)
PRP Lead. For PRP-lead sites, the Revised Model CERCLA RD/RA Consent
Decree (Federal Register, Vol. 60, No. 145, pp. 38817-38837, July 28, 1995) requires a pre-
certification inspection upon completion of the RA. This inspection, which involves the PRP(s),
EPA, and the State, is intended to determine if the RA is fully complete and if the remediation
objectives/cleanup goals are attained. After the pre-certification inspection, the PRPs are also
required to submit a written report, for EPA approval, stating that the RA is complete in full
compliance with the requirements of the Consent Decree. If it contains the proper information,
this report can serve as the RA report for the OU. For groundwater and surface water restoration
remedies, where an interim RA report is appropriate, EPA may require the preparation of a
separate (interim) RA report for groundwater or surface water, since it is not normally required
in the Consent Decree.
(4)
FF Lead. Federal facility agreements (FFAs) generally require an additional set
of inspections to determine that all aspects of the remedy have been implemented in accordance
with applicable enforcement documents and the ROD. Participants include the EPA, Federal
facility, oversight contractor, and the State. These inspections may be conducted concurrently
with either of the pre-final or final inspections described above.
b.
Remedial Action Reporting. When the RA for an operable unit is complete, the
RA report is prepared. There are two basic types of RA reports, interim and final. An interim
RA report is completed only for RAs that include groundwater or surface water restoration
remedies, including monitored natural attenuation. Interim reports are used because of the
extended duration between the completion of the treatment system construction (or the ROD
signature, in the case of monitored natural attenuation) and the achievement of the cleanup goals.
A final RA report is complete when the remediation objectives/cleanup goals are achieved.
More detailed information on preparation, timing, distribution, approval, and review of RA
reports is provided in Chapter 3.
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