EP 1110-3-8
9 Apr 04
Notes
The following notes are referenced in Selecting Documents for the Administrative Record. Only
documents containing factual data relevant to the selection of the response action on the FUDS
property should be included in the Administrative Record.
1. Internal correspondence should generally be excluded from the Administrative Record.
However, if these records contain facts that are not available elsewhere, they should be included
in the Administrative Record. Also, all government attorney correspondence should be excluded
from the Administrative Record as well as privileged documents. This material includes formal
letters, meeting notes, and telephone notes.
2. Sampling and analysis data must be included in the Administrative Record. When it is
available, validated data should be used. In order to limit the physical size of Administrative
Records, sampling and analysis data may be included in the Record by referencing the data in
the Record's Index.
3. Only the final version of a work plan (including all subplans) and any subsequent
revisions/modifications need to be included in the Administrative Record.
4. Only progress reports that provide factual information related to a selection of a response
action must be included in the Administrative Record.
5. ARAR information which is directly related to decisions made at the FUDS project must be
included in the Administrative Record. Correspondence between attorneys and/or FUDS project
team members relating to ARARs should be excluded from the Administrative Record.
6. Certain documents may need to be added to the Administrative Record after the Action
Memorandum is signed. These documents would be added to the Administrative Record if they
are relevant to a follow-up action or if the Action Memorandum is amended.
7. All relevant draft documents (e.g., EE/CA, RI/FS, ROD, Public Involvement Plan) that are
made available to the public and upon which the government received comments should be
included in the Administrative Record. Draft documents which contain factual information that
does not appear in the final document or is included in other documents, and upon which the
government based a portion of its response action decision (even if the document was not
released to the public) must be included in the Administrative Record.
8. Documents generated after the Action Memorandum, the ROD, or the DD are final are
usually not included in the Administrative Record. However, if there are multiple areas within a
FUDS property, some documents generated after one Action Memorandum, ROD, or DD may be
included in the Administrative Record if it is related to how the government made a decision for
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