The Administrative Record (AR) consists of documents that justify EPA’s decision for a response action at a Superfund site. These collections are made available to the public for comments and to view EPA’s decision. Toeroek has supported multiple EPA regions in their efforts to classify, process, and distribute ARs. We provide AR technical assistance to EPA staff, including training and AR document collection consultation.
Toeroek also supports EPA and DOJ in certifying ARs for court submittal during litigation. For a Superfund site in Colorado, Toeroek coordinated a large number of changes to over 70,000 AR designations and 5,000 privileged designations within a time period, enabling EPA to certify the AR before the deadline set by the Court. Toeroek obtained the site file index from the Superfund Records Center, imported it into a database that was used by both the EPA and DOJ site team, trained EPA attorneys and paralegals on how to use the system to review and identify groups of documents, coordinated with other EPA contractors in obtaining additional documents to supplement the AR, performed a privilege review on over 5,000 documents, and created a privilege log substantiating the EPA and DOJ privilege determinations.
Highlights:
- Expertise in preparing ARs for EPA
- AR training to EPA Region staff resulting in time and cost savings
- Assist EPA in producing accurate and timely Court-certified ARs; often requiring many revisions in short time period; delivered on time and with 100% accuracy
