analytical tracking

8/2/2019 Analytical Tracking

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY' WASHINGTON, D.C. 20460

OFFICE OFSOLID WASTE ANDEMERGENCY

RESPONSE

MEMORANDUM

Directive # 9240.0-2C

November 14,2002

SUBJECT: Tracking Superfund Non-CLP Analytical DataFROM: Michael B. Cook //ss// Michael B. Cook

Director, Office of Emergencyand Remedial Response (TO: Superfund National Program Policy ManagersRegional Science and Technology Division Directors

Purpose

This directive reinforces the requirement for nationally tracking non-Contract LaboratoryProgram (CLP) analytical services and supersedes OSWER Directives 9240.0-2A and 2B. Theprior directives established theAnalyticalServices Tracking System (ANSETS)as a trackingsystem for non-CLP data, since the CLP already had extensive tracking procedures inplace. Itis still a requirement to submit data to ANSETS. However, the focus is primarily on trackinganalytical data generated via EPAfield contractors and their subcontractors at federal fund leadsites and at sites whereEPA is the lead agency overseeinga federal facility cleanup underanInteragency Agreement. To aid in ANSETS data submission, the system has been updated, thereporting elements have been reduced, and various options (including FORMS IILite*) areavailable to submit the required data. (See the FORMS II Lite Companion Directive# 9420.0-38 for additional details). Since ANSETS is not considered a self-reporting quality assurancetool, the EPARegions need to provide this function. TheOffice of Emergency andRemedialResponse (OERR) is also developing electronic tools to facilitate data review for non-CLP data.The Importance of ANSETS

The Superfund program requires analyticaldata for critical decision making. Analyticaldata is used to demonstrate the natureand extent of contamination at hazardous waste sites, toassess response priorities based on risks to human health and theenvironment, to establishappropriatedeanup actions, and to determine thecompletion of remedial actions.Thegeneration of technically soundand legally defensible data is of primary importanceto

Internet Address (URL) http://www.apa.govRocycted/Rcyelable Printed with Vsgelabte 01 Based Inks on Recyded Paper (Minimum 30% Postconsumer)


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Superfund fo r site decisions as well as to support enforcement actionsand cost recovery. It isequally essential that the Regions ensureth e appropriatequality assurance or analytical dataan d select the most cost effectivecontract vehicle.

The Field and Analytical Services Teaming Advisory Committee (FASTAC), which iscomprised of managers from OERR,the Regional Scienceand Technology (RS&T) Divisions,and the Regional Superfund Divisions,established a decision tree for selecting analyticalservices. In general, the RS&T Division laboratories {i.e., Tier 1) are the preferred option fo rspecial analytical services while the CLP (i.e., Tier 2) is the preferred option for routineanalytical services. Region-specific analytical services contracts comprise Tier3. The leastpreferred option (i.e.,Tier 4) for obtaining analytical services Is using subcontractors via fieldcontracts such as Response Action Contracts (RACS), Superfund Technical AssessmentandResponse Team (START), Emergency and Rapid Response Services (ERRS), and otherheadquarters or regional contracts. EPA's concerns with Tier 4 include lack ofdirect oversightof these contractors, quality assurance potentially not meeting EPA standards, and often highercosts. By requiring contractors to use the ANSETS tracking system, the Superfund programcan determine whether the FASTAC strategy is being implemented, analyze trends in newservices needed, track national laboratory analyses acquired for the Superfund program, andplan for quality assurance oversight.Scope of ANSETS Requirements

Although the majority of the Regions are submitting ANSETS data, there appears to beunder-reporting, and not all contractors are complying with the requirement. This new Directiveis aimed at reinvigorating analytical services information collection from all EPA field contractors(e.g., RACS, START, ERRS) and their subcontractors at federal fund lead sites and at siteswhere EPA is the lead agency overseeing federal facility cleanups under an InteragencyAgreement (i.e., Tier 4).RS&T Division laboratories (i.e., Tier 1) do not need to comply with the ANSETSrequirements. The Regions have the option of reporting data generated fromtheir Region-specific analytical services contracts (i.e., Tier 3).State-funded sites and Potentially Responsible Parties (PRPs) do not need to complywith ANSETS data submission, although regional management should establish (or continue)regional systems to track and oversee PRP analytical services. Tracking PRP data is animportant step to take, especially in light of past problems with potentially fraudulent data anddifficulty in tracking down affected sites.

Procedures for Submitting ANSETS DataThe Regions should use their discretion to determine the most appropriate steps neededto fulfill the ANSETS data submission requirement. Therearefour major mechanisms to submitANSETS data toOERR:

4 FORMS II Lite (preferred) - FORMS II Lite automates sampling field documentationand exports the data electronically. The export file from FORMS IILite captures theessential ANSETS data and is the most direct and effective method to meet theANSETS requirements. Samplers can use FORMS II Lite for sampling events and to


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submit the export file electronically via the Internet.4 Web-Based Submission Form - Contractors can submit the ANSETS data bycompleting the web-based formand submitting the data via the Internet.4 ANSETS Standalone Desktop Application- Contractors submit data to the Regions. The

Regions use the desktop applicationto manage and submit the ANSETS data toOERR.$ Batch submissions - Contractors submit data toRegional tracking systems. The

Regions then batch the data and provide it bi-monthly to OERR.Detailed instructions and procedures for submitting ANSETS data can be found at:http://www.epa.gov/superfund/programs/cip/ansets.htm.

Suggested Contract Language for EPAContracts. Cooperative Agreements, andInteragency AgreementsAttachment 1 provides additional detailsand suggested languageto modify EPAcontracts, Cooperative Agreements, and Interagency Agreements. Attachment 2 lists therequired data for ANSETS submission. Amendments to State cooperative agreements and

federal facility interagency agreements for EPA-lead cleanups may also be required. EachRegion should amend its major assessment and response contracts (e.g., RACS, START,ERRS) that provideanalytical services to ensure the ANSETS requirements can be met.Regional modifications may be needed to accommodate Region-specific needs. In instanceswhere FORMS II Lite will be used to meet theANSETS requirement, contractors shall providethe equipment necessary to operate FORMS IILite. Contract language for the FORMS IILite requirement and information on the software and training can be found in Directive #9420.0-38. OERR recommends the contract amendments for the FORMS IILite andANSETS requirements be made at the same time. The ANSETS requirements should be inplace by January 1, 2003.Next Steps

Regional Contracting Officers and Project Officers will need to amend their assessmentand response contracts to reinforce the ANSETS analytical services tracking requirements.Regions need to designate a person to serve at the ANSETS liaison with Headquarters toensure compliance. The Regional ANSETS liaison needs to work closely with site managers toensure the analytical contractors are reporting data to ANSETS. Please send the name of theANSETS liaison to Dana Tulis by December 10,2002. OERR will continue to provide summaryANSETS reports to the Regions every two months.

Thank you for your cooperation in improving compliance with the ANSETS requirement.Please call DanaTulis at 703-603-8993 for general policy issues and Willie Wong at 703-603-8846 for technical questions.AttachmentsCC:Field and Analytical Services Teaming Advisory Committee


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Superfund Senior Regional Management and Acquisition CouncilRegional Lab DirectorsRegional Quality Assurance ManagersCL P Project OfficersRegional Sample Control Center CoordinatorsRACs. START, ERRS Contract Officers/Project OfficersOERR Senior Management Team


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United StatesEnvironmental Protectionincy

Date:

Please seeANSETS Website for Current List of Required DataAttachment 2 - ANSETS Data Requirement(List of Required Data )Sampling Start Date:Sampling EndDate:

Project NumbersProjectNumber Regional Account DAS Assoc.Number Number: CLP Case No:Site InformationSite Name:CERCLIS ID:ResponsibleEP A Project Individual:

Operable Unit:City:Action:

State:Funding Lead:

SamplingOrganization:

Analytical Services InformationIf field analytical services areused during this projectwrite "field analysis"In the Laboratory Name Column. If fixed laboratory Is used write the nameof the laboratory In the Laboratory Name Column. Please specify In thisbox all field analytical techniques used.

Laboratory Name (includelocation if multiple lab locations) No.Samples

Completed by:

Matrix

COST:

Analysis

Organization:

RequestedTurnaround (Days)

Date:

analytical tracking

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