United State*
              Environmental Protection
              Agency
          Off ic« of
          Solid Waste and
          Emergency Responae
     3EPA
               Agency
           emergency nesponae
                DIRECTIVE NUMBER:  9242.0-02A

                TITLE:  Further Guidance on OSWER Directive &&4&.0-02
                   Analytical Support for Superfund
APPROVAL DATE:

EFFECTIVE DATE:

ORIGINATING OFFICE: HSED
                                11/20/90

                               11/20/90
                D DRAFT

                 STATUS:



                REFERENCE (other documents):

                    9242.0-02
  OSWER     OSWER      OSWER
VE   DIRECTIVE   DIRECTIVE   Dl

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                            United Stttn tnviroflmenui Prelection Aowicv
                                  Washington. DC 204«0   y ^
                  OSWER Directive Initiation Request
                                      1. Diftcvv* Numtxr
                                       9240.0-02A
                                  2. Oriqlnilor Inforrrntion
           Contact Person
         til Cod*
         OS-230
                Office
                  HSED
                                                                  Telepnone Coo
           Further Guidance on OSWER Directive 9240.0-02, Analytical Support for
           Superfund
       . Summary of Directive (indude onel siaiemcnt of purpose)
           SuoDlements 9240.0-02,  by establishing a system for tracking analytical
        services Srfor^ed by BSD laboratories,  contractors, and subcontractors
      5. Ktywords
           Superfund; analysis; contract labs; QA/QC
      6t. Does this Oirictrve Suptc»tc« Previous Oir*ciivc(sj?
      b. Dots It Suppltment Previous
                                        j	j No    j	I Yw   Whit dir«ctlv« (number.
                                           tAle)
                                            No    I x I Yes   Whit dlrecUve (number. ttt«)
                                                       9240.0-02 - Same Title
      7. Draft LeveJ
          A-S^gnedby/WDAA
XX
8 - Signed by Office Director
                         C - For Review & Comment
D - ti Development
8.
Document
to
•i
be
distributed to
States by Headquarters? 1 1 Y«
x>

NO
Thl* R«qu«»t M««u OSWER Directives System Formit SUnd«rd4. . - - '
9. Signtture of Lead Office Directrves Coordinator
Betti C. VanEpps, OERR Directives Coordinator
Henry L. "Longest II, Director, QERR
Date
11/20/90
Gate
11/20/90 '
     EPA Form 1315-17 (Rev. s-*7) Previous editions are obsolete.
   OSWER           OSWER               OSWER               O
VE    DIRECTIVE          DIRECTIVE        DIRECTIVE

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         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                    WASHINGTON, D.C. 20460
                        MOV 2 0 1990
                                                   OFFICE Of
                                           SOUO WASTE AND EMERGENCY RESPONSE
MEMORANDUM                         OSWER Directive #9240.0-02A


SUBJECT:  Further Guidance on OSWER Directive ££40.0-2,  Analytical
          Support for  Superfund

FROM:     Henry  L.  Longest II, Director
          Office of Emergency and  Remedi,
         l~/                          £.
        /7'Bruce  M.  Diamond,  Direct or /.
        '^ Office of Waste Programs Enforcement

TO:       Addressees


Purpose:   The purpose of this memorandum is  to provide  guidance
and  instructions   for  implementing  OSWER  Directive   S240.0-2,
Analytical Support  for Superfund,  March  20,  1986,  by establishing
a system  for tracking Superfund analytical  services performed by
Environmental'   Services  Division    (ESD)    laboratories,    the
Environmental  Services  Assistance   Teams  (ESAT),  .other  field
contractors  (e.g.,  ARCS,  TAT,  TES)  and  their  subcontractors,
States,  other  federal  facilities,   and  Potentially Responsible
Parties (PRPs).  Another purpose of  this memorandum is  to request
that you  designate  a  contact  in  your Region who will work with
Headquarters to  implement this Superfund wide..analytical  services
tracking  system.   As  you know, the Contract Laboratory Program
(CLP)  already has  extensive tracking procedures.   This  system
establishes  similar procedures for  tracking critical information
associated with  non-CLP  services.

Background;   In 1986, the above directive was  issued  to require
the  oversight  and   monitoring   of  all   Superfund  analytical
activities,  not just those analyses  provided  by  ESD  and  CLP
laboratories.  Compliance with the directive has been difficult to
determine,  originally because:  (1)  analytical  services  provided
outside  of  ESD/CLP  laboratories  comprised  a  relatively  small
percentage   of  Superfund's   analysis activities;  (2) there  were
limited resources  to undertake additional  monitoring activities;
and  (3) guidance was  needed on  exactly  how to  track and .monitor
non-CLP analytical  support.  We now know  that non-CLP services play
a  significant   role  in  supporting  Superfund  and  we  now  have
contractor resources in  place  to assist  in the oversight of these
services.
                                                       Printed on Rt cycled ?ap*r

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The-tracking system described in this memorandum has been discussed
with Analytical Services Advisory Committee (ASAC) members, and has
been  pilot  tested in  Regions II,  IV,  and  VII.    This  system
addresses  the  need for guidance  on tracking  and monitoring  all
analysis activities.  The system's paper and automated procedures
have  been reviewed  by ASAC members,  subjected to  a  study  and
thorough workgroup review, and  revised based on the results of the
pilot study  and workgroup comments.

Objective:   The objective of  the tracking system is  to capture
information  needed to determine the use, magnitude, and quality of
analytical  services and thereby  provide  a means for  Regions to
oversee and  monitor these resources in accordance  with Directive
9420.0-2.    It  also   is  intended  to  provide Regional  quality
assurance  (QA)  officials  with  information they need to implement
and manage QA  programs that encompass  all analytical activities
within  the  Regions.    In  addition  to  facilitating  Regional QA
oversight  activities,  the  tracking system is  intended to monitor
PRP enforcement laboratory and  field data  generation activities to
provide  Headquarters  with  national  information  on  analytical
services  that  support  Superfund.   This  information  will enable
Headquarters to plan and implement  a  comprehensive  Superfund QA
program and  provide the Regions with QA support, such as providing
sufficient  quantities and types  of performance  evaluation  (PE)
materials  to assist in evaluating  the  quality of  data generated
from all Superfund  analyses.

Implementation:   The  Hazardous Site Evaluation Division's  (HSED)
Analytical Operations  Branch (AOB) has  been directed to work with
each Regional and Headquarters contact, as well as OWPE, to ensure
that the  tracking system  assists  Regional efforts to. manage  non-
CLP  analytical  services  and  that  the   system  is   implemented
smoothly.  Regions  will ensure 'that  current contracts  are changed
to provide directions, as  needed,  to comply with and implement  this
directive.  The ncn-CLP tracking system will apply to all Superfund
activities   including   those   related   to enforcement  oversight
conducted  by all  Superfund contracts.   OWPE will provide  separate
guidance  in  the near  future on  utilization of  the tracking systeia
for PRP generated  data.

     In addition  OWPE  is  evaluating  the benefits of this  tracking
system for RCRA purposes.  It is reasonable to assume  that some of
the laboratories inspected under the RCRA  program will also be  used
for  Superfund  analysis even if not in the CLP.   The  laboratory
audit inspection  that  RCRA enforcement  staff  conducts  is  designed
to determine whether laboratories  are analyzing groundwater samples
and  performing the proper analysis with  the  appropriate.sample,
analytical methods and QC requirements.   Therefore,  potentially
valuable information (historical or current) on the lab may already
exist in  your  regional or  State RCRA files.   We will  be providing
further guidance on this  issue.

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      The  Regional Hazardous Waste Management Divisions will have
 the responsibility for directing the collection of information and
 the   Environmental  Services  Division  will  be responsible  for
 compiling the information,  carrying  out appropriate QA oversight,
 and reporting to Headquarters.   Each Region will decide how best
 to  operate   the  system  in  accordance  with  its  requirements,
 resources (contracts),  and existing  operations.   Moreover, each
 Region  will decide who  (e.g.,  Regional  staff or contractors)  is
 responsible  for collecting and entering tracking information and
 the appropriate media for tracking that information  (e.g., paper
 or  automated  formats).    Headquarters will provide  both paper
 documentation and software  for  automating the process.

      We fully expect that the  tracking system will provide you with
 valuable  information  on  a continuing basis,  and only  require that
 you   provide  automated   updates   periodically  to  Headquarters.
.Examples  of  the  types  of  information the  tracking  system will
 provide include:

      •     Magnitude  of non-CLP support,  by laboratory and on an
           aggregated  basis;

      •     List of "Non-CLP"  labs used  by  the  Regions  that are
           candidates  for on-site  audits;

      •     Quality of  data generated and the  extent to which data
           meet intended  uses;

      •     Number of  "Non-CLP"  samples analyzed  by  a  laboratory
           under investigation by  the IG;

      •     Extent of review performed on  these data;

      •     Types cf analyses and methodologies performed; and

      •     Extent of  services used by Regions,  their  contractors,
           states, and PRPs.

      The  information  transmitted to  Headquarters  on  analytical
 activities will form  a national database to which the Regions will
 have  access  and from  which Headquarters will generate a variety of
 national and Regional reports on  trends,  quality,  and utilization
 of services.  Approximate costs for various types of analyses will
 be collected by ether mechanisms.  Headquarters will provide user
 support to the designated Regional contact  and will encourage the
 participation of these contacts in user group's to enhance tracking
 system  operations.

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    . The  tracking  system's manual  and PC-based data  collection
instruments,  together  with   procedures   for   implementing   and
operating the system, will be  provided  by the AOB to your Regional
contact  prior to  national  implementation  in  March,  1991.    The
system will be introduced and discussed in detail at the National
Non-CLP Tracking System Meeting, planned for December 11-13,  1990
at the  Holiday  Inn Golden Gateway  in  San  Francisco,  California.
Region  specific  implementation and  operational details will  be
worked out between Regional contacts and the AOB.

     To  begin the process  of implementing the  tracking  system,
please designate your Region's contact  and have the contact notify
David Eng at the  AOB  (FTS  382-4619,  FAX  (202)  252-0524,  E-mail
EPA5512, Mailcode OS-230)  by December  3, 1990.
Attachments
Addressees:
     Director, Waste Management Division
          Regions I, IV, V, VII, VIII
     Director, Emergency and Remedial Response Division
          Region II
     Director, Hazardous Waste Management Division
          Regions III, VI
     Director, Toxic and Waste Management Division
          Regipn IX.
     Director, Hazardous Waste Division
          Region X
     Director, Environmental Services Division
          Regions I-X

cc:  HSCD      Paul Nadeau, Acting Director
     ERD       Stephen Luftig, Director
     OWPE      Frank Biros, Chief, Technical Support Branch
     OE        David Van Slyke, Deputy AEC - KWED
     Non-CLP  Tracking System Workgroup members

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