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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