oEPA
                United States
                Environmental Protection
                Agency
             Off ic« of
             Solid Waste and
             Emergency Response
URITM State*
Enwonmenui Protection
             Orf-ca o«
             Solid Waste and
             Emergency fteieonsa
 DIRECTIVE NUMBER:

 TITLE:
                                    9240.0-03

                     Superfund Analytical Review & Oversight
                APPROVAL DATE:

                EFFECTIVE DATE:

                ORIGINATING OFFICE:

                Q FINAL
                 10/18/88

                 10/18/88


                  OERR/SSED/Site Assntt. Br.
                D DRAFT

                 STATUS:
            [  ]  A- Pending O.MB approval
            [  J  B- Pending AA-OSWER approval
                C- For review &/or comment
                D- In development or circulating

REFERENCE (other documents):       headquarters
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              J
              J
  OS WER       OS WER      OS WER
VE    DIRECTIVE   DIRECTIVE   Dl

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                            united states c.iviror.rrterv.ai ;"":tec::on .
                Wasnmgton. DC 20*60
OSWER Directive Initiation Request
                                                                     9240.0-02
      iName ol Contact Person
                 i Mail Coot
                       Joan Barnes
                                                   OERR/HSED
Teiepncre Coce
      13. •
             "Superfund Analytical Review and Oversight"
      [4. Summary ol Cirective iincuce onet statement of purpose)
        Memorandum that outlines procedures and responsibilities related to review and
        oversight of Superfund analytical data, incorpoating comments from draft memorandum
        of March 18, 1988.
      |5.*eyworos  Superfund, CERCLA, SARA

       Ba. Does This Directive Superseot Previous directives)?


      [ b. Coes It Supplement Previous Oirearve(s)?
                         I No .      Yes   Whit direct** (numoer. true)
                      a
                                            No       YM   What directrvt (numb*, ttfle)
      17. uran
      |  ) A - Signed by AA/OAA    [  j  8 - Signtd by Offlct Dirtelor   [  [ C - For fltvivw A Comment  I   ] 0 - In Otw«opm«nt
            8. Document to be distributed to States by Headquarters?  I  IY"   |  |No
Tnla Request M««u OSWCR Directives System Format Standards.
9.
10
Signature of Lead Office Oirec
t*es Cooramator
Z^JZ4^=>
. Name ana Title ofAoproving Official / /
Steve Linale, Director,
/
HSED Division
Oat*
10/18/88
Oat*
10/18/88
      EPA Form 1315-17 (R«v. S-«7) Previous editions are oosoiete.
   OSWER          OSWER               OSWER              O
VE     DIRECTIVE          DIRECTIVE        DIRECTIVE

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               UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                         WASHINGTON, D.C. 20460
                        AUG I  8 1988
                                                           OFFICE OF
                                                   SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
                                       OSWER Directive 9240.0.03
                                                OvA-slght
SUBJECT:  Superfund Analytical Data Review and

PROM:     Henry L. Longest II, Director
          Office of Emergency and Remedial Rei

TO:       Waste Management Division Directors
          Environmental Services Division Directors
                                                      (OS-200)
PURPOSE;

     This memorandum outlines  procedures  and  responsibilities
related to review and oversight  of  Superfund  analytical data.
It incorporates comments  received on my draft memorandum of
March 18, 1988.

BACKGROUND

     At the February 1988 San  Antonio  meeting,  a number of areas,
Including the data review process,  were identified as  providing
opportunities for streamlining the  RI/PS  process.  This memorandum
responds to these opportunities  by  offering an alternative approach
to data review that we  believe will be successful in streamlining
this important aspect of  the RI/PS  process.   Some Regions have
already 'begun to revise their  approach to data review.  Others
are considering additional steps.

     One further factor that has lead  to  the  approach outlined in
this memorandum is the need that many  of  us perceive to broaden
the quality assurance oversight  role in the Regions to address
areas sucKva* field sampling,  responsible party and State lead
sampling and analysis, and other data  that does not go through the
Contract Laboratory Program.   In addition, there is a continuing
need for closer "up front" involvement of the Environmental
Services Divisions in development of Quality  Assurance Project
Plans (QAPJPs) in order to speed their accurate completion and
approval.
     I have previously requested  that  the  Waste Management and
Environmental Services Divisions  in  each Region work together to

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                             - 2 -                      9240.0.03


 determine how to best get work done that cuts across the divisions
 and who  should do it.  As a result, the process and organization
 used by  each Region to review data vary.  Also, data review is
 currently being conducted to different degrees across the Regions,
 although most are reviewing 100J of the Contract Laboratory
 Program  data.  The measure of success for this approach is an
 absence  of roadblocks in the critical path for site cleanups.

     There are several purposes for reviewing analytical data.
 For Contract Laboratory Program (CLP) Routine Analytical Services,
 review for compliance with contract requirements (e.g., complete-
 ness of  the data package and technical quality assurance measures
 regarding instrument tuning, calibration, etc.) is done by EPA's
 Sample Management Office.  Deficiencies are reported directly to
 laboratories for correction of any problems.  This "Contract
 Compliance Screening (CCS)" process is being fully automated now
 that data are required to be delivered on diskette.  This will
 facilitate self-inspection by laboratories and speed the CCS
 process  so that results are available to the Regions in a matter
 of days.

     This memorandum specifically addresses the review for both
 validity and useability, i.e., "data review," that is carried out
 by the Regions for all analytical data used to support Superfund
 decision-making.

 OBJECTIVES                     '

     0   To streamline analytical support for the RI/PS process
         and other Superfund programs by expediting data review
         and validation.

     0   To satisfy the Superfund quality assurance requirements
         of providing oversight of all Superfund data, including
         responsible party data, State lead data and non-Contract
         Laboratory Program federal lead data.

 IMPLEMENTATION

     In  accordance with the Data Quality Objectives guidance, the
 data user-.li- to establish the objectives for quality that the
 data must meet.  Further, the user should determine the required
 level of assurance, i.e. data review, that the data generated
 actually meet the specified quality.  The data review requirements
 should be stated in the project plan.  The level of data review
 required may vary across projects and within projects based  on
 the decisions to which the data will be applied, site characteris-
 tics,  laboratory considerations and the nature of  the data itself.

     The actual review of the data should be done  by the organiza-
tion that will use the data.  They are best able to set priorities

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                              - 3  -                       9240.0.03
 for the sites to be reviewed,  and  tailor the review to the
 objectives and use  discussed  above.   In the majority of federal
 lead situations this will  be  the field contractor that requested
 the analysis.  The  Region  may  determine the Environmental Services
 Division/Environmental  Services Assistance Team to be the most
 appropriate review  source  in  some  cases such as where there is a
 potential  conflict  of interest.

      In all cases the data should  be  provided to the reviewer
 immediately upon receipt and  should not be held awaiting additional
 information or corrections.   Initial  data packages may be incomplete
 in some cases,  but  often the  incompleteness involves relatively
•minor items that do not effect the review or immediate use of the
 data.   I recommend  that all data packages be provided to the
 reviewing  organization  immediately, allowing the reviewer to
 decide whether to proceed  to  review and use the data..  The Region
 should determine whom it will  designate to most expeditiously
 communicate with the laboratories  regarding any deliverable
 issues consistent with  existing policy to maintain a reasonable
 number of  designated contacts.

      Regional quality assurance personnel should maintain signifi-
 cant responsibilities in this  process.  The Regional QA personnel
 should keep management  informed of the status of the QA program to
 ensure tha_t_:   decisions on the level .of data review are appropriate;
 see that adequate staff resource levels and skills are provided;
 confirm that consistent and high quality reviews are carried out
 based  on the EPA guidelines; and that required tracking, reporting
 and follow-up on data review  results  occurs.  Environmental
 Services Assistance Team (ESAT) resources should be used to
 supplement  these expanded  oversight efforts as appropriate.  This
 expanded oversight  will facilitate maximum use of the increased
 sources  of  data review  available through the Alternative Remedial
 Contracts  and other contracts.

     The March 20,  1986 OSWER  Directive 9240.0-2 regarding Ana-
 lytical  Support for Superfund  emphasized including all analytical
 services in a management system that  provides documented adherence
 to  appropriate  quality  assurance practices and procedures.
 Consistent-with this, Reglonal/ESAT staff should perform similar
 oversight and audit on  the non-CLP data related to federal, State
 and responsible party lead projects,  and audit field sampling and
 analysis*   They also should place  high priority on the development
 of  Quality  Assurance Project Plans.

     A Region may wish  to  make organizational assignments for
 data review and quality assurance  that vary from this approach.
 However, it must meet the  objectives  for all sources of Superfund
 Data outlined in* v.ii. memo.  The Region is responsible for deter-
 mining the  degree to which data review will be done, the process
 and  organization for conducting the reviews and the approach for

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                             - 4 -                      9240.0.03
guidance, training, logistics, auditing and documentation.  Each
Region should develop an approach to implementation and'establish
a timetable that achieves these objectives as soon as possible,
taking the Region's individual circumstances into account.

     In the future, we will issue supplementary guidance to this
memorandum.  This guidance will be developed under the auspices
of the Data Review/Data Useability Workgroup of the Analytical
Services Advisory Committee.  The guidance will address such
areas as linking data quality objectives to the levels of data
review.  Guidance related to the expanded quality assurance
program will also be developed.  In addition, OERR Headquarters
will review the Regions' implementation of this memorandum and
the effectiveness of their data review programs as part of the
Office of Solid Waste and Emergency Response (OSWER) Regional
program evaluations.

     Stephen Lingle, Director of the Hazardous Site Evaluation
Division and Joan Barnes, Chief of the Analytical Operations
Branch are prepared to discuss this with you further.  My staff
is available to assist with this effort upon your request.
                                  i?
Attachment

cc:   Regional Superfund Remedial, Removal and Enforcement
     Branch Chiefs
     Regional Quality Assurance Officers
     Regional Data Review Branch Chiefs
     Office of Waste Programs Enforcement
     Quality Assurance Management Staff
     Office of Regional Operations

bcc:   Hazardous Site Control Division
      Environmental Response Division
     . Duane Geuder, OERR
      Hazardous Site Evaluation Division, Site Assessment Branch

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