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
f
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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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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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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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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