United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
SEPA
DIRECTIVE NUMBER: 9240.0-2
TITLE: Analytical Support for Superfund
APPROVAL DATE: 3/20/86
EFFECTIVE DATE: 3/20/86
ORIGINATING OFFICE: QERP
S FINAL
D DRAFT
*
STATUS:
REFERENCE (other documents):
OS WE Ft OSWER OSWER
F DIRECTIVE DIRECTIVE Dl
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&EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9240.0-2
TITLE: Analytical Support for Superfund
APPROVAL DATE: 3/20/86
EFFECTIVE DATE: 3/2o/86
ORIGINATING OFFICE: QERR
S FINAL
D DRAFT
STATUS:
REFERENCE (other documents):
OSWER OSWER OSWER
-------
>>EPA
United States Environmental Protection Agency
Washington. DC 20460
OSWER Directive initiation Request
Interim Directive Number
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Originator Information
Name
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Approved for Review
Signature of Office Director
Date
Title
Analytical Support for Superfund
Summary of Directive
A review of alternative Superfund sample analysis resources (CLP,
BSD, REM, FIT, TAT, ERGS, AND ESAT).
General guidance regarding the use of the analysis resource given
above.
Request that each Region manage and monitor the use of said
resources via an integrated management and tracking systems which
provides for:
1. a site project manager accountable for specifying project needs.
2. an interface with the lab services of the BSD and the CLP.
3. a planning and scheduling function.
4. maintenance of a data base which includes sample sources, where
sent, turnaround times, cost and QA.
5. documented adherence to QA practices.
'ype of Directive (Manual. Policy Directive. Announcement, etc.)
Policy and Procedural Guidance*
Status
CD Draft
|X] Fin^l
H New
1 — 1 Revision
Does this Directive Supersede Previous Directives)? (| Yes
f "Yes" to Either Question. What Directive {number, title)
No Doe's It Supplement Previous Directive^)? | j Yes | -X| No
eview Plan
O AA-OSWER Q OUST
D OERR D OWPE
Q OSW LJ Regions
OECM
D OGC
D OPPE
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Other (Specify)
his Requejtjyieets OSWER Directives System Format
ignature of Lekdydffice 0)*«ctiy,
„
ignature of OSWER Directives Officer
Date
Date
EPA Form 1315-17(10-85)
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
20
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
SUBJECT: Analytical Support for Superfund
FROM: Henry L. Longest II, Director
Office of Emergency and Remedi
nse
TO: Waste Management Division Directors
Regions I - X
Environmental Services Division Directors
Regions I, VI, and VII
The purposes of this memorandum are:
0 to review the a-lternative Superfund sample analysis resources
that are available to you;
0 to provide some general guidance regarding the use of these
resources; and
0 to request that each Region manage and monitor the use of
these resources.
The two principal sources of Superfund program analytical
support have been the Regional laboratories and the Contract
Laboratory Program (CLP). Additional contractor sources are
Remedial (REM), Field Investigation Teams (FIT), Technical
Assistance Teams (TAT) or Emergency Response Cleanup Services
(ERGS) and their subcontractors, and the Environmental Services
Assistance Teams (ESAT) Program. ESAT is currently being devel-
oped to supplement the Regional laboratory staffing levels with
contractor employees. We expect to have the ESAT contracts
awarded and operational before the end of the first quarter in
FY '87.
As a general rule, the Regional labs should be used to
analyze samples where responsiveness and flexibility are para-
mount requirements. Analyses requiring quick response, methodo-
logy fine-tuning, and close interaction between the analyst and
the data user are best done in Regional labs. In ?Y '86, we are
using a total of 109 EPA work years to analyze samples, review
data, and manage sample workload in support of Superfund activi-
ties. In FY "87, we willr"supplement EPA resources with 100 ESAT
work years.
OSWER Directive No. 9240.0-2
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The CLP is the laboratory service that should be used for
routine high volume sample analysis requiring consistency of
methodology, 30 to 40 day turn-around times, and data of known
and documented quality. Faster turn-around times can be obtained
by using the Special Analytical Services (SAS) option of the
CLP. SAS can also be used to analyze unusual matrices with
non-standard methodology. In addition, SAS has frequently been
used to enhance routine CLP analyses by incorporating a desired
method or parameter change consistently across an analytical
case. In FY '85, the CLP analyzed 70,400 samples at a total
analysis cost of $32,998,143. The CLP will be able to analyze
over 80,000 samples in FY '87. It should be viewed as your
primary resource for the above described services.
The analytical resources available from the remedial and
removal contractors include both fixed laboratory support, and
mobile laboratories and portable instruments for use in the
field. The amount of support available from these sources is
limited when compared to the CL^ and must be effectively managed.
Attached are descriptions of emergency response removal, remedial
and enforcement program needs and some suggestions on how the
remedial/removal contractor resources can be used to supplement
the CLP and BSD activities.
The choice of which analytical service to use should be
driven by the data requirements of each program activity. The
Regional laboratories and the CLP have well established and
recognized Quality Assurance programs. However, whenever they
cannot meet program requirements, you may use the other contract-
ing modes at your disposal as long as you assure that basic
requirements are met. In particular, you should be sensitive to
costs, to clear definition of work, to enforcement needs, and to
quality assurance requirements.
Careful management of analytical support services is import-
ant because of the large commitment of both FTE and dollar re-
sources to this effort. The need for good Regional management and
coordination was emphasized in the May 17, 1985 report of the
Superfund Laboratory Services Management Review Group established
by the Administrator. Although several Regions have already
taken important initiatives in this area, I want to emphasize the
importance of including all analytical services in this manage-
ment system. Specifically, I believe that it is essential that
each Region have an integrated management and tracking system
that meets the following requirements as a minimum:
1. Site project manager accountability for specifying project
needs and acquiring appropriate analytical services for the
project.
OSWER Directive No. 9240.0-2
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2. A point of interface with the laboratory services of the ESO
and CLP that can inform the project manager of the avail-
ability of these services and schedule sample analysis.
3. A planning and scheduling function closely linked to the
overall site planning process and that will provide accurate
projections of analytical needs and close week-to-week program
contact on scheduled and actual sample shipments.
4. Maintenance of a data base to monitor costs and schedules for
remedial, removal, and enforcement samples. At a minimum
these data should include:
0 records on where samples were sent for analysis, i.e., ESD
lab, CLP, or other (e.g., remedial or removal) contractor
lab; this should be keyed to the source of the samples.
0 data on turn-around times, cost, and QA requirements for
samples not analyzed through the CLP.
5. Documented adhe'rence to appropriate quality assurance
practices and procedures.
I believe it should be each Region's choice as to what
organizational units should provide these integrated management
functions. My concern is simply that the functions exist in each
Region and that they have the ability to both manage the process
and provide useful information to Regional and Headquarters
managers.
Attachment
cc: Environmental Services Division Directors
Regions II, III, IV, v, VIII, IX, and X
Carol Finch
Office of Regional Operations
Gene Lucero
Office of Waste Programs and Enforcement
OSWER Directive No. 9240.0-2
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REMEDIAL PROGRAM ANALYTICAL REQUIREMENTS
The primary requirement for analytical support under the remedial propram
is the RI/FS. Specific requirements include a variety of analytical techniques
and protocols tailored towards site specific requirements for quantity,
quality, timeliness and coot. Four key phases of analytical support have been
identified within the RI/FS process:
PHASE JL: INITIAL CHARACTERIZATION— The first phase is the up-front
field analysis to characterize the problems at the site and the probable extent
of contamination. The key requirements of this phase are the ability to take a
fairly large number of samples and perform the analyses quickly and
Inexpensively. This may be accomplished through portable field instruments and
mobile laboratories operated by the remedial contractors. The information
provided by this process is used to design the second phase of sampling.
PHASE 2- DETAILED SITE SAMPLIN6— The second phase entails a more
focused sampling to accurately define the extent of contamination. This
information is used during the feasibility study to support the development and
evaluation of alternative remedial actions, and during the ROD process to
support key decisions on the appropriate extent of remedy and selection of the
cost effective remedy. Therefore, QA/QC requirements are essential. The
primary analytical resource for this phase is the CLP, with judicious use of
ESD or remedial contractor laboratories to meet special program requirements.
PHASE 2^ FILLING JJN DATA GAPS— The third phase is best characterized
as "filling in" the data gaps identified during the feasibility study. These
are normally highly focused samples designed to answer particular questions
regarding the analysis of alternatives or determining the extent of remedy.
Quick turn-around is a key concern for these analyses to avoid delaying the
completion of the projects however, data quality must be commensurate with the
intended use of the data in the decision-making process. Sources available for
these analyses include the remedial contractor in-house laboratories, special
analytical services under the CLP, and the ESD lab.
PHASE &z PROJECT ENGINEERING-- The fourth phase involves special
analyses to support bench and pilot scale testing and treatability studies to
assess the technical performance of a particular technology or to provide
engineering data for remedial design. Normally, this work is done by the
remedial contractors.
Two efforts are currently underway which should better define these
requirements. The first is the development of Data Quality Objectives
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ANALYTICAL REQUIREMENTS OF THE EMERGENCY RESPONSE PROGRAM
The emergency response program requires analytical services throughout the
response process. Phases of an emergency or removal action that may require
analytical support include: 1) preliminary assessment to determine whether an
emergency response is appropriate; 2) site investigation, including verification of
the identity, concentration, and/or location of hazardous substances, including data
to support selection of the appropriate removal action; 3) proper disposal of
contaminated materials; and 4) verification that the removal action was effective,
including site samples to determine full cleanup and long-term monitoring. Each of
these activities requires that the Region specify the analytical needs consistent with
the incident to be addressed. Considerations include analytical services, turnaround
time, quality assurance (QA), and cost (see table below). These considerations can
vary by the phase of the response, and whether the incident is a clear-cut,
time-critical emergency or a removal action where timeliness is needed, but not
critical.
Generally, either TAT or ERCS obtains analytical services with the approval of
the OSC. Use of CLP Routine Analytical Services (RAS) is generally inappropriate if
turnaround times of less than 30 days are required. However, CLP Special Analytical
Services (SAS) may be able to provide turnaround times of 14 days or less if special
requests are submitted. Support from Regional or State laboratories also should be
considered. Regional laboratories may be able to provide cost-effective, rapid
analyses through the ESAT program. When the CLP or Regional laboratory mechanisms are
not utilized, TAT obtains laboratory support through TAT Special Projects. ERCS
contractors often rely on OSC or TAT recommendations, or in some cases, access private
laboratories based on pre-existing verbal arrangements.
CONSIDERATIONS FOR REMOVAL PROGRAM ANALYTICAL NEEDS
(Importance of Time, QA, and Cost)
Preliminary
Assessment For
Emergency Response
II
Site
Investigation
III
Disposal
Screen
IV
Verification/ *
Monitoring
Time
QA
High, particularly
if acute threat of
human exposure to
high-hazard sub-
stances.
Medium. Need
usable data, but
not high QA at
expense of timeli
ness.
Cost Low. Other
considerations are
more important in
a suspected
emergency.
OSWEK Directive No. 9240.0-2
Medium. Reason-
able turnaround
time needed for
removal decision
process.
High. Need ver-
ifiable data to
make removal
decisions, doc-
ument for cost
recovery.
Medium. Stan-
dard analyses
and medium time
frame allow more
cost considera-
tion.
Medium.
Reasonable
turnaround
time needed
to proceed
with removal
action and
disposal.
Medium.
Data quality
does not need
to be high
for waste
compatibility
and disposal.
High. Stan-
dard analyses
and medium
time frame
al low more
cost consid-
eration.
Medium/Low.
Verification of
cleanup duri ng
and after re-
moval requires
better turn-
around time
than does long-
term moni tori ny,
Medium. Need
usable data,
but not high
QA at expense
of cost con-
siderations.
High. Stan-
dard analysis
and longer
time frame
al 1 ow more
cost consid-
eration.
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ENFORCEMENT ANALYTICAL REQUIREMENTS
The enforcement analytical needs fall into two categories:
1) RI/FS and 2) case support. The majority of the analytical
needs for enforcement are for RI/FS on enforcement lead sites.
Since these studies are being done by the same contractors who
conduct RI/FS for Fund lead sites, the remedial program analytical
requirements also apply to these studies. For the second category,
civil case support, analytical needs can arise long after the
RI/FS is completed and limited data are needed to support a file
case. In this instance the preference is to utilize the Regional
and other EPA laboraories. However, each Region should decide on
a case-by-case basis how to manage its resources, and judicious
use of CLP and other contractor analytical services may be neces-
sary. For those sites where samples are taken for criminal case
support, only EPA laboratories should be used.
OSWER Directive No. 9240.0-2
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