UNITED  STATES  ENVIRONMENTAL  PROTECTION AGENCY
            1                      WASHINGTON,  B.C.   20460
            o
                                                                     OFFICE OP
                                                              SOLID WASTE AND EMERGENCY
                                                                      RESPONSE
                                 Directive #  9240.0-2C
                                                                 November 14, 2002
MEMORANDUM
SUBJECT: Tracking Superfund Non-CLP Analytical Data

FROM:     Michael B. Cook//ss// Michael B. Cook
            Director, Office of Emergency and Remedial Response

TO:         Superfund National Program Policy Managers
            Regional Science and Technology Division Directors
Purpose

       This directive reinforces the requirement for nationally tracking non-Contract Laboratory
Program (CLP) analytical services and supersedes OSWER Directives 9240.0-2A and 2B.  The
prior directives established the Analytical Services Tracking System (ANSETS) as a tracking
system for non-CLP data, since the CLP already had extensive tracking procedures in place.  It
is still a requirement to submit data to ANSETS. However, the focus is primarily on tracking
analytical data generated via EPA field contractors and their subcontractors at federal fund lead
sites and at sites where  EPA is the lead agency overseeing a federal facility cleanup under an
Interagency Agreement.  To aid in ANSETS data submission, the system has been updated, the
reporting elements have been reduced, and various options (including FORMS II Lite™) are
available to submit the required data. (See the FORMS II Lite™ Companion Directive  # 9420.0-
38 for additional details). Since ANSETS is not considered a self-reporting quality assurance
tool, the EPA Regions need to provide this function. The Office of Emergency and Remedial
Response (OERR) is also developing electronic tools to facilitate data review for non-CLP data.

The Importance of ANSETS

       The Superfund program requires analytical data for critical decision making. Analytical
data is used to demonstrate the nature and extent of contamination at hazardous waste sites, to
assess response priorities based  on risks to human health and the environment, to establish
appropriate cleanup actions, and to determine the completion of remedial actions. The
generation of technically sound and legally defensible data is of primary importance to
Superfund for site decisions as well as to support enforcement actions and cost recovery.  It is
equally essential that the Regions ensure the appropriate quality assurance for analytical data
and select the most cost effective contract vehicle.

       The Field and Analytical Services Teaming Advisory Committee (FASTAC), which is
comprised of managers from OERR, the Regional Science and Technology (RS&T) Divisions,

-------
and the Regional Superfund Divisions, established a decision tree for selecting analytical
services. In general, the RS&T Division laboratories (i.e., Tier 1) are the preferred option for
special analytical services while the CLP (i.e., Tier 2) is the preferred option for routine
analytical services. Region-specific analytical services contracts comprise Tier 3. The least
preferred option (i.e..Tier 4) for obtaining analytical services is using subcontractors via field
contracts such as Response Action Contracts (RACS), Superfund Technical Assessment and
Response Team (START), Emergency and Rapid Response Services (ERRS), and other
headquarters or regional contracts. EPA's concerns with Tier 4 include lack of direct oversight
of these contractors, quality assurance potentially not meeting EPA standards, and often higher
costs.  By requiring contractors to use the ANSETS tracking system, the Superfund program
can determine whether the FASTAC strategy is being implemented, analyze trends in new
services needed, track national laboratory analyses acquired for the Superfund program, and
plan for quality assurance oversight.

Scope of ANSETS Requirements

       Although the majority of the Regions are submitting ANSETS data, there appears to be
under-reporting, and not all contractors are complying with the requirement.  This new Directive
is aimed at  reinvigorating analytical services information collection from all EPA field contractors
(e.g., RACS, START, ERRS) and their subcontractors at federal fund lead sites and at sites
where EPA is the lead agency overseeing federal facility cleanups under an Interagency
Agreement  (i.e., Tier 4).

       RS&T Division laboratories (i.e., Tier 1) do not need to comply with the ANSETS
requirements.  The Regions have the option of reporting data generated from their Region-
specific analytical services contracts (i.e., Tier 3).

       State-funded sites and Potentially Responsible Parties (PRPs) do not need to  comply
with ANSETS data submission, although regional management should establish  (or continue)
regional systems to track and oversee PRP analytical services.  Tracking PRP data is an
important step  to take, especially in light of past problems with potentially fraudulent data and
difficulty in tracking down affected sites.

Procedures for Submitting ANSETS Data

       The Regions should use their discretion to determine the most appropriate steps needed
to fulfill the  ANSETS data submission requirement. There are four major mechanisms to submit
ANSETS data to OERR:


*     FORMS II Lite™ (preferred) - FORMS II Lite™ automates sampling field documentation
       and exports the data electronically. The export file from FORMS II Lite™  captures the
       essential ANSETS data and is the most direct and effective method to meet the
       ANSETS requirements.  Samplers can use FORMS II Lite™ for sampling  events and to
       submit the export file electronically via the Internet.

*     Web-Based Submission Form - Contractors can submit the ANSETS data by
       completing the web-based form and submitting the  data via the  Internet.

*     ANSETS Standalone Desktop Application- Contractors submit data to the Regions. The
       Regions use the desktop application to manage and submit the ANSETS data to OERR.

*     Batch submissions - Contractors submit data to Regional tracking systems. The
       Regions then batch the data and provide it bi-monthly to OERR.

       Detailed instructions and procedures for submitting ANSETS data can be found at:
       http://www.epa.gov/superfund/programs/clp/ansets.htm.

-------
Suggested Contract Language for EPA Contracts. Cooperative Agreements, and
Interagencv Agreements

      Attachment 1  provides additional details and suggested language to modify EPA
contracts, Cooperative Agreements, and Interagency Agreements. Attachment 2 lists the
required data for ANSETS submission. Amendments to State cooperative agreements and
federal facility interagency agreements for EPA-lead cleanups may also be required. Each
Region should amend its major assessment and response contracts (e.g., RACS, START,
ERRS) that provide analytical services to ensure the ANSETS requirements can be met.
Regional modifications may be needed to accommodate Region-specific needs. In instances
where FORMS II Lite™ will be used to meet the ANSETS requirement, contractors shall provide
the equipment necessary to operate FORMS II Lite™.  Contract language for the FORMS II
Lite™ requirement and information on the software and training can be found in Directive #
9420.0-38. OERR recommends the contract amendments for the FORMS II Lite™ and
ANSETS requirements be made at the same time. The ANSETS requirements should be in
place by January 1, 2003.

Next Steps

      Regional Contracting Officers and Project Officers will need to amend their assessment
and response contracts to reinforce the ANSETS analytical services tracking requirements.
Regions need to designate a person to serve at the ANSETS liaison with Headquarters to
ensure compliance.  The Regional ANSETS liaison needs to work closely with site managers to
ensure the analytical contractors are reporting data to ANSETS.  Please send the name of the
ANSETS liaison to Dana Tulis by December 10, 2002. OERR will continue to  provide summary
ANSETS reports to the Regions every two months.

      Thank you for your cooperation in improving compliance with the ANSETS requirement.
Please call Dana Tulis at 703-603-8993 for general policy issues and Willie Wong at 703-603-
8846 for technical questions.

Attachments

CC:
Field and Analytical Services Teaming Advisory Committee
Superfund Senior Regional Management and Acquisition Council
Regional Lab Directors
Regional Quality Assurance Managers
CLP Project Officers
Regional Sample Control Center Coordinators
RACs, START, ERRS Contract Officers/Project Officers
OERR Senior Management Team

-------
                                 ATTACHMENT 1
   Suggested Language for EPA Contracts, Cooperative Agreements, and Interagency
                                   Agreements

The Contractor shall be required to complete and submit bi-monthly (i.e., every 2 months) Non-
CLP Superfund Analytical Services Tracking System (ANSETSJ data for analytical work that is
performed by a contractor or subcontractor at mobile or in-house laboratories. Waste disposal
profile data and qualitative field screening data are exempt from this requirement.1

The Contractor can fulfill the ANSETS requirement by one of the following mechanisms:

4     FORMS II Lite™ (preferred) - FORMS II Lite™ automates sampling field documentation
      and exports the data electronically. The export file from FORMS II Lite™ captures the
      essential ANSETS data and is the most direct and effective method to meet the
      ANSETS requirements.  Samplers can use FORMS II Lite™ for sampling events and to
      submit the export file electronically via the Internet.

•     Web-Based Submission Form - Contractors can submit the ANSETS data by completing
      the web-based form  and submitting the data via the Internet.

4     ANSETS Standalone Desktop Application- Contractors submit data to the Regions. The
      Regions use the desktop application to manage and submit the ANSETS data bi-
      monthly to the Office of Emergency and Remedial Response.

4     Batch Submissions - Contractors submit data to Regional tracking systems.  The
      Regions then batch the data and provide it bi-monthly to OERR.

      Detailed instructions on submitting ANSETS data are provided at the following web
address: http://www.epa.gov/superfund/programs/clp/ansets.htm.  The Contractor will utilize
this web page for guidance and for updates of future changes to the non-CLP tracking
requirements.
      1   Regions have the discretion of collecting quantitative or semi-quantitative field
screening data, and will need to modify their contracts accordingly.

-------
     United States
     Environmental Protection
Date:
                        Attachment 2 - ANSETS Data Requirement
                                  (List of Required Data )
Sampling Start Date:
Sampling End Date:
Project Numbers
Project
Number:
Regional Account DAS Assoc.
Number: Number: CLP Case No:
Site Information
Site Name:
CERCLIS ID:

Operable Unit:
Responsible
EPA Project Individual:

City:
Action:

State:
Funding Lead:
Sampling
Organization:
Analytical Services Information
If field analytical services are used during this project write "field
analysis" in the Laboratory Name Column. If fixed laboratory is used
write the name of the laboratory in the Laboratory Name Column. Please
specify in this box all field analytical techniques used.

Laboratory Name (include
location if multiple lab locations)















No.
Samples















Completed by:
Matrix
















COST:

Analysis















Organization:
Requested
Turnaround (Days)















Date:
07/17/2000
                                        verl.O

-------