<£D S7»,
a
a
\
 s
 I
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
              WASHINGTON, D.C. 20460
                                           •1  -2010
                                                                             OFFICE OF
                                                                           SOLID WASTE AND
                                                                         EMERGENCY RESPONSE

                                                         OSWER Directive No. 9200.1-103
  MEMORANDUM
  SUBJECT:

  FROM:


  TO:


  Purpose
     Inclusion of Scribe into the Role of Tracking Superfund Sampling Data
     James E. Woolford, Director
     Office of Superfund Remedial
                                 :hnology Innovation
     Superfund National Policy Managers, Regions 1-10
     Regional Science and Technology Directors
         The purpose of this directive is to add Scribe as an additional sample tracking software
  tool for use for the Contract Laboratory Program (CLP).  This directive shall be a companion
  document with OSWER Directive 9240.0-38 (FORMS II Lite™ Role in Tracking Superfund
  Sampling Data) and Directive 9240.0-2C (Tracking Superfund Non-CLP Analytical Data).
         In OSWER Directive 9240.0-38, FORMS II Lite™ is identified as the mandatory sample
  tracking system for use with CLP samples. This directive shall establish that Scribe or FORMS II
  Lite™ sample tracking tools can be used for both CLP and CLP Non-Routine Analytical
  Services (CLP-NRAS) sampiing activities. The Scribe tool provides end-users with multiple
  features for managing environmental data. Scribe will be phased into the Superfund CLP and
  CLP-NRAS sampling activities by January 1, 2011.  Ultimately, FORMS II Lite™ will be
  phased out of those programs,  OSRTI plans to disinvest from further upgrades to the FORMS II
  Lite1M software.
         The background of Scribe, suggested language and requirements for EPA contracts,
  Interagency Agreements, and Cooperative Agreements, status of software and training
  opportunities, and implementation are provided below.

  Background

         Scribe is a software tool developed by the USEPA's Environmental Response Team
  (KRT) to assist in the process of managing environmental data.  Specifically, Scribe:
                                  Internet Address (URL) • http://wwwepa.gov
           Recycled/Recyclable • Primed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper

-------
«  captures sampling, observational, and monitoring field data (e.g., field tasks which include
   Soil Sampling, Water Sampling, Air Sampling and Biota Sampling);

*  provides import capabilities for electronic data including Analytical Lab Result data
   (Electronic Data Deliverable) and Sampling Location data such as global positioning system
   coordinates;

*  supports handheld extensions, Scriblets, to capture and import sampling and monitoring data
   collected on handheld personal digital assistants (PDAs);

•  generates and prints documentation (e.g., bottle labels, Traffic Reports/Chain of Custody,
   Analytical Lab Result data reports);

•  supports exporting electronic data for user services such as geographic information system
   tools and spreadsheets so sampling data may be further analyzed and incorporated into report
   writing and deliverabies; and

•  supports the Staged Electronic Data Deliverable (SEDD) Stage I electronic analytical result
   data, FORMS II Lite™, and the Region 5 Rapid Assessment Tool (RAT).

 Attachment 1 provides a summary of Scribe software and hardware requirements.

Suggested Language and Requirements for EPA Contracts, Interagency Agreements, and
Cooperative Agreements

       Attachment 2 and OSWER Directive 9420.0-38 provide additional details and suggested
language to modify EPA contracts and Interagency Agreements. Amendments to cooperative
agreements with the States and Tribes may be required to address the incorporation of the Scribe
requirement or to purchase equipment. Amendments to Interagency Agreements with federal
facilities for EPA-lead sites may also be needed. The language is provided to establish national
consistency in overseeing sampling activities.  Each region needs to amend its major assessment
and response contracts (e.g., Remedial Action Contracts (RACs),  Superfund Technical
Assessment and Response Team (START) that provide sampling  services.  In addition, regional
modifications may be necessary to accommodate region-specific needs.  Contractors shall
provide the equipment and software necessary to operate Scribe and/or FORMS II Lite™.

       Effective January 1, 2011, the contractors performing sampling work for the CLP and
CLP-NRAS shall be required to use either Scribe or FORMS II Liter  to manage sample
collection, documentation, and submission of all relevant reports.  The samplers shall also submit
electronic traffic reports/chain-of-custody to the Sample Management Office (SMO) to automate
the sample tracking process. Exceptions to the January 1, 2011 requirement should be rare (our
goal is 100% use of either Scribe or FORMS II Lite™ usage for the CLP) but can be waived by
the Regional Sample Control Center Coordinator (RSCC) or another regional designee who is
most familiar with the sampling activities.  The region may also institute special procedures to
handle situations when the use of Scribe  or FORMS II Lite™ is not practical. Headquarters does
not need to approve individual waivers or the waiver process.  Examples of acceptable waivers

-------
include small businesses conducting very limited sampling for one site such as at Brownfield
sites, and substantial breakdown of equipment such as laptops, printers, or other related
equipment. The RSCC should coordinate with the Project Officer and/or Contracting Officer if
there is a trend in equipment problems or to address penalties for non-compliance, as
appropriate. The region will be responsible for determining alternative tracking procedures for
sites that are waived from using either Scribe or FORMS II Lite™.

       States and Tribes accessing the CLP or using CLP-NRAS services for analyses should
comply with the implementation date as well.  However, each region can use their judgment on
whether certain States and/or Tribes need special accommodations or an extension of the
deadline. Potentially responsible parties have the option of using either Scribe or FORMS II
Lite1M, unless the samples (e.g., split samples) are being analyzed by EPA contractors. The
Scribe and FORMS II Lite™ software can be downloaded at the following web  sites:

Scribe:  http://v\ .- » _•'.>' i;y >r  * ±s-_?, -'x_.'i > ne nbn
FORMS II Lite™: jj^  \\ :_:_-'"  -j __ ^rvifrnJ r»_..y_ns ^"  : ' _ n-

Status of Software and Training

       Scribe and FORMS II Lite1M software and training are offered at no cost to EPA
personnel, EPA contractors conducting Superfund work, the States and Tribes. Scribe will
continue to be upgraded to meet customer needs.  However, there are no plans for further
upgrades of FORMS II Lite™  Samplers in all the regions and some states have been trained by
OSRTI and additional training requests will be honored based upon available funding. Training
is also provided via computer-based and web-based systems, a self-help web site, and the Scribe
and FORMS II Lite1M help desks.  Training can be requested via the RSCCs or by directly
contacting Joseph Schaefer at 732-906-6920 {Schaefcr.Joseptva.epa.gov) for Scribe and Eric
Reynolds at 703-603-9928 (Reynolds. Hric>g'epa.gov) for FORMS II Lite™.

Implementation

       Regional Contracting Officers and Project Officers must amend their assessment and
response contracts to  address Scribe requirements. Site project managers must also ensure that
sampling contractors  use either Scribe or FORMS II Lite™, RSCCs or other appropriate staff
overseeing sampling activities must work closely with site managers to ensure sampling
contractors comply with these requirements,  OSRTI will provide quarterly updates to the
regions on which samplers have been trained and are using Scribe or FORMS II Lite™ for CLP
samples. As an effort in eliminating duplication and based upon funding. OSRTI will evaluate
the need for both sample tracking tools with potential emphasis on whether or not to continue
support of the FORMS II Lite™^

       Thank you for your cooperation in deploying the Scribe tool requirement for sample
tracking. Please direct any questions to Eric Reynolds of my staff at 703-603-9928 or
Reynolds. Eric@epa.gov.  For technical questions related to Scribe, contact Joe Schaefer at 732-
906-6920 or Schaefer.Joe@epa.gov.

-------
Attachments

cc:  Mathy Stanislaus, OSWER
    Barry Breen, OSWER
    Lisa Feldt, OSWER
    Renee Wynn, OSWER/OPM
    Dana  Tulis, OSWER/OEM
    Suzanne Rudzinski, ORCR     ,
    David R. Lloyd, OSWER/OBLR
    Reginald Cheatham, OSWER/FFRRO
    Carolyn Hoskinson, OSWER/OUST '
    Elliott Gilberg, OECA/OSRE             „
    David Kling, OECA/FFEO
    John Michaud, OGC/SWRELO  -
    OSRTI Managers
    Chloe Metz, Superfund Lead Region Coordinator, US EPA Region 2
    NARPM Co-Chairs

-------
                                ATTACHMENTl
              Summary of Scribe Software and Hardware Requirements

Scribe Minimum System Requirements

Recommended minimum configuration requirements for the user's system are as follows:
•  Windows XP or higher;
•  Microsoft Internet Explorer 6.x or higher;   ,
«  300 MHz Pentium processor;
•  128 MB RAM;
•  200MB available hard disk space;
•  800x600 resolution using small fonts; and
«  Mouse interface, printer, and remote power sources for field use.

-------
                                  ATTACHMENTS
    Suggested Language for EPA Contracts, Interagency Agreements, and Cooperative
                                      Agreements

       The contractor shall be required to use EPA's field sample tracking software tools. Field
                                         -  "             'V\A
Operations and Records Management System (FORMS II Lite  ) or Scribe, to manage the
sample collection, documentation and submission of all relevant reports for Contract Laboratory
Program (CLP) and CLP Non-Routine Analytical Services (CLP-NRAS) activities by January 1,
2011. The contractor shall provide the equipment (e.g., laptops, portable printers) and software
(e.g.. Internet Explorer) necessary to operate FORMS II Lite   or Scribe.  EPA will  provide
FORMS II Lite™ and Scribe software tools and training at no charge to the contractor.
Exceptions to this requirement will be waived by the Regional Sample Control Center
Coordinator (RSCC) or another regional designee who is most familiar with the sampling
activities.1 The region may also institute special procedures to handle situations when the use of
FORMS II Lite1M or Scribe is not practical. Examples of acceptable waivers include small
businesses conducting very limited sampling for one site  such as at Brownfield sites, emergency
response situations, and substantial breakdown of equipment such as laptops, printers, or other
related equipment.

       The contractor shall use the FORMS II Lite1M or Scribe software tools to generate and
submit traffic reports (also known as a Chain-of-Custody form) in accordance with established
regional guidance. For CLP services, the samplers shall also submit electronic traffic reports to
the Sample Management Office to automate the sample tracking process. The extensible mark-
up language (XML) electronic traffic reports can be submitted via the Internet.  Exact procedures
and instructions on how to submit electronic traffic reports are available on the Office of
Superfund Remediation and Technology Innovations CLP web page
       1 Please include an EPA point of contact and telephone number if possible in the modified contract
 language. Regional penalties, if instituted, would need to be stated as well.

-------