UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
SOLID WASTE AND EMERGENCY
RESPONSE
MEMORANDUM
Directive # 9240.0-2C
November 14,2002
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
Internet Address (URL) • http://www.apa.gov
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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:
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
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submit the export file electronically via the Internet.
4 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 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/cip/ansets.htm.
Suggested Contract Language for EPA Contracts. Cooperative Agreements, and
Interaqency 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-tead 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
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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
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United States
Environmental Protection
Date:
Please see ANSETS Website for Current List of Required Data
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:
Responsible
EPA Project Individual:
Operable Unit:
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:
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