FASTAC Implementation Strategy

REGION 6 FASTAC IMPLEMENTATION STRATEGY

I. FIELD AND ANALYTICAL SERVICES TEAMING ADVISORY COMMITTEE (FASTAC) LIAISONS

A. Superfund Program

Walt Helmick (6SF)
Quality Assurance Officer
Superfund Division
Phone: (214) 665-8373

B. Research Science and Technology (RS&T)

Marvelyn Humphrey (6MD-HE)
Team Leader, External Laboratory Oversight
Environmental Services Branch
Management Division
Phone: (281) 983-2140

II. REGION 6 ANALYTICAL SERVICES DECISION TREE PROCESS

Available Analytical Services Resources

The Region 6 laboratory is located in Houston, Texas. The Region 6 laboratory is the Environmental Services Branch (ESB). The laboratory is staffed with EPA employees and onsite ESAT contractor employees. The Region utilizes the national Contract Laboratory Program (CLP) as a primary source for analysis of Routine Analytical Services (RAS) samples. Region 6 currently does not have any Region specific analytical services contracts and does not anticipate procuring any in the near future. The Region has seven field contracts which can subcontract for analytical services. The field contracts include two Response Action Contracts (RAC), two Superfund Technical Assessment and Response Team (START) contracts, two Emergency and Rapid Response Services (ERRS) contract, and one Response Action Contract (ROC).

Budget Resources for Analytical Services

Headquarters’ Office of Superfund Remediation and Technology Innovation (OSRTI) funds the national CLP. Therefore, analytical services acquired through this vehicle are considered to be of “no charge” to the Region.

Money to pay for analytical services in the field contracts comes from the Region’s extramural Pipeline Operations Advice of Allowance. It is important for the Region to use the national CLP if at all possible, thereby reducing the drain on the Region’s extramural funds which are needed for many other site activities.

FASTAC Decision Tree for Analytical Services

The following recommended decision tree for analytical services was distributed to the
Regions in a memorandum dated November 17, 1998, and signed by Tim Fields, Office of Solid Waste and Emergency Response, and Betty Bailey, Office of Acquisition Management:

Tier 1 – EPA Regional Laboratory and ESAT Contract
Tier 2 – National Analytical Services Contracts (i.e., CLP)
Tier 3 – Region Specific Analytical Services Contract
Tier 4 - Analytical Services IAGs and Field Contracts/Subcontracts

Region 6 Implementation of Decision Tree

In Region 6, the hierarchy currently consists of Tiers 1, 2, and 4 only. The Regional Sample Control Center (R6SCC) is located in the Environmental Services Branch at the regional laboratory in Houston. The R6SCC is the group responsible for scheduling samples through the Region 6 laboratory/ESAT or the CLP.

To ensure that the users know what analytical services are available through the Region 6 Laboratory/ESAT and the CLP, tables of all current services are posted on the internet at the Region 6 Laboratory web page. The user contacts the R6SCC or consults/reviews the analytical services tables to determine whether his/her samples can be processed by the Regional laboratory/ESAT or CLP.

If the user determines, after reviewing the (internet) tables, that the samples can be processed through the Region 6 laboratory/ ESAT or the CLP, the user must contact Christy Warren, of the Region 6 Sample Control Center. If the user determines that the samples cannot go through the Region 6 laboratory/ESAT or the CLP, the user will utilize the appropriate field contract. If the user is unsure of the most appropriate analytical service to use, the R6SCC may be contacted for guidance.

Of the analytical services requests that go to the R6SCC, the laboratory is given the right of first refusal. The R6SCC determines if the regional laboratory has the capability and capacity to analyze the samples. Assuming the laboratory has the capability and capacity, the R6SCC will accept the samples. If the laboratory declines the samples, the R6SCC determines if the samples are CLP appropriate. If CLP appropriate, the R6SCC notifies the user and submits the analytical request forms to the CLP RSCC. If samples can be analyzed by ESAT, the R6SCC in coordination with laboratory team leaders determines which samples will be analyzed, and ESAT is notified. If samples cannot be processed through the Region 6 laboratory/ESAT or CLP, the user is notified and he/she will proceed with the field contracts option.

To document and track the samples not processed through the R6SCC (Special Analytical Services [SAS]), field contractors are required to provide analytical services information for Non-CLP work to the Analytical Services Tracking System (ANSETS). There are three major methods of submitting ANSETS data. Links to these methods, including a description and instructions are provided at http://www.epa.gov/superfund/programs/clp/ansets.htm

Contractors will submit the ANSETS information to the Project Officers of the individual contractor and to HQs via the EPA website listed above. The Superfund Division FASTAC representative and the Houston Laboratory (ESB) FASTAC representative will meet quarterly to discuss whether the samples analyzed through the field contracts could have been analyzed through Tier 1 (Regional Laboratory/ESAT) or Tier 2 (CLP) of the FASTAC Decision Tree.

If it appears Region 6 has a problem with RAS samples going to the non-CLP contracts, the Superfund and Houston Laboratory FASTAC representatives will elevate the problem to their management and will convene a meeting to determine what corrective action should be taken.

Field Contracts

Under the RACs contracts, each contract was modified to incorporate into the contract language an analytical services delivery (ASD) plan. These plans set out the procedures for obtaining analytical services for RAC work assignments. The plans say that generally under RAC, the Houston laboratory or the CLP will perform RAS analyses and the contractor-procured laboratories would perform SAS analyses. However, when neither the Houston laboratory or a CLP laboratory is available to perform required RAS analyses, the contractor will need to procure a subcontractor laboratory to perform those analyses. If the Houston laboratory or a CLP laboratory cannot perform the required analytical services, the EPA project manager will meet with the contractor to determine the best method of procuring the necessary analytical services.

The majority of the SAS samples are processed through the START contract. The START contract supports the Removal and Site Assessment programs. Most of the Site Assessment samples go through the CLP. Most if not all of the Removal samples require a shorter turnaround time than is currently available through the laboratory or the CLP. Region 6 has not been using the ESS contract much for analytical services. Region 6 has also not used the zone ROC contract much since its award. The analytical services provided under the ERRS contract is generally for determining where waste can be taken for disposal.

III. TRAINING

Personnel of the Houston Environmental Services Branch conduct training sessions to explain the hierarchy to Superfund personnel (and their contractors) on an annual basis.