What is the Superfund CLP and How Does it Work?
The Contract Laboratory Program (CLP) works with all 10 EPA regional offices, federal, state and Tribal agencies supporting: Superfund, Brownfields, the Great Lakes National Program, Resource Conservation and Recovery Act (RCRA), and oil programs. Because of our supportive infrastructure, we are able to provide analytical services that are flexible, and cost-effective to a variety of programs.
ASB manages and supports the CLP. The CLP is a national network of EPA personnel, commercial laboratories, and support contractors whose fundamental mission is to provide data of known and documented quality. The CLP supports EPA’s Superfund program, created under the 1980 Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), and currently under the 1986 Superfund Amendments and Reauthorization Act (SARA).
The CLP's primary service is the provision of analytical data of known and documented quality to CLP customers. The CLP provides data through its chemical analytical services, and has implemented supporting services to ensure that data of known and documented quality is provided to CLP users. Because of its supportive infrastructure, the CLP is able to provide all services in a cost-effective and efficient manner.
All analytical services are performed by EPA-approved contract laboratories who meet stringent requirements and standards in order to be a part of the CLP. Each sample processed by the CLP is properly documented to ensure timely and accurate analysis for all requested parameters. This process creates sample data that can be used in potential enforcement actions.
Since the CLP's inception in 1980, more than 180 CLP laboratories have performed over 3,894,000 analyses on samples from more than 21,000 sites at an approximate expense of over $446,400,000. The CLP's commitment to customer service and its ability to meet the changing needs of its customers is shown through the types of analytical services that it offers, the number of samples its laboratories can analyze, and the support services that it provides. The CLP services allow users the option to combine analytical parameters, data turnaround times, and detection limits.
CLP data is used for a variety of purposes such as defining the nature and extent of contamination at Superfund sites, determining appropriate cleanup actions, determining emergency response and remedial actions, and enforcement/litigation activities. The data may also be used in all stages of hazardous waste site investigations including site inspections, Hazardous Ranking System (HRS) scoring, remedial investigation/feasibility studies, and remedial design.
The CLP operates through a network of program participants who manage all aspects of sample scheduling, tracking, analysis, data inspection, and invoice processing and payment. Each sample processed by the CLP is documented for timely, accurate, and complete analysis of requested parameters.
Sample Scheduling and Tracking
CLP analytical services begin when samples are scheduled for analysis. The CLP user requests the samples through the EPA Regional Sample Control Coordinator (RSCC). The samples are collected by regional samplers once a laboratory is assigned. The samples are then shipped to the assigned laboratory after the sample collection process is complete.
When the samples arrive at the assigned laboratory, the sample custodian verifies the receipt and condition of the samples and documents it on the CLP Traffic Report/Chain-of-Custody (TR/COC) form. Unless otherwise directed by EPA, the laboratory proceeds with the sample analyses according to the appropriate CLP statement of work (SOW).
Data Inspection and Contract Compliance
The analytical data must be reviewed by the data user after the laboratory performs the required analyses. The data user reviews the analytical data using the National Functional Guidelines for Data Review to determine whether additional action is necessary. Data users may supplement the data review process with additional review and validation based on user-specific or site-specific concerns.
Laboratories are required to submit their data electronically and in hardcopy. Both electronic and hardcopy data is verified to ensure that the analyses have been performed in accordance with the requirements in the contract. The review results are then delivered to customers via the Internet.
Invoice Processing and Payment
The invoice and payment process provides financial information useful in potential enforcement actions. CLP laboratories submit invoices for payment of the analytical services that they performed for processing and payment.