, united states environmental protection agency …

, UNITED STATES ENVIRONMENTAL PROTECTION AGENCY<i REGION III

w] 841 Chestnut Building'* Philadelphia, Pennsylvania 19107

OEO 1Victor C. Leap, Executive DirectorMeadville ^Area Industrial Commission628 Arch StreetMeadville,; PA 16335

Dear Mr. Leap:

Thank you for providing me with the map showing the proposed accessroad which( would transverse part of the Saegertown Industrial AreaSite. Pripr to granting EPA approval for the construction of thisroad, EPA requires that surface and shallow subsurface soilinvestigations be conducted in the area to be excavated todetermine the presence or abscence of contamination.

iThis includes submitting a Workplan to EPA for its approval whichdescribes your proposed sampling locations and methodologies,sample identification and handling procedures, decontaminationprocedures, sample custody, data management protocol, etc., asdescribed on the attachment. The attachment contains excerpts froma sampling plan previously approved by EPA.

In additipn, the samples collected need to be analyzed by alaboratory in the Contract Laboratory Program (CLP) for TargetAnalyte List (TAL) inorganics, Target Compound List (TCL) volatileorganics and TCL semivolatile organics parameters. Samples willneed to be accompanied by blind duplicates, blind field blanks,blind travel blanks and matrix spike/duplicate (MSD) sets asrequired by CLP.

iA contractor of your choice, with EPA approval, can collect thesamples or EPA can collect the samples for analysis by the CLPlaboratory. If you choose to have a contractor collect thesamples, EPA needs two weeks notice of the sample collection datein order to provide for oversight.

In summary, EPA must receive the validated data before a decisioncan be made; regarding the access road. Please contact me when youreceive this letter so that we can discuss this further and so Ican answer,any questions that you may have.

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Sincerely,

Christine ChulickProject Manager

Enclosure AR2006M

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3.5 Data Management PlanI

3.5.1 ' Purpose and Objectives of Data Managementj

In order to provide a sound data base for subsequent remedialdecision-making, the RI must provide a means for thedemonstration of the accuracy, precision and completeness ofdata, maintaining data accessibility, and tracking the RI process.Through the use of a phased approach of sampling, analysis, dataassessment (data review), data qualification, and feedback, theoverall data management objective is to provide a complete database with a high degree of confidence. This will be accomplishedby the design of data management at four levels: field data,sample management and tracking, data manipulation and validation,and document control and inventory.

3.5.2 ; Field Data

Field data collection will constitute the taking and recording offour types' of data: raw measurements, observations or logs,procedural" d e s c r i p t i o n s a n d sample d o c u m e n t a t i o n(chain-of-custody). All data other than the chain-of-custodywill be taken in a bound field notebook. The format of the fieldbook will be as described in Section 8.0 of this QAPP, and theresponsibility of maintaining the field records will lie with theField Operations Manager (FOM). Should simultaneous datacollection activities occur, multiple field notebooks will beused, all of which will be dedicated solely to this RI. The FOMwill check each field notebook daily and initial it. Followingthe completion of a task of the RI, the FOM will provide a fieldreport to the RI Manager, including photocopies of theappropriate field notebook pages. Table 3-3 presents the typesof data to be collected and the standards for recording the data.

Sample custody will be documented as provided in Section 5.0 ofthis QAPP. The FOM will be responsible for ensuring that all ofthis documentation is accurate and complete, as well as fortransmitting copies of this documentation to the RI Manager.

3.5.3 ' Sample Management and Tracking

The management of samples will include the maintenance ofcommunication logs with the analytical laboratory, a samplet r a c k i n g ' s c h e d u l e , and sample custody documentation.Coordination with the analytical laboratory will be theresponsibility of the Laboratory Coordinator, who will maintain alog of all arrangements and communications. Thi* ffiOfonpflijigtQorwill also maintain a schedule of sample statusY w*hHcrr wrllinclude the sample identification, Traffic Report Number, matrix,

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date and time of sampling, dates of shipment and receipt,requested analyses and holding times. Such a log will providethe means for tracking the samples through their analysis andavoiding missed holding times. The Laboratory Coordinator willprovide an updated copy of this schedule to the RI Manager, aswell as pertinent communication logs, at the completion of eachanalytical task.

3.5.4 Data Manipulation and Validation

Calculations performed on raw data or measurements will becontrolled by two review processes. Data manipulation performedby the analytical laboratories will be reviewed by the QualityAssurance Manager. This data review and validation process isdescribed in Section 12 of this QAPP. During this reviewprocess, data are entered into a spreadsheet data base along withapplicable qualifiers. These spreadsheets are included as a partof a Data Quality Assurance Report to the RI Manager, which alsoincludes the results of any necessary laboratory audits, anassessment of internal quality control checks, and a review ofany corrective action that was necessary. Quality AssuranceReports are provided to the RI Manager at the completion of eachtask.

Data manipulation that is performed in-house is reviewed by theRI Manager. All such data reduction will be performed in anapproved format, will be signed and dated by the personperforming the calculation/manipulation, and will be checked bythe RI Manager prior to placement in the file. Such data willinclude calculations on surface water flow; aquifer permeabilitytest calculations; surface soil permeability tests; and logs ofborings, pits and well completion details.

3«5.5 Document Control and Inventory

Upon validation, all data, field reports, quality assurancereports, sample custody documentation and raw data will be placedin a file to be maintained by the RI Manager. This file willalso contain any photographs, computer disks or non-paper itemsthat were used in the development of the RI report. Each itemwill be placed into the RI file according to the format presentedin Table 3-4 and will be sequentially numbered as shown. Allsupport documentation for the Quality Assurance Reports,chain-of-custody documentation, and raw data from the RI will bemaintained in-house for the duration of the RI/FS. Following thecompletion of the RI/FS, these data will be stored in a securelocation for seven years after the completion of the study.

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duplicate ;and submitted blind to the laboratory to monitorsampling variability.

j _4.1.2 'OVA Monitoring

A Foxboro Century Model 128 OVA will be used to monitor for totalvolatile organics in air during all on-site activities for healthand safety [ purposes. The OVA will be calibrated as described i"nSection 6 of. this QAPP.

4.2 Soil Sampling

The RISOP addresses collection of subsurface soil samples fromtest borings and shallow soil samples from hand auger borings.OVA readings during soil sampling will be" recorded in a fieldbook.

4.2.1 Surface Soil Samplingj

Surface soil samples identified in the RISOP will be collectedusing a hand-driven bucket auger from land surface to a depth of18 inches. Soil samples will be collected from 6 to 12 inches indepth for volatile organic compounds, and 0 to 6 inches in depthfor the remaining TCL compounds specified in Section 7 of theQAPP. '

The soil sample will be removed from the bucket auger using aprecleaned stainless steel scoop or spoon. The VOC sample willbe placed immediately in a 4-oz. laboratory-cleaned glass jarfrom the 6^ to 12-inch depth. The soils from the 0 to 6-inchdepth will be placed on a disposable aluminum pan and will behomogenized using a stainless steel scoop or spoon. Anappropriately sized volume will then be transferred to theappropriate sample containers for the remaining TCL analyses.IOne composite sample will be submitted for analysis for dioxins.This sample will be taken by compositing soils from the 0 to6-inch depth interval at several random locations. Thesesubsamples will be composited in an aluminum pan as describedabove.

4.2.2 ', Subsurface Soil Samplingi

Split barrel split-spoon soil samples will be collected as perASTM D-1586. Each split-spoon sample will be opened andimmediately scanned with a Foxboro Century Model 128 OVA and the

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reading recorded in the project field book. The OVA measurementsand physical observation will be used to aid in selection ofsamples for laboratory analysis from each boring.The selectedsample aliquot will be placed (using a clean stainless steels p a t u l a ) in laboratory supplied glass bottles with aTeflon®-lined enclosure and handled as described in Section 4.6.3of this QAPP.

4.3 Surface Water and Stream Bed Sediment Sampling

4.3.1 Surface Water and Bioassay Water Sampling

Surface water sampling will proceed from the farthest downstreamlocation and proceed to upstream locations to minimize potentialcross-contamination from suspended material in the stream fromsampling activities. Depending upon depth and stream velocity,samples will be either collected directly into the appropriatesample containers at a point upstream of the sampler's positionor through the use of a long-handled polyethylene grab samplerfrom the bank of the stream.

Stream velocity and flow will be assessed qualitatively at eachsampling location. Flow will be measured at three streamsampling stations by the procedures described in Section 3.5.3 ofthe RISOP.

The water necessary for the bioassay test will collected (asdescribed above) directly into the container for transport.Sufficient water will be collected to ensure the laboratory isprovided with water that is no more than seven days old.

4.3.2 Stream Bed Sediment Sampling

At the select surface water sampling locations identified in theRISOP, a sediment sample will also be collected. If present, acomposite of equal volumes of fine sediments (surface) from twopoints in the vicinity of the surface water location will behomogenized on an enamel pan with a stainless steel spatula andan appropriately sized volume transferred to the samplecontainers.

Stream bed sediments will be collected with a stainless steeltrowel and dewatered as much as possible prior to placement intothe sample containers.

The

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4.5.3 Sample Acquisition]i

Sample acquisition will be as described in Section 3.1.1.3 ofAttachment 2. Dedicated 1.25-inch bottom-loading stainless steelbailers will be used to collect grab, ground water samples fortransfer into the proper sample containers. Nylon™ string willbe used to[ raise and lower the bailer. If well yields are low atthe site, the samples will be collected as the well recovers andprovides a sufficient volume for sample collection.

i4.6 Decontamination and Post-Sampling Procedures

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4.6.1 Drilling Equipment Decontaminationi

Drilling equipment will be decontaminated prior to initial use,between boring locations, and at the completion of drillingactivities. Items necessary to decontaminate include thefollowing:

back of drilling rigauger flightsdown-hole equipmentwell casing and screen

A manual scrubbing to remove foreign material followed by athorough steam cleaning will be used for decontamination of theabove items. Drilling equipment, well screen, and well casingwill be stored in a contaminant-free location above ground onwooden supports after decontamination and covered with plasticuntil use.

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4.6.2 Sampling Equipment Decontamination

All non-disposable equipment (bailers, split- samplers, handtrowels, etc.) will be decontaminated according to the proceduresdescribed below:

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- manual scrub with a non-phosphate soap solution- tap water rinse- 10% nitric acid rinse- Pesticide-grade methanol or acetone rinse

distilled water rinseair dry

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Decontamination will be performed at each sampling location.Waste solvents will be collected in a temporary container andheld until disposal in a dedicated 55 gallon drum at the easternend of the pile. At the conclusion of the RI, this drum will beproperly disposed.

Following decontamination; each dedicated bailer will beindividually wrapped in plastic trash bags, sealed, and storedon site at a contaminant-free location or at ERIl's warehouse forfuture use.

The submersible pump system will be decontaminated between wellsby flushing with approximately 50 gallons of clean tap water.The outside of the pump and discharge tubing will be thoroughlyrinsed with distilled water using a hand-held pressure sprayer.

4.6.3 Sample Preparation and Preservation

Ground water and surface water samples collected for metalsanalysis will be field-filtered through a 0.45-um pore sizefilter prior to preservation to allow determination of dissolvedmetals. The filtering system used will be as described inSection 4.2 of the SOP. The filters will be rinsed with analiquot of distilled water prior to the filtration of samples.Surface water samples will also be submitted for total metals(unfiltered) analysis.

Immediately after collection, samples will be transferred toproperly labeled (see Section 5 of this QAPP) sample containerswith all necessary preservatives added. Sample containers aresupplied by I-Chem of Hayward, CA, and will be Type II grade (tomeet EPA requirements), and preservatives are Ultrex gradequality. Table 4-3 lists the proper container material, volumerequirement, and preservation needed for the EDM site analyses.Samples requiring refrigeration for preservation will beimmediately transferred to coolers packed with ice or ice packs.Proper chain-of-custody documentation will be maintained asdiscussed in Section 5 of this QAPP.

Field measurements for pH, specific conductance, and temperaturewill be obtained on ground water samples immediately followingsample collection. A grab sample collected in a beaker will beused to obtain measurements. Surface water samples will bemeasured in s itu. A one to two (1:2) sediment to distilledwater slurry will be used to measure sediment pH ancLEh 4n a

Section: __Revision No.:«MMHPage: 1 of 2

SECTION 5

SAMPLE CUSTODY

The primary objective of sample custody procedures is to createan accurate written record which can be used to trace thepossession and handling of all samples from the moment of theircollection^ through analysis, until their final disposition.Sample custody for samples collected during this investigationwill be maintained by the Field Operations Manager (FOM) or thefield personnel collecting the samples. The FOM or fieldpersonnel are responsible for documenting each sample transferand maintaining custody of all samples until they are shipped tothe laboratory.

ijffi will use Series 200 bottles obtained from I-CHEM of Hayward,California, for use as sample containers. All necessary chemicalpreservatives will be added to the bottles prior to the samplingevent according to MIBb Standard Operating Procedures for bottlecontainer and preservation. Custody of the sample bottles willbe maintained by the FOM. Sample bottles needed for a specificsampling task will be relinquished by the FOM to the samplingteam after the FOM has verified the integrity of the bottles andensured that: the proper bottles have been assigned to the task tobe conducted.

A self-adhesive sample label will be affixed to each containerbefore sample collection. At a minimum, the sample label willcontain the information as shown on Figure 5-1.

Client - Job Name (EDM RI)•• Traffic Report NumberSample identification - place of samplingData a|nd time collectedSampler's initialsTesting requiredPreservatives added

|

Immediately after sample collection, each sample bottle will besealed in an individual plastic bag. Samples willimmediately into an insulated cooler forlaboratory. 4B field Chain-of-Custody records (Figure 5-2) and

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an flBk Traffic Report (Figure 5-3) completed at the time ofsample collection will accompany the samples inside the coolerfor shipment to the laboratory. The samples will be properlyrelinquished on the field Chain-of-Custody record by the samplingteam. These record forms will be sealed in a ziplock plastic bagto protect them against moisture. Each cooler will containsufficient ice and/or ice packs to ensure that proper temperatureis maintained and will be packed in a manner to prevent damage tosample containers. The FOM will then initial and custody seal(Figure 5-4) each sample cooler. All coolers will be shipped byan overnight courier according' to current US DOT regulations.Prior to releasing the coolers, the FOM will require the -courierto sign an W Cooler Transfer Acknowledgment (Figure 5-5). Uponreceiving the samples, the laboratory Sample Custodian willinspect the condition of the samples, compare the information onthe sample labels against the field Chain-of-Custody record andTraffic Reports, assign a CAA laboratory control number, and logthe control number into the computer sample inventory system.

The preparation of all sample bottles (cleaning technique,preservative added, etc.) will be documented. When samplesrequiring preservation by either acid or base are received at thelaboratory, the pH will be measured and documented. TheLaboratory Sample Custodian will then store the sample in asecure sample storage cooler maintained at 4°C and maintaincustody until the sample is assigned to an analyst.

The Laboratory Sample Custodian will riote any damaged samplecontainers or discrepancies between the sample label andinformation on the field Chain-of-Custody record when logging thesample and will note any discrepancies in Section 11 of the ERMTraffic Report. This information will also be communicated tothe FOM or field personnel so proper action can be taken. TheChain-of-Custody form will be signed by both the relinquishingand receiving parties each time the sample changes hands, and thereason for transfer indicated.

An internal Chain-of-Custody form will be used by CAA to documentsample possession from laboratory Sample Custodian to analystsand final disposition. All Chain-of-Custody information .will besupplied with the data packages for inclusion in the documentcontrol file.

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TABLE 7-3

RECOMMENDED HOLDING TIMES FOR ANALYSES

______________Holding Time__________Sample Analysis W a t e r ^ S o l i d / S o i l s

1. Target Compound List 14 days 10 daysVolatile Organics

2. Target Compound List 7 days until extraction 7 days until extractionSemivolatile Organics 40 days after extraction 40 days until extraction

3. Target Compound List 7 days until extraction 7 days until extractionPesticides/PCBs 40 days after extraction 40 days until extraction

4. TAL Metals 6 months (28 days for Hg) 6 months (28 days for Hg)

5. Cyanide 14 days 14 days

6. Field pH, Eh, Measured immediately after NAconductivity, sample collectiontemperature anddissolved oxygen

7. Total Organic Carbon 28 days 28 days

8. Total Phenols 28 days NAi

9. Total Dissolved Solids 7 days NA

10. Total Suspended Solids 7 days NA

11. Alkalinity 14 days NA

12. Hardness 6 months • NAiI

13. Chemical Oxygen Demand 28 days NAi

14. Biochemical OxygenDemand 48 hours NA

j15. Amronia 28 days NA

i1 Unless otherwise specified, Federal Register, 40 CFR Part 136,

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SECTION 8

DATA REPORTING, VALIDATION, AND REDUCTION

Data validation practices will be followed to ensure that rawdata are not altered and that an audit trail is developed forthose data which require reduction. All the field data, such asthose generated during field measurements, observations and fieldinstrument calibrations, will be entered directly into a boundfield notebook. Each project team member will be responsible forproofing all data transfers made, and the Field OperationsManager will proof at least 10 percent of all data transfers.

CAA group leaders will check and validate all data generated bytheir group as specified in Attachment 1, Section 10.0. Uponreceipt of the sample data packages by 4HP the laboratory datawill again be quantitatively and qualitatively validated byQuality Assurance Manager or a staff data reviewer. Datavalidation is discussed in detail in Section 12.

It is a n t i c i p a t e d that IflBHp data reduction for thisinvestigation will be minimal and will consist primarily oftabulating analytical results from CAA's Form I (AnalyticalReports) onto summary tables through the use of computerizedspreadsheet software. All reduced data will be assigned documentcontrol identification numbers and placed in the central filemaintained by the RI Manager.

All analytical data obtained during the course of theinvestigation for ground water, surface water and other aqueoussamples will be reported as ug/1. Analytical data for solid/soilsamples will be reported as ug/kg on a dry weight basis. Datapackages associated with the analyses of samples collected duringthe RI will be prepared utilizing full CLP deliverables. Therequired deliverables are stated in Section B of the organic andinorganic SOWs currently in use by CAA.

^^fcwill require a rigorous data control program that will ensurethat all documents for the investigations are accounted for whenthey are completed (see Section 3.5 of this QAPP). J^.ccpunJ:abledocuments include items such as log books, field oHifia294.p6O3p,correspondence, chain-of-custody records, analytical reports,data packages, photographs, computer disks, and reports. The RI

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Manager is responsible for maintaining a central file in whichall accountable documents will be inventoried.

!To maintain control in the transfer of data, all copies of rawdata from the field notebooks, and the data as received from thelaboratory, will be entered into a data file and assigned anappropriate document control identification number. The datafile will serve as the ultimate archive for all information anddata generated during this investigation.

The documentation of sample collection will include the use ofbound field log books in which all information on samplecollect! o'n will be entered in indelible ink. Appropriateinformation will be entered to reconstruct the sampling event,including ': site name (top of each page), sample identification,brief description of sample, date and time of collection,sampling methodology, field measurements and observations, andsampler's initials (bottom of each page and dated).__An exampleof a f iel'd log is presented in Figure 8-1. §•••» Sampl ingNotebook SOP is photocopied and attached to the front cover ofall field books issued. This ensures all required information isrecorded. A copy of the SOP is presented as Figure 8-2.

Following [the validation of data from each matrix, the RI Managerwill append the summary tables and validation report to the nextmonthly progress report to EPA. The results from the latest CLPperformance evaluation sample analysis by CAA will be attached tothe' first of these data reports. The field audit report, andany amendments to the RISOP and this QAPP will also betransmitted with the next monthly report. These reports will beforwarded seperately to the following recipients:

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FIGURE 8-2 (continued)

SAMPLE INFORMATION

Sample # (Traffic Report)

Date and time sample collected

Source of sample' (well, stream, domestic well, field etc.)

Purged Well - type of equipment, purge volume, rate ofpurge, and decontamination procedures

Location of Sample - document with a site sketch and/orwritten description, where sample was taken so that itcould be found again.

How was sample taken? (bailer, trowel, SS spoon, thief,etc. )

Analysis and QA/QC required (601, 602, Metals, Tier I,Tier II, etc.)

Chemical Preservation used (HN03, H2S04, NaOH, etc.)

Field Data (pH, DO, spec, and temp., etc.)

Field Observations - significant observations should bedocumented.

Sample condition (color, odor, turbidity, oil, sheen)Site condition (stressed vegetation, exposure of buriedwastes, erosion problems, etc.)

How sample was shipped, date, time and where to, and iflegal seals were attached to transport container(s).

»

Comments - Any observation or event that occurred that wouldbe relevant to the site; for example, weather changes oreffects on sampling; conversations with the client, publicofficial or private citizen; instrument calibration;equipment problems, etc.

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j SECTION 12

I SPECIFIC ROUTINE PROCEDURES USEDi TO ASSESS DATA PRECISION,J ACCURACY, AND COMPLETENESS

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12.1 Overall Project AssessmentI

Overall data quality will be assessed by a thorough understandingof the data quality objectives which are stated during the designphase of the investigation. By maintaining thoroughdocumentation of all decisions made during each phase ofsampling, performing field and laboratory audits, thoroughlyreviewing (validating) the analytical data as it is generated bythe laboratory, and providing appropriate feedback as problemsarise in the field or at the laboratory, •fcwill closely monitordata accuracy, precision and completeness.j12.2 Field Quality Assessment

To ensure that all field data are collected accurately andcorrectly, specific written instructions will be issued to allpersonnel involved in field data acquisition by the ProjectManager. The Quality Assurance Officer will perform a fieldaudit during an initial sampling of the investigation to documentthat the appropriate procedures are being followed with respectto sample (and blank) collection. These audits will include athorough review of the field books used by the project personnelto ensure that all tasks were performed as specified in theinstructions. The field audits will necessarily enable the dataquality to be assessed with regard to the field operations.

iThe evaluation (data review) of field blanks and other field QCsamples will provide definitive indications of the data quality.If a problem that can be isolated arises, corrective actions canbe instituted for future field efforts.

12.3 Laboratory Data Quality AssessmentiSpecific measures that will be taken by CAA to assess dataquality are presented in Attachment 1, Section 14.

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12.4 B > Laboratory Data Assessment

12.4.1 EBfData Validation

All analytical data generated during the investigation willundergo a rigorous BPdata review. This review will beperformed in accordance with the "Functional Guidelines for theEvaluation of Organic (and Inorganic) Analysis."

A preliminary review will be performed to verify that allnecessary paperwork (chain-of-custodies, traffic reports,analytical reports, laboratory personnel signatures) anddeliverables (as stated in the current organic and inorganicSOWs) are present.

A detailed quality assurance review will be performed by the HBQuality Assurance Manager (or a staff reviewer) to verify thequalitative and quantitative reliability of the data aspresented. This review will include a detailed review andinterpretation of all data generated by CAA. The primary toolswhich will be used by experienced data review chemists will beguidance documents, established (contractual) CLP criteria, andprofessional judgement. Table 12-1 presents the items examinedduring the quality assurance review.

Based upon the review of the analytical data, an organic andinorganic Quality Assurance Report will be prepared which willstate in a technical yet "user friendly" fashion the qualitativeand quantitative reliability of the analytical data. The reportwill consist of a general introduction section, followed byqualifying statements that should be taken into consideration forthe analytical results to best be utilized. Based upon thequality assurance review, qualifier codes will be placed next tospecific sample results on the sample data table. Thesequalifier codes will serve as an indication of the qualitativeand quantitative reliability.

During the course of the data review, an organic and inorganicsupport documentation package is prepared which will provide thebackup information that will accompany all qualifying statementspresented in the quality assurance review.

Once the review has been completed, the Quality Assurance Managerwill then submit these data to the RI Manager. These approveddata tables and quality assurance reviews will be signed anddated by the Quality Assurance Manager.

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SECTION 2

PREPARATION OP A PROJECT SAMPLING PLAM

Prior to the collection of environmental samples* it is necessaryto prepare a project sampling plan which is site-specific. Thiswill require determination of the following: (1) the objectivesof the sampling program* (2) the media to be sampled* (3) thesampling locations* and (4) the analyses to be conducted.Predetermination of these items will result in the design andperformance of a cost-effective- and technically feasible samplingplan.The three basic objectives of a sampling plan are the following:(1) determine the presence or absence of contamination* (2)determine the extent and magnitude of contamination* and (3)determine the contaminant pathways which may exist at a site.lach of these will greatly affect the sampling plan as each willsubsequently affect the determination of the media to be sampled*the sampling locations* and the- analyses to be conducted. •The second step in developing a sampling plan is the determina-tion of the media to be sampled at a particular site. This mayinclude the collection of surface and ground water samples*stream sediment samples* leachate springs or seeps* soil or rocksamples* or air samples. Again* the materials to be sampled willbe greatly affected by the objectives of the sampling.

The third step is to determine the sampling locations. Inaddition* it is necessary that the justifications for theselection of the sampling'locations be detailed along with theintended use of the data.-

The fourth step is to determine exactly what analysis will beconducted. The constituents analyzed are usually selected forseveral reasons. These are: (1) required by regulations? (2)considered to be toxic and present at the site or there is anindication of their presence at the site; (3) indicators ofcontamination which may not be toxic; and (4) site-specificconstituents or those constituents known to be present at thesite whether toxic or non-toxic.iAll of the above factors will be dependent upon the work to beconducted at the site* whether it be a site investigation*feasibility study* and/or remedial design. In order to makeinformed decisions as to the above considerstionl$£§§§Ri§nda-tory that all available background data on the site be collected

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and reviewed. Using this information* a detailed site-specificsampling plan for the investigation can be proposed. The planmust include a checklist of all equipment which will be neededduring the sampling and a detailed discussion of all proceduresto be used. As stated previously* the following sections willdetail BRH's Standard Operating Procedures for the collection ofenvironmental samples. These are to be used where applicable inthe development and performance of the sampling plan.

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Very sUiple techniques can usually be employed in collectingsediment samples. Below are some suggested techniques forsediment sampling:

As previously mentioned* in small* low-flowingstreams or near the shore of a pond or lake* thesample container* a shovel* or hand-operatedbucket auger may be used to scrape up sediments.The sediment must be dewatered as much as possibleso as not to reflect soluble concentrations in thewater. : . .•To obtain sediments from larger streams or furtherfrom the shore of a pond or lake* a beakerattached to a telescoping aluminum pole by meansof a clamp may be used to dredge sediments.

To obtain sediments from rivers or in deeper lakesand ponds* a spring-loaded sediment dredge (Bckmandredge) or benthic sampler may be used. Several

: types of sediment core samples exis.t for special-ised sampling of sediments.

Lastly* all. the equipment used should be decontaminated betweenthe sampling stations using the procedures described in thefollowing section.

3.4 Soil Sampling

There are two types of soil samples: surface (consisting of thetop two feet) and subsurface (below two feet). In most cases*both types will b« collected as grab samples* Although* in somecases composite sampling may be useful for obtaining data aboutcontamination over a wide area. This provides a rough estimateof the overall extent and magnitude of contamination, whilereducing the analytical costs. However* when composite sampling,it is important that extreme care be taken in documenting thelocation and depth of the composites.

3.4.1 Surface 80tlListed bolow are three possible scenarios for the collection ofsurface soil samples over a large area:

the total, area may be divided by a grid system toidentify specific sampling locations;

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if the area is large and if complete characteriza-tion is required* a random sampling approach maybe used to reduce the number of samples. In thisinstance* the area is laid out in a grid andsample locations determined randomly; and

an extremely large study area can also be dividedby grids with soil samples being composited fromseveral locations within the grid.

The list of equipment necessary for the collection of surfacesoil samples may be minimal* depending upon the analyticalparameters to be determined. As previously discussed in Section2 of this document* the sampling devices may be constructed ofeither PVC, linear polyethylene* Teflon* or stainless steel*depending upon the parameters of interest* The following is alist of equipment necessary for the collection of surface soilsamples:

Materials for sample preparation (see Section4.1). •

• Appropriate sample containers (see Section 4.4).- Chain-of-custody labels* tags* and record forms

(see Section 5.2)*Log book and indelible ink marker. This is forrecording information pertinent to the samplingprocedures used and information on environmentalconditions at the time of sampling.Sampling devices. Generally* these include ascoop* or hand trowel constructed of appropriatematerial. However* in some cases* shovels* picks*hoes* and/or hand augers may be necessary.

Decontamination solutions/water. These will beused for decontaminating equipment (see Section4.1).

Buckets* plastic wash basins* scrub brushes* andsponges. These will be used in the cleaning ofcontaminated equipment.Camera/film. For use in documenting samplingprocedures and sample location.

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Grab samples of surface soils are collected by placing thescooped or troweled sample into an appropriately sized bottle.However, composite soil sampling requires considerably morecaution. Depending upon the number of samples to be collectedand the area to be covered* the soil samples from various areasshould be placed into an appropriately constructed pan* thorough-ly mixed, and an appropriately sized aliquot taken. It isimportant that the volume of soil from each location be asidentical as possible. Nhen possible* it is recommended thatcomposite soil sampling only be conducted when the soils arerelatively dry. Wet soils are very difficult to work with thusmaking the collection of a representative composite sampledifficult., Since it is necessary to split the samples and exposethem to the atmosphere prior to storage* it is impossible tocollect representative composite soil sample for volatileconstituents.i

j

3.4*2 Subsurface Soil1 . .

Subsurface soils can be collected either as grab or compositesamples* The same precautions for composite sampling of surfacesoils apply to the compositing of subsurface soils. Althoughthis document does not generally discuss safety factors involvedin the collection of samples* it is important at this point tonote that the collection of subsurface soil samples can consti-tute a substantial safety hazard. The most important safetyfactor involved is the avoidance of buried containers or pocketsof highly contaminated material. A thorough background informa-tion search should be completed before obtaining subsurfacesamples. At a minimum* a metal detector survey should also beperformed at sites where buried materials are suspected.

j

Generally* the*problems encountered in the collection of subsur-face soil samples are similar to those encountered in thecollection of surface soil samples. Additionally* subsurfacesampling must also address the depths from which the samples willbe obtained. The overall approach is similar to that discussedpreviously for surface sampling* considering the aspects uf gridsystems and random versus specific sampling locations. Thedepths at which samples are to be taken will depend upon thesuspected contaminants* their general mobilities* and the methodby which they have entered the subsurface environment. Generally,subsurface samples can be obtained by three methods: shallowsubsurface sampling by hand-operated equipment and deep subsur-face samples by use of a drilling rig or a backhoe.

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The following is a list of recommended equipment for samplingsubsurface soils:

Materials for sample preparation (see Section4.2).

Appropriate sample containers (see Section 4.4).

Chain-of-custody labels* tags* and record forms(see Section 5.2).

Log book and indelible ink marker. This is forrecording information petinent to the samplingprocedures used and observations on the environ-mental conditions at the time of sampling and thelocation.

Sampling devices (depending upon the samplingmethods.described in the following paragraph).Decontamination solutions/water* These will b«used for decontaminating all equipment that comesinto, contact with the soils and the inside of thecasing or auger flights (se« section 4.1).

- Bucket** wash basins* scrub brushes* and sponges.These will be used for equipment decontamination.

- Steam cleaner. A steam cleaner should be usedwhen attempting to decontaminate large pieces ofequipment such as auger flights.Camera/film. These are for use in documentingsampling procedures and sample locations.

iDepending upon the depth and type of samples to be collected, avariety of methods are available for sampling subsurface soils.These include: '

- A shovel which may be used to depths of severalinches or several feet* depending on soil types.

A slotted sampling trier which is limited to abouttwo and one-half (2-1/2) to three feet.

- A hand auger may be used to collect subsurfacesamples at depths up to four to five feet?however* it mixes and thus destroys the cohesivestructure and stratigraphie character of the»Sjoilkrt /* /• ipreventing detailed soil description. Hn£UUOOI

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A hand-driven split-spoon sampler provides a meansto obtain somewhat undisturbed core samples. Thedtpth will again be limited by the soil type.

Drill rig-operated sampling devices. These may beplaced into two categories: (1) solid stem augersand (2) hollow stem augers. With solid stemaugers* materials are mixed as brought to thesurface, making representative samples fromdiscreet depths impossible to obtain. With hollowstem augers* either a split-spoon or Shelby tubecan be used for sample collection.

Soil samples may be collected from a backhoetrench. It is emphasized that at no time shouldthe sampler enter the backhoe trench. A contami-nated air supply or possible caving makes this adangerous situation* To collect samples from thepit* a long-handled bucket auger or the backhoebucket may be used to collect the soil from thedesired depth interval.

Lastly* proper decontamination procedures* discussed in Section4.1* should be used in cleaning all the soil sampling equipment.Sample preservation for soils is not as imperative althoughvolatile organic soils should be kept cool* and BRM recommendsrefrigeration of all soil samples.

3.5 Air Samplingi

Air sampling of a hazardous waste site is useful in assessingpotential adverse health effects caused by the inhalation oforganics or inorganic constituents. Organic compounds volatizinginto the air fro* surface streams* lagoons* open drums, orcontaminated soils* as well as inorganic particulatea, such isasbestos off lead* may be collected in sampling bags or tubes andanalyzed to determine the specific constituents and theirrespective concentrations.

iAs previously discussed with the other types of environmentalsampling* an initial survey of the site is necessary to providebackground information needed for the design of an effective airsampling program. This background information includes: identi-fication of personnel safety requirements* the locations ofpotential contaminant source areas* location of a backgroundsampling station* and prevailing upwind and downwind directions.Also* if the types of constituents that are being monitored areknown, then the sampling program should be designed to better

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SECTION 4

POST-SAMPLING PROCBDORM

Post sampling procedures include: (1) equipment decontamination,(2) sample preparation* (3) sample preservation* and (4) samplestorage. Additionally* in many cases* in-field measurements ofcertain parameters may be required.

4.1 BmtipjMnt Decontamination

All non-disposable equipment used for the collection* prepara-tion* preservation* and storage of the environmental samples mustbe cleaned prior to their use and after each subsequent use.Unless the equipment and materials.being used are disposable orof sufficient number so'as net to be reused during any onesampling period* decontamination will have- to b« conducted in thefield. Field decontamination can be a tedious and expensive

s~ chore* as it. can require, taking into the field a sizable amount' of equipment and reagents. . If possible* attempts should be made

to minimize field decontamination.The materials needed for decontamination are dependent upon theequipment to be cleaned. The following is a very generalizedlist of equipment to be used during decontamination:

Cleaning solutions. These will be dependent uponthe items to be cleaned and the parameters whichare being analysed.

Water. In some cases* tap water may be adequatefor initial or intermediate rinses. The finalrinses* however* must be with deionized/distilledwater.

Storage vessels. These will be used to transportlarge volumes of deionized/distilled water to thesite. It is recommended that fifteen-gallonplastic carboys with a spigot positioned near thebottom of the tank be used.

Buckets and wash basins. For use in the washingand rinsing of equipment.

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A drying rack. All materials and equipment must bedried prior to additional use. Paper towels or£hemwipes should not be used for drying surfaces ofequipment which come into contact with the samples.|£aper towels and Chemwipes. For use in cleaning allputside surfaces or surfaces that do not come into'contact with the sample.

Basically, there are two types of recommended field cleaningprocedures, when collecting samples for inorganic constituents,the following procedures are recommended:

Wash with a non-phosphate detergent (or steam clean).

Rinse with tap water.IiWash or rinse through the use of a squirt bottle with a'dilute nitric acid. A one to five percent nitric acidsolution is adequate.

Rinse three times with deionized/distilled water.

When sampling for organic parameters, the following cleaningsequence is recommended:i

Wash with a non-phosphate detergent (or steam clean).Rinse with tap water.Rinse with pesticide-grade methanol.Triple rinse with deionized water.

i

If analyses are to be conducted for ammonia or nitrogencompounds, it is necessary that one to five percent solution ofhydrochloric acid be used in place of the nitric acid bath. Ifit is found that persistent stains or water marks are present, itmay be desirable to use a chromic acid solution as a furthercleaning procedure. However, both hydrochloric acid and chromicacid are extremely corrosive and, if possible, their use shouldbe avoidedpwhile in the field.

|Larger pieces of equipment may require specialized decontamina-tion procedures. The small-diameter bladder-type pump can bedecontaminated with the use of two specially-designed decontami-nation tanks. These tanks can be constructed of a three-footsection of four-inch 1.0. PVC pipe with an end cap 8 H< §0)S§ eend. The pump is set inside one tank along with three to fivegallons of clean tap water. By pumping the clean tap water from

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the tanks* both the outside and inside of the pump can bedecontaminated. After the tap water wash* the pump should beappropriately cleaned as per the above procedures using deionizedwater and the second tank.

The tubing used for a centrifugal pump can be decontaminated bypumping tap and then distilled water through the tubing. Theoutside of the tubing can b« decontaminated by use of a pressuresprayer. To avoid cross-contamination* it is recommended thatthe PVC tubing be dedicated to each well and cleaned betweenuses. • - • .

Larger diameter submersible pumps are difficult to decontaminateand for this reason should be used only where absolutely neces-sary. These pumps have high flow rates and large volumes ofclean water are needed to decontamiante the inside of the tubing.In most cases* the cost of the tubing for these pumps is prohibi-tive to dedication of tubing to each well. A pressure sprayercan be used to effectively decontaminate the outside of the pumpand' tubing. At sites where a clean tap water source is avail-able* the submersible pump should alrso be decontaminated bypumping 75 to 100 gallons through it and the discharge tubing. A45-gallon polyethylene drum has been dedicated for this use.

4.2 Sample Preparation

Immediately before sample collection* each sample bottle shouldhave a label attached which includes the following information:sample identification* date* time* samplers name* analysisrequested* and the site name.

Whether or not'a sample is to'be prepared prior to preservationand storage depends upon the analyses to be conducted and thetype of sample collected. If dissolved metal concentrations aredesired* then the sample must be filtered in the field immediate-ly after collection. Field filtration of surface water samplesis not am critical as filtration of ground water samples. Surfacewater samples generally exist in equilibrium with atmosphericconditions and* as such* will not undergo rapid change aftercollection* However* ground waters tend to b« more reducing and,precipitation will occur if the sample is not filtered immediate-ly after withdrawal.It is recommended that all surface and ground water samples befiltered using a Sartorious"* or Nalgene" filtration apparatus ora Millipore" pressure filter* depending on the quantity andturbidity of the samples (Figures 1* 2* and 3).and Nalgene* apparatus is inert with respect to

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is a closed system which will prevent oxidation of the sample. A.45-micron pore sized membrane should be used for sample filtra-tion. The sample may be pumped through the filter using astandard! laboratory vacuum pump or a Nalgene hand vacuum pump.The Mill!pore" pressure filter can be used where large volumes ofsample need to be filtered* or the sample is extremely turbid.This pressure filter allows for rapid filtration and is con-structed of all stainless steel and Teflon* materials. A «2 9*»sample is needed to operate it. Samples being collected fororganic contaminants need not be field filtered.

In general* soil and sediment samples are not prepared in thefield. However* in cases where composite samples are beingcollected* it may sometimes be desirable to combine and split thesamples in the field. In these cases* it will be necessary tosieve the samples to remove large* non-representative fractionsand then to split the same using a soil sample splitter. Thisprocedure* however* will be extremely difficult if the soils andsediments are damp or wet. In this ease* it will be necessary toreturn the individual aliquots to the laboratory for preparation.As stated previously* samples collected for volatile constituentscannot be composited.

4.3 Sample Preservation

It is impossible to completely stabilize every constituent withina sample. At best* preservation techniques can only retard thechemical and biological changes that continue after the sample isremoved from its environment. If the sample environment issignificantly different from atmospheric conditions* the samplemay undergo changes which will render it non-representative ofits original environment. Methods of preservation are relativelylimited and are intended to retard biological action, hydrolysisof chemical compounds and complexes* and volatility. Generally,preservation methods are limited to pR control* chemical addi-tion, refrigeration* and freezing. Table 1 gives recommendedvolume si*es* container types* preservatives* and holding tim**sfor a variety of standard water quality parameters. Please beaware that preservative techniques are continuously changing, andthese should be routinely checked.

Sample preservation should be performed in the field immediatelyafter sample collection and preparation. In many cases where pHcontrol or additions of reagents are required* separate bottlesand preservatives may be supplied by the laboratory. In othercases* the preservatives may be placed directly in the samplebottle prior to collection.

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•...-.. " Table 1Recommendation For Sampling And Preservation

Of Samples According To MeasurementVoLReq; Holrf*

Measurement (ml) ' Container"' Preservative Ttme<»f•

100 Phiniqi Froecrttq

* » p.0 Cool.4-C 24 Hn.

t 100 P.O Caol. 4T 24 Hn.-100 P.G Cool.4rc

HNO,ieRH<2

* siu

ToWl l<jo '.<3 HNO, WpH<2

Cosl C 24Hn.25 P.0 fete.*. 4Hn.

100 P.0 CMl. «TC -7 Day,

NO.VFUtcnW. 100 p.0 Cool. 4T 7

Tottl »« M CoeU 4T 7 Day$VoUta« 100 P.O Cool. «-C 7 Days

Smlnkte Mancr 1000 p.o MOM R«a. 24 Hn.T«mp«,«» • WOO P.0 ' D*C 0. u« No Holdjn|

Turbid*, ! 100 ftO CoeU 4X 7 Oay,200 M«uh _ -

200 P.G Filitr oa site 6 M«« •«•HNO,wpH<2

HR200667

* Table 1 (Cont)VoL

HoldingMeasurement (ml) Container'11 Preservative Time"'

KtacuryD«o4vtd-- 100 p.C ----..- Wlt.ro. sh« 31 Day,

HNO, iopH<2 (Glass)13 Days(Hard

'""" —~~— . Plastic)

Tottl l« "-O HNO,(opH<2 31 Day,(Glass)

13 Day,(HardPlank)

300 taornnief. Kon-M«uffiq

100 P.0 NeMX^ 24 Hn.

100 P.0 Coat 4X 24 Hn.

100 P.O Cool 4-C 24 Hn.

30 P.0 NflMRco, - 7 Days

» W O^oesht No Holding300 P.O Cool. 4*C 24

K.OH to pH 12 24

Fluorid* 300 P.G N^tlUq. 7 Day$

. 100 P.O. Cod. 4«C - 24 Hn.

400. P.OH,S04topH<2

Tool 500 P.G C** 4X 24 Hn '«topH<2

Nhww plus Niuht 100 P.G CooC 4«C 24H,SO. topH<2

100 P.G Cod, 4-C 24 Hn.

Nicriw 50 P.G • Cod. 4-C 4S Hrs.

I

-.-. ' Table 1 (Cont) .VoLReq. Holding

Measurement (ml) Container'" Preservative Time'"

... 50 p.GH,SO. wsH<2

Toot SO P.O PVHT e» steOted«*i • Cod.4%

M pH<2

SHe» SO Pody Cod. 4X

SdTat* 50 P.O Cod. 4%

500 P.G 2 ml BM

Ptote 300 Gody Of. o. she No Holdlnf

Wiokkr 300 Gody Fl* o. sit. <_, How$Phosphorus" .. •-•Ottho.Pj»«»du<«. SO P.G Piker on sit*OvteH d Cooi.4X

Hydtdyabl* 50 P.G Cool. «*CH,SO« tepH<2

SO P.O Dec os sit* No Holdint.400 Ortanics<^m • • .

800 I 1000 P.O Cod.4X

030 SO P.G H,S04CepH<2OH A GroM 1000 G only Cod. 4«C

K O. or HQ to pH < 2Off*** carboa 23 P.G Cod. 4«C 24

H O. or HCl«pH<2

W»«ne'ks 500 G only Cool. 4*C 24H,PO. to pH<41.0 ( CuSOyi

MBAS 230 P.G Cod. 4*C

Table 1 (Cont)

VoLReq. Holding

Measurement (ml) Container*1* Preservative Time'"•

NTA SO P.O Cod. 4*C 24 Hn.

1. M«rt specific instructions for preservation and sampling art found with each procedure as• _ • • * • _ _ «^ • _ _ _ _ t * _ _ _ _ _ _ • _ • • _ _ _ _ _ _ * _ _ _ •• » * * . .

BTl*iwr* >pv«ui« ifw««w»MVH« »M t>»%j i »»»m« MM* •wnfiiMigdetailed in this manual A general discussion on sampling water and industrial waitcwattr maybe found is ASTM. Part 31. p. 72-12 (1974) Method O-33T"Plastic (P) or Glass (G). For metals, polyethylene with a polypropylene cap (no finer) ispreferred.

It should be pointed out that holding limes listed above are recommended for properlypreserved samples based on currently available data. It is recognized that for some sampletypes, extension of these times may be possible while for other types, these times may be toolong. Where shipping regulations prevent the use of the proper preservation technique or theholding time is exceeded, such as the case of a 24-hour composite, the final reported data forthese samples should indicate the specific variance.

If the sample is stabilized by eeofing, it should be warmed to 23*C for reading, or temperaturecorrection made and results reported at 23*C

Where HNO) cannot be used because of shipping restrictions, the sample may be initiallypreserved V icing and immediately shipped to the laboratory. Upon receipt in the laboratory.the sample most be acidified to a pH <2 with HNO, (normally 3 ml 1:1 HNO,/!iter issufficient). At the time of analysis, the sample container should be thoroughly rinsed with I: lHNOt and the washings added to the sample (volume correction may be required).

•

Data obtained from National Enforcement Investiptions Center-Denver. Colorado, support afcur*week holding time for this parameter in Sewerage Systems. (SIC 4952).

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4.4 Sasjol* storage

The ideal sample bottle must be constructed of a non-reactive•aterial. In general/ there are three types of Material fromwhich sample bottles are made. These are: plastic/ glass/ andTeflon. In general/ samples collected for metals and generalwater quality parameters are stored in plastic bottles. Samplescollected for organic analysis are routinely placed in glassbottles of various types and sixes/ depending upon the particularanalysis to be conducted. Table 1 gives a list of recommendedsample containers and their volumes. In most cases/ bottles willbe supplied by the laboratory conducting the analysis.

4.5 In-field Measurements

As discussed previously/ determination of sample pB/ Be/ Eh/ andtemperature on ground and surface waters require in fieldmeasurements taken immediately after sample collection. Althoughin-field measurements are more critical for ground water samplesthan samples fro* aerated surface waters* it is recommended thatmeasurements be taken as soon as the sample is removed from itsin-situ environment. When possible* measurements may be madedirectly in the well to avoid the loss of sample integrity.An alternative method for in-situ measurements is through the useof a 'closed cell". This is particularly applicable to groundwater measurements where pumped water can be used to fill up aclosed container in which measurement probes have been previouslyinstalled (closed cell). After removing all head space from theclosed cell* the cell is closed to atmospheric conditions throughthe use of two. stop cocks. This allows measurements on groundwater samples to be made as close to its original/ reducingenvironment as:it were in the formation/ and eliminates error dueto atmospheric oxidation of the sample.

Prior to conducting the in-field measurement/ the samplers orfield team must review the operating manuals for the equipment tobe employed and guarantee that all of the instruments and probesare properly standardized. All measurements should then beconducted according to the procedures outlined in the appropriateoperating manuals.

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SECTION 5

SAMPLE PACKAGING/ SUPPING/ ANDCHAXM-Or-COSTOOV. PROCEDURES

Once the samples have been collected/ prepared/ preserved/ andappropriately stored/ they must be packaged for shipment and/ordelivery to the laboratory. In addition/ from the time of samplecollection until the analyses have been completed/ chain-of-custody procedures must b« followed to insure the proper handlingand possession of the samples. This section outlines proceduresfor the packing and shipping of environmental samples/ andgeneral chain-of-custody procedures.

i

3.1 Packaging and Shipping Procedures fog Environmental SamplesAll -individual sample'containers mast be placed in a strongoutside shipping container. It is recommended that for thispurpose, a metal o.r styrofoam insulated cooler be used. Thefollowing is an outline of the procedures to be followed:

- : Using fiberglass tape* secure the drain plug ati the bottom) of the cooler to insure that water from; sample container breakage or ice melting does notleak from the outside container.Line the bottom of the cooler with a layer ofabsorbent material such as vermiculite.

Place' all sample containers in the cooler. Checkscrew caps for tightness and mark sample volumelevel on the outside of large containers.Per large glass containers/ packing peanuts may beused to keep containers in place and to preventbreakage.Small containers such as forty-milliliter vialsmay be placed in small plastic sandwich bags. Whenshipping these with large containers/ steps shouldbe taken to prevent shifting of the largercontainers which might break the smaller ones.

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Cushioning material is not necessary when shippingonly plastic sample containers. Bowever/ someabsorbent should be included in case of breakageor leaks.

lee sealed in plastic bags or cool paks should beplaced in the cooler when samples must be kept at4"C.

- Documents accompanying the samples should besealed in a xiplock plastic bag attached to theinside of the cooler lid.

The lid of the cooler must be closed and fasten-ed.Fiberglass tap* should be used to seal the spacebetween the lid and the cooler. The tape shouldbe wrapped around the cooler several times to'insure that the lid does not open if the latchbecomes unfastened.

- .The following information must be attached to theoutside of the coolers name and address ofreceiving laboratory with return address/ arrowsindicating "This End Up" on all four sides/ and•This End Up" label on the top of the lid.Additional labels such as "Liquid in Glass" areoptional. If the bottles have been carefullypackaged* additional warnings should not beneeded.

If the cooler is not equipped with a padlock/ acustody seal should be affixed and signed acrossthe lid of the cooler.

Samples packaged in this way may be shipped by commercial air.Personnel should b« prepared to open and reseal the cooler forinspection if it is required. Be aware that some commercialcarriers have limits as to the number of pounds per item that canbe shipped.

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5.2 ehain-of-Custody Procedures

As in any other activity that may be used to support litigation/fMHmust be able to provide the chain-of-possession and custodyof any samples which are offered to evidence or which form thebasis of analytical test results introduced as evidence. Writtenprocedures must be available and followed whenever samples arecollected/ transferred/ stored/ analyzed/ or destroyed. Theprimary objective of these procedures is to create an accuratewritten record which can be used to trace the possession andhandling of the sample from the moment of its collection throughanalysis and its introduction as evidence.

A sample in defined as being in someone's custody if:

it is in one's actual possession* or! it is in one's view* after being in one's physical| possession* orit is in one's physical possession and then stored

i in a secure facility or location so that no one.can tamper with- it.* or '

I it is kept in a secured area* restricted toi authorized personnel only.i ' •

The number of persons involved in collecting and handling samplesshould be kept to a minimum. Detailed field records should bekept in a bound log book and should contain the followinginformation:j

i

Unique sample identification or log number

Date -and tima

Source of sample (including name/ location/ andsample type)

Preservative usedAnalysis required

Name of collector (s)

Pertinent field data (pR/ DO* residual chlorine/specific conductance/ temperature/ redox poten-

flR20067USerial numbers on seals and transportation cases

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To help eliminate possible problems in the chain-of-custodyprotocol/ one person will be appointed Field Custodian for eachinvestigation. For investigations where large sampling teams areused/ all samples are to be turned over to the Field Custodian bythe team members who collected the samples. The Field Custodianwill then document each transaction and the sample will remain inhis/her custody until it is shipped to the laboratory.Each sample must be labeled using waterproof ink and sealedimmediately after it is collected. Labels should be filled outbefore collection to minimize handling of the sample container.

Labels and tags must be firmly affixed to the sample containers.Be sure that the container is dry enough for a gummed label to besecurely attached. Tags attached by string are acceptable whengummed labels are not applicable.

The sample container should then be placed in a transportationcase/ along with the chain-of-custody record form* pertinentfield record* and analysis request form as needed. The transpor-tation case should be sealed or locked* Bowever* on thoseoccasions when the use of a chest is inconvenient* the collectorshould seal the cap of the individual sample container with tapein a way that tampering would be easy to detect. ;

When samples are composited over a time period* unsealed samplescan be transferred from) one field crew to the next. The transfer-ring crew lists the samples and a member of the receiving crewsigns the list. The receiving crew either transfers the samplesto another crew or delivers them to the laboratory.When transferring the samples/ the transferee must sign andrecord the dat'e and time on the chain-of-custody record (Figure2). Custody transfers made to a sample custodian in the fieldshould account .for each sample/ although samples may be transfer-red as a group. Every person who takes custody must fill in theappropriate section of the chain-of-custody record form. Tominimize custody records/ the number of custodians in thechain-of•possession should be minimized.The Field Custodian is responsible for properly packaging anddispatching samples to the appropriate laboratory. This respon-sibility includes filling out/ dating* and signing the appropri-ate portion of the chain-of-custody record.

All packages sent to the laboratory should be accompanied by theehain-of-custody record and other pertinent forms. A copy ofthese forms should be retained by the originating office (eithercarbon or photo copy). Hailed packages can be registered with

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return receipt requested. For packages sent by common carrier/receipts should be retained as part of the permanent chain-of-custody documentation.

jWriting chain-of-custody procedures/ as well as the variouspromulgated laboratory analytical procedures/ facilitates theadmission of evidence under Rule 803(6) of the Federal Rules ofEvidence (P.L..93-575). Under this statute/ written records ofregularly conducted business activities may be introduced intoevidence AS an exception to the "hearsay rule" without thetestimony, of the pecjo.n(s). .who .made the record,. Although it ispreferable/ it is' not a'lways possible for the individuals whocollected/ kept/ and analyzed samples to testify in court. Inaddition* if the opposing party does not intend to contest theintegrity of the sample or testing evidence* admission under Rule803(6)* can save a great-deal-of trial-time.- For-these reasons*.it is important to standardize the procedures followed incollection and analysis of evidentiary samples.

In criminal cases* however* records and reports of mattersobserved by -police-officers- and other law. enforcement .personnelare not included under the business record exceptions to the•hearsay rule" according to Rule 803(8)* P.L. 93-595. It isarguable that those portions' of the compliance inspection reportdealing with matters other than sampling and analysis resultscome within this exception.. For this reason* in criminal cases/records and reports of response team members may not be admiss-ible. The evidence may still have to be presented in the form oforal testimony by the person(s) who made the record or report/even though the materials come within the definition of businessrecords. \ ... ----- . . . . - . _ . . . . . . .In a criminal case/ the defense counsel may be able to-obtaincopies of reports prepared by a'witness* even if the witness doesnot refer to the records while testifying. If obtained/ therecords may be used in cross-examination.Records are not automatically admitted in either of theseactions. The business records section authorizes admission•unless the source of information or the method of circumstanceof preparation indicates lack of trustworthiness". The caveatunder the; public records reads "unless the sources of informationor other circumstances indicate lack of trustworthiness".

i|

Thus/ whether or not the team members anticipate that variousrecords will be introduced as evidence/ they should make certainthat all reports are as accurate and objective as possible.

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