>EPA
United States
Environmental Protection
Agency
                           Environmental Monitoring
                           Systems Laboratory
                           P.O. Box 93478
                           Las Vegas NV 89193-3478
EPA/600/8-89/046
March 1989
Research and Development
Soil Sampling
Quality Assurance
User's Guide
Second Edition

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                                                                               THE
              SOIL SAMPLING QUALITY ASSURANCE USER'S GUIDE

                                   Second Edition

                               PROJECT SUMMARY

       An  adequate quality assurance/quality control (QA/QC) program  requires the
identification and  quantification of all sources  of error associated  with each step of a
monitoring program so that the resulting data will be of known quality.  The components of
error,  or variance, include those associated with sampling,  sample preparation, extraction,
analysis, and residual error.  In the past, major emphasis often has been placed on QA/QC
aspects of sample analysis and closely associated operations  such as sample preparation and
extraction.   For monitoring  a  relatively inhomogeneous medium such as soil,  the sampling
component of variance will usually significantly exceed the analysis component  Thus, in this
case a minimum adequate QA/QC plan must include a section dealing with soil sampling. The
purpose of this document is to provide guidance in QA/QC aspects related to soil sampling.

       Generally soil monitoring is undertaken to carry out  the  provisions  and intent of
applicable environmental laws with high priority requirements associated with hazardous waste
management. The objectives of soil monitoring programs are  often to obtain data on the basis
of which to answer one or more of the following questions:

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       •      Are  the concentrations of specified soil pollutants in a  defined  study  region
              significantly different from the concentrations in a control region?

       •      Do the concentrations of specified soil pollutants in a defined region exceed
              established threshold action levels?

       •      At the measured concentrations of specified soil pollutants in a defined study
              region, what is the associated risk of adverse effects to public health, welfare, or
              the environment?

       For each of these applications,  the  QA/QC methods  and procedures cannot be
specified without giving careful consideration to the consequences of making an error,  for
example, in a decision to require or not to require cleanup of a contaminated region. It follows
in general  that to be maximally cost-effective and defensible  the  QA/QC objectives of a soil
monitoring program cannot be separated from the objectives of the soil monitoring program
itself.

       In general, the progression of events leading to the development of an adequate Quality
Assurance Program Plan (QAPP) follows the outline shown below:

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              1.      State study objectives.
              2.      Evaluate impacts of mistakes.
              3.      Define data quality objectives (DQOs).
              4.      Design study to achieve DQOs.
              5.      Design QAPP to confirm achievement of DQOs.

Often it will not be possible to specify in advance what DQOs are possible to achieve. In such
cases DQO goals should be set, a QAPP prepared, and a pilot study conducted to determine the
achievability of the goals.

       Present U.S. EPA guidance for development of DQOs requires that specifications for
the following factors must be addressed:

              •       precision,
              •       accuracy,
              •       completeness,
              •       representativeness, and
              •       comparability.

A sixth factor of importance to all of the above is the detection limit of the measurement
method used. Other important factors which should be considered in specifying DQOs include:

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              •      acceptable probability of a Type I error  (judging a clean area to be
                     dirty);
              •      acceptable probability of a Type II error (judging a dirty area to be
                     dean); and
              •      desired minimum detectable relative difference between two different
                     geographical areas.

       The development of DQOs involves an iterative interaction between management and
technical staff.  Management identifies the needs and resources available. The technical staff
develops guidance for assisting management in making the decisions required to develop the
DQOs.  The DQO process usually involves a three-stage process as outlined below.

              L      Identify decision types.
              2.      Identify data uses/needs.
              3.      Design data collection program.

The end result is site-specific guidance for evaluating and interpreting sampling data.

       Control samples are normally as important to a sofl monitoring study as are samples
taken from the study region.  The data from control samples aid in the interpretation of the
results from the study region and also help to identify sources and important transport routes

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for soil pollutants. Accordingly, the same level of effort and degree of QA/QC checks should
go into selecting and sampling a control region as goes into sampling the study region.

       In the sampling of a continuous medium such as  soil,  it is  necessary  to put  extra
emphasis on the definition of a sampling unit.  In  addition to having a specified location, each
sampling unit of soil has a certain three-dimensional volume, shape, and orientation. These
latter three characteristics, when taken together, are called the support of the sample. Changes
in support not only change  the  means of distribution,  they also change the  variances of
concentrations and the correlations of concentrations between sampling units.

       It is essential that  any action  level for soils be defined as a concentration over a
particular support and location relative to the ground surface.  In this definition of an action
level, the support is referred to in this document as the action support For example, the action
support might be defined as the top ten  cm of soil over a square area of 100 m2.

       The table below provides recommendations, as part of the DQO process, for confidence
levels,  powers, and minimum detectable  relative  increases over background  for different
operational situations.

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              Confidence Level    Power        Relative Increase over Background
                (1-a)            (1 - ft)        (100(M -/O//*n] to be Detectable
                                               with a Probability (I - 0)
Preliminary     70-80%          90-95%             10-20%
Site Investigation
Emergency      80-90%          90-95%             10-20%
Cleanup
Planned        90-95%          90-95%             10-20%
Removal and
Remedial Response
where et = probability of a Type I error and
      4» probability of a Type n error
       Both Type I (false positive) and Type n (false negative) errors should be considered in
hypothesis testing.  Tables and an equation are provided for use in determining the required
number of samples to achieve defined confidence levels and powers. The location of sampling
is also important Stratification of the sampling region may reduce the variance in cases where
the variance is considered to be unacceptably large.  Compositing of samples is generally not
recommended since it allows no estimate of the variance among the samples being composited.
However, some compositing of samples increases the representativeness of samples and may be
justified on that basis.

       Suggested types of QA/QC samples include various types of blanks, laboratory control
standards, calibration check standards,  triplicate samples (splits), duplicate samples,  various
kinds of audit samples, etc. How many samples of each type would be needed in  a  specific

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study is a question of considerable importance.  The recommended approach is to determine
how each type of QA/QC sample is to be employed and then determine the number for that
type based on  the use.  For example, field duplicates are used to estimate the combined
variance contribution of several sources of variation. Hence, the number of field duplicates to
be obtained in a study should be dictated by how precise one wants that estimate of variance to
be.

       Geostatistics (or kriging) is an application of  classical statistical theory to geological
measurements  that takes into account  the spatial  continuities of geological  variables in
estimating the distribution of variables. In many ways, geostatistics is for measurements taken
in 2-, 3-, and 4-dimensional space (the three spatial dimensions and the time dimension), what
time series is for measurements taken in one-dimensional space (time). However, a principal
use of time series is in forecasting; in geostatistics the principal emphasis is on interpolation.
Nevertheless, both statistical procedures emphasize modeling the process to get an insight into
the system being investigated.

       The application of classical statistical procedures to soil measurement data requires that
the samples be collected randomly (i.e^ not on systematic grids), that the data be independent
and identically  distributed (with the distribution being a normal distribution), and that the
measurement error variance (particularly the between-batch error variance) be a very small
part of the total variance of the measurements in a sample survey of a region.

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       In many soil sampling studies one or all of the following questions will be of primary
interest.

       •      Are  there  any action  supports within  the study area  that  have pollutant
              concentrations above action level?

       •      Where are the above-action-level action supports located?

       •      What is the spatial distribution  of pollutant concentration levels among action
              supports that have pollutant concentrations above action level?

       Hie problem with posing soil sampling  methods and objectives in terms of population
means is that the mean will depend on the size  of the area chosen and  the distribution of
contamination throughout that area.  For example, the mean in a small area may exceed the
action level; but if the size of small area is increased by adding a substantial amount of less
contaminated soil, the mean in the larger area  may not exceed  the action limit. Decisions on
the need for remedial action should not be based on how one chooses the size of the area to be
sampled, but rather on whether action supports  exist that are above designated action limits. A
comparison of means  is reasonable in comparing pollutant concentrations at a background site
with pollutant concentrations of a site down-gradient from a suspected hazardous waste source.
Also, deanup areas may be defined so that the average concentration in those units of soil may
be compared with a standard.
                                          8

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       It follows from the above discussion that for most applications, geostatistica! procedures



for designing soil sampling studies and analyzing resultant data are  generally preferred over



classical statistical procedures.







       Once objectives have been defined for a soil monitoring study,  a total study protocol,



including an appropriate QA/QC program must be prepared.  Usually not enough is known



about the sources and  transport properties  of  the  soil pollutants  to accomplish  this in a



cost-effective manner without additional study.   The suggested  approach is to conduct an



exploratory study including both a literature and information search followed by selected field



measurements based on an assumed dispersion model The data resulting from this exploratory



study serve as the basis for the more definitive total study protocol  If one is dealing with a



situation requiring possible emergency action  to protect  public health,  it  is  necessary to



compress the planning and study design into a short time period and proceed to the definitive



study without delay. In either case, the objectives of the monitoring study constitute the driving



force for all elements of the study design, including the QA/QC aspects.







       To develop the exploratory study protocol with its associated QA/QC plan, one needs



to combine into an assumed dispersion model  the  information obtained prior to any field



measurements. On the basis of this model, the standard deviation of the mean for soil samples



is estimated.   Value judgments are used to define required  precision and confidence levels



(related to acceptable levels  of Type I or Type II errors).  A  control region is selected.  The



numbers of required samples may then be calculated. Additional samples should be required to

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validate the assumed  model.   The locations of the  sampling sites should he selected by an



appropriate combination of judgmental (use of the assumed model), systematic (to allow for the



fact that the model may be wrong), and random (to minimize bias) sampling.  Sampling and



sample  handling must be accomplished according to  standardized  procedures  based on



principles designed to achieve data of both adequate quality and  maximal cost-effectiveness.



Particular attention should be given to factors surrounding the disposition of non-soil materials



collected with the soil samples.







       The requirements for QA/QC for the exploratory study need not be as stringent as for



the more definitive study in the sense that acceptable precisions and confidence levels may be



relaxed somewhat   Allowance should be made, however,  for the  collection of a modest



additional number of QA/QC samples over that specified in the QA/QC plan to verify that the



QA/QC study design is adequately achieving its assigned objectives. Also, all normal analytical



QA/QC checks should be used.







       If the exploratory study is conducted well, it  will  provide some data for achieving the



overall objectives of the total monitoring study; it will provide a check of the feasibility and



efficacy of all aspects of the monitoring design including the QA/QC plan;  it will  serve as a



training vehicle for all participants; it will pinpoint where additional measurements need to be



made; and it will provide a body of information and data which can be incorporated into the



final report for the total monitoring study.
                                          10

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       For the more definitive study, the selection of numbers of samples and sampling sites,
sample collection procedures, and sample handling methods and procedures follow and build on
the principles discussed and results obtained in the exploratory study.

       Frequency of sampling is an important aspect of the more definitive study which usually
cannot be addressed in the exploratory study because of the relatively short time span over
which the exploratory study is conducted.  The required frequency of sampling depends on the
objectives of the study, the sources of pollution, the pollutants of interest, transport rates,  and
disappearance rates (physical,  chemical,  or biological transformations as well as dilution or
dispersion).  Sampling frequency may be related to changes over time, season, or precipitation.
An approach that has been used successfully has been to provide intensive sampling early in the
life of the study (e.g^ monthly for the first year) and then  to decrease the frequency as the
levels begin to drop.  The important principle is that the sampling should be conducted often
enough that changes in the concentrations of soil pollutants important to the achievement of
the monitoring objectives are not missed.

       The important questions to be answered in the analyses and interpretation of QA/QC
data are: "What is the quality of the data?" and "Could the same objective have been achieved
through an improved QA/QC design which may have required fewer resources?" It is desirable
to provide summarized tables of validated QA/QC data in the  final report. This  approach
allows users to verify the  reported  results  as  well  as  begin to  build a  body of QA/QC
experimental data in the literature which allow comparisons to be made among studies. Special
                                          11

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emphasis should he placed on how overall levels of precision and confidence were derived from



the data. If portions of the study results are ambiguous and supportable conclusions cannot be



drawn with regard to the reliability of the data, that situation must be clearly stated.







       The adequacy  of all aspects of the QA/QC plan  should be examined in  detail with



emphasis on defining for future studies an appropriate minimum adequate plan. Some aspects



of the QA/QC plan  may have been too restrictive; some may not have been restrictive enough.



Soil monitoring studies should have checks and balances built into the QA/QC plan which will



identify early in the study whether the plan is  adequate and, if required,  allow for corrective



action  to be taken  before the  study continues.   This is one of the major  advantages of



conducting an exploratory study.







       There is insufficient  knowledge dealing with soil monitoring  studies to state with



confidence which portions of the QA/QC plan will be generally applicable to all soil monitoring



studies and which must vary depending on site-specific factors. As experience is gained, it may



be possible to provide more adequate guidance on this subject   In the  meantime,  it is



recommended that many important factors of QA/QC plans be considered  as site-specific until



proven otherwise.







       Another important aspect of QA/QC is auditing. The purpose of an audit  is to insure



that all aspects of the QA/QC system planned for the project are in place and functioning well.



This includes all aspects of field, sample bank, and laboratory operations. Whenever a problem
                                          12

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is identified,  corrective action  should  be initiated  and pursued  until corrected.   Sample
chain-of-custody procedures and raw data are checked as  appropriate, and results of blind
QA/QC samples routinely inserted into the sample load are reviewed. Spot checks of sampling
methods and  techniques,  sampling and  analysis calculations,  and  data transcription  are
performed.  Checks are made to ascertain that required documentation has been maintained
and  in  an  orderly fashion, that each  of the recorded  items  is properly categorized, and
cross-checking can be easily accomplished.  Checks  are  made  to insure that data recording
conforms to strict document control protocols and the program's QA/QC plan.

       It is recommended that an audit of the overall QA/QC plan for sample documentation,
collection, preparation,  storage, and transfer procedures be performed just before sampling
starts.  This is to review critically the entire sampling operation to determine the need for any
corrective action early in the program.

       The project leader of a soil monitoring project is responsible for ascertaining that all
members of his project team have adequate training and experience to carry out satisfactorily
their assigned missions and functions. This is normally accomplished through a combination of
required classroom  training,  briefings on the  specific monitoring project about  to be
implemented, and field training exercises. Special training programs should be completed by all
personnel prior to their involvement in conducting audits.
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                                        EPA 600/8-89/046
                                            March 1989
Soil Sampling Quality Assurance
             User's Guide
                  Second Edition
                     by
        Delbert S. Barth, Benjamin J. Mason,
      Thomas H. Starks, and Kenneth W. Brown
       Cooperative Agreement No. CR 814701
          Environmental Research Center
          University of Nevada-Las Vegas
            Las Vegas, Nevada 89154
         Kenneth W. Brown, Project Officer
       Exposure Assessment Research Division

    Environmental Monitoring Systems Laboratory
        Office of Research and Development
          Las Vegas, Nevada 89183-3478

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                                     NOTICE
       The information in this document has been funded wholly or in part by the United



States Environmental Protection Agency under Cooperative Agreement CR 814701 to  the



Environmental Research Center.  It has been subject to the Agency's peer and administrative



review and has been approved for publication as an EPA document.
                                         11

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                                    CONTENTS
                                                                            Page

Figures      	    v
Tables       	    v
Preface      	    vi

1.      Introduction  	   1
             Objectives    	   1
             Audience    	   2
             Approach    	   3
             Background  	,	   4
2.      Purposes for Soil Sampling   	   7
3.      Data Quality Objectives     	   16
             Measurement Concepts      	   24
             Stages for Developing DQOs 	   28
4.      Quality Assurance Project Plans     	   60
5.      The Concept of Support     	   66
6.      Exploratory Study    	   73
             Example of an Exploratory Study    	   78
             Sample Design       	   79
             Data Transformations	   82
             Quality Assurance Data      	,	   83
7.      Guidance for Specific Soil Sampling Programs      	   85
             Objectives for Background Monitoring	  90
             Specific Monitoring Objectives in CERCLA and RCRA    	  92
             Preliminary Site Investigation	   104
             Emergency Clean-up 	  105
             Planned Removal and Remedial Response Studies   	   107
             Monitoring or Research Studies     	   109
8.      Selection of Numbers of Samples and Sampling Sites for the
       Definitive Study     	   110
             Introduction  	   110
             Number of Sampling Sites Required 	   114
9.      Control of Measurement-Error Variance    	   119
             Introduction  	   119
             Goals  	   122
             Components of Variance    	   124
             QA Samples  	,	   127
             Bias   	   137
10.    Sample Design and Data Analysis    	   140
             Sample Design       	  140
             Role of Quality Assurance   	,	   146
             Geostatistics  	   149
             Objectives    	   154
             Design for Hot Spot Detection      	   157
             Some Classical Statistical Procedures	   160
11.    Sample Documentation, Collection, and Preparation	  170
             Introduction  	   170
             Documentation      	  173
             Sample Collection    	  184
             Sample Preparation	  187
             Quality Assurance Aspects   	,	  199
                                         ui

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                               CONTENTS (continued)

12.    Analysis and Interpretation of QA/QC Data	 200
              Introduction  	 200
              Presentation of data summaries      	 201
              Presentation of results and conclusions      	 203
              Quality assurance aspects    	 204
13.    System Audits and Training   	 206
              Introduction  	 206
              Sample bank audit    	 209
              Field audits   	 211
              Training      	 212
Glossary      	 213
References    	 222

Appendices
       A.     Application of Soil Monitoring Data to an Exposure and Risk
              Assessment Study     	 A-l
       B.     Percentiles of the t Distribution      	 B-l
       C.     Data Quality Objectives Development Process      	 C-l
                                          IV

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                                 LIST OF TABLES

1.      Summary of Data Needs     	  44
2.      Results from Duplicate Samples at the Palmerton NPL Site 	  71
3.      Results from Individual Cores at the Palmerton NPL Site   	  72
4.      Number of Samples Required in a One-sided, One-sample t-test   	  Ill
5.      Results from Splits at the Palmerton NPL Site       	  130
6.      Type of QA/QC Samples or Procedures     	  132
7.      Some 95% Confidence Intervals for Variance       	  135
8.      PCB Measurements (Hypothetical Data)    	  167
9.      Accountable Documents     	  177
10.     Sampling Containers, Preservation Requirements, and Holding
       Times for Soil Samples      	  194

Appendix B - Percentiles of the t Distribution      	,	  B-l


                                 LIST OF FIGURES

1.      Three Stages in the DQO Process    	  23
2.      Elements of a Conceptual Model     	  39
3.      Steps in Defining the Attainment Objectives 	  49
4.      Palmerton Exploratory Sampling Design    	  80
5.      Data Acquisition Flow for Hazardous Materials     	  95
6.      Monitoring Data Flow      	  100
7.      Technology  Transfer  Data Flow      	  102

Appendix A
A-l.   Elements of Toxicologic Studies to Assess Adverse Effects Related to
       Exposure to Environmental Pollutants      	  A-5
A-2.   Generalized Spectrum of Human Responses to an Environmental
       Pollutant     	  A-6
A-3.   Possible Exposure Pathways from a source of Environmental Pollution to man	  A-8
A-4.   General Model for Converting Environmental Pollutant Measurements in various
       Media into Estimated Total Exposure to Humans   	  A-9
A-5.   Relationship of Total Human Exposure to Possible Effects and to Risk Estimation  A-10
A-6.   Three Hypothetical General Classes of Exposure-Response
       Relationships  	  A-ll
A-7.   Exposure Monitoring Elements Requiring Quality Assurance      	  A-13
A-8.   Hypothetical Exposure Distribution  	  A-14
A-9.   Equation for Estimating Total Lifetime Dose to TCDD    	  A-16
A-10.  Estimated Daily Deposition of Soil on Human Skin by Age 	  A-18
A-ll.  Concentrations of TCDD in Soil that  are Projected to Produce the
       Maximum Allowable  Residues in Foods     	  A-20
A-12.  Estimated Average Daily Dose Corresponding to Initial TCDD-Soil
       Contamination Levels	  A-21

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                                       PREFACE
       Use of the first edition of the "Soil Sampling Quality Assurance User's Guide" as a text in a



series of seminars conducted at various U.S. EPA Regional Offices elicited many constructive



comments for improvements from seminar attendees.  Many of these suggested improvements



have been incorporated in this second edition.







       Specifically, the references have been updated,  particularly through the incorporation of



recent U.S. EPA guideline documents. More attention has been given to experimental design,



specifically to procedures for developing data quality  objectives.  The statistical coverage has



been  expanded considerably to include an introduction to applications  of geostatistics and a



discussion of requirements for the definition of support  in conjunction with guidance for soil



sampling.







       This report  is intended  to be a living document providing state-of-the-art guidance.



Accordingly,  from  time to time  revisions will be prepared to maintain harmony  with



improvements in soil sampling quality assurance methodology. Future revisions will be prepared,



and authorship identified, on a chapter-by-chapter basis.
                                           VI

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                                     CHAPTER 1

                                   INTRODUCTION


OBJECTIVES



       This document is  a user's guide presenting and explaining selected principles and

applications of methods and procedures for establishing adequate quality assurance on soil

sampling aspects of environmental monitoring programs.  Soil sampling aspects treated include

sample site selection, sample collection, sample handling, sample analysis, and interpretation of

resulting data. No detailed treatment of analytical quality assurance procedures is given, since

that important aspect has been adequately treated elsewhere  (U.S. EPA, 1982; U.S.  EPA,

1984b).  It  should be noted, however, that sampling quality  assurance procedures  are not

separable from analytical  quality assurance procedures.   This  is particularly true for sample

collection and handling.  If an intact,  timely,  and representative sample of proper size and

composition is not delivered to the analytical laboratory, the analytical methods and associated

quality assurance procedures cannot yield meaningful results.  Thus, the soil  sampling quality

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assurance procedures presented here should be viewed as an important, integral part of the

overall quality assurance plan.



       In this second edition of the Soil Sampling Quality Assurance User's Guide, the authors

have included guidance  on developing Data  Quality Objectives  (DQOs) and have added

additional examples to  aid the user in preparing an adequate soil sampling quality assurance

plan.  This guide is not intended to be a generic plan for all sites; it is presented as a guidance

document only. By adhering to the principles and procedures outlined, the user should be able

to develop a quality assurance plan that will meet most soil sampling needs.



AUDIENCE



       This document  has been developed to serve  as a  user's guide for anyone designing,

implementing, or overseeing soil monitoring programs. It is especially applicable for personnel

responsible for regulatory programs where soil monitoring is an important integral element.

Special attention is given to soil sampling examples related to CERCLA, since such applications

are deemed to be high priority sampling programs.  Many of  the principles and procedures

discussed, however, are applicable to other situations as well.

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APPROACH



       Following the discussion below of the background of quality assurance procedures used

by the U.S.  Environmental Protection Agency (U.S. EPA), Chapter 2 addresses purposes for

soil sampling and Chapter 3 addresses the development of DQOs for various aspects of soil

sampling. Chapter 4 presents an outline of the objectives of quality assurance plans. Chapters

7 through 10 deal with statistical aspects of experimental design, soil support, quality assurance/

quality control (QA/QC), hypothesis testing, etc.  Some attention will be focused on  both

geostatistics and a technique known as the components of variance analysis. The components

of variance analysis results from the use of a statistical sampling plan designed to measure as

many of the sources of variation as can  be identified and sampled in a cost-effective manner.

The analysis further identifies the amount of total sample error (or variance) that results from

each component in the sampling-analysis chain.



       Discussion of the value of an exploratory study (Chapter 6) to the subsequent design of

a soil sampling quality assurance program  leads logically into more detailed discussions of

sample site  selection, sample collection, and sample handling (Chapter 11).  These detailed

discussions will include minimal coverage of soil monitoring protocols per se, since they  have

been treated in a comprehensive document (Mason, 1983).  The focus of the discussions will be

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quality assurance.  The goal of each discussion will be the development of design features for

sample  site selection,  sample collection,  and sample handling to meet quality assurance

objectives of defined power and levels of confidence for each subject area.



        The goal of the discussion concerning analysis and interpretation of data (Chapter 12)

will focus on quality assurance aspects.  The goals of the discussion concerning analysis and

interpretation of data program audits and personnel training are treated in Chapter 13. To the

maximum extent feasible throughout this report, we will first present concepts and principles,

followed by selected examples of how these concepts and principles may be applied in realistic

situations.



BACKGROUND



       Since its founding, the U.S. EPA has been aware that the environmental data needs of

the Agency require that quality assurance and quality control (QA/QC) meet predetermined

standards.  U.S. EPA Order 5360.1 (U.S. EPA, 1984) establishes the responsibilities of National

Program Managers in the Agency's Mandatory  Quality  Assurance Program.    These

responsibilities include ensuring that "data quality acceptance criteria" and QA Project Plans

are prepared for all data collection projects  sponsored by the Agency.  In a memorandum of

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April 17,  1984,  accompanying the issuance of Order  5360.1,  Deputy Administrator  Aim

identified two steps that must be taken to ensure that all data collected by the U.S. EPA are

suitable for their intended use:



       "...the user must first specify the quality of data he needs; then the degree of quality

       control necessary to assure that the resultant data satisfy his specifications must be

       determined."



       The first  step is accomplished  through  the development of Data Quality  Objectives

(DQOs).  Data Quality Objectives are qualitative and quantitative statements developed by

data users to specify the quality of data needed from a particular data collection activity  (U.S.

EPA  1987a).   DQOs  must address  five data  characteristics: precision,  accuracy,

representativeness, completeness,  and comparability.   A sixth  data characteristic,  level of

detection, should also be addressed since it is closely related to the other five.  In addition,

DQOs should specify allowable probabilities of false positive (Type I) and false negative (Type

II) errors. In order to determine required numbers of samples, another important factor  is the

desired  minimum detectable relative  difference  between two data sets taken at different

locations or times.  The data quality characteristics addressed are sometimes referred  to as

measurement DQOs, while the probabilistic goals are termed system DQOs.

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       The second step in the QA process is the preparation of quality assurance project plans

(QAPPs).  The QAPP addresses the procedures to be followed to assure that the needs

expressed by the DQOs are met.  The DQOs become plumblines against which  the  data

generated by a sampling effort can be evaluated. The whole quality assurance process is carried

out to insure that the regulator,  decision maker,  or researcher has reliable data of known

quality.



       The chapters that follow address the various steps required to assure the quality of soil

sampling data.

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                                     CHAPTER 2

                          PURPOSES FOR SOIL SAMPLING


       The mission of the U.S. EPA is to control environmental pollutants to abate potential

adverse effects on man and/or the  environment.   Complying with this mission  requires

identifying significant sources of pollutants of concern and linking these emission sources to

adverse effects upon critical receptors.  This Unking is done through exposure assessment. To

carry out the intent of CERCLA,  for example, concentrations of hazardous  pollutants in

environmental media, including soils,  should not be allowed to exceed  levels established as

being adequately protective of humans and the environment.  Identification of the sources of

the pollutant of concern should include not only the present emissions but also an assessment of

probable future emissions.  From a soil perspective,  one needs to establish the role of soils as

sources or sinks for selected air or water pollutants and how that role may change in time and

space, as well as the effect of such physical parameters as temperature, wind direction and

speed, water flow rates, and geological factors on that role.  Biological factors within the soil

matrix may also be involved in the degradation or transformation of pollutants into different

chemical substances.

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Specifically, soil sampling efforts can be designed and conducted to:

•      determine the extent to which soils act as either sources or sinks for air or water

       pollutants,

•      determine the risk to human  health and/or  the environment from soil

       contamination by selected pollutants,

•      determine the presence and concentration of specified pollutants in comparison

       to background levels,

•      determine  the  concentration of pollutants and  their spatial and temporal

       distribution,

•      measure the efficacy of control or removal actions,

•      obtain measurements for validation or use of soil transport and deposition

       models,

•      determine the potential risk to flora and fauna from specific soil pollutants,

•      identify pollutant  sources,  transport mechanisms  or  routes,  and  potential

       receptors,

•      contribute  to  a  research technology transfer or environmental model

       development study, and

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       •      meet the provisions and intent of environmental laws such as the Resource

              Conservation and Recovery Act (RCRA), the Comprehensive Environmental

              Response, Compensation, and Liability Act (CERCLA), the Federal Insecticide,

              Fungicide, and Rodenticide Act (FIFRA), and the Toxic Substances Control Act

              (TSCA).



       Soils encompass the mass (surface and subsurface)  of  unconsolidated mantle of

weathered rock and loose material lying above solid rock. The soil component can be defined

as all mineral and naturally occurring organic material 2 mm or less in particle size. This is the

size normally used to distinguish between soils (e. g.,  sands, silts,  and clays) and gravels.  In

addition, the 2-mm size is generally compatible with analytical laboratory methods/capabilities.

Organic matter is commonly found in many soils and must be considered as an integral part of

the soil.



       The non-soil fraction (e.g., automobile  fluff,  wood chips,  various  absorbents and

mineral/organic material  greater than 2 mm) must also  be addressed  during  the sampling

effort.  This component may contain a greater amount of contaminant(s) than the associated

soil.   At sites in which this occurs reporting  contaminant levels only in the soil fraction will

ultimately lead to inappropriate and incorrect decision  making.  Decision makers must be

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aware that a number of problems are normally encountered in obtaining and using data from

non-soil components.  For example, questions arise concerning the validity of data obtained

from the analysis of materials that do not meet the size and volume requirements in which the

analytical processes  were validated.  Also, standard reference  and audit materials are not

available to substantiate and validate analytical results. The current recommended procedures

are to identify and record the type and volume of non-soil material for each sample collected.

A minimum of 10 percent of these non-soil samples should be submitted for analysis.  Proper

data assessment and  conclusions made from these results are paramount to the success of a soil

sampling program.



       The behavior of pollutants in the soil environment is a function of the pollutant's and

soil's physical and chemical properties. Soil sorption (the retention of substances by adsorption

or absorption) is related to properties of  the  pollutants (e.g., solubilities, heats of solution,

viscosity,  and vapor pressure)  and to properties of soils (e.g., clay content,  organic content,

texture, permeability,  pH, particle size, specific surface area, ion exchange capacity,  water

content, and temperature). The soil components that are most associated with sorption are clay

content and organic matter.  The soil particle surface  characteristics thought to be  most

important in adsorption are surface area and cation exchange capacity (CEC).
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       The extreme complexity and variability of soil necessitates a multitude of sampling/

monitoring approaches. The investigator must select methods and approaches that will satisfy

the stated program objectives while accommodating specific site needs.



       Both field and laboratory tests are necessary to understand the presence and behavior

of pollutants  in soil.  Field tests primarily supply definitive information for soil classification

and its relation to on-site environmental conditions.  Laboratory tests supply analytical data

beyond  the capabilities of most field measurements,  such  as the type and quantity of a

pollutant.



       Soil containment measurements may be source-, transport-, or receptor-oriented, or

some combination.  For example, if the major concern is possible risk to human receptors, it

may be wise to take early measurements in the immediate vicinity of the receptors to obtain the

best estimates of exposures resulting from soil contamination.  If exposures are deemed to be

insignificant or acceptable,  no further measurements may be required.   If, however,  the

exposures are deemed to be unacceptable, additional measurements will be required to identify

both important pollutant sources and  important  exposure pathways.   Information on these

matters will be necessary to devise cost-effective control strategies.
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       Determination of risk to human health and the environment from contaminated soils

involves several steps.  Required are exposure and dose distributions to the most sensitive

populations or receptors of  concern via all  significant exposure pathways.  This will  involve

possible soil-related exposure from other media such as air or water, exposure from the soils

themselves either through ingestion, inhalation, or skin absorption, as well as exposure through

ingestion of foods contaminated directly or indirectly from the soils.  An additional parameter

is the biological availability of the pollutant(s) of concern. Thus, it is important to measure or

estimate the extent to which  the soils act as sources (through contacting air or waters) for the

pollutant(s) of concern.  Knowing the concentration of pollutants in air or water originating

from contaminated soils is not sufficient for estimating exposure. An additional parameter

required is the biological availability of the pollutant(s) of concern.   For example,  if soil

pollutants are not incorporated into the edible parts of crops or animal products, even large

concentrations in the soil might  not lead to  significant human exposure through ingestion of

food stuffs. In such an instance, however, inhalation of vapors from the soil or ingestion of

drinking water might constitute an important exposure pathway.



       Once desired exposure or  dose distributions have  been constructed,  comparison to

established exposure or dose-response relationships enables a determination of whether or not
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the existing risk is acceptable. Underestimating exposures or doses might lead to accepting an

unacceptable risk,  whereas  overestimating might lead  to unnecessary,  and  possibly costly,

control actions.  A detailed case study showing how an action level for dioxin in soil was derived

is presented in Appendix A.



       If significant quantities of pollutant(s) become permanently attached to soil and remain

biologically unavailable, the soils may constitute a sink.  Pollutant control needs in these cases

may  be reduced by  the amounts  by which the  soils reduce  the pollutant availability.

Underestimating the ability of soils to act as a sink might lead to source control requirements

more stringent  than necessary, whereas overestimating might lead to less stringent control

requirements than necessary.



       If significant quantities of selected pollutants are found to be associated  with soils

initially and then released slowly over relatively long periods of time, the soils, in essence, act as

pollutant sources.   Underestimating the extent to which  soils act as  sources will lead to

inappropriate and insufficient controls of other additional sources, whereas overestimating may

lead to expensive soil removal to a greater degree than necessary.  Soil removal as a cleanup

measure is a complicated proposition.  It involves extensive testing of the soils and evaluation of
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proposed disposal options to determine which option will have the least environmental impact

with due regard for cost.



       Soil sampling to measure the efficacy of control or removal actions must be preceded by

the establishment of unacceptable concentrations of pollutants of  concern in soil.   Once

unacceptable concentrations, or action levels, have been identified, it  is then possible to devise

sampling plans with defined probabilities of Type I or Type H errors. A critical consideration in

this instance will be the depth and surface areal extent of the soil sample on the basis of which

the soil concentration will be calculated.  This  is addressed in greater detail in a subsequent

chapter dealing with the concept of sample support and "action support" (Chapter 5).



       Soil  sampling for validation or use  of  soil transport and deposition models will not

normally  lead to control actions.    Positive  or negative errors  are  unlikely to lead  to

corresponding over- or underestimates of control needs.  However, errors of unknown direction

and size, if sufficiently large,  might seem to  validate an erroneous model or fail to validate an

acceptable model. The consequences of such errors cannot be evaluated without knowing the

purposes for which the model might be used and what actions might be taken on the basis of

conclusions drawn from the model.
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       Prior to  undertaking  any soil sampling program to  achieve defined objectives,  it is

necessary to establish  appropriate  measurement and system DQOs.   These should be

established  after due  consideration  of the consequences  of taking actions which might

subsequently be shown not to be justified on the basis of the available data.



       Once appropriate DQOs have been established, an operational protocol should be

prepared, setting forth what is to be done for what purpose  and how, when, where, and how

many samples will be collected.   Also, the protocol should indicate how the samples will be

preserved, prepared for analysis, and then analyzed for what  substances, and how the resulting

data will be validated, analyzed, and interpreted.  As part of this protocol,  a complete QA/QC

plan must be included covering all aspects of the experimental program with special attention to

sampling aspects. Quality assurance is defined as the system of activities required to provide a

quality  product,  whereas quality control is  the system of activities required to  provide

information as to whether the quality assurance system is performing adequately.  It cannot be

overemphasized that an adequate QA/QC program cannot be tailored for a study until a clear

statement of monitoring objectives has been provided, together with allowable errors.
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                                     CHAPTERS

                            DATA QUALITY OBJECTIVES


       Studies conducted in the past were often controlled by data quality that was considered

to be the "best data possible" (U.S. EPA, 1986-b). It was not uncommon to expend considerable

resources on a sampling and analysis program, only to find that the samples were not collected

in a manner that would allow valid conclusions to be drawn from the resulting data. The "best

data possible" approach provided useful data in some cases but frequently lacked the scientific

rigor required for the regulatory arena. The development of Data Quality Objectives (DQOs)

is an attempt to provide the rigor required to meet the data needs of the U.S. EPA.



       "Data Quality Objectives are  qualitative and quantitative  statements of the quality of

data needed to support specific decisions or regulatory actions" (U.S. EPA,  1986a).   The

important starting point for the  detailed design of a data collection effort, DQOs are the basis

for specifying the quality assurance and quality control activities and requirements associated

with the data collection process.  During the detailed planning and preparation of technical
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guidance for data collectors, DQOs are used as the key for developing explicit,  quantitative

statements of the type of errors that will be controlled, the level to which those errors will be

controlled, and the information that will be collected in order to characterize all of the known

sources of error.  These quantitative statements are known as data quality indicators.  Data

quality indicators are needed to select appropriate methods for sample collection, laboratory

analysis, and statistical data analysis.  They also form  the  basis for selecting QA and  QC

procedures (U.S. EPA, 1987a).



       The DQO process is a dynamic process that has not yet been implemented uniformly in

all regions; therefore, the information presented in this document is for guidance only.  The

three-stage process envisioned in guidance  documents (U.S.  EPA, 1986a, 1987a)  includes

requirements for the following factors to be addressed:



                     •  precision,

                     •  accuracy,

                     •  completeness,

                     •  representativeness, and

                     •  comparability.
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A sixth factor, "detection limit," has been added by the authors as a critical factor which should

be considered in specifying the other five factors.



       Statistical rigor, combined with managerial and budgetary guidance, should be used to

develop the specific objectives required to develop the specifications for the above factors.

Statistical sampling is a mechanism by which the QA/QC program can determine the sampling

precision and provide a measure of the reliability of the entire sampling effort.



       It  is essential that the  reliability of the data be reported.  Buffington (1978) quotes

Congressman George E. Brown, Jr., as saying "no number is significant, and subsequently

worthy of being recorded, without an estimate of its uncertainty."  This statement should be

considered when designing the QA/QC plan for a soil sampling effort because soil is by its very

nature extremely variable.   Superimposed on this natural variability are other sources of

variation  or error that can be introduced into the final result by the sampling and analytical

efforts.  These sources of variation  can lead a  manager to conclude that an area needs no

remedial action when, in fact, it does need such action (called a Type n error) or, alternatively,

conclude an action is needed when, in fact, no actions should be taken (called a Type I error).
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       To establish an adequate, cost-effective QA/QC plan for a soil monitoring program, it

is necessary, after careful analysis of the consequences, for a decision-making official to specify

probabilities of Type I and Type n errors that will be allowed in making decisions based on

sample data.



       The acceptable probability for each type of error must be established in relation to the

consequences  of making such errors and depends upon the specific  objectives  of  the soil

monitoring program.  The Type I error is the error most often considered in the literature.  In

environmental monitoring, however, a Type n error may be more important than a Type I

error.  The clean-up of a highly toxic spill would be an example where a false negative could

create major problems for the project manager. The Type n error would lead the manager to

conclude that a clean-up of some areas is not necessary when, in fact, the action levels are being

exceeded and clean-up is necessary.  The probabilities of Type I and n errors for the  QA/QC

effort should equal the probability levels chosen for the overall sampling effort itself.  This

acceptable probability of error in different cases may, for example, range from 20 percent to 1

percent or less.  In some circumstances, the level selected by value judgment may simply be a

statement of a probability of error  not to be exceeded  in the final data.   The authors are

proposing that these  two probabilities be included as system DQOs in conjunction  with the
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measurement  DQOs outlined  earlier, i.e.,  precision,  accuracy,  representativeness,

completeness, comparability (PARCC), and detection limit.



       There may be a  temptation in many cases to avoid making the necessary value

judgments concerning acceptable probabilities of making different kinds of error.  The course

of action often substituted for the difficult value judgment is to adopt as a guiding principle the

concept that one should always strive to achieve the highest power and level of confidence (or

lowest probability  of error) possible with existing available resources.  The resulting data are

then used as the basis for making decisions with the assumption that this guiding principle gives

the best possible result. Obviously, such an approach will rarely, if ever, be cost effective. Two

types of errors are possible.   The  data  may be much better than required,  which indicates

resources have been wasted,  or the data may not be of adequate quality, thereby resulting in

decisions of doubtful  validity.   This point may be  summarized by  stating  that resource

availability is an important factor for consideration in the establishment of quality assurance

programs, but resource availability should not be accepted as the sole determinant of required

quality assurance  methods and procedures.  Maximal cost effectiveness should be the overall

goal.  This generally means that a minimum adequate quality assurance plan must be defined

and then implemented.  The DQO process has been designed to incorporate both cost and
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reliability of the data as a first principle, and thus precludes the tendency to use cost as the

single guiding principle for implementing a particular sampling design.



       Once system and measurement data quality objectives (DQOs) have been set on the

basis of acceptable risks of making mistakes in any resulting decisions, an experimental design

can be adopted to achieve the required DQOs.  The purpose of the Quality Assurance Project

Plan (QAPP) then becomes the collection and analysis of adequate QA/QC samples to confirm

the achievement of the DQOs.  Another way of stating this is that the objective of the QAPP is

to define the procedures used to achieve the desired quality of the data and thus insure that it is

adequate to the degree required for its intended end use.  (These matters will be covered more

extensively in subsequent chapters).



       Guidance on the DQO process (U.S. EPA, 1987a) identifies three stages for arriving at

the quality of data to be used:



       1)     Identify decision types,

       2)     Identify data uses/needs, and

       3)     Design data collection program.
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Figure 1 identifies each stage along with the tasks covered in each stage,  Thus, the DQO

process becomes an iterative interaction  between  management  and  the technical  staff.

Management identifies the needs and  resources available.   The technical staff  develops

guidance for assisting management in making the decisions required to develop the DQOs.

The end result is site-specific guidance for evaluating and interpreting sampling data.



       Agency guidance (U.S. EPA,  1987a) provides the basis for developing the DQOs.

Statistical designs should be used so that the quality assurance procedures can verify that the

DQOs are being met. Where possible, numerical values or limits should be placed on precision,

accuracy,  representativeness, completeness, comparability, and detection limits.  Once these

numerical measures are defined, the preparation of statistical  designs, sampling protocols and

quality assurance plans can be initiated.  The result of such a  process meets the needs of the

Agency for quality data, addresses the requirements of the user, and aids the technical staff in

providing the quality of services requested.



       Chapters 7 through 10 discuss in detail the statistical aspects of sample design and data

evaluation.
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                       Stage 1
              Identify Decision Types
            • Identify and involve data users
            • Evaluate available data
            • Develop conceptual model
            • Specify RI/FS objectives
                         1
                       Stage 2
             Identify Data Uses/Needs
              Identify data uses
              Identify data types
              Evaluate sampling/analysis options
              Identify data quantity needs
              Identify data quality needs
              Specify PARCC goals
                       Stage 3
         Design Data Collection Program
            • Design program
            • Develop data collection documentation
Figure 1:  Three Stages of the DQO Process (U.S. EPA, 1987a)

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       The soil sampling requirements of both CERCLA and RCRA are site-specific.  A

history of the site, including the sources of the pollutant and a conceptual model of the routes

of exposure should be developed before the sampling plan is finalized.  It may be necessary to

conduct an exploratory study before this  conceptual model can be confirmed  or a different

model defined.  (Chapter 6 outlines guidance for conducting the exploratory study.) This study

should provide  insight into the types of pollutants present, the population  at  risk, and the

magnitude of the risk. These factors can then be combined to design the final sampling plan

and to specify the size of sampling unit or support (Chapter 5) addressed by each sample or set

of samples.



MEASUREMENT CONCEPTS



       The following three sections discuss some basic  concepts that must  be kept in mind

when developing data quality objectives for soil sampling.  These concepts may have application

in other types of sampling, but they are considered to be particularly pertinent to soil sampling

efforts.
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Support



       As presented in Chapter 5, the support for a sample is the unit of soil that the sampling

effort measures.  The support has a specific size, shape, and orientation. In the vernacular of

the soil scientist, this unit of soil is not too unlike the pedon in terms of its dimensions and

definition (Soil Survey Staff, 1975).  The choice of support can significantly affect the precision

of estimates obtained from the survey data (Starks,  1986).



       Risk and exposure assessment data can be used to define an action level for a particular

chemical. This action level must be defined as a concentration over a particular support. Starks

(1986) identifies this particular support as an "action support."



       The action  support  should be  defined prior to establishing  study  objectives or,

alternately, as part of the DQO system. The support must be kept in mind when characterizing

acceptable  levels of probability of Type I and Type n errors, when defining precision, when

evaluating  representativeness and comparability, and when defining detection limits for the

analytical method used.
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The Measurement Process



       Data users often look at a concentration obtained from  a laboratory as being "the

concentration" in the soil without realizing that the number generated by the laboratory is the

end point of an entire process extending from design of the sampling through collecting,

handling, processing, analysis, quality evaluation, and reporting. Variation or error can occur at

any of the steps in the process.  The final number reported represents the actual concentration

found in the soil plus a number of components of variation.



       A regulator or researcher would like to have an analytical result that has no error in the

reported concentration, but this is not possible to attain with a medium such as soil.  Since it is

not possible to eliminate the natural error in the measurement process, the investigator would

like to  know the variation so that he can use this information in making a decision or in

controlling the quality of the data.  A components of variance analysis provides a means for

determining the source of the variation in the data and estimating its magnitude.



        Examination of the results of a components of variance analysis performed on soils data

from  an NPL site sampled for PCBs indicates that 92% of the total variation came from the

location of the sample, while only 8% was introduced after the sample was taken.  Less than 1%
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of the total could be attributed to the analytical process itself; yet, this latter area is where a

majority of the QA resources  are normally focused.  These relative values are probably a

reasonable pattern for many different soil studies.  Properly  specified data quality objectives

should bring a balance into the QA/QC process.



       Generally, a decision must be made as to whether a site is contaminated  enough to

cause an environmental problem, and, following this decision, within the site an area-by-area

decision must be made as to which must be cleaned or remedied and to what extent.



       No valid decision can be made about the data or the site under investigation without

some knowledge of the magnitude and sources of error in the data. This aspect becomes very

important when concentrations  of pollutants  in a  support approach an  action level.

Concentrations that exceed the  action level by orders of magnitude require only limited QA as

do those areas that contain no pollutant.  The area where sampling intensity and  increased

quality assurance becomes important are those areas where it is not possible to make a clear

decision as to the need for and extent of action.



       The  design  of a  sampling effort  and  its associated  quality  assurance plan must

accomplish three things:
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       •      Determine  the variability in the entire  measurement process  along with the

              sources and magnitude of the variation in the results generated;

       •      Provide a means of determining whether a sampling program meets the DQO's

              provided; and

       •      Identify areas of contamination where action is needed.



STAGES FOR DEVELOPING DQOS



       Figure 1 shows the three stages for developing the data quality objectives for a study or

decision process. Each stage is discussed below.



Stage 1: Identity Decision Types



              Stage 1 of the DQO process provides the foundation for Stages 2 and 3.   In

       Stage 1, all available information on the site is compiled and analyzed. Based on the

       available information, a conceptual model or models (related to different categories of

       pollutants present) of the site are developed. These models describe suspected sources,

       contaminant pathways, and potential  receptors.  The models will assist in identifying
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       decisions which must be made as well as deficiencies in the existing information. Stage

       1 is undertaken to define the types of decisions which will be made during the remedial

       investigation/feasibility  study (RI/FS) and involves  defining program objectives and

       identifying and involving end-users of the data.  The decision maker and all potential

       data users should be involved in this and all subsequent DQO stages.  Stage 1 results in

       the specification of the decision-making process and justification for the collection of

       any new data (U.S. EPA, 1987a).



       Identify and Involve Data Users: The person with primary interest in the DQO process

is the ultimate decision maker.  It is not likely that this individual will be directly involved with

the process of developing the DQOs, but a representative will be designated by him to help

make the necessary detailed decisions. Individuals likely to become involved are:



       •      Regional Administrator or representative

       •      The Remedial Project Manager

       •      DOJ, EPA, and State Attorneys

       •      Chemists

       •      Quality Assurance Officer

       •      Statistician
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       •     Risk specialist

       •     Other technical specialists needed to design and review the DQOs

       •     Consultants and contractors

       •     Other interested parties



       The Remedial Project Manager (RPM) manages remedial activites and is accountable

for the technical quality, schedule, and cost of the work.  Therefore, he is the primary person

responsible for insuring that the DQOs meet program needs for a particular site. The RPM is

not expected to and should not develop the  DQOs alone but must include the necessary

engineers, hydrogeologists,  soil scientists,  chemists,  statisticians, risk specialists, and

toxicologists in the design of the DQOs.



       In time, portions of the DQO development process may become standardized.  Generic

levels of measurement and system DQOs may be developed.  Until such standard DQOs are

established, the entire DQO development process will have to be followed in each case with all

parties being involved.  However, Regions may desire to establish a means for developing and

reviewing a generic set  of DQOs for use in emergency situations.   This would  avoid hasty

decisions on the quality of data needed for clean-up and reduce the amount of time needed to

field an emergency team.
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       There are occasions where the Potentially Responsible Parties (PRPs) may be asked to

review the DQOs. This is usually addressed through the attorneys representing the PRPs and

will be responded to by a consultant or a technical member of each PRP's staff.  In cases where

there is considerable public interest, representatives from interested parties also may be asked

to review and comment  on the DQOs.  These reviews can greatly reduce the likelihood of

conflict at later stages of the study.



       The RPM must be familiar with the site to properly identify the potential data users. A

site visit combined with the results of an exploratory study can provide a basis for selecting the

individuals and disciplines to identify DQO requirements.  The process of conducting the

RI/FS is an ongoing, iterative process.   As data become available,  it may be necessary to

redefine the team required to evaluate the data and provide guidance on the overall planning

and execution  of the sampling effort.  Refinement of the data collection process  also may

require that additional technical staff be  added to improve the review and evaluation of the

data.



        Chemists and statisticians should be a part of the planning for any soil sampling effort.

The analytical chemist can provide insight into the types of analyses needed and the levels of
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detection that are required to meet the objectives of the study.  Soil scientists or geochemists

should be included to aid in evaluating the interactions of the chemicals with the soil. Scientists

and  statisticians  trained  in  geostatistics can provide  guidance in the use  of the various

geostatistical tools to evaluate the spatial distribution of the chemicals.



       The RPM may desire to have all of the various data users represented during the initial

planning meetings.  The choice of users and their involvement can be defined better after the

first few meetings.  Even though a user may not be directly involved in the development of the

DQOs, all potential users should  be given an opportunity to review and comment on the final

study objectives, protocols, QA/QC plans, and reports.



Assemble and Evaluate Background Data:



        Background data: Many sources of soil related data are available for use in planning a

study. Mason (1983) outlines a number of sources of published and public domain soils data.  A

detailed list of other sources of background information is provided in an  Agency document

(U.S. EPA, 1985).  Results of any preliminary or exploratory studies provide an excellent source

of information for use in developing final DQOs.  Data quality objectives for studies conducted

in similar settings also provide an excellent resource for use in specifying DQOs.
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       The information that is being accumulated about a site for the first time will generally

be more fragmentary and incomplete. The quality of the data at the outset may be insufficient

to support required decisions.  As the RI/FS  efforts continue, the data should improve in

reliability and become more useful in guiding further sampling efforts.



       Site Visit: A site visit provides the basis for identifying the types of data that may prove

to be useful to the team. When feasible, Agency team members as well as involved contractors

should take part in the site visit. This visit may also provide information on any potential health

and safety risks. Site visits are used to:


              •      Inventory other possible off-site sources of contamination;

              •      Identify any exposed populations;

              •      Confirm existing information;

              •      Record observational data about the site;

              •      Determine existing site conditions;

              •      Determine  access,  possible  sampling points,  obstructions,  and  site
                     configurational limitations;

              •      Determine the possible presence of volatile chemicals, explosive hazards,
                     etc.;

              •      Determine restrictions or Limitations for particular RI activities;


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              •     Delineate areas of waste storage or contamination and their contents;

              •     Determine the security of the site and identify where this needs to be
                    repaired or improved; and

              •     Identify and document any monitoring, industrial or potable water wells
                    on or near the site.
       A topographic map at a scale large enough for recording changes to the site and other

pertinent information such as locations of underground pipes or wires should be available

during the site visit.   Photocopies  of portions of USGS,  7Vi-minute  Quad sheets can be

prepared.  The graphic scale of the map should also be enlarged and copied at the same time as

the map. This provides a means of plotting any objects or conditions observed.
       A tool that can be quite useful for the site visit is a scaled aerial photograph of the site

and adjacent environs.  Information on obtaining and interpreting aerial photographs can be

obtained at U.S. EPA's Environmental Monitoring Systems Laboratory, Las Vegas, NV.



       Dated photographs and video movies of the site are  also useful for preparing study

protocols.  These should be well documented so that they can be used as evidence at a later

date if this becomes necessary.
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       All of these pieces of information become part of the official record to be assembled for

the site.



       Evaluate Existing Data:   Data that have been assembled from all available sources

should be evaluated as to their relevancy and accuracy.   Adequate time should be spent in

examining the data set that has been assembled.  Often information that is not classed as valid

because of QA restrictions can be used in establishing a hypothesis about how the pollutants on

the site have behaved over time.  These data cannot be used in making the final decisions about

the need for clean-up,  but they can be used to help develop a conceptual model for the site.

Factors that must be considered in evaluating the data for their usefulness are:



              •      the age of the data sets and their comparability,

              •      the precision and accuracy of the data,

              •      the sampling design used to collect the samples,

              •      the methods used to collect, preserve, handle, and transport the samples,

              •      the analytical methods used to measure the pollutant,

              •      the detection limits for the methods, and

              •      the quality control measures used by the laboratory and field team.
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       Older data sets were often acquired by methods that are no longer considered to be

valid.  For example,  soil samples for volatile chemicals were originally collected in  a large

container with headspace.  Current methods call for use of a 125 ml wide mouth glass bottle

filled with no headspace.  Reported values for volatiles  from the former method probably

indicate  only the  qualitative presence or absence of volatile chemicals.  The quantitative

concentrations reported should be seriously questioned.



       Similar to sample  collection  and handling methods,  analytical methods have  also

improved over time.  This should also be taken into consideration when evaluating previously

collected data.   Any uncertainty associated with the data  should be a major consideration in

evaluating the useability of the data.  Keep in mind the discussion on sampling and analytical

errors outlined in the section above on the Measurement Process. If a components of variance

test was  carried  out or can be carried out on the data, the test results can be used to determine

the usefulness of the data.  One of the major factors that the investigator or RPM attempts to

determine is an estimate of the probable precision and accuracy of the available data.  Any

available components of variance data can be used as a guide for designing the sampling effort

to meet the DQO requirements.
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       The primary objective of the data evaluation process is to determine if the data are a

valid representation of the site at the time the samples were collected. A valid representation

of the site provides a means of determining if there have been changes in the conditions at the

site over time.  Some chemicals may have been degraded, volatilized or leached from the site.

Other chemicals may have been deposited on the site, moved through or onto the site from

surrounding areas,  or formed at the site through various physical and biological interactions.

This aspect of the evaluation becomes very important when litigation is anticipated.



Develop a Conceptual Model of the Site:



       A guidance report (U.S. EPA, 1985) outlines procedures for developing a conceptual

model or models.   Essentially models are graphic and narrative descriptions of the site, the

pollutants on the site, and the behavior of the pollutants over time. The models should describe

all potential routes of exposure that may be important during the operation of the site and

following deposition of the pollutants at the site.  The graphic depiction of routes of exposure

helps the RPM and the other decision makers to visualize where problems may exist.  The

models essentially become hypotheses that are to be tested  by the sampling effort. A properly

designed sampling plan will address all of the routes of exposure and the populations that may

have  been exposed.    For example,  vaporization,  contact,  and  leaching  are  the major
                                           37

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mechanisms whereby soil pollutants may be transported from contaminated soil to receptors.

The vapors may be inhaled; soil particles may come in contact with skin, be inhaled,  or be

ingested; and leachates may become sources of surface and groundwater pollution. Figure 2,

taken from U.S. EPA, 1987a, outlines the important elements of a conceptual model.



       Investigators must be cognizant that soil is only a part of the total system that should be

considered at a site. A model of the soil compartment includes the following components:



                    •     soil cover,

                    •     soil elevation contours,

                    •     soil matrix,

                    •     particle sizes,

                    •     soil solution,

                    •     soil vapor, and

                     •     associated debris.



       As collected data identify specific areas where the model is not valid, the model  should

be modified to reflect the new information.  An important model input is the presence of

contaminated non-soil debris in the soil mass which is usually one of the first things identified
                                          38

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during soil sampling. This must be considered in the evaluation of the hazard posed by the site.

Most soil sampling and analytical efforts attempt to remove large pieces of debris such as wood,

etc., from the sample. In some cases, the debris rather than the soil may be the source of the

pollution,  since it is common to use wood chips or shredded wood  as an absorbent for liquid

wastes.  Screening non-soil debris out of the soil material and excluding it from the analysis may

bias the results against obtaining a valid assessment of the risk posed  by the site.



       Mathematical models or computer codes are often used to  estimate the extent of the

exposure.   The conceptual model developed during the RI/FS can become  the  basis of the

computer models used to evaluate the risk to exposed individuals. Modelers should become a

valuable part of the team defining the DQOs for a particular site.



Specify the RI/FS Objectives:



       The remedial investigation (RI) addresses data collection and site characterization to

identify and assess threats or potential threats to human health and the environment posed by a

site. The feasibility study (FS) identifies and evaluates remedial alternatives using appropriate

environmental, engineering, and economic factors (U.S. EPA, 1987b).
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       Some of the questions that should be addressed before  or during the RI/FS study

include:

       •     Is the area contaminated with hazardous chemicals?

       •     What is the distribution of the chemicals over the site?

       •     Are there any  areas that create  a  threat of an immediate life-threatening

             exposure?

       •     What are the dominant routes of soil exposure at the site?

       •     At  the concentrations seen, what is the minimum size area to be considered as

             posing a risk to the environment or the surrounding population?

       •     Which areas must be treated in order to reduce the risk from exposure to an

             acceptable level?

       •     Which remedies can be applied at this site in order to clean up the soil?

       •     What is the volume of material that must be treated by the remedy?

       •     What is the source of the pollutants?

       •     Are there other sources from which the chemicals could have migrated onto the

             site from other outside areas?



       The two components,  RI and FS, are conducted as interdependent phases so that the

data collection and assessment requirements  of  the RI complement and  support the
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recommendations of the FS.  The resulting report identifies possible remedial actions and

makes specific recommendations.



       A graphic illustration showing the relationship of the DQO process to the phased RI/FS

approach is presented in U.S. EPA 1987b.   Investigators must incorporate and apply DQO

process requirements during the  RI/FS scoping effort and after each RI/FS data collection

activity.



Stage 2:  Identify Data Uses and Needs



       Stage 2 results in the stipulation of the criteria for determining data adequacy. This

       stage involves specifying the level of data certainty sufficient to meet the objectives

       specified in Stage 1. In Stage 2, the needs and goals of the remedial investigation will

       be determined and all decisions to be based on information gathered during the RI

       specified This stage also provides for the evaluation and selection of the sampling

       approaches and the analytical options and evaluation of the use of a multiple-option

       approach to effect a more  timely or cost effective RI/FS (U.S. EPA,  1987a).
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       Identify Data Uses and Needs:  Stage 2 starts after the evaluation of the existing data
and the determination of how well the data fit the conceptual model that was designed.  In rare
cases after concluding Stage 1,  there may be adequate data to make a  decision without
additional sampling.  In most cases, the type,  quantity, and quality of required data will be
defined in Stage 2.  One should then attempt to  identify all of the expected uses of the data.
The amount of detail will depend upon the level of the effort. In cases where soil sampling is
only a minor part of a RI,  the  table would be  very abbreviated.  Where  soil is the major
component of exposure and a soil remedy is anticipated, the table could be extensive. The
specification of the data types must be in adequate detail to address the  objectives  of the
RI/FS.

       A number of the new remedies such as fixation and soil cleaning that are being used
require that components of the soil mass be segregated, screened, or processed in some manner
during the remedy. It is impossible to determine the feasibility of implementing these remedies
without physical data such as unit density, percent debris, percent moisture, etc. Also a number
of non-standard chemical analyses may be required. These should be included in the Summary
of Data Needs Table (Table 1) even though guidance for developing the DQOs (U.S. EPA,
1987a) calls for rather broad generic data uses.
                                          43

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       Once the data  needs and types have been identified,  priorities must be set so that

resources can be properly allocated to the sampling effort. This prioritization should be closely

linked to the allowable level of Type I and Type II errors.  The required data quality for the

highest priority data use will control the planning and implementation of the sampling effort.



       Since soil sampling is expensive, there is a tendency to attempt to acquire as much data

as possible from a single study.  It may be more cost effective to conduct the sampling effort in

stages or increments (i.e., exploratory study followed by a more definitive effort).  Data from an

exploratory study can provide considerable guidance in identifying the types of samples needed,

the analyses  required,  and the quality of data that can be expected for  a particular sampling

method. The example presented below shows how the results of the exploratory study can be

used to identify the analytical needs of a study.



              Example: A transformer repair yard located in a small Florida town was

       sampled during an  exploratory study.  Soil samples were collected at three depths

       from twenty-five grid points over the site.  Priority pollutant analyses were carried

       out on these samples.  The only pollutants found were PCBs (reported as Aroclor
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       1260),  trichlorobenzene and tetrachlorobenzene.  No breakdown products of the

       PCBs or the chlorobenzenes were noted.



       In this case, extensive use of priority pollutant analyses on any additional samples would

be wasteful of resources.   Analyses should be focused on the three chemicals identified.

Verification of the findings of the exploratory study may be  substantiated  by submitting a

limited number of new samples for priority pollutant analyses.



       Evaluate Various Sampling and Analysis Options: Each component of the sampling

process (i.e., type of sample and its associated  analyses) must be  identified  and carefully

evaluated to determine if the particular  sample type and analysis will provide the necessary

information to meet the use or data need.



       An example would be  an  emergency response situation such as a spill site where

exposure to the population is critical. The high concentrations found at these sites often can be

detected by use of some Level I field instruments. Screening of the soil with a photoionization

or a  flame ionization detector,  for  example, could provide the necessary results for the

immediate clean-up of the spill  Samples collected in and around the area  identified by the

Level I instruments may then be submitted to a field laboratory for Level n analysis. The areas
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identified as requiring clean-up could then be addressed for the emergency response action.  A

limited number of samples should be submitted for Level in or IV analysis. This phasing of the

analysis can provide the rapid turnaround needed by the emergency situation and still provide

the necessary high quality data needed for verification and possible litigation. For information

concerning analytical levels appropriate for selected data uses, see U.S. EPA 1987a.



       The use of various levels of analyses should be considered when allocating resources for

the RI/FS. The cost of field methods (i.e., Level 1 and 2) time-to-data availability are usually

considerably less than the cost and time of a Level IV analysis. By coordinating Levels I and n

with the laboratory methods (i.e., Level HI), a higher quality data set can be developed in less

time and for less cost.



       Acceptance Criteria:  Westat  (1988)  outlines a  process for  determining when a

particular environmental goal has been attained. This process can be used to assist in planning

the system DQOs for a particular sampling effort.  Figure 3, taken from Westat's  report,

outlines appropriate attainment objectives that should be developed by the DQO  Team in

conjunction with the decision makers. The decision criteria that are developed  must  take into

consideration the action level and the  acceptable risks  associated with  that  level.   The

acceptable risk of a  false  negative,  for example,  is  defined as the  probability that  an
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unremediated area will in fact exceed the action level.



       There are few  regulatory guidelines or standards for soils;  therefore,  it may be

necessary to determine  a  reasonable  action level for identifying potential areas in need of

cleanup. Where multiple chemicals are present, one can prioritize chemicals according to their

toxicity, mobility, persistence, and concentrations. An Agency publication (U.S. EPA, 1984) can

be a resource in helping to select indicator chemicals.



       It may not be possible to precisely define the cleanup area at a particular site at the

outset.  It may be possible to arrive at an estimated size for this area based on the conceptual

model prior to the sampling.   This can become the basis for defining the monitoring design

approach.
                                            48

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      c
Start

     Define the sample areas.
               I
        Specify the sample
      collection procedures.
       Specify the chemicals
           to be tested.
               i
    Specify the parameter to be
 compared to the cleanup standard.
Specify the probability of mistakenly
  declaring the sample area clean.
               I
    Review all elements of the
      attainment objectives.
                                                  Yes
                                          Are any
                                       changes in the
                                    attainment objectives
                                         required?
        Figure 3. Steps in defining the attainment objectives.

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       Data Quantity and Quality Needs:  Guidance for determining the number of samples

that must be taken and the type of analyses that must be carried out is provided in Mason

(1983) and in later chapters of this document. There must be a balancing between the number

of samples and the resources available to meet the sampling/monitoring needs.  A properly

designed exploratory study will provide  data needed for  determining the final number of

samples to be taken. In those cases where an exploratory study cannot be carried out, a phased

sampling plan may be used.  This allows the collection of an initial set of data that is used to

design the next phase of collection. Addressing the questions presented below will be helpful in

selecting sampling locations and numbers.

       •     Are there visible sources of pollutant on the surface of the soil?

       •      Is there soil erosion or recent cuts or fills on the site?

       •      What is the surface water flow pattern?

       •     Are  there sensitive ecosystems or residences located down  gradient from the

              site?

       •     Are there known hotspots on the site?

       •     Are there confining layers or porous layers in the soil horizon?
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It helps to evaluate the form of the chemical pollutant, the media that transport it, the reactions

that it may undergo, the routes that it may follow, and any sinks or other restraints that it may

encounter as it moves from source to receptor.  Those locations in the soil system where the

pollutant is likely to be found should be sampled.



       The required quality of the data can vary depending upon the use of the data.  The

evaluation  of the existing data that was carried out in Stage 1 will indicate if the data are  of

adequate quality for the needs of the data users. The actual data quality that can be assigned to

a particular data set can only be determined after the results are evaluated and interpreted.  If

the data do not meet  the specified DQOs,  additional data must be collected to bring the final

data set up to the level of quality required to make the final decision.



       Specify Precision, Accuracy, Representativeness,  Completeness, Comparability, and

Detection  Limit Goals:  The key phase of Stage 2 is the setting of the required levels  of

precision,  accuracy,   representativeness,  completeness,  and comparability  along  with the

detection limits needed to meet the data quality  objectives.  All data uses do  not require the

same quality of data.   "What is required, however, is that all data collected be of known and

documented quality" (U.S. EPA, 1987a).
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       Detection Limits:  Appropriate detection limits should be selected for the intended

purposes of the sampling effort.  Sampling to identify strata to be used in a later,  more

definitive sampling effort may be carried out with Level I or n techniques in the field.  The

minimum  detection  limit of these instruments may be quite  high  compared  to  laboratory

methods.  For example, measurements of background levels would not normally be done with

these field instruments because of their high detection limits. Field instruments with a higher

detection limit may be appropriate for use in areas that have high pollutant levels. If a 10 ppm

clean-up level has been identified, it is not cost effective to use an analytical procedure with a

parts-per-billion detection limit.  A field gas chromatograph can provide the reliability for the

clean-up work.  A set of samples can be submitted to a laboratory to verify that the field

analyses meet the desired standards.



       Field audit samples with a low concentration can be used to determine the minimum

detection limits for the measurement process being used. The variability data from the analyses

of the field audit samples will provide a means for determining at what level analytical results

should be reported without qualifiers.
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       The  detection limit  selected should reflect the risks associated with exposure  to  a

particular pollutant. Detection limits should not be chosen a priori on the basis of the methods

available for analysis,  but should result from a review of the needs of the decision maker and

the data users.  A rule of thumb might be to use whenever possible a detection limit one order

of magnitude lower than any level of concern.  This allows values close to the concentration

levels of concern to be reported and evaluated.



Precision:     The precision required for a particular study will depend upon the difference

between background levels and the action level  Measurements of chemicals that have a very

low action level such as 2,3,7,8-tetrachlorodibenzodioxin (TCDD) will require much  greater

precision than would measurements of a chemical with an action level in the parts per million

range.  The amount of preparation that  samples undergo prior to analysis will also greatly

influence the precision of the measurement process.  Soil  samples that have been taken for

metals analysis are often dried, sieved,  and mixed, and then carefully subsampled.  These

subsamples  provide a much  more precise  measure of the average concentration in the sample

than would  be expected from a sample that could not be prepared in  the same manner.  For

example, samples collected  for volatile organic analysis cannot be dried, ground,  or mixed if

they are to reflect the concentrations found in the soil.
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       Laboratory precision is only one part of the total precision of the measurement process
leading from sample collection through data reporting.  Selection of an  acceptable precision
level should not be based solely on what is attainable in the laboratory.  Once the sample is
submitted  to  the laboratory  much of the  sample-to-sample  variation has  already  been
introduced into the sample by activities in the field.

       A key factor to remember when making a decision on the desired level of precision is
that the selection  should be made on the basis of risk of exposure if protection of public health
and the environment is the principle matter of concern.  The detection limits,  the sampling
methods, and the sample handling procedures must then be specified on the basis of the levels
of pollutants judged harmful by the risk assessment.  Where litigation is a key factor and costs
are high, the choice of techniques for assuring adequate precision become important.

       Normally precision is measured by the standard deviation of the data set; however, the
range can also be  used (Bauer, 1971). Replicate quality control samples are submitted from the
field to provide a means of determining the precision of the measurement process.  Two types
of samples should be used for this purpose.  Routine samples should be submitted as either
splits or co-located samples. In addition to the routine samples, field audit samples also should
be submitted on a regular basis.
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       Accuracy: Accuracy is controlled primarily by the laboratory and is reported as bias.
Standards, spiked samples, referee samples, and field audit samples are all used to assess and
control the accuracy of the results as well as the comparability of the results.

       Representativeness:  Representativeness is the  degree to which the samples collected
reflect the conditions at a particular site.  For example, a sample of soil screened from a rubble
pile does not represent the conditions at that site,  but  only provides a measure of a small
fraction of material that happens to fall within the screened particle size range.

       Sampling techniques and the monitoring design selected determine what is actually
being measured. The rationale for selecting a particular technique or design (e.g., when, when,
and how to  sample) should be carefully defined and documented as to its applicability in
defining site conditions.   Samples that are biased toward hotspots should be identified.
Sampling only suspected hotspots is often used in the initial stages of an  investigation and
insures that some potential problems will be identified quickly, but it generally provides only a
limited indication of the magnitude of the total problem.

       Completeness:   Completeness is a measure of the amount of validated  data  that is
obtained from a particular sampling scheme.  It is  calculated  by dividing the  number of
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validated data points by the total number of samples collected.  The design of a particular

sampling effort provides a minimum number of samples that is needed to yield a desired level

of precision for the final results.  The probabilities of false positive and false negative answers

are specified at the outset. Obviously any loss from the required number of samples will impact

the final results.  The U.S. Department of Energy has set a completeness objective for the

Environmental Survey Program at 90% for both field sampling and laboratory analyses (U.S.

DOE, 1987).



       The planning stages of any study must take into consideration  the fact  that not all

samples will make it intact through the entire measurement process. Sample containers will be

broken, instruments  will fall out of control, data will be lost, sample tags will be lost, storage

conditions will be violated, etc. There are many factors that can lead  to a sample result being

invalidated. This can be compensated for by oversampling or by using a phased sampling effort

that allows areas where samples were lost to be resampled in subsequent phases.  This latter

approach insures that the desired number of samples will be collected.



       The completeness goal must be realistic and must assure that adequate  data will be

available for meeting the objectives of the sampling program.
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       Comparability: The comparability objective provides the needed control over the total
measurement processes  to insure that different studies can be compared.   Comparability
provides a basis for comparing trends over time or space,  for evaluating the relationship
between sampling programs, and for insuring that phased sampling efforts produce data of a
consistent quality.  The quality control procedures used in the laboratory provide a portion of
the control over comparability, but the field audit sample provides the best basis for insuring
that data sets are comparable. A field audit sample from a previous study should be included in
the first few batches of samples submitted from a new site. This allows comparisons to be made
through the two sets of field audit samples.

       When sampling is to occur over an extended period of time or when the investigator
desires to compare several sites, it is necessary to insure that the samples be collected in a
comparable manner, from comparable fractions of the soil mass, and with comparable methods.
For example, one should not attempt to compare samples collected by coring with bucket auger
samples.
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Stage 3: Design of the Data Collection Program

              During Stage 3, the methods used to obtain and analyze data, as well
              as the quality and quantity of data required to achieve the objectives
              outlined in Stage 2 will be specified.  This information is provided in
              documents such as the work plan or quality assurance project plan.
              Stage 3 results  in the specification of the methods by which data of
              acceptable quality and quantity will be obtained (U.S. EPA, 1987a).

       During Stage 2, specific guidelines have been developed for sample collection, chemical
analyses, and data evaluation.  The data quality objectives that were defined are used to design
the procedures that will be used to acquire the quality of data  that is needed to meet the
demands of the decision maker and the data users.  Stage 3 compiles information and merges it
with the data quality objectives to arrive at a data collection program.  The output of Stage 3
should be a set of well-defined and documented plans for acquiring the data and insuring that
the quality of the data meets the DQOs. A U.S. EPA publication (U.S. EPA, 1987b) provides
an example of DQOs for soil sampling that can be used as a guide.
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       Mason (1983) has prepared a manual for use in preparing soil sampling protocols. This

document outlines sample design considerations and sampling techniques that can be used to

prepare the documentation needed for a soil sampling effort.



       A detailed protocol or work plan that spells out detailed instructions for every aspect of

the soil sampling program  should be prepared.  Documentation should include instructions for

acquisition and preparation of sampling equipment, sampling/monitoring design, health and

safety, quality assurance, decontamination, disposal of wastes, sample and document control,

analytical procedures and  data validation and analysis.  These aspects may be  combined into

one large document, but most likely it will be a  series of documents addressing specific aspects

of the entire measurement process.



       To provide additional information and assistance to those responsible for designing and

implementing sampling/monitoring programs, a Data Quality Objectives Development Process

is presented  in Appendix  C.  This process involves a four-stage interactive approach.  The

accompanying checklists and critical elements of a quality assurance plan are used by U.S. EPA

Region 10 to address and identify site-specific Data Quality Objective requirements.
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                                    CHAPTER 4

                      QUALITY ASSURANCE PROJECT PLANS


      The U.S. Environmental Protection Agency quality assurance policy requires that every

environmental monitoring and measurement project must have a written and approved Quality

Assurance Project Plan (QAPP) (U.S. EPA, 1980, 1986, 1987d).  These plans are based on the

data quality objectives that have been  developed for the RI/FS.  The QAPP becomes the

primary instrument for directing the quality assurance effort for the project and for insuring

that the DQOs are met. U.S. EPA policy requires that the QAPP contain the sixteen elements

listed below.



       1.     Title page with provision for approval signatures.



       2.     Table of Contents.  (This must include a serial listing of each of the 16 QAPP

             components.)
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3.      Project Description.  (A general description of the project should be provided

       together with the intended end use of the acquired data. This should be closely

       tied to the objectives identified during the DQO stages.)



4.      Project organization and responsibility. (List the key individuals, including the

       QA  Officer,  who are responsible  for ensuring  that the collection of valid

       measurement data and the routine assessment of measurement systems have

       met the DQOs.)



5.      QA objectives for measurement data in terms of precision, accuracy, complete-

       ness,  representativeness,  and comparability.   (For each major measurement

       parameter, list the DQOs for precision, accuracy, and completeness, detection

       limits, along with the probability of committing a Type I or Type n error that

       was used in defining the objectives. All measurements must be made so that the

       results are representative of the media and conditions being measured.



6.      Sampling procedures. (For each major measurement parameter, including all

       pollutant measurement  systems,  provide a  description  of the sampling
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       procedures to be  used.   Any later changes  to  these procedures should be

       documented by attachment of approved amendments to these procedures.)



7.      Sample custody. (Where samples may be needed for legal purposes, chain-of-

       custody procedures will be used.  Most RI/FS data falls into this category. It will

       be necessary to define a detailed set of procedures to be followed by the  field

       teams and the laboratories to insure that the chain-of-custody is followed.)



8.      Calibration procedures and frequency.  (Information should be provided on the

       calibration standards to be used and their sources.)



9.      Analytical procedures. (Describe the analytical procedures to be used for  each

       major measurement parameter along with the associated detection limits.)
 10.    Data analysis, validation, and reporting.  (This section will include the principal

       criteria that will be  used to validate  data integrity during collection  and

       reporting of data as well as methods used to treat outliers. This section should
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       also detail the procedures that will be used to insure that the DQOs have been

       met.)



11.     Internal quality control checks.  (Examples of items to be considered include

       replicates,  spike samples,  split  samples, field audit  samples,  control charts,

       blanks,  internal standards, span gases,  quality control samples,  surrogate

       samples, calibration standards and devices, and reagent checks.)



12.     Performance and systems audits. (Each QAPP must describe the internal and

       external performance and systems audits that will be required  to monitor the

       capability and performance of the total measurement  system. The use of field

       audit samples should be outlined in this section.)



13.     Preventive maintenance.  (This section should include a schedule of important

       preventive maintenance tasks as well as inspection activities.)



14.     Specific routine procedures used  to  assess  data  precision,  accuracy,  and

       completeness. (These procedures should include the equations used to calculate
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       precision, accuracy, and completeness, and the methods used to gather data for
       the precision and accuracy calculations.  The types of control charts to be used
       along with the equations used to calculate control limits should also be included
       in this section.)

15.     Corrective action. (This section must include the predetermined limits for data
       acceptability beyond which corrective action is  required  as well as  specific
       procedures for corrective action.)

16.     Quality assurance reports to management.   (These reports should include
       periodic assessment of measurement data accuracy, precision, and completeness
       as well as an  identification of significant  QA problems  and  recommended
       solutions. The interim reports should specifically outline any problems that will
       cause failure to meet the DQOs.  The final report should address how well the
       data quality objectives for the study have been achieved, along with any reasons
       for failure to meet these objectives.)
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       Since the original design of the QAPP, the use of data  quality objectives has been

implemented.  The data quality objectives define the standards that must be met in order to

insure that the quality of the data meets the needs of both the decision makers and the data

users.  Properly implemented, these objectives become a powerful tool in the overall RI/FS

process.   The QAPP becomes the roadmap  for confirming achievement of the objectives

outlined during the DQO process.  To be maximally effective, QAPPs should be designed in

such a way that out-of-control situations are detected at the earliest possible time so that

corrective actions may be taken quickly to avoid wasting valuable resources.
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                                     CHAPTERS
                            THE CONCEPT OF SUPPORT

       The better known texts on  sampling theory and methods (e.g., Hansen et al.,  1953;
Cochran, 1977) deal primarily with  the sampling of people, housing units, or businesses where
sampling units are discrete and well defined. In the sampling of a continuous medium such as
soil,  it is necessary to emphasize the definition of a sampling unit. In addition to a specified
location,  each soil  sampling unit has a certain  three-dimensional volume,  shape,  and
orientation.  These latter three characteristics when taken together are called the support of the
sample. The concept of support is  somewhat analogous to the concept of a pedon used in soil
classification work (Soil Survey Staff, 1975).

       The choice of support will affect the characteristics of the distribution of the pollutant
concentrations of the population of possible sampling units in the region being sampled.  For
example, if the sampling unit is a soil core and pollutant concentration decreases with depth,
then the longer the core,  the smaller  is the mean concentration of pollutant in the sampling
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unit.  However, changes in support not only change the means of the distributions, they also

change the variances of concentrations and the correlations of concentrations between sampling

units.  Large variances  of pollutant concentrations between sampling units often necessitate

taking large numbers of samples or cause  a compromise  that results in larger than desired

variances of sample estimates.  In many cases, a change in the support of the sampling unit will

substantially reduce the variance between sampling units and thereby reduce the variances of

sample estimates.



       Since one of the objectives of QA is to estimate the precision of measurements and

sample estimates,  it is essential that the support of all sampling units within a study be  the

same.   However,   it  is possible to change support between an  exploratory study and  the

definitive study and still be able to use the data from both studies in making estimates. This is

permissible  when  the changes  in  support have not  altered  the  expected values of  the

concentrations in the sampling units, and the data from the two studies are weighted to reflect

the differences in variances of the measurements.



       Soil is a very heterogeneous material.   Samples with very small support volume (say

1 mm3) may vary  from zero to very high concentrations,  regardless of the concentrations in
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samples of larger volume from the same location.  With no prior information, it is difficult to

choose an appropriate support. With information as to the spatial continuity of the pollutant

concentration in the soil, one can follow a systematic procedure to determine the appropriate

support for a soil sample.  (See Starks, 1986.)  In a later paragraph, it is shown how quality

assurance samples can also give information on the appropriateness of the chosen support.



       Often one finds action levels expressed as a certain number of parts per million or parts

per billion, but for soils, such statements of action level have little meaning.  As mentioned

above, for sampling units with very small volumes, it is almost certain that some samples will be

above action level  For example, suppose that all the pollutant were concentrated in particles of

size 1 mm3 and that each of these particles has 10 times the action level concentration.  If these

particles were uniformly distributed in the top ten cm of the soil in the area of interest, and the

total volume of all such particles were only 0.1 percent of the total volume of the soil in the top

ten cm, one would conclude that no remedial action is necessary. However, If the particles were

all concentrated in the soil so that they formed a "hot spot" of perhaps the top ten cm of one

acre in a 1,000-acre region, it would be important to locate the hot spot so that remedial  action

could be taken.  Hence, it is essential that the action level be defined as a concentration  over a

particular support and location rektive to the ground surface.

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       In this definition of action levels, the support will be referred to as the action support.

For example, one might state as an  action level that if there is a soil volume that has a

concentration of pollutant X exceeding 10 ppm in the top ten cm over a square area of at least

100 m2, then remedial action should be taken on that volume.  In this example,  the action

support is the top  10 cm over a square area of 100 m2.



       At the Palmerton, Pennsylvania, Superfund site, cadmium was one of the soil pollutants

of interest (Starks et al., 1987). The support of soil samples taken in an exploratory study was a

set of four (2 cm diameter) cores taken to a depth of 15 cm with one core from each of the four

cardinal compass points on a 6 m diameter circle. The four cores were composited at all but 10

of the 211 sample locations. At  ten locations, measurements were obtained from each of the

four cores.  At another 10 sample locations,  the sampling team took a second (duplicate)

sample of four composited cores within 0.5 m of each of the original four cores. (See Table 2.)



       The variance between  measurements on the duplicate pairs was 31 percent of the total

variance between samples (after correcting for changes in expected values over locations). The

variation between measurements on individual cores was found to be quite large. (See Table
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3.)  Other QA sample results indicated that the large variances found between duplicates and

individual core measurements were not caused by subsampling or chemical analysis errors.



       To reduce the large component of total variance caused by the placement of the sample

cores, it was decided that nine cores should be taken at each sampling location in the second

(definitive) study.  The nine cores came from four points at the cardinal compass points of a 6

m circle, from the four minor compass points of a concentric 4.25 m circle, and one point at the

center of the circles. This increase in the support of the samples, plus the increased experience

of the sampling teams, brought the variance between duplicates down to less than 10 percent of

the total variance in the definitive study.
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TABLE 2.  RESULTS FROM DUPLICATE SAMPLES AT THE
                  PALMERTON SITE
                        (mg/kg)
POINT
AK26
A030
BP30
BQ33
BQ34
BT32
BT46
BY29
DL78
DP34
Median:

CADMIUM D.3
8.85
22.30
86.30
58.20
100.4
39.50
172.0
43.70
2.76
68.10

s
7.35
8.46
63.10
40.30
77.10
37.90
144.0
34.20
2.71
61.70

2 = lLj2/20
1.50
13.84
23.20
17.90
23.30
2.40
28.00
9.50
0.05
6.40
11.67
» 0.0691
Lb
0.186
0.970
0.313
0.368
0.264
0.041
0.178
0.245
0.018
0.098
0.216

          5 D - absolute pair difference
          b L » absolute pair difference of log-transformed data
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       TABLE 3. RESULTS FROM INDIVIDUAL CORES
               AT THE PALMERTON NPL SITE
                       (Cadmium, mg/kg)
* Sample variances on ln(Cd) over 4 cores at each site.
 Pooled sample variance based on first nine sample points: 0.3659.
 Pooled sample variance based on all ten sample points: 0.8453.
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SAMPLE
POINT
BO29
BR33
BR38
BS33
BU33
BU38
BX30
CF46
CI34
CJ50
CORES
S
30.7
56.7
104.0
42.9
29.4
64.0
56.3
51.5
112.0
0.75
W
5.0
66.8
147.0
21.2
24.1
33.1
35.9
97.1
167.0
47.4
\I
66.3
25.8
124.0
30.5
31.0
82.3
46.2
46.7
158.0
115.0
E
29.0
104.3
100.6
45.5
48.6
127.0
111.0
79.0
196.0
52.0
RANGE
61.3
78.5
46.4
24.3
24.5
93.9
75.1
50.4
84.0
114.25
V*
1.195
0.339
0.031
0.124
0.877
0.316
0.234
0.121
0.055
5.159
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                                    CHAPTER 6

                              EXPLORATORY STUDY


       Once objectives which involve the need for soil sampling have been defined, the next

step is to develop a total study protocol including DQOs as well as an appropriate QA/QC

program. Answers to the following questions should be available or estimates made in order to

develop the protocols.



       •     What are the probable sources of the pollutants of concern?

       •     How have the emissions from these sources varied in the past compared to their

             present levels?

       •     What are the  important  transport  routes which contribute  to soil

             contamination?

       •     What is the geographic extent of the contamination?
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       •      What average concentrations of the pollutants exist at different locations, and

              how do these vary as a function of space and time?

       •      Do localized areas of high concentrations exist, and if so, where are they and

              what are the concentrations?

       •      Is it possible to  stratify the sampling  region to reduce the spatial variations

              within strata?

       •      What  are  the soil  characteristics,  hydrological  features,  meteorological  or

              climatic  factors,  land  use patterns,  and  agricultural practices  affecting  the

              transport and distribution of the pollutants of concern in the soil?

       •      What is an appropriate background or control region to use for the study?

       •      What  are  the acceptable  levels of precision,   minimum  relative  levels  of

              detectability, and probabilities of both Type  I and Type n errors for this study?



       If answers to all of these questions are not available, an exploratory  study (this also can

be called a pilot study or a preliminary study) should be carried out. To be designed after a site

visit, this study should address the components of a conceptual dispersion model.  Clearly not

all the above questions can be answered in detail by a single exploratory  study; however, as

many as possible should be attempted.
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       The  authors  recommend developing the conceptual model after a  compilation  of

literature and all existing data have been completed in Stage 1 of the DQO process.  Much of

the information pertinent to the above questions may already be available in the published

literature, in the files of governmental  agencies or  industrial corporations, in ongoing  or

completed research at local universities, or in the knowledge of local citizens.  A carefully

planned and organized effort should be mounted to accumulate what relevant information is

available.  Only after this information has been collected, collated,  and evaluated should any

field measurements be made. It is good policy to adhere to a reasonable fixed period of time

for the collection and analysis of available information,  otherwise this process could drag on

interminably. Only at the end of the fixed time period, and based on whatever information is

available at that time, should the design and implementation of the field measurements portion

of the exploratory study be undertaken.



       In those cases where there is not enough data available for designing the soil sampling

study, an exploratory study becomes an essential element of the planning process.  Properly

designed, the exploratory study is simply phase one of a multiphased sampling effort.
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       The primary intent of the exploratory study is to determine if the site poses a potentially
unacceptable risk to the local human population or the environment. The study also assembles
and collects data needed to prepare revised Data Quality Objectives, work plans, QAPPs, and
sampling protocols.

       The designs  used to acquire  the data during the exploratory  study  should  have a
statistical basis that provides  some measure of the precision that can be expected  for the
particular soil-pollutant combinations that exist on  the site.  The authors recommend that a
coarse grid pattern be used in order to provide some information on the distribution of the
chemicals over the site.   The investigators may decide  that a combination of judgmental
sampling  and systematic sampling may provide more useful information for a particular
situation.  Those samples that are selected on a judgmental basis are biased toward finding
pollution.   Because of this bias,  the samples should be  identified in such a way that the
statistician can take the bias into consideration when providing a statistical analysis of the data.
One possible alternate approach is to stratify the study area on judgmental evidence and then
take random samples within each stratified area.
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       Aerial photographs of the site and its vicinity along with appropriate maps should be

assembled before the exploratory study.  This provides a basis for evaluating terrain, surface

water flow, erosional patterns, land use patterns, and other similar factors that may influence

the distribution and dispersal of the pollutants over the site.  Careful attention should be paid

to the identification of the primary sources of the pollution and to the primary routes of

migration.  These should be noted on the maps and incorporated into the conceptual model of

the site.



       The conceptual model of the site should be used as the basis for designing the sampling

effort. Those areas deemed to be of primary concern should be sampled in such a manner that

the model can in fact be verified or amended as needed.  This involves incorporating into the

sampling design  adequate replication on several scales  to  determine the expected spatial

variation over the site.  Assumptions may have to be made about the expected variation that

one would  expect to encounter based upon similar situations at other sites.  These would then

be adjusted in the final sampling effort to incorporate the information gained in the exploratory

study or preliminary site investigation. The Palmerton NPL Site example discussed below is an

excellent example of the use of the preliminary study to guide the final sample design.  The

short-range variation (Le.,  variation between  samples 0.5  m apart) among  results from
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neighboring grid points was considered to be too large based on the preliminary study.  This

was corrected by altering grid spacing to effectively reduce the influence of the short-range

variation on the final results.



       Guidance for the confidence level (1-ot) and the power (!-/>) of the data set that should

be used for the exploratory study are given in Chapter 7 along with the relative increase over

background that should be used in designing any random statistical sampling  plans.  This

chapter also recommends the number of quality  assurance and quality control  samples that

should be taken during the exploratory study.



EXAMPLE OF AN EXPLORATORY STUDY



       The Palmerton NPL Site is used as an example of the use of an exploratory study to

develop the guidance that  is needed to  develop the main phases of a definitive  soil sampling

program.   In the narrative that follows the reasoning for the sample design, reasoning for

transformation of data, and the types of quality of assurance data are discussed.  (For more

details than can be presented here about the study, the reader is referred to Starks et al., 1986;

Starks et a/., 1987; and U.S. EPA, 1989.)
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       The purpose of the entire study was to determine the spatial distribution of certain

metals (principal interest was in the concentrations of cadmium and lead) in the soil  in

residential and farming regions near two zinc smelters.  The two smelters are located on the

southwest  and the southeast edges  of Palmerton, Pennsylvania.   (See Figure 4.)   This

information was needed to plan remediation procedures for the area. The site RPM requested

a geostatistical analysis of the data to obtain kriging estimates of the spatial distribution of the

metals in the soil.  The purpose of the exploratory study was to  estimate the extent and the

spatial structure of soil contamination by cadmium, copper, lead, and zinc.



Sample Design



       As stated  above,   the principal objective  of  the exploratory study was to  obtain

information for estimating spatial structure and extent of the pollution. Estimation of spatial

structure requires information on how concentrations vary with location and how differences in

concentrations vary with distances between sampling units. A square grid of sampling locations
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                                 .  Jr,ast    Slag Pile
                                /  Plant          .
4000ft.
                                                             Aquashicola

                                                                Creek
       Figure 4. Palmerton Exploratory Sampling Design.
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is good for this purpose in that each interior point can be associated with several other points a

given multiple of the unit grid distance from it. The unit grid distance is of importance in that

in that if it  is too large, no spatial correlation will be detected;  and if it is too small, more

information than necessary will be obtained, and either a very small area will be sampled or a

very large number of samples will be required.

       In planning this study, the designers used results from a study of lead pollution in soil in

Dallas,  Texas, which indicated a range of influence (a distance beyond which there was no

spatial correlation) of about 1,200 feet. Based on this information, a unit grid spacing of 400

feet was selected.  This provided pairs of points at four distances (400, 800, 40072 and 800/2

feet) at which  positive spatial covariances  might be expected  for  use in estimating the

covariance function.  To obtain a reasonable number of such pairs, a rotated square grid of 85

sample points was formed over a diamond-shaped area.  (See Figure 4.)  To obtain information

on the extent of metal pollution in the soil, additional sample points were selected along eight

transects originating at the center of the diamond and extending through its sides and vertices.



       This grid of sample points was centered in the Town of Palmerton and oriented in such

a way that three of the transects conformed to the valley system in which the town lies.  One

transect was bent to follow the Lehigh River.  These transects also  followed the principal
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windrose directions.  The lengths of the transects were based on windrose data and land use

data.  The number of samples to be collected and analyzed had to be kept small, so that there

would be resources to carry out the definitive study.  Thus, spacing between points along the

transect was generally  greater than within the  square  grid.   By centering the design  in

Palmerton, it was unnecessary to wait for the definitive  study to obtain kriging estimates of

metal concentrations for the area where most of the people in the study region lived.



Data  Transformations



       The need to transform data arises from the need to stabilize variances.  If variance

changes from location to location, there is no one variance to estimate. In addition, the kriging

estimation process in geostatistics is variance-based and, therefore, requires a stable variance.

The data in Tables 2 and 3 indicate that the variability in concentration measurements between

duplicates and between cores from the same site tends to increase as the average concentration

increases, and the same occurs between splits from the same sample.  These phenomena were

also observed in the concentration measurements for the other three metals. This indicates the

need for a data transformation.  Several methods for making a choice of transformation are

given by  Box and Cox (1964) and Hoaglin et al. (1983).  However, estimates of proper
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transformations based on the small amount of data in the above mentioned tables are rather

unreliable.  In this case, it was known that the logarithmic transformation had been applied to

these types of measurements in the past,  and it was found to do a good job of stabilizing

variance on a larger set of duplicate lead measurements from the Dallas study. Hence, the

simple logarithmic transformation (Y=lnX) was employed.



       Graphical plots of means versus standard  deviations for the log-transformed metal

concentrations data showed no indication of a relationship between the two, and the variances

of duplicates for the four metals were very close to being the same, even though  the mean

concentrations were quite different.  This is as it should be, since the process of accumulation in

the soil should be the same for all of the  metals.   Similar inter-metal confirmations of the

logarithmic transformation were found in the data from split samples.
       Assurance Data
       Several types of quality assurance data were collected in the Palmerton exploratory

study.  These included duplicates, splits,  and individual cores.  In addition, decontamination

blanks and QC samples were analyzed. A decontamination blank was collected at one sample
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location out of every 20. This blank was obtained by bringing the sample corer into contact with

distilled deionized (DDI) (ASTM Type n quality) water (final rinse) prior to its use in taking

the soil sample.  The blanks were prepared in the field at the sample locations, then shipped

with the field samples through the sample bank to the soil chemistry laboratory to determine

whether the sample collection instruments were contaminated prior to taking a soil sample.

Additional decontamination blanks were prepared in the sample bank by bringing DDI water

into contact with the soil sieve and mixing equipment. One such blank was prepared after 40

samples were passed  through the equipment to determine whether it  was being properly

cleaned between samples. Four QC samples consisting of DDI water with known quantities of

Cd, Cu, Pb,  and Zn were prepared and sent through the sample bank to the laboratory for

accuracy checks.



       If anything, this exploratory study was a bit short on QC samples. At least 20 duplicate

samples should have been taken  to allow better estimation of both the measurement error

variance and the  appropriate  data transformation.   In addition,  no  field audit samples

(performance evaluation soils) were  employed to check the precision and  accuracy of the

methods by using a soil matrix.
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                                    CHAPTER?

              GUIDANCE FOR SPECIFIC SOIL SAMPLING PROGRAMS

       Chapter 2 discussed some of the functional objectives for soil sampling.  The material

that  follows presents guidance for determining the confidence  level,  the power,  and the

detectable relative difference between different data sets that should be anticipated for

different types of soil sampling programs. Most of the information relates to the provisions and

intent of RCRA and CERCLA. Operational situations in which soil sampling may be involved

include:



             •      background monitoring,

             •      preliminary site investigation,

             •      emergency cleanup operations,

             •      planned removal operations,

             •      remedial response operations,

             •      monitoring, and
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              •      research or technology transfer studies.



       With the possible exception of research or technology transfer studies,  all of the

operational situations listed have a potential for litigation.   For  this reason,  a statistical

experimental  design incorporating  appropriate  QA/QC  measures  including  National

Enforcement  Investigation Center  (NEIC)  "chain-of-custody"  procedures should be

incorporated into the overall sampling program.  The total QA/QC plan should be designed to

insure that the data quality objectives are met.



Background Sampling



       Sampling to determine the background  levels of the various chemicals found in the

environment should be carried out as part of any routine sampling programs.  Background

levels are usually found in those areas where the levels are below the minimum detection limits.

However, certain of the trace metals may be present at levels that are detectable and still be

background levels. In order to determine if a specific area is contaminated above background,

it may be necessary to carry out studies with this specific objective in mind.
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       Background areas should be areas outside industrial complexes that may be contributing

to the overall pollution burden and should be upwind and upstream from them.  These areas

should be in similar topographical settings and have  the same or very similar soil types.  The

parent material for the soil should be the same if at all possible.   When the same soil type

cannot be found, care should be taken to insure that  the amount of organic matter and clay is

similar in the soils chosen for the background areas.



       These factors become especially important when chemicals normally found in the soil

are the pollutant of concern. Sensitive analytical methods with low detection limits will detect

many of the metals in the soil  When these are detected in the soil near a site, care must be

taken in interpreting this as an indication of pollution.



Preliminary Site Investigation



       The purpose of a  preliminary  site  investigation or exploratory study is to provide

information about a specific site that can be used in making initial management decisions and,

should further work be necessary, for designing a more detailed and comprehensive sampling

investigation.   Since the data  collected during the  preliminary study will be used to make
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important decisions about the site, it is essential that the reliability of the data be demonstrated

through incorporation and implementation of adequate QA/QC.  For example, the preliminary

results may indicate that an emergency response should be initiated.  Making an erroneous

decision based upon data of unknown quality could lead to serious and costly consequences.



Emergency Cleanup Operations



       The purpose of an emergency cleanup operation is to remove enough of the pollutants

as quickly as possible to achieve a level that is considered an acceptable risk to human health or

the environment. The principal role of the QA/QC plan in this situation is to provide a reliable

demonstration that cleanup operations have been adequate. An emergency cleanup operation

often leads to a requirement for either a planned removal or a  remedial response operation.

Thus, any soil sampling undertaken during the emergency phase should have adequate QA/QC

measures incorporated into the study to ensure that  the resulting data may be used as a

foundation for any subsequent investigations.

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Planned Removal and Remedial Response Operations

       The  purpose of planned removal or remedial response operations (they differ
principally with regard to time scale) is to provide a more permanent solution to the problem.
These operations and the associated RI/FS may involve extensive sampling and data analysis
programs. Adequate QA/QC measures are essential, since litigation to recover the costs of the
operations is a probable sequel  Consequently, all data collected may be closely examined in
court.

Monitoring

       Monitoring,  or sequential measurements over time,  may take place before, during, or
after any of the operational situations listed above.  Whatever trends are  measured must be
demonstrated to be reliable in order to serve as a basis for making decisions that hold up to
challenges.
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Research or Technology Transfer Studies

       The purposes of research or technology transfer studies vary widely.  In any event, the
incorporation of adequate QA/QC plans into these studies is mandatory in order for the results
of the studies to withstand the normal peer review processes required for publication and/or
application of the findings.

       In summary, an adequate QA/QC plan should be part of any soil sampling program
relevant to any of the operational situations listed. The only remaining question pertains to the
definition of the word "adequate."  The sections that  follow discuss the above study types in
more detail.

OBJECTIVES FOR BACKGROUND MONITORING

       Generally, the design of soil monitoring programs requires that the levels of defined
hazardous or potentially hazardous  substances  and  their spatial  and  temporal  trends be
measured for some specific purpose.  Often it is critical not only to quantify levels and trends,
but also to link the existing levels to sources.  This is necessary  to enable adequate control
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actions to be taken whenever a situation that is hazardous to human health, welfare, or the

environment is identified.  The situation often is complicated by the fact that multiple sources

contribute to the measured levels.  The situation is further complicated by the presence of

pollutants of recent origin mixed with pollutants of past origin.  This mixing becomes especially

important when the investigator attempts to trace the migration from source to receptor and

also in predicting future levels after  various proposed  control measures  are implemented.

Identification of spatial and temporal trends, along with linkage of observed measurements to

sources, requires that adequate background, reference, or control samples be taken.



       In the absence of such background samples, interpretation of the resulting data may

become extremely difficult, if not impossible. The burden of proof that background samples are

not necessary for  a particular soil monitoring study rests with the principal Investigator. In the

absence  of such  proof,  a prudent investigator will  ensure that an  adequate number of

background samples be included in the monitoring study design.



       Since  measured levels in presumably higher concentration areas will be compared to

background levels, QA/QC procedures are just as critical for the background measurements as

they are for the study  area measurements.   Thus,  for background sampling,  a  QA/QC
                                          91

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procedural umbrella must cover the selection of appropriate geographical areas; the selection

of sampling sites within the geographical areas; sampling, sample storage and/or preparation;

sample analysis, data reduction, and interpretation of study results.



       Under most circumstances, background data will not be available for a given monitoring

location. These data must be acquired either before or during the exploratory or preliminary

investigation phase.  The intensity of the background sampling that is undertaken depends upon

the pollutants being measured, the soil characteristics and variability,  the levels of pollutant

likely to be found in the study area, and the purpose of the study.
SPECIFIC OBJECTIVES FOR MONITORING IN SUPPORT OF CERCLA AND RCRA
       The principal sampling media now being measured to carry out the provisions and

intent of CERCLA and RCRA are soil and groundwater.  Hazardous constituents from a

hazardous waste facility may enter soils through transport of the constituents from the waste

site to soils via organic solvent, surface water, or groundwater flow. Air transport followed by
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dry precipitation, rainout, or washout will generally be less important than other transport
routes.
       Suppose a situation exists in which hazardous waste constituents have been leaving a
site for a relatively long period of time and nearby soils have built up considerable levels of
pollutants.   Further,   suppose that the soils  now  constitute  a source  of the hazardous
constituents. At this time, removal of the hazardous wastes from their  original disposal site
may still leave a significant unsolved problem in the form of the contaminated soils, which may
cause human exposure through skin contact or through ingestion  or inhalation of soil particles.
Also human foods, contaminated directly or indirectly through contact with soils, may be unfit
for human consumption.  Furthermore, as the hazardous constituents move through different
trophic levels, substantial biomagnification of contaminants may take place, thereby increasing
the risk to humans consuming foods from higher trophic levels.  Thus,  it is conceivable that
situations may exist in which concentrations of hazardous constituents in soils may represent a
major risk to human health or the environment.  To identify such situations, data from soil
sampling is an important link in the chain of required evidence.
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       The specific QA/QC precision and confidence level objectives for any sampling study

are controlled in part by the goals of the particular study. Three situations where soil sampling

would probably be undertaken are:



       •      hazardous materials investigations for areas such as  abandoned  landfills or

              chemical spills,

        •     monitoring studies, and

       •      technology transfer.



       The data flow that can occur in each of these situations is outlined in Figures 5,6, and 7.

The data generated in each category can provide input into the development of plans and

specifications for the other situations.  Data that have been subjected to a good QA/QC plan

can be relied upon as a resource for the development of new data.
                                           94

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End
End
                     Preliminary Site
                      Investigation
                        Emergency
                        Clean-up
                               Yes
Clean-up
Complete
  "	 9
        Figure 5. Data acquisition flow for hazardous materials.
                      95

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    Remedial
    Response
    Litigation
    Sampling
   Monitoring
     Effort
Figure 5. (Continued)

       96

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        Corrective
          Action
    Design Corrective
        Measures
    Figures. (Continued)
97

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   Remedial
   Response
   Clean-up
   Complete
       Is
   Litigation
    Planned
    Planned
    Removal
Planned
Removal


FigureS. (Continued)

    98

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        Is
     Research
     Needed
     Research
      Studies
FigureS. (Continued)
99

-------
        Design
   Monitoring Study
         1
       Acquire
   Monitoring Data
        Exceed
       Standards
        Initiate
   Corrective Action
No
Figured. Monitoring data flow.
           100

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    Litigation
   Anticipated
   Litigation
     Studies
Figure 6. (Continued)
101

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         Technology
          Transfer
           Studies
Figure 7. Technology transfer data flow.

      102

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       The main area where the magnitude of the soil sampling can be controlled is in the

precision required by the sampling designs. The accuracy of the sampling is unknown because

the true average is not available. Repeated sampling for high precision nevertheless, must rely

on the analytical accuracy obtained in the laboratory to insure that the methods used measure

what is present in the soil sample.  Thus, the accuracy for analysis applies only to the samples,

while the accuracy for the study depends on the degree to which the samples are representative

of the  area.  The balancing of resources with data reliability is a primary goal  of the DQO

process.



       The specific goals for each type of study will determine the allowable probabilities of

Type I and Type n errors and the minimum relative difference between sampled population

mean and either background mean, or designated action level that is considered  important to

detect.    Suggested guidelines  are  presented below for the operational situations listed

previously.
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PRELIMINARY SITE INVESTIGATION



       The preliminary investigation is the foundation upon which other studies in hazardous

waste site assessments should be based.  As part of this study,  it is essential to determine

whether or not soils are the sample media of importance to the  total assessment. The total

assessment must provide data which will enable decision makers to decide whether the soil

contaminants pose an imminent and substantial endangerment to human health requiring

emergency action,  and whether  there is an  unacceptable long-term risk to  man or the

environment. If soils are determined to be unimportant in the preliminary study, it is likely that

no further attention will be directed to them. In view of this, a Type n error is considered to be

of greater importance than a Type I error.  Presented below are suggested guidelines for use in

developing DQOs that may be used initially.



       Confidence Level           Power       Relative Increase over Background

          (1-a)                    (1 - ft)       [lOO^-Mo)//^ to be Detectable

                                               with a Probability (1-4)

          70 - 80%                90 - 95%            10 - 30%
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       If resources limit the number of samples that can be taken, the investigator should

determine,  for the number of samples that can be collected,  value judgment-based optimum

values  for confidence level, power,  and detectable  relative difference.   If these values are

deemed adequate, the study may proceed.



       Using five-percent duplicate  samples may provide adequate QA/QC for measuring

variance between samples (Plumb, 1981). However, there should be a minimum of two sets of

duplicates in each strata sampled.  As data become available, these assumptions should be

checked. This is usually accomplished by collecting and analyzing more duplicates initially and

then checking to determine the minimum number required for the sites being sampled and the

pollutants being measured.



EMERGENCY CLEAN-UP



       Emergency sampling is designed to identify those areas in which soils are contaminated

to such a degree as to threaten imminent and substantial endangerment to human health.  The

threat  may be due to the soils acting as a  source of hazardous constituents to drinking water,

air, or human foods.  The emergency action in these cases may be nothing more than staying
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indoors on windy days, using dust suppression, switching to bottled water for drinking and/or

taking certain locally produced human foods off the market rather than a full-scale soil removal

program. Soil removal may well be implemented at a later date as part of a planned removal or

a remedial response operation.  Of course, any long-term  solution to the problem would also

have to address the removal of the primary source of hazardous substances to the soils.



       For an emergency response operation involving soils,  a Type n error is considered of

greater importance than a Type I error.   Presented below  are suggested guidelines for

developing DQOs to be used for emergency response operations.



       Confidence Level           Power        Relative Increase over Background

          (1 - a)                  (1-0)         or an Action Level to be Detectable

                                                with Probability (1-0)



          80 - 90%                90 - 95%             10 - 20%
                                          106

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PLANNED REMOVAL AND REMEDIAL RESPONSE STUDIES

       Planned removal and remedial response studies are sometimes continuations of those
initiated during emergency clean-up  studies.  They should be designed to provide specific
information needed to resolve control option issues.  The areas to be surveyed should be
stratified and sampled according to a design that can be used to determine spatial variability. A
suitable statistical design should be formulated so that components  of variance for the study
situation may be  identified  and evaluated.    Appropriate QA/QC  procedures  must be
formulated and implemented.

       If the sampling during exploratory or emergency response investigations has been done
properly,  there will be a sound basis for determining the sample size  and sampling site
distributions.   The design will have to incorporate information on the vertical distribution as
well as the horizontal distributions. Measurements of concentration trends with time may be of
critical importance, particularly if soil concentrations are changing appreciably with time.  For
example, the concentrations of pollutants in soils may decrease with time once  the primary
source of contamination is removed.   This reduction in concentration  may be due  to a
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combination of biotic degradation of the contaminants, chemical degradation,  volatilization,

removal of contaminants by leaching, etc.



       For a planned removal or a remedial response operation involving soils, it is considered

that a "type I and a Type n error are of about equal significance.  Furthermore, an attempt at

cost recovery which might lead to litigation is a likely successor to these studies. Accordingly, it

is important to achieve the highest order of precision and accuracy feasible.  Presented below

are suggested  guidelines for developing DQOs that may be used  for planned removal and

remedial response studies.
       Confidence Level

          (1-or)
Power        Relative Increase over Background

(1-0)         or an Action Level to be Detectable

              with Probability (1-0)
          90-95%
90-95%
10 - 20%
                                          108

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MONITORING OR RESEARCH STUDIES



       The guidelines for confidence levels,  power,  and detectable relative differences for

monitoring or research studies should be set on the basis of the objectives of each study. As

actions which may be taken on the basis of resulting data become more and more significant

and costly, greater effort should be placed on achieving an increased level of reliability for the

data.    Publication of the  results in a peer-reviewed journal will usually require  some

demonstration that an  adequate QA/QC plan has been incorporated into the experimental

protocol.
                                          109

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                                    CHAPTERS

      SELECTION OF NUMBERS OF SAMPLES AND SAMPLING SITES FOR THE
                               DEFINITIVE STUDY
INTRODUCTION



      The QA/QC plan must  be designed to allow for estimation  of  errors  in  the

determination of, as a minimum, mean concentrations and standard deviations of the means.

In some cases the primary interest may be in the determination of a reasonable mean of

extreme values (the stratum having the highest mean concentration) which must be compared

to an acceptable action level  In the latter case corrective actions will generally be required if

the acceptable action level is deemed to be exceeded.  For this case, the QA/QC plan must

provide data on the basis of which one may state with what reliability the action level is, or is

not, exceeded.  Both Type I and Type n errors must be taken into consideration. These errors

can be controlled only by choosing an appropriate number of samples.  (See Table 4.)



      On the basis of data  from the exploratory study, the following minimum amount of

information wifl be available.
                                        110

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TABLE 4.   NUMBER OF SAMPLES REQUIRED IN A ONE-SIDED ONE-SAMPLE
          t-TEST TO ACHIEVE A MINIMUM DETECTABLE  RELATIVE
          DIFFERENCE AT CONFIDENCE LEVEL (1-a) AND POWER OF (1-0).
Coefficient Power Confidence
of Level
Variation
(%) (%) (%)
10 95 99
95
90
80
90 99
95
90
80
80 99
95
90
80
15 95 99
95
90
80
90 99
95
90
80
80 99
95
90
80
20 95 99
95
90
80
90 99
95
90
80
80 99
95
90
80
Minimum Detectable
Relative Difference
(%)
I
66
45
36
26
55
36
28
19
43
27
19
12
145
99
78
57
120
79
60
41
94
58
42
26
256
175
138
100
211
139
107
73
164
101
73
46
10
19
13
10
7
16
10
8
5
13
8
6
4
39
26
21
15
32
21
16
11
26
16
11
7
66
45
36
26
55
36
28
19
43
27
19
12
20
7
5
3
2
6
4
3
2
6
3
2
2
12
8
6
4
11
7
5
3
9
5
4
2
19
13
10
7
16
10
8
5
13
8
6
4
30
5
3
2
2
5
3
2
1
4
3
2
1
7
5
3
2
6
4
3
2
6
3
2
2
10
9
5
4
9
6
4
3
8
5
3
2
I
40
4
3
2
1
4
2
2
1
4
2
2
1
5
3
3
2
5
3
2
1
5
3
2
1
7
5
3
2
6
4
3
2
6
3
2
2
                               111

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TABLE 4. CONTINUED
Coefficient
  of
Variation
Power  Confidence
        Level
Minimum Detectable
Relative Difference
{70) {70 ) {70)
25 95 99
95
90
80
90 99
95
90
80
80 99
95
90
80
30 95 99
95
90
80
90 99
95
90
80
80 99
95
90
80
35 95 99
95
90
80
90 99
95
90
80
80 99
95
90
80
i
5
397
272
216
155
329
272
166
114
254
156
114
72
571
391
310
223
472
310
238
163
364
224
164
103
532
421
304
641
421
323
222
495
305
222
140
10
102
69
55
40
85
70
42
29
66
41
30
19
145
99
78
57
120
79
61
41
84
58
42
26
196
134
106
77
163
107
82
56
126
78
57
36
20
28
19
15
11
24
19
12
8
19
12
8
5
39
26
21
15
32
21
16
11
26
16
11
7
42
35
26
20
43
28
21
15
34
21
15
10
30
14
9
7
5
12
9
6
4
10
6
4
3
19
13
10
7
16
10
8
5
13
8
6
4
25
17
13
9
21
14
10
7
17
10
7
5
40
9
6
5
3
8
6
4
3
7
4
3
2
12
8
6
• 4
11
7
5
3
9
5
4
2
15
10
8
6
13
8
6
4
11
7
5
3
                                      112

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•      Mean concentrations and standard deviations of the means for stratified regions

(assuming it was deemed necessary to stratify the study region).



•      Mean concentrations and standard deviation of the mean for the control region.



•      Results of tests at specified confidence levels to determine  whether or not the

mean concentrations  in all strata are significantly  different from the control region

mean concentration.



•      Results of tests at specified confidence levels to determine whether or not peak

or maximum measured concentrations exceed any established action levels.



•      Some measure, through analysis of variance tests, of the distribution of observed

variances among various elements of the sampling process such as sample collection,

sample handling, and sample analysis.
                                   113

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       An evaluation must be made during Stage 2 of the DQO process to determine which

elements of the exploratory study provide sufficient information to meet program objectives,

and where additional measurements will be necessary. Generally, since the exploratory study

was designed to provide only a  limited  sample of the  desired study population, it  will be

necessary to obtain additional measurements to improve the levels of precision and confidence,

to confirm the results,  and to expand  the measurements to cover regions not previously

sampled.



NUMBER OF SAMPLING SITES REQUIRED



       The minimum number of samples, n, required  to achieve a specified precision and

confidence level at a defined minimum detectable relative difference may be estimated by the

use of Table 4 or one of the following equations:
       n * [(Za +



for a one-sided, one-sample t-test, and
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for a one-sided, two-sample t-test

where: Za is a percentile of the standard normal distribution such that P(Z > Zft ) = ^ Za is
similarly defined, and D »  (minimum relative detectable difference/CV. CV * coefficient of
variation.  For  a two-sided t-test, the values for Za should be changed to Za/2.

       As an  example  of application of the first equation above,  assume CV  » 30%,
Confidence Level = 80%,  Power = 95%, and Minimum  Detectable Relative Difference =
20%. From Appendix B for infinite degrees of freedom (t distribution becomes a normal one)
Za = 0.842 and Z^ - 1.645. From the data assumed, D » 20%/30%. Therefore

       n * [(0.842 + 1.645)/(20/30)]2 » 0.5 (0.842)2
       n * 13.917 + 0.354 - 14.269
       n = 15  (always round up) which agrees with the value given in Table 4.
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       In case multiple pollutants are present, the particular pollutant requiring the greatest
number of samples to  achieve the assigned DQOs would be the controlling factor.  In this
instance, however, all samples collected may not have to be analyzed for all pollutants.

       In general,  a suitable soil sample from a number of possible sampling designs may be
selected on the basis of random, stratified random, judgmental, or systematic sampling.  The
authors recommend the use of geostatistical techniques as the most appropriate methods of
handling spatial data.  The tools of geostatistics are easier to apply and the utilization of
resources is better if one of the systematic designs is used.

       The optimum approach appears to be a combination  of systematic and judgmental
sampling.  Assuming  that appropriate information  has been obtained in the information-
gathering phase of the exploratory study, a conceptual model may be hypothesized describing
the spatial distribution of soil contamination, as well as identifying a likely background or
control area. Judgmental samples can be taken for any purpose; however, these purposes must
be documented and explained Randomization of a systematic grid can be difficult because,
once the spacing is selected, the starting point identified and the orientation chosen, there are
no degrees of freedom to use for randomizing the sample location.
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       The  major axis of orientation should be selected along  the  most likely  route  of

migration. It is likely that there will be no indication of the most likely direction of migration;

however, in such cases, the direction used as the major axis of the sampling grid can be chosen

at random.



       The starting point of the grid may be chosen on the basis of either a random start or the

center of the pollution source.  A smelter stack would be a possible point source for the

pollution, and could be the starting point for the grid. The major axis would be the direction of

the prevailing winds. Sites with no known major concentration(s) or where the source is quite

large in area require a different starting point.  This can be handled by placing a grid over a

map of the area.  A random number table can then be used to select a grid point on  this map,

which becomes the starting point for the sampling grid.  Once the sampling grid is properly

transferred to the map, a convenient numbering scheme can be set up to allow identification of

the samples.



       Samples would  then be collected from each of the grid nodes or at some subset of these

nodes, depending upon the intensity of the sampling expected. The Palmerton NPL Site study,

discussed previously, provides a good example  of this approach.  Samples were collected
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intensely in the areas near the smelter sites, but only selected nodes were sampled in areas

distant from  the  sources.  The starting point for the grid  was the center  of the Town of

Palmerton.
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                                     CHAPTER 9

                  CONTROL OF MEASUREMENT-ERROR VARIANCE


INTRODUCTION



       The quality assurance plan should address two types of variation in soil sample data.

One is the population variation, the variation between true sample values, which is a function of

the spatial variation in the pollutant concentrations.  Treatment of this type of variation is

discussed in Chapter 10.  The other variation,  measurement-error variation in the data, is

induced by differences between true sample values and reported values.



       The distribution of the true values of the pollutant concentrations in the population of

sampling units will typically be multimodal and nothing like the probability distributions dealt

with in statistics textbooks.   The  modes of the distribution will probably correspond to

background values, and concentrations of various types of materials that have found their way

to the site being sampled. It is the distribution of measurement errors and of deviations of true
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values from expected values (see Geostatistics, Chapter 10) that are of principal concern in the

development of the quality assurance plan and in the evaluation of the quality assurance data.

Fortunately, these latter distributions generally are similar to distributions discussed in statistics

texts.



       Plans for the taking of samples, analysis of samples, and analysis of resulting data are

based on assumptions concerning the probability distributions of the measurement errors or of

the deviations of true values from expected values.   These assumptions should be consistent

with results from past surveys taken under similar conditions, and, in particular, with the results

of an exploratory study.



       The variability in measurement errors is a function of the variable being measured, the

sample collection method and handling  procedures,  the analytical procedure, and the data

transcription procedures.   If the distribution  of the measurement  errors is  normal,  it is

symmmetric about its expected value (center of gravity of the probability distribution), and its

variability is completely characterized by its variance (moment of inertia of the probability

distribution about its center of gravity when probability is treated as mass).  The symmetry

makes  the expected value a reasonable measure of location,  whereas in non-symmetric
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distributions other measures of location may be preferred (e.g.,  the median).  Also,  the

statistician has means of dividing variance into components representing various sources of

variation.



       With most non-normal probability distributions, the variability is only partially described

by the variance. Hence, these properties of symmetry, and variance representing variation, are

two prime reasons for transforming variables so that the new variables will have approximately

normal probability distributions.  Procedures for such transformations are given in Box and Cox

(1964) and in Hoaglin et al. (1983). A discussion of the importance of the normality assumption

and data transformations appears in Scheffe (1959). In what follows, we shall assume that the

data have been transformed so that the measurement errors are nearly normal in distribution.

Additional information about the distribution of measurement errors for  various types of

pollutants and measurement procedures may be obtained from the U.S. EPA's Regional Offices

and Laboratories and its National Enforcement Investigation Center in Denver, Colorado.



       If the variable of interest has a count measurement, such as with  radioactivity or the

presence or absence of a pollutant, other statistical methods are required.  These methods are
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usually denoted as qualitative or discrete statistical methods.  Bishop et al.  (1975) is a good

reference to such procedures. The methods of this chapter should not be applied to count data.



       As stated  above,  the measurement error variance is the variance of the differences

between the true concentrations for the sampling units and the reported concentrations. The

variance of the differences between the true and reported concentrations is typically the sum of

variances of many random errors that are made in sample taking, sample  handling, sample

analysis, and data transcription.
GOALS
       There are  two  commonly  encountered rules  of thumb  in restricting the

measurement-error variance that may be viewed as goals in quality assurance.  They are quite

similar and equally  reasonable.  One  rule says keep the measurement error variance to less

than one-tenth the total variance between measurements; the other says keep the measurement

error standard deviation to less than one-fourth the  total between-measurement  standard

deviation.
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       The reason for these rules is that if they are achieved in the absence of measurement
bias, the measurement error on the average is so small relative to the differences between
measurements that it can effectively be ignored  when analyzing the data.   If one has not
accomplished this goal  in a survey, there  are many almost insoluble difficulties in the final
analysis of the data. A major problem is that measurement errors are typically correlated (e.g.,
a calibration error  that  causes one  measurement to be too large will  cause the other
measurements to be too large until the next calibration).   The levels of correlation in these
measurements are difficult to estimate,  but are  needed to calculate estimation variances if
measurement error variance is not small relative to total variance.  Once either goal has been
reached, it is hard to justify any  additional effort to reduce measurement error variance, since
that reduction will affect such  a  negligibly small change  in the  total variance and in the
variances of the sample estimates.

       It  is necessary to  search out the major sources of measurement error variance and
develop QA procedures to ensure that these sources are controlled.  It is also necessary that
QA data  be  obtained to  monitor the  sources  of error and  to provide an  estimate of their
contributions to total error variance in the final QA data analysis.
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COMPONENTS OF VARIANCE

       The measurement error in a soil sampling survey is usually the sum of several errors
from independent sources. The total measurement error variance can be represented by a sum
of the variances of the errors arising from these independent sources. A procedure called
components of variance  analysis  (Scheffe,  1959; Snedecor and Cochran,  1982) provides
estimates  of the  portion of the  total variance coming  from each  of the  sources in the
measurement process.  Basic assumptions of this procedure are that the measurement errors
are normal  in distribution, independent, and for each  independent source have constant
variance.
       Example:  Consider the hypothetical data from a stratified random sample design
       that  has four strata,  three random samples per stratum,  two subsamples per
       sample, and one analysis per subsample.  The stratum effects are assumed to be
       fixed unknown  constants.   The random sources  of variation  in the data are
       between samples within strata and between subsamples within samples (combined
       with analytical error).  In the table of data below, a period in place of a letter in
       the subscript means that the data have been summed over that letter (e.g., 2^ X.{..
       - V
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Computations:

I.      C=X2/(abn) = (82.30)2/24 = 282.2204

H.     Total: Z^ X2k - C - (3.172 + ...+ 4.632) - C * 29.8656

m.    Strata: ^ X2../bn - C - (14.752 + ...+ 26.812)/6 - C = 23.7517

IV.    Samples: 1^ X2 /n - C = (5.812+...+ 20.422)/2 - C = 26.3109

V.     Samples within Strata: IV - m - 26.3109 - 23.7517 » 2.5592

VI.    Subsamples within Samples: H-IV » 29.8656 - 26.3109 - 3.5547
These computations are now organized within the table below.
                     Analysis of Variance
Source of
Variation
Strata
Samples/
Strata
Subsamples/
Samples
Total
Degrees of
Freedom
a-1-3
a(b-l)-8
ab(n-l)-12
23
Sum of
Squares
23.7517
2.5592
3.5547
29.8656
Mean
Square
7.9172
0.3199
0.2962

Expected
Mean Square
0^+nff2 + bnM/3
"l*1^
"1

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       From the analysis of variance table, one obtains the variance estimates:

       SA = 0.2962, which estimates c£, variance owing to subsampling and analysis;

       s2B = (0.3199 - 0.2962)/2  = 0.0118, which estimates o£,  the  variance  owing to
       sampling within strata.


              The symbol M in the above table stands for the sum of squared deviations of

       stratum means about their grand mean.



              The results of this analysis indicate that the experimenter should either have

       made a greater effort to reduce subsampling and analytical errors or taken many

       more subsamples, since the error variance estimated by s^ (» 0.2962) is much larger

       than the estimated variance s|  (= 0.0118), between samples within strata, which is

       just the opposite of the goal suggested earlier in this chapter.



       While  the above example illustrates a classic components  of variance analysis for a

situation in which the data have a hierarchical structure (i.e., strata, samples within strata, etc.),

there are many instances in environmental monitoring where this  hierarchical structure is

lacking and other methods of separating the variance components are called for.  Such an

example involving quality assurance samples is given in the next section.
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QA SAMPLES



       In quality assurance, procedures are specified for the survey in an attempt to keep

measurement errors, measurement bias, and measurement error variance small. It is essential

that the sampling project include  the means to determine whether the  procedures are being

followed  and the necessary data at the end of the survey to show how  successful the quality

assurance procedures were in controlling measurement-error variance.  To obtain the needed

data, it is necessary to introduce QA/QC samples into the measurement process.



       The  principal independent sources of random  error must be specified.   If the

independent sources of random error are listed as sources A, B, ..., then the total measurement

error variance, aT2 can be written as
where a^is the variance of the random errors associated with source A, etc. A partial list of

such sources might include failing to sample at specified sampling locations, mistakes in taking

the sample,  errors  in processing the sample,  subsampling errors,  analytical errors,  and
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transcription errors.  Measurements on quality assurance samples can be used to estimate the

variances from one source or  the combined variance  of  several  sources  of random

measurement error. In addition, quality control samples can be used to determine whether the

measurement systems are in control during the survey.  For example, laboratory audit samples

are run along with field samples.  If the errors in the measurements of these audit samples are

too large, they will indicate that the laboratory analytical process is out of control and that

corrective action is required prior to analysis of additional field samples.



       Example:  This example  again considers the exploratory study  performed at the

       Palmerton NPL Site (Starks et al., 1987) mentioned earlier. The duplicate samples

       (Table 2) taken at each of ten sampling locations were QC samples.  The individual

       cores (Table 3) that were taken at ten sites but not composited were QC samples. In

       this study, the four composited cores taken from each site were mixed and sieved. A

       subsample was then taken and sent to the laboratory for analysis of concentrations of

     -  four metals (Cd, Pb, Cu, and Zn). For the soil from 10 sites, an additional subsample

       (called  a  split) was taken after the mixing and sent  to the laboratory with no

       identification to associate it with the first subsample taken from  the soil sample.

       These splits were also QC samples.  The results from the splits are given in Table 5.
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This example shows how these three types of QC samples were used in evaluating

the QA procedure employed in the exploratory study.



       The  variance estimate s2 -  0.0032  in  Table 5 gives  an estimate  of the

measurement error variance coming from subsampling, analysis, and data recording.

The variance estimate s2 = 0.0691 obtained from duplicate samples in Table  2 is an

estimate of the total of  the variance coming  from short range (0.5 m)  spatial

variation, sample taking and handling, sifting and mixing, and also the subsampling,

analysis, and data recording. Hence, the difference, s2, » 0.0659, between these two

variance estimates is an estimate of the total of the measurement error variances

coming from short range (0.5 m) spatial variation, sample taking and handling, sifting

and mixing.  If the variance s2  were primarily from errors in sampling handling,

sifting and mixing, one would expect a variance between  individual cores (s2  =

0.3659, Table 3) similar  to that between duplicates. This was not the case, so one is

led to the conclusion that the  combination  of short-range spatial variation and

variation in sample taking is the major  contributor to total measurement-error

variance. For this reason, the support of the sampling units was increased from four

to nine cores in the second (definitive) study.
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        TABLE 5. RESULTS FROM SPLITS AT THE PALMERTON NPL SITE
SITE
DD70
BV35
CB34
BT70
AY34
BT35
DP82
CB42
BR34
CD24

CADMIUM*
4.17 4.13
116 106
73.8 63.1
7.34 7.32
88.0 81.9
95.1 83.1
2.50 2.43
280 279
68.7 63.3
9.1 8.99
s2 - XLj2/20 »
D"
0.04
10.00
10.70
0.02
6.10
12.00
0.07
1.00
5.40
0.11
0.0032
Lb
0.010
.090
.157
.003
.072
.135
.028
.004
.082
.012

       "units are mg/kg
       bD * absolute pair difference, and L = absolute pair difference of log-transformed data
       Table 6 lists typical QA/QC samples and how measurements of these samples are used

in the  control  of the measurement process and in the evaluation of the quality assurance

procedures employed by the project. To obtain an unbiased measure of the internal consistency

of the samples and their analyses, the individual QA/QC samples should be labeled with a code

number so that the chemist (and preferably also the laboratory) does not know the relationship
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between the samples he is analyzing.  This reduces the chances of conscious or unconscious

efforts to improve the apparent consistency of the analyses.



       Samples can be split to:



              •      provide samples for both parties in a  litigation or potential litigation

                     situation;

              •      provide a measure of the within-sample variability;

              •      provide materials for spiking in order to test recovery; and

              •      provide a measure of the analytical and extraction errors.



The location of the sample splitting determines the components of variance that are measured

by the split. A split  made in the sample bank (i.e., facility to which samples are sent from the

field) measures error introduced from that level onward.  A split made in the field includes

errors associated with field handling. A split or series of subsamples made in the laboratory for

extraction purposes measures the extraction error and subsequent analytical errors.
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                     Table 6. Type of QA/QC Samples or Procedures
Procedure                         Description
1.   Field Blank                 A sample container filled with distilled,  deionized (DDI)
                                water, exposed during sampling and then analyzed to detect
                                accidental or incidental contamination.

2.   Sample Bank Rinsate        A sample (last rinse of DDI water) of DDI water, passed
                                over the sample preparation apparatus, after cleaning,  to
                                check for residual contamination.

3.   Field Rinsate                A sample (last rinse of DDI water) of DDI water, passed
                                over the sampling apparatus after cleaning,  to check for
                                residual contamination.

4.   Reagent Blank              A DDI water sample analyzed  as a routine sample  to check
                                for reagent contamination.

5.   Calibration Check Standard  A standard material to check instrument calibration.

6.   Spiked Extract              A  separate aliquot of extract to which a known amount of
                                anatyte  is added to check for  extract matrix effects on the
                                recovery of added analyte.

7.   Spiked Sample              A  separate aliquot of the soil sample haying an  appropriate
                                standard  reference material added to check for  soU  and
                                extract matrix effects on recovery.

8.  Total Recoverable          A  second aliquot of the sample which is analyzed by a more
                                rigorous  method  to check the  efficacy of the  protocol
                                method.

9.  Laboratory Control Standard A sample of a soil standard carried through the analytical
                                procedure to determine overall method bias.

 10.  Re-extraction               A re-extraction of the residue from the first extraction to
                                determine extraction efficiency.

                                                                             (Continued)


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Table 6. Continued
Procedure
   Description
11.  Split Extract
12.  Triplicate Samples (Splits)
13. Duplicate Sample
14. Field Audit
15. External Laboratory Audit
 16. Internal Laboratory Audit
An additional aliquot  of the extract which is analyzed to
check injection and instrument reproducibility.

The prepared sample is split into three portions to provide
blind  duplicates for the analytical laboratory and a third
replicate  for the  referee  laboratory to  determine
interlaboratory precision.

An additional sample  taken  near  the field  sample to
determine total within-batch measurement error.

A sample of well-characterized soil that is taken into  the
field with the sampling crew, sent through the sample bank
to the laboratory with the field samples to detect bias in the
entire measurement process and to determine batch to batch
variability.

A sample  of well-characterized soil  sent directly  to  the
laboratory for analysis.   The  analyte concentrations  are
unknown to the laboratory.  This  type of sample is used to
estimate laboratory bias and batch-to-batch variability.  It
may  also  be used  for external quality control  of  the
laboratory.

A  sample  of well-characterized  soil,  whose analyte
concentrations are known to the laboratory, to be used for
internal laboratory quality control.
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    Spiked samples are prepared by adding a known amount of reference chemical to one of a

pair of split samples. Comparing the results of the analysis of a spiked member to that of the

non-spiked member of  the  split measures spike recovery  and provides  a  measure  of the

analytical bias. Spiked samples are difficult to prepare with soil material itself. Frequently the

spike solution is added to the extract of the soil sample. This avoids the problem of mixing, but

does not provide a measure of the interaction of the chemicals in the soil with the spike, neither

does it provide an evaluation of the extraction efficiency.



    Blanks and rinsates provide a measure of various cross-contamination sources, background

levels in the reagents,  decontamination efficiency,   and other potential  error that can be

introduced from sources other than the sample.  For example,  a field blank measures input

from contaminated dust or air into  the sample. A rinsate sample measures any chemical that

may have been on the sampling tools after the decontamination process is completed.



    A question that frequently arises is how many QA/QC samples of each type are needed in

a study. One often sees rules of thumb such as one for every 20 field samples. However, such

rules  of thumb are oversimplifications and should be treated with great  caution.   A better

approach  is to determine how each type of QA/QC sample is  to be employed and  then
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determine the number for that type based on the use. For example, field duplicates are used to

estimate the combined variance contribution of several sources of variation.   Hence,  the

number of field duplicates to be obtained in the study should be dictated by how precise one

wants that estimate of the variance to be. The precision of an estimate of the variance depends

on the degrees of freedom (i.e., number of duplicate pairs) of the estimate. Table 7 gives the

95% confidence intervals for various numbers of degrees of freedom, based on an assumption

that the data are, or have  been transformed to,  normally distributed data.   Methods for

obtaining such confidence intervals for any number of degrees of freedom are given in most

elementary statistics texts.



	Table 7. Some 95 Percent Confidence Intervals for Variance	

    Degrees of Freedom                         Confidence Interval


              2                                 0.27s2* a2*  39.21s2
              5                                 0.39s2 * 02*  6.02s2
             10                                 0.49s2 * 02*  3.08s2
             20                                 0.58s2* a2*  2.08s2
             50                                 0.70s2* a2*  1.61s2
             100                                 0.77s2 * a2 $  1.35s2
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    If it is decided that 20 degrees of freedom gives satisfactory precision for the estimate of

the variance, one might equally space the duplicate samples among the field samples so as to

have 20 duplicates by the end of the survey.  Alternatively, one might take duplicate samples at

a fairly high frequency at the start of the survey until 10 duplicate pairs are obtained and then

obtain the remaining ten duplicate pairs at a reduced rate over the remainder of the survey.

This second procedure would allow an early estimate of the variance based on 10 degrees of

freedom to determine whether  the  QA plan is resulting in error variances  in  the  range

expected, and the remaining ten pairs would allow the after-survey variance estimate to take the

entire survey into account.



    Some types of samples, such as the calibration check standards, are used to provide a

quality control function.  That is,  if measurements of these check standards differ by too much

from their reference values, the instrument is declared out  of control and will have  to  be

adjusted.   Then it will be necessary  to go back and re-analyze all samples between the last

in-control reading and the out-of-control reading.  The frequency of use of samples of this

quality control type should be based on costs of the analyses of these samples versus the costs of

reanalyzing field samples in out-of-control situations.  This frequency of use will also be a

function of the probability of obtaining an out-of-control situation in the laboratory. Of course
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the objective is to minimize  expenditures of both time and money while obtaining data of

adequate quality.



    The percentage of the total monitoring effort allocated to QA/QC will depend on many

factors including the size of  the project,  the available  knowledge concerning sampling and

analytical procedures, the relationship of environmental risk to pollutant concentration, and the

nearness of action levels to method detection limits.  Typically the smaller the project, the

larger will  be the  proportion of cost allocated to QA/QC.   New,  untried procedures will

typically require pilot study runs and additional training for personnel.  If the action level is

near the method detection limit, there will be little room for error in the measurements, and

the QA/QC effort may have to be large to assure that measurement errors are kept small. One

should not  specify a certain percentage of a project's costs to QA/QC without considering the

above factors.
BIAS
    Bias identifies a systematic component of error that causes the mean value of the sample

data to be either consistently higher or consistently lower than the true mean value. Bias may
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be caused by faults in sampling design, sampling procedure, handling procedure, or analytical

procedure.  An example of a bias would be the error in analytical results introduced by an

instrument's being out of calibration during a  portion of the analysis.   Laboratories usually

introduce reference and audit samples into their sample load to detect possible changes.  Bias

in soil sampling is difficult to detect.  The presence of a bias can be proven by the technique

described as standard additions or by using audit samples.  On the other hand, it is difficult to

prove that bias is not present because an apparent lack of bias may be the result of an inability

to measure it rather than its actual absence.



    A procedure called standard additions is commonly used to detect bias in a sampling effort.

In this procedure, known amounts of standard solutions are added to aliquots of soil samples.

It is recommended that this be done in the field or in a field laboratory.  The main problem

encountered is that mixing soils to obtain homogeneity is difficult in a laboratory,  and even

more so in the field. Several known quantities of the standard are added to the aliquots of the

soil samples. The analytical results should follow a straight line:



                                       y » a + bx,
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where x is the increase in concentration caused by the addition and y is the value obtained by

the laboratory. Bias is indicated if the data do not follow a straight line, or if a < 0. If the units

of x and y are the same, the value of b should be near one, and a significant deviation from one

would indicate a proportional bias.
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                                     CHAPTER 10

                       SAMPLE DESIGN AND DATA ANALYSIS

       Data obtained from soil sampling is  used to estimate characteristics of the sampled

population, such as pollutant concentrations on action supports at various locations on the study

site and mean concentrations of background regions.  There are three basic approaches for

increasing the precision of statistical estimates and the power of statistical tests to be based on

survey results.  They are:  (1) to use more efficient  statistical estimators and tests; (2) to

improve the sampling design; and (3) to increase the sample size (i.e., to increase the sampling

density).  This chapter deals with the influence of sample design and estimation  techniques on

the variance of estimates and the power of tests, with determination of required sampling

density, and with statistical analysis of survey data.



SAMPLE DESIGN



       Given a site to be sampled,  several decisions must be made as to how the soil will be

sampled. First, the support for the sampling unit must be specified, then decisions concerning
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type of sampling design and sampling density must be made.  The prime objectives of a

statistical sampling design are either to provide the most complete information possible about a

question of interest for a  fixed survey cost or to minimize survey cost for a fixed amount of

information.  A common measure of the amount of information provided by a survey about an

estimated parameter is the inverse of the variance of the estimate.  Secondary concerns in

sampling design are simplicity of resulting data analysis and simplicity  of field operations in

performing the survey.



       A common type of design given in many elementary texts is the simple random sample

design in which the sampling units are determined by random selection without replacement.

This plan for site investigation simplifies the statistical analysis; however, it is typically very

wasteful of resources and is, therefore, very difficult to justify.



       The stratified random design is another common type of design.  With this design the

region  to  be sampled is partitioned into subregions (strata) on  the basis of  suspected

differences in level of pollutant, on cost of sampling, on the basis of equal strata  areas, or on

some combination of the  above.  A  simple random sample is taken from each stratum.  For

example, one may have sufficient information to divide the site into strata where the level of
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pollutant concentrations is either far above action level, near action level, or far below action

level. In this case, it would seem reasonable to expend most of the sampling effort (i.e., high

sample density) on the strata that is near action level, so that one can decide with a high level of

accuracy which parcels of land need remediation and which do not.  Stratification ensures that

all subregions of the site will  be sampled, which may not be the case with a simple random

sample of the site.



       Stratification can use scientific or historical knowledge that the pollutant concentrations

are  quite  different  in  identifiable  segments of the area  being  sampled to  improve the

subsequent estimate of the mean concentration over the entire site. Another criterion that may

be useful in stratification for environmental soil sampling is distance from known point sources.



       Both stratified random sample and simple random sample procedures were developed

for sampling of discrete sampling units and do not adequately take into account the spatial

continuity  and spatial correlation of soil properties.  Samples taken at locations that are close

together tend to give redundant information and are therefore wasteful of resources.  For this

reason, some type of sample selection grid (systematic design) is often used to assure that
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sample  locations will  not  be close to one another.   The grid  may  be radial,  triangular,

rectangular, hexagonal, etc.



       Systematic grid designs provide many  of the advantages of  stratification  plus the

avoidance of redundant samples.  They thereby improve precision and power. Investigations of

the efficiencies of the grid designs show that the hexagonal grid is the most efficient given

certain assumptions about the spatial distribution of the pollutant, but the square or rectangular

grid is easier to use in practice.  The difference in efficiency is not great.  The radial grid has

some advantages in investigating the distribution of a pollutant near a point source.



       A grid will typically be oriented in the direction of flow of the pollutant, which may

relate to site topography or a  wind rose.  Once the sampling density  (grid spacing) and the

orientation of the grid has been determined, a selection of one sample location will completely

determine the locations of all sample locations.



       A possible shortcoming of  the grid design is the  possibility of a periodicity in the

pollutant concentrations, with the grid spacing a multiple of the period.  This is an extremely

unlikely situation in  pollution studies,  but one  way to guard against this possibility is  to
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superimpose a small stratified random sample over the grid design.  In this case the strata

would be subregions of approximately equal area.  In practice, even when a grid (systematic)

design is employed, many of the actual sample locations will not be at the grid locations because

of the presence of obstructions such  as roads,  houses,  rocks, and trees.  Also, a soil sample

should not be taken at a specified grid point if it is evident that fill has recently been added or if

there has been a recent grade cut at the location.  When the field crew cannot  sample at a

specified location,  they should have  instructions to take a sample at the nearest point in a

prespecified direction from the original point where a sample can be obtained, provided that

the location is within a specified distance (usually less than half the grid spacing) of the original

point.



       Simple random sampling and  stratified  random sampling designs are among a class of

designs originally developed for the sampling of units that are discrete objects such as people,

houses, and retail stores. The statistical analysis techniques associated with these designs  are

primarily associated with the estimation of population means.  The basic designs and statistical

procedures  associated with surveys of discrete objects are given in a text by Hansen  et  al.,

(1953).
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       The systematic grid  designs are more closely related  to the sampling of continuous

media such as soil, air, and sediment.  In the sampling of continuous media, the sampling units

must be defined in terms of support (Chapter 5). Gy (1982) gives an extensive description of

techniques for the sampling of the continuous media of participate materials. The statistical

analyses associated with the  results of these surveys of continuous media are typically aimed at

estimating the spatial distribution of a property of the media such as a pollutant concentration

or in finding "hot spots" within the region or site being sampled.



       Many of the statistical techniques used in the analysis of  data from  surveys  of

continuous media fall into a category called geostatistics.  For sample surveys involving random

selection of sampling units, the statistical procedures are usually formed on a probability base

provided by the randomization, while in geostatistics, the statistical inferences are based on

what is known as a random field model A good discussion of the nature and differences of

these two approaches is given in a paper by Bergman and Quimby (1988).
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ROLE OF QUALITY ASSURANCE IN SAMPLE DESIGN



       The Quality Assurance Officer should be involved in reviewing the sampling design

proposed by the investigator. He or she should require that the information obtained provides

measures of the components of variance that are identified in the field.  An additional quality

check that should be undertaken as part of the QA program is the review of the  design by

qualified soil scientists and other peers who are in a position to provide the necessary oversight

of the sampling effort.



       Broms (1980) makes the following statement: There should be a balance between the

soil investigation method,  the quality of the soil samples,  and the care  and skill spent on the

preparation and testing of the samples.  There is no point in spending time and money on

careful sample preparation and testing if the quality of the samples is poor." The QA program

must address the total flow of information from the design to the reporting of results.   The

sampling design is  the foundation of the  whole study;  therefore,  it must be given careful

consideration if the purposes and data quality objectives of the sampling effort are to be met.
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Compositing of Samples



       From the point of view of geostatistics, it is desirable to have a sample support that has

a fixed depth and a square horizontal cross-section,  because such supports can be grouped

together to form rectangular blocks and action supports, and potential clean-up areas (e.g., city

lots) are  typically rectangular.   However, to sample such  a square support of sufficient

cross-sectional area to make its short-range variance small requires the taking of a very large

quantity of soil  It is difficult to handle large quantities of soil and make them homogeneous

prior to subsampling.  One way  to avoid this problem is to take a uniform array of soil cores

within  the square in sufficient  number  so that the error variance associated  with the true

differences  between  the  average pollutant concentration of the squares  and  that of the

associated composites of the cores  is quite  small relative  to  the short-range  variance of

pollutant concentrations of the square supports. This procedure is explained in detail in Starks

(1986).



       While compositing of cores at individual sampling sites can be quite advantageous in

terms of handling costs and measurement errors, the compositing of samples from different

sampling  locations should be done with great caution if at all.  The compositing of samples
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technique is often performed to reduce sample handling and analytical costs.  This procedure is

used extensively by agricultural workers to determine fertilizer requirements  for farm fields.  It

is also done in medical studies to screen blood samples for relatively rare antibodies. Peterson

and Calvin (1965) make the following statement about the technique:



       "It should be pointed out that the composite samples provide only an  estimate of the

       mean of the population from which the samples forming the composite are drawn.

       No  estimate of the variance of the mean, and hence, the precision  with which the

       mean is estimated can be obtained from a  composite  of the samples.  It is not

       sufficient to analyze two or more subsamples from the same composite to obtain an

       estimate of the variation within the population.  Such a procedure would permit the

       estimation of the variation among subsamples within the composite,  but  not the

       variation among samples in the field.  Similarly, if composites are formed  from

       samples within different parts  of a population,  the variability among the parts, but

       not the variability within the parts, can be estimated. If an estimate of the variability

       among sampled units within the population is required,  two or more samples taken

       at random within the population must be analyzed separately."
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       Youden and Steiner (1975) caution against the use of the composite sample for many of

the same reasons as those outlined above. Since the prime purpose of QA/QC is to assess and

assure acceptable values for the bias and the precision of the data and of estimates obtained

from the data,  it is essential to be  able to gauge the precision of the data.  Therefore, the

compositing of samples cannot, in general,  be recommended unless  it is for a stated specific

purpose and unless a justification is provided.



       Some work on determining  the precision of estimates of the mean  from composite

samples has been published.  Such estimates  of precision usually require strong assumptions

about variance  components and/or the stochastic nature of the composited samples.   (See

Duncan, 1962, and Elder et al., 1980.)



GEOSTATISTICS



       Geostatistics is an application of classical statistical theory to  geological measurements

that takes into account the spatial continuities of geological variables in estimating the

distribution of variables.  In many ways, geostatistics is for measurements taken in 2-, 3-, and

4-dimensional space (the three spatial dimensions and the time dimension), what time series is
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for measurements taken in one-dimensional space time.  However,  a principal use of time

series is in forecasting; in geostatistics, the principal emphasis is on interpolation.  Nevertheless,

both statistical procedures emphasize modeling the process to get an insight into the system

being investigated.



       For purposes of discussion, consider sampling units that have a support that is a volume

with a square horizontal cross-section (s x s) and a fixed depth d for a total volume of ds2. It

will be assumed that the correlation (and covariance) between a measurement  of a sampling

unit and that of any other sampling unit is strictly a function of the distance between the units.

(It is important to remember that the population of all the sampling units is the volume of soil

of interest in the site under investigation and that the soil samples taken in the  survey form a

proper subset of the population of sampling units.)



       A geostatistical estimation procedure called block kriging (named after a South African

mining engineer named D.G. Krige) is employed to estimate the mean pollutant concentration

in a rectangular block of sampling units. The estimate of the mean concentration is a linear

combination 2a^, of the concentration measurements z. obtained at sample locations on or near

the block.   The coefficients a.  are chosen to  minimize,  subject to certain constraints, the
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estimation variance V(M* - M) where M* is the estimator of the mean block concentration and

M is the mean block concentration.



       V(M* - M) = 22ajajCov(Zi,ZJ) + ZZCov(Ch,Ck) - 2ai2Cov(Zi,Ch)



where Cov stands for covariance,  Z; is the random variable corresponding to measurement z;,

and Ch is the concentration of pollutant in sampling unit h in the block. The calculation of the

coefficients a; that minimize the estimation variance is  a simple mathematical procedure

involving the solution of a system of linear equations subject to a set of linear constraints on the

ar Once the a{ are calculated, the estimate of the mean concentration and the variance for that

estimator are found directly by substitution in the above equations.  The constraints imposed on

the coefficients a:  depend on how the  expected  value of Z{ is related to the location of the

sampling unit L  The relationship between location and expected value is called drift in the

geostatistical literature.  If the expected value  of Z. is independent of the location of the

sampling unit, one says that there is no drift.  The nature of the drift and of the covariance

function taken together are sometimes referred to as the spatial structure of the phenomenon

being measured Typically, the spatial structure will have to be estimated from the data, but the

nature of the phenomenon being measured will usually provide basic information as to which
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spatial structures are reasonable and which are not.  For example, in measuring the pollution

emanating from a point source, it would seem reasonable to expect drift to be present; that is,

one would expect to find higher concentrations of the pollutant close to the source than at a

greater distance.



       One of the major problems in using these geostatistical procedures is in the estimation

of the covariance as a function of distance.  It  must be estimated from the data.  The several

ways of doing this, unfortunately, will typically give quite different answers.  It is essential that

the assumptions about drift used  in obtaining  an estimate of the covariance function  be

consistent with  the realities of  the  phenomenon  being measured and that the  estimated

covariance function be checked against the data for goodness of fit. This check against the data

is done by a process called cross-validation. Cross-validation in this instance consists of kriging

to obtain an estimate of the concentration at  each sample  location  based on data from

neighboring sample locations.  The observed measurement at that location is then subtracted,

and  this  difference is divided by  the square-root of the estimation  variance to  obtain a

standardized score.   This is done  for all sample locations, and the sample  variance of the

standardized scores is obtained. This sample variance should be close to one. (Starks and Fang

[1982] also  conjectured that the standardized scores should have an approximately normal
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distribution.)  One of the problems faced by users of geostatistics is that there are a large

number of software packages on the market that will take the data and do the kriging without

any consideration of whether the assumptions implicit in the package procedure are correct and

without any cross-validation of the results.



       It  should  be pointed out that because kriging obtains estimates by assigning larger

weights to nearby sample location measurements and smaller weights to those more distant, the

estimations  of pollutant concentrations are  quite similar over a wide  range  of covariance

functions  that might be employed.  However,  in quality assurance,  one is also interested  in

estimating the precision of the concentration estimates, and here is where the trouble lies.  Bad

estimates of covariance  functions will usually  lead to bad estimates of the precision of the

kriging estimates.   Bad estimates of  precision in the exploratory study can,  in turn, lead  to

inaccurate estimates of the number of samples needed in the definitive study.



       Once an  acceptable estimate of  the covariance function has  been  found from the

exploratory  study,  an acceptable spacing for sampling locations on a square grid can be

determined  by use of the kriging procedure.   The  estimation variance in block kriging is

determined  solely by the covariance  function,  the spacing of the sample locations, and the
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position of the block relative to the sample points. A block in the center of the square formed

by four points in the sample location grid will have a larger estimation variance associated with

it than will any other block of equal size located within the array of sampling locations. Hence,

one can pick a grid spacing distance,  arbitrarily assign values to the sample locations, perform

the block kriging on a block  at the center of a square,  and find  the maximum estimation

variance for that block size. By trial and error, one can quickly find a grid spacing that gives a

maximum  estimation  variance  that  is sufficiently small to  be  in accord with  precision

requirements of the quality assurance plan (i.e., satisfies data quality objectives).



WARNING:  Kriging  is  a good procedure for interpolation,  but  a  bad  procedure for

extrapolation. Do not give credence to block kriging estimates for locations that are beyond the

range of the sample locations.



OBJECTIVES



       In  all the operational situations listed  in Chapter 7,  preliminary site investigations,

emergency cleanup  operations, planned removal operations,  remedial response operations,
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monitoring, and research or technology transfer studies, one or all of the following questions

will be of primary interest.



       •      Are there any action supports (see Chapter 5) within the  study area that have

              pollutant concentrations above action level concentration?

       •      Where are the above-action-level action supports located?

       •      What is the spatial distribution of pollutant concentration levels among action

              supports that have pollutant concentrations above action level?



In many situations, the answer to the first question is known from previous studies. But if it is

not known, one needs to plan the sample survey in such a way as to be reasonably sure that

there are no action  supports with pollutant concentrations above action level if none of the

samples in the  survey  has a measured concentration above action level    The statistical

procedures for "hot spot" detection that are used in such planning are discussed in a subsequent

paragraph.  The procedures for answering the other two questions were discussed earlier in the

section on geostatistics.  No elaborate (or simple) tests of hypotheses  are  required.  If no

samples show concentrations above action level, no remedial action is called for. If, however, a

sample with proper support, which is considered reliable because of an excellent QA/QC
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program being in place, is obtained that has a pollutant concentration above the action level,

then remedial action is called for in the neighborhood of that sample.



       The problem with posing soil sampling methods and objectives in terms of population

means is that the mean will depend on the area chosen.  If one chooses a small area near a

point source, the mean may exceed the action level;  but if one increases the area so that it

contains a region that is not contaminated or that is only  lightly contaminated by the point

source, the mean may not exceed the action limit.  Decisions on the need for remedial action

should not be based on how one chooses the size of the area to be sampled, but rather on whether

action supports exist that are  above designated action  limits.  About the only place where a

comparison of means seems  reasonable is in comparing  the pollutant concentrations at a

background (up-gradient) site  with the pollutant concentrations of a site down-gradient from a

suspected point source.  Also, clean-up areas may be defined so that the average concentration

in those units of soil must be compared with a standard.
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DESIGN FOR HOT SPOT DETECTION



       As stated earlier in this chapter, one of the primary questions in many environmental

monitoring situations is whether  there are any action supports in the study area in which the

pollutant concentration exceeds the action level concentration.  (We shall call an action support

in which the pollutant concentration exceeds the action level a hot spot.)  If this is a primary

question in a study, then subsequent questions in the planning of the sampling design are:



       •      What is the probability that a sample will detect  a hot spot? and

       •      What is the probability that a hot spot exists when no hot spot is found in the

              sampling?



The procedures for addressing these design problems are discussed in  more detail by Gilbert

(1987).



       The assumptions that will be made in this discussion are the following:

       (1)    the hot spot is circular in horizontal cross-section;

       (2)    samples are taken on a square grid;
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       (3)     the  distance  between  grid points is much larger than the sample support

              diameter;

       (4)     there are no measurement misclassification errors (i.e., if a sample comes from

              a hot spot,  the measured pollutant concentration in the sample will exceed

              action level;  and,  if the sample is not of a hot spot,  the measured pollutant

              concentration will be below action level); and

       (5)     either the hot spot or an initial point in defining the sampling grid is randomly

              located within the site.



(Gilbert [1987] allows elliptical hot spots and rectangular or triangular grids In his discussion.)



       Let R represent the radius of a hot spot and D be the distance between adjacent grid

points where samples will be collected. The probability that a grid point will fall on a hot spot is

easily obtained from a geometrical argument since at least  one grid point must fall in any

square of area D2 centered at the center of the hot spot.  From this concept, it follows that the

probability of sampling a hot spot is given by
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       P(H) = (wR2) / D2     ifR^D/2

            = {R2[* • 2 arc cos (D/(2R))] + (D/4),/(4R2 - D2)}/!)2     if D/2 < R < DJ2/2

            = 1   if R £ DJ2/2



where the angle whose cosine is D/(2R) is expressed in radian measure. If the grid spacing is

taken to be D = 2R, the probability of a hit is ff/4 = 0.785, which implies that the probability

that this grid spacing would not hit a hot spot if it exists is 0.215.



       The second question concerning the  probability that no hot spot exists (given that none

was found) requires the use of a subjective  probability, P(E), based on historical and perhaps

geophysical evidence of the existence of a hot spot on the site.  Then, if E is the event that there

are no hot spots at the study site and if R is the event that no hot spot is sampled in the survey,

Bayes formula gives


           P(E |  H) - P(R | E) P(E) / [ P(H | E)P(E) + P(R |B)P(E)]

                                 -  P(H|  E) P(E) / [P(H| E)P(E) + P(E)].
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For the case where D  = 2R, it was found that P(H | E)  = 0.215, so if one is given that the

chance P(E) of a hot spot is thought to be 0.25 prior to the investigation, the probability of a hot

spot existing if the study does not find a hot spot is



              P(E | no hit) « 0.215 (0.25) / [0.215 (0.25) + 0.75] = 0.067.



Hence, the probability that no hot spot exists is (1 - 0.067)  = 0.933.
SOME CLASSICAL STATISTICAL PROCEDURES



       In this  section, classical tests of hypotheses,  confidence intervals,  and  prediction

intervals based on the Student's t-distribution will be discussed. While these procedures do not

apply to the three  primary questions listed above concerning the existence  and location of

action supports above action level, they may be useful in comparing pollutant concentrations in

regions up-gradient and down-gradient from a possible point source. It should also be pointed

out that these  procedures are only applicable  to random samples (i.e., not to systematic grid

samples), and  great care is required in using them for  anything other than simple random
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samples.   The basic assumptions of these procedures are that  the  data in  a sample are

independent and identically distributed (with the distribution being a normal distribution) and

that the measurement error variance (particularly the between-batch error variance) is a very

small part of the total variance of the measurements in a sample survey of a region.



Confidence Intervals



       Often one wishes to estimate the concentration of measured pollutant over an action

support or over a larger subregion of a study area and to indicate the precision of the estimated

concentration. The precision may be indicated by a variance, standard deviation, coefficient of

variation, or confidence interval for the expected value (mean) H of the concentration.  Where

statistical designs involving randomization in the selection of all sample points  are employed,

the analysis of variance table (see example in Chapter 9) often provides needed information for

the calculation of these quantities and intervals.



       The confidence interval is bounded by confidence limits which represent the bounds of

the uncertainty caused  by the variability of the data in the study.  A two-tailed confidence

interval for /i based on the assumptions stated above is of the form
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       x-ts/ymi /i 
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is (
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                                    3.16 * M <, 3.70.



Prediction Intervals



       Prediction intervals (see Hahn, 1969, or Guttman et aL,  1982) are similar to confidence

intervals in appearance but are used to give an interval estimate of one future randomly chosen

sample  value.  If that one additional sample is to be taken from stratum  i,  the defining

two-tailed interval for the one future value, xtf (say), is


              X; - ts/[(l/n)+(l/bn)]* x.rf * x, + ts7[(l/n)+(l/bn)],

where Xj is the sample mean for stratum L Hence, one can say for the above example that if one

more sample were randomly taken from stratum 1 (which had sample mean 2.46), one would be

95 percent confident that the mean of the analyses of the two subsamples of that sample would

give a value xtf such that



     2.46-(2.306)(y0.3199)y[(l/2) + (1/6)] i x.,, i 2.46 + (2.306)(70.3199)y[(l/2) + (1/6)],
which is
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       One-tailed confidence and prediction intervals can be obtained using the same methods,

only leaving off the bound on one side and using the "one-tailed" heading on the t-table in

Appendix B.



Tests of Hypotheses



       Probably the most commonly used test of hypotheses  for comparison  between two

population means or the comparison of a population mean with some standard value (e.g.,

action level) is a t-test.  To compare two means, jij and /I2, using data from simple random

samples of the two populations, the following test statistic is employed:


                    t, = £

where the pooled standard deviation,

                         »p « yKOV1)'!2 + (n2-l)s22}/(n1+n2-2)]

and x j,  s?, and n. are the sample mean, sample variance, and sample size of sample i (i= 1,2).

This two-sample t-test requires one additional assumption to the ones mentioned earlier;

namely, it is assumed that the population variance is the same  for both populations sampled.

The test is of the null (no difference)  hypothesis H: Mj  = H2 versus either the two-tailed
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alternative A: /it ^  Hy  or a one-tailed alternative such as A: ^  > ny  For the two-tailed

alternative, one accepts the alternative hypothesis only if | t§ |  > t, where t is the value found in

the table of Appendix B and listed in the (1-cr) column, for two-tailed alternatives, and in the

(nj+nj-2) degrees of freedom (df) row. For the one-tail alternative, one accepts the alternative

hypothesis only if ts  >  t,  where the value t is again found as before, only now use the (1-or)

column for one-tailed tests.



       The need to use a  one-sample t-test which compares a  population mean against a

standard value may arise in determining whether the mean concentration of a pollutant in a

study area or clean-up unit of a study area exceeds a specified action level. The test statistic for

this test is


                            tc»(x-L)(yn)/s,


where  L is the action level, and n is the sample size.  One- and two-tailed tests of H: M = L

versus A: p + L or A: n >  L, are performed in the same way as described for the two-sample

tests, except now the degrees of freedom are (n-1) for the one-sample  tests.
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Example:  A preliminary  study is done in an  area  suspected of being

contaminated with polychlorinated  biphenyls (PCBs).  Sixteen soil samples

were collected from both the study area and from a background area through

the use of simple random sampling.  It was decided before sampling that a

t-test of H: /is » /ig versus A: ps >  /ig will be performed on the data and that

the probability of making a Type I error (i.e., accepting A when H is true) will

be limited to 1 percent  (a -  0.01).    Table 8 lists the concentration

measurements.



TABLES. PCB MEASUREMENTS (HYPOTHETICALDATA)
Background Area (ppb)
35.8 38.5
45.5 36.0
35.5 40.5
32.0 35.5
50.0 45.5
39.0 37.0
37.0 36.0
47.0 53.0
XB- 40.23 4s36-8825
*s - 52.61 s* - 60.2598
Study Area (ppb)
47.0 50.0
62.0 49.6
47.0 53.5
59.5 68.0
40.0 60.0
57.5 45.0
48.5 42.5
53.0 58.7
nB - 16 CVB -
n, - 16 CVS -



15.1%
14.8%
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The test statistic is calculated as follows:

       sp - /[15(36.8825 + 60.2598)/(16 + 16-2)] = 6.97

       tg  - [52.61 - 40.23]/[6.9?y(2/16)] = 5.02

The critical value for t for an a * 0.01, one- tailed t-test with 30 degrees of

freedom is found in Appendix B to be 2.457. The observed value of the test

statistic 5.02 is larger than the critical value, so it would be concluded that the

mean  concentration  for  PCB  is  larger in the  study area than  in the

background area. A one-sided 99 percent confidence interval for /J$ - /Jg is
              "s • "B > *s • *B ' MO/IS) + (1/nJ]  - 6.28 ppb.


       One might also wish to test whether the mean concentration of the

study site is above an action level of 50 ppb.  Now one uses a one-tailed, one

sample t-test of H: Hs <, 50 versus A: Hs  > 50.  Here the maximum possible

probability of making a Type I error is set  at 5 percent  (a =  0-05) for

illustrative purposes.  The test statistic takes the value



                  tc - (52.61 - 50.00)(/16)//60.2598 = 1.34.
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       The critical value found from the table in Appendix B for a one-tailed test

       with or = 0.05 and 15 degrees of freedom is 1.753.  Since the value of the test

       statistic is less than the critical value, one does  not accept the alternative

       hypothesis.  Here one must worry whether the alternative hypothesis might

       have been accepted if more samples had been taken. That is, has a Type n

       error been committed in this case for lack of sufficient information?



       In the use of one-tailed t-tests and confidence intervals such as those illustrated in the

above example, one needs to worry about the assumption of normal distribution for the data

and the equality of population variances.   While two-tailed  tests are relatively robust with

respect to these assumptions, one-tailed tests are not.  Unfortunately,  as has been pointed out

before, the underlying distribution of the population of pollutant concentrations can be quite

nonnormal and also difficult to transform to normality. Further, there is no reason to expect

the population variances  to be equal in two different regions.   To avoid this problem in

one-tailed procedures, one may prefer to employ rank tests (see Lehmann,  1975) that do not

require distribution assumptions.
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                                   CHAPTER 11

           SAMPLE DOCUMENTATION, COLLECTION AND PREPARATION


INTRODUCTION



      An important segment of a study's QA/QC plan deals with sample documentation,

collection, and preparation methods.  These aspects of the definitive study must be identified

and appropriately applied if the specific objectives of the sampling/monitoring effort are to be

met.  Improperly collected and documented samples can void the entire study.  As such, the

final protocol must provide  guidance and identify  sample collection and handling methods,

equipment requirements, sampling locations, documentation requirements, sample compositing

requirements and methods, and the depth or depths that will be sampled.



      The  authors recommend that the RPM or investigators  be able to  estimate the

components of variance or error associated with each element of  the sample collection and

preparation  methods and  procedures used from the data generated by the study.  Evidence
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from  the exploratory  study  pertinent to  this estimation  process  should be  taken  into

consideration.   It is recommended that  a minimum adequate  documentation and sample

methodology approach  be selected consistent with the objectives of the study,  the resources

available and the designated levels of precision and confidence.  It is important that criteria or

procedures  for  determining,  during and after the  fact,  whether or  not the sample

collection/preparation elements of the protocol were satisfactorily achieved.   Guidance for

selecting,  incorporating,  assessing, and interpreting sampling QA/QC data is presented in

Chapter 12.



       The recommendations and guidance presented in this chapter are general in nature.

However,  recommended detailed procedures  and methods addressing and  identifying

documentation, soil sample collection methods,  and soil sample preparation methods are

presented in a number of reports including the following  working protocols  and guidance

documents:



       Documentation  of EMSL-LV Contribution to Dallas Lead Study

       U.S. EPA EPA-600/4-84-012 1984.  Las Vegas, Nevada
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Sampling for Hazardous  Materials U.S.  EPA OERR,  Environmental Response

Team. Washington, D.C.



The Environmental Survey Manual U.S. DOE Volumes 1-4 DOE/EH-0053  1989.

Washington, D.C.



Refuge Contaminant Monitoring Operations Manual.   Soil Sampling Reference

Field Methods U.S. FWS. 1988. Prepared by USDOE/INEL/EG&G, Idaho  Falls,

Idaho.



Preparation of Soil Sampling Protocol:  Techniques and  Strategies.   U.S.  EPA

EPA-600/4-83-020 1983. Las Vegas, Nevada



National Enforcement  Investigations Center Policies and Procedures.  U.S.  EPA

NEIC EPA-330/9-78-001-R 1986. Denver, Colorado
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       Refuge Contaminant Monitoring Operations  Manual.  Documentation Guidance

       Standard Operating Procedure.   U.S.  FWS  1989.    Prepared by  USDOE/

       INEL/EG&G, Idaho Falls, Idaho.



DOCUMENTATION



       Documentation  establishes procedures and  identifies written records that must be

incorporated into the operating procedures for sampling/monitoring efforts. Document control

procedures are required for the following three reasons:



       •     Enhances and facilitates sample tracking and the interpretation of sampling and

             analytical data.



       •     Standardizes data entries for input into data management systems for efficient

             retrieval and data manipulation.



       •     Identifies and establishes the authenticity of data collected for possible remedial

             measures.
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       The first parameter  addresses the need to view  sampling  and analysis results as  a

function of data quality and data application.  Knowledge of the circumstances under which the

samples were collected, handled, preserved, transported, and analyzed will play an important

role in how analytical data are used and interpreted.



       The second parameter addresses the need for uniformity in data recording, as a number

of sampling teams may be  involved in sample collecting and data gathering.  As such,  a

consistent, standardized documentation  program is essential for  developing an effective and

efficient  data  management  system.  The third parameter addresses the potential for the

adjudication  of sampling and analysis results and  the associated role  that  evidentiary

proceedings may play in remedial measures.



       Contaminant monitoring  from  an enforcement  remedial  perspective will  involve

information gathering  procedures that  are  more restrictive  on personnel,  materials,  and

methods than procedures used for many ecological research and/or environmental surveys. As

a result, some protocols previously used for collecting, handling, documenting, and shipping

samples may fail to meet the demands required for contaminant sampling situations.
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       For EPA's contaminant sampling/monitoring efforts, record-keeping and documenting

field activities are essential elements of a thorough investigation.  A written record of all field

data, samples, observations, and events provide the following:



       •      Ensures that all essential and required information is consistently acquired and

              preserved for current use and future reference.



       •      Assures  timely,  correct,  and  complete  analysis  for  all parameters being

              requested.



       •      Satisfies quality assurance requirements.



       •      Establishes a chain-of-custody record for samples.



       •      Provides evidence in court proceedings.



       •      Provides solid basis for further sampling activities.
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       Maintaining standardized records enhances the usability of data necessary for decision

making. Using standard forms also ensures that the same types of information will be recorded

consistently. These records will document and support decisions regarding the existence and

abatement of contaminant problems.



Document Control



       Document control is a systematic procedure for ensuring that all sampling/monitoring

program documents are property identified and accounted for during program implementation

and after program completion. Document control encompasses the following:



       •      serialized documents,

       •      document inventory and assignment record, and

       •      document file repository.



       Presented in Table 9 are the program documents that are  accountable and must be

identified  and  included in the document control  procedure.   Also identified are  those
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documents that are commonly serialized.  For detailed guidance in the selection and use of

appropriate documents, see U.S. EPA (1986), U.S. DOE (1987), and U.S. FWS (1988) (1989).



       Because  of the complexity and importance of proper document control it may be

advisable to select an individual to oversee and coordinate all document control responsibilities.

The size and magnitude of the sampling effort will be a determining factor in the selection of a

document coordinator. This decision must be made on a case-by-case basis.
                     TABLE 9. ACCOUNTABLE DOCUMENTS
Document Control Identifiers and Headers                     Serialized
Sampling plan                                  Sample identification documents
Quality assurance plan                          Tags
Analytical forms                                Chain-of-custody documents
Logbooks
Field data records and forms
Shipping forms
Correspondence
Photographs, maps, drawings, etc.
Check-Out logs
Litigation documents
Final report
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       A number of documents identified in Table 9 require only the proper program identifier

title and header (e.g., photographs, correspondence). Others, such as project logbooks, chain-

of-custody forms, field data forms, and  sample identification documents,  require detailed

entries. The header,  consisting of the program identifier (title or code), Section, Revision,

Date, and page	of	should be placed on the upper right-hand corner of each page of

documents such as QA/QC plans and sampling/analytical protocols.



       Document inventory will provide document accountability to the appropriate data users

and to those who will use the data results to make decisions.  For example,  decisions and

actions taken concerning any changes  in samples/monitoring methodology or any remedial

measures will be available. All documents should be cataloged, categorized, and have a unique

program identifier that identifies the region, specific site and year sampling/monitoring activity

was conducted.



       After the sampling/monitoring program has been completed,  all documents generated

should be assembled and stored in a program file or repository.  The RPM or his/her designee
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is  responsible for ensuring that  the  collection,  assembly,  and  inventory of all  program

documents are completed.  This document file repository should have an index identifying all

included program documents and a system that identifies the disposition of and location of all

original and copied documents.  This file is considered accountable; therefore, any documents

leaving the repository must be signed out.



       The  following general guidance will  apply to  all documents  for  contaminant

sampling/monitoring program:
              Entries made in logbooks, field records and forms, sample labels and tags, and

              chain-of-custody documents should be made  only with waterproof ink and/or

              grease pencils. If lead pencils or other writing instruments are used, note the

              reason in the logbook.



              Correct errors by drawing a single line through the error and enter the correct

              information.
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       •      Initial and date all corrections. (A list of names and initials should be part of

             the written record.)



       •      Enter in  the  logbook the location and disposition of voided documents by

             recording their serial number (serialized documents)  and/or program header

             and identifier  information.



       •      Place pre-numbered (serialized), and voided documents in the program file for

             accountability.



       •      Use only bound logbooks.



Logbooks



       Logbooks  are maintained to  (1)  record,  identify  and  describe  all  pertinent

sampling/monitoring activities and (2) to record quantitative information for each sample

collected.  Included with a  contents page for easy reference, the field logbook should also
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address and describe team activities (e.g., activity log) sampling site descriptions and sample

descriptions, including field measurement data (e.g., sample log).



Field Data Records and Forms



       A  number of sampling/monitoring situations may require the collection of field data

that necessitates the use of specialized field data forms such as profile descriptions, core logs,

and field measurements (e.g., pH, temperature).  When specialized forms are used, they must

be included in the Field Logbook or, if more convenient,  bound  in a separate  Field Data

Records and Forms Logbook. If a Field Data Records and Forms Logbook is required, it must

have the  appropriate identifier and header and be  categorized by sample matrix with an

appropriate table of contents page. This logbook becomes a part of the program file and must

be filled out and handled as previously identified for all program documents.
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Sample Labels and Tags



       Sample labels and tags are required for properly identifying samples and evidence. The

data obtained from samples  collected for a sampling/monitoring activity may be used for

remedial measures. All samples must be properly labeled and tagged.



       It is recommended that physical samples be identified with a label and a tag.   Both

sample labels and sample tags must accompany physical samples to the analytical laboratory.

However, while the sample label will be disposed of with the sample, the sample tag must be

kept as a permanent record in the program files.  The sample tag should be returned to the

originator and/or the custodian of the program files as physical evidence of sample receipt and

analysis, and may later be introduced as evidence in litigation proceedings.



Chain-of-Custody



       Chain-of-Custody (COC)  is  mandatory  in all  cases that involve  litigation.

Chain-of-Custody records perform three functions:  (a) records who has custody of a sample,

(b) identifies who takes possession of a sample when it is transferred, and (c) verifies that a
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sample was constantly under custody between sample collection and laboratory analysis.



       According to the U.S. EPA's National Enforcement Investigation  Center's (NEIC)

Policies and Procedures (1986),  in-situ measurements can be considered and will constitute

evidence.   A sample collected  from a site for the determination of contaminants can be

considered as physical evidence.



       A sample is under custody if:



       •      it is in your possession,

       •      it is in your view, after being in your possession,

       •      it was in your possession and you locked it up, and

       •      it is in a designated secure area.



       To establish the integrity of samples, it is necessary to demonstrate that the samples

were maintained under custody from the time they were collected in the field to the time they

were analyzed in the laboratory.
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       The Chain-of-Custody Record form must list all transfers in the possession of samples.

(See U.S. EPA (1986), U.S. EPA (1984), U.S. DOE (1987), and U.S. FWS (1989) for guidance.)

Properly used, this piece of documentary evidence will attest that the sample was constantly

under custody between sample collection and laboratory analysis.



       While being shipped from the field to the laboratory, samples pass through the hands of

postal clerks, couriers, and others who are unidentified. The samples, however, are effectively

in a secure  area.  NEIC procedures  require that a  custody seal be affixed to  the shipping

container in such a way that, if the shipping container is properly secured and arrives at the

laboratory with the custody seal intact and with adequate documentation, the integrity of the

samples can be demonstrated.



SAMPLE COLLECTION



       Devices for collecting samples must successfully operate in conditions such as sand, silt

and clays  in rocky, dry,  and wet environments, surface area sampling requirements, depth

requirements, and must be  able to collect the required volume.   In addition, the sample

collection device should provide the most cost-efficient sample over the total sampling effort.
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U.S. EPA (1983),  U.S. EPA (1983a),  U.S. EPA (1988)  and US. FWS (1988) provide

information on available soil sampling devices and their operational requirements.  Soils are

extremely complex and will provide investigators with a multitude of sampling situations.  As a

result, no single sampling method can be recommended.  Sampling personnel will have to select

the method that will best accommodate their sampling needs and that will  satisfy the stated

program objectives.  Sampling devices must be carefully cleaned prior to and  between each

sample to avoid cross contamination.  Suggested cleaning or  decontamination procedures are

presented in U.S. DOE (1987), U.S. FWS (1989a) and in U.S. EPA (1982) and (1984).



Frequency of Sampling



       Frequency of sampling depends on program objectives, sources of pollution, pollutants

of  interest,  transport  rates,   and disappearance  rates (physical,  chemical or  biological

transformations, as well as dilution  or the determination of dispersion).  Sampling frequency

may be related to changes over time, season, or precipitation. Normally little information will

be  obtained on sampling frequency from the exploratory study,  but in those cases where

temporal changes are expected, the final study should address sampling frequency in the design
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and in the selection of sampling devices.  It is not uncommon for many definitive studies to be

conducted over a period of one year or more or through cycles of wet and dry environments.



       Rapid  changes expected  in  the concentration  of pollutants in soil are normally

associated with precipitation. Precipitation may influence the movement of chemical pollutants

downward and aids in decomposition. Sampling frequency associated with either major rainfall

events or with accumulated amounts of rainfall can often provide valuable information on

changes that are occurring.



       Monitoring studies are  often designed to measure the effects of some remedial measure

on the site.  Trends are important  in  these cases.   The  frequency of sampling should be

designed to measure changes, e.g.,  efficiency of remedial measures.   One approach used

successfully has  been  to provide intensive initial sampling early,  then decrease sampling

frequency as the levels begin to drop.   One recommended procedure  would be to sample

monthly for the first year, quarterly for the second year, semiannually for the next two to three

years, then annually thereafter.
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       Evaluation of the  trend of the data should allow the RPM  to determine when the

sampling frequency can be reduced or halted completely.  Monthly sampling may provide the

needed data for performing statistical tests and for determining the yearly variation.



       Samples collected for evaluating trends can usually be obtained on some subset of the

initial year's sampling.  The major focus is mainly on the highly contaminated and on the

immediately adjacent areas.   The investigator is primarily interested in detecting changes  in

these adjacent areas in order to provide early warning of the efficacy of remedial measures.



SAMPLE PREPARATION



       Sample preparation encompasses all physical handling of sample(s) following the actual

collection. This includes, but is not limited to the following:



       •      transfer from the collecting device,

       •      sieving/mixing procedures,

       •      drying methods and procedures,

       •      selecting and using containers,
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       •     preservation,

       •     archiving (storage), and

       •     transportation and shipment.



       It is  inappropriate to  initiate a sampling effort without first becoming familiar with

sample preparation requirements.   For example, it is not recommended to dry and sieve

samples that are collected for the determination of volatile contaminants.  Collecting samples

that cannot  be  suitably analyzed will  not yield high quality decision-making data,  thereby

compromising achievement of the sampling/monitoring objectives.



       In addition  to the protocols  and guidance documents previously identified,

recommended soil  sample preparation methods for  different  contaminant analyses  are

presented in U.S. EPA (1986a),  U.S. EPA (1989), OSU (1971), and by Peterson and Calvin

(1965).
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Sieving/Mixing



       Note:  Sieving and mixing can only be carried out on soils containing pollutants with

little or no tendency to vaporize. This requires that the techniques discussed below not be used

for volatile pollutants.



       Analytical methods that are used by the U.S. EPA to analyze soils have been validated

with a prescribed sample volume and a specified particle size.  As such, for the best analytical

results, the analyst must be  provided with a sample that is commensurate with the analytical

requirements.  The responsibility for providing the appropriate sample for analysis lies with

sampling personnel. This responsibility also includes the requirement to prepare (e.g., mix and

sieve) soil samples in a prescribed manner to provide a representative sample from the total

soil material collected.  For example, when single- or multiple-sample cores are collected for

compositing, it is recommended that the samples be prepared before they are shipped to the

analytical laboratory.



       Soil  sieving/mixing sample preparation  methods  must  satisfy  the following

requirements:
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       •      provide the specified amount of material,

       •      provide a representative aliquot of the total sample collected, and

       •      provide an adequate and appropriate sample to enable analyses for the required

              contaminants (e.g., volatiles, semivolatiles, metals).



       It is extremely rare to collect soil that does not contain non-soil components (e.g., rocks,

non-mineral material). Also, in many soils organic matter is commonly found and is an integral

part of the soil matrix.   Both the non-soil components and the organic matter may play an

important role in the interpretation of the analytical data (e.g., the non-soil components may be

a source of contamination to the soil matrix).



       The potential for errors being introduced in the sample sieving and mixing procedures is

high, especially involving discarded non-soil or non-sieved material, as well as possible physical

and/or chemical losses during any grinding or drying operation.  Decisions concerning the

non-soil fraction may be made  on the basis  of data obtained  from  an exploratory study.

Available data may indicate that significant contamination is in the discarded portion. If so, it

is recommended that the discarded portion from ten percent of the samples collected from
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areas having the highest concentrations be analyzed. An estimate can then be made of the total

amount of contamination being discarded by multiplying the measured concentration in the

discarded material by the total amount of the discarded material. Assuming that this amount is

uniformly distributed through the soil sample remaining after non-soil and non-sieved materials

have been discarded, one can then calculate an estimated value for the potential soil sample

total concentration,  if none of the contamination had been discarded.  Comparison of this

potential concentration to the actual measured concentration  will enable an estimate of the

possible error related to discarded contamination.



       If the error estimated by this process exceeds acceptable limits specified in the QA/QC

plan, it might be necessary to modify sample preparation procedures for the definitive study.

One might consider a sample sieving and mixing procedure in which the  entire collected sample

(soil and non-soil materials) is extracted in the analytical laboratory.  The analytical results

could then be reported as amounts of contaminant per gram  of mixed material. At present

there is no acceptable method for proceeding in cases such as these. One problem is the lack of

standard reference materials for determining and measuring errors in extraction efficiency.

One solution may be to try different methods of extraction and compare the results.  The final

interpretation of the data must then take into consideration these estimated errors.
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       If the error estimated by this process exceeds acceptable limits specified in the QA/QC

plan, it might be necessary to modify sample preparation procedures for the definitive study.

One might consider a sample sieving and mixing procedure in which the entire collected sample

(soil and non-soil materials) is extracted in the analytical laboratory.  The analytical results

could then be reported as amounts of contaminant per gram of mixed material.  At present

there is no acceptable method for proceeding in cases such as these. One problem is the lack of

standard reference materials for determining and measuring errors in extraction efficiency.

One solution may be to try different methods of extraction and compare the results. The final

interpretation of the data must then take into consideration these estimated errors.



Sample Containers



       The current EPA recommended container, preservation and holding time requirements

for specific contaminants is shown in Table 10. Recommended sample volumes are presented

in U.S. EPA (1983a), U.S. DOE (1987), and U.S. FWS (1989).



       It is recommended that sample containers be  obtained from a commercial source that

provides containers cleaned to EPA-approved specifications.  The cleaning procedures used
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should be EPA approved. Also, sampling personnel should check current container and sample

volume recommendations as improvements in containers,  materials used in their construction,

holding time requirements, preservation procedures, and analytical protocols are consistently

being updated and improved.



Archiving



       A number of sampling/monitoring circumstances may require the archiving or storing

of collected samples or portions of collected samples that have been submitted for analysis. For

example, the design of a monitoring program may require that a large number of samples be

collected.  If there is uncertainty as to the definitive identity of a contaminant(s) or cost of

analysis is a concern, an alternative for analyzing all of the samples collected is to select only a

small number of them for analysis.  Following the analysis and data assessment of these initial

samples, a decision to analyze additional samples  can  be made.   Additional reasons for

archiving samples is to provide a "back-up" if a sample is lost or spilled, and/or when additional

analysis is necessary for validating an unexpected or unusual (exceedingly high or  low) result.

When samples are being archived, the samples should be stored in containers and under the

preservation requirements presented on Table 10.  If samples are stored for  a period longer
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TABLE 10. SAMPLING CONTAINERS, PRESERVATION REQUIREMENTS, AND
                HOLDING TIMES FOR SOIL SAMPLES
Contaminant
Acidity
Alkalinity
Ammonia
Sulfate
Sulfide
Sulfite
Nitrate
Nitrate-Nitrite
Nitrite
Oil and Grease
Organic Carbon
Metals
Chromium VI
Mercury
Metals except above
Cyanide
Organic Compounds
Extractives
(including phthalates,
nitrosamines organo-
chlorine pesticides,
PCB's nitroaromatics,
isophorone, polynuclear
aromatic hydrocarbons,
haloethers, chlorinated
hydrocarbons and TCDD)
Extractables (phenols)



Purgables (halocarbons
and aromatics)
Container
P,G
P,G
P,G
P,G
P,G
P,G
P,G
P,G
P,G
G
P,G

P,G
P,G
P,G
P,G

G, teflon-lined
cap







G, teflon-lined
cap


G, teflon-lined
septum
Preservation
Cool, 4°C
Cool, 4°C
Cool, 4°C
Cool, 4°C
Cool, 4°C
Cool, 4°C
Cool, 4°C
Cool, 4°C
Cool, 4°C
Cool, 4°C
Cool, 4°C

Cool,4eC
Cool,40C
Cool,40C
Cool, 4°C

Cool, 4°C








Cool,40C



Cool, 4°C

Holding Time
14 days
14 days
28 days
28 days
28 days
48 hours
48 hours
28 days
48 hours
28 days
28 days

48 hours
28 days
6 months
28 days

7 days (until
extraction)
30 days (after
extraction)





7 days (until
extraction)
30 days (after
extraction)
14 days

                                                          (continued)
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                               TABLE 10. (Continued)
Contaminant
Container
Preservation     Holding Time
Purgables (acrolein and
 acrylonitrate
Orthophosphate
Pesticides
Phenols
Phosphorus
Phosphorus, total
Chlorinated organic
 compounds
Polyethylene (P)
 or Glass (G)
      G, teflon-lined
        septum
      P,G
      G, teflon-lined
        cap
      G
      G
      P,G
      G, teflon-lined
        cap
Cool, 4°C

Cool, 4°C
Cool, 4°C
Cool, 4°C
Cool, 4°C
Cool, 4°C
Cool, 4°C
 3 days

48 hours
 7 days (until
   extraction)
30 days (after
   extraction)
28 days
48 hours
28 days
 7 days (until
   extraction)
30 days (after
   extraction)
P » polyethylene
G » glass

Sample preservation should be performed immediately upon sample collection.  For composite
samples,  each aliquot should be preserved at the time of collection.  When impossible to
preserve  each aliquot, then samples may be preserved by maintaining at 4°C until compositing
and sample splitting is completed.

Samples  should be analyzed as soon as possible  after collection.  The times listed are the
maximum times that  samples may be held before analysis and still considered valid.  Samples
may be held for longer periods only if the analytical laboratory has data on file to show that the
specific types of samples under study are stable for the longer time.

For additional information see U.S. EPA (1983a).
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than the stated holding time, a decision concerning the utility of the data obtained from their

analysis must be made. This decision would have to be made by the data user on a case-by-case

basis as a function of the intended use of that particular data and should be documented as

necessary.



Sample Bank



       For  sampling studies  that  require  a large number of  samples and/or  extensive

pre-analytical sample preparation, a sample bank may be advantageous.  The sample bank is

the element that operates between the field sampling effort and the analytical laboratory.  It is

established to handle the distribution and preparation of samples for large  sampling efforts

(U.S. EPA, 1980).  However, for smaller studies the sample bank's responsibilities are often

incorporated into the responsibilities of the field sampling team or the analytical laboratory.



       The following sample bank responsibilities and procedures have been used successfully

on a number of soil monitoring studies (U.S. EPA 1982,1984,1989).
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A.     Issuing Supplies:

       (1)     The sample bank  issues,  as  required,  sample containers,  sample

              collection tags, chain-of-custody forms, and site description forms to the

              sampling teams.  Sample collection tags and chain-of-custody forms are

              normally accountable documents; the sample bank will log the forms by

              numerical lot identifying the team and/or the individual responsible for

              the temporary custody of these documents.

       (2)     The sample bank may be  required to store  sampling equipment in a

              suitable environment.   If sampling equipment is stored at the sample

              bank,  issuing this equipment to the sampling teams as required will be

              necessary.



B.     Record Keeping

       (1)     Custodian for all records pertaining to the sampling, sample preparation

              as required, and shipment of soil samples to analytical laboratories.

       (2)     Responsibility for record filing and  storing, for storing and preparation

              of soil samples, and for dispensing containers, sampling equipment and

              all custody documents  such as chain-of-custody  forms  and sample
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                    collection and analytical tags, as required.

             (3)    Responsibility for updating and maintaining  the project's master log

                    book, auditing the records as required, generating QC samples (e.g.,

                    sample bank blanks, splits, etc.), accepting QA/QC samples for inclusion

                    into the analytical scheme, and for scheduling the collection of field

                    sample blanks.

             (4)    Responsibility for completing, as required, analysis data reporting forms

                    and for assuring that all chain-of custody requirements pertaining to all

                    field sampling, shipping and sample bank operations are adhered to.

             (5)    All unused accountable documents  as shown in  Table 10  must be

                    returned to the sample bank on a daily basis.  However, depending upon

                    circumstances,  such as a  sampling team's schedule  and  route,

                    accountable documents  may be retained by the sampling team  leader.

                    The sample bank supervisor, however, must be aware of the situation.



       Preparation of soil samples for analysis normally requires sample bank personnel to dry,

sieve, mix and aliquot samples appropriately.  The preparation procedures selected must be
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identified in the protocol and adequately address the contaminant(s) to be measured and the

analytical requirements.



QUALITY ASSURANCE ASPECTS



       QA/QC procedures of the sample documentation/collection effort must identify and

determine the magnitude of errors associated with characterizing soil contamination introduced

through the sample collection effort.  Audits (Chapter 13) are an effective tool for insuring that

sampling is being done as specified.  Factors most likely to influence the magnitude of the

sample collection error are collection and preparation methods, and  frequency of sampling.

Perhaps the most important of these are preparation methods and frequency of sampling.



       The tools and equipment used for collecting and preparing soil  samples themselves are

not likely to be sources of error. Errors will most likely occur in the inconsistent use of these

devices.  Proper replication, decontamination and  appropriate QC sample selection, analysis,

and assessment will insure that the precision of the procedure(s) meets the QA/QC objectives

and thence the DQOs.
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                                   CHAPTER 12

                ANALYSIS AND INTERPRETATION OF QA/QC DATA

INTRODUCTION



       One goal in the analysis and interpretation of data is to show how all aspects of QA/QC

for a soil monitoring study combine to give an overall level of precision and confidence for the

data resulting  from the study.  Another goal may be  to determine whether all QA/QC

procedures used were necessary and adequate and should definitely be incorporated into future

studies of the same type. This entire evaluation must be  closely linked to the objectives,  and

specifically, to the data quality objectives of the study. In summary, the important questions to

be answered are: "What is the quality of the data (maximum accuracy attainable)?" and "Could

the same objective have been achieved through an improved QA/QC design which may have

required fewer resources?"
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PRESENTATION OF DATA SUMMARIES



       It is desirable to provide summarized tables of validated QA/QC data in the final

report.  For example, QA/QC data validation procedures used in a number of soil sampling

studies reported by Brown and Black (1983) included validation of sample data sets by checking

and  assessing  the  accompanying QA/QC data.   The criteria  for QA/QC samples and

procedures used to validate all data included:
Samples and Procedures                   Example Criteria
1.      Reagent Blanks*            Concentrations had to be less than
                                 0.25
2.     Calibration Check*         Recovery must be between 95% and 105%
        Standards                of the known value for either the first
                                 analysis or the first re-check analysis.

3.     Laboratory Control*        Recovery must be between 90% and 110%
        Standards                of the known value for either the first
                                 analysis or the first re-check analysis.
* Applies to analysis of soils for lead
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       One of the studies discussed by Brown and Black (1983) involved lead-contaminated
soils. The results of the QC analyses for this soil monitoring study were presented as follows:
QC Sample
Calibration Check Standard
Laboratory Control Standard
Field Blank (/ig ml'1)
Sample Bank Blank (/ig ml"1)
Reagent Blank (jig ml"1)
Re-extraction Analysis
Total Recoverable
SpUt Extract (CV)*
Spiked Extract
Spiked Sample
Duplicate Aliquot (CV)
Duplicate Sample (CV)
Triplicate Analysis (CV)
No.
150
147
76
77
148
17
144
147
147
147
134
129
220
Mean
101.5%
101.2%
<0.25
<0.2S
<0.25
1.7%
99.8%
0.0089
99.4%
100.4%
0.053
0.189
0.144
s
2.6%
4.1%


1.4%
8.0%
0.0079
5.0%
5.1%
0.047
0.168
0.128
•CV
       Mean
       From data summarized in this fashion, it is possible to determine the adequacy of the
QAPP in insuring the achievement of the assigned DQOs.
       It is required that the QA/QC plan document and insure that all data collected, whether
used for research or for monitoring purposes, be scientifically valid, defensible and of known
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precision and accuracy.  The described presentation of QC data, though designed for analysis of

lead in soil, can be used as a guide  for other sampling and data analysis protocols and/or

QA/QC plans.



       Presentation of QA/QC data allows readers to verify conclusions  drawn as to the

reliability of the data. Such an approach also contributes to the building of a body of QA/QC

and  monitoring  experimental  data in the literature  which  allow comparisons  to  be  made

between and among studies.  Procedures used to validate the individual data points should be

presented,  and where some points are discarded, arguments should be presented to support

these decisions.



PRESENTATION OF RESULTS AND CONCLUSIONS



       Special emphasis should be placed on how overall levels of precision and confidence

were derived from the data. Great care must be exercised to insure that, in determining results

and conclusions,  assumptions are not made which were not part of the study design and which

cannot be tested by data derived from the study.  If portions of the study results are ambiguous

and supportable conclusions cannot be drawn with regard to the total reliability of the  data, that
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situation must be clearly stated.  In that event it is desirable to include recommendations for

conducting an improved study in such a way as to clarify the observed ambiguities.



QUALITY ASSURANCE ASPECTS



       The adequacy of all aspects of the QA/QC plan should be examined in detail with

emphasis on defining an appropriate minimum adequate plan for future studies.  Some aspects

of the plan actually used may have been too  restrictive, while others  may not have been

restrictive enough.  Appropriate analyses and interpretation of the data should identify the

actual situation.



       Future soil monitoring studies should have checks and balances built into the QA/QC

plan which will identify early in the study whether the plan is adequate and, if necessary, allow

for corrective action to be taken before the study continues.   This is one  of the  major

advantages of conducting an exploratory study along the lines outlined in this report. If there

are problems with the QA/QC plan, they will often be identified in the exploratory study and be

corrected before major resources are expended.
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       There is insufficient knowledge dealing with  soil monitoring studies to state with

confidence which components of the QA/QC plan will  be generally applicable to all soil

monitoring studies and which components should vary depending on site-specific factors.  As

experience is gained, it may be possible to provide more adequate guidance on this subject.  In

the meantime, it is recommended that the best approach is to assume that important factors of

QA/QC plans are site-specific, and to conduct an appropriate exploratory study at each new

study site to verify that various aspects of the QA/QC plan are adequate to meet program

objectives prior  to proceeding with the final definitive study.
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                                    CHAPTER 13



                          SYSTEM AUDITS AND TRAINING



INTRODUCTION



       An adequate soil sampling quality assurance program ensures that the quality of the

final product meets required standards.  Audits are an integral part of the quality assurance

process and  are vital for assuring that program procedures are being implemented.  They are

performed to document the implementation of the quality assurance program plan, quality

assurance project plan and/or associated operational protocols.



       Three types of audits are commonly used to determine  adequacy of the analytical

measurement system,  adequacy of the  data collection system,  completeness of the

documentation of data collection activities, and document if required data collection  and data

quality objectives are being met.  These audits are commonly referred to as System Audits,

Performance Audits, and Data Quality Audits.
              System Audits are qualitative on-site field audits that evaluate the technical
              aspects of field operations (e.g., sampling methods) against the requirements of
              approved QA plans and protocols.  System audit reports note problems and
              recommend or allow corrective  actions to be taken to protect the validity of
              collected data.
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       •      Data Quality Audits are evaluations of the documentation associated with data
              quality indicators of measurement data to verify that the generated data are of
              known and documented quality.  This is an important part of the validation of
              data  packages showing that the methods and Standard Operating Procedures
              (SOPs) designated in the QA plans were followed and that the resulting data set
              is a functional part of satisfying the established DQOs.  The results are vital to
              decisions regarding the legal defensibility of the data should it be challenged in
              litigation.

       •      Performance Audits are generally based  on Performance  Evaluation  (PE)
              samples.  Samples having known concentrations may be tested as  unknowns in
              the laboratory or  a sample  may  be analyzed for the presence of certain
              compounds.  Performance audits are used to determine objectively whether an
              analytical measurement system is operating within established control limits at
              the time of the audit.  The performance of personnel and instrumentation are
              tested by the degree of accuracy obtained.


       Standard  Operating Procedures to  assist auditors in  addressing  critical program

elements  and preparing for on-site audits  are  presented in  U.S.  EPA (1985).   The

recommended initial phase for conducting an audit is the preparation of a program specific

checklist.  Examples of audit checklists and laboratory evaluations are presented  in U.S. EPA

(1984a, b, 1989), and for numerous sampling effects conducted for the environmental Survey

Program (U.S. DOE 1987).  A discussion with the RPM concerning the current  status  of the

project and the identity of any problems encountered is suggested before conducting on-site

field audits.
       Audits,  in  most  part,  are conducted by  appropriate elements  of  agencies or

organizations having cognizance over a monitoring project. However, audits can be conducted

by independent or third party organizations.  The frequency of auditing should be determined
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by the RPM or project officer.  Juran et al., (1979), states that, "the activities subject to audit
should include any that affect quality regardless of the internal organizational location." For
illustrative purposes, important factors that are addressed in a systems audit will be discussed.
Definitive procedures for conducting audits of analytical measurement systems are presented in
(U.S. EPA, 1984a, 1989).

       Specifically system audits:
       •      verify that  sampling  methodology is being performed in  accordance with
              program requirements,
       •      check on the use of appropriate field QA/QC measures,
       •      check methods  of sample handling,  i.e.,  packaging,  labeling,  preserving,
              transporting, and archiving in accordance with program requirements,
       •      check program documentation,  i.e., records (site description, chain-of-custody
              collection and analytical tags, field and sample bank log books and field work
              sheets),
       •      recommend corrective action if a problem is identified,
       •      assess personnel experience and qualifications if required,
       •      follow-up on any corrective action previously mandated,
       •      provide on-site debriefings for sampling team and sample bank personnel, and
       •      provide a written evaluation of the sampling and sample bank program.
       Components of a systems  audit may  include  sample bank operations  and field
operations.
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SAMPLE BANK AUDIT



       The primary objective is to determine the status of all Sample Bank documentation and

archived samples.  Emphasis is placed on:


       •      verifying  that the documentation is in order and  sufficient to establish  the
              disposition of any sample collected,

       •      determining any discrepancies that currently exist and initiating  corrective
              action as appropriate,

       •      verifying  that the recording and documentation of QA/QC measures (blanks,
              duplicate spikes, blinds) is in accordance with the QA/QC plan, and

       •      establishing procedures for final  disposition  and  mechanics of transfer of all
              Sample Bank holdings upon termination of the operation.


An initial step is to inventory the Sample Bank records and archived samples. The records that

must be inspected are:
       •      Chain-of-custody forms, including
                     Field forms and
                     Analysis forms;

       •      Sample tags, includin
                     Field tags am
                     Analysis tags;

       •      Analysis forms, including
                     Individual samples and
                     Batch sheets;

       •      Shipment forms;
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       •      Logbooks, including
                    Soils and
                    Daily log.

The operational procedures inspected include:

       •      Preparation Procedures (sample bank or analytical laboratory),
                    Preservation,
                    Drying (if used),
                    Sieving,
                    Mixing,
                    Packaging, and
                    Shipping.

       •      Housekeeping,
                    Safety,
                    Decontamination, and
                    Evaluation of Swipe Samples;

       •      Security,
                    Forms (documents),
                    Samples; and

       •      Storage,
                    Sampling equipment, and
                    Archived samples (when appropriate).


       Check that required documentation has been maintained in an orderly fashion, that

each of the recorded items is properly categorized, and cross-checking can be easily performed.

In addition, ensure that data recording conforms to approved documentation procedures.
       Check archived samples. Verify that appropriate samples exist for each entry in the

logbook. Review sample bank logbooks for complete sample information.  In addition, checks

for the identification and documentation of split and duplicate samples, and field and Sample
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Bank rinsate samples must be performed.  Detailed sample bank procedures are presented in

U.S. EPA (1982,1984, and 1989).



FIELD AUDITS



       The primary objective is to determine the status of sampling operations. Emphasis is

placed on:


       •      verifying that operational aspects and procedures are in accordance with the
              protocols and QA/QC plan,

       •      verifying the collection of all samples including duplicates, rinsates, and blanks,

       •      verifying that documentation is in order and sufficient to establish the collection
              location of any sample collected,

       •      determining discrepancies  that exist  and initiating  corrective action as
              appropriate, and

       •      collecting independent samples.

       Records inspected include:

       a.     chain-of-custody forms,
       b.     sample tags,
       c.     site description forms, and
       d.     log books.

       The operational procedures inspected include:

       •      sampling procedures,

                     equipment,
                     techniques,
                     decontamination,
                     collection of duplicate and field blank samples,


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                     security,
                     sample storage and transportation,
                     containers
                     contaminated waste storage and disposal, and
                     site Description Form entries.
TRAINING
       The project officer is responsible for determining that all members of his team have
adequate  training and  experience  to cany  out satisfactorily their assigned missions and
functions. Until a field sampling team has worked together long enough for the project leader
to have verified this, it is good practice, in addition to any classroom training or experience, to
conduct comprehensive briefing sessions for all involved parties.  During these sessions,  all
aspects of the sampling protocol, including the QA/QC plan, are presented and discussed in
detail.  Sufficient field  training exercises should follow the briefing sessions until each team
member can demonstrate successfully that he can perform his job well and without delay.

       In summary, the sampling effort must include classroom and field training programs
that provide detailed instruction and practical experience to personnel in sample collection
techniques and procedures, labeling, preservation, documentation, transport, and sample bank
operational procedures.  Also, any specialized training, such as field measurement procedures
and documentation, should be completed  by  all personnel prior to their involvement in the
conduction of any audits.
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                                     GLOSSARY
                                                                              Glossary
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Absorption
The penetration of a substance into or through another.
Accuracy
Measures the bias in a measurement system; it is difficult to measure for
the entire data collection activity.  Sources of error are the sampling
process,  field contamination,  preservation,  handling,  sample matrix,
sample preparation, and analysis techniques.  Sampling accuracy may be
assessed by evaluating the results of field/trip blanks, analytical accuracy
may be assessed through use of known and unknown QC samples and
matrix spikes.
Anion
A negatively charged ion.
Background Level    Amount of pollutants present in the ambient soil due to natural sources.
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Bulk density         The mass of dry soil per unit bulk volume, determined before drying to a
                    constant weight at 105°C.
Calibration Check
  Standard          A standard material to check instrument calibration.
Cation
A positively charged ion.
Cation-exchange
The total of exchangeable cations that a soil can absorb, expressed either
in milliequivalents per gram or in milliequivalents per 100 grams of soil.
Comparability
A qualitative parameter expressing the confidence with which one data
set can be compared with another.  Sample data should be comparable
with other measurement data for similar samples and sample conditions.
This goal is achieved through using standard techniques to collect and
analyze  representative samples and  reporting analytical  results  in
appropriate units.    Comparability  is limited to the other PARCC
parameters because only when precision and accuracy are known can
data sets be compared with confidence.
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Completeness       Defined as the percentage of measurements made which are judged to

                    be valid measurements.  The completeness goal is essentially the same

                    for all data uses:  that a sufficient amount of valid data be generated. It

                    is important that critical samples  are  identified and plans made to

                    achieve valid data for them.



Data Quality

  Objectives (DQOs) Qualitative and quantitative statements which specify the quality of the

                    data  required to support Agency decisions during remedial response

                    activities. DQOs are determined based on the end use of the data to be

                    collected.



Duplicate Sample    An additional sample  taken  near the  field sample co-located to

                    determine total within-batch measurement error variance.

External Laboratory

 Audit Sample      A sample of well-characterized soil that is sent directly to the laboratory

                    for analysis.  The analyte concentrations are unknown to the laboratory.

                    This  type of sample is used to estimate laboratory bias and laboratory
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                     batch to batch variability. It may also be used for external quality control

                     of the laboratory.



Field Audit Sample   A sample of well-characterized soil that is taken into the field with the

                     sampling crew, sent through the sample bank to the laboratory with the

                     field samples to detect bias in the entire measurement process and to

                     determine batch-to-batch variability.
Field Blank
A sample container filled with distilled, deionized water, exposed during

sampling and then analyzed to  detect accidental  or incidental

contamination.
Field Rinsate
A blank (last rinse using distilled deionized water)  passed over the

sampling apparatus after cleaning, to check for residual contamination.
Heavy Metals
Metals having a specific gravity of 5.0 or over.
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Internal Laboratory
 Audit Sample       A sample  of well-characterized soil whose analyte concentrations are
                    known  to  the  laboratory to be used for internal laboratory quality
                    control.

Laboratory Control
  Standard          A sample of a soil standard carried through the analytical procedure to
                    determine overall method bias.
Matrix
The predominant material  of which the  sample to be analyzed is
composed.
PARCC
Precision, accuracy, representativeness, completeness, and comparability
parameters.
Precision
Measures the reproducibility of measurements under a given set  of
conditions. Specifically, it is a quantitative measure of the variability of a
group of measurements compared to their average value.  Precision is
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                    usually stated in terms of standard deviation, but other estimates such as

                    the  coefficient of variation (relative  standard deviation),   range

                    (maximum  value  minus minimum value),  and relative range are

                    common.
Reagent Blank
A DDI  water  sample  analyzed as  a routine  check  for  reagent

contamination.
Re-extraction
A re-extraction of the residue from the first extraction to  determine

extraction efficiency.
Remedial Project

  Manager (RPM)    Manages remedial activities at assigned regional sites.  Accountable for

                     the technical quality, schedule, and cost of work.
Representativess
Expresses the degree to  which sample data  accurately and precisely

represent a characteristic of a population,  parameter  variations at a

sampling point, or an environmental condition. Representativeness is a
                                          218

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                                                                                Glossary
                                                                              Revision 1
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                                                                              Page 7 of 9
                     qualitative parameter which is most concerned with the proper design of

                     the sampling program.  The representativeness criterion is best satisfied

                     by making certain that sampling locations are selected properly and a

                     sufficient number of samples are collected.



Sample Bank Rinsate A sample (last rinse using distilled, deionized water) passed through the

                     sample  preparation apparatus,  after  cleaning, to check for residual

                     contamination.
Semivolatiles
A group of organic compounds consisting of base/neutrals,  acids,  and

pesticides that are identified in and analyzed by Method 625  in 40 CRF

Part 136.
Soil classification     The systematic arrangement of soils into groups or categories on the

                     basis of their characteristics.
Soil Profile
A vertical section of the soil from the surface through all its horizons,

including C horizons.
                                           219

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                                                                                Glossary
                                                                              Revision 1
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Spiked Extract
A separate aliquot of extract that is spiked to check for extract matrix
effects on the recovery of known added analytes.
Spiked Sample
A separate aliquot of a soil sample spiked with an appropriate standard
reference material to  check for  soil and  extract matrix  effects on
recovery.
Split Extract
An additional aliquot of the extract which is analyzed to check injection
and instrument reproducibility.
Total Recoverable    A second aliquot of a sample digested by a more rigorous method to
                     check the efficacy of the protocol method.
Triplicate Samples
  (Splits)
The  prepared sample is split into three  portions  to  provide blind
duplicates for the analytical laboratory and a third replicate for the
referee laboratory to determine interlaboratory precision.
                                           220

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                                                                               Glossary
                                                                              Revision 1
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Volatile              Solids or liquids which are relatively unstable at standard temperature

                     and pressure and undergo spontaneous phase change to a gaseous state.
                                           221

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                                                                         References
                                                                         Revision 1
                                                                          03/01/89
                                                                         Page Iof4
                                  REFERENCES

1.     Bauer, E.L. A Statistical Manual for Chemists. Academic Press.  New York, NY.  193
      pp. 1971.

2.     Beyer, W.  Handbook of Tables for Probability and Statistics (Second Edition). The
      Chemical Rubber Co. Cleveland, OH.  1968.

3.     Borgman,  L.E., and W.F. Quimby.  Sampling for Tests of Hypothesis When Data are
      Correlated in Space and Time.  In:  Principles of Environmental Sampling, L.H. Keith,
      ed., ACS Professional Reference Book, American Chemical Society, Washington, D.C.
      pp. 25-43.  1988.

4.     Box, G.E.P., and D.R.  Cox.  The Analysis of Transformations.  Journal of the Royal
      Statistical Society, Series B. Vol. 26 (2):211-243.  1964.

5.     Broms, Bengt B.   Soil Sampling in Europe:  State-of-the-Art,   Journal of the
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5.     Brown, K.W., and S.C. Black.  Quality Assurance and Quality Control Data Validation
      Procedures used for the Love  Canal and Dallas Lead Soil Monitoring Programs.
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7.     BufGngton,  J.P.  Developing Recommendations to Improve Quality Assurance for
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8.     Cochran, W.G. Sampling Techniques (3rd. Ed.). John Wiley & Sons. New York, NY.
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9.     Davis, J.C.  Statistics and Data Analysis in Geology. John Wiley A Sons. New York,
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10.    Gilbert,  R.O.   Statistical Methods for Environmental  Pollution Monitoring.  Van
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11.    Gulezian,  R.C. Statistics for Decision Making.  W.B. Saunders Co.  Philadelphia, PA.
      665pp. 1979.

12.    Guttman,  I., S.S. Wilks, and J.S. Hunter. Introductory Engineering Statistics (3rd Ed.).
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13.    Gy,  P.M.   Sampling Paniculate  Materials, Theory and  Practice.  Elsevier Scientific
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14.    Hansen, M.H., W.N. Hurwitz, and W.G. Madow. Sample Survey Methods and Theory,
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                                        222

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15.     Hoaglin, D.C., F. Mosteller, and J.W. Tukey.  Understanding Robust and Exploratory
       Data Analysis. John Wiley & Sons. New York, NY. 447pp. 1983.

16.     Juran, J.M., P.M. Gryna, Jr. and R.S. Bingham, Jr., eds.   Quality Control Handbook,
       Third Edition, McGraw Hill. 1979.

17.     Lehmann, E1L.  Nonparametrics: Statistical Methods Based on Ranks.  Holden-Day
       Inc. San Francisco, CA. 457 pp.  1975.

18.     Mason,  BJ.   Preparation of Soil Sampling Protocols:   Techniques  and Strategies.
       EPA-600/4-83-020.    Environmental Monitoring Systems Laboratory.    U.S.
       Environmental Protection Agency. Las Vegas, NV. 102 pp. 1983.

19.     Natrella, M.G.   Experimental Statistics.   NBS  Handbook 91.   National Bureau of
       Standards.  U.S. Government Printing Office. Washington, D.C. 1963.

20.     Oregon State University. Methods of Soil Analysis Used in Soil Testing Laboratory at
       Oregon State University. Special Report 321. Corvallis, OR.  1971.

21.     Peterson, R.G. and L.D. Calvin.  Sampling.  In: Methods of Soil Analysis.  Part 1,
       Physical and  Mineralogical Properties,  Including  Statistics of Measurement  and
       Sampling.  CA. Black, et al., ed. American Society of Agronomy, Madison, WI. pp.
       54-71. 1965.

22.     Plumb, Russel H., Jr. Procedures for Handling and Chemical Analysis of Sediment and
       Water Samples.  EPA-48/05-5720-10, U.S. Environmental Protection Agency/Corps of
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       ML 1981.

23.     Rohlf, FJ. and R.R. Sokal.  Statistical Tables. W.H. Freeman and Co., San Francisco,
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24.     Snedecor, G.W. and W.G.  Cochran. Statistical Methods. The Iowa State University
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25.     Soil Survey Staff.   Soil Taxonomy.  Agricultrual Handbook 436.  Soil  Conservation
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26.     Starks, TJi, and J.H. Fang.   On the Estimation of  the  Generalized Covariance
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27.     Starks, T.H.  Determination of Support in Soil Sampling.   Mathematical Geology
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28.     Starks, T.H., K.W. Brown, and N. Fisher.  Preliminary Monitoring Design for Metal
       Pollution in Palmerton,  Pennsylvania.    In:   Quality  Control in  Remedial Site
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                                         223

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                                                                         References
                                                                         Revision 1
                                                                          03/01/89
                                                                         Page 3 of 4


       C.L. Peckert, ed.  American Society for Testing and Materials.  Philadelphia, PA.  pp.
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29.     Starks, T.H., A.R. Sparks, and K.W. Brown.  Geostatistical Analysis of Palmerton Soil
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30.     U.S.  Department of Energy.   The Environmental Survey Manual.   DOE/EH-0053.
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31.     U.S. Environmental Protection Agency. Quality Assurance Plan Love Canal Study.  LC
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32.     U.S.  Environmental  Protection Agency.   Environmental  Monitoring at Love Canal.
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33.     U.S.  Environmental Protection Agency.   Preparation of Soil Sampling Protocols:
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34.     U.S. Environmental Protection Agency. Characterization of Hazardous Waste Sites-A
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35.     U.S. Environmental Protection Agency. Documentation of EMSL-LV Contribution to
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36.     U.S. Environmental Progection Agency. Documentation of EMSL-LV Contribution to
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       Laboratory, Las Vegas, NV. 1984b.

37.     U.S.  Environmental  Protection Agency.   Standard  Operating  Procedures for
       Conducting  Sampling  and  Sample Bank Audits.   EPA  600/4-85-003.    U.S.
       Environmental Protection Agency. Las Vegas, NV.  1985.

38.     U.S.  Environmental Protection Agency.  Soil Homogenization. U.S. EPA, Las Vegas,
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39.     U.S.  Environmental Protection  Agency.   Interim Guidance on Preparing Revised
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40.     U.S.  Environmental Protection  Agency.   Data Quality Objectives  for  Remedial
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41.     U.S.  Environmental Protection  Agency.   Data Quality Objectives  for  Remedial
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                                         224

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                                                                         References
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                                                                         Page 4 of 4


42.     U.S. Environmental Protection Agency.  ORD Implementation of Quality Assurance.
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44.     U.S. Environmental Protection Agency.  National Enforcement Investigation Center
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45.     U.S.  Environmental Protection Agency.   The RPM Primer.   EPA-540/G-87/005.
       September 1987. U.S. Environmental Protection Agency, Washington, D.C. 1987f.

46.     U.S.   Environmental Protection Agency.    Sampling  for Hazardous Materials.
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48.     U.S. Environmental Protection Agency.  Documentation of EMSL-LV Contribution to
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49.     U.S.  Fish and Wildlife  Service.   Soil Sampling Reference  Field Methods.   Refuge
       Contaminant Monitoring Operations Manual  Prepared by USDOE/INEL/EG&G,
       Idaho Falls, Idaho. In review. 1988.

SO.     U.S.   Fish and Wildlife  Service.   Documentation Guidance  Standard Operating
       Procedures.   Refuge Contaminant Monitoring Operations Manual.   Prepared by
       USDOE/INEL/EG&G, Idaho Falls,  Idaho. In review. 1989a.

51.     U.S. Fish and Wildlife Service.  Decontamination Reference Field Methods.   Refuge
       Contaminant Monitoring Operations Manual.  Prepared by USDOE/INEL/EG&G,
       Idaho Falls, Idaho. In review. 1989b.

52.     Wernimont, G.  Use of Control Charts in the Analytical  Laboratory.  Industrial and
       Engineering Chemistry - Analytical Edition. Vol. 18 (10):587-592.  1946.

53.     Westat, Inc.  Statistical Methods for Evaluating the Attainment of Superfund Cleanup
       Standards. VoL l:Soils and Solid Media.  Final Draft. Statistical Policy Branch.  U.S.
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       pp.  1988.

                                        225

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                                                                       Appendix A
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                                                                       Page 1 of 21
                                   APPENDIX A



                    APPLICATION OF SOIL MONITORING DATA

                 TO AN EXPOSURE AND RISK ASSESSMENT STUDY



      One of the possible purposes for soil monitoring is to provide  data for input into

exposure and risk assessment studies.  The risk assessment study conducted by the Centers for

Disease  Control (CDC) to estimate an allowable concentration of 2,3,7,8-tetrachlorodibenzo-

dioxin (TCDD) in residential soil provides an instructive example.  Prior to presenting  the

example, however, a brief introduction to the general subject of risk assessment will be given.



      Risk assessment as defined by the World Health Organization (WHO) is composed of

three different elements:
                                        A-l

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                                                                            Appendix A
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       •      risk identification,
       •      risk estimation, and
       •      risk evaluation or management.

Risk identification involves the accumulation of sufficient evidence to warrant identifying the
presence of a specific pollutant in the environment, at a defined concentration and averaging
time,  as possibly  being an unacceptable risk  to  man or the environment.  A formal risk
identification on the basis of a qualitative value judgement requires further study to determine
whether the risk is or is not acceptable.

       Risk estimation is the process whereby a risk which has been identified is quantified in
terms of developing estimates of the numbers of people, for example, who would suffer adverse
health effects  as a result of exposure to defined levels of the pollutant(s) of concern.   Risk
estimation requires the availability  of both applicable exposure-response relationships for the
adverse effect of concern in the exposed population and existing exposure distributions in the
appropriate population(s).   By comparing exposure  distributions  to exposure-response
relationships, it a possible to predict the expected number of adverse effects in the exposed
population(s).
                                          A-2

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                                                                            Appendix A
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       Risk evaluation (or management) is the process whereby responsible public officials

come to a value judgment decision as to what risk is acceptable. Social, economic, political, and

health considerations generally are involved in this important decision.  If the present risk as

estimated in the previous step is deemed unacceptable, it is imperative that prompt action be

initiated to reduce the risk to acceptable levels.



       The risk assessment process is often easier to define than it is to perform. For example,

the  risk  estimation process  assumes  the availability of  applicable  exposure-response

relationships.  Let us briefly examine how such relationships are developed. Figure A-l depicts

the elements of toxicologic studies designed to assess adverse effects related to exposure to

environmental pollutants.    Such  studies  are usually the basis  for  exposure-response

relationships in humans.  Note that there are many different possible testing systems, there are

several possible exposure routes, the form and levels of pollutant may vary over wide limits, and

there is almost an unending list of possible adverse effect end points.



       Studies where different combinations  of the toxicologic  study elements  have been

examined comprehensively exist for only a very small number of substances.  The situation is

additionally complicated by the fact that results from experimental animals,  usually at high
                                          A-3

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                                                                           Appendix A
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                                                                           Page 4 of 21



exposures,  must be extrapolated to humans,  usually at much lower  exposures.   Also,

combination effects resulting from the presence of more than one pollutant at a time in the real

world are usually not assessed.



       Due to variations in sensitivity,  not all humans respond the same way to  the same

exposures.  Figure A-2 shows a generalized spectrum of human responses to an environmental

pollutant.  Generally in the United States, an increased body burden and physiological or

biochemical changes of uncertain significance are not considered to be adverse health effects.



       Figure A-3 shows the possible routes of entry of pollutants to man  from the generating

source(s).  In the  development of exposure distributions to man, significant exposures via all

routes of entry must be assessed.  When exposures via more than one route are important, it is

necessary to estimate the total exposure by appropriately summing all contributions.



       Figure A-4 presents a total exposure model showing how media measurements (shown

on the top line in the slide) may be converted to exposures. At the present time, the ability to

quantify human exposures via skin absorption for many pollutants is not considered adequate.

More research is needed here.
                                          A-4

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                                                                            Appendix A
                                                                             Revision 1
                                                                              03/01/89
                                                                            Page 7 of 21
       Figure A-5 shows the relationship of exposure to risk estimation.  Note that it may be

possible to infer some information about total exposure from  the effects of increased body

burden, or physiological and biochemical changes of uncertain significance.



       Figure A-6 gives three hypothetical general classes of exposure-response relationships.

Curve I shows the situation where there is no threshold of exposure which must be exceeded

prior to observation of some effects.  Many feel that this is the appropriate class to use for

cancer-causing pollutants. Curve n shows that a threshold of exposure must be exceeded prior

to observation of effects.  Curve HI depicts a situation where there are some effects at zero

exposure. This shows that the pollutant of concern is not the only cause or contributor to the

adverse effect being measured.   Generally,  experimental points used to define exposure-

response relationships are for high exposures, and the shape and location of the curve near zero

exposure is unknown. Note that if the curve is really of Class n, but is assumed to be of Class I,

extrapolation  of an  experimental  point at B through zero would seriously overestimate the

effects of low exposures.
                                           A-7

-------
                                     I   Soil  1
                                   Ground Water
Figure A-3. Possible exposure pathways from a source of environmental pollution to man.
                                       A-8

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-------
                                                                           Appendix A
                                                                            Revision 1
                                                                             03/01/89
                                                                          Page 12 of 21
       Figure A-7 depicts exposure monitoring elements requiring quality assurance (QA).

Note that one must have a QA plan for many more factors than analytical techniques.



       Figure A-8 shows a hypothetical example of an exposure distribution.  In using an

exposure distribution together with an exposure-response relationship to derive a quantitative

risk estimate,  one must decide to what population  the  exposure distribution should be

applicable.  Also whether the important exposure is the mean or one of the top percentiles must

be decided.



ASSESSING DIOXIN EXPOSURE



       In the early 1970s, a waste oil dealer in Missouri  disposed of waste materials containing

TCDD by  mixing them with  salvage  oil and spraying  the mixture on dirt roads and riding

arenas.  Measurements in soil gave values ranging from less than 1 to greater than 1,000 parts

per billion (ppb) of TCDD. The Centers for Disease Control (CDC) was assigned the task of

assessing possible health implications and, if feasible, recommending a soil concentration value

for TCDD which should not be exceeded.   The reference describing the results of CDC's

deliberations is given below.
                                         A-12

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                                                                          Appendix A
                                                                            Revision 1
                                                                             03/01/89
                                                                         Page 15 of 21
       Kimbrough,  R.D.,  H.  Falk,  P.  Stehr,  and  G.  Fries.   Health Implications  of

2,3,7,8-Tetrachlorodibenzodioxin (TCDD) Contamination of Residential Soil. Jour, of Toxicol.

and Environ, fflth, 1984.



       The following were identified as the most important factors influencing human exposure

(dose):



•      concentrations of environmental contamination,

•      location of and access to contaminated areas,

•      type of activities in contaminated areas,

•      duration of exposure, and

•      specific exposure mechanisms.



       Figure A-9 shows the mathematical equation derived to calculate the total lifetime dose

to TCDD.  Note that dose is used rather than exposure.  Exposure via a specific route may be

converted to dose via the same route by multiplying the exposure by the percent absorbed. The

use of exposure is more conservative since it is implicitly assumed that the absorption percent is

100.  As an  example, exposure to skin is the amount of pollutant in contact with the skin,

whereas dose is the amount which is absorbed through the skin.
                                         A-15

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                                      A-16

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                                                                          Appendix A
                                                                           Revision 1
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                                                                         Page 17 of 21
       Note that only three exposure routes were considered: dermal absorption through direct
contact with the soil, ingestion of soil, and the inhalation of dust to which TCDD was attached.
Possible exposures via inhalation of vapors or ingestion of food or water containing TCDD
were not included.  Probably the most serious omission is the food exposure route.

       Some additional assumptions made on the basis of the limited data available are listed
below:
       •      The environmental half-life of TCDD in soil is 12 years.
       •      TCDD levels in airborne dust are the same as those in soil
       •      Indoor TCDD levels in dust are the same as outdoor levels.
       •      Fifteen m3 of air is exchanged per person per day.
       •      The GI absorption rate of TCDD in soil is 30%.
       •      Exposures would  take place only 6 months of the year because of seasonal
              influences and varying activity patterns.
       •      The dermal absorption rate of TCDD in soil is 1%.

       Figure A-10 gives the estimated dairy deposition of soil on skin by age.   The same
amounts were assumed to be ingested each day. These values are based on work done studying
lead uptake from contaminated soils.
                                         A-17

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                                                                          Appendix A
                                                                            Revision 1
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                                                                          Page 19 of 21
       The authors make the point that their analysis applies only to residential areas and

suggest that a lower safe value may be more appropriate for range or dairy farm areas, whereas

a higher value may be adequate for commercial areas. Figure A-11 shows some results derived

by the Food and Drug Administration (FDA)  by analogy to polybrominated biphenyl (PBB)

data.  A maximum allowable intake of 100 picograms/day was assumed. Note that the value in

soil which would produce the maximum allowable residue in milk is 6.2 pg/g or 6.2 parts per

trillion (ppt).



       Based on direct extrapolation of rodent data to humans and  extrapolation to low doses

by the linear derived multistage model, a dose of 28 fg/kg body weight/day is calculated as the

virtually safe dose (an added cancer risk of 1/106).  For a 70 kg man, this is equivalent to 1.96

pg/person/day. A uniform concentration of 1 ppb in soil by the model used would lead to 44

pg/person/day.



       Figure A-12 gives the estimated average daily dose corresponding to initial TCDD-soil

contamination levels. It also shows the uncertainty ranges for both 10"6 and 10*5 excess lifetime

cancer risks.  On the basis of these results and the assumption that  not 100% of contaminated

areas would be at the peak level, the authors conclude that 1 ppb is a soil level of TCDD which

should not be exceeded in residential areas.
                                         A-19

-------
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                                 A-20

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A-21

-------
df

1
2
3
4
5
                             APPENDIX B.

                PERCENTILES OF THE t DISTRIBUTION
    Confidence Level (%): 1-ot/, for two-tailed test
    20      30       60      SO      90
    Confidence Level (%): 1-cr for one-tailed test
    60      70       80      90      95
                                                                     Appendix B
                                                                    Revision  1
                                                                       03/01/89
                                                                    Page  1  of 1
.325
.289
.277
.271
.267
6   .265
7   .263
8   .262
9   .261
10  .260

11  .260
12  .259
13  .259
14  .258
15  .258

16  .258
17  .257
18  .257
19  .257
20  .257

21  .257
22  .256
23  .256
24  .256
25  .256

26  .256
27  .256
28  .256
29  .256
30  .256

40  .255
60  .254
 120 .254
oc  .253
.727
.617
.584
.569
.559

.553
.549
.546
.543
.542

.540
.539
.538
.537
.536

.535
.534
.534
.533
.533

.532
.532
.532
.531
.531

.531
.531
.530
.530
.530

.529
.527
.526
.524
1.376
1.061
 .978
 .941
 .920

 .906
 .896
 .889
 .883
 .879

 .876
 .873
 .870
 .868
 .866

 .865
 .863
 .862
 .861
 .860

 .859
 .858
 .858
 .857
 .856

 .856
 .855
 .855
 .854
 .854

 .851
 .848
 .845
 .842
3.078
1.886
1.638
1.533
1.476

1.440
1.415
1.397
1.383
1.372

1.363
1.356
1.350
1.345
1.341

1.337
U33
1.330
1.328
1.325

1.323
1.321
1.319
1.318
1.316

1.315
1.314
1.313
1.311
1.310

1.303
1.2%
1.289
1.282
6.314
2.920
2.353
2.132
2.015

1.943
1.895
1.860
1.833
1.812

1.796
1.782
1.771
1.761
1.753

1.746
1.740
1.734
1.729
1.725

1.721
1.717
1.714
1.711
1.708

1.706
1.703
1.701
1.699
1.697

1.684
1.671
1.658
1.645
95
97.5
12.706
4.303
3.182
2.776
2.571
2.447
2.365
2.306
2.262
2.228
2.201
2.179
2.160
2.145
2.131
2.120
2.110
2.101
2.093
2.386
2.080
2.074
2.069
2.064
2.060
2.056
2.052
2.048
2.045
2.042
2.021
2.000
1.980
1.960
98
99
31.821
6.965
4.541
3.747
3.365
3.143
2.998
2.896
2.821
2.764
2.718
2.681
2.650
2.624
2.602
2.583
2.567
2.552
2.539
2.528
2.518
2.508
2.500
2.492
2.485
2.479
2.473
2.467
2.462
2.457
2.423
2.390
2.358
2.326
99
99.5
63.657
9.925
5.641
4.604
4.032
3.707
3.499
3.355
3.250
3.169
3.106
3.055
3.012
2.977
2.947
2.921
2.898
2.878
2.861
2.845
2.831
2.819
2.807
2.797
2.787
2.779
2.771
2.763
2.756
2.750
2.704
2.660
2.617
2.576
                                   B-l

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               APPENDIX C
DATA QUALITY OBJECTIVES DEVELOPMENT PROCESS
                 C-l

-------
                                  Appendix  C
                                  Revision  1
                                  03/01/89
                                  Page  2  of 13
C-2

-------
          DATA QUALITY OBJECTIVES (DQOs) DEVELOPMENT CHECKLIST




                         FOR STAGE I (DECISION MAKER)



                                 'AUTHORITIES"
L.  Initial perception of what decision must be made.



   Comment:	
2.  What information is needed?



   Comment:	
3.  Why and When needed?



   Comment:	
4.  How will information/data be used?



   Comment:	
5.  What are consequences of inadequate/incomplete data?



   Comment:	
6.  Estimates of Time and Resources available?



   Comment:	
7.  Establishment of Priority for project?



   Comment:	
8.  Record Decision.



   Comment:	
9.  Close Project or Phase of Project.



   Comment:	
Complete? a
Complete? a
Complele? a
Complete? a
Complete? a
Complete? a
Complete? o
Complete? a
Complete? a
                                   C-3

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           DATA QUALITY OBJECTIVES (DQOs) DEVELOPMENT CHECKLIST

                      FOR STAGE II (SENIOR PROGRAM STAFF)

                                  "MANAGEMENT"


 I. Examine Stage I  Results                                              Complete? ~

     a. Interaction with Decision MakerKs).                                          -

     b. Internal Discussion and Work Groups.                                        2

     c. Section/Office Tasking.                                                    z>

   Comment:__	__	


2. Generate specific guidance for data collection project.                  Complete? 2

     a. Interaction with decision makerts).                                           a

     b. Internal Discussion and Work groups.                                         -

     c. Section/Office Tasking                                                     -

   Comment:^	


3. Refine and Define DQOs:                                             Complete? a

     a. Proposed and final statements of type and quality
        of environmental data Required.                                            -z

     b. Technical constraints; define logistic and
        resource limits on Data Collection Project.                                   a

   Comment:	
                                       C-4

-------
           DATA QUALITY OBJECTIVES (DQOs) DEVELOPMENT CHECKLIST




                        FOR STAGE III (TECHNICAL STAFF)




                                   "PLANNING"
1.  Develop QA Project Plan and Work Plan:



     a. Draft addressing all elements in guidance.



     b. Internal Review.



     c. External Review.



     d. Finalize Draft QAPjP.



     e. Documentation oi* all operations.



     f. Sample acquisition and analyses.





     g. Data reduction and validation



   Comment:	
2.  Develop Acceptance Criteria for evaluation of Project.



   Comment:	
Complete? c
          G





          a
Complete? c
3.  Oversight of Project Team activities.



   Comment:	  	
Complete? a
                                    C-5

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           DATA QUALITY OBJECTIVES (DQOs) DEVELOPMENT CHECKLIST

                           I'OR STAGE IV (PROJECT TEAM)

                                    "SUPPORT"
 I.  Execute Work Plan field operations adhering
    to QAPjP criteria for procedures and documentation.
   Comment:
Complete? a
2. Analyze samples, reduce and validate data.

   Comment:	
Complete?
3. Make and correlate all necessary observations
   for professional opinion statements.
   Comment:
Complete? a
4.  Preliminary Report

   Comment:
Complete? 3
     a. Validated data package

     b. Operational documentation

     c. Technical Deliverables as called for in QAPjP
        (includes but not limited to, Professional Opinions,
        Model or Trend analyses results, Photograph, etc.)

o.  Execute Corrective actions if needed

   Comment:	
Complete? a
6.  Close out site operations unless otherwise
   directed for anticipated subsequent phases.

   Comment:       	  	
Complete? a
                                    C-6

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                                                                       Appendix C
                                                                       Revision 1
                                                                       03/01/89
                                                                       Page  7 of  13
                  EXAMPLE  FORMAT  AND  CRITICAL  ELEMENTS  OF

                            QUALITY  ASSURANCE  PLAN
                        Project name:.
                        Project code:
                        Address:
                        Responsible organization:
Approvals:

    Project Officer:	Date.

    QA Off1cer:_	Date.

    ESD Peer Review:	Oate_

    Regional Sample  Control  Center (RSCC):	Date.

    Super vi sor:	Date.
                                      C-7

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           ORGANIZATION AND RESPONSIBILITY
      The following is a list of key project personnel =na their
 'esccnsi bi 1 1 ties :

      Organization Manager _
      Project Officer _
      QA Officer
                             Appendix C
                             Revision 1
                             03/01/89
                             Page 8 of 13
      Field Operation 	
      Laboratory Operation 	
      Data Quality Review 	
      System/Performance Audit
   PROJECT CODES AND SAMPLE NUMBERS (to be completed by RSCC)
      Project NO.:	
      Laboratory Designated:	
      Sample Numbers assigned:   from_
Account NO..
EPA
 CLP
"to "
Private
   PROJECT DESCRIPTION

      1.  Objective  and Scope:
      2.  Schedule  of Tasks  and Milestones:
         Activities
                                            Dates
      3.  Data Usage:.
      4.  Monitoring  network/sample collection design ard
••aticnale:   	   	
                                        -2-    C-8

-------
•  PROJECT DESCRIPTION  -  continued
Appendix C
Revision 1
03/01/89
Page 9 of 13
# of
Samples





Sample
Matrix





Col lec-
tion
Fre-
quency





Anal yt-
icai
Parame-
ter





Type Of
Sample
Contai ner





Samoie
Preserva-
tion





Holdi nq
Time





Analyti cal
Detection
Limi t





Qual i tyj
Control
Samples





   DATA QUALITY OBJECTIVES

         1. Precision and Accuracy  protocols/1imlts:
        2. Data Representativeness:
        3. Data Comparabi1ity:
        4. Data Completeness:
   SAMPLING PROCEDURES (including QC checks):
                                           -3-
                                            09

-------
                                                                       Appendix C
                                                                       Revision 1
   SAMPLE CUSTODY PROCEDURES:                                          03/01/89
                                                                       Page  LO of  L3
   CALIBRATION PROCEDURES AND PREVENTIVE MAINTENANCE:
•  ANALYTICAL METHODS (including QC checks):
•  DOCUMENTATION,  DATA REDUCTION AND REPORTING

         1.  Documentation:  	
         2.  Data  Reduction  and Reporting:
   DATA ASSESSMENT:
•  PERFORMANCE/SYSTEM AUDITS:
                                            -4-
                                           C-10

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                                                                       Appendix C
                                                                       Revision 1
•  CORRECTIVE ACTION:                                                   03/01/89
                                                                       Page 11 of 13
•  REPORTS:
                                            -5-


                                           C-ll

-------
                                                                       Appendix C
                          SAMPLE ALTERATION CHECKLIST            Revision 1
                                                                       03/01/89
                                                                       Page 12 of 13
 Project Name and Number:
 Material to be sampled:
 Measurement Parameter:
Standard Procedure for Field collection & Laboratory Analysis (cite references):
 Reason for change in Field Procedure or Analytical Variation:
Variation from Field or Analytical Procedure:
Special Equipment, Materials, or Personnel Required:
Initiators Name:  	  Date:

Project Approval: 	  Date:

Laboratory Approval:  	  Date:

<^A Officer/Reviewer:  	  Date:

Sample Control Center:  	  Dato:
                                        C-12

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                         CORRECTIVE ACTION CHECKLIST
 Project Name and Number:
                       Appendix C
                       Revision 1
                       03/01/89
                       Page  13  of  13
Sample Dates Involved:
Measurement Parameters):
Acceptable Data Range:
Problem Areas Requiring Corrective Action:
Measures Required to Correct Problems:
Means of Detecting Problems and Verifying Correction:
Initiators Name:

Project Approval:
Laboratory Approval: _

QA Officer/Reviewer:

Sample Control Center:
                                        -6-
Date:

Date:

Date:

Date:

Date:
                                                                  (2-11)5/86
                                        C-13

-------