United States
 Environmental Protection
 Agency
Environmental Monitoring Systems
Laboratory
Las Vegas NV 89114
 Research and Development
EPA-600/S4-85-003  Jan. 1985
 Project  Summary
 Standard Operating
 Procedures for Conducting
 Sampling  and  Sample
 Bank Audits
  A Standard Operating Procedure
(SOP) for conducting audits of Resource
Conservation and Recovery Act (RCRA)
and Comprehensive  Environmental
Response Compensation and Liability
Act (CERCLA—also known as Super-
fund) field sampling and sample bank
activities is presented in the full report.
The SOP provides audit personnel with
a description  of the components and
organization of an audit program. Also
discussed are administrative and pro-
cedural functions necessary to initiate,
conduct, and complete the audit and
suggested qualifications and training
requirements for audit personnel. The
Appendix of the SOP provides check-
lists for use in conducting the audit.
Checklists are presented for identifying
and evaluating the use of proper samp-
ling equipment and materials, sampling
methodology, packaging, labeling and
shipment of samples, quality assurance
and quality control protocols, sampling
plans and sampling personnel.
  This Project Summary was developed
by EPA's Environmental Monitoring
Systems Laboratory, Las Vegas, NV, to
announce key findings of the research
project that is fully documented in a
separate report of the same  title (see
Project Report ordering information at
back).

Introduction
  Under RCRA regulations, EPA requires
that owners and operators of hazardous
waste treatment, storage, and disposal
(TSD) facilities initially sample and ana-
lyze all wastes handled at the facility to
determine if they are hazardous. Periodic
analysis is required if wastes are haz-
ardous and when a process or other type
of change might affect waste composition.
Owners and operators of hazardous waste
TSD facilities may also be required to
sample and analyze ground water, surface
water, and soil under various circum-
stances (e.g., if they operate a land
disposal facility, ground-water monitoring
is required; soil analysis to check for
contamination may be required when
closing a hazardous waste TSD unit).
  The EPA has also developed and im-
plemented field monitoring programs
under CERCLA in response to incidents of
environmental contamination.
  The EMSL-LV is responsible for pre-
paring SOPs  for auditing RCRA and
CERCLA related sampling and sample
bank activities as well as conducting field
audits of these activities when performed
by EPA and its contractors. Although
SOPs for auditing analytical methods and
laboratory practices have been developed,
guidelines for conducting evaluations of
sampling and sample bank activities are
lacking. This SOP provides the Agency
with such guidelines for use in evaluating
and auditing sampling and sample bank
activities.

Synopsis of Key Sections

Background
  An audit involves a systematic check to
determine  if the project personnel are
adhering to the steps, methods and pro-
tocols required by the Project and Quality
Assurance (QA) Plans.
  Specifically, the audit should:

• Verify that the sampling methodology
  and QA  measures are being performed

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   in accordance with program require-
   ments.
 • Verify that project documentation is in
   order (i.e., records, chain-of-custody
   forms, analytical tags, logbooks, work
   sheets).
 • Verify key project personnel and quali-
   fications.
 • Identify QA problems.
 • Require corrective actions if necessary.
 • Follow-up on previous recommenda-
   tions.
 • Provide a written report .of the audit.

Audit Team
  The audit team consists  of an  audit
program manager who has overall re-
sponsibility for the audit and final report;
a team leader responsible for leading the
team through preparation, the site visit,
and report preparation; and one or more
team members  with assignments for
specific activities in connection with the
audit.
  The team members must be trained in
performing an audit, RCRA and CERCLA
regulations, safety protocols, safety equip-
ment, first aid, cardiopulmonary resusci-
tation (CPR), contingency and evacuation
plans, chain-of-custody, preservation of
evidence, risk assessment, and personal
hygiene. The team members must have
sufficient  academic training and  work
experience in fields  related to the audit
activities. Minimum requirements are pre-
sented in the SOP.
  Team members must undergo medical
examinations  periodically  throughout
their assignment. An initial examination
will be required  prior to participation in
any activity dealing with hazardous mate-
rials. Follow-up examinations should be
performed at least annually. Additional
exams may be called for if the person has
been subjected to uncontrolled or unsafe
conditions where he may  have  been
exposed to potentially hazardous material.
A personal  emergency card must be
completed for each team member and be
part of the equipment and supplies which
accompany the team to the site.

In-House Audit Preparation
  The  products  of  the in-house  audit
preparation should be the following:

 • Assignments  for  the team members
   during both the preparation and field
   audit phases.
 • Checklists to  identify  and verify per-
   formance of critical steps in activities.
• List of equipment and supplies needed
   during the audit.
• Schedule of activities for the site visit
   including the introductory  meeting
   with senior field personnel, the various
   audit activities, a session for the team
   to prepare for the debriefing, and finally
   the debriefing of site personnel.

  The team should prepare to conduct the
audit  by reviewing documents  on the
project including:

• Project Plan
• QA Project Plan and QA Reports
• Protocols and Methods
• Previous  Audit  Reports from other
   offices or agencies
• Project and Progress Reports
• Contract and Proposals
• Health and  Safety  Plan and  Contin-
   gency and Evacuation Plan


Conducting the Field Audit
  Multimedia sampling audit checklists
especially tailored to a specific sampling
program or the prepared checklists
presented should  be  used for  on-site
documentation. An auditor  using the
sampling audit checklists must verify that
all documentation  is in order and is
sufficient to establish  the disposition of
collected samples by examining  records
and any archived samples. Records re-
viewed should  include chain-of-custody
forms, sample tags, custody seals, ship-
ment forms, and logbooks. In addition, per-
sonnel identified in the Programs Project
Plan, QA Plan and/or contract, including
all managers, middle managers, profes-
sional specialists, and  first-line field
supervisors, should be identified.
  It is recommended  that all  sampling
and sample handling procedures be ob-
served first hand. The  use of proper
sampling equipment,  decontamination
procedures, sample site description forms,
field  logbooks and that correct sampling
sites  were sampled should be docu-
mented.
  The preparation and use of checklists
are also recommended for the following
activities:

• Housekeeping—safety, accident docu-
   mentation and security
• Sampling equipment and container
   preparation
• Storage and sampling equipment
• Frequency of collection of field blanks,
   replicates, splits and spikes

Audit Completion
  The audit  is completed by comparing
the findings of the site visit with the
project requirements and documenting
the results in a written report.
  The report should summarize observa-
tions in the following areas:

• Sampling activities and documentation
• Sample Bank activities and documen-
   tation
• QA problems
• Follow-up on previous recommenda-
   tions
• Summary

  The report should clearly identify the
points which require corrective action.
These should be in the form of recom-
mendations made to the office requesting
the audit.

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     This Project Summary was authored by staff of Life Systems, Inc., Cleveland, OH
       44122.
     J. Gareth Pearson is the EPA Project Officer (see below).
     The complete report, entitled "Standard Operating Procedures for Conducting
       Sampling and Sample Bank A udits," (Order No. PB85-143 279; Cost: $11.50,
       subject to change) will be available only from:
            National Technical Information Service
            5285 Port Royal Road
            Springfield,  VA 22161
            Telephone: 703-487-4650
     The EPA Project Officer can be contacted at:
            Environmental Monitoring Systems Laboratory
            U.S. Environmental Protection Agency
            P.O. Box 15027
            Las Vegas, NV 89114
                                       * U.S. GOVERNMENT PRINTING OFFICE; 1985 — 559-016/7902
United States
Environmental Protection
Agency
Center for Environmental Research
Information
Cincinnati OH 45268
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