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 (CERCLAalso 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 ------- 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: Housekeepingsafety, 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. ------- 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 .,.,;,,,:-. /""r'qsfAGE&"FEESPA ":'"' " ' .c', '--,,< - nEP^ O "" ' . :"u ' *PERWITilo.M3-35, Official Business Penalty for Private Use $300 OOOC329 PS 'GIMCY ------- |