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
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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:
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.
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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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