United States
            Environmental Protection
            Agency
                 Region V
                 563 South Clark Street
                 Chicago, Illinois 60605
August, 1981
            Surveillance & Analysis Division
                                 905R81012
&EPA
S&A
Policies and  Procedures
Manual

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 ENVIRONMENTAL PROTECTION AGENCY
             REGION V
S&A POLICIES AND PROCEDURES MANUAL
           AUGUST 1981
 SURVEILLANCE & ANALYSIS DIVISION
        CHICAGO, ILLINOIS

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                                  FORWARD
This manual has been prepared as a definitive guide for use by employees
of the Surveillance and Analysis Division, Region V, U.S. EPA, in labor-
atory and field activities in support of agency programs.  The policies
and procedures outlined herein are thus the standard to which each em-
ployee is to adhere.  The document is comprehensive, and covers such
matters as project phases; employee conduct; procedures for entering a
facility; report writing and standardized formats; resource accountability/
tracking commitments; sample handling; chain of custody; document control;
expert witness guidelines and quality assurance.

Much of the information contained herein constitutes a compilation of
existing regional and/or national policy and procedures, modified or fully
developed, as necessary, to meet the needs of Region V.  In this sense,
special acknowledgement is given to NEIC and the Region VIII S&A Divi-
sion, both in Denver, that provided a foundation from which to produce
this report.  In addition, many S&AD Region V managers and staff worked
to provide parts of this document, and to review and refine the whole.
Special appreciation is accorded to Ms. Eva Howard, who discharged the
arduous responsibility of putting together the parts, coordinating com-
ments, and resolving problems to enable the completion of this report.
William H. Sanders III, Director
Thomas E. Yeates, Deputy Director

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                             TABLE OF CONTENTS
FOREWARD                                                              PAGE

1.  S&A Project Phases	    1
    1.1      Introduction 	    1
    1.2      Project Request	    1
    1.3      Background Review	    4
    1.4      Project Plan	    4
    1.5      Followup	    6
    1.6      Witness Guidelines 	    6
    1.7      Project Activities 	   12
    1.8      Reports	12

2.  S&A Operating Policies and Procedures 	   13
    2.1      Introduction	13
    2.2      Employee Conduct 	   14
    2.2.1    Entering a Facility	   15
    2.2.1.1  Authority	15
    2.2.2    Unreasonable Search and Seizure	15
    2.2.3    Acquisition of Confidential Business Information ....   17
    2.2.4    Storage and Use of CBI	17 -
    2.2.5    Distribution of Disclosure of CBI	21 -
    2.3      S&A Project Leader Responsibilities	21
    2.3.1    Project Plans - Routine Surveys	23
    2.3.2    Project Plans - Major or Special Surveys 	   23
    2.3.3    Administrative Matters 	   23
    2.3.3.1  Procurement Requests 	   23
    2.3.3.2  Time Keeping	24
    2.3.4    Field Activities 	   24
    2.3.5    Report Writing	25
    2.4      S&AD Tracking of Resources and Commitments	25
    2.4.1    Discussion	25
    2.4.2    S&AD Tracking Program Entry Requirements 	   26
    2.4.3    Outputs	26
    2.5      S&A Division Safety Program	31
    2.5.1    Safety Policy Statement	31
    2.5.2    Emergencies	31
    2.5.3    Office Safety Requirements 	   32
    2.5.4    Self-Protection Plan	33
    2.5.5    Field and Laboratory Safety	33
    2.5.6    Medical Monitoring Program 	   33

3.  Sample Handling and Custody Procedures	34
    3.1      Introduction	34
    3.2      Sample Control/Holding Procedures	34
    3.2.1    Procedure for Hazardous and Non-Hazardous
               Water and Sediment Samples	40
    3.2.2    Procedure for Packaging and Shipment of Fish Samples .  .   41
    3.2.3    Sampling Handling - Contract Laboratories
               and Field Staff	42

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                                                                      PAGE

    3.3      Chain-of-Cus tody-Procedures	43
    3.3.1    Sample Custody	45
    3.3.2    Field Custody Procedures 	  45
    3.3.3    Transfer of Custody and Shipment	45
    3.3.4    Field Custody - Contractors	46
    3.3.5    Field Logbook	46
    3.3.6    Laboratory Chain-of-Cus tody Procedure	47
    3.4      Procedures for Air Shipment of Environmental Samples .  .  48

4.  Documentation Control Program .. 	  49
    4.1      Introduction ..... 	  49
    4.1.2    Region V Documentation Control Program Description ...  49
    4.1.3    Document Control Number	  50
    4.1.4    Serialized Documents 	  50
    4.1.5    Project Logbooks 	  50
    4.1.6    Field Data Records - Region V Field Record Forms ....  51
    4.1.7    Sample Identification Documents	52
    4.1.8    Chain-of-Custody Records 	  52
    4.1.9    Other Controlled Documents 	  53
    4.1.10   Photographs	54
    4.1.11   Corrections to Documentation 	  55
    4.1.12   Consistency of Documentation 	  55
    4.1.13   Document Numbering System and Inventory Procedure. ...  56
    4.1.14   Branch Files 	  56
    4.2      Evidentiary File	56

5.  Quality Assurance 	  57
    5.1      Introduction	57
    5.2      Policy and Objectives	58
    5.3      Quality Assurance Management 	  59
    5.4      Elements of a Quality Assurance Plan	59
    5.5      Data Collection	  61
    5.5.1    Sampling Methodology 	  61
    5.5.2    Quality Assurance Project Plans	61
    5.5.3    Analytical Methodology 	  62
    5.6      Data Processing	64
    5.6.1    Collection	64
    5.6.2    Validation	64
    5.6.3    Storage	64
    5.6.4    Transfers	64
    5.6.5    Reduction	64
    5.7      Data Quality Assessment	65
    5.7.1    Completeness	65
    5.7.2    Accuracy	65
    5.7.3    Precision	66
    5.7.4    Representativeness .	66
    5.7.5    Comparability	67
    5.8      Corrective Action	67

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                              LIST OF FIGURES


FIGURE                                                            PAGE

  1        Project Request Form                                     2

  2        Authority and Confidentiality Provisions                18

  3        Confidential Cover Sheet                                20

  4        S&A Division's Resources and Tracking Report/           29
           Stationary Source Monitoring - Initial Loading

  5        S&A Division's Resources and Tracking Report/           30
           Stationary Source Monitoring - After First Update

  6        Region V Field Data Record Sheet                        36

  7        Example Sheet From Field Logbook                        37

  8        Sample Identification Tags                              38

  9        Chain-of-Custody Record                                 44

 10        Relationship of the Quality Assurance Function          60
           to Other Regional Program Functions

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1.        S&A PROJECT PHASES

1.1       INTRODUCTION

         The projects undertaken by S&A span a wide variety of activ-
         ities,  from one employee performing technical,  supportive or
         administrative tasks,  to numerous employees from divergent
         disciplines working as a team to accomplish a series of complex
         tasks.   Most of the Division's projects consist of these phases;

                             Project Request

                             Background Review

                             Project Plan

                             Followup

                             Witness Guidelines

                             Project Activities

         This section of the manual discusses the items  covered in each
         phase which are common to most projects, and outlines S&A
         policies pertinent to  each phase.

1.2       PROJECT REQUEST

         The Project Request Form (see Figure 1) should  be completed for
         all services requested of the S&A Division.  The project objec-
         tive must be clearly stated and should be developed in concert
         with S&A Division personnel to facilitate project implementation
         and succesful completion.  Multiple requests (i.e., visible
         emission evaluations,  CEI's, CSI's, PAI's, etc.) should be made
         with one form wherever possible.  It is important to identify the
         decision unit and specific activity to which the project can be
         charged.

         Include supplementary  information as appropriate, i.e., corre-
         spondence,  permits, consent agreements, or other important
         documents not currently available to S&A, as well as any specific
         requests or limitations the S&A project leader  should be aware
         of.  The S&A project leader will formulate a work plan and sche-
         dule in conformance with the project objective  and priority.
         The work plan will be  reviewed with the requestor.  It is not
         desirable or necessary for the requestor to develop detailed work
         plans.

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                                       2



                  UNITED STATES ENVIRONMENTAL PROTECTION AGENCY







  jATE.                         FIGURE 1.   PROJECT REQUEST FORM




SUBJECT.   REQUEST  FOR:







  FROM






    ro.





         PROJECT  OBJECTIVE
         Decision Unit 	 Specific Activity 	 Priority




         Desired Completion Date 	 Legal Authority 	
         Principal Contact: 	 Phone
            Date:




         Subject:   Acknowledgement of Receipt of Work Request




            From:




              To:






         	 will do the above work (as specified) (with modifications).
         Target Comp.  Date: 	 S&A Project No. 	 Est. Cost




         S&A Project Leader: 	 Phone 	




         Comments:
 •-OA FORM 1321! fi "F-..T* (S&A-81-01)

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The
requestor should use the following priority system when
'.estine work:
requesting work:
PRIORITY 1  -
PRIORITY 2  -
PRIORITY 3  -
PRIORITY 4  -
           Highest priority work; immediate response
           or initiation of the project by S&A is
           necessary; other work in progress may be
           curtailed.

           High priority projects to be scheduled and
           completed as soon as possible without dis-
           rupting other work in progress.

           Projects to be completed around Priority 1
           and 2 projects, but with some definite
           completion date, usually at least two or
           three months from request date.

           Projects that may be completed if time is
           available.  No requested due date.
The S&A Division will acknowledge the request by return mail.
Priority 1 work requests should be submitted along with adequate
justification to the S&A Division Director from the requesting
Division or Office Director/ Deputy Director.  Copies should be
delivered to the Central Regional Laboratory and the appropriate
field office at that time.  Priority 2, 3, 4 work requests should
be directed to the appropriate S&A District Office and signed
by the requesting Section Chief or above.

Turnaround time on Priority 1 requests will generally be from
five to ten working days after receipt of request.  More complex
chemical analysis, larger sample sets and number of Priority 1
requests will of course increase turnaround time accordingly.
Therefore, such requests should be kept to an absolute minimum.

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1.3      BACKGROUND REVIEW

         Review of the available background information applicable to
         a specific project is a logical and essential first step in
         providing technical assistance.  Scope and duration of the
         background review varies with the complexity of the project
         request.   Where necessary,  a reconnaissance of the project site
         provides  background verification or updating.  Examples of
         information obtained during a background review include:  spe-
         cific descriptions of related process and pollution control
         systems,  copies of relevant source permits and compliance
         schedules, past self-monitoring data, prior government or
         facility  studies and availability of established analytical
         methods.

         The primary purpose of a review is to familiarize S&A personnel
         with the  background of the  work request, its ramifications, test
         objectives, and sampling requirements so that a comprehensive
         project plan can be developed.   Moreover, information obtained
         during the review will often be used during project performance
         and report preparation.  Therefore, it is important to conduct
         as thorough a review as possible early in the project development.
         The background review may even continue throughout the project
         to obtain needed information.

1.4      PROJECT PLAN

         A general project outline is included with the S&A acceptance of
         an official request.  After sufficient background information has
         been obtained and evaluated, a comprehensive project plan is
         usually prepared based on the specific objectives and tasks in
         the project request.  For projects that are small in scope, the
         acceptance memorandum may serve as the project plan.  Projects
         such as complex pollution control evaluations, NPDES case pre-
         paration, inspections, air  pollution source surveys, ambient air
         and/or receiving water quality surveys and hazardous waste dis-
         posal evaluations normally  require a detailed project plan.

         The project Leader prepares the project plan detailing the pro-
         ject's scope, logistics and schedules.  Items addressed in the
         project plan are:

         1.  Objectives

         2.  Background identification of a summary of process(es),
             applicable regulations  or permit conditions, etc.

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3.  Survey methods, including sampling locations, schedules
    and procedures, analytical requirements, quality control
    program, etc.

4.  Process data to be collected

5.  Personnel and equipment requirements

6.  Safety program and equipment (see Region V's Safety Manual)

7.  Custody procedures

8.  Report schedules

9.  Followup plans (when necessary)

The Project Leader works closely with the appropriate S&A staff
to determine items such as equipment and logistical requirements,
analytical capabilities and personnel availability.  The Project
Leader also communicates with the requester or designated repre-
sentative to ensure that the plan being developed addresses the
tasks requested and focuses on the objectives to be completed
within a specific time frame.

The importance of the project plan cannot be overemphasized.  The
plan approximates an agreement between the requesting party and
those individuals performing the work.  Manpower, equipment needs
and logistics can be forecast and scheduled.  Additional equip-
ment, contract services, or personnel can be secured expeditiously
with the advance determination of needs.

The project plan should be provided by S&A to the requester and
the survey team at least two weeks before any specific field,
laboratory, or technical assistance activity is undertaken.  If
no comments on the plan are received from the requester during
this period, it is assumed that the plan is acceptable.  Changes
made to the project plan will be coordinated with the requester
by the Project Leader.  If considered necessary, the project
leader will arrange a meeting between the appropriate S&A per-
sonnel and the requester to discuss any differences and modifi-
cations.  Once all concerned parties agree to the project plan,
it serves as a reference document for the project.

However, during the conduct of the project, some modifications
to the plan may be deemed necessary by the S&A personnel when
unforseen circumstances arise.   If the requester desires changes
in the project plan after the project activities have commenced,
such request will be directed to the Project Leader.  Each
request will be discussed with the appropriate management and
supervisory staff.  Agreed upon changes will be detailed in a
memorandum to the Director.

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1.5      FOLLOWUP

         Because the majority of S&A investigative activities are
         associated with potential  enforcement actions,  Priority 1
         projects and special studies (e.g.,  of the type that would
         merit a quality assurance  plan such  as special  ambient air
         studies, etc.)  will be transmitted under the signature of the
         Director,  Surveillance and Analysis  Division.

         Completion and  transmittal of the project does  not necessarily
         signify the end of S&A's involvement with the project.  Con-
         tinuing involvement may include technical consultation on
         monitoring programs and other technical measures.   S&A per-
         sonnel will continue to followup project involvement in
         subsequent legal proceedings.  In such cases,  S&A personnel may
         be involved in  enforcement cases preparation and serve as, or
         be deposed as witnesses.  Section 1.6 gives Witness Guidelines
         for preparing testimony as an expert witness.   Other reports
         may affect EPA  policies or serve as  forerunners for additional
         enforcement studies.

1.6      WITNESS GUIDELINES

         The following suggestions  are made for prospective witnesses in
         order to lessen the fears  and apprehensions which almost everyone
         has when first  testifying  before a board, commission, hearing
         officer, or in  court.   Even those who have testified previously
         encounter a certain anxiety when called for a repeat performance.
         When a witness  is properly prepared, both with regard to the sub-
         ject matter of  testimony and conduct on the witness stand, there
         should be little fear about testifying.

         It is of utmost importance that the  witness be thoroughly pre-
         pared as to the subject matter of his/her testimony.  Only the
         witness can recall what occurred in  the field and/or laboratory
         and why.  Since many cases are tried substantially after field
         and laboratory  activities  are conducted, it is  imperative that
         adequate documentation be  originally prepared in order that a
         witness' memory may be refreshed.  A thorough and detailed review
         of all survey documents is the only  way prospective witnesses can
         be adequately prepared.

         In order to assist witnesses on how  they should conduct them-
         selves the following suggestions are given.

         The witness will be required to take an oath to tell nothing but
         the truth.  The important  point is to remember that there are two
         ways to tell the truth	one is a halting, stumbling, hesitant
         manner, which makes the board member, hearing officer, judge or
         jury doubt that the witness is telling all the facts in a truthful

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way; and the other way is a confident, straightforward manner,
which inspires faith in what is being said.  It is most important
that the witness testify in the latter manner.  To assist a
witness in testifying in such a manner, a list of time-proven
hints and aids are provided below.

GENERAL INSTRUCTIONS FOR A WITNESS

If you are to be a witness in a case involving testimony concern-
ing the appearance of an object, place, condition, etc., try to
refresh your recollection by again inspecting the object, place,
condition, field notes and records, etc., before the hearing or
trial.  While making such inspection close your eyes and try to
picture the item and recall, if you can, the important points of
your testimony.  Repeat the test until you have thoroughly famil-
iarized yourself with the features of your testimony that will be
given.

Before you testify, visit a court trial or board hearing and
listen to other witnesses testifying.  This will make you familiar
with such surroundings and help you to understand some of the
things you will come up against when you testify.  At least be
present at the hearing of the matter in which you are to testify
in sufficient time to hear other witnesses testify before you
take the witness chair.  This, however, may not always be possible
since on occasion, witnesses are excluded from the court room.

A good witness listens to the question and then answers calmly
and directly in a sincere manner.  The facts should be well known
so they can be communicated.  Testimony in this manner applies to
cross-examination as well as direct examination.

Wear neat, clean clothes when you are to testify.  Dress conserva-
tively.  Do not chew gum while testifying or taking an oath.
Speak clearly and do not mumble.  You will not be permitted to
smoke while testifying.

DIRECT EXAMINATION

In a discussion on administrative procedures, E. Barrett Prettman,
Retired Chief Judge, U.S. Court of Appeals for the District of
Columbia, gave the following advice:

        The best form of oral testimony is a series of short,
        accurate, and complete statements of fact.  Again, it
        is to be emphasized that the testimony will be read
        by the finder of the facts, and that he will draw his
        findings from what he reads. . . Confused, discursive,
        incomplete statements of fact do not yield satisfactory
        findings.

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                            8

Stand upright when taking the oath.  Pay attention and say
"I do" clearly.  Do not slouch in the witness chair.

Do not memorize what you are going to say as a witness.  If
you have prepared answers to possible questions, by all means
do not memorize such answers.  It is, however, very important
that you familiarize yourself as much as possible with the
facts about which you will be called upon to testify.

During your direct examination, you may elaborate and respond
more fully than is advisable on cross-examination.  However,
when you volunteer information, do not ramble and do not stray
from the main point raised in your lawyer's question.  The
taking of testimony is a dialogue, not a monologue.  If your
testimony concerns a specialized technical area, the Court or
hearing board will find it easier to understand if it is pre-
sented in the form of short answers to a logical progression
of questions.  In addition, by letting your lawyer control the
direction of your testimony, you will avoid making remarks which
are legally objectionable or tactically unwise.

Be serious at all times.  Avoid laughing and talking about the
case in the halls, restrooms or any place in the building where
the hearing or trial is being held.

While testifying, talk to the judge, hearing officer or jury.
Look at him or them most of the time, and speak frankly and
openly as you would to any friend or neighbor.  Do not cover your
mouth with your hand.  Speak clearly and loudly enough so that
anyone in the hearing room or courtroom can hear you easily.  At
all times make certain that the reporter taking the verbatim
record of your testimony is able to hear you and record what you
actually say.  The case will be decided entirely on the words
that are finally reported as having been the testimony given at
the hearing or trial.  Always make sure that you give a complete
statement in a complete sentence.  Half statements or incomplete
sentences may convey your thought in the context of the hearing,
but may be unintelligible when read from the cold record many
months later.

CROSS EXAMINATION

Concerning cross-examination, Judge Prettyman gives the following
advice to prospective witnesses:

    Don't argue.  Don't fence.  Don't guess.  Don't make
    wisecracks.  Don't take sides.  Don't get irritated.
    Think first, then speak.  If you do not know the

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    answer but have an opinion or belief on the subject
    based on information, say exactly that and let the
    hearing, officer decide whether you shall or shall not
    give such information as you have.  If a 'yes or no'
    answer to a question is demanded but you think that a
    qualification should be made to any such answer, give
    the 'yes or no' and at once request permission to
    explain your answer.  Don't worry about being bull-
    dozed or embarrassed; counsel will protect you.  If
    you know the answer to a question, state it as pre-
    cisely and succintly as you can.  The best protection
    against extensive cross-examination is to be brief,
    absolutely accurate, and entirely calm.

The hearing officer, board member or jury wants only the facts,
not hearsay, conclusions, or opinions.  You usually will not
be allowed to testify about what someone else told you.

Always be polite, even to the attorney for the opposing party.

Do not be a smart aleck or cocky witness.  This will lose you
the respect and objectivity of the trier of the facts in the
case.

Do not exaggerate or embroider your testimony.

Stop instantly when the judge, hearing officer or board member
interrupts, or when the other attorney objects to what you say.
Do not try to sneak your answer in.

Do not nod your head for a "yes" or "no" answer.  Speak out
clearly.  The reporter must hear an answer to record it.

If the question is about distances or time and your answer is
only an estimate, be certain that you say it is only an estimate.

Listen carefully to the question asked of you.  No matter how
nice the other attorney may seem on cross-examination, he may be
trying to hurt you as a witness.  Understand the question.  Have
it repeated if necessary; then give a thoughtful, considered
answer.  Do not give a snap answer without thinking.  You cannot
be rushed into answering, although, of course, it would look bad
to take so much time on each question that the board member,
hearing officer or jury would think that you are making up the
answers.

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                            10

Answer the question that is asked—not the question that you
think the examiner (particularly the cross-examiner) intended
to ask.   The printed record shows only the question asked, not
what was in the examiner's mind and a nonresponsive answer may
be very detrimental to your side's case.   This situation exists
when the witness thinks "I know what he is after but he hasn't
asked for it."  Answer only what is asked.

Explain your answers if necessary.  This is better than a simple
"yes" or "no".  Give an answer in your own words.  If a question
cannot be answered truthfully with a "yes" or "no", you have a
right to explain the answer.

Answer directly and simply the question asked you and then stop.
Never volunteer information.

If by chance your answer was wrong, correct it immediately; if
your answer was not clear, clarify it immediately.

You are sworn to tell the truth.  Tell it.  Every material truth
should be readily admitted, even if not to the advantage of the
party for whom you are testifying.  Do not stop to figure out
whether your answer will help or hurt your side.  Just answer
the question to the best of your ability.  Give positive,
definite answers when at all possible.  Avoid saying "I think,"
"I believe," "In my opinion."  If you do not know, say so.  Do
not make up an answer.  You can be positive about the important
things which you naturally would remember.  If asked about little
details which a person naturally would not remember, it is best
to say that you do not remember.

Do not act nervous.  Avoid mannerisms which will make it appear
that you are scared, or not telling the truth, or all that you
know.

Above all, it is most important that you do not lose your temper.
Testifying at length is tiring.  It causes fatigue.  You will
recognize fatigue by certain symptoms:  (a) tiredness, (b) cross-
ness, (c) nervousness, (d) anger, (e) careless answers, (f) will-
ingness to say anything or answer any question in order to leave
the witness stand.  When you feel these symptoms, recognize them
and strive to overcome fatigue.  Remember that some attorneys on
cross-examination are trying to wear you out so you will lose
your temper and say things that are not correct, or that will
hurt you or your testimony.  Do not let this happen.

If you do not want to answer a question, do not ask the judge,
hearing officer or board member whether you must answer it.  If
it is an improper question, your attorney will object for you.
Do not ask the presiding officer, judge or board member for his
advice.

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                            11

Do not look at your attorney or at the judge, hearing officer or
board member for help in answering a question.  You are on your
own.  If the question is an improper one, your attorney will
object.  If the judge, hearing officer or board member then says
to answer it, do so.

Do not hedge or argue with the opposing attorney.

There are several questions which are known as "trick questions.1
That is, if you answer them the way the opposing attorney hopes
you will, he can make your answer sound bad.  Here are two of
them:

    "Have you talked to anybody about this matter?"  If you
    say "no," the hearing officer or board member, or a
    seasoned jury, will know that is not right because good
    lawyers always talk to the witnesses before they testify.
    If you say "yes," the lawyer may try to imply that you
    were told what to say.  The best thing to say is that you
    have talked to Mr. 	, your lawyer, to the
    appellant, etc., and that you were just asked what the
    facts were.  All we want you to do is simply tell the
    truth.

    "Are you getting paid to testify in this appeal?"  The
    lawyer asking this hopes your answer will be "yes,"
    thereby implying that you are being paid to say what your
    side wants you to say.  Your answer should be something
    like "no, I am not getting paid to testify; I am only
    getting compensation for my time off from work, and the
    expense it is costing me to be here."

In addition to the above suggestions and guidelines, several
additional references are available for further background:

Expert Witnesses and Environmental Litigation, J. L. Sullivan
and R. J. Roberts, Journal of the Air Pollution Control
Association, April 1975, Vol.  25, No.  4.

Environmental Litigation and the In-House Engineer, F. Finn;
R. C. Heidrick; K. Thompson, Journal of the Air Pollution Con-
trol Association, February 1977, Vol.  27, No. 2.

Essentials of Cross-Examination, Leo R. Firedman, CEB 1968.

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                                     12

1.7      PROJECT ACTIVITIES

         Technical duties such as  technical information searches,  inspec-
         tion,  evaluations,  sampling  surveys,  observations,  data gathering
         and interpretation  and analytical testing are performed in accord-
         ance with the applicable  established  procedures.   When new methods
         or modifications to existing procedures  are required,  they must be
         documented as expeditiously  as possible.   Because  of  the close
         scrutiny that may be given to S&A gathered data during litigation,
         all samples are maintained under chain-of-custody  procedures  and
         accounted for by a  document  control program.   To ensure that  all
         procedures practiced by S&A yield accurate data, these procedures
         are audited routinely through a quality  assurance  management  pro-
         gram.   (See Section 5 for procedures  and programs.)

1.8      REPORTS

         The Surveillance and Analysis Division conducts a  variety of  in-
         vestigations for client programs.  Depending on the request,  an
         investigation may be performed by any one of the four branches/
         offices within the  Division.  Preparation of the project report,
         including coordinating the preparation of individual  reports  by
         project participants is the  responsibility of the  project leader,
         Field Support Team, in the Eastern District Office and/or Central
         District Office. To achieve consistent  appearance, and provide
         direction to employees, Region V's Surveillance and Analysis
         Division document entitled,  "Investigation Report  Formats"
         (DPM No. 22, February, 1981) provides guidance on  formats to  use
         in reporting the results  from the more common types of investi-
         gations performed by the  Division.

         While it is desirable that project reports be consistent in
         appearance, it is essential  that they be factual,  clear, concise,
         defensible and responsive to the project objectives.   A good
         command of the English language and strong technical  writing
         skills are key requisites to producing high quality reports.

         Overall responsibility for preparing  the final report, resides
         with the project leader,  who along with  the management of S&A,
         bears the burden for the  accuracy and defensibility of the report
         and its conclusion.  Achieving this goal, however, requires that
         each S&A organization participating in the project assure that
         its individual contributions are accurate.

         Except for Priority 1 requests, completed investigation reports
         are to be transmitted as  described in the "Investigation Report
         Formats" document.   The Division objective is to maintain a two
         week turnaround time for  completed reports.  The turnaround time
         should be determined as follows:

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                                     13

             Inspections - 2 weeks after date of inspection
             Inspections with sampling - 2 weeks after receipt of
             data by the project leader

         The protocol applicable to the completion of Priority 1 (Emergency
         survey) requests is described in DPM No. 18.  Basically two types
         of reports are required:

         Preliminary Report

         The preliminary report is intended to be brief and consist of (a)
         a brief concise listing of "preliminary findings"; (b) a tabula-
         tion of field and laboratory data; and (c) a listing of sample
         numbers and sample descriptions.  The report will be transmitted
         via memo for signature of the Branch Chief to the requester with
         a carbon copy including attachments to the Director of S&A.  The
         transmittal should indicate the name and location of the survey;
         the dates of the request, inspection and sampling; name of re-
         quester; and the name of the S&A Project Leader.  Except for
         large/ complex requests, the total turnaround time from date of
         initiation of request to provision of preliminary report to the
         requesting Division should fall within the following limits:

               5 workdays - outstanding
              10 workdays - adequate
              15 workdays - Unacceptable

         Final Project

         Depending on the specific request, the Final Project Report may
         be in the form of a memo or separate report with a transmittal
         memo.  The transmittal memo for the Final Project Report should
         be prepared for the signature of the Director, S&A, addressed to
         the Director of the Requesting Division/Office and indicate the
         name of the S&A Project Leader and, as appropriate, a concise
         statement of only the most significant findings that warrant
         highlighting to senior management.  Carbon copies with attach-
         ments should be provided to the requesting Branch Chief.  The
         final report should follow as soon as possible after the pre-
         liminary report.

2.        S&A OPERATING POLICIES AND PROCEDURES

2.1      INTRODUCTION

         This section of the manual includes information on:

             Employee Conduct
             Project Leader Responsibilities and Authority
             S&A Tracking of Resources & Commitments
             S&A Division Safety Program

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                                     14

         The purpose of this section is to provide useful  information on
         procedural guidance for  these activities.
2.2      EMPLOYEE CONDUCT
         S&A employees are required to perform their duties in a profes-
         sional and responsible manner,  refraining from any use of  official
         position for private  gain.  S&A employees are also required to
         collect and report the facts of an investigation completely,
         accurately and objectively.   They must also conduct themselves
         at all times in accordance with the regulations prescribed in the
         EPA handbook, RESPONSIBILITIES  AND CONDUCT FOR EPA EMPLOYEES.
         The following four paragraphs review some topics in the handbook
         especially applicable to  S&A work.

         Employees shall avoid conflicts of interest through outside employ-
         ment or other private interests.   A conflict of interest may exist
         whenever an EPA employee  has a  personal or private interest in a
         matter which is related to his  official duties and responsibil-
         ities.  It is important to avoid even the appearance of a  conflict
         of interest because the appearance of a conflict damages the in-
         tegrity of the Agency and its employees in the eyes of the public.
         All employees must, therefore,  avoid situations which are, or give
         the appearance of conflicts  of  interest when dealing with  others
         in or outside the government.

         Good public relations and common sense dictate that employees dress
         appropriately and with proper safety equipment for the activity
         in which engaged.  When in the  laboratory, field, or industrial
         facility, employees should consult their supervisor and the Region
         V SAFETY MANUAL relative  to  proper attire and safety requirements.
         When performing work  at a facility, employees must conform to the
         safety requirement specified by the facility representatives.

         It is important that  cooperation be obtained and good working re-
         lations established when  working with the public.  This can best
         be accomplished by using  diplomacy, tact, and persuasion.   Em-
         ployees should not speak  of  any person, other regulatory agency
         or facility in a derogatory manner, and should use discretion
         when asked to give a  professional opinion on specific products
         or projects.  All information acquired during an employee's duties
         is for official use only.

         An employee is forbidden to solicit or accept any gift, gratuity,
         entertainment, favors, loans, or any other thing of monetary value
         from any person, corporation, or group which has a contractual or
         financial relationship with EPA,  which has interests that  may be

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                                     15

         substantially affected by such employee's official actions,  or
         which conducts operations regulated by EPA.   Responsibility  for
         individual actions rests with the employee where circumstances
         make it inappropriate to decline a nominally valued gratuity,
         such as lunch in a company cafeteria where no payment mechanism
         is provided (EPA Notice, No.  80-1 January 15, 1980 Employee  Re-
         sponsibilities and Conduct)

2.2.1    ENTERING A FACILITY

2.2.1.1  AUTHORITY

         Various Federal environmental statutes grant EPA enforcement per-
         sonnel authority to enter and inspect facilities.  The authority
         granted in each statute is similar to that stated below,  in
         Section 308 of the Clean Water Act:

             "(a)(B) the Administrator or his authorized representative,
             upon presentation of his  credentials

             (i) shall have a right of entry to, upon, or through  any
             premises in which an effluent source is located or in which
             any records required to  be maintained	are located, and

             (ii) may at reasonable time have access to and copy records,
             inspect any monitoring equipment or method required....,
             and sample any effluents  which the owner or operator  of  such
             source is required to sample..."

         For the specific requirements on conducting inspections and  col-
         lecting data pursuant to other particular ACTS, see:  Section 114
         of the Clean Air Act; Sections 8 and 9 of the Federal Insecticide,
         Fungicide, and Rodenticide Act; Section 3007 of the Resource Con-
         servation and Recovery Act;  Section 8 and 11 of the Toxic Sub-
         stances Control Act; Section 1445 of the Safe Drinking Water Act;
         and the Comprehensive Environmental Response, Compensation,  and
         Liability Act of 1980, P.L.  96-510 (Superfund).

2.2.2    UNREASONABLE SEARCH AND SEIZURE

         EPA authority under the various Acts is subject to the "unreason-
         able search and seizure" provisions of the Fourth Amendment  to
         the Constitution.  It prohibits all searches and seizures which
         are unreasonable or to which required consent has not been given.
         While a consensual entry may  not be necessary for entering a
         public area or for acting under emergency conditions, no  forcible
         entry is permitted without due process of law when entry  has been
         denied.  Consent, in this context, means the intentional  fore-
         going of right to privacy which is not the result of either  fear,
         ignorance or trickery.

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                            16

Consent to enter may be revoked by a facility prior to the com-
pletion of an inspection.   If that should occur, all work per-
formed during the consensual entry should remain in the possession
of the inspection team.  When a withdrawal of consent occurs, the
inspection team shall leave the area and follow the procedures for
denial of entry as detailed below.

To comply with the Acts and avoid any "unreasonable search" and
procedural problems, a facility should be entered in the following
manner:

1.  The plant premises should be entered through the main
    gate or through the entrance designated by the source
    if in response to an inspection notification letter.

2.  The employee should introduce himself in a dignified,
    courteous manner to a responsible plant official and
    briefly describe the purpose of the visit.  Identifica-
    tion credentials should always be shown.  A responsible
    plant official may be the owner, operator, officer or
    agent in charge for the facility, including the plant
    environmental engineer.

3.  If there is only a guard present at the entrance, the
    employee should present his credentials and suggest
    that the guard call his superior on the phone.  The
    inspector may request that the guard call the respons-
    ible official directly when the name is known.

4.  S&A employees shall not sign a release of liability
    (waiver) when entering a facility under the authority
    of Federal law.

5.  If entry is refused, the employee should not contest
    the issue with the facility representative, but will
    immediately do the following:

    a.  Obtain name and title of the individual denying
        entry and record the date and time;

    b.  Cite the appropriate EPA-administered legislation,
        ask if he/she heard and understood the reason for
        your presence, record the answer and any reasons
        given for denial of entry.

    c.  Leave the premises.

After leaving the facility, the employee should, at the earliest
possible moment, inform the appropriate Regional enforcement
attorney of the events which took place.

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                                     17

2.2.3    ACQUISITION OF CONFIDENTIAL BUSINESS INFORMATION (CBI)

         When conducting plant evaluations, inspections, or reconnais-
         sance, S&A personnel should attempt to collect all information
         that appears to be necessary to accomplish the objectives of
         the investigation, without consideration of claims of confi-
         dentiality for portions of it by the company.  However, a clear
         explanation of the Agency's authority and basic procedures for
         handling CBI should be presented to the company at the start
         of the visit.   This may be done either orally or by presenting
         company personnel with a written explanation (see examples in
         Figure 2).  The company should be instructed to designate clearly
         any data, other than that which is obviously effluent or emission
         data, that it  wishes to claim confidential.  This material should
         be marked appropriately and segregated from the other information
         collected.

2.2.4    STORAGE AND USE OF CBI

         Any information (letter, document, photograph, etc.)  that has
         been claimed confidential in whole or in part by the  submitting
         industry is treated as confidential unless/until a formal deter-
         mination has been made to the contrary by the Office  of Regional
         Counsel (ORC).  The only exception is information that clearly
         comprises solely effluent or emission data under the  definitions
         in 40 CFR Part 2.  In addition, any secondary documents generated
         by U.S. EPA that contain information claimed confidential by the
         industry also  are treated as confidential (e.g., letters/memo-
         randa, meetings notes, other reports, telephone memoranda,
         Lexitron discs, tape recordings, etc.).

         Depending on the extent of the material claimed confidential re-
         lative to the  total document, and the need to distribute the
         document widely or outside the Agency, a decision is  made whether
         to treat the entire document as confidential or to create a
         sanitized version by deleting the portions claimed confidential.
         A cross-referencing note is placed in the file or in  the sanitized
         document to indicate that information has been deleted for protec-
         tion of confidentiality.  A special cover sheet (see  Figure 3) is
         attached to the confidential portion, and it is placed in the
         Confidential File.  A Confidential File log is maintained listing
         the documents  in the File, their sources, and the dates of receipt.

         Access to any  CBI is obtained through [designated S&A personnel
         responsible for controlling CBI].   In general, any S&A staff member
         with a need for the information can borrow it during  the day.
         She/he is instructed to sign the cover sheet and return the mate-
         rial before the end of the day so that it can be put  back in the
         safe.   The material can be kept for longer periods, if the bor-
         rower has an adequate storage facility available.

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                                     18
                                  FIGURE 2
                  AUTHORITY AND CONFIDENTIALITY PROVISIONS
AUTHORITY
This request for information is made under authority provided by Sec-
tion 308 of the Clean Water Act, 33 U.S.C. 1318;  Section 114 of the Clean
Air Act, 42 U.S.C. 7414;  and Section 3007 of the  Resource Conservation
and Recovery Act, 42 U.S.C. 6927.

Section 308 provides that:  "Whenever required to carry out the objective
of this Act,....the Administrator shall require the owner or operator of
any point source to establish and maintain such records, make such reports,
...and provide such other information as he may reasonably require; and the
Administrator or his authorized representative, upon presentation of his
credentials, shall have a right of entry to...any premises in which an
effluent source is located or in which any records...are located, and may
at reasonable times have access to and copy any records...and sample any
effluents...."

Section 114 states:  "For the purpose...of carrying out any provision of
this Act...the Administrator may require any person who owns or operates
any emission source...to establish and maintain such records, make such
reports,...and provide such other information, as he may reasonably require;
and the Administrator or his authorized representative, upon presentation
of his credentials, shall have a right of access  to...any premises of such
person or in which any records...are located, and may at reasonable times
have access to and copy any records...and sample  any emissions...."

Section 3007 states:  "For purposes of...enforcing the provisions of this
title, any person who generates, stores, treats,  transports, disposes of,
or otherwise handles or has handled hazardous wastes shall, upon request
of any officer, employee or representative of the Environmental Protection
Agency,...furnish information relating to such wastes and permit such person
at all reasonable times to have access to, and copy all records relating to
such wastes.  [Such officers, employees or representatives are authorized—

     "(1) to enter at reasonable times any establishment or other place
     where hazardous wastes are or have been generated, stored, treated
     disposed of, or transported from;

     "(2) to inspect and obtain samples from any person of any such wastes
     and samples of any containers or labeling for such wastes."

CONFIDENTIALITY

Information may not be withheld from the Administrator or his authorized re-
presentative because it is confidential.  However, when requested to do so,
the Administrator is required to consider information to be confidential and
to treat it accordingly, if disclosure would divulge methods or processes
entitled to protection as trade secrets.  EPA regulations concerning confi-
dentiality of business information are contained in 40 CFR Part 2, Subpart B.

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                                     19

FIGURE 2 (Continued)
These regulations provide that a business may, if it desires, assert a
business confidentiality claim covering part or all of the information
furnished to EPA.  The manner of asserting such claims is specified in
40 CFR 2.203(b).  Information covered by such a claim will be treated by
the Agency in accordance with the procedures set forth in the Subpart B
regulations.  In the event that a request is made for release of inform-
ation covered by a claim of confidentiality or the Agency otherwise decides
to make a determination whether or not such information is entitled to con-
fidential treatment, notice will be provided to the business which furn-
ished the information.  However, if no claim of confidentiality is made
when information is furnished to EPA, the information may be made available
to the public without notice to the business.

Effluent data (as defined in 40 CFR 2.302(a)(2)) and emission data (as de-
fined in 40 CFR 2.301(a)(2)) may not be considered by EPA as confidential.
In addition, any information may be disclosed to other officers, employees
or authorized representatives of the United States concerned with carrying
out the provisions of the Clean Water Act, the Clean Air Act, or the Re-
source Conservation and Recovery Act or when relevant in any proceedings
under these Acts.

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                                     20

                                  FIGURE 3
                          CONFIDENTIAL COVER SHEET

INFORMATION RECEIVED BY:                             DATE RECEIVED
                               DO NOT DETACH
                                                    Facility and Permit No.

                      ENVIRONMENTAL PROTECTION AGENCY

                   PRIVILEGED INFORMATION CONTROL RECORD

An assertion by the submitter, or a determination by U.S.  EPA, of confiden-
tiality has been made for the attached information.  It is to be considered
privileged information.   This information must be severely restricted in its
dissemination, and may be made available only to those Environmental Protec-
tion Agency officials with a valid need for it.  See 40 CFR Part 2.   All
persons reviewing this information must sign below.

INFORMATION REFERRED TO:

           NAME                         SIGNATURE                  DATE
Unauthorized disclosure of the attached information may be punishable by
$1,000.00 fine or imprisonment of not more than one year, or both, and
removal from office of employment.  (18 USC 1905)

                               DO NOT DETACH

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                                     21

2.2.5    DISTRIBUTION OR DISCLOSURE OF CBI

         Distribution of information claimed confidential is restricted
         as much as possible.  Whenever access to any CBI is requested by
         any person outside the Division, the Chief of the Enforcement
         Legal Section most closely related to the work that generated
         the CBI should be consulted.  In general, the following proce-
         dures are followed:

             Contractors are allowed access to CBI needed for their
             work on an Agency contract, if they have signed the neces-
             sary agreement with U.S. EPA (see 41 CFR 15-7.350.1 and 2).

             States are allowed access, if it has been determined form-
             ally that they have procedures equivalent to the Agency's.

             If access to confidential information is requested by a
             member of the public, a formal determination must be
             made by ORC whether the requested material is entitled
             to protection as confidential.  The submitting industry
             is notified and allowed to present its arguments at that
             time.  Normally, a formal determination never is made
             unless there is a request for release — or unless U.S.
             EPA desires to release the information.

         If it is necessary to send confidential material to an Agency
         staff member or other authorized person, the item is first placed
         in a sealed envelope bearing the name and addressee together with
         the words:  "Privileged Information—To Be Opened by Addressee
         Only."  This envelope is then placed inside  another envelope
         bearing only the name and address.  The item is then mailed by
         Certified Mail.   Return Receipt Requested.

2.3      S&A PROJECT LEADER RESPONSIBILITIES

         An S&A Project Leader will be assigned to each work request (i.e.,
         inspection, sampling survey, technical review, etc.).  Assignments
         are made generally on a case-by-case basis,  considering the com-
         plexity of the project, expertise required and employee workload.
         Project Leader responsibilities include:

          1.  Overall responsibilities for accomplishment of the assigned
              work request and assuring that the agreed upon project
              objectives are met.

          2.  Serve as the primary S&A contact to the client,  facility and
              media for all matters pertaining to the project, to answer
              questions,  resolve problems, etc., within existing policy
              and procedures.

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                            22

 3.   Receiving and reviewing the assigned work request, and as
     appropriate,  negotiating the project objective and scope
     with the client.

 4.   Obtaining and reviewing background information pertinent to
     the project.

 5.   Formulating a study plan and schedule in conformance with
     the project objective and assigned priority in consultation
     with the field support team, laboratory, QAO (non-routine
     projects in accordance with the Region V QAO Implementation
     Plan),  and others as appropriate.

 6.   Leading/coordinating all discussions/negotiations with the
     client  regarding  the study plan, including obtaining the
     clients concurrence with the study plan.

 7.   Preparing analysis request form(s).

 8.   Making  modifications to the study plan during the conduct of
     the project when  unforeseen circumstances arise or based on
     on-site findings.

 9.   Apprising client  of project status, including problems
     encountered.

10.   Assuring proper and timely notification of state and/or
     local agencies and others as appropriate.

11.   Tracking and reporting on S&A resources expanded on the
     project.

12.   Assuring proper handling of confidential information/
     documents.

13.   Overall responsibility for project document control and
     chain-of-custody.

14.   Preparation of the project report, including coordinating
     the preparation of individual reports by project partici-
     pants.

15.   Assuring the proper release of data and the project report.
     No data or reports are released without the knowledge and
     concurrence of the Project Leader.

16.   Initiating follow-up with the client after project comple-
     tion to stay informed of client action on the completed
     project.

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                                     23

2.3.1    PROJECT PLANS - ROUTINE SURVEYS

         The Project Leader is responsible for conducting routine/simple
         surveys or inspections to the extent that procedures, previously
         defined by the District Offices, are followed.  These routine
         surveys/inspections do not require special project plans in that
         the same defined procedures (often mandated by regulation) are
         used on a. regular, recurring basis.

2.3.2    PROJECT PLANS - MAJOR OR SPECIAL SURVEYS

         The Project Leader is responsible for preparing the project plan
         for major surveys.  This involves obtaining the necessary inputs
         from the client(s) (Divisions or States), all affected S&A
         Branches, and the safety officer.  When appropriate, a draft
         plan (stamped DRAFT REPORT FOR AGENCY REVIEW ONLY, DO NOT DUPLI-
         CATE) will be provided for internal review to all involved Branch
         Chiefs, client(s), and project participants.  The Project Leader
         is responsible for disseminating the draft project plan for re-
         view.  After comments have been incorporated into the final pro-
         ject plan, a revised copy will be sent to the requestor.  As a
         general rule, the final plan should be sent to the client(s) and
         given to project participants at least two weeks before any field
         work begins.  The project plan will detail field and sampling
         procedures to be used in accordance with established procedures.

         A briefing on the plan will be held prior to beginning any field
         work.  At that time, those aspects of the study such as test
         methods, chain-of-custody procedures, legal aspects, safety re-
         quirements, document control and related activities will be dis-
         cussed with all participants in the project, who are expected
         to read the project plan and be aware of the required procedures.

2.3.3    ADMINISTRATIVE MATTERS

2.3.3.1  PROCUREMENT REQUESTS

         Prior to the survey, the respective S&A Branches are expected to
         submit purchase requisitions for survey needs in a timely fashion
         to avoid emergency requests.  The Project Leader, Field Support
         Team, is responsible for determining travel advance needs for the
         study and designating those individuals who will receive travel
         advances.  When appropriate, the Project Leader will arrange to
         use purchase orders in the field.  For example, ice is often re-
         quired in large quantities during a survey; thus, a purchase re-
         quisition is often appropriate.

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                                     24

2.3.3.2  TIME KEEPING

         The Project Leader, Field Support Team, is expected to certify as
         correct the Time Reports used by field personnel to report regular
         time, overtime, and compensatory hours.  It is expected that Pro-
         ject Leaders and Branch Chiefs be familiar with the Fair Labor
         Standards Act, the EPA Pay Administration Manual and Region V
         Orders as they pertain to overtime,  holiday and hazardous-duty
         pay, and compensatory hours.  As appropriate, the Project Leader
         will be provided a packet containing the necessary pay manuals,
         policy statements, and forms.  Instructions for the completion
         and submission of time records will  be provided by the respective
         Branch Chiefs.

2.3.4    FIELD ACTIVITIES

         The Project Leader, Field Support Team, shall have the overall
         responsibility for determining that  all field activities are per-
         formed expeditiously and that the project objectives are met.
         Branch Chiefs are expected to assign personnel capable of perform-
         ing the Branch responsibility associated with a particular study;
         these personnel are expected to understand and follow the pro-
         cedures relative to their assignments.

         Changes from the project plan not affecting the objectives or
         overall scope of the study	such as addition or deletion of
         sampling points; modifications to schedules or frequencies; or
         changes in analytical load	will be coordinated through and
         approved by the Project Leader.  This includes any support work
         being conducted by individuals and S&A organizations participat-
         ing in the study.

         Transportation needs in the field will be determined during the
         planning stage.  GSA vehicles will be used whenever available.
         The Project Leader, Field Support Team, will be responsible for
         assuring that vehicles and mobile laboratories transported from
         the appropriate duty location will generally travel in convoy.
         It is imperative that the Project Leader be notified immediately
         of any delays that occur enroute.  It is also expected that the
         rolling stock (mobile laboratories,  vehicles, boats, monitoring
         equipment) are kept in a state of readiness.  If equipment is
         returned from the field needing repair, maintenance or overhaul,
         it shall be accomplished expeditiously by the appropriate Branch.

         During the field study, the Project  Leader, Field Support Team,
         is responsible for seeing that all Chain-of-Custody and quality
         control procedures for sampling, flow monitoring, analyses,
         record keeping, etc. are followed.  The field personnel are,

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                                     25

         however, expected to understand and follow the custody procedures
         relative to their assignments.  Following completion of the field
         activities and before returning to the duty station, the Project
         Leader or designee shall account for all field documentation	
         such as field logbooks, sample tags, Chain-of-Custody records	
         and verify that it is complete.

         The Project Leader is responsible and has the authority for assur-
         ing that all field work is conducted safely, and that required
         safety equipment is used.  All participants are required to read
         and adhere to the Region V SAFETY MANUAL.

2.3.5    REPORT WRITING

         The Project Leader, in cooperation with other personnel, will
         develop an outline and determine the writing assignments for a pro-
         ject report.  The Project Leader is responsible for assembling the
         report and as appropriate circulating review copies which will be
         numbered and stamped DRAFT REPORT FOR AGENCY REVIEW ONLY, DO NOT
         DUPLICATE.  The Project Leader, shall make every attempt to ensure
         that all draft copies are returned, and that all appropriate com-
         ments are incorporated.  These draft reports are disposed of upon
         completion of the final report.  In preparing reports, the quality
         of and the ability to substantiate and defend the contents are
         foremost.  The Project Leader, S&A management and supervisory per-
         sonnel are responsible for assuring that all S&A reports achieve
         this goal.

2.4      S&AD TRACKING OF RESOURCES & COMMITMENTS

2.4.1    DISCUSSION

         The S&AD will utilize a computer program to track resources usage
         and commitment status.  The program involved will basically gen-
         erate a program format based on allocated resources and attendant
         S&A commitments on a decision unit and sub-decision unit work item
         basis.  This form will be distributed during the planning process
         for each Branch to enter its commitments based on allocated re-
         sources (distribution of resources by S&AD Director) as a part of
         the S&AD commitments for the respective programs, shown for each
         decision unit.  In this fashion,  all S&AD offices will be tracking
         uniformly identified work items.   The program will be able to
         generate summary S&AD Director reports summarizing the usage of
         total resources and commitment status for all respective decision
         units across all offices in the S&AD; generate reports for each
         individual office providing summarized resources usage and commit-
         ment status for each decision unit;  and provide for a comments
         section to add comments regarding entry items, etc.

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                                     26

2.4.2    S&AD TRACKING PROGRAM ENTRY REQUIREMENTS

         The operation of the S&AD tracking report will require each branch
         office,  reporting on a weekly or less frequent basis to enter work
         items completed by the sub-decision units of planned work and the
         resources required to complete each unit of attendant work.  (This
         entry will be accomplished by filling out standard work sheet docu-
         ments.   The information will be entered by the district offices,
         EDO and  CDO by remote terminal.  The program's design allows for
         standard work load factor (time factor) to be loaded for each de-
         cision unit sub-unit work item on a T, +T, or -T basis, i.e., if
         work item is within the loaded T'factor, the computer will make
         all further calculation transactions; if it took more time to do
         the survey, merely enter the extra time (+T) and the computer will
         add the  two times [(standard time) + (the addition time)]  to get
         the total time involved.  Surveys requiring less time than T1 will
         only require the -T entry and the computer will complete the trans-
         action.

2.4.3    OUTPUTS

         The S&AD resources and tracking report will provide a summary of
         decision units individually or across all offices at the division
         director level on demand.  The program will provide each S&AD
         office with a sumamrized decision unit report for each sub-decision
         unit item of planned work.  These summaries will itemize both com-
         mitment  and resource status.  Figures 4 and 5 are examples (using
         hypothetical information) of the formated report for sub-decision
         unit items of work for all offices...Figure 2 represents initially
         loading  the programs for the units of work displayed.  The first
         entry of completed work is described in Figure 3.

         A decision unit is a budgetary tool used to discribe mutually ex-
         clusive  discreet types of work.  The S&A Division performs work
         under numberous decision units.  A complete listing of the Agency's
         decision units are listed below:

DECISION    PROGRAM
UNIT
A230
A235
A305
ELEMENT
A20A2D
A23A2F
A25A3A
TITLE
Air Quality Management Implementation
Ambient Air Quality Monitoring
Stationary Source Enforcement
  B203      A41B2A     Water Quality—State Program Regs, and Guidelines

  B209      A52B2D     Dredge and Fill

-------
                                     27
DECISION
  UNIT
PROGRAM
ELEMENT
TITLE
            A7XB2A     Standards and Regs.

  B212      A51B2D     Environmental Emergency Response and Prevention

  B224      A53B2F     Ambient Water Quality Monitoring

  B230      A54B2G     Municipal Waste Treatment Fac. Construction

            A56B2G     Waste Treatment Facility Operation and Maintenance

            A7VB2G     NEPA Compliance—EIS Prep. Mun. Fac. Construction

  B241      A42B2A     Great Lakes Program

  B303      A59B3A     Water Quality Enforcement

  B306      A59B3A     Permit Issuance

  C215      A70C2D     Water Supply—Public Systems Supervision

  C220      A71C2D     Underground Injection Control

  C305      A72C3A     Drinking Water Enforcement

  D310      A80D2D     Hazardous Waste Reg. Strategy Implementation

  E240      A96E2P     Pesticides Use Management

  E305      A97E3A     Pesticides Enforcement

  F210      A1DF2D     Radiation Program Implementation

  H210      A1PH2A     Interdisciplinary EIS Review

  L305      A2FL3A     Toxic Substances Enforcement

  R348      A2XT5A     Regional Counsel

  R503      A3XT5A     Policy Direction

  R533      A3YT5A     Planning, Evaluation, and Analysis

  R536      A3ZT5A     Financial Management

  R572      A4AT5A     Personnel Management

  R577      A4BT5A     Administrative Management

-------
                                   28




SUPERFUND APPROPRIATION




Y510      TENY5A     Hazardous Substances Financial Management




Y520      TETY5A     Hazardous Substances Administrative Management




Y530      TEYY5A     Hazardous Substances Legal Services




Y305      TEZY3A     Hazardous Substances Response and Enforcement




Y905      TFAY9A     Hazardous Substances Spill and Site Response

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                            29
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-------
                                      31

2.5      S&A DIVISION SAFETY PROGRAM

2.5.1    SAFETY POLICY STATEMENT

         The S&A Division has the responsibility to provide a safety pro-
         gram that will insure the protection and well being of all field,
         laboratory and office personnel within the Division.  It must be
         understood that safety rules cannot be developed to cover every
         situation that could arise.  Therefore, each employee must use a
         high degree of common sense, practical judgement, and personal
         experience in order to maintain a high level of safety conscious-
         ness.

         An S&A Division Safety Manual which covers overall safety proce-
         dures  for the Division along with a Central Regional Laboratory
         Safety Manual and Eastern District Office laboratory safety pro-
         cedures are available to employees.  It is mandatory that each
         employee involved in field and/or laboratory work read these
         documents and apply the policies and procedures contained therein.
         Office personnel should also become familiar with general office
         safety requirements.

         First-line supervisors are responsible for maintaining a strong
         and highly visible safety program within the unit they supervise.
         Thus responsibility includes ensuring that proper equipment is
         available and supplies are maintained, that offices and work areas
         are kept clean and orderly and that employees are adequately
         trained.  If safety rules are violated, supervisors are respons-
         ible to see that appropriate corrective and/or disciplinary action
         is taken.

         Periodic unannounced safety inspections will be conducted to deter-
         mine if employees are conforming to the requirements of the safety
         manuals.

2.5.2    EMERGENCIES

         There  are three kinds of emergency situations each person should be
         prepared for.   These are:  (a)  fire, (b)  accident, (c) sudden
         illness.

         In the event of an accident,  or illness,  the first person on the
         scene  should:

         a.  Call the building first aid center (3-0307) if the accident is
             not obviously very serious.   Call the Fire Department (911) if
             the accident will require immediate emergency treatment.

-------
                                      32

         b.   Stay with the victim and provide assistance until the PHS nurse
             or rescue squad arrives.

         c.   Advise the supervisor and safety officer of the accident and
             related circumstances.

         The accident victim's  supervisor should complete Form 1440-9 and
         Form CA-1 or CA-2.   Copies  of the forms should be sent to the
         offices described on the different colored forms.  Both forms are
         available from Max Anderson (6-6228) S&A Division Safety Officer.
         The Westlake Fire Department is 871-3322.

         a.   In the event of fire alarm sounds:   All personnel should leave
             the building immediately and assemble in an area away from the
             building.  Each supervisor should account for all assigned
             employees.

         b.   If you observe a small  fire, and no alarm has sounded, use a
             fire extinguisher  and extinguish the fire.  If the fire is too
             large to be extinguished quickly, sound the fire alarm and
             evacuate the building.

2.5.3   'OFFICE SAFETY REQUIREMENTS

         1.   General Housekeeping

             a.  Passage ways,  exits and elevator lobbies should always be
                 kept clear at  all times to allow free passage of personnel
                 and fire-fighting equipment.

             b.  Desks and individual work areas including tops of radi-
                 ators, filing  cabinets, book cases and window sills should
                 be kept free of excess paper, publications and all other
                 unnecessary materials.  Each employee will be held re-
                 sponsible to keep their respective areas clean and neat
                 looking.  If it's not needed, recycle it.

             c.  Electrical extension cords should not be used without
                 approval of the supervisor.  Cords should not extend
                 across walkways (unless properly covered) or any other
                 areas that would create a potential hazard.  No more
                 than one electrical cord should be used per wall socket.

             d.  Coffee pots and other small appliances must have a pilot
                 light to indicate usage and should be unplugged at the
                 close of each work day.  The Division's Safety Officer
                 will make inspections to ensure this is being done.  Only
                 those appliances that are approved by Underwriters' Labor-
                 atory and installed in accordance with local fire codes
                 and building manager's approval shall be used.

-------
                                      33

             e.  "No Smoking" and all other safety signs should be observed
                 and obeyed.

2.5.4    SELF-PROTECTION PLAN

         The Self-Protection Plan for the S&A Division is posted in the
         10th floor lunch room.   All employees should become familiar with
         this plan.

         Self-Protection Plans for the 536 South Clark Street Building and
         the Westlake,  Ohio Building are available from the Section or
         Office Safety Committee Members.

         The Safety Committee Members are:

             Max Anderson - S&A Division Safety Officer
             Phyllis Reed/Syl Bernatos - Central District Office
             Curtis Ross/Chick Steiner - Central Regional Laboratory
             Bud Burge - Eastern District Office

2.5.5    FIELD AND LABORATORY SAFETY

         Procedures for S&A Division field and laboratory safety are out-
         lined in three documents:  (1) Surveillance and Analysis Division,
         Region V Safety Manual, (2) Central Regional Laboratory Safety
         Manual, and (3) Eastern District Office's Safety Policies & Pro-
         cedures.  In order to minimize accidents and injuries it is
         mandatory that all field and laboratory personnel become familiar
         with the procedures  set forth in these documents.

2.5.6    MEDICAL MONITORING PROGRAM

         The medical program is  designed basically for laboratory and field
         workers whose work regularly poses the possibility of exposure to
         toxic materials.   In addition, the program should meet the needs
         of other diverse groups of employees whose jobs require periodic
         health assessment.  Generally, administrative, fiscal, secretarial,
         statistical, and other  support personnel who are exposed to toxic
         materials indirectly, infrequently, or inconsequentially should
         not be included.   Representative job categories that should have
         medical monitoring made available on exposure include chemists,
         microbiologists,  toxicologists, physical scientists, and the tech-
         nical personnel who  support these disciplines.  Employees who
         collect various types of polluted samples should be included if
         the sampling requires exposure to pollutants significantly in
         excess of ambient concentrations, as should those who perform
         custodial services in actual laboratories or in areas where toxic

-------
                                      34

         materials are stored.   Part-time and temporary employees should
         be included if their jobs  are similar to the categories previously
         mentioned.  The decision as to which employees are nominated
         should rest with the program director or supervisor most familiar
         with the possible hazards  involved.

         As more Federal regulations and recommendations appear for em-
         ployees potentially exposed to toxic chemical and physical agents,
         program updates and modifications are to be expected.   When such
         changes occur, they will be presented by the Agency's  Office of
         Occupational Health and Safety.

         More detailed information  on the Medical Monitoring program can be
         obtained from the Division Safety Officer for those employees who
         are interested.

3.        SAMPLE HANDLING AND CUSTODY PROCEDURES

3.1      INTRODUCTION

         As in any other litigation, EPA must be able to prove  that any
         analytical data offered into evidence in a court of law accurately
         represents environmental conditions  existing at the time of sample
         collection.  This implies  that it can be clearly demonstrated that
         none of the involved samples could possibly have been  tampered with
         during collection, transfer, storage or analysis.  Therefore, an
         accurate written record must be maintained to trace the possession
         of each sample from the moment of its collection through its intro-
         duction into evidence.   Samples for  which this accurate documenta-
         tion is maintained are  called custody samples.

         Since the S&A performs  the same basic sample handling  operations
         on both known litigation and non-litigation samples all samples
         collected by the S&A will  be collected and handled accordingly to
         the standard custody procedures.  All samples, except  GLNPO
         samples - collected by  other than S&A staff, will be placed into
         the standard custody procedure upon  sample reception by the first
         S&A staff receiving the subject samples.

3.2      SAMPLE CONTROL/HOLDING  PROCEDURES

         A sample is physical evidence collected from a facility and/or
         from environmental components.  An essential part of all enforce-
         ment investigations is  that evidence collected be controlled.  To
         accomplish this, standard  operation  procedures for sample handling
         and chain-of-custody have  been developed.  Accordingly, these pro-
         cedures shall be utilized  for all sampling situations  and sample
         types (parameters and preservative types) carried out  by the S&A
         staff.

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                             35

Facility and/or environmental samples may represent several media/
matrices or mixed media/matrices types; e.g., water, fish, sedi-
ment, air, soil, oil, oil and water, etc.  Some of the desired
measurement parameters may be completed in the field (e.g., pH,
temperature, flow measurement, continuous air monitoring, stack
gas analysis, etc.).  All field measurements will be recorded (in
the field at the time of measurement) directly in serialized Field
Logbooks or on field data record forms.  (Field Data Record Sheet
Form RV 3460.1, and example sheet from the Field Logbook are shown
as Figures 6 and 7).

Samples other than the in-sites and in-field measurements will be
identified by the National Standard format tags (see Figure 8)
with all information filled out as appropriate and indicated.

These samples are removed from the sample location and transported
to a laboratory or other location for analysis under proper pre-
servation and shipping procedures.  Before removal, however, a
sample is often separated into portions depending upon the analyses
to be performed.  Each portion is preserved in accordance with
applicable procedures and the sample container is identified by a
sample tag.  Sample tags shall be completed for each sample, using
waterproof ink unless prohibited by weather conditions.  For
example, a logbook notation would explain that a pencil was used
to fill out the sample tag because a ballpoint pen would not
function in freezing weather.   The information recorded on the
sample tag would include:

Project Code     -  A number assigned by S&A and also serves as
                    the Document Control number for the survey.

Station Number   -  A number assigned by the Project Leader -
                    using the CRL Log Number system.

Date             -  A number indicating the year, month, and day
                    of collection.

Time             -  A four digit number (XXXX) indicating the
                    military time of collection - for example:
                    0954.

Station Location -  The sampling station description, as specified
                    in the project plan.

Samplers         -  Each sampler signs.

Tag Number       -  A unique serial number is stamped on each tag.

Remarks          -  The samplers record pertinent observations and
                    sample type; i.e.,  water, sediment, fish, etc.

-------
                                         36
                               FIGURE 6   REGION V FIELD DATA RECORD SHEET

                                       UMTED STATES
                            ENVIRONMENTAL PROTECTION AGENCY
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                                    CMeago. Wnols 60608
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-------
                                            37
                             FIGURE 7   EXAMPLE  SHEET  FROM FIELD LOGBOOK

                                        UNITED STATES
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                    - '38
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ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
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                             39

Referencing the example sheet of the Field Logbook, see Figures
6 and 7, the responsible field staff will enter both formated in-
formation (required entries) and observational information (judge-
mental data).  The Field Logbook will be serially numbered and
unique to each survey/project.

During collection, separation, identification, and preservation,
all samples will be maintained under Chain-of-Custody procedures
discussed later.  If the composite or grab sample is to be split,
it is aliquoted into similar sample containers.  Identical sample
tags are completed and attached to each replicate and marked with
a "D" in the sample number.  The tag identifies the replicate
sample for the appropriate government agency, facility, laboratory,
or company.  In a similar fashion, all tags on blank or duplicate
samples will be marked with an "R" or a "D", respectively.  An
explanation of the numbering system is detailed below.

The sample type letter is used to identify quality assurance and
other sample types.  The following letters are fixed and are to be
used only as specified:

                         S = Sample
        D = Duplicate Sample (two samples collected)
         A = Duplicate Analysis (one sample split)
              L = Laboratory Control Standard
                 R = Reagent Blank (Field)
               B = Reagent Blank (Laboratory)

All other letters may be used as the Project Officer wishes, after
clearing with the CRL Sample Custodian.

The sample numbers should be assigned in numerical order to all
samples collected during the specified survey.  If more than 99
samples are collected during a given survey, a new survey number
should be used as required to uniquely identify all samples.
Quality Assurance samples should receive unique numbers with
duplicates being always for the preceeding sample.

Additional examples are given below to further explain the system.

Sample number "AM01S01"

Where:   A = Air Surveillance Branch
         M = Charles Miller
        01 = Miller's first survey in FY-78
         S = Sample
        01 = First sample collected for Project 01

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                                      40

         Sample Number "AM02Z37"

         Where:   A = Air Surveillance Branch
                  M = Charles  Miller
                 02 = Miller's second  survey  in FY'78
                  Z = Sample  from Site "Z"*
                 37 = The 37th sample  from Project  02

                 *The use of  the  letter Z  to  specify a  site  had  been
                 approved by  the  CRL for the  O'Hare Study.

         Sample Number "AM02A38"

         Where:   A = Air Surveillance Branch
                  M = Charles  Miller
                 02 = Miller's second  survey  in FY'78
                  A = A duplicate analysis of Sample Number  AM02S37
                 38 = The 38th sample  in Project 02

         Sample Number "AM02D39"

         Where:   A = Air Surveillance Branch
                  M = Charles  Miller
                 02 = Miller's second  survey  in FY'78
                  D = A duplicate sample of Sample  Number AM02A38
                      (or AM02S37)
                 39 = The 39th sample  in Project 02

         During the time that  the environmental samples are  collected,  the
         proper aliquots are  prepared  and  properly  preserved,  an analysis
         request sheet is completed, commensurate with  the desired para-
         meters for each discrete aliquot. The analysis request forms
         should have parameters listed that match with  the parameters
         checked off on each  sample tag, on each sample aliquot.  (In the
         future, the CRL will  generate the analysis request  sheet  by  com-
         puter.)  Most sample  data will be entered  onto these  analysis
         request sheets by the CRL and returned to  the  data  user.

         All field collected  samples requiring shipment from the field  to
         an EPA laboratory or to  a centralized location, and/or  shipment to
         a contractor's laboratory will be shipped  in compliance with all
         applicable D.O.T. regulations, preservation  requirements, and  EPA
         safety requirements.   An overview of these procedures are listed
         below:

3.2.1    PROCEDURE FOR HAZARDOUS  AND NON-HAZARDOUS
         WATER AND SEDIMENT SAMPLES

         These samples generally  are collected in one  (1) pint,  one (1)
         quart, one (1) gallon, or two and one-half (2  1/2)  gallon glass
         containers.

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                                      41

         Forty-eight (48) or 76 quart capacity plastic picnic coolers
         should be used to ship the samples.

         Samples are placed in the picnic cooler in an upright position
         and separated by styrofoam sheets of 1" X 3" thickness.  Alter-
         nately, cardboard sections are placed in a manner so as to keep
         the glass sample bottles from "banging up" against each other,
         both sideways and from the top and bottom.

         After the styrofoam or cardboard is placed in the picnic cooler,
         additional packaging material consisting of "peanut", "popcorn"
         absorbents or "bubble" plastic sheets are used to further cushion
         and compact the cooler so that movement is minimized.

         Volatile organic samples (40 ml VGA vials) are wrapped in the
         "bubble" plastic sheets and placed in one corner of the picnic
         cooler to prevent breakage and leakage.  Paperwork to be shipped
         with the samples is placed in a plastic ziplock bag and sealed
         with tape.  Liberal portions of ice, crushed or cubed, are added
         to fill the cooler and a cardboard sheet placed over the ice and
         the picnic cooler is sealed.  The cardboard serves to prevent
         breakage if the cooler is dropped, either in an upright or upside
         down position.  D.O.T. regulations require packaging to withstand
         a four foot (4') fall.  The above packaging methods achieve this
         requirement.  The picnic cooler is sealed with filament tape com-
         pletely around all edges and the custody seal is placed on both
         sides of the cooler and taped once so that when the picnic cooler
         is received, the receiver can readily check to see if the seal has
         been tampered with.

         On the outside of the chest, a sticker indicating "THIS SIDE UP",
         "WATER SAMPLES", "FLAMMABLE" or "HAZARDOUS MATERIALS", "GLASS", or
         "FRAGILE" will be attached to the sides and top of the cooler (to
         assure that any warning notice can be clearly recognized by the
         courier).

         When shipping hazardous samples, a "HAZARDOUS MATERIALS SHIPPERS
         CERTIFICATE" and an address label must be attached to the top of
         the picnic cooler (these latter procedures apply to Federal Express
         shipments only).  All of the former  procedures mentioned above
         apply to Purolator Courier and Federal Express Courier.  (The CRL
         presently does not use United Parcel Service.)

3.2.2    PROCEDURE FOR PACKAGING AND SHIPMENT OF FISH SAMPLES

         Samples are packaged in a "freezer-safe" cardboard box equipped
         with a styrofoam-lined box inside of the big box.  The samples
         are first wrapped twice in aluminum  foil, so as to retain all

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                                      42

         fluids, and then placed in a teflon bag.   "Peanut or popcorn"
         packaging material (approximately one-to-two inches (l"-2") high
         is added to the box and the fish samples  are placed on top of the
         packing material.   Packaging material is  added so as to completely
         cover the samples, but enough room must be left to allow placement
         of ten pounds (10  Ibs.) of dry ice wrapped in newspaper (or brown
         packing paper) into the box.  A styrofoam top sheet is put over
         the dry ice and the box is sealed with one inch (1") filament or
         nylon tape.  Custody papers and seals are put in a plastic bag and
         attached to the top of the box.  The shipping label must indicate
         "SAMPLES PACKED IN DRY ICE", so that the  courier handling the box
         will know.

         The samples, properly packaged with all prescribed forms filled
         out are delivered  to the laboratory(s) by field staff or by mail
         delivery.  At the  laboratory, the samples will be checked for
         proper samples and custody, logged in, and dispensed to a custody
         room (refrigerator-freezer provided).  The laboratory file of
         information is considered complete when all samples are analyzed
         and the results are recorded on the analysis request forms.

         These files of original data are reviewed for completeness by the
         Office Director(s) or his designee(s) and filed in locked custody
         files in each of the S&AD offices.  A logbook is maintained in
         each office for the custody files which lists the files stored and
         the name of all persons having access to  any files, the data and
         item(s) removed at any time from the file, and the name of the
         person who removed the file.  Therefore,  all original information,
         relative to a sample or group of samples  should be available
         shortly, after a request for such information is made and the files
         should be up-to-date, complete and accurate at all times.

3.2.3    SAMPLING HANDLING  - CONTRACT LABORATORIES AND FIELD STAFF

         When practicable,  all Regional laboratory and field contracts
         managed by the S&AD will require the Contractor(s) to follow
         identical sample handling procedures as described above - any
         justifiable exception to the above shall  require the approval
         of the S&AD Director.  However, it should be noted - with parti-
         cularity - that the Agency has several national contracts for
         field investigation/sample collection and laboratory analysis
         and each of these  contracts has its own specific handling pro-
         tocol; accordingly, these specific protocols must be followed
         attendant to the contractual agreement.  In addition, all of
         Region V's handling requirements must also be met.  Prior to
         establishing analytical or field investigation/sampling con-
         tracts, CRL staff  person(s) responsible for coordinating con-
         tract analytical work should be contacted for specifics.
         General guidelines are listed below:

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                                      43

         1.   Both U.S.  EPA and Contractors will use the National
             Standard Sample Tag and the National Standard Custody
             form - other specific field and tracking forms and as
             required by the contract.

         2.   All samples to be shipped will follow the Standard Re-
             gional/D.O.T. requirements as defined under Shipping
             Procedures.

         3.   All samples shipped to Region V contracted laboratories
             for analyses will be accompanied by the tracking form,
             with distribution made as shown on the form.

         4.   Samples to be collected by the FIT"s Contractor or U.S.
             EPA Region V staff for analysis by the VIAR Contractor
             will follow specific protocol.  All forms and procedures
             must follow the required order and sequences or the
             associated samples will be discarded.

3.3      CHAIN OF CUSTODY PROCEDURES

         Due to the known or potential evidential nature of samples col-
         lected during environmental investigations, possession must be
         traceable from the time the samples are collected until they are
         introduced as evidence in legal proceedings—it shall be the
         policy in U.S. EPA's Region V S&AD to collect all samples under
         the standard custody procedures.   In addition, it shall be policy
         to place all non-custody samples (except GLNPO samples) collected
         by samplers outside the S&AD under the standard custody procedures
         upon reception by S&AD staff (any exception to this policy shall
         require a case-by-case review and concurrence by the S&AD Director
         before the fact or as soon as reasonably possible after the fact).

         Sample custody is initiated at the time of sample collection by
         fixing a numbered custody seal to each sample taken or by placing
         the sample in a locked container or into a container which is
         sealed with a custody seal.  The custody form is also, immediately
         filled out and signed by the person collecting the sample.  It is
         the responsibility of the sampler to ensure that the sample and
         sample descriptive forms are in custody (locked or properly sealed
         to prevent tampering) and that all descriptive information is
         accurate and complete.  Each individual who subsequently signs
         the custody form has a similar responsibility and, in addition,
         must ensure that all information added to the sample descriptive
         forms is also complete and accurate.  This process is documented
         by the use of the Standard National Chain of Custody Record form
         (see Figure 9).  The Chain of Custody Record forms are serially
         numbered (forms are accountable)  and provides an original for
         accompanying the associated samples and a copy for the field
         records.

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                                                        44
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                                      45

3.3.1    SAMPLE CUSTODY

         By definition, a sample is under custody if:

         1.  It is in your possession or

         2.  It is in your view, after being in your possession or

         3.  It was in your possession and then you locked it up to
             prevent tampering or

         4.  It is in a designated secure area.

3.3.2    FIELD CUSTODY PROCEDURES

         1.  In collecting samples for evidence, collect only that number
             which provides a good representation of the media being
             sampled.  To the extent possible, the quantity and types of
             samples and sample locations are determined prior to the
             actual field work.  As few people as possible should handle
             the samples.

         2.  The field sampler is personally responsible for the care and
             custody of the samples collected until they are transferred
             or dispatched properly.

         3.  Sample tags shall be completed for each sample using water-
             proof ink, unless prohibited by weather conditions.  For
             example, a logbook notation would explain that a pencil was
             used to fill out the sample tag because a ballpoint pen would
             not function in freezing weather.

         4.  The Project Leader determines whether proper custody procedures
             were followed during the field work and decides if additional
             samples are required.

3.3.3    TRANSFER OF CUSTODY AND SHIPMENT

         1.  Samples are accompanied by a Chain-of-Custody Record.  When
             transferring the possession of samples, the individuals re-
             linquishing and receiving will sign, date, and note the time
             on the record.  This record documents sample custody transfer
             from the sampler, often through other persons, to the analyst
             and subsequently, sample storage in a custody room (if appro-
             priate) .

         2.  Samples will be packaged properly for shipment and dispatched
             to the appropriate laboratory for analysis, with a separate
             custody record accompanying each shipment (each ice chest).

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                                      46

             Shipping containers  will be padlocked or sealed for shipment
             to the laboratory.   The method of shipment,  courier name(s),
             and other pertinent  information,  is entered  in the "Remarks"
             section.  (The general  and specific procedures for shipping
             are described under  "Shipping Procedures"  of the document.)

         3.   Whenever samples  are split (replicated)  with a source or
             government agency, it is noted in the "Remarks" section of
             the Custody form  and in the Field Logbook.   The note indicates
             with whom the samples are being split and  signed by both the
             sampler and the recipient.  The person relinquishing the
             samples to the facility or agency should request the signature
             of a representative  of  the appropriate party, acknowledging
             receipt of the samples.  If a representative is unavailable or
             refuses to sign,  this is noted in the "Remarks" section.

         4.   All shipments will be accompanied by the Chain-of-Custody
             Record identifying its  contents.   The original record will
             accompany the shipment, and a copy will be retained by the
             Project Coordinator.

         5.   If sent by mail,  the package will be registered with return
             receipt requested.   If  sent by common carrier, a Government
             Bill of Lading will  be used.  Air Freight  shipments are sent
             collect.  Freight bills, post office receipts and Bills of
             Lading will be retained as part of the permanent documenta-
             tion (see Shipping Procedures Section).

3.3.4    FIELD CUSTODY - CONTRACTORS

         All Regional field contracts managed by the S&AD will follow the
         above custody procedure  when practical and appropriate.

         All justifiable cases requiring a variant from the above shall be
         reviewed by the S&AD  for approval.  This review shall occur before
         the fact in normal operational procedures or as  soon as possible
         after the fact for emergencies or other controlled situations.
         NOTE:  The National Standard Tag and Custody Sheets are always
         used for all sampling protocols.

3.3.5    FIELD LOGBOOK

         In addition to the sample tags, field sheets,  analysis request
         sheets, custody sheets,  and/or other contractor  required forms, a
         serially numbered bound  field logbook must be maintained by the
         Survey Leader and/or  other Field Team members (as needed) to pro-
         vide a daily record of  significant events.  In order to accommodate
         surveys of different  magnitudes field logbooks will be ordered in
         different sizes.

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                                      47

         All entries must be signed and dated.   (All members of the Survey
         Team must use either (1)  one single assigned field logbook or (2)
         a series of field logbooks assigned to specific team members.)
         The logbook(s) are kept as a permanent record - in enforcement
         cases, the logbook will become a part of the documentation file.

3.3.6    LABORATORY CHAIN-OF-CUSTODY PROCEDURE

         Due to the evidentiary nature of enforcement type samples collected
         and analyzed in the laboratory during enforcement investigations
         (active and potential), possession must be traceable from the time
         received by the laboratory until they are introduced as evidence in
         legal proceedings or ultimately disposed.  These samples include
         all samples collected by S&A staff and all samples received and/or
         analyzed by the S&A (except GLNPO samples).  To maintain and docu-
         ment sample possession in the laboratory, the following Chain-of-
         Custody Procedure shall be followed:

         A sample is under custody if:

         1.  It is in your possession or

         2.  It is in your view, after being in your possession or

         3.  It is in a secure area.

         The actual procedure shall be as follows:

         1.  There shall be designated, a Sample Custodian and Alternate
             Sample Custodian(s).   The Custodian accepts custody of the
             shipped or brought-in samples and verifies that the seal is
             intact and has not been tampered with, opens the case, reviews
             and verifies that the information on the tags are appropriate
             and that they match the information on the Field Chain-of-
             Custody Record.  Other pertinent information, as to shipment
             pickup, courier, etc., is entered in the "Remarks" section of
             the Chain-of-Custody Record.  The Chain-of-Custody Record form
             will remain in the official transfer registry within the
             laboratory.  All appropriate transfers will be entered on that
             form.  The samples will then be placed in a secured area, pre-
             ferably, a dedicated  area whose only access is the Custodian
             or Alternate Custodian (Custody Sample Storage Room).

         2.  The Custodian will assign samples  from and to his/her custody
             to the appropriate analysts.  The  names and signature of indivi-
             duals who receive samples are recorded on the Chain-of-Custody
             Record.  Laboratory personnel are  responsible for the care and

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                                      48

             custody of samples  from the time they are received until they
             are returned to the Custodian.   The sample is considered in the
             Custody of the Analyst when it  is in their possession,  site,  or
             in a secure area.   The sample will be returned to the Sample
             Custodian when the  Analyst completes the procedure.

         3.   When sample analyses and necessary quality assurance checks have
             been completed for  identified enforcement cases,  all identifying
             tags, data sheets,  and laboratory records shall be retained as
             part of the permanent documentation file.  Residual (unused)
             sample quantities will be retained in secure storage after the
             completion of analytical determinations until formal notice is
             given from Enforcement that the samples can be disposed of.

             The final date(s) of disposal will be recorded on the Chain-of-
             Custody Record by memorandum.  For all samples not identified as
             enforcement cases,  the file management will be the same as above
             except that all attendant samples shall be disposed of  after
             three (3) months of storage. Disposal date(s) shall be docu-
             mented to the documentation file by memorandum from the Sample
             Custodian.

         4.   It should be noted  - with particularity - that all of the
             National Standard Tags associated with samples must be  filed
             respectively in the appropriate survey documentation files, at
             the time the sample is disposed of or at the time of laboratory
             analysis, if all the sample volume is used during the analytical
             phases.  This requirement means that tags associated with active
             samples are never discarded by  the bench analysts or field
             staff	tags can only be discarded by procedures governing the
             documentation Control File.

3.4      PROCEDURES FOR AIR SHIPMENT OF ENVIRONMENTAL SAMPLES

         The Air Shipping procedures are applicable to hazardous samples and
         are pertinent to EPA staff shipping samples for two primary reasons:

         1.   The U.S. EPA staff  has personal responsibility to ensure that
             all shipped samples are in compliance with Department of Trans-
             portation (D.O.T.)  regulations  in 49 CFR, Parts 170-179.

         2.   The procedures, inherently, provide shipping procedures which
             significantly reduces the breakage or losage of sample during
             shipment.

         The above regulations apply to all  hazardous samples being  air-
         shipped (contractor and EPA alike).  A U.S. EPA Region V manual
         of shipping procedures  is being developed.  The manual will pro-
         vide D.O.T. Regulations, U.S. EPA Order Information and other
         recommended shipping procedures.

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                                      49

4.       DOCUMENTATION CONTROL PROGRAM

4.1      INTRODUCTION

         The goal of the Region V Document Control Program is to assure
         that all project documents issued to and/or generated by S&AD
         and other Divisions'  staff will be accountable (in legal con-
         notation) when the project is completed.   The system involves
         locating all cases affecting information in officially located
         documented files.  These files shall be capable of consolidation
         into one central file or to stand alone containing a unique single
         document control number system, per case/survey, a document in-
         ventory procedure, and an evidentiary filing system all operated
         and managed by respective document control managers.

         Accountable documents used or generated by S&AD employees include
         logbooks, field data  records, correspondence, sample tags, graph,
         Chain-of-Custody records, bench sheets and photographic prints,
         etc.  Each document bears a serialized number and document control
         number and is listed, with both numbers,  in a project document
         inventory assembled by each Branch at the project's completion.
         Unused accountable documents may be disposed of after they are re-
         turned to the document control manager.

4.1.2    REGION V DOCUMENTATION CONTROL PROGRAM DESCRIPTION

         Region V shall operate its Documentation Control Program at two
         levels, as described  below.

         1.   The District Offices will maintain a Document Control Program
             file with an appointed document control file manager — will
             receive all required field office investigation and laboratory
             data.  Active enforcement Document Control files will be for-
             warded to the appropriate enforcement office for maintenance.
             Non-enforcement cases will be maintained by the District
             Offices'  Document Control Program files for a period of at
             least five years  . . . this file will be designated as the
             D.O.  Branch Documentation Control File.

         2.   The Central Regional Laboratory will  maintain a Document Con-
             trol Program file with an appointed document control file
             manager — will receive all required  laboratory records and
             analytical data records.   Active enforcement Document Control
             files will be forwarded directly to the District Office(s). . .
             this file will be designated as the CRL Branch Documentation
             Control File.

         The above two level systems will allow the S&AD to handle all sur-
         veys and analytical analyses  in the custody mode with little
         additional resources  usage.  This procedure will allow all survey
         data to be used in Court, if  needed, without resampling.

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                                      50

  4.1.3  DOCUMENT CONTROL NUMBER

         The CRL has been assigning a sequential data set number to each
         survey of samples received at the Laboratory — this number is
         preceeded by an identification code which identifies the office
         collecting the sample.   As an example,  EDO for Eastern District
         Office, CDO for Central District Office, etc.  This data set
         numbering system will be used to generate the Document Control
         Program numbers for each field investigation study.  This system
         of assigning Document Control numbers will apply to both sampling
         and non sampling surveys alike — in essence, every field investi-
         gation situation and/or any S&AD reception of samples from other
         Divisions or other sources must result in the assignment of a
         document control number.  The CRL Document Control Program manager
         will assign the document numbers to the data users' Document Con-
         trol Program managers in blocks of series.  Tracking of this
         numbering system will be done by use of a computer program.

4.1.4    SERIALIZED DOCUMENTS

         The CRL has responsibility for the procurement of all forms and
         logbooks.  Typically, several months supply of these numerically
         serialized materials will be assigned to each office conducting
         field surveys or collecting samples.  The serialized series of
         numbers on the documentation materials will be recorded by the CRL
         Documentation Control Program manager.   The field investigation
         offices' Document Control Program managers will assign the subject
         serialized materials to each project coordinator, who will in turn
         assign the subject serialized materials to the appropriate field
         investigation team or to the participating samplers — the project
         coordinator has complete responsibility for insuring and document-
         ing in his or her logbook, the sufficient and proper distribution
         of documentation control documents.  Policy Note:  All serialized
         documentation control documents will have a document control number
         affixed to it, prior to use on any survey.

4.1.5    PROJECT LOGBOOKS

         Policy Note:  For all field inspections (sampling and non-sampling
         inspection surveys) each inspector shall be issued a serialized
         bound logbook for recording all pertinent information concerning a
         given field inspection.  The logbook of the project coordinator
         shall document the transfer of logbooks to other participating
         individuals who have been designated to perform specific tasks on
         the survey(s).  All pertinent information shall be recorded in
         these logbooks from the time each individual is assigned to the
         project until the project is completed.  These logbooks shall have
         an affixed document control number, prior to issuance, by the
         coordinator.

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                                      51

         Specifically, entries into the logbook shall conform to the S&AD
         Field Operation Procedures Manual and the format of the logbooks.

         Generally, logbook entries should be dated, legible and contain
         accurate and inclusive documentation of an individual's project
         activities.   Because the logbook forms the basis for the subse-
         quent written reports, it must contain only facts and observations.
         Language should be objective,  factual and free of personal feelings
         or other terminology which might prove inappropriate.  Entries made
         by individuals other than the  person to whom the logbook was
         assigned are dated and signed  by the individual making the entry.

         Laboratory analysts who conduct their assigned project analyses in
         a mobile laboratory, or in other field facilities, are assigned a
         logbook by the Project Leader  in the same manner as described
         above.  In addition to information documenting the analysis per-
         formed, field analysts document in their logbooks or on bench
         sheets the date and results of any calibration of mobile labor-
         atory equipment.   A record is  also kept of any incidents related
         to the survey; for example, the electricity going off in the lab-
         oratory, tampering with government vehicles or equipment, etc.
         Appropriate notations of visitors to the mobile laboratory, such
         as facility personnel, are entered in the logbook.  All laboratory
         logbook information will be returned to the laboratory for for-
         warding to the Project Leader  with final laboratory input.

         All project logbooks are the property of Region V and are to be
         returned to the Project Leader when a survey assignment has been
         concluded.  (Refer to S&AD Field Procedures Manual for further
         instructions on the use of the field logbook.)

4.1.6    FIELD DATA RECORDS - REGION V  FIELD RECORD FORMS

         Where appropriate, serialized  Field Data Records (in the form of
         Region V Field Record Forms or bound logbooks with affixed docu-
         ment control numbers) are maintained for each survey sampling
         station or location and the project code and station number are
         usually recorded on each page.  The Project Leader also numbers
         the FDR covers with the appropriate project code and station
         number.  All in-situ measurements and field observations are
         recorded in the FDR's with all pertinent information necessary
         to explain and reconstruct sampling operations.   Each page of a
         Field Data Record is dated and signed by all individuals making
         entries on that page.  The Project Leader and the field team on
         duty are responsible for ensuring that FDRs are present during
         all monitoring activities and  are stored safely to avoid possible
         tampering.  Any lost, damaged  or voided FDRs are reported to the
         Project Leader.

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                                      52

4.1.7    SAMPLE IDENTIFICATION DOCUMENTS

         All necessary serialized sample tags (with affixed document con-
         trol numbers) are distributed to field personnel by the Project
         Leader (or designated project participant) and the serial numbers
         are recorded in the Project Leader's logbook and each involved
         inspector's logbook.  Individuals are accountable for each tag
         assigned to them.  A tag is considered in their possession until
         it has been filled out,  attached to a sample, and transferred to
         another individual with the corresponding Chain-of-Custody Record.
         At no time are any sample tags to be discarded and if any tags are
         lost, voided, or damaged, this is noted in the appropriate FDR or
         logbook immediately upon discovery and the Project Leader is noti-
         fied.  At the completion of the field investigation activities,
         all unused sample tags are returned to the designated individual
         who checks them against  the list of assigned tag serial numbers.
         Tags attached to those samples split with the source or another
         government agency are accounted for.

4.1.8    CHAIN-OF-CUSTODY RECORDS

         Serialized Chain-of-Custody Records (with affixed document control
         numbers) are assigned and accounted for in a manner similar to
         that used for sample tags.  Double copy forms of the Custody Sheets
         are filled out in the field, according to the Region V Custody Pro-
         cedures Manual.  All field staff having charge (legal custody) of a
         sample(s) must sign the respective Custody Sheet(s).  The Project
         Leader or a designated field custodian transmits the samples and
         properly signed Custody Sheets to the respective office custodian
         locally or may mail samples from the field directly to another
         U.S. EPA or contractor laboratory(s) — the various options in-
         volving samples exchanges and Custody Sheet management are listed
         below:

         1.  Samples transported from the field by field staff and turned
             into the laboratory or office custodian — Double copied
             Custody Sheets are signed by all field staff legally respons-
             ible for custody and turned over to the laboratory or office
             custodian.

         2.  Samples mailed from the field directly to the CRL 	 Samplers
             and/or inspectors sign the double copied Custody Sheet(s) and
             forward original (top sheet) with the samples (Note:  A copy
             of the Custody Sheet must be packaged with each package of
             samples shipped).  The second Custody Sheet (copy) is turned
             over to the shipping office's sample custodian, either by the
             Project Leader or designated staff — a record of this trans-
             action is entered into the Project Leader's field logbook.

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                                      53

         3.   Samples mailed from the field directly to a contractor's
             laboratory — Follow the protocol prescribed for the specific
             contract,  such as VIAR and the additional Regional protocol(s),
             as specified by the Project Officer.

         4.   For all samples to be tracked by the local field laboratory(s)
             — No CRL  responsibility — the original of the Custody Sheet
             will be turned over to the field office sample custodian and a
             copy (second page) of the signed Custody Sheet will be mailed
             to the contract laboratory stamped, "Sign and return to Sample
             Custodian".  Generally, the contract will state that contract
             laboratory shall make and retain a copy of the subject Custody
             Sheet, prior to returning it.  (Note:  It is expected to be
             rare cases where samples will be sent to contract by S&AD
             offices and the CRL will not track the analyses.)

4.1.9    OTHER CONTROLLED DOCUMENTS

         The analytical laboratory logbooks and data sheets that are used
         for various purposes, such as chemical, bacteriological and bio-
         logical analyses, equipment calibration, etc., within the S&A
         Laboratories will be forwarded with the resulting data to the
         laboratory1s Custody File.

         Bench sheets and other similar documents each will show the re-
         spective Document Control Number, complete sample identification
         number, dates, name(s) of analyst(s) and other pertinent identi-
         fication instrument printouts and other separate documents, except
         laboratory logbooks, will be labeled in a similar manner.  These
         documents will be sent to the Evidentiary File along with the
         commensurate data.

         All laboratory observations and calculations not recorded on bench
         sheets instrument graph printouts, etc., are entered in serialized
         logbooks assigned by a Branch custodian or other designated indivi-
         dual.   Each numbered page of the logbook* actually consists of two
         pages - an original and a copy.  The original copy is perforated
         so  that it can be removed from the logbook to be forwarded to the
         Evidentiary File.  When this type of logbook is unavailable, dupli-
         cates of individual pages will be identified and forwarded to the
         Evidentiary File.
         *The original page requires no carbon paper.  The logbook is re-
         ferred to as an NCR logbook.

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                                      54

         The logbook needs  to  contain information sufficient to recall and
         describe succintly each step of  the analysis  performed because it
         may be necessary for  the analyst to testify in subsequent enforce-
         ment proceedings*.  Moreover,  sufficient detail is  necessary to
         enable others  to reconstruct the procedures followed should the
         original analyst be unavailable  for testimony.  Any irregularities
         observed during the testing  process need to be noted.   If,  in the
         technical judgment of the analyst,  it  is necessary  to  deviate from
         a particular analytical method,  the deviation shall be justified
         and properly documented.

         The serialized logbook assigned  to  an  individual can be used for
         more than one  project.   However, only  one project is discussed on
         any given page(s).  That page(s) is labeled with the project code,
         dated, and signed  by  the individual.   The custodian accounts for
         each completed laboratory logbook and  the logbook is filed by the
         CRL Quality Assurance Coordinator or the Field Office  Custodian.

         The CRL Custodian or  Field Office Custodian will issue serialized
         analytical laboratory logbooks for  the recording of all information
         relating to the calibration, operation and maintenance of a spe-
         cific laboratory instrument(s).

         Usually, each specific piece of  analytical equipment will require
         an instrument  logbook.   It is required that instrument information
         in the instrument logbooks be sufficiently documented (Document
         Control and Sample I.D. numbers, dates, and analyst(s) signa-
         ture(s), so as to relate to  specific sample runs.
4.1.10   PHOTOGRAPHS
         When movies, slides or photographs are taken which visually show
         the effluent or emission source and/or any monitoring locations,
         they are numbered to correspond to logbook entries.  The name of
         the photographer, date, time,  site location, and site description
         are entered sequentially in the logbook as photos are taken.
         Chain-of-Custody procedures depend upon the type of film and the
         processing it requires.  Once  developed, the slides or photogrpahic
         prints shall be serially numbered corresponding to the logbook de-
         scriptions labeled and forwarded with the logbook in the logbook
         photo page format.
         *If sample merely requires routine documented analytical approaches,
         then notate same with "Samples analyzed using routine CRL Method
         #	".  These entries should only describe in a synoptic fashion
         what the chain of events were, it should not be a lengthy report in
         itself.

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                                      55

4.1.11   CORRECTIONS TO DOCUMENTATION

         As previously noted,  unless prohibited by weather conditions,  all
         original data recorded in logbooks,  sample tags,  and other data
         sheet entries are written with waterproof ink.   None of the
         accountable serialized documents listed above are to be destroyed
         or thrown away, even  if they are illegible or contain inaccuracies
         which required a replacement document.

         If an error is made on an accountable document assigned to one
         individual, that individual may make contemporaneous corrections
         simply by crossing a  line through the error and entering the cor-
         rect information.  Any subsequent error discovered on an accountable
         document should be corrected by the  person who made the entry.  All
         subsequent corrections must be initialed and dated.

         If a sample tag is lost in shipment, or a tag was never prepared
         for a sample(s), or a properly tagged sample was  not transferred
         with a formal Chain-of-Custody tag,  the following procedure applies.
         A written statement is prepared detailing how the sample was col-
         lected, air-dispatched or hand-transferred to the field or S&A
         laboratory.  The statement should include all pertinent inform-
         ation, such as entries in field logbooks regarding the sample,
         whether the sample was in the sample collector's  physical posses-
         sion or in a locked compartment until hand-transferred to the labor-
         atory, etc.  Copies of the statement are distributed to the Project
         Leader and the appropriate office Custody Files.

4.1.12   CONSISTENCY OF DOCUMENTATION

         Before release of a final project report from the CRL, the Chem-
         istry and/or Biology  Sections assemble and cross-check information
         on corresponding sample tags, custody records,  bench sheets,
         analyst logbooks and  sample entry logbooks to ensure that data
         pertaining to each particular sample is consistent throughout the
         record.  The CRL Data Coordinator provides the final cross-check,
         prior to transmitting the data to the Project Coordinator and
         filing the laboratory's documentation information, such as logbooks,
         calibration information graphs, etc., in the Custody File.  The
         Project Coordinator subsequently performs a cross-check of eviden-
         tiary data in his possession (FDRs,  logbooks, custody records,
         etc.) to ensure that  information recorded corresponds with that
         of the S&A contract laboratories' data reports and is consistent
         throughout the project record.   A statement that  all project
         evidentiary data has  been accounted  for accompanies the transfer
         of the data from the  CRL to the Field Office or data user and the
         transfer of the data  from the Field  Offices to the Regulatory
         Divisions.

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                                      56

4.1.13   DOCUMENT NUMBERING SYSTEM AND INVENTORY PROCEDURE

         To provide document accountability to the appropriate individuals,
         each of the document categories discussed above features a unique
         serialized number for each item within the category.

         All other documents (such as recorder graph paper, data calcula-
         tions sheets, memoranda,  correspondence, photos, etc.,) which are
         generated during a project are sequentially numbered  and affixed
         with the documentation number and sample number(s).

4.1.14   BRANCH FILES

         After a Branch has completed its work for a particular investiga-
         tion, all documents generated from that project should be assembled
         by the Project Coordinator and turned over to the Documentation
         Control Coordinator who will enter the materials into the Branch
         file.  Individuals may retain clean (no handwritten comments) copies
         of documents for their personal files but shall insure that the
         original or similar copy is in the Branch file.  The  Project Co-
         ordinator is responsible for assuring the collection, assembly, and
         inventory of all documents relative to a particular project at the
         time the project objectives are completed and the Branch Documen-
         tation Control Coordinator is responsible for maintaining the in-
         tegrity of the accountable file.  All records leaving the file
         must be signed out and signed in.  The file itself will be kept
         locked.

4.2      EVIDENTIARY FILE

         The S&AD Branch Documentation Control Coordinator associated with
         the responsible Project Coordinator for specific field projects
         will automatically forward the entire S&AD documentation control
         file for all custody surveys/samples to the appropriate enforce-
         ment office.  This means that for all custody surveys, the S&AD
         Branch Project Coordinator and the associated Documentation Con-
         trol Coordinator shall receive the files from all participating
         S&AD Branches and in turn forward the S&AD collated file to the
         designated Enforcement Evidentiary File Coordinator.   In the other
         case, when routine surveys (those designated as noncustody en-
         forcement) which will be handled by S&AD in the same fashion as
         enforcement designated surveys, the individual S&AD Branch level
         Documentation Control Coordinators will maintain their parts of
         the file under standard operating custody procedures.  If the
         routine survey reverts to enforcement designated custody, the
         Branch Documentation Control Coordinators will forward their parts
         of the file to the Branch Project Coordinator for collation and
         review and then forward to the Evidentiary File by the attendant
         Branch Documentation Control Coordinator.

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                                      57

         The format of the Evidentiary File is to arrange each project by
         Branch documents and includes the following document classes:

             A.  Project Plan

             B.  Project Logbooks

             C.  Field Data Records

             D.  Sample Identification Documents

             E.  Sample/Chain-of-Custody tag

             F.  Analytical logbooks, Lab Data, Calculations, Bench Cards,
                 Graphs, etc.

             G.  Correspondence

                 1.  Intra-office
                 2.  EPA
                 3.  Industry
                 4.  Record of Confidential Material

             H.  Report Notes, Calculations, etc.

             I.  References, Literature

             J.  Sample (on-hand) Inventory

             K.  Check-out Logs

             L.  Litigation Documents

             M.  Miscellaneous - photos, maps, drawings, etc.

             N.  Final Report

         Once deposited in the Branch Documentation File, documents may only
         be checked out through the Documentation Control Coordinator or
         designated representative.  The file will be kept locked at all
         t ime s.

5.       QUALITY ASSURANCE

5.1      INTRODUCTION

         Environmental Protection Agency (EPA) Policy, enunciated in memo-
         randa of May 30 and June 14, 1979, requires participation in a
         centrally managed Quality Assurance (QA) program by all EPA Re-
         gional Offices, Program Offices, EPA Laboratories and the States.

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                                      58

         This includes those monitoring and measurement efforts mandated or
         supported by EPA through regulations,  grants,  contracts,  or other
         formalized agreements.   The QA programs for the States in Region V
         will be cooperatively developed with them and  implemented through
         the Regional Office.

         The Office of Research and Development (ORD) has been given respon-
         sibility for developing, coordinating, and directing the  implemen-
         tation of the Agency QA program.   In addition, an Agency  QA Advisory
         Committee, chaired by ORD and with representatives from the Program
         Offices, Regional Offices, Staff Offices, and  the States, has been
         established to coordinate this effort.

         As an initial step in implementing this policy, QA Plans  (Programs)
         must be prepared by all EPA-supported  or-required environmental
         monitoring and measurement activities  per the  specifications of
         EPA's guidance document QAMS-004/80.

         Such a program has been documented by  the Quality Assurance Office
         (QAO) in Report No. EPA - 905/4-80-001, title  "QA program, Guide-
         lines and Specifications, Criteria, and Procedures, Region V".  The
         purpose of this report (manual) is to  describe the QA program for
         Region V, U.S. EPA that will produce a numerical estimate of the
         reliability of all data values reported or used by the Region.

5.2      POLICY AND OBJECTIVES

         QA is necessary at each organizational level to insure high quality
         data.  Each organization should have a written QA policy.

         This policy statement provides the framework within which a Region
         develops and implements its QA program.  The policy statement must
         describe the Region's goals and specify those  requirements and
         activities needed to realize these goals.  Paralleling the Admini-
         strator's directive of May 30, 1979, the Region's policy statement
         must emphasize those requirements and  activities needed to ensure
         that all data obtained are of known quality.  Policy is to be
         directed towards a formal commitment of time and resources neces-
         sary to ensure that data are as precise and accurate and as com-
         plete and representative as required.

         A policy statement meeting the above specifications was approved by
         the Regional Administrator for Region V, on January 20, 1980.  Re-
         gion V's policy statement is listed in Section 2 of Report No.
         EPA - 905/4-80-001.  This policy has been distributed to all Re-
         gional and State organizational monitoring activities so Regional
         policy and scope of coverage are known.  This  policy statement
         indicates managements commitments to QA throughout the data gen-
         erating and processing operations.

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                                      59

         The primary goal of the Region V, QA program is to define and im-
         prove the reliability (accuracy and precision) of data generated
         and used by the Region, per Headquarters'  mandate and Agency regu-
         lations.  There must be a mechanism for so doing.  In order to
         measure or estimate changes in data quality, the quality must be
         expressed in measurable (numerical) terms.  Therefore, the first
         priority in the Region V QA program is to establish and implement
         a method to define and quantitate the program product - data
         quality.  This includes data from Regional program, State and local
         Agencies, grants and contracts.  Each evaluation and review process
         such that all of the activities that influence the quality of data
         are performed by appropriated trained staff, by methods acceptable
         to EPA on instruments that are approved and maintained and each data
         collection activity has a documented quality controlled program.

         Other QA program objectives are listed in Section 3 of Report No.
         EPA - 905/4-80-001.

5.3      QUALITY ASSURANCE MANAGEMENT

         The Agency's QA policy statement specifies that the Regional Admini-
         strator is responsible for the implementation and coordination of
         the mandatory QA activities within Region V.  This responsibility
         also includes external monitoring and measurement activities of
         States, local agencies, contractors, grantees, and others covered
         by the Agency QA plan.  The Director of the Surveillance and
         Analysis Division (S&AD), through the Chief of the QAO, assures
         that QA objectives are met for each monitoring project conducted
         within Region V.  The QAO is responsible for developing and im-
         plementing procedures to insure the reliability of data supporting
         the air, pesticides, solid waste, and toxic substances programs in
         the Air and Hazardous Material Division (AHMD), the public drink-
         ing water, ambient surface and groundwater, and industrial and
         domestic wastewater programs in the Water Division, all enforcement
         monitoring data, the International Joint Commission and harbor
         dredging progenerating environmental data.  The QAO has respons-
         ibility for evaluating the QA and quality control (QC) programs
         for State Program Grants in Ambient Air Quality Monitoring, Water
         Quality Monitoring and for all monitoring contracts initiated by
         Region V.

         Specific details of this responsibility are delineated in Section 4
         of Report No. EPA - 905/4-80-001.  The organizational structure into
         which the QA management interacts, as established by the Region's QA
         policy is shown in Figure 10.

5.4      ELEMENTS OF A QUALITY ASSURANCE PLAN

         Elements to be addressed for the preparation of QA programs are con-
         tained in Section 8 of Report No. EPA - 905/4-80-001.

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                                        60
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           FIGURE 10  RELATIONSHIP OF THE QUALITY ASSURANTE FUfcTION
                           TO OTHER REGIONAL PROGRAM FUNCTIONS  -

                           Office of the Regional Administrator
                                 Office of Deputy R. A.
          •	^Special Assistant to R. A.
                                 Regional Counsel«-
                                        of Great Lakes National Program
                               -^Office of External Affairs
                            ^Planning and Management Division
                                      Processing Branch^-
                               -^Resource Management Branch<-
                               •^Personnel  and Manpower Dev. Branch
                                 General  Services Branch
                                 Analytical Center^	
                           Air and Hazardous Materials Division
                               > Air Programs Branch
                               > Waste Management Branch
                                 Pesticides Branchy
                               -^Office of Grant Support
                               -^Office of Toxic Substances
                                      Water Division
                              -reconstruction Grants  Branch
                                 Office of Policy and Evaluation^—
                                 Environmental Engineering Branch<-
                                 Faclllties Planning<.
                                 Construction Management  Branch^
                               ->Water Supply Branch
                               -^Water Quality'Management Branch
                            Surveillance and Analysis Division
                               —-Quality Assurance Office	
                               -^Central Regional  Laboratory
                               ->Env1 ronmental Emergency Investigation Branch
                               -technical Support Branch
                               -^Central District  Office
                               -Eastern District  Office
                                   Enforcement Division
                                   r Enforcement Branch
                               •Water and Hazardous Materials Enf.  Branch
                               •^Permits Branch
                        State and Local Agency Monitoring Programs
                                -^(Including all EPA funded monitoring
                                    within a State)

                                       IJC Activity
                                 Data Quality
                           Monitoring Contracts (Sampljng and Analyses)

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                                      61

5.5      DATA COLLECTION

         Data quality changes occurring during data collection can come from
         six major activities:  a)  formulating sound objectives for the
         sampling program,  b) collecting representative samples,  c)  main-
         taining sample integrity  through proper sample handling  and pre-
         servation, d) adhering to appropriate sample identification and,
         where needed, chain-of-custody procedures, e) practicing QA pro-
         cedures in the-_sample transportation, storage, and preparation
         processes, and f)  using proper analytical techniques complete
         with appropriate QC activities to generate the actual data.

5.5.1    SAMPLING METHODOLOGY

         The objective of sampling is to obtain a representative  portion of
         the total environment under investigation.

         Sampling plan objectives  are determined by the following activ-
         ities: a) planning (areawide or basin), b) permits, c) compliance,
         d)  enforcement, e) design,  f) process control, and g) research and
         development.  The  types of  sampling programs to be employed, depend-
         ing on suitability to program objectives, include reconnaissance
         surveys, point-source characterization, intensive surveys;  fixed-
         station network monitoring, groundwater monitoring, ambient air
         and stationary source emission monitoring and special surveys in-
         volving chemical,  biological, microbiological and radiological
         monitoring.

         As  a minimum a sampling plan (QA Project Plan) shall be  prepared
         and contain, as a  minimum the factors listed below.  The plan must
         be  approved by the QAO prior to the start of the task.

5.5.2    QUALITY ASSURANCE  PROJECT PLANS

         QA  Project Plans for monitoring and measurement projects should
         contain the following, as applicable:

          1.  Title Page, with provision for approval signatures

          2.  Table of Contents

          3.  Project Description

          4.  Project Organization and Responsibilities

          5.  QA objectives for measurement data in terms of precision,
              accuracy, completeness,  and representativeness

          6.  Sampling Procedures

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                                      62

          7.   Calibration Procedures and References

          8.   Analytical Procedures (manual and automated)

          9.   Data Analysis,  Validation, and Reporting (manual
              and automated)

         10.   Internal Quality Control Checks

         11.   Performance and System Audits

         12.   Preventive Maintenance Procedures and Schedules

         13.   Sample Custody

         14.   Specific procedures to be used to routinely assess
              and document data precision,  accuracy, and complete-
              ness of specific measurement  parameters involved

         15.   Corrective Action

         16.   Quality Assurance Reports to  Management

         The QA Project Plans will be prepared in document control format,
         with provision for revision, as needed, and with a record of the
         official distribution.

         Note:  See the "Guidelines and Specifications for Preparing QA
                Project Plans, QAMS-005/80" for more detail.

5.5.3    ANALYTICAL METHODOLOGY

         The analytical laboratory provides qualitative and quantitative
         data for use in decision making.  To be valuable, the data must
         accurately describe the characteristics and concentrations of
         constituents in the  samples submitted to the laboratory.   In many
         cases, because they lead to faulty interpretation, approximate
         or incorrect results are worse than no results at all.

         Uniformity of methodology within a single laboratory as well as
         among a group of cooperating laboratories is required to remove
         methodology as a variable when there are many data users.  Uni-
         formity of methodology is particularly important when several
         laboratories provide data to a common data bank (such as STORET)
         or cooperate in joint field surveys.  A lack of uniformity of
         methodology may raise doubts as to the validity of the reported
         results.  If the same constituents are measured by different

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                             63

analytical procedures within a single laboratory, or by a dif-
ferent procedure in different laboratories, it may be asked which
procedure is superior, why the superior method is not used
throughout, and what effects the various methods and procedures
have on the data values and their interpretations.

Physical and chemical measurement methods used in environmental
laboratories should be selected by the following criteria:

1.  The selected methods should measure desired constituents
    or environmental samples in the presence of normal inter-
    ferences with sufficient precision and accuracy to meet
    the environmental data needs.

2.  The selected procedures should use equipment and skills
    ordinarily available in the average environmental laboratory.

3.  The selected methods should be sufficiently tested to have
    established their validity.

4.  The selected methods should be sufficiently rapid to permit
    repetitive routine use in the examination of large numbers
    of environmental samples.

The restriction to the use of EPA methods in all laboratories
providing data to EPA permits the combination of data from dif-
ferent EPA programs and supports the validity of decisions made
by EPA.

As a minimum analytical methodology (laboratory and field) is to
be documented per the specifications listed in Sections 8.3, 8.4,
8.5, 8.6 and 8.7 of Report No. EPA - 905/4-80-001.

The QAO requires that the methodology be carefully documented.
In some reports it is stated that a standard method from an
authoritative reference was used throughout an investigation,
when close examination has indicated, however, that this was not
strictly true.  Standard methods may be modified or entirely
replaced because of recent advances in the state-of-the-art or
personal preferences of the laboratory staff.   Documentation of
measurement procedures used in arriving at laboratory data should
be clear, honest and adequately referenced, and the procedures
should be applied exactly as documented.

Reviewers can apply the associated precision and accuracy of each
specific method when interpreting the laboratory results.  If the
accuracy and precision of the analytical methodology are unknown
or uncertain, the data user may have to establish the reliability
of the result he or she is interpreting before proceeding with the
interpretation.

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5.6      DATA PROCESSING

         Data processing includes collection,  validation,  storage,  trans-
         fers and reduction.   Precautions shall be taken each time  the data
         are reduced, recorded,  calculated and transcribed to prevent errors
         and the loss of information.

         All QC Plans (Project Plans)  must document the mechanisms  to deal
         with the requirements listed  below.   Those mechanisms shall be as
         stringent as those specified  in Sections 9.1, 9.2 and 9.3  of Report
         No. EPA - 905/4-80-001.

5.6.1    COLLECTION

         Each QC Plan (Project Plan)  shall address the checks which must be
         used to avoid errors in the  data collection process.

5.6.2    VALIDATION

         Data validation is defined as "the process whereby data are filtered
         and accepted or rejected based on a set of criteria."  Since this
         aspect of QC may include various forms of manual or computerized
         checks, criteria for data validation shall be specified in each QC
         Plan (Project Plan).

5.6.3    STORAGE

         Each QC Plan (Project Plan)  shall indicate how specific types of
         data will be stored, and the  duration of storage.  For every stage
         of data processing at which data are stored, procedures shall be
         established to ensure data integrity and security.

5.6.4    TRANSFERS

         Each QC Plan (Project Plan)  shall describe procedures which shall
         be used to ensure that data  transfer is error-free, and that no
         information is lost in the transfer.   Examples of data transfers
         are:  copying raw data from a notebook onto a data form for key-
         punching, converting a written data set to punched cards,  copying
         from computer tape to disk and telemetering.  Data transfer steps
         contained in each QC Plan shall be kept to a minimum.

5.6.5    REDUCTION

         Each QC Plan (Project Plan)  shall contain procedures for ensuring
         and verifying the correctness of data reduction processes.  Data
         reduction includes all processes which change either the form of

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         expression or quantity of data items.   It is distinct from data
         transfer in that it entails a reduction in the size (or dimension-
         ality) of the data set.  The QC Plan must identify the processes
         used to obtain the reduced data,

5.7      DATA QUALITY ASSESSMENT

         The quality of all environmental  data generated and processed shall
         be assessed for completeness, accuracy, precision, representative-
         ness, and comparability based upon the QC Project Plans.   All re-
         ported data shall include the associated precision and accuracy.
         Protocol for minimum documentation shall be per specifications
         listed in Section 11 of Report No. EPA - 905/4-80-001.

         The results of each data quality  assessment shall be provided in
         the semiannual QC reports and in  project progress and final reports.

5.7.1    COMPLETENESS

         Each QC Plan (Project Plan) shall identify the quantity of data
         needed to support a planning or enforcement action.  Completeness
         shall take into consideration the potential for environmental
         change with respect to time or timing.

5.7.2    ACCURACY

         Each QC Plan (Project Plan) contain a mechanism which will demon-
         strate that the reported data are favorably comparable to the true
         value(s).  Examples of activities to assess accuracy are:

         1.  Traceability of Instrumentation - Each measurement device
             shall be assigned a unique identification number.  Documen-
             tation shall identify the specific measurement device, where
             and when used, maintenance performed, and the equipment and
             standards used for calibration.

         2.  Traceability of Standards - Each standard and each measurement
             device shall be calibrated against a standard of known and
             higher accuracy.  All calibration standards shall be  traceable
             to available National Bureau  of Standards (NBS) standards.  If
             NBS standards are not available, other primary standards shall
             be used.

         3.  Traceability of Samples - Each sample shall be assigned a
             unique identification number.  Documentation shall identify
             sampling time, place and action taken on each sample.

         4.  Traceability of Data - Data shall  be documented to allow com-
             plete reconstruction, from initial field records through data
             storage system retrieval.

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         5.   Methodology - If available, only Federal reference,  equivalent,
             or approved alternate test methods shall be used.

         6.   Reference or Spiked Samples - Recoveries shall be  within pre-
             determined acceptance limits.

         7.   Performance Audits - Each environmental monitoring program
             shall continually participate in the EPA National  and Regional
             Performance Audit Programs.  Each program shall develop a
             system of intraprogram performance audits to demonstrate that
             all measurements are within acceptable, predefined control
             limits.

5.7.3    PRECISION

         Each QC Plan (Project Plan) shall contain a mechanism  which will
         demonstrate  the reproducibility of the measurement process.
         Examples of  activities to assess precision are:

         1.   Replicate Samples - Replicate sample data shall be within
             predetermined acceptance limits.

         2.   Collocated Monitors - Sample data from collocated  monitors
             shall be within predetermined acceptance limits.

         3.   Interprogram Testing - Sample data from independent organiza-
             tions shall be within predetermined acceptance limits.

         4.   Instrumental Checks - Each measurement device shall have
             routine checks performed to demonstrate that variables are
             within predetermined acceptance limits.  Examples  of checks
             include:

             1.  Zero and span

             2.  Noise levels

             3.  Drift

             4.  Flow rate

             5.  Linearity

5.7.4    REPRESENTATIVENESS

         Each QC Plan (Project Shall) contain procedures to ensure that
         each sample collected, as accurately and precisely as  possible,
         represents the media sampled.  Examples of activities  to assess
         this representativeness are:

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         1.  Site Purpose - Each sampling site shall have a preidentified,
             documented purpose.

         2.  Site Description - Each sampling site shall be specifically
             identified by location and by suitability to meet the pre-
             identified purpose.

         3.  Site Photodocumentation - The conditions under which each
             sample was collected shall be described.  Conditions include
             such items as:

             1.   Stream flow

             2.   Wind speed and direction

             3.   Temperature

             4.   Barometric pressure

5.7.5    COMPARABILITY

         Each QC Plan (Project Plan) shall contain procedures to assure the
         comparability of data.  Examples are:

         1.  Consistency of reporting units

         2.  Standardized siting, sampling, and analysis

         3.  Standardized data format

5.8      CORRECTIVE ACTION

         Each QC Plan (Project Plan) shall include provisions for written
         requirements establishing and maintaining reporting or feedback
         channels to the appropriate QA management authority to ensure that
         early and effective corrective action can be taken when data
         quality falls below required limits.   Each QC Plan (Project Plan)
         shall also include provisions to keep responsible management in-
         formed  of the performance of all data collection systems.   Each
         QC Plan (Project Plan) shall describe the mechanism(s) to  be used
         when corrective actions are necessary.   Corrective action shall
         relate  to the overall QA management scheme:   Who is responsible
         for taking corrective actions, when corrective actions are to be
         taken and who ensures corrective actions were taken and produced
         the desired results.

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Corrective action shall be minimized through the development and
implementation of routine internal program controls prior to an
adverse program impact.  Examples of controls include:

1.  Each measurement system shall have predetermined limits to
    identify when corrective action is required, before data
    become unacceptable.

2.  A procedure shall be established for each measurement system
    to identify the corrective action which will be taken when
    the warning or control limits are exceeded.

3.  For each measurement system, the level within the organization
    responsible for taking corrective action, and also the level
    within the organization responsible for approving corrective
    action.

Results of the following QC activities may also initiate corrective
actions:

1.  Performance audits

2.  System audits

3.  Interprogram comparison studies

4.  Failure to adhere to the approved QA Program Plan, QA Project
    Plan or Standard Operating Procedures

5.  Loss of litigation

6.  Justified public peer criticism

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