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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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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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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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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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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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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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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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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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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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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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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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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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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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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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
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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
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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.
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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
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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.
-------
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
•urvcnanc* and Analysis Division
•36 South dark St.
CMeago. Wnols 60608
CIMTKAL MSTRICT OFPICI
IT MiO.l OO/JO/74)
t.«. anrno
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-------
37
FIGURE 7 EXAMPLE SHEET FROM FIELD LOGBOOK
UNITED STATES
ENVmONMENTAL PROTECTION AGENCY
WOONV
Surv*«*nc* «nd Analytic OtvWen
S36 South Ctartc St.
CNeago. Knot* 60605
•CENTRAL OUTtlCT OFFICE
•* MM.1 (10/M/74)
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-------
- '38
FIGURE 8 SAMPLE IDENTIFICATION TAGS
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Station Location
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o o <•> sz "of^i^S
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ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
BUILDING 53, BOX
25227. DENVER fEDERAL CENTER -.
ri^Ti
DENVER,
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COLORADO 80225 ' ^
***^\
-------
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
-------
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.
-------
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
-------
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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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