905-R-83-115
SAMPLE HANDLING PROTOCOL FOR HAZARDOUS WASTE
            REM/FIT CONTRACT
   U.S. ENVIRONMENTAL PROTECTION AfiENCY
                REGION V
     ENVIRONMENTAL SERVICES DIVISION
          536 SOUTH CLARK STREET
         CHICAGO, ILLINOIS 60605
              MAY 3,  19R3

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                  UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                      REGION V

  GATE   MAY Og  1983                                          905R83115

 JBJECT    Sample Handling Protocol  for Hazardous Waste, REty/rii contract


  FROM:    William H. Sanders III, Director
          Environmental  Services Division

    T0:    Richard BarteU, Chief      and   Michael Harris          and  Joseph  Petrilli, FIT
          Remedial Response Branch         CH2W1LL, Incorporated       Ecology & Environmen


          Attached is a  copy of the Region V  Environmental Services Division
          "Sampling Handling Protocol  for Hazardous Waste REM/FIT Contract".
          When it is known that samples will  be shipped to a National  Contract
          Laboratory for analysis,  this protocol must be followed in total  by
          all authorized samplers.

          While this protocol is applicable for the analysis of water, oils
          and solid wastes, the same procedure must be used for air analysis
          requests.  These requests will be processed under special analytical
          services (see  page 2 of protocol).

          For additional information,  please  contact Charles E.lly, Sample Analyses
          Coordinator, at the Central  Regional Laboratory at 353-R370.
                                               William H. Sanders III

          Attachment(s)

          cc:  Sanders
               Yeates
               Dikinas
               Ross
               Adams
               Constantelos
               Vanderlaan
               Diefenbach
               Getty, FIT
EPA FORM 132M .SEV3-76)

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                             REM/FIT PROTOCOL
The following procedures shall apply with regard to  data  review and
sample handli ng.

I.  CASE SET-UP AND LOGISTICS OF SAMPLE HANOIING

    A.  Cl^MHILL will set-up its own cases to secure National  Contract
Laboratories (NCL's) by telephoning the EPA,  Sanpling Management Office
(SMO) in Alexandria, Virginia (702-557-24%,  Ms. Eileen O'Connor).  For
high hazard samples which require inorganic analysis, D^MHILL will have
to first contact Ms. O'Connor, followed by a  written request  from the
EPA Regional Counsel or the ESft Director (copy to SMO X Regional Lab)
to Or. Theodore Meiggs, Assistant Laboratory  Director, EPA,  National
Enforcement Investigations Center (NEIC)(303-234-4661).

    R.  CH-jMHILL will provide Mr. Charles Elly, EPA, Region  V, Environ-
mental Services Division, Central Regional Laboratory (CRL)  with copies
of the case number, NCL and yellow copy of the chain-of-custody form
for each study.  This should occur not more than two (2)  days after
samples have been shipped to the NCL.  If sampling will occur frequently,
than reports should be submitted to Mr. Elly  on a weekly  basis.

    C.  Charles Elly or other CRL personnel will prepare  all  Special
Analytical Services requests (SAS's), secure  NCL's and case  numbers for
the SAS's and send the information to CH?MHILL and to Paul Friedman
of the SMO.  Dr. Friedman will review all SAS data.   Following are
examples of when SAS's will he required.

        1.  Priority Pollutant Organic and Metals Analysis of Oils
are requested.

         2.  EP Toxicity, Flashpoint and other RCRCA Solid Waste
parameters are requested.

         3.  Dioxins are requested by the Region VII or High Resolution
Method.

         4.  Parameters other than the 114 Priority Pollutant Organics
or the Task 1 and 2 Metals or Task 3 Inorganics are requested.

         5.  Lower detection limits than those in the regular IFB's
are requested.  Other quality control which is more extensive than the
IFB calls for.

         6.  Quicker turnaround times than the normal 30  to  40 days are
requested.

         7.  Other requests not covered above.


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     D.  Packaging and Shipping

         CH2MHILL shall use as a guide the Region V  "Sampling  Handling
Protocol for Hazardous Waste", May 27, 1982 and the  "Users  Guide to
the EPA Contract. Laboratory Program", August 1Q82 (Attached).

II.  DATA REVIEW

     One copy of the data initially will  he sent by  the  National Contract
Laboratory to the SMO (Paul Friedran) and one copy will  be  sent to the
CRL.

     A.  Dr. Paul Friedman will review all of the data.

     B.  Ms. Marcia Kuehl, CRL Duality Control  Coordinator  wil 1 establish
formal procedures for insuring that Or. Friedman is  reviewing  data
correctly.  (This protocol will be formally tracked, since  this is a
pilot study).
     C.  Paul Friedman will forward his findings  to the CRL.   The  CRL
Coordinator will forward Dr. Friednan's findings  (following  verification)
and all of the raw data to CHgHMILL.

III. TRAINING

     Charles Elly and Kathy Getty or Cindy Bachunas of FIT will  provide
a one-day training session concerning implpmentation of the  National
Contract Laboratory Program.

IV.  RESOLUTION OF PROBLEMS

     All problems involving samples should be referred by SMO to CHpMHRL,
and all problems regarding data should he referred to Or. Paul  Friedman.
All correspondence on these issues should be copied to Charles Elly and/or
Marcia Kuehl.

Attachments

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                                    REGIONV
                  UMITED STATES ENVIRONMENTAL PROTECTION AGEHCY
              0  3 1982

SUBJECT:  Revised Sample Handling Protocol for Hazardous Waste
        William H. Sanders III, Director
        Environmental Services Division
    TO!  Gerald Regan, CDO
        A.R. Winklhofer. EDO
        Joseph Petrilli, FIT
        Scott McCone, TAT
        Attached is a newly revised copy of the Region V Environmental Services
        Division "Sample Handling Protocol for Hazardous Waste".  When it is known
        that samples will be shipped to a National Contract Laboratory for analysis,

        this protocol must be followed in toto by all authorized  samplers.
        While this protocol is applicable for the analysis of water, oils and solid
        wastes, the same procedure must be used for air analysis requests.  These
        requests will be processed under special analytical services (see Attach-
        ment #2 of protocol).
        For additional information, please contact Charles Elly,  Sample  Analyses Co
        ordinator, at the Central Regional Laboratory at 353-8370.

        Attachment (s)

        cc:  Sanders
             Yeates
             Wagner
             Ross
             Adams
             Constantelos
             Bartelt
             Vanderlaan
             Diefenbach
             Klepitsch
             Kee
             Schaffer
            '•Sutfin
             Bryson
 K»A ro*M
            mev.

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      SAMPLE HANDLING PROTOCOL
        FOR HAZARDOUS WASTE
U.S. ENVIRONMENTAL PROTECTION AGENCY
              REGION V
  ENVIRONMENTAL SERVICES DIVISION
       536 South Clark Street
      Chicago, Illinois 60605
            May 27, 1982

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              SAMPLE HANDLING PROTOCOL FOR HAZARDOUS WASTE

                       *•  OPERATIONAL PROCEDURES

                            A. Data Requests

     For samples to be analyzed by the Central Regional Laboratory
(CRL) or by a contract laboratory, all requests should be initiated by
submittal of the ESD's Form-81-01 "Request for Analysis" (see Attach-
ment 11).  This form should be submitted, at least two weeks prior to
the survey, to William H. Sanders 111, Director, ESD, for Priority tl
surveys and to Curtis Ross, Director, CRL, for all other requests.

     The following Is a listing of priority types:
PRIORITY II - Highest priority work; immediate response or Initiation
              of the project by CRL is necessary; or other work already
              in progress may be curtailed*
PRIORITY 12 - High priority projects to be scheduled and completed as
              soon as possible without disrupting other work already in
              progress.
PRIORITY. 13 - Projects to be completed around Priority fl and #2 pro-
              jects, but with some definite completion date, usually,
              at least two or three months from request date*
PRIORITY IA - Projects that may be completed if time is available.  No
              requested due date.
     Samples will be analyzed either at the CRL or by a National Con-
tract Laboratory (NCL) administered by the V1AR & Company,  Incorporated,
EPA Hazardous Waste Investigations, Sample Management Office (SMO),
hereafter referred to as "SMO".  The decision of whether the samples
will be analyzed at the CRL or by a contractor laboratory will depend

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                                  -2-
on the priority, parameter, and sample type, or other factors.  Most
Priority II samples will be analyzed at the CRL.  (The Division Direct-
or and the CRL Director make the determination*)

     With regard to samples sent to a National Contract  Laboratory,
Charles Elly is the EPA Region V SMO Coordinator.  Elly  will determine
Whether samples will be sent to a NCL or to the CRL to be analyzed.
All prospective Samplers (FIT excluded - FIT and TAT have designated
SMO Coordinators) must contact Elly.  Elly also arranges for all  analy-
ses to be done under Special Analytical Services (SAS -  see Attachment
f2), as well as distribute SMO Traffic forms.  Curtis Ross determines
the disposition of "Toxics" or other types of samples.

     Charles Elly resolves questions as to whether to analyze samples
which were not collected according to the SMO protocol,  inclusive of
FIT collected samples.

     When completing the ESD Sample Request form, as much information
as possible should be provided about the site.  This will help to
assure the safety of laboratory personnel handling the samples and will
assist in the proper selection of analytical methods.

                         Contractor Pefinitions

     Generally, samples are divided Into three categories:  low, medium,
or high hazard.

     Low hazard samples are normally be groundwater, leachate, or sur-
face water.  (Concentration ranges from 0 to 10mg/l  (10 ppm)) of con-
stituents.
     Medium hazard samples are up to 152 (150,000 ppm) of a single
hazardous constituent.  They are, for example, samples of materials
lying along side of a drum.  The lower range for medium hazard samples
is 10mg/l (10 ppm)*

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                                    -3-

       High hazard samples are samples of hazardous waste materials, gen-

  erally* the contents of drums.  (Concentration ranges from 15Z to 100Z.)
  These samples are usually sent to the National Enforcement Investiga-

  tions Center, Regulated Substances Laboratory in Denver, Colorado, for

  dilution and extraction, and then sent to a NCL, the NEIC or the CRL

  for analysis.  Following are the turnaround times which NCL's are

  required to provide:


       - Low Hazard Samples:  waters; organic and inorganic analyses:
         AO calendar days.

       - Low and Medium Soil and Sediments:  Organic and Inorganic analy-
         ses :  30 calendar days.

       . Medium waters:  30 calendar days.

       - High Concentration Samples:  21 calendar days at the NEIC and
                                      30 calendar days at a MCL

        (The total number of calendar days is equivalent to 51 calendar days.)

       - SAS:  No set limitations  (see Attachment fl).


               B.  LOW HAZARD SAMPLES (Water, Soil,  Sediment)
                Bottles,  Preservation, Holding Times,  Forms,
               Quality Control, Custody  and Shipping Procedures


        Each low hazard sample collection by either FIT,  TAT,  or EPA

   personnel shall consist of the following:


   1.  ORGANICS:  Water

   •  1-one gallon glass bottle (teflon-lined caps) or 2-half gallon
      glass bottles; iced to 4*C.  MAXIMUM HOLDING TIME:   2 days until
      extraction*

.   -  2-40ml glass Volatile Organic Analysis (VOA) vials (duplicates);
      iced to 4*C (teflon-lined caps).  MAXIMUM HOLDING TIME;  7 days.

                 Soils and/or Sediments
   -  1-8 ounce glass wide-mouthed bottle (teflon-lined caps) iced to
      4*C (filled no more than three-fourths full with sample)*

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                                     -4-

    2.   INORGANICS;  Water

    -   1-one liter high density  polyethylene bottle (metals, 3ml 1:1 HN03
       preservative).* MAXIMUM HOLDING TIME;  6 nonths.

    -   l-360ml high  density polyethylene bottle (Mercury, 3ml 1:1 HN03 pre-
       servative).  MAXIMUM HOLDING TIME;  14 days

    -   l-360ml high  density polyethylene bottle (Mercury, 2ml of HNC>3-»*.2Cr207
       preservative).   MAXIMUM HOLDING TIME;  28 days.

    -   l-500ml high  density polyethylene bottle (NHj+TOC, 2ml 1:1, ^SO^
       preservative, 4*C).   MAXIMUM HOLDING TIME;  28 days

    -   l-500ml high  density polyethylene bottle (pH+F~, General Chen., no
       preservative, 4*C).   MAXIMUM HOLDING TIME;  48 hours.

    -   1-one liter high density  polyethylene bottle (CN~, 5ml 6N NaOH
       preservative, 4'C).   MAXIMUM HOLDING TIME:  14 days.

    -   1-one liter high density  polyethylene bottle (S~,  8ml, Zinc  acetate
       preservative, 4*C).   MAXIMUM HOLDING TIME:  7 days.

    -   1-one quart glass wide-mouthed bottle (Oil/Grease, 10ml  1:1  ^SO^
       preservative).   MAXIMUM HOLDING TIME;  28  days.

    -   1-one liter high density  polyethylene bottle (Phenols,  10ml  CuS04-
             preservative,  iced  to 4*C).   MAXIMUM HOLDING TIME;   48 hours.
        INORGANICS;  Soils and/or Sediments

    -  1-8 ounce plastic wide-mouthed bottle (iced to 4°C). (Filled no more
       than three-fourths full with sample).
    *NOTE:  The pH of the sample should be checked in the laboratory, upon
            receipt of sample.  If the pH is over 2, more HN03 should be
            added to bring it to 2 or below.
         All low hazard samples should be preserved before arrival at the
    CRL (or a NCL), according to procedures listed above, Which are consis-
    tent with those on pages VI-4 thru VI-6 of the Draft NEIC Manual (en-

    titled "Enforcement Considerations-for Evaluations of Uncontrolled

    Hazardous Waste Disposal by Contractor's" Manual, National Enforcement

••   Investigations Center (NEIC), Denver, Colorado; April, 1980.  The
   .amounts of preservatives recommended are consistent with DOT regula-

    tions, therefore, the samples can be shipped via Air Freight.

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                                   -5-
                          Field Quality Control

      For low hazard water camples, a reagent blank IB required for each
 type or group of parameters (especially those Which require preserva-
 tion)*  In all cases, the bottles must be the same as the sample bottles
 and must be filled with distilled-delonited or carbon-free water and
 the preservative, if any.  This "field" blank should be taken to the
 site where the real samples are collected and handled under the same
 conditions as the samples.

      For low hazard water and soil/sediment samples, a "field" dupli-
 cate is required for every ten samples collected.

      The requirements for a field blank(s) and duplicate(s) is an EPA
 national quality assurance mandate and is fully implemented in Region
 V.  The purpose is to detect laboratory and/or field contamination and
 variation.

      As a minimum, there should always be at least one field reagent
 blank and duplicate per survey.  Ideally, one blank and duplicate per
 ten samples should be collected where practical.  If only one or two
 samples are collected and are critical, the Sampler should use  judgment
 regarding collection of the blank and duplicate.

                       Chain of Custody Procedures

      EPA Region V and FIT/TAT personnel must use the Region V "Chain-
 of-Custody Record" (from the EPA's Office of Enforcement)  and Custody
 Tags.  All samples to be tracked by  CRL personnel must contain CKL
 sample numbers.

      Attached is a memo from Robert  Laidlaw, NE1C  (Attachment 13),  to
.•Thomas Yeates, Region V DPO, which excellently highlights the chain-of-
 custody and should be used as a reference.   Please note the requirement
 of a separate custody record for samples shipped to different labora-
 tories and a separate custody sheet  for each sampling site.  Do not

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                                     -6-
   put more than one survey on the same custody sheet (example:  Breiten-
   •tine, Bershberger and Lake County Landfill surveys were  all put on
   the same custody sheet).  Each site of a facility should  be listed
   separately.

        Low hazard samples »ay be brought into the CRL; however, samples
   •ay also be shipped from the field, providing the following protocol is
   strictly adhered to - all samples which will be sent to a NCL should be
   accompanied by:

            The SMO Organics Traffic Report
            The SMO Inorganics Traffic Report
                      rlmiauuy Cample Number	•	
         Jt.  The Region V BSD Chain-of-Custody Form(s)
         >.  The Region V BSD Custody Tag(s)
         >.  The Region V BSD Custody Seal
         F.  Stick-On Label removed from the Traffic Report
     __J	The-*egluu V BSD Bablc DaLa Fuim (for samples \
   *Required of TAT, Regional EPA and FIT personnel.
        All samples  (organic and inorganic) are to be shipped via Federal
   Express, Purolator, or Emery.

  W     Charles Elly (or his designated alternative) should be notified
   prior  to shipment of the samples.  Elly will contact the Sample Manage-
                         __
   ment Office (SMO) for EPA and/or TAT, obtain a case number, and the NCL
   to which the samples will be sent.  Under no circumstances is  the  Sam-
   pier to call the  SMO or the NCL.  This protocol must be adhered to by
   EPA and TAT personnel.  FIT personnel make  its own shipping arrange-
   ments  with the SMO.

                            Packaging and Shipping
'         Before shipment,  the Sampler must provide the following:  (FIT is
<.  -exempted)
    1.   Check to make certain the stick-on label(s) from the Organic and/or
        Inorganic Traffic Report form(s) is sticking to the bottle(s), along

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                                                      -7-

                        vith the Custody Tag(s) and that the Custody Tag(s)  coincide with
                        the CRL Sample Number(s) written on the Traffic Report  sheets.

                        Complete all of the information on the Organic and/or Inorganic
                        Traffic Report(s).  The top (SMO copy) and pink (Regional copy) of
                        the Organic and/or Inorganic Traffic Report(s) should be sent  to
                        Charles Elly no later than two (2) work days after sampling.
                    NOTE:  The Air-Freight Bill Number and Carrier Company has to be called
                           in to Charles Elly the same day of shipment (before 4;00 PM,  CDT).
                           The Sampler will have to make a copy if he/she desires one; all
                           other sheets must be enclosed with the samples.
                    3.  Place the original Chain-of-Custody Form sheet(s) in a plastic,
                        water-proof envelope and enclose it with the samples.  Send the
                        yellow copy of the Custody Sheet to Charles Elly.  The Field Samp-
                        ler keeps the pink copy.  Also, send Charles Elly a partially com-
                        pleted CRL Priority sheet (ESD and TAT personnel only) with Items
                        12, 13, 16, 18, 19, and 110 completed.  Indicate under the "Remarks"
                        Section the assigned CRL Sampie(s) Number and where the samples
                        were sent.
                         The same protocol is to be followed for samples brought (self-

                    delivered) to the CRL for shipment.  The partially completed Priority

                    sheet should be given to Charles Elly to fill in the appropriate CRL
                    Data Set Number(s), Sample Number(s), Case Number(s), and the location

                    of where the samples will be shipped.


                            C.  MEDIUM CONCENTRATION SAMPLES (Water, Soil. Sediment)
                                     Bottles, Preservation, Holding Times,
                                     Forms, Custody and  Shipping Procedures
                         The following  requirements apply  for:
                         ORGANICS
I
1-8 ouncewide-mouthed , round, clear glass Jar with screw-neck
finish and teflon-lined cap (KERR AC802 brand or equivalent;
available from VWR Scientific - Catalog No. #1694-063); filled
one-half to three-fourths full with the sample.  No ice or preserv
ative.  MAXIMUM HOLDING TIME;  Not established yet.

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                                                       -8-
                         INORGANICS*   ->  5 O
S
                         1-8 ounce wide-mouthed, round, clear plastic  or glass jar with
                         •crew-neck finish and teflon-lined cap;  filled one-half  to three-
                         fourths with the sample.  No Ice or preservative*  MAXIMUM HOLDING
                         TIME: Not established yet.
                    *A separate sample must be collected for organic and inorganic, since
                     the samples will be sent to two different laboratories.
                          Field Quality Control

      For medium hazard water or liquid samples, a reagent blank is re-
 commended  for  each type or group of parameters, for example, one blank
 for organics,  one blank for sulfides, etc.  The bottle should be the
 same type  as the  sample bottles and must be filled one-half to three-
 fourths full with diatilled-deionlzed or carbon-free water.  This
 "field" blank  should be taken  to the site where the real samples are
 collected  and  handled under the same conditions as the samples.

      For medium water and soil/sediment samples, a "field" duplicate is
 required for every ten samples collected.

      The requirement for a field  blank(s) and dupllcate(s) is an EPA
 quality assurance mandate and  is fully implemented in Region V.  The
 purpose is to  detect laboratory and/or field  contamination and varia-
 tion.

      As a  minimum, there  should always be  at  least one  field  reagent
 blank and  duplicate per survey.  Ideally,  one blank  and duplicate  per
 ten samples should be collected where practical.  If only one or two
 samples are collected, the Sampler should  use judgment  regarding collec-
 tion of the blank and duplicate.

                       Chain-of-Custody  Procedures
•• t ,   •  -                             "

      The same  procedures  as  outlined for low hazard  samples (see page
 "5" of this protocol) should be used.

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                                                        -9-
                                                      Shipplng

                          All medium samples ( organic s and Inorganics) are to be chipped via
                     Federal Express, Purolator, or Emery Air Freight*

                          Guidelines for shipment of medium concentration hazardous waste
                     samples are contained in the Draft NE1C Manual, 1980.  Sampling should
                     be carried out so as to collect only one phase per sample, if possible.
                          Medium hazard concentration samples^ must^ be , shipped in cans v^a
                             Express,
                          Samples should be packaged as described in the NE1C Manual, and
                     shipped according to DOT regulations.  Each sample is packaged in an
                     outer metal can with clips, tape or other positive seal.  Each can
                     is marked with the destination name and address; indicate "Flammable
                     Liquid, N.O.S." (if not liquid, "Flammable Solid", N.O.S.) and "Cargo
                     Aircraft Only" on the outside.
I
     Inside the can, the sample is sealed inside a plastic bag.  Vermi-
culite is used to cushion the sample inside the can.  Traffic or labor-
atory numbers should be written on the inside sample tag and outside of
the cans.  Hazardous labels should also be placed on the inside and out-
side of cans.

     If Federal Express is the carrier, the form "Federal Express  Ship-
ping Certificate for Hazardous Materials" (FEC-S-0147) must accompany
the shipment.  Other carriers have an equivalent form.

     The same SMO Traffic forms are required, as for low hazard  samples.
However, on the Organic and Inorganic Traffic Reports it must be noted
that the samples are "medium hazard concentration water, soil, or  sedi-
ment"*

     Charles Elly (or his designated alternative) should be notified
prior to shipment of the samples.  Elly will contact the SMO  for EPA

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*
                                                        -10-
                      and/or FIT, obtain a case number, and the NCL to which the samples
                      will be sent.  Under no circumstances is the  Sampler to call the SMO
                      or the NCL.  This protocol must be followed for EPA and TAT personnel.
                      FIT personnel makes Its own arrangements for  shipment with the SMO.

                               D.   HIGH HAZARD SAMPLES (Organic/Inorganic Liquid or
                                    Other Phases Collectable From Drums  or Around Drums)

                           All high hazard samples should be collected according to the Draft
                      NEIC Manual.
                                        Bottles, Preservation, Holding Times,
                                        Forms, Custody and Shipping Procedures
                           ORGAKICS AND INORGANICS (All fractions; liquids and solids)
                           1-8 ounce wide-mouthed, round, clear glass jar with screw-neck
                           finish and teflon-lined cap (KERR AC802 brand or equivalent; avail-
                           able from VWR Scientific - Catalog Ko.#1694-063); filled one-half
                           to three-fourths full with the sample.  No ice or preservative.
                           MAXIMUM HOLDING TIME;  Not established yet.
                           Table I contains an itemization of the sample sizes which are re-
                      quired to analyze each fraction.

                                               Field Quality Control

                           A blank Is not required.  Duplicate sample (s) should be collected,
                      wherever possible.

                                            Chain of Custody Procedures

                           The same procedures as outlined for low and medium hazard samples
                      (see page "5" of this protocol) should be used.
REQUIRED FORMS t
     1.  The SMO High Hazard Traffic Report (not required If analyses
         will be done at the CRL).

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                                                         TABLE 1
                                        SAMPLE CONTAINER AND QUANTITY REQUIREMENTS
                                  Requests
                       Recommended
                        Quantity
                        Required
Shipping
Container'
                         ROUTINE REQUESTS;

                              Total Metals, Strong,     60 grams
                              and Weak Acid Anions

                              Total Mercury              3 grams
                              Base/Neutral, Acid,        6 grams
                              and TCDD

                              Pesticides/PCB             6 grams
                              Volatile  Organics          6 grams
                                      8 ounce or smaller jar
                                      with Teflon-lined cap

                                      8 ounce or smaller jar
                                      with Teflon-lined cap

                                      8 ounce or smaller jar
                                      with Teflon-lined cap

                                      8 ounce or smaller jar
                                      with Teflon-lined cap

                                      8 ounce or smaller jar
                                      with Teflon-lined cap
                          SPECIAL REQUESTS;

                               EP Toxiclty


                               Corrosivity


                               Ignitability
                        300 grams      1  quart glass jar with
                                       Teflon-lined cap

                          1 liter      1/2 gallon glass jar
                                       with Teflon-lined cap

                          1 liter      1/2 gallon glass jar
I
* Obtainable from VWR Scientific; Catalog No. 116194-063.

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                                                     -12-
                         2.  The NEIC  Hazardous Waste Sample Preparation Request
                         3.  The CRL Sample  Number
                         4.  The Region V ESD Chain-of-Custody Form(s)
                         5.  The Region V ESD Custody Tag(s)
                         6*  The Region V ESD Custody Seal
                         7.  The Region V ESD Basic Data  Form (for samples analyzed at the
                            CRL only)

                                             Packaging  and  Shipping

                         The requirements are the same  as outlined for medium hazard  samples.
                    (Please read carefully and follow guidelines as  outlined on pages 9,  10,
                    and 11.)

                         Shipment of high hazard samples  directly from the field is encour-
                    aged.  The samples are mailed to the  EPA,  NElC-Regulated Substances
                    Laboratory, c/o Dr. Steven Kunen, Fred  C.  Hart Associates,  (an EPA
                    Contractor), Denver Federal Center, Building 53, Box 25227, Denver,
                    Colorado,  80225.

                         One extra high hazaTxSf^unr'must accompany all samples.  This is
                    for an NEIC preparejt-re'agent blatok.  Spike, matrix spike and duplicate
                    results will^e added to the Sample Trafi^c form.
          The Air-Freight Bill Number and shipping company? must be phoned  in
     to Charles Elly the same day, or early the next morning  (as  soon as
     possible).   (FIT exempted.)

  4       Charles Elly will contact Fred C. Hart  Associates approximately
 i?   two  (2) weeks in advance of each projected on-slte sampling  survey to
V ''
     verify whether Hart Associates will accept the  samples.   The EPA, FIT
     of' TAT Sampler must contact Charles Elly before  shipment to  Denver.

     Copies of all the aforementioned items must  be  forwarded to  Charles
     Elly immediately after shipment (24 hours or less).  (FIT exempted.)

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                                  -13-
     Tbe turnaround tine quoted by EPA, NEIC and Hart Associates Is
twenty-one (21) days for routine samples.  (NOTE:  This Is only for
extraction.) Further organic and inorganic analyses will be done at
the CRL or a NCL, which will require additional turnaround time (prob-
ably -30 more days).

     For samples which go directly from the NEIC (or Hart Associates)
to a NCL, the Sampler forwards the SMO High Hazard form mentioned  above.
The NCL will forward the final sample analyses results to the Region V
CRL.

                        E.  Tracking of Samples

     Tracking of EPA and TAT forwarded samples is done by Charles  Elly.
This is accomplished through the use of the attached Table  (2) entitled
"Status of Region V Hazardous Waste Samples".  This Table is kept  in a
logbook and includes information beginning from the time of collection
of the samples through the date of final analysis.  The  CRL Data Manage-
ment Coordinator tracks data at the CRL after a copy of  the Traffic
Form(s) and Custody Sheet is given to William Sargent,  CRL16 Shipping
and Receiving Clerk, who logs in the sample numbers and  assigns a data
set number (for EPA and TAT samples).

                      F.  FIT Tracking of Samples

     The FIT Contractor tracks its own samples.  This was delegated
from ESD to FIT to lessen the paperwork and burden on Region V EPA
personnel, as well as to speed up data turnaround.

     As a minimum, FIT transmits weekly  (each and  every Tuesday), to
Charles Elly, the following:
     Sample collection date; sample shipment date;  sample  type  (low
     hazard soils, medium hazard concentration waters, etc.); National
     Laboratory samples were shipped to  (and/or  NEIC); NEIC Traffic
     numbers (Inclusive of the  total number of samples); SMO Case
     Number, CRL Numbers, and projected  date of  return.

-------
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-------
                                       -15-

            G.  DATA SUBMITTAL AND RESPONSIBILITIES (FIGURE  1)

The NCLP data are sent directly to the CRL.   A date of receipt  is  stamped
on the data and-it is given to the Data Coordinator.  The Data  Coordinator
logs the data onto the Internal Tracking Sheet (Form 3) which includes the
SMO Case and Traffic numbers. CRL Number(s), Decision Unit,  Site Name and
CRL Data Set Number; date information is assigned;  listing of outstanding
data not received; and the date the data is  sent to the user.   The Data
Coordinator-also completes and attaches a form entitled "Review of Region V
Contractor Data" (see Attachment *4).  Elly  passes  the organic  data on to
Kendall Young, CRL Organic Section Chief, who assigns a organic reviewer
to the data.  Inorganic data is passed from  Charles Elly to either
Dr. John Morris, CRL Metals Team Leader or Ms. Andrea Jirka, CRL Minerals/
Nutrients Team Leader for review.  Charles Elly may also review inorganic
data, if the Team Leaders are scheduled for  other duties.

Once the data have been reviewed by Organic  and/or Inorganic Laboratory
Section reviewers, it is returned to Charles Elly.   If quality  control
(OC) deficiencies or out-of-control audits were noted by the reviewer(s),
the data is passed to Ms. Marcia Kuehl, CRL  Acting Quality Control Coordinator.
Ms. Kuehl tallies these OC deficiencies and  makes a recommendation as to
whether the data should be released to the data user.  Recurring OC violations
and deficiencies with laboratories are documented and Dr. Eugene Meier,
EMSL-Las Vegas, is notified through Dr. Alfred Haeberer.  If the data are
considered unacceptable for use, Elly is notified and the data  are returned
to him to arrange either additional sampling or re-analysis.

Data that has passed through review hy the Organic and/or Inorganic Laboratory
Section reviewers with no OC deficiencies or out-of-control  audits noted,
are directly returned to Charles Elly for final review.  The Data  Management
Coordinator is responsible for actual data transmittal to the  data user.
A xerox copy of the data is made and attached with a cover memo (Attachment  #4)
which notes OC violations, if any, that affect the data.

QC flags are noted on Attachments #4 and #5  (for organic data  only).
Attachment #5 is a draft of the "Regional Review of Uncontrolled Hazardous
Waste Site Contract Laboratory Data Package" and has been revised  to suit
Regional needs.  This review form is to he sent to the SMO when OC problems
requiring total rejection or organic data occur and is routinely sent to
the data user.

The following two Sections explain the criteria and specific acceptance
limits used hy the CRL data reviewers.

                     H.  REVIEW OF INORGANIC CLP DATA

The following items are checked, hy the Inorganic reviewers, and deficiencies
and/or out-of-control audits are entered on  Attachment 44.  Form #6 must be
completed for all SAS case data and sent to  SMO only.

-------
oF
                                 -16-
                                             *€Y»ti>J
                                  f Smo  \
*'. i >
                                                                                I I

-------
                                  - 17-

1.  DATA SHEETS should be legihle, in sequential  units anrl the minimum
    detection limits should be listed with the  instrument noted.

    ACTION:  Call SMO

2.  FINAL DATA PACKAGE should contain:

    ALL Tasks:  Results for each sample to two  significant figures
                List of detection limits used,  supporting raw data

    TASK 1:  ICAP or validated alternate results  for  Al, Cr, Ba, Be,
             Cd, Co, Cu, Fe, Pb, Ni,  Mn, Zn,  B, V,  Ca, Mg, Na
             *Inorganic Quality Assurance form

    TASK 2.:  Flame/furnace AA results for As, Sb, Se, Tl, Hg, Sn, Ag
             Mnorganic Quality Assurance form

    TASK 3:  a) Low concentration NH3, F, S,  CN,  pH and  TOC  results

             b) Medium concentration  NH3, S,  and  CN results
                Inorganic Duality Assurance form

    *Inorganic Quality Assurance forms contain  initial  calibration  veri-
     fication, continuing calibration verification, duplicate and spike
     results.

3.  METHOD BLANKS should contain less than one-half the  minimum detection
    limit and should he reported on the data  sheets with the results.

    ACTION:  Flag affected samples as contaminated

4.  INITIAL and CONTINUING CALIBRATION VERIFICATION should  be  reported on
    the Inorganics Quality Assurance forms.  Continuing  calibration
    verification should show no drift larger  than that  listed on form 1.
    If this drift did occur, a new initial calibration  curve must  be  included.

    ACTION:  Flag affected samples as having unreliable quantitation

5.  ICAP INTERFERENCE CHECKS should be run at the beginning, end,  and
    once every 20 samples.  Results should be recorded  and  labeled as
    "ICAP Interference Check" on the Inorganics Quality  Assurance  form,
    under Section II.

    ACTION;  Flag affected sample data as possible  biased

6.  LAB DUPLICATES should be recorded on the  Inorganics  Quality Assurance
    fprm and not exceed the following limits for concentrations greater
    tWn the detection limit:

     '  *  ' ' 1)  TASK 1:  RPD <20
             2)  TASK 2:  RPD <50
             3)  TASK 3:  RPD <50

-------
                                  -fe-

7.  MATRIX EFFECT SPIKES should be recorded  on the  Inorganic Quality
    Assurance fprm and not exceed the limits listed  in form 1.

    ACTION;  Flag the affected sample element(s)  data as biased

8.  FIELD PC

    Field prepared duplicates should not  vary by  more than + 20%.  Field
    blanks should be examined for contamination levels > I/? the detection
    limit.

    CORRECTIVE ACTION:  Flag all sanples  in  case  as  being of >20% precision
    and/or containing bottle/sampler introduced contamination (if field
    blank contents vary from lab method blank contents, call field team
    to check on possible sources of contamination or imprecision).

                        .  REVIEW OF ORGANIC CLP  DATA

At a minimun, data reviewers must review  the following eight items in
judging organic data.  Additional review  items are  listed to be pursued
only when time and suspect data quality dictates  it. Forms *4 and #5
must be completed for all routine and SAS CLP cases. Form #6 is for
SAS data and is sent, to SMO only.  Form #2 gives  the current criteria.

A) MINIMUM REVIEW ITEMS:  (Not in order of importance)

   1.  BFP/DFTPP Specs must meet those in contract.

       ACTION:  Flag affected samples data-  if the  out-of-control mass
       not meeting specs, was used to ID  or  quantify a pollutant, it is
       invalid.

   2«  BLANKS  must be clean (< method detection  limit) and sample
       concentration must he >10 X blank  to  he considered valid.

       ACTION:  Flag affected sample data appearing at <10 X blank
       contamination level as due to lab  and/or field contamination.

   3.  POSITIVE PRIORITY POLLUTANT hits must be verified by visually
       checking MS, sample and retention  time match up against standard.

       ACTION:  Cross-out incorrect pollutant and flag as not detected.

   4.  TENTATIVE IP's must be visually checked against spectra supplied  -
       "elegant" compounds should be verified to  see if they could survive
       the GC/MS conditions or if they are artifacts of the operator's
       imagination.

       ACTION:  Cross-out unreasonable compound match and note as unknown

-------
                                                 n
                                               -19-

                5.   HOLDING TIMES should be checked, this  is only to be done if sample
                    is a natural  water or sediment.  Drum  samples are excluded as the
                    time is not crucial.

                    ACTION:  Negative hits should be noted as possibly being biased low
                    for samples with holding times  exceeded, positive hits need to be
                    qualified as not meetiny holding times.

                6.   DUPLICATE PRECISION for both  field  and lab should be within the
                    criteria.

                    ACTION:  Flag only the affected samples/duplicate compound data
                    as imprecise, give actual  RPD.  If  a compound is not detected at
                    all in one sample or duplicate, flag that compound as questionable
                    if the concentration level  is <10 X detection.  If the concentration
                    level is >10 X detection,  flag the  precision of that compound as
                    erratic.  Note any non-homogeneity  of  sample in qualifying statement.

                7.   SURROGATE SPIKE RECOVERIES  should fall  within the criteria.  If any
                    lab notation is made of lab accidents  or reruns, flag data accordingly,

                    ACTION:  Flags depend on the  number and severity of deviations from
                    the limits.  Note that only fractions  per sample are flagged unless
                    a generalization over the whole case can be made.  Guideline levels
                    are given below.
I

-------
 FRACTION

rVQA;
 d5 Toluene
 dg Benzene
                               -EO-
TOTAL NUMBER    f ACCEPTABLE
                     2
                     1
                     0
 ACin/B/N:           4
 d5-phenol(A)
 2-fluorophenol(A)
 d^-nitrobenzeneCB/N)
 2-fluorobiphenyl(B/N)
 TCDO:
 17773,4-TCDD
                     4
                     3
                                     1

                                     0
                     1
                     0
SAMPLE FRACTION
   QUALIFIER

acceptable
related conpound data invalid
unacceptable and/or biased
matrix problem.
acceptable
acceptable with qualification:
note compound class with out-
of-control recovery
if both A or B/N, that class
of compounds invalid biased
if one A and one B/N-data qualified
as suspect
one class data invalid, other
suspect
both compound classes unacceptable
or biased, matrix problem?
dioxin data valid
dioxin data invalid, matrix
problem?
     *'

-------
                                  -21-
8.  MATRIX SPIKE RECOVERIES should fall  within the  advisory limits criteria.
    If any lab notation is made of lab accidents  or reruns, flag data
    accordingly.  The flags only apply to the sample chosen as the spike.

    ACTION:  Flags depend on the number and severity of  deviations from
  r the limits.  Guideline levels are given below:
    FRACTION

    VOA:
    Chlorobenzene
    Toluene
    Benzene
                    I COMPOUNDS      * ACCEPTABLE      SAMPLE QUALIFIER

                                                      acceptable
                                                      actual level of the
                                                      specific compound outside
                                                      limit may be biased
                                                      (compound flaj)
                                                      flag compound(s)
                                                      unacceptable biased
                                                      matrix problem?
    B/N:                 7
    T72~,4-tri Chlorobenzene
    acenaphthene
    2,4-dinitrotoluene
    di-n-butylphthalate
    pyrene
    N-ni troso-di-n-propylami ne
    1,4-diChlorobenzene
    ACID:
    pentachlorphenol
    phenol
    2-chlorophenol
    p-chloro-m-cresol
    4-nitrophenol
    PESTICIDES;
    heptachlor
    aldrin
    deildrin
                                          1
                                          0
                                          7            acceptable
                                          6            acceptable, flag  compound(s)
                                          5            acceptable, flag  compound(s)
                                          4            B/N data biased and/or
                                                       erratic, flag  compounds
                                          3            B/N data biased and/or
                                                       erratic, flag  compounds
                                          2            matrix problem? unacceptable
                                                       biased
                                          1            matrix problem? unacceptable
                                          0            biased

                                          5            acceptable
                                          4            acceptable, flag  compound
                                          3            acceptable, flag  compounds
                                          2            B/N or acid data  biased  and/
                                                       erratic, flag  compounds
                                          1            unacceptable,  biased matrix
                                                       problem?
                                          0            unacceptable  biased, matrix
                                                       problem?
                                          3            acceptable
                                          2            acceptable, flag compound
                                          1            unacceptable biased matrix
                                                       problem?
                                          0            unacceptable biased matrix
                                                       prohl em?

Note'that all of a case's positive sample results for matrix spike compounds
may nee0. to, be qualified if the sample chosen as the spike 1s representative
of the entire case.

-------
                                  -22-

B) AnniTIONAL REVIEW ITEMS:

   1.  New or additional surrogate and matrix  spike  compound  recoveries.
 r                                                              •
   2.  Initial and continuing calibration.

   3.  Tailing factor, benzidine and pentachlorophenol  response.

   4.  Internal standards response stability.

   5.  Choose one positive hit sample/case  and walk  through all calculations
       for A/B/N, pesticides, VOA's.

   6.  Chromatogram quality (GC/MS & GC/EC)

   7.  Blind OA audit results if applicable.

                      I.  DATA USAGE RECOMMENDATIONS

Data that has received QC flags (that render  it  useless to the Oata Requestor)
is brought to the attention of Or. Alfred Haeberer,  EPA Support Services
Branch and Dr. Eugene Meier, EMSL-Las Vegas.   This invalid data may be  remedied
by reanalysis or resampling and subsequent analysis by  another laboratory.
Continuing problems with particular laboratories or analyses  is also  brought
to the attention of these two support people.

Presently, the CRL reviewers use the same protocol to review  all CLP  data
(Sections II ft III) regardless of data user OC requirements.  Thomas  Yeates,
Region V OPO, is in the process of accumulating input from data users as to
the intended objective of the data.  Some data does not require as stringent
OC as others.  Data from sites indicated as less critical, or data intended
as only a screening process will continue to  be reviewed under the same
protocol.  Violations of limits and deficiencies will still be indicated
on Attachment *4, but data may still be judged acceptable ev«»n though limits
have been exceeded or deficiencies found.  The data user will have full
knowledge of the quality of the data and may  request follow-up analyses.

Once the decision has been made to invalidate sample data, no matter what
objective it was to serve, Region V will insist that the samples  be reanalyzed
under the CLP.  Unacceptable data will not be released to the data user.
The data user will be consulted during the decision making process to determine
the degree of OC needed to best serve the data objective.

Once the data has been judged acceptable or preliminary, the CRL  Data
Management Coordinator puts the CRL lab numbers on all  data  sheets and  makes
a .copy.  Within 24 hours after review, the copy of the data  and  Attachment *4
are -sent to the TAT, FIT or EPA data requestor.  FIT and TAT data are
transmitted to Cindy Bachunas (Environment *  Ecology) through the mailbox
in Thomas Yeates1 office.  REM/FIT data will  be initially reviewed by
Paul Friedman, SMO and verified by Marcia Kuehl before release.

-------
                                  - 23-

The entire reivew and transmittal of data should take no longer than  five  (5)
work days, after receipt by the CRL.  Questions regarding the status  of data
should he referred to Charles Elly, SMO Coordinator.   Questions regarding  the
quality of the data should be referred to MS. Marcia  Kuehl,  CRL QC Coordinator.
       V'

-------
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-------
                                                                                     4
                   UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                        REGION V
   DATE: r
SUBJECT:  Review of  Region V-CLP Data
         Received for  Review on
   FROM:  Curtis Ross,  Director
         Central Regional Laboratory

     TO:  Data User:
         We have reviewed  the  data  for  the following case(s).

         SITE NAME:                                       SMO CASE NO.
                                              No. of
         EPA Data Set  No.	Samples	DU/Activity No.
         CRL No.'s
         SMO Traffic No.'s
         Contract Lab;      	Hours required for review:

         Following are  our  findings.
         ( ,-).Data are acceptable for use.
         (  ) Data are acceptable for use with qualifications  noted  above.
         ( " j) -Da
-------
                   REGIONAL REVIEW OF UNCONTUOUn) HAZARDOUS WASTE SITE CONTRACT
                                      LABORATORY DATA PACKAGE
    TO«  U.S. environmental Protection Agency                         CASE NO.
         S**ple Management Office (SMO)                                         	
         F.D. Bo* BIB
      r  Aleiandris, Virginia  22313
                                                                                  •

    The hardpopied (laboratory news) 	data package received st
    Region	_nM D**n reviewed and the quality aaaurance and performance data sum*
    The data reviewed  included!


SMO Sample         Cone.a          SMO  Sample        Conc.i.          SMO  Sample        Conc.i
   No.               Matrix            No.              Matrix            No.              Matrix
     Contract No.           ._ r»qulr«« that  tpeciric •n«lyllc»l work b« 6on«  »r«l thtt w«oel«t*d
     toportt b* provided by tr* contractor to  the Rt^ions, EMSl-LY, »nd SHQ.   T>» gtrwtkl crlttrl*
     used to detacnine th« performance were  based on an examination eft

                 •  Data completeneaa              •  Duplicate analytia reaults
                 •  Spectra welching quality        •  Blank analyaia reeulta
                 •  Surrogate apike results        •  DTTPP and BTB performance results
                 •  Matrix spiks results

     The deta revleu forms for each of the above review itens are contained within  the  body of this
     Cotmentss
                                                 15

-------
                            DELIVERABLE
CASE *_
CONTRACTOR
                                      CONTRACT I
                                SECTION TITLE
        KARRATIVt

        Contains:   Case I,  Contract I, turn* 17 of any QC,  sample,  shipoent and
        analytical  problem*, documentation of any Internal decision tree process
        used.		
  II
     ry SUHKART
    *A.  Surrogate t recovery sMsaaary fora.
    f*B.  Reagent blank suasary form.
    pC.  Matrix splice duplicate/recovery fora
      .  Instruaent tune & perforaance suaaary form
 III
      SAHPLt DATA PACKET
         A.  Saaple Data in increasing SMO I ordert

             1) RSL results.
             2) CC/KS tentative ID sheet, sven if noue found*
             3) Rav data (VOX. AjB/H. P«»t, Diozia)
                i. Cnrooatogrca(s)
               11. Data Systea printout
              ill. HSL spectra with  standard (dual display)
               Iv. CC/KS library  search  spectra
         	T. Quantltatlon/calculatlon of tentative ID eopcentration
  IV
          A.   Cross-reference table (lab's internal)*
          B.   VOA standards chronato&raas and data systea printout*
          C.   A/B/N standards chroaatograas and data systea printouts.
          D.   Pesticide standards chroaato&r&a* and data systea printouts.
          C.   Dtoxin standards chroaatograas and data systea printouts.
          *F.   Intenud standard verification data sKest.
          *C.   FSCC Initial calibration data.
          *H.   Calibration check.
          I.   Current list of lab detection Halts.
Designates new fons.
                                                   (_)33 - OS8

-------
•prpiEST TV" " •"••--—---

          in progress may DC cu**...	


Priority 2 - High priority projects to Ve scheduled and completed
          as soon as possible without disrupting other wort, in


           progress.

 Priority 5 • Projects to Ve completed around Priority I and 2 pro-
           jects, but with some definite completion date, usually

           at least two or three BontKs Croa xequest date.

                                     -- -•— i. ,vai  - -
                -———•


-------
§O.,«CT,
                 For:
    -to.  Project Ob3"*ive:
             Decision Unit

             Desired Completion Date


              Principal Contact:
                                       Specific Activity
               Prom:
Target COB. Date:

ESD Project Uader:
                   .*'.*
                                              tSD project Wo.
                                                                      Phone
          *»*. re*
     I f
    r' '

-------
                ATTACHMENT 12
PECIAL    ANALYTICAL    SERVICES

-------
.





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,.   cyanic,















  ,.
                        PCB
                                      MENU OF
                                                              M
                                            Fast Data Turnaround
                                         -**'


                                          _  Added Capacity
                                             Compounds

              ,.
                        Sample Analyses
                            ,   s
              ,.   RCRA Analyses


               M.  Fused SUicaCapmar, Column Ana.y.«
                12.
                            Analyses

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I
                                  SPECIAL ANALYTICAL SERVICES
            A.   Background

                  In addition to standardized types ot analyses provided under the Contract
            Laboratory Program, the Sample Analysis Program has established a system to
            provide limited custom or Special Analytical Services 1SAS) which are beyond the
            scope of the current laboratory contracts and/or available protocols but which are
            consistent  with Program objectives.  Upon  a sampler's  request and  Program
            authorization, the Sample Management Office  will arrange for analytical services
            Including  but not limited to quicKtumaround analyses,  verification  analyses,
            Identification and quantification of  non-priority  pollutant compounds, general
            waste characterizations, RCRA, Dioxln and other  specific  analyses.  The Sample
             Management Office,  In Its continuing performance of sample scheduling, data
             integration functions, and data base preparations, procures these Special Analytical
             Services by subcontracting with laboratories currently in the Contract Laboratory
             Program to perform the required task.

            B.   SAS Initiation

                  Depending on the complexity of  the  Special  Analytical Service request,
             special services can be Initiated in fairly short periods of time; however, because
             the SAS program requires SMO to procure laboratories on  a competitive basis, at
             least a weeks lead-time is  recommended.  In general, the institution  of  Special
             Analytical Services, because of protocol diversity  and specific laboratory procure-
             ment procedures, demands greater advance  planning  and more lead-time than
                                            •                              •
             required for the standard laboratory analyses programs.
                                                 m-i

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I
I
1

                          pr
                            ocedures.
                                               ^  * authorlzetrrepresentau              oi
                                                                                ,< rcauired data



                                           reeel?t'

                                           
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 I
I                             Additionally, ft written request document should be forwarded to
                             SMO after the initial verbal contact.
 I
 1
1
b.   Program Authorization and Protocol Confirmation

     As the SAS program b an extension ol the Contract Laboratory
     Program, the EPA Program Manager must review and approve
     qualified SAS requests.  If a SAS request b authorized which
     requires a non-program methodology, the Quality Control/Quality
     Assurance Officer (EMSL/LV)  confirms  the  validity  of  the
     requested analytic protocol, amending  It as necessary.  If the
     request is denied, tht Program Manager  indicates the reasons for
     denial.

C.   Pre-Samplina Procedures

     li accepted, the Sample Management Office telephones the SAS
     requestor to coordinate the sampling, sample shipment and analy-
     sis requirements.

      (1)   SMO  and the sampling coordinator  agree to sample label
           numbers and any site or specific coding Information to place
           on tracking documents and sample  bottles.  SMO provides
           the name and address of the analytical laboratory alter a
           subcontract Is awarded.

      (2)  SMO forwards  tracking documents to  the  SAS user, or
           arranges to have them supplied by  the EPA Regional con-
           tact.

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I
I
1
I
1
I
1
          (3)  The SAS sampling coordinator  provides  all cample  and
               tracking documents/instructions,  etc.  to  sampling team
               leader (communication with SMO if necessary).  Sampling
               takes place.

          (4)  Sampling team leader telephones SMO after sampling  with
               appropriate shipment information which includes:
I                                o  Date and time of shipment.
                                 o  Any changes in the sample numbers, types, etc. as
|                                   specified in the SAS.
                                 o  Numbers of containers, confirmation of sample ID num-
I                                   bers, special instructions.
                o  Air carrier and airbill number.

2.   Sample Tracking

     SMO will  track  the  sample/sample fraction from the sampling site
     through  the labor atory(ies) in accordance with established Program
     procedures.  SMO will provide and monitor all sample tracking forms
     and related documentation.

3.   Data Receipt

     a.    The laboratory will forward all data and other relevant document
           copies to  SMO.   SMO  validates the data tor completeness,
           deliverables completion within contractually-specified time per-
          'tods, and adherence to all terms of subcontract.

      b.    The EPA Program Manager and Technical Officer are responsible
           lor technical validation of the data results.  The  EPA QA/QC
           Officer is responsible for the validity and accuracy of the quality
           control data.
                                                m»*

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c.
while
conned. «.  r«.e«n« *.  k .or-W  -  -
p,,.-* bourc*. EMSL B reined, etc.)  SMO  w

copy 1« possible future reall.

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                                        ATTACHMENT f3
  . •   .                       ENVIRONMENTAL PROTECTION AGENCY
                                   OWCE O? ENFORCEMENT
                         NATIONAL ENFORCEMENT INVESTIGATIONS CENTER

                                    KNVU. COIORAOO  ao«s

           Tom Yeates                                       *n  February 10,19B2
10     .  .  &PD. Region V


..o* .      Rob Laldlaw
           Evidence Audit Unit, MEIC
           Chain-of-Custody
            As per our earlier discussion, 1 am enclosing copies of sample tags and
            chaIn-of-custody records filled out as an example of a hazardous waste
            site investigation.  Also enclosed ere EPA sample control and chain-of-
            custody  procedures (October 1980).
              •
            Some specific concerns regarding documentation of custody are:

            1.   All members of the sampling team for a  particular investigation
                 should  be listed on the sample tags and custody records.  This
                 provides a consistent record of individuals participating.

            2.   All information recorded on a sample tag should be  identical to the
                 custody record (station No., station description, date, time,
                 project name* etc).  This also provides consistency of documentation.

            3.   Station location descriptions need to be designated and all personnel
                 refer to them in the same manner.  Elimination of estimating by
                 different  investigators is desirable.  For example,

                 one person records on a tag. station Ol...leachate 10 yds from SE
                 corner of  storage shed,

                 another person records on a custody record, station 01... leachate
   ^ .          100 feet from SE corner of storage shed.
     •
                 Even though the sample was  taken at one location, the records show
                 a difference of 70 feet.  This is a very conroon type of documenta-
                 tion problem.
              *"
    »^       4.  VA11 blanks on tags and custody records should be filled out to the
              '  extent possible. This assures that all necessary information is
                 recorded.

    .»        S.   The first name in the "Relinquished by"  box on the custody records
                 must be one of the names listed as a sampler on line 2 (see example).
                  If not, there is a potential break in custody in the documentation.

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2.
3.
4.
 5.
                       Federal Express »9° JRetTto them
                                                       .
     , —
      ""'                 «•«"
1   jfli samples «»— —
    "^        . .__, _ t*. tta of colUdion untU shipped.

                                                     .  «*
                  receded secured.
               were stored in a secured area.
    S.  Bench records show names of analysts.

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ese resort.                                        ^ w (ns
„ , «., be of further .ssUUnce. »1e«e fee! free to

234-4706).
 Enclosures

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-ir

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                        ctdafe fa* 51
ri

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 Projeel Cod*

 COO
           Sution No
                                     Tune
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                               to
                              Starters (Signature*)

                                          0
                                              r>
.BOO Anions
So.'idj USSIlTOSMSS
ANALYSES
                                       *
                                                             t

                                                             I

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*'.!  /

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                       r'OtltttO*
                  '..»' -•'
• I

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                                  DELIVERY ORDER
                                  Under Provisions of
                              EPA Contract No. 6S-01-656S
                                                                 Order No.
Date of Order

FROM:
(Requestor
 name, address
 & telephone)
TO:
                            Emergency Order:  	
                                                     (date & time order called in)
                                (signature)

              Repository Project Manager - Analytical Services Center
              Ecology & Environment, Inc. - P.O. Box D - Buffalo, NY 14225
              Telephone:  716/631/0360
Please ship the following items for arrival by:
    Order is designated for shipment to a temporary field location (e.g., hotel, local carrier
    office). Please ship order to arrive no earlier than:   	
                                                                 (date)

                                                                   CONTRACTOR
                                                                     USE ONLY
Ite
N.
1
2
3
4
5
6







sm N
o. Description
1/2 gallon amber glass bottle
40-mL borosilicate glass vial
1-L high-density polyethylene bottle
500-mL polyethylene bottle
16-oz wide-mouth glass jar
8-oz wide-mouth glass jar

Ship To:
(Designee
street address)

Attention:

lo. of Items No. of Cases No. of Cases
Per Case Ordered Shipped
12
100
76
161
4&
96







 CONTRACTOR USE ONLY

 The above materials have been shipped as requested.

 Date Shipped: 	     Mode of Shipment:
       ' - ' * '	     A/B, UPS BOL No:
Signature:
Type of Order:     Routine	
                                   Emergency	
Partial	       Complete_
    DISTRIBUTION: White - Repository Copy, Yellow - Repository Copy for Return to SMO,
                    v.  Pink - SMO Copy, Gold - Requestor File Copy

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\
 )
                CURRENT CLP SMO IFB ANALYSIS LABORATORIES

     :       -"
                             Organics - Multimedia

  California Analytical Laboratories, Inc. (916) 381-5105
  5895 Power Inn Road
  Sacramento, CA 9582*
        Attn:  Bonnie McNeil            'ALTERNATE:  .Julia Frey           -   ^
        (916) 381-5105
                             Organics - High Hazard

  California Analytical Laboratories, Inc. (916) 381-5105
  5895 Power Inn Road
  Sacramento, CA 9582*
        Attn:  Bonnie McNeil            ALTERNATE:  Julia Frey  •
  West Coast Technical Service   "      (714)523-9200
   17605 Fabrica Way, Suite D
  Cerritos, CA  90701
        Attn:  Linda Krokenberger       PRIMARY:  Jack Northington

                             Inorganics • Multimedia

  United States Testing Company, Inc.  *  (201) 792-2400 -ext  253
   1*15 Park Avenue
  Hoboken, N3  07030 (Hudson)
        Attn: AlTordini                ALTERNATE:  Richard Posner  (ext  320)

   Rocky Mountain Analytical Laboratories, Inc.  (303)421-6611
   5530 Marshall Street
   Arvada, CO  80002
0. ;r - Attn: TonyMaiorana                  PRIMARY:   Mark Carter

   Ghem tech Cons-jlting Group, Ltd.  '   (212)255-2100
   36b West .11. th Street .
'•'  NeW'ToVlq-NY 1001* '             -  -. • ;
      ;; */f> -•< * ^           -                   -
,, -.-„  , ^AUn: ^5r. Alan Schof iman       ALTERNATE:  Frank Brezynski
  r~.vj* "^"•'•^y v -•
 '  ff^r^ff- • ' -  -,' -
,'. ^^ri'/Mefe'-   ;                     (703)750-3000  •
  ,'1se>2i K
  ,.   '.v:iAhh:.3$netBeckman   •         PRIMARY:   Richard Ronan
  * C.1" -i^1'" I. '.•'•'

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                       Inorganics - Multimedia (cont'd)
University of Washington
College of Fisheries
108 Fisheries, WH-10
Seattle, WA 98195   -
     Attn:  Dr. A. Nevissi
California Analytical Laboratories, Inc.
5895 Power Inn Road
Sacramento, CA 9582*
     Attn:  Bonnie McNeil

3TC Environmental Consultants, Inc.
7979 Old Georgetown Rd.
Bethesda, MD  2001*
     Attn:  Deb White
           (206) 543-4259



           ALTERNATE:   John Sung
           (916) 381-5105


           ALTERNATE:   Julia Frey

           (301) 656-5850



           ALTERNATE:   Jeanne Hankins
West Coast Technical Service
17605 Fabrica Way, Suite D
Cerritos.CA 90701
     Attn:  Linda Krokenberger

Energy Resources Company, Inc.
185 Alewife Brook Pkwy.
Cambridge, MA 02138

     Attn:  Dallas Wait
Mead Compu/Chem
P.O. Box 12652
3308 Chapel Hill/Nelson Hwy.
Research Triangle Park, NC 27709
      Attn:  Angie Frye
Laucks Testing Laboratories, Inc.
9*0 South Harney
King County
Seattle, WA 98108
      Attn: Mike Nelson

California Analytical Laboratories, Inc.
5895 Power Inn Road
Sacramento, CA 9582*

      Attn: Bonnie McNeil
Organics - GC Screen

           (714)  523-9200
           PRIMARY:   Jack  Northington

           (617)  661-3111



           PRIMARY:   Tyrone  Smith
           (919)  549-8263  ext  224
           PRIMARY:   Becky  Siebert/ALTERNATE:
           (206)  767-5060
           ALTERNATE:   Barbara  McNatt
           (916) 381-5105



           ALTERNATE:   Julia  Frey
Paul Mi'


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\
                             Organics - GC Screen (cont'd)
)
         U.S. Testing Company, Inc.
         1*15 Park Avenue
         Hoboken, N3 07030 (Hudson)

              Attn: AlTordini     •

         Hazleton-Raltech
         3301 Kinsman Blvd/P.O. Box 7545
         Madison, Wl 5370*
               Attn: David Hills

          EAL Corporation
          2030 Wright Avenue
          Richmond, CA  9*80*
               Attn: George Caesar, 3r.

                                   High Hazard Containment

          Fred C. Hart Associates               (312) 234-2683
          Regulated Laboratory
          Denver Federal Center
          Building 53 (Green Trailer)
          Denver, CO 80225
                Attn: Steve Kunen
                                          (201) 792-2400 ext 253


                                          ALTERNATE:   Richard Posner (ext 320)

                                          (608) 241-4471


                                          ALTERNATE:   Chris Alstetter/Emilio Sturino
            'frti":
                                                                  Revised 1/3/83
                                                /TV /'  J
            * * t'

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       SECTION TITLE
       KAU QC PATA FADTT

       A.  PFTP?

          •1) CC/MS  performance standard fom.
           2) Bar graph apectrua.
           3) H;Z ll«ting.

       i.
           *1) CC/MS performance ataodard fora.
            2) B*r graph •p*ctrua.
            3) H/Z littinj.

        C«  Chroaatogtaphy Cbtck Data
            1) B«uidia«
            2) ?civtachlorophcnol ZICT'a/calculattona.
            3) CC/EC eoluan ch*c\u

            BlanV Pata(ln order VOA. A./B/W. Fettlcide. Ptorta)
            1) Chrcaatograaa.
            2) D*t* «y»t«k printout.
 E.  Katrlx Spike Pata(in ordar VOX.

     1) Chzoaatograaa.
     2) Data ajatca printout.
                                                 t ?e»ticld«)
        7.  Matrix SptVe Duplicate Pata(ln order VCAt A/B/W, ?e»tlcidO

            1) Chroaatogram*.
            2) Data aystea printout.                         _
VI
  SATIP1X PR£PA]UkTIOH  PACKET

/ A*   S&apl*  control  aheat (lab's  inttroal).
  1.   Screan  data (in  order VOA,  A/J/H, peaticldO

      1)  CC/FID chrcaatograaa.
      2)  CC acreen data aheeta.	
*Deaigoataa new fora.

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TENTATIVELY IDENTIFIED COMPOUNDS-UK£fcASDA}A&UEr
    r
Sample  Fraction        •  Compound                Scan   flT   PurUy Concentration

-------
                             Exhibit B

                             Page 22 of 42
                                               CSJ

                                               00
                                               trt
                                               4-»

                                               "i
FORM  III

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                          Exhibit B
                          Page 23 of 42
FORM III (continued)

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                          Exhibit B
                          Page 25 of
FORM V

-------
                         Exhibit B





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FORM IV

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                            IVHL *NU rfcKtUKflANtt SUfttlAKY

CASE NO.	  CONTRACTOR 	  CONTRACT HO.	
LOW LEVEL                MED. LEVEL	  HIGH LEVEL              *"
WATER                """  SOIL/SED.  	  OTHER(Specify) 	

DFTPP and BFB Performance Results;

	The DFTPP performance results were reviewed and found to be within
      the specified criteria.
      The BFB performance results were reviewed and found to  be  within
      the specified criteria.

               DFTPP                                   BFB
 Mass  Ion Abundance Criteria             Mass  Ion Abundance Criteria
   51  30-60 percent of mass 198            50  15-40 percent of mass 95
   68  less than 2 percent of mass 69       75  30-60 percent of mass 95
   70  less than 2 percent of -ass 69       95  base peak, 100 percent
   127  40-60 percent of mass 198            96  5-9 percent of mass 95
   197  less than 1 percent of BBSS 198     173  less than 2 percent of mass 174
   198  base peak, 100  percent              174  greater than 50  percent of mass 95
   199  5-9 percent of mass 198             175  5-9 percent of mass 95
   275  10-30 percent of mass 198           176  greater than 95  percent,  but
   365  greater than 1 percent of mass 198       less than 101 percent of 174
   441  present but less mass than 443      177  5-9 percent of mass 176
   442  greater than 40 percent of mass 198
   443  17-23 percent of mass 442

Deviations;                                            Required   Observed
Date/Time     Instrument^ File f     Compound    m/z    Abundance  Abundance
 FSCC AUDIT SUMMARY;
 50 ng  benzidine detectable for all runs? 	
 Pentachlorophenol  response factor >.05 relative to D-10 anthracene for
 •11 runs? 	
       ',*'.* '
 Comments:

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 VIXX.  DttOHATQCRVKY OCOCS
  r     Type ef Colu»n;  Fecked Column ______     Fused Silice Cepillsry Column
-"-      Fecked Column Chrometogrephy
        Telling Tectore        accept ence Windoxs       Hctusl
        Benzidine               .Lee* then 3         	
                                 Leu than J
        FSCC Chroff«to9r>phy Check
        S0>ng benzidine detectable?         Yes _____   No
        Fentechlorophenol responss rector?   Yes 	   No
 lte«srket
                                               24

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  IX.  STUOMDS
 .*-  r
-^;.    Central ah«p« of thr total ion
'..*".•'
                                         Volttlltt      f»»ticid«»
               Intcrf*
               Background
               4-nitroph«nol
                    cMorophvnol
               Btnzidin*
               He*»chlorocyclop»nt«di*n>
                Itophoron*
                Dinitrotoluvrw*
   •   .HS Ttltphonc Ito.i
       Coan*relal Tclaphorw No.t

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                                                            on the Introduction Fe,e.)

                                                                 No	
                                     Ol-n-octylpHth«l«U

                                     Fluor anthem
                                                            Him
D.t. of:  C«Hbr«tion
               Acid fraction:
2,«-dichlorophenol

2-nitrophenol
Phenol
Pentachlorophenol
                                                              Nsan
  D.t* of:  C«li»r«ttan
            Verification

            Analyti*

                 Volitllt Traction:
  1,1-dichlotoethylen»
  Chloroform
  1,2-dichloropropam
  Toluene
  Cthylbenzene
                                                                Keen
    Date of:  Calibration
              Verification
              Analyala
                     to b« In calibration during analyaiat  Yea
                                                                          No
                                                    26

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                          SPECIAL ANALYTICAL SERVICES
                                REVIEW DOCUMENT
A.   Client
B.   Laboratory(s)
C.   SAS Number
                                                                           Task
                                                                         CodeU)
D.   Specific Request:   Organic*
                        Inorganics
                        Other
                                                                         Protocol
                                                                          Code(s)
E.    Analytical Methodologies:   Organics
                                Inorganics
                                Other
F.    Methods Source
G.    Reviewer Name
 H.   Reviewer Function or Title
 The purpose of this inquiry is to gain information and recommendations from the SAS Pro-
 gram Principals directly, in order to improve the methodology(ies), QA/QC requirements, or
 reporting formats for future  similar Special Analytical Services.  Therefore, please respond
 in a timely fashion to all questions and requests.
        V
         . t '

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                          SPECIAL ANALYTICAL SERVICES

                              CLIENT REVIEW INQUIRY
Please return this inquiry  document to SMO after review of the data package for this
Special Analytical Service.
                              A.  General Methodologies
                                             «•

1.  Did the referenced methodology(ies) or protocol provide technically useful information
    lor this specific SAS request? If not, please explain.
 2.   Describe any changes  in methodology  or  other technical improvements that you
     recommend in order to more adequately perform this specific SAS task.
        *'

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   r                            B. QC Requirements

i.   Were  the QC procedures adequate for  determining the quality of the data for this
    specific  SAS request?   If  not, describe any  problems encountered  with  the QC
   •information.
2.  Describe any changes  in the QC requirements that you recommend in order  to more
    adequately perform this specific SAS task.

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   r                     C.  Data Sheets and Report Format

1.   Were the reporting deliverable* clear and understandable? If not, please explain.
2.  What changes in report or deliverable format do you recommend?
                                D.  Other Comments
Enter here any comments or recommendations for items not covered above.

-------