Guidance Manual

          For

 Collection  of  Samples

During RCRA Inspections
     Prepared by:

   Laura L. Gentile
  U.S. EPA Region  IX
      Revision  1
     November 1995

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                                              RCRA Sampling SOP
                                              Date: November, 1995
                                              Revision: 1
                         TABLE OF CONTENTS
Section        Topic                                         Page

0.0  Important Contacts  to Know	1

1.0  Purpose and Objectives  of Guidance Manual	2

     1.1  Purpose of Performing RCRA  Compliance Sampling	3
     1.2  Sampling Strategies for RCRA Facilities	3

2. 0  Sampling Plan Development	4

3. 0  Health and Safety Plan  Development	5

     3.1  Site Access	5

4 . 0  Recommended Field Eguipment	7

5.0  Sample Terminology, Containers,  and
     Preservation Techniques	8

     5.1  Terminology	8
     5.2  Sample Containers and Preservation Techniques	10
     5.3  Sample Analysis	11
     5.4  Disposal of Contaminated Materials	12

6.0  Quality Assurance in Sampling	13

     6.1  Sample Contamination	13
          6.1.1     Equipment Decontamination	14
          6.1.2     Equipment Blanks	14
          6.1.3     Field Bottle Blanks and
                    VOA Travel Blanks	15

     6.2  Field Duplicates	15
     6.3  Background Samples	15

7.0  Collection of Samples of Opportunity	17

     7. l  Water Sampling	17
          7.1.1     Surface Water:  Sampling Locations,
                    Equipment, and Techniques	17
          7.1.2     Surface Impoundments	20
          7.1.3     Leachate	21

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                                              RCRA Sampling SOP
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      7.2   Soil and Sediment Sampling	21
           7.2.1     Surface Soil 	22
           7.2.2     Sediment Sampling	23
           7.2.3     Waste Piles	24

      7.3   Collecting Samples From Containers	25
           7.3.1     Drum Sampling:   Liquid,  Sludge,  and
                     Solid Wastes	25

 8.0   Document  Control	28

      8.1   Documentation	28
      8.2   Corrections to Documentation	29
      8.3   Photographs	29
      8.4   Confidential Information	 . 29

 9.0   Sample Handling,  Packaging,  and Shipping Procedures	31

      9.1   Bottle Labelling Requirements	31
      9.2   Chain of  Custody Documentation	31
      9.3   Packaging and Shipping Procedures
           9.3.1     Shipment of  Environmental
                     (Low Concentration)  Samples	33
           9.3.2     Shipment of  High Concentration Samples....35

 10.0  References	38
APPENDICES

Appendix A.    Abridged Sampling Plan

Appendix B.    Health and Safety Plan

Appendix C.    Equipment Checklist

Appendix D.    SW-846 Test Methods to Know...

Appendix E.    .Chain-of-Custody Form and Instructions

Appendix F.    Chain-of-Custody Seal

Appendix G.    IATA Dangerous Goods regulations
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                                             RCRA Sampling SOP
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0.0  IMPORTANT CONTACTS TO KNOW
In preparing your sampling plan, selecting analytical methods,
obtaining equipment, and other related tasks, the following  EPA
contact numbers will be helpful to know:

     Chief. Quality Assurance Management Section (OAMS)

          For technical assistance in preparing sampling plan,
          selecting methods, obtaining laboratory space.

          (415)  744-1492

     Chief, EPA Laboratory.  Richmond. CA

          For obtaining laboratory space.

          (510)  412-2311

     Regional Sample Control Coordinator (RSCC).  QAMS

          RSCC must be notified as far in advance as possible
          with the anticipated number of samples to be collected
          and analyzed.   In  addition, RSCC must be called
          immediately following shipment of any samples to the
          laboratory.

          (415)  744-1498

     EPA  Logistics Management Specialist

          For obtaining  sample containers,  metal  paint cans,  PPE.

          (415)  744-2322

     Equipment Management Facility (EMFac).  Manager.  EPA
     Laboratory.  Richmond. CA

          For obtaining  sampling equipment.

          (510)  412-2335

     EPA  Health  and  Safety Manager

          For assistance in  completing health & safety plan.

          (415)  744-1491

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                                              RCRA Sampling SOP
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 1.0   PURPOSE AND OBJECTIVES  OF GUIDANCE MANUAL

 Environmental samples  may be useful  in  evaluating whether  a waste
 stream is  hazardous  or nonhazardous,  in determining the existence
 of contamination,  and  in  assessing whether  or not a release of  a
 hazardous  waste  or hazardous waste constituent has occurred.
 The  primary  objective  of  sampling during a  Resource Conservation
 and  Recovery Act (RCRA) site inspection is  to obtain legally
 defensible data  which  will assist personnel in identifying
 releases of  hazardous  waste  or hazardous waste constituents or  in
 determining  if a material can be classified as a  characteristic
 hazardous  waste.   The  data from samples acquired  during a  RCRA
 site inspection  may  become the basis  of a RCRA enforcement
 action.  Collected data may  further be  used in the development  of
 appropriate  corrective actions.

 Prior  to actually  collecting environmental  samples,  upfront
 planning is  critical to ensure that the samples obtained meet the
 objectives of  the  investigation.  This  guidance manual  is
 designed to  provide  the RCRA inspector  with guidance for
 collecting a limited number  of samples  of opportunity during
 routine RCRA inspections.  Samples of opportunity are initial
 grab samples collected during inspections in order to gather data
 to determine whether a detailed statistical assessment  may be
 necessary  at a site.

 The  procedures outlined in this guidance  manual pertain to the
 collection of  less than twenty samples  of opportunity (including
 QC samples,  such as blanks and background samples)  after the
 sampling objectives have  been  clearly defined  and the health and
 safety risks determined to be  minimal.  For example,  a  sampling
 event may  include collection  of ten soil  samples,  one equipment
 blank, one duplicate,  and one  background  sample.

 Samples should only be collected following  careful  consideration
 of the intended use of the analytical data  and  the  health  and
 safety aspects of collecting and transporting the  samples.  More
 extensive  sampling efforts, or  those posing significant  health
 and  safety risks, require the  development of more detailed
 sampling and health and safety  plans than those presented  in this
 guidance manual.

The  specific procedures outlined in this guidance manual
 correspond to EPA Region IX Environmental Services  Branch  (ESB)
guidelines.  This guidance is  intended for use by experienced
 inspectors who are already familiar with basic  inspection
procedures, such as basic health & safety procedures  and how to
properly document evidence.  It is assumed that the ESB
 laboratory will be used for most analytical services.  However,
the procedures outlined are also applicable when.coordinating
sample analyses with a private  laboratory.

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                                              RCRA Sampling SOP
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 1.1  PURPOSE OF PERFORMING RCRA COMPLIANCE SAMPLING

 Under RCRA,  periodic inspections of hazardous waste facilities
 are required in order to evaluate each facility's continued
 compliance with applicable RCRA regulations and/or RCRA permit
 conditions.   In addition to inspections,  periodic compliance
 sampling  may be helpful  in order to fully evaluate the compliance
 of  a facility and to make determinations  such as  one or more of
 the following:

      •     To determine whether  site operations have resulted in a
           release that poses an actual or potential threat  to
           human health and the  environment;

      •     To determine if an unknown waste can be  classified as a
           characteristic or listed  hazardous  waste;  and

      •     To determine whether  a  permit or RCRA regulatory
           violation  has  occurred.

 1.2   SAMPLING STRATEGIES FOR RCRA FACILITIES

 In general,  EPA uses  a biased approach in collecting samples to
 provide evidence  of  a hazardous waste  or  hazardous waste
 constituent  release  or permit violation.   In  the biased approach,
 samples are  collected in areas where a release  of hazardous  waste
 or hazardous waste constituents has most  likely occurred or  where
 evidence exists indicating that a release may have occurred
 (i.e., stained  soil).  Background information collected during
previous inspections  can provide a basis  for  selecting  waste
streams or site locations to sample for hazardous waste
characterization.  Environmental media  in  locations  such as
 lagoons, waste ponds, tailings,  or disposal trenches may be
sampled directly to determine waste characteristics  and/or to
 identify releases of hazardous constituents.  Further description
of sampling strategies and protocols are provided in this
document.

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                                              RCRA Sampling SOP
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 2.0   SAMPLING PLAN DEVELOPMENT
 The  purpose  of  a  sampling plan is to document all field and
 laboratory activities  associated with a sampling effort.   An
 abridged  sampling plan to be  completed prior to a RCRA inspection
 is included  as  Appendix A.

 The  abridged sampling  plan should be brief  and concise but must
 always  contain  the following  basic elements:

      •     General site information (site name,  description,  and
           EPA ID  Number if  available);
      •     Name  and phone  number of person requesting  the
           analyses;
           Analytical sampling dates;
           Analyses requested;
           Number  of samples,  including QC samples;
           Matrix  of each  sample;
           Type  of preservation for each sample;
           Analytical holding  times;
           Expected concentration  of  the samples;
           Type  and size of  sample containers;
           Objectives/Purpose  of sampling;
           Analytical parameters;
           Inspection personnel; and
           Equipment needs.

As this list  indicates, the sampling plan allows  EPA  to
tentatively schedule such resources  as  equipment  and  laboratory
services sufficiently  in advance  of  a proposed  inspection.   The
sampling plan is  thus  an essential tool  in  investigating RCRA
facilities.  The Regional Sample  Control Coordinator  (RSCC)
should be  contacted at  (415)  744-1498 at least two weeks in
advance of the  inspection in  order to facilitate  the  scheduling
of laboratory analyses.  The RSCC  should be provided  with  the
title page, the Request for Analyses section, and Request  for
Analyses tables of the  sampling plan as far in advance  of  the
inspection as possible.

The abridged sampling plan should be approved by  the  EPA Chief  of
the Quality Assurance Management  Section (QAMS) before  field
sampling begins.  In addition, the abridged sampling  plan  should
be submitted to ESB to serve as laboratory notification of
intended potential sample analyses.  Technical assistance  for
completion of the sampling plan can be obtained by contacting the
Chief of QAMS.

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                                              RCRA Sampling SOP
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 3.0  HEALTH AND SAFETY PLAN DEVELOPMENT
 No site activity should be conducted without a site safety plan.
 The contents of the safety plan prepared for a site depend on
 both the hazards known or suspected and the specific tasks
 planned for the inspection.   A health and safety plan to be
 completed prior to a RCRA inspection is included as Appendix B
 (this plan can also be found on the G-drive on the LAN).  The
 essential elements of the safety plan include:

           General site information;
           Personal protection equipment (PPE);
           Health and safety precautions;
           An on-site safety meeting;
           Route to nearest hospital;
           Emergency contact telephone numbers;
           Emergency procedures,  especially those concerning the
           appropriate use of PPE in hazardous  situations;
           Exposure limit  for the contaminants  of concern;  and
           Chemical and physical hazards of concern.

The  site  safety plan is prepared by the EPA RCRA inspector or
designate  and  forwarded to the EPA  Region IX Health and  Safety
officer  for  review.   The  RCRA inspector must have appropriate
training  for the level of protection  required  at the site.

3.1   SITE  ACCESS

Section 3007 of  the  RCRA  Statute (42  U.S.C.A. §6927)  specifies
the  following  regarding the  collection  of samples for the
purposes of  developing or assisting  in  the development of  any
regulation or  enforcing the  provisions  of RCRA by U.S. EPA:

      •    That U.S.  EPA is authorized to  "inspect and obtain
           samples  from any person of  any  such wastes  of  any
           containers  or labelling of  such wastes";

      •    That after  obtaining  samples, prior to  leaving the
          premises, the EPA person shall  give to  the  owner,
          operator, or  agent  in  charge  a  receipt  describing the
          sample obtained and  if requested a portion  of  each
          sample equal  in volume or weight to the portion
          retained; and

      •    That if any analysis  is made  of  such samples,  a copy of
          the  results of  such analysis  shall be furnished
          promptly to the owner, operator,  or agent in charge.

Although inspectors have the authority to  collect samples during
an inspection, a facility may refuse to allow an-inspector  to
collect samples if the  inspector does not have the safety
equipment required by the facility  (as per  OSHA requirements).
In this case,  it is generally possible to  obtain access  by
returning with the proper safety equipment.  However, other

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                                              RCRA Sampling SOP
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reasons for denial  of access may not be valid  and  may require
obtaining a warrant to conduct the inspection.   For more details
on obtaining access,  refer to the EPA RCRA inspection Manual.

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                                              RCRA Sampling SOP
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 4.0  RECOMMENDED FIELD EQUIPMENT

 A generic  equipment checklist has been developed in support of
 sample collection and is  presented as Appendix C.   It is unlikely
 that all of the  equipment listed in the checklist will  be
 necessary  for  sampling during a  routine RCRA inspection.
 Inspectors can select the necessary equipment from the  checklist
 based on the type of sampling anticipated for the  inspection.

 In addition to the sampling equipment,  personnel should be
 equipped with  personal protective equipment  (PPE),  including
 steel-toed boots,  hard hat, safety glasses,  and respirator with
 appropriate cartridges.   Also, a cooler or other appropriate
 shipping container must be obtained prior to sampling.

 Sample containers,  sampling equipment,  and limited  PPE  may be
 obtained from  the  Equipment Management  Facility (EMFac)  at the
 EPA Region IX  Laboratory  in Richmond, California.   EMFac is
primarily  a Superfund  support  activity  but there are currently
some supplies  and  equipment available to other  programs including
RCRA.   The EPA Logistics Management Specialist  should be
contacted at (415)  744-2162 to obtain sample containers,  metal
paint cans, and PPE.  The EMFac Manager  may  be  contacted at  (510)
412-2335 to obtain  sampling equipment.

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                                              RCRA Sampling SOP
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5.0  SAMPLE TERMINOLOGY, CONTAINERS, AND PRESERVATION TECHNIQUES

5.1  TERMINOLOGY

Some of the common terms used in the sampling program are  defined
in this section.

•    sample Media/Sample Matrix refers to the type of material
     that is collected as a sample.  Sample media refers to the
     environmental media from which a sample  is collected, such
     as air, water, or soil.  Sample matrix specifically refers
     to the type of sample material within one media  type.  For
     example, silt, clay, and loam are different matrices within
     the medium of soil.  A variety of media  or sample matrices
     may be encountered at hazardous waste sites, including
     surface water, sediments, soil, oily wastes, pure or nearly
     pure chemicals, and chemical sludges.  The media/matrices
     sampled during a RCRA inspection will depend on  site-
     specific conditions.

•    Environmental Sample is a sample of water,  soil,  or sediment
     that is associated with a RCRA facility  but is distant from
     the source of contamination or waste stream.  These samples
     may contain low concentrations of any single contaminant.
     Environmental samples do not require the special  shipping
     procedures necessary for hazardous materials.

•    Hazardous Material Sample is a sample from drums, bulk
     storage tanks, or obviously contaminated surface
     impoundments (lagoons), pits,  or waste sites.  These samples
     are expected to contain high concentrations of contaminants.
     Hazardous material samples require special  shipping.
     Inspectors are discouraged from collecting hazardous
     material samples during routine RCRA inspections.

•    Sample Concentration Designations refer to  the concentration
     of contaminants expected in a  sample.   The  definitions vary
     depending on the context being used.   For example, high
     concentrations of a contaminant for health  and safety
     purposes may be considered a medium or low  concentration for
     laboratory analysis,  or vice versa.   In general, the
     following designations  are recognized:

     Low Concentrations - Generally less than 10 parts per
     million (ppm)  of any single contaminant is  expected to be
     detected in low concentration  samples.   These samples may be
     shipped as environmental samples.

     Note:   For concentrations of contaminants in water samples,
     the ppm unit of measurement is equivalent to mg/1 and parts
     per billion (ppb)  is equivalent to ug/1.  For soil/sediment
     samples,  ppm is equivalent to  mg/kg and ppb is equivalent to
     ug/kg.
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                                          RCRA Sampling SOP
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  Medium Concentrations - Generally between 10 ppm to 150 000
  ppm (15 percent)  of a single contaminant is expected to 'be
  detected in medium concentration samples.  These samples may
  be shipped as other environmental or hazardous material
  samples depending on the specific nature of the sample.

  High Concentrations - Greater than 15 percent of any single
  contaminant is expected.   In general,  all high concentration
  samples are shipped as hazardous material samples.

  IMPORTANT  NOTE:   For purposes of this  guidance manual, only
  low  concentration (environmental)  or high concentration
  (hazardous material)  samples  will be recognized due  to the
  difficulty in  the field in distinguishing  medium
  concentration  samples  and selecting an appropriate shipping
  procedure.  The EPA  inspector must exercise careful  judgment
  in determining appropriate procedures.  When in doubt, the
  sample should be  handled as high  concentration  (hazardous
 material) .

 Leachate Sample is a solution produced by the percolation of
 water through solid materials such as landfills, mine
 tailing materials, or soils.   Such a sample may be either an
 environmental sample or hazardous material sample, depending
 on several factors (such as proximity to the source,
 concentration of the material in the source, infiltration
 rate of water,  solubility,  or adsorptivity) .  These samples
 are usually collected as surface waters issuing from
 embankments or impoundment features.

 Grab or Discrete Sample represents an instantaneous
 collection  of a single amount of a substance,  or an
 individual  sample  collected from a single source.

 Composite Sample is a combination of  individual samples
 taken at multiple  sampling points.  The sample  composite  is
 collected by removing a fixed  amount of the substance and
 combining it with  other similarly collected amounts to
 produce  a single sample for analysis.

 The "site composite"  involves  combining samples  from
 different locations or  intervals  at a single location on the
 site  and  can be used  in some circumstances  to increase
 analytical  economy.   Such a sample may provide useful data
 about average concentrations of contaminants or about the
presence  or absence of hazardous constituents at the  site.
 It is advisable to save the discrete samples used in
collecting the composite, in the event that analysis of the
composite sample indicates high concentrations of any
          J lnte"s,t-  If this occurred, it. would be
         p


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                                              RCRA Sampling SOP
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      cause  a  loss  of  certain  substances,  especially volatiles,
      that may yield inaccurate  results or yield false negative
      results  through  dilution.   In  addition,  it should be  noted
      that compositing can mask  problems by diluting isolated
      concentrations of some hazardous compounds below detection
      limits.

 •     Duplicate/Split  Sample is  a sample that  has been apportioned
      into two or more containers from a single  sample container.
      Split  samples are duplicate samples  often  given to the
      owner, operator,  site representative, or independent  lab.
      If the split  sample is being taken for the operator,  the
      site representative must be contacted prior to sampling to
      allow  for sampling oversight by a designated representative
      to be  present at the time  of sampling.   Split samples can
      also be  used to  provide  precision information on analytical
      procedures (i.e.,  a measurement of the reproducibility of
      measurements or  a measurement  of how close the duplicates
      are to each other).

 Selection of  sample types is  based  on background studies and
 observations  of current site  conditions.  The EPA inspector will
 select the  sample matrices while conducting the onsite
 inspection, complete  the chain-of-custody documentation, and
 submit both the samples and the  chain-of-custody documentation  to
 ESB or the  private laboratory for analyses.

 5.2   SAMPLE CONTAINERS  AND PRESERVATION TECHNIQUES

 Procedures  for containing samples are guided  by the sample
 matrix, the suspected  level of concentration, and the  analysis  to
 be performed.

 Samples collected during investigation of RCRA  facilities  are
 contained and preserved according to their matrix and  the  type  of
 analysis scheduled.  For a description of the recommended
 container for various  chemical parameters and sample types,  the
 amount of sample required,  preservation requirements,  and  the
 maximum allowable holding time before sample  analyses, refer to
 Appendix D.

 Preservatives are added to retard biological  action and to
prevent loss of aqueous inorganic species, such as  ions and
 complexes.   The standard preservatives used by  EPA to preserve
 environmental or low-concentration water and  soil samples  are
 included in Appendix D.  Preservation methods are generally
 limited to the addition of a chemical to the  sample, pH control
 and sample refrigeration.   If chemical preservation is determined
to be necessary,  EPA Region IX recommends preservation in the
 field as opposed to obtaining sample bottles that have been
preserved in advance.   The preservation of low  organic
concentration sediments and soils requires cooling to 4°C.
Hazardous material or high-concentration samples are collected  in
 8-oz glass jars,  regardless of matrix,  and do not require

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 preservation.

 For samples  requiring the addition of  acid as a preservative
 (i.e.,  metals,  volatiles),  the  adequacy of the preservation
 should  be checked  in the  field  as  follows:

      •     Volatiles:   To  check  on  the  adequacy of sample
           preservation, add two drops  1:1  HC1 to a pH check vial
           prior to sample collection.   The vial will  be filled
           with  sample fluid, the pH of the solution will be
           checked,  HC1 will be  added as necessary to  achieve a  pH
           less  than 2, the  amount  of acid  added will  be noted,
           and the  pH check  vial will be discarded properly.
           Samples  should  be collected  once the pH check has been
           performed;

      •     Sample vials should not  be reopened and/or  refilled
           once  the sample  is collected.  If air bubbles are
           present  in a sample vial, the vial  should be discarded
           properly and another  vial should be used to collect the
           sample.

      •     Metals:   For sample preservation, use a pipette  to add
           1:1 nitric  acid to the sample bottle soon after  sample
           collection  to adjust  the  pH  to less than 2.  Mix the
           sample by capping and turning the bottle upside  down.
           Check  the pH by pouring  a small  amount of the sample
           into the  bottle cap and  checking  the pH with pH  paper.
           Discard  the  liquid in the cap after checking the pH.
           Repeat if necessary.

5.3   SAMPLE ANALYSIS

The purpose of collecting samples  of opportunity during RCRA
inspections will be to collect  data which may be used  to
determine  if a facility is  in compliance with RCRA regulations
and/or permitted requirements and to determine if  additional
sampling may be  required at a site  or  facility.   Sampling  during
an  inspection may be particularly helpful  in  aiding inspectors  in
determining if a solid waste observed  during  an  inspection  is a
characteristic or a listed hazardous waste.

To determine if  a solid waste is a  characteristic  hazardous  waste
by sampling,  the analytical results of the  sampling should
indicate whether the sample fails the Toxic Characteristic
Leaching Procedure  (TCLP)  for one or more of  the TC contaminants
specified  in 40 CFR 261.24.  Determining that  a  solid waste  is a
listed hazardous waste by sampling  is not as  clear  cut.  At  a
minimum, inspectors should determine one or more  listed waste
codes that the waste of concern may fall under.  -The analytical
results of sampling should indicate whether one  or more of the
chemical compounds  found under these listed wastes  is present.

Most samples  of opportunity collected during RCRA  inspections

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 will  be  analyzed using  methods  outlined in Test Methods for
 Evaluating Solid Waste,  SW-846  (SW-846).   Some of the more
 commonly used  SW-846  analytical methods can be found in Appendix
 D.  Inspectors are  encouraged to  check for the most recent update
 of  SW-846 in selecting  analytical methods.

 In  order to obtain  quality data,  inspectors should ensure that
 the analytical methods  chosen match the objective  of the sampling
 effort.  With  so many environmental analytical methods  to choose
 from, selecting the appropriate method can  be  quite complex with
 many  variables to consider, such  as setting detection limits,
 dealing  with matrix interferences, as  well  as  many others.  Prior
 to  any sampling effort,  EPA Region IX  strongly encourages
 inspectors to  request assistance  from  ESB in selecting  the proper
 analytical methods  to ensure quality data.

 5.4  DISPOSAL  OF CONTAMINATED MATERIALS

 It  is the responsibility of the party  conducting the  sampling to
 properly dispose of all waste generated according  to  local,
 state, and federal  regulations.  Disposable clothing  and gloves
worn during sampling will be placed in plastic  garbage  bags for
disposal as municipal waste.  All waste and samples that are
hazardous,  as defined in 40 Code .of Federal Regulations  (CFR),
part 261, must be contained, transported, and disposed  of as a
hazardous material.   Transportation of hazardous materials must
be conducted in accordance with 29 CFR  (Department of
Transportation  [DOT]).
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 6.0   QUALITY ASSURANCE IN SAMPLING

 The  submission of an abridged sampling plan (Section 2.0) to the
 laboratory prior to sampling is an essential part of quality
 control.   The sampling plan justifies  the rationale for selecting
 samples  and confirms contaminants  to be analyzed and methods to
 be followed.   Using appropriate sample containers and proper
 document control procedures,  as described below,  are also
 essential parts of quality assurance in sampling.   An essential
 element  of ensuring overall data quality'is the  documented
 cleanness of  sample containers.  EPA personnel must acquire
 bottles  that  have been cleaned and tested in accordance with EPA
 protocol  and  standards.

 The  use  of quality assurance  samples is strongly recommended to
 assist with evaluating the accuracy of the resulting enforcement
 data, regardless of how many  primary samples are targeted for
 collection during a sampling  event.  When sampling equipment is
 decontaminated  and reused  in  the field,  an equipment blank must
 be collected.   For enforcement purposes,  inspectors may need to
 collect blank samples  to demonstrate that there  was no
 contamination of samples resulting in  false positives.

 6.1  SAMPLE CONTAMINATION

 Contamination is generally understood  to mean something that is
 inadvertently added to  the sample  during the sampling process
 (i.e., false positives) and is a common source of  error in all
 types of  environmental measurements.   Typically,  contamination  of
 samples may occur  at any of numerous points in the sample
 collection  and  analysis process.   In the field,  contamination may
 occur during sample  collection, handling,  storage,  or in
 transport to the lab.  After  arrival at the lab, contamination
 may occur during storage,  in  the preparation and handling
 process,  or during  the process  of  sample  analysis.

 Equipment used  for  sample  collection is  a  common route  for
 introducing sample  contamination in many types of  environmental
 measurements.   Cross-contamination may  occur  as a  result of
 improper  cleaning of sampling  equipment.   In  addition,
 contamination may occur due to the use  of  sampling  equipment  made
 out of certain materials that may react with  the sample  itself.
 It is important  to select  sampling equipment made  out of
materials that will  not contaminate the  sample.  For  example, if
 sampling for the presence  of extractable organics,  do not  use
 equipment or containers made out of plastic or polyvinyl chloride
 (PVC).  For samples  collected  for organic analyses, EPA Region  IX
 requires that sampling equipment be made of stainless steel,
glass, or teflon.

 If equipment used in the field is to be reused at multiple
 sampling locations, decontamination of equipment is recommended.
 In order to check the effectiveness of the decontamination
procedure, equipment blanks are recommended as the most effective

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 tool for the assessment and control of sample contamination.

 EPA Region IX generally recommends  that only one type of blank be
 collected,  and that blanks  be  collected in the following order of
 preference:   equipment  blank,  field blank,  and VOA travel blank.

 6.1.1     Equipment Decontamination

 Adequate decontamination of equipment  to be reused at multiple
 sampling locations  will help to  ensure that cross contamination
 between  samples does not occur.  Careless sample handling and
 dirty sampling equipment can be  sources of  sporadic
 contamination,  which can affect  the measurement process  by
 introducing  false positives.   The following is an EPA Region  IX
 recommended  generic procedure  for decontamination of  sampling
 equipment during low-level  sampling:

      1.    Wash with non-phosphate detergent;
      2.    Tap-water rinse;
      3.    0.1N nitric acid  rinse (when cross  contamination from
           metals is a concern);
      4.    Deionized/distilled  water rinse;
      5.    Pesticide grade solvent rinse (when semivolatile and
           non-volatile  organic contamination  may be present);
      6.    Deionized/distilled  water rinse (twice);  and
      7.   Organic-free  water rinse  (HPLC  grade water).

The above procedure is  not  appropriate for  every field situation.
Clearly  document your procedure  in  the sampling plan.

6.1.2     Equipment Blanks

An equipment blank  should be collected when sampling  equipment  is
decontaminated  and  reused in the field or when a sample
collection vessel (i.e., a  bailer or a beaker)  will be used.
Equipment blanks are defined as  samples which  are obtained by
running  organic-free water  over  or  through  (whichever is  more
appropriate) the sample collection  equipment  after  it has been
cleaned.   EPA Region IX recommends  the use  of  organic-free water
to collect blanks that are  targeted for organics  analysis and
deionized/distilled water for  blanks that are  targeted for
inorganics analysis, although  this  is  not required  if the source
of water has been historically been contaminant-free.

The purpose of the equipment blank  is  to  demonstrate  that
sampling procedures have not yielded false positive results.
Specifically, the equipment blank checks  the presence of  any
contaminants which may have been introduced to  the sample through
contact with sampling equipment.   In addition,  the use of an
equipment blank is to verify the effectiveness  of cleaning
procedures.  One blank should be collected  for  each type  of
sampling device used.                  *
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 6.1.3     Field Bottle Blanks and VOA Travel Blanks

 A field bottle blank may be collected in situations when
 equipment decontamination is not necessary and when a sample
 collection vessel  will not be used to collect a sample (i.e.,
 with dedicated pumps).  The field blank should be collected  by
 pouring appropriate "blank water" (as described in Section 6.1.2)
 into a  bottle at one of the locations where a sample had been
 collected (a  sampling point).   EPA recommends collecting one
 field blank per day when an equipment blank is not collected and
 when a  sample collection vessel will  not be used.

 EPA  recommends collecting one VOA travel blank per shipping
 container or  cooler when water samples are collected for analysis
 of volatile organic contaminants and  when no other blank is
 collected.

 6.2   FIELD DUPLICATES

 Duplicate samples  refer to samples collected at the same time
 from the  same locations under  identical  conditions.   Field
 duplicate samples  provide a  check on  the precision of the
 sampling  and  analytical procedures.   Field duplicates are
 particularly  important for the sampling  of heterogeneous wastes,
 such as soil  and material from waste  piles,  because of the large
 degree of variability  associated with these wastes.   Duplicates
 should be collected from sampling points which are known or
 suspected to  be contaminated.   In addition,  a  rationale  for  the
 selection of  duplicate locations,  or  the decision  process which
 was  used  to select duplicate  locations,  should be  documented.

 Field duplicates and background samples  will be  collected,
 numbered,  packaged, and sealed  in the  same manner  as  primary
 samples and will be submitted  "blind"  to the laboratory.

 6.3  BACKGROUND SAMPLES

 Background samples  are  collected  to document ambient
 concentration  levels, which then  can be  compared to levels found
 on site,  when  appropriate.  With  any sampling  program, sampling
 points beyond  the  limits  of site  contamination (i.e., upstream
 surface water  samples) will be  identified,  if  possible.   In  most
 instances, samples  will  be collected to  determine  if more  in-
 depth sampling is  required and to  assess  compliance with RCRA and
 other applicable regulations.  This provides a means of assessing
 the true  on-site concentration values.   Background sample data
 are typically useful in determining the  presence of metals at a
 site, as  opposed to volatiles.  Background  samples should be
 analyzed  for the complete set of parameters for each matrix.   EPA
Region IX recommends that ten percent of the samples collected
 during an  investigation be background samples.  Background
 samples should be representative of the  sampling and analytical
process.  In many  instances, such as samples collected from  drums
 or samples collected from heterogeneous waste piles, background

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sample media will not  be available.
Field duplicates and  background samples will be collected,
numbered, packaged, and sealed in the same manner as primary
samples and will be submitted "blind" to the laboratory.
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                                              RCRA Sampling SOP
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 7.0  COLLECTION OF SAMPLES OP OPPORTUNITY
 Inspectors must remember that samples of opportunity are initial
 grab samples collected during inspections in order to gather data
 to determine whether a detailed statistical  assessment may be
 necessary at a site.   Based on observations  during sampling and
 the results of samples of opportunity collected,  more detailed
 sampling plans may be necessary to adequately assess site
 conditions.   For additional guidance  on development of detailed
 sampling plans,  statistical sampling  methods,  and related topics,
 inspectors are encouraged to refer to the guidance documents
 listed  in Section 10.0 (References) of this  manual.

 Inspectors must recognize the more stringent sample handling,
 transportation,  and disposal requirements when collecting
 hazardous material samples during  RCRA inspections.   If hazardous
 material samples must be collected, then compliance with specific
 regulations  governing the packaging,  transportation,  and disposal
 of  hazardous materials is required.   All waste and samples that
 are hazardous,  as defined in 40  CFR,  part 261,  must be contained,
 transported,  and disposed of as  a  hazardous  material.
 Transportation of hazardous materials must be  conducted in
 accordance with  29  CFR (DOT regulations).  In  addition,  the use
 of  air  transportation for shipment of hazardous material samples
 requires compliance with the International Air Transportation
 Association  (IATA)  Dangerous Goods Regulations (see Appendix G).
 Guidance for the packaging and shipping of nonhazardous materials
 is  addressed in  Section  9.0.

 7.1  WATER SAMPLING

 This guidance  manual  does  not  provide specific information on
 definitions  of size/depth  of lakes, decision procedures for the
 selection  of the number,  locations, depths of  samples,  or working
 examples  of  lakes,  ponds,  and  impoundments which may have been
 sampled.   For  specific guidance  on selection of the number,
 locations, and depths of samples,  inspectors should refer to
 Guidance for Data Quality  Objective Process, EPA QA/G-4,  Final,
 September  1994.   In addition, more information on  sampling
 procedures for water  sampling may  be  found in  the  Compendium on
 ERT Surface Water and Sediment Sampling Procedures, EPA 540/P-
 91/005,  January  1991.

 7.1.1      Surface Water:   Sampling Locations/  Equipment,  and
           Techniques

 Sampling of surface water may be a component of a RCRA
 inspection.  This section describes the equipment, methods  of
 collection, and  sample site  selection used when sampling  surface
 water.   Collection of surface water samples  of opportunity  may be
 required to help  establish the existence or  extent of contaminant
migration  and to  collect data to determine if  a more detailed
 sampling assessment is required.   Such  data may help
 investigators  identify risks to populations  and determine

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 appropriate remedial actions.   Comparisons of water chemistry
 from sampling points upstream  or upgradient to sampling locations
 both on-site and downstream or downgradient from the site are
 used to  evaluate contaminant releases.

 If  possible,  the surface water drainage  in and around a site
 should be  characterized prior  to sampling  using all available
 background information, including topographic maps and river
 basin studies.   In general,  sampling  locations may include
 rivers,  creeks,  or streams  running through or adjacent to a  site,
 including  those  bodies of water that  may receive surface runoff
 or  leachate from a site.  Surface water  samples may also be
 collected  from lakes, stock watering  ponds,  or other types of
 impoundments.

 Surface  Water Sampling Locations

 Ease of  access to the sampling location  is sometimes an important
 health and safety consideration.   Wading for water samples is not
 recommended in shallow lakes,  ponds,  and slow-moving rivers  and
 streams  because  bottom deposits are easily disturbed,  resulting
 in  increased  sediment in the overlying water column.

 Rivers,  streams,  and Creeks;   Actual  sample  locations  vary with
 the  size of the  water body  and the amount  of turbulence in the
 stream or  river.  Generally, with small  streams less than about
 20  feet wide, a  sampling site  can be  found where the water is
 well  mixed.   In  such cases,  a  single  grab  sample taken  at mid-
 depth in the  center of the  channel is adequate  to represent  the
 entire cross  section  (a sediment  sample  can  also be  collected in
 the  center  of the channel).  For  slightly  larger streams,  at
 least one vertical composite should be taken from midstream,  with
 samples taken just below the surface, at mid-depth,  and just
 above the bottom.

 Lakes, Ponds, and Impoundments;   Sampling  locations  may include
 any  adjacent bodies of water such  as  lakes,  stock watering ponds,
 sediment of flood control ponds, marshes,  or impoundments  that
might receive contaminants.  The  number of water sampling  sites
 on a  lake,  pond,  or impoundment will vary with  the depth,  size,
 and  shape of the basin.

 Standing surface waters have a much greater  tendency to  stratify
than rivers and  streams.   The relative lack  of mixing requires
that more subsamples be obtained.  In ponds  and  small
 impoundments, a  single vertical composite at the  deepest point
may be sufficient.  In naturally formed ponds, the deepest point
 is usually near the center; in impoundments, the  deepest point  is
usually near the dam.

In lakes and larger impoundments, several vertical aliquots  may
be composited to form a single sample.  Again, the number  of
vertical composites and the depths at which  samples  are  taken are
usually at the discretion of the sampling crew.

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usually at the discretion  of the  sampling  crew.

Leachates;  Leachates can  be formed when precipitation mixes with
wastes.  A leachate may enter groundwater  systems causing
deterioration of the water quality.  In areas where  the  ground
surface slopes steeply away from  buried wastes, the  leachate may
"break out" or emerge on the ground surface.  This situation is
typically encountered at landfills or at the  foot of waste
residue disposal piles.  Samples  taken from leachate streams may
have to be treated as medium or high-concentration samples,
depending on the field evaluation.

Surface Water Sampling Equipment

The equipment needed for surface  water sampling during
investigations of hazardous waste sites is minimal.  In most
instances, the sample container serves as the sampling device.
The use of highly sophisticated or automatic sample  devices  is
normally not required to collect  the limited number  of samples
addressed by this guidance manual.  Refer to Appendix C for  the
Field Equipment Checklist.

Surface Water Sampling Techniques

Most samples taken during EPA RCRA investigations  are grab
samples.   Typically,  surface water sampling involves immersing
the sample container in the body  of water; however, the following
suggestions will help ensure that the samples obtained are
representative of site conditions.

     •    The most representative stream samples are obtained
          from mid-channel  at a depth of about six inches below
          the surface in a  well-mixed stream.   For larger
          streams,  at least one vertical composite should be
          taken from midstream,  with samples taken just below the
          surface,  at mid-depth,  and just above the bottom;

     •    Stagnated areas or pools in a stream or river may
          contain zones of  varying pollutant concentrations,
          depending on the  physical/chemical properties of the
          contaminants and  the proximity of these stagnated areas
          to the site;

     •    When sampling running water,  it is suggested that
          sampling progress from downstream to upstream to
          eliminate sediment disturbance in subsequent samples;

     •    To sample a pond  or other standing body of water,  the
          surface area may  be divided into grids.   A series of
          samples taken from each grid is combined into one
          sample,  or  several grids may be selected at random (for
          more information  on selecting grid sizes, inspectors
          should refer to Guidance for the Data Quality Objective
          Process,  EPA QA/G-4,  Final,  September 1994).

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      •    Care should be taken to  avoid  excessive agitation of
          the water during transfer  from source  to bottle.
          Agitation could result in  the  loss  of  volatile
          constituents;

      •    When collecting samples  in 40  mL septum vials for
          volatile organic analysis  (VOA), it is important  to
          exclude any air space in the top of the bottle.   For
          this procedure, the container  is slowly filled to
          overflowing.  After sealing, the bottle should be
          turned upside down and shaken  once  against the hand,
          then checked visually for  air  bubbles.   If air bubbles
          are present/ the sample  bottle should  be discarded.  A
          new VOA vial should be used to collect the sample in
          order to minimize the loss of  compounds  by
          volatilization.  In addition,  the sampler should  verify
          the adequacy of the preservation of the  sample using pH
          paper and an extra vial  which  is not used as an actual
          sample (see procedure outlined in Section 5.2); and

     •    Do not sample at the water surface unless sampling
          specifically for an immiscible constituent on top of
          the water.  Instead, the sample container should  be
          inverted, lowered to the appropriate depth, turned up,
          and held at about a 45° angle with the mouth of the
          bottle facing upstream.  Samplers may  need to use the
          telescoping aluminum pole and  clamp technique described
          in Section 7.1.2 (Surface Impoundments)  for sampling in
          this situation rather than submerging  a  gloved hand
          into a potentially contaminated stream.

7.1.2     Surface Impoundments

The sampling approach for on-site surface impoundments depends on
such factors as the surface area,  depth,  and stratification of
layers of the impoundment.   For the purposes of collecting
samples of opportunity as addressed by this guidance, the
following are some general guidelines for collecting such
samples:

     •    Several samples should be taken from different points
          in the impoundment.   If the impoundment is large,  the
          surface area may be divided into grids and a sample
          taken from each grid or from a predetermined number of
          randomly chosen grids;

     •    The safest technique for obtaining samples is to use a
          Teflon beaker or 8-oz  glass jar clamped to the end of a
          telescoping aluminum pole.   The sample medium is
          transferred from the Teflon beaker or jar to an
          appropriate sample  container.   The apparatus must be
          thoroughly decontaminated between samples; and

     •    Obtaining a sludge  sample from the bottom of an

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           impoundment is limited to the use of the pole/Teflon
           beaker,  which may be employed from the bank to scoop
           sludge from the bottom.

 7.1.3      Leachate

 One  of  the principal  pathways  for  off-site  movement of
 contaminants  is  leachate from  buried wastes.   Because leachate
 streams may contain contaminants,  it is recommended that samples
 of leachate be handled and treated as hazardous material samples
 until reliable data indicate otherwise.  The  general guidelines
 for  collecting leachate samples  outlined below should be
 followed:

     •     If  possible,  leachate  streams should be  sampled under
           both low and high flow conditions;

     •     The sample  container is  used  as the sample collection
           device because leachate  stream samples will be grab
           samples.  Unless prior arrangements have been  made with
           the analytical laboratory, the container of choice is
           an  8 02  wide-mouth glass jar  with a Teflon-lined lid
           and with a  10 percent  head space  allowance.  The
           telescoping aluminum pole  and clamp technique  should be
           used when collecting leachate samples.

     •     If  the leachate  stream flow is low,  a shovel or
           stainless steel  spoon  may  be  used to dig a small hole
           at  the sampling  point.   The hole  is allowed to fill
           with leachate and  sufficient  sample volume is  then
           obtained.   Disturbed and suspended  sediments should be
           allowed  to  settle  before collection of the leachate
           sample.  Any  sample  turbidity should be  noted  in the
           field notebook and on  the  chain-of-custody form.  The
           shovel or spoon  should be  properly  decontaminated or
           disposed of after  use.

7.2  SOIL  AND SEDIMENT  SAMPLING

The analysis  of soil  and sediment  at the RCRA facility is
intended to provide verification of hazardous  waste  releases,
permit violations, the  source  of contamination,  and  the  existence
and extent of waste stream migration.   Samplers  should take into
consideration the  factors that contribute to  dilution of a
contaminant in soils and sediments such  as  oxidative or
photochemical degradation, biological degradation, dispersion by
surface runoff and streams,  and dispersion  due to  infiltration by
surface water.

Soil and sediment properties vary not only  from  one  location to
another, but also among the horizons of a given  profile.  The
variation of the soil and sediment must be  considered before
sampling.   The inspector should develop a concise  objective of
why the study is needed and the questions the  study  is to answer.

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 The  EPA  inspector must  decide  on  the  type  of  sampling dictated  by
 site circumstances  and  whether a  biased  or statistical sampling
 method is required.  The purpose  of this guidance is to address
 the  collection of a limited number of samples in  order to
 determine compliance with RCRA regulations and/or permitted
 requirements and to collect data  in order  to  determine if  more
 in-depth sampling may be required.  Statistical sampling is
 beyond the  scope of this SOP guidance.   Inspectors may refer  to
 Principles  of Environmental Sampling,  ACS  Professional Reference
 Book (1988) for more information  on statistical environmental
 sampling methods.   In the biased  sampling  approach,  which  is
 commonly practiced  in RCRA investigations,  samples are collected
 where spills or leaks of contaminants may  have occurred.   Biased
 samples  are often used  for enforcement to  prove that
 contamination exists at a given site.  Investigators can
 determine these areas through  a variety  of means,  including site
 records, photographs, direct observation of visibly  stained
 and/or discolored soils, or areas lacking  vegetation.   Sampling
 of pure  product from drums, for example, should normally be
 collected for high  concentration  analyses.

 7.2.1     Surface Soil

 Surface  soil sampling under biased conditions may  be selected
 after considering factors such  as type of  pollutant,  length of
 time the area has been  contaminated,  the type of soil,  and  the
 past use of the area. Surface sampling may be appropriate  in
 situations where the contaminant  is easily sorbed, the  spill  or
 leak is  recent, the  soil has a  high affinity for that particular
 pollutant,  or if soil is contaminated by wind-or water-borne
migration.   In addition, surface soil sampling, which usually
 includes the upper 0 to 3 inches of soil,  is necessary  to
 evaluate the on-site exposure pathway.  For both grab and
 composite sample collection,  it is important to avoid mixing  soil
types (unless specifically required)  and to collect  samples from
a uniform depth and from a uniform area.

The following describes sampling techniques and equipment for
surface and near-surface soil sampling.

     •    Grab sample

          1.   The most desirable sample collection  instrument  is
               a stainless steel spoon.  For certain inorganic
               sampling objectives (such as metals),  plastic
               scoops may be  used;

          2.   Sample collection devices for true surface
               sampling (top  0-3 inches of soil)- include
               stainless steel  scoops or hand trowels.

     •    Composite Sampling
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           1.    Composite  sampling is  sometimes used to minimize
                sample  numbers  or  to assess  direct contact
                exposure.   Compositing is  not recommended for
                collection of VOA  samples  due to the loss of
                volatile constituents  in the process of mixing the
                sample.  The most  desirable  method of compositing
                soil  subsamples is within  a  stainless steel  bowl,
                aluminum pie tin,  paper paint bucket,  or on
                aluminum foil.   Samples should be stirred
                continuously for at least  60 secpnds;  and

           2.    To provide a more  representative sample,  three to
                five  subsamples may be collected in a consistent
                pattern surrounding the designated sample
                locations  and then composited.   Typically, by
                increasing the  number  of subsamples,  the
                interpretive value of  the  data is reduced.   By
                compositing samples of widely variable
                concentrations,  those  species appearing
                intermittently  or  in small quantities may be
                diluted out or  masked  by high detection limits
                imposed by species occurring in  high
                concentrations.

7.2.2     Sediment Sampling

Sediment samples are valuable  for  locating  contaminants  of  low
water solubility and high  soil  binding affinity.   Surface water
samples might show trace  quantities of contaminants,  thus leading
EPA inspectors  to believe  that  a waste stream is  of minor
concern; however, the analysis  of  sediments  might indicate
otherwise.  Heavy metals  and high molecular  weight  hydrocarbons
are examples of contaminants that might be  found  in greater
concentrations  in sediments than  in the surface waters.

Sediment samples can be collected  from rivers, creeks, ponds,
flood control ponds,  lakes, lagoons,  and  impoundments.

A review of available background  information may  indicate the
types of substances that may be present in sediments  at a site.
The following items should be considered when sampling.

     •    Many pollutants adsorb on sediments having  a large
          surface-to-volume ratio.  Therefore, silts  and clays
          typically contain higher concentrations of  organic
          compounds and trace metals than do coarser  sediments
          such as sands and gravels;

     •    Samples for organic analyses should not be collected
          from areas  exposed to the air during periods of low
          flow or low recharge; and

     •    Sediment samples should be obtained from the area
          nearest the suspected contaminant source.


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                                              RCRA Sampling SOP
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 Sediment Sampling Techniques
 Simple  techniques  can usually  be  employed  for  sediment sampling.
 Most  samples will  be grab  samples,  although  sometimes sediment
 taken from various locations may  be combined into  one sample to
 reduce  the amount  of analytical support required.   Suggested
 techniques include the following:

      •    In small streams with low flow rates or  near the  shore
          of a pond or lake, an 8-oz wide-mouth jar may be  used
          to scrape up the sediments and to  contain the sample.
          Four to  eight ounces of material should  be  collected.
          Stainless steel  spoons may aid in  sample collection;

      •    To obtain sediments from  larger streams  or  from a
          location further from the shore of a pond or lake,  a
          Teflon beaker (attached to a telescoping aluminum pole
          by a clamp) may  be used to dredge  sediments.   In  most
          circumstances, a number of sediment  samples  should be
          collected along  a cross-section of a river  or stream  to
          characterize the bed material adequately; and

      •    To obtain sediment from rivers or  in deeper  lakes and
          ponds, samples may be obtained by  lowering  a spring-
          loaded sediment  dredge or benthic sampler to the
          appropriate depth.  The sediments thus obtained are
          placed into the  sample container.  The sampling device
          must be decontaminated between locations.

7.2.3     Waste Piles

Waste piles may consist of sludges  from various processes or
contaminated soil excavated during site closure operations.   The
sampling approach depends on the size or volume of  the .pile,
known or suspected waste constituents,  and other physical factors
such as soil type,  density of the pile, and presence of  other
material such as crushed steel drums.  Because it  is likely that
waste piles will be heterogeneous, it is best to select  as  large
a test sample as practical for sample preparation.

For waste piles, composite samples may be particularly useful due
to the large degree of variability associated with these
heterogeneous wastes.   Compositing may be useful in overcoming
the lack of homogeneity over time or.in the distribution of
chemical species, but compositing may also dilute peak values of
concern.  Therefore, if peak concentrations of analytes are
important,  compositing should be supplemented with grab samples
taken at sites where and when high values are suspected.

     •    For collecting grab or composite samples from waste
          piles, the pile can be divided into a number of grids
          corresponding to the number of samples to be taken, and
          a surface sample taken from each grid using a stainless
          steel scoop.

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 7.3   COLLECTING SAMPLES FROM CONTAINERS

 Techniques for sampling from containers are determined by  the
 type of  container,  access to the container (opened/closed),  and
 the  physical state  of  the material  in the container (solid,
 liquid,  sludge).  Please note that  inspectors must not sample
 from tanks,  tank trucks,  or  tank cars until adequate guidance is
 available.

 In general,  samples collected from  containers and waste sources
 should be  similarly labelled and must be handled  and treated as
 hazardous  material  samples until reliable data indicate otherwise
 (see 40  CFR,  part 261  for definition  of hazardous materials,  29
 CFR  for  DOT  regulations,  and Appendix G - IATA Dangerous Goods
 Regulations).   If hazardous  materials must be collected, then
 compliance with specific  regulations  governing the packaging,
 transportation,  and disposal of  hazardous materials is  required
 (see 29  CFR,  40  CFR part  261,  and IATA Dangerous  Goods
 Regulations).   In addition,  hazardous materials must be disposed
 of in accordance  with  all state  and federal regulations.
 Guidance for  the  packaging and shipping of hazardous materials  is
 addressed  in  Section 9.0.  Detailed guidelines for collecting
 such samples  may  be found in "Compendium of ERT Waste Sampling
 Procedures,"  EPA/540/P-91/008.   Some  general guidelines for
 collecting samples  from drums  are presented below.

 7.3.1     Drum Sampling:   Liquid/ Sludge,  and Solid Waste

 Liquid Waste;  Samples can be  collected  from drums by using  a
 glass tube commonly referred to  as  a  glass thief  or drum thief.
 This  sampling device consists  of  an inexpensive and easily
 discarded or  decontaminated  glass tube.   The sample is  collected
 by opening the drum and lowering  the  glass  tube slowly  through
 the  open bung.  If  possible, the  tubing  should be  inserted at an
 angle to help obtain a representative  sample.  For most liquids,
 tubing with an inside diameter of 6 to 8 mm is adequate, but  a
 larger bore may be  needed  for more viscous  material.  The top end
 of the tubing is then blocked with a thumb  or rubber  stopper.
The tubing is raised from  the drum and held over the  sample
bottle,  while the thumb or stopper is raised  slightly to break
the vacuum and let  the sample trickle slowly  into  the container.
The operation is repeated until adequate volume is  obtained.
After the sample container is sealed,  the tube may .be discarded
by inserting  it back into the drum where  it  is broken,  or cleaned
for subsequent use.   This  sampling device has the  advantages  of
being disposable as well as easily cleaned.

Following are several important notes on sampling  liquid wastes
from containers:

     •    A 10 percent head space to allow  for expansion of the
          collected waste should be allowed  in any  container
          used;
                               25

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                                              RCRA Sampling SOP
                                              Date: November, 1995
                                              Revision: 1

       •    Sampling personnel  should  avoid  contact with the
           material on  the  outside  of the tubing.   In addition,
           samplers must  not allow  the material  spilled on gloves
           during the sampling process to come in  contact with the
           material from  a  different  drum.  Potentially dangerous
           reactions may  occur, which could result in failure  of
           the protective clothing.   Where  the presence of
           incompatible materials is  suspected,  the sampler  may
           wear several disposable  gloves.  The  outer glove  can be
           disposed of  after each sampling  operation.   Gloved
           hands should never  be used in an intended way in  which
           contaminated materials come in contact  with gloves,
           since the chemical  compatibility of gloves varies
           depending on the material  from which  the gloves were
           made.  The health and safety plan will  prescribe  PPE
           requirements;

     •     A rubber pipet bulb may  be used  on  the  sampling tube.
           Care must be taken  to prevent the material from
           contacting the bulb;

     •     The sampling team should attempt to determine if
           multiphase liquid layers are present  in the drum  by
           observing the  contents of  the glass tubing;

     •     If the sampling  party notes any  evidence of a reaction
           (such as light or smoke),  all equipment should be
           abandoned and  the site evacuated;

     •     If the glass tubing becomes clouded or  smoky when it is
           inserted in the  drum,  it should  be  withdrawn and
           discarded since  this may indicate the presence of
           caustics or hydrofluoric acid.   A. length  of  rigid
           Teflon tubing  and a Teflon sample container  should be
           substituted; and

     •     Sampling personnel should avoid  opening  any
           unidentified drums or containers without proper PPE and
          monitoring equipment.   The health and safety  plan will
          prescribe PPE requirements.

Sludge Waste;   For collection of sludge samples from containers,
larger bore glass tubing or an 8-ounce wide mouth glass jar
fastened to a length of wooden dowel may be used.   A minimum of
20 to 30 grams (g)  of concentrated sludge  is required  for
extraction and preparation.  This 20 to 30 g  sample would be
approximately equivalent to an 8-ounce wide mouth glass jar
three-quarters full.   The sampling apparatus may be discarded
with other waste accumulated during the sampling operation.

Solid Waste:   Occasionally, a drum containing solid or  granular
waste material may be encountered.   This type of material is
often contained in fiberboard drums.   An 8-ounce wide mouth glass
jar attached to a length of wooden dowel may be used  for an open-

                               26

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                                              RCRA Sampling SOP
                                              Date: November, 1995
                                              Revision: 1

top drum, and  a  brass  deflagrating  spoon attached to a length of
wooden dowel may be used  to  obtain  material  through a bung hole.
Only 20 to 30  g  of this type of material are required.

It is possible that when  a glass tube  is inserted through a hole
in a drum, a solid layer  may be encountered  below the liquid
layer.  If the solid layer is soft,  it is probably a sludge and
the sample may be obtained using the method  previously described.
If the solid is  hard,  it  could be a  hardened sludge,  or it may  be
a less common  reactive metal  such as sodium.  Apply pressure to a
length of glass  tubing carefully to  obtain a small core for
analysis.  A stainless steel  microspatula could be used to remove
the material from the end of  the tubing.  Care should be taken  to
keep the material from contacting water.  It should also be noted
whether the material discolors on contact with air.
                               27

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                                              RCRA Sampling SOP
                                              Date: November, 1995
                                              Revision: 1
 8.0   DOCUMENT CONTROL
 Many investigations at RCRA facilities may eventually provide
 evidence  of  RCRA regulatory or permit violations under the
 enforcement  provisions of RCRA.   All information,  data, samples,
 and  documents  must  be legally defensible,  must be treated as
 evidence  and must be retrievable  when the  project is completed.

 8.1   DOCUMENTATION

 All  observations and other pertinent data  must be recorded in an
 individual,  bound logbook.   It is important that logbook entries
 be made in ink and  be objective,  legible,  dated,  and signed by
 the  person recording the  information.   Logbooks are  helpful for
 completing reports,  for recall of events during possible future
 testimony, or  for use by  other EPA personnel if the  investigator
 is no longer available.   At a minimum,  it  is recommended that the
 logbook contain the following information:

 •     Project name,  site address,  date(s),  and site identification
      number;

 •     Site sketch;

 •     Sample  type, location,  and depth  descriptions,  and sample
      identification numbers;

 •     Type of sampling eguipment;

 •     Chronological  description of  field activities,  including
      date and  time  of  sample  collection;

 •     References to  documents  associated with the sampling effort,
      such as other  field  log  books,  the sampling and analysis
      plan, and health  and safety plan;

 •     All variances  from approved standard operating  procedures,
      including the  sampling and analysis plan;

 •     Observations and details  important to the  integrity of  the
      samples that may affect  data quality objectives;

 •     Name of laboratory to receive the samples;

 •    Recipients of split samples,  including  the date, time,
      location of sample transfer-,  and the identification number
     of the chain of custody record form;

 •    Levels of safety protection;  and

 •    Date of entry and signature of inspector.

Logbooks and chain-of-custody records are considered to  be
accountable documents.  Each of these must be retrievable and


                                28

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                                              RCRA Sampling SOP
                                              Date: November, 1995
                                              Revision: 1

 accounted for at the end of the project.   Official EPA Chain-of-
 Custody Record forms,  Custody Seals,  Traffic Report Forms,  and
 Field QC Summary forms may be obtained from the RSCC at QAMS (see
 Section 0.0).

 Sample bottle labels make it possible for individual samples to
 carry unique  identifying codes that are recorded in the logbook
 for the project.   A unique code makes sample handling and
 differentiation easier and provides a reference code for the
 laboratory to use when reporting analytical results.   Completion
 of  EPA sample bottle labels is addressed  in Section 9.1.

 8.2  CORRECTIONS  TO DOCUMENTATION

 If  errors are made while recording  observations and other
 information,  the  error can be corrected at once by drawing  a
 single line through the wrong information,  initialing the line,
 and entering  the  correct information.   Any error correction
 required after the fact can be accomplished by  drawing a single
 line through  the  wrong information  and entering the correct
 information.   It  must  be accompanied  by a signature and date of
 entry.   Explanations of corrections should be done in a narrative
 style and must be complete.

 8.3   PHOTOGRAPHS

 Photographs are important to  document  the cause-and-effect
 relationship  of the RCRA facility inspection, especially  in  the
 areas of  environmental  damage and permit  violations.  Whenever
 samples  are collected,  photographs  should be taken to verify the
 written  description in  the field  logbook.   Photographs  should
 contain  an  object to portray  the  scale of the subject being
 photographed.   Immediately after developing,  the back side of
 photographic  prints will  be labelled with the appropriate
 information so  the field  notebook can  be  used to reference the
 photos in the proper order.   In all cases where  a  photograph is
 taken, the  following information must  be  written in the  logbook.

      •    Time, date, location and, if  appropriate, weather
          conditions;

      •    Complete  description of identification of the subject
          in  the  photograph,  and reason why  the  photograph was
          taken;

      •    The sequential number of the photograph  and the film
          roll number; and

      •    Name of person taking the photograph.


 8.4  CONFIDENTIAL INFORMATION

Any information given to an investigator  and declared to be

                                29

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                                              RCRA Sampling SOP
                                              Date: November, 1995
                                              Revision: 1

confidential should be treated as confidential  business
information  (CBI).  Justification for the confidentiality  claim
must be provided  at the time of the claim.  All confidential
information should be stored in a separate  locked file and
recorded in a logbook for tracking purposes.  Such information
should be available on a need-to-know basis to  appropriate
personnel.  A check-out system should be used to control access
and prevent loss  of records.  Confidential  information must  not.
be reproduced except by approval of the person  in charge of  the
documents.  For more information about CBI, contact the Section
Chief of the RCRA Permitting Section.

Any data declared confidential according to the provisions of the
Toxic Substances  Control Act (TSCA; Public  Law  94-469)  must  be
received only by  a person with the necessary  specific  clearance.
All others should avoid receiving such confidential information.
                               30

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                                              RCRA Sampling SOP
                                              Date: November, 1995
                                              Revision: 1

 9.0   SAMPLE HANDLING,  PACKAGING,  AND SHIPPING PROCEDURES

 After samples  are  collected,  they must be handled in a manner
 which will ensure  that their  integrity is maintained.   Proper
 packaging and  shipping requirements  for samples  are discussed
 below.

 9.1   BOTTLE LABELLING  REQUIREMENTS

 Each  bottle should be  labelled with  the following information:
 sample location, analytical parameter,  EPA method number,  date  of
 sample collection, project name,  time  of sample  collection,  and
 any preservative added to the sample.

 9.2   CHAIN-OF-CUSTODY  DOCUMENTATION

 An unbroken chain  of sample custody, both  in the field  and the
 laboratory, is necessary to ensure that no one has  tampered  with
 the samples — an  important consideration  in legal  proceedings.
 Chain-of-custody records include  the logbook, chain-of-custody
 form  (Appendix E), and custody seals  (Appendix F).   Custody  forms
 are consecutively  numbered and must be  obtained  prior to  sampling
 from  the laboratory or from QAMS.

 After  sample collection and identification, the  samples should  be
 maintained under the chain-of-custody procedures.   If the  sample
 collected is to be split with the  owner or operator of the site
 or other regulatory entities, it must be aliquoted  into similar
 sample containers.  Bottle labels  completed with  identical
 information are attached to each of the sample bottles prior to
 sample collection and  are marked as "split."  EPA Region  IX  QAMS
 recommends that unigue codes and sample identification numbers  be
used on chain of custody forms so that  field QC  samples cannot  be
differentiated from primary samples by  the laboratory.  The  field
notebook should contain a key for the identification of field QC
samples.

Each person involved with the sample must know chain-of-custody
procedures.   Because samples can serve  as  legal evidence,  the
possession of samples must be traceable from the time they are
collected until they are introduced in  legal proceedings.  Chain-
of-custody procedures are summarized below.

     •    A sample is under custody if:

          1.    It is in your actual possession;

          2.    It is in your view, after being in your physical
               possession;

          3.    It was in your physical possession and then locked
               in a car or room to prevent tampering; and

          4.    It is in a designated and identified secured area.

                               31

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                                    RCRA Sampling SOP
                                    Date: November, 1995
                                    Revision: 1
 Field  Custody  Procedures
 1.    To  the  extent  possible,  the  quantity and types of
      samples and  sample  locations are  determined before
      the actual field work.   The  sample  bottle label
      should  be completed and  affixed to  the  container
      prior to sample collection;   as few people as
      possible should handle the samples.

 2.    Sample  labels  are to 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.  In addition,  EPA
      Region  IX recommends sealing the  label  to the
      bottle  with  a  piece of wide  clear tape  long enough
      to  completely  go around  the  bottle.

 3.    The  field sampler is personally responsible for
      the  care and custody of  the  samples until they are
      transferred  or properly  dispatched.   The sample
      collectors for the samples listed in  a  chain-of-
      custody  form must sign the upper  left box of this
      form.

 4.   The  inspector  must review all field activities to
     determine whether proper custody  procedures were
     followed during the field work, and must decide if
     additional samples are required.  The inspector
     should notify  the EPA Regional QA Officer of any
     breach or irregularity in chain-of-custody
     procedures.

Transfer of Custody and Shipment

1.   Samples are accompanied by a chain-of-custody
     record.   When transferring the possession  of
     samples, the individuals relinquishing and
     receiving the samples will sign,  date, and note
     the time on the record.   This record documents
     transfer of custody of samples from the  sampler to
     another person, to a mobile laboratory,  or to  the
     permanent laboratory.

2.   Samples will be properly packaged for shipment  and
     dispatched to the appropriate laboratory  for
     analysis, with a separate signed custody record
     enclosed in each sample box or cooler.  Shipping
     containers will be locked or secured with
     fiberglass or nylon strapping tape for shipment to
     the laboratory.  Preferred procedure is to affix
     two signed and dated chain of custody seals on the
     front of the cooler and two signed and dated chain

                     32

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                                              RCRA Sampling SOP
                                              Date: November, 1995
                                              Revision: 1

                of  custody seals  on the back of the cooler.   The
                custody  seal  should be folded over and stuck to
                the shipping  container so the gap between the lid
                and the  body  of the shipping container is covered.

           3.    The responsible party  must accept/decline split
                samples.   One of  the four appropriate
                "relinquished by/received by" signature boxes
                should be  signed  and dated by the responsible
                party who  accepts the  split samples.   A copy of
                the chain  of  custody is given to the  responsible
                party.   If he/she is not present,  the copy will  be
                mailed certified  to him/her.   This communication
                must be  recorded  in the field logbook.

           4.    All shipments will  be  accompanied by  the chain-of-
                custody  record identifying the contents.  The
                original record will accompany the shipment  and  a
                copy will  be  retained  by the  project  leader  for
                the file.

           5.    The overnight carrier  contracted by EPA Region IX
                for shipment  of samples should be contacted  when
                arranging  for shipping to assist in completing
                specific airbill  information  required,  especially
                when shipping hazardous material samples.  The
                airbill will  be retained as part of the permanent
                chain-of-custody  documentation.

Receipt for Split  Samples

A receipt must  be  provided for samples  split  with facility
owners.  A chain-of-custody  form can  be modified  to  serve as a
receipt document or the receipt  form.

9.3  PACKAGING  AND  SHIPPING  PROCEDURES

The shipper (person signing  the  shipping papers)  is  responsible
for ensuring that  samples are packaged  in accordance with the
provisions of this manual.   All  sample containers must be placed
inside a strong shipping container.  A sturdy metal  cooler lined
with hard plastic  liner is recommended.  Based  on the
concentration of the samples to be  shipped, one of the following
procedures below is to be followed.

9.3.1     Shipment of Low Concentration Samples

     •    Using fiberglass or nylon strapping tape,  secure the
          drain plug at the bottom of  the cooler to ensure that
          water from melting ice does  not leak  from the cooler.

     •    Check screw caps for tightness and mark the sample
          volume level on the outside  of large containers with a
          wax pencil.


                               33

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                                    RCRA Sampling SOP
                                    Date: November, 1995
                                    Revision: 1

 Place a custody seal over each bottle cap.   Wrap glass
 bottles with bubble wrap and tape.

 For  large  glass containers such as  half-gallon jugs for
 extractable organic analysis,  pieces of carved-out
 plastic foam may be used to help keep the containers in
 place.

 Small containers,  such  as 40 mL septum vials for
 volatile organic analysis,  may be placed in small
 plastic bags,  or secured in test tube racks.   Padding,  •
 such as bubble wrap,  should be wrapped around the vials
 for  protection.   When shipping the  vials with larger
 containers,  steps should be taken to prevent the larger
 containers  from shifting,  which could cause the  vials
 to break.

 Place each  individual bottle into a Zip-loc plastic bag
 and  seal by taping the  plastic bag  shut.

 Place the protected bottles in a cooler,  which has been
 double-lined with two large plastic bags.   Add double-
 bagged  ice  to  maintain  the  proper temperature inside
 the  cooler.  Double-bagging the ice will prevent water
 leakage into the  cooler.  Loose ice must not be  poured
 into the cooler.

 Fill empty  spaces  in  the cooler with vermiculite,  or
 other appropriate  absorbent in order to  any absorb any
 spilled material.   EPA  recommends that Styrofoam™ not
 be used as  an  absorbent since  the properties  of
 Styrofoam™ do not allow it to be an effective
 absorbent.   Line the  bottom of  the  cooler inside the
 plastic bag  with a  3-inch layer of  cushioning and
 absorbent material  such as  Styrofoam popcorn  or
 vermiculite.

 The  chain-of-custody  record should  be sealed  in  a  large
 sealed  plastic bag  attached to  the  inside of  the cooler
 lid  so  that  it will not  be  damaged  by leaks.

 The  lid  of the cooler should be  closed and  the latch
 fastened.  Seal the cooler  shut  with  strapping tape.
 The  cooler should be wrapped completely  (twice around)
 with  nylon strapping tape in two locations.   Affix  four
 signed  and dated custody seals  to the cooler, two on
 the  front and two on the back.   Cover custody seals
with  clear tape.

The  following self-adhesive  labels  should be  placed on
 the  outside  of the cooler:

     Name and address of receiving  laboratory with
     return address.


                      34

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                                              RCRA Sampling SOP
                                              Date: November, 1995
                                              Revision: 1

                Label  on  the  top  of  the  cooler indicating  "This
                End Up".

                "Fragile"  on  two  sides  (optional)

                Additional labels, such  as  "Liquid in Glass,"  are
                optional.

      •    The samples should be  shipped by overnight carrier  by
          completing  the  airbill as described in  Section  11.2.
          Personnel should be prepared  to  open and reseal the
          cooler for  inspection, if required.

      It is important  to notify the  EPA  Region IX  RSCC by
      telephone  at (415) 744-1498 within 24 hours  after sample
      shipment.  Please provide the  RSCC with  the  following
      information:

      •    Sampling contractor or EPA staff name(s);

      •    Site  name;

      •    Total number(s)  by concentration and matrix of  samples
          shipped to  each laboratory;

      •    Carrier, airbill number(s), method  of shipment  (e.g.,
          priority next day);

      •    Shipment date and  intended laboratory receipt date;

      •    Irregularities  or anticipated problems  associated with
          the samples; and

      •    Whether the current shipment  is  the  final  shipment  or
          if additional samples  will be shipped under the same
          case number.

9.3.2     Shipment of Hazardous  or High Concentration Samples

IMPORTANT NOTE:  If hazardous materials must be collected, then
careful attention must be paid to packaging and transportation
requirements.  In addition, hazardous materials must  be disposed
of in accordance with all state  and federal regulations.
Guidance for the packaging and shipping of hazardous  materials is
addressed in this section.  The  ESB laboratory and many private
analytical laboratories will not accept unknown hazardous
material samples.  When collection of a hazardous material sample
is warranted, the inspector must be able to properly  identify,
label, and ship the "dangerous goods" according to appropriate
regulations  (Appendix G).  Specific requirements-may  be found in
40 CFR 172.402 and the International Air Transport Association
(IATA) Dangerous goods regulations  (Appendix G).  Because the EPA
contract carrier uses air transportation,   IATA regulations apply.
Some of the most common shipping names  and associated UN shipping


                               35

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                                             RCRA Sampling SOP
                                             Date: November, 1995
                                             Revision: 1

numbers for dangerous goods include the following:  (1) UN  3082
Environmentally hazardous substance, liquid, n.o.s.;  (2) UN 3077,
Environmentally hazardous substance, solid, n.o.s.; and  (3)  UN
8027, Other regulated .substance.  Use of these shipping names
also requires use of appropriate labels (i.e., flammable,
corrosive), containers, and packaging.

Shipping procedures for flammable liquids (or solids)  are  similar
to the procedures outlined for environmental samples,  with  the
exception that EPA policy requires that the samples be contained
in metal paint cans for added security.  In addition,  ice  is not
added to the cooler.  Follow the procedure outlined in Section
9.3.1 with the following additional steps:

     •    Line the bottom of the cooler inside the plastic  bag
          with a 3-inch layer of cushioning and absorbent
          material such as vermiculite.

     •    To prevent leakage,  fill container no more than 90
          percent full at 130°F.   If an air  space in the sample
          container would affect sample integrity, place that
          container within a second container to meet the 90
          percent requirement.
            \
             N
     •    Place sample bottle inside a 1-quart (preferred)  or 1-
          gallon metal paint can and cushion it with enough
          vermiculite between the bottom and sides of the can and
          bag to prevent breakage and absorb leakage.  Pack one
          bag per can.   Use clips to hold can lid secure and
          tight.

     •    Place the following  information,  either hand-printed or
          in label form,  on the metal can:

               Laboratory name  and address

               "Flammable Liquid,  n.o.s.  UN1993"  or  "Flammable
               Solid,  n.o.s. UN1325." Not otherwise  specified
               (n.o.s.)  is not  used if the flammable liquid (or
               solid)  is identified.   Then the  name  of the
               specific material  is listed before the category
               (for example, Acetone,  Flammable Liquid) followed
               by its  appropriate UN number  found in the DOT
               hazardous materials table  at  Title 49 of the Code
               of Federal Regulations (CFR)  Part 172.01,  (49 CFR
               172.101).

               "Dangerous When  Wet"  must  be  used with "Flammable
               Solid"  label  if  material meets the definition of a
               water-reactive material.

               "Cargo Aircraft  Only:  must  be used if net quantity
               of sample in  each  package  is  greater  than 1  quart
               (for "Flammable  Liquid,  n.o.s.")  or 25 pounds (for

                               36

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                                    RCRA Sampling SOP
                                    Date: November, 1995
                                    Revision: 1
      "Flammable  Solid,  n.o.s.").
Place the metal cans  in  the  cooler.   Additional
cushioning and absorbent material  should be placed
between the metal cans by  filling  all remaining space
with vermiculite.  The top of the  liner should then be
tied shut and sealed  with  tape.

The custody record should  be sealed  in a large plastic
bag attached to the inside of the  cooler lid so that it
will not be damaged by leaks.  The lid of the cooler
should be closed and  the latch fastened.

After acceptance by the  overnight  carrier,  the cooler
should be wrapped completely (twice  around)  with nylon
strapping tape at two locations.

Affix signed and dated custody seals  on the front right
and left rear aside of the cooler.   Cover seals with
clear tape.

The following self-adhesive  labels are  placed on the
outside of the cooler.

     All labels previously described  for  the metal
     cans.

     Arrows indicating "This End Up"  on all  four sides.

     "This End Up" on the top of the  lid.
                     37

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                                              RCRA Sampling sop
                                              Date: November, 1995
                                              Revision: 1
 10.0  REFERENCES
 1.    Standard Operating Procedures for the Collection of Samples
      of  Opportunity at EPA Region 8 RCRA Facilities,  October
      1993.

 2.    Principles  of  Environmental Sampling.  Edited by Lawrence H.
      Keith, American Chemical  Society,  1988.

 3.    Characterizing Heterogeneous Wastes:   Methods and
      Recommendations,  EPA/600/R-92/033,  February 1992.

 4.    Quality  Assurance/Quality Control  Guidance for .Removal
      Activities, Interim Final,  EPA/540/G-90/004,  April 1990.

 5.    Preparation of a  U.S.  EPA Region 9  Field Sample  Plan for
      EPA-Lead Superfund Projects,  U.S.  EPA  Region 9,  Quality
      Assurance Management  Section,  Document Control Number 9QA-
      05-93, August  1993.

6.    Handouts from  Hazardous Waste Site  Sampling Course (EPA
      Course 161.5),  EPA Region IV,  Environmental Services
      Division.

7.    Compendium of  ERT Waste Sampling Procedures,  U.S.  EPA,
      Office of Solid Waste  and Emergency Response,  EPA/540/P-
      91/008, January 1991.

8.    Compendium of  ERT Surface Water and Sediment  Sampling
      Procedures, Office  of  Solid Waste and  Emergency  Response,
      EPA/540/P-91/005,  January 1991.

9.   Test Methods for  Evaluating Solid Waste,  SW-846, Volumes
      I-II with updates through IIB  (January 1995).

10.   Guidance for Data Quality Objective Process,  EPA QA/G-4,
     Final, September  1994

11.   IATA Dangerous Goods Regulations, 36th Edition,  effective
     January 1, 1995.
                               ,38

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      APPENDIX A



Abridged Sampling Plan

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                      ABRIDGED SAMPLING PUN (Page 1 of 2)
 I. Site/General Information

 Facility/Site Name:		  EPA ID#:
 Address: .	.	.	—
 General Location:	
 Anticipated Sampling Date(s):
 11. Site-Description
ill. Sampling Objectives and Rationale (including number and type of field QC samples planned):
IV. Environmental Samples Requested

5ample(s) Analysis:

Type/Number                                             Type °f
of Samples             Test              Method       '     Bottle           Preservation

                     VOA         '.                                                 "
                  Semivolatiles
              	Metals	
                   Ignitability
                   Corrosivity
                Reactivity (sulfide)
               Reactivity (Cyanide)
                   TCLP-VOA
                   TCLP-BNA
                   TCLP-Herb
                 TCLP Pesticide
                 TCLP-metals

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                     ABRIDGED SAMPLING PLAN  (Page 2 of 2)
                    —    -

 V. Field Equipment Requested
 VI. EPA Inspection Personnel



    Personnel/Telephone Number                            Responsibility
VII. Miscellaneous



Lab Name/Location:



Facility Contact: 	
VIII. Signature/Approvals



Sample Plan Prepared by:	 Date:



Approved by:	  Date:

-------
     APPENDIX B



Health & Safety Plan

-------
           UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                    OFFICE OF POLICY AND MANAGEMENT
                        HEALTH AND SAFETY OFFICE

                     SITE SAFETY AND HEALTH PLAN
  Site:
  Location:
Site Phone: (	}.

Superfund :  Yes .
                              No
  SSP Prepared By:
     Mail Code ( - - ) Phone 4-_
  Proposed Date of Response/Investigation:

  Purpose/Objective:	
 Background Review:              Complete

 Background Material Attached:    Yes
                   Preliminary

                   No 	
 Indicate which of the following information source(s) were  consulted:
 State and/or Local Agency,  State and/or Federal OSHA, NXOSH,  EPA
 files, Site Operator and Local Fire Department.
 Overall Hazard Summary:
Low
          High
                               Medium 	  Unknown

 Route of Exposure: Inhalation 	  Skin Contact 	

 Map or Sketch Attached:        Yes 	          No
                       Ingestion
EPA-9  FORM HSO-003-1
  page 1
                                                 Revised May, 1992

-------
EPA-9  FORM HSO-003-1
                                       p=.ge 2
Reviicd May, 1992

-------
 A. Facility Description:.
 B. Hazardous Substance(s) Description;
 C. • Disposal/Storage Methods:
 D.  Status:  Active 	   Inactive 	  Unknown 	

 E. History:  (Include accidents or injuries on-site, complaints from
 public, previous releases and agency reports):	
 F. Is personal protective equipment required by Facility /Site
 Management? List equipment and specific areas where required:
 G. Are employees working at the facility/site monitored for exposure
 to airborne contaminants? If so, describe situation:
 H. Do employees working at the facility/site participate in an
 occupational medical monitoring program? If so, are  special
 biological tests performed or Biologic Limit Values  (BLVs)  used?
 I. Describe medical monitoring procedures for evidence  of personnel
 exposure: 	
 J. Is there an on-site emergency alarm system? If so, describe alarm:
 K.  is there an eyewash/safety shower available on site?   If not,
 explain alternate procedures (where applicable):	
EPA-9  FORM HSO-003-1                page 3           Revised May, 1992

-------
          —^—•_   -.'   	          ' —	                           	
 A. Hazard Assessment  (Toxic effects,  TLV,  odor threshold, reactivity,
 stability,  flammability, and  operational hazards with sampling,
 decontamination, etc.)  Attach Material Safety Data Sheets for toxic
 compounds:	.—.—.	—	•	'•	


 Areas of Concern         Hazard Potential         Precautions
          ~               (High, Tied,  Low)
 Explosive;               __	    	

 Oxygen Deficient;
 (e.g. Confined Spaces)   	    	
 Additional workplan is required for confined space entry.

 Particulates; (dusts, mists.
 asbestos fibers,etc.)

 Toxic Gases/Vapors:
 a. General  (HNU meter)

 b. Specific:  (e.g.,
 Sorbent or Detector Tube)

 Skin/Eve Contact;
 Ultraviolet  (UV) :
 Heat Stress:
 Falling Objects;
  (stacked drums, etc.)

 Falls ; pits, ponds,
 elevated work places)

 Radioactive Hazard:      Hazard?        Exposure rate       Source
 Background               yes no
 Alpha particles          yes no
 Beta particles           yes no
 Gamma radiation          yes no
 B.  Monitoring Instruments and Techniques To Be Used:  (air,
 environmental, personnel):                           Date calibrated
 	  a. Combustible gas indicator                        	
 	  b. Oxygen concentration meter                       	
 	  c. Radiation survey meter  (Type;   	)       	
 	  d. Organic vapor survey meter  (Type;    	)     	
 	  e. Colorimetric tubes  (Type:	)     	
 	  f. Other (	)     	
EPA-9  FORM HSO-003-1                page 4           Revised May,

-------
Hazardous Substance «-- r^

A.  Level of Protection:  A

Modifications: _
                                  Field Investigations

                                  B       C -   D
 Surveillance Equipment and Materials:
     Entry Procedures:
 C.  Field Investigation and Decontamination Procedures:
 Perimeter Establishment: Zones of Contamination Identified?
 Public Perimeter Identified?

 Notes: 	
                                   Map/Sketch Attached?
 D.  EPA Personnel
                           Cert.     Initial
   Name       Field Duties Level     24/40hr
                           (B,I,A)*  train.
                                              INSERT DATE
                                              Last    Last     Last
                                              8-hr    Resp.    Mod.
                                              train,  fit-test exam
 E.  Work Schedule/Limitations  (Heat Stress)
 F. Communications:      Radio Call Sign:  	
      Frequency/Channel:  	

 6.  Spill Containment Procedures  (loose particulate absorbent,
 spill control pillows, spill pads/blankets):	
 * Indicate Basic, Intermediate, or Advanced Certification Levels
EPA-9  FORM HSO-003-1
                               page 5
                                                  Revised May, 1992

-------
  H.  Decontamination Procedures (contaminated protective clothing,
  instruments,  equipment,  etc.): 	
  I.   Disposal Procedures (contaminated equipment,  supplies, disposal
  items,  wash water,  etc.):.	;	.	
  J.  Project Team Leader is responsible to provide each designated
  EPA employee with a copy of this Site Safety Plan,  in addition, pre-
  entry briefings are to be held prior to initiating any site activity,
      at such other times as necessary.   Initial (  )
       Compound
Acute Exposure Symptoms
First Aid
 A.  Nearest Hospital Emergency Room.   Note:  for remote locations,
     give directions to hospital and attach map.
    Name: 	
    Address:
    Telephone: 	

 B. Emergency Services  (Telephone Numbers)
    1.  Fire: 	
    2.  Police: _
    3.  Ambulance
 C.  Poison Control Center of San Francisco
         Toxic and Hazardous Chemicals:  415-476-6600  (24-Hr.)

 D.  Regional Health and Safety Office:  415-744-1607  or -1606

 E.  Regional Radiation Representative: Hike Bandrowski 744-1048
     Steve Dean   (415) 744-1045.
EPA-9  FORM HSO-003-1
        page 6
                                                  Revised May, 1992

-------
  PLEASE NOTE:  The  Project  Team Leader is responsible for submitting
  the  site-specific  Post-Visit Summary to the Health and Safety Office
  within two weeks after completing the trip (see Appendix B) »
                                                             Date:
  Project Team Leader:

  Supervisor: 	
  Health and Safety Office:
EPA-9  FORM HSO-003-1
                                 page  7
                                                   Revised May, 1992

-------
                       ATMOSPHERIC HAZARD GUIDELINES1
Monitoring Equipment   Hazard
Combustible gas
indicator
Explosive
atmosphere
 Ambient Level

 < 10% LEL



   10%-25%
Oxygen % meter
  Oxygen
                                      > 25% LEL
 < 19.5%
                                        19.5%-22%
                                           >  25.0%
Radiation Survey
Instrument
 Ionizing
 radiation
 3  to 5  times
 above background
 (approx 30  -
 50  uREH/HR).

. > 1.0  mR/bx
 Action

 Continue
 monitoring
 with caution.

 Continue
 monitoring
 with extreme
 caution,
 especially as
 higher levels are
 encountered.

 Explosion •hazard!
 Withdraw from area
 immediately.

 Monitor wearing
 SCBA.
MOTE; Combustible
 gas readings are
 not valid in
 atmospheres with
 < 19.5% oxygen.

 Continue
 investivation
 with caution. SCBA
 not needed, based
 on oxygen content
 only.

 Discontinue
 inspection
 Fire potential.
 Consult
 specialist.
                                                          Consult Health
                                                          Physicist.
                                                          Stop work.
                                                          Consult
                                                          Health Physicist.
      EPA-9 FORM HSO-003-1
            page 8
                                                       Revised May, 1992

-------
  pnitoring Equipment

 r^olorimetric tubes
Hazard
Ambient Level
  oncentrations.*

 "hotoionization
  etector (PID)a
 Standard
'_yiame ionization
 letector (FID)3
 Standard
r-Safety
     Organic and
     inorganic

     vapors/gases
      Depends on
      chemical
                                                           Action
     Consult standard
     reference manuals

     permissible air
Organic
vapors/gases
Organic
vapors/gases
1) Depends on
   species
     2) Total

   response
   mode

1) Depends on
   chemical
Consult standard
reference manuals for
permissible air
concentrations

     Consult EPA

Operating Safety
Guides.5

Consult standard
reference manuals for
air concentrations/
toyicity data.
                    2) Total        Consult EPA
                            response     Operating
                                mode          Guides
 NOTE 1:  Reference - Standard Operating Safety Guides, Office of
          Emergency and Remedial Response,  Hazardous Response Support
          Division, November,  1984.

      2:  HNU Photoionizer or other PID instrument.

      3:  Century Organic Vapor Analyzer (OVA) or equivalent.

      4:  ACGIH-TLVs, OSHA PELs (29 CFR 1910.120), NIOSH - Pocket Guide
          to Chemical Hazards, MSDSs, etc.

      5:  Background to 5 ppm above background - Level C
          5 to 500 ppm - Level B
       EPA-9 FORM HSO-003-1
            page  9
                                                         Revised Hay, 1992

-------
                             POST-VISIT SUMMARY
Employee(s):.

Site:	
                                        Field
                                        Activity Date (B):.
                                      City/State:
  If Superfund, list Site Number:.

1.  Protection Level Used:  A	
5.

6.
    a.  Level B/C - Skin protection:  Tyvek
                                                 Tyvek/Saranex
                                                 	  Other 	
                                      Acid/Rain 	
    b.  Level C - Identify Cartridge/Canister	
    c.  Level D - Provide Justification for Hazard Pay Differential*
2.  Monitoring Instruments Used:

    a.  Combustible gas indicator
    b.  Oxygen concentration meter
    c.  Radiation survey meter (Type:
                                                            On-Site Levels
                                                                       T.TtT.
                                                                       Oxygen
    d.  Organic vapor survey meter (Type:
    e.  Colorimetric tubes (Type: 	
    f.  Other (	
                                                                _mR/hr
                                                                jppm.
                                                                _ppan
3.  List possible chemical exposure:.
    Did any of the above-mentioned employees experience respirator cartridge
       breakthrough?  If yes, explain.  Yes 	  No 	

    Equipment Decontamination:  a. Clothing  b. Respirator  c. Monitoring

                         Disposed:   	     	
                       Cleaned:
                     No Action:
Approximate time in hot zone/exclusion area:
Was Medical attention/exam required for this response:  Yes
If yes, explain:	
                                                                     No
7.  Date
    Prepared:
                    Supervisor's
                    Signature:
                                                               Date:
For additional comments use reverse, or additional pages.
      EPA-9  FORM HSO-003-1
                               page 10
                                                        Revised May, 1992

-------
    APPENDIX  C



Equipment Checklist

-------
        APPENDIX C




FIELD EQUIPMENT CHECKLIST
1 EQUIPMENT
Nylon rope (50')
Strapping tape
Tape measure (50')
1 Utility Jknife
Polyvinyl chloride
(PVC) scoops
Stainless steel
spoons /mi crospa tul a
Field logbook vith
pens
Flashlight
Rubber pipet bulb
Drum thief (Colivasa
tube) and rubber
stopper
80-oz amber bottles
1- liter amber
bottles
1-liter poly bottles
40-ml volatile
organic analysis
(VOA) vials
4—oz glass jars
8-oz glass jars
ITyvek coveralls
Surgical gloves
(indicating the
material the gloves
are made of)
Nitrile gloves
Trash bags (10)
RECOMMENDED
AMOUNT
1 bag
2 rolls
1
1
as needed
as needed
1
1
1
2
as needed
as needed
as needed
as needed
as needed
as needed
3
1 box
3 pair
1 box
ACTUALS!
AMOUNTX
-.



















CuECKEb bx : \
4i(INITIAL)





















-------
EQUIPMENT
Shipping labels
Chain-of -custody
forms
Bottle labels
Chain-of -custody
forms
Bottle labels
Wooden dowel
Supplies for
compositing soil
samples (see Section
8.2.1 for options -
stainless steel
bovl, aJiimfmin pie
tin/ paper paint
bucket)
Shovel (leacbate
sample collection)
pB paper or pB meter
Rigid Teflon"1 tubing
Teflon™ beaker
AJ «>n i num tel escoping
pole £ clamp
RECOMMENDED
AMOOWTliisI
as needed
3
as needed
3
20
1
as needed
as needed
one roll of
paper
or one meter
as needed
(indicate
length)
as needed
as needed
ACTUAL
^ImHoonT^'--


-









CHECKED BY:
^(INITIAL)
..











HOTS: The items listed on this checklist as veil as tie recommended amounts
      are only intended to be used as a guide to inspectors.  Jt is possible
      that equipment not listed on tnis checJtlist trill be needed for a
      particular sampling event, just as it is likely that the recommended
      amounts of equipment needed for a particular sampling event vill
      probably vary depending on the sampling event.

      Sampling personnel are to be equipped with steel-toed hoots, hard hat,
      safety glasses, and respirator with cartridges.  Cartridges are not
      included in the sample fait hecause they have expiration dates and should
      be discarded if expired.

-------
          APPENDIX D




SW-846 Test Methods to Know.

-------
                                      APPENDIX D
                      COMMON Sff-846 TEST METHODS TO KNOW ...
 from Test Methods for Evtlimtir* Solid Uwte. SU-846. Volume I-II with updrtM through II-B-. .January 1995.
PARAMETER/SPA
VASTS CODS
TCLP zero
headspace
extraction
(volatilea)/
D004
TCLP
extraction
(Beou.volatdJ.ea
, pesticides,
herbicides, f
metala)/D004
Ignitability/
D001
Reactivity/
D003
Corroaivity/
D002
pB
Stuel
f^hrnmitnn YI
Mercury
Cyanide
ynffllHOP'
VUXBRR
1311 /ZEE
I31lf
SVUST
1010
Sff-846
Ch. 7,
Vol. I
9045
1110
7196
7470
9010
SJOPLB OWTAUnSR
Solid Liquid
*4 ox jar
*16 ox jar
8 of jar
8 of jar
8 of jar
8 of jar
8 of jar
8 of jar
4 of jar
2 40-mL
vials
2 1 -liter
amber
glass
IT/A
JT/A
JT/A
*/A
1 liter
poly
1 liter
poly
1 liter
poly
SJUfPLS
PJUSSKRVATTOK
5 « Solid
L - liquid
*L-1:1BC1 <
2pB
Stir-cooled
4*C
^SSL-cooled
4*C
V/A
IT/A
If/A
JT/A
S«L-cooled
<°C
L-BVO^ < 2 pB
L-2mlB of 10H
KaOB
S t L -
cooled 4F°C
"BDLDJKC
:TZHK
14 days
14 days
14 day a
ASAP
ASAP
ASAP
24 hours
28 days
14 days
NOTE: Sample container and preservation requirements are baaed on environmental or low
      concentration samples.  Hazardous Material or higli concentration samples are
      collected in 8-0 f glass jars, regardless of matrix,  and do not require
      preservation.  Bach 8 ox vide •outn glass jar that contains nign concentration
      sample Media needs to be placed in a aetal paint can for shipment.
           TCtP,  if the solids content of the sample exceeds 0.5 percent,  the volumes
      specified for liquids may not be sufficient to perform a  TCLP extraction.
                  K/A
                  c
                  Of
                  mT.
                  BCL
                  BKO,
                  VaCS
                  Poly
                  Amber
Hot applicable
Celsius
Ounce
ffilliliter
Hydrochloric acid
Witric acid
Sodium hydroxide
Polyethylene
Glass Amber

-------
                               APPENDIX D  (Continued)
                     COMMON Stf-846 TEST METHODS TO KNOW . . .
 Free -T««t Methods for Ev*li»tir« Solid Uaste. SW-846. Voliae I-II with update, throu^ II-i-. January 1995.
PARAMETER/EPA
VASTS CODS
Volatilea
Senivolatiles
(BNA)
Pesticides
Herbicides
PCBB
fuels
Balogenated
VOCa
2 Aroma tic VOCa
Combined
pur-gables
2Phenola
Metals
Cyanide
Mercury
Conductivity
pB
Phthalatea
METHOD
VUXBSR
8240
8270
8080
8151
8080A
BOISE
8010 A
8020A
8021
8041
6010/7000
series
9020
7470 (L)
7471 (S)
90501
120.V
9040 (L)
9045 (S)
8060
SAXPLB CONTAINER
Solid Liquid
4 os jar
16 o* jar
0 o* jar
8 os jar
8 o* j'ar
4 ox jar
4 os jar
4 os jar
4 os jar
8 os jar
8 os jar
4 os jar
8 os jar
8 os jar
4 os jar
8 os jar
2 40-mL
vials
2 1 -liter
glass
80 os
amber
80 os
amber
1 liter
amber
2 40-mL
vials
2 40-mL
vials
2 40-mL
viols
2 40-mL
vials
1 liter
amber
1 liter
poly
1 liter
poly
1 liter
poly
1 liter
poly
1 liter
poly
1 liter
amber
SAMPLE
PRESERVATION
S - Solid
L - Liquid
L-ltlBCl < 2pH
StL-cooled 4°C
StL-cooled 4°C
StL-cooled 4°C
StL-cooled 4°C
StL-cooled 4°C
StL-cooled 4°C
L - Ka^O,
StL-cooled 4°C
L - EC1 < 2pH
StL-cooled 4°C
L - SCI < 2pH
StL-cooled 4°C
L - SCI < 2pS
StL-cooled 4°C
L-0.1N BNO, <
2pB
L-2mlB of ION
NaOB
StL-cooled 4°C
L - ON03 < 2 pS
StL-cooled 4°C
StL-cooled 4°C
StL-cooled 4°C
HOLDING
TIME
14 day a
14 day a
L-7 days
5-14 days
L-7
S-14
7 days
14 day a
14 day a
14 day a
14 day a
7 day a
6 months
14 day a
28 days
28 days
ASAP (in
field)
7 days
NOTE: Sample container and preservation reguireaents are based on environmental or lov
      concentration samples.  Hazardous Material  or nigh concentration mamplea are
      collected in 8-os glass jars, regardless of matrix, and do not require
      preservation.

      '•Methods for the Analysis of Water and Wastes', SPA document.

      2It is recomended that NaySf, be used to preserve samples that are suspected of
      containing residual ch2orj.de, and that Na-SJO, be added to the samples before BCL
      to ensure that free chloride is removed properly.

-------
              APPENDIX E



Chain-of-Custody Form and Instructions

-------
                   Instructions  for Completing

                      CHAIN-OF-CUSTODY FORM
     GENERAL:

     A chain-of-custody form must be completed for each cooler
     shipped.  (Note:  If samples come from multiple sites,  one
     chain-of-custody form should accompany samples from each
     site).   The carbon copies of the original form should be
     distributed as follows:
     Original copy (white)
     First copy (pink)
     Second copy
B.   PREPARATION:

     1.   Project  Number
     2.   Project  Name
     3.   Samplers
     4.    Station Number

     5.    Date
     6.    Time
     7.    Comp
     8.    Grab
     9 .    Station Location
     10.   No.  of Containers
          Insided slanted
          lines
          Remarks
11.

12.

13.   Relinquished by
     14.   Date/Time


     15.   Received by

     16.   Received by  lab
                              Shipped with samples
                              Retained in EPA regional files
                              Presented to site owner or
                              mailed if no representatives
                              are on site.
Enter number
Enter number and case number
Enter signature of all
samplers who have signed
custody seals
Enter sample points/locations
listed in sampling plan
Enter sampling date
Enter time
Check if sample is composite
Check if sample is grab
Location description
Enter number of containers
collected at each station
point.
Enter EPA Method Number(s)

Enter airbill number and
custody seal number
Signature of one of the
samplers.  Must match
"samplers" at top of custody
record
Enter date and time samples
are relinquished to laboratory
or to Federal Express
Enter name of carrier (Federal
Express)
Signature of individual in
laboratory who signed for
samples

-------
    I HUHIVILH I ML. I IIU I LO I I wi <

         Office of Enforcement
                                                           CHAIN OF CUSTODY RECORD
                                                                                                                 75 Hawthorne Street
                                                                                                            San Francisco, California 94105
   PROJ NO.
PROJECT NAME
SAMPLERS: ISigntture)
 STA. NO.
          DATE
                 TIME
                         STATION LOCATION
                                                      NO.


                                                      OF


                                                      CON-
                                                    TAINERS
                                                                                                                             REMARKS
Relinquished by:
                   Date /Time
Received by: ISigntturtl
Relinquished by: (Signtturtl
              Date /Time
Received by:
Relinquished by: ISigntturtl
                   Date /Time
Received by: {Sign*tun)
Relinquished by:
              Date /Time
Received by:
Relinquished by: tSignnurel
                   Date /Time
Received for Laboratory by:
ISigntturil
     Date /Time
                   Oillribution: Origins! Accomptnin Shipmtnt; Copy to Coordinator Fittd Filtl
Remarks
                                                                                                                   9   22273

-------
     APPENDIX F



Chain-of-Custody Seal

-------
                       SAMPLE CUSTODY SEAL
This seal may be placed around each container top in such a manner mat attempts to
open the container will cause damage to the seal.

Alternatively, mis seal may be placed on the front and rear side edge of the shipping
cooler instead of on each sample container

Enter shipping date on the seal and sign your name.

-------
           APPENDIX G



IATA Dangerous Goods Regulations

-------
IATA
       REGULATIONS
       36th Edition. Effective 1 January 1995
                      5*fe
                 uy -*•*
                    RADIOACTIVE
    •JSZ&&







    . .J^NJ"

-------
    »J
  IATA
Identification







A













D

D


D










A
A











H






. — j 	 • 	
1
1
i
UN 1 Proper Shipping
or 1 Name/Description
ml
i
NO.
-A - .. B
3 143 1 Dye. *olld. toilc. n.o.s. • t
1
1
1
Dynamite, see Explosive, blasting, type A t (UN 0081)
Electric SQUIDS, see Igniters t (UN 0325. UN 0454)
Electric storage batteries, see Batteries, etc. t
(UN 2794. etc.)
(Electrolyte (acid) tor batteries, t see Battery fluid,
acid (UN 2796)
(Electrolyte (alkali) tor batteries, t see Battery fluid,
(alkali (UN 2797)
Electron tubes containing mercury, see Mercury
contained In manufactured articles (UN 2809)
3257 Elevated temperature liquid, n.o.s..
I at or above 100'C and below its flash point
3256 [Elevated temperature liquid, flammable, n.o.s..
I with Hash point above 60.5'C, at or above its flash
loom!
3258 1 Elevated temperature solid, n.o.s..
I at or aoove 240*C
Enamel, see Paint (UN 1263)
3166 Engines, Internal combustion
I(LPG powered) including where fitted in machinery
lor vehicles
3166JEnglnes. internal combustion
1 (other than LPG powered) including where fitted in
(machinery of vehicles
Engines, rocket, see Rocket motors, etc. t
(UN 0250. UN 0280. UN 0395. etc.)
960 Engine starting fluid.
with fiammaDie gas
082 Environmental^ hazardous substance, liquid, n.o.s. •

558 Epibromohydrln
023 1 Eplchlorohydrin

U.2 EoonyDutane. see 1.2-Butylene oxide, stabilized
(UN 3022)
lEpoxyctnane. see Ethyiene oxide, etc. (UN 1040)
752 1 1 .2-Epoxy-3-ethoxyprop«ne

2.3-Epoxy-t-bropanal. see Glycldaldehyde (UN 2622)
|2.3-Epoxyoropyl ethyl ether, see 1.2-Epoxy-
|3-ethoxypropane (UN 2752)
3272 Esters, n.o.s. •
I
I

035 1 Ethane, compressed
961 (Ethane, refrigerated liquid
|Ethanethiol. see Ethyl mercaptan (UN 2363)




Clas
or
Dm
sron
C
6.1













9

3


g


9


9


2.1

9
9
6.1
6.1




3




3



2.1
2.1





Subs
diary
Risk

D















































-.






Hazard
Label(s)

E .
Poison
Poison
Poison
Poison
Poison


















Miscellaneous


Miscellaneous


Flammable gas

Miscellaneous
Miscellaneous

Poison
Poison



Flammable liquid
Flammable liquid



Flammable liquid
Flammable liquid
Flammable liquid
Flammable liquid
Flammable gas


PASSENGER
AIRCRAFT


Pkg
Instr.

G
606
613
V6T3
619
Y6J9
Max
Net
Oty/
Pkge
H
5 "g
25kg
1*9
100kg
10kg
Forbidden









Fort










idden

Forbidden




Forbidden




Forbidden




900 and 901
No Limit
!
Forbidden


Forbidden

914
911

No Limit
No Limit
Forbidden
609
Y609



309
V309



305
Y30S
309
V309
5L
1 L



60 L
rot



5L
t L
60 L
10 L
Forbidden
Forbidden

CARGO
AIRCRAFT
ONLY

Pkg
Instr

I
607
615

619

Max
Net
Oty/
Pkge
! J
50kg
100kg

200kg

Forbidden









Fort










>idden

Forbidden




Forbidden




900 and 901
No Limit
1
900 and 901
No Limit
Forbidden

200

914
911

150kg



Forbidden
611 •




310




07

10

200
60 L




220 L




60 L

220 L

150kg
Forbidden



Special
Provi-
sions
see
Subsect.
4.4
K
A3
AS





















A67
A70
A87
A67
A70
A87


A1

A97












A3



At


                                                                                                      D
                                                                                                      E
FOR EXPLANATION OF ABBREVIATIONS AND REFERENCE MARKS. SEE APPENDIX B.
            141

-------
    I AT A
                                                                                  Identification




UN
or
»f\
ID
NO
„
3019



2786





2471
8027
8035


8036


3139



3098





3099





1479




308S





3137
3087





3100
3121





Proper Shipping
Name/Description


Organotln pesticide, liquid, toxic, flammable •
flash point 23*C or more



Organotln pesticide, •olid, toxic •
•


Ortnophosphoric acid, see Phosphoric acid (UN 1805)
Osmic acid anhydride, see Osmium tetroxlde (UN 2471)
Osmium tetroxlde
Other reaulated substance t
Other regulated substance.
aromatic extract or flavouring, not falling under
me definitions of Classes 1 - 8. liquid t
Other regulated substance.
aromatic extract or flavouring, not falling under
tne definitions of Classes 1 - 8. solid t
Oxidizing liquid, n.o.s. •



Oxidizing liquid, corrosive, n.o.s. •





)xldlzlng liquid, toxic, n.o.s. •





Oxidizing solid, n.o.s. •




Oxidizing solid, corrosive, n.o.s. *





Oxidizing solid, flammable, n.o.s. •
Oxidizing solid, toxic, n.o.s. •





Kldlzlng solid, self-hestlng, n.o.s. •
xldlzlng solid, water-reactive, n.o.s. •
xirane. see Ethylene oxide, etc. (UN 1040)




Class
or
Divi-
sion
C
6.1



6.1





6.1
9
9


9


5.1



5.1





5.1





5.1




5.1





5.1
5.1





5.1
s"i





Subsi
diary
Risk

D
3





















8





61










8





4.1
6.1





4.2
4.3





Hazard
Label(s)

E
Poison
& Flammable liquid
Poison
& Flammable liquid
Poison
& Flammable liquid
Poison
Poison
Poison
Poison
Poison .


Poison
Miscellaneous
Miscellaneous


Miscellaneous


Oxidizer
Oxidizer
Oxidizer
Oxidizer
Oxidizer
& Corrosive
Oxidizer
& Corrosive
Oxidizer
& Corrosive
Oxidizer
& Poison
Oxidizer
& Poison
Oxidizer
& Poison
Oxidizer
Oxidizer
Oxidizer
Oxidizer
Oxidizer
Oxidizer
& Corrosive
Oxidizer
& Corrosive
Oxidizer
& Corrosive

Oxidizer
& Poison
Oxidizer
& Poison
Oxidizer
& Poison







PG

F
1
II
II
II
II
1
II
II
II
II


1







II
II
III
II
I

II
II
II
II
1

1
1
II
II
1
1
1
II
II
I

1
1
1
1



1
1
1
1



PASSENGER
AIRCRAFT


Pkg
Instr.

G
603
609
Y609
611
Y611
606
613
Y6i3
619
YB19


606
906
906


906


503
YS03
514
YS14
fort

501
Y50J
514
V574
Max
Net
Oty/
Pkge
H
5L
» L
60L
2L
5kg
25kg
'»<7
100kg
10kg


5kg
No Unit
100 L


tOO kg


1 L
0.5 t
2.5 L
1L
idden

1 L
0.5 L
2.5 L
1 L
Forbidden

501
V50)
514
Y5H
509
508
YS08
516
YS16
508

508
Y508
516
Y516

1 L
0.5 L
2.5 L
J L
'*8
5kg
2.5 Kg
25 kg
JO Kg
1*8

5kg
2.5*0
25kg
5kg
Forbidden
508

508
Y50B
516
Y5I6
1*9

Skg
»
-------
                 Dangerous Goods^ Regulations
        0.5 gram of lithium or lithium alloy or if a solid cathode
        battery contains more than 1 gram of lithium or lithium alloy,
        it must not contain a liquid or gas which is considered
        dangerous unless the liquid or gas. if free, would be
        completely absorbed or neutralized by other  materials in
        the battery.
        Lithium cells and lithium batteries are also regarded as not
        subject to tbese  Regulations if they  meet  the following
        requirements:
        A45(7)  each cell contains not more  than  5 grams of
        lithium or lithium alloy;
        A45(6)  each battery contains not more than 25 grams of
        lithium or lithium alloy;
        A45(9)  each cell or battery is the type proved to be non-
        dangerous by testing in accordance with the United Nations
        Recommendations on the Transport of Dangerous Goods,
        Tests and Criteria (UN Document ST/ST/AC.W/11). Such
        testing must be carried out on each type prior  to the initial
        transport of the type; and
        A45(10)  cells and batteries are designed  or packed in
        such a way as to  prevent short circuits under the normal
        conditions of transport.
    A  A46  Mixtures of  solids  which are not  subject to  these
        Regulations and flammable liquids may be  transported
        under  this entry without  first applying the classification
        criteria of Division 4.1, providing there  is no free  liquid
        visible at the time the substance is packaged and the pack-
        aging is leak-proof.
    &  A47  Genetically  modified  micro-organisms  which are
        infectious must be transported as UN 2814 or UN 2900.
**45    A4B  Packaging tests are not considered necessary,.
 tO     A49  Other inert material or inert material mixture may be
        used at the discretion  of the appropriate authority of the
        State of  origin, provided this inert material  has identical
        phlegmatizing properties.
        A50  Mixtures of  solids  which  are not subject to these
        Regulations  and poisonous liquids may be transported
        under this entry without first applying the  classification
        criteria of Division  6.1, providing there is no free liquid
        visible at the time the substance is packaged and the pack-
        aging is leak-proof. This entry must not be used lor solids
        containing a Packing Group I liquid.
        A51  Carbon,  activated (UN 1362) and Carbon, animal or
        vegetable origin (non-activated) (UN 1361) in  powdered,
        granulated or lump form,  are not subject to these Regula-
       tions when:
       A51 (a)  in the case of lumps, the carbon has been cooled
       for 4 or more days since manufacture; or
       A51 (b)   in the case of powdered carbon or of granulated
       carbon in a granule size less than 8 mm. the carbon has
       been cooled for 8  or more days since manufacture either
       by being air-cooled in thin layers or by a process ensuring
       an equivalent degree of cooling; or
       A51 (c)  in the case of carbons made by processes which
       reduce the flammable  volatile material,  they  cannot be
       ignited by a match and they meet the requirements of the
       following self-heating test:
         SELF-HEATING TEST FOR CARBON
         Apparatus
         (1)  Oven:  A laboratory  oven fitted with internal air
         circulation   and  capable of  being  controlled  at
         140CC±2°C.
       (2)  Wire mesh cube: Construct an open top cube,
       100mm  side, from  phosphor-bronze gauze 18.000
       mesh per square centimetre (350x350 mesh). Insert it
       inside a slightly larger, well-fitting cube, made of phos-
       phor-bronze  gauze 11 mesh per square centimetre
       (8x8 mesh). Fit the outer cube with a handle or hooks
       so that it can be suspended from above.
       P)  Temperature measurement:  A suitable system to
       measure and record the temperature of the oven and in
       the centre of the cube. Chromel-alumel thermocouples.
       made from 0.27 millimetre diameter wire, are suitable for
       measuring the temperature range expected.
       Procedure
       Fill the cube with carbon and tap down gently, adding
       carbon until the cube is full. Suspend the sample in the
       centre of the oven  which  has been  preheated to
       1400C±.20C. Insert one thermocouple in the centre of
       the sample and the other between the cube and the
       oven wall.  Maintain the  temperature of  the  oven at
       140°C ±2°C for 12 hours and record the oven temperat-
       ure and the temperature within the sample.
       Results
       (1)  Non-activated carbon,  non-activated  charcoal.
       carbon black, lamp black fail the test if the temperature
       within the sample at any time during the 12 hours
       exceeded 200°C (392°F).
       (2)   Activated carbon, activated charcoal fail the test if
      the temperature within the  sample at any time during the
       12 hours exceeded 400°C (672°F).
 A A52  Mixtures not meeting the criteria for flammable gases
   (Division 2.1) must be transported under UN 3163.
 A A53  This substance is  not subject to these Regulations
   when coated.
 A A54  This substance is not subject to these Regulations
   when in any other form.
 A ASS  Solvent extracted soya bean meal containing 1.5%
   or less oil and 11% or less moisture, which is substantially
   free of  flammable   solvent,  is  not  subject to  these
   Regulations.
 A A56  This entry applies to articles which may be classified
   in Class 1 in accordance with 3.1.1 which are life-saving
   vehicle  air  bags or  seat-belts,  when  transported  as
   component parts and when packaged as for transport have
   been tested  in accordance with the External Fire (Bonfire)
   Test. Test series 6(c) of Part I  of the UN Recommendations
   on the Transport of Dangerous Goods. Tests and Criteria,
   with no explosion of the device, no fragmentation of device
   casings, and no projection hazard or thermal effect which
   would significantly hinder fire-fighting or other emergency
   response efforts in the immediate vicinity. These air bags or
   seat-belts when installed in vehicles or in completed vehicle
   components such as steering columns and door panels are
   not subject to these Regulations. The quantities given in
   Columns H and J of 4.2 (List of Dangerous Goods) refer to
   the net mass of the finished article.
   Note:  For the carriage  of a sell-propelled vehicle, see
   Packing Instruction 901.
   A57 Receptacles must be so constructed that explosion
   is not possible  by an  increase of internal pressure: other-
   wise, except for UN 2555. the substance must be classified
   as Class 1.
.•'. A58 An aqueous solution containing 24% or less alcohol
   by volume is not subject to these Regulations.
   A59 A tire assembly unserviceable or damaged is  not
       250

-------
                       TAT^F  Dangerous Goods Regulations
               A86
                to
              A108
2

j
u
3
 solids when tested in accordance with 3.4.2.2(b)(") (chips,
 if necessary, crushed and sieved to a particle size of less
 than 1.25mm).
 A87  The "Miscellaneous Dangerous Goods" label is not
 required when the article is not fully enclosed by pack-
 aging, crates or other means that prevent the ready identi-
•• fication of the article.
 ABB  Zirconium wire, sheets and strip, dry 254 microns or
 thicker,  are not subject to these  Regulations for air
 transport.
 A89  In determining the ammonium nitrate  content, all
 nitrate ions for which a molecular equivalent of ammonium
 ions is present in the mixture shall be calculated as ammo-
 nium nitrate.
 A90  Ammonium nitrate fertilizers of this composition and
 within these limits are not subject to these Regulations H
 shown by a trough test not to be liable to self-sustaining
 decomposition  and  providing they  do not  contain an
 excess of nitrate greater than 10% by mass (calculated as
 potassium nitrate). See Tests and Criteria. Part IV of the UN
 Recommendations on the Transport of Dangerous Goods
 (UN Document ST/SG/AC.10/11) for trough tests.

 A91  A  nitrocellulose solution containing not more than
 20% nitrocellulose may  be transported under the require-
 ments for "Paint". UN 1263 or UN 3066, or "Printing Ink",
 UN 1210, as appropriate.

 A92  Lead compounds which, when mixed  in a ratio of
 1:1000 with 0.07 M (molar) hydrochloric acid and stirred for
 one hour at a temperature of 23°C ± 2°C. exhibit a solubility
 of   5%  or  less  are  considered   insoluble  (see  ISO
 3711:1990).

 A93 A heat-producing article is not subject to these Regu-
 lations when the heat-producing component or the energy
 source is removed to prevent unintentional functioning
 during transport.

 A94 Not used.

 A95 This entry is not to be used for Polychlorinated
 biphenyls(UN2315).

 A96 Only  formulations which,  in  laboratory  testing,
 neither detonate in the cav'rtated state or deflagrate, which
 show no effect when heated under confinement and which
 exhibit no explosive power may be transported under this
 entry. The  formulation must be thermally stable,  i.e. the
 SADT is 60°C or higher for a 50 kilogram package. Formula-
 tions not meeting these criteria must be transported under
 the appropriate provisions of Division 5.2.

 A97 The assignment of substances to this entry is to be
 cteririRfl hv thR annrnnriate national authority

 A98  Radioactive material in an excepted package which
 also meets the criteria for another class/division must be
 classified, packed, marked, labelled and documented in
 accordance with the provisions relating to the other class/
 division. The Shipper's Declaration must also contain the
 information required by 6.7.3. In such cases, this informa-
 tion need not be shown on the air waybill.

 A99  Subsidiary risk label not required if the toxicity arises
 solely from the destructive effect on tissue.
 D  A100  Gasoline, motor spirit and petrol must De assignee
    to this entry regardless of variation tn volatility.
 D  A101  This substance may be carried under provisions
    other than those of Class 1 only if it'is so packed that the
    percentage  of water will not fall below that  stated  at any
    time during transport. When phlegmatired with water and
    inorganic inert material the content of urea nitrate may not
   "exceed 75% by mass and the mixture must not be capable
    of being detonated by Test 1(a)(i) or Test i(a)(ii) in the UN
    Recommendations on the Transport of Dangerous Goods.
    Tesfs and Criteria.                                    '
 D  A102  This listing includes aluminium ashes, aluminium
    dross, aluminium  potlining, aluminium skimmings, pot
    skimmings,  spent cathodes,  spent potlmer. and  waste(
    cathodes.
 Q  A103  Not subject to these Regulations if containing less
    than 100 grams flammable, non-toxic,  liquefied gas.
 Q  A104  The  poison subsidiary risk label should not be"
    used.
 D  A105  Sulphur is not subject to these Regulations when it
    is transported in quantities of less than 400 kg per package,
    or when it has been formed to a specific shape, e.g. prills
    granules, pellets, pastilles or flakes.
 D  A106  This entry may only be used for samples of chem
    icals taken for analysis in connection with the implementa-
   tion of the Chemical Weapons Convention.
   They may be transported on a passenger or  cargo aircraft
   providing prior approval has been granted by the appropri^
   ate authority of the State of origin or the Director Genera"
   of the  Organization  for  the  Prohibition   of  ChemiCc
   Weapons. For  instructions on shipping  such  samples
   contact the national competent  authority.
   The substance is assumed to meet the criteria of Packin
   Group I for  Division  6.1.  Subsidiary risk labelling  is nc
   required.
   A copy of the document of approval showing the quantir"
   limitations and the packing requirements must accompan
   the consignment.
   Note:  The transport ot substances under this descriptio^
   must be in accordance with chain of custody and securi
   procedures specified by the Organization for the Prohibitic
   of Chemical Weapons.
n A107  This entry only applies to machinery  or apparati-
   containing dangerous goods as an integral element of tr
   machinery or apparatus. It must not be used for machine..
   or apparatus for which a proper shipping name alreac*'
   exists in 4.2 (List of Dangerous Goods).               p-
[" A108  The provisions of Special Provision A1 apply to tr
   entry for Packing Group I only.
                      252

-------
     Tff Dangerous Goods Regulations
906
PACKIN« INSTRUCTION 906
A
A
A
r
or








OPERATOR VARIATIONS: BA-01 . CI-01 . SK-03. SW-01 . TW-09
The General Packing Requirements of Subsection 5.0.2 must also be met.
For ID 8027 UN specification packaging is not required.
For ID 803? and ID 8036 only, the following specification packagings must be used.
Combination and single packagings are permitted.
For ID 8035 liquids:
COMBINATION PACKAGINGS
INNER PACKAGINGS
Desc.
Spec.
Maximum
quantity
Glass. Earthenware
IP1
5.0 1
OUTER PACKAGINGS
Desc.
Spec.
Desc.
Spec.
Steel drum
1A2
Plastic jerrican
3H2


Plastic
IP2
10.0 L


Metal (not aluminium) Alumina
IP3 IP3A
25.0 L 25.0 I

Aluminium drum Plywood drum Fibre drum Pla

1B2
ID 1G
Reconstituted
Wooden box Plywood box wood box Fibre

4C1 4C2
4D 4F

im Glass ampoule
IP8
0.5 L

istic drum Steel jerrican
1H2 3A2
Jboard box Plastic box
4G 4H1 4H2
SINGLE PACKAGINGS
Desc.
Spec.
Steel drum
1A1 1A2
Aluminium drum Plastic drum Steel jerrican Plas

1B1 1B2 1H1 1H2 3A1 3A2 3
For ID 8036 solids:
Composite
packagings
(plastic)
tic jerrican (see 10.2.16)
all (see Table
H1 3H2 5.0.C)

COMBINATION PACKAGINGS
INNER PACKAGINGS
Desc.
Spec.
Maximum
quantity
Glass.
Earthenware
IPt
5.0kg

Plastic Metal
IP2 IP3 IP3A
25.0 kg 25.0 kg
Fibre can or
Plastic bag* box
IPS IP6
25.0 kg 5.0 kg
Paper bag.
lined Plastic film bag
IP10 5H4
25.0 kg 50.0 kg
* A plastic bag inner packaging is forbidden in 4H1 expanded plastic box outer packaging.
    444

-------
 IATA
Packing
PACKING INSTRUCTION 906 (continued)
COMBINATION PACKAGINGS
OUTER PACKAGINGS
Desc.
Spec.
Desc.
Spec.
Steel drum
1A2
Plastic jerrican
3H2

Aluminium drum
1B2
Wooden box
4C1 4C2

Plywood drum
1D
Plywood box
40

Fibre drum
1G
Reconstituted
wood box
4F
Plastic drum
1H2
Fibreboard box
4G
Steel jerrican
3A2
Plastic box
4H1 4H2
SINGLE PACKAGINGS
Oesc.
Spec.
Alum
Steel drum da
1A1 1A2 1B1
Plywood
drum (with
nium inner plastic
tm liner)
182 10
Fibre drum
(with inner
plastic liner)
1G
Plastic
drum
1H1
1H2
Steel
jerrican
3A1 3A2
Plastic Plasti
jerrican be
3H1 3H2 5h
Composite
packagmgs
c film (plastic)
ig (see 10.2.16)
all (see Table
14 5.0.C)
Note: For ID 8035 and ID 8036, the words "Aromatic Extract' or •Aromatic Flavouring' must be added immediately
adjacent to the name "Other Regulated Substance' on the package.
                                                                                906
                                                                         445

-------
           Dangerous Goods Regulatiq/is
     PACKING INSTRUCTION 911
911
®
A
A






OPERATOR VARIATIONS: CI-01. FM-06, SK-03, SW-01. TW-09
The General Packing Requirements of Subsection 5.0.2 must also be met.
Combination and single packagings are permitted.
COMBINATION PACKAGINGS
INNER PACKAGINGS
Oesc.
Spec.
Maximum
quantity
Glass.
Earthenware
IP1
5.0kg

Plastic
IP2
10.0
kg

Metal
IP3 IP3A
10.0 kg
* A plastic bag inner packaging is forbidden
OUTER PACKAGINGS
Oesc.
Spec.
Desc.
Spec.
Steel drum
1A2
Plastic jerrican
3H2

Aluminium drum
1B2
Wooden box

4C1
4C2

Paper bag
IP4
5.0kg
in4H1
Fibre can or
Plastic bag* box
IPS
5.0kg
IP6
5.0kg

Glass Paper bag,
ampoule lined
IP8 IP 10
0.5 kg 5.0 kg
expanded plastic box outer packaging.

Plywood drum
ID
Plywood box
4D
Fibre drum Plastic
1G
11-
Reconstituted
wood box FibrebOi
4F
4C

drum Steel jerrican
12 3A2
3rd box Plastic box
3 4H1 4H2
SINGLE PACKAGINGS
Desc
Spec.
Desc.
Steel drum
1A1 1A2
Aluminium drum

Plastic jerrican
Spec. 3H1 3H2
1B1
1B2
Plywood drum
(with inner plastic
liner)
1D
Woven plastic bag
5H2 5H3
Fibre drum (with
inner plastic liner) Plastic
1G
Plastic film bag
5H4
1H1
Paper bag
5M2
drum Steel jerrican
1H2 3A1 3A2
Composite packagings
(plastic) (see 10.2.16)
all (see Table 5.0.C)
    452

-------
        _
      IATA  Dangerous Goods Reg/ulations
     PACKING INSTRUCTION 914
©
A
A




OPERATOR VARIATIONS: CI-01. FM-06. SK-03. SW-01. TW-09
The General Packing Requirements of Subsection 5.0.2 must also be met.
Combination and single packagings are permitted.
COMBINATION PACKAGINGS
INNER PACKAGINGS
Desc.
Spec.
Maximum
quantity
Glass,
Earthenware Plastic Metal
IP1 IP2 IP3 IP3A
5.0 L 5.0 L 10.0 L
Glass
ampoule
IPS
0.5 L
OUTER PACKAGINGS
Oesc.
Spec.
Oesc.
Spec.
Steel drum Aluminium drum
1A2 1B2
Plastic jerrican Wooden box .
3H2 4C1 4C2
Plywood drum Fibre drurr
ID 1G
Reconstitute
Plywood box wood box
4D 4F
SINGLE PACKAGINGS
Desc.
Spec.
Aluminium
Steel drum drum Plastic drum Steel jerrican Plastit
1A1 1B1 1H1 3A1 3



) . Plastic drum Steel jerrican
1H2 3A2
•d
Rbreboard box Plastic box
4G 4H1 4H2

Composite
packagings
(plastic)
: jerrican (see 10.2.16) Cylinders
As permitted in
all (see Table Packing
IH1 5.0.C) Instruction 200
914
    454

-------