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
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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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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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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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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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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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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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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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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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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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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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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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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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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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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;
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• 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-
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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.
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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
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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
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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.
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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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
APPENDIX A
Abridged Sampling Plan
-------
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
-------
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
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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
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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
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_
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
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