ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
COMPLIANCE MONITORING PROCEDURES
NATIONAL FIELD INVESTIGATIONS CENTER-DENVER
DENVER, COLORADO
JULY 1974
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ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
COMPLIANCE MONITORING PROCEDURES
NATIONAL FIELD INVESTIGATIONS CENTER-DENVER
DENVER, COLORADO
JULY 1974
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TABLE OF CONTENTS
Page
COMPLIANCE MONITORING PROCEDURES 1
COMPLIANCE MONITORING CHECKLIST , 4
PLANT EVALUATION AND FIELD SURVEY PROCEDURES 11
PLANT EVALUATION FORMS 15
INDUSTRIAL 15
MUNICIPAL 19
CHECKLIST FOR FLOW MEASUREMENT EQUIPMENT
INSTALLED BY EPA 22
CHECKLIST FOR EXISTING FLOW MEASUREMENT DEVICES 23
CHECKLIST FOR FIELD INSTRUMENTS 25
CHECKLIST FOR INSTALLATION OF AUTOMATIC SAMPLER 26
ANALYTICAL QUALITY CONTROL CHECKLIST 28
CHAIN OF CUSTODY PROCEDURES 29
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COMPLIANCE MONITORING PROCEDURES
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July 5, 1974
NATIONAL FIELD INVESTIGATIONS CENTER - DENVER
COMPLIANCE MONITORING PROCEDURES
Verification Monitoring is required to document the effectiveness of
self monitoring and reporting activities of permittees and to provide
sufficient documentation and verification of NPDES permit conditions and
related requirements to justify the issuance of section 309 regulatory
orders or other enforcement actions. Verification monitoring, then, will
be performed in sufficient detail to acquire primary evidence to satisfy
case preparation requirements.
National Field Investigations Center procedures, as outlined below,
are consistent with, and meet the objectives of, the overall EPA compliance
monitoring strategy. Major emphasis will be placed upon specific permit
parameters (effluent limitations, compliance schedules, etc.) although
additional surveillance may be required to demonstrate water quality
standards violations, the discharge of toxic substances, etc.
To provide the basis for design of the sampling program at each location,
a variety of background information will be obtained, compiled and evaluated
prior to on-site visits. This will normally be accomplished in two steps.
The General Point Source File (GPSF) and auxiliary computerized data bases
will be searched and all available application data, permit requirements
(effluent limitations, monitoring requirements, compliance schedules), and
self-monitoring data will be retrieved. A visit will then be made to the
Regional and/or State office, as appropriate, to review permit files and
collect additional information, as necessary, to provide the most current
data available on production, pollution controls and compliance with permit
requirements. The self-monitoring reports will be screened for permit
violations, manually at first and, optionally by computer after GPSF
becomes fully functional. As a general rule, the Regional office should
provide the permittee with reasonable notice of a time period within which
Inspections and sampling will be conducted. It will be more meaningful,
however, to schedule "unannounced" visits for the actual verification and
sampling.
Facility inspections and sampling are designed to be consistent with
the overall compliance monitoring objectives. In-plant evaluations will be
conducted prior to, or concurrent with, the sampling program. In-plant
evaluations will be made by personnel most knowledgeable of the particular
waste source and the processes employed. Industrial dischargers will be
subjected to process evaluations to verify that the processes, raw materials,
amount of product produced, water usage, waste treatment processes and
other similar factors relative to concentrations and loads of pollutants
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Compliance Monitoring Procedures (Continued) :
contained in the discharges are as described in the permit application and
the issued permit. In the case of municipal dischargers, 0 & M procedures,
wastewater quantity and quality, raw waste load, type of industrial waste
input, pretreatment regulations and compliance, etc. will be evaluated.
Monitoring of the influent to a municipal facility may also be required
where the permit is controlled by the percentage-removal provisions of
the secondary treatment regulations. Process verification also includes
determining that solids, sludge, filter backwash and other pollutants
removed from wastewater are not entering navigable waters.
Effluent monitoring will be conducted for the parameters and within the
time frames as specified in the NPDES permit. Generally, three or more
operating day composite samples with calculated loads and concentrations
will be considered the minimum to acquire representative and technically
defensible data to verify wastewater characteristics and provide the basis
for prosecution, if necessary.
In cases "where effluent limitations are prescribed in the permit which are
more stringent than published effluent guidelines because of water quality
standards, limited stream surveys may also be conducted. Stream surveys
may also be required where toxic or deleterious substances are suspected
of being discharged. Stream surveying may be necessary to demonstrate
irreparable harm for anticipated court action where known toxic pollutants
or deleterious materials are discharged.
Sampling will be accomplished using automatic samplers, whenever possible.
Appropriate security measures will be taken to insure the integrity of
the sampling device and collected samples. NFIC - Denver published chain-
of-custody procedures will be followed at all times.
Flow measuring devices used by the permittee will be checked for accuracy
and, where necessary, EPA personnel will install independent flow measuring
equipment for use during the monitoring period.
At facilities discharging deleterious substances, biological monitoring
may be required to determine compliance with permit conditions or demonstrate
the need for control of additional pollutant parameters. Such monitoring
would consist of bioassays, fish survival studies, or other biological
tests to determine the suitability of discharge of the effluent to receiving
waters. Biological monitoring may also be considered when it is determined
or suspected that the receiving waterway is water quality limited.
Water samples will be collected that are representative of the waste effluent.
When possible, samples will be preserved and analyzed at the NFIC - Denver
central laboratory under closely controlled conditions. Samples which require
immediate analysis, will be run on-site at a mobile field laboratory. In
all cases, there will be strict adherence to recommended maximum holding times.
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Compliance Monitoring Procedures (Continued)
Standardized procedures have been instituted by the Center for insuring
sample integrity during collection, transportation, storage, and analysis.
These procedures, as well as documented chain-of-custody procedures, protect
against mis-identification, loss or error of data relating to sampling,
theft, loss, damage, or alteration of the sample.
Physical and chemical analysis for determining compliance with effluent
limitations will be performed by the use of acceptable analytical methods
as set forth in the Federal Register pursuant to section 304(g) of the
Federal Water Pollution Control Act Amendments of 1972. For analysis of
components whose test procedures have not yet been promulgated or defined
in the permit, defensible professional judgment will be exercised in selec-
tion of suitable test procedures.
In order to demonstrate that the analytical laboratory can perform a test
in a correct and reproducible manner, the laboratory will analyze a suit-
able number of replicate and standard spiked samples to demonstrate that
the test can be performed within the published precision and accuracy
range. Laboratory instruments essential to the monitoring program will be
properly maintained and calibrated. Regular, periodic calibration checks
and re-calibrations will be performed on measuring instruments such as
electrometers, volumetric equipment and weighing devices and test solutions.
Wherever possible, the ultimate reference for all calibrations will be
weights, volumetric glassware, thermometers, reagent standards, etc.
bearing certificates of an approved standardization program (e.g., National
Bureau of Standards).
The laboratory has established an analytical quality control program to
demonstrate on a day-to-day basis that the laboratory is producing reliable
Information. Basically, the overall quality control program will utilize
a combination of techniques such as periodic standardization, replicate
sample analysis, standard spiked sample recovery and reference sample
analysis.
Data summaries resulting from each laboratory evaluation will be thoroughly
reviewed and accompanied by a brief report that quantifies the precision
and accuracy of the data reported. This report will also specify any
problems or interference encountered.
A report and checklist covering the findings of the in-plant evaluation,
an interpretation of the monitoring results and recommendations will be
prepared and forwarded to the Regional Office Enforcement Director within
four weeks of survey completion. In cases where gross permit violations
are evident and enforcement action may be required, the Enforcement Director
will be immediately notified. Enforcement Division/NFIC mid-survey dis-
cussions may result in expanding the scope of a survey should it become
evident that immediate enforcement action is necessary.
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COMPLIANCE MONITORING CHECKLIST
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NATIONAL FIELD INVESTIGATIONS CENTER - DENVER
COMPLIANCE MONITORING CHECKLIST
EXACT NAME OF DISCHARGER,
CITY AND STATE
NAME, ADDRESS, AND TELEPHONE NUMBER
OF HIGHEST OFFICIAL OF COMPANY OR
MUNICIPALITY DISCHARGING
RECEIVING WATER:
I. BACKGROUND INFORMATION
A. DISCHARGER IS: MUNICIPALITY,
B. TYPE OF OPERATION*
NPDES PERMIT NO..
STATE PERMIT NO.
; INDUSTRY
.; OTHER (SPECIFY)
C. PRODUCTION: ACTUAL
D. WATER SUPPLY: WELL(S).
E. DISCHARGE IS: CONTINUOUS
PERMIT
SURFACE
OTHER
INTERMITTENT.
ACCIDENTAL SPILL OTHER
F. RECEIVING WATER CLASSIFICATION
G. EFFLUENT LIMITATIONS NOW APPLICABLE: INITIAL
BATCH
INTERIM
FINAL (BPCTA).
*e.g., PRIMARY WWTP SERVING XXX PEOPLE; SUGAR MILL, ETC.
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: CO
II. SUMMARY OF SELF REPORTING DATA
A. EFFLUENT LIMITATIONS VIOLATIONS:
PERMIT CONDITIONS
PARAMETER
FLOW
DAILY AVG.
DAILY MAX,
SELF REPORTING DATA VIOLATIONS
DAILY AVG. DAILY MAX. DATE
MAGNITUDE OF VIOLATIONS:
NUMBER OF VIOLATIONS PER NUMBER OF SAMPLES:
B. COMPLIANCE SCHEDULE VIOLATIONS:
MILESTONE PERMIT DATE
ACTUAL ACHIEVEMENT DATE
C. OTHER PERMIT CONDITIONS VIOLATED:
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III. IN-PLANT EVALUATION
A. DATE OF EVALUATION
B. VERIFICATION OF OPERATION CHANGES
YES NO REMARKS
1. INDUSTRIAL
a. PROCESS
b. RAW MATERIALS
c. AMOUNT OF PRODUCT PRODUCED
d. WATER USAGE
e. WASTE TREATMENT PROCESSES .
f. OTHER
2. MUNICIPAL
a. 0 & M PROCEDURES
b. WASTEWATER QUANTITY
c. WASTEWATER QUALITY
d. INFLUENT WASTE LOAD
e. TYPE AND PERCENTAGE
INDUSTRIAL INPUT
f. PRETREATMENT REGULATIONS
g. OTHER
3. OTHER
4. SOLIDS, SLUDGE, FILTER BACKWASH, AND OTHER POLLUTANTS REMOVED BY
TREATMENT ARE NOT ENTERING NAVIGABLE WATERS
YES NO
:8-
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:' IV. FIELD AND LABORATORY RESULTS
A. DATES OF FIELD SURVEY DATES OF ANALYSES
B. FLOW MEASURED BY: COMPANY DEVICE, TYPE PRECISION,
EPA MEASURING DEVICE TYPE \ PRECISION,
QUANTITY
C. FIELD INSTRUMENTS STANDARDIZED
YES NO
D. PROPER PRESERVATION AND SAMPLE HOLDING TIMES ADHERED TO
YES NO
E. PROMULGATED GUIDELINES ESTABLISHING TEST PROCEDURES FOR ANALYZING OF POLLUTANTS FOLLOWED
YES NO
F. ANALYTICAL QUALITY CONTROL PROCEDURES FOLLOWED
YES NO
G. CHAIN OF CUSTODY PROCEDURES FOLLOWED
YES NO
H. ADEQUACY OF SAMPLING LOCATION:
I. BIOLOGICAL MONITORING RESULTS:
J. WATER QUALITY STANDARDS VIOLATIONS:
STREAM FLOW SOURCE OF INFORMATION
WQ STANDARDS SURVEY DATA VIOLATIONS DATE
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v/> IV. FIELD AND LABORATORY RESULTS (CONTINUED)
Ox
ru
PERMIT CONDITIONS
PARAMETER
K. EFFLUENT LIMITATIONS VIOLATIONS:
DAILY AVG.DAILY MAX.
SURVEY DATA VIOLATIONS
DAILY AVG.
DAILY MAX.
DATE
MAGNITUDE OF VIOLATIONS:
NUMBER OF VIOLATIONS PER NUMBER OF SAMPLES:
CD
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V. PRECISION AND ACCURACY OF AVAILABLE DATA
A. CONSIDERING THE VARIABILITY OF THE TESTING PROCEDURES, IS IT LIKELY
THAT THE VIOLATIONS LISTED ARE: REAL APPARENT
REMARKS:
B. IF ADDITIONAL DATA REQUIRED, EXPLAIN NATURE OF DATA, ETC.
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VI. VIOLATIONS
A. FEDERAL WATER POLLUTION CONTROL ACT AMENDMENTS OF 1972:
1. FAILURE TO FILE FOR NPDES PERMIT
2. SECTION 301 EFFLUENT LIMITATION OR
COMPLIANCE SCHEDULE
3. SECTION 302 WATER QUALITY LIMITED EFFLUENT LIMITATION OR
COMPLIANCE SCHEDULE_
4. SECTION 306 STANDARD OF PERFORMANCE
5. SECTION 307(a) TOXIC POLLUTANT STANDARD,
6. SECTION 307(b) PRETREATMENT STANDARD
7. SECTION 308 INSPECTIONS, MONITORING AND ENTRY_
8. OTHER:
B. REFUSE ACT:
CHECKLIST CERTIFIED BY: DATE
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PLANT EVALUATION AND FIELD SURVEY PROCEDURES
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PLANT EVALUATION AND FIELD SURVEY PROCEDURES
Although each field survey and plant evaluation are different,
there are certain procedures which are connon to all. Assuming that
the problem has been adequately, or at least generally defined, back-
ground information must be evaluated and updated before going into the
field. Background data may consist of:
1. NPDES or RAPP applications and/or permits
2. Previous field surveys conducted fn the area
3. Reports by the industries and industrial listings
4. Literature reviews
5. Legal actions in the area
6. Climatology
7. Historical stream flows of major waterways
8. Applicable water quality and air quality standards
Appropriate Federal, state, and municipal officials should be
contacted to discuss the objectives of the survey. Records may be
available from these officials which can be used for background
Information.
A reconnaissance trip is next in the plan of action. Waste
sources must be investigated to validate the background information.
Prior to making the trip, all companies should be contacted and appoint-
ments established. Once the schedule is firm, state authorities should
be notified as they may want to be present during the interviews. It
1s important to allow sufficient time during the plant inspections so
that all information is obtained on one visit. Large industrial
I
8 S - c» <3 8
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Plant Evaluation and Field Survey Procedures (Continued)
complexes may require, several days while smaller companies may only
take several hours. Knowing exactly what the purpose of the survey is
and the role each industry plays will provide the basis of the interview
and evaluation. An interview form should Be prepared before the actual
inspection and may include the following:
1. Company name, location, corporate headquarters.
2. Company official, phone, title.
3. Description of production process, rates (average and
maximum), hours of operation, cleanup schedule, number
of employees.
4. Waste treatment practices, efficiencies of equipment,
waste loads or emissions.
5. Number and location of all outfalls including discharges
to city sewers.
6. Establish sampling locations and how flows will be
measured (this is very important).
7. Water supplies, quantities, sources, flow measurements.
8. Air pollution control equipment wastewater flows.
9. Solid waste disposal.
10. Anticipated changes or expansion.
11. Blueprints or drawings of plant layout.
12. Design specs on pollution control equipment.
13. Operational problems.
14. OSHA regulations which apply to field crews.
13 S - 6 2 8
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13
Plant Evaluation and Field Survey Procedures (Continued)
15. Wtll the company want to split samples.
16. Water quality standards and classification of receiving
waters (f.e., where water quality limiting).
Additional information required while on the reconnaissance include:
1. Sufficient area maps for field crews.
2. Establish locations for mobile laboratories.
3. Accommodations for field personnel.
4. Airline freight schedules.
5. Locations of state, city and Federal offices and the
contacts within each office.
6. Supply of ice for preservation.
7. Location of hospitals.
8. Set of area telephone books.
The background information and field reconnaissance data are
then used to set up the actual survey. All waste sources should be
located on a map and the dates established when they will be investi-
gated. Logistics should be worked out to reduce travel time. After
the dates are established, all companies should be notified and permission
to sample obtained in writing when applicable.
All waste sources should be assigned a sample location number with
all analyses listed (i.e., those for which effluent limitations have
been established and others as required, e.g., toxic substances). The
daily analytical load will be determined on the basis of laboratory
capability. Where there is a water quality limiting situation, the
receiving waters will be monitored to determine compliance or non-compliance
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14
Plant Evaluation and Field Survey Procedures (Continued)
with applicable water quality standards.
Equipment and manpower requirement will be determined and included
as part of the study plan. The plan will be revised as necessary.
A briefing of all personnel involved will be held prior to the
survey.
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PLANT EVALUATION FORMS
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INDUSTRIAL PLANT EVALUATION FORM
GENERAL
Company: Date Visited:
Location: . EPA Personnel
Contact:
Title: Phone No.
Main Office:
Raw Materials Used:
Finished Products & Current Production Rates: (Flow Diagram)
Rated Plant Capacity:
Previous Studies:
OPERATIONS
No. of Days/Week No. of Hrs/Day_
No. of Production Employees
Date Plant Began Operating_
Current Operating Permits & Applications Filed:
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Plant Evaluation Form (Continued)
HATER SUPPLY & USES
Source (s): ' ' : :; • : : : ' ' : ' ;
Treatment:
Use(s) & Quantity Used:
Analysis:
WASTE SOURCES & TREATMENT
A. Domestic Waste - Quantity:
Type of Treatment:
Receiving Water:
Analysis:
B. Process Waste(s)
Source & Quantity:
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Plant Evaluation Form (Continued)
Treatment (flow diagram)
Receiving Waters (State classification and uses).
Analysis of Effluent
FUTURE PLANS (Expansion, modification of process, water reuse, by-product recovery, etc)
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Plant Evaluation Form (Continued)
FIELD NOTES & OBSERVATIONS:
By (Signature)
Date
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MUNICIPAL PLANT EVALUATION FORM
GENERAL
Name of Facility_
Location _ EPA Personnel
Contact
City Official
Type of Treatment;Units Employed (Flow Diagram)
Industrial Waste Contribution (Percentage, Types,Pre-treatment ordinance, etc.)
Flow Devices Utilized
Design Capacity(Ave. & Max) Flow_
Wasteload (BOD, Solids, etc.)
Present Conditions (Max, Min, Ave.) - Flow Wasteload (BOD, Solids, etc)
Inf1uent
Effluent
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Wet Weather Flow vs Dry Weather Flow
Lift Stations (No., By-Pass, Auxiliary Power Unit, etc.)
RECEIVING WATER
Name
Classification & Use
OPERATIONS
No. of Plant Operators
Certification Held by Operators_
No. of Hours and Days Operators on Duty_
Current Operation Permits and Effluent Limitations
Laboratory Provided
Type of Analyses Performed
Type of Samples Collected (Grab, Composite)
Summary of Historical & Present Data
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Wastewater Reuse
Future Plans (Expansion, Modifications, Etc.)
Field Notes & Observations (Problem w/sampling, etc.)
(Signature;
Date
66 S- dO*
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CHECKLIST FOR FLOW MEASUREMENT EQUIPMENT
INSTALLED BY EPA
88 S-cc!
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CHECKLIST FOR FLOW MEASUREMENT EQUIPMENT INSTALLED BY EPA
Name of Industry or Municipal tty_
Date of Installation
Permit Discharge No.
Date of Removal
Type Samples to be Collected_
Grab;
_Flow Weighted Composite
Type of Wastes:
Type of Discharge:
Batch
Continuous,
Selection of Flow Measuring Site:
Description of Discharge Channel
_Hrs/Batch,_
Hrs/Day
_Time Weighted Composite
Number/Day.
Depth of Flow in Channel
Velocity of Flow in Channel
Range of Flow Expected
Type of Device Installed_
Discharge Capacity of Device_
Type of Recording Device Installed
Relation Between Recording Device and Measuring Device_
.(Ft)
(FPS)
_(mgd)
_(mgd)
Date
By_
_(Signature)
JSite location and flow measurement device can be selected based on criteria set forth
In Water Measurement Manual, U. S. Dept. of Interior, Bureau of Reclamation, Denver,
Colorado 1967 and Handbook For Monitoring Industrial Wastewater, Technology Transfer,
U.S. EPA August 1973.
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CHECKLIST FOR EXISTING FLOW MEASUREMENT DEVICES
H
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CHECKLIST FOR EXISTING FLOW MEASUREMENT DEVICES1
Name of Industry or Municipality_
Name of Contact
Date:
Permit Discharge Number:_
Type of Wastes:
Type of Discharge: Batch_
Continuous
2Type of Measurement Device:_
Dimensions (e.g., Length of Weir)_
Hrs/Batch,
_Hrs/Day
23
Number/Day
Capacity of Device
_(Max-Min mgd)
Range of Flows (From Self-Monitoring Record)
3»'*Is Device Properly Installed Yes;
If no, specify reasons installation is not correct:
No.
When was device last calibrated by company: __
Type of Stage Recording Device (manufacturer, model, etc.).
Relation Between Recording Device and Measuring Device
Is Recorder Device Properly Installed:
Yes;
If no, specify reasons installation is not correct:
No
r c) £ 8
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Checklist for Existing Flow Measurement Devices (Continued)
Is Recording Device Functioning Properly: Yes; No
If no, specify reasons for malfunctions: •••••-•••• ' '-'.'.'.'.
temarks
i
l
By (Signature)
evice installed by discharger.
•Examples: 60° V-notch, Parshall Flume, rectangular wier, Cipolletti weir, etc.
3Information recorded depends on type of measurement device. The accuracy and
tdequacy of the device will be ascertained using the criteria set forth in
he Water Measurement Manual, U. S. Department of the Interior, Bureau of
Reclamation, Denver, Colorado 1967, and the Handbook for Monitoring Industrial
fJastewater, Technology Transfer, U.S. EPA. August 1973.
check of the device will be made to determine if, for example, it is level, is
it at a suitable location, is there leakage, is there free or submerged flow, etc.
("he reference cited in Footnote #3 contains a list of points to be considered
len installing flow measurement devices.
8 8 S - 0
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CHECKLIST FOR FIELD INSTRUMENTS
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25
CHECKLIST FOR FIELD INSTRUMENTS
Date: Tttte By;
Conductivity Meter: Model ' ' ': ' '_'
Identification No.
Probe '' • ':::;: '':; '''' ; Battery_
Remarks
pH Meter: Model
Identification No.
Calibration (Reference) pH 4.0 pH 7.0_ , pH 9.0_
Recorder
1 Remarks
Thermometer (check against National Bureau of Standards thermometer)_
Date By - ' (Signature)
1Indicate if instrument is working properly. If not, what changes were necessary.
I
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CHECKLIST FOR INSTALLATION OF AUTOMATIC SAMPLER
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CHECKLIST FOR INSTALLATION OF AUTOMATIC SAMPLER
Name of Industry or Municipality
Name of Contact
Date of Installation
Time Sampling Commenced Time Sampling Ended
Date of Removal
Number of Sampler Permit Discharge No._
Sampler Location (Describe)__
Nearest Power Available
Nearest Cleanup Facilities Available_
Description of Waste Channel
Type Wastes to be Sampled
2
Position of Sampler Intake
Type of Sample: -. Grab; '. ^Composite (flow weighted)^
Reason Method Selected . (equal volume)_
Time Period Covered
Specify the Compositing Interval (i.e., continuous, 15 min., 1 hr., etc.)
Method of Preservation (e.g., Temperature Control),
Method of Securing Sampler (Maintenance of Chain of Custody)
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27
Checklist for Installation of Automatic Sampler (Continued)
^Periodic Inspection of Sampler
Date Time
Position of Sample Intake
Mechanical Operation of Sampler
Check of Sample Preservation (e.g., temperature control)
Security (Check for Possible Tampering, etc.)_
Date By (Signature)
^Sampler shall be located so that a representative sample is collected. Dye will be
•used to determine the mixing characteristics.
2Wastes containing high solids, rags, fibrous material, etc. can clog intake of sampler.
•intake must be placed to minimize while at same time obtaining a representative sample.
^Interval should be such that a representative sample is collected during the compositing
(eriod.
ethod used to preserve sample (i.e., temperature, chemical, etc.) and maintain at that
—level.
• his inspection generally made several times per day.
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ANALYTICAL QUALITY CONTROL CHECKLIST
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NATIONAL FIELD INVESTIGATIONS CENTER - DENVER
ANALYTICAL QUALITY CONTROL CHECKLIST
EXACT NAME OF DISCHARGER,
CITY AND STATE
1. CHAIN OF CUSTODY PROCEDURES FOLLOWED
2. REAGENTS, STANDARDS, BLANKS, AND DILUTIONS
PREPARED USING DISTILLED WATER FROM THE
APPROVED LABORATORY SUPPLY
3. REAGENTS AND STANDARDS PREPARED USING AR
GRADE CHEMICALS UNLESS OTHER PURITY GRADES
ARE SUGGESTED BY THE PROPER PROCEDURE
4. REAGENTS STANDARDIZED IN ACCORDANCE WITH
THE PROCEDURE APPLIED
5. STANDARDIZATION DATA REPORTED TO THE AQC
OFFICER WITH THE RAW DATA
6. CLASS A (NBS) MEASURING GLASSWARE USED
THROUGHOUT THE ANALYSIS. ANY VOLUMETRIC
MEASURING DEVICES NOT CLASSIFIED ACCORDING
TO FEDERAL SPECIFICATIONS OF CIRCULAR 602
OF NBS CALIBRATED PRIOR TO USE
7. PRECISION CALCULATED AS STANDARD DEVIATION
OF REPLICATE ANALYSES CONDUCTED AT LEAST
ONCE EVERY TEN SAMPLES. IF FEWER THAN TEN
SAMPLES ARE ANALYZED AS A SINGLE SERIES,
AT LEAST ONE REPLICATE SAMPLE INCLUDED IN
THE SERIES
8. ACCURACY CALCULATED AS PERCENT RECOVERY
FROM STANDARD ADDITIONS ANALYZED AT LEAST
ONCE EVERY TEN SAMPLES. IF FEWER THAN
TEN SAMPLES ARE ANALYZED AS A SINGLE
SERIES, AT LEAST ONE STANDARD ADDITION
INCLUDED IN THE SERIES
9. REPLICATES AND STANDARD ADDITIONS PREPARED
AND ANALYZED CONCURRENTLY WITH THE UNKNOWN
SAMPLE SERIES
10. CUSTODY OF REMAINING SAMPLE ALIQUOT
SECURED AND MAINTAINED
YES NO
REMARKS
CHECKLIST CERTIFIED BY:
DATE
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CHAIN OF CUSTODY PROCEDURES
(Partial Revision - June 1975)
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ENVIRONMENTAL PROTECTION AGENCY
Office Of Enforcemenf
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
Building 53, Box 25227, Denver Federal Center
Denver, Colorado 80225
June 1, 1975
CHAIN OF CUSTODY PROCEDURES
General:
The evidence gathering portion of a survey should be characterized by the
minimum number of samples required to give a fair representation of the
effluent or water body from which taken. To the extent possible, the quan-
tity of samples and sample locations will be determined prior to the survey.
Chain of Custody procedures must be followed to maintain the documentation
necessary to trace sample possession from the time taken until .the evidence
is introduced into court. A sample is in your "custody" if:
% 1. It is in your actual physical possession, or
2. It is in your view, after being in your physical possession, or
3. It was in your physical possession and then you locked it up in
a manner so that no one could tamper with it.
All survey participants will receive a copy of the survey study plan and will
be knowledgeable of its contents prior to the survey. A pre-survey briefing
will be held to re-appraise all participants of the survey objectives, sample
locations and Chain of Custody procedures. After all Chain of Custody samples
are collected, a de-briefing will be held in the field to determine adherence
to Chain of Custody procedures and whether additional evidence type samples
are required.
Sample Collection:
1. To the maximum extent achievable, as few people as possible should
handle the sample.
2. Stream and effluent samples shall be obtained, using standard field
sampling techniques.
3. Sample tags (Exhibit I) shall be securely attached to the sample
container at the time the complete sample is collected and shall
contain, at a minimum, the following information: station number,
station location, date taken, time taken, type of sample, sequence
number (first sample of the day - sequence No. 1, second sample -
sequence No. 2, etc.), analyses required and samplers. The tags
must be legibly filled out in ballpoint (waterproof ink).
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Chain of Custody Procedures (Continued)
Sample Collection (Continued)
4. Blank samples shall also be taken with preservatives which will
be analyzed by the laboratory to exclude the possibility of
container or preservative contamination.
5. A pre-printed, bound Field Data Record logbook shall be main-
tained to record field measurements and other pertinent infor-
mation, necessary to refresh the sampler's memory in the event
he later takes the stand to testify regarding his action's
during the evidence gathering activity. A separate set of field
notebooks shall be maintained for each survey and stored in a
safe place where they could be protected and accounted for at
all times. Standard formats (Exhibits II and III) have been
established to minimize field entries and include the date, time,
survey, type of samples taken, volume of each sample, type of
analysis, sample numbers, preservatives, sample location and
field measurements such as temperature, conductivity, DO, pH,
flow and any other pertinent information or observations. The
entries shall be signed by the field sampler. The preparation
, and conservation of the field logbooks during the survey will
be the responsibility of the survey coordinator. Once the
survey is complete, field logs will be retained by the survey
coordinator, or his designated representative, as a part of the
permanent record.
6v. The field sampler is responsible for the care and custody of the
samples collected until properly dispatched to the receiving lab-
oratory or turned over to an assigned custodian. He must assure
that each container is in his physical possession or in his view
at all times, or locked in such a place and manner that no one can
tamper with it.
7. Colored slides or photographs should be taken which would visually
show the outfall sample location and any water pollution to sub-
stantiate any conclusions of the investigation. Written documenta-
tion on the back of the photo should include the signature of the
photographer, time, date and site location. Photographs of this
nature, which may be used as evidence, shall also be handled
recognizing Chain of Custody procedures to prevent alteration.
Transfer of Custody and Shipment: .
1. Samples will be accompanied by a Chain of Custody Record which
.Includes the name of the survey, samplers signatures, station
number, station location, date, time, type of sample, sequence
number, number of containers and analyses required (Fig. IV).
When turning over the possession of samples, the transferor and
transferee will sign, date and time the sheet. This record sheet
-------
Chain of Custody Procedures (Continued)
allows transfer of custody of a group of samples in the field,
to the mobile laboratory or when samples are dispatched to the
NFIC - Denver laboratory. When transferring a portion of the
samples identified on the sheet to the field mobile laboratory,
the individual samples must be noted in the column with the
signature of the person relinquishing the samples. The field
laboratory person receiving the samples will acknowledge receipt
by signing in the appropriate column.
2. The field custodian or field sampler, if a custodian has not
been assigned, will have the responsibility of properly pack-
aging and dispatching samples to the proper laboratory for
analysis. The "Dispatch" portion of the Chain of Custody Record
shall be properly filled out, dated, and signed.
3. Samples will be properly packed in shipment containers such as
1ce chests, to avoid breakage. The shipping containers will be
padlocked for shipment to the receiving laboratory.
4. All packages will be accompanied by the Chain of Custody Record
's showing identification of the contents. The original will accom-
• pany the shipment, and a copy will be retained by the survey
coordinator.
5. If sent by mail, register the package with return receipt request-
ed. If sent by common carrier, a Government Bill of Lading should
be obtained. Receipts from post offices and bills of lading will
be retained as part of the permanent Chain of Custody documentation.
6. If samples are delivered to the laboratory when appropriate person-
nel are not there to receive them, the samples must be locked in
a designated area within the laboratory in a manner so that no
one can tamper with them. The same person must then return to the
laboratory and unlock the samples and deliver custody to the
appropriate custodian.
Laboratory Custody Procedures:
1. The laboratory shall designate a "sample custodian." An alternate
will be designated in his absence. In addition, the laboratory
shall set aside a "sample storage security area." This should be
a clean, dry, isolated room which can be securely locked from the
outside.
2. All samples should be handled by the minimum possible number of
persons.
3. All incoming samples shall be received only by the custodian, who
will indicate receipt by signing the Chain of Custody Record Sheet
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32
Chain of Custody Procedures (Continued) ;
accompanying the samples and retaining the sheet as permanent
records. Couriers picking up samples at the airport, post
office, etc. shall sign jointly with the laboratory custodian.
4. Immediately upon receipt, the custodian will place the sample
in the sample room, which will be locked at all times except
when samples are removed or replaced by the custodian. To the
maximum extent possible, only the custodian should be permitted
1n the sample room.
5. The custodian shall ensure that heat-sensitive or light-sensitive
samples, or other sample materials having unusual physical
characteristics, or requiring special handling, are properly
stored and maintained.
6. Only the custodian will distribute samples to personnel who are
to perform tests.
7. The analyst will record in his laboratory notebook or analytical
worksheet, identifying information describing the sample, the
procedures performed and the results of the testing. The notes
shall be dated and indicate who performed the tests. The notes
shall be retained as a permanent record in the laboratory and
should note any abnormalities which occurred during the testing
procedure. In the event that the person who performed the tests
Is not available as a witness at time of trial, the government
may be able to introduce the notes in evidence under the Federal
Business Records Act.
8. Standard methods of laboratory analyses shall be used as described
in the "Guidelines Establishing Test Procedures for Analysis of
Pollutants," 38 F.R. 28758, October 16, 1973. If laboratory
personnel deviate from standard procedures, they should be prepared
to justify their decision during cross-examination.
9. Laboratory personnel are responsible for the care and custody of
the sample once it is handed over to them and should be prepared
to testify that the sample was in theiir possession and view or
secured in the laboratory at all times, from the moment it was
received from the custodian until the tests were run.
10. Once the sample testing is completed, the unused, portion of the
.sample together with all identifying fags and laboratory records,
should be returned to the custodian. The returned tagged sample
will be retained in the sample room until it is required for trial.
Strip charts and other documentation of work will also be turned
over to the custodian.
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33
Chain of Custody Procedures (Continued)
11. Samples, tags and laboratory records of tests may be destroyed
only upon the order of the laboratory director, who will first
confer with the Chief, Enforcement Specialist Office, to make
certain that the information is no longer required or the samples
have deteriorated.
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34
EXHIBIT I
EPA, NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
Station No.
Data
Time
Sequence No.
Station Location
_COD
.Nutrients
.Mefalj
.Oil and Grease
_Other
Samplers:
-Crab
_Comp.
Remarks/Preservative:
Front
ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
BUILDING 53, BOX 25227, DENVER FEDERAL CENTER
DENVER, COLORADO 80225
Back
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EXHIBIT II
FOR
SURVEY, PHASE.
DATE
TYPE OF SAMPLE.
ANALYSE.S REQUIRED
STATION
NUMBER
STATION DESCRIPTION
TOTAL VOLUME
TYPE CONTAINER
PRESERVATIVE
£
z
UJ
C£
>—
Z
Q
O
CO
Q
O
u
u
O
>—
V)
Q
6
1/5
<
O
SUSPENDED SOLIDS |
ALKALINITY ]
O
Q
*
Q.
CONDUCTIVITY' j
TEMPERATURE' |
TOTAL COLIFORM |
FECAL COLIFORM j
TURBIDITY |
UJ
«/i
<
UJ
ct:
O
Q
Z
<
_j
O
METALS |
u
<
CO
•
PESTICIDES |
C3
o:
LU
I
•
TRACE ORGANICS |
PHENOL . |
CYANIDE ' '
REMARKS
CO
in
-------
EMMIT
FIELD DATA RECORD
-'. , '. •• • . . •
STATION
*
•
NUMBER
DATE
TIME
TEMPERATURE
•c
CONDUCTIVITY
fji mhos/cm
PH
S.U.
D.O.
mg/1
Gage Ht.
or Flow
Ft. or CFS
OJ
-------
EXHIBIT IV
ENVIRONMENTAL PROTECTION AGENCY
Office Of Enforcement
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
Building 53, Box 25227, Denver Federal Center
Denver, Colorado 80225
CHAIN OF CUSTODY RECORD
37
SURVEY
STATION
NUMBER
STATION LOCATION
DATE
Relinquished by: (signature)
Relinquished by: (Signature)
Relinquished by: (signature)
Relinquished by: (signature;
Dispatched by: (Signature)
Method of Shipment:
Date/
TIME
SAMPLERS: (Signature)
SAMPLE TYPE
Water
Comp.
Grab.
Air
SEO.
NO.
NO. OF
CONTAINERS
ANALYSIS
REQUIRED
•
Received by: (signature)
Received by: (Signature)
Received by: (signature)
Received by Mobile Laboratory for field
analysis: (Signature)
'Time
Received for Laboratory by:
Date/Time
Date/Time
Date/Time
Date/Time
Date/Time
Distribution: Orig.— Accompany Shipment
1 Copy—Survey Coordinator Field Files
OPO BS4 -BO
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