UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
ALJG 2 9 1991
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
OSWER Publication Number: 9360.4-11FS
MEMORANDUM
SUBJECT: Fact Sheet on Removal Program Quality Assurance/Quality
Control (QA/QC) Initiatives: Suiqmatfy of Activities
FROM:
TO:
Henry L. Longest II, Director
Office of Emergency and Remedial R'e'sponse
Director, Waste Management Division
Regions I, IV, V
Director, Emergency and Remedial Response Division
Region II
Director, Hazardous Waste Management Division
Regions III, VI, VII, VIII, IX
Director Hazardous Waste Division
Region X
Director, Environmental Services Division
Regions I, VI, VII
PURPOSE
This memorandum transmits a fact sheet entitled "Removal
Program QA/QC Initiatives: Summary of Activities."
BACKGROUND
The Environmental Response Team (ERT), located in Edison,
New Jersey, is responsible for managing quality assurance/quality
control (QA/QC) activities for the removal program. In this
regard, ERT has produced many guidances and tools to assist
On-Scene Coordinators (OSCs) in fulfilling their QA/QC
responsibilities.
Printed on Recycled Paper
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OBJECTIVE
This objective of this fact sheet is to inform OSCs, other
EPA personnel, other Federal Agencies, and other interested
parties on removal program QA/QC activities. Information is
provided on available guidances, standard operating procedures,
checklists, software and training. These tools are intended to
assist field personnel in complying with Agency policy for all
environmental data collection and environmental measurement
during removal actions. The fact sheet specifies highlights of
each document, where to obtain more information, and a timeframe
for final publication and availability.
IMPLEMENTATION
This is an advance copy of the fact sheet and Regions should
feel free to reproduce the attached advance copy for internal use
while the fact sheet is being printed. A supply of printed
documents will be sent to your Regional Office within the next
eight weeks, and will be inventoried for agency use at the
Superfund Document Center, Headquarters, 401 M Street SW,
OS-240, Washington, DC 20406; E-mail: OERR/PUBS. Contractors
and members of the public may purchase the documents from the
National Technical Information Service (NTIS), U.S. Department of
Commerce, 5285 Port Royal Road, Springfield, VA 22161;
(703) 487-4600.
Questions regarding this fact sheet should be addressed to
William Coakley, ERT, FTS 8-340-6921.
Attachment
cc: Removal Managers, Regions I-X
Superfund Branch Chiefs, Regions I-X
OERR Division Directors
Technical Assistance Team (TAT) Deputy Project Officers
Emergency Response Cleanup Services (ERGS) Deputy Project
Officers
Regional QA Officers
Duane Geuder, CORAS
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United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Publication 9360.4-11 FS
June 1991
Removal Program
QA/QC Initiatives:
Summary of Activities
Office of Emergency and Remedial Response
Environmental Response Branch, MS-101
Quick Reference Fact Sheet
This fact sheet is the first in a series of intermittent fact sheets on the Removal Program's Quality
Assurance/Quality Control (QA/QC) activities for On-Scene Coordinators (OSCs), other EPA personnel, other
Federal Agencies, and other interested parties. These activities include developing and disseminating guidance
documents, software, operating procedures, and checklists, as well as providing training. The Environmental
Response Team (ERT) has responsibility for these activities. The activities will assist field personnel in
complying with Agency policy for all environmental data collection and environmental measurement during
removal actions. Highlights of, detailed information on, a timeframe for final publication and availability of each
of the documents are included in this fact sheet. Updated fact sheets will be published periodically to include
an explanation of key issues, discuss additional training, and to update the publication schedule of manuals as
necessary.
Quality Assurance/Quality Control
Guidance for Removal Activities:
Sampling QA/QC Plan and
Data Validation Procedures
BACKGROUND
As stated in the Administrator's Memorandum of
May 30, 1979, Agency policy requires that all EPA
organizational units that perform environmentally
related measurements, including program offices,
EPA regional offices, and. EPA laboratories,
• participate in a centrally managed quality assurance
program. This requirement applies to all
environmental monitoring and measurements
mandated or supported by EPA through regulations,
grants, contracts, or other formal means not
currently covered by regulation. The responsibility
for developing, coordinating, and directing the
implementation of this program has been delegated
to the Office of Research and Development, which
has established the Quality
Assurance Management Staff for
this purpose. As stated in EPA
Executive Order 5360.1, "Policy
and Program Requirements to
Implement the Mandatory Quality
Assurance Program," the primary
goal of the QA/QC program is to ensure that all
environmentally related measurements performed or
supported by EPA produce data of known quality.
The Removal Program's QA/QC guidance consists
of two parts: part one provides guidance on
establishing, implementing, and using QA/QC
protocols for data collection activities; and part two
provides guidance for reviewing and validating
laboratory data packages according to the guidance
established in part one.
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PART ONE
Part one includes a detailed description of each
section to be contained in a sampling QA/QC plan.
The development of the plan is the responsibility of
the OSC. The OSC reviews and approves the site-
specific plan and may obtain assistance from the
Regional QA/QC Officer. The guidance assists the
OSC in ensuring that reliable, accurate, and quality
data are obtained through field sampling efforts as
well as field and laboratory analytical services. The
sampling QA/QC plan produced from this guidance
is neither intended to supersede nor replace the
generic QA project plan, but rather to augment the
project plan by detailing site-specific information
regarding sampling, analysis, and QA/QC protocols.
PART TWO
Part two provides guidance on the validation of
laboratory data packages. It is a compilation of the
procedures used in the Contract Laboratory
Program (CLP) and those found in the "Laboratory
Data Validation Functional Guidelines for
Evaluating Organic, Inorganics, Pesticides, and
Dioxin Analysis." This guidance was developed for
the Emergency Response Division's (ERD) use and
is not intended to supersede the guidance
documents developed for CLP data validation used
for remedial activities.
SOFTWARE
Two software packages that support the QA/QC
Guidance for Removal Activities are QASPER, the
Quality Assurance Sampling Plan for Emergency
Response, and e-DATA for data validation
procedures.
QASPER
QASPER is a PC-based software package which
compiles generic text and
user provided site-specific
information into a QA/QC
sampling plan. QASPER
addresses the nine sections in
parts one and two of the
QA/QC guidance.
e-DATA
e-DATA is a PC-based system designed to manage,
validate, report, and communicate hazardous waste
sample information generated through the sample
collection, analysis, and validation process.
It consists of three separate and distinct modules
which reflect the needs of the OSC, the laboratory,
and the data validator.
The appropriate e-DATA system modules are
installed at each location and communicate via a
Central Node or bulletin board. The Central Node
module provides the centralized electronic
repository and controls the file transfer between the
site, lab, and validation modules. e-DATA is
available to OSCs whenever ERT is accessed for
on-site monitoring.
Representative Sampling Guidances
The Representative Sampling Guidances are a
series of documents designed to assist Removal
Program OSCs and other field staff in obtaining
representative samples at removal sites.
Representative sampling is the degree to which a
sample or group of samples accurately characterize
site conditions. The guidance documents are
designed to assist field personnel
in conducting representative
sampling, including evaluating
historical data, designing a
sampling plan, collecting samples,
generating data, evaluating
variability, applying QA/QC
requirements, and interpretation
of data.
The guidances address specific Removal Program
objectives including identifying the threat,
delineating sources and the extent of the
contamination, and confirming the achievement of
cleanup standards. Because many costly decisions
are based on the sampling data, OSCs and other
field personnel need to understand the importance
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of accurately sampling to characterize actual site
conditions.
The documents are divided by sampling medium:
air, soil, ecological, waste, and water. Each
document has unique aspects, but the overall
objectives of representative sampling are included in
all five documents.
SOIL
This document includes information on
representative soil sampling. It describes sampling
design, field sample collection, field sample
preparation, quality assurance evaluation, and data
interpretation and presentation. Soil sampling, field
screening, and geophysical equipment are described
and assessed in tables. A case study illustrates the
principles described in the document.
AIR
This document includes information on
representative air sampling. Because air is a unique
medium when compared to soil and groundwater,
the statistical considerations developed for other
media are not applicable to air. Air concentrations
vary at a given location over time. Because of this
variability, this document describes sampling
applications, sample design considerations, sampling
and analytical techniques, atmospheric modeling,
and quality assurance/quality control that are
unique for air.
ECOLOGICAL
This document explains the type of
information that an ecological
assessment will provide. This
includes but is not limited to the
effects of pollutants on plant and animals and the
ecological impacts of the removal action. This
document is still in early draft form but the chapters
include development of data quality objectives,
development of an ecological sampling plan,
ecological sampling methods and equipment, quality
assurance/quality control, statistical considerations,
and data validation and interpretation. This
document will include various stand-alone decision
trees for on-site use.
WASTE
The development of this
volume will begin in July 1991.
It will address representative
sampling of wastes piles, waste
lagoons, drums, tank cars, and
mixed waste, as well as how to
obtain wipe and chip samples.
WATER
The development of this volume
will begin in December 1991. It
will address groundwater and
surface water representative
sampling.
ERT Standard Operating Procedures
In 1987, EPA began a program to promote
consistencies in the Removal Program's sampling
and analytical protocols. Consequently, ERT wrote
detailed Standard Operating Procedures (SOPs) on
45 field activities. SOPs promote uniform and
consistent collection of monitoring data and help
define and control uncertainties. The ERT SOP
compendiums will soon be available for use by the
Removal Program.
The 45 ERT SOPs will be published in seven
compendiums:
• ERT Groundwater Sampling Procedures
• ERT Waste Sampling Procedures
• ERT Soil Sampling and Surface Geophysics
Procedures
• ERT Surface Water and Sediment
Sampling Procedures
• ERT Toxicity Testing Procedures
• ERT Field Analytical Procedures
• ERT Air Sampling Procedures
The ERT Groundwater Sampling Procedures
include procedures for decontaminating sampling
equipment; and provide general guidelines for
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groundwater well sampling, and guidelines for
conducting controlled pumping tests and slug tests.
The compendium provides a quick means of
evaluating underground contamination with soil gas
sampling, summarizes the methods used for
monitoring well installation and well development,
and sets guidelines for the determination of the
depth of water in an open borehole, cased borehole,
monitoring well or piezometer.
The ERT Waste Sampling Procedures provide
technical guidance on safe and cost-effective
response actions at hazardous waste sites containing
waste in piles, drums, and tanks. It also outlines the
recommended protocol for collecting representative
chip, wipe, and sweep samples to monitor potential
surficial contamination, as well as protocols for
decontaminating sampling equipment.
The ERT Soil Sampling and Surface Geophysics
Procedures describe procedures for collecting
representative soil samples and provide a quick
means of evaluating underground contamination
with soil gas sampling. Also, this compendium
addresses the general procedures used to acquire
surface geophysical data which can identify and
delineate subsurface waste and help interpret
geological and hydrogeological site data.
The ERT Surface Water SOP describes procedures
for aqueous and nonaqueous sampling of lakes,
lagoons, and streams on the surface and at various
depths. The ERT Sediment Sampling SOP, in the
same compendium, provides procedures on
sediment sampling beneath standing and running
water. This compendium also includes an
equipment decontamination SOP.
The ERT Toxicity Testing
Procedures include nine tests of
toxicity involving larval
Pimephales promelas, Daphnia
magna, Daphnia pulex,
Ceriodaphnia dubia, or
Selenastnim capricomutum.
The ERT Field Analytical Procedures include SOPs
on x-ray fluorescence (XRF), photoionization
detectors (PID), Photovac gas chromatographs, the
Sentex gas chromatograph, and the Micromonitor
M200 gas chromatograph.
The ERT Air Sampling Procedures include SOPs
on SUMMA canister cleaning, sampling, and
analysis; preparation of SUMMA canister field
standards; and low level methane analysis of
SUMMA canister gas samples. The compendium
also includes asbestos sampling, Tedlar bag
sampling, charcoal tube sampling, Tenax tube
sampling, and procedures for using polyurethane
foam (PUF) samplers.
The first five compendiums listed above have been
completed, sent to the Office of Emergency and
Remedial Response (OERR) for publication and
will be available in the early summer of 1991. The
remaining two compendiums are near completion,
and should be available in the fall.
Performance Evaluation Samples
Performance evaluation (PE) samples provide EPA
with an external quality assurance measure for
laboratory and/or method performance.
Traditionally, PE samples are prepared and certified
by the Agency's three environmental monitoring and
support laboratories (EMSL).
Most PE samples are available only in a water
medium, which cannot truly measure laboratory or
method performance for air or soil samples.
Currently, EMSL/Las Vegas is obtaining actual site
samples and analyzing them for contaminants of
interest at specific levels. PE samples for metals in
soil are available, along with blank soil samples. If
the combination of chemical contaminants, or
analyte profile, is appropriate for evaluating
laboratory/method performance,
the samples are then homogenized
well, the analyte concentrations
are certified, and the samples are
packaged into single sample lots.
These samples will then be made
available to the Regions to include with actual site
samples being sent to CLP and other contract
laboratories.
Each Region has a designated coordinator for
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requesting PE samples. This person orders PE
samples from the appropriate EMSL contact.
Generally, PEs for water and ecological samples are
available from EMSL/Cincinnati, PEs for asbestos
and ambient air organics are available from
EMSL/RTP, and PEs for soil/sediments and wastes
are available from EMSL/Las Vegas.
Analytical Solicitation and
Deliverables Checklist
The availability of analytical methods and support
services from non-CLP laboratories is a primary
concern to Regional offices. In response to the
concern, ERD is developing a detailed checklist for
the Regional offices to use to collect useful
information about non-CLP laboratories. On the
checklist, the laboratory will respond to questions
regarding the available analytical and support
services and turnaround times offered by potential
non-CLP laboratories. In this way, Analytical
Coordinators can put non-CLP
analytical resources to optimal
use. Using the checklist,
Analytical Coordinators can
reduce the length of time spent
learning about a laboratory, and
can make better judgments when
selecting a laboratory, both of
which will minimize removal costs.
This checklist is expected to be available by June
1991.
Field Audit Checklist
A field audit checklist was developed to evaluate the
need for training and to improve field sampling
procedures. It is a tool to ensure that all field
activities are consistent for each TAT and ERCS
contractor. The contractor uses
the audit checklist as part of
their internal audit activities
required by their QA Program
Plan and the contract statement
of work.
Using this checklist, the field activities auditor is
responsible for auditing ten percent of his/her site
activities, verifying that approved protocols, spelled
out in the QA Sampling Plan, are being followed.
The audit checklist, together with a summary of
findings and any necessary corrective actions, are to
be filed with the Regional TAT or ERCS office, the
EPA project officer, and the EPA Deputy Project
Officer. Periodically, the QA Coordinator for ERD
will make office and/or site visits to review these
audit checklists, to assess the need for program
improvements and trainings.
Training
REPRESENTATIVE SOIL SAMPLING TRAINING
This course is designed
for new staff entering
the various components
of the Removal
Program, for individuals
currently involved with
sampling plan design
and actual sampling,
and as a train-the-
trainer program for mid-level management and
group leaders. The course spans 1 1/2 days and
involves several representative soil sampling
documents and a case study exercise using the
example site in the ERT guidance.
QUALITY ASSURANCE/QUALITY CONTROL TRAINING
This course is designed for individuals interested in
acquiring knowledge in establishing, implementing,
and using QA/QC protocols for data collection
activities performed under the Removal Program.
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The 1 1/2 day course begins with information on
the contents of a sampling plan, the QA/QC
objectives and levels, and a hands-on exercise on
QA/QC procedures using the QASPER software.
A round-table discussion on data validation
procedures is held at the conclusion of the course.
Where to Obtain More Information on
Removal Program QA/QC Activities
QA/OC GUIDANCE
This document is available from EPA's Center for
Environmental Research Information (CERI) at
513-569-7652 or FTS 684-7562. The OSWER
directive number is 9360.4-01.
REPRESENTATIVE SAMPLING GUIDANCE
These documents are expected to be available at
CERI according to the following schedule:
Soil - July 1991
Air - July 1991
Ecological - January 1992
Waste - February 1992
Water - September 1992
The documents listed above will be distributed to
the Emergency Response Branch and regional QA
Officers.
ERT STANDARD OPERATION PROCEDURES
The following ERT compendiums are expected to
be available from CERI by August 1991. These
compendiums will be available to On-Scene
Coordinators and Regional QA officers from ERT.
Compendium of ERT Groundwater Sampling
Procedures - OSWER directive 9360.4-06
Compendium of ERT Waste Sampling Procedures -
OSWER directive 9360.4-07
Compendium of ERT Soil Sampling and Surface
Geophysics Procedures - OSWER directive
9360.4-02
Compendium of ERT Surface Water and Sediment
Sampling Procedures - OSWER directive
9360.4-03
Compendium of ERT Toxicity Testing Procedures -
OSWER directive 9360.4-08
Compendium of ERT Field Analytical Procedures -
OSWER directive 9360.4-04
Compendium of ERT Air Sampling Procedures -
OSWER directive 9360.4-05.
PERFORMANCE EVALUATION SAMPLES
To obtain more information on Performance
Evaluation Samples, contact your Performance
Evaluation Coordinator in the Regional Emergency
Response Branch.
ANALYTICAL SOLICITATION AND DELIVERABLE^
CHECKLIST
This checklist is used to determine useful
information about non-CLP laboratories. Contact
your TAT Regional Analytical Coordinators for
more information.
FIELD AUDIT CHECKLIST
These checklists are available from the Regional
Internal (TAT Contractor) Audit Program of Field
Activities.
For further information
on training and any of the
above activities or
documents, call Mr.
William Coakley at:
(908) 906-6921 or
FTS #: 340-6921.
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