United States
Environmental Protection
Agency
Environmental Monitoring
Systems Laboratory
P.O. Box 15027
Las Vegas NV 89114-5027
January 1985
EPA 600/4-85-003
Research and Development
xvEPA
Standard Operating
Procedures for
Conducting Sampling
and Sample Bank
Audits
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EPA 600/4-85-003
January 1985
STANDARD OPERATING PROCEDURES FOR CONDUCTING
SAMPLING AND SAMPLE BANK AUDITS
by
Life Systems, Inc.
24755 Highpoint Road
Cleveland, Ohio 44122
EPA Contract No. 68-03-3136
Program 1254
Assignment 25
Project Officer
J. Gareth Pearson
Quality Assurance Division
Environmental Monitoring Systems Laboratory
Las Vegas, Nevada 89114
Technical Contact
Kenneth W. Brown
Exposure Assessment Research Division
Environmental Monitoring Systems Laboratory
Las Vegas, Nevada 89114
ENVIRONMENTAL MONITORING SYSTEMS LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
LAS VEGAS, NEVADA 89114
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FOREWORD
This Standard Operating Procedure for Conducting Sampling and Sample Bank
Audits was prepared by ICAIR, Life Systems, Inc., under U.S. Environmental
Protection Agency Contract 68-03-3136 during the period March 8, 1984 to
September 30, 1984. The program was directed by Ms. Cynthia D. Patrick. The
technical effort was completed by Mr. Timothy W. Owens and Dr. D. J.
Northington.
Mr. Kenneth Brown was the Technical Contact for the Environmental
Monitoring Systems Laboratory, Las Vegas, NV 89114.
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NOTICE
The preparation of this document has been funded wholly by the U.S.
Environmental Protection Agency through Contract 68-03-3136 to Life Systems,
Inc.. Cleveland, OH. It has been subjected to Agency peer and administrative
review and has been approved for publication.
11
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ABSTRACT
The U.S. Environmental Protection Agency's (USEPA) Environmental
Monitoring Systems Laboratory-Las Vegas (EMSL-LV) Is responsible for preparing
Standard Operating Procedures (SOPs) for auditing sampling and sample bank
activities performed under the Resource Conservation and Recovery Act (RCRA)
as well as conducting field audits of these activities when they are performed
by EPA and EPA contractors. Although SOPs for auditing analytical methods and
laboratory practices have been developed, guidelines for conducting
evaluations of sampling and sample bank activities are generally lacking.
This SOP provides the Agency with such guidelines for evaluating and auditing
sample collection and sample bank activities.
This SOP provides audit personnel with a description of the components
and organization of an audit program. Also discussed are administrative and
procedural functions necessary to initiate, conduct and complete the audit and
suggested qualifications and training requirements for audit personnel. The
Appendix of the SOP provides checklists for use in conducting the audit.
Checklists are presented for identifying and/or evaluating the use of proper
sampling equipment and materials, sampling methodology, packaging, labeling
and shipment of samples, quality assurance/quality control (QA/QC) protocols,
sampling plans and sampling personnel.
ill
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CONTENTS
Foreword i
Notice ii
Abstract ill
Figures v
Tables v
1. Introduction 1
Background 1
Purpose 2
2. Audit Team 6
Introduction 6
Audit Program Manager 9
Audit Team Leader 10
Audit Team Members 10
3 In-House Audit Preparation 11
Overview 11
Audit Initiation 11
Review and Assessment of Documentation 12
In-House Preparation for Field Audit 14
4. Conducting the Field Audit 17
Overview 17
Performing the Audit 17
Post-Audit Debriefing 18
5. Audit Completion 20
Overview 20
Report Preparation 20
Corrective Action 20
References 22
Appendix Sampling Audit Checklist for RCRA/CERCLA Activities 24
I. General Information 24
II. Sampling Plan 27
III. Sampling Equipment/Materials 30
IV. Sampling Approach/Methodology 45
V. Packaging, Labeling, Transport 62
VI. Quality Assurance/Quality Control 65
VII. Sampling Personnel 71
iv
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FIGURES
Number Page
1 Audit process flow diagram 3
2 Audit team 7
3 Field audit preparation checklist 16
4 Cover page to audit report 21
LIST OF TABLES
TABLE Page
1 Audit schedule A
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SECTION 1
INTRODUCTION
The primary objective of a sampling QA/QC plan Is to determine the
quality of the reported data and ensure that it is adequate to the degree
required for the intended end use of the data. Hov this objective is met
depends upon the purpose of the particular sampling program (Barth and Mason
1984).
Data resulting from any monitoring or sampling program cannot be
evaluated and interpreted with confidence unless adequate quality assurance
methods and procedures have been incorporated into the program design.
Quality assurance/quality control has been used to develop a system for
assuring the quality of the results by attempting to either provide control of
the various steps in the interpretation or to provide adequate replication for
statistically determining and quantifying the sources of variation or error in
the chain.
In 1976, the USEPA (USEFA 1976) required that the quality of data
considered to be acceptable must be defined as quantitatively as possible.
The requirement for a quantitative standard for acceptability requires that a
statistical sampling plan be developed that assures the precision, bias,
completeness, comparability and representativeness of the sampling effort and
of the resulting data.
This document is intended to address the EPA's quality assurance
requirement (USEPA 1980a) to audit all sampling and monitoring activities that
generate and process environmentally-related data for Agency use. It is not
intended to provide peer review of the technical merit or to verify the
scientific validity of the monitoring/sampling design, sampling devices or
program protocols.
BACKGROUND
This SOP is designed for the process of auditing activities carried out
by EPA and EPA contractors as a result of two acts of Congress. The Resource
Conservation and Recovery Act (RCRA) (1976) was designed to set standards for
the operation and maintenance of hazardous waste treatment, storage and
disposal facilities. Section 3007 of the act authorizes EPA to enforce the
Act by conducting inspections of facilities that handle hazardous wastes.
On the other hand, the Comprehensive Environmental Response Compensation and
Liability Act (CERCLA) (1980), or "Superfund" program, was designed to
discover, study, mitigate and remedy abandoned or uncontrolled hazardous waste
sites.
The EMSL-LV is responsible for the preparation of SOPs for auditing
RCRA-related sampling and sample bank activities as well as conducting field
audits of these activities when performed by EPA and EPA contractors. The
object of these sampling activities is to provide the Agency with samples that
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can be used for the generation of statistically representative, valid and
dependable data. The data must, of course, be scientifically and legally
defensible, which means the data must meet certain quality specifications
usually defined in the Project and QA Plans. An audit is a systematic check
to determine whether the project personnel are adhering to the steps, methods
and protocols required by the Project and QA Plan.
The terms QA and QC are often used interchangeably. Quality assurance,
however, refers to an integrated program of controls designed to address and
certify the quality of data produced for a program or project. Quality
control, on the other hand, refers to specific steps taken to monitor the
measurement process. The term "quality" as applied to data pertains primarily
to the following characteristics:
Accuracy - The degree to which the measurements represent the true or
accepted value.
Precision - A measure of how closely individual measurements of the same
kind are in agreement with each other, without regard to the
true value.
The term Sample Bank refers to a facility used for sample storage,
document control (i.e., chain-of-custody, logs, tags, etc.) and shipping of
samples as opposed to the activities of actually taking the sample. Sampling
activities require adherence to strict protocols as well as documentation of
the activity. Sample Bank activities tend to emphasize the latter; as such,
auditing these activities primarily involves verifying completeness of
records, although Sample Bank activities may include sample preparation
procedures (i.e., mixing, sieving, drying, etc.).
Figure 1 depicts a typical audit process flow diagram. The audit process
requires considerable preparation to Identify the steps and processes that are
critical to achieving the goals defined In the Project and QA Plans. Once
identified, these critical processes and steps are observed in the field by
the audit team to verify that the Plans are being followed. In this way the
Agency may be assured that the required quality of data is actually being
achieved.
Table 1 provides a suggested schedule for conducting various parts of the
audit. Note that this schedule is only an example, and that the time
schedules for audits will vary depending on the size and complexity of the
operation. A large project that has been going on for a year or more,
involving hundreds of sampling points and perhaps thousands of samples, may
require several weeks of preparation by six to ten auditors and a week or more
to conduct the audit.
PURPOSE
As stated above, the purpose of the audit is to ensure that the protocols
required by the Project Plan and QA Project Plan are in place and functioning
well.
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Section No. 1
Revision No. 2
Date: September 30, 198A
Page 3 of 6
Audit Initiation
I
Audit Scheduling
I
Selection of Audit Team
I
In-House Audit Preparation
I
Conducting the Field Audit
I
Audit Completion
Figure 1. Audit process flow diagram.
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Table 1. AUDIT SCHEDULE
Week Activity
0 Audit assigned by EMSL-LV
Lab Director
Team Leader and members selected
Request Project Documentation
1 Receipt of Project Documentation
2-3 Preparation for audit
2 Auditor arranges schedules with
sampling Project Officer
3-4 Conduct audit
4-6 Prepare Final Report on audit
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Specifically, the audit should (Brown and Hern, 1983):
Verify that the sampling methodology and QA measures are being
performed in accordance with program requirements.
Verify that project documentation is in order (i.e., records, chain-
of-custody forms, analytical tags, log books, work sheets).
Verify the identity and qualifications of key project personnel.
Identify QA problems.
Require corrective actions, if necessary.
Follow up on previous recommendations.
Provide a written report of the audit.
It is important to note that this SOP addresses audits of sampling and
sample bank activities, not technical audits to verify the scientific validity
of sampling devices or protocols being used in a project. It is not an
analytical audit, an evidentiary audit or an audit of safety procedures. The
technical approach should be reviewed by several well-qualified scientists
during the contract award and/or project peer review phase. Of course, if the
audit team notes any technical deficiencies, it should discuss them with the
Project Officer. Evidentiary audits are carried out through another office
within the Agency, the National Enforcement Investigation Center (NEIC)
(USEPA, 1980b). Analytical and health and safety audits are performed by
others with backgrounds in these areas. In any case, problems in any of these
areas should be pointed out to the Project Officer. The real thrust of the
audit, however, should be to verify that the procedures specified in the
Project and QA Plans are actually being followed.
The audit is designed to be well-announced and planned with the Project
Officer of the sampling project, not a surprise inspection. There are several
reasons for this:
Inspectors and observers from EPA Regions and Project Offices are
often on site.
A surprise Inspection may cause confusion among the field personnel
and the other Agency observers.
A surprise inspection may hinder the field operations.
Due to the hazardous nature of many field projects, unannounced
visits could increase the risk of accidents.
Key personnel and/or log books and sampling records may not be
available.
An unannounced audit is advantageous only because of the element of
surprise. Since it allows little time for correcting any problems or
deficiencies that occur, an unannounced inspection should be performed only if
there is information indicating that there are serious problems with the
sampling program.
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SECTION 2
AUDIT TEAM
INTRODUCTION
The audit team should consist of at least two people and usually four or
more. The size of the team will depend upon the extent of the operations
being audited; however, any operations which are potentially hazardous must be
performed using the buddy system.
Since the disciplines required to perform sampling activities are quite
varied, the audit team must have a variety of technical expertise. Backgrounds
may include the earth sciences, chemistry, engineering, health and safety,
biology and environmental science. As far as possible, the team should be
composed of specialists having overlapping experience in the various fields of
science and engineering related to the project to be audited.
The team must consist of professional individuals. The process of
reviewing the work of others and making constructive, objective evaluation is
required. The additional aspect of a hazardous environment requires that
personnel be alert, safety conscious and possess a high degree of
professionalism.
Organization Overview
As shown in Figure 2, the audit team reports to the Audit Program Manager,
who has overall responsibility for the audit and final report. The team
leader is primarily responsible for leading the team through the preparation,
the site visit and the preliminary report preparation.
Training Requirements
This section focuses on the training that auditors should have. Training
should be similar to that required for other personnel involved in hazardous
waste site/facility investigations (JRB undated, USEPA 1980b). The following
subject areas should constitute the personnel training program:
Performing an audit.
RCRA/CERCLA Regulations, including the rights of inspectors and
owner/operators of hazardous waste sites/facilities (JRB undated).
Safety protocols, including removal, decontamination and disposal of
clothing and equipment used during site visits and use and
restrictions of clean areas.
Safety equipment, including the use of respirators and
self-contained breathing apparatus (SCBA) and protective clothing.
First aid/cardiopulmonary resuscitation (CPR).
Site-specific contingency and evacuation plans.
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Section No. 2
Revision No. 2
Date: September 30, 1984
Page 2 of 5
Audit Program Manager
Team Leader
Audit Team
Members
Member
Program Manager
Team Leader
Team Member
Recommended Minimum
Qualifications
Bachelor's degree or 3-8 years'
experience
3 years' audit experience
1 year as Team Leader
Bachelor's degree or 3-8 years'
experience
2 years' audit experience
Bachelor's degree or 3-8 years'
experience
Attended 2 audits as observer
Figure 2. Audit team.
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Legal ramifications of the audit, including requirements of
chain-of-custody (Hart, F. C. 1981), preservation of evidence and
witness and testimony responsibilities.
Recognition and evaluation of extent of hazards, methods used to
control risks and chemical compatibilities/reactions.
Personal hygiene, including prohibitions against eating, drinking
and smoking (USEPA 1979) and the effect of facial hair on respirator
efficiency.
Certification at the intermediate and/or advanced level of EPA's
Health and Safety Training Program (USEPA 1981).
Refresher courses in first aid, CPR, use of safety equipment and safety
training should be repeated at least once a year. Hazards specific to a
particular site should be discussed at pre-audit meetings.
Medical and Health Requirements
This section presents the minimum medical and health standards that
should be met by auditors of hazardous sampling activities and the continuing
medical care requirements recommended for these auditors. As with training
requirements, the health and medical requirements are similar to those for
people who work on-site and are involved in clean-up activities or in other
hazardous waste handling activities (JRB undated). An excellent medical
program designed for laboratory and field workers exposed to toxic materials
is presented in USEPA 1984.
Team members should undergo medical examinations periodically throughout
their assignment. An initial examination is required prior to participation
in any activity dealing with hazardous materials; follow-up examinations
should be performed at least once a year. Additional examinations may be
called for if the person has been subjected to uncontrolled or unsafe
conditions where he may have been exposed to potentially hazardous material.
Finally, an exit examination is required whenever a team member terminates his
employment or is reassigned to an unrelated program.
Physicians conducting the examinations must be certified to practice
occupational medicine. Records must be kept for thirty years, and the worker
must sign a release form authorizing the physician to release all relevant
medical records to the Agency in accordance with OSHA's rule on Access to
Employee Exposure and Medical Records (29 CFR Part 1910).
The physical examinations should include the following:
Personal/family history
Work history
Standard physical examination
Visual acuity measurements
Audiogram
Pulmonary function tests
Chest X-ray
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Electrocardiogram
Urinalysis, including occult blood
Complete blood count (CBC)
Sequential multiple analyzer computer-23 (SMAC-23) profile which
includes calcium, phosphorus, glucose, uric acid, blood urea
nitrogen (BUN), creatinine, albumin, serum glutamic-pyruvic
transaminase (SGPT), serum glutamic oxalacetic transanlnase (SCOT),
lactate dehydrogenase (LDH), globulin, adenosine/guanosine (A/G)
ratio, chloride, CO., triglycerides, cholesterol and creatinine/BUN
ratio
At the physician's discretion, other tests may be performed which are
related to possible exposures to hazardous materials. For example, exposure
to benzene may require a complete blood count, serum bilirubin and phenol in
urine, while exposure to heavy metals may require further tests of the
respiratory system, kidney and blood, as well as tests for heavy metals in
urine.
A personal emergency card must be completed for each team member and be
carried as part of the equipment and supplies that accompany the team to the
site. This card should include blood type; allergies to drugs, insect bites
or plants; current medical problems and treatments; special problems such as
contact lenses; name of personal physician and any other information which may
be important in case of an accident.
AUDIT PROGRAM MANAGER
Qualifications
The Audit Program Manager must possess technical as well as managerial
talents. Since the team consists of professionals with a variety of
scientific and engineering backgrounds, the background of the manager should
be as multidisciplinary as possible and preferably be centered around
environmental science. At a minimum, the Audit Program Manager should have a
bachelor's degree in a scientific or engineering field or have related
professional experience, three years' experience as an auditor of related
activities (or participation in at least ten audits) and one year's experience
(or four audits) as an audit team leader.
Responsibilities
The Audit Program Manager receives the audit assignment from the
appropriate EPA Laboratory or Office Director. The Program Manager selects a
Team Leader and, with the Team Leader's assistance, the team members; he
also makes assignments to individual members, assists the Leader, where
necessary, in preparing for the audit and approves all plans and reports.
Finally, the Program Manager is responsible for retaining all records and
reports of the audit proceedings.
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AUDIT TEAM LEADER
Qualifications
The Team Leader should be selected from among those team members who have
participated in a number of audits and have demonstrated clear managerial and
leadership qualities. It is recommended that, at a minimum, the Team Leader
have a bachelor's degree (or three to eight years of applicable work
experience) in a scientific or engineering field and two years' experience (or
participation in six audits) as an audit team member.
Responsibilities
The Team Leader receives his assignment from the Program Manager. He
helps in selecting team members and making assignments and leads the team in
preparing, conducting and reporting the results of the audit.
AUDIT TEAM MEMBERS
Qualifications
It is recommended that each member have either a bachelor's degree in an
appropriate scientific or engineering discipline or three to eight years of
applicable work experience. In addition, he should have at least one year of
experience in performing field sampling.
Responsibilities
The team members work with and take direction from the Leader in
preparing for, conducting and reporting the results of the audit.
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SECTION 3
IN-HOUSE AUDIT PREPARATION
OVERVIEW
Once the assignment has been received and the team selected, members
should prepare to conduct the audit by reviewing documents on the project,
including protocols and progress reports. In reviewing the documents and
preparing for the audit, the audit team should prepare checklists to aid
in Identifying procedures in the field that are critical to the project goals.
Example checklists are presented in the Appendix. This checklist or portions
thereof may require modification to account for site-specific factors.
Preparations for the field audit/site visit should also include a review of
health and safety precautions and of the field equipment needed for the audit.
Final preparations should include communications with the Project Officer
regarding the anticipated schedule, the activities to be observed, any current
problems and assistance with health and safety aspects, including the safety
equipment available at the site for the audit team.
The products of the in-house audit preparation should Include:
Assignments for the Team Members during both the preparation and the
field audit phase.
Checklists to identify and verify performance of critical sampling
activities.
List of equipment and supplies needed during the audit.
Schedule of activities for the site visit, Including the
introductory meeting with senior field personnel, the various audit
activities, a session for the team to prepare for the debriefing
and, finally, the debriefing of site personnel.
AUDIT INITIATION
Audit Initiation and Arrangements
This section focuses on the protocol involved in setting up an audit.
Generally, the audit is initiated by a written request to the appropriate EPA
Office or Laboratory Director (e.g., EMSL-LV) from an EPA Regional Office
responsible for a sampling project.
Acceptance of the request, along with the name, address and phone number of
the Audit Program Manager, is communicated by the appropriate Agency
Laboratory, Office or QA Officer. Further communication is conducted through
the Audit Program Manager. Rejection of the request would be routed through
the same channels, but without the need to identify a Program Manager. The
requesting Office must identify the Project Officer to whom communication
should be directed over the course of the audit.
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Request and Receipt of Documentation
Once he has been identified to the EPA Regional Officer and the Project
Officer, the Audit Program Manager should request background documents, such
as those listed below, from the Project Officer.
Project Plan
QA Project Plan and QA Reports
Protocols and Methods
Chain-of-Custody Procedures and Documents
Previous Audit Reports from other offices or agencies
Project and Progress Reports
Contract and Proposals
Documents to provide background information on the site (e.g., RCRA
permit applications, preliminary assessment reports, groundwater
monitoring plans, etc.)
Health and Safety Plan including contingency and evacuation plans
The Project QA plan must be approved by the requesting office's QA
Officer or equivalent before submission to the auditor.
If the project involves a RCRA-regulated site, background documents that
may be helpful include Part A and applicable sections of the Part B permit
(e.g., Waste Analysis Plan, Groundwater Monitoring Plan, etc.) of the
facilities' permit applications. If the project involves a CERCLA site, a
preliminary site assessment report or other information may be available.
Once the Audit Program Manager has made Initial contact with the Project
Officer, he should identify the Team Leader so that further communication may
be directed to him.
Prior to the site visit, the Team Leader and/or Health and Safety
Specialist should determine what potential health and safety risks may be
encountered on site and become familiar with the site layout, various site
activities and contingency plans, Including evacuation routes. When possible,
provisions are made with the Project Officer for field personnel to accompany
audit personnel whenever hazardous activities are involved: It will be safer
if the audit team members are accompanied by someone who is familiar with the
site and the specific hazards the team will face. To lessen the expense and
time needed to prepare for the audit, the team may also inquire into the
availability of safety equipment and protective clothing. The field personnel
should have all the necessary safety equipment for the audit team, but such
prior arrangements will ensure availability.
REVIEW AND ASSESSMENT OF DOCUMENTATION
Guidelines
The project documents should be reviewed in order to clarify the overall
project goals so that the activities which are critical to those goals may be
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audited. Items the auditors should review include: site layout, sampling
strategies and methods, QA/QC procedures, any current problems with and/or
on-site modifications of sampling methods and techniques of the project.
The Audit Team Manager and Team Leader should make assignments for the
team members based upon the site activities to be audited and the available
team members' backgrounds. Sampling and sample bank activities may be either
chemical, geological or biological in nature. Assignments for the audit
in-house preparation and field activities should be matched to the team
members whose experience best suits these assignments. For example, some
assignments may require more experience in health and safety, or engineering
or geology.
Evaluation of Plans and Protocols
Up to two weeks may be required for evaluating the project documentation,
planning, modifying checklists and completing those items on the checklists
not requiring on-site observation (NOTE: Though some items may not require
on-site observation, they should be verified on-site whenever possible).
First, the project activities which are called for in the Project Plan
and QA Project Plan and which are critical to the project goals should be
identified. Using the checklists in the Appendix as a starting point, the
team should Identify each critical step in each activity. Whether or not
these steps in the procedures and protocols are being followed as prescribed
in the Project Plan and QA Project Plan will be verified during the field
audit. It should be noted that the technical merit of the methods and
protocols should not be addressed unless there are significant problems which
will affect the achievement of project goals. The checklists in the Appendix
may be comprehensive enough to use in auditing any RCRA or CERCLA site.
Realistically, however, situations will be encountered in which the audit team
will have to "customize" the checklist to cover the specific sampling
activities of a site.
The Project Plan should contain the criteria used to select both the
sampling points and the sampling methods. An understanding of these criteria
is necessary in determining which steps are critical to the project goals and
thus must be observed during the site visit. Other information, such as the
contract, proposal and site background document, will also help in
understanding the reasoning behind the activities prescribed in the Project
Plan.
The QA Project Plan contains specific policies, activities and control
procedures which, when followed, should yield data that meet certain quality
parameters. This document should contain the parties responsible for the QA
program, the QA objectives for the measurement processes, chain-of-custody,
sampling, sample custody, calibration, analytical and data reporting
procedures, and the frequency of performance audits, preventative maintenance,
corrective actions and QA reports (USEPA 1980). In reviewing this document,
the measurement processes that are critical to the project goals should be
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identified. The necessary checklists which pertain to verifying these steps
in the field must be reviewed and/or revised for each of these processes.
The checklists should also contain information for verifying that all samples
critical for meeting the QA objectives as stated in the QA Plan are being met.
Also, samples for determining accuracy and precision must be identified and
the records showing frequency of calibration and preventative maintenance
measures must be noted. In many cases, the above documents may only reference
the literature (i.e., reference methods in the Federal Register). instead of
containing complete copies of the detailed protocols and methods to be used in
the project. Reviews of these references may be necessary to completely
Identify the critical steps which should be included in the checklist and
verified during the site visit.
Due to available resources and/or time constraints, only a portion of the
sampling program may be selected for auditing. For example, if the
chain-of-custody procedures were selected for audit, only those methods,
forms, document control procedures and security devices (i.e., evidence tape,
locks, etc.) would be examined and as such, only checklists addressing these
operations would be required.
Previous audit reports and Project Progress Reports may contain problems,
changes in procedures and suggested corrective actions which will need to be
reviewed. The checklists should identify observations which should be made
when following up on these items.
The Team Leader and/or Audit Program Manager should communicate with the
Project Officer and QA Officer on questions that surface during audit
preparation and inquire about the current status of the project.
Evaluation of Personnel Qualifications
In preparing for the audit and reviewing the Project Plan, a list should
be made of key field personnel, their positions and functions within the
organization and their qualifications. Key field personnel include levels
such as project manager and middle manager, scientific and engineering
specialists and consultants and first-line field supervisors. Checklists
should include notations of observations which are necessary to verify that
these people are still performing their functions and that if any personnel
changes have taken place, the replacements have the qualifications necessary
to perform their functions.
IN-HOUSE PREPARATION FOR FIELD AUDIT
Planning Meetings
Once the audit team has been assembled, assignments have been made, and
team members have studied project documents, a series of planning meetings
should be held to:
Review project documents
Discuss health and safety considerations
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Review/revise checklists
Develop lists of equipment and supplies
Develop a site visit schedule
Safety and Health Considerations
The meeting which is held to review general safety and health protocol
should also be used, when appropriate, to review the specific health and
safety aspects that the audit team will face when Inspecting a particular
site.
During initial discussions with the Project Officer, the Team Leader
and/or a Health and Safety Specialist assigned to assist the audit team should
have determined what health and safety problems the team may face during the
site visit. The audit team may need to provide their own safety equipment, or
the equipment may be available through the sampling team. This equipment may
Include boots, goggles, gloves, respirators, coveralls, SCBA, detector tubes,
oxygen meter, Geiger counter, combustible gas detector, etc.. Necessary
equipment may be available through the office or company performing the
sampling work, but they should not be relied upon to furnish safety equipment.
Arrangements must be made in advance for each piece of equipment the team may
need.
Required Equipment/Materials
During the planning meetings, a list should be prepared of equipment and
materials that will be required to conduct the audit. One team member should
be assigned to obtain all of the necessary safety, sampling and auditing
equipment. Figure 3 presents a checklist for identifying the necessary
equipment and materials and confirming that they have been assembled.
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Completed by:
FIELD AUDIT PREPARATION CHECKLIST
Audit Date(s): __/__/ to / /_
Project Name/Description:
Required? Obtained
Equipment/Materials
Boots
Goggles
Gloves
Respirators
Protective Clothing
Detector Tubes
Oxygen Monitor
Geiger Counter
Combustible Gas
Detectors
Decontamination
Equipment
First Aid Equipment
Radio Equipment
Snake Bite Kit
Personal Emergency
Cards
NOTES:
Yes
D
D
D
D
D
D
D
D
D
D
D
D
D
D
No
D
D
D
D
D
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D
D
D
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D
D
Yes
D
D
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D
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n
D
D
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and Inspected?
No
D
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N/A
D
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~J »'__
^^^'^^^ '^^_
' | ' T-
_/_/_
_/_/_
^ -, * ^^ * , ,
-M-- '
_^_^^^_ ___
' '
Figure 3. Field audit preparation checklist.
16
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SECTION A
CONDUCTING THE FIELD AUDIT
OVERVIEW
The Team Leader and the Project Officer should make the final arrange-
ments for the site visit to conduct the audit. Prior to the site visit, a
schedule of the audit should be mutually agreed upon which will not substan-
tially interfere with the project. The audit should be conducted in a profes-
sional, objective manner. Personality conflicts, personal preferences,
biases, and bad manners must not be allowed to detract from an objective audit
of the project. Audits are not intended to threaten, intimidate or abuse in
any manner the sampling and monitoring performance.
PERFORMING THE AUDIT
ProtocolDo's and Don'ts
The following is a list of items identifying some rules of etiquette that
should be followed when conducting the on-site sampling audit:
Do's
Upon arrival at site, Immediately identify audit team personnel to
the Project Officer or the most senior project person on site.
Meet with the project personnel and review the Intended work
schedule, identifying which on-site personnel and operations will be
involved in the audit.
Review all safety requirements, hazards and the safety equipment
which will be used on site.
Conduct the audit during normal working hours and at the convenience
of the owner or manager of the site and the Project Officer.
Don'ts
Don't verbally render judgment to site personnel.
During the on-site visit, the audit team members are strictly
observers, not participants.
Don't hinder operations.
Methodology
After the introductory meeting of the audit team with the senior project
personnel on-site and a review of the audit schedule and tasks, team members
should start performing their audit functions using the checklists.
Whenever possible, it should be verified that the documentation is in
order and is sufficient to establish the disposition of any collected sample by
inventorying the sample bank records and archived samples. The flow of
17
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specific samples should be traced through the system. Records reviewed should
include: chain-of-custody (COC) forms, sample tags, custody seals, shipment
forms, logbooks and archived samples. Logs must be clear and concise.
Changes to the log books should be made by the field personnel by lining
through, so that the original entry is still visible; the change is then
initialed. Problems should be documented in the logs.
The use of personnel identified in the Project Plan, QA Plan and contract
proposal, including all managers, middle managers, professional specialists
and first-line field supervisors, should be verified.
Activities performed by the sample bank custodian(s) should be observed.
Before accepting custody of any samples, sample bank personnel should check to
make sure that:
Each sample has a completed sample collection tag attached.
Each sample is Identified on the COC form.
A sample/site description form or record has been completed for all
samples.
Discrepancies are corrected.
Sampling methods and sample handling procedures should be observed
first-hand. A sampling methods audit encompasses proper equipment, sampling
locations, location documentation, decontamination, container preparation
(I.e., labeling, storing, preserving and COC documentation), field logbooks
and notes. Sample handling procedures may include drying, sieving, mixing,
compositing, splitting, packaging and shipping.
Use the checklists for documentation while observing the following:
Housekeepingsafety, decontamination, accident documentation and
security
Sampling equipment and containers
Cleaning and storage of sampling equipment (USEPA 1980c)
Preparation of collection procedures
Frequency of collection of field blanks, replicates, splits and
spikes (if any)
POST-AUDIT DEBRIEFING
Responsibilities
The Team Leader should meet alone with the team members to review their
results and determine what should be addressed at the debriefing. The review
should address the following points, allowing team members to summarize their
findings:
Sampling activities and documentation
Sample Bank activities and documentation
QA problems
Follow-up on previous recommendations
Summary
18
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The Team Leader should take notes and prepare a presentation for the
debriefing.
Audience
The debriefing should be held between the team and the project personnel
deemed appropriate by the Project Officer.
Results Presentation
In most cases, the Team Leader should conduct the debriefing and review
the team's initial findings. The Leader may choose to let team members
comment on their own findings. It should be made clear that the results of the
audit are still tentative at this stage, and that the final audit results will
be reported in writing within three weeks.
The format of the debriefing may conform to the outline used above in the
team meeting. Project personnel should be allowed to make comments after each
topic is discussed. The Team Leader should request any further
documentation, such as resumes of new people, copies of additional protocols,
etc., that he or she may need for the final report.
If any serious problems were discovered during the audit, they should be
resolved by discussions with the Project Officer and the Regional EPA Office
that requested the audit as soon as possible.
19
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SECTION 5
AUDIT COMPLETION
OVERVIEW
The audit is completed by comparing the findings of the site visit with
the project requirements and documenting the results in a written report.
REPORT PREPARATION
Each team member should write a report on his findings and include a copy
of his completed checklists. The report is then assembled into a consensus
document by the Team Leader and reviewed by the Audit Program Manager. After
revisions, the final report, signed by the Team Leader and approved for
distribution by the Program Manager, is released to the office requesting the
audit and to the sampling Project Officer.
The cover page of the report should be similar to that shown in Figure 4
(USEPA 1983). The report should contain a summary of observations in the
following areas:
Sampling activities and documentation
Sampling Bank activities and documentation
QA problems
Follow-up on previous recommendations
Summary
The last section should present conclusions and recommendations. The
complete checklists should be attached as an appendix.
CORRECTIVE ACTION
The report should clearly Identify the points which require corrective
action. These should be in the form of recommendations made to the Office
requesting the audit.
Follow-up
If follow-up is desired by the EPA Regional Officer, a schedule can be
discussed between the Audit Program Manager and the Regional Office, and then
approved by the appropriate Agency Office or Laboratory Director.
20
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AUDIT REPORT
Project Name:
Audit Date:
Audit Team:
(Name, Affiliation)
Project Personnel Contacted
Project Officer:
Other Personnel:
(Names, titles,
affiliations)
Signatures/Date
Team Leader:
Audit Program Manager:
Figure 4. Cover page of audit report.
21
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REFERENCES
American Society fox Testing and Materials. 1983. Water and environmental
technology. Pesticides: resource recovery; hazardous substances and oil
spill response; waste disposal; biological effects. Annual Book of ASTM
standards, Section II, Vol. 11.04. pp. 263-264.
Barth DS, Mason BJ. 1984. Soil sampling quality assurance guide.
Environmental Monitoring Systems Laboratory, Las Vegas, Nevada. EPA
600/4-84-043.
Brown KW, Hern SC. 1983. Monitoring support procedures for methods of
validation. Sampling and sample bank audit. Memorandum to E. Paul Richett,
Jr. Environmental Monitoring Systems Laboratory-Las Vegas: U.S.
Environmental Protection Agency.
deVera ER, Simmons BP, Stephens RD, Storm DL. California Dept. of Health
Services. 1980. Samplers and sampling procedures for hazardous waste
streams. Cincinnati, Ohio: Solid and Hazardous Waste Research Division,
Municipal Environmental Research Laboratory. U.S. Environmental Protection
Agency. Grant No. R804692010.
Ford PJ, Turina, PJ, Seely, OE GCA Corp. GCA Technology Div. 1983.
Characterization of hazardous waste sitesa methods manual, second edition,
Vol. II. Las Vegas, Nevada: Advanced Monitoring Systems Laboratory,
Environmental Monitoring Systems Laboratory. U.S. Environmental Protection
Agency. Contract No. 68-03-3050.
Hart FC Associates, Inc. 1981. RCRA Inspection Manual. Washington, DC:
Office of Solid Waste and Emergency Response, U.S. Environmental Protection
Agency. WA 83-A001.
JRB Associates Inc.. Undated. Training manual for hazardous waste site
investigations. Washington, DC: U.S. Environmental Protection Agency.
Mason, BJ. Ethura. 1983. Preparation of soil sampling protocol: techniques
and strategies. Las Vegas, Nevada: Exposure Assessment Research Division.
U.S. Environmental Protection Agency. EPA-600/4-83-020.
Smith RL. 1966. Ecology and Field Biology. New York: Harper and Row.
Southwood TRE. 1968. Ecological methods with particular reference to the
study of insect populations. London: Methuen & Co. LTD.
USEPA. 1973. United States Environmental Protection Agency. Biological
field and laboratory methods for measuring the quality of surface water and
effluents. Cincinnati, Ohio: National Environmental Protection Agency. EPA
670/4-73-001.
22
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USEPA. 1976. U.S. Environmental Protection Agency. Quality assurance
handbook for air pollution measurement systems. Research Triangle Park, NC:
Environmental Monitoring and Support Laboratory. EPA-600/9-76-005.
USEPA. 1977. U.S. Environmental Protection Agency. Procedures manual for
groundwater monitoring at solid waste disposal facilities. Washington, DC:
Office of Water and Waste Management, U.S. Environmental Protection Agency.
EPA/530/SW-611.
USEPA. 1979. U.S. Environmental Protection Agency-National Enforcement
Investigation Center. Safety Manual for Hazardous Waste Site Investigations.
September 1979.
USEPA. 1980. U.S. Environmental Protection Agency. Test methods for
evaluating solid and hazardous waste, physical/chemical methods. Washington,
DC: Office of Water and Waste Management, U.S. Environmental Protection
Agency. SW-846.
USEPA. 1980. U.S. Environmental Protection Agency. Health and safety
requirements for employees engaged in field activities. Washington, DC. EPA
Order 1440.2.
USEPA. 1980s. U.S. Environmental Protection Agency. Office of Research and
Development. Interim guidelines and specifications for preparing quality
assurance project plan. QAMS-005/80.
USEPA. 1980b. U.S. Environmental Protection Agency, National Enforcement
Investigation Center. Enforcement considerations for evaluations of
uncontrolled hazardous waste disposal sites by contractors. Draft. Denver,
Colorado: National Enforcement Investigations Center. U.S. Environmental
Protection Agency. WA83-A001.
USEPA. 1983. U.S. Environmental Protection Agency. On-site sampling
evaluation from monitoring support procedures for method validation, Prickly
Pear Creek, Montana. Environmental Monitoring Systems Laboratory: Las Vegas,
Nevada.
USEPA. 1984a. U.S. Environmental Protection Agency. Documentation of
EMSL-LV contribution to the Kellogg Idaho study. Environmental Monitoring
Systems Laboratory: Las Vegas, Nevada. EPA 600/X-84-052.
USEPA. 1984b. U.S. Environmental Protection Agency. FY "84" Occupational
Medical Guldlelines. Occupational Health and Safety Division.
Washington, DC.
23
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APPENDIX
SAMPLING AUDIT CHECKLIST FOR
RCRA/CERCLA ACTIVITIES
I. GENERAL INFORMATION
Audit Dates: __/_/__ to / /
Arrival Time: D a.m. D p.m.
Departure Tine: D a.m. D p.m.
Facility/Site Information
Facility/Site Name:
Facility/Site Address or Location:
Facility/Site Telephone No.: ( ) - D N/A(a)
Facility Contact (Name/Title):
DN/A
Function/Description of Facility/Site:
Treatment/Storage/Disposal (TSD) Processes/Units at Facility/Site:
G Container D Landfill
D Tank G Land Application
D Waste Pile D Surface Impoundment
D Incinerator D Non-regulated
Disposal (spill,
dump, etc.)
D Other (describe)
(a) Not applicable or not available.
24
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Media Being Sampled:
D Waste-Liquid D Waste-Slurry
D Waste-Solid D Waste-Gas
D Soil D Groundwater
D Surface Water D Other (describe)
Sampling Team Information
Team Contact (Name/Title/Affiliation):
Team Members (Name/Title/Affiliation)
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
Team Contact Telephone No.: ( )
Team Contact Address:
Brief Description of Sampling Team Efforts/Objectives:
25
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Audit Team Information
Team Leader (Name/Title/Affiliation):
Team Members (Name/Title/Affiliation):
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
26
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II. SAMPLING PLAN
1. Is a Sampling Plan available for review? D Yes D No
Comments:
2. Does the Sampling Plan discuss the objectives of the sampling program to
be performed and how the sampling approach(es) will satisfy program
requirements? D Yes G No
Comments:
3. Are levels of precision and confidence levels Identified in the Plan?
D Yes D No
Comments:
4. Does the Plan describe the system to be used for identifying, logging and
tracking all samples obtained? D Yes D No
Summarize the tracking system below under Comments.
Comments:
5. Are criteria used to select sampling methods, including sampling
equipment and procedures discussed in the Sampling Plan? D Yes D No
Comments:
27
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6. Is a discussion of the limitations of each sample method presented?
D Yes D No D N/A
Comments:
7. Does the Plan identify criteria used for selecting the media (e.g., soil,
groundwater, wastes, etc.) to be sampled? D Yes D No
Comments:
Does the Sampling Plan identify criteria used for selecting sampling
points for each type of unit (e.g., containers, tanks, waste piles,
surface impoundment, etc.)? D Yes D No
Comments:
9. Does the Sampling Plan provide detailed protocols, identifying the size,
number, locations, and types of samples to be collected? D Yes D No
Comments:
10. Does the Plan describe procedures for and the extent of compositing or
other sample reduction methods? D Yes D No
Comments:
28
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11. Are the types of sample containers and methods and materials used to
clean these containers identified in the plan? D Yes D No
If Yes. is the method of cleaning appropriate? D Yes D No
Comments:
12. Are there separate cleaning procedures for sample containers used for
organic and inorganic samples? D Yes D No
Comments:
13. Are field decontamination procedures and materials for sampling equipment
discussed in the Plan? D Yes D No
Comments:
29
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III. SAMPLING EQUIPMENT/MATERIALS
A. General
1. Is sampling equipment maintained on regularly scheduled basis?
D Yes D No
If Yes, is this schedule documented? D Yes D No
Comments:
2. Is sampling equipment inspected prior to each use for defects, proper
operation and where applicable calibration? D Yes D No
Comments:
3. Are calibration methods identified? D Yes D No D N/A
Comments:
4. Are records or logs kept identifying:
D Equipment inspection dates? D Inspection results?
D Inspector's name? D Corrective actions taken?
Comments:
30
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5. Are glass containers with Teflon-lined screw caps used to collect the
following types of samples:
a. Water samples for organic analyses? O Yes D No
b. Soil and sediment samples? . D Yes D No
c. Liquid and solid hazardous waste samples? D Yes D No
Comments:
6. Are polyethylene bottles with solid polyethylene or polyethylene-lined
caps used to collect the following types of samples:
a. Water samples for metal analysis? D Yes D No
b. Water samples for pH and fluoride analysis? D Yes D No
c. Water samples for cyanide analysis? D Yes D No
7. Are amber glass or aluminum foil-wrapped glass bottles used for samples
suspected of being photosensitive? D Yes D No
Comments:
8. Are equipment decontamination methods and materials described in the
Sampling Plan practiced in the field? D Yes D No
Comments:
9. Is all sampling equipment constructed of materials that are compatible
with the wastes being sampled? D Yes D No
(a) Highly alkaline wastes and wastes known to contain hydrofluoric acid
should be collected in plastic containers. If it is suspected that highly
alkaline materials or hydrofluoric acid is present, a small sample should
be tested to determine if it reacts with the sample container.
31
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10. Where the nature and identity of the sample(s) material is unknown, is
the compatibility of the sample material and sampler material tested
prior to obtaining a sample? D Yes D No D N/A
Comments:
11. Is any of the equipment plated or painted? D Yes D No
Comments:
12. Are mixing containers and tools completely decontaminated or replaced
prior to mixing the next sample? D Yes D No
If decontaminated, are decontamination methods adequate? D Yes D No
Comments:
13. Where the presence of ignitable materials is suspected are sampling
equipment and devices being used spark and/or explosion-proof?
D Yes D No
Comments:
B. Waste Sampling
1. Are wastes being sampled at this site? D Yes D No
If No, go to Subsection C.
Comments:
2. Identify the sampling device(s) used for sampling drums:
D Glass tubing
D Composite Liquid Waste Sampler (COLIWASSA)
D Drum pump or other pump system (describe below)
32
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D Syringe
D Remote hydraulic penetrating sampler
D Other (describe below)
Comments:
3. Identify the sampling device(s) used for sampling tanks:
D COLIWASSA
D Tank Valves
D Pump system (describe under Comments)
D Weighted bottle sampler
D Van Dorn/Nansen bottle
D Kemmerer bottle
D Other (describe under Comments)
Comments:
4. Identify the sampling device(s) for waste pile sampling:
D Scoop/spatula
D Auger
D Core sampler
D Sample trier
D Other (identify under Comments)
Comments:
5. Is the sampler being used to sample waste piles at least twice the
diameter of the largest solid particles in the waste pile? D Yes D No
Comments:
6. Identify the sampling device(s) used to sample liquids from surface
impoundments, lagoons, pits, ponds, etc.:
33
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D Pond sampler D Weighted sample bottle
D Van Dorn/Nansen bottle D COL1WASSA
D Kemmerer water bottle D Other (describe under Comments)
D Air lift sampler
Comments:
Identify the sampling device(s) used to sample sludges from tanks,
surface impoundments, lagoons, pits, ponds, etc.:
D Eckman, Peterson or Smith-Mclntyre grab samplers
D Core sampler
D Other (identify under Comments)
Comments:
C. Soil Sampling
1. Is soil being sampled at this site? D Yes D No
If No, go to Subsection D.
Comments:
2. Identify the sampling device(s) used for soil sampling:
D Scoop/spatula/shovel
D Soil auger
D Core sampler
D Other
Comments:
3. Is any soil or sludge sampling equipment plated or painted? D Yes D No
Comments:
3A
-------
4. Does the plating or paint material contain any of the metals and/or
organics to be analyzed for in the sample? D Yes D No
Comments:
D. Groundwater Sampling
1. Is groundwater being sampled at this site? D Yes D No
If No, go to Subsection E.
2. Identify the sampling device(s) used for groundvater sampling:
D Manual bailer D Submersible pump
D Air-lift sampler G Eductor pump
D Peristaltic pump D Other (identify and describe under Comments)
Comments:
3. What are the materials of construction (MOC's) for the well casing?
4. What are the MOC's for the well screen?
5. Do the MOC's potentially interfere with or jeopardize analytical results
obtained on the groundwater? D Yes D No
Comments:
6. Is the device(s) used to measure well depth and depth to the water level
thoroughly cleaned prior to use in another well? D Yes D No
If Yes, how is it cleaned?
Comments:
35
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7. Are sampling pumps serviced and calibrated after each use? D Yes D No
If Yes, are maintenance and calibration records available for
verification? D Yes D No
Comments:
8. Are pump parts and attachments that will come Into contact with wastes
made of compatible materials? D Yes D No
Comments:
9. Are all pumps checked for proper operation prior to use? D Yes D No
10. During sampling are pumps run at the same rate or within the range of
which they were calibrated? D Yes D No
Comments:
E. Air Sampling
1. Is air being sampled at this site? D Yes D No
If No, go to Subsection F.
2. Identify the sampling device(s) used for air sampling:
D Oxygen indicators D Detector tubes
D Combustible gas detectors D Solid sorbent cartridges/pump
D Hydrocarbon analyzers D Other (identify and describe under
(identify detector type Comments)
(e.g., flame ionization,
infrared, photoionization,
etc.) under Comments)
Comments:
3. Are instruments cleaned, serviced and calibrated after each use?
D Yes D No
36
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If Yes, are maintenance and calibration records available for
verification? D Yes D No
Comments:
4. Are instruments calibrated at the temperature of intended use?
D Yes D No
Comments:
5. Is all equipment checked for proper operation prior to use? D Yes D No
Comments:
6. Are detector solutions for oxygen meters replaced with the frequency
specified by the manufacturer? D Yes D No
Comments:
7. Are Instrument batteries checked for full charge prior to each use?
D Yes D No
Comments:
8. Are instruments allowed to warm up prior to use? D Yes D No
9. Are oxygen meters calibrated against fresh air? D Yes D No
If No, what is used for calibration?
Comments:
37
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10. Are combustible gas meters zeroed in combustible gas-free ambient air?
D Yes D No D N/A
Comments:
11. If calibrated with a specific gas, are differences in the combustible
limits of other gases that may be encountered taken into consideration
when recording results (e.g., conversion tables may be available to
obtain the low explosive limits (LEL) for combustible gases other than
the one used for calibrating)? D Yes D No D N/A
Comments:
12. For combustible gas meters with a non-adjustable calibration control, is
a calibration curve prepared and applied? D Yes D No D N/A
Comments:
13. If in-line filters are used in hydrocarbon detectors, are the frequency
of cleaning and cleaning procedures discussed in the Sampling Plan?
D Yes D No
If No, briefly describe the frequency and procedures below.
Comments:
Are gas concentrations measured within the limits of the calibration
curve? D Yes D No If No, how are these data treated?
Comments:
38
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14. If solid sorbent cartridges are used to collect air samples and are not
prepacked, are the cartridges thoroughly cleaned prior to packing the
sorbent? D Yes D No
Are the cleaning procedures described in the Sampling Plan? D Yes D No
Comments:
15. Has the solid sorbent being used been selected for its efficiency in
collecting the desired contaminant(s)? D Yes D No
Is the applicability of the sorbent in regard to the contaminant(s)
referenced? D Yes D No
16. If the solid sorbent cartridges are not obtained prepacked, are
procedures for cleaning and conditioning the solid sorbent documented?
DYes DNo
Comments:
17. If sampling pumps are used, are they calibrated prior to each use?
D Yes D No
If Yes, is the calibration method documented? DYes DNo
Comments:
18. Are calibration records for pumps available? D Yes D No
Comments:
19. If polyurethane foam (PUF) is used as a collection media has it been
thoroughly cleaned by Soxhlet extraction using high-grade hexane prior to
use? D Yes D No
Comments:
39
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F. Biota Sampling
Plankton
1. Identify the type of sampling device(s) used for collecting phyto- and
zooplankton:
D Kemmerer bottle D Pump
D Van Dorn/Nansen sampler D Net
D Jarday sampler D Other (identify and describe under
Comments)
Comments:
Periphyton
1. Identify the type of sampling device(s) used for sampling periphyton:
D Artificial substrate sampler (glass or plexiglass slides, contained
rocks, etc.)
D Scraper (knife, spatula, etc.)
D Other (identify under Comments)
Comments:
Macrophytes
1. Identify the type of sampling device(s) used for sampling macrophytes:
D Rake D Manual
D Ekman dredge D Other (identify under Comments)
D Petersen dredge
Comments:
Macroinvertebrates
1. Identify the type of sampling device used for macrolnvertebrate sampling:
D Ekman dredge D Petersen dredge
D Smith-Mclntyre D Core sampler
-------
D Ponar grab D Artificial substrate sampler
D Drift nets D Other (identify under Comments)
Comments:
Fish
1. Identify the type of sampling device used for macrolnvertebrate sampling:
D Seining D Chemical poisoning D Other (identify and
D Trawling D Gill/trammel nets describe under Comments)
D Electroshock D Hoop/trap nets
Comments:
Vegetation
1. Are vegetative samples collected for analysis? D Yes D No
Are vegetative subsamples composited? D Yes D No
Comments:
2. What sampling approach is used to sample vegetation:
D Quadrats D Variable plot method
D Transects D Random pairs method
D Loop method D Quarter method
Comments:
3. Does the sampling approach used satisfy the goals of the study?
D Yes D No
41
-------
Comments:
4. Are the species of plants collected for analyses recorded in the logbook?
D Yes D No
Comments:
5. Is the exact location of each vegetative sample collected noted in the
logbook? D Yes D No
Comments:
6. Are the parts of each plant (e.g., root, leaves) collected for analysis
identified in the logbook? D Yes D No
Comments:
7. Is care taken to prevent contamination of vegetative samples by other
media (e.g., soil) and improper handling (i.e., collection without use of
clean disposable gloves)? D Yes D No
Comments:
8. Are vegetative samples thoroughly rinsed with distilled deionized water
prior to analysis to remove any potentially contaminated media?
D Yes D No
Comments:
-------
9. Are vegetative samples placed in clean polyethylene containers?
D Yes D No
Comments:
10. Are all samples properly tagged and labeled? D Yes D No
Comment s:
Mammals
1. Are mammals collected for tissue analysis? D Yes D No D N/A
If Yes, identify types under Comments.
Comments:
2. Are traps used to collect the animals? D Yes D No
If not, how are animals collected?
Comments:
3. Are trapping designs identified?
D In a grid system
D Parallel lines
D Hexagonal layout
D Other (describe under Comments)
Comments:
43
-------
4. Is the distance between trapping stations identified? D Yes D No
Comments:
5. Are the number of traps set at each station identified and in place?
D Yes D No
Comments:
6. At a minimum, is the following information entered in the logbook?
IH Date
D Station number and location
D Species caught
D Sex of each animal
D Animal is adult or juvenile
7. Is the time and duration of the trapping program identified? D Yes D No
Comment s:
44
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IV. SAMPLING APPROACH/METHODOLOGY
A. General
1. The sampling approach specified and utilized for each media and/or unit
is identified as:
Media/Unit
Sampling Approach
Staple Random
Stratified Kandoa
Syatematlc
Judgmental
Waste
Conidlncrb
Tanks
Surface
or LiRoone
Waace
Pile
Land
Treatment
Soil
Ground-
Water
Air
Ambient
Contained
Biota
Comments:
2. Were approaches identified in the Sampling Plan employed in the field?
D Yes D No
Comments:
3. Are specified sampling equipment being utilized? D Yes D No
Comments:
4. Where composite samples are taken, are they mixed thoroughly as specified
to yield a homogeneous sample? D Yes D No
Comments:
45
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5. Is care taken to ensure equal sample sizes or alternatively are samples
properly weighted when individual samples are composited? D Yes D No
DN/A
Comments:
6. Is each sampling device thoroughly decontaminated prior to collecting the
next sample? D Yes D No
If not, is an unused, clean sampling device used to collect each sample?
D Yes D No
Comments:
Are disposable sampling devices/containers that have been contaminated
disposed of properly (i.e., left in the containerized waste or placed in
plastic bags for later disposal)? D Yes D No
Comments:
8. Where applicable, are sample collection containers rinsed once with the
sample material prior to collection? D Yes D No
Comments:
9. If metal devices are being used for sampling drums, tanks or other metal
storage or process vessels where ignitable substance may be present, are
they being properly grounded? D Yes D No
10. Are sample containers capped immediately following collection of the
sample? D Yes D No
Comments:
46
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11. Are liquid sample containers filled with sample to at least 90 percent
capacity? D Yes D No
Comments:
B. Wastes
1. For waste sampling, has an effort been made to use disposable sampling
devices where possible? D Yes D No
2. When sampling containers containing waste liquids, is the sample obtained
through a top or side bung opening? D Yes III No D N/A
If No, describe sampling procedure under Comments.
Comments:
If a sample is taken from a side bung opening, are the drum contents
gently mixed so that a homogeneous sample will be obtained? D Yes D No
D N/A (Note: This may not always be possible or advisable depending on
the drum contents.)
Comments:
Are representative, composite, storage tank samples obtained by
collecting and combining samples from at least three sections (e.g.,
upper, middle, lower) of the tank or by taking a verticle profile sample?
D Yes D No D N/A
When sampling barrels, fiberdrums, bags, etc., containing powdered or
granular wastes, are at least two samples taken by inserting the sampler
(grain sampler, sample trier, etc.) at one edge or corner and through the
center of the material to the edge or corner diagonally opposite the
point of entry? D Yes D No
Comments:
47
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6. When sampling surface impoundments, waste piles, or land treatment areas,
are all sampling points identified on maps or sketches? D Yes D No
Comments:
7. Are liquid samples poured into sample bottles in a manner that minimizes
turbulence? D Yes D No
Comments:
8. Is sufficient ullage allowed for liquid waste samples? D Yes D No
Comments:
9. When liquid waste samples are being taken, is the sampling device slowly
submerged to minimize disturbance of the waste? D Yes D No
Comments:
10. When sampling a waste pile, are samples taken by inserting the sampler
near the top of the pile at a 0-45 degree angle to a point diagonally
opposite the point of entry? D Yes D No
Comments:
11. Are the specified points near the top of the waste pile sampled and
composited? D Yes D No
Comments:
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12. If the waste pile consists of a solid mass or of primarily large chunks
of waste (i.e., < 3 ft), what sample collection methodology is used to
obtain a representative sample?
Comments:
13. Are any preservation methods other than refrigeration used for waste
samples other than surface or groundwater? D Yes D No
If Yes, is the preservation method applicable to one or two specific
components known to be present in the waste? D Yes D No
Comments:
C. Soils
1. Has a control area been selected? D Yes D No
Comments:
2. Does documentation exist showing that a control area if utilized exhibits
soil characteristics, depth to groundwater, vegetation type and other
characteristics similar to the sample area? D Yes D No
Comments:
3. Is the control area selected upwind from the sampling area? D Yes D No
Comments:
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When a soil auger is used, is a collection container also used to prevent
the ejected soil sample from contacting the surrounding ground?
D Yes D No
Comments:
S. Is the depth to which each soil sample is taken logged in the field
logbook or on a data sheet? D Yes D No
Comments:
Is the exact location of each soil sample identified and logged in the
field notebook? D Yes D No. Describe under Comments the method used to
identify sampling point locations.
Comments:
7. Are approximate soil sampling locations identified on a sketch of the
site drawn in the field log book or on data sheets? D Yes D No
Comments:
8. If contaminant concentrations are desired at specific soil depths, what
sampling techniques are used and precautions taken to prevent cross-
contamination between the soil levels?
Comments:
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9. When soil samples are composited, are they mixed as specified?
D Yes D No
Comments:
10. Are samples of rinse water, solvents or other materials used for
decontamination taken periodically and analyzed for possible
contamination? D Yes D Mo
Comments:
11. Are soil and bottom sediment samples properly preserved? D Yes D No
Comments:
12. Are equipment swipes and/or rinses taken periodically and analyzed to
check for complete decontamination? D Yes D No
Comments:
13. Are replicates (duplicates or triplicates) taken as specified?
D Yes D No
Comments:
14. To establish baseline values, is the number of samples collected and
their sampling location within the control area being completed as
specified in the Sampling Plan? D Yes D No
Comments:
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15. For each subsurface soil sample, is a boring or core log completed?
D Yes D No
Comments:
16. Does the log contain the following:
D Soil types and corresponding depth and thickness
D Soil structural changes
D Presence of anomalies (e.g., rock, sand and gravel lenses, root
channels, animal burrows, etc.)
D Other (specify under Comments)
Comments:
D. Groundwater and Surface Water
1. Are the following preservatives used for surface or groundwater samples:
Measurement Preservative Yes No N/A
Nitrogen forms
Phosphorous forms (hydrolyzable)
Metals
Organic samples (COD, oil and
grease, organic carbon)
Ammonia, amines
Cyanides, organic acids
Acidity-Alkalinity
Organic materials
BOD
Color
Odor
Organic phosphorus
Organic nitrogen/carbon
Biological organisms (e.g.,
colifonn)
Other
H.SO, to pH2 D D D
H,SO; to pH2 D D D
Nitric acid (HNO ) D D D
Sulfuric acid (HpO^) D D D
H SO, D D D
Sodium hydroxide (NaOH) D D D
Refrigeration D D D
Refrigeration D D D
Refrigeration D D D
Refrigeration D D D
Refrigeration D D D
Refrigeration D D D
Refrigeration ODD
Refrigeration D D D
Comments:
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2. Are at least 3-5 volumes of water in each groundwater monitoring well
casing evacuated prior to collecting a sample? D Yes D No
If not, how many volumes are evacuated?
3. For monitoring wells that can be evacuated to dryness, is the well
allowed to recover completely prior to withdrawing a sample? D Yes D No
Is a measurement taken to verify this? D Yes D No
Comments:
4. For monitoring wells that cannot be evacuated to dryness, is a minimum of
4-5 volumes of water pumped from the well at a rate equal to the well's
recovery rate? D Yes D No
Comments:
5. Have the specified number of groundwater monitoring wells been installed
downgradient and upgradient of the land storage, disposal, and treatment
sites? (e.g., landfills, surface impoundments, land treatment areas and
waste piles) D Yes D No D N/A
Comments:
6. Are the monitoring wells located as specified? D Yes D No D N/A
Comments:
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7. When a sample is transferred from the sampler to a sample bottle, is care
taken to minimize sample agitation and contact with air? D Yes D No
Comments:
8. Is the sampler thoroughly rinsed with tap water and then with the first
sample from the next well prior to collecting the sample for analysis?
D Yes D No
Comments:
9. Have the specified number of samples been taken to determine background
values? D Yes D No
Comments:
10. Is the volume of liquid in the well (i.e., bore-hole volume) calculated
prior to purging? D Yes D No
Comments:
11. If pumps are used for purging and sample collection are they thoroughly
cleaned prior to use in another well? D Yes D No D N/A
12. Are any methods used to verify that well purging is complete?
D Yes D No
If Yes, describe.
Comments:
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13. If a pump is used to collect the sample, is an effort made to withdraw
the sample at approximately the same rate as the well refills (i.e.,
aquifer transmission rate)? D Yes D No D N/A
Comments:
E. Air
Is the flow rate established during calibration of pumps and/or
Instruments marked on the rotameter and/or recorded on sampling data
sheets for later reference during actual sampling? D Yes D No
Comments:
2. Is the calibration flow rate maintained during sampling? D Yes D No
Comments:
3. Are calibration and actual sampling conditions within the following
ranges of each other:
Condition and Range Yes Np_
Temperature ±15°C D D
Barometric pressure ±10 mm Hg D D
Comments:
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4. If used, are sample cartridges protected from exposure to sunlight prior
to and after sample collection? D Yes D No
If Yes, note method.
Comments:
5. Are sample cartridges packed in coolers and stored at 4°C prior to
analysis? D Yes D No
Comments:
6. Are sample cartridges analyzed within the holding time specified in the
sampling plan? D Yes D No
Comments:
7. Do compounds sampled using polyurethane foam have vapor pressures less
than 1 mm (Hg) at 20°C? D Yes D No
Comments:
8. At a minimum, is the following information recorded on a sample sheet or
in a sample log book at the start and end of the sampling period?
D Name of sampler
D Start & stop
times/dates
D Counter reading
Comments:
D Blank number
D Cartridge number
or filter
D Pump/sampling
apparatus number
D Barometric pressure
D Ambient temperature
D Relative humidity
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When sampling streams, are sampling points located as specified (i.e., on
both sides of the stream upstream and downstream of stretches suspected
of contamination)? D Yes D No
Comments:
2. If specified, are all sampling points located in the main channel out of
backwater areas? D Yes D No
Comments:
Plankton
1. Has the following information been determined in conjunction with
plankton sampling efforts:
D Flow volumes D Water temperatures
D Current velocity, direction D Turbidity
D Prevailing wind direction
Comments:
2. Is the frequency of sampling specified being adhered to? D Yes D No
Comments:
3. If specified, are sampling points in lakes located at various depths?
D Yes D No
Comments:
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4. Does the field log book contain at a minimum the following information on
samples:
D Weather information (temperature, wind direction and speed, etc.)
D Cloud cover
D Water surface condition
D Water color and turbidity
D Total depth at each sample station and depth at which sample was taken
D Sampling station locations
Comments:
5. Which of the following preservative(s) is used?
D Formalin (40% formaldehyde) neutralized with sodium tetraborate
G Merthiolate
D Other (identify under Comments)
Comments:
6. a. Are plankton concentrated prior to counting? D Yes D No
b. If Yes, what method is used for phytoplankton:
D Sedimentation
D Centrifugation
D Filtration
c. Identify the method used for zooplankton.
Comments:
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Periphyton
1. a. If scrape samples are taken for quantitative analysis, is the area
of the scrape carefully measured and recorded? D Yes D No D N/A
b. Is a minimum of 5-10 mL of scrapings collected? D Yes D No
Comments:
2. Are samples stored in pre-cleaned glass containers? D Yes D No
Comments:
3. If chlorophyll analyses are to be performed, are samples stored at A°C
and protected from light sources? D Yes D No D N/A
Comments:
4. Identify the preservative used:
D 1-5% Acid-Lugols
D 5% formalin
D Other (identify under Comments)
Comments:
5. Are the depths at which samples are collected consistent at each sampling
station? D Yes D No
6. Is care taken to ensure that the size of the area sampled is the same for
each sample? D Yes D No
Comments:
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7. Are triplate samples being taken at each sampling site? D Yes D No
If Yes, are the samples composited? D Yes D No
Comments:
8. Are samples to be used for tissue analysis stored at 4°C up until the
time they are analyzed? D Yes D No
Comments:
9. When artificial substrates are used, are they exposed for at least two
(2) weeks? D Yes D No D N/A
Comments:
Macrophyton
1. Is sampling quantitative or qualitative?
Comments:
2. Are wet and dry particle size analyses of the inorganic components
conducted on one or more samples from each sampling site? D Yes D No
Comments:
3. Is the depth at which each sample is collected measured and recorded?
D Yes D No
Comments:
If specified, is the current velocity at each sampling site determined
and recorded? D Yes D No
Comments:
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5. a. Are samples to be used for tissue analysis placed in glass
containers and frozen until analysis as specified? D Yes D No
Comments:
b. Are all other samples preserved properly? D Yes D No
Comments:
6. When collected samples are sorted, are total numbers of organisms being
estimated? D Yes D No
Comments:
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V. PACKAGING, LABELING, TRANSPORT
1. Are waste samples, whose chemical identity is known (e.g., discarded
commercial products), labeled, packaged and shipped according to the
hazardous waste classes identified in the 49 CFT 172.101, Hazardous
Materials Table? D Yes D No D N/A
Comments:
2. a. Are all non-gaseous hazardous waste samples not considered
environmental samples (e.g., off-site samples of low contamination
potential) and not taken from closed containers labeled as
"Flammable Liquid (or Solid) N.O.S."? D Yes D No D N/A
b. Are these sample containers placed in a plastic bag and then sealed
in a metal can surrounded by a noncombustible and nonreactive
absorbent? G Yes D No
c. Does each metal can bear labels with the following marking?
Yes No
"Flammable Liquid, N.O.S." or "Flammable Solid, N.O.S." D D
Testing laboratory name and address and return address D D
"Cargo Aircraft Only" D D
"Flammable Liquid" or "Flammable Solid" D D
"Dangerous When Wet" D D
d. Is the metal can, in turn, placed in a large container (e.g.,
cooler, fiberboard box) and packed with noncombustible and
nonreactive absorbent? D Yes D No
e. Does the larger shipping container bear the following labels and
markings ?
Yes N£
All labels placed on the shipping cans D D
"Laboratory Samples" D D
"This End Up" with arrows on all four sides pointing G G
in the appropriate direction
Comments:
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3. a. Are unidentified samples, obtained from closed containers or tanks,
labeled, packaged and shipped as DOT Poison A material?
D Yes D No D N/A
b. Are sample containers with wastes classified as DOT Poison A
materials packaged in DOT Spec. 3A1800 or 3AAA1800 metal compressor
gas cylinders? G Yes D No
c. Are sample containers packed in the metal cylinders, surrounded by
incombustible, absorbent, packaging material? D Yes D No
d. Is a tag wired to the cylinder valve protector or a label affixed to
the cylinder that is marked with "Poisonous Liquid N.O.S." and the
laboratory name and address and return address? D Yes D No
e. Is a separate label, marked "Poisonous Gas," also affixed to the
cylinder? D Yes D No
f. If metal cylinders are placed into the same shipping container, does
the container bear the following labels and markings:
D All labels/markings placed on the enclosed metal cylinders
D "Laboratory Samples" and "Inside Packages Comply with Prescribed
Specifications" marked on top of the container
D "This End Up" on the top of the container with arrows on all four
sides pointing in the appropriate direction
Comments:
4. Does packaging of environmental samples meet the following criteria:
D All sample containers are placed in a strong outside shipping container
capable of containing any leaks from sample containers.
G Ice is put into a plastic bag before being placed in the outside
shipping container.
G The lids of all sample containers are screwed on tightly and taped
closed or are placed in a plastic bag which is taped tightly to close.
G Glass containers are packed with an inert, absorbent packing material
in a manner to prevent contact with other glass containers.
Comments:
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5. Is sufficient ullage (approximately 10% by volume) allowed in sample
containers with liquids? D Yes D No D N/A
Comments:
6. Unidentified samples (e.g., DOT Poison A classified) are transported by:
D Common, public or commercial ground carrier
D Government aircraft
D Other (identify under Comments)
Comments:
7. When shipping hazardous samples, are bills of lading or manifests marked
with the following information?
D "Flammable Liquid (or Solid), N.O.S." (not otherwise specified) or for
unidentified samples from closed containers or tanks, "Poisonous
Liquid, N.O.S."
D "Net Weight" or "Net Volume" by item
D "Cargo Aircraft Only"
D "Limited Quantity"
D "Laboratory Samples"
Comments:
Are arrangements made prior to the start of sampling to ship samples to
the laboratory for analysis so that recommended holding times are not
exceeded? D Yes D No
Comments:
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VI. QUALITY ASSURANCE/QUALITY CONTROL
A. Sample Documentation and Chain-of-Custody
1. Is the following information being recorded in the field log book or on
data sheets?
D Project Name and Project Number
D Purpose of sampling (e.g., quarterly sampling, resample to confirm
previous analysis, initial site assessment, etc.)
D Date and time each sample was collected
D Date and starting/stopping times (Hr:Min) for air samples
D Date and well bailing time for groundwater
D Blank, duplicate and split sample identification numbers
D Sample description including type (i.e., soil, sludge, groundwater,
etc.)
D Field measurement results (i.e., conductivity, pH, dissolved oxygen,
combustible gas (e.g., LEL), radioactivity, etc.)
D Preservation method for each sample
D Type and quantity of containers used for each sample
D Weather conditions at time of sampling
D Photographic log identifying subject, reason for photograph, date,
time, direction in which photograph was taken, number of the picture on
the roll
D Sample destination
D Analyses to be performed on each sample
D Reference number from all forms on which the sample is listed or labels
attached to the sample (i.e., chain-of-custody, bill of lading or
manifest forms, etc.)
D Name(s) of sampling personnel
D Signature of person(s) making entries on each page
Comments:
2. Is a chain-of-custody record completed for all samples collected?
D Yes D No
Comments:
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3. Is the following information completed on each chain-of-custody record?
D Sample Identification number
D Sample collector's signature
D Date and time of collection
D Place and address of collection
D Waste sample description
D Shipper's name and address
D Name and address of organization(s) receiving sample
D Signatures and titles of persons involved in chain-of-possession
D Inclusive dates of possession for each possession
Comments:
4. Does a sample analysis request sheet accompany all samples on delivery to
the laboratory sample custodian (sample bank)? D Yes D No
Comments:
5. At a minimum, has the following information been completed on each sample
analysis request sheet?
D Name of person receiving sample (sample custodian)
D Laboratory sample number
D Date of sample receipt
D Sample allocation
D Analyses to be performed
D Collector's name, affiliation name, address and phone number
D Date and time of sampling
D Location of sampling
D Special handling and/or storage requirements
6. Has a field custodian been assigned for sample recovery, preservation and
storage until shipment? D Yes D No
Comments:
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B. Sample Bank Operations
1. lias a sample custodian been assigned to receive all samples? D Yes D No
Comments:
2. Does the custodian carefully inspect the condition of sample containers
and/or packages upon receipt? D Yes D No
Comments:
3. If damaged or leaking containers and/or packages are received, is this
fact documented in a log book or on a data sheet? D Yes D No
Comments:
4. a. Are sample containers and/or packages inspected to see if the sample
seal is intact? D Yes D No
b. If the seal is broken, is the information recorded in the log book
or on a data sheet? D Yes D No
c. Describe the recourse taken when sample containers or packages with
broken seals are received.
Comments:
5. a. Does the sample custodian check to ensure that the information
(I.e., sample number) on the sample label and seal match that on the
chain-of-custody record? D Yes D No
b. If discrepancies are found between the label or seal and the
chain-of-custody record, what actions are taken to resolve the
problem?
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Comments:
6. Is a separate laboratory number assigned to each sample received?
D Yes D No
Is this number recorded in the log book along with the other information
describing the sample? D Yes D No
Comments:
7. Has a sample label or tag been applied to each sample container?
DYes DNo
Comments:
8. At a minimum, has the following information been completed on each sample
label or tag?
D Collector's name
D Date and time of collection
D Place of collection
D Sample number
9. Has a tamperproof paper seal been attached to each sample package not
secured by some other means in such a manner that the seal must be broken
when opening the package? G Yes D No
Comments:
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10. At a minimum, has the following Information been completed on each sample
seal applied to packages?
D Collector's name
D Date and time of sampling
D Sample number
Does this information match that provided on the sample label?
DYes DNo
Comments:
11. Are all samples stored in a clean and secure area? D Yes DNo
Comments:
12. Are samples stored in a way to maintain preservation? D Yes DNo
Comments:
13. Are sample holding time limitations satisfied? D Yes D No
Comments:
14. Do laboratory records demonstrate personnel transferring and receiving
samples in the lab? D Yes D No
Comments:
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C. Quality Control
1. Are any of the following QC samples being generated?
D Split sample
D Blank samples
D Field blank
D Reagent blank
D Sample bank blank (where applicable)
D Decontamination blank
D Spiked sample
D Duplicates
Comments:
2. For RCRA sites, are splits for all samples obtained offered to the owner
or operator? D Yes D No D N/A
Comments:
3. a. Are duplicates generated from composited samples? D Yes D No
b. If No, is care taken to obtain duplicates using identical methods,
under identical conditions, and at specified locations?
D Yes D No
Comments:
4. Are control samples collected by identical methods, under similar
conditions, and at the specified location? D Yes D No
Comments:
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VII. SAMPLING PERSONNEL
1. Are personnel performing on-site sampling operations those described in
the Sampling Plan? D Yes D No
If not, have replacement personnel been trained for the position they
have assumed? D Yes D No
Comments:
Indicate sampling team performance in the following areas observed during
the on-site audit. (NOTE: Identify poor work practices and violations of
protocol under comments.)
Work Practice Good Fair Poor
Sampling technique ODD
Protective equipment use ODD
Safety procedures D D D
Forbidden personal practices (e.g., smoking, D D D
eating in forbidden areas)
Equipment use/maintenance/calibration ODD
Comments:
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