OSWER Directive 9360.4-14
                                                       EPA 540/R-95/141
                                                           PB96-963207
                                                         December 1995
            SUPERFUND PROGRAM

REPRESENTATIVE SAMPLING GUIDANCE


                VOLUME 4:  WASTE

                    Interim Final
               Environmental Response Team

          Office of Emergency and Remedial Response
         Office of Solid Waste and Emergency Response

            U.S. Environmental Protection Agency
                  Washington, DC 20460

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                                               Notice
This document has been reviewed in accordance with U.S. Environmental Protection Agency policy and approved
for publication.

The  policies and  procedures established in this document are  intended solely for the guidance of government
personnel, for use in the Superfund Program. They are not intended, and cannot be relied upon, to create any rights,
substantive or procedural, enforceable by any party in litigation with the United States.  The Agency reserves the right
to act at variance with these policies and procedures and to change them at any time without public notice.

For more information on Waste Sampling procedures, refer to the Compendium ofERT Waste Sampling Procedures,
OSWER Directive  9360.4-07, EPA/540/P-91/008. Topics covered in this compendium include: sampling equipment
decontamination; drum sampling;  tank sampling; chip, wipe, and sweep sampling; and waste pile sampling.

Please note that the procedures in this document should only be used by individuals properly trained and certified
under a 40-hour hazardous waste site training course that meets the requirements set forth in 29 CFR 1910.120(e)(3).
It should not be used to replace or supersede any information obtained in a 40-hour hazardous waste site training
course.

Questions,  comments, and recommendations are welcomed regarding the Superfund Program Representative
Sampling Guidance, Volume 4 —  Waste.  Send remarks to:


                                       Mr. William A.  Coakley
                             Chairman, Representative Sampling Committee
                                           U.S. EPA-ERT
                                  Rantan Depot - Building 18, MS-101
                                       2890 Woodbridge Avenue
                                        Edison, NJ 08837-3679

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                                           Disclaimer


This document has been reviewed under U.S. Environmental Protection Agency policy and approved for publication.
Mention of trade names or commercial products does not constitute endorsement or recommendation for use.

The following trade names are mentioned in this  document:

Drager is a trademark of National Draeger, Inc. of Pittsburgh, Pennsylvania

Sensidyne is a trademark of Sensidyne, Inc.

MSA is a trademark of Mine Safety Appliance Company of Pittsburgh, Pennsylvania

Teflonฎ and Tyvekฎ are registered trademarks of E.I. DuPont de Nemours and Company of Wilmington, Delaware
                                                in

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                                         Contents


Notice	  ii

Disclaimer  	iii

List of Figures	 vii

List of Tables  	 vii

1.0  INTRODUCTION	   1

       1.1     OBJECTIVE AND SCOPE	   1
       1.2     CHARACTERISTICS OF WASTE	   1
       1.3     REPRESENTATIVE SAMPLING OBJECTIVES  	   1
       1.4     CONCEPTUAL SITE MODEL	  3
       1.5     EXAMPLE SITE	  5

2.0  SAMPLING DESIGN	  6

       2.1     INTRODUCTION	  6
       2.2     SAMPLING PLAN	  6
              2.2.1   Historical Data Review  	  7
              2.2.2   Site Reconnaissance	  7
              2.2.3   Physiographic and Other Factors	  7
       2.3     WASTE SAMPLE TYPES  	  7
              2.3.1   Grab Sample  	  7
              2.3.2   Composite Sample	  8
       2.4     WASTE TYPES 	  8
       2.5     WASTE CHARACTERISTICS	  9
              2.5.1   Homogeneity 	  9
              2.5.2   Physical State	  9
              2.5.3   Chemical Stability  	  9
              2.5.4   Particle Size (solids)  	  9
              2.5.5   Viscosity (liquids)  	  10
       2.6     WASTE SOURCES  	  10
              2.6.1   Containerized Waste  	  10
              2.6.2   Uncontainerized Waste  	  11
              2.6.3   Surfaces and Debris	  11
       2.7     QUALITY ASSURANCE CONSIDERATIONS  	  11
       2.8     DATA QUALITY OBJECTIVES	  12
       2.9     FIELD ANALYTICAL SCREENING AND GEOPHYSICAL TECHNIQUES  	  12
       2.10   ANALYTICAL PARAMETERS AND METHODS	  12
       2.11   REPRESENTATIVE SAMPLING APPROACHES  	  13
              2.11.1  Judgmental Sampling	  13
              2.11.2  Random Sampling  	  13
              2.11.3  Systematic Grid  Sampling	  14
              2.11.4  Systematic Random Sampling	  14
              2.11.5  Transect Sampling	  14
       2.12   SAMPLING LOCATIONS AND NUMBER 	  15
       2.13   EXAMPLE SITE	  16
              2.13.1  Background  	  16
              2.13.2  Site Entry	  16
              2.13.3  Site Inventory	  17
                                              IV

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               2.13.4  Selecting Analytical Parameters	  18

3.0  FIELD ANALYTICAL SCREENING AND SAMPLING EQUIPMENT	  20

       3.1     INTRODUCTION	  20
               3.1.1   Combustible Gas Indicator	  20
               3.1.2   Radiation Screening Instruments 	  20
               3.1.3   Flame lonization Detector  	  20
               3.1.4   Photoionization Detector	  21
               3.1.5   Colorimetric Tubes 	  21
               3.1.6   Hazard Categorization	  21
               3.1.7   Immunoassay Tests 	  22
               3.1.8   X-Ray Fluorescence	  22
               3.1.9   Gas Chromatograph	  22
       3.2     SAMPLING EQUIPMENT	  23
               3.2.1   Drum Openers 	  23
               3.2.2   Liquid Samplers	  23
               3.2.3   Sludge Samplers 	  24
               3.2.4   Solids Samplers	  25
       3.3     EXAMPLE SITE	  26
               3.3.1   Drum Screening and Sampling Equipment	  26
               3.3.2   Plating Vat Screening and Sampling Equipment 	  26
               3.3.3   Waste Pile Screening and Sampling Equipment	  26
               3.3.4   Impoundment Screening and Sampling Equipment 	  27
               3.3.5   Transformer Screening and Sampling Equipment	  27

4.0  FIELD SAMPLE COLLECTION AND PREPARATION	  29

       4.1     INTRODUCTION	  29
       4.2     SAMPLE VOLUME	  29
       4.3     SOURCE SAMPLING 	  29
               4.3.1   Drum Sampling 	  29
               4.3.2   Bulk Storage Tank and Transformer Sampling	  30
               4.3.3   Lab Pack Sampling 	  30
               4.3.4   Surface Impoundment Sampling  	  30
               4.3.5   Waste Pile Sampling 	  30
               4.3.6   Surface Sampling	  31
               4.3.7   Debris Sampling 	  32
               4.3.8   Compressed Liquid/Gas Cylinders	  32
       4.4     SAMPLE PREPARATION	  32
               4.4.1   Removing Extraneous Material 	  33
               4.4.2   Homogenizing	  33
               4.4.3   Splitting	  33
               4.4.4   Final Preparation 	  33
       4.5     EXAMPLE SITE	  34
               4.5.1   Source Sampling 	  34
               4.5.2   Sample Preparation 	  34

5.0  QUALITY ASSURANCE/QUALITY CONTROL  	  36

       5.1     INTRODUCTION	  36
       5.2     DATA CATEGORIES  	  36
       5.3     SOURCES OF ERROR	  36
               5.3.1   Sampling Design 	  36
               5.3.2   Sampling Methodology 	  37
               5.3.3   Sample Heterogeneity  	  37

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              5.3.4   Analytical Procedures  	  37
       5.4    QA/QC SAMPLES  	  37
              5.4.1   Field Replicate Samples	  38
              5.4.2   Collocated Samples	  38
              5.4.3   Background Samples	  38
              5.4.4   Performance Evaluation/Laboratory Control Samples 	  38
              5.4.5   Matrix Spike/Matrix Spike Duplicate Samples	  38
              5.4.6   Rinsate Blank Samples	  39
              5.4.7   Field Blank Samples  	  39
              5.4.8   Trip Blank Samples	  39
              5.4.9   Laboratory Duplicate Samples	  39
       5.5    EVALUATION OF ANALYTICAL ERROR	  39
       5.6    CORRELATION BETWEEN FIELD SCREENING RESULTS AND
              LABORATORY RESULTS 	  39
       5.7    EXAMPLE SITE	  40
              5.7.1   QA Objectives	  40
              5.7.2   Sources of Error	  40
              5.7.3   Field QA/QC Samples	  40
              5.7.4   Laboratory QA/QC Samples 	  41

6.0  DATA PRESENTATION AND ANALYSIS  	  42

       6.1    INTRODUCTION	  42
       6.2    DATA POSTING 	  42
       6.3    CROSS-SECTION/FENCE DIAGRAMS	  42
       6.4    CONTOUR MAPPING	  42
       6.5    STATISTICAL GRAPHICS	  42
       6.6    RECOMMENDED DATA INTERPRETATION METHODS 	  43
       6.7    EXAMPLE SITE	  43

Appendix A     EXAMPLE OF FLOW DIAGRAM FOR CONCEPTUAL SITE MODEL	  47

References  	  50
                                              VI

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                                       List of Figures






1      Conceptual Site Model  	 4




2      Random Sampling	 13




3      Systematic Grid Sampling	 14




4      Systematic Random Sampling	 15




5      Transect Sampling	 15




6      ABC Plating Site  Sketch	 17




7      Example of a Drum Inspection Log	 19




8      Example of a Hazard Categorization Data Sheet	 28




9      Posted Total Chromium Data for Impoundment No. 1	 44




A-l    Migration Routes  of a Gas Contaminant 	 47




A-2    Migration Routes  of a Liquid Contaminant	 48




A-3    Migration Routes  of a Solid Contaminant	 49







                                       List of Tables






1      ABC Plating Sample Log 	 35




2      Haz-Cat Results -- ABC Plating Site	 45
                                              vn

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                                    1.0  INTRODUCTION
1.1     OBJECTIVE AND SCOPE

This is the fourth volume  in a series of guidance
documents that  assist  Superfund  Program  Site
Managers, On-Scene Coordinators (OSCs), Remedial
Project Managers (RPMs),  and other field  staff in
obtaining representative  samples at Superfund sites.
The objective of representative sampling is to ensure
that  a sample  or a group of  samples  accurately
characterizes  site conditions.   The representative
sampling principles discussed in this document are
applicable throughout the Superfund Program.  The
following chapters will help  field personnel to assess
available information, select an appropriate sampling
approach, select and utilize field analytical screening
methods and sampling equipment, incorporate suitable
types and numbers of quality assurance/quality control
(QA/QC) samples, and interpret and present the site
analytical data.

As  the  Superfund  Program  has developed, the
emphasis of this response action has expanded beyond
addressing  emergency  response  and  short-term
cleanups.   Each  planned  response  action  must
consider a variety of sampling objectives, including
identifying   threat,   delineating   sources   of
contamination, and  confirming  the achievement of
clean-up standards.   Because many important and
potentially costly decisions are based on the sampling
data, Site Managers and other field personnel must
characterize site conditions  accurately.  To that end,
this document emphasizes the use of cost-effective
field analytical screening techniques to characterize
the site and aid in the selection of sampling locations.
1.2    CHARACTERISTICS
        WASTE
OF
Waste, in general terms, can include solid, liquid, and
sludge material typically generated as a by-product of
an industrial process.  Assume that containerized
wastes comprise high concentrations of hazardous
substances, unless clearly indicated otherwise through
previous   sample   analysis   or   other  reliable
documentation.   Waste  samples  are  often of high
concentration and phased (e.g., light liquid, dense
            liquid, and sludge), an important point to consider
            when developing a sampling strategy.  This document
            specifically addresses the sampling of wastes typically
            found  in  drums, tanks,  lab  packs, transformers,
            impoundments, waste piles, and on surfaces.

            The National Oil and Hazardous Substances Pollution
            Contingency Plan (NCP) definition for a hazardous
            substance  includes  "...any  substance  designated
            pursuant to section 311 (b)(2)(A) of the Clean Water
            Act; any element, compound, mixture,  solution, or
            substance designated pursuant to Section 3001 of the
            Solid  Waste Disposal Act (but not including  any
            waste the regulation of which under the Solid Waste
            Disposal Act has  been suspended  by an  Act of
            Congress); any hazardous air  pollutant listed under
            Section 112 of the Clean Air Act; and any imminently
            hazardous chemical substance or mixture with respect
            to  which the EPA Administrator  has taken action
            pursuant to Section 7 of the Toxic Substances Control
            Act.  The term does not include petroleum including
            crude  oil  or any  fraction thereof which  is  not
            otherwise  specifically listed  or  designated as  a
            hazardous substance..., and the term does not  include
            natural gas, natural gas liquids, liquified natural  gas,
            or synthetic gas usable for fuel (or mixtures of natural
            gas and such synthetic gas)."   Pursuant to 40 CFR
            261, Subpart C,  a waste is considered hazardous if it
            exhibits  any  of  the following   characteristics:
            ignitability, corrosivity, reactivity, ortoxicity; or if it
            is a listed hazardous waste under 40 CFR 261.30,
            Subpart D.  Asbestos and "mixed"  waste  (having
            radioactive and hazardous waste components), while
            included in  this  definition,  require  specialized
            sampling methods  and techniques and  will  not be
            addressed in this document.
            1.3     REPRESENTATIVE SAMPLING
                    OBJECTIVES

            Representative sampling applies to all phases of a
            Superfund response action.  Representative sampling
            objectives for waste include:

            •   Identify  the waste,  including composition  and
               characteristics, and determine if it is hazardous.

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•   Determine if there is an imminent or substantial
    threat  to  public health  or  welfare  or  the
    environment.

•   Determine the need for long-term action.

•   Develop containment and control strategies.

•   Evaluate appropriate disposal/treatment  options.

•   Verify treatment goals or clean-up levels.

Determine Hazard and  Identify Waste

One of the first objectives during a response action at
a site is to  determine the  presence, identity,  and
potential threat of any hazardous materials. Use field
screening techniques (discussed in Chapter 3) for
rapid  detection  of wastes.   Upon  confirming  the
presence  of hazardous  materials,  sample and/or
continue screening to identify their compositions and
determine their concentrations.

In addition to characterizing the waste  sufficiently,
conduct compatibility tests to help classify waste by
composition and other physical characteristics into
compatible waste streams  (e.g.,   acid, base,  or
oxidizer).   This will ensure  safer handling,  staging,
bulking, storage,  and transportation of wastes both on
and off site.

Establish Threat

Establishing threat to the public or environment is a
primary objective during a response  action.  The data
obtained from characterizing the waste will  help the
Site Manager to determine whether an imminent or
substantial threat exists and whether  a removal action
or other response action is necessary. The type  and
degree  of threat  determines the rate  at  which  a
response action is taken.

Determine Need for Long-Term Action

Site conditions may establish a long-term threat that
is not  imminent or substantial.  Characterization of the
waste can assist the Site Manager in  setting a priority
for long-term remediation evaluation and response.
Waste characterization data are required to evaluate
the site under the Hazard  Ranking System and to
identify sites eligible for inclusion on the National
Priorities List (NPL). The NPL is the ranking list of
those sites at highest national priority for long-term
evaluation and remediation.

Develop   Waste   Containment   and  Control
Strategies

Once the chemical constituents and threat have been
established, many strategies for waste containment
and  control are available  to the  Site Manager.
Analytical data indicating the presence of chemical
hazards are not  in themselves sufficient to select a
containment or control strategy. Site reconnaissance
and historical site research provide information on site
conditions and the physical state of the waste sources;
waste containment and control strategies are largely
determined  by this information.  For example,  site
security measures (such as erecting a fence) may be
sufficient to stabilize a site containing intact drums of
solvents, and overpacking may be sufficient to contain
a  corroded drum  of organophosphate  pesticides.
Unstable or explosive wastes, such as picric acid, may
require immediate removal by demolition experts.

Identify Available Treatment/Disposal Options

The site contaminants should be identified, quantified,
and  compared to  selected  action levels.   Where
regulatory  action levels  do not exist, site-specific
clean-up levels are determined by the EPA Region
(often in  consultation with the Agency  for  Toxic
Substances and Disease Registry (ATSDR)). If action
levels are exceeded, a series of chemical and physical
tests may be required to evaluate possible treatment
and/or disposal options.  Each treatment or disposal
method has a corresponding set of waste parameters
that must  be  evaluated, e.g., ash content, British
thermal unit (BTU) value, total metals concentration,
total organic halides, cyanide, total chlorine and NOx
are minimum requirements for incineration.   It is
important to test for treatment/disposal parameters as
early as possible during the  site assessment  and
characterization  procedure.  Relatively inexpensive
tests such as total organic carbon (TOC), BTU,  and
pH should be considered early in the response action
in order to contribute to later treatability studies. The
test results will ultimately help to determine the most
appropriate treatment or disposal option for meeting
regulatory requirements.

Verify Treatment Goals or Clean-up Levels

After treatment or disposal,  representative sampling
results should either confirm that the response actions

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have met the site-specific treatment goals or clean-up
levels, or indicate that further treatment or removal is
necessary.   Refer to the Representative Sampling
Guidance,  Volume 1  —  Soil,  OSWER Directive
9360.4-10, for guidelines  on soil sample collection
and preparation for confirming cleanup.

Sampling   to  verify   cleanup  requires   careful
coordination with demobilization activities.  After
treatment of one area on a site, verification sampling
can begin in that area by using field screening and on-
site analysis. Meanwhile, other areas can be treated.
Lab  confirmation of the screening performed in the
treated areas can help ensure accuracy of screening for
subsequent areas to meet QA objectives (as discussed
in Section 5.2).
1.4    CONCEPTUAL SITE MODEL

A conceptual site model is a useful tool for selecting
sampling  locations.   It helps ensure that  sources,
pathways, and receptors throughout the site have been
considered before sampling locations are chosen.  The
conceptual  model  assists  the  site  manager in
evaluating the interaction of  different site features.
Risk assessors use conceptual models to help plan for
risk assessment activities. Frequently, a conceptual
model is created as a site map (see Figure 1) or it may
be  developed as a flow diagram which describes
potential migration of contaminants to site receptors
(see Appendix A).

A conceptual model follows contaminants from their
sources, to pathways  (e.g., air, surface water), and
eventually to the assessment endpoints.  Consider the
following when creating a conceptual model:

•   The state(s) of each contaminant and its potential
    mobility

•   Site topographical features

•   Meteorological    conditions    (e.g.,    wind
    direction/speed,      average     precipitation,
    temperature, humidity)

•   Human/wildlife activities on or near the site

The conceptual  site model on  the next page is an
example created for this document.  The model assists
in identifying the following site characteristics:
Potential Sources'.

Site (waste pile, lagoon); drum dump; sewage plant
discharge

Potential Migration Pathways'.

Soil — Leachate from the waste pile or drum dump;
soil in direct contact with solids in the waste pile or
drum dump

Surface  Water — Liquid waste from the lagoon or
sewage plant discharge (into the lake)

Sediments — Liquid waste from the lagoon or sewage
plant discharge (into the lake)

Air — Release of vapors/particulates from the waste
pile, drum dump or lagoon

Potential Exposure Routes'.

Ingestion — Particles from the waste pile  or drum
dump; liquid from the lagoon or lake (from sewage
plant discharge)

Inhalation — Vapors from the waste pile, drum dump,
lagoon, or lake (sewage plant discharge)

Absorption/direct contact — Contact with the waste
pile,  drum dump, lagoon,  or lake  (sewage plant
discharge)

Potential Receptors  of Concern  (and associated
potential exposure sources)'.

Human Population

   Residents/Trespassers:

    Soil  — Leachate  from the drum  dump;  direct
   contact with soil from solids in the drum dump

    Surface water — Liquid waste from the lagoon into
   the river or sewage plant discharge into the lake

   Air — Vapors/particulates from the waste pile,
   drum   dump,  lagoon,   or  lake  (sewage  plant
   discharge)

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    Workers/Trespassers:

    Soil —  Leachate from  the  waste pile; direct
    contact with soil from solids in the waste pile

    Surface water -- Liquid waste in the lagoon or
    associated with the sewage plant discharge

    Air — Vapors/particulates  from  the waste pile,
    drum dump, lagoon, or sewage plant discharge
Biota
    Threatened or endangered species or human food
    chain organisms known to frequent areas near the
    waste pile, drum dump, lagoon, or lake (sewage
    plant discharge)
Preliminary   site   information  may  provide  the
identification of the contaminant of concern and the
level of the contamination.  A sampling plan should
be developed based upon the selected receptors of
concern and the suspected sources and pathways.  The
model  may assist in the selection of on-site and off-
site sampling locations.

1.5    EXAMPLE SITE

An example site presented at the end of each chapter
illustrates the development of a representative waste
sampling  plan  that  meets  Superfund Program
objectives for an early action.

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                                  2.0  SAMPLING  DESIGN
2.1     INTRODUCTION

There   is  no   universal  sampling  method  for
characterizing wastes because site characteristics vary
widely. The sampling methods and equipment must
be suited to the specific  sampling situation.   A
properly developed waste sampling design defines the
sampling  purpose, protects  site worker health and
safety, effectively utilizes resources, and minimizes
errors.  The sampling design will vary according to
the  type  of waste  sampled  (including type  of
containers or sources),  and the characteristics of the
site.  When developing a sampling  design, consider:
prior actions at the  site (e.g., sampling practices,
compliance inspections); properties and characteristics
of the wastes  sampled; site  waste  sources (e.g.,
impoundments,  waste  piles, drums); topographic,
geologic, hydrologic, and meteorologic conditions of
the site; and flora, fauna, and human populations in
the area.

Waste material may  be liquid, solid, or sludge, and
may  be contained in drums, tanks, waste piles, surface
impoundments, on surfaces (e.g., building structures,
floors, equipment), in  lab packs, or other sources.
Sampling each waste  stream may require a variety of
sampling techniques, equipment, sample packaging,
and sample analyses.
2.2    SAMPLING PLAN

Many  site-specific factors  are important  in  the
development of a good sampling plan, including: data
use  and  quality  assurance  objectives;  sampling
equipment;  sampling  design;  standard  operating
procedures  (SOPs);  field   analytical   screening;
analytical method selection; decontamination; sample
handling and shipment; and data validation.

The U.S. EPA Quality Assurance Sampling Plan for
Environmental Response (QASPER) was designed to
develop  sampling  plans  for  response  actions.
QASPER is menu-driven software which prompts the
user to input background information and to select
prescribed  parameters  for development of a site-
specific sampling plan.  It also gives the user access
to any previously developed site-specific  sampling
plans.

The  following procedures  are  recommended for
developing a thorough waste sampling plan. Many
steps can be performed concurrently, and the sequence
is flexible.

•  Review the history of the site, including regulatory
   and reported spill history;  note current and former
   locations of buildings, tanks, and process, storage,
   and disposal areas.

•  Perform   a  site   reconnaissance;  categorize
   physical/chemical   properties  and  hazardous
   characteristics of materials involved.

•  Identify topographic, geologic and hydrologic
   characteristics of the site including surface water,
   groundwater, and soil characteristics, as well as
   potential migration pathways and receptors.

•  Determine   geographic    and    demographic
   information,  including population size and  its
   proximity to the site (e.g., public health threats,
   source of drinking water); identify threatened
   environments  (e.g.,  potentially   contaminated
   wetlands or other sensitive ecosystems).

•  Select  sampling strategies,   considering  field
   analytical  screening and  statistical applications,
   when appropriate.

•  Determine data  quality  and  quality  assurance
   objectives for field analytical screening, sampling,
   and  analysis.  As  the extent of  contamination
   becomes quantified, the  sampling plan  can  be
   modified  to better assess sampling objectives
   throughout the action.

It is recognized that many of these steps (described in
detail below) would not be applicable during a classic
emergency response because of the lack of advance
notice.  Emergency  response sampling nevertheless
requires good documentation of sampling events.

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2.2.1  Historical Data Review

The  first step in developing a sampling plan is a
review  of historical site data, examining past and
present site  operations and  disposal  practices  to
provide  clues   on  possible  site  contamination.
Available sources of information include:  federal,
state and local agencies and officials; federal, state,
and local agency files (e.g., site inspection reports and
legal actions);   deed or title records;  current and
former  facility  employees; potentially responsible
parties (PRPs); local residents; and facility records or
files.

A review of previous sampling information should
include sampling  locations,  matrices,  methods  of
collection and  analysis, and relevant  contaminant
concentrations.  Assess the reliability and usefulness
of existing analytical data, including those which are
not  substantiated  by  documentation  or  QA/QC
controls, but which may still illustrate general site
trends.

Collect information that describes specific chemical
processes, raw materials used, products and wastes,
and waste storage and disposal practices.  Review any
available site maps, facility blueprints, and historical
aerial photographs detailing past and present storage,
process, and waste  disposal locations.   County
property and tax records and U.S. Geological Survey
(USGS) topographic maps  are  useful sources  of
information on the site and its surroundings.

2.2.2  Site Reconnaissance

A site reconnaissance can be conducted at an earlier
date  or immediately prior to sampling  activities.  It
allows  field personnel to assess site conditions,
evaluate areas of potential contamination, evaluate
potential  hazards  associated  with sampling, and
finalize  a sampling plan.    Site  reconnaissance
activities include:  observing and photographing the
site; noting site access routes and potential evacuation
routes; noting potential safety hazards; recording label
information  from drums, tanks, or other containers;
mapping process and waste disposal areas such  as
landfills, impoundments, and effluent pipes; making
an inventory of the wastes on site; mapping potential
contaminant  migration  routes such  as  drainage,
streams, and irrigation ditches; noting the condition of
animals and/or vegetation; and noting topographic
and/or structural features. Field personnel should use
appropriate personal protective equipment (PPE) when
engaged in any site activities.

2.2.3  Physiographic  and  Other
        Factors

Other procedures, such as determining data quality
and  QA/QC objectives, utilizing  field  analytical
screening   techniques,   identifying  topographic,
geologic   and  hydrologic   characteristics,   and
determining geographic and demographic information
are important steps of an overall sampling plan. Field
analytical  screening techniques and equipment are
discussed in Chapter 3; QA objectives are discussed
in Chapter  5.   Since this document specifically
pertains to  waste sampling, the remaining procedures
listed above will not be addressed in detail here.
(Please refer  to   the  Representative  Sampling
Guidance,  Volume 1  — Soil, OSWER Directive
9360.4-10.) The U.S. EPA is currently developing an
ecological  sampling guidance  document that will
contain a detailed checklist for collecting ecological
data.
2.3    WASTE SAM RLE TYPES

Design sampling  procedures to match  sampling
objectives. The type of sample collected may depend
on suspected waste types and characteristics; size and
accessibility of waste containers, impoundments and
other media; target analytes;  and health and safely
requirements.

The following section describes and gives examples of
the two types of waste samples.

2.3.1  Grab Sample

A grab sample is a discrete aliquot collected from one
specific sampling location at a specific point in time,
and   may   be  considered  representative  of  a
homogeneous and stable waste. When obtaining grab
samples from containers or from an  impoundment
having stratified layers, sample each phase or stratum
separately; the separate aliquots are representative of
their respective stratum.  When sampling stratified
sources, determine as many properties of the wastes as
possible   through  historical    data  and    site
reconnaissance prior to sampling, and use caution
because the individual phase components may be
more concentrated  than the original waste material.

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2.3.2  Composite Sample

A  composite  sample  is  a  non-discrete sample
composed of two or more equal aliquots collected at
various sampling points or times. There are four types
of   composite  samples:   areal,   vertical,  flow
proportional, and time.   An areal composite is
comprised  of individual aliquots  collected over  a
defined area (e.g., surface of a waste pile).  It is made
up of aliquots of equal volume, each collected in an
identical manner at  the same horizon (depth).  A
vertical composite is composed of individual aliquots
collected  at  different depths  but  along the  same
vertical line (e.g., borehole).  It is made up of aliquots
of equal volume which are collected in an identical
manner. A flow proportional composite is a sample
collected proportional to the  flow rate during the
compositing period by either a time-varying/constant
volume or time-constant/varying volume method. A
time composite is composed of a varying number of
discrete, equal-volume aliquots collected at equal time
intervals during the compositing period.  (Both flow
and  time  composite samples  are  appropriate for
sampling wastewater or streams.)

By design, composite samples reflect an "average"
concentration within the composite area, flow, or
interval.      Compositing   is  appropriate   when
determining  the  general  characteristics  or  the
representativeness of certain sources (e.g., a waste
pile or impoundment) when considering methods of
treatment  or disposal.  When  compositing samples
from a waste stream, note that resulting concentrations
are representative of the  waste   stream's  average
concentration, but not of discrete  areas within the
waste stream.

Composite sampling should be performed only on like
waste streams.  Do not composite dissimilar waste
streams or waste sources (e.g., drums with unknown
contents or dissimilar materials)  because of health and
safety  risks  associated with possible reactions; in
addition, the resulting sample will not define or
represent  the origin of the  mixed  contaminants.
Composite  aliquots  from  tanks,  drums,  or  other
containers    only    after   adequate   hazardous
characterization screening  to  prevent  mixing of
incompatible wastes.

A result of sample compositing is the dilution of high
concentration aliquots.  To  compensate for dilution,
reduce the applicable  detection  limits accordingly. If
the composite value is to be compared to a selected
action level, then the action level must be divided by
the number of aliquots that make up the composite in
order to determine the appropriate detection limit.  For
example, if the action level for a particular substance
is 40 ppb, a  detection limit of 10 ppb should be used
when analyzing a 4-aliquot composite.

When compositing waste, four aliquots per sample are
recommended because two ounces of each aliquot can
be added to an 8-ounce (or larger) jar.   Individual
aliquots in storage from any "hit" composites can be
analyzed later to pinpoint contamination.
2.4    WASTE TYPES

The types of wastes  encountered  at a site greatly
influence the development of the site sampling plan.
The number of grab and composite samples, type of
screening/sampling equipment used, and analytical
methods all depend on the types of wastes present at
the site.  Waste  solids can vary from granular or
powdered  materials  to  contaminated  structural
surfaces or demolition debris.   Waste liquids  can
include  solvents, acids, bases, process solutions,  and
lubricants, among  others.   Waste sludges  have
characteristics of both solids and liquids.

Each type of waste  may  be  highly concentrated,
consisting of virtually pure industrial products, raw or
spent materials, chemicals, or  process by-products.
Methods for sampling and analyzing vary by waste
type, and the sampling plan should specify appropriate
sample collection and analysis methods.

Waste samples  are often complex mixtures and may
be difficult to analyze in the laboratory. Provide the
analytical laboratory  with  as much information as
possible to help minimize  delays in analysis.  The
laboratory will find the following information helpful
in expediting the analysis of waste samples:

•  Whether  the   sample  is  pure  waste or   an
   environmental sample (e.g., oil as opposed to oily
   water).

•  Viscosity, particle size, or an accurate description
   of the waste  characteristics.

•  Qualitative estimate of concentration  (i.e., low,
   medium, high).

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•   Presence of extreme pH levels (i.e., less than 2 or
    greater than 12);  some analytical methods will
    not yield successful results on such samples; it
    may be necessary to consult with a chemist to
    change the method.

•   Presence  of chlorinated dioxins,  even if the
    samples are being analyzed for another parameter
    (e.g., metals).  The Occupational  Safety  and
    Health Administration (OSHA) specifies special
    handling facilities for samples contaminated with
    dioxin; many laboratories are not set up to handle
    these samples.

•   Presence  of high  concentrations  of organic
    substances, particularly aromatics, in samples to
    be analyzed for metals (some methods for metals
    analysis   are  not   compatible  with   high
    concentrations of organic materials).

Inform  the laboratory in advance  about important
sample constituents of interest and QA/QC criteria.
Waste  samples  typically must  be  diluted before
analysis, which  may  prevent  detection  of these
constituents. Also consult with the laboratory on how
to prepare subaliquots of non-typical samples.
2.5    WASTE  CHARACTERISTICS

Waste  characteristics,  including  homogeneity,
physical state, chemical stability, particle size (solids),
and viscosity (liquids) are other factors that influence
the number and types of samples collected.

2.5.1  Homogeneity

Wastes may be homogeneous or heterogeneous. The
solubility, specific gravity, and mechanical mixing
ability  of the  waste  can  affect  its  degree  of
homogeneity.  A single grab sample per waste stream
may be appropriate for a homogeneous  material;
however, heterogeneous and unclassified wastes often
require  more extensive  sampling and  analysis to
ensure that the various phases and concentrations of
the waste  are  represented in  the  samples.   The
sampling  strategy  should reflect  the homogeneity,
random heterogeneity,  or stratification of the waste
over space or time.
2.5.2  Physical State

The physical state of waste (i.e., solid, liquid, gas, or
multiphasic) will influence the selection of sampling
devices and many other aspects of the sampling effort.
Variances  in  each physical state  can  also  affect
sampling.  For example, free-flowing liquid would
require a different sampling approach than a viscous
liquid.

Sample containers with wide mouths are best for solid
samples, sludges, and liquids with substantial amounts
of suspended matter.  Bottles with air-tight closures
are needed for gas  samples  or gases adsorbed onto
solids or dissolved in liquids.

The sampling strategy will vary if the physical state of
the waste is subject to stratification (for example,
liquid wastes with differing densities or viscosities, or
those with suspended solids),  homogenization, or
random heterogeneity.

2.5.3  Chemical Stability

Waste materials  can  differ considerably in  their
inherent chemical stability. Exposure to the elements
(e.g., sunlight, air, rain) and leaching  may  cause
chemical degradation or reaction, thereby creating
new  compounds.    Heterogenous materials  may
undergo  physical  separation, resulting in pockets or
layers of different compounds. Sampling methods and
shipping practices will vary according to the toxicity,
ignitability, corrosivity, and reactivity of the waste.

2.5.4  Particle Size (solids)

Waste solids are  often made up  of materials with
different particle sizes. This variation can influence
analytical results by introducing either a negative or
positive bias.  For example,  if large pieces of waste
material  (e.g., slag) are not collected and included
with a sample, a negative bias of contaminants may
result (analytical results may be lower than what is
actually representative).  Small particle size can also
bias a sample.  Some pollutants adsorb more readily
onto small  particles, so a small-fraction sample may
result in a  positive bias  (analytical results may be
higher than what is representative). If it is necessary
to sample  material that has unusual particle size
characteristics,  identify   an  approximate  size
distribution and consult the laboratory in advance to
determine a method for representative analysis of the

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irregular materials.  Sieving of waste is not usually
recommended. If grinding or pulverizing large pieces
is  desired,  make special  arrangements  with the
laboratory.

2.5.5  Viscosity (liquids)

Viscosity is the internal friction of a fluid  that
produces a resistance to flow.  The viscosity of waste
liquids  often greatly affects the effort required for
sample  collection and may indirectly determine the
volume  of sample required.   Because viscosity can
affect the representativeness of the sample, and can
itself be  a physical limitation for sampling, a sampling
technique suited to the viscosity of the material must
be selected.  Very  viscous  materials (greater than
100,000 centipoise (cps)) must be scooped, while low
viscosity materials may be aspirated, encapsulated, or
poured.    To collect  a representative  sample for
viscosity testing, it is important to  limit handling and
contact time. The sample must be allowed to return to
equilibrium   before   measurement.     Without  a
viscometer, viscosity may be roughly determined by
comparison to water (low viscosity), syrup (medium
viscosity), and mayonnaise or taffy (high viscosity), as
well as to other materials of known viscosity.

Several  sampling devices  have  been designed to
sample waste liquids within a specific viscosity range.
Weighted bottle samplers, PACS grab samplers, and
composite liquid waste samplers (COLIWASAs) are
suited for sampling less viscous liquids and become
difficult  to use in very viscous liquids.  The glass thief
and bacon bomb sampler are suitable for sampling
moderately to highly viscous materials. See Section
3.2 for a discussion of sampling equipment.
2.6    WASTE SOURCES

There  are a  variety  of potential waste sources
commonly found at waste sites.  The type of waste
source affects many aspects of the  sampling design,
such  as  sampling  approach (e.g., judgmental or
random), sampling equipment, and types/numbers of
samples (including QA/QC samples).  The type of
source will also affect many  logistical considerations,
such as cost, level of effort, and duration of a response
action. This section introduces the three categories of
waste sources: containerized waste, uncontainerized
waste, and surfaces and debris.
2.6.1  Containerized Waste

Containerized waste consists of solids, liquids, or
sludges that are found in drums, bulk storage tanks,
transformers, and lab packs. Evaluate container label
information before making sampling decisions.   It
may be possible to identify numerous containers of
similar material.  Wherever possible, use screening
techniques  to   substantiate   label   information.
Screening results should be confirmed with laboratory
test results prior to making any treatment or disposal
decisions (affirming that screening was effective).
Specialized equipment (e.g., forklift, grapple, manlift)
may be needed to access drums and tanks safely.

The  sampling objective determines which and how
many containers need to be sampled. For example, if
the objective is to establish threat, it may  be most
important to sample a few containers having visible
leaks or spills.  If the objective is to  estimate the
disposal cost, it may be appropriate to  sample each of
the  largest  volume  containers   to  identify  the
predominant waste streams.

Drums can be of different volumes (typically from 30
to 90 gallons), varied construction (e.g., top bung, side
bung, removable top, lined), and be made of a variety
of  materials   (e.g.,  steel,  polyethylene,  fiber,
combinations).  Drums located at a waste site often
vary in condition,  sometimes showing deterioration,
bulging, and/or damage.  These physical criteria can
be useful in making assumptions about  a drum's
contents.  For example, strong acids,  caustics, or other
corrosives are typically stored  in  30-  to 55-gallon
polyethylene or polyethylene-lined steel drums with
top bung holes. While this is not a fool-proof method
of determining drum contents, it gives the investigator
an indication prior to sampling of the general types of
materials to be encountered.

Bulk storage tanks include tank cars/trucks, vats,
storage vessels, and transformers. They range in size
from less than 100 gallons to millions of gallons.
Like drums,  bulk storage tanks are  constructed of
many different materials and are designed  in many
configurations.

Lab  packs consist of small,  individually-labelled
containers of laboratory  waste or  unused  reagents.
The  chemical containers are usually not more than
five  gallons  each,  and  are often packaged  or
transported  together  in  a  larger  Department  of
                                                   10

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Transportation (DOT) shippable container (these are
typically 30- to 55-gallon drums).  Be sure to screen
lab  packs  for  radioactivity,   since  radioactive
substances (alpha, beta,  and gamma emitters)  are
commonly found in lab packs.

Another type of waste that can be found on site is
biological waste, also known as  "red bag  waste."
Note that contaminated biological waste (dressings,
syringes,  etc.)  may  not always  be  found  in  the
required red  bag.   It should be  handled only by
personnel specifically trained and authorized to deal
with biological waste.    If "red bag  waste"  is
encountered at a site, notify the AT SDR, or local
health authorities.

2.6.2  Uncontainerized Waste

Uncontainerized waste consists of solids, liquids, and
sludges that are found in waste piles and  surface
impoundments.

Waste piles may be composed of solid wastes such as
tank bottom solids, contaminated soil, ash, solidified
sludges, or a mixture of liquid and solid chemical
wastes. The shape and size of waste piles can vary
greatly, depending  on the  generating process  or
facility. The sampling plan should take into  account
the chemical and physical characteristics of the waste
pile. For example, contaminants can leach out of the
surface layers of a waste pile, resulting in deceptively
low or nonrepresentative concentrations at the top.
The sampling plan should account for leaching by
taking  composite samples from  various horizons
within   the   pile   to  determine  an   "average"
concentration.

Surface impoundments  include lined and  unlined
lagoons,  ponds,   and   trenches  that   contain
predominantly liquids and sludges from site processes
or surface runoff.  The liquids may be homogeneous
or stratified, depending on the chemical and physical
properties of the wastes. Reactions may occur within
the impoundment to  alter or degrade the  original
chemicals. Do not compromise any existing liners
when sampling bottom sludges.

2.6.3  Surfaces and Debris

Surfaces and  debris require specialized sampling
techniques.  During a response action, it may be
necessary to sample object and structural surfaces for
contamination to determine the need for dismantling
and eventual disposal.  Virtually any surface on the
site may have to be sampled, including walls and
floors of buildings, process machinery, tanks, vats, air
ducts,  vehicles,  and  furniture.   There are  three
methods for sampling surfaces: wipe sampling, chip
sampling,  and  dust sampling.   Each method  is
described further in Section 4.3.6.

Debris can be highly variable and includes demolition
rubbish, construction and destruction materials, paint
cans,   empty  55-gallon  drums,  battery-casings,
shredded  automobiles,  and  other miscellaneous
matrices  such as process waste, tannery waste, and
slag.  Debris may be composed  of plastic, metal,
rubber, paper, concrete, wood, glass, masonry, and
municipal waste. It can include contaminated waste
sampling  articles  such  as  protective disposable
clothing  (e.g., Tyvek suits), sample collection jars,
and disposable  sampling  equipment  (e.g.,  plastic
scoops).
2.7    QUALITY ASSURANCE
        CONSIDERATIONS

Quality assurance components are defined as follows:

•  Precision — measurement of variability in the data
   collection process

•  Accuracy  (bias)  — measurement of bias  in the
   analytical process;  the term "bias" throughout this
   document   refers  to  the  QA/QC  accuracy
   measurement

•  Completeness  —  percentage  of  sampling
   measurements which are judged to be valid

•  Representativeness — degree to which sample data
   accurately    and   precisely   represent   the
   characteristics and concentrations of the waste
   contaminants

•  Comparability — evaluation of the  similarity of
   conditions    (e.g.,   sample   depth,   sample
   homogeneity) under which separate sets of data are
   produced

To   ensure  that   the   analytical   samples  are
representative of site conditions,  quality assurance
measures must be associated with each sampling and
                                                  11

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analysis event.  The sampling plan must specify these
measures. QA measures include, but are not limited
to:  laboratory  SOPs,  sample  bottle  preparation,
equipment decontamination, field blanks, replicate
samples, performance  evaluation samples, sample
preservation  and  handling,  and chain-of-custody
requirements    (see    Chapter    5,    Quality
Assurance/Quality Control).
2.8    DATA QUALITY OBJECTIVES

Data quality  objectives (DQOs) state the level of
uncertainty that is acceptable  for  data  collection
activities and define the certainty of the data necessary
to make decisions.  When establishing DQOs for a
particular project, consider:

•   Decision(s) to be made or question(s) to  be
    answered
•   Why analytical data are needed and how the
    results will be used
•   Time and resource constraints on data collection
•   Descriptions of the analytical data to be collected
•   Applicable model or data interpretation method
    used to arrive at a conclusion
•   Detection limits for analytes of concern
•   Sampling and analytical error
2.9    FIELD ANALYTICAL
        SCREENING AND
        GEOPHYSICAL TECHNIQUES

There  are two types of analytical data that can be
generated during a response action: field analytical
screening data and laboratory analytical data. Field
analytical  screening  instruments  and  techniques
provide real-time or direct (or colorimetric) readings.
They  include: flame ionization  detectors  (FIDs),
photoionization detectors (PIDs), colorimetric tubes,
portable X-ray fluorescence (XRF) units, portable gas
chromatography (GC) units, immunoassay tests, and
hazard categorization kits.  These screening methods
can assist with the selection of sample locations or
samples  to be  sent for laboratory analysis by
narrowing the possible groups or classes of chemicals.
They are effective and economical for gathering large
amounts of site  data.   After  an area or group of
containers  has  been   characterized using  field
screening techniques, a subset of samples can be sent
for laboratory analysis to substantiate the screening
results.   Field analytical screening  with  laboratory
confirmation usually generates more analytical data
under a limited sampling budget than will sampling
with  off-site laboratory analysis alone.  Whenever
possible, use field analytical screening methods which
provide  detection limits  below applicable action
levels.   If these methods are  not  available,  field
analytical screening can  still be useful  for waste
sampling by detecting grossly contaminated areas as
well as for on-site health  and safety determination.
Field analytical screening techniques to support waste
sampling are discussed in more detail in Chapter 3.

Geophysical techniques may be utilized during  a
response action to locate potential  buried drums or
tanks, buried waste, and disturbed areas.  Geophysical
techniques include ground penetrating radar (GPR),
magnetometry, electromagnetic conductivity (EM),
and  resistivity  surveys.    Refer  to U.S.  EPA
Representative Sampling Guidance, Volume 1 — Soil,
OSWER Directive 9360.4-10, for a discussion of soil
geophysical techniques that are also applicable for
waste sampling.
2.10   ANALYTICAL  PARAMETERS
        AND METHODS

Designing  a representative waste sampling  plan
includes selecting analytical parameters and methods.
Use data collected during the historical data review
(e.g., past site processes, materials stored on site) to
select appropriate analytical parameters and methods.
If the historical data review reveals little information
about the types of waste on site, select analytical
parameters by initially characterizing the waste. Use
applicable  field  screening  methods and  limited
laboratory analysis to rule out the presence of high
concentrations of certain contaminants, and to narrow
the list of analytical parameters.  Methods often used
for characterization of waste include GC/MS (gas
chromatography/mass spectroscopy) screening for
tentatively identified compounds (TICs) in the volatile
and   semivolatile   organic  fractions,   infrared
spectroscopy (IR) for organic compounds, inductively
coupled plasma (ICP) for inorganic substances, and
product comparison.  These methods are used  to
determine chemical percentages in waste samples.
After characterization, future sampling and analysis
efforts can focus on substances identified above the
action level.
                                                   12

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2.11   REPRESENTATIVE SAMPLING
        APPROACHES

Representative sampling approaches appropriate for
waste   sampling   include  judgmental,  random,
systematic  grid, systematic random, and  transect
sampling. A representative sampling plan may use
one or a combination of these approaches.

2.11.1  Judgmental Sampling

Judgmental  sampling is the  biased selection  of
sampling locations  at  a site, based  on historical
information, visual inspection, sampling objectives,
and professional judgment. In waste sampling, three
distinct situations  prevail:  1) selecting locations
within a large waste stream such as a waste pile or a
stratum  in an impoundment; 2) selecting a subset of
containerized wastes when all containers cannot  be
sampled; and 3) sampling both containerized and non-
containerized wastes in order to identify worst-case
conditions and establish threat.  If determining threat,
the presence of certain site conditions such as leaking
drums, spill areas, and large volume containers will
indicate appropriate  sampling locations if the source
is known to be hazardous.  Select drums to sample  by
existing labelling/markings or by container type, but
not  by random selection.  When establishing threat,
screen drums  first  to  select a  subset  of drums
containing hazardous  materials or waste to be sent for
analysis. This will avoid sampling drums of non-
hazardous materials, which  is  not  cost-effective.
Judgmental sampling includes no randomization in the
sampling strategy, precluding statistical interpretation
of the sampling results.
2.11.2  Random Sampling

Random sampling  is the  arbitrary  collection  of
samples  having  like contaminants within defined
boundaries of the area of concern.  Choose random
sampling  locations  using  a  random  selection
procedure (e.g., a random number table).  (Refer to
Ford and Turina, July, 1984, for  an  example of a
random number  table.)  The arbitrary selection of
sampling points ensures that each sampling point is
selected independently from all other points, so that
all locations within the area of concern have an equal
chance of being sampled. Randomization is necessary
in order to make probability or confidence statements
about the sampling results.  The key to  interpreting
these  statements is the assumption that the site or
waste  stream is  homogeneous with respect to the
parameters being monitored. The higher the  degree of
heterogeneity, the less the random sampling approach
will adequately characterize true conditions. The use
of random  sampling on a subset of containers is not
appropriate   if   different   waste   streams   or
concentrations might be present. Random sampling of
waste piles and impoundments is  often  appropriate
because  of their large  areal  extent and relative
homogeneity.  Use random sampling to  confirm the
attainment of treatment levels of contaminated waste.
(Refer to U.S. EPA, Methods for Evaluating the
Attainment of Cleanup Standards, Volume 1 — Soils
and Solid Media, EPA/230/02-89/042, pages 5-3 to 5-
5 for guidelines on selecting sample coordinates for
random sampling.)   Figure 2 illustrates a random
sampling approach.
                                   Figure 2:  Random Sampling
                            200-
                                     I	1	1	1	1	1	1	1
                                    50   100   150   200   250   300   350   400
                                 KEY
                        X SELECTED SAMPLE LOCATION
                                                            After U.S. EPA, February 1989
                                                  13

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2.11.3   Systematic Grid Sampling

Systematic grid sampling involves subdividing the
area of concern by using a square or triangular grid
and collecting samples from the nodes (intersections
of the grid lines).  Select the origin and direction for
placement of the grid using an initial random point.
From that point, construct a coordinate axis and grid
over the  source.   Generally, the more samples
collected (and the smaller the grid spacing), the more
reproducible and representative the results. Shorter
distances between sampling locations also improve
representativeness.
 Systematic grid sampling can be used to characterize
 a waste pile, impoundments, or loose tank bottom
 solids.  Systematic grid sampling is not applicable to
 sampling individual small containers or drums.  (Refer
 to U.S. EPA, Methods for Evaluating the Attainment
 of Cleanup Standards, Volume 1 — Soils and Solid
 Media, pages 5-5 to 5-12 for guidelines on selecting
 sample  coordinates for systematic  grid sampling.)
 Figure   3  illustrates a  systematic grid  sampling
 approach.
                                Figure 3:  Systematic Grid Sampling
                           200-
                           150--
                           100--
                            50-
                                    -\	h
-\	1	h
                             0      50   100    150    200   250   300   350   400
                                                     FEET
                                KEY
                       X SELECTED SAMPLE LOCATION
                                                              After U.S. EPA, February 1989
2.11.4   Systematic Random
          Sampling

Systematic random sampling is a useful and flexible
design  for  estimating   the   average   pollutant
concentration within grid cells.  Subdivide the area of
concern  using  a  square or  triangular  grid  (as
mentioned above) then collect samples from within
each  cell  using  random selection  procedures.
Systematic random sampling allows for the isolation
of cells that may require additional sampling  and
analysis.  Like systematic grid sampling, systematic
random sampling can be used to characterize a waste
pile, loose tank bottom solids, or impoundments, but
not small containers or drums.  Figure 4 illustrates a
systematic random sampling approach.
 2.11.5   Transect Sampling

 Transect sampling involves establishing one or more
 transect lines across a surface.  Collect samples at
 regular intervals along the transect lines at the surface
 and/or at one or more given depths.  The length of the
 transect line and  the  number  of samples to be
 collected determine the  spacing between  sampling
 points along the transect.  Multiple transect lines may
 be parallel or non-parallel to one another. If the  lines
 are  parallel, the sampling  objective is similar to
 systematic grid sampling.   The primary benefit of
 transect sampling versus systematic grid sampling is
 the  ease of establishing and  relocating individual
 transect lines.

 Transect sampling is  applicable to  waste piles or
 impoundments.    Figure 5  illustrates  a  transect
 sampling approach.
                                                  14

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                          Figure 4:  Systematic Random Sampling
200-
150-
100-
50-

(

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X
X *

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X
X
" ซ
X
X
X
X
X
X
X
X


X
X
X
X


*;
XV
X
*


jy
                            0     50   100   150   200   250   300   350   400
                                                 FEET
                              KEY
                      X SELECTED SAMPLE LOCATION
                                                         After US. EPA, February 1989
                                 Figure 5:  Transect Sampling
              Hi
              LU
                  200—
                   150 —
                   100 —
                    50—
-I       I       h-
 50    100    150
—I      \-
 200    250

  FEET
                                                                       +
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                                                               300    350   400
                     KEY
            SELECTED SAMPLE LOCATION
                                                             After U.S. EPA, February 1989
2.12  SAMPLING LOCATIONS
       AND NUMBER

The locations and number of samples to be collected
must be carefully selected to obtain samples that are
truly representative of the material being sampled, as
well as of the general site area.   The sampling
objectives,   waste   type,   container/source  type,
                         sampling approach, and other factors determine where
                         and how many samples are collected. For example, a
                         judgmental sampling approach can establish threat or
                         identify the presence of wastes with a few carefully
                         selected samples.  A larger number of samples  are
                         needed to characterize wastes, and sampling locations
                         should be selected using random, systematic grid, and
                         systematic  random  sampling  techniques.    Field
                         screening  techniques  are valuable  for selecting
                                                15

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sampling locations.  In situations where there is a very
large waste area or numerous containers of potentially
different wastes, field  screening  techniques may
identify similar waste streams.  These wastes can be
segregated into general chemical classes (e.g., strong
acids, halogenated solvents) and then samples can be
collected for confirmation by laboratory analysis.

Sampling locations which pose a severe chemical or
physical hazard to sampling teams (e.g., cylinders of
hydrofluoric acid, hydrogen cyanide, or nerve agents)
should be avoided or sampled remotely.  Sampling
cylinders requires  specially  trained and authorized
personnel.
2.13   EXAMPLE SITE

2.13.1  Background

ABC Plating, a multi-purpose specialty plating facility
in northern Pennsylvania operating from 1947 to 1982,
stored and treated its plating wastes by placing them
in a series of unlined and unpermitted impoundments.
State RCRA personnel cited the owner/operator for
the operation of an unpermitted treatment system and
ordered the owner to submit a remediation plan for
state approval. Before the state could follow up on the
order, the impoundments were partially backfilled
with the wastes in place.   The facility  was later
destroyed by a fire of  suspicious origin. The owner
abandoned the facility and could not be located by
enforcement authorities.  The state contacted U.S.
EPA for an assessment of the site for a possible
federally funded response action.

U.S. EPA  initiated a  removal assessment with  the
following primary sampling objectives:

•   To  establish  the  identities and volumes of
    hazardous materials present  on the  site to
    determine the potential threat to the surrounding
    population and the environment.

•   To develop site stabilization strategies.
After federal funds were obtained and the site was
stabilized, EPA addressed two additional objectives:

•  To identify treatment and disposal options for the
   wastes on site.

•  To verify that established clean-up levels are met.

2.13.2  Site Entry

Within four hours of the initial request for assistance
from the state, an EPA On-Scene Coordinator (OSC)
and  other response personnel mobilized to  the site
with equipment to perform multi-media sampling.
The  next  day, the  OSC met  with the township
manager,  representatives from the county  health
department  and the Pennsylvania  Department  of
Environmental  Resources  (PA  DER), and  the
township Fire Chief.  The OSC reviewed PA DER
enforcement  reports  and aerial photographs which
indicated the presence and locations of chromium,
copper, and zinc plating process  areas.   The  OSC
interviewed local residents and performed a walk-
through,   donning Level  B  personal   protective
equipment  (PPE),   to   survey  the  general   site
conditions.  A site sketch was generated (Figure 6),
indicating the locations and container types of the
wastes. A total of nineteen 30- and 55-gallon  fiber
and metal drums, fifteen 250- to 500- gallon plating
vats, two  10- to 15- cubic yard waste piles, a feeder
trench leading to two 80 feet x  20 feet x 7 feet
partially filled impoundments, and a transformer were
located and noted in the site sketch.  Some rooms of
the building could not be entered because of unsafe
structural conditions caused by the fire.

The  OSC  and  PA  DER  reviewed  all available
information to formulate a sampling  plan  for the
drums, vats,  impoundments, and waste  piles.  The
entry team used  a judgmental sampling approach
during the initial assessment, first collecting samples
from containerized wastes for screening and possible
analysis    (suspecting   that   the   containerized
concentrated  material posed the greatest potential
hazard).
                                                  16

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                            Figure 6:  ABC Plating Site Sketch
                                                               Die
                                                                    D18  •Dig
VI
c55^
• 01
^
UlTi
plating vat
waste pile
drum
door
transformer
                                                                         Note: map Is not to scale
2.13.3  Site Inventory

During this phase of the response, a field entry team
in Level B personal  protective  equipment (PPE)
inventoried  drums,  plating  vats,   waste  piles,
impoundments, and a transformer found at the site.

Drums

The entry team numbered each drum and noted drum
type, size, condition, and label information on  a drum
inspection log (Figure 7).  The chemical properties of
constituents listed on labelled drums were researched.
Typical hazardous materials used at plating facilities
were determined from the references available; these
substances  include strong  acids  and  bases, heavy
metal  solutions  and  solids, and cyanide-bearing
compounds.

Vats

The plating vats were inspected, numbered, and noted
on the  site  sketch.  An estimate of the volume was
documented for each  of the vats.  All vats were
covered with non-reactive  polyethylene sheeting to
prevent  rain  water  from collecting in them and
increasing the waste  stream volume.

Waste Piles

The waste piles were inspected and noted on the site
sketch. Transects were established along the longest
horizontal axis of each pile.  The transects were also
noted on  the  site sketch.   The samples will be
collected and screening will be conducted along each
transect.

Impoundments

The  OSC determined that the contents  of the
impoundments posed  a potential direct contact hazard
to the surrounding population.   In preparation for
sampling, a transect was established from the entry
point of the feeder trench across each impoundment.
During site operation, wastes flowed from the feeder
trench into the impoundments.  Suspended solids were
suspected to be present in a gradient decreasing with
distance from the feeder trench.
                                                 17

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Transformer

The OSC was concerned that the single transformer
outside the plating building could  contain  PCB
dielectric fluid.    Inspection of  the transformer
determined  that  it  was  disconnected  by  first
responders during the facility fire.  The maximum
transformer volume, the type of oil used, the date of
manufacture,  and the manufacturer's name  were
indicated on the metal plate on the side  of the unit,
and this information was noted.  The unit was not
leaking,  so it  was numbered  and noted  on the site
sketch for future screening or sampling.

Information obtained from the site inventory and data
review was used to create a site-specific conceptual
model. Sources (e.g., vats, drums), pathways  (e.g.,
vapors from the impoundments, soil under leaking
drums), and potential receptors (e.g., local residents)
were  detailed to assist the selection of  sampling
approaches, objectives, and locations.

2.13.4 Selecting  Analytical
         Parameters

Analytical parameters were selected based on research
of plating chemistry and the initial site  screening.
Plating facilities generally use either an acid bath or
basic cyanide  bath to achieve the desired coating on
their  metal products.   Based on  the  researched
information and the measured pH of the liquid wastes
on site, the following compounds were suspected to be
present:

•    Sodium  and zinc  cyanide  salts and sodium
    hydroxide  (highly basic, grey to green color) from
    zinc plating practices

•    Chromic acid and sulfuric acid/sodium sulfate
    (acidic, yellow  or dulled color) from chromium
    plating practices
•  Copper sulfate and sulfuric acid (acidic, blue/green
   color) from copper plating practices.

During the assessment, liquid vat samples underwent
field screening to assist in the selection of analytical
parameters.  Samples from all highly basic solutions
were shipped to a laboratory for analysis of metals and
cyanide.  Acidic  samples were sent for analysis of
metals only.   The  composition of  some  of the
drummed materials  was initially  unknown.   In
addition to the plating chemicals listed above, other
possible drum contents included various cleaners, oils,
fuels, and solvents. Many of the drums still had labels
identifying their contents, and field  screening was
used to confirm content composition. Acids and bases
were easily identified with pH paper, which was by
far the most useful and inexpensive screening tool.

The  waste piles were thought to include plating vat
sludge waste. Samples collected from the piles were
sent for laboratory metals and cyanide  analyses.

Initial samples from impoundment liquids and solids
(large-volume unsecured waste streams) were sent for
full target analyte list (TAL), hexavalent chromium,
pH, and total and amenable cyanide analyses.  These
analyses  were conducted to fully characterize the
liquid  impoundment wastes for evaluation  of the
various on-site water treatment system needs.  This
information was  later used  to select optimum pH
conditions and flocculent type for maximum settling
efficiency.  A local industrial wastewater treatment
facility agreed to accept the liquid wastes if the heavy
metal  and cyanide levels were within their permit
parameters.    In addition  to evaluating off-site
treatment  and disposal  options, the  impoundment
bottom samples were characterized   using  target
compound list (TCL),  hexavalent chromium, total and
amenable cyanide, pH, and total alkalinity analyses to
allow  evaluation of possible  on-site  stabilization,
solidification and treatment techniques.
                                                   18

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Figure 7:  Example of a Drum Inspection Log
DRUM INSPECTION LOG
Site:
Location:

Drum Number: Date:
Project Code Number: Time:
Type of Contents: SOLID LIQUID SLUDGE
Color PID
LAB PACK

pH CGI
FID
Amount of Contents: Full 3/4 1/2 1/4
Drum Size: 5 5 -gallon 41 -gallon 30-gallon
Drum Markings:
Less than 1"
5 -gallon




Hazard Class Label:
Drum Type: 17H 17E 37M Fiber Overpack
Drum Construction: Metal Poly Fiber Polylined
Drum Condition: Deteriorated Leaking Dented
Sample Method: Pipette Trowel Other
Sample Number Custody Sheet Number
Other
Other
OK/DOT

Comments: LAYER DESCRIPTION







Observations by:








                   19

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   3.0  FIELD ANALYTICAL SCREENING AND SAMPLING EQUIPMENT
3.1    INTRODUCTION

Field analytical screening techniques and equipment
may  provide valuable  information for developing
sampling strategies.  Field analytical screening can
determine chemical classes of wastes and in some
cases can identify particular substances of concern.
Real-time or direct-reading capabilities narrow the
possible groups or classes of substances which aids in
selecting the appropriate laboratory analytical method.
These screening techniques are useful and economical
when gathering large amounts of site data. Some of
the commonly  used screening  methods for  waste
analysis are presented in this chapter in the general
order that they would initially be used at a waste site,
although site-specific conditions  may mandate  a
different sequence.   This chapter focuses on site-
screening methods, but the instruments described
below have specific health and safely applications as
well.  Refer to the Compendium of ERT  Waste
Sampling Procedures, OSWER Directive 9360.4-07,
for specific information about most of the following
techniques or equipment. Refer to Standard Operating
Safety  Guides  for  each  instrument,  and  the
Occupational Safety and Health Guidance Manual
for Hazardous  Waste Site Activities  (NIOSH Pub.
85-115) for site entry information.

3.1.1  Combustible Gas Indicator

The combustible gas indicator (CGI) measures the
concentration of a flammable vapor or gas in the air,
registering  the results as a percentage of the lower
explosive limit (LEL) of the calibration gas.  The CGI
is often combined  with an  oxygen  meter;  some
contemporary models also have built-in compound-
specific  detectors  (e.g.,  hydrogen  sulfide,  sulfur
dioxide,  carbon  monoxide,  and hydrogen cyanide).
CGIs are particularly useful for entry into unknown
and/or confined space atmospheres.

There are several factors that must be considered
when using  a CGI for waste site work. The accuracy
of the reading is temperature dependent; the CGI must
be calibrated at ambient temperatures.  The sensitivity
of the CGI is also  a function of the  physical  and
chemical properties of the calibration gas versus those
of the unknown atmosphere.  Oxygen concentrations
that are less than or greater than normal may cause
erroneous  readings.    Leaded  gasoline  vapors,
halogens,  silicates,  and  sulfur compounds  can
decrease sensitivity.  As a sample screening tool, the
CGI is of limited  value  because  it  yields non-
qualitative results for flammable vapors.

3.1.2  Radiation Screening
        Instruments

Screening for ionizing radiation is mandatory for all
Superfund assessments, primarily for health and safety
reasons.  Since gamma rays and X-rays have high
penetration capabilities even at extended distances,
radiation screening instruments are generally used
during the initial site entry.  As containerized wastes
are opened, alpha and beta radiation which was not
detected during the initial walk-through screening may
be encountered.

Most  of the commonly used radiation screening
instruments have gamma or beta/gamma detecting
probes. Pure alpha detectors are not commonly used
on site because the probes are too fragile and because
pure  alpha emitters   are  rare.   However,  an
alpha/beta/gamma probe is suggested for screening
wastes in lab packs, research facilities, laboratories,
and on military installations where radioactive waste
may be present (e.g., Department of Defense (DOD)
and Department of Energy (DOE) installations).

3.1.3  Flame lonization Detector

The  flame ionization detector  (FID)  detects and
measures the  level  of total organic  compounds
(including  methane) in the ambient  air or in a
container headspace.   The  FID is used  to evaluate
existing conditions, identify potential sample locations
and extent of contamination, and support health and
safety  decisions.   The FID uses the  principle of
hydrogen  flame   ionization  for  detection  and
measurement.   It is especially effective  as an
ethane/methane detector when used with an activated
charcoal  filter  because  most  organic  vapors are
absorbed as the sample passes through the filter,
leaving only ethane and methane to be measured.
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The FID operates in one of two modes:  the survey
mode, or the gas chromatography (GC) mode.  In the
survey mode, the FID provides an approximate total
concentration of all detectable  organic  vapors and
gases measured relative to the calibration gas (usually
methane).  The GC mode identifies and measures
specific components, some with detection limits as
low as a few parts per million (ppm), using known
standards run concurrently in the field.  Since the GC
mode  requires standards  to  identify  classes  of
compounds, before sampling it is necessary to have an
idea of which compounds might be present on site.
Advantages  of the  FID  are  that it  is  portable,
relatively rugged, and provides real-time results.

The FID does not respond to inorganic substances. It
has positive or negative response factors for each
compound depending on the selected calibration gas
standard.  The  FID does not recognize and may  be
damaged by acids;  use pH paper to screen acids.
Ambient air temperatures  less  than  40  degrees
Fahrenheit  will cause  slower  responses;  relative
humidity  of greater than  95  percent  can  cause
inaccurate and unstable responses.  Low  ambient
oxygen levels can  cause the flame to  go out; use a
CGI/oxygen meter  in conjunction with an FID  in
confined  space applications.    Interpretation  of
readings (especially in the GC mode) requires training
and experience  with the instrument.

3.1.4  Photoionization Detector

Another portable air monitoring instrument frequently
used for field screening is the photoionization detector
(PID).  Like the FID, the PID provides data for real-
time total organic vapor  measurements evaluating
existing  conditions, identifying  potential  sample
locations and extent of contamination, and supporting
health  and safety decisions.  The PID works on the
principle of photoionization. Unlike the FID, the PID
can be used to detect  gross  organic, and some
inorganic  vapors  depending  on  the  substance's
ionization potential (IP) and the selected probe energy.
It  is portable  and  relatively easy to operate and
maintain in the field.

The  PID  detects total  concentrations  and is not
generally used to quantify specific substances. PIDs
cannot  detect  methane; however, methane  is  an
ultraviolet (UV) light absorber,  and false negative
instrument  readings may register in  methane-rich
environments. The PID cannot detect substances with
IPs greater than that of the UV light source. Readings
can  be affected  by high wind speeds, humidity,
condensation, dust, power lines, and portable radios.
Dust particles and water droplets (humidity) in the
sample may collect on the light source and absorb or
deflect UV energy, causing erratic responses in PIDs
not equipped with dust and moisture filters.

3.1.5  Colorimetric Tubes

Colorimetric indicator tubes (e.g., Drager, Sensidyne,
MSA) provide real-time results in  environments
where a specific gas or vapor  is suspected to  be
present.   In waste sampling, they  are  useful for
situations such as screening drums, where drum labels
provide limited information on the contents of only
some of the drums.

Colorimetric tubes consist of a glass tube filled with
silica gel or a similar material impregnated with an
indicator reagent which changes color in the presence
of specific contaminants. The tube is attached to an
intrinsically safe piston-syringe or bellows-type pump
which slowly pulls a measured volume of air through
the tube.   The contaminant then reacts with the
indicator chemical within the tube producing a color
change  proportional to  the  concentration  of the
chemical.

Although the indicator tubes are usually chemical or
class specific, interferences can occur.  Common
interferences are  noted  in the  directions  for the
specific tube.  The  tubes have a limited shelf life, and
cannot be reused.  Results can be misinterpreted due
to cross-sensitivity, and there exists a potential for
error in reading the end point of color change. Errors
result if the limit  of the tube has been exceeded (in
very  concentrated environments).  High humidity may
reduce tube sensitivity.

3.1.6  Hazard Categorization

Hazard categorization (haz-catting) is performed as an
initial  screen for hazardous substances to  provide
identification  of  the classes/types  of  substances
present in individual waste streams. Haz-catting tests
for general chemical characteristics or the presence of
specific ions to determine chemical class; it is not
compound-specific. The information from haz-catting
is useful for determining compatibility of unknown
wastes.
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Various   indicators  and   wet  chemistry   tests
characterize   the   wastes   according  to   their
chemical/physical   properties   (e.g.,   solubility,
combustibility), and indicate the presence of sulfides,
oxidizers, and cyanide.   The haz-catting procedure
requires    numerous    chemical   reagents    and
interpretation  of  results.   Common  haz-cat  tests
include the char test for differentiating organic from
inorganic substances; chlorine hot wire test to detect
chlorine  in organic solvents; combustibility  test;
cyanide  test  for cyanide  salts;  flame  test for
identifying cations and some anions; iodine crystal
test for solvent classification; oxidizer test; sulfide
test; water solubility test; and/)// test.

3.1.7  Immunoassay Tests

Immunoassay tests can be used on site to screen for
certain organic compounds such as pentachlorophenol
(PCP), PCBs, and pesticides. Immunoassay tests are
used  for  locating   and mapping  the  extent  of
contamination, and for screening samples in the field
prior to laboratory analysis.

Immunoassay   tests   utilize   semi-quantitative,
colorimetric methods.  Some of the commonly used
tests  utilize  tubes  coated  with a chemical that
specifically binds to the contaminant. These types of
tests utilize highly selective antibodies and sensitive
enzyme  reactions   to   yield   qualitative,   semi-
quantitative, and  quantitative results for a specific
compound or for a closely related series of compounds
(e.g., PCP, PCBs, and 2,4,D-pesticides).  Antibodies
can be either coated on the test tube, or attached to
microparticulates or reaction well/ plates, depending
on  the brand.  Other types of  immunoassay  tests
utilize   enzyme-linked,   immunosorbent   assays
(ELISAs)  and magnetic particles to  bind to the
contaminants.

The concentration range of a sample is determined by
comparing the color change of the  sample with that of
duplicate standards  of known concentrations.  The
color  intensity  in   each tube  decreases as  the
contaminant concentration increases.  Photometers are
available to "read"  and digitally display, print, and
store the color difference between the prepared sample
and the standards. Since the results are compared to
standards, the  accuracy achievable is a contaminant
range  (e.g., greater than 100 ppm but less  than
1,000 ppm). Laboratory confirmation is required when
using  these  tests  in  the  semi-quantitative  and
qualitative modes.  Performance  evaluation spikes
determine the efficiency of the test.  Some training is
needed to effectively run and interpret immunoassay
tests.

3.1.8  X-Ray  Fluorescence

Field analytical screening  using X-ray fluorescence
(XRF) is a cost-effective and time-saving method to
detect and classify  lead and other heavy metals in
wastes.  XRF screening provides immediate semi-
quantitative results.  The principle behind XRF is the
detection and measurement of the X-rays released
from  an atom when it is ionized.  The measure of
energy released identifies the atom present.

Results of XRF analysis help determine the presence
of metals and are often used to assess the  extent of
soil contamination at a site. For waste sampling, the
XRF  can be used for screening waste piles and for
assessing metals in certain liquids such as paint. XRF
use requires a trained operator  and may require
numerous site-specific calibration samples.

3.1.9  Gas Chromatograph

Although many FIDs are equipped with a GC mode,
an independent, portable GC can also be used on site
to provide a chromatographic profile of the occurrence
and intensity of unknown volatile organic compounds
(VOCs).  The  GC  is useful as a screening tool to
determine  "hot spots," potential interferences,  and
semi-quantitation of VOCs and semi-volatile organic
compounds (semi-VOCs).

Compounds with  high response factors, such  as
benzene and toluene, produce large response peaks at
low concentrations, and can mask the presence of
compounds with lower response factors.  However,
recent improvements in GCs, such as pre-concentrator
devices  for  lower  concentrations,  pre-column
detection  with  back-flush capability  for  rapid
analytical time, and the multi-detector (PID, FID, and
electron capture detector (BCD)),  all enable  better
detection of  compounds.    The  GC  is  highly
temperature-sensitive. It requires set-up time, many
standards, and operation by trained personnel.
                                                   22

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3.2    SAMPLING EQUIPMENT

Representative   waste   sampling   requires   an
understanding of the  capabilities of the  sampling
equipment, since the use of inappropriate equipment
may result in biased  samples.   Select appropriate
sampling equipment based on the sample type and
matrix,  physical location of the  sample point, and
other site-specific conditions.  Consideration must be
given to the compatibility of the waste with the design
and composition of the sampling device.  Follow
SOPs for the proper  use and decontamination of
sampling   equipment.    This   section  provides
descriptions of drum opening and sampling equipment
descriptions,  and  other  information  to  assist in
selecting  appropriate  equipment.   Refer to the
Compendium of ERT  Waste  Sampling Procedures,
OSWER Directive 9360.4-07, for expanded guidelines
on the use of the equipment discussed below.

3.2.1   Drum Openers

Closed drums need to be opened for sampling.  Tools
suitable  for opening drums include:  universal bung
wrench, drum deheader, backhoe spike, hydraulic
drum opener, and pneumatic bung remover.  Each of
these devices has specific applications based on the
drum  type, composition, condition,  location,  and
suspected contents.

Follow ERT  SOP  #2009 (Drum Sampling) in the
Compendium of ERT  Waste  Sampling Procedures,
OSWER Directive 9360.4-07,  for  guidelines  on
opening drums and the operating instructions for the
particular equipment used. Always use non-sparking
instruments to open drums and comply with proper
health and safety protocols.  Note that the use of a
non-sparking tool does not completely eliminate the
possibility of a spark being produced. Drums should
be grounded to decrease the chance of static charges
and sparks. Stage drums by suspected compatibility
type prior to opening  and sampling to decrease the
risk  of  chemical  reaction   between incompatible
substances.

3.2.2  Liquid Samplers

The following samplers are useful for collecting waste
liquids from various sources:  composite liquid waste
sampler (COLIWASA), glass  thief, bailer, and bacon
bomb.   Each  has specific applications  for use
depending on the type and nature of the waste and the
type of source.

COLIWASA

The COLIWASA is a tool typically used for sampling
stratified  liquids  in   drums  and  other similar
containers.  It is a transparent or opaque glass, PVC,
or Teflon tube approximately 60 inches in length and
1 inch in diameter. A neoprene stopper at the bottom
of the tube can be opened and closed via a rod that
passes through the length of the sampler.

The COLIWASA is difficult to decontaminate in the
field but is versatile and simple to operate.  Because
of the relatively high cost of the  COLIWASA,
COLIWASA-type glass thieves have been developed
which  utilize  neoprene  or  ground  glass stopper
mechanisms.     Before  conducting  multiphased
sampling, make sure that the physical and chemical
properties of the  container's contents and  phases are
understood.

Glass Thief

Another commonly  used drum sampling device, the
glass thief, is a hollow glass tube 40 to 48 inches in
length and commonly  10 mm to 19 mm in diameter.
The larger diameter tubes are used to collect more
viscous materials.  The glass  thief is  simple  to
operate, versatile, and disposable,  eliminating the
need for decontamination.

Conduct  the sampling carefully in  order to  avoid
sample spillage.  Low  viscosity liquids, thin-layered
phases, and partially filled containers may be difficult
to sample with a hollow glass thief.  In those cases,
use the COLIWASA-type glass thief, whose stopper
mechanism prevents the sample from leaking out of
the thief as it is removed from the container.

Bailer

A bailer is used to  sample waste liquids in vessels
(wells, tanks, or deep containers) where the liquid
surface is far below the sampling entry access (i.e.,
too far for a glass thief or COLIWASA).  The bailer
consists of a hollow tube (constructed of relatively
inert materials such as stainless steel, glass, or Teflon)
with a bottom ball-check valve, usually  suspended
from a wire or rope for sampling.  Bailers are good for
                                                  23

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sampling VOCs because of the relatively low surface-
to-volume ratio which reduces off-gassing.

Most bailers cannot obtain discrete depth or phased
samples,  so their use  is  primarily  limited  to
homogeneous liquids or shallow (length of bailer)
sampling.    As  with any  sampling  device,  the
construction material should not interfere with the
wastes or the desired analytical parameters.

Bacon Bomb

The  bacon bomb sampler is used to collect waste
liquid  samples from various  levels  within  storage
tanks or surface impoundments.  Storage tank  and
impoundment wastes  are  often stratified,  and  the
bacon  bomb is useful when a  discrete sample is
needed from any level in the tank or impoundment.
The bacon bomb consists of a cylindrical body with an
internal tapered plunger for sampling. A separate line
attached to the top of the plunger opens and closes the
bottom valve at the desired depth or stratum.   A
removable top cover attaches the sample line and has
a locking mechanism to keep the plunger closed after
sampling.  The bacon bomb is usually constructed of
chrome-plated brass and bronze or stainless steel. A
rubber O-ring acts as the  plunger sealing surface.

Transfer of the sample to  sample  containers is
sometimes difficult and  tends to  aerate the sample,
resulting in loss of volatile constituents. The bacon
bomb sampler can be more difficult to decontaminate
than a bailer.

3.2.3  Sludge  Samplers

The following devices are useful for sampling waste
sludges:   Ponar/Ekman  dredge, sludge judge,  and
PACS  grab sampler.

Ponar/Ekman Dredge

Ponar/Ekman dredges are  clamshell-shaped scoops
that are used to extract waste sludge samples from the
bottom of impoundments,  lakes, or  other standing
water bodies.  The Ponar dredge's jaws are  latched
open and the unit is slowly lowered to the bottom of
the area being sampled. When tension is eased on the
lowering cable, the latch  releases, and the  lifting
action  of the cable on the lever  system closes the
dredge around a sample of sludge.  The Ekman dredge
operates similarly but it closes by using a messenger
or depressing a button on the upper end of the handle.

The substrate depth to which both dredges can sample
usually does not exceed 4 to 6 inches, and they are not
capable of collecting an undisturbed sample.   As a
result, material in the top inch of sludge cannot be
separated from  material  at  lower depths.   The
sampling  action  of the  dredges causes agitation
currents  which may temporarily  re-suspend some
settled solids, especially the fine fraction.

Dredges are  normally used  from a boat or dock.
Because the dredges are heavy, a boom is frequently
used  to  ease the raising and  lowering of  them.
Dredges are not usually effective in sampling hard or
stony bottom material.  Bottom vegetation will also
limit dredge effectiveness.

Sludge Judge

The sludge judge is  a long narrow tube with a check
valve on the bottom, used primarily to obtain cores of
waste sludge, or waste liquids mixed with sludge,
from drums, tanks, or similar sources.  Sludge judges
are useful for determining the physical state of a tank's
contents or its volume of settled sludge. The sludge
judge is constructed of PVC which can limit its use
because   of   potential  interference   with  the
contaminants of concern. The device is  difficult to
decontaminate and  not recommended for use with
very thick sludges.

PACS Grab Sampler

The PACS grab sampler is used to collect sludge
samples   at   discrete   depths   from  surface
impoundments such as ponds and lagoons and also
from  certain  types  of containers.  The PACS grab
sampler consists of a  1000-ml wide-necked bottle with
a control valve which screws on to the end of a 2-
meter long handle.   Large openings in the  bottle
facilitate sample  collection.   The control valve is
operated from the top of the handle once the sampler
is at the desired depth. Depth of sampling is limited
by the length of the pole  handle.  The device is not
useful in very viscous sludges, and it can be difficult
to decontaminate.
                                                  24

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3.2.4  Solids Samplers

The following devices are used to collect samples
from waste piles and other sources of solid waste:
scoop/trowel, bucket auger, sampling trier, waste pile
sampler, cork screw auger, and split-barrel sampler.

Scoop/Trowel

Scoops or trowels are useful for collecting solid or
sludge  samples  from waste  piles.    Collection is
usually  limited to near-surface  and depends  on the
length of the scoop or trowel.  These instruments are
available in a variety of materials, including stainless
steel and plastic.  Stainless steel scoops and trowels
are appropriate for VOC sample collection but require
decontamination between sampling stations.  Plastic
scoops and trowels are suitable for metal analyses and
are  disposable,   which  eliminates  the  need  to
decontaminate between sampling  stations.  Do not use
trowels  with painted or chromium-plated  surfaces,
because the paint or plating  can chip off into the
sample.

Bucket Auger

Bucket  augers are typically composed of stainless
steel and are used to collect solid or sludge samples
from waste piles or surface impoundments. The auger
is  effective  for subsurface sampling, but tends to
destroy  horizons during  sampling,  making  VOC
collection difficult. The bucket auger is therefore not
recommended for VOC collection; use a split-barrel
sampler instead. Bucket augers can be used for sludge
sampling in a surface impoundment, depending  on
accessibility.

Bucket augers provide uniform sampling diameter and
good depth  control, and are easy to decontaminate.
Their effectiveness is reduced in rocky or hard solids,
heavy clays, or very sandy solids.

Sampling Trier

A  sampling trier is used  to collect  powdered  or
granular materials from bags, fiber or metal drums,
sacks, or similar containers. A typical sampling trier
is  a long tube with a slot which extends almost  its
entire length. The tip and edges of the tube slot are
sharpened so that when rotated after insertion into the
material, the trier cuts out a sample core.  Sampling
triers range from  24 to 40 inches in length and from
1/2 to  1 inch in diameter, and are usually made of
stainless steel (or a similar composition) with wooden
handles.   Triers are relatively  easy  to use  and to
decontaminate.

Waste Pile Sampler

The waste pile sampler is essentially a large sampling
trier used for sampling large waste piles (with cross-
sectional diameters greater than 1 meter).  It can also
be used for sampling granular or powdered wastes,
and material in large bins or barges.

The waste pile sampler is commercially available, but
one can be easily and inexpensively fabricated from
sheet metal or plastic pipe.  The sampler does not
collect representative samples when the diameters of
the solid  particles are greater  than one-half the
diameter of the tube.

Cork Screw Auger

The cork screw auger is a hand-driven sampler used to
sample bulk solid wastes such as waste piles.  The
auger tip resembles a large drill bit ranging from 3/4
to 1-1/2 inches in  diameter. The auger is used for
sampling  at depth by adding rod extensions.  It is
effective in soft to hard materials, although saturated
waste may be difficult to sample.  Decontamination of
the auger is relatively easy. The cork  screw auger
disturbs the waste profile and thus has limited utility
for VOC sampling.

Split-Barrel Sampler

The  split-barrel sampler (also called a split-spoon
sampler) is used to collect waste samples from the
bottom of boreholes. The split-barrel sampler consists
of a hollow tube with a circular chisel or cutting  shoe
threaded onto one  end  and a driving head or collet
threaded onto the other end. The  sample tube is split
lengthwise  into two halves  to facilitate sample
removal  and decontamination.  A  drilling rig is
required to use the split-barrel sampler. The sampler
is attached to the end of the drilling rod and is driven
into  the bottom of the borehole with a specially
designed,  140-lb. drive hammer.  The split-barrel
sampler can be used to determine the relative density
of the material that is being cored or  drilled by
counting the number of drive hammer blows it takes
to drive the barrel 18 inches below the bottom of the
borehole.

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The  split-barrel sampler  is useful for collecting
relatively  undisturbed  waste samples  from  great
depths.  Because split-barrel samplers do not disturb
the sample, they  are suitable for sampling VOCs.
They can be used to sample deep into  large waste
piles, subsurface wastes, or dry lagoon beds, but they
are not effective  in  rocky or  very  consolidated
materials.
3.3    EXAMPLE SITE

After conducting proper site entry procedures (health
and  safely  monitoring),  the  OSC  utilized  field
screening techniques to the greatest extent possible.
This allowed for the rapid collection of information to
support the decision-making process and to limit the
need for laboratory analysis. All waste streams were
screened (as discussed below) to determine which
laboratory  analyses  would be necessary,  and to
provide a logical basis for selecting a limited number
of analytical parameters. All waste streams were also
screened for radiation; none was detected.

3.3.1  Drum Screening and Sampling
        Equipment

Each of the closed drums appeared to be in relatively
good condition, showing no signs of internal pressure
or other instability, and were opened using a spark-
proof bung wrench. Five drums were already open to
the elements. After each drum  was opened, samples
were collected for screening using a glass thief. All
drums were screened using haz-catting procedures.
All haz-catting information was recorded in the field
on a Hazard Categorization Data Sheet (illustrated in
Figure 8).  The first haz-catting procedure conducted
was for pH. Four drums were found to contain strong
acids; five drums contained strong bases.  Various
colorimetric tubes were used in an attempt to identify
specific  acids;  however, all  the tubes  exhibited
positive  reactions due  to interferences  from the
presence of similar  strong acids.  Since cyanide-
bearing  solutions are typically  basic,   all basic
solutions were screened for the presence of cyanide to
prevent the potential generation of hydrogen cyanide
gas (HCN) during handling. As a result of screening,
three   drums   containing basic solutions   were
tentatively determined to contain cyanide. Additional
haz-cat screening (PID, FID, solubility, chlorine, and
peroxide) was conducted for the ten drums exhibiting
relatively neutral pH.   From this additional screening,
three drums of oil, one drum of halogenated solvents,
and one drum of kerosene were tentatively identified.
Two drums were suspected to contain rainwater.  The
screening results were inconclusive for three drums.

The drums containing strong acids and bases were, by
definition,  RCRA hazardous  characteristic wastes.
Because of the risks associated with strong acids and
bases, there was no need for further data analysis to
establish imminent threat.  The entry team separated
incompatible  materials  to reduce the  risk  of a
chemical reaction/release.

3.3.2  Plating Vat Screening  and
        Sampling  Equipment

Some plating vats were already open; others had large,
easy-to-open lids similar to that of a trash dumpster.
The vat liquids  and bottom  solids were screened
separately in the same manner as the drums, using a
COLIWASA-style glass thief to collect the samples
and haz-catting to identify the wastes. The samplers
were  long enough to reach the bottom of the vats,
providing  a sample of the  entire vertical column of
liquid. A hollow glass thief was then used to collect
a single grab sample from the bottom solids in each
vat.

The vat contents were tentatively identified as strong
acids, strong bases, and cyanide bases. Haz-catting
results were inconclusive for four vats.  No volatile
organic compounds were detected using PID and FID
instruments.

3.3.3  Waste Pile Screening and
        Sampling  Equipment

The piles contained blue and green solids that were
assumed to be bottom solids cleaned from the plating
vats.  Screening  samples from the waste piles were
collected using a corkscrew auger and stainless steel
trowels (because of the hardened texture of the piles).
Waste pile samples  were haz-catted in the  same
manner the samples from drums and vats. However,
since haz-cat tests are better suited to liquid matrix
waste streams, the two waste piles were  difficult to
classify into general hazard categories.

Screening results indicated that the wastes were not
water reactive, flammable, combustible, or chlorine-
bearing;   organic  compounds were  not detected.
Results  of the cyanide test were positive.  Sample
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color and other visual signs of contamination were
documented as the screening samples were collected.

3.3.4 Impoundment Screening and
       Sampling Equipment

Screening samples were collected from both surface
impoundments. Waste liquids were sampled using a
bacon bomb sampler, and waste bottom sludges were
sampled using a Ponar dredge. Waste liquid samples
were taken  from the center of each impoundment at
depths of 0 to 2 feet, and 2 feet to bottom. Five waste
sludge samples were collected from the bottom of
each impoundment at 20 foot intervals along a transect
established  across each impoundment.   A small
rowboat with stabilizing lines was moved along the
transects to  collect screening samples.

Impoundment liquids were screened by haz-catting.
The  results indicated   that impoundment liquids
contained water and were slightly acidic, possibly
cyanide-bearing, non-flammable, and non-chlorinated.
The PID and FID did not detect any organic vapors,
suggesting a non-organic wastewater classification.
A chemical test kit  was used to identify low levels of
specific  metals   in  the  impoundment  liquids.
Screening of the bottom sludge had similar results,
except for a higher metals content and the positive
presence of cyanide.

3.3.5 Transformer Screening  and
       Sampling Equipment

The transformer top was  removed using a standard
socket wrench. A transformer fluid screening sample
was  collected using a makeshift sampling  device
consisting of a clean, 4-oz sampling jar on a string.
The transformer was screened for PCBs using a PCB
screening kit.  A grab sample was collected and the
test was performed on site following  the directions
provided with the kit.  The potential interferences
listed in the directions were determined not to apply to
this  sampling event.   The test  indicated that  the
transformer contained less than the 50 ppm total PCBs
action level (based on a colorimetric interpretation).
The sample fluid was placed back into the transformer
and the vessel was resealed.
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                    Figure 8: Example of a Hazard Categorization Data Sheet
                                 HAZARD CHARACTERIZATION DATA                    Page	of	
Site:                                                       Date:
Sampler(s):	                       Sample ID Number:
Phase:    All   Top    Bottom N/A                    Sample Collected?:      Yes    No






                                HAZARD CHARACTERIZATION RESULTS




Soluble:  Yes (dissolves/emulsifies in water)       Heavier (than water)     Lighter (than water)




pH:	(if using instrument, round to nearest whole number)




Flammable:   Yes No




Chlorine:   Yes  No




Oxidizer:     Yes No




Cyanide:      Yes No




Sulfide:      Yes No




Other Test A:	




Other Test B:	




Action  Taken:  Overpacked    Staged (location	)     Bulked Other	
Sort Class:	(optional—specify 2 character alphanumeric designator to assign user sort class)






                                        SAMPLE DESCRIPTION




Color(s):   Colorless White  Yellow     Blue    Red    Green  Purple  Brown Black   Other	




Clarity:    Clear   Cloudy   Turbid (suspended solids)    Opaque N/A (if solid)




Viscosity:  Water   Light Oil   Heavy Oil       Sludge  N/A (if solid)




Impurities:	




Comments:
                                                           Observations by:
                                                  28

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           4.0  FIELD SAMPLE COLLECTION AND PREPARATION
4.1     INTRODUCTION

During  a response  action,  proper field  sample
collection and preparation is as important as proper
sampling equipment  selection.  Sample  collection
refers to the physical removal  of a portion of waste
material from its source for the  purpose of either
screening or laboratory  analysis.   Field  sample
preparation refers to all aspects of sample handling
from collection to the time the  sample is received by
the laboratory. This chapter provides information on
sample collection and preparation for various waste
types and sources.
4.2   SAMPLE VOLUME

The volume of a  sample should be sufficient  to
perform all  required laboratory  analyses with an
additional amount remaining for analysis of QA/QC
samples (including replicate analyses).   However,
because  waste  samples  are  generally  of high
concentration,  sample volumes should be kept to a
minimum  (to minimize disposal  costs).   The EPA
method description and the laboratory receiving the
sample should be consulted  for specific volume
requirements for each parameter.

Make  an initial estimate  of the volume or area  of
waste represented by each sample. When obtaining
representative samples from waste which appears to
be  relatively homogeneous, note the total waste
volume in cubic yards or gallons.
4.3   SOURCE SAMPLING

The following sections provide general information on
sampling several types of waste sources, including
drums,  bulk  storage  tanks,  lab  packs,  surface
impoundments, waste piles, surfaces, and debris. For
specific sampling information on these waste types,
refer to the Compendium of ERT Waste Sampling
Procedures,  OSWER Directive 9360.4-07.
4.3.1  Drum Sampling

Each   drum  can  have  different  contents  and
concentrations, so each must be considered a unique
waste source.  A site-wide representative sampling
approach is not appropriate.  Screening techniques
should be used on the contents  of each drum  to
determine compatibility. This haz-cat information can
help  determine  whether  bulking  of  wastes  is
technically and economically feasible.

Drums may be sampled in place  or staged in rows
prior to sampling, depending on their condition and
accessibility.   If drums  are  stacked, a forklift  or
grapple may be needed to move them for sampling.
(If  drums cannot be safely moved, sample only
accessible drums.)  When moving drums, document
on a site sketch their original locations. Number all
drums and record their label information on a drum
log sheet (see Chapter 2, Figure 6).  Research all label
information   to   determine   health  and  safety
precautions, including use of appropriate PPE. It does
not necessarily follow that the labels affixed to the
drums represent their actual contents.  (Drums are
often  reused without regard to proper rinsing and
relabelling procedures.)   Further categorization  is
necessary to  determine or confirm  drum contents
accurately.  Be particularly cautious with drums that
have crystalline deposits or a precipitate around the
bung  or lid.   Some  chemicals form a  potentially
shock-sensitive, explosive, or reactive phase as they
degrade or react over time (e.g.,  picric  acid forms
shock-sensitive crystals). Do not move drums in this
condition!

Bulging  or  misshapened drums  and those with
unknown contents should be opened remotely. Rough
handling can trigger reactions which may  cause them
to rupture.   Open unknown  or unstable  drums
remotely.  If drums contain a combination of solid,
liquid, or sludge  wastes, separate sampling of each
phase may be necessary using chemically  compatible
sampling equipment  (e.g.,  COLIWASA  or  glass
thief).  Where wastes are stratified, sample the top
stratum first to avoid mixing strata.  Since each drum
may contain a different type of waste, it is usually not
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possible to make composites from separate drums
until the contents have been screened. As with most
containers, drums should be sampled through upper
bungs or openings whenever possible.  Document
contents,   physical  characteristics  (e.g.,   color,
viscosity)  and field screening readings (e.g., FID,
PID, CGI).

Refer to Section 2.11.1 for a discussion of judgmental
sampling as it applies to drum sampling.

4.3.2 Bulk Storage Tank  and
       Transformer  Sampling

Bulk storage tank  sampling involves many of the
procedures and precautions  noted for drum sampling.
Number and document each tank, noting National Fire
Protection  Association  (NFPA)  704 markings, if
present. Document available information on vessel
construction, tank location  (e.g., in a tank farm), and
the presence of any secondary containment.  Estimate
maximum tank volume using mathematical volume
equations  (V=Br2h) or tank  charts.  Measure the
content  volume  using exterior level indicators, if
present.

Perform  sampling  through top hatches  whenever
possible; avoid using bottom valves because a spill is
possible if the valve does not reseal. When there is
more than one phase, identify the distinct phases and
associated  volumes.   The  objective is to  identify
volume in gallons (liquids) or cubic yards (solids) to
determine the total waste volume that  each sample
represents.  Sample each phase separately, including
tank bottom sludges (use  a bacon bomb sampler,
PACS grab sampler,  or  a  sludge judge).   Obtain a
sample from each compartment in multicompart-ment
tanks.

When sampling specialized tanks or transformers, it
may be necessary to use a manlift to gain access. Be
certain that transformers   are  "off-line"  and  de-
energized.  Exercise spill control measures and ensure
secondary  containment  is  in  place around  a
transformer before opening it. Access a transformer
through the top and collect  a stratified sample.

4.3.3 Lab Pack Sampling

Initial inspection of lab packs may uncover packing
slips listing contents  and associated volumes.  The
packing slips may  be affixed to the outside of the
drum or under the drum lid. If the labels on individual
containers are  legible, inventory the containers and
repackage them in inert cushioning and absorbent
materials in accordance with 49 CFR 100-199. If the
label is illegible or missing, the lab pack should be
treated as an unknown.  Unknowns are generally not
manually opened because of the potential health and
safety  risks (exposure  and reactivity).   A  safer
approach  is to use  remote  opening  or crushing
techniques and collecting the crushed containers and
their contents in an absorptive medium, which is then
sampled using a representative composite sampling
method.

4.3.4  Surface Impoundment
        Sampling

When sampling a surface impoundment, consider its
characteristics, which include size, depth, flow, liquid
viscosity, bottom composition  and whether a liner is
present. The bottom sludges and liquid phases may be
homogeneous or stratified.

Surface impoundments are often stratified by depth;
each phase should be sampled separately. Transect
sampling at various depths (including bottom sludge
sampling) is generally  recommended.  Horizontal
concentration gradients in the bottom sludges may be
present from  the  point  where liquids enter the
impoundment. Vertical gradients may also be present
in bottom sludges. The logistics and health and safety
concerns of sampling large impoundments usually
dictate  the use of manlifts, boats, and safety lines. If
a liner  is present, take care to maintain its integrity.

4.3.5  Waste Pile Sampling

Waste  pile sample collection techniques will depend
upon the sampling objective.  If the objective is to
determine threat, grab sampling from the surface using
a waste pile  sampler or a scoop/trowel might be
sufficient.  If the objective is to obtain an average
concentration  value  for  the  entire   pile  for
treatment/disposal estimates, then the sampling should
include grab samples or composite aliquots collected
from the interior (using a waste pile sampler or an
auger) and the surface of the pile.  Composite aliquots
collected at a given depth from several sides and the
top of the pile can be used to obtain an estimate of the
average pile concentration.  The number of aliquots
collected will depend on many site-specific factors,
                                                  30

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including the size, composition, and accessibility of
the waste pile, as well as on budget considerations.

The surface of a pile continually weathers chemically
and physically. Depending on the size of the pile, it
may be  divided into  sections for compositing at
various  depths.    This will define  an  average
concentration for each section of the pile.  For large
piles (e.g.,  large impoundment dredge or slag piles),
a three-foot depth is generally adequate to reach the
more representative materials.  Extensive sampling of
a pile for both chemical and physical characteristics is
conducted  during  the  evaluation of treatment and
disposal options. If the pile has been stabilized (e.g.,
cover, liner), do not collect samples that might breach
the integrity of the pile containment.

4.3.6  Surface Sampling

Special situations  may  present the need to sample
surfaces  such as floors, walls, or equipment.  When
sampling surfaces for contamination, choose sampling
points based on site history, manufacturing processes,
personnel  practices,  obvious contamination,  and
available  surface  area.   Where  possible, collect
comparable media background samples from surfaces
unlikely  to  have  been  contaminated.    This is
especially  important when  sampling for naturally
occurring substances such as metals.

Surface  sampling includes wipe,  chip,  and  dust
sampling.  Analytical results for dust sampling are
reported  in weight/weight; wipe sampling results are
reported in weight per unit area.  Note that there are
very few  action levels or health standards reported in
weight of contaminant per unit area to assist a Site
Manager in decision-making.

The  methods  of  sampling  described  below are
appropriate for surfaces  contaminated with  non-
volatile  species of  analytes  (e.g., PCBs, PCDD,
PCDF, metals, pesticides, cyanide). Detection limits
are analyte-specific. Determine sample size based
upon the detection limit desired, amount of sample
requested by  the analytical laboratory, and sampling
locations and configuration.

Wipe Sampling

Wipe sampling is a method for collecting non-volatile
species of analytes from relatively smooth,  non-
porous surfaces.  It is appropriate for sampling walls,
floors, ventilation ducts and fans, empty transformers,
process equipment, and vehicles. Wipe sampling can
be used to confirm cleanup after steam cleaning or
decontamination of smooth building walls.

To  collect a wipe  sample, use a  piece of  sterile
medical gauze soaked in pesticide grade solvent (e.g.,
hexane, water, methanol, nitric acid).  The type of
solvent used depends on the target  analytes.  When
requested in advance, analytical laboratories will often
prepare the gauze and sample jars.  Use caution and
maintain  proper  safety  protocols  when handling
hexane and other  solvents.

Several wipe sampling techniques were developed for
use in OSHA  enforcement and industrial hygiene
decision-making  to  evaluate  potential  sources of
ingestion and direct contact exposures. Most of these
techniques recommend a uniform wipe area of at least
100 cm2,  but larger areas may need to be wiped to
collect enough sample for the analytical method
detection limit. Disposable cardboard templates (or
glass  or  stainless  steel templates which can be
decontaminated)  are recommended  to ensure  a
uniform surface area. Very few approved standards or
action levels are available to compare with the wipe
sampling results (this supports qualitative rather than
quantitative conclusions).  Wipe sampling is typically
used  to  determine  if  decontamination has  been
effective or to select the type of disposal facility (e.g.
hazardous vs. non-hazardous).  A blank consisting of
a solvent-soaked pad is required for each batch of
samples.

Sampling  locations   are  typically   judgmental
selections. They are chosen because they are areas of
highest   suspected   contamination  (for  disposal
decisions), or  areas of suspected direct contact (for
exposure and hygiene evaluations).

Chip Sampling

Chip sampling is a method for collecting non-volatile
species of analytes from porous surfaces such as
cement, brick, or wood.  Sample points include floors
near process areas, storage tanks, and loading dock
areas.  Chip sampling is usually performed with a
hammer and chisel or with  an electric hammer.  It is
important to ensure that the chipping device does not
bias the integrity of the sample. Stainless steel tools
allow for easy  decontamination and preparation for
reuse.
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To collect the sample, chip the desired sampling area
to a suitable depth (e.g., 1/8 inch).  Gather the chips
and place them in a sample container using forceps, a
small  scoop,  or  a dust  pan.    Make  advance
arrangements with the analytical laboratory prior to
sampling to determine acceptable preparation and
analysis procedures.  The  laboratory may require
special grinding or extraction procedures.

Chip sampling is most often used to determine the
necessity or effectiveness of decontamination, or the
necessity for demolishing and disposing of a wall or
building.  As with wipe sampling, existing action
levels  may not  be available for each application.
Make appropriate decisions based on precedents and
Regional guidelines.

Dust  Sampling

Dust sampling is a method for collecting metal and
semi-volatile contaminants in residue or dust found on
porous  or  non-porous  surfaces.   Dust sampling
techniques are used where a solvent cannot be used or
where too much residue exists for a wipe sample to be
easily collected. Dust sampling is used in industry to
assess potential exposure of airborne contaminants to
workers.  For example, dust sampling  would be
effective in a  bagging, processing, or grinding area
where  powdery  contaminants and dust may have
accumulated.

To  collect a  dust sample, select  and  sweep an
appropriate area using a dedicated brush and dust pan.
Transfer the  sample to  a sample container.  Dust
sampling can also be conducted using a cellulose fiber
filter attached to a high-volume pump.  Dust/residue
is vacuumed onto the filter.

Dust   sampling   results  are  reported  in  mg/kg
(weight/weight).  The size of the area to be swept is
dependent on the sample volume needed for the
desired analysis and detection level. Dust sampling is
often used to assess potential  respiratory, direct
contact, and  ingestion  hazards to workers and the
public.  It may also be used to determine the need and
method for building decontamination.

4.3.7  Debris Sampling

The purpose of sampling waste debris is to select a
disposal  option.   Since debris  often consists  of
irregular pieces of material, it is a difficult matrix to
analyze in the laboratory.  Provide the laboratory with
instructions to guide it in preparing a representative
subaliquot of debris samples for analysis.

Currently there  are  no  standardized methods that
reliably conserve VOCs  during the grinding of large
objects, nor are  there good methods for extracting
non-polar organic contaminants from plastic matrices
without dissolving the plastic.

Use a judgmental sampling approach to sample debris,
selecting sampling locations by matrix and physical
properties. Use a chip sampling technique for porous
materials and wipe sampling for non-porous materials.
It  is difficult to collect  a representative  sample  of
debris  because of its heterogeneous  composition.
Compositing  large  objects  will  not  result   in
meaningful data, and obtaining a sample of different
components of debris is not always practical. Only if
feasible, separate debris into components (e.g., metal,
plastic,  wood) and  collect a representative surface
sample of each.

4.3.8  Compressed  Liquid/Gas
        Cylinders

Although   dealing   with  compressed   liquid/gas
cylinders is outside the scope of this document, they
are often found at waste sites.  Compressed liquids
and gases are  stored in  a variety of low- and high-
pressure vessels or cylinders.  Though the liquids or
gases in the cylinders are rarely considered  to be
waste, the original cylinder may have been weakened
by   exposure   to   heat,  pressure,   or  outside
contamination.   Cylinders represent a  chemical,
explosion/fire, and projectile  hazard.  Compressed
liquids and gases, especially those in cylinders, should
be sampled only by specialists.
4.4    SAMPLE PREPARATION

Sample  preparation  depends  on  the  sampling
objectives and  analyses to be performed.  Proper
sample preparation and handling maintain sample
integrity.  Improper handling can render samples
unsuitable for analysis. For example, homogenizing
and compositing samples result in a loss of volatile
constituents and are thus inappropriate when volatile
contaminants are of concern.  Sample preparation for
waste may include, but is not limited to:
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•   Removing extraneous material
•   Homogenizing
•   Splitting
•   Final preparation

Another field preparation technique is compositing of
samples, which requires that each discrete aliquot be
equal,   and  that   the  aliquots  be  thoroughly
homogenized.    Compositing  waste samples  is
discussed in detail in Section 2.3.2.

4.4.1  Removing  Extraneous Material

During  sample  collection,  identify  and  discard
materials from the sample which are not relevant or
vital for characterizing the site, since their presence
may introduce an error into the sampling or analytical
procedures.  Examples of extraneous material include
pieces  of glass, twigs,  or leaves.  However, not all
external materials are extraneous.  For example, when
sampling at a  junkyard,  lead-contaminated battery
casing pieces should not be removed from a sample if
the casing  comprises more than 10 percent of the
sample  volume.    (For  such   a   sample to  be
representative, it must incorporate the lead from the
casing.) Collect samples of any material thought to be
a potential source  of  contamination.  Discuss  any
special  analytical  requirements  for  extraneous
materials with the project team (project management,
geologists, and chemists), and notify the laboratory of
any special sample handling requirements or method
changes.

4.4.2 Homogenizing

Homogenizing is the mixing or blending of a grab or
composite  sample  to  distribute  contaminants
uniformly   within  the  sample.    Ideally,  proper
homogenizing ensures that all portions of the sample
are equal  or  identical  in  composition   and  are
representative   of   the  total  sample  collected.
Incomplete homogenizing can introduce  sampling
error.  Homogenizing requires additional handling of
the waste and is not appropriate for all wastes. Unless
layered,  liquid  wastes  can be  assumed to  be
homogeneous and do not require additional mixing.
If they occur in phases, treat each phase as a unique
homogeneous medium and sample each separately, as
discussed in Section 2.3.1.  Solid samples that will be
composited should be homogenized after all aliquots
have been combined. Manually homogenize solid and
sludge samples using a stainless steel spoon or scoop
and a stainless steel bucket or pyrex bowl, or use a
disposable plastic scoop and pan, depending on the
analyses.  Do not homogenize samples  for VOC
analysis.

4.4.3  Splitting

After collection  and  field preparation, samples are
split into two or more equivalent parts when two or
more portions of the same sample need to be analyzed
separately.  Split samples are most often collected in
enforcement  actions  to  compare  sample   results
obtained by EPA  with  those  obtained  by  the
potentially  responsible party.   Split samples also
provide measures of sample variability and  analytical
error.  Before splitting, follow the  homogenization
techniques outlined above.  Fill two sample  collection
jars  at  the  same  time,  alternating  spoonfuls (or
scoopfuls) of homogenized  sample between them.
Samples  for   VOC  analysis  should   not   be
homogenized;  instead, collect two uniform samples
concurrently from the same location (collocated).

4.4.4  Final Preparation

Select sample containers on the basis of compatibility
with  the  material  being  sampled,  resistance  to
breakage, and capacity.  Appropriate sample volumes
and containers will vary according to the parameters
being analyzed.  Actual sample volumes, appropriate
containers, and holding times are specified in the U.S.
EPA Quality Assurance/Quality Control  (QA/QC)
Guidance for Removal Activities, EPA/540/G-90/004,
April 1990, in 40 CFR  136, and in the Compendium
of ERT Waste  Sampling  Procedures,  OSWER
Directive  9360.4-07.    Package  all samples  in
compliance with current International Air  Transport
Association (IATA) or Department of Transportation
(DOT) requirements, as applicable. Packaging should
be performed  by someone trained  in current DOT
shipping procedures.

Specific handling techniques may  be required for
physical parameters such as permeability or particle
size distribution.  Preservation of the original sample
conditions    will    determine   in   part   the
representativeness    of  the  analytical    results.
Permeability is  affected  by evaporation  and  by
thermal variations;  particle size  is  affected  by
handling.   In general, cooling samples  can help
maintain original conditions; however, wastes are
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often of such high concentration that cooling a sample
is not necessary.

4.5   EXAMPLE SITE

Table  1 is a  sample log for the ABC Plating  site,
illustrating the parameters used  by  the  analytical
laboratory  to evaluate each waste  source.   The
analytical results provided preliminary information on
waste composition plus data necessary to begin clean-
up  strategy and treatment/disposal planning.   The
sampling objective of the initial assessment was to
establish threat.

4.5.1  Source Sampling

The following  is a detailed description of the sampling
activities listed in Table 1.

Drum Sampling

Samples were collected from three drums tentatively
identified from screening results as containing cyanide
bases.  They were sent for laboratory analysis of free
and  total  cyanide, TCL organic compounds,  and
metals.    Each  sample  was  collected using  a
COLIWASA  sampler which preserved phase layers
that were present.

Vat Sampling

Samples were collected from two vats which were
tentatively  identified  as containing cyanide bases.
They were sent for laboratory analysis of free and
total cyanide and metals. Vat samples were assumed
to  be relatively homogeneous  and were collected
using a COLIWASA-style glass thief.

Waste Pile Sampling

Two composite samples were collected (one from
each waste pile) for laboratory  analysis of free and
total cyanide and metals. For each pile, four aliquots
were collected from 12-inch depths at equally-spaced
points  located  along  the  previously  established
transect.   Sample aliquots  were collected  with a
corkscrew auger and a hard plastic scoop. Aliquots
from each pile  were composited in separate disposable
plastic  trays.
Impoundment Sampling

Two waste liquid samples and five waste bottom
sludge   samples   were   collected  from   each
impoundment.  Waste liquids were  analyzed in the
laboratory for  full TAL substances and the waste
sludges were  laboratory analyzed for full  TCL
substances.  Sample locations and techniques were
identical to those chosen for initial screening (Section
3.3.4). Waste liquid samples were collected using a
bacon bomb sampler and waste sludge samples were
collected with a Ponar dredge.

Surface Sampling

Non-porous walls and the concrete slab floor in the
plating  building  were   wipe  and  chip  sampled,
respectively. A one-square foot template was used to
mark each area for wipe sampling. Sterile gauze pads
soaked in hexane were used to collect four samples
from  non-porous  walls.   Four chip samples were
collected from the floor using block hammers and
chisels.  Wipe and chip  samples were analyzed for
metals and cyanide to determine if the facility block
walls and concrete floor needed to be sent to a secure
or sanitary chemical landfill.

4.5.2  Sample Preparation

Removing Extraneous Material

Drum, vat, and impoundment liquid samples did not
contain extraneous material. Stones and small pieces
of stainless steel wire  were removed from  solid
samples collected from the waste pile, but clumps of
blue-green solid material were not removed.  Based on
screening data  and knowledge of plating processes,
the  clumps were suspected  to be plating  solids
containing high concentrations of metals and possibly
cyanide.  Sticks and other extraneous materials (e.g.,
plastic  and metal objects) were discarded  from
dredged impoundment sludge samples. The presence
of extraneous  materials  was  documented  for later
consideration during  treatment/disposal technology
evaluation.

Homogenizing Samples

Homogeneity was assumed for most liquid samples,
since plating processes require homogenous solutions
to promote for even ion movement and uniformity of
the coating. The liquid samples which appeared to be
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uniform were  not homogenized.   Several drums
containing liquid materials had distinct phases present
which  were visible  in the  glass  thieves during
sampling. Each phase was sampled separately using
a  COLIWASA.     The  solid  waste  piles   and
impoundment sludge samples were homogenized after
screening results indicated a lack of volatile organic
compounds. Since metals were a primary concern at
the site, pyrex mixing bowls (instead of disposable
aluminum pans) were used to homogenize samples.
Splitting Samples

At the request of the State, all initial containerized and
impoundment waste samples were split during the
removal  assessment.   The split  samples were
preserved and  labelled,  then  chain  of  custody
papersand samples were signed over to an on-site state
representative.
                                  Table 1: ABC  Plating Sample Log
Sampling Locations
Plating Vats
Drums
Waste Piles
Impoundment Liquids
Impoundment Sludges
Surfaces
Number of Samples
2
3
2
4
10
8
Analytical Parameters
metals, cyanide
metals, cyanide, full TCL
substances
metals, cyanide
full TAL substances
full TCL substances
metals, cyanide

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                 5.0  QUALITY ASSURANCE/QUALITY CONTROL
5.1     INTRODUCTION

The  goal of representative  sampling is  to  obtain
analytical results that accurately depict site conditions
during  a  given  time.    The   goal  of  quality
assurance/quality control (QA/QC) is to implement
correct methodologies which limit the introduction of
error into the sampling and analytical procedures, and
ultimately into the analytical data.

QA/QC samples evaluate three types of information:
1) the degree of site variation; 2) whether samples
were cross-contaminated during sampling and sample
handling procedures; and 3) whether a discrepancy in
sample results is a result of laboratory handling and
analysis procedures.
digital values)  in  the form of paper printouts or
computer-generated electronic  files.  Data may be
generated at the site or at an off-site location, as long
as the QA/QC requirements are satisfied. For the data
to be definitive, either analytical  or total measurement
error must be determined.  QC measures for definitive
data contain all of the  elements associated with
screening data, but also may include trip, method, and
rinsate blanks; matrix spikes; performance evaluation
samples;   and  replicate   analyses  for  error
determination.

For further information on these QA/QC objectives,
please refer  to EPA's Quality Assurance/Quality
Control Guidance  for Removal Activities or EPA's
Data Quality Objectives Process for Superfund.
5.2    DATA CATEGORIES

EPA has established data quality objectives (DQOs)
which   ensure  that  the  precision,   accuracy,
representativeness, and quality of environmental data
are  appropriate  for  their  intended  application.
Superfund  DQO  guidance  defines  two  broad
categories  of  analytical data:    screening  and
definitive.

Screening data are generated by rapid, less precise
methods of  analysis with  less  rigorous  sample
preparation.   Sample  preparation  steps  may  be
restricted to simple procedures such as dilution with
a solvent, rather than elaborate extraction/digestion
and cleanup. At least 10 percent of the screening data
are confirmed  using the analytical methods and
QA/QC  procedures  and  criteria associated with
definitive data.  Screening data without associated
confirmation  data are not considered to be data of
known quality To be acceptable, screening data must
include  the following: chain of custody, initial and
continuing calibration, analyte  identification, and
analyte quantification. Streamlined QC requirements
are the defining characteristic of screening data.

Definitive data are generated using rigorous analytical
methods (e.g.,  approved  EPA  reference methods).
These data are analyte-specific, with confirmation of
analyte identity and concentration.  Methods produce
tangible raw  data (e.g.,  chromatograms, spectra,
5.3    SOURCES OF ERROR

The four most common potential sources of data error
in waste sampling are:

•  Sampling design
•  Sampling methodology
•  Sample heterogeneity
•  Analytical procedures

5.3.1  Sampling Design

Waste samples  are  often  heterogeneous.   Waste
components separate into phases or layers by specific
gravity and solubility.  For example, an impoundment
may  have an  oily  layer  on  top  and  relatively
contaminant-free water below.  Failure to account for
differences in composition of multiple phases can
introduce sampling error.  The sampling design must
account for all phases and strata which may contain
hazardous substances.

The  sampling design should utilize approved SOPs
and previously approved sampling designs to ensure
uniformity and comparability between samples.  The
actual sample collection process should be determined
prior to sampling.  All samples should be collected
using a uniform surface area and/or depth to ensure
data comparability.  Sampling equipment must be
standardized for like sampling situations.
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The sampling design should fulfill sampling and data
quality objectives.  The QA objectives selected should
be built into  the sampling  design, including all
necessary QA/QC samples.

5.3.2  Sampling Methodology

Sampling  methodology  and   sample  handling
procedures have possible sources of error, including:
cross-contamination from inappropriate use of sample
collection equipment;  unclean  sample  containers;
improper sampling equipment decontamination; and
improper  shipment  procedures.   Procedures  for
collecting, handling, and shipping samples should be
standardized to allow  easier identification of any
source(s) of error, and to minimize the potential for
error.  Use SOPs to  ensure that all given sampling
techniques  are performed  in  the  same  manner,
regardless of the individual sampling team,  date, or
location of  sampling activity.   Use field  blanks,
replicate samples, trip blanks, and rinsate blanks to
identify errors due to improper sampling methodology
and sample handling procedures.

Site  screening and haz-catting often employ kits or
"cookbook" procedures requiring interpretations based
on chemical reactions which produce a color change.
The degree of subjectivity  inherent in interpretation,
and  the complexity of some  of  the  procedures,
introduce a significant source of potential error.

5.3.3  Sample Heterogeneity

Wastes   may  become  heterogeneous   through
vaporization,   settling,  solubility,  migration,  or
addition of  new wastes over  time.    Identify
heterogeneity  by  obtaining several samples or
composite aliquots from various  depths.

Waste sources vary both in type and in concentration
level.  Incorporate representative sampling techniques
into the sampling design to identify and define this
variation accurately.  Collect a grab sample of each
phase or stratum suspected of containing contaminants
of  concern;  the  samples  will   be  relatively
homogeneous  and representative of their respective
phases.  For example, if an impoundment has three
liquid phases and sludge on the bottom,  collect one
sample  of each liquid  phase and a  sample of the
bottom sludge.
5.3.4  Analytical Procedures

Analytical  procedures  may  introduce errors from:
laboratory cross-contamination; inefficient extraction;
and inappropriate methodology. High concentration
waste samples tend to foul analytical equipment,
which can lead to poor data reproducibility. Matrix
spike, laboratory duplicate, performance evaluation,
and laboratory  control samples help to distinguish
analytical error from sampling error.
5.4    QA/QC SAMPLES

QA/QC samples are collected at the site or prepared
for or by the  laboratory.  Analysis of the QA/QC
samples provides information on the variability and
usability of waste sampling data, indicates possible
field  sampling or laboratory  error, and provides a
basis  for future validation  and usability  of the
analytical data.   The most common field QA/QC
samples  are field replicate, background, and rinsate
blank  samples.  The most common laboratory QA/QC
samples  are performance evaluation,  matrix  spike
(MS), and matrix spike duplicate (MSD) samples.
QA/QC results may suggest the need for modifying
sample collection, preparation, handling, or analytical
procedures if  the resultant data do not meet site-
specific quality assurance objectives.

Waste   is   typically   characterized  by   high
concentrations of contaminants, making precision and
accuracy less important than for samples with  lower
concentrations (e.g., water, air).  This eliminates the
need  for frequent  field blanks.    In addition,
contaminant concentrations in waste samples are often
several  orders  of  magnitude  higher  than the
concentrations of standard laboratory QA/QC mixes,
which may  render  them useless  in  measuring
laboratory  error.  The laboratory spikes are not
detected because of masking caused by the high
sample  concentrations.    Fouling  of  analytical
equipment associated with high concentration samples
may occur. Analytical error in waste sampling can be
measured by performance evaluation samples and
laboratory control samples, which are not subject to
matrix interferences.

Refer to data validation procedures  in U.S.  EPA
Quality   Assurance/Quality   Control   (QA/QC)
Guidance for Removal Activities, EPA/540/G-90/004,
April   1990,  for guidelines  on utilizing QA/QC
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analytical results.  The following  sections briefly
describe the types of QA/QC samples appropriate for
waste sampling.

5.4.1 Field Replicate  Samples

Field replicates, also referred to as field duplicates and
split samples,  are field samples obtained  from one
sampling point, homogenized (where appropriate),
divided into  separate  containers,  and treated  as
separate samples throughout the  remaining sample
handling and  analytical processes.  Use replicate
samples  to  assess error associated with  sample
heterogeneity,  sample methodology, and  analytical
procedures.  Field replicates can also be used when
determining total  error for  critical samples  with
contamination concentrations near the action level.  In
such a case, a minimum of eight replicate samples is
recommended  for valid statistical analysis.  Field
replicates may  be sent to two or more laboratories or
to the same laboratory as unique samples.  For total
error determination, samples should be analyzed  by
the same laboratory.

5.4.2 Collocated  Samples

A collocated  sample  is collected  from  an  area
adjoining a field sample to determine local variability
of the waste.  Collocated samples of solids, such as
waste  pile  samples,  are  situated  side  by  side.
Collocated samples of liquids, such as vat samples,
are  collected from the  same location  and depth.
Collocated samples are collected and  analyzed  as
discrete samples; they are not composited.  Because of
the non-homogeneous nature of many waste sources,
collocated samples should not  be used  to assess
variability  within  a  large  source and   are  not
recommended  for  assessing error.   Determine the
applicability of collocated samples on a site-by-site
and source-by-source  basis.

5.4.3 Background Samples

Waste  sampling typically involves containerized or
relatively  immobile  waste  streams.   Background
sampling, which is appropriate when sampling soil,
surface water, groundwater,  and  air,  has  less
application to waste sampling.  In some cases (e.g.,
uncontainerized   waste)   soil   samples   from
uncontaminated  areas  can serve  as  background
samples for waste sampling.  Background samples are
appropriate for some surface sampling applications, as
discussed in Section 4.3.6.

5.4.4  Performance Evaluation/
        Laboratory Control Samples

A performance evaluation (PE) sample evaluates the
overall error contributed by the analytical laboratory
and detects any bias in the analytical  method being
used.  PE samples contain known quantities of target
analytes manufactured  under  strict quality control.
They  are usually prepared by a third party under an
EPA certification program. The samples are usually
submitted "blind"  to   analytical laboratories (the
sampling team knows the contents of the samples, but
the laboratory does not). Laboratory analytical error
may  be evaluated by  the percent recoveries and
correct identification of the components in the PE
sample.

A blind PE sample may be included in a set of split
samples provided to the PRP. The PE sample will
measure PRP  laboratory accuracy, which may  be
critical during enforcement litigation.

A  laboratory control  sample (LCS)  also contains
known quantities of target analytes in certified clean
water. In this case, the laboratory knows the contents
of the sample; the LCS is usually prepared by the
laboratory.  PE and LCS samples are not affected by
waste matrix interference, and thus can provide a clear
measure of laboratory error.

5.4.5  Matrix Spike/Matrix Spike
        Duplicate  Samples

Matrix spike and matrix spike duplicate  samples
(MS/MSDs) are field samples that are spiked in the
laboratory with a known concentration of a  target
analyte(s) in order to determine percent recoveries in
sample  extraction.   The  percent recovery  from
MS/MSDs  indicates the degree to which matrix
interferences will  affect the  identification  of  a
substance.  MS/MSDs  can also be used to monitor
laboratory performance.  When four or more pairs of
MS/MSDs are analyzed, the data obtained may also
be used to evaluate error due to laboratory bias and
precision.  Analyze one MS/MSD pair to assess bias
for every 20 samples, and use the average percent
recovery for the pair. To assess precision, analyze at
least 8 matrix spike replicates from the same sample,
and  determine  the  standard deviation  and  the
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coefficient of variation.  See pages 9-10 of the U.S.
EPA Quality Assurance/Quality Control  (QA/QC)
Guidance for Removal Activities, April 1990, for
directions on calculating analytical error. MS/MSDs
are recommended for screening data and are required
as one of several methods for determining analytical
error  for definitive data.  Since the MS/MSDs are
spiked field  samples, provide sufficient volume for
three separate analyses.  Because the spiking solutions
used  in  MS/MSDs are  often obscured  by  high
concentrations of contaminants or by matrix effects,
the usefulness of MS/MSDs for high  concentration
samples may be limited.

5.4.6  Rinsate Blank Samples

A rinsate blank is used  to assess cross-contamination
from    improper    equipment    decontamination
procedures.  Rinsate blanks  are samples obtained by
running  analyte-free  water over decontaminated
sampling equipment.  Any residual  contamination
should appear in the rinsate sample data. Analyze the
rinsate blank for the same analytical parameters as the
field samples collected that day.  Handle and ship the
rinsate like a low-concentration field sample.  Where
dedicated sampling equipment is not utilized, collect
one rinsate blank per sampling batch per day.

5.4.7  Field  Blank Samples

Field blanks are samples prepared in the field using
certified clean water or sand which are then submitted
to the laboratory for analysis.  A field blank is used to
evaluate  contamination  or error  associated  with
sampling      methodology,       preservation,
handling/shipping,  and laboratory procedures.  For
high-concentration samples, the usefulness of field
blanks is limited.  Parts per billion (ppb) or low parts
per million (ppm) error has little significance when
identifying high concentration wastes  or addressing
action levels in the hundreds of ppm. If available and
appropriate, submit one field blank per day.

5.4.8  Trip Blank Samples

Trip blanks are samples prepared prior to going into
the field.  They consist of  certified clean water or
sand, and  are  not opened until they reach  the
laboratory. If available,  utilize trip blanks to meet QA
objectives for volatile organic analyses only. Handle,
transport, and analyze trip blanks in the same manner
as the other volatile organic samples  collected that
day.  Trip blanks are used to evaluate error associated
with sampling methodology, shipping and handling,
and  analytical  procedures,  since any   volatile
contamination of a trip blank would have to be
introduced during one of those procedures. Since
waste  samples  are  often  high concentration, trip
blanks  are not typically used during waste sampling.

5.4.9  Laboratory Duplicate Samples

A  laboratory duplicate is a sample that undergoes
preparation and analysis twice. The laboratory takes
two  aliquots of one sample  and  analyses them as
separate samples.  Comparison of data from the two
analyses   provides   a  measure   of   analytical
reproducibility within a sample set.  Discrepancies in
duplicate analyses may indicate poor homogenization
in the field or other sample preparation error, either in
the field  or in  the laboratory.    The  benefit of
laboratory  duplicates  in waste  sampling may be
limited. High concentration waste samples may foul
analytical equipment and result in unavoidably poor
reproducibility.    Laboratory duplicates  of high
concentration waste samples should not be used to
measure laboratory performance.
5.5    EVALUATION OF ANALYTICAL
        ERROR

Analytical  error becomes significant in decision-
making  as sample results  approach the action level.
The acceptable level of error is determined by the
intended use of the data and litigation concerns.
Definitive data require quantitative measurement of
analytical error with PE samples and replicates. The
other QA  samples  identified  in this section can
indicate a  variety of qualitative  and quantitative
sampling errors. As discussed earlier, error in the ppb
or low  ppm range  may  not  be of concern when
analyzing high concentration wastes.
5.6    CORRELATION BETWEEN
        FIELD SCREENING RESULTS
        AND LABORATORY RESULTS

A cost-effective approach for evaluating wastes and
waste  sources  is  to compare  inexpensive  field
screening data and other field measurements (e.g.,
XRF) with laboratory results.  This relies in part on
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statistical correlation, which involves computing an
index  called  the  correlation coefficient  (r) that
indicates the degree and nature  of the relationship
between two or more sets of values. The correlation
coefficient ranges from -1.0 (a  perfect inverse or
negative relationship), through 0 (no relationship), to
+1.0 (a perfect direct  or positive relationship). The
square of the correlation coefficient,  called  the
coefficient of determination, R2, is an estimate of the
proportion of variance in one variable (the dependent
variable) that can be accounted for by the independent
variables.  An acceptable R2 value depends on the
sampling objectives and intended data uses.  As a rule,
statistical relationships should have an R2 value of at
least 0.6 to determine a reliable model.  For health or
risk assessment purposes, the acceptable R2 value may
be more  stringent (e.g.,  0.6).  Analytical calibration
regressions have an R2 value of 0.98 or greater. Once
a reliable regression equation has been derived, the
field screening data can be used to predict laboratory
results. These predicted values can then be located on
a base map and  contoured (mapping methods  are
described in  Section  6.4).  The contour maps  can
illustrate the estimated extent of contamination (for
certain waste sources)  and  the adequacy  of  the
sampling program.
5.7    EXAMPLE SITE

5.7.1  QA Objectives

Screening  data,  which  generate  non-definitive,
unconfirmed results (e.g., total hydrocarbons, total
halogens,  cyanide, PCBs)  were  used  to  select
analytical  parameters.   Samples were sent to the
analytical laboratory under protocols which provided
definitive  data.   The rigorous laboratory analyses
provided definitive identification and quantitation of
contaminants (e.g., 50 ppm benzene, 110 ppm total
chromium, 75 ppm total cyanide).

5.7.2  Sources of Error

All direct reading instruments were maintained and
calibrated  in accordance with  their  instruction
manuals. Many of these instruments are  class-specific
(e.g. volatile organic vapors)  with relative response
rates  that  are  dependent on  the  calibration  gas
selected.   Instrument  response to  ambient  vapor
concentrations may differ by  an order  of magnitude
from response to calibration standards.  If compounds
of interest are known, site-specific standards may be
prepared;  they are most applicable for field gas
chromatographs (GCs).   These standards  can  be
prepared on site in a gas bag or flask, but have limited
holding  times.   Preparation of standards  on  site
introduces its own potential error. For sites of long
duration, specialty mixtures may be ordered from a
specialty gas company or an analytical laboratory.

The number and location of initial field samples were
based on observation  and professional judgment (as
outlined  in Section 2.8).  Liquid wastes  in the vats,
impoundments, and transformers were assumed to be
homogeneous because there were no  visible phases.
(An erroneous observation could introduce significant
error into the sampling design.)

Field standard operating procedures, documented in
the  site  sampling   plan,  established   consistent
screening  and   sampling procedures  among  all
samplers. This reduced the chances for variability and
error during sampling.  Site briefings were conducted
prior to all sampling and  screening events to review
the use of proper screening and sampling techniques.

Other  steps taken  to limit  error included  proper
sample preparation, adherence to sample holding
times, and the use of proper shipment procedures. All
off-site laboratory  sample analyses were performed
using EPA standard methods and protocols.

5.7.3  Field QA/QC Samples

Few field  QA/QC  samples  were collected  during
waste sampling at the ABC Plating site. For the low-
concentration impoundment liquids, a PE sample for
metals was sent to the  laboratory. (The PE sample is
not affected by matrix interferences.) Field and trip
blanks were not applicable  since they are used to
determine cross-contamination of low concentration
samples.  Cross-contamination that may occur during
storage and shipping is minimal compared to the high
ppm  or  percent level  concentrations  which are
typically  found in  plating wastes.   Nevertheless,
suspected high  concentration samples were shipped
separately from the low level samples.  One rinsate
blank sample was  collected from the impoundment
sampling equipment  (dredge   and  bacon   bomb
samplers) to check for cross-contamination  during
equipment decontamination.
                                                   40

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5.7.4  Laboratory QA/QC Samples

Instructions on  matrices, target  compounds, and
QA/QC criteria of particular interest were provided to
the laboratory to help ensure that analytical results
met the  required objectives.  The  laboratory was
instructed to run a duplicate of LCS samples for each
batch of high concentration liquid  vat samples  to
check reproducibility  of the laboratory results.   A
matrix spike was not requested because the  level  of
error measured by the standard low/medium spiking
mixtures  did  not  apply to  the  expected  high
concentrations  in  the  samples.   The  laboratory
analyzed the metals using the methods of inductively
coupled  plasma (ICP) spectrometry and  atomic
absorption (AA).   The presence of  cyanide was
confirmed in the  laboratory using total and amenable
cyanide analyses (colorimetric manual method, SW-
846 Method 9010).

PE sample results indicated low recoveries for some
metals. The difference between LCS duplicate results
was within the acceptable range, so  these results were
used as estimates with a low  bias.  The confirmation
by a second method on 10 percent, or one per batch,  of
the high  concentration samples indicated acceptable
accuracy.
The waste pile was thought to be vat bottom materials
of high contaminant concentrations, therefore a matrix
spike was not requested. An LCS duplicate was used
to evaluate the reproducibility of the results and to
establish if the solid samples were homogeneous.
Agreement  between the  LCS duplicates indicates
good laboratory precision.  When results of the LCS
and LCS duplicate correlate, but the field replicates do
not, two possible  errors  are  indicated:  either  the
matrix interfered with recovery, or there was poor
sample homogenization in the field.  The laboratory
does not homogenize samples unless specified  in the
analytical method.

For the impoundment samples, matrix spike and LCS
duplicate  samples were used.   Matrix spikes  are
applicable  since the impoundment samples have a
lower concentration than the vat samples.  Matrix
spike   recoveries  for  certain  metals  were  low.
However, LCS results were  within control limits,
indicating good laboratory performance.
                                                  41

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                    6.0  DATA PRESENTATION AND ANALYSIS
6.1     INTRODUCTION
6.4    CONTOUR MAPPING
Data  presentation  and  analysis  techniques  are
performed  with  analytical,  field  screening,  or
geophysical results. The techniques discussed below
can be used to compare analytical values, to evaluate
numerical  distribution  of data, and to reveal the
location of "hot spots" and the extent of contamination
at a  site.  The appropriate methods to present and
analyze  sample  data  depend  on  the  sampling
objectives,  the number of samples collected, the
sampling approaches used, and other considerations.
6.2    DATA POSTING

Data posting involves placement of sample values on
a site base map or cross-section.  Data posting is
useful for displaying the distribution of sample values,
visually  depicting  the  location  of wastes  with
associated assessment data.  Data posting  requires
each sample to have a specific location (e.g., x, y, and
sometimes  z  coordinates).   Ideally,  the sample
coordinates are surveyed values or inventoried and
numbered containers, facilitating placement on  a
scaled  map.  Data  posting is useful for depicting
concentration values of non-containerized wastes and
surfaces, but has limited application to containerized
wastes.
6.3    CROSS-SECTION/FENCE
        DIAGRAMS

Cross-section diagrams (two-dimensional) and fence
diagrams (three-dimensional) depict layers or phases
of wastes in sources such as tanks and impoundments.
Two-dimensional  cross-sections  may  be used  to
illustrate vertical profiles of waste concentrations in
containerized wastes or impoundments.  For solid
wastes  in  waste  piles,  three-dimensional  fence
diagrams are often used to interpolate data between
sampling locations. Solid wastes in waste piles do not
usually  form horizontal layers, so  fence diagrams
based  on  a  few  sampling  points  may  not be
representative.    Both cross-sections  and  fence
diagrams can provide useful visual interpretations of
contaminant concentrations.
Contour maps are useful for depicting contaminant
concentration values in waste piles or impoundments.
Contour  mapping  requires  an  accurate,  to-scale
basemap of the site. After data posting sample values
on the basemap, insert contour lines (or isopleths) at
a specified  contour  interval,  interpolating values
between sample points.  Contour lines can be drawn
manually  or  can be  generated by computer using
contouring software.  Although the software makes
the  contouring process easier, computer programs
have a limitation: as they interpolate between data
points, they attempt to " smooth" the values by fitting
contour intervals to the full range of data values.  This
can result in a contour map that does not accurately
represent general site contaminant trends.  Typical
waste sites have low  concentration/non-detect areas
and  "hot  spots."  If there is  a  big  difference in
concentration between the  waste  "hot spot" and the
surrounding area, the  computer contouring program,
using a contour interval that attempts to smooth the
"hot spots,"  may eliminate most of the  subtle  site
features and  general  trends.  For waste sampling,
contouring may apply only to large waste piles  and
impoundments.
6.5    STATISTICAL GRAPHICS

If using statistical interpretation, the distribution or
spread of the data set is important in determining
which  statistical  techniques  to  use.    Common
statistical analyses, such as the t-test, rely on normally
distributed data. The histogram is a statistical bar
graph which displays the distribution of a data set. A
normally distributed data set takes the shape of a bell
curve, with the mean and median close together about
halfway between the maximum and minimum values.
A probability plot depicts cumulative percent against
the  concentration of the contaminant of concern.  A
normally distributed data set, when plotted  as  a
probability plot, would appear as a straight line.  A
histogram or probability plot can be used to see trends
and anomalies in the data from a waste source (e.g.,
impoundment) prior to  conducting more rigorous
forms  of  statistical analysis.  As  with contour
mapping, statistical data interpretation applications for
waste are limited.
                                                 42

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6.6    RECOMMENDED  DATA
        INTERPRETATION METHODS

The data interpretation methods  chosen  depend on
project-specific considerations, such as the number of
sampling  locations  and their  associated range in
values.  Data which are dissimilar in composition
(e.g.,  drums  with different chemicals or different
waste media) should not be compared using statistical
interpretation methods. Data posting, screening, and
sampling  data  sheets,   and   cross-section/fence
diagrams may be appropriate. A site feature depicting
extremely low data values (e.g., non-detects), together
with significantly higher values (e.g., 5000  ppm) from
neighboring "hot spots" with little or no concentration
gradient in between, does not lend itself to contouring.
6.7    EXAMPLE SITE

Figure 9 illustrates a transect of impoundment No. 1 in
a two-dimensional cross-section.   The  sampling
intervals are indicated by the twenty foot markings
along the transect  of the cross-section.  Analytical
results  were  data  posted on the cross-section to
illustrate contaminant trends.  Contaminant volume
can be visualized by depicting both the sludge layer
and  impoundment bottom.   The bottom sludges
contained 300 to 427 ppm total chromium;   other
parameters exhibited a similar concentration gradient
range.

Table  2 presents  the  haz-catting  results of  all
containerized waste and waste piles on  site.  This
table was generated as the initial step in analyzing the
data prior to posting on the base map and lists results
from several  different tests.  These data were then
posted on the base map.
                                                  43

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                Figure 9:  Posted Total Chromium Data for Impoundment No. 1
                                          4O
                                                                                8O  ft.
427 ppm
                   411 ppm
                                          

                                         377 ppm
 is   sludge sample point



(Tj)   liquid sample point




 ''• ..... •-,_   sludge surface



          Impoundment bottom



   377 ppm   total chromium concentration
                                                                                    PPm
                                                          Vertical scale exaggerated  ~3X
                                         44

-------
Table 2: Haz-Cat Results
    ABC Plating Site
      (page 1 of 2)
Container
D1
D2
D3
D4
D5
D6
D7
D8
D9
D10
D11
D12
D13
D14
D15
D16
D17
D18
ni9
Rad
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
pH
12
>12
>12
>12
6
7
7
7
7
N/A
5
5
5
5
<2
<2
<2
<2
>11
CN
Y
Y
Y
N
N/A
N/A
N/A
N/A
N/A
N
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N
PID
N/A
N/A
N/A
N/A
4
18
26
14
45
18
6
8
ND
ND
N/A
N/A
N/A
N/A
N/A
FID
N/A
N/A
N/A
N/A
2
35
70
39
128
26
11
6
ND
ND
N/A
N/A
N/A
N/A
N/A
Solubility
in water
Y
Y
Y
Y
Y
N Floats
N Floats
N Floats
N Sinks
Y
Y
Y
Y
Y
Reacts
Reacts
Reacts
Reacts
Y
Chlorine
Test
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
Peroxide
Test
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
Phase
L
L
L
L
L
L
L
L
L
L
L
L
L
L
L
L
L
L
S
Cu+
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
Comments
cyanide base
cyanide base
cyanide base
base
inconclusive
oil
oil
oil
halogenated
solvent
kersosene
open; rain water?
open; rain water?
inconclusive
inconclusive
strong acid
strong acid
strong acid
strong acid
caustic soda
            45

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                            Table 2: Haz-Cat Results (Cont'd)
                                    ABC Plating Site
                                     (page 2 of 2)
Container
V1
V2
V3
V4
V5
V6
V7
V8
V9
V10
V11
V12
V13
V14
V15
P1
P2
Rad
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
pH
>12
>12
9
2
2
8
2
2
8
<2
<2
8
<2
<2
>12
N/A
N/A
CN
Y
Y
N
N
N
N
N
N
N
N
N
N
N
N
N
Y
Y
PID
N/A
N/A
ND
N/A
N/A
ND
N/A
N/A
ND
N/A
N/A
ND
N/A
N/A
N/A
ND
ND
FID
N/A
N/A
ND
N/A
N/A
ND
N/A
N/A
ND
N/A
N/A
ND
N/A
N/A
N/A
ND
ND
Solubility
in water
Y
Y
Y
Y
Y
Y
Y
Y
Y
Reacts
Reacts
Y
Reacts
Reacts
Y
N
N
Chlorine
Test
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
Peroxide
Test
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N/A
N/A
Phase
L
L
L
L
L
L
L
L
L
L
L
L
L
L
L
S
S
Cu+
N
N
N
N
N
N
N
N
N
Y
Y
N
N
N
N
N/A
N/A
Comments
cyanide base
cyanide base
inconclusive
acid
acid
inconclusive
acid
acid
inconclusive
strong acid
strong acid
inconclusive
strong acid
strong acid
strong base
inconclusive
inconclusive
ND - none detected
NA - not applicable
L - liquid
S - solid
Y - yes
N - no
                                          46

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     APPENDIX A -- Example of Flow Diagram For Conceptual Site Model
                          Figure A-1
Migration Routes of a  Gas Contaminant
           from  Origin to Receptor
Original state
of contaminant
of concern*
Gas**
>
Pathway
from
origin
Air
condc
solldl
Change of
contaminant
state In
pathway
jnsatlon
— > Liquid
k Hnc**
> dab
— > Solid
Flcatlon




Final
pathway
to receptor
> SO
> SW
> so
> AT
>• AA j.
^ SW
1 > so
1 ^ sw
Receptor
Human
G,D
G,D
I,D
I,D
G,D
G,D
G,D
Ecological Threat
Terrestrial
G,D
G,D
I,D
I,D
I,D
G,D
G,D
Aquatic
N/A
G,D
N/A
N/A
G,D
N/A
G,D
     *  May be a transformation product
     ** Includes vapors
Receptor Key

D  = Dermal Contact
]  = Inhalation
G  - Ingestlon
N/A - Not Applicable
Pathway Key

AI =Alr
SO = Soil
SW - Surface Water
(Including sediments)
GW - Ground Water
                            47

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                 Figure A-2
Migration Routes of a Liquid Contaminant
         from Origin to Receptor
Change of
Original state Pathway contaminant
of contaminant from state In
of concern* origin pathway
Liquid
* May be a t
** Includes v
> Liquid
-*• SW t fiac**
solidification ^O-1-10
kQO h 1 i n 1 1 1 H —
r OU . . . * I_-LUU-LU
leachate,
Infiltration
—> AT t fiac**
Mฑ f Vjdo —
ransformation product
apors

Final
pathway
to receptor
> SW
k AT
' Al
k O\A/
^ oW
> SW
>> SO
>> SW
* GW
> SO
> AI
^ SW
neceptor
Human
G3D
I,D
G,D
G,D
Ecological Threat
Terrestrial
G,D
I,D
G,D
G,D
Aquatic
G,D
N/A
G,A
G,D

G,D
G,D
G,D
G,D
G,D
N/A
N/A
G,D
N/A

G,D
I,D
G,D
G,D
I,D
G,D
N/A
N/A
G,D

Receptor Key
D - Dermal Contact
I - Inhalation
G - Ingestlon
N/A - Not Applicable
Pathway Key
AI . Air
SO - Soil
SW - Surface Water
(Including sediments)
GW -Ground Water
                   48

-------
                           Figure A-3
      Migration  Routes of a Solid Contaminant
                 from Origin to Receptor
 Original state
 of contaminant
 of concern*
Solid
            AI
               partlculates/
                 dust
SW
Solid



Solid

Liquid


     **
                        Solid
                        Liquid
 * May be a transformation product
 ** Includes vapors
AI

SW

SO


SW

SW

so

AI

SW
                                     so
                                     SW
Receptor Key
D - Dermal Contact
I - Inhalation
G - Ingestlon
N/A - Not Applicable

Pathway Key
AI . Air
SO - Soil
SW - Surface Water
(Including sediments)
GW - Ground Water
Receptor
Human
IiD
G,D
G,D
Ecological Threat
Terrestrial
I,D
G,D
G,D
Aquatic
N/A
G,D
N/A
G,D
G,D
G,D
G,D
G,D
G,D
G,D
I,D
G,D
G,D
G,D
G,D
G,D
G,D
I,D
G,D
G,D
G,D
N/A
G,D
N/A
N/A
G,D
N/A
N/A
N/A
G,D
                             49

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                                                 51

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