SERA
         United Stales
         Environmental Protection
           OHiee ot
           Toxic Substances
           Washingjon DC 2W60
EPA-56Q/5-66-017
May. 1986
         Toxic Substances
FIELD MANUAL FOR
GRID SAMPLING OF
PCB SPILL SITES TO
VERIFY CLEANUP



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                               F1ELD        FOR               OF PCS
                                   SPILL SITES TO VERIFY CLEANUP
                                                By

                                           Gary L, Kelso
                                       Mitchell 0, Erickson
                                    MIDWEST RESEARCH INSTITUTE

                                                and

                                           David C. Cox
                                    WASHINGTON CONSULTING
                                       INTERIM        NO. 3
                                                         37
                                    EPA Contract No.
                                    MR! Project No, 8501-A(37)

                                                and

                                    EPA Contract No, 68-01-6721
                         WCG Subcontract to Battelle Columbus Laboratories
                                        No. F4138(8149)435
                                           Prepared for

                               U.S. Environmental Protection Agency
                                    Office of Toxic Substances
                                   Field Studies        (TS-798)
                                        401 M Street, S.W.
                                       Washington, DC

                       Attn:  Mr. Daniel T. Heqqem, Work Assignment Manager
                              Or. Joseph J. Breen, Project Officer
                              Richard A. Levy, Work Assignment Manager
                              Cindy Stroup, Project Officer

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                                 DISCLAIMER
          This document has been reviewed and approved for publication by
the Office of Toxic Substances, Office of Pesticides and Toxic Substances,
U.S.  Environmental Protection Agency.  The use of trade names or commercial
products does not constitute Agency endorsement or recommendation for use.

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                                   PREFACE
          This Interim Report was prepared for the Environmental Protection
Agency under EPA Contract No. 68-02-3938, Work Assignment 37.   The work
assignment was directed by Mitchell D.  Erickson.   This report was prepared
by Gary Kelso and Dr,  Erickson of Midwest Research Institute (MRI).   David C.
Cox of the Washington Consulting Group, 1625 I Street, N.W. ,  Washington, O.C.
20006, contributed to the sampling design (Section 5.0) and compositing strat-
egies (Appendix) sections under subcontract to Battelle Columbus Laboratories,
Subcontract No.  F4138(8149)435, EPA Contract No.  68-01-6721 with the Design
and Development Branch, Exposure Evaluation Division,

          This report is a revision of a previous draft report entitled
"Field Manual for Verification of PCB Spill Cleanup" (Draft Interim Report
No. 3, Task 37,  EPA Prime Contract No.  68-02-3938, June 27,  1985).   Both
English and metric units are used in this document, where appropriate.   EPA
field inspectors will  most commonly measure the site in English units;  there-
fore these units were used for the site measurements in this report.

          The EPA Work Assignment Managers, Daniel T. Heggem,  Richard A. Levy,
and John H. Smith, as well as Joseph J. Breen and Cindy Stroup of the Office
of Toxic Substances, provided helpful guidance,  Ms. Joan Westbrock and
Mr. Ted Harrison of MRI and Mr. David Phillippi and Mr. Robert Jackson  of
EPA Region VII assisted in the field validation of this manual.

                                             MIDWEST RESEARCH INSTITUTE
                                             3aul C.  Constant
                                             Program Manager
Approved!

    v >  f-
John E. Going, Director
Chemical Sciences Department
May 1986
                                      11

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                              TABLE OF CONTENTS



1.0       Scope and Application, ,  ,  ,	      1

2.0       Summary, 	 .....,,..«,...,.,.,      2

3.0       Safety	,  ,  .	      3

4.0       Sampling Equipment and Materials 	 ...      4

               4.1  Personnel Equipment.  ,...,...,...,..      4
               4.2  Sampling Equipment and Materials 	  ....      5
               4.3  Documentation Materials.  .... 	  ....      6
               4.4  Trip Preparation	      6

5.0       Sample  Design, .......................      6

               5.1  Step 1:  Diagram the Cleanup Site	      7
               5.2  Step 2:  Diagram All  Cleanup Surfaces in the
                      Same Plane .......  	      9
               5.3  Step 3:  Find the Center and Radius of the
                      Sampling Circle		      9
               5.4  Step 4:  Determine the Number of Grid Sample
                      Points to Use	    12
               5.5  Step 5:  Lay Out the Sampling Points on the
                      Diagram Constructed in Step 2. .........    15
               5.6  Step 8:  Lay Out the Sampling Locations on
                      the Site	    22
               5.7  Step 7:  Consideration of Special Cases.  .  	    23
               5.8  Example of Laying Out the Sample Design.  .....    24

6.0       Sample  Collection, Handling,  and Preservation	    28

               6.1  Surface Soil Sampling.	    30
               6.2  Soil Core-Sampling 	  .......    31
               6,3  Water Sampling .  ,	    32
               6.4  Surface Sampling ........ 	  .   .    33
               6.5  Vegetation Sampling.  .......  	    35
               6.6  Compositing Strategies 	  ........    35

7.0       Quality Assurance	    35

8.0       Quality Control	    36

               8.1  Field Blanks	    3?
               8.2  Sampling Without Contamination ...,..,.,.    37
               8.3  Sample Custody	    38
               8.4  Documentation of  Field Sampling	    39
                                     111

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                                    TABLE OF CONTENTS (Concluded)

                                                                                    Page

            9.0       Documentation and Records.  ,,,.,...  	     40

                           9.1  Equipment Preparation Log Book	     40
                           9,2  Sample Codes ..,,.,.,.  	     40
                           9,3  Field Log Book	  .     41
                           9.4  Site Description Forms	     41
                           9.5  Chain-of-Custody Forms	     42
                           9.6  Sample and Analysis Request Forms	     42
                           9.7  Field Trip Report.  .	     43

            10.0      Validation of the Manual 	  .......     43

            11.0      References	     45

            Appendix - Strategies for Compositing Samples.  ............    A-l
L
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                               LIST OF TABLES

No.                                  Title                               Page

 I        Required Number of Grid Samples Based on the Radius
            of the Sampling Circle	.,....,,,.     12

 2        Geometric Parameters of the Hexagonal Grid Designs,
            for Sampling Radius r	  ,	     15
                               LIST OF

Ho_                                 Title                               Page

 1        Example PCB spill site diagram, ....,.,...,,,.       8

 2        Example spill  cleanup site diagrammed in the same plane ,  .      10

 3        Locating the center and sampling radius of the example
            spill cleanup site. .	      11

 4        Method to find center and radius of the sampling circle .  .      13

 5        Locating the center and sampling circle radius of
            irregularly shaped spill areas.  .  .  	      14

 8        Location of sampling points in a 7-point grid 	 .  .      16

 7        Location of sampling points in a 19-point grid	      17

 8        Location of sampling points in a 37-point grid,  ......      18

 9        Construction of sampling grid on a site diagram ......      19

10        Sampling locations on the example PCB spill  site.  .....      21

11        Scale diagram of PCB spill site	      25

12        Determining center (C) and sampling radius (r) of
            sampling circle ...........  	      26

13        Diagram of 19-point grid superimposed on the PCB spill
            site	'......	      29

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1,0  SCOPEAND APPLICATION

          The purpose of this manual is to provide detailed, step-by-step
guidance to EPA staff for using hexagonal grid sampling at a PCB spill site.
Emphasis is placed on sampling sites which have already been cleaned, although
the sampling methods presented may also be used at PCB spill sites which have
not been cleaned.   Guidance is given for preparing the sample design; collect-
ing, handling, and preserving the samples taken;  maintaining quality assurance
and quality control; and documenting and reporting the sampling procedures
used.   An optional strategy for compositing samples is given in the appendix,

          This is  a companion document to the report "Verification of PCB
Spill  Cleanup by Sampling and Analysis" (EPA 560/5-85-026, August 1985, Second
Printing).   That report provides an overview of PCB spill  cleanup activities
and guidelines for sampling and analysis including:  sampling designs, sam-
pling techniques,  analytical techniques, selection of appropriate analytical
methods, quality assurance, documentation and records, and reporting results.
The previous report provided the rationale and background  for the techniques
selected and describes many options in greater detail.

          This "how-to" report concentrates on detailed guidance for field
sampling personnel and does not attempt to provide background information on
the techniques presented.   This manual  addresses  field sampling only and does
not provide information on laboratory procedures,   including sample analysis,
data reduction and laboratory data reporting.   The types of field sampling
situations discussed in this manual are those typically found when a PCB spill
results from a PCB article, PCB container,  or PCB  equipment spill.   Unusual
PCB spill situations, such as elongated spills on  highways from a moving
vehicle, large spills in waterways, and large, catastrophic spills,  are not.
addressed.

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2.0  SUMMARY

          This manual is divided into the following sections:

     •   Safety
        Sampling Equipment and Materials
        Sample Design
        Sample Collection, Handling, and Preservation
        Quality Assurance
        Qua!i ty Control
        Documentation and Records
        Validation of the Manual

          Safety aspects of field sampling include wearing proper protective
equipment, practicing good hygiene,  using safe work practices, and training
field inspectors in safety procedures.   Sampling equipment and materials in-
clude personnel equipment, sampling equipment, and documentation materials.
Prior to making the field sampling trip, the EPA inspector should ensure that
all sampling equipment and materials are available, and that all sampling
containers and equipment have been properly precleaned.

          The  sample design is based on a hexagonal grid of 7, 19, or 3? sam-
ple points.   A step-wise method describes how to construct a diagram of the
PCS spill site on graph  paper; determine the radius and center of the sam-
pling circle;  determine  which grid size to use; lay out the grid on the dia-
gram; and then lay out the sampling grid on the site.

          After the sampling grid has been laid out on the site, a sample
must be taken  at each grid point.  Methods to collect, handle, and preserve
different types of samples, including surface soil samples, soil core samples,
surface and subsurface water samples, wipe samples from nonporous hard sur-
faces,  destructive samples from porous hard surfaces,  and vegetation samples,
are suggested.   For each type of sample to be taken, methods are recommended
to prevent cross-contamination between samples.

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          Quality assurance (QA) and quality control (QC) must be an integral
part of any sampling scheme,  A quality assurance plan must be developed by
appropriate EPA offices according to EPA guidelines and be submitted to the
regional QA officer or other appropriate QA official for approval prior to
sampling PCB spill sites.   Each EPA office must, operate a formal QC program
and all QC measures should be stipulated in the QA plan.   Some of the require-
ments of quality control are discussed in this report, including field blanks,
sampling without cross-contamination, sample custody, and documentation of
the field sampling activities.

          All  sampling activities should be thoroughly documented and reported
as a part of the verification process.   Each EPA office is responsible for
preparing and maintaining complete records, including an equipment preparation
log book, a field log book, site description forms, chain-of-custody forms,
sample analysis request forms,  and field trip reports.

          Section 10.0 briefly  describes a field study which was conducted to
test and validate the sample design given in this manual.   The study showed
that the sampling design is easy to follow and understood by those unfamiliar
with the manual prior to reading it, and that the grid sample points can be
correctly laid out in a relatively short period of time.

          The appendix gives strategies that may be used to composite the
samples taken at a PCB spill site when compositing is deemed to be desirable.
3,0  SAFETY

          A PCB spill site which has been cleaned up should have very low
levels of PCBs present.   The EPA inspectors) who sample the site to verify
that the site has been properly cleaned up should, however, take      pre-
cautions to minimize any exposure to PCBs or other potential hazards at the
s i te.

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          In order to ensure that the inspectors understand and practice good
safety procedures, a training and education program should be established and
a health and safety manual provided by the responsible EPA officer.  The pro-
gram should inform inspectors of the potential hazards of exposure to PCBs,
and the proper safety procedures to follow when sampling PCB spill sites.
4 • °  SAMPLING.	EQU1PME_NT AND MAT E RIA L S

          The equipment and materials required to sample a PCB spill site
will vary with the types of samples to be taken.   The general lists of equip-
ment and materials given below must be adjusted for the specific requirements
of each spill.   The lists include personnel equipment, sampling equipment and
materials, and documentation materials which should be taken to the spill site
by the EPA inspector.   These equipment and materials must be assembled prior
to making the site visit, and all sampling containers and sampling equipment
must be precleaned.

     4,1  Personnel Equipment

          The inspector should take the following personnel  equipment to the
spill s i te:

             Disposable rubber gloves
             Plastic overshoes
             Safety glasses
             Impervious paper-like coveralls
             Hardhat
             Safety shoes
             First-aid kit
             Other safety equipment specified by  safety officer

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grid has a 98% chance of detection of this contamination level, while analysis
of six random grab samples from the site has only a 3% chance of detection
(Boomer et al. 1985).

          The hexagonal grid sampling design is to be laid out within a sam-
ple circle centered on the spill site, and extending just beyond its boun-
daries.  Preparation of the design requires the following steps:

          Ste_£_l:  Diagram the Cleanup Site
          Step 2:  Diagram All Cleanup Surfaces in the Same Plane
                   Find the Center and Radius of the Sampling Circle
                   Determine the Number of Grid Sample Points to Use
                   Lay Out the Sampling Points on the Diagram Constructed in
                     Step 2
                   Lay Out the Sampling Locations on the Site
                   Consider Special Cases and Use Judgment for Sample Points

          The discussion which follows gives the methods to be used in accom-
plishing each step of the hexagonal grid sampling design, using a three-
dimensional spill surface as an example.   Following this discussion, a simple
example of laying out the sample design on a rectangular two-dimensional sur-
face is given.

     5.1  Step 1:  Pi agram the C1eanug Site

          Draw a scale diagram of the cleanup site on graph paper,  including
vertical surfaces (walls, fences,  etc.),  noting important dimensions and dif-
ferent types of surfaces (sod, cement, asphalt, etc.).   Such a diagram may
sometimes be found in records of the cleanup.   If not,  site measurements
should be taken.   Great accuracy (e.g., using surveying instruments) is not
necessary, however; the use of a tape measure and pacing should be adequate.
An example diagram is shown in Figure 1 on a scale of 1 in,  = 4 ft.

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figure 1,  Example PCB spill  site diagrar

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          The site diagram should include as many reference points as neces-
sary to relocate the spill area in the future, if necessary.  For example,
a spill site in an open field should be located with respect to nearby struc-
tures such as roads, telephone poles, buildings, etc.   The direction of north
should be indicated on the diagram.

          If available, a detailed drawing or a survey plot of the spill site
should be obtained from the individual(s) that cleaned the site.

     5. 2  Step 2:   Diagram Aj 1__C_1eanup Surfaces in the Same	PJane

          The purpose of this second diagram is to determine and show the
dimensions of the total cleanup area, including vertical surfaces, so that
the required sample size can be found.  The diagram also facilitates the
determination of sampling locations on vertical surfaces.   Constructing the
diagram is analogous to flattening a cardboard box.   All vertical surfaces
are placed in the same plane as the adjoining horizontal surfaces.  Figure 2,
also on a scale of 1 in,  = 4 ft, shows the example spill cleanup site dia-
grammed in the same plane.  The actual site dimensions are shown in feet.

     5.3  Step 3:   Find the Center and Radius of the Sampling Circle

          In practice, the contaminated area from a spill  will be irregular
in shape.   In order to standardize sample design and layout in the field,
samples are collected within a circular area surrounding the contaminated
area.  The sampling circle is, approximately, the smallest circle contain-
ing all cleanup surfaces diagrammed in Step 2,

          A recommended procedure for finding the center and radius of the
sampling circle is illustrated in Figure 3 and is described below;

          1.   Draw the longest dimension, lj, of the site diagram in Step 2.

          2.   Find the midpoint, P,  of Lj.

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          3.  Draw a second dimension, L2, through P perpendicular to LI.
L2 extends to the boundaries of the site diagram.

          4.  The midpoint, C, of L2 is the center of the sampling circle.

          5.  The distance from C to either end of the longest dimension, Lj,
is the samplingradius. r.

          Figure 4 illustrates the application of this procedure to a site
with an irregular shape, and Figure 5 shows the procedure for a variety of
irregularly shaped areas.   These figures show that the center and radius
determined are generally reasonable.

     5. 4  Step 4:   Determine the_	Number_of	Gri_dSamplePoints to Use

          The number of grid samples to be taken at a site depends upon the
radius of the sampling circle, which is determined from the scale diagram
shown in Figure 3.   The number of samples to be taken at a spill site should
increase as the radius of the sample circle increases.   The reason for this
is that the probability of detecting residual PCB contamination at a given
site increases as the number of grid samples increases.   Table 1 shows the
required number of grid samples for sampling circles with a radius of 4 ft or
less (seven samples); greater than 4 ft to 11 ft (19 samples); and greater
than 11 ft (37 samples),

               Table 1.   Required Number of Grid Samples Based
                     on the Radius of the Sampling Circle

           Sampling radius, r (ft)               Number of Samples

                     54                                 7
                  > 4 - 11                              19
                      > 11                              37
                                    12

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(a) Draw longest dimension, I],
    on site diagram.
   (b)  find midpoint, P» of l|.
(c)  Draw line, t2t through P
     perpendicular to L|,
(d) The midpoint,  C, of L2 is the
    center of the sampling circle.
                  (e) The distance from C to the end of I]
                      is the sampling radius, r.
 Figure  4,   Method to find  center and radius  of the samplinq  circle.

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Figure 5.  Locating the center and sampling circle radius of
               irregularly shaped spill areas.
                              14

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          The radius, r, for the example site is 3-1/4  in,  in Figure 3.   Thus
ihe actual site sampling radius is 13 ft (3-1/4  in. x 4  ft/in.) and the num-
ber of grid samples required is 37,

          Figures 6, 7, and 8 illustrate the hexagonal grid sampling design
for the three sample sizes given in Table I, for a sampling radius of 4,  10,
and 20 ft, respectively,

     5. 5  Stej3__5j__Lay_Out the Sampling Points on the Diagram Cons true ted _j n
          The geometric properties of the hexagonal designs can be used in
many ways to lay out the sampling points.  Perhaps the simplest way to pro-
ceed is as follows.  Define s to be the distance between adjacent points and
u to be the distance between successive rows of the design.  The distances
s and u are given  in terms of the sampling radius, r, in Table 2 below for
the given number of samples defined by the radius rule and listed in Table 1,

        Table 2.  Geometric Parameters of the Hexagonal  Grid Designs,
                            for Sampling Radius r
Number of samples
7
19
37
Distance, s, between
adjacent sample points
0.87r
0.48r
0.30r
Distance, u,
successive
0,75r
0.42r
0,26r
between
rows

          The recommended method for laying out the sample points of the
hexagonal grid on the scale diagram is illustrated in Figure 9 and is de-
scribed below,

          1.   Draw a diameter of the sampling circle on the scale diagram.
The orientation of the diameter (e.g., east-west) should be chosen to maximize
the number of sample points which fall within the spill area, when practical.
                                    15

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     The outer boundary of the contaminated area
     Is         to be 4 feet from the center (C)
     of rtie spill site,
                6,  Location  of                  in
                      a 7-point grid.
                             16

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     The outer boundary of the contaminated area is assumed to be
     10 feet from the center (C) of the spill site.
      Figure 7.  Location of  sampling points in a 19-point grid.
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     The outer boundary of the contaminated area Is assumed to be
     20 feet from the center (C) of the spell site,
      Figure 8,   Location of                  in a  37-point grid,
                                  18

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                           •c
(a)  Center of cleanup area, C,
                                               (b)  Middle row of grid points
                                                    located distance, s, apart.
                                                (c)  Next two grid rows perpendicular
                                                    distance, u,  from middle row.
                                                (d)  Completed 19 sample point grid,
figure 9.  Construction of sampling grid  on a site diaqram.
                                 19

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A transparent overlay like Figures 6, 7 and 8 (using the appropriate scale)
may be helpful in determining the orientation of the diameter.

          2.  Place the center point of the hexagonal design at the center (€}
of the sampling circle,   Lay out the middle row of the design along the diam-
eter with successive points a distance, s, apart.

          3,  To 'lay out the next row, find the midpoint between the last two
sample points of the middle row and move a distance, u, perpendicular to the
middle row as shown in figure 9,   This is the first sample point of the next
row.   Now lay out the remaining points at distance s from each other.   By
systematically following this plan, the entire design can be laid out.

          Figure 10 shows the sample point locations for the 37 grid points
for the example PCS spill site diagrammed previously in Figures 1, 2,  and 3.
On the diagram, r = 3-1/4 in.  so from Table 2 the grid spacing is s = 0.30r -
1 in,  and the distance between the rows is u = 0.26r = 7/8 in.

          In Figure 10,  a horizontal diameter is drawn through C.   Sampling
locations 1 through 7 are marked I in,  apart.   To lay out the next row of the
design, we first find location 8.   Point D is the midpoint between locations
3 and 4.   Then, as described,  location 8 is a vertical  distance u = 7/8 in.
{3 ft 6 in.  on the site) above D.   Now locations 9 through 13 are laid out
1 in.  apart.  In the same way, locations 14 through 18 are found.   Continuing
so, the entire grid is marked on the diagram.

          All of the sample points in Figure 10 are numbered (1 to 37),   Any
type of numbering system can be used, but the points must each be identified
so that the location of  the samples taken can be identified by reference to
the diagram points.

          Note that sampling locations 4, 7, 8,  13, 23, 34, 35, 36, and 37
are outside the cleanup  area.   Of these, locations 4, 8, 23, 34, and 35 do
not correspond to a physical location—al 1 are in "thin air," so to speak--
and samples cannot be collected at these locations.   Locations 36 and 37 are
concrete samples; locations 7 and 13 are dirt samples (from Figure 2).
                                    20

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                                      Sampling Circle
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          The orientation of the sample circle diameter shown does not ac-
tually maximize the number of points falling within the spill area, since a
45° clockwise rotation would result in only 8 points lying outside the spill
area instead of the 9 points shown,  However, a 45° orientation would make
the sample points very difficult to locate on the actual site with little to
gain by the addition of one more sample point within the spill area.

     5,6  Step 6:  Lay Out the	Sampjing Locations on the Site

          To locate the sample points on the site, use the same procedure as
was used to construct the diagram of the sample points in Step 5, but use a
tape measure or pacing, as appropriate, to measure distance.   Since s = 1 in.
in the diagram (figure 10), then s = 4 ft on the site.   Similarly, u = 3 ft
6 in.  on the site.   It may be helpful to show the actual distances (in ft) on
the diagram before laying out the site sample points.   For example, the sam-
ples on the wall are most easily found by measuring the distance on the scaled
diagram from one end of the wall and the height above the driveway, and then
converting these measurements to find the actual location on the wall.  Con-
sider point 32, for example.   On Figure 10, it is located approximately 3/4 in.
above the driveway and 5/8 in,  from the left edge of the wall.  On the site,
then,  this point is 3 ft above the driveway and 2-1/2 ft from the left edge
of the wal1.

          The PCB spill site should be considered contaminated until  labora-
tory analyses of the samples taken verify the site is clean.   Therefore,  cau-
tion should be exercised when marking the sample points on the site to prevent
possible cross-contamination.   The inspector should make minimum contact with
the spill surfaces.  One method for accomplishing this would be to cover the
surfaces with plastic sheeting.
                                    22

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sampling points include suspicious stains outside the spill area, cracks or
crevices, or any area where the inspector suspects inadequate cleanup,

          5.7.4  Samp1ing Sma11 ftreas

          The grid sample design specifies that seven samples should be taken
in areas which have a sample circle radius of less than 4 ft.   In cases where
the spill area is very small, fewer than seven samples can be taken at the
discretion of the EPA inspector.

     5,8  Exampleof Laying Outthe Sample Design

          This section summarizes the step-wise procedures required to deter-
mine the locations of the grid sample points at a PCB spill site.  The example
used is  a simple 8 x 10 ft rectangular spill site.

          Steps 1 and 2:   Measure and Diagram the PCB Spill Cleanup Site

          The PCB spill cleanup site must first be measured (usually with a
tape measure).   Then the site should be drawn to scale on graph paper.  In
this example, the site is assumed to be an 8 x 10 ft rectangle, as shown in
Figure 11.   A scale of 1 in.  = 2 ft is used.

          Step 3:   Determine theCenter and Radius of the	Sampling Circle

          The center and radius of the sampling circle is determined on a
separate diagram as follows,  and is illustrated in Figure 12:

          1.    Draw the site diagram to scale (same as Figure 11).

          2.    Draw a line representing the longest dimension, Ll5 of the
               site diagram.

          3.    find the midpoint, P, of Lj.
                                    24

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                                                           N
                          Soil
  2'
Scale
     Figure  11,   Scale         of PCS spill site.

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                                                       N
i '

      *
'igure  12.
          Determini no center (C
            of sampline circle.
)  and  samo 1 irtc rad 1 us ir'!

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          4.   Draw a second line, L2, perpendicular to  Llt through  point  P.
               Line L2 must extend to the boundaries of  the site,

          5,   Find the midpoint, C, of line L2.  Point  C is the center of  the
               sampling circle,  (In this example, points P and C coincide,
               but will not coincide for many other types of configurations.)

          6.   Measure the distance from point  C to either end of L1, which
               is the samp!ing radius, r.   The  distance, r, should be measured
               to the nearest 1/16 in,

          7.   Scale radius, r, up to actual size.  In this example, the
               radius, r, is 3-1/4 in, on a scale of 1 in.  = 2 ft, or 6-1/2 ft
               (3-1/4 in. x 2 ft/in.).

          Step 4:  Find the Nunber_gjf_Grj_d_Samgles_to be Used

          The number of samples to be taken in  a hexagonal  grid depends upon
the length of the sampling radius, as shown in Table 1 and repeated  here,

               Sampling Radius, r (ft)       Number of Samples
                        S 4                          7
                     > 4 - 11                       19
                       > 11                         37
          Since the radius in this example is 6-1/2 ft,  the number of sampling
points would be 19.

          Step 5:  Plot the Sampling Points on the Site Diagram

          The sampling points in a grid row are a distance, s, apart; and the
grid rows are a distance, u, apart.   The distances s and u are determined from
the following table.
                                    27

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                           Distance, s, Between      Distance, u. Between
    Number of Samples     Adjacent Sampl_e Points     	 Adjacent Rows	
            ?                      0.87 r                    0,75 r
           19                      0.48 r                    0,42 r
           37                      0,30 r                    0-26 r
          In this example, the distance,  s,  between the points in a row is
1-9/18 in. [(0.48) x (3.25 in.)] on the diagram, or about 3 ft 2 in,
[(1-9/16 in.) x (2 ft/in.)] on the actual site.   The distance, u, between
rows is 1-3/8 in,  [(0,42) x (3.25 in.)] on the diagram, or about 2 ft 9 in.
[(1-3/8 in.) x (2 ft/in.)] on the actual  site.

          The center point of the grid lies  on the center, C,  of the sampling
circle.  Construct the hexagonal grid and superimpose it over  the site diagram
(constructed on a third piece of graph paper),  as illustrated  in Figure 13 for
this example.  The middle row of the grid (points 1 through 5} should be
oriented to maximize the number of sample points which lie within the bound-
aries of the spill cleanup site.

          It should be noted that adjacent rows are staggered, and that the
sample points of one row are located midway  (horizontally) between the sample
points of the other row.

          Step 6:   Hark the Sample Points	on the	jrtg

          Starting at the center, C, of the  spill cleanup site,  mark the mid-
dle row points a distance of 3 ft 2 in. apart.   Locate the adjacent rows a
distance (u) of 2 ft 9 in. from the middle row, and mark the four sample
points in each of these rows a distance of 3 ft 2 in,  apart.   Complete the
site sampling grid with the other two rows of sample points.
8.0  SAMPLE COLLECTION, HANDLING fiND PRESERVATION

          After the sampling grid has been diagrammed on the site description
forms and laid out on the site,  a sample must be taken at each grid point.
                                    28

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                   a
                   10
                   a
                   11
                   a
                   12
                                                                       N
         a
         6
         a
         7
o
1
o
2
                             D
                             9
                                                 u = 1-3/8" - 2'9'


                                                  s* (midpoint)
3s= 1-9/16
                 -N3
         O
         13
         O
         14
          O
         15
D
16
          O
          5
                   a
                   17
                   a
                  18
                   D
                   19
            Scale
             Figure 13,          of  19-point grid               on  the
                          PCB spill site.

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template and scoop may then be placed in a plastic bag to be taken back to the
laboratory to be cleaned for the next field sampling job.  The rubber gloves
should be discarded into a plastic bag which will be disposed of as PCB-
contaminated material if any samples exhibit PCB contamination.

          If a sufficient number of templates or scoops are not available to
use only one item per sample, then each of these equipment items must be
thoroughly cleaned between samples.  The template and scoop should be thor-
oughly rinsed with solvent and wiped with a disposable wiping cloth (which
should be discarded into the plastic bag intended for disposal  of PC8-
contaminated materials).

     6, 2  So i 1Core-Samp1ing

          When core samples of sod or soil are needed, the samples may be taken
using a coring device such as a piston corer or King-tube sampler.   Core sam-
ples should be taken to a depth of about 5 cm.   The soil  core can be pushed
out into a precleaned glass bottle and capped,  or the tube containing the sam-
ple can be wrapped in solvent-rinsed aluminum foil, depending upon the type
of coring device used.   The sample should be properly labeled,  a yellow TSCA
PCB mark affixed, and placed in an ice chest (to keep the sample about 4°C).
If samples are to be analyzed soon, the cold storage requirements may be re-
laxed as long as sample integrity is maintained.   The sample collection data
should be entered in the field log book and on the chain-of-custody form.

          Core samples of  soil or sod should be taken with individual  core
tubes for each sample.   If this is not possible,  then the coring device should
be rinsed with solvent and wiped with a disposable wipe cloth to remove any
visible particles before taking another sample.   After each sample, rubber
gloves and wipe cloth should be discarded into a plastic  bag intended for dis-
posal  of PCS-contaminated  materials.
                                    31

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     8.3  Water Sampling

          PCB spills on water may result in a surface film (particularly when
the PCBs are dissolved in hydrocarbon oils) or sink to the bottom (particu-
larly when the PCBs are in askarel or other heavier-than-water matrix).  When
a surface film is suspected (or visible), the water surface should be sampled.
Otherwise, a water sample should be taken near the bottom of the body of water.

          6.3.1  Surf_ace S amp 1ing

          Surface water samples should be collected by lowering an open, pre-
cleaned glass sample bottle horizontally into the water at the designated sam-
ple collection point.   As water begins to run into the bottle, slowly turn
the bottle upright, keeping the lip just under the surface so that only surface
water is collected.   Lift the bottle out of the water, wipe the outside with
a disposable wiping cloth, and cap the bottle.  Label the bottle, affix a
yellow TSCA PCB mark,  and put the bottle in an ice chest (to keep the sample
at about 4°C).   If samples are to be analyzed soon, the cold storage require-
ments may be relaxed as long as sample integrity is maintained.   The sample
collection data should be entered in the field log book and on the chain-of-
custody form.   The wiping cloth and rubber gloves should be discarded into a
plastic bag used for disposal  of RGB-contaminated materials.

          6.3.2  Subs u rfa ce Samp 1i ng

          Water near the bottom of the body of water should be sampled by
lowering a sealed sampler bottle to the required depth,  removing the bottle
top, allowing the bottle to fill,  and removing the bottle from the water.
Transfer the subsurface sample into a precleaned glass bottle and cap.   Wipe
the bottle with a disposable wiping cloth,  fill  out and label the sample bot-
tle, affix a yellow TSCA PCB mark, and put the sample bottle in an ice chest.
If samples are to be analyzed soon,  the cold storage requirements may be re-
laxed as long as sample integrity is maintained.   The sample collection data
should be entered into the field log book and on the chain-of-custody form.
                                    32

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                                              '""  sea r d e d  1n t o  a p 1 a s t i c b a g
          To prevent cross-contamination  of  samples,  separate sampler bottles
should be used to take th<=>  samples.  Alternatively,  the  sampler  bottle can be
rinsed three times with distil iecl  w^te*",  so i \ ent- r i nset;,  and air^ar"ed beiweer
samp 1es.
          A wipe $amp''e  is taken by  Mr'st apply-nq a  suitable  so"
as isooctanej to a piece of 11 cm  filter paper  (e.g., Whatman  40  ashless  or
Whatman bO smear tabs) or gauze pad.  The moistened  filter paper  or  gauze
pad is ther held with a pair of stainless steel  forcep1"--  or rubber  gioves  and

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     6- 5  yeggtation Samp]inj

          The sample design or visual observation may indicate that samples
of vegetation, such as tree leaves, bushes, and flowers, are required.  In
this case, the sample may be taken with pruning shears,  a saw, or other suit-
able tool, and placed in a precleaned glass bottle, which should be capped,
labeled, affixed with a yellow TSCA PCS mark, and placed in an ice chest.
If samples are to be analyzed soon, the cold storage requirements may be re-
laxed as long as sample integrity is maintained.   The sample collection data
should be entered into the field log book and on the chain-of-custody form.

          After each sample is taken, the pruning shears should be rinsed with
solvent and wiped with a disposable wipe cloth to prevent cross-contamination
between samples.   Also, rubber gloves and wipe cloths should be discarded into
a plastic disposal  bag intended for PCB-contaminated materials.

     6,6  Compositing Strategies

          Compositing is the pooling of several samples  to form one sample
for chemical  analysis.   In many circumstances it may be  desirable to com-
posite samples to reduce the number of (often costly) analyses needed.  The
suggested strategies for compositing samples are given in the appendix.
7.0  QUALITY ASSURANCE

          Quality assurance must be applied throughout the entire sampling
program, including sample design and sample collection, handling, and preser-
vation.   Each EPA office must develop a quality assurance plan (QAP) accord-
ing to EPA guidelines (USEPA 1980).   The QAP must be submitted to the re-
gional QA officer or other appropriate QA official  for approval  prior to
sampling PCB spill sites.
                                    35

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          The elements of a QAP (USEPA 1980) include:

          Title page
          Table of contents
          Project description
          Project organization and responsibility
          QA objectives for measurement data in terms of precision, accuracy,
            completeness, representativeness, and comparability
          Sampling procedures
          Sample tracking and traceability
          Calibration procedures and frequency
          Analytical procedures
          Data reduction, validation, and reporting
          Internal quality control checks
          Performance and system audits
          Preventive maintenace
          Specific routine procedures used to assess data precision,
            accuracy, and completeness
          Corrective action
          Quality assurance reports to management

          Each EPA inspector who will sample PCB spill  sites should understand
and conform with all elements of the QAP,
8,0  QUALITY

          Each EPA office that samples PCB spill  sites must operate a formal
quality control (QC) program.   The minimum requirements of this program con-
sist of preparing field blanks for the laboratory;  sampling without contam-
ination of samples; maintaining a rigid chain-of-custody procedure for the
samples; and fully documenting the entire sampling  program and maintaining
records of the documentation.
                                    36

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          The quality control measures taken by each EPA office should be
stipulated in the QA plan.  The QC measures discussed below are given as ex-
amples only.   EPA offices must decide which of the following measures, and
additional measures, will be required for each situation.

     8.1  Field _Bjanks

          Field blanks are given to the laboratory to demonstrate that the
sampling equipment has not been contaminated,   A field blank may be generated
by using the sampling equipment to obtain a clean sample of solids or water.
for example,  the scoop or soil coring device can be used to obtain a clean
solids blank sample.  The water sampling equipment can be used to collect a
blank sample using laboratory reagent grade water.   These field blanks should
be obtained both before and after field sampling.

          Field blanks for wipe samples should be obtained in the field by
wetting a clean filter paper with the solvent and storing the wetted paper in
a clean sample jar.

          One empty glass sample bottle and one filled with solvent should
also be given to the laboratory as field blanks,

     8.2  Sampling Without Contamination

          Samples collected from PCB spill  sites which have been cleaned up
may become contaminated in two ways:   (a) dirty sample containers, and (b)
cross-contamination of samples from the use of contaminated sampling equip-
ment.   The first type of contamination can  be eliminated by properly pre-
cleaning all  sample containers prior to making the sampling trip.   All glass
jars should be washed with soap and water,  rinsed three times with distilled
water, rinsed with solvent (isooctane is recommended), baked in an oven at
350°C for 1 h, and sealed with a Teflon-lined cap.   All aluminum foil used
should be rinsed with solvent.
                                    37

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          The sampling equipment should be precleaned before the site visit
by rinsing with solvent and thoroughly wiping the equipment down.   Cross-
contamination during sampling can be avoided by using a separate sampler (such
as a scoop, spatula, corer, etc.) for each sample, or cleaning the sample
equipment between samples.   Methods that can be used to clean the  equipment
between samples are given in the sample collection, handling, and  preservation
discussion (Section 6,0).

     8.3  SampleCustody

          As part of the quality assurance plan,  the chain-of-custody proto-
col must be described.   A chain-of-custody provides defensible proof of the
sample,  and data integrity.  The less rigorous sample traceability documenta-
tion merely provides a record of when operations  were performed, and by whom.
Sample traceability is not acceptable for enforcement activities.

          Chain-of-custody is required for analyses which may result in legal
proceedings, and when the data must be subject to legal scrutiny.   Chain-of-
custody provides conclusive written proof that samples are taken,  transferred,
prepared, and analyzed in an unbroken line as a means to maintain  sample in-
tegrity.  A sample is in custody if:

          -  It is in the possession of an authorized individual.

             It is in the field of vision of an authorized individual.

             It is in a designated secure area.

             It has been placed in a locked container by an authorized
             individual.

A typical chain-of-custody protocol contains the following elements:

          1.  Unique sample identification numbers.
                                    38

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9.0  DOCUMENTATION AND

          Each EPA office is responsible for preparing and maintaining com-
plete records of the field sampling operations.   A detailed documentation plan
should be prepared as a. part of the QAP ,  and should be strictly followed.  The
following written records should be maintained for each field sampling opera-
tion:

          Equipment preparation log book
          Sample codes
          Field log book
          Site description forms
          thai n~of -custody forms
          Sample analysis request forms
          Field trip report

     9. 1  Equipment Preparation Log Book

          A log book should be maintained which lists the sampling equipment
taken to each spill  site.   A detailed description of the cleaning and prepara-
tion procedures used for the sample collection equipment (templates,  scoops,
glass bottle, etc.)  should be recorded.

     9. 2
          Each sample should be assigned a unique sample code and labeled
accordingly when collected.   The sample code should contain information on
the site and which sampling point the sample represents.   This sample code
must, be used to identify all sample records,

          Each sample must also be labeled with a yellow TSCA PCB mark as
described in 40 CFR 761.45 until it is determined to be PCB free.
                                    40

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     9.3  Field Log Book

          The EPA inspector should maintain a field log book which contains
all information pertinent to the field sampling program.   The notebook should
be bound and entries be made in ink by the field inspector.   All entries
should be signed by the inspector.

          At a minimum, the log book should include the following entries;

          Owner of spi11 site
          Location of spill site
          Date(s) of sample collection
          Exact times of sample collection
          Type of samples taken and sample identification numbers
          Number of samples taken
          Description of sampling methodology
          Field observations
          Name and address of field contact
          Cross-reference of sample identification numbers to grid sample
            points (shown on site description forms)

          Since sampling situations will  vary widely,  no  specific guidelines
can be given as to the extent of information which should be entered into the
field log book.   Enough information should be recorded, however, so that some-
one can reconstruct the sampling program  in the absence of the field inspector.

          The field log book should be maintained in a secure place.

     9.4  Site Description Forms

          Serialized site description forms should be used to record the con-
ditions of the site, provide sketches of  the site, and show the location of
the grid sampling points.   The grid sampling points should be shown on di-
mensioned drawings and numbered.   These forms should be accompanied by
                                    41

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photographs (preferably Polaroid-type photographs) of the site.  Each  form
and photograph should be signed and dated by the EPA inspector,

     9, 5  Chain-of-C us tody Fo rms

          Chain-of-custody forms should be completed and accompany the samples.
These forms should contain the following information:

             Project site
             Sample identification number
             Date and time of sample collection
             Location of sample site
             Type of sample (soil, water, etc.)
             Signature of sample collector
             Signatures of those who relinquish and those who receive the
               samples, and date and time that samples change possession
             Inclusive dates of possession

     9. 6  Sajti£j_e_and_Anii'j_ -\_^_^^< . j e__s tFgrtns

          A sample analysis request form should accompany the samples de-
livered to the laboratory.  The field inspector should enter the following
information on the form:

             Project si te
             Name of sample collector
             Sample identification numbers
             Types of samples (soil, water, etc.)
             Location of sample site for each sample
             Analysis requested [analyte (i.e., total PCBs), method, desired
               method detection limit, etc.]
             QC requirements (replicates, lab blanks, lab spikes, etc.)
             Special handling and storage requirements
                                    42

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          The laboratory personnel receiving the samples should enter the
following information on the form:

             Name of person receiving the samples
             Laboratory sample numbers
             Date of sample receipt
             Sample allocation
             Analyses to be performed

     9.7  Field Trip Report

          The EPA inspector should prepare a brief field trip report to be
maintained on file.   The report should provide information such as the proj-
ect site, date(s) of sampling, types and number of samples collected, any
problems encountered, any notable events, and specific reference to the other
documents listed above.
10.0  VALIDATION OF THE MANUAL

          A previous draft of this manual entitled "Field Manual for Verifi-
cation of PCB Spill Cleanup" (Draft Interim Report No,  3, Task 37, EPA Prime
Contract No.  68-02-3938, June 27, 1985) was used in a brief field validation
study.  The primary purposes of the study were to:   (1) determine the degree
of difficulty of understanding the grid sampling designs in the field manual;
(2) determine the amount of time and degree of difficulty required to lay out
the sampling grids on simulated PCB spill sites; and (3) identify any concerns
or problems that may arise in implementing the field manual.   To achieve these
goals, simulated PCB spill sites were constructed for the exercise.   Four per-
sons (Mr,  David Phillippi and Mr. Robert Jackson of the EPA Region VII Office
and Ms.  Joan Westbrook and Mr.  Ted Harrison of MRI) were selected to lay out
the sampling grids on the spill sites after they had read the field manual.
These four persons had no prior association with developing the field manual.
Other persons from EPA and MRI acted as observers since they were intimately
familiar with the field manual.
                                    43

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          Four simulated spill sites having the following characteristics
were laid out:

             A rectangle (3 ft x 6 ft)
             A parallelogram (about 3 ft on a side)
             A circle (about 12 ft diameter)
             A square (6 ft on a side)

The first two sites required seven grid sample points, and the other two re-
quired 19 grid sample points.

          Each of the four "inspectors" laid out the grid sample points on
two of the four sites after constructing the designs on graph paper.  In all
cases the sample points were laid out correctly with little or no difficulty
in 30 min or less.   Each inspector commented that there was little or no dif-
ficulty in performing the exercises.

          As a final exercise, a "large irregular simulated PCB spill site
was constructed, and all attendees participated in laying out the 37 grid
sample points.  The spill site was designed so that some sample points were
located on the floor and two adjacent walls to make the exercise relatively
difficult.  The 37 grid sample points were laid out correctly with relative
ease in about 45 min.   Some discussions were required to decide how to treat
sampling points which fell  in the overlap where the two walls intersected.

          It was concluded from the exercise and discussions which followed
that:   (1) the field manual is easy to follow and understood by people un-
familiar with the manual prior to reading it; (2) the grid sample points are
never "perfectly" laid out (with the sample points precisely aligned) so that,
some degree of randomness is built into the sample designs; (3) the time re-
quired to lay out the grid sample points after the boundaries of the spill
site have been determined is relatively short (less than 1 h); and (4) using
this manual, the grid sample points can be correctly laid out by inexperienced
people.
                                    44

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11.0

       BA, Erickson MO, Swanson SA, Kelso GL, Cox DC, Schultz BO.
(August),   Verification of PCB spill cleanup by sampling     analysis (second
printing).  Interim report.   Washington, DC:  Office of Toxic Substances, U.S.
Environmental  Protection Agency.   EPA-560/5-85-026.

Mason BJ.   1982 (October).  Preparation of soil sampling protocol:   tech-
niques and strategies.   ETHURA, McLean, VA, under subcontract to Environ-
mental Research Center, University of Nevada, for U.S.  Environmental
Protection Agency, Las Vegas.

USEPA,  1980.   U.S.  Environmental  Protection Agency.   Guidelines     specifi-
cations for preparing quality assurance project plans.   Office of Monitoring
Systems and Quality Assurance, QAMS-005/80.

USEPA,  1981 (March),   U.S.  Environmental Protection Agency.   TSCA Inspection
Manual.
                                    45

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APPENDIX
   A-l

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                                  APPENDIX
          This appendix gives suggested strategies for compositing samples
taken from PCB spill  sites which are sampled using the grid sampling methods
described in the text of the report.   Compositing may result in a savings of
analysis time and cost.  Sample compositing is not required and should be
used only if time or cost savings may result.   The strategies for forming
composites are as follows:

          1.  Composite only samples of the same type (i.e., all  soil or all
water).   Since the composite must be thoroughly mixed to ensure homogeneity,
certain types of samples such as asphalt, wipe samples, wood samples and
other hard-to-mix matrices should not be composited.

          2.  Do not form a composite with more than 10 samples,  since in
some situations compositing a greater number of samples may lead to such low
PCB levels in the composite that the recommended analytical method approaches
its limit of detection and becomes less reliable.

          3.  for each type of sample, determine the number of composites to
be formed using the table below.
                  Number of samples          Number of composites
                         2-10                          1
                        11-20                          2
                        21-30                          3
                        31-37                          4
          As much as possible, try to form composites of equal size.   For
example, if 37 soil samples are taken, then four composites could be formed
using 9, 9, 9, and 10 samples apiece.
                                     A-2

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          4.   To the extent possible, composite adjacent samples.   If resi-
dual contamination is present, it is likely that, high PCB levels will be
found in some samples taken close together.

          Because of the large number of situations that     be encountered
in practice,  it is not possible to specify compositing strategies more pre-
cisely.   The  laboratory     field staff should exercise judgment in all  case?
                                     ft-3

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