GENERAL FIELD
                                  SAMPLING GUIDELINES
                                        SOP#: 2001
                                   DATE: 08/11/94
                                        REV. #:  0.0
1.0     SCOPE AND APPLICATION

The purpose of this Standard Operating Procedure
(SOP) is to provide general field sampling guidelines
that will assist REAC personnel in choosing sampling
strategies,  location,   and  frequency   for  proper
assessment of  site  characteristics.   This SOP is
applicable to all field activities that involve sampling.

These   are  standard  (i.e.,  typically  applicable)
operating procedures which may be varied or changed
as required, dependent on site conditions, equipment
limitations or limitations imposed by the procedure. In
all instances, the ultimate procedures employed should
be documented and associated with the final report.

Mention of trade names or commercial products does
not    constitute   U.S.   EPA   endorsement   or
recommendation for use.

2.0     METHOD SUMMARY

Sampling is the selection of a representative portion of
a larger population,  universe,  or body.  Through
examination of a  sample, the characteristics of the
larger body from which the sample was drawn can be
inferred.  In this manner, sampling can be a valuable
tool for determining the presence, type, and extent of
contamination  by hazardous  substances in  the
environment.

The primary objective  of all sampling activities is to
characterize a hazardous waste site accurately so that
its impact on human health and the environment can
be properly evaluated. It is only through sampling and
analysis that site hazards can be measured and the job
of cleanup and  restoration  can  be  accomplished
effectively  with minimal risk.  The sampling itself
must  be conducted  so that  every  sample collected
retains  its  original  physical form  and  chemical
composition. In this way,  sample integrity is insured,
quality assurance  standards  are maintained, and the
sample can accurately represent the  larger body of
material under investigation.

The extent to which valid inferences can be drawn
from a sample depends on the degree to which the
sampling effort conforms  to the project's objectives.
For example, as few  as  one  sample may  produce
adequate,  technically  valid  data  to  address  the
project's objectives. Meeting the project's objectives
requires thorough planning  of sampling activities, and
implementation of the most appropriate sampling and
analytical procedures. These issues will be discussed
in this procedure.

3.0     SAMPLE      PRESERVATION,
        CONTAINERS,     HANDLING,
        AND STORAGE

The amount of sample to be collected, and the proper
sample container type  (i.e., glass, plastic), chemical
preservation, and storage requirements are dependent
on the matrix being sampled and the parameter(s) of
interest.  Sample preservation, containers, handling,
and storage for air and waste samples are discussed in
the specific  SOPs  for   air  and  waste  sampling
techniques.

4.0     INTERFERENCES      AND
        POTENTIAL PROBLEMS

The nature of the object or materials being sampled
may be a potential  problem to the sampler.  If a
material  is homogeneous, it will generally have a
uniform composition throughout.  In this case,  any
sample increment can be considered representative of
the material.  On the other  hand, heterogeneous
samples present problems to the sampler because of
changes in the material over distance, both laterally
and vertically.

Samples of hazardous materials may pose  a safety
threat to both field and laboratory personnel. Proper
health and safety precautions should be implemented
when handling this type of sample.

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Environmental  conditions,  weather conditions, or
non-target chemicals  may  cause  problems and/or
interferences when performing sampling activities or
when sampling for a specific parameter.  Refer to the
specific SOPs for sampling techniques.

5.0     EQUIPMENT/APPARATUS

The equipment/apparatus required to collect samples
must be determined on a site specific basis. Due to the
wide variety of sampling equipment available, refer to
the specific SOPs for sampling techniques which
include lists of the equipment/apparatus required for
sampling.

6.0     REAGENTS

Reagents may be utilized for preservation of samples
and for decontamination of sampling equipment.  The
preservatives required are specified by the analysis to
be  performed.   Decontamination  solutions  are
specified in ERT SOP #2006, Sampling Equipment
Decontamination.

7.0     PROCEDURE

7.1     Types of Samples

In relation to the media to be sampled, two basic types
of samples can be considered:  the environmental
sample and the hazardous sample.

Environmental  samples are those collected from
streams, ponds, lakes, wells, and are off-site samples
that  are not  expected  to  be  contaminated  with
hazardous materials. They usually do not require the
special  handling  procedures  typically  used  for
concentrated wastes.  However, in certain instances,
environmental   samples   can   contain   elevated
concentrations of pollutants and in such cases would
have to be handled as hazardous samples.

Hazardous or concentrated samples are those collected
from drums, tanks, lagoons, pits, waste piles, fresh
spills, or areas previously identified as  contaminated,
and require special handling procedures because of
their potential toxicity or hazard. These samples can
be further subdivided based on their degree of hazard;
however, care should be  taken when handling  and
shipping any wastes  believed to be  concentrated
regardless of the degree.
The  importance of making the distinction between
environmental and hazardous samples is two-fold:

(1)      Personnel safety requirements:  Any sample
        thought  to   contain  enough  hazardous
        materials to  pose a safely threat should be
        designated as hazardous and handled in a
        manner which ensures the safety of both field
        and laboratory personnel.

(2)      Transportation requirements:  Hazardous
        samples  must be  packaged, labeled,  and
        shipped according to the International Air
        Transport Association (IATA) Dangerous
        Goods  Regulations  or  Department  of
        Transportation (DOT) regulations and U.S.
        EPA guidelines.

7.2     Sample Collection Techniques

In general,  two basic  types  of  sample collection
techniques are recognized, both of which can be used
for either environmental or hazardous samples.

Grab Samples

A grab sample  is  defined as  a discrete  aliquot
representative of a specific location at a given point in
time.  The  sample is collected all  at once at one
particular point  in  the   sample medium.    The
representativeness of such samples is defined by the
nature of the materials being sampled. In general, as
sources  vary   over  time  and   distance,  the
representativeness of grab samples will decrease.

Composite Samples

Composites  are  nondiscrete samples composed of
more than one specific aliquot collected at various
sampling  locations and/or different  points in time.
Analysis of this type  of sample produces an average
value and can in certain instances  be used as an
alternative to analyzing a  number of individual grab
samples and calculating an average value.  It should
be noted, however,  that  compositing can mask
problems by  diluting isolated concentrations of some
hazardous compounds below detection limits.

Compositing is often used for environmental samples
and may be used for hazardous samples under certain
conditions.  For example, compositing of hazardous
waste is often performed after compatibility tests have

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been completed to determine an average value over a
number of different locations (group of drums).  This
procedure  generates  data  that  can  be  useful  by
providing an average concentration within a number
of units, can serve to keep analytical costs down, and
can provide  information useful to transporters and
waste disposal operations.

For sampling situations involving hazardous wastes,
grab  sampling techniques  are generally preferred
because grab sampling minimizes the amount of time
sampling personnel  must  be in contact with the
wastes, reduces risks associated with  compositing
unknowns,  and eliminates  chemical  changes  that
might occur due to compositing.

7.3     Types of Sampling Strategies

The number of samples that should be collected and
analyzed depends on the objective of the investigation.
There are three basic  sampling strategies: random,
systematic, and judgmental  sampling.

Random sampling involves collection of samples in a
nonsystematic fashion from the entire site or a specific
portion of a site.  Systematic  sampling involves
collection of samples based on a  grid or a  pattern
which has  been  previously  established.   When
judgmental  sampling is performed,  samples are
collected only from the portion(s) of the site  most
likely to be contaminated.  Often, a combination of
these strategies is the best approach depending on the
type  of the suspected/known contamination, the
uniformity and size of the site, the  level/type of
information desired, etc.

7.4     QA Work  Plans (QAWP)

A QAWP is required when  it becomes evident that a
field investigation is necessary. It should be initiated
in conjunction  with,  or  immediately  following,
notification of the field investigation. This plan should
be clear and concise and should detail the following
basic components, with regard to sampling activities:

•       Objective and purpose of the investigation.
•       Basis upon which data will be evaluated.
•       Information known about the site including
        location, type and size of the  facility, and
        length of operations/abandonment.
•       Type and volume of contaminated material,
        contaminants   of   concern    (including
        concentration),    and    basis    of   the
        information/data.
•       Technical approach including media/matrix
        to be sampled, sampling equipment to  be
        used, sample equipment decontamination (if
        necessary), sampling design and rationale,
        and SOPs or description of the procedure to
        be implemented.
•       Project management and reporting, schedule,
        project  organization  and responsibilities,
        manpower and cost projections, and required
        deliverables.
•       QA objectives and protocols including tables
        summarizing field  sampling and  QA/QC
        analysis and objectives.

Note that this list of QAWP components is not all-
inclusive and that additional elements may be added
or altered depending on the specific requirements of
the field investigation.  It should also be recognized
that although a detailed QAWP is quite important, it
may be impractical in some instances. Emergency
responses and accidental spills are prime examples of
such  instances  where  time  might  prohibit  the
development of site-specific QAWPs prior to  field
activities.  In such cases, investigators would have to
rely on general guidelines and personal judgment, and
the sampling or response plans might simply  be a
strategy  based  on  preliminary  information  and
finalized on site. In any event, a plan of action should
be developed, no matter how concise or informal, to
aid investigators  in  maintaining  a logical  and
consistent order to the implementation of their task.

7.5     Legal Implications

The data derived from sampling activities are often
introduced as critical evidence during litigation of a
hazardous waste site cleanup. Legal issues in which
sampling data are important may include cleanup cost
recovery,  identification of pollution sources and
responsible  parties, and  technical  validation  of
remedial design methodologies.  Because  of the
potential for  involvement  in  legal  actions,  strict
adherence to technical and  administrative SOPs is
essential  during   both  the  development  and
implementation of sampling activities.

Technically valid sampling begins with thorough
planning and continues through the sample collection
and   analytical   procedures.      Administrative
requirements    involve    thorough,    accurate

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documentation    of   all   sampling   activities.         10.0 DATA VALIDATION
Documentation requirements include maintenance of
a chain of custody, as well as accurate records of field        Refer to  the  specific  SOPs  for data validation
activities and analytical  instructions.  Failure to        activities  that  are  associated   with  sampling
observe these procedures fully  and consistently may        techniques
result  in data  that  are questionable, invalid  and
non-defensible in court, and the consequent loss of        110    HEALTH AND SAFETY
enforcement proceedings.
                                                        When working with potentially hazardous materials,
8.0     CALCULATIONS                          follow U.S. EPA, OSHA, and  corporate health and
                                                        safely procedures.
Refer to the specific  SOPs for any calculations which
are associated with sampling techniques.

9.0     QUALITY ASSURANCE/
        QUALITY CONTROL

Refer to the specific  SOPs for the type and frequency
of QA/QC samples to be  analyzed, the acceptance
criteria for the QA/QC samples, and any other QA/QC
activities  which are  associated with sampling
techniques.

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