Chapter 12

HAZARDOUS WASTE SITE

INVESTIGATIONS

General

Hazardous waste site investigations are geologic by

nature. Site geology affects how the contaminants enter
and migrate through the environment, controls the
severity of the contamination problem, and determines if
and how the contamination is remediated. An accurate
characterization of site geology is critical for the
successful removal and/or remediation of hazardous
waste.

Investigations at hazardous waste sites use the same

basic tenets of geology commonly applied in other areas
of engineering geologic exploration. Even though these
engineering geologic investigation techniques are
universal, certain specialized criteria and regulations are
required at hazardous waste sites which differ from
traditional geologic work. This chapter assumes that
accepted geologic procedures and equipment are used at
hazardous waste sites and only discusses the variations
in the planning, implementation, and documentation of
geologic field work required at such sites. Documentation
at hazardous waste sites plays a very prominent role and
involves much more effort than other geologic
investigations.

This chapter provides a general overview of documents,

terminology, processes, requirements, and site specific
factors for an investigation. This information can be used
to better prepare or conduct a field program. Much
information provided here is extracted from numerous
Environmental Protection Agency (EPA) guidance
documents. Hazardous waste investigations involve a
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myriad of documents and processes, mostly referred to by

acronyms. See the appendix for an explanation of the
more common acronyms.

In hazardous waste investigations, understanding the

contaminant’s physical and chemical properties is very
important. These properties are useful for predicting
pathways that allow contaminant migration through
complex subsurface conditions. The understanding of
subsurface conditions permits a program designed to
better investigate and sample potentially contaminated
soil, rock, and water.

Common Terminology and Processes

The "typical" hazardous waste site remediation process

involves several investigation phases. Each phase
usually has a different emphasis and a different level of
detail.

In general, there are two sets of regulations involved in

hazardous waste site remediation: Resource Conserva-
tion Recovery Act (RCRA) and Comprehensive Environ-
mental Response, Compensation, and Liability Act
(CERCLA). RCRA regulations are largely confined to
operators and generators of existing facilities, whereas
CERCLA regulations are confined to the investigation of
abandoned sites (Superfund). Although most Bureau of
Reclamation (Reclamation) activities involve CERCLA
investigations, wastes generated during the investigation
may fall under RCRA regulations.

According to EPA guidelines (Guidance for Performing

Preliminary Assessments Under CERCLA, EPA/540/G-
91/013), EPA uses a structured program to determine
appropriate response for Superfund sites. The CERCLA/

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Superfund Amendments and Reauthorization Act of 1986

(SARA) process ideally evolves through the following
phases: (1) discovery, (2) preliminary assessment, (3) site
inspection, (4) hazard ranking, (5) remedial investigation,
(6) feasibility study, (7) record of decision, (8) remedial
design, (9) remedial action, and (10) operation and
maintenance. Removal actions may occur at any stage.

Documentation

Proper documentation at jobs involving hazardous waste

is more important than at more "traditional" geologic
investigation sites. The alleged low concentration values
for risks to human health and the associated costs for
contaminant testing are primary reasons for good
documentation. Soil contaminants are typically reported
in parts per million (ppm) (milligram per kilogram
[mg/Kg]) and water contaminants are typically reported
in parts per billion (ppb) (microgram per liter [µg/L]).
Since relatively low concentration levels may influence a
decision for an expensive cleanup, the prevention of cross
contamination and proper testing procedures is a
necessity. Also, proper documentation is necessary for
legally defensible data.

EPA has established documentation requirements for

investigations. This chapter discusses the various
documents needed by EPA under the Superfund program
with an emphasis on the Sampling and Analysis Plan
(SAP). Other documents such as the Health and Safety
Plan (HASP), Spill Prevention Plan, and Community
Relation Plan are often pertinent to the field operation.

The SAP will assist in preparing the required documents

necessary before actual site work begins. Specific
requirements for individual programs vary greatly, and

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common sense and regulatory concurrence dictate the

level of detail needed. The EPA report Guidance for
Conducting Remedial Investigations and Feasibility
Studies Under CERCLA, Interim Final, October 1988
(EPA/540/G-89/004) provides additional details regarding
EPA-required documentation.

Work Plan (WP)

The WP includes a review of the existing data

(background and study rationale), documents the
decisions to be made during the evaluation process, and
presents anticipated future tasks. The WP also
designates responsibilities and sets the project schedule
and cost. The primary use of the WP is to provide an
agreed procedure to accomplish the work. The WP also
provides other interested agencies (such as local
government agencies) the opportunity to review proposed
work. The WP is placed in the Administrative Record.

The WP may include an analysis and summary of the site

background and physical setting, an analysis and
summary of previous studies and response actions, a
presentation of the conceptual site model (including the
nature and extent of contamination), a preliminary
assessment of human health and environmental impacts,
additional data needs to conduct a baseline risk
assessment, the preliminary identification of general
response actions and alternatives, and the data needs for
the evaluation of alternatives.

Sampling and Analysis Plan (SAP)

The SAP provides the "nuts and bolts" of the procedures

to be used at a site and must be site specific. The SAP
should consist of three parts:

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(1) A Field Sampling Plan (FSP) that provides

guidance for all field work by defining in detail the
sampling and data-gathering methods to be used on a
project.

(2) An Analysis Plan (AP) that describes analysis of

the collected data, such as the contaminant chemical
data, the groundwater quality, and the geologic
setting.

(3) A Quality Assurance Project Plan (QAPP) that

describes the quality assurance and quality control
protocols necessary to achieve Data Qaulity Objectives
(DQOs). Data Quality Objectives are qualitative and
quantitative statements that clarify the study
objective, define the type of data to collect, determine
the appropriate collection conditions, and specify
tolerable decision error limits on the quality and
quantity of data needed to support a decision.

The level of detail contained within the SAP varies.

Depending on the WP, the testing, analysis, and quality
control may be delegated to a differing lead agency or
contractor. Whether the SAP contains individual FSP,
AP, and/or QAPP, the SAP indicates the field personnel
roles and responsibilities, the acquired data goals, the
analytical methods, and how these methods meet the
DQOs. Guidance for the selection and definition of field
methods, sampling procedures, and custody can be
obtained from the EPA report Compendium of Superfund
Field Operations Methods, December 1987
(EPA/540/P-87/001 or National Technical Information
Service [NTIS] publication PB88-181557). This report is
a compilation of demonstrated field techniques that have
been used during remedial response activities at
hazardous waste sites.

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The FSP specifies the actual data collection activities to

be performed. The AP provides the details if changes in
sampling methods or number of samples need to be made.
If the AP is a separate document, the FSP should spell
out in detail exactly how and why samples will be
collected in the field.

Included with the SAP (sometimes as an appendix to the

FSP) are the standard operating procedures (SOPs) to be
used during the investigations. The SOPs describe, in
item-by-item detail, the exact steps to be followed for each
sampling procedure. Included in the SOPs are calibration
and maintenance requirements for equipment to be used.
Manufacturer's recommendations and usage manuals can
serve as part of the individual SOPs. Further details
regarding standardized tasks are given in the EPA
Quality Assurance Technical Information Bulletin
Creating SOP Documents.

The QAPP is a companion document typically written

when the FSP is final. The QAPP ensures that data and
the subsequent analyses are of sufficient quantity and
quality to accurately represent the conditions at the site.
The QAPP often describes policy, organization, and
functional activities not addressed within the work plan.

The following is a suggested SAP format.

Example Sampling and Analysis Plan

FSP
1. Site Background
2. Sampling Objectives
3. Sample Location and Frequency
4. Sample Designation
5. Sampling Equipment and Procedures
6. Sample Handling and Analysis

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AP
1. Objective(s) of the Data Collection
2. Analytical Methods and Software
3. Parameters Available and Required
4. Analytical Assumptions (Boundaries, Estimated
Data)
5. Data Management and Manipulation
6. Evaluation of Accuracy (Model Calibration
and/or Sensitivity Analysis)

QAPP
1. Project Organization and Responsibilities
2. QA Objectives for Measurement
3. Sample Custody
4. Calibration Procedures
5. Data Reduction, Validation, and Reporting
6. Internal Quality Control
7. Performance and System Audits
8. Preventative Maintenance
9. Data Assessment Procedures
10. Corrective Actions
11. Quality Assurance Reports

Health and Safety Plan (HASP)

Each field activity will vary as to amount of planning,

special training, supervision, and protective equipment
needed. The HASP, prepared to support the field effort,
must conform to the Reclamation “Safety and Health
Standards.” The site-specific HASP should be prepared
concurrently with the SAP to identify potential problems
early in the planning stage, such as availability of trained
personnel and equipment. The HASP preparer should
review site historical information along with proposed
activities to identify potentially hazardous operations or
exposures and to require appropriate protective
measures. Appendix B of the Occupational Safety and

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Health Guidance Manual for Hazardous Waste Site

Activities (National Institute for Occupational Safety and
Health/Occupational Safety and Health
Administration/U.S. Coast Guard/U.S. Environmental
Protection Agency, 1985) provides an example of a generic
format for an HASP. Commercial computer programs
that allow preparers to "fill in the blanks" to produce
rudimentary HASPs are also available.

A HASP should include, as appropriate, the following

elements:
1.
Name of site health and safety officer and names
of key personnel and alternates responsible for site
safety and health.
2. Listing of the potential contaminants at the site
and associated risk(s).
3. A health and safety risk analysis for existing site
conditions and for each site task and operation.
4. Employee training assignments.
5. A description of personal protective equipment to
be used by employees for each of the site tasks and
operations being conducted.
6. Medical surveillance requirements.
7. A description of the frequency and types of air
monitoring, personnel monitoring, and environ-
mental sampling techniques and instrumentation
to be used.
8. Site control measures.
9. Decontamination procedures.
10. Standard operating procedures for the site.

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11. A contingency plan that meets the requirements of

29 CFR 1910.120(l)(1) and (l)(2).
12. Entry procedures for confined spaces.
13. Local emergency numbers, notification procedures,
and a clear map (and written instructions) showing
the route to the nearest medical facility capable of
handling emergencies arising from a hazardous
waste site.

Spill Prevention Plan (SPP)

All samples, equipment, cuttings, and other materials

that have been exposed to potential contaminants must
be decontaminated and/or tested and treated according to
Applicable or Relevant and Appropriate Requirement
(ARAR). Contingencies must be made for accidentally
releasing and spreading contaminants into the
environment during field activities at hazardous waste
sites. Contaminants may originate from substances
brought onto the site for specialized testing (e.g.,
standards for chemical testing), from accumulations of
"free" contaminants, or from contaminated natural water
which is released during sampling or investigations.
Sufficient equipment (e.g., drums, absorbents, etc.) must
be onsite to effectively control spills. In addition, key
personnel should be identified for the control of spills.
Paramount to such planning are spill prevention
measures. Spill prevention plans may be incorporated
into appropriate sections of a SAP or HASP, if desired.

Contaminant Characteristics and Migration

A primary difference between conventional engineering

geology investigations and hazardous waste inves-
tigations is that drilling methods may impact the
contaminant sampling results and increase migration

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paths. Lubricants, fuels, and equipment may mask

specific chemical testing or react with the contaminant of
concern (COC). All samples, waste discharges, and
equipment used in the investigations require evaluation
in relation to the potential contaminant(s). The following
unique site factors are also important.

Contaminant Properties

Some contaminants are inherently mobile, for example,

volatile organic compounds (VOCs). When released,
VOCs can migrate rapidly through air, soil, and
groundwater. Other contaminants, such as heavy metal
solids, are less mobile. Heavy metals tend to accumulate
on the surface of the ground. Although heavy metals may
not readily migrate into and through the subsurface,
heavy metals may still migrate through the air as
airborne particles. Understanding the behavior of COCs
is very important because behavior will significantly
influence the ultimate design of the exploration program.
For example, investigations to find gasoline, a light
nonaqueous phase liquid (LNAPL), should concentrate on
the water table surface. Dense, nonaqueous phase liquid
(DNAPL) investigations should concentrate towards the
bottom of the aquifer(s) or water table. Note that some
contaminants react with investigation materials; e.g.,
TCE in high concentrations reacts with polyvinyl chloride
(PVC) pipe.

When possible, the typical contaminant investigation will

estimate the source type and location. The source type
may be barrels, storage tanks, pipelines, injection wells,
landfills, or holding ponds. In investigations that involve
groundwater contamination, the investigation must
address collecting samples of material that may be
moving or have moved off site.

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Identifying the contaminant and its behavior within the

hydrogeologic environment must be kept foremost in
mind while developing the program. Hydrochemical
parameters such as density, diffusivity, solubility, soil
sorption coefficient, volatilization (vapor pressure), and
viscosity may impact the specific contaminant movement.
Biological activities or meteoric waters may impact
various COCs in the subsurface. Some contaminants
degrade over time and under some environmental
conditions. In some instances, the degradation product
(TCE to vinyl chloride) is worse than the original product.

A general introductory geological hazardous waste inves-

tigation reference is the Standard Handbook for Solid
and Hazardous Waste Facility Assessments, by Sara,
1994. A general introductory reference for environ-
mental chemistry is Fundamentals of Environmental
Chemistry, by Manahan, 1993. A reference on DNAPL
materials is DNAPL - Site Evaluation by Cohen and
Mercer, 1993. A reference for groundwater chemical and
physical properties is Groundwater Chemicals - Desk
Reference, by Montgomery, 1996. Toxicological Profile
Series published by the U.S. Department of Health and
Human Resources describes physical, chemical, and
biological processes which effect contaminant fate and
transport.

Geologic Factors

The migration of contaminants is dependent on the

subsurface materials and water. The arrangement of the
geologic materials impacts the direction and flow rate of
the contaminants and groundwater. Geologic factors such
as stratigraphy, structure, and lithology control the
occurrence and movement of water.

Various geologic factors to consider include: depth of soil,

depth to bedrock, depth to the water table, seasonal

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variations in water table, water quality characteristics of

site aquifers, mineralogic compositions of soil and rock,
gradation, consolidation, and fracturing. Contaminant
characteristics, such as property differences between solid
or liquid materials, differences in liquid viscosity, or
differences in liquid density relative to water, may
influence how the contaminants interact with geologic
factors and how the contamination plumes will behave.

Hydrologic Factors

Groundwater flow is a function of precipitation, runoff,

and infiltration (figure 12-1).

Groundwater flow occurs through two zones: the

unsaturated (vadose or aeration) zone and the saturated
zone. Each zone can be either soil or rock. Groundwater
movement is affected by the characteristics of the
material pore spaces (porosity) and the interconnectivity
of the pore spaces (permeability). Water movement
occurs under a hydraulic gradient.

Other terms often used in groundwater are transmissivity

and storativity. Both terms are bulk terms used to
describe the water over the entire hydrologic unit. Trans-
missivity is directly related to permeability. Storativity
is a dimensionless value often incorrectly equated with
specific yield. For a more detailed description, see the
Bureau of Reclamation Water Resource Technical Publi-
cation, Ground Water Manual, second edition, 1995 or
Groundwater, by Freeze and Cherry, 1979.

An unconfined aquifer, often referred to as a "water table"

aquifer, has no overlying confining layer. Water infiltrat-
ing into the ground percolates downward through air-
filled interstices of the vadose zone to the saturated zone.
The water table, or surface of the saturated groundwater

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379

Figure 12-1.—Aquifer types.

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body, is in contact with the atmosphere through the open

pores of the material above and is in balance with
atmospheric pressure.

A confined, or artesian, aquifer has an overlying,

confining layer of lower permeability than the aquifer.
Water in an artesian aquifer is under pressure, and when
the confining layer is penetrated, the water will rise
above the bottom of the confining bed to an elevation
controlled by the aquifer pressure. If the confining layer
transmits some water into adjacent layers, the aquifer is
said to be a "leaky aquifer." A perched aquifer is created
by beds of clay or silt, unfractured rock, or other material
with relatively lower permeability impeding the
downward percolation of water. An unsaturated zone is
present between the bottom of the perching bed and the
regional aquifer. Such an aquifer may be permanent or
may be seasonal.

Aquifers are typically anisotropic; i.e., flow conditions

vary with direction. In granular materials, the particle
shapes, orientation, and the deposition process usually
result in vertical permeability being less than horizontal
permeability. The primary cause of anisotropy on a
microscopic scale is the orientation of platy minerals. In
some rock, the size, shape, orientation, and spacing of
discontinuities and other voids may result in anisotropy.
These factors should always be considered when modeling
contaminant migration from hazardous waste sites.

After the natural flow conditions at a site are char-

acterized, the presence of artificial conditions which may
modify the flow direction or velocity of groundwater is
determined. Such items as surface water impoundments
and drainages may influence overall groundwater flow
models. Also, if existing water wells are present in the
area, pumping may be drawing the contaminants toward
the wells. All possible influences affecting the

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groundwater flow must be identified to model

contaminant plume migration rates and paths.

Classification and Handling of Materials

Classification of soils for engineering properties is

described in chapter 3. “ Instructions for Logging Soils
and Surficial Deposits” (chapter 11) describes logging
procedures, but there are two significant differences for
hazardous waste investigations.

(1) Logging of the soil is often limited to visual

inspection of cuttings. The sampling protocol may
prohibit the handling or poking of samples. Often
the samples are sealed for chemical testing, and time
for classification is restricted to the period when the
sample is being packaged. Size of samples is kept to
a minimum to reduce the amount of investigation-
derived waste.

(2) All material recovered or generated during an

investigation (samples, cuttings, water, etc.) should
be considered hazardous waste unless proven other-
wise. Material removed should not be considered
“normal” waste unless tested and permitted.

The RCRA “statutory” definition for hazardous waste is

broad and qualitative and does not have clear bounds.
Hazardous waste is defined as material meeting the
regulatory definition contained in 40 CFR 261.3.
However, the definitions of solid and hazardous waste
contained in 40 CFR 261 are relevant only in identifying
the waste. Material may still be considered solid or
hazardous waste for purposes of other sections of RCRA.
Some waste defined under the present regulatory statutes
could become hazardous waste in the future.

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From the RCRA document, the definition of hazardous

waste is any

. . .solid waste or combination of solid wastes

which because of its quantity, concentration, or
physical, chemical, or infectious characteristics
may: (A) cause, or significantly contribute to, an
increase in mortality or an increase in serious
irreversible, or incapacitating reversible, illness;
or (B) pose a substantial present or potential
hazard to humans or the environment when
improperly treated, stored, transported, or
disposed of, or otherwise managed.

The level of contamination acceptable within the subsur-

face is based on a complex formula that involves the risk
of exposure; toxicity, mobility, and volume of contami-
nants; and the cost of remediation. Soil and rock removed
from a site cannot be returned to a site after the
investigation has been completed.

Investigation waste water must be tested and handled

under a different set of rules. If the water is mixed with
cuttings, the material is considered a combination of solid
wastes. If the water is discharged on a site, the water
typically must meet drinking water standards. EPA cur-
rently requires that sole source aquifers have special
project review criteria for Federal actions possibly
affecting designated aquifers. Water withdrawn for
public drinking water supplies currently falls under the
Safe Drinking Water Act (SDWA) (Public Law 93-523)
regulations, as amended and reauthorized (1974). (See
40 CFR 141 G for applicable water supply systems. See
40 CFR 143 for applicable water supply systems.) Note
that the number of regulated constituents and their
respective maximum contaminant levels (MCLs) are
frequently updated.

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Identifying and classifying hazardous waste is described

in Hazardous Waste, by Wagner, 1990. Procedures for
site evaluation are contained in EPA Guidance for
Conducting Remedial Investigation and Feasibility
Studies Under CERCLA, 1988.

Field Sampling Protocol

One of the most difficult parts of any investigation is

collecting representative samples. A sampling strategy
must be efficiently and logically planned which delineates
site location, number of samples collected, types of
samples collected, testing methods to be used, and the
duration and frequency of sampling. The difficulties of
drilling in the “right” location and the problems
associated with collecting representative samples is
similar to traditional investigations. However, for
hazardous waste investigation, the COC must be con-
sidered in both time and space. Statistical considera-
tions should be part of the sampling program. The follow-
ing are references for sampling statistical considerations:

• Harvey, R.P. “Statistical Aspects of Air Sampling

Strategies.” In: Detection and Measurement of
Hazardous Gases; edited by C.F. Cullis and
J.G. Firth. Heineman Educational Books, London,
1981.

• Mason, B.J. Protocol for Soil Sampling: Tech-

niques and Strategies. EPA Environmental
Systems Laboratory, Contract No. CR808529-01-2.
March 30, 1982. EPA-600/54-83-0020.

• Smith, R., and G.V. James. The Sampling of Bulk

Materials. The Royal Society of Chemistry,
London. 1981.

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• Environmental Protection Agency. Handbook for

Sampling and Sample Preservation of Water and
Wastewater. September 1982. EPA 600/4-82-029.

Sampling Strategies

Investigators must determine the correct number and

types of samples to be collected, the proper chemical
testing methods (analytical procedures), and the proper
sampling equipment before field activities begin. Sample
containers, preservatives, sample quantities, and proper
holding times are also dictated by the chosen methods.

Table 12-1 is a list of recommended sampling containers

and holding times for various classes of contaminants in
soils.

Several sampling strategies are available, each with

advantages and disadvantages. Random sampling uses
the theory of random chance probabilities to choose repre-
sentative sample locations. This is appropriate when
little information exists concerning the material, loca-
tions, etc. Random sampling is most effective when the
number of sampling locations is large enough to lend
statistical validity to the random selection.

Systematic random sampling involves the collection of

randomly selected samples at predetermined, regular
intervals (i.e., a grid). The method is a common sampling
scheme, but care must be exercised to avoid over-
sampling of one material or population type over others.

Stratified sampling is useful if data are available from

previous investigations and/or the investigator has
experience with similar situations. This scheme reduces
the number of samples needed to attain a specified
precision. Stratified sampling involves the division of the

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Table 12-1.—EPA recommended sampling

containers, preservation requirements, and holding
times for soil samples

Container1 Holding
Contaminant Preservation2 time3
Acidity P, G 14 days
Alkalinity P, G 14 days
Ammonia P, G 28 days
Sulfate P, G 28 days
Sulfide P, G 28 days
Sulfite P, G 48 hours
Nitrate P, G 48 hours
Nitrate-Nitrite P, G 28 days
Nitrite P, G 48 hours
Oil and grease G 28 days
Organic carbon P, G 28 days
Metals
Chromium VI P, G 48 hours
Mercury P, G 28 days
Other metals P, G 6 months
Cyanide P, G 28 days
Organic compounds
Extractables
Including: Phthalates, nitro- G, Teflon®- 7 days until
samines, organic pesticides, lined cap extraction
PCBs, nitroaromatics, iso-
phorone, polynuclear aroma- 30 days
tics hydrocarbons, haloethers, after
chlorinated hydrocarbons, and extraction
tetrachlorodibenzo-p-dioxin
(TCDD)

Footnotes at end of table.

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Table 12-1.—EPA recommended sampling

containers, preservation requirements, and
holding times for soil samples (continued)

Container1 Holding
Contaminant Preservation2 time3
Purgeables
Halocarbons and G, Teflon®-lined 14 days
aromatics septum
Acrolein and acrylonitrate G, Teflon®-lined 3 days
septum
Orthophosphate P, G 48 hours
Pesticides G, Teflon®-lined 7 days until
cap extraction

30 days after
extraction
Phenols G 28 days
Phosphorus G 48 hours
Phosphorus, total P, G 28 days
Chlorinated organic G, Teflon®-lined 7 days
compounds cap
1
P = polyethylene, G = glass.
2
All samples are cooled to 4 EC. Preservation is performed
immediately upon collection. For composites, each aliquot preserved
at collection. When impossible to preserve each aliquot, samples may
be preserved by maintaining 4 EC until compositing and sample
splitting is completed.
3
Samples are analyzed as soon as possible. Times listed are
maximum holding if analysis is to be valid.

Source: Description and Sampling of Contaminated Soils,

EPA/625/11-91/002 (1991).

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sample population into groups based on sample char-

acteristics. The procedure involves handling each group
or division separately with a simple random sampling
scheme.

Judgement sampling introduces a certain amount of

judgment into the sampling approach and should be
avoided if a true random sample is desired. Judgment
sampling allows investigator bias to influence decisions,
which can lead to poor quality data or improper conclu-
sions. If the local geology is fairly well understood,
judgement sampling may provide the most efficient and
cost-effective sampling scheme; however, regulatory
concurrence, rationale, and proper documentation will be
necessary.

Hybrid sampling is a combination of the types previously

described. For example, an initial investigation of drums
might be based on preliminary information concerning
contents (judgement, stratified) and then random sam-
pling of the drums within specific population groups
(random). Hybrid schemes are usually the method of
choice for sampling a diverse population, reducing the
variance, and improving precision within each subgroup.

After the appropriate sampling scheme has been chosen,

the specific type of samples necessary for characterization
must be identified. The unique characteristics of the site
COCs will play an important role in determining which
media will be sampled. Some sampling devices are
described in this manual or the Earth Manual, parts 1
and 2, USBR, 1990 and 1999. A summary of sampling
devices is shown in table 12-2.

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Table 12-2.—Summary of soil sampling devices

Sampling
device Applications Limitations
Hand-held samplers
Spoons and Surface soil samples Limited to relatively
scoops or the sides of pits or shallow depths;
trenches disturbed samples
Shovels and A wide variety of soil Limited to relatively
picks conditions shallow depths
Augers1
Screw auger Cohesive, soft, or hard Will not retain dry,
soils or residue cohesionless, or
granular material
Standard General soil or May not retain dry,
bucket auger residue cohesionless, or
granular material
Sand bucket Bit designed to retain Difficult to advance
auger dry, cohesionless, or boring in cohesive
granular material soils
(silt, sand, and gravel)
Mud bucket Bit and bucket de- Will not retain dry,
auger signed for wet silt and cohesionless, or
clay soil or residue granular material

Dutch auger Designed specifically

for wet, fibrous, or
rooted soils (marshes)
1
Suitable for soils with limited coarse fragments; only the
stoney soil auger will work well in very gravelly soil.

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Table 12-2.—Summary of soil sampling devices (continued)

Sampling
device Applications Limitations
1
Augers
In situ soil Collection of soil sam- Similar to standard
recovery ples in reusable liners; bucket auger
auger closed top reduces con-
tamination from caving
sidewalls
Eijkelcamp Stoney soils and
stoney soil asphalt
auger
Planer auger Clean out and flatten
the bottom of predrilled
holes
Tube samplers2
Soil probe Cohesive, soft soils or Sampling depth
residue; representative generally limited to
samples in soft to less than 1 meter
medium cohesive soils
and silts
Thin-walled Cohesive, soft soils or Similar to
tubes residue; special tips for Veihmeyer tube
wet or dry soils
available
Soil recovery Similar to thin-walled Similar to
probe tube; cores are Veihmeyer tube
collected in reusable
liners, minimizing
contact with the air
1
Suitable for soils with limited coarse fragments; only the stoney
soil auger will work well in very gravelly soil.
2
Not suitable for soils with coarse fragments.

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Table 12-2.—Summary of soil sampling devices (continued)

Sampling
device Applications Limitations
1
Tube samplers (continued)
Veihmeyer Cohesive soils or Difficult to drive into
tube residue to depth of dense or hard mate-
10 feet (3 meters [m]) rial; will not retain
dry, cohesionless, or
granular material;
may be difficult to
pull from ground
Peat sampler Wet, fibrous, organic
soils
Power-driven samplers
Split spoon Disturbed samples Ineffective in cohe-
sampler from cohesive soils sionless sands; not
suitable for collection
of samples for
laboratory tests
requiring
undisturbed soil
Thin-walled samplers
Fixed piston Undisturbed samples Ineffective in
sampler in cohesive soils, silt, cohesionless sands
and sand above or
below water table
Hydraulic Similar to fixed-piston Not possible to limit
piston sampler the length of push or
sampler to determine amount
(Osterberg) of partial sampler
penetration during
push
1
Not suitable for soils with coarse fragments.

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 HAZARDOUS WASTE

Table 12-2.—Summary of soil sampling devices (continued)

Sampling
device Applications Limitations
Thin-walled samplers (continued)
Free piston Similar to stationary Not suitable for
sampler piston sampler cohesionless soils
Open drive Similar to stationary Not suitable for
sampler piston sampler cohesionless soils
Pitcher Undisturbed samples Frequently
sampler in hard, brittle, cohe- ineffective in
sive soils and ce- cohesionless soils
mented sands; repre-
sentative samples in
soft to medium cohe-
sive soils, silts, and
some sands; variable
success with cohe-
sionless soils
Denison Undisturbed samples Not suitable for
sampler in stiff to hard cohe- undisturbed
sive soils, cemented sampling of
sands, and soft rocks; cohesionless soils or
variable success with soft cohesive soils
cohesionless materials
Vicksburg Similar to Denison
sampler sampler except takes
wider diameter
samples

In addition, the following references may be consulted for

sample collection methods:
• Environmental Protection Agency. Characterization
of Hazardous Waste Sites - A Methods Manual,
Volume I - Site Investigations. April 1985. EPA
600/4-84-075.

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 FIELD MANUAL

• Environmental Protection Agency. Characterization

of Hazardous Waste Sites - A Methods Manual:
Volume II. Available Sampling Methods. September
1983. EPA 600/4-83-040, PB84-126929.

• Environmental Protection Agency. A Compendium of

Superfund Field Operation Methods. December 1987.
EPA 540/P-87-001, PB88-181557.

Samples can be either grab or composite samples. Grab

samples are collected at a discrete point, representing one
location and/or time interval. Composite samples are
collected from several sources which are then accumu-
lated to represent a broader area of interest. The
requirements for testing will often dictate which sampling
method is used. For example, composite samples of soil
cannot be used for volatile compounds because portions of
the contaminants may easily volatilize during collection.

Many soil samples are collected as grab samples. Soil

samples should be collected from areas where dumping,
spills, or leaks are apparent. Soil samples should be
collected from areas upstream and downstream from
suspected contaminant entry and in areas where
sediment deposition is significant. Samples can be
collected readily from the first 18 inches (450 mm)
(depending upon the soil type) by using relatively simple
tools, such as spades, scoops, and dredge scoops. If scoops
are used for collecting surface soil samples, purchase
enough scoops to use a new scoop for each sample rather
than decontaminating scoops between samples. Not only
is time saved, but cross contamination is kept to a
minimum. The COC must also be considered. If
sampling for heavy metals, metal scoops should not be
used, or if sampling for semivolatiles, plastic scoops
should be avoided. Samples from greater depths usually
require more elaborate methods or equipment, such as
test pits, hand augers, thin-wall tube samplers, hand or

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power corers, bucket augers, cutting or wash samples,

direct-push tools, etc. The nature of the geologic material
to be sampled will influence significantly the methods to
use, but every effort should be made to reduce the amount
of investigation-derived waste generated from the
sampling method. Direct-push sampling (such as the
Geoprobe®) is preferable in that drill cuttings and drilling
fluids are not generated.

A useful field pocket guide is available from EPA:

Description and Sampling of Contaminated Soils,
EPA/625/12-9/002, November 1991. This guide addresses
soil characterization, description, sampling, and sample
handling. Within this guide are general protocols for soil
sample handling and preparation. The following are
procedures from the guide:

Soil Sample Collection Procedures for Volatiles.—

1. Tube samples are preferred when collecting for

volatiles. Augers should be used only if soil condi-
tions make collection of undisturbed cores
impossible. Soil recovery probes and augers with
dedicated or reusable liners will minimize contact
of the sample with the atmosphere.

2. Place the first adequate grab sample, maintaining

and handling the sample in as undisturbed a state
as possible, in 40-milliliter (mL) septum vials or in
a 1-liter (L) glass wide mouth bottle with a
Teflon®-lined cap. Do not mix or sieve soil
samples.

3. Ensure the 40-mL containers are filled to the top to

minimize volatile loss. Secure the cap tightly, but
do not overtighten.

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 FIELD MANUAL

4. Examine the hole from which the sample was

taken with an organic vapor instrument after each
sample increment. Record instrument readings.

5. Label and tag sample containers, and record

appropriate data on soil sample data sheets (depth,
location, etc.).

6. Place glass sample containers in sealable plastic

bags, if required, and place containers in iced
shipping container. Samples should be cooled to
4 degrees Centigrade (EC) as soon as possible.

7. Complete chain of custody forms and ship as soon

as possible to minimize sample holding time.
Scheduled arrival time at the analytical laboratory
should give as much holding time as possible for
scheduling of sample analyses.

8. Follow required decontamination and disposal

procedures.

Soil Sample Collection and Mixing Procedures for

Semivolatiles and Metals.—

1. Collect samples.

2. If required, composite the grab samples or use

discrete grab samples.

3. If possible, screen the soils in the field through a

precleaned O-mesh (No. 10, 2-millimeter [mm])
stainless steel screen for semivolatiles, or Teflon®-
lined screen for metals.

4. Mix the sample in a stainless steel, aluminum (not

suitable when testing for aluminum), or glass
mixing container using appropriate tool (stainless
steel spoon, trowel, or pestle).

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 HAZARDOUS WASTE

5. After thorough mixing, place the sample in the

middle of a relatively inexpensive 1-meter (m)
square piece of suitable plastic, canvas, or rubber
sheeting.

6. Roll the sample backward and forward on the

sheet while alternately lifting and releasing
opposite sides or corners of the sheet.

7. After thorough mixing, spread the soil out evenly

on the sheet with a stainless steel spoon, trowel,
spatula, or large knife.

8. Take sample container and check that a Teflon®

liner is present in the cap, if required.

9. Divide the sample into quarters, and take samples

from each quarter in a consecutive manner until
appropriate sampling volume is collected for each
required container. Separate sample containers
would be required for semivolatiles, metals,
duplicate samples, triplicate samples (split), and
spiked samples.

10. Secure the cap tightly. The chemical preservation

of solids is generally not recommended.

11. Label and tag sample containers, and record

appropriate data on soil sample data sheets (depth,
location, etc.).

12. Place glass sample containers in sealable plastic

bags, if required, and place containers in iced
shipping container. Samples should be cooled to
4 EC as soon as possible.

13. Complete chain of custody forms and ship as soon

as possible to minimize sample holding time.
Scheduled arrival time at the analytical laboratory

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 FIELD MANUAL

should give as much holding time as possible for

scheduling of sample analyses.

14. Follow required decontamination and disposal

procedures.

Water Quality Sample Collection Methods

Surface Water Collection.—Surface water on or

adjacent to a suspected hazardous waste site can yield
significant information with minimal sampling effort.
Surface water can reveal the presence of contamination
from several pathway mechanisms. If only a knowledge
of the presence or absence of contamination in the water
is needed, the collection of grab samples will usually
suffice. If the water source is a stream, samples also
should be collected upstream and downstream from the
area of concern. Additional monitoring of surface water
is required of seeps, spills, surface leachates, etc. If the
site has National Pollutant Discharge Elimination
System (NPDES) outfalls, the discharges should be
sampled.

Water quality samples are often the most important

material collected at a site. Determining the appropriate
number of samples and appropriate test method is critical
to a successful program. A good guidance document to
develop a water quality sampling program and provide
the reasoning for collecting appropriate water samples is
EPA’s Handbook, Ground Water, volumes I and II,
EPA/625/6-90/016. There are several factors to consider
in the selection of appropriate sampling devices. Time
and money are obvious factors; however, the data use,
formation permeability, water depth, and contamination
type are considerations. Water monitoring goals and
objectives should be addressed, such as:

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 HAZARDOUS WASTE

• Is the investigation to determine source(s)?

• Are the investigations included for a time critical
removal action?
• Have the potential contaminants been identified?
• Will there be a follow up risk assessment and/or
remediation?
• Are there potential responsible parties (PRPs)
involved?

Water samples can be routinely analyzed for current EPA

listed priority pollutants. Alkalinity, acidity, total
organic halogens, and chemical oxygen demand are often
indicators of contamination. Routine tests can be used as
screening techniques before implementing more costly
priority pollutant analyses. Bioassessment samples, if
needed, are described in Rapid Bioassessment Protocols
for Use in Streams and Rivers, EPA/444/4-89-001. If
technical impracticability (Guidance for Evaluating the
Technical Impracticability, EPA Directive 9234.2-25, or
natural attenuation are potential remediation options,
additional water quality parameters may need testing
consideration.

Groundwater Collection.—Groundwater
contamination is usually difficult and costly to assess,
control, and remove. Monitoring wells sample a small
part of an aquifer, depending on screen size, length,
placement depth, pumping rates, and other factors. The
use of wells and piezometers can introduce additional
problems due to material contamination, inadequate
construction, and uncertainties of the water zone
sampled. Guarding against cross contamination of
multiple aquifers is important. Proper well construction
requires significant skill. General guidelines for design
and construction of monitoring wells can be found in
American Society for Testing Materials (ASTM)

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 FIELD MANUAL

D5092-90, and guidelines for sampling can be found in

RCRA Groundwater Monitoring Draft Technical
Guidance, EPA/530-R-93-001. For general details on
groundwater quality monitoring well construction, see
figure 12-2. The location of the screen and designing and
development of the screen and sand pack is extremely
important in hazardous waste wells. Meeting the
turbidity requirement of less than five nephelometric
turbidity units (NTUs) is difficult to achieve in the best
circumstances. Drilling exploration and monitoring wells
in sequence from least to most contaminated areas is
good practice because this minimizes the possibility of
introducing contaminants into cleaner aquifers or areas.

Although the Compendium of ERT Groundwater

Sampling Procedures, EPA/540/P-91/007, provides
standard operating procedures for emergency response
teams, the recommended water quality sampling
procedures for groundwater should be in accordance with
EPA’s Low-Flow (Minimal Drawdown) Ground-Water
Sampling Procedures, EPA/540/S-95/504. The Minimal
Drawdown (MD) method requires using a submersible
pump placed within a riser and not operated until the
well has stabilized. The use of bailers and hand pumps,
including automated hand pump systems for water
quality sampling, is discouraged under the MD method.

Limiting water column disturbance is a primary reason

for installing a dedicated submersible pump. Lowering a
temporary sampling device into the water column creates
a mini-slug test. The surge of water may induce sedi-
ments into the monitoring well. As a result, the water
may not meet the five NTU limit that is part of the
requirement for water quality monitoring wells.
Sediments can significantly impact testing. If sediment

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 HAZARDOUS WASTE

Figure 12-2.—Typical monitoring well

construction for water quality sampling.

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 FIELD MANUAL

content is great, additional tests, such as comparing total

versus dissolved solids, should be considered.

Some sampling devices may induce volatilization.

Peristaltic pumps, bailers, or hand pumps in low-flow
conditions can impact the test results for semi-volatile
and volatile compounds. Peristaltic pumps may induce
volatilization if the samples are lifted from depths greater
than about 25 feet.

The MD method is the preferred sampling collection

method because the method uses a low pumping rate (as
low as 0.1 liter per minute) and attempts to limit
drawdown to less than 0.3 foot. If the extraction rate
exceeds the ability of the formation to yield water for low
permeability wells, turbulent conditions can be induced
within the borehole. Water may trickle and fall down the
casing. This may potentially increase air exposure and
can entrain air in the water.

Although preferred water quality sampling uses the

MD method, other methods may be acceptable to EPA or
other regulatory agencies. Devices such as bailers or
peristaltic and hand pumps are routinely used at some
sites. However, if these devices are used and surge the
well, water sampling protocols often require that the well
be purged of at least three well volumes of water prior to
collecting a sample.

Whatever sample device is selected, stabilization of

typical water quality parameters, such as pH, redox
potential, conductivity, dissolved oxygen, and turbidity,
are usually required. Which water quality parameters
are specified may be dependent on the site conditions and
regulatory requirements. The water extraction devices
and procedures should be specified in the FSP and

400
 HAZARDOUS WASTE

correlated to match the site conditions, contaminants,

and the regulatory agency requirements.

Vadose Zone.—In addition to sampling aquifers at

hazardous waste sites, significant information can be
obtained by vadose zone sampling. Leachates from COCs
migrate through the vadose zone toward the water table.
Samples collected from this zone can indicate the types of
contaminants present and can aid in assessing the
potential threat to the aquifer below. The various types
of vadose zone monitors can be used to collect water
samples or interstitial pore space vapors for chemical
analyses and to determine directional flow of COCs. The
main advantage is that such sampling is relatively
inexpensive, simple to do, and can begin supplying
information before aquifer monitoring is started. The
types of vadose zone monitors, their applications, and
their use in satisfying the requirements of RCRA are
discussed in Vadose Zone Monitoring at Hazardous Waste
Sites, EMSL-LV KT-82-018R, April 1983.

Geophysical Methods

Geophysical methods can be used effectively at hazardous

waste sites to assist in defining the subsurface character
of the site, to assist in the proper placement of monitoring
wells, to identify buried containers and debris, and to
decrease the safety risks associated with drilling into
unknown buried materials. A good overview of the
subject of geophysical methods for surveying hazardous
waste sites is: Geophysical Techniques for Sensing Buried
Wastes and Waste Migration, prepared for EPA by
Technos, Inc., available from the National Water Well
Association.

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 FIELD MANUAL

Miscellaneous Methods

Ambient concentrations of volatile and semivolatile

organics, trace metals, and particulate matter in the air
can provide important data on the atmospheric migration
path and the populations at risk and can be used for
source evaluations and personnel monitoring. Portable
monitoring devices such as organic vapor analyzers, stain
detector tubes, or other monitors can detect the presence
of various atmospheric hazards. Other monitors
commonly used at hazardous waste sites are explosi-
meters, oxygen indicators, and personal sampling pumps.

Other specialized sampling techniques may be necessary

at hazardous waste sites to sample media normally not
found in the geologic environment. Wipe samples may be
used to document the presence of toxic materials and to
determine that site or equipment decontamination has
been adequate. Wipe sampling consists of rubbing a
moistened filter paper, such as Whatman 541 filter paper,
over a measured area of 15 in2 (100 cm2) to 10 ft2 (1 m2).
The paper is then sent to a laboratory for analysis.

Sample Analysis

Onsite laboratories and field analytical equipment, such

as portable gas chromatographs (GCs) and immunoassay
kits, can be very beneficial for rapid analyses. Rapid-
analysis equipment, such as GCs, immunoassay, and
colorometric kits, are a cost-effective alternative for
providing qualitative and semi-quantitative chemical
data and for screening large numbers of samples prior to
submittals for laboratory testing. Another beneficial use
of field screening techniques is to provide general
contaminant level data for samples to be tested in the
laboratory. If a sample has a very high contaminant

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 HAZARDOUS WASTE

concentration, the sample may have to be diluted before

being analyzed to protect the laboratory instruments from
costly contaminant saturation problems.

There are many standardized testing procedures and

methods for hazardous waste evaluation. Table 12-3 lists
some common method series. Each series contains
numerous individual methods. There are over 25 series-
500 (determination of organic compounds in drinking
water) methods. Method 502.1 is for halogenated volatile
organics (purgeable halocarbons) by GC (48 compounds);
Method 502.2 is for nonhalogenated volatile organics by
GC (6 compounds); Method 503.1 is for aromatic and
unsaturated volatile organics (purgeable aromatics) by
GC (28 compounds); Method 507 is for nitrogen and
phosphorus containing pesticides by GC (66 substances).

The following references discuss some of the common

methods:

• Methods for the Determination of Organic

Compounds in Drinking Water. EPA-600/4-
88/039, December 1988 (500 Series).

• Guidelines Establishing Test Procedures for the

Analysis of Pollutants Under the Clean Water Act.
40 CFR Part 136, October 26, 1984 (600 Series,
for effluent - wastewater discharged to a sewer or
body of water).

• Test Methods for Evaluating Solid Waste.

SW-846, 2nd Edition, Revised, 1985 (8000 Series
for groundwater, soil, liquid, and solid wastes).

• Methods for Chemical Analysis of Water and

Wastes. EPA-600/4-79-020, March 1983.

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 FIELD MANUAL

Table 12-3.—Common laboratory testing methods1

Method testing series Analytes

100 - EPA method Physical properties - water

200 - EPA method Metals - water
300 - EPA method Inorganic, non-metallics - water (i.e.,
alkalinity)
400 - EPA method Organics - water (i.e., chemical oxygen
demand, total recoverable petroleum
hydrocarbons [TRPH])
500 - EPA method Organic compounds in drinking water
600 - EPA method Organic compounds in effluent
900 - EPA method Biologic - water (i.e., coliform, fecal
streptococcal)
1000 - SW-846 method Ignitability, toxicity characteristic leaching
procedure (TCLP), extractions, cleanup,
headspace - solids
3000 - SW-846 method Acid digestion, extractions, cleanup,
headspace - solids
4010 - SW-846 method Screening for pentachlorophenol by
immunoassay - solids
5000 - SW-846 method Organic (purge and trap, gas
chromatograph/mass spectrometer
[GC/MS], sorbent cartridges)
6000 - SW-846 method Inductively coupled plasma (spectrometry)
7000 - SW-846 method Metals - solid waste
8000 - SW-846 method Organic compounds in solid waste
9000 - SW-846 method Inorganics, coliform, oil and grease
extractions - solids
1
This list is not inclusive. Significant overlap and exceptions are present.
Methods listed are basic guides to provide the investigator with the general
structure of the testing method scheme. Numerous individual methods exist
within each series.

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 HAZARDOUS WASTE

• Standard Methods for the Examination of Water

and Wastewater, 19th edition, Greenberg;
American Public Health Association, Washington,
DC, 1995.

Reference guides are also available from several sources,

such as the Trace Analysis Laboratory Reference Guides
from Trace Analysis Laboratory, Inc., 3423 Investment
Boulevard, No. 8, Hayward, California 94545, telephone
(415) 783-6960.

An important consideration in planning any field

investigation program is scheduling the anticipated
activities. Sufficient time must be allowed for the
peculiarities of hazardous waste work. Several factors
must be considered: (1) time for establishing work zones
and erecting physical barriers, (2) time for establishing
equipment, personnel, and vehicle decontamination
stations, (3) time needed to decontaminate equipment
and personnel, ( 4) loss of worker efficiency due to safety
monitoring, safety meetings, and the use of protective
clothing, (5) documentation requirements and sample-
handling procedures, and (6) inventory and procurement
of specialized sample containers, preservative pre-
paration, and reference standards, and equipment
calibrations.

Safety at Hazardous Waste Sites

A major factor during hazardous waste site investigations

is the safety of both the general public and the site
investigators. The following references may be of
assistance:

405
 FIELD MANUAL

• Interim Standard Operation Safety Guides.

Revised September 1982, U.S. EPA, Office of
Emergency and Remedial Response (OERR).

• Guidance Manual for Protection of Health and

Safety at Uncontrolled Hazardous Substances
Sites. EPA, Center for Environmental Research
Information (ORD) (in draft, January 1983).

• Reclamation Safety and Health Standards.

U.S. Department of the Interior, Bureau of
Reclamation, Denver, Colorado, 1993.

• Chemical Substance Hazard Assessment and

Protection Guide. OWENS/URIE Enterprises,
Inc., Henehan, Urie, & Farlern, Wheat Ridge,
Colorado, 1994.

Sample Quality Assurance and Quality Control

Sample QA procedures confirm the quality of the data by

documenting that integrity is present throughout the
sample history. Several sample types are used. Field
blanks are samples of a "pure" substance, either water,
solid, or air, which are collected in the field using the
same procedures as are used for actual environmental
samples. The purpose of the field blank is to ensure that
outside influences are not contaminating the true
samples (i.e., vehicular exhaust) during sampling. If
"hits" are discovered in the field blank, the question
arises whether contamination not associated with the site
is affecting the true samples.

Trip blanks are samples of a "pure" substance (analyte-

free deionized water which accompanies samples with
volatile contaminants) prepared in a laboratory or other

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 HAZARDOUS WASTE

controlled area and placed in a shipping container with

environmental samples. The purpose of the trip blank is
to ensure that samples were not cross contaminated
during shipment and storage. "Hits" in a trip blank
indicate that COCs were present in a container to a
degree sufficient to infiltrate into the trip blank sample
jar and, hence, possibly into true samples.

Equipment blanks are used when sampling equipment is

cleaned and re-used for subsequent sample collection.
The blanks verify the effectiveness of field cleaning
procedures. The final rinse for the sampling equipment
is often made with analyte-free deionized water. The
rinse water is run on or through the sampling equipment,
collected in appropriate containers and preserved. These
samples are usually collected on a schedule, such as once
every 10 episodes.

Duplicates are samples collected at the same time, in the

same way, and contained, preserved, and transported in
the same manner as a corresponding duplicate.
Duplicates are used to determine the precision of the
laboratory method and integrity of the sample from
collection through testing. Duplicates are typically
collected once every 10 samples.

Matrix spikes provide the best overall assessment of

accuracy for the entire measurement system. For water
investigation episodes, a laboratory usually prepares the
spike samples, sends them to the site, and the spike
sample(s) are included in the sample handling and
shipping process. The samples are analyzed blind by the
off-site laboratory. Matrix spikes can also be made from
certified mixtures of a contaminant and clean soil in the
field.

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 FIELD MANUAL

All types of blanks and duplicates must be prepared in

the same sample containers as actual samples including
labeling and identification schemes so that the laboratory
analyzes the sample without knowing that the samples
are quality control (QC) samples (blind testing).

In addition to field QC samples, the analytical laboratory

also uses QC samples. Method blanks are organic-free or
deionized water carried through the analytical scheme
like a sample. Method blanks measure contamination
associated with laboratory activities. Calibration blanks
are prepared with standards to create a calibration curve.
Internal standards are measured amounts of certain
compounds added after preparation or extraction of a
sample. Surrogates are measured amounts of certain
compounds added before preparation or extraction of a
sample to determine systematic extraction problems.
Duplicates and duplicate spikes are aliquots of samples
subjected to the same preparation and analytical scheme
as the original sample. Laboratory control standards
(LCSs) are aliquots of organic-free or deionized water to
which known amounts of analyte have been added. LCSs
are subjected to the sample preparation or extraction
procedure and analyzed as samples.

Field, laboratory, data validation, and report presentation

documents must be meticulously maintained during
hazardous waste site investigations. All field activities
should be recorded in bound, consecutively numbered log
books. Each entry should be made with indelible ink, and
all strike outs should be made by a single line which
allows the original error to be legible and initialed and
dated by the person making the correction. Entries
should include date, weather conditions, personnel
involved with the activity, the type of activity being
performed, unusual circumstances or variations made to
the SOPs, and data appropriate to the activity being

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 HAZARDOUS WASTE

performed. This is a diary of all activities on a site. The

investigator responsible for the activity is responsible for
maintaining the field log book. An important purpose of
the field log book is to document any changes made to
SOPs. If such changes may affect data quality,
concurrence with managers or regulatory personnel is
required in writing. All records must be under control at
all times. Unique project numbers should be assigned to
all log books, documents, and reports. All records must
be maintained and custody documented so that
unauthorized changes or tampering are eliminated. Log
book entries should be photocopied on a regular schedule
to ensure that field data are not lost if the original book
is lost or destroyed.

Activities during an investigation must be reviewed to

ensure that all procedures are followed. System audits
should consist of inspections of training status, records,
QC data, calibrations, and conformance to SOPs. System
audits are performed periodically on field, laboratory, and
office operations. Each major investigation type should
be subject to at least one system audit as early as
practicable. Performance audits include evaluation and
analysis of check samples, usually from laboratory
activities. Readiness reviews occur immediately prior to
beginning each type of field activity to assess the
readiness of the team to begin work. A checklist of
prerequisite issues, such as necessary equipment,
controlled documents, training, assignments, spare parts,
field arrangements, etc., are discussed and documented.

If any weaknesses or deficiencies are identified, the

investigator must resolve them before field activities
proceed.

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 FIELD MANUAL

Sample Management

There must be control and documentation of all samples

after the environmental samples are collected in the field.
The proper quantity of a sample must be collected to have
sufficient volume for the subsequent analysis. The proper
sample container and preservative must be used so that
sample integrity is not compromised. Many types of
samples (e.g., volatiles) must be cooled, usually to 4 EC,
throughout their history after collection. The proper
analytical methods must be identified to obtain the
desired result. The laboratory must handle and track the
received samples in a timely and accurate manner to
ensure that the results are correct.

Sample Custody

Sample custody is a prime consideration in the proper

management of samples. Sample custody is designed to
create an accurate, written, and verified record that can
be used to trace the possession and handling of the
samples from collection through data analyses and
reporting. Adequate sample custody is achieved by
means of QA-approved field and analytical
documentation. A sample is considered in custody if the
sample is (1) in one's actual physical possession, (2) is in
one's view after being in one's physical possession, (3) is
in one's physical possession and then locked up or
otherwise sealed so that tampering will be evident, or
(4) is kept in a secure area restricted to authorized
personnel only. Personnel who collect samples are
personally responsible for the care and integrity of these
collected samples until the samples are properly
transferred or dispatched. To document that samples are
properly transferred or dispatched, sample identification

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 HAZARDOUS WASTE

and chain of custody procedures must be followed.

Sample custody in the field and in transit involves the
steps described below.

Sample Identification.—The sample must first be

properly and uniquely identified. Sample identification
entails establishing a scheme which ensures that each
sample is identified in such a way that one sample cannot
be mistaken for another. Examples of sample labels are
shown in figure 12-3. Labels must be filled out
immediately after the sample is collected to ensure that
containers are not later misidentified. Indelible ink must
be used on all labels, and the writing must be legible. For
samples which require preservation, the sample labels
must have a space on the label reserved for noting the
preservative added, or other treatments, such as filtering,
compositing, etc. Labels can be removed from a sample
jar during shipment, especially if the accompanying ice
melts and saturates the shipping labels. Double-label
samples such as sacked soil whenever possible or
completely wrap the label over the sample bottle with
wide, water-proof tape. Also record the collection of each
sample in the field log book and chain of custody records.

Chain of Custody.—Once all samples for a specific sam-

pling task have been collected, the sampler(s) will com-
plete the chain of custody record (figure 12-4). Specific
procedures for completing this form should be included in
the work plan documents specific to the project. This
record accompanies the samples to their destination. All
samples typically are transferred from the sample
transport container (e.g., cooler) and kept in the exclusion
zone until transferred to a noncontaminated sample
transport container in the contamination reduction zone.
The samples, with accompanying documentation, are

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Figure 12-3.—Soil and water sample identification labels.

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413

Figure 12-4.—Chain of custody record.

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then prepared for either distribution to the onsite

laboratory or shipment to an analytical laboratory in the
support zone.

When transferring the possession of samples, the

individuals relinquishing and receiving the samples will
sign, date, and note the time on the chain of custody
record. This record documents sample custody transfer
from the sampler to the analyst. Note that some
commercial shippers (such as Federal Express) do not
sign chain of custody records but do prepare separate
shipping documents which indicate receipt of the
cooler(s). When samples are passed among field
personnel while still onsite, chain of custody records do
not need to be signed, as long as physical possession is
retained by identified, responsible personnel during
transit of the container(s).

Packaging

Samples must be packaged properly for shipment and

dispatched to the appropriate laboratory for analysis; a
separate record accompanies each shipment. Samples
within shipping containers will be sealed for shipment to
the laboratory by using custody seals (figure 12-5). Seals
are made of paper, with adhesive backing, so that they
will tear easily to indicate possible tampering. There are
two methods of using custody seals. One method is to
place several sample containers in individual plastic bags
(or boxes) within the shipping container and then place
the custody seal along the only opening of each bag. An
advantage of this scheme is that the seal is not exposed
to outside influences; but the disadvantages are that the
bags are very pliable, and shifting may cause the seal to
break, and the seal may become immersed in water if ice
melts around the bags. The second method is to place the
custody seal on the outside of the cooler, along a seam of

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415

Figure 12-5—Custody seal.

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the lid. The advantage of this method is that the seal is

stuck to the solid body of the cooler. The main
disadvantage is that the seal is exposed to handling by
the shipping company and other personnel from the field
to the laboratory. The seal must not be broken acci-
dentally because a broken seal will place all the
samples represented by the seal in jeopardy of
disqualification due to tampering. An option may be to
place clear tape over the seal as added protection.

The samples within a container must be packed to avoid

rattling and breakage. Styrofoam "popcorn" or bubble
pack sheeting are acceptable packing materials. Organic
packing materials, including sawdust, should be avoided
due to the possibility of becoming wet from melting ice.
Each sample jar should be wrapped such that jar-to-jar
contact is avoided. Also, it is usually desirable to place
ice at the bottom of the container, and place the samples
above the ice, with a water-proof barrier between the ice
and samples. This way, if the ice melts, there is a
lessened probability of the samples becoming immersed.
If time is available, ice should be double-wrapped, using
several "ice packages" to lessen spillage potential.
Chemical ice packs and dry ice should be avoided, if
possible, to lessen the chance of chemical contamination.
The chain of custody record must accompany each
container and list only the samples contained within the
specified cooler. The original chain of custody record
should be sealed in a "zip-lock" plastic bag and taped to
the inside top of the cooler lid. When the laboratory
opens a cooler, the number and identification of each
sample contained within the cooler must exactly match
the corresponding chain of custody record. A copy of the
chain of custody record is to be retained by the
investigator or site manager, and a copy is also retained
by the laboratory. A three-carbon copy type chain of
custody record is best.

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The water drain at the lower edge of the cooler must be

sealed so there is no possibility of the drain opening. If
any leakage occurs from a cooler containing environ-
mental samples, the shipping company will cease ship-
ment and delay the arrival of the samples, possibly
exceeding the holding times of the contained samples. A
shipping company may have unique requirements; but as
a general rule, the weight of a cooler should not exceed
50 to 70 pounds. If sent by mail, the package must be
receipt requested. If sent by common carrier, a govern-
ment bill of lading can be used. Proper shipment tracking
methods must be in place. Copies of all receipts, etc.,
must be retained as part of the permanent
documentation.

Upon arrival at the laboratory, the containers will be

opened, the custody seals inspected and documented, and
any problems with chain of custody, temperature, or
sample integrity noted. The laboratory custodian will
then sign and date the chain of custody record and enter
the sample identification numbers into a bound,
paginated log book, possibly assigning and cross-
referencing a unique laboratory number to each sample
received. The laboratory then controls the samples
according to the SOPs specified in their work plan
documents.

Decontamination

Decontamination consists of removing contaminants

and/or changing their chemical nature to innocuous
substances. How extensive decontamination must be
depends on a number of factors, the most important being
the type of contaminants involved. The more harmful the
contaminant, the more extensive and thorough decon-
tamination must be. Less harmful contaminants may

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require less decontamination. Only general guidance can

be given on methods and techniques for decontamination.
The exact procedure to use must be determined after
evaluating a number of factors specific to the site.

When planning site operations, methods should be

developed to prevent the contamination of people and
equipment. For example, using remote sampling tech-
niques, using disposable sampling equipment, watering
down dusty areas, and not walking through areas of
obvious contamination would reduce the probability of
becoming contaminated and require a less elaborate
decontamination procedure.

The initial decontamination plan is usually based on a

worst-case situation. During the investigations, specific
conditions are evaluated including: type of contaminant,
the amount of contamination, the levels of protection
required, and the type of protective clothing needed. The
initial decontamination system may be modified by
adapting it to actual site conditions.

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