Collection, Handling, and Analysis of Environmental Samples in Support of Regulatory Projects

In Reply Refer To:                            January 14, 1994
Mail Stop 412


Subject:  Collection, Handling, and Analysis of Environmental
          Samples in Support of Regulatory Projects


The Water Resources Division (WRD) is a nonregulatory organization which has
traditionally focused on data collection, applied hydrology, and research. 
Pursuit of these traditional hydrologic programs will continue to be the major
part of the WRD mission.  However, since the mid-1980's, regulatory projects
have increased in importance in the Division from both a scientific and funding
perspective.  To help ensure that both WRD standards and regulatory
requirements are met, this memorandum provides some guidance concerning the
collection, handling, and analysis of samples from regulatory projects and
associated health and safety issues.  


Regulatory projects are typically driven by Federal and State
laws and regulations.  These projects may involve compliance monitoring,
permitting, waste characterization, and activities supporting facility
cleanup.  Regulatory projects must follow specific and demanding guidelines and
protocols; failure to do so may cause invalidation of all data and information.

As WRD involvement in regulatory projects expands, it is imperative that
District personnel ensure that (a) methods and procedures related to the
collection, handling, and analysis of environmental samples are acceptable to
the regulating authority, and (b) the project takes the necessary precautions
to protect the safety and health of personnel.  Each project needs to answer at
least four questions:

     1.  What are the requirements for the project 
         Quality Assurance/Quality Control (QA/QC) Plan?
     2.  Which analytical methods are required?
     3.  What are the chain-of-custody requirements?
     4.  What are the health and safety requirements?

Each question is discussed below.

QA/QC Plans

Prior to beginning a project, District personnel must develop 
a comprehensive project QA/QC plan that (a) identifies and describes all of the
required QA precautions and steps, and (b) identifies the QC data needed to
support environmental data acquisition.  To avoid invalidation of results, the
QA/QC plan must be reviewed and officially accepted in writing by the
regulatory agency.  Information on developing and integrating QA/QC into
project workplans is available in Open-File Report 92.162 (Shampine and others,
1992).  Sample QA/QC reports and additional information on this topic are
available from Bill Shampine, Branch of Quality Assurance (BQA), at (303) 
239-5001, or John Powell, Department of Defense Environmental Contamination
(DODEC) Program Manager, at (703) 648-5010.

Field QC may include field replicates, sample splits, equipment blanks, ambient
condition blanks, trip blanks, surrogates, and matrix spikes.  For organic
analytes, the National Water Quality Laboratory (NWQL) has a number of spiking
solutions available for field use where required.  To order a field spiking
kit, please contact Will Lanier at (303) 467-8065; to obtain advice on how to
apply the kits to your project, please contact Bruce Darnel at (303) 467-8089.
For inorganic constituents, field QC emphasizes replicates, sample splits, and
occasionally reference samples, which are available through BQA (contact Keith
Long at (303) 239-5005 or Jerry Farrar at (303) 239-5009.

Bench-level QC data are available at the NWQL and typically include information
on standard calibration curves, blanks, replicates, and spike and surrogate
recoveries.  Many regulatory programs require such information before the
analytical data will be accepted.  The NWQL does not routinely publish 
bench-level QC data, but release of these data can be arranged through the NWQL
prior to the start of the project.  District personnel should cntact the
Quality Management Program (QMP) at the NWQL prior to sampling to define the
exact QA/QC requirements for a specific project and to arrange the release of
required QC data (contact Chief, QMP, at (303) 467-8041.  

Analytical Methods

Work involving regulatory issues or compliance monitoring often requires
analytical methods specified by regulatory agencies.  The majority of the
regulatory programs require the use of methods specified in U.S. Environmental
Protection Agency (USEPA) 40 CFR, Part 136.  A number of programs also require
that a laboratory obtain specific certification before results from that
laboratory are acceptable by the regulating agency.  For example, drinking
water samples and urban runoff samples must be tested by methods that the USEPA
or the individual State has specified for these particular programs.  The NWQL
has obtained USEPA certification for specified methods to provide acceptable
methods for drinking-water testing.   

The NWQL does not actually perform the analytical work for most Resource
Conservation Recovery Act (RCRA) or Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) projects.  However, the DODEC Unit at
the NWQL works closely with WRD personnel to provide a mechanism through which
all of the required services can be made available.  Under the coordination and
monitoring of the DODEC Unit, the NWQL has established a contract with the
Rocky Mountain Analytical Laboratory to obtain analyses for RCRA and CERCLA not
available in the NWQL.  To avoid confusion or possible invalidation of data,
each project should obtain a signed, written list of the analytical methods
required by the regulatory agency.  This list should be communicated with the
DODEC Unit of NWQL to (a) ensure that required methods are available and used
appropriately, and (b) determine what to do if certain required methods are not
available at the NWQL or under the existing contract (contact Dorothy Walker at
(303) 467-8051 or Bob Brock at (303) 467-8097).

Chain of Custody

Chain of custody is a protocol developed to provide a legal record of the
persons having contact with a sample from the moment of collection to final
disposal.  If the analytical results performed in a project become subject to
litigation, the project chief may be required to provide documentation and
witnesses to prove that a chain-of-custody protocol was followed.

To meet chain-of-custody requirements, some agencies may simply ask that the
NWQL acknowledge receipt of samples by completing a form, whereas others may
require that samples be kept in a secure lock-up, signed out to each individual
analyst separately, and accounted for at all times.  To avoid problems,
District personnel should confirm in writing the specific chain-of-custody
requirements of the regulatory agency.

When dealing with chain-of-custody samples, it is important to understand that
if the required procedures are not followed, all of the analytical work may
become invalidated.  To avoid misunderstandings or invalidated data, it is
suggested that District personnel contact the NWQL prior to accepting any work
with District chain-of-custody requirements (contact Bob Williams at (303) 


Regulatory work often involves testing for known carcinogens in contaminated
sites, and the contaminants may occur at much higher levels than in ambient
settings.  WRD policy requires that a site where hazardous materials are known
to be present must be characterized as to the level of protection required
before WRD personnel are allowed to enter the site.  A contractor is available,
if required, to assist the WRD in characterizing the site.  The development of
a site safety plan is also required.  Guidance in developing a site safety plan
is available from the Branch of Operational Support.  WRD policy, in compliance
with USEPA 29 CFR, Part 1910.120, requires that all personnel who work at a
hazardous waste site must receive 40 hours of safety training and an annual 
8-hour refresher training course.  The WRD makes both of these courses
available.  Medical monitoring is also required for all WRD personnel working
at a hazardous waste site.  A medical surveillance program has been established
by the WRD that requires a baseline physical and then annual physicals that are
reviewed by the Department of the Interior Medical Director.  Guidelines on
safety are provided in WRD Memorandums 93.33 and 92.54.


All phases of analytical data acquisition in a regulatory project must be well
documented.  Care must be taken to ensure that QA/QC, analytical methods, 
chain-of-custody requirements, and health and safety issues are clearly
understood and that the services are acceptable to the regulatory agency.  
All points of debate should be well defined, clarified in writing, and accepted
by signature prior to initiating work.  

Additional Reading

U.S. Environmental Protection Agency, 1991, Code of Federal Regulations, 
40 CFR, Part 136, p. 301-586

_____1991, Code of Federal Regulations, 29 CFR, Part 1910, p. 67-824.

_____1988, Guidance for conducting remedial investigations and feasibility
studies under CERCLA:  Washington D.C., U.S. Environmental Protection Agency,
EPA 540 G-89/004, variable pagination.

_____1990, Drinking water regulations under the Safe Drinking Water Act: 
Criteria and Standards Division, Office of Drinking Water, U.S. Environmental
Protection Agency, Safe Drinking Water Act Fact Sheet, May 1990, 43 p.

_____1992, NPDES storm water sampling guidance document:  Washington D.C., 
U.S. Environmental Protection Agency, EPA 833-B-92-001, variable pagination.

Pritt, J.W., Paese, J.W., 1992, Quality assurance/quality control manual,
National Water Quality Laboratory:  U.S. Geological Survey Open-File Report 
92-495, 33 p.

Shampine, W.J., Pope, G.L., and Kotterba, M.T., 1992, Integrating QA in project
workplans:  U.S. Geological Survey Open-File Report 92.162.

Watterson, C.A., and Kashuba, A.T., 1993, 1993 National Water Quality
Laboratory Services Catalog:  U.S. Geological Survey, National Water Quality
Laborarory Technical Memorandum 93.04, 115 p.

                             David A. Rickert
                             Chief, Office of Water Quality

Key words:  Regulatory program, safety, sampling

This memorandum does not supersede any previous Office of Water Quality
Technical Memorandum.

Distribution:  A, B, S, FO, PO, AH