9.0 SAMPLE CHAIN OF CUSTODY/DOCUMENTATION
The procedures outlined in this section are provided to assure that all site remediation activities are fully and accurately documented. Included in this section are procedures for maintaining field notebooks, documenting remedial progress with photographs, documenting site sampling procedures, and maintaining site documents.
9.1 Field Logbook
All activities performed at the Site will be recorded in bound, field logbook(s). All logbooks will be kept at the Site while remedial activities are ongoing. At the completion of the site cleanup, logbooks and all other records (e.g., chains-of-custody) will be transferred to the appropriate office for use in completing the final reports. At the completion of the project, all logbooks and other records will be transferred to IOC for inclusion in the project file.
Field logbooks are legal documents, and thus need to be thoughtfully, accurately, and legibly prepared to qualify as the legal record of all site activities. Logbooks will be reviewed periodically to assure that quality records of site activities are being maintained. Information to be recorded in field logbooks must be as accurate and as detailed as practical; however, logbook entries must be factual statements only; no judgmental comments should be included. All field activities should be recorded in the bound logbooks at the time they occur. If an amendment is made to the logbook, it must be identified as an amendment, dated, and signed by the person making the amendment.
Field logbooks may include one or a combination of the following: Site Logbook, Sampling Logbook, Health & Safety Logbook, Radiological Controls Logbook, and/or Visitor Logbook. Overall site activities are recorded in the Site Logbook, with activity-specific information detailed in the appropriate activity logbook. Each logbook is described in the following sections. The Construction Manager shall be responsible for the preparation and maintenance of project field activity logbooks. This responsibility may be delegated to a designated Field Operations Leader or, in the case of the Health & Safety Logbook, the Site Health & Safety Officer (SHSO). Logbook formats shall be at the discretion of the individual Construction Manager while adhering to the following basic requirements:
· All field logbooks must be weatherproof and permanently bound with consecutively numbered pages;
· The project name, project number, and site name and address are to be written on the cover of each logbook;
· Entries are to be made using permanent waterproof blue or black ink;
· Erasures are not permitted. Errors must be crossed-out with a single-line so that the error is not obscured, and initialed by the person making the entry, and dated;
· A new page is to be started each day with the signature of the person responsible for making the entries. The end of each daily entry will be indicated by "End of log for the day applicable date" along with the signature of the person responsible for the entries. If the last entry for a particular day does not end at the bottom of a page, a line is to be drawn diagonally down the remainder of the page, and the bottom of the page must be signed and dated;
· Blank pages that may be inadvertently left in the logbook are to have a large 'X' drawn across the entire page along with the signature of the appropriate field team member; and;
· All pages must include the date at the top of the page and the time of day, in military time, in the left margin preceding each entry.
In general, logbook entries can be defined by the following four categories: daily logbook entries, observations, sample collection activities, and health & safety information. Examples of the types of information that should be recorded in the logbook include, but are not limited to, the following:
Daily Logbook Entries
· Record the time of site entry.
· Record the weather conditions - specific information regarding amount of rainfall, wind speed and direction must be recorded along with any changes in the weather conditions during that day's activities.
· Record the names of all team members and their responsibilities during that day's activities.
· Record general discussion of visitor activities including a list of all visitors on the Site that day.
· Record all conversations held with other persons responsible for or in some way involved with the Site.
· Record a step-by-step explanation of site activities. This can be accompanied by photographs and/or sketches, as appropriate, to better describe activities.
Observations
· Record descriptions of site physical or topographic features pertinent to site activities.
· Record remediation activities, construction details, equipment usage, problems encountered, and explanation of any down time.
· Record information on arrival and removal from the site of all shipping containers or rail cars. Details regarding the number of containers received and quantity of materials shipped should be included.
· Describe stratification of the subsurface, soil or water conditions, and other subsurface data. Soil sample descriptions will be recorded using the Unified Soil Classification System (USCS), American Society for Testing and Materials (ASTM) D2488.
· Record field measurements exactly as taken. All calculations made should be entered in the logbook indicating the measurements and formula used in performing the calculation.
· All observation entries must be identified with a location, use sketches to illustrate locations when appropriate.
Sample Collection Activities
· Record the names of samplers.
· Record the sample number(s).
· Describe sample location coordinates and elevation, indicate references to photographs, maps, or sketches made, as appropriate.
· Reference the sampling equipment used, including serial numbers of field screening or testing instruments.
· Record the results of field instrument calibrations.
· Record sampling method(s) used.
· Record the time interval of sampling (military time).
· Detail any variance from original plans.
· Explain any mishaps or malfunctions and the action taken to correct the mishap/malfunction, including the rationale, and the name of the individual authorizing the corrective action.
· Decontamination procedures used and method of disposal of generated waste.
· Identification of specific QC samples.
Health & Safety Information
· Record the results and readings of daily health and safety monitoring equipment calibration.
· Detail any background locations and measurements taken.
· List the level of PPE used during the day.
· Describe any incidents, accidents, and course of action taken and by whose authority.
9.2 Site Photographs
The QA/QC manager will maintain a site photograph log on-site. All photographs taken by site personnel will be described in the photograph logbook. The logbook will be a bound notebook in which the date, number of photos, and a brief description of the contents of the photographs and an explanation of the purpose for taking the photographs will be included. All printed photographs will have a note written on the back to indicate the date taken, the photograph number, and the page in the photographic log where the photograph is described.
Photographs should be taken using a digital camera, and all electronic files will be stored in the on-site computer. The electronic files will be stored within directories according to date, and each electronic file will have a unique name. An onsite color printer will be used to print color photographs as necessary.
9.3 Sample Numbering System
The sample numbering system will be used to identify each sample taken and to provide a tracking procedure for retrieval of information. Sample numbers will be generated in the BOM-XX-YYY-NNN format as follows:
1. XX = Sample type, as follows:
AA = General area air filter sample
AE = Environmental (perimeter) air filter sample
AP = Personnel air filter sample
FS = Final status survey soil
LW = Liquid waste
SL = Soil
WP = Wipe
SW = Surface water
SD = Sediment
LA = Offsite lab
DP = Disposal profile sample (to provide information to the disposal facility)
SC = site characterization
SP = Shipping profile sample (to provide information for shipping paperwork
OT = Other
2. YYY = Survey Unit Number for final status survey samples, or for sampling location where repetitive samples are being collected or location identifier
3. NNN = sequential number
9.4 Sample Documentation
9.4.1 Sample Labels
Sample labels will be completed for each sample using waterproof ink. Computer printed labels are also acceptable provided that the ink used is waterproof and the label remains attached to the sample when wet. If inclement weather conditions prohibit use of waterproof ink, a logbook notation should explain that a pencil was used to fill out the sample label because a pen would not function under field conditions. Information to be recorded on each label includes:
1. site name
2. sample number
3. date
4. time of collection
5. name of sampler
6. analysis requested
9.4.2 Sample Log Sheets
Sampling crews will record all specific sampling information (i.e., sample number, date, time, etc.) on sample log sheets. The make, model, and serial number (if applicable) of sample collection equipment, field analytical equipment, and physical measuring equipment will also be recorded on the log sheet.
Sample log sheets will be numbered consecutively to follow the sequence of sampling. Use of sample log sheets will be noted in the site logbook.
Sample log sheets completed in the field may not be transcribed to clean sheets. All sample log sheets and sample summary sheets will be assembled in a loose-leaf binder.
Separate log sheets for other field activities, such as field analyses, etc., may be used as needed, upon approval by the Site Manager. Use of such data sheets will be noted in the site logbook.
9.4.3 Chain-of-Custody Records
Off-site samples are accompanied by a Chain-of-Custody (COC) Record Form supplied by the laboratory. Each COC must have an unique identification number. When transferring samples, the individuals relinquishing and receiving will sign, date, and note the time on the Record. This Record documents sample custody transfer from the sampler, often through another person, to the laboratory. The Chain-of-Custody Record is filled out as follows:
1) Enter header information (project number and name). For each station number, enter date, time, composite/grab, station location, number of containers, analytical parameters, and sample identification number (in remarks column).
2) Sign, date and enter the time under "Relinquished by" entry.
3) Make sure that the person receiving the sample signs the "Received by" entry, or enter the name of the carrier (e.g., UPS, Federal Express) under "Received by." Receiving laboratory will sign "Received for Laboratory by" on the lower line and enter the date and time.
4) Enter the bill-of-lading or carrier air bill number under "Remarks," if appropriate.
5) Place the original (top, signed copy) of the COC Record Form in the appropriate shipping package. Retain a copy with field records.
Common carriers will usually not accept responsibility for handling COC Record Forms. This necessitates packing the record in the sample container (enclosed in a plastic zip-lock bag). As long as custody forms are sealed inside the sample container and the custody seals are intact, commercial carriers are not required to sign off on the custody form.
The laboratory representative who accepts the incoming sample shipment will sign and date the COC Record, completing the sample transfer process. It is then the laboratory's responsibility to maintain custody records throughout sample preparation and analysis.
9.5 Corrections to Documentation
All field documentation, including field logbooks, labels, sample log sheets, and chain of custody records are completed using blue or black waterproof ink. Any corrections are made by drawing a line through the error, initialing and dating the change, and entering the correct information. Erasures are not permitted.
9.6 Internal QC Checks
Field sampling procedures will be monitored for precision and accuracy by the collection and submittal of field duplicate samples, rinsate blanks, and split samples. These samples will be a blind submittal to the laboratory so as to be indistinguishable from the original sample. The collection of these QC samples will be documented in the field logbook and in the sample logbook.
Rinsate blank samples will be collected by passing laboratory-supplied ASTM Type II deionized water over the decontaminated sample equipment and into the required sample containers. Rinsate samples will be collected at a frequency of one per 20 samples collected or one per sampling event, whichever is more frequent. Rinsate blanks will be analyzed for the same chemical parameters as the samples being collected.
Field duplicate samples will assess the precision of sampling and analytical methods. Field duplicate samples will be prepared by dividing the original sample into two equal aliquots. Each aliquot will be submitted separately and be analyzed for the same parameters as the main samples. The frequency of duplicate sample collection is one duplicate per every 20 samples collected per matrix.
Split samples will be collected at a rate of one sample per 20 samples collected, including final status survey samples. Split samples are collected in the same fashion as field duplicate samples. They will be sent to a designated Quality Assurance lab for radiological and chemical analyses (if necessary) and will serve as a check on the primary laboratory. The check will be performed by calculating split sample Relative Percent Difference (RPD). The RPD is calculated by dividing the difference between two measured values by the average of the two measured values. This number is then multiplied by 100.
Where V1 and V2 are the measured values. RPD's greater than 50% will be investigated to determine if suspect results are present and potential corrective actions are needed.
A population histogram of the results from a split samples and duplicate samples will be developed that plots the on-site soil sample results versus frequency or relative frequency and the off-site soil sample results. This will be used to observe any differences between the aggregate result. A box plot of the data may be developed to determine how the median and the 25th percentile and 75th percentile of on-site and off-site data relate. If these percentiles do not overlap the data shall be investigated for bias.
9.7 Corrective Actions
9.7.1 Field Activities
The initial responsibility for reporting and documenting unsafe actions, improper activities, and/or potentially dangerous situations lies with the on-site personnel. On-site personnel must immediately notify the Construction Manager, who is responsible for immediately reporting events to the Contractor Quality Control (QC) Manager and for documenting the event. The Construction Manager is responsible for investigating identified problems and implementing corrective action, or for assigning other personnel to perform these tasks. The Construction Manager must also verify that the corrective action has eliminated the problem in question. All field personnel have the authority to stop work when an event has occurred that could impact the quality or safety of the site work. Corrective actions will be decided upon by the Construction Manager in consultation with the Project Manager.
Corrective actions in the field are likely to be immediate in nature and can be implemented by field personnel or the Construction Manager. The corrective action will usually involve reanalysis, repeating the instrument calibration, or resampling at a particular location. Once an event has occurred and the Construction Manager and Project Manager have been notified, the following steps will be taken to regain control:
1. The Construction Manager will investigate and determine the probable cause of the event.
2. The Construction Manager will consult with the QC Manager regarding appropriate corrective actions.
3. The Construction Manager will decide on an appropriate corrective action.
4. The Construction Manager will implement or direct the Contractor(s) to implement immediate corrective action.
5. The Project Manager will verify the effectiveness of the corrective action and decide on further actions if necessary.
The Project Manager will document each event by recording the situation and its resolution (including all notifications and corrective actions taken). Possible causes, proposed corrective action(s), and the date the corrective action(s) occurred will be recorded. The Project Manager will check to be sure that corrective action has been taken, the corrective action appears effective, and the situation has been fully resolved.
9.7.2 Laboratory
At the laboratory level, re-analysis and other corrective measures are contractually required if specific control limits established on the standard methods are exceeded. The person directly responsible for the test must know the current operating and acceptance limits, and take the required corrective actions), including sample re-analysis. Lab results must also be reviewed by the laboratory staff to insure that all method-specified QA requirements have been met. The report is then prepared and submitted for final QA check. Each person in the review process has the authority to require re-extraction and re-analysis of a sample if QC problems are identified.
The QC chemist is responsible for preliminary data review. If data review or QC audits result in detection of unacceptable conditions in the data results, the QC chemist will be responsible for the timely notification of the laboratory. Corrective action may include:
· Re-analyzing samples if holding time criteria permit;
· Re-sampling and analyzing;
· Evaluating and amending sampling and analytical procedures; and
· Accepting data acknowledging level of uncertainty.
Data inadequacies attributable to site-specific interference or conditions may require that sampling procedures or analytical methods be modified.
9.8 Investigation-Derived Wastes (IDW)
There are four types of wastes that will be generated during remediation of the BOMARC Site, including:
· General trash;
· Contaminated clothing, filters, etc.;
· Excess sample collected for analysis; and
· Decontamination fluids.
9.8.1 General Trash
General trash may include items such as packaging material, office paper, unused sample jars, pallets, wood, non-contaminated protective clothing, and any other non-contaminated waste materials. A roll-off container will be located at the site, and arrangements will be made with a local hauler to pick up the general garbage once a week.
9.8.2 Contaminated Clothing, Filters, etc
Contaminated materials generated during the BOMARC Site remediation will mainly consist of used personal protective equipment (boots, gloves, tyvek), but will also include used sample jars, used air filters, etc. All such waste will be collected as generated, placed in shipping containers with the contaminated soil, and shipped to a licensed facility for disposal with the soil.
9.8.3 Excess Sample Collected for Analysis
Numerous types of samples will be collected during field operations, for both on-site and off-site analyses. All excess materials remaining after on-site analysis will be disposed with the original materials from which the sample was taken, unless the sample is archived. In other words, contaminated solids will be disposed with the contaminated soils, and non-contaminated solids will be disposed with general trash.
9.8.4 Decontamination Fluids
Decontamination fluids include fluid generated at the decontamination pad and decontamination fluids collected as part of the sampling efforts. If conditions allow, all decontamination fluids will be used to control dust on the >8 pCi/g soil pile. If conditions are such that the moisture content of the pile will be adversely affected by the additional moisture, the fluids will be place into a holding tank. Solids will be allowed settle to the bottom of the tank, while liquids will be tested to determine the level of radioactivity. If below release criteria, the water will be used for on-site dust suppression. Water remaining in the tank at the completion of remediation will be disposed at an off-site disposal facility. Solids remaining once the water has been removed will be analyzed and disposed with the contaminated soils.
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