How’s Your CCR Sampling Team Doing?

Many of Environmental Standards’ energy clients operate coal combustion residuals (CCR) units as defined by the United States Environmental Protection Agency (US EPA) CCR Rule and have had to implement groundwater monitoring and corrective action activities in accordance with the provisions of the rule. These provisions require (in part) the installation of a monitoring well network, development of procedures for sampling groundwater from the wells, and analyzing groundwater samples for constituents of concern.  As part of a robust quality assurance/quality control (QA/QC) and data management process, Environmental Standards has been conducting field sampling audits during CCR groundwater sampling activities at a frequency of approximately 50 audits per year for the last several years. The intent of the audits is for Environmental Standards to work as part of the Project Team to facilitate and assist the Field Teams with continuous improvements, to ensure field activities are conducted in compliance with project control documents (PCDs), and to assess and ensure that the resulting sample data are as reliable, defensible, and representative as possible. Each of the various aspects of the field activities (including pre-task planning, field documentation, sample containers, sampling activities, QA/QC samples, Chain-of-Custody Records, decontamination, sample packaging, waste management, and health and safety) are evaluated, but specific attention is paid to the well purging and sampling procedures as the key parameters for CCR groundwater sampling programs are typically inorganics, which can be greatly influenced by elevated turbidity levels. Compliance with the PCDs, specifically as it relates to groundwater stabilization criteria, is key and is often where deviations are observed. The implementation of real-time corrective measures during the field audits is critical in helping to ensure representative groundwater samples are collected. Consistency, not just for the Sampling Team activities, but between PCDs at all client facilities, is key in getting consistent and reliable data program-wide, and as such, many clients also ask Environmental Standards to review and update the PCDs with the goal of establishing and implementing standard procedures throughout their CCR program. Please let us know if we can assist you with your CCR field sampling QA/QC program.