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UCMR3 Sampling
Workshop:
What You Need to Know
Presented by: Joseph Mattheis
Life and Health Sciences
Water Quality Account Executive
UL and the UL logo are trademarks of UL LLC © 2012
Agenda
About UL
UCMR 3 Overview
UCMR 3 Methods
UCMR 3 Sample Collection
UCMR 3 Costs
Questions
2
UL at a Glance: Standards Development, Testing,
Certification, Knowledge Services
UL founded by William
Henry Merrill
following 1893
Chicago World’s Fair
1897
Takes name of
Underwriters’
Laboratories,
Inc.
First international
office opened in
London
1903
1958
1901
1894
First published
list of approved
electrical devices
UL/CCIC
agreement for
inspections
1916
First UL standard
published
STR QA
acquisition
1988
1980
Fire protection
lab built
2011
Hong Kong and
Taiwan offices open
118 year history
105 facilities globally
60,000+ customers in 102
countries
10,000+ employees
23 billion UL marks appear
on 72,000 products
2.0 billion consumers
reached
Mission: Promote safe living and working environments for people
around the world
3
About UL
Safe Living & Working
Environments
Facilitating Global
Trade
Trusted Source
Serving the Public Safety Mission Globally
•
Our mission enables industry and geographic growth
•
Our global footprint and scale support our customers
•
Our legacy, integrity and knowledge platform provide unparalleled information to customers
4
UL Business Units
Product Safety
Encompasses UL’s traditional testing and
certification business; helping manufacturers bring
safer products to global markets faster
Verification
Services
Provides performance / verification testing and
inspection services for manufacturers and retailers
Life & Health
Focuses on human safety in the medical, food, and
water industries
Knowledge
Services
Offers training, education, and technical expertise in
product safety and related areas
Environment
Provides environmental claims validation and
certification to help guide industries, governments,
and consumers with sustainability and environmental
product-related decisions
5
Drinking Water Analytical Services
Analytical Expertise
At our state-of-the-art 70,000 square foot facility,
UL performs virtually all analyses required under
the Safe Drinking Water Act (SDWA) including:
• Dioxin
• Disinfection byproducts
• Metals
• Microbial contaminants
• Organic & inorganic constituents
• Radiological parameters
UCMR 3 Overview
• Purpose
• Reporting
• Timeline
• PWSs
• Applicability
• Monitoring
• Elements
• Dates
• Data
• Lists
• Contacts
• Contaminants
• Methods
• Sampling Frequency
• Sampling Instructions
• Sampling Locations
8
Purpose of UCMR 3
• 1996 Amendments to SDWA require
EPA to monitor unregulated
contaminants
• Specifies frequency of every 5 years
• Data generated allow for Public
exposure assessment to
unregulated contaminants of
concern
• Data provide the basis for regulatory
decisions – which contaminants to
regulate
9
UCMR 3 Time Frame
• December 21, 2010 – applicability date
• State monitoring plans developed (including national representative
sample based on SDWIS/Fed population)
• March 3, 2011 – proposed rule published
• Laboratory approval program begins
• May 2, 2012 – final rule published
• States/EPA begin to inform PWSs and finalize monitoring plans
10
UCMR 3 Timeline
2012
2013
2014
2015
2016
Pre-monitoring
Implementation
• Lab Approval
• SDWARS
Registration
- Inventory
- Schedule
Sampling Period
One consecutive 12-month period during
January 2013 – December 2015
(monitoring can span more than 1
calendar year, as long as conducted in a
consecutive 12- month period).
Complete
Reporting to
SDWARS
• Review Data
• Post to
NCOD
11
UCMR 3 Applicability – Who is Required To
Test?
Assessment Monitoring (List 1 Contaminants)
• All CWS & NTNCWS serving populations >10,000 (~4,200)
plus 800 randomly selected serving populations ≤ 10,000
Screening Survey (List 2 Contaminants)
• All CWS & NTNCWS serving populations >100,000 (~410) ;
~320 randomly selected serving populations 10,001 to 100,000
and 480 randomly selected serving populations ≤ 10,000
Pre-Screen Testing (List 3 Contaminants)
• 800 Randomly selected systems serving populations ≤ 1,000
12
UCMR 3 Monitoring Lists
Assessment Monitoring – List 1 Contaminants
• EPA Method 524.3 Volatile Organic Compounds
- 1,2,3-trichloropropane
- 1,3-butadiene
- chloromethane
- 1,1-dichloroethane
- bromomethane
- chlorodifluoromethane
- bromochloromethane
13
UCMR 3 Monitoring Lists
Assessment Monitoring – List 1 Contaminants (cont.)
• EPA Method 537 - Perfluorinated Compounds
- perfluorooctane sulfonic acid (PFOS)
- perfluorooctanoic acid (PFOA)
- perfluorononanoic acid (PFNA)
- perfluorohexane sulfonic acid (PFHxS)
- perfluorophtanoic acid (PFHpA)
- perfluorobutaneseulfonic acid (PFBS)
• EPA Method 522 - Synthetic Organic Compounds
- 1,4-Dioxane
14
UCMR 3 Monitoring Lists
Assessment Monitoring – List 1 Contaminants (cont.)
• EPA Method 300.1 - Chlorate
- chlorate
• EPA Method 200.8 - Metals (alternate methods also available)
- vanadium
- molybdenum
- cobalt
- strontium
- chromium
• EPA Method 218.7 - Chromium6 (Cr6)
- chromium-6
15
UCMR 3 Monitoring Lists
Screening Survey – List 2 Contaminants
• EPA 539 - Hormones
• 17-β-estradiol
• 17-α-ethynylestradiol (ethinyl estradiol)
• 16-α-hydroxyestradiol (estriol)
• equilin
• esterone
• testosterone
• 4-androstene-3,17-dione
16
UCMR 3 Monitoring Lists
Pre-Screen Testing – List 3 Contaminants
• Cell Culture or QPCR
- enterovirus
• QPCR
- norovirus
• Various Methods - Microbiological Indicators
- total coliforms
- E. coli
- enterococci
- bateriophage
- aerobic spores
EPA will collect the samples from List 3 sampling locations and will pay for all analytical and shipping costs
associated with viruses and indicators for these small systems (≤ 1,000).
17
UCMR 3 Monitoring Frequency
PWSs must monitor during a consecutive 12-month period between
2013 - 2015
• Number of times a PWS samples is directly related to the sample
point source
- Surface Water and Ground Water under the Direct Influence of Surface
Water – must monitor quarterly during their 12-month schedule (sampling
events three months apart)
- Ground Water – must monitor twice during their 12-month schedule
(sampling events five to seven months apart)
• EPA established a monitoring schedule for all PWSs
- PWSs can change their pre-determined schedule in SDWARS by
November 29, 2012, independently, or after that date with EPA permission
18
UCMR 3 Monitoring Locations
All samples for UCMR 3 contaminants will be collected at the Entry Point to the
Distribution System (EP or EPTDS); in addition three methods will also be
collected at the Distribution System Maximum Residence Time (DSMRT)
List 1: Assessment Monitoring Contaminants
Sampling Location Type
Contaminant Type
EPA 524.3:
EPA 537:
EPA 522:
EPA 300.1:
EPA 200.8:
EPA 218.7:
Volatile Organic Compounds
Perfluorinated Compounds
Synthetic Organic Compounds
Chlorate
Metals
Chromium-6
EPTDS
DSMRT
x
x
x
x
x
x
x
x
x
List 2: Screening Survey Contaminants
Contaminant Type
Sampling Location Type
EPTDS
EPA 539:
Hormones
DSMRT
x
19
UCMR 3 Monitoring Locations – Field Blanks
Due to susceptibility to outside source contamination, UCMR3 requires field
blanks to be processed, extracted and analyzed for three of the List 1 Methods
and the List 2 Method if there is a contaminant detected in the associated field
sample. Field Blanks will be included with the following methods:
List 1
List 2
• EPA Method 524.3
• EPA Method 539
• Collected at the EPTDS
- Collected at the EPTDS
• EPA Method 537
• Collected at the EPTDS
• EPA 200.8
• Collected at the EPTDS & at
the DSMRT
20
UCMR 3 Monitoring and Reporting
Small PWSs serving 10,000 or fewer people are not responsible for the
costs associated with the analysis
• EPA coordinates sample analyses with contracted laboratories
• Laboratories submit the data directly to the EPA
• EPA examines the quality control results and generates reports
• EPA collects samples for only List 3 contaminants
• PWS reviews and can act upon data in SDWARS 3
21
UCMR 3 Monitoring and Reporting
Large PWSs serving more than 10,000 people are responsible for the
costs associated with the analyses
• PWS coordinates sample analyses with an approved laboratory,
and that lab sends the data to the Safe Drinking Water Accession
and Review System (SDWARS 3)
• http://cdx.epa.gov/epa_home.asp
• PWS reviews and can act upon data in SDWARS 3
22
UCMR 3 Reporting Elements
UCMR 3 Reporting Elements
Public Water System
Identification Code
Disinfection Type
Sample Analysis Type
Public Water System Facility
Identification Code
Sample Collection Date
Analytical Results - Sign
Water Source Type
Sample Identification Code
Analytical Results - Value
Sampling Point Identification
Code
Contaminant
Laboratory Identification Code
Sampling Point Type
Identification Code
Analytical Method Code
Sample Event Code
As a one-time reporting requirement, PWSs must report the U.S. Postal Service Zip Code(s) for all
areas being served water by that PWS.
23
UCMR 3 Reporting Elements
All of the disinfectants that have been added to the water being
sampled must be reported by systems for each sampling point with
possible choices being:
• CLGA – Gaseous chlorine
• CLOF – Offsite Generated Hypochlorite (stored as liquid)
• CLON – Onsite Generated Hypochlorite (no storage)
• GAGC – Chloramine (formed from gaseous chlorine)
• CAOF – Chloramine (formed from offsite hypochlorite)
• CAON – Chloramine (formed from onsite hypochlorite)
• CLDO – Chlorine Dioxide
• OZON – Ozone
• ULVL – Ultraviolet Light
• OTHD – All other Types of Disinfectant
• NODU – No Disinfectant Used
24
UCMR 3 Key Dates – November 29, 2012
Systems must submit contact information to SDWARS.
• Subsequent changes must be submitted within 30 days of the
change occurring
Systems can change their monitoring schedule, and review and edit
if necessary, inventory information for sampling locations.
• After November 29th, systems must request a change (with an
explanation) and obtain EPA approval of the change
25
UCMR 3 Data Reporting
Samples must be analyzed by EPA-approved laboratories.
• EPA-approved laboratories will be listed on the UCMR website at:
http://water.epa.gov/lawsregs/rulesregs/sdwa/ucmr/ucmr3/laboratori
es.cfm
• Within 120 days of sample collection
- Laboratories post data to SDWARS
• Within 60 days of lab posting data
- PWS reviews and approves the data. If the PWS has not taken
action after 60 days, the data are considered approved and ready
for state and EPA review
26
EPA Use of UCMR 3 Data
• Updated quarterly by EPA and posted in the National Contaminant
Database (NCOD)
• www.epa/safewater/databases/ncod/index.html
• Data will continue to be added and may be corrected upon further
review
• Use caution when interpreting the data before the dataset is
complete
• UCMR 3 is one of the primary sources of occurrence and exposure
information the agency uses to develop regulatory decisions for
contaminants of concern
27
UCMR 3 Contacts
• UCMR Message Center: (800) 949-1581
• This number may change later this year, but as of Sept 7th is still in use
• Safe Drinking Water Hotline: (800) 426-4791
• CDX/SDWARS Help Desk: (888) 890-1995
• UCMR Sampling Coordinator or Laboratory Approval Coordinator
UCMR_Sampling_Coordinator@epa.gov
USEPA Technical Support Center
26 West Martin Luther King Drive (MS 140)
Cincinnati, OH 45268
28
UCMR 3 EPA Online Resources
• UCMR 3 EPA Website
• http://water.epa.gov/lawsregs/rulesregs/sdwa/ucmr/ucmr3/
- Home
- Basic Information
- Methods & Contaminants
- Laboratories
- Reporting
29
UCMR 3 Methods
Assessment Monitoring (List 1 Contaminants) primarily utilize
common analytical method technologies used by drinking water
laboratories.
• 524.3
GC/MS
• 522
Quadrupole GC/MS
• 300.1
Ion-Chromatography
• 218.7
Ion-Chromatography
• 200.8
ICP-MS
• 537
LC/MS/MS
30
UCMR 3 Methods
Screening Survey (List 2 Contaminants) primarily uses common
analytical method technologies used by drinking water laboratories.
• 539 LC-ESI-MS/MS
Pre-Screen Testing (List 3 Contaminants) uses newer method
technologies not as commonly used by drinking water laboratories.
For UCMR 3 these PWSs are ground water systems that:
• Serve less than 1,000 people
• Do not disinfect
• Are located in areas of karst or fractured bedrock
31
UCMR 3 Sampling Information
Partnering with your selected laboratory is crucial to your
success!
• Complete and Accurate detail on the Chain of Custody and bottle
labels is critical for successful data uploads to SDWARS
• Following the collection schedule
• Understand the collection and preservation instructions (Method
522 requires a 2 step preservation process)
• Be certain that both you and your selected laboratory clearly
understand the field blank protocols
32
UCMR 3 Sampling Information
Properly handling Field Blanks is critical to avoid costly and time
consuming recollections.
• Four Methods require field blanks with each sample
• 524.3 (in duplicate)
• 200.8 (at both the EPTDS and the DSMRT)
• 537
• 539
• Collection protocols differ depending on the method
• Any field sample with a detect requires analysis of the associated
field blank
• Field Samples with a detect greater than >1/3 MRL requires
re-collection
33
UCMR 3 Sampling Information
Both the sample collector and the primary PWS contact (if not the same
person) need to know and understand the Field Blank protocols.
• 524.3 (EPTDS)
• Pre-preserved vials filled with reagent water shipped with collection containers
• DO NOT open in the field
• 200.8 (EPTDS and DSMRT)
• Bottle filled with reagent water shipped with collection containers
• At the collection site, OPEN the Field Blank, recap, and return with the field
samples to the laboratory
• 537 and 539 (EPTDS)
• Pre-preserved bottles with reagent water as well as a empty bottle shipped with
collection containers
• At the collection site, transfer the preserved reagent water into the corresponding
empty container and return with the field samples to the laboratory
34
Sampling Instructions
Before Sampling
• Read all instructions thoroughly as there are multiple sampling
procedures required.
• Remove refrigerant packs from shipping container and place in
freezer. The packs must be frozen before returning samples to the
laboratory.
• Plan to have samples collected just prior to the normal pick-up time
of your overnight carrier.
35
Sampling Instructions
Sampling Steps
1.If your sampling point has a faucet with an aerator, it must be removed prior to
collection of the samples.
2.Flush the cold water sampling line approximately 10 minutes immediately prior to
sampling.
3.Do not touch inside the cap or around the edge of the bottle.
4.Slow the water stream before collection.
5.Refer to the method-specific sampling instructions described below.
6.Indicate sampling date, time, site, and name of sampler on both the bottle labels and
the enclosed Chain of Custody.
7.Information on the Chain of Custody and labels must match and be complete.
8.Caution: Bottles and vials may contain chemical preservatives. Avoid skin contact!
36
Method-Specific Sampling Instructions
UCMR 3 Volatiles – EPA 524.3:
• Fill three vials so that no air
remains when capped.
• Do not overfill. Do not flush away
the preservative.
• After tightening the cap, the vial
should be inverted and tapped to
check for air bubbles.
• If bubbles are present, do not
empty the vial. Slowly add several
additional drops of water until all air
is eliminated.
 3 Amber glass 40 ml vials with Teflonfaced silicone septa in polypropylene
caps.
 Storage temp: <= 10 C first 48 hrs., <= 6
C after 48 hrs.
 Hold Time: 14 days
 Preservative: 20-30 mg ascorbic acid +
180-220 mg maleic acid
37
UCMR 3 Volatiles – EPA 524.3 Field Reagent
Blanks:
• The bottles with the blue label
are Field Reagent Blanks
(FRB).
• DO NOT OPEN in the field.
These field blanks must
remain sealed.
• Return with field sample.
UCMR 3- Method 524.3
Field Reagent Blanks
*DO NOT OPEN
38
UCMR 3 Hexavalent Chromium – EPA 218.7:
• Remove cap, fill the sample
bottle to the neck, then replace
cap and tighten.
Do not overfill. Do not flush
away the preservative.
 1 High density polyethylene (HDPE) 120 ml
bottle, collect 100 ml of sample.
 Storage temp: <= 10 C first 48 hrs., <= 6 C after
48 hrs.
 Hold Time: 14 days
 Preservative: 68.2-73.8 mg solid
Na2CO3/NaHCO3/(NH4)2SO4 buffer mixture
39
UCMR 3 Chlorate – EPA 300.1
Is chlorine dioxide used as part of your disinfection
treatment process?
No
Yes
Use Standard Sampling
Procedures
Use Sparging Procedure
Prior to Sampling
40
UCMR 3 Chlorate – EPA 300.1:
Standard Sampling Procedure
•
Remove cap, fill the sample
bottle to the neck
• Replace cap and tighten. Do
not overfill.
• Do not flush away the
preservative.
 1 Plastic 120 ml bottle
 Storage temp: Ambient
 Hold Time: 28 days
 Preservative: 0.12 ml 5% EDA
41
UCMR 3 Chlorate – EPA 300.1:
Sample Sparging Procedure for Systems Using
Chlorine Dioxide
120 mL plastic labeled sample bottle (prepreserved) plus a 250 mL plastic
unlabeled sparging bottle
42
UCMR 3 Chlorate – EPA 300.1:
Sample Sparging Procedure for Systems Using
Chlorine Dioxide (cont.)
Disposable glass Pasteur pipette
with PVC tubing.
Sparging gas should bean inert gas
such as a lecture bottle of nitrogen or
helium fitted with a regulator.
43
UCMR 3 Chlorate – EPA 300.1:
Sample Sparging Procedure for Systems Using
Chlorine Dioxide (cont.)
• Remove cap from the unlabeled
250 mL plastic bottle and fill
approximately ¾ full with sample
• Insert the pipette and adjust gas
flow to produce a steady flow of
bubbles
• Sparge the sample for
approximately 10-15 minutes. The
chlorine dioxide should be
effectively removed from the
sample.
44
UCMR 3 Chlorate – EPA 300.1:
Sample Sparging Procedure for Systems Using
Chlorine Dioxide (cont.)
• Transfer the sparged sample into the EDA preserved
120 mL bottle filling to the neck of the bottle.
• Replace the cap on the 120 mL bottle and tighten.
• Dispose of any extra sparged sample and its
container.
45
UCMR 3 Metals – EPA 200.8:
• Remove cap, fill the sample bottle to the neck, then replace cap and tighten.
 250 mL Plastic Bottle
 Hold Time: 14 days for unpreserved
samples, 6 months for samples
preserved within 14
days
46
UCMR 3 Metals – EPA 200.8 Field Trip Blank:
• The bottle with the blue label is
a Field Trip Blank (FTB).
• Break the custody seal and
OPEN the bottle.
• Recap the bottle at the
sampling site after collecting
field samples.
• Return with the field sample.
• The custody seal must be
broken.
UCMR 3-200.8
Field Trip Blank
*Open at the
sampling site
*Replace cap and
tighten,
safety seal must be
broken
47
UCMR 3-1,4-Dioxane – EPA 522:
•
Remove cap, fill the sample bottle to
the neck, then replace cap and tighten.
• Do not overfill. Do not flush away the
preservative.
 3 Amber Glass 250 ml bottles with
Teflon lined caps pre-preserved with
20 +/- 2 mg Na2SO3
 1 small vial of 250 +/- 25 mg
NaHSO4 to be added at sampling
 Storage temp: <= 10°C first 48 hrs.,
<= 6°C after 48 hrs. Do not freeze.
 Hold Time: 28 days
•
Cap the bottle and shake vigorously to
dissolve the de-chlorinating agent
sodium sulfite.
•
Uncap the bottle. Add entire contents
of vial of sodium bisulfate preservative
into the sample.
•
Cap the bottle and shake vigorously to
dissolve the preservative.
48
UCMR 3 PFCs – EPA 537:
• Nitrile gloves (provided) MUST
be worn during the sampling
steps.
• Remove cap, fill the sample
bottle to the raised line on the
bottle.
• Replace cap and tighten.
• Do not overfill. Do not flush
away the preservative.
 3 Plastic 250 ml bottles with
polypropylene caps.
 Storage temp: <= 10 C first 48 hrs.,
<= 6 C after 48 hrs.
 Hold Time: 14 days
 Preservative: 1.2-1.3 g Trizma Preset
49
UCMR 3 PFCs – EPA 537 Field Trip Blank:
• The bottle with the blue label is a
Field Trip Blank (FTB).
• Break the custody seal, open the
bottle, and then pour the Field
Trip Blank Water into the empty
bottle with a blue label.
• Return with the field sample.
UCMR 3-537 Field Trip Blank
*Transfer the filled bottle into the
empty FTB bottle
50
UCMR 3 Hormones – EPA 539:
• Nitrile gloves (provided) MUST be worn during the sampling steps.
• Remove cap, fill the sample bottle to the neck, then replace cap and
tighten.
• Do not overfill. Do not flush away the preservative.
 3 Amber Glass 1 L bottles with Teflon
lined caps.
 Storage temp: <= 10 C first 48 hrs.,
 <= 6 C after 48 hrs.
 Hold Time: 28 days
 Preservative: 75-85 mg sodium
thiosulfate + 60-70 mg sodium omadine
51
UCMR 3 Hormones – EPA 539 Field Trip Blank:
• The bottle with the blue label is a
Field Trip Blank (FTB).
• Break the custody seal, open the
bottle, and then pour the Field
Trip Blank into the empty bottle
with a blue label.
• Return with the field sample.
UCMR 3-539 Field Trip Blank
*Transfer the filled bottle into the empty
FTB bottle
52
Sample Shipping Instructions
Shipping Instructions:
• Place frozen refrigerant packs, bags of wet ice, samples and Chain
of Custody into shipping container and return to the laboratory
immediately after collection.
• Sample bottles must be hand delivered or sent by an overnight
carrier.
• Laboratory must be notified prior to shipment of samples for
Saturday delivery.
53
UCMR 3 Distribution Kit
54
Chain Of Custody - DSMRT
55
UCMR 3 List 1 Kit
56
Chain Of Custody – EPTDS List 1
57
UCMR 3 List 1 + List 2 Kit
58
Chain Of Custody – EPTDS List 1 and 2
59
UCMR 3 Collection Video
60
Why is UCMR 3 Testing Expensive?
EPA made assumptions that laboratories would take steps with all field
blanks to ensure that if analysis of any of the blanks becomes
necessary, required holding times would not be exceeded.
These assumptions include:
• All 524.3 field blanks would be analyzed
• All 537 and 539 blanks would be extracted
• EPA’s conservative assumption that all 537 and 539 Field Blanks will be
extracted
• Extraction is only part of the process, it only covers a portion of the
total cost if a sample does end up requiring analysis such as
• Costs associated with additional analytical batches
• Additional staff salaries for analysis, peer review, client notifications,
report generation, and reporting to the client and SDWARS
61
Why is UCMR 3 Testing Expensive? (cont.)
Parameter
CAS #
Number of
Finished Water
samples
Analyzed
Number of
Detects >
UCMR3 MRL
UCMR3 MRL
% w/ Detects >MRL
Chromium
7440-47-3
16269
12441
0.2 ug/L
76%
Cobalt
7440-48-4
7949
516
1.0 ug/L
6%
Molybdenum 7439-98-7
8232
4221
1.0 ug/L
51%
Strontium
7440-24-6
9427
9049
0.3 ug/L
96%
Vanadium
7440-62-2
8809
4996
0.2 ug/L
57%
• 200.8 Field Blanks were NOT mentioned in EPA’s cost assumptions.
• Based on a high rate of occurrence as illustrated in the table above,
expect field blanks for 200.8 to require analysis.
• A Field Blank that requires analysis is not different than a field sample
and cost the laboratory the same amount to analyze.
• Assuming a PWS has just 1 EPTDS and 1 DSMRT, this makes four
analyses
62
UCMR 3 Costs - Budgeting & Planning
There is no doubt that UCMR 3 is an inexpensive regulation. There are,
however, a few things that you can do to spread the cost out and
minimize the potential for additional costs.
• Adjust your schedule in SDWARS so collections fall over 2 fiscal years
instead of 1
• 12 consecutive months does not mean those twelve months must be in
the same calendar year
• If you are required to perform Assessment Monitoring (List 1), a SW
supply can collect the last two quarters of one year and the first two of the
next year
• If you are required to perform Screening Survey monitoring, you could
collect all of your List 1 samples in one year and all of your List 2 samples
in the next year
• Memorize the Field Blank protocols, this will reduce the likelihood of
contamination during collection and potentially avoid additional laboratory
fees (some may bill all or a percentage for sample and Field Blank
analysis if it is invalid due to contamination during collection)
63
Questions?
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