Department of Health Seal

TGM for the Implementation of the Hawai'i State Contingency Plan
Section 3.6
SAMPLING AND ANALYSIS PLANS

3.6 SAMPLING AND ANALYSIS PLANS

The Sampling and Analysis Plan (SAP), developed during Step 6 of systematic planning, specifies the final design and configuration of the environmental measurement effort required to resolve issues and questions stated in the systematic planning steps (Steps 1- 5). The SAP is a comprehensive document that would enable an experienced field sampling team unfamiliar with the site to come in and examine the site and collect the required samples and field information. The SAP designates the types and quantities of samples or monitoring information to be collected; where, when and under what conditions they should be collected; the variables to be measured; and the Quality Assurance/Quality Control (QA/QC) procedures to ensure that sampling design and measurement errors meet the tolerable decision error specified.

The QA/QC procedures are described within the Quality Assurance Project Plan (QAPP), which is included within the SAP. The site-specific Health and Safety Plan is also included as part of the overall SAP (alternately, the Health and Safety Plan can be presented with the SAP in a site Work Plan). The SAP must be flexible and dynamic to deal with unexpected discoveries or circumstances that may be encountered during the site investigation. To ensure appropriate characterization of the site and to minimize the need to perform additional sampling, it is recommended that SAPs be reviewed and approved by the HEER Office. In addition, it is important to consult with the laboratory while developing the SAP to ensure objectives are in alignment with chosen laboratory practices, and to provide contingencies for matrix problems that may occur. Important among such issues to discuss with the laboratory are expectations for storing remaining portions of MI samples that have been analyzed, until site sampling decisions are completed. Based on initial data analysis or new information, additional analyses may be conducted from stored bulk MI samples rather than having to mobilize and collect additional samples in the field.

The suggested outline for the SAP is as follows:

  1. Introduction
  2. Site Background
    1. Site description
    2. Site characteristics
  3. Investigation History
  4. Site Investigation Objectives
  5. Scope of Work
  1. Description of Sampling Activities
  2. Analytical Methods
  3. Quality Assurance Project Plan
  4. Documentation and Reporting
  5. Schedule
  6. Health and Safety Plan
  7. References

More detailed information regarding the outline, format, and required content of the SAP is presented in Section 18.

3.6.1 SAMPLE COLLECTION STRATEGY

A sampling strategy should reflect the approach that will best meet investigation objectives within acceptable uncertainty limits, with consideration taken for efficient use of time, money, and human resources. Section 4 discuses sample collection strategies for soil and sediment.

Sample collection for soils generally falls under two main categories: Multi Increment samples and discrete samples (see Section 4):

  • The HEER Office strongly encourages the use of Multi Increment/Decision Unit strategies to investigate contaminated soil. Multi Increment samples are collected using a probabilistic sampling theory and involve the collection of a large number of increments (30-100) from within the target DU. Each increment is made up of approximately 5 to 50 grams of soil. The increments are combined to form a single, Multi Increment sample for the DU. A detailed discussion of Multi Increment sampling approaches is provided in Section 4.
  • Discrete samples (i.e., samples typically consisting of only one increment) are collected using either random or biased sample point locations based on professional judgment. In some cases, groups of discrete samples are combined for analyses. A small number of discrete samples are typically not representative of average contaminant levels in a specific DU as are Multi Increment samples, and therefore not recommended in most cases. Discrete sample data can, however, prove useful at the early stages of a site investigation, especially when available from previous studies. This includes screening sites for the presence of large spill areas not obvious in the field, and providing data to help select DU boundaries for collection of more detailed Multi Increment samples (see Section 4.3).

See Section 6 for sample collection strategies for groundwater, and Section 13 for information and references regarding ecological risk evaluations.

Information regarding sampling design is also available in USEPA’s Guidance on Choosing a Sampling Design for Environmental Data Collection (USEPA, 2002f), although the guidance focuses on the collection of discrete samples. Software is available to assist in designing a sampling strategy, although again, they are primarily applicable to discrete sampling approaches. One example is Visual Sample Plan [VSP] software available from Pacific Northwest National Laboratory (PNNL, 2005).

3.6.2 SAMPLING COLLECTION METHODS

After the sampling design is determined, sampling methods are selected to facilitate the sampling design. Sampling methods are specific to the sampling design and the needs of the site and are selected to meet requirements of the site investigation objectives and associated DQO.

Sampling design approaches are discussed in Section 4.Sampling soil DUs at depth typically involves additional time and resources compared to DUs for surface soil (refer to Subsection 3.4.4 and Section 4). Several sampling approaches might be useful for a given site. Sampling method procedural guidance for soil and sediment, groundwater and surface water, and soil vapor and indoor air is presented in Sections 5, 6, and 7, respectively. The application of Decision Unit approaches is recommended for characterization of sediment and surface water as well as soil.

3.6.3 HEALTH AND SAFETY PLANS

Hawai’i hazardous substance release sites fall under the definition of "uncontrolled hazardous waste sites" pursuant to Occupational Safety and Health Administration (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) Title 29 Code of Federal Regulations (CFR) Section 1910.120(a)(1). A health and safety plan (HASP) is required under Title 29 of the Code of Federal Regulations, Section 1910.120 (Hazardous Waste Operations and Emergency Response), which includes a requirement for a hazard communication program meeting the requirements of 29 CFR 1910.1200. Like rules were adopted under Hawai’i Administrative Rules (HAR) Title 12, Chapters 60 and 203.1, Division of Occupational Safety and Health Standards. The Health and Safety plan is typically a part of the SAP (or alternately, part of the site Work Plan). The HEER Office recommends that an employer develop a written Health and Safety Plan, which includes the following elements:

  • An organizational structure
  • A comprehensive work plan
  • A site-specific health and safety plan
  • A health and safety training program
  • A medical surveillance program
  • Standard operating procedures for health and safety
  • Any necessary interface between general program and site-specific activities

The OSHA HAZWOPER Standard, Title 29 CFR 1910.120, requires that personnel working in and around hazardous waste have a site-specific HASP and competent safety officers to enforce health and safety rules. OSHA has determined that employees must be trained if they work in proximity to hazardous chemicals with a potential for release or substantial threats of release, without regard to the location of the hazard.

An OSHA-certified 40-hour class focusing on HAZWOPER training is required for those who are performing regular work on hazardous waste sites; an annual 8-hour refresher course is required to maintain the certification achieved through this training. An OSHA-certified 24-hour course is required for those who have occasional exposure to hazardous waste. In addition, an 8-hour course is required for supervisors and management personnel who oversee hazardous waste projects. The amount of training required is contingent upon an employee’s responsibilities and involvement with hazardous materials; these must be clearly established by the employer and communicated to the employee(s). The HEER Office does not approve Health and Safety Plans, but does require that one be in place for field activities at hazardous chemical release (or suspect release) sites. Contact the Hawai`i Division of Occupational Safety and Health (HIOSH) for detailed information on HASPs and organizations offering HAZWOPER training.