United States Office of Solid Waste and EPA-542-F-01-030a

Environmental Protection Emergency Response April 2001

Agency (5102G) www.epa.gov/tio

www.cluin.org

Improving Sampling, Analysis, and Data

Management for Site Investigation and Cleanup

The United States Environmental Protection Agency (EPA) supports the adoption of streamlined

approaches to sampling, analysis, and data management activities conducted during site assessment,

characterization, and cleanup. This position reflects the growing trend towards using smarter, faster,

and better technologies and work strategies. EPA is coordinating with other Federal and State agencies

to educate regulators, practitioners, site owners, and others involved in site cleanup decisions about the

benefits of a streamlined approach. Ultimately, EPA expects to institutionalize these newer approaches

and anticipates that the principles will guide the way data are collected and analyzed for future site

cleanup decisions.

The Approach

The trend towards modernization and streamlining relies on a three-pronged or “triad”

approach. It incorporates:

 Systematic planning for all site activities,

ensuring that the end goals for each project are

clearly identified. Once goals are defined,

systematic planning involves charting the most

resource-effective course to reach those end

goals. A team of multi-disciplinary, experienced

technical staff works to translate the project’s

goals into realistic technical objectives. The

conceptual site model (CSM) is the planning

tool that organizes what is already known about

the site and helps the team identify what more

must be known to make the decisions that will

achieve the project’s goals. The systematic

planning process ties project goals to individual

activities necessary to reach these goals by

identifying data gaps in the CSM. The team

then uses the CSM to direct field work and the

gathering of needed information. This process

allows the CSM to evolve and mature as site

work progresses and data gaps are filled. The

CSM is the key organizing tool for:

 Planning site activities,

 Modeling and data interpretation, and

 Communication among the team, the

decision makers, the stakeholders, and

the field personnel.

 The application of a dynamic work plan

guides project teams in making decisions in

the field about how subsequent site activities

will progress. It uses a regulator-approved (as

necessary) decision-tree, and is supported by

the rapid turnaround of data collected, analyzed, and interpreted in the field. Success of

the “dynamic” approach hinges on the presence

of experienced staff in the field, who are empowered to “call the shots” based on the decision logic developed during the planning stage

and to cope with any unanticipated issues.

Field staff maintain close communication with

regulators or others overseeing the project

during implementation of the dynamic work

plan.

 The use of on-site analytical tools, rapid

sampling platforms (e.g., direct push technologies), and on-site data interpretation

The “Triad”

On-Site Measurement Technologies

Systematic

Planning

Dynamic

Work Plans
and management makes dynamic work plans

possible. During the planning process, the

team identifies the type, rigor, and quantity of

data needed to answer the questions raised by

the CSM. Those decisions then guide the

design of sampling regimens and the selection

of analytical tools and methods to focus data

collection on providing relevant information.

Figure 1 illustrates the iterative and interlinked

nature of projects managed using this dynamic

work strategy. The decision rules developed

during systematic planning and built into the

CSM serve as the foundation for evaluating all

proposed and implemented project activities.

Occasionally, decision makers will discover that

the original project objectives cannot be met

due to technical or budgetary constraints, and

pragmatic refinement of the decision rules may

be needed.

Supporting Developments

Faster, cheaper, yet still protective, resolution of

contaminated sites is achievable through the

use of new technologies and the new strategies

those technologies can support. If used correctly, innovative rapid-turnaround field analytical and software tools coupled with on-site

decision making can significantly condense a

project’s overall budget and lifetime, while

significantly increasing the likelihood that the

gathered data will guide transparent decisions.

Site professionals, policy makers, and the

public should support the flexibility needed to

adopt cost-effective new tools and strategies

into site cleanup practice provided that clearly

defined performance goals are achieved.

The specific developments driving the trend

towards modernization and streamlining

include:

1) Field analytical chemistry has made significant advances in scientific rigor and credibility. Computerization, photonics, miniaturization, immunochemistry, and a host of other

advances in the chemical, biological, and

physical science disciplines are contributing

to technology improvements and innovations.

2) Successes with improved strategies such as

Expedited Site Characterization, Accelerated

Site Characterization, Rapid or Adaptive Site

Characterization, and Dynamic Workplanning

are demonstrating just how cost-effective

these strategies can be.

3) Regulatory policies are now focusing more

on achieving tangible end-results. For example, EPA and other agencies support

performance-based measurement systems

(PBMS) as a preferred alternative to rigidly

prescribing which analytical tools are used

and how. PBMS improves the cost-effectiveness and scientific defensibility of environmental analyses by emphasizing the information and decision-making value of a representative data set and by requiring that data

quality be matched to its planned use. PBMS

principles support the use of field analytical

technologies to meet the specified project

needs and decision goals.

4) Better decision-making tools (i.e., computer

software and hardware) are available that

facilitate efficient and effective data management, interpretation, and decision making as

the data are collected and analyzed. This

allows mapping and modeling of contaminants and maturation of the conceptual site

model on-site. The project team can incorporate data, modify site characterization activities, and hone cleanup decisions to minimize

the number of field mobilizations.

5) Modern communication technologies mean

that the field team is no longer isolated from

regulators, technical experts, site owners, and

trustees. New information can be shared

instantly among parties, and regulator buy-in

and technical support can be obtained from

remote locations.

6) Evolving emphases in environmental programs [such as Brownfields, State

Voluntary Clean-Up Programs (VCPs), and

Base Realignment and Closure (BRAC) at

military facilities] focus site activities on how

the site will be redeveloped or reused. Flexible cleanup goals [such as risk-based corrective action (RBCA) levels] support faster

return of these sites to productive re-use.

When cleanup and end-use goals are articulated at the start, systematic planning can

ensure a cost-effective work plan that

achieves the desired outcome.

7)Increasing workloads and decreasing budgets have forced regulators and industry to

consider innovative strategies that can increase public confidence and satisfaction by

reducing uncertainties (about any threats the

site may pose) while reducing the time and

costs involved in cleaning up these sites.

Tools for Change

To accomplish change, the remediation industry

and regulators should move towards a more

innovation-friendly system that can produce

defensible site decisions at an affordable cost.

Such a system would:

Focus on decision-specific performance

requirements, rather than inflexible adherence to arbitrary policies or “boiler-plate”

procedural checklists that do not add value or

provide beneficial results.

Employ transparent and logical reasoning

to define project goals, manage uncertainties, state assumptions, plan site activities,

derive conclusions, and prepare defensible

decisions.

Value technical and scientific proficiency, and

understand the need for technical experts

in the scientific, mathematical, and engineering disciplines required to competently

manage the complex issues of hazardous

waste sites.

Require regular continuing education of its

practitioners, especially in rapidly evolving

technology areas.

Facilitate application of innovative technologies and strategies by logically evaluating project-specific needs, site conditions,

and prior technology performance, with

residual areas of uncertainty being identified

and addressed before use.

Reward responsible risk taking by practitioners who do not fear to ask, “why don’t we

look into...?” or “what if we tried...?”

Pockets of forward-thinking practitioners are

already successfully using and demonstrating

the validity of the triad approach described

above. This fact sheet and the tools referenced

below are offered to encourage project managers at-large to adopt this approach into their

routine practice.

EPA, along with a number of other Federal

agencies and state organizations, is accelerating the development of policies and information to support site decision makers as they

shift to newer, streamlined approaches. An

array of educational, training, and guidance

resources already exist and additional ones are

under development. Access to these resources

is provided through the http://clu-in.org web site

and are detailed in the companion fact sheet,

Resources for Strategic Site Investigation

and Monitoring, EPA-542-F01-030b.

Updating hazardous waste site practices to

accommodate these new tools and strategies

has broad ramifications for both practice and

policy. Revising institutional and regulatory

barriers will take time and effort. Nevertheless,

the benefits offered by “smarter strategies”

make the effort worthwhile.