June 2003

Using the Triad Approach to Streamline Brownfields

Site Assessment and Cleanup –

Brownfields Technology Primer Series

U.S. Environmental Protection Agency

Office of Solid Waste and Emergency Response

Brownfields Technology Support Center

Washington, DC 20460
NOTICE AND DISCLAIMER

This primer was prepared by the United States Environmental Protection Agency’s (EPA) Office of Solid

Waste and Emergency Response under EPA Contract 68-W-02-034. The information in this primer is not

intended to revise or update EPA policy or guidance on how to investigate or cleanup Brownfields or

other revitalization sites. Mention of trade names or commercial products does not constitute

endorsement or recommendation for use.

This document can be obtained from EPA’s Brownfields Technology Support Center at

http://www.brownfieldstsc.org. A limited number of hard copies of this document is available free of

charge by mail from EPA’s National Service Center for Environmental Publications at the following

address (please allow 4-6 weeks for delivery):

U.S. EPA/National Service Center for Environmental Publications

P.O. Box 42419

Cincinnati, OH 45242

Phone: (513) 489-8190 or (800) 490-9198

Fax: (513) 489-8695
Using the Triad Approach to Streamline Brownfields Site Assessment and Cleanup

U.S. Environmental Protection Agency

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TABLE OF CONTENTS

Section Page

1.0 INTRODUCTION ......................................................................................................................... 1

1.1 PURPOSE ......................................................................................................................... 1

1.2 BACKGROUND .............................................................................................................. 2

1.3 ORGANIZATION ............................................................................................................ 3

2.0 THE TRIAD APPROACH ............................................................................................................ 4

2.1 SYSTEMATIC PROJECT PLANNING .......................................................................... 5

2.2 DYNAMIC WORK PLAN STRATEGIES .................................................................... 18

2.3 REAL-TIME MEASUREMENT TECHNOLOGIES ..................................................... 20

3.0 PROJECT MANAGEMENT AND PROCUREMENT CONSIDERATIONS ........................... 23

3.1 PROJECT MANAGEMENT .......................................................................................... 23

3.2 PROCUREMENT ISSUES ............................................................................................. 25

3.3 MANAGEMENT TOOLS .............................................................................................. 26

4.0 SUMMARY ................................................................................................................................. 29

TABLES

Table Page

1 Data Gaps and Tools to Manage Uncertainty ................................................................................. 6

FIGURES

Figure Page

1 The Triad Approach ....................................................................................................................... 2

2 Understanding the Context of Cleanup .......................................................................................... 5

3 Employing the Triad Approach .................................................................................................... 10

4 Life Cycle of a Conceptual Site Model ........................................................................................ 11

5 CSM of Example Pathway Receptor Networks ........................................................................... 16

6 Example of CSMs for Urban Soil Contamination ........................................................................ 17

Appendices

A FREQUENTLY ASKED QUESTIONS (FAQ) WHEN DESIGNING A PROGRAM USING

THE TRIAD APPROACH

B LIST OF ACRONYMS

C LIST OF RESOURCES

D DESCRIPTIONS OF COMMONLY USED FIELD-BASED SAMPLING AND ANALYTICAL

TECHNOLOGIES
Using the Triad Approach to Streamline Brownfields Site Assessment and Cleanup

U.S. Environmental Protection Agency

Office of Solid Waste and Emergency Response

Brownfields Technology Support Center 1

Brownfields Technology Support Center

EPA established the Brownfields Technology Support Center (BTSC) to ensure that brownfields decisionmakers are aware of the full range of technologies available for conducting site assessments and cleanup, and

can make informed decisions about their sites. The center can help decision makers evaluate strategies to

streamline the site assessment and cleanup process, identify and review information about complex technology

options, evaluate contractor capabilities and recommendations, explain complex technologies to communities,

and plan technology demonstrations. The center is coordinated through EPA’s Technology Innovation Office

(TIO) and offers access to experts from EPA’s Office of Research and Development (ORD) and other Federal

agencies such as the Department of Defense (DoD) and the Department of Energy (DOE). Localities can submit

requests for assistance directly through their EPA Regional Brownfields Coordinators; online at

brownfieldstsc.org; or by calling toll free 1-877-838-7220. For more information about the program, contact

Dan Powell of EPA TIO at 703-603-7196 or powell.dan@epa.gov. Contact information for Regional

Brownfields Coordinators can be found at www.epa.gov/brownfields/contacts.htm.

Other publications developed through the BTSC:

• Brownfields Technology Primer: Selecting and Using Phytoremediation for Site Cleanup 

• Brownfields Technology Primer: Requesting and Evaluating Proposals That Encourage Innovative

Technologies for Investigation and Cleanup

• Road Map to Understanding Innovative Technology Options for Brownfields Investigation and Cleanup,

Third Edition 

• Assessing Contractor Capabilities for Streamlined Site Investigations 

• Directory of Technology Support Services to Brownfields Localities

Primers currently under development:

• Brownfields Technology Primer: Perspectives on Technology Selection and Use

• Directory of Technical Assistance for Land Revitalization

• Understanding Procurement for Innovative Sampling and Analytical Services for Waste Site Cleanup

1.0 INTRODUCTION

1.1 PURPOSE

The U.S. Environmental Protection Agency (EPA) Brownfields Technology Support Center (BTSC) has

prepared this document to provide an educational tool for site owners, project managers, and regulators to

help streamline assessment and cleanup activities at brownfields sites. Strategies that reduce costs,

decrease time frames, and positively affect regulatory and community acceptance also can improve the

economics of redevelopment at brownfields sites. Increased attention to brownfields sites and the manner

in which they are redeveloped places greater importance on the approach to site cleanup. This primer is

one in a series that will address specific cleanup issues.
Using the Triad Approach to Streamline Brownfields Site Assessment and Cleanup

U.S. Environmental Protection Agency

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Brownfields Technology Support Center 2

The Brownfields Revitalization and

Environmental Restoration Act of 2001 defines

a “brownfield site” as real property, the

expansion, redevelopment, or reuse of which

may be complicated by the presence or potential

presence of a hazardous substance, pollutant, or

contaminant.

A Systems Approach Framework A Systems Approach Framework

The Triad Approach The Triad Approach

Systematic

Project

Planning

Dynamic

Work Plan

Strategies

Real-time Measurement

Technologies

Uncertainty

Management

Figure 1. The Triad Approach

1.2 BACKGROUND

Since its inception in 1995, EPA’s Brownfields

Initiative has grown into a major national program that

has changed the way contaminated property is

perceived, addressed, and managed in the United

States. In addition, over time, there has been a shift

within EPA and other environmental organizations in

the way that hazardous waste sites are cleaned up. Historically, sites have largely been cleaned up using a

relatively standard approach to “command and control” the cleanup process . This approach was

developed for dealing with the most heavily contaminated and hazardous sites and often did not (or could

not due to specific long-term issues) consider the ultimate end use of a property, and could be both costly

and lengthy. More recently, regulators and site managers are increasingly recognizing the value of

implementing a more dynamic approach to

site cleanup that is flexible and recognizes

site-specific decisions and data needs and can

reduce costs, improve decision certainty, and

expedite site closeout. As shown in Figure 1,

this new approach relies on a three-pronged

or Triad approach that focuses on the

management of decision uncertainty by

incorporating: (1) systematic project

planning, (2) dynamic work plan strategies,

and (3) the use of real-time measurement

technologies to accelerate and improve the

cleanup process.

EPA has shown its support for the adoption of streamlined approaches to sampling, analysis, data

reviews, and evaluations conducted during site assessment, characterization, and cleanup through a

number of activities, including technical and guidance documents. As part of these activities, EPA has

been coordinating with many Federal and state agencies to educate regulators, practitioners, site owners,

and others involved in site cleanup decisions about the benefits of a streamlined approach.
Using the Triad Approach to Streamline Brownfields Site Assessment and Cleanup

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Brownfields sites are well suited to using the Triad approach, where limited funding and intended reuse

strongly influence cleanup. Inherent in the Triad approach is the need for cooperation and collaboration

among the many stakeholders in the process. A goal of the Brownfields Initiative is to enable states and

communities to work together to assess, safely cleanup, and sustainably reuse brownfields sites,

consistent with EPA’s emphasis on future use, including engineering and land use controls.

Both the Triad approach and the Brownfields Initiative mutually reinforce each other through a common

sense approach where barriers are removed and dollars are leveraged to provide the most cost-effective

and streamlined approach to monitoring and measurement activities. Use of real-time measurements,

including real-time measurement technologies, combined with a rigorous planning process to understand

and control sources of uncertainty, is inherent to the Triad approach and helps stakeholders improve the

reliability of risk-related decisions.

1.3 ORGANIZATION

The primer is organized into three sections, including this introduction. Section 2 describes the three

elements of the Triad approach, and provides examples of using each element. Section 3 discusses the

role of the technical team in managing a project, procurement considerations when planning a project, and

decision-support software and other tools that are available to help brownfields site managers.

In addition, this primer includes the following appendices:

• Appendix A – Frequently asked questions (FAQ)

• Appendix B – List of acronyms

• Appendix C – List of resources

• Appendix D – Descriptions of commonly used field-based sampling and analytical technologies
Using the Triad Approach to Streamline Brownfields Site Assessment and Cleanup

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Selected Triad Resources

Listed below are useful resource materials about the Triad approach. For more information on these resources

and references to additional material, please see Appendix C.

Each document listed below can be found at the CLU-IN Internet Site at http://cluin.org/triad/:

• Innovations in Site Characterization Case Study: Site Cleanup of the Wenatchee Tree Fruit Test Pilot Site

Using a Dynamic Work Plan

• Using the Triad Approach to Improve the Cost-Effectiveness of Hazardous Waste Site Cleanups

• Improving Sampling, Analysis, and Data Management for Site Investigation and Cleanup Sheet (Fact Sheet)

(EPA 542-F-01-030a)

• Resources for Strategic Site Investigation and Monitoring (Fact Sheet) (EPA 542-F-01-030b)

• A Dynamic Site Investigation: Adaptive Sampling and Analysis Program for Operable Unit 1 at Hanscom

Air Force Base, Bedford, Massachusetts

Related Internet sites include:

EPA’s Dynamic Field Activities Internet Site: http://www.epa.gov/superfund/programs/dfa/index.htm

EPA’s Field Analytical Technologies Encyclopedia: http://fate.cluin.org

Note: Web addresses are current through 6/16/03

2.0 THE TRIAD APPROACH

The keystone concept of the Triad approach is the identification and management of those unknowns (i.e.,

uncertainties) that could cause excessive or intolerable errors in decision-making. An example of such a

decision error would be to declare a site "clean" for redevelopment to proceed because contamination that

would have been treated or removed prior to redevelopment was missed during sampling. The Triad

minimizes the likelihood of mistakes by cost-effectively supporting the development of an accurate

conceptual site model (CSM). CSMs are discussed in detail in Section 2.1. Briefly, a CSM is any

graphical or written representation (or "conceptualization") of site contamination concerns: how it got

there, whether or not it is migrating or degrading, how variable concentrations are across the site, what

receptors might be exposed, and what risk-reduction strategies are most feasible. An accurate CSM is a

primary work product of the Triad approach that is refined and matured over the course of an

investigation. To develop an accurate CSM, the Triad approach incorporates the elements of systematic

project planning, dynamic work plan strategies, and real-time measurement technologies into a decision

support matrix designed to manage uncertainties associated with environmental restoration projects. 

Selected Triad resources are identified below.
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Reuse Plans and Goals

Site Decisions:

• Clean-up goals

• Tolerable decision uncertainty

• Data (type, quality)

Approaches to:

• Assessment

• Investigation

• Cleanup Design and 

Implementation

• Closeout, Long-Term Operations, 

and Maintenance

Tools for:

• Sampling and Analysis

• Cleanup/Remediation

3⁄4Containment

3⁄4Cleanup

3⁄4Controls

• Monitoring and maintenance 

Drive

Determine

Understanding the Context of Cleanup

Reuse Plans and Goals

Site Decisions:

• Clean-up goals

• Tolerable decision uncertainty

• Data (type, quality)

Approaches to:

• Assessment

• Investigation

• Cleanup Design and 

Implementation

• Closeout, Long-Term Operations, 

and Maintenance

Tools for:

• Sampling and Analysis

• Cleanup/Remediation

3⁄4Containment

3⁄4Cleanup

3⁄4Controls

• Monitoring and maintenance 

Drive

Determine

Understanding the Context of Cleanup

Figure 2. Understanding the Context of Cleanup

The Triad approach is applicable to many elements of monitoring and measurement activities that occur

on site - from early investigations aimed at risk estimation, through designing, implementing, and

monitoring the implementation of a remedy. The key to the Triad approach and its benefits to

brownfields sites is that decisions are not made in a vacuum, but with the full consideration of existing

information developed during past site use and cleanup activities, and with a thorough understanding of

how the site might be reused. Using this approach, activities are performed that target the principal

sources of uncertainty that can affect the confidence of site decisions. Use of the Triad approach at

brownfields sites allows decision-makers to economically collect the volume and quality of data

necessary to reassure regulators and communities that a property is safe for reuse.

Figure 2 summarizes the interaction between

reuse plans and goals, site decisions, and

sampling and analysis approaches and tools. 

As shown, these approaches are interdependent. Unlike the Triad approach, a

traditional one-size-fits-all approach leads to

predetermined strategies and cleanup tools

and does not generally consider the interdependence of reuse plans and goals with a

cleanup approach.

The three elements of the Triad approach are discussed in more detail below.

2.1 SYSTEMATIC PROJECT PLANNING

In the context of contaminated site cleanup, systematic project planning is a transparent, deliberate, and

coordinated effort to identify and manage factors and issues that contribute to decision uncertainty (those

unknowns that could contribute to decision errors).

During systematic project planning, factors and variables that may impact the design and execution of

project activities should be identified so that cost-effective strategies to manage those factors (or manage

around them) can be developed. Drawing on previous personal experience and institutional knowledge, a

project manager should try to anticipate issues that may adversely impact the project. Factors that may be
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important to systematic planning (depending on the particulars of the site and the project) include budget

(including contracting mechanisms), schedule (time frames) and other resources (including the

availability of staff and support personnel, the state of scientific and technical knowledge, and the

availability of technology/equipment), as well as regulatory and programmatic requirements. For some

sites, political and media interest, local community health and economic concerns, and broader health and

economic considerations can have a large impact on the design and flow of site activities.

Of the three elements of the Triad approach, the systematic planning component is the most important and

the most universally applicable. Regardless of the type of site and strategy chosen for data collection,

decision-makers should engage in systematic planning to tie the data collection to site decisions. It is the

basis for creating a defensible approach and a scientifically sound data set. A thorough and systematic

planning effort will help determine if and where field technologies can be used. Systematic planning

helps determine if and how a dynamic implementation approach makes sense at a site and it establishes

the framework to ensure that the data collected are sufficient for site needs. The emphasis on a thorough

planning process is essential to achieving the savings (time and cost) that are possible with the Triad

approach and achieving the defensibility and confidence in site decisions. Some examples of the types of

data gaps and the tools used to manage uncertainty in the systematic planning process are shown in

Table 1.

Table 1. Data Gaps and Tools to Manage Uncertainty

Portion of the Cleanup

Process

Types of Data and/or Information Gaps

Typically Identified 

Tools to Address Filling Data Gaps 

and Managing Uncertainty

Early on and throughout the

project as more is learned

and decisions change 

• What are the potential environmental issues

at the site?

• What are the potentially impacted media and

potential receptors?

• What are the planned reuse and political

status? 

• What is the economic viability of cleanup?

• Who are the responsible party and regulating

authority?

• Historical records, depositions, and visual inspections

• Site location, historical photos, geological information

• Public and other stakeholders

• Cost benefit analyses 

• Record searches

• Depositions

• Operational history

Investigations • What is the nature and extent of regulated

chemical contaminants?

• Analytical chemistry methods

• Sampling designs

• Sample collection equipment

• Classical statistical models to estimate contaminant

concentrations 

• Geostatistical models to define contaminant populations

• Contaminant distribution maps

• What is the estimated fate and transport of

contaminants?

Geological measurements

• Hydrogeological measurements

• Geophysical measurements

• Modeling
Table 1.  Data Gaps and Tools to Manage Uncertainty (continued)

Using the Triad Approach to Streamline Brownfields Site Assessment and Cleanup

Portion of the Cleanup

Process

Types of Data and/or Information Gaps

Typically Identified

Tools to Address Filling Data Gaps

and Managing Uncertainty

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Investigations (continued) • Are exposure pathways complete? • Analytical chemistry methods

• Sampling designs

• Geological measurements

• Hydrogeological measurements

• Geophysical measurements

• Air release measurements

• Sampling and analysis data

• What are the appropriate cleanup levels for

the site? 

• Toxicological information

• Existing regulations

• Exposure scenarios

• Future use

• Are reporting limits above the potential

action levels?

• Analytical chemistry methods

• Method modifications

• Risk data

Investigations and cleanup

actions

• Is there sufficient data to support site

closure?

• Statistical data

• Modeling

• Existing data

Remedy designs and

cleanups

• What data are needed to support

implementation of potential remedies at the

site

• Information concerning available remedies

• Nature and extent data

• Engineering considerations

• Land use controls

Remedy design • Do viable treatment or containment

technologies or other alternatives exist?

• Vendor cost and performance information

• Case studies

Remedy implementation • What is the preferred alternative?

• What data are needed to evaluate remedy

effectiveness, including need for source

removal?

• How can closure be documented?

• Pilot studies

• Engineering designs

• Statistical evaluations

• Operational data

• Confirmation sampling results

• Engineering/land use controls

Operations and

maintenance

• How can system performance be optimized

and operating costs reduced?

• Chemical and engineering data

• Cost-effectiveness evaluation

To Learn More about Systematic Project Planning

The Marino Scrap Yard site in the Borough of Rochester, Pennsylvania, is using the Triad approach for

streamlining site assessment and cleanup. The city is considering reuse of this site. However, there are

concerns about contamination of shallow soils with lead, mercury, and polychlorinated biphenyls (PCBs). The

BTSC has provided support to the city for this site, including: (1) tools and methods used to develop a

conceptual site model for contamination at the site; (2) pathway analysis and risk estimation; (3) development

of a dynamic work plan strategy; (4) requirements for the use and control of field-based technologies to limit

decision uncertainty; (5) procurement approaches and costing methods in support of Triad type projects; and

(6) the key elements of systematic planning for reuse at the site. The conceptual site model developed by the

BTSC, the dynamic work plan strategy, and statement of work can be found at brownfieldstsc.org.

Under the Triad approach, decision-makers may need to expend a greater amount of time and energy on

up-front planning than is commonly needed under a more traditional approach, including adequate time to

plan for project schedules and resources. However, this up-front planning effort will reduce the
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Decision Quality

The term “decision quality,” in its broadest sense, implies that decisions are defensible. Ideally, decision quality

would be equivalent to the correctness of a decision. However, in the environmental field, decision correctness is

often unknown (and perhaps unknowable) at the time of decision-making. "Correct" decisions are those that

would be made if project decision-makers possessed complete and accurate knowledge about site contamination. 

When knowledge is limited, decision quality hinges on whether the decision can be defended against reasonable

challenge in whatever venue it is contested, be it scientific, legal, or otherwise. Scientific defensibility requires

that conclusions drawn from scientific data do not extrapolate beyond the available evidence. If scientific

evidence is insufficient or conflicting, decision defensibility may rest properly on other considerations. No matter

what those considerations are, “defensibility” implies there is honest and open acknowledgment of the full range

of uncertainties impacting the decision-making process. Systematic planning may identify a number of ways to

manage decision uncertainty. For regulatory programs seeking to use sound science as the basis for defensible

decision-making, then the uncertainty involved in generating and interpreting scientific data will have to be

addressed and managed. The Triad approach makes it cost-effective to do so. [EPA’s Office of Solid Waste and

Emergency Response (OSWER) policy states that sound science must underscore all OSWER regulatory, policy,

and programmatic decisions.]

uncertainty and increase the efficiency of activities while crews are in the field. Conversely, insufficient

planning often can lead to cost overruns, extended project time frames, and confusion over data. In

addition, users of the Triad approach need to devote adequate time for procuring and conducting site

work. 

What is meant by systematic planning? Systematic planning is a common-sense approach to help

ensure that the level of information gathered will facilitate the decision-making process required to reach

site redevelopment objectives. An important component of systematic planning is to identify decision

end-points and estimate acceptable levels of uncertainty for the decisions that need to be made at a site

(see box on decision quality). The rigor of the techniques used to collect and analyze data should match

the intended use. For example, data used for waste segregation prior to final characterization often can be

of lesser analytical rigor. Money saved on analytical costs can be used to manage other critical aspects of

data quality, such as improving sampling representativeness and the accuracy of the CSM by taking

greater numbers of samples. Confirmation of the presence or absence of specific contaminants on a few

samples of known representativeness may require highly accurate, analyte-specific analytical techniques.

While the use of real-time measurement is a key component of maximizing information value while

minimizing costs, decision-makers should ultimately focus on the best analytical and sampling strategy

for conducting an investigation. This will often involve "mixing and matching" various sampling and

analytical techniques. Detailed systematic planning encourages project managers to consider the use of
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field-based technologies or quick turnaround fixed

laboratory analyses to support timely decisionmaking. Decisions made on a timely basis (daily or

weekly) help ensure that project decision points are

reached in as few mobilizations as possible, and

that project technical staff optimize the efficiency

of a sampling or cleanup design, which is one of

the biggest advantages of using the Triad approach.

Systematic planning is undertaken to chart a course

for the project that is both cost-effective and

technically sound and defensible, attaining the

appropriate decision quality based on “sound

science.” A primary goal of the Triad approach is a

CSM that can be used to support correct decisions.

The Conceptual Site Model

The CSM is the one of the primary planning tools used in systematic project planning. The CSM

organizes the information known about a site and helps the team identify additional information that

needs to be obtained. The systematic planning process ties project goals to those individual activities

necessary to reach these goals by identifying data gaps. The project team uses the CSM to direct the

gathering of needed information; the CSM is revised and decision goals refined as more is learned about

the site. As the CSM matures and as contaminant characteristics become better defined, the project team

may need to revisit measurement quality objectives and decision criteria.

Figure 3 summarizes how the planning components and in-field activities typically interact in a step-wise

fashion during the life cycle of a CSM under the Triad approach. Figure 4 provides a more detailed

overview of the life cycle of a CSM, as a project moves through increasing levels of complexity.
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Employing the Triad Approach

CSM Incomplete CSM More Complete

Develop or contract

development of a 

preliminary CSM and

systematic plan

Write SOW

Unitize costs

and activities

Select a contractor

Prepare work plans 

for conducting and 

documenting 

defensibility of decisions

Method selection

and modification

Resources and Constraints

Resources and Constraints

Resources and Constraints

Conduct demonstration

of methods applicability

Refine decision

criteria and implement

field activities

Perform real -time

data assessment and

desk top reviews

Finalize close -out

documentation

Optimize methods and

decision logic (if needed)

Identify principal study

questions and decisions

Select a contractor

CSM Incomplete CSM More Complete

Develop or contract

development of a 

preliminary CSM and

systematic plan

Write SOW

Unitize costs

and activities

Select a contractor

Prepare work plans 

for conducting and 

documenting 

defensibility of decisions

Method selection

and modification

Resources and Constraints

Resources and Constraints

Resources and Constraints

Conduct demonstration

of methods applicability

Refine decision

criteria and implement

field activities

Perform real-time

data assessment and

desktop reviews

Finalize close-out

documentation

Optimize methods and

decision logic (if needed)

Identify principal study

questions and decisions

Select a contractor

Employing the Triad Approach

CSM Incomplete CSM More Complete

Develop or contract

development of a 

preliminary CSM and

systematic plan

Write SOW

Unitize costs

and activities

Select a contractor

Prepare work plans 

for conducting and 

documenting 

defensibility of decisions

Method selection

and modification

Resources and Constraints

Resources and Constraints

Resources and Constraints

Conduct demonstration

of methods applicability

Refine decision

criteria and implement

field activities

Perform real -time

data assessment and

desk top reviews

Finalize close -out

documentation

Optimize methods and

decision logic (if needed)

Identify principal study

questions and decisions

Select a contractor

CSM Incomplete CSM More Complete

Develop or contract

development of a 

preliminary CSM and

systematic plan

Write SOW

Unitize costs

and activities

Select a contractor

Prepare work plans 

for conducting and 

documenting 

defensibility of decisions

Method selection

and modification

Resources and Constraints

Resources and Constraints

Resources and Constraints

Conduct demonstration

of methods applicability

Refine decision

criteria and implement

field activities

Perform real-time

data assessment and

desktop reviews

Finalize close-out

documentation

Optimize methods and

decision logic (if needed)

Identify principal study

questions and decisions

Select a contractor

CSM Incomplete CSM More Complete

Develop or contract

development of a 

preliminary CSM and

systematic plan

Write SOW

Unitize costs

and activities

Select a contractor

Prepare work plans 

for conducting and 

documenting 

defensibility of decisions

Method selection

and modification

Resources and Constraints

Resources and Constraints

Resources and Constraints

Conduct demonstration

of methods applicability

Refine decision

criteria and implement

field activities

Perform real -time

data assessment and

desk top reviews

Finalize close -out

documentation

Optimize methods and

decision logic (if needed)

Identify principal study

questions and decisions

Select a contractor

CSM Incomplete CSM More Complete

Develop or contract

development of a 

preliminary CSM and

systematic plan

Write SOW

Unitize costs

and activities

Select a contractor

Prepare work plans 

for conducting and 

documenting 

defensibility of decisions

Method selection

and modification

Resources and Constraints

Resources and Constraints

Resources and Constraints

Conduct demonstration

of methods applicability

Refine decision

criteria and implement

field activities

Perform real-time

data assessment and

desktop reviews

Finalize close-out

documentation

Optimize methods and

decision logic (if needed)

Identify principal study

questions and decisions

Select a contractor

Figure 3. Employing the Triad Approach

In guiding the site characterization process, the CSM provides:

• The framework for conducting

and scoping a site investigation or

cleanup action that takes into

account the future use of the site

• A detailed description of the site

and its setting that is used to form

hypotheses about the release and

ultimate fate of contamination at

the site 

• Sources of contamination at the

site, potential chemicals of

concern, and the media (soil,

groundwater, surface water,

structures) affected

• How contaminants may be

migrating from the sources, and

the media and pathways through which migration and exposure of potential human or environmental

receptors could occur (including possible air releases)

• An evaluation of potential or preferred cleanup options

• A basis for developing site-specific sampling designs and procedures for sample collection and

analysis

• A reliable estimate of site conditions that may lead to unacceptable risks and warrant further study

As shown in Figure 3, as a CSM is made more complete, it is typical to conduct a methods applicability

study. This study is performed to evaluate specific analytical methods in the context of site-specific

project needs.

The initial or preliminary CSM should be refined using information collected during measurement,

analysis, and integration of data activities to assist in the decision-making process. It is used as a

planning tool to provide a basis for determining when data collection is sufficient to meet project needs

(creating a tangible end point for sampling and analysis).
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Receptors Receptors

CSM Maturity Level

Preliminary

Conceptual

Site Model

(little or no

site-specific

data available)

Design and

Implement a

Dynamic Work Plan

to Verify/Define the

Preliminary

CSM

Quantitative

Risk

Assessment

Based on a

Mature

CSM

























	




























































Perform Site

Restoration

Perform Site

Restoration

Key Decisions

1. Is there a potential

threat to

human health

and the

environment?

2. Which

chemicals

from what

media pose a potential risk

under the

land use scenario?

3. Does a risk

exist above

tolerable

levels based on default

criteria?

4. What action

level would

be acceptable

based on default risk

criteria?

5. Based on realistic

exposure and

response

scenarios,

what site

cleanup goals or action

levels are required?

Collect Additional Data to

Support Remedial Actions

Collect Additional Data to

Support Remedial Actions

Perform a Quantitative

Risk Assessment

(Monte Carlo)

Perform a Quantitative

Risk Assessment

(Monte Carlo)

Remediation

to Default

Action Levels

Feasible?

Remediation

to Default

Action Levels

Feasible?

Confirm and Refine

Exposure Pathway

Assumptions

Confirm and Refine

Exposure Pathway

Assumptions

Identify Potential

Exposure Pathways

Identify Potential

Exposure Pathways

Site Identification

and Review of

Past and Current

Activities

Site Identification

and Review of

Past and Current

Activities

Media Media Contaminants Contaminants Land LandUse Use

		




Yes

No























Receptors Receptors

CSM Maturity Level

Preliminary

Conceptual

Site Model

(little or no

site-specific

data available)

Design and

Implement a

Dynamic Work Plan

to Verify/Define the

Preliminary

CSM

Quantitative

Risk

Assessment

Based on a

Mature

CSM

























	




























































Perform Site

Restoration

Perform Site

Restoration

Key Decisions

1. Is there a potential

threat to

human health

and the

environment?

2. Which

chemicals

from what

media pose a potential risk

under the

land use scenario?

3. Does a risk

exist above

tolerable

levels based on default

criteria?

4. What action

level would

be acceptable

based on default risk

criteria?

5. Based on realistic

exposure and

response

scenarios,

what site

cleanup goals or action

levels are required?

Collect Additional Data to

Support Remedial Actions

Collect Additional Data to

Support Remedial Actions

Perform a Quantitative

Risk Assessment

(Monte Carlo)

Perform a Quantitative

Risk Assessment

(Monte Carlo)

Remediation

to Default

Action Levels

Feasible?

Remediation

to Default

Action Levels

Feasible?

Confirm and Refine

Exposure Pathway

Assumptions

Confirm and Refine

Exposure Pathway

Assumptions

Identify Potential

Exposure Pathways

Identify Potential

Exposure Pathways

Site Identification

and Review of

Past and Current

Activities

Site Identification

and Review of

Past and Current

Activities

Media Media Contaminants Contaminants Land LandUse Use

		




Yes

No























Figure 4. Life Cycle of a Conceptual Site Model
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To Learn More about Demonstrations of Methods Applicability

The Town of Bluffton, South Carolina, is using the Triad approach to develop a cost-efficient strategy for

assessing the extent of lead contamination in a soil berm at a shooting range (Small Arms Firing Range) used

by the town police force. A first step in developing the strategy was designing a demonstration of methods

applicability study, consistent with EPA SW-846 method development guidelines. The BTSC has provided the

state with a white paper discussing potential options for evaluating how XRF samples should be collected, what

sample preparation should be considered, and how these options can be driven by proposed reuse and remedial

alternatives. Results from the BTSC effort are described in Analysis of Considerations for Developing a

Methods Applicability Study at a Small Arms Firing Range in Bluffton, South Carolina. Two documents that

were used as supplemental material for the applicability study that provide useful information on the

remediation of small arms firing ranges are:

• Technical/Regulatory Guidelines Characteristics and Remediation of Soils at Closed Small Arms Firing

Ranges; Prepared by the Interstate Technology Regulatory Council.

• Technical Protocol for Determining the Remedial Requirements for Soils at Small-Arms Firing Ranges;

Prepared for Air Force Center for Environmental Excellence Technology Transfer Division, Brooks Air

Force Base, Texas.

The white paper along with the supplemental materials can be found at brownfieldstsc.org.

Examples of the types and sources of background information that can be important when developing a

preliminary CSM and refining a CSM are described below. Study areas are rarely exactly alike and the

construction of a CSM for an individual site will require site-specific background information sources. 

Some types of background information will frequently be relevant to a CSM while others will have little

or no significance to the site. It is the project planning team’s job to identify and research the relevant

types of background information to aid in the construction of a preliminary CSM.

Archeological/Historical Use

The archeological and historical use of a site can reveal a variety of important data for the construction of

a CSM. For example, if a region had been historically used as a mining district, the impacts from the

historical mining could contribute to the CSM in numerous ways. Such mining influences can

significantly alter all aspects of a site’s surface and groundwater geochemistry, fauna, flora, and

geomorphology, and should be considered in the construction of a CSM. The impacts of future land use

and other effects on archeological sensitive sites should also be considered. A starting point for gathering

archeological information on a specific site can be found at the National Archeological Data Base at

http://web.cast.uark.edu/other/nps/nadb. This site provides information on archeological activities and

sites nationwide.
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Physiographic

Identifying the physiographic province in which a site is located can be important to a CSM. A

physiographic province is a region with similar geologic structures and climate, and whose pattern of

topographic relief differs significantly from that of adjacent regions, indicating a unified geomorphic

history. With the identification of the site’s physiographic province, key climatic, geologic, and

hydrologic components to the CSM may be identified. A good starting point for gathering general

physiographic information for sites in the United States can be found at

http://www.blm.gov/wildlife/pifplans.htm. More detailed information available in U.S. Geological Survey

(USGS) topographic maps illustrating physiographic features can be found at

http://rmmcweb.cr.usgs.gov/public/outreach/featureindex.html.

Climatic

Climatic conditions can play a major role in a CSM. Climatic conditions have significant influences on

several key components of a CSM, including hydrologic budget, fauna, flora, and land use. For example,

precipitation rates can impact aquifer recharge and land use. Basic climatic properties, such as air

temperature, precipitation, and prevailing wind speed and direction can be important properties of a CSM. 

With a basic understanding of a few climatic indicators, an understanding of the climate’s impact on the

study area can be incorporated into a CSM. Climatic information from worldwide weather stations can be

found at http://www.worldclimate.com/worldclimate.

Geologic

A fundamental understanding of the geology of a study area is essential in the construction of a sound

CSM. Among the basic geologic components that need to be incorporated into a CSM are the types of

geologic materials that make up the study area, structural geologic features, depositional environments,

and geomorphology. For example, a CSM would indicate what the study area consists of, such as

unconsolidated alluvial deposits underlain by bedrock. A starting point to gather geologic information is

USGS geologic research activities, which are grouped by geographic locations and can be found at

http://geode.usgs.gov/. For topographic, photoimage, geologic, and hydrologic maps, go to

http://mac.usgs.gov/mac/isb/pubs/booklets/usgsmaps/ usgsmaps.html. Additionally, the site

http://geosurvey.state.co.us/GeoLinks.htm#state will provide links to each state’s geologic survey.
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Hydrogeologic

When a CSM is constructed as a result of environmental concerns, the hydrogeologic component

typically receives the most attention because of the importance placed on groundwater and surface water

quantity and quality. An understanding of the site hydrogeology is required to provide an adequate

representation of the hydrogeologic component of a CSM. A site’s hydrogeology may be broken into

three main categories: aquifer characteristics, hydrologic budget, and groundwater flow. 

Examples of the types of hydrogeologic information included in a CSM are provided below.

1. Aquifer characteristics

a. Type (Examples: unconfined, confined, or semi-confined)

b. Characteristics (Examples: hydraulic conductivity, transmissivity, storitivity)

c. Geology (materials and structure)

2. Hydrologic budget

a. Recharge rates (Examples: precipitation, artificial recharge)

b. Discharge rates (Examples: evaporation, transpiration, groundwater pumping)

3. Groundwater flow

a. Hydraulic gradient (Examples: groundwater elevations, flow direction)

b. Flow velocity (travel time)

c. Boundary conditions (Examples: Dirichlet, Neumann)

To characterize a site’s hydrogeology, many different sources of hydrogeologic data may be used. The

availability of hydrogeology data for a particular study is simply a matter of what work has been

performed—and if it is publicly available. A good source of publicly available hydrogeologic data and

reports is the USGS. The USGS produces open file reports and maintains a database of hydraulic

information for sites throughout the United States and its territories.

A good starting place to develop the hydrogeologic portion of a CSM is to identify the hydrologic setting

of the study area from the Army Corps of Engineers Cycle II National Water-Quality Assessment

(NAWQA) Study Units (http://water.usgs.gov/nawqa/studyu.html). Additional sources for hydrogeologic

information on U.S. water resources can be found at http://water.usgs.gov/nwis.
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ASTM Standard E1527 - Phase 1 Site Assessments

The American Society for Testing and Materials (ASTM) (www.astm.org), has developed Standard E1527-00

“Standard Practice for Environmental Site Assessments: Phase 1 Environmental Site Assessment Process.” This

standard, along with its predecessor E1527-97, is intended to define good commercial and customary practice in

the U.S. for conducting an environmental site assessment of a parcel of commercial real estate with respect to the

range of contaminants within the scope of CERCLA or for petroleum products. Under 40 CFR Section 312, EPA

recently finalized a rule (68 FR 24888; 5/9/03) that identifies these standards as satifying the requirements for

conducting “all appropriate inquiry” under The Brownfields Revitalization and Environmental Restoration Act of

2001.

Other relevant ASTM Standards include D6235-98a Standard Practice for Expedited Site Characterization of

Vadose Zone and Ground Water Contamination at Hazardous Waste Contaminated Sites and E1912-98 Standard

Guide for Accelerated Site Characterization for Confirmed or Suspected Petroleum Releases.

In addition, the hydrogeological portion of a CSM also might address environmentally sensitive areas

(e.g., wetlands, watersheds, and breeding areas). These areas should be considered within an overall

CSM, including the potential impact of contamination on human or environmental endpoints.

Other Data Sources Used to Build a Preliminary CSM

Additional sources of data used to build a CSM include database reviews, usually conducted for a fee by

professional data resource companies such as Environmental Data Resources http://www.edrnet.com/ and

Vista Info http://www.vistainfo.com/. ASTM Standard E1527 (see box below) requires a review of the

physical setting of the property being investigated. A current USGS 7.5 Minute Topographic Map (or

equivalent) showing the area where the property is located should be reviewed. Maps can be obtained

through the USGS at http://mapping.usgs.gov/ or through professional data resource companies such as

Environmental Data Resources and Vista Info. The 7.5 Minute Topographic Maps can be used in

describing the physical setting of the property and adjoining properties, determining prior land uses, and

in estimating local groundwater flow direction. Groundwater flow direction is important in determining if

nearby sites identified in the database searches have the potential to impact the property.

Figure 5 is a simplified CSM that identifies examples of pathway receptor networks. Typical questions

asked during the planning process and in building a CSM include:

1. What is the proposed reuse or current use of the site?

2. Is the proposed reuse of the site politically, economically, and socially viable?

3. What media are impacted and by what type of contamination?
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4. Are there any potentially complete Figure 5. CSM of Example Pathway Receptor Networks

 receptor pathway networks

 present at the site?

5. What exposure point concentration

 might represent a potential risk?

6. Do the exposure assumptions used

 in the risk assessment match the

 reuse scenario?

7. What method reporting limits are

needed to assure the delineation of

potential hot spots?

8. What are some of the available

remedies for the site?

9. What are the potential human

exposure pathways? (EPA’s 1996 Soil Screening Guidance (SSG) provides site managers with a

tiered framework for developing risk-based, site-specific soil screening levels for the protection of

human health. The SSG, specifically the User’s Guide and Appendix A, provides additional guidance

on developing a CSM. More information on the guidance can be found at

http://www.epa.gov/superfund/resources/soil/#fact).

A CSM should not be limited to soil and groundwater contamination; rather, it should consider all

potential exposures and receptors. For example, air exposure pathways (e.g., inhalation) are particularly

important to consider in those situations where contamination will be left in-place, such as when a

building will be located above an area with residual waste.

Figure 6 shows additional examples of CSMs that are relevant to brownfields sampling and cleanups that

represent varieties of urban soil contamination. As this figure shows, identifying the model for

contaminant deposition is an important consideration in the development of a representative sampling and

analysis plan for urban soil contamination.

Under dynamic work plan strategies (described in the next section), the CSM is continuously updated

(usually daily or weekly) as additional information is produced from the investigation. As the knowledge

about site conditions increases, there is an increase in the level of certainty about whether the objectives

of the investigation can be achieved with the available resources. Decision-makers need to recognize that

it is virtually impossible to achieve 100 percent certainty about site conditions – no matter how much

money is spent on the investigation. In using a CSM, decision-makers identify the data quantity and

quality that will maximize the weight of evidence upon which decisions will be made.
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1

10

50

100

Wind Direction

NO

Concentration profiles

Distance

Concentration

UTM

coordinates

Concentration profiles

Distance

Concentration

Distance

Concentration profiles

Concentration

Distance

Concentration profiles

Concentration

UTM

coordinates

UTM

coordinates

UTM

coordinates

UTM

coordinates

Distance

Concentration profiles

Concentration

Profile

Profile

CSM #1 - Deposition Model

Airborne emissions (dust, gases) from

point source(s); concentrations decrease

with distance from source and area of

deposition dependent on many variables.

Pollution most evident in the topsoil and

decreases with depth.

CSM #2 - Line Model

Soil impact that originates from moving

point sources aligned along a long linear

element in the landscape, e.g. a road,

railway.

Pollution decreases with distance from

the line source and with depth.

CSM #3 - Surface Addition Model

Spreading of a contaminating material,

e.g. cinders, sewerage slam, sediment,

spent oxide from gasworks.

The diffuse soil pollution constitutes a

uniform load in the upper topsoil.

CSM #4 - Contribution Model

Small random contributions over many

years, e.g. the historic fill on top of which

a town develops.

The diffuse soil pollution constitutes a

variable and random load to the historic

fill.

CSM #5 - Soil Fill Model

Systematic dumping/filling with soil, waste,

material of unknown origin, e.g. land

reclamation of low lying areas and coast

regions, backfill, harbor construction.

The diffuse soil pollution constitutes a

variable and random load to the historic

fill.

Profile

Figure 6. Example of CSMs for Urban Soil Contamination

Source: Project on diffuse soil pollution funded by the Danish EPA. Paper by Jacqueline Falkenberg, NIRAS;

Ulla Højsholt, the Danish EPA; Arne Rokkjaer, Information Center of Contaminated Sites; Mariam Wahid, the

Agency of Environmental Protection in Copenhagen. Consoil 2003. (Used with permission)
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At brownfields sites, systematic planning and development of the CSM need to closely tie into the reuse

plans for the site. A balance must be achieved between the costs required to purchase and redevelop the

site and the potential benefits (revenues, resale/asset value, social/political) once the site is ready for

reuse. CSMs will identify the environmental, financial, and social factors that will likely determine the

potential reuse scenarios possible at a site.

2.2 DYNAMIC WORK PLAN STRATEGIES

What is a dynamic work plan strategy? Dynamic work plan strategies are the second element of the

Triad approach. These types of strategies use real-time decision-making in the field to limit the number

of mobilizations back to the field to fill data gaps or take remedial actions. This approach significantly

reduces project costs and the schedule to reach project closeout. Use of a dynamic work plan strategy and

related project management strategies can improve the economics that drive the reuse potential for

brownfields properties.

A dynamic work plan strategy is one where decisions are made and the work plans guiding sampling and

analysis are adjusted in response to data generated while the field crew is still on site (i.e., while still in

the field). Proper application of a dynamic strategy allows field teams to efficiently collect the data

needed for decision-making and to fill data gaps (described in the preceding section) with as few 

mobilizations as possible. Dynamic work planning is the element of the Triad approach that can have the

greatest impact on cost and time savings.

A dynamic work plan strategy relies on real-time data to reach decision points and quickly identify the

need for alternative action. Real-time data is defined in terms of the timing required to satisfy decisionmaking needs. Decisions are often of several different types – small scale decisions may need to be made

daily, while larger scale decisions may need to be made weekly to keep the project moving. A key

element is the development of decision logic to guide the teams while in the field. This logic should be

reviewed and approved by the regulator and others who will use the data and determine the

appropriateness and validity of specific site decisions. The logic for decision-making is identified and

responsibilities, authority, and lines of communication clearly established in the plan. Implementation of

all field work is driven by the critical project decisions needed to reach closure. These decision points

and potential scenarios are carefully mapped during the planning process.
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To Learn More about Dynamic Work Plan Strategies

The Cos Cob Power Plant site in Greenwich, Connecticut, was formerly a coal-fired power generation station. 

The city was examining a reuse plan for the site consisting of multiple use recreation areas, however concerns

existed about PCB- and petroleum-contaminated soils at the site. Polycyclic aromatic hydrocarbons (PAHs),

metals, and asbestos were suspected to be present at the site. The BTSC has provided support to the city for

using the Triad approach, including participation in the development of a dynamic work plan strategy to

implement a field-based measurement program. These activities have been documented in a project

profile/case study available at brownfieldstsc.org.

The Wenatchee Tree Fruit Fruit Research and Extension Center site is an agricultural research facility located

in Wenatchee, Washington. The test plot area of the site contained soils contaminated with organochlorine

pesticides, organophosphorus pesticides, and other pesticides. Site investigation and cleanup was performed

using the Triad approach, including use of a dynamic work plan strategy and immunoassay field test kits. In

addition, a pilot test was performed that demonstrated the applicability of immunoassay test methods for

pesticides such as DDT and cyclodiene and that was used to guide on-site decision-making. The U.S. Army

Corps of Engineers (USACE) prepared several documents about this effort, including a Remedial Action

Management Plan and a Sampling and Analysis Plan. These documents provide background on the site, as

well as discuss project scope and objectives, and field activities, including soil characterization by

immunoassay and traditional techniques. These documents can be found at brownfieldstsc.org.

Once the strategy and logic are established, an approved decision tree can then be used by the field team

to guide their dynamic decision-making during field activities. The decision tree provides the basis for

decisions made in the field and results in a defensible paper trail for the field work and resulting data. 

Deviations from the approved decision tree require thorough documentation, and may require real-time

approval of regulators and stakeholders. Dynamic work plans are designed to use decision trees and realtime uncertainty management practices to reach critical decision points in as few mobilizations as

possible. Sequencing of activities is used to minimize crew sizes and allow for data collection and

processing time, while not slowing overall project progress. For example, members of a field crew can be

split into groups to perform concurrent activities. One group can be staking locations while another is

sampling and analyzing samples, and another is determining and managing excavation activities.

The likelihood of success for a dynamic approach is enhanced when experienced staff, at least initially, go

to the field to review operations and trouble-shoot decision logic during project startup. Having some

level of senior staff review during project startup helps to ensure that the appropriate staff are empowered

to make decisions, that decision logic is sound, and that foreseeable problems are anticipated before they

arise. Field staff in a dynamic field program are responsible for involving core technical team members

who, in turn, usually are responsible for communicating results to regulators or others overseeing the
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project. After completion of a project, summary reports should clearly discuss the decisions that were

made, the uncertainties that impacted project decision-making, and the strategies used to manage these

uncertainties.

Recent advances in communications technologies and communications plans support modern dynamic

strategies. Conference calls, mobile telephones, wireless email and Internet access, decision support

software, videostreaming, and faxes are among the tools that can be applied to facilitate communication

among team members. These tools can support the daily and weekly decision meetings that are needed

without necessarily requiring that all the key decision-makers (for example, regulators, risk assessors,

senior managers, and so forth) be physically on site during field work. It is essential, however, that the

field team include a senior authority who has the confidence of the project team to effectively transmit

information and to execute project decisions in the field.

2.3 REAL-TIME MEASUREMENT TECHNOLOGIES

What is real-time measurement? Real-time measurements are those that are produced within a rapid

time frame so that real-time decision-making and maturation of the CSM can occur in real-time (i.e.,

while the team is in the field). The term "real-time measurement technologies" encompasses much more

than just on-site analytical tools such as test kits and field instrumentation such as field-portable gas

chromatography (GC) or x-ray fluorescence (XRF). It also includes rapid sampling platforms, in situ

detection technologies, and the software programs used to manage, interpret, display, and map data in

real-time to make dynamic work plan strategies possible. In addition, the term includes rapid turnaround

of results from a fixed laboratory that may use either definitive or screening methods. Although

screening methods traditionally have been associated with field use, running "field" methods in a

traditional laboratory should be considered since under certain circumstances it is the most efficient

option both logistically and economically.

Using field analytical tools and non-traditional analytical strategies are key to saving time and money

while limiting decision uncertainty, but requires thinking "outside of the box." The tools include a broad

category of analytical methods and equipment that can be applied either at the sample collection site or at

a nearby laboratory capable of generating results on a quick or slightly accelerated rate. They include

methods that can be used outdoors with hand-held, portable equipment, as well as more rigorous methods

that require the controlled environments of a mobile (transportable) or fixed laboratory. During the
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planning process, the project team identifies the type, quality, and quantity of data needed to answer the

questions requiring resolution to reach project closeout. Use of decision support software can also save

project managers time and money and is discussed further in Section 3.3.

When using innovative field-based technologies to better characterize a site, it is often desirable to

combine information collaboratively for the purpose of obtaining a clearer image of the problem present

at a site. Collaborative data sets are two or more distinct data sets that are used together to manage

different sources of uncertainty for a particular decision. For example, cheaper analytical methods can be

used to increase sampling density (i.e., the number of samples per matrix volume, area, or decision) and

to improve the accuracy of the CSM (i.e., manage sampling uncertainty). After sampling

representativeness has been established, residual analytical uncertainty is then managed by carefully

selecting informative samples to be sent for more rigorous analyses to provide lower detection limits,

analyte-specific results as needed to meet risk assessment or regulatory requirements. The use of

collaborative data sets can take several forms including the following:

1. Comparison of results from fixed lab methods to those from proposed field-based methods to

evaluate anticipated performance. Depending on results, this might involve selecting alternative

conservative action levels for use with field-based methods. For example, use of a field-based

method with less analytical precision or accuracy might be coupled with a lower action level to

provide for greater certainty in identifying contaminated soil.

2. Using data collaboratively to arrive at a particular conclusion. For example, laser induced

fluorescence measurements, cone penetrometer geotechnical data, and field-based gas

chromatography information to guide design of a treatment system. 

3. Using field-based immunoassay results to decide when and where confirmation samples should be

collected for fixed laboratory gas chromatography mass spectrometry results.

4. Upfront demonstrations of methods (sampling and analytical) applicability developed using fieldbased and modeling methods can be used to understand the inherent variability of contamination

expected in the field prior to the commencement of site characterization activities. The EPA online calculators (www.epa.gov/athens/onsite) were developed to provide modelers and model

reviewers with prepackaged tools for performing site assessment calculations (i.e., inherent

variability of contamination expected in the field prior to the commencement of site

characterization activities).

An example of using data collaboratively to arrive at a solution in the most expeditious and economically

efficient manner is provided on the next page.
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EXAMPLE: Use of Collaborative Data Sets

If disposal costs vary widely based on a specific land disposal restriction (LDR) at a site, it may be desirable to

obtain more accurate results when concentrations are close to the LDR value. For example, when screening

analysis accompanied by appropriate quality control (whether performed in a fixed or field laboratory) indicates

total PCB concentrations for a given volume of waste material is either far above or far below the regulatory

threshold (that can trigger costly treatment such as incineration), then there would be little doubt about whether

treatment is required or not based on the screening method results. However, if the screening analysis results

indicates that PCB concentrations are close to the regulatory threshold (i.e., closer than the resolution of the

screening method can distinguish), then follow-on analysis using a more definitive method could be warranted. It

would be important however, to first use the results of the screening method to estimate the variability within the

waste volume, so that the proper strategy to collect representative samples (e.g., by compositing or calculating a

statistically valid number of samples) for more expensive, definitive PCB analysis can be determined. Both sets of

data are then used to justify the final decision about disposal: the much larger data set composed of screening

analyses collaborates with the smaller set of definitive analyses so that definitive analysis of one or a few samples

can be confidently extrapolated to represent the entire matrix volume in question. While this approach could result

in an additional, upfront expense, it may result in saving more at a later date when it is time to dispose of material

and to justify to stakeholders that the correct decision was made.

When matrix heterogeneity is greater than analytical variability and the cost of making a wrong decision (i.e.,

about disposal of potentially contaminated materials) is high, collecting more samples for less expensive (i.e., less

rigorous) analytical quality is usually desirable to permit management of the data uncertainties caused by sampling

variability. Dynamic work plans that provide for reactions to the observed variability in results help project teams

make "on the fly" decisions to increase sampling density as appropriate to target the volume of contaminated soil

that would need to be disposed.

Real-time measurements can support successful redevelopment at brownfields sites by providing a clearer

view of the problems and potential action alternatives. Screening analyses provide vital input to

developing the CSM by estimating the variability in contaminated matrices and indicating when one of

more distinct populations (such as "clean" areas vs. hotspots) are present. The role of more rigorous,

traditional fixed laboratory methods is to provide analyte-specific data with low detection limits, low bias,

and better precision for samples of known representativeness (i.e., the sample representativeness is

already established on the basis of the maturing CSM) when higher analytical rigor is needed for risk

assessment or establishing regulatory compliance. The collaborative use of screening and definitive data

collection methods for monitoring and measurement is changing standard assumptions of what is possible

in terms of cost, time required to reach closure, and viability of remedial alternatives. Owners can more

reliably predict what it will cost to obtain a “clean” value (purchase price plus redevelopment costs). 

Achieving a “clean” value at a lower cost can have a significant affect on properties for redevelopment.

Further information about the legal defensibility of using field methods can be found in “Using Field

Methods - Experiences and Lessons: Defensibility of Field Data”; Barton P. Simmons, California

Department of Toxic Substances Control; available at www.cluin.org/char1.
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3.0 PROJECT MANAGEMENT AND PROCUREMENT CONSIDERATIONS

This section discusses project management and procurement considerations important for use at

brownfields sites, including management tools that can be used to assist project managers in decisionmaking.

3.1 PROJECT MANAGEMENT

During the development of a systematic plan for a site, a project manager should assemble a core

technical team. This project team should include multi-disciplinary members and area experts as

necessary. A typical project team consists of a geologist, chemist, hydrogeologist, risk assessor, field

manager, engineer, and a procurement specialist. Activities should be rolled into logically related groups

and unitized rates developed when possible. Using unit rates and activities will assist project managers in

scoping out and managing project growth or costs as more is learned about a site. For example, surface

soil sample collection, analyses, data management, data interpretation, and communication of daily results

could be rolled into a unit cost with associated sample processing minimums (for example, 30 samples

per day). By using a dynamic work plan strategy approach, decisions about whether additional samples

are required can be made in the field. Project managers should estimate the maximum number of samples

required based on existing information but still plan for the unknown potential for project growth or

shrinkage. By obtaining unit costs from service providers, project managers have the information needed

to decide about the impact of authorizing additional work or reallocating project resources as necessary.

The approach used for project management will vary based on the nature and complexity of the site

activities. Relatively large, complex sites or groups of sites in an area-wide approach tend to involve a

more complex project management team, while relatively smaller, straightforward sites will have a less

complex team. However, in all cases that use the Triad approach, the project manager can use unitized

rates and draw on expertise as needed to manage the uncertainty and plan and execute a cost-effective site

assessment or cleanup. Use of experienced staff can help to more quickly identify potential problems as

they develop in the field and determine solutions that would more quickly get the project moving toward

completion.

When applying the Triad approach, it may be beneficial to use internal or separate contractors to assist

during planning, rather than those who actually implement or perform the work. This practice helps to
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ensure the unbiased development of a plan to limit costs during project implementation. A higher level of

expertise may be required during planning. However, detailed instructions that are clear and a well

defined scope can encourage less expensive, less experienced contractors to bid on more complex jobs. 

Once the systematic plan and statement of work are developed by the core technical team, it should be

communicated to stakeholders and other project personnel and feedback solicited. Senior core technical

team members, stakeholders, and project team members need to have clear lines for communication so

that the approach and associated documents can be revised as more is learned about a site. Once a course

of action and appropriate triggers for corrective action are identified, an organized trail of documentation,

electronic and hard copy, needs to be put in place. Daily and weekly decision-making requires the use of

innovative communication tools such as those discussed in Section 3.3. Having a well thought out

communication strategy helps to ensure that finalizing results and obtaining a closeout letter on a site is

streamlined. Cost savings realized in streamlineg the investigation, cleanup, and closeout cycle are where

the true benefits of the Triad approach can be realized.

Insurance also is becoming a critical component to the success of Brownfields programs. Insurance

companies are experts at identifying a monetary value for “managing uncertainty.” By using the Triad

approach, the level of uncertainty at a site can be decreased and a more accurate CSM can be developed,

resulting in the potential for a lower premium for an insurance policy to cover the cleanup and

redevelopment of a site. If insurance is anticipated to be a component of a Brownfield redevelopment, an

insurance company should be consulted during the systematic planning process to identify their

information needs. Case studies on these approaches and other publications indicate that upfront

management and planning costs can be higher with the use of the Triad approach than for other more

traditional programs. However, use of the Triad approach can result in back-end savings for

implementation and cleanup of 50 percent or more than the original estimation of project costs.

EPA’s Dynamic Field Activities guidance provides site project managers with an overview of the

information needed to oversee the effective implementation of dynamic field activities, which include

systematic planning, dynamic work plans, and rapid analytical results, at their sites. More information on

this new guidance can be found at www.epa.gov/superfund/programs/dfa/.
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Achieving State Regulatory Acceptance of the Triad

A major part of implementing the Triad approach is developing a framework that works within state regulations,

for example addressing variations in terminology and standards. Several efforts with state regulators currently

are underway to broaden the understanding of the requirements related to using the Triad approach.

Northeast Waste Management Officials’ Association (NEWMOA)

NEWMOA’s waste site cleanup program focuses on issues of interests to state programs that have responsibility

for the investigation and remediation of contaminated sites. Currently, the waste site cleanup program is working

on issues surrounding the use of innovative site characterization and remediation technologies within state

programs. More information on NEWMOA’s efforts can be found at

http://www.newmoa.org/Newmoa/htdocs/cleanup/.

Interstate Technology Regulatory Council (ITRC)

ITRC is a state-led coalition working together with industry and stakeholders to achieve regulatory acceptance of

environmental technologies. ITRC consists of 40 states, the District of Columbia, multiple federal partners,

industry participants, and other stakeholders, cooperating to break down barriers and reduce compliance costs,

making it easier to use new technologies, and helping states maximize resources. ITRC teams have developed

guidance on accelerated site characterization including documents such as the ITRC/ASTM Partnership for

Accelerated Site Characterization Summary Report. In addition, ITRC has formed a Sampling, Characterization,

and Monitoring Team. The team is examining not only innovative sampling and monitoring technologies, but

also innovative approaches like the Triad approach and helping them gain acceptance from state agencies. For

more information on the ITRC, please visit www.itrcweb.org.

3.2 PROCUREMENT ISSUES

Procurement of innovative sampling and analytical technologies and services is an important part of

planning for streamlined site investigations and use of the Triad approach. Innovative procurement

strategies can help with implementing a Triad approach, including use of fixed unit costs for sampling

and analytical activities. The following information is further discussed in EPA’s Understanding

Procurement for Innovative Sampling and Analytical Services for Waste Site Cleanup (currently in draft

form) and in Assessing Contractor Capabilities for Streamlined Site Investigations (EPA 542-R-00-001,

January 2000, brownfieldstsc.org/publications_index.htm).

Among the essential procurement issues related to use of the Triad approach are:

• The need to ensure that solicitations and requests for proposals (RFP) allow flexibility necessary to

use field methods and rapid sampling and to allow for use of technologies and approaches that can

support dynamic decision-making about a range of measurements during implementation of the

project.

• The need to require and budget for adequate systematic planning in the RFP and the project work

plan.
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• The need to match the expertise of available contractors (for example, those likely to bid on the job)

and their ability to employ field tools with the required level of knowledge and understanding.

• The need to seek expertise in reviewing proposals and interviewing service providers to determine

if the proposed approach will yield data required for specific tasks. This consideration becomes

particularly important when an RFP allows flexibility in approach, numbers of samples, analytical

strategies, and so forth. Simple comparisons of costs and schedules may not be sufficient. Hiring

someone to conduct the planning and to review a technical approach separately from and prior to

hiring a contractor to do the field work may be a way to simplify the review process.

To Learn More about Innovative Procurement Strategies

The former Reitz #4 property in Central City, Pennsylvania was used to support coal mining operations in the

surrounding area and includes a motor/car repair shop, a powerhouse, and a machine shop. Potential concerns

at the site included the presence of transformers, which may contain PCBs, drums and containers of inks and

thinners, and basements full of potentially-contaminated water. The BTSC helped the city with using the Triad

approach through the development of a statement of work based on a dynamic work plan strategy for

conducting a Phase II investigation. The city incorporated some elements of the Triad into a RFP. The RFP

and proposed statement of work can be found at brownfieldstsc.org.

The City of Trenton, along with multiple partners including New Jersey Institute of Technology, EPA Region

2, EPA’s BTSC, New Jersey DEP, and USACE, acquired services to perform a site investigation/remedial

investigation at 60-acre site that formerly had been used for industrial purposes. The property consists of

multiple brownfields sites contaminated with numerous substances including heavy metals, PAHs, and PCBs. 

The entire area will be incorporated into the planned Assunpink Creek Park and Greenway. The objective of

the project was to use the concepts of the Triad approach including use of field analytical technologies to

achieve the goals of the investigation and define the level of remediation necessary to implement the planned

reuse. This project involved coordination between Federal and state partners regarding a variety of technologyrelated items including use of field analytical technologies. More information on this site, including the RFP,

can be found at brownfieldstsc.org.

3.3 MANAGEMENT TOOLS

Use of innovative technologies and approaches can save time and money, and project managers can use

decision support software packages to help implement these approaches. Many good decision-support

software packages are available to support the determination of attainment, preparation of sampling plan

design, and estimation and tracking of remediation costs and progress. However, it should be noted that

every statistical tool is based on certain assumptions about contaminant distribution. If the assumptions

of a statistical tool are violated, the statistical results may not be reliable. Users of these tools need to

understand what drives the statistical models and the assumptions they rely on. As more information

becomes known, the user should continually re-assess whether the assumptions of the chosen statistical
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model are still valid. In addition, there must be a clear understanding of what decisions are going to be

made and what role statistics will play in those decisions (i.e., what data are needed to guide those

decisions and what variability and distinct contaminant populations the CSM predicts). Several publiclyavailable EPA-sponsored software packages currently are available that can help in managing projects

that use the Triad. Additional information is also provided in Appendix C. Examples of software

packages include:

• Spatial Analysis Decision Assistance (SADA) – The University of Tennessee, Knoxville, with

support from EPA and DOE, and in collaboration with Oak Ridge National Laboratory, has

developed a software program that integrates visualization, geospatial analysis, statistical analysis,

human health risk assessment, cost-effective analysis, sampling design, and decision analysis

(www.tiem.utk.edu/~sada/). SADA is free software that incorporates tools from environmental

assessment fields into an effective problem solving environment. These tools include integrated

modules for visualization, geospatial analysis, statistical analysis, human health risk assessment,

ecological risk assessment, cost/benefit analysis, sampling design, and decision analysis. The

capabilities of SADA can be used independently or collectively to address site-specific concerns

when characterizing a contaminated site, assessing risk, determining the location of future samples,

and when designing remedial action. For information on training sessions, email

sada@tiem.utk.dcu. Question and user support can be obtained by sending a blank email to

sadusers-subcribe@yahoogroups.com.

• U.S. EPA FIeld EnvironmentaL Decision Support (FIELDS) – EPA Region 5 developed the

FIELDS system which combines geographic information systems (GIS), global positioning systems

(GPS), database analysis, and imaging technologies to identify, assess, communicate, and help

solve environmental problems (www.epa.gov/region5fields/). The FIELDS system is a set of

software modules designed to simplify sophisticated site and contamination analysis. Each module

is a self-contained unit that can be applied to a variety of scenarios. When used together, either

working through the FIELDS process, or being applied according to a different schedule, the

modules offer unprecedented power and efficiency in the characterization, analysis, and cleanup of

environmental contamination. FIELDS has been used at many brownfields sites supported by the

BTSC in an effort to facilitate the planning process. Information about training sessions on

FIELDS can be found at the website referenced above.
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• U.S. DOE Pacific Northwest National Laboratory Visual Sampling Plan (VSP) – VSP provides

statistical solutions to sampling design to help users decide where samples should be collected and

how many are needed (http://dqo.pnl.gov/vsp/). The purpose of VSP is to provide simple,

defensible tools for defining an optimal, technically defensible sampling scheme for

characterization. VSP is applicable for any two-dimensional sampling plan including surface soil,

building surfaces, water bodies, or other similar applications. VSP development has been partially

supported by the DOE’s National Analytical Management Program (NAMP) and is presently a joint

effort between Pacific Northwest National Laboratory (PNNL) (www.pnl.gov) and Advanced

Infrastructure Management Technologies (AIMTech) - Grand Junction, Colorado.

• U.S. EPA Removal Cost Management System (RCMS) 2000, Version 1.2 – RCMS is a cost

accounting and reporting system used on removal sites to track costs and usage of personnel,

equipment, subcontractors, and purchases. Modules include: cost tracking, cost projection, and

EPA invoicing. To order RCMS, please visit www.ert.org.

• U.S. EPA Scribe (Environmental Field Data Capture), V2.2 – A Windows software that can be

used to assist in the management of environmental sampling data for soil, water, groundwater, air,

and biota. Outputs include sample labels, assorted field data sheets and reports, and chain of

custody generation. This software currently is being updated by EPA’s Environmental Response

Team (ERT). For more information, please call ERT’s Software Support at (800) 999-6990.

• Center for Subsurface Modeling Support (CSMoS) – CSMoS provides public domain

ground-water and vadose zone modeling software and services to public agencies and private

companies throughout the nation. CSMoS is located in Ada, Oklahoma at the National Risk

Management Research Laboratory (NRMRL), EPA's Center for Ground-Water Research. The

primary aims of CSMoS are to provide direct technical support to EPA and state decision-makers in

subsurface model applications and to manage and support the ground-water models and databases

resulting from the research at NRMRL. For more information on CSMoS, please visit

http://www.epa.gov/ahaazvuc/csmos.html.

• Center for Exposure Assessment Modeling (CEAM) – CEAM was established to meet the

scientific and technical exposure assessment needs of EPA as well as state environmental and

resource management agencies. CEAM provides proven predictive exposure assessment

techniques for aquatic, terrestrial, and multimedia pathways for organic chemicals and metals. 

More information can be found at http://www.epa.gov/ceampubl/.
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4.0 SUMMARY

The concepts of the Triad approach are not new. From the early 1980s on, DOE articulated many of the

core concepts of the Triad approach as Expedited Site Characterization (ESC). In addition, DOE linked

the use of a dynamic work plan strategy with systematic planning with the intent of speeding up

Superfund site investigations and feasibility studies at DOE sites in an approach called SAFER

(Streamlined Approach for Environmental Restoration). The USACE began institutionalizing an

integrated approach to systematic planning under the name “Technical Project Planning (TPP) Process”. 

For more information on the TPP Process, please visit

http://hq.environmental.usace.army.mil/tools/tpp/brochure/pdf). Although it does not address dynamic

work plan strategies and the use of real-time measurements directly, the TPP engineering manual stresses

the importance of a multi-disciplinary team that performs “comprehensive and systematic planning that

will accelerate progress to site closeout within all project constraints.” In 1996-1997, EPA Region 1 and

Tufts University coordinated with the U.S. Air Force to conduct a demonstration of a dynamic site

investigation using real-time results generated by a mobile laboratory to delineate residential soil

contamination at Hanscom Air Force Base (Innovations in Site Characterization Case Study:  Hanscom

Air Force Base, Operable Unit 1, September 1998, EPA 542-R-98-006,

http://www.epa.gov/swertio1/download/char/hafbcs2.pdf). The project showed that innovative

technologies combined with an adaptive sampling and analysis program could drastically reduce the time

and cost, while increasing the confidence of site decisions. Argonne National Laboratory’s

Environmental Assessment Division (EAD) refers to the same basic concepts as Adaptive Sampling and

Analysis Programs (ASAP) to expedite data collection in support of hazardous waste site characterization

and remediation. ASAPs emphasize “real-time” data collection and field-based decision-making, using

dynamic work plan strategies. The Triad approach takes these same concepts further by explicitly making

the management of decision uncertainty the linchpin for systematic planning, while relying on innovative

technologies and dynamic/adaptive work planning as the only mechanisms to cost-effectively manage

data uncertainty and build accurate CSMs.

The Triad approach is a common sense approach that has been successfully applied by other Federal,

state, local, and private organizations. Similarly, the dynamic nature of the Triad approach allows

decision-makers to focus on the best strategy for conducting environmental measurements that is flexible

and meets site needs. Use of systematic planning has continually resulted in lower overall project costs. 

Use of dynamic work plan strategies can reduce or eliminate the need for multiple mobilizations on a site
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to reach closeout. For brownfields sites, where decision-making is so closely tied to economic constraints

and public acceptance, increased information value obtained using real-time measurement technologies

collaboratively with definitive fixed laboratory methods for data collection will provide stakeholders with

the confidence they need at a reduced cost. Reducing project costs and schedules to obtain closure means

that more dormant or abandoned sites may become economically viable for redevelopment.

The Triad approach can be implemented at sites by taking advantage of the key elements and steps

outlined in this primer. In addition, the documents referenced throughout this primer and the resources

identified in Appendix C provide valuable information on the application of the Triad approach at various

sites and describe various technologies that can be used to characterize or remediate a site. By using

these approaches and technologies at brownfields and other redevelopment sites, site owners and

environmental professionals can streamline the effort involved with bringing a contaminated site back

into productive use.
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APPENDIX A

FREQUENTLY ASKED QUESTIONS (FAQ) WHEN

DESIGNING A PROGRAM USING THE TRIAD APPROACH

Question 1: What is the Triad approach?

Answer 1: The Triad approach consists of using systematic project planning, dynamic work plan

strategies, and real-time measurement technologies, and is applicable to contaminated site

investigations and cleanup. It is a work strategy framework for economically managing

project decision uncertainties by drawing on the technical knowledge and experience

gained over the past 20 to 30 years of hazardous site cleanup. The Triad approach

proactively exploits new characterization and treatment tools, using work strategies

developed by innovative and successful site professionals. An important product of the

Triad approach is a conceptual site model (CSM) accurate enough to support correct

project decisions.

Question 2: Who should use the Triad approach?

Answer 2: Project managers and their technical staff responsible for cleanups at hazardous waste

sites should consider using the Triad approach.

Question 3: What is systematic project planning?

Answer 3: Systematic project planning is the most important and often used element of the Triad

approach. Systematic planning is a common sense approach to identifying the decisions

that need to be made to reach project goals. Once it is clear what decisions are driving

the project, systematic planning identifies the inputs needed to feed those decisions and

project constraints (budgetary, regulatory, legal, scientific, etc.). Inputs to decisions

about contaminated sites usually involve some kind of environmental data, so systematic

planning also involves developing the technical strategies used to generate and interpret

the data feeding the decision-making process. Up-front systematic planning should

involve all parties, including stakeholders, and a multi-disciplinary technical team. 

Question 4: What is a dynamic work plan?

Answer 4: A dynamic work plan is a work plan that is written to be flexible so that the course of site

work can adapt to new information as it is being acquired in real-time. Dynamic work

plan strategies are the second element of the Triad approach. These types of strategies

use real-time decision-making in the field to limit the number of mobilizations back to

the field to fill data gaps or take remedial actions. This approach can reduce project costs

and the time needed to reach project closeout. Use of a dynamic work plan strategy and

related management strategies can drastically improve the economics that drive the reuse

potential for brownfields properties. 

Question 5: What are field-based measurement technologies?

Answer 5: Field-based measurement technologies provide analytical results on site, and they are a

primary means of providing measurements in real-time, although by no means are they

the only way. Note that "real-time measurement technologies" (NOT "field-based
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measurements") constitutes the third leg of the Triad. Field-based technologies are but

one option to provide real-time turnaround of results. Field-based measurement

technologies include mobile laboratories equipped with instrumentation ranging from

state-of-the-art sophisticated instrumentation to "simple" test kits. Field-based

measurement technologies also include using a test kit under a tent, taking XRF

measurements on the ground or through a plastic bag, performing fence-line monitoring

with "high tech" ultraviolet (UV) or infrared (IR) spectroscopy instrumentation, and

taking a pH or turbidity measurement in a well. Modern field-based measurement

technologies now run the gamut from highly accurate analytical instrumentation to

"low-tech" screening analyses. The quality of data generated in the field cannot be

judged based on the location where the results were generated, but according to the data's

ability to support the intended decisions, which includes sufficient quality control

documentation to ensure that data are of known quality.

Questions 6: What are real-time measurement technologies?

Answer 6: “Real-time measurement technologies” compose the third leg of the Triad approach. The

term includes any mechanism that supports turning around data results within the time

frame needed to support real-time decision-making. ("Real-time decision-making" refers

to updating the CSM with new information and adapting subsequent site work to that

updated knowledge while the field crew remains in the field.) The mechanisms used to

provide real-time measurements include rapid turnaround from a fixed laboratory; on-site

measurement in a mobile lab, or in the back of a truck, or in situ; and the hardware and

software used to rapidly process instrument signals, store and retrieve analytical results,

evaluate quality control, perform statistical analysis, display or map data, and share data

with colleagues, regulators, and stakeholders back in the office or across the country.

Question 7: What are the benefits of using non-traditional measurement technologies?

Answer 7: Frequently, the most cost-effective option for generating real-time data is to use

field-based measurement technologies. Another advantage of using screening methods in

fixed laboratories and field analytical methods is that they can provide the higher

numbers of samples needed to manage the uncertainties associated with sample

representativeness. Whatever measurement techniques are used, data of known quality

must be produced using a technically sound quality control program. 

"Mixing-and-matching" several analytical methods (i.e., fixed and field methods)

according to their various strengths is usually the most economical way to generate data

sets that are effective for making project decisions because sampling and analytical

uncertainties have been managed commensurate with the desired or negotiated project

outcome. For brownfields sites, increased information content to support decisionmaking is essential. Making sound decisions will ensure long-term liability is reduced 

within the context of the reuse scenario, including residential, industrial, or recreational

scenarios.

Question 8: When should the Triad be applied?

Answer 8: Systematic project planning should always be applied when tackling problems at

hazardous waste sites. Developing a CSM accurate enough to support correct decisions

should be a goal for every project. Dynamic work plan strategies are best used early and
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throughout the investigative portions of a project when physical and chemical conditions

at a site are being defined. They are particularly useful during cleanup actions when the

scale of decision-making is being redefined and economic constraints are of paramount

concern. Real-time measurements can reap benefits throughout all portions of the

cleanup process from investigation through long-term monitoring and verification of the

effectiveness of risk management cleanup strategies.

Question 9: How do I identify contractors or forms of support to assist in implementing the Triad?

Answer 9: EPA’s Technology Innovation Office (TIO), Superfund, and many other organizations

are partnering to promote the use of the Triad approach. Planning, technological, and

vendor resources can be identified through the TIO web site at http://cluin.org. The

BTSC also provides related information at brownfieldstsc.org.

Question 10: Can the Triad approach assist in improving lender confidence or reducing the cost of

environmental insurance?

Answer 10: The Triad approach can be used to alleviate the need for deed restrictions or conditionson-closure letters in some cases. Lending and insurance requirements are generally

driven by policy. The Triad approach can be used to reduce the perception of risk

because more direct, objective evidence and hard data can be developed during early site

evaluations. The Triad approach can improve the confidence with which environmental

decisions are made by targeting the primary sources of uncertainty that increase the

perception of risk.

Question 11: What is a dynamic work plan strategy and what planning documents describe the

approach to be used?

Answer 11: A dynamic work plan strategy is a flexible, adaptive work strategy that rapidly reaches

project objectives by allowing real-time feedback (i.e., data) to guide selection of the

alternative options of a pre-approved decision tree. A common theme is that the number

and placement of samples is not fixed before field work begins, but is decided in the field

(according to pre-established decision logic) based on site conditions. During systematic

planning, the core technical team works with stakeholders to agree upon a plan of action. 

The flow of activities is designed to work through as many branch points of the decision

tree as possible during a single field mobilization. The necessary details for

implementation are then translated into concisely worded, streamlined planning

documents such as a work plan, field sampling and analysis plan, or quality assurance

project plan.

Question 12: Is a dynamic work plan strategy appropriate for every site?

Answer 12: Dynamic work plan strategies are not always appropriate. They involve development of

decision logic about appropriatenss and validity of site-specific decisions. Programs that

do not provide clearly-identified responsibilities or authority to implement decision logic

may lead to relatively slower progress on implementing a dynamic work plan. In

addition, site conditions or level of maturity (i.e., long-term monitoring or background

type of evaluations) may not warrant the need for a dynamic approach. However, many

projects from the initial investigation through cleanup can benefit from the use of a

dynamic work plan strategy for some or all of the site activities.
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Question 13: What contingencies are necessary to assure that project progress is not hampered?

Answer 13: Practical and analytical contingencies should be anticipated and addressed during project

planning. For example, if direct-push rig refusal is expected at a specific depth, then a rig

with an auger attachment might be considered. If analytical results for a particular soil

management area are unclear, then perhaps more samples should be budgeted for in case

they are required to verify if the area should be considered clean. A practical approach

using the expertise from the project team and pool of stakeholders should be used to

identify potential contingencies.

Question 14: At what frequency should senior staff review field and laboratory activities?

Answer 14: Early in an investigation, senior staff should go to the field to trouble-shoot problems

encountered and assure that documentation is being adequately prepared. Similarly,

senior staff should also visit the fixed laboratory (if one is being used) before samples are

sent. Closeout audits by senior staff also are recommended; adequately prepared

electronic and hardcopy records will allow a project to seamlessly reach closeout.

Question 15: How can primary decision-makers assure the quality of decisions made in the field and

justify changes made in initial sampling plans?

Answer 15: Through the development of well designed decision trees and standard operating

procedures for identifying the need for changes in decision logic, a project manager and

technical lead can identify and incorporate changes easily. Addendum development

protocols and triggers designed into QA review procedures help ensure that decisions are

based on sound science and that problems are identified and addressed early in the

process. Decision trees should be communicated along with the proposed approach to

stakeholders before a project is implemented. Options should be identified and public

comment addressed as appropriate before project startup. Periodic review of field

activities before and during implementation should be conducted as another type of

safety check.

Question 16: Should field-based or fixed laboratory analysis be used?

Answer 16: The answer to this question should not be seen as “either-or." It will depend heavily on

the nature of the contaminants of concern (COC), the type of decision(s) being made, and

the sampling and analytical uncertainties that need to be managed in order to make the

decision(s). For example, some XRF units are capable of analyzing for the presence of a

wide variety of metals in the field. However, XRF reporting limits are typically in the

parts per million (ppm) range. Therefore, if decisions will be based on metals

concentrations in the parts per billion (ppb) range, fixed-laboratory analysis using

inductively coupled plasma spectrometry (ICP-OES) may be the preferred option to

produce ppb concentration data and manage analytical uncertainty. However, the

cheaper, faster XRF technique may be useful to characterize the variability of

contaminant concentrations, and detect “hotspots” or other spatial patterns of distinct

populations that could compromise the representativeness of the data set. The XRF can

be used to manage sampling uncertainty, while samples established to be representative

of the decision are sent for ICP analysis. The selectivity required to meet project needs

also drives instrument selection. For example, if a decision can be based on total
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polychlorinated biphenyls (PCB) concentrations, immunoassay results may be sufficient.

Decisions requiring homolog or congener-specific PCB analyses will require much more

rigorous methods than field kits can provide. However, as with the XRF example, the

high sampling density provided by the immunoassay method may be critical to

establishing the representativeness of data provided by expensive fixed laboratory

methods.

It is prudent to perform a cost-benefit analysis prior to deciding what mix of field- and/or

fixed-laboratory analyses should be used. While instrument rental costs can be low

relative to fixed-laboratory unit costs, additional personnel are also required in the field

to conduct the analyses. In general, as the number of analyses required to support a

dynamic work plan and manage sampling uncertainty increases, field-based analysis

becomes generally more appealing. As mentioned previously, development of

collaborative data sets to optimize a sampling and analytical strategy will improve the

efficiency of the characterization approach.

The project may also consider running a non-standard method in a fixed laboratory

setting as opposed to running the method in the field. Sometimes logistically and

financially this approach makes more sense and still provides the project team with

timely data at a lower cost.

Question 17: How can analytical costs be managed when using field-based technologies?

Answer 17: When using field-based or real-time measurement strategies, project technical leads

should combine data collection, analysis, review and reporting into unit costs that can be

managed on a daily basis. In this way, as a project grows or shrinks costs can be

managed. Identifying and funding contingencies early in a project can help project

managers avoid unnecessary delays.

Question 18: How can available technologies be identified for use?

Answer 18: EPA identifies several site characterization and monitoring technologies through web

sites for Field-based Analytical Technology Encyclopedia (FATE) (http://fate.cluin.org/),

EPA Environmental Technology Verification (ETV) (http://www.epa.gov/etv/), EPA

Superfund Innovative Technology Evaluation (SITE) Program

(http://www.epa.gov/ORD/SITE), and the Interstate Technology Regulatory Council

(http://www.itrcweb.org). It is also important for the project team to seek out vendor

assistance, but only with the assistance of the team’s own technical experts. Hazardous

Substances Technical Liaisons (http://www.epa.gov/osp/features/factsheets.htm) also are

available for technical support.

Question 19: What documentation will assure that the results obtained are legally and technically

defensible?

Answer 19: Documentation must be sufficient to reproduce a result and to assure stakeholders that

“good scientific practices” were adhered to during the project. The method used should

have been peer reviewed or be sufficiently convincing that the results can stand on their

own merit. There must be evidence that the samples were representative of the matrix

population for the decision being defended. For environmental matrices which tend to be
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highly heterogeneous with great variability in contaminant concentration from place to

place, demonstrating data representativeness has been difficult because of the relatively

higher cost for analysis of a larger number of samples. With the wider availability of

field analytical methods and screening methods for use in fixed-based laboratories (such

as dioxin screening methods), it is now possible to analyze enough samples to ensure data

representativeness. (Also refer to paper by Barton Simmons “Using Field Methods -

Defensibility of Field Data” available at www.cluin.org/.
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APPENDIX B

LIST OF ACRONYMS

AIMTech Advanced Infrastructure Management Technologies

ASAP Adaptive Sampling and Analysis Program

BTSC Brownfields Technology Support Center

COC Contaminants of concern

CSM Conceptual site model

DOE U.S. Department of Energy

EAD Argonne National Laboratory Environmental Assessment Division

EPA U.S. Environmental Protection Agency

ESC Expedited site characterization

FAQ Frequently asked questions

FIELDS FIeld EnvironmentaL Decision Support

GC Gas chromatography

GIS Geographic information systems

GPS Global positioning systems

ICP Inductively coupled plasma

IR Infrared

LDR Land disposal restriction

NAMP National Analytical Management Program

NAWQA National Water-Quality Assessment

ORD EPA Office of Research and Development

OSWER EPA Office of Solid Waste and Emergency Response

PAH Polycyclic aromatic hydrocarbon

PCB Polychlorinated biphenyls
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PNNL Pacific Northwest National Laboratory

RCMS Removal Cost Management System

RFP Request for proposal

RI Remedial investigation

SADA Spatial Analysis Decision Assistance

SAFER Streamlined Approach for Environmental Restoration

SITE Superfund Innovative Technology Evaluation

SOW Statement of work

TCLP Toxicity Characteristic Leaching Procedures

TIO EPA Technology Innovation Office

TPH Total petroleum hydrocarbons

TPP Technical project planning

USACE U.S. Army Corps of Engineers

USGS U.S. Geological Survey

UV Ultraviolet

VOC Volatile organic compound

VSP Visual Sampling Plan

XRF X-ray fluorescence
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APPENDIX C

LIST OF RESOURCES

Brownfields Technology Support Center (http://brownfieldstsc.org) – EPA established the Brownfields

Technology Support Center (BTSC) to ensure that brownfields decision-makers are aware of the full

range of technologies available for conducting site assessments and cleanup, and can make informed

decisions about their sites. The center can help decision-makers evaluate strategies to streamline the site

assessment and cleanup process, identify and review information about complex technology options,

evaluate contractor capabilities and recommendations, explain complex technologies to communities, and

plan technology demonstrations. The center is coordinated through EPA’s Technology Innovation Office

(TIO) and EPA’s Office of Research and Development. Localities can submit requests for assistance

directly through their EPA Regional Brownfields Coordinators; online at brownfieldstsc.org; or by calling

toll free 1-877-838-7220. For more information about the program, contact Dan Powell of EPA TIO at

703-603-7196 or powell.dan@epa.gov.

Hazardous Waste Cleanup Information (CLU-IN) Internet site (http://cluin.org) – The CLU-IN site

provides information about innovative treatment technologies and site characterization technologies to the

hazardous waste remediation community. It describes programs, organizations, publications, and other

tools for Federal and state personnel, consulting engineers, technology developers and vendors,

remediation contractors, researchers, community groups, and individual citizens. 

CLU-IN Case Studies (http://cluin.org/char1.cfm) – As part of a section on Site Characterization, the

CLU-IN web site provides selected case studies which involved use of field analytical technologies. 

These include projects at the Wenatchee Tree Fruit, Oak Ridge Drum Disposal, and Hanscom Air Force

Base sites.

Specific resources available through CLU-IN that provide useful information about the Triad approach

include:

Innovations in Site Characterization Case Study: Site Cleanup of the Wenatchee Tree Fruit

Test Pilot Site Using a Dynamic Work Plan – This case study is designed to provide cost and

performance information for innovative tools that support less costly and more representative site

characterization.

Using the Triad Approach to Improve the Cost-Effectiveness of Hazardous Waste Site

Cleanups – This paper describes the overall strategy of using systematic project planning, dynamic

work plans and real-time measurement technologies to speed cost-effective investigations and

cleanups, while maintaining or improving the defensibility of site decision-making.

Improving Sampling, Analysis, and Data Management for Site Investigation and Cleanup

Fact Sheet (EPA 542-F-01-030a) – This fact sheet discusses the 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.

Resources for Strategic Site Investigation and Monitoring (EPA 542-F-01-030b) – This

document discusses EPA efforts, in concert with other federal agencies and state organizations, in

accelerating the development of policies and information to support Strategic Investigation and

Monitoring activities at hazardous waste sites. The educational, training, and guidance resources

described in this fact sheet either already exist or are under development to support project

managers seeking to apply these approaches.
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EPA Field Analytical Technologies Encyclopedia (http://fate.cluin.org) – FATE is an online

encyclopedia of information about technologies that can be used in the field to characterize contaminated

soil and groundwater, monitor the progress of remedial efforts, and in some cases, for confirmation

sampling and analysis for site closeout.

EPA Remediation And Characterization Innovative Technologies (REACHIT)

(http://www.epareachit.org/) – EPA REACHIT is a system that lets environmental professionals search,

view, download, and print information about innovative remediation and characterization technologies. 

The site uses information submitted by technology service providers about remediation and

characterization technologies and information from EPA, Department of Defense (DoD), Department of

Energy (DOE), and state project managers about sites at which innovative technologies are being

deployed. These sources together provide up-to-date information about technologies that can be used to

characterize or remediate a site, sites at which those technologies are being used, and the service

providers that offer them.

EPA Dynamic Field Activities Internet Site (http://www.epa.gov/superfund/programs/dfa/index.htm)

– This internet site provides information on the draft guidance for dynamic field activities and DFA case

studies. For example, one case study provides cost and performance information for a soil and

groundwater characterization at Hanscom Air Force Base. The site also provides additional information

on systematic planning and dynamic work plans.

EPA ORD’s Office of Science Policy Hazardous Substances Technical Liaison Program

(http://www.epa.gov/osp/features/factsheets.htm) – The program was created jointly by EPA ORD, EPA

OSWER, and the regional offices to expand the technical support available to regional staff.

Road Map to Understanding Innovative Technology Options for Brownfields Investigation and

Cleanup, Third Edition (http://brownfieldstsc.org/publications_index.htm) – The Road Map identifies

potential technology options available at each of the basic phases involved in the characterization and

cleanup of brownfields sites and connects those steps with available resources. The third edition of the

Road Map has been expanded significantly to include new and updated resources, one-page "spotlights,"

and an index of more than 150 resources. Appendices in the Road Map include a list of common

contaminants found at typical brownfields sites, a detailed guide to common environmental terms and

acronyms, and a list of state and EPA points of contact.

EPA’s Environmental Technology Verification Program (www.epa.gov/etv/) – EPA’s ETV Program

develops testing protocols and verifies the performance of innovative technologies that have the potential

to improve protection of human health and the environment. ETV was created to accelerate the entrance

of new technologies into the domestic and international marketplace.

Case Studies

Case studies are provided in several of the resources described above, as well as on related web sites such

as FRTR, SCRD, ITRC, and RTDF.

Federal Remediation Technologies Roundtable (http://www.frtr.gov) – The Federal Remediation

Technologies Roundtable (FRTR) provides more than 300 case studies concerning use of remedial

technologies in site cleanup, as well as more than 100 case studies about site characterization and

monitoring technologies, and 7 reports about optimization of long-term monitoring. The FRTR reports

focus on the cost and performance for use of these technologies, and cover a wide range of technology
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types and contaminants. Recent additions to the FRTR collection include reports addressing cleanup of

groundwater using in situ technologies such as bioremediation, surfactant flushing, chemical oxidation,

thermal treatment, permeable reactive barriers, phytoremediation, air sparging, and in-well air stripping.

State Coalition for Remediation of Dry Cleaners (http://www.drycleancoalition.org) – The State

Coalition for Remediation of Drycleaners (SCRD) consists of representatives of states with established

drycleaner remediation programs, including Alabama, Florida, Illinois, Kansas, Minnesota, Missouri,

North Carolina, Oregon, South Carolina, Tennessee, and Wisconsin. The SCRD provides more than 60

case studies covering a diverse set of innovative treatment technologies used at dry cleaner sites.

Interstate Technology Regulatory Council (http://www.itrcweb.org) – The Interstate Technology

Regulatory Council (ITRC) is a state-led coalition working together with industry and stakeholders to

achieve regulatory acceptance of environmental technologies, and consists of more than 35 states, the

District of Columbia, multiple federal partners, industry participants, and other stakeholders. The ITRC

has prepared more than 15 guidance documents on technical topics, many of which include selected case

studies.

Remediation Technology Development Forum (http://www.rtdf.org) – The Remediation Technology

Development Forum (RTDF) is a public-private partnership to undertake research, development,

demonstration, and evaluation efforts focused on finding innovative solutions to high priority problems. 

It consists of six action teams, covering subjects such as bioremediation, NAPLs, permeable reactive

barriers, phytoremediation, and sediments. These action teams publish materials including information

about specific sites where technologies have been applied.

EPA Superfund Innovative Technology Evaluation (SITE) Program

(http://www.epa.gov/ORD/SITE) – The SITE Program was established by EPA's OSWER and the ORD

in response to the 1986 Superfund Amendments and Reauthorization Act, which recognized a need for an

"Alternative or Innovative Treatment Technology Research and Demonstration Program." The SITE

Demonstration Program encourages the development and implementation of innovative treatment

technologies for hazardous waste site remediation, monitoring, and measurement. In the SITE

Demonstration Program, technologies are field-tested on hazardous waste materials. Engineering and

cost data are gathered on the innovative technology so that potential users can assess the technology's

applicability to a particular site.

U.S. EPA Hazardous Substance Research Centers (www.jhu.edu/hsrc, www.mhsrc.org,

http://www.toscprogram.org/, www.toscprogram.org, http://wrhsrc.orst.edu/) – In 2001, EPA

established five new university-based HSRCs affiliated with 22 universities. The Centers address

concerns about hazardous substances in the environment by conducting basic and applied research, and

providing technology transfer and community outreach. The Centers work on the remediation and

redevelopment of brownfields and Superfund sites.

Training

Classroom (http://trainex.org) – In partnership with the ITRC, TIO provides a range of training

information to EPA, other federal agency, state, tribal, and local staff involved in hazardous waste

management and remediation. Trainex.org includes training schedules for deliveries of many courses,

both classroom and Internet-based. Training Coordinators, On-Scene Coordinators (OSC), Remedial

Project Managers (RPM), Permit Writers, Corrective Action Managers, Site Assessment Managers

(SAM), enforcement staff, Community Involvement Coordinators (CIC), state program managers, and

others will find training courses and information directly targeted to their needs.
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Internet seminars (http://cluin.org/studio) – CLU-IN's ongoing series of Internet Seminars are webbased slide presentations with a companion audio portion. TIO provides two options for accessing the

audio portion of the seminar, by phone line or streaming audio simulcast. More information and

registration for all Internet Seminars is available by selecting the individual seminar listed on the site.
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APPENDIX D

DESCRIPTIONS OF COMMONLY USED FIELD-BASED

SAMPLING AND ANALYTICAL TECHNOLOGIES

Direct-Push Sampling – Direct-push sampling platforms have gained widespread acceptance in the

environmental industry over the past decade because of their versatility, relatively low cost, and mobility. 

As opposed to drilling techniques in which soil is removed and a borehole is produced, direct-push units

use hydraulic pressure to advance sampling devices and geotechnical and analytical sensors into the

subsurface. The weight of the truck in combination with a hydraulic ram or hammer is used to “push” the

tool string into the ground. With this, no soil is removed, and only a very small borehole is created. The

two major classes of direct-push platforms are cone penetrometer (CPT) and rotary hammer systems. 

While “CPT” technically refers only to the geotechnical cone penetrometer instruments advanced by

these large vehicles, the vehicles themselves have come to be known by this designation. The distinction

between these units is that CPT advance the tool string by applying a hydraulic ram against the weight or

mass of the vehicle alone, while rotary hammer units add a hydraulic hammer to the hydraulic ram to

compensate for their lower mass. These platforms share the same principle of operation, similar tools,

and a number of advantages and limitations. They differ in scale, application, and to some extent the

types of instruments and tools that have been developed for each. For these reasons, CPT and rotary

hammer platforms fill different niches in the environmental field.

Gas Chromatography – Gas chromatography (GC) analysis is a widely used technique for field-based

analysis. Analysis of organic compounds is possible for a variety of matrices such as water, soil, soil gas,

and ambient air. Typical settings include: (1) site characterization, (2) stationary source testing and

monitoring, (3) hazardous waste sites for determining personal protective equipment (PPE) level, (4)

fence line monitoring during removal or remediation activities, and (5) emergency response testing. GC

analysis with photoionization detection has been used extensively to characterize and remediate sites

contaminated with VOCs. Likewise, gas chromatographs coupled with an electron capture detector are

used for analysis on sites contaminated with chlorinated pesticides. The recent development of truly field

portable quadrupole mass spectrometers now permits GC-mass spectrometry analysis which provides

definitive identification. This instrument and technique is being implemented during emergency response

and counter-terrorism situations that require definitive identification of contaminants in near real-time. 

Geophysics – Geophysical surveys are useful for characterization of the geology or hydrogeology of a

site, detection and mapping of contamination, detection of geological conditions favorable for

contaminant migration, and evaluation of past site uses. There are three primary geophysical methods: in

situ, surface, and borehole. In situ geophysical measurements typically are made by placing a probe or

sensor into the media of interest in such a way that causes minimal disturbance of the media. Surface

geophysical techniques usually result in no significant disturbance of the subsurface media – surface

sensors may be in contact with the ground surface or held above the ground surface. Borehole

geophysical measurements are made only after a boring has been made into the media of interest. The

sensor itself may not actually contact the walls of the borehole.

Immunoassay – Immunoassay is a widely-accepted field analytical technology for many organic

contaminants and classes of contaminants (and at least one inorganic contaminant). Various

immunoassay kits and methods are tailored to specific classes of environmental contaminants. 

Immunoassay uses antibodies that have been developed to bind with a target compound or class of

compounds. The technology has been used widely in the environmental field because the antibodies can

be highly specific to the target compound or group of compounds and because the kits are relatively quick

and simple to use. Concentrations of analytes are identified through the use of a sensitive colorimetric
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reaction. The determination of the target analyte’s presence is made by comparing the color developed by

a sample of unknown concentration with the color formed by the standard containing the analyte at a

known concentration. The concentration of the analyte is determined by the intensity of color in the

sample. The concentration can be estimated roughly by the naked eye or can be determined more

accurately with a photometer or spectrophotometer.

Laser-Induced Fluorescence – Laser-induced fluorescence (LIF) is a method for real-time, in-situ, field

screening of hydrocarbons in undisturbed subsurface soils and groundwater. The technology is intended

to provide highly detailed, qualitative to semiquantitative information about the distribution of subsurface

petroleum contamination. LIF sensors are deployed as part of integrated mobile CPT systems that are

operated by trained technicians. There are currently two major LIF systems available, the Site

Characterization and Analysis Penetrometer System (SCAPS) and Rapid Optical Screening Tool

(ROSTTM) systems. The SCAPS LIF system is one of several CPT-mounted sensors developed through a

collaborative effort of the Army, Navy, and Air Force under the Tri-Services Program. The ROSTTM

system was developed by Loral Corporation and Dakota Technologies, Inc. The SCAPS LIF is available

only through the U.S. Army Corps of Engineers and the U.S. Navy. ROSTTM is available commercially

through Fugro, Inc. 

Mass Spectrometry – In the environmental field, mass spectrometers (MS) are typically used as

detectors for GCs. Because of the increased durability of modern instruments, field gas

chromatographs/mass spectrometers (GC/MS) are capable of the same analyses as fixed laboratory

instruments. 

X-Ray Fluorescence – Energy dispersive X-ray fluorescence (XRF) is a method of detecting metals and

other elements, such as arsenic and selenium, in soil, sediment, and water. Some of the primary elements

of environmental concern that XRF can identify are arsenic, barium, cadmium, chromium, copper, lead,

mercury, selenium, silver, and zinc. Field-portable XRF units that run on battery power and use a

radioactive source were developed for use in analysis for lead-based paint and now are accepted as a

stand-alone technique for lead analysis. In response to the growing need for field analysis of metals at

hazardous waste sites, many of these field-portable XRF units have been adapted for use in the

environmental field. They provide data in the field that can be used to identify and characterize

contaminated sites and guide remedial work, among other applications.