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Using Dynamic Field Activities for
On-Site Decision Making:
A Guide for Project Managers
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OSWER No. 9200.1-40
EPA/540/R-03/002
May 2003
www.epa.gov
Using Dynamic Field Activities
for On-Site Decision Making:
A Guide for Project Managers
Office of Solid Waste and Emergency Response
U.S. Environmental Protection Agency
Washington, DC 20460
Recycled/Recyclable
Fnnsecl wih Soy.Carwia ink OT paper i
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NOTICE
This document was developed with funding from the United
States Environmental Protection Agency (EPA) under
Contract 68-W-02-033 and has been approved for publica-
tion only after being subjected to the Agency's review
process.
The procedures set forth in this document are intended as
guidance for employees of the EPA, states, and other
governmental agencies. EPA officials may decide to follow
the guidance provided in this document, or to act at variance
with it, based on analysis of site specific conditions. EPA
also reserves the right to modify this guidance at any time
without public notice. Interested parties are free to raise
questions and objections about the substance of this
guidance and the appropriateness of the application of this
guidance to a particular situation. In addition, the Agency
welcomes public input on this document at any time.
This guidance does not constitute EPA rulemaking and
cannot be relied upon to create any rights enforceable by any
party in litigation with the United States.
Mention of trade names, products, or services does not
convey, and should not be interpreted as conveying, official
EPA approval, endorsement, or recommendation.
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Acknowledgments
This document was developed by EPA's Office of Solid Waste and
Emergency Response with oversight and review provided by the U.S.
Army Corps of Engineers and the following EPA programs:
Office of Administration and Resources Management
Office of Research and Development
Office of Air and Radiation
Office of General Counsel
Office of Enforcement and Compliance Assurance
Office of Environmental Information
Region 1
Region 2
Region 3
Region 4
Region 5
Region 6
Region 7
Region 8
Region 9
Region 10
Additional contributions and comments were provided by:
U.S. Air Force
U.S. Navy
Argonne National Laboratory
Pacific Northwest Laboratory
Florida Department of Environmental Protection
New Jersey Department of Environmental Protection
California Environmental Protection Agency
Boulding Soil-Water Consulting
Ecology and Environment, Inc.
Transglobal Environmental Geochemistry
Gary Struthers Associates, Inc.
Tetra Tech NUS, Inc.
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Contents
Page
Exhibits xii
Abbreviations xiii
Chapter I: Introduction 1-1
Purpose 1-1
Intended Audience 1-1
Scope and Limitations I-2
How To Use This Guidance I-4
Chapter II: Overview of the On-Site Decision-Making Process 11-1
Overview 11-1
Section 1: The On-Site Decision-Making Process II-3
Step 1: Using a Systematic Planning Process II-4
Step 2: Preparing a Dynamic Work Plan II-4
Step 3: Conducting a Dynamic Field Activity II-5
Step 4: Writing a Final Report II-6
Section 2: Applying Dynamic Field Activities to
Contaminated Sites II-7
Characterization II-7
Cost-Effective, Rapid, and Comprehensive Site
Characterization II-7
Integration of Characterization and Remedy
Evaluation Tasks II-9
Smooth Transition to Subsequent Remediation
Activities II-9
Improving Risk Assessments 11-10
Increasing Knowledge About Site
Conditions 11-10
Including Risk Assessors in Field Decision
Making 11-10
Cleanup 11-10
Optimize a Cleanup Technology 11-11
Confirm That Cleanup Objectives Have Been
Achieved 11-11
Segregate Soil for Various Treatment Options . . 11-11
Monitoring 11-12
Initial Site Screening 11-12
Evaluating Several Potential Exposure
Pathways or Sources Areas 11-13
Planning Field Work at Sites with Known
Class of Potential Contaminants 11-13
Linking Source Area to a Receptor 11-14
vii
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Assessing Actual Human Health or Ecological
Risk 11-14
Sections: Special Considerations of Dynamic Field Activities 11-15
Additional Preparatory Planning 11-15
Contingency Budgeting 11-16
Increased Agency Oversight 11-16
Availability of Rapid Analytical Methods 11-17
Experienced Technical Staff 11-17
Conclusion 11-18
Chapter III: Managing Dynamic Field Activities 111-1
Overview 111-1
Section 1: Using Systematic Planning to Develop a
Dynamic Work Plan III-3
Systematic Planning III-3
Dynamic Work Plan III-4
Oversight of Subcontractors III-7
Documenting the Decision-Making Process .... III-7
Sampling and Analysis Plan III-7
Quality Assurance Project Plan III-8
Contingency Procedures III-8
Decision-Making Procedures III-9
Standard Operating Procedures III-9
Quality Control Samples 111-10
Field Laboratory Audits 111-10
Field Sampling Plan 111-11
Contingency Planning 111-11
Decision-Making Procedures 111-13
Standard Operating Procedures 111-13
Data Management Plan 111-14
Communications Strategies 111-14
Data Summaries 111-14
Contingency Procedures 111-16
Data Format, Entry, and Display 111-16
Community Involvement Plan 111-16
Section 2: Determining Funding Needs 111-18
Developing an Independent Cost Estimate 111-18
Step 1: Estimate Minimum Work That Will Be
Needed 111-18
Step 2: Develop Decision Trees 111-19
Step 3: Develop List of Unit Costs 111-19
Evaluating Field Analytical Equipment Needs III-20
Renting Analytical Equipment III-20
Buying Analytical Equipment 111-21
Acquiring a Controlled Space 111-21
Acquiring a Qualified Analytical Equipment
Operator 111-21
viii
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Addressing Funding Limitations 111-22
Section 3: Ensuring the Selection of Qualified Personnel. . . 111-23
Planning Team Member Responsibilities and
Qualifications 111-24
Technical Team Leader 111-26
Project Hydrogeologist/Geologist 111-26
Project Chemist 111-27
Project Environmental Engineer 111-27
Project Geophysicist 111-27
Project Risk Assessor (Human Health and/or
Ecological) 111-28
Project Statistician 111-28
Community Involvement Coordinator 111-28
Health and Safety Specialist 111-28
Information Technology Specialist 111-29
Data Management Specialist 111-29
Field Team Member Responsibilities and Qualifications 111-29
Field Analytical Equipment Operators 111-30
Field Geologist 111-31
Field Technician/Sampler 111-31
Specialty Samplers 111-31
Selecting Technical Specialty Firms 111-31
Section 4: Preparing and Overseeing the Field Work III-33
Organizing a Kick-Off Meeting III-33
Obtaining Commitments for Technical Consultation . III-34
Oversight Teams III-34
Technical Review Teams III-34
Developing Decision Points III-35
Establishing a Meeting Schedule III-35
Preparing for Data Exchange III-36
Data Required for Decision Making III-36
Data Transfer Schedule and Format III-37
Conclusion III-38
Chapter IV: Key Considerations for Meeting Project Requirements with
Field-Based Analytical Methods IV-1
Overview IV-1
Section 1: Selecting Field-Based Analytical Methods IV-3
Principal Method Selection Process IV-3
Initial Method Selection Criteria IV-5
Method Sensitivity IV-5
Detection Limits IV-6
Quantitation Limits IV-6
Method Selectivity IV-6
Dynamic Range IV-7
Additional Measurement Performance Criteria . . IV-8
Precision and Accuracy IV-8
ix
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Indirectly Measuring Target Compounds . IV-8
Practical Considerations for Analysis in
the Field IV-9
Method Applicability Studies IV-10
Alternative Selection Strategies If Existing Methods
Do Not Meet Project Requirements IV-11
Altering Project Requirements IV-11
Modifying Existing Methods IV-12
Developing a New Method IV-12
Method Validation Studies IV-13
Section 2: Applying Quality Assurance and Quality Control to
Field-Based Analytical Methods IV-14
Quality Assurance IV-14
Establishing Quality Assurance Project Plans . IV-15
Developing Standard Operating Procedures .. IV-15
Evaluating the Type and Frequency of Quality
Assurance Audits IV-15
Quality Control IV-16
Quality Control Sample Analysis IV-16
Evaluating "Confirmation" Analyses .... IV-17
Selecting Split Samples IV-19
Documenting Quality Control Results IV-19
Data Review IV-20
Section 3: Managing Data During a Dynamic Field Activity . IV-22
Data Flowcharts IV-22
Data Management Readiness Review IV-25
Document Review IV-25
Data Verification IV-25
Data Validation IV-26
Data Tracking Systems IV-26
Document Control IV-27
Data Visualization IV-27
Conclusion IV-29
Chapter V: Dynamic Field Activity Case Study Summaries V-1
Overview V-1
Section 1: Soil and Groundwater Characterization, Marine Corps
Air Station Tustin V-4
Background V-4
Innovative Approach V-4
Results V-6
Lessons Learned V-6
Section 2: Soil and Sediment Cleanup, Loring Air Force Base . V-7
Background V-7
Innovative Approach V-7
Results V-8
Lessons Learned V-8
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Section 3: Treatment System Optimization, Umatilla Chemical
Depot V-10
Background V-10
Innovative Approach V-11
Results V-11
Lessons Learned V-11
Section 4: Innovative Dynamic Strategies During Initial Site
Screening V-13
B&M Laundromat, Escambia County, Florida V-13
Innovative Approach V-14
Results V-14
Potential Benefits and Applications V-15
Jacobs Smelter, Stockton, Utah V-15
Innovative Approach V-15
Results V-16
Potential Benefits and Applications V-16
Iceland Coin Laundry and Dry Cleaning, Vineland,
New Jersey V-17
Innovative Approach V-17
Results V-17
Potential Benefits and Applications V-17
Conclusion V-19
References R-1
Appendix A: Daily and Weekly Activity Summary Reports A-1
Appendix B: Qualification Worksheets B-1
Appendix C: Summary of Detection Limits for Selected Field-Based
Analytical Methods C-1
Glossary G-1
XI
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Exhibits
Exhibit Page
1-1 Comparison of Field Activity Terms Used by EPA Contaminated
Site Cleanup Programs I-4
11-1 Schematic of the On-Site Decision-Making Process II-3
II-2 Summary of Applications to Contaminated Site Activities II-8
111-1 Summary of Issues to be Covered by Project Planning
Documents for a Dynamic Field Activity III-6
III-2 Example Decision Tree for TCE Release Investigation 111-12
III-3 Example Communication Strategy 111-15
III-4 Summary of Planning Team Member Qualifications III-25
III-5 Summary of Field Team Member Qualifications III-30
IV-1 Method Selection Process Overview IV-4
IV-2 Summary of Quality Control Sample Issues IV-18
IV-3 Summary of Documentation Issues IV-20
IV-4 Summary of Data Management Issues IV-23
IV-5 Screening Sampling Data Management Flow Diagram IV-24
V-1 Summary of Dynamic Field Activity Case Studies V-2
V-2 Summary of Several Previously Reported Dynamic Field Activity
Case Studies V-3
V-3 Summary of Innovative Dynamic Strategies During Initial Site
Screening V-13
XII
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Abbreviations
ASTM American Society for Testing and Materials
BAP benzo(a)pyrene
bgs below ground surface
BRAC Base Realignment and Closure
BTEX benzene, toluene, ethylbenzene, and xylenes
CERCLA Comprehensive Environmental Response, Compensation, and
Liability Act
CFR Code of Federal Regulations
CLP Contract Laboratory Program
CLU-IN Clean-Up Information System
CRREL Cold Regions Research and Engineering Laboratory
DDD di chl orodiphenyl di chl oroethane
DDE di chl orodiphenyl di chl oroethene
DDT dichlorodiphenyltrichloroethane
DNAPL dense nonaqueous phase liquid
DOD United States Department of Defense
DOE United States Department of Energy
DP direct push
DQA data quality assessment
DQO data quality objective
ECD electron capture detector
EPA United States Environmental Protection Agency
ERT Environmental Response Team
ESAT Environmental Services Assistance Team
FAM field-based analytical method
FASP Field Analytical Support Programs
FID flame ionization detector
FS feasibility study
FSP field sampling plan
GAC granular activated carbon
GC gas chromatograph
GIS geographic information systems
HMX high melting explosive
HRS Hazard Ranking System
ICP inductively coupled plasma
IRP Installation Restoration Program
ISE ion-specific electrode
MCAS Marine Corps Air Station
MCL maximum contaminant level
Hg/kg micrograms per kilogram
|ig/L micrograms per liter
mg/kg milligrams per kilogram
XIII
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mg/L milligrams per liter
ng/L nanograms per liter
MS mass spectrometry
ND nondetect
NPL National Priorities List
NOAA National Oceanic and Atmospheric Administration
O&M operation and maintenance
OES optical emission spectroscopy
OERR Office of Emergency and Remedial Response
OSWER Office of Solid Waste and Emergency Response
OU operable unit
PAH polyaromatic hydrocarbon
PCB polychlorinated biphenyl
PCE tetrachloroethene or perchloroethene
PE performance evaluation
PID photoionization detector
ppb parts per billion
ppm parts per million
PRP potentially responsible party
QA quality assurance
QAPP quality assurance project plan
QC quality control
RCRA Resource Conservation and Recovery Act
RDX royal demolition explosive
RI remedial investigation
RI/FS remedial investigation/feasibility study
SAP sampling and analysis plan
SCAPS Site Characterization and Analysis Penetrometer System
SOP standard operating procedure
TCE trichloroethene
TNT trinitrotoluene
TRPH total recoverable petroleum hydrocarbons
U.S. EPA United States Environmental Protection Agency
USAGE United States Army Corps of Engineers
UST underground storage tank
VOC volatile organic compound
XRF X-ray fluorescence
XIV
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Chapter I
Introduction
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Chapter I
Introduction
Purpose
This document provides environmental cleanup professionals with
guidance on how to use an on-site decision-making process to streamline field
work at contaminated sites. Because of the adaptive nature of this process, it can
be applied to all U.S. Environmental Protection Agency (EPA) programs within
the Office of Solid and Emergency Response (OSWER), including the
Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA), Resource Conservation and Recovery Act (RCRA) corrective
action, Brownfields, and leaking underground storage tanks. Sites that have used
on-site decision making, as reviewed in Chapter V, consistently demonstrated
that this process reduces the time needed to meet project objectives, reduces the
cost of site activities, and increases confidence in the decisions, thereby improving
the overall quality of field work.
Proper implementation of an on-site decision-making process depends on
three key elements: thorough systematic planning, development of "dynamic" or
"flexible" work plans, and quick turnaround analytical methods—typically
provided by field-based analytical methods. While systematic planning is an
established and essential component of all types of data collection efforts, the
other two elements have generally not been well understood by regulators,
contractors, and industry. In particular, there has been a general misconception
that data generated in the field cannot withstand judicial scrutiny. In reality,
however, as long as field generated data meet project requirements with an
appropriate level of quality control procedures and documentation to support its
scientific defensibility, the data are generally legally defensible.
Consequently, this guidance focuses on how project managers can use
dynamic work plans and field-based analytical methods to meet project require-
ments and streamline site activities. The guidance provides an overview of the
entire process to provide some context for the use of these two issues. Also
provided are examples of how this process has already been successfully utilized.
On-site decision making
is applicable for all
types of data collection
activities, and it can
provide a "better, faster,
cheaper" method of
doing business.
Systematic planning,
dynamic work plans,
and quick turnaround
analytical results are
key elements to suc-
cessfully using an on-
site decision-making
process.
Intended Audience
The primary audience for this guidance is contaminated site project
managers who have the primary responsibility for carrying out regulatory response
activities at their assigned sites. In addition, this guidance is designed to help
educate other key participants (e.g., relevant EPA personnel, contractors, other
federal and state agencies, industry) about the on-site decision-making process so
1-1
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that these groups can work in concert with EPA project managers when imple-
menting these projects.
Although this document is written primarily for EPA programs, the ideas
and recommendations contained within it are generally applicable for any field
work at a contaminated site because the data generation and decision-making
issues are similar, regardless of a site's regulatory status. As such, this guidance
may also be useful for individuals undertaking assessment, characterization,
remediation, and monitoring at sites being managed by federal facilities, states, or
tribes.
Scope and Limitations
The material presented in this guidance is based on the knowledge and
experience of the authors and peer reviewers, as well as the latest available
technical data and information. However, this document cannot provide project
managers with definitive or comprehensive recommendations that are broadly
applicable for all situations; nor can it resolve all of the questions and issues
involved with implementing an on-site decision-making process. Consequently,
project managers will need to seek the assistance of experts from their regional
offices, contractors, or other government agencies (e.g., U.S. Army Corps of
Engineers, U.S. Geological Survey). Other initiatives and resources that can
provide additional support to project managers include:
• The "Triad" campaign (http://clu-in.org). which promotes the use of
systematic planning, dynamic work plans, and quick turnaround
measurements for streamlining site activities through a number of
projects that complement this guidance;
• Fully Integrated Environmental Location Decision Support (FIELDS)
(http://www.epa.gov/region5fields/static/pages/index.html) is a software
system that integrates geographic information systems, a global position-
ing system, imaging software, and in-field sampling and analysis
technologies;
• Spatial Analysis and Decision Assistance (SADA)
(http://www.tiem.utk.edu/~sada/) is a software program, partially funded
by EPA, that integrates visualization, geospatial analysis, statistical
analysis, human health risk assessment, cost-effective analysis, sampling
design, and decision analysis;
• Performance-based measurement systems (PBMS) (http://www.epa. gov/
SW-846/pbms.htm) is an approach that emphasizes the use of analytical
methods according to decision objectives rather than through regulation;
• U.S. EPA, 1997. Expedited Site Assessment Tools for Underground
Storage Tank Sites: A Guide for Regulators, EPA 510-B-97-001. Office
This guidance is only
one piece of a larger
initiative to improve
contaminated site
decision making.
1-2
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of Solid Waste and Emergency Response, Washington, DC.
http://www.epa.gov/swerustl/pubs/index.htm : and
ASTM D6235-98, Standard Practice for Expedited Site Characterization
of Vadose Zone and Groundwater Contamination at Hazardous Waste
Contaminated Sites, and ASTM E1912-98, Standard Guide for Accelera-
ted Site Characterization of Confirmed or Suspected Petroleum Releases.
http://www.astm.org.
The text has been written in very general terms that are applicable to a
broad range of programs and conditions. Consequently, the term "project
manager" is used unless the information is applicable for only a specific type of
project manager (e.g., on-scene coordinator, remedial project manager). Likewise,
generic terms are used to describe activities throughout the phases of
contaminated site work, such as characterization, cleanup, and monitoring.
When the text is applicable to all phases of site work, terms like "field activities"
or "field work" are commonly used. Program-specific terminology is used only
in the context of providing examples. Exhibit 1-1 summarizes the field activity
terms used by the programs within OSWER and how they relate to each other.
The on-site decision-making process promoted in this guidance refers to
decisions being made while equipment and personnel are in the field, ready to
follow through with decisions made by experienced staff, regulators, and stake-
holders. The term "on-site decision making" is not intended to imply that all of
the decision-makers need to be on site. On the contrary, through the use of
modern information technologies, many decision makers may be able to provide
their input from remote locations. In addition, this process does not encourage
project personnel to make unlimited decisions about site activities; rather, the site
decisions should be limited to the scope of work outlined in the project planning
documents. The on-site decision-making process is further limited by legal
restrictions for some regulatory programs that require a formal review process
before certain additional site activities may occur. For example, CERCLA
requires a 30-day public comment period for proposed remedies at National
Priority List (NPL) sites.
In addition, this document defines the term "field-based analytical
methods" as a broad category of analytical methods that can be applied at the site
during sample collection activities. The definition encompasses methods that can
be used outdoors, as well as those that require the controlled environments of a
mobile laboratory. Although using field-based analytical methods is the most
common approach to supporting an on-site decision-making process, this
guidance does not intend to imply that they are the only means. For instance, off-
site laboratories may be appropriate when they can provide data at a competitive
price within the time frame needed for on-site decision making. The selection of
the most appropriate analytical methods should be determined on a site-specific
basis. This document uses the terms "quick turnaround," "rapid," or "timely," to
refer to data generation methods used to support on-site decision making.
On-site decision
making is limited by
program specific
legislation and
regulations as well as
the scope of work
described in the
project planning
documents.
Examples of the types
of decisions that may
be made with an on-
site decision making
process include:
- Placement of
monitoring wells;
- Determining if
cleanup objectives
have been met;
- Timing of carbon
change-out for pump
and treat systems.
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Exhibit 1-1
Comparison of Field Activity Terms Used by EPA Contaminated Site
Cleanup Programs
CERCLA
Remedial
Program
Preliminary
Assessment/
Site Inspection
Remedial
Investigation
Feasibility Study
Remedial
Design/Remedial
Action
Operation and
Maintenance
CERCLA
Removal
Program
Removal Site
Evaluation
Engineering
Evaluation/Cost
Analysis*
Removal Action
Post-removal site
control
RCRA
Corrective Action
Program
RCRA Facility
Assessment
RCRA Facility
Investigation
Corrective Measures
Study
Solid Waste
Management Unit
Closure
Corrective Measures
Implementation
Interim Measure
Operation,
Maintenance, and
Monitoring
LUST Site
Investigation
Characterization
Assessment
Corrective Action Plan
Remediation
Cleanup
Interim Measure
Monitoring
*Non-time critical removal actions only.
How To Use This Guidance
EPA encourages project managers to use this guidance as a reference
document during the planning and management of their projects. To help readers
find the information they need for a particular activity, several features have been
developed. First, text boxes, summary tables, and figures are provided to high-
light major points. Second, the text has been organized into many brief sections
each with a subtitle heading so that subject areas of particular interest can be
quickly found and reviewed. Third, supporting documentation and additional
resources have been added to the appendices and referenced to web pages. Lastly,
web site addresses are included in the reference section wherever possible. Older
EPA documents (e.g., pre-1996) that do not have a specific website address may
be accessed at http://www.epa.gov/ncepihom/nepishom/index.html where a scan-
ned copy is generally available. Finally, Chapter n has been developed as an
overview for the guidance. As such, it provides a "roadmap" for finding key
information within the rest of the guidance.
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Following this chapter, the guidance is divided into four subject areas:
Chapter n Overview of the On-Site Decision-Making Process. This chapter
presents an overview of the activities needed to successfully imple-
ment on-site decision making, how the process can be applied to
different phases of field work, and some of the special considera-
tions that are needed for proper implementation.
Chapter HI Managing Dynamic Field Activities. This chapter provides project
managers with information to put a dynamic work plan in place,
ensure that qualified staff work on the project, and oversee site
activities.
Chapter IV Key Considerations for Meeting Project Requirements with Field-
Based Analytical Methods. This chapter describes steps that can be
used to enhance the scientific defensibility of data generated with
field-based analytical methods for on-site decision making.
Chapter V Dynamic Field Activity Case Study Summaries. This chapter
provides brief examples of how on-site decision-making processes
have been used at different sites. The full texts of these case
studies are available at
http://www.epa.gov/superfund/programs/dfa/casestudies.
Examples include soil and groundwater characterization; soil and
sediment cleanup; and treatment system optimization. In addition,
three examples of a dynamic approach being applied during initial
site screening are provided.
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Chapter II
Overview of the On-Site Decision-Making
Process
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Chapter II
Overview of the On-Site Decision-Making Process
Overview
This chapter provides an overview of the on-site decision-making process,
its applications for contaminated site cleanup programs, and special
considerations that help to avoid problems in the field. This process necessitates
systematic planning, dynamic work plans, and rapid analytical results. The
resulting project is a dynamic field activity—an approach that combines on-site
data generation with on-site decision making. The term "dynamic" is used
because these field activities are designed to incorporate changes as new
information is obtained, thus, accommodating the iterative nature of field work at
contaminated sites. Consequently, dynamic field activities help project managers
reach site decisions while avoiding numerous planning efforts and field mobiliza-
tions that would otherwise be necessary. Because of its flexible approach, this
process is applicable to all data collection
activities (e.g., initial site screening,
characterization, remediation, monitoring).
Dynamic field activities contrast with the
"traditional" staged approach where site decisions
are made after all the data have been collected and
evaluated, typically many weeks after sampling
equipment has been demobilized from the site.
This approach entails using numerous
mobilizations to complete projects in stages. The
project scopes are similar to dynamic field
activities, however, iterations are guided during
off-site evaluations rather than through on-site
decision making.
The dynamic approach can eliminate many
of the mobilization stages by collecting the data
needed for decision making before the field work
is terminated. This concept is not new. A number
of sites have successfully used this process already
and it has been promoted by a number of different
programs. Of particular interest for large complex sites is the ASTM Expedited
Site Characterization standard (ASTM, 1998a). For less complicated petroleum
sites with leaking underground storage tanks, the ASTM Accelerated Site
Characterization standard (ASTM, 1998b) and EPA''s Expedited Site Assessment
On-Site Decision Making is Not New
Several programs have promoted on-site decision
making for streamlining field work at contaminated
sites:
• Common practice in the CERCLA removal
program.
• Expedited Site Characterization by DOE
(Burton, 1993) and ASTM (ASTM, 1998a)
• Accelerated Site Characterization (for UST
sites) by ASTM (ASTM, 1998b).
• Expedited Site Assessment promoted by
EPA's Office of Underground Storage Tanks
(U.S. EPA, 1997c).
• Described as a Triad Approach (Crumbling,
2000).
• Rapid Site Assessment used by the State of
Florida (Applegate and Fitton, 1997).
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Tools for Underground Storage Tank Sites (U.S. EPA, 1997c) are particularly
relevant. The key features promoted in all of these initiatives include:
• Thorough systematic planning carried out by experienced technical staff
that will be involved in the actual field work;
• Cooperation of all stakeholders throughout the planning and implementa-
tion process;
• Flexible sampling and analytical plans;
• Reliance on quick turnaround analytical methods; and
• Strategies to minimize mobilizations.
The benefits of integrating these features into project activities are signifi-
cant. As demonstrated through numerous case studies documented in Chapter V,
dynamic field activities can help to:
• Reduce administrative costs for regulators and contractors by eliminating
iterations of project planning, interim report writing, and document
review;
• Reduce remediation costs through detailed site characterization that can
help focus subsequent field work;
• Improve project quality control;
• Eliminate delays in getting results caused by an over-booked off-site
laboratory, thereby increasing the effective use of excavation equipment;
• Improve data quality that meet all decision criteria established in project
planning documents;
• Improve overall project efficiency;
• Reduce total project costs by 15 to 45 percent; and
• Reduce project time by 33 to 60 percent.
The following chapter provides an overview of the concepts that are
important in using an on-site decision-making process and also refers the reader to
other sections of this guidance for more detail on specific topics. The description
of this process is not intended to imply that only purely dynamic projects provide
benefits to contaminated sites. On the contrary, many times a hybrid use of on-
site decision making and staged activities are appropriate depending on a number
of factors, including staff experience level, available funding, and knowledge of
site conditions.
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Section 1: The On-Site Decision-Making Process
On-site decision making provides an iterative, flexible framework for
collecting data and making site decisions throughout contaminated site activities.
The schematic drawing presented in Exhibit II-1 summarizes the four step process
as:
Using a systematic planning process;
Preparing a dynamic work plan that documents an on-site decision-making
strategy;
Conducting a dynamic field activity; and
Writing a final report.
Exhibit 11-1
Schematic of the On-Site Decision-Making Process
Final Report
Systematic Planning
Dynamic
Field Activity
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Step 1: Using a Systematic Planning Process
Systematic planning is a process that is based on the scientific method.
In the context of a contaminated site it is a transparent, deliberate, coordinated
effort to identify and manage decision uncertainty with minimal decision errors.
Because dynamic field activities rely on clearly developed goals to effectively
guide the field work, systematic planning is particularly important for their
successful execution. To facilitate the use of a systematic planning process for
data collection, EPA has developed guidance (U.S. EPA, 2000d) which recom-
mends the use of data quality objectives (DQOs). Regardless of the formal
process used, systematic project planning should entail:
Reviewing existing site information;
Selecting key personnel;
Identifying the project objectives;
Developing an initial conceptual site model;
Preparing sampling and measurement strategies; and
Selecting appropriate analytical methods, equipment, and contractors.
The development of an initial conceptual site model in the systematic
planning process is an essential activity. Commonly, it is presented in a series of
maps and diagrams that include contaminant release mechanisms, geological
features, migration pathways, human and ecological receptors, and other informa-
tion important for understanding site conditions. This information is used for
making sampling and analytical decisions. The conceptual site model is updated
during a dynamic field activity so that subsequent on-site decisions can be based
on all available information. Consequently, this process necessitates that decision
makers establish methods for reviewing their initial assumptions, integrating new
data, and modifying the conceptual site model accordingly. Electronic tools for
accomplishing this integration from both the communication and management
perspectives are discussed in Chapter in, Managing Dynamic Field Activities and
Chapter IV, Key Considerations for Meeting Project Requirements with Field-
Based Analytical Methods. The cleanup case study of Loring Air Force Base,
summarized in Chapter V, provides an example of how this process can be
accomplished.
Step 2: Preparing a Dynamic Work Plan
After the initial phase of systematic planning has been completed, project
planners may prepare a dynamic work plan—the document that provides the
project team with the lines of communication and on-site decision-making
The key to a successful
dynamic field activity
is communication.
Project managers need
to meet with the impor-
tant decision makers
and stakeholders to
identify problems and
agree on the approach
to the site early in the
planning process.
Dynamic work plans
document the approach
and rationale behind the
on-site decision-making
process.
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strategy. It outlines a sequence of activities that accommodate the decision-
making process and stakeholder involvement to keep the project moving forward.
As such, dynamic work plans describe project activities that are adaptable to the
new information acquired during field work. They are accompanied with a series
of official documents, such as the field sampling plan, quality assurance project
plan, data management plan, and community involvement plan, that target specific
audiences. Chapter HI, Managing Dynamic Field Activities, provides more infor-
mation on how to develop a dynamic work plan.
Dynamic work plans should include contingencies so that unexpected
findings or unsuccessful procedures can be quickly modified without halting the
field work. For example, a dynamic work plan might include a contingency for an
alternative sampling technique to be used if the preferred one fails to perform as
expected. Although every effort should be made to ensure that the selected
equipment and methods are appropriate for the expected field conditions,
thorough planning cannot always anticipate unexpected circumstances. Conse-
quently, dynamic work plans should fully discuss the procedures that would take
place to access additional equipment or services if the need arises. This discus-
sion is often presented in an "if-then" format. For example, the dynamic work
plan for the soil and sediment cleanup case study, summarized in Chapter V,
demonstrates the use of a contingency plan in making a smooth transition from an
unsatisfactory immunoassay technique to a transportable gas chromatography
(GC) method for PCB analysis. In addition, Chapter HI, Managing Dynamic
Field Activities, provides a detailed discussion on how contingency planning can
be integrated into dynamic work plans.
For a dynamic field activity to be successful, all of the associated planning
documents should support the on-site decision-making process. For example, the
community involvement plan should provide a mechanism for sharing data with
the local community and determining the specific decision points where each
stakeholder should be involved. Where specific decisions require cooperation
with the local community, the community involvement plan should discuss the
potential situations, options, and acceptable activities with the community prior to
the mobilization.
Step 3: Conducting a Dynamic Field Activity
Dynamic field activities utilize an iterative sampling, analysis, and
evaluation strategy that allows project teams to continually refine the conceptual
site model in the field until they are satisfied they have reached their project
objectives. This iterative process minimizes the number of site mobilizations.
Dynamic field activities
use quick turnaround
data to support on-site
decision making.
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Although the field sampling plan for a dynamic field activity may initially
select sampling locations (e.g., a probabilistic sampling approach), it should also
establish a scheme for using the findings to guide additional field work (e.g.,
judgmental sampling, statistical techniques that facilitate adaptive or sequential
sampling programs). In this respect, the field sampling plan should provide a
framework for data collection that can be modified and optimized continuously as
the field program proceeds. Experienced personnel are an essential component of
this process to evaluate results and guide the progress of the project. Consequent-
ly, the field sampling plan should establish lines of communication that enable
technical experts to evaluate data in a timely fashion. Typically, a very experi-
enced and cross-trained technical team leader will supervise activities in the field
and ensure that appropriate personnel have the information they need to generate
and evaluate data.
The dynamic field activity is completed when project requirements, as
documented in the dynamic work plan, are met. Although thorough project
planning can typically avoid ending a project before reaching the objectives, on
occasion field conditions or external events may cause work to end earlier than
expected. For instance, field work may stop if additional legal proceedings are
required to pursue a contaminant plume across property lines. Consequently, the
planning documents need to define success for the project as well as the
conditions that will require demobilization for additional planning.
Step 4: Writing a Final Report
As with any environmental field work, projects using dynamic field activi-
ties document results in a final written report. However, since dynamic projects
can generate more meaningful data sets and provide greater project confidence in
site conditions than other approaches, the final report should also provide better
guidance on a subsequent course of action. For example, if a dynamic field
activity is used to generate a CERCLA site inspection report, decision makers
should have a better understanding of the risks posed by the site, thereby
improving their ability to decide whether to include it on the National Priorities
List. In addition, any subsequent field work will have more information to build
upon.
One added benefit of the report writing process is that much of the data
processing and evaluation are done as part of the field work, so the report writing
is significantly streamlined in comparison to a staged approach. Furthermore,
since the experienced staff are more involved with the actual field work, they need
less time to review and become familiar with the documentation in preparation of
writing the report.
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Section 2: Applying Dynamic Field Activities to
Contaminated Sites
Examples of how dynamic field activities can be used throughout all
phases of work at contaminated sites are provided in this section to enlighten and
encourage project managers to use this approach for a variety of activities.
Dynamic field activities provide two strategic benefits for contaminated site
cleanup programs. First, they force better integration of programmatic issues that
may not otherwise be coordinated by helping decision makers to understand site
problems and solutions quickly. For example, implementing a dynamic field
activity during the initial site screening creates more and better data for followup
characterization which, in turn, can allow for a more streamlined implementation
of cleanup and monitoring activities.
Second, by reducing the time between site discovery and cleanup,
dynamic field activities help to reduce the spread of contaminants, thereby
reducing the area of contamination and possibly the need for recharacterization
of redistributed contaminants. For example, a storm event or spring snow melt
can sometimes mobilize contaminated sediment. By streamlining the evaluation
process, dynamic field activities can help to cleanup contaminants as they are
characterized. A summary of these applications is provided in Exhibit II-2.
Characterization
Site characterization is the most obvious and most commonly used appli-
cation of dynamic field activities. It has already been thoroughly described by a
number of organizations, as mentioned earlier in this chapter. The four benefits
commonly cited for this phase of field work include:
Providing a cost-effective, rapid, and comprehensive site characterization;
Facilitating the integration of characterization and cleanup technology
evaluation tasks;
Facilitating a smooth transition into subsequent remediation activities; and
Improving risk assessments.
Dynamic field activities
can be used for
characterization,
cleanup, and
monitoring. If the
potential contaminants
at a site are known,
dynamic field activities
can benefit initial site
Cost-Effective, Rapid, and Comprehensive Site Characterization
Dynamic field activities improve site characterization by allowing the
iterative investigation process to take place in the field rather than off site. They
also promote the use of multiple, complementary methods that increase confid-
ence in the conceptual site model, especially at sites where the subsurface is
heterogeneous. As a result, the overall project cost and time can be substantially
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Exhibit 11-2
Summary of Applications to Contaminated Site Activities
Site Activity
Application
Overall, dynamic field activities encourage better integration of response programs and, by
streamlining field work, they contribute to a more timely cleanup.
Characterization
Cleanup
Monitoring
Initial Site Screening
Complete characterization quickly and with better
understanding of site conditions.
Increase confidence that preferential contaminant migration
pathways have been identified in heterogenous geologic
settings.
Make decisions with higher level of statistical certainty (e.g.,
declaring an area "clean").
Integrate characterization and cleanup technology evaluation
tasks.
Streamline subsequent remediation activities.
Improve risk assessments.
Optimize cleanup technology.
Make decisions with higher level of statistical certainty.
Streamline soil removal and treatment decisions.
Evaluate and optimize remedy performance.
Evaluate several potential exposure pathways or source areas.
Plan field work at sites with known classes of potential
contaminants.
Determine "attribution" of source area to receptor.
Assess actual human health or ecological risk.
reduced. An analysis of the characterization case study presented in Chapter V
indicates that the most easily quantifiable cost and time savings were derived from
a reduction in contractor hours dedicated to writing the work plans and interim
reports as well as the Agency's time in reviewing these documents. While the
total analytical costs were comparable, the dynamic process provided the project
team with significantly more data points and sufficient QA/QC to define the
nature and extent of the contamination in both the soil and groundwater. If the
project managers had tried to use a traditional phased approach with the same
level of confidence using off-site analyses, the total costs would have been
prohibitive.
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Integration of Characterization and Remedy Evaluation Tasks
Dynamic field activities can facilitate the integration of characterization
and remedy evaluation tasks, as recommended in EPA guidance (U.S. EPA,
1988), by allowing project teams to use characterization data simultaneously for
remedy evaluation purposes. If project planners develop dynamic work plans that
include remedial objectives and appropriate remedies along with characterization
objectives, data collection efforts can support the evaluation of remedy options
since these options will become clearer as the investigation proceeds.
For example, if a suspected TCE release is being characterized, the
investigators will need to collect data for the remedy evaluation of TCE in soil
and potentially TCE in groundwater. A dynamic field activity can quickly narrow
the remedy options (e.g., soil vapor extraction, ex situ thermal desorption, air
sparging) by determining the depth of the source area and the soil types in which it
is located. If the project team finds contamination in a clayey soil, it can eliminate
soil vapor extraction as a treatment option. If it discovers that groundwater
contamination is limited to a clayey aquifer, it can eliminate air sparging. If, on
the other hand, groundwater contamination is in a sandy aquifer, the project team
can schedule an aquifer pumping test during the installation of monitoring wells.
These types of evaluations were successfully carried out for a TCE release in the
soil and groundwater characterization case study summarized in Chapter V.
Smooth Transition to Subsequent Remediation Activities
Dynamic field activities usually result in a more fully detailed site char-
acterization that allows the subsequent steps in the remedial process to proceed
expeditiously. For example, CERCLA remedial project managers often spend
considerable resources developing additional site characterization data during the
remedial design because of inadequate characterization during the remedial
investigation. Additional data may also be needed during the remedial action
process before the remediation technology can be installed or implemented. By
allowing projects to collect sufficient data for implementing potential remedies,
dynamic field activities may allow remedial action resources to be focused on
cleanup activities. Furthermore, having an accurate "final" conceptual site model
aids in the implementation of effective operation and maintenance activities as
well.
The Hanscom Air Force Base case study (Robbat, 1997a) provides an
example of how an inadequate characterization resulted in the need for additional
investigations after the remediation technology proved to be ineffective. In this
case a dynamic field activity was used to identify gaps in the site characterization.
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Improving Risk Assessments
As a site is characterized, data are collected to determine the risk the site
poses to human health and ecological receptors. There are at least two ways in
which risk assessment data collection efforts can be improved with the use of
dynamic field activities:
• Increasing knowledge about site conditions; and
• Including risk assessors in field decision making.
Increasing Knowledge About Site Conditions
Although risk assessors often have to work with very limited data sets for
evaluating site conditions, they can gather more data about a site with an on-site
decision-making process provided an analytical method can be found that has
adequate detection limits. The data collected is also likely to be more relevant to
the risk assessment because sample locations can be modified based on the latest
site information. Therefore, risk assessors can determine if data points with high
concentrations are merely outliers that do not significantly affect the actual level
of risk, or if they are part of a significant area of contamination. Consequently,
project managers can make risk decisions based on samples that are representative
of the area of concern and with a better understanding of the overall conceptual
site model, thereby increasing the confidence in their actions.
Including Risk Assessors in Field Decision Making
Dynamic field activities allow risk assessors to review data as they are
produced and influence the selection of additional samples to meet the needs of
the risk evaluation, thus they can avoid having to depend on site characterization
data that do not meet their needs. By providing risk assessors with an opportunity
to influence sample selection, additional mobilizations can be avoided and
decision makers can have increased confidence in the risk assessors' evaluations.
Cleanup
Dynamic field activities may be used in at least three ways as part of the
cleanup process, including:
• Optimize a cleanup technology;
• Confirm that cleanup objectives have been achieved; and
• Segregate soil for various treatment options.
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Optimize a Cleanup Technology
Implementing a dynamic optimization strategy during the startup period of
a cleanup technology allows the remediation team to adjust equipment parameters
based on quick turnaround analytical results. For example, if thermal desorption
or a soil washing technology is being implemented, field-based analytical methods
may provide data that ensure the technology is operating within the project
requirements, thereby allowing the project team to refine the treatment process
quickly and precisely. The Umatilla case study summarized in Chapter V
provides an example of how a colorimetric analytical method and a dynamic
sampling strategy were used to optimize protocols at a groundwater treatment
plant. In addition, the King of Prussia soil washing report (U.S. EPA, 1995a)
demonstrates how x-ray fluorescence (XRF) has been used to confirm the
effectiveness of a treatment system.
Confirm That Cleanup Objectives Have Been Achieved
Dynamic field activities can play a very valuable role in cleanup scenarios
that need a large number of samples to make a statistical determination of whether
cleanup goals were met. For example, if the distribution of the constituents of
concern is heterogenous, then the project team may need to collect a large number
of samples before an area can be declared "clean." Field-based analytical methods
that meet the project's data use needs can help project teams generate sufficient
data to expedite the decision-making process of declaring the cleanup complete,
prior to demobilization. In addition, by allowing the project team to collect more
data with the same analytical budget, this process can increase the certainty with
which they make site decisions.
Segregate Soil for Various Treatment Options
Often during cleanup activities quick turnaround analysis is essential, such
as during a soil removal operation where the hourly cost of removal equipment is
much greater than the cost of quick turnaround off-site analysis. If field-based
analytical methods can be used to support decision making for a dynamic field
activity, then the project can avoid paying the higher analytical fees. Likewise, if
a treatment process is less expensive per ton of soil than an off-site analytical
method, it is often more cost effective to treat soil that may be "clean." If a low
cost analytical method can meet the project requirements, project managers can
avoid treating questionably contaminated soil and expedite the treatment process.
The Wenatchee Tree Fruit case study (U.S. EPA, 2000h) and the Loring Air Force
Base case study summarized in Chapter V both provide examples of these
benefits.
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Monitoring
Dynamic field activities are relevant for monitoring activities when a
cleanup technology needs to be evaluated and optimized. As a result, the applica-
tions are similar to the activities demonstrated in the Umatilla and Hanscom case
studies already mentioned. In addition, dynamic field activities should result in
lower monitoring costs by:
• Reducing the number of monitoring wells (see Tustin case study in
Chapter V); and
• Optimizing the cleanup technology, thereby leaving a lower level of
residual contamination.
Initial Site Screening
Generally, initial site screening is used to determine which, if any,
program should take responsibility for additional work at a site. If project plan-
ners realize that only a few samples will be needed to make a site decision, or very
little is known about the nature of the contamination, on-site decision making may
not benefit the project. However, even with the limited budgets often used for
initial site screening, there are several situations in which dynamic field activities
can address this project goal. A list of possible scenarios includes:
• Evaluating several potential exposure pathways or source areas;
• Planning field work at sites with known classes of potential contaminants;
• Linking a source area to a receptor; and
• Assessing actual human health or ecological risks.
Examples of each of these situations are presented in the initial site screening case
studies described in Chapter V.
In addition, as with other project goals, dynamic field activities help to
reduce the number of mobilizations needed to make a site decision by providing
investigators with the flexibility to maximize the amount of information that is
collected during each sampling event. Many times project planners believe that a
site can be screened with only a few key samples, only to learn that another
sampling event is needed once the results arrive. By using a dynamic sampling
strategy, it is possible to reduce a number of these remobilizations.
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Evaluating Several Potential Exposure Pathways or Sources Areas
If a site contains several potential exposure pathways or source areas that
need evaluation, a dynamic field activity may be the best strategy for obtaining the
necessary information in a reasonable time frame. Although the use of mobile
laboratories are often considered too expensive for initial site screening, in this
situation they may be appropriate, considering the number of samples that may be
needed. In addition, even without sophisticated mobile laboratories, project
managers can benefit from an on-site decision-making process. Inexpensive port-
able field analytical instruments, such as portable GC, XRF, and immunoassay
test kits can often help to evaluate contaminant distribution and provide a high
degree of confidence in the results due to increased sampling density with data of
known quality.
Planning Field Work at Sites with Known Class of Potential
Contaminants
If known classes of contaminants exist at a site, project planners can often
select inexpensive analytical equipment that can support a dynamic field activity
and allow a decision to be made in as little as a single mobilization. Examples of
site types that may be applicable, include:
• Dry cleaner sites where volatile chlorinated hydrocarbons are expected: a
portable GC may be used.
• Smelters, platers, and battery recycling sites where specific metals are
expected: XRF may be used;
• Agricultural sites where specific pesticides are expected: immunoassay
test kits or portable GCs may be used;
• Firing range sites where specific types of explosives are expected:
immunoassay test kits or colorimetric methods may be used; and
• Sites where radionuclides are expected: equipment such as a long range
alpha detector may be appropriate (MARSSEVI, 2000).
In all of these situations, the field-based analytical method could cost-
effectively identify and quantify the suspected contaminant in a large number of
samples while a small number of quality control samples could be sent to an off-
site laboratory for confirmatory analysis, if necessary, using the Contract
Laboratory Program (CLP) or other reference methods. Information on how these
confirmatory samples can be selected to build confidence between methods and
reinforce decisions at critical locations is provided in Chapter IV.
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Linking Source Area to a Receptor
One of the activities that is often necessary during the initial screening of a
site is to determine if contamination at a source area can be linked to a specific
receptor (e.g., a drinking water well). Typically, many samples are needed to link
these two points because the pattern and direction of contamination should be
defined. Dynamic field activities allow many samples to be collected rapidly by
providing the sampling team with the data they need to select new sampling points
in real time. Therefore, this process can benefit initial screening activities by
providing more, and better, information with which to connect a source of
contamination and receptors.
Assessing Actual Human Health or Ecological Risk
During the initial site screening, dynamic field activities provide a quick
and cost effective method of preliminarily determining contaminant exposure.
Although this phase of program activities generally do not necessitate a full scale
risk assessment, just enough data may be collected to estimate the effect site
contamination may have on human health and ecological receptors. For example,
a dynamic field activity may be used to determine how many residential properties
near a lead smelter have elevated levels of lead without having to conduct
numerous mobilizations.
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Section 3: Special Considerations of
Dynamic Field Activities
Although the benefits of using dynamic field activities are substantial, they
are not applicable for all situations. In addition, special considerations should be
taken to maximize their positive aspects. These considerations include:
Additional preparatory planning;
Contingency budgeting;
Increased level of Agency oversight during planning and field activities;
Availability of rapid analytical methods to meet project-specific
objectives; and
Experienced technical staff to evaluate data and assist in decision making.
A more detailed discussion of how to manage these special considerations
is presented in Chapter HI, Managing Dynamic Field Activities.
Additional Preparatory Planning
Dynamic field activities often need more preparatory planning than the
initial planning of comparable staged field activities because dynamic work plans
should prepare not only for what is known about a site, but also for the possible
site conditions that could affect the completion of the field work. Although this
process may delay the initial mobilization, it should also result in a more rapid
completion of the project and a better final product that increases the confidence
in decisions. For example, if a project team is planning a staged field activity to
investigate a drum storage area, typically a sampling grid is overlain on the area
suspected of contamination and a set number of samples are taken at pre-
specified locations and depths. If the data evaluation process determines that a
subsequent mobilization is needed, then a new round of planning may also be
needed. In contrast, if the project involves a dynamic field activity, the site
activities may be the same at the beginning, but the project planners should also
prepare to continue the investigation if contamination is discovered. Likewise, if
the initial samples indicate that the contamination may have reached groundwater,
equipment to sample the groundwater should be acquired. Furthermore, if the
groundwater plume subsequently appears to extend off site, sampling beyond the
property boundaries will be needed. The characterization case study summarized
in Chapter V illustrates these points.
Extra up-front effort
will result in a better
final product.
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Contingency Budgeting
Although the final cost of a dynamic field activity is often much lower
than that of a staged process using only off-site analytical capabilities, the initial
budget is often higher than the initial budget for the same project using a staged
process because the costs of subsequent stages are built into the dynamic work
plan up front. In addition, a dynamic field activity typically benefits from being
fully funded at the outset so that project managers may extend field work if site
conditions indicate the need. Full funding generally includes money for any
plausible contingencies, such as bringing new analytical equipment on site if
previously unreported contaminants are identified. However, if full funding is
not possible, the project manager may be able to plan the work around two
different budget cycles or complete the work in smaller increments, funding
each section of a site when the field team is ready. Creative budgeting strategies
such as these may allow project managers to take advantage of dynamic field
activities without acquiring full funding in the initial budget.
This approach can save
significant resources
over the life of a
project.
Increased Agency Oversight
Dynamic field activities generally need more Agency field oversight
because the Agency should be involved in evaluating key technical decisions as
they occur. As a result, EPA project managers may need timely support from
Agency technical experts (e.g., chemists, hydrogeologists) or independent
contractors to help guide the field program. The increase in oversight during
dynamic field activities should be offset by a reduction in administrative
document review (e.g., work plans, interim reports) that is generally needed for
staged approaches. For example, a project manager overseeing a dynamic
groundwater investigation may need to consult an independent hydrogeologist if
the contractor recommends installing new monitoring wells based on additional
groundwater data that changed the conceptual site model. In a staged approach,
the independent hydrogeologist would be consulted after the interim report was
submitted. Dynamic field activities, therefore, may result in more consultation
during a mobilization but should also result in less administrative review after it.
In addition, project managers should consider Internet and visualization
software options for sites that will need extended field work. By allowing the
project manager to evaluate progress from a remote location rather than in the
field, these tools can actually reduce the amount of direct oversight needed. This
approach was successfully used at the Loring Air Force Base cleanup summarized
in Chapter V.
This approach can
reduce overall oversight
effort by eliminating an
iterative review process
for work plans and
interim reports.
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Availability of Rapid Analytical Methods
Although dynamic field activities do not absolutely necessitate that data be
generated on site for on-site decision making to take place, data nonetheless
should be provided to the field team in a time frame that allows for decision
making to take place without significant delays. In many cases this means that
data are generated on site. However, there are situations when it is either
technically or economically preferred that samples be sent expeditiously to an
off-site laboratory for quick turnaround analysis. For example, if a project
requires a method that detects chromium in soil, currently only a fixed labora-
tory method can meet the quantitation limits needed for an evaluation of its
threat of leaching into groundwater. If quick turnaround analysis from the fixed
laboratory is not economically or technically feasible, a staged approach for this
aspect of the field work may be more appropriate.
Both field-based
analytical methods and
off-site laboratories can
support dynamic field
activities.
Experienced Technical Staff
Unlike a staged approach, the presence of one or more experienced
technical staff in the field is recommended for dynamic field activities because
experienced staff play a key role in the decision-making process and their
recommendations can greatly influence the direction field activities take.
Although recent innovations in information technologies, such as password
protected "e-rooms," allow technical experts to participate in these projects from
remote locations, at least one experienced field team member should be on site
because they provide the field team with immediate access to someone that can
interpret results, avoid pitfalls, and provide overall leadership to a potentially
complicated field effort. This individual should be a cross-trained technical
professional who is empowered to make field decisions with access to specialists
when needed or to make field related recommendations to the Agency project
manager and technical experts. If an experienced technical team leader is not
available to oversee the field work, a dynamic field activity will often be
ineffective. Experienced technical staff are especially important during geologic
and hydrogeologic characterizations because expert judgement is needed to select
sample locations in the subsurface.
Modern communica-
tion strategies allow
communication with
team members in
remote locations.
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Conclusion
Dynamic sampling and analytical strategies can streamline contaminated
site activities by providing the data needed to make site decisions without multiple
iterations of project work plans and interim reports. At the same time, the on-site
decision-making process has the potential to save significant resources for the
Agency while increasing confidence in the decisions that are made. This process
is not new. It has been used successfully at a number of sites. Experience at
several sites has demonstrated that the key to success is in using:
• Thorough systematic planning;
• Flexible "dynamic" work plans;
• Rapid data generation, particularly with field-based analytical methods;
• Expertise in the field; and
• Constant communication between stakeholders.
However, dynamic field activities offer more challenges to implement than
traditional approaches and some precautions are necessary in order to maximize
the benefits they can provide. Consequently, project managers should be
committed to:
• Using a systematic planning process for the project design and implemen-
tation;
• Developing thorough project planning documents that take into account
multiple scenarios and contingencies;
• Establishing a budget that provides flexibility in pursuing various levels of
effort;
• Creating an independent oversight team, where appropriate, whose
members are available for project updates and able to provide feedback
when needed; and
• Selecting experienced technical staff for conducting a systematic planning
process and implementing the field work.
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Chapter
Managing Dynamic Field Activities
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Chapter III
Managing Dynamic Field Activities
Overview
This chapter provides project managers with a basic understanding of the
key issues involved in managing a dynamic field activity. Although specific
activities differ among sites and programs, general guidelines have been
developed on:
Using systematic planning in developing a dynamic work plan;
Determining funding needs;
Ensuring the selection of qualified personnel; and
Preparing and overseeing the field work.
Managing a dynamic field activity presents special issues for the EPA
project team because of the extensive planning required and rapid progress of the
field work. Project managers need to be closely involved to ensure that the
appropriate people are doing the work and that key individuals have the infor-
mation needed to make defensible decisions in a timely manner. The high level
of involvement they provide up front should ultimately save substantial project
time by eliminating numerous project planning and report review cycles.
Project managers can benefit from a dynamic field activity when they find
ways to maximize flexibility in the project's planning, management, funding,
and oversight. Obtaining a high level of flexibility starts with selecting an
organization for conducting the project. When a site is an Agency-lead site,
project managers generally have at least four different mechanisms for finding
the right people to do the work. The best choice is often dictated by site-
specific, regional, and funding issues, but the primary goal should be to find
qualified personnel to do the work, regardless of their affiliations. For example,
in the Superfund program, the options generally include:
• Conducting the work in-house through EPA Regional Science and
Technology Divisions, their in-house contractors (Environmental
Services Assistance Team— ESAT), and the use of Field Analytical
Support Programs (FASPs);
• Accessing Army Corps of Engineers staff and contractors through an
Inter-Agency agreement to work with EPA staff and contractors;
• Using regional level-of-effort contracts, such as the Superfund Response
Action Contract (RAC), to access an EPA contractor; or
• Requesting support from the Environmental Response Team's (ERT) in-
house staff or through their Response Engineering and Analytical Contract
(REAC).
The primary goal in
assembling a project
team should be to find
the right people for the
work. Project
managers should
consider a variety of
affiliations.
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When the potential responsible party/responsible party (PRP/RP) takes the
lead at the site, project managers often need access to similar types of expertise as
those needed at Agency-lead sites to oversee the development of work plans, field
work, and project reports. This chapter provides an overview of the types of
information project managers should look for from project teams that are
designing and implementing a dynamic field activity.
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Section 1: Using Systematic Planning to Develop a
Dynamic Work Plan
As mentioned in Chapter II, a dynamic work plan is the document that
provides the project team with the lines of communication and an agreed upon
framework that facilitates decision making in the field. Dynamic work plans
provide "structured flexibility" to project teams by describing the specific bound-
aries and criteria within which project teams can make decisions based on new
data. For Agency-lead sites where an EPA project manager chooses to use an in-
place contractor to implement a dynamic field activity, the project manager
should prepare a statement of work that allows a dynamic work plan to be
developed. For all other situations in which a dynamic approach is under
consideration, project managers need to negotiate the contents of the dynamic
work plan. For both scenarios, this section provides project managers with the
basic information they should expect in the planning documents that will allow
on-site decision making while still maintaining proper Agency review.
Once a decision has been made to use an existing contract to conduct the
field work, the project manager should issue a statement of work that requests
the development of a dynamic work plan. Project managers should keep in mind
that work plans proposed by a contractor are limited to the activities outlined in
the statement of work. Although the overall statement of work should not be
much different for a dynamic field activity than for a staged approach, the
project manager should ensure that this document tells the contractor the prefer-
red approach is one that uses rapid data generation to support on-site decision
making. In addition, the statement of work should indicate the areas where the
contractor should consider innovative field characterization techniques and
analytical equipment.
The dynamic work plan
translates the project
requirements,
developed with stake-
holders through the
systematic planning
process, into proced-
ures to be used by the
project team that will
conduct the dynamic
field activity.
Systematic Planning
In order to write a dynamic work plan the planning team should follow a
systematic planning process to establish the project objectives and boundaries. It
is through this process that the planning team can establish sampling and analyti-
cal protocols that meet project requirements in the most cost effective manner.
Examples of issues to be determined through the systematic planning process
include:
• Identifying project objectives;
Designing an initial conceptual site model;
• Identifying action limits, including how and where the contaminant action
levels may vary at the site;
Determining detection limits and quantitation limits that will be necessary
to support the site's action limits;
I-3
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• Establishing quality control protocols that will be needed to ensure
analytical data meet project requirements; and
• Identifying initial sampling locations, methods, selection criteria, and
quality control protocols to ensure that sufficient and representative data
are collected.
The planning team should identify important variables in the design and
execution of the project so that cost-effective strategies to manage them can be
developed. Variables to be identified include:
Budget;
Time frames;
Skill level of staff;
Availability of staff;
Historical site information;
Equipment availability; and
Regulatory and programmatic requirements.
At some sites other factors will also have a large impact, such as political and
media interest, local community health and economic concerns, and broader
ecological and economic considerations.
Project planners should also use the systematic planning process to
develop a common sense approach that fits the level of planning to the level of
concern about making mistakes. This objective requires that key decision makers
collaborate with stakeholders to set clear and reasonable goals for a project,
including the level of confidence sought in avoiding mistakes. After the project
begins, the two groups should continue to evaluate their goals and ensure that the
goals are being met. Consequently, systematic planning is not only the first step
for planning a dynamic field activity, it is also an iterative process that takes place
throughout the life of the project. For more information on what the systematic
planning process entails, readers should refer to EPA guidance (U.S. EPA,
2000a). For an example of data quality objectives developed for a dynamic field
activity, readers can refer to a U.S. Navy document developed for Marine Corps
Air Station, Tustin available on the web (see reference, U.S. Naval Facilities
Engineering, 1995c).
Dynamic Work Plan
Developing a dynamic work plan is an iterative process. The result is a
document that provides a roadmap of decisions that the field team can follow. It
is not just a paper requirement, by providing the field team with agreed upon
guidelines to meet the project requirements, stakeholders can have increased
confidence that their goals will be accomplished.
Dynamic work plans
document the objec-
tives and rationale
behind the on-site
decision making
process.
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For a work plan to be "dynamic," it should provide the project team with
the lines of communication and agreed upon criteria needed to facilitate on-site
decision making. As such, it outlines a sequence of adaptive approaches to field
work that accommodate the decision-making process and stakeholder involve-
ment to keep the project moving forward. Consequently, the dynamic work plan
should contain:
• The intended technical approach;
• Project goals;
• A description of the initial conceptual site model;
• An estimated time needed to complete each field task, including the mini-
mum and maximum depending on site conditions; and
• A management plan for completing the field work.
In addition, EPA project managers using existing EPA contracts should request in
the statement of work that contractors:
• Provide the qualifications of the proposed staff and subcontractors for
EPA review before work on the project begins.
• Keep turnover of key personnel to an absolute minimum; and
• Notify the project manager when there are key personnel changes and
provide the qualifications of replacement personnel for EPA approval.
While EPA may not specify the individuals the contractor will assign to a project,
EPA may and should ensure that the contractor's proposed staff are qualified and
appropriate for the required work. General guidelines for staff qualifications are
provided in Section 3 of this chapter.
In addition to the dynamic work plan, there are a number of planning
documents normally developed for site activities that should also be modified
significantly to support a dynamic field activity, including:
• Sampling and Analysis Plan
- Quality Assurance Project Plan
- Field Sampling Plan
Data Management Plan
• Community Involvement Plan.
A summary of the key activities that should be in the various planning documents
for a dynamic field activity are provided in Exhibit III-l.
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Exhibit 111-1
Summary of Issues to be Covered by Project Planning
Documents for a Dynamic Field Activity
Planning Documents
Dynamic Field Activity Aspect
Statement of Work
(developed by project
manager)
States that the preferred approach uses rapid data generation to support
on-site decision making.
Contains type of experience and/or qualifications expected for each field
activity.
Requests prime contractor to certify their review of subcontractor
references for similar work.
Requests personnel turnover be kept to a minimum, particularly key
personnel.
Dynamic Work Plan
Describes the intended technical approach.
Provides estimates of the time needed to complete each field task,
including a minimum and maximum range that would be controlled by
the complexity of site conditions.
Describes the initial conceptual site model.
Explains the management plan for completing the field work.
Documents personnel and subcontractors' qualifications.
Describes measures to keep personnel turnover to a minimum,
particularly key personnel.
Discusses how decisions will be made and the action taken
documented.
Sampling and Analysis
Plan
The QAPP, FSP, and DMP should be modified to accommodate
flexibility in the field.
Quality
Assurance
Project Plan
Contains SOPs of all analytical methods.
Identifies QC requirements for all analytical methods.
Field Sampling
Plan
Provides decision tree for how sampling will take place.
Provides alternative sampling/geotechnical techniques in the event the
preferred method fails.
Data
Management
Plan
Provides a detailed discussion of data flow from sampling through
measurement, validation, and display/evaluation.
Identifies potential bottlenecks and areas that will need special
oversight/QC.
Community
Involvement Plan
Discusses how the community will be expeditiously informed of decisions
and/or findings that depart from the initial conceptual site model or
remedial approach.
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Oversight of Subcontractors
If the actual subcontractors have not been chosen at the time the dynamic
work plan is submitted, the plan can reference the type of experience the prime
contractor will be seeking for each subcontract. Because EPA personnel do not
have a legal agreement or "privity of contract" with a prime's subcontractor, EPA
personnel may not approve or reject the prime's selection of a subcontractor.
However, the project manager may specify the type of experience and/or qualifi-
cations the Agency expects the contractor to provide for each field activity (i.e.,
DP, drilling, soil gas) to be performed under the statement of work. By including
the specifications in the statement of work, it is incumbent upon the prime to
adhere to these expectations when selecting its subcontractor. In addition, project
managers should specify in their statements of work that the prime contractor
requests and reviews client references for similar work, and that it certifies to
EPA that the references have been checked. This certification will help ensure
that appropriate personnel, capable of providing quality deliverables, are assigned
to key roles. Once the subcontractor begins work, an EPA project manager that is
dissatisfied with a subcontractor's performance or qualifications should raise
these concerns directly with the prime contractor.
Documenting the Decision-Making Process
The project manager should also look for a dynamic work plan that
discusses who will be involved in the decision-making process and how
decisions will be documented. In some situations, formal Decision Memoranda
may be appropriate. In other situations, less formal notes documenting meetings
and the consensus decisions that were reached may be sufficient. In either case,
the decision process should involve the project manager to avoid any disagree-
ment about the direction the project should take and the Agency's approval of that
decision. Documented concurrence from the EPA project manager is often key
for PRP-led dynamic field activities. To help ensure that the decision-making
process is efficient, the lines of communication and authority should be clearly
outlined in the dynamic work plan. For example, a contractor should state how
often (e.g., once a week) or when (e.g., a source area has been bounded) decisions
will be made and documented. For small sites, these decisions should document
approval of the work before demobilization. For large sites, periodic decisions
help avoid the need for remobilizations after work has been completed at a
particular location.
The dynamic work plan
should discuss who will
be involved in decision
making and how
decisions will be
documented.
Sampling and Analysis Plan
Although the format for site plans can vary significantly among EPA
regional offices and programs, the general issues covered within them is generally
consistent. Whether a project plan is being written for a leaking underground
storage tank site characterization or a CERCLA remedial action, the planning
document(s) will discuss sampling, analysis, site access, security, contingency
procedures, and management responsibilities. Depending on the scale of the
111-7
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project, these issues may be covered in one document or several. For the purpose
of explaining how these issues should be discussed within a dynamic field activity
framework, these topics are considered part of the sampling and analysis plan
(SAP). For large projects, sections of the SAP may be broken out into a number
of separate and distinct planning documents, including a quality assurance project
plan (QAPP), field sampling plan (FSP), and data management plan (DMP).
Although the SAP may contain additional sections, such as a health and safety
plan, this discussion is limited to sections of a SAP that will be significantly
modified to accommodate a dynamic field activity. As with any project, a copy of
the approved SAP should be maintained at the site for reference.
Quality Assurance Project Plan
The QAPP describes the policy, organization, functional activities, and
QA/QC protocols necessary to achieve the project data quality objectives (DQOs
-see glossary for definition). A more detailed discussion of QA and QC
considerations for field-based analytical methods is found in Chapter IV. In over-
seeing the development of a QAPP for a dynamic work plan, project managers
should request that discussions of the following issues be covered:
• Contingency procedures;
• Decision-making procedures;
• Standard operating procedures;
• Quality control samples; and
• Field laboratory audits.
Contingency Procedures
As the project team refines the conceptual site model, specific field-based
analytical methods may not be able to continue meeting project requirements due
to a number of site conditions, including newly identified analytes, problems with
matrices, or changing weather conditions. Consequently, the project manager
should ensure that the QAPP discusses the circumstances that would lead to a
transition between field-based analytical methods and how this transition would
be made with a minimal disruption to the field work. This discussion should
clearly show that the new field-based analytical method is capable of meeting
project data objectives under the new conditions. Since all situations cannot be
anticipated, it is imperative that the planning team members be sufficiently
experienced to be able to successfully react to unplanned conditions and to
recognize when a project should be stopped so that a satisfactory plan of action
can be developed. The Loring Air Force Base case study summarized in Chapter
V provides an example of a dynamic field activity that made a smooth transition
between analytical methods when their initial choice was not performing as
expected. By having the contingency thoroughly evaluated and discussed in the
1-8
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approved QAPP, switching field-based analytical methods resulted in little loss of
time for that project.
Decision-Making Procedures
The project manager should ensure that the QAPP explains how the results
from the proposed field-based analytical method will be used to support decision
making. This discussion should include a full evaluation of the analytical
capabilities of all selected and contingency methods, including matrix
interferences, frequency, and type of QA/QC needed; and estimated quantitation
limits, so that the project manager understands and can justify the use of
particular methods for on-site decision making.
In order to eliminate misunderstandings between the field team and EPA,
the QAPP should also discuss the type of decisions that should be made in
conjunction with the Agency and the type of decisions that are merely routine
adjustments to the QAPP and may be made without prior approval. For
example, the decision to stop using a particular field-based analytical method in
favor of a contingency procedure may require input from the Agency, whereas
the decision to correct an error in an analytical procedure by rerunning a sample
should not require Agency consultation.
The QAPP should
outline the decisions
that can be made by the
field team, the
appropriate documenta-
tion needed, and the
types of decisions that
call for consultation
with EPA.
Standard Operating Procedures
Standard operating procedures (SOPs) for field-based analytical methods
prepared in support of a dynamic work plan should contain site-specific details
that go beyond the manufacturer's specifications. For instance, calibration
standards for immunoassay test kits should be matched to the site's decision
criteria in order to provide useful information. Likewise, soil preparation
procedures should match the data quality needed for specific decisions,
particularly for methods such as XRF or immunoassay.
There should also be an SOP for all analytical methods that will potenti-
ally be used, or reference a document already on file with the Agency, because of
the need for project-specific information on how methods will be run. This
recommendation is in line with the existing EPA policy that laboratory SOPs be
submitted along with the QAPP. In general, both fixed and mobile laboratories
should be able to easily comply with this requirement by using or modifying
existing SOPs. Many other SOPs can be found on a number of web sites, as listed
in Chapter IV under Principle Method Selection Process. Proj ect managers
should note that simply citing an SW-846 method does not fulfill this recom-
mendation because many of these methods are merely summaries and most
provide several options that the analyst can choose from. The SOPs need to
describe the specific method used so that analysts can be interchanged,
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modifications can be made easily when needed, and defensible documentation can
be provided.
In addition, the SOPs should be located near the respective on-site instru-
ments for reference. If method modifications are necessary in the field, the
process for documenting these changes should be specified in the project
communication and documentation strategy just as is normally the process for
documenting changes to sampling SOPs. Additional information on developing
SOPs is provided in existing EPA guidance (U.S. EPA, 200la).
Quality Control Samples
Project managers should expect a QAPP that includes a discussion of the
number and types of QC samples that will be used to demonstrate that field-based
analytical methods are meeting the project's acceptance criteria. This discussion
should state how QC sample data will be documented and how they will be used
to demonstrate analytical data defensibility. In particular, the discussion should
explain how performance evaluation (PE) samples will be used with field-based
analytical methods. As a starting point, QAPP developers should refer to Section
3 of Chapter IV for information on how QC samples can be used to support
dynamic field activities.
Field Laboratory Audits
Field laboratory audits are often necessary for ensuring that field-based
analytical methods are providing data at a level of quality that is expected and
required. Consequently, project managers should ensure that the QAPP discusses
the frequency and format of audits that will be performed and who will perform
them.
Although the audit should involve the project's technical team leader who
is in a position to make the necessary changes rapidly, the individual selected to
do the audit should be independent of the project team. The individual may be a
contractor staff chemist who was not involved in designing the investigation or a
representative of the regional QA program. The results should then be evaluated
by an Agency chemist or quality assurance specialist and reviewed by the project
manager. Furthermore, if the field laboratory work will be performed by a
subcontractor, the prime contractor's QAPP should include:
• An outline of the field laboratory audit formats and checklists;
• SOPs that will be used by both the prime and subcontractors;
• An outline of information to be included in the prime contractor's formal
field audit report to the Agency;
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The time frame within which audit reports will be produced; and
An agreement that the prime contractor will notify the Agency whenever
there is a change in laboratory personnel.
Field Sampling Plan
A field sampling plan (FSP) describes the types of samples to be collected,
the method for collecting them, and the conditions under which additional
samples will be collected. The FSP for a dynamic field activity should include:
• Contingency planning;
• Decision-making procedures; and
• Standard operating procedures.
Contingency Planning
As with the QAPP, the project manager should ensure that the FSP
includes decision-tree contingencies that allow for expanding, contracting, or
implementing a different sample design plan if the data indicate it is needed. The
FSP should also address potential problems discovered on site and how they can
be resolved quickly. Contingencies should include:
• Sample design contingencies (e.g., if "x" is found then "y" will follow; but
if "x" is not found then "z" will follow);
• A discussion about the limitations of equipment and methods as well as
the likelihood of encountering conditions that are affected by these
limitations;
• The potential for equipment failure and how replacement equipment will
be obtained; and
• A description of corrective actions to be taken when necessary.
For sampling design contingencies, if the field work calls for delineating
the extent of contamination, the project manager should look for a FSP that also
contains a description of the mutually agreed upon procedures (e.g., among the
contractor, EPA project manager, and appropriate stakeholders) that will be used
for responding to potential site scenarios as data become available. This program
can often be presented in the form of a decision tree, such as the one presented in
Exhibit III-2. When the planning team cannot construct a decision tree due to
limited information at a very complex site, a discussion should be included that
explains how different data outcomes will be addressed with sampling equipment
and analytical instrumentation so that the Agency can pre-approve site activities,
particularly at PRP-lead sites. Additional information on how to develop decision
trees is provided in Section 2 of this chapter.
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Exhibit 111-2
Example Decision Tree for TCE Release Investigation1
BEGIN
Initial field design:
- 20 samples (Bin-1ft bgs)
- Soil samples randomly located
in sampling grid
- Taken by hand auger
- Hole screened by FID
Vertical extent of
contamination
bounded at that
location
NO
to
onsite
lab
- Hand auger to 5 feet
- Screen soils with FID
- Look for changes in soil lithology that might
indicate contaminant concentration, highest
reading goes to lab and at 5 feet bgs and expand
grid to sample at 6 in to 1 ft bgs
Direct push continuous sample to 18 ft
Screen soil cores with FID
Look for changes in lithology, highest soil core to
laboratory
Collect groundwater sample
Arrange to bring
equipment on site
that can go deeper
No further action
Every 10 ft, sample groundwater or lithology for
changes at the geologist's discretion to extent of DP
capability (about 40-50 feet bgs)
YES/ contaminated
at each depth?
gw
contamination?
Step back 1/4
calculated distance
Step out calculated
distance
Every 10 ft, sample groundwater or lithology for changes
at the geologist's discretion to extent of DP capability
(about 40-50 feet)
Calculate minimum
travel distance and
collect groundwater
sample with DP
Candidate location for
deeper investigation
Taken from the Tustin Case Study. See Chapter 5.
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If the planning team needs multiple equipment contingencies, it should list
them in order of preference with a brief explanation of how switching to the
alternative would occur. For example, if the team proposes to take shallow
groundwater samples with a direct push rig, the contractor should prepare a
contingency method, such as the use of a hollow stem auger, in case the direct
push rig has problems penetrating the formation to the required depth. They
could also set up a contingency to use a more robust method, such as an air-rotary
drill rig in case the hollow stem auger is unable to penetrate a particular
formation. The discussion of each contingency method should be as complete as
needed to allow pre-approval by the Agency and implementation in the field.
Experienced staff may need to field test some methods before actual field work
begins because site-specific conditions may result in some revisions. For
example, if the planning team selects a direct push conductivity meter to delineate
a contaminant plume, it should test the meter's capability of differentiating the
uncontaminated soil from the contaminated soil.
Decision-Making Procedures
Project managers should expect decision-making procedures in the FSP
that resolve coordination questions with the Agency. This section should discuss
the type of decisions that will be made in conjunction with the Agency and the
type of decisions that could be made without prior approval (e.g., routine
adjustments to the planning documents). For example, if the field team concludes
that contamination has seeped into a deeper aquifer than expected, the FSP may
state that the technical team leader will request approval from the EPA project
manager prior to taking action because the deeper investigation would commit a
substantial amount of resources. On the other hand, the FSP may state that if the
field team determines that several more shallow soil samples should be collected
and analyzed to fully evaluate the level of soil contamination in a specific area,
prior Agency approval would not be necessary.
Standard Operating Procedures
As with QAPPs, project managers should ensure that the FSP includes
SOPs for all equipment and sampling methods that will potentially be used.
Additional information on developing SOPs is provided in existing EPA guidance
(U.S. EPA, 200 la). For EPA contractors, if EPA maintains a master copy of field
SOPs, then the FSP need only reference them, although any site- specific changes
should be noted. Regardless of who conducts the field work, a copy of the all the
SOPs should be maintained at the site for reference.
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Data Management Plan
The DMP describes how data will be managed and displayed. For
conducting a dynamic field activity, project managers should look for DMPs to
include discussions on:
• Communication strategies;
• Data summaries;
• Contingency procedures; and
• Data format, entry, and display.
Additional information on procedures for data management can be found
in Appendix X5 of ASTM 6235 (1998a) Quality Control for Field Data and
Computer Records. In addition, data quality issues that should be considered in
the DMP are provided in Chapter IV of this guidance.
Communications Strategies
The communication strategy identifies relevant people to contact and their
reporting hierarchy so that new information can be transferred in a timely manner
to the people who need it. The contact people should include regulators, contrac-
tors, support organizations, PRPs, and community organizations. The strategy
should indicate the anticipated frequency of communications among groups of
individuals so that all participants understand their roles and responsibilities to
transfer information. An example of a communication strategy is provided in
Exhibit III-3.
Data Summaries
The DMP should state how data summaries will be prepared, what infor-
mation they will contain, how frequently they will be generated, and who will
review them. Examples of daily and weekly summary reports are presented in
Appendix A. Project managers should ensure that stakeholders are consulted in
the development of the data summary plan. Several key people may be
designated to review data summaries at the end of each day. Data summaries for
large or complex sites should include a meeting schedule among the EPA project
manager, the technical team leader, and other key personnel on the implications
of project findings. Presenting data summaries in an electronic format using
visual software can enhance stakeholder understanding of the data summary
reports and transfer the data quickly to project personnel. Issues related to the
type of data provided in these summaries and to whom they should be provided
are discussed Section 4 of this chapter under the title Data Exchange and in
Chapter IV, Section 3, entitled Managing Data During a Dynamic Field Activity.
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Exibit 111-3
Example Communication Strategy
Ul
As Needed
California Department of ^ ^
Toxic Substances Control
EPA RPM
and Oversight Team*
JL.
Regularly Scheduled
V
As Needed
Project
Manager* "^ ^
May com
any projec
T
Technical As Ne
Team -4 —
Leader*
t team member As Needed Dai'V _ f A;
Daily ^
r
Core Technical
Planning Team Field ^ —
Personnel*
FIELD/OFFICE | " JL
Website Contacts* QA/QC Officer*
Technical Pr°Ject
Support Data
Staff Office Leader*
Project Geologist* Kerr Lab*
As Needed t
1 1
T
Daily Site Maintenanc
(Subcontr;
As Needed I •. r
111^
Courier Off-Site EPAFASP crAocr *
Service* Laboratories* Laboratory Team* W'AP5> leam
* For actual strategy the name or
point of contact plus phone
number is given
Drilling Geophj
Subcontractor* Survey "
Health and
""*" Safety Officer
1 May cnmmi inha
Needed any project team
Daily
v
e Manager* FIELD
ictor)
te with
member
im
T Daily as Delegated
r |
rsical Land
ream* Survey Team*
Adapted From:
MANAGEMENT PLAN
FOR NAPL FIELD EXPLORATION
McCormick and Baxter Superfund Site
Stockton, California
-------
Contingency Procedures
Contingency procedures described in the FSP and QAPP should be
addressed in the DMP. Contingency planning in the DMP is important because
data produced by different field equipment or different analytical instruments will
need to be compatible with, or quickly adjusted to, the data management system.
For example, the Loring Air Force Base cleanup summarized in Chapter V
initially generated immunoassay PCB data that were entered into the database by
hand. However, when a transportable GC replaced the immunoassay test kit, the
data output became electronic. Because the central database had been configured
to accept both, the transition occurred smoothly. The discussion of contingency
procedures also should consider how the project team plans to modify their
activities if information technologies fail, for whatever reason.
Data Format, Entry, and Display
Data management plans include a section on how data will be formatted,
entered, and displayed. Typically, this section discusses the software packages
that will be used, their capabilities, and their compatibility with other relevant
systems (both for receiving data and for interactive access). For a dynamic field
activity, project managers should look for a discussion on:
• QA and QC procedures for ensuring that the chemical data have been
sufficiently validated before they are entered into the database; and
• How both the chemical and non-chemical data entered in the database
(e.g., field pH, XRF readings, geological logs) will be compared to the
original field collection forms before they are used.
ASTM (ASTM, 1998a), Appendix X5, provides additional information on
maintaining quality control for field data and computer records.
Community Involvement Plan
The community involvement plan documents the history of community
involvement for the site, the community's concerns, and a mechanism for sharing
data with the local community. The need for developing a community involve-
ment plan will vary among projects. Although it is a required document for many
CERCLA activities atNPL sites, it may be beneficial for some projects (e.g.,
Brownfields), or not necessary at all for others.
When it is appropriate, the plan specifies decision points where stake-
holders should be involved. For a dynamic field activity, project managers should
look for a discussion on how the community will be informed if project activities
change based on the acquisition of new information. The community
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involvement plan should ensure that communities have a chance to review project
plans including all activities and contingencies that are likely to occur at a site so
that issues of concern can be resolved during the review and comment period.
Where specific decisions require cooperation with the local community, the
community involvement plan should specify when opportunities to discuss the
potential situations, options, and acceptable activities with the community prior to
the mobilization will occur.
For example, an on-site information officer may be appropriate if the field
work is expected to continue for less than a week. If the field work is expected to
continue significantly longer, the community involvement plan may consider a
schedule for community meetings and a mechanism for distributing information
(e.g., flyers). If the extent of the field work changes significantly because of the
findings in the initial stages, the community should be informed and the process
of involving the community should be thoroughly discussed. Additional guidance
on working with communities is provided in existing EPA guidance (U.S. EPA,
200 Id).
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Section 2: Determining Funding Needs
One of the more difficult issues to resolve in planning a dynamic field
activity is deciding on the funding level and allocating the necessary resources to
achieve the project goals. In deciding on a funding level, project managers
should consider how much is known about the site. When there is little
information, there is an increased need for flexibility, contingencies, and
resources. This section is designed to help project managers determine the
funding level for these projects and provide information on three issues that are
important for the acquisition of Agency resources:
• Developing an independent cost estimate;
• Evaluating field analytical equipment needs; and
• Addressing funding limitations.
This section is not intended to be a stand alone resource for estimating
project costs and resource needs, rather, it should be used along with existing
documents and in conjunction with existing practices, such as the Procurement
Guide available at the Procurement Corner on the Brownfields Technical Support
Center website (http://brownfieldstsc.org/). In addition, ASTM (1998a) provides
some guidance on procurement and contracting.
Developing an Independent Cost Estimate
All statements of work necessitate that the EPA project manager and the
contractor independently estimate the cost of performing the work. When using
a staged approach, calculating direct costs is relatively straightforward because
the work to be performed in the field is fixed. In contrast, because dynamic
work plans are flexible, they, by definition, cannot describe all the specific
work that will take place in the field. Consequently, it is much more difficult to
estimate the total cost of field activities. To estimate the cost of a dynamic field
activity, project managers may want to use the following three step process:
Step 1: Estimate the minimal work that will be needed;
Step 2: Develop decision trees for the work that could take place; and
Step 3: Develop a list of unit costs.
Although developing an
accurate estimate of
funding needs for
dynamic field activities
is more difficult than for
staged field activities,
minimum and maximum
cost estimates can be
systematically
developed.
Step 1: Estimate Minimum Work That Will Be Needed
As a starting point, the cost of a dynamic field activity can be estimated
the same way as a staged approach. The least amount of field work that will be
needed is a known quantity and the cost can be easily calculated. Because the
initial sampling and analysis will often need to test the accuracy of an initial
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conceptual site model, the minimum number of samples needed and the type of
analysis can be predicted. The main difference in managing the cost of a dynamic
field activity versus a staged approach is that the field work generally does not
end at this point.
Step 2: Develop Decision Trees
After considering the minimum work that will be necessary at a site,
project managers can develop an estimate of the range of possible work at a site
by developing credible scenarios (i.e., a prediction of the actual conditions that is
neither optimistic nor worst case based on all available information) with the goal
of fully funding the project and creating project decision trees based on them. An
example of a decision tree is provided in Exhibit III-2. It is derived from the
characterization case study summarized in Chapter V. This decision tree outlines
the logical steps that the field team would take as they acquire more site data. In
many cases, EPA project managers should consult with Agency technical experts
to develop these scenarios and decisions trees. By completing the decision trees
to their logical conclusions based on the credible scenarios, project managers can
develop an estimate of the minimum and maximum amount of work that will be
necessary at a site, including the approximate number of samples, types of
analyses, and labor hours.
Step 3: Develop List of Unit Costs
To develop an estimate of the total cost for the site, the project manager
should use the decision trees developed in Step 2 to determine the type of
equipment and personnel needed for each scenario. With an itemized list, unit
costs can be calculated for all anticipated and contingency equipment as well as
analytical needs. Unit costs may include:
• Geophysical evaluations, generally charged on a per day or per week
basis;
• Field-based analytical methods, generally calculated on a per day or per
week basis:
- Note that if the sample number is expected to be low, it may also
be worth comparing the per sample on-site cost with the per sample
off-site cost on a quick turnaround basis;
- In calculating this cost it is also very important to ensure that the
sample generating capability matches the analytical throughput so
that resources are not wasted by one group waiting another;
• Fixed laboratory analysis, generally on a per sample basis;
• Drilling equipment, generally given on a per foot basis with specific set-
up costs for each location, or on a per day basis for additional sampling
flexibility, along with a mobilization fee and cost for standby time; and
• Direct push rigs, generally per day, along with a mobilization fee.
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In addition, project managers may need to include estimated costs to the
prime contractor for soliciting contingency equipment or methods. After vendors
or consultants are selected, the project manager should work with the prime
contractor to refine costs. Sources of information about unit costs include
Agency technical experts, such as those on the Field Analytical Support Programs
and the Environmental Response Team (ERT), as well as vendors. A variety of
field analytical method vendors can be found at http://www.epareachit.org or the
Environmental Technology Verification website at http://www.epa.gov/etv.
Evaluating Field Analytical Equipment Needs
An important element of the costing effort is evaluating what field
analytical equipment will be needed and how it will be accessed. Accordingly,
EPA project managers should determine if the Agency has the necessary analyti-
cal equipment and whether it can be used for the entire period of the project.
Internal Agency sources of analytical equipment include the Regional Science
and Technology Divisions; Field Analytical Support Programs; and ERT. If the
work will be completed in-house and the equipment is not already on hand, the
Agency may conduct a cost-benefit analysis of buying or renting the equipment.
As part of this analysis, project managers should evaluate whether acquiring a
controlled space, such as a trailer or building, will be necessary and how
equipment operators will be obtained.
Weigh the cost of
renting verses
purchasing equipment.
Renting Analytical Equipment
The ease of obtaining some types of rental equipment may favor it over
purchasing. However, rental equipment can cost much more than buying equip-
ment if it is used for an extended period. Also extra care is needed to ensure that
rental equipment is in good repair. If the project manager decides to rent the
analytical equipment, there are a couple of options that may be considered. The
first option is to rent from a rental company. However, with this option, the
project manager should have access to a trained instrument operator (e.g., EPA
staff, ESAT/FASP contractors, Army Corps of Engineers) since the vendors
generally do not provide personnel. The second option is to rent the equipment as
part of a mobile laboratory from a vendor specializing in environmental mobile
laboratories. Depending upon the vendor, this arrangement may include an
operator. The choice between the two options depends upon the size of the
project and the complexity of the contaminant matrix that needs analysis.
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Buying Analytical Equipment
The decision to buy equipment may be made on a project-by-project basis
or in the context of the overall program depending on the cost of equipment and
the scope of an individual project. For example, purchase of a spectrophotometer,
costing $5,000, to improve the accuracy of immunoassay analyses makes sense if
the project expects to analyze a significant number of samples (e.g., greater than
100) because the cost per sample would still be very competitive relative to off-
site analysis, and the instrument would be available for use on other projects. On
the other hand, the purchase of a portable GC, costing $25,000, would probably
be done on a program-wide basis because very few projects would provide a
sufficient number of samples to justify such a large expenditure. Consequently,
the decision to buy and maintain equipment is often based on whether there are
many sites on which the instrument can be used or whether one project can absorb
the total cost.
If purchasing equipment is being considered for a project, the EPA project
manager should consult with the EPA project officer, contracting officer, and
regional QA/laboratory staff as soon as possible to prevent procurement delays
and ensure that the equipment is appropriate for the anticipated field work. This
process should be handled during the project planning process because procure-
ment can be difficult to accomplish within the tight schedules of dynamic field
activities.
Acquiring a Controlled Space
When analytical equipment is needed on site, project planners should
consider the need for controlled space. A controlled space is particularly impor-
tant for transportable equipment, such as a laboratory grade GC or XRF. If the
space needs to be provided, then this cost, including a power source, should be
added to the analytical cost estimate. Project managers should determine
whether any local, state, and federal regulations apply to the set up and operation
of mobile laboratories. Examples of projects that set up field laboratories are
provided in Chapter V. For the characterization case study, a small laboratory
trailer was rented. In the cleanup case study, an unused building was provided at
no cost to the project.
Consider the need for a
controlled space:
building? trailer? back
of a truck?
Acquiring a Qualified Analytical Equipment Operator
When costing out the analytical equipment, project managers should
include the cost of the operator because most field-based analytical methods need
well-trained operators to ensure consistent results. While the operator does not
have to be a chemist, having a chemist can provide an additional level of QC that
a lesser-trained technician may not be able to provide for some field-based
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analytical methods. The Environmental Technology Verification reports at
http://www.epa.gov/etv/verifrpt.htm provide a discussion of the minimum training
needs for the instruments that they have evaluated.
Addressing Funding Limitations
If more funds are needed than are available for the project after costing
the most credible scenario, the project manager should consider whether funding
could be spread over multiple budget cycles using a dynamic phased approach.
Under this scenario, the project manager scopes an addressable phase
(constrained by budget) but uses a dynamic approach. This funding method
should result in a portion of the field work being done with greater data certainty
and in less time than using an approach without on-site decision making. The
potential benefits of the process are significant, regardless of the scale that the
project manager chooses to use.
For example, if a site were divided into two operable units, one being soil
contamination, and the other being groundwater contamination, a dynamic field
activity could be planned for the soil contamination first. Once that work was
complete, a dynamic field activity could be planned for the groundwater con-
tamination. Although an approach using different phases would take longer than
a dynamic field activity of the entire site, it would likely be faster and more cost
effective than a staged field activity.
In addition, EPA managers may find that they can accomplish more of
their programmatic goals and address a greater number of sites more quickly by
targeting a limited number of projects with an on-site decision making strategy.
Although this approach may have an appearance of fewer accomplishments in
the short-term, over several years it has the potential of demonstrating signifi-
cantly more completions than a program dedicated to staged field activities.
Dynamic field
activities are not "all or
nothing" events.
Activities can be
broken out according
to funding limitations
while still providing a
benefit to the project as
a whole.
A programmatic-wide
shift to using dynamic
field activities has the
potential to demon-
strate significant
accomplishments over
a period of several
years.
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Section 3: Ensuring the Selection of Qualified Personnel
Project managers should work closely with their contractors to ensure that
the contractors select qualified contract personnel because choosing staff with the
appropriate experience is an essential part of conducting a successful dynamic
field activity. This section provides information on the types of personnel that
project managers often need to evaluate when preparing for a dynamic field
activity. As such, it should help them negotiate with their contractors for
qualified personnel for their projects. Types of personnel include:
• Planning team members;
• Field team members; and
• Staff of speciality technical firms.
The composition of the project team for a dynamic field activity will
depend on the size and complexity of the site. Consequently, the guidelines
below are provided merely to give project managers and contractors a general
idea of the type of expertise they will need. None of these guidelines are
intended to be used as requirements on any particular project, particularly the
guidelines on years of experience. In some cases, individuals with fewer years
may be qualified for specific positions because of the quality of their experience
or knowledge, or because of the complementary experience of other team
members. Likewise, some individuals will not qualify for certain positions in
spite of their years of experience because the project may be particularly
difficult or their experience may not match specific requirements of the site.
Thus, team member qualifications should be viewed in the context of the team
rather than as individuals with highly defined roles. For example, if the technical
team leader has strong hydrogeology and fate and transport skills, the experience
level of other team members who have these expertises could be considerably
lower than if the technical team leader had only a general understanding of these
issues.
When a contractor is designated to carry out the work, it is the contractor's
responsibility to propose staff it believes capable of executing the work in a
fashion that meets project objectives (U.S. EPA, 2000c). Consequently, state-
ments of work developed by EPA project managers need to be very specific in
describing anticipated site conditions and the types of experience that will be
needed to assist contractors in choosing appropriate skill levels. If the proposed
individuals/skill levels are widely different from those outlined in the following
section, then there may be a misunderstanding concerning the complexity of the
site. Project managers should consider meeting with the contractor to ensure full
understanding of site complexities and performance expectations to enable the
contractor to propose a team sufficiently qualified to successfully complete the
project.
Accessing qualified
staff is essential for the
execution of a
successful dynamic
field activity. Project
managers should insist
on specific staff
qualifications for their
projects.
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Planning Team Member Responsibilities and Qualifications
The planning team represents the project's most experienced staff who are
responsible for the technical quality of work plans, field work, subcontractors,
and final deliverables. Project managers should inquire, either formally in writing
or in discussions with the contractor, whether planning team members have ever
run projects using on-site decision making. Although experience with these
projects may not be a requirement for every individual, as a group, they should
have enough experience to understand where potential problems may occur and
be capable of taking corrective action. In addition, contractors should be advised
that key individuals proposed in a work plan will be expected to staff the project
from planning through execution because dynamic field activities are dependent
on team members understanding site conditions and being able to make
recommendations rapidly. This point is particularly important for the core group
of planning team members that have the greatest impact on site decisions. When
staff turnover is high, the ability of a team to meet this criteria is severely
affected. Likewise, project managers should request in a statement of work that
they review team member qualifications and approve replacements if any changes
in staffing occur.
The planning team may include the following positions:
Technical team leader;
Proj ect hydrogeologist/geologist;
Project chemist;
Environmental engineer;
Geophysicist;
Risk assessor (human health and/or ecological);
Statistician;
Quality assurance specialist;
Community involvement coordinator;
Health and safety specialist;
Information technology specialist; and
Data management specialist.
For large projects these positions may be filled by separate individuals;
however, for small projects, one person may be able to fill several roles. For
example, the technical team leader may also be the project hydrogeologist, geo-
logist, or geophysicist while the project chemist might also fill the roles of the
risk assessor, statistician, and health and safety specialist. These individuals may
be assisted by less experienced staff who help draft documents. However, the
planning team members should be responsible for the technical content and
accuracy of the documents. In addition, planning team membership may depend
on the urgency of the field work. For example, a time-critical removal action may
rely only on an expert risk assessor or QA specialist for plan review rather than
plan development. A summary of the qualifications for planning team members
is provided in Exhibit III-4.
A core group of technical
staff, such as the
technical team leader,
project hydrogeologist,
and project chemist,
should commit to
working on the project
from project planning
through the submission
of the final report.
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Exhibit 111-4
Summary of Planning Team Member Qualifications
Position
Technical team
leader
Project
hydrogeologist/
geologist
Project chemist
Project
environmental
engineer
Project
geophysicist
Risk assessor
Statistician
Community
involvement
coordinator
Health and safety
specialist
Information
technology
specialist
Data management
specialist
Suggested
Minimum
Experience
(years)
5 to 10
5 to 10
5 to 10
>3
5 to 10
3 to 5
3 to 5
Not
Applicable
1
Not
Applicable
2 to 3
Special Qualifications for Conducting
Dynamic Field Activities
A cross-trained and experienced individual who can quickly
integrate information from multiple disciplines to guide field
activities.
At least 3 years involved in interpreting chemical,
geological, and hydrogeologic environmental data.
Experience using direct push technologies.
Ability to integrate data from various sources and
disciplines.
At least 2 years involved in QA/QC activities that involve
conducting laboratory audits.
Specific knowledge of field analytical equipment that is
proposed to be used on the project.
Qualifications are the same whether dynamic or staged
approaches are used.
Capable of selecting techniques, determining where they
should be applied, and evaluating conclusions provided by
subcontractors.
Experience conducting QA/QC audits of the subcontractors
during their work performance.
Qualifications are the same whether dynamic or staged
approaches are used.
Experience choosing appropriate sample support
strategies, providing advice on overcoming sample design
uncertainties, designing background sampling strategies,
and working with the statistical techniques laid out in EPA
guidance.
Experience dealing with a variety of community outreach
issues and situations.
Demonstrated ability to react quickly.
Qualifications are the same whether dynamic or staged
approaches are used.
For real-time visualization software, this person should
have extensive experience with both the proposed
hardware and software packages.
Coordinates with other team members to ensure data
transfer is compatible and usable.
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Technical Team Leader
The technical team leader is responsible for the overall development of
work plans, execution of field activities, data evaluation, and final deliverables.
For small projects this individual may also fill the role of the contractor's project
manager; however, for larger projects, the administrative duties of this position
are likely to be too much for the technical team leader to manage. The technical
team leader should be a cross-trained, experienced individual who can quickly
integrate information from multiple disciplines to guide the investigation activi-
ties. This individual has the final decision-making responsibilities in the field
and is responsible for communicating those decisions and/or recommendations to
the Agency. Technical team leaders are also responsible for ensuring that field
audit activities are carried out as needed. Often, CERCLA on-scene coordinators
(OSCs) perform the role of technical team leader for the Agency. In these
instances the contractor's team leader may not need to meet the requirements
described in this document. As a guide, technical team leaders should have the
following minimum level of experience:
• For small, uncomplicated projects (e.g., a 600-cubic yard surficial dig-
and-haul removal action), 5 years of actual field experience with 3 years
as a field project leader.
• For large or complex sites, 10 years of field investigation or remedial/
removal action experience with 5 years of technical project management
(as opposed to administrative project management) and data
interpretation/integration experience.
• For characterization work, the experience shown should be in assessing
geologic, hydrogeologic, and chemical data and directing field work.
• For cleanup, the experience shown should be in design and/or installation
and operation of remedial technologies with emphasis on the technology
that will be used at the site.
General project management (e.g., office level or non-environmental)
experience should not count toward the years of experience for this position. In
addition, technical team leaders may have a core discipline that matches one of
the specialties discussed below (e.g., hydrogeologist, chemist, geophysicist) and
fill both roles when project requirements do not necessitate separate full-time
commitments for the positions.
The technical team
leader should be cross-
trained and very
experienced because
this individual is
responsible for:
evaluating data,
making field decisions,
and providing
recommendations to
EPA.
Project Hydrogeologist/Geologist
The project hydrogeologist/geologist should have 5 to 10 years of experi-
ence in site investigations, with at least 3 years field experience involved in
interpreting chemical and hydrogeologic environmental data, including
knowledge of field and laboratory methods for measuring subsurface hydrologic
properties (e.g., performing and interpreting aquifer tests). If sampling will be
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conducted within unconsolidated soil, the hydrogeologist should have experience
using direct push technologies and be familiar with their rapid sampling and data
collection capabilities. Depending upon the complexity of the site, the project
hydrogeologist/geologist may or may not be needed in the field. If the individual
being considered for this position does not have a strong background in both
environmental geology and hydrogeology, it may be necessary to fill this position
with two people.
Project Chemist
The role the project chemist plays in site activities can vary from being on
site, overseeing or running analyses, and providing continual data interpretation
to the technical team leader, to being off site, providing consultation as requested.
This person should have 5 to 10 years of experience working with environmental
analytical methods, including at least 2 years in QA and QC activities that involve
conducting laboratory audits. In addition, the project chemist should have
specific knowledge on the operation of any field analytical equipment that is
proposed for use.
Project Environmental Engineer
The amount of experience necessary for a project environmental engineer
can vary greatly depending on the type of project, however, 3 to 5 years of experi-
ence is generally sufficient for determining the data needs for a remedy evalua-
tion. The experience needed to design and install a remedial technology may be
significantly higher, depending on the size and type of remedy.
Project Geophysicist
For projects that involve investigations, the planning team often includes a
project geophysicist who has 5 to 10 years experience using geophysical methods
for environmental work. Generally, project geophysicists oversee the work of
subcontractors, and in doing so, they select the methods that will be used, deter-
mine where they will be applied, and evaluate conclusions provided by subcon-
tractors. Consequently, they should have experience providing recommendations
on how subcontractors' conclusions will affect the overall investigation and have
demonstrated capability in conducting QA and QC audits of the subcontractors
during their work performance.
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Project Risk Assessor (Human Health and/or Ecological)
The project risk assessor should have at least 3 to 5 years of experience in
conducting risk assessments. An ecological risk assessor should also have suffici-
ent field experience to provide necessary guidance on the collection of biota.
Project risk assessors are generally not needed on site during a field activity, but
in the case of ecological risk assessments they may need to supervise the sample
collection to acquire the correct sample population. Since the data needs for risk
assessments are the same whether or not a project is dynamic, there are no special
qualifications for this position.
Project Statistician
The project statistician should have 3 to 5 years experience assisting in the
design of environmental sampling strategies and choosing appropriate statistical
tests for evaluating data usability. This experience should include providing
advice on overcoming sample design uncertainties, designing background
sampling strategies, and working with the statistical techniques laid out in EPA
guidance (U.S. EPA, 2000a). This individual is not needed on site but may need
to be available for consultation, particularly if assumptions about contaminant
distribution are found to be inaccurate after the field work has begun.
Community Involvement Coordinator
Community involvement coordinators generally need to be more proactive
during a dynamic field activity than for a staged field activities because of the
rapid decision making and the flexible work planning aspects. Consequently,
they should be able to react quickly to site information and have very good
communication skills so that information coming from the field work will not
adversely affect the community support for the project. To adequately address
these changing circumstances, the planning team should have an individual who
has successfully dealt with a variety of situations in conducting community
involvement activities. Guidelines for years of experience cannot be provided for
this position because some important skills, such as good facilitation skills, good
written and oral communication skills, and, most importantly, sensitivity to the
needs of the community are not necessarily acquired through experience.
Health and Safety Specialist
There are no special qualifications beyond the normal requirements for
health and safety specialists overseeing a dynamic field activity because exposure
issues are essentially the same for any field work. As with all contaminated site
activities, this person should have American Conference of Governmental and
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Industrial Hygienists certification. One year of experience should be adequate for
this position.
Information Technology Specialist
Depending upon the size of the project, the data management needs can
vary from producing in-plan maps with several data points to real-time visualiza-
tion modeling involving thousands of data points. If the project manager chooses
to use real-time visualization, it is imperative that the information technology
specialist have extensive experience with both the proposed hardware and
software packages, since there will be very little time to troubleshoot unforeseen
problems once the project begins. This level of experience differs from a staged
approach because dynamic field activities need to access data within a shorter
timeframe. No guidelines on qualifications can be provided because information
technology hardware and software change rapidly. Instead, experience with the
particular hardware and software package that will be used at a site (including
those used by the particular site field-based analytical methods) is more important
than years of experience.
Data Management Specialist
The data management specialist should have 2 to 3 years experience in
planning and managing data flow and storage for projects of equivalent size and
complexity to the one being planned. Together with the project chemist and
hydrogeologist, the data management specialist will either choose the appropriate
off-the-shelf software or develop a storage and retrieval program using off-the-
shelf database software. In either case, the system needs all appropriate data
entry fields and it needs to be compatible with other data systems (e.g., GIS,
models, laboratory equipment outputs).
Field Team Member Responsibilities and Qualifications
The field team consists of members of the planning team who should be
involved with the daily site activities along with additional technical support staff
and subcontractors who implement the project. It is imperative that planning
team members whose involvement is needed only periodically, be available for
consultation whenever their input is needed. With the use of modern
communication technologies, remote involvement is both feasible and cost
effective.
Dynamic field activities necessitate more scrutiny of field team member
qualifications because these members play a key role in the decision-making
process, and their recommendations can greatly influence the direction field
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activities take. This section provides some basic information on the responsi-
bilities and qualifications of the field team staff who are not part of the planning
team. These positions include:
• Field analytical equipment operators;
• Field geologist;
• Field technician/sampler; and
• Specialty samplers.
During small projects, active participation of the planning team in the field
is generally confined to the technical team leader. As the project grows in
complexity, more members of the planning team may need to be in the field,
especially if real-time visualization tools are not being used. In this event, the
staff most likely to be needed in the field full-time would include the project
chemist, hydrogeologist, and geophysicist. A summary of the qualifications for
field team members is provided in Exhibit III-5.
Exhibit 111-5
Summary of Field Team Member Qualifications
Position
Field analytical
equipment
operator
Field geologist
Field technician/
sampler
Specialty
samplers
Suggested
Minimum
Experience
(years)
1
1 to 5
Oto2
Oto2
Special Qualifications for Conducting
Dynamic Field Activities
A chemistry background with data evaluation
experience is desirable but not required.
If not a chemist, have access to an experienced
chemist who can troubleshoot analytical problems.
Qualifications are the same whether dynamic or
staged approaches are used.
Qualifications are the same whether dynamic or
staged approaches are used.
Qualifications are the same whether dynamic or
staged approaches are used.
Field Analytical Equipment Operators
Generally, field analytical equipment operators should have completed at
least 1 year performing field-based analyses with the equipment to be used.
Classroom experience can count toward the total experience, particularly if
hands-on training has been provided, but it should not constitute the only
experience unless a more experienced equipment operator is directly supervising
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the work. A chemistry background with data evaluation experience is desirable
but not required. In addition, if the operators are not chemists themselves, they
should have access to an experienced chemist who can troubleshoot analytical
problems.
Field Geologist
The field geologist will generally be responsible for logging soil borings;
overseeing well installations; performing slug or pumping tests; and taking or
overseeing soil, surface water, and groundwater samples. As a guide, this
position needs mid-level staff (e.g., 3 to 5 years experience) unless supervision is
also provided, in which case entry-level staff may be acceptable (e.g., 1 to 2 years
experience).
Field Technician/Sampler
When additional staff are needed for activities that do not require an in-
depth knowledge of the science behind the activity, such as a routine sampling
event, planning staff often select field technicians/samplers. If they are in the
field without supervision, they should have at least 2 years experience. If proper
training and supervision are provided, then no additional experience is necessary.
Specialty Samplers
Speciality samplers, such as those needed to conduct biota sampling or
tidal/estuarine sampling, are occasionally needed for ecological evaluations. The
individuals responsible for managing the collection of these samples should have
knowledge of the area of concern, be familiar with the specific ecosystem they are
sampling, and be on site during the sampling event to do the sampling or super-
vise others. Specialty samplers who are in the field without supervision should
have at least 2 years experience. These individuals are generally reached through
subcontracts with local area firms or with local college staff because they
generally have a better understanding of unique regional-specific conditions.
Selecting Technical Specialty Firms
Technical specialty firms are companies that supply equipment and
personnel for specific activities that are not readily available in-house or through
a prime contractor. Examples of the type of services provided by technical
specialty firms include soil gas sampling, mobile laboratory analysis, geophysical
surveys, direct push soil and groundwater sampling, and cone penetrometer rigs
with laser induced fluorescence (LIF) analysis.
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As with the selection of other personnel, the project manager should
examine the qualifications, availability, and capacity of the proposed specialty
technical firm personnel to ensure that they are capable of meeting project
requirements. The project manager should discuss the proposed work plan with
the prime contractor and subcontractor (technical specialty firm) representatives.
To prepare for this meeting, the project manager may request that the prime
contractor complete a worksheet, such as the one presented in Appendix B, for the
specialty technical firms. They may also ask the prime contractor to check refer-
ences and provide examples of reports that the proposed firms have completed to
review their capabilities. During the meeting, the project manager should
specifically ask how contingencies will be resolved and determine if the firm is
capable of implementing the field work to the full extent of the contract (e.g., if
the work plan states the need for one DP rig during a two month period with a
contingency for up to three DP rigs at some point in that same period, they should
have the capability to supply them). If there are any questions about the firm's
ability to handle a full work load, then the prime contractor may need to establish
multiple subcontracts as backups to provide the same service.
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Section 4: Preparing and Overseeing the Field Work
Managing dynamic field activities generally involves more preparation
and oversight than a staged approach because the field work needs to be
structured as an intensive effort for a short duration. In addition, because
significant decisions are made during the field work, project managers need to
be involved in reviewing data on a regular basis. Consequently, project
managers need to ensure that the resources they will need during the field work
are arranged prior to the mobilization so that field work can progress as
smoothly as possible. The following program areas are particularly important
for a project manager's preparation and oversight of a dynamic field activity:
Organizing a kick-off meeting;
Obtaining commitments for technical consultation;
Developing decision points;
Establishing a meeting schedule; and
Preparing for data exchange.
Project managers or
their representatives
need to be involved in
reviewing field
generated data on a
regular basis.
Organizing a Kick-Off Meeting
The project manager should organize a kick-off meeting to discuss the
issues that are important for the successful implementation of the project once
organizations involved with the project have been determined and the decision
makers from each group have had a chance to review the existing site data.
Although kick-off meetings are important for any field work, they are essential
for dynamic field activities because the success of these projects are particularly
dependent on up-front planning and acceptance by all stakeholders. EPA
project managers should arrange to have Agency technical personnel attend the
kick-off meeting to discuss the work plans and the overall approach to the field
work. Agency attendees and Agency representatives should be defined on a
project-specific basis and may include a project manager, chemist, hydrogeo-
logist, contracting officer, risk assessor, and quality assurance officer. All other
organizations involved in the project implementation should send their decision
makers as well so that each perspective is represented. In addition to the areas
normally covered at a kick-off meeting, the following are important issues to
discuss when planning a dynamic field activity:
• Roles and responsibilities, including the level of involvement of different
team members and how that relates to the communication strategy (e.g.,
who will be involved in detailed decisions and who will only be consulted
on decisions that involve a change to existing plans);
The kick-off meeting is
critical for establishing
communication among
stakeholders and
developing consensus
on how a project
should proceed.
-------
Field work objectives and boundaries to the scope of work (e.g.,
characterization of soil contamination only? stay within property
boundaries? complete characterization?); and
Overall approach to the field work (e.g., is a dynamic strategy appropriate
for the site at this time?).
Obtaining Commitments for Technical Consultation
For most types of field work, project managers often need to consult with
chemists, hydrogeologists, engineers, and QA specialists, among others, to
evaluate work plans and review reports because they are generally not technical
experts in multiple fields. Additional technical consultation is often needed
during the field work of a dynamic field activity since data are interpreted as they
are collected and decisions about the appropriate course of action made
accordingly. Consequently, project managers should prepare for a mobilization
by assessing the need for expert input during the mobilization and obtaining the
appropriate commitments. The number and level of involvement of these
technical experts will vary with the size and nature of the project. To facilitate
the rapid flow of information and decisions, oversight teams may be needed for
PRP-lead sites, and technical review teams may be needed for Agency-lead sites.
Oversight Teams
For PRP- and Federal Facility-lead sites, technical consultation will gener-
ally take the form of an oversight team. The purpose of the oversight team is to
provide an independent evaluation of the site activities and field team recom-
mendations. The oversight team may consist of Agency experts, Army Corps of
Engineers staff, or contractors with no conflict of interest in the site. The charac-
terization case study described in Chapter V provides an example of how an
oversight team for a Federal Facility-lead site may function. In this case study,
the oversight team consisted of an Agency hydrogeologist, chemist, QA officer,
risk assessor, and Agency project manager.
For dynamic field activities to function effectively at PRP and Federal
Facility sites, there should be a high degree of coordination, trust, and communi-
cation between the project lead and the oversight team because the PRP's techni-
cal team leader provides the primary evaluation of the data and resulting recom-
mendations. In contrast, the oversight team reacts to rather than formulates its
own ground-level evaluation. The level of oversight team commitment will, of
course, depend on the size and complexity of the site.
Technical Review Teams
For EPA-lead site activities that are performed by an Agency funded
contractor, the EPA will still need Agency technical review team approval of
1-34
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work plans and reports. The review team should be defined on a project specific
basis and may include a QA officer, hydrogeologist, risk assessor, chemist, and
environmental engineer. Depending on the size and complexity of the site, a
dynamic field activity may also need these Agency technical experts to be
involved during the field work. Accordingly, prior to the onset of field activities,
the project manager should determine the type of technical expertise needed for
review during the field work and make those personnel available through Agency
resources (e.g., ERT, Tech Support, Office of Research and Development),
contractors, or the Army Corps of Engineers.
Developing Decision Points
In order to reach and quickly resolve decision points during a dynamic
field activity, project managers should ensure that decision trees consisting of a
series of "if-then" statements (see Exhibit III-2) are developed before the mobili-
zation. Examples of decision points include:
• Identifying when and how characterization work should proceed;
• Selecting when and where to place a monitoring well;
• Changing sampling or analytical methods to account for unexpected
conditions;
• Deciding that the field work has accomplished the objectives laid out in
the dynamic work plan and can be stopped; and
• Deciding that cleanup criteria have been met and where characterization
should continue if action levels are not satisfied.
These decisions may have to be made within several hours and generally
cannot be delayed longer than a day or two, depending on the size of the site and
the type of work being conducted. For example, if a dry cleaner site is being
investigated to delineate an area of PCE contamination emanating from only one
source area, there would be little for a field crew to do if the decision about the
next sampling location or installation of a well was delayed. On the other hand,
the characterization of multiple contaminant source areas on a military base may
not be significantly hindered by delays in decisions since a field crew could be
diverted to other source areas while the issue is resolved. In either situation,
however, the project manager, with the help of the technical review team, will
need to stay sufficiently well informed about the progress of field work to make
timely decisions based on the information presented by the technical team leader.
Establishing decision
points is extremely
important for the
success of a dynamic
field activity.
Establishing a Meeting Schedule
If the dynamic field activity will last more than a week, the project
manager may need to establish a schedule for meetings to discuss progress and
subsequent steps. The format and schedule of meetings may range from daily
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telephone conversations to weekly face-to-face meetings. The amount of
interaction will depend on the estimated number of decision points. For small
sites with a single source in which the overall time in the field will be two weeks
or less, a daily phone conversation may be all that is necessary. On the other
hand, field work on a large site with multiple sources lasting several months may
necessitate weekly teleconferences or bi-weekly face-to-face meetings. In some
situations, the field work will benefit from having the project manager on site for
continuous interaction with contractors rather than relying on intermittent discus-
sions. Other factors involved in determining the number and type of meetings
will be the cost of travel and the type of data management system that has been
implemented for the project. The frequency of the meetings, type and format of
information to be discussed, location and/or method of communication, and
individuals to be involved, should be clearly stated in the planning documents.
Regardless of the established meeting schedule, the project manager should also
arrange to be contacted at any time during the field work when the project
manager's input is needed.
Preparing for Data Exchange
Data exchange is important for the project manager to understand because
dynamic field activities are controlled by the exchange of information. As
discussed below, the project manager needs to establish two major data exchange
topics before a project begins:
• Data required for decision making; and
• Data transfer schedule and format.
Data Required for Decision Making
For EPA-lead sites, the EPA project manager should work with the
planning team to determine what data will be required for making decisions and
what format to use to eliminate extraneous data not needed to support decisions.
For example, although data may be collected for a great many analytes to support
various activities (e.g., modeling, determining what chemicals are present, or
remedial technology screening), only one or two analytes may drive an invest!
gation. Consequently, decision makers may prefer to receive report summaries
that concentrate on only the key analytes. On the other hand, technical team
experts (e.g., project chemist, project hydrogeologist) will want to review a wide
variety of data, such as turbidity levels for groundwater samples that were
analyzed for inorganic constituents. If the field work is carried out by a PRP
contractor, the project manager should expect the same kind of information in the
PRP's dynamic work plan or data management plan as is provided for EPA-lead
sites. The EPA project manager also will need information on when and what
kind of data the PRP will provide the Agency as well as negotiated time periods
in which the Agency has to concur or not concur with PRP recommendations.
The project team
should decide what
data will drive the site
decisions so that the
data manager can
focus on the best way
to provide it to them.
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Data Transfer Schedule and Format
Project managers should decide how often they want to receive updates.
This decision can range from continuous to biweekly; however, project managers
should keep in mind that, in general, the more often updates are provided,
especially in data visualization formats, the more the data transfer system will
cost. Therefore, the project needs should be balanced with the cost of the system.
The key to performing this analysis is to examine how often major decision points
are expected and schedule the reviews accordingly. Both the technical team
leader and the project manager should be aware that the regular meeting schedule
does not replace the need for meetings caused by unexpected occurrences or
special events.
Depending upon the equipment chosen, much of the data generated in the
field, especially geologic data, should receive QC before being recorded. Each
entry should be "fact checked" before being used for modeling. ASTM's
Expedited Site Characterization Standard (ASTM, 1998a) provides some
guidance on procedures for QC of geologic and hydrogeologic data in Appendix
X4. Project managers and technical team leaders should be aware that the
integration of false data into a conceptual site model during a dynamic field
activity can be very costly since the field team is able to react quickly to new
information.
When project managers are determining the data transfer mechanisms and
format, they should also consider interface problems between the field equipment
and the software running the models or visualization. Remote viewing may also
require software installation on Agency computers and the expertise to
manipulate it. If an automated real- to near real-time system is chosen, the
operators should be well trained, and a contingency plan should be in place in the
event of a system failure.
A quick and easy way to transfer data is to have the technical team leader
provide a data summary sheet at the end of each day. This sheet will touch on the
major analytical and QA/QC results reported during the day and briefly describe
the results of other field activities and findings (e.g., site stratigraphy, wells
installed, cubic yards of materials removed). The sheet can then be transmitted to
all concerned parties. Examples of daily and weekly data summary sheets are
provided in Appendix A. Another possibility is to develop an "e-group" in which
all the information is stored and accessed by interested parties at a password
protected website. The cleanup case study summarized in Chapter V provides an
example of how this was accomplished. A number of EPA supported software
programs that can facilitate this process are described in Chapter IV, including
FORMS II LITE, FIELDS, and SADA.
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Conclusion
Managing dynamic field activities necessitates a concerted and coordina-
ted effort from all participating parties because clear communication and consen-
sus decision making are essential for responding rapidly to unexpected site condi-
tions. Project managers need to work closely with the contractors, independent
technical experts, PRPs, and communities throughout the entire planning and
implementation of these projects because they are primarily responsible for
ensuring that these activities are handled appropriately.
In many respects, project managers need to be more involved in the details
of a project when managing a dynamic field activity because decisions are needed
during the field work. The proper planning and oversight of these activities
involves a more intensive effort than is generally needed for a staged approach,
but the end result should be a site that demands less Agency resources, both in
time and money, to reach completion. In addition, the extra effort should also
result in a better product that is less likely to cause unexpected problems in the
future.
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Chapter IV
Key Considerations for Meeting Project
Requirements with Field-Based Analytical
Methods
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Chapter IV
Key Considerations for Meeting Project Requirements with
Field-Based Analytical Methods
Overview
Using data generated on site for on-site decision making is a simple
concept that is intuitively appealing. It allows data gaps to be filled while equip-
ment is still available to collect and analyze samples, thereby reducing additional
mobilizations; it reduces overall project costs by decreasing the number of itera-
tions for writing and reviewing both work plans and reports; and it can increase
the level of certainty about site decisions by generating more data points with
which to make decisions (Crumbling et al., 2001). Unfortunately, this process
has been underutilized in contaminated site programs for a number of complex
reasons. One of the greatest barriers has been the perception that data generated
on site can only be used for screening purposes because they cannot withstand
judicial scrutiny. In reality, however, field generated data can be used for
making site decisions as long as they meet a level of scientific defensibility that
is appropriate for the decision being made. Adequate quality control procedures
can be used to ensure that the data generated meet project requirements and
modern data management methods can provide the needed supporting
documentation. As long as the data can be determined to be scientifically
defensible, it can generally be considered legally defensible.
This chapter provides project managers with an overview of data quality
issues that affect the use of field-based analytical methods (FAMs). The chapter
also provides explanations of how FAMs can be effectively integrated into the
overall data quality process within an on-site decision making framework. This
chapter cannot substitute for the presence of an experienced chemist or QA/QC
expertise on the planning team; rather, it is designed to complement existing
guidance already developed by EPA by focusing project managers on ways they
can meet project requirements with FAMs. As such, it includes the following
three sections:
Selecting FAMs;
Applying quality assurance and quality control to FAMs; and
Managing data during a dynamic field activity.
The quality of data is not limited to the performance criteria of an
analytical method. Rather, it reflects the success of the entire data quality
program which considers all aspects of the sampling and analysis process,
including sampling design, because the number and type of samples to be
collected should be sufficient to provide a representative measurement of the true
value of the contaminants present. Analytical methods and performance criteria
Field-based analytical
methods, with careful
planning, can produce
data of suitable quality,
both technically and
legally defensible, for
making decisions.
Field-based analytical
methods help to
improve a project's
overall data quality by
increasing sample
density and improving
the selection of sample
locations.
IV-1
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can vary greatly at a single site, depending on the end use of the data. However,
as long as the data meet the project data quality requirements, they are considered
acceptable. FAMs can be used to improve the quality of a data set in at least two
ways:
• By increasing the number of samples that can be collected and analyzed
with the same analytical budget, they provide greater confidence that
contaminated areas are adequately characterized; and
• By providing rapid turnaround data, they allow better selection of
subsequent sample locations to quickly fill data gaps and address data
quality problems.
Although fixed laboratories and standard analytical methods can be used
to support dynamic field activities, they are not discussed in this chapter because
QC protocols for these methods are well established. However, they may play
an important role in:
• Providing supporting documentation through the use of confirmatory
analysis;
• Providing a means for validating a FAM modification, or FAM
development prior to mobilization; or
• Providing data for on-site decision making when FAMs are not available
or cost effective, and project turnaround times can cost-effectively be met.
As with all projects, a successful dynamic field activity starts with syste-
matic planning. EPA has developed guidance on how to use a systematic plan-
ning process for contaminated site activities (U.S. EPA, 2000a). Project
managers interested in developing a dynamic work plan and implementing a
dynamic field activity should work with someone who is experienced in using a
systematic planning process. Although dynamic field activities are not appropri-
ate for all situations, particularly if site knowledge is extremely limited or analyti-
cal methods are not available to support their use, project planners should under-
stand what is necessary for a dynamic field activity and they should be
encouraged to consider it as an option from the very beginning. Readers
interested in reviewing data quality objectives (DQOs) developed for a dynamic
field activity can refer to http://www.epa.gov/superfund/programs/dfa/casestudies
to view the DQOs for the Marine Corps Air Station Tustin characterization that is
summarized in Chapter V.
Field-Based Analytical
Method Benefits
- Allow more analysis
for same or less
cost.
- Make data available
to direct sampling.
- Resolve data quality
problems quickly.
Systematic planning is
essential for the
success of any project.
IV-2
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Section 1: Selecting Field-Based Analytical Methods
The process of selecting a FAM for a dynamic field activity is very similar
to the process of selecting any method for a staged field activity. However,
selecting FAMs necessitates consideration of some additional criteria. For
instance, they need project planners to evaluate FAM applicability to particular
field conditions. Exhibit IV-1 provides an overview of the decision process
involved with selecting field-based and fixed laboratory methods. Essentially,
this process involves two parallel tracks: a principal method selection track,
which involves progressive steps of comparing available methods with project
requirements; and an alternative track that is used if the available methods do
not meet project requirements. In addition, one of the most important steps a
project manager can take in selecting appropriate methods is consulting with a
qualified chemist who is experienced in field chemistry and is familiar with the
available methods for the analytes of interest. The chemist can identify and
evaluate methods and suggest any modifications that might be needed to meet
project requirements developed during the systematic planning process.
When selecting field-
based analytical
methods, secure the
services of an
experienced chemist to
lead the process.
Principal Method Selection Process
In the principal method selection process, the project planning team
attempts to match the selection criteria developed in the systematic planning
process with existing field and laboratory-based methods. The steps of this
process involve:
• Listing all potentially appropriate methods based on the analyte(s) and
media of interest;
• Comparing existing methods to project requirements for sensitivity,
selectivity, and dynamic range;
• Examining the refined list of appropriate methods with additional
measurement performance criteria; and
• Conducting method applicability studies, if necessary.
In addition to the assistance of a suitably qualified chemist, basic information on
available FAMs can be found in Appendix C, Summary of Detection Limits for
Selected Field-Based Analytical Methods, and numerous Internet sites, some of
which are listed below:
• Dynamic field activities web site, which contains many links and listings
of available FAMs, at http://www.epa. gov/superfund/programs/dfa:
• National Environmental Methods Index website, which contains a search-
able index of water methods at http ://www.nemi. gov:
Field-based analytical
method selection can
be based on their
ability to provide data
for risk assessments, to
guide a site character-
ization, or both.
IV-3
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Exhibit IV-1
Method Selection Process Overview
Project requirements identified
in systematic planning
Identify rnethod(s) capable of detecting
analyte of concern with required
sensitivity and selectivity
YES
Consider method modification,
development, or altering project
requirements
NO
YES
Evaluate method(s) based on precision,
accuracy, and applicability
to field conditions
YES
Consider method modification,
development, or altering project
requirements
NO ,
Select FAMs for screening, definitive,
and/or confirmatory analysis
Select fixed laboratory method for
screening, definitive, and/or
confirmatory analysis
Conduct method applicability studies
i
YES
NO,
mor method modification or
altering project requirements?
NO
I
L
Consider method modification,
development, or altering project
requirements
IV-4
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Final Update III and Draft Update IV of SW-846, which contains draft and
final methods for a number of established FAMs (e.g., GC,
immunoassays, and XRF) at
http ://www. epa. gov/epaoswer/hazwaste/test/main.htm:
EPA Compendium of ERT Field Analytical Procedures at
http://www.ert.org:
Innovative technology verification reports at http://www.epa.gov/etv:
Hazardous Waste Clean-Up Information (CLU-IN) website, developed by
EPA at http://www.clu-in.org:
The Federal Remediation Technologies Roundtable, developed
co-operatively by EPA, DOD, DOE, and other federal agencies at
http://www.frtr.gov:
Vendor information, including the vendor database at
http ://www. epareachit.org:
The field analytical technologies encyclopedia (FATE) at
http://fate.clu-in.org: and
Field Analytical Measurement Technologies, Applications and Selection,
California Military Environmental Coordination Committee, 1996, at
http://www.epa.gov/region09/qa/r9-qadocs.html.
Initial Method Selection Criteria
Initial method selection criteria include method sensitivity, method
selectivity, and dynamic range. These criteria should be considered simultane-
ously because their relationship to project requirements dictates if a method
should be considered for further evaluation. Selectivity plays an important role in
evaluating sensitivity because it describes whether a method measures a single
analyte or a class of analytes. Depending on project requirements and site condi-
tions, a method's selectivity may not be an important factor, thereby allowing
project planners to choose from a larger group of methods.
Method Sensitivity
In considering the necessary sensitivity of methods, the project planning
team should be aware that there may be multiple action levels for an analyte
depending on what part of the site is being sampled. For example, a highly
sensitive FAM that is needed to reliably detect the leading edge of a groundwater
plume of VOCs could be replaced with a less sensitive FAM within the source
area where contamination levels are high. Two basic aspects of method sensiti-
vity should be considered in the selection process:
• Detection limits; and
• Quantitation limits.
The analytical method
needs to provide
reliable information
about a compound's
concentration at the
action level.
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Detection Limits
A detection limit is the lowest concentration or amount of a target analyte
that can be determined to be different from zero at a stated level of probability. It
is used in calculating the lowest level of measurements achievable by a method or
instrument. The detection limit is important in the method selection process
because it helps the analyst determine the quantitation limit and to interpret values
that fall below the quantitation limit.
Quantitation Limits
A quantitation limit is the lowest concentration of an analyte that a method
can accurately and precisely quantify. Project planners should seek a method
with a quantitation limit below the action level to ensure confidence in decisions
made at the action level. When choosing a method, the project planner should
consider how the data will be used and how much an individual data point will
affect a decision. Generally, project planners should seek a quantitation limit that
is one third to one half the project-specific action level to ensure that the method
will provide reliable data. This ratio provides a margin of safety for the results
and ensures that concentrations reported near the action level do not fall between
the quantitation limit and the detection limit where they would be considered
estimates. If a large number of data points are used to make a decision, the quan-
titation limit can be set closer to the action level because of the increased stati-
stical confidence. Likewise, quantitation limits may need to be set significantly
lower than one half the action level if a project's DQOs do not allow for a signi-
ficant amount of measurement error. Examples of widely used and accepted
terms for quantitation limits include:
Contract required quantitation limits, used exclusively by the EPA
Contract Laboratory Program;
Practical/estimated quantitation limits, used by SW-846;
Method reporting limits, a term in general usage;
Required detection limits, a term in general usage; and
Sample quantitation limits, often used by risk assessors.
Choose a method that
can detect the analytes
of concern below the
action level.
Method Selectivity
Method selectivity refers to the ability of an analytical method to detect or
quantify a particular analyte when other chemically similar analytes are present.
Some analytical methods measure single analytes while others measure a class of
analytes. The project planning team needs to understand what a prospective
analytical method is measuring to ensure the method is appropriate, the results are
meaningful, and to account for possible interferences. If the method's selectivity
is understood, a method that measures a class of analytes can be used to make
Methods that detect a
class of compounds
can be used to make
decisions about
specific analytes in
some cases.
IV-6
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decisions about a specific analyte under site specific conditions. For example, if a
project needs to ensure that the concentration of total polyaromatic hydrocarbons
(PAHs) in soil does not exceed 5.0 mg/kg and that the concentration of
benzo(a)pyrene (BAP), a carcinogenic PAH, does not exceed 1.0 mg/kg, a PAH
immunoassay test kit that gives results by measuring total PAHs could still be
used to select samples that have a total PAH concentration greater than 5.0 mg/kg
for disposal and greater than 1.0 mg/kg for off-site analysis. In addition, it could
determine samples with less than 1.0 mg/kg total PAHs as "clean," since the
concentration of BAP would also be less than 1.0 mg/kg.
Similarly, a method that is subject to interferences from non-target
analytes can be used if the project planning team has additional information about
the interfering compounds. For example, chlorinated pesticide immunoassay test
kits may be marketed for DDT or chlordane, but they tend to have a high degree
of sensitivity to other chlorinated compounds, such as endrin, endosulfan, and
dieldrin. If project planners can demonstrate that interfering compounds are not
present, the immunoassay method may provide reliable data for the target
compound. One significant application of the methods that are sensitive to more
than one analyte is in removal activities to show that cleanup levels have been
achieved because the broad sensitivity can be used as a benefit while also
providing significant cost savings over fixed-laboratory analytical methods.
Dynamic Range
Dynamic range is the range of concentrations an instrument can accurately
measure before a dilution step needs to be performed. There are several issues to
consider when evaluating whether the dynamic range of a method is suitable for
a site. The first is whether quantitative or semi-quantitative concentration
values are required across the entire range of concentrations expected at the site,
and how the expected concentrations compare with the range of the method. If
decision makers only need to know that the concentrations exceed a single
action level, and not by how much, then a method that includes that action level
in its dynamic range should be perfectly suitable. However, if quantitative and
semi-quantitative values are required across the entire range of expected
concentrations then the number of dilutions that may be needed to span this
range should be considered. The method may not be practicable if it has to be
run through a number of dilutions to obtain all the data needed. Project planners
also should consider whether the method is linear through the dilutions and, if
not, if the nonlinearity is correctable.
The Loring Air Force Base case study summarized in Chapter V provides
a good example of this situation. The project planners at this site had originally
intended to use immunoassay test kits for the analysis of PCBs in order to deter-
mine whether soil/sediment should be removed and how it should be treated.
Because there was a broad range of action levels that determined the disposal
Even if a method is
sensitive enough to
meet project require-
ments, it may not be
appropriate if too many
analyses or dilutions are
needed to produce
useful data.
IV-7
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options, project managers soon realized that too many dilutions and analyses were
needed before they could decide the appropriate course of action, thereby
negating any cost savings accrued by the use of immunoassay. Consequently,
they needed a method that could produce a specific data point over a broad range
of concentrations. To meet this project requirement they selected a transportable
gas chromatography unit with an electron capture detector (BCD).
Additional Measurement Performance Criteria
Once appropriate methods have been identified based on the initial selec-
tion criteria, potential methods should be evaluated according to additional
measurement performance criteria. These criteria include:
• Precision and accuracy;
• Applicability to indirectly measuring target compounds; and
• Applicability to field conditions.
Precision and Accuracy
Precision and accuracy are data quality attributes that should be evaluated
for each method during method selection. The results of the systematic planning
process indicate the total study error a project may be able to tolerate. Perfor-
mance criteria are derived for the degree of imprecision and bias (accuracy) that
the project planners can accommodate in the method. Although precision and
accuracy are interrelated, it is possible for a method to be precise, inasmuch as it
gives reproducible results, but be biased in one direction. For example, all the
results generated by a particular method might be biased high. It may be possible
for the project planners to use a biased method if they are aware of the degree of
bias, and can make allowance for it. However, if a method is imprecise, the
degree of error the method will contribute to the total study error should be
carefully assessed so that DQOs for total study error are not exceeded.
Indirectly Measuring Target Compounds
Another issue that should be considered during the method selection
process is whether indirect measurements can be used to evaluate the concentra-
tion of the target compound, also referred to as using "surrogate" analytes or
"indicator" compounds. This process can only be evaluated under site-specific
conditions, as outlined in the data quality objectives, because the selected surro-
gate analyte will not always correlate with the target analyte in the same way.
Hence this option necessitates thorough evaluation to ensure that surrogate
concentrations are directly related to the target analyte and that the analysis of the
IV-8
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surrogate analyte is easier or less expensive to measure. Actual site examples
include:
• Total recoverable petroleum hydrocarbons (TRPH) in soil using on-site
infrared spectroscopy to estimate the level of PAHs and metals. Site
investigation data indicated that there were linear relationships between
TRPH and the two other classes of analytes. This relationship was based
on the fact that the PAHs and some metal risk drivers were associated with
waste oils (see the characterization case study summarized in Chapter V).
• Chlordane and lead analysis in soil using an on-site GC/ECD and XRF,
respectively, as a surrogate for toxicity characteristic leaching procedure
(TCLP) analysis. This substitution was possible because concentrations in
the particular soil type could be directly correlated with TCLP results (see
the cleanup case study summarized in Chapter V).
• Fluoride analysis in groundwater using an on-site ion specific electrode as
a conservative method of defining a plume containing fluoride, arsenic,
cyanide, and PCE at an aluminum production plant because the fluoride
ion was known to travel at least as far as all other analytes of interest.
All of these examples demonstrate that indirect analysis of target com-
pounds can be a valuable tool in reducing project costs and analytical times when
appropriate. Consequently, project planners should consider the use of surrogates
in the method selection process.
Practical Considerations for Analysis in the Field
One final issue that should be considered in selecting a FAM is its applic-
ability to field conditions. Although every method has specific limitations, often
the limitations can be overcome through project planning. Field analysis adds a
new dimension to method selection because the limitations should also be evalu-
ated with specific field conditions in mind. When considering FAMs, project
planners should take into account the following:
• Ruggedness—will the instrument withstand transportation to the site and
perhaps being carried around on site?
• Environmental sensitivity—is the instrument capable of operating in a
wide range of humidity and temperature conditions?
• Electricity demands—if there is a need, how will electricity be accessed?
How and where will instruments that need batteries to operate be
recharged?
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Size and weight—is the instrument truly portable, can it be easily
transported between locations, or will it have to stay in one place?
Water needs—will tap water be easily accessible?
Accessories—will associated equipment and disposable products be
needed, such as balances, pipettes, wipes, towels, carrier gas, and timer?
Training needs—how much experience, oversight, or instruction is neces-
sary for the field operators?
Safety issues—what is the need for items, such as personal protective
equipment or a fume hood?
Investigation derived waste (IDW)—how much waste will be generated,
how hazardous will it be, and how should it be disposed?
Workspace needs—how many people will be working together, and will
they be in each other's way?
Costs—how cost effective is it for the project as a whole? Field genera-
tion of samples should be well matched to analytical throughput capabi-
lities.
Turnaround times—will the analytical method be able to provide results
by the time they are needed to make a decision?
Required licenses—will radioactive sources, such as an XRF instrument,
be used?
There are many
logistical considerations
to using field-based
analytical methods that
need to be evaluated
during project planning.
Method Applicability Studies
Method applicability studies are used in the initial stages of field
mobilization to verify that a proposed FAM will perform as predicted under site-
specific field conditions. Project planners should establish criteria for success
before implementing a method applicability study in order to obtain the most
useful data from the event. A method applicability study may not be necessary
when project planners have "hands-on" experience with a FAM in the matrix they
expect to encounter. However, when needed, these studies are important for
establishing:
• The physical and chemical effects of the site-specific matrix on FAM
performance;
That personnel are proficient in the use of the FAM and can generate
project-required electronic and hardcopy documentation;
IV-10
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That the expected MDLs can be achieved in the matrices of interest;The
comparability of FAM data with the confirmatory method;
The need for backup analytical instrumentation;
The rate of disposable supply consumption; and
An estimated number of samples needed to achieve a statistically signifi-
cant decision based on matrix heterogeneity and statistical variability.
Alternative Selection Strategies If Existing Methods Do Not
Meet Project Requirements
If at anytime in the method selection process project planners realize that
available methods will not be able to meet project requirements, they should
consider three different alternatives:
• Altering the proj ect requirements;
• Modifying existing methods; or
• Developing a new method.
If a new method needs to be developed, a method validation study (U.S. EPA,
1992c) is necessary to document its performance with the matrix and analyte of
concern.
Altering Project Requirements
Sometimes the method selection process will result in a reexamination of
project requirements because the performance criteria for sensitivity cannot
feasibly be met. For example, there are a number of PAHs, such as
benzo(a)pyrene (BAP), that pose a significant cancer risk at extremely low
concentrations. When these concentrations are used as action levels, they result
in a need for both low quantitation limits and low remediation goals. For BAP,
the 10"6 excess lifetime cancer risk value is 12 ng/L in water. In order for analysts
to use a method that has a quantitation level below this concentration, they would
need to take additional measures, such as using very large sample volumes for
extraction, which would increase the cost and time for analysis. In some cases,
regulators may decide that the extra expense of achieving this quantitation limit is
not justified and will allow the project requirements to be altered to an action
level that is more reasonably attainable. If altering project requirements is being
considered, data users (e.g., risk assessors) need to agree to the alteration.
IV-11
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Modifying Existing Methods
Many times an existing method can be modified to meet project require-
ments when there is no readily available method. Modifications may range in
complexity from minor, easily adapted changes, to major changes that necessitate
intensive testing. Regardless of the level of modifications needed, any project-
specific method modification should be clearly documented in the method
standard operating procedure (SOP) maintained by the project.
Minor method modifications are a common solution to meeting project
requirements and may only need an existing method to be run with a modified
preparation or analytical procedure. For example, the Spittler Method (a micro-
extraction technique) is a modified organic extraction method frequently used in
the field to prepare semi-volatiles (e.g., pesticide, PCBs) in soil for analysis by
gas chromatography (U.S. EPA, 2002a). The principles of the Spittler extraction
are the same as those used by off-site laboratories for solvent extractions, but the
quantities of solvent employed and the weight of the soil sample used for extrac-
tion are reduced. Although this modification results in an increased quantitation
limit, it allows for rapid on-site analysis by reducing extraction time and the need
for a complex and expensive extraction apparatus. An additional benefit is that
waste solvent volumes are minimized. Many other simple adaptations to field
conditions and small method modifications can easily be implemented by a field
chemist in order to make on-site analysis more rapid while meeting project
objectives. Examples include:
• Raising GC column temperatures to shorten run times;
• Using an auto sampler to allow unattended overnight analysis of excess
samples when site-specific conditions permit; and
• Using two columns, each with identical injection ports and detectors, to
effectively double the rate of analysis rather than use the second column
for confirmation.
If the project planners intent to compare data generated by a modified method to
data produced by an existing method, a correlation study should be performed
early in the project.
Simple method
modifications can
often enable an
existing method to
meet project-specific
requirements.
Developing a New Method
Because the process of developing a new method is very time consuming
and expensive, project planners generally reserve method development for either
the introduction of a novel analytical technology, or a major modification to an
existing method when there is a serious problem posed by a constituent. An
example of a situation in which method development was justified is presented by
Thorne and Jenkins (1995). In this study, the Army Corps of Engineers was
charged with developing a field method for ammonium picrate and picric acid,
IV-12
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two highly toxic compounds used in explosives. Since the methods they devel-
oped were to be applied to a number of sites and would greatly increase the
potential capabilities of remediation activities at these sites, the Department of
Defense determined that the expense of method development was justified.
Method Validation Studies
Method validation studies are needed for new or highly modified methods
that will be used for site-specific purposes to evaluate the performance of the
method with site-specific matrices. However, they can be expensive. A method
validation study may involve analyzing a reasonably large number of spiked,
field-split samples (probably 25 to 50) with the new, or modified method, and
with an established definitive method. The results of the two sets of analyses are
then compared, and the performance of the new method evaluated. The process
results in a report that is similar to the Innovative Technology Evaluation Reports
produced by the EPA Environmental Technology Verification (ETV) program. A
method validation study for a new FAM does not necessarily involve the tradi-
tional round-robin analysis by multiple laboratories that is associated with
developing fixed laboratory analytical methods. However, a sufficient number of
analyses should be performed to establish method detection limits, allowable
matrix recovery percentages, and precision and accuracy.
IV-13
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Section 2: Applying Quality Assurance and Quality Control
to Field-Based Analytical Methods
Quality assurance (QA) and quality control (QC) comprise interrelated
processes that ensure data will meet project requirements. They also help to
ensure the technical and legal defensibility of analytical data. One aspect in
which dynamic field activities have a tremendous advantage over staged field
activities is in their ability to rapidly identify data deficiencies. This information
allows project managers to fix problems immediately so that data deficiencies are
rectified before demobilization. In contrast, by relying on off-site data, typically
submitted to a project weeks after samples are collected, staged field activities
may not identify problems until after the field work has ended. In these situations
project managers are faced with the unpleasant choice of making decisions with
incomplete information, or delaying decisions many months while a
remobilization is planned and implemented.
In order to ensure that analytical data can withstand judicial review,
project planning teams should develop QA and QC programs that match project
requirements. The purpose of this section is to provide information to project
managers on the key issues to look for in QA and QC programs that are
designed to support a dynamic field activity. Although the procedures are the
same for both on-site and off-site analyses, conducting field analyses
necessitates additional considerations regarding their applications. The degree
to which QA and QC activities are implemented is site specific. Small sites with
relatively simple problems generally use only a fraction of the planning and
management activities presented in this section, while large, complex, and
contentious sites may need full implementation of all the measures discussed
below.
QA/QC considerations
are the same for field-
based analytical
methods and off-site
methods.
Match the QA/QC
project requirements to
the intended use of the
data.
Quality Assurance
QA encompasses all management activities that ensure data are defensible
and of a quality that fits with their intended use. Quality assurance measures
include:
• Establishing quality assurance project plans;
• Developing standard operating procedures; and
• Evaluating the type and frequency of quality assurance audits.
Due to differences among regional offices, EPA project managers should refer to
their regional programmatic quality management plan to identify staff responsible
for reviewing project planning documents and conducting audits.
IV-14
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Establishing Quality Assurance Project Plans
Quality assurance project plans (QAPPs) describe all the necessary
project-specific DQOs and QA/QC procedures for successful data collection.
They forge the link between the outputs of the systematic planning process and its
end product—sufficient, defensible analytical data for project decisions. Not only
are approved QAPPs required before any EPA data collection activities begin
(U.S. EPA, 2000g), but projects undertaken without them are subject to a very
high risk of failure because the QAPP provides the road map for ensuring that
sampling and analytical activities will meet project objectives. For more
information on developing QAPPs, refer to existing EPA guidance (U.S. EPA,
200 la).
Developing Standard Operating Procedures
Standard operating procedures (SOPs) are a QA measure that allows
tasks for meeting project objectives to be reproduced, even if there are changes
in the personnel performing them. SOPs are needed for specific tasks, such as
sampling, decontamination, and analysis because reproducibility is essential for
successful data collection. For example, project teams should be able to
establish that the variation between two soil samples is attributable to a
heterogeneous matrix rather than differences in sampling technique. For more
information on developing SOPs, the reader can refer to existing EPA guidance
(U.S. EPA, 2001b).
The personnel respon-
sible for implementing
SOPs should be
thoroughly familiar
with them before field
work begins.
Evaluating the Type and Frequency of Quality Assurance Audits
An important aspect of a well-designed QA program is evaluating the type
and frequency of QA audits. These audits are independent reviews of sampling
and analytical activities. They are designed to reveal process deficiencies.
Although implementing audits is actually a QC procedure, they are discussed in
this section because determining their applicability for a particular project is a QA
activity.
Audits are an essential part of a QA program because they allow the
project team to attain an objective evaluation of their procedures, and they enable
project teams to implement any necessary corrective actions. Because audit
programs are project specific, the QAPP needs to describe their frequency and the
person, by name and title, who is responsible for performing each type of QA
oversight. In general, project managers should plan on using an audit to evaluate
sampling and analytical procedures at the beginning of a field mobilization,
particularly for large projects. In addition, audits may be needed in the field when
there are:
IV-15
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• Significant changes in field conditions, such as extreme weather condi-
tions, or when project activities are moved to a location with different
geology and geochemistry;
• Changes in field personnel or instrumentation;
• Continuing failures to meet project-specific QC criteria;
• Interferences that impair data quality; or
• Documents found to be incomplete or to indicate unreliable results.
Detailed information on conducting audits is provided in EPA guidance (U.S.
EPA, 2000f). Because of the site-specific nature of audit programs, project
managers should access someone with expertise in conducting audits for the type
of site being managed.
Quality Control
QC encompasses all of the performance measurement activities used to
determine whether a system is meeting performance criteria and, therefore, is
attaining the goals established by QA planning. QC procedures are important for
determining when problems need to be fixed, and for documenting that the data
are of known quality, which helps to ensure reported results are defensible. In
addition to QA audits, there are three major aspects of QC that should be
employed in hazardous waste site activities to meet this objective:
• QC sample analysis;
• Documentation of QC results; and
Data review.
Quality Control Sample Analysis
QC sample analyses are used for estimating whether a method is perform-
ing within the method's performance criteria. Dynamic field activities often need
more QC checks because FAMs can be exposed to environments that are less
controlled and more varied than in fixed laboratories. Although no subset of QC
samples are wholly unique to FAMs, there is a project-driven approach to their
use. Since FAMs provide data on site, they allow QC sample decisions to be
made according to project needs rather than to rigid preset levels. In this way,
dynamic field activities can take full advantage of the on-site data that FAMs
provide to increase confidence in the data and decisions in the most cost-effective
manner.
The five major categories of QC samples include:
• Calibration standards—to determine if analytical systems are performing
within project-specified limits;
IV-16
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• Blanks—to verify that sampling, preparation, or system procedures are not
introducing contaminants;
Spikes—to evaluate if measurements are accurate and free from bias;
Duplicates/Replicates—to evaluate precision among measurements or, in
the case of field duplicates, to evaluate spatial and temporal heterogeneity;
and
• Splits—to compare data provided by two different methods or two
laboratories using the same method.
Traditionally, off-site analysis of split samples has been called "confirmation
analysis."
A summary of these issues is presented in Exhibit IV-2. In addition, a
comprehensive list of QC samples and the type of information they can provide is
available at: http://www.epa.gov/superfund/programs/dfa/download/qctable.pdf
Evaluating "Confirmation" Analyses
One of the most important uses of QC samples during a dynamic field
activity is in confirming whether a FAM is providing data that meets the project
requirements. In order to evaluate these QC samples, it is first necessary to
develop project specific QC protocols for evaluating the differences between a
reference method and a FAM. Split samples have commonly been called
"confirmation samples," implying they provide the most accurate data; however,
it is necessary to evaluate the quality of each data set to confirm the accuracy of
the results. Consequently, split sample analyses should not be used as the sole
QC mechanism to evaluate FAM data. In order to use split samples for
confirmation of a FAM, data users need to be able to understand the sampling
variability (e.g., homogenize samples) and they need to have specific criteria for
determining when results are comparable or which results are more representative
when results are not comparable. A discrepancy between results does not
necessarily indicate a problem with the FAM. Examples of apparent differences
between the two methods that are not the result of problems with the FAM
include:
• Heterogeneity of the sample media—make sure samples from which
duplicates are to be taken are thoroughly mixed to reduce the likelihood
that they contain different levels of the target analyte due to the variation
in sample heterogeneity.
• Size of the sample used for extraction—if the FAM uses a smaller sample
to expedite extraction, the method will generally be less sensitive than a
similar confirmatory method that uses a larger extraction volume.
Comparison studies can identify systematic bias.
When comparing two
sets of data, make sure
you know the quality of
each data set.
Even if a reference
method and a field-
based analytical
method provide
different results, the
field-based analytical
may be operating
properly. Several
factors could cause a
difference in results.
IV-17
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Exhibit IV-2
Summary of Quality Control Sample Issues
Activity
Relationship to Dynamic Field Activities
Quality Control
Sample Program
Design
The QC sample program should be designed to meet the needs of the
specific project.
Consider all types of QC samples to find the right ones to provide
confidence in the FAM generated data.
Calibration Standards
(Quantitation)
FAMs typically need more frequent calibration checks than fixed
laboratory analyses due to environmental conditions such as changes
in temperature, humidity, etc. The frequent calibrations help to ensure
reliable quantitations.
Blank Samples
(Contamination)
Use method blanks, instrument blanks, and cleaning blanks to verify
that contamination has not been introduced into the FAM. Rapid
identification of contamination sources helps to improve data quality
while minimizing cost.
Spiked Samples
(Accuracy)
Several different kinds of sample spikes can be used with FAMs to
provide confidence that the compounds of interest can be accurately
identified and quantified. These spikes include: surrogates in each
sample, matrix spikes, and laboratory control samples (LCSs).
Performance
Evaluation (PE)
Samples
(Accuracy)
PE Samples, also known as proficiency testing samples, are spiked
samples that are provided to the laboratory as an unknown. They can
be used to test if the FAM can accurately identify and quantify the
compounds of interest. They can also be used to test the proficiency
of an analyst for the particular FAM.
Replicates:
Duplicates and
Triplicates
(Precision)
Judicious selection of replicate samples can help to assess the
reproducibility of a measurement and the variability in taking a sample.
Project managers can target the use of replicates to their most critical
decision points and get rapid feedback with the use of FAMs.
Laboratory duplicates and matrix spike/matrix spike duplicates
(MS/MSD) measure analytical variability. FAMs can benefit by using
MS/MSDs to ensure there is a quantitative comparison - project
managers should consider setting relatively wide acceptance windows.
Field replicates can help assess overall measurement error - both
sampling and analysis - since they are separately collected samples.
Field replicates and colocated samples are useful for providing an
early indication of the problems in the sampling and analytical process.
Additional information on their application can be found in existing EPA
guidance (U.S. EPA, 1990).
Split Samples
(Comparability)
Carefully homogenized samples that are divided and sent for analysis
by two different methods or two laboratories using the same method
can help provide confidence that the FAM is producing data of known
quality. These samples, sometimes called confirmation samples, can
help convince decision makers that the FAM is reliable.
IV-18
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Instruments measuring different constituents—many FAMs measure
slightly different analytes than their confirmatory method counterpart. For
example, XRF measures total metal concentrations while inductively
coupled plasma (ICP) methods measure the concentration of metals
extracted through an acid digestion process. Hence, the XRF method may
justifiably provide higher results than the ICP method. Comparison
studies can address these differences.
Loss of volatiles—on-site analysis of volatile compounds often indicates
higher concentrations than off-site analysis due to the loss of volatiles
during shipping and handling. This problem often increases the longer a
sample is stored before analysis. Consequently, sampling and storage
procedures should be used that minimize loss of volatiles.
Redistribution of previously homogenized sample—some samples, such
as saturated sediments, tend to separate by particle size when shaken,
thereby creating a potential for the two methods to provide very different
results. Consequently, procedures should be in place to ensure that
laboratories re-homogenize the samples before subsampling for analysis.
Inconsistent measurement and reporting methods—for example, a field
gas chromatography method may report the wet weight soil concentration
while the confirmation method may report the dry weight concentration.
Therefore, QAPPs should request data to be reported consistently.
Selecting Split Samples
A QC protocol that has commonly been used by projects is to select 10
percent of the samples designated for FAM analysis for "confirmation" with split
analysis throughout the life of the project. A better approach is to submit split
samples for analysis at carefully chosen decision points. The rationale for this
protocol is that a higher percentages of split samples are needed at the beginning
of projects to determine how a method is performing in different site conditions
(e.g., clayey samples versus sandy; turbid samples versus clear). However, once
FAM reliability has been established, split samples are best used to provide
information at key decision points (e.g., where the FAM results are close to the
project's action level; when continued FAM reliability may be in doubt). In some
cases, this protocol may result in more than 10 percent comparative analyses, and
in other cases it may result in less. In either case, the data set will provide the
project team with more confidence in their decisions than fixed-interval submis-
sion for analysis of a predetermined percentage.
Documenting Quality Control Results
Documenting QC results is an important aspect of QC because it enables
the project planning team to prove that the data are of sufficient quality for the
Split samples should
be selected judiciously.
Focus on the beginning
of the project and key
decision points.
The documentation
system should ensure
that QC samples are
easily associated with
appropriate field
samples.
IV-19
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intended use. Environmental samples need to be clearly associated with the
quality control sample(s) that are analyzed with them. This information can be
preserved by having a sample identification scheme that links field samples to
their associated field and method quality control samples. Adequately planning
and documenting procedures up-front will enhance the defensibility of the
resulting data. In addition to this routine recording of QC sample results,
documentation entails maintaining records of:
• All method evaluation procedures, such as method applicability studies;
• SOPs and any modifications that have been adopted; and
• Corrective actions.
A summary of how these issues relate to the implementation of dynamic field
activities is presented in Exhibit IV-3.
Exhibit IV-3
Summary of Documentation Issues
Activity
Documentation of
Study Results
Standard Operating
Procedures
Corrective Action
Relationship to Dynamic Field Activities
A field analytical logbook should be maintained for each FAM
along with any instrument printouts necessary for results to be
verified or validated by an independent reviewer.
Special protocols may be needed to document FAM data.
Changes in SOPs should be clearly documented, particularly for
dynamic field activities, because unexpected changes in site
conditions may need to be accommodated.
Clear direction should be given in the project-specific SOP for
each FAM stating the information that needs to be captured by
the measurement system.
The problem, corrective action, and resolution need to be
recorded so that the problem does not reoccur.
Data Review
Data review is a series of QC procedures that allows project teams to
determine if the data they have collected meet project requirements. Dynamic
field activities rely on this data review process to occur in real time so that
changes can be made to the field activities before data collection is complete.
Data review includes:
• Data verification;
• Data validation; and
• Data quality assessment.
IV-20
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Additional information on data verification and validation is provided in Section
3 of this chapter, Managing Data During a Dynamic Field Activity.
Data quality assessment (DQA) helps illuminate the big picture by
combining results from the sampling and analytical procedures to evaluate
whether the activities met the project's needs. For dynamic field activities, data
quality assessment generally occurs at two points in a project. The first is
informal and occurs daily as the technical team leader examines and evaluates the
data to determine if they make sense and meet the project requirements. This type
of DQA is unique to dynamic field activities and it provides an advantage over
staged field activities because it allows the technical team leader to identify and
correct problems as they occur. During this informal process, the technical team
leader should also discuss the progress of the data collection with the risk
assessors to determine if the data are meeting their needs as well.
The formal DQA is the final step in data review, and it is performed after
data verification and validation are completed. A formal DQA involves a scienti-
fic and statistical evaluation of a data set to determine if it is appropriate for its
intended use. While not strictly a QC procedure, DQA detects conditions under
which a project's DQOs will not be met and is mentioned here for completeness.
U.S. EPA (2000c) has published a five-step process for DQA that should be
consulted for further information on this topic.
The use of FAMs allows for large numbers of data points to be collected
that may not otherwise be economically feasible, and they facilitate the generation
of a data set more representative of site conditions than would otherwise be pos-
sible. Consequently, the quantity of data provided during dynamic field activities
increases the types of statistical analyses that can be conducted with the data, and
it enhances the ability of the statistical methods to aid decision making with
higher levels of statistical probability.
IV-21
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Section 3: Managing Data During a Dynamic Field Activity
Data management is an essential part of ensuring that a project's data are
accurately specified and can be accessed as long as it is needed. Although data
management plans also vary in length and degree of sophistication, all have the
same objectives:
• To report analytical and geological data accurately in an agreed upon,
consistent, and uniform format (e.g., all metal concentrations in mg/kg,
dry weight);
• To provide accessible data, readily retrievable from their stored form,
whether electronic or hardcopy; and
• To ensure the traceability of the data to a specific location, collection time,
and technique.
Data for a dynamic field activity needs be managed very rapidly so that
field work can proceed based on timely and accurate information. This process is
much different than that for a staged field activity where data are generally not
used until after the sampling event. The information in this section complements
existing EPA guidance on managing data (U.S. EPA 1998a and 2001a). Topics
of particular concern to dynamic field activities include:
• Data flowcharts;
• Data management readiness review;
• Data review;
• Data tracking systems;
• Document control; and
• Data visualization.
A summary of data management issues related to dynamic field activities is
presented in Exhibit IV-4.
Data Flowcharts
The first, and perhaps the most crucial, data management activity for a
dynamic field activity is the preparation of a flowchart that clearly documents the
steps of data generation from its source(s) to final storage and retrieval. An
example of a data flowchart is provided in Exhibit IV-5. This flowchart was
developed for the Loring Air Force Base cleanup, which is summarized in
Chapter V. The flowchart contents should include:
Any point at which data are manipulated, transferred, or transformed;
• Those points when QC checks are performed;
• Names, titles, and responsibilities of each individual handling the data;
and
IV-22
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Exhibit IV-4
Summary of Data Management Issues
Activity
Data Flowcharts
Data Management
Readiness Review
Document Review
Data Verification
Data Validation
Document Control
Data Visualization
Relationship to Dynamic Field Activities
Flowcharts should identify and eliminate any
bottlenecks where data could accumulate uselessly.
A rehearsal of the data handling system for large
projects is useful because of the complex data flow
process during a dynamic field activity.
These services should be provided in a timely fashion.
100 percent verification is necessary throughout the
activity for field generated data.
Select which data need validation.
Using "in-house" staff generally provides more control
for ensuring that validation is completed in real time.
Explore electronic data validation options.
Validating FAM data as they are generated may help
to identify and resolve data anomalies, allowing new
samples to be collected where necessary.
In general, QC sample validation should be used with
all FAMs.
Full validation should be used if FAMs are providing
the confirmation level data.
Dynamic field activities can generate an enormous
amount of documents that an independent reviewer
may need to use to establish that data quality was
maintained at project-required levels.
Electronic manipulation of data with software
packages enables the conceptual site model to be
viewed in 2 and/or 3 dimensions with the latest
information integrated quickly, thus greatly enhancing
the decision-making process, particularly for large
projects.
Time frame for each step of the data flow process (e.g., mobile laboratory
chemist to report results to the project chemist/data validator by close of
business each working day; the project chemist is to present validated
results to the team leader by 2:00 p.m. the subsequent day).
The flowchart should indicate that data generated during dynamic field activities
are continually moving toward the end user without any bottlenecks where data
may accumulate uselessly.
IV-23
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IV-25
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Data Management Readiness Review
For large projects, project managers should ensure that every member of
the project team participates in a rehearsal, or readiness review, of the data
handling system, as documented in the flowchart, before the mobilization so that
deficiencies can be identified and personnel can become familiar with the flow
process. For small projects, this recommendation is generally not necessary
because there are not as many groups handling data. Both electronic and hard-
copy dummy data deliverables, similar to anticipated project deliverables, should
be taken through as many steps of the data flow process as possible. This activity
can be accomplished with suitably edited, pre-existing information, such as field
generated data; field boring logs; and laboratory deliverables, including both hard
and electronic copies.
Make sure the data
handling system works
before going into the
field.
Document Review
Project managers need to make sure processes are in place to review data
rapidly during a dynamic field activity so that data of a known quality are avail-
able when they are needed. Document review includes data verification and data
validation. There are numerous ways to facilitate the quick turnaround of data,
such as:
Making analytical and geological data available on a timely basis for the
personnel responsible for data entry;
Giving specific individuals the responsibility of compiling and providing
different types of data on a timely basis;
Providing data, along with supporting documents, to data validation and
verification groups on an agreed-upon time frame;
Using pre-printed forms and worksheets to facilitate the capture of needed
data;
Using, when appropriate, the Field Operations and Records Management
System II Lite (FORMS II Lite), which is a sample document automation
software that aids aspects of data management, such as sample labeling
and tracking, chain of custody reporting, and export of electronic data
(available from EPA Contract Laboratory Program); and
Using data validation software, with oversight from an experienced
chemist, if data are electronically transmitted to a project's database.
Decision makers need
reliable data in a
timely fashion.
Data Verification
Data verification includes the steps used to ensure that the electronic and
hard copy results agree. Project managers should ensure that project plans and
appropriate SOPs clearly state the percentage of results to be reviewed for
verification and how problems will be fixed if incorrect entries are identified.
Determine the steps
needed for the project
manager to have
confidence in the data.
IV-25
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Initially, all data deliverables from a laboratory should be verified; however, this
standard can be scaled back to around 5 or 10 percent once confidence is estab-
lished in the submittals. For field generated data, 100 percent verification is
needed throughout the activity. All field documents (e.g., hydrogeologic data,
drilling logs) should be rapidly reviewed so that field analytical results can be
traced back to a three-dimensional location, date, and time of sampling.
Data Validation
Data validation assesses the quality of the data and assigns flags to it
based on how well the results adhere to the QC criteria. The percentage of a data
set that should be validated is project specific, therefore, project planners should
set a target during the systematic planning process that fits with the end use of the
data. For example, when a large amount of screening data are collected during a
dynamic field activity, much of the data may not need validation since these data
are often collected for the purpose of deciding which sample should be analyzed
with a definitive method. In addition, validation of FAM data is very important at
the beginning of a project, but once its reliability is established, usually the
percentage of validation can be scaled back.
Validating FAM data as they are generated may help to identify and
resolve data anomalies, allowing new samples to be collected where necessary.
In general, QC sample validation should be used with all FAMs. It entails the
review of the results from QC samples and it assesses compliance with the
project-specific performance criteria. Full validation entails a more stringent
level of QC such as having a qualified chemist examine the raw data to determine
if proper analyte identification and quantitation has been reported. A reasonable
standard for determining the level of validation needed is to increase the
thoroughness of review when a data set is critical in supporting a project decision.
Consequently, full validation should be used if FAMs are providing the
confirmation level data (i.e., data that are used to verify a decision or to show that
a sampling and analysis program is performing as expected). Less stringent levels
of validation may be acceptable when long-range trends in the data are being
estimated (e.g., groundwater monitoring).
Data validation can be accomplished using "in-house" staffer by hiring
data validation firms. However, project managers generally have greater control
of the validation schedule when in-house staff is used because data validation
firms may not always dedicate the necessary staff when needed. Control of
validation staff is particularly important during dynamic field activities because
these projects generally need validation to be completed rapidly.
IV-26
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Data Tracking Systems
Project managers should ensure that a system is in place for tracking data
during a dynamic field activity because there may be a relatively long period
between sample submittals for fixed laboratory analysis and the data delivery.
Without proper data tracking information, due dates and potential delays may be
overlooked. In addition, the system should track field-generated data to ensure
that data are available for decision making when expected.
Document Control
Dynamic field activities can generate a considerable number of documents
that an independent reviewer needs to examine to certify that quality was main-
tained at project-required levels. Consequently, project managers should ensure
that a well-designed document control system is developed. Aspects of document
control that should be developed include:
• Training for field personnel on generating and storing field documents;
• Long-term storage of hardcopy and electronic records, including the
frequency that electronic records should be backed-up;
• The length of time records should be maintained; and
• A list of important documents and their location, such as the work plan,
sampling and analysis plan, original chains of custody forms, and field
logbooks.
Data Visualization
Project managers should ensure that data visualization procedures are
established for their projects to help the project team interpret data as it is
generated. Generally, this manipulation occurs with visualization software. For
small projects, this activity may involve no more than a specification of the
software to be used to show boring logs, cross sections, and in-plan maps in the
final report. In these situations, field visualization is usually performed with hand
drawn diagrams. For more complex projects, electronic visualization software is
often more appropriate, especially if stakeholders will be viewing the information
off site.
Depending upon the size of the project and the stakeholders involved,
project managers may want to use a password protected web page to share raw
data and data visualizations with remote users so that decisions requiring broad
input can be made rapidly. The Loring Air Force Base case study, summarized in
Chapter V provides an example of how this activity can be accomplished. If real-
time viewing is not considered necessary, data can also be plotted on a single
IV-27
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computer that is used to distribute reports through e-mail on a pre-determined
schedule (e.g., every few days, weekly, biweekly).
A number of software programs can be used for data visualization. Some
are commercially available. The following programs can be downloaded for free:
EPA's Kerr laboratory provides access within the public domain to
numerous groundwater and vadose zone modeling software programs, at
http://www.epa.gov/ada/csmos/models.html.
• The USGS provides access to public domain software, such as
MODFLOW and related programs at
http://water.usgs.gov/nrp/gwsoftware/.
Spatial Analysis and Decision Assistance (SADA) was developed by the
University of Tennessee, Knoxville, with funding from EPA and DOE in
collaboration with Oak Ridge National Laboratory (ORNL). SADA
incorporates tools from the environmental assessment field into an
effective problem solving environment. The tools include integrated
modules for visualization, geospatial analysis, statistical analysis, human
health risk assessment, cost-effective analysis, sampling design, and
decision analysis at http ://www. si s .utk. edu/ci s/sada/.
• Fully Integrated Environmental Location Decision Support (FIELDS)
Software was developed by EPA's Region 5. It integrates geographic
information systems (GIS), global positioning systems, database, and
analytical and imaging technologies to facilitate site characterization
decision making at http://www.epa.gov/region5fields/.
IV-28
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Conclusion
Technical advances in analytical instrumentation have created an enor-
mous number of choices for project managers. These choices include rapid
generation of rigorous data to support dynamic field activities. Because of the
many advantages to using an on-site decision-making process, project managers
should ensure that project planning teams consider the selection of FAMs during
the initial systematic planning process. In order to ensure adequate consideration,
project managers should work closely with experienced chemists to select
methods that meet their project objectives.
Concerns about the scientific defensibility of FAMs are no more relevant
to the project planning process than concerns about fixed laboratory methods.
Well planned projects can use a wide array of QA and QC procedures to
demonstrate that methods meet project requirements. In addition, there are
numerous data management tools that can be used with field generated data to
ensure appropriate data handling and storage.
In short, for dynamic field activities to result in rational site decisions and
for their resulting data to be effective in court, good laboratory practice and suit-
ably qualified, experienced professionals are needed to support all site activities.
Good laboratory practice is not an extraordinary standard; rather it is part of a
basic quality assurance program to ensure that the data reported are accurate and
support the site decisions. Furthermore, because more data can be generated
economically with FAMs than with fixed laboratories, dynamic field activities
help to increase the confidence project managers and stakeholders have in site
decisions by alleviating questions of data interpretation where most challenges to
scientific evidence occur. In order to meet these standards, project managers need
to understand that confidence in data is related to both sampling and analytical
procedures. They also need to implement the data quality aspects outlined in this
chapter, including:
• Ensuring systematic planning considers all options and selects the most
appropriate procedures;
• Encouraging project chemists to select analytical methods according to
data needs;
• Overseeing the development of project-specific QA and QC protocols; and
• Developing procedures to manage data effectively.
IV-29
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Chapter V
Dynamic Field Activity Case Study Summaries
-------
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Chapter V
Dynamic Field Activity Case Study Summaries
Overview
Although the term "dynamic field activities" is new, a number of project
managers have already demonstrated the effectiveness of this type of field work.
Working independently, they have identified similar techniques for using field-
based analytical methods (FAMs) to streamline site decision making in a way that
results in quantifiable savings in the time and cost of field work. They have also
demonstrated that the FAMs met project requirements for analytical data quality,
and the end product was equal to or better than what could have been done if the
project had relied on fixed-laboratory analyses for decision making.
This chapter summarizes examples of dynamic field activities that have
taken place at three CERCLA sites. Readers interested in reviewing the complete
reports, including supporting information and a full discussion of how cost and
time savings were calculated, should refer to http://www.epa.gov/superfund/
programs/dfa/casestudies. Links to additional case studies are also provided on
this web page.
None of the case studies presented in this chapter are intended to be a
perfect example of a dynamic field activity. Rather, they demonstrate that in
spite of the problems and mistakes that occurred, substantial benefits were real-
ized. In addition to the significant time and cost savings that were documented,
these case studies provide examples of a number of unquantifiable but important
benefits. For example, in the treatment system optimization case study, FAMs
provided a mechanism for discovering mistakes quickly so that corrective actions
could be instituted before problems caused a significant expenditure of resources.
In all three case studies, FAMs helped promote a higher level of confidence in
site decisions by using a larger data set than would have been feasible with con-
ventional approaches. Consequently, by integrating FAMs into project decision
making, overall project QC was improved beyond what could have been obtained
with fixed laboratory analysis alone.
Coincidentally, each of the case studies presented in this chapter is a
Federal Facility site that was part of the Department of Defense's Base Realign-
ment and Closure (BRAC) program. However, they also provide a very diverse
set of contaminants, FAMs, site conditions, activities, and problems. Conse-
quently, they should contain helpful information for a large number of situations.
A comparison of these case studies is provided in Exhibit V-l.
Dynamic field activi-
ties have already been
completed at a number
of sites. Evaluations
of these projects
demonstrate improved
site decision making in
addition to cost
savings ranging from
15 to 57 percent and
time savings ranging
from 33 to 60 percent.
V-1
-------
Exhibit V-1
Summary of Dynamic Field Activity Case Studies
Project Topic
Location
Lead Organization
Constituents of
Concern
Source of
Contamination
Contaminated Media
Receptors
FAMs Used
Action Level
FAM Quantitation
Limit
Activity
Project Time
Percent Time
Savings
Cost Savings
Percent Cost Savings
Characterization
Tustin Marine Corps Air
Station, California
Navy
TCE, metals, PAHs
Leaks and spillage in drum
storage areas
Soil and groundwater
Direct human contact,
discharge to surface water
and downstream wildlife
refuge
FID, GC/PID, Infrared
spectroscopy
TCE (water) 5 ug/L
TCE (soil) 7100ug/kg
TRPH(soil) 10mg/kg1
TCE (water) 5 ug/L
TCE (soil) 50 ug/kg
TRPH(soil) 10mg/kg
Delineation of
contamination
10 months
60
$90,0002
152
Cleanup
Loring Air Force Base,
Maine
Air Force
PCBs, DDT, Chlordane,
Lead, PAHs
Run-off from runway,
industrial activities, direct
application of pesticides
Soil and sediment
Direct human contact,
wetland, wildlife, human
consumption of
contaminated trout
Immunoassay, XRF,
GC/FID, GC/ECD
Aroclor1260 1.0mg/kg
DDD/DDE/DDT 0.12 mg/kg
Chlordanes 0.32 mg/kg
Benzo(a)pyrene 5.14 mg/kg
Aroclor1260 0.5 mg/kg
DDD/DDE/DDT 0.06 mg/kg
Chlordanes 0.16 mg/kg
Benzo(a)pyrene 2.57 mg/kg
Removal of contaminated
soil and sediment;
restoration of stream and
wetlands
2 construction seasons
(May through October)
33
$5 million
25
Treatment System
Optimization
Umatilla Chemical Depot,
Oregon
Army
RDX, TNT, Degradation
products
Washout and recovery of
explosives from munitions
Groundwater
Drinking water supply
Colorimetric test kit
RDX 2.1 ug/L
TNT 2.8 ug/L
RDX 2.0 ug/L
TNT 0.9 ug/L
Optimization of
groundwater treatment
system
Long-term remediation
Not Applicable
$180,000 per year
453
1 Based on the preliminary remediation goals for PAHs.
2 Calculation does not include EPA administrative savings from reduced staff time
reviewing multiple work plans and interim reports. Additional savings in RD/RA are
likely due to detailed characterization.
3 Based on the total cost of sample analysis and treatment with granular activated carbon.
In addition, a summary of a few additional case studies that have been
previously described in other documents is provided in Exhibit V-2. These previ-
ously reported case studies emphasize the applicability of this process to a broad
range of programs and site conditions, including small dry cleaning and leaking
underground storage tank (LUST) sites. The range of cost savings for all of these
sites is 15 to 57 percent, while the range of time savings is 33 to 60 percent.
V-2
-------
Exhibit V-2
Summary of Several Previously Reported
Dynamic Field Activity Case Studies
Project Topic
Location
Lead
Organization
Constituents
of Concern
Contaminated
Media
FAMs
Site Activity
Time Savings
(percent)
Cost Savings
(percent)
Applegate et al.,
1997
8 dry cleaner sites
in Jacksonville,
Florida
State of Florida
PCE
Soil and
groundwater
Transportable GC
running SW-846
methods 8010 and
8020
Characterization
>50
30 to 50
Robbat, 1997
Hanscom AFB,
Massachusetts
Air Force
VOCs, PCBs,
PAHs, metals
Soil and
groundwater
Laboratory grade
equipment used
onsite, including
GC/MS and
ICP/OES
Characterization
Not Calculated
36 to 57
ASTM, 1998b
Unidentified
gasoline station
Unidentified
State Program
Benzene,
Toluene,
Ethylbenzene,
Xylene(s)
Soil and
groundwater
Transportable
GC running SW-
846 methods
801 5 and 8020
Characterization
Not Calculated
Not Calculated
U.S. EPA,
2000h
Wenatchee,
Washington
EPA
Pesticides
Soil
Immunoassay
Removal
Not Calculated
50
V-3
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Section 1: Soil and Groundwater Characterization,
Marine Corps Air Station Tustin
Background
The U.S. Navy planned, implemented, and completed a dynamic field
activity at the Marine Corps Air Station Tustin, in Southern California between
July 1995 and June 1996 (U.S. EPA, 2002c). The 1600-acre military base was
part of the Department of Defense's Base Realignment and Closure (BRAC)
program and the land was designated for redevelopment and integration into the
surrounding community of Tustin, located just north of Irvine in Orange County.
Based on background information, the U.S. Navy and regulators knew of
15 Installation Restoration Program (TRP) sites that may have experienced
hazardous substance releases. Site managers placed seven of these IRPs into the
CERCLA remedial program, and scheduled a remedial investigation/feasibility
study, because they believed these locations were likely to have had substantial
releases. The site managers placed the remaining eight IRPs into the CERCLA
removal program so that an engineering evaluation/cost analysis could be per-
formed, however, they also stipulated that if any of these sites had contamination
worse than anticipated, the site would be transferred to the remedial program. In
addition, the Navy was responsible for investigating approximately 70 RCRA
solid waste management units, a number of potential fuel/heating oil problems,
agricultural fields to determine the impact of past pesticide application, and base
residential areas.
For the purposes of providing a succinct case study of how dynamic field
activities can be used to conduct a characterization, this discussion focuses on the
work at a single site, IRP-12—Drum Storage Area #2; however, investigators
used the same methods throughout the base.
Innovative Approach
Based on historical information, investigators believed that groundwater at
the site was shallow (i.e., less than 20 feet below ground surface) and that the
stratigraphy was generally a sequence of clays and silty sands until reaching the
regional aquifer at about 100 feet bgs. In addition, their list of known chemicals
of concern included chlorinated solvents, BTEX, waste oils (PAHs and metals),
and paint stripper wastes (solvents and metals). With their knowledge of the site,
the project consultants believed that a dynamic approach was both feasible and
advantageous.
One of their first planning activities was to select analytical methods that
would provide data that they could use for on-site decision making. For the
chlorinated solvents and BTEX, they selected the EPA Environmental Response
V-4
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Team GC/PID SOP with detection limits of 5 • g/L for water and 20-50 • g/kg for
soil. For waste oils they selected an infrared spectrophotometer using a modified
EPA method 418.1 that provided a detection limit of 10 ppm in soil and guidance
on which samples to analyze off-site for PAHs. This method allowed investiga-
tors to avoid the time and expense of analyzing for PAHs in the field while
ensuring that contaminated samples would not be missed. In order to ensure
consistent results, they rented a laboratory trailer in which to operate the analytical
equipment and they employed experienced chemists to run the analyses.
Metals analysis in the field posed a problem for investigators because the
common field equipment (i.e., XRF) did not provide the detection limits they
needed for field decision making. However, because investigators realized that
metal contamination was associated with waste oils and paint stripping (i.e.,
chlorinated solvents) they proposed, and regulators accepted, using analytical
results from the IR spectrophotometer and the GC/PID to select samples for off-
site analysis of metals. By using waste oils and chlorinated solvents as surrogates
for metals, they were able to avoid the expense of on-site metals analysis while
ensuring that metal contamination was not being overlooked. In addition,
investigators set up a confirmatory off-site analytical scheme to ensure that
analytes were not missed by the on-site equipment.
To collect soil samples, investigators used a dual tube direct push rig that
provided continuous cores of the subsurface. Each core was logged, examined for
staining and potential preferential pathways, and screened with an organic vapor
analyzer for VOCs. Samples were selected for on-site analysis based on these
observations. Although the initial sampling design was based on a statistically
determined grid, with a majority of the samples being taken on 20-foot centers, a
dynamic work plan was developed to allow the technical team leader to collect
additional samples based on the results of the initial findings. Flexibility clauses
were included allowing deeper sampling, sampling outside the grid, suspension of
grid sampling, and increased sampling densities as needed. When the dynamic
work plan was fully implemented, investigators expected to produce up to 50
samples a day for on-site analysis. Investigators set up the on-site laboratory to
handle approximately 70 samples a day to ensure that the laboratory would not be
a bottle neck for data generation. This excess capability also allowed them to
submit samples from other field activities as needed.
Regular communication among stakeholders (i.e., Navy, EPA, State of
California, contractors) was essential for managing the complicated activities at
this site. To facilitate communication, weekly meetings, either face-to-face or by
teleconference, were held with the decision makers from each organization to
discuss progress, resolve any concerns, and determine the general investigation
plan for the following week. In addition, if any decision points were reached prior
to a scheduled meeting, decision makers were contacted on an as needed basis.
V-5
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Results
Within 30 days of starting the field work, investigators had discovered and
delineated five source areas in the drum storage area that contributed to two TCE
groundwater plumes. Ironically, the initial work plan did not target any of these
zones of contamination. One groundwater plume was 400 feet long and the other
was 1,500 feet long. Neither of these plumes had reached the regional drinking
water aquifer, and although the larger plume had migrated into a deeper perme-
able zone, the groundwater modeling programs indicated that neither plume
would reach the drinking water aquifer.
Investigators also demonstrated that the site did not have any appreciable
contamination from waste oils, contrary to what had been reported previously, and
had no risk level PAHs or metals. The off-site laboratory did detect a Freon
113™ plume contained within the larger TCE plume that was not detected by the
on site GCs. However, the existing QC program had sufficient checks and
balances to ensure contaminants undetected by the field equipment would be
identified.
Compared with what would have been possible at this site using rigid
work plans and decision making based on off-site analysis, the on-site decision
making process at this site cost 15 percent less money ($497,000 vs. $587,000);
required 60 percent less time (44 weeks verses 110 weeks, including project
planning and report writing); and provided much more data than would have
otherwise been feasible, thereby enabling decision makers to have much more
confidence that contamination had not been missed and that they were making the
right site decisions.
Lessons Learned
There were six significant lessons learned from this dynamic field activity:
Regular communication among all stakeholders was essential.
On-site decision making proved to be a "faster, better, cheaper" approach
to meeting the project goals.
•• On-site analysis and DP sampling techniques (both soil and groundwater)
were a powerful combination in rapidly collecting the required data.
•• On-site analysis increased the confidence project managers had in the risk
assessment.
Additional analytical savings could have been realized, without sacrificing
data quality or defensibility, if investigators had selected QC samples
based on decision needs rather than pre-specified percentages.
Although the on-site laboratory used generic PE samples, more useful
information could have been attained if the PE samples contained site-
specific constituents in site-specific matrices.
V-6
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Section 2: Soil and Sediment Cleanup,
Loring Air Force Base
Background
Loring Air Force Base, located near Limestone, Maine, and the Canadian
border, was a 9,000-acre military installation that began operation in 1952 and
closed in September 1994 as part of the Department of Defense Base Realignment
and Closure (BRAC) process (U.S. EPA, 2003). During the base closure process,
the Air Force identified 15 operable units (OUs) requiring investigation. The
CERCLA remedial investigation/feasibility study identified eight separate areas
that required remediation. In order to provide a reasonably concise description of
how a dynamic field activity facilitates site cleanup, this case study discusses the
activities at one of these areas, the Flightline Drainage Ditch Wetlands.
The Flightline Drainage Ditch Wetlands is located between a spill contain-
ment facility and a trout stream, East Branch Greenlaw Brook. The spill contain-
ment facility was a clay-lined detention basin designed to prevent fuel spills and
other contaminants from traveling from the flightline through the Flightline Drain-
age Ditch and downstream into environmentally sensitive areas. Discharges from
the spill containment facility flowed into the 20-acre Flightline Drainage Ditch
Wetlands. The CERCLA remedial investigation/feasibility study (RI/FS) identi-
fied PCBs, lead, DDT/DDD/DDE, chlordane, and PAHs as contaminants of
concern in the sediments of these wetlands.
Innovative Approach
Before the cleanup activities could begin, the site required extensive
sampling and analysis to delineate the zones of contamination more precisely than
had been done during the RI/FS. To facilitate the rapid turnaround of data at a
reasonable cost, the project team set up an on-site laboratory, using a vacant
building, and equipped it with an XRF, two transportable GCs (one with an FID
for the PAHs and the other with an ECD for the PCBs/pesticides). The GCs were
configured with split samplers that allowed their two columns to be used separ-
ately, thus doubling their analytical capabilities. Once the project team estab-
lished confidence in the on-site analytical capabilities among all stakeholders, it
increased the GC's QA and QC protocols to meet off-site laboratory QA/QC
standards. This change allowed the project team to determine if an excavation
area met cleanup levels with on-site analysis, thereby eliminating quick turn-
around off-site analysis of cleanup confirmation samples and greatly reducing
analytical costs.
To improve communication among stakeholders and facilitate rapid
decision making, the project team set up an Internet-based visualization system
V-7
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that displayed data within 24 hours of analysis. This system allowed all the
project decision makers to rapidly come to agreement on whether an area was
clean, thereby enabling stream/wetland excavation and restoration efforts to
continue uninterrupted.
Results
During the initial phase of the field work, the field team collected 271
samples to locate the contamination and determine which areas required excava-
tion. An additional 355 samples were analyzed to confirm removal activities met
the cleanup goals. Both sets of samples were analyzed by the on-site laboratory
and all project decisions were based on these results. A subsequent analysis of
on-site versus off-site data found that in 93 percent of the samples the same
decision would have been made if off-site data had been used. In greater than 6
percent of the samples the on-site laboratory was conservative - suggesting
excavation where excavation may not have been necessary, and in less than 1
percent of the samples the on-site data indicated no further action while the off-
site data would have dictated further excavation. These error rates were well
within the project requirements.
The Record of Decision (ROD) specified that the wetlands would be
restored as part of the remedial action. The project carefully mapped the existing
conditions before the excavations began. By producing data within 24 hours of
sample collection, the restoration crews were able to operate immediately behind
the remediation crews, thereby saving an enormous amount of time. The Air
Force estimates that this process allowed them to reduce the project time frame
from three construction seasons (i.e., May through October) to two. By reducing
the project time, the project saved about 25 percent of the necessary funds
(approximately $5 million). In addition, the on-site laboratory saved the project at
least 50 percent of the potential analytical expenditures.
Lessons Learned
There were five major lessons learned by the dynamic field activity at
Loring Air Force Base:
Close coordination among the stakeholders was essential for rapid
decision making.
•• An on-site laboratory can meet all of the QA and QC protocols of an off-
site fixed-based laboratory.
•• On-site analysis provided several benefits to the project, including: fast
data turnaround times, flexibility in selecting the order in which the
samples were analyzed, and lower analytical costs.
V-8
-------
Faster analytical results enabled the project team to simultaneously
conduct the remedial actions and the restoration activities, thereby saving
considerable project time.
Although rapidly disseminating analytical data to stakeholders was labor
intensive and expensive (due to the need to verify/validate data on very
tight timeframes), the process was invaluable in obtaining agreement on
the course of action and proceeding with the field work without delay.
V-9
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Section 3: Treatment System Optimization,
Umatilla Chemical Depot
Background
The Umatilla Chemical Depot was established as an Army ordnance depot
in 1941 for the purpose of storing and handling munitions. It is located in north-
eastern Oregon in Morrow and Umatilla Counties, approximately five miles west
of Hermiston, Oregon, and six miles south of the Columbia River. The installa-
tion covers over 19,000 acres, 86 percent of which was used by the Army and the
remaining 14 percent for agriculture. In 1988, Umatilla Chemical Depot was
included in the Department of Defense's Base Realignment and Closure (BRAC)
Program, which required its conventional ordnance storage mission to be
transferred to another installation (U.S. EPA, 2002d).
Beginning in the 1950s, the chemical depot operated an on-site explosives
washout plant. The plant was cleaned weekly, and the wash water, which
contained high concentrations of explosives, was disposed of in two nearby
unlined lagoons, where it percolated into the soil to form a 330-acre groundwater
plume in the underlying unconfmed sandy aquifer. The plume consisted primarily
of Royal Demolition Explosive (RDX) with concentrations ranging up to 6,816
Hg/L. Trinitrotoluene (TNT) was also found at elevated levels (3,000 |ig/L), but it
was generally confined to the area under and near the lagoons. In 1994, the
Record of Decision for the groundwater operable unit (OU) selected groundwater
extraction and granular activated carbon (GAC) treatment as the remedy. To meet
these requirements, the Army Corps of Engineers designed and constructed two
parallel treatment systems, each with a pair of 20,000-gallon GAC filled tanks.
The lead tank would remove the majority of contamination and a polishing tank
would ensure that no contaminants were reinjected into the aquifer. The flow rate
for the entire system was 1,300 gallons per minute.
To monitor the treatment system the BRAC cleanup team tested the level
of RDX, the most conservative contaminant, between the lead and polish tanks on
a weekly basis with an on-site colorimetric method. When the team detected an
RDX concentration of 5 • g/L, it shut the system down and changed the lead tank
for off-site regeneration. During the first year of the plant's operation, the project
team noticed that the lead tank was being replaced far more often than had been
anticipated. After evaluating the system they realized that the system's flow rate
was too high for the efficient removal of the RDX although the contact time for
TNT appeared to be satisfactory. Therefore, their challenge was to find a way to
maximize the useful life of the GAC without redesigning the entire treatment
system.
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Innovative Approach
The BRAC cleanup team decided that the best method of optimizing the
system was to use the on-site analytical method to detect breakthrough on the
polishing tank before it violated their discharge permit. In doing so, the lead tank
would be much more fully loaded with contaminants than if its changeout were
based solely on the early breakthrough of RDX as it left the lead tank. As a result,
the team developed four scenarios for evaluating the treatment systems remaining
contaminant removal capacity to be compared with the original sampling and
analysis protocols. Each scenario required someone to analyze samples from
different locations on various schedules. To determine the most cost-effective
scenario, the project team tested each method over four cycles of carbon change-
out starting in December 1997. After the first two cycles, the project team added
an additional scenario to accommodate lower concentration loadings that would
likely occur over time. Each of the scenarios relied on the on-site colorimetric
method for the data the BRAC cleanup team used to make plant shutdown and
tank changeout decisions.
Results
The BRAC cleanup team determined that the most cost-effective scenario
was the last one developed. The new protocols called for sampling and analyzing
the effluent of the lead tank after the first 5 weeks of the treatment cycle (the
experiments indicated no RDX would break through the polish tank that quickly).
The RDX ratio of an influent sample and the lead tank effluent concentrations of
RDX indicated when breakthrough would occur. As long as the ratio stayed
below 0.25, the sampling and analysis of the lead tank effluent were performed
every other week. When the ratio passed 0.25 but was less than 0.5, the sampling
and analysis were performed every week. Finally, when the ratio passed 0.5, the
sampling and analysis was performed every other day at the lead tank effluent line
and at the treatment system effluent line until break through was observed, at
which time the system was shut down for change-out. The use of on-site analysis
allowed these sampling protocols to be tested at a reasonable cost. The new
sampling protocols saved the project approximately $180,000 per year (or 45
percent) in operation and maintenance costs compared to the cost of an approach
of using off-site analysis and the original sampling protocols.
Lessons Learned
Although the capabilities and limitations of the RDX/TNT colorimetric
method for this groundwater pump-and-treat system were thoroughly researched
before it was selected, a number of problems were discovered during the initial
stages of its integration into the project, and the following lessons were learned
from this experience:
V-11
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Method requirements must be clearly provided to the contractor, and the
designated operator must be thoroughly trained in its execution;
Site-specific matrices may require method modifications—high nitrate
levels in the water at the site reduced the method performance, and
modifications were required to meet project objectives;
The data generated on site were essential for the optimization process; and
Undocumented analytical issues may exist, even for well researched
methods; therefore, a method evaluation procedure is often needed to
resolve any potential site-specific problems.
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Section 4: Innovative Dynamic Strategies
During Initial Site Screening
This section provides three examples of the use of dynamic strategies
during the initial site screening process. Although a couple of these sites did not
necessarily take full advantage of dynamic field activities to reduce the time
needed to reach a site decision, they demonstrated the potential for integrating
dynamic field activities more completely into initial site screening programs (e.g.,
CERCLA site assessment). Cost savings for these sites have not been calculated
because the project goals were only to screen sites. The sites discussed in this
section, and their innovative strategies, include:
A dry cleaner site in Florida that used a colorimetric detector tube to track
a groundwater plume;
A lead smelter site that used XRF during the removal evaluation to obtain
the data needed to list the site on the National Priorities List (NPL); and
•• A dry cleaner site in which groundwater samples collected with a direct
push rig were analyzed with a field GC/PID to attribute a PCE plume to its
source and use the data for a CERCLA Hazard Ranking System (HRS)
package.
A summary of the activities at these sites is presented in Exhibit V-3.
Exhibit V-3
Summary of Innovative Dynamic Strategies
During Initial Site Screening
Project Topic
Contaminant
FAM
Benefits and
Applications
B&M Laundromat
PCE
Colorimetric detection
tubes
Inexpensive screening
technique can be used
to supply field GC with
samples
Jacobs Smelter
Lead, Arsenic
XRF
Integrated Site
Inspection/ Removal
Action reducing time
need to list site
Iceland Coin
Laundry
PCE
GC/PID
DP and field GC used
to improve HRS
package QC and
determine the source
for contaminated wells.
Data used in HRS
package
B&M Laundromat, Escambia County, Florida
The B&M Laundromat operated commercial washing machines, clothes
dryers, and a dry-cleaning unit between 1968 and 1974. A 55-gallon drum of PCE
V-13
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was used to top off the level of PCE in the dry-cleaning unit as needed. Employ-
ees transferred PCE to the unit with a hand pump mounted on the top of the drum.
Any spillage during transfer or cleaning of the unit was hosed down with water
and swept out of the back of the building. The site first came to the attention of
the State of Florida when an areal survey was conducted to assess potential
sources of contamination of two nearby supply wells.
Innovative Approach
The field team used a combination of direct push groundwater sampling
and an innovative modification of a colorimetric gas detector tube method to
develop vertical profiles of PCE levels in the subsurface 19 to 30 feet bgs. These
profiles were developed at seven locations with 59 samples that had all been
collected within a single day. An SOP for the detector tube method is available at
http://www.epa.gov/superfund/programs/dfa/fldmeth.htmtfdetect. It is specific to
chlorinated ethenes and, for PCE alone, it has a detection limit of 8 |ig/L. The
method only takes a minute, and the disposables cost about $4.00 per sample. A
24 ml sample of water (or 10 cc of soil placed in 10 ml of ultrapure deionized
water) is put in a 40 ml vial with a septum cap and vigorously shaken. The cap is
then punctured by two hollow needles. One is used to allow air into the vial and
the other to extract the headspace air by hand pumping through the colorimetric
tube. As the headspace air is extracted, the induced vacuum draws ambient air
through the second needle where it bubbles up through the water sample. This
purges the water of its volatile content. The chlorinated ethenes react with the
reagent in the tube, and a direct reading of the relative concentration is provided.
The greater the number of chlorine ions, the greater the sensitivity. Consequently,
the method is very sensitive to PCE and much less sensitive to vinyl chloride.
Results
The information provided by the detector tube method was used to select
three new monitoring well locations, one background and two downgradient, and
to select samples for more rigorous off-site analysis. The investigation confirmed
a groundwater flow direction to the northeast towards the contaminated irrigation
wells. Off-site analysis of the monitoring wells confirmed the existence of a
significant PCE plume, including concentrations as high as 2,000 |ig/L in one of
the new monitoring wells. Since this concentration is greater than 1 percent of the
solubility of PCE, there was a high likelihood of a DNAPL at this location
according to the Agency's "1 percent rule."
In addition, the field analyses were successfully used to choose the most
contaminated soil samples for off-site confirmation analysis, as well as to show
relative levels of contamination in the other core samples. By using the on-site
analysis the investigation team was able to reduce the number of samples analyzed
V-14
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off-site and to focus these samples on the locations that would provide the most
useful information.
Because the federal MCL for PCE is 5 jig/L and the State of Florida MCL
is 3 |ig/L, the site inspection indicated that the site posed a substantial threat to the
groundwater supply of 18,000 people within one mile of the site. Accordingly,
further site work was recommended.
Potential Benefits and Applications
Historically, there had been a general programmatic policy of limiting the
number of samples collected at a site until there was a clear indication that the site
should be considered for the NPL. As a result, the project planners developed a
work plan with a limited scope of work so that additional site decisions and
activities could be made in stages. However, the equipment available to the
project team was ideally suited for a dynamic field activity and it could have been
used to collect all the data necessary to make the site decision in a single mobili-
zation. For example, if the dynamic work plan had allowed a continuation of the
field work to identify any DNAPL source during the initial sampling, then
additional samples could have been collected to link the source area to receptors.
The resulting costs would have been only slightly more than the originally
scheduled field work, since only one work plan, mobilization, and final report
would have been needed. In addition, the complete report would have provided
decision makers with detailed information about the size of the plume and the
actual threat to drinking water supplies, enabling them to implement corrective
action expeditiously if needed.
Jacobs Smelter, Stockton, Utah
Jacobs Smelter is located in the northeastern Utah City of Stockton. It
operated from 1872 to perhaps the early 1900s, refining lead and silver ore. The
State of Utah collected some initial soil and sediment samples from resident
yards, fields, and former smelting locations in 1997 and found extremely high
levels of lead (68,400 mg/kg) and arsenic (6,550 mg/kg), prompting further
investigation at the site. For more information about this site, the reader can refer
to the HRS documentation package located on the Internet at:
http://www.epa.gov/oeriDage/superfund/sites/docrec/pdocl566.pdf
Innovative Approach
The project planners used a dynamic strategy to implement a CERCLA
integrated site assessment/removal action between August 10, 1998, and October
9, 1998. A total of 5,296 samples were collected and analyzed on site with XRF
at 252 properties to delineate contamination, begin removal activities, and collect
V-15
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data for HRS purposes. Composite sampling of the surface soils (0-2 inches bgs)
was used to determine if lead levels exceeded the action level of 400 mg/kg, or
arsenic was detected above 100 mg/kg. Because XRF results are greatly influe-
nced by the sampling and processing procedures that are used, the QAPP outlined
detailed procedures that would ensure consistent results. The samples were
collected with a stainless steel spoon and dried. Before analysis, the dried
surficial samples were passed through a 60 mesh sieve (i.e., openings of 0.250
mm). If XRF results indicated high levels, three more samples (2-6 inches bgs,
6-12 inches bgs, and 12-18 inches bgs) would be collected at each of the loca-
tions where the initial composite samples were gathered. After being dried and
passed through a 10 mesh sieve (i.e., openings of 2.00 mm), they again were
analyzed with XRF.
As a QC procedure, 10 percent of these samples were sent to an off-site
laboratory for confirmatory analysis with SW-846 Method 6010. Because XRF
analysis does not destroy the sample, the identical sample was used for the
confirmatory analysis, thereby minimizing the potential for site heterogeneity to
affect the comparison of results. For detailed information on the performance of
XRF analyzers and how they can be used for specific project objectives, the reader
can refer to information on the Dynamic Field Activities web site
(http ://www. epa. gov/superfund/programs/dfa/fldmeth.htm#xray).
Results
The results indicated that more than half of the soil composites were near
or exceeded the 400 mg/kg action level for lead, and the followup sampling
indicated that 30 residences had lead soil levels greater than 3,000 mg/kg.
Because the investigation integrated remedial and removal activities, project
managers were able to schedule a removal action at the highly contaminated
homes immediately.
A comparison of on-site and off-site confirmation results for lead showed
a good correlation. However, the correlation with the arsenic results was not good
because elevated levels of lead in the samples interfered with the XRF analysis
and masked its presence. Fortunately, because the levels of lead that interfered
with arsenic analysis were in excess of the action level, this analytical problem did
not affect the decisions that were made.
Potential Benefits and Applications
By using an on-site XRF for this investigation, the field investigation was
completed in one mobilization over a two-month period. The real-time analysis
allowed for decisions to be made in the field on whether a given area required
further sampling. The XRF and off-site confirmation sample results showed
sufficiently close correlation to allow for decisions on whether or not to excavate
V-16
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an area based on the field instrument results alone. By integrating the remedial
and removal programs, project managers were able to streamline site decision
making and take rapid action.
Iceland Coin Laundry and Dry Cleaning, Vineland, New
Jersey
Iceland Coin Laundry and Dry Cleaning operated in the southern New
Jersey Town of Vineland between approximately 1963 and 1971. According to the
property owner, the laundry had four coin-operated dry cleaning units. These
eight-pound-capacity machines each used four gallons of PCE. At the time of
operation, the building had two 14-foot-deep cesspools with a 40-foot drain field.
For more detailed information about this site, the reader can refer to the HRS
documentation package located on the Internet at: http://www.epa. gov/oerrpage/
superfund/sites/docrec/pdoc 1561.pdf.
Innovative Approach
DP equipment was used to collect 50 groundwater samples at 14 locations.
Forty-four of these were analyzed on site with a portable GC/PID capable of
detecting the contaminants of concern (PCE, TCE, and 1,2-DCE).
Results
By combining DP equipment with a portable GC/PID, the field team was
able to develop a vertical profile of the contaminant plume and estimate its areal
extent before placing monitoring wells. The investigation confirmed that the
Iceland property was the source of a PCE plume that was impacting private water
supply wells. It also showed the location of the highest contaminant concentra-
tions as well as identify several potential source areas on the site.
Potential Benefits and Applications
There were two interesting aspects to this site inspection. First, the HRS
package was completed with data generated from DP groundwater sampling rather
than traditional monitoring wells. Second, the on-site analysis seemed to provide
better data quality than the fixed-laboratory analysis, providing an example of on-
site measurements supplying a quality check for off-site results. Evidence of this
conclusion is provided by:
•• The fixed laboratory reported common laboratory solvents, such as
acetone, methylene chloride, and carbon disulfide in field blanks, trip
blanks, and field samples;
V-17
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•• The on-site GC provided consistently higher concentrations of PCE;
•• The validation company rejected a detection of 1,1,2,2-tetrachloroethane at
the off-site laboratory due to inadequate instrument calibrations; and
A separate round of sampling used a different fixed laboratory for
confirmation analysis and a comparison of the results showed better
agreement between the on-site and fixed laboratory results.
Consequently, this site provides evidence that not only can DP ground-
water sampling and on-site analysis be used to develop an HRS package, but also
they can help to improve the package with another level of QC that provides more
data to support the site's listing.
V-18
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Conclusion
The case studies provided in this chapter demonstrate that dynamic field
activities are capable of reducing the time and cost of field work at contaminated
sites for a wide range of site activities. They can also substantially improve QC
by providing real-time data that can be used to correct problems or even to
provide another method of verifying fixed-laboratory data. A summary of some
of the specific benefits that these case studies document include:
•• Reduced administrative costs for regulators and contractors by eliminating
iterations of project planning, interim report writing, and document
review;
•• Reduced remediation and O&M costs through detailed site
characterization that can help focus subsequent field work;
•• Improved project QC;
•• Eliminated delays in getting results caused by an over-booked off-site
laboratory, thereby increasing the effective use of excavation equipment;
Improved data quality that met all decision criteria established in project
planning documents;
•• Improved overall project efficiency;
Reduced total project costs by 15 to 45 percent; and
Reduced project time by 33 to 60 percent.
Although these benefits are significant, they cannot be attained simply by
using FAMs. Successful dynamic field activities require a concerted effort by all
the parties involved in a project to develop a project plan that allows decisions to
be made as data are generated. In order for this goal to be accomplished, the
project must develop:
• • Clear lines of communication;
•• Mutually agreed upon criteria for specific decisions so that actions can be
taken when those criteria are met;
Contingency procedures and contracts that can be implemented rapidly if
problems are encountered; and,
Dynamic work plans that allow project activities to be modified as new
information is received.
V-19
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Response, Washington, DC. http://www.ert.org
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and Sediment, Part I — Surface Water and Sediment. Interim Final. OSWER 9360.4-16. Office
of Emergency and Remedial Response, Washington, DC. http://www.ert.org
U. S. EPA. 1996a. Environmental Investigations Standard Operating Procedures and Quality
Assurance Manual (EISOPQAM). Region 4, Science and Ecosystem Support Division, Athens,
GA. http://www.epa.gov/region04/sesd/eisopqam/eisopqam.html
U.S. EPA. 1996b. Explosives in Water Field Screening Technologies UMDA andSUBASE
Bangor (draft). Prepared by Black & Veatch Special Projects Corp., Tacoma, WA, for U.S.
Environmental Protection Agency Region 10, Project Number 71370
U.S. EPA. 1996c. Sampler's Guide to the Contract Laboratory Program. EPA/540/R-96/032.
Office of Solid Waste and Emergency Response, Washington, DC.
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EPA/540/R-95/128. Office of Emergency and Remedial Response, Washington, DC.
http://www.epa.gov/superfund/resources/soil/introtbd.htm
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Emergency and Remedial Response, Washington, DC. http://www.epa.gov/
superfund/resources/soil/index.htm#user
U.S. EPA. 1997a. Data Quality Assessment Statistical Toolbox (DataQUEST) (EPA QA/G-9D).
EPA/600/R-96/085. Office of Research and Development, Quality Assurance Division,
Washington, DC. http://www.epa.gov/quality/qa_docs.html
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Marine Corps Air Facility Tustin, California, CTO-0049/1165.
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U.S. EPA. 1997 c. Expedited Site Assessment Tools For Underground Storage Tank Sites: A
Guide for Regulators, EPA 510-B-97-001. Office of Solid Waste and Emergency Response,
Washington, DC. http://www.epa.gov/swerust 1 /pubs/index.htm
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Washington, DC. http://www.epa.gov/epaoswer/hazwaste/test/main.htm
U.S. EPA. 1998a. Guidance for Quality Assurance Project Plans (EPA QA/G-5). EPA/600/R-
98/018. Office of Research and Development, Quality Assurance Division, Washington, DC.
http://www.epa. gov/quality/qa_docs.html
U.S. EPA. 1998b. Environmental Technology Verification Report: Immunoassay Kit—Strategic
Diagnostics, Inc., EnviroGard PCB Test Kit. EPA/600/R-98/113. Office of Research and
Development, Washington, DC. http://www.epa.gov/etv/02/egard.pdf
U.S. EPA. 1999a. Contract Laboratory Program (CLP) Statement of Work (SOW) for
Inorganics Analysis, Multi-Media, Multi-Concentration. SOW ILM04.1.
http://www.epa.gov/superfund/programs/clp/methods.htm
U.S. EPA. 1999b. Contract Laboratory Program (CLP) Statement of Work (SO W) for Organics
Analysis, Multi-Media, Multi-Concentration. SOW OLM04.2.
http://www.epa.gov/superfund/programs/clp/methods.htm
U.S. EPA. 1999c. 40 CFR Part 136—Guidelines Establishing Test Procedures for the Analysis
of Pollutants. http://www.epa.gov/epacfr40/chapt-I.info/subch-D/40P0136.pdf
U. S. EPA. 1999d. 40 CFR Part 300—National Oil and Hazardous Substance Pollution
Contingency Plan. http://www.epa.gov/docs/epacfr40/chapt-I.info/subch-J/40P0300.pdf
U.S. EPA. 1999e. Hazard Ranking System Documentation Package: Iceland Coin Laundry
Area Ground Water Plume, Vineland, Cumberland County, New Jersey. CERCLIS ID No.:
NJDOOO1360882. http://www.epa.gov/oerrpage/superfund/sites/docrec/pdocl561.pdf
U.S.EPA. 1999f. HRS Documentation Record: Jacobs Smelter, UT0002391472. U.S.
Environmental Protection Agency, Region VIJJ.
http://www.epa.gov/oerrpage/superfund/sites/docrec/pdocl566.pdf
U.S. EPA. 1999g. Sampling Analysis Report, Jacobs Smelter, Stockton, Utah. TDD No. 9806-
0015.
U.S. EPA. 1999h. USEPA Contract Laboratory Program National Functional Guidelines for
Organic Data Review. EPA/540/R-99/008, OSWER 9240.1-05 A-P. Office of Emergency and
Remedial Response, Washington, DC.
http://www.epa.gov/superfund/programs/clp/guidance.htm
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U.S. EPA. 2000a. EPA Manual for Quality Environmental Programs. Manual 5360 Al. Office
of Environmental Information Quality, Washington, DC.
http://www.epa. gov/quality/qa_docs.html
U.S. EPA. 2000b. Field Operations and Records Management System II Lite (FORMS II Lite)
Version 5.0 Software. Superfund Contract Laboratory Program, Washington, D.C.
U.S. EPA. 2000c. Guidance for the Data Quality Assessment: Practical Methods for Data
Analysis (EPA QA/G-9). EPA/600/R-96/084. Office of Research and Development, Quality
Assurance Division, Washington, DC. http://www.epa.gov/quality/qa_docs.html
U.S. EPA. 2000d. Guidance for the Data Quality Objectives Process (EPA QA/G-4).
EPA/600/R-96/055. Office of Research and Development, Quality Assurance Division,
Washington, DC. http://www.epa.gov/quality/qa_docs.html
U.S. EPA. 2000e. Guidance for the Data Quality Objectives Process for Hazardous Waste Sites
(EPA QA/G-4HW). EPA/600/R-00/007. Office of Research and Development, Quality Assurance
Division, Washington, DC. http://www.epa.gov/quality/qa_docs.html
U. S. EPA. 2000f Guidance for Data Quality Assessment: Practical Methods for Data Analysis
(EPA QA/G-9—QAOO Update). EPA/600/R-96/084. Office of Research and Development,
Quality Assurance Division, Washington, DC. http://www.epa.gov/quality/qa_docs.html
U.S. EPA. 2000g. Guidance on Technical Audits and Related Assessments for Environmental
Data Operations, (EPAQA/G-7). EPA/600/R-99/080. Office of Environmental Information,
Washington, DC. http://www.epa.gov/quality/qa_docs.html
U.S. EPA. 2000h. Innovations in Site Characterization, Case Study: Site Cleanup of the
Wenatchee Tree Fruit Test Plot Site Using a Dynamic Work Plan, EPA/542/R-00/009. Office of
Solid Waste and Emergency Response, Washington, DC.
http ://www. epa. gov/tio/download/char/treefruit/wtfrec.pdf
U.S. EPA. 2000i. Policy and Program Requirements for the Mandatory Agency-Wide Quality
System. EPA Order 5360.1 A2. http://www.epa.gov/quality/qa_docs.html
U.S. EPA. 2000J. Quality Manual for Environmental Programs, EPA Order 5360. al. Office of
Environmental Information, Washington, DC. http://www.epa.gov/qualityl/qa_docs.html
U.S. EPA. 2000k. Superfund/RCRA Regional Procurement Operations Division Contracts
Guidance Document No. 00-01.
U.S. EPA. 200 la. EPA Requirements for Quality Assurance Project Plans (EPA QA/R-5).
EPA/240/B-1/003. Office of Environmental Information, Quality Assurance Staff, Washington,
DC. http://www.epa.gov/quality/qa_docs.html
U.S. EPA. 200 Ib. EPA Requirements for Quality Management Plans. (EPAQA/R-2).
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EPA/240/B-1/002. Office of Environmental Information, Quality Assurance Staff, Washington,
DC. http://www.epa.gov/quality/qa_docs.html
U.S. EPA. 2001 c. Guidance for the Preparation of Standard Operating Procedures (SOPs) for
Quality-Related Documents (EPA QA/G-6). EPA/240/B-01/004. Office of Environmental
Information, Quality Assurance Staff, Washington, DC.
http://www.epa. gov/quality/qa_docs.html
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http://www.epa. gov/oerrpage/superfund/tools/cag/ci_handbook.pdf
U.S. EPA. 2001e. Supplemental Guidance for Developing Soil Screening Levels for Superfund
Sites: Peer Review Draft. OSWER 9355.4-24.
http://www.epa.gov/superfund/resources/soil/ssgmarch01.pdf
U.S. EPA. 2002a. Standard Operating Procedure for PCB Field Testingfor Soil and Sediment
Samples. Unpublished document developed by EPA Region 1.
http://www.epa.gov/superfund/programs/dfa/download/pcb_sop.pdf
U. S. EPA. 2002b. Handbook ofGroundwater Protection and Cleanup Policies for RCRA
Corrective Action: For Facilities Subject to Corrective Action Under Subtitle C of the Resources
Conservation and Recovery Act. EPA/530/R-01/015. Office of Solid Waste and Emergency
Response. Washington, D.C.
http://www.epa.gov/correctiveaction/resource/guidance/gw/gwhandbk/gwhndbk.htm
U.S. EPA. 2002c. Dynamic Field Activity Case Study: Soil and Groundwater Characterization,
Marine Corps Air Station Tustin. EPA/540/R-02/005. OSWER No. 9200.1-43. Office of Solid
Waste and Emergency Response, Washington, D.C.
http://www.epa.gov/superfund/programs/dfa/casestudies
U.S. EPA. 2002d. Dynamic Field Activity Case Study: Treatment System Optimization,
Umatilla Chemical Depot. EPA/540/R-02/007. OSWER No. 9200.1-45. Office of Solid Waste
and Emergency Response, Washington, D.C.
http://www.epa.gov/superfund/programs/dfa/casestudies
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Integrity of Information Disseminated by the Environmental Protection Agency, EP A/260/R-
02/008. Office of Environmental Information, Washington, DC.
http://www.epa.gov/oei/qualityguidelines/index.html.
U.S. EPA. 2003. Dynamic Field Activity Case Study: Soil and Sediment Cleanup, LoringAir
Force Base. EPA/540/R-02/006. OSWER No. 9200.1-44. Office of Solid Waste and
Emergency Response, Washington, D.C.
http://www.epa.gov/superfund/programs/dfa/casestudies
U.S. Naval Facilities Engineering, Southwest Division. 1995a. Draft Final Remedial Investiga-
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tion Work Plan for OU-1 andOU-2, Marine Corps Air Station, Tustin, California.
U.S. Naval Facilities Engineering, Southwest Division. 1995b. Draft Final Sampling and
Analysis Plan Marine Corps Air Station, Tustin, California. .
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Data Quality Objectives IRP-12 (Drum Storage Area No. 2). Draft Final Remedial Investigation
Work Plan for OU-1 andOU-2, Marine Corps Air Station, Tustin, California.
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tion Report for Operable Units 1 and 2, Marine Corps Air Facility, Tustin, California.
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Advection, Dispersion, and Chemical Reactions of Contaminants in Groundwater Systems. S.S.
Papadopulos & Associates, Inc. Software and user guide prepared for U.S. EPA.
http://www.epa.gov/ada/csmos/models.html
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Appendix A
Daily and Weekly Activity Summary
Reports
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Appendix A
Daily and Weekly Activity Summary Reports
Summary reports are a convenient way for technical team leaders to
communicate the highlights of site activities to all interested parties and to
provide a succinct historical record. The following daily and weekly summary
reports are provided as examples of the type of information that should be
included in these documents. They may be modified to meet the data needs of
specific projects or simply copied and used as is. These reports are not intended
to record a detailed listing of all data collected or to replace data evaluations that
result in a detailed picture of the nature and extent of contamination. The follow-
ing discussion provides an explanation of the requested information.
Equipment On Site
This section should include any major equipment, such as a mobile labora-
tory, drilling rig, DP rig, or well development rig, that has been used on site
during the assigned time period. Designate the type of rig, such as CME-51 hol-
low stem auger. In addition, this section should discuss any new equipment that is
expected to be needed during the following period.
Summary of Surface/Subsurface Activities and On-Site
Chemical Analysis
This section should not be overly specific but should be sufficiently
detailed such that a person familiar with the field activities will know what is
being accomplished. The chemical analysis discussion should also be general
with significant findings highlighted. Any QA/QC problems and subsequent
corrective action should be noted. Examples of the type of text to include in this
section are:
1,500 cubic yards of soil were removed from area B for offsite disposal at
the designated PCB landfill. Immunoassay results indicate there is a
remaining hotspot in the southeast corner of this area. I have scheduled
the chemist to come in early tomorrow so we can take two deeper soil
samples by hand auger to determine the depth to which the soil should be
removed in this area. There were no noted QA/QC or equipment
problems.
• Seven DP locations were pushed to 20 feet in area C. The onsite GC indi-
cated five were not in contaminated areas but two were. Soil contami-
nation is associated with the presence of groundwater, which also contains
TCE (15 and 100 |ig/l) at the two contaminated locations. In accordance
A-1
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with the FSP, DP activities tomorrow will try to bound the plume width
and then look for the source. No QA/QC or equipment problems were
encountered.
Twenty surficial samples (less than 1-inch deep) were taken in area D
according to the gridding scheme and analyzed onsite. XRF readings for
lead ranged from 40 mg/kg to 530 mg/kg. Three of these are above the
action level. However, a QC sample taken one foot away from the
designated grid location was 200 mg/kg higher than the regular sample.
This denotes an unexpected heterogeneity in the sampling grid. The site
will be resampled tomorrow using the alternate compositing scheme
provided in the FSP. The regular sample and the duplicate will be
included in the confirmation samples being sent offsite.
In the past week the creosote release at the drip pad was delineated by
CPT/LIF. Forty pushes on 10-foot centers revealed a pool of creosote
resting on a clay unit at 12 feet bgs. The creosote did not penetrate into
the clay at sufficiently high concentrations to be detected by the LIF. The
soil above the clay unit in the release area is contaminated throughout its
depth. The pooling extends 15 feet to the east beyond the contaminated
overburden foot print. The attached cross sections give the approximate
concentration distributions. No QA/QC or equipment problems were
encountered. We anticipate moving the investigation to the impoundment
area the first of next week.
Location of Samples Collected for Off-Site Analysis and
Requested Analyses
If the sample identification system includes sample location information,
such as GPS coordinates, then a copy of the chain-of-custody can simply be
attached because it indicates the requested analyses. On the other hand, if the
identification system does not include location information, as is often the case
with radionuclide samples, then this information should be added.
Other Activities and Problems Encountered
This section provides an opportunity to document activities that occur only
occasionally, such as an EPA laboratory audit or a visit by the project manager. It
should also include problems encountered that are not described as part of the
sampling and analysis activities above.
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Attachments
Depending on the site conditions, purpose of the field work, and the needs
of interested parties, copies of various types of information can be attached to
weekly and in some cases, daily summary reports. If the data for the field work
are available on a website, however, attachments may not be necessary.
A-3
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Daily Activity Summary Report
Date:
Project Name:
Project Number:
Weather
Temp (F)
Wind
Humidity
Bright
Sun
Under 32
Still
Dry
Clear
32-50
Mod.
Mod.
Overcast
51-70
High
High
Rain
71-85
Snow
Over 85
Report No.
Equipment on site (include any expected changes):
Summary of surface/subsurface activities and results of on-site chemical analysis:
Sheet 1 of 2
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Daily Activity Summary Report Con't
Project Name:
Project No./Task No.:
Date:
Location of samples collected for off-site analysis and requested analyses:
Other activities/problems encountered:
Sheet 2 of 2
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Weekly Activity Summary Report
Project Name:
Project Number:
Date:
Week of:
Equipment used on site (include any expected changes):
Summary of surface/subsurface activities and on-site chemical analysis results:
Sheet 1 of 3
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Weekly Activity Summary Report Con't
Location of samples collected for off-site analysis and requested analyses:
Other activities/problems encountered:
Sheet 2 of 3
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Weekly Activity Summary Report Con't
Field activities planned for following week:
Attachments (check box and describe):
D Drilling Logs:
D Well Construction Logs:
D Well Development Data Sheets:
D Field Change Notice:
D Aquifer Test Data:
D Geotechnical Soil Data Sheets:
D Fence Diagram:
D In-Plan Diagram (sample locations, groundwater contours, contaminant plume):
D Laboratory Data:
D In Situ Water Quality Data:
D Interpreted CRT Logs:
D Chains of Custody:
Sheet 3 of 3
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Appendix B
Qualification Work Sheets
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Appendix B
Qualification Worksheets
This appendix contains three worksheets that are designed to aid EPA
project managers in evaluating the experience and qualifications of the personnel
and firms proposed by the project leads (e.g., Army Corps of Engineers, contrac-
tor, EPA). It does not specify minimum requirements; rather it provides a sum-
mary of key information that the Agency project manager can use to quickly
review qualifications and identify information gaps and areas, such as level of
experience, that need clarification. As such, the worksheets can be used to
supplement resumes provided by project leads.
Worksheet I
Worksheet I asks for names and experience levels of the planning team
members. This worksheet should only include the names of the principals who
will be responsible for the planning and execution of field work, decision making,
data evaluation and management (including QA/QC activities), and report writing.
This list should not include personnel who will be involved only in the field (e.g.,
a junior level geologist who assists in data collection but is not part of the
decision-making team).
The third and fourth columns of this worksheet ask for the planning team
members' years of experience in environmental work and in their area of exper-
tise. For example, if an individual is a geologist with 10 years experience but 8 of
those years were as an exploratory geologist with a mining company and only 2
years were related to environmental investigations, then 2 years would be entered
in the third column and 10 would be entered in the fourth column. The key issue
covered by this worksheet is to reveal the amount of relevant experience for key
personnel.
Worksheet II
The purpose of Worksheet n is to clarify the level of experience of
individuals conducting the field work. The worksheet asks for two essential
pieces of information: the years of experience in performing the specific field task
the individual will be assigned; and the years of experience an individual has in
general in their area of expertise. For example, if the work plan calls for having a
hollow stem auger on site, then this would be listed and the name and qualifica-
tions of the individual assigned to work with the driller would be listed (e.g.,
geologist, 2 years logging borings and installing wells with hollow stem augers, 5
years overall).
B-1
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Individuals that perform multiple tasks at a site will have multiple entries
on the worksheet. For example, if a geologist is logging soil but will also collect
soil and groundwater samples, his or her years of experience with all three activi-
ties should be provided.
Worksheet III
Worksheet in is designed to provide information about the capabilities of
technical specialty firms and their personnel. The second column dealing with the
firm's experience in the designated work area is easily obtained from its qualifica-
tions statement. The third column addresses the qualifications of the individual
assigned to operate the equipment. As with the questions for prime contractors,
the years of experience of the individual doing the actual work should be
provided.
B-2
-------
Worksheet I
Planning Team Member Qualifications
Planning Team Member
Job Title
Name
Years Experience1
in Appropriate2
Environmental
Work
Years Experience
in Principal Area of
Expertise
How much time will this
individual spend in the
field?
Full-
time
Part-
time
None
CD
1 Years of experience exclusive of education; for data management/IT positions, years of experience applies to the proposed data management
software and equipment interfaces.
2 If action is a soil removal, "appropriate" means soil removal. If action is characterization, then "appropriate" means characterization.
-------
Worksheet II
Field Team Qualifications
Field Activity
Drilling/DP (1)
Soil logging
Soil sampling
DP Groundwater sampling
Monitoring well installation
Drilling/DP (2)
Soil logging
Soil sampling
DP Groundwater sampling
Monitoring well installation
Drilling/DP (3)
Soil logging
Soil sampling
DP Groundwater sampling
Monitoring well installation
Proposed Field
Equipment
Proposed Individual
Name
Job Title
Years Experience in
Appropriate1 Field
Work
Years Experience
in Principal Area
of Expertise
CD
1 If the activity is soil sampling, "appropriate" means soil sampling alone. If the activity is operating a field GC, "appropriate" means operating a
field GC not other field equipment.
-------
Worksheet II
Field Team Qualifications (Continued)
Field Activity
DP analytical
measurements
Field analytical
measurements
Geophysical surveys
Data Management/IT
Air Sampling (specify type)
Groundwater sampling
(monitoring system)
Proposed Field
Equipment
Proposed Individual
Name
Job Title
Years Experience in
Appropriate1 Field
Work
Years Experience
in Principal Area
of Expertise
DO
en
1 If the activity is soil sampling, "appropriate" means soil sampling alone. If the activity is operating a field GC, "appropriate" means operating a field GC not
other field equipment.
-------
Worksheet II
Field Team Qualifications (Continued)
Field Activity
Soil sampling (non-rig related)
Biota sampling
Sediment sampling
Surface water sampling
Estuarine sampling
Tidal sampling
Other
Proposed Field
Equipment
Proposed Individual
Name
Job Title
Years Experience
in Appropriate1
Field Work
Years
Experience in
Principal Area
of Expertise
CD
1 If the activity is soil sampling, "appropriate" means soil sampling alone. If the activity is operating a field GC, "appropriate" means operating a field GC not
other field equipment.
-------
Worksheet III
Technical Specialty Firm Qualifications
Technical Specialty Firm Field Activity1
Driller (specify type)
Direct Push (specify type)
Direct Push Chemical Analyzer Probe (specify type)
Soil Gas Analysis (specify type)
Air Sampling (specify type)
Mobile Laboratory (list proposed instrumentation)
Portable Field Instrumentation (specify type)
Geophysics (specify instrument)
Other
Firm's Experience in
Designated Work2
Principal Operator's
Experience3 with
Equipment
1 This checklist provides an estimate of the experience being placed in the field by the specialty firm. For
example, if the driller is providing three hollow-stem auger rigs, then three should be listed below
"Driller."
2 Provides experience of the firm in the given area or equipment type—for example, the years the firm
has been performing soil gas surveys.
3 Operator experience with the instrument in question. For example, a field GC (specify brand) is
proposed and the operator has been using this type of instrument for 4 years.
B-7
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-------
Appendix C
Summary of Detection Limits for Selected
Field-Based Analytical Methods
-------
-------
Appendix C
Summary of Detection Limits for Selected
Field-Based Analytical Methods
This appendix is designed to provide the reader with a list of estimated
detection limits that can be attained with some commonly used field-based
analytical methods. It is not intended to be comprehensive because the total
number of field-based analytical methods is overwhelmingly large and it is not
intended to provide definitive detection limits because their performance is
extremely site specific. Rather, the tables provided below should be used as a
starting point in the search for analytical methods that are appropriate for your
site. As such, they should be used with numerous other sources of information,
including the advice of an experienced chemist. Readers can find additional
sources of information on the Internet as listed in Chapter IV, including the
dynamic field activities web page at http://www.epa. gov/superfund/programs/dfa
and the Field Analytic Technologies Encyclopedia at http://fate.clu-in.org. In
addition, the dynamic field activities web page provides detailed tables with
estimates of samples per day, interferences, and performance tips/limitations for
each of the methods listed in this appendix.
The information provided in these tables was assembled from SW-846;
Appendix A of 40 CFR 136 (Guidelines Establishing Test Procedures for the
Analysis of Pollutants); California Military Environmental Coordination Commit-
tee (CMECC): Field Analytical Measurement Technologies, Applications, and
Selection, Standard Methods for the Examination of Water and Wastewater;
Environmental Technology Verification (ETV) reports; and manufacturer docu-
mentation. Although manufacturer documentation should be examined critically,
for the purposes of this appendix, the information was acceptable because the data
are designed to be used as a starting point in the method selection process. When
multiple manufacturers of specific technologies had very similar equipment (e.g.,
conventional ion-specific electrodes, colorimetric analysis with spectrophoto-
meter), detection limits were evaluated for "reasonableness" before a value was
selected. For example, if one manufacturer had a detection limit well below the
others, the lowest detection limit was not used in the table.
The field-based analytical methods included in this appendix have been
limited to organic methods using three instruments:
GC/MS;
GC; and
• Immunoassay.
C-1
-------
And inorganic methods using five instruments:
• Immunoassay for mercury;
XRF;
• Colorimetric with spectrophotometer;
• Conventional ion-specific electrode; and
• In situ ion-specific electrode.
The number of field-based analytical methods that are potentially useful
for contaminated activities are too numerous to evaluate completely in this
document, and new instruments are continually being developed. In addition to
the field-based analytical methods summarized here, project planners may also be
interested in considering detector tubes, fiber optic chemical sensors, turbidi-
metric test kits, infrared detectors, open path techniques (e.g. fourier transform
infrared spectroscopy) and the numerous probes and sensors that can be attached
to DPT rods (e.g., laser-induced fluorescence).
C-2
-------
o
Inorganic Field-Based Analytical Method Detection Limits
Media
Aluminum
Ammonium
Antimony
Arsenic
Barium
Boron
Bromide
Bromine
Cadmium
Calcium
Carbonate
Chloride
Chlorine
Chlorine Dioxide
Chromium
Colorimetric
Spectrophotometer
mg/L
Water
0.03
No detection limit
provided, <100.
Precision of ± 1.0
0.02
0.03
0.001
0.3
0.01
0.03
Conventional
Ion-Specific
Electrode
mg/L
Water
0.02
10
0.4
0.2
0.02
1.8
0.010
In Situ Ion-
Specific
Electrode
mg/L
Water
0.09
1.4
0.4
0.1
0.02
0.008
1
X-ray
Fluorescence1
mg/L
Water
0.5
1.3
0.04
0.08
0.24
0.03
0.03
X-ray
Fluroescence2
mg/kg
Soil
40
40
20
100
70
150
Immunoassay3
mg/kg
Soil
-------
o
Inorganic Field-Based Analytical Method Detection Limits (Continued)
Media
Chromium, hexavalent
Cobalt
Copper
Cyanide
Fluoride
Iodide
Iron
Lead
Manganese
Mercury
Molybdenum
Nickel
Colorimetric
Spectrophotometer
mg/L
Water
0.01
0.03
0.02
No detection limit
provide, <0.2.
Precision of ±0.0043
0.02
0.03
0.003
0.03
0.03
0.02
Conventional
Ion-Specific
Electrode
mg/L
Water
0.3
0.03
0.01
0.02
1.0
In Situ Ion-
Specific
Electrode
mg/L
Water
0.008
0.03
0.20
0.005
0.20
0.2
X-ray
Fluorescence1
mg/L
Water
0.03
0.03
0.03
0.16
0.03
0.04
0.03
X-ray
Fluroescence2
mg/kg
Soil
60
50
60
20
70
30
10
50
Immunoassay3
mg/kg
Soil
0.5
-------
o
Inorganic Field-Based Analytical Detection Limits (Continued)
Media
Nitrogen (Nitrate)
Nitrogen (Nitrite)
Perchlorate
Phosphorus, Phosphate
Potassium
Rubidium
Selenium
Silver
Sodium
Strontium
Sulfate
Sulfide
Colorimetric
Spectrophotometer
mg/L
Water
No detection limit
provided, <0.40.
Precision of ±0.01
0.001
0.01
No detection limit
provided, O.6.
Precision of ±0.0067
7
Conventional
Ion-Specific
Electrode
mg/L
Water
0.08
0.02
0.7
0.04
0.01
0.001
0.003
In Situ Ion-
Specific
Electrode
mg/L
Water
0.40
0.18
0.20
0.04
0.01
0.001
X-ray
Fluorescence1
mg/L
Water
0.25
0.07
0.07
0.12
0.6
0.18
0.04
X-ray
Fluroescence2
mg/kg
Soil
200
10
40
70
10
Immunoassay3
mg/kg
Soil
-------
Inorganic Field-Based Analytical Method Detection Limits (Continued)
Media
Thallium
Thorium
Tin
Titanium
Vanadium
Zinc
Zirconium
Colorimetric
Spectrophotometer
mg/L
Water
Conventional
Ion-Specific
Electrode
mg/L
Water
In Situ Ion-
Specific
Electrode
mg/L
Water
X-ray
Fluorescence1
mg/L
Water
0.06
0.3
0.04
0.04
0.03
0.04
X-ray
Fluroescence2
mg/kg
Soil
20
10
60
50
50
50
10
Immunoassay3
mg/kg
Soil
o
'XRF water numbers are from Kevexspectrace (water quality 200 mg/L TDS) drying must be done in a clean area. TDS does effect sensitivity of measurement.
2EPA Method 6200 Interference free detection limits.
3T
3EPA Method 4500 Mercury by Immunoassay.
-------
o
Organic Field-Based Analytical Method Detection Limits
Analyte
Alachlor
Aldicarb
Benomyl/Carbendazim
Captan
Carbaryl
Carbofuran
Chlordane (Method 404 1 )
Chlorothalonil
Chlorpyrifos
Cyanazine
Immunoassay
Detection Limit
Water
(|jg/L or ppb)
0.05 ppb
RaPID Assay®:
0.25 ppb
Enviro-Gard®:
2.0 ppb
0.1-0.2 ppb
10 ppb
0.25 ppb
0.056 ppb
0.070 ppb
Enviro-Gard®:
0.050 ppb
RaPID Assay®:
0.100 ppb
0.14 ppb
Soil
(pg/kg or ppb)
6.4 jig/kg
Gas Chromatograph1
Detection Limit
Water
(M9/L)
NIC
NIC
NIC
NIC
NIC
NIC
NIC
0.073
NIC
Soil
(M9/kg)
1.53
Gas Chromatograph/Mass
Spectrometer
Detection Limit
Water
( M9/L)
NIC
NIC
NIC
502
102
102
NIC
NIC
NIC
Soil
(M9/kg)
1.72
-------
o
Organic Field-Based Analytical Method Detection Limits (Continued)
Analyte
Cyclodienes
Diazinon
Dichloro-diphenyl-
trichloroethane (DDT)
2, 4-Dichlorophenoxy-acetic
Acid (2,4-D)
2, 4-Dichlorophenoxy-acetic
Acid (2,4-D)
Endosulfan
Endothall
Fluridone
Hexahydro-1 ,3,5-trinitro-
l,3,5-triazine(RDX)
Immunoassay
Detection Limit
Water
(Mg/L or ppb)
Enviro-Gard®:0.6 ppb as
Endosulfan. If Endosulfan
is not the cyclodiene of
interest, check the kit
directions to see what the
detection limit for the target
compound of interest is.
RaPID Assay®: 0.6 ppb
0.022 ppb
2^g/L
0.08 ppb
3.0 ppb
0.02 ppb
4^g/L
Soil
(|jg/kg or ppb)
44 ppb
(Method 4042)
160 ppb
(Method 40 15)
800 ng/Kg5
(Method 4051)
Gas Chromatograph1
Detection Limit
Water
(M9/L)
NIC
0.23
0.23
0.9-1. 33
NIC
NIC
NIC
Soil
(ng/kg)
0.63
O.ll3
NIC
Gas Chromatograph/Mass
Spectrometer
Detection Limit
Water
( M9/L)
NIC
NIC
NIC
NIC
NIC
NIC
NIC
Soil
(Mg/kg)
330 4
NIC
NIC
-------
o
CD
Organic Field-Based Analytical Method Detection Limits (Continued)
Analyte
Isoproturon
Lindane
Metolachlor
Paraquat
Parathion
Pentachlorophenol
Pentachlorophenol
Petroleum Hydrocarbons
Picloram
Polyaromatic Hydrocarbons
(PAHs)
Immunoassay
Detection Limit
Water
(|jg/L or ppb)
0.02 ppb
Enviro-Gard®: 0.07 ppb
RaPID Assay®: 0.05 ppb
0.02 ppb
0.03 ppb
5 |ig/L (kit specific)
0.87 ppb
Soil
(|jg/Kg or ppb)
400 ppb
500 ng/kg
(kit specific)
5000 ppb
200 to 1000 ppb
depending upon the
kit.
Gas Chromatograph1
Detection Limit
Water
(M9/L)
NIC
NIC
NIC
0.063
0.0763
NIC
Soil
(M9/Kg)
1.43
0.163
NIC
No published data.
Gas Chromatograph/Mass
Spectrometer
Detection Limit
Water
( M9/L)
NIC
NIC
NIC
102
502
NIC
Soil
(M9/Kg)
NIC
33002
NIC
6602
-------
o
o
Organic Field-Based Analytical Method Detection Limits (Continued)
Analyte
Polychlorinated Biphenyls
(PCBs)
Semivolatile Organics
Silvex
Simazine
Spinosad
Thiabendazole
Total Benzene, Toluene,
Ethylbenzene, and Xylenes
(BTEX)
Toxaphene
Immunoassay
Detection Limit
Water
(|jg/L or ppb)
5000 ng/L but has different
detection levels for each
Aroclor. Check test kit for
specific number.
0.03 ppb
0.02 ng/L spinosyn A.
0.2 ppb
100 ppb
Soil
(|jg/Kg or ppb)
250-1000 ppb
depending on test
kit.
Enviro-gard®:
20 ppb
RaPID Assay®:
14 ppb
500 ng/kg
Gas Chromatograph1
Detection Limit
Water
(M9/L)
No published
data.
0.04-23002
NTC
NTC
NTC
0.009-0.023
Soil
(M9/Kg)
57-703
0.02-702
0.283
No published
data.
Gas Chromatograph/Mass
Spectrometer
Detection Limit
Water
( M9/L)
No published data.
10-2002
NTC
NTC
NTC
0.04-0.082
Soil
(M9/Kg)
33-6V4
6602
NTC
1704
-------
o
Organic Field-Based Analytical Method Detection Limits (Continued)
Analyte
Triasulfuron
Triazine Herbicides
Trichloropyridinol
Trinitrotoluene (TNT)
Urea Herbicides
Volatile Organics
Immunoassay
Detection Limit
Water
(|jg/L or ppb)
0.04 ppb
0.03 ug/L
0.25 ug/L
5 ug/L
See interferents.
Soil
(|jg/Kg or ppb)
500 to 700 ppb
depending upon the
kit.
Gas Chromatograph1
Detection Limit
Water
(M9/L)
NTC
NTC
NTC
No published
data.
NTC
0.04-30 ug/L2
Soil
(M9/Kg)
No published
data.
0.04-30 ug/kg2
Gas Chromatograph/Mass
Spectrometer
Detection Limit
Water
( M9/L)
NTC
NTC
NTC
NTC
NTC
5 ug/L2
Soil
(M9/Kg)
NTC
5 ug/kg2
1 Values are for most effective detector.
2 SW-846 estimated quantitation limit. Detection limit may be lower.
3 SW-846 method detection limit.
4 Contract Laboratory Program CRQL.
5 EnSys Test Kit.
NTC: Non-target compound. The detection limits and estimated quantitation limits for the GC and GC/MS methods are taken from published EPA methods.
These methods provide information on program specific target compounds. Non-target compounds may be analyzed by GC or GC/MS but detection limits, and the
ability to analyze these compounds, should be verfied by a project manager prior to beginning field work.
-------
-------
Glossary
-------
-------
GlossaryD
accuracy: The degree of agreement between an observed value and an accepted
reference value. Accuracy includes a combination of random error (precision) and
systematic error (bias) components that are due to sampling and analytical opera-
tions; a data quality indicator. Examples of QC measures for accuracy include PE
samples, matrix spikes, laboratory control samples (LCSs), and equipment blanks.
action level: The numerical value that causes the decision maker to take a
response action. It may be a regulatory threshold standard, such as a Maximum
Contaminant Level for drinking water; a risk-based concentration level; an
analytical technology limitation; or a reference-based standard. Note: the action
level generally is specified during the planning phase of a data collection activity;.
It is usually not calculated from the sampling data.
air sparging: A cleanup technique where air is forced into wells with screens set
below the water table. As the air moves into the formation it promotes volatili-
zation of dissolved contaminants and encourages biodegradation by enriching the
groundwater as well as the overlying vadose zone with oxygen. This method is
usually employed in conjunction with a vadose zone soil gas capture system.
Aroclor: A trade name for mixtures of polychlorinated biphenyls( PCBs) of
various chlorine content sold for many years in the United States by Monsanto
Company. Although Aroclors are no longer marketed, the PCBs remain in the
environment and are sometimes found as residues in foods, especially fish.
Base Realignment and Closure Program (BRAC): The federal program that
identifies and closes surplus military bases.
benzo(a)pyrene (BAP): A carcinogenic polyaromatic hydrocarbon consisting of
five fused benzene rings having the general chemical formula C20H12.
bias: The systematic or persistent distortion of a measurement process, which
causes errors in one direction (i.e., the expected sample measurement is different
from the sample's true value).
blank: A sample subjected to the usual analytical or measurement process to
establish a zero baseline or background value. A sample that is intended to
contain none of the analytes of interest. A blank is used to detect contamination
during sample handling preparation and/or analysis.
BRAC Cleanup Team: The group responsible for remediation activities at a
military base that is within the Base Realignment and Closure Program (BRAC).
G-1
-------
The team usually consists of representatives from the Department of Defense,
their contractors, as well as State and Federal regulators along with their experts.
calibration: Comparison of a measurement standard, instrument, or item with a
standard or instrument of higher accuracy to detect and quantify inaccuracies and
to report or eliminate those inaccuracies by adjustments.
calibration standard: A substance or reference material used to calibrate an
instrument.
chain-of-custody: An unbroken trail of accountability that ensures the physical
security of samples, data, and records.
chlordane: A chlorinated insecticide consisting of isomers of the general formula
column: The tubing that provides support for the stationary phase (i.e., material
that promotes separation of the target analytes present in the sample) in gas
chromatography or high performance liquid chromatography.
community involvement plan: A plan described in 40 CFR 300.430(c) of the
National Contingency Plan that lays out how the lead agency informs and involves
the surrounding community in the remedial investigation/feasibility study, remedy
selection, remedial design, and remedial action. This plan may also be referred to
as the "community relations plan."
Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA): A federal law enacted in 1980 and nicknamed "Superfund" that
provides Federal cleanup authority. It also created a trust fund, known as the
Superfund, to assist with the cleanup of inactive and abandoned waste sites.
conceptual site model: A model of how chemicals were released at a site, their
transport mechanisms, and exposure routes for both ecological and human
receptors. It should be constructed during the systematic planning process and
updated throughout the life of a project as new information becomes available.
confirmation data: Those data that are used to verify a decision (risk exists,
cleanup is complete) or to show that a sampling and analysis program is
performing as expected.
constituents of concern: The matrix-specific list of chemical compounds and
analytes determined pertinent to a specific site or project. Sometimes used
interchangeably with "contaminants of concern."
contaminants of concern: See "constituents of concern ."
G-2
-------
Contract Laboratory Program (CLP): A national network of EPA personnel,
commercial laboratories, and support contractors whose fundamental mission is to
provide data of known and documented quality in support of the EPA's Superfund
efforts by setting standards for analysis of samples by contracted laboratories.
Contract Laboratory Program method: A method of analysis specified for
laboratories participating in the EPA Contract Laboratory Program.
Corrective Action: An EPA program to address the investigation and remedi-
ation of contamination at or from hazardous waste treatment, storage, or disposal.
Corrective Action Plan: OSWER Directive 9902.3-2A, May 1994. Provides an
overall program implementation framework; and model scopes of work for site
characterizations, interim actions, evaluations of remedial alternatives, and
remedy implementation.
Corrective Measures Implementation: Components of corrective action in
which the owner and operator performs detailed design, construction, operation,
maintenance, and monitoring of a chosen cleanup remedy.
Corrective Measures Study: An evaluation, if deemed necessary by the over-
seeing regulatory program, in which the owner/operator identifies and evaluates
remediation alternatives at a given contaminated site.
data management plan: One of the series of documents that make up the quality
assurance project plan (QAPP). It details the procedures the project will follow in
collecting, transcribing, storing, and displaying data.
data quality assessment (DQA): The scientific and statistical evaluation of data
to determine if data obtained from environmental operations are of the right type,
quality, and quantity to support their intended use. The five steps of the data
quality assessment process include (1) reviewing the DQOs and sampling design,
(2) conducting a preliminary data review, (3) selecting the statistical test, (4)
verifying the assumptions of the statistical test, and (5) drawing conclusions from
the data.
data quality indicators: The quantitative statistics and qualitative descriptors
that are used to interpret the degree of acceptability or utility of data to the user.
The principal data quality indicators are precision, accuracy, representativeness,
comparability, completeness, and sensitivity. Also referred to as data quality
attributes.
data quality objectives (DQOs): Qualitative and quantitative statements derived
from the DQO process that clarify a study's objectives, define the appropriate type
of data, and specify tolerable levels of potential decision errors. DQOs will be
G-3
-------
used as the basis for establishing the quality and quantity of data needed to
support decisions.
data quality objective (DQO) process: A systematic strategic planning tool
based on the scientific method that identifies and defines the type, quality, and
quantity of data needed to satisfy a specified use. DQOs are the qualitative and
quantitative outputs from the DQO process. For additional information about the
DQO process, please refer to Guidance for the Data Quality Objectives Process
(G-4) at http://www.epa.gov/quality/qa_docs.html.
data review: The process of examining and/or evaluating data to varying levels
of detail and specificity by a variety of personnel who have different responsibili-
ties within the data management process. It includes, but is not limited to, data
verification, data validation, and data usability assessment.
data usability assessment: Evaluation of data based upon the results of data
validation and verification for the decisions being made. In the usability step, one
should assess whether the process execution and resulting data meets quality
objectives based on criteria established in the QAPP.
data validation: The process of determining the reliability of reported results by
a rigorous technical assessment that encompasses a review of the documentation
related to sample collection, preparation, analysis, quality control, data reduction,
and reporting.
data verification: The process of reviewing data to ensure that data are collected
and analyzed by project-prescribed methods, transcribed accurately from an
analytical logbook into an electronic database when necessary, and recorded
consistently between laboratory hard and electronic copy.
decision memoranda: A paper issued by a technical team leader to the lead
agency's project manager at any critical decision point in a field activity. The
paper asks for concurrence that a project goal for that decision point has been met
and either work can be stopped or moved to other objectives.
definitive data: Analytical data of known quality, concentration, and level of
uncertainty. The levels of quality and uncertainty of the analytical data are
consistent with the requirements for the decision to be made. Suitable for final
decision-making.
dense nonaqueous phase liquid (DNAPL): A hydrophobic liquid with a
specific gravity greater than one.
detection limit: A measure of the capability of an analytical method to disting-
uish samples that do not contain a specific analyte from samples that contain low
G-4
-------
concentrations of the analyte; the lowest concentration or amount of the target
analyte that can be determined to be different from zero by a single measurement
at a stated level of probability. Detection limits are analyte- and matrix-specific
and may be instrument- and laboratory-dependent.
dichloro-diphenyl-trichloroethane (DDT): A pesticide which was widely used
in the United States before it was banned in 1972 due to its toxicity, environ-
mental persistence, and tendency to bioaccumulate in the food-chain.
direct push (DP): A broad family of tools used for performing subsurface
investigations by driving, pushing, and/or vibrating small-diameter hollow steel
rods into the ground. Various probes, tips, or instruments can be attached to rods
in order to collect soil, soil gas, or groundwater samples; install monitoring
points; collect continuous logs on a variety of subsurface data; as well as perform
numerous other tasks for the investigation and remediation of contaminated sites.
Also known as "direct drive," "drive point," or "push" technology
duplicate analysis: The analysis of two samples that are expected to yield
closely similar results by measuring the same variable (or set of variables) in each
of them. It can be used to assess both laboratory and total measurement precision.
Also refer to "laboratory duplicate" and "field duplicate" for additional
information.
dynamic field activities: Contaminated site activities that combine on-site data
generation with on-site decision making.
dynamic range: The concentration range that an instrument can accurately
measure before a dilution is needed.
dynamic work plan: A work plan that is designed to allow decision making in
the field based on analytical data that are generated as they are needed.
electron capture detector (ECD): An analytical measuring device that uses a
stream of nitrogen to carry chemicals past a p-emitting material where they are
ionized prior to passing between two electrodes which have a voltage differential
of several hundred volts. As the ionized chemicals pass between the electrodes,
the voltage differential drops, and the drop can be related to their concentration.
An ECD is generally employed to detect halogenated chemicals, such as
chlorinated pesticides.
ex situ thermal desorption: A cleanup technique in which contaminated
materials (usually soils) are dug up and run through a unit that applies sufficient
heat to cause the contaminants of concern to volatilize where upon they are either
captured or destroyed.
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Environmental Response Team (ERT): An EPA program with staff stationed
in Edison, NJ, and Cincinnati, OH, that provides expertise in various problems
associated with response actions. The group can offer call-in advice for local
response actions and in the event of a major release can be mobilized to the scene.
feasibility study (FS): A study undertaken by the lead agency to develop and
evaluate options for remedial action. The FS emphasizes data analysis and is
generally performed concurrently and in an interactive fashion with the RI, using
data gathered during the RI. The data are used to define the objectives of the
response action, to develop remedial action alternatives, and to undertake an
initial screening and detailed analysis of the alternatives. The term also refers to
the report that describes the results of the study.
Field Analytical Support Program (FASP): A program operated by some of the
EPA Regional offices through a contract in which mobile laboratories can be
detailed to sites for on-site analyses.
field blank: A blank used to provide information about contaminants that may be
introduced during sample collection, storage, and transport. A clean sample
exposed to sampling conditions, transported to the laboratory, and treated as an
environmental sample.
field boring log: A record of the lithology of a borehole.
field duplicate, co-located: Two or more separate portions collected from side-
by-side locations at the same point in time and space so as to be considered
identical. These separate samples are said to represent the same population and
are carried through all steps of the sampling and analytical procedures in an
identical manner. These samples are used to assess precision of the total method,
including sampling, analysis, and site heterogeneity. This definition does not
include a subsample field duplicate, which is one sample that is homogenized and
then split into two or more portions.
field duplicate, subsample: Similar to a split sample except the same laboratory
analyzes both samples. The sample is homogenized before being divided into two
or more portions. These samples do not assess site heterogeneity, only specific
sample point heterogeneity.
Field Operations and Records Management System II Lite (FORMS II Lite):
EPA software that automates many of the manual procedures associated with
documenting sample collection activities, including the completion of sample
tags, sample labels, and chain-of-custody records.
field sampling plan: A component of a sampling and analysis plan that details
how and where samples will be collected and handled. The plan generally
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includes standard operating procedures for each sampling method and
decontamination procedures.
field team: The environmental professionals responsible for implementing day-
to-day field activities and decisions at the site.
field-based analytical methods (FAMs): A broad category of analytical
methods that can be applied at the site of sample collection activities. They
include methods that can be used outdoors, as well as methods that require the
controlled environments of a mobile laboratory.
flame ionization detector (FID): An organic compound detector that uses a
hydrogen flame to ionize organic vapors and then measures the electrical current
generated by the free ions which is related to the concentration of the compounds
present in the sample. It can be used as a stand alone detector to provide a rough
indication of the concentration of all the compounds present in a sample or in
conjunction with gas chromatography in order to provide the concentration of
individual compounds in a sample.
Freon 113™: A trademark name for l,l,2-trichloro-l,2,2-trifluoroethane which
has commonly been used as a refrigerant and a degreaser.
full data validation: A rigorous technical evaluation of all aspects of either field
or fixed laboratory analysis, involving the examination of raw data as well as
quality control summary data.
gas chromatograph (GC): An instrument used to separate analytes on a
stationary phase within a chromatographic column.
gas chromatography/mass spectrometry (GC/MS): An analytical technique
that uses a gas chromatograph to separate constituents of concern and a mass
spectrometer to identify and quantitate them.
global positioning system (GPS): A system that uses satellites to locate a
position on the earth in terms of latitude and longitude coordinates by means of
triangulation.
granular activated carbon (GAC): A material produced by heating carbonace-
ous materials, such as wood or coconut shells, in the absence of air. The result is
an extremely porous structure that can be used to filter (by absorption and
adsorption) contaminants from water or air.
hazardous waste: Any waste material that satisfies the definition of hazardous
waste given in 40 CFR 261, "Identification and Listing of Hazardous Waste."
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Hazard Ranking System (HRS): A numerically based screening system that
uses information from initial investigations to assess the relative potential of sites
to pose a threat to human health or the environment. As a matter of Agency
policy, those sites that score 28.50 or greater with the HRS are eligible for
inclusion on the NPL.
health and safety plan: A site-specific document that identifies the potential
hazards that may be encountered at the site and specifically describes what shall
be done to mitigate or eliminate them during field activities.
hollow stem auger: A large diameter pipe with flights welded to the outside that
convey soil to the surface as the pipe is advanced by a drill rig. The lead auger is
usually equipped with a cutter head and pilot bit. In situ soil samples can be taken
by removing the cutter head and replacing it with a sampling tube (e.g., split
spoon, Shelby).
immunoassay: An analytical method for detecting a substance by using anti-
bodies (i.e., proteins developed by living organisms to identify foreign objects as
part of their immune systems) to identify and measure target constituents (i.e.,
antigens) through the use of an antibody-antigen reaction. In order to facilitate
interpretation of the analysis, immunoassay test kits utilize special reagents, called
enzyme conjugates, to allow for color development that can then be associated
with the target analyte concentration.
inductively coupled plasma (ICP) analysis: A technique for the simultaneous
or sequential multi-element determination of elements in solution. The basis of
the method is the measurement of atomic emission by an optical spectroscopic
technique. Characteristic atomic line emission spectra are produced by excitation
of the sample in a radio frequency inductively induced plasma.
interim measure: Under RCRA subtitle C corrective action, a short-term action
to control ongoing risks while site characterization is underway or before a final
remedy is selected.
infrared (IR) spectroscopy: An analytical technique that uses wavelength
absorption in the infrared range for assessing the characteristics of a compound.
A sample's molecular structures are revealed through their characteristic
frequency-dependent absorption bands.
inorganic chemical: A compound that is not a hydrocarbon or derived from a
hydrocarbon through other than direct thermal oxidation processes.
Installation Restoration Program (IRP): A Department of Defense program
that addresses environmental contamination at active and closing military
facilities.
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investigation derived waste (IDW): Wastes that are produced during a site
assessment or investigation that are handled as hazardous materials until subse-
quent evaluation identifies them as hazardous or nonhazardous. Examples would
be soil cuttings from drilling activities in contaminated soil areas and contami-
nated groundwater from well development and purging activities.
ion-specific electrode: A cyclindrical tube usually made of glass or plastic with
an ion selective membrane at one end that comes into contact with the solution to
be measured and a wire on the opposite side of the membrane that leads to a
millivolt measuring device. The difference in potentials between a reference of
known concentration and the ion-specific electrode allows for a calculation of the
ion concentration. A variation of this design uses a solid state sensor that is
specific to the target analyte and does not require the use of a reference electrode.
lead organization: An entity responsible for all phases of the data collection
operation.
mass spectrometry (MS): An analytical technique that ionizes and fragments the
target analytes present in a sample. An electric or magnetic field is then applied,
and the trajectories of the particles are measured to determine their mass to charge
ratios, which are subsequently used to identify and quantitate the target analytes in
the sample.
matrix spike: A sample prepared by adding a known concentration of a target
analyte to an aliquot of a specific homogenized environmental sample for which
an independent estimate of the target analyte concentration is available. The
matrix spike is accompanied by an independent analysis of the unspiked aliquot of
the environmental sample. Spiked samples are used to determine the effect of the
matrix on a method's recovery efficiency.
matrix spike duplicate: A homogeneous sample used to determine the precision
of the intralaboratory analytical process for specific analytes (organics only) in a
sample matrix. Sample is prepared simultaneously as a split with the matrix spike
sample, as each is spiked with identical, know concentrations of targeted
analyte(s).
measurement error: Uncertainty associated with data caused by random and
systematic errors being introduced into the measurement process by such activities
as sample handling, sample preparation, sample analysis, and data reduction.
method: A body of procedures and techniques for performing an activity (e.g.,
sampling, modeling, chemical analysis, quantification) systematically presented in
the order in which they are to be executed.
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method applicability study: A study undertaken before a formal field activity
begins to determine if the method will meet project measurement quality
objectives. It is a field test of the method before mobilization.
method detection limit: The minimum concentration of a substance that can be
reported with 99% confidence that the analyte concentration is greater than zero.
method reporting limit (MRL) : The concentration (usually the quantitation
limit) below which any detected analytes will be reported as estimated quantities
and to which non-detects will be reported.
method selectivity: The ability of an analytical method to detect or quantify a
particular analyte when other chemically similar analytes are present.
method sensitivity: The ability of an analytical method to detect a change in
response to a particular analyte at a particular concentration.
mobilization: The activities leading up to and including the implementation of
field work at a site.
National Priorities List (NPL): An information and management tool of the
Superfund program. A specific site may be listed on the NPL after the Hazard
Ranking System (HRS) screening process has been completed and public
comments about the proposed site have been solicited and addressed.
Office of Solid Waste and Emergency Response (OSWER): An EPA office
that provides policy, guidance, and direction for the land disposal of hazardous
waste, underground storage tanks, solid waste management, encouragement of
innovative technologies, source reduction of wastes, and implementation of
CERCLA.
on-scene coordinator (OSC): The federal official (EPA or the U.S. Coast
Guard) who coordinates and directs federal responses under subpart D of the NCP
(for oil) or removal actions under subpart E of the NCP (hazardous substances).
operable unit (OU): A distinct portion of the overall site cleanup. Sites can be
divided into operable units based on the media to be addressed (e.g., groundwater
or soil), geographic area, or other measures.
operation and maintenance (O&M): The measures initiated after the remedy
has achieved the remedial action objectives and remediation goals in the Record
of Decision, and is determined to be operational and functional, except for
groundwater or surface-water restoration actions which enter O&M after the long-
term response action (LARA) period is completed. O&M measures are designed
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to ensure that the remedy remains protective to human health and the
environment.
organic chemical: A compound that is a hydrocarbon or is derived from a
hydrocarbon other than through thermal oxidation.
organic vapor analyzer (OVA): A device that provides an averaged concen-
tration of organic molecules in an air stream in units of parts per million. The
most common devices contain flame ionization detectors and are calibrated using
a mixture of gases of different atomic weights.
performance evaluation (PE) sample: A sample, the composition of which is
unknown to the laboratory or analyst, which is provided to that analyst or labora-
tory to assess capability to produce results within acceptable criteria. PE samples
can fall into three categories: (1) prequalification, conducted prior to a laboratory
beginning project work, to establish initial proficiency; (2) periodic (e.g., quar-
terly, monthly, or episodic) to establish ongoing laboratory proficiency; and (3)
batch-specific, which is conducted simultaneously with analysis of a sample
batch. Also called a proficiency testing sample.
photoionization detector (PID): A detector that uses an ultraviolet lamp to
ionize compounds in a carrier gas (usually ultrapure air or nitrogen) that are then
collected at positively charged electrodes where the change in current is measured.
It can be used as a stand alone detector to provide a rough indication of the
concentration of all the compounds present in a sample or in conjunction with gas
chromatography in order to provide the concentration of individual compounds in
a sample.
planning team: The group of technical experts that develops the planning
documents for a Dynamic Field Activity. It is generally comprised of individuals
who fill the roles of technical team leader, project hydrogeologist, project chemist,
quality assurance specialist, statistician, risk assessor, community relations expert,
health and safety expert, data management expert, information technology expert,
and depending upon the need, a geophysicist.
polyaromatic hydrocarbon (PAH): Aromatic hydrocarbons containing more
than one benzene ring. (Also called "polycyclic aromatic hydrocarbon.")
polychlorinated biphenyls (PCBs): A chemical family of over 200 congeners
derived from the progressive substitution of chlorine for hydrogen in the biphenyl
ring system.
potentially responsible party (PRP): An individual, business, or other entity
that is potentially liable for cleaning up a site. The four types of responsible
parties include a site's present owner(s) and operator(s), its previous owner(s) and
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operator(s) during the time when hazardous substances were released, as well as
those who arrange and transport for disposal.
precision: The degree to which a set of observations or measurements of the
same property, obtained under similar conditions, conform to themselves.
Precision is usually expressed as standard deviation, variance or range, in either
absolute or relative terms. Examples of QC measures for precision include field
duplicates, laboratory duplicates, analytical replicates, and internal standards.
preliminary remediation goal (PRG): Chemical concentration set by regulatory
agencies that defines a minimum, preliminary human health risk goal. Concentra-
tions of contaminants found above their respective PRGs at a site necessitate a full
characterization and a risk assessment.
pump and treat: A remediation technique in which contaminated groundwater is
pumped to a surface treatment unit. The treated water is either re-injected or
discharged to a local surface water or publically owned wastewater treatment
plant.
pumping test: A test that measures the transmissivity of an aquifer by pumping
water from one well and measuring drawdown in other wells placed at specified
distances and depths from the pumping well.
quality assurance (QA): An integrated system of management activities involv-
ing planning, implementation, assessment, reporting, and quality improvement to
ensure that a process, item, or service is of the type and quality needed and
expected by the client.
quality assurance audit: A documented activity performed to verify, by
examination and evaluation of objective evidence, that applicable elements of the
quality system are suitable and have been developed, documented, and effectively
implemented in accordance with specified requirements.
quality assurance project plan (QAPP): A formal document describing in
comprehensive detail the necessary quality assurance, quality control, and other
technical activities that must be implemented to ensure that the results of the work
performed will satisfy the stated performance criteria.
quality control (QC): The overall system of technical activities that measures
the attributes and performance of a process, item, or service against defined
standards to verify that they meet the stated requirements established by the
customer; operational techniques and activities that are used to fulfill require-
ments for quality. The system of activities and checks used to ensure that
measurement systems are maintained within prescribed limits, providing
protection against "out of control" conditions and ensuring the results are of
acceptable quality.
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quality control sample: One of any number of samples, such as a PE sample,
intended to demonstrate that a measurement system or activity is in control.
quality control sample validation: The review of the results from calibration
standards, blank samples, spiked samples, duplicate samples, and replicate
samples that are presented on the quality control summary forms in a data
package. Also known as "summary forms-only" validation.
quantitation limit: The minimum concentration of an analyte or category of
analytes in a specific matrix that can be identified and quantified above the
method detection limit and within specified limits of precision and bias during
routine analytical operating conditions.
readiness review: A systematic, documented review of the readiness for the
start-up or continued use of a facility, process, or activity. Readiness reviews are
typically conducted before proceeding beyond project milestones and prior to
initiation of a major phase of work.
Record of Decision (ROD): The document explaining EPA's remedy decision.
remedial action (RA): In general, the longer-term remedy at an NPL site
(CERCLA §101 has broad definition).
remedial design (RD): The engineering plan for cleaning up a site or portion of a
site. The design generally includes technical specifications for equipment, loading
rates, and other information necessary to construct and/or implement the remedial
action.
remedial investigation (RI): In general, a Superfund site study that involves
gathering data to determine the type, extent, and level of risk posed by contami-
nation at a site.
remedial project manager (RPM): EPA staff person responsible for overseeing
cleanup activities at NPL sites.
replicate samples: Multiple duplicate samples.
representativeness: A measure of the degree to which data accurately and
precisely represent a characteristic of a population, a parameter variation at a
sampling point, a process condition, or an environmental condition.
Resource Conservation and Recovery Act (RCRA): 42 U.S.C. s/s 6901 et seq
(1976) gives EPA the authority to control hazardous waste from the "cradle-to-
grave." This includes the generation, transportation, treatment, storage, and
disposal of hazardous waste. RCRA also set forth a framework for the manage-
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ment of non-hazardous wastes. Amended in 1984 to require phasing out of land
disposal of hazardous waste. Some other parts of this amendment include
increased enforcement authority for EPA, more stringent hazardous waste
management standards, and a comprehensive underground storage tank program.
RCRA Facility Assessment: Element of RCRA Corrective Action where regula-
tors and/or owners and operator compile existing information on environmental
conditions at a given facility, including information on actual and potential
releases.
RCRA Facility Investigation: Site characterization that should describe the
facility and releases of hazardous waste and constituents as necessary to enable
the identification and implementation remedies needed to achieve the desired
results.
required detection limit: Project specific method detection limit that is usually
specified as part of the measurement quality objectives.
Royal Demolition Explosive (RDX): Hexahydro-l,3,5-trinitro-l,3,5-triazine,
commonly referred to as RDX.
sample quantitation limit: Quantitation limit adjusted for dilutions, changes to
sample volume/sizes and extract/digestate volumes, percent solids and clean-up
procedures.
sampling and analysis plan (SAP): The overarching quality assurance plan that
normally includes a field sampling plan and a quality assurance project plan.
screening data: Analytical data of know quality, concentration, and level of
uncertainty. The levels of quality and uncertainty of the analytical data are
consistent with the requirements for the decision to be made. Screening data are
of sufficient quality to support an intermediate or preliminary decision but must
eventually be supported by definitive data before a project is complete.
semi-volatile organic compound (SVOC): An organic compound that volatili-
zes slowly at 20° C and 1 atm pressure.
sensitivity: The capability of a test method or instrument to discriminate between
measurement responses representing different levels (e.g., concentrations) of a
variable of interest. Examples of QC measures for determining the sensitivity
include laboratory-fortified blanks, a method detection limit study, and initial
calibration low standards at the quantitation limit.
site assessment: Generally, a screening-level environmental evaluation of an area
(e.g., site, property) to determine where an environmental cleanup action may be
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required. Within the Superfund program, site assessment involves data collection
and analysis to determine which sites may need cleanup under EPA's removal
(short-term) or remedial (long-term) cleanup programs. Examples of site
assessment activities include preliminary assessments and site inspections.
site inspection (SI): The second stage of the EPA process for screening a
contaminated site to determine if it warrants inclusion on the National Priorities
List. The site inspection normally involves collection and analysis of a limited
number of soil and water samples.
soil vapor extraction: A cleanup technique in which extraction wells (vertical or
horizontal) are placed in the unsaturated zone of a contaminated area and a
vacuum applied to collect volatilized contaminants and move them to an above-
ground treatment system.
Solid Waste Management Unit: For purposes of RCRA corrective action, any
discernible unit at which solid wastes have been placed at any time, irrespective of
whether the unit was intended for the management of solid or hazardous wastes.
Such units include any area of a facility at which solid wastes have been routinely
and systematically released.
speciality technical firm: A vendor that provides specific technical expertise
such as geophysical surveys, soil gas monitoring, and on-site laboratory services.
They generally do not perform services outside of their core area of expertise.
spectrophotometer: An instrument used to identify and quantitate chemicals
based on their absorption of characteristic spectral wavelengths.
spike: A substance that is added to an environmental sample to increase the
concentration of target analytes by known amounts; used to assess measurement
accuracy (spike recovery). Spike duplicates are used to assess measurement
precision.
split samples: Two or more representative portions taken from a sample in the
field or laboratory, analyzed by at least two different laboratories. Prior to split-
ting, a sample is mixed (except volatiles) to minimize sample heterogeneity.
These are quality control samples used to assess precision, variability, and data
comparability between different laboratories. (Should be used when accompanied
by a PE sample.)
staged field activity: A field approach consisting of a series of mobilizations
with each subsequent mobilization being based on an evaluation of data collected
during the previous mobilization.
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standard operating procedure (SOP): A written document that details the
method for an operation, analysis, or action with thoroughly prescribed techniques
and steps and that is officially approved as the method for performing certain
routine or repetitive tasks.
statement of work: The specifications or other description that describes the
general scope, nature, complexity, and purpose of the supplies or services the
Government requires in a manner that will enable the contractor to develop a
technical plan or proposal, schedule, and a cost estimate.
SW-846: An EPA publication entitled Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods and developed by the Office of Solid Waste (OSW).
It is OSW's official compendium of analytical and sampling methods that have
been evaluated and approved for use in complying with the RCRA regulations.
SW-846 functions primarily as a guidance document setting forth acceptable,
although not required, methods for the regulated and regulatory communities to
use in responding to RCRA related sampling and analysis requirements. It has
become widely adopted and used throughout the hazardous waste site remediation
community.
systematic planning process: A planning approach for environmental data
operations that is based upon two primary elements: (1) the scientific method and
(2) a common sense, graded approach to ensure that the level of detail in planning
is commensurate with the importance and intended use of the work and the
available resources.
technical team leader: The experienced individual who is responsible for the
overall development of work plans, execution of field activities, data evaluation,
and final deliverables. The technical team leader must be a cross-trained,
experienced individual who can quickly integrate information from multiple
disciplines to guide the investigation activities. This individual has the final
decision-making responsibilities in the field and is responsible for communicating
those decisions and/or recommendations to the Agency. Many times OSCs
perform the role of technical team leader for the Agency during removal actions.
total recoverable petroleum hydrocarbons (TRPH): The concentration
measured by a method that uses an extractant chemical to selectively dissolve
hydrocarbons from a media for measurement. As indicated by its name, the
process may not remove all of the hydrocarbons from the target media.
trinitrotoluene (TNT): An explosive that consists of a benzene ring with three
nitrogens and a methyl group.
validation - sampling and analysis validation: Confirmation by examination
and provision of objective evidence that the particular requirements for a specific
intended use are fulfilled. Data validation is a sampling and analytical process
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evaluation that includes evaluating method, procedural, or contractual compli-
ance, and extends to criteria based upon the quality objectives developed in the
project QAPP. The purpose of data validation is to assess the performance
associated with the sampling and analysis to determine the quality of specified
data. [Compliance with method, procedural, and contractual requirements.
Comparison to project quality criteria from the QAPP.]
verification - sampling and analysis verification: Confirmation by examina-
tion and provision of objective evidence that the specified requirements (sampling
and analytical) have been completed. [Completeness check.]
volatile organic compound (VOC): Any hydrocarbon-based chemical with a
vapor pressure equal to or greater than 0.1 mm Hg or with a boiling point below
200° C.
work plan: A document that explains in general terms the approach that will be
used for a field activity.
x-ray fluorescence: An analytical method that depends on the emission of
characteristic x-ray line spectra when an unknown substance is exposed to x-rays
for identification and quantitation.
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