Using the Triad Approach to
  Streamline Brownfields Site
  Assessment and Cleanup
        Planning
                                 trategies
               Uncertainty
              Management
 Reuse Goal

  Decisions

    Data

Tools/Strategies
               Measurement
               Technologies
Brownfields Technology Primer Series

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                                                    June 2003
Using the Triad Approach to Streamline Brownfields
            Site Assessment and Cleanup -
        Brownfields Technology Primer Series
                  U.S. Environmental Protection Agency
               Office of Solid Waste and Emergency Response
                 Brownfields Technology Support Center
                      Washington, DC 20460

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                                NOTICE AND DISCLAIMER

This primer was prepared by the United States Environmental Protection Agency's (EPA) Office of Solid
Waste and Emergency Response under EPA Contract 68-W-02-034. The information in this primer is not
intended to revise or update EPA policy or guidance on how to investigate or cleanup Brownfields or
other revitalization sites.  Mention of trade names or commercial products does not constitute
endorsement or recommendation for use.

This document can be obtained from EPA's Brownfields Technology Support Center at
http://www. brownfieldstsc. org. A limited number of hard copies of this document is available free of
charge by mail from EPA's National Service Center for Environmental Publications at the following
address (please allow 4-6 weeks for delivery):

       U.S. EPA/National Service Center for Environmental Publications
       P.O. Box 42419
       Cincinnati,  OH 45242
       Phone:  (513) 489-8190 or (800) 490-9198
       Fax: (513)489-8695

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                Using the Triad Approach to Streamline Brownfields Site Assessment and Cleanup
                              TABLE OF CONTENTS

Section

1.0    INTRODUCTION 	
      1.1    PURPOSE 	 1
      1.2    BACKGROUND 	 2
      1.3    ORGANIZATION 	 3

2.0    THE TRIAD APPROACH 	 4

      2.1    SYSTEMATIC PROJECT PLANNING 	 5
      2.2    DYNAMIC WORK PLAN STRATEGIES 	 18
      2.3    REAL-TIME MEASUREMENT TECHNOLOGIES	 20

3.0    PROJECT MANAGEMENT AND PROCUREMENT CONSIDERATIONS 	 23

      3.1    PROJECT MANAGEMENT 	 23
      3.2    PROCUREMENT ISSUES	 25
      3.3    MANAGEMENT TOOLS 	 26

4.0    SUMMARY 	 29


                                     TABLES
      Data Gaps and Tools to Manage Uncertainty	 6
                                    FIGURES
Figure                                                                        Page

1     The Triad Approach 	 2
2     Understanding the Context of Cleanup 	 5
3     Employing the Triad Approach	 10
4     Life Cycle of a Conceptual Site Model 	 11
5     CSM of Example Pathway Receptor Networks 	 16
6     Example of CSMs for Urban Soil Contamination	 17


Appendices

A     FREQUENTLY ASKED QUESTIONS (FAQ) WHEN DESIGNING A PROGRAM USING
      THE TRIAD APPROACH

B     LIST OF ACRONYMS

C     LIST OF RESOURCES

D     DESCRIPTIONS OF COMMONLY USED FIELD-BASED SAMPLING AND ANALYTICAL
      TECHNOLOGIES
U.S. Environmental Protection Agency
Office of Solid Waste and Emergency Response
Brownfields Technology Support Center

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                    Using the Triad Approach to Streamline Brownfields Site Assessment and Cleanup
                                       1.0  INTRODUCTION


1.1     PURPOSE


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

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

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

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

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

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

one in a series that will address specific cleanup issues.
                              Brownfields Technology Support Center

  EPA established the Brownfields Technology Support Center (BTSC) to ensure that brownfields decision-
  makers are aware of the full range of technologies available for conducting site assessments and cleanup, and
  can make informed decisions about their sites. The center can help decision makers evaluate strategies to
  streamline the site assessment and cleanup process, identify and review information about complex technology
  options, evaluate contractor capabilities and recommendations, explain complex technologies to communities,
  and plan technology demonstrations.  The center is coordinated through EPA's Technology Innovation Office
  (TIO) and offers access to experts from EPA's Office of Research and Development (ORD) and other Federal
  agencies such as the Department of Defense (DoD) and the Department of Energy (DOE). Localities can submit
  requests for assistance directly through their EPA Regional Brownfields Coordinators; online at
  brownfieldstsc.org', or by calling toll free 1-877-838-7220.  For more information about the program, contact
  Dan Powell of EPA TIO at 703-603-7196 or powell.dan(q),epa.gov.  Contact information for Regional
  Brownfields Coordinators can be found at www.epa. sov/brownfields/contacts. htm.

  Other publications developed through the BTSC:

  •   Brownfields Technology Primer:  Selecting and Using Phytoremediation for Site Cleanup
  •   Brownfields Technology Primer:  Requesting and Evaluating Proposals That Encourage Innovative
      Technologies for Investigation and Cleanup
  •   Road Map to Understanding Innovative Technology Options for Brownfields Investigation and Cleanup,
      Third Edition
  •   Assessing Contractor Capabilities for Streamlined Site Investigations
  •   Directory of Technology Support Services to Brownfields Localities

  Primers currently under development:

  •   Brownfields Technology Primer:  Perspectives on Technology  Selection and Use
  •   Directory of Technical Assistance for Land Revitalization
  •   Understanding Procurement for Innovative Sampling and Analytical Services for Waste Site Cleanup
U.S. Environmental Protection Agency
Office of Solid Waste and Emergency Response
Brownfields Technology Support Center

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                   Using the Triad Approach to Streamline Brownfields Site Assessment and Cleanup
1.2
        BACKGROUND
                                                       The Brownfields Revitalization and
                                                       Environmental Restoration Act of 2001 defines
                                                       a "brownfield site" as real property, the
                                                       expansion, redevelopment, or reuse of which
                                                       may be complicated by the presence or potential
                                                       presence of a hazardous substance, pollutant, or
                                                       contaminant.
Since its inception in 1995, EPA's Brownfields
Initiative has grown into a major national program that
has changed the way contaminated property is
perceived, addressed, and managed in the United
States. In addition, over time, there has been a shift
within EPA and other environmental organizations in
the way that hazardous waste sites are cleaned up.  Historically, sites have largely been cleaned up using a
relatively standard approach to "command and control" the cleanup process . This approach was
developed for dealing with the most heavily contaminated and hazardous sites and often did not (or could
not due to specific long-term issues) consider the ultimate end use of a property, and could be both costly
and lengthy. More recently, regulators and site managers are increasingly recognizing the value of
implementing a more dynamic approach to
site cleanup that is flexible and recognizes                  Figure 1. The Triad Approach
site-specific decisions and data needs and can
reduce costs, improve decision certainty, and
expedite site closeout. As shown in Figure 1,
this new approach relies on a three-pronged
or Triad approach that focuses on the
management of decision uncertainty by
incorporating:  (1) systematic project
planning, (2) dynamic work plan strategies,
and (3) the use of real-time measurement
technologies to accelerate and improve the
cleanup process.
                                                    A Systems Approach Framework
                                                 Systematic
                                                   Project
                                                   Planning
 Dynamic
Work Plan
Strategies
                                                           Real-time Measurement
                                                                Technologies
EPA has shown its support for the adoption of streamlined approaches to sampling, analysis, data
reviews, and evaluations conducted during site assessment, characterization, and cleanup through a
number of activities, including technical and guidance documents.  As part of these activities, EPA has
been coordinating with many Federal and state agencies to educate regulators, practitioners, site owners,
and others involved in site cleanup decisions about the benefits of a streamlined approach.
U.S. Environmental Protection Agency
Office of Solid Waste and Emergency Response
Brownfields Technology Support Center

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                   Using the Triad Approach to Streamline Brownfields Site Assessment and Cleanup
Brownfields sites are well suited to using the Triad approach, where limited funding and intended reuse
strongly influence cleanup.  Inherent in the Triad approach is the need for cooperation and collaboration
among the many stakeholders in the process. A goal of the Brownfields Initiative is to enable states and
communities to work together to assess, safely cleanup, and sustainably reuse brownfields sites,
consistent with EPA's emphasis on future use, including engineering and land use controls.

Both the Triad approach and the Brownfields Initiative mutually reinforce each other through a common
sense approach where barriers are removed and dollars are leveraged to provide the most cost-effective
and streamlined approach to monitoring and measurement activities.  Use of real-time measurements,
including real-time measurement technologies, combined with a rigorous planning process to understand
and control sources of uncertainty, is inherent to the Triad approach and helps stakeholders improve the
reliability  of risk-related decisions.

1.3    ORGANIZATION

The primer is organized into three sections, including this introduction.  Section 2 describes the three
elements of the Triad approach, and provides examples of using each element.  Section 3 discusses the
role of the technical team in managing a project, procurement considerations when planning a project, and
decision-support software and other tools that are available to help brownfields site  managers.

In addition, this primer includes the  following appendices:

       Appendix A - Frequently asked  questions (FAQ)
•      Appendix B - List of acronyms
       Appendix C - List of resources
•      Appendix D - Descriptions  of commonly used field-based sampling and  analytical technologies
U.S. Environmental Protection Agency
Office of Solid Waste and Emergency Response
Brownfields Technology Support Center

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                    Using the Triad Approach to Streamline Brownfields Site Assessment and Cleanup
                                   2.0  THE TRIAD APPROACH

The keystone concept of the Triad approach is the identification and management of those unknowns (i.e.,
uncertainties) that could cause excessive or intolerable errors in decision-making. An example of such a
decision error would be to declare a site "clean" for redevelopment to proceed because contamination that
would have been treated or removed prior to redevelopment was missed during sampling. The Triad
minimizes the likelihood of mistakes by cost-effectively supporting the development of an accurate
conceptual site model (CSM).  CSMs are discussed in detail in Section 2.1. Briefly, a CSM is any
graphical or written representation (or "conceptualization") of site contamination concerns:  how it got
there, whether or not it is migrating or degrading, how variable  concentrations are across the site, what
receptors might be exposed, and what risk-reduction strategies are most feasible. An accurate CSM is a
primary work product of the Triad approach that is refined and matured over the course of an
investigation. To develop an accurate CSM, the Triad approach incorporates the elements of systematic
project planning, dynamic work plan strategies, and real-time measurement technologies into a decision
support matrix designed to manage uncertainties associated with environmental restoration projects.
Selected Triad resources are identified below.
                                      Selected Triad Resources
 Listed below are useful resource materials about the Triad approach.  For more information on these resources
 and references to additional material, please see Appendix C.
 Each document listed below can be found at the CLU-IN Internet Site at http://cluin. org/triad/:
 •   Innovations in Site Characterization Case Study: Site Cleanup of the Wenatchee Tree Fruit Test Pilot Site
     Using a Dynamic Work Plan
 •   Using the  Triad Approach to Improve the Cost-Effectiveness of Hazardous Waste Site Cleanups
 •   Improving Sampling, Analysis, and Data Management for Site Investigation and Cleanup Sheet (Fact Sheet)
     (EPA542-F-01-030a)
 •   Resources for Strategic Site Investigation and Monitoring (Fact Sheet) (EPA 542-F-01-030b)
 •   A Dynamic Site Investigation: Adaptive Sampling and Analysis Program for Operable Unit 1 at Hanscom
     Air Force Base, Bedford, Massachusetts
 Related Internet sites  include:
 EPA's Dynamic Field Activities Internet Site: http://www.epa.sov/superfund/prosrams/dfa/index.htm
 EPA's Field Analytical Technologies Encyclopedia:  http://fate.cluin.ors
Note: Web addresses are current through 6/16/03
U.S. Environmental Protection Agency
Office of Solid Waste and Emergency Response
Brownfields Technology Support Center

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                   Using the Triad Approach to Streamline Brownfields Site Assessment and Cleanup
The Triad approach is applicable to many elements of monitoring and measurement activities that occur
on site - from early investigations aimed at risk estimation, through designing, implementing, and
monitoring the implementation of a remedy.  The key to the Triad approach and its benefits to
brownfields sites is that decisions are not made in a vacuum, but with the full consideration of existing
information developed during past site use and cleanup activities, and with a thorough understanding of
how the site might be reused. Using this approach, activities are performed that target the principal
sources of uncertainty that can affect the confidence of site decisions. Use of the Triad approach at
brownfields sites allows decision-makers to economically collect the volume and quality of data
necessary to reassure regulators and communities that a property is safe for reuse.
Figure 2 summarizes the interaction between
reuse plans and goals, site decisions, and
sampling and analysis approaches and tools.
As shown, these approaches are inter-
dependent. Unlike the Triad approach, a
traditional one-size-fits-all approach leads to
predetermined strategies and cleanup tools
and does not generally consider the inter-
dependence of reuse plans and goals with a
cleanup approach.
                                        Figure 2.  Understanding the Context of Cleanup
Understa
nding the Context of
Reuse Plans and Goals
_^H Drive _^B
Site Decisions:
• Clean-up goals
• Tolerable decision uncertainty
• Data (type, quality)
Cleanup
_^H Determine _^B
Approaches to:
• Assessment
• Investigation
• Cleanup Design and
Implementation
• Closeout, Long-Term Operations,
and Maintenance
M
Tools for:
• Sampling and Analysis
• Cleanup/Remediation
> Containment
> Cleanup
> Controls
• Monitoring and maintenance
The three elements of the Triad approach are discussed in more detail below.
2.1
SYSTEMATIC PROJECT PLANNING
In the context of contaminated site cleanup, systematic project planning is a transparent, deliberate, and
coordinated effort to identify and manage factors and issues that contribute to decision uncertainty (those
unknowns that could contribute to decision errors).

During systematic project planning, factors and variables that may impact the design and execution of
project activities should be identified so that cost-effective strategies to manage those factors (or manage
around them) can be developed. Drawing on previous personal experience and institutional knowledge, a
project manager should try to anticipate issues that may adversely impact the project.  Factors that may be
U.S. Environmental Protection Agency
Office of Solid Waste and Emergency Response
Brownfields Technology Support Center

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                     Using the Triad Approach to Streamline Brownfields Site Assessment and Cleanup
important to systematic planning (depending on the particulars of the site and the project) include budget
(including contracting mechanisms), schedule (time frames) and other resources (including the
availability of staff and support personnel, the state of scientific and technical knowledge, and the
availability of technology/equipment), as well as regulatory and programmatic requirements. For some
sites, political and media interest, local community health and economic concerns, and broader health and
economic considerations can have a large impact on the design and flow of site activities.


Of the three elements of the Triad approach, the systematic planning component is the most important and
the most universally applicable.   Regardless of the type of site and strategy chosen for data collection,
decision-makers should engage in systematic planning to tie the data collection to site decisions.  It is the
basis for creating a defensible approach and a scientifically sound data set.  A thorough and systematic
planning effort will help determine if and where field technologies can be used.  Systematic planning
helps determine if and how a dynamic implementation approach makes sense at a site and it establishes
the framework to ensure that the  data collected are sufficient for site needs.  The emphasis on a thorough
planning process is essential to achieving the savings (time and cost) that are possible with the Triad
approach and achieving the defensibility  and confidence in site decisions. Some  examples of the types of
data gaps and the tools used to manage uncertainty in the systematic planning process are shown in
Table 1.
                         Table 1.  Data Gaps and Tools to Manage Uncertainty
   Portion of the Cleanup
        Process
Types of Data and/or Information Gaps
        Typically Identified
     Tools to Address Filling Data Gaps
         and Managing Uncertainty
 Early on and throughout the
 project as more is learned
 and decisions change
What are the potential environmental issues
at the site?
What are the potentially impacted media and
potential receptors?
What are the planned reuse and political
status?
What is the economic viability of cleanup?
Who are the responsible party and regulating
authority?
Historical records, depositions, and visual inspections
Site location, historical photos, geological information
Public and other stakeholders
Cost benefit analyses
Record searches
Depositions
Operational history
 Investigations
What is the nature and extent of regulated
chemical contaminants?
Analytical chemistry methods
Sampling designs
Sample collection equipment
Classical statistical models to estimate contaminant
concentrations
Geostatistical models to define contaminant populations
Contaminant distribution maps
                           What is the estimated fate and transport of
                           contaminants?
                                    Geological measurements
                                    •   Hydrogeological measurements
                                    •   Geophysical measurements
                                    •   Modeling
U.S. Environmental Protection Agency
Office of Solid Waste and Emergency Response
Brownfields Technology Support Center

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                    Using the Triad Approach to Streamline Brownfields Site Assessment and Cleanup
                  Table 1. Data Gaps and Tools to Manage Uncertainty (continued)
Portion of the Cleanup
Process
Investigations (continued)
Investigations and cleanup
actions
Remedy designs and
cleanups
Remedy design
Remedy implementation
Operations and
maintenance
Types of Data and/or Information Gaps
Typically Identified
• Are exposure pathways complete?
• What are the appropriate cleanup levels for
the site?
• Are reporting limits above the potential
action levels?
• Is there sufficient data to support site
closure?
• What data are needed to support
implementation of potential remedies at the
site
• Do viable treatment or containment
technologies or other alternatives exist?
• What is the preferred alternative?
• What data are needed to evaluate remedy
effectiveness, including need for source
removal?
• How can closure be documented?
• How can system performance be optimized
and operating costs reduced?
Tools to Address Filling Data Gaps
and Managing Uncertainty
• Analytical chemistry methods
• Sampling designs
• Geological measurements
• Hydrogeological measurements
• Geophysical measurements
• Air release measurements
• Sampling and analysis data
• Toxicological information
• Existing regulations
• Exposure scenarios
• Future use
• Analytical chemistry methods
• Method modifications
• Risk data
• Statistical data
• Modeling
• Existing data
• Information concerning available remedies
• Nature and extent data
• Engineering considerations
• Land use controls
• Vendor cost and performance information
• Case studies
• Pilot studies
• Engineering designs
• Statistical evaluations
• Operational data
• Confirmation sampling results
• Engineering/land use controls
• Chemical and engineering data
• Cost-effectiveness evaluation
                         To Learn More about Systematic Project Planning
   The Marino Scrap Yard site in the Borough of Rochester, Pennsylvania, is using the Triad approach for
   streamlining site assessment and cleanup. The city is considering reuse of this site.  However, there are
   concerns about contamination of shallow soils with lead, mercury, and polychlorinated biphenyls (PCBs). The
   BTSC has provided support to the city for this site, including:  (1) tools and methods used to develop a
   conceptual site model for contamination at the site; (2) pathway analysis and risk estimation; (3) development
   of a dynamic work plan strategy;  (4) requirements for the use and control of field-based technologies to limit
   decision uncertainly; (5) procurement approaches and costing methods in support of Triad type projects; and
   (6) the key elements of systematic planning for reuse at the site.  The conceptual site model developed by the
   BTSC, the dynamic work plan strategy, and statement of work can be found at brownfieldstsc.org.
Under the Triad approach, decision-makers may need to expend a greater amount of time and energy on

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

plan for project schedules and resources. However, this up-front planning effort will reduce the
U.S. Environmental Protection Agency
Office of Solid Waste and Emergency Response
Brownfields Technology Support Center

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                    Using the Triad Approach to Streamline Brownfields Site Assessment and Cleanup
uncertainty and increase the efficiency of activities while crews are in the field. Conversely, insufficient

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

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


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

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

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

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

(see box on decision quality). The rigor of the techniques used to collect and analyze data should match
the intended use. For example, data used for waste segregation prior to final characterization often can be

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

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

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

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

 The term "decision quality," in its broadest sense, implies that decisions are defensible.  Ideally, decision quality
 would be equivalent to the correctness of a decision. However, in the environmental field, decision correctness is
 often unknown (and perhaps unknowable) at the time of decision-making. "Correct" decisions are those that
 would be made if project decision-makers possessed complete and accurate knowledge about site contamination.
 When knowledge is limited, decision quality hinges on whether the decision can be defended against reasonable
 challenge in whatever venue it is contested, be it scientific, legal, or otherwise. Scientific defensibility requires
 that conclusions drawn from scientific data do not extrapolate beyond the available evidence. If scientific
 evidence is insufficient or conflicting, decision defensibility may rest properly on other considerations. No matter
 what those considerations are, "defensibility" implies there is honest and open acknowledgment of the full range
 of uncertainties impacting the decision-making process. Systematic planning may identify a number of ways to
 manage decision uncertainty. For regulatory programs seeking to use sound science as the basis for defensible
 decision-making, then the uncertainty involved in generating and interpreting scientific data will have to be
 addressed and managed. The Triad approach makes it cost-effective to do so. [EPA's Office of Solid Waste and
 Emergency Response (OSWER) policy states that sound science must underscore all OSWER regulatory, policy,
 and programmatic decisions.]
While the use of real-time measurement is a key component of maximizing information value while

minimizing costs, decision-makers should ultimately focus on the best analytical and sampling strategy
for conducting an investigation.  This will often involve "mixing and matching" various sampling and

analytical techniques.  Detailed systematic planning encourages project managers to consider the use of
U.S. Environmental Protection Agency
Office of Solid Waste and Emergency Response
Brownfields Technology Support Center

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                   Using the Triad Approach to Streamline Brownfields Site Assessment and Cleanup
field-based technologies or quick turnaround fixed
laboratory analyses to support timely decision-
making.  Decisions made on a timely basis (daily or
weekly) help ensure that project decision points are
reached in as few mobilizations as possible, and
that project technical staff optimize the efficiency
of a sampling or cleanup design, which is one of
the biggest advantages of using the Triad approach.

Systematic planning is undertaken to chart a course
for the project that is both cost-effective and
technically sound and defensible, attaining the
appropriate decision quality based on "sound
science." A primary goal of the Triad approach is a
CSM that can be used to support correct decisions.
Managing Sources
of Uncertainty...

The Conceptual Site Model

The CSM is the one of the primary planning tools used in systematic project planning.  The CSM
organizes the information known about a site and helps the team identify additional information that
needs to be obtained. The systematic planning process ties project goals to those individual activities
necessary to reach these goals by identifying data gaps. The project team uses the CSM to direct the
gathering of needed information; the CSM is revised and decision goals refined as more is learned about
the site. As the CSM matures and as contaminant characteristics become better defined, the project team
may need to revisit measurement quality objectives and decision criteria.

Figure 3 summarizes how the planning components and in-field activities typically interact in a step-wise
fashion during the life cycle of a CSM under the Triad approach. Figure 4 provides a more detailed
overview of the life cycle of a CSM, as a project moves through increasing levels of complexity.
U.S. Environmental Protection Agency
Office of Solid Waste and Emergency Response
Brownfields Technology Support Center

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                   Using the Triad Approach to Streamline Brownfields Site Assessment and Cleanup
In guiding the site characterization process, the CSM provides:
                                               Figure 3.  Employing the Triad Approach
                                             Employing the Triad Approach
•  The framework for conducting
   and scoping a site investigation or
   cleanup action that takes into
   account the future use of the site

•  A detailed description of the site
   and its setting that is used to form
   hypotheses about the release and
   ultimate fate of contamination at
   the site

•  Sources of contamination at the
   site, potential chemicals of
   concern, and the media (soil,
   groundwater, surface water,
   structures) affected

•  How contaminants may be
   migrating from the sources, and
   the media and pathways through which migration and exposure of potential human or environmental
   receptors could occur (including possible air releases)

•  An evaluation of potential or preferred cleanup options

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

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


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

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

project needs.

— *



Identify principal study
questions and decisions
~
i
\
J
3
s
n
>
j
i
)
C

O


Conduct demonstration
of methods applicability
~
§
O
T3
C
(T
t
The initial or preliminary CSM should be refined using information collected during measurement,

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

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

(creating a tangible end point for sampling and analysis).
U.S. Environmental Protection Agency
Office of Solid Waste and Emergency Response
Brownfields Technology Support Center
                                                10

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                       Using the Triad Approach to Streamline Brownfields Site Assessment and Cleanup
                              Figure 4. Life Cycle of a Conceptual Site Model
   CSM Maturity Level
       Preliminary
       Conceptual
       Site Model
       (little or no
       site-specific
       data available)
       Design and
       Implement a
       Dynamic Work Plan
       to Verify/Define the
       Preliminary
       CSM
       Quantitative
       Risk
       Assessment
       Based on a
       Mature
       CSM
                       a
                        ^ 1   \ f
                                          Confirm and Refine
                                          Exposure Pathway
                                             Assumptions
                                         Perform a Quantitative
                                           Risk Assessment
                                             (Monte Carlo)
Collect Additional Data to
Support Remedial Actions
                                                           Key Decisions
                                                                                                  1. Is there a
                                                                                                    potential
                                                                                                    threat to
                                                                                                    human health
                                                                                                    and the
                                                                                                    environment?
                                                           2. Which
                                                             chemicals
                                                             from what
                                                             media pose a
                                                             potential risk
                                                             under the
                                                             land use
                                                             scenario?
                                                           3. Does a risk
                                                             exist above
                                                             tolerable
                                                             levels based
                                                             on default
                                                             criteria?
                                                           4. What action
                                                             based on
                                                             default risk
                                                             criteria?
5. Based on
  realistic
  exposure and
  response
  scenarios,
  what site
  cleanup goals
  or action
  levels are
  required?
U.S. Environmental Protection Agency
Office of Solid Waste and Emergency Response
Brownfields Technology Support Center
                   11

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                    Using the Triad Approach to Streamline Brownfields Site Assessment and Cleanup
                   To Learn More about Demonstrations of Methods Applicability
   The Town of Bluffton, South Carolina, is using the Triad approach to develop a cost-efficient strategy for
   assessing the extent of lead contamination in a soil berm at a shooting range (Small Arms Firing Range) used
   by the town police force.  A first step in developing the strategy was designing a demonstration of methods
   applicability study, consistent with EPA SW-846 method development guidelines.  The BTSC has provided the
   state with a white paper discussing potential options for evaluating how XRF samples should be collected, what
   sample preparation should be considered, and how these options can be driven by proposed reuse and remedial
   alternatives. Results from the BTSC effort are described in Analysis of Considerations for Developing a
   Methods Applicability Study at a Small Arms Firing Range in Bluffton, South Carolina. Two documents that
   were used as supplemental material for the applicability study that provide useful information on the
   remediation of small arms firing ranges are:
   •    Technical/Regulatory Guidelines Characteristics and Remediation of Soils at Closed Small Arms Firing
        Ranges; Prepared by the Interstate Technology Regulatory Council.
   •    Technical Protocol for Determining the Remedial Requirements for Soils at Small-Arms Firing Ranges;
        Prepared for Air Force Center for Environmental Excellence Technology Transfer Division, Brooks Air
        Force Base, Texas.
   The white paper along with the supplemental materials can be found at brownfieldstsc. ors.
Examples of the types and sources of background information that can be important when developing a
preliminary CSM and refining a CSM are described below. Study areas are rarely exactly alike and the
construction of a CSM for an individual site will require site-specific background information sources.
Some types of background information will frequently be relevant to a CSM while others will have little
or no significance to the site.  It is the project planning team's job to identify and research the relevant
types of background information to aid in the construction of a preliminary CSM.

Archeological/Historical  Use
The archeological and historical use of a site can reveal a variety of important data for the construction of
a CSM. For example, if a  region had been historically used as a mining district, the impacts from the
historical mining could contribute to the CSM in numerous ways.  Such mining influences can
significantly alter all aspects of a site's surface and groundwater geochemistry, fauna, flora, and
geomorphology,  and should be considered in the construction of a CSM. The impacts of future land use
and other effects  on archeological sensitive sites should also be  considered. A starting point for gathering
archeological information  on a specific site can be found at the National Archeological Data Base at
http://web.cast.uark.edu/other/nps/nadb. This site provides information on archeological activities and
sites nationwide.
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Physiographic
Identifying the physiographic province in which a site is located can be important to a CSM.  A
physiographic province is a region with similar geologic structures and climate, and whose pattern of
topographic relief differs significantly from that of adjacent regions, indicating a unified geomorphic
history. With the identification of the site's physiographic province, key climatic, geologic, and
hydrologic components to the CSM may be identified.  A good starting point for gathering general
physiographic information for sites in the United States can be found at
http://www.him.gov/wildlife/pi fplans.htm. More detailed information available in U.S. Geological Survey
(USGS) topographic maps illustrating physiographic features can be found at
http://rmmcweb.cr.usgs.gov/public/outreach/featureindex.html.

Climatic
Climatic conditions can play a major role in a CSM.  Climatic conditions have significant influences on
several key components of a CSM, including hydrologic budget, fauna, flora,  and land use. For example,
precipitation rates can impact aquifer recharge and land use.  Basic climatic properties, such as air
temperature, precipitation, and prevailing wind speed and direction can be important properties of a CSM.
With a basic understanding of a few climatic indicators, an understanding of the climate's impact on the
study area can be incorporated into a CSM. Climatic information from worldwide weather stations can be
found at http://www.worldclimate. com/worldclimate.

Geologic
A fundamental understanding of the geology  of a study area is essential in the construction of a sound
CSM.  Among the  basic geologic components that need to be incorporated into a CSM are the types of
geologic materials  that make up the study area, structural geologic features, depositional environments,
and geomorphology. For example, a CSM would indicate what the study area consists of, such as
unconsolidated alluvial deposits underlain by bedrock.  A starting point to gather geologic information is
USGS geologic research activities, which are grouped by geographic locations and  can be found at
hftp://geode. usgs. gov/. For topographic, photoimage, geologic, and hydrologic maps, go to
http://mac.usgs.gov/mac/isb/pubs/booklets/usgsmaps/usgsmaps.html.  Additionally, the site
http://geosurvey.state.co.us/GeoLinks.htm#state will provide links to each state's geologic survey.
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Hydrogeologic
When a CSM is constructed as a result of environmental concerns, the hydrogeologic component
typically receives the most attention because of the importance placed on groundwater and surface water
quantity and quality. An understanding of the site hydrogeology is required to provide an adequate
representation of the hydrogeologic component of a CSM. A site's hydrogeology may be broken into
three main categories: aquifer characteristics, hydrologic budget, and groundwater flow.

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

    1.  Aquifer characteristics
       a.  Type (Examples:  unconfined, confined, or semi-confined)
       b.  Characteristics (Examples:  hydraulic conductivity, transmissivity, storitivity)
       c.  Geology (materials and structure)

    2.  Hydrologic budget
       a.  Recharge rates (Examples:  precipitation, artificial recharge)
       b.  Discharge rates (Examples: evaporation, transpiration, groundwater pumping)

    3.  Groundwater flow
       a.  Hydraulic gradient (Examples: groundwater elevations, flow direction)
       b.  Flow velocity (travel time)
       c.  Boundary conditions (Examples: Dirichlet, Neumann)

To characterize a site's hydrogeology, many different sources of hydrogeologic data may be used. The
availability of hydrogeology data for a particular study is simply a matter of what work has  been
performed—and if it is publicly available. A good source of publicly available hydrogeologic data and
reports is the USGS. The USGS produces open file reports and maintains a database of hydraulic
information for sites throughout the United States and its territories.

A good starting place to develop the hydrogeologic portion of a CSM is to identify the hydrologic setting
of the study area from the Army Corps of Engineers Cycle II National Water-Quality Assessment
(NAWQA) Study Units  (http://water.usgs.gov/nawqa/studyu.html).  Additional sources for  hydrogeologic
information on U.S. water resources can be found at http://water.usgs.sov/nwis.
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In addition, the hydrogeological portion of a CSM also might address environmentally sensitive areas
(e.g., wetlands, watersheds, and breeding areas). These areas should be considered within an overall
CSM, including the potential impact of contamination on human or environmental endpoints.

Other Data Sources Used to Build a Preliminary CSM
Additional sources of data used to build a CSM include database reviews, usually conducted for a fee by
professional data resource companies such as Environmental Data Resources http://www.edrnet. com/ and
Vista Info http://www. vistainfo. com/. ASTM Standard E1527 (see box below) requires a review of the
physical setting of the property being investigated. A current USGS 7.5  Minute Topographic Map (or
equivalent) showing the area where the property is located should be reviewed.  Maps can be obtained
through the USGS at http://mapping.usss.gov/or through professional data resource companies such as
Environmental Data Resources and Vista Info.  The 7.5 Minute Topographic Maps can be used in
describing the physical setting of the property and adjoining properties, determining prior land  uses, and
in estimating local groundwater flow direction.  Groundwater flow direction is important in determining if
nearby sites identified in the database searches have the potential to impact the property.
                         ASTM Standard E1527 - Phase 1 Site Assessments

 The American Society for Testing and Materials (ASTM) (www.astm.org), has developed Standard El527-00
 "Standard Practice for Environmental Site Assessments: Phase 1 Environmental Site Assessment Process." This
 standard, along with its predecessor El 527-97, is intended to define good commercial and customary practice in
 the U.S. for conducting an environmental site assessment of a parcel of commercial real estate with respect to the
 range of contaminants within the scope of CERCLA or for petroleum products. Under 40 CFR Section 312, EPA
 recently finalized a rule (68 FR 24888;  5/9/03) that identifies these standards as satifying the requirements for
 conducting "all appropriate inquiry" under The Brownfields Revitalization and Environmental Restoration Act of
 2001.
 Other relevant ASTM Standards include D6235-98a Standard Practice for Expedited  Site Characterization of
 Vadose Zone and Ground Water Contamination at Hazardous Waste Contaminated Sites and E1912-98 Standard
 Guide for Accelerated Site Characterization for Confirmed or Suspected Petroleum Releases.
Figure 5 is a simplified CSM that identifies examples of pathway receptor networks.  Typical questions
asked during the planning process and in building a CSM include:

1.  What is the proposed reuse or current use of the site?
2.  Is the proposed reuse of the site politically, economically, and socially viable?
3.  What media are impacted and by what type of contamination?
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                                        Figure 5. CSM of Example Pathway Receptor Networks
                                                           l Prevailing wind direction
                                                                              Transport Medium (air)
                                                                                         Release
                                                                                         mechanism
                                                                                         (volatilization)
                                                                         Transport medium (ground water)
4.   Are there any potentially complete
    receptor pathway networks
    present at the site?

5.   What exposure point concentration
    might represent a potential risk?

6.   Do the exposure assumptions used
    in the risk assessment match the
    reuse scenario?

7.   What method reporting limits are
    needed to assure the delineation of
    potential hot spots?

8.   What are some of the available
    remedies for the site?
9.   What are the potential human
    exposure pathways?  (EPA's 1996 Soil Screening Guidance (SSG) provides site managers with a
    tiered framework for developing risk-based, site-specific soil screening levels for the protection of
    human health. The SSG, specifically the User's Guide and Appendix A, provides additional guidance
    on developing a CSM.  More information on the guidance can be found at
    http://www.epa.gov/superfund/resources/soilMfact).

A CSM should not be limited to soil and groundwater contamination; rather, it should consider all
potential exposures and receptors. For example, air exposure pathways (e.g., inhalation) are particularly
important to consider in those situations where contamination will be left in-place, such as when a
building will be located above an area with residual waste.


Figure 6 shows additional examples of CSMs that are relevant to brownfields sampling and cleanups that
represent varieties of urban soil contamination. As this figure shows, identifying the model for
contaminant deposition is an important  consideration in the development of a representative sampling and
analysis plan for urban soil contamination.


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

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

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

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

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

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

quality that will maximize the weight of evidence upon which decisions will be made.
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                          Figure 6.  Example of CSMs for Urban Soil Contamination
              CSM #1 - Deposition Model

              Airborne emissions (dust, gases) from
              point source(s); concentrations decrease
              with distance from source and area of
              deposition dependent on many variables.

              Pollution most evident in the topsoil and
              decreases with depth.
              CSM #2 - Line Model

              Soil impact that originates from moving
              point sources aligned along a long linear
              element in the landscape, e.g. a road,
              railway.

              Pollution decreases with distance from
              the line source and with depth.
              CSM #3 - Surface Addition Model

              Spreading of a contaminating material,
              e.g. cinders, sewerage slam, sediment,
              spent oxide from gasworks.

              The diffuse soil pollution constitutes a
              uniform load in the uppertopsoil.
              CSM #4 - Contribution Model

              Small random contributions over many
              years, e.g. the historic fill on top of which
              a town develops.

              The diffuse soil pollution constitutes a
              variable and random load to the historic
              fill.
              CSM #5-Soil Fill Model

              Systematic dumping/filling with soil, waste,
              material of unknown origin, e.g. land
              reclamation of low lying areas and coast
              regions, backfill, harbor construction.

              The diffuse soil pollution constitutes a
              variable and random load to the historic
              fill.
                                                                                                 Concentration profiles
                                     Concentration
                           Vi
                                                                                                 Concentration profiles
                                   Concentration profiles


                              v-s/^^A/^f  W*   U^
                                      Concentration
                                   Concentration profiles
     Source:  Project on diffuse soil pollution funded by the Danish EPA.  Paper by Jacqueline Falkenberg, NIRAS;
     Ulla H0jsholt, the Danish EPA; Arne Rokkjaer, Information Center of Contaminated Sites; Mariam Wahid, the
     Agency of Environmental Protection in Copenhagen.  Consoil 2003.  (Used with permission)
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At brownfields sites, systematic planning and development of the CSM need to closely tie into the reuse
plans for the site. A balance must be achieved between the costs required to purchase and redevelop the
site and the potential benefits (revenues, resale/asset value, social/political) once the site is ready for
reuse.  CSMs will identify the environmental, financial, and social factors that will likely determine the
potential reuse scenarios possible at a site.

2.2  DYNAMIC WORK PLAN STRATEGIES

What is a dynamic work plan strategy? Dynamic work plan strategies are the second element of the
Triad approach.  These types of strategies use real-time decision-making in the field to limit the number
of mobilizations back to the field to fill data gaps or take remedial actions. This approach significantly
reduces project costs and the schedule to reach project closeout.  Use of a dynamic work plan strategy and
related project management strategies can improve the economics that drive the reuse potential for
brownfields properties.

A dynamic work plan strategy is one where decisions are made and the work plans guiding sampling and
analysis are adjusted in response to data generated while the field crew is still on site (i.e., while still in
the field). Proper application of a dynamic strategy allows field teams to efficiently  collect the data
needed for decision-making and to fill data gaps (described in the preceding section) with as few
mobilizations as possible.  Dynamic work planning is the element of the Triad approach that can have the
greatest impact on cost and time savings.

A dynamic work plan strategy relies on real-time data to reach decision points and quickly identify the
need for alternative action.  Real-time data is defined in terms of the timing required to satisfy decision-
making needs. Decisions are often of several different types - small scale decisions may need to be made
daily, while larger scale decisions may need to be made weekly to keep the project moving.   A key
element is the development of decision logic to guide the teams while in the field. This logic should be
reviewed and approved by the regulator and others who will use the data and determine the
appropriateness and validity of specific site decisions.  The logic for decision-making is identified and
responsibilities, authority, and lines of communication clearly established in the plan.  Implementation of
all field work is driven by the critical project decisions needed to reach closure. These decision points
and potential scenarios  are carefully mapped during the planning process.
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                        To Learn More about Dynamic Work Plan Strategies
   The Cos Cob Power Plant site in Greenwich, Connecticut, was formerly a coal-fired power generation station.
   The city was examining a reuse plan for the site consisting of multiple use recreation areas, however concerns
   existed about PCS- and petroleum-contaminated soils at the site. Polycyclic aromatic hydrocarbons (PAHs),
   metals, and asbestos were suspected to be present at the site. The BTSC has provided support to the city for
   using the Triad approach, including participation in the development of a dynamic work plan strategy to
   implement a field-based measurement program.  These activities have been documented in a project
   profile/case study available at brownfieldstsc. org.
   The Wenatchee Tree Fruit Fruit Research and Extension Center site is an agricultural research facility located
   in Wenatchee, Washington.  The test plot area of the site contained soils contaminated with organochlorine
   pesticides, organophosphorus pesticides, and other pesticides.  Site investigation and cleanup was performed
   using the Triad approach, including use of a dynamic work plan strategy and immunoassay field test kits. In
   addition, a pilot test was performed that demonstrated the applicability of immunoassay test methods for
   pesticides such as DDT and cyclodiene and that was used to guide on-site decision-making. The U.S. Army
   Corps of Engineers (USAGE) prepared several documents about this effort, including a Remedial Action
   Management Plan and a Sampling and Analysis Plan. These documents provide background on the site, as
   well  as discuss project scope and objectives, and field activities, including soil characterization by
   immunoassay and traditional techniques.  These documents can be found at brownfieldstsc. ors.
Once the strategy and logic are established, an approved decision tree can then be used by the field team
to guide their dynamic decision-making during field activities.  The decision tree provides the basis for
decisions made in the field and results in a defensible paper trail for the field work and resulting data.
Deviations from the approved decision tree require thorough documentation, and may require real-time
approval of regulators and stakeholders. Dynamic work plans are designed to use decision trees and real-
time uncertainty management practices to reach critical decision points in as few mobilizations as
possible. Sequencing of activities is used to minimize crew sizes and allow for data collection and
processing time, while not slowing overall project progress. For example, members of a field crew can be
split into groups to perform concurrent activities. One group can be staking locations while another is
sampling and analyzing  samples, and another is determining and managing excavation activities.

The likelihood of success for a dynamic approach is enhanced when experienced staff, at least initially, go
to the field to review operations and trouble-shoot decision logic during project startup. Having some
level of senior  staff review during project startup helps to ensure that the appropriate staff are empowered
to make decisions, that decision logic is sound, and that foreseeable problems are anticipated before they
arise. Field staff in a dynamic field program are responsible for involving core technical team members
who, in turn, usually are responsible for communicating results to regulators  or others  overseeing the
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project. After completion of a project, summary reports should clearly discuss the decisions that were
made, the uncertainties that impacted project decision-making, and the strategies used to manage these
uncertainties.

Recent advances in communications technologies and communications plans support modern dynamic
strategies. Conference calls, mobile telephones, wireless email and Internet access, decision support
software, videostreaming, and faxes are among the tools that can be applied to facilitate communication
among team members. These tools can support the daily and weekly decision meetings that are needed
without necessarily requiring that all the key decision-makers (for example, regulators, risk assessors,
senior managers, and so forth) be physically on site during field work. It is essential, however, that the
field team include a senior authority who has the confidence of the project team to effectively transmit
information and to execute project decisions in the field.

2.3  REAL-TIME MEASUREMENT TECHNOLOGIES

What is real-time measurement?  Real-time  measurements are those that are produced within a rapid
time frame so that real-time decision-making and maturation of the CSM can occur in real-time (i.e.,
while the team is in the field). The term "real-time measurement technologies" encompasses much more
than just on-site analytical tools such as test kits and field instrumentation such as field-portable gas
chromatography (GC) or x-ray fluorescence (XRF). It also includes rapid  sampling platforms, in situ
detection technologies, and the software programs used to manage, interpret, display, and map data in
real-time to make dynamic work plan strategies possible. In addition, the term includes rapid turnaround
of results from a fixed laboratory that may use either definitive or screening methods. Although
screening methods traditionally have been associated with field use, running "field" methods in a
traditional laboratory should be  considered since under certain circumstances it is the most efficient
option both logistically and economically.

Using field analytical tools and non-traditional analytical strategies are key to saving time and money
while limiting decision uncertainty, but requires thinking "outside of the box." The tools include a broad
category of analytical methods and equipment that can be applied either  at the sample collection site or at
a nearby laboratory capable of generating results on a quick or slightly accelerated rate. They include
methods that can be used outdoors with hand-held, portable equipment, as well as more rigorous methods
that require the  controlled environments of a mobile (transportable) or fixed laboratory. During the
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planning process, the project team identifies the type, quality, and quantity of data needed to answer the

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

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


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

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

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

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

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

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

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

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

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

collaborative data sets can take several forms including the following:
1.     Comparison of results from fixed lab methods to those from proposed field-based methods to
      evaluate anticipated performance.  Depending on results, this might involve selecting alternative
      conservative action levels for use with field-based methods. For example, use of a field-based
      method with less analytical precision or accuracy might be coupled with a lower action level to
      provide for greater certainty in identifying contaminated soil.

2.     Using data collaboratively to arrive at a particular conclusion.  For example, laser induced
      fluorescence measurements, cone penetrometer geotechnical data, and field-based gas
      chromatography information to guide design of a treatment system.

3.     Using field-based immunoassay results to decide when and where confirmation samples should be
      collected for fixed laboratory gas chromatography mass spectrometry results.

4.     Upfront demonstrations of methods (sampling and analytical) applicability developed using field-
      based and modeling methods can be used to understand the inherent variability of contamination
      expected in the field prior to the commencement of site characterization activities.  The EPA on-
      line calculators (www. epa. gov/athens/onsite) were developed to provide modelers and model
      reviewers with prepackaged tools for performing site assessment calculations (i.e., inherent
      variability of contamination expected in the field prior to the commencement of site
      characterization activities).


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

efficient manner is provided on the next page.
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Real-time measurements can support successful redevelopment at brownfields sites by providing a clearer

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

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

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

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

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

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

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

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

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

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

Achieving a "clean" value at a lower cost can have a significant affect on properties for redevelopment.
                             EXAMPLE: Use of Collaborative Data Sets

 If disposal costs vary widely based on a specific land disposal restriction (LDR) at a site, it may be desirable to
 obtain more accurate results when concentrations are close to the LDR value. For example, when screening
 analysis accompanied by appropriate quality control (whether performed in a fixed or field laboratory) indicates
 total PCB concentrations for a given volume of waste material is either far above or far below the regulatory
 threshold (that can trigger costly treatment such as incineration), then there would be little doubt about whether
 treatment is required or not based on the screening method results.  However, if the screening analysis results
 indicates that PCB concentrations are close to the regulatory threshold (i.e., closer than the resolution of the
 screening method can distinguish), then follow-on analysis using a more definitive method could be warranted. It
 would be important however, to first use the results of the screening method to estimate the variability within the
 waste volume, so that the proper strategy to collect representative samples (e.g., by compositing or calculating a
 statistically valid number of samples) for more expensive, definitive PCB analysis can be determined. Both sets of
 data are then used to justify the final decision about disposal: the much larger data set composed of screening
 analyses collaborates with the smaller set of definitive analyses so that definitive analysis of one or a  few samples
 can be confidently extrapolated to represent the entire matrix volume  in question.  While this  approach could result
 in an additional, upfront expense, it may result in saving more at a later date when it is time to dispose of material
 and to justify to stakeholders that the correct decision was made.

 When matrix heterogeneity is greater than analytical variability and the cost  of making a wrong decision (i.e.,
 about disposal of potentially contaminated materials) is high, collecting more samples for less expensive (i.e., less
 rigorous) analytical quality  is usually desirable to permit management of the data uncertainties caused by sampling
 variability. Dynamic work plans that provide for reactions to the observed variability in results help project teams
 make "on the fly" decisions to increase sampling density as appropriate to target the volume of contaminated soil
 that would need to be disposed.
Further information about the legal defensibility of using field methods can be found in "Using Field

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

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

This section discusses project management and procurement considerations important for use at
brownfields sites, including management tools that can be used to assist project managers in decision-
making.

3.1   PROJECT MANAGEMENT

During the development of a systematic plan for a site, a project manager should assemble a core
technical team.  This project team should include multi-disciplinary members and area experts as
necessary. A typical project team consists of a geologist, chemist, hydrogeologist, risk assessor, field
manager, engineer, and a procurement specialist. Activities should be rolled into logically related groups
and unitized rates developed when possible.  Using unit rates and activities will assist project managers in
scoping out and managing project growth or costs as more is learned about a site. For example, surface
soil sample collection, analyses, data management, data interpretation, and communication of daily results
could be rolled into a unit cost with associated sample processing minimums (for example, 30  samples
per day). By using a dynamic work plan strategy approach, decisions about whether additional samples
are required can be made in the field.  Project managers should estimate the maximum number of samples
required based on existing information but still plan for the unknown potential for project growth or
shrinkage. By obtaining unit costs from service providers, project managers have the information needed
to decide about the impact of authorizing additional work or reallocating project resources as necessary.

The approach used for project management will vary based on the nature  and complexity of the site
activities.  Relatively large,  complex sites or groups of sites  in an area-wide approach tend to involve a
more complex project management team, while relatively smaller, straightforward sites will  have a less
complex team. However, in all cases that use the Triad approach, the project manager can use unitized
rates and draw on expertise  as needed to manage the uncertainty and plan and execute a cost-effective site
assessment or cleanup.  Use of experienced staff can help to more quickly identify potential  problems as
they develop in the field and determine solutions that would more quickly get the project moving toward
completion.

When applying the Triad approach, it may be beneficial to use internal or separate contractors  to assist
during planning, rather than those who actually implement or perform the work. This practice helps to
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ensure the unbiased development of a plan to limit costs during project implementation. A higher level of
expertise may be required during planning. However, detailed instructions that are clear and a well
defined scope can encourage less expensive, less experienced contractors to bid on more complex jobs.
Once the systematic plan and statement of work are developed by the core technical team, it should be
communicated to stakeholders and other project personnel and feedback solicited.  Senior core technical
team members, stakeholders, and project team members need to have clear lines for communication so
that the approach and associated documents can be revised as more is learned about a site. Once a course
of action and appropriate triggers for corrective action are identified, an organized trail of documentation,
electronic and hard copy, needs to be put in place.  Daily and weekly decision-making requires the use of
innovative communication tools such as those discussed in Section 3.3.  Having a well thought out
communication strategy helps to ensure that finalizing results and obtaining a closeout letter on a site is
streamlined.  Cost savings realized in  streamlineg the investigation, cleanup, and closeout cycle are where
the true benefits of the Triad approach can be realized.

Insurance also is becoming a critical component to the success of Brownfields programs.  Insurance
companies are experts at identifying a monetary value for "managing uncertainty."  By using the Triad
approach, the level of uncertainty at a site can be decreased and a more accurate CSM can be developed,
resulting in the potential for a lower premium for an insurance policy to cover the cleanup and
redevelopment of a site. If insurance is anticipated to be a component of a Brownfield redevelopment, an
insurance company should be consulted during the systematic planning process to identify their
information needs. Case studies on these approaches and other publications indicate that upfront
management and planning costs can be higher with the use of the Triad approach than for other more
traditional programs. However, use of the Triad approach can result in back-end savings for
implementation and cleanup of 50 percent or more than the original estimation of project costs.

EPA's Dynamic Field Activities guidance provides site project managers with an overview of the
information needed to oversee the effective implementation of dynamic field activities, which include
systematic planning, dynamic work plans, and rapid analytical results, at their sites. More information on
this new guidance can be found at www. epa. sov/superfund/prosrams/dfa/.
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                        Achieving State Regulatory Acceptance of the Triad

 A major part of implementing the Triad approach is developing a framework that works within state regulations,
 for example addressing variations in terminology and standards.  Several efforts with state regulators currently
 are underway to broaden the understanding of the requirements related to using the Triad approach.

 Northeast Waste Management Officials' Association (NEWMOA)

 NEWMOA's waste site cleanup program focuses on issues of interests to state programs that have responsibility
 for the investigation and remediation of contaminated sites.  Currently, the waste site cleanup program is working
 on issues surrounding the use of innovative site characterization and remediation technologies within state
 programs. More information on NEWMOA's efforts can be found at
 http://www. newmoa. org/Newmoa/htdocs/cleanup/.

 Interstate Technology Regulatory Council (TTRC)

 ITRC is a state-led coalition working together with industry and stakeholders to achieve regulatory acceptance of
 environmental technologies. ITRC consists of 40 states, the District of Columbia, multiple federal partners,
 industry participants, and other stakeholders, cooperating to break down barriers and reduce compliance costs,
 making it easier to use new technologies, and helping states maximize resources. ITRC teams have developed
 guidance on accelerated site characterization including documents such as the ITRC/ASTM Partnership for
 Accelerated Site Characterization Summary Report. In addition, ITRC has formed a Sampling, Characterization,
 and Monitoring Team. The team is examining not only innovative sampling and monitoring technologies, but
 also innovative approaches like the Triad approach and helping them gain acceptance from state agencies.  For
 more information on the ITRC, please visit www.itrcweb.org.
3.2   PROCUREMENT ISSUES



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

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

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

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

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

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

January 2000, brownfieldstsc.ors/publications _index.htm).



Among the essential procurement issues related to use of the Triad approach are:
      The need to ensure that solicitations and requests for proposals (RFP) allow flexibility necessary to
      use field methods and rapid sampling and to allow for use of technologies and approaches that can
      support dynamic decision-making about a range of measurements during implementation of the
      project.

      The need to require and budget for adequate systematic planning in the RFP and the project work
      plan.
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      The need to match the expertise of available contractors (for example, those likely to bid on the job)
      and their ability to employ field tools with the required level of knowledge and understanding.

      The need to seek expertise in reviewing proposals and interviewing service providers to determine
      if the proposed approach will yield data required for specific tasks. This consideration becomes
      particularly important when an RFP  allows flexibility in approach, numbers of samples, analytical
      strategies, and so forth. Simple comparisons of costs and schedules may not be sufficient.  Hiring
      someone to conduct the planning and to review a technical approach separately from and prior to
      hiring a contractor to  do the field work may be a way to simplify the review process.
                      To Learn More about Innovative Procurement Strategies
   The former Reitz #4 property in Central City, Pennsylvania was used to support coal mining operations in the
   surrounding area and includes a motor/car repair shop, a powerhouse, and a machine shop.  Potential concerns
   at the site included the presence of transformers, which may contain PCBs, drums and containers of inks and
   thinners, and basements full of potentially-contaminated water. The BTSC helped the city with using the Triad
   approach through the development of a statement of work based on a dynamic work plan strategy for
   conducting a Phase II investigation.  The city incorporated some elements of the Triad into  a RFP. The RFP
   and proposed statement of work can be found at brownfieldstsc. ors.

   The City of Trenton,  along with multiple partners including New Jersey Institute of Technology, EPA Region
   2, EPA's BTSC, New Jersey DEP, and USAGE, acquired services to perform a site investigation/remedial
   investigation at 60-acre site that formerly had been used for industrial purposes. The property consists of
   multiple brownfields  sites contaminated with numerous substances including heavy metals, PAHs, and PCBs.
   The entire area will be incorporated into the planned Assunpink Creek Park and Greenway. The objective of
   the project was to use the concepts of the Triad approach including use of field analytical technologies to
   achieve the goals of the investigation and define the level of remediation necessary to implement the planned
   reuse. This project involved coordination between Federal and state partners regarding a variety of technology-
   related items including use of field analytical technologies. More information on this site, including the RFP,
   can be found at brownfieldstsc. ors.
3.3   MANAGEMENT TOOLS
Use of innovative technologies and approaches can save time and money, and project managers can use

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

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

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

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

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

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

becomes known, the user should continually re-assess whether the assumptions of the chosen statistical
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model are still valid.  In addition, there must be a clear understanding of what decisions are going to be
made and what role statistics will play in those decisions (i.e., what data are needed to guide those
decisions and what variability and distinct contaminant populations the  CSM predicts). Several publicly-
available EPA-sponsored software packages currently are available that can help in managing projects
that use the Triad.  Additional information is also provided in Appendix C. Examples of software
packages include:

•     Spatial Analysis Decision Assistance (SADA) - The University of Tennessee, Knoxville, with
      support from EPA and DOE, and in collaboration with Oak Ridge National Laboratory, has
      developed a software program that integrates visualization, geospatial analysis, statistical analysis,
      human health risk assessment, cost-effective analysis, sampling design, and decision analysis
      (www. tiem. utk. edu/~sada/). SADA is free software that incorporates tools from environmental
      assessment fields into an effective problem solving environment.  These tools include integrated
      modules for visualization, geospatial analysis, statistical analysis, human health risk assessment,
      ecological risk assessment, cost/benefit analysis, sampling design, and decision analysis. The
      capabilities of SADA can be used independently or collectively to address site-specific concerns
      when characterizing a contaminated site, assessing risk, determining the location of future samples,
      and when designing remedial action. For information on training sessions, email
      sada(ff),tiem. utk. dcu. Question and user support can be obtained by sending a blank email to
      sadusers-subcribe(q),yahoosroups. com.

      U.S. EPA Field Environmental, Decision Support (FIELDS) - EPA Region 5 developed the
      FIELDS system which combines geographic information systems (GIS), global positioning systems
      (GPS), database analysis, and imaging technologies to identify, assess, communicate, and help
      solve environmental problems (www.epa.gov/region5 fields/). The FIELDS system is a set of
      software modules designed to simplify sophisticated site and contamination analysis. Each module
      is a self-contained unit that can be applied to a variety of scenarios.  When used together, either
      working through the FIELDS process, or being applied according to a different schedule, the
      modules offer unprecedented power and efficiency in the characterization, analysis, and cleanup of
      environmental contamination. FIELDS has been used at many brownfields sites supported by the
      BTSC in an effort to facilitate the planning process.  Information  about training sessions on
      FIELDS can be found at the website referenced above.
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     U.S. DOE Pacific Northwest National Laboratory Visual Sampling Plan (VSP) - VSP provides
     statistical solutions to sampling design to help users decide where samples should be collected and
     how many are needed (h ftp://dqo.pnl. gov/vsp/).  The purpose of VSP is to provide simple,
     defensible tools for defining an optimal, technically defensible sampling scheme for
     characterization. VSP is applicable for any two-dimensional sampling plan including surface soil,
     building surfaces, water bodies, or other similar applications.  VSP development has been partially
     supported by the DOE's National Analytical Management Program (NAMP) and is presently a joint
     effort between Pacific Northwest National Laboratory (PNNL) (-www.pnl.gov) and Advanced
     Infrastructure Management Technologies (AIMTech) - Grand Junction, Colorado.

     U.S. EPA Removal Cost Management System (RCMS) 2000, Version 1.2 - RCMS is a cost
     accounting and reporting system used on removal sites to track costs and usage  of personnel,
     equipment, subcontractors, and purchases.  Modules include:  cost tracking, cost projection,  and
     EPA invoicing.  To order RCMS, please visit www.ert.org.

     U.S. EPA Scribe (Environmental Field Data Capture), V2.2 - A Windows software that  can be
     used to assist in the management of environmental sampling data for soil, water, groundwater, air,
     and biota. Outputs include sample labels, assorted field data sheets and reports, and chain of
     custody generation.  This software currently is being updated by EPA's Environmental Response
     Team (ERT). For more information, please call ERT's Software Support at (800) 999-6990.

     Center for Subsurface Modeling Support (CSMoS) - CSMoS provides public domain
     ground-water and vadose zone modeling software and services to public agencies and private
     companies throughout the nation.  CSMoS is  located in Ada, Oklahoma at the National Risk
     Management Research Laboratory (NRMRL), EPA's Center for Ground-Water Research.  The
     primary aims of CSMoS are to provide direct technical support to EPA and state decision-makers in
     subsurface model applications and to manage and support the ground-water models and databases
     resulting from the research at NRMRL. For more information on CSMoS, please visit
     http://www.epa.gov/ahaazvuc/csmos.html.

     Center for Exposure Assessment Modeling (CEAM) - CEAM was established to meet the
     scientific and technical exposure assessment needs of EPA as well as state environmental and
     resource management agencies. CEAM provides proven predictive exposure assessment
     techniques for aquatic, terrestrial,  and multimedia pathways for organic chemicals and metals.
     More information can be found at http://www.epa.gov/ceampubl/.
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                                        4.0  SUMMARY

The concepts of the Triad approach are not new. From the early 1980s on, DOE articulated many of the
core concepts of the Triad approach as Expedited Site Characterization (ESC). In addition, DOE linked
the use of a dynamic work plan strategy with systematic planning with the intent of speeding up
Superfund site investigations and feasibility studies at DOE sites in an approach called SAFER
(Streamlined Approach for Environmental Restoration). The USAGE began institutionalizing an
integrated approach to systematic planning under the name "Technical Project Planning (TPP) Process".
For more information on the TPP Process, please visit
http://hq. environmental.usace.army.mil/tools/tpp/brochure/pdf).  Although it does not address dynamic
work plan strategies and the use of real-time measurements directly, the TPP engineering manual stresses
the importance of a multi-disciplinary team that performs "comprehensive and systematic planning that
will accelerate progress to site closeout within all project constraints." In 1996-1997, EPA Region 1 and
Tufts University coordinated with the U.S.  Air Force to conduct a demonstration of a dynamic site
investigation using real-time results generated by a mobile laboratory to delineate residential soil
contamination at Hanscom Air Force Base (Innovations in Site Characterization Case Study: Hanscom
Air Force Base, Operable Unit 1, September 1998, EPA 542-R-98-006,
http://www.epa.gov/swertiol/download/char/hafbcs2.pdf}. The project showed that innovative
technologies combined with an adaptive sampling and analysis program could drastically reduce the time
and cost, while increasing the confidence of site decisions. Argonne National Laboratory's
Environmental Assessment Division (BAD) refers to the same basic concepts as Adaptive Sampling and
Analysis Programs (ASAP) to expedite data collection in support of hazardous waste site characterization
and remediation. ASAPs emphasize "real-time" data collection and field-based decision-making, using
dynamic work plan strategies.  The Triad approach takes these same concepts further by explicitly making
the management of decision uncertainty the linchpin  for systematic planning, while relying on innovative
technologies and dynamic/adaptive work planning as the only mechanisms to cost-effectively manage
data uncertainty and build accurate CSMs.

The Triad approach is a common sense approach that has been successfully applied by other Federal,
state, local, and private organizations. Similarly, the  dynamic nature of the Triad approach allows
decision-makers to focus on the best strategy  for conducting environmental measurements that is flexible
and meets site needs. Use of systematic planning has continually resulted in lower overall project costs.
Use of dynamic work plan strategies can reduce or eliminate the need for multiple mobilizations on a site
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to reach closeout. For brownfields sites, where decision-making is so closely tied to economic constraints
and public acceptance, increased information value obtained using real-time measurement technologies
collaboratively with definitive fixed laboratory methods for data collection will provide stakeholders with
the confidence they need at a reduced cost.  Reducing project costs and schedules to obtain closure means
that more dormant or abandoned sites may become economically viable for redevelopment.

The Triad approach can be implemented at sites by taking advantage of the key elements and steps
outlined in this primer.   In addition, the documents referenced throughout this primer and the resources
identified in Appendix C provide valuable information on the application of the Triad approach at various
sites and describe various technologies that can be used to characterize or remediate a site. By using
these approaches and technologies at brownfields and other redevelopment sites, site owners and
environmental professionals can streamline the effort involved with bringing a contaminated site back
into productive use.
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                                         APPENDIX A
                      FREQUENTLY ASKED QUESTIONS (FAQ) WHEN
                 DESIGNING A PROGRAM USING THE TRIAD APPROACH

Question 1:    What is the Triad approach ?

Answer 1:      The Triad approach consists of using systematic project planning, dynamic work plan
               strategies, and real-time measurement technologies, and is applicable to contaminated site
               investigations and cleanup. It is a work strategy framework for economically managing
               project decision uncertainties by drawing on the technical knowledge and experience
               gained over the past 20 to 30 years of hazardous site cleanup.  The Triad  approach
               proactively exploits new characterization and treatment tools, using work strategies
               developed by innovative and successful site professionals. An important product of the
               Triad approach is a conceptual site model (CSM) accurate enough to support correct
               project decisions.

Question 2:    Who should use the Triad approach ?

Answer 2:      Project managers and their technical staff responsible for cleanups at hazardous waste
               sites should consider using the Triad approach.

Question 3:    Wh at is systematic project plann ing ?

Answer 3:      Systematic project planning is the most important and often used element of the Triad
               approach.  Systematic planning is a common sense approach to identifying the decisions
               that need to be made to reach project goals.  Once it is clear what decisions are driving
               the project, systematic planning identifies the inputs needed to feed those decisions and
               project constraints (budgetary, regulatory, legal, scientific, etc.). Inputs to decisions
               about contaminated sites usually  involve some kind of environmental data, so systematic
               planning also involves developing the technical strategies used to generate and interpret
               the data feeding the decision-making process.  Up-front systematic planning should
               involve all parties, including stakeholders, and a multi-disciplinary technical team.

Question 4:    What is a dynamic work plan ?

Answer 4:      A dynamic work plan is a work plan that is written to be flexible so that the course of site
               work can adapt to new information as it is being acquired in real-time.  Dynamic work
               plan strategies  are the second element of the Triad approach. These types of strategies
               use real-time decision-making in the field to limit the number of mobilizations back to
               the field to fill  data gaps or take remedial actions.  This approach can reduce project costs
               and the time needed to reach project closeout.  Use of a dynamic work  plan strategy and
               related management strategies can drastically improve the economics that drive the reuse
               potential for brownfields properties.

Question 5:    Wh at are field-based measurement techn ologies ?

Answer 5:      Field-based measurement technologies provide analytical results on site, and they are a
               primary means of providing measurements in real-time, although by no means are they
               the only way. Note that "real-time measurement technologies" (NOT "field-based
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               measurements") constitutes the third leg of the Triad. Field-based technologies are but
               one option to provide real-time turnaround of results. Field-based measurement
               technologies include mobile laboratories equipped with instrumentation ranging from
               state-of-the-art sophisticated instrumentation to "simple" test kits. Field-based
               measurement technologies also include using a test kit under a tent, taking XRF
               measurements on the ground or through a plastic bag, performing fence-line monitoring
               with "high tech" ultraviolet (UV) or infrared (IR) spectroscopy instrumentation, and
               taking a pH or turbidity measurement in a well. Modern field-based measurement
               technologies now run the gamut from highly accurate analytical instrumentation to
               "low-tech" screening analyses. The quality of data generated in the field cannot be
               judged based on the location where the results were generated, but according to the data's
               ability to support the intended decisions, which includes sufficient quality control
               documentation to ensure that data are of known quality.

Questions 6:   What are real-time measurement technologies?

Answer 6:      "Real-time measurement technologies" compose the third leg of the Triad approach.  The
               term includes any mechanism that supports turning around data results within the  time
               frame needed to support real-time decision-making. ("Real-time decision-making" refers
               to updating the CSM with new information and adapting subsequent site work to that
               updated knowledge while the field crew remains in the field.) The mechanisms used to
               provide real-time measurements include rapid turnaround from a fixed laboratory; on-site
               measurement in a mobile lab, or in the back of a truck, or in situ; and the hardware and
               software used to rapidly process instrument signals, store and retrieve analytical results,
               evaluate quality control, perform statistical analysis, display or map data, and share data
               with colleagues, regulators, and stakeholders back in the office or across the country.

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

Answer 7:      Frequently, the most cost-effective option for generating real-time data is to use
               field-based measurement technologies. Another advantage of using screening methods in
               fixed laboratories and field analytical methods is that they can provide the higher
               numbers of samples needed to manage the uncertainties associated with sample
               representativeness. Whatever measurement techniques are used, data of known quality
               must be produced using a technically sound quality control program.
               "Mixing-and-matching" several analytical methods (i.e., fixed and field methods)
               according to their various strengths is usually the most economical way to generate data
               sets that are effective for making project decisions because sampling and analytical
               uncertainties have been managed commensurate with the desired or negotiated project
               outcome.  For brownfields sites, increased information content to support decision-
               making is essential. Making sound decisions will ensure long-term liability is reduced
               within the context of the reuse scenario, including residential, industrial, or recreational
               scenarios.

Question 8:    When should the Triad be applied?

Answer 8:      Systematic project planning should always be applied when tackling problems at
               hazardous waste sites. Developing a CSM accurate enough to support correct decisions
               should be a goal for every project. Dynamic work plan strategies are best used early and
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               throughout the investigative portions of a project when physical and chemical conditions
               at a site are being defined.  They are particularly useful during cleanup actions when the
               scale of decision-making is being redefined and economic constraints are of paramount
               concern.  Real-time measurements can reap benefits throughout all portions of the
               cleanup process from investigation through long-term monitoring and verification of the
               effectiveness of risk management cleanup strategies.

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

Answer 9:     EPA's Technology Innovation Office (TIO), Superfund, and many other organizations
               are partnering to promote the use of the Triad approach.  Planning, technological, and
               vendor resources can be identified through the TIO web site at http://cluin.org.  The
               BTSC also provides related information at brownfieldstsc. org.

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

Answer 10:    The Triad approach can be used to alleviate the need for deed restrictions or conditions-
               on-closure letters in some cases. Lending and insurance requirements are generally
               driven by policy. The Triad approach can be used to reduce the perception of risk
               because more direct, objective evidence and hard data can be developed during early site
               evaluations.  The Triad approach can improve the confidence with which environmental
               decisions are made by targeting the primary sources of uncertainty that increase the
               perception of risk.

Question 11:   What is a dynamic work plan strategy and what planning documents describe the
               approach to be used?

Answer 11:    A dynamic work plan strategy is a flexible, adaptive work strategy that rapidly reaches
               project objectives by allowing real-time feedback (i.e., data) to guide selection of the
               alternative options of a pre-approved decision tree.  A common theme is that the number
               and placement of samples is not fixed before field work begins, but is decided in the field
               (according to pre-established decision logic) based  on site conditions. During systematic
               planning, the core technical team works with stakeholders to agree upon a plan of action.
               The flow of activities is designed to work through as many branch points of the decision
               tree as possible during a single field mobilization. The necessary details for
               implementation are then translated into concisely worded, streamlined planning
               documents such  as a work  plan, field sampling and analysis plan, or quality assurance
               project plan.

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

Answer 12:    Dynamic work plan strategies are not always appropriate. They involve development of
               decision logic about appropriatenss and validity of site-specific decisions.  Programs that
               do not provide clearly-identified responsibilities or authority to implement decision logic
               may lead to relatively slower progress on implementing a dynamic work plan.  In
               addition,  site conditions or level of maturity (i.e., long-term monitoring or background
               type of evaluations) may not warrant the need for a dynamic approach. However, many
               projects from the initial investigation through cleanup can benefit from the use of a
               dynamic work plan strategy for some  or all of the site activities.
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Question 13:   What contingencies are necessary to assure that project progress is not hampered?

Answer 13:    Practical and analytical contingencies should be anticipated and addressed during project
               planning.  For example, if direct-push rig refusal is expected at a specific depth, then a rig
               with an auger attachment might be considered. If analytical results for a particular soil
               management area are unclear, then perhaps more samples should be budgeted for in case
               they are required to verify if the area should be considered clean.  A practical approach
               using the expertise from the project team and pool of stakeholders should be used to
               identify potential contingencies.

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

Answer 14:    Early in an investigation, senior staff should go to the field to trouble-shoot problems
               encountered and assure that documentation is being adequately prepared.  Similarly,
               senior staff should also visit the fixed laboratory (if one is being used) before samples are
               sent.  Closeout audits by senior staff also are recommended; adequately prepared
               electronic and hardcopy records will allow a project to seamlessly reach closeout.

Question 15:   How can primary decision-makers assure the quality of decisions made in the field and
               justify changes made in initial sampling plans?

Answer 15:    Through the development of well designed decision trees and standard operating
               procedures for identifying the need for changes in decision logic,  a project manager and
               technical lead can identify and  incorporate changes easily. Addendum development
               protocols and triggers designed into QA review procedures help ensure that decisions are
               based on sound science and that problems are identified and addressed early in the
               process. Decision trees should be communicated along with the proposed approach to
               stakeholders before a project is implemented. Options should be identified and public
               comment addressed as appropriate before project startup.  Periodic review of field
               activities before and during implementation should be conducted  as another type of
               safety check.

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

Answer 16:    The answer to this question should not be seen as "either-or." It will depend heavily on
               the nature of the contaminants of concern  (COC), the type of decision(s) being made, and
               the sampling and analytical uncertainties that need to be managed in order to make the
               decision(s).  For example, some XRF units are capable of analyzing for the presence of a
               wide variety of metals in the field.  However, XRF reporting limits are typically in the
               parts per million (ppm) range.  Therefore, if decisions will be based on metals
               concentrations in the parts per billion (ppb) range, fixed-laboratory analysis using
               inductively coupled plasma spectrometry (ICP-OES)  may be the preferred option to
               produce ppb concentration data and manage analytical uncertainty.  However, the
               cheaper, faster XRF technique may be useful to characterize the variability of
               contaminant concentrations, and detect "hotspots" or  other spatial patterns of distinct
               populations that could compromise the representativeness of the data set. The XRF can
               be used to manage sampling uncertainty, while samples established to be representative
               of the decision are sent for ICP analysis.  The selectivity required to meet project needs
               also drives instrument selection. For example, if a decision can be based on total
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               polychlorinated biphenyls (PCB) concentrations, immunoassay results may be sufficient.
               Decisions requiring homolog or congener-specific PCB analyses will require much more
               rigorous methods than field kits can provide. However, as with the XRF example, the
               high sampling density provided by the immunoassay method may be critical to
               establishing the representativeness of data provided by expensive fixed laboratory
               methods.

               It is prudent to perform a cost-benefit analysis prior to deciding what mix of field- and/or
               fixed-laboratory analyses should be used. While instrument rental costs can be low
               relative to fixed-laboratory unit costs, additional personnel are also required in the field
               to conduct the analyses. In general, as the number of analyses required to support a
               dynamic work plan and manage sampling uncertainty increases, field-based analysis
               becomes generally  more appealing. As mentioned previously, development of
               collaborative data sets to optimize a sampling and analytical strategy will improve the
               efficiency of the characterization approach.

               The project may also consider running a non-standard method in a fixed laboratory
               setting as opposed to running the method in the field.  Sometimes logistically and
               financially this approach makes more sense and still provides the project team with
               timely data at a lower cost.

Question 17:   How can analytical costs be managed when using field-based technologies?

Answer 17:    When using field-based or real-time measurement strategies, project technical leads
               should combine data collection, analysis, review and reporting into unit costs that can be
               managed on a daily basis. In this way, as a project grows or shrinks costs can be
               managed.  Identifying and funding contingencies early in a project can help project
               managers avoid unnecessary delays.

Question 18:   How can available technologies be identified for use?

Answer 18:    EPA identifies several site characterization and monitoring technologies through web
               sites for Field-based Analytical Technology Encyclopedia (FATE)  (http://fate.cluin. org/],
               EPA Environmental Technology Verification (ETV) (http://www. epa.gov/etv/). EPA
               Superfund Innovative Technology Evaluation (SITE) Program
               (http://www. epa.gov/ORD/SITE), and the Interstate Technology Regulatory Council
               (http://www.itrcweb. org).  It is also important for the project team to seek out vendor
               assistance, but only with the assistance of the team's own technical experts. Hazardous
               Substances Technical Liaisons (http://www.epa.gov/osp/features/factsheets.htm) also are
               available for technical support.

Question 19:   What documentation will assure that the results obtained are legally and technically
               defensible?

Answer 19:    Documentation must be sufficient to reproduce a result and to assure stakeholders that
               "good scientific practices" were adhered to during the project. The method used should
               have been peer reviewed or be sufficiently convincing that the results can stand on their
               own merit.  There must be evidence that the samples were representative of the matrix
               population for the decision being defended. For environmental matrices which tend to be
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                highly heterogeneous with great variability in contaminant concentration from place to
                place, demonstrating data representativeness has been difficult because of the relatively
                higher cost for analysis of a larger number of samples. With the wider availability of
                field analytical methods and screening methods for use in fixed-based laboratories (such
                as dioxin screening methods), it is now possible to analyze enough samples to ensure data
                representativeness. (Also refer to paper by Barton Simmons "Using Field Methods -
                Defensibility of Field Data" available at www.cluin.ors/.
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                                        APPENDIX B
                                    LIST OF ACRONYMS

AIMTech     Advanced Infrastructure Management Technologies

ASAP        Adaptive Sampling and Analysis Program

BTSC        Brownfields Technology Support Center

COC         Contaminants of concern

CSM         Conceptual site model

DOE         U. S. Department of Energy

EAD         Argonne National Laboratory Environmental Assessment Division

EPA         U.S. Environmental Protection Agency

ESC          Expedited site characterization

FAQ         Frequently asked questions

FIELDS      Field EnvironmentaL Decision Support

GC           Gas chromatography

GIS          Geographic information systems

GPS          Global positioning systems

ICP          Inductively coupled plasma

IR            Infrared

LDR         Land disposal restriction

NAMP        National Analytical Management Program

NAWQA     National Water-Quality Assessment

ORD         EPA Office of Research and Development

OSWER      EPA Office of Solid Waste and Emergency Response

PAH         Polycyclic aromatic hydrocarbon

PCB          Polychlorinated biphenyls
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PNNL         Pacific Northwest National Laboratory

RCMS         Removal Cost Management System

RFP           Request for proposal

RI             Remedial investigation

SADA         Spatial Analysis Decision Assistance

SAFER        Streamlined Approach for Environmental Restoration

SITE          Superfund Innovative Technology Evaluation

SOW          Statement of work

TCLP         Toxicity Characteristic Leaching Procedures

TIO           EPA Technology Innovation Office

TPH           Total petroleum hydrocarbons

TPP           Technical project planning

US ACE        U.S. Army Corps of Engineers

USGS         U.S. Geological Survey

UV            Ultraviolet

VOC          Volatile organic compound

VSP           Visual Sampling Plan

XRF           X-ray fluorescence
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                                         APPENDIX C
                                    LIST OF RESOURCES

Brownfields Technology Support Center (http://brownfieldstsc. org) - EPA established the Brownfields
Technology Support Center (BTSC) to ensure that brownfields decision-makers are aware of the full
range of technologies available for conducting site assessments and cleanup, and can make informed
decisions about their sites.  The center can help decision-makers evaluate strategies to streamline the site
assessment and cleanup process, identify and review information about complex technology options,
evaluate contractor capabilities and recommendations, explain complex technologies to communities, and
plan technology demonstrations. The center is coordinated through EPA's Technology Innovation Office
(TIO) and EPA's Office of Research and Development. Localities can submit requests for assistance
directly through their EPA Regional Brownfields Coordinators; online at brownfieldstsc. org; or by calling
toll free 1-877-838-7220.  For more information about the program, contact Dan Powell of EPA TIO at
703-603-7196 or powell. dan(q),epa. gov.

Hazardous Waste Cleanup Information (CLU-IN) Internet site (http://cluin. org) - The CLU-IN site
provides information about innovative treatment technologies and site characterization technologies to the
hazardous waste remediation community.  It describes programs, organizations, publications, and other
tools for Federal and state personnel, consulting engineers, technology developers and vendors,
remediation contractors, researchers, community groups, and individual citizens.

CLU-IN Case Studies (http://cluin. org/charl. cfm) - As part of a section on Site Characterization, the
CLU-IN web site provides selected case studies which involved use of field analytical technologies.
These include projects at the Wenatchee Tree Fruit, Oak Ridge Drum Disposal, and Hanscom Air Force
Base sites.

Specific resources available through CLU-IN that provide useful information about the Triad approach
include:

      Innovations in Site Characterization Case Study: Site Cleanup of the Wenatchee Tree Fruit
      Test Pilot Site Using a Dynamic Work Plan - This case study is designed to provide cost and
      performance information for innovative tools that support less costly and more representative site
      characterization.

      Using the Triad Approach to Improve the Cost-Effectiveness of Hazardous Waste Site
      Cleanups - This paper describes the overall strategy of using systematic project planning, dynamic
      work plans and real-time measurement technologies to speed cost-effective investigations and
      cleanups, while maintaining or improving the defensibility of site decision-making.

      Improving Sampling, Analysis, and Data Management  for Site Investigation and Cleanup
      Fact Sheet (EPA 542-F-01-030a) - This fact sheet discusses the streamlined approaches to
      sampling, analysis, and data management activities conducted during site assessment,
      characterization, and cleanup.  This position reflects the growing trend towards using smarter,
      faster, and better technologies and work strategies.

      Resources for Strategic Site Investigation and Monitoring (EPA 542-F-01-030b) - This
      document discusses EPA efforts, in concert with other federal agencies and state organizations, in
      accelerating the development of policies and information to support Strategic Investigation and
      Monitoring activities at hazardous waste sites. The educational, training, and guidance resources
      described in this fact sheet either already exist or are under development to support project
      managers seeking to apply these approaches.
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EPA Field Analytical Technologies Encyclopedia (http://fate.cluin. org) - FATE is an online
encyclopedia of information about technologies that can be used in the field to characterize contaminated
soil and groundwater, monitor the progress of remedial efforts, and in some cases, for confirmation
sampling and analysis for site closeout.

EPA Remediation And Characterization Innovative Technologies (REACHIT)
(http://www. epareachit. org/) - EPA REACHIT is a system that lets environmental professionals search,
view, download, and print information about innovative remediation and characterization technologies.
The site uses information submitted by technology service providers about remediation and
characterization technologies and information from EPA,  Department of Defense (DoD), Department of
Energy (DOE), and state project managers about sites at which innovative technologies are being
deployed. These sources together provide up-to-date information about technologies that can be used to
characterize or remediate a site, sites at which those technologies are being used, and the service
providers that offer them.

EPA Dynamic Field Activities Internet Site (http://www. epa.gov/superfund/programs/dfa/index.htm)
- This internet site provides information on the draft guidance for dynamic field activities and DFA case
studies.  For example, one case study provides cost and performance information for a soil and
groundwater characterization at Hanscom Air Force Base. The  site also provides additional information
on systematic planning and dynamic work plans.

EPA ORD's Office of Science Policy Hazardous Substances Technical Liaison Program
(http://www.epa.gov/osp/features/factsheets.htm) - The program was created jointly by EPA ORD, EPA
OSWER, and the regional offices to expand the technical  support available to regional staff.

Road Map to Understanding Innovative Technology Options for Brownfields Investigation and
Cleanup, Third Edition (http://brownfieldstsc. org/publications_index. htm) - The Road Map identifies
potential technology options available at each of the basic phases involved in the characterization and
cleanup of brownfields sites  and connects those steps with available resources.  The third edition of the
Road Map has been expanded significantly to include new and updated resources, one-page "spotlights,"
and an index of more than 150 resources.  Appendices in the Road Map include a list of common
contaminants found at typical brownfields sites, a detailed guide to common environmental terms and
acronyms, and a list of state and EPA points of contact.

EPA's Environmental Technology Verification Program (www. epa. gov/etv/) - EPA's ETV Program
develops testing protocols and verifies the performance of innovative technologies that have the potential
to improve protection of human health and the environment.  ETV was created to accelerate the entrance
of new technologies into the domestic and international marketplace.

Case Studies

Case studies are provided in  several of the resources described above, as well as on related web sites such
as FRTR, SCRD, ITRC, and RTDF.

Federal Remediation Technologies Roundtable (http://www.frtr.gov) - The Federal Remediation
Technologies Roundtable (FRTR) provides more than 300 case studies concerning use of remedial
technologies in site cleanup,  as well as more than 100 case studies about site characterization and
monitoring technologies, and 7 reports about optimization of long-term monitoring.  The FRTR reports
focus on the  cost and performance for use of these technologies, and cover a wide range of technology
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types and contaminants.  Recent additions to the FRTR collection include reports addressing cleanup of
groundwater using in situ technologies such as bioremediation, surfactant flushing, chemical oxidation,
thermal treatment, permeable reactive barriers, phytoremediation, air sparging, and in-well air stripping.

State Coalition for Remediation of Dry Cleaners (http://www. drycleancoalition. org) - The State
Coalition for Remediation of Drycleaners (SCRD) consists of representatives of states with established
drycleaner remediation programs, including Alabama, Florida, Illinois, Kansas, Minnesota, Missouri,
North Carolina, Oregon, South Carolina, Tennessee, and Wisconsin. The SCRD provides more than 60
case studies covering a diverse set of innovative treatment technologies used at dry cleaner sites.

Interstate Technology Regulatory Council (http://www.itrcweb. org) - The Interstate Technology
Regulatory Council (ITRC) is a state-led coalition working together with industry and stakeholders to
achieve regulatory acceptance of environmental technologies, and consists of more than 35 states, the
District of Columbia, multiple federal partners, industry participants, and other stakeholders.  The ITRC
has prepared more than 15 guidance documents on technical topics, many of which include selected case
studies.

Remediation Technology Development Forum (http://www.rtdf. org) - The Remediation Technology
Development Forum (RTDF) is a public-private partnership to undertake research, development,
demonstration, and evaluation efforts focused on finding innovative solutions to high priority problems.
It consists of six action teams, covering subjects such as bioremediation, NAPLs, permeable reactive
barriers, phytoremediation, and sediments. These action teams publish materials including information
about specific sites where technologies have been applied.

EPA Superfund Innovative Technology Evaluation (SITE) Program
(http://www.eva.sov/ORD/SITE) - The SITE Program was established by EPA's OSWER and the ORD
in response to the 1986 Superfund Amendments and Reauthorization Act, which recognized a need for an
"Alternative or Innovative Treatment Technology Research and Demonstration Program." The SITE
Demonstration Program encourages the development and implementation of innovative treatment
technologies for hazardous waste site remediation, monitoring, and measurement.  In the SITE
Demonstration Program, technologies are field-tested on hazardous waste materials. Engineering and
cost data are gathered on the innovative technology so that potential users can assess the technology's
applicability to a particular site.

U.S. EPA Hazardous Substance Research Centers (www.jhu. edu/hsrc, www.mhsrc. org,
http://www. toscprogram. org/, www. toscprogram. org, http://wrhsrc. orst. edu/) - In 2001, EPA
established five new university-based HSRCs affiliated with 22 universities.  The Centers address
concerns about hazardous substances in the environment by conducting basic and  applied research, and
providing technology transfer and community outreach. The Centers work on the remediation and
redevelopment of brownfields and Superfund  sites.

Training

Classroom (http://trainex.org) - In partnership with the ITRC,  TIO provides a range of training
information to EPA, other federal agency, state, tribal, and local staff involved in hazardous waste
management and remediation. Trainex.org includes training schedules for deliveries of many courses,
both classroom and Internet-based. Training Coordinators, On-Scene Coordinators (OSC), Remedial
Project Managers (RPM), Permit Writers, Corrective Action Managers, Site Assessment Managers
(SAM), enforcement staff, Community Involvement Coordinators (CIC), state program managers, and
others will find training courses and information directly targeted to their needs.
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Internet seminars (http://cluin. org/studio) - CLU-IN's ongoing series of Internet Seminars are web-
based slide presentations with a companion audio portion. TIO provides two options for accessing the
audio portion of the seminar, by phone line or streaming audio simulcast.  More information and
registration for all Internet Seminars is available by selecting the individual seminar listed on the site.
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                                         APPENDIX D
                   DESCRIPTIONS OF COMMONLY USED FIELD-BASED
                      SAMPLING AND ANALYTICAL TECHNOLOGIES

Direct-Push Sampling - Direct-push sampling platforms have gained widespread acceptance in the
environmental industry over the past decade because of their versatility, relatively low cost, and mobility.
As opposed to drilling techniques in which soil is removed and a borehole is produced, direct-push units
use hydraulic pressure to advance sampling devices and geotechnical and analytical sensors into the
subsurface. The weight of the truck in combination with a hydraulic ram or hammer is used to "push" the
tool string into the ground. With this, no soil is removed, and only a very small borehole is created.  The
two major classes of direct-push platforms are cone penetrometer (CPT) and rotary hammer systems.
While "CPT" technically refers only to the geotechnical cone penetrometer instruments advanced by
these large vehicles, the vehicles themselves have come to be known by this designation.  The distinction
between these units is that CPT advance the tool string by applying a hydraulic ram against the weight or
mass of the vehicle alone, while rotary hammer units add a hydraulic hammer to the hydraulic ram to
compensate for their lower mass.  These platforms share the  same principle of operation, similar tools,
and a number of advantages and limitations.  They differ in scale, application, and to some extent the
types of instruments and tools that have been developed for each. For these reasons, CPT and rotary
hammer platforms fill different niches in the environmental field.

Gas Chromatography - Gas chromatography (GC) analysis is a widely used technique for field-based
analysis.  Analysis of organic compounds is possible for a variety of matrices such as water, soil, soil gas,
and ambient air.  Typical settings  include:  (1) site characterization, (2) stationary source testing and
monitoring, (3) hazardous waste sites for determining personal protective equipment (PPE) level, (4)
fence line monitoring during removal or remediation activities, and (5) emergency response testing.  GC
analysis with photoionization detection has been used extensively to characterize and remediate sites
contaminated with VOCs. Likewise, gas chromatographs coupled with an electron capture detector are
used for analysis on sites contaminated with chlorinated pesticides.  The recent development of truly field
portable quadrupole mass spectrometers now permits GC-mass spectrometry analysis which provides
definitive identification. This instrument and technique is being implemented during emergency response
and counter-terrorism situations that require definitive identification of contaminants in near real-time.

Geophysics - Geophysical surveys are useful for characterization of the geology or hydrogeology of a
site, detection and mapping of contamination, detection of geological conditions favorable for
contaminant migration, and evaluation of past site uses. There are three primary geophysical methods:  in
situ, surface, and borehole. In situ geophysical measurements typically are made by placing a probe or
sensor into the media of interest in such a way that causes minimal disturbance of the media. Surface
geophysical techniques usually result in no significant disturbance of the subsurface media - surface
sensors may be in contact with the ground surface or held above the ground surface.  Borehole
geophysical measurements are made only after a boring has been made into the media of interest. The
sensor itself may not actually contact the walls  of the borehole.

Immunoassay - Immunoassay is a widely-accepted field analytical technology for many organic
contaminants and classes of contaminants (and at least one inorganic contaminant).  Various
immunoassay kits and methods are tailored to specific classes of environmental contaminants.
Immunoassay uses antibodies that have been developed to bind with a target compound or class of
compounds. The technology has been used widely in the environmental field because the antibodies can
be highly specific to the target compound or group of compounds and because the kits are relatively quick
and simple to use. Concentrations of analytes are identified through the use of a sensitive colorimetric
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reaction.  The determination of the target analyte's presence is made by comparing the color developed by
a sample of unknown concentration with the color formed by the standard containing the analyte at a
known concentration.  The concentration of the analyte is determined by the intensity of color in the
sample. The concentration can be estimated roughly by the naked eye or can be determined more
accurately with a photometer or spectrophotometer.

Laser-Induced Fluorescence - Laser-induced fluorescence (LIF) is a method for real-time, in-situ, field
screening of hydrocarbons in undisturbed subsurface soils and groundwater. The technology is intended
to provide highly detailed, qualitative to semiquantitative information about the distribution of subsurface
petroleum contamination. LIF sensors are deployed as part of integrated mobile CPT systems that are
operated by trained technicians. There are currently two major LIF systems available, the Site
Characterization and Analysis Penetrometer System (SCAPS) and Rapid Optical Screening Tool
(ROST™) systems.  The SCAPS LIF system is one of several CPT-mounted sensors developed through a
collaborative effort of the Army, Navy, and Air Force under the Tri-Services Program.  The ROST™
system was developed by Loral Corporation and Dakota Technologies, Inc.  The SCAPS LIF is available
only through the U.S. Army Corps of Engineers and the U.S.  Navy.  ROST™  is available commercially
through Fugro, Inc.

Mass Spectrometry - In the environmental field, mass spectrometers  (MS) are typically used as
detectors for GCs. Because of the increased durability of modern instruments, field gas
chromatographs/mass spectrometers (GC/MS) are capable of the same analyses as fixed laboratory
instruments.

X-Ray Fluorescence - Energy dispersive X-ray fluorescence (XRF) is a method of detecting metals and
other elements, such as arsenic and selenium, in soil, sediment, and water. Some of the primary elements
of environmental concern that XRF can identify are arsenic, barium, cadmium, chromium, copper, lead,
mercury, selenium, silver, and zinc. Field-portable XRF units that run on battery power and use a
radioactive source were developed for use in analysis for lead-based paint and  now are accepted as a
stand-alone technique for lead analysis.  In response to the growing need for field analysis of metals at
hazardous waste sites, many of these field-portable XRF units have been adapted for use in the
environmental field. They provide data in the field that can be used to identify and characterize
contaminated sites and guide remedial work, among other applications.
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