£EPA
United States
Environmental Protection
Agency
Office of Solid Waste and
Emergency Response
(5102G)
EPA-542-F-01-030a
April 2001
www.epa.gov/tio
www.cluin.org
Improving Sampling, Analysis, and Data
Management for Site Investigation and Cleanup
The United States Environmental Protection Agency (EPA) supports the adoption of streamlined
approaches to sampling, analysis, and data management activities conducted during site assessment,
characterization, and cleanup. This position reflects the growing trend towards using smarter, faster,
and better technologies and work strategies. EPA is coordinating with other Federal and State agencies
to educate regulators, practitioners, site owners, and others involved in site cleanup decisions about the
benefits of a streamlined approach. Ultimately, EPA expects to institutionalize these newer approaches
and anticipates that the principles will guide the way data are collected and analyzed for future site
cleanup decisions.
The Approach
The trend towards modernization and stream-
lining relies on a three-pronged or "triad"
approach. It incorporates:
• Systematic planning for all site activities,
ensuring that the end goals for each project are
clearly identified. Once goals are defined,
systematic planning involves charting the most
resource-effective course to reach those end
goals. A team of multi-disciplinary, experienced
technical staff works to translate the project's
goals into realistic technical objectives. The
conceptual site model (CSM) is the planning
tool that organizes what is already known about
the site and helps the team identify what more
must be known to make the decisions that will
achieve the project's goals. The systematic
planning process ties project goals to individual
activities necessary to reach these goals by
The "Triad"
Systematic
Planning
Dynamic
Work Plans
On-Site Measurement Technologies
identifying data gaps in the CSM. The team
then uses the CSM to direct field work and the
gathering of needed information. This process
allows the CSM to evolve and mature as site
work progresses and data gaps are filled. The
CSM is the key organizing tool for:
* Planning site activities,
* Modeling and data interpretation, and
* Communication among the team, the
decision makers, the stakeholders, and
the field personnel.
• The application of a dynamic work plan
guides project teams in making decisions in
the field about how subsequent site activities
will progress. It uses a regulator-approved (as
necessary) decision-tree, and is supported by
the rapid turnaround of data collected, ana-
lyzed, and interpreted in the field. Success of
the "dynamic" approach hinges on the presence
of experienced staff in the field, who are em-
powered to "call the shots" based on the deci-
sion logic developed during the planning stage
and to cope with any unanticipated issues.
Field staff maintain close communication with
regulators or others overseeing the project
during implementation of the dynamic work
plan.
• The use of on-site analytical tools, rapid
sampling platforms (e.g., direct push technolo-
gies), and on-site data interpretation
-------
and management makes dynamic work plans
possible. During the planning process, the
team identifies the type, rigor, and quantity of
data needed to answer the questions raised by
the CSM. Those decisions then guide the
design of sampling regimens and the selection
of analytical tools and methods to focus data
collection on providing relevant information.
Figure 1 illustrates the iterative and interlinked
nature of projects managed using this dynamic
work strategy. The decision rules developed
during systematic planning and built into the
CSM serve as the foundation for evaluating all
proposed and implemented project activities.
Occasionally, decision makers will discover that
the original project objectives cannot be met
due to technical or budgetary constraints, and
pragmatic refinement of the decision rules may
be needed.
Supporting Developments
Faster, cheaper, yet still protective, resolution of
contaminated sites is achievable through the
use of new technologies and the new strategies
those technologies can support. If used cor-
rectly, innovative rapid-turnaround field analyti-
cal and software tools coupled with on-site
decision making can significantly condense a
project's overall budget and lifetime, while
significantly increasing the likelihood that the
gathered data will guide transparent decisions.
Site professionals, policy makers, and the
public should support the flexibility needed to
adopt cost-effective new tools and strategies
into site cleanup practice provided that clearly
defined performance goals are achieved.
The specific developments driving the trend
towards modernization and streamlining
include:
1) Field analytical chemistry has made signifi-
cant advances in scientific rigor and credibil-
ity. Computerization, photonics, miniaturiza-
tion, immunochemistry, and a host of other
advances in the chemical, biological, and
physical science disciplines are contributing
to technology improvements and innovations.
2) Successes with improved strategies such as
Expedited Site Characterization, Accelerated
Site Characterization, Rapid or Adaptive Site
Characterization, and Dynamic Workplanning
are demonstrating just how cost-effective
these strategies can be.
3) Regulatory policies are now focusing more
on achieving tangible end-results. For ex-
ample, EPA and other agencies support
performance-based measurement systems
(PBMS) as a preferred alternative to rigidly
prescribing which analytical tools are used
and how. PBMS improves the cost-effective-
ness and scientific defensibility of environ-
mental analyses by emphasizing the informa-
tion and decision-making value of a represen-
tative data set and by requiring that data
quality be matched to its planned use. PBMS
principles support the use of field analytical
technologies to meet the specified project
needs and decision goals.
4) Better decision-making tools (i.e., computer
software and hardware) are available that
facilitate efficient and effective data manage-
ment, interpretation, and decision making as
the data are collected and analyzed. This
allows mapping and modeling of contami-
nants and maturation of the conceptual site
model on-site. The project team can incorpo-
rate data, modify site characterization activi-
ties, and hone cleanup decisions to minimize
the number of field mobilizations.
5) Modern communication technologies mean
that the field team is no longer isolated from
regulators, technical experts, site owners, and
trustees. New information can be shared
instantly among parties, and regulator buy-in
and technical support can be obtained from
remote locations.
-------
c
E
=
•—
u
o
-^
-
X
—
c
-
-
Ml
Figure 1
Modernizing Site Characterization and Monitoring
Project Initiation
Define Project Objectives,
Assemble Team,
Identify Key Decision Makers,
^ Define Decisions to
be Made
Project Startup
—
u
•a
u
u
a
Pi
c
.S
f.
'J
—
u
I
1
I
I
I
I
t
Draft
Dynamic Work Plan (DWP)
and Sampling Strategy/
Decision Logic
Develop Detailed
Analytical Strategy
Fie Id-base d/Fixed Lab
Refine Project Decision
Logic and Finalize Plans
Client/Regulator
Re vie w/Ap p ro va I
Field Program
Data Validation,
Verification, and
Assessment
Sampling and
Analysis to
Fill Data Gaps
No
Refine Conceptual
Site Model(CSM);
P ro je c t O b je c t ive s Me t'.'
let? J
Yes
Make Decision(s)
and
Prepare Report
bC
.B
<=
-
E
a
0!
^,
Q co
s «
g ^
II
a-W
B
Proceed to Next
Activity (e.g. close site,
cleanup/reuse, etc.)
-------
6) Evolving emphases in environmental pro-
grams [such as Brownfields, State
Voluntary Clean-Up Programs (VCPs), and
Base Realignment and Closure (BRAC) at
military facilities] focus site activities on how
the site will be redeveloped or reused. Flex-
ible cleanup goals [such as risk-based correc-
tive action (RBCA) levels] support faster
return of these sites to productive re-use.
When cleanup and end-use goals are articu-
lated at the start, systematic planning can
ensure a cost-effective work plan that
achieves the desired outcome.
7) Increasing workloads and decreasing bud-
gets have forced regulators and industry to
consider innovative strategies that can in-
crease public confidence and satisfaction by
reducing uncertainties (about any threats the
site may pose) while reducing the time and
costs involved in cleaning up these sites.
Tools for Change
To accomplish change, the remediation industry
and regulators should move towards a more
innovation-friendly system that can produce
defensible site decisions at an affordable cost.
Such a system would:
/ Focus on decision-specific performance
requirements, rather than inflexible adher-
ence to arbitrary policies or "boiler-plate"
procedural checklists that do not add value or
provide beneficial results.
/ Employ transparent and logical reasoning
to define project goals, manage uncertain-
ties, state assumptions, plan site activities,
derive conclusions, and prepare defensible
decisions.
/ Value technical and scientific proficiency, and
understand the need for technical experts
in the scientific, mathematical, and engineer-
ing disciplines required to competently
manage the complex issues of hazardous
waste sites.
/ Require regular continuing education of its
practitioners, especially in rapidly evolving
technology areas.
/ Facilitate application of innovative tech-
nologies and strategies by logically evaluat-
ing project-specific needs, site conditions,
and prior technology performance, with
residual areas of uncertainty being identified
and addressed before use.
/ Reward responsible risk taking by practitio-
ners who do not fear to ask, "why don't we
look into...?" or "what if we tried...?"
Pockets of forward-thinking practitioners are
already successfully using and demonstrating
the validity of the triad approach described
above. This fact sheet and the tools referenced
below are offered to encourage project manag-
ers at-large to adopt this approach into their
routine practice.
EPA, along with a number of other Federal
agencies and state organizations, is acceler-
ating the development of policies and informa-
tion to support site decision makers as they
shift to newer, streamlined approaches. An
array of educational, training, and guidance
resources already exist and additional ones are
under development. Access to these resources
is provided through the http://clu-in.org web site
and are detailed in the companion fact sheet,
Resources for Strategic Site Investigation
and Monitoring, EPA-542-F01-030b.
Updating hazardous waste site practices to
accommodate these new tools and strategies
has broad ramifications for both practice and
policy. Revising institutional and regulatory
barriers will take time and effort. Nevertheless,
the benefits offered by "smarter strategies"
make the effort worthwhile.
------- |