£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.

-------