542B04002
Technical/Regulatory Guidelines
Technical and Regulatory
Guidance for the Triad Approach:
A New Paradigm for Environmental
Project Management
December 2003
Prepared by
The Interstate Technology & Regulatory Council
Sampling, Characterization and Monitoring Team
XX
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ABOUT ITRC
Established in 1995, the Interstate Technology & Regulatory Council (ITRC) is a state-led,
national coalition of personnel from the environmental regulatory agencies of some 40 states and
the District of Columbia; three federal agencies; tribes; and public and industry stakeholders. The
organization is devoted to reducing barriers to, and speeding interstate deployment of, better,
more cost-effective, innovative environmental techniques. ITRC operates as a committee of the
Environmental Research Institute of the States (ERIS), a Section 501(c)(3) public charity that
supports the Environmental Council of the States (ECOS) through its educational and research
activities aimed at improving the environment in the United States and providing a forum for
state environmental policy makers. More information about ITRC and its available products and
services can be found on the Internet at www.itrcweb.org.
DISCLAIMER
This document is designed to help regulators and others develop a consistent approach to their
evaluation, regulatory approval, and deployment of specific technologies at specific sites.
Although the information in this document is believed to be reliable and accurate, this document
and all material set forth herein are provided without warranties of any kind, either express or
implied, including but not limited to warranties of the accuracy or completeness of information
contained in the document. The technical implications of any information or guidance contained
in this document may vary widely based on the specific facts involved and should not be used as
a substitute for consultation with professional and competent advisors. Although this document
attempts to address what the authors believe to be all relevant points, it is not intended to be an
exhaustive treatise on the subject. Interested readers should do their own research, and a list of
references may be provided as a starting point. This document does not necessarily address all
applicable heath and safety risks and precautions with respect to particular materials, conditions,
or procedures in specific applications of any technology. Consequently, ITRC recommends also
consulting applicable standards, laws, regulations, suppliers of materials, and material safety data
sheets for information concerning safety and health risks and precautions and compliance with
then-applicable laws and regulations. The use of this document and the materials set forth herein
is at the user's own risk. ECOS, ERIS, and ITRC shall not be liable for any direct, indirect,
incidental, special, consequential, or punitive damages arising out of the use of any information,
apparatus, method, or process discussed in this document. This document may be revised or
withdrawn at any time without prior notice.
ECOS, ERIS, and ITRC do not endorse the use of, nor do they attempt to determine the merits
of, any specific technology or technology provider through publication of this guidance
document or any other ITRC document. The type of work described in this document should be
performed by trained professionals, and federal, state, and municipal laws should be consulted.
ECOS, ERIS, and ITRC shall not be liable in the event of any conflict between this guidance
document and such laws, regulations, and/or ordinances. Mention of trade names or commercial
products does not constitute endorsement or recommendation of use by ECOS, ERIS, or ITRC.
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* INTERSTATE *
INTERSTATE TECHNOLOGY & REGULATORY COUNCIL
Document
Evaluation Survey
We value your opinion! Please complete the following survey to tell us how useful the ITRC documents have been to you.
Thank you.
1. Please write the title of the ITRC document for which you are completing this evaluation. (Please complete a separate form for
each document that you are evaluating.)
2. Please identify your involvement with the site-specific application of this document:
Your Name: (Optional) Your Organization:
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3. Did the use of this document aid in your review / approval of the site-specific application?
4. Did the use of this document provide you with new / important background information
on the use of the technology?
5. How many other sources of information did you use for background information?
6. If you had read the ITRC document first, would you still have needed the other materials?
7. Did the use of the document provide you with a better understanding of the regulatory
requirements involved in using the technology?
8. In which part(s) of the approval process did the use of the ITRC document help?
Please circle as many as apply:
Test Plan / Treatability Study / Remedial Investigation and Feasibility Study /
Remedial Action (Work) Plan / Record of Decision / Other
9. Was the guidance from this document incorporated into your site-specific application?
If yes, please explain how:
lO.Did the use of the document save time / money in the review and application of the technology
11 .Will the use of this document result in time and/or monetary savings at subsequent applications?
12.Overall, did you find the guidance document useful?
13.Overall, did you concur with the guidance outlined in the document?
14.Please identify which sections of the document were most useful in your application.
Yes No
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15.For what other areas should the ITRC develop guidance?.
Please fax completed surveys to ITRC c/o WPI at: (540) 557-6085.
No cover sheet is necessary. Thank you.
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Technical and Regulatory Guidance
for the Triad Approach: A New Paradigm
for Environmental Project Management
December 2003
Prepared by
Interstate Technology & Regulatory Council
Sampling, Characterization and Monitoring Team
Copyright 2003 Interstate Technology & Regulatory Council
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ACKNOWLEDGEMENTS
The members of the Interstate Technology & Regulatory Council (ITRC) Sampling,
Characterization and Monitoring (SCM) team wish to acknowledge the individuals,
organizations, and agencies that contributed to this guidance document.
As part of the broader ITRC effort, the SCM Team is funded primarily by the U.S. Department
of Energy. Additional funding is provided by the U.S. Department of Defense and the U.S.
Environmental Protection Agency (EPA). ITRC operates as a committee of the Environmental
Research Institute of the States (ERIS), a Section 501(c)(3) public charity that supports the
Environmental Council of the States (ECOS) through its educational and research activities
aimed at improving the environment in the United States and providing a forum for state
environmental policy makers.
The work team recognizes the efforts of the following state, federal, industry, academia, and
consulting personnel who contributed to this document:
Stuart Nagourney, New Jersey Department of Environmental Protection, Team Leader
Kimberlee Foster, Missouri Department of Natural Resources, Triad Subteam Leader
Brian Allen, Missouri Department of Natural Resources
Bradley Call, U.S. Army Corps of Engineers, Sacramento District
Hugo Martinez Cazon, Vermont Department of Environmental Conservation
Ruth Chang, California EPA Department of Toxic Substances Control
Ahad Chowdhury, Kentucky Department for Environmental Protection
Chris Clayton, Department of Energy
Steven Gelb, S2C2 Inc.
Richard LoCastro, Langan Engineering and Environmental Services, Inc.
Keisha Long, South Carolina Department of Health and Environmental Control
James Mack, New Jersey Institute of Technology
Denise MacMillan, U.S. Army Corps of Engineers Engineering Research and Development
Center
Bill Major, Naval Facilities Engineering Service Center
John Pohl, McGuire Air Force Base, 305th Environmental Flight
Qazi Salahuddin, Delaware Department of Natural Resources and Environmental Control
Peter Shebell, Department of Energy, Environmental Measurements Laboratory
Jim Shirazi, Oklahoma Department of Agriculture
Shawn Wenzel, Wisconsin Department of Commerce
The SCM Team would especially like to thank Deana Crumbling, U.S. EPA Technology
Innovation Office, for her efforts in explaining the principles involved as well as contributing to
the preparation of this document. Katherine Owens and Mary Jo Ondrechen provided
stakeholder perspectives. George Hall, ITRC Program Advisor for the SCM team, provided
valuable guidance and advice. Outside reviewers included the U.S. Army Corps of Engineers
Innovative Technology Advocates; the SCM team thanks Cheryl Groenjes and Kira Lynch for
their efforts. Appendix D provides contact information for the SCM Team members.
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EXECUTIVE SUMMARY
This technical/regulatory guidance document was prepared by the ITRC Sampling,
Characterization and Monitoring (SCM) Team and serves to introduce new concepts regarding
the manner in which environmental work is conducted. This document is atypical for the
Interstate Technology & Regulatory Council in that it does not report on a new technology per se
but introduces new concepts to the manner in which environmental work is conducted. These
concepts can increase effectiveness and quality and save project money. These ideas aren't new
but have been developed into a logical approach for environmental project management.
The concepts embodied in the three legs of the Triad approach are (1) systematic project
planning, (2) dynamic work strategies, and (3) real-time measurement technologies. The Triad
approach can be thought of as an initiative to update the environmental restoration process by
providing a better union of scientific and societal factors involved in the resolution of
contamination issues. It does this by emphasizing better investigation preparation (systematic
project planning), greater flexibility while performing field work (dynamic work strategies), and
advocacy of real-time measurement technologies, including field-generated data. The central
concept that joins all of these ideas is the need to understand and manage uncertainties that affect
decision making. The Triad approach consists of ideas that have been formulated previously but
are now united to form a new paradigm for environmental project management.
The Triad approach relies on technological, scientific, and process advances that offer the
potential for improvements in both quality and cost savings. The cost-saving potential is
considered to be significant but is only now being documented by case studies. The challenges
involved in changing from long-established procedures to any new method will be great, and
there will be opposition to the Triad approach from those unfamiliar with its potential.
The SCM team has created this document as a first step to stimulate understanding and
discussion of the ideas embodied in the Triad approach. It explains the relationship of the Triad
to existing guidance such as the data quality objectives process. It lists the advantages and
disadvantages of the Triad and notes regulatory and organizational barriers that may present
obstacles to its use. New Jersey has only recently implemented a formal program to adopt the
Triad approach, and a section is devoted to explanation of that program. Stakeholder issues are
an important consideration for adoption of any technology or approach, and this document has a
section dedicated to that end. Case studies revealing the advantages and potential success of
using the Triad approach are summarized in the text and detailed in Appendix B.
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TABLE OF CONTENTS
EXECUTIVE SUMMARY iii
1.0 INTRODUCTION 1
1.1 Evolution of the Current Investigation Paradigm 1
1.2 Why Change the Paradigm? 1
2.0 THE TRIAD APPROACH 2
2.1 Overview of the Triad Approach 2
2.2 Resource Savings and Investigation Quality 5
2.3 Applicability 5
2.4 Triad Approach Perspective 6
2.5 Systematic Project Planning 17
2.6 Dynamic Work Strategies 19
2.7 Real-Time Measurement Technologies 23
2.8 Other Triad Approach Considerations 28
2.9 Summary 30
3.0 RELATIONSHIPS TO EXISTING GUIDANCE 31
3.1 The Triad Approach and the DQO Process 32
3.2 The Triad Approach and PBMS 33
3.3 The Triad Approach and the Dynamic Field Activities Guidance 34
3.4 The Triad Approach and MARSSIM 34
3.5 The Triad Approach versus the "Sediment Quality Triad" 35
3.6 The Triad Approach and the Technical Project Planning Approach 35
3.7 The Triad Approach and Early ITRC Guidance 35
4.0 ADVANTAGES AND DISADVANTAGES 36
4.1 Advantages 36
4.2 Disadvantages 37
5.0 REGULATORY AND OTHER BARRIERS 38
5.1 Organizational Barriers 38
5.2 Concerns with Real-Time Measurement Technologies 42
5.3 Conflicts with State Law, Policy, or Guidance 48
5.4 Lack of Guidance for State Regulators 48
5.5 Defining Action Levels During Systematic Project Planning 49
5.6 Associating Uncertainty to Specific Decisions 50
5.7 Recommendations for Overcoming Barriers 51
6.0 IMPLEMENTATION OF TRIAD IN A STATE REGULATORY AGENCY 52
6.1 New Jersey Policy Statement Supporting the Triad Approach 52
6.2 New Jersey Triad Approach Training 52
6.3 New Jersey Regulations Pertinent to the Triad Approach 53
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7.0 STAKEHOLDER CONCERNS 55
8.0 HEALTH AND SAFETY CONSIDERATIONS 56
9.0 CASE STUDY SUMMARIES 57
9.1 Fernald Uranium Processing Facility 57
9.2 Varsity Cleaners 57
9.3 Wanatchee Tree Fruit Research and Extension Center Test Plot 57
9.4 Assunpink Creek Brownfields 58
9.5 McGuire Air Force Base C-17 Hangar Site 58
9.6 Pine Street Barge Canal 58
10.0 REFERENCES 58
11.0 ADDITIONAL SOURCES OF INFORMATION 62
LIST OF TABLES
Table 1. Triad process overview 4
Table 2. Subsample variability 15
Table 3. Summary of advantages and disadvantages 36
LIST OF FIGURES
Figure 1. The Triad approach components 3
Figure 2. Project planning and execution relationships 6
Figure 3. Simple hydrogeologic conceptual site model 11
Figure 4. Sample representativeness and uncertainty 13
Figure 5. The data quality chain 16
Figure 6. The strengths and limitations of analytical methods 25
Figure 7. Collaborative data sets increase data quality for heterogeneous matrices 26
APPENDICES
APPENDIX A. Acronyms
APPENDIX B. Case Studies
APPENDIX C. Response to Comments
APPENDIX D. ITRC Contacts, Fact Sheet, and Product List
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THE TRIAD APPROACH: A NEW PARADIGM FOR ENVIRONMENTAL PROJECT
MANAGEMENT
1.0 INTRODUCTION
The environmental cleanup profession has been in existence for more than 20 years and has
developed a tremendous body of practical and scientific knowledge. However, despite this
experience, environmental restoration remains a lengthy and expensive process. The U.S.
Environmental Protection Agency (EPA) has combined the best elements from a number of
initiatives designed to improve restoration effectiveness and calls the resulting synthesis the
"Triad approach." This Interstate Technology & Regulatory Council (ITRC) document explains
the advantages offered by the Triad approach and shows how it results in better restorations,
accomplished faster and with less expense. These improvements benefit government regulators,
the regulated community, and the public. Because there is often resistance to change from
established procedures, it is important to involve the stakeholder community from the beginning
of any project utilizing the Triad approach.
1.1 Evolution of the Current Investigation Paradigm
The current methodology for site characterization (created to support early cleanup programs)
includes a multistage investigative process that was intended to provide sufficient understanding
of site contamination issues to take remedial action. This process has proved to be very
expensive and time-consuming. When this methodology was developed in the 1980s, there were
good reasons to adopt a carefully staged approach to site characterization, ranging from the need
to build a base of knowledge in this field to the tremendous complexity involved when predicting
contaminant behavior in natural geologic settings. In addition, analytical methods required the
controlled environment of static laboratories for proper implementation and quality control (QC)
oversight. When this reality was combined with periodic budgeting cycles for government-
funded work, it is not difficult to understand how multiple investigations—each with its own
multiyear cycle of work plan preparation, field work, and report of findings—became the
accepted approach.
Associated with the development of the multistage investigation process was the establishment
of carefully documented analytical procedures (SW-846), which have become a standard in the
environmental industry. Legal defensibility considerations have led to the widespread opinion
that only SW-846 methods are suitable for site decision making. The importance of obtaining
contaminant concentration data of known quality cannot be underestimated; however, the
exclusive focus on analytical quality alone disregards other equally important considerations.
1.2 Why Change the Paradigm?
Many environmental professionals have recognized that the current approach is not always the
most efficient in terms of either financial resources or technical sophistication. Despite this
realization, it was not clear how to move away from multistage investigations. The fact remains
that the complexity of contaminant distribution and geological heterogeneity requires a large
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ITRC- The Triad Approach: A New Paradigm for Environmental Project Management December 2003
number of costly samples to reduce uncertainty to acceptable levels. However, recent advances
in field analytical methods, sample collection techniques, and geologic definition now offer the
opportunity to dramatically improve investigation effectiveness. Yet, improvements in
technology alone are not sufficient since they must be combined with changes in approach.
Changes in approach include the following:
• better initial determination of investigation objectives,
• better use of conceptual site models (CSMs) during planning and project decision making,
• early agreement by all project team members and stakeholders on acceptable action
concentrations,
• use of techniques to evaluate data uncertainty, and
• real-time management and analysis of data.
These ideals are now within reach of routine investigation, cleanup, and monitoring practices.
All of these considerations revolve around one central concept: understanding and managing
uncertainty. Environmental investigations are truly multidisciplinary endeavors, and this fact
creates a management challenge. The project team must avoid a loss of focus on the specific
investigation objectives while integrating different technical viewpoints. This goal is
accomplished by achieving consensus on the investigation objectives prior to beginning
generation of planning documents that support field work. This vital step of systematic planning
is central to a successful investigation.
2.0 THE TRIAD APPROACH
This section begins by explaining the potential cost savings and quality improvements offered by
the Triad approach. It next describes the type of projects to which this new system will be
applicable. The underpinnings of the Triad approach are described, and the section goes on to
provide additional information on each of the legs of the Triad: systematic project planning,
dynamic work strategies, and real-time measurement technologies.
The primary product of the Triad approach is an accurate CSM that can support decisions about
exposure to contaminants, site cleanup and reuse, and long-term monitoring. The Triad approach
is grounded in science but recognizes that environmental restoration decision making considers
policy, public debate, and negotiation. Because the Triad focuses on uncertainty management, it
ensures that the unknowns impacting our ability to make good decisions are identified and
documented so that all involved parties can openly evaluate the relative risks of each decision.
The Triad encourages strategy and technology options that can lower project costs, while
ensuring that the desired levels of environmental protection are achieved.
2.1 Overview of the Triad Approach
The Triad approach embraces scientific and process improvements in three areas: systematic
project planning, dynamic work strategies, and real-time measurement technologies (Figure 1).
The central principle of the Triad approach is the management of decision uncertainty.
Systematic planning encompasses all tasks that produce clear project goals and decisions;
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^ The Triad Approach: A New Paradigm for Environmental Project Management
December 2003
Real-Time Measurement Technologies
describe unknowns (i.e., uncertainties) that
could cause erroneous decisions; and foster
clear communication, documentation, and
coordination of all project activities. The
adjective "dynamic" describes work
strategies designed around consensus-
derived decision logic so that real-time
decision making can quickly refine field
work as new information becomes available. ^. ^ m ^ .
Real-time measurement technologies include Fl§ure J- The Trlad approach components.
geophysics and other imaging techniques, on-site technologies and in situ detection techniques,
and rapid turnaround from mobile and fixed labs, as well as software packages for processing,
displaying, and sharing data so that the CSM can evolve while the work crew remains in the field
(EPA2001f).
The Triad focuses first on establishing clear project goals. That is why "systematic project
planning" (sometimes called "strategic planning") is the single most important element in the
Triad. After project goals are understood, then the uncertainties that stand in the way of
achieving those goals will be addressed. Usually environmental data will be collected as one
means to manage decision uncertainty. When data are used to make decisions, the sampling and
analytical uncertainties inherent to environmental data generation must be managed to a level
commensurate with project decision needs. Having clear project objectives spelled out up front
improves the quality of investigation activities because data collection becomes more efficient.
The dynamic work strategies element of the Triad is based on real-time decision making. This
element greatly reduces project lifetime costs and duration, making Triad life-cycle costs much
less than traditional life-cycle costs. Project quality is improved because more data is acquired in
exactly the right places to fill important data gaps in the CSM.
Real-time measurement technologies, the third element in the Triad, make real-time decision
making possible. The state of the art is to use software tools that process and display or map data
in real time. Together, real-time technologies and real-time work strategies work hand in hand so
that data collection is focused and informative. Real-time decision making improves project
decision confidence by providing higher-density sampling (more samples) and rapid feedback of
information needed to efficiently mature the project CSM to sufficient accuracy so that exposure
risk and remedial decisions are correct. It is critical to use the CSM to avoid sampling errors and
to interpret results from various data sets, including lower-density (fewer samples) fixed-
laboratory analysis in conjunction with the real-time measurements.
In the broadest sense, the Triad approach is a conceptual and strategic framework that explicitly
recognizes the scientific and technical complexities of site characterization, risk estimation, and
treatment design. In particular, the Triad approach acknowledges that environmental media are
fundamentally heterogeneous at both larger and smaller scales. Heterogeneity can have important
repercussions on sampling design, analytical method performance, spatial interpretation of data,
toxicity and risk estimation, and remedy design and success. Most of the ideas found in the Triad
approach are not new, and many in the environmental community both understand and support
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ITRC - The Triad Approach: A New Paradigm for Environmental Project Management
December 2003
these concepts. What is new about the Triad is the effort to comprehensively incorporate all these
ideas simultaneously into a next-generation model for cleanup practices supported by EPA.
Table 1 lists the major components of the Triad and the questions answered by each component.
Table 1 should be considered as a process that begins at the top with systematic planning and
continues to decision making, perhaps iterating several times till complete.
Table 1. Triad process overview
SYSTEMATIC
PROJECT
PLANNING
Project Initiation
Assemble project team
Define project objectives
Identify key decision makers
Define decisions to be made
Develop initial conceptual site model (CSM)
Answers:
• Who
• What
• Why
ADAPTIVE
WORK PLAN
IMPLEMENTATION
Plan Approval
Client/regulator/stakeholder review/approval
Refine project decision logic and finalize plans
Answers:
• Who
• What
• Why
• How
DECISION
MAKING
Are Project Objectives Met?
Evolve/refine CSM
Modify adaptive work plan
Client/stakeholder/regulatory review/approval
Whv
What
How
Who
Central Concept = Uncertainty Management
The Triad approach explicitly focuses on the identification and management of sources of
decision uncertainty that could lead to decision errors. The Triad explicitly manages the
largest source of data uncertainty, which is data variability caused by the heterogeneity of
chemical contaminants and the impacted environmental matrices.
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ITRC - The Triad Approach: A New Paradigm for Environmental Project Management December 2003
The ideas contained within the Triad approach are a continuation and synthesis of efforts begun
in the 1980s by the U.S. Department of Energy (DOE) to make site investigation and cleanup
more cost-effective (Burton 1993). Over the years, a variety of governmental, academic, and
private sector innovators continued to contribute to the theoretical and practical considerations
that the Triad approach embraces (e.g., Robbat 1997). Similar efforts in Europe are also under
way. A consortium of European academic and government institutions is pursuing an initiative
(referred to as "Network Oriented Risk Investigation for Site Characterization," or "NORISC")
to develop strategies for expediting site characterization that have some similarity to the Triad
approach. NORISC emphasizes early and active stakeholder involvement in the establishment of
cleanup goals and places strong emphasis upon the use of on-site analysis selection software
(more information can be found at the NORISC Web site at http://www.norisc.com/').
2.2 Resource Savings and Investigation Quality
Reducing restoration costs and time are common goals for environmental professionals. The
EPA and other practitioners have shown across a variety of project types that implementation of
the Triad approach will result in significant improvements in both investigation quality and cost
efficiency. Several examples of such projects are described in more detail in Section 9. Cost and
time savings result primarily from reducing the number of investigation field mobilizations
needed to complete the characterization. Significant cost and time savings can result because
characterization can focus on uncertainties that impact appropriate remedial action selection,
design, and associated cost estimation. Improved investigation quality arises from better focus on
project goals, increased sample coverage of the site, fewer unexplored site uncertainties,
flexibility for field activities to adjust to unexpected conditions, and sophisticated data
management tools to analyze and communicate the findings.
The Triad Approach Is Efficient
The Triad approach offers the potential for significant cost savings. Cost savings up to 50%
have been observed. The cost savings potential increases with site complexity.
Time savings can also be significant. Systematic project planning establishes clear project
goals and the associated decision logic so that a dynamic work strategy can reduce the
number of field mobilizations.
2.3 Applicability
In contrast to earlier efforts to improve quality and cost-effectiveness, the Triad approach is not
narrowly focused on a single EPA remedial program. Rather, the Triad integrates the core
principles behind many conceptually similar "expedited," "accelerated," or "streamlining"
initiatives developed by federal and state agencies. The Triad approach is applicable to all EPA
programs such as the Resource Conservation Recovery Act (RCRA), Superfund, brownfields,
and the underground storage tank (UST) program, as well as similar state programs. Universal
concepts underlying the Triad approach apply to any site, no matter what stage of investigation
or remediation, and no matter what size or complexity of the site. These concepts include
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ITRC - The Triad Approach: A New Paradigm for Environmental Project Management
December 2003
managing decision uncertainties and developing a conceptual site model accurate enough to
support cost-effective, yet protective decisions.
The Triad Approach is Broadly Applicable
The Triad approach is a conceptual framework developed by synthesizing various strategic
improvements to environmental investigation planning, execution and evaluation. It is
applicable across all types of environmental programs.
2.4 Triad Approach Perspective
The Triad approach rests on the principle that the quality of an investigation depends on
achieving a level of decision confidence that meets the customers' (including stakeholders')
expectations for a successful project outcome. To reach the desired outcome, the project team
makes specific regulatory, economic, and engineering decisions, each with inherent uncertainty.
Detailed planning reveals cost-effective ways to ensure confidence in the project outcome
despite the persistence of uncertainties with some of the decision inputs. Project planning always
involves creating a preliminary or initial CSM. Planning with the "end" (i.e., the desired project
outcome) in view reveals which knowledge gaps in the CSM are truly important. Data collection
to fill those gaps should be tailored to be representative of the decision to be made. With its
focus on managing decision uncertainty, Triad systematic planning allows projects to be done
right the first time.
Significant components of project planning and execution are shown graphically in Figure 2. The
general time order for tackling each of these components during the planning process is reversed
during project implementation. Projects begin with the need to achieve a certain restoration or
reuse outcome. A successful outcome depends on satisfactorily resolving regulatory and
technical decisions about contaminant presence, exposure, and fate.
Systematic Project Planning
Project Outcome
(Sect. 2.4.1)
Project Decisions
(Sect. 2.4.2)
Conceptual Site
Model (Sect 2.4.3)
Data (Sect. 2.4.4)
Project Implementation/Resolution
Figure 2. Project planning and execution relationships. Systematic planning tailors data
collection by starting at the highest level (the desired outcome) and working downward into
the details of sampling and analysis (arrow pointing right). As the work strategy is
implemented, the generated data are used to mature the CSM, which is in turn used to make
decisions about whether the outcome can be satisfactorily achieved (arrow pointing left).
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ITRC - The Triad Approach: A New Paradigm for Environmental Project Management
December 2003
The CSM integrates information about contaminant release, migration, and risk reduction
options into a form that decision makers can use. Information gaps always exist in preliminary
CSMs. Gaps are identified by comparing what is already known with what needs to be known to
make appropriate regulatory and engineering decisions. Data-gathering strategies are then
devised to fill CSM gaps. As the CSM progressively becomes more mature, decision uncertainty
progressively decreases. These ideas are illustrated in Figure 2 and are more fully explained in
the sections that follow.
2.4.1 Project Outcomes
A hypothetical example is used in the following paragraphs to illustrate the Triad approach. The
desired project outcome is construction of a school at a former commercial parcel that is now
being managed as a brownfields site. Project team members and stakeholders will be concerned
about the certainty of a specific outcome, such as ensuring that if a school is built on the
brownfields site, the children will not be exposed to site contaminants.
The decision about whether a school can be safely built is itself dependent on a number of
specific regulatory and engineering decisions about whether contamination is present above
regulatory thresholds, and if so, whether intact exposure pathways might exist after school
construction is completed.
2.4.2 Project Decisions
To achieve the desired project outcome, a number of regulatory and technical decisions must be
made along the way. In practice, project decisions are made using a combination of scientific
data and other inputs. These other inputs include political, economic, and social considerations
that may have local, regional, and national linkages. Different projects will have different lists of
decisions. A partial list of example project decisions includes deciding whether
• contamination is greater than background;
• there is a threat to groundwater;
• the contamination has been adequately characterized;
» the extent and variability in contamination distribution has been adequately assessed;
• natural attenuation is occurring, and if so at what rate;
• people are exposed to the contamination, and if so by what pathways;
• environmental (ecological) receptors are exposed;
• contamination levels are greater than regulatory action level;
• there are cost-effective remedial options;
• it is possible to apply new and innovative remedial approaches;
• other institutional controls, such as land use restrictions, are appropriate for the site;
* a risk-based remedial strategy is appropriate for the site; and
* long-term monitoring will be required.
Making these decisions requires knowledge of site contamination issues, collectively referred to
as a conceptual site model. The CSM will be discussed in more detail below, but at this point it is
sufficient to understand that the CSM is constructed with information, much of which consists of
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ITRC ~ The Triad Approach: A New Paradigm for Environmental Project Management
December 2003
environmental data for understanding how contaminants are distributed throughout the site,
along with contaminant fate, migration, and exposure pathways.
The project team's confidence in making correct decisions depends on its ability to assemble an
accurate CSM. To continue with the hypothetical brownfields school redevelopment site, when
evaluating whether it is safe to build the school, the project team must determine whether there
are unacceptable levels of contamination and complete exposure pathways. Assume that the
project team must decide if lead contamination in near-surface soils would pose a risk to school
children if a playground were built. A regulatory action level has been established, and the
limited amount of available data and site history used to create the initial CSM suggests that lead
may be unevenly distributed across the site. The project team must decide whether the average
lead concentration and the concentration of any isolated hot spots exceeding a certain size in the
playground soils exceed established regulatory action levels. To demonstrate with confidence
whether lead concentrations could be high enough to pose a threat, a sampling program is
needed. To have confidence that the sampling design can detect hot spots of concern and produce
an accurate estimate of the mean, the project team needs to develop the sampling program that
estimates contaminant variability and is dense enough to locate any significant hot spots. If there
are doubts about the correctness of a regulatory decision because of excessive uncertainty in
estimates of lead concentrations, then all team members will be in doubt regarding the success of
the school development project from the standpoint of the children's safety. In other words,
doubts about whether decisions are made correctly create doubts (i.e., uncertainty) about the
success of the project outcome.
As mentioned earlier, it is sometimes possible to manage outcome uncertainty despite unresolved
decision uncertainty. Continuing with the school example, this possibility can be illustrated by
considering how a remedial option might render actual soil lead concentrations irrelevant by
simply blocking the exposure pathway. For example, physically capping potentially
contaminated soil at the playground ensures confidence in the desired outcome that children not
be exposed to contaminated soil. This outcome is achieved without costly soil sampling to
determine the actual lead concentrations. Exposure to any other nonmobile contaminant that may
happen to be present in the subsurface is similarly blocked by this containment option. Selection
of this option is conservative in the sense that all team members will have high confidence in the
desired protective outcome, despite continued uncertainty about whether or not lead
concentrations exceed regulatory thresholds. The benefits of this decision strategy are that
regulatory agencies can quickly confirm the completion of remedial actions, financial institutions
can confidently lend money for redevelopment to proceed, and insurance brokers can provide
coverage at reasonable rates.
This type of decision uncertainty management may be appropriate for some sites but not for
others. It depends on myriad site-specific, economic, social, and regulatory variables. While
conservative protective options may be appropriate and cost-effective in some instances, in other
cases the costs and consequences of overly conservative decisions may outweigh any perceived
benefits. When cost-effective treatment options are available (such as precision removal and
disposal of contamination hot spots followed by evaluating the hazard posed by any remaining
contamination), sampling and analysis to support a cleanup strategy are generally preferable to
preserve a wider range of land use options. In that case, developing a sampling plan that gives an
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accurate picture of lead concentrations becomes a critical component of the project planning.
Tolerable levels of decision uncertainty (how much contamination can be missed by the
sampling program without causing undue risk) must also be established in the work plan.
Decision Strategies Are Determined During Systematic Project Planning
Decision strategies are determined with the input of stakeholders and the approval of
regulators. If too little information is available to know which decision strategy would be
best, the factors driving the selection of one strategy over another (e.g., selecting a cleanup
strategy rather than a containment option) are determined. These factors can be arrayed into a
matrix or decision tree, which is resolved as the needed information is gathered during
implementation of the dynamic work strategy.
An important task of Triad systematic planning is to consider which decision strategy is most
appropriate for a particular project, weighing each strategy's pros and cons against budgetary and
regulatory constraints and stakeholder interests. Early in the project life cycle there may not be
enough knowledge to determine which decision strategy is best. In that case, systematic planning
focuses on the information needed to decide which decision strategy makes the most sense.
Selection of a decision strategy may be summarized as a series of "if-then" statements that
capture the relationships between drivers such as costs, risk, cleanup versus containment options,
and stakeholder concerns. For example, "If characterization finds that estimates of the highly
contaminated soil requiring disposal (if removed) exceed 100 tons, then capping and restricted
reuse is the only financially viable option. Further delineation of soil contamination will be
aborted, and a decision strategy to support containment design will be instituted. However, if
contamination is found to be low level and disposal is estimated at less than 100 tons,
characterization will continue according to a decision strategy supporting complete cleanup and
unrestricted site reuse." As long as all stakeholders agree on the decision logic, final selection of
the decision strategy can be a seamless part of field implementation.
2.4.3 Conceptual Site Models (CSM)
Building a CSM begins with information about land use, records of chemical usage, other
historical data, and expectations about how contaminants may have been released to the
environment. Contaminant release mechanisms determine how variable contaminant
concentrations are likely to be across the site. When new data are collected, CSM hypotheses are
tested and confirmed, modified, or rejected. New data are used to "mature the CSM," that is, to
build an accurate understanding of what contamination is present and where, whether the
contamination can pose current or future risks to potential receptors, and if so, how that risk can
be mitigated. The CSM and "data" are tightly coupled in a feedback loop: the CSM guides the
collection of new data, but the CSM is also changed and refined as those new results are
integrated into it. The updated CSM then guides the collection of more data, which further
refines the CSM. Traditional approaches were forced to update the CSM in separate field
mobilizations. Under the Triad, new technologies allow the CSM update cycle to proceed daily,
with a fully matured CSM emerging in as little as a single field mobilization.
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The CSM creates the setting within which the analytical contaminant data are evaluated and
understood. The CSM consists of chemical, physical and biological data that are organized into
text, graphics, tables, or some other useful representation (or "model") able to support site
decision making. Key elements typically included in a CSM include the following, adapted from
the Vermont Department of Environmental Conservation:
• General physical site description
• Regional environmental setting
o Geology
o Hydrogeology
o Habitat description
• Land use description
o Current land use
o Proposed land use
o Land use history
• Contaminant regime and site investigations
o Results of previous site investigations
o Contaminants of concern
o Contaminant sources
o Contaminant fate and transport
o Contaminant susceptibility to various treatment or destruction options
o Contaminant variability in time and space (at larger and smaller scales)
• Potential risks and potential receptors
o Exposure pathways
o Activities and risks
• Data evaluation
• Identification of data gaps and data needs to serve various exposure or remedial decisions
Different decisions may require different representations of the CSM. For example, decisions
about groundwater contamination migration or cleanup need a CSM that emphasizes
hydrogeology and contaminant concentrations and fate information; whereas decisions about
contaminant exposure require a CSM that focuses on identifying all potential receptors and
exposure pathways. Figure 3 shows a simple pictorial CSM representing geologic and
hydrogeologic settings. A geologic cross section is an effective method to show manmade and
natural features that affect contaminant transport and receptor exposure. A complex site may
have several depictions of the CSM, each of which addresses a different medium or subset of the
decisions to be made or represents one of multiple hypotheses that need to be clarified by getting
more data (USAGE 2003; ASTM 2002).
The CSM is updated as new information becomes available, generally after completion of each
phase of investigation. Using a dynamic work strategy, a "phase" might be completed one day,
the CSM updated overnight, and the next "phase" begun the next day without a break in field
work. The CSM can be updated whenever new data suggest a significant change to a previous
interpretation or to direct the next sampling or remedial effort. The revision/updating cycle of the
CSM should be a group decision made by team members and stakeholders during the systematic
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Figure 3. Simple hydrogeologic conceptual site model (USACE 2003).
planning. When not performing the CSM updates themselves, it is critical that field personnel be
kept informed of any updates to the CSM.
The CSM becomes sufficiently accurate when there is confidence that the CSM represents actual
site heterogeneity so that decisions about exposure and remediation can be correct and cost-
effective. Spatial heterogeneity occurs because of differing release scenarios, the many diverse
fate and transport mechanisms that affect a contaminant, and the heterogeneity of geologic
environments. Spatial heterogeneity creates areas that can differ widely in contaminant
concentrations. These different areas may constitute different contaminant populations.
Populations can be considered different if the mechanism creating them is different and/or if
decisions are different. For example, for noncontaminated areas, the obvious decision is "no
action required." For contaminated areas of sufficient size, with concentrations above the action
level or large contaminant mass, the decision is to remediate.
A preliminary CSM considers the site history and physical characteristics to determine what type
of spatial patterning might be expected. The same information can predict whether the
concentrations from place to place within a single population are expected to be more or less
uniform or whether they are likely to be highly variable. This knowledge is critical to designing
cost-effective sampling plans. Statistical sampling plans, such as those used to estimate a mean
for use in risk assessment (where an average concentration over an exposure unit is required), are
much more powerful when data from different contaminant populations are kept separate.
Successful remedial designs are entirely dependent on sampling plans that develop an
understanding of spatial patterns and concentration extremes (e.g., finding a dense, nonaqueous-
phase liquid [DNAPL] source area).
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Heterogeneity Is Addressed in the CSM
The CSM is the primary tool used to
• predict the degree of contaminant heterogeneity and the nature of spatial patterning and
migration pathways;
• verify whether those predictions were accurate;
• assess whether heterogeneity impacts the performance of statistical sampling plans;
• understand "data representativeness;" and
• integrate knowledge of heterogeneity and spatial patterning into decisions about exposure
pathways, selecting remedies, designing treatment systems, and long-term monitoring
strategies.
The term "data representativeness" is frequently used in a generic sense by environmental
practitioners, but mechanisms to make the concept practical have not received sufficient
attention. "Data representativeness" can be made more meaningful if it is evaluated in terms of
the CSM and the project decisions. Data that are representative of the CSM will first enable
delineation of distinct contaminant populations of interest to the project. Once the approximate
boundaries of those populations are understood (i.e., the CSM is mature), data that are
representative of specific project decisions are used to estimate the properties of interest for each
population (for example, a risk assessment decision requires an estimate of the mean
concentration over an exposure unit).
Generating representative data is not a simple matter when heterogeneous environmental
matrices are involved. Although data may be correct in the sense that the analytical results are
accurate for the tiny samples analyzed, extrapolating the results from those tiny samples to the
much larger matrix volumes encompassed by the CSM may create a false picture. This is termed
"sampling error." Sampling errors occur when the analysis is accurate but the sample analyzed is
not representative of what the data user thinks it represents. Because environmental matrices are
frequently heterogeneous at both macro and micro scales, sampling errors can contribute to very
misleading CSMs, which in turn can lead to erroneous decisions about risk or cleanup strategies.
As a group, the factors that contribute to sampling errors are termed "sampling uncertainties."
Spatial heterogeneity at the scale of many grid-based sampling designs is one contributor to
sampling uncertainty. This case is illustrated in the top panel of Figure 4. This cartoon illustrates
a sampling design where too few high-analytical quality samples miss important areas of
contamination and fail to define the true extent of contaminant populations (such as hot spots).
When few samples are collected, there is no choice but to extrapolate the result of a tiny sample
analyzed in the laboratory (often as little as 1 gram) to volumes of matrix a million or more times
larger. Statistical calculations (such as calculation of a mean) make the assumption that the result
from a tiny sample in the center of a grid represents the contaminant concentration for the entire
grid block. The degree to which this is a valid assumption depends on the CSM (i.e., how you
think the contamination got there and whether the release mechanism is expected to produce
uniform contaminant concentrations).
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From this...
High
Project
Decision
Uncertainty
Incomplete Site
Characterization
Additional Characterization
and Remediation Needed
To this...
Complete Site
Characterization
Low
Project
Decision
Uncertainty
Site Restoration Completed to a
Higher Level of Quality in One Effort
Figure 4. Sample representativeness and uncertainty. By collecting a larger number of less-
expensive (0) samples a more complete understanding of site conditions can be achieved.
i
Another source of uncertainty arises from errors in the statistics used to summarize the data and
can be termed "statistical error." Such error may result from any of the following actions:
The wrong distribution was assumed (normal versus abnormal).
Assumptions concerning the statistic were violated (contamination may not be random or
independent).
The wrong statistic was used to describe the samples.
Censored data was used incorrectly (how nondetects were interpreted).
Selecting correct statistical procedures is dependent on having a reasonably accurate CSM.
High-Density Sampling versus Analytical Perfection
Decision errors about risk and remediation are an unavoidable consequence of traditional
work strategies that rely on fixed-laboratory analyses. Since such analyses are expensive,
relatively few samples can be analyzed compared to the number needed to accurately
characterize heterogeneous contaminant distributions. High analytical quality is seldom
needed to refine the CSM. However, without a reliable CSM to support the representativeness
of expensive, high-analytical quality data points, those data may be misleading and result in
decision errors.
When the sampling density (number of samples per unit volume of environmental media) is
insufficient to capture the effects of heterogeneity, incomplete or inaccurate CSMs are produced.
Consequences include errors about risk and compliance. Estimates of contaminant nature and
extent may be seriously biased. Decisions about exposure pathways may be wrong. Treatment
designs may fail to achieve cleanup the first time, requiring another round of characterization
and cleanup after remediation fails or when unexpected contamination is discovered. Poor
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characterization needlessly increases the costs of cleanup when "clean" matrix is inadvertently
lumped together with the "dirty" matrix, unnecessarily increasing the volume to be treated or
disposed while artificially decreasing treatment efficiency.
2.4.4 Data and Sources of Data Uncertainty
"Data uncertainty," in its broadest sense, can include the ideas that
• the necessary data are completely missing,
• accurate data exist but were not collected in sufficient quantities to provide confidence that
the CSM is complete and accurate for decision-making purposes, and
• data exist but the accuracy or representativeness of the data is either in doubt or known to be
inadequate.
All of these kinds of data uncertainty may be relevant for site cleanup projects. As noted
previously, uncertainty is a hallmark of all environmental data, with contributions from both the
sampling and the analytical components. Difficulties stem from the fact that environmental
matrices are heterogeneous in composition and in contaminant distribution. Composition
heterogeneity makes it impossible to devise cost-effective standardized sampling and analysis
methods that will work equally well for all possible applications. Contaminant heterogeneity
across larger and smaller spatial scales means that it is dangerous to assume that results from tiny
samples can be extrapolated to represent larger matrix volumes. Environmental heterogeneity
produces true variability in sample results. In other words, the actual concentration in one sample
is truly different from the concentration in another sample, even though the samples may be
taken only inches apart in the field or taken from the same sample jar. It has long been
recognized that the largest source of data uncertainty is sampling variability associated with the
heterogeneity of environmental matrices (Homsher 1991, Jenkins et al. 1997).
As mentioned earlier, factors associated with sampling variability can lead to sampling errors,
where the analysis is accurate but the sample or subsample is not representative of the matrix
volume to which the result is being applied. For solid environmental samples, such as soils,
sediments, and waste materials, even the volume of a subsample taken from a "homogenized"
sample introduces variability because it is impossible to completely homogenize solid
environmental matrices so that the contaminant is uniformly distributed throughout the sample.
For trace analyses of parts per million (ppm) and lower, models predict that matrix grains with
attached contaminants distribute nonuniformly throughout a "sea" of grains that have few or no
contaminant molecules attached. The smaller the subsample, the more likely it is that the number
of contaminated grains will vary greatly from one subsample to the next. When analyzed, the
subsample results will vary widely. Yet, current protocols unquestioningly extrapolate a single
subsample result to represent the result for the entire jar, leading to erroneous conclusions.
A DOE study first published in 1978 demonstrated how subsample volume could produce
misleading results. A site contaminated with americium-241 (Am-241, a radionuclide) was
sampled to create a single large containerized soil sample (about 4—5 kg). That sample was
carefully homogenized by drying, ball-milling, and sieving through a 10-mesh screen. The true
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mean for this large sample was determined to be 1.92 ppm. Twenty subsamples each of 1, 10, 50,
and 100 volumes were taken and analyzed separately. The results are summarized in Table 2.
Table 2. Subsampie variability
Subsampie
volume
(R)
1
10
50
100
Range of results for 20
individual subsamples
(ppm)
1.01-8.00
1.36-3.43
1.55-2.46
1.70-2.30
(Adapted from Gilbert and Doctor 1985.)
Obviously, the larger the subsample, the less variable the results, and the much more reliably any
single subsample result estimated the true mean (1.92 ppm) for the original sample (Gilbert and
Doctor 1985). A sampling error would occur if a data user got the result of 8 ppm (as reported by
the laboratory on a 1-g subsample) and assumed that it represented the true concentration for the
entire jar of sample (an error of over 400%). The error would be further compounded if that
8 ppm result were extrapolated to represent the concentration of Am-241 for a large portion (e.g.,
a 100-square-foot by 1-foot-deep grid volume) of the site.
This type of sampling error is a consequence of a "sample support" problem. The term "sample
support" refers to the physical properties of the sample or subsample. In the environmental field,
the concept of sample support includes (1) the sample or subsample volume, (2) the spatial
orientation or dimensions of the sample collection device which determines the spatial
dimensions of the sample, and (3) the particle sizes making up the sample. The concept of
sample support is critical for both solids (such as soils) and water (such as groundwater).
Analytical results can be different simply because the sample support is different, excluding any
variability in the analytical method itself.
The concept of sample support was introduced into waste cleanup programs by EPA years ago,
although the concept never received wide recognition. For example, Data Quality Objectives
Process for Superfund guidance (EPA 1993, p. 41) lists sample support as one of the design
elements required to be discussed in the Quality Assurance Project Plan (QAPP) or the Sampling
and Analysis Plan (SAP). Controlling sampling variables (to ensure that sample results are truly
representative of intended decisions) is a critical first step to managing data uncertainty for
cleanup projects.
Figure 5 illustrates how variables governing the generation of decision quality data (i.e., data
fully representative of the intended decision) can be coarsely grouped into sampling and
analytical categories. Each of these categories is a step where serious data errors can occur,
creating nonrepresentative or poor quality data. The four sampling-related categories are "sample
support," which covers variables related to the volume, spatial orientation, and particle size of
individual samples; "sampling design," which covers all those issues related to how many
samples to take and where to take them; "sample preservation," which includes all those tasks
involved with ensuring that analytes are not lost through degradation or volatilization, or gained
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through cross-contamination; and "subsampling," which covers sample homogenization and
subsample support when a smaller portion is taken from a sample container for analysis. On the
analytical side, "sample preparation method(s)" refer to extraction or digestion procedures used
to remove targeted analytes from the original matrix of the sample or subsample. Extraction
procedures inappropriate for the particular matrix or for individual analytes on a determinative
method list will falsely bias results lower than the true value. "Extract cleanup method(s)" are
used for removing coextracted interferences for analytes like pesticides and dioxins. Significant
loss of target analyte can occur in this step. "Determinative method" refers to the instrumental
method that determines the numerical result. "Result reporting" from the laboratory is the last
link in the chain where clerical errors can be introduced before the data user receives the results.
All links in the Data Quality chain must be ™«"»»y
intact for Decision Quality to be supported !
Figure 5. The data quality chain. Failure to control any of these variables can break the data
quality chain, rendering the reported results nonrepresentative and misleading (Crumbling 2003b).
"Representative data" are generated when all these variables are controlled by selecting the
appropriate procedures based on the intended use of the data. Depending on the analyte, the site
type, the matrix, and the estimation procedure, sampling uncertainties can account for most to
nearly all of the variability in a given data set. Even on just the analytical side, sample
preparation methods and extract cleanup methods (separate method numbers in the SW-846
methods manual) can introduce significant variability into analytical results. Yet regulatory
programs focus nearly all "data quality" oversight only on the last step, the analytical side of data
generation: the determinative method. Most SW-846 methods familiar to practitioners designate
only a determinative method. For example, SW-846 Method 8260 simply denotes that a gas
chromatography-mass spectrometer (GC-MS) is used to measure volatile organic compounds
(VOCs). The sample preparation method is not specified by referring to Method 8260 and needs
to be designated separately. For example, the nearly universal purge-and-trap sample preparation
method for VOCs is designated by Method 5030 (for water samples) and by Method 5035 (for
solid samples). Selection of sample preparation method can impact the accuracy of the analysis.
A generalized preparation method (such as Method 5030) will unavoidably perform better for
some analytes than for others on the same (determinative) method list. At least five alternatives
to the purge-and-trap sample preparation method for VOCs are referenced in SW-846 Method
8260 because the purge-and-trap method is not recommended for those VOC analytes that have
low purging efficiency (EPA 2003d). Although the GC-MS may be able to measure any ethanol,
for example, that gets into the instrument, the results will be falsely low if purging cannot move
the ethanol out of the sample and into the GC-MS.
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It should be clear that regulatory oversight for only SW-846 determinative methods leaves most
of the data variability uncontrolled and unaddressed. In contrast, practitioners who use the Triad
approach are expected to address all sources of data uncertainty that are of sufficient magnitude
to cause decision errors. Within the Triad, there is no one-size-fits-all sampling and analysis
program for a diverse range of site types and analytes. On the contrary, the Triad uses systematic
planning to tailor all steps in the data generation chain to be representative of the exact decision
goals articulated for the project.
As was illustrated in Figure 4, overall uncertainty in the data set used to develop the CSM is
better managed using less-expensive analyses (such as field analyses) that can affordably
increase the number of samples. Expensive laboratory analyses are reserved for samples of
known representativeness to answer questions that the less-expensive analyses cannot address.
High numbers of less-expensive analyses are used to develop the CSM and manage sampling
uncertainties; fewer, carefully selected, fixed-laboratory analyses are used to manage analytical
uncertainty (as illustrated later in Figure 7). In this way, the Triad approach uses a second-
generation data quality model that breaks with the practice of using analytical uncertainty as a
surrogate for overall data uncertainty. By explicitly managing sampling uncertainty, the Triad
keeps the project team focused on all sources of data uncertainty and guides the selection of
investigation techniques to keep decision errors within tolerable limits.
It is important to remember that all analytical methods contain some degree of purely analytical
imprecision, even on a perfectly homogenous, well-behaved matrix. Repeated measurements of
the same sample or extract will provide slightly different results, no matter how good the
method. Analytical performance is further complicated when matrices are composed of mixtures
of components that interfere with contaminant extraction or detection. The composition of
typical site matrices (such as soil, groundwater, and wastes) is complex and variable in ways that
affect the repeatability of the analysis. For example, soil analysis generally produces more
measurement uncertainty than the analysis of water. The Triad approach encourages project
teams to be realistic when determining during systematic planning the degree of analytical
imprecision that can be tolerated in the decision-making process. The relevance of analytical
imprecision should be balanced against the imprecision in the data set contributed by real-world
heterogeneity. The goal is to generate data that are representative for their intended use.
Judicious mixing and matching of sampling and analytical options allows data generation to be
representative and economical. This approach to analytical method selection is equivalent to
EPA's Performance-Based Measurement System (PBMS) initiative, which is discussed in more
detail in Section 3.2.
The remainder of Section 2 provides additional information on the three legs of the Triad.
2.5 Systematic Project Planning
Many in the environmental community have recognized the need for systematic project planning
as reflected in the EPA's data quality objective (DQO) process, the U.S. Army Corps of
Engineers' (USACE) Technical Project Planning (TPP) Guidance (USAGE 1998), and others.
Too often during the course of performing environmental investigations, insufficient attention is
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directed to establishing clear objectives for the work, sometimes leading to unproductive
investigations that fail to efficiently gather the information necessary for scientifically defensible
decisions.
Systematic Project Planning Is the Key
The dynamic work strategy and real-time measurement technology components of the Triad
approach may not be applicable to some sites. However, systematic project planning to
establish clear objectives is essential for all environmental restoration projects.
Project teams should consider known or potential cleanup goals for a site from the earliest
planning stages. Often cleanup goals will not yet be established or accepted, in which case values
obtained from regulatory guidance (such as EPA Preliminary Remediation Goals [PRGs],
maximum contaminant levels [MCLs], state action levels, etc.) or from preliminary site-specific
screening risk assessments can be used Consideration of cleanup goals may need to be combined
with discussion of potential institutional controls (deed restrictions, etc.) if consistent with the
intended land use. Where possible and appropriate, the project planning should also identify
potential remedial responses. Consideration of corrective action at this stage of the project allows
for the earliest possible collection of specific data critical for evaluation of the potential remedial
activity. Planning should detail how background conditions will be evaluated. For example,
systematic planning can establish how background concentrations of naturally occurring metals
will be calculated and used.
Optimization of data collection is a central theme of systematic project planning; however, it also
includes many familiar tasks such as preparing for smooth workflow, ensuring the health and
safety of field teams and local residents, procuring necessary contractor services, acquiring rights
of entry, involving the public, and other related activities. Related to project workflow
considerations is the early identification of key decision points that can result in significant
alterations to the CSM. For example, discovery of a preferential pathway could result in a major
reappraisal of likely contamination migration pathways and necessitate immediate modifications
to the investigation strategy.
Another familiar theme that is emphasized in systematic project planning is the need for quality
control. The project QC program must be comprehensive enough to detect deviations from
expected performance and to allow for estimation of sampling and analytical uncertainties, as
well as their impact on decision making. The actual quality will often vary by collection/
analytical technology and in accordance to the type of decision to be made. Varying the levels of
analytical quality through the mixing and matching of methods offers potential cost and time
savings, but the added complexity to the QC program must be carefully managed.
Sample collection and analysis methods must be shown appropriate to specific project conditions
and applications. A pilot applicability study (called "demonstration of methods applicability" in
SW-846) can be an important aspect of project QC that should be considered during the planning
stage. This activity is recommended in Chapter 2 of SW-846 when using all analytical methods,
including traditional fixed-laboratory methods, because of the complexity of waste-related
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matrices. A demonstration of methods applicability can be critical to determine whether a
particular field method is appropriate to an intended application.
Establishing a project team with a cross section of necessary skills and experience is of
fundamental importance to successful project planning. However, technical skills alone are not
enough, and the team must include regulators and stakeholders from the outset to ensure that all
parties participate in the development of the project goals. ,
The project team should begin its planning by gathering and organizing available site and
regional data. The use of environmental data management systems (databases, geography
information systems [GIS], etc.) will often be very helpful in accomplishing this task. Next the
team will develop a CSM or various depictions of the site model to convey competing
alternatives or complementary levels of site detail. For example, a small leaking UST site may
need only a limited CSM focused on the shallow vadose zone and a small number of potential
receptors. Conversely, at a complex site where large amounts of a very mobile contaminant have
been released to the environment, development of a comprehensive CSM may require integration
of geologic, hydrogeologic, geochemical, and potential receptor models.
For those situations where an environmental consultant will be retained to conduct the project,
the earliest possible consideration should be given to preparing a scope of services that will
ensure formation of a team with the necessary skills. The project scope of services should
contain language highlighting the overall approach to the investigation, thereby requiring that
some planning be conducted prior to contract award. In cases where new and innovative
investigation technologies may be under consideration, it is especially useful to discuss options
with potential vendors prior to finalizing the scope of services.
In summary, systematic project planning includes familiar project preparation activities
combined with several important new tasks, such as early determination of action criteria and
identification of key decision points. To successfully apply the Triad approach, these new tasks
must be fully integrated into the planning process, and the project team must not abridge the
planning process with the hope that problems can be corrected later. Failure to fully embrace all
facets of systematic project planning can result in compromised projects that fail to achieve the
desired project outcome.
2.6 Dynamic Work Strategies
Dynamic planning documents differ from conventional work planning documents in that they
contain decision logic enabling the field team to change or modify site activities as required to
achieve the project objectives in the face of potential confounding site complexities. This
flexibility does not necessarily require that all decision makers be present in the field, only that
they be accessible to support the field crew. Telecommunications advances permit the real-time
sharing of data, diagrams, and maps anywhere. Many Triad projects are entirely successful even
though various team members are scattered across the country. The rapid pace of Triad field
projects means that work is fairly intensive while it is occurring, but it spans a shorter period of
time. An implicit goal is to complete the field work in as few mobilizations as possible. Dynamic
strategies do this by providing contingencies to actually change or modify the field activity
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quickly as the investigation proceeds. Since project cost is proportional to time invested, it is
important that the adaptive work plan be developed to allow the investigation to proceed as
quickly as possible. This approach requires close involvement by the project team and processes
to allow for rapid data evaluation and decision making. The use of environmental data
management systems can play a large role in making the investigation a success.
A critical feature of any work plan document prepared using Triad principles is clear articulation
of project goals and the rationale behind each proposed activity. Work planning documents for
Triad projects should include discussion of the following:
• decision goals,
• the initial CSM,
• decision uncertainties,
• mechanisms to manage decision uncertainties and refine the CSM,
• data needs to address decision goals, and
• mechanisms to address data (sampling and analytical) uncertainties.
The word "dynamic" describes the flexibility or adaptability of the intended flow of work
activities. There is a tendency to use this term to title work documents, but that may not be a
good idea. Work plan documents go by many different names, such as "field sampling plans"
(FSPs), "sampling and analysis plans," "quality assurance project plans," "remedial action
management plans" (RAMPs), and others. The naming convention for project planning and
reporting documents is often specific to the program or the contractor. The Triad approach does
not change that. It is inadvisable to title a document "Dynamic Work Plan" simply because it is
written using a flexible or dynamic decision logic. Experience has shown that doing so causes
confusion. It is not clear whether a reference to the "dynamic work plan" refers to a particular
paper document or to the decision logic or strategy that underlie behind the written plan.
Remedial investigation plans, RAMPs, FSPs, QAPPs, SAPs, health and safety plans (HSPs),
community relations plans, etc., may all be written to follow an adaptive or dynamic decision-
making strategy. Keep in mind that each planning document (whether a RAMP, QAPP, or HSP)
supporting a particular Triad project must be written to be harmonious with the overall dynamic
work strategy. For example, simple wholesale adoption of an HSP from a previous non-Triad
project into a Triad project will certainly create inconsistencies with the overall flow of work
activities written into the SAP or RAMP and may cause planning documents for the same project
to conflict with each other.
Triad Work Planning Documents
In addition to the usual elements that comprise a conventional work plan, flexibly written
work planning documents supporting a dynamic work strategy contain
• decision logic that adapts the investigation approach to changing conditions,
• mechanisms for rapid project team communication and decision making, and
• real-time data management.
It is not a good idea to use "Dynamic Work Plan" as the title of a document.
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The naming of documents or the parceling of activities between various documents is not
important to the Triad approach. What is important is that planning documents discuss how
overall decision uncertainty will be managed. When environmental data are collected,
investigation elements that will address uncertainty should be detailed (such as what sample
support will be representative of the decision or how to minimize variance by separating and
delineating distinct contaminant populations). For those projects where statistical measures are
compared to action levels, the statistical procedures must be identified in the work plan. In some
cases multiple statistical procedures combined with professional interpretation may be necessary.
QC considerations will include familiar checks on fixed-laboratory analysis but will be expanded
to include all investigation techniques, such as geophysical methods, direct-push lithologic data
evaluation, in situ contaminant measurements, and field-based analytical methods. "QC" is used
here in the generic sense encompassing varied definitions of quality assurance (QA) and QC.
The goal of the QC program will be to produce data of known quality that is commensurate with
achieving project decision goals and helps the project team understand data variability.
A dynamic or adaptive work plan contains the same kind of QC measures associated with a
conventional approach; however, the application may be more complex. Multiple field analytical
technologies are typically used in conjunction with fixed-laboratory analysis techniques, with
each managing different components of data uncertainty. It is often advisable to evaluate some
QC data very early during the investigation. For example, it may be desirable to confirm that an
on-site method is performing as expected soon after it is used because real-time decisions depend
upon its performance. "Adaptive quality control" describes QC procedures that support higher
frequencies of QC samples when the uncertainty is high and lower frequencies when there is
greater confidence in the analytical performance.
Dynamic work strategies allow a sample-by-sample evaluation of results, if desired. Results can
be assessed in real time for their value to CSM development and to project decisions. If there is a
conflict between a result and the current CSM, there are two possibilities: either the result or the
CSM is wrong. Within an adaptive work plan it is a simple matter to quickly double-check and
resolve an incompatible data result. Something may have gone wrong with the analysis or the
sampling. Perhaps an equipment problem has developed that needs to be rectified. If the result is
confirmed to be correct, then the CSM needs to be modified. Incompatible results are valuable
clues to detect errors or false assumptions in the CSM.
Better Quality Control
Triad systematic planning revolves around the identification and management of things that
can cause decision errors. This is the essence of quality control.
Quality control within the context of a dynamic work strategy is much more effective at
catching mistakes than traditional work strategies relying on static work plans and fixed-
laboratory analyses. Results are immediately compared with the current CSM.
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Real-time checks of data compatibility with the CSM are a powerful QC procedure seldom
available to traditional projects using standard laboratory methods. Much of the QC performed
with traditional analyses tries to compensate for the fact that the analyst must work blind, having
little or no knowledge of the intended data use or project uncertainties. In turn, the data user
interacts with the analyst only through written reports that may leave many questions
unanswered. Traditional paradigms for regulatory oversight of analytical data were created based
on this mass-production mode of most fixed-laboratory analyses. The operator seldom knows
whether results make sense from the project standpoint, whether detection limits are too high, or
whether simple method modifications (such as adding another calibration standard to extend the
method's quantitation range) could produce much more useful data. Batch-based QC checks may
not pick up sample-specific problems if the QC sample run with the batch was not from the same
site or was 18 samples away in the analytical run. In contrast, Triad practitioners have greater
opportunity to detect and rectify problems before errors lead to costly mistakes. For example,
Triad projects sometimes have access to two different real-time methods that are able to cross-
check and confirm each other's results. One example is using an on-site GC-MS primarily set up
for polycyclic aromatic hydrocarbon (PAH) analyses to verify detections of polychlorinated
biphenyls (PCBs) indicated by an immunoassay kit during the same project.
Providers of Triad Analytical Services
Bring vital expertise and participate in the up-front systematic planning.
Interact closely with data users during field implementation.
Routinely adapt their method procedures and QC checks (maintaining accountability and
documentation) to manage uncertainty to match the specific needs of the project at that
moment in time.
Regulatory programs seeking to support Triad projects will be challenged to adapt their oversight
procedures to acknowledge the power of CSM-data compatibility checks. Inflexible
requirements for QC can be counterproductive. Rather, QC can have its own dynamic decision
tree written into the QAPP for regulatory approval. Only unplanned deviations from the
approved options would require additional regulatory oversight. Some QC checks based solely
on the need to compensate for the limitations of routine fixed-laboratory analysis may be
superfluous for Triad projects. Requiring certain QC checks simply because they appear on a
one-size-fits-all fixed-laboratory checklist (but add no value toward managing data uncertainty at
the project decision level) will waste resources that could be better used increasing the sampling
density to perfect the CSM.
Dynamic Work Strategies Alone Are Not the Triad Approach
Using the Triad approach means that systematic planning clearly identifies project decision
goals and that decision and data uncertainties are actively managed. Dynamic work strategies
make this level of effort and project quality both achievable and affordable.
It is possible to use a dynamic approach without doing systematic project planning and
focusing on uncertainty management, but that is not the Triad approach.
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On the other hand, QC checks seldom used now (such as mechanisms to detect and control for
sampling variables) are very important for Triad projects. When approving work plans for Triad
projects, regulators should expect to see a concise list of planned QC checks, along with brief
descriptions of the role each is intended to play in managing uncertainty in the data, the CSM, or
the project decisions.
2.7 Real-Time Measurement Technologies
As mentioned before, the ability to gather a large number of samples at a site helps to reduce
uncertainty in the CSM. To achieve this objective, the environmental community must provide
greater acceptance of data generated in the field, which can produce more information in a
shorter amount of time than fixed-based laboratories. The increased use of real-time analytical
procedures, combined with changes in the emphasis in data quality procedures, will be a
fundamental shift in thinking for many environmental professionals.
Field Methods Alone Do Not Make a Triad Project
Just as using a dynamic work strategy alone does not equate to using the Triad approach; nor
does the sole use of field methods. Systematic project planning to select the right analytical
methods and to develop proper QC protocols is essential to Triad's goal of managing
uncertainty.
Real-time measurement technologies are the third element of the Triad because real-time data are
necessary to support real-time decision making. Many people mistakenly believe this leg of the
Triad refers only to things like test kits and x-ray fluorescence (XRF), but the term encompasses
also the technologies that support data management, processing, interpretation, and sharing.
Because the technologies used by Triad projects often generate very large numbers of data
points, electronic tools to reliably handle and manipulate this volume of data are critical. For
example, open-path air monitoring systems and subsurface geophysical detection tools deployed
in situ via direct push can generate thousands of individual data points that must be assimilated
and manipulated by computer to provide the full benefit of their real-time imaging capabilities.
Fortunately, data management tools have become more available in recent years, and
experienced Triad practitioners are already exploiting them.
QC for field-generated data and for data management tools is a critical aspect of the Triad
approach. The wide range of available and emerging field analytical techniques and the uses to
which they may be put make it impossible to prescribe blanket requirements for QC. Field
techniques now range from simple yes-no detection of contaminant presence to highly
sophisticated and quantitative mass spectrometers. The value of the information cannot be
judged by the analytical rigor of the method, as even simple detection tools can be highly
valuable for refining the CSM. The exact QC checks to be employed depend on the nature of the
technique and the way the information generated will be used. Qualitative data uses, e.g., those
that support a general site (screening) assessment or refine the CSM, may rely on the data's
general agreement with expected CSM as a form of verification. However, in general, the
validity of all in-field measurements should be established by QC procedures that demonstrate
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that instruments are calibrated (if appropriate) and functioning properly. When data uses are
quantitative in nature, the assessment of the numerical values produced becomes more critical.
QC protocols should include both instrumental and matrix-specific QC checks to verify the
equipment is not only working properly, but that the method shows acceptable performance with
the project matrices. Routine QC checks applied might include an evaluation of potential cross-
contamination sources (e.g., various blanks), limits of quantitation (LOQ)/detection limits (DL)
in the project matrix, or the bias from matrix interferences. Accuracy of the method should be
checked at project decision levels to assess the need for establishing intervals of decision
uncertainty and triggers for appropriate split sample analyses. A series of duplicate samples can
be executed to evaluate sampling and analytical procedures, as well as characteristics of sample
heterogeneity and other sample support issues. There are diverse ranges of options for
documenting that a tool is performing as intended. Under the Triad approach, project planners
are expected to determine which options make logistical and technical sense for their tools, their
work plan, and their project constraints. They must be prepared to provide full justification and
documentation for their choices.
A frequent QC technique that should be avoided is relying on an arbitrary, fixed percentage of
split "confirmation" samples between the field and fixed-lab analysis as the sole QC to establish.
reliability of the field data. In practice, this tactic may fail to manage data and decision
uncertainties. It also creates an economic disincentive for increasing the sampling density by
using the less-expensive methods. Another serious deficiency of this arbitrary confirmation
sample approach can be the untimeliness of the comparison of data sets. In a traditional
approach, many times the evaluation of comparability between field and fixed data sets actually
waits until the final report. The Triad instead tries to work real time to optimize the
methods/techniques, understand their limitations, trends, and effects on use. Even the term
"confirmation sampling" is misleading because it assumes that the fixed-lab analysis is correct,
and that may not be the case.
Avoid Requirements for Fixed Percentages of Split Samples
Arbitrary percentages of QC samples, such as "10% split sample confirmation," nearly
always fail to provide convincing evidence to "confirm" that field data are reliable. Split
sample evidence is usually equivocal. Split samples are not a substitute for in-field method
QC to demonstrate the method is working properly. Split samples should be selected on the
basis of the analytical information these samples provide to enable interpretation of
nonspecific analyses and to provide the low reporting limits and analyte-specific data needed
for risk assessment or to demonstrate regulatory closure compliance.
Relying on confirmation by the fixed lab ignores the many sampling and analytical variables that
cause analytical results to vary (as discussed in Section 2.4.4.). Although split samples can
provide important information, arbitrary percentages and arbitrary selection of those splits fail to
manage uncertainty for both the field and fixed-lab data sets. Managing uncertainty with the
Triad approach requires that a rationale for the number and selection of split samples be
developed and followed. Field analyses are generally not a direct substitute for fixed-laboratory
analysis and so cannot be expected to always achieve a one-to-one correspondence. They
complement each other for the purpose of refining the accuracy of the CSM.
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Figure 6 illustrates that both traditional fixed-laboratory methods and alternative, less-expensive
methods have certain strengths and weaknesses. If used independently of each other, both
method types produce data sets with significant amounts of uncertainty. The use of either
laboratory or field analysis in isolation may result in "screening quality data," which equates to
excessive decision uncertainty (Crumbling 2003b).
Costly "definitive"
analytical methods
Cheaper (?screening?)
analytical methods
Low detection limits + analyte specificity
High spatial density
Manages analytical uncertainty
= analytical representativeness
= analytical quality
Manages sampling uncertainty
= sampling representativeness
= sampling quality
"Definitive" analytical qualitys
Screening sampling quality
^'Definitive" sampling quality
Screening analytical quality
Figure 6. The strengths and limitations of analytical methods (Crumbling 2003b).
If used alone, fixed-laboratory methods are generally too expensive to get a high enough
sampling density to characterize heterogeneous contamination and build confidence in the CSM.
Therefore, the representativeness of those high-analytical quality data points is in doubt. On the
other hand, a nonspecific and/or biased field method can be useful to understand contaminant
distributions and spatial patterning to support the CSM. The data may even be useful for making
some project decisions where there is confidence that the method correctly indicates areas either
well above or well below a regulatory action level. However, there may be too much analytical
uncertainty to support confident decision making near the action level or to support risk
assessment or a demonstration of regulatory compliance. Note that this generalization may not be
true for those field methods based on rigorous analytical techniques, such as field-portable GC-
MS for VOCs, where the analytical quality may equal or surpass that of a fixed laboratory.
The solution to this dilemma is to use field and fixed-laboratory analyses in a collaborative effort
that maximizes their respective strengths but compensates for their respective weaknesses. This
approach is illustrated in Figure 7. Less-expensive methods are used to increase sampling density
and build the CSM. Where unresolved analytical uncertainty remains, samples are selected for
fixed-laboratory analysis. These samples are selected based on their representativeness (already
established by the refined CSM) to support specific decisions for which more analyte-specific
information or more accurate quantitation is required. Collaborative data sets complement each
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other by managing all sources of data uncertainty, both sampling and analytical, important to site
decision making (Crumbling 2003b).
Cheap Gab? field?
screening? rigorous?)
analytical methods
1
High-density sampling
Manages CSM
and sampling
uncertainty
Costlier rigorous
analytical methods
1
Low detection limits +
analyte specificity
Manages analytical
uncertainty
Figure 7. Collaborative data sets increase data quality in heterogeneous matrices
(Crumbling 2003b).
Care should be exercised if databases are used to store collaborative data sets. The two separate
data sets should not be indiscriminately mixed together because they often will not be
statistically comparable. Especially when nonspecific screening methods (such as immunoassay
test kits for PCBs or pesticides) are used to build the CSM, results from the test kit are seldom
numerically comparable to analyte-specific fixed-laboratory data. In other cases, differences in
sample volume or processing may create noncomparable data sets. Blind merging of the two data
sets, such as in statistical programs to calculate means and standard deviation, should be avoided.
This situation does not in any way invalidate the usefulness or reliability of the data for making
project decisions. One data set is used to build the CSM; the other is used to manage any
lingering analytical uncertainties from the first data set. The confidence provided by
collaborative data sets is much higher than can be achieved by either data set alone.
The increased impetus the Triad places on field analysis should not imply that laboratory
analysis is of lesser importance. Data derived from fixed laboratories continue to play an
important role in analysis of contaminants not currently amenable to field analysis and to
evaluate the effectiveness of analytical data obtained in the field. Samples split between the field
and fixed laboratory are required when comparison analysis is needed to help interpret results
from nonspecific or biased analytical methods. Split samples, especially for solids, seldom match
closely, however, for a number of important reasons. For example, different analytical
techniques may be measuring different things, or the sample support may be different. Some
matrices and analytes are more difficult to homogenize than others. For reasons covered in
Section 2.4.4, heterogeneity at microscales makes it nearly impossible to split samples so that
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Real-Time Measurement
Technologies
• Faster decision making
• Fewer uncertainties
• Better conceptual site model
• Better use of resources
each analytical method is presented with the exact same
concentrations of analytes. This is another reason why
confirmation sampling seldom works if a fixed percentage
of splits is the only QC being performed to support the
field data.
The terms "screening" and "confirmation" are used widely
by the environmental community, especially in the context
of sampling and analytical activities. The ambiguous use
of both terms easily causes confusion. Confusion is avoided by being clear about what activity is
being described. The word "confirmation" implies the intent to manage some aspect of
uncertainty. When postremediation samples are analyzed at a fixed laboratory, these results are
used to "confirm" that the cleanup was successful and that regulatory action levels are met (thus
managing uncertainty regarding the completed cleanup action).
The term "confirmation" is also used to refer to reducing uncertainty regarding the performance
of specific sampling and analytical procedures. Confirmation of analytical performance is often
done by homogenizing samples that are then split between different laboratories or analyzed by
different methods by the same laboratory. There are a variety of reasons why split sample
analysis is performed:
• provide oversight of a laboratory or analyst performance;
• evaluate the comparability of different analytical, sample preparation, and extraction
techniques; and
• provide analyte-specific results to guide the interpretation of results produced by test kits that
do not produce analyte-specific data.
Because of the confusion that can arise when term "confirmation" is used ambiguously, Triad
practitioners try to be very clear about what exactly is intended to be "confirmed" when split
samples are used. More accurate phrases, such as "comparison analysis" or "establishing the
comparability between data sets" are often used by Triad practitioners rather than the more vague
"confirmation analysis." When performing any kind of "confirmation analyses" under the Triad
approach, first be clear about what you intend to "confirm" and what uncertainties you are
expecting to manage. Secondly, whenever split samples are used, consider the impact of
heterogeneity on your ability to compare or interpret results from the splits. Control for that
variability by careful homogenization if you can, but know that no homogenization procedure is
perfect. It is a good idea to determine how much variability is occurring simply from imperfect
homogenization. This can be done by doing "control splits." Control splits are prepared the same
way as splits between the fixed lab and the field lab. However, the same analyst analyzes both
splits at the same time in both the fixed lab and the field. Since the analytical variability is thus
held constant, you will be able to estimate how much variability is due to imperfect sample
splitting. The analytical results for splits between the field and fixed lab cannot be expected to
match any better than this.
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Field Methods Used in a Fixed Laboratory
There can be advantages to performing methods typically associated with the field in a fixed
laboratory. If a fixed lab is nearby, the option exists for running real-time analyses in a
controlled environment, thereby avoiding the costs of support facilities on site. This may
improve method performance while retaining the advantages of rapid turnaround and greater
sample numbers.
A detailed description of all available real-time measurement technologies is not within the
scope of this document. A more comprehensive list and descriptions are available at the Web
sites noted in Section 10. Following is a partial list of some of the categories of geophysical and
analytical methods available:
Geophysical techniques:
• borehole techniques (gamma-gamma probe, for example)
• electrical (resistivity)
• electromagnetic (conductivity, ground-penetrating radar)
• magnetics
• magnetotellurics
• seismic (reflection, refraction)
• borehole tomography
Analytical techniques:
• DNAPL detection techniques such as hydrophobic dye and sheen tests
• mobile gas chromatography (SW-846 8000 methods series)
• mobile mass spectrometers (Draft SW-846 Method 8265)
• x-ray fluorescence (SW-846 Method 6200)
• immunoassay (SW-846 4000 methods series)
* colorimetric (a number of SW-846 methods in the 8500 and 9000 series)
• in situ probes such as laser-induced fluorescence (LIF), and the membrane interface probe
(MIP)
• electrochemical methods (SW-846 Method 7472 and Method 9078)
• ion-specific electrodes (SW-846 9200 methods series)
• open-path techniques (ultraviolet differential optical absorption spectrometry, Fourier
transform infrared spectroscopy, and tunable dye lasers) for atmospheric monitoring for
fenceline, landfill, and vapor-intrusion detection (EPA 2003e)
Geological techniques:
• cone penetrometer test (CPT) logging
• direct-push down-hole video
2.8 Other Triad Approach Considerations
The use of the Triad approach to conduct a project may introduce a number of new concepts to
project teams. In some cases these concepts will require changes to long-established business
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practices or acquisition of new capabilities. While departure from familiar procedures may be
daunting, the potential improvements to quality and cost-effectiveness are significant. It should
be noted that development of tools to facilitate Triad implementation is an ongoing process.
Some of the considerations linked to application of the Triad approach are described below.
2.8.1 Need for Senior/Exfterienced Field Personnel
When applying the Triad approach, field teams are required to evaluate site data as they become
available. This requires that experienced technical staff (geologists, chemists, engineers, etc.) be
either in the field or available via telecommunications to guide the unfolding investigation in real
time as directed by the preapproved decision logic and contingencies identified in the project
work plans.
2.8.2 Change in Approach to Quality Control
Investigations conducted in accordance with traditional methods apply most of the QC effort
towards the validation of chemistry data originating from fixed laboratories. The Triad approach
advances the idea that a better investigation can be achieved by identifying all sources of
uncertainty. The Triad approach emphasizes development of a QC plan that minimizes the
overall uncertainty without undue emphasis on fixed-laboratory data at the expense of equally
important considerations such as sample density, location, and representativeness. QC data are
explicitly leveraged to address uncertainties in the data and in the CSM that are relevant to
project decisions. Within the context of an adaptive sampling and analysis program, the intensity
of QC checks is adjustable in real time (according to a preapproved rationale) depending on the
kinds and levels of uncertainty present at each milestone of project implementation.
2.8.3 Greater Use of Multidisciplinary Investigation Teams
Traditional investigation processes allow generous amounts of time for various disciplines to be
consulted during the course of data evaluation. Conducting an investigation using the Triad
approach requires that significant data evaluation occur in the course of the field work, which
necessitates that all needed disciplines be included on the project team from the earliest phases of
the project,
2.8.4 Early Consideration of Land Use. Action Levels. Etc.
Successful systematic project planning requires project team and stakeholder consensus on
objectives prior to conducting the field work. Future use of the site must be agreed upon so that
the data obtained support evaluation against action levels consistent with that use. It is
sometimes possible for the team to agree on a range of future land uses if the specific land use is
not known. Data must be collected with a specific future land use (or range of uses) in mind.
Later changes in land use may require reevaluation. Notwithstanding the foregoing discussion,
some states have regulations that require sites to be remediated to residential use levels
regardless of the future use. Consideration must be given to state regulations regarding future
land use.
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2.8.5 Need for Data Management Tools
Field teams often need tools for the management and evaluation of the increased amount of data
generated during Triad investigations. These software tools may include some form of database,
GIS, and data visualization applications (such as Surfer, RockWorks and EarthVision). The
successful utilization of these applications may require database and computer data evaluation
team members to be involved in both planning and implementation of the field work.
2.8.6 Research and Training Needed
A fundamental tenet of the Triad approach is to improve investigation quality by reducing
decision uncertainty. Decision uncertainty can be reduced even further with improvements in
statistical or visualization tools that display in real time and quantify geologic variability,
contaminant fate and transport, preferential pathways, and human activities generating
contamination. Additional training, guidance, and software tools (decision support applications)
are needed to assist all project teams to successfully address these issues.
2.8.7 Not All Projects Are Amenable to Full Application of the Triad Approach
Although systematic planning has been mandated by EPA for years and managing the
uncertainty in decisions and data are fundamental to any successful, science-based project, not
every project is amenable to a real-time, accelerated approach. Legally contentious projects may
be required to move very slowly and deliberately. There may be economic disincentives to
spending more money in the short run to save money in the long run. When one party saves
money on a cleanup, another party is losing money that would have otherwise been spent. As
long as traditional approaches are considered satisfactory by regulatory agencies, non-Triad
approaches are still available to anyone who wishes to use them. Since employing the Triad can
require significant changes to familiar ways of doing business, adoption of Triad concepts might
be phased in gradually to allow practitioners to become more proficient. Alternatively, staff
could "practice" by using Triad strategies on smaller discrete tasks within larger projects that
would be too complex if tackled whole. Lastly, dynamic work strategies and on-site methods are
often used outside of the decision uncertainly management umbrella of the Triad approach.
2.9 Summary
The three legs of the Triad—systematic project planning, dynamic work strategies, and real-time
measurement technologies—utilize both established and new ideas and methods. The key new
components include the following:
• greater efforts to define project goals,
• a renewed emphasis on the CSM and sample representativeness,
• greater application of field analytical techniques to increase sample density,
• adaptive QC to ensure representative data of known quality,
• dynamic sample collection programs, and
• increased effort to define necessary analytical quality.
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The goal of the Triad approach is to improve investigation effectiveness. This is achieved by
focusing on clearly defined goals up front and incorporating recent technological advances. It
provides the potential for more efficient, less-expensive site characterizations that generate data
of improved quality and more definitive conceptual models, leading to more decision confidence.
The Triad approach is an outgrowth of the natural evolution of the site restoration industry in
response to imperatives that include evolving economic considerations (such as environmental
insurance coverage and a community focus on redeveloping/reusing sites) and improved science
and technology for both characterization and remediation. Many federal and state programs have
recognized the impetus for change and improvement, as shown by the large number of program
initiatives under development that reflect the universal principles embodied in the Triad
approach.
3.0 RELATIONSHIPS TO EXISTING GUIDANCE
Knowing that EPA and other organizations have developed a number of process streamlining
initiatives, environmental professionals may wonder how the Triad approach relates to these
programs. This section addresses that issue both generally and for several specific programs. As
discussed previously, the Triad approach is not a new environmental program. The Triad
approach brings together into a single integrated package concepts articulated in a variety of
prior initiatives. These include the Observational Approach, the DQO process, Technical Project
Planning (TPP), Expedited Site Characterization (ESC), QuickSite, Accelerated Site
Characterization (ASC), ESC using the Ma Approach, Streamlined Approach for Environmental
Restoration (SAFER), Expedited Site Assessment (ESA), and Superftmd Accelerated Cleanup
Model (SACM). These and other approaches have been described by various parties including
EPA, DOE, ITRC, the Department of Defense, universities, and private-sector consulting firms
(TetraTech EM, Inc. 1997). The Triad approach is consistent with any guidance or approach that
recognizes the following:
• Site decisions are made based on scientific, economic, social, and political considerations.
• Data quality concepts need to emphasize sampling representativeness instead of focusing
solely on laboratory analytical procedures.
• Good science requires that data be shown to be representative of the target populations at the
same scales as the decision to be made about those populations.
• Good science also requires controlling variables that introduce data uncertainty.
• Data collection should be tailored to the specific decisions developed during the systematic
planning process.
• Analytical and sampling plans are most efficient when they can adapt to unexpected
conditions.
• Data representativeness both determines and is determined by the CSM and project
decisions.
• Appropriate scientific/technical expertise is required throughout project planning and
implementation to address complexities and direct activities. Otherwise, identification and
management of relevant uncertainties does not occur, data quality is frequently mismatched
to data use, sound science is not achieved, and decisions may be made in error, wasting time,
resources, and public good will.
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Acceptance of these concepts constitutes an ongoing evolution of regulatory thought and
technical approach. At the birth of cleanup programs, explicit management of scientific sources
of uncertainty was exceedingly expensive, if possible at all, because the scientific foundations
and technological capabilities to do so were lacking. In recent years this situation has changed,
and a number of practitioners have developed initiatives to address some of the same key
concepts as the Triad. The sections that follow detail some of these other initiatives and related
processes.
3.1 The Triad Approach and the DQO Process
One obvious question is whether the Triad approach differs from the data quality objective
initiative also promoted by EPA. The answer is that the Triad approach is entirely consistent with
the DQO process as articulated in EPA guidance. Both are methods to structure the project
planning processes. There is a slight difference in that the DQO process focuses primarily on
data collection, whereas systematic planning under the Triad approach is far broader in scope.
Although data quality is an extremely important aspect of the Triad approach, it is but one
aspect. The Triad approach explicitly considers remedial design, the flow of work tasks (such as
implementing the dynamic strategy), stakeholder concerns, long-term monitoring designs, and all
other types of site-related activities to be within the scope of "systematic project planning" and
integral to the process of identifying and managing decision uncertainties. Within the broader
scope of Triad project planning, an accurate CSM is used to decide how classical statistics and
geostatistics will be used for evaluating data. Some practitioners may call this "the DQO
process," whereas other practitioners might not. What the systematic planning process is called is
less important than the fact that it is done (EPA 2000b),
It is important to acknowledge, however, that confusion has arisen because the DQO process has
not been consistently applied by the environmental community. Many practitioners have been
unclear about how to utilize some elements of the process, such as statistical hypothesis testing.
Although the originators of the DQO process do not consider statistical hypothesis testing to be a
requirement of using the systematic planning aspects of the DQO process, some DQO
proponents have so strongly emphasized classical statistics and hypothesis testing that they have
become inseparably linked to DQOs for many. While hypothesis testing can be a very valuable
tool for some aspects of risk and compliance decision making, many professionals realize that
not all environmental scenarios faced by project managers are amenable to classical statistical
modeling. This idea has caused some to dismiss the DQO process in its entirety, an unfortunate
reaction since the planning structure that the DQO process provides is very useful. Classical
statistical models are important tools when applied properly and guided by a CSM.
Originally, the DQO process was named the "Data Quality Objectives for Environmental
Decision-Making." Although much more intuitively meaningful, the name became truncated to
"data quality objectives," and over time, the important conceptual linkage between data quality
and the project-specific decision-making process was muted (Crumbling 2003a). The term
"DQO" was originally intended to convey the idea that project objectives (i.e., decisions)
determined what data quality was needed. In other words, DQOs were supposed to describe the
project objectives that would drive the selection of sampling and analytical methods, when all of
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the factors impacting the relationship between data quality and decision quality were considered.
The intent behind the DQO process is wholly consistent with the Triad approach.
When the DQO process was developed in the 1980s, there were few tools that could allow the
DQO process to be executed as it was intended within available budgets. For example, statistical
calculations that took true matrix heterogeneity (and thus sampling variability) into account
determined that hundreds to thousands of samples were required to reach statistical confidence
for site decisions. The cost of laboratory methods available at the time made large numbers of
samples cost-prohibitive for most projects. Given real constraints on their ability to cope with
sampling uncertainties, many began to think of DQOs in terms of strict control over analytical
quality. This thinking has resulted in some practitioners now using the term "DQOs" to refer
specifically to requirements for analytical methods and laboratory performance. Another
prevalent outcome is that DQOs (as laboratory requirements) became defined at programmatic
levels that are independent of project- and decision-specific data needs. This development has
contributed to the pervasive misconception that "analytical quality = data quality." Attempts to
clarify DQO terminology for the data user community have been so far unsuccessful at
harmonizing DQO language and usage across the environmental industry (Crumbling et al.
2001). Because of the propensity for confusion and miscommunications, an interagency team
coordinating Triad development avoids DQO language in favor of intuitively meaningful or
descriptive words or terms for which the Triad usage has been clearly defined.
3.2 The Triad Approach and PBMS
The Performance-Based Measurement System initiative described by EPA several years ago and
the Triad approach are completely consistent with each other. As articulated by EPA's waste
programs, PBMS makes the policy statement that any analytical method may be used to generate
data (whether or not it is currently published in SW-846) as long as it can be demonstrated
• to measure the constituent of concern
• in the matrix of concern,
• at the concentration level of concern, and
• at the degree of accuracy necessary to address the site decision.
In other words, PBMS is a formal articulation of the idea that analytical uncertainty should be
managed to a degree commensurate with the overall project decision goals (EPA 2003a). It
might be noted that this is also the intent of the DQO process. Although a PBMS strategy has
always existed in the language of the SW-846 methods compendium, it has long been
overlooked in favor of simpler one-size-fits-all prescriptive method requirements.
A primary factor contributing to confusion over EPA's analytical strategy is that EPA
encompasses two distinct analytical method programs that function very differently. EPA's
Office of Water programs has a very prescriptive, one-size-fits-all regulation-driven analytical
strategy. While it may be debated whether this prescriptive approach has served the needs of
water programs well, it is very clear that a prescriptive analytical strategy cannot meet the data
quality needs of waste programs and risk-based decision making. Technical and logistical
difficulties posed by the matrices encountered in waste programs render one-size-fits-all
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analytical approaches counterproductive to the goals of protective, yet efficient and economical
site cleanup. Waste programs deal with some very difficult matrices and analytes subject to a
wide variety of decisions about exposure, remediation, and long-term monitoring. Therefore, the
value of analytical and sampling flexibility has long been recognized by the scientists who
developed and maintain the SW-846 methods manual. The PBMS initiative was EPA's effon to
elevate public awareness that the flexibility already inherent in SW-846 and EPA waste program
policies is vital to good science and cost-effective waste programs. The Triad approach builds on
these very same principles, and a PBMS approach is vital to the success of Triad-type projects.
3.3 The Triad Approach and the Dynamic Field Activities Guidance
From about 1998 to present, an interagency Triad team have been pooling their experiences from
actual projects to formulate the Triad approach as a coherent framework. About the same time,
EPA's Superfund program was interested in promoting dynamic work strategies since a number
of innovative Superfund projects using this basic approach had demonstrated cost savings. Semi-
independently of concurrent Triad efforts, the Superfund program prepared a document titled
Using Dynamic Field Activities for On-Site Decision Making: A Guide for Project Managers
(EPA 2003b). This guide includes descriptions of several projects conducted in the 1990s that
used a dynamic field approach. Internet links to the online guide and to the endorsement
memorandum from the Assistant Administrator for EPA's Office of Solid Waste and Emergency
Response are found in Section 10.
Although this first release of the dynamic field activities (DFA) guide has many commonalities
with the Triad approach, there are currently a few differences. In general these stem from the fact
that the DFA guide focuses more on streamlining site activities and field analytical tools and less
on the concepts of uncertainty management and systematic planning. Despite the differences, the
DFA guide makes an important contribution that demonstrates the Superfund program's
approval for dynamic work strategies. The fact that EPA accepts these strategies does not negate
the fact that considerable time and coordination will be required (even within EPA) to restructure
programmatic budget allocations, contracting, staffing, and logistical mechanisms to facilitate
the routine implementation of dynamic work strategies. However, releasing the DFA guide is an
important step in communicating EPA's intention to move in that direction.
3.4 The Triad Approach and MARSSIM
The Multi-Agency Radiation Surveys and Site Investigation Manual (MARSSIM) was
developed by Departments of Defense and Energy, EPA, and the Nuclear Regulatory
Commission. MARSSIM was created to provide guidance for planning, implementation, and
evaluation of environmental and facility radiological surveys conducted to demonstrate
compliance with either a dose- or risk-based regulation (EPA 2000a). The focus of MARSSIM is
on demonstrating compliance during the final status survey, which follows scoping,
characterization, and any necessary remedial actions. MARSSIM describes how to plan
systematically and how to make planning decisions during the seven steps of the DQO process.
Therefore, its connection to the Triad approach is through the DQO process. The Triad approach
is tied to a CSM and is focused on characterization to support a full range of project decisions,
while MARSSIM is prescriptive and focused on compliance.
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3.5 The Triad Approach versus the "Sediment Quality Triad"
The word "triad" has been used by others in the environmental community. Its application to
sediment risk evaluation may cause confusion with the term as used in this document. These two
triads are completely unrelated. The sediment quality triad (SQT) was described by Chapman to
comprehensively evaluate contamination effects on the health of sediment-exposed biota. SQT is
an effect-based technique that involves three components: sediment chemistry, sediment toxicity
testing, and in situ environmental receptor appraisals (Chapman 1996).
3.6 The Triad Approach and the Technical Project Planning Approach
USACE developed the TPP process to improve planning activities associated with hazardous,
toxic, and radioactive waste (HTRW) site cleanup. The TPP process is an example of a Triad-
consistent systematic planning process that involves four different phases of planning activities.
The TPP process is meant to be initiated at the start of activities associated with a HTRW site
and continue through the life cycle of cleanup. The expectation is that the application of the TPP
process will ensure that the requisite type, quality, and quantity of information are obtained to
satisfy project objectives.
3.7 The Triad Approach and Early ITRC Guidance
ITRC has been involved with "accelerated" efforts for site characterization since 1995. In May
1996 the ITRC Cone Penetrometer Site Characterization Task Group published a document titled
Multi-State Evaluation of an Expedited Site Characterization Technology: Site Characterization
and Analysis Penetrometer System Laser-Induced Fluorescence (SCAPS-LIF).
Also in 1996, the American Society for Testing and Materials (ASTM) partnered with the
Accelerated Site Characterization Task Team of ITRC to release a 1997 technology review
summary report that reviewed the accelerated site characterization guide that ASTM was
developing (ITRC 1997). In 1998, ASTM published its Standard Practice for Expedited Site
Characterization of Vadose Zone and Ground Water Contamination at Hazardous Waste
Contaminated Sites (ASTM D6235-98a). In 1997 the ITRC Cone Penetrometer Site
Characterization Task Group published another document, Multi-State Evaluation of the Site
Characterization and Analysis Penetrometer System Volatile Organic Compound (SCAPS-VOC)
Sensing Technologies. ITRC had an ASC team in 1997, which formed a partnership with the
EPA Consortium for Site Characterization Technology (CSCT) to verify technologies and
publish an overview report in January 1998. The focus of the partnership was on verifying
promising new technologies that might be used for rapid assessments in the field. The CSCT was
one of the first pilot programs under the EPA Environmental Technology Verification program.
These early efforts were building blocks that laid the foundation to help support today's Triad
approach. Documents resulting from these earlier ITRC efforts are available on the ITRC Web
site (www.itrcweb.org) and are included in Section 10.
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4.0 ADVANTAGES AND DISADVANTAGES
This section discusses specific advantages and disadvantages associated with use of the Triad
approach. Table 3 summarizes the potential benefits and disadvantages for practitioners to keep
in mind when considering application of the Triad approach.
4.1 Advantages
The advantages discussed below can be documented from the case studies presented later hi this
document. Section 9 presents a summary of the case studies, and Appendix B contains more
detailed information.
Table 3. Summary of advantages and disadvantages
Advantages
Better investigation quality
Faster investigations, restoration, and redevelopment
Lower life-cycle costs
Improved stakeholder communication
More effective cleanups
Disadvantages
Higher up-front costs
Change in approach to data quality
Lack of tools to manage decision uncertainty
Greater need for training about Triad
Negative bias towards field-generated data
4.1.1 Better Investigation Quality
As compared to using the traditional multistage investigation process, applying the Triad
approach allows for the collection of more data supporting a more representative CSM for the
site. Fewer site/data uncertainties will remain uninvestigated, resulting in a better understanding
of site conditions, less decision uncertainty, and better project outcomes.
4.1.2 Faster Investigations
Dynamic work strategies reduce or eliminate repeated mobilizations to the field, with
commensurate reduction in overall investigation costs. The repetitive production and review of
work plans and reports of findings that consume large amounts of time and financial resources
are thereby avoided.
4.1.3 Lower Life-Cycle Costs
Project teams can anticipate that most environmental projects will be successfully completed for
a lower overall life-cycle cost. The Triad approach produces this effect by consistently using
systematic project planning. Improved planning leads to fewer mobilizations to the field, fewer
reports and work plans, rapid resolution of data gaps, and most importantly, shorter overall
project schedules.
4.1.4 Improved Stakeholder Communication
Successful application of the Triad approach encourages involvement by the public from the
earliest stages of systematic project planning. The project should not move to the field until all
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affected parties, including tribes and other stakeholders, reach consensus on goals. The CSM
prepared during the planning is especially helpful in communicating complex aspects of the
project to stakeholders.
4.1.5 More Effective Cleanups
Project teams arrive at more efficient remedial decisions when fewer site uncertainties remain.
Contaminated areas requiring remediation are separated from clean areas not requiring action. In
this way improved site characterizations produce more focused, more effective, and less costly
remedial systems, ultimately achieving significant reductions in overall project costs,
4.2 Disadvantages
4.2.1 Higher Up-Front Costs
Preparation for, and execution of, an investigation using the Triad approach requires more effort
and professional expertise than traditional methods. This difference shifts more funding to early
phases but avoids spreading less effective investigative efforts over longer time periods. In the
Triad approach, greater resources are invested in the initial (and perhaps only) field effort with
the expectation of reduced overall project costs.
4.2.2 Change in Approach to Data Quality
Traditional investigation methods have long emphasized the importance of implementing the
laboratory analytical procedures outlined in SW-846. In addition many environmental
professionals are of the opinion that only traditional laboratory data will withstand legal scrutiny.
The Triad approach recognizes that decision quality data can be obtained by nontraditional
methods and by non-SW-846 methods as long as appropriate QC measures are in place. Some
practitioners may be surprised to learn that many common field analytical methods have been
included in SW-846 since the mid 1990s. Environmental professionals may be reluctant to depart
from prescribed analytical expectations and validation/verification procedures. When procedures
are evaluated for their usefulness and defensibility within the Triad approach, the overarching
goal of managing uncertainty should be used as the touchstone to decide whether or not a given
procedure adds value.
4.2.3 Greater Need for Triad Training
All environmental professionals will need some level of training to effectively implement the
Triad approach. This training should include both general overviews and more specific technical
training. Scientists and engineers involved in preparing or implementing these projects will
especially benefit from training on understanding and managing uncertainty. Federal and state
regulators must be trained to ensure that they can effectively oversee these faster-paced projects.
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4.2.4 Negative Bias Towards Field Generated Data
Many environmental professionals consider data acquired in the field to be a lesser, "screening-
level" quality and therefore unsuitable for site decision making. Actually, with proper QC
procedures, data generated in the field can be demonstrated to be suitable for a wide range of
project decision-making purposes.
5.0 REGULATORY AND OTHER BARRIERS
The Triad approach requires innovative thinking and a flexible approach to planning, work plan
development, and application of analytical methodologies. Regulators are guided in their
oversight work by agency business practices created to enforce state law and regulations. As a
result they operate in a carefully prescribed manner when overseeing projects. These business
practices are often difficult to change due to regulatory policies and/or organizational and
cultural barriers. When implementing the Triad approach, it is important for regulators to remain
aware of implementation issues and any real or perceived barriers. Identification and
understanding of these barriers is a key issue for regulatory acceptance of the Triad approach.
This section presents these obstacles in six categories:
• organizational barriers,
• concerns with real-time measurement technologies,
• conflicts with state law,
• lack of regulatory guidance,
• difficulties of establishing cleanup criteria during initial planning, and
• confusion in associating uncertainty to specific decisions.
The following states participated in the development of this guidance document and contributed
to the following discussion regarding potential barriers: California (CA), Delaware (DE),
Kentucky (KY), Missouri (MO), New Jersey (NJ), Oklahoma (OK), South Carolina (SC),
Vermont (VT), and Wisconsin (Wl).
5.1 Organizational Barriers
Regulatory agencies may have both organizational and institutional barriers to the use of a
conceptual framework like the Triad approach. For a regulatory agency, the Triad approach may
require changes in process, timing, and staffing as well as consideration of new technologies and
ideas. The sections that follow describe some of these issues.
5.1.1 Business Practice Inertia
Regulatory agency procedures, like those in any large organization, can become institutionalized
over time. As state environmental officials recognize the benefits associated with the Triad
approach, it can be expected that more projects will be conducted this way and the concepts will
become established and more widely applied. The New Jersey Department of Environmental
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Protection has recently taken formal steps to allow the Triad approach to be applied to its
projects. This change is discussed in more detail in Section 6.
A number of states (including CA, DE, KY, MO, NJ, SC, VT, and WI) indicated that business
practice inertia is not necessarily foreseen as a barrier to implementation of the Triad approach.
Although all of these states have guidance and procedures for site characterization and
remediation, varying degrees of flexibility are allowed as long as QC procedures are followed.
For example, these states all allow the use of several field analytical methods.
Comments from specific states are as follows:
* CA - California does not anticipate difficulties in implementing the Triad approach if (1) a
proposed investigative technology has the capability to achieve data quality needs that meet
project specific objectives, (2) QC is performed as specified in the QAPP, and (3) the state
remedial project manager and technical staff approve the use of the Triad approach.
• DE - Delaware does have procedures and guidance in place for investigation and cleanup;
however, some flexibility regarding sampling and analyses is allowed. Field methods like
direct-push wells and field analyses are encouraged. Although application of parts of the
Triad is currently taking place, a consistent application of all three aspects of Triad has not
yet begun. Management recently began considering an approach similar to Triad.
• KY - Kentucky is open to new approaches and ideas. Project managers are yet to be
convinced that field analytical methods can achieve the DQOs necessary to make the cleanup
decisions based on human health and ecological risk assessments. Project managers
recognize the benefits of the Triad approach, and in some cases the Triad approach has been
applied within the constraints of agency procedures. Kentucky believes that integration of the
Triad approach with regulatory agency procedures is the way to proceed for Triad acceptance
and success.
• MO - The various environmental programs do have guidance and standard operating
procedures in place and often have procedures for allowing some flexibility within the work
plan. Creating new practices (like those needed for Triad success) is a challenge, especially
for established staff members. The key to overcoming this challenge is to ensure that
adequate QC procedures are documented.
• NJ - Some concern has been expressed among Department of Environmental Protection
(DEP) personnel that it will be hard to change how staff "do business." For initial Triad
implementation, the department is involving only those staff that are flexible and eager to try
a new concept such as the Triad.
• OK - Oklahoma already uses some aspects of the Triad approach without using the term in a
formal sense. It is not a barrier in programs dealing with voluntary closure and brownfield
activities, but programs dealing with Superfund have not accepted this approach in total.
• SC - South Carolina does not anticipate difficulties in implementing the Triad approach. A
proposed investigative technology must be able to attain project specific data quality needs
and objectives, meet QC guidelines specified in the QAPP, and be approved by the project
manager.
• VT - Consultants working in Vermont are primarily state-based, small consulting firms.
Many of these firms are distinguished for the quality of the science they bring to site
investigation. Part of that entrepreneurial spirit is shared at the Vermont Department of
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Environmental Conservation (DEC), in that it manages a broad spectrum of projects with a
relatively small team of scientist-regulators. These consulting firms have played a role in
proposing innovative analytical approaches to site characterization, starting as early as 1991.
Although some consultant clients are willing to undertake dynamic work plan projects,
responsible party apprehension of seemingly uncontrollable (unpredictable) costs in a
flexible work plan setting is a concern. Site manager (regulator) unfamiliarity or discomfort
with the consultant's expertise in innovative investigation methodologies can act as a barrier
to adoption.
• WI - Business practice inertia is not foreseen as a barrier. In some regards, Wisconsin
already allows some flexibility with work plans and the use of field analytical methods.
5.1.2 Lack of Adequately Trained Staff for Triad Pro] ects
The staffing flexibility and experience required to implement the Triad approach might be
problematic for state regulatory agencies in some cases. Successful implementation of Triad
requires environmental staff with considerable experience in the application of geochemistry,
geology, analytical chemistry, statistics, and other disciplines. Many agencies have junior-level
staff doing the majority of the oversight, while the more experienced and knowledgeable staff
members are not always available to spend significant time on individual projects. This
distribution of knowledge within an agency is a significant barrier to Triad approach
implementation. Problems of this nature will be overcome as regulatory agencies align their staff
for oversight of projects conducted using the Triad approach.
Oversight of Triad projects by junior staff is facilitated if regulators consistently and explicitly
require detailed, transparent work plans and reports. These documents should provide
• a succinct list of project objectives or desired outcomes,
• a list of decisions that need to be made to achieve those objectives,
• a listing of the qualitative (and quantitative, if possible) unknowns that could lead to decision
errors if the uncertainties are not managed or data gaps filled, and
• a clear discussion of the preliminary CSM or the more mature (after the investigation has
occurred) CSM.
Comments from specific states are as follows:
• CA - A competent technical team available to direct the field activities during the project
implementation phase is crucial in the success of Triad Approach. Only personnel who have
the specific skill and knowledge on the related subject area and who have the necessary
experience should implement the Triad, whether the regulatory agency or a consultant
conducts the project. The personnel qualifications need to be defined. Every technical person
involved in the project has the responsibility to carry out the field activities in accordance
with the QAPP.
• DE - Delaware does have a technical team consisting of experienced staff from different
disciplines that review technical documents including work plans. However, junior staff
members are performing most of the field work, and there have been relatively few
applications of dynamic work plans. For the most part regulators provide oversight on
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projects performed by consultants. These consultants also use junior staff to perform field
work. Use of a decision tree and communication with experienced staff in the office may
offer some solution.
• KY - This problem is inherent in state government and can be overcome through training,
proper planning, and cooperation from management.
• MO - Due to the nature of state government, the staff turnover rate is rather high. The
majority of workers doing field work (and sometimes designing sampling plans) are
somewhat inexperienced. While it's true that senior level staff oversee the work plans and
procedures, this is often done as part of a review process rather than in the active planning
process. Getting the most qualified staff in the field is often difficult due to administrative
responsibilities that keep them in the office.
• NJ - Many staff within the New Jersey DEP are aware of Triad. The department is providing
on-site education of Triad from EPA and USAGE.
• OK - Contract consultants perform most of the work. A junior- or mid-level staff person may
visit the site once a week for oversight purposes. Lack of staff is a real problem. Due to the cuts
in the budget, the situation may not improve for quite some time.
• SC - In general, staff have a wide variety of knowledge and experience. Typically, an
engineer and a hydrogeologist are assigned to each project (Superfund). Risk assessors are
also available upon request. Senior-level staff oversee the review of work plans and
procedures.
• VT - The experience that Vermont DEC has with oversight of projects similar to Triad has
resulted in a cadre of professional regulators capable of keeping abreast of the innovations in
the private sector. The insufficient number of staff at VTDEC remains a problem, and
consequently some sites are currently unmanaged.
• WI - In general, staff have a wide variety of knowledge and experience to build upon.
However, as indicated above, junior-level staff complete the majority of the site-specific
work.
5.1.3 Requirement for Additional Commitment of Time and Effort
Regulators often manage a large number of sites and may feel that they are unable to devote the
time necessary to both participate in detailed project planning or in the fast-paced evaluation of
data generated using dynamic work strategies. While this may be the initial impression of some
state regulators, in actuality the Triad approach can reduce regulator workload in the long run.
Carefully planned and executed projects with clearly identified goals come to a conclusion faster
and with less overall effort than work at the same site using traditional methods. However, there
is no doubt that a learning curve requires an up-front investment of time and effort that could tax
staff laboring under already heavy workloads.
Comments from specific states are as follows:
• CA - If the project goals are well defined and a technology or test method is properly
selected, the overall costs with respect to time and money should be less than those of the
traditional way of operation. Several successful case studies using the Triad approach for site
projects, as described in Section 9, show the potential time savings.
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• DE - Similar to that of other states, Delaware staff manages a large number of sites. Initially,
Triad implementation will take more time especially during systematic planning. This need
will cause an initial resistance to Triad implementation. However, as Triad implementation
becomes routine the time and cost savings will become evident and the barriers will be
removed.
• KY - This is a problem, but not a significant barrier. This problem will vary across the
Kentucky DEP; however, with management cooperation and staff training, it can be
managed.
• MO - The time factor will be a real barrier until staff are adequately trained in systematic
project planning and evaluation of the data quality. Staff are already overworked, and adding
additional time to a project will not be well received. Eventually, staff will gain experience
and then time will not be an issue.
• NJ - This is a concern of New Jersey DEP management. The actual time commitment
involved in managing a Triad project will need to be accurately calculated. The department is
educating managers that although Triad projects may take more time initially because of the
development of the CSM, overall time savings will accrue from lack of repeated
mobilizations.
• OK - In Oklahoma, there is a need for more education and training at all levels. Initially, the
time needed for systematic planning and dynamic work plan development may be difficult to
achieve due to shortage of sufficiently qualified staff, but eventually the situation could
improve.
• SC - South Carolina encourages project managers and/or their support team to have a
presence on each site, particularly residential cleanup sites. However, since the Triad
approach requires more commitment, time management is essential.
• VT - Triad approach projects require immediate regulatory attention at the initial stage. It is
necessary for the responsible party's consultant to confer with the Vermont DEC so as to
arrive at an approach that will lead in a regulator-acceptable direction.
• WI - This will be a barrier, at least during the first few years of allowing the use of such an
approach. As with almost every other state, budget constraints have limited the number of
staff available to work on sites (i.e., there is a need to do more work with fewer people). This
problem will vary as state budgets fluctuate.
5.2 Concerns with Real-Time Measurement Technologies
The majority of the real and perceived state regulatory barriers revolve around the real-time
analysis leg of the Triad, rather than the systematic planning or dynamic work strategy
components. Most, if not all, of these concerns involve the use of field analytical data. These real
and perceived barriers will most likely be the toughest to overcome for those proposing the use
of the Triad approach. As previously mentioned, data quality is the key to successful utilization
of Triad. Many regulators believe that data quality is equivalent to analytical quality, which sets
limitations on the types of data that can be used for making site decisions. Traditionally, a
significant amount of time and money have been spent on analytical quality control. However,
the Triad approach recognizes that the majority of error in the site decision is not in the
analytical data but rather the representativeness of the sampling. The regulatory culture must
accept the significance of sample representativeness and the relationship between data quality
and decisions. Analytical quality is important and should not be discounted; however, the overall
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data quality encompasses much more than just analytical methods, and the regulatory agencies
should be encouraged to recognize this fact.
Comments from specific states are as follows:
• CA - As long as the data quality is validated by the associated QC results, the test method
used is not an issue. This concept is consistent with the PBMS. However, to ensure the data
quality, a fraction of split sample analysis by a reference method is usually recommended,
specifically for samples with concentrations around the action level.
• DE - Significant barriers exist regarding the use of results of samples analyzed in the field
for risk assessment and site closure.
• KY - This is a barrier, but it will ease when examples of site closure and risk decisions using
field analytical methods from other states are presented to management and project
managers.
* MO - The key to overcoming this barrier is a staff comprehension of the definition of
"quality" for a given data set. The general belief is that data gathered in the field could not be
of the same quality as that of data generated in a fixed lab. It's going to take a huge change in
thinking about the true meaning of "quality" for any given data,
* NJ - NJ has accepted field analytical data for many years when used to define areas of
contamination.
* OK - There is inherent bias against these technologies in the Superfund program. However, the
voluntary cleanup and brownfield programs are generally more flexible. Field screening must
still be verified by fixed-lab results.
• SC - Barriers exist regarding the use of results from samples analyzed in the field for risk
assessment and site closure.
• VT - The Vermont DEC has a history of applying real-time analytical measurements with
success.
• WI - The barriers stated later in this section do coincide with our current concerns. It is
generally accepted in Wisconsin that the field "screening" analytical data is of lower quality
and reliability than fixed-laboratory data.
5.2.1 Field Data Quality Concerns
Some regulatory agencies have expressed concern regarding the quality of data generated in the
field. The Triad approach's success relies not only on defining the necessary data quality, but
also on establishing QC procedures to verify the results. Application of QC procedures for
precision and accuracy can establish that field data are of adequate quality. Therefore it is
possible for field data to satisfy state guidelines and to be used for decision-making purposes.
Comments from specific states are as follows:
* CA - With the recent advancement in hardware and software, many field instruments have
high specificity, sensitivity, and selectivity and are able to generate data in a more efficient
manner. It depends on the project manager to select an appropriate field technology to meet
the project-specific objectives. As a matter of fact, the data generated by a reference method
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may not always be appropriate for the project. A comprehensive QC program and complete
documentations of field activities are crucial to the accountability of data quality.
• DE - Although Delaware does allow field analyses of samples, it is generally viewed as a
screening tool and requires confirmatory samples analyzed by a fixed lab. Field analyses for
some media and some contaminants such as soil contaminated with metals are accepted.
Delaware has concerns regarding the reliability of the field methods and the training of field
method operators.
• KY - This is a concern at the Kentucky DEP. Kentucky allows the use of field analytical
methods for site closure and investigative work as long as certain percentages (10%-15%) of
data are confirmed by laboratory analyses.
• MO - The belief that field data lacks quality is a real barrier. Having a work plan that defines
the acceptability and use for the collected data is helpful, along with having significant QC
procedures both in the design of the work plan and the collection of data. Again, experienced
staff is the key to making this work, and that's a concern.
• NJ - The New Jersey DEP technical regulations have allowed the use of data obtained from
field analytical measurements for years. This is not a concern at the DEP.
• OK - There is a perceived concern that the quality of field data is not as good as that of fixed-
lab data. In certain programs, such as UST and enforcement activities, field data have been used
for initial decision making, but final decisions are made after results from the fixed lab become
available.
• SC - The belief that field data lacks quality is a real barrier. A work plan that defines the
acceptability and use for the collected data is needed. The inclusion of significant QC
procedures in the work plan would be helpful. Also, experienced professionals are key to
making the Triad work.
• VT - Federal (EPA) QC requirements typically drive a site towards traditional iterative lab-
based approaches. The EPA quality control requirements are only necessary to meet on
federal sites (superfund, etc). On state-lead sites VT has much more flexibility regarding this
issue.
5.2.2 Analytical Quality Versus Data Quality
As mentioned above, many environmental professionals have the misconception that only
analytical methods listed in SW-846 can produce data of adequate quality for decision-making
purposes. Many are not aware that many field analytical methods have been in the SW-846
methods manual for years. Section 2 details how uncertainty associated with sample
representativeness has a much larger adverse effect on project decision making than that
associated with analytical error. Therefore, regulatory agency efforts to control quality with
method certification alone will never be sufficient. To ensure successful project outcomes,
regulatory agencies must take a more holistic approach to managing uncertainty, which will
mean much more attention devoted to goal development and QC measures, rather than exclusive
focus on ensuring that specific analytical methods are referenced in SW-846.
Comments from specific states are as follows:
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• CA - The concepts of "analytical quality" and "data quality" need to be clarified among the
analytical chemistry community as well as the regulatory agencies. This message can be
introduced through the training process.
• DE - Misconceptions and lack of knowledge about different field methods exist. Studies
showing effectiveness of the use of field methods and acceptance by EPA and other states
will help in the elimination of this barrier.
• KY - Certain misconception exists but will ease as case studies of acceptance of field data
are available to the management and project managers. EPA's acceptance of the field
analytical methods will go a long way in eliminating this barrier.
• MO - Many staff members greatly struggle with this concept of "data quality." The vast
majority of QC auditing is conducted only on our fixed labs and the data that are generated
by them. This process furthers the belief that "lab data = quality data" because it implies that
if data are not generated in the lab, then they don't even warrant a QC review. This concept is
further hindered by the misconception that all data gathered in the field are of "screening"
quality and that confirmation of the result is needed prior to a decision.
• NJ - This concept has been explained to New Jersey DEP management and staff but is not
yet well understood by either group. Further education on this issue is needed.
• OK - There is a lack of understanding about the accuracy and relevance of several field
measurement techniques. Some regulators have taken a "wait and see" approach about certain
emerging technologies. Established field measurement techniques are well received for
screening purposes. State will accept real-time measurement technologies if EPA or other
federal agency takes a lead in their acceptance.
• SC - Misconceptions and lack of knowledge about different field methods exist. Studies
showing the effectiveness of field methods and acceptance by EPA and other states will help
in the elimination of this barrier.
5.2.3 Legal Defensibility
There is a widespread opinion that data generated by real-time measurement technologies will
not withstand legal scrutiny, and this argument is sometimes used as a reason not to consider
these methods. The opinion that field generated data are not legally defensible is a
misconception. The standards for the admissibility of scientific evidence by a state court may be
different from a federal court. The admissibility of evidence in a federal court is based on two
basic requirements: the evidence is relevant to the case, and the data and information are reliable.
In addition, the U.S. Supreme Court expressed the following criteria: whether (1) the technique
has been valid and tested, (2) the principle of the technology has been subjected to peer review
and in publication, (3) the rates of potential error associated with the relevant testing are known,
and (4) the technique has gained general acceptance in a relevant scientific community (William
Daubert v. Merrell Dow Phamaceuticals, Inc. United States Supreme Court, 509 U.S. 579, 1993).
Comments from specific states are as follows:
• CA - For regulatory acceptance, environmental data must be legally defensible. The
standards for analytical data to be accepted as evidence in California courts are based on
three requirements (The People v. Kelly, 17 Cal.Sd 14 ,1976):
o A technology is generally recognized in the scientific community.
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o The test method is performed correctly.
o The case is substantiated by an expert witness.
• DE - This barrier exists primarily due to perception.
• KY - This issue is a barrier mainly because of the misconception concerning the field
analytical data. Acceptance of the field methods by EPA and other states will help toward the
elimination of this barrier.
• MO - Whether or not a Missouri court has challenged field data is not known at this time.
However, most site cases would not even be considered for litigation unless the data had
been QC audited according to the standard operating procedures, which are mainly
applicable to fixed labs.
• NJ -The New Jersey DEP Assistant Commissioner for Site Remediation has endorsed the
Triad approach, and this issue is not expected to be a problem,
• OK - Real-time measurement technologies are generally looked upon as screening tool;
therefore, their legality has been questioned in the court. However, in many cases these
technologies such as electromagnetic surveys are used with follow-up data. In most cases the
court has accepted the technique "for whatever it's worth" basis.
• SC - For regulatory acceptance, environmental data must be legally defensible. South
Carolina has experienced a setback when the three principles listed by Simmons were
applied. An analytical method not listed in SW-846 was used to analyze for hexavalent
chromium at a site in Charleston. The use of this method resulted in a verdict against the
South Carolina Department of Health and Environmental Center (DHEC) and the loss of
some cost-recovery funds.
• VT - Legal predisposition towards establishing certainty is a barrier within the community of
responsible parties in Vermont, particularly at large sites. However, the Vermont DEC has
successfully implemented a number of state-lead real-time measurement site investigations
and has successfully defended the validity of the data in state courts.
5.2.4 Validation or Certification of Field Analytical Methods or Operators
Real-time analysis is often achieved by field analytical methods, which could potentially be in
conflict with a state's laboratory certification and/or data acceptability requirements. For most
states, data acceptability is linked to laboratory certification, which does not currently apply to
field analytical methods. Laboratory or operator certification does not guarantee understanding
of all types of data uncertainty. With the Triad process, uncertainties not addressed (most
prominently, the very large impact from sampling uncertainties) must be evaluated through other
mechanisms.
The current EPA SW-846 compendium of analytical methods that apply to environmental
measurements includes many, but not all, of the available and well-documented emerging field
analytical technologies. In general, it takes several years to gather performance data, write, test,
review, and edit the method information that is adopted into SW-846 by a consensus process.
Resource limitations slow the inclusion of new technologies into SW-846. In the meantime, the
fact that a particular field analytical method is not currently included in SW-846, does not mean
that regulators should assume that the data do not have adequate precision and accuracy. Nor
should they assume that they couldn't permit the use of non-SW-846 methods.
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It should also be noted that the SW-846 manual has been "deregulated" by EPA under the
Methods Innovation Rule. This means that many of the required uses of SW-846 methods that
were written into some Resource Conservation and Recovery Act regulations years ago have
been eliminated. Use of SW-846 methods would continue to be required only in those limited
situations where the written test method itself defines the property being measured (e.g., the
Toxicity Characteristics Leaching Procedure test). Deregulation of the SW-846 manual means
that the process required for including new methods will be less resource- and time-intensive,
which should result in faster incorporation of new technologies (EPA 2003c).
Comments from specific states are as follows:
• CA - The criteria for the selection of a field test method and standards for field
measurements should be consistent with the standards approved by the National
Environmental Laboratory Accreditation Conference (NELAC Chapter 7, Field activities
approved July, 2002, effective July 1, 2004). To ensure the data quality, it is commonly
specified in the QAPP that a fraction of samples be submitted to a certified laboratory for
confirmatory analysis. Field data associated with proper QC results can be used for the
regulatory purposes if data meet the project-specific objectives. Currently in California there
is no requirement that an instrument operator be certified.
• DE - Delaware does have a laboratory certification program, and these labs have to be used
for confirmatory samples. However, field analyses are allowed primarily as a screening tool.
• MO - Missouri does not have a laboratory certification program. In fact, although contractors
often use the Contract Laboratory Program labs, the majority of samples collected by the
department are sent to the Environmental Services Program or the State Health Laboratory—
neither of which is certified as a CLP lab.
• NJ - The New Jersey DEP Office of Quality Assurance will be implementing a program to
certify an entity providing field analytical measurements for the following types of field
measurements:
o immunoassay,
o field-portable GC,
o field-portable GC-MS, and
o field-portable XRF.
• OK - Oklahoma has a lab certification program run by the Department of Environmental
Quality (DEQ). All samples are to be analyzed by a certified laboratory. Field labs using real-
time measurement technologies are not certified by DEQ.
• SC - South Carolina has a laboratory certification program, and confirmatory samples are
sent to these labs. However, field analysis techniques are used often (e.g., site assessments).
* VT - The Vermont DEC does not have laboratory certification programs. For real-time
analytical methodologies, we discuss with the consultant the need for a certain percentage of
duplicate samples to go to a fixed laboratory for confirmation. DEC also works with the
consultant and responsible party to establish the quality criteria for accepting or rejecting
real-time analytical data.
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5.3 Conflicts with State Law, Policy, or Guidance
Application of Triad approach concepts may be inconsistent with state law in a number of ways.
Some states have prescriptive guidance on preparation of work plans, reports, and decision
documents. A responsible party risks violation of state regulatory policy by proposing a dynamic
work plan that may deviate from established law or guidance. In addition, some states also have
stipulated specific analytical methods (such as SW-846) in environmental regulations and are
hesitant to allow the use of field methods.
Comments from specific states are as follows:
• CA - CA Health and Safety Code Section 25198 indicates "the analysis of any materials
shall be performed by a laboratory certified by the state Environmental Laboratory
Accreditation Program (ELAP) in the Department of Health Services (DHS)." This statute
appears to be a regulatory barrier for implementing Triad approach. In reality, this statute is a
perceived barrier, because in many instances the test method is outside the scope of DHS
accreditation and the project manager can make the decision in selecting the appropriate test
methods for the project. To avoid this potential problem, changing state law or including the
field test methods in the ELAP scope would be an alternative for eliminating this perceived
regulatory barrier.
• DE - This is considered a procedural barrier because there is guidance on work plans and
cleanup procedures. However, the laws are flexible to allow for example dynamic work
plans. As mentioned earlier, field analyses are not accepted for certain decision such as site
closures. As field analyses become more sophisticated and diverse, the acceptance will
increase.
• MO - No barriers are known. Policies (like Voluntary Cleanup Program) indicate that field
data may be used for site assessment; however, no guidance is specifically known to exclude
field data for site closures, etc.
• NJ - No barriers are known.
• OK - There is no clear-cut barrier in Oklahoma. The Triad concept has been used by some
agencies more than others. For closure purposes a fixed lab must verify field results.
• SC - No barriers are known. Field data may be used for site assessment; however, no
guidance is specifically known to exclude field data for site closures, etc.
• VT - Vermont has no policy or guidance that precludes the use of real-time analytical
methods or flexible work plans.
• WI - This is a barrier in Wisconsin. Current administrative codes require that a certain
number of samples be submitted to a certified lab for analysis. Field analytical data are not to
be used for closure decisions.
5.4 Lack of Guidance for State Regulators
The Triad approach has only recently taken shape, and therefore guidance is in the earliest stages
of development. The lack of such guidance at either the federal or state level is a serious
hindrance to applying the Triad approach. However, guidance is beginning to appear (see
Sections 3.3, 6, and 10), and a number of peer-reviewed articles are available in environmental
journals. It is expected that an increasing number of EPA and state regulatory agency
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technical/guidance documents will become available in the near future as efforts continue to put
definition to Triad concepts. This document is the first phase of Triad guidance to be offered by
ITRC. The next phase will consist of training sessions to transfer the technology worldwide to
the environmental community. Other phases may follow, depending on the need.
However, it is impractical to produce a single guidance document that could address all of the
programmatic procedures of 50 state agencies and 10 EPA regional offices. The choice of
adapting state regulatory policies to support Triad implementation will rest with each state
program. For that reason, adoption of the Triad into regulatory and engineering practice is
expected to be gradual. State regulators might consider supporting one or two "pilot" Triad
projects with assistance from experienced Triad implementers. As these pilot projects unfold,
they should be observed by the program staff to gather lessons learned and pinpoint any
constraints of the current regulatory structure. States wishing to try Triad pilots should
coordinate through the ITRC to share lessons learned and supporting documentation as they is
developed. This approach will allow states to share knowledge, experience, and materials,
avoiding the time and expense of "reinventing the wheel" and promoting greater consistency
across state and federal programs.
Comments from specific states are as follows:
• CA - The memorandum "Distribution of OSWER Guidance Using Dynamic Field Activities
for On-Site Decision Making: A Guide to Project Managers" from EPA Assistant
Administrator, Office of Solid Waste and Emergency Response, dated May 7, 2003 will have
an impact on the implementation of Triad approach.
* DE - This is a temporary but significant barrier. Once detailed guidance and case studies are
available, this barrier will be resolved.
• MO - There is a need for guidance to transition between the "old" ways and the new,
innovative approach.
• NJ - The New Jersey DEP is developing written guidance for Triad implementation.
• OK - This is true. There are very few people out there who are aware of the Triad approach. But
it could change if the guidance documents become available and regulator training starts.
• SC - As guidance is developed, this barrier will go away.
• VT - The Vermont DEC does not have internal Triad guidance documents for state
regulators. A majority of our site staff have participated in the ITRC-sponsored Web-based
training seminars. Our existing generic guidance documents have allowed us to successfully
implement Triad-like investigations over the last 10 years.
• WI - This will be a barrier for at least a short while. Like anything else, if there are not
enough people that know about an issue, it is hard to promote it. As guidance is developed,
this barrier will go away.
5.5 Defining Action Levels During Systematic Project Planning
As described in earlier sections, it is important to define appropriate action levels during the
earliest stages of systematic project planning. Some regulators are more accustomed to
identifying appropriate action levels only after investigation data has been gathered and
evaluated. The regulatory community must be encouraged to actively consider action levels very
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early in the systematic project planning process. Early identification of action levels will become
more common as regulators are made integral members of project team decision making.
Comments from specific states are as follows:
• CA - The action level is one of the targets usually stated in the QAPP.
• DE - Action levels are determined based on risk to human health and environment. Guidance
lists action levels for contaminants based on the end use of the site (i.e., residential,
commercial, etc.). However, there may be a problem with finding field methods that can
achieve the detection levels close to the action levels.
• MO - Site projects in Missouri mainly rely on the Cleanup Levels for Missouri (CALM) for
site closures within the state. Even federal Superfund sites often defer to the CALM levels
for cleanup goals. CALM was developed by the state Voluntary Cleanup Program with
coordination from a variety of partners, including the health department and EPA. The levels
are risk based and are dependent on future site use.
• NJ - This issue has yet to be addressed.
• OK - Action levels are arrived at after careful study of all applicable factors including the
economics. They generally go through a public participation process. For closure and risk
assessment purposes the field methods are used as preliminary data.
• SC - Current administration policy allows for this; however, the burden is on the consultant
to prove that the levels are appropriate. Risk to human health and the environment determine
action levels. Guidance lists action levels for contaminants based on the end use of the site
(i.e., residential, commercial, etc.). However, problems may exist with finding field methods
that can achieve the detection levels close to the action levels.
• VT - The Vermont DEC utilizes the Groundwater Enforcement Standards informally applies
the Region IX and III PRGs and, where appropriate, site-specific goals for soils and
sediments.
• WI - This is not foreseen as a barrier. Wisconsin's current administrative code allows for
this; however, it will be the burden of the consultant to prove that the levels are appropriate
(not simply state that the level should be OK).
5.6 Associating Uncertainty to Specific Decisions
Identifying and managing uncertainty are central to successful application of Triad approach
concepts. Until guidance and computer application tools (like decision support software) become
more widely distributed to assist in associating tolerable levels of uncertainty to sampling plans,
this process will remain within the realm of professional judgment, and for this reason many
regulators will be reluctant to consider proposals to manage projects in this way. EPA and the
interagency Triad team are aware of the lack of guidance in this area and are working to
overcome the lack of such technical assistance.
Comments from specific states are as follows:
• CA - This is one of the areas needing consensus among the regulators, technical teams, and
responsible parties during the project planning step. This would be a complicated step for the
implementation of Triad approach.
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• DE - Delaware is moving towards associating uncertainty to a specific decision. Although
several software programs are available, guidance on their proper use is very much needed.
• MO - This issue has yet to be addressed.
• NJ - This issue has yet to be addressed, although future state Triad guidance will comment
on this issue.
• OK - The problem of associating uncertainty within the analytical methods and sampling
method is critical. There is need for more discussion in this area. In Oklahoma this issue is
discussed, but generally no action is taken.
• SC - The South Carolina DHEC administrative policy currently allows for some professional
judgment in day-to-day decision-making efforts.
• WI - This should not be much of a barrier. Our administrative code currently allows for
some professional judgment in our day-to-day decision-making efforts.
5.7 Recommendations for Overcoming Barriers
5.7.1 Organizational Barriers
* Establish a training program on the Triad approach, for both regulators and practitioners.
• Create a cadre of trained staff to respond to Triad-related projects.
• Publicize Triad experiences to encourage information sharing.
• Educate their senior managers about the advantages of Triad.
• Draw upon the experience of previous investigations to demonstrate the savings of time and
money.
• Develop a state peer network of experienced Triad users.
5.7.2 Concerns Regarding Acceptance of Data Generated from Field Analytical Methods
• Expand existing state laboratory accreditation/certification programs to include field
analytical methods. Consider granting certification for specific methods.
• Consider qualifying individuals performing selected real-time measurement technologies.
Try to strike a balance between regulation and project-specific QC requirements.
• Remind staff that some field analytical methods are included in SW-846 (accepted EPA
analytical methods).
• Educate national laboratory accreditation/certification programs on the benefits of field
analytical methods.
• Dialogue with national analytical service providers regarding the benefits of field analytics.
5.7.3 Conflicts with State Law, Policy and Guidance
• Document problems as they arise during implementation of Triad projects.
• Utilize experience gained in other states to predict similar Triad implementation issues.
• Change state law, policy, and guidance to remove regulatory barriers
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5.7.4 Lack of Written Guidance
• Create guidance on how to practice Triad with concurrence of state regulators.
• Compile successful Triad implementation case studies.
5.7.5 Defining Action Levels During Systematic Project Planning
• Publicize results of case studies where action levels were successfully defined prior to project
implementation.
6.0 IMPLEMENTATION OF TRIAD IN A STATE REGULATORY AGENCY
New Jersey is the first state to initiate a formal program to use the Triad approach, and the
program is still in its infancy. This section discusses the New Jersey Triad program and presents
materials that may be beneficial to other states considering similar programs of their own.
Information on the New Jersey Department of Environmental Protection (NJDEP) approach to
Triad implementation can be found at http://www.ni.gov/dep/srp/triad/.
6.1 New Jersey Policy Statement Supporting the Triad Approach
NJDEP is committed to streamlining the site investigation and remediation process at
contaminated sites without compromising data quality and reliability. This goal can sometimes
be better achieved by implementing the Triad approach, a process that integrates systematic
planning, dynamic work strategies, and real-time measurement technologies to achieve more
timely and cost-effective site characterization and cleanup. The Triad approach seeks to
recognize and manage the uncertainties involved in generating representative data from
heterogeneous environmental matrices.
NJDEP supports and encourages the use of Triad for sites undergoing investigation and
remediation within the Site Remediation and Waste Management Program where feasible.
NJDEP has evaluated the Technical Requirements for Site Remediation, New Jersey
Administrative Code (NJ.A.C.) 7:26E, in the context of Triad and has determined that the
concepts embodied in Triad can be implemented within the framework of the rules. NJDEP
encourages persons interested in using the Triad approach to enter into memoranda of agreement,
as described in NJ.A.C. 7:26C, because successful implementation of the Triad approach
requires close interaction with NJDEP to ensure that appropriate considerations have been
addressed. NJDEP will continue to consider whether modification of applicable rules would
facilitate or further encourage use of the Triad method.
6.2 New Jersey Triad Approach Training
As of September 2003 NJDEP had conducted three training sessions for its managers, staff, and
consultants on Triad. EPA also supports this approach and is very interested in promoting this
approach nationally. EPA has partnered with NJDEP and the New Jersey Institute of Technology
(NJIT) to use the Triad approach to expedite site characterization and cleanup of contaminated
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sites in New Jersey. Speakers have included NJDEP program managers and case managers,
Deana Crumbling of EPA's Technology Innovation Office, Kira Lynch of the Army Corps of
Engineers, and Jim Mack of NJIT. As of September 2003, more than 200 people had been
trained.
6.3 New Jersey Regulations Pertinent to the Triad Approach
NJDEP has published rules governing the remediation of contaminated sites in N.J.A.C. 7:26E.
These rules are titled "Technical Requirements for Site Remediation" (also known as the "Tech
Rules"). The latest version of N.J.A.C. 7:26E was adopted in 2003.
The Triad approach can be implemented within the framework of the technical rules. For
example, N.J.A.C. 7:26E 2.1(b) provides for liberal use of real-time analyses when conducting
investigation and remediation, and 3.3(d) provides that "It is often appropriate to phase the site
investigation so that the areas of concern most likely to be contaminated above the applicable
remediation standards are sampled first. If at any time during the site investigation, any
contamination is found above the applicable remediation standards, then the site investigation
may be discontinued and the remediation continued at either the remedial investigation or
remedial action phase." There are certain provisions in the technical rules that require department
oversight or notification, and other provisions that the department has determined are often
associated with complex aspects of investigation and remediation. It is critical that these
provisions be considered during the systematic project planning phase of the Triad process.
These provisions from N.J.A.C. 7:26E are as follows:
1. Department Oversight Required
1.12 - Requirement for department oversight of remediation (for sites suspected or known to
be contaminated with anthropogenic radionuclide contamination of any media; and sites with
immediate environmental concern (IEC) conditions.
5.2 - Remedial action selection report (oversight required for certain types of remedies).
6.1(d) - Free and/or residual product (oversight required for containment remedies).
6.2(b) - Soil reuse (oversight required).
6.7 - Remedial action report (oversight required).
7 - Permit identification and application schedule (oversight required).
8 - Engineering and institutional controls (oversight required; note: if the need for a deed
notice is reasonably anticipated, plan for time delays in obtaining property owner approval).
2. Department Notification
1.4-Required
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• prior to the initiation of any sampling activities at a contaminated site which is not
already known to the department,
• if immediate environmental concern conditions are identified, and
• if an interim response action in response to an IEC is to be conducted.
3.7(e)3.ii - Potable well search (plan for possible time delays at this stage).
3.7(g)5 - Up-gradient groundwater contamination.
3. Potentially Complex Aspects of Investigation and Remediation
2.1(a)5 - Proposing an alternative analytical method.
3.7(g) - Background groundwater investigation.
3.10 - Background investigation in soil.
3.11 - Ecological evaluation .
3.12 - Investigation of historic fill material.
4.1 - If off-site contamination of soil, groundwater, or other media is reasonably anticipated,
plan for time delays in obtaining off-site access.
4.8 (c)3i - Sampling results summary table and averaging requirements. Using field
analytical method data to calculate average contaminant concentrations for contaminated
areas should be conducted only in consultation with the department.
NJDEP is strongly encouraging the application of Triad to site remediation activities. The plan
for NJDEP Triad implementation includes the following components:
• Articulation of strong support by senior NJDEP management.
• Creation of an interdisciplinary Triad implementation work group of NJDEP staff.
• Identification of subset of NJDEP case managers, technical coordinators, and project
geologists who have expressed an interest in utilizing the Triad approach. These are the staff
members who will be working on Triad-related projects.
• Training for these NJDEP staff including presentations by the leading practitioners of the
Triad approach including the EPA, USAGE, as well as engineering firms and consultants.
• Development of a Triad implementation guide for NJDEP staff.
• Inclusion of field analytical measurement technologies in the NJDEP laboratory certification
program by the Office of Quality Assurance (OQA) at N.J.A.C. 7:18, Regulations Governing
the Certification of Laboratories and Environmental Measurements. Four categories of field
analytical methods will be included:
o immunoassay,
o field-portable gas chromatography,
o field-portable gas chromatography mass spectrometry, and
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o field-portable X-ray fluorescence spectroscopy.
* Once implemented, any laboratory, engineering firm, or consultant employing these field
analytical measurements will need to be certified by the OQA before providing these data to
NJDEP on any Triad project. The OQA will require submission of standard operating
procedures, experience of analysts, performance criteria, and other documentation prior to
certification. Certified entities will be subject to future audits and/or proficiency
demonstrations in order to maintain their certification(s).
• Continuing training for NJDEP Triad staff.
7.0 STAKEHOLDER CONCERNS
For the purposes of this document, "stakeholders" are affected tribes, community members,
representatives of environmental and community advocacy groups, and the public. Stakeholders
generally show great interest in the nature and extent of the contamination problem, in the means
by which the site will be remediated, and in the cost of the restoration effort. Given the financial,
technical, and regulatory complexities inherent in the remediation process, it is essential that
affected stakeholders are involved in all phases of the cleanup. Only through meaningful and
substantial participation will the stakeholders support the difficult policy, budget, and technical
choices that will have to be made (WGA 1994).
It is important to note that affected stakeholders are not necessarily limited to adjacent property
owners. For instance, those who live downstream of a contaminated site may be affected even if
they are not in the immediate vicinity of the site. Furthermore, tribes may have treaties or other
pacts with the federal government that grant them fishing, hunting, or access rights in places that
are not necessarily near their present-day reservations. In other words, nonadjacent tribes may
have legal rights involving the contaminated site or other property affected by the contamination,
even though they do not own the property or live adjacent to the site.
All interested stakeholders must have access to critical information and the opportunity to
provide input to technology development decisions at all stages of the evaluation, planning, and
implementation processes. It is particularly important at the site level to involve stakeholders in
collaborative decision making. Stakeholder and regulator interactions with the technology
developers, including examination of data and evaluation of demonstration results, increases the
credibility of predicted outcomes and decreases the likelihood that barriers to the implementation
of a technology will be encountered (WGA 1996a). Effective stakeholder participation can
promote a more accurate understanding of the relative risks of various technologies and
remediation options. Participants gain a greater understanding of the regulatory requirements and
processes, as well as a greater understanding of the technologies and/or remediation techniques,
are thus more likely to accept less costly environmental solutions. At the Oxnard Plain site in
Port Huneme, California, for example, the Restoration Advisory Board members recommended a
less-expensive remediation alternative than the plan originally proposed by the Navy (WGA
1996b). In addition, stakeholders often have valuable, in-depth knowledge of the site
characteristics and site history that enhances the effectiveness of the evaluation, planning, and
implementation processes.
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ITRC - The Triad Approach: A New Paradigm for Environmental Project Management December 2QQ3
EPA, 2001b. Current Perspectives in Site Remediation and Monitoring: Clarifying DQO
Terminology Usage to Support Modernization of Site Cleanup Practice. EPA-542-R-01-
014. Available online at http://cluin.org/download/char/dqo.pdf.
EPA. 200 Ic. Current Perspectives in Site Remediation and Monitoring: The Relationship
Between SW-846, PBMS and Innovative Analytical Technologies. EPA-542-R-01-015.
Available online at http: //cluin. org/download/char/sw- 846 .pdf.
EPA. 200Id. Current Perspectives in Site Remediation and Monitoring: Using the Triad
Approach to Improve the Cost-Effectiveness of Hazardous Waste Site Cleanups. EPA-
542-R-01-016. Available online at http://cluin.org/download/char/triad2.pdf.
EPA. 2001 e. Current Perspectives in Site Remediation and Monitoring: Applying the Concept of
Effective Data to Environmental Analyses for Contaminated Sites. EPA-542-R-01-013.
Available online at http://cluin.org/downloaoVchar/effective data.pdf.
EPA. 2001f. Improving Sampling, Analysis, and Data Management for Site Investigation and
Cleanup (Fact Sheet, 2003 update). EPA-542-F-030a. Available online at
http://cluin.org/download/char/542-f-01-Q30a.pdf.
EPA. 2003a. Office of Solid Waste Methods Team Web pages. For additional PBMS
information, go to http://www.epa.gov/epaoswer/ha2waste/test/pbms.htm.
EPA. 2003b. Using Dynamic Field Activities for On-Site Decision Making: A Guide for Project
Managers. EPA-540-R-03-002. Available online at
http://www.epa.gov/superfund/programs/dfa/. Also see the May 7, 2003 Memorandum
from the OSWER Assistant Administrator at
http://www.epa.gov/superfund/pro grams/dfa/download/guidance/memo_txt.pdf.
EPA. 2003c. Office of Solid Waste Methods Team Web pages. For information about the
Methods Innovation Rule, go to the EPA URL:
http://www.epa.gov/epaoswer/hazwaste/test/news.htm#3bext and the Federal Register
notice at http://www.epa.gov/fedrgstr/EPA-WASTE/2002/October/Day-30/f26441.htm.
EPA. 2003d. Office of Solid Waste Methods Team Web pages. See SW-846 online at
http://www.epa.gov/epaoswer/hazwaste/test/main.htm. See SW-846 Method 8260 at
http://www.epa.gov/epaoswer/hazwaste/test/pdfs/8260b.pdf.
EPA. 2003e. Open Path Technologies: Measurements at a Distance. Measurement and
Monitoring Technologies for the 21 st Century Web site at
http://cluin.org/programs/21m2/openpath/.
Gilbert, R.O. and P.G. Doctor. 1985. "Determining the Number and Size of Soil Aliquots for
Assessing Particulate Contaminant Concentrations," Journal of Environmental Quality,
14(2): 286-92.
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ITRC - The Triad Approach: A New Paradigm for Environmental Project Management December 2003
Homsher, M.T., F. Haeberer, P.J. Marsden, R.K. Mitchum, D. Neptune, and J. Warren. 1991.
"Performance-Based Criteria, A Panel Discussion," Environmental Lab,
October/November.
HSA (H.S.A. Environmental Engineers and Scientists). 2002. Florida Department of
Environmental Protection Contamination Assessment Report Varsity Cleaners, Tampa
Florida.
ICRU (International Commission on Radiation Units and Measurements). 1994. Gamma-Ray
Spectrometry in the Environment. Technical Report ICRU 53, Bethesda, Md.
ITRC Accelerated Site Characterization Work Team. 1997. Mutli-State Evaluation of the Site
Characterization and Analysis Penetrometer System—Volatile Organic Compound
(SCAPS-VOC) Sensing Technologies. Available online at http://www.itrcweb.org.
ITRC Accelerated Site Characterization Work Team. 1997. Interstate Technology and
Regulatory Cooperation Work Group (ITRC) I American Society for Testing and Materials
(ASTM) Partnership for Accelerated Site Characterization. Available online at
http://www.itrcweb.org.
ITRC Accelerated Site Characterization Work Team. 1998. Interstate Technology and
Regulatory Cooperation Work Group (ITRC) & U.S. Environmental Protection Agency
Consortium for Site Characterization Technology (CSCT) Partnership FY-97 Summary
Report. Available online at http://www.itrcweb.org.
ITRC Cone Penetrometer Site Characterization Technology Task Group. 1996. Multi-State
Evaluation of an Expedited Site Characterization Technology: Site Characterization and
Analysis Penetrometer System Laser-Induced Fluorescence (SCAPS-LIF). Available
online at http://www.itrcweb.org.
Jenkins, T.F., M.E. Walsh, P.G. Thome, S. Thiboutot, G. Ampleman, T.A. Ranney, and C.L.
Grant. 1997. Assessment of Sampling Error Associated with Collection and Analysis of
Soil Samples at a Firing Range Contaminated -with HMX, Special Report 97-22. U.S.
Army Corps of Engineers/Cold Regions Research and Engineering Laboratory, National
Technical Information Service. Available online at
http://www.crrel.usace.armv.mil/techpub/CRREL_Reports/reports/SR97_22.pdf.
Lesnik, B., and D.M. Crumbling. 2001. "Some Guidelines for Preparing Sampling and Analysis
Plans using Systematic Planning and the PBMS Approach." Environmental Testing &
Analysis (Jan/Feb). Available online at http://cluin.org/download/char/etasaparticle.pdf.
Miller, K.M, P. Shebell, and G.A. Klemic. 1994. "In Situ Gamma-Ray Spectrometry for the
Measurement of Uranium Surface Soils," Heath Physics 67: 140-50.
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ITRC - The Triad Approach^ A New Paradigm for Environmental Project Management December 2003
Powell, D.M. and D.M. Crumbling. 2001. "The Triad Approach to Site Cleanup," CleanupNews
(EPA Office of Site Remediation Enforcement quarterly newsletter, EPA 300-N-01-009),
Issue #8 (Fall). Available online at
http://www.epa.gov/Compliance/resources/newsletters/cleanurj/cleanup8.pdf.
Robbat, A. 1997. A Guideline for Dynamic Workplans and Field Analytics: The Keys to Cost-
Effective Site Characterization and Cleanup, sponsored by the President's Environmental
Technology Initiative, through the U.S. Environmental Protection Agency, Washington,
D.C. Available online at http://cluin.org/download/char/dynwkphi.pdf.
Simmons, B. P. N.d. Using Field Methods—Experiences and Lessons: Defensibility of Field
Data. California Environmental Protection Agency Department of Toxic Substances
Control. Available online at http://cluin.org/download/char/legalpap.pdf.
TetraTech EM, Inc. 1997. "Summary of Recent Improvements in Methods for the Study of
Contaminated and Potentially Contaminated Sites," white paper prepared for U.S. EPA
under contract No. 68-W5-0055. Available online at
http://www.cluin.org/coni7tio/svsplan/whtpaper.pdf
USACE (U.S. Army Corps of Engineers). 1998. Technical Project Planning (TPP) Process.
Engineer Manual EM 200-1-2. Available online at
http://www.usace.army.mil/inet/usacedocs/ eng-manuals/em.htm.
USACE. 2003. Conceptual Site Models for Ordnance and Explosives (OE) and Hazardous,
Toxic, and Radioactive Waste (HTRW) Projects. Engineer Manual EM 1110-1-1200.
Available online at http://www.usace.armv.mil/inet/usace-docs/eng-manuals/em.htm.
WGA (Western Governors' Association). 1994. Federal Advisory Committee to Develop On-
Site Innovative Technologies. DOIT Project Demonstration Resource Manual, p. 5.
WGA. 1996a. Mixed Waste Working Group, Committee to Develop On-Site Innovative
Technologies (DOIT), Final Report, p. 2. Available online at
http://www.westgov.org/wga/publicat/public.htm.
WGA. 1996b. Federal Advisory Committee to Develop On-Site Innovative Technologies.
Assessment of Local Stakeholder Involvement. Laura Belsten, University of Denver, p. 4.
11.0 ADDITIONAL SOURCES OF INFORMATION
Guidance for practical application of the Triad approach is in the early stages of development.
However, there is a gathering body of knowledge concerning these issues. Available resources
can be grouped into Web-based technical resources, regulatory guidance, and peer-reviewed
articles (also see Section 10).
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JTRC - The Triad Approach: A New Paradigm for Environmental Project Management December 2003
Web-Based Resources:
EPA Triad Resource Center
The EPA is currently working with an interagency Triad team to prepare a "Triad Resource
Center" on the Internet that compiles technical resources and case study information to assist
practitioners in applying these concepts. This resource will both facilitate the dissemination of
the information and allow for the updating of the center as the body of knowledge grows. This
Triad Resource Center should be available in late 2003/early 2004. Information on availability
can be obtained through the EPA "Clu-in" Web site http://clu-in.org/
Field Analytical Technologies Encyclopedia (FATE)
Another valuable resource available on the EPA Clu-in Web site is a compilation of on-site
technology information. This section of the Clu-in Web site contains articles and technical
information on the theory of operation, strengths/weaknesses, and general operating costs for a
large variety of analytical procedures that can be implemented in the field. This information can
be accessed through the EPA "Clu-in" Web site http://clu-in.org/. Guidance concerning CSMs,
sampling designs, sampling handling, and similar topics can be accessed through the site
characterization menus of the Clu-in Web site.
Technical Project Planning, USAGE
The Corps of Engineers has produced a guidance manual for technical project planning (the
Corps' terminology for "systematic project planning"). The document is titled Technical Project
Planning (TPP) Process, Engineer Manual EM 200-1-2, and is dated August 31, 1998. It can be
accessed online at the Corps of Engineers guidance Web site
http://www.usace.armv.miVinet/usace-docs/eng-manuals/em.htm.
NORISC
A European consortium developing an approach with some similarities to Triad
http://www.norisc.com.
Regulatory Guidance
Using Dynamic Field Activities for On-Site Decision Making: A Guide for Project Managers.
EPA
This guide encourages consideration of some of the concepts central to the Triad approach;
systematic project planning, flexible (or dynamic) work plans, and quick-turnaround analytical
methods. The manual also includes example case studies. This document can be found at the
EPA Superfund Dynamic Field Activity Web site: http://www.epa.gov/superfund/programs/dfa/
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Acronyms
AFB Air Force Base
AOC area of concern
ASC Accelerated Site Characterization
ASTM American Society of Testing and Materials
CALM Cleanup Levels for Missouri
CERCLA Comprehensive Environmental Response, Compensation and Liability Act
CFR Code of Federal Regulations
COC contaminant of concern
CPT cone penetrometer test
CSM conceptual site model
DEC Department of Environmental Conservation
DEP Department of Environmental Protection
DEQ Department of Environmental Quality
DFA dynamic field activities
DHEC Department of Health and Environmental Center
DL detection limit
DNAPL dense, nonaqueous-phase liquid
DOE Department of Energy
DOIT (Committee to) Develop On-Site Innovative Technologies
DSITMS direct sampling ion trap mass spectrometer
DTSC Department of Toxic Substances Control (CA)
DQO data quality objective
ECOS Environmental Council of the States
ELAP Environmental Laboratory Accreditation Program
EM electromagnetic
EPA Environmental Protection Agency
ERJS Environmental Research Institute of the States
ESA Expedited Site Assessment
ESC Expedited Site Characterization
FATE Field Analytical Technologies Encyclopedia
FFD fuel fluorescence detector
FSP field sampling plan
GC gas chromatograph
GIS geographical information system
GPS global positioning system
HSP health and safety plan
HTRW hazardous, toxic, and radioactive waste
ICRU International Commission on Radiation Units and Measurements
ITRC Interstate Technology & Regulatory Council
ITS Integrated Technology Suite
LIF laser-induced fluorescence
LOQ limits of quantitation
MARS SIM Multi-Agency Radiation Survey and Site Investigation Manual
MCL maximum contaminant level
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B.I Fernald Uranium Processing Facility
B. 1.1 Background Summary
Originally named the Feed Material Production Center, this Ohio facility's primary mission was
to produce high-purity uranium metal products in the form of ingots, derbies, billets, and fuel
cores for other sites within the nuclear weapons complex. Some sites used the products as fuel
for nuclear reactors to produce plutonium. The Fernald site was a uranium processing facility; it
did not contain a nuclear reactor, nor did it produce or handle explosive devices, nuclear
weapons, or highly radioactive material. During its 38 years of operations, the Fernald site
played a critical role in the nuclear weapons complex, delivering nearly 170,000 metric tons
uranium (MTU) metal products and 35,000 MTU of intermediate compounds, such as uranium
trioxide and uranium tetrafluoride. In 1989, after 37 years of operations to support the U.S.
weapons program, site management shut down uranium metal production to concentrate on
environmental compliance, waste management, and remediation.
B.I.2 Significant Project Issues
Many U.S. Department of Energy (DOE) sites are involved in a cleanup and closure process. The
surface soils (e.g., the top 10 cm) of many of these sites are contaminated with gamma-emitting
fission products (e.g., cesium, Cs-137 and cobalt, Co-60) and product material (e.g., uranium).
The site investigative process involves many soil surveys:
• an initial characterization survey to delineate radionuclide contamination,
• a remedial action surveys that support remediation activities and determine when a site or
survey unit is ready for a final status survey, and
• a final status survey that is used to verify that a site or survey unit has met its cleanup goals.
At the time that Fernald began site remediation, regulatory guidance addressing protocols for soil
sampling and sample collection was provided by the EPA (EPA 1992). In general, the approach
to a characterization survey for surface soil involves the collection of discrete soil cores,
typically to a depth of about 10 cm. While the number and location of the samples depend on the
nature of the contamination coupled with a limit on the sampling uncertainty, a conservative
estimate for an initial characterization survey might be one soil sample for every 100 m2. To
illustrate the economic impact of any sampling protocol adopted by the DOE, consider the fact
that the DOE's Office of Environmental Management has identified 36 sites in 14 states that
need remediation. The total area of these 36 sites covers approximately 1590 square miles. If one
soil sample were collected for every 100 m2, then over 41 million samples would be needed. The
cost of such an effort would likely run into the billions of dollars. Faced with these numbers site
managers are forced to look for alternative or innovative approaches to soil characterization to
reduce the effort and cost involved in soil measurements.
B.I.3 Project Team
Fluor Fernald has managed the cleanup of the Fernald site for DOE. Rob Janke was the DOE
project manager responsible for the soil remediation effort. Fernald formed a Real-Time
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Measurement Work Group, which consisted of DOE management, contractors, technical experts,
and regulators, to examine the use of emerging real-time soil characterization technologies (e.g.,
in situ gamma ray spectrometry) as a means of providing a cost-effective, technically defensible
approach to site characterization
B. 1.4 Implementation of Triad Approach
• Systematic Project Planning - The project team met to identify project goals, necessary
decisions, and the regulatory process. It was possible to reach agreement among the team
regarding many issues. For example, while it was acceptable to utilize real-time measurement
technologies for initial characterization surveys, it was agreed that final status surveys would
be done using the conventional radionuclide-sampling techniques.
• Dynamic Work Strategies - Using a field-portable gamma-ray spectrometer, a global
positioning system (GPS), and geographic information system (GIS) software the position
and concentrations of contaminants in the near surface were mapped at the conclusion of
each day in the field. This approach allowed contaminant distributions to be measured in a
study area. The available maps, in turn, allowed for dynamic work plans where decisions on
further remedial action were made while field teams were deployed or while closure
verification processes were started using the final in situ data and/or a statistical sampling
plan for collecting physical samples.
• Real-Time Measurement Technologies - The technology used at Fernald consisted of field-
based gamma-ray spectrometers and corresponding platforms, along with GPS and GIS. The
GPS and GIS systems provided the ability to map contamination. The system is referred to as
the Integrated Technology Suite (ITS) and is not commercially available. A detailed
description of in situ gamma-ray spectrometry and the ITS may be found in papers and
reports documenting activities at Fernald (Mille, Shebell, and Klemic 1993; ICRU 1994;
DOE 2001).
B.I.5 Project Improvements due to the Triad Approach
Early in the project (June 1998) a detailed estimate was prepared that addressed expected costs
and cost saving associated with using real-time soil characterization techniques. Cost savings
were estimated as the difference between the estimated cost of characterization activities during
remedial activities using real-time methods and the estimated cost of accomplishing a similar
level of characterization using conventional sampling and analysis methods. The estimated
savings were $34M (1998$) for the period FY1998 to FY2006 (DOE 2000).
B. 1.6 Project Outcome and Lessons Learned
Regulatory approval can be an obstacle to the use of in situ characterization methods.
Regulatory approval can be an obstacle to the use of in situ characterization methods.
Regulators (state and federal) did not approve the use of in situ methods for certifying that
the soil meets the appropriate cleanup criteria. The regulators did approve in situ methods for
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use in all phases of characterization during soil remediation except for the final certification
phase. When only a limited numbers of soil samples collected, the conventional approach is
subject to substantial uncertainty due to sampling error. However, for regulators the technical
advantage of in situ measurements may be of less importance than the perceived risk
associated with approving the use of a nonstandard approach.
The major cost savings that result from the use of the ITS at Fernald are associated with
precertification.
The major cost savings associated with the use of the ITS occur when mobile detectors are
used to scan large areas, as is done during precertification. Such scans greatly increase the
probability of locating significant hot spots and allow the average soil concentrations of the
primary radiological contaminants in the area to be determined. These averages can be
compared to cleanup levels to determine whether any additional soil excavation is necessary.
To obtain comparable results using a conventional sampling and analysis approach would
require the collection and analysis of a large number of samples, at a cost of approximately
$44K per acre. Average field costs for use of the ITS during precertification, based on
several years of experience, are about S1.2K per acre.
The detectors require calibration under controlled conditions.
The detectors (sodium iodide scintillators coupled to photomultiplier tubes) used on mobile
platforms were initially calibrated in the field using location having contaminated soil that
has been characterized independently using other more reliable detectors (i.e., high-purity
germanium detectors). However, the contamination in such areas is heterogeneous and
occurrences of different types of contamination may be correlated. Also, the calibration
locations are lost as contaminated soil is excavated. Therefore, a permanent calibration pad
was constructed, and the detectors were calibrated under controlled conditions using the pad.
B.I.7 Contacts
Fluor Fernald, Inc.
Richard Abitz
Phone:(513)648-4629
E-mail: Rich. Abitzfoifernald.gov
B.2 Varsity Cleaners
B.2.1 Background Summary
The Florida legislature established a voluntary state-funded program in 1996 to clean up
properties that are contaminated as a result of operations of a dry cleaning facility, prioritizing
sites with potential impacts to drinking water supplies. The Florida Dry Cleaning Solvent
Cleanup Program is funded through a gross receipts tax on dry cleaner operations and a tax on
the sale of perchloroethylene (PCE). Remediation of sites is performed by state-approved
contractors who employ a Triad-like approach utilizing systematic planning, dynamic work
strategies, and real-time measurement technologies for site evaluation and cleanup (HSA 2002)
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Varsity Cleaners, located in Tampa Florida, is in a mixed commercial/residential setting where a
dry cleaning business operated from 1960 to 1998. A service station was formerly located on an
adjacent property, and a water supply well is 0.5 miles northeast of the site. It was suspected that
groundwater was contaminated with various organic solvents. PCE was found to be the
contaminant with the highest concentration, 4,940 ug/L in a groundwater plume estimated to be
420 by 300 feet in size. The highest concentration of PCE found in soil was 2,260 ^g/kg. The
cleanup goals were established prior to remediation and for PCE were set at 3.0 ^ig/L for
groundwater and 30 |ag/kg for soil. These values were achieved during the cleanup.
B.2.2 Significant Project Issues
Construction of a large drugstore adjacent to this site demanded that the work be performed as
quickly as possible. The most important issues in this investigation were potential impacts to
groundwater and the desire of developers to reuse the site as soon as possible. The use of the
Triad approach minimized multiple mobilizations and greatly reduced the time required for
project completion.
Florida DEP worked with the contractor to define cleanup goals and approaches through
systematic project planning, and the contractor was allowed flexibility in means to perform site
remediation. This interactive approach encouraged trust between regulator and contractor and
allowed HSA Engineers and Scientists, the contractor, the flexibility to employ their expertise as
required to achieve the project goals.
B .2.3 Proj ect Team
HSA Engineers and Scientists (HSA) - a Florida DEP-approved contractor
Elizabeth Walker, Florida DEP, Drycleaner Solvent Cleanup Program, Contract Manager
B .2.4 Implementation of the Triad Approach
• Systematic Project Planning - Despite the short time frame to initiate the project, the project
team met to develop project goals. The project team had considerable experience with dry
cleaning sites in similar geologic settings, which facilitated the creation of the CSM. Due to
financial reasons the owner of the site requested that the remediation of the former dry
cleaning site be completed quickly.
• Dynamic Work Strategies - The work began on September 14, 1998 and concluded less than
two months later on November 4, 1998. The decision logic created during systematic project
planning was used to guide the investigation and remediation of the site. The entire project
was completed in one mobilization.
• Real-Time Measurement Technologies — A variety of analytical parameters were examined
including volatile organic compounds (VOCs), nitrate/nitrite, ammonia, total Kjeldahl
nitrogen, total organic carbon, iron, sulfate, and chloride. All field measurements were
performed in accordance with HSA's Florida DEP-approved quality assurance plan and
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included blind and duplicate samples at prescribed frequencies. Comparisons of VOC
samples analyzed by a Photovac field-portable GC and by SW-846 methodology were made
to confirm data quality and to guide project decisions. The extensive use of field-portable GC
analyses and the reduced turnaround time from sample acquisition to data availability greatly
contributed to the reduction of time and cost for this Triad approach as compared to
conventional remediations involving only the use of analyses generated by fixed off-site
laboratories.
B.2.5 Project Improvements due to the Triad Approach
Total project costs were $690,600, of which only $148,000 was attributable to site assessment
activities. It is impossible to quantify how much this remediation would have cost if a non-Triad
approach had been employed, but conservative estimates are that 2-3 times the cost would have
been incurred.
B.2.6 Project Outcome and Lessons Learned
Adaptive field activities
Use of field GC measurements enabled specific sources of PCE contamination to be
delineated, including a concrete vault and drain field that, if not identified, would have acted
as a continuing contaminant source.
Refinement of soil excavation quantities
Thorough characterization using field analysis minimized the amount of soil that needed to
be removed. This could not have been accomplished using fixed-laboratory methods alone.
Acquisition of both characterization and remedial design data
After the site was investigated and the soil hot spots removed, a pump-and-treat system was
installed to remediate residual contamination in the clay and limestone.
Final confirmation samples
Regulatory-approved analytical methods were employed to confirm final contaminant levels.
B.2.7 Contacts
Florida Department of Environmental Protection
Elizabeth Walker, Contract/Project Manager
Phone: (850) 245-8927
E-mail: beth.walker@dep.state.fl.us
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B.3 Wenatchee Tree Fruit Research and Extension Center Test Plot
B.3.1 Background Summary
The Wenatchee Tree Fruit Research and Extension Center located in Wenatchee, Washington,
contained soils contaminated with organochlorine pesticides (which include DDT, endrin, and
dieldrin, among others), organophosphorus pesticides, and other pesticides due to agriculture-
related research activities conducted from 1966 until the mid-1980s. In 1997, the U.S. Army
Corps of Engineers (USAGE) implemented an integrated site characterization and remediation
project at the site. The Triad approach was used to facilitate quick cleanup and included
systematic project planning, on-site remedial decision making using dynamic work strategies,
and on-site measurements with immunoassay methods. This approach permitted characterization,
excavation, and segregation of soil based on the result of rapid on-site analyses employing
commercially available immunoassay testing products (EPA 2000c).
B.3.2 Significant Project Issues
The determination of the suitability for the on-site analytical methods was a major project issue.
Therefore, a pilot test was performed to compare the immunoassay field method and traditional
fixed-laboratory methods. The test demonstrated the applicability of immunoassay and laid the
grounds for method modification, and provided data for development of site-specific action
levels. No significant problems were encountered throughout the project, primarily due to the
systematic planning that had identified potential issues and reached consensus on the course of
actions.
B.3.3 Project Team
Planning and field teams were created to include the appropriate mix of skill and regulatory
authorities needed to plan and implement cleanup. The planning team comprised representatives
from EPA ORD (responsible party), the regulator (Washington State Department of Ecology),
stakeholders (Washington State University), USAGE project manager, chemist, heath and safety
hygienist, and construction engineer. The field team comprised of USAGE project manager,
chemist, construction engineer, field QA/QC and health and safety officer; the prime contractor
(project manager, field engineer, project chemist/QC officer); and subcontractors to perform
excavation, IA, operate Geoprobe, and manage soil disposal activities.
B.3.4 Implementation of the Triad Approach
• Systematic Project Planning - Systematic planning for the project was accomplished by a
team representing the USAGE, EPA, the site owners, and state regulators with appropriate
mix of skills and decision-making authority. An initial conceptual site model (GSM) was
developed after reviewing existing information. The primary purpose for the project was to
clean up contaminated soil. The team during the systematic planning phase identified the
specific goals:
o focused removal of concentrated pesticide product,
o gross removal of pesticide-contaminated soil,
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o restoration of the site to achieve the cleanup level, and
o characterization, classification, and disposal of contaminated materials.
The decisions to achieve these goals were identified. The first decision was to determine
whether the soil within each unit was contaminated above the action levels for each
contaminant of concern (COC). After removal, a second decision was required to determine
if the remaining soil attained the cleanup standard. Once the soil and other wastes were
removed, a third decision was to define appropriate classification of the waste for disposal
purpose.
Inputs to the decisions were identified, for example, to make remedial decisions (i.e., to
remove or not to remove the soil) the necessary inputs included, at a minimum, a list of
COCs and cleanup levels, target quantitation limit, candidate analytical method of achieving
the quantitation limits, and measurement performance criteria. The limits of the decision
errors were also specified in the planning stage.
• Dynamic Work Strategies - The use of data generated on site allowed relatively quick
decision making regarding subsequent steps in accordance to the decision rule established
during the planning stage. Field-generated data were used to update the CSM to direct
subsequent steps. This approach permitted rapid location and definition of hot areas, guided
removal of contaminated soil, and quickly identified when enough information had been
collected. This approach minimized the collection and analysis of uninformative samples,
avoided unnecessary removal of soil, avoided multiple rounds of mobilization, and
effectively identified when the project was done.
• Real-Time Measurement Technologies - Immunoassay test kits were used to analyze
contaminated soil in the field. A pilot test was performed by analyzing contaminated soil by
immunoassay methods and by traditional fixed-laboratory methods. The result of the pilot
test demonstrated the applicability of the field methods, guided method modification to
streamline field analyses, and enabled establishment of site-specific action levels. The
adaptive work plan permitted field team to make real-time decisions on the basis of data
generated in the field.
B.3.5 Project Improvements due to Triad Approach
The use of the Triad approach for this project resulted in savings of about 50% (over $500,000)
over traditional site characterization and remediation methods. The project was completed in one
mobilization, which allowed significant cost savings over multiple mobilizations that would have
otherwise occurred. The systematic project planning and use of dynamic work strategies saved
significant time by allowing on-site decision making and reduction in multiple regulatory
reviews. Costs of waste disposal were significantly reduced by using field analyses to
characterize and segregate wastes that required costly incineration from other waste that were
suitable for less-expensive disposal methods.
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B.3.6 Project Outcome and Lessons Learned
Unexpected conditions
There was some uncertainty regarding the actual project boundaries. This was confirmed
during the course of the field work, and the uncertainty was easily resolved with the
immunoassay test kits.
Use of immunoassav test kits
Immunoassay analysis is not specific to a single compound but reacts to a range of
structurally similar chemicals. Thus, it is important to ensure that the investigation QC
program addresses potential immunoassay cross-reactivity. In addition, the immunoassay test
kits are manufactured to have a high bias to ensure against false negative decision errors. It
may be necessary to determine the actual bias for a specific project.
B.3.7 Contacts
Responsible Party: Howard Wilson, U.S. Environmental Protection Agency, Office of
Research and Development, 1200 Pennsylvania Avenue, NW, Washington, DC 20406, (202)
564-1646
Contractor: Ralph Totorica, Project Manager and Greg Gervais, QA Representative, Kira
Lynch, Project Environmental Scientist, USAGE, Seattle District, 4735 East Marginal Way
South, Seattle, WA 98134, (206) 764-6837
State Regulatory Contact: Thomas L. Mackie, Washington State Department of Ecology,
Central Regional Office, 15 West Yakima Avenue, Suite 200, Yakima, WA 98902-3401,
(509) 454-7834
Technology Demonstrator: Mike Webb, Garry Struthers Associates, Inc., 3150 Richards
Road, Suite 100, Bellevue, WA 98005-4446, (425) 519-0300
B.4 Assunpink Creek Brownfields
B.4.1 Background Summary
The Triad approach was utilized to investigate two brownfields sites that are part of the
Assunpink Creek Greenway Project in Trenton, New Jersey. The project is an initiative by the
City of Trenton to redevelop abandoned brownfields properties along the Assunpink Creek into a
recreational area and greenway. The City of Trenton entered into a memorandum of agreement
with the New Jersey Department of Environmental Protection (NJDEP) to investigate portions of
the Crescent Wire site and the Freight Yards site. The Crescent Wire site is an approximately
2-acre vacant lot that is currently owned by the city and was formerly used for the manufacturing
of high-tension cables and wires. Operations at the site ceased prior to 1995, and the former
building was destroyed by fire in 1996. The site is presently vacant and covered primarily by
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concrete. The city owns a portion of the Freight Yards site, which was historically used as
railroad freight depot. Operations at this site ceased in the mid-1980s. The Freight Yards site
comprises an area of approximately 37 acres and presently includes paved roadways and
unpaved areas that are primarily covered by rails.
Preliminary assessment activities were performed, and limited sampling was initially conducted
at both properties to provide initial characterization of environmental conditions. Several areas of
concern (AOCs) were identified at each site that required further delineation. This information
was utilized to support development of the preliminary conceptual site model (CSM) and to
initiate the systematic planning step. The Triad approach was selected to complete the
delineation of PCB impacts that were identified in soil at the Crescent Wire site and to complete
the investigation of several AOCs at the Freight Yards site including sitewide soil impacts across
the rail area, an existing aboveground storage tank area, fuel oil spills, and areas of distressed
vegetation. Dynamic work strategies were incorporated into project planning documents to
codify the investigative objectives and approach, for approval by all stakeholders prior to
initiating the field investigation.
B.4.2 Significant Project Issues
The City of Trenton was interested in accelerating the site characterization phase so that the
scope and cost of remedial actions could be developed in a short time frame. The Triad approach
was selected in an attempt to complete the characterization of identified impacts in one
mobilization.
The project was undertaken in cooperation with several stakeholders to evaluate an innovative
approach for reducing the cost and timeframe for environmental investigations at brownfields
sites.
The use of field analytical methods required preapproval by NJDEP, which participated in the
systematic planning process along with the other stakeholders.
B.4.3 Project Team
• City of Trenton, N.J.
• Langan Engineering & Environmental Services, Inc. - Doylestown, Pa.
• S2C2 Inc. - Raritan, N. J.
• New Jersey Department of Environmental Protection
• New Jersey Institute of Technology
• U.S. Environmental Protection Agency, Technology Innovation Office
B.4.4 Implementation of the Triad Approach
• Systematic Project Planning - The systematic planning process involved a careful review of
existing environmental data for the sites, the generation of a CSM, and several meetings with
stakeholders to identify project objectives and reach a consensus on an investigative
approach. A project kick-off meeting was held to discuss project objectives and stakeholder
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concerns. Two additional meetings were then conducted to discuss the investigative approach
and finalize the adaptive work plan.
• Dynamic Work Strategies - The work planning documents laid out the investigative
objectives and the approach and clearly articulated the investigative decision logic. The work
plan contained a review of existing environmental data and a presentation of the CSM. A
crucial element of the adaptive work plan was a series of decision rules, which directed
continued sampling until project objectives were met. Stakeholders' comments on draft work
plans were incorporated into the final NJDEP-approved adaptive work plan.
• Real-Time Measurement Technologies - A variety of analytical methods were utilized in the
field to obtain real-time data that were evaluated and used to direct the field program until the
investigative objectives were achieved. A modified version of EPA SW-846 gas
chromatograph - mass spectrometer (GC-MS) Method 8270C was used for the analysis of
individual polynuclear aromatic hydrocarbons (PAHs) and total petroleum hydrocarbons
(TPH) in soil. A Spectrace 600 x-ray fluorescence (XRF) was used for the analysis of metals
in soil. An immunoassay RaPID Assay test kit by EPA SW-846 Method 4020 was used for
the analysis of PCBs in soil. PCB detections by the RaPID Assay were confirmed in real time
by the on-site GC-MS (modified 8270C). A Petro Flag test kit was used for the analysis of
TPH in soil.
B.4.5 Project Improvements due to the Triad Approach
The most significant benefit resulting from the use of the Triad approach was the reduction in
investigative phases and overall time for the characterization of environmental impacts at the
site. The investigation of the Crescent Wire site was completed within one week, and the
investigation of the Freight Yards site was completed within four weeks. The increased sampling
density afforded by the lower cost field analyses enabled a more detailed characterization of the
site, thereby reducing the uncertainty of environmental conditions. Although the overall cost
savings using the Triad approach has not been quantified, the completion of site characterization
objectives within one mobilization and the use of field analytical methods resulted in a cost
benefit to the City of Trenton.
B.4.6 Project Outcome and Lessons Learned
Accelerated site characterization
The Triad approach was successfully applied to accelerate the characterization and
delineation of environmental contamination at two brownfields sites.
Fewer unresolved site uncertainties
The high sampling density utilized as part of the Triad approach identified a PCB "hot spot"
at the Freight Yards site that would have likely been missed by a conventional investigative
approach.
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Greater initial effort required of the regulators
The systematic planning and dynamic work strategy steps of the Triad approach required a
considerable amount of NJDEP resources on this high-profile project that may not always be
as readily available. However, as the Triad approach becomes better understood and more
widely accepted, it is anticipated that less up-front involvement would be required of the
regulators.
B.4.7 Contacts
John Musco and Katherine Linnell
Langan Engineering & Environmental Services, Inc.
500 Hyde Park
Doylestown, PA 18901
Phone:(215)348-7101
E-mail: imusco@langan.com and klinnell@langan.com
B.5 McGuire Air Force Base C-17 Hangar Site
B.5.1 Background Summary
McGuire Air Force Base (AFB) in New Jersey was selected to receive a new transport aircraft,
the C-17, to support United States military operations. The C-17 aircraft required a new hangar
that was to be constructed on the location of former base maintenance buildings. The limited
investigation data available for the new hangar location suggested that chlorinated solvent
contamination was present at concentrations requiring remedial action.
B.5.2 Significant Project Issues
Construction had started on the $28 million C-17 hangar when contamination issues required that
the work be halted. Preliminary work on the hangar was stopped in March 2003. The Air Force
determined that construction must resume no later than July 2003 to enable the deployment of
the C-17 to remain on schedule. To accomplish this goal, the investigation of the site had to be
completed in only three months. An interim remedial action would follow shortly thereafter. The
environmental restoration team at McGuire AFB realized that only an innovative process—the
Triad approach—would allow the hangar project to remain on schedule. McGuire AFB formed a
core technical team from environmental consultants with the necessary experience to implement
Triad.
B.5.3 Project Team
Christopher Archer, McGuire AFB Environmental Flight, Chief
Bryan O'Ferrall, Air Force Center for Environmental Excellence, Project Manager
John Pohl, McGuire AFB Environmental Flight, Restoration Project Manager
Paul Ingrisano, U.S. Environmental Protection Agency, Region II Remedial Project Manager
Phil Cole, New Jersey Department of Environmental Protection, Case Manager
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Scott Beckman, Science Applications International Corporation (SAIC), Project Manager
Joel Hayworth, Hayworth Engineering Science (HES), Inc., Core Technical Team Leader
William Davis, TriCorder Environmental, Core Technical Team member
B.5.4 Implementation of the Triad Approach
• Systematic Project Planning - After the team was assembled, specific project objectives were
established: (1) locate the source of the solvent contamination, (2) characterize the
groundwater solvent contamination, (3) determine whether other contaminants were present,
(4) obtain appropriate data to support an interim remedial action, if needed, and (5) conduct
any needed removal actions beneath the footprint of the hangar. A CSM was created based
on historical information and the limited available contaminant data. The regulatory agencies
were included from the very earliest stages of planning. The project team agreed to
contaminant action levels and to decision logic guiding investigation and remedial activities.
• Dynamic Work Strategies - The project work plan included sampling contingencies based on
the decision logic established earlier. Data collection was sequenced to efficiently determine
the hydrogeology as well as the magnitude and extent of the contamination. Experienced
members of the Core Technical Team guided the field work. The CSM was updated
frequently using data from a variety of real-time collection technologies. All site
uncertainties were investigated and resolved during the course of the fieldwork.
• Real-Time Measurement Technologies - To ensure that the site was completely
characterized within the available three-week field work schedule, direct-push equipment
equipped with advanced sensor technology was used. A cone penerrometer test (CPT) rig
with both a membrane interface probe (MIP) and fuel florescence detector (FFD) was
deployed to the site. This was supplemented with a drilling rig combining direct push with a
hollow-stem auger system. Volatile organic chemical analysis in soil and groundwater was
accomplished with a direct sampling ion trap mass spectrometer (DSITMS) running EPA
Method 8265. A Niton XLT/500 x-ray florescence (XRF) unit was used for analysis of
metals in soil. Sample collection locations were surveyed with a global positioning system
(GPS) with submeter accuracy. Data was managed/evaluated in the field using geographical
information system (GIS) and analysis software applications.
B.5.5 Project Improvements due to the Triad Approach
No cost estimates were prepared comparing a hypothetical traditional process to the actual
approach (Triad). However, it was estimated that the cost of the investigation was comparable to
a more traditional investigation that would have taken longer, provided less contaminant data,
and would have likely left significant site uncertainties unresolved. The most significant benefits
to the project were the time savings—on the order of 18-24 months—which allowed the pending
hangar construction to proceed on schedule.
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B.5.6 Project Outcome and Lessons Learned
Early involvement of the regulators in planning
Faced with the abbreviated schedule for the project the McGuire AFB environmental
restoration team recognized that the regulators must be involved from the beginning of
project planning. The project team including the regulators was successful in quickly
identifying objectives and agreeing on responses to a variety of potential contaminant
scenarios.
The benefit of experienced environmental professionals
It would not have been possible to plan and successfully execute the investigation within the
available time without the use of experienced environmental professionals. The Core
Technical Team consisted of senior engineers and scientists accustomed to working in a
multidisciplinary fashion.
The use of environmental data management software
The real-time measurement technologies employed for this project generated large amounts
of data. It would not have been possible to rapidly manage, visualize, and use these data
without the use of database, GIS, and contaminant analysis software.
B.5.7 Contacts
John Pohl, Restoration Project Manager
McGuire Air Force Base, New Jersey 08641
Phone: (609) 754-3495
E-mail: iohn.pohl(a),mcguire.af.mil
B.6 Pine Street Barge Canal
B.6.1 Background Summary
The Pine Street Barge Canal is located in Burlington Vermont and was constructed in 1868. The
Canal presented an environmental risk where the contaminants of concern were coal tars and
metals. Historical site uses included a lumber and coal shipping yard and a manufactured gas
plant that operated from 1895 through 1966. Waste from the plant, including coal tar, was
released to the site, where it was absorbed into natural peat and layers of wood chip fill in the
subsurface. Over the decades, coal tar constituents from the gas plant accumulated in the
sediments in the canal. Oil spills, other industrial discharges and disposal activities, and urban
storm-water runoff also have impacted the site.
Burlington is a lakeside community that values highly its past and present relationship with Lake
Champlain. The Pine Street Barge Canal was a 70-acre site in the downtown area and on
Burlington's waterfront to Lake Champlain.
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In 1983 the site was listed as a Superfund site, and in 1991 the EPA arrived at a proposed
remedy. That proposal called for a $50 million remedial plan that involved dredging and the
construction of a containment unit that would have become one of the most salient elements in
the city's landscape. In response to public concern about the proposed remedy, EPA withdrew its
proposed remedial plan in 1992 and accepted an initiative to develop an alternative plan. In 1992
the Pine Street Barge Canal Coordinating Council was formed. The potentially responsible
parties (PRPs) agreed to undertake an additional RI/FS in 1993 that was performed with the
active participation of the Coordinating Council.
Elements of the Triad approach (systematic planning and real-time measurement) were applied
to plan and implement the additional RI/FS, leading to substantial investigation time and
remediation cost savings.
B.6.2 Significant Project Issues
• Acceptance of real-time measurements as decision quality data, without involving EPA Level
IV QAPP protocols. This was at a time when real-time measurement methods were in an
early phase of acceptance. The Pine Street Barge Canal Coordinating Council overcame that
hurdle by undertaking a correlation study, which compared full laboratory protocol to
immunoassay measurement.
• The project was the first to involve a coordinating council of the PRPs and active community
representatives in the work plan development and decision-making process.
B.6.3 Project Team
The project team included
Pine Street Barge Canal Coordinating Council
Vermont Department of Environmental Conservation
The Johnson Company, consulting engineers, Montpelier, Vermont
EPA Superfund Program
B.6.4 Implementation of the Triad Approach
• Systematic Project Planning - The systematic project planning process was achieved through
the development of an exhaustive CSM, based on the data developed in the previous years of
investigation, which identified the before undescribed hydrogeologic equilibrium processes
with the adjacent Lake Champlain. The Coordinating Council produced a work plan through
consensus, which clearly identified the goals and objectives for the Additional RI/FS and
established the remedial option decision selection process.
• Dynamic Work Strategies - The work plan involved the identification in the field of different
bioregions of the Pine Street Barge Canal wetland and provided a detailed description of the
sampling protocols and the decision-making procedure for further sampling, based on the
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field-identified soil matrix conditions. Those soils meeting the work plan criteria were
submitted to real-time measurement.
• Real-time Measurement Technologies - In the RI/FS investigations that ensued after 1992,
the focus was to characterize the contaminant distribution within the shallow soil and
sediments. The consultant proposed a Phase I ARI that applied real-time measurement of
PAHs via immunoassay screening and on-site XRF for metals with a 10% analytical
laboratory confirmation. The per sample costs for these screening analyses were a fraction of
the laboratory analytical costs. The plan also called for the establishment of a field lab with a
QAPP. During the implementation of the Phase I ARI sampling plan, 146 shallow
upland/wetland soil samples and 87 canal sediment samples were collected and analyzed for
PAHs. Forty-five more surface soils were analyzed to characterize areas for human health
risk assessment that had not been sampled earlier. Twenty-five confirmation samples were
submitted for PAHs and metals. The data developed during this phase of the investigation
allowed the study area to be divided into eight distinct areas of similar features for
subsequent toxicity testing. The correlation between the real-time measurements and the
commercial analytical laboratory supported the use of the real-time measurements for the
overall site characterization. This characterization identified areas most likely to pose
unacceptable ecological risk. The toxicity testing and other ecological sampling programs
were then designed to evaluate these areas. During a Phase II ARI the real-time measurement
techniques were again applied to identify the sample points that would be submitted for
toxicity testing. The results of this phase established that five of the eight distinct areas
required risk management measures. This process effectively reduced the 70-acre Superfund
site area to 38 acres.
B.6.5 Project Improvements due to Triad Approach
The selection of a remedial strategy was a collaborative effort between the PRPs, EPA, the State
of Vermont, the U.S. Fish and Wildlife Service, the City of Burlington, the Lake Champlain
Committee (a local environmental group), and local public and business representatives. This
process was the first such collaborative process for the EPA Superfund Program. EPA New
England Administrator at the time, John P. DeVillars, said that the consensus-building model
used at the Pine Street Barge Canal stands as a national model for community-based decision
making.
The findings from these real time-based investigations led to the selection of an innovative,
much less intrusive, remedial approach that was accepted by regulatory agencies and the public,
costing less than $5M. A $45M cost savings was realized, along with the implementation of a
less intrusive and more protective remedial option that preserved the city's landscape. The
primary feature of the revised approach was a subaqueous silt/sand cap over the coal tar-
contaminated sediments to isolate them from ecological receptors.
Also significant to this effort was that the site definition was reduced from 70 acres to 38 acres,
allowing the PRPs and the city to better manage the future use and development of the site.
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B.6.6 Project Outcome and Lessons Learned
Faster site characterization
Real-time in-field analysis successfully accelerated the characterization and delineation of
environmental impacts at the Pine Street Barge Canal.
Better quality investigations
Greater number of sample points for a comparable investigative cost allowed a more
thorough description of site conditions and a higher level of development of the CSM.
Correlation study facilitated use of field analytical methods
The correlation study was a fundamental threshold in the acceptance of real-time
measurements as decision quality data in environmental investigations.
B.6.7 Contacts
Sonja Schuyler, Senior Scientist
The Johnson Company, Inc.
100 State Street
Montpelier, VT 05406
(802) 229-4600
E-mail: sas@icomail.com
Michael B. Smith, Hydrogeologist
Waste Management Division
103 South Main Street West Building
Waterbury, VT 05671-0404
(802)241-3879
E-mail: michael.smith(5),anr.state.vt.us
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APPENDIX C
Response to Comments
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SCM Team Response to Review Comments
SPECIAL NOTE; The ITRC Sampling, Characterization, and Monitoring team is especially
grateful to members of the USAGE ITA program who reviewed and commented on the
document. Of particular note, Kira Lynch and Cheryl Groenjes provided constructive comments
that helped improve the document. Jeff Breckenridge is the former coordinator of the USAGE
ITA program, and Greg Mellema became the program coordinator during the time of this review.
The team is grateful to both for allowing participation in the review.
The SCM team is also grateful to those states that responded with comments about the draft
document. Of particular note, the team would like to thank the very thoughtful and thorough
review made by the Nebraska DEQ. Comments from the various reviewers follow.
Reviewer: US Army Corps of Engineers Innovative Technology Advocates
Program
The document provides excellent guidance and will help to lay the groundwork for change in our
industry and improvements in the execution of the Triad projects. Thank you for the opportunity
to comment.
We concur, and thank you.
1. p. 2, Penultimate sentence of 1.2 (& p. 27, 2.8.4-similar text). Suggest, "...achieving
consensus on the investigation objectives prior to beginning generation of planning documents,
which support fieldwork." Clarification will focus this being accomplished before the writing,
review and approval of project planning documents. This can increase the cost effectiveness of
these tasks by all parties —for they have been discussed during planning and are in agreement
with the basic concepts and objectives with which they are based.
We concur - the suggested wording was added to the sentence.
2. p. 4, (2.1) 1st paragraph of pg., last sentence. Suggest, "It is crucial to use the GSM to avoid
sampling errors and to interpret results from various data sets, including lower density fixed-
laboratory analysis in conjunction with the real-time measurements.
We concur - the suggested wording was added to the sentence.
3. p. 4, (2.1) 2nd paragraph of pg., 3rd sentence. Suggest, "Heterogeneity can have important
repercussions on sampling design, analytical method performance, spatial interpretation of
data, toxicity and risk estimation, and remedy design and success."
We concur - the suggested wording was added to the sentence.
4. p. 4, Outlined box, last sentence. Suggest, "The Triad explicitly manages the largest source of
data uncertainty, which is data variability caused by the heterogeneity of chemical
contaminants and the impacted environmental matrices."
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We concur - the suggested wording was added to the sentence.
5. p. 11-15, 2.4.3 and 2,4.4. Some of the text in these sections could be better focused. Suggest
rework of text in light of the following.
• p.11, 2nd paragraph. The first sentence's message - which the CSM is generally updated
after the completion of each 'phase' of work and then seems to have to clarify that a
'phase' can be 'daily' is odd. Suggest as an alternative, that the revision/updating cycle
for the CSM(s) be noted as a project-specific decision(s) made during planning, that is
linked to the data being produced (how much, how fast) and how the data is being used
(are their daily decisions being made based on it, or is less frequency acceptable). The
motto should be the more data and more real-time the needs, the more frequent the CSM
should be updated. Daily is about as frequent as you can achieve / maintain. Suggest
emphasizing this as a group decision(s) by team members and project stakeholders. It
should be noted as a key aspect of the data management and project communication
strategies developed. Retain the sentence that states that the CSM be updated whenever a
significant change in previous interpretations. The last sentence seems confusing, for the
field personnel are normally the ones doing the CSM updating. Suggest, "When not
performing the CSM updates themselves, it is critical that field personnel be kept
informed of any updates to the CSM that occur during data collection activities."
We concur - similar wording was added to the sentence and paragraph.
• p.11, 2.4.3, 3rd paragraph. The text noted here and on p.14 in section 2.4.4 (1st and 2nd
paragraphs) lack a logical foundation to describe many of the terms used (i.e., various
heterogeneities, errors, and uncertainties), their sources, associations, or how to mitigate
them. Text on heterogeneities is disjointed across the 2 sections. Suggest these topics be
gleaned together and reworked to concisely introduce these topics with some of the
principals below for clarification.
o Heterogeneity is a state of nature that causes all sampling error. There are two types
of heterogeneity affecting environmental sampling: compositional and
distributional.
o Compositional heterogeneity applies predominantly to solids or suspended particles,
and can be defined as the difference in composition of particles for an analyte of
interest within a population. With compositional heterogeneity, because all particles
do not have the same concentration (i.e., contamination may be greater in the fines
or larger particles), this induces fundamental error, which can exacerbate other
sampling errors. The means for controlling compositional heterogeneity and
fundamental error is by collecting sufficient sample mass (based on particle size of
matrix, etc.).
o Distributional heterogeneity is defined as nonrandom distribution of particles,
which lead to grouping and segregation errors. The environmental causes for this
should be linked to existing text on p. 11 under spatial heterogeneity. Mitigation of
these can be done by collecting many random increments, segregating CSM (and
managing related data sets) into groups with similar characteristics, using sampling
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tools that minimize sample bias, and thorough mixing of the samples. The Triad
approach focuses on this type of heterogeneity and its associated sources of error by
initial segregation of the CSM into different populations based on suspected
contamination spatial patterns and project decisions associated with them (see
examples on bottom of p. 11), providing greater sample density with the use of real-
time measurement technologies, and ensuring thorough evaluation during planning
phases of the key sampling and analytical factors that impact the representativeness
of that sample and its data (fig.5).
o If existing project data shows high RPD values between duplicate samples
(indicating an incompatibility in results), this should trigger additional evaluation of
these matrix heterogeneity issues (and how they impact decisions). Research work
by T. Jenkins of CRREL, Chuck Ramsey of Envirostat, Inc., etc. on the impact
these heterogeneities have on soil sampling have identified the acquisition of short-
range (multi-aliquot) composite samples as a means to provide a more
representative field sample. Additionally, employing steps to dry, grind, and sieve
the sample matrix prior to sample preparation / analyses can also improve analytical
performance. Suggest linking this topic to text on p. 15 1st— 3rd paragraphs (DOE
study), which apply to compositional heterogeneity and its measured
uncertainty/variability.
We concur that heterogeneity could be better explained in the document; however, we
believe that most of the readers of this document will already have a basic understanding of
the subject. The suggested addition is an excellent discussion, and we will use it as part of
the planned internet and classroom training seminars to better explain environmental
heterogeneity.
• p. 12, 4thparagraph, last sentence. Once the approximate boundaries...(i.e., the CSM is
mature), data that are representative of specific project decisions is used will be collected
to estimate the properties of interest (stet).
We concur - the suggested wording was added to the sentence.
• p. 13, 2nd paragraph, last 2 sentences. Suggest this discussion be associated with another
type of error, i.e., statistical error. Some aspects influencing the amount of statistical error
are noted below, which in turn can lead to incorrect inferences about the population from
the data.
o Assume the wrong distribution (normal vs. abnormal)
o Violate assumptions of that statistic or distributions (contamination is not typically
random or independent)
o Use of the wrong statistic
o Incorrect use of censored data (how to interpret the nondetects)
We concur - similar wording was added.
6. p. 18, 2.5, 3rd paragraph, last sentence. Suggest, "For example, systematic planning can
establish how background concentrations of naturally occurring metals will be calculated and
used.
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We concur - the suggested wording was added to the sentence.
7. p. 19, 2.5, 2nd paragraph. Suggest noting this step is recommended when field data's use is
quantitative in nature. For instance, a numerical value will be generated that will be evaluated
against a project decision level, e.g., when used to monitor removal actions or other remedial
response actions. Also, include a reference to later sections (p. 27) 2.7 and the discussion of
confirmation samples / split sample analysis (2nd bullet). Another task commonly performed time
(during a pilot study, or initial start-up) is the modification / adaptation of preparatory procedures
and analyses to improve extraction efficiency, or improve performance in the project matrices.
We concur with the concept, but do not believe it is necessary to develop the paragraph to
this level of detail. No change was made.
8. p. 24, 2.7, 2nd paragraph. Suggest nominal clarification be provided to guide the application of
a quality control program. After the discussion on "the way the information generated will be
used", suggest introducing the concept of qualitative and quantitative data uses: Qualitative
data uses, e.g., those that support a general site (screening) assessment or refine the CSM,
may rely on the data's general agreement with expected CSM as a form of verification.
However in general, the validity of all in-field measurements should be established by
instrumental QC checks that demonstrate that the instruments calibrated (if appropriate.) and
functioning properly. When data uses are quantitative in nature, the assessment of the
numerical values produced becomes more critical. QC protocols should include both
instrumental and matrix-specific QC checks to verify the equipment is not only working
properly, but that the method shows acceptable performance with the project matrices.
Routine QC checks applied might include an evaluation of cross-contamination potential
sources (e.g., various blanks), limits of quantitation (LOQ) / detection limits (DL) in the
project matrix, or the bias from matrix interferences. Accuracy of the method should be
checked at project decision levels to assess the need for establishing 'gray regions' and
triggers for appropriate (split sample) (redundant) more definitive analyses. A series of
duplicate samples can be executed to evaluate sampling and analytical procedures, as well
as characteristics of sample heterogeneity and other sample support issues. There is a
diverse... (stet)
We concur - similar wording was added.
9. p. 24, 2.7, 3rd paragraph. Another serious deficiency of this arbitrary, rote confirmation sample
approach can be the untimeliness of the comparison of data sets. Although the option to evaluate
near real time is available, a traditional approach has been applied many times - where the
evaluation of comparability between field and fixed data sets actually waits until the final report.
When the correlation was not as expected or hoped, whole data sets were discarded. The Triad
instead tries to work real time to optimize the methods/techniques, understand their limitations,
trends, and effects on use. Suggest the "timing" of this data evaluation be emphasized, if any
benefit is to be assured from these data sets.
We concur - similar wording was added.
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10. p. 27, 2.7, last paragraph. Suggest associating this (confirmation) QC with data uses that are
quantitative in nature. Also recommend a minimum of 6 split samples be done to ensure nominal
validity of statistics performed.
We concur in general but do not believe the additional wording is needed. Because each site
is unique, we hesitate to recommend 6 (or any number) as a minimum for split samples.
11. p. 27, Field Methods can be used in a Fixed Lab box, 2nd sentence. Suggest, "If a fixed lab is
nearby a site, the option exists for running real-time analyses in a controlled environment,
thereby avoiding the costs of support facilities onsite. This may improve method performance
while retaining the advantages of rapid turnaround and greater sample numbers.
We concur - similar wording was added.
12. p. 28, 3rd and 6th Analytical bullets. Suggest dropping the "Draft" designation from Method
8265. (I know it is in draft form right now, but this will be removed soon.) Suggest adding 8510,
8515, (85** others?) to the current reference of the 9000-series colorimetric methods.
We concur and made the addition to the colorimetric bullet but left the "draft" on Method
8265 as it is draft at the time of this document publication.
The technical/regulatory guidelines document is very well written and will go a long way toward
helping to educate the environmental remediation community regarding the use of Triad work
strategies. Thank you for the opportunity to comment.
We concur, and thank you.
1. p. v, Executive Summary, I recommend changing the language in the second paragraph that
references "advocacy of field generated data" to "advocacy of use of near real-time data". The
reason for recommending this change is that far to many people think that the Triad equates to
using field analytical methods. The Triad does not specifically advocate the use of field
generated data but rather encourages people to consider the wide variety of analytical techniques
available and to design data collection strategies to make use of the numerous innovative
measurement and data visualization techniques available.
We concur. The wording was changed as suggested.
2. p. 5, first paragraph, Significant cost and time savings can result because characterization can
focus on uncertainties that impact appropriate remedial action selection, design, and associated
cost estimation. This is a key issue that should be documented in this paragraph and in the box.
We concur. The wording was changed as suggested.
3. p. 8, third paragraph, Fix typographical errors.
We concur; typographical errors have been fixed during the document review.
C-5
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4. p. 19, fifth paragraph, I suggest referencing the EPA Triad Procurement Guide since in this
guide we discuss issues when procuring Triad services at length. Consider adding "logistical
planning" to the new tasks that must be fully integrated into the planning process. The logistical
planning (i.e. access agreements, sequencing of tasks so that the data builds on the CSM,
contracting issues for back up equipment and services, etc.) is critical to the success of Triad
projects and is significantly different then standard phased projects.
We concur but think that the existing language broadly covers all planning issues. The
team may prepare a Triad "How - To" document in the future, and if so will consider
adding logistical planning as a separate discussion item.
5. p. 21, second paragraph, QC programs should also be designed to help the project team
understand data variability. Fix typo in third paragraph.
We concur - similar language was added to the end of the paragraph. Typo was fixed.
6. p. 22, the box at the bottom of this page, I suggest deleting the bullet "produce better data and
better project outcomes for less cost".
We concur; the bullet was removed.
7. p. 29, section 2.8.4, It is possible for the team to agree on a range of uses if the specific land
use is not known.
We concur - the statement "It is sometimes possible for the team to agree on a range of
land uses if the specific land use is not known," was added.
8. Table 2, This table needs to have an arrow or something that makes it clear that "decision
making" and the top box "systematic planning" are connected and must be considered iteratively.
Development of a communication strategy should be part of the dynamic work strategy.
We concur and added this sentence; As shown in Table 2, the final step "Decision Making"
is related to the first step "Systematic Planning," and the 2 must be considered iteratively.
9. p. 32, second paragraph, Fix typographical error.
We concur; the typo was fixed.
10. p. 32, This section should really include a comparison to the Corps Technical Project
Planning Process. I could write this section if you would like.
We concur. The suggested addition was included in the document.
11. p. 36, Table 3, The use of the word disadvantages is misleading since many of the issues
raised under this category are not what I would call "disadvantages".
C-6
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We do not concur. There are some negative aspects involved with implementing a Triad
project, especially for untrained personnel. The ITRC team has attempted to present all
the pros and cons in an unbiased manner so that a reader can consider all aspects.
Reviewer: Nevada PEP
I did not find any regulations or policies that would prevent NDEP from using the Triad
concepts. Both NAC 445A and NAC 459 state a specific test method or an equivalent test
method approved by the Division. This language allows NDEP the flexibility to use the Triad
approach.
Good to know.
In regards to the presentation of the document, I suggest that table 2 (Triad Process Overview)
which is a road map be included up front in the document behind the Executive Summary. As I
was reading the document, I kept saying they need an outline or road map so the reader can keep
the different section and subsections in context as to where it fits in the process. I finally ran into
it on Page 31.
We concur. Table 2 was moved toward the front of the document and renamed as Table 1.
This approach will be successful due to the emphasis placed on strategic, systematic planning,
and the flexibility in work strategies. Triad will definitely remove the vast confusion pertaining
to the DQO process that is many times improperly applied.
We concur.
Specific comments and suggestions:
Page 1 Introduction:
Rephrase? In the last 20 years, tremendous strides, both practical and scientific, have
been made in the environmental restoration industry.
The sentence was rephrased.
Second sentence: change this experience to these improvements
Either approach would work. The sentence was not changed.
Fourth sentence: change gathered to combine
We concur and changed the sentence.
C-7
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Rephrase? Six sentence: This ITRC document highlights the advantages of the Triad
approach with regards to achieving higher quality and more cost-effective environmental
remedies.
Either approach would work. The sentence was not changed.
Page 2: Bullet item four: standard techniques or mutually accepted techniques
We don't think this would help clarify the issue. Many of the Triad techniques are not
"standard," but the assumption is that all techniques were mutually agreed upon by the
involved parties.
Page 3: first paragraph: explain lower density fixed laboratory analysis.
We concur. The phrase "fewer samples" was added in parentheses after the term "lower-
density" to explain its meaning, and the phrase "more samples" was added similarly after
the term "higher-density."
Page 8: third paragraph third sentence typo: simple should be simply
We concur. The typo was fixed.
Page 21: fourth paragraph sixth sentence: typo (itused)
We concur. The typo was fixed.
Page 32: second paragraph first sentence: typo (anew)
We concur. The typo was fixed.
Reviewer: Illinois EPA
NOTE: IEPA personnel indicated that they use the Triad approach and find it very useful. They
had no comments on the document.
Good to know they already use the approach.
Reviewer; Vermont DEC
Page 10: The document references the VT DEC conceptual site model process. The references
should include the VT Site Investigation Guidance Document (available on the web:
http://www.anr.state.vt.us/dec/wastediv/sms/pubs/SI Guidance 96.pdf
We concur. The reference was included in section 11 "Additional Sources of Information."
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Page 17: Figure 5: Please re-work these colors, they make it very difficult (for me anyway) to
read the left side of the document on my color printout. This should also be checked to see what
it looks like in black and white.
"We concur. We changed these colors.
Page 17: 2nd paragraph: The third sentence in this paragraph states "High numbers of cheaper
analyses..." This term is also used elsewhere in the document. As "cheaper" holds a certain
connotation that it is poor quality, I would suggest that the word cheaper be replaces with "less
expensive" where appropriate.
We concur. The change was made throughout the document.
Page 20: Section 2.6: This section states that an implicit goal of triad is to complete the field
work in one mobilization. I would generally dispute this and say that even with the most efficient
triad process, at large sites, you will generally need more than one mobilization (if not for
anything else for monitoring environmental quality over time versus the single snapshot in time
that one field phase will provide), I would suggest replacing "one mobilization" with "minimize
mobilizations".
We concur. The change was made throughout the document.
Page 28: List showing analytical methods. There should be a category for field screening using
less analytical techniques. We have found (and defended successfully in court) that both the PID
and FID can play a very important role in site investigations and can supply important data.
Good point. The list isn't intended to be exhaustive and include all possible methods,
just provide a general sampling to the reader. No change was made.
Page 29: Section 2.8.4: I have some concerns about this section. While future land use can be
important in making remedial decisions, this must be coupled with relevant state regulations.
Some states require a site to be cleaned up to residential use no matter what the actual future use
of the site will be. This section should be revised to incorporate the concept of regulations in land
use decisions.
We concur. The following text was added to that section; "Notwithstanding the foregoing
discussion, some states have regulations that require sites to be remediated to residential
use levels regardless of the future use. Consideration must be given to state regulations
regarding future land use."
Page 30: Section 2.8.7 title: The title currently reads: "All Projects are not Amenable to the
Triad Approach". Should this read "Not all Projects are Amenable to the Triad Approach"?
We concur. The language was changed.
C-9
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Page 39: Section 5.1 and on: This section lists certain states and their comments. I think that the
states should be placed in alphabetical order. While this is not a big issue, it will just appear more
logical if, in this list and the following lists, there is a rational for the ordering of the state
comments.
We concur. The states were listed in alphabetical order.
Page 44: Section 5.2.1: The comment from Vermont should be revised to state the EPA quality
control requirements are only necessary to meet on federal sites (superfund, etc). On state lead
sites we have much more flexibility I this issue.
The comment was revised as requested.
Page 51: Section 5.5" The comment for VT should be revised to include "informally applies the
Region IX and III PRGs and where appropriate, site specific goals for soils and sediments"
The comment was revised as requested.
Thanks for giving VT the opportunity to comment on this document.
Reviewer; California DTSC
1. The issue of changing the term "Performance-Based Measurement System (PBMS)" to
"Performance - Based System (PBS)" has been discussed and finalized in the Method and Data
Comparability Board (MDCB) meeting recently held in Albany, NY.
Good information to know. However, at the time of this printing the term that has been
used to date is the term that should be used in this document.
2. Conflict with State Law, Policy or Guidance
CA - CA Health and Safety Code Section 25198 indicates "The analysis of any materials shall be
performed by a laboratory certified by the state Environmental Laboratory Accreditation
Program (CA ELAP) in the Department of Health Services (DHS). This statute appears to be a
regulatory barrier for implementing Triad approach. In reality, this statute is a perceived barrier,
because in many instances the test method is outside the scope of DHS accreditation and the
project manager can make the decision in selecting the appropriate test methods for the project.
To avoid this potential problem, changing state law or including the field test methods in the
ELAP scope would be an alternative for eliminating this perceived regulatory barrier.
The wording above was substituted for the original wording from California
• Recommendations for Overcoming Barriers
5.7.2 Concerns regarding acceptance of data generated from field analytical methods
C-io
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Due to budget and time constraints, gathering all the involved parties in making systematic
project planning can be a problem. A video conference call would be an alternative solution.
We concur that this is a worthwhile approach, but don't think this wording fits well in this
C ASVd-V f\W*
section.
Reviewer: Nebraska DEO
Technical & Regulatory Guidance for the Triad Approach; A new Paradigm for Environmental
Project Management
Review Comments (based on 11/10/03 version)
General Comment: Consider changing the title of the document to include mention of the fact
that the Tech & Reg Guidance is on Understanding the Triad Approach.
We concur. The Title was changed to be more indicative of the document's content.
General Comment: The material presented in Sections 2.6, 2.7, 5.2 and other parts of
Sections 5.0, and portions of Section 6.0 was straight forward and very informative with
enough detail to grasp the Triad concept.
We concur.
Key Issue-Question/Concern from the Sampling, Characterization, and Monitoring (SCM) team:
Are there any regulations or policies in your state that would prevent you from using the
concepts discussed in the document? Response: Our CERCLA/Superfund program and some
voluntary clean-up sub-programs are Federally funded and the sampling protocol for those
programs is in accordance with a generic QAPP that is based on Region 7 EPA policy and
practice. We don't have our own CERCLA/Superfund laws and we use EPA guidance documents
for sampling and analysis and related QA/QC requirements. Thus, we would need regional
Region 7 EPA to make changes in their procedures or accept an alternate procedure, before we
could implement such changes for site characterization and investigative work for these
Federally funded projects.
Good to know. However, since the Triad development has been led and sponsored by the
EPA, it is likely that the EPA Regions are willing to be flexible in this regard.
SCM Team Question: Does our approach in describing and presenting the Triad approach help
you understand it? Response: Yes, however, the document can be improved by eliminating
repetitive discussions about each of the three legs of the Triad and their associated pros and cons.
Also suggest limiting the number of comments from states, used as support information in
Section 5, to about 3 or 4 comments per issue (choose the most representative ones), instead of
listing 7 to 9 comments per item.
C-ll
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The document has been rewritten to eliminate some of the repetitive discussions. The states
that provided comments in Section 5 are states that had a representative on the SCM team,
SCM Team Question: Would you be willing to suggest its (the Triad approach) use on particular
projects in your state? Response: I believe that the Triad approach has merit on medium to large
site assessment, characterization, and remedial investigation/remedial action projects. I believe
we have been utilizing many of the key aspects of the Triad's three components. We encourage
the use of on-site labs and direct push technology for sampling and other exploratory/pilot
studies (hence, real-time measurement aspect), with confirmation spilt samples as appropriate for
federally funded projects. Work plans are designed to accommodate selection of samples (type,
number and location) during later rounds of a mobilization, based on the results/feed-back from
the field lab results of earlier rounds of samples collected during the same event (hence, the
dynamic work strategies aspect). Additionally, we determine how extensive the planning
requirements are for each project based on the level complexity. We apply experience gained in
previous similar planning situations, assemble team members with varying backgrounds/multi-
disciplines when deemed necessary, and coordinate with other agencies early on, to the extent
that I believe we do apply elements of the "systematic project planning" process at varying
degrees. However, I do think that we can benefit from the following:
Access training on the elements of the Triad approach for personnel
at various levels of involvement with site assessment/remediation.
Make changes in our work plans and QA/QC procedure documents (perhaps as part of our
internal program development efforts and also in
response to regional EPA shifts in requirements) to include various
elements of the Triad approach, like using the Conceptual Site Model
(and all the dynamics that surround its development) to help guide project decisions.
Seeking greater use (meaning regulatory
acceptance/certification/implementation) of real-time
measurement/field methods when deemed appropriate.
Good to know. The SCM team will develop internet training for the Triad early in 2004,
and this will help with the training needs mentioned above.
Section 1.0, suggest combining the last two sentences of text into a single improved sentence
reading: "Because there is often resistance to change from established procedures, it is important
to involve the stakeholder community from the beginning of any project utilizing the Triad
approach."
We concur. The change was made.
Section 1.1, fourth sentence of the first paragraph: The sentence reads "These reasons ranged
from the need to build a basis of knowledge in the field ..." Suggest replacing the word "basis"
with the word "base"
We concur. The change was made.
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Section 2.1, last sentence of the third paragraph of text after Figure 1: The sentence reads "It is
critical to use the CSM to avoid sampling errors and to interpret results from lower density fixed
laboratory analysis." This sentence is contusing and sounds like the low density terminology is
part of the fixed laboratory analysis; please clarify.
We concur. The term "low-density" was clarified.
Section 2,3, first sentence of second paragraph: Spell out/introduce the acronym RCRA since
this is the first time it appears in the document. There axe other acronyms that need to be spelled
out when first introduced, including DNAPL in Section 2.4.3, GIS in Section 2.5, DL in Figure 6
(Section 2.7), TCLP and CLP in Section 5.2.4, PRG in Section 5.5, and NJ.A.C. in Section 6.1
(please note that N.J.A.C. is spelled out later in Sect. 6.3).
We concur. The changes were made.
Section 4.0, Table 3: There is awkward wording used for some of the advantages &
disadvantages with using Triad listed in the table, please consider rewording. Also, to avoid
confusion, the table listings should be the identical wording used in the sub-titles for Sections
4.1.1 through 4.2.4.
We concur. The listings and/or table contents were changed to be similar.
Beginning within Table 3 and elsewhere in the document, there are terms like up-front, lifecycle,
and clean-ups that are sometimes hyphenated and not at other times; recommend being
consistent and hyphenate.
We concur. The terms were made uniform throughout.
Section 4.2.3, second sentence of text: The sentence reads "This training should include both
general overviews to more specific technical training." Perhaps the word "to" should be changed
to "and."
We concur. The change was made.
Section 5.1.2, under specific states comments, the last sentence of the California entry: The
sentence reads "... the ethical and legal responsibility to carry out the field activities in according
to the QAPP." Suggest changing "in according to" to "in accordance with"
The CA entry was modified such that this is no longer an issue.
Section 7.0, last sentence of the second paragraph: The sentence reads "Furthermore, tribes may
have treaties or other pacts with the federal government that grant them fishing, hunting, or
access rights in places that are not necessarily near their present-day reservations." This sentence
may need some clarification or closure by adding another sentence after it because I can not
make the complete connection on just how it supports the previous information in that paragraph.
C-13
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We concur. An additional sentence was added to clarify the meaning.
Section 7.0, first sentence in the fifth paragraph: The sentence reads "The dynamic work strategy
phase of the Triad approach is more directed at field activities." Suggest deleting the word
"more."
We concur. The change was made.
Section 7.0, last sentence of the sixth paragraph: The sentence reads "Those decisions guide the
design of sampling regimens and the selection of analytical tools and methods ..." Correct the
spelling of the word regiments.
Either spelling may be used based on the definition of the words. No change was made.
C-14
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APPENDIX D
ITRC Contacts, Fact Sheet, and Product List
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ITRC Sampling, Characterization and Monitoring Team Contact List
Brian Allen
Environmental Specialist
Missouri Department of Natural Resources
P.O. Box 176
Jefferson City, MO 65102
P:(573)526-3380
F: (573) 526-3350
nralleb@,mail.dnr.state.mo.us
Bradley Call P.E.
Senior Environmental Engineer
U.S. Army Corps of Engineers
1325 J Street (Attn: CESPK-ED-EE)
Sacramento, CA 95814
P: (916) 557-6649
F: (916) 557-5307
BradIev.A.Call@usace.armv.mil
Rick Carlson
Bus: (775) 831-9468
E-mail: rick@groundtruthenvironment.com
Hugo Martinez Cazon
Environmental Engineer
Vermont Department of Environmental
Conservation
103 South Main St., West Building
Waterbury, VT
P:(802) 241-3892
F: (802) 241-3896
hugom@dec.anr.state.vt.us
Ruth Chang, Ph.D.
Senior Hazardous Substances Scientist
California Department of Toxic Substances
Control, Hazardous Materials Laboratory
2151 Berkeley Way
Berkeley, CA 94704
P: (510) 540-2651
F: (510) 540-2305
rchang@dtsc. ca. go v
Ahad Chowdhury, Ph.D., P.G.
Registered Geologist
Kentucky Department for Environmental
Protection
HReillyRoad
Frankfort, KY 40601
P: (502) 564-6716 ext. 208
F: (502) 564-2705
ahad.chowdhury@mail.state.ky.us
Chris Clayton
Physical Scientist
U.S. Department of Energy
LM-40/Forrestal Building
1000 Independence Ave., SW
Washington, DC 20585
P: (202) 586-9034
F: (202) 586-1241
christopher.clavton@em.doe.gov
Deana Crumbling
Environmental Scientist
U.S. Environmental Protection Agency
MailCode5102G
1200 Pennsylvania Ave., NW
Washington, DC 20460
P: (703) 603-0643
F: (703) 603-9135
crumbling.deana@epa.gov
William Davis
Tri-Corder Environmental, Inc.
1800 Old Meadow Road, Suite 102
McLean, VA 22102
P: (703)201-6064
F: (703) 448-1010
mmbdavis@bellsouth.net
DeFina, John
New Jersey Department of Environmental
Protection
9 Ewing Street
Trenton, NJ 08625
D-l
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Kimberlee Foster
Environmental Specialist
Missouri Department of Natural Resources
4750 Troost Avenue
Kansas City, MO 64118
P: (816) 759-7313
F: (816) 759-7317
nrfostk@dnr.state.mo.us
Steven B. Gelb
President/Principal Hydrogeologist
S2C2 Inc.
5 Johnson Drive, Suite 12
Raritan, NJ 08869
P: (908) 253-3200 ext. 11
F:(908)253-9797
sgelb@s2c2inc.com
George J. Hall, P.E.
_ITRC Program Advisor
Hall Consulting, P.L.L.C.
4217 W. 91 St.
Tulsa, OK 74132-3739
P: (918) 446-7288
F: (918) 446-9232
TechnologyConsultant@prodigv.net
Richard P. LoCastro, P.G.
Project Manager
Langan Engineering and Environmental
Services, Inc.
500 Hyde Park
Doylestown, PN, 18901
P: (215) 348-7110
F:(215)348-7125
rlocastro@langan.com
Keisha D. Long
Environmental Engineer Associate
South Carolina Department of Health and
Environmental Control
2600 Bull Street
Columbia, SC 29201
P: (803) 896-4073
F: (803) 896-4292
longkd@dhec.sc.gov
Mack, Jim
P: (973)596-5887
mack@adni.niit.edu
Denise MacMillan
Environmental Laboratory, Engineering
Research and Development Center
420 S. 18th Street
Omaha, NE 68102
P: (402) 444-4304
F:(402)341-5448
Denise.K.Macmillan@nwo02.usace.armv.mil
Bill Major
Naval Facilities Engineering Service Center
110023rdAve.
Port Hueneme, CA 93043-4370
P:(805)982-1808
F: (805) 982-4304
maiorwr@nfesc.navy.mil
Stuart Nagourney
Research Scientist
New Jersey Department of Environmental
Protection
9 Ewing Street
Trenton, NJ 08625
P: (609) 292-4945
F: (609) 777-1774
stu.nagourney@dep.state.nj.us
Mary Jo Ondrechen
Professor
Northeastern University
Department of Chemistry
360 Huntington Avenue
Boston, MA 02115
P: (617)373-2856
F: (617)373-8795
mjo@neu.edu
Katherine Owens
Community Stakeholder
1278 Riviera Drive
Idaho Falls, ID 83404
P: (208)522-0513
F:(208) 522-3151
paragon@ida.net
D-2
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John G. Pohl
Restoration Program Manager
305th Environmental Flight
2403 Vandenberg Ave.
McGuire Air Force Base, NJ 08642
P: (609) 754-3495
F: (609) 754-2096
Jorm.pohl@mcguire.af.mil
Roelant, David
Florida International University
10555 W. Flagler Street, Suite 2100
Miami, FL 33174
Bus: (305) 348-6625
Bus Fax: (305) 348-1852
roelant@heet.fiu.edu
Qazi Salahuddin Ph.D.
Environmental Scientist
Delaware Department of Natural Resources
and Environmental Control
391 Lukens Drive
New Castle, DE 19720-2774
P: (302) 395-2640
F: (302) 395-2641
qazi.salahuddin@state.de.us
Peter Shebell
Environmental Measurements Laboratory
201 Varick St. 5th Floor
New York, NY 10014-4811
P: (212) 620-3568
F: (212) 620-3600
pshebell@eml.doe.gov
G.A. (Jim) Shirazi, Ph.D., P.G.,
PSScHydrologist/Soil Scientist
Oklahoma Department of Agriculture
Oklahoma City, OK 73105
P: (405)522-6144
F: (405) 522-0909
gashirazi@aol.com
Shawn Wenzel
Hydrogeologist
Wisconsin Department of Commerce, Bureau
ofPECFA
201 W. Washington Ave.
Madison, WI 53708-8044
P: (608) 261-5401
F: (608) 267-1381
swenzel@commerce.state.wi.us
D-3
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The Interstate Technology &
Regulatory Council [ITRC) is a
state-led coalition of regulators,
industry experts, academia, citi-
zen stakeholders, and federal
partners working together to
increase regulatory acceptance
of state-of-the-art environmental
technologies and approaches.
With its diverse mix of environ-
mental experts and stakeholders
from both the public and private
sectors and official participation
of more than 40 states, ITRC
builds consensus to eliminate
barriers to the use of new tech-
nologies so that states can
reduce compliance costs and
maximize resources. Our net-
work of more than 11,000 peo-
p e from all aspects of the envi-
ronmenta community is a unique
catalyst for dialogue between
regulators and the regulated
community to build and share
technical knowledge about the
selection, approval, and appli-
cation of emerging technologies.
Together, we're building the
states' ability to expedite quality
environmenta decision making
while protecting human health
and the environment.
Regulate
the futu
...... ........... 0
cceptance
We create...
Guidance documents
ITRC's guidance documents include technology
overviews, case studies, and technical/
regulatory guidelines. These guidelines—
often incorporating decision trees—suggest
uniform data requirements for technology
demonstrations or approvals. State concur-
rence with ITRC guidance makes the permit-
ting process more uniform and efficient across
states, helping technology consultants and
vendors avoid the time and expense of meet-
ing different requirements in each state where
an innovative technology is proposed for use.
'Regulation is necessarily conservative
regarding deployment of new tech-
nologies, yet new technologies often
are key to achieving better reiu
sooner and at ess cost III
squarely at this dilemma and, drew
from the combined fethnica skills
experience of participating
Training courses
ITRC develops and delivers free, live, interac-
tive, Internet-based training on emerging envi-
ronmental technologies and approaches. We
also partner with industry and other organiza-
tions to develop inexpensive cassroom courses
offered across the country. Our cost-effective
training has successfully reached more than
15,000 state, federal, industry, and other
stakeholders. When asked about the impact of
ITRC documents and training, 90% of respon-
dents indicate that the knowledge they've
gained will help them save time or money—
usually both—and sometimes the savings
amount to millions.
Consensus in the
environmental community
Working in teams to create documents and
training, ITRC participants leverage each
other's expertise. The contentiousness that
often characterizes relations between regula-
tors and the regulated community dissipates
as teams build understanding of the conditions
under which new technologies should be
applied, consensus about how they should be
regulated, and confidence in their merits.
Sharing problems, information, and lessons
learned spreads news of successful solutions
and increases deployments of the most appro-
priate technologies and approaches.
-------
ITRC
is bringing about a culture change in environmental deci-
sion making, replacing long-standing adversarial relationships
with collaboration, consensus, and concurrence. State regulators are
using ITRC guidance documents, training, and peer exchange to find
creative ways to reduce regulatory barriers to new environmental
technologies, cut approval time, and enhance their ability to make
quality decisions. As a result, regulated industries and contractors are
benefiting from reduced remediation costs and accelerated ceanup
schedules. ITRC's ultimate beneficiary is the public—through a
safer, healthier environment; redeveloped brownfields; ana a better
return on tax dollars.
finding better solutions
Lackland Air Force Base used the expertise, documents, and train-
ing of ITRC's Small Arms Firing Range Team to keep 3,500 truck-
loads of untreated soi off the highways and avoid the associated
transportation and disposa costs. At base invitation, team member
Gary Beyer, RCRA Corrective Action specialist for the Texas
Commission on Environmental Quality, shared alternatives for dis-
posal of lead-contaminated soils examined during the development
of ITRC guidance. The soi was chemically stabilized and used to
shore up a failing adjacent landfill, an alternative that saved well
over $10 million. Beyer suggests that everyone involved with the
ceanup of hazardous waste sites "consider participating in the pro-
grams, attend Internet training courses, and use guidance docu-
ments developed by ITRC to examine using cutting-edge technolo-
gies and regulatory solutions developed and promoted by ITRC to
save time and money and promote the decreased risk from environ-
mental hazards."
Slashing remediation costs
ITRC guidance on enhanced in situ biodenitrification was used
extensively in developing the conceptual remedy for a New Jersey
industrial site and in preparing the pilot and treatability study plans
submitted to state regulators. "Use of the ITRC guidance saved our
client perhaps six months of time and about $ 10,000 in consulting
fees...on top of the remediation savings of between $250,000
and $1.5 million associated with the innovative alternative,"
according to the site's environmental consultant.
ITRC guidance documents were also key to implementing a biore-
mediation remedy instead of a large pump-and-treat system at a
California chemical manufacturing facility. The facility estimates
using ITRC guidance "saved at least a year of consulting time,
modeling costs, and other documentation that would have been
ni3triQC
We're mak ng
a difference
ITRC has documented hundreds of helpful applications of ITRC
documents and training beyond the examples presented here to
illustrate the range of benefits and beneficiaries. Credit is
shared, of course, with the developers of innovative technologies
and approaches and the project managers who blaze trails by
deploying them. More examples and details are available at
www. itrcweb.org.
needed to devel-
op an experimen-
ta design, con-
vince the agency,
and implement a
plan that would
have gotten us to
the same point.
ITRC protocos and
principles saved
our company at
least half a million
dollars." Further
ITRC guidance helped
with Sne Installation of
permeable reactive
barriers in Colorado
and New jersey, result-
ing in cosf savings
measured in millions.
savings of at least $14 million in capita costs and $3 million in
annual costs resulted because the facility was able to demonstrate,
with the help of ITRC documents, that in situ bioremediation could
work as the primary remedy.
Cutting approval time
tnvi
ITRC's guidance and training for monitored natural attenuation
[MNA) of chlorinated solvents helped lead the Louisiana
Department of Environmental Qualify to approve MNA at a
Monsanto plant. Several potential remedies were examined for
addressing residual contamination near the sol-groundwater inter-
face. ITRC information and training on implementing monitoring for
natural attenuation led to buyin from LDEQ. Although MNA does
require continued monitoring, overall savings of thousands of dol-
lars will occur over time as a result of the adoption of this remedy.
"It takes...energy to investigate new remedies and to break down
barriers to implement alternative technologies to ceanup. ITRC infor-
mation and expertise gives confidence that soutions are good."
—Doug Bradford, LDEQ Environmental Technology Division
Results from passive diffusion bag (PDB) sampling are being used to
determine additional remove or remediation steps to be taken at
Nebraska's Ogalla a groundwater contamination site. "It took some
time to determine if the PDBs were applicable, but the information
provided by ITRC allowed the decision to use PDBs to move for-
ward," says EPA's Diane Easley. The use of PDBs is anticipated to
save $20,000-$50,000 for this project alone. The experience
gained at Ogallala a so encouraged EPA to allow the use of PDBs
at other Nebraska Superfund sites contaminated with vo atile
organic compounds.
-------
Sharing expertise
RC documents and training helped consultant Mark Waltharn
review a site remediation plan incorporating in situ chemical
oxi
dation.
was able to use knowledge gained from ISCO
training to confidently review the...plan. The ITRC training got
me up the learning curve very quickly and the interactive nature
of fhe seminar allowed me to get quick answers to my concerns
about the technology from experts." The proposed strategy will
save severa hundred thousand dollars as well as reduce the
remediation time from 5-10 years down to 1-2 years.
VIIRC documents and training have helped ^outh
Carolina regulators provide more effective and
efficient oversight at a mu tifude of sites. And in
sharing this common foundation of know edge
with c eonup contractors and site owners, South
Carolina has streamlined the det
i, former uepufy lomm wiener.
Colorado wildland firefighters recently faced not only intense fires
but a so potentia encounters with unexploded ordnance (UXO) on
a former defense site. ITRC UXO Team members from the state's
Department of Public Health and Environment helped staff from
the U.S. Army Corps of Engineers add local and fire manage-
ment protocol information to the team's UXO Basic Training. Forty
firefighters attended the first course just one week after the need
for the training was recognized. Subsequent iterations in other
states have delivered critica training that would have otherwise
been cost-prohibitive.
Bui ding stakeholder confidence
When community leaders (earned that uranium had been on
a brownfield site in the San Francisco Bay area, they called
on members of the ITRC Radionuclides Team to help deter-
mine fhe best protocol to ensure againsf subsurface contami-
nation. ITRC expertise and synergy yielded a monitoring solu-
tion that increased public confidence and led to a quicker res-
o ution of issues confronting site developers.
"I have worked on a number of very challenging DNAPL sites
around the world with some of the top researchers in the country,
many listed in your [DNAPL overview] document. One of my largest
problems on these sites is finding a reference for the public and my
clients which is not too technical yet still thorough enough to explain
the many complications encountered on a DNAPL site. I have finally
found the right document! Thanks very much for this effort!'-—Michael
/Moore, The Johnson Company, Montpelier, Vermont
The Diffusion Sampler Team's Resource CD contains nearly 70 arti-
cles and presentations on various diffusion sampers, as well as an
ITRC training video. One consultant says, "to effectively coordinate
the PDB work performed by others at various remedial locations,
needed a concise source of current information on diffusion sampling
procedures and results. The ITRC CD provided that information."
Another reports the CD "detailed enough to fully educate the user on
the key aspects associated with PDB sampling yet simple and inter-
esting enough to keep a captive audience. We plan to [use] the CD
to educate our field staff."
"Substantial dollar savings were realized by using the phytotechnolo-
gies decision tree to determine the feasibility of using phytoextraction.
Classroom training and guidance documents were critical to the
design and implementation of a remediation pan."—Regulator with
the Centra! California Coast Regional Water Qualify Control Board
"The ISCO training was very useful, timely, and presented in a pro-
fessional manner, I am recommending that engineers in our organiza-
tion take the ITRC Internet training."—Ron Santini, Duke Energy
"ITRC instructors are the creme de la creme, the most knowledgeable
peope covering the topics...well known, lending credibility and inter-
est. The casses are good, solid material with a deep content. We
get to hear regulators and subject matter experts discuss current,
ongoing issues outside our own backyard."—Teresa Feagin,
Westinghouse Savannah River electronic training coordinator
The training was extremely cost-effective and provided a tremendous
amount of useful information. No fluff!"—Industry participant
"The networking opportunity provided by ITRC classroom training is
great. We're able to successfully bring new technologies into fhe
field more quickly as a result of the training and interaction with other
folks versed in chemical oxidation technology. ITRC-sponsored train-
ing...has enhanced our ability to bring innovative, cost-effective solu-
tions to our clients."—Chuck Elmendorf, Panther Technologies, Inc.
-------
We're organized for success
learns focus on consensus priorifies
I The annua revision of ITRC's Five-Year Program Plan is an open
process tor soliciting and reviewing proposed areas on which to
, focus resources. With representatives from state agencies, industry
and citizen stakeholders and input from sponsoring federal agen-
cies IIRCs seven-member Board of Advisors makes final decisions
on the technical areas and issues that ITRC's teams pursue The 21
technica teams funded through this process in 2004 are address-
ing a diverse set of regulatory and technical issues related to many
ot the nations most pressing environmental problems [see fable)
re dioioque
"
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| » COUNCIL *
INTERSTATE *
in
•ECHNOLOCK
INTERSTATETECHNGLOGYS
c REGULATORY COUNCIL
Product
List
February 2004
ITRC documents and other products listed
below are available on the ITRC Web site at
http://www.itrcweb.org.
Document types are shown using the following codes:
G Technical/Regulatory Guidelines
O Technical or Regulatory Overviews
C Case Studies
X Other
Accelerated Site Characterization (ASC)
Doc.#
Title
Description
Type
Partners
ASC-1
ITRC/ASTM Partnership for Accelerated
Site Characterization-FY-97 Summary
Report (December 1997)
ITRC review and input on ASTM Guide for
Expedited Site Characterization of Hazardous
Waste and report on the options for future
collaboration between ITRC and ASTM.
American Society for
Testing and Materials
(ASTM)
ASC-2
ITRC/USEPA Consortium for Site
Characterization Technology
Partnership-FY-97 Summary Report
(January 1998)
State participation in the USEPA verification of PCS
field analytical and well-head monitoring and soil
and soil-gas sampling technologies.
O
USEPA
ASC-3
Multi-State Evaluation of an Expedited
Site Characterization Technology: Site
Characterization and Analysis
Penetrometer System-Laser-Induced
Fluorescence (SCAPS-LIF) (May 1996)
California certification, USEPA verification, and
multi-state acceptance of the SCAPS sensor for in
situ subsurface field screening method for
polynuclear aromatic hydrocarbons (PAHs).
U.S. Navy, Army,
and Air Force
Multi-State Evaluation of the Site
Characterization and Analysis
Penetrometer System-Volatile Organic
Compounds (SCAPS-VOC) Sensing
Technologies (December 1997)
Evaluation and approval of SCAPS-deployed
hydrosparge VOC sensor for real-time in situ
detection of VOCs below the water table.
U.S. Army Corps of
Engineers,
Waterways
Experimental Station
Alternative Landfill Technologies (ALT)
ALT-1
Technology Overview Using Case
Studies of Alternative Landfill
Technologies and Associated
Regulatory Topics (March 2003)
Presents examples of flexibility used in regulatory
frameworks for approving alternative landfill cover
designs, current research information about the use
of alternative covers, and examples of approved
designs and constructed covers.
O
ALT-2
Technical and Regulatory Guidance for
Design, Installation, and Monitoring of
Alternative Final Landfill Covers
(December 2003)
Brownfields (BRNFLD)
BRNFLD-1
Vapor Intrusion Issues at Brownfield
Sites (December 2003)
Focuses on the decisions and facilitating the
decision processes related to design, evaluation,
construction, and post-closure care associated with
alternative final landfill covers.
••••••
An overview of vapor intrusion, contaminant types
with vapor intrusion potential, brownfield sites'
potential to have indoor air exposure from vapor
intrusion, and steps that can be taken to limit
exposures.
O
Dense Non-Aqueous Phase Liquids (DNAPLs)
DNAPLs-1
Dense Non-Aqueous Phase Liquids
(DNAPLs): Review of Emerging
Characterization and Remediation
Technologies (June 2000)
Reviews three general types of emerging DNAPL
characterization technologies—including
geophysical, cone penetrometer, and in situ
tracers— and two categories of emerging DNAPL
remediation technologies—thermal enhanced
extraction and in situ chemical oxidation.
O
DNAPLs-2
DNAPL Source Reduction: Facing the
Challenge (April 2002)
Summarizes current regulatory attitudes regarding
DNAPL source zone remediation and outlines the
pros and cons of partial source removal.
DNAPLs-3
Technical and Regulatory Guidance for
Surfactant/Cosolvent Flushing of
DNAPL Source Zones (April 2003)
Summarizes information needed by regulators and
others in selecting and evaluating design and
implementation work plans for surfactant and
cosolvejit flushing of DNAPLs.
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Page 2
ITRC Product List
Dense Non-Aqueous Phase Liquids (DNAPLs) Continued
Doc. #
DNAPLs-4
Title
An Introduction to Characterizing Sites
Contaminated with DNAPLs
(September 2003)
Description
Discusses scientific approaches and strategies used
to characterize sites that are known, or suspected,
to be contaminated with dense, nonaqueous-phase
liquids.
Type
O
Partners
Diffusion Sampler Protocol (DSP)
DSP-1
DSP-2
DSP-3
User's Guide for Polyethylene-Based
Passive Diffusion Bag Samplers to
Obtain Volatile Organic Compound
Concentrations in Wells (March 2001)
ITRC Diffusion Sampler Resource CD
(November 2002)
Technical and Regulatory Guidance for
Using Polyethylene Diffusion Bag
Samplers to Monitor Volatile Organic
Compounds in Groundwater (February
2004)
A jointly developed protocol for determining when,
where, and how to use diffusion samplers for
groundwater sampling.
Contains nearly 70 articles and presentations on
various diffusion samplers, as well as a training
video and an AFCEE/Parsons field sampling video.
Guidance for regulators, technology users, and
stakeholders to facilitate the use of polyethylene
diffusion bag sampling, particularly for long-term
monitoring, including applicability and regulatory
issues, a cost model, and case histories.
G
X
G
U.S. Geological
Survey, Navy,
Air Force, USEPA
Enhanced In Situ Biodenitrification (EISBD)
EISBD-1
Emerging Technologies for Enhanced In
Situ Biodenitrification (EISBD) of Nitrate-
Contaminated Ground Water (June
2000)
Description of nitrate in the environment, sources of
nitrate, environmental and health effects of nitrate,
current nitrate remediation practices, and the
emerging technology of EISBD.
O
In Situ Bioremediation (ISB)
ISB-1
ISB-2
ISB-3
ISB-4
ISB-5
ISB-6
ISB-7
ISB-8
Case Studies of Regulatory Acceptance
of ISB Technologies (February 1996)
ISB Protocol Binder & Resource
Document for Hydrocarbons (June
1996) (re-released September 1998)
Natural Attenuation of Chlorinated
Solvents in Groundwater: Principles and
Practices (reprinted September 1999)
ITRC/ISB Closure Criteria
Focus Group Report
(March 1998)
Cosf & Performance Reporting for In
Situ Bioremediation Technologies
(December 1997)
Technical and Regulatory
Requirements for Enhanced In Situ
Bioremediation of Chlorinated Solvents
in Groundwater (December 1998)
Five-Course Evaluation Summary for
the ITRC/RTDF Training Course:
Natural Attenuation of Chlorinated
Solvents in Groundwater
(September 1999)
A Systematic Approach to In Situ
Bioremediation in Groundwater
(August 2002)
Case studies of the regulatory barriers and
implementation of in situ bioremediation in six
states.
General protocol and outline for ISB and literature
review for natural attenuation and bioventing of
petroleum hydrocarbons.
Description of practices to be used to recognize and
evaluate the presence of natural attenuation of
chlorinated solvent contamination.
Evaluation of state practices for establishing and
implementing closure criteria for bioventing, vapor
extraction, and natural attenuation of petroleum
hydrocarbons and chlorinated solvents.
Template for obtaining and reporting cost and
performance information about the use of in situ
bioremediation.
Presents and discusses regulatory processes
appropriate to a variety of active bioremediation
techniques for chlorinated solvents in groundwater.
Presents a summary of results of surveys returned
by people who took the natural attenuation course.
Presents flow paths for defining parameters and
criteria leading to decision points for deployment of
ISB. Includes decision trees for evaluating in situ
bioremediation for treating nitrates, carbon
tetrachloride, and perchlorate in groundwater.
C
G
G
O
G
G
X
G
Colorado Center for
Environmental
Management
(CCEM)
Industrial members
of the Remediation
Technology
Development Forum
(RTDF): Ciba
Specialty, Dow,
DuPont, GE,
GeoSyntec
Consultants, ICI,
Novartis, Zeneca
RTDF industrial
members
RTDF industrial
members
RTDF industrial
members, DOD
RTDF industrial
members
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ITRC Product List
Page3
In Situ Chemical Oxidation (ISCO)
Doc.#
Title
Description
Type
Partners
ISCO-1
Technical and Regulatory Guidance for
In Situ Chemical Oxidation of
Contaminated Soil and Groundwater
(June 2001)
Metals in Soils (MIS)
MIS-1
Technical and Regulatory Guidelines for
Soil Washing (December 1997)
Discusses the capabilities, limitations, costs,
regulatory concerns, and data requirements for
using ISCO to remove or destroy BTEX,
chlorinated volatile organics, polycyclic aromatic
hydrocarbon compounds, and chlorinated semi-
volatile organic compounds.
Technical requirements for using soil washing
technologies.
DOE (Office of
Environmental
Restoration and the
Mixed Waste Focus
Area)
MIS-2
Fixed Facilities for Soil Washing: A
Regulatory Analysis (December 1997)
A case study of fixed facilities for soil washing in the
United States and in other countries for identifying
succ_essfu|_rnodels_of deployment.
RTDF I INERT
Technology Team
MIS-3
MIS-4
MIS-5
Emerging Technologies for the
Remediation of Metals in Soils:
In Situ Stabilization/lnplace Inactivation
(December 1997)
Electrokinetics (December 1997)
Phytoremediation ^December 1997)
Three separate status reports on technologies for
the treatment of metals in soils and the potential
regulatory issues associated with their use.
O
RTDF, USEPA
Updates the five previous documents.
MIS-6 Metals in Soils 1998 Technology Status
Report: Soil Washing and the Emerging
Technologies of Phytoremediation,
Electrokinetics, and In Situ
Stabilization/In Place Inactivation
(December 1998)
Permeable Reactive Barriers (PRB, formerly PBW)
O
PBW-1
Regulatory Guidance for Permeable
Reactive Barriers Designed to
Remediate Chlorinated Solvents (2nd
Edition, December 1999)
Review of regulatory issues associated with
permeable reactive barriers.
RTDF
PBW-2
Design Guidance for Application of
Permeable Reactive Barriers for
Groundwater Remediation (March
2000)
U.S. Air Force document revised with state input to
provide technical information for PRB installation.
U.S. Air Force,
Environics
Directorate,
Armstrong Lab,
Battelle
PRB-3 Regulatory Guidance for Permeable
Reactive Barriers Designed to
Remediate Inorganic and Radionuclide
Contamination (September 1999)
Phytotechnologies (PHYTO)
PHYTO-1
Phytoremediation Decision Tree
(December 1999)
Provides regulatory guidelines for the installation of
permeable reactive barriers for the remediation of
inorganics and radionuclides.
A tool for determining the applicability of
phytoremediation at a gjyen site.
RTDF
USEPA
PHYTO-2
Phytotechnology Technical and
Regulatory Guidance Document
(April 2001)
Plasma Technologies (PT)
A Regulatory Overview of Plasma
Technologies (June 1996)
Identifies key regulatory and technical issues
relevant to the implementation of phytoremediation.
General description of plasma technology and
regulatory pathways for permitting.
G
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Page 4
ITRC Product List
Policy (POL)
Doc.#
Title
Description
Type
Partners
POL-1
An Analysis of Performance-Based
Systems for Encouraging Innovative
Environmental Technologies
(December 1997)
Case studies of performance-based environmental
regulatory and contracting practices and an analysis
of activities that could encourage development and
deployment of innovative technologies.
U.S. Army
Environmental Policy
Institute, DOD (ES),
Idaho National
Engineering and
Environmental
Laboratory (INEEL)
POL-2
Case Studies of Selected States'
Voluntary Cleanup/Brownfields
Programs (September 1997)
In-depth case studies of selected states' voluntary
cleanup/brownfields programs and
recommendations for possible enhancements.
Colorado Center for
Environmental
Management,
Association of State
and Territorial Solid
Waste Management
Officials
Radionuclides (RAD)
RAD-1
Radiation Reference Guide: Relevant
Organizations and Regulatory Terms
(December 1999)
Resource of organizations, activities, and technical
terminology related to radioactive contamination.
X
RAD-2
Determining Cleanup Goals at
Radioactively Contaminated Sites:
Case Studies (April 2002)
Summarizes the various regulatory standards and
requirements dictating the cleanup of radioactively
contaminated sites, processes for developing
cleanup levels and, case studies from 12 sites.
Sampling, Characterization and Monitoring (SCM)
SCM-1 Technical and Regulatory Guidance for
the Triad Approach: A New Paradigm
for Environmental Project Management
(December 2003)
Small Arms Firing Range (SMART)
SMART-1
Characterization and Remediation of
Soils at Closed Small Arms Firing
Ranoes (January 2003)
Introduces the Triad approach to conducting
environmental work, which increases effectiveness
and quality and reduces project costs.
Provide decision diagram and guidance for planning,
evaluating, and approving lead soil remediation
systems.
Technology Acceptance & www.dep.state.pa.us/dep/deputate/pollprev/techservices/tarp
Reciprocity Partnership (TARP)
Tier 1 Guidance (December 2000)
A protocol for defining the quality of information that
TARP states will accept for a field demonstration of
any technology
X
Massachusetts,
Pennsylvania, New
Jersey, New York,
California, Illinois
MOU-1
Strategy for Reciprocal State
Acceptance of Environmental
Technologies (December 2000)
The six-state strategy for reducing duplicative
demonstration and testing of technologies,
expediting multistate technology acceptance and
reducing costs for both vendors and state regulators
Massachusetts,
Pennsylvania, New
Jersey, New York,
California, Illinois
Protocol for Stormwater Best
Management Practice Demonstrations
(July 2003)
Thermal Desorption (TD)
TD-1
TD-2
TD-3
Technical Requirements for On-Site
Low Temperature Thermal
Desorption of
Non-Hazardous Soils Contaminated
with Petroleum/Coal Tar/Gas Plant
M/asfes (December 1997)
Solid Media Contaminated with
Hazardous Chlorinated Organics
(September 1997)
Solid Media and Low Level Mixed
Waste Contaminated with Mercury
and/or Hazardous Chlorinated Organics
(September 1998)
Provides a uniform method for demonstrating
stormwater technologies and developing test quality
assurance plans for certification or verification of
performance claims.
•^^^^•^^^^^••^^^^^^^•^^•^^•^^^^^•^^•^^H
These three reports serve as the protocol for
minimum technical requirements and can be used
together when treating a mix of contaminants.
Massachusetts,
Pennsylvania, New
Jersey, New York,
California, Illinois,
Virginia
••
DOE Mixed Waste
Focus Area
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ITRC Product List
Unexploded Ordnance (UXO)
Doc.#
UXO-1
UXO-2
Title
Breaking Barriers to the Use of
Innovative Technologies: State
Regulatory Rote in Unexploded
Ordnance Detection and
Characterization Technology Selection
(December 2000)
Technical/Regulatory Guideline for
Munitions Response Historical Records
Review (November 2003)
Description
Using case studies, this document recommends
including states in the selection of technologies for
detecting and characterizing unexploded ordnance.
A guide for regulators, stakeholders, and others
involved in oversight or review of munitions
response historical records review projects on
munitions response sites
Type
C
G
Partners
Verification (VT)
Nancy Uziemblo (WA) • (509) 736-3014
VT-1
Multi-State Evaluation of Elements
Important to the Verification of
Remediation Technologies, 2nd Edition
(December 1999)
Wetlands (WTLND)
WTLND-1
Technical and Regulatory Guidance for
Constructed Treatment Wetlands
(November 2003)
A matrix of data requirements for a technology
verification process to enhance states' confidence in
the technology verification and demonstration
results. Use of this matrix will allow verification
programs to modify their efforts and provide the data
most needed by states in their approval process.
This type of data collection will encourage states to
consider reciprocal state acceptance of verification
efforts. Highlights of the verification programs are
also provided.
••i
A guide to help regulators, consultants, and
stakeholders make informed decisions about the use
of constructed treatment wetland systems for
remediating a variety of waste streams, including
acid mine water, remedial wastewaters, and
agriculture waste streams.
11 North American
verification
programs, DOE,
USEPA
In addition to continuing to develop products in many of the technical areas listed above, ITRC is
developing products in the following technical areas:
• Arsenic in Groundwater
• Contaminated Sediments
• Ecological Enhancements
• Mitigation Wetlands
• MTBE and Other Fuel Oxygenates
• Natural Attenuation and Passive Bioremediation
• Perchlorate
• Remediation Process Optimization
• Risk Assessment Resources
• Vapor Intrusion (Indoor Air)
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SCM-1
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