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  A\  Improving Sampling, Analysis,  and Data
          Management for Site  Investigation and Cleanup
The United States Environmental Protection Agency (EPA) supports the adoption of streamlined
approaches to sampling, analysis, and data management activities conducted during site assessment,
characterization, and cleanup. This position reflects the growing trend toward using smarter, faster, and
better technologies and work strategies. EPA is coordinating with other Federal and State agencies to
educate regulators, practitioners, site owners, and others involved in site cleanup decisions about the
benefits of a streamlined approach. Ultimately, EPA expects to institutionalize these newer approaches
and anticipates that the principles will guide the way data are collected and analyzed for future site
cleanup decisions.
The Triad Approach
The trend toward modernization and stream-
lining relies on a three-pronged aproach called
theTriad approach. The cornerstone of the
Triad is the explicit identification and manage-
ment of decision uncertainties. A primary Triad
product is an accurate conceptual site model
(CSM) that delineates distinct contaminant
populations for which risk estimation and cost-
effective remedial decisions will differ. The main
elements of the Triad are

A Systematic project planning for all site
activities, ensuring that end goals for a project
are clearly identified. Once goals are defined,
systematic planning involves charting the most
resource-effective course to reach those de-
sired outcomes. A team of multi-disciplinary,
experienced technical staff works to translate
the project's goals into realistic technical objec-
tives. The CSM is the planning tool that orga-


              The Triad
Systematic
  Project
 Planning
 Dynamic
  Work
Strategies
  Real-time Measurement Technologies
nizes what is already known about the site and
helps the team identify what more must be
known to make project decisions. The system-
atic planning process ties project goals to the
necessary data collection and remediation
activities by identifying information gaps in the
CSM. The team then uses the CSM to direct
field work, updating the CSM as site work
progresses and data gaps are filled. The CSM is
the key integration tool for:
* Understanding contaminant release, fate, and
migration mechanisms to predict contaminant
distributions and spatial patterns;
* Predicting exposure and designing cost-
effective risk management strategies;
* Planning site activities;
* Modeling and data interpretation; and
* Communicating among the team, decision
    makers, stakeholders, and field personnel.

A  A dynamic work strategy, often in the form
of a regulator-approved decision tree, guides
project teams in making decisions in the field
about how subsequent site activities will
progress. Real-time decision making requires
sufficiently rapid ("real-time") turnaround of data.
Success of the "dynamic" approach hinges on
the presence of experienced staff empowered
to "call the shots" while work crews are still in
the field based on the decision logic developed
during the planning stage. Field staff maintain
close communication with project oversight
during implementation of the dynamic work plan
and to address any unanticipated issues.
               United States
               Environmental Protection
               Agency
              Office of Solid Waste and
              Emergency Response
              (5102G)
                           EPA-542-F-04-001a
                           April 2004
                           www.epa.gov/tio
                           www.cluin.org

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A Real-time measurements might be gener-
ated in the field or in a fixed laboratory. In addi-
tion to analytical techniques, the term includes
rapid sampling platforms (e.g., direct push
technologies), geophysical tools, and on-site
data management and display software that
makes real-time decision making possible. The
capabilities of advanced information technology
(IT)  tools permits rapid sharing of data among
interested parties no matter where they may be
physically or geographically located. During up-
front planning, the team identifies the types,
rigor, and quantities of data needed to answer
the questions raised by the CSM. Those deci-
sions then guide the design of sampling plans
that address data representativeness issues
stemming from environmental heterogeneity.
Analytical methods are carefully mixed-and-
matched to focus data collection on maturing
the CSM and providing data that are representa-
tive of the decisions to be made.

Figure 1  illustrates the iterative and  interlinked
nature of projects managed using the Triad.
The decision rules developed during systematic
planning are built into the work and sampling
plans. Occasionally, decision makers will
discover that the original project objectives
cannot be met due to technical or budgetary
constraints, and pragmatic refinement of the
decision rules may  be needed.

Supporting Developments
Faster, cheaper,  yet still protective, resolution of
contaminated sites  is achievable by  adopting
new technologies and the new strategies those
technologies support. If used correctly, innova-
tive rapid-turnaround field analytical  and soft-
ware tools coupled  with on-site decision making
can significantly condense a project's overall
budget and lifetime, while significantly increas-
ing the likelihood that the gathered data will
guide better, more transparent decisions. Site
professionals, policy makers, and the public
should support the flexibility needed  to adopt
cost-effective new tools and strategies  into
improved site cleanup practices in conjunction
with  clearly defined performance goals. Eco-
nomics, site redevelopment, and regulatory
evolution are driving trends toward moderniza-
tion and streamlining. Technology advancement
and 25+ years of site cleanup experience are
pointing toward a next-generation environmental
data quality model that includes explicit man-
agement of sampling uncertainties by grounding
them in the decision context. Specific develop-
ments that support modernization include:

if Field analytical chemistry has made signifi-
  cant advances in scientific rigor and credibil-
  ity. Computerization, photonics, miniaturiza-
  tion, immunochemistry, and a host of other
  advances in the chemical, biological, and
  physical science disciplines are contributing
  to technology improvements and innovations.
  When field methods are used, proactively
  managing any excessive analytical uncer-
  tainty requires educated staff and quality
  control that is solidly grounded in the project
  decisions.

* Successes with  various streamlining
  initiatves such as Expedited Site
  Characterization (ESC), Accelerated Site
  Characterization (ASC), Rapid or Adaptive
  Site Characterization (RSC), and Adaptive
  Sampling and Analysis Programs (ASAPs)
  demonstrate the validity and cost-effective-
  ness of principles that are captured within the
  Triad framework.

if Regulatory policies are focusing more on
  achieving tangible end-results. For example,
  EPA and other agencies support perfor-
  mance-based measurement systems
  (PBMS) as a preferred alternative to rigidly
  prescribing which analytical tools are used
  and how. PBMS  principles support the use of
  field analytical technologies to meet the
  specified project needs and decision goals.

* Evolving emphases in environmental pro-
  grams [such as Brownfields, State Voluntary
  Clean-Up Programs (VCPs), and Base
  Realignment and Closure (BRAC) at military
  facilities] focus site activities on how  the site
  will be redeveloped or reused. Flexible
  cleanup goals [such as risk-based corrective
  action (RBCA) levels] can be tailored to meet
  specific reuse objectives. When cleanup and
  end-use goals are articulated at the start,
  systematic planning can ensure a cost-
  effective work plan that achieves the  desired
  outcome. Added focus on redevelopment and
  the involvement of insurance, banking, real

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                                Figure  1
     Modernizing Site Characterization and Monitoring

                             Project Initiation
                               c Project Ob jet: live s
                               Assemble Team.
                          Identity Key Decision Makers,
                              Define Decisions to
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                                                     Detailed
                                             Analytical Strategy
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   estate and land use planners create market
  incentives for identifying and managing all
  uncertainties that could delay or derail a
  project.

* Better decision-making tools  (i.e., computer
  software and hardware) facilitate rapid data
  management,  statistical processing, and
  interpretation as data are being generated.
  These capabilities allow display and modeling
  of contaminant distributions and maturation of
  the CSM in real-time. The project team can
  rapidly incorporate data, modify site
  characterization activities, and refine cleanup
  decisions to target contamination and mini-
  mize repeated field mobilizations.

* Modern communication technologies mean
  that the field team is no longer isolated from
  regulators, technical experts, site owners,
  and trustees. Newly developed information
  can be shared instantly among distant par-
  ties, while regulator buy-in and technical
  support can be obtained from  remote loca-
  tions, allowing high level staff to spend less
  time being physically in the field.

* Increasing workloads and decreasing
   budgets have forced regulators and
   industry to consider innovative strategies
   that can increase public confidence and
   satisfaction by reducing uncertainties
   (about any threats the site may pose)
   while reducing the time and costs involved in
   cleaning up these sites.

Tools for Change
To accomplish change, the remediation industry
and regulators should move toward a more
innovation-friendly system that can produce
defensible site decisions at an affordable cost.
Such a system would:

/ Focus on decision-specific performance
  requirements,  rather than inflexible adher-
  ence to traditional policies or "boiler-plate"
  procedural checklists that do not add value or
  provide beneficial results. In particular, over-
  sight must evaluate data quality as a function
  of both sampling and analytical uncertainties
  as they contribute to development of an
  accurate CSM, not simply as a function of the
  analytical method used or the location (on-
  site vs. off-site) where the data is generated.

/ Employ transparent and logical reasoning
  to define project goals, manage uncertainties,
  state assumptions, plan activities, and derive
  conclusions so that decisions are  defensible.

/ Value technical proficiency in environmental
  practice through teams of "allied environ-
  mental professionals" that collectively
  possess the scientific, mathematical, and
  engineering disciplines required to compe-
  tently manage the complex issues of hazard-
  ous waste sites.

/ Facilitate application of innovative tech-
  nologies and strategies by logically evaluat-
  ing project-specific needs, site conditions,
  and prior technology performance, with
  residual areas of uncertainty being identified
  and addressed before use.

A handful of practitioners have been success-
fully using the Triad approach, although many
institutional and regulatory hurdles still exist.
EPA is  encouraging  project  managers and
regulators at-large to evaluate how Triad prin-
ciples can be adopted into routine practice.

EPA is collaborating with Federal and state
partners to accelerate policy development and
information dissemination in support of a shift to
newer,  streamlined approaches. An array of
educational, training, and guidance resources
already exist and additional ones are in develop-
ment. Access to these resources is provided
through the http://cluin.org/triad website and are
detailed in the companion fact sheet, Re-
sources for Strategic Site Investigation and
Monitoring, EPA-542-F-04-001 b.

Updating hazardous waste site practices to
accommodate new tools and strategies has
broad ramifications for both practice  and policy.
Revising institutional and regulatory barriers will
take time and effort. Nevertheless, the protec-
tive and cost-saving benefits offered by next-
generation strategies make  the effort worth-
while.

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