United States
               Environmental Protection
               Agency
Office of Solid Waste and
Emergency Response
(5102G)
EPA 542-R-01-013
October 2001
www.epa.gov
www.clu-in.org
V EPA   Current Perspectives in Site Remediation and Monitoring
                APPLYING THE CONCEPT OF EFFECTIVE DATA TO
                ENVIRONMENTAL ANALYSES FOR CONTAMINATED SITES


                D. M. Crumbling1
                Executive Summary

                Analytical chemistry methods can be classified as "definitive methods" or "screening methods."
                Environmental decision-makers and practitioners frequently make a simplifying assumption that
                definitive analytical methods generate "definitive data," while screening methods generate
                "screening data." The pervasiveness of this incorrect assumption inhibits the development and
                application  of more cost-effective strategies for environmental  sampling and analysis  at
                contaminated  sites.  Adopting the concept of "effective data" could promote the cost-saving
                advantages of modern measurement and monitoring options in the context of contaminated site
                cleanup, while ensuring the reliability of site cleanup decisions. This concept embodies the
                principle  that the information value  of data (i.e.,  data quality) depends heavily upon the
                interaction between sampling design, analytical  design, and the  intended use of the data.
                Considering site-specific conditions, sample support, quality control, and data documentation
                assure the scientific defensibility of  effective data. When the interplay of these factors is
                understood, screening methods can play important roles in generating data that are effective for
                making defensible project decisions, while simultaneously improving the cost-effectiveness and
                efficiency of site restoration activities.
                Introduction

                This issue paper provides detailed discussion
                to supplement the article, Managing Uncer-
                tainty in Environmental Decisions: Applying
                the Concept of Effective Data at Contamina-
                ted Sites Could Reduce  Costs and Improve
                Cleanups, that appeared in  the October 1,
                2001, issue of Environmental Science &
                Technology (1).

                This paper assumes that the regulatory action
                levels or threshold values used to establish
                acceptable/unacceptable levels of contamina-
                tion have been developed  in  a  defensible
                manner. Although evaluating the  validity of
                the action level is a very important component
          of scientifically defensible decisions about
          whether a site poses unacceptable risk, the
          topic itself is beyond the scope of this paper.

          Likewise, while the selection and implemen-
          tation of specific cleanup activities are impor-
          tant, the topic of remedial technologies is also
          beyond this discussion. This paper addresses
          issues that revolve around the generation and
          use  of contaminant data as produced  by
          analytical chemistry methods. Uses for this
          data  include determining the "nature and
          extent of site contamination," short- or long-
          term  monitoring of remedial effectiveness,
          and  demonstrating regulatory compliance.
          Contaminant data are used to decide whether
          remedial actions are required for a site, and if
                ' EPA, Technology Innovation Office

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so, to guide  the  selection and  design of remedial
activities. The reliability of contaminant data (as well as
other types of data) may be critical to the success and
cost-effectiveness   of  remediation   or  monitoring
activities.

Overview

It is important that regulators provide direction on how
compliance with an action level is to be demonstrated.
For example, is the action level intended to represent an
average concentration that should not be exceeded over
some exposure unit, or does it represent some  other
statistical benchmark? A clear mechanistic understan-
ding of what  an action level represents is needed in
order to design a scientifically  valid  sampling and
analysis  plan. Without this  understanding,  project
decision goals will remain vague, resulting in confusion
and wasted effort. An important task of project-specific
systematic planning is to establish how regulatory action
levels will be applied to a particular site  or  project.
Obviously, the regulatory agency must "participate" in
the up-front planning process for efficient design and
implementation of a project plan  to be  possible. This
"participation" may range from written guidance that
presents clear, unambiguous interpretation of the regula-
tory benchmark to regulatory staff representation on a
project-specific planning team. Modernization of site
characterization and cleanup activities requires that all
parties bring the industry and regulatory  experience
gained over the past 25-30 years to the table when
planning today's projects.

When gathering contaminant data, regulators, lawyers,
and project managers dealing with contaminated sites
have  often insisted upon using "approved" analytical
methods. There is a very common perception that
prescriptively  mandating what methods may be used
(and how they may be used) can assure defensibility and
data  quality.  In other  words,  it is  assumed that if
"approved" methods are used, the data can be trusted. If
the methods used  are not considered to be regulator-
approved, the data may be considered suspect solely on
those grounds and  for that reason be rejected the
regulator. A commonly expressed concern is that data
produced by not-approved methods will not be legally
defensible. This concern is unwarranted when courts
operate from the basic common-sense principle that if
data are scientifically defensible, they should be legally
defensible. Federal standards (and at least  some state
standards) do operate from this principle, and for those
courts, the admissibility of evidence does not require
adherence to methods approved by EPA or any other
standard-setting organizations (2). A more thorough
discussion of the regulatory and technology issues
surrounding the question of "EPA-approved" methods
within the context of the waste  programs is  found in
another paper (3).

This issue paper will argue that rigidity in the applica-
tion of analytical methods to environmental samples can
undermine the very data quality and defensibility that
regulators seek to secure. Furthermore, this paper will
argue that using more modern and innovative methods
for sampling and analysis holds the promise of greatly
improving the cost-effectiveness of scientifically defens-
ible environmental decision-making. But taking advan-
tage of these  modern new tools  will  require  that
regulatory-driven conceptualizations of "data quality" be
placed on a more scientifically defensible  footing. In
addition, realizing the benefits of analytical flexibility
requires  that  practitioners  take responsibility  for
instituting the multidisciplinary  teaming and training
needed to select and use analytical tools properly.

Transitioning to  a  more  modern site  restoration
paradigm  is  facilitated when judgments about "data
quality" are more closely linked to the project decisions
actually driving the  data collection efforts (i.e.,  the
data's  intended use),  rather than tied  solely to  the
analytical  procedures  used  (which is  the  current
paradigm). In other words, the data assessment question
should not be, "Was an approved  method used and
followed  exactly  as  written?"  Rather,  the  primary
questions should be, "Are the data effective  for making
the specified decisions, and are both the sampling and
analytical  documentation  accompanying  the   data
sufficient to  establish that  they are?" Answering this
question is the foundation of scientific defensibility. We
suggest that the terms "effective data" and "decision
quality data" could intuitively reinforce scientific defen-
sibility within environmental cleanup programs if the
terms become part of the environmental lexicon, paving
the way for more modern and more cost-effective work
strategies.  More  cost-effective  investigations  and
cleanups mean that more sites may be evaluated and
brought to resolution for the same resource investment.

Terminology—Methods vs. Data

First, a  distinction  between methods  and  data  is
required. Although analytical methods are indeed used
to generate data, the analytical method is one of the last
links in a very long  chain of events that forms  the
foundation of scientific  data. Nonetheless, decision-
makers at all levels of policy and practice assume that

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"definitive  data  of high quality"  is  automatically
produced when traditional laboratories  use definitive
analytical methods (4). It is further assumed  that any
decisions based on those data will be legally defensible
as long  as the laboratory  strictly  adhered to the
"approved" method and to whatever quality assurance/
quality control (QA/QC) is assumed specified for that
method (irrespective of the QC's relevance to the data's
intended use). On the other hand, on-site analytical
methods are usually categorized as  "field screening
methods" [despite the fact that some field methods are
based on definitive method technologies (5)].

"Screening analytical methods" are assumed to produce
screening quality data that are considered inferior and
not legally defensible. It is also assumed that adequate
QA is not possible when  screening methods are used,
and particularly when analysis is performed in the field.
Whatever utility these assumptions may have had in the
past, the evolution of analytical technologies and of our
experience in using them shows these generalizations to
be false. Data produced by screening methods can be of
known and documented quality; adequate  quality control
can be used in conjunction with data generated in the
field. But to do so, common traps that compromise data
quality and drive up costs must be  avoided. Current
engineering practice must be challenged to integrate
analytical  chemistry expertise  into  project planning
when data collection efforts are designed.  This challenge
is especially critical to the use of on-site measurement
technologies that are based on screening methodologies
where  potential  analytical  uncertainties  must  be
balanced according to the data's intended use. As will be
discussed in more detail later in this paper, there is no
"bright line" that distinguishes  screening analytical
methods from definitive analytical  methods. Rather
there are gradations where screening methods tend to
have more uncertainty in analyte identification and
quantification than methods that  are considered to be
definitive. Yet definitive methods are far from foolproof.
Even methods such as  ICP-AES  and ICP-MS are not
free from interferences that can compromise data quality
(6).

When data quality issues are treated as  if they were
solely  dependent  on  method   requirements  and
independent of data use, a myopic focus on managing
analytical error  can actually trigger major  decision
errors  (7).  Environmental  decisions  are  especially
susceptible to error in site cleanup situations because the
maj or source of decision uncertainty (as much as 90% or
more by some estimates) is due to sampling variability
as a  direct  consequence of the  heterogeneity of
environmental matrices (8-10). Figure 1 illustrates the
paradox that highly accurate and QA-documented (i.e.,
"high quality") data points may actually form a poor
quality data set that produces misleading conclusions
and erroneous project decisions.  Figure 1 depicts two
different sampling and analysis scenarios for a cartooned
site containing two hot spots (locations  with signifi-
cantly higher contamination concentrations than the
surrounding area). Analyzing samples using  a highly
                  Data  Quality vs.  Information Value
                    Fewer "higher quality"
                    data points leads to
                    lower information
                    value of the data set
                             .  \
      Many "lower quality"
      data points leads to
      higher information
      value of the data set

                           Goal: A defensible site decision that reflects the
                                        "true" site condition
                                              FIGURE 1.

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accurate method is very expensive, so the hard truth is
that budget constraints frequently limit the number of
samples used to determine the presence and degree of
contamination.

Even if the  data points themselves are "perfect," an
inaccurate assessment is likely when a few  samples
cannot accurately locate or represent site contamination
(i.e., the samples are not "representative" of the site in
the context of the intended decisions about the site). A
much more accurate picture of the site is gained when
many  samples  are  analyzed, even if the analytical
method itself is somewhat less accurate.

Thus, we must move beyond the pervasive assumption
that the use of definitive methods will automatically
produce  definitive  data. "Data" (as  measurements
produced  on samples  for the purpose of supporting
decisions) are  the  end product  of a  long  chain of
activities. Selecting representative samples is one of the
early activities that critically impacts the usefulness and
reliability of data for  decision-making purposes, but
there are many other steps that contribute to the overall
"quality" or validity of environmental measurements.
Errors and problems can occur  in the processes of
collecting a sample; preserving it; transporting it to the
laboratory; taking a subsample  for actual  analysis;
extracting analytes from the sample matrix; introducing
the analytes into an  instrument; coping with  any
chemical and physical interferences that may arise;
ensuring that analytical quality control criteria are met;
and finally documenting and reporting the results to the
data user. A problem in any single step can compromise
or invalidate the accuracy of a data point generated from
that sample, no matter how much attention is  given to
other steps. Therefore, project planning must carefully
consider each step in the data generation chain in light
of the project goals and the nature of the site conditions
(11-14). Yet, discussions about "methods" (especially
references to SW-846 methods) almost always focus
exclusively  on  instrumental  determinative methods,
completely ignoring the critical importance of methods
for sample collection, sample preparation, and extract
cleanup  (15).   If  quality   assurance  deliberations
concentrate only on strengthening only one or two links
in isolation from the rest of the data quality chain (for
example, ensuring stringent laboratory QA/QC practices
for the determinative method), the weaker links [for
example,  unevaluated  variability in  sampling  and
subsampling  (16)] can still severely compromise the
ability of data to support valid environmental decisions.
This is one of the reasons why, despite heroic efforts to
control variability in the delivery of laboratory services,
data quality problems continue to plague environmental
programs (17).

Terminology—Effective Data

Public stakeholders do not care whether Method A or B
was used to generate data at hazardous waste sites. They
do care  whether correct decisions are being made that
protect their well-being. The key to defensible environ-
mental decision-making is to openly acknowledge  all
underlying assumptions and to manage all sources of
uncertainty that can significantly impact the correctness
of a decision to the degree feasible. Often a "weight of
evidence" approach is needed because no single piece of
information can provide definitive evidence  given the
complexities  present   in   environmental  systems.
Although it makes regulators' and practitioners' jobs
much more difficult, the inescapable truth is that relying
on  one-size-fits-all  approaches to gathering environ-
mental data ultimately compromises the validity (or
"quality")  of  environmental  decisions. This is true
whenever a wide variety  of  sampling and  analytical
conditions and a broad range  of decisions are encoun-
tered  in site  restoration  programs. A  multitude  of
complex and interacting variables  cannot be accommo-
dated by preparing a simple  checklist of prescriptive
sampling or analytical methodologies, or by substituting
laboratory certification for systematic project planning
(7). Flexibility (both in the choice  of analytical method
and in the specific operations of a method) and the
professional expertise to apply it are vital if site data are
to be generated reliably and economically.

Terminology that explicitly or implicitly judges data
quality according to the definitive vs. screening nature
of the determinative method is misleading, because (as
argued above) the nature of the determinative  method is
inadequate to assess whether the  data themselves are
useful and reliable  for their  intended purpose.  Some
environmental practitioners report that they use the term
"definitive  data" to apply to any data that is  of known
quality and demonstrated useful and reliable for their
intended purpose,  even if generated  by a  screening
method. This  is a legitimate application of the term
"definitive data." But it must be recognized that use of
the  term in this manner runs counter to the way it has
been traditionally used in the environmental industry,
and such usage could create additional confusion in an
already   ambiguous and  conflicted  environmental
lexicon.

To  foster clarity,  this  paper suggests that different
terminology be introduced. This paper suggests the term

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"effective data" as a term that describes "data of known
quality that can be logically shown to be effective for
making defensible project decisions because  both
sampling  and  analytical  uncertainties  have  been
managed to the degree necessary to meet clearly defined
project goals." The term "decision quality data" carries
the same intuitive meaning,  and is  viewed  as an
equivalent term.

There are a number of implications of this definition that
should be noted:

1)  In contrast to evaluation protocols that evaluate
    "data  quality" solely  on adherence to analytical
    protocols, data judged to be  of decision quality
    (alternatively, data judged to be  effective  for
    decision-making) must explicitly include evaluations
    of sample representativeness as a fundamental data
    quality indicator (18,19). It is a matter of common
    sense  that if  the samples cannot be shown to be
    representative of the site conditions in the context of
    the decision to be made, evaluation of the measure-
    ment quality  for the analysis on those samples is
    meaningless.  If evidence for representativeness is
    not presented, the data cannot  be characterized as
    effective for project decision-making.  Demonstra-
    ting appropriate analytical quality is only part of the
    picture.

2)  Data  cannot  be  characterized as  effective  for
    decision-making (alternatively,  data  cannot be
    characterized as being of decision quality) unless
    the  decision(s) that the data  are to support has
    (have) been  clearly  articulated,  along  with an
    expression of the amount of uncertainty that can be
    tolerated in  the  decision.  Thus,  a  systematic
    planning process based on the scientific method,
    such as EPA's Data  Quality  Objectives (DQO)
    process, is vital (20). All pertinent project planning
    and reporting documents using the term "effective
    data" should contain clear statements that concisely
    describe:

     •  what the primary project decisions are;
     •  what level of  confidence  is  desired in those
        decisions;
     •  what sources  of uncertainty  could lead to
        making an incorrect decision;
     •  what strategies are used to  manage for each
        source  of  uncertainty  so that  making an
        incorrect  decision  is avoided;
     •  what assumptions are  used when knowledge
        gaps are  encountered that are not feasible or
       practical to fill with more definitive informa-
       tion; and
     •  how do these assumptions impact the decision
       outcome.

    A  summary sheet concisely  listing these items
    would have supporting discussion contained within
    the body of the planning or reporting document.

3)  What are the types of "decisions" for which the term
    "effective data" should be used? Introduction of the
    term "effective  data" seeks  to  address issues
    associated with the generation and use of analytical
    chemistry data for characterizing chemical contam-
    ination or demonstrating regulatory compliance with
    limits placed on the amount of contaminants present
    in environmental media. Therefore, the "decisions"
    to which the term "effective data" alludes are those
    that  address  questions about contamination: Is
    contamination present, and if it is, is it at a high
    enough concentration to exceed regulatory levels or
    to pose a threat to receptors? These might be called
    "primary project decisions" or some other term that
    denotes that these are decisions that must be made
    in  order  to resolve the  status  of a potentially
    contaminated site (or  portion  thereof). There are
    many other decisions that must be made during the
    course  of site activities, but unless they  directly
    involve decisions determining the presence/absence
    of contamination, the distinction of "effective data"
    probably  is not necessary. Overuse of the  term
    would be undesirable since it would undermine the
    meaning and impact of the term.

4)  Managing uncertainty in environmental decision-
    making  will  often involve  the  collection  and
    interpretation of environmental data, but this is not
    an absolute. Careful planning may indicate  that the
    cost of a reliable sampling and analysis program is
    as, or more expensive, than simply assuming a worst
    case scenario and acting accordingly to manage the
    assumed  risks. One   case  study  showed  that,
    although using immunassay methods to guide clean
    up of a small contaminated site saved the responsi-
    ble party at least 50% over projected costs,  relying
    solely on a traditional site characterization scenario
    to delineate contaminated hot spots would have cost
    as much as assuming the entire soil mass needed to
    be incinerated without attempting characterization
    (21).

5)  A data set that might not be effective for making a
    certain decision when considered alone may become

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    part of an effective data set when considered in
    conjunction with other relevant information, such as
    another data set that contains supporting or comple-
    mentary information. An example of this is when
    the  cost  of a definitive analytical  method may
    prohibit the sampling density needed to  manage
    sampling uncertainty, whereas existing screening
    analytical methods cannot supply all the analytical
    quality needed. Intelligent sampling and analysis
    design may  be  able to  select an  inexpensive
    screening method to manage sampling uncertainties,
    while  judicious confirmatory analysis of selected
    samples  by  the  definitive method  manages for
    residual  analytical uncertainties in  the data set
    produced by the screening method. In this way, the
    two data  sets collaborate to produce data effective
    for supporting the  final decision(s) (21).

6)  There is a key phrase in the definition of effective
    data that  must not be overlooked: data must be of
    "known quality." This means that analytical quality
    assurance and quality control (QA/QC) protocols
    must be selected, implemented, and interpreted so
    that the analytical sensitivity, bias, precision, and
    the effect of potential interferences can be  deter-
    mined and reported. To achieve  this at the project
    level,  a  demonstration  of method  applicability
    (wherein  site-specific samples are evaluated for
    matrix-specific impacts  on method performance)
    may be  required  to identify the sampling and
    analytical uncertainties requiring management, and
    permit the proper selection of the QA/QC para-
    meters and acceptance criteria to be  used during
    project implementation (22). Estimating the contri-
    bution to data variability due to matrix heterogeneity
    and subsampling may also be importantto establish-
    ing that data are of known quality (19).  No matter
    whether a method is considered to be a screening
    method or a definitive method, QA/QC procedures
    are  required  to  produce  data  of  known and
    documented quality from any analytical chemistry
    method.

Terminology—Screening Data

Data that cannot be shown to be of decision quality may
still provide  some useful information. As  such they
might be characterized as "screening data." Screening
quality  data  do not provide enough information  to
satisfactorily  answer the question being asked with the
desired degree of certainty. For example, consider data
resulting  from pesticide  analysis  by gas chroma-
tography/mass spectrometry (GC/MS—considered to be
a definitive determinative method) performed in the
presence of high levels of hydrocarbon interferences
without benefit of an appropriate extract cleanup method
(assume that representative sampling was documented).
Such interferences often raise the  reporting limits of
individual pesticide analytes (14). If the reporting limits
are higher then the project's decision levels, non-detect
results are not sufficient to declare the samples "clean."
Although  a potentially definitive technique (GC/MS)
was used, in this situation it provided screening data
because other aspects of the analytical chain were
insufficient to achieve the needed analytical data quality.
The information provided by the compromised data is
somewhat  useful (there is indication  that  pesticide
contamination is not present above the reporting limit
for those samples), but that information does not meet
the project manager's need to make the primary project
decisions  at the levels of concern.  However,  the
screening  data can also provide information that  can
guide the  project chemist to  modify any subsequent
analyses (e.g., select an appropriate cleanup method) to
address the analytical problems so that effective data can
be generated.

Terminology—Sample Support

Because sample representativeness is a critical first link
in the data quality chain, it is useful to discuss "sample
support,"  a term not  yet commonly used within the
environmental industry, although it has been around for
some  years  (4).  Sample representativeness can  be
divided into broad components of sample selection and
sample handling. Sample selection must consider the
"location" of samples (i.e., where or when the specimen
is collected).  The heterogeneity of most environmental
matrices demands that sample selection  be carefully
considered so that the number, type, location, and timing
of sample collection will be representative of spatial and
temporal variability in relation to the study objectives.
On the other hand, sample support impacts both sample
selection  and sample handling.  The  term "sample
support" refers to the physical dimensions of the sample,
which is determined by the interplay between a number
of factors.  Sample   support  is  critical to sample
representativeness. Evaluating sample support includes
considering the size, shape, volume, and orientation of
the specimen and of the components that comprise it,
and the  ability of the  sampling tool (such as a coring
device, spatula, or liquid sampler) to collect a represen-
tative specimen  from the statistical population about
which decisions are to be made (19,20).

Even when analysis occurs in situ, the concept of sample

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support is very important to evaluate what "sample" the
sensor or detector actually "sees." Understanding the
sample support governs the comparability of in situ
results to results  obtained by the analysis of discrete
samples,  which, in turn, determines the ability to use in
situ results to guide project decisions. In all sampling
and analysis scenarios, sample support greatly influen-
ces the legitimate interpretation of analytical results. Yet
under the current paradigm, analysts charged with the
task of assessing  the quality or usability of analytical
data packages may not understand what the proj ect goals
are or what  was done in the  field well  enough to
evaluate  whether the samples (and thus the analytical
data package) were indeed representative  and  thus
usable for their intended purpose (7,23).

Whether samples are tree cores, fish tissue, soil borings,
or industrial wastewater, the concept of sample support
is critical to generating reliable environmental data. To
illustrate, consider a hypothetical proj ect where environ-
mental decisions  will  hinge on  ascertaining whether
recent atmospheric deposition has contributed to  lead
contamination in  surface soils.  Contrast two possible
sampling and analysis designs. In Design 1, an approp-
riately calibrated  field portable  X-ray fluorescence
(XRF) instrument is operated in an in situ "point-and-
shoot" fashion where each "shot" measures the total
concentration of lead over a 2 cm2 area to a depth of 1 to
2 mm, and a high sampling density across the site's
surface soil is easily feasible.  In Design 2, a small
number of samples are collected because of the expense
of sending samples to the laboratory  for definitive
analysis using atomic  absorption spectroscopy (AAS).
Design 2 samples are collected using a 4 inch diameter
coring device that takes a 4 inch deep vertical core. The
whole core is deposited in the  sample container for
transport to  the  laboratory.  Once  there, the  lab
technician thoroughly homogenizes the  entire sample
before a 1 gram portion  is taken to  undergo  acid
digestion. The digestate is then analyzed for lead content
by the AAS instrumentation. Which data generation
approach would be expected to be more representative
of the true site condition in relation to the stated project
decisions?

The XRF approach of Design 1 yields more represen-
tative data for two reasons. First, and most critically, the
sample support (a thin surface layer of soil) analyzed by
the XRF is more representative of soil contaminated
through atmospheric deposition than a 4 inch deep  core
that is homogenized before analysis. Second, the higher
number of samples possible with the XRF for a similar
analytical   budget   permits   a  more  thorough
characterization of variability  due to heterogeneity,
improving confidence that anomalous readings (either
high or low) will not distort interpretation of the results.
If isolated high readings are found and if it is important
to the project goals, the extent of hot spot areas could be
quickly delineated during the same field mobilization if
XRF were being used.

As  part of a carefully designed XRF quality control
program tailored  to the needs of the  project, a small
number of split samples might be sent to an off-site
laboratory to establish method comparability between
the  XRF data set and more traditional lead analysis
results or to evaluate potential method interferences.
Note that if samples are sent for off-site  analysis, the
sample support for the two sets of analyses must be the
same or else there will be poor agreement. Typically,
proj ect managers assume that the field method is at fault
if there is not close agreement with fixed  laboratory
"confirmatory samples." In actuality, both methods may
be accurately reporting resultsyfor the samples presented
to them. Differences in sample support (the physical
nature  of the sample, such as particle size) or matrix
heterogeneity  (a  failure to achieve sufficient sample
homogenization prior to splitting the sample) often
accounts for differences between  split sample results.
Significant dissimilarities are also possible in the actual
constituents being measured by  each method,  even
though each method is working perfectly as designed.
For example, the XRF measures total lead in the 2 cm2
surface area it "sees," while the AAS method quantitates
only the lead solubilized under the particular digestion
conditions used (24).

The Data  Quality  Conundrum—Finding a Better
Way

Despite the  fact that  analytical  rigidity  in  many
environmental programs is counterproductive, prescri-
bing how analytical methods are selected and applied
has nearly universal appeal among regulators seeking
simplicity and  predictability in regulatory programs.
This is a  commendable goal, but past attempts  at
"standardizing"  sampling  and  analysis  procedures
created a false sense of security (7). The scientific need
for  project-specific  sampling  and analysis designs
cannot be neglected in favor of convenient uniformity
without jeopardizing the reliability of the environmental
data and their ability to support  sound decisions.

As illustrated in Figure 1, a one-size-fits-all quest for ill-
defined "high quality data" easily adds to program costs
without commensurate benefits. The  effectiveness of

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subsequent remedial actions is put at risk when project
managers  respond  to  high  per-sample  costs  by
decreasing the number  of samples, an  action  that
increases the likelihood of faulty conclusions (23). In
contrast, EPA policies explicitly require proj ect-specific
data collection designs to be matched to the nature of the
samples and to the intended use of the data (25).  EPA's
SW-846  methods manual (used in the waste programs)
warns that its procedures are "meant to be... coupled
with the realization that  the problems encountered in
sampling and  analysis  situations  require  a  certain
amount of flexibility... [that] puts an extra burden on the
user,  [but] is  unavoidable because of the variety of
sampling and analytical conditions found with hazardous
waste" (15).

The way out of the data quality dilemma is to focus on
the bottom line, which is ensuring the overall quality of
the decision driving the data collection effort. Because
uncertainty in environmental decisions is dominated by
sampling variability, increasing the sampling density
increases the certainty that decisions will be correct (as
long as the data generated on those samples is of known
quality commensurate with the decision). Recent advan-
ces in electronics, photonics, and biological reporter
systems have supported the development of innovative
characterization technologies that economically facili-
tate higher sampling densities. Better management of
sampling uncertainty and increased statistical power (the
ability to find a statistical difference when one actually
exists) is possible when  more samples  are  collected.
Public interests would be well served by integrating
these technologies into routine practice because better
overall   decision  certainty  is  achieved  through a
combination of lower per-sample analytical costs and
(most importantly) the ability of innovative measure-
ment technologies to support smarter and faster work
strategies by providing real-time analytical results.

Smarter work strategies have been articulated by various
authors and practitioners over the years, and they go by
names such as expedited site characterization, dynamic
work plans, rapid adaptive site characterization, adaptive
sampling and analysis plans, and similar terms (26-29).
The concept common to all  is using real-time  data
results to guide real-time project decision-making and
integrate characterization efforts with cleanup activities
to the greatest extent feasible. Project managers that
successfully use this strategy demonstrate significant
cost-savings, dramatically shortened timeframes, and
increased confidence in  the protectiveness of project
decisions. Successful implementation of a dynamic work
plan approach requires  considerable investment in
funding  and effort  to perform thorough, up-front,
systematic planning with a core team possessing the full
range of technical skills relevant to project goals. Work
plans are designed to be dynamic, so that subsequent site
activities can rapidly adapt as new information is gained.
Flexibility in the work plans is guided by transparent,
regulator-approved, decision  logic that is focused on
achieving  clearly  defined  project  goals.  Highly
experienced staff must be present in the field to generate
and interpret data, communicate with  regulators, and
implement the decision logic (28,30). Yet, the invest-
ment in planning and qualified technical specialists is
returned handsomely because lifetime project costs are
as much as 50% lower than under traditional scenarios
and  project decisions are  more reliable, often with
statistically  quantifiable certainty. Also, client and
stakeholder  satisfaction is much higher when work is
done quickly and correctly the first time (21,29,31).

There are a number of options by which real-time results
may be produced. Paying for 24-hour turnaround from
a  traditional laboratory is an option that  may be
logistically  and economically  feasible  under  some
circumstances. Under other circumstances, establishing
on-site laboratory facilities in vans or trailers may be
viable options. Field-portable or in situ instrumentation
is increasingly an option of  choice  as technology
development extends the capabilities of these technolo-
gies  into a growing  number  of project  situations.
Selection of analytical platform should be made only
after careful systematic planning has considered the pros
and cons of each option in the context of the project's
decision goals, contaminants of concern, site logistics,
budget, contractor capabilities, etc.

Field-portable technologies used to generate on-site
measurements encompass a growing number of both
definitive and screening methodologies. However, since
some of these technologies do not fit the  "approved
method" paradigm, regulatory acceptance has lagged,
although there are signs that this is changing. Regulators
should be cautious when field analytical technologies
are proposed, ensuring that the use of these technologies
has been carefully considered on a proj ect-specific level.
The  regulator  would want  to  feel  confident  that
analytical and sampling uncertainties are managed and
balanced to meet  the desired  decision certainty, as
described in a proj ect-specific quality assurance plan. It
is to be expected that there would be a learning curve.
The  generation  of data of known  and documented
quality using on-site measurementtechnologies requires
that analytical chemistry expertise be part of the project
planning process from the start. The selection of an

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appropriate field technology and the design of a field
QA/QC protocol that will demonstrate that all relevant
analytical uncertainties are managed to the degree
needed  to assure  scientific  defensibility  requires a
merger of project management expertise, statistical and
geostatistical sampling design knowledge, and analytical
chemistry sophistication. To achieve this multidisciplin-
ary skill mix, the  consulting  engineering community
might partner with analytical service providers, statis-
ticians, and other disciplines. A shift to such extensive
partnering will no doubt be new to many consulting
firms and regulatory agencies.

Regulators can play an important role to  foster this
transition if their  oversight  shifts  from controlling
analytical methods to managing the overall uncertainty
in project decisions. This can be done by ensuring that
project planning documents 1) clearly explain what a
project's goals really are, and what decisions have to be
made in order to achieve those goals; 2) identify  the
maj or factors expected to contribute to uncertainty in the
project decisions; and 3) ensure there is  a technically
valid strategy in place to manage each of those factors.
As the project proceeds, quality assurance  staff could
assure the overall quality  of  project decisions  by
evaluating whether the relative contributions to overall
uncertainty from the various components of sampling
and  analytical error  have  indeed  been  considered
(18,20,25). Planning documents must clearly distinguish
between uncertainties that operate at the analytical level
(i.e., analytical quality or performance at the laboratory
level that is not affected by sample-specific constraints),
at the data level (i.e., evaluation of data quality that
includes sample-specific analytical performance and
consideration about sample representativeness), and at
the project level (i.e., expressions of decision confi-
dence).

Data Set Information Value vs. Data Point Quality in
the Use of Screening Methods

As   discussed  previously, accurate  partitioning   of
sampling and analytical errors reveals that the ability of
many environmental  data sets  to  provide reliable
information has less to do with analytical data quality
than with sampling density. The advantage of many
screening methods is that they are less expensive than
most definitive methods (so more data points can be
obtained) and they can be operated to provide real-time
results. Contrary to popular belief, screening methods
can be selected and operated in ways that produce data
sets that contain meaningful information at a high degree
of confidence, but appropriate analytical  chemistry
expertise and sufficient quality control mechanisms are
required to do so. The cost  advantages of using
screening methods are not sacrificed by this investment
in analytical proficiency.

The contrast between the information value of data sets
and the quality of individual data points was illustrated
in Figure 1. Assume that the data points of Scenario B
were generated using a screening method with a higher
detection limit, less precision, more interferences, and a
tendency to be biased high compared to  the more
expensive definitive method depicted in  Scenario A.
However, the screening method is less expensive, and it
can be used on-site to generate results within hours of
sample collection. If the goal of the project is to detect
the presence of hot spots above  a certain contaminant
concentration and greater than a given size, not only can
the  analytical  method in Scenario B produce  a more
accurate representation of  the  site's contamination
(producing site decisions that are more protective and
defensible), the real-time results can be used to discover,
delineate, and remove hot  spots  in  a  single  field
mobilization.  This  dynamic   approach  can  save
considerable time and money over a hot spot delineation
approach phased over months or years while waiting for
each round  of laboratory results to be returned and
interpreted. Instead, the screening method could produce
data of known quality that are  effective for  site
characterization and cleanup as long as project planning
establishes that the following conditions are met:

 •  The quantitation limit of the screening method is
    well below  the decision level(s) used to define
    unacceptable  concentrations   of  the  targeted
    contaminant(s).

 •  The analytical  variability is minor compared to the
    precision needed to support hot spot detection and
    delineation.

 •  Adequate QC procedures (which may include, but
    by no means are limited to, split sample analysis by
    traditional laboratory methods) are used to monitor
    the amount of bias in the  field results, and to control
    for any impact from interferences. Data quality is
   judged acceptable as long as the  amount of bias or
    the effect of interferences is documented, and can be
    shown to not cause unacceptable errors in project
    decision-making.

Depending on the  nature of the  contaminants and the
field methods used, confirmation that a site is "clean"
for purposes of regulatory closure often will require the

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analyte-specific, highly quantitative results that only
definitive laboratory methods can provide. But if prior
site  characterization using  the field  method  was
thorough, the representativeness of these expensive
samples will be assured, even if they are relatively few
in number. There will be no surprise "hits" or unexpec-
ted analytical  problems  with the closure samples,
allowing  statistical estimation of confidence  in the
closure decision to be determined cost-effectively (21).

Screening Methods Can Produce Data of Known
Quality

Results from screening methods  are often viewed with
suspicion. This view is justified if the QA/QC needed to
establish validity of the data has not been performed, or
if critical uncertainties in the analytical method have not
been managed. Screening methods may be described as
analytical methods for which significant uncertainties
exist  in  the  method's ability to positively identify
individual compounds  (within a class or of a certain
type)  and/or to quantitate analyte concentrations. For
example, an immunoassay method for DDT will produce
a response not just for the two DDT isomers, but also for
degradation products  of DDT  and possibly other
compounds  with similar  chemical  structures. Most
immunoassay  kits  for environmental applications are
also designed to have a significant positive bias to mini-
mize the  chance of false negative results. Obviously, it
would be foolish to expect that a result from a "DDT"
immunoassay  kit would be  directly comparable to a
DDT  result from a definitive method (21).

Although similar  kinds  of uncertainties  exist  for
definitive methods as well,  the magnitude of these
uncertainties is expected to be much less for definitive
methods  than  for screening  methods. Yet, data users
should be aware that the same definitive method that
produces  excellent recovery and precision for some
analytes on the list of potential target analytes may well
produce poor recovery and precision for other analytes
on the list. That is because optimizing the operating
conditions of an analytical technique for certain analytes
necessarily degrades the performance of other analytes
that have different  chemical  properties.  This short-
coming is particularly true for generalized methods that
have very long and diverse target analyte lists, such as
SW-846  Methods  8260 (GC/MS for volatile  organic
compounds, VOCs) and 8270 (GC/MS for semi-volatile
organic compounds, SVOCs). Even if only analytical
quality is assessed, the data for  some analytes from a
sample might be considered "definitive"  while other
analyte results for the same sample and analytical run
should be considered "screening." This is not a fault of
environmental laboratories; this is the consequence of
demanding that a diverse list of analytes be reported
from a single instrument run to cut analytical costs. This
is an acceptable approach as long as it is quite clear to
the data user that some  results should be  considered
"screening" (i.e., highly uncertain) despite the fact that
they were generated from a definitive method.

The phrase  "data of known quality" means that data
quality characteristics such as representativeness, degree
of bias and precision, selectivity, detection/quantitation
limits, and impact by interferences are documented. The
goal of project planning is to match an analytical method
and its ability to produce data of a certain quality with
the needs of the project. This principle is true whether
definitive or screening techniques are being considered.
With  an appropriate project-specific QA/QC protocol,
estimates for a screening method's  quantitation  limit,
bias,  and any other data  quality indicators  relevant to
project  decision-making  can be determined. Together
with evidence of sample representativeness, these para-
meters establish data of known quality. When the actual
data quality generated through the use of proj ect-specific
QC samples is compared against the data quality needed
for making defensible project decision, and the actual
data quality is found inadequate for decision-making
purposes, the data may still serve useful purposes as
screening quality data. Screening data may be defined as
data that provide some information (such as indications
of matrix variability or analytical interferences) useful
to furthering understanding of contaminant distribution
or behavior. But the data  contain too much uncertainty
to be  used for making solid project decisions that can
bring the site to final resolution. Deliberately producing
screening data (using either a screening or definitive
technique)  can be a highly cost-effective strategy, as
long as the difference between decision quality data and
screening data (and how they individually will be used
in the context of project)  remains clear.

Data that are of unknown quality (because of inadequate
QC  or  sampling  density)  may possibly  serve  as
screening data if interpreted very carefully and conser-
vatively. But the production of data of unknown quality
is an  undesirable situation that generally means  there
was a breakdown in the project planning process. Data
of unknown quality cannot be used to make project
decisions (i.e., data of  unknown quality  cannot be
treated  as decision quality data) since, by definition,
critical analytical uncertainties were not controlled and
the possibility that the data may cause a decision error is
too great.
                                                   10

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Under the  traditional paradigm, it may  be weeks  or
months before project  personnel  get data packages
returned from a laboratory and discover whether the
actual data quality is of decision quality, screening
quality,  or unknown quality. Current  procurement
practices mean that laboratories are seldom aware of a
project's actual data needs, and laboratories are seldom
authorized  to explore method modifications to improve
data quality  when  sample interferences compromise
analytical performance. By the time a project managers
realizes that the data are inadequate, they are faced with
a difficult decision. They must choose either to signifi-
cantly delay subsequent site work and incur additional
costs while samples are recollected or reanalyzed, or to
significantly weaken the defensibility of their decisions
by "taking their best guess" based on the data available.

On-site analysis offer substantial advantages in this area,
as long as adequate  systematic planning has clearly
defined the data requirements. On-site measurement
methods can  easily be operated with a project-specific
QA/QC  protocol  tailored specifically  to  meet the
project's data quality requirements. During  project
implementation,  real-time results  provide  immediate
feedback to project personnel about actual data quality
as it is being generated. Contingency plans (which are an
integral feature of dynamic strategies) are activated if
analytical or matrix problems are encountered, minimi-
zing wasted analyses and delays. Analytical results that
seem out of line can be immediately investigated to rule
out clerical errors and other blunders, or  to reevaluate
the representativeness of the current sampling  design
(32).

When using  a screening method to generate decision
quality  data, the key is to openly  acknowledge the
strengths and limitations of the method. In principle, this
is true whether using a definitive method or a screening
method, but there is more opportunity for error when
selecting a screening method,  which is  why it  is
e specially important that the person making the selection
have the appropriate  analytical chemistry experience.
Method selection requires that the project chemist:

1)  Demonstrate that the  uncertainty  in  the data
    produced by the selected method will be insignifi-
    cant in relation to the nature of the decision. For
    example, uncertainty about whetherthe actual result
    is 10 ppm vs.  20 ppm may be unimportant if the
    decision  hinges only on whether the contaminant
    concentration  is  greater  or   less than 50 ppm
    (compare Figure 2);
2)  Use various strategies to  cost-effectively control
    potential analytical uncertainties, such as evaluating
    historical information to assess what contaminants
    likely may or may  not be present, performing a
    demonstration of applicability (i.e., an  analytical
    pilot study) to verify anticipated site-specific perfor-
    mance (15), and  tailoring a confirmation testing
    protocol  to  establish  project-specific  method
    comparability and detect any interferences; and

3)  Use less specific methods to a project's advantage.
    For example, a method that detects a wide range of
    chlorinated organic compounds could be used to
    assess  site  locations for a large number of such
    contaminants simultaneously. Negative results at an
    appropriate level of quantitation could economically
    rule out  the presence  of contaminants such as
    polychlorinated biphenyls (PCBs), organochlorine
    pesticides,  chlorobenzenes,  chlorophenols,  etc.
    Expensive traditional analyses could be reserved for
    selected samples with positive results higher than a
    concentration of potential concern that is kit- or
    proj ect-specific; and serve to unequivocally identify
    the contaminant(s) and their actual concentration(s).

A prudent project chemist can use information about
interferences and contaminant concentrations provided
by screening method results to improve the quality and
cost-effectiveness of any follow-up definitive analyses.
Further, by collaborating with statistical expertise, the
planning team can use screening methods in conjunction
with limited definitive analysis to produce highly cost-
effective data sets based on statistically rigorous samp-
ling designs such as ranked  set sampling and adaptive
cluster sampling (33).

When  data are  of known  quality, it is  possible to
designate  which data results are effective for making
decisions, and which data results would not be effective.
For example, when a screening method is used, results
that fall well above or well  below an action level are
often effective for making decisions about  "clean"
versus "dirty" areas. However, when the uncertainty in
the method's results overlaps the action level, results
that fall  within the range  of overlap  might not be
effective for making decisions about that action level.
Because further analysis would be required  to make a
defensible decision, data within that range of uncertainty
would constitute screening data. Of course, those results
are still highly valuable  since they guide sample selec-
tion for more expensive  analysis. In this way, the value
of confirmation testing dollars is maximized since
samples are selected for confirmatory analysis with a
                                                   11

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specific goal in mind, that of filling the data gaps most
relevant to decreasing decision uncertainty and estab-
lishing regulatory compliance. Figure 2 illustrates how
the data ranges that would comprise effective data in the
context of a  hypothetical  project  might be clearly
specified in the project's sampling and analysis plan,
along with the action that will be taken when data fall
into a range that is not effective for making the project
decision.

Benefits of More Descriptive Terminology

Adopting  the concept  of  "effective data"  would
reinforce a more productive conceptual framework for
data generation within the context of site restoration.
The foundation of that framework is an appreciation for
the importance of a systematic planning process (such as
EPA's DQO process) (20,34). Both terms, "effective
data" and "decision quality data," equivalently serve to
support systematic planning by encouraging critical
thinking about the anticipated role of data. Both terms
intuitively demand that these questions be addressed:

 • What  is it that the data are to be effective for? In
   other words, what is the intended use of the data?
   What are the decisions to be supported? And how
   "good" should those decisions be (i.e., what level of
   decision confidence or certainty is desired)?

 • When planning to generate effective data, what are
   the  strengths and limitations  of the  proposed
   methods (costs, labor requirements,  quantitation
   limits, precision, expected rates for false positive
             and false negative  analytical results, bias, turn-
             around time, complexity of the  procedure, equip-
             ment reliability, etc.)?

          •  What are the site-specific considerations that could
             adversely impact  analytical performance  (e.g.,
             physical and chemical matrix effects, and operating
             conditions for onsite analysis like temperature and
             humidity), and how will those things be controlled?

          •  What are the site-specific considerations that will
             influence representative sampling (e.g., contaminant
             variability in time  and space,  and the physical
             makeup of the matrix)?

          •  What are the site-specific considerations that will
             govern  what  statistical  measure(s)  should  be
             determined (e.g., the mean  concentration across
             some  exposure  unit  vs.  an estimate of  some
             maximum value)?

         Conclusion

         When data needs are clearly articulated, and where a
         number of modern sampling and analytical options exist,
         it  is possible to optimize data collection so that the
         information produced is sufficiently accurate  for its
         intended purpose, yet  at  a much lower cost  than
         previously  thought possible. A judicious blending of
         screening and definitive methods,  used both  in the
         traditional laboratory setting and in the field, contribute
         to generating both effective and screening data sets that
         each play valuable roles in defensible, yet highly cost-
                        Effective Data Range Illustration
                  A project plans to classify drums of PCB waste as        or     than
                  a 50 ppm action level. An immunoassay (IA) kit is demonstrated to be
                  effective for such decision-making if the kit result is < 45 ppm or > 65
                  ppm.                      , IA kit accuracy does not achieve the
                  level needed to meet the decision goal confidence as set in the project
                  DQOs.  Therefore, samples with kit results in the 45-65 range will be
                  tested by another method that can provide the needed accuracy.


                                   PCB concentration by IA (ppm)
                          Effective Data
                             frue< AL
    AL
 45 50
H  !
                                                         65
Effective Data
                                            Additional Testing
                                                Required
                                               FIGURE 2.

                                                   12

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effective  decision-making, as long as the distinctions
between  them are  understood by  decision-makers.
Emerging site characterization and monitoring tools
promise to  bring down  the costs of  environmental
restoration and long-term monitoring, but only if regula-
tors and  practitioners incorporate them appropriately
into modern, efficient work strategies, such as dynamic
work plans.

Terminology that reinforces systematic planning and
acknowledges the capabilities  of new  tools to  assist
environmental decision-making could cultivate a more
productive attitude  about data quality issues  where
assessment of "data  quality" is  solidly anchored in the
data's intended  use. Language is the  instrument  of
                                          thought, and unfortunately, terms like "definitive data"
                                          or "high quality  data" have become  ingrained with
                                          misconceptions arising from the idea that prescriptive
                                          method requirements can somehow guarantee that data
                                          point quality will  equate to decision quality. A culture
                                          has emerged that  rigidly scrutinizes data points, while
                                          the very foundations of information quality and scien-
                                          tific defensibility are neglected. The authors  propose
                                          adoption of the equivalent terms, "effective data" and
                                          "decision quality  data," as the foundation of a frame-
                                          work that can refocus the environmental community and
                                          data quality assessment on ensuring better decisions
                                          through more defensible, protective, cost-effective, and
                                          innovation-friendly   approaches   to  environmental
                                          decision-making.
Glossary
 Term
Description of term as used in this paper
 field-based     Equivalent to "on-site analytical methods" and a host of similar terms that are used to denote that the
 measurement   instrumentation and methods used to perform real-time analyses is in close proximity to the actual location
 technologies    of sample collection. Implementation ranges from hand-held instruments used outdoors to full-scale mobile
                laboratories.
 field screening  This term is highly ambiguous and misleading.  Its use is discouraged unless additional descriptors are
                provided to clarify whether the speaker intends to refer to screening methods (i.e., non-specific, interference
                prone, imprecise analytical techniques), screening data (i.e., some useful information is provided, but not
                enough to defensibly support project decisions), or screening decisions (i.e., decisions that are not fully
                defensible because of insufficient evidence).
 decision       Ideally, the degree to which an actual decision coincides with the decision that would have been made if
 quality         complete and fully accurate information (i.e., the true state) were known (or knowable). Because the "true
                state" might not be known at the time  of decision-making (i.e., it may not be feasible to know for certain
                whether the decision was correct in an absolute sense), decision quality is commensurate with the degree of
                confidence in the correctness of a decision. That confidence is a function of the extent to which information
                is weighed fairly while acknowledging the assumptions, conditions, and uncertainties that could impact the
                correctness of the decision. Hence, decision quality is also related to its ability to be defended in a reasonable,
                honest and logical discussion of issues.
 data quality     Although usage of this term has tended to be vague, the EPA has recently defined data quality as "the totality
                of features and characteristics  of data that bear on its ability to meet the stated or implied needs and
                expectations of the customer " (i.e., data user) (35). In the same vein, recent EPA guidance states that"... data
                quality, as a concept, is meaningful only when it relates to the intended use of the data. Data quality does not
                exist in a vacuum; one must know in what context a data set is to be used in order to establish a relevant
                yardstick for judging whether or not the data set is adequate" (36). Since analytical data are generated from
                samples, pre-analytical considerations  (such as  sample representativeness and sample integrity) are crucial
                when determining whether the data are of sufficient quality to meet the user's need to make correct decisions.
 analytical      An expression of the bias, precision, and other characteristics of the measurement process that reflect the
 quality         ability of the analytical method to produce results that represent the true concentration of the target analyte
                in the sample that was presented to the analytical process. Pre-analytical considerations are not a factor in
                determining analytical quality.
 defensible      Derived logically with all underlying assumptions and uncertainties openly acknowledged. To the degree
                feasible, uncertainties are controlled or documented so that the impact on the likelihood of decisions errors
                is understood. Conclusions are thus able to withstand reasonable challenge.
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Term
               Description of term as used in this paper
definitive      As the term is used in the environmental field: An analytical method for which the degree of uncertainty in
analytical      the identification and quantification of target analytes  is documented, normally  using ideal or well
method        characterized matrices. The specificity associated with an analytical measurement and the potential for
               influences from interferences can be identified. Example: GC-MS. Definitive  methods  are not free of
               uncertainties, but the degree of uncertainty is less than that considered to be characteristic of screening
               methods.
screening      Analytical methods for which higher levels of uncertainty are expected in the data produced because the
analytical      method is limited in its ability to quantify the presence of specific analytes. The resulting data are expected
method        to have higher quantitation  limits, be more biased, be less precise,  be  less selective, and/or be more
               susceptible to interferences than data produced by definitive methods. Example: immunoassay kit for DDT.
data point      Analytical results for a single sample, specimen, or target analyte.
data set        Analytical results for a group of samples that are expected to be representative of the characteristic(s) of the
               environmental matrix under investigation.
definitive data  Although a legitimate term in science, this term is not recommended in the environmental field because the
               current convention for using the term has focused solely on analytical quality, and sampling uncertainty (or
               total measurement uncertainty) has not addressed in practice. The term has thus not been  conducive to
               ensuring decision quality. Current usage of the term in the environmental field seems to stem from selective
               reading of an EPA definition says,  in part: "Definitive data  are  generated using rigorous  analytical
               methods... are analyte-specific, with confirmation of analyte identity and concentration." (4).
screening data  Data (points or set) that may provide some useful information, but that information by itself may not be
               sufficient to support project decision-making because the amount of uncertainty (due to sampling, analytical,
               or other considerations)  is  greater than what is tolerable.  When data that would be considered screening
               quality (if considered in isolation) are combined with other information or additional data that manages the
               relevant uncertainties, the combined data/information package becomes effective  for decision-making (see
               collaborative data sets).
effective data   Data (points or set) of known quality that can be logically shown to be effective for making scientifically
               defensible primary project decisions without requiring additional data or information to back them up,
               because both the sampling and analytical uncertainties in the data have been  controlled to the  degree
               necessary to meet clearly defined decision goals. Equivalent to "decision quality" data.
               Term is equivalent to "effective" data.
decision
quality data
data of known
quality
               Data for which the contributions to its uncertainty from both sampling and analytical variability can be
               estimated (either qualitatively or  quantitatively) with respect to the intended use of the data, and the
               documentation to that effect is verifiable and recognized by the scientific community as defensible.
collaborative   Data sets that might not be effective for making project decisions when considered alone, but combined
data sets       together they manage all relevant uncertainties to the degree necessary to support defensible decision-making.
               This may sometimes be considered a type of "weight of evidence" approach.
ancillary data   Project data used to manage project activities other than those directly engaged in supporting primary project
               decisions.  Examples  of ancillary data include  health &  safety monitoring  data, meteorological data,
               stratigraphic data, etc.
sample support The size, shape (length, width and height dimensions), and orientation of a sample in relation to the parent
               matrix or contaminant population it is desired to emulate.
sample         An expression of the degree to which a sample can be used to estimate the characteristics of a population
representa-     under investigation with respect to the decision to be made.
tiveness
analytical      An expression of the degree to which a sample analysis represents the characteristic of a population under
representative- investigation with respect to the decision to be made.
ness
primary        Forprojects involving the cleanup and closeout of contaminated sites, these are decisions that drive resolution
project         of that project. Generally these decisions are based on demonstrating the presence/absence of pollutants
decision       above/below certain thresholds.  Therefore, contaminant  data generated on environmental matrices by
               analytical chemistry methods usually drive primary project decisions.
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References

(1) Crumbling, D.M., C. Groenjes, B. Lesnik, K. Lynch, J. Shockley, J. van Ee, R.A. Howe, L.H. Keith, and J.
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(6) Smith, R.-K. 2001.  Interpretation of Inorganic Data. Genium Publishing Corporation. Canada. http://www.
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(11)  Fairless, B.J. and  D.I. Bates.  1989. Estimating the quality of environmental data. Pollution  Engineering
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(14) Smith, R.-K. 2000. Interpretation of Organic Data. Genium Publishing Corporation. Canada. http://www.
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(19) U.S. Environmental Protection Agency (USEPA).  1989. Soil Sampling Quality Assurance User's Guide (2nd
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(22) Crumbling, D.M. 2001. Current Perspectives in Site Remediation and Monitoring: Clarifying DQO Terminology
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(28) Robbat, A. 1997. A Guideline for Dynamic Workplans and Field Analytics: The Keys to Cost-Effective Site
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Environmental Protection Agency, Washington, DC. http://clujn.org/download/char/dynwkpln.pdf

(29) U.S. Department of Energy (DOE). 2001. Adaptive Sampling and Analysis Programs (ASAPs). DOE/EM-0592.
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(31) U.S. Department of Energy. 1998. Innovative Technology Summary Report: Expedited Site Characterization.
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(32) Crume, C. The Business of Making a Lab Field-Portable: Getting the Big Picture on an Emerging Market.
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(33) For additional information concerning statistical sampling designs, refer to EPA's Cleanup Information website
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(34) U.S. Environmental Protection Agency (USEPA). 1999. Review of the Agency-Wide Quality System. Letter
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(35) U.S. Environmental Protection Agency (USEPA). 2000. Office of Environmental Information Management
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(36) U.S. Environmental Protection Agency (USEPA). 2000. Guidance for Data Quality Assessment: Practical
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final.pdf
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