Systematic Planning
MODULE AT A GLANCE
Overview
SLIDE SP-1 – Systematic Planning
SLIDE SP-2 – Overview
SLIDE SP-3 – Systematic Planning is an Organized Method For:
SLIDE SP-4 – Activities in Systematic Planning
Project Management
SLIDE SP-5 – Assemble Stakeholders and Project Team
SLIDE SP-6 – Generic Project Organizational Structure
SLIDE SP-7 – Identify Stakeholders
SLIDE SP-8 – Stakeholders/Decisionmakers – Role in Project Planning
SLIDE SP-9 – Assemble Effective Project Teams
SLIDE SP-10 – Challenges in Project Management
Conceptual Site Models (CSM)
SLIDE SP-11 – Conceptual Site Models (CSM)
SLIDE SP-12 – Overview – What is a CSM?
SLIDE SP-13 – Graphical Illustration of CSM
SLIDE SP-14 – Narrative Description of CSM
SLIDE SP-15 – Tabular Presentation of CSM
SLIDE SP-16 – Role of CSM in Conventional Site Characterization
SLIDE SP-17 – The Role of a Continually Refined CSM
SLIDE SP-18 – NAWS China Lake CSM
SLIDE SP-19 – The Power of a Poor CSM – China Lake Naval Air Weapons Station
SLIDE SP-20 – The Power of a Refined CSM – China Lake Naval Air Weapons Station
SLIDE SP-21 – CSMs and Site Cleanup
Demonstration of Methods Applicability
SLIDE SP-22 – Decision Criteria
SLIDE SP-23 – Decision Supports Using CSM
SLIDE SP-24 – The CSM and Sample Support
SLIDE SP-25 – Outputs from Sample Support Evaluation
SLIDE SP-26 – Is the Subsample Support Representative?
SLIDE SP-27 – Assess Field-based Analytical Methods
SLIDE SP-28 – Constraining the Tools – Demonstration of Method Applicability
SLIDE SP-29 – Considering the DMA
Systematic Planning – i
SLIDE SP-30 – DMA – Important Outputs
SLIDE SP-31 – Refining Decision Logic and Data Collection
SLIDE SP-32 – Example – Ross Incinerator Site, EPA Region 8
Dynamic Work Strategies
SLIDE SP-33 – Dynamic Work Strategy/Adaptive Decision Statements
SLIDE SP-34 – Examples of Decision Statements
SLIDE SP-35 – Other Uses of Decision Trees
Real-Time Data Management
SLIDE SP-36 – Data Management
SLIDE SP-37 – Designing a Triad Data Management Scheme
SLIDE SP-38 – Overall Data Flow
SLIDE SP-39 – Core Technical Team Considerations
SLIDE SP-40 – Core Technical Team Considerations (continued)
SLIDE SP-41 – Core Technical Team Considerations (continued)
SLIDE SP-42 – Database Design
SLIDE SP-43 – Database Development
SLIDE SP-44 – Database Management
SLIDE SP-45 – Data Entry and Quality Control (QC)
SLIDE SP-46 – Web-Based Real-Time Data Management
SLIDE SP-47 – Triad Data Management Requirements
SLIDE SP-48 – Deployable Subsurface Sensor Systems
SLIDE SP-49 – MIP – Multiple Channel Data Sets
SLIDE SP-50 – Laser Induced Fluorescence Data
SLIDE SP-51 – Cone Penetrometer Data
SLIDE SP-52 – 3-D Optimization via Webcast – Well Data
SLIDE SP-53 – Soil Conductivity Results
SLIDE SP-54 – Costs for Obtaining Collaborative versus Quantitative Data
SLIDE SP-55 – Hunters Point Shipyard (HPS) Web Portal
SLIDE SP-56 – HPS Web Portal (continued)
Procurement and Contracting Considerations
SLIDE SP-57 – Procurement and Contracting Considerations
Systematic Planning – ii
Overview
EPA SP-1
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Notes:
The Environmental Protection Agency’s (EPA) Policy and Program Requirements for the
Mandatory Agency-wide Quality System (Order 360.1 CHG 1; EPA 1998) requires a systematic planning process for all data collection and use by or for the Agency. The process has been assigned various titles by different organizations; whatever it is called, the process is critical to maximize project efficiency.
Comprehensive, up-front planning is essential to effectively complete any environmental project.
Proper planning will assure that the data collected will lead to defensible decisions. During characterization, the ultimate cleanup goals for the site should be used as the basis for developing a sampling strategy and selecting the appropriate tools and methods for both sampling and analysis. Dynamic work plan strategies and decision making based on real-time measurement are not appropriate for all projects. By developing a systematic plan, however, it will become obvious whether a dynamic strategy and real-time decision making will yield substantial economic or technical benefits and will improve the quality of the decision.
The Triad approach encourages project managers to develop a systematic plan and identify a core technical team as early as possible in a project’s life cycle. Project managers may even consider contracting outside help to assist during the preliminary planning phase to assure that a proposed approach is complete.
SP-1
Module: Systematic Planning
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Overview
Development of a systematic plan before a service provider is selected an integral part of using the Triad, for several reasons:
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Contingencies can be anticipated. A detailed statement of work (SOW) can be prepared that allows vendors at all levels of sophistication to bid on complex jobs.
The proposed approach and analytical tools must be truth-checked informally with vendors before a formal request for proposal (RFP) is issued or an SOW is prepared for an existing contractor.
Project personnel, sellers of services and goods, and decisions makers need to work together to identify activities that will assure the project objectives are satisfied. Project work using the
Triad approach, in particular, requires that the data or information (including stakeholder input) be of known quality, quantity, and type to support the requirements of the project.
The systematic planning process has been assigned various titles by different organizations. For example, EPA has articulated the Data Quality Objective (DQO) process to focus planning for collecting data to support decisions about whether site contamination exceeds regulatory thresholds for exposure (see EPA QA/G-4, 2000; http://www.epa.gov/quality/qa_docs.html
). Another example of an established approach to systematic planning is the Technical Project Planning (TPP) process established by the U.S.
Army Corps of Engineers (USACE) for Cleanup of Hazardous, Toxic, and Radioactive Waste
(HTRW)(USACE EM 200-1-2, 1998; http://www.usace.army.mil./inet/usace-docs/eng-manuals/em.htm
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Module: Systematic Planning
SP-2
Overview
EPA SP-2
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Notes:
In this module, we will take a broad look at the systematic planning process. We will attempt to provide an overarching framework as the basis for the specific activities and tools used on
Triad projects. Certain practical activities can be used under most circumstances to begin to develop a sound, systematic plan for investigation through restoration. Although these activities will change in character depending on many site-specific constraints, the types of information required are generally similar for different sites. By grouping these activities under an activity type, we hope that practitioners will find time to methodically examine site-specific data and other resource needs ahead of time so that projects are executed with the utmost efficiency.
This checklist-type approach is designed to help assist project managers in understanding the essential elements of uncertainty management and are not intended as a prescribed checklist.
Each of the activities described must be examined and designed specifically around the requirements of each site. Understanding the sources of decision error and segregating these elements so that they can be more easily identified and managed is the key to project success using the Triad.
Quality control and use of the Triad are often a large topic for discussion. The increased use of field-based measurement technologies to guide decision making puts more pressure on project teams to react quickly and be prepared before they go to the field by understanding the technologies they plan to use and assuring that these technologies match conditions at the site.
The more aggressive management of data quality through the use of a conceptual site model, more analysis of replicate and duplicate samples, and statistical comparisons create the need for
SP-3
Module: Systematic Planning
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Overview new tools to support the project planning, implementation, and reporting processes. These concepts and methods of data analysis are the means to assure the reliability of project decisions. The quality assurance (QA) process and resulting quality control (QC) sampling programs used at Triad sites can be facilitated in some cases only through use of new field-based tools or use of multiple lines of evidence. This concept is really nothing new, but no formal guidance has been available to date to address some of the major sources of decision uncertainties, such as spatial heterogeneity.
Finally, we will examine a case study where the Triad was used at a 12-acre former power plant site with a long history of operation and storage of transformers. Systematic planning was used, along with the other two main operating principles of the Triad, dynamic work strategies and field-based measurements, to evaluate whether the planned reuse for the site as a recreation facility and wetlands park were viable. The project was completed in a single mobilization, reducing anticipated costs and the time required to reach the project objectives.
Module: Systematic Planning
SP-4
Overview
EPA SP-3
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Notes:
Clearly State Project Objectives and Identify Stakeholders, Timelines, and Other Constraints
Project managers are encouraged to seek assistance from technical experts as early as possible in a project’s lifecycle to assure the reliability of project decision logic and project cost estimates. Without the appropriate training and experience, the constraints that will control the success or failure of a project are less than obvious.
The first step of the systematic planning process may be the most difficult to carry out and the most vital to the success of any project. Stakeholders must agree on the overall objectives of the project to ensure that decisions can be made with an accepted level of confidence.
The skill base of the planning team and the scope of the activities must be matched to assure the quality of the credible scenarios that are required to implement the dynamic work plan strategy.
Exposure scenarios, along with the conceptual site model (CSM), must be reviewed against the scope of services developed to ensure that the information that will be collected will satisfy project objectives. It may be desirable to initially develop the CSM and potential exposure scenarios within a small group before a plan for the site as a whole is set forth to other team members and stakeholders.
SP-5
Module: Systematic Planning
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Overview
Members of the planning team who should review and agree on a scope of services and the overall plan for a site might include:
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Project Manager – Typically, the project manager is the primary decision maker responsible for interaction with other regulatory bodies, other potentially responsible parties (PRP), the public, and team members. The project manager is responsible for allocating resources and coordinating on-site activities.
Regulatory Authorities or their Consultants – This category includes the regulatory authorities or their consultants who might bring policy considerations to decisions. For example, state environmental organizations, EPA regional staff, or local jurisdictions will require that their viewpoints be incorporated into the process to assure a successful conclusion.
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Technical Staff – This component encompasses the multidisciplinary experts who should be considered, such as QA specialists, chemists, hydrologists, human health and ecological risk assessors, biologists, geologists, engineers, data managers, and statisticians. Each of these members needs to review relevant sections of the required scopes of work and unit costs to ensure that they are appropriate based on site conditions.
Stakeholders – This component includes interested members of the community, local government authorities, and other potentially responsible parties. Often, these members can provide valuable practical input on the proposed plan of action.
Specialists in areas such as geology, chemistry, health and safety, and other disciplines should assist in identifying contingency plans and preparing relevant aspects of project planning documents. Specialists who develop the systematic plan preferably will not be directly involved with the project. In addition, before the systematic plan is issued to potential bidders, the proposed approach should be discussed with qualified professionals outside the planning team to truth-check the plan and identify as many contingencies as possible.
The planning team should accommodate not only technical considerations but also community involvement. Community relations and appropriate reviews by public and private interests may be needed. In addition, their concerns must be considered, and under the requirements of the National
Contingency Plan (NCP), written responses prepared.
Establish Decisions to be Made by Developing a CSM and Defining Exposure Scenarios
In this portion of the systematic planning process, the project planning team refines the principal study questions into decisions that need to be made. The initial decision statements should lead to more detailed decisions that might need to be used collaboratively to make the primary decision. The nature of these decision statements will depend on the stage of a site in the cleanup process. These statements
SP-6
Module: Systematic Planning
Overview should be developed for all types of environmental restorations contemplated at a site. The statements may be qualitative or quantitative, but should lay the foundation for the project team to focus resources and define the boundaries of activities that will be necessary to reach a defensible decision.
Decision statements and the related action may need to be developed that provide the accepted decision criteria that will be used as a basis for making real-time decisions. Decision statements should be organized in a logical manner so that data or results from one type of activity roll easily into the next logical step in the project.
Well-defined decision logic is paramount to project efficiency and identifying logical related activities that can be combined when monitoring and measurement are implemented. Scheduling, for example, may depend on the number of samples that can be collected in a day as well as on the number that can be analyzed and processed. When decision making becomes problematic, alternative decision logic should be identified, along with any follow-on action required.
A CSM is a functional description of everything that is known about a site and the contamination present. The CSM is developed at the start of a project and is carefully maintained and updated throughout the life of activities at the site.
Instruments that provide continuous readings often require near real-time analysis of collaborative results to reach decision points. All results and reviews required must be considered in preparing a project schedule. Limiting factors such as QA/QC and analysis of confirmation samples may need to be considered and results obtained before excavation equipment can be remobilized to an adjacent location, for example, a project team needs to develop a CSM for the site to identify required project decisions and set up a project schedule and contingencies.
As the CSM matures, more detail is added concerning:
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Location of contamination or waste sources and new sampling locations
Types and expected concentrations of contaminants
Potentially contaminated media and migration pathways
Potential human and ecological receptors
Modifications to the scope of services required
Potential interferences and other contingency plans
The planning team initially develops the CSM by collecting all available site data, including QA and QC documentation associated with previous investigations. Knowledge of the waste types and the nature of contaminants at the site are then used to develop decision logic and select a specific sampling and analysis scheme. The project team develops a schedule and cost options to mitigate or further evaluate critical data gaps.
Initial exposure scenarios are often based on a limited data set to evaluate the preliminary or baseline risk associated with a site. “Risk Assessment Guidance for Superfund” (EPA 1991) provides more
SP-7
Module: Systematic Planning
Overview information on planning for a monitoring and measurement study, usually to refine exposure assumptions or refine a design for action.
Risks driving constituents and scenarios include:
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The presence of sensitive populations or ecosystems
Contaminants of potential concern based on past activities at a site
Current and future uses of the property
Applicable or Relevant and Appropriate Requirements (ARARs)
Preliminary remediation goals for constituents when ARARs do not exist or are deemed insufficiently protective of human health and the environment
Risk drivers and exposure scenarios that should represent the highest level of exposure that could reasonably occur at the site.
Risk evaluations should examine, at least from a qualitative standpoint, actual and potential exposure pathways through environmental media from both primary and secondary sources. Threshold risk values and exposure scenarios will control the analytical tools and methods, both sampling and analytical, that are viable in supporting a specific decision.
Specify Data and Resource Needs
The project planning team should review the overall decision statements and identify the activities or data that will be required to reach the decisions. For example, sources of data can be evaluated and compared with the decision criteria.
Issues such as the availability of existing data, the sensitivity of analytical methods, cost, method reliability, and sources of error for analytical, sampling design, and risk estimation are considered so that the appropriate activities and methods to collect the desired information can be established.
Scoping a project can be improved when field-based measurement technologies are considered during the initial portions of an investigation. Collecting some preliminary results from key areas on a site using a candidate technology can help assure that data needs and resources required are accurately assessed.
Data collection and design specifications must be adjusted if contaminants are derived from unknown sources or are randomly distributed. Some limited fixed-laboratory methods that can discriminate among individual contaminants within complex mixtures of contaminants may be required before an appropriate field-based measurement technology can be identified if the type of contaminants may be diverse. This process is referred to as a demonstration of method applicability. Data collection using fixed-laboratory methods is often cost prohibitive to support statistically based decision making. If the contaminants are well defined, less selective field-based methods may provide the data required because the impact of potential interferences is understood or minimal. When strictly statistical or probabilistic decisions must be made, field-based methods are often the only way to collect sufficient data economically. Field-based measurement technologies allow for rapid collection of a larger number
SP-8
Module: Systematic Planning
Overview of data points. Thus, they lend more power and confidence to the statistical test used during decision making, regardless of the slightly lower level of data quality for some field-based methods.
Identify Boundaries and Decision Criteria
Realistic spatial and temporal boundaries are clearly defined in this step of the systematic planning process. In addition, specific decision rules are established in conjunction with the boundaries of the study that will be used to guide activities as data are compiled, evaluated, and used to make project decisions.
Boundaries should encompass aspects of the site that will be studied and sampled. The boundaries also should consider the schedule for the investigation, the timing of sampling in relationship to the project objectives, and all stakeholders and contractors or vendors involved.
A site should be segregated into the smallest logical and viable groups of subpopulations or activity areas to assist in estimating the cost of implementing and managing the investigation in a series of sequenced activities. Logically related activities or tasks should be stand-alone to the degree possible to allow maximum flexibility during contracting and project implementation.
These boundaries should consider any practical constraints identified and potential obstacles discussed in terms of their impact on the anticipated progress of the project. The boundaries should describe populations of required results and the media to be examined. Physical and political hurdles also should be identified.
The level of authority for decisionmaking may be based on:
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Technical discipline
Impact on risk estimations
Permits or other regulatory conditions for a site
Technology or economy-of-scale issues
Financial considerations
Contaminant segregation
Physical or temporal constraints
Resource constraints
Any combination of these factors.
For dynamic investigations, activities should be sequenced whenever possible to limit the size of the crew and maximize efficiency. The level of authority required for small and large decisions should be well established and documented in the work plan and other supporting documents.
Decision criteria are developed through understanding and managing potential sources of uncertainty and matching data quality with the intended use of the data, as briefly introduced in the following sections. Sources of uncertainty can be viewed as an “onion skin” or hierarchical set of factors: some
SP-9
Module: Systematic Planning
Overview are sampling-related and some are related to the analytical method. Deciding on decision criteria can be less than obvious when using field-based measurement technologies and is a principal discussion point for this module.
Define Acceptable Levels of Uncertainty
Setting tolerable limits on decision errors is complex, but manageable, when the type of decision and the potential risks are well defined. These limits require the planning team to weigh the threat to human health and the environment against the expenditure of resources and the consequences of an incorrect decision.
Not all environmental decisions require complex statistical analysis. Many sites, even large complex sites, are often controlled by simple realities such as cost or public perception. The good project manager needs to realize these critical points wherever they may enter the process. When confronted with these types of decisions, the simplest solution is often the correct one (a principle known as
Occam’s Razor).
Other sites require more scientific study before classical hypothesis testing is needed. Qualitative uncertainty management may be all that is required. For example, at large complex sites development of a CSM may be all that is required and classical hypothesis testing inappropriate. However, project decisions must still be made on the adequacy of the CSM or if potential pathways exist. These types of decisions require strictly qualitative uncertainty management practices, based on good science.
Most environmental professionals are familiar with classical hypothesis testing. However, simple comparisons may be misleading. For example, when performing site-to-background comparisons, statistical tests can often suggest that contaminant concentrations are elevated relative to background when in actuality distributional characteristics of the data provide insufficient information to truly make such a comparison.
Risk estimation, sampling, and analytical uncertainty confer a level of complexity on some decisions that require project managers to use values other than the default values calculated using conservative assumptions related to exposure, toxicity, or other risk-related factors. When a potential risk has been identified as potentially high and the cost of remediation is likewise high, it may be necessary to ensure through more quantitative analysis that a risk exists and at what level. Risk analysis must then be examined more carefully using more sophisticated statistical methods in terms of response, type of toxicity, and modeled concentration at an exposure point. These types of decisions require more sophisticated quantitative methods of analysis, such as are employed using Monte Carlo analysis or sophisticated geostatistical modeling.
The bottom line in most environmental evaluations is that it is nearly impossible to manage uncertainty quantitatively. Project managers should, however, attempt to weigh uncertainty and manage toward the sources that are the least certain and affect risk and cost benefit the most.
SP-10
Module: Systematic Planning
Overview
Ingersoll’s (2000) uncertainty calculator and other types of weight-of-evidence approaches can be used to assist project managers in deciding which principal sources of error deserve the greatest attention.
The three types of error associated with most environmental restorations include the following:
S Measurement Error – Measurement error is a function of the variability inherent in the analytical instrumentation and the method of analysis. Frequency and type of instrument calibration, along with the analysis of QC samples, can be used to manage measurement error.
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Sampling Design Error – Sampling design error is associated with the probability of making a correct (or incorrect) decision based on a certain number of samples arranged in one of several different ways in an attempt to collect a representative sample that can portray the true distribution of contaminants within a given medium.
Risk Estimation Error – Risk estimation error is related to estimation of toxicity type, dosage, exposure, and receptor response.
Potential total error is directly related to the ability of measurements to estimate the true condition at a site and the related risk. Sampling error is a result of fundamental error, segregation and grouping, trends or cycles, delimiting error, and preparation error. An array of literature is available that discusses management of these types of error. The reader is referred to the RCRA Waste Sampling
Draft Technical Guidance SW-846 Section Nine (July 1999, www.epa.gov/sw-846 ) for more detail on how various types of error are defined and quantitatively estimated and managed. (Also see, for example, “Environmental Analytical Uncertainty Estimation, Nested Hierarchical Approach.” Ingersoll
2001. “EURACHEM/CITAC Guide: Quantifying Uncertainty in Analytical Measurement”). The quality of results and decisions can be maintained through management of the sources of decision error.
The elements of the data quality chain shown in this figure are incomplete. A project team will need to clearly identify goals and major sources of error on a project-specific basis before an uncertainty management scheme can be selected.
Translate Project Needs into Sampling, Analysis, and Decision Making Requirements
The planning team reviews the output of the previous steps in this portion of the systematic planning process to select a resource-effective sampling and analysis design that satisfies project requirements.
The team then prepares a dynamic work plan, quality assurance project plan (QAPP), sampling and analysis plan (SAP), health and safety plan, community relations plan, and any other plans required to implement the project. The output of this step allows for a project to be implemented smoothly and efficiently. Through planning documents, the methods for translating project needs into requirements for a sampling and analysis program are established—at least until more information is obtained. They define how the uncertainty management program will allow for project decisions to be made with the level of confidence required.
SP-11
Module: Systematic Planning
Overview
EPA SP-4
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Notes:
A major product of the systematic planning process is the approved planning documents for the investigation, but systematic planning does not end there. Systematic planning continues throughout the life of the project as adjustments and refinements are made to the:
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Project team
CSM
Decision logic
Technical approach (sampling strategy and analytical methods)
QA/QC protocol
Procurement and equipment needs
Planning for Triad projects stresses flexibility and identification of contingencies, so that the field program can adapt as data are collected. The objectives, the CSM, and the technical approach of the project are continuously refined during real-time data collection and evaluation.
With appropriate planning, the project can easily adapt to unknowns as they arise without the need for major revisions to planning documents. Being able to adapt and focus project activities in an organized and controlled fashion can save time and money in the long run.
However, project teams must think out clearly all possible options that might be encountered before reaching the field. This adaptive capability should not be confused with the flexibility to do whatever seems to fit the project manager’s need at the moment. It is the opposite.
Adaptive planning and the flexibility that comes with it must be earned through communication
SP-12
Module: Systematic Planning
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Overview with stakeholders and condensing the essential decisions required at a site into a simple set of accepted operating principals. These principals act as the basic truths that will be used to guide an investigation regardless of the outcome of chemical or other types of analyses.
Some fundamental activities such as are listed in this slide are critical to the success of a Triad project. Assembling some type of multidiscipline core technical team and obtaining input from stakeholders assure that the approach is sound and addresses all concerns before planning documents are developed. A preliminary CSM also is needed early in the process that can be used as the basis for the proposed approach. A broad definition is used for Triad projects when compared with the components of a conceptual model. The model should include not only geologic and hydrogeologic information but also information on pathways and receptors, potentially applicable regulatory threshold limit, the reuse alternative planned for the, and even potential presumptive remedies. In essence, the CSM should be a summary of all that is known about the site and requirements or potential remedies, if any, that might be applicable.
A DMA is used early in the planning or implementation process to constrain field-based and or fixed-laboratory methods planned for use at a site. The DMA can include comparison of more selective analysis by a fixed-laboratory with less specific field-based technologies to establish preliminary field-based action levels. It can be used to establish the optimal sample preparation steps for use at a site or the need for method modifications to address interferences in the medium from a site.
Dynamic work strategies require project managers to manage change proactively. Decision statements must be developed on a scale that will allow field activities to be optimized and larger project decisions to be made in an orderly fashion even when unexpected conditions are discovered. Development of detailed decision logic and accepted decision criteria streamlines the document preparation, plan implementation, and reporting processes. Ultimately, this effort can result in significant cost savings, but almost always requires more upfront planning meetings and conferencing.
Data management, assessment, and presentation are at the heart of any successful Triad project. A well-organized strategy is key that describes how data will be formatted for receipt by the project team, managed they are once received, and ultimately presented. In this module, we will mention only those broad concepts for data management. The sampling module portion of this class provides a more detailed discussion of data management issues, proposed management procedures for data, the essence of a good data assessment program, and some decision support tools that can be used to present results on a real-time basis.
A procurement strategy can be developed once technologies for use at a site and potential options have been identified to respond to unknown conditions. Once again, this module provides some brief level discussions concerning this complex subject. More details can be found in an upcoming publication on the subject available now in draft form from the
Brownfields Technology Support Center (BTSC), sponsored by the Office of Superfund
Remediation and Technology Innovation that is responsible for this class material.
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Module: Systematic Planning
Project Management
EPA SP-5
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Notes:
Hazardous waste site characterization and cleanup are conducted within a variety of different organizational frameworks. Activities may be regulator-led (EPA or state equivalent) or responsible party-led (for example, voluntary cleanup programs, the U.S. Department of
Energy [DOE], and the U.S. Department of Defense [DoD] cleanups). In one instance, a single entity may handle all technical planning, contracting, and implementation, while in another case these responsibilities may be subcontracted out with varying levels of oversight and involvement by the funding organization. Whatever the case, a Triad approach assumes a base level of continuity in technical staffing among participating organizations as work progresses from systematic planning on through development and implementation of dynamic work strategies. A Triad approach will not function well when project management is built on a series of discrete steps, with products or plans “tossed over the fence” to the next subcontractor in a chain of project activities.
As a result, it may be necessary to bring contractors or subcontractors on board as part of the systematic planning process before field activities begin, so that key logistical issues and technical constraints can be identified early on in the planning process and captured in the dynamic work strategy.
Although stakeholder participation is necessary for all hazardous waste site remediation and closure efforts, it plays a particularly important role in the Triad approach. Participation is critical because of the Triad’s reliance on what may be non-standard analyses to support
SP-14
Module: Systematic Planning
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Project Management real-time decision making and its use of dynamic work strategies that often defer significant decisions to the field during data collection, remediation, or monitoring. Successful deployment of a Triad approach requires stakeholder participation not only in concurring with strategies and work plans, but also potentially with decisions that are made in the field in response to conditions and real-time results as they are encountered. This level of participation can benefit the ultimate outcome of a characterization or remediation program, since stakeholder issues with data can be addressed while field work is underway. However, it also requires a different form of interaction with stakeholders than has traditionally been the case.
Triad-based data collection programs can produce significant amounts of data rapidly.
Effective decision making based on these data presumes a means for efficiently organizing, managing, and presenting the data to decision-makers in a timely fashion. These decision-makers may be on site, or they may be physically distant from site activities. The need to provide in-field decision support is a unique characteristic of Triad-based work strategies.
The results are data management requirements that are not typically associated with more traditional field activities, where analytical data management is seldom time critical and becomes an issue only after field work is complete.
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Module: Systematic Planning
Project Management
EPA
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Notes:
One way to increase stakeholder involvement is through use of a core team that guides implementation of the Triad approach. The core team would include representatives of the responsible party, regulatory agencies, and local groups or organizations, and as well as professionals with relevant technical expertise. The purpose of the core team is to reach concurrence at key decision points as work progresses and to be on call if critical decisions are required unexpectedly during field activities. The intent of the core team is to support consensus-based decision making and streamline the cycle of document preparation, submittal, review, comment, and comment response. For core teams to be successful, participants must be committed to work through technical issues in a non-adversarial manner and to be available and engaged on an as-needed basis. Continuity in membership also is a critical component in successful core teams over the life-cycle of a project, since the team will embody a collective understanding of the technical and political basis for work done to date and proposed for the future.
There also is the assumption that members of the core team can speak for their agencies and organizations, minimizing the possibility that formal approval by agencies of proposed plans and strategies would not be obtained. The use of a core team, however, does not supercede the roles regulatory and oversight agencies play, nor does it completely eliminate the potential for an impasse to develop among stakeholders that must be resolved via more traditional mechanisms.
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Module: Systematic Planning
Project Management
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Module: Systematic Planning
Project Management
Broad categories:
» Property owners (current, past, future)
» Regulators (federal, state, local)
» Community and other interest groups
Identified by:
» Reviewing site history, planned future use
» Understanding the community and history of community involvement
» Assessing the regulatory setting
…Look at similar sites and projects
EPA SP-7
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Notes:
Early in the planning process, the project technical lead should make an effort to identify community interests, potential stakeholders, and their perspectives. It is crucial to identify potential concerns, conflicts, and roadblocks early in the process. Concerns identified later in the process could significantly delay project implementation or site closure.
Stakeholders include all who are involved in making a meaningful contribution to a project.
EPA’s “Terms of Environment” ( http://www.epa.gov/OCEPAterms/ ) defines a stakeholder as
“Any organization, governmental entity, or individual that has a stake in or may be impacted by a given approach to environmental regulation, pollution prevention, energy conservation, etc.”
Concerns and ideas of stakeholders should be considered during the entire project to contribute to efficient progress toward site closeout. Some potential stakeholders include:
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Project technical lead
Customer
Current property owners
Government agencies
Restoration advisory boards
Several suggestions for project teams that are attempting to identify stakeholders and potential community concerns are listed below:
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Project Management
Consider the surrounding community and existing community groups in identifying stakeholders
Review the history of the site to identify potentially responsible parties
Consider the future of the site to identify future users, owners, or investors who will have an interest in site closure
S Review participation by the regulatory community in other field programs to identify additional potential stakeholders
Once stakeholders are identified, setting up a forum for public education and participation is the next step. Community outreach can include anything from posting information on an agency website or community bulletin board to holding public meetings. Effective methods for ensuring public and stakeholder involvement include fact sheets, roundtables, constituency meetings, information-gathering sessions, and websites. As with decision makers, stakeholders may be assisted by technical support staff or contractors. Stakeholder support staff should be included as appropriate in the organizational communication structure.
EPA has developed a strategy for facilitating successful stakeholder involvement and public participation in environmental field programs as described in the January 2001 document titled,
“Stakeholder Involvement and Public Participation at the USEPA”
( http://www.epa.gov/publicinvolvement/pdf/sipp.pdf
). Five “lessons learned” by EPA in development of this strategy are summarized in Table 4.1.1. Project teams also should be mindful of the unique composition and dynamics of the stakeholder group. The project team should assess how the group learns best to best educate and communicate with the audience.
Obviously, meetings should be advertised and hosted at times that are most visible and convenient for the community. If public participation seems to decline, it is important for the project team to evaluate why and possibly restructure its approach. Perhaps increasing the capacity of the citizens to learn through use of varied educational tools and media will improve public participation. Allotting time and resources to these community and educational activities can reap benefits in increasing the level of meaningful dialogue and consensus among the stakeholder groups. If there is no backing from the decision makers and project team for outreach initiatives, however, tools and ideas will be limited and the level of public understanding and support may be lower. Additional information on stakeholder and community involvement can be found on the website of “EPA's Office of Policy, Economics and Innovation” ( http://www.epa.gov/opei/pubsinfo.htm
).
EPA has identified five lessons crucial to stakeholder involvement and public participation initiatives (EPA 2001a); these lessons are valuable for all types of stakeholder involvement and may be adapted to other environmental programs.
SP-19
Module: Systematic Planning
Project Management
S Lesson 1 – Help the public and stakeholders trust the government agencies involved.
Realistically, the amount of time needed to build this trusting relationship can be lengthy, perhaps stemming from historically unstable relationships between the public and the government agencies, or possibly from statutory or regulatory limitations. If it is limited in the beginning, there are ways to nurture the public’s trust. For example, being proactive and meeting with the community early to address its concerns show the community that it will be valued in the decision. Maintaining a presence in the community and openly sharing information show the public that the decision maker wants to learn from the community and vice versa. By keeping communication open, the community will realize that the agency is approachable.
S
S
S
S
Lesson 2 – Provide credible data and technical assistance to the public. Both are crucial to encourage the public to participate. If the community feels that the data are contradictory or confusing, trust in the decision maker will diminish. Frequently, the community will contract an outside source to evaluate whether the data can be reproduced or to check validity. Groups and communities that lack the technical background needed for understanding an issue will rely on the outside source for a second opinion. Increased access to technical experts will enable these non-technical groups to interpret data and reports and understand the technical issues of the site.
Furthermore, the technical advice will allow the groups to interact with the decision maker more clearly and convey their concerns effectively.
Lesson 3 – Foster integration of the community’s environmental, economic, and social concerns. This integration will permit the decision maker to collectively learn more about the community, the quality of life, and the environmental concerns. By researching community health, demographics, cultural resources, and religious and historical sites, the decision maker can only enhance his understanding of the impacts on the community.
Lesson 4 – Become an expert in the stakeholder involvement and public participation processes. The technical team and technical staff facilitating these programs need to know the background of these methods and how to apply them correctly to effectively address the needs of the public. The stakeholders and public will be the first to assume that the information is not credible, thus bringing down the level of trust. Outside expert assistance may be required if training is not available to technical staff. In addition, bringing in a local resident who is experienced in community outreach may be beneficial.
Lesson 5 – Understand the factors that can limit participation from the stakeholders and the public. For instance, people may feel intimidated by the technical discussions and that they will not contribute anything substantive to the plan. Moreover, members of the public may feel that they lack the amount of time needed to participate in the decision, or that there is no important issue. Furthermore, inadequate explanations of
SP-20
Module: Systematic Planning
•
•
•
•
S
Project Management background and technical material or overwhelming amounts of information are enough to cause the public to lose interest. Many members of the community may distance themselves from the issue based on historical, social, or cultural reasons.
•
Here are some additional community outreach and public involvement resources:
RCRA
“Enhanced Public Involvement”
( http://www.epa.gov/epaoswer/hazwaste/permit/pubpart/index.htm
) – The RCRA
Expanded Public Participation Rule promotes partnership, empowerment, and flexibility in the RCRA permitting field program.
S “Public Involvement” ( http://www.epa.gov/epaoswer/hazwaste/ca/pubinvol.htm
) –
This page provides links to information about public involvement.
CERCLA
S
S
“Cleanup Enforcement - Superfund - Getting Involved”
( http://www.epa.gov/compliance/cleanup/superfund/-getinvolved/index.html
) –
This web page describes how the public can become involved in EPA decisions on how to study and clean up hazardous waste sites.
“Superfund Public Involvement Toolkit” ( http://www.epa.gov/superfund/tools/ ) – The tool kit was initiated in 1998 to provide a forum for more and better coordination of community involvement activities at Superfund and other hazardous waste sites.
A general challenge with stakeholder involvement is usually many divergent interests are involved. It may be necessary to involve an experienced facilitator in contacting and negotiating with stakeholder groups; otherwise, all interests may not be represented fairly. Continued participation of high-level decision makers is also crucial to help maintain the involvement of stakeholders. Without high-level participation, other stakeholders may feel that the decision makers are not serious in addressing their concerns and reaching consensus.
Projects and project teams are successful when the stakeholders on the project are satisfied.
Therefore, identifying the correct and complete list of stakeholders is the first priority in moving a project forward. Key stakeholders will make all of the important decisions during the project.
As a result, identifying people or entities that will have the greatest influence and authority is the first step in project planning.
Community involvement and public relations are key elements during all phases of a project. A good example of their importance is the requirement for community involvement in cost recovery under the National Oil and Hazardous Substances Pollution Contingency Plan (NCP).
SP-21
Module: Systematic Planning
Project Management
NCP is the federal government’s blueprint for responding to releases of oil and hazardous substances. Under these programs, the earlier stakeholders are involved in the project, the better. For example, a common mistake in project planning is to defer soliciting community feedback until the remedial investigation and feasibility study (RI/FS) project phase. Under the
NCP, this omission often prevents the responsible party from being eligible to recover costs.
The NCP requires that public comment be solicited throughout all phases of the project and be meaningful. In other words, the project team must consider or incorporate public comments, to the extent possible, into a project. For larger projects, it is common to hire a public relations firm to aid in soliciting and documenting public involvement. For more information on the NCP, check out the “National Contingency Plan Overview for EPA's Oil Program”
( http://www.epa.gov/oilspill/ncpover.htm
).
Module: Systematic Planning
SP-22
Project Management
EPA SP-8
•
•
Notes:
The first priority of a project technical lead will be to identify a team of decision makers. Early identification is necessary because this team will be involved in and integral to the entire project.
Decision makers can include the responsible party for the site (also termed the owner, client, or customer) and regulatory authorities (Federal, state, and local). Stakeholders such as citizen groups, property buyers and developers, and other interest groups also should be included as decision makers as well.
Each decision maker has an interest in the outcome of activities related to the field program.
The project technical lead should address the concerns of decision makers as early as possible in the planning process. These concerns are best addressed by ensuring that the rationale for each activity is clearly explained: What is this activity supposed to accomplish? What specific project decisions or goals will this activity support? How does it do that? Identifying and resolving confusion or conflicts early will allow decision making to be streamlined and accelerated during implementation, the stage of the project where delays are most costly and disruptive.
SP-23
Module: Systematic Planning
Project Management
EPA SP-9
•
Notes:
As with the decision making team, effective organization and communication among members of the core technical team will expedite program implementation. Some factors to consider in organizing the core technical team are summarized below:
S
S
Clear roles – as with any team, it is imperative that each member of the core technical team understands his or her role on the team and in the project. Roles may vary in extent and duration.
Core team continuity – as with the decision making team, some changes may be inevitable. To the extent possible, a consistent core team will enhance the effectiveness of the program.
S
S
Multidisciplinary perspective – as discussed above, the core team should represent program perspectives and disciplines without becoming unwieldy in size. In particular, the end use of data and the needs of the data users must be addressed during project planning. Individuals who are adequately cross-trained and experienced in various disciplines may serve more than one role for some projects.
Quality assurance – the core team must include technical experts who can assess and assure quality in multiple areas: data, decisions, regulatory compliance, end-use, and so forth.
SP-24
Module: Systematic Planning
•
S
S
S
S
S
S
Project Management
Long-term (core) versus short-term members – on complex projects, it may be appropriate to include specialists on the core team only during specific periods. All members should understand the extent and duration of their roles.
S Communication – clear lines of communication must be defined within the team, between the core team and decision makers, and between the core team and support staff or consultants.
The Triad core team should include stakeholders and engage them in the decision making process. A successful Triad project team requires:
A non-adversarial approach to problem solving
Decision makers and technical experts who are available and engaged on an as-needed basis
Continuity in team membership over the project life cycle
Ability of team members to speak for the organizations they represent
Decision makers who are not overly averse to risk
SP-25
Module: Systematic Planning
Project Management
Changes in decision makers
Increased involvement of regulators and decision makers
Greater decision making power to:
» Technical staff
» Contractors
Scheduling and “load balancing”
Contract and cost management
EPA SP-10
•
•
•
Notes:
It is likely that the makeup and personnel of the decision making team will change during longterm or complex field programs. Therefore, it is critical that all decision makers anticipate, prepare for, and respond to changes within the team. Changes are likely to occur when new stakeholders are identified, representatives of groups, companies, or agencies change, or new responsible parties are identified.
Decision makers can ease these transitions by thoroughly documenting all decisions and the rationale used to make decisions, as well as revisions to planned activities and the reasons for the revisions. When new members join the team, it is imperative that they come up to speed quickly to minimize project delays and make an effort to understand and honor previous agreements. New team members should also be open to the Triad Approach and be prepared for the potential increased workload and involvement required at times for such an approach.
The field program can continue to operate efficiently if new decision makers understand how the field program came to be so that old conflicts or decisions do not require renegotiation.
Several layers of decision making can take place within a Triad-based field activity. The first layer includes relatively straightforward decisions that are the responsibility of field team leads.
These typically are decisions associated with conditions anticipated by the work plan or that are relatively inconsequential (such as, moving a sampling location several feet to avoid an obstruction). The second layer covers decisions that are more significant and that require consultation with and direction from senior project leads who may or may not be on site. These
SP-26
Module: Systematic Planning
•
Project Management second-level decisions typically also require some additional level of technical input (for example, from an analytical chemist if there are concerns about measurement system performance). The third layer covers decisions that can only be made at the level of a Triad core group (for example, determining whether closure has been achieved for specific portions of a site). The needs for decision support at each layer are distinctly different. For example, in the last two cases, information must be expeditiously shared with personnel who are not necessarily present at a site.
The concept of load balancing, which is intimately related to scheduling, also is important to the
Triad. The concept is simple: matching analytical capacity to sample production and throughput in a manner that optimizes the overall characterization or remediation program.
Optimization here means achieving confident decision making at the lowest overall project costs. The importance of load balancing lies in the fact that analytical over-capacity (under utilized analytical capabilities) is a waste of project resources (since for most real-time measurement systems, per sample cost is a function of sample throughput), while analytical under capacity can result in project delays or time-critical decisions that are made without the requisite supporting data. Ways to promote effective Triad scheduling and load balancing include: (1) rotating data collection and analysis activities and decision making among different areas or tasks at the site; (2) staggering work assignments within a work day to support a regular decision turnaround (for example, 24 hours); and (3) providing for overflow sampling or analytical capacity that can be used if required.
SP-27
Module: Systematic Planning
Conceptual Site Models
EPA SP-11
•
•
Notes:
EPA guidance on preparing scoping documents under the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) requires development of a site conceptual exposure model (SCEM) as a planning tool for public health and ecological risk assessments. The Resource Conservation and Recovery Act (RCRA) corrective actions also require risk assessments to evaluate the potential impacts to public health and the environment.
To streamline this process, the DOE Office of Environmental Policy and Assistance,
RCRA/CERCLA Division (EH-413), created the SCEM Builder, a user-friendly computer application to assist environmental restoration program managers (ERPMs) in preparing
SCEMs. SCEMs are used as a planning tool during the environmental site investigation phase to allocate finite financial and personnel resources to address data gaps and identify sources of contamination, release mechanisms, exposure pathways, and human or ecological receptors.
The SCEMs include a visual presentation of site conditions and provide a narrative description of the assumptions used in the model. The ERPMs can use the information in SCEMs to develop data quality objectives (DQOs) for risk assessment and prioritize field sampling activities, thereby reducing the uncertainty associated with risk characterization.
Several characteristics of CSM development and application are important from a Triad perspective.
S A project’s CSM may take any (or several) of a number of formats that can effectively portray concerns significant to the decisions that must be made. Formats are typically
SP-28
Module: Systematic Planning
S
S
Conceptual Site Models specific to the decision need. For example, a CSM early in the site assessment process may simply be a schematic drawing that indicates primary areas of concern along with accompanying text that describe the basis for concern for each area, along with any supporting information (such as, photographs, interview information, site observations, descriptions of process or infrastructure, or potentially pertinent regulations or regulatory guidelines). As a site moves to the equivalent of a remedial investigation and on to remediation, the CSM could include a fate and transport model (numerical or analytical); a pathways analysis to support risk evaluation, if required, along with a supporting risk or dose model; a spatially correct electronic map of the site that incorporates pertinent contextual features such as roads, fence lines, building footprints, aerial photos, existing analytical data, pertinent infrastructure, and topographical information; a subsurface stratigraphic model; and a statistical model of where contamination is believed to exist at levels of concern based on past sampling results.
A project’s CSM will evolve and mature as project work progresses. This evolution reflects both the level of site understanding at any point in time and the amount of information and complexity of analysis required to support the decisions that must be made at any time. For sites with a long-term life cycle (where the characterization, remediation, and closure process will be measured in years), continuity in maintaining the CSM and carrying it forward as it evolves and matures becomes a critical management issue. The problem is two-fold. First, supporting technical contractors often prefer certain software systems for developing and maintaining CSMs. These systems may include proprietary components. It is extremely important that project managers identify specifications and deliverables for the CSM that will facilitate maintenance of the CSM even if contractors change. These specifications can include identifying early on the spatial coordinate system that will be used for all data sets produced and delivered (such as, State Plane feet NAD83), the base mapping system to be used (such as, AutoCad, ArcView, MapInfo), and electronic data deliverable
(EDD) formats for all analytical data. The second issue is staff related. A CSM is an electronic or hard copy snapshot of site conditions that is a reflection of the understanding of core team members. Loss or replacement of core team members over the life of a project, while at times unavoidable, can have significant impacts on maintenance of the CSM.
A complete and accurate CSM not only captures what is known about the site, but also supports the evaluation of the uncertainty associated with decision making based on the information currently available. Uncertainty may be addressed in a qualitative fashion, using a weight-of-evidence approach, or it may be more quantitative, using statistical techniques and statistical concepts. This evaluation of uncertainty is an extremely important point of concurrence for the Triad project team. As a result of an uncertainty evaluation, a decision can be made based on existing information as embodied in the
CSM. Alternatively, the result may identify data gaps that, if addressed by additional data collection, would allow decision making to go forward.
SP-29
Module: Systematic Planning
Conceptual Site Models
S Where the level of uncertainty is unacceptable, the CSM should provide the foundation for developing information-gathering programs to reduce decision making uncertainty to acceptable levels. The CSM should lead to hypotheses or statements that are
“testable” or verifiable via data collection (for example, “contamination levels within a decision unit do not satisfy cleanup requirements”). From a Triad perspective, the
CSM should support a dynamic work strategy for resolving these uncertainties. This approach inherently assumes that the CSM can and will be updated and refined as activities that are part of the dynamic work strategy produce new information.
Module: Systematic Planning
SP-30
Conceptual Site Models
Concise depiction of a site and its issues
» Usually involves visual representations
» Provides a mechanism to communicate key site features
Presents hypotheses about:
» Types of contaminants - SOURCES
» Routes of migration - PATHWAYS
» Receptors, exposure routes - RECEPTORS
EPA SP-12
•
•
•
Notes:
The CSM is a description of the site and its environment that is based on existing knowledge.
The CSM should be described in a narrative and depicted in both graphical and tabular forms.
The depiction of the site and its environment is used to form hypotheses about the release and the ultimate fate of contaminants at the site. A complete CSM network (source-pathwayreceptor) indicates a connection between a source of a contaminant and a potential receptor and that actual or potential risk exists. The CSM indicates the data gaps that the site characterization process must fill to determine whether complete CSM networks exist.
It is important to identify all possible sources, pathways, and receptors so that they can be incorporated into the site characterization process.
The CSM describes sources of contaminants at the site. Sources of contaminants may be primary, such as waste lagoons, or secondary, such as soil contaminated by waste lagoons.
The CSM identifies the types of sources, as well as the types of contaminants generated from these sources. The type of contaminants of concern affect the evaluation of both migration pathways and exposure routes.
The CSM describes how contaminants may be migrating from the sources at the site. The migration routes commonly are known as pathways. The CSM follows the contaminants released from the sources through all available pathways, such as groundwater, soil, surface water, and air. The CSM then evaluates where the pathways might lead. It is especially important that the CSM include a detailed geologic and hydrologic model of the site that
SP-31
Module: Systematic Planning
•
•
Conceptual Site Models identifies all data gaps that must be addressed, since the fate and transport of contaminants in groundwater depend on the hydrology of the site.
The CSM describes all the potential receptors and exposure routes and the contaminant migration pathways. The likelihood of exposure can be evaluated as part of the CSM. The actual and potential human and environmental receptors are identified. In addition, all routes of exposure (ingestion, inhalation, and direct contact) are examined. The description of each receptor is specific to the site in question. Receptors may include workers at the site, nearby residents, trespassers, and terrestrial and aquatic animals and plants.
The CSM presents the actual and potential source-pathway-receptor networks at a site. The site characterization must be designed to determine whether the hypothetical networks identified in the CSM are complete. Doing so requires collection and evaluation of data on types of contaminants and volumes of contaminants (source information), fate and transport of contaminants (pathway information), and the environmental setting and nearby populations
(receptor information). In many cases, the CSM will show that potential networks are not complete and that there is no link between the source and the receptor. To document that incomplete networks were evaluated and considered, it is important that the CSM include them. As site characterization progresses, the information gathered for the CSM increases the understanding of source-pathway-receptor networks at the site. A mature CSM provides an accurate picture of all potential and actual source-pathway-receptor networks. The site characterization effort provides the necessary information to develop such a mature CSM.
The CSM guides the entire characterization process. All new data collected during the characterization process are used to update and refine the CSM. Therefore, the CSM represents the core of the site characterization process and is ultimately used to decide whether remedial action is required.
Module: Systematic Planning
SP-32
Conceptual Site Models
Exposure point
Release mechanism
(volatilization)
Transport medium
(soil)
Waste
(Source)
EPA SP-13
•
Notes:
This graphical illustration is a simplified CSM. It depicts the sources, pathways, and receptors at a site. This format is most useful for planning and implementing field sampling activities.
More detailed and complex graphical illustrations of the hydrology of the site should be developed to provide a better understanding of the groundwater pathway.
SP-33
Module: Systematic Planning
Conceptual Site Models
EPA SP-14
•
•
•
Notes:
The “Standard Guide for Developing Conceptual Site Models for Contaminated Sites”
(E 1689-95) prepared by ASTM International, provides an outline of a CSM. The outline includes a narrative description of the CSM, accompanied by photographs, maps, figures, and tables. The narrative description should include a brief site summary that focuses on information about sources, pathways, and receptors. A brief description of current conditions at the site should be included. The narrative description of the site should be accompanied by a standard 7.5-minute U.S. Geological Survey (USGS) topographic quadrangle map or geologic quadrangle map, or both, that shows the location of the site.
The historical information should focus on events and activities that affected current environmental conditions at the site. All information about the use of the site, any waste that may have been disposed of there, and other waste management practices that may have affected the environment should be presented.
The source characterization portion of the narrative should identify and define the location, size, and condition of the sources of contamination at the site. Figures and maps should be used to identify the location of all sources of contamination. Multiple CSMs, one for each set of differing source-pathway-receptor networks, may be needed at large sites with diverse geologic and hydrogeologic setting. Both primary and secondary sources of contamination should be identified. Many CSMs also identify the release mechanisms for primary and secondary sources.
SP-34
Module: Systematic Planning
•
•
Conceptual Site Models
All migration pathways should be identified. Migration pathways are the routes contaminants can take as they migrate from the source through the environmental media. All potentially affected environmental media should be evaluated — soil, groundwater, surface water, sediment, and air. The food chain should be evaluated, as well. A migration pathway also may be a secondary source of contamination. For example, soil may become contaminated by a surface impoundment. In such a circumstance, the soil is a migration pathway and a secondary source of contamination of groundwater. Maps, figures, and cross-sections should be used to depict the migration pathways in relation to the sources and the potential receptors. It is especially important to identify all data gaps associated with the hydrology of the site.
Current and future human and ecological receptors should be identified and located on site maps. Care should be taken to identify sensitive populations, such as children or the elderly.
The migration pathways and sources that place or might place the environmental receptors at risk should be discussed. The routes of exposure to receptors also should be identified.
SP-35
Module: Systematic Planning
Conceptual Site Models
Primary
Sources
Drums and
Tanks
Lagoon
Structures,
Drums,
Tanks,
Lagoon
Primary
Release
Mechanism
Spills
Infiltration/
Percolation
Overtopping
Dike
Secondary
Sources
Soil
Secondary
Release
Mechanism
Dust and/or
Volatile
Emissions
Infiltration/
Percolation
Storm
Water
Runoff
Pathway
Wind
Groundwater
Surface
Water and
Sediments
Receptor
Human Biota
Exposure
Route
Ingestion
Inhalation
Dermal
Contact
Ingestion
Dermal
Contact
Ingestion
Inhalation
Dermal
Contact
Ingestion
Inhalation
Dermal
Contact
Dermal
Contact
EPA SP-15
•
Notes:
This slide shows a tabular CSM. This presentation format is most useful for planning and conducting the baseline human health risk assessment and for identifying complete and incomplete source-pathway-receptor networks. Similar CSMs also can be developed for ecological risk assessments, but they may be more complex than this example because they include numerous types of receptors, such as fish, birds, mammals, and invertebrates.
Module: Systematic Planning
SP-36
Conceptual Site Models
EPA SP-16
•
•
Notes:
EPA’s October 1988 “Guidance for Conducting Remedial Investigations and Feasibility
Studies Under CERCLA” presents a methodology for characterizing sites and evaluating remedial options under the Superfund program. The 1988 guidance revised and significantly improved the information presented in the 1985 RI/FS guidance. Because it preceded many of the advances in field-based technologies, it provides a conventional approach to site characterization. Although EPA’s RI/FS guidance still is valid and useful, the site characterization it presents should be adjusted to accommodate field-based characterization technologies. EPA’s RI/FS guidance first identifies the CSM in the chapter on scoping the
RI/FS. The guidance identifies 10 steps in project planning. The CSM is included in Step 2, collecting and analyzing existing data. The guidance states that “information on the waste sources, pathways, and receptors at a site is used to develop a conceptual understanding of the site to evaluate potential risks to human health and the environment.”
The CSM has been used to identify gaps in information about sources, pathways, and receptors. Under the conventional approach to site characterization, a plan (specifying sampling locations and types of samples) was developed to collect data to fill the information gaps identified through the CSM. In addition, the CSM has been used to identify remedial technologies that might be necessary to address the sources, pathways, and receptors identified in the CSM.
SP-37
Module: Systematic Planning
•
•
Conceptual Site Models
Conventional site characterization, with its heavy reliance on validated laboratory data from an off-site laboratory followed by preparation of reports, separated data collection from data evaluation by 3 to 9 months. A great deal of time thus elapsed between creation of the CSM and its revision. During that time, the members of the technical team may have changed, or the technical team may have lost its focus on the site.
The technical team that developed the CSM typically was not the team that collected the data.
Therefore, the gap between the personnel in the field and familiar with the data collection process and the personnel interpreting the data created a less efficient overall understanding of the problems at the site.
Module: Systematic Planning
SP-38
Conceptual Site Models
EPA SP-17
•
•
•
Notes:
Under accelerated approaches to sampling and analysis, the CSM is the essential framework for evaluating the importance of information and of the activities that make up the investigative effort. All activities, including measurement, analysis, and integration of data, should have direct, logical connections to the CSM. Any activity that is related only vaguely to the CSM
(that is, to the effort to determine whether source-pathway-receptors networks are complete) should be questioned. An example of a data collection activity that is only vaguely related to the CSM is the installation and sampling of groundwater monitoring wells before a thorough understanding of the site’s hydrologic CSM has been developed.
Accelerated approaches to sampling and analysis involve the continual updating of the CSM with data that are collected and evaluated in the field by highly skilled and experienced technical professionals. Under accelerated approaches to sampling and analysis, the goal is to achieve a full understanding of the CSM.
The CSM also can serve several supporting roles in the implementation of a Triad approach.
These include educating stakeholders, identifying required technical expertise, screening applicable analytical or characterization technologies, refining project strategies, identifying potential regulatory drivers, selecting points of compliance, estimating dose or risk and deriving risk or dose-based cleanup criteria, evaluating and implementing remedial alternatives, and supporting site close-out.
SP-39
Module: Systematic Planning
Conceptual Site Models
Huge operating air weapons stations with 100’s of potential sites located in the Owens Valley, California
An oversimplified CSM had lead the project team to focus on the central portion of the facility where water use from the nearby town was suspected to be drawing contamination into the water supply
The revised CSM showed the central portion of the site was protected by 900 feet of clay and was not likely contributing to the increased TDS in the water supply
The revised CSM was used to redirect water use nearer to the Sierra Nevada and prioritize site investigation activities near the edges of the clay plug
EPA SP-18
Notes:
Module: Systematic Planning
SP-40
Notes:
Conceptual Site Models
SIERRA
NEVADA
MOUNTAINS
RECHARGE
ARGUS
RANGE
CHINA
LAKE
EPA SP-19
SP-41
Module: Systematic Planning
Conceptual Site Models
Notes:
EPA SP-29
Module: Systematic Planning
SP-42
Notes:
Conceptual Site Models
EPA SP-21
SP-43
Module: Systematic Planning
Demonstration of Methods Applicability
Background data sets
Risk-based criteria (MCLs, PRGs, AWQC)
Other regulatory thresholds (RCRA waste limits, TSCA)
Site-specific criteria developed through:
» Risk assessment
» Modeling
» Cumulative or indirect criteria
Nuances in applying criteria
EPA SP-22
•
•
Notes:
An action level or concentration limit is a specified threshold that prompts a decision maker to select among various alternative actions. Generally, analytical or testing results are compared with an established action level to evaluate whether it has been “exceeded.” A level that is exceeded implies that further investigation, remedial action, treatment, containment, or some other form of risk management may be needed. (The word “exceed” can have different meanings for different data collection activities and hence must be carefully defined by the project team, as discussed later).
Action levels vary depending on the stage of a project. For example, results at early stages may be compared with very conservative (protective) levels such as screening action levels
(SALs), preliminary remediation goals (PRGs), maximum contaminant levels (MCLs), ambient water quality criteria (AWQC), or protective concentration limits (PCLs). If the CSM shows that contaminant concentrations are below these levels, the decision may be that no further action will be required since the likelihood of excess risk to human or ecological receptors is small. On the other hand, if the CSM indicates that contaminant concentrations exceed a conservative threshold, more intensive sampling will be necessary to evaluate whether risk actually exists. At later stages of a project, site-specific action levels may be developed based on the risk assessment.
Module: Systematic Planning
SP-44
•
•
•
Demonstration of Methods Applicability
Action levels are not needed for certain situations. For example, to evaluate whether an “on site” area has been contaminated with respect to a “background” area, the action level is regarded as a concentration based on the background sample data. Other cases include situations where a release or the presence or absence of certain chemicals should be identified.
In these situations, process knowledge, visual examination, observation of abandoned barrels, containers, or other discarded receptacles that contain hazardous wastes may substantiate the presence of wastes without sampling or comparison to action levels.
It is also critical to verify that the analytical method can achieve the detection or quantitation limits required. If all results are nondetect but the quantitation limit is above the action level, then it is not possible to conclusively determine whether contaminants in the waste are at concentrations above or below the action level. Furthermore, the sum of the quantitation limits should be considerably less than the sum of the action levels if several contaminants of concern
(COCs) are being used in a risk-based scenario. Otherwise, results for all sample locations may exceed the risk-based action level simply by virtue of high quantitation limits.
Whereas some decision criteria are mandated by regulations, project statekholders must carefully select criteria for many site characterization and remedial decisions on the basis of site-specific considerations, including the environmental medium investigated. An important aspect of the Triad is exploring the possibility of identifying site-specific action levels, based on exposure scenarios and remedial or reuse issues of interest that can be applied with field-based methods for real-time decision making.
SP-45
Module: Systematic Planning
Demonstration of Methods Applicability
Project team must assess what data will best support decisions:
» Sample support – size, shape, and orientation
» Sampling:
—
Statistical vs. judgmental
—
Soil gas, nonintrusive, direct push, surrogates, other
» Analytical method requirements – analytes, detection limits, data quality
» Other practical information
EPA SP-23
Notes:
•
•
Most projects will involve a series of different, but possibly interrelated, project decisions.
CSMs are used to understand site conditions in the context of the decisions to articulate the information gaps that need to be filled to manage decision uncertainty. A summary of the general tools applied to address data gaps and manage uncertainty throughout the site cleanup process is presented in the table, “ Environmental Decisions and Decision Support for
Managing Uncertainty ”.
Once the need for data has been identified, the type and density of information should be considered. The more the decisions and existing conditions at the site can be refined, the more likely it is that the data collected will match the intended use. In the CSM module (Aztlan case study), we examined how differing forms of data are funneled into the CSM. Techniques such as geophysics and modeling were introduced as ways to focus data collection. The key to identifying and filling data gaps creatively is to match the scale of data collection to the decision that must be made. This match may not be possible under many circumstances unless innovative site characterization tools are considered. For example, the source material at dense nonaqueous phase liquid (DNAPL) sites can be broadly dispersed in hard-to-find pockets. In simple as well as complex geologic settings, characterization to support remedy selection and costing can be difficult. Only through the use of direct-push methods and collaborative geotechnical tools is it sometimes possible to achieve project goals economically. Examining existing data sets for a site using accepted statistical approaches and available planning tools
( DEFT, VSP, SADA, FIELDS ) can assist project teams in assessing the scale of data collection.
SP-46
Module: Systematic Planning
•
•
Demonstration of Methods Applicability
Until recently, available tools and best practices were insufficient to assure that results obtained were representative of a certain environmental condition. Often, the environmental condition was so complex that it was virtually impossible to collect sufficient data to assure representativeness. With the advent of field-based methods and real-time measurement technologies that can provide nearly continuous downhole measurements, scientists are finally able to begin tackling sampling-related uncertainties in an economically viable way.
Although variability within the laboratory cannot be ignored, sampling variability is the primary source of decision uncertainty for many types of environmental projects. This understanding is driving environmental professionals to take a closer look at the use of different methods that can help manage overall data uncertainty when data are used for decision making. As mentioned previously, sample support, sampling strategy (such as discrete versus composite samples), and the density of data points (usually improved by using field-based methods) are being examined more closely in an attempt to improve the representativeness of results used in decision making.
(The concepts “sample support” and “representativeness” are discussed in more detail later in the module.) Organized approaches to estimating and managing sampling and analytical uncertainty are also emerging. As they become available, EPA is continuing to develop case studies and technology profiles of new methods for managing uncertainty and assuring the representativeness of data to meet project decision making needs.
SP-47
Module: Systematic Planning
Demonstration of Methods Applicability
Which sample support provides a sample that represents atmospheric deposition from a smelter?
Right answer requires understanding the nature of the release (CSM) and the decision to be made.
EPA SP-24
Notes:
•
•
Sample support is a concept that encompasses the physical properties of samples, such as the particle sizes that make up a solid sample and a sample’s dimensions (the volume [size], shape, and orientation). Because of the heterogeneous nature of environmental media, the sample support is a critical aspect of representativeness. An inappropriate sample support will produce misleading data that are inappropriate for decision making. Appropriate sample supports are selected with the assistance of the CSM.
If a project technical lead examines each element of a sampling and analysis program to the level necessary during systematic planning, the appropriate sample support and decision support will appear obvious. For example, refer to the illustration on this slide. Suppose a project requires evaluation of impacts to surface soil from airborne deposition of lead from a smelter. The preliminary CSM considers historical site information, deposition models, data from similar sites, and other information as necessary to identify the soil media of interest for the project. The dark surface layer in the figure is the soil the CSM indicates is affected by atmospheric deposition. The “decision support” then is the location and physical dimensions
(area and thickness) of the surface layer of interest. The goal is to collect samples that are representative of that layer. Which sample support (the white areas #1, #2, or #3) provides a sample that is representative of atmospheric deposition for this site? (Keep in mind that the entire sample is homogenized before it is subsampled for analysis.) The answer is that the sample support (the physical dimensions of the sample) for Sample #1 would be representative of the matrix affected by atmospheric deposition, but the sample supports of samples #2 and #3 would not be.
SP-48
Module: Systematic Planning
•
•
Demonstration of Methods Applicability
Sample #3 in particular illustrates the importance of strict control over sample support in scenarios where careful stratification of populations is required to avoid biasing results by including non-representative material. Even though the general orientation of sample collection in #3 is similar to #1, the concentration of lead in sample #3 might be expected to be diluted by the inclusion of “cleaner” soil from a non-representative layer into the sample. When project staff clearly understand the decisions the data are intended to support, the proper choice of sample support, as well as sample collection tools and procedures, becomes much more straightforward.
Sample support will be discussed in more detail later in this module, as well as in the module on
Sampling Design. The volume, number, and processing (such as, compositing, sieving, or grinding) of samples will be examined as they relate to designing an analytical program or deciding on a sampling scheme. Decision support (the area or volume and orientation of the decision unit) and chemical characteristics can dictate the sample support needed to assure the defensibility of project decisions. Statistical methods can assist project technical leads in assigning the spatial dimensions and configuration of the decision unit.
SP-49
Module: Systematic Planning
Demonstration of Methods Applicability
Sample size, shape, orientation
Sample processing protocols
» Composite
» Homogenized or discrete
» Sieve
» Dry
» Filter
Analytical sampling and subsampling requirements
EPA SP-25
•
Notes:
The project team must ask whether any of the following can be managed differently to limit variability in the data to the degree possible to improve decision certainty. If the answer is yes, then the variable must be managed more aggressively by changing the sample support.
S
S
S
S
S
S
S
S
S
Sample and subsample particle size
Sample and subsample volume
Sample and subsample collection technique
Homogenization technique
Analytical preparation method
Analytical cleanup method
Analytical or method
Reporting or data storage technique
Mapping or interpretation technique
Module: Systematic Planning
SP-50
Demonstration of Methods Applicability
Soil Grain Size
(Standard Sieve Mesh
Size)
Soil Fractionization (%)
Pb Conc. in fraction by
AA (mg/kg)
Lead Distribution
(% of total lead)
Greater than 3/8” (0.375”) 18.85
10 0.20
Between 4-mesh and 3/8” 4.53
50 0.24
Between 4- and 10-mesh 3.65
108 0.43
Between 10- and 50-mesh
Between 50- and 200mesh
Less than 200-mesh
11.25
27.80
165
836
2.00
25.06
33.92
1,970 72.07
Totals 100%
927
(wt-averaged)
100%
Adapted from ITRC (2003); see http://www.itrcweb.org/SMART-1.pdf
EPA SP-26
•
Notes:
The concentration of lead at small-arms firing ranges can vary with particle size.
Source: Interstate Technology and Regulatory Counsel (ITRC). 2003. Characterization and
Remediation of Soils at Closed Small Arms Firing Ranges . January. Available on-line at http://www.itrcweb.org/SMART-1.pdf.
Size conversions:
•
3/8” = 0.375 in. = 9.525 mm
ASTM nominal aperture mesh size (mm):
4-mesh = 4.76 mm
10-mesh = 2 mm
50-mesh = 0.297 = 0.3 mm
200-mesh = 0.074 mm
A technical white paper that discusses the development of demonstrations of methods applicability for XRF at small arms firing ranges is available on the BTSC’s website at
Brownfields.org. This paper discusses project planning decisions and sampling strategies in some detail for a project in Blufton, South Carolina.
SP-51
Module: Systematic Planning
Demonstration of Methods Applicability
Consult with experts in assessing data quality
Remember practicality criteria
» Cost
» Sample throughput and turnaround
» Degree of complexity
» Compatibility with site facilities, conditions
» Portability and ruggedness
» Comparability with other methods
EPA SP-27
•
•
Notes:
It is important that suitable technical expertise is available to support the selection process. The expert preferably is an analytical chemist who is familiar with both standard fixed-laboratory techniques that apply to the contaminants of concern, and also with non-standard, field-deployable methods that can be used to generate for generating real-time information.
The types of technologies considered may include methods that are not widely available commercially, either because they are proprietary or because service providers have only limited experience with their deployment. In this case, it may be necessary to involve vendors or service providers at some level in the selection process. The vendor or service provider may be the only source of the technology-specific information on technical performance that is required to properly compare alternatives. In addition, consultation with the vendor or service provider will be useful if site-specific method modifications are required to optimize technology performance. Finally, the vendor or service provider may be aware of technology-specific deployment needs that may be important when selecting measurement technologies and designing data collection programs.
Some contaminants and associated cleanup levels are problematic for currently available real-time measurement technologies. Examples include dioxins/furans and some radionuclides.
In these cases, real-time methods may be available for surrogate parameters that could be used to facilitate real-time decision making as part of a dynamic work strategy. Surrogates are parameters, compounds, or elements that are readily measurable, and whose presence and level have a strong relationship with contaminants of concern that are important for decision
SP-52
Module: Systematic Planning
•
•
Demonstration of Methods Applicability making. However, the contaminants of concern are more difficult to identify or quantify with real-time techniques.
A basic example of a surrogate is soil contamination associated with a layer or type that is visually different from uncontaminated soils. This situation can arise when contamination was the result of disposal of contaminated media, or is associated with buried waste areas. In this example, visual characteristics of the medium observed by the experienced eye of a field geologist may provide an effective, cost-efficient surrogate for soil samples as a means for guiding characterization or remediation. Another example is where multiple contaminants are consistently collocated, with one or more present that are amenable to real-time measurement and that can be used to support in-field decisions even if they are not of primary concern. In this case, x-ray fluorescence (XRF) could be used at a site where beryllium are lead commingled, with beryllium being the primary risk driver. Although an XRF would not be effective for beryllium, it could be used to measure the concentration of lead. In this case, XRF results for lead could be used as a surrogate to support decisions pertaining to beryllium.
The potential applications of data produced by alternative measurement techniques in project decisions are important to the selection process. Generic applications (arranged in order of analytical quality requirements, from less to more) are as follows:
S Reliably identify the presence or absence of classes of contaminants. This is the application simplest, with the result being the conclusion that a class of contaminants
(such as, polychlorinated biphenyls [PCBs] or pesticides) is or is not potentially present. No conclusions would be drawn about contaminant concentrations, however.
Technologies capable of making this determination can be used to narrow the list of contaminants of concern for specific areas or waste streams. Examples include directpush conductivity probes for identification of subsurface plumes, gamma walkover surveys for surface radionuclide contamination, and ion probes or paper strips to detect nitrites/nitrates.
S
S
Reliably identify the presence of a specific contaminant above an upper threshold. This case assumes that a method can reliably identify the presence or absence of a specific contaminant (such as, lead) at a level that is higher than cleanup requirements.
Technologies capable of making this determination can be used to identify hot spots, to support delineation of contaminant boundaries, and potentially to satisfy waste acceptance criteria.
Reliably identify the presence or absence of a specific contaminant around cleanup guidelines. This case assumes that a method can reliably establish that a specific contaminant is or is not present above cleanup requirements. Technologies capable of making this determination can be used to support remediation decision making and demonstrate compliance with cleanup requirements.
SP-53
Module: Systematic Planning
•
Demonstration of Methods Applicability
S Reliably quantify the level of a speficic contaminant with some known level of analytical quality (such as, precision and bias) down to levels below cleanup requirements.
Technologies with these characteristics produce data that can potentially be used for risk assessments (base-line and post-remediation) or documenting closure conditions.
The table compares the features of XRF and the associated issues that might be addressed when its application is considered.
Fundamentally different than laboratory methods for metals (no extraction; sample not destroyed)
May be biased high relative to laboratory comparison results if incomplete digestions are used in the fixed laboratory
May only be useful for hot spot delineation as opposed to
“clean vs. dirty” decisions
Use site-specific standards to compensate for interferences
• The table compares the features of immunoassay test kits and the associated issues that might be addressed when its application is considered.
Relationship to laboratory data may be complex ( not always imply that the kit data are bad!
) ) and does
Typically, test kits provide semi-quantitative results above, below AL
Kits can be sensitive to sample preparation batching and other influences
Must establish single conservative action level for a contaminant class
Requires DMA and follows-on fixed and field analyses to assess matrix effects
Requires raw data review and a thorough understanding of analyte chemistry (breakdown products)
Increased calibration and QC required to generate decision quality data
Field-based action levels must be developed and revised as project progresses
Analyst proficiency testing and matching the site conditions to dilutions is required
Module: Systematic Planning
SP-54
Demonstration of Methods Applicability
EPA SP-28
•
•
•
Notes:
The Triad requires a level of expertise and input in analytical chemistry that is commonly not found in more traditional approaches. This expertise is required to select the correct mix of analytical techniques, to support modifications to existing standard operating procedures that may be necessary to meet site-specific needs, to develop appropriate QA/QC protocols for proposed methods, to gain regulatory acceptance, and to interpret analytical data as they are being produced.
Triad-based data collection programs typically rely on a variety of data collection techniques and analytical methods to achieve the desired level of certainty in decision making. These methods will include analyses that are considered standard in description, methodology, and associated quality control. The application of other methods may be considered non-standard and may be technologies that truly are innovative and different. The base technique of other technologies may have been standardized, but the standard operating procedures are modified to meet site-specific needs. For these techniques, regulatory and stakeholder acceptance will be critical to their successful deployment.
Analytical methods are often classified based on their acceptance or recognition by federal or state regulatory agencies and programs. An example is the SW-846 catalog of methods maintained by the RCRA program. (As an added note, many methods typically associated with field analysis, such a broad range of test kits and XRF, are already included in SW-846.
Regulators should take comfort in the knowledge that these methods have been thoroughly
SP-55
Module: Systematic Planning
•
•
Demonstration of Methods Applicability evaluated for their ability to provide reliable data when used appropriately.) A second example is the set of methods commonly used by the Superfund Contract Laboratory Program. Other examples are the various laboratory and methods certification programs administered by DoD or state agencies. These methods catalogs are useful when reviewing the analytical options for a Triad program. These methods have achieved a certain level of respectability, and in many cases acceptability, within the state and federal regulatory community. They are usually readily available. From a Triad perspective, however, two important points should be kept in mind.
First, just because a particular method is contained in SW-846, for example, does not mean that it is applicable without modification or that it is even the most appropriate method for the needs of a site. This fact is stated within the SW-846 methods manual itself (Chapter 2), although few realize that SW-846 acknowledges that analytical flexibility is required to accommodate the scientific needs of waste programs. Analytical flexibility is the basis of EPA’s new Performance Based Measurement System (PBMS) initiative. Second, just because a method is not contained in a catalog of methods does not mean that it is inferior for a particular site application. Because of budget and workload constraints, it usually requires several years before a new technology, no matter how superior, can be incorporated into established methods catalogs.
Measurement technologies can be categorized as producing either decision-quality or screening-quality data. Decision-quality data (individual points or set) are of known quality that can be logically shown as effective for making scientifically defensible project decisions without requiring additional data or information to back them up. In this case, the relational, sampling, and analytical uncertainties in the data have been controlled to the degree necessary to meet clearly defined decision goals. Triad practitioners also refer to these type of data as “effective data,” reflecting their value as “effective for decision making purposes.” In contrast, screeningquality data (individual points or set) may provide some useful information that by itself is not adequate to support project decision making. They are not adequate because the amount of uncertainty (stemming from sampling, analytical, or relational uncertainty or other considerations) in the data set is greater than is tolerable. Screening-quality data place decision-makers in the “region of decision making uncertainty,” as was discussed previously in this module.
When data that would be considered screening quality (if considered in isolation) are combined with other information or additional data that manage the relevant uncertainties, the combined data and information package may become effective for decision making. When data sets produced from different technologies are used collaboratively to manage both sampling and analytical uncertainties, the Triad refers to these as “collaborative data sets.” From a Triad perspective, usually the most cost-effective source of decision-quality data is when two or more analytical technologies are used collaboratively.
Module: Systematic Planning
SP-56
Demonstration of Methods Applicability
Is a DMA needed?
» How will data be used?
» Does a technology provide stand alone data or an indirect measurement?
A DMA may need to address:
» Sample support
» Minimum reportable concentrations (MDL/PQL)
» Method working range (calibration range)
» Precision and bias (sampling and analytical)
» False positive/negative rates
» Practicability (cost, TAT, throughput, ease of use)
EPA SP-29
•
•
Notes:
As discussed earlier, the expected site-specific performance of any measurement technology depends as much on the site-specific distribution of contamination and media characteristics as on the generic performance characteristics of the technology itself. The CSM plays an important role in predicting measurement technology performance, since the CSM captures the understanding about the spatial distribution of contamination and nature of contaminated media.
As a site moves through the characterization and remediation processes, the CSM is constantly evolving and becoming more accurate. Selecting appropriate real-time measurement techniques and predicting their performance becomes progressively easier as the cleanup process proceeds.
A DMA is essential where there is significant uncertainty about the potential performance of specific techniques or the need to modify a particular technique to meet site-specific requirements. This type of study can be conducted as a stand-alone exercise or can be integrated with planned characterization activities. This is one of the reasons for introducing a
Triad approach as early into the characterization and remediation process as possible. Fielding alternative measurement technologies in a limited fashion as part of the site assessment or remedial investigation can pave the way to more effective and comprehensive deployment during later stages of work.
SP-57
Module: Systematic Planning
•
Demonstration of Methods Applicability
Approach for pilot testing can vary widely, and can involve…
S
S
S
S
Analysis of site samples and matrix QC samples (matrix spike and matrix spike duplicate [MS/MSDs], reporting limit spikes)
Evaluation of sampling as well as analytical procedures
Analysis of split samples by different methods
Statistical evaluation of initial data collected
Module: Systematic Planning
SP-58
Demonstration of Methods Applicability
EPA SP-30
•
Notes:
Benefits of a DMA include:
S
S
S
S
S
S
Increased data usability
Fewer surprises or failures
Superior interpretation of CSM
Development of cost data
Clarification of practicality, health and safety, waste generation, and logistics issues
Development of site-specific SOPs for sampling and methods, as well as contingencies that may be needed for method application
SP-59
Module: Systematic Planning
Demonstration of Methods Applicability
AL (ppm)
Confident Decision that True Conc. < AL
40 50 65
Confident Decision that True Conc. > AL
EPA
Window of decision uncertainty: additional testing required for confident decision
SP-31
•
•
Notes:
When developing decision logic for sites where actions will be based primarily on field-based measurement technologies it is often necessary to consider many factors, such as:
S
S
Field observations or other data may suggest that there is the potential for similar, yet different analytes to yield similar responses when a test kit or other screening analytical method is used. This issue can be effectively accommodated using a variety of strategies; the selection will depend on project-specific considerations.
If a significant bias is expected in the field analytical results, one strategy is to collect sufficient comparison data (for example, splitting well-homogenized samples for analysis by both the field and traditional methods) during a “demonstration of method applicability” or in early sampling events (or both). If a predictive relationship can be identified between the field measurements on an analyte-specific basis, it could be used to guide decision making using the field methods.
A predictive relationship can be established qualitatively or quantitatively. Qualitative relationships are based on professional judgment between involved parties to set the limits that will be used to make decisions based on field data. Setting these limits using qualitative professional judgment is necessary when the comparison data set is too small or poorly behaved for meaningful mathematical (statistical) treatment. The limits are selected based on an estimate of where decisions can be made with adequate confidence. In addition, intolerable
SP-60
Module: Systematic Planning
•
•
•
•
Demonstration of Methods Applicability uncertainty must be avoided. The words “adequate” and “intolerable” correctly imply that values and personal preferences and interests are involved in making these judgments. As a result, setting these limits should involve participation among all concerned parties.
If the work plan allows for generation of a sufficiently large comparison data set of the correct type, a quantitative statistical relationship may be calculated. Value judgments will still be involved in selecting the level of statistical confidence to be used.
A quantitative option for expressing this predictive relationship is to develop “response factors” or multipliers. These factors mathematically adjust the field-based measurement results to
“correct” the bias so that the field data are more directly comparable to traditional laboratory results for comparison with regulatory threshold limit values. The validity and regulatory acceptance of these “corrections” depend on documentation that the causes of the bias are understood, as well as on transparent documentation to demonstrate the mathematical relationship between the field and traditional data sets are derived.
Another option for expressing this predictive relationship between the two data sets is to set
“decision intervals,” as displayed in the slide. Depending on the nature of the project and the decision, two or three decision intervals are common. The most common breakdown is into three intervals, as shown in the diagram below: (1) an interval where it is judged that the field data results can be confidently trusted to declare areas “clean” (where no further action is needed), shown on the left side of the line below; (2) an interval where field results can be trusted to confidently declare an area “dirty” (where remedial action is needed), shown on the right side of the line; and (3) an interval where the field results are considered ambiguous and a confident decision of “clean” or “dirty” would require more data to manage the decision uncertainty, shown in yellow in the central area of the line. This uncertainty may stem from sampling variability or from analytical uncertainty (imprecision or bias in the field method), or both. When only two intervals are used, a single limit is proposed: data values less than this limit allow the area to be declared “clean,” and data values greater than the limit are accepted as indicating that the area is “dirty.” In this case, the uncertainty is built into the limit or is ignored.
Especially when qualitative judgment is used to establish limits on the decision interval, setting these limits becomes a judgment that must balance several considerations: (1) the quality of the predictive relationship (that is, how many comparison points are available to build confidence that decisions can be made correctly, and how much scatter is present around the predictive line); (2) how well the range of variables affecting the performance of the two analytical systems
(for example, potential analytical interferences, different matrix characteristics, and low versus high levels of contaminants) was captured in the comparison data set; and (3) the cost of making a decision error (that is, declaring an area “clean” when it actually is not, or declaring an area “dirty” when it actually is not) versus the cost of collecting the additional data needed to address excessive decision error, as discussed below.
SP-61
Module: Systematic Planning
•
•
Demonstration of Methods Applicability
Weighing sampling costs versus potential decision errors further involves the following considerations:
S
S
Estimating the cost of collecting and analyzing additional samples should consider not only the financial cost, but the repercussions of any delays to the project schedule that may be incurred as well. (If the project work plan is based on a dynamic approach, the cost to budget and schedule may be minimal.)
Estimating the cost of a “false action” decision error (that is, incorrectly declaring an area “dirty” so that follow-up action is required) requires considering whether the cost would be minor or major. The cost may be minor if it is known that a soil treatment system or institutional control will be built in any case, and the ramification of this particular “false action” decision will add only an incremental amount of soil to the volume already slated for treatment; for example, to add additional fencing to isolate 11 acres instead of 10. On the other hand, a “false action” could be costly if the decision of whether a treatment system or institutional control is needed hinges on a faulty conclusion. The costs of “false action” decision errors also should factor in any social, redevelopment, or community ramifications of declaring an area “dirty.”
S Estimating the cost of a “false inaction” decision error (that is, incorrectly declaring an area “clean” so that no further action is needed) must consider the human health and ecological ramifications of potential exposure to excessive contamination, as well as the social and political costs that will be incurred when the error is discovered or suspected. It is often more important to protect public health and the environment from potentially harmful health effects, and to err on the side of caution. On the other hand, this approach can be costly. Nonetheless, it can be prohibitively expensive in some scenarios to gather all the information needed to ensure that decisions are entirely correct. Therefore, it is possible to structure the decision making process so that substantial costs can be saved by judiciously deciding when relatively small errors on the side of caution can be accommodated. These errors can be thought of as a kind of
“safety factor” that supports using field measurements and other types of nontraditional tools to achieve significant cost savings while decisions remain protective of human health and the environment.
Managing decision uncertainty that stems from sampling variability can require collection of grab or composite samples to obtain a more confident estimate of the concentration mean for the decision unit or of the boundaries of contamination. Managing decision uncertainty that stems from analytical uncertainty requires first that sampling uncertainty has been managed (so the representativeness of samples is known). Then, samples that represent critical decision points are selected for processing by more rigorous analytical methods to produce analyte-specific data, or data that are free of excessive analytical bias or imprecision.
SP-62
Module: Systematic Planning
•
•
Demonstration of Methods Applicability
Usually, a study (the “demonstration of methods applicability” as defined by EPA’s Office of
Solid Waste Methods Team, which manages the SW-846 methods manual) is designed and implemented initially to begin the process of evaluating potential sampling and analytical method issues. The study also may evaluate the comparability of the various sampling and analytical methods under consideration. The results of the study are used to compute appropriate safety factors and uncertainty limits for decision making that should be applied at a site. Differing safety factors may be developed for a monitoring and measurement technology and type of decision being made. Uncertainty limits to support decision making are used to establish concentrations where stakeholders feel comfortable that a correct decision is being made.
Safety factors involve the correlation between field-based and fixed-laboratory methods.
Although safety factors are an essential part of developing uncertainty limits for decision making, they are one piece of the puzzle.
A DMA is usually designed to evaluate the ability of a method to meet project-specific data needs (that is, the specific contaminants and media of concern at a site). The study considers the precision, sensitivity, and bias of the field-based instrument technology such that an adequate safety factor can be built into the overall limits on decision uncertainty. Internal method quality control results, along with investigative, replicate, and spiked samples analyzed in the field as well as by off-site methods, are generally used to establish safety factors. A safety factor thus becomes a tool project teams can use to manage uncertainty in project decisions, not only for field-based methods but for any data collection at a site where results are compared with screening criteria. Some other approaches for managing uncertainty based on inputs from QC or analytical data are summarized later in the module. When methods applicability studies are used, the number of data points is typically limited, making rigorous statistical analysis nonproductive. Judgment is therefore used to evaluate the comparison data set to construct a decision making mechanism that allows use of the data, but with a sufficient safety buffer so that intolerable decision errors are avoided.
SP-63
Module: Systematic Planning
Demonstration of Methods Applicability
Confident Decision that True Concentration
< Action Level
Confident Decision that True Concentration
> Action Level
Safety Factor (95% UCL of Regression Line)
EPA SP-32
•
•
Notes:
Data collected by EPA Region 8 at the Ross Incinerator site (the site) in Colman, South
Dakota, were evaluated. EPA Region 8 requested assistance from the EPA Brownfields
Technology Support Center (BTSC) in the statistical assessment and interpretation of the analytical results from a focused site inspection (SI). The statistical assessment focused on 31 surface soil samples that were collected at the site. A judgmental (biased) sampling approach was used, so that in samples were collected near potential sources and from disturbed or stained areas. A random grid sampling approach was applied in areas of the site where sources or disturbed areas were not observed. The soil samples were analyzed for total PCBs using RaPID Assay immunoassay test kits provided by Strategic Diagnostics, Inc (SDI). Five of the samples were sent for further analysis of PCBs at an off-site laboratory by EPA Contract
Laboratory Program (CLP) analytical methods.
The figure in the slide is a correlation plot for the data for on-site surface soil, showing the correlation line (with 95 percent confidence intervals) between the test kit and the CLP laboratory data. Although only five on-site samples were collected for both test kit and CLP analyses, a clear correlation is obtained r = 0.989). The kits consistently display a significantly high, conservative bias (on the order of 10 times, or more) over the CLP results. This level of bias is greater than was found in the EPA Environmental Technology Verification (ETV) study for the RaPID Assay test kits that was completed in 1998
( http://www.epa.gov/etv/verifications/vcenter1-7.html
). The CLP data reported Aroclor
1260 as the predominant PCB mixture in each of the five samples submitted. Because the test
SP-64
Module: Systematic Planning
•
•
Demonstration of Methods Applicability kits were calibrated based on Aroclor 1254, the test kit data were divided by a correction factor of 1.56 to report Aroclor 1260 per SDI’s recommendations.
The main purpose of the correlation plot is to generate a field-based action level for the kit that is connected to the risk-based concentration of interest for the Site. Establishment of an action level is necessary if the results from the test kit are to be used for decision making. EPA Region
8 currently favors the EPA Region 3 preliminary remedial goal (PRG) for industrial soil (2.9
parts per million [ppm] for Aroclor 1260) in the screening of risk for on-site workers (the envisioned future land use scenario). As illustrated on the plot, a conservative estimate of the kit result that corresponds to a laboratory concentration of 2.9 ppm can be found by using the
95 percent upper confidence limit of the regression line rather than the line itself, and then estimating the corresponding test kit result. Accordingly, the red arrows on Figure 1 indicate that 2.9 ppm correlates with a field result of approximately 26 ppm Aroclor 1260. Through multiplying by 1.56, this field result can be further adjusted to the equivalent the Aroclor 1254 result reported by the kits. This adjustment yields a field-based action level of 40 ppm.
The implication of the correlation plot is that because the highest result for a test kit found at the site (18.9 ppm) is well below the field-based action level of 40 ppm, no action is necessary to protect workers at the site using the EPA Region 3 industrial PRG as a risk screening criterion.
In this sense, the statistical analysis indicates that the results for the field test kit and correlating
CLP results comprise a data set of sufficient quality for decision making at the site. One or two additional CLP samples collected on site could have better defined the degree of correlation.
Based on the initial evaluation through the BTSC, however, the test kits appear to have cost effectively produced a high data density at the site and indicate that no further action is necessary at the site if an industrial risk-screening level of 2.9 ppm is applied.
SP-65
Module: Systematic Planning
Dynamic Work Strategies
—
—
EPA SP-33
•
•
•
Notes:
It is critical that dynamic work strategies be well documented down to the level necessary to facilitate decision making in the field. Decision statements can be well defined in terms of cleanup conditions or other requirements. Conversely, they can be based on use of a field method and subsequent confirmation using a definitive method. They can be arranged around a volume constraint or a maximum number based on economic constraints. Incomplete definitions of cleanup complicate systematic planning, confuse decision making, and make design of a technically defensible sampling program difficult.
Complete cleanup requirements include the spatial scale (decision unit) where the cleanup requirement applies and also may include a time scale. They also come in two general types: a wide-area average requirement, and an elevated requirement (“hot spot”) applied to much smaller areas.
Decision statements can also include how data will be processed, such as the diagrams provided at the end of this module. Decision uncertainty and how it will be managed can often not be specifically addressed until more data have been collected. However, the process used to assess and even conveyed uncertainty can be designed such that it is clear the path that will be taken. This type of structure decision tree is what allows adaptive and dynamic work strategies to be implemented in the field, while assuring stakeholders that undue risk is not condoned.
SP-66
Module: Systematic Planning
•
Dynamic Work Strategies
Using the Triad, many different types of data may be combined and used collaboratively to support decision making and the approved weight-of-evidence decisions that must be made at hazardous waste sites. Stating when and how each form of data will be combined and evaluated and what will trigger contingencies will assure all involved that the project will proceed according to plan regardless of any unknowns encountered.
SP-67
Module: Systematic Planning
Dynamic Work Strategies
EPA SP-34
•
•
•
Notes:
The decision logic diagram, or “decision tree” outlines the logical steps the field team will take as site data are acquired. The decision tree defines the criteria (which might be regulatory action levels, but also might be decision-specific or site-specific thresholds that define when specific actions will or will not be taken) and how the data collected will be compared with these criteria (whether through a direct comparison or a statistical quantity or test). Project managers should ensure that decision trees consisting of a series of well-defined “if-then” statements are developed before the mobilization to reach and quickly resolve decision points during a dynamic investigation. Examples of decision points and the “if-then” statements or other types of decision rules that can be created are presented in the slide.
Timeframes for the decisions also should be addressed during the planning process in a dynamic investigation. Decisions may have to be made within several hours and generally cannot be delayed longer than a day or two, depending on the size of the site and the type of work conducted.
For example, if a dry cleaner site is being investigated to delineate an area of tetrachloroethene
(PCE) contamination emanating from only one source area, there would be little for a field crew to do if the decision about the next sampling location or installation of a well was delayed. On the other hand, characterization of multiple contaminant source areas on a military base may not be significantly hindered by delays in decisions since a field crew could be diverted to other source areas while the issue is resolved. In either situation, however, the project manager, with
SP-68
Module: Systematic Planning
•
•
•
Dynamic Work Strategies the help of the technical review team, will need to stay sufficiently well informed about the progress of field work to make timely decisions based on the information presented by the technical team leader.
Project managers should consult with technical experts in conjunction with regulatory oversight staff and other stakeholders to develop investigation scenarios and decisions trees. Once a consensus has been established, the project manager should ensure that the decision tree is incorporated into project planning documents to clearly demonstrate how the data collected will be used to support decision making. As appropriate, decision trees should incorporate the tolerable error rates into each decision point.
It is possible that although a variety data may be collected to support various activities, only one or two analytes may drive the decision making (such as, aquifer characteristics, modeling, or remedial technology screening). Consequently, decision makers may prefer to receive report summaries that concentrate on only the key data points.
The project planning documents should discuss the type of decisions that should be made with input from regulators and other stakeholders to eliminate misunderstandings between the core technical team and the decision makers. These documents also should discuss the type of decisions that are minor adjustments to the investigation approach and may be made without prior approval. For example, the decision to cease data collection because contamination has been delineated in terms of the applicable risk-based standard may require notification of and approval by the regulators, whereas minor adaptations of sampling or analytical procedures to field conditions may not need regulatory consultation (at least on a “real-time” basis). Decisions that require concurrence from parties other than the core technical team should be denoted as appropriate on the decision trees prepared for the investigation.
SP-69
Module: Systematic Planning
Dynamic Work Strategies
EPA SP-35
•
Notes:
Project managers can develop estimates of project schedules by estimating the time needed to bring the decision trees to their logical conclusions based on the credible site scenarios.
Decision trees can also be used for scoping and costing; they can assist in estimating the minimum and maximum amount of work that may be necessary at a site, including the approximate number of samples, types of analyses, and labor hours.
Module: Systematic Planning
SP-70
Real-Time Data Management
EPA SP-36
1.
2.
•
Notes:
Below is an example of a database dictionary developed for a site where direct-push and a broad spectrum of analyses were performed. Following the data dictionary is a diagram showing the relational database structure used at this site.
STRUCTURE OF MARINO ACCESS ENVIRONMENTAL DATABASE
All data entered into the attribute database should be entered exclusively in UPPERCASE.
3.
Any column name preceded by an asterisk (*) is required and must be entered into the database.
Any column name preceded by a pound symbol (#) is CONDITIONALLY required. The description of the column explains when an entry is required.
4.
Any column name preceded by an ampersand (&) is DERIVED. No data entry should occur for this column. This column will be calculated or completed by the computer.
5.
The information in the column labeled DATA TYPE defines the database fields as follows:
S (Cn) - indicates a text field n characters long, where n is any integer greater than 0.
SP-71
Module: Systematic Planning
Real-Time Data Management
S (Nn,m) - indicates a numeric field n digits long with m digits after the decimal place. A data type of (N8) indicates a long integer field (no decimal places). A data type of
(N12,4) indicates a decimal field with total of 12 digits, both to the left and right of the decimal point. There are 4 digits to the right of the decimal point.
S (DATE) - indicates a date field. Date fields in Access can be entered in several formats, such as MM/DD/YY, or converted to Julian dates.
Module: Systematic Planning
SP-72
Real-Time Data Management
EPA SP-37
•
•
Notes:
The above flow chart shows how data might flow for a typical project. Chain of custody information is generated and then carried into the field where samples are collected. Samples are then delivered to the mobile lad and the database manager in the field. The database manager checks to see that the samples indicated on the chain correspond to those planned and then checks to see that the appropriate suite of analyses has been requested. At the same time the field lab prepares its internal chain of custody, assigns a batch, number, and then analyzes the samples. The results are then communicated along with the appropriate QC check summaries back to the data manager and field chemist for review and data reduction and qualification.
The flow chart shown on the next page provides more detail concerning a data flow during a typical Triad type project.
SP-83
Module: Systematic Planning
Real-Time Data Management
Module: Systematic Planning
SP-84
Real-Time Data Management
COC input to lab and database
Run analyses and check COC
Desktop reviews, load chemical data, check
Update database
Output to decision support tools
Prepare real-time products
Post data to web
Obtain stakeholder buy-in
EPA SP-38
•
•
•
Notes:
Chain-of-Custody (COC) input to laboratory and database
COC is filled out in the field by samplers.
COC consists of:
S
S
General COC form - project name, sampler names, sample identification, sample date, sample time, sample medium, container information, preservatives, analyses required, remarks, sample custody information
Extended COC form - project name, sampler names, sample identification, sample date, investigation (sample event name), point (location) name, site name, point type
(MW, HP, SB, …), sample type (NORM, FD, FB, …), top sample depth, bottom sample depth, sample medium (water, soil, sediment, air), grab or composite, sampler’s company, remarks
New location form is filled out by the samplers.
SP-85
Module: Systematic Planning
•
Real-Time Data Management
New location form consists of:
S Project name, investigation, consultant, point name, point type, origination date, description, source of coordinates (survey, GPS, map)
•
•
•
• Completed general COC form and sample are sent to the laboratory.
Completed general and extended COC forms are sent to database management.
Completed new location form is sent to database management.
Coordinate data is sent to database management (electronic file that links to COC by point name, or if picked off of a map then manually entered into database).
•
•
•
•
Run analyses and check COC
Laboratory runs the chemical analyses.
Database management enters COC information into the database. COC data is checked
(completeness, lookup values, …)
Survey information is imported (or entered) into the database.
Survey information is checked against the COC to ensure that all points have coordinates.
Survey locations are verified to be within the project area.
•
•
•
•
•
Desktop reviews, load chemical data, and check
Chemical results data is exported from lab into an electronic file (and hard copy reports).
Hard copy QC packages are produced from laboratory.
Chemist performs a desktop review of chemical data.
Once chemist approves chemical data, the data are loaded into the database.
Data undergoes checks and verification to ensure that results have been loaded for each sample, and that all data matches between COC and chemical results file.
Module: Systematic Planning
SP-86
•
Real-Time Data Management
•
Revise database
Additional review by chemist to ensure 1 result per sample per analyte (pick dilution result, …)
Database is revised and checked to ensure that a single result exists for each sample/analyte combination.
•
Output to SADA
Data is electronically exported to a SADA compatible format.
SP-87
Module: Systematic Planning
Real-Time Data Management
Database Manager Qualifications
» Intermediate database manager
» 2+ yrs of hands-on experience
» Work under pressure
» Understand environmental data and documentation
» Good communicator (liaison between field, lab, data management)
» Independent worker
EPA
(continued)
SP-39
•
Notes:
At the minimum, an intermediate database manager is required. Most have at least 2 years of hands-on experience managing environmental data. The manager needs to have a solid skill set and can perform under pressure and will have to effectively interact with field and laboratory staff. The database manager also needs to be able to work independently (without day by day management) and will be required to create documentation on various procedures. For example, the steps required to import the instrument data from the laboratory.
Module: Systematic Planning
SP-88
Real-Time Data Management
Database Manager Skills
» Database design
» Database development
» Real-time data management and manipulation
» QC
» Data entry
» Reports
» Forms
» Macros
» Visual Basic
EPA
(continued)
SP-40
Notes:
The database manager will have to:
Design the database
•
•
•
•
•
•
•
[Basic steps]
Determine the purpose of your system
Determine the tables you need in the system
Determine the fields you need in the tables
Identify fields with unique values
Determine the relationships between tables
Refine the design
Add data (populate tables) and create other system objects (query, macros, reports, code)
•
•
•
•
[Advanced steps]
Use/create entity relationship diagram (ERD)
Use/create data dictionary
Optimize database (indexes, keys)
Normalization
SP-89
Module: Systematic Planning
•
•
Real-Time Data Management
Develop database
Implement the design
S
S
S
S
S
S
Need to create:
S Tables
S Relationships (primary key, foreign key)
Indexes
Queries (select, insert, update, delete)
Macros or code (import, export, checks, …)
Reports
Forms
Visual Basic for Applications (VBA) coding – for example, create forms that will run a report based on user criteria
•
•
•
•
•
Data management and manipulation
Create on-the-fly queries
Update queries
Append queries
Compare data
Create import, export functionality
•
•
•
Quality control (QC)
Perform quality control checks on the data (both electronic and manual)
Ensure data integrity
Maintain lookup tables and relationships to other tables
Data entry
•
•
•
Reports
Enter data from COC, ECOC, New Location forms
Manage data entry staff
Verify data entry
•
•
• Create reports on-the-fly
Standard reports
Ability to run from forms
•
Forms
Support data entry, queries, reports
SP-90
Module: Systematic Planning
Real-Time Data Management
•
Macros
Macros are very useful for automating simple tasks, such as carrying out an action when the user clicks a command button. You don't need to know how to program to use macros.
Macros can perform a number of the common tasks that you can also use Visual Basic code to perform. However, using Visual Basic code instead of macros gives you much more flexibility and power, and there are many things you can only do in code, such as returning values or iterating through record sets.
•
•
VBA code
Visual Basic for Applications for more complicated issues
Forms, reports, queries, etc.
•
Queries
Be able to quickly and efficiently produce all types of queries
SP-91
Module: Systematic Planning
Real-Time Data Management
Chemistry Manager Skills
» 5 + years of experience
» 2+ years in a lab
» Some MS Excel skills
» QA/QC implementation
» QAPP preparation
» Data interpretation
» Report writing
» Good communication skills
EPA SP-41
Notes:
Module: Systematic Planning
SP-92
Real-Time Data Management
EPA SP-42
•
•
•
Notes:
A good design is the keystone to creating a system that does what you want it to do effectively, accurately, and efficiently.
Determine the purpose of your system you need to know what information you want from the database (detailed scenario). From that, you can determine what subjects you need to store facts about (the tables) and what facts you need to store about each subject (the fields in the tables).
Make sure that you do answer the following questions:
S What types of things should the system keep track off? (System objects -> purpose and use)
S
S
S
What would a user want to know about these things and what restrictions should be placed on changing the attributes of these things? (System properties -> features, attributes, nature)
What would a user want to do to these things? (System methods -> actions to be taken)
What is the relationship between the different (things) types? (System Object Model)
SP-93
Module: Systematic Planning
•
•
•
Real-Time Data Management
Determining the tables can be the trickiest step in the database design process. That is because the results you want from your database (for example, the reports you want to print, the forms you want to use, the questions you want answered) don't necessarily provide clues about the structure of the tables that produce them. In fact, it may be better to sketch out and rework your design on paper first. When you design your tables, divide up pieces of information by keeping following fundamental design principles in mind:
S
S
S
A table should not contain duplicate information, and information should not be duplicated between tables (e.g., store each customer address and phone number once, in one table)
When each piece of information is stored in only one table, you update it in one place.
This is more efficient, and also eliminates the possibility of duplicate entries that contain different information.
Each table should contain information about one subject. When each table contains facts about only one subject, you can maintain information about each subject independently from other subjects (e.g., you would store customer addresses in a different table from the customers' orders, so that you could delete one order and still maintain the customer information).
There are several things you can do to optimize your tables:
S Design tables without redundant data
S
S
Choose appropriate data types for fields; you can save space in your database and improve join operations
Create indexes for fields you sort, join, or set criteria. This will make dramatic improvements in the speed of queries by indexing fields on both sides of joins, or by creating a relationship between those fields and indexing any field used to set criteria for the query. Finding records through the Find dialog box is also much faster when searching an indexed field
S
S
S
Determine the fields you need - Each table contains information about the same subject, and each field in a table contains individual facts about the table's subject (e.g., a customer table may include company name, address, city, state, and phone number fields). When sketching out the fields for each table, keep following tips in mind:
Relate each field directly to the subject of the table
Don't include derived or calculated data (data that is the result of an expression)
Include all the information you need
SP-94
Module: Systematic Planning
•
•
•
•
•
S
Real-Time Data Management
Store information in its smallest logical parts (for example, first name and last name, rather than just name)
Identify fields with unique values - In order to connect information stored in separate tables
(for example, to connect a customer with all the customer's orders) each table in your database must include a field or set of fields that uniquely identifies each individual record in the table.
Such a field or set of fields is called a primary key.
Determine the relationships between tables - Now that you've divided your information into tables and identified primary key fields, you need a way to tell the system how to bring related information back together again in meaningful ways. To do this, you define relationships between tables. Relationship is an association between common fields (columns) in two tables.
A relationship works by matching data in key fields. In most cases, these matching fields are the primary key from one table, which provides a unique identifier for each record, and a foreign key in the other table. The kind of relationship that the system creates depends on how the related fields are defined. When you physically join two tables by connecting fields with like information, you create a relationship that is recognized by Access. The specified relationship is important. It tells Access how to find and display information from fields in two or more tables.
The program needs to know whether to look for only one record in a table or to look for several records on the basis of the relationship.
In addition to specifying relationships between two tables in a database, you also set up referential integrity rules that will help in maintaining a degree of accuracy between tables.
It would prevent unwanted and accidental deletions of records in a parent (primary) table that relate to records in the child table. This type of problem could be catastrophic. These rules keep the relationships between tables intact and unbroken in a relational database management system, because the referential integrity prohibits you from changing existing data in ways that invalidate the links between tables. Referential integrity operates strictly on the basis of the tables’ key fields. It checks each time a key field, whether primary or foreign, is added, changed or deleted. If any of these listed actions creates an invalid relationship between two tables, it is said to violate referential integrity . Referential integrity is a system of rules that
Microsoft Access uses to ensure that relationships between records in related tables are valid, and that you don't accidentally delete or incorrectly change related data.
NOTE: When tables are linked together, one table is usually called parent table (always “one end” of an existing relationship) and another table is called child table (always “many end” of an existing relationship). This is known as a parent-child relationship between tables. Referential integrity guarantees that there will not be an orphan , a child record without a parent record.
Refine the design - After designing the tables, fields, and relationships you need the time to study the design and detect any flaws that might remain. It is easier to change your database design now, rather than after you have populated the tables with data or created the relevant screens.
SP-95
Module: Systematic Planning
•
Real-Time Data Management
Enter data and create other system objects structures meet the design goals described here, then it's time to go ahead and add all your existing data to the tables. You can then create any queries, forms, reports, macros, and modules that you may want.
- When you are satisfied that the table
Module: Systematic Planning
SP-96
Real-Time Data Management
Implement the design
» Tables
» Relationships
» Indexes
» Queries
» Code modules
» Macros
» Reports
» Forms
EPA SP-43
•
•
Notes:
Develop database
To implement the design, you need to create:
S
S
S
S
S
S
Need to create:
S Tables
S Relationships (primary key, foreign key)
Indexes
Queries (select, insert, update, delete)
Macros or Code (import, export, checks)
Reports
Forms
Visual Basic for Applications (VBA) coding – for example, create forms that will run a report based on user criteria
Macros are very useful for automating simple tasks, such as carrying out an action when the user clicks a command button. You don't need to know how to program to use macros.
Macros can perform a number of the common tasks that you can also use Visual Basic code to perform. However, using Visual Basic code instead of macros gives you much more flexibility and power, and there are many things you can only do in code, such as returning values or iterating through recordsets.
SP-97
Module: Systematic Planning
Real-Time Data Management
EPA SP-44
•
•
Notes:
Database management involves manipulation of the data. This includes importing the data, comparing the data to existing data, making corrections/updates, appending the data to the main tables, QC the data, make more updates, export the approved data.
S
S
S
S
S
The functionality needed:
Import (macros, code, forms)
Queries (select, update, append)
Forms
Reports
Export (macros, code, forms)
Module: Systematic Planning
SP-98
Real-Time Data Management
EPA
•
•
•
Notes:
Data entry
•
•
•
•
Manual data entry of COC, ECOC, new location forms
Manual data entry of survey coordinates if not in electronic form
Electronic import of survey coordinates
S
S
Include exact point name
XYZ in project system/format
Electronic import of lab chemical results
Quality control (QC)
Create hard copy reports to check manual data entry
Develop procedures (code, query, macros) to check electronic data
Have methodology in place for dealing with problems
SP-45
SP-99
Module: Systematic Planning
Real-Time Data Management
—
—
EPA SP-46
•
Notes:
There are many emerging options for sharing data real-time with potential stakeholders. The above listed options are some of the primary tools being used at present. Many new platforms such as e-rooms and intranet secure sites are also arising, but a complete discussion of all available options is beyond the scope of this module.
Module: Systematic Planning
SP-100
Real-Time Data Management
EPA SP-47
•
•
Notes:
In addition to needing to manage traditional forms of data, Triad projects often need to also manage new forms of data which can have a very different form and require display capabilities not traditionally required for projects. In addition, project teams need to convey collaborative data sets and communicate why decisions will be made based on multiple line of evidence. For this reason narratives or brief explanations should be considered for inclusion with daily reports to assure stakeholders are processing the correct information in the appropriate order such that they can understand the decision making process being conducted in the field.
Traditional data assessment must also accompany most activities conducted in the field. Basic statistical packages should be brought to the field such that data reduction can be facilitated.
Interactive capabilities as provided for in more elaborate web applications such as portals can also be beneficial when complex decision making and data interpretation is required to support on-site decisions.
SP-101
Module: Systematic Planning
Real-Time Data Management
Sensors
Membrane Interface Probe
Laser Induced Fluorescence
Fuel Fluorescence Detectors
Cone Penetrometer
Neutron/Gamma Monitors
¨
¨
¨
¨
¨
Target Data
Volatile Organic Compounds
POL Hydrocarbons
POL Hydrocarbons
Soil Characteristics
Radiation Monitoring
Permeameter
New
Developments
Haloprobe
Polymers
¨ Hydraulic Conductivity
¨ DNAPL Chlorinated Solvents
¨ Chlorinated Solvents/Energetics
EPA SP-48
•
Notes:
Listed above are some examples of none traditional form of data which may need to be managed and results communicated.
Module: Systematic Planning
SP-102
Real-Time Data Management
SP-49
Notes:
EPA
SP-103
Module: Systematic Planning
Real-Time Data Management
Notes:
EPA SP-50
Module: Systematic Planning
SP-104
Real-Time Data Management
SP-51
Notes:
EPA
SP-105
Module: Systematic Planning
Real-Time Data Management
EPA
• Do we know the source?
• How many other possible sources do we have?
• What is the extent vertically AND horizontally?
• Where should we place our wells?
SP-52
Notes:
Module: Systematic Planning
SP-106
Real-Time Data Management
SP-62
Notes:
EPA
SP-107
Module: Systematic Planning
Real-Time Data Management
OBJECTIVE APPROACH
Quantitative
Data for Site
Closure
EPA
Collaborative
Data for High
Definition
Conceptual
Site Models
Combination for
Monitoring of
Remediation
Performance
Geoprobe and
Fixed Lab
Analysis
Direct Sensing, for example,
Membrane
Interface Probe
Direct Sensing and Lab/Mobile
Lab
DATA
POINTS/DAY
10-20 samples and analyses
COST/
POINT
$150-300
200-2000 field measurements
20-200
$2-20 ea
<<< $150
Notes:
SP-54
Module: Systematic Planning
SP-108
Notes:
Real-Time Data Management
The HPS Portal is a web-based information repository for all parties involved in the HPS cleanup project.
It allows HPS staff to
» View archived published documents
» Work collaboratively on documents
» Keep abreast of new developments
» Report status of projects
» Discuss issues and problems
» Query the environmental database
» View GIS maps (predefined or based on query results)
(continued)
EPA SP-55
SP-109
Module: Systematic Planning
Real-Time Data Management
EPA SP-56
•
•
Notes:
The parcel map is a quick way to access the “Basewide HPS” projects. Click on a parcel to get to that parcel’s Project, inside the “Basewide HPS” team. Click on the “Basewide” button to get to the “Basewide” project, inside the “Basewide HPS” team. “My page” is the starting page of the portal, and displays information aggregated and customized for you.
S
S
S
S
S
S
S
S
S
S
The Portal comes with ten default “gadgets”:
My Project Search
My Projects
Parcel Map
My Announcements
My Calendar
My Documents
My Tasks
HPS Report Status
Query Tool
Mapping Tool
Module: Systematic Planning
SP-110
Procurement and Contracting Considerations
EPA SP-57
•
Notes:
The procurement strategy for a site includes a number of elements: soliciting proposals, selecting the appropriate contract types, and executing options on an as-needed basis.
Procurement practices should match site conditions with appropriate technologies to maintain the flexibility to address unforeseen conditions as they arise in the field. As mentioned previously EPA’s Office of Superfund Remediation and Technology Innovation (OSRTI) formerly the Technology Innovation Office (TIO), has prepared a draft procurement guide to assist project managers, consultants, site owners, and technology vendors in understanding procurement options for innovative approaches to characterization and monitoring at hazardous waste sites. The procurement guide covers:
S Elements of a successful procurement: preparing SOWs and requests for proposals
(RFPs) and selecting contract types and bidding systems
S
S
S
Evaluating proposals: technical approach, qualifications, and costs
Procurement tools and resources: electronic resources, publications, periodicals, and vendor and technology information
Case studies in successful procurements involving the Triad Approach
SP-111
Module: Systematic Planning
•
•
•
•
•
Procurement and Contracting Considerations
Systematic planning identifies the constraints that factor into building site-specific unit costs and ensures that all data collected and analyzed support the specific objectives of the site. Thus, the project team should prepare a detailed statement of work based on the systematic plan before a request for proposal is issued. This SOW will provide adequate guidelines for bidders to supply unit cost estimates that match project needs. If development of the systematic plan itself requires contractor support, use of a separate contract mechanism earlier in the process also assures more efficient use of resources. In this way, the required expertise and equipment can be identified before a contractor is procured for the actual investigation.
Decision makers must not only develop a systematic plan and understand technological constraints to develop unit costs; they must also understand the logistics of procurement.
Identifying qualified firms and candidate technologies is the first step of the procurement process. Once again, this step cannot be taken successfully without a well-defined systematic plan. Consulting with technology vendors and service suppliers during the conceptual phase of a project, long before a request for proposal is issued, is paramount to identifying the appropriate expertise, technical approaches, and resource requirements for a project. During the planning stage, the users may interview numerous vendors to check the project design.
Preparing a comprehensive request for proposal is the next step toward a successful procurement.
There are two elements of a comprehensive request for proposal. First, the user develops a complete and thorough description of the work (statement of work) based on vendor information and site-specific constraints identified when the systematic plan is developed. This statement of work should include contingency scenarios. Costs for contingencies should be estimated and activities unitized, but the costs may or may not need to be paid, depending on discoveries that are made as a project progresses.
Second, the user selects a contract type that matches the information known about the site and the types of decisions to be made. The contract agreement will dictate how the project is implemented. Hence, selecting the appropriate contract type is a critical step in project implementation. Several factors affect selection of the contract type. They include:
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The decision maker’s contractual obligations
The contract scope
The flexibility required to meet project objectives
When services are procured for projects using the Triad Approach, maximum flexibility must be maintained while costs are controlled. As discussed above, a preference is developing among most government as well as private users for a fixed unit price/requirements type contract when the SOW can be at least fairly well defined, even if options are identified. In this type of contract, both the vendor and the user agree to share some of the risk related to unknown factors that can alter the scope of a project.
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Developing effective unit costs requires anticipating how work will likely progress and how modifications to the needs of the project will address unknown conditions. When innovative technologies are used, it is necessary to consult a core technical team to detail project-specific requirements. The user must factor requirements for personal protective equipment (PPE), back-up equipment and personnel, sample throughput, documentation, and timing of activities under the dynamic work plan into the unit cost structure. Cost-type contracts and firm-fixed price contracts generally are difficult to implement when a dynamic work plan approach is applied. The fixed unit cost contracts that are becoming the preferred option under the Triad
Approach can appear similar to a cost-type contract when little is known about a site. As more is discovered and the work becomes better defined, this type of contract can appear similar to a firm-fixed price contract that allows for cost growth as well as some decrease in scope and cost.
Developing the cost units for the project also requires an understanding of the capabilities and limitations of the technologies to be used on the project. New tools and technologies are continuously being invented to improve and streamline environmental data collection. Knowing the advantages, limitations, and costs of field-based technologies will facilitate efficiency.
Dynamic work plans, if appropriately applied, can limit mobilization costs. Unit costs allow for increase or decrease in the scope of work as necessary to make decisions with a higher degree of certainty. More information can be found in the Brownfields Technology Primer:
Requesting and Evaluating Proposals That Encourage Innovative Technologies for
Investigation and Cleanup ( http://www.brownfieldstsc.org/Docs/rfpfinal.pdf
).
After the statement of work is written and contingencies have been identified, the bid evaluation process begins. Evaluating proposals requires assessing the technical approach, personnel qualifications, corporate experience, design of the quality assurance (QA) and quality control
(QC) program, cost proposals, and insurance coverages. The best contractor may be selected using these criteria. When a contractor is selected, unit costs and rates can be refined, along with the project schedule, between the buyer and seller. Ongoing project management often involves reevaluating unit costs and contract activities throughout the project. More information can be found in Assessing Contractor Capabilities for Streamlined Site
Investigations ( http://www.brownfieldstsc.org/Docs/ContractorCap.pdf
).
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Contract Type
Cost Plus Fixed Fee (CPFF)
Contractor reimbursed for all expenses is predetermined.
Cost Plus Award Fee (CPAF)
Contractor reimbursed for all expenses. Contractor fee is based on performance
Time and Materials
Fixed labor rates
Firm Fixed Price (FFP)
Buyer pays specified price to seller upon completion of specified services (also, lump sum)
Advantages
• Fee remains fixed even if costs rise
• Used when the up front LOE is unknown
• Standard type of cost reimbursement contract
• Negotiate task orders as needs arise
• Motivates contractor to improve performance
• Suitable for uncertain requirements
Disadvantages
• Indirect rates may be subject to adjustment long after project completion
• Risk of additional cost to permit completion of work
• Costly to administer
• Incentive is subjective and requires extensive analysis and substantiation
• Expensive to administer
• Work does not need to be exactly defined
• Fixed rate per labor hour includes overhead and profit
• Materials supplied at cost
• Simple Procurement to evaluate
• The fixed price is not subject to adjustment
• Seller liable for completion of services
• Minimum administration
• No incentive to complete services
• No incentive to control cost
• Can only use if scope of services is very well defined.
• Contractor may cut corners
• Expensive because contractor includes cost of risk in bid
The basic types of contracts typically used for environmental projects include fixed-price and cost-reimbursable. The decision about the type of contract to be used will be project specific, depending on a number of factors, including whether the scope and schedule of the project are clearly defined, the type of contingencies expected, and the requirements specific to the procuring entity (government or private).
Cost-reimbursable contracts (such as, cost plus or time and materials contracts) are generally used when there is some uncertainty in the scope of the project. Under this type of contract, the contractor is reimbursed based on actual costs at a negotiated markup and fee (profit).
Risks associated with uncertainty in the project scope are borne by the contracting organization. Although they offer significant flexibility, cost-reimbursable contracts are generally the most expensive to administer and offer reduced incentive for contractors to be cost efficient.
Fixed-price contracts are generally used when the scope of a project is well defined. Under a fixed-price contract, the contractor agrees to complete the specific work for the price stated in the contract and assumes any risk of cost overruns. When allowable, any change to the scope of the project generally requires a formal change to the contract (a change order) to raise the contract ceiling. Fixed-price contracts are among the easiest types to administer and encourage efficiency in contractor work since the level of profit realized depends on a contractor’s ability to control costs. However, fixed-price contracts can result in relatively inflexible project activities, with significant institutional disincentives to modify activities once work is under way.
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There are several variations on these contract types of contracts. Fixed-price contracts may be non-negotiable, such as in firm-fixed price contract types, or may include incentives, such as in fixed-price-incentive contracts. Alternatively, fixed prices may be established for specific tasks or units of activities. Cost-reimbursement contracts may include cost-plus-fixed-fee, cost-plus-award-fee, and cost-plus-incentive-fee contracts. Fixed-price and cost-reimbursable contracts can be further defined by their schedule and quantity requirements. Both fixed-price and cost-reimbursable contracts can be described as indefinite delivery contracts, including the following:
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Definite-quantity contracts specify the quantity of supplies or services to be delivered within a fixed time period.
Requirements contracts provide for filling defined purchase requirements for supplies or services during a contract period by placing orders.
S Indefinite-quantity contracts provide for an indefinite quantity, within stated limits, of supplies or services within a fixed period; also known as task order or delivery order contracts.
• For example, a fixed-price contract for investigation services can be described as an indefinite-delivery/indefinite-quantity (ID/IQ) contract. ID/IQ contracts allow the buyer flexibility in both the quantity of services to be procured and in scheduling of those tasks.
Contract Type
Fixed Unit Price/Requirements
(Hybrid Contract)
Unit rates established for all services and costs reimbursed for actual quantities performed or delivered (also Fixed Price level of effort [LOE])
Mixed Contract
Project divided into well-defined and flexible components. Welldefined elements procured by fixed price, flexible elements through cost reimbursable
Contract Options
Contingencies and scope uncertainty handled through optional scope and costing
Advantages
• Work need not be precisely described in advance
• Unit prices or rates are locked in
• Flexible structure of costcontrol
• Accommodates options for potential work
• Balances risk between buyer and seller
• Balances flexibility and quality with cost management
• Fine tunes contract, identifying the most appropriate mechanism for each scope element
• Contingencies can be implemented without delay during the field program
• Can designate fixed price or cost reimbursable mechanisms for options, whatever is most appropriate
Disadvantages
• Once units are generated for logically connected activities, it may be difficult to revise these units
• SOW performance objectives must be defined clearly to enable bidders to estimate quantity
• More complex and difficult to administer
• May encounter ambiguity in identifying and apportioning flexible versus non-flexible work elements as the project proceeds
• Works only for well-defined options and contingencies
• Not all contingencies can be anticipated or defined with sufficient certainty
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Detailed, unitized cost structures are becoming a preferred a way to promote flexibility and manage changes in project activities under accelerated site characterization strategies such as the Triad. The essence of this approach is the identification of logical groups of services and supplies that can be assigned costs and tracked as units. Cost units that are built to match project requirements can be tracked easily and changed as the scope of the project requires.
Unitization is an essential element of environmental procurement because it allows vendors and project managers to adjust to dynamic changes in the project, while still providing an element of protection against unknown conditions. Unitization also allows both buyers and sellers to share the risk associated with changes in the project. For the sellers, unit costs cover the actual costs and assure a reasonable profit. For the buyers, unit costs assure that they will pay only for the services required. Buyers and sellers must understand site constraints, contracting options, and the capabilities and limitations of specific technologies to develop viable cost units. In such an environment, project managers must understand project constraints and be familiar with the intricacies of the technology applied.
Flexibility, unitization, and other features that facilitate the Triad approach can be incorporated into the following contract options that also provide efficiency incentives to contractors:
S Hybrid Contracts . An example of a hybrid contract is a fixed unit cost and requirements contract. For this type of contract, unitized costs are treated as fixed-cost items, while the number of activity units is left open. This type of contract resembles a cost-reimbursable contract for sites where significant uncertainty exists regarding project outcomes. However, it more closely resembles a fixed-price contract as the
CSM matures and uncertainty is removed from both decision making and the project scope. The key to this type of contract is a unitized costing structure. Performance awards can be included in this type of contracting mechanism to further encourage contractor efficiency.
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Mixed Contracts . Under a mixed-contracts paradigm, project activities are divided into two basic sets: one where the scope is well defined and known with a high level of certainty (for example, the costs associated with work plan development), and a second where the scope is more uncertain (for example, waste disposition). The former are procured through fixed-price contracting mechanisms, while the latter are addressed through a cost-reimbursable or hybrid contract. The point is to select the contracting mechanism for subsets of project activities that is the most appropriate for the expected level of flexibility required for a successful project outcome.
Contract Options . In cases where contingencies are well-defined for a Triad-based activity, a contract option added to the main contracting vehicle may make sense for handling uncertainty in the scope. Well-defined contingencies occur when a possible
(even if unlikely) project outcome has been clearly identified. For contingencies where the scope is less certain, a cost-reimbursable option may be appropriate. A fixed-price contract option would make sense for a contingency where the scope would be fixed.
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