CEMP-RT

Engineer Manual200-1-2

Department of the ArmyU.S. Army Corps of Engineers

Washington, DC 20314-1000

EM 200-1-2

31 August 98

Environmental Quality

TECHNICAL PROJECT PLANNING (TPP) PROCESS

Distribution Restriction StatementApproved for public release; distribution is

unlimited.

EM 200-1-2 31 August 1998

ENVIRONMENTAL QUALITY

TECHNICAL PROJECT PLANNING(TPP) PROCESS

ENGINEER MANUAL

This Engineer Manual is approved for public release, distribution is unlimited.

AVAILABILITY

Electronic copies of this and other U.S. Army Corps of Engineers (USACE)publications are available on the Internet athttp://www.usace.army.mil/inet/usace-docs/. This site is the only repositoryfor all official USACE engineer regulations, circulars, manuals, and otherdocuments originating from HQUSACE. Publications are provided inportable document format (PDF).

CEMP-RT

ManualNo. 200-l-2

DEPARTMENT OF THE ARMYU. S. Army Corps of EngineersWashington, D.C. 20314-1000

EM 200-l-2

31 August 98Environmental Quality

TECHNICAL PROJECT PLANNING (TPP) PROCESS

1. Purpose. This Engineer Manual (EM) describes the Technical Project Planning (TPP) processfor identifying project objectives and designing data collection programs at hazardous, toxic, andradioactive waste sites, The TPP process helps ensure that the requisite type, quality, andquantity of data are obtained to satisfy project objectives that lead to informed decisions and sitecloseout. The TPP process can be used from investigation through closeout at small, simple sitesas well as large, complex sites. The TPP process is a critical component of the U.S. Army Corpsof Engineers (USACE) quality management system that meets the American National Standardfor planning the collection and evaluation of environmental data. This EM is intended for use byUSACE project managers and both technical and contractor personnel for implementation ofEngineer Regulation (ER) 5-1-11.

2. Applicability. This EM applies to all HQUSACE elements and USACE commandsresponsible for hazardous, toxic, and radioactive waste projects.

3. References. References are listed in Appendix A.

4. Distribution. Approved for public release, distribution is unlimited.

5. Discussion. The four-phase TPP process is a comprehensive and systematic planning processthat will accelerate progress to site closeout within all project constraints, Project objectives areidentified and documented early during Phase I of the TPP process to establish the focus requiredto achieve site closeout for the customer. Phases II and III provide a framework to develop datacollection options for the customer’s consideration during Phase IV. The project-specific dataquality requirements established throughout the TPP process are then documented as data qualityobjectives during Phase IV. Many other documentation tools within this EM also encouragedetailed data collection planning and contribute to maintaining institutional site knowledge.

FOR THE COMMANDER:

7 Appendices(See Table of Contents) Major General, USA

Chief of Staff

This manual supersedes EM 200-1-2 dated 31 July 95.

v Printed on Recycled Paper

i

DEPARTMENT OF THE ARMY EM 200-1-2U. S. Army Corps of Engineers

CEMP-RT Washington, D.C. 20314-1000

ManualNo. 200-1-2 31 August 98

Environmental QualityTECHNICAL PROJECT PLANNING (TPP) PROCESS

Table of Contents

Subject Paragraph Page Subject Paragraph Page

FOREWORD . . . . . . . . . . . . . . . . . . . . 1

CHAPTER 1IDENTIFY CURRENT PROJECT (PHASE I)

PREPARE TEAM INFORMATION PACKAGE . . . . . . 1.1 1-2Identify TPP Team Members . . . . . . . . . 1.1.1 1-2Identify Customer Goals . . . . . . . . . . . . 1.1.2 1-5Gather Existing Site Information . . . . . . 1.1.3 1-6

IDENTIFY SITE APPROACH . . . . . . 1.2 1-7Evaluate Site Information and Data . . . . 1.2.1 1-8Identify and Document Project Objectives . . . . . . . . . . . . . . . . . . . . . . . 1.2.2 1-10Identify Regulator and CHAPTER 3 Stakeholder Perspectives . . . . . . . . . . . 1.2.3 1-12Define Probable Remedies . . . . . . . . . . 1.2.4 1-12Identify Executable Stages to Site Closeout . . . . . . . . . . . . . . . . . . . . . . . . 1.2.5 1-13

IDENTIFY CURRENT PROJECT . . . 1.3 1-14Recognize Site Constraints and Dependencies . . . . . . . . . . . . . . . . . . . . 1.3.1 1-14Define Courses of Action for Achieving Site Closeout . . . . . . . . . . . . . . . . . . . . . 1.3.2 1-16Document Current Executable Stage . . 1.3.3 1-18

COMPLETE PHASE I ACTIVITIES . . 1.4 1-18Finalize Acquisition Strategy . . . . . . . . . 1.4.1 1-18Initiate Scope of Work Sections . . . . . . 1.4.2 1-19Prepare Phase I Memorandum for Record . . . . . . . . . . . . . . . . . . . . . . . 1.4.3 1-19

CHAPTER 2DETERMINE DATA NEEDS (PHASE II)

DETERMINE DATA NEEDS . . . . . . . 2.1 2-1Review Phase I Memorandum for Record (MFR) . . . . . . . . . . . . . . . . . 2.1.1 2-1Establish Data User’s Roles . . . . . . . . . 2.1.2 2-1Evaluate Use of Existing Data . . . . . . . 2.1.3 2-4Define Data Needs . . . . . . . . . . . . . . . . . 2.1.4 2-4

DOCUMENT DATA NEEDS . . . . . . . 2.2 2-9

COMPLETE PHASE II ACTIVITIES . . . . . . . . . . . . . . . . . . . . 2.3 2-10

DEVELOP DATA COLLECTION OPTIONS(PHASE III)

PLAN SAMPLING AND ANALYSIS APPROACH . . . . . . . . . . . . . . . . . . . . . 3.1 3-1Review Phase I and Phase II Information . . . . . . . . . . . . . . . . . . . . . . 3.1.1 3-1Plan Sampling and Analysis Approaches . . . . . . . . . . . . . . . . . . . . . . 3.1.2 3-2

DEVELOP DATA COLLECTION OPTIONS . . . . . . . . . . . . . . . . . . . . . . 3.2 3-8Basic Data Collection Option . . . . . . . . 3.2.1 3-8Optimum Data Collection Option. . . . . 3.2.2 3-8Excessive Data Collection Option . . . . . 3.2.3 3-8

DOCUMENT DATA COLLECTION OPTIONS . . . . . . . . . . . . . . . . . . . . . . . 3.3 3-9

COMPLETE PHASE III ACTIVITIES . . . . . . . . . . . . . . . . . . . . 3.4 3-10

EM 200-1-231 Aug 98

Subject Paragraph Page

ii

CHAPTER 4 APPENDIX FFINALIZE DATA COLLECTION PROGRAM WORKSHEETS FOR (PHASE IV) DOCUMENTATION . . . . . . . . . . . . . F-1FINALIZE DATA COLLECTION PROGRAM . . . . . . . . . . . . . . . . . . . . . 4.1 4-1Prepare Customer Communications . . . 4.1.1 4-1Encourage Customer Participation . . . . 4.1.2 4-2Suggest Regulator Participation . . . . . . 4.1.3 4-3Consider Participation of Others . . . . . . 4.1.4 4-3DOCUMENT DATA COLLECTION PROGRAM . . . . . . . . . . . . . . . . . . . . . 4.2 4-4Prepare Data Quality Objective Statements . . . . . . . . . . . . . . . . . . . . . . . 4.2.1 4-4Prepare Final Scope of Work or Work Plan . . . . . . . . . . . . . . . . . . . . . 4.2.2 4-5Prepare Detailed Cost Estimate . . . . . . . 4.2.3 4-5Prepare Fact Sheet(s) . . . . . . . . . . . . . . . 4.2.4 4-5COMPLETE PHASE IV ACTIVITIES . . . . . . . . . . . . . . . . . . . 4.3 4-6

CHAPTER 5IMPLEMENT AND ASSESSDATA COLLECTION PROGRAM IMPLEMENTATION OF DATA COLLECTION PROGRAM . . . . . . . . 5.1 5-1AMENDMENTS TO DATA COLLECTION PROGRAM . . . . . . . . 5.2 5-1VERIFICATION OF DATA QUALITY OBJECTIVE ATTAINMENT . . . . . . . 5.3 5-1ASSESSMENTS OF TPP EFFORTS . 5.4 5-1PLANNING SUBSEQUENT DATA COLLECTION PROGRAMS . . . . . . . 5.5 5-2

APPENDIX AREFERENCES . . . . . . . . . . . . . . . . . . A-1

APPENDIX B Phase I MFR Worksheet . . . . . . . . . . . . F-7ABBREVIATIONS AND Data Need Worksheet-Risk Perspective F-13ACRONYMS . . . . . . . . . . . . . . . . . . . . B-1

APPENDIX CDEFINITIONS . . . . . . . . . . . . . . . . . . C-1

APPENDIX DOUTLINE OF TPP ACTIVITIES . . D-1

APPENDIX ECROSSWALK TO EPA’s7-STEP DQO PROCESS . . . . . . . . . . E-1

APPENDIX GVERIFICATION OFDQO ATTAINMENT . . . . . . . . . . . . . G-1

FIGURES

Subject Figure Page

Effects of Optimal Planning . . . . . . . . . . 1 5Phase I of Four-Phase TPP Process . . . 1-1 1-1Phase II of Four-Phase TPP Process . . . 2-1 2-1Phase III of Four-Phase TPP Process . . 3-1 3-1Phase IV of Four-Phase TPP Process . . 4-1 4-1Technical Project Planning (TPP) Process . . . . . . . . . . . . . . . . . . . . D-1 D-1Alignment Between EPA’s 7-Step DQO Process and the TPP Process . . . E-1 E-2

TABLES

Subject Table Page

Outline of TPP Activities . . . . . . . . . . . . D-1 D-2Crosswalk from 7-Step DQO Process to the TPP Process . . . . . . . . . . . . . . . . E-1 E-3

WORKSHEETS

Worksheet Page

Project Objectives Worksheet . . . . . . . . F-3Site Information Worksheet . . . . . . . . . . F-5

Data Need Worksheet-Compliance Perspective . . . . . . . . . . . . . . . . . . . . . . F-17Data Need Worksheet-Remedy Perspective . . . . . . . . . . . . . . . . . . . . . . F-21Data Need Worksheet-Responsibility Perspective . . . . . . . . . . . . . . . . . . . . . . F-25Sampling and Analysis Planning Worksheet F-29Summary Table of Data Collection Options . . . . . . . . . . . . . . . . . . . . . . . . . F-33Data Quality Objective Worksheet . . . . F-37DQO Attainment Verification Worksheet . . . . . . . . . . . . . . . . . . . . . . . G-2

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Foreword

Investigating, remediating, and closing best meets the customer’s short- and long-termhazardous, toxic, and radioactive waste needs within all project and site constraints.(HTRW) sites is complex. On many occasions,new people get involved in a project and siteconditions or remediation progress is unknown The TPP process is needed when initiallywhen efforts begin. Progress at a site is iterative planning any activities at a site (i.e.,as more is learned about a site, and as regulatory investigation; design; construction, operationand legal issues are identified and resolved. and maintenance; or long-term monitoring).

This manual describes the Technical Project after a customer requests that a project bePlanning (TPP) process for identifying project performed at a site and also when planning theobjectives and designing data collection next executable stage of site activities.programs at HTRW sites. The TPP process wasdeveloped to provide comprehensive planningguidance to ensure effective and efficient Readers of this manual and users of the TPPprogress to site closeout within all project process are encouraged to become familiar withconstraints. Chapters 1 through 4 describe how the following key terms and concepts.to conduct Phase I through Phase IV of the TPPprocess, respectively. Chapter 5 describesimplementation and assessment of data The TPP team is identified during Phase I, andcollection programs resulting from the use of works together throughout the TPP process andthe TPP process. the subsequent execution of the work. The TPP

The following discussions offer a uniform personnel to represent the following planningtechnical basis for the broad range of readers perspectives.using this manual and the TPP process.

What is the TPP process? manager, regulators, and stakeholders).The TPP process is a systematic process thatinvolves four phases of planning activities.Phase I activities bring together a TPP team toidentify the current project and to documentboth short- and long-term project objectivesthrough completion of all work at a site (sitecloseout). Phase II efforts involve an evaluationto determine if additional data are needed tosatisfy the project objectives. The data needrequirements for the additional data are thenidentified during the balance of Phase II efforts.Phase III activities involve identifying theappropriate sampling and analysis methods for

the data needed. During Phase IV, the TPPteam finalizes a data collection program that

When is the TPP process needed?

The TPP process should be used immediately

Key Terms and Concepts

TPP Team

process requires a multi-disciplinary team of

C Decision Makers (i.e., customer, project

Decision makers each have specific interestsin the outcome of site-related activities. Themost important responsibility of eachdecision maker is to participate in the team’sefforts to identify and document projectobjectives during Phase I. As deemedappropriate by the customer, the regulatorsand stakeholders may also contribute to TPPactivities during Phases II through IV. (Thecustomer is the person representing thefederal agency or sponsor, who is fundingthe project and responsible for completingwork at the site or facility.)

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C Data Users (i.e., risk, compliance, remedy, Site Closeoutand responsibility perspectives). Data usersare the technical and other personnelresponsible for engineering, scientific, andlegal evaluations that are the basis for sitedecisions. Data users participate throughoutthe TPP process. Their primaryresponsibilities occur during Phase I andPhase II when they identify the data neededto satisfy the project objectives that requireadditional data collection. Several technicaldisciplines typically must collaborate toadequately represent these data userperspectives:

Risk Perspective(evaluates potential risks to human healthand the environment);

Compliance Perspective(evaluates, monitors, and ensures legal andregulatory compliance);

Remedy Perspective(identifies, designs, constructs, operates, andmaintains site remediation systems); and

Responsibility Perspective(focuses on the customer’s potential liabilityand the apportionment of responsibility withother potentially responsible parties).

C Data Implementors (i.e., sampling andanalysis perspectives). Data implementorsare the technical personnel who areresponsible for identifying sampling andanalysis methods suitable for satisfying thedata users’ data needs. Both sampling andanalysis types of data implementorsparticipate throughout the TPP process withtheir primary responsibilities occurringduring Phase I and Phase III.

Site closeout is achieving the “walk away goal,”or final condition of a site, as envisioned by thecustomer. Site closeout represents achievingeither an interim final condition (e.g., expeditedremoval, remediation with 5-year reviews) orfinal completion of all work at a site. DuringPhase I, the TPP team develops an effective sitecloseout statement after considering future landuse of the site; the site’s regulatory compliancestatus and issues; and the customer’spreferences for the final condition of the site. Agood definition of site closeout enables the TPPteam to focus planning and site activities fromthe current site status and condition through anynecessary remediation; operation andmaintenance; or monitoring efforts.

Project ObjectivesProject objectives must be satisfied or resolvedin order to progress from the current site statusand condition to site closeout. Satisfying orresolving the project objectives, based on theunderlying regulations or site decisions, is thepurpose of all site activities. Phase I efforts toidentify and clearly document project objectiveswill ensure that the team establishes the focusrequired to successfully address the site-specificregulatory status and environmental conditions.Although many project objectives are aconsequence of the applicable federal, state, andlocal regulations, several other customer- orsite-specific project objectives may need to bedocumented to ensure efficient progress to sitecloseout. If project objectives are either vagueor undefined, it is unlikely that meaningfulprogress can be made toward achieving sitecloseout. Once all project objectives have beenidentified, and both customer and regulatorconcurrence is obtained, the team works togroup the project objectives in relation tocurrent and future executable stages of siteactivities through site closeout.

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Basic, Optimum, and Excessive C “Excessive” Excessive project objectivesBasic, optimum, and excessive are simple termsused during the TPP process for classifyingproject objectives and grouping data needs.Although these terms are simple, their use isvery powerful throughout the TPP process.

C “Basic” Basic project objectives and data realize that select data needs, imposed orneeds are related to the current project. mandated by others, are not required toDuring the end of Phase I, the TPP team satisfy the basic or optimum projectidentifies the current project and the objectives. “Excessive” data needs exceedcorresponding “basic” project objectives. data need requirements of data users, butData need requirements for the current are grouped together during Phase III.project, as identified by various data user During Phase IV, the customer is briefedperspectives during Phase II, are then about technical and financial issues relatedgrouped together as the “basic” data to the “excessive” data collection option.collection option during Phase III. DuringPhase IV, the project manager and technicalpersonnel present the “basic” data collection Preparation of DQO statements during Phase IVoption for the customer’s consideration. is the culmination of many TPP activities.

C “Optimum” Optimum project objectivesand data needs are anticipated for futureexecutable project stages. Once the currentproject has been identified during the end ofPhase I, those project objectives associatedwith future executable project stages areclassified as “optimum” project objectives.Data need requirements for futureexecutable stages, as identified by variousdata user perspectives during Phase II, arethen grouped together as the “optimum”data collection option during Phase III.(Data needs grouped within the “optimum”data collection option represent only thosedata needs that would be cost-effective andprudent to fulfill during the current projecteven though the data use(s) is related to asubsequent executable stage of siteactivities.) During Phase IV, the projectmanager and technical personnel present the“optimum” data collection option for thecustomer’s consideration.

and data needs are neither related to thecurrent project nor future executable projectstages. A project objective is classified as“excessive” when it does not lead to sitecloseout. “Excessive” data needs areidentified during Phase II when data users

Data Quality Objectives (DQOs)

DQOs become formal documentation of thedata quality requirements. Effective use ofDQOs yield data of known quality, documentthe planning process, and establish a benchmarkto determine if data obtained from the siteactually meet the specified data needrequirements of the data users. DQOs producedas a result of the TPP process meet the U.S.Environmental Protection Agency’s definition ofa DQO and are project-specific statements thatinclude these nine data quality requirements:(1) Project objective(s) satisfied;(2) Data user perspective(s) satisfied;(3) Contaminant or characteristic of interest

identified;(4) Media of interest identified;(5) Required sampling areas or locations and

depths identified;(6) Number of samples required;(7) Reference concentration of interest or other

performance criteria identified;(8) Sampling method identified; and(9) Analytical method identified.

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Those individuals with experience usingthe TPP process are expected to providethe customer, project manager,regulators, stakeholders, and othertechnical personnel an introduction to theTPP process and this manual, whenbeginning to use the TPP process for asite. In many instances, it can be usefulto use the services of an independent TPPfacilitator to support and guide a team'sapplication of the TPP process.

Communication Strategy Tenets of TPP ProcessThis manual and the TPP process clearly The TPP process offers the project manager,advocate communication and documentation technical personnel, customer, regulators, andacross a TPP team. Beyond using the TPP stakeholders a systematic planning process forprocess, each TPP team should develop a identifying project objectives and designing datacommunication strategy that will work for the collection programs at small, simple sites as wellentire TPP team. Open, timely, and effective as large, complex sites. This manual and thecommunication between the customer, project TPP process expect a team to:manager, technical personnel, regulators, C Use the TPP process to establish anstakeholders, contractors, and laboratory effective team, open communications, andrepresentatives will result in a successful document specific project objectives;project, independent of the complexity of a site C Consider the consequences of unacceptableor a site’s issues. Some considerations related decisions or decision errors;to developing a communication strategy are as C Consider the data quality requirements;follows. C Consider data collection approaches,C How often, and by what means, does the including when expedited site

customer want to receive updates regarding characterization and field analytical andTPP efforts and project efforts? screening methods would be appropriate;

C How will communications with regulators C Decide how data needs can be balancedand stakeholders be maintained and who within project cost and schedule constraints;does the customer authorize for direct C Present data collection options for thecommunications, if anyone? customer’s consideration; and then

C How will worksheets, graphics, or tables be C Ensure that institutional site knowledge canused to improve the distribution of site be transferred to new people involved withinformation, data, and site decisions? a site through the use of various TPP

C How will information and resources be planning documents and worksheets.shared electronically (e.g., telephonefacsimile, electronic mail, express mail,restricted Internet site)?

C Should communication templates bedeveloped and included within work plansto ensure the entire team becomes involvedin developing, implementing, andmaintaining effective methods ofcommunicating information?

C How will the communication strategy andcommunication requirements be specifiedwithin scope of work documents to ensurethey are included in cost estimates?

C What, if any, decisions has the customerspecifically indicated the team has thecustomer’s authority to either make orcommunicate with other parties?

PR

OJE

CT

EX

EC

UT

ION

ST

YL

E

TIME

PLAN

DO

CHECK

FIN

ISH

Too little commitment to project planning.

IDEAL COMMITMENTTO PROJECT PLANNING

Too much commitment to project planning.

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In some instances, TPP teams havelearned that a series of half-day meetingsare sufficient for performing segments ofthe TPP process. In other instances, anoutside facilitator has introduced the TPPprocess to a TPP team and then helpedthe TPP team to apply the process andcapture the TPP plans for a project.

Effective and Timely PlanningA premise of the TPP process is that eachindividual contributing to a project has his/herown project execution style. Some individualsbegin site activities before planning, othersexhibit an ideal commitment to planning, andsome individuals may tend to over-plan projectactivities. The systematic TPP process enablesa project manager to achieve an appropriatebalance of project execution styles within a teamand ultimately accelerate overall progress to sitecloseout. The entire TPP team will find thattime spent planning reduces expensive time andefforts during the “do,” “check,” and “finish”stages of any project.

Figure 1 illustrates the following benefits ofeffective and timely planning:C Less time is expended to “check” and

“finish” a well planned project; andC Less overall time (and money) is expended

when early efforts are focused and the teamstrives to optimally plan a project.

Figure 1Effects of Optimal Planning (Nayatani 1994)

Phase I

Phase II

Phase III

Phase IV

IdentifyCurrent Project

DetermineData Needs

Develop DataCollection Options

Finalize DataCollection Program

· Prepare Team Information Package· Identify Site Approach· Identify Current Project

Existing SiteInformation

Customer'sGoals

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Reference and overview resources:C Foreword (pages 1-5);C Required and Related References

(Appendix A);C Abbreviations and Acronyms

(Appendix B);C Definitions (Appendix C); andC Outline of TPP Activities

(Appendix D).

Chapter 1Identify Current Project (Phase I)

The Technical Project Planning (TPP) process is both short- and long-term project objectivesa comprehensive and systematic planning through completion of all work at a site. Theprocess for identifying project objectives and Phase I efforts involve preparing a teamdesigning data collection programs at information package, determining an overall sitehazardous, toxic, and radioactive waste sites. approach, and identifying the current projectThe TPP process is integral to the program and focus for a site.project management business process, thecorporate management approach for managingall U.S. Army Corps of Engineers (USACE)programs and projects.

The four-phase TPP process helps to ensure thatthe requisite type, quality, and quantity of dataare obtained to satisfy project objectives thatlead to informed decisions and site closeout.Phase IV efforts to prepare data qualityobjective (DQO) statements is the culminationof many TPP activities. (Appendix E presents adetailed “crosswalk” from the TPP process tothe U.S. Environmental Protection Agency’s(EPA’s) 7-Step DQO Process, a similar Although Phase I activities are designed toplanning tool. ) “front-load” conflicts and decision making, the1

The TPP process should be used when initially compensates for the early commitment toplanning for any activities at a site (i.e., proactive planning and communication. Phaseinvestigation; design; remediation, operation and I TPP efforts will ultimately accelerate themaintenance; long-term monitoring), and when protection of human health and the environment,planning the next executable stage of site while expediting progress to the desired futureactivities where work is already ongoing. use conditions at a site.

Phase I (see Figure 1-1) activities bring togetherdecision makers and technical personnel toidentify the current project and to document

Figure 1-1Phase I of Four-Phase TPP Process

resultant project efficiency more than

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The TPP team concept emphasizes theneed to have all appropriate technicalplanning perspectives represented foreach project. Even on small, relativelysimple sites, the team should at leastobtain input from each technical planningperspective during the TPP activities.

1.1 PREPARE TEAM INFORMATIONPACKAGE.Preparation of a team information packageshould be a result of the initial Phase I activities.A team information package is an informalcollection of existing site information that iscompiled for reference by the entire team.Common components of a team informationpackage include these items:C List of individuals who constitute the multi-

disciplinary TPP team for the site;C Customer’s concept of site closeout;C Customer’s schedule and budget

requirements; Many perspectives of decision makers areC All correspondence to and from regulators, typically associated with a site. The customer,

including an index of the project file or PM, regulators, and stakeholders each haveadministrative record, if available; and specific interests in the outcome of site-related

C Existing site data, reports, illustrations, or activities. Decision maker input should bedrawings (that are available and pertinent). included during all TPP activities, but is most

1.1.1 Identify TPP Team Members.The TPP process requires a multi-disciplinary the planning process as possible, but direct inputteam of personnel to represent the planning is required during TPP Phases I and IV.perspectives of decision-making, data use, anddata implementation. The project manager The most important responsibility of the(PM) is responsible for ensuring that all the TPP decision makers is to participate in the team’sperspectives are represented within the multi- efforts to identify and document projectdisciplinary team of personnel. The PM should objectives during Phase I. Other responsibilitiesrely on the functional chiefs or department heads of the decision makers include contributing tofor assigning qualified members to project the team’s efforts to do the following:teams, keeping commitments made in C Define site closeout;management plans, and ensuring technical C Gather existing site information;processes produce the desired results. C Identify project constraints; and2

In general, several disciplines of technicalpersonnel will collaborate to represent each of 1.1.1.1.1 Customer.the data user and data implementor perspectives The customer is the person, representing thefor a site. For instance, a geologist, industrial Federal agency or sponsor, who is funding thehygienist, or chemist may support the risk, project and responsible for completing work atcompliance, or remedy data user perspectives, the site or facility. As such, the PM andwhile also contributing to the sampling or technical personnel always recognize andanalysis data implementor perspective. On small, respect the customer as the primary decisionrelatively simple sites, personnel implementing maker for all site decisions and activities.

the TPP process may perform multiple roles andsupport multiple perspectives.

1.1.1.1 Decision Makers.

critical during Phases I and IV. The concerns ofdecision makers should be introduced as early in

C Document the current executable stage.

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Therefore, the customer is a key member of C PM provides leadership to the multi-every TPP team. The PM should encourage the disciplined project team with responsibilitycustomer to participate throughout the TPP for assuring that a project stays focused onactivities and understand relevant uncertainties the customer’s needs and expectations; andassociated with each project. that the team takes effective, coordinated

1.1.1.1.2 Project Manager.Within the TPP process, the project manager 1.1.1.1.3 Regulators.(PM) is the decision maker responsible for Federal, state, and local regulators are theleading the team’s TPP efforts, progressing decision makers who may have jurisdictionaltowards site closeout, and meeting the authority to directly affect site closeout.customer’s expectations. Even in those Regulators may specify standards, criteria, andinstances where technical elements, contractors, guidance to be followed during siteor stakeholders significantly contribute to a characterization and remediation. Regulatorsproject, the PM remains responsible for may also establish schedules under Federalmaximizing the use of the TPP process. Facility Agreements that can stipulate penalties

The PM’s leadership role in the TPP process is possible jurisdictional authority should bemost apparent during Phases I and IV. During included in TPP efforts to ensure efficientPhases II and III, the PM should function more progress to site closeout. In particular,in a support role by responding to information regulator input is prudent during Phase I andneeds of the technical personnel who are portions of Phase IV. As deemed appropriaterepresenting data user and data implementor by the customer, regulators may also contributeperspectives. during Phase II and Phase III of TPP activities.

The TPP process supports a PM’s 1.1.1.1.4 Stakeholders.implementation of the following requirements of Stakeholders with interests in site activities andEngineer Regulation 5-1-11 : site closeout could include current property2

C PM is primary point of contact with the owners, Restoration Advisory Boards, and anycustomer; number of other individuals or special interest

C PM manages project resources, data, and groups. Concerns and ideas of stakeholderscommitments; should be considered during TPP efforts to

C PM provides leadership to a multi-discipline contribute to efficient progress to site closeout.project team in accordance with the project- Phase I of the TPP process includes a deliberatespecific management plan developed by the effort to determine and consider communityPM, customer, and other team members; interests and the perspectives of stakeholders.

C PM is responsible and accountable for A Phase IV activity encourages the preparationsuccessful completion and delivery of and distribution of fact sheets, whenassigned project to customer within appropriate, for communicating the dataestablished costs, schedules, and quality collection program to interested partiesparameters; and including stakeholders. As deemed appropriate

actions to deliver the completed project.

for missed milestone dates. Regulators with

by the customer, various stakeholders may alsoparticipate during Phase II and Phase III efforts.

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After the team has identified the currentproject by the end of Phase I, the PMshould re-examine the size andcapabilities of the TPP team and reviewboth in-house and contractor supportrequirements.

1.1.1.2 Data Users. C Sampling Data ImplementorData users are technical and other personnelresponsible for engineering, scientific, and legalevaluations that are the basis for site decisions.Progress to site closeout requires collaborativeinvolvement of many technical disciplines torepresent these data user perspectives:C Risk Perspective

(evaluates potential risks to human healthand the environment);

C Compliance Perspective(evaluates, monitors, and ensures legal and For each site, the team should include theregulatory compliance); decision makers and the necessary technical

C Remedy Perspective(identifies, designs, constructs, operates, andmaintains site remediation systems); and

C Responsibility Perspective(focuses on customer’s liability andapportionment of responsibility with otherpotentially responsible parties).

Some of the technical disciplines who supportthe data user perspectives include chemists;engineers (e.g., chemical, civil, cost,environmental, electrical, geotechnical, andmechanical); geologists; industrial hygienists;regulatory specialists; risk assessmentspecialists; and safety officers. Other personnelsupporting the data user perspectives includevarious types of scientists and legal counselpersonnel. The nature and complexity of aproject dictate the skills, technical disciplines,and personnel needed. All data users participatethroughout the TPP process, with their primaryefforts occurring during Phase I and Phase II.

1.1.1.3 Data Implementors.Data implementors are the technical personnelresponsible for identifying sampling and analysismethods to satisfy the data users’ data needs.Several technical disciplines may work togetherto adequately represent these data implementorperspectives during the TPP process:

(identifies appropriate sampling protocols);and

C Analysis Data Implementor(identifies appropriate analytical protocols)

Data implementors participate throughout theTPP process with their primary responsibilitiesoccurring during Phase I and Phase III.

1.1.1.4 Team Selection.

personnel to represent all of the data user anddata implementor perspectives. In somesituations, the PM will need to go beyond in-house resources to obtain the technicalpersonnel experienced or available for allaspects of the work. Technical support fromother offices or contractors may be required toensure all TPP team perspectives arerepresented for each site. The PM shouldconsider at least the following when identifyingtechnical resources needed for a TPP team:C Technical specialists from various functional

elements (e.g., planning, engineering,occupational safety and health, construction,operations, counsel, contracting) may beappropriate participants for a portion of theTPP activities;

C Real estate personnel should contributewhen site efforts involve property notcontrolled by the customer; and

C The customer may want to assign some oftheir technical personnel to the team.

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It is ultimately the PM’s responsibility tounderstand and monitor the customer'sgoals and changing needs as additionalsite information becomes available. ThePM is responsible for assessing thesechanging needs and their effect on projectplanning and execution.

Under the leadership of the PM, all TPP effortsshould be performed by in-house personnel orsome combination of in-house and contractorpersonnel. Once roles and responsibilities aredefined, the PM should determine and documentthe acquisition strategy(ies) for procuring anynecessary contractor support. Thedocumentation should include the rationalesupporting the acquisition strategy(ies) and theproject tasks that have not yet been assigned toeither in-house or contractor personnel.

1.1.2 Identify Customer Goals. the reasonably anticipated future land use.Identifying customer goals is a critical anddeliberate activity within the TPP process toensure that the customer's expectations areunderstood from the start of the planningefforts. A customer’s goals should be identifiedfor each site and then documented in the teaminformation package. In order to meet orexceed the customer's expectations, the PMmust then ensure that desired project activities,schedules, and budgets are consistent, and inaccordance with all applicable regulations.

Customer goals are defined by future land use atthe site, regulatory compliance, the customer’sschedule requirements, and the customer’s sitebudget.

1.1.2.1 Customer’s Concept of SiteCloseout.Site closeout is achieving the “walk away goal,”or the final condition of a site, as envisioned bythe customer. The development of an effectivesite closeout statement involves the followingconsiderations.

1.1.2.1.1 Future Land Use.Future land use assumptions allow site activitiesto be focused on developing practical and costeffective remedial alternatives consistent with

3

Although a customer may not have specificfuture use plans for a site, the PM and technicalpersonnel should at least narrow the range ofpotential future uses considered for a site. In allinstances, initial discussions with the customershould address anticipated future uses of a siteto seek the customer’s concurrence about futureuse scenarios (e.g., residential development,landfill construction) that can be eliminated. Itis important to recognize that future land useassumptions may be different at sites where afederal agency will not, or does not, maintaincontrol of the affected real estate. Finalselection of a reasonable future land use willalso require discussions with the customer,regulators, and stakeholders (e.g.; local land useplanning authorities; city, state, and federalofficials; the public; and current propertyowners), as appropriate.

1.1.2.1.2 Regulatory Compliance.A site’s current regulatory status [e.g.,site/facility listed on National Priority List;Resource Conservation and Recovery Act(RCRA) permitted facility] is also critical tounderstanding a customer’s concept of sitecloseout. The PM and technical personnelshould determine if the customer is aware of anyapplicable regulatory programs or requirementsand obtain copies of related regulatory

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correspondence such as a Federal FacilityAgreement or a RCRA permit.

1.1.2.1.3 Interim Site Closeout Goals.An interim site closeout goal (e.g., operable unitcloseout; completion of a site investigationphase; operation and maintenance of aremediation system, remediation with five-yearreviews) may also be useful to the team. Theseinterim closeout goals are only useful, however,if they are defined within the overall context ofthe customer's concept of final site closeoutconditions.

1.1.2.1.4 Site Closeout Statement.A site closeout statement should be documentedfor reference throughout the life of the project.A good definition of site closeout will focusefforts from the current site status and conditionthrough any necessary remediation, operationand maintenance, or monitoring efforts. Sitecloseout statements should also be revised if thecustomer’s vision for the site changes. A wellprepared site closeout statement will increaseproject efficiency by ensuring:C The team can visualize the physical

appearance of the site at closeout;C Team members can identify what actions are

required to achieve site closeout;C Phasing and timing constraints associated

with site closeout are understood; andC The customer’s intent for operation and

maintenance and monitoring are clear.

1.1.2.2 Customer’s Schedule bodies, property lines, site access, existing wellRequirements.Effective project planning requires that the team treatment systems).know all of the customer's short- and long-termschedule milestones to site closeout. The siteapproach must incorporate and fulfill the So that redundant data are not collected,customer’s schedule requirements and any determine and gather all existing site data andchanges to their requirements throughout the reports for reference and use by the team. Someproject activities. of the most pertinent data includes:

1.1.2.3 Customer’s Site Budget.The customer’s budget constraints must also beincluded in project planning. In particular, theteam needs to understand the customer's desiredinvestment and the customer's perception ofanticipated costs. The site approach must bedeveloped within the customer’s budgetconstraints. If a customer’s site budget changes,the changes need to be documented and thencommunicated to the team.

1.1.3 Gather Existing Site Information.Identify existing site information and gather themost pertinent data. (Appendix F provides aworksheet for listing any preliminary siteinformation needs identified during this TPPactivity.) Existing site information should becompiled and included within the teaminformation package. Not all of the followingactivities will be conducted as it is dependentupon the stage of site activities and the team’sexperience at the site.

1.1.3.1 Conduct Preliminary Site Visit.Technical personnel should consider conductinga preliminary site visit to identify all potentialsources of site information. Current andhistorical photographs of site conditions andoperations should be obtained. It may also bebeneficial to videotape the site and specificfeatures. Preliminary site visits should be usedto obtain site maps or drawings that depictcritical site features (e.g., historical land use,buildings, tanks, topography, surface water

locations, disposal/storage/staging areas, and

1.1.3.2 Gather Site Data and Reports.

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C Site maps; past, with the potential for contaminant releases.C Site and aerial photographs; It is also crucial for the responsibilityC Historical ownership information; perspective to be involved to assure properC Regulatory status of the site and facility; documentation is prepared and any relatedC Facility or site-related geology; substantiation is considered.C Hydrogeology, hydrology, climatology,

ecology, and demographic information;C Current and future land use information Efforts to identify a site approach involve

about areas adjacent to the site; development of an overall strategy for managingC Results and reports of previous site studies a site from its current condition to the desired

or investigations; site closeout condition. These TPP efforts areC Data quality control data (e.g., method critical because evolving schedule, financial,

blanks and duplicates), data usability political, and other constraints affect siteinformation or evaluations, and any support- activities from site identification through siteing data packages (partial or complete); and closeout. Without a planned site approach, the

C Known influence of other nearby sites. following situations can occur:

1.1.3.3 Obtain Operations Records.Obtain historical operations records about the but may not yield data of the sufficient type,facility or site to understand site features and quality, or quantity to enable site or projectpossible sources of contamination. decisions to be made at required times; and

1.1.3.4 Collect Background Literature.Collect background literature and obtain other in the context of the entire site. This cangeneral information (e.g., regional geology and result in site closeout delays whenhydrogeology; upstream and downstream subsequent site activities deviate from thoseNational Pollutant Discharge Elimination originally envisioned.System effluent information; and localnewspaper accounts) for use by the team as By performing the following TPP activities, thenecessary. Investigations on other nearby sites team can identify a site approach and be bettercan often be a source of relevant data. prepared to manage and consider the effects of

1.1.3.5 Conduct Site History Interviews.Discussions with former and current employees memorandum for record (worksheet provided inabout previous operations and waste handling Appendix F), or a series of specific TPPshould be planned with input from those memoranda, should be prepared to documentrepresenting the responsibility perspective. these critical elements of a site approach:Employees and personnel interviewed may C Preliminary Conceptual Site Model;include individuals involved with site operations, C Project Objectives (worksheet provided inpermitting, previous investigations, or Appendix F);environmental and engineering personnel C Stakeholder Perspectives;associated with the facility or site. This should C Probable Remedies; andinclude all users of the property, current and C Executable Stages to Site Closeout.

1.2 IDENTIFY SITE APPROACH.

C Data collection plans are modified as ashort-term solution to urgent constraints,

C A team will not be able to determine theimpacts of modifying current project plans

outside constraints and proposed changes todata collection programs. A Phase I

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1.2.1 Evaluate Site Information and Data.The PM should rely on individual technical logs, soil boring logs, soil classification data,personnel to evaluate the quality, reliability, and water quality information, and previous siteusability of existing site information and data. sampling reports). As their understanding of aTheir evaluation should result in the site’s physical characteristics improve, they maydevelopment of a preliminary conceptual site also draft or sketch some initial figuresmodel and the identification of potential points approximating site features.of compliance.

1.2.1.1 Review Site Information andData.Individual team members should be tasked to physical and chemical characteristics ofreview all of the existing site information and contaminants of interest. Knowledge of thedata for the site. Of particular interest during chemical characteristics will provide insight intothis review should be the site’s physical their behavior in the environment and theircharacteristics; the physical and chemical affinity to, or solubility in, media at the site.characteristics of the potential contaminants of Information such as solubility, retardationinterest; and the likely transport pathways. As constants, Henry's Law constants, vaporthese select team members begin their review pressure, and molecular weight can be used inefforts, the PM should clearly communicate the conjunction with an understanding of the site’sallotted time for conducting this preliminary physical features to understand behavior ofreview of the existing information and data. chemicals (e.g., transport, degradation,More exhaustive review and use of the data will persistence) in site media. Variation in detectedbegin during Phase II of the TPP process as contamination concentrations should also betechnical personnel begin to determine the noted to preclude invalid assumptions about siteadditional data needed at a site. These review contaminant homogeneity.efforts should only be preliminary and must befocused to help the team identify the site 1.2.1.1.3 Transport Pathways.approach and the current project as described Known and suspected source areas should bewithin Phase I of the TPP process. evaluated, using site characteristics, sampling

1.2.1.1.1 Site Physical Characteristics. physical characteristics, to predict possibleThose responsible for preliminary data review contaminant transport within various media andwill need to become familiar with the physical the migration of chemicals in the environment.characteristics of the site (e.g., topographic Typical transport pathways could includerelief, geologic and hydrogeologic features) and volatile organic chemical emissions, soil erosion,evaluate possible access limitations; proximity of storm water runoff, sediment deposition,source areas to the ground surface, leaching into groundwater and groundwatergroundwater, and surface water features; and recharge into surface water. At this point in theproximity of a site's source area(s) to other TPP process, review personnel may even beginknown or potential source areas. Their visual to identify contaminant transport models whichconceptualization may involve site visits and might be appropriate for evaluating transportreview of site information (e.g., topographic features at a site.

maps, geologic cross-sections, well installation

1.2.1.1.2 Physical and Chemical Characteristicsof Contaminants of Interest.A preliminary data review should consider the

data from previous studies, and chemical and

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1.2.1.2 Identify Preliminary ConceptualSite Model.The preliminary review efforts must be sufficientfor technical personnel to identify a preliminary As the team works to identify the site approachconceptual site model (CSM) for a site. A CSM and current project, the technical personnelis a written or pictorial representation of the should evaluate what is known about potentiallyenvironmental system at a site and the complete and incomplete exposure pathways atbiological, physical, and chemical processes that a site. If any of the four elements are missing,affect contaminant transport. EPA’s Risk the pathway is not complete and likely needs noAssessment Guidance for Superfund (for human further evaluation. Those exposure pathwaysand ecological risk) and the American Society of known, or suspected, to be complete need to beTesting Materials standard guide for developing represented for the team to efficiently proceeda CSM would be useful resources during this with Phase I of the TPP activities.TPP activity.4, 5, 6

A preliminary CSM would typically be used by the purposes of evaluating site compliancea team as a simple model of the relationships conditions, planning a removal or remedialbetween chemicals detected at a site and action, or evaluating potential contributions topotential exposure pathways to site receptors. a site by other potentially responsible parties.In order for an exposure pathway to becomplete, these four elements must be present:C A source and mechanism of release;C A retention or transport medium; Having prepared a preliminary CSM for a site,C A point of potential contact with the an attempt should be made to identify potential

contaminated medium; and points of regulatory compliance at the site.C An exposure route (e.g., ingestion) at the With assistance from those technical personnel

contact point with a receptor. responsible for the compliance data user

The review personnel should quickly draw a annotated with symbols to represent known orpreliminary CSM for each site. Depending upon potential points of compliance. Knowledge ofthe current site setting, it may be appropriate to at least some potential points of compliance atprepare preliminary CSMs for both human and a site will help the team remain focusedecological receptors at a site. In general, the throughout the balance of Phase I activities.technical personnel who support the risk datauser perspective are most experienced withpreparing a site’s CSM. Once drafted, even apreliminary CSM will help the entire team begin Another result of having prepared a preliminaryto visually organize all potential current and CSM is that media of potential concern shouldfuture exposure pathways at a site, and to be very apparent. Those site media directlyidentify whether or not they are complete. It affected by site contaminants, as well as theshould be evident that each distinct source area, transport media and any exposure media, shouldexposure route, and receptor relationship will each be designated as media of potentialform a separate exposure pathway. A typical concern at a site. Knowledge of at least some

site will have numerous exposure pathways thatwill require further evaluation by the team.

A preliminary CSM could also be developed for

1.2.1.3 Identify Potential Points ofCompliance.

perspective, the preliminary CSM could be

1.2.1.4 Designate Media of PotentialConcern.

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of the potential media of concern at a site will A TPP team may identify and document as manyhelp the team remain focused throughout the as 15 basic project objectives associated withbalance of Phase I activities. the current executable stage of site activities and

1.2.2 Identify and Document ProjectObjectives.Project objectives are the short- and long-term specific details documented within basic projectsite issues to be addressed and resolved at a site. objectives for a site.Satisfying or resolving the project objectives,based on the underlying regulations or sitedecisions, are the purpose of all site activities. The primary legal processes for most siteProject objectives must be documented to focus activities are the Comprehensive Environmentalthe team's thinking toward a specific set of Response, Compensation and Liability Actconcerns that can be addressed through the (CERCLA, commonly referred to asplanning and completion of an executable Superfund), as amended by the Superfundstage(s) at a site. Although identifying and Amendments and Reauthorization Act, anddocumenting the project objectives for a site can RCRA. Although CERCLA and RCRAbe relatively straightforward since most project contain similarities, data and documentationobjectives are a consequence of the governing requirements are different. It is imperative thatstatutes and applicable regulations, customer the team understand which of these laws, orand regulator concurrence on the project which other laws (i.e., Underground Storageobjectives is critical. (Appendix F provides a Tank, Toxic Substances Control Act, or Stateworksheet for documenting and managing RCRA), will govern site activities to ensure thatproject objectives during the TPP process.) appropriate requirements are considered.

Effective planning can only be accomplished The procedural requirements of the mainwhen the regulatory requirements are known governing laws are the promulgated regulationsand understood by the team. Regulatory in the Code of Federal Regulations (CFR). Justrequirements serve to establish a framework for a few specific examples of the detailed projectsite activities. Any legally binding agreements objectives imposed by some portions of(e.g., Federal Facility Agreements, Interagency CERCLA include the following:Agreements, site orders, permits); applicable or C ...eliminate from further considerationrelevant and appropriate requirements; and those releases that pose no significantmandatory schedule compliance dates should be threat to public health or the environment,identified and reviewed to establish the direction 40 CFR 300.420(c)(I);of proposed site activities. Within the context C Determine the general characteristics of theof the TPP process, the legal and regulatory waste, including quantities, state,requirements applicable to a site should be concentration, toxicity, propensity toclearly identified as project objectives. Project bioaccumulate, persistence, and mobility,objectives identified by the team should include 40 CFR 300.430(d)(2)(iii);only the specific and detailed objectives that C Determine applicable or relevant andmust be satisfied in order to progress toward appropriate requirements,and ultimately reach site closeout. 40 CFR 300.400(g); and

several optimum project objectives associatedwith future executable stages. Optimum projectobjectives will typically be more general than the

1.2.2.1 Primary Regulatory Processes.

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If the TPP process is initiated during theexecution of an ongoing project, it isessential for the team to identify anddocument project-specific objectives tofocus subsequent project activities.

C Evaluate the degree to which alternatives C Clean Air Actemploy recycling or treatment that reduces Determine the specific requirements fortoxicity, mobility, or volume, including how handling asbestos during demolition oftreatment is used to address the principal structures containing asbestos,threats posed by the site, 40 CFR 61.145(a);40 CFR 300.430(e)(9)(iii)(D). C Clean Water Act

Some states also have primacy over (i.e., can polychlorinated biphenyls for site remedialimplement and enforce) certain federal action waste water,requirements, such as hazardous waste 40 CFR 129.105; andmanagement under RCRA. In those instances C Safe Drinking Water Actwhen state programs have more stringent Determine maximum contaminant levels forrequirements than the federal program, state- inorganic contaminants in groundwater,specific project objectives should be defined and 40 CFR 141.11.documented to ensure the appropriateregulations are satisfied. Legal counsel As with primary regulatory programs, statespersonnel should also be consulted to determine may have primacy over secondary federalthe extent of state authority. regulatory programs. Therefore, the team needs

In those instances when a state has project objectives beyond federal requirements.implementation and enforcement authority forthe site’s regulatory program(s), the team willneed to determine the standards, criteria, and Project objectives beyond the primaryguidance that are required by the applicable regulatory process and secondary regulatorystate program. In these situations, the team programs must also be identified andshould define and document the project documented to ensure that all issues andobjectives to ensure the state’s requirements are requirements are addressed for a project. satisfied for the applicable program.

1.2.2.2 Secondary Regulatory Programs.Secondary regulatory requirements includefederal, state, or local regulations, andperformance criteria or standards to be metduring the current or future executable stages.Secondary requirements can dictate that data becollected to perform engineering, scientific, or If a customer wants site activities thatlegal evaluations. supplement those associated with the

Project objectives associated with secondary regulatory processes or secondary regulatoryregulatory programs are also found in the CFR programs, the PM and technical personnelor other regulatory statutes. A few examples should manage the customer needs by8

of specific project objectives that are detailed in designating specific project objectives for thevarious secondary regulatory statutes include: supplemental activities.

Determine required effluent standards for

to be aware of the potential for additional

1.2.2.3 Other Project Objectives.

administrative requirements of the primary

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Some data user perspectives may also determinethat specific project objectives are needed forsome aspects of the work. For example: After determining the primary regulatoryC Ecological and human health risk process, applicable secondary regulatory

assessments, not adequately addressed by requirements, and all related project objectives,current regulatory programs or guidance, the perspectives of the regulators should bemay necessitate that additional project obtained regarding these decisions and theobjectives be identified and documented; related project objectives. Regulators, as

C Remedy-specific project objectives may be possible decision makers who affect progress toappropriate and useful for evaluating the site closeout, must be consulted to gain theirsuitability of natural attenuation at a site due participation in the TPP process and team and toto the site-specific parameters that would understand and consider their expectationsneed to be investigated and considered in relative to a site. Efforts to determine regulatorthe design; perspectives should not be taken lightly or

C Industry-wide initiatives to identify, collect, overlooked. Well planned and timely meetingsand evaluate cost and performance data with the regulators early in the TPP process willrelated to the construction, operation, contribute to the success of the planned projectmaintenance, and monitoring of a remedial and the efficiency of progress to site closeout.technology; and

C The responsibility perspective at a site caninvolve legal counsel efforts to develop a Determine the status of any current or formercustomer's position and litigate community interest associated with the site.apportionment with other potentially Community interest input can contribute toresponsible parties at a site. These legal project success and efficient progress to site9, 10

counsel considerations may result in unique closeout.project objectives for each element ofresponsibility determination. For example,position development for a customer may If a site is still in an investigation stage, probablerequire a detailed search of ownership remedies should be defined so the overall siterecords or waste disposal data associated approach is consistent with the most likelywith another entity. remedial alternative should remedial actions be

1.2.3 Identify Regulator and StakeholderPerspectives.The customer, with support of the PM and the specific remediation technologies (e.g., soiltechnical or legal personnel in some cases, needs vapor extraction, landfill cover) that may beto solicit and monitor the perspectives of both applicable to a site if remediation is necessary.the regulators and stakeholders during the TPP However, in some instances, the team will onlyprocess to ensure their needs and concerns are be able to consider a general type or category ofunderstood. Both the site approach and current remedial technologies (e.g., containment,project should consider regulator and collection and removal, soil treatment) whenstakeholder perspectives that exist at a site. available site information and environmental

1.2.3.1 Determine RegulatorPerspectives.

1.2.3.2 Determine Community Interests.

9

1.2.4 Define Probable Remedies.

necessary. The team will want to consider allremedies potentially appropriate for a site.Whenever possible, the team should consider

data is limited.

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Once project objectives have beenidentified, technical personnel shouldevaluate and determine if the site isalready eligible for closeout. If enoughdata of an acceptable quality already existto satisfy all project objectives to sitecloseout, then the PM and technicalpersonnel should assist the customer inpetitioning the regulators for site closeoutand delisting, as appropriate.

If the customer’s goal is no further action, then efforts. Numerous sources of innovativeprobable remedies likely need not be identified. technology are available and a team should seekIn this situation, the team should document that input from several technical sources regardingthe remedy data user perspective is not application experience with specific innovativeparticipating because of the customer’s vision of technologies that may be viable for a site.site closeout.

When defining probable remedies for a site, theteam should consider both presumptive All possible executable stages to site closeoutremedies and innovative technologies that may should be identified by the team. The scope ofbe suitable for site conditions. an executable stage can be thought of as the site

1.2.4.1 Presumptive Remedies.Presumptive remedies are preferred technologies Executable stages should be designated from thefor common categories of sites, based on unfulfilled administrative requirements of theremedy selection and implementation applicable primary regulatory process (e.g.,experience. The team will find that a suitable CERCLA, RCRA) and secondary regulatorypresumptive remedy can do the following: programs (e.g., Clean Water Act, Clean AirC Accelerate the planning process; Act). Agreements, permits, and orders shouldC Provide consistency in remedy selection; also be reviewed as they may includeC Reduce the remediation schedule and requirements for particular work items or data

expenditures; and compilations, as well as consultation andC Achieve earlier site closeout. schedule obligations. The team must also

Note that the team's consideration of a each executable stage through site closeout. presumptive remedy should not preclude theirconsideration of an innovative technology,should an innovative technology prove to be aseffective or superior to a presumptive remedy.

1.2.4.2 Innovative Technologies.As stated in Section 300.430(a)(1)(iii)(E) of theNational Contingency Plan, “USEPA expects toconsider using innovative technology when suchtechnology offers the potential for comparableor superior treatment performance orimplementability, fewer or lesser adverseimpacts than other available approaches, orlower costs for similar levels of performance Depending on the size and complexity of thethan demonstrated technologies.” Therefore, it site, several executable stages may be necessaryis important that utilization of innovative and appropriate to proceed from the current sitetechnologies be considered for both site status and condition to site closeout. Only aftercharacterization and remediation during TPP all executable stages for a site have been

1.2.5 Identify Executable Stages to SiteCloseout.

activities scheduled to occur between milestonesalong the critical path timeline of site activities.

identify the project objectives that correspond to

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Even if a customer only requests servicesfor a single executable stage, it isappropriate to identify all executablestages and corresponding projectobjectives through site closeout. Withknowledge of at least some future projectobjectives, the team may be able to offerthe customer some significant costsavings by meeting data needs ofsubsequent executable stages when theircollection can be cost effective and agood business decision for the customer.

identified can the team identify the current Team members involved in identifying the siteproject for completing the first executable stage approach should contribute to recognizingof site activities. constraints and dependencies and their potential

1.3 IDENTIFY CURRENT PROJECT.After developing the overall approach for The PM should also identify any fundingmanaging a site from its current condition to the constraints that may affect project execution.desired site closeout condition, a team can work The team should be informed when funding forto identify the current project for a site. By site activities is available and what levels areidentifying the current project, a team can programmed for the next several years. Projectformulate a detailed strategy for completing the execution options should be developed in linecurrent executable stage of site activities. with funding obligations and within all fundingIdentification of a current project will also focus limitations.team efforts during TPP Phases II, III, and IV.

Due to the inherent complexity of identifying the investigations or subsequent remedial actionscurrent project, the PM and technical personnel will require access agreements, real estatemust obtain input from the customer, regulators, easements, or acquisition of property. Inand other stakeholders as appropriate. The PM instances where offsite contamination is knownshould consider leading some working team or suspected, the team will want to carefullymeetings as a means of promoting concurrence research real estate acquisition needs. The teamamong the decision makers. should recognize that site constraints and

1.3.1 Recognize Site Constraints andDependencies.Existing site information should be reviewed in acquisition. For example, specific-use purposesthe context of the overall site approach to established within a temporary permit should beidentify site constraints and dependencies that recognized as site constraints and dependenciesmay affect project planning and execution. during TPP efforts.

effects on the anticipated site activities. Inparticular, problems or constraints discoveredduring preceding work at the site should beidentified. These efforts should at least includeconsideration of administrative, technical, legaland regulatory issues.

1.3.1.1 Administrative Constraints andDependencies.The PM should identify any constraints ordependencies associated with differencesbetween the anticipated level and duration ofefforts required to satisfy the project objectivesand the availability of various technicalpersonnel on the team.

The team should consider whether site

dependencies may be associated with the legaldocuments used for real estate accessagreements, temporary easements, and property

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Involve occupational health and safetypersonnel to assure that any relatedtechnical constraints are identified and toproperly develop and implement sitesafety and health plans for site activities.11

In those instances when other potentially C Physical considerations would includeresponsible parties may be involved, the PM geographic location; site geology andshould specifically request that legal counsel topography; regional climatology; locationspersonnel identify which work may be of buildings, structures, pavements, under-performed at a site. Legal counsel should also ground or overhead utilities, and streams ordirect the team through any legal determinations ponds; slope stability within a trench orof liability, defenses, and allocation excavation; site access or securityrequirements. restrictions; on-going site activities; and

1.3.1.2 Technical Constraints andDependencies.Each member of the team should consider that experiences significant seasonaltechnical aspects of site activities that could variations in weather conditions. Foraffect project execution. Unanticipated example, extensive surface water samplingtechnical constraints and dependencies may would be difficult if typical winter weatherresult in ineffective data collection programs, results in frozen streams or ponds; or biotamisrepresentation of site conditions, and actions sampling during a habitat-stressed low flowthat are unsuccessful or even unnecessary. condition would not be representative of

The team should be proactive in its efforts to C Constraints related to spatial considerationsidentify any occupational health and safety range from issues such as deep groundwaterissues or concerns that present constraint or sampling cannot be performed until a deepdependency relationships related to a site. For well is installed, to identifying the presence11

example, site investigation and remediation and location of unexploded ordnance prioractivities will require both medical monitoring to intrusive site activities within areasand health and safety planning prior to all site known to have unexploded ordnance.activities. Occupational health and safety C Chemical considerations would include thestandards must also be addressed in design of presence of radioactivity; presence orsite remediation systems to ensure worker safety history of chemical agent testing or disposal;during both construction and operation and presence of volatile organic chemicals;maintenance activities at a site. known or suspected accumulation of

Examples of other technical considerations that effectiveness limited by depth or subsurfacemay enable the team to identify site constraints geology; vehicle access needs when usingor dependencies include the following. some direct push techniques; installation of

neighboring property uses.C Temporal considerations may present

several climate-related constraints at a site

typical site conditions.

methane in a landfill; and oxygen deficiencyor hydrogen cyanide accumulation insanitary and storm sewers.

C Field sampling considerations would includeefforts to prevent cross-contamination orthe creation of a new contaminant transportpathway; compliance with height or lightingrestrictions within flightline areas; sampling

temporary electrical service to support a

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Timely and proper management ofinvestigation derived wastes must be aconstraint and dependency considerationon every site that involves intrusivesampling or remediation activities.

mobile laboratory; and the need to earnregulator agreement for using appropriatefield screening and field analytical methods. At this step in the TPP process, the TPP team

C Analytical considerations might include the may find a brainstorming meeting very useful forpotential for matrix interferences; sample defining options for achieving site closeout.shipment measures required to meet holding Although the discussions that follow providetimes; laboratory services needed to perform examples of typical project execution options, itthe desired analytical protocols; and the data is important to recognize that several options tovalidation procedures to be employed. achieve site closeout may be combined into a

1.3.1.3 Legal and Regulatory Milestonesand Requirements. 1.3.2.1 Operable Units/Exposure Areas.Legal counsel and a regulatory specialist, either Designation of operable units or exposure areason the team as compliance data users, or at a site can be very useful for managing asupporting the team, should identify site con- complex site. Operable units are typicallystraints and dependencies related to legal and associated with suspected source areas orregulatory milestones and requirements. The affected media at a site. Exposure areas aremost significant regulatory constraints and typically areas at or adjacent to a site thatdependencies will typically involve the primary include a related group of exposure pathways,regulatory process for a site; the applicable or involve a common receptor, and can be easilyrelevant and appropriate requirements; and any identified on the preliminary CSM. The team'sagreement, permit, orders, or record of a notice designation of operable units or exposure areasof violation. Schedules and compliance dates will typically promote more focused siteestablished within RCRA permits, Federal activities and accelerate progress to siteFacility Agreements, and other types of closeout for both the operable units or exposurecompliance agreements; as well as state-specific areas and an entire site.regulations and guidance; must also beconsidered when identifying a site’s regulatorymilestones and requirements. The team must be Given that significant volumes of data now existsure to review any agreements, permits, or at many sites, expedited removal is anotherorders as they may include requirements for execution option that warrants seriousparticular work items or technical evaluations, consideration. Removal actions (time critical oras well as consultation and schedule obligations. non-time critical) and interim remedial actions,

1.3.2 Define Courses of Action forAchieving Site Closeout.

single executable stage. For example, it may bebeneficial to simultaneously start investigationand remediation activities at a site. In theseinstances, two options for achieving sitecloseout (i.e., investigation and removal actionactivities) are combined into a single executablestage of site activities. Efforts to define projectexecution options should consider at least thesefollowing typical project execution options.

1.3.2.2 Expedited Removal.

or interim corrective measures, can be takenanytime during the CERCLA or RCRA process.

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A well designed removal action or interimremedial action can end up being the finalremedial action at a site if all legalrequirements are satisfied and the work isadequately protective.

Although ESC has several similarities tothe TPP process, the entire TPP processshould be used to develop a datacollection program that uses ESCapproaches where appropriate.

Removal activities include source reduction orremoval; access control (e.g., capping, fencing); Expedited site characterization (ESC) is anprovision for an alternative water supply; or execution option that also merits considerationeven temporary relocation of residents. during the TPP process. Use of an ESCRegulator participation in both considering and approach utilizes in-field decision making,planning removal actions, interim remedial dynamic work plans, and real-time dataactions, and interim corrective actions is critical acquisition and interpretation. ESC expects aduring TPP efforts. multi-disciplinary team to plan a data collection

1.3.2.3 Phasing (Series or Parallel).A common project execution option to be conditions are better understood during dataconsidered by the team is phasing site activities collection efforts. Dynamic work plans can onlyconcurrently or consecutively. Each stage of be successful if the entire team agrees with theproject execution, whether planned in series or plans and the plans include when and howparallel, corresponds to several specific project communications will occur between fieldobjectives selected for each executable stage. personnel and the customer, regulators, andMultiple phases can also be combined or stakeholders, as appropriate.conducted in parallel if the team believes that itcan satisfy the project objectives of multiple ESC approaches can be effectively used at bothproject phases during a single executable stage. small and large sites; involve any media ofParallel phasing of project activities involves interest at a site; and for all types ofplanning for concurrent activities at a site. For investigations, removal actions, and remedialexample, a team may consider a removal action actions that. For example, an ESC approachconcurrent with remedial investigation sampling. involving a site with potentially contaminated

1.3.2.4 Field Screening and FieldAnalytical Methods.Field screening and field analytical methods can focus on the chemical contaminant portion ofbe a useful tool to characterize site contaminants the conceptual site model.while reducing analytical costs. The team couldplan to conduct some field screening activitiesconcurrent with TPP efforts during Phases I, II,or III to refine their understanding of a site priorto design of a data collection program for thecurrent executable stage of site activities.

1.3.2.5 Expedited Site Characterization.

12

program and then the same key personnelimplement the program in the field.

Dynamic work plans used by the team in thefield offer some decision logic in advance offield activities, including sampling that is directlycontingent on the findings of earlier sampling.Dynamic work plans empower the team todecide on-site to modify field efforts as site

groundwater would first typically focus on thehydrogeologic portion of a site’s conceptual sitemodel. A second phase of ESC field work then

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The current executable stage of siteactivities may involve satisfying as manyas 15 project objectives. Futureexecutable stages will typically involvesatisfying optimum project objectives thatare more general than those documentedas basic project objectives for a site.

1.3.3 Document Current Executable Stage.Within the TPP process, the current project that stage of site activities may be iterative. As athe team focuses on consists of at least the first team works to sequence and group the projectexecutable stage of site activities and the objectives, it may need to further refine thecorresponding project objectives. In order to project objectives and possibly identifyselect project objectives for the current project, additional project-specific objectives to ensureeach project objective must first be correlated that all issues are addressed during the project.with an executable stage of planned siteactivities (see Project Objectives Worksheetprovided in Appendix F). Project objectivesshould be listed in chronological order and thengrouped in relation to desired executable stagesof site activities. The team should designateproject objectives for each executable stage bygrouping them so that they can be achievedwithin site constraints and dependencies. Bygrouping project objectives relative toexecutable stages of site activities, the team willunderstand the sequence and timing of projectobjectives to be satisfied through site closeout.

Once the team has selected project objectives A step in completing Phase I is finalizing thefor the first executable stage, they have acquisition strategy(ies) that will becompleted identification of the current project implemented to obtain the technical personneland can document the current executable stage needed to perform the balance of the TPPby listing the corresponding project objectives activities. Although the acquisition strategyas the “basic” project objectives. The team must be finalized to proceed with the TPPshould document the current executable stage process, the acquisition strategy should also beby renumbering all project objectives to reviewed, refined, and modified as appropriaterepresent the planned sequence as well as clearly during the life of the project.differentiate between those project objectivesassociated with current and future executable The PM should update the acquisition strategystages at the site. The project objectives identifying the most suitable contracting optionassociated with future executable stages are for performing the TPP activities based on theclassified as the “optimum” project objectives. scope; schedule; manpower constraints;Project objectives that do not lead to site availability and accessibility of in-house orcloseout are classified as “excessive,” unless contractor resources during subsequent projectclarified and then adequately related to either activities at a site; and other technicalthe current or future executable stages. considerations related to the site. At this step in

In all instances, obtaining the customer’s and confirm that the acquisition strategy(ies) isregulators’ concurrence on all project objectives appropriate or revise it as necessary.is critical before proceeding with TPP activities.

Efforts to document the current executable

1.4 COMPLETE PHASE I ACTIVITIES.

1.4.1 Finalize Acquisition Strategy.

the TPP process, the PM should be able to

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The PM should distribute a MFR to allteam members after completing Phase Iactivities. A well developed MFR can beused to document project planningobjectives and focus the team's effortsthroughout TPP Phases II, III, and IV. The Phase I MFR should be a stand-alonedocument attached to the site-relatedProject Management Plan. A completePhase I MFR can help to ensure thatinstitutional site knowledge is transferredto new people involved with a site.

Note that the PM should also refer to other In accordance with the applicable qualityguidance for specific information regarding the management plan, the PM should haveprocedures for developing, implementing, and independent technical or management personnelrevising the acquisition strategy(ies). review the Phase I MFR to ensure it is effective

1.4.2 Initiate Scope of Work Sections.The PM should rely on support from technicalpersonnel to initiate introductory-type scope ofwork (SOW) sections, or work plancomponents, as appropriate. In general, PMsshould consult applicable SOW guidance andrely on input from technical personnel. TypicalSOW sections to initiate during completion ofPhase I TPP activities include:C Site Background (e.g., site location and

history; previous studies and results;regulatory history and authorities);

C Project Planning Overview and Objectives(e.g., site approach, current projectdescription, project objectives for thecurrent executable stage); and

C Project Management (e.g., schedules,submittals).

1.4.3 Prepare Phase I Memorandum forRecord.At this step in the TPP process, a Phase Imemorandum for record (MFR) should beprepared to document the team's findings anddecisions during Phase I (see Appendix F for aPhase I MFR worksheet). The PM andtechnical personnel should reference portions ofthe previously prepared team informationpackage, preliminary conceptual site model, andlisted project objectives as components of theMFR. The MFR should clearly document thecurrent project and associated project objectiveswithin the context of the overall site approachfor the current executable stage of site activities.The MFR should clearly indicate the customer'sgoals (i.e., concept of site closeout, schedulerequirements, and site budget), as well as siteconstraints and dependencies.

and complete.

Phase I

Phase II

Phase III

Phase IV

IdentifyCurrent Project

DetermineData Needs

Develop DataCollection Options

Finalize DataCollection Program

· Determine Data Needs· Document Data Needs

Existing SiteInformation

Customer'sGoals

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Data needs determined should include:C Environmental data needed from a

site (obtained on-site or by laboratoryanalysis of a sample from the site);and

C Site information data needed aboutthe site (e.g., “as-built” drawings;weather information; water andelectrical supply sources; utilityconflicts; site access limitations).

Chapter 2Determine Data Needs (Phase II)

Phase II (see Figure 2-1) of the TechnicalProject Planning (TPP) process is designed toensure that all data needed to satisfy a site’sproject objectives are identified. This chapteroffers guidance to data users for the detailedlevel of planning required to determine anddocument data needed for the current project,and subsequent executable stages. Data userswill find guidance in this chapter to help themdocument their data quality requirements for theintended use(s) of each data need.

Data users must also continue to use their process. As presented in this manual, manyexperience, input from others, findings within technical personnel must collaborate to definelessons learned systems, and other technical what is required to satisfy the project objectives.resources to determine data needs for each site.

Figure 2-1 responsibilities and what is required to satisfyPhase II of Four-Phase TPP Process the site’s project objectives.

2.1 DETERMINE DATA NEEDS.Determining data needs is an iterative thought

2.1.1 Review Phase I Memorandum forRecord (MFR).The PM should distribute the Phase I MFR andany project objective worksheets to technicalpersonnel involved in Phase II. Data users’efforts to determine data needs should beginwith their review of the Phase I MFR. Reviewof Phase I information is particularly critical forthose personnel not involved in Phase I effortsand for the entire team when some time haspassed since Phase I efforts were completed.

2.1.2 Establish Data User’s Roles.Project objectives identified during Phase Ishould be reviewed to ensure technicalpersonnel understand each project objective.Technical personnel must also be aware of boththe “basic” project objectives associated withthe current project and those “optimum” projectobjectives associated with future executablestages. Efforts to establish data user’s roles willhelp focus all technical personnel on their

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Application of the data user perspectivesof risk, compliance, remedy, andresponsibility will ensure planning issufficiently detailed to identify the rangeof data typically required for satisfyingproject objectives and progressing to sitecloseout.

In most cases, the project manager (PM) shouldmeet with the data users to discuss the Risk data users evaluate human health andpreliminary conceptual site model and provide ecological risks at a site. Technical personnelleadership as they discuss what is required to who collaborate to determine risk-related datasatisfy each project objective. While convened, needs typically have the following roles at a site:the TPP team should confirm that they share a C Evaluate potential risk-based screeningcommon understanding of the preliminary levels to ensure appropriate quantitationconceptual site model and which data users have limits are established for environmentala role in determining the data needed to satisfy analyses;each project objective. C Perform preliminary determination of hazard

The PM should also reinforce the premise that further action is warranted;data users must work to identify “basic” data C Prepare a baseline risk assessment orneeds of the current project; “optimum” data quantitative evaluation of risk to support aneeds that are cost-effective and prudent to determination of the degree of risk andfulfill during the current project for a future whether remediation is required;executable phase; and any “excessive” data C Develop remedial action objectives andneeds specifically requested by someone besides cleanup levels, as well as detailed analysesthe data users, but not needed by the data users. of risk reduction provided by remedial

“Excessive” type data needs should not be C Evaluate suitability of site controls forcreated, but identified as a result of data users mitigating short-term risks associated withrealizing that some data needs, imposed or remediation;mandated by others, are not required to satisfy C Verify safety of working conditions forthe basic and optimum project objectives. In personnel during treatment systemsome cases, data users will learn that the construction and operation and maintenanceintended use of the mandated data is actually efforts; andappropriate, but simply lacked a sufficiently C Evaluate monitoring data to determine thedocumented project objective. In other cases, site no longer poses risk and long-term sitedata users may realize that the “excessive” data monitoring can be discontinued.needs imposed by others represent differences inprofessional opinion or technical judgment as towhat data is needed to satisfy a projectobjective. Compliance data users evaluate and monitor

2.1.2.1 Risk Data User Perspective.

or risk to support the decision as to whether

alternatives;

2.1.2.2 Compliance Data UserPerspective.

satisfaction of legal and regulatory requirementsat a site. Personnel who collaborate todetermine legal or regulatory-related data needstypically have the following roles at a site:C Determine a site’s regulatory compliance

with each applicable or relevant andappropriate requirement (ARAR) and latercompliance with ARARs;

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Contaminant fate and transport dataneeds vary by data user perspective. Therefore, the TPP process encourageseach data user perspective to determinetheir specific fate and transport dataneeds.

C Properly manage remediation and implement a remedial technology at a site.investigation derived wastes; Technical personnel who collaborate to

C Contribute to development of remedial determine remedy-related data needs typicallyaction objectives, as well as evaluate have the following roles at a site:remedial alternatives for compliance with C Perform preliminary determination ofeach ARAR; chemical and physical characteristics of the

C Verify that implementation of remedial wastes to begin to determine potential siteaction systems will be compliant with each remedies;ARAR; C Identify and screen technologies potentially

C Complete procedural requirements under the suitable for mitigating site risks tolaw governing the response actions (usually acceptable levels, as well as perform theCERCLA or RCRA); detailed analysis necessary to support

C Adhere to the obligations of any remedy selection;agreements, permits, or orders controlling C Prepare engineering design and constructionthe response actions; plans for response actions, including

C Determine whether certain comments, alternative analysis;requests, or demands from non-federal C Optimize operation and maintenanceentities (including regulators), require activities and long-term monitoring; andadherence; C Gather cost and performance data needed

C Predict legal or regulatory issues that will for life-cycle assessments, evaluation of thedrive response and other regulatory actions; technology on similar sites, andand incorporation of lessons learned and

C Comply with specific sampling requirements improvements on future designs.of federal and state programs.

2.1.2.3 Remedy Data User Perspective.Remedy data users identify possible alternatives presenting or defending in legal proceedingsfor response actions and design all response related to responsibility. Some responsibilityaction components. The role of the remedy data perspective data needs have elements inusers involves evaluating the feasibility, common with other data user perspectives (e.g.,implementability, or effectiveness of remedies at site history and characterization), and manya site. Remedy data users must also consider responsibility perspective determinations arepotential process interferences and the dependent on conclusions of the investigationsecondary technologies required to successfully and design process at a site (e.g., baseline risk

2.1.2.4 Responsibility Data UserPerspective.Responsibility data users attempt to define whatfederal or non-federal entity has responsibilityfor the site’s conditions in the event that anyresponse actions are required. Responsibility-related data needs are typically related todetermining federal liability at a site, developinga legally defensible position, creating a costallocation strategy, defining settlement termswith other potentially responsible parties, or

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Review of existing data is a fundamentaland critical TPP activity that must occurprior to determining the additional dataneeded at a site. However, prior toeliminating any data needs from furtherconsideration, the team should be surethat the data user(s) concur that existingdata is usable for the intended use(s).

Efforts to define data needs must focuson establishing data need requirementsfor each media type, including samplingareas and depths; chemical concentrationsof interest; and the number of samplesnecessary to satisfy the project objectives.

assessment will establish need for response andaffect the need for a responsibility During this TPP activity, technical personneldetermination). Several elements of a representing each data user perspective defineresponsibility evaluation (e.g., liability the data needed to satisfy the project objectives.determinations, cost allocations) are unique tothe responsibility perspective.

2.1.3 Evaluate Use of Existing Data.Before defining new data needs for a project,data users and data implementors shouldevaluate the usability of existing data todetermine whether additional data are required.Experience has shown that some, if not most,existing data may be suitable for qualitative and To identify and organize the data needed,for quantitative uses. Detailed usability reviews technical personnel should take every advantagecan determine existing data quality and potential of tools such as the preliminary conceptual siteneed(s) for additional data to satisfy the project model; decision trees or flowcharts; and processobjectives. diagrams. These tools can provide a logical

The question of whether and how existing data prompt for reviewing available site informationcan be used (e.g., in a risk assessment and defining additional data needs. Othercalculation or to support a clean closure) will potential tools include data need checklistsrequire specific evaluations of their usability for provided in other technical references.each intended use. Technical personnel must However, data need checklists should not beremember that some existing data may be of an used as standard lists of data to collect, but asunacceptable quality for one use, but yet of an checklists to prompt data users to identify theacceptable quality for another unrelated use at site-specific data needed to satisfy projectthe site. objectives at a site. While defining data needs,

2.1.4 Define Data Needs.

basis and offer technical personnel a visual

data users should:C Consider the consequences of unacceptable

decisions or decision errors throughoutcompletion of the work at the site;

C Consider how much data is required;C Consider data collection approaches,

including expedited site characterization andfield screening approaches;

C Consider the cost of additional datacollection in dollars and time; and then

C Decide how data needs can be balancedwithin project cost and schedule constraints.

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Although powerful, obtainingconcurrence among decision makersregarding probabilistic decisions can bedifficult. Application of probabilisticmethods can only be accomplished whenthese three conditions exist:(1) A precise study question is defined;(2) The customer and lead regulator are

willing to and successful inestablishing tolerable limits ondecision errors; and

(3) The support of a qualifiedenvironmental statistician is availableto work on the project.

2.1.4.1 Probabilistic/Non-Probabilistic 2.1.4.2 Number of Samples.Decisions.As data users define data needs and the number number of samples, or decision logic, requiredof samples required, they must recognize that for each data need based on the intended databoth probabilistic and non-probabilistic data use(s) and the project objectives.needs should be identified, as appropriate basedon intended data uses and the project objectives. When non-probabilistic or judgmental sampling

When a data user defines a probabilistic-type designated by guidance or technical literaturedata need during this TPP activity, the data user specific to the data user perspective. In someshould use Steps 5 and 6 of the U.S. cases, the number of samples needed to satisfyEnvironmental Protection Agency’s (EPA’s) 7- an objective (e.g., determining if a contaminantStep Data Quality Objective (DQO) Process to is present) may be based on experienceddetermine the number of samples required for judgment of the technical personnel representingthe intended data use. (Appendix E presents a the data user perspectives for each specific site.1

detailed “crosswalk” to EPA’s 7-Step DQOProcess from the TPP process.) In some instances, data needs should be fulfilled

When probabilistic methods are either probabilistic data needs can also result in eitherinappropriate or cannot be employed for a data the collection of too many or too few samples.need because the three conditions do not exist,data collection planning can be judgmentally When necessary, in accordance withbased on the expertise of the technical personnel recommendations within EPA's Guidance forrepresenting the applicable data user Data Usability for Risk Assessment, riskperspective. assessment personnel should indicate the

Each data user is responsible for identifying the

is appropriate, the number of samples may be

using probabilistic or random sampling wherethe number of samples required to make therelated site decision should be calculated. Forexample, project objectives that have specificdata needs (e.g., determining if the contaminantlevels detected are sufficiently different from thebackground levels of the constituent at the site)may provide a suitable opportunity to use astatistical basis to establish the number ofsamples to be collected. In any case, it isimportant that data users recognize that use ofstatistical techniques as the basis for designingenvironmental sampling plans can reduce thenumber of unnecessary samples taken in thefield, and improve the samplingrepresentativeness by quantifying the statisticaluncertainty of the sampling design.Inappropriate application of statistics for

number of samples in terms of classical

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statistics. The remedy perspective, on the techniques are appropriate for environmental13

other hand, typically uses engineering judgment sampling programs intended to define oror other performance criteria as a means to evaluate the distribution of contamination at adesignate the number of samples required to site or within an area of interest. Geostatisticssupport a remedy-related data need. are particularly useful for identifying “hot spots”

Decisions to use classical statistics methods or exposure for risk assessments. It can also begeostatistical methods must also be based on the used to produce probability estimates of aintended data use(s) and known or anticipated variable of interest based on recognizedvariability of the data in the environment. This geostatistics methods (e.g., semivariogramis the case because randomly distributed analysis, cross-validation, and data kriging).variables or data are suited for classical statistics Data users and data implementors shouldapplications and spatially related or regionalized seriously consider the use of geostatisticalvariables that have continuity from point to methods since they can provide considerablepoint present opportunities to use geostatistics. support to the development of data collection

2.1.4.2.1 Applications of Classical Statistics. Potential applications of geostatistics include:Classical statistics tools (e.g., random, stratified C Contour mapping and interpolation;random, or systematic random sampling C Identification of sample locations;designs) can be used to determine the number of C Optimization of sampling existingsamples required to support various probabilistic monitoring devices;decisions. Classical statistics can be used to C Risk assessment/probability estimation; anddetermine the number of samples required to C Remedial design.define representative concentration values (e.g.,background soil concentrations) or evaluatetrends (e.g., waste pile sampling, chemical While defining data needs, each data user shouldconcentrations in soils) over an area of interest. re-evaluate earlier considerations of using eitherClassical statistics are most appropriate for field screening or expedited site characterizationmean concentrations; however, other methods (ESC) approaches for collecting site data. Asmay be more appropriate or suitable for discussed in Paragraph 1.3.2.4, the team maycomparing populations or identifying “hot chose to conduct some field screening activitiesspots.” Classical statistics methods can be used concurrent with Phase I, II, or III TPP activitiesto determine the number of samples needed to refine their understanding of a site. Use of anfrom each medium (or each stratum within a ESC approach typically expects data users tomedium) to provide sufficient data to support first establish a site’s physical setting beforeproject objectives. contaminant investigations are conducted as

2.1.4.2.2 Applications of Geostatistics.Geostatistics are a specific branch of statistics When data users have identified appropriateused to optimize the co-variance of a variable of opportunities to use field screening or ESCinterest and can involve classical (or simple) approaches, they should advise the PM and datarandom, stratified random, or systematic implementors which data needs are candidatesrandom sampling designs. Geostatistical for using either approach. In those instances

and calculating the reasonable maximum

programs and result in significant cost savings.

2.1.4.3 Data Collection Considerations.

discussed in Paragraph 1.3.2.5.

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where field screening or ESC approaches will be evaluation and chemical of potential concernused, it will even be more critical for the data identification; exposure assessment; toxicityusers to provide the decision logic information assessment; and risk characterization).that can be incorporated into the correspondingdynamic work plan for the site. Data users will Future land use pathways (if different fromalso need to provide a description or decision current pathways) will require data to supportflowchart of the rationale that should be used transport models suited for evaluating spatialfor making field decisions contingent on the and temporal behavior of the chemical(s) at theresults of previous samples. site over time. Therefore, the risk perspective

Data users must also recognize that data needs satisfy the project objectives since dataidentified during this TPP activity should include requirements vary by model.both site information and environmental data.Appendix F provides a site informationworksheet and several data need worksheets Compliance data users should compare sitethat are recommended for documenting the data conditions or activities with legal and regulatoryneeds of the data users. requirements and standards to establish the

When defining each data need, data users are what is required for site compliance. They mustresponsible for communicating whether a data also compare possible site conditions orneed is a “basic” data need that contributes to activities that are regulated (e.g., treatment,satisfying a current project objective, an storage, and disposal) with applicable regulatory“optimum” data need that would be cost- standards. Potentially applicable regulatoryeffective and prudent to fulfill during the current standards are defined by the primary regulatoryproject, or an “excessive” data need specifically program and may specify chemical analysisrequested by someone other than the data users, requirements and point(s) of complianceand not needed by the data users. (Paragraph (location and type of samples) used to assess3.2 further describes the data collection options compliance. Compliance data user efforts toof “basic,” “optimum,” and “excessive”.) define compliance data needs should involve:

2.1.4.4 Risk Data Needs.Using the preliminary conceptual site model CERCLA Sections 104, 120, 121; RCRAdeveloped during Phase I, the risk data users Sections 3004u and 3008h) and theshould conceptualize and identify the data applicable regulations;needed to address each of the pathways that will C Identification of activities or conditions thatbe part of the risk assessment for the site. In give rise to certain standards, requirements,assessing risks to human and environmental or criteria that must be satisfied (e.g.,receptors, one must be able to show a treatment, storage, and disposal; drinkingrelationship between potentially exposed water contamination; surface waterpopulations (for both current and future site discharge);use) and the chemicals detected onsite. This C Consideration of potentially affected mediarelationship is evident in the elements of a risk (i.e., air, surface water, sediment, soil,assessment (e.g., conceptual site models; data groundwater);

must determine the most appropriate models to

2.1.4.5 Compliance Data Needs.

governing laws and regulations and to determine

C Review of the project objectives identifiedfrom the primary governing statutes (e.g.,

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Remedy design-type personnel shouldcontribute to TPP efforts beginning withthe earliest stages of site assessment andinvestigation. Remedy construction-typepersonnel should begin to contribute toTPP efforts when site remedy selectionand design activities begin.

C Identification of chemical-, action-, and previously identified for a site. The remedy datalocation-specific ARARs; needs for technology screening are typically

C Identification of point(s) of compliance environmental type data needs (e.g., soil(e.g., drinking water aquifer, effluent moisture content, pneumatic permeability, anddischarge, stack emissions); cation exchange capacity). Based on

C Compilation of documents, reports, data, technology screening results, only a fewcorrespondence, etc., that demonstrate alternatives for remedy selection and design aresatisfaction of procedural requirements further considered. While constructing,arising from laws, regulations, agreements, operating, maintaining, and monitoring apermits, or orders; and remedy, ongoing efforts will be expended by the

C Identification of community relations and remedy data users to obtain cost andpublic involvement activities for outreach to performance information for optimizing theinterested stakeholders. treatment system and for similar systems in the

Compliance data needs will be both qualitative later evaluations will be more complex andand subjective (point of compliance), as well as require both site information and environmentalquantitative (environmental data needs). data (e.g., treatability studies, soil compaction,

2.1.4.6 Remedy Data Needs.Remedy data users define data needed toidentify, screen, and analyze possible responseaction alternatives at a site. The efforts todefine remedy data needs will depend on thephase of a site’s progress to site closeout.Remedy data needs become more complex asthe alternative evaluation process proceeds fromtechnology identification to remedy selectionand design, and finally operation andmaintenance of treatment systems.

During the early stages of a site’s progress to responsible for defining responsibility data needssite closeout, technical personnel should begin will not only be concerned with determining theto consider possible general technologies that legal basis for a response action, but also withmay be applicable to the site (e.g., containment; defining responsibility at a site. Responsibilityexcavation and disposal; in-situ treatment). Site data users must rely on legal counsel to identifyinformation type data needs are typically the phase of execution and specific position andsufficient to support these evaluations (e.g., negotiation strategies that will affect thecontaminant characteristics, physical identification of responsibility data needs.characteristics of the site, and physical featuresof the site). The next level of evaluation For example, one emphasis would be to obtainincludes identification of common technologies data for determining a site’s eligibility under the(e.g., soil washing, incineration, capping) that Formerly Used Defense Site program andrelate to the general technology type(s) identifying the potential for another potentially

future. The remedy data needs to support these

and available water sources).14

2.1.4.7 Responsibility Data Needs.The technical and legal counsel personnel

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Site information worksheets and dataneed worksheets are comprehensive listsof the data needs at a site. Informationpresented on the worksheets identifyadditional data needed by each data userperspective to satisfy the projectobjectives.

responsible party (PRP). In this case, site information worksheet and a series of data10

responsibility data would need to be collected need worksheets for documenting data needs oftoward the goal of settling with the other PRP. the risk, compliance, remedy, and responsibilityIn another instance, responsibility data needs data user perspectives. Use of standardizedwould involve collecting past disposal records data need worksheets will allow quick and easyfor position development purposes that quality assurance/quality control review of theultimately contribute to developing a cost data need planning.allocation formula during negotiations withother PRPs. The critical aspects of documenting data needs

Background and historical site information will C What data is needed (e.g., contaminant ormake up much of the responsibility data needed characteristic of interest, and media)?to develop a negotiation position. This includes C Who needs the data (i.e., risk, compliance,articles of incorporation; facility ownership remedy, or responsibility data userrecords; contract documents; lease agreements; perspective)?historic process and operations information; C What is the intended data use(s) (e.g.,federal and industry information on standard contaminant fate and transport; baseline riskpractices related to the chemicals of concern; assessment; remedial design; operation andmanifests; disposal logs; and aerial photos. The maintenance plan) to satisfy projectsite characterization data can focus the historical objectives?research toward the use and disposal of specific C What number of samples are required tochemicals at specific locations based on satisfy the intended use(s), includingobserved contamination. Historical information whether the number of samples is fixed,should guide site characterization work by somehow contingent upon field screeningnarrowing the list of analyses and general results, or is the minimum anticipated by thesampling locations. These two investigations dynamic decision logic approach defined byshould be done in parallel to be successful. the data user?

2.2 DOCUMENT DATA NEEDS.Personnel representing data user perspectives level, compliance standard, decision level,are responsible for communicating their data design tolerance)?needs so the needs can be incorporated within C Where is area of interest or desired samplingdata collection options developed during Phase location(s) and depth(s)?III activities. Communicating or documentingdata needs are critical TPP activities that lead tosuccessful project execution. Documenting dataneeds, as discussed here, is the recommendedmeans for technical personnel to communicatetheir data needs.

This manual offers several options fordocumenting data needs given the wide range ofdata needs and data uses. Appendix F offers a

can be reduced to the following.

C What is reference concentration of interestor other performance criteria (e.g., action

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2.3 COMPLETE PHASE IIACTIVITIES.The technical personnel should review the dataneed worksheets to ensure that each projectobjective has been considered and related dataneed considerations have been made by eachapplicable data user perspective. In accordancewith the applicable quality management plan, thePM should also have independent technicalresources review the data need worksheets.(The data need worksheet examples provided inAppendix F may be useful during independentreview efforts.) In any case, all projects will beperiodically evaluated by the project team toensure baseline requirements of scope, schedule,and cost are being met.2

If it appears that some project objectives haveno associated data needs, the PM should meetwith the technical personnel and confirm that noadditional data is needed to support theparticular project objectives. The PM ortechnical personnel should document in theproject file why specific project objectivesrequire no additional data. The PM should alsomeet with the technical personnel to understandany instances when no “optimum” data needshave been identified during Phase II activities.

The PM should review any site informationworksheets or lists of site information dataneeds that have been identified by the datausers. It is the PM’s responsibility, workingwith the technical personnel, to decide how andwhen site information needs will be fulfilled(e.g., discussions with the customer, site visits,incorporated within appropriate scope of workor work plan sections).

The PM should then distribute copies of all dataneed worksheets and any attached illustrationsto all appropriate TPP team members.

Phase I

Phase II

Phase III

Phase IV

IdentifyCurrent Project

DetermineData Needs

Develop DataCollection Options

Finalize DataCollection Program

· Plan Sampling & Analysis Approach· Develop Data Collection Options· Document Data Collection Options

Existing SiteInformation

Customer'sGoals

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The PM and technical personnel will findthat Phase III activities are iterative withPhase II activities as data needs tend tobe clarified and refined. Therefore, dataimplementors will find communicationwith the data users to be invaluableduring this phase of TPP activities.

Chapter 3Develop Data Collection Options (Phase III)

This chapter offers guidance to sampling andanalysis data implementors for their detailedplanning efforts. Phase III (see Figure 3-1) ofthe Technical Project Planning (TPP) process isdesigned for planning sampling and analysisapproaches that will satisfy the data needsidentified during Phase II. Data collectionoptions are also developed during Phase III to Data implementors will find guidance in thisensure the customer has adequate information chapter to help them document both theduring Phase IV for business decisions related to appropriate sampling and analysis methods anda project’s data collection program. the data collection options. Although this

Figure 3-1Phase III of Four-Phase TPP Process

chapter supports efforts to plan sampling andanalysis approaches, it is not an exhaustivereference or resource.

3.1 PLAN SAMPLING AND ANALYSISAPPROACH.Planning the most appropriate sampling andanalysis approaches for a site is an iterativethought process. As presented in this manual,many technical personnel must collaborate todetermine suitable sampling and analysismethods and develop data collection options fora site.

3.1.1 Review Phase I and Phase IIInformation.The project manager (PM) should distributecopies of the Phase I memorandum for record(MFR) and any corresponding project objectiveworksheets, and Phase II data need worksheetsto all personnel involved in Phase III. Efforts toplan sampling and analysis approaches shouldbegin with review of the earlier TPPinformation. Review of Phase I and Phase IIinformation is particularly critical for thosepersonnel not involved in those efforts, and forthe entire team when some time has passed sincePhase I and Phase II efforts were completed.

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3.1.1.1 Review Phase I MFR.Review of the Phase I MFR and any project needs, they should begin to recognize bothobjective worksheets will refresh technical similar and unique data needs to ensure that allpersonnel of the site approach, project of the data needs are understood. Althoughobjectives, current project focus, and any site data implementors may have been consultedconstraints and dependencies. during Phase II by data users, data need

Although the data implementors may have been may introduce new or refined data needsinvolved in Phase I activities, the Phase I MFR developed by each data user perspective. Datamay contain revised constraint information implementors will probably find it necessary toincluding the finalized acquisition strategy, a contact data users when trying to interpret datamodified budget, and updated schedule needs or to obtain additional informationinformation. For example, schedule and site regarding data quality requirements.physical constraints may now preclude use of aproposed sampling method, while new budgetand regulatory constraints may dictate theselection of analytical options. The MFR may The sampling data implementor should generallyalso contain or reference useful site background lead efforts to first sort and then combine theinformation including analytical data from data needs prior to developing and documentingprevious studies, site physical characteristics, sampling strategies. The analysis dataaerial photographs, topographic maps, site implementor should then proceed to developcross-sections, site boring logs, etc. The and document field and laboratory analysispreliminary conceptual site model prepared strategies. And finally, technical personnelduring Phase I can also acquaint data representing both the sampling and analysis dataimplementors with the physical and chemical implementor perspectives should refine theirfeatures of a site in relation to possible sampling plans within cost and schedule constraints of thestrategies. project. Data implementors will find Step 7 of

3.1.1.2 Review Phase II Data Needs.Data implementors should review the range of during these TPP efforts.data needs identified during Phase II by the datausers. Documentation prepared at the end of While planning sampling and analysisPhase II should communicate the intended data approaches, data implementors are expected touses, the required number of samples, the consider both analytical and field sources ofcontaminant concentrations of interest, and the error to ensure the data will be useable for thenecessary sampling areas or locations and intended data use(s). Detailed planning by datadepths. The Phase II documentation should also implementors can further minimize analyticaldesignate each of the data needs as “basic,” error and significantly reduce potential sources“optimum,” or “excessive,” as well as any of field error. Proper management of analyticalopportunities for use of field screening or field and field sources of error requires that both theanalytical methods and expedited site sampling and analysis data implementors employcharacterization approaches. the most current accepted methods for sampling

As data implementors review the Phase II data

worksheets or other Phase II documentation

3.1.2 Plan Sampling and AnalysisApproaches.

the U.S. Environmental Protection Agency’s 7-Step Data Quality Objective Process useful

1

and analyzing all types of media.15, 16

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Data implementors must address site-specific sampling and analysisrequirements rather than merely planningto implement sampling or analysisactivities that were developed for aprevious project or similar site.

3.1.2.1 Sort and Combine Data Needs.Data implementors should first sort and then perspective, the more stringent riskcombine data needs by media and location. It is sensitivity requirements should not beimportant to identify overlapping data needs at applied. When balancing sensitivitya particular location and unique data needs from requirements, data implementors must becommon locations at a site. Similar data needs sure to effectively communicate and involveshould be combined to the extent possible to the appropriate laboratory personnel toensure sampling and analysis efforts are prevent misunderstandings during sampleminimized. The efforts of data implementors to analysis.carefully sort and combine data needs can makea project very successful and efficient. Whensorting and combining data needs, it is intendedthat some of the efforts include the following.

C Balancing Sensitivity Requirements site location. In those instances where someWhen combining similar data needs, data data needs directly overlap each other inimplementors are cautioned to only apply location and depths, data implementorsthe most stringent or lowest concentrations should be sure to meet the discrete samplingof interest requirements to those locations depth requirements of any data users withdesignated by the data users based on the unique sampling depth needs.intended data use. Typically, data used tocharacterize risk must meet more stringentsensitivity requirements than data used toevaluate, design, implement, and operateremedial technologies. The data required toidentify potentially responsible parties mayalso require a greater degree of confidence,or number of samples, than other dataneeds. An example of overlapping dataneeds is a risk perspective data need forgroundwater contaminant concentrationsfrom an existing drinking water well and aremedy perspective data need forgroundwater contaminant concentrations

from the same vicinity. Both data needscould be satisfied simultaneously as long asthe analytical sensitivity meets the morestringent of the two requirements. In thiscase, the risk data need requirements forlower analytical quantitation limits is likelythe most stringent requirement. However,if additional groundwater contaminantconcentration information was requiredfrom adjacent wells for only the remedy

C Meeting Sampling Depth RequirementsData implementors may recognize similardata needs in a particular area of a site oreven overlapping data needs at a common

C Evaluating Data Need Trade-OffsData need trade-off situations may bediscovered where an alternate adjacentsampling location may be acceptable andrepresentative for several data userperspectives instead of merely collectingdata from several individual but adjacentsampling locations. After consultation withdata users, they may agree to reduce thenumber of samples or increase theirconcentrations of interest on some dataneeds to help meet project cost or scheduleconstraints. Such trade-offs may enable the

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Although the greatest cost savings can beachieved when the data needs of severaldata user perspectives overlap (e.g.,contaminants of concern, soil chemical orphysical characteristics), overlooking aunique data need from a common sitelocation could result in costlyremobilization to the site to re-sample thelocation. Another common opportunityfor cost savings is ensuring thatmanagement decisions regardinginvestigation and remediation derivedwastes can be made using the analyticalresults from corresponding matrixsampling locations.

data implementors to decrease the overall implementor may consider involving some of theuncertainty of site decisions by using the other technical personnel to determine the bestavailable funds for conducting other sampling strategy to meet the data needs,required field screening or field analytical develop the data collection options, and applywork at a site. Still another data need trade- field screening or field analytical and expeditedoff may involve the use of composite site characterization approaches wheneversampling where it can be appropriate for the appropriate.intended data use(s). This trade-off mayhelp to meet project constraints while 3.1.2.2.1 Sampling Strategy Constraints.decreasing the uncertainty of some site The total sampling time and costs should bedecisions. estimated based on site access considerations,

3.1.2.2 Develop and DocumentSampling Strategies.Developing the sampling strategy requires a only a one-time offsite sampling effort, ratherthorough understanding of a site, and all the than multiple or periodic sampling events thatinformation generated during TPP Phases I and may require a costly real estate acquisition.II. In particular, the sampling data implementorshould understand the team’s preliminary For each sample collection design alternative,conceptual site model and consider its use while the sampling data implementor should select thedeveloping sampling strategies for a site. Data optimal number of samples and the mostimplementors should also be sure to follow any resource-effective data collection design thatstate-specific guidance on sampling design that satisfies all of corresponding data needs.is applicable to a site. Based on initial efforts to Sampling design approaches for designatingwork with this information, the sampling data sampling locations include both probabilistic and

proximity of multiple sampling locations,seasonal weather conditions, mobilization/demobilization efforts, equipmentdecontamination measures, sample managementactivities, concurrent site operations, and thetotal number of samples associated with eachdata collection event. The sampling dataimplementor should work to ensure that theentire field sampling activity can be conductedwithin the time allotted on the project scheduleand within the project’s budget constraints.

Because it is often necessary to sample propertyadjacent to a customer's property, the teamshould be proactive to obtain an accessagreement and sensitive to minimizingdisruption to the properties of adjacent owners.It can also be very time consuming to getappropriate site access agreements in place.Therefore, a common sampling strategy is todevelop a sample collection design that involves

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When evaluating sample collectiondesigns, the sampling data implementormust remember to include appropriatequality assurance/quality controlmeasures.

non-probabilistic methods and must correspond 3.1.2.2.4 Field Screening and Analysis.to the type of decision to be made as discussed Field screening and field analytical methods canin Paragraph 2.1.4.1. be useful tools for satisfying some data need

3.1.2.2.2 Probabilistic Sampling. screening methods is provided in ParagraphIf decision error quantification is required, 3.1.2.3.1.probabilistic sampling must be performed. Forthose investigations when litigation with another 3.1.2.2.5 Expedited Site Characterizationpotentially responsible party is anticipated, a (ESC) Techniques.probabilistic or random sampling approach may Another sampling and analysis execution optionbe desired for extrapolating results from a set of that should be considered and re-visited at thissamples to larger portions of a site. By step in the TPP process is the use of ESCcombining an efficient probabilistic sampling techniques. ESC is a methodology that utilizesdesign with a statistical hypothesis test, data in-field decision making, dynamic work plans,implementors can optimize resources (e.g., and real-time data acquisition andpersonnel, equipment, funding, site access, interpretation.temporal constraints) and provide data of anacceptable quality for the intended data use(s). In the case of the TPP process, ESC encouragesPlanning for statistical analysis before sample the data users and data implementors to plan acollection is crucial so data support the intended data collection program in the office and thendata use(s). Other guidance should be used for those same key personnel implement the dataestablishing tolerable limits on decision errors collection program in the field. In instancesand statistically determining the number of where the data users and data implementorssamples to be collected based on the hypothesis believe ESC techniques are appropriate,test and random data collection design. dynamic work plans should be used by the team1

3.1.2.2.3 Non-Probabilistic Sampling. field activities. It will also provide sufficientNon-probabilistic or judgmental sampling flexibility for field modifications based on on-locations are selected by the data user based on site decision making. By having establishedsite knowledge of contaminant distribution and decision logic and providing on-site decisionthe intended data use. With judgmental making authority, field work can be suspendedsampling, it is not possible to quantify decision whenever conditions deviate from what waserrors related to the number of samples, and the planned or anticipated.sample is only as good as the conceptual modelused to define the target population.

requirements while reducing costs. Dataimplementors could also plan to conduct somefield screening or field analytical activitiesduring these Phase III TPP efforts to refine theteam’s understanding of the site prior todesigning a data collection program for thecurrent executable stage of site activities.Further discussion about the use of field

12

to provide some decision logic in advance of

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The sampling data implementor shouldnot hesitate to obtain clarifications fromthe data users to ensure the samplingmethods will meet Phase II data needs.

If at this step in the TPP process the team requirements must be considered. In all cases,believes some ESC techniques should be applied the costs and turnaround times should beat a site, the team should review Phase I TPP compared to the project’s analytical budget andactivities to ensure ESC is appropriate within schedule, and the analytical strategies adjustedthe site approach and the current project. As to fit within the project constraints.the team proceeds with integrating ESCtechniques, the technical personnel should also The generation of screening data versusreview Phase II TPP activities to identify and definitive data should always be considered.redefine the data needs that could be adequately Whenever appropriate or potentially viable,fulfilled using ESC techniques. performance based measurement systems should

3.1.2.3 Develop and Document AnalysisStrategies.The analysis data implementor should evaluate sampling and analysis approaches or to providethe testing requirements, media to be sampled, additional site characterization data to dataand chemical and physical characteristics of the users. Various types of field screening analysescontaminants to select the analytical strategy. should be considered to gather preliminaryBy involving the appropriate laboratory information, reduce errors associated withpersonnel during these efforts, the analysis data spatial heterogeneity, or to prepare preliminaryimplementor will be more successful in maps as guides for further sampling. Fieldidentifying and communicating project specific screening analyses can be conducted toanalytical requirements. determine worker protection levels; extent of

The analysis data implementor must incorporate underground contamination; and the potentiala comprehensive and multifaceted approach to applicability of presumptive remedies orquality assurance/quality control in order to innovative technologies. For many sites, fieldachieve and document that data quality screening analyses can also provide useful datarequirements have been attained for the intended for a risk assessment because they can be useddata usage. They should also refer to Engineer quantitatively if confirmed with definitive data.16

Manual 200-1-6 concerning compliance In general, field screening data intended formonitoring activities that may be applied to quantitative use should be confirmed with atensure adequate chemical data quality least 10 percent replicate samples analyzedmanagement is achieved on a project. using definitive methods.

The anticipated analytical costs and turnaround Effective planning for the use of fieldtime associated with each analytical method and measurement technologies involvesthe related quality assurance/quality control consideration of at least the following factors:

also be evaluated. By being less prescriptiveabout the laboratory analysis to be performed,performance based measurement systems can betailored for application at a site and can enableoptimization of cost and schedule expenditures.

3.1.2.3.1 Screening Data.Field screening activities can be used during theTPP process (e.g., during a site visit) to refine

contamination or hot spots; presence of

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Data users must be consulted for theirconcurrence regarding the use of fieldscreening methods to meet their intendeddata uses. Collaboration between theanalysis and sampling data implementorsis crucial when the team plans to use fieldscreening and field analytical methods. The team also needs to establish howfield decisions will be made andcommunicated across the team.

The analysis data implementor should nothesitate to obtain clarifications from thedata users to ensure the analyticalmethods will meet Phase II data needs.

C Knowledge of site contaminants and what contaminants and the media type andmay be encountered that could affect complexity. Other critical, site-specificperformance of the field measurement considerations include regulatory agencytechnology; method preferences and quantitation limit

C Determining whether the measurement requirements; chemical quantitation andsensitivity is sufficient for the contaminant identification requirements; cleanup capabilities;concentration(s) of interest; quality assurance/quality control requirements;

C Understanding exactly what the field and turnaround time needed. There may also beanalysis technology measures; a need for future proof of data results for

C Understanding the factors controlling the compliance, responsibility, or cost allocationperformance of the field analysis technology; disputes.and

C Establishing a site-specific correlationbetween the screening and definitivemeasurement techniques.

3.1.2.3.2 Definitive Data. analysis may also contribute to balancing theDefinitive data are generated using rigorous, sampling design within project constraints.analyte-specific methods where analyteidentifications and quantitations are confirmed, Data implementors should also evaluate effectsand quality assurance/quality control of schedule and any temporal constraints thatrequirements are satisfied. Definitive data can apply to site activities. An extremely shortbe generated from standardized analytical schedule may require some sampling events tomethods (e.g., EPA reference methods) or non- be concurrent rather than phased activities. Thestandardized methods in which the analytical or level of effort associated with the entire datatotal measurement error has been determined. collection plan could exceed the scheduledThe potential analytical methods should be duration of field activities. Temporal conditionsselected based upon the intended data use(s). may be such that some data needs could only beAnalytical method selection should be based on fulfilled during a seasonally dry or warm periodthe chemicals of concern, the anticipated range of time.of concentrations for the individual chemical

3.1.2.4 Refine Plans Within ProjectConstraints.Data implementors should generate order-of-magnitude cost estimates to determine if theproposed sampling and analysis scheme can beexecuted within the budget constraints. Dataimplementors may find that the number ofsamples, sampling methods, or analysis methodsneed to be changed to remain within budgetconstraints. Archiving samples for subsequent

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In all instances, data implementors shouldbe careful to recognize and develop datacollection strategies for obtaining “basic,”“optimum,” and “excessive” data needs.

3.2 DEVELOP DATA COLLECTIONOPTIONS.After planning sampling and analysis activities, those future data needs that technical personneldata implementors should work with data users believe are good current investments towardto group the data needs into data collection future executable stages at a site.options for consideration during Phase IVactivities. Data collection options provide a A typical optimum data collection option wouldsimple mechanism to document the “basic” data be to include the feasibility study and remedialneeded for the current project; “optimum” data design data that can be cost-effectively obtainedthat is cost-effective and prudent to collect for during the remedial investigation at a site. Evenfuture executable stages; and any “excessive” if the current project budget cannot afforddata that is imposed or mandated by others in optimal data collection, data implementorsexcess of the data needed by data users. should still develop an optimum data collection

3.2.1 Basic Data Collection Option.The “basic” data collection option is the data setneeded to satisfy the current project objectives(e.g., remedial investigation data). The data This unique group of data needs are those datacollection efforts would produce data that needs that data users believe are excessive forgenerally meets all the data quality requirements the purposes of satisfying both current andof the data users for only the current project. future project objectives. The data needs

If data quality requirements cannot be met for specifically requested, imposed, or mandated bythe data users, the technical personnel need to others and not needed by the data users.clearly communicate this information to the PM.For example, the PM should be advised if Examples of excessive data collection optionsplanning compromises have been incorporated would include planning to have full suiteby the technical personnel when existing laboratory analysis of all samples when full suitesampling or analysis methods cannot achieve analysis of select samples would meet theaction levels or concentrations of interest project objectives; or planning to installrequired by the data users. If all the basic data additional groundwater monitoring wells whenneeds for the current project cannot be obtained the data users can use the existing monitoringwithin budget or schedule constraints, technical wells for meeting the project objectives.personnel should prioritize the data needs withinthis basic group of data needs, but not eliminatedata needs at this step in the TPP process.

3.2.2 Optimum Data Collection Option.The “optimum” data collection option highlightsopportunities to collect data needed to satisfyfuture project objectives at the site, during thecurrent project. This grouping includes theportion of data needed for future executablestages that would be cost-effective and prudentto obtain during the current project. Theoptimum data collection option includes only

option to be considered by the customer duringPhase IV.

3.2.3 Excessive Data Collection Option.

classified as “excessive” will be those

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Development or recommendation of allthree types of data collection options maynot be possible or appropriate on somesites. For example, if no data needs wererequested, imposed, or mandated abovethe data need or data quality requirementsof the data users, then the excessive datacollection option is not necessary. Although development of an optimumdata collection option should always bepursued, recommendation of an optimumdata collection option may be deemedinappropriate if the data needed to satisfycurrent project objectives already exceedsproject cost and schedule constraints.

Sampling and analysis planningworksheets offer a concise yet completemeans of communicating the samplingand analysis methods to obtain data thatsatisfies the data requirements associatedwith the intended data uses. Wellprepared sampling and analysisworksheets can be inserted directly intoappropriate scope of work or work plansections.

All data needs within the excessive data standardized worksheets and tables will allowcollection option exceed the data needs or data quick and easy quality assurance/quality controlquality requirements of the data users for the review of the data collection and analysis plans.current and future executable phases of theproject. The excessive data collection option Critical aspects of documenting the appropriateshould not be misused to represent the data sampling and analysis methods and dataneeds that cannot be collected within cost or collection options are as follows:schedule constraints of the project. C What data needs are being met;

3.3 DOCUMENT DATA COLLECTIONOPTIONS.Data implementors are responsible for figures will be used during Phase IV activities.communicating data collection options forfurther consideration during Phase IV. Dataimplementors’ efforts to document projectspecific requirements for the basic, optimum,and excessive data collection options are criticalfor the success of TPP activities and continuedprogress to site closeout. Data implementorsshould consider recording the appropriatesampling and analysis methods and the datacollection options using the sampling andanalysis planning worksheet and the summarytable of data collection options provided inAppendix F or similar methods. Use of

C What project objectives will be satisfied;C How many samples need to be collected;C Where do the samples need to be collected;C What sample collection methods need to be

used (e.g., discrete or composite samples;sampling equipment and technique; qualityassurance/quality control samples);

C What sample analysis methods need to beused (e.g., sample preparation; laboratoryanalysis; method detection limit andquantitation limit; laboratory qualityassurance/quality control); and

C What technical limitations, cost benefits, andimposed requirements are associated witheach applicable data collection option.

Data implementors should also develop order-of-magnitude costs for preliminary estimates andprepare draft figures representing plannedsampling locations or areas. The data collectiontables, preliminary cost estimates, and draft

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3.4 COMPLETE PHASE IIIACTIVITIES.The technical personnel should review thesampling and analysis planning worksheets toensure that all data needs were appropriatelyincorporated within a data collection option. Inaccordance with the applicable qualitymanagement plan, the PM should also haveindependent technical resources review thesampling and analysis planning worksheets. (Anexample of a sampling and analysis planningworksheet is provided in Appendix F and maybe useful during independent review efforts.) Inany case, all projects will be periodicallyevaluated by the project team to ensure baselinerequirements of scope, schedule, and cost arebeing met. If it appears that some data needs2

were omitted from grouping within a datacollection option, the PM should meet with thedata implementors to correct the apparentomission. After the technical personnelcomplete quality control confirmation that thedata collection tables are complete, they shoulddocument in the project file if any data needswere not grouped within the data collectionoptions to be considered during Phase IV.

The PM should review any site informationworksheets or lists of site information dataneeds that were identified by the dataimplementors. It is the PM’s responsibility,working with the technical personnel, to decidehow and when the additional site informationdata needs will be fulfilled (e.g., discussionswith the customer, site visits, incorporatedwithin appropriate scope of work or work plansections).

At the conclusion of Phase III, the PM shoulddistribute copies of all sampling and analysisplanning worksheets and attach relatedillustrations to all appropriate TPP teammembers.

Phase I

Phase II

Phase III

Phase IV

IdentifyCurrent Project

DetermineData Needs

Develop DataCollection Options

Finalize DataCollection Program

· Finalize Data Collection Program· Document Data Collection Program

Existing SiteInformation

Customer'sGoals

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This chapter and the entire TPP processsupports efforts to prepare projectspecific DQO statements that meet thedefinition of a DQO as provided withinthe U.S. Environmental ProtectionAgency’s 7-Step DQO Process.1

Chapter 4Finalize Data Collection Program (Phase IV)

During Phase IV (see Figure 4-1) of theTechnical Project Planning (TPP) process thecustomer, project manager (PM), andappropriate technical personnel discuss datacollection options and finalize a data collectionprogram that best meets the customer’s short-and long-term goals for a site. This chapter alsooffers guidance for documenting the datacollection program with a project specific data The PM, key data users and data implementors,quality objective (DQO) statement for each data and customer should work together to designneed, final scope of work or work plan, detailed the data collection program. In many instances,cost estimates, and fact sheet(s). the customer and PM will also decide to involve

Communication and interaction with both the to design the data collection program. Designcustomer and the regulator are strongly of the data collection program will be based onencouraged during Phase IV efforts. the customer’s preferred combination of

Figure 4-1Phase IV of Four-Phase TPP Process

4.1 FINALIZE DATA COLLECTIONPROGRAM.

the regulators and stakeholders, as appropriate,

meeting current project objectives (“basic” dataneeds), obtaining data cost-effectively for futureexecutable stages (“optimum” data needs), andincluding any “excessive” data needs thecustomer chooses to retain.

Finalizing the data collection program requiresreview of the customer’s goals, the projectobjectives, the intended data uses, the datacollection options, and key risk managementconsiderations (e.g., feasibility, cost, schedule,uncertainty, and political concerns).

4.1.1 Prepare Customer Communications.If the customer was not directly involved indetermining the data needs (Phase II) anddeveloping the data collection options (PhaseIII), then summary information should beprovided. The PM should consider utilizinginput from both the data users and dataimplementors to ensure the summaryinformation is precise about both the dataneeded and the data collection options available.Illustrations representing the site or data

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The PM and technical personnel shouldcommunicate to the customer theuncertainty; cost and technical benefits;and regulatory perspective associatedwithin each data collection option.

collection activities and flowcharts or decision The PM or an assigned technical team membertrees may also be useful when communicating should lead the team through this sequence ofthe data collection options and activities to obtain the customer’s input and torecommendations to the customer. support the customer’s considerations.

In some instances, a summary table of data recommend to the customer the basic datacollection options and a series of sampling and collection option and present all elements ofanalysis planning worksheets, would provide the optimum data collection option.sufficient detail. (Appendix F provides a C The uncertainty, costs, and benefitssummary table of data collection options and an associated with the basic and optimum dataexample.) However, in most cases, it is more collection options should be explained andappropriate to add a simple overview discussed. Primary considerations shoulddescription that summarizes the important include schedule, budget, technicalattributes and characteristics of each option. A constraints, regulatory perspective, and sitewell prepared overview supplements a summary precedents.table of data collection options and describes C The PM and technical personnel shouldpotential effects of design decisions on quality, present and explain all elements of theschedule, and cost. Not only will this assist the excessive data collection option. Technicalcustomer in understanding the benefits and personnel should be prepared to belimitations of various data collection options, responsive to the customer’s questionsbut it will also provide the basis of subsequent regarding technical details and rationale;design discussions or presentations. cost and schedule implications; and site

4.1.2 Encourage Customer Participation.Efforts to design the data collection program options, as appropriate.should include obtaining input from thecustomer. The customer should always be When designing the data collection programinvited and encouraged to participate in design with customer input, technical personnel mustof the data collection program for their site. be sure that the customer understands theRegardless of a customer's level of technical effects of any reductions in the number ofexpertise related to the site work, the customer's samples or adjustments to the sampling orparticipation at this time will facilitate a design analysis methods. Although the customer maythat provides maximum customer satisfaction initially be satisfied with resulting schedule andwithin the schedule, budget, technical, and cost reductions, the increased uncertainty of theregulatory constraints associated with a site. findings may not satisfy the intended data uses

C The PM and technical personnel should

precedent concerns related to each elementof the excessive data collection option.Elements of the excessive data collectionoption should only be included in the datacollection program when explictedly desiredby the customer.

C The TPP team should finalize design of thedata collection program by combining thecustomer preferred components of the basic,optimum, and excessive data collection

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The Phase I Memorandum for Record,project objective worksheets, data needworksheets, and sampling and analysisplanning worksheets can be very useful tothe PM, customer, and technicalpersonnel when working with regulatorsduring consensus decision efforts.

or related project objectives. It is the In order to achieve regulator acceptance of theresponsibility of both the PM and the technical data collection program, their input andpersonnel to remind the customer of any concerns should be considered. Dependingregulatory requirements, technical constraints, upon the customer’s preference and experienceand stakeholder perspectives that should be with the regulators, the customer may be betterfactored into the customer’s decisions. served by meeting with the regulators after

In some instances, the PM may ask that data regulators for their review and comment. In anyusers and data implementors re-examine case, regulator desired refinements to the dataportions of their Phase II and III efforts to fully collection program should ultimately beunderstand and communicate consequences of incorporated only when explicitly agreed to byrefining the data collection program. In other the customer.instances, the project objectives correspondingwith the current project may need to be revised,or the number of project objectives may need tobe reduced or increased depending upon acustomer’s interests and needs while finalizingdesign of a data collection program. Changes togrouping of the project objectives shouldinvolve some revision to the Phase IMemorandum for Record or the applicableproject objective worksheet. Since there is noone correct answer for what belongs in a site’sdata collection program, a team will typically In many cases, stakeholder interests anditerate back into Phase II and Phase III while concerns can have a significant effect onfinalizing design of a data collection program. decisions made by both the customer and

4.1.3 Suggest Regulator Participation.Regulator involvement at this time during the participation is likely appropriate during thisTPP process will enhance acceptance of the final step in the TPP process. The team may want todesign. Regulator participation in the TPP offer stakeholders an opportunity to provideactivities can reduce the number of technical written comments regarding site plans. Or thecomments received from the regulators, reduce team may consider using some community orthe time expended to plan and execute work, public relations techniques and offer a specialand increase opportunities for the entire team to forum for stakeholders to learn more about thebe flexible and creative in resolving site rationale for the planned site activities. Theproblems. concerns and issues of stakeholders can typically

After discussions with the customer, but prior to and response exchange or by conducting afinal scoping, regulators should be included in a special meeting tailored to their understandingconsensus decision process. However, it is of the site. However, it remains the customer’salways the customer’s decision as to whether or decision as to whether, when, and howwhen regulators participate in the TPP process. stakeholders participate in this TPP activity.

DQOs have been written and provided to the

4.1.4 Consider Participation of Others.

regulator at a site. If stakeholders are activelyinterested in site activities, some level of their

be addressed and managed through a comment

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4.2 DOCUMENT DATA COLLECTIONPROGRAM.The PM and technical personnel must document documented during this TPP activity should bethe decisions made during the TPP efforts to project-specific statements that describe thecontribute to institutional knowledge at a site, intended data use(s), the data needand for presentation directly in related sampling requirements, and the means to achieve them.and analysis plans and work plans. DQOs documented as a result of the TPPDocumentation should include project-specific process should be comprehensive and includeDQOs, the final scope of work, a detailed cost each of the following data quality requirements.estimate, and a fact sheet(s) when appropriate.

4.2.1 Prepare Data Quality Objective (1) Project objective(s) satisfied.Statements.The preparation of DQO statements is aculmination of many of the TPP activities.Similar guidance for preparing DQOs isprovided in the U.S. Environmental ProtectionAgency’s (EPA’s) 7-Step DQO Process and inAmerican Society of Testing Materials.1,17

(Appendix E presents a detailed “crosswalk”from EPA’s 7-Step DQO Process to the TPPprocess.) The DQOs become the formaldocumentation of the data quality requirements.(Appendix F provides a DQO worksheet fordocumenting the nine data quality requirementsof a DQO.) Effective use of DQOs yield data ofknown quality, documentation of the planningprocess, and a benchmark to determine if thedata meet specified objectives. (Appendix Gprovides a DQO attainment verificationworksheet.)

4.2.1.1 Definition of a DQO.As defined by EPA, DQOs are “qualitative andquantitative statements derived from the DQOProcess that clarify study objectives, define theappropriate type of data, and specify thetolerable levels of potential decision errors thatwill be used as the basis for establishing thequality and quantity of data needed to supportdecisions.”1

DQOs produced as a result of the TPP processmeet EPA’s definition of a DQO. The DQOs

C Intended Data Use(s):

C Data Need Requirements:(2) Data user perspective(s)

(i.e., risk, compliance, remedy, orresponsibility) satisfied;

(3) Contaminant or characteristic of interestidentified;

(4) Media of interest identified;(5) Required sampling areas or locations

and depths identified;(6) Number of samples required

(e.g., fixed number or dynamic estimate;probabilistic or non-probabilistic basis);and

(7) Reference concentration of interest orother performance criteria (e.g., actionlevel, compliance standard, decisionlevel, design tolerance) identified.

C Appropriate Sampling and AnalysisMethods:(8) Sampling method (e.g., discrete or

composite sample; sampling equipmentand technique; quality assurance/qualitycontrol samples) identified; and

(9) Analytical method (e.g., samplepreparation, laboratory analysis methoddetection limit and quantitation limit,laboratory quality assurance/qualitycontrol) identified.

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Even on small projects, DQO statementsproduced as a result of the TPP processshould be reviewed by either project orindependent personnel to ensure eachDQO is complete and implementable.

4.2.1.2 Team Preparation of DQOs.A DQO statement should be prepared for each guidance and resources in order to prepare thedata need within a data collection program. detailed information and cost estimates for theThis manual recommends that key data users planned site activities.and data implementors share the responsibilityof preparing the DQO statements to ensure eachis correct and complete. Technical personnel The PM and technical personnel’s TPP effortsshould find this effort to involve merely may involve providing the customer withcompiling the information from the project community relations or public affairs assistanceobjective worksheets, the source data need to communicate information about the dataworksheets, and the sampling and analysis collection program. Although preparation ofplanning worksheets. (Appendix F provides DQOs, the project SOW or work plan, and aseveral worksheets and tables useful for detailed cost estimate are successful methods ofdocumenting TPP planning decisions.) communicating some of the pertinent

4.2.2 Prepare Final Scope of Work or WorkPlan.The PM should consult applicable scope of C Prepare customer to brief superiors,work (SOW) and work plan guidance, and rely regulators, other potentially responsibleon technical personnel, to prepare and finalize parties, or other stakeholders;the SOW or work plan for the project. In C Negotiate with regulators with, or on behalf,accordance with applicable guidance, the SOW of the customer;or work plan must include at least the project C Inform interested citizens or other partiesobjectives, site-specific DQO statements, and (e.g.; introduce public to a site; obtainthe related technical requirements. public participation in planning process;

4.2.3 Prepare Detailed Cost Estimate.The PM should coordinate the efforts of various concerns as a handout at a public meeting ortechnical personnel to prepare detailed cost as a direct mail brochure); andestimates for all components of the data C Provide an outline of key project planningcollection program. For contracted services, an information to include within a site’sIndependent Government Estimate is required. community relations plan.The PM will find that estimates are bestprepared immediately after data collectionprogram design, while technical personnel caneasily recall data collection program details.

Technical personnel will need to reference other

18

4.2.4 Prepare Fact Sheet(s).

information to parties involved in site planningand implementation activities, preparation of afact sheet(s) for presentation to regulators andother interested parties may be necessary orhelpful.

In instances where a fact sheet will be preparedfor presentation, the TPP team should carefullyplan the fact sheet for the receiving audience.Objectives of typical fact sheets include:

establish public concurrence with plannedactivities; or address public resistance or

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The PM should also store all the TPPproducts for the project together forfuture reference. Many of the TPPproducts should also be attached to themanagement plan for the project (e.g.,sampling and analysis planningworksheets; DQO statements; final SOW;work plans, and related cost estimates).

The team should consider the potentialcommunication value of some of the followingTPP products when planning to prepare a factsheet:C Site history and site background information

excerpts from the Phase I Memorandum forRecord, if confirmed to be accurate;

C Project objective worksheets preparedduring Phase I;

C Conceptual site model figures ordescriptions, including planned samplinglocations;

C Data need worksheets prepared duringPhase II;

C Sampling and analysis planning tablesprepared during Phase III;

C Site-specific summary tables of datacollection options prepared during Phase III;

C DQO statements; andC Final SOW or work plan.

4.3 COMPLETE PHASE IVACTIVITIES.The PM should distribute copies of all datacollection program components (e.g., Phase IMemorandum for Record; project objectiveworksheets; data need worksheets; sampling andanalysis planning worksheets; summary tables ofdata collection options; DQOs; final SOW orwork plan; detailed cost estimates; and factsheets) to the customer and technical personnel,as appropriate. (The customer should decidewhat TPP components, if any, will be providedto the regulators or stakeholders.) These itemswill aid preparation and review of subsequentsampling and analysis plans and work plansrelated to the current project activities.

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Chapter 5Implement and Assess Data CollectionProgram

This EM offers the Technical Project Planning possible. In some instances, it may be beneficial(TPP) process as a systematic planning process to reconvene key TPP team members tofor identifying project objectives and designing consider what TPP products should be furtherdata collection programs. This chapter provides reviewed or revised as a result of changedsome discussion about implementing and circumstances.assessing data collection programs that havebeen designed using the TPP process.

5.1 IMPLEMENTATION OF DATACOLLECTION PROGRAM.At the completion of Phase IV, sampling and users to understand any data usability limitationsanalysis plans and work plans should be finalized associated with project data. Efforts to verifyand field work should begin. It may also be DQO attainment can be thought of as follow-upbeneficial for contractors and laboratory TPP activities that should be conducted beforepersonnel, responsible for implementing the other data quality assessments are performed.plans, to meet with some members of the TPP Appendix G provides additional guidanceteam to discuss any questions and refer to the regarding verification of DQO attainment and arelated TPP products. related worksheet.

When issues arise during execution of the siteactivities, the TPP team should be consulted and After completing data collection activities at athe TPP products should be reviewed to quickly site, the TPP team should perform an evaluationresolve many issues and provide related of the effectiveness of the TPP planning andbackground planning information (e.g., project implementation efforts. Assessments andobjectives worksheet, data needs worksheet, evaluations should be done to improve futuresampling and analysis planning worksheets). TPP planning efforts and to prevent recurring

5.2 AMENDMENTS TO DATACOLLECTION PROGRAM.Amendments to project plans tend to be expenditures of cost and time for implementingunavoidable due to any number of the following the TPP process, and the resulting benefits. Ofcircumstances: particular interest is an evaluation of how costC External events (e.g., change in regulations); and schedule savings, attributed to use of theC Improvement in technologies (e.g., TPP process or concepts, compare to the

sampling, analysis, remediation); approximate expenditures of cost and time toC Inadequate or poorly defined requirements; assemble a TPP team and use the TPP process.C Discovery of incorrect technical

assumptions; andC Flaws in the initial plan or design.

When project plans need to be amended, the PMshould obtain input from the appropriate TPPperspectives to ensure that any additional datacollection is done as effectively and efficiently as

5.3 VERIFICATION OF DATAQUALITY OBJECTIVE ATTAINMENT.Efforts to evaluate and verify attainment of dataquality objective (DQO) statements enable data

5.4 ASSESSMENTS OF TPP EFFORTS.

problems.

One assessment should be regarding the

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5.5 PLANNING SUBSEQUENT DATACOLLECTION PROGRAMS.When beginning to plan the next executablestage of site activities, the current TPP team ora subsequent TPP team should begin at Phase Iby first updating the site approach andidentifying the next current project. The TPPprocess is iterative and should be repeated eachexecutable stage until site closeout is achievedfor the customer.

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A-1

Appendix AReferences

A.1 REQUIRED PUBLICATIONS.References listed below have been cited in the Environmental Restoration Program,text and the appendices. Department of Defense.

EPA QA/G-4, Guidance for the Data USACE DERP-FUDS Standard Operating1

Quality Objectives Process, EPA/600R- Procedures for Potentially Responsible Party96/055, U.S. Environmental Protection Projects.Agency.

ER 5-1-11, Program and Project Health Document Requirements for HTRW2

Management, U.S. Army Corps of and Ordnance Explosive Waste Activities.Engineers.

OSWER Directive No. 9355.7-04, Land Characterization of Vadose Zone and3

Use in the CERCLA Remedy Selection Groundwater Contamination at HazardousProcess, U.S. Environmental Protection Waste Contaminated Sites, AmericanAgency. Society of Testing Materials.

EPA/540/1-89/002, Risk Assessment OSWER Directive 9285.7-09A, Guidance4

Guidance for Superfund: Vol. 1 - Human for Data Useability in Risk Assessment (PartHealth Evaluation Manual (Part A), U.S. A), Final Report, U.S. EnvironmentalEnvironmental Protection Agency. Protection Agency.

EPA 1997 EPA/540/R-95/059, OSWER Directive No.5

OSWER Directive No. 9285.7-75. 9355.0-04B, Remedial Design/RemedialEcological Risk Assessment Guidance for Action Handbook, U.S. EnvironmentalSuperfund: Process for Designing and Protection Agency.Conducting Ecological Risk Assessments,Interim Final. EM 200-1-3, Requirements for the

E1689-95, Standard Guide for Developing U.S. Army Corps of Engineers.6

Conceptual Site Models for ContaminatedSites, American Society of Testing EM 200-1-6, Chemical Quality AssuranceMaterials. for HTRW Projects, U.S. Army Corps of

United States Code (USC) (several statutes7

are cited in this manual).

Title 40, Code of Federal Regulations8

(CFR) (several CFR cited only as examples).

Management Guidance for the Defense9

10

ER 385-1-92, Safety and Occupational11

D6235, Practice for Expedited Site12

13

14

15

Preparation of Sampling and Analysis Plans,

16

Engineers.

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A-2

D5792-95, Standard Practice for Generation FR 30810, Vol 55, No. 145, July 27, 1990,17

of Environmental Data Related to Waste 40CFR Parts 264, 265, 270, and 271,Management Activities: Development of Corrective Action for Solid Waste ManagementData Quality Objectives, American Society Units at Hazardous Waste Managementof Testing Materials. Facilities, Proposed Rule.

ER 1110-3-1301, Cost Engineering Policy FR 19431, Vol 61, No. 85, May 1, 1996,18

and General Requirements for Hazardous, Corrective Action for Releases from SolidToxic, and Radioactive Waste Cost Waste Management Units at Hazardous WasteEstimates, U.S. Army Corps of Engineers. Management Facilities; Proposed Rule.

ANSI/ASQC E4, Specifications and19

Guidelines for Quality Systems for U.S. Air Force 1992Environmental Data Collection and Installation Restoration Program RemedialEnvironmental Technology Programs, Project Manager's Guide.American National StandardsInstitute/American Society for QualityControl. AR 5-1

EPA 199820

EPA QA/G-9, Guidance for Data Quality AR 200-1Assessment - Practical Methods for Data Environmental Protection and Enhancement.Analysis, EPA/600/R-96/084.

Nayatani, Yoshinobu, and others, 1994, The Environmental Effects of Army Actions.21

Seven QC Tools: Practical Applications forManagers, Quality Resources, New York. AR 200-3(Figure 1 was adapted with permission of Natural Resources--Land, Forest and Wildlifepublisher, Quality Resources, New York.) Management.

A.2 RELATED PUBLICATIONS. A.2.4 U.S. Army Corps of EngineersThese additional sources of information arerelated to this manual. Note that these relatedpublications are restricted to current references ER 1110-1-12that are already published as a final document. Quality Management.

A.2.1 Federal Register (FR).FR 41000, Vol 54, Oct 4, 1989 Chemical Data Quality Management for HTRWNPL for Uncontrolled Hazardous Waste Sites, Remedial Activities.Final Rule.

A.2.2 U.S. Air Force.

A.2.3 U.S. Army.

Army Management Philosophy.

AR 200-2

(USACE).

ER 1110-1-263

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A-3

ER 1180-1-6 Project Manager and Technical ManagerConstruction Quality Management. Responsibility Guide for Hazardous, Toxic and

EP 1110-1-19Technical Requirements for Specifications to USACE CEMP-RT memorandum, subject:Report HTRW Environmental Restoration Cost "Environmental Cleanup and Protectionand Performance. Management Plan for Military Programs."

EP 1110-1-21 USACE CEMP-RT memorandum, subject:Air Pathway Analysis for the Design of HTRW "Technical Roles and Responsibilities for theRemedial Action Projects. USACE HTRW Program."

EM 200-1-1Validation of Analytical Chemistry Laboratories.

EM 200-1-4 Health Effects Assessment Summary Tables.Risk Assessment Handbook; Volume I: HumanHealth Evaluation; Volume II: Environmental EPAEvaluation. Integrated Risk Information System, On-Line

EM 200-1-5Design, Installation and Utilization of EPA 1986Fixed-Fenceline Sample Collection and OSWER Directive 9205.00-5, RCRA FacilityMonitoring Systems. Assessment Guidance.

EM 1110-1-502 EPA 1987Technical Guidelines for Hazardous and Toxic OSWER Directive 9345.1-02, Expanded SiteWaste Treatment and Cleanup Activities. Inspection.

EM 1110-1-1906 EPA 1987Soil Sampling. EPA/540/G-87/001-004, Data Quality

CEGS-01450Chemical Data Quality Control. EPA 1988

DRP-95-1 CERCLA Compliance with Other Laws Manual,User’s Guide for GEOSITE: Geotechnical Site Part I.Investigation Methods, U.S. Army EngineerWaterways Experiment Station, Vicksburg, MS. EPA 1988

Radiological Waste, Draft.

A.2.5 U.S. Environmental ProtectionAgency (EPA).EPA

Database.

Objectives for Remedial Response Activities.

OSWER Directive 9234.1-01 and -02,

EPA-530-SW-88-028, RCRA Corrective ActionPlan, Interim Final.

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A-4

EPA 1988 EPA 1991EPA-530-SW-88-029, RCRA Corrective Action OSWER Directive 9285.7-01B, Human HealthInterim Measures Guidance, Interim Final. Evaluation Manual, Part B: “Development of

EPA 1988EPA/540/1-88/001, Superfund Exposure EPA 1991Assessment Manual. OSWER Directive 9285.7-01C, Human Health

EPA 1989 Remedial Alternatives”.EPA/540/G-89/009, CERCLA Compliance withOther Laws Manual: Part II, Clean Air Act and EPA 1992Other Environmental Statutes and State EPA/630/R-92/001, Framework for EcologicalRequirements. Risk Assessment.

EPA 1989 EPA 1992EPA/530-SW-89-026, Statistical Analysis of Publication No. 9285.7-09B. PB92-963362.Ground-Water Monitoring Data at RCRA Guidance for Data Useability in RiskFacilities, Interim Final Guidance. Assessment. Part B.

EPA 1989 EPA 1992EPA/540/SW-89-031, RCRA Facility EPA/530-R-93-001, RCRA Ground-WaterInvestigation Guidance. Monitoring: Draft Technical Guidance.

EPA 1989 EPA 1992EPA/540/G-89/004, OSWER Directive 9355.3- Statistical Analysis of Ground-Water01, Guidance for Conducting Remedial Monitoring Data at RCRA Facilities -Investigations and Feasibility Studies Under Addendum to Interim Final Guidance.CERCLA.

EPA 1991 OSWER Directive 9203.1-01, SuperfundEPA-540/6-91/013, OSWER Directive 9345.0- Accelerated Cleanup Model (SACM).01A, Guidance for Performing PreliminaryAssessments Under CERCLA. EPA 1992

EPA 1991 Implementation of the SACM Under CERCLAData Use Categories and Data Useability. and the NCP.

EPA 1991 EPA 1992Streamlining Superfund Soil Studies: Using the EPA/540/R-92/021, Guidance for PerformingData Quality Objectives Process for Scoping. Site Inspections Under CERCLA.

Risk-Based Preliminary Remediation Goals.”

Evaluation Manual, Part C: “Risk Evaluation of

EPA 1992

OSWER Directive 9203.1-03, Guidance on the

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A-5

EPA 1992 EPA 1994EPA/540/R-92/071a, Guidance for Conducting EPA/542/B-94/013, Remediation TechnologiesTreatability Studies Under CERCLA, OSWER Screening Matrix and Reference Guide,Directive 9380.3-10. prepared by the DOD Environmental

EPA 1993 Remediation Technologies RoundtableEPA/625 /R-93 /003a , Subsur face (NTIS PB95-104782).Characterization and Monitoring Techniques, ADesk Reference Guide, Vol I: Solids and EPA 1994Ground Water, App A and B. EPA/540/R-93/519a, Guide for Conducting

EPA 1993 Biodegradation Remedy Selection.EPA/625 /R-93 /003b , Subsur faceCharacterization and Monitoring Techniques, A EPA 1995Desk Reference Guide, Vol II: Vadose Zone EPA 542-B-95-002, Guide to DocumentingField Screening and Analytical Methods, App C Cost and Performance for Remediation Projects.and D.

EPA 1993 EPA/542/R-95/001, Abstracts for RemediationEPA 540-F-93-047, Presumptive Remedies: Case Studies.Policy and Procedures.

EPA 1993 EPA/540/R-95/534, Principles and Practices ofEPA 540-F-93-048, Presumptive Remedies: Bioventing; Volume 1: Bioventing Principles;Site Characterization and Technology Selection Volume 2: Bioventing Design.for CERCLA Sites with Volatile OrganicCompounds in Soils. EPA 1986 - 1996

EPA 1993 Waste, Third Edition (September 1986), FinalEPA 540-F-93-035, Presumptive Remedy for Update I (July1992), Final Update IIA (AugustCERCLA Municipal Landfill Sites. 1993), Final Update II (September 1994), Final

EPA 1994EPA QA/G-4D, Data Quality Objectives EPA 1997Decision Errors Feasibility Trials Software for EPA/600/P-95/002Fa,b,c, Exposure Factorsthe Data Quality Objectives Process, Handbook, Office of Health and EnvironmentalEPA/600R-96/056. Assessment.

Technology Transfer Committee for the Federal

Treatability Studies Under CERCLA:

EPA 1995

EPA 1995

SW-846, Test Methods for Evaluating Solid

Update IIB (January 1995), Final Update III.

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A-6

EPA 1997 ASTM D4700EPA 4020R097-106, Multi-Agency Radiation Standard Guide for Soil Sampling From theSurvey and Site Investigation Manual. Vadose Zone.

EPA 1997 ASTM D4823EPA QA/G-9D, Data Quality Evaluation Standard Guide for Core Sampling Submerged,Statistical Toolbox (DataQuest), Unconsolidated Sediments.EPA/600R-96/085.

EPA 1998 Standard Guide to Site Characterization forOSWER Directive 9285.7-01D. EPA/540/R- Environmental Purposes With Emphasis on Soil,97/033. Human Health Evaluation Manual, Part Rock, Vadose Zone and Ground Water.D: “Standardized Planning, Reporting, andReview of Superfund Risk Assessments.” ASTM D5793

EPA 1998 Waste Management Activities: QualityEPA QA/R-5, EPA Guidance for Quality Assurance and Quality Control Planning andAssurance Project Plans, EPA/600R-98/018. Implementation.

EPA 1998 ASTM D5979EPA/542/B-98/002, Field Sampling and Standard Guide for Conceptualization andAnalysis Technologies Matrix and Reference Characterization of Ground-Water Systems.Guide.

EPA 1998 Standard Guide for Selection of the MinimumEPA/630/R-95/002F, Guidelines for Ecological Set of Data Elements Required to IdentifyRisk Assessment. Locations Chosen for the Field Collection of

A.2.6 American Society of TestingMaterials (ASTM).ASTM D4448 ASTM E1527Standard Guide for Sampling Groundwater Standard Practice for Environmental SiteMonitoring Wells. Assessments: Phase I Environmental Site

ASTM D4696Standard Guide for Pore-Liquid Sampling from ASTM E1903the Vadose Zone. Standard Guide for Environmental Site

ASTM D5730

Generation of Environmental Data Related to

ASTM D6168

Information to Describe Soil, Rock, and TheirContained Fluids.

Assessments Process.

Assessments: Phase II Environmental SiteAssessments Process.

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A-7

ASTM E1528 Plumb 1981Standard Practice for Environmental Site “Procedures For Handling and ChemicalAssessments: Transaction Screen Process. Analysis of Sediment and Water Samples,” U.S.

ASTM E1739 Experiment Station, Vicksburg, MS.Standard Guide for Risk-Based CorrectiveAction Applied at Petroleum Release Sites. Ramsey 1991

ASTM E1912 sampling theory to the sampling of solid wasteStandard Guide for Accelerated Site materials.” Presented at EPA's Seventh AnnualCharacterization for Confirmed or Suspected Waste Testing and Quality AssurancePetroleum Releases. Symposium, Washington, DC.

ASTM PS 104 Rendu 1980Provisional Standard Guide for Risk Based Rendu, J. M. 1980. “Disjunctive kriging: ACorrective Action. simplified theory,” Mathematical Geology 12,

ASTM ES 38-94Emergency Standard Guide for Risk-Based Rouhani 1993 Corrective Action Applied at Petroleum Release Rouhani, S. 1993. “EnvironmentalSites. applications--A modular three-day intensive

A.2.7 Others.American Society of Civil Engineers (ASCE) May 12-14, 1993.Task Committee on Geostatistical Techniques inGeohydrology (S. Rouhani, Chairman and Rouhani 1986Principal Author). “Review of geostatistics in Rouhani, S. 1986. “Comparative study ofgeohydrology, I. Basic concepts,” ASCE ground water mapping,” Journal of GroundJournal of Hydraulic Engineering 116(5), 612- Water 24(2), 207-16.32.

Barcelona 1988 Rouhani, S., and T. J. Hall 1988a. “Space-timeBarcelona, Michael J. 1988. “Overview of the kriging of groundwater data,” in M. Armstrong,sampling process.” Principles of environmental Geostatistics, vol 2, Kluwer Academicsampling. L. H. Keith, (ed.), American Publishers, Dordrecth, 639-50.Chemical Society, Washington, DC.

EPA and U.S. Army Engineer Waterways

Ramsey, Charles A. 1991. “Application of Gy's

306-21 (GEOS).

course (EST 153),” Course Notes, presented atthe Georgia Institute of Technology, Atlanta,

Rouhani and Hall 1988a

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A-8

Rouhani and Hall 1988bRouhani, S., and Hall, T. J. 1988b.“Geostatistical schemes for groundwatersampling,” Journal of Hydrology 103, 85-102.

Scholtes 1988Scholtes, Peter R. 1988. The team handbook,how to use teams to improve quality. JoinerAssociates Inc., Madison, WI.

Wentsel, et al., 1996Tri-Service Procedural Guidelines forEcological Risk Assessments.

Wiedmeier, T.H., et al 1996Technical Protocol for Evaluating NaturalAttenuation of Chlorinated Solvents in GroundWater, for Air Force Center for EnvironmentalExcellence, Technology Transfer Division,Brooks Air Force Base, San Antonio, TX.

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B-1

Appendix BAbbreviations and Acronyms

ANSI American National Standards MDRD minimum detectable relativeInstitute difference

AR Army Regulation MFR Memorandum for RecordARAR applicable or relevant and MS/MSD Matrix Spike/Matrix Spike

appropriate requirement DuplicateASCE American Society of Civil N/A not applicable

Engineers NCP National Contingency PlanASQC American Society for Quality NPL National Priority List

Control NTIS National Technical InformationASTM American Society of Testing Service

Materials O&M operation and maintenanceCEGS Corps of Engineers Guide OSWER Office of Solid Waste and

Specifications Emergency ResponseCERCLA Comprehensive Environmental P power

Response, Compensation and PA/SI Preliminary Assessment/SiteLiability Act of 1980 (commonly Investigationreferred to as “Superfund”) PM Project Manager

CFR Code of Federal Regulations PM Project Management PlanCL confidence limit PRP potentially responsible partyCSM conceptual site model PS Provisional StandardCWA Clean Water Act of 1972 QA/QC quality assurance/quality controlDERP Defense Environmental QAPP Quality Assurance Project Plan

Restoration Program RCRA Resource Conservation andDOD U.S. Department of Defense Recovery ActDRP Dredging Research Program SACM Superfund Accelerated CleanupDQO data quality objective ModelEM Engineer Manual SAP Sampling and Analysis PlanER Engineer Regulation SDWA Safe Drinking Water ActEP Engineer Pamphlet SOW scope of workEPA U.S. Environmental Protection SW surface water

Agency TBD to be determinedES Emergency Standard TCLP toxicity characteristic leachingESC expedited site characterization procedureFFA Federal Facility Agreement TDS total dissolved solidsFR Federal Register TOC total organic carbonFUDS Formerly Used Defense Sites TPP Technical Project PlanningGW groundwater USACE U.S. Army Corps of EngineersHTRW hazardous, toxic and radioactive USEPA U.S. Environmental Protection

waste AgencyHQUSACE Headquarters USACE

IDW investigation derived wasteMCL maximum contaminant levelMDL method detection limit

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C-1

Appendix C Conceptual Site ModelDefinitions

GLOSSARY OF TERMS AND PHRASESThe following terms and phrases are unique or chemical processes that affect contaminantcritical to this manual and the TPP process. transport. The TPP team should develop a

Analysis Data ImplementorChemists, biologists, industrial hygienists, and chemicals detected at a site and potentialother technical specialists who contribute to the exposure pathways to site receptors. Aanalysis data implementor perspective are preliminary CSM could also be developed forresponsible for identifying suitable analytical the purposes of evaluating site compliancemethods and requirements necessary to satisfy conditions; planning a removal or remedialdata needs within the data collection program. action; or evaluating potential contributions toAnalysis data implementors participate a site by other PRPs. Each data userthroughout the TPP process with their primary perspective will reference the site’s CSM duringresponsibilities occurring during Phase I and Phase II efforts to identify data needs.Phase III.

Areas of InterestSite areas or locations of particular interest to sponsor that depends upon the professionalindividual team members based on their services, expertise, and advice of a projectperspective (e.g., the segment of a stream used manager and technical personnel. Within thefor recreation represents an area of interest to TPP process, a customer is the decision makerthe risk data user; the discharge pipe and stream who is funding the project and responsible foroutfall from a water treatment plant represent achieving site closeout. Typical USACEareas of interest to the compliance data user). customers include U.S. Department of DefenseAreas of interest are established during Phase I, agencies, the U.S. Environmental Protectionrefined during Phase II, and considered Agency in some instances, and Support forthroughout the TPP process. Others (internal and external USACE

Compliance Data UserLegal counsel, regulatory specialists, industrial participate throughout the TPP process. Thehygienists, and other technical personnel who customer’s primary decision making and inputcontribute to the compliance data user occurs during Phases I and IV.perspective are responsible for identifying thedata needs associated with evaluating andmonitoring the legal and regulatory compliance Data collection options represent differentof a site or site activities. The compliance data groups of data needs and their associateduser participates throughout the TPP process sampling and analysis methods. Data collectionwith his/her primary responsibilities occurring options provide a simple mechanism toduring Phase I and Phase II. document the “basic” data needed for the

A conceptual site model (CSM) is a written orpictorial representation of the environmentalsystem at a site and the biological, physical, and

5

preliminary CSM during Phase I activities as asimple model of the relationships between

CustomerThe customer is a party, organization, or

customers). The customer is a key member ofevery TPP team and should be encouraged to

Data Collection Options

current project; “optimum” data that is cost-

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effective and prudent to collect for futureexecutable stages; and any “excessive” data that Data quality is a simple term used to representsomeone besides the data users imposes or several complex characteristics of a data need.mandates in excess of the data needed by data A data user’s quality requirements include theseusers. Data collection options are considered characteristics related to each data need:during Phases I and II, developed and C Contaminant or characteristic of interest;documented during Phase III, and used by the C Media of interest;team during Phase IV to design the data C Required sampling areas or locations, andcollection program for a site. depths;

Data Collection ProgramThe principal goal and outcome of the TPP non-probabilistic basis);process is the development and design of a data C Reference concentration of interest or othercollection program that is to be subsequently performance criteria (e.g., action level,implemented at a site. The team designs a data compliance standard, decision level, designcollection program throughout the TPP process tolerance);which culminates in the documentation of the C Sampling method [e.g., discrete ordata collection program during Phase IV. composite sample; sampling equipment and

Data ImplementorTechnical personnel (e.g., chemists, engineers, C Analytical method (e.g., sample preparation,geologists, scientists) who contribute to the data laboratory analysis method and quantitationimplementor perspective are responsible for limit, laboratory QA/QC).identifying sampling and analysis methodssuitable for satisfying the data users’ data needs. Data quality requirements can only beData implementors are generally referred to as established by the data user ultimately using theeither a sampling or analysis type of data data. Data users establish data qualityimplementor. Both sampling and analysis types requirements based on a level of uncertaintyof data implementors participate throughout the scientifically acceptable for the intended dataTPP process with their primary responsibilities use(s) and accepted practices within a particularoccurring during Phase I and Phase III. field (e.g., science, engineering, legal).

Data Need WorksheetSeveral data user-specific data need worksheets requirements for a data need are defined by theare provided in Appendix F for documenting data user when identifying each data needdata needs. The data need worksheets can be during Phase II. During Phase III, dataused in part to determine data needs. Data need implementors define the remaining data qualityworksheets, or other similar forms, can be requirements for each data need when theyprepared by each data user perspective to determine appropriate sampling and analysisspecify environmental data needs. Data need methods. During Phase IV, data qualityworksheets are prepared by data users during requirements become a large part of thePhase II and subsequently used by data planning information documented in a dataimplementors during Phase III. quality objective statement for each data need.

Data Quality

C Number of samples required (e.g., fixednumber or dynamic estimate; probabilistic or

technique; quality assurance/quality control(QA/QC) samples]; and

Most characteristics of data quality

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Data Quality Objectives (DQOs) Data Quality Objectives WorksheetDQO statements are the culmination of many The DQO worksheet provided in Appendix F isTPP activities. DQOs become formal a tool useful for documenting the nine datadocumentation of the data quality requirements. quality requirements of a DQO produced duringEffective use of DQOs yield data of known the TPP process.quality, documentation of the planning process,and a benchmark to determine if data meetspecified objectives. DQOs produced as a result Data users are technical and other personnelof the TPP process meet EPA’s definition of a responsible for engineering, scientific, and legalDQO and should be project-specific statements evaluations that are the basis for site decisions.that describe the intended data use(s), the data Progress to site closeout typically requires theneed requirements, and the means to achieve collaborative involvement of many technicalthem. DQOs documented as a result of the TPP disciplines to represent data user perspectives ofprocess should include the following nine data risk, compliance, remedy, and responsibility.quality requirements: Data users are responsible for determining data1 Project objective(s) satisfied; needs required to satisfy the project objectives.2 Data user perspective(s) Data users participate throughout the TPP

(i.e., risk, compliance, remedy, or process with their primary responsibilitiesresponsibility) satisfied; occurring during Phase I and Phase II.

3 Contaminant or characteristic of interestidentified;

4 Media of interest identified; Decision makers (i.e., customer, PM, regulators,5 Required sampling areas or locations, and and stakeholders) each have specific interests in

depths identified; the outcome of site-related activities. The most6 Number of samples required important responsibility of each decision maker

(e.g., fixed number or dynamic estimate; is to participate in the team’s efforts to identifyprobabilistic or non-probabilistic basis); and document project objectives during Phase I.

7 Reference concentration of interest or other As deemed appropriate by the customer, theperformance criteria (e.g., action level, regulators and stakeholders may also contributecompliance standard, decision level, design to TPP activities during Phases II through IV.tolerance) identified;

8 Sampling method [e.g., discrete orcomposite sample; sampling equipment and A dynamic work plan is a work plan thattechnique; quality assurance/quality control includes some decision logic in advance of field(QA/QC) samples] identified; and activities, including sampling that is directly

9 Analytical method (e.g., sample preparation, contingent on the findings of earlier sampling.laboratory analysis method detection limit Dynamic work plans empower field personnel toand quantitation limit, laboratory QA/QC) decide on-site to modify field efforts as siteidentified. conditions are better understood during data

Data User

Decision Maker

Dynamic Work Plan

collection efforts. Dynamic work plans can onlybe successful if the entire team agrees with theplans and the plans include when and howcommunications will occur between field

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personnel and the customer, regulators, andstakeholders, as appropriate. Dynamic work Field screening and field analytical methods canplans are most commonly used when expedited be a useful tool to characterize site contaminantssite characterization approaches are being while reducing analytical costs. The team couldemployed and field personnel are using real-time plan to conduct some field screening activitiesdata acquisition and interpretation methods. concurrent with Phase I, II, or III TPP efforts to

Environmental DataEnvironmental data are site-specific current executable stage of site activities.environmental-type data (e.g., chemical,biological, physical) that must be obtained fromthe field or by laboratory analysis of a sample Air, surface water, sediment, soil, andcollected in the field. Environmental data, as groundwater are the most common types ofreferred to in this manual, should not be environmental media at a site. Media can be anymistaken for “site information.” Environmental naturally occurring environmental material thatdata needs are identified by data users during can be affected by contamination at a site.Phase II and are typically listed on data needworksheets provided in Appendix F.

Executable StageDuring Phase I the team identifies all possible of Phase I. Appendix F provides a worksheetexecutable stages to site closeout for each for preparing a Phase I MFR during Phase I ofunique site. Depending on the size and the TPP process. A Phase I MFR should clearlycomplexity of the site, several executable stages document the current project and associatedmay be necessary and appropriate to proceed project objectives, within the context of thefrom site investigation to site closeout. Scoping overall site approach, for the current executableexecutable stages is based on an overall site stage of site activities. The MFR should clearlyapproach and a current project focus that reflect indicate the customer's goals (i.e., concept ofthe effects of project constraints, project site closeout, schedule requirements, and sitedependencies, and options for project execution. budget), as well as site constraints and

Expedited Site CharacterizationExpedited site characterization (ESC) is a members at the end of Phase I. If a customer’smethodology that utilizes in-field decision site budget or schedule changes, the changesmaking, dynamic work plans, and real-time data should be documented and then communicatedacquisition and interpretation. Although ESC to the entire team using technical memorandums12

has several similarities to the TPP process, the or addendums to the Phase I MFR. Inentire TPP process should be used to develop accordance with the applicable qualitythe data collection program that will be fulfilled management plan, the PM should haveusing ESC methodology. ESC should be independent technical or management personnelconsidered as an execution option during Phase review the Phase I MFR to ensure it is effectiveI, and planned for throughout Phases II, III, and and complete.IV when deemed appropriate for site activities.

Field Screening/Field Analytical

refine their understanding of a site prior todesign of a data collection program for the

Media

Phase I MFRThe Phase I MFR (memorandum for record) isa document that should be prepared at the end

dependencies. The PM is responsible fordistributing the Phase I MFR to all team

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Point of Compliance (or Compliance Point) Project Objectives WorksheetA compliance point is the location, identified by The project objectives worksheet provided inthe compliance data user perspective where a Appendix F is a tool useful for documenting andspecific data need exists due to an applicable or managing project objectives throughout the TPPrelevant and appropriate requirement. Typical process.points of compliance include the outfall of apermitted water treatment facility or theatmospheric discharge point of an air treatment Federal, state, and local regulators are decisionsystem. makers who may have jurisdictional authority to

Presumptive RemediesPresumptive remedies are preferred technologies followed during site characterization andfor common categories of sites, based on remediation. Regulators may also establishremedy selection and implementation schedules under Federal Facility Agreementsexperience. A suitable presumptive remedy can that can stipulate penalties for missed milestoneaccelerate the planning process; provide dates. Regulators with possible jurisdictionalconsistency in remedy selection; reduce the authority should be included in TPP efforts toremediation schedule and expenditures; and ensure efficient progress to site closeout. Inachieve earlier site closeout. particular, regulator input is prudent during

Project Manager (PM)Within the TPP process, the PM is the decision also be welcomed to contribute during Phase IImaker responsible for leading the team’s TPP and Phase III of TPP activities.efforts, progressing towards site closeout, andmeeting the customer’s expectations. The PM’sleadership role in the TPP process is most Design and construction engineers,apparent during Phases I and IV. During Phases hydrogeologists, technicians, and other technicalII and III, the PM should function more in a personnel who contribute to the remedy datasupport role by responding to information needs user perspective are responsible for identifyingof the technical personnel who are representing the data needs associated with the remedy ordata user and data implementor perspectives. specific remedy components for site closeout

Project ObjectivesProject objectives are the short- and long-term data user participates throughout the TPPsite issues to be addressed and resolved at a site. process with his/her primary responsibilitiesSatisfying or resolving the project objectives, occurring during Phase I and Phase II.based on the underlying regulations or sitedecisions, are the purpose of all site activities.Identifying and documenting the projectobjectives for a site during Phase I can berelatively straightforward since most projectobjectives are a consequence of the governingstatutes and applicable regulations.

Regulators

directly affect site closeout. Regulators mayspecify standards, criteria, and guidance to be

Phase I and portions of Phase IV. As deemedappropriate by the customer, regulators may

Remedy Data User

based on the remedy stage of the site and theexecutable phase of the project. The remedy

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Responsibility Data User Sampling Data ImplementorLegal counsel, attorneys, and legal perspective Engineers, geologists, chemists, and otherpersonnel who contribute to the responsibility technical specialists who contribute to thedata user perspective are responsible for sampling data implementor perspective areidentifying data needs associated with potential responsible for identifying suitable samplinglitigation of the appropriate apportionment of methods and requirements necessary to satisfyresponsibility for site investigation and closeout data needs within the data collection program.activities. The responsibility data user The sampling data implementor participatesparticipates throughout the TPP process with throughout the TPP process with his/herhis/her primary responsibilities occurring during primary responsibilities occurring during PhasePhase I and Phase II. I and Phase III.

Risk Data User Scope of WorkRisk assessors; industrial hygienists; chemists; A scope of work (SOW) is a narrativegeologists; scientists; occupational health and description of work to be performed by asafety specialists; and other technical personnel contractor. Several SOW sections are typicallywho contribute to the risk data user perspective used as an acquisition instrument withare responsible for identifying the data needs information sufficient to enable offerors toassociated with evaluating current and future submit proposals and the resultant contractor torisk (human health or ecological) associated perform at levels that meet the government'swith site conditions, site investigation activities, needs. A SOW includes criteria such asand site remediation conditions. The risk data required work products, work quality standards,user participates throughout the TPP process budget parameters, schedule or deliverywith his/her primary responsibilities occurring requirements, and specific performanceduring Phase I and Phase II. requirements.

Sampling and Analysis Planning Worksheet Sensitivity LimitsThe sampling and analysis planning worksheet is Sensitivity limits are the capability of a methoda tool that can be used to document data or instrument to discriminate betweencollection plans, but not directly useful for the measurement responses representing differentpurpose of identifying sampling and analysis levels of a variable of interest. Analysis andmethods for site activities. The sampling and sampling data implementors work togetheranalysis planning worksheet is intended to during Phase III to evaluate sensitivity limits toprovide data implementors a method to organize ensure that appropriate sampling and analysisand communicate the recommended sampling methods are selected to obtain the data neededand analysis methods to obtain the data needed by the data users. Data implementors can usewithin each data collection option (i.e., basic, the sampling and analysis planning worksheetoptimum, and excessive). Sampling and analysis provided in Appendix F when selecting theplanning worksheets are prepared by data methods and setting method detection limits andimplementors during Phase III and are used quantitation limits.during Phase IV design of the data collectionprogram. A sampling and analysis planningworksheet is provided in Appendix F.

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Site ApproachA site approach is an overall strategy for Appendix F provides a Site Informationmanaging a site from its current condition to the Worksheet useful during TPP efforts. It is thedesired site closeout condition. Identification of PM’s responsibility, working with the technicala site approach during Phase I enables a team to personnel, to decide how and when sitebe better prepared to manage and consider the information data needs will be fulfilled.effects of outside constraints and proposedchanges to data collection programs. Criticalelements of a site approach include a preliminary The Site Information Worksheet is provided inconceptual site model, the project objectives, Appendix F for documenting and managing siteother stakeholder perspectives, the probable information needs throughout the TPP process.remedies, and some definition of executablestages to site closeout.

Site CloseoutSite closeout is achieving the “walk away goal,” owners, restoration advisory boards, and anyor the final condition of a site, as envisioned by number of other individuals or special interestthe customer. The efforts to define site closeout groups. The TPP process advocates thatinvolve understanding the customer’s vision for concerns and ideas of stakeholders bethe site and translating his/her vision into a considered during TPP efforts to contribute todescriptive statement that can be used by the efficient progress to site closeout. Phase I ofteam. The scope and meaning of site closeout is the TPP process includes a deliberate effort todefined by the team during Phase I and then determine and consider community interests andprovides focus to all personnel during execution the perspectives of stakeholders. A Phase IVof the TPP activities and subsequent site activity encourages the team to prepare andactivities. distribute fact sheets, when appropriate, for

Site Information DataSite information data is specific site information deemed appropriate by the customer, variousthat is not obtained as the result of stakeholders may also be welcomed toenvironmental field work. Site information data contribute during Phase II and Phase III of TPPneeds are typically noncontaminant-related site activities.information obtained from the site's owner (e.g.,“as-built” drawings, geological information),technical or site-specific literature (e.g., A summary table of data collection options isprecipitation and temperature trends; current provided in Appendix F as a tool useful forand future zoning; material or equipment documenting an overview or summary of dataavailability; site operations information) or an collection options. The summary table of dataengineering-type site visit (e.g., topographic collection options is not directly useful forsurvey; utility conflicts and service connections; identifying basic, optimum, and excessive typessite access). Preliminary site information data of applicable data collection options for a site.needs are generally identified during Phase I It provides data implementors a tool and methodwith additional site information data needs to communicate the fundamental aspects of each

identified by data users during Phase II.

Site Information Worksheet

StakeholdersStakeholders with interests in site activities andsite closeout could include current property

communicating the data collection program tointerested parties including stakeholders. As

Summary Table of Data Collection Options

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data collection option (i.e., number of samples,level of effort, order-of-magnitude cost, and This manual presents the TPP process forrelated considerations). The team will use the designing data collection programs at HTRWsummary table when considering the data sites. The TPP process helps ensure that thecollection program tables and designing the data requisite type, quality, and quantity of data arecollection program for a site during Phase IV of obtained to satisfy project objectives that lead tothe TPP process. A summary table of data informed decisions and site closeout. The four-collection options is prepared by data phase TPP process is a comprehensive andimplementors at the end of Phase III. systematic planning process that will accelerate

Team Information PackageA team information package is an informal investigation through closeout at small, simplecollection of existing site information that is sites, as well as large, complex sites. The TPPcompiled early during Phase I for reference by process is a critical component of the USACEthe entire team. Common components of a quality management system that meets theteam information package include existing site American National Standard for planning thedata, reports, illustrations, or drawings; the collection and evaluation of environmentalcustomer’s concept of site closeout; the data. Appendix D provides an outline of thecustomer’s schedule and budget requirements; activities within the TPP process.all correspondence from regulators; an index ofthe project file and/or administrative record, ifavailable; and a list of the individuals on the TPPteam for a site. The PM typically distributes theteam information package to the team earlyduring Phase I efforts.

Technical Planning Team (Team)The TPP process requires a multi-disciplinaryteam of personnel to represent the planningperspectives of decision-making, data use, anddata implementation. The PM is responsible forensuring that all TPP perspectives arerepresented within a multi-disciplinary team ofpersonnel. On small, relatively simple sites,personnel implementing the TPP process mayperform multiple roles and support multipleperspectives. In general, several disciplines oftechnical and legal personnel will collaborate torepresent each of data user and dataimplementor perspective for a site. The team isidentified during Phase I and works togetherthroughout the TPP process and execution ofthe work.

Technical Project Planning (TPP) Process

progress to site closeout within all projectconstraints. The TPP process can be used from

19

Phase II

Phase III

Phase IV

Develop DataCollection Options

Finalize DataCollection Program

Existing SiteInformation

Detailed Data Quality Objectives

Technical Basis for Sampling andAnalysis Plan; Quality AssuranceProject Plan; and Work Plan

Accurate Cost Forecasting

Progress to Site Closeout

DetermineData Needs

Customer'sGoals

Detailed Project Objectives

Phase IIdentify

Current Project

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Appendix DOutline of TPP Activities

Table D-1 provides an outline of the TechnicalProject Planning (TPP) process (see Figure D-1) Chapter 5 provides some discussion aboutactivities described in this manual. implementing and assessing data collection

Figure D-1Technical Project Planning (TPP) Process

Chapters 1 through 4 describe how to conductPhase I through Phase IV of the TPP process,respectively.

programs that have been designed using the TPPprocess.

The preparation of data quality objective (DQO)statements is just one of the outcomes of theTPP process. Similar guidance for preparingDQOs is provided in the U.S. EnvironmentalProtection Agency’s (EPA’s) 7-Step DQOProcess and in American Society of TestingMaterials. (Appendix E presents a detailed1,17

“crosswalk” from EPA’s 7-Step DQO Processto the TPP process.)

Appendix F provides several worksheets andtables for documenting TPP information,decisions, and plans. The Appendix F tools areintended to help a team design and document adata collection program throughout their use ofthe TPP process.

Appendix G provides additional guidanceregarding verification of DQO attainment and arelated worksheet. Efforts to verify DQOattainment can be thought of as follow-up TPPactivities that should be conducted before otherdata quality assessments are performed.

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Table D-1Outline of TPP Activities

Phase Activity Sub-Activities/Consideration(s)

Phase I

1.1Prepare Team Information Package

Team Information Package = an informal collection of existingsite information that is compiled forreference by the entire team

1.1.1 1.1.1.1 Decision MakersIdentify TPP Team Members(p 1-2 to 1-5)

1.1.1.2 Data Users1.1.1.3 Data Implementors1.1.1.4 Team Selection

1.1.2 1.1.2.1 Customer’s Concept of Site CloseoutIdentify Customer Goals(p 1-5 to 1-6)

1.1.2.2 Customer’s Schedule Requirements1.1.2.3 Customer’s Site Budget

1.1.3 1.1.3.1 Conduct Preliminary Site Visit Gather Existing Site Information(p 1-6 to 1-7)

1.1.3.2 Gather Site Data and Reports1.1.3.3 Obtain Operations Records1.1.3.4 Collect Background Literature1.1.3.5 Conduct Site History Interviews

Phase I

1.2Identify Site Approach

Site Approach = an overall strategy for managing asite from its current condition to thedesired site closeout condition

1.2.1 1.2.1.1 Review Site Information and DataEvaluate Site Information and Data(p 1-8 to 1-10)

1.2.1.2 Identify Preliminary Conceptual SiteModel1.2.1.3 Identify Potential Points ofCompliance1.2.1.4 Designate Media of Potential Concern

1.2.2 1.2.2.1 Primary Regulatory ProcessesIdentify and Document Project Objectives(p 1-10 to 1-12)

1.2.2.2 Secondary Regulatory Programs 1.2.2.3 Other Project Objectives

1.2.3 1.2.3.1 Determine Regulator PerspectivesIdentify Regulator and Stakeholder Perspectives(p 1-12)

1.2.3.2 Determine Community Interests

1.2.4 1.2.4.1 Presumptive RemediesDefine Probable Remedies(p 1-12 to 1-13)

1.2.4.2 Innovative Technologies

1.2.5Identify Executable Stages to Site Closeout thought of as the site activities scheduled to(p 1-13 to 1-14) occur between milestones along the critical

(The scope of an executable stage can be

path timeline of site activities.)

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Table D-1 (continued)Outline of TPP Activities

Phase Activity Sub-Activities/Consideration(s)

D-3

Phase I

1.3Identify Current Project

Current Project = a detailed strategy for completing Requirements the current executable stage(s) ofsite activities including finalizationof project objectives

1.3.1 1.3.1.1 Administrative Constraints andRecognize Site Constraints and Dependencies(p 1-14 to 1-16)

Dependencies

1.3.1.2 Technical Constraints andDependencies

1.3.1.3 Legal and Regulatory Milestones and

1.3.2 1.3.2.1 Operable Units/Exposure AreasDefine Courses of Action for Achieving SiteCloseout(p 1-16 to 1-17)

1.3.2.2 Expedited Removal

1.3.2.3 Phasing (Series or Parallel)

1.3.2.4 Field Screening and Field AnalyticalMethods

1.3.2.5 Expedited Site Characterization

1.3.3Document Current Executable Stage executable stage by renumbering all project(p 1-18) objectives to represent the planned sequence,

The team should document the current

as well as clearly differentiate between thebasic project objectives associated withcurrent project and the optimum projectobjectives associated with future executablestages at a site.

Phase I

1.4Complete Phase I Activities

1.4.1 Finalize Acquisition Strategy(p 1-18)

1.4.2 Initiate Scope of Work Sections(p 1-19)

1.4.3 Prepare Phase I Memorandum for Record(p 1-19)

A complete Phase I MFR contributes toinstitutional site knowledge about a site andshould be a stand-alone document attached tothe site-related Project Management Plan.

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Table D-1 (continued)Outline of TPP Activities

Phase Activity Sub-Activities/Consideration(s)

D-4

Phase II Review of Phase I information is particularly

2.1Determine Data Needs some time has passed since Phase I efforts

data need =site information or environmentaldata that is required to satisfy aproject objective(s)

2.1.1Review Phase I Memorandum for Record (MFR) critical for those personnel not involved in(p 2-1) Phase I efforts and for the entire team when

were completed.

2.1.2 2.1.2.1 Risk Data User PerspectiveEstablish Data User’s Roles(p 2-1 to 2-4) 2.1.2.2 Compliance Data User Perspective

2.1.2.3 Remedy Data User Perspective

2.1.2.4 Responsibility Data User Perspective

2.1.3Evaluate Use of Existing Data and critical TPP activity that must occur prior(p 2-4) to determining the additional data needed at a

The review of existing data is a fundamental

site to satisfy the project objectives.

2.1.4 2.1.4.1 Probabilistic/Non-ProbabilisticDefine Data Needs(p 2-4 to 2-9)

Decisions2.1.4.2 Number of Samples2.1.4.3 Data Collection Considerations2.1.4.4 Risk Data Needs2.1.4.5 Compliance Data Needs2.1.4.6 Remedy Data Needs2.1.4.7 Responsibility Data Needs

Phase II (p 2-9) What data is needed to satisfy which project

2.2Document Data Needs What is the intended data use(s)?

objective(s)?Who needs the data?

What number of samples are required tosatisfy the intended use(s)?What is reference concentration of interest orother performance criteria?Where is area of interest or desired samplinglocation(s) and depth(s)?

Phase II (p 2-10) Review Data Need Worksheets

2.3Complete Phase II Activities

Review Lists of Site Information NeedsDistribute Data Need Worksheets

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Table D-1 (continued)Outline of TPP Activities

Phase Activity Sub-Activities/Consideration(s)

D-5

Phase III

3.1Plan Sampling and AnalysisApproach

3.1.1 3.1.1.1 Review Phase I MFRReview Phase I and Phase II Information(p 3-1 to 3-2)

3.1.1.2 Review Phase II Data Needs

3.1.2 3.1.2.1 Sort and Combine Data NeedsPlan Sampling and Analysis Approaches(p 3-2 to 3-7)

3.1.2.2 Develop and Document SamplingStrategies3.1.2.3 Develop and Document AnalysisStrategies3.1.2.4 Refine Plans Within ProjectConstraints

Phase III The “basic” data collection option is the data

3.2Develop Data Collection Options The data collection efforts would produce data

data collection options = “basic,” “optimum,” and“excessive” data collection optionsare labels for data collection plansthat satisfy the basic projectobjectives related to the currentexecutable phase; minimize futurecosts by collecting data forsubsequent executable phases(optimum project objectives); andclearly isolate any data that isimposed or mandated by others inexcess of the data needed by datausers (excessive), respectively.

3.2.1Basic Data Collection Option set needed to satisfy the current project(p 3-8) objectives (e.g., remedial investigation data).

that meets all the data quality requirements ofthe data users for only the current project.

3.2.2Optimum Data Collection Option highlights opportunities to collect data needed(p 3-8) to satisfy future project objectives during the

The “optimum” data collection option

current project. This grouping includes theportion of data needed for future executablestages that would be cost-effective andprudent to obtain during the current project.

3.2.3Excessive Data Collection Option data needs that data users believe are(p 3-8 to 3-9) excessive for the purposes of satisfying both

This unique group of data needs are those

current and future project objectives. Thedata needs classified as “excessive” are thosespecifically requested, imposed, or mandatedby others, but not needed by data users.

Phase III (p 3-9) What data needs are being met?

3.3Document Data Collection Options Where do the samples need to be collected?

What project objectives will be satisfied?How many samples need to be collected?

What sample collection methods need to beused?What sample analysis methods need to beused?What technical limitations, cost benefits, andimposed requirements are associated witheach type of applicable data collection option?

Phase III (p 3-10) Review Data Collection Tables

3.4Complete Phase III Activities

Review Lists of Site Information NeedsDistribute Data Collection Tables

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Table D-1 (continued)Outline of TPP Activities

Phase Activity Sub-Activities/Consideration(s)

D-6

Phase IV Customer briefing should communicate to a

4.1Finalize Data Collection Program with each data collection option.

data collection program = plans for obtaining site informationand environmental data needed bydata users for satisfying projectobjectives and supporting sitedecision making efforts

4.1.1Prepare Customer Communications customer uncertainty, cost and technical(p 4-1 to 4-2) benefits, and regulatory perspective associated

4.1.2Encourage Customer Participation should include obtaining input from the(p 4-2 to 4-3) customer. The customer should always be

Efforts to design the data collection program

invited and encouraged to participate in designof the data collection program for their site.

4.1.3Suggest Regulator Participation to final scoping, the regulator should be(p 4-3) included in a consensus decision process.

After discussions with the customer, but prior

However, it is always the customer’s decisionas to whether or when the regulator is askedto participate in the TPP process.

4.1.4Consider Participation of Others concerns can have a significant effect on (p 4-3) decisions made by both the customer and

In many cases, other stakeholder interests and

regulator at a site. If stakeholders are activelyinterested in site activities, some level of theirparticipation is likely appropriate during thisstep in the TPP process.

Phase IV

4.2Document Data Collection Program

4.2.1 4.2.1.1 Definition of a DQOPrepare Data Quality Objective Statements(p 4-4 to 4-5)

4.2.1.2 Team Preparation of DQOs

4.2.2Prepare Final Scope of Work or Work Plan SOW and work plan must include at least the(p 4-5) project objectives, site-specific DQO

In accordance with applicable guidance, the

statements, and related technicalrequirements.

4.2.3Prepare Detailed Cost Estimate are best prepared immediately after data(p 4-5) collection program design, while technical

The PM will generally find that cost estimates

personnel can easily recall details of the datacollection program.

4.2.4Prepare Fact Sheet(s) prepared for presentation, the customer, PM,(p 4-5 to 4-6) legal, and technical personnel should carefully

In instances where a fact sheet will be

plan the fact sheet for the receiving audience.

Phase IV (p 4-6) The PM should distribute copies of all data

4.3Complete Phase IV Activities appropriate. Many of the TPP products

collection program components to thecustomer and technical personnel, as

should also be attached to the PMP.

EM 200-1-231 Aug 98

E-1

Appendix E E.3 Use of EPA’s 7-Step Process DuringCrosswalk to EPA’s 7-Step DQO Process

E.1 Comparison of TPP Process to EPA’s7-Step DQO ProcessU.S. Environmental Protection Agency’s guidance corresponds to a specific TPP activity.(EPA’s) 7-Step Data Quality Objective (DQO) In those instances when a data user defines aProcess and the Technical Project Planning probabilistic-type data need during Phase II (see1

(TPP) process are both planning tools intended Paragraph 2.1.4.1), the data user should useto ensure data are of the type, quantity, and Steps 5 and 6 of the 7-Step DQO Process toquality needed for decision making at determine the number of samples required forhazardous, toxic, and radioactive waste sites. the intended data use. During Phase III, dataFigure E-1 represents similarities between implementors will find Step 7 of EPA’s 7-StepEPA’s 7-Step DQO Process and the TPP DQO Process useful when optimizing samplingprocess. As compared to the 7-Step DQO plans for the data needed for probabilisticProcess, the TPP activities, guidance, and tools decisions. After using Steps 5 through 7 ofprovide more explicit guidance and support for EPA’s 7-Step Process, use of the TPP processdesigning a data collection program for a site. should be completed to ensure appropriate

In general, the 7-Step DQO Process is a obtain the data needed, data collection optionsdecision quality objective process that enables a are considered, and detailed DQO statementsteam to quantify tolerable decision error within are produced.a sample design. The 7-Step DQO Processsupports a team’s efforts to develop the basisfor probabilistic decisions at a site. Outputs As defined by EPA, DQOs are “qualitative andthroughout the 7-Step DQO process are the quantitative statements derived from the DQOdecision performance criteria that will be used Process that clarify study objectives, define theto develop a data collection program. appropriate type of data, and specify the

The TPP process is a comprehensive and will be used as the basis for establishing thesystematic project planning process to design a quality and quantity of data needed to supportdata collection program. Preparation of decisions.” As discussed in Paragraph 4.2.1,probabilistic and nonprobabilistic DQO DQOs produced as a result of the TPP processstatements is the culmination of many of the meet EPA’s definition of a DQO. The DQOsTPP activities. DQO statements are just one of documented during Phase IV of the TPPthe outcomes of the TPP efforts. process should be project-specific statements

E.2 Crosswalk Between EPA’s 7-StepDQO Process and the TPP ProcessTable E-1 offers a detailed crosswalk from eachportion of EPA’s 7-Step DQO Process to thecorresponding activity within the TPP process.

TPP ActivitiesWhen using the TPP process, technicalpersonnel can refer to Table E-1 to determinewhich portion(s) of EPA’s 7-Step DQO Process

sampling and analysis methods are identified to

E.4 Definitions of DQOs

tolerable levels of potential decision errors that

1

that describe the intended data use(s), the dataneed requirements, and the means to achieveacceptable data quality for the intended use(s).DQOs documented as a result of the TPPprocess should be comprehensive and includeeach of the nine data quality requirements listedin Paragraph 4.2.1.1.

EM 200-1-231 Aug 98

E-2

EPA’s 7-Step DQO Process Technical Project Planning (TPP) Process

Step 1 Phase III Phase IVState the Problem (cont.) (cont.)

Phase I

IdentifyCurrentProject

Phase II

DetermineDataStep 4

NeedsDefine the Study Boundaries

Step 2Identify the Decision

Step 3Identify Inputs to the Decision

Phase III

DevelopData

CollectionOptions

Step 5 Phase IDevelop a Decision Rule (cont.)

Step 6Specify Limits on Decision Errors

Step 7Optimize the Design for Obtaining Data

Phase IVFinalize

DataCollectionProgram

Figure E-1Alignment Between EPA’s 7-Step DQO Process and the TPP Process

EM 200-1-231 Aug 98

Table E-1Crosswalk from 7-Step DQO Process to the TPP Process

E-3

EPA’s 7-Step DQO Process Technical Project Planning (TPP) Processa b

DQO Step Activity Activity TPP Phase(s)c

Step 1 Phase I

State theProblem

1.1 Identify TPP Team Members“Identify members of the planning team.” (p 10) (Paragraph 1.1.1, p 1-2 to 1-5)- “Samplers - Decision Makers- Chemists and Other Scientists and Engineers Customer- Modelers Project Manager (PM)- Technical Project Managers Regulators- Community Representatives Stakeholders- Administrative and Executive Managers - Data Users- QA/QC Experts (e.g., QA Manager) Risk Perspective- Data Users Compliance Perspective- Decision Makers Remedy Perspective- Statistician (or someone knowledgeable and experienced with Responsibility Perspectiveenvironmental statistical design and analysis)” - Data Implementors

Sampling Perspective Analysis Perspective

1.2a [Under the leadership of the PM, the TPP process“Identify the primary decision maker of the planning team ...” involves bringing together all of the decision makers to(p 10) ensure that the data collection program consists of all the

required data, within project constraints, and that the datais available for timely decisions.]

Phase I

1.2b [EM 200-1-2 describes the responsibilities of each team“... and define each member’s role and responsibility during the member for every TPP activity.]DQO process.” (p 10)

All Phases

EM 200-1-231 Aug 98

EPA’s 7-Step DQO Process Technical Project Planning (TPP) Processa b

DQO Step Activity Activity TPP Phase(s)c

E-4

Step 1 Phase I

State theProblem(continued)

1.3 Identify Customer Goals (Paragraph 1.1.2, p 1-5 to 1-6)“Develop a concise description of the problem.” (p 11) Identify and Document Project Objectives

(Paragraph 1.2.2, p 1-10 to 1-12)Identify Regulator and Stakeholder Perspectives(Paragraph 1.2.3, p 1-12)

1.3.1 Customer’s Concept of Site Closeout“Describe the conditions or circumstances that are causing the (Paragraph 1.1.2.1, p 1-5 to 1-6)problem and the reason for conducting (sic) the study.” Evaluate Site Information and Data(p 11 and Table 1-1, p 12) (Paragraph 1.2.1, p 1-8 to 1-10)

Identify and Document Project Objectives(Paragraph 1.2.2, p 1-10 to 1-12)Identify Regulator and Stakeholder Perspectives(Paragraph 1.2.3, p 1-12)

Phase I

1.3.2 Gather Existing Site Information“Describe the problem as it is currently understood by briefly (Paragraph 1.1.3, p 1-6 to 1-7)summarizing existing information.” (p 11) Evaluate Site Information and Data

(Paragraph 1.2.1, p 1-8 to 1-10)

Phase I

1.3.3 Gather Existing Site Information“Conduct literature searches and examine past or ongoing (Paragraph 1.1.3, p 1-6 to 1-7)studies to ensure that the problem is correctly defined and has Evaluate Site Information and Datanot been previously solved.” (p 11) (Paragraph 1.2.1, p 1-8 to 1-10)

“If enough data of an acceptable quality already exist tosatisfy all project objectives to site closeout, then the PMand technical personnel should assist the customer inpetitioning the regulators for site closeout and delisting,as appropriate.” (p 1-13)Identify Executable Stages to Site Closeout(Paragraph 1.2.5, p 1-13 to 1-14)Evaluate Use of Existing Data (Paragraph 2.1.3, p 2-4)

Phase I

Phase II

EM 200-1-231 Aug 98

Table E-1 (continued)Crosswalk from 7-Step DQO Process to the TPP Process

EPA’s 7-Step DQO Process Technical Project Planning (TPP) Processa b

DQO Step Activity Activity TPP Phase(s)c

E-5

Step 1 Phase I

State theProblem(continued)

1.3.4a Define Courses of Action for Achieving Site Closeout“If the problem is complex, consider breaking it into more (Paragraph 1.3.2, p 1-16 to 1-17)manageable pieces. Identify those pieces that could be - operable units/exposure areasaddressed by separate studies.” (p 11) - expedited removal

- phasing (series or parallel) - field screening and field analytical methods - expedited site characterizationEstablish Data User’s Roles(Paragraph 2.1.2, p 2-1 to 2-4)

Phase II

1.3.4b Define Courses of Action for Achieving Site Closeout“Assign priorities to and logical relationships among the pieces (Paragraph 1.3.2, p 1-16 to 1-17)of the problem.” (p 11) Document Current Executable Stage

(Paragraph 1.3.3, p 1-18)

Phase I

1.4 Identify TPP Team Members“Specify the available resources and relevant deadlines for the (Paragraph 1.1.1, p 1-2 to 1-5)study.” (p 11) Document Current Executable Stage

(Paragraph 1.3.3, p 1-18)Finalize Acquisition Strategy (Paragraph 1.4.1, p 1-18)Prepare Phase I Memorandum for Record(Paragraph 1.4.3, p 1-19)

Phase I

1.4a Customer’s Site Budget (Paragraph 1.1.2.3, p 1-6)“Stipulate the anticipated budget ...” (p 11) Prepare Phase I Memorandum for Record

(Paragraph 1.4.3, p 1-19)Prepare Detailed Cost Estimate (Paragraph 4.2.3, p 4-5)

Phase I

Phase IV

EM 200-1-231 Aug 98

Table E-1 (continued)Crosswalk from 7-Step DQO Process to the TPP Process

EPA’s 7-Step DQO Process Technical Project Planning (TPP) Processa b

DQO Step Activity Activity TPP Phase(s)c

E-6

Step 1 Phase I

State theProblem(continued)

1.4b Identify TPP Team Members“... available personnel and contractual vehicles.” (p 11) (Paragraph 1.1.1, p 1-2 to 1-5)

Prepare Phase I Memorandum for Record(Paragraph 1.4.3, p 1-19)Initiate Scope of Work Sections(Paragraph 1.4.2, p 1-1-19)Prepare Final Scope of Work or Work Plan(Paragraph 4.2.2, p 4-5)

Phase IV

1.4c Customer’s Schedule Requirements“Also, enumerate any deadlines for completion of the study and (Paragraph 1.1.2.2, p 1-6)any intermediate deadlines that may need to be met.” (p 11) Identify Executable Stages to Site Closeout

(Paragraph 1.2.5, p 1-13)Document Current Executable Stage(Paragraph 1.3.3, p 1-18)Prepare Phase I Memorandum for Record(Paragraph 1.4.3, p 1-19)

Phase I

Step 2 Phase II

Identify theDecision

Review Phase I Memorandum for Record(Paragraph 2.1.1, p 2-1)

2.1 Identify and Document Project Objectives“Identify the principal study question.” (p 14) (Paragraph 1.2.2, p 1-10 to 1-12)

Document Current Executable Stage(Paragraph 1.3.3, p 1-18)

Phase I

2.2 Define Probable Remedies“Define the alternate actions that could result from resolution of (Paragraph 1.2.4, p 1-12 to 1-13)the principal study question.” (p 15)

Phase I

EM 200-1-231 Aug 98

Table E-1 (continued)Crosswalk from 7-Step DQO Process to the TPP Process

EPA’s 7-Step DQO Process Technical Project Planning (TPP) Processa b

DQO Step Activity Activity TPP Phase(s)c

E-7

Step 2 Phase I

Identify theDecision(continued)

2.3 Document Current Executable Stage“Combine the principal study question and the alternative (Paragraph 1.3.3, p 1-18)actions into a decision statement.” (p 15)

2.4 Define Courses of Action for Achieving Site Closeout“Organize multiple decisions.” (p 15 and Figure 2-1) (Paragraph 1.3.2, p 1-16 to 1-17)

Document Current Executable Stage(Paragraph 1.3.3, p 1-18)Establish Data User’s Roles(Paragraph 2.1.2, p 2-1 to 2-4)

Phase I

Phase II

Step 3 Phase II

IdentifyInputs tothe Decision

3.1 Establish Data User’s Roles“Identify the information that will be required to resolve the (Paragraph 2.1.2, p 2-1 to 2-4)decision statement.” (p 18)

3.2 Evaluate Use of Existing Data (Paragraph 2.1.3, p 2-4)“Determine the sources for each item of information identified Define Data Needs (Paragraph 2.1.4, p 2-4 to 2-9)above.” (p 18)

Phase II

3.2.1 Define Data Needs (Paragraph 2.1.4, p 2-4 to 2-9)“Identify and list the sources for the information needed toresolve the decision statement.” (p 18)

Phase II

3.2.2 Evaluate Use of Existing Data (Paragraph 2.1.3, p 2-4)“Next, qualitatively evaluate whether any existing data areappropriate for the study.” (p 18)

Phase II

3.3 Define Data Needs (Paragraph 2.1.4, p 2-4 to 2-9)“Identify the information that is needed to establish the action Sampling and Analysis Planning Worksheet (Appendix F)level.” (p 18)

Phase II

EM 200-1-231 Aug 98

Table E-1 (continued)Crosswalk from 7-Step DQO Process to the TPP Process

EPA’s 7-Step DQO Process Technical Project Planning (TPP) Processa b

DQO Step Activity Activity TPP Phase(s)c

E-8

Step 3 Phase III

IdentifyInputs tothe Decision(continued)

3.4 Plan Sampling and Analysis Approaches“Confirm that appropriate measurement methods exist to (Paragraph 3.1.2, p 3-2 to 3-7)provide the necessary data.” (p 18)

Step 4 Phase II

Define theStudyBoundaries

4.1 Define Data Needs (Paragraph 2.1.4, p 2-4 to 2-9)“Specify the characteristics that define the population of Document Data Needs (Paragraph 2.2, p 2-9 to 2-10)interest.” (p 20) Data Need Worksheets (Appendix F)

4.2 Define Data Needs (Paragraph 2.1.4, p 2-4 to 2-9)“Define the spatial boundary of the decision statement.” (p 20) Document Data Needs (Paragraph 2.2, p 2-9 to 2-10)

Phase II

4.2.1 Define Data Needs (Paragraph 2.1.4, p 2-4 to 2-9)“Define the geographic area to which the decision statement Document Data Needs (Paragraph 2.2, p 2-9 to 2-10)applies.” (p 20) Data Need Worksheets (Appendix F)

Phase II

4.2.2 Define Data Needs (Paragraph 2.1.4, p 2-4 to 2-9)“When appropriate, divide the population into strata that have Document Data Needs (Paragraph 2.2, p 2-9 to 2-10)relatively homogeneous characteristics.” Plan Sampling and Analysis Approaches(p 21; Figure 4-1, p 22) (Paragraph 3.1.2, p 3-2 to 3-7)

Phase II

Phase III

4.3 Define Data Needs (Paragraph 2.1.4, p 2-4 to 2-9)“Define the temporal boundary of the problem.” (p 21)

Phase II

4.3.1 Define Data Needs (Paragraph 2.1.4, p 2-4 to 2-9)“Determine the time frame to which the decision applies.”(p 21)

Phase II

EM 200-1-231 Aug 98

Table E-1 (continued)Crosswalk from 7-Step DQO Process to the TPP Process

EPA’s 7-Step DQO Process Technical Project Planning (TPP) Processa b

DQO Step Activity Activity TPP Phase(s)c

E-9

Step 4 Phase II

Define theStudyBoundaries(continued) 4.4 Define Data Needs (Paragraph 2.1.4, p 2-4 to 2-9)

4.3.2 Define Data Needs (Paragraph 2.1.4, p 2-4 to 2-9)“Determine when to collect data.” (p 21) Plan Sampling and Analysis Approaches

(Paragraph 3.1.2, p 3-2 to 3-7)Develop Data Collection Options(Paragraph 3.2, p 3-8 to 3-9)

Phase III

“Define the scale of decision making.” (p 21)Phase II

4.5 Recognize Site Constraints and Dependencies“Identify any practical constraints on data collection.” (p 22) (Paragraph 1.3.1, p 1-14 to 1-16)

Refine Plans Within Project Constraints(Paragraph 3.1.2.4, p 3-7)

Phase I

Phase III

Complete Phase II Activities (Paragraph 2.3, p 2-10) Phase II

Step 5 Phase III

Develop aDecisionRule

Review Phase I and Phase II Information(Paragraph 3.1.1, p 3-1 to 3-2)

5.1 Define Data Needs (Paragraph 2.1.4, p 2-4 to 2-9)“Specify the statistical parameter that characterizes thepopulation (the parameter of interest).”(p 24 and Table 5-1, pp 25-26)

Phase II

5.2 Define Data Needs (Paragraph 2.1.4, p 2-4 to 2-9)“Specify the action level for the study.” (p 25) Sampling and Analysis Planning Worksheet (Appendix F)

Phase II

EM 200-1-231 Aug 98

Table E-1 (continued)Crosswalk from 7-Step DQO Process to the TPP Process

EPA’s 7-Step DQO Process Technical Project Planning (TPP) Processa b

DQO Step Activity Activity TPP Phase(s)c

E-10

Step 5 Phase III

Develop aDecisionRule(continued)

5.2.1 Plan Sampling and Analysis Approaches“Confirm that the action level is greater than the detection and (Paragraph 3.1.2, p 3-2 to 3-7)quantitation limits for the potential measurement methods Develop Data Collection Optionsidentified in Step 3.” (p 25) (Paragraph 3.2, p 3-8 to 3-9)

5.3 Define Data Needs (Paragraph 2.1.4, p 2-4 to 2-9)“Develop a decision rule.” (p 25)

Phase II

Step 6 Phase II

SpecifyLimits onDecisionErrors

6.1 Define Data Needs (Paragraph 2.1.4, p 2-4 to 2-9)“Determine the possible range of the parameter of interest.” Plan Sampling and Analysis Approaches(p 30, Figures 6-1 and 6-2) (Paragraph 3.1.2, p 3-2 to 3-7)

Phase III

6.2 Define Data Needs (Paragraph 2.1.4, p 2-4 to 2-9)“Identify the decision errors and choose the null hypothesis.”(pp 30-32)

Phase II

6.3 Define Data Needs (Paragraph 2.1.4, p 2-4 to 2-9)“Specify a range of possible parameter values where theconsequences of decision errors are relatively minor (grayregion).” (pp 33-34)

Phase II

6.4 Define Data Needs (Paragraph 2.1.4, p 2-4 to 2-9)“Assign probability limits to points above and below the grayregion that reflect the tolerable probability for the occurrence ofdecision errors.” (p 34, Figures 6-1 and 6-2, Tables 6-1 and 6-2)

Phase II

EM 200-1-231 Aug 98

Table E-1 (continued)Crosswalk from 7-Step DQO Process to the TPP Process

EPA’s 7-Step DQO Process Technical Project Planning (TPP) Processa b

DQO Step Activity Activity TPP Phase(s)c

E-11

Step 7 Phase IV

Optimizethe DesignforObtainingData

7.1 Verification of DQO Attainment (Appendix G)“Review the DQO outputs and existing environmental data.”(p 38)

Appendix G

7.2 Plan Sampling and Analysis Approaches“Develop general data collection design alternatives.” (p 38) (Paragraph 3.1.2, p 3-2 to 3-7)

Develop Data Collection Options(Paragraph 3.2, p 3-8 to 3-9)

Phase III

7.3 Plan Sampling and Analysis Approaches“Formulate the mathematical expressions needed to solve the (Paragraph 3.1.2, p 3-2 to 3-7)design problem for each data collection design alternative.” Develop Data Collection Options(p 39) (Paragraph 3.2, p 3-8 to 3-9)

Phase III

7.4 Plan Sampling and Analysis Approaches“Select the optimal sample size that satisfies the DQOs for (Paragraph 3.1.2, p 3-2 to 3-7)each data collection design alternative.” (p 39)

Phase III

7.5 Plan Sampling and Analysis Approaches“Select the most resource-effective data collection design that (Paragraph 3.1.2, p 3-2 to 3-7)satisfies all of the DQOs.” (p 39-40 and Figure 7-1) Develop Data Collection Options

(Paragraph 3.2, p 3-8 to 3-9)Document Data Collection Options(Paragraph 3.3, p 3-9 to 3-10)

Phase III

EM 200-1-231 Aug 98

Table E-1 (continued)Crosswalk from 7-Step DQO Process to the TPP Process

EPA’s 7-Step DQO Process Technical Project Planning (TPP) Processa b

DQO Step Activity Activity TPP Phase(s)c

E-12

Step 7 Phase IV

Optimizethe DesignforObtainingData(continued)

Prepare Customer Communications(Paragraph 4.1.1, p 4-1 to 4-2)Encourage Customer Participation(Paragraph 4.1.2, p 4-2 to 4-3)Suggest Regulator Participation (Paragraph 4.1.3, p 4-3)Consider Participation of Others (Paragraph 4.1.4, p 4-3)

7.6 Prepare Data Quality Objective Statements“Document the operational details and theoretical assumptions (Paragraph 4.2.1, p 4-4 to 4-5)of the selected design in the sampling and analysis plan.” Prepare Final Scope of Work or Work Plan(p 40) (Paragraph 4.2.2, p 4-5)

Prepare Fact Sheet(s) (Paragraph 4.2.4, p 4-5 to 4-6)

Phase IV

Project Objectives WorksheetSite Information WorksheetData Need WorksheetsSampling and Analysis Planning WorksheetSummary Table of Data Collection OptionsDQO Worksheet

Appendix F

DQO Attainment Worksheet Appendix G

EPA QA/G-4a 1

EM 200-1-2 (31 Aug 98)b

The activity number convention has been applied to EPA’s 7-Step DQO Process for the convenience of this crosswalk table.c

EM 200-1-231 Aug 98

F-1

TPP teams should consider developingelectronic files which integrate projectobjectives; data needs; sampling andanalysis planning; and data collectionoptions. Integrated electronic files couldthen be easily transmitted to various TPPteam members and printed as oversizedtables (e.g., 11 inches by 17 inches andlarger) for specific projects or sites.

Appendix FWorksheets for Documentation

F.1 INTRODUCTION. F.2 WORKSHEETS PROVIDED.This appendix provides several worksheets and The following worksheets are provided for usetables for documenting Technical Project by teams using the TPP process:Planning (TPP) information, decisions, andplans. These tools are intended to help a teamdesign and document a data collection programthroughout their TPP efforts.

Although these worksheets and tables mayinitially be overwhelming, users will find thateach tool provides a very practical method ofimplementing the TPP process and documentingthe critical information required for a successfulprojects. At a minimum, use of these tools willenhance team communication and contribute tomaintaining institutional site knowledge.

These tools are just one method to achieveimplementation of the concepts discussed in thismanual. Technical personnel may choose todevelop or refine some of the tools presentedherein to fit their specific needs.

Use of standardized worksheets and tables willallow quick and easy quality assurance/qualitycontrol review of the work efforts and datacollection program plans.

Project Objectives p F-3 to F-4Worksheet

Site Information p F-5 to F-6Worksheet

Phase I MFR Worksheet p F-7 to F-11

Data Need Worksheet- p F-13 to F-15Risk Perspective

Data Need Worksheet- p F-17 to F-19Compliance Perspective

Data Need Worksheet- p F-21 to F-23Remedy Perspective

Data Need Worksheet- p F-25 to F-27Responsibility Perspective

Sampling and Analysis p F-29 to F-31Planning Worksheet

Summary Table of Data p F-33 to F-35Collection Options

Data Quality Objective p F-37Worksheet

EM 200-1-231 Aug 98

F-2

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EM 200-1-231 Aug 98

F-3

PROJECT OBJECTIVES WORKSHEETPAGE ____ of _____

SITE: _________________________

PROJECT: ________________________

Project Objectivea

Data User(s)Project Objective

ClassificationdNumber Description Source

Executable Stageb

c

Current Future

____ Risk ____ Basic____ Compliance ____ Optimum____ Remedy ____ Excessive____ Responsibility

____ Risk ____ Basic____ Compliance ____ Optimum____ Remedy ____ Excessive____ Responsibility

____ Risk ____ Basic____ Compliance ____ Optimum____ Remedy ____ Excessive____ Responsibility

Refer to EM 200-1-2, Paragraph 1.2.2.a

Refer to EM 200-1-2, Paragraph 1.2.5.b

For example, CERCLA ____, State Regulation ______, FFA Section ______, RCRA Permit, Meeting with Customer or Regulator.c

Classification of project objectives can only occur after the current project has been identified. Refer to EM 200-1-2, Paragraph 1.3.3.d

EM 200-1-231 Aug 98

F-4

PROJECT OBJECTIVES WORKSHEET (examples)PAGE ____ of _____

SITE: _________________________

PROJECT: ________________________

Project Objectivea

Data User(s)Executable StageProject Objective

Classificationd

Number Description Source

b

c

Current Future

1 X

Eliminate from further consideration those releases that pose no significant CERCLA 40 XX Risk XX Basicthreat to public health or the environment. CFR 300.420 ____ Compliance ____ Optimum

(c)(i) ____ Remedy ____ Excessive____ Responsibility

2 X

Evaluate and quantify the likely contribution of ABCS Manufacturing’s Legal Counsel ____ Risk XX Basiccontribution to the surface water and groundwater conditions that were Action ____ Compliance ____ Optimumidentified during previous investigations. #218-4401 ____ Remedy ____ Excessive

XX Responsibility

3 X

Determine if excavated soil will require disposal as a hazardous waste. RCRA ____ Risk ____ Basic40 CFR 261.24 XX Compliance XX Optimum

XX Remedy ____ Excessive____ Responsibility

4 X

Classify groundwater in accordance with rules 3745-300-10 and 3745- State Admin. ____ Risk ____ Basic300-07 of the State Administrative Code (Title 3745, Chapter 300). Code XX Compliance XX Optimum

____ Remedy ____ Excessive____ Responsibility

5 X

Obtain cost and performance data related to life-cycle assessment of EPA’s ____ Risk ____ Basictreatment wall remedial action at the site. Innovative ____ Compliance XX Optimum

Technologies XX Remedy ____ ExcessiveAdvocate ____ Responsibility

6

Investigate and remediate potentially contaminated soil below existing Requested by ____ Risk ____ Basicroadway prior to widening of roadway. State Dept. of ____ Compliance ____ Optimum

Health ____ Remedy XX ExcessiveRegulator ____ Responsibility

Several more specific project objectives are typically needed for a project than the few examples provided above.

EM 200-1-231 Aug 98

F-5

SITE INFORMATION WORKSHEETPAGE ____ of _____

SITE: _________________________

PROJECT: ________________________

Site Information Needed Obtaining Sitea

Potential SuggestedSource(s) User of Site Means to

of Site Information Obtain SiteInformation Information

b

Deadline for

Information

1

2

3

4

5

6

Refer to EM 200-1-2, Paragraphs 1.1.3 and 2.2.a

Indicate a specific TPP team member (e.g., Risk Data User, Customer, Regulator, Sampling Data Implementor).b

EM 200-1-231 Aug 98

F-6

SITE INFORMATION WORKSHEET (examples)PAGE ____ of _____

SITE: _________________________PROJECT: ________________________

Site Information Needed Obtaining Site

Potential SuggestedSource(s) User of Site Means to

of Site Information Obtain SiteInformation Information

Deadline for

Information

1 Determine if any threatened or endangered species State Risk Data User Written Needare known to be present at the site. Department of correspondence concurrent with

Health evaluatinginvestigationdata.

2 Obtain PA/SI report and all related analytical Customer all Data Users Site visit Before Phase IIresults. efforts begin.

3 Aerial photographs between 1952 and the present. Aerial Surveyor Remedy and Telephone call Needed duringResponsibility Phase II efforts.Data Users

4 Agricultural report for county. Dept. of Responsibility Telephone call Evaluation ofAgriculture Data User potential PRPs

during Phase II.

5 Local geologic and hydrogeologic information and State Board of Hydrogeologist Visit State Duringboring logs from within 2 miles of the site. Geology supporting offices feasibility study

Remedy Data evaluations.User

EM 200-1-231 Aug 98

F-7

Phase I MFR Worksheet

Author(s) Reviewer Latest Revision Date Review Date

Location: Site: Project:

(Attach Phase I MFR to PMP)

TPP TEAM EM 200-1-2, Paragraph 1.1.1

Decision MakersData User Data Implementor

Perspectives Perspectives

Customer: Risk: Sampling:

Project Manager:

Regulator(s): Analysis:

Stakeholders: Remedy:

Compliance:

Responsibility:

CUSTOMER’S GOALS EM 200-1-2, Paragraph 1.1.2

Future Land Use(s) @ SiteRegulatory Compliance Interim Site Closeout Goal

Status and Issues (if applicable)

EM 200-1-231 Aug 98

F-8

CUSTOMER’S GOALS (continued) EM 200-1-2, Paragraph 1.1.2

Site Closeout Statement

Customer’s Schedule Requirements

Customer’s Site Budget

EM 200-1-231 Aug 98

F-9

IDENTIFY SITE APPROACH

EXISTING SITE INFORMATION AND DATA EM 200-1-2, Paragraphs 1.1.3 and 1.2.1

Attachment(s) to Site Information PreliminaryPhase I MFR Repository(ies) Conceptual Site Model

POTENTIAL POINTS OF COMPLIANCE EM 200-1-2, Paragraph 1.2.1.3

MEDIA OF POTENTIAL CONCERN EM 200-1-2, Paragraph 1.2.1.4

PROJECT OBJECTIVES EM 200-1-2, Paragraph 1.2.2

(The TPP team should begin to complete several Project Objective Worksheets at this time.)

EM 200-1-231 Aug 98

F-10

IDENTIFY SITE APPROACH (continued)

REGULATOR AND STAKEHOLDER PERSPECTIVES EM 200-1-2, Paragraph 1.2.3

Regulators Community Interests Others

PROBABLE REMEDIES EM 200-1-2, Paragraph 1.2.4

EXECUTABLE STAGES TO SITE CLOSEOUT EM 200-1-2, Paragraph 1.2.5

EM 200-1-231 Aug 98

F-11

IDENTIFY CURRENT PROJECT

SITE CONSTRAINTS AND DEPENDENCIES EM 200-1-2, Paragraph 1.3.1

- Administrative Constraints and Dependencies

- Technical Constraints and Dependencies

- Legal and Regulatory Milestones and Requirements

CURRENT EXECUTABLE STAGE EM 200-1-2, Paragraph 1.3.3

(Also list project objective numbers and attach Project Objectives Worksheet with descriptions.)

Basic Optimum Excessive(current project) (future projects) (objectives that do not

lead to site closeout)

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F-12

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EM 200-1-231 Aug 98

F-13

DATA NEED WORKSHEET- RISK PERSPECTIVEPAGE ____ of _____

SITE: _________________________ DATA USER NAME(s):__________________

PROJECT: ________________________

Data Need Data Use(s) Number of Samples Risk Action Level(s)a

ProjectObjective(s) b

& Data NeedGroup

c d e

Exposure Area(s) /Sample Location(s)

and Depthf

Contaminantof Concern, or Current or Receptor CL P MDRD HumanCharacteristic Future Use Group(s) (%) (%) (%) Health

of Interest

Media Exposure EcologicalReceptor’s

Route(s)

EM 200-1-231 Aug 98

F-14

DATA NEED WORKSHEET- RISK PERSPECTIVE (examples)

Data Need Data Use(s) Number of Samples Risk Action Level(s)a

ProjectObjective(s)b

& Data NeedGroup

c d e

Exposure Area(s) /Sample Location(s)

and Depthf

Contaminantof Concern, or Current or Receptor CL P MDRD HumanCharacteristic Future Use Group(s) (%) (%) (%) Health

of Interest

Media Exposure EcologicalReceptor’s

Route(s)

Vinyl Industrial Ingestion,Chloride Workers Dermal, &

GW Current Use 2 N/A N/A downgradient wells1 The 2 worst case

Basic found @ PA/SI

Incidental

Inhalation

Vinyl Ingestion, 0.019 ug/LChloride Dermal, & (RBC)

GW Future Use Resident 2 N/A downgradient wells2 The 2 worst case

Basic found @ PA/SI

Incidental

Inhalation

Lead and Industrial Ingestion & outlined onCadmium Workers Dermal attached figure and

Soil Current Use P = 90% 1,000 N/A1 CL = 80% 1,000 and

Basic MDRD = 20% mg/kg

within area

@ 0" to 24"

Lead and Ingestion & 400 and 39 0.1 and 2.5 outlined onCadmium Dermal mg/kg mg/kg attached figure and

Soil Future Use Resident P = 95%2 CL = 90%

Basic MDRD = 20%

within area

@ 0" to 24"

Total Organic (fate &Carbon transport)

Soil Future Use GW Model 2 +/- 0.1% of the 2 new wells2 w/i screen interval

Basic on attached figure

Hydraulic aquifer (fate &Conductivity viability and transport)

GW Future Use 2 using data logger shown on the2 (rising head slug test At the 2 new wells

Basic and transducers) attached figure

GW Model,

classification

EM 200-1-231 Aug 98

F-15

DATA NEED WORKSHEET- RISK PERSPECTIVE(instructions)

Data Needa

List each specific environmental data need that should be referenced to consider best use ofis required to satisfy a project objective(s) classical statistics and geostatistics ifidentified during Phase I. (Site information probabilistic methods are appropriate forworksheet should be used for site information establishing the number of samples required.needs.) Limit requests for “full suite” to select Desired Confidence Limit (CL), Power (P),locations or areas, and only when necessary to and Minimum Detectable Relative Differencesatisfy a project objective. A unique data need (MDRD) should be provided whennumber (e.g., risk-1) should be assigned to probabilistic decisions are involved. (Refer toeach data need. Paragraph 2.1.4 regarding probabilistic/

Project Objective(s) & Data Need Groupb

Correlate each data need with the project appropriate number of samples.)objective(s) that the data will be used to helpsatisfy. Data needs listed without acorresponding project objective number(s) and Specify risk action levels for each data need.data need group (i.e., basic, optimum, (Entries in this column help ensure thatexcessive) should not be included in the data laboratory quantitation limits are appropriatecollection program. (Project objectives are so the resulting data can represent detectablediscussed in Paragraph 1.2.2, documented results below these concentration(s) of interestusing the Project Objective Worksheet, and for decision making.)sequentially numbered for record keeping.)

Data Use(s) Depthc

Communicate the intended use(s) of the data. Specify the area or physical location(s) that(Multiple worksheet lines should be used to would need to be sampled to provide the datarepresent each exposure scenario when sample required for the intended data use(s). (Specificnumbers; risk action levels; sample areas or sampling locations should only be designatedlocations; or the applicable project objectives when they are the known critical locations fordiffer.) the intended use.) Site maps should be

Number of Samplesd

Define the number of samples based on the well as sampling depth(s) where applicable.accepted practices of the intended data use(s). (This information will be used by dataWorksheet entry should represent minimum implementors to ensure the required data isnumber of samples required to provide obtained, and to identify opportunities to co-acceptable data quality for the intended data locate sampling efforts and develop datause(s). Note that number of samples may be a collection options.)fixed number or a dynamic estimate based onintended data use and whether ESC methods

are being employed. Other guidance resources

nonprobabilistic decisions and efforts fordeveloping the rationale for designating the

Risk Action Level(s)e

Exposure Area(s)/Sample Location(s) andf

attached as appropriate to help delineate theappropriate sampling area or location(s), as

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F-16

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F-17

DATA NEED WORKSHEET- COMPLIANCE PERSPECTIVEPAGE ____ of _____

SITE: _________________________ DATA USER NAME(s):_________________ PROJECT: ________________________

Data Need Data Usea

ProjectObjective(s) Number ofb

& Data Need SamplesGroup

c

d

Compliance Point(s) ofReference Compliance/Sample

Concentration Locations(s) and Depthe f

Contaminantof Concern, orCharacteristic

of Interest

Media Statute, Specific UseRegulatory Program or

and Citation

EM 200-1-231 Aug 98

F-18

DATA NEED WORKSHEET- COMPLIANCE PERSPECTIVE(examples)

Data Need Data Usea

ProjectObjective(s) Number ofb

& Data Need SamplesGroup

c

d

Compliance Point(s) ofReference Compliance/Sample

Concentration Locations(s) and Depthe f

Contaminantof Concern, orCharacteristic

of Interest

Media Program or Statute, Specific UseRegulatory Regulatory

and Citation

Chromium, Cr Soil4 RCRA 5.0 mg/L

Basic 40 CFR 261.24 (TCLP Cr)Determine if IDW ishazardous waste.

1 compositesample Representative sample of

per rolloff waste stream (soil)container

Total GWChromium, Cr Basic 40 CFR 261.24 (Total Cr)

4 RCRA 5.0 mg/L1 sample Representative sample ofper drum waste stream (purge water)

Chromium,Cr III (time frame

Water 180 ug/L effluent at point source6 CWA Groundwater treatment plant

Optimum 40 CFR 131 discharge locationDetermine if treatmentplant effluent requirespre-treatment prior to

dischargeto surface water.

1 sample

is TBD)

Chromium,Cr VI (time frame

Water 10 ug/L effluent at point source6 CWA Groundwater treatment plant

Optimum 40 CFR 131 discharge location

1 sample

is TBD)

Chromium, Cr GW 1 per well 0.1 mg/L tap, but sampling at7 SDWA Required at the point of use

Optimum 40 CFR 141 monitoring wells is adequate.

Do GW concentrationsexceed MCL?

EM 200-1-231 Aug 98

F-19

DATA NEED WORKSHEET- COMPLIANCE PERSPECTIVE(instructions)

Data Needa

List each specific environmental data need that resources should be referenced to consider theis required to satisfy a project objective(s) best use of classical statistics and geostatisticsidentified during Phase I. (Site information if probabilistic methods are appropriate forworksheet should be used for site information establishing the number of samples required.needs.) Limit requests for “full suite” to select (Refer to Paragraph 2.1.4 for discussionslocations or areas, and only when necessary to regarding probabilistic/nonprobabilisticsatisfy a project objective. A unique data need decisions and efforts for developing thenumber (e.g., compliance-1) should be rationale for designating the appropriateassigned to each data need. number of samples.)

Project Objective(s) & Data Need Group Compliance Reference Concentrationb

Correlate each data need with the project Specify the reference concentration of interestobjective(s) that the data will be used to help for each data need. (Entries in this columnsatisfy. Data needs listed without a help ensure that laboratory quantitation limitscorresponding project objective number(s) and are appropriate so the resulting data candata need group (i.e., basic, optimum, represent detectable results below theseexcessive) should not be included in the data concentration(s) of interest for decisioncollection program. (Project objectives are making.)discussed in Paragraph 1.2.2, documentedusing the Project Objective Worksheet, andsequentially numbered for record keeping.)

Data Use(s)c

Communicate the intended use(s) of the data. provide the data required for the intended data(Multiple worksheet lines should be used to use(s). (Specific sampling locations shouldrepresent each applicable regulatory statute only be designated when they are the knownwhen sample numbers; reference critical locations for the intended use.) Siteconcentration; sample areas or locations; or maps should be attached as appropriate to helpthe applicable project objectives differ.) delineate the appropriate sampling area or

Number of Samplesd

Define the number of samples based on the data implementors to ensure the required dataaccepted practices of the intended data use(s). is obtained, and to identify opportunities to co-Worksheet entry should represent minimum locate sampling efforts and develop datanumber of samples required to provide collection options.)acceptable data quality for the intended datause(s). Note that the number of samples maybe a fixed number or a dynamic estimate basedon intended data use and whether ESC

methods are being employed. Other guidance

e

Point(s) of Compliance/Samplef

Location(s) and DepthSpecify the point(s) of compliance or physicallocation(s) that would need to be sampled to

location(s), as well as sampling depth(s) whereapplicable. (This information will be used by

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F-20

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EM 200-1-231 Aug 98

F-21

DATA NEED WORKSHEET- REMEDY PERSPECTIVEPAGE ____ of _____

SITE: _________________________ DATA USER NAME(s):_________________

PROJECT: ________________________

Data Need Data Usea

Project Concentration ofObjective(s) Number of Interest orb

& Data Need Samples Sensitivity ofGroup Measurement(s)

c

d

e

Remediation Area(s) /Sample Locations(s) and

Depthf

Contaminantof Concern, or Remedy Method(s) Criteria to beCharacteristic of Interest Considered

of Interest

Media

EM 200-1-231 Aug 98

F-22

DATA NEED WORKSHEET- REMEDY PERSPECTIVE(examples)

Data Need Data Usea

Project Concentration ofObjective(s) Number of Interest orb

& Data Need Samples Sensitivity ofGroup Measurement(s)

c

d

e

Remediation Area(s) /Sample Locations(s) and

Depthf

Contaminantof Concern, or Remedy Method(s) Criteria to beCharacteristic of Interest Considered

of Interest

Media

Vinyl At stack emissionsChloride after air stripper.

Air air stripping effectiveness control operating 2.0 gm/hr7 3 over 3 day

Optimum period

Depth to slurry wall and treatmentBedrock wall as shown on attached

Soil & conceptual cost should be within8 & 9 implementability measurements

Optimum estimate +/- 1'

slurry wall1 locationevery 100'

Along planned alignments of

figuretreatment wall1 locationevery 25'

hydraulicconductivity, 10 ASTM,

grain size GW treatment wall 5 ASTM,distribution, Optimum +/- 0.1%and porosity

effectiveness, Preferred locationsimplementability distributed along middle of& conceptual cost planned alignment of

estimate treatment wall

Lead and estimate ofCadmium transportation and

Soil offsite disposal yards of TCLP soil pile (i.e., BV2, BV4,11 per 100 cubic from within each stockpiled

Optimum stockpiled BV7-9, and BV12) on

Removal action

disposal costs

composite 1 Random, composite samples

soils the attached figure.

pH, totaldissolved 12 & 13 effectiveness, pH w/I +/- .5,solids, and SW implementability, cost, 5 TDS and TOC

total organic Optimum and O&M w/i +/- .5 mg/lcarbon

onsite water treatment Surface water samples half-by electrochemical way down water column; 2

precipitation in the center of basin 15, or ion exchange and 3 along the edges.

EM 200-1-231 Aug 98

F-23

DATA NEED WORKSHEET- REMEDY PERSPECTIVE(instructions)

Data Needa

List each specific environmental data need that should be referenced to consider best use ofis required to satisfy a project objective(s) classical statistics and geostatistics ifidentified during Phase I. (Site information probabilistic methods are appropriate forworksheet should be used for site information establishing the number of samples required. needs.) Limit requests for “full suite” to select (Refer to Paragraph 2.1.4 regardinglocations or areas, and only when necessary to probabilistic/nonprobabilistic decisions andsatisfy a project objective. A unique data need efforts for developing the rationale fornumber (e.g., rem-1) should be assigned to designating appropriate number of samples.)each data need.

Project Objective(s) & Data Need Group Measurement(s)b

Correlate each data need with the project Specify concentration of interest, or requiredobjective(s) that the data will be used to help sensitivity of measurement, for each data need.satisfy. Data needs listed without a Measurement sensitivity could be noted as +corresponding project objective number(s) and 50 feet for a preliminary estimate of the arealdata need group (i.e., basic, optimum, extent of a surface cap, or + 5 mg/L ofexcessive) should not be included in the data benzene in groundwater for an evaluation ofcollection program. (Project objectives are potential remedy methods. (These entries helpdiscussed in Paragraph 1.2.2, documented ensure that appropriate sampling and analysisusing the Project Objective Worksheet, and methods are used to produce data of adequatesequentially numbered for record keeping.) quality for use.)

Data Use(s) Remediation Area(s)/Sample Location(s)c

Communicate the intended use(s) of the data.(Multiple worksheet lines should be used to Specify area or physical location(s) that needrepresent each remedy being evaluated, to be sampled to provide data required for thedesigned, or operated when sample numbers; intended data use(s). (Specific samplingreference concentration; sample areas or locations should only be designated when theylocations; or the applicable project objectives are critical locations for the intended use.)differ.) Site maps should be attached as appropriate to

Number of Samplesd

Define the number of samples based on the applicable. (This information will be used byaccepted practices of the intended data use(s). data implementors to ensure the required dataWorksheet entry should represent minimum is obtained, and to identify opportunities to co-number of samples required to provide locate sampling efforts and develop dataacceptable data quality for the intended data collection options.)use(s). Note that number of samples may be afixed number or a dynamic estimate based onintended data use and whether ESC methods

are being employed. Other guidance resources

Concentration of Interest or Sensitivity ofe

f

and Depth

help delineate the appropriate sampling area orlocation(s), as well as sampling depth(s) where

EM 200-1-231 Aug 98

F-24

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EM 200-1-231 Aug 98

F-25

DATA NEED WORKSHEET- RESPONSIBILITY PERSPECTIVEPAGE ____ of _____

SITE: _________________________ DATA USER NAME(s):_________________

PROJECT: ________________________

Data Need Data Usea

Project Concentration ofObjective(s) Number of Interest orb

& Data Need Samples Sensitivity ofGroup Measurement(s)

c

d

e

Responsibility Area(s) /Sample Locations(s) and

Depthf

Contaminantof Concern, or Related Historical Phase of ResponsibilityCharacteristic Information/Criteria Determination

of Interest

Media

EM 200-1-231 Aug 98

F-26

DATA NEED WORKSHEET- RESPONSIBILITY PERSPECTIVE(examples)

Data Need Data Usea

Project Concentration ofObjective(s) Number of Interest orb

& Data Need Samples Sensitivity ofGroup Measurement(s)

c

d

e

Responsibility Area(s) /Sample Locations(s) and

Depthf

Contaminantof Concern, or Related Historical Phase of ResponsibilityCharacteristic Information/Criteria Determination

of Interest

Media

All metals SW discharge to stream that 621 Upgradient industries

Basic traverses site

Investigating prospect immediately downgradient ofof other PRPs at site source area and 2 where

2 where stream enters site, 2

stream discharges from site.

All metals GW contribute to GW 3 preferred sampling areas21 Upgradient sites may Refer to attached figure for

Basic conditions entering site upgradient of the site.

Investigating prospectof other PRPs at site

TCE GW contribute to GW 3 5.0 ug/L preferred sampling areas21 Upgradient sites may Refer to attached figure for

Basic conditions entering site upgradient of the site.

Investigating prospectof other PRPs at site

BTEX GW stations’ contribution Cost allocation analysis 4 GB5s, and GB6s22 Adjacent service Existing wells GB1s, GB4s,

Optimum to site should be sampled.

B = 1.51 ug/LT = 1,600 ug/LE = 800 ug/LX = 16,000 ug/L

EM 200-1-231 Aug 98

F-27

DATA NEED WORKSHEET- RESPONSIBILITY PERSPECTIVE(instructions)

Data Needa

List each specific environmental data need that methods are being employed. Other guidanceis required to satisfy a project objective(s) resources should be referenced to consider theidentified during Phase I. (Site information best use of classical statistics and geostatisticsworksheet should be used for site information if probabilistic methods are appropriate forneeds.) Limit requests for “full suite” to select establishing the number of samples required.locations or areas, and only when necessary to (Refer to Paragraph 2.1.4 for discussionssatisfy a project objective. A unique data need regarding probabilistic/nonprobabilisticnumber (e.g., res-1) should be assigned to decisions and efforts for developing theeach data need. rationale for designating the appropriate

Project Objective(s) & Data Need Groupb

Correlate each data need with the projectobjective(s) that the data will be used to helpsatisfy. Data needs listed without a Specify the concentration of interest, or thecorresponding project objective number(s) and required sensitivity of the measurement, fordata need group (i.e., basic, optimum, each data need. (Entries in this column helpexcessive) should not be included in the data ensure that the appropriate methods are usecollection program. (Project objectives are and the resulting data will be of adequatediscussed in Paragraph 1.2.2, documented quality for the intended data use.)using the Project Objective Worksheet, andsequentially numbered for record keeping.)

Data Use(s)c

Communicate the intended use(s) of the data. would need to be sampled to provide the data(Multiple worksheet lines should be used to required for the intended data use(s). (Specificrepresent each responsibility consideration sampling locations should only be designatedbeing evaluated when sample numbers; when they are the known critical locations forreference concentration; sample areas or the intended use.) Site maps should belocations; or the applicable project objectives attached as appropriate to help delineate thediffer.) appropriate sampling area or location(s), as

Number of Samplesd

Define the number of samples based on the implementors to ensure the required data isaccepted practices of the intended data use(s). obtained, and to identify opportunities to co-Worksheet entry should represent minimum locate sampling efforts and develop datanumber of samples required to provide collection options.)acceptable data quality for the intended datause(s). Note that the number of samples maybe a fixed number or a dynamic estimate based

on intended data use and whether ESC

number of samples.)

Concentration of Interest or Sensitivity ofe

Measurement(s)

Responsibility Area(s)/Sample Location(s)f

and DepthSpecify the area or physical location(s) that

well as sampling depth(s) where applicable.(This information will be used by data

EM 200-1-231 Aug 98

F-28

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EM 200-1-231 Aug 98

F-29

SAMPLING AND ANALYSIS PLANNING WORKSHEETPAGE ____ of ____

SITE: ________________________ DATA IMPLEMENTORS:Sampling: _____________________

PROJECT: ________________________ Analysis: _____________________

Project Objective(s)a

Data Need Designation(s)a

Mediuma

Contaminant of Concerna

Sampling MethodInformationb

Area or Location of Interest

Depth(s)

Concentration Riskof Interestc

Compliance

Remedy

Responsibility

Analysis Analyte(s)Informationd

Preparation Method

Analysis Method

Method Detection Limit (MDL)

Quantitation Limit(Low Standard)

Reporting Limit

Number of MatrixSamplese

QC Duplicates

QA Duplicates

Field Blanks

Trip Blanks

MS/MSD

Other

EM 200-1-231 Aug 98

F-30

SAMPLING AND ANALYSIS PLANNING WORKSHEET (examples)PAGE __1__ of __1__

SITE: ________________________ DATA IMPLEMENTORS:Sampling: _____________________

PROJECT: ________________________ Analysis: _____________________

Project Objective(s) 3 5 6a

Data Need Designation(s) RI-3, C-2,RM-2 RM-4 RI-6, C-3a

Medium GW Soil GWa

Contaminant of Concern TCE -- Leada

Sampling Method Low Flow split spoon w/ Low FlowInformation Shelby attachmentb

Area or Location of Interest See Figure 1 See Figure 2 See Figure 1

Depth(s) 1st aquifer 18' - 20' and perched aquifer26'-28' bls

Concentration Risk 10 ppb -- 15 ppbof Interestc

Compliance 20 ppb -- 15 ppb

Remedy 25 ppb +/- 5% --

Responsibility -- -- --

Analysis Analyte(s) VOCs Moisture Content LeadInformationd

Preparation Method SW-846 3520C -- SW-846 3020A

Analysis Method SW-846 8260B ASTM D2216-80 SW-846 7421

Method Detection Limit (MDL) 0.05 ug/L -- 1.0 ug/L

Quantitation Limit 5.0 ug/L -- --(Low Standard)

Reporting Limit 5.0 ug/L -- 5.0 ug/L

Number of Matrix 4 24 5Samplese

QC Duplicates 1 2 1

QA Duplicates 1 2 1

Field Blanks 0 1 0

Trip Blanks 1 1 0

MS/MSD 1 2 1

Other none none none

EM 200-1-231 Aug 98

F-31

TPP teams should consider developingintegrated electronic worksheets oroversized tables (e.g., 11 inches by 17inches and larger) for specific projectsor sites.

SAMPLING AND ANALYSIS PLANNING WORKSHEET(instructions)

Worksheet entries for project objective(s),a

data need designation(s), medium, andcontaminant of interest should correlatedirectly to data need worksheets preparedduring Phase II of the TPP efforts.

Sampling Informationb

Data needs of all data users should first besorted and combined as much as possible whilestill fulfilling all unique data needrequirements. Figures or maps will generallyneed to be attached to designate necessarysampling areas or locations.

Concentration of Interestc

List the concentration of interest for each datauser as a means to identify the mostappropriate MDL(s). Data implementors are Number of Samplescautioned to only apply the most stringent dataquality requirements to those locationsdesignated by the data users based on theintended data use.

Analysis Informationd

Analyte: A discrete chemical component of asample to be identified or measured throughanalysis.

Prep Method: Method used to extract ordigest analyte of interest from sample prior toanalysis.

Analysis Method: Method used to determineconcentration of analyte of interest in asample.

Method Detection Limit: The minimumconcentration of an analyte that can bemeasured within a given matrix and reportedwith a 99 percent confidence that the analyte

concentration is greater than zero. MDLsshall be estimated for each target analyte usingthe procedures presented in 40 CFR, Part 136,Appendix B, or equivalent statistical approach.

Quantitation Limit: The minimumconcentration of an analyte in a specific matrixthat can be identified and quantified withinspecified limits of precision and accuracy. Thequantitation limit should be defined as the lowcalibration standard from the initial calibrationcurve.

Reporting Limit: Project specific thresholdlimit below which a numerical value for data isreported as less than or non-detect.

e

The number of matrix samples should be basedon those required by the data users and notjust a summation of their needs. Dataimplementors should refer to EM 200-1-3 forguidance regarding the appropriate number ofQA/QC duplicate samples, blanks, andMS/MSD samples. The need to collectadditional samples classified as “other” shouldbe noted on the table. If the number of matrixsamples is a dynamic estimate based onintended data use, then the correspondingdecision rationale should be attached asdeveloped by the data user employing ESCmethods at the site.

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EM 200-1-231 Aug 98

F-33

Summary Table of Data Collection Optionsa

SITE PROJECT

DATA IMPLEMENTORS Sampling Analysis

DATE

DataCollection

Option Commentsb

Number of Samplesc Order-of-Magnitude

Cost(dollars)

dAir Sediment SoilSurface Ground OtherWater Water

Excessive

Optimum

Basic

EM 200-1-231 Aug 98

F-34

Summary Table of Data Collection Optionsa

(example)

DataCollection Comments

Optionb

Number of Samplesc Order-of-Magnitude

Cost(dollars)

d

Air Sediment SoilSurface Ground OtherWater Water

Excessive

4(State

Regulatorexpects 9

new wells)

12 (soil gas

studydesired byCustomer)

$111,000and

$230,000

Use of existing groundwater wells and the additional 5wells included in the Basic option should be sufficient forlong-term monitoring of closed site (project objective 8).

Soil gas study around perimeter of landfill is not aregulated requirement for closed site.

Optimum 15 and

Topographicsurvey ofcap whilesurveyingnew wells

$15,000 (Savings of nearly $65,000 and 45 days.)

$4,500 Baseline topographic survey will be required within 2

Collection of 15 soil samples from new well boreholes willbe used for establishing deep soil background conditionsfor OU4 at the facility.

years of site closure. This can be done during the currentproject, saving $3,500, and ensure compliance withclosure monitoring requirements.

Basic 14 28 17 5 $790,000 lowest priority Project Objective associated with the

Option meets schedule and cost constraints of project. However, ...

1. The data needed to satisfy Project Objective 9, the

current project, will not be met.

2. Some field screening results are proposed for use in theBaseline Risk Assessment.

EM 200-1-231 Aug 98

F-35

SUMMARY TABLE OF DATA COLLECTION OPTIONS(instructions)

Development of all three types of dataa

collection options may not be possible orappropriate on some sites. For example, if nodata needs were requested, imposed, ormandated above the data need or data qualityrequirements of the data users are involved,then the “excessive” data collection option isnot necessary. Although development of anoptimum data collection option should alwaysbe pursued, recommendation of an optimumdata collection option may be deemedinappropriate if the data needed to satisfy thecurrent project objectives already exceedsproject cost and schedule constraints.

Data Collection Optionb

Refer to Paragraphs 3.2 and 3.3 fordiscussions regarding the development anddocumentation of data collection options,respectively.

Number of Samplesc

Indicate the total number of samples for eachmedium, including QA/QC samples, and attachSampling and Analysis Planning Worksheetsfor each data collection option summarizedabove.

Commentsd

Provide brief descriptions of the imposedrequirements grouped in the excessive datacollection option; the cost and schedulebenefits associated with the optimum datacollection option; and the limitations, if any,associated with the basic data collectionoption.

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F-37

DATA QUALITY OBJECTIVE WORKSHEETPAGE ____ of _____

SITE: _________________________

PROJECT: ________________________

DQO STATEMENT NUMBER: _________________

DQOElement DQO Element Description Site-Specific DQO StatementNumbera

a

Intended Data Use(s):

1 Project Objective(s) Satisfied

Data Need Requirements:

2 Data User Perspective(s)

3 Contaminant orCharacteristic of Interest

4 Media of Interest

5 Required Sampling Locations or Areasand Depths

6 Number of Samples Required

7 Reference Concentration of Interest orOther Performance Criteria

Appropriate Sampling and Analysis Methods:

8 Sampling Method

9 Analytical Method

Refer to EM 200-1-2, Paragraph 4.2.1a

EM 200-1-231 Aug 98

G-1

Appendix GVerification of DQO Attainment

G.1 VERIFYING DQO ATTAINMENT.Verifying the attainment of the data qualityobjective (DQO) statements should be done asfollows:C Verification should generally be done by the

data user perspective(s) that will be usingthe data;

C Verification of DQO attainment must becompleted before the data are used by thedata users;

C All data quality requirements of a DQOstatement should be verified; and

C Verification of DQO attainment is typicallyrequired to ensure contract compliance.

The DQO Attainment Verification worksheetprovided in this appendix would be useful forverifying DQO attainment when the DQOstatements were originally developed using theTPP process. The U.S. EnvironmentalProtection Agency’s (EPA’s) Guidance for DataQuality Assessment should also be referencedwhen verifying DQO attainment. EPA’s20

guidance is particularly suited for verifyingDQO attainment when probabilistic decisionsare involved.

G.2 C O R R E C T I V E A C T I O NCONSIDERATIONS.Appropriate corrective actions should be takenwhenever data obtained are inadequate for theintended use(s). After completing anassessment of the effects of a missed DQO, thesource or cause for missing the DQO should beinvestigated and understood by the team. Whenpossible and necessary, re-sampling, and/or re-analysis, should then be performed at theexpense of the responsible party (e.g.,government, contractor, laboratory).

EM 200-1-231 Aug 98

G-2

DQO ATTAINMENT VERIFICATION WORKSHEETPAGE ____ of _____

SITE: _________________________

PROJECT: ________________________

DQO STATEMENT NUMBER: _________________

DQOElement DQO Element Description Site-Specific DQO Statement Attained? Required Corrective Action?Numbera

a b

Intended Data Use(s):

1 Project Objective(s)Satisfied

Yes ____No ____

Data Need Requirements:

2 Data User Perspective(s) Yes ____No ____

3 Contaminant orCharacteristic of Interest

Yes ____No ____

4 Media of InterestYes ____No ____

5 Required SamplingLocations or Areasand Depths

Yes ____No ____

6 Number ofSamples Required

Yes ____No ____

7 Reference Concentration ofInterest or OtherPerformance Criteria

Yes ____No ____

Appropriate Sampling and Analysis Methods:

8 Sampling MethodYes ____No ____

9 Analytical MethodYes ____No ____

Refer to Paragraph 4.2.1, p 4-4 to 4-5.a

DQO statement should be taken directly from originating DQO worksheet orb

corresponding SOW.