MORE EFFICIENT SAMPLING

[Lenny Siegel <lsiegel@igc.org>]

CALIFORNIA TASK FORCE CALLS FOR MORE EFFICIENT 
TESTING

 In December, 1994 the California Base Closure Environmental 
Committee (CBCEC), representing the armed services as well as state 
and federal Environmental Protection Agencies, issued a report 
proposing six initiatives designed to reduce the cost of laboratory 
analysis in environmental restoration. "Options for Cost Reductions in 
Environmental Assessment" compiled information from a number of 
earlier studies. Although focused on closing bases, most of the 
proposals are applicable to active bases and other contamination sites, 
too.

 CBCEC suggested that laboratory costs make up a large chunk 
of cleanup costs. It cited a MITRE Corporation study, in which fifteen 
sites were reviewed, that found that analytical services account for 
about 22 percent of the cost of the remedial investigation/feasibility 
study phase of environmental restoration.

 CBCEC concluded that often remedial project managers order 
testing without clearly defined objectives. At times, too many quality 
control samples are checked, without any improvement in data quality. 
Documentation, it found, is often redundantQincluding the same 
boilerplate language in study after study. Noting that most cleanup 
program lab work is contracted out, it cited a Navy study that 
concluded that government labs can perform testing for less expense 
that outside contractors.

 The report recommended five major initiatives:

1) Improve definition of sampling and analysis objectives in 
restoration. It presented the following as a possible model sequence of 
objectives:
 a) Determine whether contamination requiring remediation 
exists as a result of site activities.
 b) Locate the source of contamination and obtain site 
characterization information necessary for remedial system design.
 c) Monitor remedial system performance.
 d) Demonstrate that remedial action objectives have been 
attained.

2) Increase use of field tests rather than conducting extractive 
sampling for off-site analysis. It noted that field tests require less rigid 
planning because real-time results can be used to guide the placement 
of the next sampling. Furthermore, "Anomalous data can be 
resampled without delay." It also found, "Cost savings are realized 
because the field tests are usually less labor, equipment, and time 
intensive than laboratory analysis.

3) Standardize requirements for analytical services throughout the 
Department of Defense. This includes the development of standardized 
documents, which "would not only save the resources required for 
development of numerous redundant plans for each project, but would 
also expedite regulatory review and approval if the standardized 
documents are developed in conjunction with regulator input."

4) Contract directly with analytical laboratories, instead on working 
through prime contractors. CBCEC suggested the formation of a 
Defense-wide Sample Management Office to facilitate efficient 
contracting.

5) Modify Defense Department laboratory structure and capabilities. 
CBCEC suggests the creation of a regional Defense-owned lab or the 
formation of a laboratory cooperative.

 The report also suggested several simpler "quick-fixes," such 
as the elimination of ambient condition blank samples, but CBCEC 
concluded that those alone would do little to improve program 
efficiency. It estimated that the cost savings of full implementation, 
which could be accomplished within two years, could be as much as 
50 percent of assessment costs. Equally important, it argued, "In 
addition, the initiatives in analytical services would parlay into cost 
savings for remedial activities by providing timely and accurate data 
concurrent with remedial system trial testing and design."

Lenny Siegel