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"In general the approach has been...and what is convincing is drilling a well, going to some particular level, screening that well over 30 feet, grabbing that water sample, taking if off to the lab, and running it. Now that's hard evidence, hard data. If you had to go to a court of law, nobody could question that. 'Well, what have you done? You've only gotten the information at one particular site, one sample, at one depth, at one point in time.'
"Time changes, the contaminant changes, [there are other variables] in the entire profile. In looking over 30 feet, maybe in fact all that contaminant is coming from this one foot level where it's being transported very quickly and all the rest of the 27 feet doesn't have anything in it. But you've integrated over the whole 30 feet. You've lost information.
"In the 1980s, the regulations and the rules about how you characterize a site were pretty open. There wasn't much structure there. Therefore, it allowed creative thought. How am I going to solve this problem? How am I going to determine where the contamination is in the subsurface here? So people took it on as a multi-faceted problem. I'm going to have to use geophysicists to figure out where are the clay beds, where are the confining beds. I'm going to have to use hydrologists to figure out where the water is flowing because that's going to transport the contaminant. I'm going to have to use the chemist to read what is that contaminant, what's the quantity, and quantify it. How severe is the contamination? You're going to have to use the geophysicist to bring in the geophysical tools that tell you the stratigraphy. So they took on sort of a logical, technical approach to the problem.
"As time went on, the EPA felt, rightly so, the data was being collected in such an ambiguous process, at the time, that they questioned how it was collected and therefore it wouldn't stand up in a court of law. It wasn't totally accepted. Everyone knows that geophysics alone has a lot of questions about it. Is that seismic really telling me that the clay layer's here? Stand alone, the geophysics won't be a convincing case. It would never stand up in a court of law. Stand alone, the hydrology will have questions in it. Stand alone, the geology will say, 'Well, I'm pretty sure I understand how the sediments are here.' However, you combine them all, and say the geology is confirming what the chemist is seeing is confirming what the hydrologist is seeing, then you've got a complete picture.
"What happened over time, from 1980 on? They became more and more rigorous about what they would accept as data that would go into that record of decision of how you were going to remediate that site. In other words, how did you really understand, did you really characterize it? Well, as you become more confining about what you'll accept as acceptable data in a court of law, [you always faced the question of hard evidence]. Hard evidence...what's that I'll always say [I need], a piece of data that nobody could argue with, okay?
"And that means taking the sample from the ground, sending it off to a lab, going through a QA/QC process in a laboratory method. But what you ended up doing was restricting that information so much that in order to get the data to characterize this large area, you have to drill a lot of wells at these very discreet depths, at this one point... one place... one point in time. So it required taking more samples. No one would believe just that well. I've got the picture here, but I don't really understand here, and is that really what's happening, well I got nondetect, nondetect, nondetect, well it's not here. Well then, where is it? I have to drill more wells to get more samples. What ended up happening? You characterized a site over two, four, seven years, never remediated, and that's exactly what's at the table now.
"Clinton in the White House is now looking at the new Superfund authorization bill, which is basically saying we only cleaned up 15 or whatever the number is, but some small fraction of the thousands of sites we've identified as being a problem. So something's got to give here. If you want hard quality data, every single sample you take, and the price tag you're going to pay, it's going to take forever to get it."
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Last Modified: 1 January 2002 by dave eckels
Expedited Site Characterization: etd/technologies/projects/esc/demos/mtown/doe.html