WEBVTT 1 00:00:00.000 --> 00:00:04.000 Hello! Hello! Everyone welcome and thank you so much for joining us today. 2 00:00:04.000 --> 00:00:07.000 On behalf of the interstate technology and Regulatory Council. 3 00:00:07.000 --> 00:00:14.000 Welcome to today's training incremental sampling methodology Update Ism: 2 We're doing an expert panel today. 4 00:00:14.000 --> 00:00:18.000 So we are here to respond to your questions. My name is Evan Madden. 5 00:00:18.000 --> 00:00:22.000 I am your moderator today, coming to you, live from Arlington, Virginia. 6 00:00:22.000 --> 00:00:27.000 If you have not already done so, we encourage you to visit the guidance document at Ism. 7 00:00:27.000 --> 00:00:32.000 2 dash, Correct! Excuse me, I have some dash to dot itrc web.org. 8 00:00:32.000 --> 00:00:34.000 We'll put this in the chat here in a moment. 9 00:00:34.000 --> 00:00:41.000 Use the Q. A. Pod during the session to ask questions or report any technical problems that you may be experiencing. 10 00:00:41.000 --> 00:00:54.000 But first we're gonna do a brief overview on the Interstate Technology and Regulatory Council, the interstate Technology and Regulatory Council, or Itrc is A program of the environmental Council of the States Itrc is a statelet organization. 11 00:00:54.000 --> 00:01:11.000 Composed of over 1,000 members from State agencies; that Federal government, the private sector, academia, and community stakeholders it Orc members participate in technical teams which produce tools, resources, in training courses, such as the one you're participating in today, we encourage you to visit 12 00:01:11.000 --> 00:01:14.000 itrc web.org to learn more about our organization. 13 00:01:14.000 --> 00:01:19.000 Additionally the full itrc disclaimer is also available on our website. 14 00:01:19.000 --> 00:01:24.000 If you plan to use any of our materials, we do ask that you review that policy in detail, and be sure to credit. 15 00:01:24.000 --> 00:01:27.000 Irc Yeah. Itrc: is partially funded by the Us. 16 00:01:27.000 --> 00:01:34.000 Government Itrc. Nor the Us. Government warranted the material, nor endorse any specific products. 17 00:01:34.000 --> 00:01:48.000 That said, Here, on Slide 4. I'm welcoming our expert trainers that have joined us today Not only these trainers volunteers, but they've dedicated many hours to developing sessions one and 2 of incremental sampling methodology which are archived and available for 18 00:01:48.000 --> 00:01:51.000 on-demand, viewing and listening on Cluin. 19 00:01:51.000 --> 00:01:54.000 We're coming together to answer any questions with this expert panel today. 20 00:01:54.000 --> 00:01:58.000 So with that, said, I'm gonna go ahead and jump right into question. 21 00:01:58.000 --> 00:02:03.000 One to get us started here. So that said, Let's define some of the terms. 22 00:02:03.000 --> 00:02:10.000 We're gonna go here and recap in Ism I'd like to turn the floor over to Jason. 23 00:02:10.000 --> 00:02:18.000 Would you? Would you be interested in able to give us a quick overview of some of the concepts covered in module 0 of session? 24 00:02:18.000 --> 00:02:36.000 yeah, sure. Hi: everyone. I'm Jason Braderson, and I was one of the key authors for the document, and just kind of a maybe just a 2 min overview of the intro module and just some of the key concepts that we'll be talking about the definition of incremental sampling is a 25 00:02:36.000 --> 00:02:45.000 statistically, technique for assessing the mean concentration of any volume of sediment or soil. 26 00:02:45.000 --> 00:02:51.000 It is conducted through. Add the collection of a highly structured composite sample. 27 00:02:51.000 --> 00:02:55.000 It's a both a sampling and a processing protocol. 28 00:02:55.000 --> 00:03:19.000 the sample itself is anywhere between 30 and a 100 increments, and increment is a often a core or a small volume of soil, that we composited together to provide the incremental sample depending on your level of confidence required and the contaminants and the size of 29 00:03:19.000 --> 00:03:23.000 interest That's what can dictate the number of increments that are using. 30 00:03:23.000 --> 00:03:28.000 So the area of soul that we're talking about is defined as a decision unit. 31 00:03:28.000 --> 00:03:35.000 Some practitioners use the term sampling unit when multiple incremental samples are used to make a decision. 32 00:03:35.000 --> 00:03:40.000 those terms can be used, interchangeably. 33 00:03:40.000 --> 00:03:45.000 Like, I said, the increment is the small volume of soil that is composited together. 34 00:03:45.000 --> 00:03:53.000 To make up your incremental sample, and an important piece really a key piece of internal sampling is the use of replicates. 35 00:03:53.000 --> 00:04:00.000 we use the term, replicates little bit interchangeably with triple kits, but you can have more than 3 replicates. 36 00:04:00.000 --> 00:04:07.000 Therefore it can be just. Use those replicates. I've worked on projects where we've done up to 7 replicates for a specific decision. 37 00:04:07.000 --> 00:04:10.000 Yet I want to emphasize the importance of planning. 38 00:04:10.000 --> 00:04:19.000 It is a sampling technique. Where and you get one data point for each incremental sample. 39 00:04:19.000 --> 00:04:24.000 And so it's super important for everyone to know how many use that data point and its replicas. 40 00:04:24.000 --> 00:04:28.000 It It kind of falls back on the importance of the conceptual site model. 41 00:04:28.000 --> 00:04:35.000 What is the question that you're trying to answer? Who are the different users of this data? 42 00:04:35.000 --> 00:04:38.000 How are you gonna use the data? What are the follow up steps? Right? 43 00:04:38.000 --> 00:04:44.000 How you want to use this data? Are you going to try to do it in one sampling event? 44 00:04:44.000 --> 00:04:47.000 Are you going to go back to decision units, if you need to? 45 00:04:47.000 --> 00:04:59.000 so asking all those questions are a key part of the conceptual site model, and then, finally, really, what I think is more the art and science of all of the internal sampling is just how are you setting up. 46 00:04:59.000 --> 00:05:04.000 Your decision unit. It's the most important part of incremental sampling, because it is really the beginning. 47 00:05:04.000 --> 00:05:09.000 It dictates how things happen from there. It's not a one-time thing. 48 00:05:09.000 --> 00:05:12.000 You can always go back to decision units. And subdivide them. 49 00:05:12.000 --> 00:05:26.000 If you want, or sample them again. But really, just always ask yourself, How are you setting up your decision unit, and how are you going to use that data? 50 00:05:26.000 --> 00:05:29.000 thanks for the overview. Jason really appreciate it. 51 00:05:29.000 --> 00:05:33.000 just wanted to again for those of you that are coming in late online. 52 00:05:33.000 --> 00:05:38.000 We do have a Q. A. Pod in the bottom menu of your zoom window. 53 00:05:38.000 --> 00:05:45.000 You can click on that and input any questions you may have into that pod and we will be able to have our experts answer those live on the call. 54 00:05:45.000 --> 00:05:48.000 So just wanted to make sure again that you're aware of that. 55 00:05:48.000 --> 00:05:53.000 But that said, I think we'll move over into into our second question. 56 00:05:53.000 --> 00:06:01.000 So the Ism. 2 training series was presented in March of 2021, first what has changed in the last year? 57 00:06:01.000 --> 00:06:09.000 I know we have Todd Miller online Todd. 58 00:06:09.000 --> 00:06:20.000 Yeah, sure. Thanks, Evan. Yeah, So in almost the 2 years since the document is come out, the concepts, methodologies, and practices it really haven't changed in that time. 59 00:06:20.000 --> 00:06:27.000 I Askedm is becoming better understood by both consultants and regulators. 60 00:06:27.000 --> 00:06:32.000 we, and we've heard from some regulars that regulators that Ism is being used for. 61 00:06:32.000 --> 00:06:53.000 You know, even more interesting and complex sites. However, there's still some misconceptions that we often hear it being used with Ism, for example, you know, Ism you know will ism miss areas of elevated concentration or you know that it will in fact, Dilute. 62 00:06:53.000 --> 00:07:10.000 the concentration that you get, and I'll just remind folks here that if you go back to Section 3, point, one of the document, you'll see that ism is designed to provide a statistical representation of the expected concentration, of the constituents of concern with any within any given decision 63 00:07:10.000 --> 00:07:21.000 unit. So you know, it. It's it's designed to get you that expected concentration, or, as Jason had said, you know the mean concentration for a decision unit. 64 00:07:21.000 --> 00:07:25.000 the key to obtaining results that are representative is in the planning. 65 00:07:25.000 --> 00:07:36.000 As Jason had said, and I hope everybody on the line really hears this and and starts thinking about it really is is the planning and deciding what a decision unit is. 66 00:07:36.000 --> 00:07:56.000 And you know why you know, as we also, as we summarize in section 9 of the document the team should involve your regulators, key stakeholders and parties that are really going to be involved with planning or use of the day, that you're gonna collect and getting 67 00:07:56.000 --> 00:08:02.000 that planning done early is a a a key, key, component to a successful project. 68 00:08:02.000 --> 00:08:11.000 there are. Yeah, there does seem to still need to be some meeting of outreach or education for this process, since this training is continuing. 69 00:08:11.000 --> 00:08:26.000 but also we we urge others to talk to their regulators about the process, and really get a better understanding of of how the different states are are viewing it and using using this process on particular sites. 70 00:08:26.000 --> 00:08:34.000 and as we discussed, last during last year's training, you know, and and, as Jason had said, in a very strong point, which is planning really is the key to a successful outcome. 71 00:08:34.000 --> 00:08:46.000 You know, planning needs to. Include, You know, all aspects of the project from how you're going to collect the data who's going to collect it, To How is it going to be used in Section 9? 72 00:08:46.000 --> 00:09:16.000 really gives gives a good description of. You know why these components are important, and how how to engage stakeholders, and how to keep those stakeholders on on track, and with what the objectives of the program are, See mark I'll I'll ask 73 00:09:16.000 --> 00:09:37.000 okay, I mean, you know, originally, Ism was developed for use on military training ranges and expanded to other parts of military sites, and then from there kind of grew out to other applications of surface soil characterization, and then kind of expanded from there into subsurface soil we've 74 00:09:37.000 --> 00:09:57.000 even seen applications on Brownfield sites, and basically that the general rule thumb, if you're trying to manage significant heterogeneity, then Ism is a tool that you should at least consider if not actually conclude that it's actually the best tool, for helping to manage that 75 00:09:57.000 --> 00:10:13.000 heterogeneity. The range of chemicals of concern have greatly expanded from the original energetics and metals, and to a wider range of semi-volid organics and volatile organics. 76 00:10:13.000 --> 00:10:25.000 and then we've got the probably the most ubiquitously requested. A group of analytics in terms of our poly fluorinated alkal substances We're seeing a lot. 77 00:10:25.000 --> 00:10:45.000 More. P. Fast sites that are now being requested, and that has its own special constraints in terms of managing contamination, both during the sample collection as well as during The sample processing and analysis so by and large it's it's just growing all over the 78 00:10:45.000 --> 00:11:03.000 place. 79 00:11:03.000 --> 00:11:16.000 sure, yeah, in in Michigan we're seeing a lot of new users just like like you guys have said a couple of new labs that are that are into the into the marketplace now, using incremental sampling the processing again. 80 00:11:16.000 --> 00:11:20.000 It's it's both the field work and the processing in the lab. 81 00:11:20.000 --> 00:11:29.000 So you gotta be on the same page with that. So we we've been tracking that, as you said, Pfas is A is a hot topic in Michigan. 82 00:11:29.000 --> 00:11:38.000 we really are seeing a lot of that. Both bio salads, residential areas, a lot of brown fields. 83 00:11:38.000 --> 00:11:57.000 We have a few rail trail projects that we're using incremental sampling on within which which involve urban Phil kind of understanding that, and then some pretty big projects where we're trying to understand the current conditions with incremental sampling and then how they manage that and do all 84 00:11:57.000 --> 00:12:06.000 the cuts and fills, and then really coming back as a separate phase to do the final grade right, which is then going to be? 85 00:12:06.000 --> 00:12:10.000 What is the exposure for the next 30 years, or 50 years? Right? 86 00:12:10.000 --> 00:12:12.000 So we're really kind of doing that in 2, 4 phases. 87 00:12:12.000 --> 00:12:16.000 The initial phase to do some investment in in soil management. 88 00:12:16.000 --> 00:12:22.000 But then we really can't use that data to do the final decision making. 89 00:12:22.000 --> 00:12:26.000 We have to do that as a separate whole separate phase. 90 00:12:26.000 --> 00:12:32.000 So again, I think the snowball is rolling down the hill that we're really seeing a lot of of really good work. 91 00:12:32.000 --> 00:12:38.000 We're working with consultants who are new to the game early and making sure that they're successful. 92 00:12:38.000 --> 00:12:46.000 And we're really seeing some great outcomes, you know, consultants, all of us like to see reproducible samples. 93 00:12:46.000 --> 00:12:51.000 So when our relative standard deviations come back real tight, our data come back tight. 94 00:12:51.000 --> 00:13:04.000 it makes everybody look good. So that's that's the experience in Michigan where we're glad people are using it and encouraging more and more to Use it. 95 00:13:04.000 --> 00:13:13.000 hey? Thanks, Chris. Well, here in California a lot of the sites that I work on are former egg fields. 96 00:13:13.000 --> 00:13:28.000 I'm a talks call. Just risk, assessor, so I serve as a expert to our project managers, and don't see the breadth of Sam Have a sites as some people, do but I do know that we have them have used it. 97 00:13:28.000 --> 00:13:35.000 At Federal facilities, and other former industrial locations also. 98 00:13:35.000 --> 00:13:52.000 So we our seeing a wide range of use in Ism, and it is increasing, and we are preparing a guidance document here at Dtsc for the use of ism citing this. It Rc. 99 00:13:52.000 --> 00:14:05.000 Guidance document for sampling from former Ag field areas 100 00:14:05.000 --> 00:14:29.000 Thanks Karen. I appreciate it. We did get a comment or question asking about Ism, and and more specifically, its relation to pfas on a on a state level. So I was wondering. 101 00:14:29.000 --> 00:14:37.000 Yeah, I could take it. I could take a stab. It all comes down to a criteria. Right? 102 00:14:37.000 --> 00:14:40.000 What What is the criteria you're going to be comparing against in many of the P. 103 00:14:40.000 --> 00:14:53.000 Fast, whether it's a a groundwater surface water interface number or a soil protective of groundwater, drinking water number That's really where that's at a lot of the P. 104 00:14:53.000 --> 00:14:58.000 Fast that we've done in Michigan is more, is it present? 105 00:14:58.000 --> 00:15:05.000 And in kind of understanding its presence or absence. At this point, So again, I think we you really have to. 106 00:15:05.000 --> 00:15:09.000 Then a talk with the lab, as Mark mentioned, lots of P. 107 00:15:09.000 --> 00:15:13.000 Fast happening, but then also kinda understand the tax ecology. 108 00:15:13.000 --> 00:15:16.000 And what are the criteria that you're applying it to? You? 109 00:15:16.000 --> 00:15:17.000 Really need to have that all figured out in the planning stages. 110 00:15:17.000 --> 00:15:32.000 If anyone online would like to comment about that 111 00:15:32.000 --> 00:15:47.000 I was just gonna note that, you know I We are seeing increasing requirements to analyze for Pythos and soil, And a number of states now have developed soil criteria for P. Fa. 112 00:15:47.000 --> 00:15:48.000 So I think it's going to be a growing need, and again, you you can use. 113 00:15:48.000 --> 00:16:18.000 Mark. Could you expand on this? Maybe a bit more or camera 114 00:16:19.000 --> 00:16:25.000 I mean, we're seeing more requests for pfas analysis. 115 00:16:25.000 --> 00:16:45.000 From Ism Collected samples. Again, in this case, primarily surface soils and you know, as I mentioned earlier, only a couple of our P. Fast labs are actually set up to handle or only a couple of our ism. 116 00:16:45.000 --> 00:16:53.000 Labs are set up to can't handle The cleanliness requirements A p fastage, typically looking at much lower levels. 117 00:16:53.000 --> 00:16:54.000 And so it's it's something that can be done. 118 00:16:54.000 --> 00:17:06.000 Mark Jason would either be like to add to that 119 00:17:06.000 --> 00:17:13.000 And can one of you speak to whether I mean p Fas and and ism is being used for Pfs. 120 00:17:13.000 --> 00:17:32.000 But it was asked whether Pfs. Was more of a groundwater issue than a soil issue per se 121 00:17:32.000 --> 00:17:57.000 Well, I'm not a state regulator, but thought I responded to that just by noting that there are a number of published criteria now states have released for Teethoss and soil, and we are increasingly being asked to analyze for P fast, and Soil oh, I I think it's 122 00:17:57.000 --> 00:18:07.000 and in understanding that soil, concentration certainly incremental sampling is the way to get what is the source, What is the volume of soil? 123 00:18:07.000 --> 00:18:13.000 Getting a good number for a representative volume of soil is what incremental sampling is all about. 124 00:18:13.000 --> 00:18:29.000 So this is the method to use. Now, what what criteria you apply, how that all fits into the source that then gets to the groundwater, and could be someone's drinking water. 125 00:18:29.000 --> 00:18:34.000 that's really more of a state specific question that you're gonna need to work through. 126 00:18:34.000 --> 00:18:47.000 What is that criteria that you're gonna be applying it, and that should all be done before the sampling takes place? 127 00:18:47.000 --> 00:18:51.000 Thanks, Chris. We did have a question involving pro Ucl and Ucl. 128 00:18:51.000 --> 00:18:56.000 Calculations, Hayley, Brittham, I think we have Hayley on the line. 129 00:18:56.000 --> 00:19:02.000 Would you care to speak to that 130 00:19:02.000 --> 00:19:08.000 sorry. Yeah, that's a great question. So with Procl version, 5 point, 2. 131 00:19:08.000 --> 00:19:11.000 it's no longer gonna recommend the Chebyshev Ucl. 132 00:19:11.000 --> 00:19:14.000 and it's true that the Chebyshev Ucl. 133 00:19:14.000 --> 00:19:19.000 Does tend to overestimate the mean compared to some other choices. 134 00:19:19.000 --> 00:19:30.000 however, with the ism, 2 document we're talking about, you know, specific recommendations related to ism designs. 135 00:19:30.000 --> 00:19:42.000 And so typically we're not gonna have as many samples as if you took discrete samples, And that limits us with respect to what you see, also, we can use. 136 00:19:42.000 --> 00:19:53.000 So in pro Ucl: if you were to input an Ism data set with between 3 and 6 samples it's gonna estimate all of these different Ucls for you. 137 00:19:53.000 --> 00:20:09.000 That might not be appropriate, just because you don't have enough samples to, for example, determine that you have a game, a distribution, or, to use any bootstrap methods so really long story short, with, between 3 and 6. 138 00:20:09.000 --> 00:20:13.000 Samples that are going to be most typical with all ism designs. 139 00:20:13.000 --> 00:20:17.000 really our only choices are the Tcl. And the Chebyshev. 140 00:20:17.000 --> 00:20:25.000 Ucl. And so if you determine that your data are too skewed to use the Tucl, then the Chebyshev Ucl. 141 00:20:25.000 --> 00:20:38.000 Is really going to be your only option. Another alternative is that if you find up the Chebyshev Ucl looks to be much higher than your sample mean, and say, for example, your Ucl. 142 00:20:38.000 --> 00:20:43.000 Is higher than your screening level. But maybe you're sampling is less than your screening level. 143 00:20:43.000 --> 00:21:01.000 Then that's an example where you might want to collect additional data. 144 00:21:01.000 --> 00:21:15.000 Thanks, Haley. We have another question, a little more general. So this is open up to everybody. 145 00:21:15.000 --> 00:21:22.000 Yeah, I can take that one as well I'm not sure there's much that's changed since the Ism. 146 00:21:22.000 --> 00:21:38.000 2 document came out. We still recommend doing background comparisons through valid statistical tests, like, for example, a t-test is one example of that we don't recommend calculating. 147 00:21:38.000 --> 00:21:45.000 btbs with ism designs, And that's typically again because of the small sample size. 148 00:21:45.000 --> 00:21:55.000 So you really need a pretty large sample size to calculate a btb, and that's not typically going to be appropriate with ism designs. 149 00:21:55.000 --> 00:22:16.000 and then, in addition to that, since I and some samples represent the mean, and it kind of complicates the conceptualization, or you know how you interpret a calculated B TV doesn't really make sense to collect samples that represent the mean and then try to calculate an upper percentile 150 00:22:16.000 --> 00:22:20.000 from those samples, so that kind of gets a little bit complicated. 151 00:22:20.000 --> 00:22:21.000 so for that reason we recommend doing valid, statistical tests. 152 00:22:21.000 --> 00:22:32.000 what has changed in the use of statistics, particularly in relation to background 153 00:22:32.000 --> 00:22:48.000 Thanks, Hayley. Just up. Next. We have another question, I believe, for Mister Bruce, with traditional contaminants, The Ism laboratory processing requires the negative that associated with small Diameter tar paint chips etc. 154 00:22:48.000 --> 00:22:57.000 Have you observed nugget effects with pfas is Pfs binding? 155 00:22:57.000 --> 00:23:01.000 Well, I can't say that we have specifically observed that nugget effect. 156 00:23:01.000 --> 00:23:13.000 I mean it's obviously most pronounced for explosives and metal fragments, and there's been a little bit of evidence suggesting that it it could be to PCB. 157 00:23:13.000 --> 00:23:18.000 As they get released, as oils that then form these little tarballs. 158 00:23:18.000 --> 00:23:26.000 well, pay fast as it's, you know, covers thousands of compounds At this point. 159 00:23:26.000 --> 00:23:27.000 There isn't a universal answer for that. It is certainly reasonable. 160 00:23:27.000 --> 00:23:31.000 Preferably with specific types of soil particles 161 00:23:31.000 --> 00:23:43.000 Think there might be some of those individual p-pass components that might have a tendency to form nuggets, but by and large we're not seeing obvious evidence of that yet. 162 00:23:43.000 --> 00:23:59.000 But it's still relatively early in the application. 163 00:23:59.000 --> 00:24:04.000 thanks. I really appreciate that. So let's take another question. 164 00:24:04.000 --> 00:24:08.000 Derek's got a question, considering Pfs. 165 00:24:08.000 --> 00:24:33.000 Can be transported through the natural of apple transpiration process and deposited to elsewhere where there's not an immediate, identifiable source of Pfs contamination? 166 00:24:33.000 --> 00:24:37.000 I I would say that means it's ubiquitous across the globe. 167 00:24:37.000 --> 00:24:41.000 Unfortunately, that that's a That's a huge question. 168 00:24:41.000 --> 00:24:49.000 to to be honest, that makes it difficult. You would certainly need to understand what is a source. 169 00:24:49.000 --> 00:24:52.000 And why are you sampling where you're sampling? 170 00:24:52.000 --> 00:25:06.000 What does the mere presence, I, and any sort of idea of a background concentration, a naturally occurring or a industrial occurring background, Concentration? Meaning. 171 00:25:06.000 --> 00:25:26.000 but that's those are the discussions that you'd need to be in in pretty detailed discussion with your State regulator and and understand what those if then, statements are gonna look like, so date doing a data quality objective process, filling out the If then statements, If, we have single digit 172 00:25:26.000 --> 00:25:29.000 per per trillion. What does that mean? Does that mean? 173 00:25:29.000 --> 00:25:33.000 We have to go out and sample. Does that mean that we are a responsible party? 174 00:25:33.000 --> 00:25:44.000 Those discussions should be occurring throughout the D Dql. 175 00:25:44.000 --> 00:25:59.000 I'll just add in Thank you, Chris, that background issue. And right if we, if we have documented background concentrations that 176 00:25:59.000 --> 00:26:29.000 We have designed our studies adequately, for then we would consider that in the risk assessment also, and it would be evaluated, and and it may or may not, be you know, depending on what the concentrations were compared to background levels a an issue, ultimately in the risk. 177 00:26:40.000 --> 00:26:41.000 Thanks, Karen. Thanks all for for chiming in on that one. 178 00:26:41.000 --> 00:27:00.000 Hi! 179 00:27:00.000 --> 00:27:03.000 I mean, I can try to answer that. That's a great question. 180 00:27:03.000 --> 00:27:15.000 it's great because Rickra has some specific regs and and language in there that is sometimes interpreted differently by different users. 181 00:27:15.000 --> 00:27:24.000 I've got a lot of clients that ask that same question It's kind of interesting, because you know, you as the generator are responsible for your waste profile right? 182 00:27:24.000 --> 00:27:28.000 And the acceptance, facility can accept or not, they can choose not to accept it. 183 00:27:28.000 --> 00:27:38.000 I feel like as a generator. You want to make sure you've got the most valid and supported data in terms of your profile. 184 00:27:38.000 --> 00:27:43.000 we've set tons of samples off to landfills and California that have accepted Ism. 185 00:27:43.000 --> 00:27:47.000 But I'll I'll state that we don't necessarily tell them exactly how we're doing it. 186 00:27:47.000 --> 00:27:51.000 We just fill out the profile, we give them the concentrations, and they accept it. 187 00:27:51.000 --> 00:28:08.000 We've had discussions with our estate agencies in California about how Ism does fit into Rickra and the California has his waste laws, and it's a comp I'll tell you it's a convoluted discussion that goes a variety of ways depending on who's interpreting 188 00:28:08.000 --> 00:28:15.000 the Regs differently. So I'm not necessarily giving any clarity to your question other than as the generator. 189 00:28:15.000 --> 00:28:16.000 You're responsible for the profile, and my advice would be if they have questions about it. 190 00:28:16.000 --> 00:28:25.000 No, I 191 00:28:25.000 --> 00:28:44.000 Yeah, and Jason, I'll add on to that in certain States they do have requirements for discrete samples, and it depends on the state you're working in as well as potentially You know if your site has a sample sampling analysis plan or or a Dq plan 192 00:28:44.000 --> 00:28:54.000 a lot of times your waste. Characterization is spelled out in that plan, so it could very well be state specific requirements or or sites. 193 00:28:54.000 --> 00:29:09.000 Specific requirements, but I agree that sitting down with the landfill and explaining to them it's a composite sample, because a lot of landfills do accept composite samples as a waste stream, representative, sample. 194 00:29:09.000 --> 00:29:14.000 So it it does. It. It does require a little more discussion. 195 00:29:14.000 --> 00:29:38.000 Upfront, and again, These are These are some of the discussions that you want to have, and some of the conversations you want to have and bring in to certain stakeholders at the planning phase of the project so I I would suggest that people have that that conversation 196 00:29:38.000 --> 00:29:40.000 how I was going to agree with Jason And Todd. 197 00:29:40.000 --> 00:29:41.000 You got to talk about it upfront. But really the purpose of waste characterization is to collect a sample that's representative of your waste stream as a whole, and I think they're solid scientific arguments to be had that ism is is the best way. 198 00:29:41.000 --> 00:30:02.000 okay. 199 00:30:02.000 --> 00:30:15.000 Thanks Thomas following up what are the most common ism sample processing options, and when should they be selected? 200 00:30:15.000 --> 00:30:25.000 Okay, Yeah, could you go ahead and show slide? 26 as I answer, this one 201 00:30:25.000 --> 00:30:32.000 Okay, what we have seen from Yeah, there you go. What we have seen when we originally developed. 202 00:30:32.000 --> 00:30:49.000 Ism. One. There was a lot of uncertainty as to what was going to be selected in terms of the most common options, and at this point things have kind of coalesced down into just a few merry commonly selected options. 203 00:30:49.000 --> 00:31:11.000 for most sample types and analytics groups. We typically start with air drying and then disaggregate, baking, breaking up the dirt clouds, and then in most cases do some sort of saving using a number 10 S is the most common and Then either proceed from There directly 204 00:31:11.000 --> 00:31:21.000 into subsampling to produce the analytical subsample that goes into the sample prep and analysis process, or sometimes there will be an intermediate milling step. 205 00:31:21.000 --> 00:31:25.000 If it's important to do further particle size, reduction. 206 00:31:25.000 --> 00:31:37.000 So those are kind of the 2 most common options. Another that shows up is if there are significant concerns that some of the analytics might be lost or degraded during the air. 207 00:31:37.000 --> 00:31:49.000 Drying step, we will actually use the 2 dimensional slab cake process and actually collect the analytical subsample on the as received sample. 208 00:31:49.000 --> 00:32:08.000 That shows up in some of the Hawaii guidance documents and a number of his other instances where we're working with a low, boiling semi-volatile organic compounds that are not strongly retained onto the soil particles so those are kind of the 3 most 209 00:32:08.000 --> 00:32:16.000 common options. Obviously there are a number of permutations in the in terms of using different sip sizes for different data and uses. 210 00:32:16.000 --> 00:32:17.000 There are some options in terms of what you want to use for milling, but by and large it's kind of coalesced down to those 3. 211 00:32:17.000 --> 00:32:27.000 maybe, Mark, if you'd like to kick this one off 212 00:32:27.000 --> 00:32:51.000 Thank you. Mark. Kind of going off that same band, of thought Michael asks The state of Washington requires discrete sediment, samples, so the results. 213 00:32:51.000 --> 00:33:08.000 well, Evan Todd Miller here, in in reading the question, I would ask you if if we're talking about sediment samples from a you know a Wetlands, Where they're being hand collected, or you know side of a stream, bank or if you're actually out in the 214 00:33:08.000 --> 00:33:15.000 water on a barge, on a small ship, because there certainly is, you know, from a sampling complexity. 215 00:33:15.000 --> 00:33:23.000 Nature, If you're talking about collecting samples from a river, there certainly is a complex nature. 216 00:33:23.000 --> 00:33:41.000 And how those samples get collected If we're talking about following the scum, 2 guidance document from the State of Washington, then the samples that they do describe are not necessarily discrete, because they do talk about grab samples and and multiple grabs from a single area 217 00:33:41.000 --> 00:33:55.000 for certain sampling, so I I think it becomes a little complicated, and probably a little more complicated than what we can address here with a simple question. 218 00:33:55.000 --> 00:34:05.000 yeah, I'd like to chime in, because I think Michael's question is relevant to a lot of different programs out there There are still a lot of State and some Federal programs that require to screen samples. 219 00:34:05.000 --> 00:34:13.000 that's a challenging one, and we've been dealing with that in California with a couple of lead agencies over the years really since 2,008. 220 00:34:13.000 --> 00:34:28.000 And it's very difficult to get an agency if they've got something riding in a guidance, or especially if it's in regulation to to come around to how to handle ism And so there's not a good answer for that other than continue. 221 00:34:28.000 --> 00:34:31.000 To work with their agency, see if they can, you know. 222 00:34:31.000 --> 00:34:34.000 Take these training, see if they can go to some of the longer trainings. 223 00:34:34.000 --> 00:34:48.000 See if you can start to introduce some of the concepts of internal sampling in terms of replicates, and how to understand and quantify your heterogeneity, of your contaminant or your media and try to get them to think along the path of Okay, well, what can we do to 224 00:34:48.000 --> 00:34:55.000 help control heterogeneity, and, more importantly, what can we do to increase the confidence in any data points? 225 00:34:55.000 --> 00:35:17.000 We get back. So I think that's just the the struggle that a lot of the folks have been working in the industry for a long time have been have been up again. 226 00:35:17.000 --> 00:35:21.000 yeah, and and as a as a state regulator for for 30 years. 227 00:35:21.000 --> 00:35:24.000 That's actually what we're doing. So we're actually training our own staff. 228 00:35:24.000 --> 00:35:29.000 So next week I have 20 staff that are going through. 229 00:35:29.000 --> 00:35:49.000 intent week, long class on incremental sampling, and and the concepts and really kind of breaking down some of those those barriers of, as you said, this is this is a continuing crusade that we're on to really insert common sense good scientific data. 230 00:35:49.000 --> 00:35:53.000 And again: the the science is there, the reproducibility is there. 231 00:35:53.000 --> 00:36:06.000 These are defendable samples, because very few discrete sample planning projects actually have that replicate data to determine how reproducible is. 232 00:36:06.000 --> 00:36:16.000 This data, so again continue to have those discussions. But but certainly there are parts of State laws that are difficult to overcome. 233 00:36:16.000 --> 00:36:27.000 There are different State guidance, documents. They're difficult to overcome, but that doesn't mean we shouldn't try from both the inside as a regulator and from the outside consultant and work together. 234 00:36:27.000 --> 00:36:37.000 this, that's that's the beauty of Itrc. 235 00:36:37.000 --> 00:36:51.000 and I can't remember off the top. Of my head who it was, but I thought we had a a member from the State of Washington as part of the ism team, you know, so you might put try to find out who that is and put them in contact with the regulators. 236 00:36:51.000 --> 00:37:04.000 That you're interfacing with. I know I'm working on a project right now that you, us EPA, actually came to us and suggested, we use ism for characterizing stream. 237 00:37:04.000 --> 00:37:17.000 Samples. We're trying to do confirmation samples after a record cleanup, you know, you take a grab sample here, and you, get one result a grab sample there and another one widely different result. 238 00:37:17.000 --> 00:37:34.000 So we ended up. How are you doing? And and I havem sampling program, which we thought would be some point first, but but, like we talked about early on you got to get all the stakeholders involved early on so we had a of whole site. 239 00:37:34.000 --> 00:37:39.000 Csm. For the project, while we wanted to do a stream. 240 00:37:39.000 --> 00:37:43.000 Ism sample. We had a you know, create a refined Csm. 241 00:37:43.000 --> 00:38:03.000 That just addressed the stream. All the potential sources of the stream, you know Onsite, run off of sediment, offsite, run off of sediment, some within the regulatory agency had some concerns, about potential groundwater contributing to contamination of the settlement so we ended up 242 00:38:03.000 --> 00:38:07.000 with a greatly diverse group of people involved in setting up. 243 00:38:07.000 --> 00:38:11.000 That ism program. We haven't reached the end yet. 244 00:38:11.000 --> 00:38:26.000 It's still in progress. But I I can tell you that there are precedent for regulatory agencies, preferring ism to characterizing settlements and I mean one of the simplest answers are is the critters in the stream don't stay in the same place all the 245 00:38:26.000 --> 00:38:34.000 time. You may have a grab sample I want to be linked to a specific biota sample, but things don't work that well in the real world. 246 00:38:34.000 --> 00:38:39.000 Things move around in the stream. You know the settlements move the creditors move. 247 00:38:39.000 --> 00:38:47.000 So really I I don't see it being scientifically defensible to Yeah, say, one grab sample equals one by other sample. 248 00:38:47.000 --> 00:38:52.000 right. It and and we've done that in stream sediment sampling in Michigan And again. 249 00:38:52.000 --> 00:38:56.000 There there's a whole group, as you said Time it, EPA. 250 00:38:56.000 --> 00:39:03.000 You know Matt Jefferson, Nate Barlot, Jack Barber just gave a really great presentation on sediment. 251 00:39:03.000 --> 00:39:11.000 Sampling related to Philadelphia area and EPA region there, so there's a lot of really great work that's happening. 252 00:39:11.000 --> 00:39:19.000 A lot of great EPA people, who are also on this mission to spread the the good news of incremental sampling. 253 00:39:19.000 --> 00:39:22.000 So there's a lot of great connections out there. 254 00:39:22.000 --> 00:39:40.000 yeah, I think if if there's a Washington State person, the you can connect with don't give up. 255 00:39:40.000 --> 00:39:46.000 speaking, the gospel of sampling. We're gonna keep kind of on that same subject. 256 00:39:46.000 --> 00:39:54.000 I'm wondering. Do you have recommendations on how to plan samples so not to miss small areas of elevated content or concentrations again. 257 00:39:54.000 --> 00:40:00.000 Still, kind of playing off that same thought Todd. 258 00:40:00.000 --> 00:40:22.000 Yeah, So thanks. Kevin. Good question, you know, really comes back down to probably the the central theme you're hearing today, which is planning and your site conceptual model section point 3, 3, point one of the document has some good examples of why this really shouldn't be a concern you 259 00:40:22.000 --> 00:40:32.000 know, if if your team has a good understanding of the the conceptual site model, then you can set up your your sampling units and your decision units to be more represented. 260 00:40:32.000 --> 00:40:37.000 Of the site and and not just the site. But the questions you're trying to answer. 261 00:40:37.000 --> 00:40:52.000 and again, you know it's it's all about the planning and and understanding how you're going to use the data and how your stakeholders want to use the data and what data are important to collect there are certainly tools out there like visual sampling plan which we haven't talked 262 00:40:52.000 --> 00:40:56.000 about Vsp: that can help design your sampling program. 263 00:40:56.000 --> 00:41:16.000 section, 3.4 has some cost benefit discussions in it that you can look at to evaluate how you collect data from small areas versus large areas and where that those those cost values or those cost benefits might be one of The other things to look at is simply your number of rep sorry. 264 00:41:16.000 --> 00:41:18.000 Your number of increments in your number of replicates. 265 00:41:18.000 --> 00:41:24.000 how many increments are you collecting free Cherry, and how many replicates are you collecting? 266 00:41:24.000 --> 00:41:42.000 So you can make sure that you you have a statistically representative set of data 267 00:41:42.000 --> 00:41:45.000 I mean, I guess one of the things I'll just add 2 things briefly. 268 00:41:45.000 --> 00:41:55.000 One is that incremental sampling has been used for years in the identification of trace elements and geologic units. 269 00:41:55.000 --> 00:42:04.000 I mean, it's designed to find things. It's not designed to hide things So so, you know, just think about how that That's how the mining industry finds. 270 00:42:04.000 --> 00:42:08.000 trace elements. Another thing to think about as well. What's the alternative? 271 00:42:08.000 --> 00:42:17.000 I. It's pretty hard to develop a sampling grid with discrete samples that are going to find the kind of hotspot or elevated concentration that you're concerned. 272 00:42:17.000 --> 00:42:20.000 Iss gonna mess. So you can have very small decision units. 273 00:42:20.000 --> 00:42:23.000 You can have decision units. There are 2 feet by 2 feet. 274 00:42:23.000 --> 00:42:27.000 You've done it before you can have, you know, large decision units that can. 275 00:42:27.000 --> 00:42:39.000 Then you can go back and subdivide them into 4, 6, 8, 16, smaller decision units. 276 00:42:39.000 --> 00:42:42.000 Yeah, like you, said Jason. You think about it same way. 277 00:42:42.000 --> 00:43:12.000 You would collect and grab samples. You know you, You kind of know where you suspect your source to be, and you size, your decision units and locate them in in such a way to to collect the information in your You're trying to collect and I thought you hit on a great point that it was one 278 00:43:16.000 --> 00:43:20.000 That's a great analogy time when planning for Ism. 279 00:43:20.000 --> 00:43:24.000 What do you need to do to appropriately plan for the intended use of data? 280 00:43:24.000 --> 00:43:34.000 Or who do you need to include in in the planning process, Todd? 281 00:43:34.000 --> 00:43:45.000 yeah, So I I Yes, as you've all heard here today, you know, the planning process is a critically important part of what we're what the program is all about. 282 00:43:45.000 --> 00:44:05.000 and it takes the whole group from your your stakeholders of folks that are going to use the data, whether that be your regulators or other third parties that might be involved in in you know, using or understanding the data your project team You know how are you going to collect the data who's going to collect it what 283 00:44:05.000 --> 00:44:07.000 are What are the skill sets that are needed, you know? 284 00:44:07.000 --> 00:44:11.000 Is this going to be in in water or on land collection? 285 00:44:11.000 --> 00:44:17.000 So, getting your project team involved getting the laboratory involved early in the process is critical. 286 00:44:17.000 --> 00:44:22.000 A lot of people don't really think about that. You know they consider I'm going to collect some samples. 287 00:44:22.000 --> 00:44:39.000 I'll just send it off, to you know Mark, at the lab and have him analyze it, and there are certain key aspects that need to be understood by the laboratory and the laboratory can really help you plan you know, how much sample is needed where it gets shipped and as well as in what 288 00:44:39.000 --> 00:44:51.000 condition? What type of containers, and also letting them know in advance, because it's not a easy process to analyze or process an ism system, also getting your risk assessors and your statisticians. 289 00:44:51.000 --> 00:45:09.000 Involved early in the process another group of folks that we sometimes go to at the last minute, saying, Hey, I really need this data, you know, analyzed or validated getting them involved early, and helping getting their use and their their specialties to help, you plan the process is critical and making sure that 290 00:45:09.000 --> 00:45:29.000 you're collecting the right number of increments that the data you're going to get can be supported through statistics, and the risk assessors give a a a real hard look at what questions are trying to be answered and will that data right. 291 00:45:29.000 --> 00:45:38.000 we, we do tend to forget about our risk, assessment till the very last minute, and on my side of my project, I was describing as a geologist. 292 00:45:38.000 --> 00:45:53.000 I never would have thought about it. But my my eco-risk assessor knew what the test organisms were going to be for the Ecot risk, assessment and pointed out to me that one of them lives at the water sediment interface the other is a a 293 00:45:53.000 --> 00:46:12.000 burrowing critter. So I had to set up my incremental sampling methodology, not only plan wise but depth; wise to be able to address both of those questions or What was gonna happen to to either one of those test organisms. 294 00:46:12.000 --> 00:46:19.000 yeah. And as a risk, Assessor Thanks Tom. For pointing out the exposure area for different receptors. 295 00:46:19.000 --> 00:46:37.000 And that is something that we want to help you design within your ism studies to make sure that the exposure area is appropriate for the sampling. 296 00:46:37.000 --> 00:46:43.000 Thanks Karen. We have another question regarding sampling to increase confidence in DC. 297 00:46:43.000 --> 00:47:08.000 In discrete sample data. Would it not be common sense to have a discrete sample process to lab Following Itrc Ism process designed to provide mean value for the sample in the jar, an email 8 ounce soil jar can have significant grouping and segregation. 298 00:47:08.000 --> 00:47:16.000 Yup, I'll speak to that one We, on a few occasions have had clients. 299 00:47:16.000 --> 00:47:28.000 Request ism processing on discrete samples, and yes, it does improve representativeness of that analytical subsample, when done appropriately. 300 00:47:28.000 --> 00:47:33.000 but it's rarely requested, but certainly could be done. 301 00:47:33.000 --> 00:47:44.000 usually our clients that are most interested in representativeness and reproducibility, also go to the additional effort of actually collecting the sample. 302 00:47:44.000 --> 00:48:11.000 Using an ism process in the field, in in short, just digging out any a random spot, keep end up with significant heterogeneity and high variability results, trying to start a sample and jar helps a little bit, but going to full ism processing significantly improve improves 303 00:48:11.000 --> 00:48:13.000 right, and and you can mix that 8 out store all you want. 304 00:48:13.000 --> 00:48:19.000 But if they pick the bad spot to grab the sample, it doesn't matter. You know. 305 00:48:19.000 --> 00:48:20.000 Representatives. Now, if you're sampling crew doesn't mix that grab sample appropriately in the field. You know, if it gets shook up on the way to the lab and it segregates and mark I hate to say but sometimes you know an analyst will just grab a scoop 306 00:48:20.000 --> 00:48:34.000 reproducibility. 307 00:48:34.000 --> 00:48:35.000 off of the top of a jar instead of yeah, trying to make sure they get a representative scoop and your own analyzing a small bit all that stuff can really screw up your results, And you're based on a lot of money. 308 00:48:35.000 --> 00:48:36.000 Yeah. 309 00:48:36.000 --> 00:48:52.000 Errors. Random test Allo from an 8 ounce jar is no more representative than a random test. Alloc quote unprocessed ism sample 310 00:48:52.000 --> 00:48:56.000 Interesting Point: Thanks for talking to that one, we have another question in the chat. 311 00:48:56.000 --> 00:49:02.000 One thing I run to is that if your isom sample comes back exceeding a, limit then you have to clean up the whole. 312 00:49:02.000 --> 00:49:14.000 Do you? Is it legitimate to go back and subdivide it to you? 313 00:49:14.000 --> 00:49:22.000 and I'll start with that one and definitely. It is legitimate to divide up the d you and resample. 314 00:49:22.000 --> 00:49:27.000 I had a case where we did have in this case. 315 00:49:27.000 --> 00:49:34.000 It was pahs, and it was a larger decision unit which came back above our screening levels. 316 00:49:34.000 --> 00:49:49.000 So we did go back, and subdivide it into 4 separate smaller sampling units, and we were able to have tighter data and all of the data then were below the screening level and No cleanup. 317 00:49:49.000 --> 00:49:50.000 Was needed. All another alternative is that you narrow your you refine your spatial characterization of the elevated area. 318 00:49:50.000 --> 00:50:20.000 And if you set up a do you and didn't like the data, can can you even start over 319 00:50:22.000 --> 00:50:28.000 Thanks Karen. 320 00:50:28.000 --> 00:50:33.000 Well, I just want to clarify a little bit. Here is that you know, if you don't like your data, I mean, the data is data. 321 00:50:33.000 --> 00:50:54.000 I think that Ism. You can have a lot more confidence in your ism sample, The more increments you collect, and the more replicates you collect and The small area that you Collect them from So I think if you think about in theory the way is and works, if you had one large decision, unit i'm 322 00:50:54.000 --> 00:51:02.000 just gonna use broad numbers here with a 100 increments, And he went back to and split it into 4, and each of those only did 25 increments. 323 00:51:02.000 --> 00:51:07.000 You should get the same result. The average from those 4 should equal the average for the above. 324 00:51:07.000 --> 00:51:20.000 But if you go back and you split those 4 into 100 increments each now you've in essence turned your new initial decision unit that was with a 100 increments into 4 increments the total 400 increments. 325 00:51:20.000 --> 00:51:46.000 So you get a lot more confidence in that data. Likely you will find where the contamination is in terms of if you're confidence is lower, until you're over an action level with your First, sample it might be, because your confidence interval is much higher because you had 2 few increments 326 00:51:46.000 --> 00:51:53.000 Yeah, and and Jason, thank you for for mentioning that, and I I will just reiterate all too often. 327 00:51:53.000 --> 00:52:00.000 People think of decision, as I'm going to go out and sample, I'm going to get an answer, and that's going to tell me if I need to clean up or not. 328 00:52:00.000 --> 00:52:07.000 Well, I would like to put out there. That is that really the question you're asking a lot of these decision. 329 00:52:07.000 --> 00:52:14.000 Units are are helping us define where we have impacts, and your decision might be okay. 330 00:52:14.000 --> 00:52:18.000 I I've selected a decision unit. I get an answer. 331 00:52:18.000 --> 00:52:22.000 What I'm really trying to determine is, do I need more data? 332 00:52:22.000 --> 00:52:26.000 So yes, it's absolutely appropriate to go back and take a decision. 333 00:52:26.000 --> 00:52:35.000 You know that has a single unit value result. And then further divide that into certain areas and identify new smaller decision. 334 00:52:35.000 --> 00:52:38.000 So yes, that's appropriate. But I also agree with Jason. 335 00:52:38.000 --> 00:52:42.000 We just shouldn't throw out all data. You know that data. 336 00:52:42.000 --> 00:52:49.000 That data is representative, and it should be considered as we move down the road. 337 00:52:49.000 --> 00:53:03.000 thanks Todd. And just if we could squeeze in one last question I was wondering, Tamara, if you have a second, do we have to collect or The The question is, do I have to collect? 338 00:53:03.000 --> 00:53:13.000 I highly recommend it. Yes, because you can't compare, and and I have some Ucl to discrete background data. 339 00:53:13.000 --> 00:53:31.000 There's no way to do that, I mean, you could do something semi quantitative If you go out and you do, you is, and program in your you know way below the published background range on sort of a qualitative level you might be being locked. 340 00:53:31.000 --> 00:53:36.000 But you you can't really compare them into apples and oranges. 341 00:53:36.000 --> 00:54:06.000 So I really do recommend that you see one or more background decision units, and also, if you look in the guidance, you will see that those decision units don't necessarily have to consist of one continuous area you can create decision units from sort of a cobble together background range and sometimes that's 342 00:54:08.000 --> 00:54:14.000 Thank you so much, Tamra. That being said, I think we're gonna start wrapping things up. 343 00:54:14.000 --> 00:54:25.000 I just wanted to say again, Thank you so much for all of our trainers, for all of your time and efforts, putting together this guidance and this training, and for your participation today all of you left. 344 00:54:25.000 --> 00:54:28.000 Online Thank you so much for your compelling great questions. 345 00:54:28.000 --> 00:54:33.000 We really appreciate those, and taking your time out of your busy schedules to join us today. 346 00:54:33.000 --> 00:54:42.000 That being said, we do offer archives of our classes, so you'll far, if you are unable to join any of our future offerings, make sure to visit Cluin. 347 00:54:42.000 --> 00:54:49.000 You can, visit and access any of our archives there. Also, you can visit our website to fill out our feedback form. 348 00:54:49.000 --> 00:54:55.000 That's your opportunity to receive a certificate of completion to let folks know that you participated in this course today. 349 00:54:55.000 --> 00:54:58.000 with that said on behalf of it, Orc. 350 00:54:58.000 --> 00:55:02.000 I and everyone on the training today. Thank you so much for your time. 351 00:55:02.000 --> 00:55:09.000 We really appreciate all your questions and your energy this afternoon 352 00:55:09.000 --> 00:55:14.000 Devin such car at it, or she just dropped in the feedback form into the chat. 353 00:55:14.000 --> 00:55:21.000 So those of you interested in receiving that certificate of completion, please follow that outward link and complete that feedback form. 354 00:55:21.000 --> 00:55:51.000 Make sure to check the box at the very bottom of the page, signifying that you did participate in the course today.