It seems that when most things in life turn out great, they start with a great plan. Sure, there are some spontaneous moments in life that we prize as some of our most memorable — but, when it comes to implementing complex environmental monitoring programs, nothing should be unplanned. And the design and execution of the plan are key.
The Goals: Two primary goals of any environmental monitoring plan should be to:
- generate high quality, reliable data that is useful for evaluating trends and/or meeting compliance objectives; and
- assure that the data is legally defensible.
Many Variables Can Impact the Data: That being said, a great monitoring plan must recognize the multiple variables that can potentially impact data quality during the sample collection, sample handling, and laboratory analytical processes. Therefore, the Project Manager should design the plan to limit these variables. And obviously, the proper execution by the field team is also critical. The following provides just a few of the variables we consider when developing a monitoring plan:
- Quality Assurance/Quality Control Samples: These vary considerably based on the regulatory program and sample type. QA/QC samples are often considered a waste of money by some, but they can be priceless when unexpected or inconsistent data shows up on the laboratory report.
- Analytical Method Selection: Methods matter! Analytical methods are designed for specific applications. Analytical laboratories can’t know what method is best suited for your samples and sampling programs unless you tell them. The wrong analytical method can result is data being rejected by a regulatory agency or provide reporting limits that exceed your regulatory limits.
- Analytical Laboratory Selection: Not all laboratories are created equal, and many are specialized toward a specific type of analytical work. We have decades of experience working with analytical laboratories in our service area and throughout the country to recommend the best choice for your monitoring program.
Training and Process Matter: To ensure that great monitoring plans are implemented as planned, you need experienced field scientists with the right training and the right equipment. Brickhouse Environmental has been successfully using this formula for decades on small to very large environmental compliance monitoring projects. The types of clients/industries that rely on our environmental monitoring services include landfills (active and closed), wastewater treatment facilities, brownfield redevelopers, mining and manufacturing.
Considering the Big Picture: Environmental monitoring data cannot be viewed in a vacuum. It’s not enough to provide the highest quality environmental monitoring data; it is the interpretation of the data (while considering the big picture) that is also critically important. This is especially true when a client is faced with a Notice of Violation (NOV) or unusual data that may or may not indicate a more significant problem. All factors that may potentially affect monitoring results must be considered from the office to the field and from the laboratory. Again, here are just a few examples of how we consider the big picture when evaluating environmental monitoring data:
- Always on the Lookout: Our project managers and field crews are degreed scientists that understand the natural and manmade systems that we monitor. All project managers and field scientists are asked to observe and consider all conditions that may affect monitoring results as they collect environmental compliance data from the field and evaluate laboratory analytical data. This is especially important at dynamic project sites such as landfills, active brownfield redevelopment projects or mine reclamation sites. A consistent trained scientific eye in the field can provide important information from the changing project site that can help explain unexpected environmental monitoring data.
- Everything is Connected: It’s not just a sample from a well or a stream, it’s a sample from an aquifer system or a stream network that can be affected not only by the project site but the lands that surround it. When evaluating environmental compliance information, it’s very important to consider all factors that can affect manmade systems, the surrounding natural systems and understand the interactions between them.
Keeping You Out of Trouble: When unusual monitoring data and outliers can’t be explained by site conditions, we question it. While Brickhouse Environmental and our chosen environmental testing laboratories do all we can to ensure accurate field and laboratory monitoring data, mistakes and other outside factors can negatively affect data quality and accuracy. The monitoring plans we prepare and implement include robust quality assurance/quality control measures that allow us to assess the validity and accuracy of field and laboratory derived monitoring information. Through detailed data review and assessment, we have discovered and corrected laboratory reporting errors that had the potential to result in costly recollection, costly regulatory interactions and non-compliance violations. We have also succeeded in having NOVs rescinded by questioning data collected by regulators.
If you are responsible for a project site that requires environmental compliance monitoring, I hope your chosen environmental professional or analytical laboratory is giving your monitoring program and monitoring results the attention they deserve. If you’re unsure, it’s worth your time to reach out to us to discuss your monitoring program and associated challenges.
“Brickhouse Environmental has been providing field services for our facility since the 1980’s. Their extensive knowledge of federal, state and local regulations, coupled with their ability to adapt to new regulations and requirements give us peace of mind that our compliance sampling and reporting is being conducted with professionalism and integrity.”
