Managing the budget is an important aspect of any project, and with Performance Based Contracts (PBCs), it is critical. PBCs offer greater opportunities for technical innovation and efficiency but can also pose financial risks. In a previous article, we discussed what your laboratory needs to know to provide you with the most accurate pricing for your project. In this article, we focus briefly on questions you should be asking of your team and actions you can take to help manage your budget, streamline your work, and increase client confidence.
At what stage in the Superfund process is your project? Have Contaminants of Potential Concern (COPCs) or Contaminants of Concern (COCs) been identified? Once a Record of Decision (ROD) has been issued, site characterization has been performed, and your contaminants have been determined.
Ideally, you identified your intention to evaluate only COCs during the proposal stage of your project. Your contract award and approval of your project plans subsequently indicate client and possibly regulatory approval of this approach. Alternately, client approval can be confirmed during scoping sessions.
If analyses for parameters other than COCs are planned on a new or on-going project, why?
It is prudent to discuss changing to COC-only analysis and reporting with clients and regulators, but push-back on ROD-compliant actions is rare. Unless there is a compelling reason to perform or continue performing analyses for non-COCs, there is no ethical or legal reason to do so.
Clients are usually receptive to simplifying approaches. If you are managing an on-going project or taking over an existing project, an historical data review may be prudent. Common laboratory contaminants sometimes show up as COCs. Contaminants that have been remediated may be listed. A thorough review of historical data can identify such parameters and determine if removal from the COC-list is appropriate. This requires formal approval from the client and regulators, but it is not usually an onerous task when taken on by personnel with experience evaluating and interpreting analytical data. It is even possible that parameters that are naturally occurring but exceed Federal action levels are listed (example: arsenic in the Western United States). In such cases, identifying background studies for your client or proposing to your client that one be designed and executed is prudent.
If you are conducting site characterization, your work is key to identifying appropriate COCs. Is site history known? Are you narrowing your focus on contaminants that are reasonably expected to be present or are you taking a “let’s do everything” approach? If the latter, is there a compelling reason to do so? Are there data gaps or suspected historical activities? If not, why do what is not needed? Do background studies exist for the site or region? Should you propose one?
Meetings with clients and regulators may be needed to streamline your analytical parameters, and formal approval may be needed, but these discussions show that you are attending to the details of the project rather than going through the motions. Asking your laboratory to reduce your analyte list only to those parameters that are meaningful to your project is a scientifically sound, ethical way to reduce not only analytical costs, but also reduce internal costs by streamlining data review, interpretation, and reporting.