United States
             Environmental Protection
             Agency
            Office of
            Solid Waste and
            Emergency Response
   oEPA
DIRECTIVE NUMBER: 9345.1-1

TITLE: DRAFT—SITE INSPECTION SAMPLING STRATEGY TO SUPPORT
      HRS SCORING
             APPROVAL DATE: JAN- 7, 1986

             EFFECTIVE DATE:

             ORIGINATING OFFICE: OERR

             D FINAL

             ID DRAFT

               STATUS: c" FOR REVIEW AND COMMENT



             REFERENCE (other documents):
OS WER      OS WER      OS WER
:.,  DIRECTIVE    DIRECTIVE   Dl

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United States Environmental Protection Agency
^ Washington. DC 20460
^!>EPA OSWER Directive Initiation Request


Originator Information
Name of Conjact Person
Lucy Sioold
Lead Office
Q OERR . •
D OSW
D
D
D
OUST
OWPE
AA-OSWER

Mail Code
WH-548-E .
Approved
Interim Directive Number
9345.1-1
,
Telephone Number
382-2454
for Review
Signature of Office Director
Date
 Title
          DRAFT  Site  Inspection  Sampling  Strategy to Support  HRS  Scoring
 Summary of Oireciive
        Guides  the SI  team in  developing  a sampling plan  that leads to  an  appropriate
        HRS  score for  the  site.   Describes some relevant  selective characteristics of
        the'HRS  and  how J;hese  characteristics  affect where to collect samples.
 Type of Directive {Manual. Policy Directive. Announcement, etc.)
    Guidance
                                    Status
                                           Draft
                                           Final
                                       C3 New
                                       I—I Revision
                  No   Doe's It Supplement Previous Directive(s)?
Does this Directive Supersede Previous Oirective(s)?
 f "Yes" to Either Question. What Directive (number, title)
Review Plan
   O AA-OSWER   D OUST
   (3 OERR        O OWPE
   LJ OSW        HI Regions
CH OECM
0 OGC
D OPPE
D
Other fSpeci/yJ
 'his Request Meets OSWER Directives System Format
Signature of Lead Office Directives Officer
                                                   Date
Signature of OSWER Directives Officer
                                                   Data
EPA Form 1315-17(10-85)
                                                                                                          ..jot

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                                              OSWER Directive Number  9345.1-1
%PRO^
               UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                          WASHINGTON, D.C. 20460
                               JAN -7 1986
MEMORANDUM

SUBJECT:  Comment on Draft Sampling Strategy
          Scoring
                                                           OFFICE OF
                                                  SOLID WASTE AND EMERGENCY RESPONSE
    FROM:
    TO:
          Henry L. Longest II, Directo
          Office of Emergency and Remed
                                                    Support HRS
                                                 Isponse
          Director, Office of Emergency and Remedial Response
                    Region II
          Director, Air & Waste Management Division,
                    Regions III, IV, VI, VII, & VIII
          Director, Toxics & Waste Management Division
                    Region IX
          Director, Hazardous Waste Division
                    Region X

     Attached is a draft strategy for how to select appropriate
sampling locations during a Site Inspection (SI).  We would
appreciate your review and comments on this guidance by February  15

     I feel very strongly about the need for this guidance.  Our
quality assurance review of Regional and State PA/SI programs and
discussions with Regional and FIT staff suggests many of the Si's
that have been done by States and FIT fall significantly short of
the goal of developing data to support a valid HRS score (for NPL
eligible sites).  It appears that a series of Si's occur before a
valid HRS score is developed.  It is my firm conviction that with
proper background data collection and rigorous application of this
sampling strategy at the first SI, the quality and usefulness of
the first SI will improve.  In addition, this should substantially
reduce the number of times when it is necessary to revisit sites,
which ultimately will reduce the time between when a PA is
performed and when a valid HRS score is developed.

     If you have any questions on this guidance, please call
Lucy Sibold of my staff at 8-382-2454.
   Attachment

   cc:   Don  Smith
         Rick Spear
         Perry  Katz
         Butch  Byer
         Jon  Johnston
         Tom  Yeates
         Debbie Flood
                           Steve Ostradka
                           Keith Bradley
                           Jo Johnson-Ballard
                           Gale Wright
                           Shelly Brodie
                           Dave Schaller
                           Jeff Rosenbloom

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                                       OSWER Directive 9345.1-1
                                       DRAFT
    SITE INSPECTION SAMPLING STRATEGY
                 FOR
SUPPORTING HAZARD RANKING SYSTEM SCORING
            December, 1985
   Discovery and Investigatioh Branch
Office of Emergency and Remedial Response
  U.S. Environmental Protection Agency

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                                                         OSWER Directive 9345.1-1
                   SITE  INSPECTION SAMPLING STRATEGY
               TO SUPPORT HAZARD RANKING SYSTEM SCORING

                          "TABLE OF CONTENTS

                                                                PAGE


1.0      INTRODUCTION                                             1

2.0      SI SAMPLING STRATEGY PRINCIPLES                          3

         2.1  Target Samples to Maximize Population Exposed       3
              or Proximity to a Sensitive Environment

         2.2  Collect Sufficient Background to Preclude          13
              Contributions from Other Sources

         2.3  Minimize On-Site Sampling                          14

         2.4  Set Priorities for On-Site Samples                 16

         2.5  Demonstrate that a Release has Occurred            16

         2.6  Sample for Air Releases                            17

3.0      FICTICIOUS CASE HISTORY                                 18

4.0      CONCLUSION                                              22

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                                                        -OSWER Directive 9345.1-1
                   SITE INSPECTION SAMPLING STRATEGY
               TO SUPPORT HAZARD RANKING SYSTEM SCORING

                                TABLES

                                                               Page



Table 1      Maximum Target Distance foe Each HRS Route          4
Table 2      Application of Sampling Principles to Sampling     21
             Points Identified in Figure 7

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                                                          OSWER Directive 9345.1-1
                   SITE INSPECTION SAMPLING STRATEGY
                TO SUPPORT HAZARD RANKING SYSTEM SCORING
                                FIGURES


                                                                Page


 Figure 1   Ground Water  -  Potential  HRS  Exposure                  6


 Figure 2   Ground Hater  Sampling  Strategy                         8


 Figure 3   Surface Hater - Potential HRS Exposure                10


 Figure 4   Air  -  Potential HRS  Exposure                          12

/                                     '   -
 Figure 5   Example HRS Background Samples  for  Ground             15
            Hater  and  Surface Hater


 Figure 6   Air  Monitoring                                        19


 Figure 7   Ficticious Case Study                                 20

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                                                          OSWER Directive 9345.1-1
                   SITE INSPECTION SAMPLING STRATEGY
             TO SUPPORT THE HAZARD RANKING SYSTEM SCORING

1.0 INTRODUCTION

    The site inspection (SI) is part of the Superfund pre-remedial
site evaluation process and serves to fulfill a number of purposes.
The two most important of these are to: 1) understand the potential
threat posed by a site—to the extent possible within the limited
scope of the SI—and 2) to determine the need for further Superfund
activity at a .hazardous substance site.

    For a site to be eligible for Superfund remedial funds it must be
listed on EPA's National Priorities List  (NPL).  The primary way for a
site to be eligible for inclusion on the NPL is determined by
assessing the site's relative risk potential through the Hazard
Ranking System (HRS) model.  The SI is the step in the site evaluation
process which enables the field investigators to collect data to
support the HRS.   This strategy is designed to identify and guide .the
SI team in developing a sampling plan that leads to an appropriate HRS
score for the site.

    It is not the intent of this strategy to suggest limiting sample
collection only to that which is necessary for HRS scoring.  Overall,
Sis should assess potential, immediate, and direct threats posed by a
site (beyond the HRS needs), support emergency response activities,
fulfill public information needs and otherwise provide information on
special site conditions at an early time in the site evaluation
process^.  While doing so, the sampling plan should include those
samples necessary to support HRS scoring.  This strategy is intended
to define only the types of samples needed to properly apply the HRS
to a site.

    The goal of this SI sampling strategy is to provide field staff
with a framework of logic for selecting appropriate sampling points
and to prepare SI sampling plans with a focus on developing data to
support the HRS.   Using this logic will (1) reduce the total number of
samples collected, (2) minimize the number of occasions where sites
need to be jresampled and (3) reduce the total cost of the effort.  In
the past, samples were collected during the SI without full
appreciation of their relevance to the HRS scoring.  Often,
informative data resulted from the sampling effort, yet the data were
    The SI is not an extent-of-contamination study nor a full risk
    assessment study.  These efforts are accomplished during the
    remedial investigation (RI) which is initiated after a site is
    listed on the NPL.
                                  -1-

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                                                          OSWER Directive 9345.1-1
not  useable  in  scoring the site.  At the same time, sampling data
essential  to the HRS scoring were not developed and it was common to
later  revisit the site to collect samples to develop the appropriate
HRS  score.   Proper understanding of the HRS and some of its basic
characteristics will reduce the number of unnecessary samples and the
need to  revisit sites for additional samples.  It will also minimize
the  number of false negatives—that is, samples taken at sites that
may  threaten health and the environment but which, due to inadequate
planning,  do not produce a score reflective of the site's risk.
Overall  this strategy will shorten the time and reduce the cost
required to  evaluate the.site for its eligibility for remedial funds.

     To plan  SI  sampling it is important to understand the
characteristics of the HRS.  Prior to undertaking an SI the person
preparing  the sampling plan should develop an initial HRS score.  This
initial  HRS  score will identify data gaps and, therefore, indicate
where  sampling  and other information is needed to strengthen or
further  substantiate the HRS score.

     As a general rule, the HRS score developed for a particular site
should accurately represent the site's conditions, rather than a score
which  just clears the NPL eligibility HRS score of 28.50.  Although
the  scores are  not necessarily a true measure of risk at each site,
they are useful for understanding the relative risk of a site compared
to others.   A legitimately high scoring site should list high on the
NPL.   Although  EPA can initiate remedial action at lower scoring
sites, higher scoring sites may receive higher priority for the next
phase  of activity.

 ..   Because  one of the primary objectives of the SI is to support the
HRS, the sampling strategy differs from traditional approaches to
environmental sampling.  Traditional approaches usually emphasize the
collection of samples which represent.the average contamination in the
nearby environment.  For effective HRS scoring, it is important to
.show releases to the environment.  To verify these releases, samples
which  are  representative of the released materials rather than of the
general  environment should be collected.  Samples representative of a
.release  are  those which demonstrate hazardous substance migration from
.the  site.  For  example, it would be more productive to collect a
sample at  the surface of a body of water if the constituent of concern
is less  dense than water and tends to float on the surface.  More
traditional  sampling approaches might suggest that a sample be taken
over the entire depth of the stream rather than the surface.  Taking a
sample at  the surface would document a release rather than describe
the  average  environment.

     The  following section presents the strategy for identifying
samples  which will optimize HRS site scoring.  The strategy is
presented as a  set of sampling principles.  These principles are
                                  -2-

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                                                          OSWER Directive 9345.1-1
 intended to guide the  development  of  a  sampling plan.   In  the
 subsequent section,  a  ficticious case history  is  also presented which
 demonstrates how the principles might apply  in developing  an SI
'sampling plan.

.2.0 SI  SAMPLING  STRATEGY PRINCIPLES

     There are six principles  which should be considered when planning
 SI  sampling activities.  These six SI sampling strategy principles are:

          Principle 1:   Target Samples  to Determine Maximum Population
                        Exposed or Proximity to a Sensitive Environment

          Principle 2:   Collect Sufficient Background to Preclude
                        Contributions from other  Sources

          Principle 3:   Minimize On-Site Sampling

          Principle 4:   Set Priorities  for On-Site Samples

          Principle 5:   Demonstrate that Release  has Occurred

          Principle 6:   Sample for Air  Releases

 Each of these is presented with relevant applications.  Taken
 together,  these  principles provide the  framework  for a  more detailed
 site-specific sampling plan.

 2.1      Principle One:  Target Samples To Determine Maximum
          Population  Exposed or Proximity to  a  Sensitive Environment

     There are two characteristics  associated with the HRS  that
 significantly influence the score  of  a  site.   First, for a site to
 score at all on  a particular  migration  route,  a target  population or
 environment must exist within a specified maximum distance of the
 facility.   Second, within that target distance, the site progressively
 scores  higher the closer the  target receptor is to the  facility..  In
 CERCLA,  the definition of "facility" means any place where a hazardous
 substance is placed  or comes  to be located.  This means that the
 "facility"  includes  the site  where waste was stored or  disposed plus
 any off-site contamination attributable to the site.  Therefore, even
 if  the  target population is a considerable distance from the site, it
 can be  within the maximum target distance from the place where the
 site's  waste comes to be located.  In effect,  the off-site
^contamination extends the facility's  boundaries and may bring within
 'the scoring range, a target population  or sensitive environment.  As
 discussed in the introduction, this underscores the need to know in
 advance of  conducting field activities, the  location and proximity of
.target  populations and environments.  Table  1  presents, for each HRS
 contaminant migration route,  the maximum distances within  which each
 target  must reside in order for it to score  for that route.
                                  -3-

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                                                         OSWER Directive 9345.1-1
         Table 1.   Maximum Target Distances For Each HRS Route
    HRS ROUTE
    Ground water
    Surface water
    Air
       TARGET

Population served as water
supply or irrigated land.

Population served as water
supply or irrigated land
  . Downstream
  . Static water body

Sensitive environment
  . > 5 acre coastal wetland
  . >. 5 acre freshwater
    wetland
  . Critical habitat of an
    endangered species or a
    National Wildlife Refuge.

Population in vicinity

Sensitive environment
  . > 5 acre coastal wetland*
  . 2. 5 acre freshwater wetland*
  . Critical habitat of an
    endangered species.**

Land use
  . Commercial/industrial area
  . National/State park, forest
    or wildlife reserve
  . Residential area
  . Agricultural land in pro-
    duction in past 5 years
     - Average land
     - Prime land
  . Historic or landmark site
MAXIMUM TARGET
  DISTANCES

 3 miles
                                                      3 stream miles
                                                      1 mile
 2 stream miles

 1 stream mile


 1 stream mile

 4 miles
                                                      2 miles
                                                      1 mile

                                                      1 mile
                                                      1 mile

                                                      2 miles
                                                      2 miles
                                                      1 mile
                                                      2 miles
                                                      within view
*   Wetland is defined by EPA in 40 CFR Part 230, Appendix A, 1980

**  Endangered species are only those designated by the U.S. Fish and
    Wildlife Service.
                                 -4-

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                                                         OSWER Directive 9345.1-1
    There may be a trade-off to undertaking sampling to identify how
close the facility's off-site contamination is to the target.  The
farther away the sampling is from the site, the less likely
contaminants will show up above detection limits.  Therefore, sampling
farther away is more uncertain.  Also, the more distant the samples
are from the site, the greater the possibility that alternative
sources of contaminants could interfere with producing definitive
results.  However, if sufficient analytical resources are available,
it may be cost-effective to add an additional sample(s) to better
understand the extent of off-site contamination and accordingly help
develop the proper HRS score.

    The following discussion demonstrates the impact and application,
of this principle to each of the HRS migration routes.

Ground Water

    The focus of sampling ground water should be to tie in a potential
ground water target population to the site.  The target population is
defined as the number of individuals who live, work, go to school or
others who would regularly use the water within a three-mile radius of
ground water contamination attributable to the site being
investigated.  Figure 1 illustrates the types of populations that may
be considered targets via ground water migration.

    The ground water, surface water and air targets are each handled
differently in the HRS and accordingly, these differences affect how
one would select where to sample.  In the HRS scoring for ground water
migration, the population served? by wells within three miles is
combined in a matrix with the distance to the nearest well.3  In
many cases the nearest well may not be the source of water for the
majority of the population served within three miles.  For example,
the nearest well may serve one person one mile away while a large,
municipal well may serve thousands of people two-and-a-half miles
away.  These two factors are evaluated separately before they are
combined in a matrix for a score assignment.  In evaluating the
    The "population served" need not be located within three miles of
    the contamination, but must receive their drinking water from a
    ground water source located within the three miles.  This point is
    illustrated in Figure 1 by the factory, the city and the irrigated
    land.

    To be considered in the HRS the "nearest" well must be either a
    drinking or irrigation well.  Monitoring and industrial wells are
    not considered.
                                  -5-

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                             Figure 1.  Ground Water - Potential MRS Exposure
PRIVATE HOUSES
   (3.8 Person* per Hou»«
                        FACTORY  (Total Stall)
                                                                                      IRRIGATED LAND
                                                                                        Parsons per Acre)
                                                                                      KEY:

                                                                                      0 Contaminated well attributed to site
VO

(Ji
•
r

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                                                          OSWER Directive 9345.1-1
 nearest well and the population served, both of these must be within
 three miles of the nearest point of contamination for the factors to
 "score" at all.

     To apply this to identifying sampling points for ground water,
 first locate the nearest well and other wells serving the largest
 population.  If these wells are more than three miles away from the
 facility, draw a three mile radius around the wells.  Next, select
 ground water sampling locations that are within three miles of the
 wells and in the direction of the source site.  The samples should be
 located either at the wells or between the site and the wells.
 Figure 2 graphically depicts this approach.  It is worth noting that
 this approach will work most often for wells that are downgradient of
 the site.  Upgradient wells and samples are not as likely to show
: detectable levels of contaminants unless (1) the well has a sizable
 drawdown to influence gradient flow or (2)  the well is inside the
/three-mile cut-off radius.  If contamination is found, at the sampling
 location, the wells are considered within 3 miles of the "facility"
 and could be included in HRS scoring.

     It is also noteworthy that in the HRS,  the shorter the distance to
 the nearest well, the higher the score for  that factor.  However, the
 same does not apply to the distance to the wells serving the majority
 of the population.  The site's score does not increase by further
 reducing the distance to the well(s) serving the majority of the
 population.  This means that sampling to determine if contaminants
 have migrated even closer than three miles to the nearest well, may be
 worth the effort.  Sampling to determine if the distance between the
 contamination and the well serving the majority of the population is
 less than three miles is not worth the effort (for HRS data collection
 purposes).4  The thresholds in the HRS model at which the score
 changes for the distance to the nearest well, are:

          three miles

          two miles

          one mile

          .38 miles (2000 feet).

     It is important when sampling ground water to have a general
 understanding of the local hydrogeology.   Often, there are two or more
 aquifers that are used in the same area.   Depending upon the
     It is worth restating here that though it may not be of any
     particular value to collect a certain sample for the purpose of
     scoring a site, it may be of value in evaluating the site for
     emergency response or to better understand the threat posed by a
     site.
                                   -7-

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                                                     OSWER Directive 9345.1-1
                 Figure 2.  Ground Water Sampling Strategy
PREVAILING
GROUND  WATER
FLOW
                SITE
                                                       NEAREST WELL
                                   MUNICIPAL WELL
                      3 MILES
                                                    SAMPLING STRATEGY

                                                    1  IDENTIFY TARGETS

                                                    2  DRAW 3-MILE RADIUS

                                                    3  SELECT SAMPLING POINT
                                -8-

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                                                          OSWER Directive 9345.1-1
 population  using  each  aquifer,  the aquifers  can  produce  significantly
 different scores.   Thus,  prior  to sampling,  each aquifer needs  to be
 evaluated separately to determine which  aquifer  will  yield  the  highest
 MRS  score.  The highest scoring aquifer  is likely to  be  the one
 serving  the greatest population within the maximum target distances
 and  the  one having  the nearest  well.   This is  referred to in the HRS
 as the "aquifer of  concern".

 Surface  Water

     The  objectives  and rationale of surface  water sampling  are  similar
 to ground water except that the target is not  limited to population
 served but  also includes  sensitive environments.   In  the surface water
 route it is possible to tie in  a target  population that  is  more than
 three miles downstream from the site  (source of  disposition), if it
 can  be established  that contamination from the site has  migrated to
 within three miles  of  the target.   As with the ground water route, the
 facility boundaries are,  in essence,  extended  to the  point  of
 contamination.  To  apply  this to surface water,  first, search for
 potentially exposed human populations, critical  habitats and National
 Wildlife Refuges.   Second, go back three miles from the  target  along
 the  migration route and then select a sampling point  just within those
 three miles.

     When sampling along the surface water route,  careful consideration
 should be given as  to  which phase of  the surface water route should be
 sampled—the aqueous phase or sediment phase.  This decision depends
 upon the physical properties of the most toxic,  persistent  and  mobile
 compounds handled by the  facility. Certain  compounds are more  likely
 to be found in sediment than the aqueous phase.

     Table 1 indicates  the three categories of  sensitive  environments
 which are considered by the HRS.   These  are  both coastal and fresh
 water wetlands  (five acres or larger)  and critical habitats of  an
 endangered  species  or  a National Wildlife Refuge.  The maximum
 distances these targets may be  from the  site or  from  contamination
 associated  with the site, in order for the target to  score, are also
 indicated in Table  1.   For the  HRS, these distances must be measured
.along the pathway the  contaminants migrate (i.e., stream miles), not
 the  straight line distance.

     Figure  3 consists  of  two examples which  illustrate the  type of
 target receptors  that  may be considered  for  HRS  scoring. Example 1
 indicates sampling  points for a nonstatic surface water  source  (river)
 which serves as a water supply  for a  city and  irrigated  land.   As was
 true for the "population  served"  by ground water, only the  water
 intakes  must reside within the  maximum target  distance not  the
 population  using  the surface water.   Both the  city and the  irrigated
                                  -9-

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                                                               OSWER Directive 9345.1-1
                  Figure 3. Surface Water • Potential MRS Exposure
EXAMPLE 1
                                      RIVER
 IRRIGATED LAND
(1.5 PEOPLE/ACRE )
 (Total Population S«rvoa)
                                        WETLAND
EXAMPLE 2
                          RIVER
                                    PRIVATE HOUSES
                                    3.8 PEOPLE /HOUSE
                                                                         BAY
   KEY:

E       CONTAMINATED SAMPLES
       ATTRIBUTABLE TO SITE
         COASTAL
         WETLAND
                                            -in-

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                                                         OSWER Directive 9345.1-1
land have water intakes within three stream miles of contamination
attributable to the site; the water is used, however, a long way
away.  Example 2 demonstrates sampling points for a static water body
(reservoir) and a coastal wetland.

    Within the three mile cut-off, the score for the population served
increases with decreasing distance between the intake to the probable
point at which the site's contaminants enter surface water.
Therefore, sampling to determine if contaminants have migrated to a
distance less than three miles is useful.  The thresholds in the HRS
model at which the score changes.for the distance to the nearest water
supply intake are:              ~  "

         two miles

         one mile

         .19 miles (1000 feet).

Thus, these radii define three concentric zones of equal scoring
factors surrounding the contamination source.

Air

    For the air route, it is difficult to determine if facility
boundaries are extended to some point off-site because of the
difficulty in measuring air releases.  Site boundaries are sometimes
extended where there is an accumulation of substances off-site
attributable to the site.  Because extension of site boundaries is
rarely possible, the primary goal of air sampling (or monitoring using
portable instruments)  is to show that the material of concern is
released to the ambient air.  If the material is shown to release,
then all targets within a four mile radius of the source can count for
HRS scoring.

    The population potentially exposed to an air release source is
counted as the persons residing within the maximum radius of four
miles, including workers in factories, offices, restaurants, motels or
students, regardless of wind direction when samples are being
collected.  Maximum target distances along the air route to sensitive
environments and other critical land uses can be found in Table 1.
Figure 4 graphically indicates the type of receptors that are
considered in the HRS.  The diagram also shows a situation where there
is a secondary contributing source.  Because this secondary source can
be attributed to the site, targets within a 4 mile radius of this
secondary source can be counted for HRS scoring.
                                 -11-

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                                                            OSWER Directive 9345.1-1
              FIGURE 4.  Air - Potential  MRS  Exposure
                             POPULATION
                                                         LANDMARK OR
                                                         HISTORIC SITE
   COASTAL  WETLAND
PARKS/FORESTS/WILDLIFE
                                                         FRESHWATER WETLAND
                                      WIND DEPOSITED
                                        SECONDARY
                                         SOURCE
\
   \
                                                                        WITHIN VIEW
                                  CRfTICAL HABITAT OF AN
                                  ENDANGERED SPECIES

                                  COMMERCIAL/INDUSTRIAL  AREA

                                  AVERAGE AGRICULTURAL LAND
     \
                                                                         KEY
                                                                  Q  Maximum lirgal
                                                                      radii for primtry
                                                                      aourc*

                                                                  :*~":  Maximum targat
                                                                  "—"  radii (or Meondary
                                                                      •ourc*
                                    -12-

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                                                         OSWER Directive 9345.1-1
    To show that a volatile or particulate substance is releasing,
therefore, sampling or monitoring (using portable monitoring
instruments) should generally be performed on site.  All sampling (or
monitoring) should be conducted in the vicinity of the suspected
source but not next to, suspected sources such as drums, well heads,
leachate pools or contaminated soils.  No disturbance of the site
which would affect sample results is allowable and samples should be
taken in the ambient air and in the "breathing zone".  The "breathing
zone" is defined as the height above the ground where air is normally
breathed by a potentially exposed population.

    The best approach for air route sampling usually requires an
understanding of waste types on-site.  The most air-dispersable
substance (volatile or particulate)  should be identified and sampling
should occur both upwind and downwind.  If there is no wind on the day
sampling occurs, it may be possible for particuilate releases to
collect dust samples from rafters or air vents at locations which are
predominantly downwind of the potential source, in places where no
mechanisms other than air could account for their transport.  Soil
samples generally do not qualify for air sampling since it is possible
that contaminants migrated via foot traffic or other non-air transport
mechanisms.

2.2      Principle Two:  Collect Sufficient Background to Preclude
         Contributions from Other Sources

    In the HRS, it is essential to demonstrate that a release above
background has occurred.  This is done by collecting analytical
evidence which reflects the normal background levels of selected
hazardous substance.  In most cases, these background levels are below
detection limits.  The background samples should be collected
upgradient, upstream or upwind from the source.  Figure 5 shows some
example background sample collection locations.

    As a practical matter, background samples should always be
collected.  However, there are some situations where background
samples may not be necessary.  These include:

         Hazardous waste deposited in the water table,

         Leachate from site observed flowing into creek, or a

         Photograph of a dust cloud from waste piles and of field
         personnel gathering dust samples.

These situations are considered direct evidence of a hazardous
substance release which requires no further evidence of contamination
or background levels.
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                                                         OSWER Directive 9345.1-1
    A second  kind of background sample are those which discriminate
 among alternative sources of the contamination.  Within a given area
 there are  often other possible sources of a particular contaminant.
 It  is important to establish through sampling that at least some of
 the contaminants observed are from the facility of interest.  In some
 cases, where  there is another source, it must be clear that the
 contamination from the facility of interest is in addition to the
 contribution  from the "other" facility.  Figure 5 also shows some
 sampling locations which will discriminate among other potential
 sources.   Traditionally, insufficient attention has been given to the
 collection of background samples, making it difficult to evaluate
 contributions from other sources of the contamination.  The background
 samples that  are commonly overlooked are those needed for every new
 stream entering a river (migration pathway) between the site and
 downstream contaminated samples.  These background samples must be
 collected  to  identify whether there is contamination originating from
 tributary  sources.

 2.3     Principle Three:  Minimize On-Site Sampling

    Under  the HRS, it is essential to establish and document the types
 of  waste handled on the site to determine the appropriate score for
 toxicity and  persistence and for the volume of waste handled on-site.
 In  the absence of the proper documentation, the site may receive a
 score but  it  will probably be lower than it would be with good data.
 This  type  of  information is also important to properly tie the wastes
 handled on the the site to contamination found off-site.  In the past,
 the tendency  has been to take most of the samples on the site.  This
 may not be necessary since often there are existing data showing the
 type  of waste handled at the facility.  Sometimes these data are found
 in  owner/operator records, generator records, permit application data,
 and compliance inspections.  Although analytical data are preferred,
 other records identifying specific contents or constituents of waste
 may be adequate.  For example, there may be well-maintained manifest
 records or other documents which specifically identify the nature of
 the wastes handled on the site.  If these specific data exist, then it
 may not be necessary to sample on the site.  These samples may be
 better applied to establishing off-site releases.  Where waste
.identification data do not exist or are not reliable, then it will be
 necessary  to  sample on-site.

    Old lagoons and decaying bulk tanks are often good candidates for
 sampling.  Samples from visibly contaminated soils in drum storage
 areas are  often more useful and less dangerous than a sample from any
 one of the drums or samples from a number of the drums.

    In cases  where little is known about the site's previous operating
 practices  and no obvious, distinctive "units" exist to sample,
 sampling in the areas where wastes are most likely to collect are more
 likely to  provide information on the type of waste previously
 handled.   These areas might include on-site ditches, pools, sinks,
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                                              OSWER Directive 9345.1-1
Figure 5.  Example MRS Background Samples
     For Ground Water and Surface Water
                                               BACKGROUND SAMPLES

                                               SAMPLES TO DISCRIMINATE
                                               AMONG ALTERNATIVE SOURCES

                                               LETTERS INSIDE SAMPLE
                                               LOCATION MARKERS INDICATE
                                               MIGRATION  ROUTE:
                                                  GROUND WATER
                                                  SURFACE WATER
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                                                         OSWER Directive 9345.1-1
drainage pipes or other similar features.  Random and non-random
composite grid sampling is another approach to identifying the type of
waste handled at a site where little is otherwise known.5  Equal
volumes of samples would be collected from selected grid locations and
then combined and homogenized.  A portion of the sample would be
removed for analysis.  Although precise identification of the location
of contaminants is not possible with this technique, positive results
are indicative of the type of waste handled at the facility.

2.4      Principle Four:  Set Priorities For On-Site Samples

    When selecting what to sample on the site, two characteristics
associated with the waste should be evaluated.  They are:  the
toxicity/persistence of the waste, and the physical state of the
waste.  First, toxicity/persistence of the waste should be
considered.g  Appropriately, the HRS gives greatest weight to the
more toxic and persistent compounds on a site.  Therefore, the focus
of any onsite sampling should be on the more toxic/persistent wastes.
Second, the physical state of the waste should be evaluated.
Ingeneral, all other things being equal, the more mobile the physical
state of waste, ,the higher the value assigned because of its greater
tendency to migrate.  Liquids, gases and sludges score higher than
powders or fine materials.  Unstabilized or unconsolidated wastes
score the lowest.

    Sometimes, these characteristics can conflict with one another.
For example, the most toxic and persistent compounds may be the solids
and unconsolidated wastes.  In this case, it would be appropriate to
evaluate how these characteristics will affect the score for the site
and structure the sampling accordingly.  In the rare situation where
little to nothing is known about the waste, the more mobile wastes—
liquids, gases, sludges, powders and fine materials—should be sampled.

2.5      Principle Five:  Demonstrate That Release Has Occurred

    Sampling should provide direct evidence of a hazardous substance
release via any of the three HRS migration paths potentially
affected.  To do this, a contaminant must be measured at a
significantly higher level than the background level, regardless of
frequency;-  For HRS purposes, the phrase "significantly higher"
relates only to the concentration or amount of material released; it
    Sample compositing should be done only for environmental samples,
    not medium or high concentration samples where reactions between
    non-compatible wastes could harm field investigators or lab
  - personnel.

    For air contaminants, only toxicity and not persistence can be
    evaluated.
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                                                         OSVffiR Directive 9345.1-1
has no bearing on the environmental or health effects of the release.
It "is" not relevant, in determining whether a release has occurred,
that the release is below regulatory recommended action levels.  If
the concentration or amount of a release is significantly above the
concentration or amount in the background, then it qualifies as a
release under the HRS.7

    To show that a release has occurred in each of the media, the
sampling plan should specify, at a minimum, collection of one sample
downgradient and immediately adjacent to the suspected source of
contamination.  For ground water, this would be the closest down-
gradient well that is completed in the aquifer that serves the largest
affected population within 3 miles.  For surface water, this would be
the most probable point at which waste enters the surface water.  For
air, the sample would be collected at a reasonable distance downwind.
These may be the single most important samples for demonstrating
whether or not a release has occurred in the absence of any other
evidence.  These become especially important as the concentrations of
contaminants in samples collected further away begin to fade.  It is
also essential if there is another contributing source.  There must be
a preponderance of evidence that the facility is contributing to the
off-site contamination.

2.6      Principle 6:  Sample for Air Releases

    Determining if there is a release of hazardous substances via the
air route is one of the most neglected factors in sampling, yet it has
the potential for substantially affecting the population and the score
of a site.  At a minimum, during a site visit, air monitoring should
be undertaken for volatile compounds.  The instruments used routinely
for monitoring for personnel safety and protection can, with little
additional effort, be used to evaluate air releases for HRS scoring.
Instrument readings should be taken upwind and downwind of the source
suspected to be releasing.3  The readings should be taken at a
    A release above background is an indication that hazardous
    substances are not being controlled and, if the site qualified for
    the NPL, remedial studies will probably be needed to determine the
    risks involved and appropriate corrective actions.

    .Procedures for air sampling must include continuous monitoring of
    wind direction throughout the monitoring period.  This approach is
    not valid if there is any significant change in wind direction.
    Procedures should also specify collection of air samples or
    monitoring in the breathing zone.
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                                                         OSWER Directive 9345.1-1
reasonable distance from the suspected source.  They do not have to be
taken off-site; however, they should not be taken immediately next to
the source.  Figure 6 graphically depicts this concept.  The source
should not be disturbed by sampling personnel while monitoring for
releases.  For example, drums should not be opened, soils disturbed or
the source tampered with in any way.  It also must be clear that the
releases reported are not methane releases.  Methane is specifically
precluded from consideration under CEBCLA.  Therefore, monitoring
instruments not sensitive to methane or procedures to evaluate whether
the releasing compound(s) is methane should be used.9  The sampling
plan also should specify sampling of the waste to show that it
contains a specific hazardous volatilizing compound.10  This will
further substantiate that the release of measure is a hazardous
compound.11

3.0 EXAMPLE CASE HISTORY

    Figure 7 presents a hypothetical situation where an appropriate SI
sampling strategy is being employed.  Each of the selected sampling
locations is discussed in Table 2 in terms of the SI sampling
principles which were described in the previous section.

    Although the usefulness of one example is limited, the situation
described by Figure 7 and Table 2 clearly demonstrates how these
sampling principles can be combined to prepare a responsive and
efficient sampling plan.  Figure 7 indicates that only 12 samples were
collected.  For other sites, this may not be adequate but will depend
on the specific character of the site.
9    For example, the OVA has a carbon filter diversion feature or
     carbon filter probe adaptation that can be used to determine if
     the substance being released is methane.

10   Colorimetric indicator type tubes may be used to document that
     the volatilizing compound has a hazardous component.  The
     collecting media should be specific for the compounds of concern
     and not be sensitive to a host of other compounds, some of which
     may be nonhazardous.

11   This procedure for identifying a specific volatilizing hazardous
     compound in the source material is necessary because the portable
     instruments do not distinguish between volatile compounds; they
     merely tell the user that some volatile compound is present, not
     its identity or its absolute concentration.
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                                                    OSWER Directive 9345.1-1
                     Figure 6.  Air Monitoring
             WIND
             DIRECTION
                                           Sample collected or
                                           monitoring  Instrument
                                           readings

                                           Waste sample
For HRS scoring, samples or Instrument measurements should not be taken
at or In drum openings and In areas physically disturbed by samplers.
A site that Is disturbed by field sampling personnel does  not reflect
ambient conditions.
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                                      OSWER Directive 9345.1-1
FIGURE 7.   FICTICIOUS CASE STUDY
                                               SAMPLING KEY

                                             O  *IR
                                             O  WASTE
                                             Q  GROUND WATER
                                             O  SURFACE WATER
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                                                         OSWER Directive 9345.1-1
Table 2: Application of Sampling Principles to Sampling Points
         Identified in Figure 7.
                   SI SAMPLING
                STRATEGY PRINCIPLE                    SAMPLE NUMBERS

Principle 1: Target Samples to Maximize               6, 10, 12
Population Exposed or Proximity to a
Sensitive Environment

Principle 2: Collect Sufficient Background            1, 5,  7, 8,  11
to Preclude Contributions from Other Sources

Principle 3: Minimize On-Site Sampling                3, 4

Principle 4: Set Priorities for On-Site               3, 4
Sampling

Principle 5: Demonstrate that a Release has           2, 6,  9
Occurred

Principle 6: Sample for Air Releases                  1, 2
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                                                          OSWER Directive 9345.1-1
4.0 CONCLUSION

    The SI sampling strategy consists of six principles which, taken
together, should form the basis of SI sampling plans.  One of the
primary objectives of SI sampling is to collect data to support the
HRS.  The most effective and responsive sampling plans are developed
after a thorough evaluation of existing data and a preliminary HRS
scor ing.

    The SI sampling strategy should be used to guide field personnel
•in sample collection activities.  With a standardized approach to
sampling, fewer samples for each site should be required.  Moreover,
there should be less need for Sl-followups and fewer samples sent for
analyses.
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