Abstract

EPA uses the Hazard Ranking System (HRS) (40 CFR Part 300, App. A) to evaluate Superfund sites to be proposed
on the National Priorities List (NPL). Based on the HRS, an observed release or observed contamination is established
when contaminants that are significantly above background levels have migrated away from a site through
environmental media. This fact sheet describes how to determine background levels for each migration pathway, and
emphasizes the necessity of strategic, efficient sampling, which is particularly important in light of conducting
integrated assessments under the Superfund Accelerated Cleanup Model (SACM).

Introduction challenging because of varying media compositions and

potentially false assumptions regarding ambient
The determination of background levels under the conditions. Consult the Guidance for Performing Site
Hazard Ranking System (HRS), usually by chemical Inspections Under CERCLA, September 1992, OSWER
analysis, is necessary to evaluate an observed release Directive 9345.1-05, for information on establishing
(Hazard Ranking System, Final Rule, 40 CFR Part background levels.
300, App. A). Background levels are key in establishing
attribution of contaminants where multiple sources or
contaminant contributors exist. Additionally, an Resource Considerations
integrated sampling strategy should be considered when
determining background levels, as appropriate. A sampling strategy for an integrated assessment under
the Superfund Accelerated Cleanup Model (SACM)
A background level is "the concentration of a hazardous should be considered, and planned if appropriate. The
substance that provides a defensible reference point that elements deemed necessary for an integrated
can be used to evaluate whether or not a release from assessment depend on the particular needs of a specific
the site has occurred. The background level should site and could involve similar, additional, or slightly
reflect the concentration of the hazardous substance in different activities compared to traditional removal or
the medium of concern for the environmental setting on remedial site assessments. (For more information, see
or near a site. Background level does not necessarily Integrated Removal and Remedial Site Assessment
represent pre-release conditions, nor conditions in the Investigations, September 1993, OSWER Directive
absence of influence from source(s) at the site" (Hazard 9345.1-16FS.)
Ranking System Guidance Manual, November 1992,
OSWER Directive 9345.1-07). Background levels do not The data gathered from the Site Inspection (SI) may be
have to reflect pristine conditions. useful later in the overall site strategy, especially where
it appears that a response action may be required. In
Obtaining suitable background samples can be such cases, site managers may consider a broader
sampling strategy. For instance, such efforts might Background Level Determination Without Sampling
include collection of the accessary site information for
development and use of Soil Screening Levels (SSLs) for Establishing a background level requires determining the
use during the Remedial Investigation/Feasibility Study concentration level of a hazardous substance. Sampling
(RI/FS). It is appropriate to use data gathered during the is not always necessary to make this determination.
SI for the RI, especially to develop the Conceptual Site Some man-made hazardous substances (e.g., pesticides,
Model. chlorinated organic solvents, except drinking water
chlorination) can be attributed only to a contaminant
SSLs are not appropriate for use at the SI stage source. The presence of these substances in the release
because the objectives of the SI and SSL are different. is sufficient to show contamination; a background sample
The objective of the SI is to obtain information on "worst is not needed (OSWER Directive 9345.1-05).
case" or "hot spot" contamination. It is not intended to be
a detailed analysis of the extent of contamination, nor a Sampling may not be necessary for certain sample
risk assessment. Based on the results of the SI, EPA locations, such as wells, which may serve as their own
decides whether the site qualifies for possible inclusion background (OSWER Directive 9345.1-05). A release
on the National Priorities List or elimination from further can be demonstrated when historical data from a
Superfund consideration. SSLs are used in the RI to contaminated well or intake show that it was previously
screen out potential contaminants and exposure areas for uncontaminated or less contaminated. Detailed historical
remedia l action under the Comprehensive Environmental data are useful to define encroachment of a contaminant
Response, Compensation, and Liability Act (CERCLA) plume. Often, historical data are available for wells and
(Draft Soil Screening Guidance, December 1994, surface water intakes at industrial sites or municipal
OSWER Directive 9355.4-14FS). water facilities which have a regular monitoring program
(OSWER Directive 9345.1-07). For example, a ground-
The Agency for Toxic Substances and Disease Registry water well or surface water intake may have associated
(ATSDR) should be consulted when there is the potential historical analytical data.
for human exposure to toxic substances. The sampling
approach for these sites should include data collection In some cases, published background levels may exist
for the human exposure information that ATSDR uses to that can be applied to a specific site. The following
determine if a health advisory is needed. ATSDR also published data sources may be consulted:
uses this data in the preparation of a public health
assessment, which is required within 12 months of • Background sample results from other nearby
proposal to the National Priorities List. CERCIA site investigations
• Local surveys by other Federal or State agencies
Usually a few background samples are necessary to (e,g., U.S. Geological Survey (USGS), Soil
evaluate an observed release and attribution for HRS Conservation Service (SCS))
purposes. The selection of strategic sampling locations is • University studies
critical to the success of the SI, which is a limited scope • Tables or databases with natural concentration
biased sampling event. When feasible, evaluate the ranges and averages in local or regional soils
benefits of sampling at specific locations and assess the (OSWER Directive 9345.1-05)
validity of available data to meet SI or other integrated
assessment objectives. The data quality objective (DQO) Published data may be useful when selecting background
process provides a logical framework for planning sampling locations. If published data are used, multiple
multiple field investigations, thereby fulfilling the sources of information help to support a comparison
integrated site assessment goal of cross-program determination. The use of background level data without
response planning and allowing optimal cross-program sampling (e.g., published data) may be acceptable for SI
data usability. (See Data Quality Objectives Process or HRS scoring activities. The analytical package for the
for Superfund, September 1993, OERR Directive published data should be obtained whenever possible
9355.9-01 for further details on the DQO process.) (OSWER Directive 9345.1-05).

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Published information may not be appropriate to use in • Pathway-specific considerations (e.g., geologic
many cases. Published data may not account for regional formations, types of surface water bodies); and
variations or unique site-specific characteristics • Other potential sources of contamination in the
(OSWER Directive 9345.1-05). Background levels may vicinity of the site (OSWER Directive 9345.1-05)
vary with regional and local geology (e.g., ore veins, soils
with naturally high metals content). It may be difficult to The number of background samples collected may also
demonstrate comparability using published data because depend upon the type of investigation performed. At
of the difficulty of duplicating sample method and times, a contaminated background sample can be
analysis. For comparison, published or existing data compared with a release to demonstrate that the site
should be generated under quality assurance/quality under investigation contributes at least part of the
control (QA/QC) measures equivalent to EPA contamination in the release (OSWER Directive 9345.1-
requirements. 05).

Considerations for Selecting Background Samples In all evaluations, release and background samples must
be similar for comparison. Factors which determine
Under the HRS, the collection of background samples sample similarity include location, type, depth, medium,
usually is necessary for the following reasons: sampling method, preservation, handling, timing, and
weather conditions during sampling.
• A release cannot be determined by direct
observation; In some situations, collection of a comparable
• The source consists of contaminated soil; background sample is not possible (e.g., when there is no
• Historical data are unavailable or insufficient; surface water sample similar to an isolated pond, or
• The substance of interest is ubiquitous. when a surface water body originates from a spring)
(OSWER Directive 9345.1-05). If background sampling
Under the HRS, the highest background sample is not possible, substitute published data, as available.
concentration generally can be used as a background
level. In a non-industrial area, average background When collecting samples at a site, the activities of the
concentrations may be used when sufficient background investigation team should not introduce any non-
samples are collected in a relatively homogeneous attributable contaminants to samples. Sampling
environment, and there are no alternative sources of methodology can minim, these potential errors.
contamination nearby. Qualified analytical data may also
be used for background level determination (refer to the
interim fact sheet Using Qualified Data to Document Variability introduced by sampling methods can be much
an Observed Release, July 1994, OSWER Directive greater than that introduced by the analytical laboratory.
9285.7-14FS, for more information). At least one When feasible, consider variability factors for each HRS
background sample per pathway or medium of concern pathway under investigation. The following are specific
should be collected. Preferably the samples should be considerations when selecting background samples for
taken outside the area believed to be influenced by the each HRS pathway.
site. However, it is often necessary to collect more than
one background sample. Ground-water Pathway

Determining the location and number of background A direct observation of a release to ground water can be
samples depends upon the following factors: documented if it is observed or known that a hazardous
substance has been deposited, or the source lies below
• Hazardous substances present at the site and the water table of the aquifer of concern (e.g., injection
expected concentrations the following factors: well, buried waste). Therefore, a direct observation of a
• Availability and quality of existing information and release to ground water does not require establishing a
analytical data; background level, but the presence of a hazardous
• Objectives of the investigation; substance in the release should be documented by
• Site hypotheses to be tested; manifest data or chemical analysis (OSWER Directives
• Media variability; 9345.1-05 and 9345.1-07.
• Size of the site, number, and type of sources;

3
When establishing an observed release to ground investigation. Sampled wells generally should be
water by chemical analysis, background samples screened at similar zones within the same aquifer,
generally are needed. Background samples should be depending on the site hydrogeologic setting, because
collected from nearby wells that are not expected to different depths may have different contaminant levels
be influenced by the source of contamination or by and water chemistry. Depth should be measured as
other sites. If there are other sites or potential local elevation relative to a reference (e.g., mean sea level)
sources of ground-water contamination, additional instead of below ground surface for data consistency.
background samples should be collected where
possible to differentiate their contribution from that of Where possible, duplicate purge parameters and
the site under investigation (OSWER Directive method, sampling method, and sampling equipment for
9345.1-05). all well samples. If possible, sample release and
background samples on the same day, but preferably
Similarity of Aquifers not more than three days apart (OSWER Directive
9345.1-05).
Aqueous release and background samples must be
collected from comparable zones (e.g., saturated zone) In cases where a background well is not available,
in the same aquifer and, where possible, should be consider the possibility of sampling a spring before it
collected during the same sampling event. reaches the surface by inserting a pipe or well point
Interconnected aquifers should not be considered as near the location where ground water discharges at the
one aquifer when comparing samples for an observed spring (OSWER Directive 9345.1-05). Sampling data
release. When collecting background samples, it is may be supplemented with applicable published data.
preferable not to use samples from a well screened in Springs may be used for background sampling of
two or more aquifers (OSWER Directive 9345.1-05). surficial aquifers only.

When feasible, evaluate aquifer characteristics before Surface Water Pathway

selecting wells for sampling. especially in areas of
complex or variable geology. Be aware of the Direct observation of a release to surface water may
existence of mines, faults or other aquifer intrusions be documented if material containing a hazardous
which may affect sample representativeness. (Note: substance is seen entering surface water; is known to
Section 7.1 of OSWER Directive 9345.1-07 provides have entered surface water through direct deposition;
detailed guidance on determining aquifers and aquifer or is present in a source which is in contact with
boundaries.) surface water through flooding. Direct observation of a
release to surface water eliminates the need for
Note information on ground-water flow direction if it background sampling, but the presence of a hazardous
is known or can be easily determined. This information substance in the release should be documented
may also be useful in selecting monitoring well analytically. A background sample is not required when
installation locations for Expanded Site Inspection sampling an effluent discharge from the site into
(ESI) and Remedial Investigation (RI) work. surface water, because the effluent is considered a
Information on flow direction should be obtained by direct observation.
using piezometers, by comparing static water levels in
existing wells in the same aquifer, and by using data In non-tidal surface water bodies, it is preferable to
from published reports. The well used for background sample downstream to upstream. Background sediment
sampling should be beyond the influence of the site samples should be from a location comparable to that of
(OSWER Directive 9345.1-05). the release (e.g., fine sediments from quiescent zones)
(OSWER Directive 9345.1-05). Generally, sediment
Comparability of Well Samples samples are preferred over aqueous samples for
evaluating the surface water pathway because
Samples from any two wells can be considered sediments are more likely to retain contaminants. In
comparable if both are collected from the same general, aqueous samples might represent current
aquifer. Filtered ground-water samples should be release conditions, whereas sediment samples might
compared to filtered background samples; unfiltered exhibit historical release conditions.
ground-water samples should be compared to
unfiltered background samples. Ideally, well When it is necessary to collect biological samples,
completion techniques and usage of background wells background samples from essentially sessi1e, benthic
should be similar to those of the well under organisms (e.g., sponges, oysters) can be compared to

4
similar (same species) tissue samples. Organisms For ponds and lakes, background samples may be
selected for background tissue sampling should be the collected near the inflow to the water body if it is not
same gender and approximate age, wherever possible, influenced by the source. A pond near the site may be
of those selected for release tissue sampling (OSWER selected for background sampling if it exhibits similar
Directive 9345.1-05). physical characteristics to the pond on site. For large
ponds and takes, background samples may be collected
Special Considerations for Tidal Water Bodies from the water body itself, but as far away as possible
from the influence of the PPE and other potential
Where appropriate, determine the need to collect sources (OSWER Directive 9345.1-07).
aqueous and sediment samples when the surface
water body is tidally influenced. One approach for Air Pathway
background sampling is to collect outside of the zone
of tidal influence (this can be gauged by the level of Background levels need not be established for the air
the highest tide). It is possible that tidal flow could pick pathway when an observed release by direct
up additional sources upstream. The effect of the tides observation is documented. Direct observation of
on contaminant concentration should be considered. release to the air pathway can be documented in two
(Upstream concentrations would be highest during the ways: a release containing hazardous substances is
rising tide and lowest at falling tide.) Consider seen entering the atmosphere directly (e.g., observing
collecting release and background samples at the same dust blowing off a pile known to contain hazardous
tidal level (OSWER Directive 9345.1-07). substances), or an adverse effect is demonstrated (e.g.,
a documented health effect from a reaction of
Comparability of Water Bodies incompatible substances).

Consider collecting release and background samples Generally, it is necessary to determine background
from the same type of water body. Flow levels for the air pathway because weather conditions
characteristics can be used to determine similar water can greatly affect them. Throughout the sampling
bodies. For example, a background sample from a period, it may be necessary to determine the
small tributary should not be compared to a sample predominant wind direction and speed, effects of low
from a river. Physical and chemical properties of the temperatures, existence of flat, open terrain, and any
surface water (e.g., lack of mixing in large, slow-flow atmospheric instability or lack of air movement.
segments of rivers, physical transport mechanisms, and Background sampling should be collected upwind of site
biological influences) are other ways of determining sources, although cross-wind samples may be
whether water bodies are similar. Where possible, acceptable. It is preferable to collect multiple samples
collect release and background samples during the for this pathway, from the same height, and at the same
same time period, since thermal stratification and time. Samples from great heights such as rooftops
salt/freshwater stratification vary with the time of generally are not useful because they do not represent
year. Consider the thermoclines of a pond or lake or target conditions; very low heights are subject to
measure them in the field prior to sampling (OSWER potential interference from particulates introduced by
Directive 9345.1-05 and 9345.1-07). field activities. Dust, wipe, soil, and soil gas samples are
not acceptable for background sampling in the air
Simple surface water pathway sampling generally pathway. Even though these types of samples may be
consists of taking a minimum of one Probable Point of used, along with field air monitoring equipment, to select
Entry (PPE) sample and one upstream background release and background sample locations, it is
sample. If the surface water pathway has multiple recommended that samples and background be
PPEs, multiple background samples may be needed. collected concurrently. A minimum 12-hour monitoring
The number of background samples collected depends period is recommended for sampling the air pathway,
on the complexity of the path of the surface water particularly during hot and dry weather conditions
body. The presence of multiple tributaries upstream (OSWER Directives 9345.1-05 and 9345.1-07).
with multiple potential sources would require collecting
multiple background samples in each tributary to Wind roses may be used to determine predominant
differentiate the potential contribution of contamination wind direction, or to document changes in it. Wind
from off-site sources (OSWER Directives 9345.1-05 direction is important when selecting sample stations
and 9345.1-07). (OSWER Directive 9345.1-07). The "rose" diagram
consist of bars on a compass face indicating the
frequency of each wind

5
direction during the selected time period, as well as the select more than one background sample and location
average high wind speed for the period. If wind roses for the soil exposure pathway. Avoid collecting
are utilized, try to determine the elevation for which background soil samples from a drainage channel
the wind rose was calculated; this elevation should be which receives water from off site (OSWER Directive
representative of target exposure. Weather stations 9345.1-07). Where possible, collect background
and airports may provide information on local wind samples from a higher elevation than the sources to
direction at ground level and at various elevations. avoid the effect of potential surface drainage. Avoid
background sample locations that are subject to
Soil Exposure Pathway airborne contamination from the site or other sources
(OSWER Directives 9345.1-05 and 9345.1-07).
Because it is not possible to directly observe
contamination in the soil exposure pathway, soil must Determining Background Levels In Industrial,
be sampled to determine background levels. As Mining, and Radioactive Areas
previously mentioned, there will be sites that appear to
require response actions (e.g., early actions). In such Industrial areas can pose a special challenge to
cases, site managers may consider a broader sampling determining background levels. Ambient conditions may
strategy. Such efforts might include collection of the include elevated concentrations of common
necessary information for development of soil contaminants from sources not associated with the site.
screening levels (SSLs). Some common contaminants in background samples in
industrial and urban areas include:
Establishing background levels in the soil pathway can
be difficult, particularly if the hazardous substances • Metals in soils (e.g., lead)
attributed to the site are naturally occurring. Where • Trichloroethene (TCE) and perchloroethene
possib1e, collect on-site background soil samples from (PCE) in urban aquifers
surficial soils not likely to be affected by the source. • Organic substances in harbor sediments
Offsite background soil samples should be collected (OSWER Directive 9345.1-05)
from shallow soils which ideally should not be affected
by other sources and sites in the area. However, if In industrial areas, the investigator often needs to
there are alternative sources of contamination in the document that a sample is above background sample
area, background levels should be measured to variability. One approach is to determine where
determine contributions, from them. When possible, potential alternative sources exist and where they could
sample release and background samples on the same possibly interfere with release or background samples.
day or within three days. (See Highlight 9-1 of Because industrial areas are affected by increased
OSWER 9345.1-07 for information on background levels of contaminants and greater local variability,
samples for non-soil sources in the soil exposure additional background samples may be required to
pathway.) establish off-site conditions. Be sure to collect a
sufficient number of samples between the site and all
Carefully document location, depth, and appearance of other potential sources of contamination in order to
all soil samples. If depths and thicknesses of soil attribute the increase to the site (OSWER Directive
strata vary with location, ensure that release and 9345.1-05). In general, it is inappropriate to average
background samples are from a similar stratum and background samples in an industrial area where more
soil type. Samples should have similar texture, color, than one type of industry existed because doing so
and grain size (OSWER Directive 9345.1-05). Grab could lead to unacceptable levels of local variability (see
samples (as opposed to composite) are preferred for Establishing Areas of Observed Contamination,
determining soil contamination in the SI. Preferably September 1995, OSWER Directive 9295.7-18FS, for
obtain the background sample from an undisturbed, more detailed information).
unfilled area, because fill may have contaminants
which are not representative of background conditions. Mining areas, like industrial areas, pose a challenge to
If a site is located on fill , it may be necessary to obtain determining background levels. Often the contaminants
the background samples from a similarly filled area associated with the mine are naturally occurring
(where the fill is not considered one of the areas of elements. Surface water may originate from the mine,
observed contamination at the site) (OSWER presenting no upstream location for background
Directive 9345.1-07). It is a recommended strategy to

6
sampling. Surface water may pass through the mined pathway only).
watershed. Consequently, the nearest upstream
location away from the influence of the site may be in Some portion of the release must be attributable to the
a different geologic formation, with different water site. For each group, compare release concentrations
chemistry, producing uncertainty about comparability. against known background radionuclide concentrations
against detection limits for a sample medium. Section
When surface water in mining areas originates in the 4.9.4 of OSWER Directive 9345.1-05 provides details
source or when no similar upstream location exists, a on establishing an observed release for each group.
water body with similar physical characteristics (e.g.,
a similar stream on the other side of a mined hill) Summary
should be selected for background sampling. The
similar water body should not be directly affected by Thorough documentation of the locations of the
the site. Concentrations in the vicinity of mining sites background samples and potential alternative sources is
may be so significantly elevated that published data necessary to assess the adequacy of the background
may provide a more reasonable background level. levels and to evaluate release and attribution. The
benefits of sampling at specific locations should be
Mines are often located in areas with aquifers that are evaluated and the validity of existing analytical data
highly fractured or influenced by mine drainage should be assessed. Meet SI objectives while
tunnels. In mining areas, it may be difficult to find conserving Superfund resources. Direct observation of
undisturbed areas in which to locate ground-water a release does not require background sampling if
wells and therefore, difficult to determine detectable concentrations of hazardous substances are
ground-water background levels. In such cases, it is documented to be present in the source. Background
preferable to determine an observed release by direct samples may not be necessary for certain man-made
observation. compounds. If demonstrating a release or establishing
actual contamination is critical to evaluating a site,
Mine tailings generally contain minerals and are background or QA/QC samples should not be limited
considered waste. Collecting background samples is unduly because of budgetary considerations–collecting
not necessary if tailings are analyzed and the mineral these samples may prevent having to return to the site.
concentrations are shown to be elevated well beyond
what might be expected under natural conditions. To establish background levels by chemical analysis,
on-site and off-site sources and their locations should be
To sample sites with radioactive wastes, follow thoroughly reviewed. Release and background samples
sampling strategies similar to those for other hazardous should be collected from similar locations and media.
substances. Criteria to establish an observed release Ground-water samples are similar when they come
through chemical analysis for radioactive substances from the same zone within an aquifer and undergo
exist for the following three groups: similar sample preparation. Background samples for
surface water should be collected upstream of the PPE.
• Radionuclides that occur naturally, or ubiquitous Additional site reconnaissance and review are often
man-made radionuclides; needed to select sampling locations in industrial and
• Non-ubiquitous man-made radionuclides; and mining areas and at complex sites.
• External gamma radiation (soil exposure