8.6 Summary
The survey identified several issues concerning the use of ISM, including how to successfully collect VOC samples with ISM, misconceptions about hot spot identification, how to use ISM data, how to apply ISM cost-effectively, and when ISM may not be the best choice. The ISM Team used the survey information to aid in developing this technical-regulatory guidance document. If the guidance document is successful, the perception of ISM will be improved, and regulatory challenges can be broken down, thus allowing ISM to be used more often and in an appropriate fashion. Table 8-2 provides a summary of the limitations and possible solutions for more widespread implementation of ISM.
Table 8-2. Limitations, solutions, and section references for using ISM
Limitations | Solutions | Section reference |
|---|---|---|
Hot spots | Address during systematic planning with proper scaling, combining, or splitting DUs |
Sections 3.5, 8.2, and 8.5 |
Vertical and horizontal DU delineation | Address during systematic planning with proper scaling or splitting DUs |
|
Acute exposure | Development of approaches for “decompositing” ISM data to estimate variability in concentrations within a DU |
Section 3.1, 3.3, and 3.5 |
Background | Development of formalized guidance on statistical methods for comparison of site and background ISM data. |
|
Leachability | ISM provides probability statement |
Sections 3.1, 3.2, 3.3, 8.3, and 8.5 |
Compare with regulatory standards | Discuss with stakeholders during systematic planning |
Sections 3.1, 7, and 8.5.4.5 |
ISM cost-effectiveness | Cost-effective when large DU, expensive analyte cost, remobilization is expensive |
|
Statistical challenges—compare ISM and discrete | Development of statistically sound methods for comparison of discrete and ISM data |
|
Statistical challenges—95% UCL | Use Student’s-t or Chebyshev |
Section 4 and Appendix A |
Statistical challenges—DUs that do not correspond to exposure units | Development of statistically based methods for combining and subdividing DUs |
Sections 3.1, 3.3, 4, and 7 |
Grinding | Not recommended for organics other than energetics by USEPA SW-846 Method 8330B; recommended for nonvolatile metals; may not be appropriate for project-specific DQOs |
Section 3.1 and 6.2 |
Lab-processing, equipment—sieving, grinding, drying | Close coordination with laboratory is essential throughout ISM; lab business decision to have specific equipment; may need to evaluate different grinding equipment based on method detection limit requirements; laboratory should be familiar with the project-specific ISM requirements and have the facilities (space) and equipment (air-drying racks, grinders, etc.) to meet project-specific DQOs |
|
Lab—lack of nationally recognized methods | USEPA/DOD methods development |
|
Field—shipping VOC container | Complete extraction in field and ship subaliquot to the lab; transport via lab pick-up or appropriate method for hazardous goods |
|
Lab—VOC elevated method detection limit | Analyze by USEPA SW-846 Method 8260C SIM; additionally, may be necessary to use low-level VOC discrete sampling and/or a combination of ISM and discrete |
|
Lab—certification | Check with the appropriate regulatory agency; some states have certification process for lab SOPs; continued research is necessary on possible effects of ISM sample preparation procedures on COPCs, especially organics; develop and implement lab certification for ISM, possibly through NELAP |
|
DU size and shape | Establish based on site history during systematic planning; may require remobilization if concern over results at the end of sample collection |
Sections 3.1, 3.2, and 3.3 |
Regulators reluctance to use ISM | Review ITRC document and attend ITRC training |
All |
Although this document attempts to cover all the relevant topics to ISM, there are several issues which were not addressed, including the following:
- consequences of sample grinding on assumptions made during ecological risk assessments
- use of ISM for sampling air, sediment, or other environmental media
- additional statistical simulation to evaluate:
- combining DUs (Section 4.4.1)
- comparing site to site DUs
- comparing IS vs. discrete
- comparing site vs. background
- comparing oversized DUs
- other types of sampling errors

