EPA review letter, 133-135 Greenwich Street

NYC 9/11 Public Portal Document

Part II - Environmental Community Monitoring Plan 133-135 Greenwich & 21-23 Thames Streets Airtek Project 05-0701— Rev 2 September 16, 2005

the sampling team being audited. Examples of non-compliance or deviations from the plans are given below: • Not wearing appropriate PPE; • Improper documentation; • Failure to collect field blanks or duplicates; • Improper sampling equipment; • Unauthorized changes in sampling locations or sampling procedures; and • Improper field equipment decontamination.

6.0 CORRECTIVE ACTION

If the validity of the data should become suspect during performance of the QA/QC procedures identified in this plan, then corrective actions will be initiated. The actual trigger, as well as the form of the appropriate corrective action, is dependent on the specific method/procedures, time at which the error was detected and the type of the error that has occurred. For analytical instruments, the corrective action may include:

• Recalibration or standardization of the instrument; • Preparation of new standards; Repair or replacement of equipment, including columns, detectors, etc.; and • Reanalysis of samples.

The laboratory's internal Standard Operating Procedures define corrective action. These procedures will be requested by all laboratories providing analytical services to Airtek under this project and will be appended t the QAPP when received.

Upon determining that deviations from the prescribed protocols contained in the QAPP have occurred, the Laboratory Data Validation Officer will be notified. Within 48 hours, written confirmation of the occurrence and the corrective action taken will be provided to the client.

7.0 ASSESSMENT AND OVERSIGHT

The following subsections describe assessment and oversight measures to be taken during data collection. These actions are separate from the final data validation described in Section 5.1.

7.1 Assessments and Response Actions

The Data Manager will be responsible for routine assessment of data collection and for initiating necessary response actions. The routine assessment will include review of data to ensure that instruments are functioning and collecting information. Routine assessment actions will also include review of the QC measures described in Section 3.6. Response actions will be initiated immediately upon discovery of a problem. The Data Manager will perform these response actions as needed to collect data that meet the project requirements.

The Project QA Officer will conduct occasional field oversight of sampling and analysis activities. During at least one of these visits the Project QA Officer will submit performance audit samples to be analyzed. During field oversight, the Project QA Officer will visually observe sample collection and analysis to verify that the procedures outlined in this QAPP are being followed and that any corrective action initiated previously is being continued.

'0 . `scca-Qt ctQ-SVo be a..a~ed k~ ~ 32

NYC-WTC 000134261