EPA review letter, 133-135 Greenwich Street

NYC 9/11 Public Portal Document

Environmental Community Air Monitoring Plan and Quality Assurance Project Plan (QAFF)

15. The QAPP appears to utilize the same sampling and analytical methodologies as the QAPP for air monitoring at the 130 Liberty Street Deconstruction Plan. Consequently, it is recommended that as much as possible of the technical and substantive material from the 130 Liberty Street QAPP be incorporated into Airtek's QAPP as well, ensuring that the quality of the work done for these demolitions will be appropriately usable for the intended purpose for these projects.

The monitoring program is designed to be consistent with the neighboring 130 Liberty Street monitoring program, and to the extent possible utilizes protocols developedfor that project.

16. There are a few items that need to be addressed specifically. The following brief comments should be used as a guide for the improvement of the QAPP and the underlying monitoring work. They are tied, as appropriate, to the sections in the QAPP, since the pages were not numbered.

Section Comment

Att C Cover Page. A distribution list is needed, covering those who will receive copies of the final version of the QAPP and copies of any revisions and/or addenda, etc. EPA and the participating contractors should be included on that list.

Distribution listformat created. To be completed when contractor list is complete.

C3.3 The specific regulations, etc. should be cited, at a minimum.

Reference to 40 CFR parts 50 and 53 has been added.

If the contractor has developed detailed Standard Operating Procedures and/or field checklists, they should be cited and attached.

SOPs, fieldforms, and check lists will be draftedfollowingfinal selection of monitoring equipment and contract laboratories.

Records of traceability, certification, etc. should all be checked and maintained, along with criteria for the various calibrations, audits, etc.

This has been added to the QAPP.

C3.4 Data requirements. The 75% requirement, probably taken from the EPA national monitoring network guidance, is not appropriate for a project such as this. The

-6-

NYC-WTC 000134347