EPA work plan review, 133-135 and 21-23 buildings, August 2005

NYC 9/11 Public Portal Document

Part II - Environmental Community Monitoring Plan 133-135 Greenwich & 21-23 Thames Streets Airtek Project 05-0701 — Rev I August 11, 2005

Deficiencies discovered by the contracted laboratory QA Officer will be documented and communicated to the Airtek QA Officer, the Project Manager, and the Laboratory. The impact of deficiencies on use of the data will be evaluated by the Airtek QA Officer and the Project Manager.

5.2 Laboratory Audits

During the laboratory analyses, Airtek QA Officer will be in direct contact with the laboratory to check on the project status. Any technical concern will be discussed during these updates, and formalized in writing by the contracted laboratory. A telefax may be used. Any significant problems impacting either the holding times, or the analytical methodologies, or the deliverable package will be determined.

5.3 FieldAud&ts

The purpose of QA field audits is to ensure compliance with the approved SAP and QAPP. During the performance of the sampling procedures, the QA Officer will make on site audits. Deviations from the approved plans will be brought to the attention of the Field Manager and the Project Manager. All deviations will be recorded in the QA Officer's log and field notebook of 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.

NYC-WTC 000134974