130 Liberty Street Building
New York, New York
Quality Assurance Project Plan for
Asbestos Building Inspection,
WTC Dust Characterization, and
Visual Mold Inspection Study
Prepared for:
Lower Manhattan Development Corporation
One Liberty Plaza, 20th Floor, New York, NY 10006
Prepared By:
The Louis Berger Group, Inc.
199 Water Street, 23rd Floor, New York, NY 10038
August 2004
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Quality Assurance Project Plan
TABLE OF CONTENTS
1.0 INTRODUCTION............................................................................................................. 1
1.1 Site History ............................................................................................................. 2
1.2 Scope and Objectives.............................................................................................. 2
2.0 PROJECT ORGANIZATION......................................................................................... 4
3.0 TASK DESCRIPTION..................................................................................................... 7
3.1 Asbestos Inspection and Material Characterization................................................ 7
3.2 WTC Dust Characterization for Asbestos............................................................... 8
3.3 WTC Dust Characterization for COPC................................................................... 9
3.4 Visual Inspection for Mold ..................................................................................... 9
4.0 QUALITY OBJECTIVES.............................................................................................. 10
5.0 SAMPLING PROCEDURES ........................................................................................ 11
5.1 Asbestos Inspection and Bulk Sampling Procedures............................................ 11
5.2 Asbestos Physical Condition Assessment............................................................. 12
5.3 Sampling Procedures for Asbestos in Dust........................................................... 13
5.4 Sampling Procedures for COPC in Dust............................................................... 15
6.0 SAMPLE HANDLING AND CUSTODY..................................................................... 18
6.1 Field Notebooks .................................................................................................... 18
6.2 Sample Log Sheet ................................................................................................. 19
6.3 Storage and Shipping ............................................................................................ 19
7.0 ANALYTICAL METHODS .......................................................................................... 21
8.0 QUALITY CONTROL SAMPLES............................................................................... 23
8.1 Field Blanks .......................................................................................................... 23
8.2 Duplicate Samples ................................................................................................ 23
8.3 Laboratory Quality Control Samples .................................................................... 23
8.4 Method Blanks ...................................................................................................... 24
8.5 Matrix Spikes ........................................................................................................ 24
8.6 Laboratory Control Samples ................................................................................. 24
9.0 QUALITY ASSURANCE OBJECTIVES .................................................................... 25
10.0 DATA QUALITY OBJECTIVES ................................................................................. 27
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(continued)
11.0 DATA REPORTS ........................................................................................................... 29
11.1 Laboratory Reports and Chain of Custody Forms ................................................ 29
12.0 DATA VALIDATION AND QUALITY ASSURANCE AUDIT ............................... 30
12.1 Data Validation ..................................................................................................... 30
12.2 Laboratory Audits ................................................................................................. 31
12.3 Field Audits........................................................................................................... 31
13.0 CORRECTIVE ACTION .............................................................................................. 32
13.1 Preventive Maintenance and GLP ........................................................................ 32
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1.0 INTRODUCTION
The Louis Berger Group, Inc. (Berger), under contract with the Lower Manhattan Development
Corporation (LMDC) and in its role as an Environmental Consultant for the World Trade Center
Memorial and Redevelopment Plan (WTC Rebuilding Plan), was authorized to conduct an
Asbestos Building Inspection, World Trade Center (WTC) Dust Characterization, and Visual
Mold Inspection Study (the Study) at the building located at 130 Liberty Street, New York, NY
(the Building). The Study was conducted to determine the presence of Asbestos Containing
Materials (ACM) and/or other contaminants of potential concern associated with settled WTC
dust and/or visible mold prior to the scheduled deconstruction of the Building. The scope of the
Study was similar to an environmental site assessment/investigation that is performed by lending
institutions and/or parties to property transactions after their initial due diligence review. As
such, the overall intent and objective of the Study was to identify any building materials that
would be classified as ACM as well as to determine whether particular contaminants
(Contaminants of Potential Concern, or COPCs) that the U.S. Environmental Protection Agency
(U.S. EPA) determined were released on September 11, 2001, were present in the Building as
surface dust.
Following the WTC Event, the U.S. EPA established a committee to evaluate COPCs found in
WTC dust. The COPC Committee of the World Trade Center Indoor Air Task Force Working
Group prepared the World Trade Center Indoor Environment Assessment: Selecting
Contaminants of Potential Concern and Setting Health-Based Benchmarks (May 2003), which
identified the compounds of concern for Lower Manhattan cleanup efforts. The WTC Dust
Characterization for COPCs, as defined by the U.S. EPA’s COPC Committee, are Silica,
Polycyclic Aromatic Hydrocarbons (PAHs), Dioxin, Polychlorinated Biphenyls (PCBs), Heavy
Metals (Barium, Beryllium, Cadmium, Chromium, Copper, Lead, Manganese, Nickel, and Zinc),
and Mercury.
The Quality Assurance Project Plan (QAPP) documents the methods by which the environmental
data operations are implemented and assessed with respect to quality during this investigation
and it details site-specific procedures necessary for quality assurance (QA). The Sampling and
Analysis Plan (SAP), which is used in conjunction with the QAPP, contains specifics about the
numbers and types of samples to be collected, decontamination procedures, sampling procedures,
and all field activities to be performed during this investigation. This work is being performed
under Contract Number F40951.
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1.1 Site History
The events of September 11, 2001, causing the destruction of the World Trade Center (WTC)
Towers, physically destroyed significant portions of the interior and exterior of the Building, a
42 story, approximately 1.5 million square foot office building. The massive debris generated
from the collapse of the South Tower broke approximately 1,500 windows and opened a gash
(“Gash Area”) in the Building’s exterior exposing portions of the interior of the north side of the
Building between the 7th through 24th Floors. The debris demolished the plaza in front of the
Building, exposing the basement and sub-basement (Basement A and Basement B) areas and
ruptured a diesel fuel tank in the basement, the contents of which burned. As a result of these
events, a combination of soot, dust, dirt, debris, and contaminants settled in and on the Building.
The Gash Area and broken windows exposed the interior of the Building to the elements, which
may have caused some further impacts even after the initial exposures and events on September
11, 2001. Subsequent to September 11, 2001, cleaning operations have been undertaken to clear
debris from the plaza, lobby and interior spaces in the Gash Area. The immediate Gash Area
was remediated in accordance with New York City Department of Environmental Protection
(NYCDEP) and New York City Department of Health (NYCDOH) protocols to permit the
construction of columns, beams and floor decks in the Gash Area to stabilize the situation; which
was followed by the hanging of a porous geosynthetic mesh or “netting” on the outside of the
gashed side of the building for further protection and safety. Once the initial cleaning and
stabilization measures were in place, office furniture, equipment and other non-attached items in
the building were removed and disposed. During this time, several study activities were also
undertaken to assist the building owner and their insurance representatives in understanding the
extent and impacts of the WTC dust-related contamination.
The WTC Rebuilding Plan also was initiated during this period. The first stage of the WTC
Rebuilding Plan has been identified as including the deconstruction of the building at 130
Liberty Street down to the top of the foundation walls. This deconstruction will include the
removal of interior walls, stairs, ceilings, floor coverings, Mechanical, Electrical and Plumbing
(MEP) items, exterior skin, superstructure concrete and structural steel. The building will be
deconstructed piece by piece as a safety precaution, and will not include the use of
explosion/implosion devices as is typically the case with conventional building demolition.
1.2 Scope and Objectives
An Asbestos Building Inspection is required to facilitate the proposed deconstruction of the
Building and to comply with: (1) the New York City Department of Buildings permitting
requirements, and (2) the pre-demolition requirements promulgated by the New York City
Department of Environmental Protection (NYCDEP), Section I-53; the New York State
Department of Labor (NYSDOL) Industrial Code, Rule 56: Asbestos Regulation, Title 15,
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Sections 56-1.4 and 56-1.9(e); and the U.S. EPA National Emissions Standards for Hazardous
Air Pollutants (NESHAP) for asbestos-containing materials (ACM).
In addition to the Asbestos Building Inspection, a WTC Dust Characterization and Mold
Inspection will be performed to determine whether or not the aforementioned COPCs and mold
are present in the Building. The results of the Study will be used to obtain permits and to aid in
developing procedures for the deconstruction process, including: (1) worker health and safety;
(2) the implementation of engineering controls and precautionary work practices to ensure public
health and safety; (3) remediation and disposal procedures that properly address all identified
contaminants; and (4) compliance with applicable Federal, State and local regulations throughout
the deconstruction process. To meet these objectives, the following scope of work has been
developed:
TASK 1 Plans and Preparation
TASK 2 Asbestos Inspection and Material Survey
TASK 3 WTC Dust Characterization for Asbestos
TASK 4 WTC Dust Characterization for Silica, PAHs, Dioxin, PCBs, Heavy
Metals, and Mercury
TASK 5 Visual Inspection for Mold
TASK 6 Communication and Report Preparation
The remainder of this report is divided into twelve sections, which will address Tasks 2 through
5 of the Study. Section 2.0 identifies the oversight personnel for this project. Task descriptions,
quality objectives, sampling procedures, and sample handling and custody are presented in
Sections 3.0, 4.0, 5.0, and 6.0, respectively. The remainder of the document (Sections 7.0
through 13.0) details analytical methods, quality control (QC) samples, data quality objectives,
data reports, data validation and QA audit, and corrective action.
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2.0 PROJECT ORGANIZATION
Berger’s staff resources provide an outstanding base of specialized professionals with proven
capabilities in asbestos and hazardous materials inspections and abatement design, and who are
familiar with the project context. The proposed Berger team for this project offers particular
expertise in these areas. In addition, Berger has committed to this project rigorous and robust
QA/QC procedures, using independent Berger staff resources for internal review. Oversight
personnel, their qualifications, and project function are described below.
Berger proposes the continuation of the Management Team that has been in place under Contract
No. F40951 with Lawrence Pesesky, AICP, Senior Vice President, as the Principal-in-Charge,
and Nicolaas Veraart, AICP, as the Program Director.
Thomas Lewis, P.E., J.D. will be the Technical Project Director for this effort and will be
responsible for the overall Quality Assurance for this project. Mr. Lewis is a Senior Vice
President of Environmental Engineering for Berger with over 15 years of environmental and
facilities engineering experience. He has managed many major building and facilities projects
regarding hazardous materials.
Anthony Lee, AICP will be the Project Manager. Mr. Lee will be the primary day-to-day
contact person for LMDC and he will be responsible for facilitating project execution and daily
coordination with the Key Task Personnel. As Project Manager for the WTC Memorial and
Redevelopment Plan GEIS; Mr. Lee’s prior experience working with LMDC will serve as a
tremendous asset in the coordination and execution of this project and ensure that the
information will be presented in the appropriate context.
Richard Wetherbee will serve as the Technical Report Manager, who will coordinate all
functions with the Project Manager and Task Managers to ensure that the scope of work and
deliverables are completed in accordance with LMDC protocols. For LMDC, Mr. Wetherbee
authored the Hazardous Materials chapter of the WTC Memorial and Redevelopment Plan GEIS
and implemented the Environmental Investigation in supported the GEIS effort.
Joseph Sbarra, CIH, will be responsible for Quality Control for Tasks 1, 2, and 3; he will
ensure that the final work product meets the stated objectives for the project, and that it will
accurately and succinctly present the information supporting that conclusion. Mr. Sbarra will be
responsible for an independent technical review of the various project elements, as well as for
selecting project team members. Additionally, Mr. Sbarra will ensure that the Project Manager
has made allowances for sufficient time to complete the planned and systematic quality control
actions.
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Stephen Pharai will be the Quality Control Officer for Tasks 2 and 3. Mr. Pharai will be
responsible for ensuring that the final work product meets the stated objectives for the project,
and that it accurately and succinctly presents the information supporting that conclusion. Mr.
Pharai is an experienced manager with over 14 years of environmental consulting experience on
multi-disciplinary projects for Federal, State and Local governmental agencies as well as private
industry. He has managed major asbestos and hazardous materials inspections and abatement
design programs for renovation projects for various public and private clients.
Kevin McMahon, CIH, will be the Task Manager/Project Safety Officer (PSO). Mr. McMahon
is a Principal Industrial Hygienist with 24 years of experience in environmental and occupational
health and safety, including 16 years in hazardous material remediation. As Task Manager, Mr.
McMahon will coordinate all functions with the Task Coordinators and be responsible for
facilitating project execution including daily coordination to assure that sufficient personnel,
equipment, and materials are available and that personnel are knowledgeable of all procedures
used to complete the work plan. Mr. McMahon will coordinate the project schedule with
Program/Project Management and field personnel to assure that work is completed on time.
Thomas Tanico, Laboratory Data Validation Officer, will oversee laboratory analysis of the
samples and data validation to ensure that the specifications and acceptance criteria are met for
the data collected. Mr. Tanico will work with the Project Manager to assess the overall project
data collection program.
Jeffrey Farrell, P.G., is a Principal Geologist for Berger who will be responsible for the
reduction of validated laboratory data deliverables into final table formats. This will include
comparison of data to applicable criteria where available. Final table format requirements will
be provided to Mr. Farrell prior to receiving laboratory data so that all data templates may be
created in a timely manner.
All sample analyses will be performed by laboratories certified by the New York State
Department of Health (NYSDOH). Laboratories performing asbestos analyses will additionally
hold certifications from Environmental Laboratory Approval Program (ELAP) and also show
proficiency in the National Institute of Occupational Safety and Health (NIOSH) Proficiency
Analytical Testing (PAT). The laboratories performing the analyses are:
AmeriSci Affiliates, New York, New York, will provide analytical services for asbestos in dust
and bulk samples;
Analytics Corporation, Richmond, Virginia, will provide analytical services for silica in dust
samples; and
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Severn Trent Laboratories, Sacramento, California, will provide analytical services for dioxins
in dust samples; Shelton, Connecticut, will provide analytical services for PCBs, PAHs, mercury,
and heavy metals in dust samples.
Each laboratory will maintain appropriate certifications and follow QA/QC plans and standard
analytical protocols as described in this QAPP and in their respective Standard Operating
Procedures. The laboratory QA Manager will ensure that the laboratory QA/QC procedures are
enforced and will provide reports to the laboratory coordinator, Thomas Tanico. All
communication with the laboratory will be directed to Mr. Tanico.
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3.0 TASK DESCRIPTION
To meet the project objectives, a scope of work has been developed for four distinct tasks: (1)
asbestos inspection and material survey; (2) WTC dust characterization for asbestos; (3) WTC
dust characterization for COPC; and (4) visual inspection for mold. These tasks are described in
the following subsections.
3.1 Asbestos Inspection and Material Characterization
Prior to the actual physical inspection of the Building, Berger will research available
documentation for information that might indicate that ACM have been used in the construction
and maintenance of the building. This document review will familiarize Berger’s Personnel with
the design, construction, and layout of the Building, and will help to identify potential ACM that
have been used. A list of documents reviewed will be included in the final report and will
include the following:
1. All available construction, asbestos-related and lead paint maintenance, and renovation
documents (drawings, specifications, plans, blueprints, diagrams, sketches, etc.);
2. All available relevant construction or renovation product submittals correspondence;
3. On-site inspections and interviews with available Building Representatives;
4. All available prior asbestos surveys, operation and maintenance management plans,
asbestos management programs, abatement plans and specifications, and asbestos
abatement project records; and
5. All available asbestos bulk sampling analytical results.
All locations within the scope of work will be physically inspected, homogeneous area-by-
homogeneous area, to determine the presence of ACM. All suspect material identified will be
categorized by homogeneous area prior to bulk sampling. In addition, random sampling will be
conducted. Inaccessible locations that cannot be inspected will be documented and the reason
for the inaccessibility will be noted on the Asbestos Field Survey Data Sheet. Berger will
accomplish all tasks necessary to identify all ACM, which will include, but is not necessarily
limited to, the following:
1. Conduct thorough on-site visual inspections of all accessible areas of the building.
Inspections will be scheduled and coordinated with the LMDC Representative and
conform to the approved work schedule. During the inspection Berger will identify and
document the condition of the suspected material, the activity level and potential for
disturbance based on usage, and other factors deemed appropriate.
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2. Indicate all areas of homogeneous material, without regard to the results of subsequent
laboratory bulk analysis, either on a set of floor plans, on schematic drawings, or in
tabular form.
3. Identify all locations where ACM may be present but cannot be sampled, including the
reason it cannot be sampled.
4. Complete the Field Survey Data Sheet for each homogeneous material, listing all
homogeneous areas where ACM with similar physical conditions are identified.
5. Berger will conduct bulk sampling of all friable and non-friable suspected asbestos-
containing materials and lead paint. Sampled locations will be clearly identified on
copies of the schematic diagrams (drawings or floor plans) and will be marked with an
identification number corresponding to the respective sample number. Each sample will
be listed on the Chain of Custody record that will accompany the samples to the
laboratory.
6. Berger will be responsible for transmittal of the samples to the laboratory and for
assuring that the laboratory analyzes each sample identifying the type and amount of
asbestos and other components present. The Laboratory Director will maintain the Chain
of Custody documentation. If the samples are retained at the laboratory, a clear copy will
be sent to Berger with the sample results for inclusion in the survey report.
3.2 WTC Dust Characterization for Asbestos
WTC dust present in the Building is assumed to contain asbestos. In order to determine whether
or not this assumption is valid, the dust will be sampled and analyzed for asbestos content in
accordance with:
1. Section 56-1.9 (e) of the New York State Department of Labor Industrial Code, Rule 56:
Asbestos Regulations, states: “If a building survey finds that a building to be demolished
contains asbestos or asbestos containing material as defined in section 56-1.4 of this
Subpart, no bids will be advertised nor contracts awarded nor demolition work
commenced by any owner or agent prior to completion of an asbestos remediation
contract performed by a licensed asbestos contractor, in conformance with all standards
set forth in this Part (rule)”. Section 56-1.4 (ac) Definitions: Demolition – The total
razing of a building or an entire portion thereof,
2. The pre-renovation and demolition requirements set by the U.S. EPA NESHAP for
ACM.
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In analyzing the data, the U.S. EPA’s definition of ACM—any material containing greater than
1% asbestos—will be used to determine whether or not the materials are considered to contain
asbestos.
3.3 WTC Dust Characterization for COPC
The following contaminants were consistently found in WTC Dust in the Lower Manhattan area
from previous sampling and testing programs conducted at the Site: silica, PAHs, PCBs, and
metals (i.e., barium, beryllium, cadmium, chromium, copper, lead, manganese, mercury, nickel,
and zinc). They were used as the basis for the former Owners to classify the interior of the
building as being contaminated. As will be specified in the SAP, samples of settled dust will be
collected and analyzed for the contaminants listed above. The sampling will be performed by
qualified industrial hygienists, under the guidance and supervision of a Certified Industrial
Hygienist (CIH).
3.4 Visual Inspection for Mold
Mold is commonly found in structures where water damaged building materials are present; it is
reportedly present at the Site. Berger will conduct a visual site inspection of areas within the
building to determine the presence of mold, water damaged building materials, or water
infiltration. The inspection team will proceed floor by floor in the accessible locations of the
building. The presence of mold, water damaged building materials, and/or water infiltration, as
well as the approximate extent of the impact will be noted on floor plans, on schematic drawings,
or in tabular form. This investigation will be performed by qualified industrial hygienists, under
the guidance and supervision of a CIH.
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4.0 QUALITY OBJECTIVES
Overall data quality objectives are to gather data of sufficient quantity to characterize conditions
at the Site and of sufficient quality to provide defensible data. The types of data required to meet
the project objectives will be generated through the collection of surface wipes, bulk dust, and
bulk material samples. The data quality objectives will be met through implementation of the
SAP and through generation of definitive data.
The specific data quality objectives for the tasks defined in Section 3 are:
Asbestos Containing Building Materials and Dust:
Determine whether the building contains asbestos at or above levels that would require the
demolition to be permitted and executed only if asbestos abatement activities occur prior to the
actual building deconstruction and take-down.
Other Chemicals in Dust:
Confirm the levels (if there are any exceeding standard method detection limits) of the chemicals
of potential concern in the dust on surfaces within the building, including within the HVAC
system and other mechanical/electrical system elements. Such confirmation will help to
determine the potential for ambient air releases, thus enabling analyses and determinations
regarding appropriate worker health and safety measures and work site controls (including
engineered controls at the site of the work as well as air monitoring both within the controlled
work site and upwind/downwind of the building at large).
Waste Handling/Disposal:
Identify and characterize any materials that require handling as contaminated, special, or
hazardous building demolition wastes (e.g., PCB containing electrical equipment, etc.).
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5.0 SAMPLING PROCEDURES
All individuals collecting bulk samples will hold valid NYS Licenses for the respective type of
work they will be conducting, and will not collect samples without the prior written approval of
the Berger’s Corporate Health and Safety Officer. WTC dust sampling for hazardous materials
will be performed by qualified industrial hygienists, under the guidance and supervision of CIH.
Sample handling and Chain of Custody procedures are described for each individual task, which
are noted in the following sections.
5.1 Asbestos Inspection and Bulk Sampling Procedures
The asbestos inspection and bulk sampling procedures to be implemented are based on the
guidelines established by the U.S. EPA in the Guidance for Controlling Asbestos Containing
Materials in Buildings, Office of Pesticides and Toxic Substances, DOC #560/5-85-024 and 40
CFR Part 763, Asbestos Hazard Emergency Response Act (AHERA). Field information is
organized according to the AHERA concept of Homogeneous Area (HA). A HA is defined as a
suspect material of similar age, appearance, function, and texture. Each material will be grouped
together as a specific HA, sampled, and then assessed for condition.
The AHERA guidelines represent the most up-to-date inspection and sampling protocol available
and as such will be utilized during the inspection and sampling. For the purposes of this
inspection, suspect ACM has been placed in three (3) material categories: thermal systems
insulation (TSI), surfacing materials, and miscellaneous materials. The locations within the
Building will be inspected physically, functional space-by-functional space, and homogeneous
area-by-homogeneous area, to determine the presence of ACM.
Core samples of friable and non-friable suspect materials will be collected by penetration of the
suspect material to its substrate. Friable ACM is material that may be crumbled, pulverized,
powdered, crushed, or exposed, or material that is capable of being released into the air by hand
pressure. The bulk samples collected will be placed in sealed containers and labeled with an
identifying code. Representative samples of each sampling area will then be submitted to the
laboratory to be analyzed for asbestos content. The inspection involves the following tasks:
• Visual determination as to the extent of visible and accessible suspect materials and
conditions of the material;
• Collection and analysis of suspect building materials for asbestos content;
• A physical "Hand Pressure" test for determining friability and condition of suspect
materials;
• An assessment of suspect friable and non-friable materials and locations;
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• Quantification of the amount of suspect friable and non-friable materials in their
respective locations;
• Identification of all suspect materials sampled on the appropriate building floor plan
diagram with the sample number; and
• Preparation of a Chain of Custody record that will accompany the samples to the
laboratory.
5.2 Asbestos Physical Condition Assessment
The U.S. EPA AHERA specifies that a physical assessment of all friable suspect material must
be performed during the inspection. The suspect materials are assessed to determine if they pose
a hazard, and if so, they are then ranked according to seriousness. The physical condition
assessment consists of determining the condition of the suspect ACM and the cause of damage
and potential for future disturbance.
AHERA lists seven categories in which to assess the current condition and potential for damage
as follows:
1. Damaged or Significantly Damaged Friable Thermal System Insulation;
2. Damaged Friable Surfacing Material;
3. Significantly Damaged Friable Surfacing Material;
4. Damaged or Significantly Damaged Friable Miscellaneous Material;
5. ACM with potential for damage;
6. ACM with the potential for significant damage; and
7. Any remaining Friable ACM or Friable Suspected (assumed) ACM.
A ranking system will be used to evaluate the ACM. A rank of "1" means the material is in
"poor" condition and requires top priority for abatement response action. A result of "5" would
indicate material in "fair" condition with "moderate" potential for future damage, which would
have a higher priority for abatement response action. A rank of "7" indicates material in "good"
condition with "low" potential for future damage. These areas would have a low abatement
response priority.
Another step in the assessment process is to determine the potential for future damage or
deterioration for material classified as good or fair. The potential for future damage shall be
classified as High, Moderate, or Low. In making the determination of whether or not there is
potential for future damage, there are many factors to consider, including potential for physical
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contact and the influence of environmental factors such as vibration, air erosion, the likelihood of
water damage, etc.
All material will also be given a friability rating and classified as either Friable ACM or Non-
Friable ACM. Friable ACM is the term given to any material that contains more than one
percent (1%) asbestos and can be crumbled, pulverized, or reduced to powder by hand pressure.
It refers to a material’s likeliness to release airborne fibers. There is a greater possibility that a
friable material will release fibers into the air when disturbed than will a non friable material
(i.e., floor tiles, roofing materials, etc.) thereby causing a potential hazard.
The Assessment Process defines the extent of damaged condition as follows:
i. If the extent of the damage is roughly ten percent (10%) of the material and is
evenly distributed throughout the material, then the material is considered
significantly damaged.
ii. If the extent of the damage is roughly twenty five percent (25%) of the material
and is localized, then the material is considered significantly damaged.
5.3 Sampling Procedures for Asbestos in Dust
Berger shall collect representative bulk samples of settled dust to determine the asbestos content,
if any, from random locations under the suspended ceiling, which will be treated as separate
functional areas. Sample locations will be determined using the U.S. EPA simplified random
sampling method (EPA 560/5-85-030a). All sample locations will be documented on the
drawings or floor plans. Each sample location is to be identified by a unique number, which will
permit the cross-referencing of sample information throughout the report. The documentation
(consisting of Field Survey Data Sheets, Chain of Custody documentation, and Floor Plans) is
anticipated to be sufficient to locate and ascertain the extent of asbestos-containing dust
throughout the Building.
All functional spaces will be investigated. Each floor will be divided into a grid with nine (9)
sections; the sections will be numbered starting from section number one in the south west
corner, number two the next section east, number three in the south east corner and number four
in the west central area; counting east from the west wall in each section. The ninth section will
be in the north east corner. The areas will be numbered using the floor number followed by the
section number. Area 1 will be the Southeast section of the floor. For example, the area in the
southeast corner of the first floor will be called Area 01-01. The areas 01-01 through 42-09 will
include every section of the Building. Samples collected above and under the suspended ceiling
shall be labeled separately to identify where the samples were collected.
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Samples will be analyzed by PLM with dispersion staining according to the method specified in
the U.S. EPA Interim Method of the Determination of Asbestos in Bulk Insulation Samples,
Appendix A, Subpart F, 40 CFR Part 763 and the NYSDOH ELAP Method 198.1. This is a
standard of analysis in optical mineralogy and the currently accepted method for the
determination of asbestos in friable bulk samples. A suspect material is immersed in a solution
of known refractive index and subjected to illumination by polarized light. The resulting
characteristic color display enables mineral identification.
For areas with significant dust accumulation, the dust will be wetted, scraped and placed into a
sample container. For areas with minimal dust accumulation, the same procedure will be
followed, except the sample area will be larger. Sample locations in each section of the Building
will be determined by the inspector in the field. Samples will be collected from any horizontal
surface in a section and from areas that contain visible dust. Dust samples shall also be collected
from the following locations and tested for asbestos content:
• Filters at fresh air intakes and other possible locations within the HVAC system, the
number of which will be determined based on field inspection and review of “as-built”
drawings; and
• Exterior construction curtain netting used to contain the damage and debris caused by the
collapse of the WTC, the number of which will be determined following review of safety
requirements.
All sampling will be performed by a New York State Department of Labor Asbestos Inspector
and/or a New York City Certified Asbestos Investigator. The sampling schedule shall comply
with the requirements of the AHERA Guidelines as explained previously in this document and
shall consist of the following:
1. A thorough on-site visual inspection of the Building Inspections will be scheduled and
coordinated with the Building Representative and conform to the approved work
schedule. During the inspection Berger shall identify areas of high/low dust
accumulation on available as-built drawing or floor plans.
2. One sample will be collected from each of the nine sub-divided areas on each floor.
Samples will be taken from non porous floors, porous floors, furniture, above ceilings,
and on mechanical equipment based on the amount of dust found on each for each sample
area. In areas where there is no discernable difference in accumulation samples will be
collected from the lowest level where dust can be sampled.
3. Identification of functional spaces within the sampling areas (number two above) will be
shown on the available as-built drawings or floor plans.
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4. Identification of any locations where the dust could not be sampled, accompanied by the
reason it cannot be sampled. Areas where access is impossible shall be indicated on the
drawings with a notation as to why the areas could not be accessed.
5. Dust samples collected above the suspended ceiling will be treated as separate
homogeneous material from the dust under the suspended ceiling.
6. Berger shall conduct sampling of all dust suspected to be asbestos-containing in
compliance with the requirements of U.S. EPA AHERA for bulk sampling (40 CFR
763.86). A minimum of one (1) side-by-side quality control sample will be collected for
each 20 samples. All sample locations will be clearly identified on copies of the building
schematic diagrams (drawings or floor plans) and marked with an identification number
corresponding to the respective sample number.
7. Each sample shall be listed on the Chain of Custody record, which will accompany the
samples to the laboratory.
5.4 Sampling Procedures for COPC in Dust
Wipe/vacuum sampling for non-asbestos analytes, e.g., metals, PAHs, dioxins, etc., within
surface dust on identified surfaces will be performed. During the initial site walk-through, five
general sampling zones were identified based on previous sampling results and the amount of
visible dust present.
Zone 1 includes those mechanical areas on the 5th and 40th floors, Zone 2 includes general
carpeted/uncarpeted office space at and below the 24th floor (including the basement and vault
areas), Zone 3 includes general carpeted/uncarpeted office space above the 24th floor, Zone 4
includes the remediated “gash” area located on the north side of the building between the 7th and
24th floors, and Zone 5 is the roof area. For Zones 1 and 2, it is anticipated that seventy-two (72)
sample locations will be identified; for Zone 3, thirty-three (33) sample locations will be
identified; for Zone 4, seven (7) sample locations will be identified; and for Zone 5, four (4)
sample locations will be identified. In each case, sample locations will be chosen based upon the
extent of visible dust and/or representation of the area. Sample locations will be divided by zone
such that approximately ¼ will be collected from floor surfaces, ¼ will be collected from ledge
(horizontal surfaces), ¼ will be collected from HVAC interior ductwork, and ¼ will be collected
from above the ceiling, i.e., the plenum. This equates to approximately twenty-nine (29) samples
for each of the previously described locations. It is anticipated that destructive techniques will
need to be utilized for spaces within HVAC ductwork. Furthermore, as floor space varies
between carpeted and uncarpeted, depending on the building floor, sample collection methods
may vary (i.e., vacuum sample for carpeting, wipe sample for tile/wood) for all COPCs
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accordingly. Zone 5 includes the roof area where one wipe sample from a horizontal surface will
be collected from each of four quadrants.
The following dust sample collection methods will be employed at the Site:
Micro-Vacuum Sampling Methods
A micro-vacuuming method may be employed to collect silica and the other COPCs from within
the zones described above for certain sampling substrates, (e.g., carpeting). A pre-weighed PVC
cassette (for silica) will be connected to a three foot length run of Tygon tubing (with a 45º angle
cut into the sample intake portion) on the sampling side and a pump set at a flow rate of 10.0
liters per minute on the intake side. Using a template, samples will be collected within a ten
centimeter-by-ten centimeter area for a period of approximately two (2) minutes. Appropriate
PPE, including coveralls, gloves, boots, and a HEPA filtered respirator will be worn by sampling
technicians at all times. Samples will be placed in a sealed bag and kept cold during collection
and holding/submittal to the approved analytical laboratory.
Bulk Dust Sampling Methods
Bulk sampling methods shall be used to collect dust for a determination of percentages of
various silica species, i.e., crystalline versus amorphous. A clean laboratory scoop will be
utilized to collect representative samples from non-porous surfaces where extensive dust is
present. Appropriate PPE, including coveralls, gloves, boots, and a HEPA filtered respirator will
be worn by sampling technicians at all times. It is anticipated that at least two such samples will
be collected from each zone. Samples will be placed in a sealed bag and kept cold during
collection and holding/submittal to the approved analytical laboratory.
Bulk Carpeting Sampling Methods
Bulk carpet sampling methods will also be employed to collect dioxin samples. A clean cutting
tool will be utilized to remove a ten centimeter-by-ten centimeter area using a pre-cut template.
Sample locations will be determined utilizing the protocol described above. Appropriate PPE,
including coveralls, gloves, boots, and a HEPA filtered respirator will be worn by sampling
technicians at all times. Samples will be placed in a sealed bag and kept cold during collection
and holding/submittal to the approved analytical laboratory.
Wipe Sampling Methods
A wipe sampling method will be employed to collect PCBs, PAHs, and metals (including
mercury) within the aforementioned zones. Wipe sampling will be the default sampling method
in locations where no carpeting is present. Individual samples (per suitable wipe/matrix/
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container) for these parameters will be collected within a ten centimeter-by-ten centimeter
templated area. PCBs and PAHs will be collected on sterile gauze pad treated with a 4:1
acetone/hexane mixture, while metals will be collected on a sterile gauze pad treated with
deionized water. Appropriate PPE, including coveralls, gloves, boots, and a HEPA filtered
respirator will be worn by sampling technicians at all times. Samples will be placed in a sealed
bag and kept cold during collection and holding/submittal to the approved analytical laboratory.
Chain of Custody procedures will be implemented for all COPC samples so that a record of
sample collection, transfer of samples between personnel, sample shipping, and receipt by the
laboratory that will analyze the samples is maintained.
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6.0 SAMPLE HANDLING AND CUSTODY
Establishing and maintaining a fully documented Chain of Custody for chemical analyses is
critical for litigation and scientific evaluation. The Chain of Custody is facilitated by use of four
elements of documentation: Sample labels, Chain of Custody forms, Custody seals, and Field
notebook.
Samples collected in this project will be labeled with water-proof labels supplied by the
laboratory. Labels will be applied as the samples are collected with the sample ID, type of
analysis, date, and time of collection.
6.1 Field Notebooks
Each Field Team Leader or his authorized representative will be issued a field notebook by the
QA Department. The field notebook will be used to record the date, time, and place of sampling
along with the unique sample number and any other relevant information about the condition of
sampling. The notebook will be used to record in indelible ink all field activities related to the
investigation. All entries will start with the date and time of the event to be described. Entries
will be made during the event. If field conditions do not permit concurrent entries, the following
entries will be made as soon as possible after the event, and will be indicated in the notebook:
• Date of sampling event;
• Sample ID and reference to drawing;
• Time of Sample;
• Description of sample type/location;
• Any unusual information pertinent to the sample; and
• Initials of sampler.
Each person making an entry in the notebook will initial and date each page. The first entry for
each new day will start at the top of a new page, and any extra space under the last entry of the
day will be crossed out to prevent additional entries at a later date.
Entries will be made neatly and will be legible. If an error is made in the entry, the error will be
struck with a single strike and correction noted. If appropriate, an explanation of the change will
be made.
All corrections will be initialed and dated and the notebooks will be kept in a safe place. The
QA Officer will periodically review the notebooks for completeness of detail, clarity, and
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observance to the Standard Operating Procedures identified. When this review is conducted, the
QA Officer will date and initial the pages.
6.2 Sample Log Sheet
The information necessary to relate sample locations for reporting purposes should be
documented on a Sampling Log Sheet, which must be completed for each sample collected. The
information on this sheet is essential to proper completion of a sample results report and
includes:
• Client and Facility information;
• Sample ID-assigned as above;
• Date/time sampled;
• Sampler;
• Room/area where sample came from- use client identifiers where possible;
• Equipment/area number if applicable-use client/facility numbers;
• Description of areas/items sampled; and
• Small sketch of sample locations.
A copy of the sample log sheet for each sample must be provided with the samples to the testing
laboratory. Originals should be forwarded to the Task Manager and QC Manager for inclusion
in the project file.
6.3 Storage and Shipping
Once the samples are placed in the storage cooler(s) on ice (four degrees Celsius), the Chain of
Custody is prepared for each cooler. To the extent possible, all samples (primary and quality
control samples) for an analytical batch will be placed in the same cooler for shipping.
The pre-printed, duplicate copy Chain of Custody form will be filled out for each cooler and the
sample numbers and types will be verified against the Sampling Plan Matrix. The “Sampling
Plan Matrix” is a list or tables that identify the numbers and types of samples and containers
from each designated sampling location. Use of the Sampling Plan Matrix is a convenient way
to keep up with container requirements and to avoid forgetting a sample in the field. The matrix
is prepared in the SAP and provides a quick overview of the site sampling activity.
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Samples will be stored in an ice chest at four degrees Celsius. Samples will not be stored in the
field for more than 48 hours. At the end of the day, the chest will be custody sealed. Should the
chests remain off site, they will be kept in a secure facility.
Each chest will be lined on the bottom with cushioning material (newspaper or bubble wrap).
After filling with samples, each bottle will be labeled and returned to the foam sheath. Glass
bottles will be wrapped with bubble wrap, and placed in a resealable plastic storage bag. Once
all the bottles are placed in the chest, packages of ice (prepared by putting ice in a resealable
plastic storage bag, doubled and secured with duct tape) will be placed between and among the
containers. Blue ice may be placed on the top of the chest. Any excess volume will be filled
with more cushioning material. The chest will be taped shut and custody sealed. In addition to
taping the chest, the drain will also be taped. The shipping labels will be completed and placed
on top of the chest. Appropriate “This End Up” labels will be affixed to the chest, which will
then be hand delivered or shipped over night express along with the Chain of Custody forms to
the contracted laboratory. The Chain of Custody form will be placed in a resealable plastic
storage bag and taped to the top of the chest.
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7.0 ANALYTICAL METHODS
Samples will be analyzed by NYSDOH approved laboratories by the following methods:
Asbestos in Bulk Materials:
Samples will be analyzed by Polarized Light Microscopy (PLM) with dispersion staining
according to the method specified in the EPA Interim Method of the Determination of Asbestos
in Bulk Insulation Samples, Appendix A, Subpart F, 40 CFR Part 763. This is a standard of
analysis in optical mineralogy and the currently accepted method for the determination of
asbestos in friable bulk samples. A suspect material is immersed in a solution of known
refractive index and subjected to illumination by polarized light. The resulting characteristic
color display enables mineral identification.
Detection of asbestos fibers used in non-friable organically bound materials (NOBs) such as
floor tile, mastics, roofing materials, and window caulking/glazing, is often extremely difficult
because of the small fibers used during manufacture, their subsequent mixing and coating with
an organic matrix (vinyl, asphalt, etc.) and potential combination during sample preparation. To
address this problem, specialized sample preparation (gravimetric reduction per Chatfield 1991),
and analysis by Transmission Electron Microscopy (TEM) in accordance with the NYSDOH
ELAP Method is required.
Asbestos in Dust:
Samples will be analyzed by PLM with dispersion staining according to the method specified in
the EPA Interim Method of the Determination of Asbestos in Bulk Insulation Samples, Appendix
A, Subpart F, 40 CFR Part 763. Materials containing greater than 1% asbestos are considered
ACMs, as has been defined by the U.S. EPA, which will be used as the criteria to determine
whether or not the dust is asbestos-containing.
COPC in Dust:
Samples will be analyzed in accordance with EPA’s SW-846 Methods, except for silica, which
will be analyzed by Modified NIOSH Method 7500, utilizing x-ray diffraction (XRD) to
characterize crystalline forms of silica. The SW-846 Methods are:
• EPA Method 8270C for analysis of PAHs by gas chromatography/mass spectroscopy
(GC/MS);
• EPA Method 8082 for analysis of PCBs by gas chromatography/electron capture detector
(GC/ECD);
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• EPA Method 8290 for analysis of dioxins by high resolution gas chromatography/high
resolution mass spectroscopy (HRGC/HRMS);
• EPA Method 6010B for analysis of metals (except mercury) by inductively coupled
plasma atomic spectroscopy (ICP); and
• EPA Method 7471A for mercury by cold vapor atomic absorption spectroscopy (CVAA).
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8.0 QUALITY CONTROL SAMPLES
Field quality control samples are collected by the sampling team for use by the contractor’s
laboratory. The purpose of the sample is to provide site-specific field originated checks that the
data generated by the contractor’s analytical lab are of suitable quality. Quality control samples
represent approximately 10 percent of all the field samples. Field QC samples will consist of a
field blank and a blind field duplicate for every batch for wipe and filter cassette samples. Field
QC samples for asbestos samples and carpet samples will consist of one blind field duplicate per
batch. A batch is not to exceed 20 samples.
Laboratory quality assurance and quality control samples are samples analyzed for the purpose
of assessing the quality of the sampling effort and of the analytical data. The purpose of the
samples is to provide site-specific field originated checks that the samples collected are
representative of site conditions and the data generated by the contractor’s analytical laboratory
are of suitable quality. Laboratory quality control samples are defined in the methodologies and
are implemented by the laboratory to provide a measure of assurance that the data quality
objectives are achieved.
8.1 Field Blanks
The purpose of the field blank is to provide an additional check on possible sources of
contamination during sampling activities. A field blank is used to indicate potential
contamination from ambient air and from instruments used to collect and transfer the samples.
For this investigation, field blanks will consist of either filter cassettes left exposed to ambient air
during sample collection or a wipe removed from its sample bottle, exposed to ambient air and
then re-folded and placed back into the sample bottle. The field blank will be collected and
transported in the same manner as the samples collected for that analytical batch. The field
blank will be analyzed for the same parameters as the primary samples.
8.2 Duplicate Samples
The collection of duplicate samples provides for the evaluation of the laboratory’s performance
by comparing analytical results of two samples from the same location. Duplicate samples are to
be included for each matrix at a minimum rate of 5 percent and be submitted to the laboratory as
a “blind” sample.
8.3 Laboratory Quality Control Samples
All laboratory quality control samples are to be reported in the deliverable to be forwarded to the
Berger Project Manager and Berger QA Officer.
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8.4 Method Blanks
Method blanks are defined as laboratory-demonstrated analyte-free water that is carried through
the entire analytical procedure. The method blank is used to determine the level of laboratory
background contamination. A method blank is required in every analytical batch.
8.5 Matrix Spikes
Matrix spike samples are used to assess matrix interference effects on the method, as well as to
evaluate instrument performance. The matrix spike and duplicate are subjected to the entire
analytical procedure in order to indicate both accuracy and precision of the method for the matrix
by measuring the percent recovery and the Relative Percent Difference (RPD) of the two spiked
samples. One set of spikes per analytical batch is required. Site-specific matrix spike and matrix
spike duplicate (MS/MSD) samples will be collected per matrix at a rate of approximately five
percent. One goal for this investigation is that all samples analyzed will contain site-specific
MS/MSD samples in their respective QC batches, this goal will be abandoned if meeting it will
cause method holding times to be exceeded. To prevent the exceedance, samples may be batched
with samples that are of a similar matrix, but not specific to the site.
8.6 Laboratory Control Samples
The Laboratory Control Sample (LCS) is a matrix similar to that of the sample, which has been
spiked with a known concentration of analytes and prepared and analyzed by the same method as
the sample. The percent recovery of these analytes is a measure of the accuracy of the
preparation and analysis method. The Laboratory Control Sample Duplicate (LCSD) is a
duplicate preparation and analysis of the LCS. The LCS and LCSD are used to calculate the
RPD, which is a measure of the precision of the preparation and analysis method. One set of the
LCS/LCSD per analytical batch is required.
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9.0 QUALITY ASSURANCE OBJECTIVES
The purpose of the following Quality Assurance/Quality Control (QA/QC) program is to provide
reliable sampling data. As such, QA/QC samples are included in the project for the purpose of
assessing the quality of the sampling effort and of the analytical data. QA and QC samples
include duplicates of field samples and field blanks. The quality of measurements made
throughout the investigation will be determined by the following characteristics: precision,
accuracy, representativeness, comparability, and completeness. Adherence to the QAPP will be
instrumental in collecting data of known quality.
The QA/QC Objectives for the environmental investigation are as follows:
Precision
The laboratory objective for precision is to equal or exceed the precision demonstrated for the
applied analytical methods on the samples of the same matrix. For this investigation, precision is
evaluated using analyses of laboratory matrix spike/matrix spike duplicates, which not only
exhibit sampling and analytical precision, but also the reproducibility of the analytical results.
For asbestos samples, precision is determined form the analysis of a “blind” duplicate sample
(i.e., the identity of the sample is unknown to the laboratory). RPD criteria will be used to
evaluate precision and comparison of these values to the control limits established within the
confines of the methodologies. Matrix spike and matrix spike duplicates will be employed at a
frequency of at least one per analytical batch (i.e., laboratory batch). If a batch exceeds 20
record samples, an additional set of quality control samples will be added for each record
samples.
Accuracy
The laboratory objective for accuracy is to equal or exceed the accuracy demonstrated for the
applied analytical methods on samples of the similar matrix. For organic matrices, surrogate
standards will be added to all environmental samples, blanks, and quality control samples.
Percent recovery criteria defined within the context of the methodologies will be used to estimate
accuracy based on the surrogates, matrix spike, and matrix duplicate samples. Matrix
interference, either suppression or enhancement will be judged for the spikes and surrogates. A
matrix spike and matrix spike duplicate will be employed at a frequency of at least one per
analytical batch. For asbestos samples, 10% of the samples are re-analyzed to verify the results
of the original analysis.
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Sensitivity
The detection limits that are desired for each analyte are those specified in the methodologies.
The actual detection limits are matrix and sample dependent.
Representativeness
The degree to which data accurately and precisely represent the environmental condition,
characteristics of a population, parameter variations at a sampling point, or a process condition.
Representativeness depends on the sampling procedures. The SAP will describe these
procedures, and they will be designed with the goal of obtaining representative samples for each
of the different matrices.
Comparability
A measure of the confidence with which one data set may be compared another. Data that are
quantitatively and qualitatively comparable to data collected in previous investigations is
provided through the use of EPA-approved analytical methods and the performance as
documented by the laboratory’s internal QA Program.
Completeness
Expressed as the percentage of valid data obtained from a measurement system compared to the
amount that was expected under normal conditions. For the data collected a goal of 90 percent is
required for completeness (or usability) of the analytical data.
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10.0 DATA QUALITY OBJECTIVES
Data Quality Objectives (DQOs) are qualitative and quantitative statements used to develop a
scientific and resource-effective sampling design. The DQOs for each project can be derived
through the use of a series of planning steps designed to ensure that the type, quantity, and
quality of environmental data used in decision-making are appropriate for the intended
application. The quality objectives for the environmental data are defined through this process,
as well, and include a statement concerning the type of data appropriate for the investigation and
the acceptable levels of decision errors used as the basis for establishing the quantity and quality
of data needed to support the decision. Definitive data will be employed to gather data of a
critical nature that will be used in making decisions, such as determining the nature and level of
contamination.
Definitive data are generated using rigorous analytical methods to provide data that are analyte-
specific, with confirmation of analyte identity and concentration. This objective for data quality
is used for activities that require a high degree of qualitative and quantitative accuracy to provide
a level of confidence for the decision maker. For the data to be definitive, the following QA/QC
requirements must be met:
• Sample documentation (location, date and time of collection, etc.);
• Chain of Custody;
• Initial and continuing calibration;
• Sampling design approach;
• Determination and documentation of detection limits;
• Analyte(s) identification;
• Analyte(s) quantification;
• QC samples; and
• Performance Evaluation samples.
The precision and accuracy of the analytical method are evaluated through matrix spike and
laboratory control samples to determine the percent recoveries of the spiking compounds and the
RPDs of duplicate analyses. Collection of co-located samples analyzed by the same methods
provides a measure of the total error from sample acquisition through analysis.
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These analytical methods produce tangible raw data (e.g., chromatograms, spectra, digital
values) in the form of paper printouts or computer-generated electronic files and may be
performed on site or at an off-site location, provided that the above requirements are met.
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11.0 DATA REPORTS
The laboratories shall provide all deliverables in either NYSDEC Category B or NYSDOH
ELAP formats, as appropriate. The laboratory will report all quality control sample results for
each batch of samples. The percent recovery will be calculated for each surrogate and spike
analyte, as applicable. The laboratory will not know which samples are duplicates and will
report them as primary samples. Data for all samples will be returned by QC batch with a copy
of the Chain of Custody form. For each record sample, the laboratory report will include, at a
minimum:
• Sample identification number assigned by the field sampling team;
• Date the sample was collected;
• Date the sample was extracted;
• Date the sample was analyzed;
• List of all target analytes for the method that lists the following data for each target
analyte:
o quantity (concentration) found in sample,
o units of measure (e.g., micrograms per liter, milligrams per kilogram),
o detection limit with unit of measure,
o analytes reported below detection limit, etc.; and
• Non-conformance summary identifying any known failure to comply with the QAPP or
Sampling and Analysis Plan such as the following:
o exceeded holding times,
o failure to achieve required detection limits,
o poor surrogate recovery or poor duplicate precision,
o unidentified samples or custody forms,
o broken custody seals, and
o uncalibrated or improperly calibrated instruments.
11.1 Laboratory Reports and Chain of Custody Forms
The laboratory will send copies of reports to the Berger QA Officer for data validation and a
copy to the Berger Project Manager for the project files. These reports will include a copy of the
Chain of Custody form. The laboratory will retain a copy of all data reports and Chain of
Custody forms.
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12.0 DATA VALIDATION AND QUALITY ASSURANCE AUDIT
This section outlines the procedures necessary for the data validation and quality assurance audit,
which ensures the accuracy of the results.
12.1 Data Validation
Data validation is a systematic procedure of reviewing a body of data against a set of established
criteria so as to provide a specified level of assurance of its validity prior to its intended use. The
review of the data will include an audit of the quality control samples—the laboratory’s method
blanks, field blanks, spikes, and surrogate recoveries. These quality control samples allow a
direct check on the variability in the methods of analysis and sampling and in the sample matrix
itself.
The data will be reviewed by the laboratory’s QA Officer for compliance to the technical
specifications and completeness. The laboratory will provide a non-conformance summary as
appropriate for the analytes determined. Included in the non-conformance summary will be
notification of sample receipts. This will include information regarding problems with sample
packaging, Chain of Custody and sample preservation. A preliminary review for deviations from
method protocols including holding times, surrogate recoveries, and spike recoveries will be
reviewed.
The QA Officer will evaluate a number of criteria including the following:
• Chain of Custody completeness;
• Analyses completed versus analyses planned;
• Time held versus holding times;
• Laboratory blanks (method and instrument);
• Laboratory Control Sample;
• Surrogate recovery (as appropriate);
• Matrix spike recovery (as appropriate);
• Matrix spike duplicate precision;
• Trip and field blank results; and
• Duplicate analyses precision.
Deficiencies discovered by the contracted laboratory QA Officer will be documented and
communicated to the Berger QA Officer, the Project Manager, and the Laboratory Corporate
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Officer. The impact of deficiencies on use of the data will be evaluated by the Berger QA
Officer and the Project Manager.
12.2 Laboratory Audits
During the laboratory analyses, Berger 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.
12.3 Field Audits
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.
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13.0 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 that may include a re-extraction.
The laboratory’s internal Standard Operating Procedures define corrective action. Those
procedures can be found within the laboratory quality assurance plan attached as an appendix to
this document.
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
13.1 Preventive Maintenance and GLP
The analytical methodologies prescribe specific analytical procedures. Included is the general
concept of good laboratory practice (GLP). For the instrumentation needed to conduct these
analyses, the contracted laboratory must have a prescribed preventive maintenance schedule for
their instruments so that analytical integrity is maintained and downtime is minimized.
A preventive maintenance program designed to minimize the downtime of sampling and
analytical equipment should focus on the areas of maintenance responsibility, establishment of
maintenance schedules, and record keeping. Maintenance responsibilities for equipment and
instruments are assumed by the laboratory manager for fixed-base instruments and by the Field
Operations Manager for the field instruments. Maintenance schedules will follow manufacturers’
recommendations for field equipment and standard operating procedures for laboratory
instruments. Maintenance and repair of field and laboratory equipment will be recorded in field
or laboratory notebooks. These records will document the equipment serial numbers, person
performing the maintenance, procedures used, and proof of successful operation of the
equipment following the maintenance or repair.
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