ROUX ASSOCIATES, INC. Environmental Consulting & Management

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1 December 21, 2007 D R A F T AMBIENT AIR MONITORING PROGRAM QUALITY ASSURANCE PROJECT PLAN Prepared for GERDAU AMERISTEEL SAYREVILLE North Crossman Road Sayreville, New Jersey ROUX ASSOCIATES, INC. Environmental Consulting & Management 209 Shafter Street, Islandia, New York GER130501Y.189/CV

2 D R A F T TABLE OF CONTENTS 1.0 QUALITY ASSURANCE PROJECT PLAN APPROVALS DISTRIBUTION LIST PROJECT/TASK ORGANIZATION Project Organization Chart and Lines of Communication Personnel Responsibilities and Reporting Requirements Project Manager Quality Assurance and Field Sampling Coordinator Laboratory Testing Facility Training Requirements PROBLEM DEFINITION AND BACKGROUND Project Purpose and Objectives Overview of Ambient Air Quality Monitoring Programs and Features Project Action Levels Decisions Based on Project Action Levels PROJECT AND TASK DESCRIPTION Description of Work to be Performed Field Sampling Tasks Particulate Matter Chemical Speciation Sampling Laboratory Tasks Project Records DATA AND MEASUREMENT QUALITY OBJECTIVES AND CRITERIA Data Quality Objectives Intended Use of Data Tolerable Error Limits Measurement Performance Criteria AMBIENT AIR QUALITY NETWORK DESCRIPTION Site Selection Meteorological Sensors Monitoring Frequency SAMPLING METHODS REQUIREMENTS Monitoring Methods Particulate Matter (Continuous Operation, BAM-1020) Particulate Matter (Intermittent Operation, Hi-Vol 3000) Sample Collection Methods Monitoring Station Design Sample Collection and Preparation Sample Set-up and Recovery Sampling / Measurement System Corrective Action Sampling Equipment, Preservation, and Holding Time Requirements Sample Contamination Prevention Sample Volume...22 ROUX ASSOCIATES, INC. - i - GER130501Y.189/QAPP

3 D R A F T TABLE OF CONTENTS (Continued) Temperature Preservation Requirements Permissible Holding Times Analyzer Audits SAMPLE HANDLING AND CUSTODY PROCEDURES Sample Custody Field Sample Custody Laboratory Sample Custody ANALYTICAL METHODS REQUIREMENTS Preparation of Samples Analytical Equipment and Methods Quality Control and Corrective Actions for Measurement Systems Laboratory Quality Control QUALITY CONTROL REQUIREMENTS Quality Control Procedures Calibrations Precision Checks Accuracy or Bias Checks Flow Rate Checks Balance Checks EQUIPMENT TESTING, INSPECTION AND MAINTENANCE REQUIREMENTS Field Equipment PM 2.5 Met One BAM-1020 Continuous Monitor TSP/PM 10 Hi-Vol 3000 Monitor Laboratory Equipment INSTRUMENT CALIBRATION AND FREQUENCY Calibration of Local Primary Standards Flow Rate Standard Temperature Standard Pressure Standard Calibration of Laboratory Equipment Documentation of Calibration Frequency DATA MANAGEMENT Sample Collection Documentation Field Notebook Project Documentation Management System Sample Identification and Labeling Data Deliverables Field Analysis Data Fixed Laboratory Data Package Deliverables Data Handling and Management...41 ROUX ASSOCIATES, INC. - ii - GER130501Y.189/QAPP

4 D R A F T TABLE OF CONTENTS (Continued) Data Transfer and Transmittal Data Analysis and Reporting Data Tracking and Control ASSESSMENT AND OVERSIGHT Assessments Management of QAPP, Field, and Laboratory Non-Conformances Assessment Findings and Corrective Action Responses Additional QAPP Non-Conformances Data Validation and Data Assessment Non-Conformances DATA REVIEW, VERIFICATION, VALIDATION, AND USABILITY Data Review, Verification, and Validation Fixed Laboratory Data Data Usability Precision Accuracy Representativeness Completeness Data Limitations and Actions REPORTING, DOCUMENTS, AND RECORDS Records REFERENCES...53 TABLES 1. Project Organization Chart 2. Relevant National Ambient Air Quality Standards 3. Summary of Particulate Matter Sampling and Analysis Methods 4. TSP/PM 10 Chemical Speciation Sampling Schedule 5. TSP/PM 10 Measurement Quality Objectives 6. Target List of Compounds of Potential Concern 7. Laboratory Quality Control Activities, Frequency, and Criteria 8. BAM-1020 Maintenance, Testing and Inspection Requirements 9. Hi-Vol 3000 Maintenance, Testing and Inspection Requirements FIGURES 1. Site Location Map 2. Locations of Particulate Monitoring Stations ROUX ASSOCIATES, INC. - iii - GER130501Y.189/QAPP

5 D R A F T TABLE OF CONTENTS (Continued) APPENDICES A. Standard Operating Procedure (SOP) for the Operation and Maintenance of the BAM-1020 PM 2.5 Particulate Monitor B. Standard Operating Procedure (SOP) for the Operation and Maintenance of the Hi-Vol 3000 Particulate Sampler C. Met One Instruments BAM-1020 Beta Attenuation Mass Monitor USEPA PM 2.5 Federal Equivalent Method Winter Campaign Test Results D. BAM-1020 Audit Sheet E. Hi-Vol 3000 Field Calibration Record F. Hi-Vol 3000 Field Data Record ROUX ASSOCIATES, INC. - iv - GER130501Y.189/QAPP

6 D R A F T 1.0 QUALITY ASSURANCE PROJECT PLAN APPROVALS This Quality Assurance Project Plan for the Ambient Air Monitoring Program at Gerdau Ameristeel Sayreville, Sayreville, New Jersey is hereby recommended for approval. Gerdau Ameristeel Sayreville is committed to implementing the elements described herein. Vice-President and General Manager: Mark Quiring Gerdau Ameristeel Sayreville Signature/Date Environmental Manager: Rey Morales, P.E. Gerdau Ameristeel Sayreville Signature/Date Laboratory Quality Assurance Manager: To Be Determined To Be Determined Signature/Date ROUX ASSOCIATES, INC GER130501Y.189/QAPP

7 D R A F T 2.0 DISTRIBUTION LIST A copy of this Quality Assurance Project Plan (QAPP) for the Gerdau Ameristeel Sayreville Ambient Air Monitoring Program has been distributed to the individuals listed below. Distribution List Recipient and Title Organization Telephone Number Kennedy O Brien, Mayor Borough of Sayreville (732) Jeffrey L. Bertrand, Business Administrator Borough of Sayreville (732) Mark Quiring, Vice-President & General Manager Gerdau Ameristeel Sayreville (732) Rey Morales, P.E., Environmental Manager Gerdau Ameristeel Sayreville (732) Paul Eisen, CCM, Principal Scientist Roux Associates, Inc. (631) Charles E. Gilbert, Ph.D., Toxicologist & Epidemiologist Laboratory Quality Assurance Manager Epidemiology and Toxicology Institute, LLC To Be Determined (631) The QAPP will also be available to other interested organizations upon request. ROUX ASSOCIATES, INC GER130501Y.189/QAPP

8 D R A F T 3.0 PROJECT/TASK ORGANIZATION The key personnel and the agencies that are participating in the Gerdau Ameristeel Sayreville (GA Sayreville) Ambient Air Monitoring Program are presented in this section. The roles and responsibilities of personnel are specified herein, including: individual responsibilities, lines of authority, communications, and reporting requirements. 3.1 Project Organization Chart and Lines of Communication The organizational structure for the GA Sayreville Ambient Air Monitoring Program is presented in the project organization chart (Table 1). The specific responsibilities of key personnel are described in Section 3.2. Any changes to the scope or procedures stated in this QAPP will be formally documented as QAPP revisions. For changes requiring immediate resolution and implementation, approval by phone will be secured from appropriate levels of management. A revised QAPP or QAPP addendum will follow and be provided to the original QAPP Distribution List. 3.2 Personnel Responsibilities and Reporting Requirements The responsibilities of quality assurance, field operations, and analytical laboratory personnel are outlined below Project Manager Mr. Rey Morales, P.E. is the Project Manager for the GA Sayreville Ambient Air Monitoring Program. His responsibilities include communication and reporting of the progress of the program to GA Sayreville management, oversight of the day-to-day activities, and receipt of all required written matter. Mr. Morales is also responsible for providing technical oversight and guidance and reviewing all technical deliverables, including plans and reports. He will periodically audit the program to verify compliance with applicable procedures and requirements, and provide all necessary senior technical support and program planning. He has responsibility for technical and scheduling matters and will serve as the main contact for GA Sayreville and senior management. Other duties, as necessary, include the following: Verifying adherence to project plans and obtaining approvals for any changes to these plans; Maintaining oversight of quality assurance activities; ROUX ASSOCIATES, INC GER130501Y.189/QAPP

9 D R A F T Overall responsibility for the ambient air monitoring network and review; Verifying that approved procedures meet project objectives; Reviewing and approving all sampling procedures; Preparing the QAPP and reviewing all reports; Assigning duties to project staff and orienting the staff to the specific needs and requirements of the project; Serving as GA Sayreville s point of contact for coordination of all field task activities, communications, reports, and technical reviews, and other support functions, and facilitating activities with the technical requirements of the project; Initiating corrective actions; Monitoring schedules for field, analytical, and data validation activities associated with the field sampling program; Maintaining the project file; and Coordinating and ensuring that preventive maintenance activities (as specified in sections and ) are carried out and documented Quality Assurance and Field Sampling Coordinator Roux Associates, Inc. (Roux Associates) will serve as the Quality Assurance and Field Sampling (QA/FS) Coordinator for the Ambient Air Monitoring Program. The QA/FS Coordinator is the communication link between GA Sayreville staff, laboratory, subcontractors, and GA Sayreville management. Specific responsibilities include the following: Providing expert guidance and coordination for the selection and location of monitoring equipment; Providing guidance on placement of monitors per United States Environmental Protection Agency (USEPA) guidelines; Reviewing and approving QA procedures, including any modifications to existing approved procedures; Overseeing and coordinating field data collection activities; Training GA Sayreville staff; Resolving any logistical problems that could potentially hinder field activities such as equipment malfunctions or availability, personnel conflicts, or weather-dependent working conditions; ROUX ASSOCIATES, INC GER130501Y.189/QAPP

10 D R A F T Providing oversight of the contract laboratory operations; Verifying that QA audits of the various phases of the project are conducted as required; Providing QA technical assistance to project staff; Approving operating procedures; Following up on corrective action; Verifying that data validation/data assessment is conducted in accordance with the QAPP; and Reporting on the adequacy, status, and effectiveness of the QA program to the GA Sayreville Plant Manager Laboratory Testing Facility Laboratory testing facility personnel will perform Total Suspended Particulates (TSP) or PM 10 High Volume (Hi-Vol) filter sample preparation and analysis functions in support of the GA Sayreville Ambient Air Monitoring Program. The laboratory personnel shall perform their duties such that the data quality provided meets or exceeds New Jersey Department of Environmental Protection (NJDEP) and USEPA quality assurance requirements. Laboratory personnel shall be responsible for preparing filters for field use. This activity includes, but is not limited to, performing assays on materials prior to and after exposure to the ambient atmosphere (e.g., inspecting and weighing the filters), preparing and analyzing control samples, maintaining consumable inventories, shipping and receiving activities, and performing analytical instrument audits. The Laboratory is ultimately responsible for the analytical data generated by this Ambient Air Monitoring Program. Laboratory managers must implement and comply with quality assurance and internal corporate policies and procedures within their organization. There must be a management system in place for verifying compliance with established quality assurance policies and procedures that are consistent with its certification and accreditation programs with the State of New Jersey and the USEPA. These procedures include approved Standard Operating Procedures (SOPs), internal audit and assessments within the laboratory to improve quality within the laboratory, supervising and providing guidance and training to laboratory staff, and timely responsiveness to all GA Sayreville inquiries involving data quality issues. The ROUX ASSOCIATES, INC GER130501Y.189/QAPP

11 D R A F T Laboratory will also provide documentation of error ranges of each of their related processes and activities. 3.3 Training Requirements GA Sayreville conducts an employee training program that is aimed at increasing and maintaining a high level of effectiveness of its employees and the Corporation. GA Sayreville s education and training program is characterized by operational procedures that track personnel qualifications, training requirements, and training frequency. Air monitoring personnel training consists of required reading prior to implementing the requirements of this QAPP. Documents required to be read shall include this QAPP and appendices and the operational procedures specific to the equipment that personnel will be working with or servicing. ROUX ASSOCIATES, INC GER130501Y.189/QAPP

12 D R A F T 4.0 PROBLEM DEFINITION AND BACKGROUND The Borough of Sayreville and the Sayreville Environmental Commission (SEC) requested that GA Sayreville prepare an action plan (Action Plan) to address recent community concerns regarding dust and noise that may be emanating from operations at the GA Sayreville mill (see Figure 1). GA Sayreville continues to update its Action Plan to address various concerns. As part of the Action Plan, GA Sayreville offered to install and operate an Ambient Air Monitoring Program for particulates to evaluate the ambient air in the neighborhood near the mill. The purpose of the evaluation is to measure ambient air particulates, identify the presence of any contaminants that may be related to mill operations, and to assess the air quality. For instance, monitoring will be performed that will allow for a comparison of measured air quality to relevant health-based National Ambient Air Quality Standards (NAAQS) established by the USEPA. In addition, the data from the monitors will be correlated with meteorological data collected at a weather tower located at the GA Sayreville mill to determine air quality concentrations upwind and downwind of the mill, so that the contribution of mill operations to downwind air quality can be assessed. The Ambient Air Monitoring Program is being implemented and administered by GA Sayreville. Initially, it is anticipated that the program will be operated for a minimum six (6) month period with the potential for an extension of the program based on the results it yields. GA Sayreville is utilizing an independent Environmental Consultant (Roux Associates) to serve in an oversight role. Such oversight includes the Quality Assurance/Quality Control (QA/QC) measures that are specified in this QAPP. 4.1 Project Purpose and Objectives The principal purpose of the Ambient Air Monitoring Program is to monitor air quality in the vicinity of GA Sayreville, North Crossman Road, Sayreville, New Jersey, and attempt to identify and quantify any impacts from the GA Sayreville facility. The Ambient Air Monitoring Program consists of monitoring of particulate matter (PM) in the vicinity of the steel recycling mill site on both a real-time or continuous basis, as well as a time-weighted (or integrated) basis. The forms of particulate matter that will be monitored are the forms for which there are NAAQS or New Jersey Ambient Air Quality Standards (NJAAQS). That is, the monitoring program will be capable of measuring total particulates or inhalable particulates (particulates less than 10 ROUX ASSOCIATES, INC GER130501Y.189/QAPP

13 D R A F T microns in diameter, PM 10 ), and respirable particulates (particulates less than 2.5 microns in diameter, PM 2.5 ). Principal objectives of the program are as follows: Monitor PM 2.5 on a real-time or continuous basis such that the dust associated with all nearby sources as well as background air quality are measured at the three (3) monitoring sites. Monitor PM 2.5 and TSP or PM 10 on a time weighted or 24-hour average basis to assess levels of particulate matter and whether they meet NAAQS and NJAAQS. Collect TSP or PM 10 on a time-weighted or integrated basis such that samples are available for analysis of target compounds potentially associated with GA Sayreville dust, including a defined list of metals of interest. The quality assurance of the meteorological data that is being collected via an onsite weather station is beyond the scope of this QAPP. The evaluation of the ambient air quality data with onsite meteorological data, or in comparison to data collected by the USEPA, NJDEP, or others, will be addressed in future reports. 4.2 Overview of Ambient Air Quality Monitoring Programs and Features There are multiple aspects and levels to the overall Ambient Air Monitoring Program proposed for GA Sayreville. The following is a brief summary of the air monitoring proposed for the project. GA Sayreville proposes to design and perform a program of ambient air monitoring in the Sayreville, New Jersey neighborhood located near its steel recycling mill. The monitoring will be conducted at up to three (3) sites selected by GA Sayreville staff and consultants, in consultation with the Borough of Sayreville, and the mill s Community Advisory Panel, following methods that are likely to be accepted by the USEPA, NJDEP, and other agencies. Quality control and quality assurance methods, as well as chain-of-custody requirements, will be strictly adhered to. Laboratories that follow USEPA and other similar accredited methods will be used to analyze samples. All data will be assembled and reported to the Borough of Sayreville and ultimately be made available to the public. ROUX ASSOCIATES, INC GER130501Y.189/QAPP

14 D R A F T 4.3 Project Action Levels Table 2 lists the relevant NAAQS and NJAAQS for this Ambient Air Monitoring Program. The results of the Ambient Air Monitoring Program will be compared with these standards to evaluate air quality at each of the monitoring locations. Table 2. Relevant Ambient Air Quality Standards Pollutant 24-hour Standard Quarterly (average) Annual Standard (arithmetic mean) Particulate PM µg/m 3 NA 15.0 µg/m 3 Particulate PM µg/m 3 NA Revoked* Lead (Pb) NA 1.5 µg/m 3 NA Total Suspended Particulates (TSP)** 260 µg/m 3 *** NA 75 µg/m 3 **** NA Not available µg/m 3 micrograms per cubic meter * Due to a lack of evidence linking health problems to long-term exposure to coarse particle pollution, the USEPA revoked the annual PM 10 standard in 2006 (effective December 17, 2006). ** Secondary NJAAQS: During any 12 consecutive months, the geometric mean value of all 24-hour averages of suspended particulate matter concentrations in ambient air shall not exceed 60 micrograms per cubic meter, and 24-hour average concentrations may exceed 150 micrograms per cubic meter no more than once. *** May exceed 260 µg/m 3 no more than once in any 12 consecutive months. **** Geometric mean value of all 24-hour averages Decisions Based on Project Action Levels The following actions will be taken if there is an exceedance of any NAAQS or NJAAQS listed in Table 2, at any of the monitoring locations. These air monitoring data, along with the information from the onsite weather station, will be evaluated in an effort to determine sources of the unacceptable particulate levels (e.g., can elevated particulate concentrations be attributed to any nearby source or group of sources). It should be noted that all of Middlesex County, as well as several other Counties in New Jersey, is currently designated non-attainment for the PM 2.5 NAAQS. Hence, measured exceedances of this NAAQS may be expected, and such measurements may be attributed to an area-wide problem. This area-wide problem is being addressed in the context of statewide air quality planning being conducted by NJDEP. Recommended actions to further investigate and eliminate exceedances that are attributed to ROUX ASSOCIATES, INC GER130501Y.189/QAPP

15 D R A F T local sources will be developed and reported to the Borough of Sayreville, the NJDEP, and its designated representatives. Air quality monitoring for all parameters will continue to demonstrate the duration of the exceedance(s), and to verify when concentrations have been returned to acceptable levels. ROUX ASSOCIATES, INC GER130501Y.189/QAPP

16 D R A F T 5.0 PROJECT AND TASK DESCRIPTION This section presents a general overview of the types of activities to be conducted, the air quality measurements that will be taken, and the associated QA/QC goals, procedures, and timing for the collection of measurements. 5.1 Description of Work to be Performed This QAPP has been prepared in association with GA Sayreville s Ambient Air Monitoring Plan to verify that the air monitoring program collects air quality data that meets or exceeds the NJDEP and USEPA quality assurance requirements. The nature of the work required to collect, document, and report this data is summarized as follows: Select and install ambient continuous PM air monitoring equipment at the appropriate locations in the vicinity of the GA Sayreville mill and the residential areas in the immediate vicinity of the GA Sayreville mill; Select and install ambient air monitors to collect samples that can be analyzed to establish the chemical species present in the PM; Collect continuous, site-specific, meteorological monitoring data concurrent with the ambient air monitoring program; Utilize accurate and reliable recording equipment, procedures, and software to manage the data collected during the program; Develop and complete documentation of compliance with quality objectives and criteria, standard equipment operating and maintenance procedures, and regular instrument calibration, and precision and accuracy evaluations. 5.2 Field Sampling Tasks GA Sayreville personnel will be responsible for those activities associated with field sampling tasks that include, but are not limited to, conducting periodic preventive maintenance and servicing the air monitoring equipment. Operational tasks may include installing and collecting PM filter samples and recording pertinent field data. Additional field activities include obtaining additional air monitoring equipment and/or relocating sites as necessary. A summary of all field sampling and analysis methods proposed for use during the Ambient Air Monitoring Program is provided in Table 3. PM 2.5 and either TSP or PM 10 will be measured at each of the three (3) stations identified in Figure 2 of this plan during the Ambient Air ROUX ASSOCIATES, INC GER130501Y.189/QAPP

17 D R A F T Monitoring Program. (The Hi-Vol 3000 monitor can sample either TSP or PM 10, depending on which inlet is installed on the sampling equipment). Appendices A and B contain the manufacturer s specifications for each monitor that, when followed, verify the monitors are operated correctly. Appendix C contains a discussion of the Federal Equivalent Method Study completed with the Met One BAM-1020 continuous PM 2.5 analyzer to prove its acceptability for meeting Federal requirements for this type of sampling. Table 3. Summary of Particulate Matter Sampling and Analysis Methods Sampling Method Instrument (Mfr. and Model #) Pollutant Flow Rate (lpm)* Federal Equivalent Method (Proposed) Met One BAM-1020 PM Federal Reference Method Ecotech Hi-Vol 3000 TSP/PM *lpm = liters per minute Particulate Matter Chemical Speciation Sampling During each sampling event, a total of four (4) filters (one from each of the Hi-Vol 3000 monitors and one trip/field blank) will be submitted to the laboratory for analysis of TSP or PM 10, metals and ph. Since the Hi-Vol 3000 monitors will be set to run selectively up to four days a week (mainly when GA Sayreville is undergoing operations), a maximum of 16 samples would be submitted for laboratory analysis each week. Table 4 summarizes the PM chemical speciation sampling schedule. Table 4. TSP/PM 10 Chemical Speciation Sampling Schedule Parameter No. of Locations Sampled per Day No. of Field/Trip Blanks Collected per Day No. of Samples to Lab per Day No. of Sampling Events per Week Estimated No. of Lab Samples to Lab per Week TSP/PM Metals ph* *The feasibility of determining the ph of the small quantity of particulate matter that is expected to be collected on ambient monitor filters is currently being investigated. It may be necessary to delete or replace this sampling parameter based upon the outcome of the investigation. ROUX ASSOCIATES, INC GER130501Y.189/QAPP

18 D R A F T 5.3 Laboratory Tasks Laboratory activities for the Ambient Air Quality Monitoring Program include the following duties: Performing assays on materials (e.g., Hi-Vol filter media) prior to and after exposure to the ambient atmosphere; Preparing and analyzing control samples; Maintaining consumable inventories; Shipping and receiving activities; Conducting analyses of particulate matter that is present on the filter media; Performing all required instrument calibrations, checks, maintenance, audits, etc.; and Documenting all error ranges. Laboratory personnel will perform these activities such that the data quality provided meets or exceeds NJDEQ and USEPA quality assurance requirements. Laboratory filter management will include the following: Pre-sampling weighing (receiving filters from GA Sayreville, checking filter integrity, conditioning filters, weighing filters, storing prior to field use, packaging filters for field use, maintaining microbalance at specified environmental conditions, equipment maintenance and calibrations, etc.); Shipping/receiving (receiving filters from the field and logging these in, storing filters, etc.); and Post-sampling weighing (checking filter integrity, stabilizing/weighing filters, data entry/storage/reporting, storing filters/archiving, etc.). The primary laboratory analytical task will be to determine the concentration of designated metals and the ph of the particulate matter on the Hi-Vol filter. 5.4 Project Records GA Sayreville will maintain procedures for the timely preparation, review, approval, issuance, control, revision, maintenance, and records retention requirements for documents that are applicable to document control for the Ambient Air Monitoring Program. ROUX ASSOCIATES, INC GER130501Y.189/QAPP

19 D R A F T 6.0 DATA AND MEASUREMENT QUALITY OBJECTIVES AND CRITERIA This section presents the data quality objectives (DQOs) for the Ambient Air Monitoring Program and establishes performance criteria for a systematic planning process and measurement system that will be used to generate the data. 6.1 Data Quality Objectives The type of data needed to meet the DQOs for the Ambient Air Monitoring Program include the specific contaminant of concern, concentration levels, media to be sampled, analysis type, and appropriate sampling techniques. The quantity of data needed to meet the DQOs includes the number of samples for each analytical parameter and a definition of the project boundaries. The number of samples for each analytical parameter is listed in Table 4 and the project boundaries are specified in the Ambient Air Quality Monitoring Plan. The quality of data needed to meet the DQOs includes the necessary data quality indicators (i.e., precision, accuracy, representativeness, comparability, completeness, selectivity, and sensitivity) required of each analytical parameter used for each media sampled. The limits set on each of these items are referred to as measurement performance criteria and define the quality of data generated. All measurement performance criteria have been established for each parameter in order to verify that the data are sound, highly defensible, and with the required quantification limits. Data (i.e., metals concentrations) will be compiled in a database, and the mean, standard deviation, and error bands will be determined. The database will periodically be updated as new data is received Intended Use of Data The ambient criteria pollutant (PM and lead) air monitoring data will be used in conjunction with meteorological data to: Establish baseline concentrations of particulate matter air pollutants in the vicinity of the GA Sayreville mill under various conditions (e.g., when the GA Sayreville mill is operating versus not operating); Monitor the variations in the concentrations of these air pollutants; ROUX ASSOCIATES, INC GER130501Y.189/QAPP

20 D R A F T Evaluate compliance with the NAAQS, for PM 10, PM 2.5, and lead; and, NJDEP standards for TSP Monitor progress made toward meeting ambient air quality standards; Potentially activate emergency control procedures that prevent or alleviate air pollution episodes; and Provide data upon which long term control strategies can be reliably developed Tolerable Error Limits The tolerable error limit for this Ambient Air Quality Monitoring Program is ±10% for each process (e.g., precision check) and analysis (e.g., metals concentrations). More stringent error limits will be adhered to when applicable (see sections 10 and 11). 6.2 Measurement Performance Criteria Measurement quality objectives (MQOs) are designed to evaluate and control various phases (sampling, preparation, analysis) of the measurement process to verify that total measurement uncertainty is within the range prescribed by the DQOs. The MQOs for the Ambient Air Quality Monitoring Program will be defined in terms of the following Data Quality Indicators (DQI): Precision - Precision is a measure of agreement between two replicate measurements of the same property without consideration of the true or accurate value (e.g., variation in the measurements of the same material for the same parameter). Precision will be calculated as either the range or as the standard deviation. Accuracy - Accuracy is the closeness of agreement between an observed value and an accepted reference value. The difference between the observed value and the reference value includes components of both systematic error (bias) and random error. Completeness - Completeness is a metric quantifying the amount of valid data obtained from a measurement system compared to the amount that was expected to be obtained under correct, normal conditions. Completeness can be expressed as a ratio or a percentage. Data completeness requirements are included in the reference methods (40 CFR Part 50). For each of the attributes identified above, acceptance criteria have been developed using various parts of 40 CFR and USEPA supplied guidance documents. The MQOs for the GA Sayreville Ambient Air Quality Monitoring Program are listed in Table 5. More detailed ROUX ASSOCIATES, INC GER130501Y.189/QAPP

21 D R A F T descriptions of these MQOs and how they will be used to control and assess measurement uncertainty are described in other elements, as well as in the SOPs of this QAPP. Table 5. TSP/PM 10 High Volume Sampler Measurement Quality Objectives Measurement Method Accuracy% Precision% Completeness% TSP/PM 10 High Volume Sampler ±10 ±10 90 ROUX ASSOCIATES, INC GER130501Y.189/QAPP

22 D R A F T 7.0 AMBIENT AIR QUALITY NETWORK DESCRIPTION The purpose of this section is to identify the functions associated with the GA Sayreville Ambient Air Monitoring Program, establish the criteria for sampling network design and monitoring site selection, and identify the intended sampling frequency. 7.1 Site Selection Three (3) ambient air monitoring stations will be situated to monitor the air quality in and around the GA Sayreville area (Figure 2). Initially, each monitor is to be located near the GA Sayreville mill; one to the west of the GA Sayreville mill, one to the east-northeast of the GA Sayreville mill, and the third air monitoring station to be placed east of the GA Sayreville mill, in a side yard of the Horseshoe Road community (yard of house on Modzelewski Terrace). (Monitors could be relocated in the future if more pertinent locations become of interest.) The monitor locations were selected based on the criteria established in the Federal Guidelines contained in 40 CFR Part 58, Appendix E. These guidelines recommend, among other things, that the distance of the monitor should be greater than 20 meters from the dripline of trees. The monitor should also have 60 degrees of vertical clearance (no obstruction) in each direction from the vertical at the top of the monitor. 7.2 Meteorological Sensors The meteorological monitoring component of the air sampling and monitoring program will consist of equipment designed to continuously record wind speed, wind direction, precipitation, and air temperature. The GA Sayreville weather station was installed during the summer of 2007 on the roof of the GA Sayreville Administrative Building. All of the equipment is calibrated and certified on installation and its continued operation and maintenance is managed by the Mill. 7.3 Monitoring Frequency The Ambient Air Monitoring Program will consist of a minimum of six (6) months of monitoring. Samples will be collected using all three (3) stations in the monitoring network. PM 2.5 will be measured continuously, while either TSP or PM 10 will be measured for 24-hour periods with a filter sample containing captured particulate available for chemical analysis. The ROUX ASSOCIATES, INC GER130501Y.189/QAPP

23 D R A F T PM 10 monitors will be set to run selectively up to four (4) days a week (mainly when GA Sayreville is undergoing operations). ROUX ASSOCIATES, INC GER130501Y.189/QAPP

24 D R A F T 8.0 SAMPLING METHODS REQUIREMENTS The purpose of this section is to identify the procedures for collecting the required environmental samples, including equipment set-up, sample preservation, and holding time requirements. 8.1 Monitoring Methods This section details the methods to be followed when using the air monitors Particulate Matter (Continuous Operation, BAM-1020) A Beta Attenuation Monitor (BAM) will be used to sample PM 2.5 continuously. The Met One Instruments model BAM-1020 pulls air through its inlet and uses inertia to separate out and trap particles larger than 10 microns in size. (A screen in the external PM 10 head of the air inlet prevents bugs and debris from entering the air monitor.) The air then immediately passes through the Optional PM 2.5 Very Sharp Cut Cyclone (VSCC), which further separates out and traps particles larger than 2.5 microns in size onto a filter tape. Some particles that are smaller than about 0.2 microns may pass through the filter tape and be exhausted. After the sample period (i.e., the time when the vacuum pump is pulling ambient air through the BAM-1020) is completed and the particulate spot is measured, there is almost always a clearly visible spot of dirt on the filter tape where the particulate was deposited. The BAM-1020 will put the spots very close together on the tape. At exactly midnight, the BAM-1020 will skip one spot, leaving a blank spot on the tape. This is a visual aid that separates daily entries on the tape. The BAM-1020 uses the principle of beta ray attenuation to automatically measure and record airborne particulate concentration levels. This method provides a simple determination of concentration in units of milligrams or micrograms of particulate per cubic meter of air. A small 14 C (Carbon 14) element emits a constant source of high-energy electrons known as beta particles. 1 These beta particles are detected and counted by a sensitive scintillation detector. When the filter tape that was exposed to ambient dust is automatically placed between the source and the detector, the beta particle signal is attenuated. The degree of attenuation correlates to the mass concentration of particulate matter on the filter tape, from which the volumetric concentration of particulate matter in the ambient air can be calculated. 1 In accordance with the exempt quantities defined in 10 CFR Section Schedule A, and 10 CFR Part 20 Appendix C, the activity of the 14 C does not require licensing or labeling. ROUX ASSOCIATES, INC GER130501Y.189/QAPP

25 D R A F T Particulate Matter (Intermittent Operation, Hi-Vol 3000) High volume air samplers are used to collect samples of air-borne matter for subsequent analysis. Generally, high volume air sampling is a technique that employs a gravimetric method for the determination of suspended particulate matter in the atmosphere. The term gravimetric implies a weight measurement. The airborne suspended particles that pass through the inlet are collected on a pre-weighed filter during a pre-determined sampling period that is programmed into the Hi-Vol by the operator. The filter collects the airborne particles for subsequent analysis. The Hi-Vol controls the flow rate and records the sampling duration and volume of air that was sampled. After the sampling period is complete, the filter is removed and re-weighed to determine the concentration and/or composition of suspended particulate matter. Concentration results are typically expressed in micrograms per cubic meter (µg/m 3 ) of air sampled at Standard Temperature and Pressure (STP) conditions. 8.2 Sample Collection Methods The physical collection of particulate filter samples, sample transport, and sample preservation techniques must adhere to the requirements of 40 CFR Part 50, Appendix J. The data will be available to download at each sampler using a PC and software provided by the manufacturer. 8.3 Monitoring Station Design The monitoring station design must encompass the operational needs of the equipment, provide an environment that supports sample integrity, and allow the operator to safely and easily service and maintain the equipment. Winter weather conditions must be considered during site selection in order to meet the station safety and serviceability requirements. The sample locations are located within and/or near a residential area and were agreed upon by members of the local community. ROUX ASSOCIATES, INC GER130501Y.189/QAPP

26 D R A F T 8.4 Sample Collection and Preparation Federal Reference Method (FRM) and Federal Equivalent Method (FEM) air monitoring samplers will be used to collect PM 2.5 and PM 10 samples for comparison to the NAAQS standards. For this monitoring program, the PM 2.5 sampler will be the Met One BAM-1020 continuous sampler and the PM 10 sampler will be the Ecotech Hi-Vol The filters from the Hi-Vol 3000 will be sent to a laboratory for heavy metals and ph analysis. Each model sampler will be installed in accordance with the procedures, guidance, and requirements detailed in 40 CFR Part 50, the sampler manufacturer s operations manual, and the appropriate SOP, as referenced as Appendices A and B of this QAPP. Prior to use in the Hi-Vol 3000, all filters must be weighed by the laboratory and the weight recorded Sample Set-up and Recovery Sample set-up of the PM 10 samplers in the ambient air monitoring network can take place any day after the previous sample has been recovered. Pursuant to 40 CFR 50, there are no sample recovery restrictions for PM 10. See Sections and below for additional details. 8.5 Sampling / Measurement System Corrective Action Corrective action measures in the Ambient Air Quality Monitoring Program will be taken to verify the data quality objectives are attained. For example, if quality control filter samples are found to contain metals, it would be necessary to determine the cause of the problem, re-analyze samples, and/or qualify the data. 8.6 Sampling Equipment, Preservation, and Holding Time Requirements This section details the requirements for particulate matter filter retention. The requirements are necessary to: Prevent sample contamination; Specify the volume of air to be sampled; Identify temperature preservation requirements; and Establish the permissible holding times to ensure against degradation of sample integrity. ROUX ASSOCIATES, INC GER130501Y.189/QAPP

27 D R A F T Sample Contamination Prevention Sampling systems are to be designed to prevent the condensation or entrapment of water and other solvents that would provide an environment for bacterial growth, the chemical alteration of sample gases and particles, and the entrapment of particulates and criteria pollutants. The Ambient Air Monitoring Program has rigid requirements to prevent sample contamination. Care will be implemented while handling filter cassettes. Once the filter cassette is taken outside of the weight room, it must never be opened as damage may result to the filter. Filter cassettes are to be stored in filter cassette storage containers or anti-static bags during transport to and from the laboratory. Once samples have been weighed, they are to be stored with the particulate side up and individually stored in static resistant zip-lock bags Sample Volume The volume of air to be sampled is specified in 40 CFR Part 50. The sample flow rate will be 16.7 lpm. The total volume of air collected will be 67.8 cubic meters per hour (m 3 /hr). Sample collection duration is expected to be 24 hours Temperature Preservation Requirements Per the requirements in 40 CFR Part 50, there are no temperature preservation requirements during transport from the weight room to the sample location Permissible Holding Times Per the requirements in 40 CFR Part 50, there are no holding time requirements for any stages of sampling. 8.7 Analyzer Audits Audits are performed according to the guidelines set in 40 CFR Part 50. A detailed review of audits for precision, accuracy, flow rate, etc. are found in Section 11 of this QAPP. ROUX ASSOCIATES, INC GER130501Y.189/QAPP

28 D R A F T 9.0 SAMPLE HANDLING AND CUSTODY PROCEDURES The following sections outline the sample handling and custody procedures once the sample has been collected. 9.1 Sample Custody Proper sample custody verifies that filters are collected, transferred, stored, and analyzed by authorized personnel; that filters are handled properly to maintain sample integrity; and that a detailed record of the treatment of the sample is made in order to confirm results, trace problems, or identify discrepancies in the data if such were to occur. 9.2 Field Sample Custody Sample handling is an important part of the field investigation program since samples that are incorrectly handled can affect the quality of data. Sample handling begins at the collection of the samples and continues until the sample has been analyzed. An overriding consideration, essential for the validation of environmental measurement data, is the necessity to demonstrate that samples have been obtained from the locations stated and that they have reached the laboratory without alteration. Evidence of sample tracking from collection to shipment, laboratory receipt, and laboratory custody must be documented. These procedures will verify that the samples will arrive at the laboratory with the chain-of-custody intact. GA Sayreville is responsible for overseeing and supervising the implementation of proper sample custody procedures in the field and up until the samples have been transferred to a courier. The procedures consist of: (1) preparing and attaching a unique sample label to each sample collected; (2) completing the chain-of-custody form; and (3) preparing and packing the samples for shipment. The field sampler is personally responsible for the care and custody of the samples until they are transferred or dispatched properly. Field procedures have been designed such that as few people as possible will handle the samples. The field procedures are outlined in Section 6 of Appendix B. ROUX ASSOCIATES, INC GER130501Y.189/QAPP

29 D R A F T The field sampler must make sure the filter is clearly labeled. The field sampler will place the filter in a dust proof container, preferably a plastic envelope, and tape the opening of the dust proof container shut to ensure the filter does not become dislodged during transit. Insert the filter and dust proof container into a manila envelope. The sample location, filter number, operator s initials, and run date will be recorded on the manila envelope. The field sample will be certain the exposed filter number corresponds to the number on the manila envelope and record any relevant comments on the manila envelope. The field sampler will record all pertinent information in the field logbook. Samples will be accompanied by a properly completed chain-of-custody form. The sample numbers and locations will be listed on the chain-of-custody form. When transferring the possession of samples, the individual(s) relinquishing and receiving will sign, date, and note the time on the record. This record documents the transfer of custody of samples from the sampler to another person, to a mobile laboratory, to the permanent laboratory, or to/from a secure storage location. Chain-of-custody records are initiated by the field sampler. The field portion of the custody documentation should include: (1) the project name; (2) the sample number, date and time of collection; (3) signature of the field sampler; (4) identification number of media associated with each sample; and (5) if applicable, air bill, or other shipping number. All shipments will be accompanied by the chain-of-custody record identifying the contents. The original record will accompany the shipment and copies will be retained by the sampler and placed in the project files. Samples will be properly packaged for shipment and dispatched to the laboratory for analysis, with a separate signed custody record enclosed in and secured to the inside top of each shipping container. If an authorized laboratory courier does not pick up the samples from the project site, custody seal(s) will be attached to the shipping container and covered with clear plastic tape after being signed by the field sampler. ROUX ASSOCIATES, INC GER130501Y.189/QAPP

30 D R A F T Samples will remain in the custody of the field sampler until transfer of custody is completed. This consists of delivery of samples to the laboratory sample custodian and signature of the laboratory sample custodian on the chain-of-custody document as receiving the samples and signature of field sampler as relinquishing samples. If an authorized laboratory courier does not pick up the samples from the project site, the samples will be transported in container(s) via overnight mail. 9.3 Laboratory Sample Custody Samples will be received and logged in by a designated sample custodian or his/her designee. Upon sample receipt, the sample custodian will: Examine the shipping containers to verify that the custody tape is intact; Examine all sample containers for damage; Determine if the temperature required for the requested testing program has been maintained during shipment and document the temperature on the chain-of-custody or sample login records; Compare samples received against those listed on the chain-of-custody; Verify that sample holding times have not been exceeded; Examine all shipping records for accuracy and completeness; Sign and date the chain-of-custody immediately (if shipment is accepted) and attach the air bill; Note any problems associated with the samples on the receipt form and notify the Laboratory Project Manager, who will be responsible for contacting the GA Sayreville Project Manager; Attach laboratory sample container labels with unique laboratory identification and test; and Place the samples in the proper laboratory storage. ROUX ASSOCIATES, INC GER130501Y.189/QAPP

31 D R A F T Following receipt, samples will be logged in according to the following recommended procedure: The samples will be entered into the laboratory tracking system. At a minimum, the following information will be entered: project name or identification; unique sample numbers (both client and internal laboratory); type of sample; required tests; date and time of laboratory receipt of samples; and field identification provided by field personnel; The Laboratory Project Manager will be notified of sample arrival; and The completed chain-of-custody, air bills, and any additional documentation will be placed in the final file. ROUX ASSOCIATES, INC GER130501Y.189/QAPP

32 D R A F T 10.0 ANALYTICAL METHODS REQUIREMENTS This section of the QAPP describes the techniques that will be used by the analytical laboratories to generate definitive data for the project. The analytical techniques are designed to meet measurement performance criteria and to achieve the project-required quantification limits for all contaminants of concern as identified in the Ambient Air Monitoring Plan Preparation of Samples The PM 10 samples collected from the Hi-Vol sampler will be periodically sent to a laboratory to be tested for the target list of chemical compounds as outlined in Table 6 below. The PM 2.5 samples from the BAM-1020 will not be sent for analysis as this monitor samples the air continuously and is designed to report PM 2.5 concentrations only. Table 6. Target List of Compounds of Potential Concern Antimony Arsenic Beryllium Cadmium Chromium Copper Lead Mercury Nickel Selenium Silver Thallium Zinc Iron Manganese ph The procedures the laboratory will follow regarding the preparation of samples for analysis is outlined in Section 7 of Appendix B. The procedures are based on 40 CFR, Part 50 Appendix B, Reference Method for the Determination of Suspended Particulate Matter in the Atmosphere (High Volume Method). ROUX ASSOCIATES, INC GER130501Y.189/QAPP

33 D R A F T 10.2 Analytical Equipment and Methods Before the laboratory can begin handling, conditioning, and weighing the filters, the laboratory must have the proper equipment ready. This equipment includes, but is not limited to, a microbalance, a continuously-reading temperature sensor, and a continuously-reading humidity sensor. All related equipment for measuring filter mass in the laboratory must be calibrated before the laboratory begins analyzing the filters. See Section 7 of Appendix B for further explanation regarding laboratory QA/QC policies. The cited methods will be followed as written. The procedures shall be based on 40 CFR Part 50. The method to be used by the laboratory for metals analysis is SW-846 Method 6010 or Sections 7 and 8 of Appendix B outline the laboratory analytical methods to be used Quality Control and Corrective Actions for Measurement Systems Quality control checks consist of routine and frequent comparisons of the equipment s measurements to established secondary standards. The checks, which are performed using standards separate from calibration standards, monitor performance and identify which instruments may be becoming unreliable Laboratory Quality Control To verify that the laboratory analysis is accurate, there are many procedures that must be implemented to prevent sample contamination during laboratory analysis. Required laboratory QC checks and QC samples are detailed in the table below: Table 7. Laboratory Quality Control Activities, Frequency, and Criteria QC Sample/Activity Frequency Criteria Lot Blanks 3 per lot Less than ± 15 µg Field Blanks 3 per session Less than ± 30 µg Laboratory Blanks 3 per session Less than ± 15 µg Balance Checks Before and after session 1 per 10 filters Less than or equal to 3 µg Less than or equal to 3 µg Temperature Quarterly ± 2 o C Relative Humidity Quarterly ± 2% Additional details of select QC sample/activity are provided below. ROUX ASSOCIATES, INC GER130501Y.189/QAPP

34 D R A F T Lot Blanks Three (3) lot blanks should be randomly selected from each shipment of filters and are subject to the conditioning procedures outlined in Section 7 of Appendix B. The blanks are weighed every 24 hours for a minimum of one week to determine the length of time it takes to maintain a stable weight reading. The acceptance criterion is less than ± 15 µg. Field Blanks Field blanks can provide an assessment of contamination from sources outside the laboratory. The acceptance criterion is less than ± 30 µg. Laboratory Blanks or Laboratory Control Samples Laboratory blanks can provide an assessment of contamination from sources within the laboratory. Three (3) laboratory blanks are weighed along with other routine filters during every weighing session. The acceptance criterion is less than ± 15 µg. In addition, a control filter is initiated every 7 days and maintained in the environmentally controlled storage room with the exposed sample filters. The filter is analyzed with each batch of samples to monitor for contamination that may occur during equilibration of the filters. The relative percent difference (RPD) between the previous and current readings of PM 10 for the holding filter should be less than or equal to ten percent. If it is not, the samples should be equilibrated for an additional 24 hours and the gravimetric analysis repeated. ROUX ASSOCIATES, INC GER130501Y.189/QAPP

35 D R A F T 11.0 QUALITY CONTROL REQUIREMENTS To assure the quality of data from air monitoring measurements, two distinct and important interrelated functions must be performed. One function is the control of the measurement process through certain activities, such as establishing policies and procedures, assigning roles and responsibilities, conducting oversight and reviews, and implementing corrective actions. The other function is the control of the measurement process through the implementation of specific quality control procedures such as audits, calibrations, checks, replicates, routine selfassessments, etc. Quality control is the overall system of technical activities that measure the attributes and performance of a process, item, or service against defined standards to verify that they meet the stated requirements established by the customer. In the case of an Ambient Air Monitoring Program, QC activities are used to ensure that measurement uncertainty is maintained within acceptable criteria. The following sections detail some Quality Control Requirements Quality Control Procedures Quality control is achieved through periodic maintenance; flow rate audits; acceptance test procedures; accuracy, bias, and precision checks; and collocated instruments and other verification techniques Calibrations Calibration is the process employed to verify and rectify an instrument s measurements in order to minimize deviation from a standard. This multiphase process begins with certifying a calibration or transfer standard against an authoritative standard. The sampling or analytical instrument s measurements are then compared to this calibration/transfer standard. If significant deviations exist between the instrument s measurements and the calibration/transfer standard s measurements, corrective action is implemented to rectify the analytical instrument s measurements. Calibration requirements for the critical field equipment are found in Appendix A and B of this QAPP, and in the BAM-1020 and Ecotech Hi-Vol 3000 operations manuals. ROUX ASSOCIATES, INC GER130501Y.189/QAPP

36 D R A F T Precision Checks Precision is the measure of mutual agreement among individual measurements of the same property, usually under prescribed similar conditions. The precision goal is to have data variation be within ±10 percent. The proposed Ambient Air Monitoring Plan does not include precision checks. If precision checks are required, per NJDEP guidance, collocating samplers within 1 to 4 meters of the proposed air samplers would need to be installed Accuracy or Bias Checks Accuracy is defined as the degree of agreement between an observed value and an accepted reference value. Based on a review of NJDEP guidance, there is no protocol on accuracy or bias checks. The QA/FS Coordinator will recommend procedures to be followed to conduct accuracy or bias checks as the Ambient Air Monitoring Program proceeds Flow Rate Checks In accordance with NJDEP guidance, each sampler is audited for flow rate once per calendar quarter. Each sampler flow rate audit is preceded by a leak check, an ambient temperature sensor audit, a filter temperature audit, and a barometric pressure audit. All audit information is documented on a Sampler Flow Rate Audit Form. The audit form for the BAM-1020 is included as Appendix D. The audit form for the Hi-Vol 3000 is included as Appendix E. The National Institute of Standards and Technology (NIST)-traceable standards for temperature, pressure, and flow rate are an American Society for Testing and Materials (ASTM) mercury-in-glass thermometer, a mercury column barometer, and an electronic mass flow meter. Three temperatures are used for conducting a temperature audit, while one audit measurement is made at the sampler s operational flow rate and one barometric pressure audit measurement is taken at ambient conditions. Please note that the audit equipment, the documentation, and the individual performing the audit are independent from those used in routine quality control checks. As per NJDEP guidance, acceptance criteria are ±4% of transfer standard for flow rate, ±2 o C for temperature, and ±10 millimeters of mercury (mm Hg) for barometric pressure. Samplers that fail these criteria are checked immediately for possible malfunctions and calibrated. ROUX ASSOCIATES, INC GER130501Y.189/QAPP

37 D R A F T Measurements taken by the sampler preceding the audit and since the last previous audit or calibration are reviewed for validity Balance Checks Balance checks are checks of the balance working standards (100 and 200 milligrams [mg] standards) against the laboratory balance to ensure that it is within acceptance criteria throughout weighing sessions. As per NJDEP guidance, weighing particulate filters is audited annually with the use of at least two ASTM Class I standard weights (100 mg and 200 mg) that are independent from those standard weights used for routine balance checks. Preceding the audit, the weighing room temperature and relative humidity sensors are audited with an NIST-traceable ASTM mercury-in-glass thermometer and a psychrometer. The acceptance criterion for microbalance audits is provided by the manufacturer and is typically less than ±0.025 mg. ROUX ASSOCIATES, INC GER130501Y.189/QAPP

38 D R A F T 12.0 EQUIPMENT TESTING, INSPECTION AND MAINTENANCE REQUIREMENTS The following sections describe the procedures and documentation activities that will be performed to verify that all analytical instrumentation and equipment are available and in working order when needed Field Equipment This section describes the procedures and documentation activities that will be performed to ensure that the field analytical instrumentation and equipment are in working order and perform correctly when needed. Instrument maintenance logs should be kept and instrumentation must be checked prior to use. The instrument maintenance log for the BAM-1020 is included as Appendix D. The instrument maintenance log for the Hi-Vol 3000 is included as Appendix E. The maintenance responsibilities for field instruments will be assigned to GA Sayreville personnel, who will be responsible for field checks, calibrations, and for reporting any problems with the instruments. The maintenance schedule will follow the manufacturer s recommendations PM 2.5 Met One BAM-1020 Continuous Monitor Table 8 highlights important maintenance, testing, and inspection requirements for the Met One BAM-1020 Continuous Monitor. Table 8. BAM-1020 Maintenance, Testing and Inspection Requirements Maintenance Item Download Error Log Download Data Log Compare BAM-1020 Data with External Datalogger Nozzle and Vane Cleaning Leak Check Flow Check Clean BAM-1020 Enclosure Clean Capstan Shaft and Pinch Roller Tires Verify Settings Set Real-Time Clock Period Weekly Weekly Weekly Monthly Monthly Monthly Monthly Monthly Monthly Monthly ROUX ASSOCIATES, INC GER130501Y.189/QAPP

39 D R A F T Maintenance Item Replace Filter Tape Run SELF-TEST Function Full Flow Calibration Clean Inlets Perform 72 Hour Zero Filter Test Replace/Clean Pump Muffler Test Flow Controller Test Pump Test Filter RH and Filter Temperature Sensors Test Smart Heater Replace Nozzle O-Ring Clean Internal Debris Filter Clean Membrane Span Foil Beta Detector Count Rate Test Beta Detector Dark Count Test Test Analog Output (If Used) Rebuild Vacuum Pump Clean Inlet Tube Replace Pump Tubing Factory Recalibration Period 2 Months 2 Months 2 Months 2 Months 6 Months 6 Months 6 Months 6 Months 6 Months 6 Months 12 Months 12 Months 12 Months 12 Months 12 Months 12 Months 24 Months 24 Months 24 Months As Required TSP/PM 10 Hi-Vol 3000 Monitor Table 9 highlights important maintenance, testing, and inspection requirements for the Hi-Vol 3000 Monitor. Table 9. Hi-Vol 3000 Maintenance, Testing and Inspection Requirements Maintenance Item Check Tie Downs Inspect Filter Holder and Rubber Gaskets Clean Sampler, Wipe Cassette and Supporting Structure with Damp Cloth Check Operation of Automatic Flow Compensation Device by Placing Two Filters in the Filter Cassette Check Power Cords Period Weekly Weekly Weekly Weekly Quarterly ROUX ASSOCIATES, INC GER130501Y.189/QAPP

40 D R A F T 12.2 Laboratory Equipment The laboratory shall test, inspect, and maintain all laboratory equipment in accordance with the testing, inspection, and maintenance requirements approved by the NJDEP and USEPA. If required, the laboratory shall provide all SOPs and instrument maintenance logs to the laboratory equipment to demonstrate compliance with NJDEP and USEPA requirements. ROUX ASSOCIATES, INC GER130501Y.189/QAPP

41 D R A F T 13.0 INSTRUMENT CALIBRATION AND FREQUENCY This section of the QAPP describes the standards to be utilized to calibrate field and laboratory instruments and the frequency of calibration events Calibration of Local Primary Standards Local (field) instruments will be calibrated using the standards detailed in the following sections Flow Rate Standard The local primary flow rate standard used to calibrate the field flow rate transfer standards will be a reference flow meter. The local primary flow rate standard will be maintained and recertified against a NIST-traceable flow rate standard by the manufacturer. The NIST-traceable standards for temperature, pressure, and flow rate are an ASTM mercury-in-glass thermometer, a mercury column barometer, and an electronic mass flow meter Temperature Standard The local primary temperature standard used to verify the accuracy of the field temperature transfer standards will be a mercury-in-glass thermometer and will be recertified against a NIST primary standard when there is an observed shift in performance Pressure Standard The local primary pressure standard used to verify the accuracy of the field barometer transfer standards will be a stationary mercury barometer Calibration of Laboratory Equipment The specific calibration procedures required by the laboratory equipment can be found in the laboratory s SOP or in the standard operations manual for the specific equipment Documentation of Calibration Frequency All of the required calibration and maintenance will be performed at the frequencies outlined in Appendices A and B, as well as Section 12 of this QAPP. Performance of calibration and maintenance will be documented in the field logbook and record notebooks. Field activities associated with equipment used by the technical staff will be kept in record notebooks as well. The records will normally be controlled by GA Sayreville personnel. ROUX ASSOCIATES, INC GER130501Y.189/QAPP

42 D R A F T 14.0 DATA MANAGEMENT This section of the QAPP describes field documentation procedures that will be followed for this project Sample Collection Documentation Records of field data will be made throughout the project to document critical data that might be needed at a later time, such as during preparation of the report, or for use by other investigators who were not present when the data were collected. Field data will be recorded on the following logs, forms, and/or notebooks: Field Log/Notebook; Field Data Forms (when applicable); Equipment Calibration Logs (when necessary); Health and Safety Logs (when applicable); and Photographs (if necessary). GA Sayreville personnel will be responsible for maintaining the various logs, forms, and notebooks that document daily field activities as discussed below. Special emphasis will be placed on the completeness and accuracy of all information recorded in the field and will contain statements that are legible, accurate, and inclusive documentation of project activities. Because the logbooks, field data forms, and chain-of-custody forms provide the basis for future reports, they must contain accurate facts and observations. The language used in recording all field data will be objective and factual. In general, field forms will be used to record most of the field information including calibrations, start and stop times of pumps, sample volumes, equipment inspections, etc. Sample field forms are included as Appendices D, E, and F. The following sections describe how data collected in the field will be documented, tracked, and controlled Field Notebook Field notebooks will provide the means of recording the chronology of data collection activities performed during the investigation. As such, entries will be described in as much detail as possible so that a particular situation could be reconstructed without reliance on memory. Field notebooks will be bound field survey books or notebooks. Notebooks will be assigned to field ROUX ASSOCIATES, INC GER130501Y.189/QAPP

43 D R A F T personnel, but will be stored in the project files when not in use. Each notebook will be identified by the project number. The title page of each notebook will contain the project name, project number, and site name. Entries into the notebook will contain a variety of information. At the beginning of each entry, the date, start time, weather, and names of all members present will be entered. Each page of the notebook will be initialized and dated by the person making the entry. All entries will be made in permanent ink and no erasures or obliterations will be made. If an incorrect entry is made, the information will be crossed out with a single strike mark that is signed and dated by the sampler. The correction shall be written adjacent to the error. Field activities will be fully documented. Information included in the notebook may include: Chronology of activities, including entry and exit times; Names of all people involved in sampling activities and organizational affiliations; Any changes made to planned protocol; Names of visitors to the site during sampling and reason for their visit; Sample location and identification; Weather conditions, including temperature and relative humidity; Dates (month/day/year) and times (military) of sample collection; Measurement equipment identification (model/manufacturer) and calibration information; Field screening results; Site observations; Sample collection methods and equipment; Sample collection date and time; Sample preservation and storage conditions; QC sample collection; Unusual observations; and Initials of person recording the information. ROUX ASSOCIATES, INC GER130501Y.189/QAPP

44 D R A F T Upon receipt of the field notebook for a particular activity, the designated person recording the notes will begin recording notes on a new page. The person recording the notes will initialize the top of the new page and indicate the date, time, and weather conditions prior to recording information about the field activity. When the designated person recording the notes either relinquishes the field logbook to another team member or turns the book in at the end of the day, the person relinquishing the field logbook will affix a signature and date to the bottom of the last page used. If the page is not complete, a diagonal line will be struck across the blank portion of the page Project Documentation Management System A file of project-related documents will be maintained by GA Sayreville. The file will contain all contracts, work authorizations, change orders, invoices, correspondences, etc. GA Sayreville will maintain an inventory of the field notebooks used during the program and will be responsible for ensuring that they are archived in the project files following the completion of the program Sample Identification and Labeling Establishing a standard sample designation/labeling protocol is essential to verify adequate quality assurance/quality control and to allow tracking of each sample and the associated analytical data. Proper labeling allows for the tracking of samples beginning from the time of sample collection through analysis and following project completion should future data correlation be deemed necessary. The proper labeling of samples is also critical in ensuring that samples are analyzed within the required sample holding times. All samples will be identified using a sample identification scheme suitable to the project and the sampling protocol. The sample identification number will be recorded on the chain-of-custody forms accompanying each sample shipment submitted for analysis Data Deliverables The following sections outline the different deliverable methods to be used during this program. ROUX ASSOCIATES, INC GER130501Y.189/QAPP

45 D R A F T Field Analysis Data Hardcopy Deliverables All field and QC sample results, calibrations, and calibration verifications will be recorded in the field logbook, on field screening forms, and/or on equipment calibration forms to ensure proper documentation and verification of the sample results. Electronic Deliverables Hi-Vol Certain data can be downloaded to a PC using software provided by the manufacturer. The data will be downloaded by GA Sayreville personnel in 24-hour averages. The sampler will be programmed to run up to four days per week and data will be retrieved approximately weekly. Electronic Deliverables BAM-1020 The BAM-1020 can be connected to almost any standard PC that has an RS-232 serial port available. Data will be downloaded on an hourly basis, continuously, and sent via communication link to a central computer (i.e., file server) located at GA Sayreville. GA Sayreville and other authorized personnel will be able to review data at any time, on a continuous basis. After validation, the data will be available on an internet accessible website, which is currently being developed for such purpose Fixed Laboratory Data Package Deliverables Hardcopy Deliverables Data deliverables from the laboratory should consist of the following: Narrative This should include summary of analytical methods used, correlation of field sample identifications, and laboratory sample identifications, data qualifier definitions, and any deviations from established QA/QC procedures with corrective action. Sample Results This should include the project name, sample ID, batch number, collection and analysis dates, sample results, quantification limits, and dilution factors. Sample Documentation This should include the chain of custody, shipping documents, and any other shipping receipt forms. QA/QC This should include any method blanks, measures of precision (lab duplicates, etc), and a summary of calibration results. Electronic Deliverables Lab data summaries should be received in both hard copy and electronic format. The electronic deliverable will be in Microsoft Excel format. ROUX ASSOCIATES, INC GER130501Y.189/QAPP

46 D R A F T 14.4 Data Handling and Management All data entry will be reviewed for accuracy. Verification will be carried out either by comparing a printout against the original data, or by duplicate entry and comparison of the two data sets to detect discrepancies Data Transfer and Transmittal Hard copy and electronic copies from the laboratories will be transmitted to GA Sayreville upon completion of analysis. After the data are validated, appropriate modifications to the data will be made to reflect the changes resulting from data validation (if any). A second quality assurance review will be performed after the validated data are entered. The validated results will be saved in the file server designated for such purposes at GA Sayreville. After validation, the data will be available on an internet accessible website, which is currently being developed for such purpose Data Analysis and Reporting All data reports will present summaries of all validated data collected during the field investigation Data Tracking and Control Management of field data is described in the sections above. Laboratory data will be maintained as described in the laboratory s QA manuals and the laboratory s SOP. GA Sayreville will maintain the contents of the files, including all relevant records, reports, logs, field notebooks, pictures, subcontractor reports, and data reviews in a secured, limited access area. ROUX ASSOCIATES, INC GER130501Y.189/QAPP

47 D R A F T 15.0 ASSESSMENT AND OVERSIGHT The following sections detail the auditing procedures for field and laboratory activities Assessments Technical system audits (TSAs) of both field and laboratory activities would be conducted by Roux Associates to verify that sampling and analysis are performed in accordance with the procedures established in the QAPP. Field Sampling TSAs - A system audit of field activities including sampling and field measurements may be conducted and documented by Roux Associates. The purpose of this audit is to verify that all established procedures are being followed as planned and to allow for timely corrective action of non-conformance. The audit will ensure that all personnel required to do so have read the QAPP. The audit will cover field sampling records, field measurement results, field instrument operation and calibration records, sample collection, preservation, handling, and packaging procedures, adherence to QA procedures, personnel training, sampling procedures, review of sampling design versus the sampling plan, corrective action procedures, chain-of-custody, etc. Upon completion of the audit, Roux Associates will prepare a written audit report, which summarizes the audit findings, identifies deficiencies, and recommends corrective actions. In addition, a verbal debriefing will also be given to designated GA Sayreville personnel. The written report will be submitted to GA Sayreville and will include who will be responsible for ensuring that corrective measures are implemented. Fixed Laboratory TSAs - If data quality issues are consistently noted during data validation, this may trigger the need for a laboratory audit. Laboratory audits may be conducted by designated qualified Roux Associates personnel. The fixed laboratory TSA includes a review of the following areas: QA organization and procedures (including the Laboratory QA Plan); Personnel training and qualifications; Facility security; Sample log-in procedures; Sample storage facilities; ROUX ASSOCIATES, INC GER130501Y.189/QAPP

48 D R A F T Analysis technique; Adherence to approved NJDEP analytical methods and the QAPP; Compliance with QA/QC objectives; Equipment, instrumentation and supplies kept on reserve; Instrument calibration and maintenance; and Data recording, reduction, review, and reporting, cleanliness and housekeeping. Preliminary results of the TSA will be discussed with the Laboratory Manager, Laboratory Project Manager, and Laboratory QA Manager during a verbal debriefing. Assessment findings will be documented and reported as described in Section 15.2 below. Data TSAs - Data audits would be performed by designated qualified Roux Associates personnel. These audits will ensure all calculations are being performed properly and will demonstrate the accuracy of the reported data and eliminate any potential systematic calculation errors Management of QAPP, Field, and Laboratory Non-Conformances The following sections describe actions that should be performed after a TSA has been performed Assessment Findings and Corrective Action Responses The results of the field sampling and fixed laboratory TSAs will be documented in written reports. In addition, verbal debriefings will also be held at the conclusion of all audits. The reports will be prepared by Roux Associates and will describe the scope of the TSA, summarize audit findings, and recommend corrective action. The report will be distributed to the appropriate personnel for response: the GA Sayreville Project Manager will be responsible for responding to the field sampling TSA report, and the Laboratory Manager will be responsible for addressing the fixed laboratory TSA report. Significant issues that are discovered during the TSA and which could potentially affect data quality or usability will be brought to the immediate attention of the appropriate personnel. The response to the TSA reports will include a description of the corrective action(s) to be implemented, the identities of the personnel responsible for implementing the corrective action, and the schedule for ROUX ASSOCIATES, INC GER130501Y.189/QAPP

49 D R A F T implementation/completion. All responses must be completed within a reasonable time period after issuance of the TSA report. The response will be reviewed by Roux Associates and, if all issues have been addressed appropriately and in a timely manner, no further action will be required. In the event that the corrective action(s) are inadequate or inappropriate, follow-up activities, including additional audits, will be conducted by Roux Associates. The complete TSA report, including resolution of any deficiencies, will be included in the QA reports to GA Sayreville Additional QAPP Non-Conformances Field Non-Conformances - Corrective action in the field may be needed whenever program changes are made (e.g., change in amount or timing of samples, etc.), or when sampling procedures and/or field analytical procedures require modification due to unexpected conditions. The GA Sayreville Project Manager will be responsible for approving and ensuring the corrective action is implemented by the field personnel. Corrective actions will be documented in the field notebook. Documentation will include: A description of the circumstances that initiated the corrective action; The action taken in response; The final resolution; and Any necessary approvals. No person performing work on the Ambient Air Monitoring Program will initiate corrective action without prior communication of findings to the GA Sayreville Project Manager. All corrective actions will take into account the possible effect on the data. Laboratory Non-Conformances - Corrective action in the laboratory may occur prior to, during, and after initial analyses. A number of conditions such as broken sample media, omissions, or discrepancies with chain-of-custody documentation and potentially high concentration samples may be identified during sample log-in or just prior to analysis. Following consultation with laboratory analysts and Laboratory Section Leaders, it may be necessary for the Laboratory QA Manager to approve the implementation of corrective action. The analytical methods specify some conditions during or after analysis that may automatically ROUX ASSOCIATES, INC GER130501Y.189/QAPP

50 D R A F T trigger corrective action or optional procedures. These conditions may include dilution of samples, additional sample extract cleanup, automatic reinjection/reanalysis when certain QC criteria are not met, loss of sample through breakage or spillage, etc. If the corrective action is not clear, the Laboratory QA Manager must notify the GA Sayreville Project Manager in writing (electronic communication is acceptable). All parties will decide and approve a subsequent corrective action procedure that will not adversely affect the achievement of project objectives. The Laboratory Section Leader, in consultation with the staff, will approve the required corrective action to be implemented by the laboratory staff. The Laboratory QA Manager will ensure implementation and documentation of the corrective action. If the non-conformance causes project objectives not to be achieved, the GA Sayreville Project Manager will be notified in writing. The GA Sayreville Project Manager may in turn contact all necessary parties for concurrence with the proposed corrective action. These corrective actions are performed prior to release of the data from the laboratory. The corrective action will be documented in both the laboratory s corrective action files and the narrative data report sent from the laboratory to GA Sayreville. If the corrective action does not rectify the situation, the laboratory will contact the GA Sayreville Project Manager in writing, who will determine the action to be taken and inform the appropriate personnel in writing. If necessary, a problem resolution audit will be conducted Data Validation and Data Assessment Non-Conformances The need for corrective action may be identified during either data validation or data assessment. Potential types of corrective action may include data qualification or reanalysis of samples by the laboratory. These actions are dependent upon whether the data to be collected is necessary to meet the required QA objectives. If the independent data validator identifies a corrective action situation, GA Sayreville will be responsible for informing the appropriate personnel. All corrective actions of this type will be documented by GA Sayreville and maintained in the project files. ROUX ASSOCIATES, INC GER130501Y.189/QAPP

51 D R A F T 16.0 DATA REVIEW, VERIFICATION, VALIDATION, AND USABILITY The following sections provide details regarding data review, verification, validation, and usability Data Review, Verification, and Validation All data generated through field activities, or by the laboratory operation, will be validated prior to reporting. No data will be disseminated by GA Sayreville until it has been subjected to the procedures summarized below. Field Sampling Data - Field data will be verified by each person performing the tasks. These data will be verified for completeness and correctness. Field sampling data will also be independently reviewed by Roux Associates to ensure that records are complete, accurate, and legible, and to verify that the sampling procedures are in accordance with the protocols specified in the QAPP. GA Sayreville personnel performing the verification tasks will sign the field notes after verification. Verification will include all field notes, field sampling forms, and chain-ofcustodies. Sample collection information will be transcribed directly into the field notebook. If errors are made, results will be legibly crossed out, initialed, and dated by the person recording the data and corrected in a space adjacent to the original (erroneous) entry. Each member of the field sampling team will be responsible for an internal verification of the transcribed information. External verification of the field records by Roux Associates will verify that: Logbooks and standardized forms have been filled out completely and that the information recorded accurately reflects the activities that were performed; Records are legible, entries are signed and dated, data are not obliterated, changes are initialed, dated, and explained; and Sample collection, handling, preservation, and storage procedures were conducted in accordance with the protocols described in the QAPP and that any deviations were documented and approved by the appropriate personnel. Field Analysis Data - Each member of the sampling team performing field tasks will verify their own data at the conclusion of each day for completeness and correctness. Field analysis data will also be independently verified by Roux Associates to ensure that records are complete, accurate, and legible, and to verify that the calibration procedures are in accordance with the protocols specified in the QAPP. Personnel performing the verification tasks will sign the field ROUX ASSOCIATES, INC GER130501Y.189/QAPP

52 D R A F T notes after verification. Verification will include all field logbook notes and equipment calibration forms. Field analysis information will be transcribed directly into the field notebook or onto standardized forms. If errors are made, results will be legibly crossed out, initialed, and dated by the person recording the data and corrected in a space adjacent to the original (erroneous) entry. Each member of the field sampling team will be responsible for an internal verification of the transcribed information. External verification of the field analysis records by Roux Associates will verify that: Field notebooks and standardized forms have been filled out completely and that the information recorded accurately reflects the activities that were performed; Records are legible, entries are signed and dated, data are not obliterated, changes are initialed, dated, and explained; and Calibration procedures were conducted in accordance with the protocols described in the QAPP and that any deviations were documented and approved by the appropriate personnel Fixed Laboratory Data Prior to the release of any data from the laboratory, the data will be verified and approved by laboratory personnel. This will consist of a review by the person performing the work and by supervisory personnel. The laboratory used in the program must have a procedure in place for documenting all levels of data review. Prior to being released as final, laboratory data will proceed through a tiered review process. Data verification starts with the analyst or technician who performs a 100 percent review of the data to ensure the work was done correctly the first time. It is the responsibility of the analyst or technician to ensure that the verification of data in his or her area is complete. The data reduction and initial verification process must verify that: Sample preparation and analysis information is correct and complete. Results are correct and complete; The appropriate NJDEP approved methods have been followed and are identified in the project records; Proper documentation procedures have been followed; All non-conformances have been documented; and ROUX ASSOCIATES, INC GER130501Y.189/QAPP

53 D R A F T Project-specific requirements have been met. Following the completion of the initial verification by the analyst or technician, a systematic check of the data will be performed by an experienced peer, Laboratory Section Leader, or designee. This check will be performed to ensure that initial review has been completed correctly and thoroughly. Included in this review will be an assessment of the acceptability of the data with respect to: Adherence of the procedure used to the referenced methods and specific instructions; Correct interpretation of data (e.g., mass spectra, chromatographic interferences, etc.); Correctness of numerical input when computer programs are used (checked randomly) and numerical correctness of calculations and formulas (checked randomly); Acceptability of QC data; Documentation that instruments were operating according to method specifications (calibrations, performance checks, etc.); Documentation of dilution factors, standard concentrations, etc.; Sample holding time assessment; and Nonconforming events have been addressed by corrective action as defined on a nonconformance memo; A third-level review will be performed by the Laboratory Project Manager before results are submitted to the client. This review serves to verify the completeness of the data report and to ensure that project requirements are met for the analyses performed. The items to be reviewed will include: Results are present for every sample in the analytical batch or reporting group; Every parameter or target compound requested is reported; The correct units and correct number of significant figures are utilized; All non-conformances, including holding time violations, and data evaluation statements that impact the data quality are accompanied by clearly expressed comments from the laboratory; and The final report is legible, contains all the supporting documentation required by the project, and is in either the standard format or in the client-required format.; ROUX ASSOCIATES, INC GER130501Y.189/QAPP

54 D R A F T A narrative to accompany the final report will be finalized by the Laboratory Project Manager. This narrative will include relevant comments, including data anomalies and non-conformances Data Usability The purpose of this section is to indicate the methods to ensure that the validated laboratory data collected for this investigation are consistent with the established project quality objectives, to ensure the quality of data was sufficient for its intended use, and to identify any anomalies in the data Precision The impact of analytical imprecision, project imprecision, and overall imprecision (when both analytical and project precision tests show problems) on data usability will be assessed by an independent data validator (provided by Roux Associates). If the precision results yield data that are not usable, a data validation memo will be drafted to identify how this problem will be resolved Accuracy If field or laboratory contamination exists, the impact on the data will be evaluated by the independent data validator. The direction of bias for contamination will be identified. Overall contamination and accuracy/bias will be reviewed for each analytical parameter. The data usability assessment will include any limitations on the use of the data, if it is limited to a particular data set, parameter, or laboratory. If the accuracy results yield data that are not usable, a data validation memo will be drafted to recommend how this problem can be resolved Representativeness If field duplicates indicate spatial variability, the independent data validator will evaluate the impact on the data. Overall sample representativeness will be evaluated for each analytical parameter. The data usability assessment will include any limitations on the use of the data, if limited to a particular data set, parameter, or laboratory. If the results of the evaluation of representativeness yield data that are not usable, a data validation memo will be drafted to recommend how this problem can be resolved. ROUX ASSOCIATES, INC GER130501Y.189/QAPP

55 D R A F T Completeness Completeness is the ratio of the number of valid sample results to the total number of samples analyzed or processed. Following completion of the testing, the percent completeness will be calculated. Overall completeness will be reviewed for each analytical parameter. The data usability assessment will include any limitations on the use of the data, if limited to a particular data set, parameter, or laboratory. If the results of the evaluation of completeness yield data that are not usable, a data validation memo will be drafted to recommend how this problem can be resolved Data Limitations and Actions The field and laboratory data collected during this investigation will be used to achieve the objectives identified in Section 6.0 of this QAPP. The QC results associated with each analytical parameter will be compared to the objectives presented in this QAPP. Data generated in association with QC results meeting the stated acceptance criteria (i.e., data determined to be valid) will be considered usable for decision-making purposes. Limitations on the use of the data will be stated and explained, if necessary. In addition, the data obtained may be both qualitatively and quantitatively assessed on a project wide, location-specific, and parameterspecific basis. Results of the measurement error assessments may be applied against the site as a whole; any conclusions will be documented in data validation or QA reports. Data generated in association with QC results not meeting the stated acceptance criteria may still be considered usable for decision-making purposes, depending on certain factors. This assessment will be performed by Roux Associates. In general, qualified data will still be usable for project objectives. Qualified data exhibiting concentrations close to the project Action Levels will be evaluated further to determine if there is a potential bias caused by the QC non-conformance, which may have caused a false exceedance or a false non-exceedance. Factors to be considered in this assessment of field and laboratory data will include, but not necessarily be limited to, the following: Conformance to the field methodologies proposed in the QAPP; Conformance to the USEPA and NJDEP methods provided in the QAPP; Adherence to proposed sampling strategy; ROUX ASSOCIATES, INC GER130501Y.189/QAPP

56 D R A F T Presence of elevated detection limits due to matrix interferences present in background ambient air or contaminants present at high concentrations; Presence of analytes not expected to be present; Conformance to validation protocols included in the QAPP for both field and laboratory data; Unusable data sets based on the data validation results; Data sets identified as usable for limited purposes based on the data validation results; Effect of qualifiers applied as a result of data validation on the ability to achieve the project objectives; Status of all issues requiring corrective action, as presented in the QA reports to management; Effect of nonconformance (procedures or requirements) on project objectives; Adequacy of the data as a whole in meeting the project objectives; Identification of any remaining data gaps and need to reevaluate data needs; Examination of site-specific and regional meteorological data to identify the source(s) of the elevated ambient concentrations; and Examine collateral data collected at the site (e.g., elevated metals concentrations should coincide with elevated particulate concentrations at the same site). Every attempt will be made to eliminate any sources of sampling and analytical error as early as possible in the Ambient Air Monitoring Program. An ongoing data assessment program throughout the Ambient Air Monitoring Program will also assist in the early detection and correction of problems, thereby ensuring that project objectives are met. Reconciliation with the project objectives will have been considered to have been met if the measurement performance criteria from Section 6.0 are met. If the data usability indicates that the project quality objectives in Section 6.0 have not been met, then the project management team will meet to determine any additional work to be performed. ROUX ASSOCIATES, INC GER130501Y.189/QAPP

57 D R A F T 17.0 REPORTING, DOCUMENTS, AND RECORDS Roux Associates will generate QA reports to document the investigation of problems identified during sampling and analysis, and the proper corrective measures taken to address the problems. The QA reports may include: All results of field and laboratory audits; Problems noted during data validation and assessment; and Significant QA/QC problems, recommended corrective actions, and the outcome of corrective actions. QA reports will be prepared and submitted on an as-needed basis Records All records will be maintained by Roux Associates. A copy of all files will also be kept at the GA Sayreville facility. ROUX ASSOCIATES, INC GER130501Y.189/QAPP

58 D R A F T 18.0 REFERENCES Airtek Environmental Corporation, November Quality Assurance Project Plan for the Environmental Community Air Monitoring Program and Waste Management Plan Greenwich Street/ Thames Street. Ecotech Hi-Vol 3000 Operations Manual. Idaho Department of Environmental Quality, June QAPP for the State of Idaho Ambient Air Quality Monitoring Program. Met One BAM-1020 Operations Manual. New Jersey Department of Environmental Protection, September QAPP New Jersey Ambient Monitoring Program for Fine Particulates (PM 2.5 ). United States Environmental Protection Agency, December QAPP: PM 2.5 Speciation Trends Network Field Sampling. United States Environmental Protection Agency, June QAPP for the Air Toxics Monitoring Program. ROUX ASSOCIATES, INC GER130501Y.189/QAPP

59 Table 1. Project Organization Chart, Ambient Air Monitoring Program Quality Assurance Project Plan, Gerdau Ameristeel Sayreville, Sayreville, New Jersey ROUX ASSOCIATES, INC. GER130501Y.189/T1

60 Site Location N Scale (Approximate) 0 1 km Figure 1 Location of Gerdau AmeriSteel Sayreville Source: USGS 7.5 Minute Series, South Amboy NJ-NY Quadrangle, 1995; Site Boundary Approximate

61 CROSSMAN RD. LEGEND 1 WEST OF MILL EAST - NORTHEAST OF MILL MONITORING SITE - EAST OF MILL GERDAU AMERISTEEL SAYREVILLE MODZELEWSKI TER. HORSESHOE RD. GUILFOYLE TER. STEGIEL PL. WILBUR TER ft 1 Title: \GER1305Y\GER01Y\189\GER CDR MAIN ST. Prepared for: ROUX AMBIENT PARTICULATE MONITORING LOCATIONS GERDAU AMERISTEEL SAYREVILLE SAYREVILLE, NEW JERSEY Compiled by: G.S. Date: 18DEC07 Prepared by: J.A.D. Scale: AS SHOWN ROUX ASSOCIATES, INC. Project Mgr.: G.S. Office: NY Environmental Consulting & Management File No.: GER CDR Project No.: Y FIGURE 2