BPM006875 Eurofins Eaton Analytical Clarifications.pdf

Ana Machiche <machiche.ana@azdeq.gov>

RE: BPM006875 Clarification Questions - Response Due COB, Thursday, June 26, 1 message

Samantha Carney <Samantha.Carney@et.eurofinsus.com> Wed, Jun 25, 2025 at 3:00 PM To: "machiche.ana@azdeq.gov" <machiche.ana@azdeq.gov> Cc: Bradley Cahoon <Bradley.Cahoon@et.eurofinsus.com>, Tom French <Tom.French@et.eurofinsus.com>

Hello Ana, Please see the attached response for BPM006875 Clarification Questions. We appreciate the opportunity to respond.

Warmest regards, Samantha Y. Carney

Sales Operations Manager

Eurofins Drinking Water Testing

Mobile: +1 717-497-5090

E-Mail: Samantha.Carney@ET.EurofinsUS.com

Please note that our standard Terms and Conditions apply to the prices quoted.

From: Ana Machiche <machiche.ana@azdeq.gov> Sent: Monday, June 23, 2025 8:03 AM To: Bradley Cahoon <Bradley.Cahoon@et.eurofinsus.com> Cc: Samantha Carney <Samantha.Carney@et.eurofinsus.com>; Tom French <Tom.French@et.eurofinsus.com> Subject: BPM006875 Clarification Questions - Response Due COB, Thursday, June 26, 2025

Unverified Sender: The sender of this email has not been verified. Review the content of the message carefully and verify the identity of the sender before acting on this email: replying, opening attachments or clicking links.

Hi Brad, Please see attached proposal clarification questions, due by COB, Thursday, June 26, 2025.

7/1/25, 2:46 PM State of Arizona Mail - RE: BPM006875 Clarification Questions - Response Due COB, Thursday, June 26, 2025 https://mail.google.com/mail/u/0/?ik=58f7a56870&view=pt&search=all&permthid=thread-a:r8731928091339888463%7Cmsg-f:1835940016329754099… 1/2 mailto:Samantha.Carney@ET.EurofinsUS.com mailto:Samantha.Carney@ET.EurofinsUS.com https://cdnmedia.eurofins.com/eurofins-us/media/12162893/updated-eurofins-eaton-analytical-terms-and-conditions-nov-2023.pdf mailto:machiche.ana@azdeq.gov mailto:Bradley.Cahoon@et.eurofinsus.com mailto:Bradley.Cahoon@et.eurofinsus.com mailto:Samantha.Carney@et.eurofinsus.com mailto:Samantha.Carney@et.eurofinsus.com mailto:Tom.French@et.eurofinsus.com

In addition, the evaluation team would like to meet to view the sampling schedule spreadsheet that will be provided to ADEQ. I will send some available dates/times in a separate email.

If you have any questions, please let me know.

Thank you, Ana Machiche

Contract Manager

Arizona Department of Environmental Quality

1110 W. Washington St., #160

Phoenix, AZ 85007

602-771-4140

AZDEQ.gov

BPM006875 MAP Clarification Questions_EEA Response 06252025.pdf 480K

7/1/25, 2:46 PM State of Arizona Mail - RE: BPM006875 Clarification Questions - Response Due COB, Thursday, June 26, 2025 https://mail.google.com/mail/u/0/?ik=58f7a56870&view=pt&search=all&permthid=thread-a:r8731928091339888463%7Cmsg-f:1835940016329754099… 2/2 https://www.google.com/maps/search/1110+W.+Washington+St.,+%23160+%0D%0A+%0D%0A+Phoenix,+AZ+85007?entry=gmail&source=g https://www.google.com/maps/search/1110+W.+Washington+St.,+%23160+%0D%0A+%0D%0A+Phoenix,+AZ+85007?entry=gmail&source=g https://azdeq.gov/ https://mail.google.com/mail/u/0/?ui=2&ik=58f7a56870&view=att&th=197a91b7b64285f3&attid=0.1&disp=attd&safe=1&zw https://mail.google.com/mail/u/0/?ui=2&ik=58f7a56870&view=att&th=197a91b7b64285f3&attid=0.1&disp=attd&safe=1&zw

Clarification Questions for BPM006875 Monitoring Assistance Program (MAP) June 23, 2025

ADEQ Requests your Organization provide a completed clarification response to items below via email to ADEQ (Ana Machiche: Machiche.Ana@azdeq.gov) by COB, Thursday, June 26, 2025.

1. Attachment 9 – Proposed Subcontractors:

Clarify the analytical methods listed for PCBs on Page 60. The proposal references EPA Method 505 for PCB analysis; however, there is no mention of Method 508A, which is necessary for compliance determinations if PCBs are detected using Method 505 or 508.

According to 40 CFR § 141.24(h)(13):

Systems analyzing for PCBs may use Methods 505, 508, 508.1, or 525.2.

If PCBs are detected via Method 505 or 508, the sample must be reanalyzed using Method 508A to quantitate PCBs as decachlorobiphenyl.

Compliance with the PCB MCL must be based on the results of Method 508A.

Additionally, the certification under Method 525.2 does not cover PCBs, only other analytes.

Please confirm whether Eurofins’ lab is certified and capable of performing EPA Method 508A, or if a subcontractor will be used for this purpose? This is essential for ADEQ to ensure the contract fulfills all regulatory requirements for PCB compliance determinations.

Eurofins Response:

There are no laboratories certified in Arizona for Drinking Water matrices (SDWA) for method EPA 508A (PCBs as decachlorobiphenyl). In the 25 years of our experience with managing SDWA testing in Arizona, including 20 for the Monitoring Assistance Program (MAP), we have never found a detection of the individual Arochlor compounds using EPA 505 as a certified method. Therefore, EPA 508A was not needed. No Eurofins laboratories holding SDWA certification have EPA 508A as a method listed, and no other laboratories hold this certification in Arizona. There is a State of Texas laboratory in Austin, TX that does perform this method, but they are not certified in Arizona. Should the testing for EPA 508A ever be needed this State Lab may be a potential source.

Alternatively, we recommend using our AZ certified EPA 505 method where we would report DCB by conversion using the 508A conversion tables.

Here is a summary of our method – We treat DCB as a surrogate with acceptance limits of 70%-130% recovery. These are the same surrogate recovery limits that we use for their other surrogate, 2,3,4,9-tetrachloro-m-xylene (TCMX). Using DCB as a surrogate makes our reporting of PCBS as DCB no more or less accurate than 508A. We do not use the DCB surrogate percent recovery in the conversion calculation to report PCBs as DCB. Our process is that we calibrate each Aroclor individually, so if a sample did have an Aroclor detection, that Aroclor would be quantitated using the corresponding Aroclor calibration curve. Each individual Aroclor could then be converted to DCB. The conversion we use is from EPA Method 508A. An example of how we use the calculation is; if a sample had 0.56 ug/L of Aroclor 1016, we would multiply that result by 1.92 (the percentage in the Decachlorobiphenyl Equivalent from the 508A conversion table) to get

1.08 ug/L of the DCB equivalent, which would be the result that would be reported for PCBs as DCB. Furthermore, commentary on 508A states, because 508A converts all PCBs to DCB, this method cannot identify specific parent PCBs. It can also produce false positives and may overestimate the original PCB amount. If DCB is detected at or above

0.5 µg/L, further analysis with another approved method is advised for accurate identification and measurement. Method 508A was last updated in 1989. Therefore, we believe, in the absence of an available 508A lab and based on the information provided here supporting the superior methodology of EPA 505, the Eurofins approach is best able to meet the intent of providing DCB data for any PCB detects.

2. Attachment 10 – Experience and Capacity:

2.1 Page 96, under 1.13 Arizona Required certificate(s) and Business license(s) mentions “See included documents following Section 5.0 below”. Also referenced Section 5.0 on page 101, 102.

Clarify if the citation should be “See Attachment 9”.

It was in error that the proposal referred to Section 5.0. The correct section where documents can found are in Attachment 9.

2.2 Question 2.4, page 100:

Response mentions 5 additional backup samplers, please provide names of the backup samplers.

In response to the question, Eurofins reconfirmed the names and status of the SWUM sampling team. The confirmed counts, names and status are as follows. SWUM maintains 4 full-time samplers with 4 additional backup samplers providing sampling resiliency for the MAP program.

Below are the designated samplers for SWUM.

Jeff Rhodes - Primary Amy George - Primary Ben Meyer - Primary

Brandon Garcia - Primary Zach Wene - Backup Blake Wene - Backup Mike Molina - Backup Jason Long - Backup

2.3 Clarify sampler conflict of interest with the drinking water systems, how will this be avoided and disclosed to ADEQ?

Eurofins Response:

Southwestern Utility Management Inc. (SWUM) is listed as the certified operator and report-to contact for many water systems in the MAP project. There are a few that they own. Since 2020, when EEA first partnered with SWUM for the MAP project, there has never been an instance of any conflict of interest with these systems. The MAP sampling, testing, and reporting is held separate from any of the system management and/or ownership by SWUM.

Should any such conflict(s) of interest arise, this will be directly communicated to the ADEQ MAP Coordinator, in the usual manner of communication. This information will be communicated prior to any sampling for the water system that the potential conflict may be applicable to, so as to enable a multi-party determination as to the status of any conflict.

3. Attachment 12 – Method of Approach:

Page 107 Question #2 Response - Visibility of sampling schedule, clarify the frequency of when the MS Excel Worksheet will be provided to ADEQ?

Eurofins Response:

Sampling schedule information, obtained through our proprietary MAP project sampling program, can be provided to ADEQ on any agreed upon schedule.

We can provide an example of this to ADEQ in a virtual meeting, scheduled so as to have the ADEQ interested parties and EEA staff in attendance.

4. Page 110 Clarification to Attachment 13 Pricing Sheet

What is the compositing fee? What is the criteria to determine which samples are composited?

There is no composite fee charged to ADEQ. The compositing of certain methods affords EEA to ability to limit the number of singular samples (not composited) in our backlog of analytical production. This allows for fewer samples for analysis, with less impact on our production.

According to 40 CFR Part 141, we are allowed to composite up to five samples, sampled on the same day. This only applies to EPA Methods 515.4, 525.2, 531.2, 547, 548, 549 and 1613B. Water systems serving < 3300 in population are allowed to be composited across systems, while those serving > 3300 in population are composited only within the system (if multiple EPDS sites are in such system).

5. Attachment 13 – Pricing Sheet:

5.1 Verify listed methods for PFOS, PFNA, PHFxS and GenX

Eurofins Response Method 537.1 REV 2.0

5.2 For line 1.92 – PFAS Sample Blank, if this needs to be analyzed, will the cost be

$0.00 as indicated in the pricing sheet?

Eurofins Response:

For the PFAS Field Reagent Blank (FRB), required by the method for compliance sampling, there is a cost of $0.00 to ADEQ, if the testing is needed due to detections of analytes of interest in the associated Field Sample (FS).

Ana Machiche <machiche.ana@azdeq.gov>

RE: BPM006875 Second Clarification Item - Response Due COB, Thursday, July 9, 1 message

Samantha Carney <Samantha.Carney@et.eurofinsus.com> Wed, Jul 2, 2025 at 8:12 AM To: Ana Machiche <machiche.ana@azdeq.gov>, Bradley Cahoon <Bradley.Cahoon@et.eurofinsus.com> Cc: Tom French <Tom.French@et.eurofinsus.com>

Hello Ana, Attached is Eurofins Eaton Analytical’s response to BPM006875 MAP 2nd Clarification. If you have any questions, please let me know.

Thank you. Happy Holiday Weekend!

Samantha Y. Carney

Sales Operations Manager

Eurofins Drinking Water Testing

Mobile: +1 717-497-5090

E-Mail: Samantha.Carney@ET.EurofinsUS.com

Please note that our standard Terms and Conditions apply to the prices quoted.

From: Ana Machiche <machiche.ana@azdeq.gov> Sent: Tuesday, July 01, 2025 2:32 PM To: Bradley Cahoon <Bradley.Cahoon@et.eurofinsus.com> Cc: Samantha Carney <Samantha.Carney@et.eurofinsus.com>; Tom French <Tom.French@et.eurofinsus.com> Subject: BPM006875 Second Clarification Item - Response Due COB, Thursday, July 9, 2025

Unverified Sender: The sender of this email has not been verified. Review the content of the message carefully and verify the identity of the sender before acting on this email: replying, opening attachments or clicking links.

Hi Brad, 7/9/25, 1:42 PM State of Arizona Mail - RE: BPM006875 Second Clarification Item - Response Due COB, Thursday, July 9, 2025 https://mail.google.com/mail/u/0/?ik=58f7a56870&view=pt&search=all&permthid=thread-a:r6401255453534501453%7Cmsg-f:1836548538898421363… 1/2 mailto:Samantha.Carney@ET.EurofinsUS.com mailto:Samantha.Carney@ET.EurofinsUS.com https://cdnmedia.eurofins.com/eurofins-us/media/12162893/updated-eurofins-eaton-analytical-terms-and-conditions-nov-2023.pdf mailto:machiche.ana@azdeq.gov mailto:Bradley.Cahoon@et.eurofinsus.com mailto:Bradley.Cahoon@et.eurofinsus.com mailto:Samantha.Carney@et.eurofinsus.com mailto:Samantha.Carney@et.eurofinsus.com mailto:Tom.French@et.eurofinsus.com

Please see attached proposal clarification item, due COB, Thursday, July 9, 2025.

If you have any questions, please let me know.

Thank you, Ana Machiche

Contract Manager

Arizona Department of Environmental Quality

1110 W. Washington St., #160

Phoenix, AZ 85007

602-771-4140

AZDEQ.gov

BPM006875 MAP 2nd Clarification Item_EEA Response 07022025.pdf 144K

7/9/25, 1:42 PM State of Arizona Mail - RE: BPM006875 Second Clarification Item - Response Due COB, Thursday, July 9, 2025 https://mail.google.com/mail/u/0/?ik=58f7a56870&view=pt&search=all&permthid=thread-a:r6401255453534501453%7Cmsg-f:1836548538898421363… 2/2 https://www.google.com/maps/search/1110+W.+Washington+St.,+%23160+%0D%0A+%0D%0A+Phoenix,+AZ+85007?entry=gmail&source=g https://www.google.com/maps/search/1110+W.+Washington+St.,+%23160+%0D%0A+%0D%0A+Phoenix,+AZ+85007?entry=gmail&source=g https://azdeq.gov/ https://mail.google.com/mail/u/0/?ui=2&ik=58f7a56870&view=att&th=197cbb2a69cd9673&attid=0.1&disp=attd&safe=1&zw https://mail.google.com/mail/u/0/?ui=2&ik=58f7a56870&view=att&th=197cbb2a69cd9673&attid=0.1&disp=attd&safe=1&zw

Clarification Questions for BPM006875 Monitoring Assistance Program (MAP) July 1, 2025

2nd Clarification Request

ADEQ Requests your Organization provide a completed clarification response to item(s) below via email to ADEQ (Ana Machiche: Machiche.Ana@azdeq.gov) by COB, Thursday, July 9, 2025.

1. Attachment 10 – Experience and Capacity:

Eurofins Eaton Analytical’s response submitted June 25, 2025 to first clarification request indicated Jason Long as a back-up sampler. Please provide Jason’s resume.

Eurofins Response:

Please see attached resume for Jason Long mailto:Machiche.Ana@azdeq.gov

Jason T. Long

Jlong954@gmail.com 208 West Moonlight Trail Casa Grande, AZ.

85122

(520) 431-7723

Work Experience

Rural Water Association of Arizona January 2012 – September 2019

Executive Director / Source Water Specialist

Executive Director o Responsible for planning, organization, and direction of the organization’s operations and programs.

o Developed and executed consistent inventory and cost accounting policies, procedures, and operational reporting/metrics.

o Overseen and reported monthly on the organization’s results to the board of directors.

o Prepared accurate and timely analyses that capture and communicate fundraising results, changes, and performance trends.

o Provided leadership to and managed the efforts of site staff to ensure appropriate support of all departments.

o Supervised the development of operations-based financial modeling.

o Coordinated and lead annual budget reviews, monthly and quarterly reviews, and periodic forecast updates with operational and senior management for all locations.

o Developed o Maintained a diverse, highly qualified staff and volunteers by providing career coaching, growth, and personal development for workers.

o Ensured that services and funding relationships are robust enough to meet or exceed strategic goals and objectives of the Association.

Source Water Specialist o Provided technical assistance to communities in the formation of source water protection plans.

o Develop and implement a plan to address the state specific source water protection needs of rural and small community water systems.

o Provide assistance and support in facilitating the implementation of source water protection plans.

o Facilitate and mediate planning meetings. Provide presentations and assistance to local officials, community groups, and others.

o Write reports and develop informational articles for dissemination.

o Respond to inquiries from facilities, consumers, governmental agencies, and others regarding technical matters.

o Act as a liaison to create better coordination, communication and collaboration between rural and small community multi-jurisdictional entities and local, county, state and federal agencies.

Long Water Management, LLC. August 2005 - Present

Owner / Remote Operator o Independently operate, repair, and inspect water/wastewater treatment facilities following all local, state and federal regulations, policies and procedures to ensure environmental compliance.

o Conduct periodic inspections of various water/wastewater facilities and perform routine operations and maintenance.

o Collect samples and identify concentrations of chemical, physical or biological characteristics of water and wastewater as required.

o Gather and test water samples for plant efficiency. Conduct maintenance on the water/wastewater systems and general housekeeping duties; calibrate, modify, or repair instrumentation and control equipment including recorders, flow meters, and other water quality monitoring equipment.

o Follow each facilities Environmental, Health and Safety Policies, and report unsafe conditions as required. Maintain a variety of records related to inspections, maintenance activity, water supply, consumption, and wastewater treatment and collection.

o Perform other related duties as needed to maintain optimal operational efficiency.

Ak-Chin Indian Community September 2001 - December 2010

Water / Wastewater Operations Manager o Managed a wide range of water/wastewater treatment facilities that included; standard ground water treatment, MBR and LPRO systems.

o Successfully supervised a staff of 14 operators while minimizing expenses through overtime.

o Managed resources and an annual budget of 7 million dollars.

o Prepared weekly, monthly and annual budgeting reports as required.

o Participated in the development of legislative/regulatory issues pertaining to water and wastewater quality at authority level meetings throughout the state.

o Tracked changes and improvements to meet the requirements of regulations.

o Prepared/reviewed monthly, quarterly and annual reports and reported findings to regulatory agencies

Certification s ADEQ

Water Treatment Specialist Grade III Water Distribution Specialist Grade III Wastewater Treatment Specialist Grade III Wastewater Collection Specialist Grade II Water Lab Analyst Wastewater Lab Analyst

ABPA

Certified Backflow Tester

NICS

40 Hour HAZWOPER Certified Incident Command Certified

ICS MAG 300, MGT – 343

ICS 100, 200, 700 and 800 First Aid and CPR Certified

Education / Skill

Central Arizona College 2008 - 2012

Environmental Engineering Microbiology Chemistry