GLA_Att.9_-_Proposed_Subcontractors_certs_QAP.pdf

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Master Agreement AZ|CTR072297
Contract number
CTR072297
Issued by
Arizona

About this file

This document is a Request for Proposal (RFP) Solicitation from the Arizona Department of Environmental Quality (ADEQ) for Assessment and Remediation of Hazardous Substances, with the primary contractor being GeoLogic Associates. The solicitation includes detailed information about proposed subcontractors, their certifications, and quality assurance/quality control (QA/QC) measures. The document involves multiple subcontractors including Turner Laboratory, Orange Coast Analytical, Cascade Drilling and Environmental Services, Yellow Jacket Drilling, The Fehling Group, Verdad Group LLC, Carollo Engineers, and Jones Environmental.

The subcontractors will provide various specialized services including laboratory analytical services, drilling, well installation, sample collection, health risk assessments, field services, and environmental engineering. Each subcontractor is designated to perform specific tasks, with percentage contributions ranging from 3-4% to 15-20% of the total contract work. The proposed subcontractors have detailed quality assurance plans, with each providing unique capabilities such as mobile laboratory services, sonic drilling, environmental sampling, hydraulic profiling, and specialized analytical testing. The document emphasizes the importance of maintaining high standards of data quality, methodology compliance, and technical competence across all contracted services.

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Request for Proposal

Solicitation No. BPM006010

ASRAC Assessment and Remediation of Hazardous Substances

Arizona Department of Environmental Quality (ADEQ)

1110 W. Washington Street Phoenix, AZ 85007

Solicitation Attachment – Proposed Subcontractors | Revision No. 1 | Revised 11-22

Attachment 9 – Proposed Subcontractors

Contractor Name: GeoLogic Associates

Check “NO” if you WILL NOT subcontract any portion of the Work and will therefore be performing all of the Work with your own personnel.

☐ NO, the Offeror will not subcontract any portion of the Work.

If you WILL subcontract any portion of the Work, check “YES” below and list the name(s) of persons or companies you propose to use as Subcontractors.

1. Fill in the information for each significant Subcontractor – indicate the type of work the Subcontractor will perform under the Contract and their approximate percentage of the total Contract work;

2. Provide copies of relevant certifications each person or firm possesses attached to this form; AND

3. Provide a description of quality assurance (QA) and quality control (QC) measures that you will use to ensure that

Subcontractor’s work meets the Contract requirements.

State may demand additional information about proposed Subcontractors as a precondition of Award.

X YES, the Offeror will use the Subcontractors listed below:

INFORMATION REGARDING THE SUBCONTRACTORS LISTED BELOW IS PROVIDED

FOLLOWING THIS FORM

No. Name and contact information Small business Work to be performed and QA/QC measures %

1 Turner Laboratory, Tucson, AZ

Elizabeth Kasik

(520) 882-5880

Yes

Laboratory Analytical Services Turner’s Quality Assurance Plan (QAP) conforms to the requirements specified in the Arizona Administrative Register, A.A.C. R9-14-601 et seq.

(October 2016), and the Manual for the Certification of Laboratories Analyzing Drinking Water, 5th Edition, EPA 815-R-05-004, (January 2005).

Turner’s policy is ensure that all analytical data generated and processed will be scientifically sound, legally defensible, of known and documented quality, and will accurately reflect the materials tested. This is accomplished by implementing quality control procedures that are monitored and assessed during the entire analytical process. Personnel shall be fully qualified to perform the analyses through the combination of education, training, and experience. The equipment and supplies shall be obtained as needed to provide for the utilization of established technology and methodology. The performance of personnel and equipment are continuously monitored and documented. Corrective action must be implemented and documented immediately if a quality problem arises. Turner’s QAP is attached.

3-4%

Arizona Department of Environmental Quality (ADEQ)

Solicitation Attachment – Method of Approach | Revision No. 1 | Revised 11-22

2.

Orange Coast Analytical

Tara Touvell

(480) 736-0960

No

Laboratory Analytical Services This Arizona-certified laboratory has a QAPP to ensure conformance with method requirements and any state of Arizona requirements for laboratory services.

3-4%

3. Cascade Drilling and Environmental Services

Andrew Whitsell

(425) 219-3920

No

Sonic drilling, well installation, direct push drilling, sample collection, earthwork for installation of remediation systems QA/QC for drilling and sample collection is done on several levels:

GLA prepares detailed technical specifications for all construction, including well drilling, construction and testing. We require that drillers keep a copy of the specification on site. Any deviations from the specification must be approved prior to implementation.

GLA provides constant oversight for all drilling, well installation, construction, and testing activities to ensure that the technical specifications are strictly followed.

Driller’s daily forms are an essential part of GLA’s QA/QC strategy in working with drillers.

GLA maintains QA forms for drilling activities. These forms are available to clients as soon as they are generated, if requested, and are appended to investigation and well installation reports. Forms include pipe tally forms, annular materials forms, sampling forms, aquifer testing forms, daily logs.

7-10%

4. Yellow Jacket Drilling

Eric Brue

(602) 425-4399

No

Drilling, well installation, direct push drilling, sample collection QA/QC for drilling and sample collection is done on several levels:

GLA prepares detailed technical specifications for all construction, including well drilling, construction and testing. We require that drillers keep a copy of the specification on site. Any deviations from the specification must be approved prior to implementation.

GLA provides constant oversight for all drilling, well installation, construction, and testing activities to ensure that the technical specifications are strictly followed.

Driller’s daily forms are an essential part of GLA’s QA/QC strategy in working with drillers.

GLA maintains QA forms for drilling activities. These forms are available to clients as soon as they are generated, if requested, and are appended to investigation and well installation reports. Forms include pipe tally forms, annular materials forms, sampling forms, aquifer testing forms, daily logs.

7-10%

Arizona Department of Environmental Quality (ADEQ)

5. The Fehling Group

Kurt Fehling

(707) 478-3484

Yes

Health Risk Assessment and Exposure Assessments The Fehling Group will provide weekly or bi-weekly status reports (as appropriate) to GLA to identify any questions or issues that may arise early in the assessment. GLA and The Fehling Group have several levels of quality assurance/quality control on each project we work on. First, each staff member is required to check their own work. That work product is then sent to their supervisor who re-checks their work. The third tier consists of the Project Manager who will review the final version of the draft deliverable in its entirety.

Finally, a staff member who has not been involved in the preparation of the deliverable conducts a full review, cross checks, all text to tables and spot checks significant calculations. Any required edits or alterations are provided to the Project Manager to address accordingly. In a broader sense, GLA and The Fehling Group frequently rely upon the EPA Data Quality Objectives (DQOs) and the associated processes. In fact, members of our team played a significant role in the creation of the DQO process while at EPA and one member of our team is the International chair of the ISO statistics committee. DQOs and QA aspects are inherently included in all projects.

3-4%

6 Verdad Group LLC

Matt Wallace

(520) 743-8553

Yes

Field Services Verdad Group LLC provides a variety of field services, including sampling (e.g., groundwater, soil vapor, soil), pump services, and remediation operations and maintenance. Their extensive equipment list (e.g., pumps, pump hoist rigs, etc.) and knowledge of computer control systems make them a valuable partner in hydrogeologic investigations. We anticipate using Verdad Group for pump services, aquifer testing assistance, and remediation system maintenance.

Because unanticipated conditions sometimes arise in the field, Verdad staff will be supervised in the field by GLA personnel to meet our QA/QC requirements.

3-4%

7 Carollo Engineers

George Maseeh

(520) 230-4729

No

Environmental Engineering The GLA team intends to subcontract with Carollo Engineers for larger-scale remediation projects where water treatment is required. Carollo is a full-service environmental engineering firm that includes civil, environmental, mechanical, structural, electrical, and instrumentation and control (EI&C) engineers, as well as scientists, planners, financial analysts, architects, CAD designers, and construction management professionals.

Clear Creek has a long and productive relationship teaming with Carollo. Clear Creek is currently a subcontractor to Carollo for TARP, a Superfund site (TCE; 1,4 dioxane; PFAS), for which Carollo has been contracted by the City of Tucson. Treated water from

15-20%

Arizona Department of Environmental Quality (ADEQ)

TARP is currently routed to the City’s recycled water system.

As with the TARP Superfund Project, QA/QC will be managed through regular (likely monthly) team meetings. The US EPA has found these to be of critical importance to anticipating roadblocks and challenges before they become a problem to the project timeline.

8 Jones Environmental

Christine Sotelo

(714) 449-9937

Yes

Laboratory Services Jones Environmental, Inc. provides mobile and stationary laboratory services. Their capabilities allow for real-time field screening results for air/soil gas, soil, and water analyses. Their QA/QC measures are governed by their laboratory method accreditations.

Jones Environmental was a valuable subcontracting partner in Clear Creek’s remedial investigation of the Stone-Grant WQARF site.

Jones Environmental is not an Arizona-certified laboratory, but does have Environmental Laboratory Accreditation Program (ELAP) certification. The data generated by the mobile lab will be confirmed by sending confirmatory samples to an Arizona-certified laboratory. In addition to the QA/QC measures that are integral to the laboratory methods, Clear Creek will provide 100% onsite supervision in the field to ensure DQOs are met.

4-6%

ARIZONA DEPARTMENT

OF HEALTH SERVICES

ENVIRONMENTAL LABORATORY LICENSE

is in compliance with Environmental Laboratory’s applicable standards for the State of Arizona and maintains on file a List of Parameters for which the laboratory is certified to perform analysis.

PERIOD OF LICENSURE FROM: TO:

Steven D. Baker, Chief Office of Laboratory Licensure & Certification Bureau of State Laboratory Services

Issued to:

Laboratory Director:

Owner/Representative: Mr. Michael J. McGovern

Turner Laboratories, Inc.

Elizabeth C. Kasik

03/24/2023 03/24/2024

AZ0066

Arizona Department Of Health Services Office of Laboratory Licensure and Certification 250 N.17th Avenue, Phoenix, Arizona 85007-3246

Laboratory Methods, Instrument & Softwares AZ License: AZ0066, Lab Name: Turner Laboratories, Inc.

SDW

Parameter EPA Method Certified On

ALKALINITY SM 2320B (2011) 10/27/1993 12:00:00 AM

ALUMINUM EPA 200.7 (4.4) 7/16/1996 12:00:00 AM

ALUMINUM EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

ANTIMONY EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

ARSENIC EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

BARIUM EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

BARIUM EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

BERYLLIUM EPA 200.7 (4.4) 11/30/1994 12:00:00 AM

BERYLLIUM EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

BROMIDE EPA 300.0 (2.1) 2/27/2013 12:00:00 AM

CADMIUM EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

CADMIUM EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

CALCIUM EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

CHLORIDE EPA 300.0 (2.1) 3/2/1992 12:00:00 AM

CHLORINE, TOTAL RESIDUAL AND FREE SM 4500-CL G (2011) 10/21/2016 2:36:54 PM

CHROMIUM TOTAL EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

CHROMIUM TOTAL EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

COBALT EPA 200.8 (5.4) 3/1/2017 11:12:23 AM

COLIFORMS, TOTAL AND E.COLI, BY

COLILERT (ONPG-MUG)

SM 9223B (2004) AND IDEXX 7/25/2006 12:00:00 AM

COLIFORMS, TOTAL, AND E. COLI BY

MODIFIED COLITAG

9223B (2004) AND MODIFIED COLITAG 10/21/2016 2:36:55 PM

COLOR SM 2120B (2011) 3/2/1992 12:00:00 AM

COPPER EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

COPPER EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

CORROSIVITY SM 2330B (2010) 3/2/1992 12:00:00 AM

CYANIDE EPA 335.4 (1.0) 10/6/1997 12:00:00 AM

EDB/DBCP EPA 504.1 (1.1) 11/14/1997 12:00:00 AM

EDB/DBCP - ADDITIONAL EPA 504.1 (1.1) 11/14/2097 12:00:00 AM

FLUORIDE EPA 300.0 (2.1) 7/16/1996 12:00:00 AM

3/7/2023 4:08:44 PM

Laboratory Methods, Instrument & Softwares AZ License: AZ0066, Lab Name: Turner Laboratories, Inc.

SDW

Parameter EPA Method Certified On

HALOACETIC ACIDS AND DALAPON BY GC-

ECD

EPA 552.2 (1.0) 7/11/2005 12:00:00 AM

HARDNESS EPA 200.7 (4.4), CA AND MG 12/5/2002 12:00:00 AM

HETEROTROPHIC PLATE COUNT SIMPLATE 9/20/2006 12:00:00 AM

HYDROGEN ION (pH) EPA 150.1 3/2/1992 12:00:00 AM

IRON EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

LEAD EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

MAGNESIUM EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

MANGANESE EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

MANGANESE EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

MERCURY EPA 245.1 (3.0) 11/21/1997 12:00:00 AM

MOLYBDENUM EPA 200.8 (5.4) 3/1/2017 11:12:23 AM

NICKEL EPA 200.7 (4.4) 11/30/1994 12:00:00 AM

NICKEL EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

NITRATE EPA 300.0 (2.1) 3/2/1992 12:00:00 AM

NITRITE EPA 300.0 (2.1) 12/23/1993 12:00:00 AM

ORTHOPHOSPHATE EPA 300.0 (2.1) 7/16/1996 12:00:00 AM

PESTICIDES AND PCBS BY GC EPA 505 (2.1) 2/24/2015 12:00:00 AM

RESIDUE, FILTERABLE (TDS) SM 2540 C (2011) 7/16/2006 12:00:00 AM

SELENIUM EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

SILICA EPA 200.7 (4.4) 7/16/1996 12:00:00 AM

SILICA SM 4500-SIO2C (2011) 7/16/2096 12:00:00 AM

SILVER EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

SILVER EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

SODIUM EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

SPECIFIC CONDUCTANCE SM 2510B(2011) 3/18/1998 12:00:00 AM

STRONTIUM EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

SULFATE EPA 300.0(2.1) 3/2/1992 12:00:00 AM

THALLIUM EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

TURBIDITY, NEPHELOMETRIC (NTU) EPA 180.1 (2.0) 3/2/1992 12:00:00 AM

URANIUM EPA 200.8 (5.4) 10/6/2010 12:00:00 AM

VANADIUM EPA 200.8 (5.4) 3/1/2017 11:12:24 AM

SDW

Parameter EPA Method Certified On

VOCS BY GC/MS EPA 524.2 (4.1) 1/15/2003 12:00:00 AM

VOCS BY GC/MS-ADDITIONAL EPA 524.2 (4.1) 1/15/2003 12:00:00 AM

ZINC EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

ZINC EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

Total Count: 63

SW

Parameter EPA Method Certified On

ALUMINUM EPA 6010C 5/13/1998 12:00:00 AM

ANTIMONY EPA 6010C 5/13/1998 12:00:00 AM

ARSENIC EPA 6010C 5/13/1998 12:00:00 AM

BARIUM EPA 6010C 5/13/1998 12:00:00 AM

BERYLLIUM EPA 6010C 5/13/1998 12:00:00 AM

BORON EPA 6010C 3/1/2021 1:10:42 PM

C10-C32 HYDROCARBONS 8015AZ1 2/9/1999 12:00:00 AM

CADMIUM EPA 6010C 5/13/1998 12:00:00 AM

CALCIUM EPA 6010C 5/13/1998 12:00:00 AM

CHROMIUM, TOTAL EPA 6010C 5/13/1998 12:00:00 AM

CLOSED SYSTEM PURGE AND TRAP

EXTRACT. VOCS

EPA 5035A 12/5/2006 12:00:00 AM

COBALT EPA 6010C 5/13/1998 12:00:00 AM

CONTINUOUS LIQUID-LIQUID EXTRACTION EPA 3520C 5/13/1998 12:00:00 AM

COPPER EPA 6010C 5/13/1998 12:00:00 AM

CORROSIVITY PH DETERMINATION EPA 9040C 12/5/2006 12:00:00 AM

DISSOLVED IN WATER EPA 3005A 11/15/1997 12:00:00 AM

FLASH POINT BY PENSKY MARTEMS CUP EPA 1010A 12/5/2006 12:00:00 AM

FLASHPOINT DETERMINATION EPA 1030 5/1/2002 12:00:00 AM

IRON EPA 6010C 5/13/1998 12:00:00 AM

LEAD EPA 6010C 5/13/1998 12:00:00 AM

MAGNESIUM EPA 6010C 5/13/1998 12:00:00 AM

MANGANESE EPA 6010C 5/13/1998 12:00:00 AM

MERCURY EPA 7470A 3/2/1992 12:00:00 AM

MERCURY EPA 7471B 11/15/1997 12:00:00 AM

SW

Parameter EPA Method Certified On

MOLYBDENUM EPA 6010C 5/13/1998 12:00:00 AM

NICKEL EPA 6010C 5/13/1998 12:00:00 AM

ORGANOCHLORINE PESTICIDES BY GC EPA 8081B 5/13/1998 12:00:00 AM

PAINT FILTER LIQUIDS TEST EPA 9095B 12/5/2006 12:00:00 AM

PCBS BY GC EPA 8082A 5/12/1998 12:00:00 AM

PCBS IN WASTE OIL 600/4-81-045 3/3/1998 12:00:00 AM

PH (HYDROGEN ION) EPA 9041A 11/15/1997 12:00:00 AM

PH (HYDROGEN ION) EPA 9045D 12/5/2006 12:00:00 AM

POTASSIUM EPA 6010C 5/13/1998 12:00:00 AM

PURGE AND TRAP FOR AQUEOUS

SAMPLES

EPA 5030C 12/5/2006 12:00:00 AM

SEDIMENTS, SLUDGES AND SOILS EPA 3050B 5/13/1998 12:00:00 AM

SELENIUM EPA 6010C 5/13/1998 12:00:00 AM

SEMIVOLATILE ORGANIC COMPOUNDS BY

GC/MS

EPA 8270C 5/13/1998 12:00:00 AM

SILVER EPA 6010C 5/13/1998 12:00:00 AM

SODIUM EPA 6010C 5/13/1998 12:00:00 AM

SPE EPA 3535A 4/17/2012 12:00:00 AM

SPLP EPA 1312 8/8/1994 12:00:00 AM

SULFURIC ACID/PERMANGANATE

CLEANUP

EPA 3665A 5/13/1998 12:00:00 AM

TCLP EPA 1311 3/2/1992 12:00:00 AM

THALLIUM EPA 6010C 5/13/1998 12:00:00 AM

TIN EPA 6010C 5/13/1998 12:00:00 AM

TOTAL METALS EPA 3010A 6/15/1998 12:00:00 AM

TOTAL RECOVERABLE IN WATER EPA 3005A 11/15/1997 12:00:00 AM

ULTRASONIC EXTRACTION EPA 3550C 5/13/1998 12:00:00 AM

VANADIUM EPA 6010C 5/13/1998 12:00:00 AM

VOCs by GC/MS, INCLUDING N-HEXANE EPA 8260B 5/13/1998 12:00:00 AM

ZINC EPA 6010C 5/13/1998 12:00:00 AM

Total Count: 51

WW

Parameter EPA Method Certified On

ESCHERICHIA COLI BY COLILERT MPN, IN

CONJUNCTION WITH SM 9221B AND 9221C

SM 9223B (2004) 8/2/2004 12:00:00 AM

ALKALINITY, TOTAL SM 2320B (2011) 10/27/1993 12:00:00 AM

ALUMINUM EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

ALUMINUM EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

AMMONIA SM 4500-NH3 C (2011) 12/14/2009 12:00:00 AM

AMMONIA SM 4500-NH3B (2011) 12/14/2009 12:00:00 AM

ANTIMONY EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

ANTIMONY EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

ARSENIC EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

ARSENIC EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

BARIUM EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

BARIUM EPA 200.7 (4.4) 11/6/1994 12:00:00 AM

BASE/NEUTRALS AND ACIDS BY GC/MS

(12/2016)

625.1 2/25/2020 2:31:32 PM

BERYLLIUM EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

BERYLLIUM EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

BIOCHEMICAL OXYGEN

DEMAND/CARBONACEOUS BIOCHEMICAL

OXYGEN DEMAND

SM 5210B (2011) 7/13/2006 12:00:00 AM

BORON EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

BROMIDE EPA 300.0 (2.1) 3/2/1992 12:00:00 AM

CADMIUM EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

CADMIUM EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

CALCIUM EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

CHEMICAL OXYGEN DEMAND HACH 8000 2/23/2009 12:00:00 AM

CHLORIDE EPA 300.0 (2.1) 3/2/1992 12:00:00 AM

CHLORINE TOTAL RESIDUAL SM 4500-CL G (2011) 10/21/2016 2:36:51 PM

CHLORINE TOTAL RESIDUAL HACH 10014 8/24/0006 12:00:00 AM

CHROMIUM TOTAL EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

CHROMIUM TOTAL EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

CHROMIUM(VI) HEXAVALENT SM 3500-CR B (2011) 10/21/2016 2:36:53 PM

COBALT EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

COBALT EPA 200.8 (5.4) 7/20/2010 12:00:00 AM

WW

Parameter EPA Method Certified On

COPPER EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

COPPER EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

CYANIDE, AVAILABLE 4500-CN G (2011) 2/15/2017 11:17:02 AM

CYANIDE, TOTAL SM 4500-CN BCE (2011) 8/4/2009 12:00:00 AM

FECAL COLIFORMS BY COLILERT 18 (APP

AND REUSE ONLY)

SM 9020B (2005)/9223B (2004) 7/22/2011 12:00:00 AM

FLUORIDE EPA 300.0 (2.1) 11/15/1997 12:00:00 AM

HARDNESS EPA 200.7 (4.4) 12/5/2002 12:00:00 AM

HYDROGEN ION (pH) SM 4500-H B (2011) 11/20/2007 12:00:00 AM

IRON EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

KJELDAHL, TOTAL NITROGEN PAI-DK01 (12/94) 6/17/2010 12:00:00 AM

LEAD EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

LEAD EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

LITHIUM EPA 200.7 (4.4) 3/1/2017 11:17:40 AM

MAGNESIUM EPA 200.7 (4.4) 10/18/2096 12:00:00 AM

MANGANESE EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

MANGANESE EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

MERCURY EPA 245.1 (3.0) 2/27/1997 12:00:00 AM

MOLYBDENUM EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

MOLYBDENUM EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

NICKEL EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

NICKEL EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

NITRATE EPA 300.0 (2.1) 3/2/1992 12:00:00 AM

NITRITE (AS N) EPA 300.0 (2.1) 3/2/1992 12:00:00 AM

OIL AND GREASE AND PETROLEUM

HYDROCARBONS

EPA 1664 REV B 2/18/2014 12:00:00 AM

ORTHOPHOSPHATE EPA 300.0 (2.1) 3/1/2017 11:15:35 AM

OXYGEN, DISSOLVED SM 4500-O G (2011) 12/5/2006 12:00:00 AM

PHENOLS EPA 420.1 (1978) 2/26/2001 12:00:00 AM

PHOSPHORUS, TOTAL EPA 200.7 (4.4) 3/18/2013 12:00:00 AM

PHOSPHORUS, TOTAL SM 4500-P E (2011) 10/21/2016 2:36:53 PM

POTASSIUM EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

WW

Parameter EPA Method Certified On

PURGABLE BY GC/MS (12/2016) EPA 624.1 2/25/2020 2:31:32 PM

RESIDUE NONFILTERABLE (TSS) SM 2540D (2011) 7/16/1996 12:00:00 AM

RESIDUE TOTAL SM 2540B (2011) 12/5/2006 12:00:00 AM

RESIDUE VOLATILE SM 2540E (2011) 2/10/2017 4:30:19 PM

RESIDUE, FILTERABLE SM 2540C (2011) 7/16/1996 12:00:00 AM

RESIDUE, SETTLEABLE SOLIDS SM 2540F (2011) 12/5/2006 12:00:00 AM

SELENIUM EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

SELENIUM EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

SILICA, DISSOLVED EPA 200.7 (4.4) 3/2/1992 12:00:00 AM

SILICA, DISSOLVED SM 4500-SIO2C (2011) 12/5/2006 12:00:00 AM

SILVER EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

SILVER EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

SODIUM EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

SPECIFIC CONDUCTANCE SM 2510B (2011) 12/5/2006 12:00:00 AM

STRONTIUM EPA 200.7 (4.4) 10/15/1996 12:00:00 AM

SULFATE EPA 300.0 (2.1) 3/2/1992 12:00:00 AM

THALLIUM EPA 200.7 (4.4) 11/15/1997 12:00:00 AM

THALLIUM EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

TIN EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

TITANIUM EPA 200.7 (4.4) 3/1/2017 11:19:30 AM

TOTAL, FIXED AND VOLATILE SOLIDS IN

SLUDGE

SM 2540G (2011) 12/14/2009 12:00:00 AM

TURBIDITY, NTU EPA 180.1 (2.0) 11/23/1991 12:00:00 AM

VANADIUM EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

VANADIUM EPA 200.8 (5.4) 7/20/2010 12:00:00 AM

ZINC EPA 200.7 (4.4) 10/8/1992 12:00:00 AM

ZINC EPA 200.8 (5.4) 7/28/2010 12:00:00 AM

Total Count: 86

Instrument Instrument Instrument Code Quantity Certified On

INDUCTIVELY COUPLED

PLASMA SPECTROMETER

ICP 1 2/18/2020 3:03:48 PM

Instrument Instrument Instrument Code Quantity Certified On

GAS CHROMATOGRAPH/MASS

SPECTROMETER

GC/MS 3 2/27/2012 12:00:00 AM

GAS CHROMATOGRAPH/MASS

SPECTROMETER

GC/MS 1 2/18/2020 3:03:48 PM

GAS CHROMATOGRAPH GC 3 2/23/2009 12:00:00 AM

INDUCTIVELY COUPLED

PLASMA SPECTROMETER

ICP 1 2/21/2013 12:00:00 AM

INDUCTIVELY COUPLED

PLASMA/MASS

SPECTROMETER

ICP/MS 1 7/21/2010 12:00:00 AM

ATOMIC ABSORPTION

SPECTROPHOTOMETER

AA 1 3/18/2011 12:00:00 AM

ION CHROMATOGRAPH IC 2 2/21/2013 12:00:00 AM

Total Count: 8

Software Software Code Certified On

PERKIN ELMER - ICP 2/24/2006 12:00:00 AM

ENVIROQUANT/CHEMSTATION - GC 8/4/2009 12:00:00 AM

VARIAN - AA 8/4/2009 12:00:00 AM

PEAKNET (DIONEX) - IC 8/4/2009 12:00:00 AM

ENVIROQUANT/CHEMSTATION - GC/MS 2/25/2020 2:31:32 PM

CHROMELEON (DIONEX) - IC 3/1/2021 1:10:42 PM

OTHER - ICP/MS 3/1/2021 1:10:42 PM

Total Count: 7

Quality Assurance Plan

Revision #33

January 29, 2024

Turner Laboratories, Inc.

2445 N. Coyote Drive

Suite 104

Tucson, Arizona

(520) 882-5880 / (520) 882-9788

Arizona License #AZ0066

Copy #: ___________________________________________________

Issued to: ____________________________________________________________________

Date Issued: ___________________________________________________

Approved by:

Elizabeth Kasik, Laboratory Director Date

Michael J. McGovern, President Date

Turner Laboratories, Inc. Quality Assurance Plan

Revision #33 January 29, 2024 Page 2 of 28

Table of Contents

Section Heading

1 Introduction

1.1 Quality Policy

1.2 Quality System

2 Organization

2.1 Facility

2.2 Responsibilities

3 Personnel Qualifications

3.1 Personnel Training

3.2 Laboratory Ethics

3.3 Client Confidentiality

4 Documentation and Records

4.1 Controlled Documents

4.2 Document Signature

4.3 Document Review & Revision

4.4 Document Retention & Disposal

4.5 Computer Hardware & Software

5 Processes & Operations

5.1 Sampling

5.2 Handling of Samples

5.3 Sample Receipt & Management

5.4 Standard Operating Procedures (SOPs)

6 Calibration Procedures

6.1 Chemical Standards

6.2 Temperature Controlled Devices

6.3 Analytical Balances

6.4 Pipets

6.5 Fume Hoods

6.6 Instruments

6.7 Calibration Models

7 Quality Control

7.1 Method Detection Limit (MDL) Determination

7.2 Practical Quantitation Limit

7.3 Initial Demonstration of Capability

7.4 Quality Control Procedures

7.4.1 Method Blanks

7.4.2 Calibration Blanks

7.4.3 Continuing Calibration Blanks

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Revision #33 January 29, 2024 Page 3 of 28

7.4.4 Calibration Standards

7.4.5 Initial Calibration Verification Standards

7.4.6 Continuing Calibration Verification Standards

7.4.7 Low-Level Standards

7.4.8 Internal Standards

7.4.9 Surrogates

7.4.10 Laboratory Control Samples

7.4.11 Matrix Spike Samples

7.4.12 Interference Check Samples

7.4.13 Post Digestion Spike

7.5.14 Representativeness

7.5.15 Reagent Water

7.5 Calculations

7.5.1 Accuracy

7.5.2 Precision

7.5.3 Control Charting

8 Data Reduction, Validation & Reporting

8.1 Data Reduction and Validation

8.2 Reporting Procedures

9 Procurement of Quality Products

9.1 Subcontract of Laboratory Services

10 Project Requirements

10.1 Client Services

11 Audits

11.1 System Audits

11.2 Performance Audits

12 Preventative Maintenance Policies

13 Nonconformance & Corrective Action Procedures

14 Licensed Parameters

Appendices The most current copy of the following appendices has been attached

Appendix A Organizational Chart

Appendix B ADHS Environmental Laboratory License and List of

Licensed Parameters/Approved Methods

Appendix C List of Major Analytical Equipment

Appendix D Summary of Turner Laboratories’ WP & WS Performance

Appendix E List of Turner Laboratories’ SOPs

Appendix F List of Turner Laboratories’ Policies

Turner Laboratories, Inc. Quality Assurance Plan

Revision #33 January 29, 2024 Page 4 of 28

Section 1 Introduction

Turner Laboratories, Inc. (Turner Laboratories) is a professional, independent, full-service laboratory that performs chemical and microbiological testing on a wide variety of sample matrices including ground and surface waters, wastewaters, soils, sediments, sludges, industrial and hazardous wastes, and other materials.

This Quality Assurance Plan (QAP) has been developed to provide information on the general procedures, practices, and methods of compliance that Turner Laboratories implements to assure that the highest achievable standards are met.

The information in this QAP has been organized to conform to the requirements specified in the Arizona

Administrative Register, A.A.C. R9-14-601 et seq. (October 2016), and the Manual for the Certification of

Laboratories Analyzing Drinking Water, 5th Edition, EPA 815-R-05-004, (January 2005).

Section 1.1 Quality Policy

It is the policy of Turner Laboratories to ensure that all analytical data generated and processed will be scientifically sound, legally defensible, of known and documented quality, and will accurately reflect the materials tested. This is accomplished by implementing quality control procedures that are monitored and assessed during the entire analytical process. Personnel shall be fully qualified to perform the analyses through the combination of education, training, and experience. The equipment and supplies shall be obtained as needed to provide for the utilization of established technology and methodology. The performance of personnel and equipment will be continuously monitored and documented. Corrective action must be implemented and documented immediately if a quality problem arises.

Implementation of this QAP is the responsibility of all employees within Turner Laboratories.

Section 1.2 Quality System

The purpose of the Quality Assurance (QA) program at Turner Laboratories is to ensure that clients are provided with analytical data that is scientifically sound, legally defensible, and of known and documented quality. The concept of Quality Assurance can be extended to the general business operations of Turner

Laboratories.

The objective of the quality assurance program at Turner Laboratories is to assure the accuracy and precision of all analytical results. Turner Laboratories has established specific quality assurance objectives for accuracy and precision, which are used to determine the acceptability of the data. These objectives are method and matrix dependent and are provided in the standard operating procedures. If the analytical method does not clarify quality control procedures, the twelve quality control elements listed in Method Updates for

40 CFR Part 136.7 (C), “The Federal Register/Vol. 77, No. 97/Friday, May 18, 2012/Rules and Regulations” will be followed. Verification that these objectives have been achieved is recorded in the supporting documentation (raw data) and/or in the final report.

Turner Laboratories, Inc. Quality Assurance Plan

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Section 2.0 Organization

Section 2.1 Facility

Turner Laboratories features over 8,400 square feet of laboratory equipped with state-of-the-art analytical and administrative support equipment. The laboratory has been designed and constructed to provide safeguards against cross-contamination of samples and is arranged according to work function, which enhances the efficiency of analytical operations. The ventilation system has been specially designed to meet the needs of the analyses performed in each workspace. Turner Laboratories also ensures that good housekeeping and facilities maintenance are performed.

In addition, the laboratory work areas are designed for safe and efficient handling of a variety of sample types. These specialized areas (and access restrictions) include:

• Shipping and Receiving

• Sample Management Office, including controlled-access sample storage areas

• Metals Sample Preparation Area

• Metals Laboratory

• General Chemistry Laboratory

• Semi-Volatile Organics Sample Preparation Area

• Semi-Volatile Organics Laboratory

• Volatile Organics Laboratory

• Microbiology Laboratory

• Laboratory Management, Client Service, Report Generation and Administration

• Data Archival, Data Review and support functions areas

• Information Technology (IT) and Laboratory Information Management System (LIMS)

In addition, the designated areas for sample receiving, refrigerated sample storage, dedicated sample container preparation and shipping provide for the efficient and safe handling of a variety of sample types.

The laboratory is equipped with state-of-the-art analytical and administrative support equipment. The equipment and instrumentation are appropriate for the procedures in use. Appendix C lists all the major analytical equipment illustrating the laboratory's overall capabilities and depth.

Turner Laboratories’ Contingency Plan consists of, but is not limited to the following:

• Analysis of samples on back-up instrumentation.

• Subcontract samples to a certified laboratory.

• Qualified cross-trained staff members are available to perform the necessary work.

Section 2.2 Responsibilities

Turner Laboratories is committed to the excellence of data quality and providing an environment that fosters such quality. Every person employed at Turner Laboratories is responsible for improving and maintaining the quality of our analytical services. Responsibilities of key positions within the laboratory are described below. A chart showing the laboratory organization and lines of responsibility is included in Appendix A.

• The Technical Director has overall responsibility for all elements of the laboratory’s technical operations, implementation of the QAP, updating laboratory policy and ensuring that all data reported by the laboratory meets the objectives of the QAP. The Technical Director performs regular, random reviews of data generated by the laboratory, ensures that audits of the laboratory are conducted, ensures that the laboratory remains in compliance, ensures that control charting of

QC data occurs and that limits are updated regularly where required, and ensures that personnel complete the proper documentation for tests they perform (i.e. MDL studies, initial demonstration of capabilities, etc.).This technical director, or his/her designee, performs a final quality assurance review on all final reports issued by the laboratory.

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• The Quality Assurance Officer is responsible for the overall implementation of Turner

Laboratories Quality Assurance program. This includes, but is not limited to, the creation and maintenance of Standard Operating Procedures as well as the Quality Assurance Manual.

• All employees, and particularly the Quality Assurance Officer, have stop work authority for al procedures performed in the Laboratory.

• The Project Manager acts as the interface between clients and the laboratory to ensure the details of the clients’ needs are met, including management of permits and subsequent reporting requirements and keeping abreast of regulatory changes. Additionally, the project manager is responsible for supervising sample receiving personnel and performs some quality control duties as designated by the Technical Director.

• The Laboratory Supervisor supervises and trains analysts. They also ensure that the quality of all data reported by the laboratory meets the objectives of the QAP, and they ensure the accuracy, completeness, and timely review of standard operating procedures (SOP) for all procedures used.

• The Sample Control Officer ensures that sample management procedures meet the QAP objectives and ensures the accuracy, completeness, and timely review of SOPs for all sample management procedures. The sample management officer or his/her designee is responsible for the login of samples into LIMS, client bottle orders, container preservation and sample disposal.

• The Administrative Assistant supervises and schedules the work of the field sampling personnel.

This employee also maintains contracts and technical records and holds selected project management responsibilities including distribution of client reports and fielding client inquiries.

• Analysts perform testing according to established SOPs and methods and ensure that the data quality meets specified criteria. All analysts are required to provide a summary of their education and experience relevant to the compliance testing they will perform. The summaries are retained in their personnel training record and are subject to inspection by regulatory agencies. Documentation must include academic training, experience, specific qualifications for the position, certifications, and other specialized training.

Turner Laboratories, Inc. Quality Assurance Plan

Revision #33 January 29, 2024 Page 7 of 28

Section 3 Personnel Qualifications

Section 3.1 Personnel Training

The employees’ quality assurance orientation must be performed at the start of employment. The training is documented in the personnel training file. The orientation includes, but is not limited to, the review of the following:

• Orientation to the facility and facility policies.

• Review of the Turner Laboratories’ Safety Manual.

• Review of the Quality Assurance Plan (QAP).

• Review of the data integrity, applicable methods and Standard Operating Procedures (SOPs) for the testing to be performed.

Before reporting results, the analyst must document that he/she has completed the following:

• Training in the use of the instrumentation and appropriate techniques used for compliance testing.

The training may be in-house, classroom experience, or manufacturer’s training. Records must indicate the place, date and length of training.

• Completion of all activities as required in the method criteria for initial demonstration of capability.

• Successful analysis of unknown quality control sample and/or proficiency evaluation sample.

(Sample may be prepared in-house as a blind sample to the analyst or may be purchased from an external source). An Initial Demonstration of Capability may also be performed to satisfy this requirement.

Documentation of these training requirements are maintained in the employee’s personnel training record, as outlined in the Turner Laboratories Policy Statement, Policy No. 4, pertaining to the maintenance of personnel training records.

Section 3.2 Laboratory Ethics

One of the most important aspects of the success of Turner Laboratories is the emphasis placed on the integrity of the data provided and services performed. To promote data quality, employees are required to comply with certain standards of conduct and ethical practices. Examples of Turner Laboratories’ policy that are representative of these standards include, but are not limited to, the following:

• Under no circumstances is the willful act of fraudulent manipulation of analytical data condoned.

Such acts are to be reported immediately to senior management for appropriate corrective action.

Unless specifically required in writing by a client, the alteration, deviation or omission of written contractual requirements is not permitted. Such changes must be in writing and approved by senior management. This will result in disciplinary action up to and including termination.

• Falsification of data in any form will not be tolerated. While much analytical data is subject to professional judgment and interpretation, outright falsification, whenever observed or discovered, will be documented, and appropriate remedies and punitive measures will be taken toward those individuals responsible. Falsification of data will result in disciplinary action up to and including termination.

• It is the responsibility of all Turner Laboratories employees to safeguard sensitive company and client information. The nature of our business and the wellbeing of our company and of our clients is dependent upon protecting and maintaining proprietary company/client information. All information, data, and reports (except that in the public domain) collected or assembled on behalf of a client is treated as confidential. Information may not be given to third parties without the written

Turner Laboratories, Inc. Quality Assurance Plan

Revision #33 January 29, 2024 Page 8 of 28 consent of the client. Unauthorized release of confidential information about the company or its clients is taken seriously and is subject to formal disciplinary action, up to and including termination.

As part of this commitment, every employee at Turner Laboratories signs and abides by a fraud-disclosure form that reads as follows:

“If I should become aware of any of the following conditions or events by anyone during my employment at Turner Laboratories, I agree to notify the principals of Turner

Laboratories immediately:

1. Short-cutting of any procedural steps, or QA/QC falsification

2. Altering data in any manner whatsoever

3. Altering time records to avoid missed holding times

4. Any condition that would, if known, result in the rejection of any analytical report by any regulatory agency - federal, state or local

“Should it become known that any information has been suppressed by any employee that could endanger the State operating license of Turner Laboratories or affect the ability to produce accurate scientific measurements, counsel will be retained by Turner Laboratories for possible legal action.”

Turner Laboratories makes every attempt to ensure that employees are free from any commercial, financial, or other undue pressures that might affect their quality of work.

Section 3.3 Client Confidentiality

Turner Laboratories’ professional ethics require that each employee maintain the highest degree of confidentiality when handling client affairs. Turner Laboratories shall ensure that all client documents and test results are confidential. In order to maintain this professional confidence, no employee shall disclose client information to outsiders, including other clients, third parties, or members of one’s own family.

Turner Laboratories has instituted procedures for protecting client confidentiality. A unique internal control number is assigned to individual samples by the LIMS. The assigned number is the primary mechanism for tracking a given sample through the laboratory system and can be traced electronically through an audit trail to ensure information is free from manipulation.

Under no circumstance will outside requests for client material be fulfilled unless prior written or electronic permission is received from the client to the Technical Director, Project Manager, or President.

All employees at Turner Laboratories have signed a confidentiality agreement form regarding the information provided in this section that reads as follows:

“If I become aware of any of the above mentioned events during my employment at Turner Laboratories, I agree to notify the principals of Turner Laboratories immediately. Should it become known that any information has been disclosed by an employee, the employee will be terminated and counsel will be retained by Turner Laboratories for possible legal action.”

Turner Laboratories, Inc. Quality Assurance Plan

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Section 4 Documents and Records

Section 4.1 Controlled Documents

Turner Laboratories has an established document control system that forms part of the quality system.

Controlled documents are those documents and data that are required for the operation of the quality system.

These documents must be controlled by being replaced in whole when revised. The controlled documents include, but are not limited to:

• Quality Assurance Plan (QAP).

• Standard Operating Procedures (SOPs).

• Instrument Run/Maintenance Logbooks.

• Nonconformance/Corrective Action Documents.

Copies of controlled documents that are released, such as the Quality Assurance Plan and Standard Operating

Procedures, will be marked “Uncontrolled”.

Section 4.2 Document Signatures

Controlled documents must have approval signatures. The Quality Assurance Plan will have the signature of the President and Technical Director. The Standard Operating Procedures will have the signatures of the

Technical Director, Quality Assurance Officer, and analyst. Final reports that are issued by the laboratory will have the signature of the Technical Director or his/her designee that performs a final quality assurance review.

Section 4.3 Document Review and Revisions

The QAP and Safety Manual are reviewed on an annual basis unless regulatory change necessitates an earlier revision. The SOPs are reviewed on an annual basis. Other QA documents that may require revision are reviewed and are revised as needed.

Any revisions to controlled QA documents are prepared by the Technical Director. The QA Officer will review the document. All changes to records are signed or initialed by the responsible staff. When revisions are made, the document is assigned the succeeding revision number.

Section 4.4 Document Retention & Disposal

The original observations, calculations, derived data, calibration records, audit reviews, and the client reports are retained for a minimum of five (5) years. The paper files are archived in boxes according to department, instrument and/or client with inclusive dates. After 5 years of archival (unless the client or contract specifies otherwise), eligible archives (not including SOPs or QAP) are purged and destroyed. Disposal of purged materials is accomplished by shredding/destruction of the material or deleting of electronic material.

Turner Laboratories archiving system includes all of the following items for each set of analyses performed:

• Bench sheets describing sample preparation (if appropriate) and analysis.

• Instrument parameters (or reference to the data acquisition method).

• Sample analysis sequence.

• Instrument printouts, including chromatograms and peak integration reports for all samples, standards, blanks, spikes and reruns.

• Electronic log ID number for the appropriate standards.

• Electronic copies of report sheets submitted to the work request file.

• Copies of Corrective Action Reports, if necessary.

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Individual sets of analyses are identified by analysis date and service request number. Since many analyses are performed with computer-based data systems, the final sample concentrations can be automatically calculated. If additional calculations are needed, they are written on the integration report or securely stapled to the chromatogram, if done on a separate sheet.

In the event that Turner Laboratories should go out of business or be bought by another company, all clients will be notified immediately. Client records will be handled by one of the following:

• If the client wishes to have control of their data, they will be given the original copies.

• If another company buys Turner Laboratories and the client wishes to have control of their data, they will receive the original copies and an exact copy (with proper documentation) will be retained by the purchaser. The purchaser will be responsible for retaining the data for the remainder of the applicable time.

Section 4.5 Computer Hardware & Software

Turner Laboratories utilizes the commercially purchased Element DataSystem by Promium, LLC Laboratory

Information Management System (LIMS). The LIMS is a secure, password protected database. The

Technical Director or designee monitors the analytical activities and database performance. Changes to the

LIMS are controlled by the Technical Director or designee. The electronic instrument files, LIMS and server system are electronically backed-up on a daily basis and a copy is taken off site each evening.

All purchased software must be used in accordance with the terms of its software license.

Instrument raw data that is collected on a local computer will be backed up to the server on a weekly basis at a minimum.

Turner Laboratories, Inc. Quality Assurance Plan

Revision #33 January 29, 2024 Page 11 of 28

Section 5 Processes & Operations Section 5.1 Sampling

The quality of analytical results depends largely upon the quality of procedures used to collect and transport samples. Turner Laboratories recommends to their clients to follow appropriate methodology and regulations, such as the requirements specified in 40 CFR Part 136 or the US EPA’s SW-846.

Turner Laboratories suggests to clients to consider the following:

• Sample matrix

• Quantity of sample needed for testing

• Type of container

• Type of sample preservation

• Transport time

• Storage (holding) time

• Complete documentation for chain-of-custody purposes

At the clients’ request, Turner Laboratories provides the following:

• Sample containers with the appropriate preservatives as specified in the applicable standard operating procedure

• Shipping containers

• Chain-of-custody forms

• Custody seals

Where obtaining sample aliquots from a submitted sample is carried out as part of a test method, Turner

Laboratories follows the appropriate procedures and techniques to obtain representative sub samples. Any deviation from standard procedures is recorded on the data package.

Turner Laboratories provides sampling services by a trained field technician.

Section 5.2 Handling of Samples

The chain-of-custody is a system for tracing the possession of a sample from collection to final disposition.

This system is implemented to protect the interests of the laboratory and the client. Changes to the sample custody must be recorded on a chain-of-custody form and must accompany the sample at all times.

Turner Laboratories requires clients to submit a completed chain-of-custody form with each sample or group of samples for analysis.

The chain-of-custody program consists of the following:

• The established protocol for sampling will be followed for all chain-of-custody samples. Sample containers and preservatives should adhere to EPA and/or other appropriate requirements.

• At the time of sampling, the sampler completes the information on the chain-of-custody form, including date, time, client’s name, sample name, sample matrix, number of containers, required tests, and signature.

• At all times after sampling, the sample must be in either the actual physical possession of the currently responsible individual, in a secure location or under laboratory control.

• When a client delivers the sample to Turner Laboratories, Turner Laboratories’ staff documents all subsequent changes of possession that occur.

Turner Laboratories, Inc. Quality Assurance Plan

Revision #33 January 29, 2024 Page 12 of 28

• Responsibility for a particular sample concludes for one party at the point when delivery is documented to the next responsible party (the receiving laboratory or commercial carrier).

• If the sample is to be transported to another laboratory (for testing not performed by Turner

Laboratories), the carrier is selected based on holding time criteria. The delivery is documented and transfer of possession to the carrier on a subcontract chain-of-custody form.

Complete sample handling procedures are available in Turner Laboratories SOP SC-1.

Section 5.3 Sample Receipt and Management

Established standard operating procedures for receiving samples ensure that the samples are received and logged into the laboratory, all associated documentation (including chain-of-custody forms) is complete and consistent with the samples received, and storage and tracking are conducted so that the samples’ integrity is maintained.

Verification of sample integrity is documented upon sample receipt on the chain-of-custody form, and requires the following conditions:

• The sample is clearly identified and matches the description on the chain-of-custody form.

• The condition of samples and sample containers meets method specifications.

• A sufficient quantity of sample is available so that all required tests can be performed.

• The sample is received within the specified holding time, and temperature requirement.

• Preservation is confirmed by the personnel receiving the sample and verified by the analyst conducting the method.

• Custody seals, if used, are present and intact.

If there is doubt as to the suitability of a sample, when the sample does not conform to the description provided, or the environmental test required is not specified in detail; Turner Laboratories will consult the client for further instructions before proceeding and the discussion shall be recorded in LIMS or on the chain-of-custody form.

At Turner Laboratories, each sample is logged into the laboratory information management system (LIMS), a secure, password-protected database that facilitates tracking and reporting of samples. The LIMS assigns a unique chronological laboratory identification number to each sample, and the sample control clerk adds pertinent information concerning collection date and time, matrix, container, preservation, and required tests.

Other pertinent information, such as the client’s preferred report distribution method (i.e. email addresses, phone number, physical address) is added to ensure accurate delivery of the report. All sample receipt documentation is retained with the sample work order through to final reporting and then retained electronically.

The sample management custodian affixes labels to the sample container(s) with the unique laboratory identification number and places the sample in the appropriate storage area until analysis (under refrigeration if required). Samples with expedited turn-around times, or whose tests have short holding times, may be given directly to the appropriate analysts. The Technical Director, Project Manager or qualified designee reviews the work order for completeness.

Turner Laboratories retains…

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