LLNL-TR-813124

Management Review Report for

2019

J. Cho, J. Bennett

July 31, 2020

Disclaimer

This document was prepared as an account of work sponsored by an agency of the United States
government. Neither the United States government nor Lawrence Livermore National Security, LLC,
nor any of their employees makes any warranty, expressed or implied, or assumes any legal liability or
responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product, or
process disclosed, or represents that its use would not infringe privately owned rights. Reference herein
to any specific commercial product, process, or service by trade name, trademark, manufacturer, or
otherwise does not necessarily constitute or imply its endorsement, recommendation, or favoring by the
United States government or Lawrence Livermore National Security, LLC. The views and opinions of
authors expressed herein do not necessarily state or reflect those of the United States government or
Lawrence Livermore National Security, LLC, and shall not be used for advertising or product
endorsement purposes.

This work performed under the auspices of the U.S. Department of Energy by Lawrence Livermore
National Laboratory under Contract DE-AC52-07NA27344.
CY2019 Management Review Report
LLNL ES&H Analytical Services and Instrumentation Division Analytical Laboratory (ALAB)

Date: July 16, 2020

Organizer: Jack Bennett, ALAB Technical Manager
Attendees: Jennifer Cho ES&H Assurance Officer & ALAB Quality Manager
Diana Larson, Industrial Hygiene Group Leader
Thom Kato, ES&H Functional Area Manager
Chris Campbell, Group Leader, Water, Air, Monitoring and Analysis
Vicki Salvo, ES&H Assurance Manager
Michele Sundsmo, AS&l Manager

Changes in internal and external issues that are relevant to the laboratory
1.1. Status of State of California ELAP regulations
1.1.1 CA ELAP continued to hold stakeholder meetings starting in January 2019 and continuing
throughout the year to listen to the concerns of the regulated community. ELAP released
a Notice of Proposed Rulemaking on Oct 11, 2019 which contained an Initial Statement
of Reasons and a 4th draft of the proposed regulations. A hearing was held in December
to address comments, and another hearing was scheduled for January 2020. CA ELAP’s
intent is to present the proposed regulations to the Water Boards during their spring
meeting.
Additional Discussions: CA Water Boards approved the CA ELAP proposed regulations package
in March of 2020. The regulations do not take full effect until 2022, and labs have until then to
come into full compliance. ALAB plans to become an early adopter. Actions to accomplish this
will be discussed in the 2020 Annual Management Review.
1.1.2 ALAB became accredited by CA ELAP for the additional Fields of Testing to support the
environmental soils testing projects for the Environmental Functional Area on 3/14/19.
Since the CA ELAP program told ALAB that they would not be able to perform an onsite
evaluation of the laboratory for the new fields of testing within a year, ALAB negotiated
with CA ELAP to use a third-party assessor (TPA, i.e. ANAB) to assess ALAB to the TNI
2009 Standard. The only way the TPA would perform the onsite audit was if ALAB
became accredited to the TNI standard through their accreditation process. That
assessment occurred from Feb 12th to 14th There were 12 minor findings from the ANAB
assessment, and all corrective actions were accepted both by ANAB and CA ELAP. CA
ELAP accepted the ANAB TPA accreditation report in lieu of CA ELAP performing an onsite
assessment and ANAB granted TNI accreditation. Much of this information was included
in the 2018 Management Review because of the actions occurring at the end of one
calendar year and the beginning of the next calendar year. Appendix 1 contains the
supporting information.
1.2. Labworks LIMS implementation
1.1.1 The Labworks LIMS implementation for the environmental soils fields of testing was mostly
completed in 2019, and the reporting from Labworks was validated by the ALAB Technical
Manager doing hand calculations to verify the reported results. The in-house Labworks
SME worked with the Labworks implementation specialist and EFA Data Management staff
to develop the EDD to electronically transmit the results to the EFA environmental
database. During the implementation ALAB discovered several idiosyncrasies that were not
expected. Two examples are that if samples from more than one sample receipt group are
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 extracted and analyzed in one preparation batch that Labworks can’t associate the batch
OC across the two batches. The analyst must create a second copy of the batch QC results
and rename it so that it is associated with the second batch. The second example is that
Labworks can’t flag sample results to indicate that the analyte is present in the method
blank. The flags must be applied manually.
1.2 Addition of CFF to ALAB AIHA Accreditation
1.2.1 The CFF expect to increase the tempo of operations and inquired about setting up a
satellite laboratory at Site 300 under the ALAB AIHA accreditation to reduce the
analytical TAT. A meeting was held in April and ALAB expressed that the AIHA
requirements for accreditation are that the accreditation is for a single site. There were
discussions about what it would take to set up an AIHA accredited laboratory at Site 300
and discussions about submitting samples to NIF, since the NIF is a 24/7 operation.
There are challenges to each of those approaches that have not been resolved. At the
present time, the CFF is still submitting their samples to ALAB.
Additional Discussions: Michelle mentioned more details were included in the discussions between
CFF then were included on the Agenda. Further discussion details will be included in the CY2020
Management Review.
2 Fulfilment of objectives
2.1 The ALAB’s mission is to provide excellent service and quality analytical results while exceeding
customer’s expectations. The ALAB is committed to using quality practices that require all tests
to be carried out in accordance with stated methods and customers’ requirements.
2.2 The objectives of the ALAB quality system align with the ES&H Directorate objectives which
include:
2.2.1 Applying quality principles throughout ALAB activities
2.2.2 Providing a process for continual improvement in all areas of ALAB performance
2.2.3 Ensuring customer needs are met in a safe, environmentally sound, and cost-
effective manner
2.2.4 Ensuring appropriate planning, organization, direction, control, and support are
provided to achieve ALAB goals
2.3 The ALAB continues to perform high-quality chemical analyses in support of the Industrial
Hygiene Program and the Environmental Functional Area.
3 Suitability of policies and procedures
3.1 Eight procedures were either revised or issued in 2019. Three SOPs are past-due for review,
and two procedures were transferred to RML. Revisions included updates to describe current
laboratory practices, updates to incorporate TNI 2009 and ISO 17025:2017 requirements, and
corrective actions from assessments. New procedures were generated for the new
environmental soil fields of testing 1nALAB.
3.2 The revised standard ISO 17025:2017 was published on 11/30/17, and revised AIHA policies
that incorporated the standard revisions were published 7/2/18 and were effective
immediately. However, the basis of the TNI 2009 requirements for the environmental methods
is still the 2005 version of ISO 17025, so ALAB is maintaining both versions of ISO 17025
requirements in the quality management system because ALAB expects that CA ELAP will
implement the NELAC Standard in the revised regulations. When that occurs, the revised
regulations will be based on the TNI 2016 version of the NELAC standard, and an additional
gap analysis will be required.
3.3 Discussed discontinuing procedure ALAB-lO Metals in Water Samples by Modified EPA Method

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 200.7 at the 2018 Management Review meeting. Jack and Ruth were tasked to identify an
accredited lab that can analyze these samples via subcontract. Additional information is provided
in the next section.
3.4 Policies and Procedures continue to be suitable.
4. Status of actions from previous management reviews
4.1 Action items from CY2018 Management Review (ITS 47465):
4.1.1. Review all SOPs that are past-due for review- Revisions completed, need
QA and peer review for three SOP’s.
Additional Discussion: Two of the three SOP’s in Section 4.1.1 were related to the
digestors analysis (Sample Receipt and Metals Analysis). ALAB discontinued those tests in
March 2020. These SOP’s will not be updated. The Sample Receipt SOP was updated by
Debbie Vanorder prior to her retirement and will be transferred to RML because they are
still performing radiochemistry analysis on the digestors.
4.1.2 Work with IT support to resolve the Be Swipes and lH Metals Swipes spike
RPD and reporting issues- Not completed. Ruth contacted ALIMS Support
and was not able to bring this to a close.
Additional Discussion: Jack has recently revived this issue and has emailed back and forth
with ALIMS Support and the issue has fallen off the table again. Michele asked to have
James Arellano brought into the discussions. Jack will revive this issue and include James
on the emails going forward.
4.1.3 Control chart lead wipes and lead paint OC Unknown samples — Completed
(see discussion below)
Additional Discussion: Ruth investigated implementing the control charting of Pb Wipe
and Paint QC Unknowns. She discovered that new programing would be needed in ALIMS
in order for this to work. Since the developers are retired and ESH management has put
obtaining a new LIMS for all AS&l as a priority item, pursuing this is not practical any
longer. Chris Campbell suggested to follow up with the appropriate people to ensure this
stays near the top of the list.
4.1.4 Implement two new networked computers in ALAB Completed.
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4.1.5. Have ALIMS IT support add the required disclaimers regarding sampling and sample
information provided by the customer to ALAB final reports Completed.
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4.1.6. Internally audit the environmental water and sewage analysis methods —

Completed.
4.1.7. Identify an accredited subcontract lab for the EPA Method 200.7 metals in water
samples Completed (Eurofins Monrovia). See Appendix 2 for the Eurofins CA
— —

ELAP certificate.
4.1.8. Review the quality programs of ALAB’s subcontract labs (Micro Analytical
Laboratories, Bureau Veritas, and EMLab P&K) Completed. See Appendix 2 for the
—

FRM-5100’s that document the review.

Additional Discussion: The review of Micro Analytical was conducted onsite and the other two
labs were a “paper” review. The scope of the review was limited to high volume tests that ALAB
subcontracts to each lab. Details were documented in the work observations in the appendix, but
it was determined the labs produced acceptable quality data. Chris Campbell mentioned that EFA
maintains a list of subcontract labs for environmental testing that ALAB can also use. He also

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 suggested that ALAB and EFA investigate if it makes sense to use the same labs. Jack and Bart
Draper will meet to discuss this.
4.1.9 Place linear range study results in the ALAB QA server folder for improved access
and knowledge retention Completed.
—

5. Outcome of recent internal audits

5.1 The Annual Management Review for CY18 meeting was held on 4/16/19. The Management
Review Report and Management Observation form were documented in the Issues Tracking
System (ITS# 47465). Nine action items resulted from the review, with due dates assigned
through the end of the calendar year. A copy of the 2018 Management Review Report is
provided in Appendix 3.
5.2 An internal audit was performed in ALAB December 17 to 19, 2019 to TNI 2009 requirements
using the ANAB CL 2067 TNI Checklist. The scope of the internal audit was the new soil analysis
fields of testing and the digestor metals methods. There were two deficiencies and two
comments. This was documented in ALAB NCR’s 10002387 and 10002388 and ITS 49271
include ing FRM-5100 (see Appendix 3).
5.3 An internal audit was performed in ALAB From November 19 to December 11, 2019 to ISO
17025:2017 and AIHA requirements using the current AIHA Checklist
[Checklist_SiteAssessment_R18_1_FINAL. The scope of the internal audit was the annual review
of AIHA-accredited industrial hygiene methods performed in both ALAB and NIF HPL. The
internal audit resulted in two deficiencies and 10 comments. This was documented in ALAB
NCR’s 10002341 and 10002342 and ITS 49169 including FRM-5100 (see Appendix3).
5.4 Work observations of all ALAB staff performing routine procedures were conducted on 3/28/19
and 4/1/19 (see Appendix 3). The work observations were documented in ITS 47427. Several
opportunities for improvement requiring follow-up were identified and are discussed
elsewhere in this report. This outcome was also discussed in the 2018 ManagementReport.
Additional discussion: Although work observations are not specifically required by either the ISO
Standard or the NELAC Standard, they are a Best Practice and should be continued. Jennifer will
perform them before the end of the year. Some of the improvements identified in Section 11 and
the risks identified in Section 13 came from work observations.
6 Corrective actions
6.1 Corrective actions are recorded for each NCR/OOT and are captured in the Quarterly QA
Reports (see Appendix 6). Effectiveness follow-ups for NCRs are recorded on the NCR as
appropriate and records are maintained in a binder log.
Additional discussion: On average, approximately 40 NCR’s are generated per quarter. This
does not indicate that there are problems in the laboratory because the vast majority of them
are out of tolerances (i.e.., a sporadic spike out of control limits).
7 Assessments by external bodies
7.1 The ANAB external site assessment was carried out February 13-14, 2019 by Site Assessor Mike
Shepherd. The audit yielded twelve deficiencies. The Responses to Deficiencies report (see
appendices) was submitted to ANAB and CA ELAP on 3/4/19. The deficiencies and corrective
actions were captured in ITS 47305 and the ALAB’s NCR system (NCR’s 10002174 to 10002187).
The corrective actions were accepted by CA ELAP and ANAB. CA ELAP issued a revised
certificate on 3/15/19 (expires 2/28/21), and ANAB issued an initial certificate on 5/17/19
(expires 5/17/21). The supporting information is provided in Appendix 1.
Additional discussion: The deficiencies cited by the ANAB assessor were minor (for example a
thermometer serial number was incorrectly transcribed and although ALAB uses the automated
algorithm for evaluating the BFB tuning compound he wanted boundaries for manual evaluation
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 put in the SOP). ALAB was well prepared because the basis of our quality system is ISO-17025, and
the NELAC Standard is based on ISO. ANAB was notified by Jack in November of 2019 that the lab
will not be maintaining its’ ANAB accreditation and will only be CA ELAP accredited since the only
reason to keep the NAAB accreditation would be for out of state work which the lab does not
perform.
8 Changes in the volume and type of the work or in the range of laboratoryactivities
8.1 The ALAB analyzed 25164 samples in 2019, which is a 16% increase from 2018 (21674). The
distribution of work between the analysis methods was approximately 43% beryllium swipes,
28% IH metals swipes, 9% lead wipes, 28% subcontracted, and <1% beryllium air filters, IH
metals air filters, and lead paint. The subcontracted analyses (28%) increased appreciably in
2019 compared to the previous three years (12% in 2016, 17% in 2017 and 22% in 2018), which
is due to supporting increased construction activities across the site and the discovery of lead
contamination in buildings on the site. Some lead wipe analysis required overnight TAT, which
ALAB could not provide due to staffing considerations, and were subcontracted. The increased
subcontracting work affects ALAB staff as chemists are required to perform the administrative
tasks to send the samples offsite for analysis instead of using their time to perform sample
analyses in ALAB. An administrative staff person was trained to do the subcontract data entry
to provide occasional help to ALAB staff.
8.2 The following tables represent the breakdown of the major categories of IH work performed by
ALAB. The increase in subcontracted analyses may hide changes in the distribution of work
done in-house. Therefore, using 2017 as a baseline, the distribution of work will also be tracked
without the subcontracted work included as seen in the second table. A third table was added
that tracks TAT in calendar days to the ALAB overall goals.
CY2016 CY2017 CY2018 CY2019
Total Samples 17237 21560 21674 25164
% Be Swipes 63% 47% 43% 34%
% lH Metals Swipes 20% 32% 29% 28%
% Lead Wipes 5% 4% 6% 9%
% Subcontracted 12% 17% 22% 28%

CY2016 CY2017 CY2018 CY2019

Total Samples N/A 17944 17343 17813
% Be Swipes N/A 57% 56% 47%
% lH Metals Swipes N/A 38% 37% 39%

% Lead Wipes N/A 5% 7% 13%

CY2016 CY2017 CY2018 CY2019

Be Swipes (6 days) N/A 4.67 4.57 4.67
IH Metals Swipes (10 N/A 6.79 6.56 6.70
days)
Lead Wipes N/A 11.35 9.63 7.62

8.3 The ALAB continued the process of setting up environmental soil analysis methods in 2019. Six
new methods were implemented in 2019. Implementing three new fields of testing included a
new LIMS and was a large undertaking with many steps and moving pieces. Since theLIMS
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 implementation occurred during 2018 and 2019, details about the timeline are included in the
2018 Management Report. After ALAB became accredited for the new FOT’s by CA ELAP, the
EFA sent several batches of samples to ALAB and their commercial subcontract laboratory.
Their comparison of results indicated that the ALAB data was comparable to the data received
from the commercial subcontract laboratory.
8.4 In addition to the subcontracted lead wipes discussed above, ALAB analyzed 1080 lead wipes
inhouse during Q2 of this year. That is approximately the same number of lead wipes analyzed
in all of 2018.
Additional discussion: The work breakdown shows that the lH Metals and Pb Wipes are becoming a
higher proportion of ALAB’s work. These tests are more labor intensive, yet ALAB still mostly met
its weekly TAT goals and did meet its overall TAT goal. Although ALAB did get administrative
support for subcontract results data entry, the bulk of it over the course of the year still fell to ALAB
staff. After the Management Review, Jack decided to include the TAT information as part of this
report. Jack also mentioned that AS&l is probably seeing the increased subcontracting costs in our
budget.
9 Customer and personnel feedback
9.1 Customerfeedback
9.1.1 The ALAB Technical Manager received verbal and email feedback from several lH’s over
the course of the year complimenting ALAB on their responsiveness and customer service.
Several instances of this are noted in the quarterly reports, which are provided in Appendix 6.
9.1.2 ALAB was nominated for and received an ES&H Gold Award for the work they did in setting
up for the soils analysis.
9.1.3 To solicit feedback from ALAB customers, a five-question SurveyMonkey online survey was
distributed to all Industrial Hygienists and Health and Safety Technicians. Survey responses
were collected October 15-31, 2019. There were 25 survey responses out of 79 possible
respondents, for a 32% survey response rate. The survey had a 100% completion rate and
took 1 mm 7 sec to complete on average. Survey responses and results are detailed in the
ALAB Customer Feedback Oct 2019 Report (see Appendix 4). The responses in 2019 were
very comparable to those from the 2018 survey, with the average response to all items
greater than 4.5 out of 5. The survey responses provided good suggestions for
improvement ofALAB processes as well as highlighted the need for awareness of some of
the services that are already available.
Additional discussion: Since we now have several years’ worth of data, it might make sense to
start looking at the standard deviation of the data to see if the fluctuations are statistically
significant or just normal variation. Jack said that our response rate is above average for
surveys. Vicki commented that LEO has given similar positive feedback about the response
rate for surveys that the Assurance Office fields.

9.2 Personnel feedback

9.2.1 Personnel feedback was collected during work observations on 3/28/19 and 4/1/19. See
the FRM-5100s documenting the feedback in Appendix 3. Feedback requiring follow up is
discussed in other sections of this report.
10 Complaints
10.1 No formal complaints were received in 2019.
11 Effectiveness of any implemented improvements
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 11.1 Time course studies were completed to extend some standard solution expiration dates to
improve laboratory efficiency and reduce waste. The details are recorded in the Quarterly
Reports.
11.2 The Linear Range Extension (LRE) discussed in the 2018 Annual Management Review was
modified over the course of the year as experience was gained while using it. The
concentrations of some elements were increased to further extend the linear range. This
improves efficiency over the alternative of diluting the sample(s) with results above the
calibration curve and running those samples at the end of the sequence.
11.3 The work observations of all ALAB staff performing routine procedures were conducted on
3/28/19 and 4/1/19. The work observations were documented in ITS 47427 (see Appendix 3).
Several opportunities for improvement requiring follow-up were identified and are discussed
elsewhere in this report. This was an effective method for maintaining familiarity with
laboratory operations and culture and for soliciting feedback and improvement ideas from
ALAB staff.
11.4 ALAB implemented Revision 2 of the EPA Method Detection Limit (MDL) procedure, but there
were challenges with tracking the additional periodic verifications, especially with the low
sample volumes for some of the tests. A new tracking system was implemented to minimize
the risks of missing quarterly MDL verifications.
11.5 ALAB was authorized to procure a new ICP to replace one of the older ones in the lab. Jack
invited three vendors (Perkin Elmer, Agilent and Thermo Fisher) to LLNL to provide
information on their modern systems. He provided then with a testing protocol (see
attached example in Appendix 5) to demonstrate the performance of their instruments. Two
of the vendors (Agilent and Thermo Fisher) completed the testing, and Jack and Cora visited
the vendors to see the instruments in operation. After reviewing the testing data, Agilent
was chosen, and the instrument was delivered in December.
11.6 ALAB transferred all manual control charts into NWA QA Analyst for control charting.
12 Adequacy of resources
12.1 The ALAB QA Manager was challenged to stay current on all her responsibilities. One large
time sink is the administrative burden of editing and formatting SOP’s and other documents.
Management should consider ways to relieve some of that burden.
Additional discussion: Jack said that he does not believe that it is an effective use of QA’s time to
be editing documents. Michele asked Thom about the status of the Document Coordinator, and
he said that the position had not been filed.
12.2 Personnel in ALAB Two ALAB chemists announced their plans to retire in 2020.
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12.3 Equipment in ALAB

12.3.1 ALAB ICP instrumentation, though reliable, is starting to get old. Need to consider a plan
for replacing instruments. This is on ES&H’s long-term investment list.
Additional discussion: Although one instrument was replaced this year, it is important to keep the
replacement of the others in mind. Michele asked about the manufacturer supporting the older
instruments. Jack said that he did not know the official end of life status on the ICP’s because we do
not use Perkin Elmer as our service provider. Even if they are end of life and parts are not available
from Perkin Elmer that our third-party service provider buys old instruments and can salvage parts
from them.
13 Results of risk identification
13.1 Evaluation of risk ALAB continuously considers risks and opportunities in everything we
—

do from environmental, safety, health, efficiency, quality, and cost perspectives.

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 13.2 Risks to impartiality (i.e. conflicts of interest) none identified iriALAB
—

13.3 Preventive actions and process improvements are recorded in the Record of Planned and
Implemented Changes Logbook and Quarterly QA Reports (see Appendix 6). Ideas to mitigate
risk and improve processes were also captured during work observations of ALAB staff.
13.3.1 During his work observation Matt stated that all the networked computers in ALAB
are somewhat old and slow. Ruth observed some significant lag times while Matt was
working in Labworks. Matt said that ‘30-40% of the work of an environmental
method analysis is done through a networked computer. Matt suggested replacing
the three networked computers currently in ALAB and adding a fourth networked
computer to improve efficiency. Three new PC’s were procured and installed.
13.3.2 During her work observation Cora raised the issue of needing rapid approval of purchase
requests and what to do if both Jack and Michele are unavailable to give approval. Cora
suggested having two more people be authorized to give those approvals if needed or
wondered if an order could be submitted directly to the TRR with no approvals required
if the approvers were not available. Michele clarified that other Group leads could
approve purchase requests in the event that she or Jack were not available.
13.3.3 Not having a control chart for lead wipes and lead paint QC Unknown samples was
identified in the last management review as being a risk. However, it requires IT
support to accomplish. Since the recoveries of the QC Unknowns are still within limits
and since it is not a requirement but a best practice, this is a low risk to operations.
13.3.4 Resolve ALIMS Be Swipes Method spikes RPD calculation and reporting issues This is still
a risk being carried over from the 2018 report. Ruth contacted ALIMS support, but did
not have success in resolving the issue.
13.3.4.1 ALIMS inconsistently/incorrectly calculates spike sample relative
percent difference (RPD) values.
13.3.4.2 The ALIMS Precision Spike Recovery report does not show spike , ieand RPD
results for spikes 1 and 2, only for spikes 3 and 4.
Additional discussion: The Record of Planned and Implemented Changes Logbook serves its
purpose but is a somewhat cumbersome way of doing things. Items 13.3.3 and 13.3.4 have been
discussed elsewhere in this report. The largest risk to operations comes from Item 13.3.4, but it is
still negligible because the correct RPD values are monitored in the control charts generated using
data from the instruments.
14 Outcomes of the assurance of the validity of results
14.1 AIHA ELPAT Rounds 106411: Acceptable results for all rounds. Round 106 had one
unacceptable result (see NCR 10002205) but passed with a % overall score. Round 109 had
one unacceptable result (see NCR 1002368) but passed with a % overall score. On average, a
slight negative bias was observed in the data for both wipes and paint samples. The magnitude
of the bias does not impact the usability of the data.
14.2 AIHA ELPAT-Air Rounds 106-111: Acceptable results in all rounds.
14.3 AIHA IHPAT Rounds 216-221: Acceptable results in all rounds.
14.4 AIHA BePAT Rounds 49-52: Acceptable results in all rounds from both ALABand HIF HPL
methods.
14.5 WP-291 Trace Metals in Water acceptable results for all reported elements
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14.6 WP-291 Mercury in Water acceptable results

—

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 14.7 Metals in Sewage Sludge CRM acceptable results for all reported elements
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14.8 ERA Soil-108 Metals in Soil: Acceptable results for all metals reported.
14.9 Environmental soils PT round (Millipore-Sigma QT-0024202):
14.9.1 Metals in Soil: 100% Acceptable
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14.9.2 Mercury in Soil: 100% -Acceptable

14.9.3 TCLP VOA in Soil: 94% Acceptable 2-Butanone not acceptable (see NCR10002187)
- —

14.9.4 TCLP Metals CA WET in Soil: 100% Acceptable

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149.5 Low Level VOAs in Soil: 100% -Acceptable

14.10 Environmental soils PT round (Millipore-Sigma LPTP19-S4)
14.10.1 Metals CA WET in Soil: 100% Acceptable-

14.10.2 TCLP VOA in Soil: 100% -Acceptable

14.10.3. Low Level VOAs in Soil: 92% Acceptable Acetone, 2-Butanone, and Methyl
- —

bromide were not acceptable (see NCR 1002355). Retested new ampule from the
study and Acetone and 2-Butanone results for both samples were within acceptable
window of assigned value. A make-up PT was ordered.
14.11 NSI Lab Solutions SQCO-OO8LB Low Level VOCs in Soil (Make-up PT): 100% Acceptable for
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Acetone, 2-Butanone, and Methyl bromide

14,12 Audits of the three primary subcontract labs (Micro analytical, EM/P&K Labs and Bureau
Veritas) were performed by the Technical Manager and the Quality Manager. A review of
the entire scope of work at each laboratory was not performed. One of the higher volume
tests was chosen. A site visit was performed at Micro Analytical, and a data package review
was performed for the other two laboratories. The audits showed that the subcontract
laboratories can produce data of acceptable quality. See Appendix 2 for the detailed
information.
Additional discussion: Generally, the environmental PT’s challenge the laboratory with more
analytes than the IH PT’s, which make it more likely that there are analytes that will fail. Our
practice has been to do a make-up environmental PT any time an analyte fails, even if the analyte
group is marked acceptable after doing an investigation to see if the reason for the PT failure can
be determined. The investigation of the failure of several compounds in the Low-Level Soil VOC PT
was particularly challenging because of the significant high bias to the results for acetone because
acetone is not used in ALAB. The analyst was interviewed, and the steps taken to analyze the PT
were reviewed, and no discrepancies were noted. The spare ampoule of the PT was analyzed, and
the results were within the acceptance window. A makeup PT was ordered and was successfully
analyzed. The root cause of the failure was indeterminable.
15. Other relevant factors, such as monitoring activities and training
15.1. AS&l thermometers were calibrated by Micro Precision on 8/13/19. There were several
errors, which are detailed in the Q3 2019 Quarterly Report. The thermometers were sent
back to Micro Precision for investigation and recalibration, which was done on 9/12/19. The
problems were documented in NCR 10002297.
15.2. Copper has been recovering at the high end of the recovery range in the spike ‘r and
standards from several different sources were compared against each other. The results did
not show a clear indication of the source of the problem. Since there seems to be a
somewhat high bias (approx. 118% recovery) to the spike results, client sample results
would overestimate the copper concentration in the samples. Details are provided in the 02
2019 Quarterly Report. The investigation is ongoing.
Additional discussion: One avenue that was not explored was to procure a NIST SRM for Cu, but
9
 that was prohibitively expensive. The investigation continued into 2020, and an answer was found.
That will be discussed in the 2020 Management Review.
15.3. An lH raised a concern that some sample descriptions on reports from Micro Analytical do
not reflect what the IH expects. Micro Analytical was contacted and said that sample
descriptions can be somewhat subjective and that we are their only customer that does not
send sample descriptions along with the samples. This was discussed at an IH Meeting, and if
the techs provide their sample description paperwork to ALAB along with the samples, ALAB
will forward those descriptions to Micro Analytical. The details are documented in the 01
2019 Quarterly Report.
15.4. Micro Analytical underestimated asbestos results in a routine PLM batch. This was
discovered after a Point Count analysis was requested on one of the samples. The entire
batch was recounted, and two results were revised with higher asbestos levels than was
originally reported. Micro Analytical performed a root cause analysis and developed
corrective actions. The details are documented in the 02 2019 Quarterly Report.
16. Action items (with responsible individuals and timelines for completion)
16.1. Review the pH Conductivity SOP that is past-due for review —Jack/Jennifer (9/1/20).
16.2. Retire procedures for Digester Elements and Wastewater Sample Handling —Jennifer
8/15/20).
16.3. Bart and Jack to see if any value can be gained from consolidating subcontract labs for IHS
and Environmental testing Jack/Bart (11/30/20).
—

16.4. Investigate options for Document Coordinator/admin help with SOPs Michele/Thom
—

(12/31/20).
16.5. ICP remain on infrastructure investment list as a plan to replace —Jack/Michele (Completed).
16.6. Address ALIMS Be RPD and lH Metals RPD calculation issue and add James to help with IT
needs —Jack (12/31/20).
16.7. Diana to send a reminder to HSTs to continue to submit sample descriptions with asbestos
samples to ALAB Diana (9/30/20).
—

16.8. Perform gap analysis between NELAC 2009 and 2016 Standards Jack/Jennifer (10/31/20).
16.9. Add annual TAT information to Annual Management Review—Jack (Completed)
16.10. Investigate if creating a PIT for normal subcontracting will make it easier to track
subcontracting expenses Jack -9/15/20.
—

10
 ALAB CY2019 Management Review

Date: 07/16/2020 Time: 8:00 AM

Location: B253 R1703 Myers Rm Webex: Meeting Number (access code): 133 463 4315

Password: K5JrEFPYE28

Organized by: Jack Bennett

Name Signature Comment

Digitallysigned by John
Jack Bennett John Thomas Thomas Bennett Jr
Onsite
Date 202007 20
Bennett Jr. ,j 0912:45-0700

Digitally signed by Ruth

Ruth Harding Ruth N. N Harding
Telecommuting
Date 2020 07 20
Harding ,

Jennifer Cho Digitally signed by Onsite

JenniferCho
Jennifer Cho Date 202007 16
07 54 50 .0700

Diana Larson Digitally signed by Diana

Larson
Telecommuting
Diana Larson Date 20200720
,‘ 09:03:05 -0700

Vicki Salvo Victoria J Digitally signed by Victoria Telecom muting

J Salvo
Date 20200720
Salvo 08 39 55 -0700

Christopher Campbell CHRISTOPHE Digitaitysigned by Telecommuting

CHRISTOPHER CAMPBELL
Date 20200720111729
R CAM P BELL -00’00

Thom Kato ( Digitally signed by Telecommuting

Thomas T. Thomas T Kato
Date 2020 07 20
Kato 13 05 48 -0700

Michele Sundsmo V.A. Michele Digitally signed byVA Telecommuting

Michele Sundsmo
Dale 2020 07 20
Sundsmo )