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-~ ~ i III IIIIIIIIIIIIIIII • 999 INTEROFFICE COMMUNICATIONS DATE: July 10, 1992 TO: Jim Pendleton ~~~ FROM: Harry Posey RE: Independant labs REF: Your 9 July 1992 letter to A. Douchane (BMRI) regarding thQ independent sampling Your note that it may not be "appropriate for contarctor's supplyin~ services to BMRI to also participate in the independent sampling and analysis ef, orts" sticks in my craw. Let's talk. I have assumed that the lab of choice, regardless of any other g~alification, will be an independent EPA certified lab. That requirement ca ries certain strict obligations on the part of the lab that gives us an ext a measure of assurance of the lab's independence. 2 elaborate. 1. EPA certified labs are registered with the EPA. (This is no~ a big deal, except that to lose registration or certification, a lab pote tially loses a lot of contract money.) 2. To gain EPA certification, labs must subject themselves to routine unannounced verification monitoring by EPA. (Although, as I understand it, this function is rarely practiced except following comp aints, EPA's unannounced access to a lab is a hickory switch on the mantle.) 3. EPA certification provides some guarantee that the lab mgets at least minimum requirements in staffing, equipment, equipment) maintenance schedules, equipment monitoring, reagents and standards verification and storage, and in training. (Again, this is not a big dea except that Hawkeye Jacque's Corner Grocery and Geochemical Analysis hoppe is not going to be s'~1e to respond to our needs with qualified bac up unless he brings help from outside the store. This will cos Perhaps unreasonably.) 4. EPA certification also provides that the lab buildings thems~lvea provide some measure of protection from tampering or other inte ference with samples. 5. To my knowledge, there is no other certifying body comparab a to EPA for commercial labs. Without their help, we or the citizen of Costilla County will have the chore of certifying the independent ab. Neither they, nor we are qualified. Though none of these qualifications guarantee that unscrupulous o~erators will not be able to prostitute an unscrupulous lab into giving them numb rs they want, there really is no other reasonable alternative, in my opinion. In the case of CORE labs, the fact they have done contract work f~ BMRI in the past is not an issue (provided they are EPA certified.) The m re important aspect is that we verify the outside lab's analyses with check s mples, blind duplicates, etc. If we don't use CORE labs, here is what we face. 1. We will have to re-train another lab. (Your eyebrow disappe rs under your hat brim, but re-training really is what you do when you as~ a commercial lab to depart from any of the standard methods in order to give you the