Document xzyK3w6Oj2NDVV3Yy3qB0RE4g
Inspection Entry Date/Time Inspection Exit Date/Time
Regulatory Program Type of Inspection
EPA REGION 6 Enforcement Division
INSPECTION REPORT
05/22/2024 08:45 (CT)
Announced: No
05/22/2024 12:30 (CT)
Access: Granted
RCRA Focused Compliance Inspection (FCI)
Facility or Site Name Facility/Site Identifier Facility/Site Physical Address City, State, Zip Code County/Borough Generator Status NAICS Type of Operation
Geographic Coordinates
Miller Environmental Services TXD981056054 401 Navigation Blvd Corpus Christi, TX 78408 Nueces County None None Miller Environmental Services is a transporter of non-hazardous waste, hazardous waste, used oil, universal waste, asbestos, and naturally occurring radioactive material waste. 27.791894, -97.453075
Additional Persons Participating in Inspection:
Name
Title
Organization
Cameron Tanaka Erin Young-Dahl
Contractor Inspector
Eastern Research Group (ERG) EPA REGION 6
John Penland
Inspector
EPA REGION 6
Email Cameron.Tanaka@erg.com
YoungDahl.Erin@epa.gov Penland.John@epa.gov
Phone (508) 314-6432
(214) 665-3166 (214) 665-9717
Lead Inspector: Brook McKeown
ERG
Brook.McKeown@erg.com
09/03/2024 (410) 459-5811
Page 1 of 7
Miller Environmental Services
Inspection Date: 05/22/2024
SECTION I - INTRODUCTION
Site Entry and Purpose of the Inspection
The Port of Corpus Christi and surrounding facilities were selected for inspection based on an Environmental Justice and Regional initiative to evaluate facilities at ports receiving or transporting Resource Conservation and Recovery Act (RCRA)-regulated hazardous wastes, and/or have an International Convention for the Prevention of Pollution from Ships (MARPOL) Annex V Certificate of Adequacy (COA) issued by the U.S. Coast Guard (USCG).
This report is based on information supplied by the facility representatives, inspector observations, and records, including photographs taken (see Appendix 1), verbal or written statements made during or after the on-site inspection, and/or materials shown, demonstrated, or submitted to the EPA during or after the on-site inspection. In addition, information gathered prior to or after the inspection from a review of EPA, State, and public records may be included in this report.
Attendees
Title/Organization Lead Inspector/ Contractor/ERG RCRA Inspector/ Contractor/ERG Inspector/Enforcement Officer/EPA Region 6 Inspector/Enforcement Officer/EPA Region 6
Name
Phone
Email
Opening Closing Conf. Conf.
Brook McKeown (410) 459-5811 Brook.McKeown@erg.com Yes
No
Cameron Tanaka (508) 314-6432 Cameron.Tanaka@erg.com Yes
No
Erin Young-Dahl (214) 665-3166 YoungDahl.Erin@epa.gov Yes
Yes
John Penland (214) 665-9717 Penland.John@epa.gov Yes
Yes
Page 2 of 7
Miller Environmental Services
Inspection Date: 05/22/2024
Facility General Description
Tenant/Area Miller Environmental Services
Inspection Date
05/22/24
Process Description Miller Environmental Services (Miller) is a transporter of non-hazardous waste, hazardous waste, used oil, universal waste, asbestos, and naturally occurring radioactive material (NORM) waste. They provide industrial services including in-plant industrial cleaning services, transportation, environmental response, and spill response. Miller transports its customers' wastes via truck. The company also services pipelines, refineries, and terminals with on-site work such as hydro blasting. Miller stores hazardous and non-hazardous remediation wastes at its own site while the waste is being profiled. The company acts as a transfer facility for hazardous waste and used oil. When acting as a transfer facility, the waste containers remain on the trucks that they arrive in and leave the facility within 10 days. The company generates waste aerosol cans, used oil, and universal waste at its facility. Miller does not maintain any MARPOL COAs.
Area of Concern
Yes
Page 3 of 7
Miller Environmental Services SECTION II - OBSERVATIONS
Inspection Date: 05/22/2024
Tenant: Miller Environmental Services
Section: 2.1
Date: 05/22/24, 8:45 AM
Contains AOC: Yes Contains CBI: No
Lead Inspector: Brook McKeown
Attendees: Lewis Steinhagen (Waste Manager), Bill Johnson (Compliance Manager)
Miller is a transporter of non-hazardous waste, hazardous waste, used oil, universal waste, asbestos, and naturally occurring radioactive material (NORM) waste. The company mostly transports waste via trucks and occasionally via vessels. Its tankers and vacuum trucks can take liquid and solid waste. The company's transportation services at terminals are generally for waste generated at the terminals and not for waste coming off of vessels. Miller provides industrial services including in-plant industrial cleaning services, transportation, waste profiling, environmental response, and spill response. For spill responses, Miller drums up the spilled material and handles the waste and contaminated media as transportation related waste that they do not generate. Non-hazardous spill drums are sometimes unloaded and stored at its site when Miller needs a truck to respond to another spill. The company also service pipelines, refineries, and terminals with on-site work such as hydro and sand blasting. Miller generally does not manage the wastes from its on-site work. Miller will occasionally be asked to collect samples and profile the waste generated during this work. However, if a current waste profile already exists, Miller will just transport the waste between the generator and US Ecology for disposal. Miller generates waste aerosol cans, used oil, and universal waste at its own facility. The company also have a mechanical team that builds drums. Miller also performs third party work for EOG Resources, Inc. under a corporate contract, including spill cleanups, waste profiling, and pickups of routine non-hazardous or RCRA exempt maintenance waste.
Miller is registered as a transporter and used oil handler under EPA ID TXD981056054. The company transports its customers' wastes via truck. Miller generally tries to avoid bringing its customers' wastes on its site for storage, but it does store hazardous and non-hazardous remediation wastes while the waste is being profiled within its role as a transfer facility for hazardous waste and used oil. When acting as a transfer facility, the waste containers remain on the trucks that they arrive in and leave within 10 days. Wastes that Miller handles are mostly transported to US Ecology. The inspection team viewed hazardous and nonhazardous manifests for Miller and noted no issues. Miller has a permit to transport used oil and transports about one to three loads of used oil every quarter. Miller generally delivers its transported used oil to Western Gulf Recycling and the used oil it generates onsite to H&H Oil Recyclers. Miller does not maintain a MARPOL COA. Miller is also licensed by the USCG to provide spill cleanup services on the water.
During the inspection, the inspection team observed the warehouse, truck bay, fueling area, yard area, and remediation waste area (see Appendix 1 - Photo 11). Observations and AOCs are organized by section below along with facility responses where relevant.
Warehouse:
In the warehouse, the inspection team observed universal waste lamps that were picked up by Miller between February and March 2024 (see Appendix 1 - Photos 1 and 2). Some lamps were dated from January 2023, but others were undated. The inspection team also observed over 25 spent lead acid batteries that were not properly labeled or otherwise identified as spent (see Appendix 1 - Photo 3) [AOC #1 - Miller did not label batteries being managed as universal waste properly or store the batteries in a properly labeled container - 40 CFR 273.14(a)]. In a response email from 06/05/2024, Mr. Johnson included a document responding to any document requests and AOCs that the inspection team identified during the inspection
Page 4 of 7
Miller Environmental Services
Inspection Date: 05/22/2024
(see Appendix 2). In this response, Mr. Johnson indicated that Miller placed a sign designating the batteries as universal waste (see Appendix 2). He also included a photograph showing the sign (see Appendix 3 - Photo 1).
Truck Bay:
The inspection team also observed four additional spent lead acid batteries that were not properly labeled or otherwise identified as spent in the truck bay (see Appendix 1 - Photo 4) [see AOC #1]. In his response, Mr. Johnson indicated that Miller placed a sign designating the batteries as universal waste (see Appendix 2) and included a photograph showing the sign (see Appendix 3 - Photo 1). The team observed a tank of used oil generated by Miller that did not have a visible label (see Appendix 1 - Photos 5 and 6). The inspection team also observed several plastic carboys used to hold used oil that were not properly labeled (see Appendix 1 - Photo 7). [AOC #2 - Miller did not clearly label a tank and containers used to store used oil with the words "Used Oil" - 40 CFR 279.22(c)(1)]. Mr. Johnson included photographs in his response email showing the used oil tank and used oil carboys with visible labels (see Appendix 3 - Photos 2 and 3).
Fueling Area:
The inspection team observed a plastic tote labeled as "Used Scrub Oil" (see Appendix 1 - Photo 8) [see AOC #2]. Mr. Johnson indicated that the tote is used to hold used oil generated from vacuum pumps on their trucks and that it was not accumulating used oil at the time of the inspection. Mr. Johnson included a photograph in his response email showing the used oil tote with a visible label (see Appendix 3 - Photo 4).
Yard Area:
The inspection team observed three unlabeled black poly 55-gallon drums located in the yard and an unlabeled blue poly 55-gallon drum located in on the north side of the yard (see Appendix 1 - Photos 9 and 10). The inspection team asked for clarification on the contents of the poly drums. In his response, Mr. Johnson indicated that a sample was taken from the three black drums and the blue drum and sent to Western Gulf Recycling, who confirmed that the material was recyclable water at its lab (see Appendix 2). The drums were all recycled at Western Gulf Recycling and a transportation Bill of Lading (BOL) was included as Appendix 4. The inspection team observed a heat exchanger which contained visible solids/debris that was transported to the facility from a customer and stored on the north side of the yard adjacent to the blue poly drum. The debris within the heat exchanger was also observed deposited on the concrete adjacent to the heat exchanger (see Appendix 1 - Photo 10). A waste determination on the debris had not been conducted [AOC #4 - Miller did not make an accurate determination as to whether its waste is a hazardous waste in order to ensure wastes are properly managed according to applicable RCRA regulations. - 40 CFR 262.11]. The inspection team asked for a waste characterization of the contents of the heat exchanger and the solids associated with it that had spilled onto the concrete. The inspection team also asked Miller for the date the heat exchanger was brought to the site, an explanation of how Miller would be managing the solids/debris associated with the heat exchanger, and any waste analytical results on the solids/debris from the heat exchanger. In his response email, Mr. Johnson indicated that the heat exchanger was brought onsite about 2 years ago, with the assumption that it was emptied and cleaned prior to shipment, to be used as a training fixture for the company's hydro blasting personnel. Mr. Johnson's email added that based on the manufacturer's tag on the equipment, the unit was a Glycol Preheater manufactured in Beaumont, TX in 2002 (see Appendix 2). Mr. Johnson explained that samples of the material were collected from inside the equipment and on the concrete around it. In his 08/12/2024 email, Mr. Johnson provided the final laboratory report from Pace Analytical (see Appendix 6). Although Miller had received the final lab report, Mr. Johnson indicated that Miller personnel had not disposed of the drum because they were trying to determine whether the material was K050 listed hazardous waste (exchanger bundle cleaning sludge from a petroleum refinery) (see Appendix 5). In a second follow-up email from 08/12/2024, Mr. Johnson provided additional information
Page 5 of 7
Miller Environmental Services
Inspection Date: 05/22/2024
regarding the final lab report and Miller's waste determination for the material (see Appendix 7). Mr. Johnson also explained that Miller personnel removed the material from the heat exchanger and the concrete and placed it in a 55-gallon drum after sending a sample off for laboratory analysis (see Appendix 2). In a followup email dated 08/12/2024, Mr. Johnson stated that the cleanup generated less than 100 pounds of material (see Appendix 5). Mr. Johnson also included photographs of the side of the heat exchanger and the adjacent concrete following the cleanup (see Appendix 3 - Photos 5 and 6).
Remediation Waste Area:
No areas of concern (AOCs) were observed in the remediation waste area.
A closing conference was conducted at approximately 12:00 PM with Miller personnel. The AOCs were communicated during the closing conference; however, further EPA review may change or add to their potential AOCs.
SECTION III - RECORDS REVIEW No RCRA-regulated records were reviewed during this focused onsite inspection.
SECTION IV - AREAS OF CONCERN
The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Tenant: Miller Environmental Services
AOC #1 - Miller did not label batteries being managed Citation: 40 CFR 273.14(a) as universal waste properly or store the batteries in a properly labeled container.
Section: 2.1
AOC #2 - Miller did not label a tank and containers used to store used oil with the words "Used Oil".
Citation: 40 CFR 279.22(c)(1)
Section: 2.1
AOC #3 - Miller did not make an accurate determination as to whether its waste is a hazardous waste in order to ensure wastes are properly managed according to applicable RCRA regulations.
Citation: 40 CFR 262.11
Section: 2.1
Page 6 of 7
Miller Environmental Services SECTION V - FOLLOW UP
Inspection Date: 05/22/2024
Any facility follow-up items are as discussed in the observations in Section II. Documents or files provided by the facility were transmitted via email and included responses to AOCs or provision of documents requested.
Communication Log
During and after the inspection, additional information was emailed to EPA including: 1. 06/05/24 Miller email - Bill Johnson sent an email with requested documentation, responses to AOCs, and photos showing corrective actions attached. 2. 08/12/24 Miller email - Bill Johnson sent an email with the final lab report for the material removed from the heat exchanger and concrete and an explanation of their progress in handling the waste. 3. 08/12/24 Miller email - Bill Johnson sent an email clarifying aspects of the final lab report for the material removed from the heat exchanger and his previous email explaining their progress in handling the waste.
SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. Follow-Up Document from Miller Appendix 3. Follow-Up Photographs from Miller Appendix 4. Western Gulf BOL and Invoice for Poly Drums in Yard Appendix 5. First Follow-Up Email from Miller August 12, 2024 Appendix 6. Laboratory Results for Heat Exchanger Material Appendix 7. Second Follow-up Email From Miller August 12, 2024
Page 7 of 7
APPENDIX 1. PHOTOGRAPH LOG
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 1
Location: Miller Environmental Services
City: Corpus Christi
County/Parish: Nueces
State: Texas
Photo File Name: DSCN1089 Date of Photo: 05/22/2024 Time of Photo: 10:34 hrs. Photographer: Cameron Tanaka Description: Overview of universal waste lamps in Miller's warehouse (observed).
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 2
Location: Miller Environmental Services
City: Corpus Christi
County/Parish: Nueces
State: Texas
Photo File Name: DSCN1090 Date of Photo: 05/22/2024 Time of Photo: 10:34 hrs. Photographer: Cameron Tanaka Description: Closeup view of a universal waste lamp label dated from January 2023 in Miller's warehouse (observed).
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 3
Location: Miller Environmental Services
City: Corpus Christi
County/Parish: Nueces
State: Texas
Photo File Name: DSCN1091 Date of Photo: 05/22/2024 Time of Photo: 10:39 hrs. Photographer: Cameron Tanaka Description: View of pallets of spent lead acid batteries that were not properly labeled in Miller's warehouse.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 4
Location: Miller Environmental Services
City: Corpus Christi
County/Parish: Nueces
State: Texas
Photo File Name: DSCN1092 Date of Photo: 05/22/2024 Time of Photo: 10:42 hrs. Photographer: Cameron Tanaka Description: View of spent lead acid batteries that were not properly labeled in Miller's truck bay.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 5
Location: Miller Environmental Services
City: Corpus Christi
County/Parish: Nueces
State: Texas
Photo File Name: DSCN1093 Date of Photo: 05/22/2024 Time of Photo: 10:45 hrs. Photographer: Cameron Tanaka Description: View of used oil tank without a visible label in Miller's truck bay.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 6
Location: Miller Environmental Services
City: Corpus Christi
County/Parish: Nueces
State: Texas
Photo File Name: DSCN1094 Date of Photo: 05/22/2024 Time of Photo: 10:45 hrs. Photographer: Cameron Tanaka Description: Closeup view of used oil tank without a visible label in Miller's truck bay.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 7
Location: Miller Environmental Services
City: Corpus Christi
County/Parish: Nueces
State: Texas
Photo File Name: DSCN1095 Date of Photo: 05/22/2024 Time of Photo: 10:48 hrs. Photographer: Cameron Tanaka Description: View of one of the plastic carboys used to hold used oil in Miller's truck bay that was not properly labeled.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 8
Location: Miller Environmental Services
City: Corpus Christi
County/Parish: Nueces
State: Texas
Photo File Name: DSCN1096 Date of Photo: 05/22/2024 Time of Photo: 10:52 hrs. Photographer: Cameron Tanaka Description: View of plastic tote labeled as "Used Scrub Oil" containing used oil in Miller's fueling area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 9
Location: Miller Environmental Services
City: Corpus Christi
County/Parish: Nueces
State: Texas
Photo File Name: DSCN1097 Date of Photo: 05/22/2024 Time of Photo: 11:07 hrs. Photographer: Cameron Tanaka Description: View of three unlabeled black poly 55-gallon drums in Miller's yard area (observed).
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 10
Location: Miller Environmental Services
City: Corpus Christi
County/Parish: Nueces
State: Texas
Photo File Name: DSCN1098 Date of Photo: 05/22/2024 Time of Photo: 11:08 hrs. Photographer: Cameron Tanaka Description: Overview of heat exchanger with visible solids/debris inside of it and on the adjacent concrete, and blue poly 55-gallon drum in Miller's yard area.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 11
Location: Miller Environmental Services
City: Corpus Christi
County/Parish: Nueces
State: Texas
Photo File Name: DSCN1099 Date of Photo: 05/22/2024 Time of Photo: 11:28 hrs. Photographer: Cameron Tanaka Description: View of sign at Miller's remediation waste area.
APPENDIX 2. FOLLOW-UP DOCUMENT FROM MILLER
Appendix 2 Page 1 of 2
Appendix 2 Page 2 of 2
APPENDIX 3. FOLLOW-UP PHOTOGRAPHS FROM MILLER
Appendix 3 Page 1 of 6
Appendix 3 Page 2 of 6
Appendix 3 Page 3 of 6
Appendix 3 Page 4 of 6
Appendix 3 Page 5 of 6
Appendix 3 Page 6 of 6
APPENDIX 4. WESTERN GULF BOL AND INVOICE FOR POLY DRUMS IN YARD
Appendix 4 Page 1 of 2
Appendix 4 Page 2 of 2
APPENDIX 5. FIRST FOLLOW-UP EMAIL FROM MILLER AUGUST 12, 2024
Appendix 5 Page 1 of 3
Appendix 5 Page 2 of 3
Appendix 5 Page 3 of 3
APPENDIX 6. LABORATORY RESULTS FOR HEAT EXCHANGER MATERIAL
ANALYTICAL REPORT
June 26, 2024
Miller Environmental Services, LLC
Sample Delivery Group:
L1740531
Samples Received:
05/25/2024
Project Number:
Description:
MILLER TRAINING BUNDLE SLUDGE
Report To:
Bill Johnson 401 Navigation Corpus Christi, TX 78406
Entire Report Reviewed By: [Preliminary Report]
Lori A Vahrenkamp
Project Manager
Results relate only to the items tested or calibrated and are reported as rounded values. This test report shall not be reproduced, except in full, without written approval of the laboratory. Where applicable, sampling conducted by Pace Analytical National is performed per guidance provided in laboratory standard operating procedures ENV-SOP-MTJL-0067 and ENV-SOP-MTJL-0068. Where sampling conducted by the customer, results relate to the accuracy of the information provided, and as the samples are received.
1 Cp 2Tc 3 Ss 4 Cn 5Sr 6Qc 7 Gl 8Al 9Sc
Pace Analytical National
12065 Lebanon Rd Mount Juliet, TN 37122 615-758-5858 800-767-5859 mydata.pacelabs.com
ACCOUNT: Miller Environmental Services, LLC
PROJECT:
SDG: L1740531
DATE/TIME: 0066//2266//2244 1121::4033
PAGE: 1 of 21
Appendix 6 Page 1 of 21
TABLE OF CONTENTS
Cp: Cover Page Tc: Table of Contents Ss: Sample Summary Cn: Case Narrative Sr: Sample Results
SAMPLE 1 - TOTALS L1740531-01 SAMPLE 1 - TCLP L1740531-02 Qc: Quality Control Summary Total Solids by Method D2974 Wet Chemistry by Method 9014 Mercury by Method 7471A Metals (ICP) by Method 6010 Metals (ICP) by Method 6010B Semi Volatile Organic Compounds (GC/MS) by Method 8270C Gl: Glossary of Terms Al: Accreditations & Locations Sc: Sample Chain of Custody
1
1
Cp
2
3 2Tc
4
3
5
Ss
5
4
Cn
6
7 5Sr
7
6
8
Qc
9
7
Gl
10
12 8Al
13
9
15
Sc
16
17
ACCOUNT: Miller Environmental Services, LLC
PROJECT:
SDG:
L1740531
Appendix 6 Page 2 of 21
DATE/TIME: 0066//2266//2244 1121::4033
PAGE: 2 of 21
SAMPLE 1 - TOTALS L1740531-01 Solid
Method
Total Solids by Method D2974 Wet Chemistry by Method 9014 Mercury by Method 7471A Metals (ICP) by Method 6010 Semi Volatile Organic Compounds (GC/MS) by Method 8270C
SAMPLE 1 - TCLP L1740531-02 Waste
Method
Preparation by Method 1311 Metals (ICP) by Method 6010B Semi Volatile Organic Compounds (GC/MS) by Method 8270C
SAMPLE SUMMARY
Batch
WG2297546 WG2295421 WG2300577 WG2296188 WG2306936
Dilution
1 1.01 5
1 64.4
Collected by LEWIS STERNHAGEN
Preparation date/time
06/03/24 14:02 05/30/24 15:49 06/07/24 13:14 05/31/24 11:30 06/19/24 22:00
Collected date/time Received date/time 05/23/24 15:00 05/25/24 09:05
Analysis date/time 06/03/24 14:10 05/30/24 15:49 06/09/24 19:03 06/01/24 09:09 06/20/24 20:53
Analyst
EIG TJG AKB TJG DSH
Location
Allen, TX Allen, TX Mt. Juliet, TN Allen, TX Mt. Juliet, TN
Batch
WG2305000 WG2306047 WG2305877
Dilution
1 1 1
Collected by LEWIS STERNHAGEN
Preparation date/time
06/14/24 13:38 06/17/24 08:53 06/15/24 20:00
Collected date/time Received date/time 05/23/24 15:00 05/25/24 09:05
Analysis date/time 06/14/24 13:38 06/17/24 19:05 06/16/24 12:35
Analyst
JWS DJS ADF
Location
Mt. Juliet, TN Mt. Juliet, TN Mt. Juliet, TN
1 Cp 2Tc 3 Ss 4 Cn 5Sr 6Qc 7 Gl 8Al 9Sc
ACCOUNT: Miller Environmental Services, LLC
PROJECT:
SDG:
L1740531
Appendix 6 Page 3 of 21
DATE/TIME: 0066//2266//2244 1121::4033
PAGE: 3 of 21
CASE NARRATIVE
1 Cp
All sample aliquots were received at the correct temperature, in the proper containers, with the
appropriate preservatives, and within method specified holding times, unless qualified or notated within
2
the report. Where applicable, all MDL (LOD) and RDL (LOQ) values reported for environmental samples
Tc
have been corrected for the dilution factor used in the analysis. All Method and Batch Quality Control
are within established criteria except where addressed in this case narrative, a non-conformance form
3
or properly qualified within the sample results. By my digital signature below, I affirm to the best of my
Ss
knowledge, all problems/anomalies observed by the laboratory as having the potential to affect the
quality of the data have been identified by the laboratory, and no information or data have been
4
knowingly withheld that would affect the quality of the data.
Cn
5Sr
6Qc [Preliminary Report]
7 Gl
P r o j e c t M a n a g e r L o r i A V a h r e n k a m p 8Al 9Sc
ACCOUNT: Miller Environmental Services, LLC
PROJECT:
SDG:
L1740531
Appendix 6 Page 4 of 21
DATE/TIME: 0066//2266//2244 1121::4033
PAGE: 4 of 21
SAMPLE 1 - TOTALS
Collected date/time: 05/23/24 15:00
Total Solids by Method D2974
Analyte
Result
Total Solids
92.5
SAMPLE RESULTS - 01
L1740531
Units
Qualifier Dilution Analysis
Batch
date / time
%
1
06/03/2024 14:10
WG2297546
Wet Chemistry by Method 9014
Analyte
Result mg/kg
Qualifier
Cyanide
<0.767
MDL mg/kg 0.767
RDL mg/kg 5.05
Dilution 1.01
Analysis date / time 05/30/2024 15:49
Batch WG2295421
Mercury by Method 7471A
Analyte
Result mg/kg
Mercury
3.12
Qualifier
MDL mg/kg 0.0900
RDL mg/kg 0.200
Dilution 5
Analysis date / time 06/09/2024 19:03
Batch WG2300577
Metals (ICP) by Method 6010
Analyte
Result mg/kg
Antimony Arsenic Barium Beryllium Cadmium Chromium Lead Nickel Selenium Silver
4.48 3.38 938 0.0404 2.08 39.2 99.6 38.0 0.966 0.173
Qualifier
V J
J3 J J
MDL mg/kg 0.222 0.254 0.0780 0.00800 0.0460 0.245 0.105 0.0760 0.362 0.0256
RDL mg/kg 1.25 1.00 1.00 0.0500 0.500 0.500 0.500 0.500 1.00 0.250
Dilution
1 1 1 1 1 1 1 1 1 1
Analysis date / time 06/01/2024 09:09 06/01/2024 09:09 06/01/2024 09:09 06/01/2024 09:09 06/01/2024 09:09 06/01/2024 09:09 06/01/2024 09:09 06/01/2024 09:09 06/01/2024 09:09 06/01/2024 09:09
Batch
WG2296188 WG2296188 WG2296188 WG2296188 WG2296188 WG2296188 WG2296188 WG2296188 WG2296188 WG2296188
Semi Volatile Organic Compounds (GC/MS) by Method 8270C
Analyte
Result mg/kg
Qualifier
MDL mg/kg
RDL mg/kg
Dilution
Phenol
<0.863
T8
(S) 2-Fluorophenol
81.3
J7
(S) Phenol-d5
76.2
J7
(S) Nitrobenzene-d5
79.2
J7
(S) 2-Fluorobiphenyl
74.5
J7
(S) 2,4,6-Tribromophenol 92.5
J7
(S) p-Terphenyl-d14
77.9
J7
0.863
21.4
64.4
12.0-120
10.0-120
10.0-122
15.0-120
10.0-127
10.0-120
Analysis date / time 06/20/2024 20:53 06/20/2024 20:53 06/20/2024 20:53 06/20/2024 20:53 06/20/2024 20:53 06/20/2024 20:53 06/20/2024 20:53
Batch
WG2306936 WG2306936 WG2306936 WG2306936 WG2306936 WG2306936 WG2306936
Sample Narrative: L1740531-01 WG2306936: Dilution due to matrix impact during extraction procedure. Surrogate failure due to matrix.
1 Cp 2Tc 3 Ss 4 Cn 5Sr 6Qc 7 Gl 8Al 9Sc
ACCOUNT: Miller Environmental Services, LLC
PROJECT:
SDG:
L1740531
Appendix 6 Page 5 of 21
DATE/TIME: 0066//2266//2244 1121::4033
PAGE: 5 of 21
SAMPLE 1 - TCLP
Collected date/time: 05/23/24 15:00
Preparation by Method 1311
Analyte
Result
TCLP Extraction
-
Initial pH
5.22
Final pH
5.98
SAMPLE RESULTS - 02
L1740531
Qualifier
Prep date / time 6/14/2024 1:38:52 PM 6/14/2024 1:38:52 PM 6/14/2024 1:38:52 PM
Batch
WG2305000 WG2305000 WG2305000
Metals (ICP) by Method 6010B
Analyte
Result
Qualifier RDL
Limit
mg/l
mg/l
mg/l
Chromium Nickel
<0.100 <0.100
0.100
5
0.100
Dilution
1 1
Analysis date / time 06/17/2024 19:05 06/17/2024 19:05
Semi Volatile Organic Compounds (GC/MS) by Method 8270C
Analyte
Result
Qualifier RDL
Limit
mg/l
mg/l
mg/l
Benzo(a)pyrene (S) 2-Fluorophenol (S) Phenol-d5 (S) Nitrobenzene-d5 (S) 2-Fluorobiphenyl (S) 2,4,6-Tribromophenol (S) p-Terphenyl-d14
<0.100
Q
25.7
26.9
67.3
57.9
44.2
55.2
0.100 10.0-120 10.0-120 10.0-127 10.0-130 10.0-155 10.0-128
Dilution 1
Analysis date / time 06/16/2024 12:35 06/16/2024 12:35 06/16/2024 12:35 06/16/2024 12:35 06/16/2024 12:35 06/16/2024 12:35 06/16/2024 12:35
Batch
WG2306047 WG2306047
Batch
WG2305877 WG2305877 WG2305877 WG2305877 WG2305877 WG2305877 WG2305877
1 Cp 2Tc 3 Ss 4 Cn 5Sr 6Qc 7 Gl 8Al 9Sc
ACCOUNT: Miller Environmental Services, LLC
PROJECT:
SDG:
L1740531
Appendix 6 Page 6 of 21
DATE/TIME: 0066//2266//2244 1121::4033
PAGE: 6 of 21
WG2297546
Total Solids by Method D2974
QUALITY CONTROL SUMMARY
L1740531-01
L1740527-08 Original Sample (OS) Duplicate (DUP)
(OS) L1740527-08 06/03/24 14:10 (DUP) R4077054-1 06/03/24 14:10
Original Result DUP Result Dilution DUP RPD
Analyte Total Solids
%
%
%
87.8
88.0
1
0.182
DUP Qualifier
DUP RPD Limits
%
20
1 Cp 2Tc 3 Ss
4 Cn
5Sr
6Qc
7 Gl
8Al
9Sc
ACCOUNT: Miller Environmental Services, LLC
PROJECT:
SDG: L1740531
Appendix 6 Page 7 of 21
DATE/TIME: 0066//2266//2244 1121::4033
PAGE: 7 of 21
WG2295421
Wet Chemistry by Method 9014
Method Blank (MB)
(MB) R4076162-1 05/30/24 15:49
MB Result
Analyte
mg/kg
Cyanide
<0.760
MB Qualifier
MB MDL mg/kg 0.760
QUALITY CONTROL SUMMARY
L1740531-01
MB RDL mg/kg 5.00
Laboratory Control Sample (LCS)
(LCS) R4076162-2 05/30/24 15:49
Spike Amount
Analyte
mg/kg
LCS Result mg/kg
Cyanide
10.0
9.09
LCS Rec. % 90.9
Rec. Limits % 85.0-115
LCS Qualifier
L1740531-01 Original Sample (OS) Matrix Spike (MS) Matrix Spike Duplicate (MSD)
(OS) L1740531-01 05/30/24 15:49 (MS) R4076162-3 05/30/24 15:49 (MSD) R4076162-4 05/30/24 15:49
Spike Amount Original Result MS Result
MSD Result MS Rec.
MSD Rec.
Analyte
mg/kg
mg/kg
mg/kg
mg/kg
%
%
Dilution
Cyanide
10.0
<0.767
9.45
9.29
94.5
93.8
1
Rec. Limits % 85.0-115
MS Qualifier
MSD Qualifier RPD % 1.70
RPD Limits % 20
1 Cp 2Tc 3 Ss 4 Cn 5Sr 6Qc 7 Gl 8Al 9Sc
ACCOUNT: Miller Environmental Services, LLC
PROJECT:
SDG: L1740531
Appendix 6 Page 8 of 21
DATE/TIME: 0066//2266//2244 1121::4033
PAGE: 8 of 21
WG2300577
Mercury by Method 7471A
Method Blank (MB)
(MB) R4079269-1 06/09/24 17:07
MB Result
Analyte
mg/kg
Mercury
<0.0180
MB Qualifier
MB MDL mg/kg 0.0180
QUALITY CONTROL SUMMARY
L1740531-01
MB RDL mg/kg 0.0400
Laboratory Control Sample (LCS)
(LCS) R4079269-2 06/09/24 17:10
Spike Amount
Analyte
mg/kg
LCS Result mg/kg
Mercury
0.500
0.468
LCS Rec. % 93.6
Rec. Limits % 80.0-120
LCS Qualifier
L1743501-14 Original Sample (OS) Matrix Spike (MS) Matrix Spike Duplicate (MSD)
(OS) L1743501-14 06/09/24 17:13 (MS) R4079269-4 06/09/24 17:23 (MSD) R4079269-5 06/09/24 17:26
Spike Amount Original Result MS Result
MSD Result MS Rec.
MSD Rec.
Analyte
mg/kg
mg/kg
mg/kg
mg/kg
%
%
Dilution
Mercury
0.500
0.0191
0.469
0.461
90.1
88.3
1
Rec. Limits % 75.0-125
MS Qualifier
MSD Qualifier RPD % 1.85
RPD Limits % 20
1 Cp 2Tc 3 Ss 4 Cn 5Sr 6Qc 7 Gl 8Al 9Sc
ACCOUNT: Miller Environmental Services, LLC
PROJECT:
SDG: L1740531
Appendix 6 Page 9 of 21
DATE/TIME: 0066//2266//2244 1121::4033
PAGE: 9 of 21
WG2296188
Metals (ICP) by Method 6010
Method Blank (MB)
(MB) R4076110-1 06/01/24 09:01
MB Result
Analyte
mg/kg
Antimony Arsenic Barium Beryllium Cadmium Chromium Lead Nickel Selenium Silver
<0.222 <0.254 <0.0780 <0.00800 <0.0460 <0.245 <0.105 <0.0760 <0.362 <0.0256
MB Qualifier
MB MDL mg/kg 0.222 0.254 0.0780 0.00800 0.0460 0.245 0.105 0.0760 0.362 0.0256
QUALITY CONTROL SUMMARY
L1740531-01
MB RDL mg/kg 1.25 1.00 1.00 0.0500 0.500 0.500 0.500 0.500 1.00 0.250
Laboratory Control Sample (LCS)
(LCS) R4076110-2 06/01/24 09:05
Spike Amount
Analyte
mg/kg
LCS Result mg/kg
Antimony Arsenic Barium Beryllium Cadmium Chromium Lead Nickel Selenium Silver
50.0
47.1
50.0
48.5
50.0
49.0
50.0
49.5
50.0
48.0
50.0
48.7
50.0
47.1
50.0
48.6
50.0
46.5
25.0
22.9
LCS Rec. % 94.2 96.9 97.9 99.1 96.0 97.5 94.1 97.2 93.0 91.8
Rec. Limits % 80.0-120 80.0-120 80.0-120 80.0-120 80.0-120 80.0-120 80.0-120 80.0-120 80.0-120 80.0-120
LCS Qualifier
L1740531-01 Original Sample (OS) Matrix Spike (MS) Matrix Spike Duplicate (MSD)
(OS) L1740531-01 06/01/24 09:09 (MS) R4076110-3 06/01/24 09:13 (MSD) R4076110-4 06/01/24 09:17
Spike Amount Original Result MS Result
MSD Result MS Rec.
MSD Rec.
Analyte
mg/kg
mg/kg
mg/kg
mg/kg
%
%
Dilution
Antimony Arsenic Barium Beryllium Cadmium Chromium Lead
50.0
4.48
48.4
46.3
87.9
83.6
1
50.0
3.38
48.5
45.8
90.2
84.8
1
50.0
938
939
1130
2.36
377
1
50.0
0.0404
47.4
44.4
94.8
88.7
1
50.0
2.08
47.1
44.1
90.0
84.0
1
50.0
39.2
86.0
92.2
93.7
106
1
50.0
99.6
129
159
59.8
119
1
Rec. Limits % 10.0-120 29.0-128 10.0-200 53.0-123 37.0-120 38.0-137 17.0-138
MS Qualifier V
MSD Qualifier RPD
%
4.52
5.64
V
18.1
6.60
6.63
6.96
J3
20.4
ACCOUNT: Miller Environmental Services, LLC
PROJECT:
SDG: L1740531
Appendix 6 Page 10 of 21
DATE/TIME: 0066//2266//2244 1121::4033
RPD Limits % 20 20 20 20 20 20 20
1 Cp 2Tc 3 Ss 4 Cn 5Sr 6Qc 7 Gl 8Al 9Sc
PAGE: 10 of 21
WG2296188
Metals (ICP) by Method 6010
QUALITY CONTROL SUMMARY
L1740531-01
L1740531-01 Original Sample (OS) Matrix Spike (MS) Matrix Spike Duplicate (MSD)
(OS) L1740531-01 06/01/24 09:09 (MS) R4076110-3 06/01/24 09:13 (MSD) R4076110-4 06/01/24 09:17
Spike Amount Original Result MS Result
MSD Result MS Rec.
MSD Rec.
Analyte
mg/kg
mg/kg
mg/kg
mg/kg
%
%
Dilution
Nickel Selenium Silver
50.0
38.0
81.4
87.7
86.8
99.5
1
50.0
0.966
43.7
41.0
85.4
80.0
1
25.0
0.173
22.5
21.6
89.4
85.7
1
Rec. Limits % 40.0-123 29.0-112 35.0-129
MS Qualifier
MSD Qualifier RPD % 7.51 6.39 4.16
RPD Limits % 20 20 20
1 Cp 2Tc 3 Ss 4 Cn 5Sr 6Qc 7 Gl 8Al 9Sc
ACCOUNT: Miller Environmental Services, LLC
PROJECT:
SDG: L1740531
Appendix 6 Page 11 of 21
DATE/TIME: 0066//2266//2244 1121::4033
PAGE: 11 of 21
WG2306047
Metals (ICP) by Method 6010B
Method Blank (MB)
(MB) R4082998-1 06/17/24 18:55
MB Result
Analyte
mg/l
Chromium Nickel
<0.0333 <0.0333
MB Qualifier
MB MDL mg/l 0.0333 0.0333
QUALITY CONTROL SUMMARY
L1740531-02
MB RDL mg/l 0.100 0.100
Laboratory Control Sample (LCS)
(LCS) R4082998-2 06/17/24 18:57
Spike Amount
Analyte
mg/l
LCS Result mg/l
Chromium Nickel
10.0
10.5
10.0
10.8
LCS Rec. % 105 108
Rec. Limits % 80.0-120 80.0-120
LCS Qualifier
L1744518-04 Original Sample (OS) Matrix Spike (MS) Matrix Spike Duplicate (MSD)
(OS) L1744518-04 06/17/24 18:58 (MS) R4082998-4 06/17/24 19:02 (MSD) R4082998-5 06/17/24 19:03
Spike Amount Original Result MS Result
MSD Result MS Rec.
MSD Rec.
Analyte
mg/l
mg/l
mg/l
mg/l
%
%
Dilution
Chromium Nickel
10.0
<0.100
10.1
10.2
101
102
1
10.0
0.140
10.3
10.5
102
104
1
Rec. Limits % 75.0-125 75.0-125
MS Qualifier
MSD Qualifier RPD % 1.49 1.83
RPD Limits % 20 20
1 Cp 2Tc 3 Ss 4 Cn 5Sr 6Qc 7 Gl 8Al 9Sc
ACCOUNT: Miller Environmental Services, LLC
PROJECT:
SDG: L1740531
Appendix 6 Page 12 of 21
DATE/TIME: 0066//2266//2244 1121::4033
PAGE: 12 of 21
WG2305877
Semi Volatile Organic Compounds (GC/MS) by Method 8270C
QUALITY CONTROL SUMMARY
L1740531-02
Method Blank (MB)
(MB) R4082494-2 06/16/24 09:44
MB Result
Analyte
mg/l
Benzo(a)pyrene (S) 2-Fluorophenol (S) Phenol-d5 (S) Nitrobenzene-d5 (S) 2-Fluorobiphenyl (S) 2,4,6-Tribromophenol (S) p-Terphenyl-d14
<0.0333 31.4 26.2 57.2 54.1 47.8 59.2
MB Qualifier
MB MDL mg/l 0.0333
MB RDL mg/l 0.100 10.0-120 10.0-120 10.0-127 10.0-130 10.0-155 10.0-128
Laboratory Control Sample (LCS)
(LCS) R4082494-1 06/16/24 09:23
Spike Amount
Analyte
mg/l
LCS Result mg/l
Benzo(a)pyrene (S) 2-Fluorophenol (S) Phenol-d5 (S) Nitrobenzene-d5 (S) 2-Fluorobiphenyl (S) 2,4,6-Tribromophenol (S) p-Terphenyl-d14
0.500
0.365
LCS Rec. % 73.0 38.8 28.9 63.0 62.3 60.5 61.2
Rec. Limits % 47.0-120 10.0-120 10.0-120 10.0-127 10.0-130 10.0-155 10.0-128
LCS Qualifier
L1740531-02 Original Sample (OS) Matrix Spike (MS) Matrix Spike Duplicate (MSD)
(OS) L1740531-02 06/16/24 12:35 (MS) R4082494-3 06/16/24 12:57 (MSD) R4082494-4 06/16/24 13:18
Spike Amount Original Result MS Result
MSD Result MS Rec.
MSD Rec.
Analyte
mg/l
mg/l
mg/l
mg/l
%
%
Dilution
Benzo(a)pyrene
0.500
<0.100
0.310
0.329
62.0
65.8
1
(S) 2-Fluorophenol
39.8
37.2
(S) Phenol-d5
28.0
28.2
(S) Nitrobenzene-d5
61.1
61.6
(S) 2-Fluorobiphenyl
63.1
60.5
(S) 2,4,6-Tribromophenol
61.5
61.5
(S) p-Terphenyl-d14
56.0
58.6
Rec. Limits % 37.0-120 10.0-120 10.0-120 10.0-127 10.0-130 10.0-155 10.0-128
MS Qualifier
MSD Qualifier RPD % 5.95
RPD Limits % 24
1 Cp 2Tc 3 Ss 4 Cn 5Sr 6Qc 7 Gl 8Al 9Sc
ACCOUNT: Miller Environmental Services, LLC
PROJECT:
SDG: L1740531
Appendix 6 Page 13 of 21
DATE/TIME: 0066//2266//2244 1121::4033
PAGE: 13 of 21
WG2306936
Semi Volatile Organic Compounds (GC/MS) by Method 8270C
QUALITY CONTROL SUMMARY
L1740531-01
Method Blank (MB)
(MB) R4084588-3 06/20/24 13:46
MB Result
Analyte
mg/kg
Phenol (S) 2-Fluorophenol (S) Phenol-d5 (S) Nitrobenzene-d5 (S) 2-Fluorobiphenyl (S) 2,4,6-Tribromophenol (S) p-Terphenyl-d14
<0.0134 76.0 71.8 63.4 70.9 54.7 75.7
MB Qualifier
MB MDL mg/kg 0.0134
MB RDL mg/kg 0.333 12.0-120 10.0-120 10.0-122 15.0-120 10.0-127 10.0-120
Laboratory Control Sample (LCS) Laboratory Control Sample Duplicate (LCSD)
(LCS) R4084588-1 06/20/24 13:03 (LCSD) R4084588-2 06/20/24 13:25
Spike Amount LCS Result LCSD Result LCS Rec.
Analyte
mg/kg
mg/kg
mg/kg
%
LCSD Rec. %
Rec. Limits %
Phenol
0.666
0.449
0.450
67.4
67.6
28.0-120
(S) 2-Fluorophenol
71.3
72.7
12.0-120
(S) Phenol-d5
65.8
66.7
10.0-120
(S) Nitrobenzene-d5
49.2
50.8
10.0-122
(S) 2-Fluorobiphenyl
67.6
68.8
15.0-120
(S) 2,4,6-Tribromophenol
69.5
72.8
10.0-127
(S) p-Terphenyl-d14
68.5
71.8
10.0-120
LCS Qualifier
LCSD Qualifier
RPD % 0.222
RPD Limits % 27
L1744881-35 Original Sample (OS) Matrix Spike (MS) Matrix Spike Duplicate (MSD)
(OS) L1744881-35 06/20/24 18:25 (MS) R4084588-4 06/20/24 18:46 (MSD) R4084588-5 06/20/24 19:07
Spike Amount Original Result MS Result
MSD Result MS Rec.
MSD Rec.
Analyte
mg/kg
mg/kg
mg/kg
mg/kg
%
%
Dilution
Phenol
0.636
<0.0134
0.179
0.249
28.1
39.3
1
(S) 2-Fluorophenol
66.7
65.9
(S) Phenol-d5
23.0
36.6
(S) Nitrobenzene-d5
45.6
43.8
(S) 2-Fluorobiphenyl
61.3
58.4
(S) 2,4,6-Tribromophenol
73.0
69.9
(S) p-Terphenyl-d14
67.9
61.5
Rec. Limits % 12.0-120 12.0-120 10.0-120 10.0-122 15.0-120 10.0-127 10.0-120
MS Qualifier J
MSD Qualifier RPD
%
J
32.7
RPD Limits % 38
1 Cp 2Tc 3 Ss 4 Cn 5Sr 6Qc 7 Gl 8Al 9Sc
ACCOUNT: Miller Environmental Services, LLC
PROJECT:
SDG: L1740531
Appendix 6 Page 14 of 21
DATE/TIME: 0066//2266//2244 1121::4033
PAGE: 14 of 21
GLOSSARY OF TERMS
Guide to Reading and Understanding Your Laboratory Report
The information below is designed to better explain the various terms used in your report of analytical results from the Laboratory. This is not intended as a comprehensive explanation, and if you have additional questions please contact your project representative.
Results Disclaimer - Information that may be provided by the customer, and contained within this report, include Permit Limits, Project Name, Sample ID, Sample Matrix, Sample Preservation, Field Blanks, Field Spikes, Field Duplicates, On-Site Data, Sampling Collection Dates/Times, and Sampling Location. Results relate to the accuracy of this information provided, and as the samples are received.
Abbreviations and Definitions
MDL RDL Rec. RPD SDG (S) Analyte
Dilution
Limits Original Sample Qualifier
Result
Uncertainty (Radiochemistry) Case Narrative (Cn) Quality Control Summary (Qc) Sample Chain of Custody (Sc)
Sample Results (Sr) Sample Summary (Ss)
Method Detection Limit. Reported Detection Limit. Recovery. Relative Percent Difference. Sample Delivery Group. Surrogate (Surrogate Standard) - Analytes added to every blank, sample, Laboratory Control Sample/Duplicate and Matrix Spike/Duplicate; used to evaluate analytical efficiency by measuring recovery. Surrogates are not expected to be detected in all environmental media. The name of the particular compound or analysis performed. Some Analyses and Methods will have multiple analytes reported. If the sample matrix contains an interfering material, the sample preparation volume or weight values differ from the standard, or if concentrations of analytes in the sample are higher than the highest limit of concentration that the laboratory can accurately report, the sample may be diluted for analysis. If a value different than 1 is used in this field, the result reported has already been corrected for this factor. These are the target % recovery ranges or % difference value that the laboratory has historically determined as normal for the method and analyte being reported. Successful QC Sample analysis will target all analytes recovered or duplicated within these ranges. The non-spiked sample in the prep batch used to determine the Relative Percent Difference (RPD) from a quality control sample. The Original Sample may not be included within the reported SDG. This column provides a letter and/or number designation that corresponds to additional information concerning the result reported. If a Qualifier is present, a definition per Qualifier is provided within the Glossary and Definitions page and potentially a discussion of possible implications of the Qualifier in the Case Narrative if applicable. The actual analytical final result (corrected for any sample specific characteristics) reported for your sample. If there was no measurable result returned for a specific analyte, the result in this column may state "ND" (Not Detected) or "BDL" (Below Detectable Levels). The information in the results column should always be accompanied by either an MDL (Method Detection Limit) or RDL (Reporting Detection Limit) that defines the lowest value that the laboratory could detect or report for this analyte.
Confidence level of 2 sigma.
A brief discussion about the included sample results, including a discussion of any non-conformances to protocol observed either at sample receipt by the laboratory from the field or during the analytical process. If present, there will be a section in the Case Narrative to discuss the meaning of any data qualifiers used in the report. This section of the report includes the results of the laboratory quality control analyses required by procedure or analytical methods to assist in evaluating the validity of the results reported for your samples. These analyses are not being performed on your samples typically, but on laboratory generated material. This is the document created in the field when your samples were initially collected. This is used to verify the time and date of collection, the person collecting the samples, and the analyses that the laboratory is requested to perform. This chain of custody also documents all persons (excluding commercial shippers) that have had control or possession of the samples from the time of collection until delivery to the laboratory for analysis. This section of your report will provide the results of all testing performed on your samples. These results are provided by sample ID and are separated by the analyses performed on each sample. The header line of each analysis section for each sample will provide the name and method number for the analysis reported. This section of the Analytical Report defines the specific analyses performed for each sample ID, including the dates and times of preparation and/or analysis.
1 Cp 2Tc 3 Ss 4 Cn 5Sr 6Qc 7 Gl 8Al 9Sc
Qualifier
J J3 J7
Q
T8 V
Description
The identification of the analyte is acceptable; the reported value is an estimate. The associated batch QC was outside the established quality control range for precision. Surrogate recovery cannot be used for control limit evaluation due to dilution. Sample was prepared and/or analyzed past holding time as defined in the method. Concentrations should be considered minimum values. Sample(s) received past/too close to holding time expiration. The sample concentration is too high to evaluate accurate spike recoveries.
ACCOUNT: Miller Environmental Services, LLC
PROJECT:
SDG:
L1740531
Appendix 6 Page 15 of 21
DATE/TIME: 0066//2266//2244 1121::4033
PAGE: 15 of 21
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TN00003
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364
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E-10277
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TN00003
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n/a Accreditation not applicable
NE-OS-15-05 TN000032021-1 2975 TN002 TN00003 11742 Env375 DW21704 41 R-140 CL0069 9915 TN200002 68-02979 LAO00356 84004002 n/a 2006 T104704245-20-18 LAB0152 TN000032021-11 VT2006 110033 C847 233 998093910 A2LA 100789 1461.01 P330-15-00234
E10388 T104704232-23-39 8727
1 Cp 2Tc 3 Ss 4 Cn 5Sr 6Qc 7 Gl 8Al 9Sc
ACCOUNT: Miller Environmental Services, LLC
PROJECT:
SDG:
L1740531
Appendix 6 Page 16 of 21
DATE/TIME: 0066//2266//2244 1121::4033
PAGE: 16 of 21
Appendix 6 Page 17 of 21
Appendix 6 Page 18 of 21
Appendix 6 Page 19 of 21
Appendix 6 Page 20 of 21
Appendix 6 Page 21 of 21
APPENDIX 7. SECOND FOLLOW-UP EMAIL FROM MILLER AUGUST 12, 2024
Appendix 7 Page 1 of 3
Appendix 7 Page 2 of 3
Appendix 7 Page 3 of 3