Curtis & Tompkins is a full service environmental analytical testing laboratory. C&T has been in business since 1878. For the last twenty years, our strategic focus has been environmental (EPA) analysis. C&T performs analysis at various Industrial and Federal sites across the country. Our Berkeley California location employs more than sixty professionals; dedicated to delivering superior data quality, on time, at a competitive price.

EXPERIENCE

Over the last twenty years, Curtis & Tompkins has worked on the full spectrum of environmental analysis. Examples of typical projects and analysis of:

• Investigations of Underground Storage Tank Sites, Soil Sampling for Lead, Landfill Site Investigations, Dump Site Characterizations, and Quick Turn Hydrocarbon Soil Excavations; for Base Closure Projects in California

• Preliminary Assessments, Site Investigations, Remedial Investigations, Feasibility Sudies, and Remedial Designs

• Soil Treatability Studies

• Pre-Excavation delineation of soil samples, Post Excavation confirmation soil samples, and Waste Samples for Characterization

• Site Characterization Remediation Projects

• Ground Water Monitoring Programs

• Site Investigations at Various Landfills and Quick Turn Hydrocarbon Soil Excavations Projects

• Quarterly Groundwater Monitoring Analysis

• Wastewater Analysis Projects

• Storm Water Analysis

• Natural Attenuation Parameters Analysis

• TCLP Extraction Projects

• STLC (WET) Extractions

• Wet Chemistry Parameters

• PCB-Contaminated Soil and Waste Disposal Projects

• Low Level Metals Projects

• RCRA & Priority Pollutant Metals Projects

Curtis & Tompkins has many years of experience delivering data for validation purposes. Typical sites have project-specific Quality Assurance Project Plans (QAPP) that include project specific reporting limits and QC limits with hard-copy reports delivered in EPA Level III and Level IV formats. Complicated electronic diskette deliverables, such as ERPIMS, IGIS, EQWIN, SEDD, Superfund, CA UST EDF Format; can become necessary as well.

HISTORY OF C&T

Founded 130 years ago in San Francisco by James M. Curtis, C&T is the oldest continually operating test and measurements laboratory in the United States. We have a long, varied, and distinguished history. A pioneer San Francisco business, J.M. Curtis & Son served the wine industry providing analyses for sugars, acidity, alcohol and solids in wines primarily for export to Europe, as the California wineries in these days were producing more than 30 barrels of wine a year for each inhabitant of the state. Phillip W. Tompkins joined the firm after receiving a chemistry degree from UC Berkeley in 1905 adding ores, minerals, fats, and oils analyses services to the scope. The great San Francisco earthquake and fire was a turning point for the business. P.W. Tompkins negotiated his full partnership in the firm by arriving at the lab on the morning of April 6, 1906 to salvage equipment and glassware before the entire block of California Street containing the lab was dynamited in an effort to control the fire.

P.W. Tompkins was president of Curtis and Tompkins Ltd. from 1910 through 1953, and worked at the firm until his death in 1968. Tompkins was a skilled technologist and adroit businessman. Under his leadership, the firm grew to approximately 45 people by 1926 providing foods, feeds, mineral, petroleum, fats and oils analyses for California's agricultural and mining industries with satellite offices and labs serving the mining industry in Reno, NV, and the fishing products industry on Cannery Row in Monterey, CA. C&T appeared in several pictorial articles in the trade press during the 1920's and 1930's touting it's new custom built laboratory and offices at 236 Front Street, which are still standing and are now used as law offices.

Tompkins passed the ownership of the firm to an employee group headed by Hugo deBusseries in 1953. By then, C&T was developing and standardizing methods for vitamin analyses and performing clinical analyses to assist in medical diagnoses, in addition to the mining and agricultural analyses. During this period C&T played a lead role in the development of a chick bone growth bioassay test method for Vitamin b12. Between 1953 and 1976, market forces and a failure of management succession planning lead to consolidate service offerings and downsize the enterprise. Clinical, mining, and petroleum analysis services were discarded to a core offering in Foods, Feeds, Agricultural, Fats, and Oils analyses from a downsized laboratory in an old cannery at 290 Division Street in San Francisco.

Present ownership of C&T appeared in 1976 and began a program of diversifying and expanding service offerings, updating facilities and equipment. Water, wastewater, and environmental analyses were offered along with the services in agriculture commodities and food testing. C&T started a lab in Wilmington, CA in 1982, and acquired a laboratory in Los Angeles in 1983 while expanding aggressively into the exploding market for environmental test and measurement services. In 1988, C&T acquired and moved to its present facilities at 2323 5th street in Berkeley. By 1991, C&T was offering agricultural, bacteriological, food, feed, petroleum, water and wastewater, bulk cargo inspection and consulting services from three labs with a staff approaching 100.

The period between 1993 and 1997 involved consolidation and downsizing for C&T and many other labs in California. Across the country, three of every four labs in environmental testing and measurements in business in 1993 were either closed or consolidated into other enterprises by 1998. During this period, C&T closed its two labs in the Los Angeles region, exited the food, bacteriology, petroleum, and agricultural services sectors to concentrate on it's core competency in environmental testing and data management from one laboratory in Berkeley. Since 1997, after shutting its Irvine CA laboratory, C&T has thrived and grown revenues and income on average 12% each year.

In 2008, we celebrate our 130th year of continuous operation as a premier firm in the test and measurements industry. Some of our staff have been with us for as long as 40 years, allowing us to retain a depth of knowledge of classical testing methods from our colleagues who worked here long before us. We're very proud of our history and integrity and enjoy sharing it with you. Come by the lab at Berkeley and ask to see some of the old pictures and lab record books. The old correspondence and antique equipment is particularly interesting. We can't show you anything before the earthquake and fire of 1906, but that leaves us a lot more history than our competitors!

SCOPE & PURPOSE OF C&T's QA PROGRAM

Curtis and Tompkins, Ltd. (C&T) provides a broad range of analytical testing services to industry, public utilities, engineering firms, Department of Defense contractors, and other private and public sector clients. Approved technical and procedural standards are a corner stone of our approach. C&T relies on, and requires, the participation of all employees in the quality program to meet our goal of providing clients with technically and legally defensible data.

At C&T, quality is defined as adherence to specifications. In the world of analytical chemistry, the QA Program is aimed specifically at procedures for control of common errors such as false negatives, false positives and misquantitations. Implementation of the QAP ensures appropriate, accurate and complete documentation of all events related to the measurement process including adherence to specifications for accuracy, precision, and completeness of the measurement data.

C&T has a policy of establishing quality specifications that encompass limits and acceptance criteria for calibration events, accuracy (spikes), precision (duplicates), and control samples for false positives (blanks) for every measurement procedure employed. These specifications are contained in the standard operating procedures (SOP's) for each specific testing method.

METHODS AND PROCEDURES

Analytical methods employed at C&T are generally those EPA methods specified in the Code of Federal Regulations (CFR) including those found in Test Methods for Evaluating Solid Waste (SW 846), Standard Methods for the Examination of Water and Wastewater (SMWW), and Methods for Chemical Analysis of Water and Wastes (EPA 600/4-79-020). Industrial methods, such as ASTM, are be used on a limited basis to analyze for specific compounds or parameters for which no EPA methods exist. Methods used for air samples include EPA, NIOSH, or other methods as applicable. The laboratory Quality Assurance Director maintains documentation of the laboratory's method capabilities.

Adherence to Accepted Methods

C&T's policy is to adhere strictly to the letter and spirit of compendial methods published by regulatory agencies (USEPA SW-846), industry organizations (WPCF-SMWW), and standards organizations (ASTM or AOAC). Strict adherence to performance parameters specified in published, recognized, and accepted methods ensures that our clients receive a defined and recognized product, which will be legally and technically defensible.

Method Selection

C&T performs measurement services according to the methods requested by our clients. If the method(s) requested by the client is inappropriate, technically unsound, or if a substitute method will provide superior results, useability or service, C&T will recommend substitution. Project managers are most frequently involved in method selection processes, however the Operations Manager and QA Director are also involved in and responsible for this process. C&T endeavors to recommend methods that provide the accuracy, precision, and regulatory defensibility required for the intended use of the data.

DATA QUALITY CONTROL AND ASSESSMENT

Quality assurance as practiced at C&T consists of quality control and data assessment procedures that are adapted to the specific procedures employed within the laboratory. The use of a general framework adapted to specific activities facilitates training and consistent data generation throughout the laboratory. Routine internal quality systems and data audits are employed to monitor the entire quality program.

Quality Control Procedures

C&T policy for quality control consists of a tri level assessment system, each level with its own set of quality control measurements. The three levels are the instrument, the analytical batch, and sample specific quality assessment. In some cases, only one or two of the levels apply, but this concept is widely applicable in the laboratory.

1.

Instrument Calibration:

The working range of each instrument is defined by generation of a calibration curve encompassing a standard at the reporting limit, a series of intermediate standards, and a stanard that defines the upper end of the quantitation range. A standard purchased from a second manufacturer is then analyzed to verify the acceptability of the calibration curve. Additional calibration verification standards are analyzed periodically throughout the analysis to ensure that the instrument response has not changed and that the calibration curve is still applicable. Additional instrument check standards are employed on a method-specific basis (ie: pesticide breakdown standards), as described by the referenced methods.

2.

Batch QC:

A "batch" of samples is defined as 20 or fewer samples of the same matrix type that are prepared using the same reagents, standards and procedures within the same time frame. Each batch includes a set of specific QC samples which are used to assess the performance of the entire measurement process (sample preparation, analysis and data reduction). Batch QC samples generally include method blanks, laboratory control samples, and matrix spikes/ duplicates, which are used to assess accuracy (recovery), precision/ reproducibility (RPD), and a check for laboratory contamination. Requirements for specific types of QC samples, their frequency, evaluation criteria, acceptance limits and corrective action criteria are specified in the method procedures (SOP), and in QAPP's submitted by clients.

3.

Sample QC:

In many analyses, primarily those written for organic compounds, there are methods of determining the performance on particular samples. Surrogate compounds, non target analyte which behave like target compounds, are added to each sample and QC sample prior to extraction or sample preparation, and assist with determining the accuracy of the analysis on a particular sample. Specific applications of these techniques are method-dependent and are described in detail in the method SOPs.

Quality Control Acceptance Limits

Quality control limits and acceptance criteria have been established throughout the laboratory for calibration, accuracy, precision and completeness. Data are reviewed for compliance to these criteria. Often, because there are multiple uses for the data, several QC limits may apply for the same methods within a lab. C&T's data quality assessment criteria are based on accuracy & precision measurements generated by the laboratory, or specified in reference publications (ie US-EPA SW846), or specified in contracts the laboratory executes with its clients. Overall C&T's primary objective is to satisfy its clients needs and contractual requirements for data of known quality based on adherence to specifications for accuracy, precision, and completeness.

Specific procedures for establishing control limits are detailed in the QA SOP for generating control limits. Data acceptability is assessed according to the following hierarchy:

1.	Client specified project limits,
2.	Internal laboratory limits, and finally,
3.	Method prescribed limits.

It is C&T policy to rely on statistically generated QC limits unless contractually required to evaluate data on the basis of a project-specific work plan. Contractually specified criteria are identified and documented by the Laboratory Project Managers; these requirements are then transferred to the analytical departments as described in the Client Services SOPs. Project Managers then review completed reports against the contract requirements.

Method Detection Limit (MDL) Studies & Method Validation

MDL studies are performed annually for each instrument and analysis, or whenever significant changes in procedures for sample preparation, cleanup or instrumental analysis are implemented. C&T has established a comprehensive procedure (QA SOP's MDL Procedure) for performing & documenting MDLs including all data reduction algorithms and documentation requirements.

The implementation of a new analytical method requires a Method Detection Limit (MDL) study, valid initial and continuing calibration, and the compliant analysis of four laboratory control standards (LCS) and at least one PE sample from an outside source.

Performance Evaluation Samples

C&T participates in WS (Water Supply), WP (Water Pollution), and UST/HW (Underground Storage Tank and Hazardous Waste) studies. Performance evaluation samples are obtained from certified sources (EPA or other third party) and analyzed by C&T using the same sample preparation and analysis procedures, reagents, and standards as used for environmental samples submitted by our clients. The results are reported back to the agency or supplier who then evaluates the results against the known or true values and provides C&T with a performance report. These reports are used to determine corrective action and method development priorities and to demonstrate comparability of the data produced by C&T with that generated by other laboratories analyzing the samples. Many clients also send performance evaluation samples to the laboratory as part of project quality requirements.

Audits

The QA Director annually conducts internal Quality Systems Audits, to evaluate the effectiveness and implementation of quality control systems, and Data Quality Audits, to assess the quality and integrity of data archived by the laboratory. Procedures for performing these audits include group-specific checklists and appear in the QA SOP's.

External audits are performed by State agencies, third party accreditors, clients and their contractors. C&T is dedicated to providing information to clients regarding procedures and QA practices.