Western Environmental
Testing Laboratory
Regulatory Requirements during COVID-19 Global Pandemic

During this unprecedented time of global uncertainty, nearly all normalcy has been lost.  Essential operations are still required to ensure our communities are adequately supplied with safe drinking water, effectively treated wastewater, and properly disposed solid waste. Manufacturing is required to make necessary items, demanding all levels of supply chain, from mining to delivery, remain open.  These operations must continue to function in order to keep our society safe and open, but what about the regulatory requirements that surround these industries?

Water utilities, wastewater treatment plants, solid waste disposals, and mining operations are surrounded by a wide network of regulatory requirements from federal, state, and local levels.  Due to COVID-19, many of these industries are facing extremely difficult operating conditions, made difficult due to staffing requirements, increased demand, public concern, and personnel safety. The Environmental Protection Agency (EPA) released a memo on March 26, 2020, outlining updated expectations for EPA regulated entities to help address some of these difficulties.

The memo includes language that identifies public drinking water systems as having a greater responsibility to maintain compliance and protect public health.  This means that water systems must continue to monitor regulated contaminants and quality parameters, and maintain compliance.  Certified operators may have continuing certification requirements delayed due to COVID-19.

For other regulated entities that are unable to meet standard regulatory requirements that would generally result in enforcement actions, the EPA will apply enforcement discretion.  This enforcement discretion will only be applied to requirements missed as a direct result of COVID-19.

In order to ask for enforcement discretion, entities that are non-complaint must take steps to minimize any effects.  They must then identify and document the dates of non-compliance, show how COVID-19 was a contributing factor, what response actions were taken after, and how compliance was reinstated.  This documentation will be required for any potential enforcement discretion, and must be provided to the appropriate regulatory agency.

Regulated operations must make all efforts to maintain compliance, and the EPA will continue with any ongoing enforcement actions.  This enforcement discretion does not apply to any operators under Superfund or RCRA Corrective Action regulations.

Standard compliance activities should be carried out to the best of your ability, which is why WETLAB is still here for your industry. WETLAB has taken steps to ensure the safety of our staff and yours, including using virtual meetings, contactless sample drop-off and bottle delivery, and digital reporting.  Contact WETLAB at (775)355-0202 to find out how we can help ensure regulatory compliance and safety in this time of uncertainty.

Sample Collection is the first, and perhaps the most important step in the analytical process. Poor sampling inhibits the labs ability to produce representative data of a sampling source. Sampling is comprised of 5 main steps:
1. Create a Field Sampling Plan
2. Contact lab to order bottle kit and discuss any scheduling complications
3. Conduct sampling following instructions from Field Sampling Plan and the lab
4. Release Custody of Samples to the lab, or a third party shipper
5. Review Sample Receipt to ensure correct analyses are ordered

What do each of these steps mean? Let’s take a closer look.

1. Field Sampling Plan- This is necessary to succeed in sampling, and generally should include the following:

  • General Facility Info or Sampling Locations
  • Contact Person and Samplers Name
  • Sampling Objectives
  • Facility of Location Information (PWS codes for drinking water)
  • Data Quality objectives
  • Sampling Points
  • Sample Collection Procedure
  • Sample Handling Procedure
  • Equipment Checklist
  • Equipment Preparation and Cleaning Procedures

 

2. Ordering Bottles and Scheduling Sampling- Call us to order your sample containers. The bottles provided will be bagged together into “sets” to keep each site organized. A cooler will also be provided. The lab will generally need the following information:

  • What are you sampling for?
  • How many sites do you intend to sample?
  • When are samples being collected and when will they be delivered to the lab?
  • Are any additional sampling supplies required (COCs, gloves, extra coolers, ice packs, custody seals, Ziploc bags, etc.)?

Depending on the situation, more coordinating and information may be required! For example:

Courier Pick Up or Drop Off– If you need sample containers dropped off at your site or picked up from a courier, it is wise to plan sampling around your labs standard courier routes. You can find WETLAB’s standard courier schedule here.

Sample Shipping– If samples are being shipped to or from a remote location, consider the amount of time samples will be in transit. If you are sending short-hold samples, selecting a “next day delivery” option may be necessary.

Subcontracted Work– Most subcontracting is shipped to southern CA and NV, therefore, factor this extra time in transit when making your sample plan. Furthermore, avoid delivering samples requiring subcontracting on Fridays, as they cannot ship out until the following Monday.

Weekend Work– Weekend work is not ideal, however, it is sometimes unavoidable! It is important, however, to notify your lab as soon as possible about weekend work so that staff can be scheduled to accommodate the request.

 

3. Sampling- Once the game plan is set, it is time to execute your sampling project.

  • Follow the steps outlined in your Sampling Plan and make sure to follow any special instructions provided by your lab.
  • Take note of the weather conditions, high and low temperatures can drastically affect how you pack and transport your samples.
  • Wear PPE! Gloves, glasses, masks, hairnets… they all serve a purpose to keep you safe and/or your samples clean.
  • Make sure to add the proper preservatives to your samples in the field, add custody seals to bottles or coolers if your sample plan requires them, and make sure to use bubble packaging for glass containers.

 

4. Releasing Custody of Samples- An additional responsibility of a sampler is properly documenting sample information and signing for any change of sample custody. The analytical Chain of Custody (or COC) is a required legal document submitted with samples to the laboratory. This document is a requirement for any sample submission to a lab, and serves numerous purposes:

  • Client and Reporting information
  • Turnaround time, compliance needs for reporting, report format, and QC requirements
  • Sample ID, Date/Time, Preservatives, Matrix, Number of Containers, and required tests
  • Miscellaneous comments, including hazard warnings, reporting requests, sample return requests, preservative notes, etc.
  • Relinquishing custody of the samples

 

5. Review Sample Receipt- WETLAB can send you an electronic “ sample receipt” which will list the entered information from your Chain of Custody, the receiving conditions of your samples (including anomalies), and an itemized list of all the analytical testing slated for your samples.
This is the final check before the testing will commence, so it’s important to review as soon as possible and contact the lab with any questions or concerns.

Contact WETLAB at (775)355-0202 to discuss your sampling requirements and project needs.

What is a holding time, and why do I need to know about it? A “holding time” is the elapsed amount of time from the point of collection to the moment of preparation or analysis. Note that this is not the date/time of receipt at the lab! If samples are analyzed beyond an analytical holding time, the data will be qualified on the analytical report and may not be usable for compliance.

The analytical hold time to a sample is like an expiration date to a carton of milk; past the hold time, analysis technically can still be performed (just as milk may be consumed after it expires), the results, however, in both cases may be unsavory. There are very few allowances for missed hold times and in almost every case, resampling is required.

You should get samples to the lab as quickly as possible, as holding times are different for volume received unpreserved. For example, metals shrink from 6 months to 7 days, nutrients from 28 days to 48 hours, others hold times may even shrink to 24 hours or less! Find out more about preservatives and sample bottles here.

Holding times are easily accessible, as the information is constantly needed (and important!):
From WETLAB’s website here
From the EPA under 40CFR, part 136, Table II
From the NDEP website here
Or, get a hard copy sheet on your next stop into WETLAB

Be aware, hold times can change as methods are updated, so you should contact WETLAB for the most up to date information before you develop your sampling plan.

 

Organic compounds are present in both indoor and outdoor environments, as they are necessary ingredients of products and materials we use every day.  Semi Volatile Organic Compounds (SVOC) are a subgroup of Volatile Organic Compounds (VOC) that have a higher molecular weight and boiling point (240-260 C to 380-400 C) and are present in everyday items like pesticides and fire retardants.

SVOCs are analyzed by sample extraction and the extract is analyzed by Gas Chromatography/ Mass Spectrometry (GC/MS).  The reported analytics can be separated into three groups (acids, bases, and neutrals) and are sometimes referred to as Base/Neutrals and Acids. WETLAB is currently in method development to perform the analysis of municipal and industrial wastewater by EPA 265 and solid waste, soils, and waste samples by EPA 8270.

At WETLAB, we are constantly trying new ideas, methods, and analyses to better serve our clients.  Contact us at (775) 355-0202 to find out how our new, in-house SVOC analysis can help you get the environmental testing results you need.

At WETLAB, we believe that good communication is a critical part of ensuring our clients receive good data.  Our QA manager and sales team presented on this topic in March at the Nevada Rural Water Association Conference in Reno, NV. Below is a small synopsis of this presentation. 

Good communication appears to be a simple goal, but can be difficult to achieve.  There are many players involved at every stage, and one small miscommunication can result in the end product not being what is needed.  The —ultimate goal is to produce legally defensible results that meet Data Quality objectives.

The many moving parts of good communication.

The many moving parts of good communication.

It is imperative that clients and the lab communicate clearly- WETLAB strives to ensure that all of our clients understand what data they need to satisfy regulatory requirements. The regulatory landscape concerning water is ever-changing, and can be confusing.  At WETLAB, we stay up to date with the latest changes so that we can help our clients get the results they need.  Outside of the lab, we talk to our clients and their regulators to determine needs.  Inside of the lab, we discuss projects clearly throughout all departments.

Clear communication has many moving pieces inside the lab.

Clear communication has many moving pieces inside the lab.

The critical point of communication occurs between the client and the lab.  Providing WETLAB with the appropriate documents helps to clearly show objectives. These documents include: a detailed Client Information Sheet, a Sampling Analysis Plan, the Scope of Work, and the Chain of Custody.  Having an accurate and clear Chain of Custody is imperative to retain legal defensibility of sample results.  Our staff reviews all Chain of Custody forms to make sure they are clear and fully completed.

If all participants communicate as clearly as possible, the goal of regulatory compliance can be achieved.  Contact WETLAB to see how we can help you achieve your goals.

In our blog posts Lessons From the Lab we answer frequently asked questions from clients.  Find all installments of Lessons From the Lab here

What is a Reporting Limit?

A Reporting Limit (RL) is defined as the smallest concentration of a chemical that can be reported by a laboratory. If a laboratory is unable to detect a chemical in a sample, it does not necessarily mean that the chemical is absent from the sample altogether. It could be that the chemical concentration in the sample is below the sensitivity of the testing instrument. Concentrations below the RL are reported as not detectable at the RL or “less than” the RL. The RL value is often defined be each specific laboratory, so it is not uncommon to come across different RL’s when testing the same compound. RL’s act as safety protocols that allow laboratories to efficiently communicate the different variables correlated with testing and analyzing samples from a wide variety of sources and factors. It is important to identify the limit of concern that the client has when testing their sample to ensure that the RL is less than the regulatory limit. That enables a laboratory to identify whether a concentration of the chemical in question is above the regulatory limit of concern.

This is the final installment of our ongoing series Life of a Sample, which explores what happens behind the scenes at WETLAB.  If you missed parts one through five, check them out here!

Our sample has now been received, prepped, distilled/ digested, analyzed, and entered.  The final, and terminal step, is reporting.  At this point, samples will have been validated, which means that QA/QC parameters have been checked to ensure they are within acceptable ranges.  These parameters include checking total versus dissolved solids, Maximum Contaminant Levels (MCLs) for drinking water, cation versus anion balances, and several others.  If any of these validation measures are outside of acceptable or expected limits, QA staff will determine if the sample needs to be re-analyzed.  If the sample passes the validation check, the data is ready to be reported to the client and regulating agency. Our client services staff ensures that clients are provided with a complete and accurate report of all results, and they understand what they have been provided with.  If the sample is being analyzed for compliance, such as drinking water for a public water system, the results are also provided to the regulating agency.  After reporting is finished, our sample’s life cycle is complete!

One of the ways WETLAB strives to better serve our clients is to understand what they do at every level.  We believe that by knowing what our clients do, we can help them reach their goals.  Hollie Timmons, Client Services Manager, and Michelle Sherven, WETLAB President visited long-time client Lyon County Utilities to better understand what they do, and what role WETLAB can play in their success.  To learn more about Lyon County Utilities, watch their client testimonial here.  Below, Hollie tells us about the visit.

On Cinco De Mayo, Michelle and I went to Lyon County Utilities to tour the wastewater treatment plant and one of their drinking water well houses. It was very interesting to see the whole process from start to finish! We started at the entry point where all the wastewater enters the plant and got to see the headworks building, where augers keep the pipes from getting clogged with hair and paper (among other things). This was the most disgusting part seeing all the hair wound up in a mass, which we were told gets all “roped-up” every so often and jams the augers, so someone has to get in there and remove all the sewage-soaked hair, which made me really appreciate my desk job! This building also had the strongest odor, which was a humid combination of raw sewage and a burning, overwhelming ammonia scent that was enough to make your eyes water! After that, we got to see the grit separator and their huge jet-engine aerators that pump air to all the tanks, where a combination of certain bacteria/microbes are added to the mixture. These bacteria do their job to break down the organic matter, and the solids settle to the bottom of the tanks to further decompose. Once this process is complete, the water is decanted/skimmed from the top and passes through a winding series of channels where the water is chlorinated for disinfection. This treated water then goes into a covered pond (to control algae growth) where it slowly seeps into the ground and is eventually returned to the ground water, completing the full circle of sewage life. The sludge (essentially the dead bacteria/microbes, killed off by the chlorination) is transferred to a drying bed, which some treatment plants then sell to farms for use as fertilizer. This treatment plant requires so much power to run, that they have the largest 12-cylinder generator I have ever seen, to ensure the plant operations do not come to a halt in the event of a power outage. After the tour was finished, we had lunch and then drove to one of their drinking water wells that takes in surface water from a nearby river/stream. The water is pumped through the well house, chlorinated, and piped to the nearby homes. While we were in the pump house, we experienced a sudden torrential hail-storm, which stranded us inside. We watched the marble-sized hail shred the leaves off nearby trees and pelt the building with a thunderous roar, falling like frozen bullets from the sky. It made for the perfect ending to a very fun day!!
Michelle and Hollie with our great clients from Lyon County Utilities

Michelle and Hollie with our great clients from Lyon County Utilities

 

Hollie is always striving to serve our clients better

Hollie is always striving to serve our clients better

Bruce Metals, Inc. has been a WETLAB client since mid-2012.  BMI is an interesting client because of their project and the way that we process their samples.  Many clients have fairly standard tests, especially those that are dictated by the state in permits.  Bruce Metals is different; WETLAB worked with them to develop tests that meet their unique matrices and concentrations.  Due to the uniqueness of working with Bruce Metals, we decided to highlight them in a client testimonial.

BMI works with several mining clients to draw metals in parts-per-billion ranges from leaching solutions.  This specialized process requires specialized testing, which is where WETLAB comes in.  We have worked with BMI to make testing procedures and data that meets their needs, ensuring a long and prosperous relationship.

If you missed our client testimonial with Andy Roberts of Bruce Metals, Inc., check it out here.

Broadbent – a full-service environmental, civil engineering, and water resources consulting firm – is experiencing fantastic growth in their air quality, cultural resource management, and water/wastewater service areas thanks in part to the support and resources of their testing partner WETLAB.

According to Randy Miller, Principal Engineer at Broadbent, “WETLAB provides competent and cost effective testing services. Their staff is knowledgeable and customer oriented. They understand our needs and the needs of our clients.”

Broadbent and Associates post-fire sceening

Broadbent and Associates post-fire screening

Recently, the company successfully collaborated with a range of stakeholders on Superfund projects in Arizona, California, and Broadbent’s home state of Nevada. One effort was EPA’s Superfund Technical Assessment and Response Team (START) contract. This took place during Gold King Mine spill response efforts in Arizona and the 4-Corners Region with Broadbent assisting the US EPA and the Navajo Nation EPA to assess the extent and effects of the spill’s plume on the San Juan River.

A similar emergency response event Broadbent supported was EPA’s recent disaster relief effort in Middletown, California. This work was in reaction to the Valley Fire that consumed much of the town and surrounding Lake County communities. The work required expedient response, complex project planning, and thorough risk assessment by staff from multiple Broadbent offices.

Broadbent is proud to address customer needs in a safe, reliable, and efficient manner by leveraging their strong business partnerships, like the one they have with WETLAB. Whether undertakings are part of upfront planning, operations, or are emergency based, Broadbent professionals are ready to bring their expertise to the field.

Broadbent

Broadbent & Associates, Inc. is a Nevada-based, full-service environmental, civil engineering, and water resources consulting firm founded in 1987. The company is tested and trusted by their client base and regulatory agencies and has forged strong relationships with agency personnel, industry leaders, and innovative partners throughout the Western US. Broadbent’s professionals know what is required to complete projects and approach work in a safe, thoughtful, and informed manner.

Broadbent specializes in a range of professional environmental services, including: Air Quality Permitting and Stack Testing, Cultural Resource Management, Environmental Sampling, Assessment, and Remediation, Emergency Response, Water and Wastewater Facility Operations, Civil Design and Construction Quality Assurance, Water Resources, and Health and Safety Services.