logo25>
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.

Check out some event photos from the 2nd annual Victory Run 5K Fun Run & Walk!  Thank you to our participants, volunteers and sponsors for making this happen. We can’t wait to see you all next year for the Victory Run!

 Congratulations and Thank You!

Thank you to our participants, volunteers and sponsors for making this happen. We had a wonderful time!

We can’t wait to see you all next year for the Victory Run! Please see below for results from the men’s, women’s, boy’s and girl’s categories:

Men’s Category: 

First Name Last Name Time
Jason Reed 19:57:00
Pierce Moran 20:46
Scott Cameron 22:17
Gennady Stolyarov 22:37
Pat Vradenburg 23:48
Samuel Delaney 24:47:00
Tom St. Marie 24:59:00
Anthony Simonte 25:05:00
Andrew Sieracki 25:42:00
Mark Cameron 26:04:00
Mike Brown 26:30:00
Tom Porta 28:44:00
Garrett Louchart 28:46:00
Rick Reef 28:46:00
Aaron Squires 29:02:00
Ryan Peel 29:41:00
TC Calhoun 29:51:00
Jonathan Steel 30:38:00
Brian Coonradt 30:40:00
Roland Blais 31:01:00
Ryan Burns 34:15:00
Paul Magenheimer 34:31:00
Alex Messinger-Patton 36:43:00
Bryan Dagerman 36:49:00
Larry Smith 38:00:00
Dean Stanphill 39:29:00
Cam Crain 41:04:00
Eric Gangloff 44:51:00
Tavin Campbell 46:27:00
Nello Gonfiantini 48:22:00
Bradley Nichols 50:21:00
Justin Norton 50:21:00
Fradi Najjar 52:34:00
Louie Adame 1:01
Taylor Campbell 1:01
Deon Daswell 1:01
Chris Parsons 1:01
David Reyes 1:01
Jason Alsum 1:02
Ty Whitaker 1:05
Scott Elon

Women’s Category: 

First Name Last Name Time
Maggie Brandenburg 20:25
Jen Rains 23:56
Kala Squires 23:59
Melissa Chavez 25:54:00
Leah St. Marie 25:59:00
Tami Goulden 26:54:00
Karen Purcell 27:22:00
Makenzie Pomi 28:43:00
Jeannie Baker 28:58:00
Katie Calhoun 29:51:00
Mary Alsum 31:44:00
Leona Cameron 32:09:00
Crissey Cameron 32:10:00
Nikki Buhrmann 32:47:00
Vani Soqosoqo 33:07:00
Haley Magenheimer 34:30:00
Kristine Kinne 35:43:00
Jennifer Mingo 35:47:00
Courtney Smith 36:42:00
Linda Gray 37:05:00
Natalie Gray 37:06:00
Jennifer Crowe 37:40:00
Miranda Smith 37:59:00
Alisanne Steel 38:22:00
Blass Laura 41:05:00
Ellen Messinger-Patton 44:31:00
Dayna Giambastiani 45:25:00
Anna Camp – Molina 45:27:00
Sara Ross 46:11:00
Jennifer Adams 46:29:00
Corrine Casanova 46:30:00
Brynna Nichols 50:23:00
Ava Beaupre 50:57:00
Stéphany Apollon 51:32:00
Kim Aldrich 51:34:00
Eliza Gilsdorf 51:34:00
Stacey Gonfiantini 51:35:00
Teresa Chalmers 52:37:00
Trisha Beaupre 52:54:00
Mindi Dagerman 58:18:00
Karen Nichols 1:01
Amanda PeQueen 1:01
Claire Schauer 1:01
Diane Wood 1:01
Vanessa Alsum 1:02
Betty Hancock 1:03
Lois Johnson 1:03
Chariese Youshida 1:03
Rosemary Mann 1:05
Abbi Whitaker 1:05

Boy’s Category: 

First Name Last Name Time
Kole Steel 25:45:00
Hunter Steel 27:58:00
Jakobe Franklin 29:10:00
Cameron Dagerman 36:54:00
Alexander Mingo 41:57:00
Lincoln Smith 42:00:00
Geronimo Molina 45:13:00
Forrest Gangloff 45:15:00
Seth Chalmers 52:48:00
Henry Dagerman 58:16:00

Girl’s Category: 

First Name Last Name Time
Milana Gangloff 27:03:00
Addison Clark 27:55:00
Lauren Sherven 28:15:00
Scarlett Squires 29:28:00
Genoa Peel 29:43:00
Joey Rose DuVall-Hill 30:25:00
Mackenzie Mingo 33:43:00
Hayley Burns 34:12:00
Ellie Douglas 35:20:00
Sophie Najjar 37:55:00
Emerson Evans 39:41:00
Lily Crain 39:42:00
Tabitha Gilsdorf 39:54:00
Gysel Najjar 41:51:00
Olivia Cook 44:29:00
Amelia Giambastiani 45:02:00
Sophia Ross 46:08:00
Sofia Gonfiantini 48:17:00
Elise Beaupre 52:35:00
Eden Whitaker 1:05

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.

 

What is a preservative, and why is it important? According to the EPA, methods of preservation are relatively limited and are intended generally to (1) retard biological action, (2) retard hydrolysis of chemical compounds and complexes, (3) reduce volatility of constituents, and (4) reduce absorption effects.

In other words, the purpose of a preservative is to “freeze” the sample chemistry at the point of sampling so that what gets analyzed at the lab is as similar to the source as possible, despite the unavoidable delay between the sampling and analysis.

Some common preservatives include:

  • Sulfuric Acid (H2SO4)
    • Preservative for Nutrients: Total Nitrogen, Ammonia, Phosphorus, TKN, etc.
  • Nitric Acid (HNO3)
    • Preservative for Metals: Arsenic, Sodium, Lead, Copper, Iron, Mercury, etc.
  • Sodium Thiosulfate (Na2S2O3)
    • Preservative for Bacteria: Total Coliform, E. Coli, Fecal
  • Sodium Hydroxide (NaOH)
    • Preservative for Cyanide: Total CN, Free CN, WAD CN, etc.
  • Hydrochloric Acid (HCl) in VOA vials
    • Preservative for Volatile Organics: VOCs and Gasoline
  • Hydrochloric Acid (HCl) in Amber Glass
    • Preservative for Organics: Oil & Grease, Diesel, Oil, etc.

 

However, the most important, but often overlooked, preservative is ice. Keeping a sample cold (between 2-6C) is a requirement for nearly every analytical test we perform EXCEPT for metals analysis. It is generally preferable to use wet ice instead of ice packs when possible.

Sample containers, just like preservatives, are designed to inhibit the natural chemical changes which will occur in a sample as time passes. In addition to that, sample containers also serve a few other purposes:

  • To ensure proper volume is provided to a lab (all tests have a minimum required volume)
  • To ensure the lab has enough volume to perform the proper quality control
  • Some containers limit a samples exposure to UV rays
  • Some containers are designed to prevent sample contact with air
  • Some are sterilized and sealed to prevent bacteria contamination
  • Some containers are designed to limit sample absorption (plastic vs. glass)
  • Some are specifically designed to be loaded directly into an instrument (or even an autosampler for composite samples)

 

But how do I know which sample bottle and preservative to use? Simple, you ask the lab! By contacting WETLAB before you begin your sampling process, you will help ensure that you use the correct bottle and preservative. Our staff can also help you review your permit making sure the correct samples are taken at the correct time of the year (DPBs, LCR, SOCs), and making sure the correct methods are used for your sample matrix (drinking water, waste water, haz waste). We can even help with sampling requirements making sure your samples are collected as intended by your permit (LCR first draw, grab vs. composite), saving you valuable time that can be lost from unintended mistakes.

Be aware, preservatives and hold times are dictated by the analytical method and enforced by state/federal agencies and the laboratory. Cyanide species, Volatile Organics, Dissolved Oxygen, Bacteria, SOCs, DBPs, and many other tests absolutely require correct bottles and preservatives to analyze for compliance.

Contact WETLAB at (775)355-0202 to discuss your sampling needs. Our seasoned staff can help you determine which samples you need, how they need to be collected, and provide you with all the right bottles and preservatives to make sure your procedures remain in compliance.

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

Cyanide sampling requirements have become stricter over the years. The Nevada Division of Environmental Protection (NDEP) issued guidance in October of 2015 that cyanide analysis must be collected correctly in the field so as not to have samples rejected by the analytical laboratory, or by the state due to incorrect sampling procedures.

NDEP stated, “If you are analyzing Cyanide samples for compliance with a Nevada program, (SDWA, CWA, RCRA, Mining) samples must be collected as described below (ASTM D-7365-09).  Data obtained from samples not collected as described in ASTM D-7365-09 will be rejected.”

“ASTM D-7365-09 8.2.1 states that sample containers shall be made of materials that will not contaminate the sample, cleaned thoroughly to remove all extraneous surface contamination prior to use.  Chemically resistant glass containers as well as rigid plastic containers made of high density polyethylene (HDPE) are suitable.  Samples should be collected and stored in amber gas tight vials or narrow mouth bottles to minimize exposure to ultraviolet radiation and to minimize headspace in the sample containers (for example, amber open top VOA vials, amber Boston round bottles, or amber narrow-mouth HDPE bottles).”

“All certified Laboratories must reject samples not collected in suitable containers.”

What does this mean? All samples, regardless of matrix (drinking water, wastewater, ground water, surface water, aqueous, soil, sludge, etc.), must be collected in an amber narrow mouth container to minimize UV radiation exposure and to minimize headspace in sample containers.  Samples not collected in the correct containers must be rejected by the laboratory and the sample should be collected in the correct containers, as described above. Furthermore, as dictated by the method cited by NDEP, chemical preservation is also required for aqueous samples.  Aqueous samples must be preserved with sodium hydroxide (NaOH) to pH >10 at the time of collection, and then chilled on ice.

At WETLAB, we provide the appropriate bottles and preservative (NaOH) needed for your cyanide analysis, and are happy to answer any questions you may have regarding cyanide sampling containers.

Please call us at any at 775-355-0202 to request sample containers.

At WETLAB we try to give back to our community in a variety of ways, and we try to honor and participate in causes that are near and dear to our employees hearts.  The Northern Nevada Breastfeeding Coalition (NNBC) is front and center in some of our employees minds, because of their impact on the lives of infants and mothers. Below, one of our employees shares her experience with NNBC and their annual race/ fundraiser event, the Liquid Gold 5k.

The Northern Nevada Breastfeeding Coalition (NNBC) is a member of the Maternal Child Health Coalition of Northern Nevada, which is a non-profit organization that supports women and children.  The NNBC aims to normalize breastfeeding and increase community awareness about the benefits of breastfeeding.  We also offer resources to moms who need support or help when they want to breastfeed.

The Northern Nevada Breastfeeding Coalition (NNBC) held our 8th annual fundraiser, the Liquid Gold 5K Run/Walk on Saturday August 4th, 2018, and our 6th annual “Big Latch On!”  The Big Latch On is a worldwide event which pairs mothers and their children in breastfeeding together for one minute. These events served as our community’s kick-off to World Breastfeeding Week, and were intended to promote community awareness and gain support for normalizing breastfeeding in Northern Nevada.

The events took place on the campus of the University of Nevada, Reno and were enjoyed by families, friends, vendors, and volunteers!  Volunteers participated in a volunteer training the night before the race, marked the course, and helped create posters for the race.  The day of the event volunteers were responsible for set up and cleaning up, assisting at the registration table, race guides on the course, and collecting survey information.  It was thanks to the volunteers that helped make our event a success!

If you are interested in learning more about the NNBC, please visit our website (https://nnbc.wildapricot.org/), or join us the first Tuesday of every month from 12:00pm – 1:00pm at The Children’s Cabinet located at 1090 S. Rock Blvd, Reno, NV 89502.

You can also check us out on Facebook at https://www.facebook.com/nevadabreastfeeds.org/

WETLAB volunteers at the NNBC's Liquid Gold 5k.

WETLAB volunteers at the NNBC’s Liquid Gold 5k.

We are pleased to announce Kathleen (Kat) Langford has joined the Client Services team as an additional Project Manager at WETLAB.  Kat has worked as a Wet Chemistry and Geochemistry Laboratory Technician with WETLAB and a Laboratory and Logistic Coordinator at Desert Research Institute.

As a project manager, Kat will be another point of contact at WETLAB to help coordinate projects, provide quotes, send reports, prepare invoices, provide job status information, and assist with general questions.

Kat studied nutrition/ dietetics and public health at the University of Nevada, Reno.  She also has volunteered with the Veterans Guest House, assisting with special events and fundraising.

Please help us welcome her to the team.  She can be reached via email at katl@wetlaboratory.com.

WETLAB is pleased to announce a new certification.  We have expanded our testing abilities, and are now certified in Nevada to analyze Total Organic Carbon (TOC) by SM5310C.  Total Organic Carbon (TOC) is a measurement of organic or carbon-based contaminants in water that come from a variety of sources.  SM 5310C uses a UV-Persulfate TOC analyzer to measure total organic carbon in drinking water, surface water, ground water, and waste water.

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 TOC analysis can help you get the environmental testing results you need.