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.
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:
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|Anna||Camp – Molina||45:27:00|
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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:
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:
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.
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:
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:
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:
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/
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 email@example.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.