During a recent family dinner, I announced to my family that I was asked to write some blog posts for Environmental Standards, Inc. Having to first endure my 16 year old daughter’s laughter and her saying “I was way too old to blog,” and combined with my recent 50th birthday, I decided to take the task to heart and share some thoughts and experiences over my almost 28 year career in environmental quality assurance and 22 years with Environmental Standards.
Specifically, my upcoming posts will include topics on independent third-party data validation regarding such issues as pre-empting a notice of violation (NOV) due to improper biochemical oxygen demand (BOD) analysis; settlement of a case prior to trial proving that the contamination was not due to my client; determining why total suspended solid (TSS) results from a laboratory did not match well with in-house analyses; documentation that resulted in laboratory data being indefensible; sampling issues that resulted in inconsistent data; and improper calculation methods to name just a few. In addition, I will sprinkle in some field documentation and laboratory audit findings of note as well.
My goal is not to provide the nitty-gritty technical details in all cases, but rather to provide some general items for consideration and lessons learned with a bit of humor to keep you following along.
So on to the real content.
A long term oil and gas client has implemented many of Environmental Standards’ services to reduce sampling errors and improve documentation, laboratory oversight through auditing, and implementation of double-blind performance studies over a period of many years. One of the services that this client employs is a chemistry consulting help desk which is approved for use whenever an analytical or data issue reared its ugly head to answer questions and resolve issues quickly.
In this case, our client operates several wastewater treatment plants (WWTPs) and generally things go merrily along with results (assumed to be correct) below permit limits without a problem. However, late last month, a single weekly sample analyzed for BOD was far outside of the normal results for the plant operations and violated the National Pollutant Discharge Elimination System (NPDES) permit limit.
- Due to logistics and timing, additional samples could not be collected and the result started an entire process in motion of Agency reporting for a permit violation and plant investigation.
- This development caused two days of operator process review to try and understand the issue from an operations standpoint (i.e., looking at “bugs,” potential discharge variance, etc.) with no clear answers.
The client contacted me to perform independent third-party data validation on a single sample result with the hope that the critical data assessment would find the magic answer to the issue. I received the laboratory report, which contained only a cover page, the analytical results, and a quality control summary. Environmental Standards jumped into action on an emergency basis as follows:
- Upon receiving authorization to contact the laboratory, Environmental Standards requested the raw data for BOD consisting of sample sequence logsheets and extensive quality control information.
- Upon receipt of the raw data, it was noted that the BOD dilution water blank reading was 2 mg/L rather than the method required < 0.2 mg/L, leading to inaccurate (suspect) BOD quantitation of the associated batch sample.
- Apparently, internal laboratory data review prior to release of the data to our client did not note this major analytical deficiency.
- Upon verification of the Environmental Standards finding by the reporting laboratory, laboratory personnel were formally directed to rescind the analytical results and issue revised data on the client’s behalf, essentially invalidating their own BOD data.
- The effect of this step resulted in pre-empting the NOV from the client and a formal corrective action at the laboratory.
Simply following the steps below can help out when data do not make sense or to review data on a periodic basis:
- Don’t assume that the laboratory results are correct.
- Developing a plan to review data on a consistent basis, not just when the result “doesn’t make sense.”
- Include independent third-party data validation to ensure compliance and accuracy of results.
- Reacting only when a result is outside a permit limit can lead to long term issues that could have been preventable earlier in the process.