Wildfires affect water-test requirements


Issue Date: January 24, 2018
By Kevin Hecteman
Samuel Brown, a lab technician at Alpha Analytical Laboratories in Elk Grove, looks over filters containing solids from stormwater samples. Wineries and breweries in California must have such testing done to comply with stormwater runoff permits. A state regulatory agency has offered partial relief to wineries and breweries near the wildfires in Napa, Sonoma and Mendocino counties, where runoff from the fires could affect test results.
Photo/Kevin Hecteman
Filters containing solids from stormwater runoff tests rest in a desiccator, where they cool before being weighed, at Alpha Analytical Laboratories in Elk Grove.
Photo/Kevin Hecteman

In response to a request from agricultural and trade associations, state water officials have given partial regulatory relief to wineries and breweries in areas hit by Northern California wildfires. The action involves required stormwater sampling, which may be affected by ash and debris resulting from the fires.

Wineries and breweries are among the California businesses required to have stormwater samples tested during certain weather events. Ash and debris left behind by the October fires could show up in the samples and skew the results.

Adam Kotin, manager of environmental regulatory affairs for the Wine Institute, said a Statewide Industrial Storm Water General Permit applies to a number of industrial facilities. This testing must be carried out whenever a "qualifying storm event" occurs—defined as rainfall that produces a discharge in at least one drainage area and is preceded by at least 48 hours of dry weather.

"It captures wineries and breweries under it," Kotin said, noting that vineyards themselves don't report under this program.

"It's basically a way of tracking the quality of stormwater that runs off of industrial facilities," Kotin said. "Wineries and breweries are lumped into the same category as a bunch of other industrial facilities that are fairly dissimilar in a lot of ways."

Recognizing that wildfire debris could affect the results, the Wine Institute, California Farm Bureau Federation and the California Craft Brewers Association sent a letter to the State Water Resources Control Board, the North Coast Regional Water Quality Control Board and the San Francisco Bay Regional Water Quality Control Board in November, asking for regulatory relief.

Danny Merkley, CFBF director of water resources, said wineries and breweries would likely experience runoff from rain this winter that is "not representative" of their operation. The stormwater samples, he said, would likely contain constituents that result from "an act of God, the result of a fire they had no control over."

The three organizations asked the state and regional water boards to consider waiving the sampling requirement for this winter.

Instead, the State Water Resources Control Board issued a letter to industries in the wildfire areas late last month, saying it could not waive testing requirements, but offering an alternative.

"Dischargers may claim that their industrial stormwater runoff sampling is unrepresentative of their facility operations by documenting and reporting which stormwater samples are impacted by wildfire conditions (including post-wildfire conditions) and information that serves as the basis for the samples being unrepresentative of their facility's runoff from industrial activity areas," the water board said.

Such documentation, the board said, should include photos of discharge location conditions; areas in and around the facility affected by fires; and areas of high erosion and ash deposits. Wineries and breweries also should provide copies of their management practices for runoff and for wildfire impacts, and comparisons of pre-fire and post-fire testing results.

Merkley said the board action should offer "some relief" to affected facilities.

"Even though you still have to take the samples, you still have to have them analyzed, you still have to report the analysis, you can put a caveat in there that, 'This is not representative of our activities. This is as a result of the fires and subsequent rains after the fact,'" he said.

"I think that the option that was made available is reasonable," the Wine Institute's Kotin said, "and hope that it is helpful to those who are dedicated to complying with their permits and want to be as open and comprehensive as possible in how they track the quality of their stormwater."

Exactly how many wineries might be affected is unknown, he said.

"It's really hard to know how many might actually see spikes in their samples, because they will be based so much on the level of ash that fell, on which surfaces, and how the stormwater flows, and whether or not local vegetation was burned to the degree that there's increased debris," Kotin said.

Ukiah-based Alpha Analytical Laboratories is among the labs that tests stormwater runoff samples. Adam Angulo, who works at Alpha's Elk Grove lab, said the industrial permit requires testing for oil and grease; total suspended solids, which would include dust and other light solids; and pH levels, which measure the acid or alkaline levels of a solution.

Under the regulation, dischargers must test two samples between July 1 and Dec. 31, and two more between Jan. 1 and June 30, with the samples being taken while the plant is in operation, he added.

Although the normal turnaround time is 10 business days, samples exceeding a certain threshold for constituents are brought to a project manager's attention immediately, Angulo said, so affected clients can be notified and can take action as needed.

(Kevin Hecteman is an assistant editor of Ag Alert. He may be contacted at khecteman@cfbf.com.)

Permission for use is granted, however, credit must be made to the California Farm Bureau Federation when reprinting this item.