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Ernie Schenone,Jr. August 19,2003 Schenone Specialty Foods,Inc. Page 7 i. Can you please explain in detail how future changes in legislative or local oversight can impact a business on a yearly permit as apposed to a business on a one-time permit? The"one-time"permit you refer to is the construction permit for the Alternative/Engineered Septic System for your facility_ The"yearly"permit pays for the cost of reviewing monitoring data and performing routine inspections of your disposal system to ensure that it is functioning properly and in compliance with parameters established by the CVRWQCB. Recent legislation(AB 885)has been passed that may change how on-site wastewater disposal systems are designed and constructed. At the current time,regulations to implement this law are still in the draft stage and will probably not be approved before tnid-2004. The effect of these regulations on your operation is unknown at this time,but projects in compliance with CVRWQCB discharge requirements should meet the new standard. ii. What is the regulatory basis for categorizing this system as a yearly permit? In June of 2001,the EHD Fee Schedule was modified to include the category of Alternative/Engineered Septic System to address the complex review necessary for.. wastewater disposal systems designed on a site-specific basis with regard to soil characteristics, groundwater quality and proposed discharge. A construction permit fee. - established which covers the cost of plan review and construction inspections: 'An was annual operating permit fee was established to cover the cost of periodic monitoring and inspection of Alternative/Engineered Septic Systems used by commercial/industrial operations. The need for on-going oversight of these types of systems is based on the fact that commercial/industrial operations are frequently subject to changes in discharge quality and quantity,changes in occupancy and use,and inherent potential for mechanical and operational problems. Your wastewater disposal system falls in the Alternative/Engineered Septic System category. iii. What options are thereto avoid the yearly permit fee? The yearly permit fee is charged to cover the cost of the required inspection and monitoring of these types of systems. c. In point#S and#6 Mr. Huggins makes reference to quarterly testing to be done at my expense for nine different parameters. I have great concern regarding these requirements without completly[sic] understanding their.significance. i. What are the limits/acceptable ranges of these parameters? These limits or ranges are set by the CVRWQCB to be protective of water quality based on your waste stream discharge. As discussed previously,the EHD will defer to the WDRs established by the CVRWQCB for your operation and will not require analysis for separate or additional parameters. ii. Can these limits/acceptable ranges change in the future? The WDRs are established to be protective of groundwater quality. Once the CVRWQCB evaluates your RWD and sets WDRs with acceptable limits or ranges,the question of future changes and compliance can be posed to their agency. iii. If the limits/acceptable ranges change will I be required to comply with these future unknown limits? See response to ii.