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improve groundwater protection. LAA will adhere to the site's issued WDR and MRP as required <br /> by the RWQCB. <br /> The land application program will be developed to prevent impacts to groundwater quality. The <br /> irrigation management practices will accommodate use of fields for beneficial agriculture. The <br /> existing 20 acre LAA will be double cropped. The 111 acres of vineyards at the Site identified for <br /> land application will be flood irrigated with process water and supplemented with existing <br /> irrigation water systems. Process water irrigation on the cropped land and vineyards will be <br /> managed to prevent tailwater generation using irrigation techniques such as cutback irrigation. <br /> Cutback irrigation involves turning off flood irrigation supplies when the irrigation water has <br /> advanced to approximately 75 to 80 percent of the length of the LAA. <br /> As currently done, the land application program will adhere to proper monitoring as required by <br /> the RWQCB to document protection of the groundwater. <br /> 1 .2 Best Practicable Treatment and Control Measures <br /> Best Practicable Treatment Control (BPTC) measures have been implemented at the Facility for <br /> source reduction, salinity control and water conservation. The BPTC measures help minimize <br /> flow and constituent loadings in the process water. The sections below describe the BPTC <br /> measures that have been implemented and are planned at the Facility. <br /> 1.2.1 Sanitation Chemicals <br /> Using a potassium-based cleaner rather than a sodium-based cleaner reduces the amount of <br /> FDS that reaches groundwater because potassium is a plant nutrient and will be beneficially <br /> used by the crops planted in the LAA. <br /> 1.2.2 Removal of Wine Ion Exchange Unit <br /> DFV previously operated an Ion Exchange Unit that required large amounts of water and <br /> created concentrated process water with salt content. After reviewing the unit's operation and <br /> the wine quality, DFV found the unit not needed to produce quality wine and removed the unit. <br /> 1 .2.3 Clean In Place (CIP) System <br /> DFV will install CIP systems for bottling line sanitation when moving the bottling lines. The CIP <br /> system will recycle water used in the cleaning process to reduce bottling water use by up to <br /> 40%. <br /> 1.2.4 Timers and Nozzles <br /> Timers are used on the tank washing pumps for minimizing over use of water during tank <br /> cleaning. Nozzles have also been installed on hoses to also minimize overuse of water. <br /> 1.2.5 Efficient Pumps <br /> A recirculation system has been installed on the water cooled vacuum pump for the rotovac <br /> filter. Water used to cool the pump is recirculated rather than continually discharged. <br /> Delicato Family Vineyards Exhibit 3.doc <br /> 11/21/2011 <br /> Page 2 of 3 <br />