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r water softening will be considered in the Salinity Reduction Study. On this basis,it is also my suspicion that the high readings of TDS in March 2002(10,200 mg/L)and June 2002(13,500 mg(L)were drawn at a time when the winery waste stream did not reflect our typical composition. I suspect it may have contained a grab sample from a cold stabilization,water softener regeneration,or contained a significant quantity of wine and was not representative of the true composition of the winery waste for those months. It also appears that the incoming source water exceeds the WDR limit for TDS in the winery discharge. A sample drawn on March 7,2002 contained 570 mg/L of TDS and a second sample drawn April 16,2003 contained 550 mg/L. I am concerned that the quality of the incoming water will prevent us from being able to meet the WDR discharge limits. It therefore appears that,exclusive of costly reverse osmosis treatment of our water streams,some modification of the TDS limits in our existing WDRs may be appropriate. Conversion to a consumptive increase limit or an aereal loading limit(lb/acre•d)may be more appropriate than the existing concentration limit which is exceeded from the start within the source water. Perhaps a revision to theWDRs,or a conversion to the forthcoming General WDR,may be appropriate for consideration at the conclusion of the proposed Salinity Reduction Study. On the issue of lining the treatment pond,we are currently waiting for our ponds to dry out sufficiently to install a clay liner. We are in the process of testing to confirm the permeation rate of the clay we intend to use. It is our intention to line the treatment ponds with twelve inches of clay with a permeation rate of 8.1 X 10"8 cm/sec. Compared with two feet of clay with a permeation rate of 1.0 X 10-6 the 12 inches of less permeable clay will delay seep through from two years with the 24 inches of 1.0 X 10-6 cm/sec clay to twelve years with 12 inches of the 8.1 X10"8 cm/sec clay. It is our belief that the measures proposed herein,along with our current efforts to upgrade our winery wastewater management system,will result in substantial improvements towards compliance with the discharge standards. We appreciate your consideration of this proposal. Should you have any questions, please do not hesitate to contact me. Sincerely, .4 LT� Jeff Runquist Winemaker Cc Glenn Dombeck,P.E.,Techqua Ed Lee, Wallace Swanson International Mike Huggins, San Joaquin County Environmental Health Department Ron McManis,McManis Family Vineyards Joe Zilles,Kleinfelder