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Staff Report -3— Waiver 3— Waiver of WDRs for Small Food Processors generated during crush by the facilities that sell bulk wine, and a limit based on tons crushed does not account for the wastewater generated from handling the bulk wine. Nevertheless, staff believe that a limit based on tons crushed is fairly accurate, and a value which winemakers are already required to report to the federal Alcohol and Tobacco Tax and Trade Bureau. Staff proposes that the waiver contain a size limitation of 80 tons of grapes crushed per year. This is consistent with the Central Coast Regional Board, and corresponds to approximately 5,000— 6,400 cases of wine(depending on the variety and quality of grape and the winemaker's preferences)and to approximately 27,000 to 121,000 gallons of wastewater(assuming between 2 and 8 gallons of wastewater per gallon of wine produced). Several comments have been received stating that winemakers that crush greater than 80 tons of grapes should also be allowed coverage under the waiver, as long as they produce less than 100,000 gallons of wastewater per year(the same limitation as for other small food processors, as described below). Staff understand that water is in short supply in some areas of the Sierra Foothills, and those winemakers therefore produce less wastewater than the industry average. In order to provide parity with the other small food processors,the waiver has been revised to apply to wineries that crush more than 80 tons of grapes but produce less than 100,000 gallons of wastewater. However, these wineries will be required to meter their wastewater flows,just as other small food processors must meter their flows. Staff recognize that winery process wastewater flows do not include the water-to which no chemical cleaning agents have been added-that is used for the soaking and final sanitary cleaning of pre-cleaned or new wine barrels. Size Limitation for Other Small Food Processors Appling Wastewater to Land This waiver is intended to apply to other small food processors in addition to wineries. These food processors typically have a limited season (for example, prune dehydrators or walnut hullers)and have a wastewater strength comparable to winery wastewater. Because of the variety of food processors which may apply for coverage under this waiver, it is not appropriate to list the volume of product processed to determine the size limitation for coverage. Instead, it is more appropriate to describe a wastewater flow limitation. In order to be consistent with the wineries,and because the wastewater strength is similar,this waiver will apply to food processors with a wastewater flow of less than 100,000 gallons per year. Individual dischargers will be required to meter their wastewater flow to determine compliance. In some cases, it may not be necessary to install flow meters; instead it may be appropriate to record run times from existing pumps(either on water supply wells or on discharge pumps). Size Limitation for Small Food Processors that Tank/Haul their Wastewater Some smaller commercial wineries have determined that, for the volume of waste they generate, it is more cost effective to store their wastewater in a holding tank and then transport the wastewater to an authorized disposal facility instead of complying with the regulations for the discharge of wastewater onto land. It is emphasized that the Regional Board is not requiring any small food processor to utilize this method of waste disposal;this disposal method was proposed by some of the smaller foothill wineries, and the use is a personal choice based on economics and permit compliance issues. The 9 May 2003 version of the draft waiver stated that wineries which tank/haul their wastewater, and crush less than 80 tons of grapes per year, would be eligible for coverage. Since that time, staff talked with industry representatives and realized that very few, if any, wineries