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Staff Report -6— Waiver 6— Waiver of WDRs for Small Food Processors from coverage under this waiver. Animal slaughterhouses and/or meat processing facilities cannot be covered by this waiver. The waiver does not allow wastewater to be placed in impoundments(any sort of pond), whether for treatment, temporary storage, or long-term storage. The placement of concentrated waste in a pond has the potential to impact water quality, and in fact, has already impacted water quality at some wineries and food processors. The use of treatment or storage ponds will be regulated under either individual WDRs or a possible future General Order for land discharge. The waiver states that wastewater must not be applied to land 24 hours before a predicted storm, during a storm,24 hours after the storm ceases, or when the ground is saturated. This is a standard specification in land discharge permits, and is necessary to ensure that wastewater will not co- mingle with stormwater. In order to implement this specification, it is expected that the dischargers granted coverage under this waiver will either modify their operations so that they are not producing wastewater during storm events, or will have some method(such as an above ground or underground tank)to allow the wastewater to be stored during storm events. Report of Waste Discharge A Report of Waste Discharge (RWD) is necessary to describe an individual food processor's operation and to show that waste is(or will be)discharged in a manner that complies with the waiver. The waiver describes the items that are to be included in the RWD. The RWD is simple enough that an individual discharger should be able to complete it directly;there should be no need to hire a consultant. It should also be noted that the Board usually requires the items of a RWD pertaining to wastewater treatment, storage, and disposal be prepared under the direction of a Califomia Registered Engineer or Geologist. However, that is not required in this case. The RWD is to include a one-time filing fee that corresponds to the lowest threat and complexity site, as described in Title 23, California Code of Regulations, Section 2200. That filing fee is currently $400, and is necessary to cover staff s time to review the RWD, prepare the coverage letter, review the annual monitoring reports, and complete other administrative tasks. Annual Report An annual report is necessary for several reasons. First,the Board will need to review the waiver within five years, and will need to have data to show a history of compliance. Also, it is anticipated that many small food processors,especially wineries,will grow over time. An annual report is necessary to show that the discharger continues to meet the conditions of waiver, including the size and/or flow limitations. If a discharger exceeds the limits within this waiver,then it will be required to apply for individual WDRs or a General Order, as applicable. Outstanding Issues Septic Tank/Leachfield Discharges Staff realize that a number of small wineries currently discharge their wastewater to septic tanks and leachfields. While we concur that the volume of wastewater generated by crushing 70-80 tons of grapes is comparable to the volume generated by a large household(although a winery generates much larger volumes during crush),the strength of the winery wastewater is substantially stronger (as shown in the above table). Staff do not believe that soil beneath a subsurface leachfield is able