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Vincent Westphal • - 4 - • 28 July 2003 , Waste Discharge Requirement Preparation Based on the information submitted to the Regional Board in the Draft and Revised RWDs, staff prepared tentative WDRs for the facility. The tentative WDRs were distributed on 10 December 2002 and included the requirement for groundwater monitoring,as is customary for monitoring the effect of land application of wastewater on groundwater quality. Tentative WDR Provision No. G.2.e stated: e. By 12 June 2003, the Discharger shall submit a workplan for characterization of groundwater qualityfor the LTUs. All active LTUs must be monitored. The workplan shall describe the installation of additional wells to allow evaluation ofgroundwater quality upgradient and downgradient of all LTUs. Monitoring wells shall be constructed to yield representative samples from the uppermost saturated interval and to comply with applicable well standards. The workplan shall be consistent with, and include the items listed in, the first section of Attachment C, "Items to be Included in a Monitoring Well Installation Workplan and a Monitoring Well Installation Report of Results. " The tentative Order did not require all the groundwater monitoring wells to be installed immediately. BCW had indicated the winery size would be increased over time with wastewater flow rates increasing with the capacity of the winery. Therefore, staff included a provision that allowed additional land application areas to be added after improvements were completed. The requirements were included in Provision G.2.b as follows: b. At least 90 days before the Discharger wishes to discharge wastewater to new LTUs described in Finding No. 23 the Discharger shall submit a report describing completion of improvements to the designated LTUs to ensure compliance with this Order. The improvements shall include, but not be limited to, installation offencing or notification signs, installation of berms to prevent surface water runoff from the LTUs, and installation of additional groundwater monitoring wells (in accordance with an approved workplan, as described in Provision G.2.e). FCE Comments on the Tentative WDRs On 31 January 2003 FCE provided comments on the tentative WDRs. The document described operational changes in the winery to reduce dissolved solids (especially fixed dissolved solids) and neutralize wastewater acidity. The winery has operated since 1934 and has discharged all wastewater, including until recently stillage, to a 12 acre land application area. On page 2 of the 31 January 2003 letter, FCE states, "There is no indication in the limited amount of groundwater data collected to date that the facility has impacted water quality underlying the site. " It should be remembered that in the Draft RWD and Revised RWD, FCE stated, "There are no wells that sample directly up and down gradient of the disposal field, therefore it is difficult to draw definitive conclusions about the effect of the Winery's disposal field on groundwater. " Because the 31 January 2003 FCE letter does not provide any new data or analysis of data, staff doesn't know what the, "no indication...that the facility has impacted water quality, " statement is based on. V:\San_Jaequin_Non15\StalftObnenTSan JoaquinTear Creek\weetphtl 21 July 03.don