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Vincent Westphal • - 5 - • 28 July 2003 In the 31 January 2003 FCE letter,modifications to the tentative WDRs Finding No. 32 were requested, stating that the presence of nitrate in groundwater indicates groundwater has not been impacted by the winery wastewater discharge because the substantial oxygen demand of wastewater would have resulted in denitrification. That might be true if the groundwater were very shallow,but groundwater at the facility is at least 70 feet deep which provides an ample soil column to filter organic materials from the wastewater. Interestingly, the paragraph requesting the changes, ends with the following statement, 'TCE agrees that additional groundwater wells and monitoring activities are required to better assess groundwater quality at the site prior to determining if historical and proposed wastewater disposal practices will impact groundwater quality. " On page 9 of the comment letter, FCE states, 'TCE recommends that alternative effluent limits be set in the permit that allows the Winery to propose a water quality protection standard that considers the quality of the source water,process wastewater and groundwater conditions after a more thorough assessment of groundwater at the facility is completed this coming year. " Staff agrees with the approach described in that FCE comment. However, if no additional data is collected,Regional Board staff has no alternative but to rely upon the existing data,which has been described in numerous documents by FCE as inadequate. On page 10 of the comment letter,FCE recommends adding the analytes chloride, sodium, and potassium to the monitoring requirements. Staff notes that the analytes described are included in standard minerals, which is required on an annual basis in the tentative Monitoring and Reporting Program (MRP) attached to the tentative WDRs. If BCW and FCE desire to collect the data more frequently, that is acceptable. Conclusions BCW has operated the winery under WDRs adopted in 1971. Wastewater treatment requirements have changed substantially since then, as well as the monitoring requirements. Discharge with little or no monitoring of the effect that discharge has on the waters of the State is not acceptable and is not in the best interest of the People of the State. Staff has worked cooperatively with the Discharger and the Discharger's consultants to prepare tentative WDRs that are consistent with WDRs imposed on other wineries in the region. BCW stated the tentative WDRs were overly restrictive and that additional information was required to resolve the following issues: • Background groundwater quality, • pH neutralization of wastewater prior to application to the land treatment units, • The level of source control already implemented by the winery, and • Effluent limits related to the water supply quality. Further investigation of all these issues were required in the tentative WDRs; neither BCW nor FCE raised objections to completing the work; in fact, FCE stated that additional groundwater characterization was needed. Staff agreed to table consideration of the tentative WDRs pending BCW's completion of site specific studies. This delay will also allow BCW to incorporate the results of the Wine Institute's study on the disposal of winery wastewater to land treatment units. It is noted that staff s review of the Wine Institute's preliminary data shows that substantial monitoring and management is necessary to prevent groundwater degradation. BCW utilizes the V:\Senloequin_NonB5 teH\ObdenTmJoauin\Benr Creek\westplW 21 July UJ.dn