SITE INFORMATION AND CORRESPONDENCE

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R Kurt Kautz -2 - 27 October 2015 Bear Creek Winery Improvement Schedule The ROWD stated that the organic loading rates have been excessive and have exceeded generally accepted loading rates for land disposal systems, especially during the crush period between August and October of each year. Our 5 March 2015 Incomplete ROWD letter commented that: Reducing conditions in the groundwater beneath the land application areas (LAAs) have occurred due to discharge of high concentrations of organic waste in the winery process wastewater and have promoted the dissolution of minerals that are naturally present in the soil. The RIND proposes to continue the use of rapid infiltration without demonstrating that it will not exacerbate the current groundwater pollution. The RWD must propose specific structural and/or operational improvements that will ensure that the pollution is mitigated to the maximum practical extent as quickly as possible. The ROWD proposed to install a wastewater treatment system that will include two lined aeration ponds, a trickling filtration system, and expanding the LAAs to reduce mass loading. We concur that these activities will help to reduce continued impact to groundwater, however the proposed schedule indicated that installation of the wastewater treatment system would occur in five to seven years, after expansion of the LAAs. Given the high strength nature of the wastewater from the winery (BOD in excess of 2,100 mg/L), the most effective way to reduce excessive mass loading and reducing conditions in groundwater will be to install the wastewater treatment system sooner rather than later in the sequence of facility improvements. WDRs 71-37 states that the discharge shall not cause a pollution of ground or surface waters. Groundwater monitoring data from the shallow wells that were destroyed in 2013 and their corresponding replacement deeper-interval monitoring wells indicate that groundwater degradation and pollution has occurred beneath the facility. The winery's response letter dated 30 April 2015 also stated that "localized impairment of groundwater has been observed, but the impacts do not appear to extend beyond the boundaries of the project site as water quality at the periphery is equal to background levels." The discharge has degraded groundwater and has violated the current WDRs, regardless if the source is confined within a property boundary. The current wastewater disposal practice is not in compliance with the Basin Plan and poses an unacceptable risk to the quality of waters of the state. We acknowledge Bear Creek Winery's efforts to develop a phased construction schedule that factors in balancing capital expenditures with economic realities. However, it is important to recognize the importance of prioritizing the protection of water quality within that plan. We recommend two years as a reasonable time frame to complete installation of the wastewater treatment system. Therefore, the WDRs will include a time schedule for the construction of the wastewater treatment system within two years of adoption of the WDRs. The WDRs will also require the submittal of a Pond Design Work Plan and Construction Quality and Assurance Plan in advance of pond installation. If the winery does not concur with this schedule, enforcement action may be necessary to discontinue any and all discharge that contributes to existing on-site groundwater impairments.