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• 0 <br /> Kennedy/Jenks Consultants <br /> Mr. Timothy O'Brien <br /> California Regional Water Quality Control Board <br /> 10 March 2005 <br /> Page 2 <br /> Item 1 — Boilers or Clean-In-Place Systems <br /> There are eight hot water heaters, rather than boilers at the facility. The hottest of these units <br /> usually does not exceed 209 degrees Fahrenheit for the bottling lines. The hot water produced <br /> from the water heaters is used directly for operations and there is no blowdown stream <br /> produced from the units. There are no recirculating clean-in-place (CIP) systems at the winery. <br /> Item 2 —Waste Minimization <br /> Waste minimization measures, including the evaluation of the possibility of eliminating or <br /> reducing process water streams and the use of alternative chemicals or sanitation measures, <br /> will be evaluated as part of the Process Water Treatment and Reuse Evaluation. Because of the <br /> size of operations at Woodbridge, it is not feasible to employ contract bottlers. Also, our <br /> experience is that these bottlers do generate wastewater. <br /> Chapter 3 — Process Water Treatment and Reuse Evaluation Work Plan <br /> Because the existing process water treatment system is most effective in treating biologically <br /> treatable process water constituents, it is important to focus on these in order to optimize the <br /> treatment system.Woodbridge agrees that the most effective means of controlling or reducing <br /> FDS constituents is often times at the source, and source reduction and control will be <br /> investigated as part of the Process Water Treatment and Reuse Evaluation. Land application of <br /> process water can, however, also attenuate, transform and precipitate some of the constituents <br /> of FDS when properly managed and controlled. Woodbridge will seek to optimize the winery <br /> operations and treatment systems as a whole to obtain the proper cost-effective balance of <br /> constituent removal and reduction. <br /> Chapter 4 — Groundwater Characterization Work Plan <br /> It is important to understand both upgradient and downgradient offsite sources, in order to better <br /> determine the impacts to onsite groundwater. Also, hydrologic data seems to indicate that <br /> groundwater may actually flow under the Mokelumne River and so the river may not be an <br /> absolute barrier to groundwater flow. We believe that the relationship between the Mokelumne <br /> River and groundwater, and whether the river is discharging to groundwater, is one of the <br /> central questions regarding the assessment of land application of process water and it will be <br /> investigated as part of our Work Plan. <br /> Item 1 — Mokelumne River Sampling <br /> Our investigation is focused primarily on the hydraulic relationship between the Mokelumne <br /> River and the groundwater onsite, and secondarily on the water quality of the river. Limited <br /> sampling of the Mokelumne River, however, will be added to the sampling plan along with the <br /> review of readily available historical water quality data collected from nearby sampling stations. <br /> The evaluation of the results of the river sampling and review of available historical data, and <br /> g`is-WoupWndnWbW31ON113.00_mnnda iV&c pndt n"Mdendumt.d <br />