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FALL NECREEK RI ENGINEERING,INC. 3. Seeding the existing 12-acres of rapid infiltration area in the 2002 and 2003 winter season and operating the area as a slow-rate infiltration system. Most importantly,the Winery has instituted best management practices within the winery in an attempt to decrease the concentration of fixed dissolved solids, organic material (BOD) and to maintain the wastewater pH near neutral. The changes the Winery has adopted include reusing cleaning/sanitizing water to clean several tanks, neutralizing the high strength ion exchange discharge before it is released into the process wastewater stream and manually removing the wine solids from filter elements before rinsing the filters with water. These modifications have led to less variable wastewater quality reflected in the lower BOD and fixed dissolved solids concentrations and more neutral pH measured in the wastewater over the past year, as presented in the monthly monitoring and reporting program reports submitted to your agency over the past year. The intent of the Winery has always been to operate their wastewater system in a manner that prevents nuisance conditions and impacts to groundwater quality, as well as to minimize any impacts to the site. The land treatment system operated by the Winery has been a rapid infiltration(RI) system that was designed to apply wastewater to 12-acres of land at a controlled rate in a designed and engineered setting. The facility has never experienced any nuisance conditions, and loading rate calculations performed by FCE indicate that the facility was operated within normal design criteria for this type of facility. There is no indication in the limited amount of groundwater data collected to date that the facility has impacted water quality underlying the site. Regardless, the Winery has chosen to expand and convert the RI land disposal system to a slow-rate land treatment system. Wastewater will be discharged to a substantially expanded and cropped area, and applied at agronomic rates to established vineyards and winter oats. Loading rates of organic matter and fixed dissolved solids will be well below levels that are detrimental to crops and underlying groundwater. The slow rate land treatment system will be operated to achieve a number of objectives, including: • Treatment of the applied wastewater • Exchange of wastewater with fresh groundwater for irrigation purposes to achieve overall water conservation at the winery; and • Economic return from the use of water and nutrients to produce marketable crops. Recognizing that the predominant waste constituent in the process water is an easily and rapidly biodegradable waste,the site specific conditions are suitable (soil conditions will facilitate adequate biological processing of the waste, and groundwater is very deep), the land treatment system should be considered the "Best Practical Treatment and Control System" for the facility. The Winery requests that the Tentative WDR incorporate additional findings that reflect the actions completed by the Winery to improve the operation of the wastewater system to meet the forth coming requirements from your agency, as well as to protect groundwatc:quality underlying the property. 2