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FALL CREEK ENGINEERING,INC. TECHNICAL COMMENTS FCE has prepared the following comments on the tentative WDR. To facilitate your review, the comments are presented in the same order as in the WDR. Findings 2. This finding should be revised to state that" Goldstone Land Company, LLC owns the facility and land treatment units; Goldstone Land Company, LLC doing business as Bear Creek Winery". 11. This finding indicates that the Keg Line and Distillery softner systems will be used in the future. The Distillery softner will no longer be used at the winery. Please revise this finding to reflect this change. 13. As previously discussed, the Winery installed a flow meter in August 2002. This information was provided in the September 2002 and subsequent monthly self- monitoring reports submitted to the RWQCB. Please revise this finding to reflect this action. 15. This finding presents a summary of wastewater quality data provided by Bear Creek Winery for 2001. This table should be updated to reflect current operating conditions through 2002. A summary of wastewater test results from October 2000 through November 2001 are presented in Attachment 1. (An electronic copy of this information can be provided to Board Staff upon request.) The Winery requests that the "typical winery wastewater quality" data included in the permit, as provided by Summit Engineering be omitted from this finding. The range of values presented by the Summit Engineering data set is too variable to add value to the site-specific conditions at the winery. Although the Summit Engineering data indicates that the pH of winery wastewater can be very low, this is not the experience at the winery. Best management practices employed at Bear Creek Winery maintain the pH at substantially higher levels than implied by the"typical'values presented in the permit. The"typical' values shown do not reflect actual monitoring data collected at the winery, and portray a "worst-case" condition that does not occur at the facility, therefore they should not be included. The total dissolved solids (TDS) concentration of the wastewater is composed of both volatile and fixed dissolved solids. In general, the wastewater consists of approximately 40 percent of volatile dissolved solids (VDS), principally as dissolved sugars and organic acids. Whereas, the fixed dissolved solids (FDS) includes the inorganic or mineral fraction (i.e. dissolved salts). This is a very important characteristic of the wastewater not addressed in any WDR findings. FCE requests that a finding be added that more clearly discusses the ratio of TDS, VDS and FDS in the wastewater. To facilitate this finding, FCE has summarized the last two years of TDS, VDS and FDS data, as presented in Attachment 2. 3