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PALL CREEK ENGINEERING,INC. 52. The concentration of fixed dissolved solids and specific conductance of the process wastewater and groundwater water that will be applied to crops is well below the threshold values presented for alfalfa and hay. This finding does not pertain to the crops or wastewater conditions found at the winery and FCE recommends that it be removed. 53. Boron is deficient in soils in the vicinity of the Winery and boron is not a constituent of concern in the wastewater. Therefore,this finding does not pertain to this facility and should be removed. 55. The last two sentences in this finding are unclear. Please rephrase these findings so that the intended meaning is clear and pertinent to the facility. 63. This finding indicates that the proposed wastewater system improvements will not be consistent with the State's Antidegradation Policy (Resolution 68-16). This finding states that"the project as proposed may degrade groundwater with dissolved solids and possibly create nuisance odors from organics if wastewater is ponded when applied to land." As previously discussed, the limited groundwater quality data does not support the staff's findings that groundwater is degraded from the prolonged discharge of wastewater over the 12-acre rapid infiltration area. The limited groundwater -hemistry does not indicate the discharge of winery wastewater to the LTU degraded groundwater underlying the site. The finding does not take into consideration the influence long-term fertigation practices in the vicinity of the winery and throughout the San Joaquin Valley have had on groundwater quality, specifically as sources of salinity and nitrogen in the shallow groundwater basin. There have been no apparent odor nuisance conditions reported since the WDRs were adopted in 1970, covering the past 30 years of operation. However, this is not recognized in the WDR. Under the proposed wastewater system improvements, wastewater will be applied to 69-acres of cropland. The system will use a mixed regime irrigation scheme: several sources of water will be used to irrigate crops over the course of a year, including process wastewater, groundwater and rainwater. Applying a conservative mass- balance equation to account for the amount of fixed dissolved solids measured in wastewater, irrigation well water and rainwater and the volume of each water source applied to the LTU, the average annual concentration of fixed dissolved solids applied to the croplands will range between 500 and 600 mg/L, which is below the presumed "background" groundwater concentration detected in monitoring well#2. The volume of wastewater will also be applied below agronomic rates for the crops grown in the LTU. Therefore, no nuisance conditions are anticipated. The proposed improvements to convert the wastewater system from a rapid infiltration system to a slow-rate system demonstrates that the Winery is applying a"Best Practicable Treatment and Control" system to manage wastewater and protect ground water 7