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FALL CREEK ENGINEERING,INC. quality at the site. The proposed project should be consistent with Resolution 68-16. Staff's finding that"the Discharger has not made BPTC demonstration"and"the project as proposed by the Discharge is not consistent with Resolution 68-16" is unfounded. 64. The finding is unclear and should be revised so the intent or meaning is clear. 66. What is the data source for winery wastewater quality presented in this finding? Footnote 1 indicates the values presented represent averages for both crush and non- crush season,but a range of values are shown. This is unclear. The water source used by the Winery contains chloride and sodium concentrations in excess of the presumed "background" well. In order to meet the proposed limits stated in this find is the Winery expected to reduce the concentration of these constituents before the water is used in the process. Is the proposed limit applied to the wastewater, or as a water quality protection standard applied to a point of compliance (such as below the five foot treatment zone of the LTU)? If the limit is applied to the wastewater the limit should be based on the fraction of total dissolved solids that is fixed or the FDS. Adopting a TDS limit in the wastewater prior to application to the slow-rate LTU is overly restrictive and does not recognize the fact that approximately 40 percent of the TDS is composed of readily decomposable dissolved sugars and organic acids that will be easily decomposed in the soils. Similarly, a fraction of the fixed dissolved solids will also be utilized by the crops, such as potassium and nitrate. The proposed effluent limit for TDS will not be attainable and is overly protective of ground water quality, whereas, adopting a limit for FDS will be more attainable and protects groundwater quality. 68. The last sentence of this finding should be rewritten, in it's current form it is unclear. 69. This finding overstates the issue of TDS. As previously discussed the permit does not properly discuss the characteristic of the wastewater(i.e the ratio of FDS and VDS present in this type of wastewater, see comment on Finding 15 above). The finding that the Discharger has not proposed to manage salts at the facility is also not well founded. As previously discussed the Winery has initiated source control measures to reduce the concentration of TDS in the wastewater. However, this finding indicates the Board Staff has not conducted any recent facility inspections nor had any clear communication with the Discharger to determine what actions have occurred at the site to address this issue. The permit is written in such a fashion to indicate negligence on the part of the Winery. This finding further indicates that potential treatment technologies that a winery could utilize to reduce salts in the wastewater include reverse osmosis and ion exchange. These technologies are not considered to be BPTC measures for this type of wastewater. These treatment schemes are very expensive, require a substantial amount of energy to operate, generate large volumes of brine that contain a high concentration of FDS, and are not appropriate for the type of waste streams generated 8