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FALL CREEK ENGINEERING,INC. at the winery. Combining source control measures and biological treatment, as proposed by the Winery is considered to be BPTC. This finding should either be removed or revised to more accurately reflect the characteristic of the wastewater generated at the facility and recognize treatment technologies that are both technically feasible and environmentally sound. 70. As previously discussed, the proposed wastewater system is designed to be consistent with the objectives of the Water Quality Control Plan for the Central Valley Region. Therefore, this finding should either be removed or be revised to reflect this condition. C. Effluent Limitations: 1. As previously discussed, the proposed effluent limitation does not account for the characteristic of the source water used by the Winery and the wastewater generated by the winery. Sodium and chloride in the source water is higher than the assumed "background"well. The wastewater is composed of both FDS and VDS, but this limit does not make this distinction. The proposed effluent limits are overly restricted and cannot be attained by the Winery. The proposed effluent limits are apparently established based on what is considered to be "background" groundwater quality. FCE does not believe the groundwater quality data collected to date is sufficient to support an effluent limit at this time. FCE recommends that alternative effluent limits be set in the permit that allows the Winery to propose a water quality protection standard that considers the quality of the source water,process wastewater and groundwater conditions after a more thorough assessment of groundwater at the facility is completed this coming year. 4. Installing a pH neutralizing system to meet this proposed effluent limit is not a BPTC technique. Chemical neutralization of the wastewater will result in additional salt loading to the LTU. This is not desired,nor protective of water quality. As previously discussed in the RWD and earlier comments, this effluent limit is overly restrictive and not protective of ground water quality, and as such is not consistent with Resolution 68-16. The pH of the groundwater supply used by the winery is between 6.0 and 6.1. This should be considered in the derivation of the effluent limit. Monitoring and Reporting Program Wine�Wastewater Monitorin�Monitorinn The wastewater monitoring program should include chloride, sodium and potassium. FCE also recommends adding volatile dissolved solids (VDS) in order to calculate FDS. elemental Irrigation Water Similarly, testing of the supplemental irrigation water should include chloride, sodium and potassium. 9