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Matt Belair - 3 - 20 August 2012 Delicato Family Vineyards g. Proposed land application area hydraulic loading rates distributed monthly in accordance with expected seasonal variations based on crop needs for both water and nutrients. h. Projected long-term percolation rates (including consideration of percolation from unlined ponds). 5. Storm Water Discharge: The Amended ROWD states that storm water from the winery may be discharged directly to the LAAs. As discussed during the meeting on 15 August 2012, direct discharge of storm water to the LAAs is acceptable, provided that the expanded LAAs can accommodate the additional flow without over irrigation. We understand that Delicato is currently considering different effluent storage design configurations, including the option of directing storm water to a separate unlined pond. As indicated above, the final design of all wastewater effluent and storm water discharge to the LAAs needs to be considered in the water balance. 6. Sumps: Please clarify whether and how wastewater will be segregated from storm water that collects in existing sumps and how those waters may be managed differently. All waste streams should be illustrated in the Flow Schematic. 7. Land Application Areas: Section 6.3.4 of the Amended ROWD states that existing LAAs will be expanded from 20 to 130 acres. The expanded LAAs will include the two existing 10-acre evaporation/percolation checks reconfigured with an adjoining parcel previously used for composting, and an additional 107 acres of existing vineyards. Figure 14 of the Amended ROWD illustrates the proposed LAAs and planned land uses of these areas, but Figures 2, 6a, 6b, and 7 depict different boundaries for the existing LAAs. Please provide updated figures showing the existing and proposed layout of LAAs. 8. Irrigation Method: The Amended ROWD indicated that process water is currently discharged to the LAAs via cutback flood irrigation. Flood irrigation will continue to be used to distribute wastewater to the expanded LAAs, which will either be double cropped or used as vineyards with cover crops. Please explain how the LAAs will be designed and maintained to prevent ponding, off-site discharge of tailwater, and off-site discharge of storm water. 9. Supply Wells: The Amended ROWD provided analytical data from the sampling of two on-site supply wells and one agricultural well (location undetermined). The number and locations of supply wells shown on Amended ROWD illustrations are inconsistent with wells previously depicted on Kleinfelder's Monitoring Well Location Map, circa 2001. From our meeting on 15 August 2012, one or more of the supply wells may have been abandoned or are not currently in use. Because some of the supply wells are located in areas where groundwater degradation has occurred, all existing on-site supply wells should be depicted on facility diagrams. Any available information on the installation date, construction details, water quality, and flow data should also be submitted to provide a better understanding of water-bearing intervals at the facility. 10. Constituent Loading Rates Tables 14, 15, and 16 of the Amended ROWD provides the results of vadose zone and groundwater modeling for the existing and proposed LAAs, however the Amended ROWD was issued before a final wastewater treatment process plan was developed. Once the final design has been developed, the loading rate calculations should be recalculated based on expected effluent quality as discussed in Comment 3. 11. Monitoring Wells: Groundwater data from monitoring wells MW-4, MW-5, and MW-6,have been used to evaluate background water quality. Once the expanded LAAs are put into use, monitoring wells MW-5 and MW-6 will be converted to points of compliance and MW-4 will be considered an upgradient monitoring location. Additional monitoring wells will be needed