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Vincent Westphal • - 3 - • 28 July 2003 , A Draft RWD prepared by FCE was submitted in February 2002; that report described an inadequate groundwater monitoring network. RWD Section 3.3, Groundwater Water Quality stated: "There are no wells that sample directly up and down gradient of the disposal field, therefore it is difficult to draw definitive conclusions about the effect of the Winery's disposal field on groundwater. However, the well that is most likely to be influenced by the wastewater disposal fields is monitoring well 3 (MW3), which is the southern most of the two monitoring wells to the west of the fields. " The report continues, "The concentration of total dissolved solids (TDS) measured in MW3 is higher than the concentration measured in the presumed up gradient well, MW2. The typical potassium concentration ofgrape juice is around 1,200 to 1,400 mg/L, while that of wine is around 800 mg/L. The Winery's wastewater is presumably enriched in this cation. Well 3, the presumptive "down gradient" well, has an elevated concentration ofpotassium compared to Well 2. " To reinforce those conclusions, in Section 3.4, of the same RWD, Summary of Findings states: "...the land disposal system may be causing some elevated mineralization to occur due to the elevated levels of potassium in the wastewater. " Staff notes that the RWD proposed adding 57 acres to the land areas used for application of wastewater and groundwater monitoring was not recommended in any of the new land areas. Additionally, new land application areas have already been developed and are in use prior to characterization of the groundwater quality. Active land application areas require installation of groundwater monitoring wells without further delay. On 15 April 2002 a Revised Report of Waste Discharge (dated March 2002)prepared by FCE was submitted. The Revised RWD Section 3.3 Groundwater Water Quality includes the same text quoted above. The Revised RWD states, "There are no wells that sample directly up and down gradient of the disposal fields, therefore it is difficult to draw definitive conclusions about the effect of the Winery's disposal field on groundwater. " The report goes on to state Well MW3 appears to be impacted by the wastewater application. Groundwater Monitoring Reports Revised Monitoring and Reporting Program (Revised MRP)No. 71-37 was issued on 25 September 2000 and requires groundwater monitoring. While either FCE or ASE has prepared the reports, both companies have reported higher concentrations of dissolved solids in Well MW-3. The First Quarter 2003 monitoring report prepared by FCE states, "The data show that monitoring well 3, which is best situated to be influenced by applications on the primary waste disposal area, carries a heavier burden of dissolved substances than does well 2 which is crossgradient from it and from the disposal area. Well 1, which is presumed to be upgradient of waste applications by Bear Creek Winery, also exceeds well 2 in TDS Thus, the differences between well 2 and well 3 are not unambiguously linked to the occasional disposal of wastewater between the two. " WSen_Joequin_Nonl 5%Stdfl06nenWm Joequin\Bear Creek\weStpIW 21 July 03.dm