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Nick Sikeotis - 2 - 6 September 2005 Application of wastewater to the land application area using sprinkler irrigation is prohibited when wind velocities exceed 30 miles per hour. The O&M Plan contingency for times when the spray irrigation system is inoperable or during a power outage is use of a 1,000-gallon tank trailer which requires the tank trailer operator to be available 24-hours a day, 7-days a week. • The statement in the Response that, "...the wastewater holding tanks are of sufficient size to contain stormwater which comes in contact with winery process equipment," is incorrect. A simple analysis of the potential runoff from a typical storm event indicates that over 8,300 gallons would be generated during a one-inch storm event. The O&M Plan describes the following equipment: a 1,000 gallon influent holding tank, a 1,200 gallon effluent holding tank, and a 1,000 gallon tank truck. If climatic conditions, soil saturation conditions, or electrical power disruptions prevent application of stormwater as it is generated, stormwater/wastewater mixtures will be discharged to the stormwater pond. Section 3.6 of the O&M Plan states, "If the wastewater holding tanks did overflow, wastewater would accumulate in the on-site stormwater pond." It is apparent that the available storage will not contain all stormwater/wastewater mixtures without close oversight and active management. Such active management is unlikely to always be immediately available in the future. In order to begin groundwater monitoring, staff is prepared to allow the wells to be installed once the remaining issues (below) are adequately addressed. Stormwater pond monitoring is required by the Monitoring and Reporting Program (MRP) Order No. R5-2004-0079. Staff expects that wastewater constituents will be detected in the stormwater pond. Should this occur staff would recommend a California Water Code Section 13267 Order for groundwater monitoring well(s)to be installed at the stormwater pond. This may result in additional cost to Jessie's Grove Winery due to the remobilization of a drill rig to the site. Remaining Issues The following issues were presented in the Regional Board's 6 April 2005 NOV but were not addressed in the Response. • NOA continues to use the phrase "neat bentonite grout"both in the Response text and attached figure. The meaning of the phrase is clear but is not what NOA believes it to be. Merriam Webster Online Dictionary http•//www.m-w.com/cgi-bin/dictionga provides the following definition for the word "neat," : a :free from admixture or dilution :<neat brandy> <neat cement> b :free from irregularity. Please revise the Response, including the Typical Well Construction Detail figure reference to "neat bentonite grout." • The statement that"The annular seal will consist of neat bentonite grout and will be placed by any convenient means available" is unacceptable. All well construction must occur using methods and materials that are consistent with the California Well Standards Bulletin 74-90. W ASWI\ObricO7 San JoaquinVessie's GmvdSikeolis 23 Aug 05.doc