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The Department of Ecology’s winery wastewater permit writing team is in the process of creating and submitting their economic impact statement for the current draft permit. WWI and industry leaders have worked with Ecology over the past four years to educate them on how our industry is different from others who discharge wastewater and thus our permit should be practical and applicable to how wineries specifically.
Thank you to everyone that commented on the pre-formal draft in early July as well as all who attended a recent webinar or workshop put on by Ecology to allow for industry input on the current draft of the permit. Your feedback is much appreciated.
As a result of industry experts pushing on the Department of Ecology to mitigate financial and operational impacts that could arise from the issuance of this permit, Ecology took the following actions to mitigate the compliance cost of the permit. These actions were taken during the development of the permit, as Ecology incorporated input from winemaking facilities to best achieve environmental protection while reducing compliance burden.
• Allowing Permittees to collect a grab sample (one single sample) rather than a composite sample (a combination of three separate samples).
• Not requiring Permittees discharging to WWTPs to sample their wastewater. They are only required to report the results of the WWTP’s analysis.
• Not requiring permittees discharging to lagoons or other liquid storage structures to sample their wastewater.
• Reducing the frequency of wastewater sample analysis. Permittees required to analyze wastewater samples are only required to do so on a quarterly basis.
• Not requiring Group 1 Permittees that discharge as irrigation to managed vegetation to analyze wastewater samples to determine how much wastewater they are permitted to discharge in order to not overload their crop/soil. The general permit now contains application rates and application frequencies.
• Not requiring Permittees that discharge as road dust abatement to analyze wastewater samples to determine how much wastewater they are permitted to discharge. The general permit now contains application rates and application frequencies.
• Not setting a minimum annual frequency for Permittees that discharge to a subsurface infiltration system to clean the tanks. They may clean on an as-needed basis.
• Not requiring an annual report.
• Not requiring Permittees installing a new subsurface infiltration system to treat domestic sewage separate from wastewater.
• Not requiring Permittees discharging to an existing subsurface infiltration system to retrofit their existing system or to treat domestic sewage separate from wastewater.
• Establishing differing reporting requirements for small wineries.
• Not covering wineries producing less than:
o 53,505 gallons of wastewater per calendar year.
o 7,500 cases of wine or juice per calendar year.
o 17,835 gallons of wine or juice per calendar year.
• Not covering wineries discharging to delegated POTWs or Listed WWTPs.
• Designing requirements for lagoon and subsurface infiltration systems to be able to be done by winery staff or management, without hiring outside engineers or other contractors.
• Requiring only adaptive management when benchmarks are exceeded.
• Allowing small wineries to estimate wastewater flow.
• Phasing in requirements for removal of fine solids and design of a waste management system that accommodates future growth and beneficially reuses wastewater.
• Phasing in assessment requirements.
• Establishing different benchmarks for Group 1 Permittees for some types of wastewater discharge.
• Not requiring Permittees to conduct inspections more frequently than twice per year.
You can find the current draft of the winery wastewater discharge permit, an updated timeline for the permit drafting and implementation process, and more information about the permit by clicking here:
WWI continues to help lead the ongoing efforts to work with the Department of Ecology as they write a general permit for winery wastewater discharge. This permit and it’s various requirements could have a tremendous, and devastating, impact on our industry so it’s imperative that we are constantly pushing on Ecology to write a permit that is flexible enough to work for the industry while also minimizing any financial and/or operational harm, with increased focus on protecting our small wineries from such harm.