SITE INFORMATION AND CORRESPONDENCE

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KLEINFELDER File No. 20-3978-01.W 10 June 12, 1997 The various heating and evaporating processes utilized steam produced by the boilers. The boilers on site were fired using fuel oil and/or natural gas. The heated water was cooled in cooling towers. According to Mr. Tucker, the cooling towers on site have never used hexavalent chromium as a scale inhibitor. Process water generated during the manufacturing process was discharged to the wastewater ponds. The waste stream included boiler blowdown, acidic and caustic wastes, and scrubber wastes. After sediment had settled out of the wastewater, the water was reclaimed for use on the crops grown on site. The manufacturing plant equipment required lubrication in the form of industrial greases. Hydraulic oil was also likely used in the plant equipment. The processing equipment was cleaned using acid or caustic solutions. Solvents were used in the machine shop for parts cleaning. Cutting oils were also commonly used in the machine shops. Maintenance activities at the Spreckels Manteca plant also included the repair of motor vehicles such as cars and farm machinery, and the maintenance of a locomotive operated on site by Spreckels. The locomotive maintenance was not conducted at a specific location but was done on the tracks wherever necessary. The Spreckels Manteca property also contains a large amount of cropland, mostly almond orchards and grain crops. The cropland served two purposes: providing a buffer zone between the factory and the adjacent community, and providing a means of disposing of clarified wastewater from the plant via irrigation. The sediment which would accumulate in the wastewater ponds was periodically removed and spread on the feedlot. Beet chips, organic material and dirt removed from the beets was also spread on the feedlot where cattle consumed the edible portion. 20-3978-Ol.W]012017L155 Page 7 of 44 Copyright 1997,Kleinfelder,Inc.