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Ms. Antonia K. J. Vorster <br />March 17, 1986 <br />Page Two <br />The requirement that the wastes be neutralized prior <br />to disposal necessitates a definition of neutralized by RWQCB. <br />Holly Sugar proposes that the definition of "neutralized" for <br />disposal purposes be when the maximum pH of a composite sample <br />of the waste is 8.5, as determined in a mixture of equal parts <br />by weight of sample and water. As the concern here is apparently <br />the formation of calcium hydroxide from calcium oxide, I believe <br />the above procedure would assure that any waste would exist <br />almost entirely in the calcium carbonate form (limerock) and, <br />as such, not be of concern. <br />I would appreciate your confirmation of the above definition <br />of neutralization for engineering the neutralization system. <br />As we have discussed, I believe this can be accomplished using <br />flume and/or CO2 gas scrubber wash water as a neutralizing <br />agent. <br />Item 3. Background Soil Tests: <br />Holly Sugar will arrange with a laboratory to perform the <br />described tests. <br />Item 4. Upgrade of Spill Containment and Chemical Storage Areas: <br />As discussed with Mr. Azevedo, Holly Sugar will work with <br />DHS-TSCD on proper containments. A chemical storage area has <br />been constructed with an impermeable base and fence. A roof <br />will be installed in the near future. <br />A sheet metal apron is currently being constructed around <br />the main oil storage tank to capture any oil which weeps from <br />the seams of the riveted construction tank. Additionally, a <br />check valve is being installed on the end of the oil truck <br />unloading line to prevent any leaking during unloading. Plastic <br />will be installed under the unloading station to prevent oil <br />from reaching the soil. <br />Containment systems for acid and caustic tanks are being <br />analyzed, as well as the fuel oil tank. Additional time will <br />also be needed in this area. <br />Item 5. Characterize and Dispose of Contaminated Materials <br />at = Corn Syrup ant: <br />Characterization is complete, and Holly has contracted <br />with American Environmental for removal of all wastes. <br />