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Memorandum � CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD . CENTRAL VALLEY REGION 3201 S Street Sacramento, California 95816 Phone: 445-0270 r TO: Antonia Vorster FRO Richard Azevedo Senior Engineer Project Engineer DATE: 17 April 1986 SIGNATURE: _ SUBJECT: TECHNICAL REPORT, HOLLY SUGAR, SAN JOAQUIN COUNTY On 20 February 1986 our office notified Holly Sugar-Tracy of several violations and threatened violations of their existing permit which were noted during a previous complaint inspection. Holly Sugar was requested to submit a technical report addressing these deficiencies by 1 April 1.986. On 17 March 1986 Holly Sugar submitted the requested report. Comments on the report are as follows: Calcium Oxide Wastes Twice yearly, at the end of their spring and fall processing (campaigns) Holly Sugar land disposes approximately 50 tons of combined calcium carbonate/oxide wastes from their lime kiln. The pH of this waste is approximately 12. Since a pH of 12. 5 is considered a ' hazardous waste' by the Department of Health Services staff recommended neutralization of this wase prior to disposal . Holly Sugar has tentatively identified a portion of their existing process that may be suitable for neutralizing this waste. Prior to actually designing the system, Holly Sugar has requested clarification of the term "neutralization". Consistent with Discharge Specification A.2 of Holly Sugar's Waste Discharge Requirements Order No. 71-22, pH of the final waste should fall in the range of 6.5 - 8.5, a target pH of 7.0 is suggested. Holly Sugar has requested a one month extension to design the system. Since disposal of the calcium oxide waste will not occur until July 1986, a month delay should not adversely impact the implementation of the system prior to July 1986. Holly Sugar should submit the neutralization system design and all necessary design information including alkalinity of the waste, neutralization calculations, amounts of waste and neutralizing compounds, flow rates and an effluent monitoring program. This system or an acceptable alternative disposal plan must be installed and operable prior to the end of the spring campaign. Corn Syrup Plant Characterization of the waste has been completed and Holly Sugar has contracted with American Environmental (AE) to remove the wastes at the corn syrup giant. In order to properly classify the waste and evaluate any proposed disposal option Holly Sugar should, prior to disposal , submit a complete waste character-