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KLEINFELDER ' sugar. The syrup left after crystallization is molasses. The sugar was then dried in granulators and stored in the sugar warehouse or silos, or ground into powdered sugar. According to Mr. Tucker, the sugar produced at the Manteca plant was shipped off site in bulk. 1 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 contained 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 were also spread on the feedlot where cattle consumed the edible portion. 3.2. BACKGROUND ON LIME POND AREA Since its construction in 1917, the Manteca Sugar Factory has been operated by Spreckels Sugar Company (Spreckels). As noted above, above-grade waste water ponds collected wash water, waste water and process water from the sugar refining operation. Process water generated during the sugar refining and plant operation was ' discharged to the waste water ponds. Additionally, there are two small "finger ponds" on site where the water was used for irrigation. The waste water ponds on site were permitted under 1961 Waste Discharge requirements. In 1977, the Waste Discharge Requirements (WDRs) were revised for the existing ponds (RWQCB Order No. 77-247). The waste discharge requirements 20-3978-03.MN7/ST08R117 2008 February 1, 0 2008 Kleinfelder Page of 08