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' KLEINFELDER ' outlined specific monitoring of the ponds, influent, effluent and groundwater. Monitoring was primarily for dissolved oxygen, temperature, pH, total dissolved solids (TDS), biological oxygen demand (BOD), chemical oxygen demand (COD), specific conductivity (EC) and flow. Most of the waste water ponds were decommissioned in the late 1970's or early 1980's due to the construction of the adjacent Highway 120 bypass. Most of the material was used as fill on the Spreckels site. The former waste water pond levees were used for ' constructing the Highway 120 Bypass. The wastewater ponds that were decommissioned were no longer necessary due to the construction of additional cooling towers and clarifiers which reduced wastewater discharge from approximately three ' million gallons to one million gallons per a day. The Spreckels factory stopped sugar production in August 1995. Since that time, ' almost all of the water in the wastewater ponds has been from stormwater runoff. On February 27, 1996, John M. Minney of Madera Ranchos, California composed a closure plan for the lime ponds on site. The closure of the remaining ponds on site was not addressed. The plan was very general and did not discuss the specifics for the closure. On August 19, 1996, the RWQCB responded to the April 24, 1996 closure plans by John Minney. In the review letter, the RWQCB stated that the closure plan by Mr. Minney was incomplete, and requested a detailed Report of Waste Discharge and a detailed Closure Plan for their review. Over the course of eight days (December 26, 1996, and January 8-9, 20-23, and 29, 1997), soil and sludge sampling was performed in the following areas by Kleinfelder: 1) The four (4) former lime ponds, 2) The four (4) former mud ponds, 3) The active onsite wastewater pond, 4) The orchard area (background). During the field work, Kleinfelder personnel collected a total of 58 soil samples from 13 borings. Samples were collected by means of both a truck-mounted drill rig and a hand ' auger/sampler. Thirty-five (35) samples were subsequently analyzed either individually or as part of a composite sample. Based on the results of the investigation as well as a statistical analysis of historical groundwater monitoring events, Kleinfelder ' recommended the 1997 WDRs be rescinded and no further investigation or cleanup in our April 7, 1997 report titled "Pond Closure Investigation and Related Groundwater Services....." 20-3978-03.MN7/ST08R117 February 1,2008 C 2008 Kleinfelder Page 7 of 19