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KLEINFELDER Sugar beets were transported from the farm to the processing plant via trucks and railcar. The loaded trucks and railcars were weighed at the scales, and the beets were unloaded at the unloading station. The Spreckels Manteca plant most recently used a series of conveyors, but formerly utilized an underground beet flume which utilized water to transport the beets from the unloading area to the factory. After unloading the beets were washed. The wash water contained soil and other substances (possibly agricultural chemicals) and was transported to the mud ponds for disposal. After washing, the beets were sliced and placed into the diffusion towers. The diffusion towers used hot water to remove the sugar from the beets. The beet pulp was then separated from the raw sugar water. At the Spreckels Manteca plant, the beet pulp was dried and stored in the pulp warehouse pending use as cattle feed. Several different feedlots have been present on the Spreckels property for this purpose since the plant was constructed. Prior to the installation of pulp dryers, the wet pulp was pumped into a large holding pond, formerly located to the east of the existing pulp warehouse, and allowed to dry prior to use as cattle feed. The pulp dryers were installed to reduce odors emanating from the plant. The raw sugar water or "juice" was purified by adding "milk of lime" and carbon dioxide to precipitate out the impurities. The milk of lime is produced by "calcining" the lime in the lime kiln and then adding water. The kiln was lined with a refractory material to withstand the high operating temperatures. The "used" lime was regenerated for reuse by activated carbon. Eventually the spent lime was disposed of at the lime ponds. After the precipitation of impurities using lime, the raw sugar juice was passed through a series of filters to further purify it. Sulfur dioxide was used to inhibit discoloration of the sugar. After filtering, the raw sugar juice was sent to the evaporators to thicken it. The thickened juice was then sent through a series of centrifuges to crystallize out the 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. 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. 20-3978-01.W32/2017P 110 Page 2 of 7 1997 Kleinfelder,Inc. August 28, 1997