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the beets were washed. The wash water contained soil and other substances (possibly agricultural chemicals) and was transported to four 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 Sugar site, the beet pulp was dried and stored in the pulp warehouse pending use as cattle feed. Several different feedlots were also present on the Spreckels Sugar site 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 then 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 pumped out to storage in the lime ponds, located north of the subject property. 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. The thickened juice was then sent through a series of centrifuges to crystallize out the sugar. The sugar was then dried in granulators and stored in the sugar warehouse or silos, or ground into powdered sugar. The sugar produced at the Spreckels Sugar site was shipped offsite in bulk. The various heating and evaporating processes utilized steam produced by boilers located onsite. The boilers onsite were fired using fuel oil and/or natural gas. The heated water was cooled in cooling towers, which were reported to have never used hexavalent chromium as a scale inhibitor. Process water generated during the manufacturing process was discharged to the wastewater ponds located on the subject property and northeast of the subject property. 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 also grown onsite. 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 of the facility. Maintenance activities at the Spreckels Sugar site also included the repair of motor vehicles such as cars and farm machinery, and the maintenance of locomotives operated onsite by the Spreckels Sugar Company. The locomotive maintenance was not conducted at a specific location but was done on the tracks wherever necessary. The Spreckels Sugar site 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 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 portions. Project No. 297376 AEI June 22, 2011 Page 13 Consultants