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The wastewater ponds formerly located on the Spreckels Sugar site were permitted under 1961 Waste Discharge requirements. In 1977, these requirements were revised for the existing ponds. The waste discharge requirements outlined specific monitoring of the ponds, influent, effluent and groundwater. Monitoring was primarily for dissolved oxygen, temperature, pH, TDS, biological oxygen demand (BOD), chemical oxygen demand (COD), specific conductivity (EC) and flow. Most of the Spreckels Sugar site's wastewater ponds were decommissioned in the late 1970s or early 1980s due to the construction of the adjacent California Highway 120 bypass. Most of the highway project material was used as fill on the Spreckels Sugar site. 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 to one million gallons per day. Since the Spreckels Sugar factory ceased sugar production in August 1995, almost all of the water present in the wastewater ponds circa 1995 through 2002 had accumulated from storm water runoff. The subject property is located in the east central portion of the former Spreckels Sugar site. The majority of the subject property was formerly occupied by wastewater ponds. A disposal area, known as Site B, which contained miscellaneous concrete rubble and a small amount of lime waste was also located in the south-central portion of the subject property. Discussion of the subsurface investigations performed in relation to these features follows. According to a previous report entitled, Closure Report: Disposal Areas B and C, Former Spreckels Sugar Plant No. Z, 18800 South Spreckels Road, Manteca, California by Kleinfelder and dated September 9, 1999, the Site B disposal area of the former Spreckels Sugar site was approximately 270 feet long and 50 feet wide by an average of 12 feet deep and contained an estimated 2,800 cubic yards of debris, soil, and lime. At the time of Kleinfelder's subsurface investigation, monitoring well MW-7 was already present on the subject property. Between June 11 and 18, 1999, 5,000 yards of soil and debris were excavated from Site B. Debris included plastic sheeting, wood, wire, and concrete. Concrete was estimated to be about 70 percent of the debris material. A strip of slaked lime was observed near the southeastern portion of the excavation measuring 150 feet long and 15 feet wide. The slaked lime was encountered at depths ranging from 8 to 10 feet bgs. Soils encountered included silt and clayey silt with slaked lime material. A small area of apparently discolored dark gray material was also noted just above the slaked lime with a strong organic odor. A greenish-gray colored soil was noted below the slaked lime at depths ranging from 10 to 20 feet bgs. These colors surrounding the lime were common in their occurrence throughout the Spreckels Sugar site due to degradation of vegetation in the lime. Soil was not excavated from Site B at depths greater than 20 feet bgs. Two groundwater samples and one soil sample were collected from Site B under the direction of Mr. Robert McCallum of the San Joaquin County Public Health Services Department Environmental Health Division (PHS/EHD). Laboratory analysis of the groundwater samples collected from Site B indicated the following analytes and their reported concentration ranges at or above laboratory reporting limits: copper at 0.0190 milligrams per liter (mg/1), manganese at Project No. 297376 AE1 June 22, 2011 Page 14 Consultants