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of concern. Based on these results, Kleinfelder recommended no further investigation for the
<br /> wastewater and mud ponds. According to URS, in response to these results, the RWQCB
<br /> concurred that no further investigation was needed within the areas of the former mud and
<br /> wastewater ponds and rescinded the Waste Discharge Requirements for the wastewater and
<br /> mud ponds. According to information reviewed at the RWQCB, the wastewater pond areas of
<br /> the former Spreckels Sugar site were classified by the RWQCB as "clean-closed" in 2002. In
<br /> addition, because the ponds were 'clean-closed," a deed restriction was not placed on the
<br /> former wastewater ponds.
<br /> According to a report entitled Limited Phase IT Soil Assessment, Railroad Spurs, Phase I ESA
<br /> Recommendation No. 21, Former Spreckels Sugar Plant No. 2, by Kleinfelder, Inc., (February 4,
<br /> 1997), Kleinfelder collected soil samples along the railroad spur that formerly traversed the
<br /> Spreckels Sugar site in a north-south direction. Soil samples collected were analyzed for
<br /> metals, TPHd, lube oil, herbicides, and SVOCs. Elevated levels were detected in one area
<br /> sampled. Kleinfelder wrote that discussions were ongoing with SJCEHD regarding closure.
<br /> According to a 1999 Phase I ESA by Dames & Moore, during a conversation with Mr. Ron Rowe
<br /> of the SJCEHD, a limited quantity of soil (approximately 3 square feet) was being removed from
<br /> the site in November 1999. Following that removal, Mr. Rowe stated that he was willing to
<br /> issue a formal closure letter. According to a 2001 Phase I ESA by URS Corporation, Ms.
<br /> Margaret Lagorio of the SJCEHD stated that the SJCEHD was requiring no further action
<br /> regarding the lead detected in the soil at the railroad spur.
<br /> Based on this information, the removal of the former railroad tracks, and the fact that the area
<br /> of the former rail spur is currently paved over, prohibiting any direct contact with near surface
<br /> soils, the former railroad spur located on the subject property circa 1917-1995 is not expected
<br /> to represent a significant environmental concern.
<br /> According to Mr. Ross Atkinson of the RWQCB and the documents reviewed at the RWQCB, the
<br /> entire former Spreckels Sugar site received case closure in June 2008. In should be noted that
<br /> the closure letter entitled, Rescission of Waste Discharge Requirements Order No. R5-2003-
<br /> 0024 and dated June 13, 2008, is not a typical case closure letter. However, it is stated within
<br /> the letter that "further remedial action is not necessary" (A copy of this letter is included within
<br /> Appendix Q. Closure was granted to the site because the source of the contamination had
<br /> been removed. In addition, groundwater quality measured in downgradient monitoring wells
<br /> had been improving since the discharge to the ponds ceased in 1995. Well sampling
<br /> immediately downgradient (northwest) of the former wastewater ponds had also shown large
<br /> decreases in constituents of concern in the initial five to seven years after the discharge had
<br /> ceased. Since 1995, the constituents of concern were noted to have become almost stable,
<br /> improving not at all or only slightly on a year-to-year basis; however, groundwater located
<br /> northwest of the former Spreckels Sugar site and in the northwest portion of the former
<br /> Spreckels Sugar site was noted to still have concentrations of salts, bicarbonates and TDS
<br /> greater than background levels.
<br /> Based on this information, including the case closure status for the former Spreckels Sugar site,
<br /> the subject property's historical use by the Spreckels Sugar Company is not expected to
<br /> represent a significant environmental concern. Nevertheless, it should be noted that low levels
<br /> of metals, toluene, 1,2,4-tri methyl benzene, total cyanide, and total xylenes in the soil and/or
<br /> groundwater may remain present in the northern-central portion (former Site B area) of the
<br /> subject property. In addition, in the event of any groundbreaking activities at the subject
<br /> Project No. 297376 AE1
<br /> June 22, 2011
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