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Sampling Plan - 2 - 25 March 2022 Stockton Propeller, Inc. 2478 Wilcox Road, Stockton SJCEHD issued a Sewage Disposal Notice to Abate directing SPI to immediately cease disposal of hazardous waste. On 3 June 2021, the California Department of Toxic Substances Control (DTSC) Office of Criminal Investigations (OCI) collected 13 samples as evidence in support of an investigation into alleged illegal storage, treatment, and disposal of hazardous waste by SPI (DTSC, 2021 a). Several samples exceeded the California Code of Regulations hazardous thresholds, including six (6) samples that were characterized as toxic, one (1) sample that exhibited the characteristics of reactivity, and three (3) samples that were characterized as corrosive. SPI identified two (2) containers that were normally emptied into the on-Site septic system. These containers included the rinse water SPI uses after dipping the metal plane parts in pure solutions, such as NuEtch E3 (strong base), DeSmut NS3 (strong acid), and Ardrox (penetrant) solutions. The DTSC collected samples from the two (2) containers (sample numbers SP-03 and SP-10A/B) and from the pure solution containers of NuEtch E3 (SP-01) and DeSmut NS3 (SP-02). Samples SP-01, SP-02, and SP-03 were characterized as corrosive and SP-02 was characterized as toxic. SPI's Service Manager, Mike Belmont, estimated approximately five (5) gallons per day of the rinse water were disposed into the septic system since 2005 (16 years). SPI has since stopped disposing hazardous waste into the on-Site septic system. On 20 December 2022, SPI collected two (2) composite samples from the septic tank. The laboratory detected concentrations of cadmium and lead above the United States Environmental Protection Agency (USEPA) maximum contaminate level (MCL), and concentrations of copper, vanadium, and zinc above the San Francisco Bay Regional Water Quality Control Board (SFBRWQCB) Tier 1 Environmental Screening Levels (ESLs). Central Valley Water Board staff has the following comments. COMMENT 1 Issue: On 18 November 2021 , Central Valley Water Board staff met with SPI and VRC Metals staff. Central Valley Water Board staff requested a work plan/sampling and analysis plan to further investigate the potential impacts to the septic system, leach field soils, and groundwater. The SAP proposes to drill six (6) boreholes to sample the soils surrounding the septic tank. However, the SAP neglects to locate and sample the leach field, septic tank, and groundwater. SPI collected two (2) composite samples from the septic tank on 20 December 2021. Prior to the collection of these samples, SPI staff observed a drop and rise of several feet in the contents of the septic tank in mid-December. SPI and the Property Owners have denied pumping or tampering with the septic tank. Therefore, it is unclear why the