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Sampling Plan - 6 - 25 March 2022 Stockton Propeller, Inc. 2478 Wilcox Road, Stockton was made public on 18 February 2022. SPI's GeoTracker page can be found https://geotracker.waterboards.ca.gov/profile report.asp?global id=T10000017618. Additionally, Section 2.1 states the USEPA Enforcement and Compliance History Online (ECHO) database does not identify any investigations or enforcement actions against SPI. SJCEHD referred the Site to the California Occupational Safety and Health Administration (Cal-OSHA) and the San Joaquin Valley Air Pollution Control District (SJVAPCD) for further investigation. SPI may have citations or violations from these entities. Requested Action: Revise the SAP to clarify the Site is an "Open Site" requiring "Site Assessment" on GeoTracker. Please rerun the ECHO report to clarify all investigations and enforcement actions from other entities, such as Cal-OSHA and SJVAPCD. COMMENT 8 Issue: Section 2.1, Previous Investigations, discusses previous inspections by SJCEHD, but neglects to discuss the results of the May 2021 investigation and citations. As a result of the May 2021 investigation and as discussed in the introduction to this letter, the SJCEHD cited two (2) Class I violations, 19 Class II violations, two (2) repeat violations, and SJCEHD issued a Sewage Disposal Notice to Abate directing SPI to immediately cease disposal of hazardous waste. Additionally, SPI may have been cited for violations from the Cal-OSHA and the SJVAPCD. Requested Action: Revise the SAP to include a discussion of all the violations SPI has received. COMMENT 9 Issue: Section 2.2, Current Investigations, discusses the results of the DTSC samples collected on 3 June 2021. The SAP identifies nine (9) of the 13 samples were characterized as either toxic or corrosive. The DTSC issued an Addendum to the Sampling Report (Addendum) on 7 December 2021 (DTSC, 2021 b). The Addendum also identified sample number SP-04B as exhibiting characteristics of reactivity. Additionally, the section does not clarify that only one (1) sample was sampled for cyanide (SP-04B) and two (2) samples were sampled for chromium VI (SP-04B and SP- 05B). Please note that the DTSC Sampling Report incorrectly states two (2) samples were analyzed for cyanide. Requested Action: Revise the SAP to include the information presented in the DTSC Addendum report and clarify the correct number of cyanide and chromium VI samples collected by the DTSC.