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Draft Sampling &Analysis Plan - 7 - 13 July 2022 Stockton Propeller, Inc. 2478 Wilcox Road, Stockton COMMENT 13 Issue: The Draft SAP neglects to provide a map showing the locations of the soil and groundwater boring locations. Additionally, the Draft SAP neglects to state whether the soil and groundwater boring global positioning system (GPS) locations will be recorded and reported in the SI Report. Required Action: Revise the Final SAP to include a map showing the proposed location of the soil and groundwater boring locations. To expedite finalization of the SAP, Central Valley Water Board staff request to be consulted on the location of the groundwater borings prior to submitting the Final SAP. Additionally, revise the Final SAP to include the collection of GPS locations of the borings. Upon sample completion, an electronic deliverable format (EDF) that contains all boring locations and sampling results will also need to be uploaded to the GeoTracker case page. COMMENT 14 Issue: Section 1- Introduction and Section 2.1- Site History state SPI's septic tank is connected to the building south of SPI. The building is occupied by Formurex, a pharmaceutical manufacturing facility. However, Section 3.2- SPI Septic Tank states the connectivity to SPI's septic tank and Formurex is unknown and requires further investigation. According to a letter Robert Hrabe wrote to the Central Valley Water Board on 11 February 2022, SPI and the property owners met to discuss the function and usage of the SPI's septic system. The property owners shared a map with the locations of several septic tanks on the property, including a septic tank located south of the Formurex building. Central Valley Water Board staff identified the septic tank locations on Figure 2 of the Order. However, Section 3.2 states the location of the septic tank south of Formurex was unable to be located during a site reconnaissance by Blankinship. Therefore, the connection between Formurex and SPI's septic tank is unknown. Required Action: Revise Sections 1 and 2.1 in the Final SAP to state the connection between SPI's septic tank and Formurex is unknown and requires further investigation. The findings of this investigation shall be reported in the SI Report. COMMENT 15 Issue: Section 1- Introduction and Section 2.1- Site History state SPI ceased disposing of Ardrox (penetrant dye) and etching liquids (NuEtch E3 and DeSmut NS3) to the septic system in February 2021. The SJCEHD conducted a Small Quantity Hazardous Waste Generator Inspection on 18 May 2021 (SJCEHD, 2021 a). During the inspection, Mr. Mike Belmont stated the spent Ardrox (penetrant dye), NuEtch E3 (strong base- potassium hydroxide), and DeSmut NS3 (strong acid- sulfuric and nitric acid) solutions were treated as non-hazardous waste. The SJCEHD staff observed submersible pumps