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Draft Sampling &Analysis Plan - 8 - 13 July 2022 Stockton Propeller, Inc. 2478 Wilcox Road, Stockton and garden hoses engineered through the ceiling to dispose of these wastes to the on- Site septic system (SJCEHD, 2021 b). On 27 May 2021, the SJCEHD issued a Sewage Disposal Notice to Abate to SPI to cease disposal of these wastes to the septic system. Therefore, these wastes were being disposed of into the septic tank after February 2021 and could not have ceased prior to May 2021. Additionally, Section 2.1- Site History states SPI removed the sink from the Etch Room in February 2021. The sink was present during the SJCEHD inspection in May 2021; therefore, the sink was not removed in February 2021. Requested Action: Revise Sections 1 and 2.1 to clarify whether SPI ceased disposing of Ardrox Dye Penetrant and etching liquids to the septic system in May 2021. Additionally, please correct the date the sink was removed from the Etching Room. COMMENT 16 Issue: Table 1- Brief Timeline of SPI Investigations and Enforcement Actions and Section 2.2.2- City of Stockton states the City of Stockton staff found "industrial waste was being washed down a sink in the Etching Room". During an industrial waste survey on 6 January 2021, the City of Stockton "ff]ound several questionable procedures and active discharging to [the] County septic tank" (City of Stockton, 2021 a). The City referred the Site to the SJCEHD. In an email on 1 February 2021 to the SJCEHD, the City of Stockton clarified the `questionable procedures' by stating they observed the etching spent wastewater and penetrant fluid being disposed of via a submersible pump and garden hose running up the wall and into the ceiling and out to the on-Site septic system (City of Stockton, 2021 b). The City of Stockton did not identify wastes being disposed of through the Etching Room sink. The SJCEHD took photos of wastes being collected in a bucket beneath the sink in the Inspection Room and garden hoses coming out of two separate buckets and up through the ceiling (one in the Inspection Room and one in the Etching Room; SJCEHD, 2021 b). It is unclear if the wastes were being disposed of through both the garden hoses engineered through the ceiling into the septic tank and the Etching Room sink or if the wastes were disposed of only through the garden hoses. Additionally, Central Valley Water Board staff requested SPI provide a detailed description of operations at the Site, including the locations of where these operations are conducted within the building, in the Site Audit and Chemical Storage and Use Questionnaire as part of the Order (Central Valley Water Board, 2022b). SPI submitted Exhibit 7 in response to this request. However, Exhibit 7 includes the same Site figures presented by Central Valley Water Board staff in the Order. This unfortunately, does not provide additional details, including the location of the sinks in the Inspection and Etching Rooms or other pertinent Site features. Requested Action: Please clarify how the Ardrox (penetrant dye) and etching liquids (NuEtch E3 and DeSmut NS3) were disposed of to the on-Site septic tank and revise the Final SAP to acknowledge waste disposal via submersible pumps and garden hoses