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8/15/22, 1:19 PM GeoTracker
<br /> SJCEHD, the City of Stockton clarified the*questionable procedures*by stating they observed the etching spent wastewater and penetrant
<br /> 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.
<br /> On 18 May 2021,the SJCEHD conducted a Small Quantity Hazardous Waste Generator Inspection and collected Site photographs. The
<br /> SJCEHD cited two(2)Class I violations, and 19 Class II violations, as defined by California Code of Regulations title 22, section 66260.10 and
<br /> Health and Safety Code section 25110.8.5,which relate to the generation,tracking, and disposal of hazardous wastes.The SJCEHD also
<br /> observed the waste disposal into the on-Site septic system via submersible pumps and garden hoses. Mr. Mike Belmont, SPI Service Manager,
<br /> stated that the Site disposes of Ardrox(penetrant), NuEtch E3 (potassium hydroxide solution), and DeSmut NS3(sulfuric and nitric acid)
<br /> wastewater, as well as spent NuEtch E3 and Desmut NS3 pure solutions to the on-Site septic system. Mr. Belmont also stated that SPI
<br /> discharges five(5)gallons a day of industrial wastewater to the septic system.
<br /> On 27 May 2021, SJCEHD conducted a Site visit and observed that SPI had dismantled the pump and garden hose to the on-Site septic system.
<br /> Instead, SPI was storing the Sites waste solution in a 55-gallon container while awaiting laboratory analysis of a sample collected by SPI*s
<br /> Environmental Health and Safety Manager. SJCEHD issued a Sewage Disposal Notice to Abate directing SPI to immediately cease disposal of
<br /> hazardous waste to the septic system .
<br /> On 3 June 2021, the California Department of Toxic Substances Control (DTSC)Office of Criminal Investigations (OCI)collected 13 samples to
<br /> investigate the potential illegal storage,treatment, and disposal of hazardous waste by SPI (OCI Case#15242). Several samples exceeded the
<br /> California Code of Regulations hazardous thresholds for chemicals, including six(6)samples that were characterized as toxic, one(1)sample
<br /> that exhibited the characteristics of reactivity, and three(3)samples that were characterized as corrosive.
<br /> During the 3 June 2021 DTSC sampling event, Mr. Belmont identified four(4)containers that he said were normally emptied into the on-Site
<br /> septic system. Similar to statements made to the SJCEHD, Mr. Belmont told the DTSC staff that two of these containers were used to store the
<br /> rinse water SPI uses after dipping metal plane parts into pure solutions such as NuEtch E3 (strong base), DeSmut NS3 (strong acid), and Ardrox
<br /> (penetrant)solutions, and that after the rinse water barrel gets full, *they pH the rinse water**and dispose of it into the septic system. Mr.
<br /> Belmont claimed that by mixing the spent solutions of NuEtch E3 and DeSmut NS3 together,the pH of the strong acid and strong base would be
<br /> neutralized.Additionally, Mr. Belmont told the DTSC staff the other two containers disposed of into the septic system are the spent solutions of
<br /> NuEtch E3 and DeSmut NS3.
<br /> The DTSC collected samples from the two(2)rinse containers(sample numbers SP-03 and SP-10A/B)and from the pure solution containers of
<br /> 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
<br /> as toxic.The DTSC also collected additional samples from containers that were improperly disposed of into the trash or heated to accelerate
<br /> evaporation of their contents to the atmosphere. These samples were classified as toxic(SP-04A, SP-05A, SP-07, SP-08, SP-09), reactive(SP-
<br /> 04B), or had no exceedances(SP-06).
<br /> On 8 November 2021, Central Valley Water Board staff issued an initial contact letter to the property owners (Wiley and Shawna Lynn Chandler),
<br /> the Environmental Health and Safety Manager of VRC Metal Systems(VRC Metals;At the time, VRC Metals was acting on behalf of SPI. Robert
<br /> Hrabe is part owner of both VRC Metals and SPI. It has since been clarified that VRC Metal does not own or operate SPI, but has provided some
<br /> assistance to SPI at the request of Mr. Hrabe), and Mike Belmont. The letter identified Central Valley Water Board staff*s interest in overseeing
<br /> the investigation and potential cleanup of the Site and requested enrollment in a Cost Recovery account.
<br /> On 18 November 2021, Central Valley Water Board staff met with SPI and VRC Metals and requested a work plan and a sampling and analysis
<br /> plan designed to investigate the potential impacts to the septic system, leach field soils, and groundwater. Consistent with his statements to the
<br /> SJCEHD and DTSC, Mr. Belmont stated to Central Valley Water Board staff that he estimates approximately five(5)gallons of SPI*s
<br /> wastewater was disposed of into the septic system per day since 2005(approximately 16 years). SPI notified Central Valley Water Board staff
<br /> that the septic tank was near capacity and required pumping but would continue to be evaluated over the next couple of weeks
<br /> On 6 December 2021, Central Valley Water Board staff approved, through email, SPI*s request to empty approximately 25 percent of the
<br /> contents of the septic tank to allow extra time for SPI to submit a work plan/sampling and analysis plan.
<br /> On 22 December 2021, Mr. Hrabe reported, through a letter addressed to the City of Stockton Municipal Utilities Department, several instances of
<br /> potential unauthorized septic tank pumping. SPI had not yet pumped the approved 25 percent of the septic tank contents.The following are direct
<br /> quotes from Mr. Hrabe*s letter:
<br /> a)24 November 2021:*an unknown waste-water company came onsite and may have pumped contents from the property*s septic system*,
<br /> as witnessed by my employees. We did not schedule this to be done.*
<br /> b) 1 December 2021:*our employees observed and inspected the properties septic system. They observed it to be full.*
<br /> c) 14 December 2021:*our employees observed and inspected the property*s septic system. They observed it to be close to empty.*
<br /> d)21 December 2021:*our employees observed and inspected the property*s septic system. They observed it to be full.*
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