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Document 2137978
1 2 3 4 5 RODI POLLOCK PETTKER CHRISTIAN & PRAMOV, A Law Corporation ROBERT A. YAHIRO (SBN 69560) 444 South Flower Street, Suite 1700 Los Angeles, California 90071 -2901 Telephone: (213) 895 -4900 Facsimile: (213) 895 -4921 Attorneys for JAMES M. GALBRAITH, Petitioner 6 7 BEFORE THE STATE WATER 8 RESOURCES CONTROL BOARD 9 STATE OF CALIFORNIA 10 ó 2 ° o Cl- o6 N Z < pZ co 11 s F- 'N.O' N óJ v W°Ud oZ K 13 14 2uu' W V aQFW ó ó CL g óZH Q ó Petitioner, 12 IN RE: LOS ANGELES REGIONAL WATER QUALITY CONTROL BOARD ORDER NO. R4- 2012 -0069 Ó i-11V.3 vo,_ .M Ce {(J James M. Galbraith, vs. Los Angeles Regional Water Quality Control Board, 15 Respondent. SUPPLEMENTAL PETITION OF JAMES M. GALBRAITH, PURSUANT TO CALIFORNIA WATER CODE SECTION 13320(a) AND CALIFORNIA CODE OF REGULATIONS, TITLE 23, §§ 2050 ET. SEQ. 16 v 17 I, JAMES M. GALBRAITH, Petitioner in the above -entitled matter, pursuant to California 18 Water Code Section 13320(a) and California Code of Regulations, Title 23, §§ 2050 et. seq., do 19 hereby petition the State Water Resources Control Board (the "Board ") to review the Order and 20 Revised Order referenced herein. This Supplemental Petition supplements and incorporates my 21 earlier Petition to the Board in this matter. In support of this Supplemental Petition, I hereby 22 declare as follows: 23 24 25 26 27 28 1. I am a resident of the State of California. I have personal knowledge of the matters set forth herein and if called upon as a witness could and would testify as follows: 2. I am 70 years old and reside at 1640 Oak Grove Avenue, San Marino, California. My telephone number is (626) 799 -1111. 3. On or about June 20, 2013, I received a copy of letter from LARWQCB. The letter was addressed to Mr. Jim Saselli, Senior Aerospace SSP. A copy of the LARWQCB letter is 1 attached hereto as Exhibit A. Accompanying the letter was LARWQCB Revised Order No. R4- 2012 -0069 -A01 2 4. 3 ("Revised 4 Corporation, William Zimmerman, and me to prepare and submit a work plan to conduct a 5 subsurface soil investigation to determine if any unauthorized release of heavy metal compounds 6 has impacted soils that could pose a threat to groundwater beneath the site located at 2980 San 7 Fernando Boulevard, Burbank, California (the "Site "). A copy of the Revised Order is attached 8 hereto as Exhibit B. 9 5. Order "). The Revised Order requires Senior Aerospace SSP, Breeze-Eastern The Revised Order, at paragraph 2, states in part that "The Site is currently owned 10 by First Industrial Real Estate, Inc. of Chicago, Illinois, who reported that Mr. William 11 Zimmerman and Mr. James Galbraith were the first owners/operators of Stainless Steel 12 Products/Industries at the Site." This statement is false and it cannot be substantiated. As such, 13 this statement is an untenable basis for the issuance of the Order and Revised Order to me. As Jv Úz;o 14 stated below, I had no ownership or any positions in, and I received no compensation from, aQFW 15 Stainless Steel Products, Inc., which was a former owner/operator at the Site. o 16 ó o "°" z ° w°o .).2 =PWZc. üJ RU Ó CO 7 JÓ g 6. The Order and the Revised Order were sent to me without any prior notice and 17 without an administrative hearing before LARWQCB. Therefore, I did not have any opportunity 18 to present objections to LARWQCB prior to the issuance of the Order and the Revised Order. 19 7. I am an inactive attorney. In large part due to health reasons, I retired from the full - 20 time practice of law in 1979, and became part -time of counsel to my law firm in 1982. Prior to 21 my full -time retirement, my law firm's business clients included Zimmerman Holdings, Inc. 22 ( "Holding 23 corporations. The corporate histories of the two corporations are complex and may be confusing. 24 A diagram depicting the separate corporate histories is attached as Exhibit C. 25 8. Company ") and Stainless Steel Products, Inc. ("Operating Company "), both California There were two separate and distinct California corporations at different times 26 named "Stainless Steel Products, Inc." Stainless Steel Products, Inc. was incorporated in 27 California in 1971, under entity number 627765, originally as "SSP Products, Inc." ( "Operating 28 Company "). A copy of the Articles of Incorporation for the Operating Company is attached hereto as Exhibit D. The Operating Company changed its corporate name in 1981 to "Stainless Steel Products, Inc." A copy of the Certificate of Amendment of Articles of Incorporation for the Operating Company is attached hereto as Exhibit E. The Articles of Incorporation and Certificate of Amendment consistently show the entity number "627765," indicating this is the same corporate entity. The Operating Company is the corporation that conducted business and was an owner /operator at the Site. 9. I was a part-time attorney in 1980 when a client of my law firm anticipated acquiring the Operating Company. To complete the acquisition, a corporation was formed under entity number 1003018, initially under the name "Stainless Steel Products, Inc." ("Holding Company"). A copy of the Articles of Incorporation for the Holding Company is attached hereto as Exhibit F. As an accommodation to the client, I was nominally appointed as corporate secretary for the Holding Company in 1980. 10. The Holding Company changed its corporate name in 1981 to "SSP, Inc." In 1982 it changed its corporate name a second time to "Zimmerman Holdings, Inc." Copies of the Certificates of Amendment of Articles of Incorporation for the Holding Company are attached hereto as Exhibits G and H. The Articles of Incorporation and two Certificates of Amendment consistently show the entity number "1003018," indicating this is the same corporate entity. 11. To the best of my knowledge, the Holding Company acquired the stock of the Operating Company in 1981 from a third-party seller. The Operating Company thus became a 100% -owned subsidiary company of the Holding Company, as shown on Exhibit C. 12. In 1982 I retired from the practice of law, in large part due to health reasons. In 1982 I also resigned as corporate secretary of the Holding Company. I have no recollection of performing any duties as corporate secretary. Except for my nominal position as corporate secretary for the Holding Company for approximately 24 months, I had no ownership or director or officer positions in, and received no compensation from, the Holding Company. I never had any ownership interest or director or officer positions in, and received no compensation from, the Operating Company. 13. To the best of my knowledge, in or about 2002, Holding Company filed for 3 bankruptcy protection, under Chapter 11 of the U.S. Bankruptcy Code (Zimmerman Holdings, Inc., United States Bankruptcy Court, Central District of California, Case No. 2:02 -bk -28981 (Judge Barry Russell)). All of the assets of the Holding Company were liquidated in bankruptcy, and its corporate existence was suspended by the California Secretary of State. 14. To the best of my knowledge, in or about 1995, the Operating Company sold its business and operating assets to an entity related to Senior Aerospace SSP. Thereafter, Operating Company had no assets, no business activities, and no employees. The corporate existence of the Operating Company was suspended by the California Secretary of State. 15. have no knowledge of, nor was I responsible in any way for, the use, storage, or I disposal of any hazardous wastes by either Operating Company or the Holding Company at the Site. 16. The Order and the Revised Order are inappropriate because I have no control or authority over either corporation or the Site and therefore cannot comply with the terms of the Order or Revised Order. 17. In addition, any involvement under the terms of the Order and Revised Order would be a severe financial burden and would jeopardize my physical health. For more than 35 years I have suffered from a chronic and debilitating condition known as Crohn's disease, as well as other auto - immune disorders. These disabilities allow me only a few good hours early in the day, after which I regularly deal with chronic Crohn's symptoms: nausea, pain, extreme fatigue, intestinal spasming, systemic inflammation, intestinal bleeding, loss of focus, joint pain, uveitis (inflammation of the vascular structures of the eye, which has caused near total blindness in one eye). This has prevented me from working, and I cannot be away from my home for more than a few hours at a time. 18. Based on a review of the Petition, this Supplemental Petition and the exhibits attached hereto, I request that the Board (a) find that I am not an owner /operator or responsible party with respect to the Site, (b) determine that the Order and the Revised Order are inappropriate with respect to me, and (c) direct the LARWQCB to rescind and withdraw the Order and Revised Order with respect to me. In the alternative, I request that the Board issue a stay of the Order and 1 the Revised Order to permit other parties in control of the Site to comply with the Order and the 2 Revised Order. 3 19. Because I did not have any opportunity to present objections to LARWQCB prior 4 to the issuance of the Order and the Revised Order, if the Board denies my request in whole or in 5 part, 6 argument. 7 20. 8 I I Executed on July 15 12 13 14 16 17 18 19 20 21 22 23 24 25 26 27 28 declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 11 15 A copy of this Supplemental Petition has been sent concurrently to the Executive Officer of LARWQCB. 9 10 request a hearing before the Board to consider testimony, additional evidence, and oral 597173.3 , 2013, at San Marino, California. Exhibit A Jun 24 2013 2:20PM James Galbraith 626 -795-6870 page 1 Ennwe O. Br+eV* MOrTMM Rco.wtt ÿtw alPnM fyRP,DM Water Boards aMf .DM Los Ar4geles Regional Water Quality Control Board June 20, 2013 Mr. Jim Sasselll Senlbr Aerospace SSP 2980 North San Fernando Boulevard Burbank, California 91.504 SUBJECT: SITE; - Ja. CERTIFIED MAIL RETURN RECEIPT REQUESTED 7011 2910 0000 0645 3199 -REVISED' REQUIREMENT FOR TEttiN)CAL KEPORT PURSUANT TO' CALIFORNIA WATER CODE SECTION.13267 OBIER NO. R4- 20l2-0069 -.M. STAINLESS STEEL PRODUCTS/INDUSTRIES, BURBANK, CALIFORNIA (FILE NO. 104.1005) 2980 SAN FERNANDO BOULEVARD, Deari Mr. Sasselli: The California Regional Water Quality Control Board, Los Angeles'Reeion ( Regional Board) Is the public with primary responsibility for the protection of ground and surface water quality for all beneficial uses within major portions of the Angeles and.Ventura Counties, including the referenced. site. age* Is The Regional Board is investigating potentlal sources for groundwater pollution within the United States Environmental Protection Agency (USEPA) San Fernando Valley Superfund Site ( Superfund Site). It is known that groundwater within the Superfund Site, Including the vicinity of the Stainless Steel Prodrrcts/Indústries facility, Is contaminated with volatile organic compounds (VOCs) and heavy metals, partlsularly chromium. . staff has reviewed technical information and historical documents contained in Regional Board files for the pröperty lOeated at 2980 North San 'Fernando Boulevard, .the. City Burbank; Califs mia (the Site). Stainless Steel Products /industries ha.soccupied the Site since approximately 1952. Stainless Steel Products/Industries' operations at the site Included the use of hexavalent chromium, sadiLm dichromate and .chromic add in processes such as metal etching and metal finishing. Previous invesIigations were conducted at the Site, which focused ón VOCs and not heavy, metals. Therefore, the potential discharge and/or release of chromium based compounds to the soils at the Site, as a result of the past Stainless Steel Products/Industries operations, has not been determined. Regiqq'nal.Board . Enclosed is a Regional Board revised order for technical report requirements pursuant to California Water Code Section 13267 Order No. R4- 2012 - 0069 -A01 (Order). The Order was previously Issued to Breeaze- Eastern Corporation, Mr. William Zimmerman, and Mr. James Galbraith. The previously issued Orders overlooked Senior Aerospace SSP, the current Site operator. Therefore, the attached Order has been revised to include Senior Aerospace SSP and to provide you with additional time to comply with - -. MARIA MENw,wu+, cMuM I SAMUK UwOq. rxtounwa wn091.1 320 WMI 4th SR. SIM. 200, LOt AnpelH, CA 90013 i www.waMrbOifCa.pgOWlDaar>palas n I.MOVaam..VN1 Jun 24 2013 2:20PM James Galbraith 626 -795 -6870 M4Jim Sasselli page 2 - 2 - June 20, 2013 Stainless Steel Products/Industries the Order ta prepare and submit a Subsurface Soit lrivestigation Workplan In order to evalúate the sublurface conditions and the potential for groundwater contamination. to the responsible parties for the Site constitutes an amendment to the California Wa er Code section 13267 Order priginalty'dated September 21, 2012. All other aspects of the Order orig flatly dated September 21, 2012, and amendments thereto, remain in full force and effect. The required tethnical.repvrt is necessary to investigate the characteristics of and extent of the discharges of Vaste at the Site and to evaluate cleanup alternatives. Therefore, the burden, including costs, of the rep$rt bears a reasonable relationship to the need for the reports and benefits to be obtained.. Pursuant to section 13268 of the California Water Code, failure to submit the required technical report by the spe4ified due date may result In civil liability administratively imposed by the Regional Board in an amount up to one thousand dollars ($1000) for each day each technical report is not received. The above addition Shoitd you have any questions related to this project, please contact Ms. or via email at luz.rabelo @waterboards_ca.gov. (2130 576.6783 Luz Rabelo via telephone at Sincérely, Samuel tang Executive Officer Enclosure: . Revised California Water Code Section 13267 Order No. R4- 2012-0069 -A01 Original California Water Code Section 13267 Order No_ R4-2012 -0069 Issued on September 21, 2012 cc: Ms. Lisa Hanusiak, USEPA Region IX Mr. Leo Chan, City of Glendale Mr. Bill Mace, City of Burbank Water Supply . Department Mr. Vahe Dabbaghian, Los Angeles Department of Water & Power 11Í1r. Milad Taghavi, Los Angeles Department of Water &Power Mr. Richard Slade, ULARA Watermaster Ms.-Sonja Donaldson, c/o Breeze -Eastern Corporation Mr. William R. Zimmerman, Stainless Steel Products Mr. James Galbraith, Stainless Steel Products Mr. Craig i3loomgarden, Manatt, Phelps & Phillips, LIP Exhibit B Jun 24 2013 2:20PM James 626-795 -6870 Galbraith page 3 Ea>rwso Q. otVr Water Boards 911OrM 4t+nwl.+ ROP110V[I s LAM ..a. f44 INTO..e.nAl 1 Pone TID Los AO geles Regional Water Quality Control Board REVISED ORDER TO PROVIDE A TECHNICAL REPORT FOR SUBSURFACE SOiL INVESTIGATION CALIFORNIA WATER CODE SECTION 13267 ORDER NO.. R4-Z012-0069 -A01 DIRECTED TO BREEZE -EASTERN CORPORATION, MR. WILLIAM ZIMMERMAN, MR. JAMES GALBRAITH AND SENIOR AEROSPACE 55P . STAINLESS STEEL PRODUCTS/INDUSTRIES 2980 NORTH SAN FERNANDO BOULEVARD, BURBANK, CALIFORNIA (FILE NO. 104.1005) Thé California Regional Water Quality Control Board, Los Angeles Region (Regional Board) makes the following findings and issues this Order pursuant to California Water Code (CWC) section 13267, which authprizes the Regional Board to require the submittal of technical and monitoring reports. 1 2' The groundwater within the San Fernando Valley Groundwater Basin [Basin) has been impacted by discharges of heavy metals, specifically chromium. The San Fernando Valley Superfund Site (Superfund Site) lies within the Basin. The United States Environmental Protection Agency (USEPA) and the Regional Board are investigating the potential sources of the discharges to the Basin. The agencies are currently focused on identifying individuals and companies responsible for the discharges of chromium In the Basin and holding them responsible for the investigation and remediation of the source sites. The property located at 2980 North San Fernando Boulevard, in the City of Burbank, California (the Site) Is a potential source of chromium and overlies the Basin. The Site was developed and occupied by stainless Steel Products/Industries since approximately 1.952. The Site is currently owned by First Industrial Real Estate, Inc_ of Chicago, Illinois, who reported that Mr, William Zimmerman and Mr. James Galbraith were the first owners/operators of Stainless Steel Products /Industries at the Site. The Site Is currently occupied by Senior Aerospace SSP. Senior. Aerospace SSP is a subsidiary of Breeze -Eastern Corporation and a successor to Stainless Steel Products/industries. Stainless Steel Products/Industries' operations at the Site included the use of hexavalent chromium, sodium dichromate, and chromic acid. Metal coating and metal finishing processes were part of the on -site operations conducted by Stainless Steel Products /industries. In 1J87, the USEPA and the Regional Board initiated an investigation at the Site which focused on volatile organic compounds (VOCS) and not on heavy. metals, Therefore, the potential discharge and /or release of chromium based compounds to the soils at the Site, as a, result of the past metal finishing operations, has not yet been determined. ' 3 JI_ CWC section 13267(b)(1) states: "fn conducting an Investigation specified in subdivision (a), the regional board may require that any person who has discharged, discharges, or is suspected of having discharged or, MIARM MçNPNIIW, 320 WI.a! attl St., Suit. POO, GYNR i SAMUEL tiNOl11, EKlCVTIY! wl'10ER Loa AnpNN. G1 $0011 Imir~ .wawó.uras,ea.po./loannaAS Y Jun 24 2013 2:20PM James Galbraith MrJJim Sasselll Senior Aerospace S5P 626 -795 -6870 page - 2 - 4 June 20, 2013 . discharging, or who proposes to discharge waste within its region, or any citizen or domiciliary, or political agency or entity of this state who has discharged, discharges, or is suspected of having discharged or discharging, or who proposes to discharge waste outside of its region that could effect the quality of waters within Its region shall furnish, under penalty of perjury, technical or monitoring program reports which the regional board requires. The burden, including costs, of these reports shall bear a reasonable relationship to the need for the reports and the benefits to be obtained from the reports. in requiring those reports, the regional board shall provide the person with a written explanation with regard to the need for the reports, and shall identify the evidence that supports requiring that person to provide the reports." A. The Regional Board has obtained evidence indicating that there is a potential waste at or from the Site. Regional Board files indicate that operations at for discharge of the Site consisted of metal coating and metal finishing processes which included the use of hexavalent chromium, sodium dichromate, and chromic acid. Stainless Steel Products/Industries is. among the suspected sources of waste discharge in the USEPA Superfund Site because of the chemicals used and the operations conducted at the Site. It is known that groundwater within the Superfund Site, Including the vicinity of the Stainless Steel Products/Industries facility, is polluted with VOCs and heavy metals, *particularly chromium. To date, a complete subsurface investigation of heavy metals in soil or groundwater has riot been performed at the Site, 5. 5. This Order identifies Breeze-Eastern Corporation, Mr. William Zimmerman, Mr. James Galbraith and Senior Aerospace SSP as the entities responsible for the suspected discharges of waste 'identified in paragraph two and, four (4) because Mr. William Zimmerman and Mr. James Galbraith were the owners/operators of the facility where the activities occurred that resulted in the suspected discharges of waste were performed and Senior Aerospace 55P is a subsidiary of Breeze -Eastern Corpòration and successor to Stainless Steel Products /industries. This Order requires the persons /entities named herein to prepare and submit a Subsurface Soil lnvestigation Workplan (Workplan) in order to evaluate the conditions at the Site and If any discharges of heavy metal determine compounds, specifically chromium, has impacted the soils beneath the Site that could consequently pose a threat to groundwater. Ytiu are expected to complete Workplan, as required by this Order, to the Regional Board, The Regional Board may reject the Workpian If Ris deemed incomplete and/or require revisions to the Workplan under this Order. submit 7_ a The Regional Board needs this information in order to determine whether the Site is discharges of waste, specifically a source of chromium, and to determine whether the subsurface soil conditions at the Site are causing or threatening to cause discharges of waste to the waters of the State within the Basin. The burdens, including costs, of these reports bear a reasonable relationship to the need for the reports and the benefits to be obtained from the reports., The information is necessary to identify sources of discharges of waste to the Basin and to assure adequate cleanup of the Stainless Steel Products /Industries facility, which as described above potentially poses significant threats to public health and the environment. 9. The issuance of this Order Is an enforcement action by a regulatory agency and is categorically exempt from the provisions of the California Environmental Quality Act (CEQA) pursuant to Jun 24 2013 2:20PM James Galbraith 626 -795-6870 Mri Jim Sasselli Senior Aerospace page 5 - 3- June 20,2013 SS P ' section 15321(a)(2), Chapter 3, Title 14 of the California Code of Regulations. This Order requires submittal of technical and/or monitoring reports and work plans. The proposed activities under the work plan are not yet known. It Is unlikely that implementation of the work associated with this Order could result In anything more than minor physical changes to the environment If the implementation may result In significant impacts on the environment, the appropriate lead agency. will address the CEQA requirements prior to implementing any work plan. 20. Any person aggrieved by this action of the Regional Board may petition the State Water Resources Control Board (State Board) to review the action in accordance with Water Code section 13320 and California Code of Regulations, title 23,, sections 2050 and following, The State Board must receive the petition by 500 p.m., 30 days after the date of this Order, except that if the thirtieth day following the date of this Order falls on a Saturday, Sunday, or state holiday, the petition must be received by the State Board by 5:00 p.m. on the next business day.. Copies of the law and regulations applicable to filing petitions may be found on the Internet at the following Link: http://www.waterboards.ea.gov/public notices/petitions/water quality or will be provided upon request. THEREFORE, tT IS HEREBY ORDERED that Breeze -Eastern Corporation, Mr. William Zimmerman, Mr. James Galbraith and Senior Aerospace SSP, pursuant to section 13267 {b) of the CWC, are required to: 1.. Submit a Subsurface Soll Investigation Workplan (Workplan) to the Regional Board by August 2, 2013. Guidancedocurrnents to assist you with this,task can be found on the Internet at the following links: "General Work Plan Requirements for a Heavy Meta! Soit Investigation" http:// www ,waterboards.ca.gov/losangeles/water Lsues /progràms/remedtatlonlgene rat Workplan Re juirerrlents for Heavy Metals Soli IRvestik_ation.pdf "Inter. Interir» Site Assessment & Cleor>up Guidebook (Mayi9961," h .. www.w. oa .s.ca._ov .san:eles water is ues ro :r.ms re guidance.shtml "Quality Assurance Project Plani http://www .waterboards.cagov /losangeles/water SFVCteanupProgram Sept2408 QfiPP,pdf h! t. ma 1996 v issues/programs /remediation /Board SGV- The Workplan shall Include detailed information of former and existing chromium storage, hazardous waste management, and associated practices. 3. The Workplan rrlust also include proposed soil sampling boring locations which shall extend to a minimum depth of 25 feet below groundsurface in the areas of the previous plating processes and waste treatment (sumps, clarifiers, etc.), hazardous waste storage area, and chemical storage area_ 4, The Workplan must contain a health and safety plan (HASP), as per the guidelines. Jun 24 2013 2:21 PM James Galbraith 626-795-6870 page Mn. Jim Sasselii Senior Aerospace SST, -4 6 - June 20, 2013 5. The Workpian shall include a detailed schedule of implementation of the Workplan, including field work and providing a report of the results to the Regional Board.. . Upon approval, the Workpian shalt be implemented and a report summarizing the results according to the approved schedule must be submitted to the Regional Board. Thé above item shall be submitted to: Ms. Luz Rabelo Water Resources Control Engineer Renlediation Section Los Angeles Regional Water Quality Control Board 320 West 4th Street, Suite 200 Los Angeles, California 90013 Phone: (213) 576 -6783 Email: lut_rabeloOwaterboards.ca.eov Pursuant to 13267(a) of the CWC, any person who fails to submit reports in accordance with the Order is guilty of a misdemeanor. Pursuant to section 13268(b)(1) of the CWC, failure to submit the required Wor)cplan described above by the specified due date(s) may result In the imposition of civil liability by the Regional Board In administrative an amount up to one thousand dollars ($1,000) per day for each day he Workplan is not received after the above due date. These civil liabilities may *be assessed by the Regi nal Board for failure to comply, beginning with the date that the violations first occurred, and withbut further warning. The Regional Board, under the authority given by the CWC section 13267, subdivision (b)(1), requires you to include a perjury statement in all reports submitted under the 13267 Order. The perjury statement shall be signed by Mr. William Zimmerman and Mr. James Galbraith and a senior authorized Breese- Eastern Corporation and Senior.Aerospace .SSP representative (not by a consultant). The perjury statement shall be in the following format: . "I, (NAME), certify under penalty of law that this dácument and all attachments were prepared by me, or under my direction or supervision, in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my inquiry of the-person or persons who manage the system, or those persons directly responsible for gathering the Information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. am aware that there are significant penalties for submitting false inforMation, including the possibility of fine and imprisonment for knowing violations." . 1 , The State Board adopted regulations (Chapter30, Division 3 of Title 23 & Division 3 of Title 27, California Code;of Regulation) requiring the electronic submittal of Information (ESI) for all site cleanup programs, startiflg January 1, 2005. Currently, all of the information on electronic submittals and Geohacker contaicts can be found on the Internet at the following link: http :4/www.waterboards.ca govfust /electronic submittal. Jim 24 2013 2:21PM James Galbraith 626 -795-6870 MrJim Sasselli Sen'iorAerospace page - 7 5- June 20, 2013 SOP To comply with the above referenced regulation, you are required to upload all technical reports, documents, and weil data to GeoTracker by the due dates specified in the Regional Board letters and orders issued to you or for the Site. However, thé Regional Board may request that you submit hard copies of selected documents and data in addition to electronic submittal of information to GeoTracker. SO thRDERED. 4en rir.41?.1----" Sarnuél Ung , P,E. Exe4utive Officer ee Date .1 2 v -z a/ 3 Exhibit C J SSP) Senior Flexonics, Inc. V asset sa e (1995) (Senior Aerospace \ ( #0627765) (suspended) Products, Inc. W r Stainless Steel Operating company name chaìge (1981) 1971 incorporated Products, Inc. ( #0627765) SSP ock (ac ired 1981) ow -rship 100% 4 #1003018) Inc. j 1980 incorporated Products, Inc. ( #1003018) Stainless Steel name cha nge (1981) ( SSP, J 1 name charige (1982) ( #1003018) (suspended) (bankruptcy 2002) Zimmerman Holdings, Inc. . secretary (1980, resigned 1982) James Galbraith Holding company Exhibit D F ARTICLES OF rTORPORATION I L. !he of the 7 OF 4 ->.-___ i SSP Pi,ODUCTS, '1..,-.:. E ill) Sc, 1 291971 Erf V VI' DA E," :-.q01 The name of this corporation is: 1,C. TI. The purooses for which this corporation iP form.Pd, the specific business in which the corporation la primarily to engage being set forth in Paragraph (1) below, are: The sof.cific business in which the corporation to engage is to manufacture, repair, fabricate, form, sell, rent, lease, license, distrinute ad otherwise uesi in ,iletal products and other orocucts reL,-ing directiv CZ indirectly to metal forming or metal_ fanrication. (1) is primarily (2) To manufacture, buy, sell, assemble, distribute, and to otherwise acquire, or to own, hold, use, sell, aasign, transfer, exchArdze, lease, license or otherwise dispose of, and to invest, trade, deal in and with goods, wares, merchandise, building 'materials, supplies and all other property of every elaes and description. (3) To .37-.Phse 7.cquire, own, hol4, ugo, 3eas.0., either as lessor cr le:11a, rent, sublcit,. grant, sail, exchRnge, subdivide, morLgage, deed in trust, inanaP:e, improve, cultivate, develoo, maintain, construct, operate, and generally deal in, any and all roal 1-,ate, improved or unl:;:proved, 3tofes, of'fica buildihgs, house:.1, boardln7 houes apA.=zfit L-znufas.,- /- 7 ; ''' . !:. :77f7.-:1"....:; ,-, ::::!:73 7 PRODUCES, ci fis-t - : -'9 be ". thr. : - , , i , _ ,., : ..' - -.'erty o,.^ 3U.si._e33. or ot:t:.,,. °'isa, thá good- . or desbuildings of an y kind _ants , d ... oth rL'.i ng kind anu <:rlv 3nd 1.11 other property of every _._.__ _ir?-ion cersulaï and mixed, and any ^r description, ..clu:ïing wa_t..r and water rights, est or right -....re other states wheresoever situated, ither _.. California, Di .,rict o_ Columbia, terrior the United States. ;he and foreign tories and _c_onie'F of the United States countries. 'd p _d, own, use and _ .. hase, acquire, ta -=, transfer, pledge, mortgage, enjoy, and to _i_, lease, or otherwise di spose of, and gener convey, grant, ass_i_..es trade, deal in arid with .__ royalties, _ t ally mineral bearing lands and ...in-e_.__ rights of all Kinds, and minerai ^a: Y .,.. products of ali kinds, oil, gas ^ and interests therein, and _.. ac_ _ and rights _.., both products t. the earth and de"c,.J:ts, ¡i ;,j,= . and surf-ace, of every nature and description. ol:v conTo enter int:), make, },er_,orlr, and carry 15J without tracts of every kind for any 'la erSul purpose association or coras to amount, with any person, firm, county, parish, state, territory, î oration, municipality other municipal or government (foreign or domestic ) or governmental subdivision. Jr limited To become a partne: (either general (6) of partnership, with or ben.) and to `-'î:..,,r into agr".,.,.aists purpose one .,_ more other persons or corr:o.TM3i.do.is,..Cri.îieÚ'..i.::' which this corpv^_'3_ of carrying on any business whatsoever in connection with any t1_o:l may deem proper or convenient or which purposes C3erei:a set forth or otherwise, or indirectly, to DPo`iïï.t._. the .. '.. directly of of .. _ calculated, iy or to enhance the value i.IterF3t of this corporation ._.... - i7) oenquire, by purchase franchises and assets of will, _._s incSr, ':rC_ rty rights, i.r undertaking, either wholly every-M.l+t, -°lth cr'tyíti-Fout F°ssso-i2:C'jo:n ln part, the liabilities o:' any person: firm,or business or corporation; and to acquire any ¡^rop3rtJ of the pro-erties. :ne maintenance, To take, purchase and otherwise acquire, own, transfer, exchange, lease, mort-.101d, use, sell, assign gage, convey in trust, pledge, hypothecate, grsnt licenses Ln respect of and otherwise dispose of letters patent of or any foreign country, patent rights, tl-;e United states licenses and rrivIleg, invfntinns,1 improvements and proand :7overno'-ssPs, copyrights, trademnrks and trade names, ,and :tent, state, terrtorial, county and municipal grants concessions of every character 1.:hich this corporation mav f.t5 business or deem advantageous in the prosecutio operation, f_ltavelo;:z.ent or extension of :re ecy ?rom time to time to apply for, purhase, ac(9) by atls_Lgnment, transfer or otherwie, exe7.cise, any benefit, rizht, privilege, pret,rry out antfl rogative or power cmferred by, acquired under or granted by any statute, ordinance, Order, license, power, authority, fr:-,nchise, commission, right or privilege whi;h any zovernment or authority or governmental agency or corporation or other puelic I 'ciy may be empowered to enact, ,:lake or grant: to pay for, aid in, and contribute to-ward carrying the sama into effect; and to appropriate any of this corporation's shares, '7.,ond3 and/or ac -t3 'o defray the costs, charzes and expenses thereof. of Tn .,uhscribe or 7ausc to be subscrabed for, and 0) to take, purchase and otherwise acquire, own, hold, use, sell, assign, trAn2fer, exchange, distribate and otherwise dispose of, the whole or any part of the s'aars of the caoital atoclt bonds, coupina, lortgages, deeds of trust, debentures, securities, oblntions, evidences cf indebi-,edness, notes, goodwill, rights, assets- and prcit'erty of any and every kind, or any part thersof, of ahr other corporation or corporations, association or associations, firm or firms, or peraon or peisons, toter. with shnres, rights, .units or interests in or in respuct of any trust estate, now or hereafter existing, and whether created by the laws of the State Of California or of any other state, territory or country; and to ' - -,». 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Al ì) V<: ,, "? ,, CC U ,t] cI C, ) . r;i , :, ! 't9 Ka r rd re C: R) Si O F, a) rd 7 tC P, Fa Ci ri 1 f'.': 4) O;J U'L 't O (? .0 s C9 6A +.) d. An N 4l t"i f (c 4t á) Fa ''") 4, .'.) aS a'i YA Ct).r r'J 'ri e-i ña ..t N a) Q) O S' . »' rs] r b) L> 4) 'S) ,.t) tq r r, Ü G O O C ^ FA F3 M) F'f t':) F') W 4I Ci;1 á) 'd ;) O 'C) ; . '>"' r!O l) î v 4) }, c) O P. O'1 ,rA, , :) ti7 o ), .t c Ú )-) Fa á7 .N w O O Ç 1> FA u C: C) 0.1 ,O r4 CJ c'd a) 1) 4, O,i 4-a TJ to., .:) 't f..; 4-a a) a.) ,rl rl ti::l) "t r'1 ,-i ,-, -! m ;) , » u] Fa rta rn 0 0 0)' >] r1 .C.., 4) N) 4) fJ 6) rll ;) a? 01) ri .1:: l!) 4) a) U) al O )) ct) ;-1 Sn Et 4-I U o) o at r,..I -.4-O+ O 27 U) G,. " rd O a) a) F. E: : O O , m (; u) m L: 'L7 r1 U ÿs 4) S ! G ; N al t nJ , a) m tS) ) o !: ai r-t ^) .f7 Ty M , S, f-, rl M a) .t:: mJ -!-) 2i 07 r) Fi )7 t#) m- .0ai b) br:. rri C)) n r fl) .i AlN 17C u C.) .-fy O), T. Fa O "] ri,.) G U rii Lá fn N L, 3 U O in r-i (17 ,. F, O ,Cl r-d O c,j .+ u] to 1:1 @ C)J ,.... -- y )) <: (J I.) F, t.?l C . 'a p rd C" r-I »;td .'1 )) h: .l) (.! P) C) I r fr C.) .) pi r) O L. _r The as a fore-go1-12; statement of laurposes shall be construed statement of both purposes and powers, and the purposes and po,4ers stated in each clause sha11,1 except where otherwise expressed, c2 in nowise limited or restricted by any reference to or Inference from the terms or provisions of any other clause, l'ut shall be regarded as independent purposes and powers. The county in the State of California where the rihcir,al office for the transactton of the business of this cornorat.L,--n is to he located la Los Angeles County . IV. No distinction shall exist tetwGen the shares of this corporation or the rizhts of the respective holders thereof with respect thereto. V. This cr,rT;ortion is authcr:i.zd to Class of aharos cf :stock. isr;u-f; only one Ths total numb ,.sr of ahare3 of stock which this corporation shall have authority to locus 1s 25,000; the acgregete par value of all shares will be ;!s25,000.00, and the par vales of be each of such shares shall .t-1.00, The number of directors of this corporation shall be three and the names and address of the partons who are appointed to act as the first directors of this corroration are as follows: Addreas bil v;eSt Sixth Street Los Angeles, California 9-A17 611 ;;esc. Sixtn Street Los AnQeies, California 11 ;Jest Sixth Street :kngeles, California liv1 7 IN WITMSS VEE720,75!, for the puTposos of forming thla corporation under tns laws of tho State of California, wo, the unders47ned, constituting the Incorporator:a of this corporation and the persons named herein as the first directore of hii corporation, have executed those Articles of incorporation this 2.5tn clay of 3 June 114 , o 71 STATE OF cALIFORN1A ) ) CO=.7 OF LOS ANGELES On this as. ) 25tn de.: June of , 1971 before me, the-unders1c4ned, a Notary Public in and for said V. GRAliAM County and State, p=rs,)n9,11y appeared ,;IL__,IAM J. FL:Ie and DAvio A. known to me to be the persons whose names are cubscribtd to th,s foreg.oing Articles of Incorporation and acknowledged to me thzt t".r.ly executed the same. WITNESS my hand and official seal. Notary Public in and for County and State grnit124II::rnwilrt11171n13712,rSEVEFZiff FI-R L3S (SEAL) My f. p-rt-as i 2. 1972. aId , Exhibit E CIRTIFICATE OF AMENDMr.NT 02 ARTICLE OF INCORPORATIUN or sS2 PRODUCTS, ci ';NC. Arthur L. Moore and Charles F. Amrhein certify that: They are the duly elected and actinu President i. zncl Secretary, resT..ectively, of this corporation. The Board of Directors of this corToration adopted 2. the following resolution by an action taken dated January 2, ii:;:out a meeting 1981. RESOLVED, that Article i of the Articles o' TncorDo,-ation of this co"-r.ortion be amendd to read as follows: The name of this c=7,,oration is STAINLESS STEEL PRODUCTS, INC."' The shareholders of this 3. ,,-o_Tpol---ation such ameadmer,L witi-..out a restion an action taken meeting as of Januar heiT;9- resolution in para,.:41-aph 2 the wcr3.ine of such eet fort 1:7_1- th* airectors: 22oove. cf shares wh,ich vc,ted.affiltire31, for ot of 8I. thc nane as tho The duil:::,er have ratified sk.laa.o,s s111-1 6nd ree.:72271tion ooiood to vote was 1,30G. el ' - --7- - -- - Each of the und-.7:rsigne:H true and correct. Certificate eeclares uncler pnalty of perjury that the matters set forth in the for;-qoin4 ae /I" /2 cuted at Los Angeles, California on January 1? "7 //./ Arthur L. Moore / Charles F. Amrhe,n 1 Exhibit F LNDORSEn FILED ARTICLES OF INCORPOPTION STAINLESS STEEL PRODUCTS, In the office of the Secretary of State of the State of California SEP 2 2 1980 INC. MANN FONG EU, Secretary of State J.uslie Glenn I Deputy The name of tnis corporation is STAINLESS STEEL PL3DUCTS; 1003018 II ay The purpose of this corporation is to engage in lawful act or activity for which a corporation may be ora,anized under the Ceneral Corporation Law of banking,vbusineLs, , California .Lnia 4 other than a the trust company bus-;ness e of a profession oc rmitted to be incorporated by the Californi;... Corporations Code. ITI The name and address in the State of Clifor-riia of this corporation's initial agent for service of process is M. Glenn Gilbert, Esq., West Sixth Street, 611 Los Angeles, California 90C17. 1600, IV This corporation is authorized to issue only one class of no par value shares of =MOP stock, and the total naz:ber of shares whicb this corporation is authorized issue t.-; is one million (1,000,000). Dated: Septembe-r 19, 1980. M. I heLe.::)y declare that I ani Glenn Gilbert the person who executed the foregoing Articles of Incorporation, which executiOn , act and deed. M. INC Glenn Gilbert ff.y . Exhibit G Clif.;%, riLED evasiori Calm*: Saw 1TO: al .4.2;.!8:310 ' - - _ /7' - - as *Wig .JAK ./ CERTIFICATE-OF:AAENDMENT OF 7 ARTICLES .0F. .-INCO0PORATION,...-' OF - .-;. .. INC. PRODUCTS, STAINLESS STEEL . .111M SoNsiits/ ' .. ...___-. . - - William 1. R. They certify that: James M. Galbraith and Zimmerman resident and elected and actin, are the duly respectively, of this coiporation. corporation adopted of Dir.'ctors1 of The Board meeting 2. withotlit a an action taken by resolution the following 8, 1981: dated January the Articles Artidle I ofi be amended "RESOLVED that corporati.on of this )ration In: of to read as follows: ration is of this co ..'The name SSP, INC.'" has ratified of this corporation shareholder sole The 3. taken ión by an actici3 resolu a by adopting such such amendment -.fording of 8, 1981, the of January as without a meeting in the directors' that set forth the same as being resolution above. i. paragraph 2 for resolution in voted affirmatively which; shares The number of 4. and the total was 50,000, resolution of such the adoption vote was 50,000. entitled toI shares ------of ---"-4 number .,.....,-.,- Sec::etary, r' - i - E - 7s - ; _,Iie".Z.,,Vear:Z.e-e 61%t----41Ze President R. Zimmerman, e--r:.."---- William - ' _ ._ ". _ .1 it it Each of the undersigned that the matters set ury are true and declares under penalty forth in the foregoing ot Certificate correct. California on Januar,/ Executed at Los Angeles, 8, 1981. - 74.7ZeS0-7:74 , r cr , ,1:11114.-44, -.:1 Exhibit H fKïFOWN HOLDINiOS, INC. FILED CERTIFICATE OF AMENDMENT OF ARTICLES OF INCORPOR,ATIOlv OF SSP, A William California _I. ii Co certify h R. Timmerman and Jarres M. tats ` respectively, are the President a d-thelSecretary, ("thecorporation" a`cororation of;SSP, Inc., a Californ Incorporation' _of: (a) Article I of- ther:Ar icles,of; read.;as.:.followssmended-..to is the Corporation They 1. . _ in is "The :tatne of_ this corpora HOLDINGS,. INC:" . ZIMMER_MAN - + ..'f Incorporation Article IV of the Article' ded to read as follows: ame is' Corporation of the aut Iized to issue two "This corporation iseachith -no par value, shares,: of classes "Voting Common respectively, designated, Common Stock." The Stock" and "Nonvoting shares cf Voting Common_. authorized number of (1,000,000). and the Nonvoting shares of authorized numberone million of (1,000,.000). is Stock Comtaon Stock is one million privileges and restricrights, provisions, Common' Stock. and the Non tions of the Voting sha11 be equal and; identiStock Common voting except that unless otherwise respect cal in all holders of shares of the provided by law, .t e shall]. :have and pessess the Voting Common Stoc The holder of shares rights. voting exclusive .entitled hall not be each Stock of Nonvoting Common share The -: - to vote. Upon the filing of - í.S of outstan1ing Cccrtr:, Stock share of Voting ccitnon Jtock. ' airen& at, lassified as one (1) I 3. Articles of Ilcorporation foregoing amendments of th '82. are effective as cf'March.l,;; Incorporation t e Articles cf The foregoing amendments of been duly approved' have thereo', date and the effective by.the Board of Directors. The - 4. i it:'sa +` ab` - .-.-. .. ; #:l - c.^ ..a w ... 5. Artïcles .of Incorporation, The foregoing amendments of the duly approved e effectiv`date- thereof,have been d in accordance theshareholders of vote bany t.'hthe required General. Corporation with:Section;902:::of theeCaliforni of `outstanding sharesOU.thei. -Lac .. The :tata1;.number The. number of ._ Corporation >is fifty thousand (50,000) -amendments, and foregoing the of in favor. shares voting thousand (50,000). the effective date thereof was fifty that the The 'undersigned declare ander..penaltÿ`iof.perjury of their are.true "eate certif matters set forth.ìn_ the foregoing taliforn..ia, on February. Angeles, Los: at own knowledge. ,Executed 18, 1982. William i Y.'.._rt-:.: _ 1_-_ . . ... ..^-srv R.. Zimmerman aY ágt;n.