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Document 2137978
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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
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BEFORE THE STATE WATER
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RESOURCES CONTROL BOARD
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STATE OF CALIFORNIA
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Petitioner,
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IN RE: LOS ANGELES REGIONAL
WATER QUALITY CONTROL BOARD
ORDER NO. R4- 2012 -0069
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James M. Galbraith,
vs.
Los Angeles Regional Water Quality Control
Board,
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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.
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v
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I, JAMES M. GALBRAITH, Petitioner in the above -entitled matter, pursuant to California
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Water Code Section 13320(a) and California Code of Regulations, Title 23, §§ 2050 et. seq., do
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hereby petition the State Water Resources Control Board (the "Board ") to review the Order and
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Revised Order referenced herein. This Supplemental Petition supplements and incorporates my
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earlier Petition to the Board in this matter. In support of this Supplemental Petition, I hereby
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declare as follows:
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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
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attached hereto as Exhibit A.
Accompanying the letter was LARWQCB Revised Order No. R4- 2012 -0069 -A01
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4.
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("Revised
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Corporation, William Zimmerman, and me to prepare and submit a work plan to conduct a
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subsurface soil investigation to determine if any unauthorized release of heavy metal compounds
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has impacted soils that could pose a threat to groundwater beneath the site located at 2980 San
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Fernando Boulevard, Burbank, California (the "Site "). A copy of the Revised Order is attached
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hereto as Exhibit B.
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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
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by First Industrial Real Estate, Inc. of Chicago, Illinois, who reported that Mr. William
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Zimmerman and Mr. James Galbraith were the first owners/operators of Stainless Steel
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Products/Industries at the Site." This statement is false and it cannot be substantiated. As such,
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this statement is an untenable basis for the issuance of the Order and Revised Order to me. As
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stated below, I had no ownership or any positions in, and I received no compensation from,
aQFW
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Stainless Steel Products, Inc., which was a former owner/operator at the Site.
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6.
The Order and the Revised Order were sent to me without any prior notice and
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without an administrative hearing before LARWQCB. Therefore, I did not have any opportunity
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to present objections to LARWQCB prior to the issuance of the Order and the Revised Order.
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7.
I am an inactive attorney. In large part due to health reasons, I retired from the full -
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time practice of law in 1979, and became part -time of counsel to my law firm in 1982. Prior to
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my full -time retirement, my law firm's business clients included Zimmerman Holdings, Inc.
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( "Holding
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corporations. The corporate histories of the two corporations are complex and may be confusing.
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A diagram depicting the separate corporate histories is attached as Exhibit C.
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8.
Company ") and Stainless Steel Products, Inc. ("Operating Company "), both California
There were two separate and distinct California corporations at different times
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named "Stainless Steel Products, Inc." Stainless Steel Products, Inc. was incorporated in
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California in 1971, under entity number 627765, originally as "SSP Products, Inc." ( "Operating
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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
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the Revised Order to permit other parties in control of the Site to comply with the Order and the
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Revised Order.
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Because I did not have any opportunity to present objections to LARWQCB prior
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to the issuance of the Order and the Revised Order, if the Board denies my request in whole or in
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part,
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argument.
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I
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Executed on July 15
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declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
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A copy of this Supplemental Petition has been sent concurrently to the Executive
Officer of LARWQCB.
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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
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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.
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Water Boards
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4t+nwl.+ ROP110V[I
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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,
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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
-
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be
".
thr.
:
-
,
,
i
,
_
,.,
:
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-
-.'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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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.
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