HomeMy WebLinkAbout02.12.26 Board Correspondence - FW_ Case CS0086265 has been assigned to group ECHO Tier 1.ATTENTION: This message originated from outside Butte County. Please exercise judgment before opening
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From:Clerk of the Board
To:Clerk of the Board; Connelly, Bill; Cook, Holly; Cook, Robin; Durfee, Peter; Jessee, Meegan; Kimmelshue, Tod;
Kitts, Melissa; Krater, Sharleen; Lee, Lewis; Little, Melissa; Pickett, Andy; Ritter, Tami; Stephens, Brad J.;
Sweeney, Kathleen; Teeter, Doug; Zepeda, Elizabeth
Cc:Mutony, Heather; Loeser, Kamie; Soderstrom, Monica; Nuzum, Danielle
Subject:Board Correspondence - FW: Case CS0086265 has been assigned to group ECHO Tier 1
Date:Thursday, February 12, 2026 5:03:42 PM
Please see Board Correspondence -
From: Andrew Merkel <ademco9787@att.net>
Sent: Thursday, February 12, 2026 12:35 PM
To: EPA Public Support <public_support@epa.gov>; Kristin Daily <kristin.daily@doj.ca.gov>; Marina
L. Ramirez <mramirez@agclawfirm.com>; District Attorney <District_Attorney@buttecounty.net>;
DAFraud <dafraud@buttecounty.net>; Clerk of the Board <clerkoftheboard@buttecounty.net>
Subject: Re: Case CS0086265 has been assigned to group ECHO Tier 1
Re: Whistleblower Complaint Under the Federal Water Pollution
Control Act (FWPCA), 33 U.S.C. § 1367
Dear OSHA Representative:
I am filing this whistleblower complaint under the Federal Water
Pollution Control Act (FWPCA) against Sierra Nevada Brewing
Company (SNBC), located at 1075 East 20th Street, Chico, CA
95928. I believe I have been retaliated against for reporting
alleged violations of the FWPCA related to the discharge of
pollutants into navigable waters from point sources without
proper permits or compliance. This retaliation includes the filing
of a workplace violence restraining order (Case No. 24CV02219,
Butte County Superior Court) against me in July 2024, which I
believe was motivated by my protected activities, as well as
potential influence on my ongoing criminal case in Redding,
California (Shasta County), where bail was revoked and other
procedural issues arose following my reports.
Covered Employee and Protected Activity
I am a private sector individual who has engaged in protected
activities under the FWPCA. Although I am not a current
employee of SNBC, the FWPCA’s whistleblower protections
extend to any person who reports violations, including non-
employees, as long as the reports pertain to discharges of
pollutants into navigable waters. My protected activities include:
• Providing information to regulatory agencies and the public
about alleged violations of the FWPCA, including unpermitted
expansions and potential bypassing of on-site wastewater
treatment at SNBC’s Chico facility, which could result in
increased organic loadings (up to 130%) into the City of
Chico’s sewage treatment works, adversely impacting
operations related to oxygen transfer, alkalinity demand, and
nutrient dosing. This is based on the 2004 U.S. EPA NPDES
Compliance Evaluation Inspection Report for SNBC.
• Reporting that SNBC’s Production Well No. 1 (constructed in
2016 under Permit EHWL16-0014 and CEQA17-0005) is
being used to support facility expansions (e.g., the CanDo co-
packing facility launched in July 2025) without proper CEQA
documentation or updates to wastewater discharge permits,
potentially violating point source discharge limits under the
FWPCA and Porter-Cologne Water Quality Control Act. The
well was approved only for an independent water supply for
existing operations, not to enlarge the facility’s footprint or
increase discharges. Key details from the well’s Construction
and Testing Summary (prepared by Luhdorff & Scalmanini
Consulting Engineers in November 2016) include: drilling
commenced August 30, 2016; pilot borehole to 900 feet bgs;
reaming to 810 feet; casing assembly with 640 feet of 12.75-
inch stainless steel blank casing and 130 feet of louvered
screen (slots at 540-620 and 710-760 feet bgs); gravel
envelope from 790-350 feet; annular seal from 350 feet to
surface installed September 23, 2016; development pumping
up to 1,450 gpm; constant rate tests showing capacities from
187 gpm (1.5 ft drawdown) to 800 gpm (13.5 ft drawdown);
and water quality meeting Title 22 drinking standards. The
CEQA Mitigated Negative Declaration (Draft IS/MND,
CEQA17-0005) includes sections on hydrology/water quality
(pages 44-50), hazards/hazardous materials (pages 40-43), and
utilities (pages 65-68), noting proximity to toxic sites like
Chico Scrap Metal (750 feet north) and Victor Industries
(1,500 feet southwest), with a public hearing on August 18,
2017.
• Participating in or assisting with potential proceedings by
sharing documents such as the 2016 Well Construction and
Testing Summary (including appendices on as-built profile,
well completion report, geophysical E-Log survey, borehole
deviation survey, 4-hour constant rate tests, field data sheets,
water quality summary, drilling permit, sanitary sewer
discharge permit, and storm drain self-monitoring report) and
the 2017 Draft Mitigated Negative Declaration (IS/MND),
which highlight site-specific risks near toxic sites (e.g., Chico
Scrap Metal and Victor Industries) and hydrology/water
quality concerns.
• Refusing to remain silent about these unsafe and unhealthful
conditions, which I reasonably believe pose risks to public
health and the environment, including navigable waters
connected to Chico’s sewage system.
These reports began as early as 2022 via public posts and
complaints to agencies like the Central Valley Regional Water
Quality Control Board (RWQCB) and Butte County
Environmental Health. I have continued to provide information,
including evidence of no public CEQA or permit records for
discharges. Additionally, I have reported potential criminal
violations to the California Department of Justice (DOJ)
Environmental Enforcement Section, as these may involve
knowing false statements in permit applications, illegal
discharges, or tampering with monitoring under the Clean Water
Act and Porter-Cologne Act. The DOJ can investigate felonies
related to environmental crimes, and I believe this supports my
good-faith reporting under FWPCA.
Unfavorable Employment Actions/Retaliation
SNBC has taken unfavorable actions against me that I believe
were motivated by my protected activities:
• On July 10, 2024, SNBC obtained a temporary restraining
order (TRO), followed by a full Workplace Violence
Restraining Order on July 29, 2024 (Case No. 24CV02219).
This prohibits contact with the company and its employees,
effectively silencing my reports and causing me harm,
including intimidation and threats to my freedom of speech.
• The timing of the RO coincides with my ongoing reports about
their expansions without proper documentation, suggesting
retaliation. This has affected my prospects, as it has been used
in my criminal case (involving bail revocation despite a PC
977 waiver), leading to potential blacklisting, denial of
benefits, and reassignment of my legal status.
• Additional intimidation includes involvement of Water Board
officials like Clint Snyder and Scott Small, who I believe
downplayed my complaints and may have coordinated with
SNBC, contributing to the retaliatory actions.
These actions occurred within the last 30 days or are ongoing,
with the most recent impacts tied to my criminal hearing
began shortly after my reports intensified in 2024-2025.
Relief Requested
I request a full investigation under 29 CFR Part 24. If the
evidence supports my claim, I seek relief to make me whole,
including:
• Reinstatement of my rights to report without fear, including
vacating or modifying the restraining order.
• Compensation for special damages, including attorney fees,
lost opportunities, emotional distress, and costs related to my
criminal defense.
• Back pay or equivalent for any financial losses incurred due to
the retaliation.
• Any other remedies available under the FWPCA, such as
punitive measures against SNBC.
I am available for an interview and can provide additional
evidence, including the attached documents (2004 EPA Report
excerpt, 2016 Well Construction Summary, 2017 CEQA MND
pages). Please contact me at the above phone or email.
Thank you for your attention to this matter.
Sincerely,
Andrew Merkel
Sent from AT&T Yahoo Mail for iPhone
On Thursday, February 12, 2026, 12:27 PM, Andrew Merkel <ademco9787@att.net> wrote:
Sent from AT&T Yahoo Mail for iPhone
On Thursday, February 12, 2026, 12:21 PM, Andrew Merkel
<ademco9787@att.net> wrote:
Here’s your POC for the Federal Government.
Thank you
Andrew Merkel
Sent from AT&T Yahoo Mail for iPhone
On Thursday, February 12, 2026, 12:19 PM, EPA Public Support
<public_support@epa.gov> wrote:
Hello Andrew Merkel,
Thank you for your message. If you believe a
facility is in possible violation of environmental laws,
please report a violation through EPA's Hotline
(https://echo.epa.gov/report-environmental-
violations). You can also contact your state
environmental agency or a regional EPA office.
Contact information for state agencies can be found
here: https://www.epa.gov/home/health-and-
environmental-agencies-us-states-and-territories.
Contact information for EPA Regions can be found
here: https://www.epa.gov/aboutepa. You may also
consider contacting your local environmental/health
department.
Please don't hesitate to contact us if you require
any additional assistance.
Regards,
Rusty
Russell Wasem
ECHO Product Owner
Office of Compliance / U.S. EPA
(202) 564-7096
wasem.russell@epa.gov
On Thursday 12, February 01:28:29 AM EST, 'EPA
Public Support ' wrote:
CS0086265 - Sierra Nevada brewery
A case has been assigned to ECHO
Tier 1.
Public User Name: Andrew Merkel
Public User Email:
Ademco9787@att.net
Question: Dear OSHA Investigator:
I am filing this whistleblower complaint
under the Federal Water Pollution
Control Act (FWPCA) against Sierra
Nevada Brewing Company (SNBC),
located at 1075 East 20th Street, Chico,
CA 95928. I believe I have been
retaliated against for reporting alleged
violations of the FWPCA related to the
discharge of pollutants into navigable
waters from point sources without
proper permits or compliance. This
retaliation includes the filing of a
workplace violence restraining order
(Case No. 24CV02219, Butte County
Superior Court) against me in July 2024,
which I believe was motivated by my
protected activities, as well as potential
influence on my ongoing criminal case
in Redding, California (Shasta County),
where bail was revoked and other
procedural issues arose following my
reports.
Covered Employee and Protected
Activity
I am a private sector individual who has
engaged in protected activities under
the FWPCA. Although I am not a current
employee of SNBC, the FWPCA’s
whistleblower protections extend to any
person who reports violations, including
non-employees, as long as the reports
pertain to discharges of pollutants into
navigable waters. My protected activities
• Providing information to regulatory
agencies and the public about alleged
violations of the FWPCA, including
unpermitted expansions and potential
bypassing of on-site wastewater
treatment at SNBC’s Chico facility,
which could result in increased organic
loadings (up to 130%) into the City of
Chico’s sewage treatment works,
adversely impacting operations related
to oxygen transfer, alkalinity demand,
and nutrient dosing. This is based on
the 2004 U.S. EPA NPDES Compliance
Evaluation Inspection Report for SNBC.
• Reporting that SNBC’s Production Well
No. 1 (constructed in 2016 under Permit
EHWL16-0014 and CEQA17-0005) is
being used to support facility
expansions (e.g., the CanDo co-packing
facility launched in July 2025) without
proper CEQA documentation or updates
to wastewater discharge permits,
potentially violating point source
discharge limits under the FWPCA and
Porter-Cologne Water Quality Control
Act. The well was approved only for an
independent water supply for existing
operations, not to enlarge the facility’s
footprint or increase discharges.
• Participating in or assisting with
potential proceedings by sharing
documents such as the 2016 Well
Construction and Testing Summary
(showing capacity up to 800 gpm) and
the 2017 Draft Mitigated Negative
Declaration (IS/MND), which highlight
site-specific risks near toxic sites (e.g.,
Chico Scrap Metal and Victor Industries)
and hydrology/water quality concerns.
• Refusing to remain silent about these
unsafe and unhealthful conditions,
which I reasonably believe pose risks to
public health and the environment,
including navigable waters connected to
Chico’s sewage system.
These reports began as early as 2022
via public posts and complaints to
Regional Water Quality Control Board
(RWQCB) and Butte County
Environmental Health. I have continued
to provide information, including
evidence of no public CEQA or permit
records for recent expansions, which
could lead to unpermitted pollutant
discharges.
Unfavorable Employment
Actions/Retaliation
SNBC has taken unfavorable actions
against me that I believe were motivated
by my protected activities:
• On July 10, 2024, SNBC obtained a
temporary restraining order (TRO),
followed by a full Workplace Violence
Restraining Order on July 29, 2024
(Case No. 24CV02219). This prohibits
contact with the company and its
employees, effectively silencing my
reports and causing me harm, including
intimidation and threats to my freedom
of speech.
• The timing of the RO coincides with my
ongoing reports about their expansions
without proper documentation,
suggesting retaliation. This has affected
my prospects, as it has been used in my
criminal case (involving bail revocation
despite a PC 977 waiver), leading to
potential blacklisting, denial of benefits,
and reassignment of my legal status.
• Additional intimidation includes
involvement of Water Board officials like
Clint Snyder and Scott Small, who I
believe downplayed my complaints and
may have coordinated with SNBC,
contributing to the retaliatory actions.
These actions occurred within the last
30 days or are ongoing, with the most
recent impacts tied to my criminal
hearing continuance (originally 45 days
from late 2025). The retaliation began
shortly after my reports intensified in
2024-2025.
Relief Requested
I request a full investigation under 29
my claim, I seek relief to make me
whole, including:
• Reinstatement of my rights to report
without fear, including vacating or
modifying the restraining order.
• Compensation for special damages,
including attorney fees, lost
opportunities, emotional distress, and
costs related to my criminal defense.
• Back pay or equivalent for any
financial losses incurred due to the
retaliation.
• Any other remedies available under
the FWPCA, such as punitive measures
against SNBC.
I am available for an interview and can
provide additional evidence, including
the attached documents (2004 EPA
Report excerpt, 2016 Well Construction
Summary, 2017 CEQA MND pages).
Please contact me at the above phone
or email.
Thank you for your attention to this
matter.
Sincerely,
Andrew Merkel
Take me to the Case
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