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Page 3 of 4 <br /> I was under the impression from your discussion with your consultant, that you wished to <br /> destroy them. I was even advised that Exxon would even be destroying the wells <br /> associated with Case#2, the USA Gas portion. <br /> Am I wrong? did I misinterpret? <br /> In mid September 2011, in discussions with your consultant, I advised that a work plan <br /> to destroy the wells OR a monitoring and reporting plan is to be submitted in order for <br /> NFA procedures to advance and the responsible parties receive their official No Further <br /> Action letter ("closed site"). Emails with Mr. Scott Bittinger discussed the permit fees and <br /> the acceptable methods in San Joaquin County for destroying the wells in order to <br /> complete the closure requirements for the site. <br /> As of today, I have not received a work plan for well destructions ora MRP. <br /> Just so you know the lastest history of the NFA procedures for this location, on August <br /> 18, 2011, the CVRWQCB concurred with our July 20, 2011 letter of intent to 'close' this <br /> site, both Case #1 & Case #2. Their letter only noted that until "all case closure activities <br /> have been completed and the County issues a Case Closure letter, the site will be <br /> considered an open case". <br /> According to San Joaquin County Well Ordinance, a well must serve its intended <br /> purpose or be destroyed. Monitoring wells must 'monitor' the groundwater- injection <br /> wells inject—vapor extraction wells, extract. If you have no intention to use the wells, <br /> they must be destroyed/removed under EHD approval and permit. Bottom line, use them <br /> or destroy them. <br /> If you desire to KEEP the wells, then a monitoring and report plan must be submitted and <br /> approved by the EHD. Once it is approved, the UST investigation/remediation part of the <br /> site/phase will be deemed adequate and the NFA letter will be issued. Reporting of the <br /> monitoring and sampling of the wells will start immediately thereafter. Eventually the <br /> wells must be destroyed if the monitoring and sampling cease. <br /> If you feel the need, I will generate an official letter advising you (Exxon, and also USA <br /> Gas) of the same information noted in this email. I will direct a due date for submittal of a <br /> proposal that lists the methods and materials to destroy the wells. I will also direct a due <br /> date the work will begin on & offsite and a date the report of findings and manifests for <br /> the IDW generated for this phase will be submitted to Geotracker. <br /> It was my intention to hasten the progress towards the RPs getting their NFA letters by <br /> working with the consultants and securing an agreement on methods, materials, and <br /> dates by email. A letter was never requested and I was under the impression we were <br /> both working towards a common goal. <br /> Let me know if you have other plans. <br /> I have four other sites going through NFA procedures and many many well destructions <br /> and I need all the time I can get to not delay their scheduled work or my inspections. I <br /> would appreciate knowing your plans and intentions for these wells as soon as you <br /> decide. <br /> thank you, <br /> 10/3/2011 <br />