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Plates 2, 3, and 4 have been prepared and are attached to this letter. All three of these plates <br /> have a base that is derived from the air photo in Plate 1. The features the RWQCB requested be <br /> included are evident in those photos. <br /> Item#3 <br /> Based on a presumed west-northwest groundwater flow direction, the well locations in the <br /> proposed land application area might be improved. Please approximately locate the property <br /> lines and reevaluate the western most well location. Additionally, considering the presumed <br /> groundwater flow direction, please reevaluate the northern most well location and resubmit <br /> Figure 1. <br /> While the RWQCB is correct that we note in our work plan that the regional groundwater <br /> gradient is towards the northwest, our workplan also notes that groundwater in the area of the <br /> other California Natural Products properties flows towards the east. The proposed monitoring <br /> well locations have been shifted (see Plate 4). However, please note that once the groundwater <br /> flow direction has been evaluated for that parcel, there is a potential that an additional <br /> monitoring well may be needed. <br /> Item#4 <br /> The use of neat cement with up to five percent bentonite by weight is acceptable as an annular <br /> seal. The wellheads shall be set in concrete in accordance with Section 13.14.4 of the San <br /> Joaquin County Environmental Health Department's (SJCEHD's) Well Standards. <br /> The San Joaquin County Public Health Services Department, Environmental Health Division <br /> frequently also accepts sand-cement slurry (a.k.a. mortar) with bentonite added. The sand in <br /> mortar also acts to reduce shrinkage and provides for additional strength over neat cement. Since <br /> it is mortar and not concrete (no gravel) it is still able to be tremmied. However, the PHS/EHD <br /> permit for this job does state neat cement with bentonite. Therefore, we agree with the <br /> statement. <br /> Item#5 <br /> If conditions in the borehole allow, it is recommended that the sand pack be surged prior to <br /> installing the bentonite seal consistent with SJCEHD Well Standards Section 13.10.8. <br /> We agree with the requirement. <br /> 20-4587-01.SAP/2011 L402 Page 2 of 3 <br /> Copyright 2001,Kleinfelder,Inc. lune 13,2001 <br /> KLEINFELDER 2825 East Mprtle Street,Stockton,CA 95205-471)4 131191 948-1345 (209)948-0621 tax <br />