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Adrienne Ellsaesser [EH] From: Adrienne Ellsaesser [EH] Sent: Thursday, January 23, 2014 10:58 AM To: Phil Goalwin (pgoalwin@e2cr.net); 'axu@e2cr.net' Cc: rcervantes@waterboards.ca.gov; Nuel Henderson [EH] Subject: Busy Bee Well Destruction Requirements Attachments: Well Destruction Evaluations.doc Hello Phil and Aiguo, Nuel Henderson, our Engineering Geologist, has reviewed the analytical data supplied by your agency of 91 wells that were used to investigate and remediate the Busy Bee cleanup site. He determined 45 wells may be destroyed by pressure grouting methods and 46 wells require over drilling destruction methods in accordance with the San Joaquin County Well Destruction Standards (see attachment). We have discussed our findings, the issues you provided concerning this site, and your request for pressure grouting all the wells with Donna Heran our Director and Roberto Cervantes, with Central Valley Regional Water Quality Control Board who provided oversight for this cleanup site. Our Department is obligated to protect groundwater quality and one way the water quality can decline is through the well. The University of Nebraska Grout Taskforce has evidence that the annular seal of wells can provide a physical connection between sources of pollution and groundwater. Their findings support our concern with PCE and TCE residuals remaining in the soil and/or groundwater that these wells pass through. If these wells remain in place and are pressure grouted instead of over-drilled, vertical movement of contaminants can further degrade the groundwater. Our local Well Destruction Standards allows for destruction by pressure grouting method when construction of a well is known and the well has been maintained in accordance with our Standards (tests at non-detectable levels for contaminants and/or is located in an area known not to be contaminated). If the well construction is unknown or the well is located in an area of known or suspected pollution or contamination, the well shall be destroyed by removing all material in the original borehole and the resulting borehole grouted to be protective of the groundwater. We are requiring the well destruction permit to be amended to include over-drilling/removal of the 46 wells listed on the attached document. If you would like to discuss our findings we are available to set up a conference call with all concerned. Another issue we need to resolvei in regard to the number of wells that require destruction for closure of the site. The December 18, 2011Well Destruction Permit Application letter lists 91 wells consisting of; 23 ground water monitoring wells, 38 air sparge wells, 29 soil vapor wells and one groundwater extraction well. Roberto Cervantes knows of 93 wells that require destruction. How many wells require destruction for the site to be closed? Your well destruction permit application submittal notes 91 wells, but the $11,455 amount of the checks only covered the permit fee for 88 wells ($11,375), with $80 remaining. Our monitoring well destruction permit fees are $375 for the inspection activity fee, plus $125 permit fee for each well. We require an additional $295 to issue(1 Well destruction permits for a total of $11,750. If 93 wells are to be destroyed, then $250 mu be submitted in addition to the $29,5 Respectfully, Adrienne Kpw Adrienne Ellsaesser, REHS 1