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1868 East Hazelton Avenue <br /> Stockton , CA 95205 <br /> Ph (209) 468-0343 <br /> Fax (209)468-0341 <br /> aellsoesser@s,icehd.com <br /> From: Phil Goalwin [mailto:pgoalwin@e2cr.net] <br /> Sent: Friday, December 27, 2013 12:13 PM <br /> To: Adrienne Ellsaesser [EH] <br /> Cc: 'Tim Hasler' <br /> Subject: FW: Former Busy Bee Cleaners - Recent Groundwater Analytical Data <br /> Importance: High <br /> Hi Adrienne <br /> Tim Hasler forwarded your email message to me and asked me to respond. <br /> As you may be aware,this project/remediation was the result of a long and protracted litigation. The litigation was <br /> settled via a performance-based remediation contract.The Central Valley RWQCB is the lead agency overseeing the <br /> remediation efforts.The RWQCB has concurred that project objectives have been met and that site closure is <br /> appropriate. A workplan for well destruction was sent to the RWQCB.The RWQCB approved this workplan by letter <br /> dated June 10, 2013 (letter provided in permit application package).They provided this approval with concurrence from <br /> the City of Lodi. <br /> We are aware of San Joaquin County's requirements for well destruction/abandonment.These requirements differ from <br /> State of California Well Destruction Standards in so far as they require drill-out of any wells that have contamination. <br /> Contamination is not defined in the San Joaquin County Well Destruction guidance document. The RWQCB has <br /> determined that concentrations in the site wells are sufficiently low to approve the site for closure. Additionally, the <br /> wells noted in your email below have concentrations below the State of California Maximum Contaminant Level (MCL) <br /> for drinking water.Therefore, we believe that wells with concentrations below MCL are not "contaminated" and <br /> destruction via pressure-grouting is appropriate at this site. <br /> As an aside,the settlement of this litigation involved a "remediation-only" performance contract.The settlement of this <br /> matter is being overseen by the Federal Court in Sacramento.This contract did not provide funding for well destruction. <br /> The funding for well destruction was negotiated between the parties and involved a high degree of cooperation to make <br /> any funds available.The Federal Court also approved the agreement for well destruction funding. The eventual <br /> agreement did not provide sufficient funding to destroy the wells by over-drilling.The cost difference between pressure- <br /> grouting and over-drilling is substantial (>$100,000) given the number of wells. If over-drilling of the wells is going to be <br /> a requirement,then the parties must re-negotiate the funding and get this approved by the Federal Court.There is little <br /> to no chance that the parties will agree to the extra costs and therefore will have to go before the Federal Court to have <br /> them decide.This could take many months, if not years. Meanwhile,the wells will remain open and the site will not <br /> receive closure. <br /> I am asking you to re-consider your position with regard to the method of well abandonment, as I believe it is in <br /> everyone's best interest to finalize the site closure particularly in light of the remaining concentrations(below MCL) in <br /> site wells. <br /> Respectfully Submitted, <br /> 3 <br />