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0 Page 1 of 16 <br /> Mike Infurna [EH] <br /> From: Josh Ewert[ewert@geoconinc.com] <br /> Sent: Tuesday, December 20, 2011 1:56 PM <br /> To: Nuel Henderson [EH] <br /> Cc: Adrienne Ellsaesser[EH]; Mike Infurna [EH]; 'Jim Brake'; 'Gleason, Nicole' <br /> Subject: RE: 5400 and 5606 Pacific Avenue, Stockton -Well Destruction Information <br /> Nuel, <br /> Thank you for clarifying and I will proceed accordingly. <br /> -Josh Ewert <br /> From: Nuel Henderson [EH] [mailto:nhenderson@sjcehd.com] <br /> Sent: Tuesday, December 20, 2011 1:03 PM <br /> To: Josh Ewert <br /> Cc: Adrienne Ellsaesser [EH]; Mike Infurna [EH]; Jim Brake; Gleason, Nicole <br /> Subject: RE: 5400 and 5606 Pacific Avenue, Stockton - Well Destruction Information <br /> Josh, <br /> I have reviewed and considered your arguments of 13 December 2011 regarding destruction requirements for <br /> monitoring wells MW-16 and MW-32, and air sparging wells AS-14, AS-15, AS-17, AS-18, AS-20 and AS-21. <br /> Regarding your interpretation of section 13.17.6 of the San Joaquin County Well Standards: my interpretation of <br /> the "and/or"condition makes the latter condition the controlling consideration. Read it with either conjunction alone <br /> and it becomes clear that if the well is in an area of known or suspected contamination, the well contents must be <br /> removed. The occasional TPHg and benzene hits in MW-16 and MW-32 puts the wells in areas of known or <br /> suspected contamination, so the well contents must be removed. <br /> I agree with much of what you say about the air sparging wells, however 13.17.6 still applies. Our view is that the <br /> small casings should be grouted prior to drilling the well out to provide some degree of protection should the drill <br /> drift off the well. Mike's recommendation to use 15-inch augers is just that—a recommendation. It is up to you to <br /> propose the method you believe will be most effective for fulfilling all the destruction requirements; the EHD will <br /> review the proposed method and either approve or disapprove it based on the technical aspects and our <br /> experience in San Joaquin County. <br /> Regards, <br /> Nuel Henderson <br /> From: Josh Ewert [mailto:ewertCalgeoconinc.com] <br /> Sent: Tuesday, December 13, 20117:07 AM <br /> To: Nuel Henderson [EH] <br /> Cc: Adrienne Ellsaesser [EH]; Mike Infurna [EH]; 'Jim Brake'; 'Gleason, Nicole' <br /> Subject: RE: 5400 and 5606 Pacific Avenue, Stockton - Well Destruction Information <br /> Good Morning Nuel, <br /> Thank you for your response to my requests. I would still like to know if you also had any comments <br /> regarding wells MW-16 and MW-32. My original comments were as follows: <br /> "MW-16 and MW-32—You state that these wells are within areas of contamination as shown on <br /> AECOM's 9-22-10 Figures 14 and 15. Would you reconsider this due to the fact that these data points are <br /> 12/20/2011 <br />