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Page 1 of 15 <br /> Nuel Henderson [EH] <br /> From: Josh Ewert[ewert@geoconinc.com] <br /> Sent: Tuesday, December 13, 2011 7:07 AMyy Nc <br /> To: Nuel Henderson [EH] �/ 2wy)� get f <br /> Cc: Adrienne Ellsaesser[EH]; Mike Infurna[EH]; 'Jim Brake'; 'Gleason, Nicole' PAW I 1 t <br /> L lcK�tts�� <br /> Subject: RE: 5400 and 5606 Pacific Avenue, Stockton -Well Destruction Information y /I <br /> wlb cit r <br /> Good Morning Nuel, <br /> Thank you for your response to my requests. I wou/Iinow if you also had any comments regarding <br /> wells MW-16 and MW-32. My original comments : <br /> "MW-16 and MW-32—You state that these wells as of contamination as shown on AECOM's 9-22- <br /> 10 Figures 14 and 15. Would you reconsider this dhat these data points are estimated results?Or <br /> in the case of MW-32,the estimated result o .6µg/hof benzene is less than its ESL, MCL and WOO and thereby <br /> doesn't fit the county's definition of contamination or pollution?" occas u 4 tow 711117 { <br /> Regarding the six 1-inch-diameter wells(AS-14,AS-15,AS-17,AS-18,AS-20 and AS-21) and Section 13.17.6: "If the <br /> well construction is unknown and/or is located in an area of known or suspected pollution or contamination,the <br /> well shall be destroyed by removing all material within the original borehole (including the well casing, screen, <br /> filter pack, and annular seal); and the created hole filled completely with appropriate sealing material. " <br /> It appears to me that that section 13.17.6. of the San Joaquin County Well Standards does not apply to these <br /> wells.The use of"and/or"and the fact that the construction details of the wells are known, gives the County the <br /> ability to deem this section not applicable and thereby allow these wells to be pressure grouted while still <br /> remaining in compliance with the County Standards. <br /> I would just like to restate that I am only requesting this because of the unusual circumstances these 1-inch- <br /> diameter wells present. I feel that following Mike Infurna's recommendation of using 15-inch augers to overdrill <br /> an 8-inch grout column opens us up to more potential problems. For example, as I understand it,the theory for <br /> advancing the 15-inch augers is to essentially use the 8-inch-diameter column of grout to guide the augers <br /> thereby keeping them centered on the well. Considering that these wells range between 62 and 105 feet in <br /> depth, what happens if the augers wander off the well (which is a reasonable possibility based on my experience <br /> and talking with multiple drilling companies about this)? By the time we would see evidence of the augers <br /> wandering(assuming we do),we would have lost our grout column guidance and have no assurance that any <br /> further drilling would benefit us in destroying the well.Also,we'd be unable to re-center on the well since augers <br /> are at depth and sealing the portion of the well beneath where the augers have wandered would become <br /> significantly more difficult.The only option I could think of to continue destroying the well would be advancing <br /> larger and larger augers which would require tripping into and out of the boring which in itself is undesirable <br /> given that some of these wells span multiple hydrostratigraphic units. Now granted, this is a worst case scenario <br /> but it is both a possibility and significantly less protective of the County's groundwater than any realistic worst <br /> case scenario I can think of involving pressure grouting.As such, I feel strongly that the pressure grouting these <br /> wells is warranted. <br /> In summary,given that the County Standards as written will allow for the destruction of these 1-inch wells by <br /> pressure grouting and given the problems involved in attempting to destroy the wells by overdrilling, I <br /> respectfully request the county reconsider its position and allow us to pressure grout these 1-inch-diameter wells. <br /> Thank you, <br /> 12/20/2011 <br />