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Page 3 of 5 <br /> From: Mike Infurna [EH] [mailto:MInfurna@sjcehd.com] <br /> Sent: Monday, November 07, 20119:31 AM <br /> To: Eisert, James <br /> Subject: RE: Tracy, CA - Maintenance Facility - Well Destructions <br /> James, <br /> I'll print out your attachments and get back to you if there are any concerns. <br /> Initially, without knowing the depth of the VMP wells (we anticipate they are <br /> no deeper than 10 feet deep since groundwater is around 12 to 15 feet <br /> deep), you cannot just pull on the tubing and expect to get it all (as if we <br /> know what all is). Plan on digging these up (or at least one to verify the <br /> well's construction) to prove that you know where the tip/screened interval <br /> is and that your proposed procedure meets the County requirements to <br /> "remove the contents" of the well. — understood, we will remove the <br /> contents of these wells using a 8-inch diameter auger to a depth of 10-feet <br /> below ground surface (bgs) — please understand these vapor monitoring <br /> points are constructed with 1/4 —inch diameter tubing, we don't anticipate <br /> that this would be considered a "conduit" to the subsurface if we didn't <br /> remove all the tubing. Regardless, we will over-drill to 10 feet bgs. <br /> And to repeat, pressure grouting has rigid requirements before it can be <br /> approved. Area of contamination as noted in our Ordinance is minimally <br /> accepted to mean NOT CONTAINING any contamination. Without this <br /> data to support that claim, pressure grouting is not permitted. <br /> Known construction is also a pressure grout requirement. Not knowing how <br /> the well is constructed, to include total depth, pressure grouting cannot be <br /> approved. <br /> The data on Table 3 provides verification for MW-2B and MW-16B. These <br /> two are ok for Pressure grouting. — understood, Table 1 has been updated <br /> to indicate only wells MW-2B and MW-16B will be pressure grouted. All <br /> other wells will be removed. Only the wells proposed for destruction are <br /> shown on the revised Table 1 . <br /> MW-3B, MW-3C, MW-17B, MW-18B and MW-21 B are NOT listed on Table <br /> 3. No data has been submitted to support that they are not impacted. As <br /> such, they do not qualify for pressure grouting. <br /> Please modify Table 1 to include my requirements and resubmit. Do NOT <br /> include wells NOT scheduled for well destruction please. Revised Table 1 <br /> is attached. <br /> 11/8/2011 <br />