SITE INFORMATION AND CORRESPONDENCE_FILE 1

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BOARD OF TRUSTEES A. R. Carver, M.i! Pres. Patricia E. Vannucci, Secy Gerald Cromwell James F. Culbertson Russell Carter, M.D. Fern Bugbee Jack T. Jennings, D.D.S. W. J. Lange Mary Anna Love 31 April 1980 SAN JOAQUIN LOCAL HEALTH DISI , tICT 1601 East Hazelton Avenue, P.O. Box 2009 Stockton, California 95201 (209)466-6781 Jack J. Williams. M. D., District Health Officer Mr. John A. Harris, Manager Environmental Health & Safety Occidental Chemical Company P. 0. Box 198 Lathrop, CA Dear Mr. Harris: SERVING City of Tracy San Joaquin County City of Escalon City of Lodi City of Manteca City of Ripon City of Stockton San Joaquin County San Joaquin County SUBJECT: LOCAL REQUIREMENTS FOR WELL PERMITS FOR GROUNDWATERS AND SOILS PROGRAM This letter is in response to your request of last week that this agency review the requirements of law (Ordinance 1862) and Local Regulations as such have been applied to the referenced subject. Specific considerations have been given to the small amount of graphic data pro- duced from the "pilot wells" which have been drilled to date. Conceptual extra- polations from the data are at best difficult to conceive, and the requirements which anteceded the initiation of well drilling are substantially appropriate. Two basic issues exist in your recent request, as again presented to me during our meeting at your office yesterday, i.e.: 1. The need for our capitulation to your view that when problems arise in drilling a well under permit, that a withdrawal of the bit and removal to an adjacent site within 10-15 feet for drilling a second well, should not require a second permit. 2. The requirement that all holes be destroyed with "neat cement" from the hole's most distal depth, to the ground surface, is not warranted; each of these bases is discussed briefly hereafter. 1. The need for separate permits for each well is a local statutory and regu- latory requirement. On that basis, relief cannot be granted from requirements. Additionally, your discussions with my staff and with me regarding the col- lapse of holes with substrata during, or shortly after incremental withdrawal of drilling components, are supported with field observations by inspecting personnel. These conditions reemphasize the need for proper distruction under inspection and permit. When drilling operations are removed to a secondary site adjacent to the "failed" primary well site, and subsequently both holes are later consequentively destroyed with "neat cement", an enhance- ment of the collapsibility of such holes occurls,.