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. • Page 2 of 3 From: "Mike Infurna [EH]" <Mlnfurna@sjcehd.com> Date: Fri, 27 May 201111:14:13 -0700 To: Barbara Mickelson<bmickelson@ameinc.net> Cc:Colin Klinesteker<CKlinesteker@_a_meinc.net> Subject: Georgia Pacific Well destruction work plan Ms. Mickelson, Mr. Klinesteker, I am the San Joaquin County Environmental Health Department(EHD) regulator assigned to the Georgia Pacific Tracy Plant. I have received your May 25, 2011 Work Plan for Well Destruction. Thank you. the plan was very concise and met nearly all of the EHD's concerns. almost. No problem with the air sparge well's destruction by drilling out. It's the 'pressure grout'for 21 monitoring wells I have some concerns with. In order for a well to qualify for the pressure grouting detailed in the SJ County Well Ordinance, the well must meet all of the following concerns: 1-be of known construction, 2-be unobstructed and clear to total depth of construction and, 3-not be in an area of contamination (interpreted as LAST water/air sample is ND at acceptable QA/QC-detection limits) I reviewed the last/most recent GW Monitoring event on Geotracker for this site. The gw data table for the monitoring wells shows the last date on the table was March 15-16, 2006. Is this correct? this was the last gw sampling event? if so, then 17 wells DO NOT qualify for pressure grout destruction as they contained detectable amounts of Chloroform, TCFM, and/or 111,TCA or DCE. as such, these wells cannot be destroyed by pressure grouting. You can contact me to determine which of the wells I have concerns with. Please provide me with more current gw lab data to support conclusions that the wells are ND. If none is available, you will have to modify the work plan to either drill out these impacted wells or wire- line explode them in place. I'm also concerned with wells listed as "abandoned" on the tables. Abandoned, in EHD terms means left unattended, unmonitored, not used but still in place, all things NOT good for me to read into. Destroyed is a better term. Destroyed under EHD permit is the best way to list a well NO longer present. I can account for all but BC-8. My records do not list this well as properly destroyed. Can you enlighten me please? thank you. I've attached our department webpage that provides you with blank a Well Permit Application Form, an information sheet, and a blank Master File Record form (MFR), that is required with every permit application. If you have any questions after you review the forms, you may contact me by email or phone. hftp://www.sgov.o you should.know that an EHD permit is required for the actual site parcel as well as for each parcel NOT owned by the RP of the site. I am under the impression wells are located, 1-onsite, 2- offsite, City right of way, 3-offsite, Reclamation district property, and 4-offsite, private party ownership. As such, 4 separate EHD permit applications and fees will be required. Access agreements are also required to be submitted to the EHD before a well destruction permit can be issued for parcels NOT under the RP's control/ownership. A City encroachment is also typically required in the City of Tracy and you should take steps now to deal with the City's Public Works Dept. Reclamation Districts also typically need a substantial amount of time to generate an access agreement before you will be 6/10/2011