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Michael Kith [EH] From: Scott Forbess <SForbess@Geosyntec.com> Sent: Monday, August 06, 2018 2:11 PM To: Linda Turkatte [EH] Cc: Michael Kith [EH]; Roger_Smith@oxy.com; Nicole Gotberg; Mike Cramer Subject: RE:Issue with permit numbers WP0038566 and WP0038567 Dear Ms. Turkatte, I had further discussions with Mr. Michael Kith this morning in which he cited the California Department of Water Resources California Well Standards as a basis for requiring the grout seal to be poured. We have reviewed the sections cited by Mr. Kith and they do not justify the requirements being placed upon us. Mr. Kith referenced sections of Bulletin 74-81, Water Well Standards, which was first issued in 1968 and updated in 1981. In 1986 the California Legislature amended the California Water Code specifically to include requirements for monitoring well standards. Monitoring wells were previously assumed by the Department to be covered by the collective term "well" in the law. Bulletin 74-90 updated the California Well Standards to provide standards for monitoring wells. Bulletin 74-90, Part II Monitoring Well Construction, Section 9. Sealing the Upper Annual Space, Part F. Placement of the Annual Seal Material does not state that sealing for a monitoring well needs to be conducted in a single continuous lift. This section does say additional discussion on placement of annular seals can be found in Section 9, Section 13, and Appendix B, of the Water Well Standards. Monitoring Wells Standards are defined separately from Water Well Standards in the California Well Standards per the 1986 changes to the California Water Code. Water Wells are defined in the California Well Standards as ""any artificial excavation constructed by any method for the purpose of extracting water from or injecting water into the underground". Monitoring wells are defined in the California Well Standards as "any artificial excavation by any method for the purpose of monitoring fluctuations in groundwater levels, quality of underground waters, or the concentration of contaminants in underground waters." Section 9, Section 13, and Appendix B, all apply to Water Wells, not Monitoring Wells. Even though these standards no not apply to monitoring well, it is of note that even in Appendix B of the Water Well Standards "suggested methods for sealing the annual space" provides allowance for the seal to be placed in lifts when the Water Well annular seal is more than 100 feet deep. Also note the Monitoring Well Standards Section 12, Part A.1 state that for monitoring wells special consideration should be given to the selection of the well casing material for chemical compatibility with the environment that the monitoring wells are installed in. Due to the presence of potentially corrosive ammonia concentrations in groundwater in the area, PVC casing was selected for the design of the project monitoring wells. During a discussion on Friday, August 8th, Mr. Kith indicated that County may allow the seal to be placed in multiple lifts if Geosyntec was willing to certify that constructing the well in this manner was protective of groundwater and consistent with the California Well Standards. Geosyntec is willing to have a licensed professional in the State of California make this certification. 1