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SA N s J O A Q U I N Environmental Health Department <br /> COUNTY— <br /> Because the annular space of this well is already filled with sand/gravel from 155 <br /> feet to 60 feet and bentonite grout from 60 feet to surface, there is no physical <br /> way to extend or deepen the existing seal from 60 feet to 100 feet. Because this <br /> well cannot meet the minimum requirements of the San Joaquin County Well <br /> Standards for domestic supply, it cannot be approved as such. This standard has <br /> been enforced for as long as I can remember (this is the purpose of EHD) and <br /> allowing irrigation wells to be used for domestic supply has never been a practice <br /> in San Joaquin County, as this does not protect public health. <br /> Irrigation or Ag wells are allowed a 50-foot annular seal but, when the standards <br /> were written, they were never meant to be co-located with wells used for domestic <br /> supply and they were never meant to be used for domestic supply. Ag wells are <br /> constructed to maximize the sand/gravel pack to maximize water production for <br /> irrigation purposes. Domestic wells are constructed to a obtain a potable water <br /> supply to be used for drinking, cooking, bathing and sanitation and so are sealed <br /> to a greater depth to protect health with the understanding that the shallow water <br /> table is subject to contamination from a variety of sources." <br /> 3- EHD issued an invoice to Mr. Hussein for the review of his Manure Management Plan <br /> after he had already paid a fee for review. <br /> The information provided by Mr. Hussein about these issues has been helpful in identifying <br /> areas of concern and allowed me the chance to further research the issues. I have, or propose, <br /> to address each as follows: <br /> 1- THE OWTS CONSIDERED AN "ENGINEERED SYSTEM" REQUIRING <br /> MONITORING AND AN ANNUAL PERMIT. <br /> discussed this concern with EHD-hired consultant, Norm Hantzsche, P.E., of Questa <br /> Engineering. Mr. Hantzsche, P.E., was hired for just this purpose, to assist as EHD's OWTS <br /> subject matter expert due to the lack of in-house expertise and staffing shortages within EHD <br /> and more importantly, within the Land Use unit that reviews projects like Mr. Hussein's. <br /> Mr. Hantzsche, P.E. advised that it would be reasonable to consider this OWTS system as low <br /> risk to groundwater due to the very limited use, 2-days per week plus holidays, and the fact that <br /> the system is oversized for the use. The volume of wastewater generated for the size of the <br /> property makes this a standard system. <br /> Accordingly, I sent a letter dated December 6, 2019, to Mr. Hussein stating that EHD is removing <br /> the OWTS "engineered system" requirements for monitoring and annual permit, provided that <br /> Mr. Hussein continues to use the OWTS for 2 days a week and on certain holidays consistent <br /> with this Use Permit approval. <br /> 2 of 4 <br />