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SAN JOAQUIN COUNTY �P' Greatness grows here. t _o _, March 30, 2022 Lauren M. Sipich, PG Arcadis U.S., Inc. 101 Creekside Ridge Court, Suite 200 Roseville, CA 956784 Environmental Health Department RE: Injection Well #2 (IW -2) Destruction Proposal by Pressure Grout Former Occidental Chemical Corporation — Lathrop Facility 16777 Howland Road, Lathrop, Ca. 95304 APN 198-180-05, SR0085055 Jasjit Kang, REHS, Director Muniappa Naidu, REHS, Assistant Director PROGRAM COORDINATORS Robert McClellon, REHS Jeff Carruesco, REHS, RDI Willy Ng, REHS Melissa Nissim, REHS Steven Shih, REHS Michelle Henry, REHS The San Joaquin County (SJC) Environmental Health Department (EHD) has reviewed Arcadis' request for variant (the requested variant) to destroy the injection well IW -2 on February 24, 2022 email and the Well Permit Application received by EHD on March 21, 2022, by pressure grouting from 275 feet below surface grade (bsg) to surface, leaving the 510 -foot deep stainless steel well casing, the (approximately) 45 -foot deep conductor casing in place, as well as the sand which has infiltrated the well from 510 feet bsg to 275 feet bsg. Arcadis stated the following: Well Casing Failure is present at about 275 feet bsg Two rounds of sand removal by development/bailing between October and December (year not specified) were unsuccessful. Lauren Sipich stated Arcadis is not considering destroying the well casing by detonation since the technology may "fracture" the Corcoran Clay layer, resulting in potential contamination of the upper aquifer with the less desirable groundwater from below the Corcoran Clay layer. The EHD does not approve the requested variant to destroy IW -2 by pressure grouting without removing the well casing and leaving the sand inside the well, for the following reasons: SJC Well Standards Section 13.7.6: If the well ... is located in area of known or suspected pollution or contamination the well shall be destroyed by removal all material within the original borehole (including the well casing screen filter pack and annular seal), and the created hole filled completely with appropriate sealing material.. Pressure grouting leaving the well casing and material does not meet this requirement. SJC Well Standards Section 13.17.3: Any obstructions found in the well or boring shall be removed before filling and sealing operations begin. Leaving the sand (which is not an approved sealing material per Section 4.7.3, and 13.17.7), in the well from about 235 feet bsg to the bottom at 510 feet bsg does not meet this requirement. SJC Well Standards Section 13.9.1: If a permanent conductor casing is to be installed or temporary conductor casing cannot be removed, the monitoring well borehole shall be at least 4 inches greater than the outside diameter of the conductor casing. The inner diameter of th3e permanent conductor casing shall in turn be at least 4 inches greater than the outside diameter of the well casing. Appropriate sealing material shall be placed between the permanent conductor casing and the borehole wall and the well casing and the conductor casing. The document provided by Arcadis including the IW -2 well log dated March 15, 1982 and the Well Drillers Report No. 072877 1868 E. Hazelton Avenue I Stockton, California 95205 1 T 209 468-3420 1 F 209 464-0138 1 www.sjgov.org/ehd