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Andrew Richle - 2 - 26 March 2024 Based on the information provided in the Work Plan, Central Valley Water Board staff generally concur with the proposed approach for well destruction with the following comments: 1. The City should note that the wells are being permanently "destroyed" as opposed to "abandoned". 2. The Work Plan indicates that soil cuttings and decontamination water will be stored in UN- rated, 55-gallon steel drums with the waste material profiled for off-site disposal. Many of the wells are located within public right of ways and the Work Plan lacks transparency on where these drums will be staged during profiling, analysis, and disposal scheduling. By 9 April 2024, the City needs to submit an addendum to the Work Plan identifying where the drummed waste will be staged and how the drums will be labeled/identified. 3. Pursuant to California Water Code 13751, a Well Completion Report is required to be completed by the driller and filed with the California Department of Water Resources for each well destroyed Well Completion Reports (ca.gov). The City needs to include copies of the well completion reports as part of the Well Destruction Report. 4. The Well Destruction Report needs to include copies of all manifests, bills of lading, and ultimate disposition of the waste materials generated as part of the well destruction effort. In summary, Central Valley Water Board staff generally concur with the Work Plan. By 9 April 2024, the City shall provide an addendum to the Work Plan designating where drummed waste will be staged and how the drums will be labeled/identified. The final Well Destruction Report shall be submitted within four weeks of completion of the field activities and shall include proposed documentation material referenced in the Work Plan as well as copies of the Well Completion Reports and waste disposal information. Please provide Board staff with a minimum of 72- hours' notice prior to fieldwork so that we have an opportunity to observe the work. If you have any questions regarding this letter, you may contact me by telephone at (916) 464- 4671 or by email at Robert.Fagerness(a�waterboards.ca.gov. Robert Fagerness, P.E. Water Resource Control Engineer Private Sites Cleanup Unit Digitally signed by Kristin 99 VLOF13381 Kristin �` Shelton tR�x FNFtg$ Date:2024.03.26 08:36:16 Shelton _07'00, p C74503 Kristi Shelton, P.E Senior Water Resource Control Engineer CIVIL Private Sites Cleanup Unit �kOF cc: Via electronic submittal Charles Swimley, City of Lodi Public Works Director Varinder Oberoi, PE, Civil Hydro Tech, Sunnyvale