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San Joaquin Countv <br /> 3➢� <br /> DIPECTOR+ <br /> � l l, ,., <br /> G � ren.RENS <br /> Z l cf ID -st 'C-1 Apt 11ur -P0GP.a,ir cOOPiDiNATORs <br /> St c,! for California 205 623.' <br /> ii i grrr?1I< r �• Robert tuicClellon,REHS <br /> l,, —__.-- -- --------- - - — - <br /> Jeff Carruesco,REHS,RDI <br /> I aJ' <br /> :- �. Kasey Foley.REXS <br /> q--. r�;• b�l'� W Y�. i 4!Gtr/ J"i Linda Turkatte.REFIS <br /> LIFO% Phone: (209) 468-3420 <br /> f7ax: (209)464-0138 <br /> July 13, 2012 <br /> Mr. Gil Moore <br /> President New West Petroleum <br /> 1831 16TH Street <br /> Sacramento, CA 95814 <br /> RE: Shell Branded / New!Nest Gas#1003 <br /> 6437 W. Banner Avenue <br /> Lodi, CA. 95242 <br /> Dear Mr. Moore: <br /> As you are aware. the Central Valley Regional Water Quality Control Board (CVRWQCB) has <br /> determined that your site can receive a No-Further-Action-Required (NFAR) site closure letter <br /> upon proper destruction of the monitoring and remediation wells that are part of your site <br /> investigation and corrective action. San Joaquin County Environmental Health Department <br /> (EHD) is the permitting agency for the required well destructions and has been reviewing <br /> various proposals to complete the task issued by your consulting company Advanced <br /> GeoEnvironmental Inc. (AGE). <br /> There are forty-two wells associated with your site that must be destroyed, of which EHD has <br /> determined fourteen must be destroyed by removing the well contents as the wells are located <br /> in areas known or suspected to have contamination or pollution. The San Joaquin County Well <br /> Standards, Section 13.17.6., which echoes State of California Well Standards, specifies that, "If <br /> the well construction is unknown, and/or is located in an area of known or suspected pollution or <br /> contamination, the well shall be destroyed by removing all material within the original borehole <br /> (including the well casing, screen, filter pack, and annular seal); and the created hole filled <br /> completely with appropriate sealing material." EHD has determined that the fourteen wells in <br /> question are in such areas. <br /> Proper destruction of wells in the Flag City area is of particular concern as there are only a <br /> limited number of aquifers of sufficient water quality available to meet the growing water <br /> requirements of the Flag City businesses. EHD/County considers the area to have a sensitive <br /> water supply due to its proximity to the County Service Area (CSA) 31 drinking water wells. <br /> In response to EHD's requirement for destruction by the removal of the fourteen wells, <br /> alternative destruction proposals and destruction waiver requests were submitted by AGE via <br /> electronic mail (email) on 13 February, 02 March, and on '11 June 2012 for consideration by <br /> EHD. In addition, per your request; this Department, along with County Public Works <br /> representatives, met with you and AGE representatives on 11 May 2012 to discuss the well <br /> destruction issues, vvater quality concerns regarding the CSA 31 water e,vells if the fourteen wells <br /> in question are pressure greeted instead of removed, and came to sin agreement for EHD to <br />