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MEMORANDUM CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD - CENTRAL VALLEY REGION 3443 Routier Road Phone: (916) 361-5600 Sacramento, CA 95827-3098 ATSS Phone: 8-495-5600 TO: Greg Vaughn FROM: Camilla Williams Senior Engineer Engineering Geologist DATE: 27 February 1990 SIGNATURE:�et Ltweag," SUBJECT TIME SUPPLYCWELLSEFOR WASTE ABANDONMENT PLANI,RGE REQUREMENTS KEARNEYIKPF, SANORDER NO. 3 AND JOAQUIN COUNTY Waste Discharge Requirements (WDRs) Order No. 89-163 were issued in September 1989 and contained a time schedule for closure of the surface impoundments and submittal of the Phase II Ground Water Assessment Report for Kearney-KPF. The WDRs were issued prematurely because of the interagency agreement (IA) between the Department of Health Services (DHS) and the State Water Resources Control Board. As a result, the adopted time schedule was not accurate in predicting the closure activities and ground water investigations at the site. Hargis submitted a new time schedule by letter dated 10 January 1990. The schedule was adjusted after the soil assessment had been performed and the analytical results had been reviewed by Hargis. The WDRs should be revised to incorporate the new time schedule. However, the WDRs will also need to be revised this summer after Hargis submits the Report of Waste Discharge and the Selected Closure Alternative Documentation (Final Closure Plan) . Therefore, it would be inefficient to revise the WDRs twice within a few months. The new time schedule can easily be incorporated into the WDRs when they are revised for closure. The closure WDRs will be revised for the June or July Board meeting. On 29 January 1990, Hargis submitted their pian to abandon the shallow and deep � i supply wells at the Kearney-KPF site. On 7 February 1990, I discussed the abandonment plan with Mr. Terry Turner of Hargis. Per our telephone 0 conversation, Halliburton will be subcontracted to perform what appears to be a type of Bradenh=ad squeeze (low-pressure) cementing technique. Because the supply wells appear to have been conduits through the annulus for contamination of lower water bearing zones, it is imperative that a "cadillac" cementing job be performed. If oil field techniques and equipment are going to be used, the contracted company should be able to give recommendations and the expertise necessary to perform this complex task. I have reviewed the abandonment plan. Mr. Turner has stated that the technique described in their plan has been previously used. Although the plan seems reasonable, my main concern is that with this technique there is no way to demonstrate whether the annulus has been adequately sealed or to test the squeeze job. Because the squeeze does not include reversing the cement out of the