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Flag City Chevron page 2 <br /> 6421 W. Capitol Ave, Lodi <br /> The Request for Variance states that if the hollow out method is unsuccessful then the <br /> CMT wells will be drilled out with hollow stem augers. The EHD has witnessed attempts <br /> to drill out CMT wells in the past and they were not successful. The CMT tubing <br /> material does not break apart as PVC does when over-bored and the tubing only <br /> deforms and jams around the lead auger a few feet below the surface. The CMT casing <br /> is then incapable of being removed or even attached to and the EHD could only allow <br /> the shallow borehole to be filled with cement grout. The remaining portion of the CMT <br /> casing to total depth was left in place with only a minimum grout placement. This <br /> procedure is not acceptable and the EHD will not allow traditional hollow stem auger <br /> drill out for CMT wells. The EHD will require another method for destroying/removing <br /> the CMT casing if the hollow out method is unsuccessful. <br /> Please submit your alternate CMT destruction proposal to the EHD for review. The well <br /> destruction permits for the CMT wells will not be issued until an acceptable alternative <br /> destruction method for these wells is approved by the EHD. <br /> Please provide a copy of the signed agreement that states which Flag City Chevron <br /> monitoring wells are to be the responsibility of New West #1003/Flag City Shell. <br /> Thank you for your patience and cooperation during this process. You may contact <br /> Michael Infurna at (209) 468-3454 if you have any questions. <br /> Donna Heran, REHS, Director <br /> Environmental Health Departnt <br /> Michael J. Infurna Jr., Senior REHS Margare Lagorio, REHS. <br /> LOP - Unit IV Program Coordinator <br /> cc: CVRWQCB —James Barton, Sacramento. <br /> SWRCB-Clean Up Fund — Mark Owens, Sacramento. <br /> AGE —Tim Cuellar 837 Shaw Rd, Stockton 95215 <br />