SITE INFORMATION AND CORRESPONDENCE

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Margaret La orio EH To: Alrani123@aol.com; admin@ford-construction.com Subject: 18846 N. Hwy 99, Stockton Attachments: Margaret Lagorio-04-23-08- BG3MEPP.pdf U Margaret Lagono- - 04-23-08- ... This information is regarding the injection well destruction at the above subject property. I was contacted by Rick Canepa back in January 2006 about destruction of the well. I E- mailed Liz Janes at USEPA about the destruction and was later contacted by George Robin of USEPA who said he was in contact with Rick Canepa and Ford Construction on the destruction. On February 19, 2008, I received copies of letters from USEPA and Irani Engineering on the plugging and abandonment of the injection well. On April 2, 2008, I sent an E-mail to the above Irani E-mail address with the form and fees to be submitted to our office for issuance of a permit for destruction of the injection well prior to scheduling the work. On April 14, 2008, I was contacted by Liz Janes at USEPA that destruction of the well was starting. She gave me a cell phone number for Bill Reynolds who was at the site. I called him and told him a permit was required from our agency and that I had E-mailed this information to Irani. He said to E-mail it to Irani again and also gave me his E-mail. He assured me that they were only preparing (removing packing) for the destruction/abandonment and that there was time for them to obtain the permit. I did not see the permit application until April 21, 2008 and when I looked up the contractor information on April 22, 2008, I found that Snow's Oilfield did not have a C-57 license as required by California Water Code and San Joaquin County Well Standards. When I called George Robin to discuss the status of the destruction I was very surprised to learn it had been completed without a permit or inspection from our agency. Especially, when it was our agency that was originally contacted regarding the destruction and thought everyone understood a permit and inspection was required by our agency. Attached are copies of the following document pages: San Joaquin County Ordinance Code Development Title Division 11, Section 9-1115.6 of the Code authorizing adoption of Well Standards, Section 9-1115.3 of the Code requiring obtaining a Well Permit from our agency for destruction of an injection well , Well Standards Section 2.1.1 requiring the permit be applied for by a C-57 licensed contractor, Well Standards Section 1.1.26 definition of an injection well, and California State Water Code Section 13750.5 stating abandoment of a well must be done by a C-57 licensed contractor. There is also Section 13710 of the State Water Code that defines a well if you would like to look up that section of the law. Oil and gas wells are exempted from the definition of a well but injection wells are defined as a well. Currently the property owners and others are in violation of State and local laws. You must obtain the services of a C-57 licensed driller who is willing to sign the well permit and take responsibility for the work that was performed. Also double permit fees will have to be paid. A complete report of the destruction will have to be submitted. Please contact me by phone or E-mail so this issue can be resolved. 1