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San Joaquin County Environmental Health Department DIRECTOR Donna Heran,RENS r. �,. . . .z 600 East Main Street PROGRAM COORDINATORS :{ Stockton, California 95202-3029 Robert McClellan,REHS Jeff Carruesco,RENS,RDI c-. p q�rFORa� Website:wwuv.sjgov.org/ehd Kasey Foley,REHS Phone: (209)468-3420 Fax: (209)464-0138 August 3, 2010 Mr. E. Bingham Kirk AKF Development LLC 1132 Norma Drive Manteca, CA 95336 Subject: Former Spreckles Sugar Plant#2 EHD Site Code: PR#: 0009289 18800 Spreckles Road Manteca, CA 95336 The San Joaquin County Environmental Health Department (EHD) has reviewed the Central Valley Regional Water Quality Control Board (CVRWQCB) correspondence Request to Destroy Monitoring Wells dated June 15, 2010, and has the following comments. In preparation for a No Further Action status being issued, the CVRWQCB has approved destruction of nine monitoring wells. (MW-13, -14, -15, -19, -20, -21, -22, -23, and -26). These nine monitoring wells were not the only monitoring wells installed by Spreckles to Investigate the groundwater of this site. Monitoring wells MW-1 r, -2r, -3r, -4, -5, 6r, -7, -8, -9, -10, -11, -12, -24, -25, -27 were also installed by Spreckles and remain. These wells must also be destroyed if they are rro longer active, before the site receives a No Further Action status. - The EHD will assist you with obtaining the Well & Boring Permits needed to properly destroy the nine monitoring wells Identified In the CVRWQCB correspondence, but will require you to either destroy the remaining 15 monitoring wells properly under END permit now or include them in a monitoring and reporting program approved by the EHD. The San Joaquin County Well Ordinance and the California Well Standards require wells to serve their Intended purpose or be properly destroyed under a destruction permit and witness of the EHD. It is a violation of our local Ordinance and California law to abandon the wells. Please submit to EHD either a monitoring and reporting proposal or a Well & Boring Permit Application for destruction of the wells. An application form shall be submitted for each parcel where a well or the wells are located. For those properties that are not under the control of AKF Development, an access agreement signed by the current landowner granting access to the property to destroy the well(s) must be submitted with the application. Please contact the private landowners where the monitoring wells are located and inform them that the proper destruction of these wells is required, at Spreckles expense, if they are no longer to be monitored or sampled by Spreckles/AKF Development. Wells that cannot be accessed by Spreckles could become the property of the current landowner and subject to monitoring, sampling, and eventual destruction requirements at their expense.