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Messrs. Hall and Musco -3 - 4 December 2002 <br /> o Centralizers are required by the California Well Standards and San Joaquin County <br /> Environmental Health Division Well Standards Section 13.8.3 but the workplan states they will <br /> be used if needed. <br /> o The workplan does not describe use of a tremie pipe for placing well materials. Please provide <br /> information on how the sand pack, transition seal, and well grout placement will comply with <br /> SJCEHD Sections 13.10.6 and 13.11.2. <br /> o The source of the water used for drilling fluid, make up water, decontamination, cement mix, <br /> etc. is not described. Water used for such purposes must be potable water as required by <br /> various subsections contained in SJCEHD Section 13. Please provide a description of the <br /> source of the water to be used; use of process wastewater is not acceptable. <br /> • Section 3.3.3 describes drilling a replacement for Well MW-9. That well will be drilled with a <br /> hollow stem auger drilling rig. Please provide a description of how the sand pack, transition seal, <br /> and well grout will be placed. As described above, California Well Standards and SJCEHD Well <br /> Ordinance require a tremie pipe. <br /> • A total of six pan lysimeters are proposed in this workplan but there does not appear to be any <br /> lysimeters planned in areas unaffected by wastewater application as required by Provision G.2.b. <br /> Please add lysimeters in areas unaffected by wastewater application. It is also noted that most of the <br /> lysimeters are located on land treatment units with relatively steep topography that may not be <br /> conductive to allowing percolate to collect in the lysimeter. Please reevaluate the location of the <br /> lysimeters and add sufficient lysimeters to comply with Provision G.2.b. <br /> • The construction of the lysimeters requires better description. The following comments regarding <br /> the lysimeter construction are provided: <br /> o The soil compaction procedure description is inadequate. Please provide better description of <br /> the criteria for recompacting the excavated material in the lysimeter. Overcompaction may <br /> result in wastewater running off and preventing percolate collection. <br /> o The construction as presented in Plate 5 does not include an anchor trench for the liner; this <br /> may allow the liner to slip down the surface of the excavation during construction. <br /> o Please provide a detail on the drainage net; will a filter fabric be installed? <br /> o Please provide specification on the polyvinyl chloride (PVC) liner. How will the liner be <br /> protected during backfilling operations? <br /> • Section 3.4 describes monitoring well development. In the past, Kleinfelder has reported wells going <br /> dry during development. Use of mud rotary to drill wells will likely worsen this problem. How will <br /> development be performed if the wells go dry? <br /> • Please describe the alternative sampling protocol in the event the wells go dry during well purging <br /> operations described in Section 3.5.1. <br /> • Section 3.5.2 describes pan lysimeter sampling, Please do not purge the lysimeter prior to sampling <br /> to provide a better chance of collecting all the samples that are required. However, the lysimeter <br /> V:lan Ioequin_NonlSSWMObimn miect Filu\MwcoVR1120202.doc <br />