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From: Beatty, Jenifer <Jenifer.Beatty@arcadis.com > Sent: Wednesday, December 06, 2017 3:52 PM To: Michael Kith [EH] Cc: Roger Smith; Hinkley, Darcy; Hackman, Scott Subject: Attachments: ENVIRONMENT HEALTH Request for a Variance to Destroy Wells - Former Pilkington Property • Figure 3 - Site Plan with warehouse.pdf; PW-08 and EW-04 Results.pdf; FORMER PNATrench results.pdf; PNA SWIS Metals and Sample Detections 12-2017.pdf; PNA Soil Investigation Soil DI Wet 0917-WRL.PDF; Summary of Brusca Sampling Results.pdf RECIENELD DEC 07 2017 Michael Kith [EH] Dear Mr. Kith, Arcadis, on behalf of Glenn Spring Holdings, has submitted to SJEHD a Well Destruction Permit Application, fees, and supporting information to destroy 6 wells located on the former Pilkington Property (see attached Figure 3). The 6 wells to be destroyed include: monitoring wells PW-08-076 (76 ft.), PW-08-155 (155 ft.), PW-08 -180 (180 ft.) extraction wells EW-04 (200 ft.) and EW-04A (218 ft.) injection well INJ-14 (205 ft.) all wells are stainless or carbon steel with the exception of INJ-14 which is PVC extraction well EW-04 has a 20 inch diameter conductor casing to 50 feet bgs. The wells are to be destroyed to prepare the site for construction of a warehouse (footprint shown in Figure 3). Supporting information provided to SJEHD since August 2017 has included a Regional Water Quality Control Plan (RWQCB) approved well destruction workplan, RWQCB approval letter (September 11, 2017), historical and current groundwater plume maps to show groundwater COCs and concentrations in deeper water beneath the property and on the adjacent Simplot property, historical aerial photographs, and select information from other consultants. The well destruction workplan includes a description of proposed methods, figures, water table plume map and well logs. As described in the well destruction work plan: injection well INJ-14 was installed in 2013 for potential additional injection of treated (clean) groundwater. However, injection well INJ-14 was never used. extraction well EW-04 was used for groundwater extraction. Extracted groundwater was pumped to the treatment system located on the Simplot property for treatment. However, this well was taken offline in 2009 as it is no longer needed for plume control or treatment. extraction well EW-04A has only been operated minimally since 2014. Well EW-04A is not required for plume control or treatment as groundwater is captured by the downgradient pumping center (EW-06, EW-14B and EW- 08B). Groundwater data from the PW-08 well cluster and EW-04 extraction wells is attached. The destruction method indicated in our permit application was pressure grout. Upon County request, Arcadis provided information to support that there was no known reason to suspect soil contamination near the wells (aerial photographs showing the site had never been developed, historical and current plume maps showing the source for the groundwater plume on the Simplot property was not on the subject property, etc); if there is no or limited soil contamination the wells do not represent a threat to groundwater by providing a vertical conduit for contaminants in soil to migrate downward to groundwater. Since then, the County has directed us to several historical and more current documents that show that the northwestern portion of the subject property was a former glass landfill and that the property nearer the wells to be 1