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From:John Lane Sent: Monday,June 24, 2019 2:21 PM To: Kith, Michael <m kith @sogov.org> Cc:Zach Solow<zsolow@condorearth.com> Subject: FW: Well Destruction Permit Application for former Ranch Market, 23569 S. Santa Fe Avenue, Riverbank, CA Hi Michael, I wanted to follow up with you on the drilling permits for the Ranch Market site at 23569 S. Santa Fe Avenue, Riverbank. I spoke with Naseem Ahmed regarding our proposed methodology to pressure grout the air sparge wells, which all have %-inch sparge pipe. I understand that it is your policy to request over-drilling of all wells unless lab results confirm ND soil results in a particular well. However,the drilling companies are not equipped to properly over-drill these small diameter wells because there is no way to use a pilot bit/rod to keep the augers centered over the sparge well since native soil is typically softer than the annular seal (the augers very frequently skip off the bore hole). As a result, even if we can stay centered, we end up with a messy bore-hole with plastic shards/bits from a shredded casing pushed into the formation. Not much of the destroyed casing comes back out of the hole. I would submit that at this particular site, where well logs show that the sparge wells are completed at depth with their well screens fully within very sandy soil (virtually all logged soil that encompasses the screens are logged as SW with gravel and cobbles; only one is logged as SP, but that is still sandy soil. So there is no migration pathway, since the entire sandpack (typically only 3 to 3.5 feet of sandpack) is within this course material. I would like to meet with you to discuss as pressure grouting is acceptable pursuant to State guidelines and very commonly employed with very small diameter wells. Section 6.3 of San Joaquin County Well Standards indicates that pressure grouting is an acceptable sealing method. The work plan was also approved by the Water Board. Please let me know if we need someone else at the meeting that is in a position to grant an exemption under Section 13.2.1 of San Joaquin County Well Standards. Please let me know at your earliest convenience when we might be able to discuss. Thank you, John P.Lane,PG Environmental Services Manager CONDOR EARTH Sonora, Stockton,Jamestown, Merced, Rancho Cordova Direct:(209)938-1061 Mobile:(209)743-7443 Email:ilane0condorearth.com Company Website:www.condorearth.com "This message is intended for the use of the individual or entity to which it is addressed,and may contain information that is privileged,confidential and exempt from disclosure under applicable law.Any unauthorized use,distribution,or disclosure is strictly prohibited.If you have received this message in error,please notify sender immediately and destroy/delete the original transmission." From:John Lane Sent: Monday,June 10, 2019 2:15 PM To: nahmed@slgov.or� Cc: Zach Solow<zsolow@condorearth.com> Subject: Well Destruction Permit Application for former Ranch Market, 23569 S. Santa Fe Avenue, Riverbank, CA Hi Naseem, 5