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Advanced <br /> GeoEnvironmental , Inc . <br /> 27 February 2012 RE <br /> AGE-NC Project No. 10-1801 CEIVED <br /> MAR 02 2012 <br /> Mr. Nuel Henderson <br /> San Joaquin County Environmental Health Department ENVIRONMENTALHEALTH <br /> 600 East Main Street PERMIT/SERVICES <br /> Stockton, CA 95202 <br /> Subject: Request for Variance to Decommission Wells by Pressure Grouting <br /> NEW WEST PETROLEUM #1003 (FLAG CITY SHELL) <br /> 6437 West Banner Street, Lodi, California <br /> Dear Mr. Henderson: <br /> On behalf of Mr. Gil Moore of New West Petroleum #1003 (Flag City Shell), Advanced <br /> GeoEnvironmental, Inc. (AGE)has prepared this request fora variance to the San Joaquin <br /> County Environmental Health Department (EHD) Well Standards for abandonment of 42 <br /> wells at 6437 West Banner Street, Lodi, California (site). In accordance with site closure <br /> proceedings, the California Regional Water Quality Control Board (RWQCB) has directed <br /> by letter dated 31 January 2012, the site's 42 ground water wells be properly destroyed. <br /> The site setting is illustrated in Figure 1; the existing monitoring/remediation well locations <br /> are depicted in Figure 2. <br /> Based on the most current ground water monitoring data available for each monitoring well, <br /> Flag City Shell monitoring wells MW-1 MW-2 MW-3AB MW-4BC, MW-SAB, MW-6AC, <br /> MW-8A MW-9BCD MW-10ABCD MWA16 MWA2A MWA3AB MWA9AB, MW-20B <br /> EW-1 through EW-7 and EW-10 are non-detect for MTBE and all other petroleum related <br /> hydrocarbons and AGE is proposing to decommission these wells in accordance with San <br /> Joaquin County well standard by pressure grouting techniques. <br /> However, well destruction by pressure grouting techniques is generally not allowed by San <br /> Joaquin County Well Standards when a well is located in an area of known or suspected <br /> contamination. Based on current data, AGE is requesting the abandonment of nine <br /> suspected MTBE-impacted wells (MW-3C, MW-4A, MW-613, MW-7A/B, MW-813, EW-8B, <br /> EW-96 and MW-20A) by pressure grouting techniques due to the following reasons: <br /> • Well MW-3C is located within the gas station drive-way and has high exposure to <br /> traffic; additionally, MW-3C is located adjacent to USTs/product piping and poses <br /> a significant safety issue. The location of the well is in an area where traffic is dense <br /> both during day and during night time hours. Acquiring a variance to destroy this <br /> 817 Shaw Road - Stockton. ( A 9521 5 <br /> Tcicphonn(_109) 467-1006 • Fax (2()9) 467-1118 <br />