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f � • • <br /> r' <br /> Advanced <br /> eoEnvironmental , Inc . <br /> 27 February 2012 <br /> AGE-NC Project No. 10-1801 <br /> Mr. Nuel Henderson <br /> San Joaquin County Environmental Health Department <br /> 600 East Main Street <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 /> Geo Environmental, 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 ®K (v, <br /> by letter dated 31 January 2012, the site's 42 ground water wells be properly destroyed. rAw I <br /> The site setting is illustrated in Figure 1; the existing monitoring/remediation well locations "J' <br /> are depicted in Figure 2. Mvfle, <br /> 4c <br /> Based on the most current ground water monitoring data available for each monitoring well, n�W s P�c <br /> Flag City Shell monitoring wells MW-1, MW-2, MW-3AB, MW-4BC MW-5AB MW-6AC hw�A <br /> MW-8A, MW-9BCD, MW-10ABCD MW-11B, MW-12A MW-13AB MW-19AB MW-206 �c <br /> EW-1 through EW-7 and EW-10 are non-detect for MTBE and all other petroleum related MW sA <br /> hydrocarbons and AGE is proposing to decommission these wells in accordance with San rW 9C <br /> Joaquin County well standard by pressure grouting techniques. 91) <br /> nW to <br /> Mw n <br /> However,well destruction by pressure grouting techniques is generally not allowed by San Mw 12 <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-6B, MW-7A/B, MW-8B, EW-8B, <br /> EW-9B 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 /> 837 Shaw Road• Stockton. CA 9s'1 < � <br /> tl�l Telephone (209)467-1006• Fax 1'_09i 46'-1 1 18 <br /> ,(,7b <br />