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• • <br /> San Joaquin County <br /> O.P`4UIN' .0 Environmental Health Department DIRECTOR <br /> >.• "�� O � Donna Heran.REHS <br /> 1868 East Hazelton Avenue <br /> PROGRAM COORDINATORS <br /> i{ <br /> Stockton, California 95205-6232 Robert McClellon,REHS <br /> • _: Jeff Carruesco,REHS,RDI <br /> 0q'•�.,,,,..••"�P • Website: wtvw.sjgov.org/ehd <br /> < Kasey Foley, RENS <br /> <FOR� <br /> Phone: (209)468-3420 Linda Turkatte, REHS <br /> Fax: (209)464.0138 <br /> July 13, 2012 <br /> Mr. Gil Moore <br /> President New West Petroleum <br /> 1831 16TH Street <br /> Sacramento, CA 95814 <br /> RE: Shell Branded/New West Gas#1003 <br /> 6437 W. Banner Avenue <br /> Lodi, CA. 95242 <br /> Dear Mr. Moore: <br /> As you are aware, the Central Valley Regional Water Quality Control Board (CVRWQCB) has <br /> determined that your site can receive a No-Further-Action-Required (NFAR) site closure letter <br /> upon proper destruction of the monitoring and remediation wells that are part of your site <br /> investigation and corrective action. San Joaquin County Environmental Health Department <br /> (EHD) is the permitting agency for the required well destructions and has been reviewing <br /> various proposals to complete the task issued by your consulting company Advanced <br /> GeoEnvironmental Inc. (AGE). <br /> There are forty-two wells associated with your site that must be destroyed, of which EHD has <br /> determined fourteen must be destroyed by removing the well contents as the wells are located <br /> in areas known or suspected to have contamination or pollution. The San Joaquin County Well <br /> Standards, Section 13.17.6., which echoes State of California Well Standards, specifies that, "If <br /> the well construction is unknown, and/or is located in an area of known or suspected pollution or <br /> contamination, the well shall be destroyed by removing all material within the original borehole <br /> (including the well casing, screen, filter pack, and annular seal); and the created hole filled <br /> completely with appropriate sealing material." EHD has determined that the fourteen wells in <br /> question are in such areas. <br /> Proper destruction of wells in the Flag City area is of particular concern as there are only a <br /> limited number of aquifers of sufficient water quality available to meet the growing water <br /> requirements of the Flag City businesses. EHD/County considers the area to have a sensitive <br /> water supply due to its proximity to the County Service Area (CSA) 31 drinking water wells. <br /> In response to EHD's requirement for destruction by the removal of the fourteen wells, <br /> alternative destruction proposals and destruction waiver requests were submitted by AGE via <br /> electronic mail (email) on 13 February, 02 March, and on 11 June 2012 for consideration by <br /> EHD. In addition, per your request, this Department, along with County Public Works <br /> representatives, met with you and AGE representatives on 11 May 2012 to discuss the well <br /> destruction issues, water quality concerns regarding the CSA 31 water wells if the fourteen wells <br /> in question are pressure grouted instead of removed, and came to an agreement for EHD to <br />