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. 'r • �blAty (,�j—go {Prfy�27oa � .�.wz,.0r1Ko Stantec Well Destruction Work Plan Stockton Charter Way Commingled Plume August 12, 2011 1 .0 INTRODUCTION AND SITE BACKGROUND On behalf of Atlantic Richfield Company (ARCO), Chevron Environmental Management Company (Chevron), Shell Oil Products US (Shell), and Sara Lee Bakery Group, Inc. (Sara Lee), Stantec has prepared this Well Destruction Work Plan (Work Plan) to propose over-drilling of SMW-7 and to propose an alternative methodology for decommissioning groundwater monitoring wells SMW-18-80 and SMW-18-120 at the former Texaco (Shell), located at 440 West Charter Way, Stockton, California. Wells SMW-7, SMW-18-80, and SMW-18-120 need to be decommissioned in order for a new station building to be installed, the details of which were described in the Further Assessment Work Plan dated February 15, 2011, which was approved by the California Regional Water Quality Control Board — Central Valley Region (CRWQCB- CVR) in a letter dated February 17, 2011. San Joaquin County Environmental Health Department (SJCEHD) requires that the entire well contents of SMW-18-80, and SMW-18-120 be removed to prevent potential vertical migration of petroleum hydrocarbons. Well SMW-7 will be over-drilled since the well is cross screened with the shallow A zone and B Zone. Wells SMW-18-80 and SMW-18-120 had been constructed using one continuous multichannel tubing (CMT). The removal of the entire well contents will require a non-conventional methodology as recommended by the manufacturer. SJCEHD offered specific requirements to destroy CMT wells in an email dated July 7, 2011 (Appendix A), which are based on previous well destruction efforts overseen by SJCEHD and assurances by a California-licensed drilling contractor and Occupational Safety and Health Administration (OSHA) requirements. If the well destruction requirements offered by SJCEHD are unacceptable, an alternative methodology must be proposed to SJCEHD in writing. The following Work Plan includes a brief description of the site, description of over-drilling SMW-7, basis for not accepting the well destruction requirements offered by SJCEHD for CMT wells SMW-18-80 and SMW-18-120, and a proposal for an alternative methodology. 1.1 Site Background The site consists of former ARCO Service Station No. 2168, Chevron Facility #9-2033, former Texaco (Shell), and former Colombo/Toscana Bakery (Sara Lee), located at 441 West Charter Way, 508 West Charter Way, 440 West Charter Way, and 1444 South Lincoln Street, respectively in Stockton, California (collectively referred to as the Stockton Charter Way Commingled Plume Site or "Site"). The Site is currently comprised of an active car wash facility (former ARCO Service Station No. 2168 - located on the northeast corner of the intersection of West Charter Way and Lincoln Street), an active Chevron-branded gasoline service station (Chevron Facility #9-2033 - located on the southwest corner of the intersection of West Charter Way and Lincoln Street), an ARCO-branded gasoline service station [former Texaco (Shell) - located on the southeast corner of the intersection of West Charter Way and Lincoln Street], and a storage warehouse [former Colombo/Toscana Bakery (Sara Lee) - located south of the former Texaco (Shell) on the east side of Lincoln Street]. A Site location map is included as Figure 1. In April 2010, the CRWQCB-CVR classified the Site as a commingled plume; although a letter of commitment has not yet been issued by the Commingled Plume Fund, the four parties are working cooperatively. The Site is comprised of parcels 16503003, 14707607, 16504016, and 16503005, respectively. A Site plan is included as Figure 2. The Site lies at an elevation of Stockton Charter Way Commingled Plume Well Destruction Work Plan.doc 1