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Water Development Corporation <br /> En vi ro n men to 1 , Mineral, Wore - i Geo ;ech n i cal Drilling Services <br /> March 6, 1998 <br /> Central Valley Regional Water Quality Control Board <br /> 3443 Routier Road, Suite A <br /> Sacramento,CA 94827-3098 <br /> Attn: Ms. Gail Wiggit <br /> RE: Letter To You From Mr.Ronald Rowe, Sr.REHS-San Joaquin County <br /> Tesoro Distribution Terminal-Stockton,CA <br /> Dear Ms. Wiggit: <br /> Water Development has received a copy of the letter sent to you from Mr.Ron Rowe,regarding the <br /> abandonment of domestic well 17A1 at the Tesoro Petroleum Distribution Terminal in Stockton. We <br /> respectfully take exception to several aspects of the chronology and to the conclusions drawn in this letter,as <br /> they relate to compliance with the work plan and to the PHS/EHD Well Standards. <br /> Water Development was subcontracted to abandon well 17A1 by Emcon Associates,on behalf of Tesoro <br /> Petroleum. This well was an agricultural water well no longer in use. Emcon had initially scheduled <br /> abandonment of this well in July of 1997 however,the well contained free floating oil and the work was <br /> delayed while the source and type of oil was determined. It was also determined that the casing size was <br /> only eight inches,while the original well log indicated the casing diameter was ten inches. We were <br /> contacted again by Emcon in late 1997 in order finalize the abandonment. Emcon had excavated the top of <br /> the well to check for the presence of a larger casing. While excavating,it was determined that the casing <br /> was loose in the borehole and should be removed to facilitate grout intrusion into any void space that might <br /> be present. An estimate was prepared on January 27, 1998 that reflected the latest plan for abandonment of <br /> well 17A1,which included grouting the well from 54 feet to surface and pulling the loose casing. <br /> On February 4, 1998,we were requested by Emcon to authorize the re-submission of a well permit <br /> application to San Joaquin County,for the abandonment of well 17A I. Apparently a previous permit <br /> application had been submitted naming another drilling company as the contractor. The work was scheduled <br /> for February 6, 1998. <br /> Water Development sent Mr.Bryan Nydoske and Mr.Daryl Whitley to the site on February 6, 1998 to <br /> perform the well abandonment. They met with representatives from Emcon and the San Joaquin County <br /> PHS/EHD around 11:00 a.m. This was Water Development's fust and only meeting or conversation with <br /> PHS/EHD officials regarding the abandonment of well 17A I. At this time, the only objection to the <br /> abandonment plan voiced by Mr.Rowe of the PHS/EHD was the type of grout to be employed. Mr. Rowe <br /> demanded that neat cement be used in place of sand grout and this change was made. Please note that either <br /> type of grout is permitted under the San Joaquin County Well Standards,Section 4.7.3. The remaining <br /> procedures,including the removal of the casing were also discussed at this time. The only other stipulations <br /> made by PHS/EHD was that the well casing be removed after grouting,and that the tremie pipe be placed as <br /> deep as it would go. No mention was made at this time of the well requiring perforation or of the <br /> abandonment plan not being in accord with the County regulations. <br /> 1202 Kentucky Avenue Woodland, California 95776 • 800 873-3073 • 530662 2829 • 530 6621592 fax <br />