SITE INFORMATION AND CORRESPONDENCE

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PUBLIC I ALTH SERVI ES P. UIN _ , SAN JOAQUIN COUNTY ENVIRONMENTAL HEALTH DIVISION V. Karen Furst, M.D., M.P.H., Health Officer O P 304 East Weber Avenue, Third Floor • Stockton, CA 95202 209/468-3420 MAR Q 3 1998 GAIL WIGGIT CENTRAL VALLEY REGIONAL WATER QUALITY CONTROL BOARD 3443 ROUTIER RD,SUITE A SACRAMENTO CA 94827-3098 RE: PORT OF STOCKTON STOCKTON TERMINALS TECHNICAL COMMITTEE TESORO DISTRIBUTION TERMINAL 3003 NAVY DRIVE STOCKTON CA On February 4, 1998 San Joaquin County Public Health Services Environmental Health Division (PHS/EHD)approved a well destruction permit(#014771)submitted by EMCON(consultant) on behalf of Water Development(C-57), for Tesoro Refining, Marketing& Supply Company. The purpose of issuing the permit was to destroy Tesoro domestic well 17A 1 which is considered a potential vertical conduit. The permit was approved in coordination with the written directives and recommendations provided by staff of the Central Valley Regional Water Quality Control Board (CVRWQCB), lead agency at the above referenced site. The original well decommissioning proposal from EMCON dated May 15, 1997 was presented to both CVRWQCB and PHS/EHD which included perforating the well casing at three foot intervals from 135 feet below grade surface to 3 feet below grade surface(bgs) followed by pressurized tremie grouting. On July 11, 1997 the CVRWQCB issued a concurrence letter to the responsible party which clearly indicated that the well must be perforated, and pressure grouted from the bottom up in accordance with local well standards enforced by PHS/EHD. PHS/EHD and CVRWQCB approval was based upon the assumption that there was no annular seal or the integrity of the seal or well was unknown therefore, the destruction proposal was at that time consistent with Section 6.3.3. of PHS/EHD Well Standards. On July 18 and 21, 1997 PHS/EHD staff inspected the 17A 1 well prior to decommissioning and reported to CVRWQCB the following, unidentified free phase product was observed in the well head and contrary to the Department of Water Resources records, this well did not fit the description found on the well log regarding its location, diameter or depth. Following these observations the CVRWQCB and PHS/EHD requested the responsible party perform a down hole video log. The findings of the video log included documentation of significant corrosion regarding the well casing and substantial voids between the bore hole walls and the casing(annular space). Emcon then issued correspondence to CVRWQCB and PHS/EHD dated December 3, 1997 which proposed a modification to the May 15, 1997 work plan. This well decommissioning proposal limited the perforation process to begin 55 feet bgs terminating at 3 feet bgs given the corrosion observed at 55 feet bgs and the well had silted in to 55 feet bgs. On January 12, 1998 the CVRWQCB issued a notice for concurrence regarding this proposal which included perforating the well casing at three foot intervals from 55 feet below grade surface to 3 feet below grade surface(bgs)followed by pressurized tremie grouting. On February 4, 1998 PHS/EHD contacted both the C-57 licensed holder, Water Development, and contractor, Emcon to inform them by telephone of the permit approval and that the grout material should 1 A Division of San Joaquin County Health Care Services