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C_ aliforniaeaional Water Quality Con&l Board <br /> 06I Central Valley Region <br /> Katherine Hart,Chair <br /> Arnold <br /> Linda S.Adams 11020 Sun Center Drive#200,Rancho Cordova,California 95670-6114 <br /> hwaneg <br /> gei <br /> Secretaryfor Phone( •FAX(916)46 -0RECEIVEDGovernor <br /> Environmental h[tp://w .waterboards.ca.gov/centralvalley <br /> Protection <br /> DEC 0 9 2010 <br /> ENVIRONMENTAL HEALTH <br /> 8 December 2010 PERMIT/SERVICES <br /> Mr. Jeff Baker 3op9 <br /> Tesoro Companies, Inc. <br /> 3450 South 3441h Way, Suite 100 <br /> Auburn, WA 98001-5931 <br /> WELL DESTRUCTION WORK PLANS, STOCKTON TERMINALS TECHNICAL <br /> COMMITTEE FACILITIES, PORT OF STOCKTON, SAN JOAQUIN COUNTY <br /> Regional Water Quality Control Board; Central Valley Region (Central Valley Water <br /> Board) staff reviewed the 11 November 2010 Monitoring Well Destruction Work Plan, <br /> Tesoro Stockton Terminal and thel5 November 2010 Monitoring Well Destruction Work <br /> Plan, Former Time Oil Terminal(Work Plans) submitted by Stantec Consulting <br /> Corporation (Stantec) on behalf of Tesoro Environmental Resources Company (Tesoro) <br /> and TOC Holdings Company for the Former Time Oil Company (FTOC), respectively. <br /> Combined, the Work Plans propose to properly abandon 23 monitoring wells, including <br /> eight at Tesoro and 15 at FTOC, respectively, due to substandard construction. The <br /> Work Plans propose to abandon each well by over-drilling with a hollow stem auger that <br /> is slightly larger than the boring, and backfilling with pressurized grout. Both Tesoro and <br /> FTOC propose to replace four of the abandoned wells on their respective properties. <br /> Following the destruction activities, Tesoro and FTOC propose to submit summary <br /> reports within nine to 11 weeks following concurrence from the Central Valley Water <br /> Board staff. <br /> Our comment is presented below. <br /> We concur that the improperly constructed wells should be abandoned to address the <br /> threat to groundwater. We have also observed, however, that several of the wells <br /> proposed for destruction are of strategic importance to the monitoring program and <br /> request that these wells be added to the list of wells scheduled for replacement. Our <br /> suggestions would increase the total number of replacement wells from eight to 15. Our <br /> rationale is tabulated below. <br /> California Environmental Protection Agency <br /> 0 Recycled Paper <br />