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T <br /> 4PRION <br /> Orion Environmental Inc. <br /> (SK2955 Redondo Avenue 562 988-27J5 PHONE <br /> Long Beach,CA 9o8o6 562 988-2759 Fnx <br /> DeA Arctos Environmental <br /> O 2332 5th Street,Suite A 510 525-2i8o PHONE <br /> Berkeley,CA 94710 510 525-2392 FAX <br /> 2 December 2019 <br /> Project No. 52STTC <br /> Michael Kith <br /> San Joaquin County Environmental Health Department <br /> 1868 E. Hazelton Avenue <br /> Stockton, California 95205 <br /> Subject: Request for Variance of Well Destruction Method Addendum <br /> Stockton Terminals Technical Committee Facilities <br /> Port of Stockton, Stockton, California <br /> RWQCB Case #SL0607737442 <br /> Mr. Kith: <br /> Orion Environmental Inc. (Orion) has prepared this addendum to a letter requesting a <br /> variance of the wel I destruction method for 12 wells associated with the subject site located <br /> at 2700 West Washington Street in Stockton, California. <br /> On 9 October 2019, San Joaquin County Environmental Health Department (SJCEHD) <br /> issued two boring permits (numbers WP0040161 and WP0040162)to Orion for destruction <br /> of 45 former ozone injection wells by overdrilling. Due to safety hazards associated with <br /> nearby underground utilities, Orion submitted a request for a variance to destroy 12 ozone <br /> wells by grouting rather than overdrilling on 30 October 2019. The following sections <br /> describe additional rationale for the variance request. <br /> Proximity to Subsurface Utilities <br /> As described in the original 30 October 2019 variance request, underground utilities were <br /> located within 5 feet of 12 former ozone injection wells. The ozone wells were installed in <br /> 2004 and utilities were installed after the wells during facility redevelopment activities. <br /> Specifically, these 12 wells are located within 5 feet of underground electrical lines and a <br /> high-pressure fuel distribution pipeline. The following table summarizes utilities located <br /> adjacent to ozone wells. Well locations are shown on Figure 1. <br /> Well ID Utility Located Within 5 Feet <br /> OS-126, OS-13B, OS-1513, OS-41, OS-43, OS-46, <br /> Underground electrical <br /> OS-47, OS-48, OS-57 <br /> OS-16B, OS-44, OS-45 Underground electrical and high-pressure fuel <br /> pipeline <br /> S:\Clients\52STTC\LTR\LTR004.docx 12/2/19 <br />