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. R I ON Orion Environmental Inc. <br /> 2955 Redondo Avenue 562 988-2755 PHONE:. <br /> Long Beach,CA 9o8o6 562 988-2759 FAX <br /> DBA Arctof Environmental <br /> O 2332 561 Street,Suite,4 510 525-2180 PHONE <br /> Berkeley,CA 94710 510 525-2392 FAX <br /> 30 October 2019 <br /> Project No. 52STTC <br /> Jeff Wong <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 <br /> Stockton Terminals Technical Committee Facilities <br /> Port of Stockton, Stockton, California <br /> RWQCB Case #SL0607737442 <br /> Mr. Wong: <br /> Orion Environmental Inc. (Orion) has prepared this letter requesting a variance of the well <br /> destruction method for 12 wells associated with the subject site located at 2700 West <br /> Washington Street in Stockton, California (Figure 1). <br /> Background <br /> Between 2004 and 2012, two ozone injection systems (the West and East Systems) were <br /> operated to remediate petroleum hydrocarbons in groundwater at the site. In a work plan <br /> dated 23 September 2016, Stantec Consulting Services, Inc. (Stantec), proposed ozone <br /> system removal and destruction of all injection wells associated with the West and East <br /> Systems (Stantec, 2016). The Central Valley Regional Water Quality Control Board <br /> (RWQCB) approved the work plan in a letter dated 14 October 2016 (RWQCB, 2016). To <br /> date, the West and East Systems have been removed, 28 ozone injection wells have been <br /> destroyed, and 45 ozone injection wells remain at the site. <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 the remaining 45 former ozone injection wells. SJCEHD specified that all wells be <br /> destroyed by overdrilling. However, due to safety hazards associated with nearby <br /> underground utilities, Orion requests a variance to destroy 12 ozone wells by grouting rather <br /> than overdrilling. <br /> Rationale for Variance Request <br /> Per Orion's drilling subcontractor, Woodward Drilling of Rancho Cordova, California, and <br /> client safety standards, overdrilling within 5 feet of an underground utility is an <br /> S:\Clients\52STTC\LTR\LTR002.docx 10/30/19 <br />