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PUBLIC HEALTH SERVICES �OP�ui�oC <br /> SAN JOAQUIN COUNTY _• �` °cy <br /> ENVIRONMENTAL HEALTH DIVISION a < <br /> Ernest M. Fujimoto, M.D., M.P.H., Acting Health Officer <br /> 445 N. San Joaquin Street • P. O. Box 388 • Stockton, CA 95201-0388 ? c°<,FonevP <br /> 209/468-3420 <br /> ) <br /> Q <br /> i <br /> SOON K KIM <br /> DEL MONTE FOODS yp <br /> 205 NORTH WIGET LANE FJ� <br /> WALNUT CREEK CA 94598 if <br /> j <br /> f RE: Del Monte/Disco SITE CODE: 2495 <br /> 110 N. Filbert Street <br /> Stockton, CA 95205 <br /> San Joaquin County Public Health Services, Environmental Health Division <br /> (PHS/EHD) has reviewed a letter from the law offices of Pillsbury, Madison, and <br /> Sutro dated November 3, 1994. Margaret Lagorio representing PHS/EHD has had <br /> telephone conversations with Rona Sandler of Pillsbury, Madison, and Sutro. It <br /> appears that clarification'�of terminology and what PHS/EHD is directing Del Monte- <br /> as a responsible party tozperform is necessary. <br /> At the meeting on Octoberr17, 1994, and with a letter dated October 26; 1994, <br />!., PHS/EHD provided you with documents indicating who we could identify as <br />( responsible parties. . As soon as Del Monte provides PHS/EHD with the name.;.of any <br /> person who owned or operated the underground storage tanks immediately before the <br /> discontinuation of their ';use we will notify the person(s) that they''are a- <br /> responsible party. Del Monte will remain a responsible party also. PHS/EHD will <br /> direct all responsible parties on the investigation and remediation of the site. <br /> The responsible parties mustdecidehow to comply with the directives .and meet <br /> the compliance dates given' by PHS/EHD. <br /> The letter from Pillsbury,!Madison, and Sutro- states that PHS/EHD "has directed <br /> 1 Del Monte to proceed with the next phase of remediation (source removal) by <br /> j November 14, 1994" . Actually CH2M Hill, Del Monte's consultant, proposed air <br /> I sparging and vapor extraction for remediation of the what they termed the source <br />�- area. In the meeting with PHS/EHD on October 17, 1994, it was explained that the <br /> air sparge wells, vapor extraction wells, and piezometers could be installed and <br /> r tests performed; and that if this method of remediation appeared to be cleaning <br /> up the soil without increasing the spread of groundwater contamination off site <br /> it could continue to operate and would be considered interim remediation, until <br /> s a Corrective Action Plan. that addressed all of the soil and groundwater <br /> contamination was finalized. It was decided at the meeting that the piezometers, <br /> air sparge and vapor extraction wells would be installed by November 14,, 1994. <br /> A copy is enclosed of the California Code of Regulations, Title 23, Division 3, <br /> Chapter 16, Article 11 (Corrective Action Regulations) Section 2725 (f) } which <br /> requires responsible parties to evaluate at least two alternatives for remedying <br /> or mitigating the actual 'or potential adverse effects of the unauthorized <br /> release. ':In order to evaluate air sparging and vapor extraction as a remedial <br /> alternative the wells need. to be installed and tests conducted. <br /> F <br /> I Section 2725 (a) of the Corrective Action Regulations (copy enclosed) discusses <br /> assessing the lateral and ,vertical 'extent of the release to determine a'. cost- <br /> effective method of cleanup. Since the extent of the release is not defined, <br /> upgradient, nor defined downgradient (due to the great distance between MW2 and <br /> MW6) , nor defined vertically, PHS/EHD is directing Del Monte to complete the - <br /> investigation of the extent of groundwater contamination by installing a <br /> monitoring well upgradientof MW1 and two wells downgradient of MW2 (one shallow <br /> and one deep monitoring well) . <br /> * E <br /> ii <br /> .4 Division oP San Joaquin County Health Care Services I <br />