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FILE COPY <br /> ENVIRO101MENTAL HEALTH DEPARTMENT <br /> OPOUIN O .� .- �-r°- <br /> ,t SAN JOAQUIN COUNTY ., <br /> c6 rt 4 Donna K.Heran,R.E.H.S. Unit Supervisors �= <br /> "Y Director 304 East Weber Avenue, Third Floor Carl Bergman,R E.x s <br /> At Olsen,R.E.H.S. StOCI{tOn, California 9$202-2708 Mike Huggins,R.E.H.S.,R.D.I. <br /> • Program Manager Douglas W.Wilson,R.E.H.S. <br /> ��FoaN Laurie A.Corolla,R.E.H.S. Telephone: (209) 468-3420 Margaret Lasorio,R.E.H.S. <br /> Program Manager Fax: (209) 464-0138 Robert McClellon,R.E.H.S. <br /> Mark Barcellos,R.E.H.S. 1 <br /> f <br /> KELLY LYNCH QUN O 5 2002 <br /> DEL MONTE FOODS <br /> 205 N WIGET LANE <br /> WALNUT CREEK CA 94598 <br /> RE: Del Monte Disco Site Site Code: 2498 <br /> 110 N. Filbert St. ROM 0000188 ) <br /> Stockton, CA., 95205 <br /> San Joaquin County Environmental Health Department (EHD) has reviewed the <br /> "Pilot Test Work Plan —Air and Ozone Sparing" proposal dated April 18, 2002 as <br /> submitted by Kleinfelder on May 17, 2002 and has the following comments. <br /> This work plan outlined a pilot test program to evaluate the feasibility of a <br /> potential remediation approach as required by underground storage tank (UST) <br /> regulations and the EHD. <br /> Based on the previous remediation work at the site, air sparging and soil vapor <br /> extraction (AS-SVE) and the demonstrated attenuation of the TPH groundwater <br /> plume after only a short duration of activity, your consultant has chosen not to <br /> seek the objective of demonstrating AS-SVE ability to reduce dissolved <br /> contamination, but rather to prove the effectiveness of the proposed test design <br /> to generate desirable physical characteristics such as an appropriate cone of air <br /> stripping and desirable oxygen delivery. This approach was suggested since a <br /> shorter test period is required and may allow for a significant reduction in the <br /> overall remediation program for the site. 1 <br /> EHD appreciates the intention of your approach to incorporate a previous, <br /> known, and site-effective remedial method into your proposal for an additional <br /> and new technology. A bench test for ozone injection was included in the <br /> proposal, as opposed to actual field installation and testing, to verify ozone <br /> destruction of dissolved 1,2-DCA. <br /> Although the bench test may be run, EHD does not regard this approach as an <br /> alternative equivalent to field-testing. An assumption was alluded to that the <br /> results from this 'ex-situ' approach (bench test) could mirror results that would be <br /> obtained from an 'in-situ' (well installations/field tests) application. EHD believes <br /> that many variables affecting an in-situ test would be missed and an in-situ test <br /> would be likely to yield significantly different results compared to the proposed i <br /> ex-situ, above ground, five-gallon container bench test. The differences may <br /> dramatically affect the remediation program time requirements and potentially <br /> increase your remedial costs. <br /> t <br />