SITE INFORMATION AND CORRESPONDENCE

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y � I catalyst in the Isomerizati_-J Process to make gasoline as indicatea y Basic Chemicals Company Catalog Cut Sheet (Exhibit G). The ethene (i.e. the bulk mass of carbon and hydrogen) in TCE and Pere comes from crude oil as explained by Jim Mertens from Dow's Customer Service Web Page (Exhibit H). I The law that establishes the UST Fund doesn't direc ly exclude chlorinated hydrocarbons, but the State Water Quality Control Board has not allowed coverage because it is not considered to be a contributor to funding. When the chlorinated hydrocarbons are additives in gasoline they are sold directly as a portion of gasoline and are directly attributable to a portion of the UST Fund. ' Also the chlorinated hydrocarbons used in the Isome ization Process can be directly responsible for creating more gasoline that would not have been ivailable. If Perc is used to make gasoline then it is directly attributable to the UST Fund. Because chlorinated hydrocarbons are direct additives to gasoline and also catalyst to the formati n of gasoline there should be no prejudice to coverage under the UST Fund when they are associated with a gasoline plume. REASON FOR ELIGIBILITY #4- The site remains pen. The UST Fund recommended closure with the reply to Reimbursement#10. Foothill Engi ieering submitted a Site Conceptual Model and request for closure. SJCHSEHD replied with re uests for further investigation. Foothill Engineering agrees with the UST Fund that this site is of minimal threat to the public, but SJCHSEHD is still the authority as to what is acceptable. As of this time, the site is not eligible for closure and eligibility under the fund should continue. REASON FOR ELIGIBILITY#5-The UST Fund h s also made the inference that Vogue Cleaners may not be responsible for the plume because the higher concentrations appear to be off site. So far, there has not been any evidence to suspect another party. SJCHSEHD continues to attribute the contamination to the two tanks on this site. Until Vogue Cleaner's is released from responsibility their claim should remain valid. The 3JCHSEHD is under contract to the State Water Resource Control Board to administer California law with regard to underground storage tanks. SJCHSEHD projects the agenda of the State Water Resource Control Board. Since the UST Fund is part of the State Water Resource Cont of Board the UST Fund should agree with the agenda. CONCLUSION In summary, the SJCHSEHD is attributing the cant mination to the underground storage tanks, the products in the underground storage tanks where direct derivatives of crude oil (leaded gas and Stoddard Solvent), and the detected chlorinated hydrocarbons (1,2-DCA) are fuel additives and are manufactured from crude oil. On this site 112-DCA is not a byproduct of Pere degradation. Its source is as a lead scavenger from leaded gasoline. This is indicated by the fact that 1,2-DCA averages 8.3ppb and Pere averages only 1 ppb. If Perc was the source of 1,2-DCA Perc should have the higher concentrations. The numerical values for the constituents in the case studies in the Region 5 publication "Dry Cleaners- A Major Source of PCE in Ground Water" indicates that DCE is the prevalent byproduct of Pe c degradation and DCA is a trace byproduct. SJCHSEHD is only concerned about Stoddard Solvent, Gasoline, and fuel additives. The detected amounts of Perc and Perc by products are below state drinking water limits. SJCHSEHD has directed testing for Halogenated H drocarbons because of fuel additives and as a secondary precaution because the SJCHSEHD couldn't verify for sure what the previous 3 F