SITE INFORMATION AND CORRESPONDENCE

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_ - _ ✓ State ''Vater Re.sources Control Board Division of Financial ssistance 1001 I Street•Sacramento,Cali cmia 95814 P.O.Box 944212•Sacramento,Calif mia-94244-2120 Arnold Schwarzenegger Alan C.Lloyd,Ph.D. (916)341-5353 FAX(916)341-5806 • www.i wreb.ca.gov/cwphome/ustcf Governor Agency Secretary MAY 5 2005 Ms. Helen Higgins 5815 Morgan Place #16 Stockton, CA 95457 Dear Ms. Higgins: UNDERGROUND STORAGE TANK(UST) CLE A FUND (FUND); FUND MANAGER DECISION FOR RECONSIDERATION OF INELIGIBLE COSTS: CLAIM NUMBER 11775; FOR SITE ADDRESS: 2315 CALIFORNIA STREET N,STOCKTON CA This letter is in response to a letter from Mike Vlach fr m Foothills Engineering dated January 7, 2005, requesting reconsideration of costs that were previously determined ineligible by Fund staff in Reimbursement Request No. 10. Mr. Vlach rec luefted reimbursement of$3,224.00 in cost for laboratory analyses for chlorinated solvents. Following my review of the letter from Mr. Vlach and the other documents in your file, I find that I must support the staff decision that the analytical costs are ineligible for reimbursement from the Fund. My decision'is based on the fact that analysis was performed solely to.delineate and monitor the presence of chlorinated solvent contamination beneath your site. Costs associated with the investigation of.chlorinated solve n are not eligible for reimbursement from the Fund because they are not derived from petroleum. In his letter, Mr. Vlach stated that the San Joaquin County Department of Environmental Health (SJCDEH) originally directed test for Stoddard solvent at your site but then revised the directive for stoddard solvents to EPA Method 8260 to include toddard solvents and chlorinated solvents. The problem with that statement is that EPA Method 8260 detects Volatile Organics that include both petroleum constituents and chlorinated solvents: owever, this method does not detect stoddard solvents. EPA 8015 for TPH--Stoddard solvents is the appropriate analysis to be run to monitor stoddard solvents. As to the directive to analyze for chlorinated solvents, the SJCDEH has the authority to direct you to investigate for chlorinated solvents base on historical activity at your site but this investigation is not eligible for reimbursement from the Fund. I want to point out that the Fund generally will allow.t ie use EPA Method 8260 in place of EPA 602/8020 to monitor for gasoline constituents. HoweN er, the costs in question are not for replacing EPA Method 602/8020 with EPA Method.8 60. My review of the invoices in question found that EPA Method 602/8020 and EPA 8015-gasc line were run to detect the.gasoline constituents and EPA Method 601 was run to detect c orinated solvents. EPA Method 601 will only detect chlorinated'solvents and not gasoline. The refore, I find that this analysis was solely run to investigate the.presence of the chlorinated solvc nts and the associated costs for this analysis is ineligible for reimbursement from the Fund. California Environmental Protection Agency Recycied P er G RECEIVED MAY 0 6 20M