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State Water,'Resources Control Board Division of FinancialAssistance 10011 Street•Sacramento,Cali romia 95814 ` Alan C.LlPh.D. P.O.Bax 944212•Sacramento,California•94244-2120 Arnold Schwarzene oyd, (916 gger AgencySecremry )341-5353 FAX(916)341-5806 • vnvw, wrcb.ca_gov/cwphome/ustcf Governor MAY 5 2W5 Ms. Helen Higgins 5815 Morgan Place#E16 Stockton, CA 95457 Dear Ms. Higgins: UNDERGROUND STORAGE TANK(UST) CLEA FUND (FUND); FUND MANAGER DECISION FOR RECONSIDERATION OF INELIGIBLE COSTS: CLAIM NUMBER 11775; FOR SITE ADDRESS: 2315 CALIFORNIA STREET 14,STOCKTON, CA I This letter is in response to a letter from Mike Vlach fr Foothills Engineering dated January 7, 2005, requesting reconsideration of costs that were prey ously determined ineligible by Fund staff in Reimbursement Request No. 10. Mr. Vlach req ested reimbursement of$3,224.00 in cost for laboratory analyses for chlorinated solvents. Following my review of the letter from Mr. Vlach and tl Le other documents in your file, I find that I must support the staff decision that the analytical c osts are ineligible for reimbursement from the Fund. My decision is based on the fact that am lysis was performed solely to delineate and monitor the presence of chlorinated solvent contain'aation beneath your site. Costs associated with the investigation of chlorinated solvents are not eligible for reimbursement from the Fund because they are not derived from petroleum. i In his letter, Mx. Vlach stated that the San Joaquin Couny Department of Environmental Health (SJCDEH)originally directed test for Stoddard solvents t your site but then revised the directive for Stoddard solvents to EPA Method 8260 to include st ddard 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: H wever, this method does not detect stoddard solvents. EPA 8015 for TPH—Stoddard solveni s 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 chlorine ed solvents base on historical activity at your site but this investigation is not eligible for reilnbur ement from the Fund. I want to point out that the Fund generally will allow the use EPA Method 8260 in place of EPA 602/8020 to monitor for gasoline constituents. However, the costs in question are not for replacing EPA Method 602/8020 with EPA Method 826 . My review of the invoices in question found that EPA Method 602/8020 and EPA 8015-gasoline were nun to detect the gasoline constituents and EPA Method 601 was run to detect chlorinated solvents. EPA Method 601 will only detect chlorinated solvents and not gasoline. There ore, I find that this analysis was solely run to investigate the presence of the chlorinated solvent and the associated costs for this analysis is ineligible for reimbursement from the Fund. Califernia Environmental Prot coon Agency Q Recycled Paper G RECEIVED MAY 0 6 2005 Zoo in allIN`HO'V'IA £6906ZL9T6 XV.d LZ:£T 90OZ/6T/90