SITE INFORMATION AND CORRESPONDENCE

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a - I 02 August 2004 USTCF Claim No. 01714 Page 2 of 3 additional chemical data delivered to the investigation through the use ofEPA 8260 was only complementary. Additionally, analytical method EPA 8260 is an approved method by the RWQCB for chemical analysis.Therefore,data collected from analysis by EPA 8260 should be reimbursed by the Fund. 2. The decision stating that prior to the installation`ofsoil borings CPT1 through CPT7, advanced in November 2002, that the down-gradient edge of the stoddard.plume had been defined. The decision states that "review found that by September 2002, the downgradient extent of Stoddard solvent contamination in the groundwater had been delineated",however the September 2002 stoddard solvent concentrations in the down-gradient well MW-10 was at 670 micrograms per liter(ug/l).Also,the vertical extent of stoddard solvent in the former UST area was not defined as of September 2002, and furthermore, a concentration of 32,000 µg/1 was detected in a ground water sample collected from 80 feet below surface grade,at the former UST area.Until the installation of the soil borings CPT 1 through CPT7, both the vertical and more importantly the lateral extent of the stoddard solvent had not been defined (see attached cross-section and site plans with stoddard contamination). The soil borings CPT 1 through CPT7, along with the grab ground water samples collected and analyzed completed the lateral delineation of stoddard solvent and aided to define vertical extent of stoddard solvents. Therefore, all monitoring wells, monitoring well samples analyzed(except method 8010),soil borings CPT1 through CPT7 and the grab groundwater samples collected generated data to aide in the investigation of the stoddard solvent plume and are therefore cost reimbursable. 3. The decision stating that "the chlorinated solvent contamination at your site, not the Stoddard solvent contamination, will primarily drive any additional investigation and ultimately, the cleanup required at your site." may not be true. Data collected from the chlorinated(tetrachloroethene(PCE))solvent plume indicates natural attenuation is presently ongoing. The plume documents the presence of Dehalococcoides,a dehalogenaous bacteria (see attached)responsible for the breakdown of PCE to trichloromethane(TCE),then to cis- 1,2-dichloroethane and finally to vinyl chloride and ether. Therefore, remediation of the stoddard solvent plume will require a cleanup technology different than natural attenuation and most likely will occur on-site, near the former UST source area. 4. The estate of Peter J. Wallace, Sr. has been damaged by the Final Division Decision indicating the USTCF would not reimburse costs for directed investigation of the former underground storage tanks. A direct financial hardship will occur,through costs associated with the sampling of stoddard solvent contamination on the site, without benefit of the USTCF cost reimbursement. The stoddard solvent investigation is fully eligible for reimbursement.The Final Division Decision declared that eligible cost would not reimbursed until an "overpaid" debt of $37,576.47 was applied towards fifty-percent of future r reimbursable costs.The Final Division Decision did not verify how the"overpaid"debt was calculated, nor how the USTCF determined that only half of future stoddard solvent assessment would be eligible/reimbursable. P