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25 May 2004 <br /> USTCF Claim No. 01714 <br /> Page 2 of 3 <br /> 3. Explanation Of Why The Estate of Peter J. Wallace, Sr., Believes The Staff Decision Is <br /> Erroneous, Inappropriate, Or Improper: <br /> The scope ofwork which the USTCF has determined not eligible for reimbursement includes <br /> the installation of borings to assess the lateral and vertical limits of the dissolved Stoddard <br /> solvent from the 348 West Harding Way, Stockton, California site. The investigative work <br /> had been approved by the SJCEHD acting as the local oversight authority of the California <br /> Regional Water Quality Control Board.The attached approval letter is dated 29 March 2002. <br /> The Estate believes that the USTCF decision to deem ineligible the SJCEHD-directed and <br /> approved scope of work is illegally prejudicial.The investigative work approved by the local <br /> oversight as "adequate and necessary" to determine the extent of stoddard solvent <br /> contamination from the site;the costs for the scope of work submitted for reimbursement to <br /> the USTCF were not designed nor implemented to determine the lateral and vertical extent <br /> of chlorinated solvents present on and off-site. <br /> Data collected from the site strongly indicates that two separate and partially co-mingled <br /> dissolved plumes are present in the area of the site. The stoddard solvent plume is present <br /> primarily in the area of the former USTs;the chlorinated solvent plume is present primarily <br /> off-site, northeast of the subject property. Furthermore, the mechanism of distribution of <br /> stoddard solvent to the subsurface has been determined to the former UST system; the <br /> mechanism of distribution to the subsurface of the chlorinated solvents has not been <br /> determined at this site, and is typically related to disposal via the sanitary sewer system. <br /> The USTCF states,in error,that "the relative concentrations ofchlorinated solvents at your <br /> site is greater than that ofthe stoddard solvent and that the chlorinated solvent have become <br /> the driving chemicals of concern at your site. "On-site monitoring wells are demonstrating <br /> 20 to 30 times greater stoddard solvent than off-site. Furthermore, as indicated above, the <br /> predominant contaminant on-site is stoddard solvent. The highest concentrations of <br /> chlorinated solvents appear to present off-site. <br /> The USTCF also states "that any additional investigation of the extent of stoddard solvent <br /> contamination will be incidental to the investigation of chlorinated solvents" and that <br /> "remediation ofthe stoddard solvent, ifrequired, will be addressed during remediation of <br /> the chlorinated solvents. " We find these statements to be scientifically unfounded and <br /> incorrect. To date,the SJCEHD continues to view the stoddard solvent as a"driving"force <br /> for the investigation and has indicated that remediation on-site will be necessary. On-site <br /> remediation is likely to have little, if any, impact on the off-site chlorinated plume. Please <br /> refer to recent reports from Advanced GeoEnvironmental, Inc. (AGE) regarding the status <br /> of investigation at the site. <br />