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Mr. Peter Wallace _4 - AUG 2 9 ZOOS Contrary to petitioner's assertions, at least fifty percent of the costs of using Method 8260 are attributable to the chlorinated solvent contamination. The hydrocarbon and chlorinated solvent methods discussed above use analytical detectors that often result in false positives (i.e. the identification of a contaminant that is not actually present in the sample). These methods are cost effective screening tools. Method 8260 is more expensive than the hydrocarbon and chlorinated solvent methods, but can more positively identify the presence of a large number of contaminants, including chlorinated solvents, using mass spectrometry. Method 8260 is often used to confirm the findings of the less expensive screening methods. While a laboratory may run a full Method 8260, it may also run a partial or abbreviated,more cost effective, Method 8260 to specifically analyze whether MTBE and several other eligible petroleum constituents are present. A full Method 8260 tests for additional chlorinated and non-halogenated organic hydrocarbons, including the chlorinated solvents found at this site. Typically, a laboratory will run a partial Method 8260 scan on samples from sites with contamination from petroleum USTs. A laboratory will normally run full Method 8260 scans on samples from sites with contamination or suspected contamination from chlorinated hydrocarbons. There is no evidence in the record that the laboratory ran partial Method 8260 scans. The laboratory tested for chlorinated solvents, MTBE, and several other eligible petroleum constituents each time it ran a Method 8260 scan on a sample from this site. Additionally, after phasing out the chlorinated solvent methods, the laboratory continued to test for stoddard solvent and BTEX via the hydrocarbon methods, in addition to running over one hundred full Method 8260 scans after the beginning of 2000. Given the site characteristics and site history there was no reason to do a full Method 8260 scan except to analyze the chlorinated solvents. Also, the use of Method 8260 coincided with the phasing out of the use of the chlorinated solvent methods. While it probably would have been reasonable to analyze at least some samples with a partial Method 8260 to confirm the presence of eligible contaminants, only full Method 8260 scans were conducted. Presumably, full Method 8260 scans also confirmed the presence of eligible contaminants, but the number of Method 8260 scans conducted greatly exceeded what would have been necessary to confirm MTBE or other petroleum constituents. Method 8260 is the most expensive test used at this site. The cost of running a full Method 8260 scan on over one hundred samples since the start of 2000 has greatly surpassed the cost of running all other tests that have been conducted at the site since December 6, 1996. As stated above, it would have been reasonable to run some partial Method 8260 scans in order to confirm the presence of eligible contaminants. Therefore, a comparable portion of the costs of the full Method 8260 scan are appropriately eligible for reimbursement, but all other costs for running the full Method 8260 scans are attributable to chlorinated solvents. Additionally, all the costs of the chlorinated solvent methods are attributable to chlorinated solvents. It would be inappropriate, however, to attribute only the cost of the chlorinated solvent methods and a portion of the costs of Method 8260 to chlorinated solvents, because the extra costs attributable California Environmental Protection Agency Za Recycled Paper