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Mr. Peter Wallace - 5 - AUG 2 4 2-001 to investigating chlorinated solvents are greater than just the cost of running an additional test on the samples. There is an additional cost associated with analyzing the chlorinated solvents data in an effort to delineate the lateral and vertical extent of the chlorinated solvents plume as directed by SJCEHD. The investigation showed that the stoddard solvent plume and chlorinated solvents plume are separate, but partially commingled. Additionally, the extent of delineated groundwater contamination is practically identical for both the stoddard solvent and chlorinated solvents plume. As a result, soil and water samples were taken from each location and tested for the presence of both chlorinated solvents and stoddard solvent in order to delineate the extent of the stoddard solvent plume and chlorinated solvents plume. Therefore, given these facts, although a more detailed analysis may find that more of the costs incurred were related to the chlorinated solvent investigation, it was appropriate for the Division to split investigative costs incurred after December 6, 1996, evenly between stoddard solvent and chlorinated solvents. Investigatory Costs, Starting With Those Contained in Reimbursement Request No. 11, Will Also Be Split Evenly Between the Eligible Stoddard Solvent and the Ineligible Chlorinated Solvents, Unless, and Until, the Investigation Shows That the Extent of the Chlorinated Solvent Plume Goes Well Beyond the Stoddard Solvent Plume The Fund Manager Decision (FMD) stated that the stoddard solvent plume was fully delineated by September 2002, while the chlorinated solvents plume had not been fully delineated yet. As a consequence, the FMD found "that the chlorinated solvent contamination at [the] site, not the Stoddard solvent contamination, will primarily drive any additional investigation and ultimately, the cleanup at [the] site." Therefore, pursuant to the FMD, any additional investigation of the extent of the stoddard solvent plume was ineligible for reimbursement While agreeing with much of the analysis in the FMD, the FDD recognized that"at least some of the near-term investigation and monitoring activities will be aimed at both Stoddard solvent and chlorinated solvents." Thus the Division determined that it is appropriate to continue to split investigation costs evenly between the stoddard solvent and chlorinated solvents, unless, and until, the investigation shows that the extent of the chlorinated solvents plume goes well beyond the stoddard solvent plume. Petitioner contends that the installation of soil borings CPT 1 through CPT7 and other costs included in Reimbursement Request No. 11 were necessary to define the vertical and horizontal extent of the stoddard solvent contamination. Petitioner asserts that since these costs were necessary to delineate the extent of the stoddard solvent plume, all of these costs are eligible for reimbursement. As discussed above, petitioner is investigating the extent of both the stoddard solvent plume and the chlorinated solvents plume. Regardless of whether this investigation contributed to the California Environmental Protection Agency �a Recycled Paper