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Mr. Peter Wallace - 3 - AUG 2 J 286 Discussion Costs of Investigation Incurred After December 6, 1996, Up to and Including Costs Contained in Reimbursement Request No. 10, Should Be Split Evenly Between the Eligible Stoddard Solvent and the Ineligible Chlorinated Solvents Throughout the corrective action that is the subject of the FDD and revised FDD, several different EPA Methods were used to analyze the contaminants at this site. Prior to December 6, 1996, Methods 8015, 8020, and 602 were used to analyze groundwater and soil samples from this site. Method 8021B is a modification of Method 8020. Since December 6, 1996, Method 8021B was sometimes used in lieu of Method 8020. Method 8015 was used to analyze stoddard solvent and Methods 8020, 8021B, and 602 were used to analyze benzene, toluene, ethyl benzene, and xylene (BTEX). For the.purposes of this dismissal, Methods 8015, 8020, 8021B, and 602 will be referred to collectively as hydrocarbon methods. According to the letter from SJCEHD dated December 6, 1996, it was requiring Method 601 because of the site's history, historically used dry cleaning solvents, and consistent interference in the laboratory methods. In response to this directive, Methods 601 and 8010 began to be used to test samples from this site. For the purposes of this dismissal, Methods 601 and 8010 will be referred to collectively as chlorinated solvent methods. Analysis of samples found chlorinated solvents tetrachloroethene(PCE), trichloroethane (TCE), vinyl chloride, and cis-1, 2 dichloroethene (cis-1,2 DCE). The chlorinated solvent methods were apparently phased out and replaced by the use of Method 8260 at this site by the middle of 2001.4 Prior to being phased out, the laboratory ran the chlorinated solvent methods on approximately the same number of samples as were analyzed via hydrocarbon methods for stoddard solvent and BTEX. The cost of analyzing samples via the chlorinated solvent methods was more expensive than the cost of the hydrocarbon methods.5 According to petitioner, Method 8260 was used at this site in order to test for eligible petroleum constituents including methyl tertiary-butyl ether (MTBE). Thus,petitioner asserts that all the costs associated with the use of Method 8260 should be reimbursed by the Fund. 4 The last time Method 8010 was run on any samples from this site was April 2001. Method 8260 was used on samples from this site on a regular basis beginning in 2000 and is still used regularly. 5 Petitioner appears to concede that$3,036 in costs previously reimbursed by the Fund for 44 groundwater samples analyzed by EPA Method 8010 are ineligible for reimbursement,because Method 8010 tests for ineligible chlorinated solvents. (Petition,p. 1.) California Environmental Protection Agency ca Recycled Paper