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detections of MTBE in the soil." This statement ignores the fact that none of the monitoring well soil samples from the Chevron site were analyzed for MTBE. It also ignores the fact that groundwater samples analyzed by EPA method 8020 have exhibited much higher concentrations at the Chevron site than at the Kwikee site. Only one sample from the Kwikee site has exceeded 500 ppb, whereas 48 samples from the Chevron site have exceeded this value (SECOR, 2003, Appendix D). Admittedly, concentrations determined by EPA method 8020 are excessive in comparison to concentrations determined by method 8260, but the discrepancies are likely to be similar for both sites. The data also do not support the suggestion that MTBE contamination at Boulevard Auto is due to migration from Kwikee Foods. This would require MTBE to migrate at least 200 feet westward across the Chevron site, past MW-3 and MW-8. According to SECOR's report, five groundwater samples collected since 1997 from MW-8 and six from MW-3 have been analyzed for gasoline oxygenates by EPA method 8260, and only one has detected MTBE (at a concentration lower than detected at Boulevard Auto). It is difficult to imagine how MTBE could have migrated westward from Kwikee Foods and reached the Boulevard Auto site without impacting wells in the center of the Chevron site. This is especially true in view of the fact that the analysis of historical groundwater elevation data in our Site Conceptual Model Report identified no period during which groundwater flow was westward from the Chevron site toward the Boulevard Auto site. Hence, our analysis has identified several significant flaws in the model proposed by SECOR, Inc. We suggested as early as November 2000 that groundwater contamination beneath Kwikee Foods is the result of eastward migration of the plume at the former Chevron site, and the additional data . that have been collected since that time only serve to strengthen that conclusion. Therefore, we restate our recommendation that Kwikee Foods should be released from further investigation and monitoring, and the responsibility for monitoring contamination at Kwikee Foods should be transferred to Chevron. 7