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JAN-05-1996 08:39 P.04107 Mr. Andrew Smith • _3- • presented in Attachment B of all quarterly monitoring reports prepared by the claimant's former consultant, Condor Barth Technologies (CET), from 1998 through 2001. These monitoring reports stated that the concentration of MTBE in soil sample GP4-5 was 14,000 mg/kg. Subsequent monitoring reports prepared by AGE did not contain the soil data from GP4-5. Nonetheless,the relevant statement made in the FMD was that the first investigation performed at the site that included analysis for MTBE identified the substance adjacent to the current ASTs. 2. The former USTs were located in a levee, and there is a difference in elevation between the former USTs and the current ASTs of 14 to 16 feet. Re onse: As stated previously, the former USTs were installed as ASTs, and the levee was later built up, and they became partially covered. This indicates that they were installed on the valley floor at the foot of the levee at a similar elevation as the current ASTs. My review of site maps prepared by CET and cross section figures confirm this. These figures show that there was only a difference of approximately two feet between the bottom of the former USTs and the bottom of the current ASTs. 3. There was a difference of ten feet in water table elevation between the former USTs and the current ASTs. Response: The closest monitoring well to the former USTs with measurable groundwater is MW-4. The difference between the water level in MW-4 and MW-2, the closest monitoring well downgradient from the current ASTs, is approximately three feet. 4. There has never been a release of fuel from the ASTs, and there is no evidence of a vapor release. Testing has been performed, and no fuel vapors were found. Response: No details of this testing have been provided to the Fund. Regardless, the lack of documentary evidence of any release from the AST is not crucial to this analysis. The location of the contamination at the site is the primary basis for the conclusions in the FMD. 5. The Fund Manager made his decision without all of the available and necessary data Response: When it was discovered that the figures from the additional assessment report were omitted, Fund staff contacted the Regional Water Board to obtain copies. These figures were reviewed prior to issuance of the FMD. Points Raised by AGE AGE Comment No. 1. See item 1, above. AGE Comment No. 2. The very high concentrations of MTBE downgradient from the current ASTs in monitoring wells (MW-2, MW-3, and EW-1) are the result of MTBE that was released from the former UST, and flushed away from the former USTs area by fast moving groundwater, due to a steep groundwater gradient in the area of the former USTs, and deposited downgradient California Eav�ioronmewa/Protection Agency `Lc�Recycled Paper