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Sep, 26. 2005 4: 14PM Adv_arcea 6eoEnvironmenlal No. 2297 P. 2 —Original Message— From: Bob Trommer[mailto,BTROMMER@waterboards.ca,govj ' Sent: Tuesdav, August 16, 2005 12*19 PM To: Subject: Request for Cost Pre-Approval, Claim As you know, the Fund is not currently doing Pre-Approvals due to staffing reductions. Therefore,the Fund will not issue a formal response to your pre-approval request for the proposed remedial action. However, I have looked at the information that you provided by e-mail and offer the following: The Fund typically will not pay for}excavation below the water table. This is because contamination in soil sample collected below the water table is ` more likely to represent the contamination in the groundwater within the pore spaces of the soil sample rather than adsorbed to the soil. Therefore, it represents a groundwater problem and not a soil problem and should be addressed by a groundwater remedial technology. In addition,'the cost is generally unreasonable due the the need for dewatering and installation of shoring. The cost to excavated to 14 to 17 feet below the water table based on one -soil sample collected 7 to 8 years ago is not reasonable. In addition to the Fund's concern discussed above, the soil sample is not repesentative of current conditions and is not appropriate to justify the significant cost associated with dewatering,shoring and excavation of soil to the proposed depth. .� The Fund is also concerned that the significant increases in groundwater contaminant concentrations identified during recent monitoring events suggest a different source of the contamination than the USTs that were removed in 1985. The Fund can only reimburse for the remediation of contamination that resulted from the unauthorized release from the USTs. I noted during review ofthis claim that your client is a"Y claimant and has not received a Letter of Comittment(LOC)due to their rank on the Priority List. Therefore, if you proceed with the proposed excavation, the Fund with evaluate the eligibility of the costs at the time you submit your reimbursement request following the issuance of the LOG 5 y: