SITE INFORMATION AND CORRESPONDENCE_FILE 2

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- i CAMBRIA The first analysis requested in this directive is "petroleum constituents." We interpret this to include total petroleum hydrocarbons as gasoline (TPHg), benzene, toluene, ethylbenzene, xylenes (BTEX). We are currently performing this analysis (along with MTBE analysis) quarterly on all groundwater samples from all wells at this site. The second analysis requested in EHD's directive is for "fuel additives. This term is typically YP Y used to refer to an oil company's proprietary chemical package added to fuel to make it brand specific. We do not believe this is what EHD is requesting we analyze for. If the term "fuel additives" in this case is referring to "fuel oxygenates" we would like to point out that fuel oxygenate analysis has been previously performed at this site. Groundwater samples from this site were analyzed for fuel oxygenates (methyl tertiary butyl ether [MTBE], ethyl tertiary butyl ether [ETBE], tertiary amyl methyl ether [TAME], tertiary butyl alcohol [TBA], di-isopropyl ether [DIPE], methanol, and ethanol from April 1998 through October 2000. In addition to the fuel oxygenate analysis we also analyzed for lead scavengers (ethylene dibromide [EDB] and 1,2 dichloroethane [1,2 DCA]). This data was last reported in our Fourth Quarter 2000 Monitoring and Remediation Report dated February 1, 2001. These analyses indicate that fuel oxygenates, other than MTBE,are not present at this site. The only exception to this is a one time detection of M TAME (44 parts per billion) and some methanol detections. These methanol detections were reported early on and have not been detected after the January 2000 sampling event. These methanol detections are also suspect due to the fact methanol is a know laboratory contaminant. These data suggest that fuel oxygenates, other than MTBE, are not present in groundwater beneath the site. As such we recommended in our Fourth Quarter 2000 Monitoring and Remediation Report that analysis for fuel oxygenates be discontinued. If EHD would like additional fuel oxygenate analysis performed at this site we would like to propose that this be done annually as we have already established that fuel oxygenates, other than MTBE are not present at this site. The third part of EHD's directive asks for us "...to report all peaks so that any chemicals resulting from degradation of the MTBE can be identified." We are not clear which chemical i compounds EHD is interested in identifying with this analysis unless it is in reference to the fuel oxygenates. When the term "all peaks" is used in reference to an EPA 8260 analysis this typically refers to a large list of compounds. Not all of the compounds included in this list may be appropriate to analyze for at a fuel leak site. Please clarify which chemical compounds you are directing us to identify. The only oxygenate we are familiar with that is a degradation product of MTBE is TBA. 0324 2