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Mr. Riddle . - 2 - Claim 2 -Claim No. 13324 Background Your claim was originally admitted into the Fund in 1998 based on a statement in your application that the 250-gallon UST removed in 1997 contained waste oil. Waste oil is an eligible petroleum product, and costs associated with corrective action to investigate and remediate waste oil contamination are eligible for reimbursement from the Fund. The initial investigation of the extent of contamination at your site conducted in 1999 focused on defining the extent of waste oil contamination. The Fund has reimbursed a total of$155,191.20 in corrective action costs. This amount was reimbursed by the Fund under the assumption that the corrective action conducted at the site was related to the unauthorized release from the former waste oil UST. However, as stated in the FMD, a review of your claim fqund that the extent of the petroleum contamination in the soil and groundwater beneath the site had been defined by December 2000, after the installation of eight soil borings and monitoring wells MW-1 through MW-4. Laboratory analyses of samples collected from these borings and wells showed that the petroleum contamination associated with the waste oil UST was limited to the immediate vicinity of the UST and that only monitoring well MW-3, installed in the center of the former UST excavation, had any detectable petroleum contamination. From December 2000 through the latest submitted quarterly monitoring report, MW-3 has consistently been the only monitoring well with any detectable petroleum contamination. Conversely, the ineligible chlorinated solvent Tetrachloroethene (PCE), has been consistently identified in groundwater samples collected from all of the monitoring wells at the site except MW-3. In addition, the concentration of PCE has generally exceeded the Maximum Contamination Level (MCL) in most of the wells during the majority of the sampling events. In a work plan for installation of additional monitoring wells, dated April 4, 2002, Ground Zero Analysis, Inc. (GZA) stated that the purpose of installation of three additional monitoring wells (MW-5, MW-6 and MW-7) was "to further investigate the lateral extent of chlorinated solvents in the groundwater beneath the site'. Similarly, in a work plan for installation of additional monitoring wells, dated February 9, 2005, GZA stated that the purpose of installation of three additional monitoring wells (MW-10, MW-11 and MW-12) was "to further investigate the lateral extent of chlorinated solvents in the groundwater beneath the site". This same work plan stated that the installation of two deeper zone groundwater monitoring wells (MW-8 and MW-9) was to further investigate the potential for vertical migration of PCE in the vicinity of MW-6 and MW-7. Discussion Issue#1 In your letter, you stated that because San Joaquin County Environmental Health Department (SJCEHD) directed the installation of the three additional monitoring wells (MW-5, MW-6 and MW-7), the Fund is obligated to reimburse for the cost of these wells. Califoriria EisvironmentalProleclioa Agency Q*Recydedpaper