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Co., Go ward Lp. <br /> Mr. Michael Harper <br /> January, 6, 1997 <br /> Page;2 <br /> 3. Autotronic disagree& with. assertions that the Bokides site is the source of <br /> groundwater contamination at the former Texaco site. <br /> Autotronic strongly disagrees with assert assertions that have been made that the Bokides site is the <br /> sole source.otgroutidwater contaminationat the former Texaco site, whether petroleum.product.s, <br /> such.as.benzene,. or 1.,2.- . or other compounds. <br /> n. Thert is: no evidence that, the Bokides site, is :A, source, of -L2-YID <br /> contamination at the former Texaco site. <br /> :Contrary to assertions of Texaco's consultants,,Autotronic believes no coftlid6fi exists between <br /> -levels of MTBE and 1,2-DCA detected in the groundwater. Texaco.s argument is that the <br /> former Texaco site cannot be a source of MTBE in the groundwater because of the dates when <br /> gasoline was sold there, and that a purported correlation between MTBE and 1,2-DCA levels <br /> indicates that the Bokides site is a likely source of the 1,2-DCA. <br /> Texaco's consultant has come to this surprising conclusion by averaging the levels of 1,2-DCA <br /> and MTBE detected in each of the five monitoring wells associated with the former Texaco site. <br /> Averaging, however, is a completely inappropriate and unreliable method of performing this <br /> analysis, especially given the fact that the numbers and dates of MTBE and 1,2-DCA do not <br /> match. Specifically, MTBE was sampled,more frequently in the:.wells.than 1.,2-DCA, and it is <br /> .,impossible to determine, whether a true <br /> correlation exists. <br /> In addition,, exam mmg the specific 1,2-DCA levels, we find th4t the:highest :1.2-DCA <br /> measurements,have been found at MVS:I located in the southerly.,.portion of the former Texaco <br /> site,.an unexpectedresult if the source of the 1,2-DCA isthe., <br /> Sim ply.put,-exis: g information is inconclusive about the source.:of:the L2-DCAI at the::former <br /> Texaco.site. Testing for the presence of 1.,2-DCA in the soils of the farmer Texaco:site., which.h. <br /> would reveal whether the::site itself is source, has never been performed.. In.addition,AS.PIM <br /> I V possible that the 1,2-DCA is simply a daughter <br /> it.I$ ,O]q prod `TCS. <br /> EHDPo-points out product the <br /> and PCE:present.in the regional.plume. Finally, a number of stormwateudrains and city sewers <br /> converge at the intersection of the Lodi.Avenue and Hutchins Street, whichtould also tie kft <br /> as a conduit and source of ehlon"n-ated solvents at the site. <br />