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Mr. Nuel Henderson I%W Re: 102 S. Wilson Way—Petition for Closure Page 4 These oxygenates [ETBE and TAME],particularly ETBE which is not known to be in current use in California, are much less likely to be found in water than MTBE... TAME is known to be in current use by one refinery in some of its reformulated gasoline at 2 percent TAME to 9 percent MTBE. As noted by the California Department of Health Services, ETBE was not used in California until after 1997, and TAME was in extremely limited use at that time and was only produced in connection with MTBE. The underground storage tanks were removed from the site 17 years before the writing of the above referenced document, making it unreasonable to conclude that the presence of ETBE and TAME is in any way attributable to an unauthorized release on the site. Furthermore, since monitoring on the site began, 96 percent of the wells registered increases of at least 100 percent for the presence of both ETBE and TAME contaminants. DIPE Di-isopropyl ether(DIPE) is an oxygenate used in the creation of reformulated gasoline. DIPE was not widely used as a gasoline additive until recent years. A federal interagency report commissioned by President Clinton, which examined the use of oxygenated fuels, was published in 1997 6 The report notes that at the time of publication, DIPE was in "limited commercial use." Because the oxygenate DIPE was in limited use in 1997, it is highly improbable that DIPE contaminants resulted from an unauthorized release occurring before 1978 when the underground storage tanks were removed. Therefore, it is unreasonable to conclude that the presence of DIPE is in any way attributable to an unauthorized release on the site. Furthermore, since monitoring on the site began, 92 percent of the wells have registered an increase of at least 100 percent for the presence of DIPE contaminants. Further Evidence of Contamination Oriewatinr from Other Site The very existence of the gasoline constituents noted above provides evidence that contaminants from an offsite source are migrating to the site of 102 S. Wilson Way. As additional verification of contaminant migration,consider the following: • Despite remediation activities at the site, 84 percent of the wells have showed an increase in TPHg of at least 100 times greater during the course of monitoring. In particular, 5 of the 6 vapor extraction wells show an increase in TPHg. One vapor extraction well which in 1998 indicated the presence of 37,000 parts per billion of TPHg,now shows that TPHg is present in the amount of 250,000 parts per billion. This clearly indicates that the vapor extraction is drawing in contaminants from the groundwater plume. s The report is available at http://www.epa.gov/otaq/regs/fuels/ostpfm.pdf