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AFFIDAVIT OF JOSEPH MUZZIO
<br /> STATE OF CALIFORNIA )
<br /> SS:
<br /> COUNTY OF SANTA CLARA )
<br /> I,the undersigned,state:
<br /> 1. I am a project geologist with Pacific Environmental Group,Inc.(PEG). As such,I am the
<br /> person principally responsible at PEG for providing consulting services to Union Oil Company
<br /> of California(Unocal)in connection with former Unocal service station 0187 located at 437 East
<br /> Miner Avenue, Stockton,California.
<br /> 2. In connection with PEG providing consulting services to Unocal as described above,I
<br /> reviewed the following documents with respect to the Site:
<br /> MPDS Services Inc., Quarterly Data Report, (MPDS-UNO0187-14R),December 11, 1997
<br /> GeoStrategies Inc., Work Plan and Feasibility Study at Former Unocal Service Station No. 0817,
<br /> 437 East Miner Avenue, Stockton, California, (Report No. 4827.07-1),October 9, 1997
<br /> GeoStrategies Inc., Soil Remediation Feasibility Study Work Plan, (Report No. 4827.05-1),
<br /> April 30, 1996
<br /> GeoStrategies Inc., Well Installation and Exploratory Soil Boring Report,
<br /> (Report No. 4827.703-5), September 21, 1994
<br /> San Joaquin County Public Health Services,Environmental Division, Correspondence for 437
<br /> East Miner Ave., Stockton CA 95202,(Site Code 1181),June 3, 1997
<br /> San Joaquin County Public Health Services,Environmental Division, Correspondence for 437
<br /> East Miner Ave., Stockton CA 95202,(Site Code 1181),June 25, 1997
<br /> San Joaquin County Public Health Services,Environmental Division,, Correspondence for 437
<br /> East Miner Ave., Stockton CA 95202,(Site Code 1181),December 10, 1997
<br /> 3. After reviewing the letter dated December 10, 1997, from the San Joaquin County Public
<br /> Health Services,Environmental Health Division(PHS/EHD). I have formed an opinion as to the
<br /> approximate cost of performing the additional tests which PHS/EHD has requested of Unocal in
<br /> that letter. The opinion is based on my experience as a project geologist who has provided
<br /> similar services to Unocal and other companies in connection with corrective action at current
<br /> and former gasoline service station sites. Based on this experience, it is my opinion that it would
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