SITE INFORMATION AND CORRESPONDENCE

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X •MICHAEL COLLINS Condensdtr"` iR ( JUNE 2, 1994 a� Page 5 Page 7 I Q. Any other upper education? 1 1986 and '87. Lead detectors were installed on the { 2 A. No. 2 pipelines and what that means is the tanks were actually 3 Q. Okay. How long have you been employed by 3 tested to make sure they had no holes or leaks or 4 the County as an environmental health inspector? 4 anything like that,and to the best of their knowledge, 5 A. Almost three years now. 5 they were--tested fine, that the tanks were okay. 6 Q. What did you do prior to that? 6Q. Okay. Do you know what it was that brought 7 A. Prior to that, I was in medical sales. 7 about the requirement or the performance of the 8 Q. Have you received any form of training in 8 precision testing in 1987? 9 regards to the assessment or cleanup of environmental 9 j�A. I am sure it was routine. 10 contamination? 10 iQ. Is it something that's ordinarily required 11 A. Yes. 11 for underground tanks? 12 Q. And what training have you received in that 12 !11 A. Yes. Some of the laws became enacted at the 13 regard? 13 tune where all of the tanks had to be tested and a lot 14 A. A full year of training,you might say 14 of problems were noted at about this time in '87 and '88 r I5 on-the-job training with the County. A full year of 15 and a lot of tanks had to be removed so I am sure it was 16 that prior to actually doing the inspections myself_. 16 routine. 17 Q. Did you take any courses as part of that 17 Q. Before we go any further, what I probably 18 training? 18 ought to do is talk toou about the y deposition 19 A. Yes. There have been courses that I have 19 procedure. 20 taken. Just several. I don't have a list of them,but 20 jP Have you had your deposition taken before? 21 I've have taken several,been to seminars, been to some 21 A. No. 22 conferences, you might say,conventions, a couple of 22 1'9. What we're doing here is taking your 23 conventions. 23 testimony under oath just as though you are testifying I 24 Q. Okay. And part of your responsibility as an 24 in court. 25 environmental health inspector for the County of San 25 l Do you understand that? Page 6 Page 8 1 Joaquin is concerning the cleanup or removal of I A. Uh-huh. 2 underground storage tanks? 2 �Q. You need to answer out loud also because the 3 A. Yes. 3 court reporter is taking down -- 4 Q. And were you overseeing the work performed 4 A. Yes,okay. 5 at 4579 Acampo Road in Acampo? 5 Q. --everything that we say word for word and 6 A. That's correct. 6 we don't want to to rely on her interpretation of grunts 7 Q. I noticed that today you have -- that you 7 or groans or uh-huhs and huh-uhs in preparing the 8 brought a-- I'Il call it your file. It's two parts. 8 transcript. 9 One is actually a file folder and-one's in a binder. 9 A. Okay. 10 Can you tell us when the first time the 10 Q. It will also make her job a lot easier if we 11 County had some contact regarding that site was? I I only speak one at time. 12 A. Sure. I would estimate that it was back in 12 A. Okay. 13 1987 regarding precision testing of the tanks over 13 Q. So I'll wait until you finish your answer l 14 there. 14 before I ask you the next question,if you please wait ; 15 Q. And do you know who that -- 15 until I finish my question before you begin your answer. 16 Or does that file reflect who that contact 16 A. Okay. 17 was with? 17 Q. If at any time during the deposition you do 18 A. As far the as the owner of the property or 18 not understand one of my questions,please don't answer 19 are you referring to the inspector? 19 it. 'Stop me and tell me you don't understand it and j 20 Q. From the owner of the property standpoint. 20 I'll try and clarify it for you. 21 A. I'll have to-- it says Save-Mor Oil Company 21 A. Okay. 22 back in '87. 22 Q. Also,during the deposition if you feel like 23 Q. What was the contact regarding precision 23 youi'need to take a break for whatever reason,just 24 testing? What do you mean by that? 24 simply say so and we'll be happy to take a break and we 25 A. It says here the precision tests were okay, 125 cariresume again when you are able to do so. PORTALE & ASSOCIATES DEPOSITION REPORTERS i, Page 5 - Page 8 I�