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. .Y MICHAEL COLLINS r A CondenseItTM I JUNE 2, 1994 <br /> Page 9 Page 11 <br /> 1 Do you know of any reason why we shouldn't I nwreason to believe there was a problem beneath the <br /> 2 go forward with your deposition today? 2 tanks prior to removal. They were just routinely <br /> 3 A. No. 3age ding the tanks out. Because of the law that was <br /> 4 Q. Any questions about the deposition 4 enacted,the tanks had to be removed by 1998. <br /> 5 procedure?. 5 Q. Okay. You really don't know what the reason <br /> 6 A. No. 6 was why they wanted the tanks removed,correct? <br /> 7 Q. Okay. After 1987,do you know when the next 7 p A. Pardon? <br /> 8 contact was at the County Health Department--or I'm 8 I�Q. You really don't know the reason why <br /> 9 sorry,the County of Public Health Services with the 9 Save-Mor wanted the tanks removed? <br /> 10 property there on Acampo Road? 10 i€A. 1 don't know if tbere was a reason other <br /> 11 A. tzt me check the file. A routine inspection 11 than just the law. <br /> 12 was made again in 1987,and I don't see the month here. 12 y Q. One thing that I should have mentioned <br /> 13 It's not legible. 13 earlier,if you don't know an answer to one of my l <br /> �l <br /> 14 Again,another routine inspection was made 14 questions,that's okay. lust tell me that you don't <br /> IS in 1989. The precision testing was okay. It says --in 15 know. I really don't want you to guess at something if <br /> 16 the file in 1989, it says the precision testing in 1990 16 it's guessing on your behalf about why they wanted to <br /> 17 there was--the tests were not available for 1990. 17 remove the tanks,for instance,because the law required <br /> 18 Precision tests were--the Site lacks precision tests 18 them to move remove them before 1998. It would just <br /> 19 for all tanks in 1990. 19 six6ly be better if you tell me that you don't know. <br /> 20 Evidently,there was a problem there and not 20 And I would appreciate that you don't make any guesses <br /> 21 all of the tests were received. 21 because I just want your accurate testimony about what <br /> 22 Q. Okay. 22 you do know. <br /> 23 A. In 1990,also, it-- oh, that was in October 23 1!}A. Okay. <br /> 24 of 1990. And then it says in November of 1990,all the 24 Q. At some point,I understand that there had <br /> 25 precision tests for the tanks were received and the 25 been some contamination discovered during the removal of <br /> Page '. '€ Page 12 <br /> 1 facility was in compliance. Okay. Okay. In 1992,this 1 the storage tanks; is that correct? <br /> 2 is May of'92, a closure plan was submitted for the 2 1„A. That's correct. <br /> 3 three underground tanks, which means a plan was 3 Q. And flow was that discovered, if you know? <br /> 4 submitted to the County for removal of the tanks. 4 j}A. Visual observation and odor. You know,just <br /> 5 Q. Okay. Not as a requirement of the County? 5 the inspector smelling the soil. That was the first <br /> 6 A. Not to my knowledge. This was a lot of 6 sign that there was contamination. <br /> 7 the-- 7 I'Q. Do you know who that inspector was? <br /> 8 As I was saying earlier,in 1987 some new 8A. Yes, Eric Trevena. <br /> 9 laws were enacted and at that time it was pretty well 9 I1)Q. Does the County regularly have an inspector <br /> 10 common knowledge that all single-walled metal tanks 10 on the site when the tanks are pulled? <br /> 11 would need to be removed in the State of California by 11 !'`A. Yes. <br /> 12 1998 and so that was probably voluntary on their part to 12 Q. From the day they are removed from the <br /> 13 the point that they wanted to go ahead and do that at 13 ground? <br /> 14 this time. 14 1U. Yes. <br /> 15 Q. Okay. Who submitted the plan? 15 {Q. Okay. And he made some notes in the file to <br /> 16 A. I am sure it was Save-Mar Oil Company. 16 that effect? <br /> 17 Q. In the plan,do they give any reason for the 17 PA. Yes. <br /> 18 removal of the tanks? 18 <br /> 1j, . Is his position as inspector basically the <br /> 19 A. No. Usually they do not. To my knowledge, 19 same position that you hold with the County? <br /> 20 they did not give any. I don't have the actual plan 20 A. After reviewing the file, I don't see any <br /> 21 with me but tom knowledge,usually not give a 21 an” that I would disagree with <br /> y edge y they � anything s gree as far as his <br /> f 22 any reason. They just want to get the single-walled 22 observations. <br /> 23 tanks out of the ground. 23 Q. I'm sorry. Maybe you misunderstood my <br /> 24 We routinely sample beneath the tanks to see 24 question. I meant in terms of his position with the <br /> 25 if there's any problem. And to my knowledge,there was 25 County. <br /> PORTALE & ASSOCIATES DEPOSITION REPORTERS Page 9 - Page 12 <br /> 1t <br />