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` MICHAEL COLLINS CondenseIt"' ;kt I JUNE 2, 1994 Page 13 � Page l5 . 1 A. Oh, 1 Q. Okay. So I think I'm getting the picture 2 Q. Is his employment position with the County, 2 now. On June 19th,the tanks were removed and it's 3 is it the same as yours? 3 apparent,at least to Mr.Trevena that that there had 4 A. Yes. 4 been some contamination? 5 Q. You are not his supervisor? 5 t3 A. Yes. 6 A. No. We are in different units but we have 6 ! Q. So that he is responsible to remove the 7 the same position. 7 tanks and develop a plan to eliminate the contamination, 8 Q. What unit is he in? 8 I guess? 9 A. He is in a unit called the Underground Tank 9 3;'A. That's correct. 10 Unit,which oversees precision testing,tank removals 10 After they get the chemical analysis back, I 1 and I am in a unit that oversees the cleanup after the 11 too. That usually takes two to three weeks. They look 12 tank removal, if there's a problem,contamination. 12 at the results and develop a plan to clean it up. 13 Q. I see. 13 Q. Okay. And do you know what those results 14 So you actually saw this file, it sounds 14 were of the samples taken on June 19th? 15 like,for the first time after Mr. Trevena made the 15 A. Yes. Six samples were taken beneath the 16 determination that there had been some contamination? 16 three tanks,two samples per tank and we can call them 17 A. 'That's correct. e 17 Tairk One,Two and Three. They were all three gasoline. 18 Q. Okay. Who actually does the soil sampling 18 tanks,regular and unleaded,and would you like for me i I9 when tanks are removed? Is that a function that the 19 to,speil out the results at this point? Just read them 20 County does or is that the function of the tanks owner 20 o They are pretty lengthy. 21 or the removal specialist? 21 ! Q. Why don't you take let me take a look at 22 A. The removal specialist does the soil 22 what you are reading there. 23 sampling beneath the tanks and it's overseen by the 23 it A. It is the first part of the table here. 24 county inspector. 24 i;Q. You know what I'm going to have you do,do 25 Q. Okay. When was your first contact with this 25yoL mind telling me what findings or what results on Page 14 Page 16 1 site, "you"being Mr. Collins? l here you find significant-- 2 A. I was given the results of the sampling 2 A. Okay. 3 beneath the tanks on 8-7-92. 3 1;Q. -- in terms of contamination? 4 Q. When had the tanks been removed? 4 !�A. Under Tank Number One on the western part of 5 A. They were removed on 6-19-92. 5 the tank,total petrolem hydrocarbon gasoline't'PHg for 6 Q. So I would take it,then,on 6-19, 6 short, 1300 parts per million. That tank also had other 7 Mr. Trevena noted that will there had been some 7 gasoline constituent with contamination including 8 contamination and some samples were taken on that day? 8 benzene,toluene,ethylbenzene and xylene,which we can 9 A. That's correct. 9 refer to as BTEX,if you would like,B-T-E-X. 10 Q. Now do you know why it would be about a 10 Under Tank Two on the western side,which by I 1 month and a half a month and three weeks later that you 11 the way,the western side was the side of the pit which 12 would receive the file or receive contact? 12 had the problem which was the side towards his market. 13 MR PAPAS: well,I'm objecting to the 13 1{Q. The pit,is that where they generally fill I4 extent that it calls for speculation. 14 the tanks up? 15 You can answer it,if you know. 15 1?A. That would be--that's the hole in the 16 THE wrrNF-ss: 1 don't know. 16 ground left after he removed the tanks. 17 MR.HASTINGS: Q.Is that a typical 17 Q. Okay. 18 time? 18 ,°A. The western side was the side where the 19 A. I would say it's pretty routine that we 19 problem was,where the contamination was. 20 usually get a work plan. Actually, it was received on 20 So it was the west side of the tank? 21 that date, 8-7-92. A work plan was received by me which 21 iSA. That's correct. 22 had the results of the sampling and it also stated a 22 Underneath Tank Two on the western side, 600 23 scope of work which they intended to do to excavate the 23 TPHg and also other problems with BTEK,pretty 24 soil beneath the tanks. So that length of time to me is 24 noticeable contamination numbers. That was the most 25 not surprising. 125 significant areas underneath the three tanks. PORTALE & ASSOCIATES DEPOSITION REPORTERS !}� Page 13 - Page 16 i