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_MICHAEL COLLIMS Condenself ` !i JUNE 2, 1994 <br /> Page 17 Page 19 <br /> 1 Q. How about Tank Three, did it have any? 1 that it would be necessary to do what we call a public <br /> 2 A. Tank Three had minor contamination. 2 participation for the site. <br /> ' 3 Q. And what depth are the samples taken at? 3 PQ. What does that mean? <br /> 4 A. Fourteen feet. 4 'A. That means that we need to notify the nearby <br /> 5 Q. Each of them? 5 people that live in the area and the school itself,in <br /> 6 A. Yes. 6 this case,that there is contamination an the property <br /> 7 Q. And generally,what did the work plan 7 nearby and that there is going to be some work done on <br /> 8 provide for? 8 the,[property to remove the contamination and we wanted <br /> 9 MR.PAPAS: I'm sorry. What was your 9 to notify them that this was going to be happening and <br /> 10 question? 10 give them 30-day notice that if there is any questions <br /> 11 MR.HASTINGS: Q.Generally,what did 11 that they have regarding their possible health safety <br /> 12 the work plan provide for, the elimination of the 12 that they can contact us and we'll answer any concerns. <br /> 13 contamination? 13 And we wanted to let them know that we felt the benefits <br /> 14 A. It provided for an over excavation of the 14 of the cleanup and the excavation outweighed any <br /> 15 soil beneath the former tanks. 15 possible health risks to them and we let them know that. <br /> 16 Q. Now is the work plan generally maintained in 16 And we didn't get any questions from the school or any <br /> 17 a different file or different location at your office? 17 of the neighbors. So we gave them 30 days to do that. <br /> 18 A. I have the work plan here. 18 Q. During that 30-day period can any work take <br /> 19 Q. Oh,you do? I thought you said that you 19 place on the property? <br /> 20 didn't. 20 A. Not in the form of a cleanup or remediation. <br /> 2I A. It's in the file. Would you like to see it? 21 Preparations can be made but not any form of the <br /> 22 Q. Yeah, please, if I could. 22 remediation in the scope of the work plan. <br /> 23 And this was from Quorum Environmental 23 Q. So you had approved the work plan but <br /> 24 Consultants? 24 couldn't begin that until thirty days ran on the public <br /> 11 <br /> 25 A. That's correct. 25 participation notice? <br /> Page 18 E —-- Page 20 <br /> 1 Q. Why don't you put a flag on that because I'm 1 A.; That's correct <br /> 2 going t0 do something here. 2 Q. � Whcn they did the initial six soli samples, <br /> 3 Is there anything in that le-colored 3 was there a <br /> ythl g purp torp prcpated for the location of those <br /> 4 document,is that all the work plan? 4 samples? <br /> 5 A. I believe so,yes. 5 A. Yes. <br /> 6 Q. Okay. What does your file indicate the next 6 Q.' And that's maintained in your file as well? <br /> 7 thing was to happen at the site? 7 A.,� Yes. I have a map right here, <br /> 8 A. Okay. As I stated,the work plan was 8 Q.11 Drawn by the hvpecw Enc Trevem <br /> 9 received on 8-7-92. The paperwork in our office began 9 1�okay. And if you don't mind,why don't we <br /> 10 at that time. 10 take a short break and I'll take a photocopy of that so <br /> 11 Q. What does that mean, somebody reviewed the 11 we can make some rkitgs on it. <br /> 12 work plan to see if it was appropriate? 12 Exhibit Num t,frands2 wwc <br /> 13 A. Yes, I did,and a file was begun at that 13 marked for identification.) <br /> 14 point. A lot of paperwork is necessary. We go back and 14 411 ,,,R xnsrmtas:v Mr.Conitro with <br /> 15 research the property owner,look at the APN number, 15 your peratission we've taloa,a copy of the map,if you <br /> 16 things like that. 16 will,or the site plan that was in your file. I guess <br /> 17 I went out on that day to make a site 17 this was prepared by Elie Ttevena? <br /> 18 inspection and the work plan was approved after I looked 18 A.�f MAIa cartoct. <br /> 19 at the site. Spoke with Mr. Mo2eb that day and he let 19 Q.i And we've marked that rlaintifre Exhibit <br /> 20 me know that he was in a hurry to get everything cleaned 20 one;is that correct? <br /> 11 <br /> 21 up. 21 A That's correct. <br /> 22 Also,we noted that there was a school 22 Q. Do you know from looking at this map here <br /> 23 across the street,Houston School. Spoke with my 23 where the filler location was for the tanks? Do you <br /> 24 supervisor at that time,Diane Henson. This is 8-11-92. 24 know l mean by"filler location"? <br /> 25 Spoke with my supervisor Diane Henson and we decided 25 A. f Yee,I know what you mean. <br /> PORTALE & ASSOCIATES DEPOSITION REPORTERS Page 17 - Page 20 <br />