SITE INFORMATION AND CORRESPONDENCE

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3 MICDAEL COLLINS Condenseitj'' i LlJUNE 2, 1994 Page 25 Page 27 1 September 8th? i contarninated,why sample at this point? So to my II �+ i. 2 A. September 28th. 2 knowledge,there were none taken at that point. 3 Q. Okay. And when was it actually performed? 3l`Q. Okay. What was the next step taken? 4 A. September the 28th. 4 j'A. The next step,addendum to the work plan was 5 Q. Oh,so the same day it was scheduled for? 5 sul}mitted by Quorum Environmental to do five soil 6 A. Yes. 6 borings on the western side of the pit—not the pit, 7 Q. And how far did they over excavate the hole? 7 but the western side to determine the full extent of the 8 A. Approximately 200 cubic yards of soil was 8 soil contamination both vertically and horizontally. 9 excavated at that time to 22 feet deep. I was there on 9 Q. Okay. So I guess by this time the pit is 10 site. There were still --there was still noticeable 10 larger than the original area taken up by the tanks so 11 contamination visually and odor, so the excavation was 11 you wouldn't be against the wall of the pit,you'd be 12 stopped at that point, at 22 feet,in order for them to 12 taking the samples from the area where the contamination 13 regroup,you might say. It was more extensive than it 13 was previously noted? 14 was previously thought to be. 14 A. We would be out on the surface doing the { 15 Q. Okay. So was it previously planned that the 15 soil borings. 16 excavation would go to 22 feet and that--I don't know 16 Q. "Surface" being the bottom of the pit? 17 if hopeful was the right word,but the expectation 17 A. No, the surface above the pit. Here's a ++ I8 anticipated at least that that should be a sufficient 18 diagram. This is the pit itself(indicating). Here's ; 19 enough over-excavation initially? 19 the}market and this is the western side. Five borings 20 MR.PAPAS: Object to the question on 20 were placed into the soil on the surface down to around 21 the ground it is vague and ambiguous. 21 40ifeet, as I recall. I'll have to check that,but to 22 Go head. 22 determine the vertical and horizontal extent of the 23 MR.HASTINGS: Q.What was the 23 contamination. 24 original work plan? What depth did the excavation of 24 Q. Why wouldn't you do a boring right in the 25 the work plan provide for? 25 floor of the pit itself? Page 26 Page 28 1 A. I'll have to look at the work plan again. 1 'A. The pit itself was 22 feet deep at that time 2 MR.PAPAS: why don't you look at 2 and it would have been a safety factor to try--to 3 Plaintiff's Exhibit 2? 3 drive a rig down in there to do a boring. It's not done 4 THE WITNESS: Okay. 4 very often. 5 This is a normal work plan in that initially 5iQ. Okay. How are boring samples taken? Do 6 we don't really know the extent of the contamination. 6 they have some kind of machine that drills a hole Like a 7 Just from prior experience we generally have a feel for 7 water-well-type drilling rig? 8 what it will be. When I said that it was more extensive 8 A. It's a drill rig with an auger that goes 9 than I thought it would be or we thought it would be,it 9 down and I believe that one went to--most of those 10 was just coming from prior experience. 10 borings went to around 40 feet. They were sampled and 11 The work plan itself did not state exactly 11 analyzed every five feet and they all came back 12 how deep it would go or when it--when the excavation 12 non-detect for TPHg and ETEX. 13 would stop,but usually the excavation is stopped when 13 '' So that is what we mean by regrouping and e 14 the backhoe itself reaches the full extent that it can 14 thinking about how we want to attack the problem. This 15 reach and you take a look at the surrounding property, 15 gave us information that,the five borings where they € I6 buildings,et cetera, and you say,Well,we need to stop 16 were placed,there was no gasoline contamination down to 17 here. We can't dig any further. We need to think about 17 40 feet so we knew that we still had a problem to deal 18 this for awhile,how we're going to attack the problem. 18 with in the pit itself. 19 MR.HASTINGS: Q.Okay. Then what 19 Q. Okay. 20 happened at 22 feet when the excavation stopped? Were 20 A. Can I continue? 21 there additional soil samples taken? 21 Q. Sure. 22 A. I don't recall any soil samples being taken 22 MR PAPAS: well,you need to respond 23 at that time because the visual and just the odor of the 23 to his questions. Let him ask the questions. F 24 sample,a lot of times we stop and think,are soil 24 THE wrrrrESS: okay. 25 samples necessary at this time? We know that it's 25 1 MR.HASTINGS: Q.What did it tell you PORTALE & ASSOCIATES DEPOSITION REPORTERS � Page 25 - Page 28