SITE INFORMATION AND CORRESPONDENCE

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t MICHAEL COLLINS CondenseItn" U JUNE 2, 1994 Page 33 ;E Page 35 1 usually not square and usually they have all kinds of I is that correct? 2 hulls and grooves and valleys where they are digging and 2 !`A. Could you repeat that? 3 I have all kinds of different shapes and I don't recall 3 I'Q. Looking at it vertically,thea the floor 4 drawing--trying to draw a diagram. I had another 4 samples that turned out to be nondetect were taken 5 inspector on site with me. His name is Harlan Knoll, 5 . within roughly a 15-foot radius of the original location 6 K-N-O-L-L,and we were trying to work as diligently as 6 of the samples that had the detections? 7 we could to make sure the pit was clean and gets it 7 ;= MR PAPAS: well, I'll object to the 8 cleaned up prior to the rainy season for Mr. Mozeb. So 8 extent that it calls for speculation. 9 as far as knowing exactly where the--I don't have a 9 1If you can tell based upon looking at that 10 good diagram of it. I could probably look at the 10 diagram or else the recollection that you have to answer 1 I pictures and-- 11 it. 12 Q. Well,do you have any kind of a recollection 12 'THE wrmEss: The original samples were 13 just generally where the location was? 13 taken at'14 feet. You are referring to them,carrect, 14 A. Of the ones that were the significant hits 14 b9eath tanks? F 15 with the contamination,is that what you are asking? 15 Q. Yes. 16 Q. Well,I think you indicated those were in 16 A. And the question was if the bottom samples 17 the west side wall of the pit? 17 were taken within a radius of 15 feet of that? 18 A. They were taken down around twenty feet,I 18 Q. Vertical radius. 19 think,on the western side wall. 19 A. Vertical. There would be a slight 20 Q. Okay. My original question was about the 20 horizontal component of five or ten feet,but yes. I 2I samples taken from the bottom of the pit. 21 don't see any problem with that. 22 A. They were taken along the comer of the 22 Q. Actually, you can -- I y guess it would be a . 23 western wall and the bottom of the pit right at the 23 horizontal radius,wouldn't it? 24 corner on the bottom. 24 if MR.PAPAS: That's what I was 25 Q. Okay. And we had a pretty good map here a 25 wondering. . Page 34 ' Page 36 1 second ago. I think it was the map that was attached to I :1 MR,HASTINGS: Q.Looking at it from 2 the addendum to the work plan. 2 the top down,it was within five to ten feet off the 3 Do you have that handy again? Is this the 3 original location? In other words,you wouldn't--if 4 one? 4 the,original detection, for example,this one is noted 5 A. Yeah,there we go. 5 by number one,which I guess was sample number one, 6 Q. At this point, did the pit include the three 6 which is detected 1300 parts per million of the-- 7 boring holes? 7 whatever that was,it wouldn't make sense when you find 8 A. When we were finished excavating,the pit 8 out if your floor's clean at 30 feet, if you take it 9 had included several of the boring holes just up to the 9 over in the lower right-hand corner? 10 bore hole and stopped. We hit concrete and stopped. �M1 Aped. 1D A. Correct. 11 Q. At the time that the floor samples were 11 Q. So you take it within the approximately same 12 taken,was it, I guess I'm trying to get a good 12 location as the original samples? 13 visualization of where those final floor samples were 13 A. 'Correct. 14 taken in relation to the boring holes? 14 Q. Okay. I y guess at some point you were 15 A. The bottom samples you are referring to? is satisfied that the hole what,is clean? 16 Q. Yes. 16 A. That's correct. 17 A. The bottom sample was taken in the center 17 Q. Okay. Can you tell me when that was? ' 18 between the north and south and along the western edge 18 A. December the 8th, 1992. 19 so it would be north and south and western edge of the 19 Q. Okay. And is there some document in your 20 bottom sample. It would be more or less right in this 20 file'ithat refers to that or just your note? 21 area here(indicating),about 30 feet. 21 A. Just the notes. Also,I spoke with the 22 Q. Okay. Okay. So within an approximate 22 other inspector on site,Harlan Knoll,in the office 23 15-foot diameter circle or radius rather,of the 23 regarding the lab results that were fax'd on that day to 24 original boring sample or the original sample that 24 us,and I have a natation in the file that he concurred, 25 detected 600 parts per million and the 1300 per million; 125 also. . PORTALE & ASSOCIATES DEPOSITION REPORTERS Page 33 - Page 36