SITE INFORMATION AND CORRESPONDENCE

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bUCHAEL COLLINS Condmsidt . U JUNE 2, 1994 Page 45 Page 47 1 property prior to--well,if it had been removed prior 1 I can further state that's not my area of expertise,the 2 to or at the time that the hole had been clean ed,which 2 prectsron testing or that particular arra is in another 3 apparently was December 8th, 1992,is when you notified 3 unit,Eric Tnovata's unit. 4 S[iN they could fill the hole? 4 MR.HASTINGS: Q.Okay. Do your 5 A. December 8th, 1992,correct. 5 records indicate that there was any precision tasting 6 Q. If the soil,contaminated soil had been 6 perfornied on these tanks between October 19—I'm sorry 7 removed to a different Save-Mor site or to antable 7 November 1990 and accep May 19927 . 8 landfill prior to that date,when would the closure-- 8 'A. Could you state that again? 9 when would the County's closure letter have been issued? 9 Q. Sure. 10 A. If the soil was removed to a landfill,the 10 Do your records indicate whether or not 11 landfill accepts responsibility for the soil. A closure 1 I there was any precision testing supplied to the 12 letter could have been mailed at that point. If the 12 County--results of precision testing supplied to the f 13 soil was removed to another area,property of Save-Mor 13 County between November 1992 and May 19927 14 or Mr. Mozeb, we could not issue a closure letter until 14A. You said October of'90 through May of'92? f 0. 15 _ the soil2 _was clean or a landfill or whatever.. 15 T,.._. Q.:.I think November of'90.-. l 16 Q. Okay. So the site, then,when you are 16 A. November of'90. November of'90 precision 17 speaking about a site closure letter,it's not only 17 tests for all tanks were received and facility was in 18 talking about the location but also the contaminated 18 compliance. As I stated earlier,the closure plan for 19 soil that may be removed or.relocated to a different 19 removal of the tanks was received in May of'92. ;t 20 location? 20 Q. All right. So no tests,then,were 21 A. Could you repeat that? 2I submitted to the County between November of'90 and May 22 Q. In the site closure letter,the site that 22 of'92? 23 you are referring to is not only the actual physical 23 A. That's correct. =.k 24 location of where the contamination had been but also 24 Q. Who did the precision tests in November of 25 the contaminated soil that had been excavated. So even 75 1907 Page 46 k Page 48 1 though the soil had been excavated and removed somewhere 1 A. That is going to be found in an underground 2 else and the hole clean backfilled,you couldn't issue 2 tank file that I do not have with me. This is--the ;h I, 3 the site closure letter even though someone looking at 3 file1,that I brought is primarily the cleanup file and I 4 the property wouldn't have any idea whether or not there 4 did!bring narratives from the underground tank file but 5 had been contamination them or not? 5 1 don't have the specific information about who did the 6 A. That's correct. 6 precision test. 7 Q. Because.soil is still under that 7 Q. Okay. If you don't mind,I'd like to have a 8 jurisdiction? 8 a copy of the amended site--I am sorry, the amended 9 A. That's correct. 9 work plan marked and attached to the deposition as 3,1 10 Q. On the day they removed that,you weren't 10 guess,and then if I could just take a look at-- I 1 i there that day. Do you have an opinion as to how the 1 I think you made mention earlier that you had some reports 12 contamination got underneath the tanks when the tanks 12 in your binder? E 13 apparently had tested clean or tested through precision 13 A. Tltat's correct. E 14 testing that apparently there had been no leaks 14 Q. What type of reports are they? E 15 detected? That wasn't a very good question. Let me ask 15 A. These are reports that came from Quorum 16 that again: 16 Environmental and sxN regarding the work that we've 17 Do you have an opinion as to how the 17 referred to earlier and also the lab analysis that was 18 contamination occurred below the tanks when on the 18 submitted to them. 19 inspections dating back into 1986 apparently indicated 19 Q. Okay. Mr. Collins,you understand that ` 20 that the tanks was not leaking? 20 you've been designated as an expert by the Defendant in r 21 mR PAPAs: rll object to the extent 21 the litigation between Mr. Mozeb and Save-Mor Oil 22 it calls for speculation. I think he previously stated 22 Company? [ 23 that the last test was in November 1990. 23 A. I heard that this morning,that's correct. 24: But go ahead and you can answer. 24 But referring to the Defendant,are you 25 TnE wrrNEss. I don't have an opinion. 25 referring to this Save-Mor Oil Company? PORTALE & ASSOCIATES DEPOSITION REPORTERS ;k Page 45 - Page 48