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David J. Irey, Esq. <br /> Mr. Douglas Wilson, R.L.H.S. <br /> October 25, 1993 <br /> Page Two <br /> With regard to test holes, my information is different than <br /> yours. I understand that no series of test hales has been dug. <br /> Falcon and Zuckerman-Mandeville have made some holes along the <br /> ditch in an effort to see how deep the trash may go. These efforts <br /> have not resulted in any estimate of the volume of the site. <br /> The only estimate of the sites volume was a guess by <br /> Zuckerman-Mandeville and me that the trash went about three to five <br /> feet deep. This was only a guess. No estimate other than this was <br /> ever presented during negotiations, nor was such an estimate <br /> the basis of the bargaining/negotiations. Your letter suggests <br /> that information was held back during our negotiations. This is <br /> simply not the case. You will recall that at your direction, a <br /> backhoe made a test whole (early on in the matter) . This one hole <br /> suggested that the trash did not extend the width of the higher <br /> ground at the dump site. You and I then discussed that the trash <br /> was somewhere between the ditch and this one test hole. No <br /> Zuckerman-Mandeville personnel estimated the volume because no <br /> Zuckerman-Mandeville personnel apparently knew the actual extent <br /> of the trash. <br /> Again, I know of no new estimate of the volume of the trash. <br /> If your office or Public Health Services would like such an <br /> estimate, we could develop one, but it will in all likelihood be <br /> very unspecific. <br /> Finally, I do not know to what you are referring in the third <br /> paragraph of your letter when you state ". . the meeting of early <br /> requirements regarding disclosure of certain information to this <br /> office." If you need anything from Zuckerman-Mandeville, you <br /> should direct such request to me. If you need anything from <br /> Falcon, you should refer to my letter of October 14, 1993. 2 am <br /> unaware of any specific requirements in the Clean Closure Plan or <br /> the terms of probation that set forth any sort of disclosure <br /> schedule. Upon request, Zuckerman--Mandeville through me will <br /> provide you and Public Health Services with any relevant <br /> information regarding the cleanup. In addition, any information <br /> or documents regarding the site that are at the site are always <br /> open to inspection and review by the on-site monitor. As to your <br /> prior requests for documentation that I passed on to Falcon, I have <br /> taken no further action on this matter (again as per my October 14 <br />