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JUN. ;O 99 (TKU) 14: 13 UNOCAL CNOR'f!l RE TEL:510 943781 P, 0�3 <br /> 1 3. Since 1992, PHSlEHD has assigned a series of three site mitigation <br /> 2 personnel to the Site, including Diane Hinson, from 1992 to 1995, Steve Sasson, from 1995 to <br /> 3 1997, and Margaret Lagorio, from 1997 to the present. After Unocal had performed wrrectivc <br /> 4 action at the Site for several years, iuuluditig conducting a soil vapor cxtraction pilot study, 1 <br /> 5 rcccivcd a letter dated January 9, 1997 from Mr. Sasson and Nis. Lagorio in which Choy stated that <br /> 6 "the assessment of groundwater contamination is complete, the assessment of soil contamination is <br /> 7 complete, and the plume appears to be stable." Attached to the Petition for Review and for Stay, <br /> 8 as Exhibit 2, is a true and correct copy of the Jannsry 9, 1(A7 letter that T received .from <br /> 9 Mr. Smsnn and Ms. Lagorio. Notwithstanding their conclusion that the assessment of the soil and <br /> 10 groundwater contamination at the Site was complete and that the plume appeared to be stable, they <br /> 11 nevertheless recommended that additional work be performed and that a feasibility study and <br /> 12 corrective action plan be prepared for the Site, [See Exhibit 2.] In response to the January 9, 1997 <br /> 13 letter, I wrote to Mr. Sasson on or about February 7, 1997, explaining why Unocal believed that no <br /> 14 further work should be required at the Site and that the Site was suitable for closure. A true and <br /> '15 correct copy of my February' 7, 1997 letter to W Sasson is attached to the Petition for Review and <br /> 16 for Stay as Exhibit 3. By letter dated March 3, 1997, Mr. Sasson and Ms. Lagorio responded by <br /> 17 informing me that closure of the Site was not appropriate. Attached to the Petition for Review and <br /> 18 for Stay, as Exhibit 6, is a true and correct copy of the March 3, 1997 letter_ <br /> 19 4., As a result of PHS/EHD's. arbitrary refusal to close the Site, OnocaL <br /> 20 asked its consultant, Pacific Environmental Group, to assist it in preparing and submitting a <br /> 21 petition for closure of the Site to the State Water Resources Control Board Cthe State Board"). 1 <br /> 22 am informed and believe and based upon such information and belief state that on or about June <br /> 23 13, 1997, Pacific Environmental. Group, Inc. submitted a petition to the State Board, on behalf of <br /> 24 Unocal, requesting closure of the site. A true and correct copy of the petition for closure is <br /> 25 attached to tic Petition for Review and for Stay as Exhibit S. <br /> 26 5. On or about July 3, 1997, a little more than two weeks after Unocal <br /> 27 ,nihmittn[1 itc pntitinn fnr r.1nciire, T rcpceived s letter frnm Margsret T.agorio of PHSlFHIM <br /> 28 informing me that PHS/EHD had received a copy of Unocal's .Pune 13, 1997 petition for closure of <br /> -1- <br />