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Following is another example of a “Don’t Do This!” In this case, the questions and answers are very confusing. There’s not much else we can say about this one, other than, “what”?

Q  Okay.

So from 122 at 12‑S to 10‑S, which is north, you have a potentiometric surface going from north to south; right?

That’s elementary hydrogeology; correct?

Are you doubting that?

A  No.

What ‑‑ what I’m ‑‑

Q  Well ‑‑ can you answer the question, please?

A  Sure.

Q  Is the answer “yes”?

A  No.

Q  It’s not?

A  The answer is, it’s going this way (Indicating), but there’s flow on this side of it.

This high is a radial flow.  This is a high point.

You have a radial flow.  So we’ve got flow going in this direction here (Indicating).  We’ve got flow going in this direction here, and then in that direction here.

Can some of this material go in that direction?


Q  Really.

So you think you could do particle tracking from a drop of water dropped at 12‑S, and you could make it go north onto the Angeles property?

MR. GRIFFIN:  Objection.



Q  Is that what you’re telling me?

MR. GRIFFIN:  Asked and answered.


THE WITNESS:  I would ‑‑ two things:

It’s the first time I’ve heard anybody has done particle tracking.  And if they have, I would be very interested in it.  We’ve never heard that before.

Q   And so where all this awful contamination that you’ve been talking about caption that’s under the AST area, the water from MW 10‑S that’s the high there, that’s all going away from the Angeles site and towards the McKesson AST area, and then on to the south; right?

That’s what the potentiometric surface shows?

A  I think the outfall is right here (Indicating).

The very high concentrations in the ditch are right here (Indicating).

This water (Indicating) is going right through that.

Q  Who ‑‑ was there anything about the outfall to the ditch in my question?

A  No.

But you’re saying that ‑‑

Q  Then why are you talking about it?

A  Because you’re saying that there was no contribution of contamination going in this direction (Indicating).

And I’m saying this clearly shows that it’s driving that contamination.