9 19 24 West Orange BOA ZB 24 06 PSEG Full size

Page 110 1 that prevents it. 2 MR. MALANGA: Is there any reason why you 3 could not use the existing footings for the piers? 4 THE WITNESS: Yes, there is. 5 MR. MALANGA: What is that? 6 THE WITNESS: I have had extensive 7 conversations with our engineering department, this is 8 PSE&G Engineering. We believe that this fence dates 9 back to 1928. I apologize that we have no one in the 10 company who has first-hand knowledge of this anymore; 11 nor do we have retirees with first-hand knowledge, but 12 the drawings we have found shows this fence from 1928 13 and the piers which we checked in the field do conform 14 to the drawing from 1928. 15 We cannot validate the suitability of the 16 existing piers; nor can we validate the foundations for 17 the existing wrought-iron fence. 18 MR. MALANGA: Did you visit the site? 19 THE WITNESS: Absolutely. 20 MR. MALANGA: Did you see any piers that 21 were not plumb; that is, straight up and down, 22 vertical? 23 THE WITNESS: I apologize that I am not an 24 engineer and cannot tell you if they are plumb or not. 25 We believe it is better not to rely on construction