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FOSHEE & TURNER COURT REPORTERS 1 IN THE UNITED STATES DISTRICT COURT 2 NORTHERN DISTRICT OF ALABAMA 3 EASTERN DIVISION 4 5 WALTER OWENS, et al., ) 6 Plaintiff, ) 7 8 vs. ) ) CIVIL ACTION NO. 9 ) CV-P-440-E 10 MONSANTO COMPANY, ) 11 Defendant. ) 12 13 DEPOSITION OF: JERRY SANFORD 14 15 In accordance with Rule 5 (d) of The 16 Alabama Rules of Civil Procedure, as Amended, 17 effective May 15,1988,1, TAMMY JENNINGS 18 GREGORY, am hereby delivering to MR. LARRY WRIGHT 19 the original transcript of the oral testimony 20 taken on the 21st day of October, 1999, along 21 with exhibits. 22 Please be advised that this is the same and 23 not retained by the court reporter, nor filed OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036672 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 2 FOSHEE & TURNER COURT REPORTERS 1 with the Court. 2 The deposition of Jerry Sanford was taken 3 before Tammy R. Jennings Gregory, commencing at 4 10:00 A.M. on the 21st day of October, 1999, by 5 the Plaintiffs, at the law offices of Fite & 6 Miller, Anniston, Alabama, pursuant to the 7 stipulations set forth herein. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036673 22 23 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 3 FOSHEE & TURNER COURT REPORTERS 1 APPEARANCES 2 3 Appearing For The Plaintiffs: 4 5 MITHOFF & JACKS, LLP 6 Larry Wright, Esquire 7 111 Congress Avenue, Suite 1010 8 Austin, Texas 78701 9 10 Appearing For The Defendant: 11 12 LIGHTFOOT, FRANKLIN & WHITE 13 By: Adam Peck, Esquire 14 The Clark Building 15 400 20th Street North 16 Birmingham, Alabama 35203-3200 17 18 Court Reporter: 19 OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036674 20 Tammy R. Jennings Gregory 21 22 23 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 4 FOSHEE & TURNER COURT REPORTERS 1 INDEX 2 3 Witness: Jerry Sanford 4 Stipulations...........................page 5 5 Examination by Mr. Wright............. page 8 6 Reporter's Certificate................ page 69 7 8 9 10 11 12 EXHIBITS 13 14 (No exhibits were marked for identification, 15 offered, or attached as exhibits hereto.) 16 17 OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036675 18 19 20 21 22 23 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 5 FOSHEE & TURNER COURT REPORTERS 1 STIPULATIONS 2 3 IT IS STIPULATED AND AGREED by and 4 between the parties through their respective 5 counsel that the deposition of Jerry Sanford may 6 be taken before Tammy R. Jennings Gregory, at the 7 law offices of Fite & Miller, Anniston, Alabama, 8 on the 21st day of October, 1999. 9 10 11 IT IS FURTHER STIPULATED AND AGREED that 12 the signature to and the reading of the 13 deposition by the witness is waived, the 14 deposition to have the same force and effect as 15 if full compliance had been had with all laws and OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036676 16 rules of court relating to the taking of 17 depositions. 18 19 20 IT IS FURTHER STIPULATED AND AGREED that 21 it shall not be necessary for any objections to 22 be made by counsel to any questions, except as to 23 form or leading questions, and that counsel for 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 6 FOSHEE & TURNER COURT REPORTERS 1 the parties may make objections and assign 2 grounds at the time of trial or at the time said 3 deposition is offered in evidence or prior 4 thereto. 5 6 7 IT IS FURTHER STIPULATED AND AGREED that 8 the notice of filing of the deposition is waived. 9 10 11 12 13 OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036677 14 15 16 17 18 19 20 21 22 23 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 7 FOSHEE & TURNER COURT REPORTERS 1 STATE OF ALABAMA, CITY OF ANNISTON, 2 OCTOBER 21, 1999, 3 10:00 AM., 4 5 JERRY SANFORD, 6 having been first duly sworn, was examined and 7 testified as follows: 8 9 COURT REPORTER: Usual stipulations 10 okay? 11 MR. WRIGHT: Form and OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036678 12 responsiveness are the only objections? 13 MR. PECK: As to form. And all 14 other objections are reserved. 15 MR. WRIGHT: Yeah. 16 MR. PECK: That's fine. Jerry, you 17 have a right as well to read and sign or 18 waive it. Oftentimes, it's waived. It's up 19 to you though. 20 THE WITNESS: That's fine. I'll 21 just waive it. 22 23 --oOo-- 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 8 FOSHEE & TURNER COURT REPORTERS 1 EXAMINATION BY MR. WRIGHT: 2 Q. Mr. Sanford, thank you for coming in this 3 morning. Have you ever given a deposition 4 before? 5 A. No. 6 Q. Okay. I'm sure you understand this, but I'm 7 going to go through it just to make sure that 8 you understand it, that a deposition is 9 testimony that can be used at the time of OWENS 05- 15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036679 10 trial. 11 You've given an oath, and it's the 12 same oath that you would take if you were 13 going to testify in the courtroom. And the 14 testimony you're giving can have the same 15 force and effect as if you were sitting up in 16 front of a judge and jury. You understand 17 that? 18 A. Yes, sir. 19 Q. If I ask you any question that you don't 20 understand, it's fair game for you to stop me 21 and say, Larry I just don't understand you; 22 can you ask it a different way, and I'll be 23 glad to do that. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 9 FOSHEE & TURNER COURT REPORTERS 1 A. Okay. 2 Q. The only other thing I'm going to ask you is 3 to speak up so that our court reporter can 4 write down your answers. 5 A. Okay. 6 Q. And you'll probably forget along the way, and 7 I'll remind you. Don't be offended. OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036680 8 Everybody forgets, and we're all used to it, 9 particularly the court reporter. 10 Can you tell me where you work now? 11 A. I don't work anywhere now. I'm retired. 12 Q. When did you retire? 13 A. 1st of April of'96. 14 Q. And you retired from Monsanto? 15 A. Yes. 16 Q. I want to go back and in a kind of summary 17 way trace through your work history. 18 A. Okay. 19 Q. And starting with your graduation from high 20 school, what did you do? 21 A. Okay. I graduated in 1959 from Jacksonville 22 High School in Jacksonville, Alabama. I 23 worked in Gadsden at Service Auto Parts, a 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 10 FOSHEE & TURNER COURT REPORTERS 1 parts store, for probably a couple of years. 2 And then I went to work -- I moved 3 to Anniston -- and went to work at Economy 4 Auto Stores and worked -- I'm not sure how 5 long -- a while there. OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036681 6 Q. Okay. 7 A. Then I went to work with Southern Life and 8 Health Insurance Company, and I worked with 9 them until April of '64, and I went to work 10 with Monsanto April of '64. 11 Q. What was your first job with Monsanto? 12 A. I was an operator, vacation relief operator. 13 Q. In what area? 14 A. In the chlorine department. 15 Q. Is that the caustic chlorine facility there 16 where they made chlorine? 17 A. Yes, sir, that's where they made chlorine. 18 Q. And how long were you in that job? 19 A. I worked there as vacation relief the first 20 summer that I worked. I went to work in 21 April of '64, and I worked there that summer 22 as vacation relief. 23 Q. Then what was your next position? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 11 FOSHEE & TURNER COURT REPORTERS 1 A. I transferred from there to the parathion 2 department in December of '64. 3 Q. Okay. What was your job in the parathion OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036682 4 department? 5 A. I was an operator. I started out in the 6 drumming area. 7 Q. And how long did you stay in that job? 8 A. I -- probably a year or maybe two. I'm not 9 sure. 10 Q. Okay. Then where did you go? 11 A. Just moved up the line. They had seniority. 12 You moved up the line to different jobs, to 13 better jobs, I guess you'd say. 14 Q. Okay. 15 A. And so I moved up the line, progressed up the 16 line by seniority. 17 Q. We'll walk through that real quickly, but 18 just before we do, did you stay in the 19 parathion department until you retired? 20 A. No, I did not. 21 Q. Okay. Then let's go back. You worked your 22 way up in the parathion department? 23 A. Correct. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 12 FOSHEE & TURNER COURT REPORTERS 1 Q. What was your final job -- I get the OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036683 2 impression you went back to the parathion 3 department after you left the parathion 4 department? 5 A. I worked in the parathion department as an 6 operator. 7 Q. Right. 8 A. And I worked up through the jobs. The last 9 job I had as an operator was I ran the stills 10 and chlorinators. 11 Q. When was that? 12 A. 1972. 13 Q. Then where did you go? 14 A. Okay. I was promoted to foreman 1972. 15 Q. Okay. 16 A. And I went into the maintenance department. 17 Q. Okay. 18 A. And my job there was I was the spare parts 19 specialist in the storeroom. That was the 20 first job I had as maintenance foreman. 21 Q. I'm sorry. Would you say that again? 22 A. I was the spare parts specialist in the 23 storeroom. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 13 FOSHEE & TURNER COURT REPORTERS OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036684 1 Q. And how long did you stay in that job? 2 A. Probably a couple of years. 3 Q. Then where did you go? 4 A. Okay. Then I was transferred back to the 5 parathion department as foreman over the 6 intermediate area. 7 Q. About '74 you would say? 8 A. Yes, sir, I think about '74 would be about 9 right. 10 Q. And how long did you stay in that job? 11 A. Okay. I stayed there until about '78 or '79. 12 I'm not sure exactly of what year there. 13 Q. And what was your next job? 14 A. I was transferred to the recycle department 15 as the foreman. 16 Q. And what did that job entail? 17 A. That was the new process to recycle the 18 organic residue from the stills. 19 Q. Were you the first foreman of that 20 department? 21 A. Yes, sir. 22 Q. We'll talk about that in a minute. 23 A. Okay. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 14 OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036685 FOSHEE & TURNER COURT REPORTERS 1 Q. Then what was your next job? 2 A. Okay. I transferred from there then to the 3 foreman of P2S5 and PNP department. 4 Q. When would that have been, just best 5 ballpark? 6 A. '82 maybe. 7 Q. Foreman in the -- over both departments? 8 A. Yes, sir. 9 Q. Okay. How long did you stay in that job? 10 A. Probably about a year in that job. 11 Q. Then where did you go? 12 A. Then I went just as foreman of the PNP 13 department. And then I stayed there until I 14 retired. Of course, they changed the name 15 from foreman to first levelsupervisor 16 sometime back in there.I'm not sure when. 17 Q. All right. So '83 to '96 foreman of the PNP 18 department? 19 A. Yes. 20 Q. Or supervisor of thePNP department? 21 A. Yes, sir. 22 Q. Explain to me your job in the chlorine 23 department. OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036686 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 15 FOSHEE & TURNER COURT REPORTERS 1 A. Okay. I was an operator. I was vacation 2 relief. I worked mostly third shift all that 3 summer because people take their vacation on 4 third shift. 5 Q. Okay. 6 A. I worked in what they call the brine area and 7 cell room itself. 8 Q. Third shift would be the night shift? 9 A. From 11:00 at night to 7:00 in the morning. 10 Q. You get the privilege of explaining how the 11 chlorine department worked because you're the 12 first person we've talked to. 13 A. You've picked the wrong person. 14 Q. You're the first one we've talked to that 15 worked there. 16 A. I told you I worked third shift in the dark. 17 Q. It was dark and a long time ago, but just 18 tell me the best you can how that worked. 19 A. Chlorine is made by -- you have a brine 20 mixture, a salt brine mixture, and it is 21 pumped through a long cell, but you have 22 mercury running through the bottom of the OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036687 23 cell, and you have a DC electric charge going 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 16 FOSHEE & TURNER COURT REPORTERS 1 through the brine down to the mercury. 2 Q. Okay. 3 A. And this electrolysis, or whatever you call 4 that, then produces chlorine gas. 5 Q. Okay. 6 A. And that's how it's made. 7 Q. Can you describe what that cell looked like? 8 A. A long cell, probably, maybe three times as 9 long as this table. Not quite as wide. It 10 had a -- probably some kind of slate or 11 marble bottom in it that the mercury flowed 12 down through. 13 And it had a rubber cover over it 14 with a vacuum system coming out of it to pull 15 the gas off. 16 Q. Okay. About twenty-five feet long would you 17 think? 18 A. I may be off ten foot, but that's probably-19 I guess. 20 Q. And did it look kind of like -- did it look OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036688 21 kind of like a narrow table, you said, with a 22 slate bottom? 23 A. Yes, sir. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 17 FOSHEE & TURNER COURT REPORTERS 1 Q. Okay. Kind of like a shuffle board? 2 A. Probably about that length, uh-huh 3 (indicating yes). 4 Q. Was the rubber cover rounded? 5 A. Seemed like it was. I mean, -- 6 Q. I know it's been a long time. 7 A. Thirty-five years ago. 8 Q. And then was there just one exhaust hose to 9 siphon off the gas? 10 A. I can't -- I don't remember that. 11 Q. Okay. Was the hose you remember at one end 12 or the other or in the middle? 13 A. I don't remember that. 14 Q. Don't remember that either? 15 A. I don't remember that either. 16 Q. That's all right. We'll do the best we can. 17 Whatever you remember, you remember, and 18 whatever you don't, you don't. OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036689 19 A. Okay. 20 Q. Now, the operator's job was what? 21 A. Was just to monitor the cell room, to take 22 samples of the caustic. The brine, as it 23 went through, it produced chlorine gas, and 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 18 FOSHEE & TURNER COURT REPORTERS 1 then as a by-product of that, this brine was 2 turned in what we call caustic. 3 So we monitored that to get the 4 percentage of the percent of caustic that we 5 wanted because they sold, you know, the 6 caustic. 7 And so therefore, we added water, 8 and then we controlled the PH of the brine in 9 order to get the caustic. The chlorine was 10 kind of like a by-product of making caustic. 11 Q. Okay. Now, the mercury, did y'all have to 12 add mercury from time to time? 13 A. From time to time, yes, but now, I don't 14 think I ever did. I worked the third shift. 15 I was young, you know. 16 Q. That would have been done by somebody else? OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036690 17 A. Yes, sir. I don't -- I don't recall that I 18 ever had to add mercury. 19 Q. Was it a continuous operation? 20 A. Yes, sir. 21 Q. Twenty-four hours a day? 22 A. Yes, sir. 23 Q. Was there only one cell? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 19 FOSHEE & TURNER COURT REPORTERS 1 A. No. There was maybe twenty, maybe more, 2 maybe thirty. I -- I'm not sure. Maybe 3 twenty or thirty. 4 Q. Was it your job to operate all of those 5 cells - 6 A. Yes, sir. 7 Q. -- when you were on? 8 A. Yes, sir. 9 Q. Okay. Was there only one operator at a time? 10 A. There was one operator in the cell room. 11 There was one operator in the brine room, and 12 then there was a chief operator. 13 Q. Do you remember who those other two people 14 were? OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036691 15 A. On the shift that I worked on, I worked with 16 Wade O'Brien. He was a chief operator. I 17 worked with him a good bit. He is deceased, 18 by the way. 19 I worked with Gene Hill. Since I 20 was vacation relief, now,I worked with 21 several different ones. 22 Q. Right. 23 A. I worked, you know -- 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 20 FOSHEE & TURNER COURT REPORTERS 1 Q. Tell me all the ones that you remember. 2 A. Melvin Womack was one. 3 Q. And tell me if they're still alive. 4 A. Yeah. Wade O'Brien is the only one that's 5 deceased so far. 6 Q. Okay. 7 A. Well, BillOwen. 8 Q. Okay. 9 A. Martin -- Mr. Martin. I don't know what his 10 first name was. 11 Q. Martin was his last name? 12 A. Yes. OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036692 13 Q. Okay. 14 A. Mr. Rainwater. 15 Q. Rainwater was his last name? 16 A. Rainwater, uh-huh (indicating yes). Let's 17 see. Mr. Hutchinson, Skeet Hutchinson. 18 Q. Skeet? 19 A. Now, he's deceased. They was more, but I 20 can't think of them. I'll think of them 21 probably as we go along. 22 Q. That's all right. As they come to you, just 23 let me know, and I'll put them back up here. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 21 FOSHEE & TURNER COURT REPORTERS 1 A. Okay. 2 Q. Now, did the cells have to be cleaned out 3 from time to time? 4 A. Yes, sir. 5 Q. How did that -- how -- how did that get done? 6 A. Well, we would shut the cell down and, you 7 know, close off the electric charge to it, 8 and close off, you know, everything to it and 9 turn it over to the maintenance department. 10 But I -- you know, I worked the OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036693 11 third shift, and I really wasn't involved in 12 that as far as that was concerned. 13 I mean, I know some nights I'd come 14 in there would be a cell down, you know. 15 Q. Was the maintenance department responsible 16 for cleaning out the cells? 17 A. I don't recall how we did that. I really 18 don't. I'm not sure if I ever even shut one 19 down. I may have, but I know they were shut 20 down, but I can't recall how we did that. 21 Q. Did you ever see how they cleaned them out? 22 Did you ever watch them do it or see part of 23 the procedure or anything? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 22 FOSHEE & TURNER COURT REPORTERS 1 A. No. I saw them working on them, you know, 2 but I never saw how -- I mean -- what they 3 would do is I think they would replace, like, 4 the boot, you know, if it got -- 5 Q. The rubber? 6 A. Rubber. 7 Q. Yeah. 8 A. Stuff like that. OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036694 9 Q. Did they ever replace the mercury? 10 A. Not that I know of. There was a big pump 11 tank we called it that the mercury stayed in. 12 It was pumped out of this tank into the cell. 13 Q. And the mercury circulated? 14 A. Yes, sir. 15 Q. So it would circulate through the bottom of 16 the cell -- 17 A. Yes, sir. 18 Q. -- go back to the pump tank -- 19 A. Yes, sir. 20 Q. -- and then get pumped again? 21 A. Yes, sir. It was a big round tank, and there 22 was a submerged pump that sat right on top < 23 the tank. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 23 FOSHEE & TURNER COURT REPORTERS 1 Q. How big was the tank? Can you describe it? 2 MR. PECK: The mercury tank? 3 Q. (By Mr. Wright) Yeah. 4 A. I'd say it would be five or six foot in 5 diameter. 6 Q. Okay. OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036695 7 A. And maybe couple of feet deep. 8 Q. Was it like a stainless steel tank, or do you 9 remember what it was made out of? 10 A. I'm not sure what it was made out of. 11 Q. Can you describe the building that the cell 12 satin? 13 A. The cell sat -- it was like a two-story 14 building. The cell room was up on the second 15 floor. It was a wooden floor building and 16 had big vents -- vent fans in the end. 17 Q. On either end? 18 A. Uh-huh (indicating yes). And big header 19 pipes going down at the -- that the vent 20 system went through. Big, you know, big 21 header pipes out to the storage tank. 22 Q. Where the chlorine would go? 23 A. (Witness nods head.) 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 24 FOSHEE & TURNER COURT REPORTERS 1 Q. Okay. 2 A. I mean, I remember we had to go upstairs, go 3 into the cell room, and the control room was 4 downstairs, and then, you know, brine area OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036696 5 was out in the yard area where the brine 6 tanks and all that was out in the yard area. 7 Q. Was the whole first floor the control room? 8 A. No, it was just in a room about this size 9 right here. 10 Q. It was the control room? 11 A. Uh-huh (indicating yes). 12 Q. What was the rest of the first floor? 13 A. Had pumps. Had -- as I recall, there was 14 compressors down there, compressor tanks, 15 there was pumps that pumped, you know, the 16 caustic, you know, out to the storage tanks 17 and all. All that was a pump room. 18 Q. I got you. Is that where the mercury vat and 19 pump were? 20 A. No, now they were on the ground level under 21 the cells. They were directly under the 22 cell, under each cell. There was a tank for 23 each cell. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 25 FOSHEE & TURNER COURT REPORTERS 1 Q. Oh, there was a tank for each cell? 2 A. Yeah. OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036697 3 Q. I got you. 4 A. There was a pump and a tank for each cell, 5 and it sat on it ground floor, you know, 6 directly under the cell room. 7 MR. PECK: When you say, "ground 8 floor," you mean first floor? 9 THE WITNESS: Yes, first floor. 10 Q. (By Mr. Wright) So that tank you described 11 and the pump system, there would have been 12 one of those for each cell? 13 A. Yes, sir. 14 Q. Did the caustic contain any mercury after it 15 came out and went into the -- 16 A. I don't know. 17 Q. You don't know? 18 A. I mean, I don't think so, but I mean, I don't 19 know. I can't say. I mean, it was clear. 20 It was water white we called it. That was -- 21 Q. Did they ever sample it for mercury to your 22 knowledge? 23 A. I don't know. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 26 FOSHEE & TURNER COURT REPORTERS OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036698 1 Q. Was the brine continuously circulated? Or 2 after it ran through, what happened to the 3 brine? 4 A. Okay. There was two different kinds of 5 brine. They was what they call a depleted 6 brine and a chlorinated brine, I think is 7 what itwas, ora dechlorinated. One or the 8 other. There was twodifferent kinds of 9 brine. 10 You mix these brines together as 11 they pump. They were all continuously 12 circulated, and you mixed them together as 13 they come back into the cell, as I recall. 14 That's what I recall that we did. 15 Q . Okay. So the only thing that was generated 16 during the continuous process was chlorine 17 gas, which was collected through the vent 18 system -- 19 A.. Yes, sir. 20 Q . -- and caustic, which went out to a tank to 21 be held until it was taken off? 22 A.. Yes, sir. 23 Q . And the brine circulated, and you just had to 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 27 OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036699 FOSHEE & TURNER COURT REPORTERS 1 remix it? 2 A. Yeah. Put so much fresh brine in with it. 3 Q. Okay. Was anything else generated when the 4 process was operating? 5 A. No, sir. 6 Q. Okay. 7 A. Nothing that I can recall. 8 Q. Were there filters in the system anywhere? 9 A. Seemed like -- yeah, I think there was some 10 brine filters. 11 Q. Where were they located? 12 A. They were outside in the brine area. 13 Q. Now, was the brine the same way? Was there 14 separate brine tank for each cell, or was 15 there one big main brine? 16 A. One big main brine. 17 Q. And then pipes going off to each of the 18 cells? 19 A. Yes, but I don't -- I don't recall how they 20 got to each cell. I remember the water -- I 21 remember us adding water because it was a 22 rotor meter type thing, and we added so much 23 water. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] 1-800-888-DEPO 28 FOSHEE & TURNER COURT REPORTERS 1 But I don't recall how the brine 2 got back to the cell. I know it was pumped, 3 but I don't -- 4 Q. Where were the filters? 5 A. They were out in the brine area, out in the 6 yard area. 7 Q. How big were those filters, do you remember? 8 A. They were big tanks. Probably maybe ten or 9 twelve foot high and maybe ten foot around, 10 maybe. 11 Q. Those were the brine tanks, or those were the 12 filters? 13 A. That's the brine filters. 14 Q. Okay. So they were big filters? 15 A. Uh-huh (indicating yes). 16 Q. How often were those changed? 17 A. As I recall, they weren't changed. I don't 18 know what -- I think they may have had 19 charcoal. 20 I'm not sure what they had in them, 21 but all we did was backwash them. And you 22 would backwash them back into the brine. So 23 you didn't change them as I recall. OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036701 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 29 FOSHEE & TURNER COURT REPORTERS 1 I mean, you didn't open them up. 2 They was just tanks, and you backwashed them 3 and backwashed them back into the brine 4 tanks. 5 Q. Just out of curiosity, seems like whatever 6 impurities you were filtering for, if you 7 kept backwashing it back into the tank, 8 they're going to build up in there and you've 9 got to get them out somehow, wouldn't you? 10 A. Yeah. 11 Q. But you don't know? 12 A. I don't recall. I really don't. I mean, I 13 know we backwashed them. 14 Q. All right. 15 A. And I -- oh, yeah. We back washed them -- 16 I'm not sure if they went back to the brine 17 -- to the feed tank or to another tank. 18 They were backwashed into a tank, but I'm not 19 sure -- 20 Q. So they may not have been backwashed back 21 into the main tank? OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036702 22 A. Yes, but I'm not sure. I'm not sure. 23 Q. Who that's still living do you think would be 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 30 FOSHEE & TURNER COURT REPORTERS 1 the best to describe or to know about that 2 process? 3 A. Probably Gene Hill or Melvin Womack. 4 Q. Are both of those fellows still in the area? 5 A. They're both retired. I'm not sure where 6 they are now. I would imagine Melvin is 7 still in the area, but I'm not sure. 8 MR. PECK: Melvin? 9 THE WITNESS: Yeah, Melvin Womack. 10 Q. (By Mr. Wright) By the way, do you still 11 live in this area? 12 A. I live in Piedmont, twenty-five miles from 13 here. 14 Q. Thank you for going through that. I know it 15 was a long time ago. 16 MR. PECK: And I won't tell Melvin 17 and Gene that you finked on them. 18 THE WITNESS: Please don't. 19 Q. (By Mr. Wright) Okay. In the parathion OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036703 20 department, I've talked to some folks, and 21 they pretty well described how that operated, 22 so I'm not going to go through that with you. 23 A. Okay. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 31 FOSHEE & TURNER COURT REPORTERS 1 Q. What I don't know is how the PNP and the P2S5 2 work, so I'm going to -- if you can, help me, 3 walk me through that process. 4 A. Okay. I'll do the P2S5. That's the one I'm 5 least familiar with because I wasn't there 6 very long. I'll do that one first. 7 Q. Okay. 8 A. P2S5 process is you take phosphorus and 9 sulfur and more or less you pump them 10 together, mix them together, in a reactor. 11 And they create their own reaction. And it's 12 just a chemical reaction that changes the 13 phosphorus and sulfur to P2 S 5. 14 Q. Is it a continuous operation or a batch 15 operation? 16 A. It is a continuous operation. 17 Then this product and the reactor OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036704 18 will just overflow out of the reactor then 19 into a cooler that would be cooled down. And 20 then it would be sent through a holoflite, we 21 called it, that actually then beat it up 22 because it would begin to solidify as it 23 cooled down. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 32 FOSHEE & TURNER COURT REPORTERS 1 It would beat it up and turn it 2 back into a powder. And the finished product 3 was a powder. 4 Q. Okay. And that's used in the parathion 5 manufacturing process? 6 A. It was used in the parathion. 7 Q. Did y'all also sell the P2S5? 8 A. Yes, there was some outside sales. 9 Q. Okay. Now, how about the PNP operation? 10 A. The PNP, you take para-nitro-chlorbenze, 11 which is PNCB is what we called it. You take 12 that product, and you takesulfuric acid and 13 caustic soda, and you mix those into a 14 reactor and through a batch operation. 15 And this chemical reaction then OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036705 16 converts into paranitrophenol or PNP. And 17 that's a batch operation. 18 Q. How many reactors did you have? 19 A. Two reactors. 20 Q. How long would it take to create a batch? 21 A. Two hours. 22 Q. Did that go twenty-four hours a day as well? 23 A. Yes, sir. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 33 FOSHEE & TURNER COURT REPORTERS 1 Q. So every two hours, you'd have a new batch? 2 A. Yeah, yeah. The -- it was reacted, and then 3 it was solidified, and then it was washed, 4 and then it was either transferred to 5 parathion or drummed out for outside sales. 6 Q. How was it washed? 7 A. Through a belt filter, a washing. The water 8 sprays over a belt filter. 9 Q. Is this a solid also, the PNP? 10 A. It's a granular like commeal. Kind of the 11 texture of cornmeal. 12 Q. And that's what's washed? 13 A. Yes, sir. OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036706 14 Q. And the water from that operation went where? 15 A. The water was -- 16 Q. The waste water? 17 A. We recycled most of it, and what was not 18 recycled went to the waste treatment 19 department, to the plant's waste treatment 20 department. 21 Q. Did you ever go in the aroclor area? 22 A. I was there as a painter. In 1969 parathion 23 was shut down for three months because of 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 34 FOSHEE & TURNER COURT REPORTERS 1 lack of sales, and all of us operators was 2 transferred into maintenance to do some extra 3 work and all. So I painted over there for 4 three months. 5 Q. Okay. That was about during the expansion. 6 Was your painting related to some of the 7 expansion of that department? 8 MR. PECK: Object to the form of 9 the question. 10 THE WITNESS: No, sir. 11 Q. (By Mr. Wright) I'm sorry. What was your OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036707 12 answer? 13 A. It was existing structure, like structure 14 steel. 15 Q. And you painted for three months? 16 A. Yes, sir. 17 Q. Okay. What part of the aroclor department 18 were you painting? 19 A. Let me back up. I didn't paint for the whole 20 three months in aroclor. I painted for three 21 months throughout theplant. 22 Q. Okay. 23 A. Let me clarify that. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 35 FOSHEE & TURNER COURT REPORTERS 1 Q. I appreciate that because I was going to ask 2 you a question that assumed you were there 3 for three months. 4 A. No, I'm sorry. I wasn't. We painted all 5 over the plant. 6 Q. How long did you paint in the aroclor 7 department? 8 A. Two or three or four weeks maybe. 9 Q. Do you remember what part of the aroclor OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036708 10 department you painted in? 11 A. It was -- it was, like, outside out in the 12 structure up two or three levels up in the 13 structured steel part of it. 14 Q. Was the aroclor department running while you 15 were painting? 16 A. Yes, sir. 17 Q. Was that the only time you were ever really 18 in the aroclor department? 19 A. As part of my relief foreman duties back up 20 there when I worked in the storeroom, I was a 21 spare parts specialist, and I was also 22 vacation relief for the maintenance foreman, 23 and I may have worked one week over there as 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 36 FOSHEE & TURNER COURT REPORTERS 1 a relief maintenance foreman while he was on 2 vacation one time. 3 Q. Now, that was in '72? 4 A. That was around '73 probably because -- it 5 would have been about'73. I mean --and 6 here again -- okay. I worked south plant 7 job, and now, I don't know if it was '72 or OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036709 8 73. 9 I don't remember exactly when it 10 was, but I was the spare parts specialist in 11 the storeroom, and I was relief foreman, you 12 know, for vacation relief for the maintenance 13 foreman. And the south plant consisted of 14 the aroclor and some other areas too. 15 Sol don't -- I mean, I may have 16 been, and I don't even recall if it was shut 17 down at the time. I don't remember. 18 Q. My understanding is it shut down in May of 19 72? 20 A. Okay. Well, it was probably along about in 21 that time. I'm not sure. 22 Q. So you don't remember whether the aroclor 23 plant was running when you were over there? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 37 FOSHEE & TURNER COURT REPORTERS 1 A. The week that I worked as maintenance 2 foreman, no, I do not remember if it was or 3 not. I do not. So -- 4 Q. How did you hear the aroclor department was 5 going to shut down? OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036710 6 A. I don't know. I mean, either word of mouth 7 probably because I wasn't -- okay. I wasn't 8 over there at the time. 9 I was in the other part of the 10 plant, and you know about the kind of two 11 different areas of the plant, you know. And 12 I wasn't -- I wasn't involved in that. 13 Q. Yeah. I know that there are going to be 14 people that would be better able to answer 15 that question than you, but since your the 16 witness right now-- 17 A. Yeah, right. 18 Q. -- I'm just asking you for your best 19 recollection. And again, I know it's been a 20 long time ago. 21 Even though you don't remember how 22 you heard, what did you hear? 23 A. I don't know if it was because of lack of 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 38 FOSHEE & TURNER COURT REPORTERS 1 sales or what because we were all kind of 2 concerned between 1969 and 1972 right along 3 in there about our jobs because parathion OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036711 4 almost shut down. 5 Well, they did shut down in '69. 6 So, as I recall, it was from lack of sales or 7 from, you know, that business, you know, that 8 aspect of it. 9 Q. Do you have a memory, or are you just kind of 10 speculating that that's what it was? 11 A. I just speculate. I really don't know. I'm 12 sure it was in Anniston Star, and I'm sure it 13 was here and there, but I do not recall how I 14 heard specifically. No, I do not. 15 Q. When did you first hear about PCB 16 contamination off the plant property? 17 A. I can't recall. Maybe late'80s, early'90s 18 or something. I don't know. I cannot 19 recall. 20 Q. You don't remember hearing anything about PCB 21 contamination off the plant property in the 22 '70s? 23 A. No, sir. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 39 FOSHEE & TURNER COURT REPORTERS 1 Q. Or in the early '80s? OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036712 2 A. No, sir, not that I recall. 3 Q. Or even mid '80s? 4 A. No, sir, no, sir. 5 Q. Again, I'm going to ask you -- I asked you 6 when you heard about it. Now I'm going to 7 ask you how you heard about it to the best of 8 your recollection. 9 A. How I heard about the PCB -- 10 Q. -- contamination off plant property. 11 A. There again, I don't know. I mean, I don't 12 -- I don't recall any formal meetings or 13 anything like that. 14 It was in the paper, I'm sure. 15 That was probably the first thing I heard or 16 first -- it was in the paper. 17 Q. So you're pretty sure that the first you 18 heard about PCB contamination off Monsanto 19 property was just through the paper? 20 A. I feel that would be a true statement. 21 Q. Okay. And so if I ask you the question of 22 what you heard about it, it's going to be 23 whatever was in the paper? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 40 FOSHEE & TURNER COURT REPORTERS OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036713 1 A. Yeah. That's true. 2 Q. Okay. Well, I won't ask you to try to 3 remember that then. 4 A. Okay. 5 Q. Were you ever involved -- I think I know the 6 answer to these question, but I'm going to 7 ask you a series of questions. 8 A. Okay. 9 Q. Were you ever involved in the landfill 10 operation? 11 A. No, sir. 12 Q. Did you ever go to the landfill? 13 A. I probably went up there two or three times 14 in thirty-two years I worked there. 15 Q. Do you remember why you went there when you 16 went there? 17 A. Probably just to go see. But I never had any 18 responsibility in that area. 19 Q. When you went up there, what did you see? 20 Again, I just want you to describe it because 21 you were there and we weren't, so to the best 22 of your recollection -- 23 A. I remember one time that there was like a 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 41 OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036714 FOSHEE & TURNER COURT REPORTERS 1 pit, like a big pit, and they were -- had a 2 truck or wagon or whatever it was they hauled 3 up there, and they were dumping over in that 4 pit. 5 Q. So you remember seeing them dump it in there 6 one time? 7 A. Uh-huh (indicating yes). 8 MR. PECK: What was the time frame 9 of that recollection? Sorry. 10 MR. WRIGHT: Good question. 11 THE WITNESS: I'd say in the '60s. 12 Q. (By Mr. Wright) Do you remember what they 13 dumped? 14 A. Well, at that time, it was plant trash. I 15 mean, it was everything from trees to, I 16 think even our garbage, even our -- maybe 17 lunchroom garbage, you know what I'm saying. 18 Q. So just everything? 19 A. Yes, sir. 20 Q. Okay. Was there an incinerator there? 21 A. Yes, sir. 22 Q. Okay. Was this being dumped -- 23 A. I'm sorry. No, there was not one at the OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036715 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 42 FOSHEE & TURNER COURT REPORTERS 1 landfill. There was one in the plant. 2 Q. That's what I'm asking. 3 A. No, there's not an incinerator at the 4 landfill. 5 Q. Okay. My understanding is there was one that 6 looked like a TP, kind of a big cone? 7 A. At the landfill? 8 Q. Yeah. 9 A. I don't remember. 10 Q. You don't remember seeing that? 11 A. No, sir, no, sir. 12 Q. Okay. We talked about one time that you went 13 to the landfill. Do you have a memory about 14 going there any other times and what you saw? 15 A. Not really. I really don't recall. I mean, 16 I do know that the waste was dumped into a 17 pit, and then later on they divided -- they 18 had areas or sections or areas. 19 And I remember they used to have to 20 fill out like a form, like Section E or 21 Section -- whatever the sections was, but I 22 couldn't -- I could not tell you where the OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036716 23 sections are or nothing. I'm sorry. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 43 FOSHEE & TURNER COURT REPORTERS 1 Q. When did y'all start filling out the forms, 2 do you remember? 3 A. No, sir, I couldn't tell you. 4 Q. Was it in the '80s? 5 A. Possibly, yes, sir. 6 Q. Who was in charge of the landfill department 7 in the '60s? 8 A. Mr. Taffee. Red Taffee was his name as I 9 remember. 10 Q. They told me last week, but I can't remember. 11 Is he still alive? 12 A. He's been real sick. I think he had some 13 strokes or something, and I thought he passed 14 away. I'm not sure. I haven't heard from 15 him in a long time. 16 MR. WRIGHT: Is he still alive? 17 MR. PECK: I thought he was just 18 very sick. I had not heard he passed away. 19 THE WITNESS: I saw him in a 20 wheelchair about eight years ago, six or OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036717 21 eight years ago. 22 MR. PECK: When this litigation 23 first started a couple months -- I think it 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 44 FOSHEE & TURNER COURT REPORTERS 1 was '94 -- he had a very serious stroke and 2 became virtually unavailable, so nobody ever 3 got to depose him. 4 MR. WRIGHT: I was going to ask if 5 he got deposed. 6 MR. PECK: Nobody got to depose him 7 before he became really unavailable to us. 8 Q. (By Mr. Wright) Who would be the second most 9 knowledgeable person about the landfill in 10 the'60s and early'70s? 11 A. It would be Jerry Brown, I suppose. 12 Q. Was he here then? 13 A. Yes, sir. I don't think he was -- I'm not 14 sure if he was involved with the landfill at 15 that time, but he would be probably the plant 16 -- most knowledgeable because he was over 17 that kind of whole area like. He's a 18 superintendent. OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036718 19 Q. Who else might know a fair amount about the 20 landfill in the '60s and 70s besides Jerry 21 Brown and Mr. Taffee? 22 A. I really couldn't say. I'd just have to be 23 pulling people's names out of the hat. I 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 45 FOSHEE & TURNER COURT REPORTERS 1 mean, I really couldn't say. 2 Q. I know that wasn't your area. 3 A. No. 4 Q. I just -- again, you're here and nobody else 5 is right now, so I'm just asking. 6 A. Right. 7 Q. Where did you live -- well, what area of town 8 did you live in when you worked at the plant? 9 A. Okay. I lived out in the Eulaton area about 10 two miles from the plant. 11 Q. Two miles which way? 12 A. West. 13 Q. On towards Jackson -- 14 A. No, out 202 West. Out this way. 15 MR. PECK: Wellborn? 16 THE WITNESS: Wellborn, and I lived OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036719 17 about a block anda half from Wellborn 18 School. 19 Q. Can you describe the area around the plant? 20 Let's start when you first started working 21 over there. 22 A. Talking about how -- I mean like -- 23 Q. Well, that's an awful broad question. I 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 46 FOSHEE & TURNER COURT REPORTERS 1 understand that. Did you ever go into the 2 area around the plant other than just to 3 drive down the road and into the plant gate? 4 Do you ever remember spending any 5 time out in the neighborhood, for example? 6 A. Used to eat up at The Dairy Maid right up, 7 you know, used to go up there and eat a lot, 8 like if we worked overtime or something or 9 whatever. 10 Really wasn't involved with any of 11 the houses northwest, in that northwest area 12 back in there. I really wasn't back in there 13 at all. 14 Q. Okay. OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036720 15 A. The area -- let's see. 16 Q. Where was The Dairy Maid located? 17 A. It's on 202. On the old 202 before they 18 built a four-lane. It was right there. 19 Q. What's now Clydesdale? 20 A. No, no. It's -- as you go past the plant 21 going west, it would be like a quarter of a 22 mile up there on the left. 23 Q. Okay. Okay. That's the other direction. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 47 FOSHEE & TURNER COURT REPORTERS 1 A. Yeah. And then before the four-lane was 2 built, I used to either go down Clydesdale to 3 go home or old 202. 4 There was two ways to go. So there 5 was a drugstore out there that we used to 6 use, that drugstore out on Clydesdale. And I 7 forget the name of the grocery store that was 8 there. 9 Q. Do you ever remember seeing the people in the 10 neighborhood as you drove by? 11 A. Oh, yeah. 12 Q. Just what memories, if any, do you have about OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036721 13 them? Anything you saw them do or anything 14 sticks out in your mind? 15 A. Well, if you're asking me a judgement of 16 people, they were a very poor people that 17 lived out around in there, very -- but they 18 were very friendly. That neighborhood had 19 been there a long time. 20 They were some of the people that I 21 knew. In fact, a couple guys worked at the 22 plant that lived out in there, and I'm trying 23 to think of the guy's name now, but I can't 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 48 FOSHEE & TURNER COURT REPORTERS 1 recall his name. It was an older guy, and he 2 lived right back out there at the back of the 3 plant. 4 Q. Black guy? 5 A. No, this was a white guy. I can't even 6 recall his name now. But they were just 7 generally a, you know, very poor people,very 8 poor housing. 9 Q. Do you remember gardens and chickens and 10 things like that? OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036722 11 A. No, sir, not really. I mean, there was 12 gardens out around our house, but if you're 13 talking about right specifically at the 14 plant, I don't. 15 But there were gardens out around 16 where I lived. In fact, I had one. I lived 17 -- first few years -- I lived in a trailer 18 out on Eulaton Pike. Me and my mother-in-law 19 had a garden. 20 Q. That's the same area where you lived? 21 A. Yes, sir, it was close. This was just past 22 Wellborn School on Eulaton Pike, and then I 23 bought a house over there next to Wellborn 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 49 FOSHEE & TURNER COURT REPORTERS 1 School. 2 MR. WRIGHT: Adam, you don't have 3 that picture book, do you? 4 MR. PECK: Huh-uh (indicating no). 5 Q. (By Mr. Wright) Why don't we take a quick 6 break? We've been going a while. 7 (Short recess.) 8 Q. (By Mr. Wright) We're almost through. I OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036723 9 just have a little cleanup stuff, and I'll 10 get you on the road to the mountains. 11 A. Okay. 12 Q. There's an industrial hygiene department now 13 out there at the plant. 14 A. Uh-huh (indicating yes). 15 Q. When do you first remember hearing about an 16 industrial hygiene department at the plant? 17 A. Well, really even back in the'60s is as 18 early as I can remember. I don't know if 19 that's what they called it, but it was. 20 Q. What do you remember about it? 21 A. Well, you know, here again, I don't want to 22 call names, but Mr. Ransaw, Ishmael Ransaw 23 kind of headed things up. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 50 FOSHEE & TURNER COURT REPORTERS 1 He was there maybe in the late 2 '60s, maybe early '70s. I'm not sure 3 exactly when, but he was involved in that and 4 monitoring, and he was like the head of that. 5 Q. Is he still out there? 6 A. No, I think he works at the Monsanto plant in OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036724 7 New Orleans now. 8 MR. PECK: He's -- actually I think 9 now he's just retired, but he has been 10 deposed. 11 MR. WRIGHT: I think we've got his. 12 Has he just been deposed once? 13 MR. PECK: I think he's been 14 deposed twice. I think he was deposed in 15 Dyer and the other case. 16 MR. WRIGHT: Okay. 17 Q. As best you recall, he showed up in the late 18 '60s or early'70s? 19 A. Yeah, as my memory -- best I can recall, 20 yeah. 21 Q. And he was in charge to the best of your 22 recollection of the health -- 23 A. -- environmental. Seemed like it was 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 51 FOSHEE & TURNER COURT REPORTERS 1 Environmental and Health or something maybe. 2 I'm not sure what the name of it was. I 3 don't even know if they really give it a name 4 back then. OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036725 5 But, yeah, he did a lot of 6 monitoring and a lot of -- 7 Q. Now, before him, do you have any recollection 8 of any kind of a program? 9 A. No, not really. I'd just have to be 10 speculating, and I really don't have any -- 11 Q. Some of the other fellows last week told me 12 they had a yearly physical? 13 A. Yeah. 14 Q. And Dr. Francis did it? 15 A. Yes. 16 Q. Did you have those as well? 17 A. Yes, sir. 18 Q. Is it your understanding everybody in the 19 plant had to have a yearly physical? 20 A. Yes, sir, yes, sir. 21 Q. Where did you go to get the physical? 22 A. At the plant. He had an office at the plant. 23 In fact, he came about every morning as I 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 52 FOSHEE & TURNER COURT REPORTERS 1 recall there for a long time. 2 Q. Did he have another office here in town? OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036726 3 A. Yes, sir. 4 Q. But he spent a lot of time out there at the 5 plant? 6 A. Yes, sir. 7 Q. Did he have records out there, I mean, files 8 and things there at the plant? 9 A. I don't know. I mean, I've never seen them. 10 I don't know. 11 Q. When you would go for the physical, did he 12 have a folder? 13 A. Yes, sir. 14 Q. Did it have all of your old physicals in the 15 folder? 16 A. I suppose. 17 Q. Best you know? 18 A. I never saw them. I just saw a folder with 19 some papers in it, so I guess. 20 Q. Did you get the impression that that -- like 21 now days when I go to the doctor's office, 22 he's got a folder, and it's got all of my 23 stuff from ten years ago. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 53 FOSHEE & TURNER COURT REPORTERS OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036727 1 A. Yes, sir. 2 Q. And on up through -- is that the kind of 3 thing you remember him having -- 4 A. Yes, sir. 5 Q. -- even though you didn't leaf through it? 6 Was that your impression of what he was -- 7 A. Yes, sir. 8 Q. Okay. But you don't know whether that was 9 maintained there at the plant or -- 10 A. No, I do not. 11 Q. -- somewhere else? 12 A. No, I do not know that. 13 Q. What do you remember Dr. Francis doing on the 14 physicals? 15 A. He would check our vital signs, talk to us, 16 question us, gave all the men a prostate 17 examination. 18 Q. Dicky Walker mentioned that was a prominent 19 annual feature. 20 A. Yeah. And they had a nurse also, and she 21 would take blood samples too. 22 Q. Okay. You remember them taking a blood 23 sample? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 54 OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036728 FOSHEE & TURNER COURT REPORTERS 1 A. Yes, sir. 2 Q. Every year? 3 A. Yes, sir. 4 Q. Do you know what they tested the blood for? 5 A. No, not -- no, I don't. 6 Q. Did you ever get results back from the blood 7 testing? 8 A. Yes, yes. 9 Q. What did they tell you about the blood 10 testing to the best of your recollection? 11 A. They showed us and -- but, I mean, it was -- 12 my mind, it would be the same as any doctor 13 you would go to and get the results back and 14 show you what they were. 15 You know, all the, you know, later 16 on in years, it was your cholesterol. They 17 used to stay on us about that, but that 18 was -- 19 Q. But you remember them taking blood at every 20 physical from the mid '60s on? 21 A. Yes, sir. 22 Q. Did they ever test for PCBs to your 23 knowledge? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036729 1-800-888-DEPO 55 FOSHEE & TURNER COURT REPORTERS 1 A. I do not know. 2 Q. They never told you your PCB results if they 3 did? 4 A. No, sir. 5 Q. When you were at the aroclor department, do 6 you have a recollection about watching them 7 or anything that happened over there? 8 A. I don't have any recollection of anything 9 happening, you know. We didn't really go in 10 the control room. We were out in the 11 structure. 12 We had our own shop, and we just 13 came in the area, you know, and let them know 14 we was there and worked outside. We didn't 15 take breaks in the control room. You know, I 16 mean, I - 17 Q. Was that in the chiorinator area where the 18 big tanks were? 19 A. It was out in the structure. I don't know 20 where the chlorinator area was. I know it 21 was out in the, like, about a three or four 22 level structure of pipe and tanks outside of 23 the building, like out in the weather, like OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036730 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 56 FOSHEE & TURNER COURT REPORTERS 1 outside. 2 Q. Okay. Okay. You don't remember -- well, let 3 me just ask: Do you have a picture in your 4 mind about being there and what you saw and 5 so forth? 6 I guess I'm just asking you to 7 describe as best you can what you remember. 8 I know you were there a very short time a 9 long time ago. 10 A. Yeah. I remember it was hard work, and I 11 wasn't used to it because I'd been an 12 operator. Wedid some sandblasting. We had 13 to wear hoods, you know, with air systems on. 14 We didn't talk to nobody much. We 15 worked, you know, and I really didn't -- I 16 mean, I really couldn't -- I couldn't 17 describe it to you. I really couldn't. 18 Q. Okay. 19 A. I know it was two or three levels up. We 20 were sandblasting -- sandblast one day and 21 paint the next, you know, and that's what we OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036731 22 did. 23 Q. Okay. That's fine. I didn't expect you to, 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 57 FOSHEE & TURNER COURT REPORTERS 1 but since I'm running out of questions, I 2 thought I'd ask it. 3 A. Okay. 4 Q. One other thing I would like to ask you about 5 because you were in the maintenance 6 department. Dicky Walker mentioned -- he 7 described the aroclor process like you 8 described the mercury process. 9 A. Uh-huh (indicating yes). 10 Q. And one of the things he mentioned is that 11 they had pumps that would circulate the 12 materials to make the aroclor. 13 A. Uh-huh (indicating yes). 14 Q. And that those pumps would leak and that the 15 maintenance people from time to time would 16 come and repack them. Did you have any 17 involvement in that? 18 A. No, sir. 19 Q. By the time you went to the maintenance OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036732 20 department, the aroclor operation was winding 21 down. Do you know who at the maintenance 22 department might have had significant 23 involvement in that operation? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 58 FOSHEE & TURNER COURT REPORTERS 1 A. A Mr. Sprayberry, and I think he's deceased. 2 He was one of the mechanics that worked there 3 a good bit. Let me think of this other guy's 4 -- oh, yeah, Don Curry. 5 Q. Okay. 6 A. Don Curry would have been one involved in 7 that. I think he was the maintenance foreman 8 that I relieved. 9 MR. PECK: Is he on your list, Don 10 Curry? 11 MR. WRIGHT: We have a deposition 12 on him. 13 MR. PECK: Okay. 14 Q. (By Mr. Wright) Anybody else you can think 15 of? 16 A. I'm trying -- okay. Otto Hill. 17 Q. Otto Hill? OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036733 18 A. Yes, sir, he was a mechanic over there. 19 Q. Is he still alive? 20 A. I don't know. I haven't seen him in years. 21 He's been retired for years and years. 22 Q. Anybody else you can think of? 23 A. I mentioned Mr. Sprayberry. Ray Kimbril. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 59 FOSHEE & TURNER COURT REPORTERS 1 Q. Ray Kimbril? 2 A. Yeah, he was a mechanic over there in the 3 south shop. This is people that would have 4 worked in the aroclor area as mechanics. 5 Q. Right. Is he still alive, Ray Kimbril? 6 A. I don't know. 7 Q. Did y'all have in the maintenance 8 department -- and I guess I'm focussing on 9 the south shop because y'all had a south 10 maintenance department and a north 11 maintenance department? 12 A. Yes, sir. 13 Q. Focussing on the south shop, did y'all have a 14 Dipster Dumpster or somekind of trash 15 collecting area? OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036734 16 A. There was a dumpster up there. Now, I'm 17 speaking of later on in the years because 18 even after aroclor shut down, there was a 19 south shop. But now in the aroclor days, I 20 couldn't tell you. I don't know. 21 But I know later on in years, yeah, 22 there was a dumpster up there because we used 23 to have a safety and housekeeping inspection, 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 60 FOSHEE & TURNER COURT REPORTERS 1 you know, came, you know, and I was on that a 2 couple of different times. 3 Q. Okay. That's what I've got here. I've got 4 the safety audits for various years. 5 A. Uh-huh (indicating yes). 6 Q. I'm not going to go through it other than to 7 just talk in general. What did y'all do in 8 your maintenance and housekeeping audits? 9 A. Okay. Now, what I'm talking about is the 10 monthly safety and housekeeping inspection. 11 Is that what the question -- 12 Q. I think I'm talking about an annual deal, but 13 go ahead and tell me about the monthly. OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036735 14 A. Well, we had a team in the plant that would 15 take one day a month and go around the plant 16 and more or less inspect the plant for 17 cleanliness, safety problems, potential 18 safety problems, so forth. 19 And we would write up 20 recommendations, then we would give them a 21 score as to a rating as to how well they did. 22 Q. When did that start? 23 A. Oh, that's been going on for years and years. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 61 FOSHEE & TURNER COURT REPORTERS 1 I mean, I couldn't -- 2 Q. In the'60s? 3 A. Possibly. I mean, in earlier years, seemed 4 like it was done by supervision, but then 5 later on, plant peoplebegan to do it. We 6 began to involve everybody in theplant in 7 it. 8 Q. Were there always written documents 9 prepared -- 10 A. Yes, sir. 11 Q. -- as a result of those? OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036736 12 A. Yes. 13 Q. When's the first time you remember doing it, 14 what year or decade? 15 A. Gosh, I don't know. Probably in the'70s. I 16 may have been involved in the '70s in it. 17 Q. Okay. 18 A. But I'm not sure of that. 19 Q. I've got a biennial, which I think means 20 twice a year, safety audit. Do you remember 21 did it start out being once every long period 22 of time and then go to monthly? Do you 23 remember? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 62 FOSHEE & TURNER COURT REPORTERS 1 A. Okay. What was the question again now? 2 Q. Well, just the document we're looking at 3 which is numbered DSW099952 is dated December 4 16th, 1975, and it's entitled parathion 5 department Biennial -- that's B-i-e-n-n-i-a-1 6 -- Safety Audit. 7 MR. PECK: That's a number we put 8 on it, so it's not going to be anything to 9 you. That's just a control number. OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036737 10 Q. (By Mr. Wright) That's just so we can dig 11 this document up when we want to look back at 12 it. 13 A. Okay. 14 Q. And this indicates your name's down here 15 under the production on the audit committee. 16 A. Okay. 17 Q. And since this says, "biennial," that means 18 once every two years, I think that's what 19 it's intended to mean. 20 A. Right. 21 Q. So I was just wondering if maybe it started 22 out once -- 23 MR. WRIGHT: What did I say, once 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 63 FOSHEE & TURNER COURT REPORTERS 1 every two years? 2 MR. PECK: Yeah, biennial. 3 Q. (By Mr. Wright) Did it start out being a 4 once every two year kind of deal, or was 5 there a special one every two years? I guess 6 I'm just wonderinghow the inspection process 7 worked. OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036738 8 A. This and the safety and housekeeping is two 9 different things all together. 10 The safety and housekeeping 11 inspection is just, you know, grass needs 12 cutting, you need to pick up the trash around 13 in the pump tank area and bla, bla, bla. 14 That's what a safety and housekeeping 15 inspection was. 16 Q. Okay. 17 A. Now, this was just like more or less a 18 property loss estimate. This was a -- like 19 what if something happens, how much will it 20 cost, what damage will it do. 21 Q. Okay. 22 A. That's one of those kinds of things. 23 Q. Let's do this then: Rather than me wading 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 64 FOSHEE & TURNER COURT REPORTERS 1 through this, would you just describe for me 2 the various kinds of inspections that there 3 were at the plant that were written down and 4 documented? This is one we've talked about. 5 A. Yeah. OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036739 6 Q. This was done every two years? 7 A. Uh-huh (indicating yes). 8 Q. You also talked about the monthly safety and 9 housekeeping audit that would have been 10 memorialized in writing. 11 About that one, let me ask you real 12 quick, was that a department by department 13 thing? 14 A. Yes, sir. 15 Q. So there would have been a separate report 16 for the parathion department, for example, 17 and -- 18 A. On the biennial? 19 Q. No, on the monthly. 20 A. No, that was a plant wide monthly safety 21 inspection. 22 Q. So there would have been one report -- 23 A. Yes, sir, for the whole plant. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 65 FOSHEE & TURNER COURT REPORTERS 1 Q. -- for the whole plant? 2 A. Yes, sir. 3 Q. And it would have been prepared on a monthly OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036740 4 basis? 5 A. Yes, sir. 6 Q. And you don't remember when that started? 7 A. No, sir, I do not. 8 Q. What other safety and housekeeping type 9 inspections did you remember? 10 A. Okay. We had -- Monsanto had a corporate 11 type inspection that we went to other plants 12 and inspected other plants. In fact, I was 13 on that team a couple of different times. 14 We had people from other plants 15 come and inspect our plant. Seems like that 16 was an annual affair. 17 Q. Okay. 18 A. Seems like that was done annually. 19 Q. Any others? The reason I'm not going to ask 20 you any questions about that is because I've 21 seen those documents. 22 A. Yeah. 23 Q. Any others you can remember? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 66 FOSHEE & TURNER COURT REPORTERS 1 A. Well, now, there was monitoring. There was OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036741 2 environmental monitoring, but this was a 3 continuous type thing, you know, that Ishmael 4 and his group did. 5 Q. By that, are you talking about the little 6 tags that you wear? 7 A. Yes, sir. 8 Q. That does remind me, do you ever remember any 9 air monitoring? 10 A. Yes. 11 Q. What air monitoring do you remember? 12 A. They would bring these little things around, 13 these little instruments, and place them out 14 in the area, you know. Guys would wear them, 15 you know. They did that. 16 Q. When did they start doing that? 17 A. That was probably in the '80s. 18 Q. Do you remember any air monitoring before the 19 '80s? 20 A. Yes, yes, there was monitoring in the'70s. 21 In fact, we had trailers that were setting -- 22 little old camper trailers -- that were 23 setting outside the plant in two or three 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 67 FOSHEE & TURNER COURT REPORTERS OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036742 1 different areas that I remember seeing. 2 I wasn't involved in the 3 monitoring. I saw them and knew what they 4 were. 5 Q. Do you know what they were monitoring for? 6 A. No, sir, not specifically any one thing or 7 just -- 8 Q. Is that the only monitoring you remember 9 other than what we've already talked about? 10 MR. PECK: Air monitoring? 11 Q. (By Mr. Wright) Air monitoring. 12 A. Air monitoring. Yes, sir, as far as I can 13 recall. 14 Q. Can you pin down when you saw those trailers, 15 maybe to a year or just as close as you can 16 get it? 17 A. I'd say in the mid'70s. Maybe'74 to'77. 18 I mean, that's-- and I'm guessing here. 19 Q. I know. Just your best estimate is all we 20 can do. 21 A. Yes, sir. 22 Q. Now, do you remember who was involved with 23 that? 2001PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 68 OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036743 FOSHEE & TURNER COURT REPORTERS 1 A. Jerry Brown and Gene Arnett were involved in 2 that. 3 Q. We've talked about the PCB off-site 4 contamination. Did you ever hear about any 5 other off-site contamination other than PCBs? 6 A. Well, the only thing I can recall was that 7 the S02 emissions from the incinerator stack, 8 and that would be more of an odor complaint, 9 I guess, than anything. 10 A Miss Hilly used to call us all 11 the time and complain. 12 Q. Okay. Besides sulfur dioxide, what else? 13 A. That's really all. All that I'm aware of. 14 Q. Okay. Mr. Sanford, thank you very much for 15 your time. I hope you have a pleasant trip. 16 A. Thank you. 17 18 (Deposition concluded at 11:30 a.m.) 19 FURTHER THE DEPONENT SAITH NOT. 20 21 22 23 OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036744 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 69 FOSHEE & TURNER COURT REPORTERS 1 CERTIFICATE 2 3 STATE OF ALABAMA ) 4 CALHOUN COUNTY ) 5 6 I HEREBY CERTIFY that the above and 7 foregoing transcript was taken down by me in 8 stenotype, and the questions and answers thereto 9 were transcribed by means of computer-aided 10 transcription, and that the foregoing represents 11 a true and correct transcript of the testimony 12 given by said witness. 13 I FURTHER CERTIFY that I am neither 14 of counsel, nor of any relation to the parties to 15 the action, nor am I anywise interested in the 16 result of said cause. 17 18 19 20 21 TAMMY R. JENNINGS GREGORY Notary Public, State of Alabama 22 MY COMMISSION EXPIRES: 9-12-2001 OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036745 23 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO OWENS 05-15-1988 Sanford, Jerry,txt[8/22/2017 4:07:39 PM] HARTOLDMON0036746