Document 1qOvNmMVRYJkKJX8dgb7OdyX

SAMANTHA E.NOBLE NOBLE & ASSOCIATES IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA EASTERN DIVISION WALTER OWENS, etal., ) ) Plaintiffs, ) ) VS. )CASE NO. CV-96-P-0440-E ) MONSANTO COMPANY, ) ) Defendant.) ___________ CONTINUED_DEPOSITION_OF_JERRY_BROWN, Taken pursuant to stipulation and agreement before SAMANTHA E. NOBLE, a Court Reporter and Commissioner for Alabama at Large, at Fite & Miller, 1000 Quintard Avenue, Suite 400, Anniston, Alabama, on the 1st day of March, 2001, commencing at approximately 10:40 a.m. APPEARANCES _____ HONORABLE LARRY WRIGHT, Attorney at Law, 111 Congress Avenue, Suite 1010, Austin, TX, 78701, appearing for and on behalf of The Plaintiffs. Page 1 1 REPORTER'S INDEX 2 3 CAPTION SHEET........................ 1-2 4 REPORTER'S INDEX...................... 3-4 5 STIPULATION PAGE ...................... 5-6 6 CONTINUED TESTIMONY OF JERRY BROWN 7 Examination by Mr. Wright. . .8-119 8 CERTIFICATE....................... 120-121 9 EXHIBITS_ 10 Plaintiffs Exhibit Number 11 ... . 7 11 Plaintiffs Exhibit Number 12 ... . 7 12 Plaintiffs Exhibit Number 13 ... . 7 13 Plaintiffs Exhibit Number 14 ... . 42 14 Plaintiffs Exhibit Number 15 ... . 49 15 Plaintiffs Exhibit Number 16 ... . 49 16 Plaintiffs Exhibit Number 17 ... . 53 17 Plaintiffs Exhibit Number 18 ... . 55 18 Plaintiffs Exhibit Number 19 ... . 19 19 Plaintiffs Exhibit Number 20 ... . 95 20 Plaintiffs Exhibit Number 21 .... 96 21 Plaintiffs Exhibit Number 22 ... . 102 22 Plaintiffs Exhibit Number 23 ... . 105 23 Plaintiffs Exhibit Number 24 ... . 107 Page 3 Page 2 1 Plaintiffs Exhibit Number 25 ... . 110 2 Plaintiffs Exhibit Number 26 ... . 112 3 Plaintiffs Exhibit Number 27 ... . 115 SAMANTHA E.NOBLE NOBLE & ASSOCIATES 4 5 6 HONORABLE WILLIAM S. COX, III, of The Law Firm of 7 8 9 10 LIGHTFOOT, FRANKLIN & WHITE, Attorneys at Law, The 11 12 13 14 Clark Building, 400 20th Street North, Birmingham, 15 16 17 18 Alabama, 35203-3200, appearing for and on behalf of 19 20 21 22 The Defendant. 23 Page 4 Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Pages 1 - 4 HARTOLDMON0034981 1 STIPULATION 2 3 IT IS STIPULATED between the 4 parties hereto that this deposition is being taken 5 for the purpose of discovery or for use as evidence 6 in the action or for both purposes. 7 IT IS FURTHER STIPULATED between 8 the parties this deposition may be taken before 9 SAMANTHA E. NOBLE, a Court Reporter of Anniston, 10 Alabama, at this time and place without the formal 11 requirement of notice. 12 IT IS FURTHER STIPULATED that 13 neither party need make any objections to any of 14 the questions asked during the taking of the 15 deposition, nor make any motion to exclude any 16 answers, except as to form and leading questions; 17 but both parties may later object to any questions 18 or make a motion to exclude any answers during the 19 trial of the action, and said failure to so object 20 or move to exclude during the taking of this 21 deposition shall not result in a waiver of the 22 right to make objections or move to exclude. 23 IT IS FURTHER STIPULATED between Page 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Page 7 the notice in front of me -- Jerry will testify or can testify about the reasons that he is aware of for the cessation of the production of PCBs in Anniston. MR. WRIGHT: Right. 1 think we've already talked about that. MR. COX: He's the person who is designated for purposes of discussing the investigation of Snow Creek, by the Attorney General in 1985. It was incorrectly designated in the notice as 1990. And 1 think the remainder had to do with Jerry's role as sort of the chief environmental person from approximately 1974 or so through the end of the 1980s timeframe, and whatever other categories that would involve, that information, he would be the person knowledgeable about that. MR. WRIGHT: Okay. Thank you. Let's start. (WHEREUPON, discussion was held off the record.) (WHEREUPON, Plaintiffs Exhibits 11, 12 & 13 were marked for identification.) Page 6 Page 8 1 the parties that all requirements as to 1 JERRY BROWN, 2 examination, reading, signing, or notice of filing 2 having been first duly sworn by the court 3 the deposition are waived. 3 reporter, was examined and testified under oath as 4 4 follows: 5 MR. COX: This is a continuation of 5 EXAMINATION 6 Jerry Brown's deposition. At the first session of 6 BY MR. WRIGHT: 7 his deposition, we also made a designation of Jerry 7 Q Okay, Mr. Brown, thank you for coming 8 pursuant to the Plaintiffs 30(b)(6) notice. And 8 back. Let me hand you what we've marked as Exhibit 9 we would just say that that designation still 9 Number 13. And you may recall you mentioned the 10 holds. 10 last time we were together that you thought that 11 MR. WRIGHT: Yeah, remind me what 11 DSN001 had been tested for PCBs and dioxins in, 1 12 categories you designated him in. 12 think you said, 1981 and 1984. 13 MR. COX: 1 was afraid you were 13 A Somewhere in that time frame. 14 going to do that to me. 14 Q And Mr. Cox was kind enough to dig up 15 MR. WRIGHT: 1 was just going to 15 what we've marked as Exhibit Number 13. What is 16 make sure. 16 Exhibit Number 13? 17 MR. COX: 1 don't have a copy of 17 A This is a priority pollutant scan. 18 the notice. Basically -- 18 THE COURT REPORTER: I'm sorry, a 19 MR. WRIGHT: Just to the best of 19 priority - 20 your recollection. 20 THE WITNESS: Priority pollutant 21 MR. COX: Basically, Jerry can 21 scan. 22 testify regarding -- subject to being corrected, 22 BY MR. WRIGHT: 23 subject to what 1 said last time around, when 1 had 23 Q What is a priority pollutant scan? Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Pages 5 - 8 HARTOLDMON0034982 Page 9 1 A 1 think we talked about that last time. 1 2 Where priority pollutants were in the Clean Water 2 3 Act, a listing of specific potential contaminants 3 4 were listed in the Clean Water Act as priority 4 5 pollutants and were incorporated into standard EPA 5 6 test methods fortesting of waters for the presence 6 7 or absence thereof and incorporating prior to 7 8 pollutant scan and PCBs and the -- 8 9 MR. COX: Let's go off the record. 9 10 (WHEREUPON, discussion was held off the record.) 10 11 MR. WRIGHT: Let's go back on the 11 12 record, because there may be something we can talk 12 13 about. 13 14 BY MR. WRIGHT: 14 15 Q It turns out that this Exhibit Number 13 15 16 does not have data for 001, correct? 1 didn't see 16 17 it. Maybe you can correct me. 17 18 A Yes, it appears that this one was well 18 19 water sampling. 19 20 Q Okay. Let's look at the screening 20 21 levels, though. What is the screening level for 21 22 the aroclor? 22 23 MR. COX: It's further in. 23 Page 11 Q Well, which one do you -A And so, unless 1 see something that indicates differently, that's --1 would -- my conclusion would be that for quantification, GC/EC is what typically was used. Q Well, why does it say either? A 1 cannot answer that. Q Now, what's bigger, a microgram or a nanogram? A What is bigger? Q Yes. A A microgram. Q Are you sure that it's parts per billion and not parts per million? Because a nanogram per liter, 1 think is parts per billion, isn't it? A No. A microgram per milliliter is a part per million. A microgram per liter is a part per billion. Q Okay. Well, we'll come back to this when we get the one for the right discharge point. A This shows in this summary the screening level of one microgram per liter, on page three. Q What page are you looking at? Page 10 Page 12 1 THE WITNESS: Two screening levels 1 A Page three. 2 are listed here, one for the GC/MS screen, which is 2 Q Okay. And they're saying they did a 3 ten micrograms per liter, and one for the 3 GC/MS analysis, you're right. 4 GC electron capture screen, which is one microgram 4 A GC/EC. 5 per liter. 5 Q Well, they say GC/MS. 6 BY MR. WRIGHT: 6 A Where are you referring to? 7 Q And first, can you translate that to 7 Q Up here in the title it says, priority 8 parts per million or parts per billion? 8 pollutant screening levels, GC/MS -- 9 A Let me borrow a piece of paper. 9 A Okay. 10 Microgram per liter is parts per billion. 10 Q -- analysis of organics in industrial 11 Q Parts per billion? 11 effluence. 12 A Uh-huh. 12 A Okay. It also lists in the screening 13 Q Okay. Do you know whether -- does it 13 level of one microgram per liter for pesticides and 14 say in here whether they use the ten parts per 14 aroclor. 15 billion or the one part per billion? Let me give 15 Q Yeah, and I'm a little bit puzzled, 16 you a hint; on page three, in the summary, it says, 16 because they say, see table three. And then table 17 they were investigated through either GC/MS or 17 three is what we just looked at. It has both 18 GC/EC screening analysis. It sounds to me like 18 levels, it has the ten and the one. 19 they're not going to tell us whether they used the 19 A And it - and 1 refer back to the 20 GC/MS or GC/EC on the aroclor. 20 statement 1 made earlier, that generally, on 21 A Normally, GC/MS was used for 21 pesticides and aroclor, for quantification, GC/EC 22 identification. GC/EC was used for quantification, 22 was most commonly used because of its lower 23 because it had a lower level of detection. 23 detection level. Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Pages 9-12 HARTOLDMON0034983 Page 13 Page 15 1 Q Let's go over the photographs. I'm 1 Q Uh- 2 going to hand you Exhibit Number 11. And we're 2 A Equipment of this type is normally 3 just going to walk through these and get you to 3 dedicated. 4 explain what each photograph shows. Let's start 4 Q I'm sorry? 5 with page one. And I've numbered on each page 5 A Equipment of this type was dedicated. 6 where there is multiple photographs, 1 lettered the! 6 Q Page three. This is where -- what is 7 photographs. So, what does 1-A show? 7 page three showing us? 8 A This is apparently one of the sewer 8 A A clean-out of one of the limestone 9 boxes. 9 beds. 10 Q You said sewer boxes? 10 Q Is this the limestone bed that fronts on 11 A Well, yes, uh-huh. 11 Clydesdale? 12 Q Basically, an opening so that you can 12 A Yes. 13 observe the sewer? 13 Q What was the purpose for cleaning it out 14 A Yes, it's basically a connection of 14 in June of'77? 15 sewers with an opening so that you can observe. 15 A Because it had basically become plugged 16 Q And what can you observe in 1-A? 16 with storm sediments, sediments from storm water. 17 A Well, 1 would have to look, go ahead and 17 Q What happened to the material that you 18 look at 1-B and C to try to tie all of those 18 dug out of it? 19 together, 1 don't -- 19 A It was transported to the landfill and 20 Q Looking at all of those, what does it 20 placed in the landfill cell. 21 show you? 21 Q Do you know which cell it was placed in? 22 A This is relating to a, if 1 remember 22 A 1 don't remember, at this time. 23 correctly, a spill of HB40 that released some few 23 Q Page four? Page 14 Page 16 1 gallons of HB40 or Therminol 66, whichever name you 1 A A is another photograph of the--the 2 want to call it, into the storm sewer. And this is 2 previous series that we looked at. 3 basically showing the capture of that. 3 Q By the way, were the sediments tested 4 Q Showing the capture? Where was it 4 for PCBs? 5 captured? 5 A At this particular event, 1 don't know. 6 A It was captured in the sewer box and 6 Photograph B is, 1 am guessing, a picture prior to 7 basically, it was -- anyplace that it was captured 7 the clean-out. 8 there, it was then sucked up with a vacuum truck 8 Q Of the limestone bed? 9 out of that point. 9 A Yes, sir. 10 Q Is HB40 heavier than water? 10 Q Page five, 1 assume this is, again, the 11 A Very slightly. 11 limestone pit? 12 Q On page two, what does page two show? 12 A Yes, sir. 13 And A looks like another sewer photo; is that 13 Q It says, mid-baffle. What is a 14 right? 14 mid-baffle? 15 A And that's basically a continuation of 15 A That's one bed, maybe both, I'm not 16 that same event that 1 referred to. And then these 16 sure, don't remember, but was constructed in 17 others appear to be photographs that were taken at 17 baffles at different points, basically, to divide, 18 the dock where the -- where the spill occurred. 18 help afford -- provide structural support for 19 Q Was this equipment once used to transfer 19 limestone. 20 PCBs? 20 Q If we look at A, there's some buildings 21 A No. 21 in the background. You can see two buildings, one 22 Q This was never used to transfer PCBs? 22 three-story building, it looks like, and then one 23 A No, not to my knowledge. 23 kind of long, metal building. What's the long, Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Pages 13-16 HARTOLDMON0034984 Page 17 1 metal building? 1 2 A It's a warehouse. 2 3 Q Is that the warehouse where PCBs used to 3 4 be stored and drummed? 4 5 A For a short period of time. That 5 6 building was built just before the-- 6 7 Q Was that part of the expansion when the 7 8 PCBs were shut down? 8 9 MR. COX: Object to the form. 9 10 BY MR. WRIGHT: 10 11 Q You can answer. 11 12 A I don't remember this being a part of an 12 13 expansion, but it was part of a new warehouse 13 14 facility that was built right about the time that 14 15 the aroclor facility was shut down. 15 16 Q It was built adjacent to the aroclor, 16 17 the old aroclor facility, correct? 17 18 A No. The old aroclor facility would have 18 19 been south and west of this structure. 19 20 (WHEREUPON, there was a brief recess.) 20 21 MR. WRIGHT: Let's go back on the 21 22 record. 22 23 BY MR. WRIGHT: 23 Page 19 up some of the writing. The writing said north pit or N pit. I assume that means north pit; is that right? A Yes. Q North pit showing mid-baffle and looking upstream to inlet end. The inlet that they're referring to is where the sewer discharges into th^ limestone pit, correct? A Yes, sir. Q And again, that's the same sewer that used to run -- well, I say it's the same sewer - the sewer that ran from the aroclor building, this is the inlet or the outlet, whatever you call it, for that sewer, correct? A There was several sewers that joined Q Right. A -- and the inlet at the pit at this point. Q One of them being the aroclor sewers? A Yes. Q Then photo B, it says north pit from inlet towards discharge. So, this is looking towards Clydesdale, correct? Page 18 Page 20 1 Q While we were off I asked you to draw a 1 A Yes, sir. 2 little bird's eye sketch of the two buildings that 2 Q Note black parenthesis dark brown close 3 we see in the background of photo 5-A. Andyou did 3 parenthesis organic liquid on surface of mud in 4 that; is that correct? 4 grit chamber. What does that mean? 5 A Yes. 5 A That's another photograph of the 6 Q And I'm going to number these buildings. 6 material I referred to earlier, that had been 7 Well, actually, I'll label them what y'all used to 7 spilled and was being cleaned up. 8 call them. What did you used to call that 8 Q Is that what it would look like when the 9 building. 9 aroclor would spill? 10 A Building twenty-eight. 10 MR. COX: Object to the form. 11 Q Building twenty-eight. The one to the 11 BY MR. WRIGHT: 12 right of the aroclor building? 12 Q You can answer. 13 A That's correct. 13 A I have no idea. I've never seen aroclor 14 Q And then the long building south of 14 spill. 15 building twenty-eight or that-- 15 Q You don't remember the fifteen hundred 16 MR. COX: That's south. That's 16 gallon spill in I believe it was '69? 17 north. 17 A No, I do not. 18 THE WITNESS: No, it's north. 18 Q Then C, photo C says, north pit looks 19 BY MR. WRIGHT: 19 southeast at grit baffle, note black organic 20 Q The building north of building 20 material, liquid on mud behind baffle before 21 twenty-eight? 21 cleaning, correct? 22 A Is called the MIC Warehouse. 22 A Yes. 23 Q Now, in the sketch, we kind of covered 23 Q Was that material ever tested for PCBs? Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Pages 17-20 HARTOLDMON0034985 Page 21 Page 23 1 MR. COX: Object to the form. 1 Q Was that clay tested for PCBs? 2 THE WITNESS: This material was 2 A That clay was totally virgin clay. But 3 HB40 and - 3 it was being dug and transported. And, no, itwa^ 4 BY MR. WRIGHT: 4 not tested for PCBs. 5 Q Right. 5 Q Where is the borrow pit? 6 A And, no, this material is not tested for 6 A The borrow pit was at a location east of 7 PCBs. 7 Mars Hill Church. 8 Q Had this limestone pit been replaced 8 Q How far east? 9 since the end of the aroclor production? 9 A Well, it's was where the -- the 10 A Yes. 10 catchment basins are now located. 11 Q When was it replaced? 11 Q So, it's just down the stream? I mean, 12 A As I remember, in the '72, '73 time 12 downhill from the landfill? 13 frame. 13 A Well, it, itself, was a hill. The flow 14 Q How was it replaced? 14 was not that direction. This was basically a large 15 A In a manner very similar to that 15 mound at the time. It was basically pure clay. 16 illustrated in the photographs. 16 Q Well - 17 Q The material was dug out, put in trucks 17 A That's the clay that was used for 18 I assume? 18 operation, both lining and cover in the landfill 19 A Yes. 19 operation. 20 Q Taken to the landfill? 20 Q And it was never tested for PCBs? 21 A Yes. 21 A No. 22 Q And then, what was placed in the pit, 22 Q 6-D, what does that show? 23 just a bunch of limestone? 23 A I don't know. I do not recognize that. Page 22 Page 24 1 A Well, it was lined with clay. 1 Q Is that sewer pipe? 2 Q Okay. 2 A It's some pipe of some type, and it 3 A Compacted, then filled with limestone. 3 looks like it's some that has been underground that 4 Q Was there just one clean-out between the 4 has been -- been removed. 5 end of the aroclor and this clean-out in '77? 5 Q Both of these pipes have large crack in 6 A As I recollect. 6 them, correct? 7 Q Now, when were these pits finally taken 7 A That's what it appears. 8 out altogether? 8 Q On page seven, again, we have a little 9 A One was removed probably in the late - 9 bit better view of the two buildings in the 10 in the mid to late--well, late'70s, and the 10 limestone pit. That's in photo A. In photo B, we 11 other in the early '80s. It's --1 don't remember 11 see the end of the warehouse and a bunch of drums. 12 specifically, but that's my best recollection. I 12 What are those drums? 13 do remember they were done one at a time. 13 MR. COX: You talking about over 14 Q How were they taken out? I mean, what 14 here? 15 happened? 15 MR. WRIGHT: Yeah. 16 A The material was physically removed as 16 THE WITNESS: They're empty drums 17 described previously, taken to the landfill and 17 that were stored as part of the warehousing 18 landfilled. 18 operation. 19 Q What was the-- 19 BY MR. WRIGHT: 20 A Then - 20 Q When the PCBs, when the aroclor were 21 Q Go ahead, I'm sorry. 21 being sold, some of them left the plant in tank 22 A - backfilled with clay from the clay 22 cars, correct? 23 borrow pit. 23 A That's correct. Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Pages 21 - 24 HARTOLDMONOQ34986 Page 25 Page 27 1 Q I assume some of them left in drums like 1 an aroclor structure. And then when the warehouse 2 this? 2 was built, a new flakerwas installed there, was 3 A They left in drums. I mean, I can't 3 operated for a short period of time, but not long 4 identify this drum well enough to know if it was 4 before it was closed down. 5 like that or not. 5 Q And remind me, what went on in building 6 Q How did the --1 think I remember 6 twenty-eight? 7 somebody saying that the solids were flaked and 7 A Building twenty-eight, over the course 8 sacked; is that right? 8 of the years, was used for quite a number of 9 A Flaked and put into fiber drums, as I 9 things. When I interviewed at the plant, my first 10 remember. 10 trip was actually caught before the administration 11 Q How else did the aroclor leave the 11 building that's known today was built and all the 12 plant? Is that it? 12 administration offices were in building 13 A Tank trucks. 13 twenty-eight, including the plant manager's office. 14 Q Any other ways? 14 There was also a conference room in that building. 15 A No. 15 The laboratory facility was located in that 16 Q If we go back to our little drawing, in 16 building. The storage facility was located in that 17 relation to these three buildings, where would the 17 building. The plant -- 18 railroad tank cars have been loaded? 18 Q Did the laboratory - 19 A Uh- 19 A The plant dispensary was also located in 20 MR. COX: You mean loaded with 20 that building. 21 liquid aroclor? 21 Q Did all the functions, except the 22 MR. WRIGHT: Yes, sir. 22 administrative functions, remain until the building 23 THE WITNESS: As I remember, in 23 was torn down? Page 26 Page 28 1 this area. (Witness Pointing.) 1 A The laboratory moved to another building 2 BY MR. WRIGHT: 2 in -- well, that was -- that was the primary QAQC 3 Q You're pointing to the - 3 laboratory. There was another building, smaller 4 A There was a rail, a rail line that came 4 building, that had the small R&D labs for R & D 5 down, and then a spur that came around, like so. 5 purposes, in addition to some drafting offices. 6 That's --1 was not directly involved with that, 6 And when aroclor closed, the laboratory 7 but that's -- that's how I remember. I think 7 was consolidated into this -- a smaller building 8 that's -- that area is shown a little bit better in 8 that had previously been R&D and drafting area. 9 some of these other pictures. 9 The building twenty-eight was continued to be used 10 Q Okay. We'll look at that in a minute 10 as maintenance offices, storeroom, dispensary, 11 then. But you think the actual loading was done - 11 conference room. 12 is this north or south? 12 Q Okay. Page eight is more pictures of 13 MR. COX: That's south. 13 the pit clean-out, correct? 14 BY MR. WRIGHT: 14 A Yes. 15 Q -- just to the south of the aroclor 15 Q So is page nine? 16 building? 16 A Yes. 17 A South and west. 17 Q And then page ten? 18 Q Okay. And then the tank trucks, where 18 A Page ten, is the -- shows the lining 19 would they have been loaded? 19 with clay. 20 A In the same locations. 20 Q Is this your handwriting? 21 Q And then the flaked solid aroclor, where 21 A No, sir. 22 would they have been drummed? 22 Q Do you know whose it is? 23 A As I recollect, that flakerwas actually 23 A I think it's Bill Taffee. Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Pages 25 - 28 HARTOLDMONOQ34987 Page 29 Page 31 1 Q Have you seen him lately? 1 weather got like this, they'd pop right back out. 2 A Bill -- Bill was basically in charge of 2 Q Okay, page fifteen. What is this 3 this operation. 3 showing us now? And is this your handwriting? 4 Q Have you seen him lately, Mr. Taffee? 4 A No, this is not my handwriting. This is 5 A Been approximately a year to fifteen 5 Burns Severson's handwriting. 6 months since I've seen Bill. 6 Q Is this showing us the sewer boxes 7 Q Where did you see him when you saw him? 7 again? 8 A 1 think the last time 1 saw Bill was at 8 A Yes. And that's a vacuum truck, 9 the barber shop. 9 removing what apparently was some small release 10 Q Does he drive himself? 10 that was captured in this box. 11 A Oh, no, no. 11 Q On photo B and photo C, can you read 12 Q Huh? 12 what's written? 13 A No. 13 A 3-B says facing railroad's entrance. 14 Q Who drove him to the barber shop? 14 THE COURT REPORTER: What road? 15 A His wife. 15 MR. WRIGHT: Railroad. 16 Q What's his condition? 16 THE WITNESS: Entrance. 17 A At that time, Bill could move with an 17 BY MR. WRIGHT: 18 aid of a walker, with assistance from somebody, 18 Q And then C, what does that say? 19 but -- well, no, he -- he was -- he was in and out 19 A 1 can read black float and pit, but 1 20 of a wheelchair. He was brought in, in a 20 can't make out the -- 21 wheelchair. 21 MR. COX: It looks like after 22 Q What -- 22 blocking backflow. 23 A He's - 23 THE WITNESS: After blocking Page 30 Page 32 1 Q -- does he have? 1 backflow, 1 can't - 2 A His verbal -- he's had a stroke. He can 2 BY MR. WRIGHT: 3 say one, maybe two words. If 1 asked him a 3 Q Maybe pit emptied of DO, does that make 4 question, he could answer with one word. 4 sense? 5 Q Now, on page twelve it shows the south 5 A No, that's what 1 can't make sense of. 6 pit. Is that one of the two limestone pits there 6 Q It's pit emptied of something 7 that were close to each other? 7 accumulation. It look likes DO or DU or OU maybe, 8 A Yes. 8 1 don't know. 9 Q And then you have some photos from '79, 9 A Yeah, 1 have absolutely no idea what 10 showing the water hyacinth growing in the pit? 10 that OU or DU is. 11 A Yes. 11 Q Page sixteen, again shows another sewer 12 Q Did y'all plant those intentionally? 12 box. Why were they stopping the backflow? 13 A The departmental supervisor for the 13 A That was to -- see, they had had a -- 14 poly-phenyls area, whose operators monitored this 14 they'd had a small release, and they would 15 area routinely, read about the use of water 15 basically stop the flow until it could be cleaned 16 hyacinths in water cleaning and filtration, and he 16 out. 17 had property in Florida, where he visited 17 Q Is this Mr. Severson showed on page 18 routinely, and he brought back some from his 18 eighteen? 19 property in Florida and put in the pit. 19 A No. 20 Q Just out of curiosity, did they 20 Q Do you know who that is? 21 regenerate after the winter? 21 A 1 can't see it well enough to recognize. 22 A Yes. They basically -- the tops died 22 Burns was a much taller, larger person than that. 23 down, but the bottoms did not. And as soon as the 23 This is an operator who was working. Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Pages 29 - 32 HARTOLDMON0034988 Page 33 Page 35 1 Q On page nineteen, photo number C, is 1 MR. COX: You're going to take 2 that the same limestone pit we've been looking at? 2 Gerald Miller's deposition on the 12th, and he wa 3 A Yes. It's simply a different 3 the aroclor supervisor when it shut down. 4 orientation. 4 MR. WRIGHT: Good. 5 Q Is that landfill in the background? Up 5 MR. COX: Jerry, you understand, 6 there at the -- you see the -- you see the hill 6 these are from - believe they're from the aroclor 7 there and then you see the bare area or--1 say 7 unit, don't you? 8 bare - the area without trees? 8 THE WITNESS: That's what 1 think. 9 A This, are you referring to this? 9 MR. WRIGHT: Well good, I'll take 10 Q Yes, sir. 10 that up with Gerald Miller then. 11 A No, the landfill would have been over 11 BY MR. WRIGHT: 12 here behind these trees. 12 Q Let's do whatever you can do today and 13 Q Behind which trees? 13 then I'll go get what he knows when 1 depose him 14 A Well, if this is the entrance into the 14 Page twenty-two. 15 plant -- 15 A Basically, the same. 1 think they're 16 Q Yes. 16 from the aroclor facility, but - 17 A -- and you -- the landfill is right in 17 Q You can't tell whether that's a 18 here. 18 chlorinator? 19 Q 1 got you. There appears to be kind of 19 A Basically, 1 conclude this because 1 20 an open area up there -- 20 know all the other facilities better and 1 do it by 21 A Yeah. 21 deduction, you know, 1 don't do it because 1 22 Q -- at the foot of the hill? 22 identify this specifically, you know, 1 did not 23 A Yeah, you got trees on the front, but 23 know the equipment that well. Page 34 Page 36 1 then an open area and then the trees resume. 1 Q So, you can't tell whether we're looking 2 Q Page twenty, that's Exhibit Number 12, 2 at chlorinators - 3 picks up with page twenty. There is only one photo 3 A No. 4 on page twenty. What does that show us? 4 Q -- in A and B? 5 A The north end of the aroclor structure. 5 A No. 6 And that photograph is extremely smudgy there, so, 6 Q Twenty-three that shows -- is that the 7 it's what appears to be obvious smudge on the 7 one you're talking about that shows the tank car 8 photograph. 8 loading? 9 Q What are these tanks that are in the 9 A That's -- yes, that -- that is one of 10 forefront of the photograph? 10 the loading docks, as 1 remember. 11 A Well, they're some of the process tanks, 11 Q And those pipes, the overhead pipes, 12 I'm -- beyond that, 1 can't identify them. 12 would they have carried the PCBs or the aroclor? 13 Q Page twenty-one, what does A show? 13 A Well, I'm not totally sure about the 14 A I'm right -- not really sure, some 14 routing. 1 know --1 do know that the acid piping 15 vessel. 1 don't know what it is. 15 went across there and maybe some aroclor piping, 16 Q Is that a chlorinator? 16 too, but I'm -- I'm not really sure there was -- 17 A No, it's--1 would not think so. But 1 17 there was also some loading back on the west side 18 did not know these vessels well enough to really 18 that's not shown here. It had been back -- back in 19 identify them. I'm not really -- didn't really go 19 this direction. 20 in this department very much during the course of 20 Q Okay. 21 my work. 21 A You know, before you get this far around 22 MR. WRIGHT: Buddy, we may end up 22 on the -- 23 having to bring one of those other guys back. 23 Q Okay, around on the -- what, it would be Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Pages 33 - 36 HARTOLDMON0034989 Page 37 Page 39 1 hidden by the building there now? 1 Q Okay. 2 A Well, it would actually be on -- west of 2 A And photograph A shows the very top part 3 the building back in here. 3 of it that had been taken off of a truck apparently 4 Q This brick ditch here, was that to drain 4 and B shows the primary body of it, which I would 5 spills and so forth, and storm water? 5 assume came in on a rail car. 6 A Well, I'm not really sure, I don't -- 6 Q Is the building in 25-A, as we're 7 you know I don't remember anything about the ditch 7 looking at it to the left, is that the aroclor 8 more than what I can see on the picture here. 8 building? 9 Q Would that have been routed to the 9 A Yes. 10 sewers, you think? 10 Q And then the building to the right, is 11 A I would think so. 11 that building twenty-eight? 12 Q 23-B, do you know what that shows? 12 A Yes. 13 A No. It's obviously a piece of equipment 13 Q And so the poly-phenyl set in between - 14 that was, you know, open for maintenance, but I 14 A Actually, it was south of them. The - 15 don't know what it is. 15 that was the nearest roadway there and it was then 16 Q 23-A appears to show some kind of debris 16 transported by crane to the -- 17 or something. Then-- 17 Q I got you. Then page twenty-six, we see 18 A 24-A. 18 there's two photos, A -- and they appear to be 19 Q 24-A, I'm sorry. 19 dated 1961. Photo A, what does that show? 20 A 24-A, that appears to be a piece of 20 A I think it's a side view of the aroclor 21 piping associated with the poly-phenyls 21 department. 22 manufacturing. It was when piping would be taken 22 Q The building was open to the air; is 23 out of service, it would be cut open and inspected 23 that right? Page 38 1 and that's -- that's what that appears to be. 1 2 Q The inside is pitted? 2 3 A Yes, sir. 3 4 Q Isn't it? 4 5 A Yes. 5 6 Q Was that corrosive? 6 7 A No, it was -- when that process was 7 8 started up, there was some pit corrosion that 8 9 occurred in the piping and it -- it occurred very 9 10 shortly after the processor was started up, then it 10 11 was immediately shut down and investigated and it 11 12 had to do with trace levels of sulfur in the--in 12 13 the stream, interacting with the metallic alloy 13 14 composition, so the metal alloy had to be changed 14 15 and the sulfur level lowered. 15 16 Q Were the PCBs corrosive, the aroclor? 16 17 A Oh, no. 17 18 Q Okay. Page twenty-five, what does that 18 19 appear to show? 19 20 A Well, that shows the arrival of the 20 21 poly-phenyls furnace that was--poly-phenyls 21 22 reactor that was installed in'61, that actually I 22 23 was referring to when I was talking about piping. 23 Page 40 A I don't --1 don't understand open to the air. I mean -- Q Well, I mean, it's got - A Are you asking if it is a totally enclosed building? Q I guess that's what I'm asking. A No, it wasn't totally enclosed. Q We can see these openings in the building on all three levels, it looks like. Did those generally remain open? A Yes. Structures of this type were never intended to be closed. They were - basically, enough building was provided for weatherproofing and that's all. Q All right. Photo B, do you know what that shows? A That appears to be an air dryer and an instruments air line. Q I'm sorry? A An air dryer and an instrument - instrument airline. Q Explain that, if you would. What do you need an air dryer for? Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Pages 37 - 40 HARTOLDMON0034990 Page 41 Page 43 1 A Well, a lot of instruments are operated 1 Q But does that tell you where the sample 2 with air pressure. If you -- when you compress 2 came from? 3 air, as you're well aware, air contains a certain 3 A That was the M - that is the permitted 4 amount of moisture. When you compress it, a lot of 4 discharge. That was the only point under MPDES, 5 this moisture is going to condense. Moisture in 5 AL1201. 6 air lines can create problems that for instrument, 6 Q So, there is only one MPDES discharge 7 air that's used for operating automated equipment. 7 point? 8 Q Okay. 8 A Yes, sir. 9 A And so instrument air typically has an 9 Q 1 thought there was a DSN002 and a 10 air dryer to dry the air so that the -- 10 DSN003 and a 4 and a 5 and a 6. 11 Q Okay. 11 A If you go back to the MPDES permits, 12 A And that appears to be an air dryer to 12 during that period of time, the 001 became the 13 me. 13 MPDES permitted discharge point. 002 was the 14 Q Okay. Page twenty-seven, what does that 14 indirect, which was under indirect discharge 15 show us? 15 permits, not a direct discharge permit. The others 16 A Photograph A is another, what 1 would 16 you referred to, three, four, five - 17 think is side view of the aroclor unit. 17 Q Right. 18 Q Do you know what those tanks -- 18 A Those were previously identified 19 A No, 1 do not. 19 discharge points that were eliminated as discharge 20 Q -- were for? Okay. And what about B? 20 points, prior to the time MPDES permit was issued. 21 A This appears to be kind of a top shot of 21 Q Well, Number 13 that we looked at just 22 a compressor. 1 can see the--the guards. Ifl 22 before -- is it Number 13? 23 had to guess, I'm guessing it's an air compressor. 23 THE COURT REPORTER: It should Page 42 1 MR. COX: Can we go off the record 1 2 for a moment? 2 3 MR. WRIGHT: Yeah. 3 4 (WHEREUPON, there was a brief recess.) 4 5 (WHEREUPON, Plaintiffs Exhibit 14 was marked for 5 6 identification.) 6 7 BY MR. WRIGHT: 7 8 Q Let's go back on the record. All right, 8 9 Mr. Brown once again, we're going to start the 9 10 session with a document that may or may not be -- 10 11 MR. COX: Is that Exhibit 14? 11 12 MR. WRIGHT: Yes, Exhibit 14. 12 13 BY MR. WRIGHT: 13 14 Q Over the lunch break, Mr. Cox went back 14 15 to the computer and pulled another document that is 15 16 one of the screening-type documents. And it states 16 17 it's screening a water sample. But 1 couldn't find 17 18 any description in there on where the water sample 18 19 came from. 19 20 A (Witness points.) Sample IDAL0001201. 20 21 Q All right. 21 22 A Which was the MPDES permit discharge 22 23 number. That -- that is the MPDES permit. 23 Page 44 still be there. BY MR. WRIGHT: Q Yeah, Number 13 shows DSN5 and 6, discharge 005 and discharge 006, in April of 1981. And this 14 is from January of '81. So, how could the 5 and 6 have been eliminated before this MPDES that you say is shown us in Exhibit Number 14? A Okay. The best way 1 know how to answer that is to kind of back up and describe a little bit about the history. Q Okay. A When the permitting process was started in the mid '70s, thereabouts, prior to that time, it was common for discharge water, whether it -and I'm talking non-contact kind of process water, to be discharged in the most convenient direction from a plant, if 1 will. Okay, as part of the MPDES permitting process, those discharges were all combined or eliminated as a discharge point from operating facilities. Okay. 5 and 6 were basically some underground pipes that dated back many, many years. And as part of this investigation, source of water Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Pages 41 - 44 HARTOLDMON0034991 Page 45 Page 47 1 that might be discharged from those was 1 A Okay, this is a sampler that basically 2 investigated and found to be spring water, ground 2 samples continuously, around the clock and puts 3 water. As part of the screening of those to ensure 3 that sample into a large jug so that a twenty-four 4 that nothing was leaving from those points, that - 4 hour composite sample is sampled for a full 5 you know, there was a --1 guess a series of 5 twenty-four hours -- put in there so that when you 6 testing screen work done on those and everything 6 take a sample out of that jug, that is a composite 7 else, and this being a part of it. 7 of that twenty-four hour sampling that was done. 8 Q Number 13 you're talking about? 8 Q So, it's taking a little bit of water 9 MR. COX: Yes, Exhibit 13. 9 every so often? 10 THE WITNESS: Uh-huh. But all 10 A Continuously, continuously, over the 11 non-contact water and boiler blow down water - 11 twenty-four hour period. 12 THE COURT REPORTER: Boiler- 12 Q Just drips in there or something? 13 THE WITNESS: Boiler. 13 A It's pumped in there, through the 14 MR. COX: Boiler. 14 sampler, the sampler is -- is taking the sample on 15 THE COURT REPORTER: I'm sorry. 15 a continuous basis. 16 THE WITNESS: Was discharged at 16 Q Okay, well here is where I'm -- I'm lost 17 point 001, which when the permit was issued, was 17 conceptually. You got a jug - 18 the 12 -- what was it 1201 on the EL0001201. 18 A Uh-huh. 19 Process water, through waste treatment, was 19 Q -- and you've got water flowing into the 20 discharged through 002, through an indirect 20 jug continuously? 21 discharge permit. That was separate from the MPDES 21 A Uh-huh. 22 direct discharge permit. 22 Q Is water flowing out of the jug 23 BY MR. WRIGHT: 23 continuously? Page 46 1 Q Going back to Exhibit Number 14, do you 1 2 know what the flow rate was when this sample was 2 3 taken? 3 4 A Not unless it's documented back --1 4 5 don't know - if it's doc- - 5 6 Q Did you take that sample? 6 7 A 1 probably did not, because it was not a 7 8 part of my job. They had a sampling technician who 8 9 was responsible for the twenty-four hour composite 9 10 samplers that were operated. Flow rate and -- was 10 11 recorded on a daily basis. Samples were taken as a 11 12 twenty-four hour composite sampler and there was a 12 13 technician who was responsible for doing that - 13 14 that daily sampling. And I'm assuming that he took 14 15 that sample at that point in time. 15 16 Q When you say there was a twenty-four 16 17 hour composite sampler, would you explain that? 17 18 A Do you know what 1 mean when 1 say 18 19 composite sampler or do 1 need to explain that? 19 20 Q You need to explain that. 20 21 A There is a - 21 22 Q 1 mean, I've got an assumption, but 1 22 23 don't want to -- 23 Page 48 A No, no, no, no, no. It's flowing in at a rate so that it will not be filled up over a twenty-four hour period. We're talking about a large jug and a slow sampling rate continuously. Q Do they empty the jug A Yes. Q -- after they take the sample? A As the sample is taken, the jug is emptied. Then that starts the next twenty-four hour composite sample. Q Okay. A And this was done on a daily basis, everyday. Q But PCBs were not checked routinely, correct? MR. COX: Object to the form. BY MR. WRIGHT: Q You can answer. A They were not checked on a daily basis, that's correct. Q In fact, 1 thought we decided in our last session that between '74 and '88, there were only approximately two PCB analysis done on the Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Pages 45 - 48 HARTOLDMON0034992 Page 49 1 discharge. Is that still your testimony? 1 2 MR. COX: Same objection. 2 3 THE WITNESS: These are the ones 3 4 that 1 remember. 4 5 (WHEREUPON, Plaintiff's Exhibits 15 & 16 were marked 5 6 for identification.) 6 7 BY MR. WRIGHT: 7 8 Q Okay. And there's two, 1 guess. 8 9 Assuming that 14 is DSN001, that's one in January 9 10 of '81 and then is this -- what's the next one? 10 11 A This is July of'83. 11 12 Q Now, this one does designate it at 0001, 12 13 the July of '83, which is Exhibit Number 15 and 13 14 then what's Number 16? 14 15 A This was waste water from the waste 15 16 treatment and biological sludge for dioxins. 16 17 Q Okay. So, aside from 15 and 16, are you 17 18 aware of any other testing for PCBs in the 18 19 discharge from the plant between 1974 and 1988? 19 20 A No. 20 21 Q And do you know that the sample that is 21 22 reflected in Exhibit Number 14, do you know 22 23 specifically how that sample was collected? 23 Page 51 there could have been. COD and PH being the most important. BY MR. WRIGHT: Q For either one of these samples, either the one shown in 14 or the one shown in 15, do you know whether there had been any rain before these samples were taken? A No, 1 do not remember. Q Was the storm water run-off ever sampled? A As a part of that sample, but not separately from it. Storm water was included in this discharge point, too. Q Well, if there was storm water - 1 mean, if it hadn't rained for several days before this sample was taken, there wouldn't be any storm water in the sample, correct? A That's correct. Q And what I'm asking you is: Specifically, was storm water that was known to be storm water run-off from the plant ever checked? A Not separately from the twenty-four hour composite sampler that was run every -- daily every Page 50 Page 52 1 A That sample was collected at the -- the 1 day. 2 official sampling point, which is a part of the 2 Q I'm talking about for PCBs, sir. 3 permit process, it's a twenty-four hour composite 3 A Not - no, not separately from those two 4 sampler, as 1 previously described. And that 4 points. 5 sample -- that sampler is run on a daily basis, 5 Q Let me just look at this real quickly. 6 other parameters as specified by permit were run 6 Exhibit Number 15, one, two -- the ninth page of 7 daily or as specified by the permit. 7 that document is where the PCBs are set out and it 8 Q Right, that's the dissolved solids and 8 shows that the screening level is ten UG, that's 9 stuff like that? 9 micrograms, 1 assume? 10 A Well, that was not a part of that-- 10 A That's correct. 11 dissolved solids weren't a part of that permit. 11 Q Per square liter? 12 Q What were the parameters that were run 12 A Per liter. 13 daily, just generally? 13 Q Per liter. 14 A In 1981, you're talking COD-- 14 MR. COX: That's an asterisk. 15 Q What is COD? 15 MR. WRIGHT: Okay, I'm reading it 16 A Chemical oxygen demand. COD would have 16 upside down. 17 been run on probably a weekly basis. PH on a daily 17 BY MR. WRIGHT: 18 basis. Phosphates had been stopped by '81. 18 Q And do you know why they didn't spike 19 THE COURT REPORTER: Phosphates, 19 the blanks? 20 I'm sorry. 20 MR. COX: Object to the form. 21 THE WITNESS: 1 started to say 21 MR. WRIGHT: What's the matter with 22 phosphates had been stopped by '81. 1 don't 22 that, Buddy? 23 specifically remember other parameters, although 23 MR. COX: Spike the blanks with Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Pages 49 - 52 HARTOLDMON0034993 Page 53 Page 55 1 what? 1 don't know any specific reason other than just 2 MR. WRIGHT: PCBs. 2 somebody taking pictures of the vegetative growth 3 MR. COX: Okay. 3 that was present. 4 THE WITNESS: No, 1 do not know. 4 (WHEREUPON, there was a brief recess.) 5 BY MR. WRIGHT: 5 (WHEREUPON, Plaintiff Exhibit 18 was marked for 6 Q Isn't that a common quality control 6 identification.) 7 procedure, so that you know that you're -- you put 7 BY MR. WRIGHT: Let's mark this as 8 a known quantity into a blank and try to recover 8 Number-- 9 that known quantity so you know that your procedure 9 THE COURT REPORTER: Okay. 10 is working correctly? 10 MR. COX: Is this 18? 11 A I'm really not that familiar with what 11 THE COURT REPORTER: It is. 12 was required or published as part of this EPA 12 MR. COX: Can he look at it? 13 method, so I'm not in a position to answer that 13 MR. WRIGHT: Sure. 14 question. 14 BY MR. WRIGHT: 15 Q All right. Let's look at these 15 Q What is Exhibit Number 17 or no 18? 16 photographs -- I'm debating on whether to attach 16 A This is the storm water permit 17 them or not. 1 guess we had better. 17 application, filled out in 1985. 18 THE COURT REPORTER: 17. 18 Q And Robert Cheever filled that out. He 19 (WHEREUPON, Plaintiffs Exhibit 17 was marked for 19 was your subordinate, at the time? 20 identification.) 20 A That's correct. 21 BY MR. WRIGHT: 21 Q And you're copied on that document, 22 Q As Exhibit Number 17 -- 22 correct? 23 MR. COX: 1 don't have any of 23 A That's correct. Page 54 Page 56 1 these. 1 Q Let me see it for just a second. On the 2 BY MR. WRIGHT: 2 fourth page of the document, there is a section 3 Q As Exhibit Number 17 we've marked a set 3 that says, discharge permits and it says, MPDES and 4 of photographs that were extracted from the bunch 4 then it has the number that we talked about 5 of photographs you brought to the first deposition. 5 earlier, AL0001201, that's correct? 6 First of all, what is shown on the first page of 6 A Correct. 7 Exhibit Number 17? There's two photographs. What 7 Q And then it shows four separate 8 are they showing? 8 discharge points 001,005, 006, correct? 9 MR. COX: And 1 think they depict 9 A That's correct. 10 the same thing; they're duplicates. 10 Q And then on the next page it has a map 11 THE WITNESS: This is a view taken 11 of the plant and it shows where each of those 12 from the top of the landfill, looking northwest 12 discharge points is, correct? 13 toward the plant. 13 A That's correct. 14 BY MR. WRIGHT: 14 Q And they are four separate points, 15 Q Do you know which cells are shown here 15 geographically, correct? 16 in this photograph? 16 A That's correct. 17 A This is westside. I'd have to look at a 17 Q So, going back to the earlier question, 18 diag -- drawing to refresh myself on numbers, but 18 you can't say for sure that the sample that's 19 this is up toward the top on the westside. 19 reflected in Exhibit Number 14 was from the end of 20 Q Did you take these pictures? 20 the pipe at Clydesdale, correct? 21 A No, 1 did not. 21 A What 1 can tell you for sure is that the 22 Q Do you know why they were taken? 22 point at Clydesdale, known as 001, was the point 23 A Let me look through them to--no, 1, 1 23 that was permitted for discharge purposes from the Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Pages 53 - 56 HARTOLDMON0034994 Page 57 Page 59 1 manufacturing of the plant. 1 at the protocol, recently? 2 The other points, as identified there, 2 A You briefly showed it to me last week, 3 were as 1 described earlier, points that existed 3 if 1 remember correctly. 4 from historical reasons, were identified, sampled, 4 Q And this shows one sample came back at 5 on a number of occasions investigated, but never 5 seven hundred and fourteen micrograms per gram, so, 6 approved as a discharge point from manufacturing 6 what is that? Is that parts per million? 7 locations of non-contact water and boiler blow down 7 A Yes. 8 water. 8 Q Seven hundred and fourteen parts per 9 Q Well, 1 mean, all 1 can go by is what's 9 million, one thousand, two hundred and eleven parts 10 written here in your application, when you're 10 per million, a hundred and twenty-three parts per 11 talking about the existing discharge permits. And 11 million, and then twelve, seventeen, fourteen, and 12 it shows four separate discharge locations under 12 three parts per billion, with three non-detects, 1 13 the MPDES permit in 1985. 13 guess; is that correct? 1 guess 1 want you to 14 A Would you like to get that permit and 14 verify that. Did 1 call those out correctly? 15 explore it further then? That's the only way 1 15 A Based on what 1 remember, yes, 1 would 16 know how to resolve this question, sir. 16 say that sounds right. 17 (WHEREUPON, Plaintiffs Exhibit 19 was marked for 17 Q What's the CMA? 18 identification.) 18 A Chemical Manufacturers Association. 19 BY MR. WRIGHT: 19 Q Have you been to CMA meetings? 20 Q Okay. Let me hand you the next 20 A Yes, 1 have. 21 document, which will be Number 19. That seems to 21 Q Monsanto is a member of the CMA? 22 reflect nine soil samples that were analyzed in 22 A Well, at that time, yes. 23 what year? 23 Q Are you aware that the CMA has published Page 58 Page 60 1 MR. COX: 1985. 1 a set of guidelines for responsible manufacturers? 2 BY MR. WRIGHT: 2 Are you generally aware of that? 3 Q 1985. Can you tell where those soil 3 A Yes. 4 samples came from? It says they came from the 4 Q And 1 believe one of those guidelines is 5 Anniston plant, but I'm wondering where, 5 or says that a responsible manufacturer has a duty 6 specifically? 6 to -- I'm trying to paraphrase correctly -- and I'm 7 A This is the sediment samples that were 7 not going to be able to, so I'll just paraphrase it 8 analyzed as part of the Attorney General 8 and then you correct me if 1 misstate it - that a 9 investigation. 9 manufacturer has a duty to clean up its chemicals 10 Q Can 1 see that? 10 after they leave its plant, if it knows that they 11 A Uh-huh. 11 might be hazardous? 12 Q How do you know that that's what those 12 MR. COX: Object to the form. 13 are? Does it say somewhere here where they came 13 THE WITNESS: 1 don't remember any 14 from? 14 guideline that stated along that line. 15 A By looking at the sample numbers, 15 BY MR. WRIGHT: 16 that -- if you correlate these sample numbers to 16 Q What do you remember the guidelines 17 that sampling protocol, that sampling science, one, 17 saying regarding materials that have left the plant 18 two, three, four, five, six, this is sampling 18 and may be hazardous? What responsibilities does a 19 points, one, two, three, four, five, and that's 19 responsible manufacturer have? 20 duplicates. If you take the sampling protocol and 20 A The primary emphasis was control of 21 the numbers listed here, they correlate with the 21 spills, releases that -- during transportation, CMA 22 sampling sites on that protocol. 22 was responsible for forming the group called 23 Q Okay. When was the last time you looked 23 CHEMTREC, which is an emergency-response group that Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Pages 57 - 60 HARTOLDMON0034995 Page 61 Page 63 1 basically coordinated a nationwide effort for 1 the -- my career, when 1 was involved with these -- 2 response in the event of accidental releases of 2 these kinds of assessments, the state-of-the-art 3 products in transport or wherever else that they 3 technology is routinely applied to every product 4 may need to be addressed. 4 that we've made or thought about making. This 5 Q So, that deals with spills and -- 5 involves both toxicity testing and environmental 6 A Accidental releases. 6 fate testing. 7 Q -- accidental releases? What about 7 Now, the most -- as 1 said, the 8 non-accidental releases that you later find out 8 best you could do is state-of-the-technology at the 9 could pose a hazard to the environment or people? 9 time. Obviously, you're asking me what to do in 10 MR. COX: Object to the form. 10 retrospect. The best, most responsible thing that 11 BY MR. WRIGHT: 11 can be done is to stop any discharge that you may 12 Q Does a manufacturer have any 12 fall -- that may fall into this category. 13 responsibility under the guidelines in that 13 BY MR. WRIGHT: 14 respect? 14 Q Then what? If you stop, but the stuff 15 MR. COX: Same objection. 15 that you put out before you stopped is still out 16 THE WITNESS: 1 don't specifically 16 there, what's the manufacturer's responsibility? 17 remember CMA guidelines that address that. 17 MR. COX: Same objection. 18 BY MR. WRIGHT: 18 THE WITNESS: That's got to be 19 Q As a former environmental manager for 19 defined as technology allows, that you can only do 20 Monsanto, what do you believe a responsible 20 what you know. 21 manufacturer's responsibility is in that situation? 21 BY MR. WRIGHT: 22 MR. COX: Object to the form. 22 Q Can you explain that, because 1 don't 23 BY MR. WRIGHT: 23 understand what you mean. Page 62 Page 64 1 Q And by "that situation," let me define 1 A One can basically do only what is the -- 2 it. When chemicals have left the plant, the 2 that you can figure out how to do. 3 manufacturer knows they've left the plant, the 3 Q Monsanto knew how to dig up dirt, didn't 4 manufacturer knows they're present outside of the 4 it in -- well, in 1935, Monsanto knew how to dig up 5 plant, as a result of the discharges from the 5 dirt, right? 6 plant, and that the chemical may be hazardous to 6 MR. COX: Object to the form. 7 the environment or to people? 7 THE WITNESS: 1 wasn't born in 8 MR. COX: Same objection. 8 1935. 9 THE WITNESS: You asked a very 9 BY MR. WRIGHT: 10 broad range of things in your series of questions, 10 Q Wouldn't you assume -- 11 so, I'll attempt to hit on it the best 1 can. 11 A 1 might be known as old as dirt, but I'm 12 BY MR. WRIGHT: 12 not that old. 13 Q Now, it's just one question. You 13 Q Wouldn't you assume that Monsanto knew 14 understand that, right? What's a manufacturer's 14 how to dig up dirt in 1935? 15 duty or responsibility under the situation that 1 15 MR. COX: Object to the form. 16 described? 16 THE WITNESS: Digging up dirt is a 17 A Okay, a manufacturer's - 17 very broad term. Now, anybody has known how to dig 18 MR. COX: Same objection. 18 up dirt since the first child went out and scooped 19 THE WITNESS: --duty is to use the 19 up dirt. 20 state-of-the-art testing that's available at the 20 BY MR. WRIGHT: 21 time to know or to determine, as well as technology 21 Q Right. What we're talking about is 22 can determine, the hazards that may exist or be 22 remedying the discharges of the past once a 23 posed by one of its products. And throughout 23 terrible hazard has been identified. And one Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Pages 61 - 64 HARTOLDMON0034996 Page 65 Page 67 1 method for remedying those discharges is to dig up 1 manufacture. 2 the contaminated dirt, like you did for a part of 2 Then it moved very quickly to realizing 3 Snow Creek in 1989, and remove the contaminated 3 that manufacturing -- stopping manufacturing would 4 dirt from its proximity to children, elderly, other 4 be the best decision. The movement from 1970 to 5 people, correct? 5 1971 was extremely fast, as much as the human 6 MR. COX: Object to the form. 6 beings and technology at the time would allow. And 7 THE WITNESS: Yes. 7 that's --1 don't know how it could have been done 8 BY MR. WRIGHT: 8 anymore aggressively. 9 Q Monsanto could have used 9 Q What if Monsanto had waited a year and a 10 state-of-the-art technology to minimize or 10 half after it knew that PCBs were accumulating in 11 eliminate its discharges before 1972, correct? 11 the environment and persistent, would that have 12 MR. COX: Object to the form. 12 been state-of-the-art and satisfied Monsanto's 13 THE WITNESS: The plant was shut 13 duty? 14 down in '71, so, yes, it was done before '72. 14 A 1 have no basis to answer that kind of 15 BY MR. WRIGHT: 15 question; 1 don't know. 16 Q Well, 1 thought part of it was shut down 16 Q So, you don't know whether waiting a 17 in '71 and part of it was shut down in '72? 17 year and a half would have been the proper thing to 18 A Well, solid aroclor, but the liquid 18 do or not? 19 aroclor is '71. 19 MR. COX: Object to the form. 20 Q Okay. Well, I'm not going to rehash 20 BY MR. WRIGHT: 21 what we did last time with the carbon absorption 21 Q Waiting a year and a half to begin 22 and things like that. 22 taking action? 23 Do you really believe that Monsanto used 23 MR. COX: Same objection. Page 66 Page 68 1 all state-of-the-art technology to minimize aroclor 1 THE WITNESS: As 1 stated, 1 have 2 discharges throughout its production history in 2 no basis to answer that; 1 don't know. 3 Anniston -- 3 BY MR. WRIGHT: 4 MR. COX: Object to -- 4 Q Okay. 1 guess you'd agree that in 5 BY MR. WRIGHT: 5 general their duty was to act as quickly as 6 Q -- and -- 6 possible to identify the hazard and then eliminate 7 MR. COX: Sorry. 7 the hazard. Is that fair? 8 BY MR. WRIGHT: 8 MR. COX: Object to the form. 9 Q -- used state-of-the-art to fully 9 THE WITNESS: That's - yes. 10 investigate the extent of its contamination after 10 BY MR. WRIGHT: 11 it became aware of the persistence of PCBs in the 11 Q Now, 1 still don't feel that my original 12 environment around the Anniston plant? 12 question has been answered. And that original 13 MR. COX: Object to the form. 13 question was: Once a responsible manufacturer 14 BY MR. WRIGHT: 14 knows that its chemical has escaped from the plant 15 Q You can answer. 15 and is a potential hazard in the environment, 16 A 1 can't answer throughout production 16 outside of the plant, and is still there, what 17 history. 1 do know that Monsanto moved extremely 17 responsibility does a responsible manufacturer 18 quickly from the development of detection 18 have? 19 technology that allowed the presence in the 19 MR. COX: Object to the form. 20 environment to be determined in roughly the late 20 THE WITNESS: 1 don't know that 1 21 '69, '70 era, up through a very, very, very 21 could answer that question any better than I've 22 aggressive program to - targeted initially to 22 already answered it. 23 eliminate discharges, while continuing to 23 BY MR. WRIGHT: Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Pages 65 - 68 HARTOLDMON0034997 Page 69 Page 71 1 Q Well, with all due respect -- 1 the environment. And if any product that was 2 A Well, 1 mean, you're trying to make me 2 shown, any potential to accumulate in the 3 say something you want me to say, and 1 can't say 3 environment was simply not manufactured, was never 4 anything more than 1 know or honestly believe. 4 approved for manufacture. 5 Q And 1 just want to know what the answer 5 Obviously, a lot of those 6 is to my question, Mr. Brown. The only answer that 6 guidelines were based on what had been learned from 7 1 recall -- and now maybe 1 missed something -- but 7 PCBs over the years, because PCBs were found to be 8 the only answer that 1 recall is, when 1 first 8 stable in the environment. 9 asked the question, you said, well, the 9 MR. WRIGHT: With all due respect, 10 manufacturer has to use state-of-the-art technology 10 I'm going to have to object, non-responsive again. 11 to find out what's going on, basically. And 1 11 BY MR. WRIGHT: 12 understand that. 12 Q The question is not whether you figure 13 But once the manufacturer has used 13 out that it's persisting in the environment; that 14 state-of-the-art technology and knows what's going 14 was an earlier question. 15 on, what duty does a responsible manufacturer have 15 The question that's on the table now is: 16 with regard to its chemicals that have left its 16 Were you ever given any guidelines by Monsanto on 17 plant and are persisting in the environment and may 17 what to do once it's been determined that your 18 be a hazard to people or animals? 18 chemical has escaped from the plant and is 19 MR. COX: Object to the form. 19 persisting in the environment near the plant and is 20 THE WITNESS: You're asking a 20 a potential hazard to the health of humans and/or 21 question that's beyond my knowledge and experience 21 animals? 22 and capabilities. 22 MR. COX: Same objection. 23 BY MR. WRIGHT: 23 THE WITNESS: Guidelines are Page 70 Page 72 1 Q All right. You were never given the 1 developed for ongoing manufacturing operations and 2 tools to answer that question by Monsanto during 2 what's assessed for the future. So, that's what 3 your years as environmental chief at Anniston? 3 I've been intensively involved in. So, this is 4 MR. COX: Object to the form. 4 what's confusing my answer to your question. 5 THE WITNESS: Monsanto has made 5 Now, retroactively, the guidelines 6 available the tools that the best minds could use 6 basically say, you don't manufacture this. And so, 7 at any point in time throughout the period of time 7 for PCBs, manufacturing was stopped. 8 1 was involved. And that included the regulatory 8 1 think what you want me to answer 9 minds and that included the technical minds. 9 is: Were there any guidelines for what you do in 10 MR. WRIGHT: Let me object, 10 that case? And the guidelines on PCBs have been an 11 non-responsive. 11 ongoing, developing -- how do 1 say it? For 12 BY MR. WRIGHT: 12 example, in 1971, the regulatory community and 13 Q Did Monsanto ever give you any 13 Monsanto felt that stopping manufacture of PCBs was 14 instruction or literature or guidance on what a 14 the absolutely most responsible thing that anybody 15 responsible manufacturer should do when its 15 could know to do. 16 chemicals are identified as persisting in the 16 In 1977 or thereabout, when TSCA 17 environment and posing a potential hazard to human 17 came along and established a limit of what was to 18 and animal life? 18 be considered PCB contaminated, fifty parts per 19 MR. COX: Object to the form. 19 million, became the target then, guideline for the 20 THE WITNESS: I've been involved 20 regulatory community and Monsanto and all other 21 over my career in many assessments of chemicals, 21 industries. So, anything that was greater than 22 and every one of these assessments have included 22 fifty parts per million was regulated as PCB 23 tests that would look for potential stability in 23 contaminated. Anything below that was felt to be Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Pages 69 - 72 HARTOLDMON0034998 Page 73 Page 75 1 fine. 1 mean, that was the state-of-the-knowledge, 1 has no responsibility to protect its neighbors from 2 that was the state-of-the-art, 2 hazardous chemicals if a regulator doesn't tell it 3 state-of-the-regulations. 3 to do so? 4 As time changes, that's continued 4 MR. COX: Object to the form. 5 to change. Now, fifty parts per million is viewed 5 THE WITNESS: 1 have to answer that 6 to be a high level. So, it has changed overtime 6 question based on my knowledge today. And 1 7 as more things have been developed. 7 answered it based on from a manufacturer's 8 BY MR. WRIGHT: 8 standpoint and that addresses what you're 9 Q Your understanding is that fifty parts 9 manufacturing or what you may think about 10 per million in a homeowner's yard was viewed as no 10 manufacturing. And, yes, there is a responsibility 11 problem by the regulators? Is that what you 11 and that responsibility is to use state-of-the-art 12 believe? 12 testing. If something is manufactured, 13 A In 1977,'78, yes, that was the 13 communication through MSDS is widely available. 14 established guideline. 14 BY MR. WRIGHT: 15 Q You're not aware of any lower guidelines 15 Q Communication to who? 16 for residential property than fifty parts per 16 A The world, whomever. 17 million? 17 Q Anybody that can -- 18 A Well, it has evolved over later years, 18 A Anybody. 19 but I'm trying to answer you for that timeframe. 19 Q - be exposed to it? 20 Q And that's what I'm asking you: In that 20 A Any - doesn't matter if you're exposed 21 time frame, 1977, 1979, you honestly believe that 21 to it or what. Anybody, period, anybody that wants 22 there were no guidelines for PCB contamination at 22 it. 23 less than fifty parts per million in things that 23 Q So, the burden's on the person -- Page 74 Page 76 1 would come in close contact with ordinary people, 1 A That's a communication tool. 2 like their yard or the food they eat or anything 2 Q All right. 3 else like that? 3 MR. COX: Go ahead and let him 4 A What I'm telling you is that fifty parts 4 finish his question. 5 per million was the guideline that had been 5 BY MR. WRIGHT: 6 established by federal regulations as a part of 6 Q Does the manufacturer have a 7 TSCA, Toxic Substances Control Act. That was 7 responsibility to communicate with the people that 8 accepted by everybody, you know, the regulators, 8 it exposes to a potentially hazardous chemical? 9 EPA, state, as being the guideline that defined PCB 9 MR. COX: Object to the form. 10 contamination. 10 THE WITNESS: Yes. 11 Q What makes you think that in'71 the 11 BY MR. WRIGHT: 12 regulators thought that stopping PCB production was 12 Q Does a manufacturer have a 13 the very best thing that could be done? Have you 13 responsibility to identify the people that are 14 seen any documents that said that? 14 being exposed to its potentially hazardous chemical 15 A No. 15 that has escaped its plant? 16 Q Were you present in any conversations 16 MR. COX: Object to the form. 17 where the regulators told you that? 17 THE WITNESS: When you know of no 18 A No, not in 1971. 18 hazard, the sheer presence is not necessarily 19 Q So, you have no basis for that 19 identified as a hazard. In every event during my 20 statement, other than you think that's probably 20 career, that I'm aware of, when some release from 21 what they were thinking? 21 our facility occurred, that could potentially 22 A Yes. 22 affect people, they were told. 1 was involved 23 Q Is it your testimony that a manufacturer 23 personally in going to the community in one event Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Pages 73 - 76 HARTOLDMON0034999 Page 77 Page 79 1 and notifying the community. 1 BY MR. WRIGHT: 2 BY MR. WRIGHT: 2 Q You didn't see that study? 3 Q That's every release except for PCBs, 3 A Which study was it? 4 correct? 4 Q Either Westinghouse or GE, 1 believe. 5 MR. COX: Object to the form. 5 A No. 6 THE WITNESS: Every release where 6 MR. COX: Object to the form. 7 there was a known potential hazard. 7 BY MR. WRIGHT: 8 BY MR. WRIGHT: 8 Q Did you ever read the ATSDR profile for 9 Q And that did not include PCBs, because 9 PCBs, either the first version or the new version? 10 nobody ever went into the community and warned the 10 A 1 don't really remember. 11 residents about the release of PCBs from Monsanto 11 Q Do you disagree with the federal 12 facility? 12 government that PCBs are a probable human 13 A There was no -- 13 carcinogen? 14 MR. COX: Object to the form. 14 MR. COX: Object to the form. 15 THE WITNESS: There was no known 15 THE WITNESS: Based on my personal 16 hazard. 16 knowledge, 1 see nothing that would support it. 17 BY MR. WRIGHT: 17 BY MR. WRIGHT: 18 Q If a chemical is a probable carcinogen, 18 Q So, the answer is, yes, you disagree 19 is it still your testimony that people that are 19 with the federal government? 20 exposed to that probable carcinogen unwittingly 20 A 1 can't say 1 disagree with the federal 21 don't deserve to be told by the manufacturer so 21 government, because 1 have not --1 don't know what 22 that they can do something about it? 22 report you may necessarily be talking about. 1 23 MR. COX: Object to the form. 23 mean, 1 -- but I'm just answering you based on my Page 78 Page 80 1 THE WITNESS: The presence of a few 1 personal knowledge. 2 parts per billion to million of PCBs, to my 2 Q Did you never hear, during your years as 3 knowledge, has -- I've never seen any documentation 3 environmental chief at Monsanto or thereafter, that 4 that exhibited any hazard from that. I've -- in 4 PCBs were a probable human carcinogen? 5 all epidemiological studies that I've ever seen of 5 A I've heard that. I've also heard to the 6 workers that have worked around much, much higher 6 contrary, too. 7 levels of PCBs for forty and fifty years, these 7 Q Who told you the contrary, Monsanto? 8 epidemiological studies have shown no difference in 8 A Well, 1 remember one particular 9 cancer rates, that 1 have read. 9 presentation from a Dr. Renate Kimbrough. 10 BY MR. WRIGHT: 10 Q Who was paid by Monsanto? 11 Q Well, did you read Monsanto's own study 11 MR. COX: Object to the form. 12 that showed an excess of lung cancer in aroclor 12 THE WITNESS: 1 don't know if she 13 workers? 13 was or not. 14 A No. 14 BY MR. WRIGHT: 15 Q You didn't read the study that showed an 15 Q You don't know that she's been paid by 16 excess of Melanoma in aroclor workers? 16 Monsanto for many, many years now? 17 MR. COX: Object to the form. 17 MR. COX: Object to the form. 18 THE WITNESS: I've not seen that. 18 THE WITNESS: 1 mean, 1 don't get 19 BY MR. WRIGHT: 19 involved in that part of it. 1 don't know that. 20 Q You didn't see the study that showed 20 BY MR. WRIGHT: 21 higher levels of digestive tract cancer in aroclor 21 Q Well, 1 guess my question is, Mr. Brown, 22 workers? 22 as the environmental chief or former environmental 23 MR. COX: Object to the form. 23 chief at the Monsanto Anniston plant, did you never Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Pages 77 - 80 HARTOLDMON0035000 Page 81 Page 83 1 feel an obligation to find out everything you could 1 Q And when did Mr. Kaley come in? 2 find out about these PCBs that you knew and your 2 A Well, prior to him, John Craddock and -- 3 company knew was in the environment, was staying in 3 but 1 mean, this is basically an ongoing thing over 4 the environment, was constantly exposing women and 4 the years. He's made many, many, many trips to the 5 children and old folks and sick people downstream 5 plant. 6 and just across the fence from the Monsanto plant? 6 Q Who has, Bob Kaley? 7 MR. COX: Object to the form. 7 A John Craddock and then followed by 8 THE WITNESS: 1 lost the question. 8 Dr. Kaley. 9 BY MR. WRIGHT: 9 Q Specifically, I'm talking about with 10 Q The question is: Didn't you feel an 10 regard to PCBs, though. 11 obligation to find out everything you could find 11 A And they were specific to PCBs. 1 mean, 12 out from the most valid sources possible -- 12 that was their -- any time they came to the plant, 13 A And we had a number -- 13 it was regarding PCBs. 14 MR. COX: Same objection. 14 Q Well, let's talk about that. Who is 15 THE WITNESS: -- of presentations 15 John Craddock? That's a name I'm not familiar 16 in our plant, both to me and our workers, from our 16 with. 17 representatives who follow this full-time. 1 had a 17 A He was -- he was basically the 18 career besides PCBs. And these presentations 18 coordinator of any PCB technology or dealings or 19 involved people who were paid by Monsanto. 1 mean, 19 regulations or-- prior to Bob Kaley. 20 Dr. Bob Kaley and -- 20 Q He was out of St. Louis, 1 assume? 21 BY MR. WRIGHT: 21 A Yes. 22 Q I'm sorry, you said who weren't paid by 22 MR. WRIGHT: Buddy, is he still 23 Monsanto? 23 around? Page 82 Page 84 1 A Who were. 1 MR. COX: He's not employed. 2 MR. COX: Who were. 2 THE WITNESS: He retired before Bob 3 THE WITNESS: 1 mean, yeah, he came 3 came -- 4 to our facility and gave presentations on the 4 MR. COX: He retired. I'm not sure 5 state-of-the-knowledge on PCBs, as did 5 if he's still alive or not, Larry, 1 just can't 6 Dr. Renate Kimbrough. 6 remember. 7 BY MR. WRIGHT: 7 MR. WRIGHT: Okay. 8 Q Dr. Kimbrough came -- I'm sorry, go 8 BY MR. WRIGHT: 9 ahead and finish your answer and I'll ask you a 9 Q What did he tell you about PCBs? 10 follow-up question. 10 A Nothing more than what I've already told 11 A And, you know, 1 didn't ask her if she 11 you. 1 mean, basically-- 12 was paid by Monsanto, but I'm sure her trip to the 12 Q That they weren't hazardous? 13 plant was paid by Monsanto. 13 A Basically, this was an ongoing tracking 14 Q So, Dr. Kimbrough actually came to the 14 of regulations and -- you know, PCBs, during that 15 Anniston plant and gave a speech to Monsanto 15 period of time, some were still used in 16 workers? 16 transformers and we -- we, across Monsanto and -- 17 A 1 don't remember who all was involved in 17 went through a gradual phase-out of any PCB 18 that presentation, but -- 18 containing electrical device. And all of these 19 Q When was that? 19 were monitored and tracked and annual inventory 20 A -- quite a few. Several years ago. 1 20 reported. And then when one was taken out of 21 can't remember exactly when. 21 service, its disposition tracked and documented and 22 Q Some time after 1994 or'95? 22 this was part of the ongoing program pertaining to 23 A Probably around '95, 1 guess. 23 PCBs. Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Pages 81 - 84 HARTOLDMON0035001 Page 85 Page 87 1 Q What you're describing is the drive to 1 there and continue to expose humans and animals 2 become a PCB-free plant, correct, in the '80s, 2 outside of the Anniston plant unless something was 3 Monsanto decided that it was going to be PCB free? 3 done about them, correct? 4 A Well, 1 think it started in the '70s 4 MR. COX: Object to the form. 5 when we started phasing out any PCB article, you 5 THE WITNESS: Monsanto knew they 6 know, transformer, capacitor. 6 were stable in the environment and the position was 7 Q And the reason Monsanto wanted to become 7 that nothing would be continued to be manufactured 8 PCB free is because PCBs were a potential hazard to 8 that was stable in the environment. 9 humans or animals, correct? 9 BY MR. WRIGHT: 10 MR. COX: Object to the form. 10 Q And Monsanto felt no responsibility to 11 THE WITNESS: The reason to become 11 identify the people that were being exposed to its 12 PCB free was the stability, the negative parts of 12 PCBs, to identify the specific locations of its 13 aroclors had been determined, its stability in the 13 PCBs that it had discharged and that were still 14 environment. And as one could phase out these 14 present in the environment or to communicate the 15 devices and basically get rid of them, you moved to 15 potential hazard to those people who were being 16 the next state-of-technology. 16 exposed or to somehow eliminate the exposure? 17 BY MR. WRIGHT: 17 Monsanto felt no responsibility to do any of those 18 Q But the reason you were phasing them out 18 things? 19 and the reason Monsanto quit making PCBs and the 19 MR. COX: Object to the form. 20 reason the government banned them is because of a 20 THE WITNESS: Yes, it did. 21 concern about hazards to human and animal health? 21 Monsanto communicated to every customer, to every 22 MR. COX: Object to the form. 22 worker, that purchased or used PCBs, they were 23 THE WITNESS: The first was a 23 told, they were stable in the environment and Page 86 Page 88 1 stability in the environment. Had -- 1 informed that the product would be discontinued. 2 BY MR. WRIGHT: 2 BY MR. WRIGHT: 3 Q Yeah, but -- 3 Q But Monsanto refused to warn or 4 A Had PCBs not been stable in the 4 communicate to its neighbors across the fence, who 5 environment, there is no known hazard that would 5 Monsanto knew were being exposed to this stable 6 have caused the phase-out of them. That hazard 6 chemical that was present and was going to stay 7 could have been very well managed. 7 present in their neighborhood? 8 Q Well, part of the hazard is their 8 MR. COX: Object to the form. 9 stability in the environment? 9 THE WITNESS: Monsanto communicated 10 A That was the hazard that caused them to 10 to every person that used aroclor. Monsanto did 11 be phased out. 11 not know the need to communicate to everybody that 12 Q And the problem with them being stable 12 may have lived along a stream that contained a few 13 in the environment is they present a long-term 13 parts per million PCBs. 14 threat to the health of humans and animals because 14 BY MR. WRIGHT: 15 they are present and going to stay present in the 15 Q Well, the numbers that we just looked at 16 environment unless you get rid of them, correct? 16 were not a few parts per million, they were eleven 17 MR. COX: Object to the form. 17 hundred and twelve hundred parts per million in 18 THE WITNESS: Yes. 18 that stream, correct? 19 BY MR. WRIGHT: 19 A At certain points. At one point. 20 Q And so Monsanto knew that they were a 20 Q Well, and at another point, it was seven 21 potential human and/or animal health hazard and 21 hundred and something? 22 that they were present in the environment outside 22 A Very shortly -- short distance from 23 the Anniston plant and they were going to stay 23 that. And that's - that was removed from the Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Pages 85 - 88 HARTOLDMON0035002 Page 89 Page 91 1 stream. 1 sampling there, I'm not that close to it. But 1 2 Q But Monsanto could have discovered 2 can assure you that in 1985, when we did that 3 twenty years ago or twenty-five years ago the - 3 sampling that we talked about earlier, that was the 4 MR. WRIGHT: Is it two hundred 4 locations were agreed on by us, Attorney General, 5 thousand parts per million, Buddy, behind Mars Hill 5 AWI -- or ADEM, at that time, and EPA. We didn't 6 or twenty thousand? 6 have the faintest idea that if we had sampled in 7 MR. COX: Two hundred. 7 that direction, we could have found PCBs. 8 BY MR. WRIGHT: 8 BY MR. WRIGHT: 9 Q -- the two hundred parts per million, 9 Q Sir, Monsanto knew that PCBs were being 10 behind the Mars Hill Baptist Church, twenty or 10 washed out of the landfill and had been washed out 11 twenty-five years ago, had they looked, correct? 11 of the landfill for thirty-five years before 1972 12 MR. COX: Object to the form. 12 and Monsanto knew that those PCBs had migrated and 13 THE WITNESS: Nobody had absolutely 13 were still there in 1972? 14 any knowledge or any reason to go looking at that 14 MR. COX: Object to the form. You 15 point in time that I'm aware of. 15 were through, weren't you? 16 BY MR. WRIGHT: 16 MR. WRIGHT: Yeah. 17 Q Well, what did Monsanto learn in 1995 17 THE WITNESS: You know, you use the 18 that was new knowledge that caused it to go looking 18 word "Monsanto" like it's a person. You're talking 19 and find the PCBs everywhere that it found them, 19 about a lot of people. 20 after 1995? What new knowledge did Monsanto have 20 And to my knowledge - you say 21 that it didn't have in 1972? 21 thirty-five years -- to my knowledge, that area was 22 MR. COX: Object to the form. 22 not used anywhere near thirty-five years. But 1 23 THE WITNESS: Well, basically there 23 can assure you, as honestly as 1 know how, in spite Page 90 Page 92 1 was a lot of new knowledge but, to answer that 1 of what you say looking backwards, that in 1985, 2 question, you've got to get somebody involved in 2 when we sat down there and as honestly and 3 1995. 1 was not involved. 3 sincerely as we could possibly know how, decided 4 BY MR. WRIGHT: 4 where to sample, that never entered anybody's mind 5 Q Well, you were there. 1 mean, you were 5 as a point that we needed to sample. 6 still employed at the Anniston plant, correct, and 6 Now, did somebody some years 7 living in Anniston? 7 previous to that have some knowledge that we were 8 A I'm - 8 not aware of, that's a possibility, but 1 don't 9 Q Or living in Heflin? 9 know who they were and they weren't available to 10 A 1 had an office there, but 1 was 10 us, at the time. All 1 can tell you is that in 11 basically working wherever. 11 1985, there was no attempt to not sample any place 12 Q Well, what's the best knowledge that you 12 where we felt we should sample. 13 have about what was new to Monsanto in 1995 that it 13 BY MR. WRIGHT: 14 did not have in 1972? 14 Q Well, let me ask you this: In all 15 MR. COX: Object to the form. 15 honesty and in all fairness, if Monsanto -- and by 16 THE WITNESS: One thing was the -- 16 Monsanto, 1 mean the decision makers at Monsanto -- 17 let me just address that hot spot per se. Nobody 17 if Monsanto had known or had a reason to know that 18 had the faintest idea that that was there. Nobody 18 PCBs were migrating off of that landfill in 1970 or 19 had the -- any basis for going to that spot in the 19 '71 and had been for a long time prior to that, 20 woods and taking a sample. Till this day, nobody 20 then should Monsanto have tried to figure out where 21 can explain how it was there, that I'm aware of. 1 21 the PCBs ended up that migrated off of the 22 mean, maybe somebody can. 1 can't. 22 landfill? 23 But what led to the eventual 23 MR. COX: Object to the form. Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Pages 89 - 92 HARTOLDMON0035003 Page 93 Page 95 1 THE WITNESS: Had that knowledge 1 MR. COX: Object to the form. 2 been available around the table when we were 2 THE WITNESS: Yes. 3 struggling in 1985 on what to do, yes, we -- the 3 BY MR. WRIGHT: 4 sampling would have been extended on up that 4 Q And those PCBs, common sense would have 5 tributary. 5 told you, wherever they might have gone, are still 6 BY MR. WRIGHT: 6 going to be present, even to this day, at least a 7 Q Should have been extended up that 7 good portion of them, correct? 8 tributary? 8 MR. COX: Object to the form. 9 A It would have been. 9 BY MR. WRIGHT: 10 Q But it should have been? 10 Q Because of the stability in the 11 MR. COX: Object to the form. 11 environment, the PCBs that common sense would have 12 THE WITNESS: What 1 was saying 12 told you migrated off of that landfill, before the 13 was, had that been available to us in 1985 when we 13 sump was put in, are still going to be around 14 were trying to put this plan together, it would 14 wherever they ended up? 15 have. 15 A Yes. 16 BY MR. WRIGHT: 16 MR. COX: Object to the form. 17 Q Would have and should have, is that 17 (WHEREUPON, there was a brief recess.) 18 fair? 18 (WHEREUPON, Plaintiff's Exhibit 20 was marked for 19 MR. COX: Object to the form. 19 identification.) 20 THE WITNESS: I'm answering you 20 BY MR. WRIGHT: 21 from the standpoint of what the intent was in 1985, 21 Q We're just going to kind of skip around 22 when that sampling protocol was put together. Had 22 now. Let me show you a memo that was sent to you 23 that information been known and available around 23 by Robert Ivory in January of '81. Do you remember Page 94 Page 96 1 that table or even thought about, it would have 1 receiving that memo? By the way, this is Exhibit 2 been included in that sampling plan. 2 20 we're talking about. 3 BY MR. WRIGHT: 3 A Well, 1 mean 1 --1 vaguely remember it. 4 Q Was Mr. Taffee still employed in 1985? 4 Q It sampled some material from the HB40 5 A No. 5 sump? 6 Q Was he still in the area? Had he had 6 A Uh-huh. 7 his stroke by then, '85? 7 Q And found a hundred and eight parts per 8 A 1 don't think so. 8 million PCBs in that material, correct? 9 Q So, he was still able to communicate and 9 A Yes. 10 answer questions and give opinions and history and 10 (WHEREUPON, Plaintiffs Exhibit 21 was marked for 11 so forth? 11 identification.) 12 MR. COX: Object to the form. 12 BY MR. WRIGHT: 13 THE WITNESS: Probably. 13 Q And then the second page of that--it 14 BY MR. WRIGHT: 14 actually may not -- actually, why don't we make 15 Q Did he never tell you about the sump at 15 that 21, because I'm not sure that they go 16 the landfill that was collecting PCBs and had to be 16 together, because one is dated in January and the 17 pumped out? 17 other one is dated in April, right? Number 20, the 18 A No. 18 typewritten memo, is dated in January and Exhibit 19 Q Had he told you that the sump in the 19 Number 21, the handwritten document, is dated in 20 drainage from the landfill was collecting PCBs, you 20 April of '81. Is that your handwriting, by the 21 could have employed common sense and figured that 21 way? 22 there were probably PCBs coming out of that 22 A No. 23 landfill before the sump was installed, correct? 23 Q Do you know whose it is on Exhibit 21 ? Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Pages 93 - 96 HARTOLDMON0035004 Page 97 Page 99 1 A 1 believe this was before Cheever. 1 there was any spill or release, that's what it 2 Whoever had that environmental position before 2 was -- that's what was its intent, around that HB40 3 Cheever. 1 believe it was Don Huckabee (phonetic), 3 area. 4 at that point in time. 4 Q And the PCBs would have come from, 1 5 Q Can you read that out loud? If you 5 guess, just fugitives from the sewer? 6 wouldn't mind. 6 A Fugitives from the--the separator 7 A Jim Campbell of Chemical Waste 7 device, itself, the big tank in the ground, if you 8 Management informs that the HB sump material was 8 will. 9 greater than a hundred parts per million, PCB 9 Q Right. But the tank was cleaned out in 10 sample has been okayed by their-- let's see -- 10 '71 or '72? 11 lab, and that they are ready to accept it. 11 A It was emptied. 12 Roland -- let's see -- to Roland, ask 12 Q Emptied. And then it accumulated 13 him to get with regional purchasing and get 13 material for the next eight or nine years? 14 purchase order or -- something tomorrow. 14 A From the HB40 unit, yes. 15 Q Now, this is some nine years after 15 Q Would that have included water from the 16 manufacture of PCBs was halted in Anniston when 16 sewers? 17 this hundred plus parts per million was found in 17 A No. 18 HB40, sump material, correct? 18 Q Where did this material that ended up in 19 A And that was the previous aroclor sump 19 the sump kit, where did it come from? 20 that the HB40 was routed to and used as a separator 20 MR. COX: PCB material? 21 vessel. And as it was cleaned out, it was analyzed 21 MR. WRIGHT: Well, the material 22 for any PCBs and then disposed of accordingly. 22 that contained PCBS, yeah. 23 Q I'm sorry? 23 THE WITNESS: When you say the Page 98 Page 100 1 A And disposed of accordingly. 1 sewers -- 2 Q Okay. Is this the only time that sump 2 BY MR. WRIGHT: 3 was ever cleaned out? 3 Q Right. 4 A It was phased out not long thereafter. 4 A --1 was assuming you were referring to 5 Q Between the end of production of 5 sewers associated with aroclor manufacturing; is 6 aroclors in '81, had it been cleaned out any other 6 that correct? Maybe you need to define what you 7 times? 7 mean better. 8 A 1 don't remember, but it's not likely, 8 Q Yeah, well, 1 probably can't, because 1 9 because any accumulation in it was extremely slow. 9 don't know what 1 mean. Let me just ask it, 10 Q Was the sump cleaned out when the 10 generally. Where did the material that ended up in 11 aroclor plant was shut down? 11 the HB40 sump, where did it come from? 12 A Yes. 12 MR. COX: Object to the form. 13 Q So, this is new material that's 13 THE WITNESS: 1 would assume it 14 accumulated PCBs, even though production has been 14 came from fugitives that were in that tank, itself. 15 stopped? 15 What's referred to as the sump. 16 A Yes. When 1 say "cleaned out," it was 16 BY MR. WRIGHT: 17 not flushed to a - it was - it was empty. And 17 Q Right. Yeah, we're not communicating. 18 any inlet sewers from the aroclor plant were 18 Right now I'm not asking specifically about the 19 basically taken out at that point in time. And so, 19 PCBs, I'm just asking about, what is the stuff that 20 it was -- this particular separator device that was 20 is the sump pit material? 21 then used to take any water from the HB40 area so 21 A From the HB40 plant. 22 it could be used as an oil water separator to 22 Q Is it everywhere? 1 mean, does the 23 separate that. Was a capture device in the event 23 whole HB40 plant funnel to the sump area? Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Pages 97-100 HARTOLDMON0035005 Page 101 Page 103 1 A It was set up so that the area was 1 Q Could 1 see that back? 2 contained, and if there was any spill or release, 2 Now, it gives an agenda for a meeting. 3 it would be tunneled to this tank. 3 It describes the objectives of the meeting and 4 Q What about water, does water go into 4 delineates the landfills and the surface 5 that tank or did water go into that tank? 5 impoundments and the storage areas and the 6 A A small amount, not -- the rainfall -- 6 satellite storage areas. And it delineates in 7 this was an area underneath the structure 7 table one, has areas of concern, the product 8 associated with HB40. And any water that would 8 storage tank spillage area, where was that? 9 have been directed in that way would have been a 9 A I'm assuming that could be any storage 10 very, very small amount. In other words, any -- 10 tank where any spill could have potentially 11 there was no processed water and rainfall couldn't 11 occurred. 12 fall in there. So if-- but if there was, you 12 Q Snow Creek PCB contamination area and 13 know, fugitive water that got into there, it would 13 former off-site landfill are the three areas of 14 go into that tank. 14 concern listed, correct? 15 1 say fugitive from the standpoint of 15 A Yes. 16 water, drip or leak or something, steam -- steam 16 Q The off-site landfill, would that be the 17 condensate. 17 landfill that we've been referring to across the 18 Q Going back to, we talked, 1 think, in 18 road and up the hill from the plant? 19 our earlier deposition, about the reports that went 19 A No. 20 to ADEM on the monthly reports that gave a daily 20 Q Or is that the westend landfill, 1 21 summary of the PCBs. Do you recall that? 21 guess? 22 A 1 recall seeing it, yes. 22 A That would have been the westend 23 Q Do you know why only twelve forty-two 23 landfill. Page 102 1 and twelve fifty-four were reported to the state 1 2 and not twelve twenty-one or any other aroclor? 2 3 A No, 1 do not. 3 4 Q You never heard? 4 5 A Was not a part of it and have never 5 6 heard. 6 7 (WHEREUPON, Plaintiffs Exhibit 22 was marked for 7 8 identification.) 8 9 BY MR. WRIGHT: 9 10 Q What is Exhibit Number 22? 10 11 A It's the EPA letter to Robert Jones, 11 12 concerning doing a RCRA facility assessment. 12 13 Q And what's the RCRA facility for? 13 14 A Resource Conservation and Recovery Act, 14 15 RCRA, is the set of laws that are applied to 15 16 landfill-type facilities. 16 17 Q So, that related to the landfill? 17 18 A Well, this was involving a facility 18 19 assessment, analyzing any potential what was called 19 20 SWMU, S-W-M-U, solid waste management units, and 20 21 any other area of concern, basically to address any 21 22 potential site that could have had any past or 22 23 ongoing release of any hazardous constituent. 23 Page 104 MR. COX: Can 1 interject, because otherwise that's wrong, 1 think. MR. WRIGHT: Okay. MR. COX: Jerry, didn't they identify or attempt to identify some old phosphate landfill and name that as an area of concern, because at the time the westend landfill was still owned by the power company? THE WITNESS: Yeah. But as 1 recollect, it was a phosphate --1 mean, it was owned by the power company, but -MR. COX: 1 thought that was the landfill they thought that was between Clydesdale and that corner of the property, at the corner of Clydesdale and 202, on-site. That's okay. 1 think the actual RFA and then the -THE WITNESS: 1 would have to go to the document and see. MR. COX: -- comments and the RCRA permit, 1 think clarify that. Sorry. MR. WRIGHT: That's okay. BY MR. WRIGHT: Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Pages 101 -104 HARTOLDMON0035006 Page 105 Page 107 1 Q Was a submittal ever prepared for this, 1 another series of documents coming to him. 2 in response to this Exhibit Number 22? 2 Q Relating to what? 3 A The way 1 remember this series of events 3 MR. COX: Object to the form. 4 is that this was done under contract by EPA with a 4 THE WITNESS: Whatever his request 5 company called A. T. Kearney. 5 was. 6 Q Who? 6 BY MR. WRIGHT: 7 A A. T. Kearney. 7 Q Well, disposal to landfill follows. But 8 MR. COX: K-E-R-N-E-N-Y, 1 think. 8 what's disposal to landfill? 9 THE WITNESS: K-E-A-R-N-E-Y. They 9 MR. COX: Object to the form. 10 came on-sight and did their investigation and 10 THE WITNESS: 1 have to assume that 11 prepared a document that had to be later corrected. 11 his request was pertaining to anything about PCBs 12 And 1 think that document was typically referred to 12 that had gone to the landfill. 13 as the RFA. 13 BY MR. WRIGHT: 14 MR. WRIGHT: Mark that as our next 14 Q Okay. Do you know why Mr. Savage was 15 exhibit. 15 asking those questions in '75? 16 (WHEREUPON, Plaintiffs Exhibit 23 was marked for 16 A No, 1 do not. 17 identification.) 17 Q You don't have any recollection of that? 18 BY MR. WRIGHT: 18 A 1 don't remember. 19 Q Here is a memo from Mr. Taffee to 19 MR. WRIGHT: Mark that as our next 20 J. R. Savage in St. Louis. And you're the first 20 exhibit. 21 copy recipient of this November 6th, 1975 memo. 21 (WHEREUPON, Plaintiffs Exhibit 24 was marked for 22 And it's entitled PCB disposal data, JRS requests 22 identification.) 23 10-31-75. Apparently, Mr. Savage requested some 23 BY MR. WRIGHT: Page 106 Page 108 1 information and Mr. Taffee is forwarding some 1 Q Let me hand you Exhibit Number 24. And 2 information. And he indicates that the effluent to 2 this is a document dated January 18th, 1979. 3 Snow Creek is reported through October '72 and 3 Again, you were a copy on it. Or 4 presumably he attached it. Item number two, data 4 actually, it's addressed to you. You're not a copy 5 on fish samples taken by Gunning and Sutkus are 5 on it, it's addressed to you. From Mr. Glasgow. 6 enclosed. 6 And it again, documents PCBs in HB40 oil in 7 You're familiar with those materials, 7 Therminol from HB40 system and then two hundred and 8 correct? 8 eighty parts per million into the sump. 9 A I'm familiar-- 9 Is that the same sump that presumably we 10 Q Gunning and Sutkus -- 10 were talking about in '81, as well? 11 A -- with their study, yes. 11 A That's the only sump I'm aware of, so, 12 Q And then he said, we can find no 12 yes. 13 indication here of any sediment analyses and no 13 Q That would indicate that PCBs continued 14 data here on receiving water analyses. What does 14 to accumulate in the sump there? 15 that mean? 15 A Well - 16 A Receiving water is water that you 16 MR. COX: Object to the form. 17 normally bring in and use as -- and indicates the 17 BY MR. WRIGHT: 18 plant is city water, that's -- or 1 -- well, I'm 18 Q Or continued to accumulate in the sump? 19 guessing that's what he means. 19 A Well, this was prior to that other. 20 Q What's this handwritten note down here 20 Q Right. So, the sump was cleaned out in 21 refer to? 21 '78 or '79 -- well, '78, 1 guess, December of '78, 22 A It says, Jim, disposal to landfill is 22 and found to have two hundred and eighty parts per 23 false. So, he's basically saying there would be 23 million PCBs, and it was cleaned out again in '81 Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Pages 105-108 HARTOLDMON0035007 Page 109 Page 111 1 and found to have a hundred and eight parts per 1 credit for discovering the spring with the brown 2 million PCBs. So, doesn't that tell you that PCBs 2 material coming out of the landfill, correct? 3 continued to accumulate? 3 A The work was started some time before 4 MR. COX: Object to the form. 4 this, the work on contacting Gunning --1 mean, 5 THE WITNESS: It doesn't tell me 5 excuse me. Geraghty and Miller, to start the 6 that it continues to accumulate, it tells me that 6 boring work, as 1 remember, in 1979. And in fact, 7 it's still removing fugitive amounts from the sump. 7 we start discussing placement of monitoring wells, 8 BY MR. WRIGHT: 8 and that was prior to -- prior to these 9 Q Do you not remember any leaching from 9 discussions. 10 the landfill during your tenure as the 10 But what he refers to here, brown algae, 11 environmental head there at Anniston? 11 that's nothing more than you see in any wet-weather 12 A Of the PCBs? 12 spring that's basically stagnant. That was not an 13 Q Well, of anything? 13 indication of contamination. 14 A The primary thing 1 can remember is 14 Q Well - 15 associated with the ground water study that we 15 A And that was not -- 16 initiated in '79, where we did many hundreds of 16 Q Well, let's look at the Geraghty and 17 borings to study ground water movement from the 17 Miller report, which is dated April of 1980. Or 18 landfill and -- 18 actually, this is just their proposal. I'm not 19 Q Was that as a result of a discovery of 19 going to mark this, but I'll reference it as 20 leaching from the landfill? 20 DSW073245. Geraghty and Miller gives background 21 A And 1 started to say, on the westside, 21 for this problem. It talks about in early '79, 22 there was a wet-weather spring that was discovered 22 however, plant personnel noticed a discoloration in 23 to contain some leachate. And so we did a study 23 water emerging from a small spring at the base of Page 110 Page 112 1 that started in '79 and then continued continuously 1 the landfill. 2 in phases over the next several years to study and 2 A That's correct, a - 3 address that kind of concern. 3 Q Subsequent analysis of the water showed 4 Q Who identified that leaking from the 4 concentrations of organo-phosphate in the range of 5 landfill? 5 from three hundred to five hundred PPM. The spring 6 A Probably Taffee. 6 discharge, estimated at from ten to twenty gallons 7 Q In fact, wasn't it a state 7 permit minute, flows over land a short distance 8 representative? 1 say "state representative". Not 8 before entering Snow Creek, which runs parallel to 9 an elected official, but a representative from the 9 the highway into Anniston. 10 Department of Public Health? 10 A That's correct. 11 A But 1 don't remember specifically how, 11 Q Don't you think that the gentleman from 12 you know, the events that triggered the study that 12 The Department of Public Health is talking about 13 was started but, you know, it's possible it was 13 the same spring and the same discoloration that the 14 noted on an inspection, 1 just don't remember. 14 Geraghty and Miller people are talking about? 15 Inspections were done on a very routine basis. 15 A The brown algae is not. Okay? But 16 MR. WRIGHT: Mark that as our next 16 this -- there was only one site, so, yes, we're 17 exhibit. 17 talking about the same site. 18 (WHEREUPON, Plaintiffs Exhibit 25 was marked for 18 MR. WRIGHT: Let's mark that. 19 identification.) 19 (WHEREUPON, Plaintiffs Exhibit 26 was marked for 20 BY MR. WRIGHT: 20 identification.) 21 Q Here is a memo from - a state document 21 BY MR. WRIGHT: 22 from the Department of Public Health, from Darryl 22 Q Let me hand you Exhibit Number 26. And 23 Baker to Alfred Chipley. And Mr. Baker claims 23 this is a memo to you. And I'll just read it. Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Pages 109-112 HARTOLDMON0035008 Page 113 Page 115 1 It's short. And then I'm going to ask you what 1 discharge only so much suspended solids to the city 2 it's about. This is from J. B. Moon at Anniston. 2 under the permit. Are you familiar with the 3 Who was J. B. Moon in February of 1980? 3 clarifier? 4 A He would have been manufacturing 4 Q Yes. 5 superintendent. 5 A I'll just draw something for 6 Q Would he have been your supervisor or 6 illustration. But a clarifier typically operates 7 was he a peer of yours, 1 guess? 7 in some sort of equilibrium where the biological 8 A Changed from supervisor to peer in 1980. 8 solids settle and water overflows the top. 9 Q At this time, was he a supervisor? 9 The upset condition that he's talking 10 A Probably my supervisor, at that point, 10 about is a condition that causes this sludge 11 that early in '80. 11 blanket to rise, therefore discharging more solids 12 Q It sounds like he's your supervisor in 12 to the city POWthan could be accepted under the 13 the body of this memo. It says, quote, "Our 13 permit. 14 current solids problems in waste treatment are a 14 When this blanket rose and did that, you 15 major concern to me at the moment. 1 feel that a 15 basically had to shut down. So, what he is talking 16 somewhat fresh approach must be taken to analyzing 16 about here is some way of predicting and 17 this problem. 17 identifying factors that would cause this blanket 18 1 know that you have considerable 18 to rise and overflow. 19 background in this area and also have developed 19 (WHEREUPON, Plaintiffs Exhibit 27 was marked for 20 natural biases. Please, try to put aside those 20 identification.) 21 biases and look at our existing data to see if 21 MR. WRIGHT: Let's mark this. 22 there are clues to predict when we are headed for 22 BY MR. WRIGHT: 23 upsets. 23 Q Let me show you these. There's two Page 114 Page 116 1 Our approach must change from one 1 analyses from 1988 by EIRA, Environmental 2 of telling people that they have a problem to that 2 Industrial Research Associates in May of'88, do 3 of telling them, one, they are headed fora 3 you know where those samples came from or what they 4 problem, and what is this causing this direction, 4 are? They found fifty-eight thousand, five hundred 5 and two, how, once the problem materializes, it can 5 micrograms per kilogram of PCB twelve sixty or 6 be readily corrected. 6 aroclor twelve sixty in something in 1988 and I'm 7 Please, document to me your plans 7 wondering what it was. 8 in developing a new approach to solids problems. 8 A That would be fifty-eight parts per 9 J. B. Moon." 9 million or fifty-eight thousand parts per billion. 10 What was he talking about? 10 1 don't know. Oh, me. 11 A Okay, in biological waste treatment 11 MR. COX: The micrograms per 12 plant, the -- obviously, the basis for a biological 12 kilogram would indicate it's a solid or liquid, 13 treatment plant is organisms, organisms that 13 Jerry. 14 biodegrade or consume or eat the waste, as you 14 THE WITNESS: Kilogram typically 15 will. 15 shown (phonetic) - 1 see absolutely nothing that 16 The biological organisms appear in the 16 gives me a clue. 17 waste treatment plant as suspended solids. As they 17 Are you sure this was associated 18 eat and consume the waste water or the waste 18 with our facility? 19 constituents in the water, the biological organisms 19 MR. WRIGHT: Yeah. It would have 20 grow and form more. So, they have to be removed 20 been - 21 over on some period of-- some basis. 21 MR. COX: Is it part of a bigger 22 Okay, the discharge limit to 002 carried 22 report? 23 a suspended solids limit, so that one could 23 MR. WRIGHT: 1 don't think so. Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Pages 113-116 HARTOLDMON0035009 Page 117 Page 119 1 BY MR. WRIGHT: 1 THE WITNESS: Really look forward 2 Q But anyway, yeah, I'm pretty sure it's 2 to it. 3 your facility, but 1 don't know anything more abou : 3 (WHEREUPON, the deposition was concluded.) 4 it. 4 5 A 1 can never remember having worked withi 5 6 that laboratory there. 6 7 Q Okay. 7 8 A It looks like two separate samples. 8 9 Q 1 think -- 9 10 A This is some solid sample from 10 11 someplace, and 1 absolutely don't know where it 11 12 would be from. 12 13 Q All right. 13 14 A Yeah, 1 mean, 1 was just looking at 14 15 their location there. 15 16 Q Where are they? 16 17 A St. Rose, Louisiana. 17 18 Q What date is that? Maybe 1 can pin it 18 19 down. 19 20 A It's '88, 4-26-88. 20 21 Q Oh, let me ask you. This is a question 21 22 I've been meaning to ask. Do you know anything 22 23 about the Bass lawsuit against Monsanto in the 23 Page 118 1 '60s? 1 CERTIFICATE 2 A Only that that 1 was told, you know. 2 STATE OF ALABAMA) 3 That happened before 1 was out of college. And 1 3 CALHOUN COUNTY ) 4 heard some few comments about it. But so far as 4 5 any, you know, real specific things, no. 5 1, SAMANTHA E. NOBLE, a Court Reporter 6 Q What did you hear about it, because 1 6 and Notary Public in and for The State of Alabama 7 haven't heard much about it, at all, so any insight 7 at Large, duly commissioned and qualified, HEREBY 8 could be helpful? 8 CERTIFY that the within named witness, JERRY BROWN, 9 A 1 don't know that 1 could tell you 9 who was made known to me, was first duly sworn to 10 anything. 1 just know that there was such. 1 10 testify the truth, the whole truth, and nothing but 11 mean, that's basically all 1 know. 11 the truth in the cause aforesaid; that the 12 Q Where was it filed, do you know? 12 testimony then given by him was by me reduced to 13 A 1 don't know. 13 shorthand in the presence of said witness, 14 Q Do you know where it was pending? 14 afterwards transcribed upon a computer, and that 15 A 1 have no idea. 15 the foregoing is a true and correct transcript of 16 Q What happened to it? 16 the testimony given by him as aforesaid. 17 A 1 have no idea. 17 1 FURTHER CERTIFY this deposition 18 MR. WRIGHT: Why don't we go off 18 was taken at the time and place in the foregoing 19 the record. 19 caption specified, and was concluded without 20 (WHEREUPON, there was discussion off the record.) 20 adjournment. 21 MR. WRIGHT: 1 guess, Mr. Brown, 21 1 FURTHER CERTIFY that 1 am not a 22 I'll reserve the rest of my questions until we get 22 relative, counsel, or attorney for either party, or 23 together again in Birmingham. 23 otherwise interested in the outcome of this action. Page 120 Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Pages 117-120 HARTOLDMON0035010 Page 121 1 ........................................................................... 2 IN WITNESS WHEREOF, 1 have hereunto 3 set my hand and affixed my seal at Anniston, 4 Alabama, on this the 2nd day of March, 2001. 5 6 7 8 9 10 SAMANTHA E. NOBLE 11 Notary Public in and for 12 Alabama at Large 13 14 15 MY COMMISSION EXPIRES: 11-14-2001. 16 17 18 19 20 21 22 23 Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) Page 121 HARTOLDMON0035011 [&- 80s] Transcript Word Index & & 1:1,1 2:1,1 7:22 28:4 49:5 0 0001 49:12 001 9:16 43:12 45:17 56:8,22 002 43:13 45:20 114:22 005 44:4 56:8 006 44:4 56:8 0440 1:1___________________ 1 1 13:7,16,18 10:40 1:1 1000 1:1 1010 1:1 102 3:21 10-31-75 105:23 105 3:22 107 3:23 11 3:10 7:22 13:2 110 4:1 111 1:1 11-14-2001 121:15 112 4:2 115 4:3 12 3:11 7:22 34:2 45:18 1-2 3:3 1201 45:18 120-121 3:8 12th 35:2 13 1994 3:12 7:22 8:9,15,16 9:15 82:22 43:21,22 44:3 45:8,9 1995 14 89:17,20 90:3,13 3:13 42:5,11,12 44:5,7 46:1 1st 49:9,22 51:5 56:19 1:1___________________ 15 2 3:14 49:5,13,17 51:5 52:6 16 20 3:19 95:18 96:2,17 3:1549:5,14,17 17 3:16 53:18,19,22 54:3,7 2001 1:1 121:4 202 55:15 18 104:15 20th 3:17 55:5,10,15 18th 108:2 19 3:18,18 57:17,21 1935 2:1 21 3:20 96:10,15,19,23 22 3:21 102:7,10 105:2 23 64:4,8,14 1961 39:19 1970 67:4 92:18 1971 3:22 37:12,16 105:16 24 3:23 37:18,19,20 107:21 108:1 25 4:1 39:6 110:18 67:5 72:12 74:18 1972 65:11 89:21 90:14 1974 7:1449:19 1975 91:11,13 26 4:2 112:19,22 27 4:3 115:19 2nd 121:4_________________ 105:21 1977 3 72:16 73:13,21 3 1979 31:13 73:21 108:2 111:6 30 1980 6:8 111:17 113:3,8 3-4 1980s 3:4 7:15 35203-3200 1981 2:1___________________ 8:12 44:4 50:14 1984 8:12 1985 7:10 55:17 57:13 58:1,3 91:2 92:1,11 93:3,13,21 94:4 1988 49:19 116:1,6 1989 65:3 1990 4 43:10 400 1:1 2:1 42 3:13 4-26-88 117:20 49 3:14,15 4 7:11 5 5 18:3 43:10 44:6,21 53 3:16 55 3:17 5-6 3:5______________________ 6 6 6:8 23:22 43:10 44:3,6,21 60s 118:1 61 38:22 66 14:1 69 20:16 66:21 6th 105:21___________________ 7 7 3:10,11,12 70 66:21 70s 22:10 44:13 85:4 71 65:14,17,19 74:11 92:19 99:10 72 21:1265:14,1799:10 106:3 73 21:12 74 48:22 75 107:15 77 15:14 22:5 78 73:13 108:21,21,21 78701 1:1 79 30:9 108:21 109:16 110:1 111:21___________________ 8 80 113:11 80s 22:11 85:2 Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) HARTOLDMON0035012 [81 - aside] 81 44:5 49:10 50:18,22 95:23 96:20 98:6 108:10,23 8-119 3:7 83 49:11,13 85 94:7 88 48:22 116:2 117:20 9 95 3:19 82:22,23 96 1:1 3:20_________________ a a.m. 1:1 able 60:7 94:9 absence 9:7 absolutely 32:9 72:14 89:13 116:15 117:11 absorption 65:21 accept 97:11 accepted 74:8 115:12 accidental 61:2,6,7,8 accumulate 71:2 108:14,18 109:3,6 accumulated 98:14 99:12 accumulating 67:10 accumulation 32:7 98:9 acid 36:14 act 9:3,4 68:5 74:7 102:14 action 5:6,19 67:22 120:23 actual 26:11 104:16 addition 28:5 address 61:1790:17 102:21 110:3 addressed 61:4 108:4,5 addresses 75:8 adem 91:5 101:20 adjacent 17:16 adjournment 120:20 administration 27:10,12 administrative 27:22 affect 76:22 affixed 121:3 afford 16:18 aforesaid 120:11,16 afraid 6:13 agenda 103:2 aggressive 66:22 aggressively 67:8 ago 82:20 89:3,3,11 agree 68:4 agreed 91:4 agreement 1:1 ahead 13:17 22:21 76:3 82:9 aid 29:18 air 39:22 40:2,17,18,20,23 41:2,3,3,6,7,9,10,10,12,23 airline 40:21 al 1:1 al0001201 56:5 all 201 43:5 alabama 1:1,1,1 2:1 5:10 120:2,6 121:4,12 alfred anymore 110:23 67:8 algae anyplace 111:10 112:15 14:7 alive anyway 84:5 117:2 allow apparently 67:6 13:8 31:9 39:3 105:23 allowed appear 66:19 14:1738:1939:18 114:16 allows appearing 63:19 1:1 2:1 alloy appears 38:13,14 9:18 24:7 33:19 34:7 37:16 altogether 37:20 38:1 40:17 41:12,21 22:8 application amount 55:17 57:10 41:4 101:6,10 applied amounts 63:3 102:15 109:7 approach analyses 113:16 114:1,8 106:13,14 116:1 approved analysis 57:6 71:4 10:18 12:3,10 48:23 112:3 approximately analyzed 1:1 7:14 29:5 48:23 57:22 58:8 97:21 april analyzing 44:4 96:17,20 111:17 102:19 113:16 area animal 26:1,8 28:8 30:14,15 33:7,8 70:18 85:21 86:21 33:20 34:1 91:21 94:6 animals 98:21 99:3 100:23 101:1,7 69:18 71:21 85:9 86:14 102:21 103:8,12 104:6 87:1 113:19 anniston areas 1:1 5:9 7:4 58:5 66:3,12 103:5,6,7,13 70:3 80:23 82:15 86:23 aroclor 87:2 90:6,7 97:16 109:11 9:22 10:20 12:14,21 17:15 112:9 113:2 121:3 17:16,17,18 18:12 19:12,19 annual 20:9,13 21:9 22:5 24:20 84:19 25:11,21 26:15,21 27:1 answer 28:6 34:5 35:3,6,16 36:12 11:7 17:11 20:12 30:4 44:8 36:15 38:16 39:7,20 41:17 48:18 53:13 66:15,16 67:14 65:18,19 66:1 78:12,16,21 68:2,21 69:5,6,8 70:2 72:4 88:10 97:19 98:11,18 100:5 72:8 73:19 75:5 79:18 82:9 102:2 116:6 90:1 94:10 aroclors answered 85:13 98:6 68:12,22 75:7 arrival answering 38:20 79:23 93:20 art answers 62:20 63:2 65:10 66:1,9 5:16,18 67:12 69:10,14 73:2 75:11 anybody article 64:17 72:14 75:17,18,21,21 85:5 anybody's aside 92:4 49:17 113:20 Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) HARTOLDMON0035013 [asked - bunch] asked aware (cont.) bed bob 5:14 18:1 30:3 62:9 69:9 90:21 92:8 108:11 15:10 16:8,15 81:20 83:6,19 84:2 asking awi beds body 40:4,6 51:19 63:9 69:20 91:5_____________________ 15:9 39:4 113:13 73:20 100:18,19 107:15 b behalf boiler assessed 72:2 assessment 102:12,19 assessments 63:2 70:21,22 assistance 29:18 associated 37:21 100:5 101:8 109:15 116:17 associates back 8:8 9:11 11:19 12:19 17:21 25:16 30:18 31:1 34:23 36:17,18,18 37:3 42:8,14 43:11 44:9,22 46:1,4 56:17 1:1 2:1 beings 67:6 believe 20:16 35:6 60:4 61:20 59:4 101:18 103:1 65:23 69:4 73:12,21 79:4 45:11,12,13,1457:7 boring 111:6 borings 109:17 born backfilled 22:22 backflow 31:22 32:1,12 background 16:21 18:3 33:5 111:20 97:1,3 64:7 best borrow 6:19 22:12 44:8 62:11 63:8 10:9 22:23 23:5,6 63:10 67:4 70:6 74:13 bottoms 90:12 30:23 better box 1:1 2:1 116:2 association 113:19 backwards 59:18 assume 16:10 19:2 21:1825:1 39:5 92:1 baffle 16:13,14 19:5 20:19,20 52:9 64:10,13 107:10 assuming 83:20 100:13 baffles 16:17 baker 46:14 49:9 100:4 103:9 assumption 110:23,23 banned 46:22 assure 85:20 baptist 91:2,23 asterisk 89:10 barber 24:9 26:8 35:20 53:17 68:21 100:7 beyond 34:12 69:21 biases 113:20,21 big 99:7 bigger 11:8,10 116:21 bill 28:23 29:2,2,6,8,17 billion 10:8,10,11,15,15 11:13,15 14:6 31:10 32:12 boxes 13:9,1031:6 break 42:14 brick 37:4 brief 17:20 42:4 55:4 95:17 briefly 59:2 bring 34:23 106:17 broad 52:14 atsdr 79:8 attach 29:9,14 bare 33:7,8 base 11:1859:1278:2 116:9 biodegrade 114:14 biological 62:10 64:17 brought 29:20 30:18 54:5 brown 53:16 attached 106:4 attempt 62:11 92:11 104:5 attorney 1:1 7:10 58:8 91:4 120:22 attorneys 2:1 austin 1:1 automated 41:7 available 62:20 70:6 75:13 92:9 93:2 111:23 49:16 114:11,12,16,19 based 59:15 71:6 75:6,7 79:15,23 basically 6:18,21 13:12,14 14:3,7,15 15:15 16:17 23:14,15 29:2 30:22 32:15 35:15,19 40:12 44:21 47:1 61:1 64:1 69:11 72:6 83:3,17 84:11,13 85:15 89:23 90:11 98:19 102:21 106:23 111:12 115:7 bird's 18:2 birmingham 2:1 118:23 bit 12:15 24:9 26:8 black 20:2,19 31:19 blank 44:10 47:8 115:15 118:11 basins 53:8 blanket 23:10 basis 115:11,14,17 blanks 1:1 3:6 8:1,7 20:2 42:9 69:6 80:21 111:1,10 112:15 118:21 120:8 brown's 6:6 buddy 34:22 52:22 83:22 89:5 building 2:1 16:22,23 17:1,6 18:9,10 18:11,12,14,15,20,20 19:12 26:1627:5,7,11,12,14,16 27:17,20,22 28:1,3,4,7,9 37:1,3 39:6,8,10,11,22 40:5 40:9,13 buildings 93:13,23 avenue 1:1,1 aware 7:2 41:3 49:18 59:23 60:2 66:11 73:15 76:20 89:15 46:11 47:15 48:12,19 50:5 50:17,18 67:14 68:2 74:19 90:19 110:15 114:12,21 bass 117:23 52:19,23 blocking 31:22,23 blow 45:11 57:7 16:20,21 18:2,6 24:9 25:17 built 17:6,14,1627:2,11 bunch 21:23 24:11 54:4 Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) HARTOLDMON0035014 [burden's - conservation] burden's 75:23 burns 31:5 32:22______________ c calhoun 120:3 call 14:2 18:8,8 19:13 59:14 called 18:22 60:22 102:19 105:5 Campbell 97:7 cancer 78:9,12,21 capabilities 69:22 capacitor 85:6 caption 3:3 120:19 capture 10:4 14:3,4 98:23 captured 14:5,6,7 31:10 car 36:7 39:5 carbon 65:21 carcinogen 77:18,20 79:13 80:4 career 63:1 70:21 76:20 81:18 carried 36:12 114:22 cars 24:22 25:18 case 1:1 72:10 catchment 23:10 categories 6:12 7:16 category 63:12 caught 27:10 cause 115:17 120:11 caused 86:6,10 89:18 causes 115:10 causing 114:4 cell 15:20,21 cells 54:15 certain 41:3 88:19 certificate 3:8 certify 120:8,17,21 cessation 7:3 chamber 20:4 change 73:5 114:1 changed 38:14 73:6 113:8 changes 73:4 charge 29:2 checked 48:14,19 51:21 cheever 55:18 97:1,3 chemical 50:16 59:18 62:6 68:14 71:18 76:8,14 77:18 88:6 97:7 chemicals 60:9 62:2 69:16 70:16,21 75:2 chemtrec 60:23 chief 7:13 70:3 80:3,22,23 child 64:18 children 65:4 81:5 chipley 110:23 chlorinator 34:16 35:18 chlorinators 36:2 church 23:7 89:10 city 106:18 115:1,12 claims 110:23 clarifier 115:3,6 clarify communicate 104:21 76:7 87:14 88:4,11 94:9 dark communicated 2:1 87:21 88:9 clay communicating 22:1,22,22 23:1,2,2,15,17 100:17 28:19 communication clean 75:13,15 76:1 9:2,4 15:8 16:7 22:4,5 community 28:13 60:9 72:12,20 76:23 77:1,10 cleaned compacted 20:7 32:15 97:21 98:3,6,10 22:3 98:16 99:9 108:20,23 company cleaning 1:1 81:3 104:8,11 105:5 15:13 20:21 30:16 composite clock 46:9,12,17,19 47:4,6 48:10 47:2 50:3 51:23 close composition 20:2 30:7 74:1 91:1 38:14 closed compress 27:4 28:6 40:12 41:2,4 clue compressor 116:16 41:22,23 clues computer 113:22 42:15 120:14 Clydesdale concentrations 15:11 19:23 56:20,22 112:4 104:13,15 conceptually cma 47:17 59:17,19,21,23 60:21 61:17 concern cod 85:21 102:21 103:7,14 50:14,15,1651:1 104:6 110:3 113:15 collected concerning 49:23 50:1 102:12 collecting conclude 94:16,20 35:19 college concluded 118:3 119:3 120:19 combined conclusion 44:19 11:4 coming condensate 8:7 94:22 107:1 111:2 101:17 commencing condense 1:1 41:5 comments condition 104:20 118:4 29:16 115:9,10 commission conference 121:15 27:1428:11 commissioned confusing 120:7 72:4 commissioner congress 1:1 1:1 common connection 44:14 53:6 94:21 95:4,11 13:14 commonly conservation 12:22 102:14 Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) HARTOLDMON0035015 [considerable - description] considerable 113:18 considered 72:18 consolidated 28:7 constantly 81:4 constituent 102:23 constituents 114:19 constructed 16:16 consume 114:14,18 contact 44:15 45:11 57:7 74:1 contacting 111:4 contain 109:23 contained 88:12 99:22 101:2 containing 84:18 contains 41:3 contaminants 9:3 contaminated 65:2,3 72:18,23 contamination 66:10 73:22 74:10 103:12 111:13 continuation 6:5 14:15 continue 87:1 continued 1:1 3:6 28:9 73:4 87:7 108:13,18 109:3 110:1 continues 109:6 continuing 66:23 continuous 47:15 continuously 47:2,10,10,20,23 48:4 110:1 contract 105:4 contrary 80:6,7 control cox (cont.) day 53:6 60:20 74:7 45:9,14 48:16 49:2 52:14 1:1 48:13 52:1 90:20 95:6 convenient 52:20,23 53:3,23 54:9 121:4 44:16 55:10,12 58:1 60:1261:10 days conversations 61:15,22 62:8,18 63:17 51:15 74:16 64:6,15 65:6,12 66:4,7,13 dealings coordinated 67:19,23 68:8,19 69:19 83:18 61:1 70:4,19 71:22 75:4 76:3,9 deals coordinator 76:16 77:5,14,23 78:17,23 61:5 83:18 79:6,14 80:11,17 81:7,14 debating copied 82:2 84:1,4 85:10,22 86:17 53:16 55:21 87:4,19 88:8 89:7,12,22 debris copy 90:15 91:14 92:23 93:11,19 37:16 6:17 105:21 108:3,4 94:12 95:1,8,16 99:20 december corner 100:12 104:1,4,12,20 105:8 108:21 104:14,14 107:3,9 108:16 109:4 decided correct 116:11,21 48:21 85:3 92:3 9:16,17 17:17 18:4,13 19:8 crack decision 19:14,23 20:21 24:6,22,23 24:5 67:4 92:16 28:1348:15,2051:17,18 craddock dedicated 52:10 55:20,22,23 56:5,6,8 83:2,7,15 15:3,5 56:9,12,13,15,16,20 59:13 crane deduction 60:8 65:5,11 77:4 85:2,9 39:16 35:21 86:16 87:3 88:18 89:11 create defendant 90:6 94:23 95:7 96:8 97:18 41:6 1:1 2:1 100:6 103:14 106:8 111:2 credit define 112:2,10 120:15 111:1 62:1 100:6 corrected creek defined 6:22 105:11 114:6 7:9 65:3 103:12 106:3 63:19 74:9 correctly 112:8 delineates 13:23 53:10 59:3,14 60:6 curiosity 103:4,6 correlate 30:20 demand 58:16,21 current 50:16 corrosion 113:14 department 38:8 customer 34:20 39:21 110:10,22 corrosive 87:21 112:12 38:6,16 cut departmental counsel 37:23 30:13 120:22 cv depict county 1:1 54:9 120:3 course 27:7 34:20 court 1:1,1 5:9 8:2,18 31:14 d daily 46:11,14 48:12,19 50:5,7 50:13,17 51:23 101:20 depose 35:13 deposition 1:1 5:4,8,15,21 6:3,6,7 35:2 54:5 101:19 119:3 120:17 43:23 45:12,15 50:19 53:18 55:9,11 120:5 cover 23:18 covered 18:23 cox 2:1 6:5,13,17,21 7:7 8:14 9:9,23 17:9 18:16 20:10 21:1 24:13 25:20 26:13 31:21 35:1,5 42:1,11,14 20:2 darryl 11022 data 9:16 105:22 106:4,14 113:21 date 11718 dated 39:19 44:22 96:16,17,18,19 108:2 111:17 describe 44:9 described 22:17 50:4 describes 103:3 describing 85:1 description 42:18 57:3 62:16 Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) HARTOLDMON0035016 [deserve - elderly] deserve 77:21 designate 49:12 designated 6:12 7:8,11 designation 6:7,9 detection 10:23 12:23 66:18 detects 59:12 determine 62:21,22 determined 66:20 71:17 85:13 developed 72:1 73:7 113:19 developing 72:11 114:8 development 66:18 device 84:18 98:20,23 99:7 devices 85:15 diag 54:18 died 30:22 difference 78:8 different 16:17 33:3 differently 11:3 dig 8:14 64:3,4,14,17 65:1 digestive 78:21 digging 64:16 dioxins 8:11 49:16 direct 43:15 45:22 directed 101:9 direction 23:14 36:19 44:16 91:7 114:4 directly 26:6 dirt 64:3,5,11,14,16,18,19 65:2 65:4 disagree 79:11,18,20 discharge 11:20 19:22 42:22 43:4,6 43:13,14,15,19,19 44:4,4 44:14,20 45:21,22 49:1,19 51:13 56:3,8,12,23 57:6,11 57:1263:11 112:6 114:22 115:1 discharged 44:16 45:1,16,20 87:13 discharges 19:7 44:19 62:5 64:22 65:1 65:11 66:2,23 discharging 115:11 discoloration 111:22 112:13 discontinued 88:1 discovered 89:2 109:22 discovering 111:1 discovery 5:5 109:19 discussing 7:8 111:7 discussion 7:21 9:10 118:20 discussions 111:9 dispensary 27:19 28:10 disposal 105:22 106:22 107:7,8 disposed 97:22 98:1 disposition 84:21 dissolved 50:8,11 distance 88:22 112:7 district 1:1,1 ditch 37:4,7 divide 16:17 division 1:1 doc 46:5 dock 14:18 docks 36:10 document 42:10,15 52:7 55:21 56:2 57:21 96:19 104:19 105:11 105:12 108:2 110:21 114:7 documentation 78:3 documented 46:4 84:21 documents 42:16 74:14 107:1 108:6 doing 46:13 102:12 don 97:3 downhill 23:12 downstream 81:5 dr 80:9 81:20 82:6,8,14 83:8 drafting 28:5,8 drain 37:4 drainage 94:20 draw 18:1 115:5 drawing 25:16 54:18 drip 101:16 drips 47:12 drive 29:10 85:1 drove 29:14 drum 25:4 drummed 17:4 26:22 drums 24:11,12,1625:1,3,9 dry 41:10 dryer 40:17,20,23 41:10,12 dsnOOl 8:11 49:9 dsn002 43:9 dsn003 43:10 dsn5 44:3 dsw073245 111:20 du 32:7,10 due 69:1 71:9 dug 15:1821:1723:3 duly 8:2 120:7,9 duplicates 54:10 58:20 duty 60:5,9 62:15,19 67:13 68:5 69:15 e e. noble 1:1 2:1 earlier 12:20 20:6 56:5,17 57:3 71:1491:3 101:19 early 22:11 111:21 113:11 east 23:6,8 eastern 1:1 eat 74:2 114:14,18 ec 10:18,20,22 11:4 12:4,21 effluence 12:11 effluent 106:2 effort 61:1 eight 18:10,11,15,21 27:6,7,13 28:9,12 39:11 96:7 99:13 109:1 116:4,8,9 eighteen 32:18 eighty 108:8,22 eira 116:1 either 10:17 11:6 51:4,4 79:4,9 120:22 el0001201 45:18 elderly 65:4 Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) HARTOLDMON0035017 [elected - first] elected equipment (cont.) existed fairness 110:9 41:7 57:3 92:15 electrical era existing fall 84:18 66:21 57:11 113:21 63:12,12 101:12 electron escaped expansion false 10:4 68:14 71:18 76:15 17:7,13 106:23 eleven established experience familiar 59:9 88:16 72:17 73:14 74:6 69:21 53:11 83:15 106:7,9 115:2 eliminate estimated expires far 65:11 66:23 68:6 87:16 112:6 121:15 23:8 36:21 118:4 eliminated et explain fast 43:19 44:6,20 1:1 13:4 40:22 46:17,19,20 67:5 emergency event 63:22 90:21 fate 60:23 14:16 16:5 61:2 76:19,23 explore 63:6 emerging 98:23 57:15 february 111:23 events expose 113:3 emphasis 105:3 110:12 87:1 federal 60:20 eventual exposed 74:6 79:11,19,20 employed 90:23 75:19,20 76:14 77:20 87:11 feel 84:1 90:6 94:4,21 everybody 87:16 88:5 68:11 81:1,10 113:15 emptied 74:8 88:11 exposes felt 32:3,6 48:9 99:11,12 evidence 76:8 72:13,23 87:10,17 92:12 empty 5:5 exposing fence 24:16 48:5 98:17 evolved 81:4 81:6 88:4 enclosed 73:18 exposure fiber 40:5,7 106:6 exactly 87:16 25:9 ended 82:21 extended fifteen 92:21 95:14 99:18 100:10 examination 93:4,7 20:15 29:5 31:2 ensure 3:7 6:2 8:5 extent fifty 45:3 examined 66:10 72:18,22 73:5,9,16,23 74:4 entered 8:3 extracted 78:7 102:1 116:4,8,9 92:4 example 54:4 figure entering 72:12 extremely 64:2 71:12 92:20 112:8 excess 34:6 66:17 67:5 98:9 figured entitled 78:12,16 eye 94:21 105:22 exclude 18:2 filed entrance 5:15,18,20,22 f 118:12 31:13,1633:14 environment 61:9 62:7 66:12,20 67:11 68:1569:1770:1771:1,3,8 71:13,19 81:3,4 85:14 86:1 86:5,9,13,16,22 87:6,8,14 87:23 95:11 environmental 7:14 61:19 63:5 70:3 80:3 80:22,22 97:2 109:11 116:1 epa 9:5 53:12 74:9 91:5 102:11 105:4 epidemiological excuse 111:5 exhibit 3:10,11,12,13,14,15,16,17 3:18,19,20,21,22,23 4:1,2,3 8:8,15,16 9:15 13:2 34:2 42:5,11,12 44:7 45:9 46:1 49:13,22 52:6 53:19,22 54:3,7 55:5,15 56:19 57:17 95:18 96:1,10,18,23 102:7 102:10 105:2,15,16 107:20 107:21 108:1 110:17,18 112:19,22 115:19 exhibited facilities 35:20 44:21 102:16 facility 17:14,15,17,18 27:15,16 35:16 76:21 77:12 82:4 10212 13 18 11618 1173 facing 31:13 fact 48:21 110:7 111:6 factors 115:17 failure 519 filing 6:2 filled 22:3 48:2 55:17,18 filtration 30:16 finally 22:7 find 42:1761:8 69:11 81:1,2,11 81:11 89:19 106:12 fine 73:1 finish 78:5,8 equilibrium 115:7 equipment 14:19 15:2,5 35:23 37:13 78:4 exhibits 3:9 7:22 49:5 exist 62:22 faintest 90 18 91 6 fair 68:7 93:18 76:4 82:9 firm 2:1 first 6:6 8:2 10:7 27:9 54:5,6,6 Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) HARTOLDMON0035018 [first - hazardous] first (cont.) formal 64:18 69:8 79:9 85:23 5:10 105:20 120:9 former fish 61:19 80:22 103:13 106:5 forming fite 60:22 1:1 forth five 37:5 94:11 16:1038:1843:1658:18,19 forty 89:3,11 91:11,21,22 112:5 78:7 101:23 116:4 forward flaked 119:1 25:7,9 26:21 forwarding flaker 106:1 26:23 27:2 found float 45:2 71:7 89:19 91:7 96:7 31:19 97:17 108:22 109:1 116:4 florida four 30:17,19 15:23 43:16 46:9,12,16 flow 47:3,5,7,11 48:3,9 50:3 23:13 32:15 46:2,10 51:22 56:7,14 57:12 58:18 flowing 58:19 102:1 47:19,22 48:1 fourteen flows 59:5,8,11 112:7 fourth flushed 56:2 98:17 frame folks 8:1321:1373:21 81:5 franklin follow 2:1 81:1782:10 free followed 85:2,3,8,12 83:7 fresh follows 113:16 8:4 107:7 front food 7:1 33:23 74:2 fronts foot 15:10 33:22 fugitive forefront 101:13,15 109:7 34:10 fugitives foregoing 99:5,6 100:14 120:15,18 full form 47:4 81:17 5:16 17:9 20:1021:1 48:16 fully 52:20 60:12 61:10,22 64:6 66:9 64:15 65:6,12 66:13 67:19 functions 68:8,19 69:19 70:4,19 75:4 27:21,22 76:9,16 77:5,14,23 78:17 funnel 78:23 79:6,14 80:11,17 100:23 81:7 85:10,22 86:17 87:4 funneled 87:19 88:8 89:12,22 90:15 101:3 91:14 92:23 93:11,19 94:12 furnace 95:1,8,16 100:12 107:3,9 38:21 108:16 109:4 114:20 further 5:7,12,23 9:23 57:15 further (cont.) greater 120:17,21 72:21 97:9 future grit 72:2 20:4,19 g gallon 20:16 gallons 14:1 112:6 gc 10:2,4,17,18,20,20,21,22 11:4 12:3,4,5,8,21 ge 79:4 general 7:10 58:8 68:5 91:4 generally 12:20 40:10 50:13 60:2 100:10 gentleman 112:11 geographically 56:15 geraghty 111:5,16,20 112:14 gerald 35:2,10 give 10:15 70:13 94:10 given 70:1 71:16 120:12,16 gives 103:2 111:20 116:16 glasgow 108:5 ground 45:2 99:7 109:15,17 group 60:22,23 grow 114:20 growing 30:10 growth 55:2 guards 41:22 guess 40:6 41:23 45:5 49:8 53:17 59:13,13 68:4 80:21 82:23 99:5 103:21 108:21 113:7 118:21 guessing 16:641:23 106:19 guidance 70:14 guideline 60:14 72:19 73:14 74:5,9 guidelines 60:1,4,1661:13,1771:6,16 71:23 72:5,9,10 73:15,22 gunning 106:5,10 111:4 guys 34:23____________________ h go half 9:9,11 13:1,17 17:21 22:21 67:10,17,21 25:16 34:19 35:13 42:1,8 halted 43:11 57:9 76:3 82:8 89:14 97:16 89:18 96:15 101:4,5,14 hand 104:18 118:18 8:8 13:2 57:20 108:1 going 112:22 121:3 6:14,15 10:19 13:2,3 18:6 handwriting 35:1 41:5 42:9 46:1 56:17 28:20 31:3,4,5 96:20 60:7 65:20 69:11,14 71:10 handwritten 76:23 85:3 86:15,23 88:6 96:19 106:20 90:19 95:6,13,21 101:18 happened 111:19 113:1 15:1722:15 118:3,16 good hazard 35:4,9 95:7 61:9 64:23 68:6,7,15 69:18 government 70:17 71:20 76:18,19 77:7 79:12,19,21 85:20 77:16 78:4 85:8 86:5,6,8,10 gradual 86:21 87:15 84:17 hazardous gram 60:11,18 62:6 75:2 76:8,14 59:5 84:12 102:23 Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) HARTOLDMON0035019 [hazards - jerry] hazards honestly illustrated inspections 62:22 85:21 69:4 73:21 91:23 92:2 21:16 110:15 hb honesty illustration installed 97:8 92:15 115:6 27:2 38:22 94:23 hb40 honorable immediately instruction 13:23 14:1,1021:3 96:4 1:1 2:1 38:11 70:14 97:18,20 98:21 99:2,14 hot important instrument 100:11,21,23 101:8 108:6,7 90:17 51:2 40:20,21 41:6,9 head hour impoundments instruments 109:11 46:9,12,17 47:4,7,11 48:3 103:5 40:1841:1 headed 48:10 50:3 51:22 include intended 113:22 114:3 hours 77:9 40:12 health 47:5 included intensively 71:20 85:21 86:14,21 huckabee 51:12 70:8,9,22 94:2 99:15 72:3 110:10,22 112:12 97:3 including intent hear huh 27:13 93:21 99:2 80:2 118:6 10:12 13:11 29:1245:10 incorporated intentionally heard 47:18,21 58:11 96:6 9:5 30:12 80:5,5 102:4,6 118:4,7 human incorporating interacting heavier 67:5 70:17 79:12 80:4 9:7 38:13 14:10 85:21 86:21 incorrectly interested heflin humans 7:10 120:23 90:9 71:20 85:9 86:14 87:1 index interject held hundred 3:4 104:1 7:21 9:10 20:15 59:5,8,9,10 88:17,17 indicate interviewed help 88:21 89:4,7,9 96:7 97:9,17 108:13 116:12 27:9 16:18 108:7,22 109:1 112:5,5 indicates inventory helpful 116:4 11:3 106:2,17 84:19 118:8 hundreds indication investigate hereto 109:16 106:13 111:13 66:10 5:4 hyacinth indirect investigated hereunto 30:10 43:14,14 45:20 10:17 38:11 45:2 57:5 121:2 hyacinths industrial investigation hidden 30:16 12:10 116:2 7:9 44:23 58:9 105:10 37:1 high 73:6 higher 78:6,21 highway 112:9 hill 23:7,13 33:6,22 89:5,10 103:18 hint 10:16 historical 57:4 history 44:10 66:2,17 94:10 hit 62:11 holds 6:10 homeowner's 73:10 i industries idal0001201 42:20 idea 20:13 32:9 90:18 91:6 11815 17 identification 7:23 10:22 42:6 49:6 53:20 55:6 57:18 95:19 96:11 102:8 105:17 107:22 110:19 112:20 115:20 identified 43:18 57:2,4 64:23 70:16 76:19 110:4 identify 25:4 34:12,19 35:22 68:6 76:13 87:11,12 104:5,5 identifying 115:17 iii 2:1 72:21 information 7:17 93:23 106:1,2 informed 88:1 informs 97:8 initially 66:22 initiated 109:16 inlet 19:6,6,13,17,22 98:18 inside 38:2 insight 118:7 inspected 37:23 inspection 110:14 involve 7:16 involved 26:6 63:1 70:8,20 72:3 76:22 80:19 81:19 82:17 90:2,3 involves 63:5 involving 102:18 issued 43:20 45:17 item 106:4 ivory 95:23 j january 44:5 49:9 95:23 96:16,18 108:2 jerry 1:1 3:6 6:6,7,21 7:1 8:1 Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) HARTOLDMON0035020 [jerry - louis] jerry (cont.) know (cont.) laws 35:5 104:4 116:13 120:8 100:9 101:13,23 107:14 102:15 jerry's 110:12,13 113:18 116:3,10 lawsuit 7:13 117:3,11,22 118:2,5,9,10 117:23 jim 118:11,12,13,14 leachate 97:7 106:22 knowledge 109:23 job 14:23 69:21 73:1 75:6 78:3 leaching 46:8 79:16 80:1 82:5 89:14,18 109:9,20 john 89:20 90:1,12 91:20,21 leading 83:2,7,15 92:7 93:1 5:16 joined knowledgeable leak 19:15 7:17 101:16 jones known leaking 102:11 27:11 51:20 53:8,9 56:22 110:4 jrs 64:11,17 77:7,15 86:5 learn 105:22 92:17 93:23 120:9 89:17 jug knows learned 47:3,6,17,20,22 48:4,5,8 35:13 60:10 62:3,4 68:14 71:6 july 69:14 leave 49:11,13 1 25:11 60:10 june 15:14 k kaley 81:20 83:1,6,8,19 kearney 105:5,7 kilogram 116:5,12,14 kimbrough 80:9 82:6,8,14 kind 8:14 16:23 18:23 33:19 37:16 41:21 44:9,15 67:14 95:21 110:3 kinds 63:2 kit 99:19 knew 64:3,4,13 67:10 81:2,3 86:20 87:5 88:5 91:9,12 know 10:13 15:21 16:5 23:23 25:4 28:22 32:8,20 34:15 34:18 35:20,21,22,23 36:14 36:14,21 37:7,12,14,15 40:15 41:18 44:8 45:5 46:2 46:5,18 49:21,22 51:6 52:18 53:4,7,9 54:15,22 55:1 57:16 58:12 62:21 63:20 66:17 67:7,15,16 68:2,20 69:4,5 72:15 74:8 76:17 79:21 80:12,15,19 82:11 84:14 85:6 88:11 lab 97:11 label 18:7 laboratory 27:15,1828:1,3,6 117:6 labs 28:4 land 112:7 landfill 15:19,20 21:20 22:17 23:12 23:18 33:5,11,17 54:12 91:10,11 92:18,22 94:16,20 94:23 95:12 102:16,17 103:13,16,17,20,23 104:6,7 104:13 106:22 107:7,8,12 109:10,18,20 110:5 111:2 112:1 landfilled 22:18 landfills 103:4 large 1:1 23:14 24:5 47:3 48:4 120:7 121:12 larger 32:22 larry 1:1 84:5 late 22:9,10,10 66:20 lately 29:1,4 law leaving 45:4 led 90:23 left 24:21 25:1,3 39:7 60:17 62:2,3 69:16 letter 102:11 lettered 13:6 level 9:21 10:23 11:22 12:13,23 38:15 52:8 73:6 levels 9:21 10:1 12:8,18 38:12 40:9 78:7,21 life 70:18 lightfoot 2:1 limestone 15:8,10 16:8,11,19 19:8 21:8,23 22:3 24:10 30:6 33:2 limit 72:17 114:22,23 line 26:4 40:18 60:14 lined 22:1 lines 41:6 lining 23:18 28:18 91:17,23 92:3,9,17 96:23 1:1 2:1,1 liquid 20:3,20 25:21 65:18 116:12 listed 9:4 10:2 58:21 103:14 listing 9:3 lists 12:12 liter 10:3,5,10 11:15,17,22 12:1352:11,12,13 literature 70:14 little 12:15 18:2 24:8 25:16 26:8 44:9 47:8 lived 88:12 living 90:7,9 loaded 25:18,20 26:19 loading 26:11 36:8,10,17 located 23:1027:15,16,19 location 23:6 117:15 locations 26:20 57:7,12 87:12 91:4 long 16:23,23 18:14 27:3 86:13 92:19 98:4 look 9:20 13:17,18 16:20 20:8 26:10 32:7 52:5 53:15 54:17,23 55:12 70:23 111:16 113:21 119:1 looked 12:17 16:2 43:21 58:23 88:15 89:11 looking 11:23 13:20 19:5,22 33:2 36:1 39:7 54:12 58:15 89:14,1892:1 117:14 looks 14:13 16:22 20:18 24:3 31:21 40:9 117:8 lost 47:16 81:8 lot 41:1,4 71:5 90:1 91:19 loud 97:5 louis 83:20 105:20 Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) HARTOLDMON0035021 [louisiana - nineteen] louisiana mars migrated motion 117:17 23:7 89:5,10 91:12 92:21 95:12 5:15,18 lower material migrating mound 10:23 12:22 73:15 15:17 20:6,20,23 21:2,6,17 92:18 23:15 lowered 22:16 96:4,8 97:8,18 98:13 miller move 38:15 99:13,18,20,21 100:10,20 1:1 35:10 111:5,17,20 5:20,22 29:17 lunch 111:2 112:14 moved 42:14 materializes miller's 28:1 66:17 67:2 85:15 lung 114:5 35:2 movement 78:12 materials milliliter 67:4 109:17 m 60:17 106:7 11:16 mpdes maintenance 28:10 37:14 major 113:15 makers 92:16 making 63:4 85:19 managed 86:7 management 97:8 102:20 manager 61:19 manager's 27:13 manner 21:15 manufacture 67:1 71:4 72:6,13 97:16 manufactured 71:3 75:12 87:7 manufacturer 60:5,9,19 61:12 62:3,4 68:13,1769:10,13,1570:15 74:23 76:6,12 77:21 manufacturers 59:18 60:1 manufacturer's 61:21 62:14,17 63:16 75:7 manufacturing 37:22 57:1,6 67:3,3 72:1,7 75:9,10 100:5 113:4 map 56:10 march 1:1 121:4 mark 55:7 105:14 107:19 110:16 111:19 112:18 115:21 marked 7:23 8:8,15 42:5 49:5 53:19 54:3 55:5 57:17 95:18 96:10 102:7 105:16 107:21 matter 52:21 75:20 mean 20:4 22:14 23:11 25:3,20 40:2,3 46:18,22 51:15 57:9 63:23 69:2 73:1 79:23 80:18 81:19 82:3 83:3,11 84:11 90:5,22 92:16 96:3 100:7,9,22 104:10 106:15 111:4 117:14 118:11 meaning 117:22 means 19:2 106:19 meeting 103:2,3 meetings 59:19 melanoma 78:16 member 59:21 memo 95:22 96:1,18 105:19,21 110:21 112:23 113:13 mentioned 8:9 metal 16:23 17:1 38:14 metallic 38:13 method 53:13 65:1 methods 9:6 mic 18:22 microgram 10:4,10 11:8,12,16,17,22 12:13 micrograms 10:3 52:9 59:5 116:5,11 mid 16:13,14 19:5 22:10 44:13 million 10:8 11:14,17 59:6,9,10,11 72:19,22 73:5,10,17,23 74:5 78:2 88:13,16,17 89:5 89:9 96:8 97:9,17 108:8,23 109:2 116:9 mind 92:4 97:6 minds 70:6,9,9 minimize 65:10 66:1 minute 26:10 112:7 missed 69:7 misstate 60:8 moisture 41:4,5,5 moment 42:2 113:15 monitored 30:14 84:19 monitoring 111:7 monsanto 1:1 59:21 61:20 64:3,4,13 65:9,23 66:17 67:9 70:2,5 70:13 71:16 72:13,20 77:11 80:3,7,10,16,23 81:6,19,23 82:12,13,15 84:16 85:3,7 85:19 86:20 87:5,10,17,21 88:3,5,9,10 89:2,17,20 90:13 91:9,12,18 92:15,16 92:16,17,20 117:23 monsanto's 67:12 78:11 monthly 101:20 months 29:6 moon 113:2,3 114:9 42:22,23 43:4,6,11,13,20 44:6,18 45:21 56:3 57:13 msds 75:13 mud 20:3,20 multiple 13:6 n name 14:1 83:15 104:6 named 120:8 nanogram 11:9,14 nationwide 61:1 natural 113:20 near 71:1991:22 nearest 39:15 necessarily 76:18 79:22 need 5:13 40:23 46:19,20 61:4 88:11 100:6 needed 92:5 negative 85:12 neighborhood 88:7 neighbors 75:1 88:4 neither 5:13 new 17:13 27:2 79:9 89:18,20 90:1,1398:13 114:8 nine 28:15 57:22 97:15 99:13 nineteen 110:18 112:19 115:19 33:1 Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) HARTOLDMON0035022 [ninth - pcbs] ninth object (cont.) ones 52:6 85:10,22 86:17 87:4,19 49:3 noble 88:8 89:12,22 90:15 91:14 ongoing 1:1,1 2:1 5:9 120:5 121:10 92:23 93:11,19 94:12 95:1 72:1,11 83:3 84:13,22 non 95:8,16 100:12 107:3,9 102:23 44:15 45:11 57:7 59:12 108:16 109:4 open 61:8 70:11 71:10 objection 33:20 34:1 37:14,23 39:22 normally 49:2 61:15 62:8,18 63:17 40:1,10 10:21 15:2 106:17 67:23 71:22 81:14 opening north objections 13:12,15 2:1 18:17,18,20 19:1,2,5,21 5:13,22 openings 20:18 26:12 34:5 objectives 40:8 northern 103:3 operated 1:1 obligation 27:3 41:1 46:10 northwest 81:1,11 operates 54:12 observe 115:6 notary 13:13,15,16 operating 120:6 121:11 obvious 41:7 44:20 note 34:7 operation 20:2,19 106:20 obviously 23:18,19 24:18 29:3 noted 37:1363:9 71:5 114:12 operations 110:14 occasions 72:1 notice 57:5 operator 5:11 6:2,8,18 7:1,11 occurred 32:23 noticed 14:18 38:9,9 76:21 103:11 operators 111:22 October 30:14 notifying 106:3 opinions 77:1 office 94:10 november 27:13 90:10 order 105:21 offices 97:14 number 27:12 28:5,10 ordinary 3:10,11,12,13,14,15,16,17 official 74:1 3:18,19,20,21,22,23 4:1,2,3 50:2 110:9 organic 8:9,15,16 9:15 13:2 18:6 oh 20:3,19 27:8 33:1 34:2 42:23 43:21 29:11 38:17 116:10 117:21 organics 43:22 44:3,7 45:8 46:1 oil 12:10 49:13,14,22 52:6 53:22 98:22 108:6 organisms 54:3,7 55:8,15 56:4,19 57:5 okay 114:13,13,16,19 57:21 81:13 96:17,19 7:198:79:20 10:13 11:19 organo 102:10 105:2 106:4 108:1 12:2,9,12 22:2 26:10,18 112:4 112:22 28:12 31:2 36:20,23 38:18 orientation numbered 39:1 41:8,11,14,20 44:8,11 33:4 13:5 44:18,21 47:1,1648:11 original numbers 49:8,17 52:15 53:3 55:9 68:11,12 54:18 58:15,16,21 88:15 57:20 58:23 62:17 65:20 ou o 68:4 84:7 98:2 104:3,16,22 32:7,10 oath 107:14 112:15 114:11,22 8:3 object 117:7 okayed 5:17,19 17:9 20:1021:1 48:16 52:20 60:12 61:10,22 64:6,15 65:6,12 66:4,13 97:10 old 17:17,1864:11,1281:5 67:19 68:8,19 69:19 70:4 70:10,19 71:10 75:4 76:9 104:5 once 76:16 77:5,14,23 78:17,23 14:19 42:9 64:22 68:13 79:6,14 80:11,17 81:7 69:1371:17 114:5 outcome 120:23 outlet 19:13 outside 62:4 68:16 86:22 87:2 overflow 115:18 overflows 115:8 overhead 36:11 owens 1:1 owned 104:8,11 oxygen 50:16 P page 3:5 10:16 11:22,23 12:1 13:5,5 14:12,12 15:6,7,23 16:1024:8 28:12,15,17,18 30:5 31:2 32:11,17 33:1 34:2,3,4,13 35:14 38:18 39:17 41:14 52:6 54:6 56:2 56:10 96:13 paid 80:10,15 81:19,22 82:12,13 paper 10:9 parallel 112:8 parameters 50:6,12,23 paraphrase 60:6,7 parenthesis 20:2,3 part 10:15 11:17,17 17:7,12,13 24:17 39:2 44:18,23 45:3,7 46:8 50:2,10,11 51:11 53:12 58:8 65:2,16,17 74:6 80:19 84:22 86:8 102:5 116:21 particular 16:5 80:8 98:20 parties 5:4,8,17 6:1 parts 10:8,8,10,11,14 11:13,14 11:15 59:6,8,9,10,12 72:18 72:22 73:5,9,16,23 74:4 78:2 85:12 88:13,16,17 89:5,9 96:7 97:9,17 108:8 108:22 109:1 116:8,9 party 5:13 120:22 pcb 48:23 72:18,22 73:22 74:9 74:12 83:18 84:17 85:2,3,5 85:8,12 97:9 99:20 103:12 105:22 116:5 pcbs 7:3 8:11 9:8 14:20,22 16:4 Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) HARTOLDMON0035023 [pcbs - presumably] pcbs (cont.) ph pits pollutant 17:3,8 20:23 21:7 23:1,4,20 50:1751:1 22:7 30:6 8:17,20,23 9:8 12:8 24:20 36:12 38:16 48:14 phase pitted pollutants 49:18 52:2,7 53:2 66:11 84:17 85:14 86:6 38:2 9:2,5 67:10 71:7,7 72:7,10,13 phased place poly 77:3,9,11 78:2,7 79:9,12 86:11 98:4 5:10 92:11 120:18 30:14 37:21 38:21,21 39:13 80:4 81:2,18 82:5 83:10,11 phases placed pop 83:13 84:9,14,23 85:8,19 110:2 15:20,21 21:22 31:1 86:4 87:12,13,22 88:13 phasing placement portion 89:19 91:7,9,12 92:18,21 85:5,18 111:7 95:7 94:16,20,22 95:4,11 96:8 phenyl plaintiff pose 97:16,22 98:14 99:4,22 39:13 55:5 61:9 100:19 101:21 107:11 phenyls plaintiffs posed 108:6,13,23 109:2,2,12 30:14 37:21 38:21,21 1:1,1 53:19 62:23 peer phonetic plaintiffs posing 113:7,8 97:3 116:15 3:10,11,12,13,14,15,16,17 70:17 pending phosphate 3:18,19,20,21,22,23 4:1,2,3 position 118:14 104:5,10 112:4 6:8 7:22 42:5 49:5 57:17 53:13 87:6 97:2 people phosphates 95:18 96:10 102:7 105:16 possibility 61:9 62:7 65:5 69:18 74:1 50:18,19,22 107:21 110:18 112:19 92:8 76:7,13,22 77:19 81:5,19 photo 115:19 possible 87:11,1591:19 112:14 14:13 18:3 19:21 20:18 plan 68:681:12 110:13 114:2 24:10,1031:11,11 33:1 93:14 94:2 possibly period 34:3 39:19 40:15 plans 92:3 17:5 27:3 43:12 47:11 48:3 photograph 114:7 potential 70:7 75:21 84:15 114:21 13:4 16:1,6 20:5 34:6,8,10 plant 9:3 68:15 70:17,23 71:2,20 permit 39:2 41:16 54:16 24:21 25:12 27:9,13,17,19 77:7 85:8 86:21 87:15 42:22,23 43:15,20 45:17,21 photographs 30:12 33:15 44:17 49:19 102:19,22 45:22 50:3,6,7,11 55:16 13:1,6,7 14:1721:1653:16 51:21 54:13 56:11 57:1 potentially 57:13,14 104:21 112:7 54:4,5,7 58:5 60:10,17 62:2,3,5,6 76:8,14,21 103:10 115:2,13 photos 65:13 66:12 68:14,16 69:17 pow permits 30:9 39:18 71:18,19 76:15 80:23 81:6 115:12 43:11,15 56:3 57:11 physically 81:16 82:13,15 83:5,12 power permitted 22:16 85:2 86:23 87:2 90:6 98:11 104:8,11 43:3,13 56:23 picks 98:18 100:21,23 103:18 ppm permitting 34:3 106:18 111:22 114:12,13 112:5 44:12,18 picture 114:17 predict persistence 16:6 37:8 please 113:22 66:11 pictures 113:20 114:7 predicting persistent 26:9 28:12 54:20 55:2 plugged 115:16 67:11 piece 15:15 prepared persisting 10:9 37:13,20 plus 105:1,11 69:1770:1671:13,19 pin 97:17 presence person 117:18 point 9:6 66:19 76:18 78:1 7:7,14,17 32:22 75:23 pipe 11:20 14:9 19:18 43:4,7,13 120:13 88:1091:18 24:1,2 56:20 44:20 45:17 46:15 50:2 present personal pipes 51:13 56:22,22 57:6 70:7 55:3 62:4 74:16 86:13,15 79:15 80:1 24:5 36:11,11 44:22 88:19,20 89:15 92:5 97:4 86:15,22 87:14 88:6,7 95:6 personally piping 98:19 113:10 presentation 76:23 36:14,15 37:21,22 38:9,23 pointing 80:9 82:18 personnel pit 26:1,3 presentations 111:22 16:11 19:1,2,2,5,8,17,21 points 81:15,18 82:4 pertaining 20:18 21:8,22 22:23 23:5,6 16:17 42:20 43:19,20 45:4 pressure 84:22 107:11 24:10 28:13 30:6,10,19 52:4 56:8,12,14 57:2,3 41:2 pesticides 31:19 32:3,6 33:2 38:8 58:19 88:19 presumably 12:13,21 100:20 106:4 108:9 Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) HARTOLDMON0035024 [pretty - regional] pretty provided quickly 117:2 40:13 52:5 66:18 67:2 68:5 previous proximity quintard 16:2 92:7 97:19 65:4 1:1 previously public quit 22:17 28:8 43:18 50:4 110:10,22 112:12 120:6 85:19 primary 121:11 quite 28:2 39:4 60:20 109:14 published 27:8 82:20 prior 53:12 59:23 quote 9:7 16:6 43:20 44:13 83:2 pulled 113:13 83:1992:19 108:19 111:8,8 42:15 r priority pumped 8:17,19,20,23 9:2,4 12:7 47:13 94:17 probable purchase 77:18,20 79:12 80:4 97:14 probably purchased 22:9 46:7 50:17 74:20 87:22 82:23 94:13,22 100:8 110:6 purchasing 113:10 97:13 problem pure 73:11 86:12 111:21 113:17 23:15 114:2,4,5 purpose problems 5:5 15:13 41:6 113:14 114:8 purposes procedure 5:6 7:8 28:5 56:23 53:7,9 pursuant process 1:1 6:8 34:11 38:7 44:12,15,19 put 45:19 50:3 21:17 25:9 30:19 47:5 53:7 processed 63:15 93:14,22 95:13 101:11 113:20 processor puts 38:10 47:2 product puzzled 63:3 71:1 88:1 103:7 12:15 production q 7:3 21:9 66:2,16 74:12 98:5 98:14 products 61:3 62:23 profile 79:8 program 66:22 84:22 proper 67:17 property 30:17,19 73:16 104:14 proposal 111:18 protect 75:1 protocol 58:17,20,22 59:1 93:22 provide 16:18 qaqc 28:2 qualified 120:7 quality 53:6 quantification 10:22 11:4 12:21 quantity 53:8,9 question 30:4 53:14 56:17 57:16 62:13 67:15 68:12,13,21 69:6,9,21 70:2 71:12,14,15 72:4 75:6 76:4 80:21 81:8 81:10 82:10 90:2 117:21 questions 5:14,16,1762:1094:10 107:15 118:22 r&d 28 4 8 rail 26:4,4 39:5 railroad 25:18 31:15 railroad's 31:13 rain 51:6 rained 51:15 rainfall 101:6,11 ran 19:12 range 62:10 112:4 rate 46:2,10 48:2,4 rates 789 rcra 102:12,13,15 104:20 reactor 38:22 read 30:1531:11,19 78:9,11,15 79:8 97:5 112:23 readily 114:6 reading 6:2 52:15 ready 97:11 real 52:5 118:5 realizing 67:2 really 34:14,18,19,19 36:16 37:6 53:11 65:23 79:10 119:1 reason 55:1 85:7,11,18,19,20 89:14 92:17 reasons 7:2 57:4 recall 8:9 69:7,8 101:21,22 receiving 96:1 106:14,16 recess 17:20 42:4 55:4 95:17 recipient 105:21 recognize 23:23 32:21 recollect 22:6 26:23 104:10 recollection 6:20 22:12 107:17 record 7:21 9:9,10,12 17:22 42:1,8 118:19,20 recorded 46:11 recover 53:8 recovery 102:14 reduced 120:12 refer 12:19 106:21 reference 111:19 referred 14:16 20:6 43:16 100:15 105:12 referring 12:6 19:7 33:9 38:23 100:4 103:17 refers 111:10 reflect 57:22 reflected 49:22 56:19 refresh 54:18 refused 88:3 regard 69:16 83:10 regarding 6:22 60:17 83:13 regenerate 30:21 regional 97:13 Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) HARTOLDMON0035025 [regulated - se] regulated reported result 72:22 84:20 102:1 106:3 5:21 62:5 109:19 regulations reporter resume 73:3 74:6 83:19 84:14 1:1 5:9 8:3,18 31:14 43:23 34:1 regulator 45:12,15 50:19 53:18 55:9 retired 75:2 55:11 120:5 84:2,4 regulators reporter's retroactively 73:11 74:8,12,17 3:4 72:5 regulatory reports retrospect 70:8 72:12,20 101:19,20 63:10 rehash representative rfa 65:20 110:8,8,9 104:17 105:13 related representatives rid 102:17 81:17 85:15 86:16 relating request right 13:22 107:2 107:4,11 5:22 7:5 11:20 12:3 14:14 relation requested 17:14 18:12 19:3,1621:5 25:17 105:23 25:8 31:1 33:17 34:14 relative requests 39:10,23 40:15 42:8,21 120:22 105:22 43:17 50:8 53:15 59:16 release required 62:14 64:5,21 70:1 76:2 31:9 32:14 76:20 77:3,6,11 53:12 96:17 99:9 100:3,17,18 99:1 101:2 102:23 requirement 108:20 117:13 released 5:11 rise 13:23 requirements 115:11,18 releases 6:1 road 60:21 61:2,6,7,8 research 31:14 103:18 remain 116:2 roadway 27:22 40:10 reserve 39:15 remainder 118:22 robert 7:12 residential 55:18 95:23 102:11 remedying 73:16 roland 64:22 65:1 residents 97:12,12 remember 77:11 role 13:22 15:22 16:16 17:12 resolve 7:13 20:1521:1222:11,1325:6 57:16 room 25:10,23 26:7 36:10 37:7 resource 27:1428:11 49:4 50:23 51:8 59:3,15 102:14 rose 60:13,1661:1779:1080:8 respect 115:14 117:17 82:17,21 84:6 95:23 96:3 61:1469:1 71:9 roughly 98:8 105:3 107:18 109:9,14 response 66:20 110:11,14 111:6 117:5 60:23 61:2 105:2 routed remind responsibilities 37:9 97:20 6:11 27:5 60:18 routine remove responsibility 110:15 65:3 61:13,21 62:15 63:16 68:17 routinely removed 75:1,10,11 76:7,13 87:10 30:15,18 48:14 63:3 22:9,16 24:4 88:23 114:20 87:17 routing removing responsible 36:14 31:9 109:7 46:9,13 60:1,5,19,22 61:20 run renate 63:1068:13,1769:1570:15 19:11 50:5,6,12,17 51:9,21 80:9 82:6 72:14 51:23 replaced responsive runs 21:8,11,14 70:11 71:10 112:8 report rest 79:22 111:17 116:22 118:22 s sacked 25:8 samantha 1:1,1 2:1 5:9 120:5 121:10 sample 42:17,18,20 43:1 46:2,6,15 47:3,4,6,14 48:7,8,10 49:21 49:23 50:1,5 51:11,16,17 56:18 58:15,16 59:4 90:20 92:4,5,11,1297:10 117:10 sampled 47:4 51:10 57:4 91:6 96:4 sampler 46:12,17,1947:1,14,14 50:4,5 51:23 samplers 46:10 samples 46:11 47:2 51:4,7 57:22 58:4,7 106:5 116:3 117:8 sampling 9:19 46:8,14 47:7 48:4 50:2 58:17,17,18,20,22 91:1,3 93:4,22 94:2 sat 92:2 satellite 103:6 satisfied 67:12 savage 105:20,23 107:14 saw 29:7,8 saying 12:2 25:7 60:17 93:12 106:23 says 10:16 12:7 16:13 19:21 20:18 31:13 56:3,3 58:4 60:5 106:22 113:13 scan 8:17,21,23 9:8 science 58:17 scooped 64:18 screen 10:2,4 45:6 screening 9:20,21 10:1,18 11:21 12:8 12:12 42:16,17 45:3 52:8 se 90:17 Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) HARTOLDMON0035026 [seal - standard] seal sheet sites sort 121:3 3:3 58:22 7:13 115:7 second shop situation sounds 56:1 96:13 29:9,14 61:21 62:1,15 10:1859:16 113:12 section short six source 56:2 17:5 27:3 88:22 112:7 39:17 58:18 44:23 sediment 113:1 sixteen sources 58:7 106:13 shorthand 32:11 81:12 sediments 120:13 sixty south 15:16,16 16:3 shortly 116:5,6 17:19 18:14,1626:12,13,15 seeing 38:10 88:22 sketch 26:17 30:5 39:14 101:22 shot 18:2,23 southeast seen 41:21 skip 20:19 20:13 29:1,4,6 74:14 78:3,5 show 95:21 specific 78:18 13:7,21 14:12 23:22 34:4 slightly 9:3 55:1 83:11 87:12 118:5 sense 34:13 37:16 38:19 39:19 14:11 specifically 32:4,5 94:21 95:4,11 41:15 95:22 115:23 slow 22:12 35:22 49:23 50:23 sent showed 48:4 98:9 51:20 58:6 61:16 83:9 95:22 32:17 59:2 78:12,15,20 sludge 100:18 110:11 separate 112:3 49:16 115:10 specified 45:21 56:7,14 57:12 98:23 showing small 50:6,7 120:19 117:8 14:3,4 15:7 19:5 30:10 31:3 28:4 31:9 32:14 101:6,10 speech separately 31:6 54:8 111 :23 82:15 51:12,22 52:3 shown smaller spike separator 26:8 36:18 44:7 51:5,5 54:6 28:3,7 52:18,23 97:20 98:20,22 99:6 54:15 71:2 78:8 116:15 smudge spill series shows 34:7 13:23 14:18 20:9,14,16 16:2 45:5 62:10 105:3 11:21 13:4 28:1830:5 smudgy 99:1 101:2 103:10 107:1 32:11 36:6,7 37:12 38:20 34:6 spillage service 39:2,4 40:16 44:3 52:8 56:7 snow 103:8 37:23 84:21 56:11 57:12 59:4 7:9 65:3 103:12 106:3 spilled session shut 112:8 20:7 6:6 42:10 48:22 17:8,15 35:3 38:11 65:13 soil spills set 65:16,1798:11 115:15 57:22 58:3 37:5 60:21 61:5 39:13 52:7 54:3 60:1 101:1 sick sold spite 102:15 121:3 81:5 24:21 91:23 settle side solid spot 115:8 36:17 39:20 41:17 26:21 65:18 102:20 116:12 90:17,19 seven sight 117:10 spring 24:8 41:14 59:5,8 88:20 105:10 solids 45:2 109:22 111:1,12,23 seventeen signing 25:7 50:8,11 113:14 114:8 112:5,13 59:11 6:2 114:17,23 115:1,8,11 spur severson similar somebody 26:5 32:17 21:15 25:7 29:18 55:2 90:2,22 square severson's simply 92:6 52:11 31:5 33:3 71:3 someplace St sewer sincerely 117:11 83:20 105:20 117:17 13:8,10,13 14:2,6,13 19:7 92:3 somewhat stability 19:10,11,12,1424:1 31:6 sir 113:16 70:23 85:12,13 86:1,9 32:11 99:5 16:9,12 19:9 20:1 25:22 soon 95:10 sewers 28:21 33:10 38:3 43:8 52:2 30:23 stable 13:15 19:15,1937:1098:18 57:16 91:9 sorry 71:8 86:4,12 87:6,8,23 88:5 99:16 100:1,5 site 8:18 15:4 22:21 37:19 stagnant sheer 102:22 103:13,16 104:15 40:19 45:15 50:20 66:7 111:12 76:18 112:16,17 81:22 82:8 97:23 104:21 standard 9:5 Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) HARTOLDMON0035027 [standpoint - thirty] standpoint structure sworn tells 75:8 93:21 101:15 17:1927:1 34:5 101:7 8:2 120:9 109:6 start structures system ten 7:20 13:4 42:9 111:5,7 40:11 108:7____________________ 10:3,14 12:1828:17,18 started struggling t 52:8 112:6 38:8,10 44:12 50:21 85:4,5 93:3 109:21 110:1,13 111:3 studies starts 78:5,8 48:9 study state 78:11,15,20 79:2,3 106:11 table 12:16,16 71:15 93:2 94:1 103:7 taffee 28:23 29:4 94:4 105:19 tenure 109:10 term 64:17 86:13 terrible 62:20 63:2,8 65:10 66:1,9 109:15,17,23 110:2,12 67:12 69:10,14 73:1,2,3 stuff 106:1 110:6 taken 64:23 test 74:9 75:11 82:5 85:16 102:1 110:7,8,21 120:2,6 stated 60:14 68:1 statement 12:20 74:20 states 1:1 42:16 stay 86:15,23 88:6 staying 81:3 steam 101:16,16 stipulated 5:3,7,12,23 stipulation 1:1 3:5 stop 32:1563:11,14 stopped 50:18,22 63:15 72:7 98:15 stopping 32:12 67:3 72:13 74:12 storage 27:16 103:5,6,8,9 stored 50:9 63:14 100:19 subject 1:1 5:4,8 14:17 21:20 22:7 22:14,17 37:22 39:3 46:3 9:6 tested 6:22,23 submittal 105:1 subordinate 55:19 subsequent 112:3 substances 46:11 48:8 51:7,16 54:11 54:22 84:20 98:19 106:5 113:16 120:18 talk 9:12 83:14 talked 7:6 9:1 56:4 91:3 101:18 talking 8:11 16:3 20:23 21:6 23:1,4 23:20 testified 8:3 testify 6:22 7:1,2 120:10 testimony 3:6 49:1 74:23 77:19 74:7 sucked 24:13 36:7 38:23 44:15 45:8 48:3 50:14 52:2 57:11 120:12,16 testing 14:8 suite 1:1,1 sulfur 38:12,15 summary 10:16 11:21 101:21 sump 94:15,19,23 95:13 96:5 97:8,18,19 98:2,10 99:19 100:11,15,20,23 108:8,9,11 108:14,18,20 109:7 superintendent 113:5 supervisor 64:21 79:22 83:9 91:18 96:2 108:10 112:12,14,17 114:10 115:9,15 talks 111:21 taller 32:22 tank 24:21 25:13,18 26:18 36:7 99:7,9 100:14 101:3,5,5,14 103:8,10 tanks 34:9,11 41:18 target 72:19 9:6 45:6 49:18 62:20 63:5,6 75:12 tests 70:23 thank 7:19 8:7 thereabout 72:16 thereabouts 44:13 thereof 9:7 therminol 14:1 108:7 thing 17:4 24:17 storeroom 30:13 35:3 113:6,8,9,10,12 support targeted 66:22 28:10 16:18 79:16 storm sure 14:2 15:16,16 37:5 51:9,12 6:16 11:13 16:1634:14 technical 70:9 technician 51:14,16,20,21 55:16 story 36:13,16 37:6 55:13 56:18 56:21 82:12 84:4 96:15 46:8,13 technology 54:10 63:10 67:17 72:14 74:13 83:3 90:16 109:14 things 27:9 62:10 65:22 73:7,23 87:18 118:5 think 7:5,128:129:1 11:1525:6 16:22 stream 116:17 117:2 surface 62:21 63:3,8,19 65:10 66:1 66:19 67:6 69:10,14 83:18 26:7,11 28:23 29:8 34:17 35:8,15 37:10,11 39:20 23:11 38:13 88:12,18 89:1 20:3 103:4 street suspended 85:16 tell 41:17 54:9 72:8 74:11,20 75:9 85:4 94:8 101:18 2:1 stroke 30:2 94:7 structural 16:18 114:17,23 115:1 sutkus 106:5,10 swmu 102:20 10:19 35:17 36:1 43:1 56:21 58:3 75:2 84:9 92:10 94:15 109:2,5 118:9 telling 74:4 114:2,3 104:2,16,21 105:8,12 112:11 116:23 117:9 thinking 74:21 thirty 91:11,21,22 Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) HARTOLDMON0035028 [thought - wants] thought trace 8:10 43:9 48:21 63:4 65:16 38:12 74:12 94:1 104:12,13 tracked thousand 84:19,21 59:9 89:5,6 116:4,9 tracking threat 84:13 86:14 tract three 78:21 10:16 11:22 12:1,16,17 transcribed 15:6,7 16:22 25:17 36:6 120:14 40:9 43:16 58:18,19 59:10 transcript 59:12,12 103:13 112:5 120:15 tie transfer 13:18 14:19,22 till transformer 90:20 85:6 time transformers 5:10 6:23 8:10,13 9:1 15:22 84:16 17:5,1421:1222:1323:15 translate 27:3 29:8,17 43:12,20 10:7 44:13 46:15 55:19 58:23 transport 59:22 62:21 63:9 65:21 61:3 67:6 70:7,7 73:4,6,21 81:17 transportation 82:22 83:12 84:15 89:15 60:21 91:5 92:10,19 97:4 98:2,19 transported 104:7 111:3 113:9 120:18 15:19 23:3 39:16 timeframe treatment 7:15 73:19 45:1949:16 113:14 114:11 times 114:13,17 98:7 trees title 33:8,12,13,23 34:1 12:7 trial today 5:19 27:11 35:12 75:6 tributary told 93:5,8 74:17 76:22 77:21 80:7 tried 84:10 87:23 94:19 95:5,12 92:20 118:2 triggered tomorrow 110:12 97:14 trip tool 27:10 82:12 76:1 trips tools 83:4 70:2,6 truck top 14:8 31:8 39:3 39:2 41:21 54:12,19 115:8 trucks tops 21:1725:1326:18 30:22 true torn 120:15 27:23 truth totally 120:10,10,11 23:2 36:13 40:4,7 try toxic 13:18 53:8 113:20 74:7 trying toxicity 60:6 69:2 73:19 93:14 63:5 tsca use 72:16 74:7 5:5 10:1430:1562:19 turns 69:10 70:6 75:11 91:17 9:15 106:17 twelve v 30:5 59:11 88:17 101:23 vacuum 102:1,2 116:5,6 twenty 18:10,11,15,21 27:6,7,13 28:9 34:2,3,4,13 35:14 36:6 14:8 31:8 vaguely 96:3 valid 38:1839:11,1741:1446:9 81:12 tx 46:12,16 47:3,5,7,11 48:3,9 50:3 51:22 59:10 89:3,3,6 89:10,11 102:2 112:6 vegetative 55:2 verbal 30:2 1:1 type verify 59:14 15:2,5 24:2 40:11 42:16 102:16 typewritten 96:18 typically version 79:9,9 vessel 34:15 97:21 vessels 11:541:9 105:12 115:6 116:14 34:18 view u 24:9 39:20 41:17 54:11 ug viewed 52:8 73:5,10 uh virgin 10:12 13:11 15:1 25:19 23:2 45:10 47:18,21 58:11 96:6 visited underground 30:17 24:3 44:22 vs underneath 1:1__________________ 101:7 understand 35:5 40:1 62:14 63:23 69:12 understanding 73:9 unit 35:7 41:1799:14 united 1:1 units 102:20 unwittingly 77:20 upset 115:9 upsets 113:23 upside 52:16 upstream 19:6 w waited 67:9 waiting 67:16,21 waived 6:3 waiver 5:21 walk 13:3 walker 29:18 waiter 1:1 want 14:2 46:23 59:13 69:3,5 72:8 wanted 85:7 wants 75:21 Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) HARTOLDMON0035029 [warehouse - years] warehouse whereof wright (cont.) 17:2,3,13 18:22 24:11 27:1 121:2 17:21,23 18:1920:11 21:4 warehousing whichever 24:15,19 25:22 26:2,14 24:17 14:1 31:15,17 32:2 34:22 35:4,9 warn white 35:11 42:3,7,12,13 44:2 88:3 2:1 45:23 48:17 49:7 51:3 warned widely 52:15,17,21 53:2,5,21 54:2 77:10 75:13 54:14 55:7,13,14 57:19 washed wife 58:2 60:1561:11,18,23 91:10,10 29:15 62:12 63:13,21 64:9,20 waste william 65:8,15 66:5,8,14 67:20 45:19 49:15,15 97:7 102:20 2:1 68:3,10,23 69:23 70:10,12 113:14 114:11,14,17,18,18 winter 71:9,11 73:8 75:14 76:5,11 water 30:21 77:2,8,17 78:10,19 79:1,7 9:2,4,19 14:10 15:16 30:10 witness 79:17 80:14,20 81:9,21 30:15,16 37:5 42:17,18 8:20 10:1 18:18 21:2 24:16 82:7 83:22 84:7,8 85:17 44:14,15,23 45:2,3,11,11 25:23 26:1 31:16,23 35:8 86:2,19 87:9 88:2,14 89:4,8 45:19 47:8,19,22 49:15 42:20 45:10,13,16 49:3 89:16 90:4 91:8,16 92:13 51:9,12,14,17,20,21 55:16 50:21 53:4 54:11 60:13 93:6,16 94:3,14 95:3,9,20 57:7,8 98:21,22 99:15 61:16 62:9,19 63:18 64:7 96:12 99:21 100:2,16 102:9 101:4,4,5,8,11,13,16 64:16 65:7,13 68:1,9,20 104:3,22,23 105:14,18 106:14,16,16,18 109:15,17 69:20 70:5,20 71:23 75:5 107:6,13,19,23 108:17 111:23 112:3 114:18,19 76:10,17 77:6,15 78:1,18 109:8 110:16,20 112:18,21 115:8 79:15 80:12,18 81:8,15 115:21,22 116:19,23 117:1 waters 82:3 84:2 85:11,23 86:18 118:18,21 9:6 87:5,20 88:9 89:13,23 writing ways 90:16 91:17 93:1,12,20 19:1,1 25:14 94:13 95:2 99:23 100:13 written weather 104:9,18 105:9 107:4,10 31:1257:10 31:1 109:22 111:11 109:5 116:14 119:1 120:8 wrong weatherproofing 120:13 121:2 104:2 40:13 week 59:2 weekly 50:17 wells 111:7 went 27:5 36:15 42:14 64:18 77:10 84:17 101:19 west 17:19 26:17 36:17 37:2 westend women 81:4 wondering 58:5 116:7 woods 90:20 word 30:4 91:18 words 30:3 101:10 work 34:21 45:6 111:3,4,6 worked y y'all 18:7 30:12 yard 73:10 74:2 yeah 6:11 12:15 24:15 32:9 33:21,23 42:3 44:3 82:3 86:3 91:16 99:22 100:8,17 104:9 116:19 117:2,14 year 29:5 57:23 67:9,17,21 103:20,22 104:7 westinghouse 79:4 wests ide 54:17,19 109:21 78:6 117:5 worker 87:22 workers 78:6,13,16,22 81:16 82:16 27:8 44:22 70:3 71:7 73:18 78:7 80:2,16 82:20 83:4 89:3,3,11 91:11,21,22 92:6 97:15 99:13 110:2 wet working 109:22 111:11 32:23 53:10 90:11 we've world 7:5 8:8,15 33:2 54:3 63:4 75:16 103:17 wright wheelchair 1:1 3:76:11,15,197:5,19 29:20,21 8:6,22 9:11,14 10:6 17:10 Brown, Jerry (Anniston Monsanto Plant employee) in OWENS (2) HARTOLDMON0035030 HARTOLDMON0035031 I I HARTOLDMON0035032 HARTOLDMON0035033 HARTOLDMON0035034 -LlfMtr. #52584 35M M PRINTS HARTOLDMON0035035 HARTOLDMON0035036 JifWW liU lllic ? i ii'lh \\p!Sr'R C -LIN t #52584 35M M PRINTS HARTOLDMON0035037 Emm ,Xy'. / ,-1. '.r U rn'Sb D ^.. UfaS /hi!; HARTOLDMON0035038 HARTOLDMON0035039 HARTOLDMON0035040 HARTOLDMON0035041 HARTOLDMON0035042 HARTOLDMON0035043 HARTOLDMON0035044 HARTOLDMON0035045 r Pi 1 So >|T *^^7, "S&H 7f mZl*k'-k $ ^ "FV 9q tis>> Vv>^vxi HARTOLDMON0035046 HARTOLDMON0035047 L1 HARTOLDMON0035048 /*-//-/-o 3S f* i-f* * * y. HARTOLDMON0035049 HARTOLDMON0035050 %v ^ fe w HARTOLDMON0035051 HARTOLDMON0035052 HARTOLDMON0035053 HARTOLDMON0035054 HARTOLDMON0035055 HARTOLDMON0035056 HARTOLDMON0035057 Monsanto f - '> 5 MONSANTO RESEARCH CORPORATION / OAYTON LABORATORY / OAYTON. OHIO 45407 EASC - Dayton (DEPT/SECTION) Analytical TYPE OF REPORT REPORT ohx Uwi ux < sc u cMn a zeJ< 0. z o CO tr> cMn z Ez < E- >u Mo> z< bo 3 JJ Oa. cn CL M CO H x' X j Bt o <M Z f* ec " o .. xX U-Ii 3 <P REPORT NO.: MDA-176 JOB/PROJECT NO.: 4 08.1000 DATE: April 24 , 1981 PERIOD COVERED: TITLE: ANALYSIS OF ANNISTON PLANT DISCHARGES FOR PRIORITY POLLUTANTS AUTHORS: Robert F. Ivory ABSTRACT: Discharge samples from the MAP Anniston Plant were analyzed for the U.S. Environmental . Protection Agency's designated priority pollutants. The results of these analyses are presented in this report. Approved by U- J fx. Robert F. Ivory Environmental Analytical sciences Center Service Project Manager Approval date Li RESTRICTED DISTRIBUTION (see over) COMPANY CONFIDENTIAL TNa Mwmm ia ti tnmni af Manwnto KhmrIi Carparatnn and da iKVMn a taa*onala far la aMat and dapeamon. k containa CONnoiNTUl. INFORMATION wh*h mud not t raoroduead. rwaaoa a un*uiho.i<a anom or am emada Mamann Raw arch Corporation and Manama Company mahout prapar auherfcation. DSW 0B16S3 HARTOLDMON0035058 DISTRIBUTION COPY NUMBER 3 J. Brown, Anniston 4 D. J. Dahm 5 R. F. Ivory 6 T. J. Hoogheem 7 Central Files a Technical Reports Lbry. 1250 1250 1250 1250 R2C ABSTRACT ONLY R. K. R. M. NOTE: Distribution of this report is restricted. Requests for additional copies should be made through the principal contact at the Monsanto location involved or the Manager, Environmental Analytical Sciences Center, Dayton Laboratory, Dayton, Ohio. ACKNOWLEDGEMENT Contributions of the following Dayton Laboratory personnel to this project are gratefully acknowledged: . Analyses: M. R. Arnold S. A. Barksdale c. Feldstein J. A. Giust J. T. Miller D. L. Sharp T. L. Shell H. M. Strickland G. Thomas R'IOM(C) COMPANY CONFIDENTIAL When no longer needed, or upon request, return this report to Central Files, Dayton. 0W 0SI&64 HARTOLDMON0035059 1. INTRODUCTION Well water samples collected at the MAP Anniston Plant were sub mitted to the Dayton Laboratory for priority pollutant screening analyses. The analyses were conducted in accordance with the U.S. Environmental Protection Agency's (EPA) screening phase protocol for priority pollutants [1] . 2. SUMMARY All analyses were conducted according to the procedures developed and recommended by the U.S. EPA [1,2,3]. the organic priority pollutants observed in Anniston plant water samples are shown in Table 1. Although all the organic priority pollutants listed in Table 2 were investigated through either GC/MS or GC/EC screening analyses, only those pollutants observed at or above the screen ing level concentrations are reported. None of the Aroclors or pesticides listed in Table 3 were detected above their screening levels. The analytical results for the priority and nonpriority pollutant metals, as determined by atomic absorption (AA) and inductively coupled (ICP) spectroscopy, are shown in Table 4. Table 5 shows the quality control data for the metals analyses. Table 6 shows the detection limits for the metals concentrations. Table 7 shows the analytical results for the total phenol and cyanide concentrations in the water samples. ., re 3. SAMPLE COLLECTION samples timsm. collected by Anr.iston Plant personnel and submitted to the Dayton Laboratory for analyses. However, the sample for analysis of phenol in Discharge 005 had to be taken from the metals sample bottle. The container labeled "Arsenic" and preserved with NaOH to pH >12 was used for the cyanide analyses. 1 081665 HARTOLDMON0035060 TABLE 1. ANALYTICAL RESULTS FOR ORGANIC PRIORITY POLLUTANTS yg/L (ppb) Analyte Base/Neutral Fraction Bis-(2-chloroethyl)-ether Di-n-butyl phthalate Bis-(2-ethylhexyl) phthalate volatile Fraction Chloroethane Methylene chloride Trichloroethylene Benzene Toluene Sample ID Discharge Discharge 005 006 <10a <10 <10 NDb <10 <10 ND <10 10 <10 <10 <10 <10 <10 <10 <10 Blank. ND ND ND ND <10 ND <10 <10 a,,<" a compound observed but was below screening level. bND * compound was not detected. 2 OSH 061666 HARTOLDMON0035061 TABLE 2. PRIORITY POLLUTANT SCREENING LEVELS GC/MS ANALYSIS OF ORGANICS IN INDUSTRIAL EFFLUENTS Compound held a: 2-Chloropher>ol 2-Nitrophcnol Phenol 2,4-Di*ethylphenol 2.4-Crchlorephenel 2.4.6-Trichiorophe nol 4-Chlero-3-methylphenol 2.4-Dinitrophenol 2-Hthyl-4,*-dinitrophenol Pentaehlorophenol 4-tu trophenol Volatileci Chloromethane 01 chlorodif luoromathane Bromomethane vinyl chloride Chloroethane Hachylene chloride Triehlorofluoromathane 1,1-Oichloroethylene 1.1-01ehloroe chine Trcrj -1,2-dichloroethylene Chloroform 1,2-Oichloroechine 1.1,1-Tr1ehloroethine Carter. cecnchlorlde 1rowedleh1oromechine Ok(chloromechyl) ether 1.2-01ehloroprofine Throe-1,J-dlchloropropene Trichloroethylene OihroaoehloroeM chine Cit-l,2-dlchloropropene 1,l,2-7Yichloroethane Benzene 2-Chloreethyl vinyl ether BrcmofanP TetradUoroechylene 1,1,2, VlBKXeehloroathane Toluene* Chlorohiftiene Ethylbenzene Direct Injeetableci herolein hcrylonierlle Screening level, VO/1 Compound Screening level, vo/1 Baee/Heucrala i 25 1,3-Dichlorobenzene 10 25 1,4-Diehlorobencene 10 25 Me cachloroethane 10 25 1,2-Dichlorobencene 10 25 Bia(2-chloriaopropyl) ether 10 25 Meccchlorobutadiene 10 25 1,2,4-tt ichlorobenzene 10 250 Mephthelene 10 250 Biz(2-chloroethylJ ether 10 25 Hexachlorocyclopentadienc 10 25 Nitrobenzene 10 Biz 12-chloroethozy) methane 10 2-Glleronaphthelane 10 acenaphthylene 10 Beenaphthene 10 10 10 10 ' laophorone 10 10 Fluerene 10 10 2,6-Dlnitroteluene 10 10 1,2- Uphenylhydra*ine 10 10 2,4-0inltrotoluene 10 10 N-nltroaodlphenylaaine 10 10 Nexachlorobenaane 10 10 4-Broeophenyl phenyl ether 10 10 Phenanthrene/anthracene 10 10 Dimethyl phchelate 10 10 Diethyl phthalace 10 10 Fluoranthene 10 10 Pyrene 10 10 Di-n-butyl phthalace 10 10 Benzidine 10 10 Butyl benzyl phthalate 10 10 Chryaene 10 10 Bla(2-ethylbexyl) phthalate 10 10 Bant(a > anthracene 10 10 BanaeID) fluoranthene 10 10 BensoIB)fluoranthene 10 Banco(a)pyrene 10 indeno11.2,3-ed)pyrene 10 Dibanco 1a,h)anthraeene 10 Banco(g,h,i)pery1ane 10 10 25 25 25 10 M-Mltroaodiaethy1aaine 10 10 N-ni troaodi-n-pz opylaaune . 10 10 4-OUorophenyl phenyl ether 10 2,3'-Dichlorobencidisa 10 Di-n-oetyl phthalate 10 200 100 Paatieidea and Broclora . 1.0 (aee Table 3) OSW 081662 HARTOLDMON0035062 TABLE 3. SCREENING LEVELS FOR PESTICIDES/PCB's EXTRACTABLE PRIORITY POLLUTANTS Compound B-Endosulfan a-BHC y-bhc S-BHC Aldrin Heptachlor Heptachlor epoxide a-Endosulfan Dieldrin 4,4*-DDE 4,4'-DDD 4,4'-DDT Endrin Endosulfan sulfate 6-BHC Chlordane Toxaphene Endrin aldehyde Methoxychlor Aroclor 1242 Aroclor 1254 Aroclor 1221 Aroclor 1232 Aroclor 1248 Aroclor 1260 Aroclor 1016 GC/MS Screen, GC/EC, ____________ V3/It .. . vg/L 10 1 10 1 10 1 10 1 10 1 10 1 10 1 10 1 10 1. 10 1 10 1 10 1 10 1 10 1 10 1 10 1 10 1 10 1 10 1 10 1 10 1 10 1 10 1 10 1 10 1 10 1 4 OSW 081666 HARTOLDMON0035063 TABLE 4. ANALYTICAL RESULTS FOR PRIORITY METAL POLLUTANTS ug/L (ppb) Analyte Arsenic & Mercury Selenium Thallium Antimony Beryllium Cadmium Chromium Copper Lead Nickel Silver Zinc Sample ID Discharge Discharge 005 006 3 <1 <4 <100 <250 2 <35 215 106 756 <120 <170 35 6 <1 <4 <100 <250 <2 <35 141 60 <345 <120 <170 180 Analyses by AA; all others by ICP. 5 DSW 081669 HARTOLDMON0035064 TABLE 5. QUALITY CONTROL DATA FOR METALS ANALYSES yg/L (ppb) Reference Standard ICP Standard Silver Beryllium Cadmium Chromium Copper Nickel Lead Antimony Zinc TM-7 Arsenic SRMA Arsenic Selenium ERA 1916 Arsenic Selenium SPEX B Mercury SPEX A Thallium TM-CI Mercury TW-2 ? Thallium Observed Value True Value Percent Recovery 1,010 171 53 371 1,320 1,080 920 1,040 372 1,000 165 50 320 1,230 1,000 1,000 1,000 330 101 104 106 115 107 108 92 104 113 38 35 107 78 77 102 13 11 117 67 84 80 22 25 89 10 10 100 100 125 125 20 21 104 1,000 990 99 Discharge 005 spiked with ICP Standard 83% recovery ' 6 osu 081670 HARTOLDMON0035065 TABLE 6. DETECTION LIMITS AND LQD* CONCENTRATIONS FOR METALS AS OF APRIL 1981 Atomic absorption metals analysis Detection limit, Element ug/liter Arsenic Mercury Selenium Thallium 5 1 5 100 Element ICP metals analysis Detection limit, LQD cone., ug/liter ug/liter Aluminum Antimony Barium Beryllium Boron Cadmium Calcium Chromium Cobalt Copper Iron Lead Magnesium Manganese Molybdenum Nickel Silver Sodium Strontium Tin Titanium Vanadium Zinc 50 2 0.4 16 7 25.6 7 20 14 8 69 0.6 0.8 27 14 34 1,400 2.2 28 10 12.8 0.3 180 250 10 2 80 35 128 35 100 70 40 345 3 4 135 120 170 7,000 11 140 50 64 15 aLQD * lowest quantitatively determinable concentration (95% confidence limits). 7 OSH QSltU HARTOLDMON0035066 TABLE 7. ANALYTICAL RESULTS FOR TOTAL PHENOL AND CYANIDE vg/L (ppb) Sample ID Discharge Discharge Analyte________ QOS___________ 006 Cyanide Phenol <4 <25 <4 29 QUALITY CONTROL DATA Reference Standard Observed Value, V<f/L True Value Ud/L ERA 2767 - Cyanide ERA Light Orange - Phenol ERA Dark Orange - Phenol 40 171 727 41 204 900 Percent recovery 98 84 81 8 OS* 081672 HARTOLDMON0035067 4. PRIORITY POLLUTANT ANALYTICAL PROCEDURES Analytical procedures developed and recommended by EPA [1,4] were used throughout this project. It is important to realize that the analysis scheme for analyzing for organic priority pollutants is a screening procedure, and is therefore a qualitative, semiquantitative analysis. Some of the organic priority pollutant analytical methods are still under development and require fur ther verification and validation. Therefore, the data presented for organic species serve to identify which of the organic pollut ants were present and to indicate their general concentration ranges. The accuracy of these data may vary by a factor of 2 to 10, depending on the overall composition and concentration of the materials present. Two of the 129 priority pollutants were not determined in the project: 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) and asbestos. The EPA Environmental Monitoring and Support Laboratory (EMSL) recommends that TCDD be omitted because of its extreme toxicity and the potential health hazard involved in preparing standard solutions in the laboratory from the pure compound [1], and therefore, the compound is not included as part of our routine screening procedures. There is presently no EPA-approved method for the determination of asbestos fibers in wastewater. The analytical procedure used [1] divides the 129 priority pollut ants into six basic categories: volatile organics, extractable organics, metals, cyanide, total phenol and asbestos. The follow ing sections outline the analytical procedures and the EPAapproved Dayton Laboratory's modifications for analyzing each group of priority pollutants. SM 08L6 73 HARTOLDMON0035068 4.1 Extractable Organics The 129 priority pollutants contain 81 solvent-extractable organic compounds that can be separated by gas chromatographic methods. Extractable organics are divided into three groups for analysis: base/neutral organics, acid organics (phenols), pesticides and Aroclors. Compounds classified as extractable organics are listed by these groups in Table 2. The analytical procedure for extractable organics is described in Reference 1. Figure 1 depicts the sample processing scheme for the base/neutral and acid fractions. A 1-liter aliguot of the extractable organics was made alkaline (pH >11) with sodium hydroxide, and the organic base/neutral compounds extracted with methylene chloride. -i`.v. Figure 1. Sample processing scheme for the analysis of the base/neutral and acid fractions of extractable organics. 10 OSM 081674 HARTOLDMON0035069 The residual aqueous phase was acidified (pH <2) with hydro chloric acid, and the organic acids were then extracted with methylene chloride. The methylene chloride extracts, one containing the base/neutral organics and the other the acidic organics, were dried on columns of anhydrous sodium sulfate. These dried extracts were concen trated to 1.0 mL in Kuderna-Danish (X-D) evaporative concentrators. The concentrates were sealed in septum-capped vials and stored at 4C until analysis. Gas chromatographic/mass spectroraetrie (GC/MS) analysis was conducted using SF-2250-DB and SP-1240-DA GC columns for the base/neutral and acid extracts, respectively. Each sample was spiked with deuterated anthracene (an internal standard) immediately prior to analysis at the GC/MS. The sample processing scheme used for pesticides and Aroclors is* shown in Figure 2. A 1-liter aliquot of the original extractable organics sample was adjusted to a pH of 6.5 to 7.5 using either 50% NaOH or concentrated HC1, and the pesticides and Aroclors were extracted into a 15% methylene chloride/hexane solution. The organic phase was separated and the sample cleaned up by acetonitrile partition. Following the cleanup procedure, the samples were screened by gas chromatography on SP-2250/SP-2401 and 3% QV-101 columns, utilizing an electron capture detector. 4.2 Volatile Organics Table 2 v* those priority pollutants classified as volatile organics.^^^je-recommended method for volatile organic analysis was designed by EPA for determining those chemical species which are amenable to the Bellar purge and trap method [1,4]. Hermetically sealed 40 mL glass vials collected from each of the sampling points were composited in the laboratory for one analysis of each sampling point. 11 SW <*16 7.5 HARTOLDMON0035070 Figure 2. Sample processing scheme for pesticides and Aroclor analysis. Two laboratory composite solutions were prepared, one for analysis and one as a backup sample. Figure 3 is a simplified diagram of the analytical scheme used for volatile organics analysis. An internal standard, 1,4-dichlorobutane, was added to 5 mL of the composited sample, and this spiked sample was sparged with helium onto a Tenax-GC silica-packed sample tube. Analyses were completed using a Hewlett-Packard 5981 GC-mass spectrofjjgtometer with a S937 data system. Sample tubes were heated 1S0#C over a 1-minute period and held at that temper ature fio#*'#' minutes to desorb the compounds onto a Carbowax 1500 column held at -4*C. For compounds with boiling points below room temperature, cryogenic trapping at -40#C (liquid nitrogen cooling) generally provides better reproducibility of retention time than does the suggested protocol temperature of 30C. After desorption, the GC column temperature was raised at 8*C/minute to OSM 08L676 HARTOLDMON0035071 Figure 3. Analytical scheme for volatile organic analysis. Qualitative identification of a compound was made using the three criteria listed in the protocol Cl]: 1) the characteristic ions must be found to maximize in the same spectrum, 2) retention time must coincide with known retention times, and 3) ratios of the three characteristic masses must stand in the proper known propor tions. Quantification of volatile organics was made using response ratios to the 1,4-dichlorobutane standard. 4.3 In addition to extractable and volatile organics, the 129 prior ity pollutants include 13 metals which are to be analyzed for under the protocol. Four metals (arsenic, mercury, selenium, and thallium) are analyzed by atomic absorption (AA) spectroscopy. All other metals were determined by an inductively coupled plasma (ICP) excitation technique. 13 081677 HARTOLDMON0035072 4.4 Total Cyanide Total cyanide was determined according to the conventional wet chemistry technique described in Reference 3. Spiked samples and independent standards were included with the plant samples for quality assurance. 4.5 Total Phenol In addition to specific phenolic compounds and phenol measured by GC/MS, total phenol was also measured by typical wet chemistry techniques [1-3], Independent phenol standards were also analyzed for quality assurance. 5. REFERENCES 1. Draft Final Report: Sampling and Analysis Procedures for Screening of Industrial Effluents for Priority Pollutants. U.S. Environmental Protection Agency, Cincinnati, Ohio, April 1977. 145 pp. 2. Manual of Methods for Chemical Analysis of Hater and Hastes. EPA-625/6-76-003a (PB 259 973). U.S. Environmental Protec tion Agency, Cincinnati, Ohio. 319 pp. 3. Standard Methods for Examination of Hater and Hastewater, Fourteenth Edition. American Public Health Association, Hashington, D.C., 1976. 1193 pp. 4. EPA Guidelines Establishing Test Procedures for the Analysis of Pollutants; Proposed Regulation, Federal Register, Monday, December 3, 1979. OSH 081678 14 HARTOLDMON0035073 AUTHORS: R. F . I v o r y TITLE: A N A LY S IS OF ANNISTO N WASTEWATER FOR P R IO R IT Y POLLUTANTS Monsanto MONSANTO RESEARCH CORPORATION / DAYTON LABORATORY / DAYTON, OHIO 45407 SASC-Dayton 10EPT/SECTION) Analysis TYPE OP REPORT REPORT REPORT NO.. MDA-14 9 JOB/PROJECT NO.: 409.17 50 DATE: January 9, 19 81 PERIOD COVERED: TITLE: ANALYSIS OF ANNISTON WASTEWATER FOR PRIORITY POLLUTANTS AUTHORS: Robert F. Ivory ABSTRACT- A water sample from the MAP Anniston Plant was analyzed for the U.S. Environmental Protection Agency designated priority pollutants. The results of the analyses are presented in this report. APPROVED BY:. A Robert F. Ivory r~) Environmental Analytical Sciences Center Service Project Manager APPROVAL DATE: // C / j. RESTRICTED DISTRIBUTION (see over) COMPANY CON FIDENTIAL Thi* document < tfa prooony of Monsanto ftaaotreii Co/porit** and tfco roc*m n rsoons/bi for *u af*MpAg and diaooamon it contact CONFIDENTIAL INFORMATION wh<ft muc not bo oroducod rovooiod to unauthorized Boraono or aont outudo Monumo Roaearth Corporation and Monsanto Co^oany without orootr authorcaten DSR Oidbi^t M D A -149 /. HEPT.NO.. COPY NO : HARTOLDMON0035074 1. INTRODUCTION A water sample collected at the MAP Anniston Plant was submitted to the Dayton Laboratory for priority pollutant screening anaivses. The analyses were conducted in accordance with the U.S. Environ mental Protection Agency's (SPA) screening phase protocol for priority pollutants [1]. 2. SUMMARY All analyses were conducted according to procedures developed and recommended by the U.S. EPA [1, 2, 3]. The organic priority pollutants found m the Anniston Plant water sample are shown m Table 1. Although all the organic priority pollutants listed m Table 2 were investigated through GC/.MS screening analysis, only those pollutants observed at or above the screening level concen trations are reported. None of the extractable organic pollutants or the Aroclors and pesticides listed m Table 3 were detected above their screening level. The analytical results for the priority and non-priority pollutant metals, as determined by atomic absorption (AA) and inductively coupled argon plasma (ICAP) spectroscopy, are shown in Table, 4. Table 5 shows the detection limits for the metal concentrations. Tables 6 shows the quality control data for the metals analyses. Table 7 shows the analytical results for the total phenol and cyanide concentrations m the water sample. 3. SAMPLE COLLECTION Samples were collected by Anniston Plant personnel. Samples were received at the MRC Dayton Laboratory in the designated EPAaporoved sampling containers. 1 DSh 03dd3 5 HARTOLDMON0035075 TABLE 1. ANALYTICAL RESULTS FOR ORGANIC PRIORITY POLLUTANTS, ug/L (ppb) Analyte________ Volatile organics Methylene chloride Tnchlorof luorome thane Trichloroethylene Benzene Toluene Sample ID AL-0001201 20 <10 10 <10 10 a"<" means compound was observed but was below screening level. 2 DSm 0 3dd3 HARTOLDMON0035076 TA3LE 2. PRIORITY POLLUTANT SCREENING LEVELS GC/MS ANALYSIS OF ORGANICS IN INDUSTRIAL EFFLUENTS Command Scrtansnq laval, .. -S/I. icidi 2*'C?i*or9pftnal 2-Nitxopntnoi Phtnol 2. 4-3inst.*iy Iphtnol 2.4-CisAlorcphnnol 2.4.5-Trichloropnanol S-CMoro-l-nttny ipntnol 2.4-Oinitrepftanol 2-atthyi-4.6-dinisropflanol PantsCAlOrapntnel 4-mirapAanal 25 25 25 25 25 25 25 250 250 25 25 'oist.las Cilarontt.'iant Ot r-loxadi f luoronatlusna lrsaontiAsna Vmy 1 clUonda OilarattAsna Hats-/lan a enlarida Tr.rn1o ro f1uo rant :.14H4 l.i-CiSt-.larassAylans X, l-3ishioraat!iaJit ftrtr-l. 2-dicAloroacfiylant Ch.arcfora 1.2-3icni3reatAan4 1.1,1 -Tr icMotat tnsnt Catpo.* tsixacAiarldt Ironedis.'.iorantiRana BiS'SMaranttiyil ttAar 1, l-Slc.-lcrsprapant . Tr^-s-l,3-dieniorapropana Tr . rniorat tfi, lea* S.^rsaopMarsnaW* f-.j-..3-d. st-.Iarsprapana 1, 1,2-TT-criiaxottliAna Banxana 2-Ciioroat.*-.yl amyl athar Iranofarr TtaracMoroatAylana 1.1,2.2-TtracAleroathana Toiuana CJiiorobansana ts.lylbanxana 20 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 srsct In;actsblas Acrolain Aexylanscri Is 200 100 Caapound Scraanin? lava!. va/L lata/Hsutrait: 1, 3-Qichlorob*n**n* 1.4-OlcMorabenxtn* Haxsehle reatiiana 1 T2-D*5.McrebA**n Sis (J-cfUoriMprapyU thr Hassehlerobutadsana i, 2 ,4-Tricftloro6nxsA MpRtAslana (as(2-eftloroattiyll athar HasaeMorocyelopantsdsant Hi tronar.sant Bis(2-cBiOroaehory) aathsna 2-Cilorcn*pht2ialtnt Aetnapfttdy1aaa Acsnspftanana Isopnorana fluarana 2,6-Oini txaeoluana 1.2-0iphanylhydxszina 2.4~DiaitT9taluA N-ftmosodipAsnylsmins HasscMarabaiuana 4-lranopAanyl phanyl athar Phansnaftrana/anthraeant Dmatftyl pntbalsta Dittftyl phtnalata riuorsr.msns tyrant Di-n-buiyl pbtftalasa (anzid.r.a ' Butyl banxyl phtftslata Cirytana lit !2-aaAylfta*yl) phtUslsta Bans !a) ar.tftractna Bansa(b> dluorantnana Banse(k)lluorantnant Banco Ulpyrant Indano(1.2.3-edlpyrana Cibar.xa (s. n) anthx scant Baaxe(p.Ii.ilpnrylana 14-Hi trasodaaa thy 1saint N-nitsasodi-n-prapylsduna 4-Chlaraphanyl pnanyl athar 2.3'-Dieftlorobansidsna Di-n-octyl pftiftsista . 10 IC 10 10 10 10 10 10 lc 10 10 1C 10 10 10 1C 10 10 10 10 10 10 10 10 10 10 10 i: 10 10 10 10 1C i: 12 10 10 25 25 25 10 10 10 10 Pasticidas and Axaclars (sat Tsais 31 12 -- 3 DSW U3dd3? HARTOLDMON0035077 TA3LZ 3. PRIORITY POLLUTANT PESTICIDES AND AROCLORS Compound S-Endosulfan ot-BKC Y-3HC S-3HC Aldrin Heptachlor Heotachlor epoxide a-Endosulfan Dieldnn 4,4'-DDE 4,4'-DDD 4,4'-DDT Endrin Endosulfan sulfate d-BHC Chlordane Toxaphene Endnn aldehyde Aroclor 1242 Aroclor 1254 Aroclor 1221 Aroclor 1232 Aroclor 1248 Aroclor 1260 Aroclor 1016 GC/MS Screen, (uc/L) 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 . GC/EC, (jc/L) 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 4 US'* 03 ad 3a HARTOLDMON0035078 TABLE 4. ANALYTICAL RESULTS FOR PRIORITY AND NON-PRIORITY METAL POLLUTANTS, ug/L (ppb) Analyte______ Priority A. rsenic a Mercury Selenium4 Thallium4 Antimony Beryllium Cadmium Chromium Copper Lead Nickel Silver Zinc Non-priority Aluminum Barium Boron Calcium Cobalt Iron , Magnesium Manganese Molybdenum Phosphorous Silicon Sodium Strontium Tin Titanium Vanadium Potassium Sample ID AL-000I201 <5 <1 <5 <100 <140 <3 <20 <30 <30 <205 <250 <150 15 <245 21 95 2.30 x 10" <45 100 1.06 x 10" 35 <60 <315 6.45 x 103 6.59 x 103 34 <90 <10 86 3.18 x 103 Note: All ICAP data repre sent duplicate analyses. aAnalyses by AA? all others by ICAP. 5 DSw 033639 HARTOLDMON0035079 TABLE 5. DETECTION LIMITS AND LQDa CONCENTRATIONS FOR METALS Atomic absorption metals analysis Element Detection limit r ug/liter Arsenic Mercury Selenium Thallium 5 1 5 100 Element I CAP metals analysis Detection limit, ug/liter LQD cone.,a ug/liter Aluminum Antimony Barium Beryllium Boron Cadmium Calcium Chromium Cobalt Copper Iron Lead Magnesium Manganese Molvbdenum Nickel Phosphorus Silicon Silver Sodium Strontium Tin Titanium Vanadium Zinc 49 28 0.7 0.6 5 4 1 6 9 6 4 41 0.7 1, 12 50 63 29 30 71 0.7 18 2 8 4 245 140 3.5 3 25 20 5 30 45 30 20 205 3.5 5 60 250 315 145 150 355 3.5 90 . 10 40 20 aLQD * lowest quantitatively determinable con centration (95% confidence limts). 6 Qd H OJdd^U HARTOLDMON0035080 TABLE 6. QUALITY CONTROL DATA FOR METALS ANALYSES, ug/L (ppb) Reference material ICAP Standard Barium Boron Cadmium Cobalt Chromium Copper Manganese Molybdenum Observed value 19 155 33 31 46 35 73 42 True value 20 150 30 30 40 30 70 40 Percent recover/ 95 103 110 103 115 117 104 105 TABLE 7. TOTAL PHENOL AND CYANIDE CONCENTRATIONS, yg/L (ppb) Analyte Phenol Cyanide Sample ID AL-QQQ1201 <50 <0.005 Quail ty control data Observed True Reference material value value Percent recovery ERA 2913 Phenol Phenol ERA 7711 Cyanide 369 930 0.261 360 900 0.275 103 103 95 Sample split First value Second Relative value difference AL-0001201 Phenol AL-0001201 Cyanide <50 <0.005 <50 <0.005 >0 >0 7 csw Uidd't l HARTOLDMON0035081 4. PRIORITY POLLUTANT ANALYTICAL PROCEDURES Analytical procedures developed and recommended by ?a [1] were used throughout this project. It is important to realize that the analysis scheme for analyzing for organic priority pollutants is a screening procedure, and is therefore a qualitative, semiquantitative analysis. Some of the organic priority pollutant analytical methods are still under development and require further verification and validation. Therefore, the data presented for organic species serve to identify which of the organic pollutants were present and to indicate their general concentration ranges. The accuracy of these data may vary by a factor of 2 to 10, depending on the overall composition and concentration of the materials present. Two of the 129 priority pollutants were not determined in the project: 2,3,7, 8-tetrachlorodibenzo-p-dioxm (TCDD) and asbestos. The EPA Environmental Monitoring and Support Laboratory (EMSL) recommends that TCDD be omitted because of its extreme toxicity and the potential health hazard involved in preparing standard solutions in the laboratory from the pure compound [1], and therefore, the compound is not included as part of our routine screening procedures. There is presently no EPA-approved method for the determination of asbestos fibers in wastewater. The analytical procedure used [11 divides the 129 priority pollut ants into six basic categories: volatile organics, extractable organics, metals, cyanide, total phenol, and asbestos. The following sections outline the analytical procedures and the EPAapproved Dayton Laboratory's modifications for analyzing each group of priority pollutants and selected non--priority pollu-a.. a DSw Qdoct't^ HARTOLDMON0035082 4.1 Extractable Organics The 129 priority pollutants contain 81 solvent-extractable organic compounds that can be separated by gas chromatographic methods. Extractable organics are divided into three groups for analysis: base/neutral organics, acid organics (phenols), pesticides and Aroclors. Compounds classified as extractable organics are listed by these groups in Table 2. The analytical procedure for extractable organics is described m Reference 1. Figure 1 depicts the sample processing scheme for the base/neutral and acid fractions. A 1-liter aliquot of the extractable organics was made alkaline (pH >11) with sodium hydroxide, and the organic base/neutral compounds extracted with methylene chloride. Figure 1. Sample processing scheme for the analysis of the base/neutral and acid fractions of extractable organics. 9 QSh 03do43 HARTOLDMON0035083 The residual aqueous phase was acidified (pH <2) with hydrochloric acid, and the organic acids were then extracted with methviene chloride. The methylene chloride extracts, one containing the base/neutral organics and the other the acidic organics, were dried on columns of anhydrous sodium sulfate. These dried extracts were concen trated to 1.0 mL in Kuderna-Danish (K-D) evaporative concentrators. The concentrates were sealed in septum-capped vials and stored at 4C until analysis. Gas chromatographic/mass spectrometric (GC/MS) analysis was conducted using SP-2250-DB and SP-1240-DA GC columns for the base/neutral and acid extracts, respectively. Each sample was spiked with deuterated anthracene (an internal standard) immediately prior to analysis at the GC/MS. The sample processing scheme used for pesticides and Aroclors is shown in Figure 2. A 1-liter aliquot of the original extractable organics sample was adjusted to a pH of 6.5 to 7.5 using either 50% NaOH or concentrated HC1, and the pesticides and Aroclors were extracted into a 15% methylene chloride/hexane solution. The organic phase was separated and the sample cleaned u? by acetonitrile partition. Following the cleanup procedure, tne samples were screened by gas chromatography on SP-2250/SP-2401 and 3% OV 101 columns, utilizing an electron capture detector. 4.2 Volatile Organics Table 2 lists those priority pollutants classified as volatile organics. The recommended method for volatile organic analysis was designed by EPA for determining those chemical species which are amenable to the Beliar purge ar.d trap method [1] . Hermetically sealed 40 ml glass vials collected from each c: the sampling points were composited m the laboratory for cr.e analysis of each sampling point. Two laboratory composite 10 HARTOLDMON0035084 Figure 2. Sample processing scheme for pesticide and Aroclox analysis. solutions were prepared, one for analysis and one as a backup sample. Figure 3 is a simplified diagram of the analytical scheme used for volatile organics analysis. An internal standard, 1,4-dichlorobutane, was added to 5 mL of the composited sample, and this spiked sample was sparged with helium onto a Ter.ax-GC silica-packed sample tube. Analyses were completed using a Hewlett-Packard 5981 GC-mass spectrophotometer with a 5937 data system. Sample tubes were heated to 180aC over a 1-minute period and held at that temper ature for 4 minutes to desorb the compounds onto a Carbowax 1500 column held at -40#C. For compounds with boiling points below room temperature, cryogenic trapping at -40aC (liquid nitrogen cooling) generally provides better reproducibility of retention time than does the suggested protocol temperature of 30C. After desorption, the GC column temperature was raised at 8aC/minute to 170aC. 11 HARTOLDMON0035085 Figure 3. Analytical scheme for volatile organics analysis. Qualitative identification of a compound was made using the three criteria listed in the protocol [1]: 1) the characteristic ions must be found to maximize in the same spectrum, 2) .retention time must coincide with known retention times, and 3] ratios of tne three characteristic masses must stand m the proper known procor- tions. Quantification of volatile organics was made using response ratios to the 1,4-dichlorobutane standard. 4.3 Metals In addition to extractable and volatile organics, the 129 priority pollutants include 13 metals which are to be analyzed for under the protocol. Four metals (arsenic, mercury, selenium, and thallium) are analyzed by atomic absorption (AA) spectroscopy. All other metals would be determined by an inductively coupled argon plasma (ICAP) excitation technique. 12 0 S n OJo d<to HARTOLDMON0035086 4.4 Total Cvam.de Total cyanide was determined according to the conventional wet chemistry technique described m Reference 3. Spiked samples and independent standards were included with the plant samples for quality assurance. 4.5 Total Phenol In addition to specific phenolic compounds and phenol measured by GC/MS, total phenol was also measured by typical wet chemistry techniques [1-3]. Independent phenol standards were also analyzed for quality assurance. 5. REFERENCES 1. Draft Final Report: Sampling and Analysis Procedures for Screening of Industrial Effluents for Priority Pollutants. U.S. Environmental Protection Agency, Cincinnati, Ohio, April 1977. 145 pp. 2. Manual of Methods for Chemical Analysis of Water and Wastes. EPA-625/6-76-003a (PB 259 973). U.S. Environmental Pro tection Agency, Cincinnati, Ohio. 319 pp. * 3. Standard Methods for Examination of Water and Wastewater, Fourteenth Edition. American Public Health Association, Washington, DC, 1976. 1193 pp. 13 QS* 03dd4-7 HARTOLDMON0035087 HARTOLDMON0035088 ENVIRONMENTAL TESTING and CERTIFICATION CORPORATION OSNIS C.K. UN. Pfi-D. V/C* President Rtsaarcn ana Operations July 15. 1983 Mr. Robert Cheevers Monsanto Company P.0. Box 249 Hwy 202 West Anniston, AL 38202 Dear Mr. Cheevers; We are pleased to submit the accompanying reports in response to your testing requirements. We are confident that the results are of the highest quality. If you have any questions regarding your report, we encourage you to contact any one of the following persons in our Client Service organization; Deb Holton (201) 225-6742 Pat Mclsaac (201) 225-6751 Janet Zimmermann (201) 225-6722 They will coordinate your inquiries with the appropriate technical personnel. Your account executives, along with our Client Service organization are also available to assist you in defining requirements for future testing programs. If we can be of further service to your organization in the DCKL:rp Attachments 2U PiRITAN CENTER PARKWAY . EDISON. NJ 0037 CSw u3od!t9 (20V 225 SSOO HARTOLDMON0035089 rTA snvircnvsntal Sm l TEST'NG iC CERTIFICATION TA81E OF CONTENTS Introduction Results Taoie 1 Results and Quality Assurance Oata Taoie 2 Method Rer-crmance Data Methodology OA Protocol Report Appendices Appendix A Appendix B Cfiam-ol-Custody Record QSW UidaoO --1 HARTOLDMON0035090 C/U S7,NG>r>a CS*7,fiiCA?'CN INTRODUCTION Tn 'sccrt contains the analytical results cn ycur water samcle. CCCi 060332 23CC 'a sucmittac cn June 'C, 1933. it .s designed to satisfy tne neecs of your ceocie a: varp'us levels n your organization ~ Tne 'esuts we detained on your saroie ara oresanted m a tacuiar format mmeoia-a , after tns .ntrocucticn inctuoec *vim tne samcle 'esuts. tne quality assurarce da'a cn ycur scecmc sample are taDUatea to verify the validity of the results detained Tne quality assurance data include those cotamed an the Surrogates, the stark. the scivec biann tne 'ecnca's ana the soiled sample (commonly known as matrix soive) aisc presentee n the quality assurance data 'epcrt s 'he /er f caNon of the orcoer funct.or.rg of the .nstruments used The gas chromatograms arc/cr mass seectra generated n *^e analys.s of ycur sample are included m the Apcencix of the report The cram of custccy record `or ycur sample is included at the end of this report Tne estaousnea methods we usee m-the analysis of ycur sample are cescr.eed /r me Methcccicgy section after the Pesul's in the analysis we fo/lowea a r-giciy cort'cnec Quality Assurance R'otocol This Protocol is desor.ped arter the Methcccicgy section We nope our report format is useful m ass.st.ng you to ootain pertinent mferma? cn c' your sampie RESULTS Tre 'esuits octameo on your sample and the acoomcanyirg ouauty assurance sa'a 5'a listed .n Taoie t. The compcunes of interest are iistac w*- *her nP2S (Na'-cnai so'i-:cr Cisc*arge Elimination System) numoer. arc Method Oe'ecticn ^irmt (MOD ous-sr.eo r f-e Fecerai Register. DecemPe' 3, 1979 When a ccrccund .s detected ceiow its MCu .t is reported in Tacie t as 3MCL (Beiow Method De'achcn Lmit) Wheo a comoounc is searched for and cannot se found is reocrtec as nC (Net Cetected! Tne cuai.ry assurance data 'nciuoe resui's octainec on the Methcc Slark, Spiked Eianx, Recreate arc Mafix Spike analyses However, s^ce the Repncare anc Matrix Soika analyses we'a perfermec on samples ranccmly cnosan >n a sample catch, your soec.fic sample ma/ ic :e the selected one Tne data on tne recovery of the surroga'as m your sample anc the eert,f ca* c" c fe GC/MS systems used in the analysis of your sample are ustec .n Taoie 2 Tne Cham-of-Custcdy Record cn your sample >s also inc'uoed at 'he ere c " s Pecort OS* 03do5L HARTOLDMON0035091 C / U Mrtcf#-->* fHYfAOHttttNTAL TeSTlNQ CiATtHCATtOH . __ _ -- , TABLE 1: QUANTITATIVE RESULTS and QUALITY ASSURANCE DATA Volatile Compounds - GC/MS Analysis Data (QROI) Junt 11. tin Chain at Cuatarty Out Haquhat tat gTC Ml MMifUMiw Summary hagotu C3986 Momenta Co AM1ST0N 0901 060883 0800 24 fic l8#t8 N. Ceew*r Facility leapt* NUI |4U llai Mown NPDE5 Number Compound IV Acrolein 2V Acrylonitrile JV B*nin* 4V bl *(Chloro#thyl )l!fir 5V Bromotorm 6V Carbon letrachlorldo 7V Chlorobanxofl* 8V Chlorodibroaomtheno 9V Chlorotlhfcna 10V 2-Chloraethylvlnyl other 1iV Chloral or* 12V DichlorobromoMtlunc 13V Dlchlarodillu*rom*lhan 14V 1.1-Oichioroothint 15V 1,2-Dlchloraethono 16V 1 , l -Dichloroethyline l?V 1,2-Otchloropropooo 18V 1,3-DichIorapropylone 22V Methylene chloride 23V 1,1,2.2-Totreehloroethene 24V Telrechloroelhylenu 25V 1,2-lrons-dichloroethyleiie 2?V 1.1.I-Trlchloroetheno 28V 1 ,1 .2-Tnchloroalhano 31V Vinyl chloride Roiulti Staple Coneon. uo/l HDl ug/1 M> M3 m M3 NO NO NO M> NO ND ND NO ND M3 NO ND ND M3 ND ND ND 6M3L f> ND ND ND M> ND ND NO ND 100 100 10 10 10 10 10 1010 10 10 10 10 10 10 10 10 10 to 10 10 to 10 10 10 10 10 10 10 10 10 QC Replicete Flrtt u/l Second u/t M3 ! M3 M3 M3 M3 M3 M3 M3 ND M3 M3 M3 M3 M3 M3 MJ M3 M3 M3 ND M3 2 NO M3 M3 M3 ND M3 ND s ND . M3 M3 Ml M3 M3 M3 2 M3 NO M3 ' ND M3 M3 M3 ND ND 6 M3 ND ND M3 M3 2 2 NO 2 3 2 ND M3 M3 QC Slonk and Spiked Blenk QC Matrix Split* Blenk Dot* ug/l Coneon. Umplked Added X Staple 08/1 Recov uo/l Concen Added uo/l % R*cov M3 M3 ND ND M3 M3 ND M3 Ml ND M> M) m ND ND M3 ND M3 ND to M3 BM3L ND ND ND M) M3 to ML ND ND 1600 160 109 sa ND 1000 37 ND ' 160 112 36 90 M> 36 86 0- M3 0 36 81 ' M3 36 SI 36 99 M3 36 94 36 89 M) 36 84 36 92 M3 36 90 36 119 Ml 36 119 36 92 M3 36 103 36 99 M) 36 100 36 101 ND 36 96 0 M3 '0 - 36 100 to 36 103 36 101 M3 36 106 36 94 NO 36 94 36 126 M> 36 80 36 I0S Ml 36 85 36 94 fO 36 67 36 103 MD 36 57 36 86 M3 36 73 36 52 3 36 53 36 98 ' Ml ; 36 104 36 78 M3 36 76 36 81 ' M3 ' 36 83 36 106 M3 36 91 36 102 AO ' 36 90 36 94 ND 36 95 36 76 Ml 36 163 36 57 AO 36 10! 36 107 AO 36 101 HARTOLDMON0035092 It------------------------------------------------------------------------------------------------------------------------ --!---------------------- I f' Ci K* TESTING a*tt C*TtfitCATtQN -- ' - - 1 ------------------------' - " -- --- TABLE 1: QUANTITATIVE RESULTS and QUALITY ASSURANCE DATA July 13, t$S3 Acid Compounds - GC/MS Analysis Data (QR02) Ctuift at Cutdy Data /aqulrap tot STC Oata Utnagamaat Summary tiaparu C3999 Monsanto Co fie Ns. Com**** AWISTON facility 0001 iwpls NlM 060983 0900 24 Oils C|pd Its* Hmmi NPnfS Number Compound IA 2-Chlorophanol 2A 2,4-Dichlorophenol 3A 2,4-DIlhylplwnol 4A 4,6-Dim l ro-o-cfdJOl bA 2,4-0lnltrnphanol M 4-Nltrophonol 9A Penlachlorophenol 1 IA 2.4,6-Trtchlorophanal Raxulti SampI a Conean uo/l HDl ug/l* ND 25 M> 25 M> 25 ND 250 ND 250 NO 25 M3 25 ND 25 > Ml 25 ND 25 ND 25 QC Rap It cat* Firat ug/l Ml NO NO ND NO NO M> NO NO ND NO Second ug/l NO ND NO NO NO ND M) ND ND ND to QC Blank and Spikad Blank Blank Data ug/r Cone an aa Added X ug/al Racov QC Matrix Splka Unaptkad Extract ug/1*1 Concan Added X Racov to ISO 48 ND 150 63 to 150 53 * ND ISO 70 ND 150 SI ND 150 63 ND ISO 59 M) 150 104 NO 150 57 NO 150 107 ND 150 50 M> ISO 68 NO 150 38 NO 150 67 M) 150 59 NO 150 79 NO ISO 79 ND ISO 107 NO ISO 26 <1 ISO 36 ND 150 5$ M) ISO 7a is n V> X o u CP a* u. HARTOLDMON0035093 fVtAOHMeTAl C i\* TESTtNQ **>d CeftTiftCATION TABLE 1: QUANTITATIVE RESULTS and QUALITY ASSURANCE DATA Base/Neutral Compounds - GC/MS Analysis Data (QR03) July f, I9EJ C/UM of Cuifody Ota fteeu/ratf it ETC Ota uaaagamant Summary Aapertt C3996 Hominto Co (1C la^U Hi. Cmma? ANNISTON fttklllf 0001 SaipU tatl 060003 0000 20 Om IOU4 )im Ntwt NPDES Number* I Cdiapound IB Acanaphthene 2B Acenaphthylene IB Anthracene 4B Benndine SB BeniuUlanthrecane 6B Beniojajpyrene IB Benzolb)fluoranthene SB Benro/ghtIperylane 9B Benzol*)fluoranthene 10B bia(2-Chloroelhoy)methane I IB bU(2-Chloroeibyl) ether I2B bi*(2-Chlorot topt onyllelher I3B blc2-Eihylhayl)Pnihal*ia UB 4-Bromophenvt Phenyl eltiar 158 Butyl benzyl phthalale IfiB 2-Chlaronephthalene I IB 4-ChIorophenyl phanyl ether ISB Chrysene 19B Dtbanzoja.hlanthrecene 20B I,2-Dtchlorobeniane 21B I ,3-Dlchlorobenzene 22B I,4-Oichlorobanrene 23B 3,3'-PtchlorobeniIdtne 24B Diethyl phthelate 25B Olaelnyl phthalete 26B Dt-n-bulvl phthalete 27B 2.4*Ointtrotoluana 28B 2,6-Dtnitrotoluene 290 Dl-n-octyl phthalale 30B I 2-DiphenyIhydrai me 3IB Fluoranthene Raeulti Seep la Concen. us/1 MDl u/l M3 M) M3 M3 M3 M3 hn m NO NO U) tl) NO NO ND ND ND ND to to to Ml M3 ND ND BM)L ND ND ND NO to 10 10 10 to 10 10 10 to* to 10 10 10 to 10 10 10 10 to 10 10 10 10 10 10 10 10 10 10 to 10 10 QC Replicate Flrjt us/1 M3 M3 M3 M3 ' M3 M3 M3 M3 ' M> tO M3 tO 3 ND M3 M3 NO ND M3 ND Ml Ml M3 1 Ml 20 ND to Ml . Ml Ml Second ufl/l Ml Ml Ml Ml Ml Ml Ml Ml ND to Ml Ml 2 Ml ND ND ND ND Ml ND ND Ml ND 2 ND IS ND NO ND Ml ND QC Blank and Spiked Blank QC Met rlx Spit* e Blank Data Ufl/1 Cancan Added us/1 Unaptkad X Eat reel Recov "9/nl Concen Added X ug/el Recov ND 100 00 Ml too 99 Ml 100 01 ND 100 96 ND 100 77 ND 100 101 ND too 01 Ml 100 68 ND 100 75 ND 100 105 Ml too 74 Ml too 1 10 Ml 100 39 tO 100 112 Ml 0 - ND 0 . ND too 67 ND 100 103 Ml 100 91 Ml too 102 Ml 100 76 ND too 09 ND 100 74 ND 100 81 i 100 76 3 100 93 Ml 100 eo ND 100 96 ND 100 63 ND too 84 ND 100 60 NO 100 94 to 100 82 ND 100 109 ND 100 84 ND 100 11 3 Ml 0 - NO 0 - fO 100 68 ND 100 79 to too 66 ND 100 76 ND 100 60 ND 100 83 ND too 102 Ml 100 133 ND 100 16 Ml 100 74 to 100 1 ND 100 63 3 100 60 12 100 75 NO 100 84 ND 100 102 ND 100 77 Ml 100 96 ND 100 03 ND 100 109 ND 100 90 Ml 100 119 Ml too 74 Ml 100 100 `'SRPCO MSO HARTOLDMON0035094 wr l tNVU90*i*9MTAt. * C / C- TKSTINQ nd CmTiHCAtOf4 TABLE 1: QUANTITATIVE RESULTS and QUALITY ASSURANCE DATA Base/Neutral Compounds - GC/MS Analysis Data (QR03) July I I9SJ CReIn el Cunedy Due Requital lei ETC Dele Management Summery Repent C3986 Hon unto Co ANNISTON 0001 060183 0800 24 CIC --1 M. C--ay fattltty Hut 11m Mm NPOE5 Number expound 328 Fluorono 330 Hexachloroben/ent 340 Hixacftlorobutadlana 3S0 Hex*ciWorocyclopenl*dltnt 368 Heaachloroethena 378 Indeno(1,2,3-c.d)pyrene 380 liophoron* 398 Naphthalene 408 Nl trabenzene 410 N-Nitrosodithyl4inint 428 N-Nltrosodl-n-prepylamlne 430 N*NitrosodiphnylAmine 44B Phenanthrene 468 Pyrene 468 1.2,4-Trlchlorobenzene 2.3.7.8-70X3 C*A Pfcfc*4kd<l MIM6 t MMI Remit! Seewle Conceit. up/t MDL up/l* M3 10 NO 10 NO 10 M3 10 M> !0 NO 10 NO NO '150 M3 10 M3 10 NO 10 NO 10 ND 10 ND 10 ND 10 M3 10 QC Riplltiti First ug/1 M3 M3 M3 M3 M3 NO U) NO M3 M3 M3 ND NO ND NO M3 Second ug/t M3 M3 ND ND ND NO ND M3 ND NO M> ND M3 to to NO QC 6Unk and Spiked Blink QC Heir la Spike Blonk Data up/1 Concan Added up/l Untplked X Extract Aecov up/el Concn Ad dad X ug/ral Racov ND too 76 NO 100 100 ND 100 79 M3 too 95 ND 100 68 M3 100 BS NO 0 * to 0 M) 100 69 M3 100 BO NO 0 NO 0 ND 100 97 NO 100 106 ND 100 75 NO too 92 ND 100 as M> 100 93 M3 0 M3 0 . ND 100 ao ND 100 90 ND 100 06 ND 100 103 M3 100 77 M> 100 98 ND too 71 M3 100 101 M3 100 119 ND too 13a NO 0 NO 0 * O tn X c LaeJ a ______ 1 HARTOLDMON0035095 TjLiyJCiiiiiiidMIMff<U 'r"`' ' C/l> rnrwd <m cmat/p/cat/om TABLE 1: QUANTITATIVE RESULTS and QUALITY ASSURANCE DATA Pesticide Compounds - GC/MS Analysis Data (QR04) July I, IU1 CAaM of Custody out Aapu/tap lot TC Oita Manasaaant Suauntry Aapoftl C3986 Manaanto Co. ANNISTON 0001 060013 0000 24 EIC lofli Ns. Cea*y facility laoylo feist III* lias Stvii WOES Nunbar Coapound IP. Aldrin (GC/MS) 2P Alpha-BHC ICC/MS) 3P Bat a-BMC (GC/HS) 4P Gamaa-BHC (GC/HS) SP OalH-BHC (GC/MS| 6P Chlordana (GC/MS) )P 4.4- -DOT (GC/MS OP 4.4'-DOE GC/MS 9P 4.4'-ODD (GC/MS I0P Otaldnn GC/MS. IIP Endoiulfan I (GC/MS) I2P Endoiulian II (G( /MM I3P Endotuifan suliato (GC/MS) 14P Endnn (GC/MS) ISP Endrln aldahvde (OC/MS) IBP haplachlor (GC/MS) I/P Hapiachlar tpoatJe (GC/MS) 1 BP PCB-1242 (GC/MS I9P PCB-1--2-5--4 GC/MS) 20P PCB-1221 GC/MS) 21P PCB-1232 (GC/MS 22P PCB-I24B GC/HS 23P PCB-1260 GC/MS) 24P PCB-1016 GC/HS) 2SP Toaaphane (GC/MS) MwVIAa Wallwd 0U law* LmI flaaulta Soap la Cancan. us/l MOL u/l* M) 10 NO 10 ND to NO 10 NO 10 Ml 10 NO IQ ND 10* ND 10 NO 10 ND 10 ND 10 ND 10 ND 10 ND to ND to ND 10 NO 10 ND 10 ND to ND 10 ND Id M> to ND 10 ND 10 QC Raplleata Flrjt u/1 ND ND M> ND NO ND W) M) ND ID ND NO ID NO Ml ID NO ND M> M> ND M> NO ND ND Sacand u/l ID ND NO ND ND ND ND ND NO NO ND ND ND NO ND ND NO ND ID ND NO ND ND to ID QC Blank and Sptkad Blank QC Hatrla Splka Blank Oata us/l Cancan Addad uo/l Unjplkad % Eatracl Racov uo/al Concan Added U0/1 % Racov ID 100 90 NO too 100 ND too 34 ND too 57 NO 100 82 NO 100 105 ND 100 38 NO 100 64 NO 100 30 NO 100 S3 ND 200 I2S NO 200 120 ND 100 99 ID 100 126 ND 100 117 ID too 133 ND 100 97 ND 100 132 ND too 111 ND 100 139 NO 130 48 ND 130 65 ND 70 3/ NO 70 79 NO IOO SI ND 100 102 ND too 116 ND too 130 ND 0 - ND 0 - ND too 89 NO 100 107 ID 100 120 ND 100 IS3 ND 0 - NO 0 - ND 0 - NO 0 - ND 0 - ND 0 - ND 0 - NO 0 - NO 0 - NO 0 - ND 0 - 0- ND 0 - NO 0 ND 0 NO fl OSw O 3 d d 5 o HARTOLDMON0035096 f------------------------------------------------------------------------------------------------ -- !-!< tNVIAONAIENTAl ' " elk, TESTING Ana CERTIFICATION "" TABLE 1: QUANTITATIVE RESULTS Metals, Cyanide and Phenols - Analysis Data (QROS) Cilia at CunsOy Old fliaulrad (or ETC Ban UAnA/Amanl Suatmiry ftaparra C39B6 Honianta Co llfi laflo Me. Ceapay MWISTQN fcltlly 0001 Sa^lo HIM 061013 0001fU2*4M4 loll lleo Moii NPOE5 Number ' Compound IM Antimony 2M Arsenic 3H BerylUum . 4H Cadmium SM Chromium 6H Copper 7H Ued BM Mercury 9M Nickel IQH Selenium 1IM Sliver I2M Thallium \3M Zinc 14M Cyanide, Total lbM PhenolIcs. Total Raaulla SaaiU Concan ui/1 MOL ua/1 (O 4 KD no no NO M> Ml BHDL NO BH5L ND NO <S 203 140 4 6 7 30 10 130 02 40 4 20 6 20 5 SO '-- . Juna 21. ItlJ o Ln X c OJ Or a LA HARTOLDMON0035097 in. ETC ENVIRONNENTaL TESTING sna CERTIFICATION TABLE 2: METHOD PERFORMANCE DATA Surrogate Recovery - GC/MS Data (QR20) Chtln al Cutitdy Out Rtiutrtd let BTC Out Utntgtmtni Summuy Rtpottl C39B6 CIC l*l Ito, CMt*4r Facility tmm\* Fl (> 1mm Httui* VOLATILE FRACTION Br omoch l o r on* I hyi Sait/ana.dg F luorobcrwana l,4'Dichlorobulan PonuHuoroboiwono Ethylbnrna,djQ ACIO fraction 2-fluaroDhnol Pontafluorophonol BASE/NSU7RAL fraction 2'Ftuorobiphanyl 1'FluoronAphthalant Nttrobinifns.dg AOUflt U0 200 150 150 200 150 ISO BO 80 SO 80 80 99 III 10B 104 IQfl 112 63 79 B2 72 86 Control Haiti * Lowr Upptr 79 63 , 74 75 58 78 20 37 62 64 58 127 122 127 117 124 1 14 Bfi 127 122 104 105 July 12, II3 ( psppco *sa HARTOLDMON0035098 E m JCS f w- rr*r4**Q *** c*mrt*tCATtoN TABLE 2: METHOD PERFORMANCE DATA JU/># 20, I90j GC/MS Tuning Data - Bromofiuorobenzene (BFB) for Volatiles Analysis (QR21) C/iafn of Cu turfy Data Aaouuarf fo/ C7C Data Uavufamaflf Summary Aapo/f* C39B6 (IC S*U Ni. Commit facility la^U Patet * U#m IIm mtu Ion Abundant# AbundMci m/i Cr Ilona fX Bait Ptak) 50 I5-40S >| thn baio puli 15 30-60X of the bos* poak 95 Bit* Peak, 100H relative abundance 96 5-9% of tho bait poak 113 lest than IS ol thn hat* paali 174 Graalar than SOS of tho base peak 175 5-91 of mis 174 lib Groator than SOX of tho bat* poak 177 5-9% of putt 176 21 . S5 100 a (i 67 5 63 3 Dalo. 061303 Run No 24919 Spoelrwi No 21 Analyst: P Kratczar O V> c a a .0 HARTOLDMON0035099 r CNVIROUMCNTAL C / O TS1ih/Q Mtut CERTIFICATION TABLE 2: METHOD PERFORMANCE DATA July 12. 19*3 GC/MS Tuning Data - Decafiuorotrlphenylphosplne (DFTPP) for Acids Analysts (QR22) Ctuln at Canady Om Raaulnd lot BTC Oita Uanaiamam Summary Raaatta C3986 (1C l9l Ik, Can ay facility lyU Nlil flits CUM4 lias Host* Ion Abundance Abundanca /I Criltru (% Bat* Paak) SI 30-60X at mats 198 68 Lots thin 2% of aats 69 70 Lais than ?X of aass 69 177 40-60X of aats 198 197 last than IX of mate 198 198 Bata paak, 100% ralativa abundanca 199 5-9X of aatt 198 27S 10*30% of aats 198 365 Grantor tl\an IX of matt 198 441 Lais than aats 443 44? Greater than 40% of aats 198 443 I7-23X of aatt 442 48 <2 <2 43 <1 100 6 20 2 6 41 8 Oita: 063093 Run No: 20779 Spactrua No. 220 Analyst M Mtikharjaa ooopto HARTOLDMON0035100 r ETCi------ ENVIRONMENTAL tesrtNQ *a cEAnFiCArtQN TABLE 2: METHOD PERFORMANCE DATA Jure 27. i93 GC/MS Tuning Data - Decafluorotrlphenylphosplne (DFTPP) for Acids Analysis (QR22) Chain at Custody Ox* Raqultad tot TC 0* IJanagamant Summary /taperit C3986 IIC Ifl H* (muy fKillty l|ita Nial t*lt I|m Naurs Ion Ahundnnct Abundance mil Cnioru (* Bis* P*k) SI 30-60X at Bit* 198 68 70 Loss Los* than thou 2% 7t ooff nmiottss 6699 127 40-601 at man 198 197 Loss thin IX of alt* 198 of198 Bis* paak, IQOX itltllii ibundinc* 199 S-9X alas 198 27b 10-3QX of Biss 198 365 Gr*it*r thin IX at aisi 198 441 Lass thin'aiss 443 of442 Grtitar thin 40X at ail* 198 443 I7-23X aiss 442 60 <2 <2 47 <1 100 6 21 2 12 80 IS Oat* 062283 Run No 20653 Spoctrim No 219 Amlyst P Krtltnr lo o p tn hco HARTOLDMON0035101 ENVIRONMENT AL tm \* TESTIHQ And CERTIFICATION TABLE 2: METHOD PERFORMANCE DATA Jun0 30, 1903 GC/MS Tuning Data - Decafluorotrlphenylphosplne (DFTPP) tor Base/Neutrals Analysis (QR23) CAaJn / Custody Data Aaoufratf for STC Data Un*i*mont Summary Aojsorfa C3986 fic tW N. ewur facility !?) HUf fata li Nyi I Ml Abundant* Abundane* m/z Critan* (X Bat* Peak) SI 30-601 of Ull |90 68 Last than 2% of mis 69 70 l*t than 21 of Ull 69 127 40*60X of sass 198 197 L**s than IX of uIS 190 198 Bax paak, IO0X ralatlva abundant* 199 S-9X of ull 190 275 10-101 of uti 190 .165 Creator than IX of un 190 441 lass than feast 443 442 Graator than 40X of lull 190 443 17-231 of matt 442 50 2 (2 44 <1 100 7 24 3 14 95 19 Oat* 062203 Run No. 25080 Spactruu No. 140 Analytt MU Ckl 7 o p p f 0 WSO HARTOLDMON0035102 Z VVIPCNMSnT At. res~i^G*no ZXT,?iC*TiCN METHOOOLOGV The methods employee m the anaiys.s cf your sample are astaoiisned E=a -rebecs *cr priority pollutants Combined gas errematograeny ana mass spectrometry (GC/v.S) was usea m the analysis of the organic compcuncs a no atomic acscrpticn spectrcoho'cme;,-/ (aa) m the analysis of the metais ' For the analysis of the vciat'ie organic comcouncs, E?a uiethod 324 (Federal Register Cecemcer 3, 19T9. oage 63532) was used. Tne methoa can oe summar-zea as `chows Helium is ouociea through a S-mi water sample contained m a specially oesigneo ourgirg cnamcer at ampien: terrperature Tne ourgeacie volatile organic ccmpounas are e*fic ent: / transferred from the aaueaus prase to the vacor pnase Tne vapor is sweet threugr a sorbent column where the ourgeacies are trapped After purging ,$ comcieted the scree": column is heated and oac flushed with helium to cescrb the purgeacias onto a gas chromatographic column. The gas enromatograoh >s temperature programmed to sacar3:e the purgeaoies wmch are then detected wth a mass spectrometer For tne analysis of the Ac.d, Sase/Meutrai and Pesticide sriorty pollutants, E3a Me*hco S2S (Federal Register. Oecemcer 3, t979; page 6954Q) was used. The method ca" ce Summarized as follows A measured volume of samcie, approximately t-iiter. was se" ai / extracted with methylene chloride at a oh greater than it ana again at ch less than 2 us.-g a seoaratory funnel or a continuous extractor Tne two methylene chloride axtrac*s we^e individually dried and concentrated to a volume of i mi The concentrates were r,e:`=c into GC/mS systems set specifically for the separation arc measurement cf the prert/ pollutants '- ' ' Qualitative identification of tne priority ooliutants was performed Titiany us ng hi relative rete'-t.cn times, the relative aoundance of three craracter.st.c icns arc :~e* ratios Tne entire mass spectrum was reviewed oefore ar icentihcaticn was 'eccrcec Quantitative analysis was performed using an r.te'-ai starcaro with a smgie character st.c ion ; I Q$,, 038863 HARTOLDMON0035103 ETC cjr/NG in<3 Zg^TiFlCAT.CN analysis of metals ACLET'JS The cetermma:ion of metals .n acuecus sa'-cies was ser'crmea according -0 --a methods oucushea Oy E=A in 'Me^ccs for Cnemicai Anai/ss or water arc wastes* E-A-5C0/4-79-C40. March, 1979, ana Apcendix iv of 're Fa^gra, degis'S'-, Gecemoe' 2 1979 Arsenic, se'emum ana thallium wera determined oy furnace a a siiver, aluminum Dar'um, per/ilium, ocron, cacmium, calcium, crrcmium, ccocer, cocait, iron magnes.um mangarese mciyoce-um, nickel ieaa. sccium, annmcny, tm, titanium, vanadium, ana z,-c were se'ermired cy iCP emission scectrcmetry. excect where 'Ower ieve<s of'ce'scicwere *ecuirea in these cases (e g ,eaa m grcurawa'er mcnitcr'ng samples; `umace aa aa usee "re ceterminaticn of mercury was per+ormec oy coio vapor aa E= TOXICITY The determination of metals m aqueous EP Toxicity leachates was pe^'crmec accc'O ~g to the me'hccs ouoiishea Oy E?a m 'Test Methocs for Evaluating Sara waste" c-~ Sw-346, July 1982. ana Appendix iv of the red Peg . Cec 3, 1979 Snver. arsemc, cacadmium, chromium, lead and selenium were determined Oy iCP erisS'C" soec'rc_e", Merc-ry was determined using cola vaocr aa For leachates fat are orgamc m -a'-re analyses were performed according to the methods sescr.sed uncer "ClL/SuJCGc ce'cw SGiL/ScDiMENT T~e determination of silver, Deryi'ium, caemum, cnromium, ccocer mckai. an time-/ eac arc z'rp in secimert samples was performed according a me'hccs cucs-ec oy E3a "irter.m Methods for the Sampling arc Araiysis of Pmor.ty Pollutants .n Secimerts a>-d' - sTissue", Esa 6CC/4-81-0S5, Cctooe1- 1980 Mercury was determined acccrsrg *c fa sedime"? metnee puOlisned oy Esa m 'Method fcr.Chemicai Araiys.s of water a^o .vas'ss' E=a 60C/4-79-C2O, March 1979 Arsemc, seiemum and thallium wrs ce'e^-mao z, furnace aa using mtric acid >n a ciosec decompasiticn vessel for sample agesnc" GiL/SL 'JCGE Tne determination of silver, aluminum, Oordn, oar.um. oeryliiu'", caicum cacmium, cccce' chromium, cocait, iron, magnesium, manganese, maiyocenum. scaum, ricxeu 'eac. a1----- c~v tm titanium vanacium, anc r~c in siudge/pet'cieum-oasac sarcies was ce^'c'--ec 0/ G= emiss.cn scectrcmetry us.ng a magresium mtra'e cry asmng cigest.on 'ec-nip^e Arsenic, selenium and thallium were determined oy furnace aa us.ng nitre ac 0 * 2 closed decomposition vessel for sample aigesfcn Mercury was oetermirec oy ccic .aocaa _smg the same digestion technipue USw Q3d8oh HARTOLDMON0035104 ere `SSTiNC na C*T,F'CAT Cn QUALITY ASSURANCE PROTOCOL The quality assurance protocol fciicwea n the analysis cf /CLr sample s casec or -ne "Handbook for Analytical Cuanty Ccrtrci m wa*ar arc Wastewate1' Lacora-ores' E?a-6CQ/4-79-G!9, March, ',979 Natcnai Enforcement investigation Center =cnc.ss arc P'ocscures manual, E3a-22C/9/73/CCI-R, Cctccer, t975, arc the recommer'ceC guce'ines for E=a Method 52a arc 52S Cur protocol calls for a higher percentage of cual'ty assurance samples man ma rscuirements of Me'^cO 624 anc 525 The <ey CA elements for the analysis of orcr.t/ pcilutarts are Surmar.zec as fellows Method 624 - 'n every block of 10 samoies. analysis cf 7 * e'e samcies, ore clank, one spiked sample anc one replicate ar9 perfor.-nec Inis amounts to a 3C% quality control factor - a minimum of three surrogate compounds are accec to each samcie m the block af ten - 8lmd duality control samples are included ,n *ie'd samples at a minimum cf one every nuncrec samples. - The C-C/MS is checked arc retuned if necessary every eight -curs *o ensure its performance on orqno*!ucrocen;ene (Era; meets me E=a enter; a. - a cautraven curve fer cuantitat.cn is prepared us.rg a minimum of 3 concentrations of a standard mix'ure of tne crcrty aciiu'arts o* interest and 3 nternal stancarcs (at a constant ccrcertrat.cn) - The calibration curve is verified with a stancard prienty pollutant mixture every eight hours - Results meet the acceptance criteria given ,n Method 624 Method 625 - in every deck cf 2C samples extracted, there are 16 field samples one oiank, one soikec oiank. one samcie spiked wtn the pr.or.ty ccii-tan: standard mixture anc a oupneate field sample - rive Surrogate comccuncs are accec to eac~ sample m the clock or 2C - 8imc cuaii'y control samples are included -r field samples at a mirirum of one every hundred samples - The GC/MS is checked and retuned, if necessary every eignt hours to ensure its performance on decafiuorotr.phenyicroscnine (0FTr) meets the EPA criteria. ' - gc pe^'ormance c'lteria as soec f ec r Me'hcg 525 are me* before analysis starts - a cancanon curve rpr cuarva'or s o-eca'ac us ^g a rmr,,-um cf 3 cc'ca^'raucns c* a stancard mixture o* `he cncr,;-/ cci'jtams of interest anc 2 2'-c i-crooip-enyi as n-e--s s's-curc. - Tne ca`'0'aticn cur.? .s e* hea w th 3 s'cta'c p . cr t/ pollutant mixture avery e J'f `curs - Results meet the acceptance criteria given in Method 525 0SW 038065 HARTOLDMON0035105 ETC *i. 7SSTINQ iflC Z$fiT!flCA7!CN Analysis of Metals (Standards) - New working standards are oreoarec for sacn catch of samples - Normal caiiorat.on is oer'prmeo usmg a ciark arc 'cur stancarcs that have been carried through the entire sarrcie oracaraticn procedure a regression analysis is used to construct the calibration curve - Ccr each sample analysis m *he stannarc acciticns techmcue, a three pcmt caiicrat.cn >s per'prmec using u S c=A Me'hocs for Chemical Analysis of water and wastes. 1979 Pesuits are cctamed usirg 'mear regression analyse Any results cotamed with a cceft'c.en; o* correlation below Q.99C are considered erroneous, necessitating raw data editing or sample re-analysis - Normal calibration curves are constructs-' us.ng greater than or ecuai -o S times the instrumental Detection Limit (ICl) as the icwes' concentration level - ah calibration standards are analyzed m duciicate, as a mirimum - independent reference stancaras are used to creek the acc-racy o' calibration standards - a check standard is analyzed every ten samc.es 'o estabt'S- -- e ;ai<ci*y of the normal calibration curve 0Si4 Qidooo HARTOLDMON0035106 <\t tJJ EI VWfi0<VMNT4(. TSSriSG i/ia CSaTIFICATlCH Analysis of Matals (Sample, for all metals except Mercury) For all homogeneous samples (minimum pf 42% CO each sample oaten may induce ,,p to 30 samples arc tne fallowing fixea numcer or GC samples - 3 Replicates - 2 Replicate soikes - 2 =eohcate mcependent reference starcar-s - 3 Cai'Praticn standards (processed using the sample precara'icn me tnc c) - 2 Blanks (using sample preparation method) - 4 Calipration standards (without sample preparation) - i Blank (without sample preparation) nor all heterogeneous samples (minimum of 65% GO, every fie'd sample m a sa^c. batch is run m oucncate a sample oaten may induce uo to 3C samples ana 'he fenowm fixed numoer of QC samples - 4 Replicates - 4 Replicate spikes - 2 Replicate ncecendent reference standards - 3 Calicrafon standards (processed us.ng the sample precarancn method) - 2 Blanks (us.ng sample preparation method) - 4 Calibration standards (without sample preparation) - t Blank (without sample preparation) Analysis of Metals (Sample. Mercury) For every mat-ix (minimum of 66% QC). an the field samples m each samcie pa`on a,run m duplicate a sampte oaten may mciuce up to 20 samples anc the fouowmg xe numoer of QC samples - 3 Replicates - 2 Replicate spikes . - 2 Replicate independent reference starcarcs - 1C Cai'bration stanoaros (processed using fe sample preparation method - 2 Blanks M OS* 036bb7 HARTOLDMON0035107 SftVIRGNMGNTAc C / O tssting csartFiCATiOH Cham-of-Custody Th8 chain-of-custocy procedure 'S part of our quality assurance orctocoi We oe-eve cur chain-of-custooy record fully complies with the legal requirements of fece'ai, sta*^ and local government agencies and of the courts of law The record covers ' '" - labeling of sample potties, packing the Sample Shuttle anc transfermg the Shuttle under seal fo the custody of a snipper. - outgoing snipping manfests, - the chain-of-custody fern completed Py the aerscr(s) Breaking tKe seal, taking the sample, reseating the Shuttle ana transferring custocy to a shipper, - incoming shipping manifests. - preaking the Shuttle's reseal, - storing each labeled sample Pottle in a secured area, - disposition of each sample to an analyst or technician anc, - the use of the sample m each pottle m a testing orccecure acs'opr ate to the mtenoed purpose of the sample The record snows for each link m this process - the person with custody. - the time and date each person acceotec or relinquished custccy QSn Q3o8oO HARTOLDMON0035108 C ( W rffSTWC Jrttf CSPTiPICATIQn report appendices The following aoeenoces provide the supper* analytical dara asscc.atec with yCur samole analyses They are arranged as follows ' Appendix A 1) Reconstructed total ion chromatogram of GC/MS analyses of your samcie 2) The individual mass soectra of all priority pollutant compcunos when nave oeen .centified as oemg present in your samcie ~ 3) The individual mass spectra of the corresponding compounds as cotai'ec from the standards Appendix 5 i) The mass spectra of the canoration ccmoounds, <t-prcmcfiucrocenze,~e r5:S; and decafluorotriphenyipnosphine (QFTrP), as obtained cn the cate o' sar-oie analyses. Appendix C [fer plus 1C and 50% internal standard cptionl i) Spectra of tentatively identified compounds, with their sif`erances Appendix 0 i) Succontractor's report These data are provided to present a comciete reoert cn your sample arc rc proves the data on when analytical decisions have oeen oased we hope this win aid you n /c-r own analysis of the cata CSW Uidiio9 HARTOLDMON0035109 c / w 7S5TING Ci*Tl*lCATia* APPENDIX A OS* U J d a 70 HARTOLDMON0035110 1U' I3n C.-'HijrA FQGR `ii'ijo . t :>< ml i on i-r -- f'iri * is1 G ' >- n--. > r t ,A : ,.f . r* ci AL I L U N fa- 13. 8 tflLfl M l 'J ' D21 '.I* OSH G3dd 7l HARTOLDMON0035111  11 < t ,*4 i*n i v0 I I I{ I( !I It ( I I ,I 5 . -3 3 OH l : o. a IO SO Hut3c IT .3 ".?\Z U<UT1-' Vi !u? I: II It II i! t iv'j 20 .0 25.0 r' * f i' -. -iit IM../nu K i ri i i i 1 a * ! I- u cJ - '.sA i. 11 (i 7 ,1 h i* " II * ^ * i ir ' ll.'ll OSW Gidd72 HARTOLDMON0035112 1*4 II l J l t' -c i'Ij I ^4 I ^ .i J t1 J f f Jr f. i * ;i i* c .* r* n fi mm--x JR x ? 0 0 10 y y -V i t?00 *. M n U }' GSh 03dS73 HARTOLDMON0035113 g El NVIBQNMg VT4i tsstihg zft,f,cation APPSNCIX a osw 03aa 7^ HARTOLDMON0035114 BFs CSLISPS'IOH CCMPCUN3 SZdblZ CC'M- B< SUB *21 [iMl 33 4 I 95 404 s.7* i Ut 131 141 194 H 1 .,,j;LU-i... g.l 100 130 140 A% FRN 24919, SPECTRUM PCI h/z ABJND M/Z 1 RET TIrtE * R2L ArUND H/Z 4 90, REL ASUND 98 PEAKS M/Z PEL AEi'JM' 21 24 24 28 29 31 32 36 37 38 39 40 41 43 45 45 46 47 43 49 50 >PAUSE 14 6 11 7 11 6 41 4 24 13 0 25 0 13 7B 71 49 9 17 11 46 ei 16 17 13 57 2B 4 r -' cn f " 51 65 es 44 114 41 52 8 6 87 4 3 116 3 'i S3 7 1 88 3 8 122 3 2 57 4 8 90 4 3 123 4 0 53 2 1 91 t 1 124 3 2 61 7 6 92 1 1 126 3 5 63 3 2 93 3 3 127 3 S 64 65 94 'll 9 128 40 65 59 95 100 0 131 46 66 5 5 96 8 1 i 39 3 6a 14 1 98 3 8 141 3 69 13 8 99 4 4 144 3 71 S 9 101 3 6 148 3 72 6 5 102 1 3 154 4 73 8.1 103 74 18 7 105 43 40 161 167 3 3 75 54 5 107 4 3 168 3 76 4 0 1Q7 4 1 174 67 4 79 1 9 109 3 3 175 51 81 4 4 111 4 3 176 62 8 83 4 9 112 38 1 77 33 r j r j pj DSn G3do75 HARTOLDMON0035115 - l i i - r r ^ ~ - - 11 ii - i t i i i ' i -- ' - i t , , x -- 1 - ` '* * * T Y r ~ 1--------- 51 4fl t906 ifl 0 >9 SB 96S6 'O ) 9/.7S i27 4 1 406? 97 0 9fl i on V9 s 91 ?S !7S i * 0 (1**R7 hS t S9T7S 45 6 496P7 42 41 6969 43 7 93437 indicates nut of rang*1 I fR (RFTIISN) TO RfRUN 30-60% MASS 198 < 2% MASS 6V < 2% MASS 69 40 -60% rtA1 . 198 < U MA^S 1VH JtA-jF PF61' s-9% t-iAi' iyf i'l SO*'. HA--- \98 > 1% MA^s 19H < MALS 443 > 40% MASS 198 17-23% MASS 44? QS* Q3dd7o HARTOLDMON0035116 N 20653 , SPECTRUM * A H/Z I l so { 52 C S6 1 5? 63 6S 69 74 7S 77 73 79 80 31 86 92 93 98 99 lot IQS USE REL A8UND 16 6 60 4 28 20 37 17 6 78 0 44 93 63 3 28 27 2. 5 37 .6 7 44 30 2.3 10 l1 M/Z 107 108 110 111 116 117 123 127 128 129 130 141 142 148 153 155 156 161 162 167 168 175 1 RET TIME 11.42, 256 PEAKS REL A8UND REL M/Z A&UND M/Z 13 6 22 32 6 46 6 78 .8 47.4 3.0 17.9 1.4 1.8 7 13 .6 7 11 8 6 29 8 13 179 130 185 186 187 192 196 198 199 204 205 206 207 217 221 223 224 225 227 244 245 246 ' 23 19 1l 10 8 25 7 27 100 0 63 24 36 16 5 12 45 43 11 9.5 24 35 86 11 13 255 256 258 273 274 275 276 277 296 323 334 365 372 423 424 441 442 443 444 REL A5UND 41 3 54 1S 9 38 21 1 2S 11 41 17 10 18 6 36 7 12 4 79 7 IS 2 14 GS*< G3dd 77 HARTOLDMON0035117 jji: D^'Pp Bk.'I *'i FTP? EPA CRITERION VERIFIER |R`! 25080 PECTR'JM 1 Macs Rel Abund 51 69 69 70 127 197 199 199 27S 365 441 442 443 57 9531 0 67 0375 0 44.2531 0 100 6 77188 24 4094 3 30625 14 4875 95 275 IS 7406 jCTE '*%' indicates out of range1 PRESS (RETURN) TO RERUN Criterion 30-60% MASS 19U < 2% HASS 69 < 2% HASS 69 40-60% HASS 198 < 1% HASS 198 BASE PEAK 5-9% HASS 198 10-30% MASS 198 ) 1% HASS 198 < HASS 443 > 40% HASS 196 17-23% MASS 442 DSw o3aa 7a HARTOLDMON0035118 HARTOLDMONOQ35119 HARTOLDMON0035120 HARTOLDMON0035121 CTf* tMl'tOHMHTAi. C I w rtsrma cMnrifiaven SAMPLE POINT INFORMATION FORM (CC2) CC FIELD MEASUREMENT DATA * la 3 pnralM (a ka ai< ky MaH>> a nVai aa* WMar klhifM nm fm aaa* RIN] m( Vr *** l" Hi I. Cntar Vw aatMt iwmwiwaR kata Q* u* *a >9MrU4) far Uv> tfna ]. hM mlmi**. MUMCIXJCS w(ero _ i Saw* {> ---- 6r ta *aiaF (n) " -- 1OiMftama Kata (CM) -- ftrriN * (a*tam (H) ......... C*at Ttma (2*30-" Saak) Ba*Rli ta Sanaa (n) -------- A >1 C D C r -M acnub 0*t JuaURy) 1.1.1 1 I I X 1 I-.L 11 . \ FIELD TEST DATA ouMKir IPJMl.l d f\S iQ LX. L fey! /1/ t Oi3t I m C*tA3 L X-LX J W.fe) 1 > tlr vi I I TTill I I ilm) few at OxaaFuailaata ` 1 ' 'Tnl --------- L.LJld ! 3ra at Suaan#uata atK af ^f.*ru eiaauataaaa [_ X.1J.. 1. L J --L 1 I i -t L J--L XXJ..1 .? 1 * ~ L_L. _L J . j .!.. j 6t***C3/Oi] Sh** 2M at ftiaawgllaaia Jra * a<*ePwtwafU aw< a* SM^^uta WE FOLLOWING DATA JS FOR TOUR RECORDS ONLY am-urr () n>*o*c*___( ) --< f) SAMPUNC METHOD (choose one) KWWS kumk-4 ^ Kmgt^ 4 ) vstBM Maa. ) sejca/'stoFC___ { ) seumenwa___( } umminw^ ) bjcron urr n/aa ( ) ximctC ) iwcr____ t ) TWIX,.--( ) vtxarrW-C ) OTMCR SAMPLE TYPE (choose one) (} () 3- h hf- ot* A______ 7a^tf*-nT CTXX J ) fi*3X3l c--w) Firm 0^ /l> Yfr't/s^ aana (p*rt) move OCCttffiBK {, I .rnar.aaar? OSw Q3i3eiu2 M QAS ?A*sfu <1erc Fern* CC2 e/t/82 HARTOLDMON0035122 ' I ^ TESTING CERTIFICATION LABORATORY CHAIN-OF-CUSTODY ETC Sample Humber (a)______ f.`?3C\C?)Cp "n Received By Relinquished By; Received By. DateTime. Relinquished By Received By Relinquished By: Received By DateTime^ DateTime. DateTime. osw 0 3 ti d d 3 V. at* ntRtTtN CENTER HAKWA7 EOISOH. HJ 0W37 (201) 2JS 500 HARTOLDMON0035123 C / Vs rgsriNC Mna csaTieiCATiQH LASCHA^CSV Chain-OP-a.'S~OOv C"gQNiC'- = E"C Samaie NumoerCs) Sample P'eoaratic- For Sase.'Neutrai 'PC3's a 3esticaes ACiCS ,, Metals Others Others C'hers O' .rs Analyst t? isP- - Cate ir&fc. / r//l , r,'.b~ Sar-j.e Analysis For Analyst Data - jjji '.4 .t.-ai'P.- ' A ?r-3tl0fles acos <Ca Purgeacies Metals G Th er 3 Gt^e's n a ef IT>Kjujc (. Others O^ars Others Others / ` A' . P .. JL, fZLlcL ,UlkJ\CUXr( -- 6/*//S / t* (e/l3--IL,l F3. ve' f.ea Sy OSw Oiaadh HARTOLDMON0035124 HARTOLDMON0035125 0257/ V* - v> > # ri MONSANTO RESEARCH CORPORATION / DAYTON LABORATORY / OAYTON, OHIO 45407 EASC-Payton__________ __ (OEfT,/SECTKJW) ...... * sampling/Analysis Tm Cf REPORT report REPORT NO,: MDA-410 J06/PROJECT NO.: 4S3.1400 Qa DATE: November 3, 1983 < 0I0 PERIOD COVERED: r *> TITLE: ANALYSIS OF WATER AND SLUDGE FOR 2,3,7,8-TCDD cs 01 o Cm AUTHORS: Frederick D. Hileman W 8 DA W abstract: water and sludge samples from the Anniston Plant were analyzed for their possible 2,3,7,8-tatra- W chlorodibenzo-p*dioxin content. The results of < these analyses are shown in this report. c* ib i-04) o HW Technical Approval: ah (>A4 fc'9 ><L if$ Approved By: Robert rf. ivory Environmental AnaWtical Sciences Center Service Project Manager 0 r-4 1 cxc % 0257/H ui * Approval Date: //- J - <f3 RESTRICTED DISTRIBUTION (see over) COMPANY CONFIDENTIAL Tht* &***+* h me prop** * Mentente Anew* Cotperatw, me me rmpier* * rmvem*>'* let m heeer* eni 4w>w<ir * GOMNMNTMi. #OftMAT)ON wfiieh mu* ft* M rwraduMtf, meeiet wwtiuttoriiMl pwwmw PmtpgoMPMeflMmpftMMnft Cerporevm *naM*r**ft Co^wv wdMMt jmm# emAMteHee, Q$* 081606 HARTOLDMON0035126 0257/jj DISTRIBUTION COPY NUMBER 1 R, Cheever, Anniston 2 R. F. ivory 3 F. D, Hileman 4 Central Files 5 Research Technical Library ABSTRACT ONLY R, M. Scott Q2B H. A. Woltermann NOTEs Distribution of this report is restricted. Requests for additional copies should be made^tHfougH"the principal contact at the Monsanto location involved or the Manager, Environmental Sciences center, Dayton Laboratory, Dayton, Ohio, ACKNOWLEDGEMENT contributions of the following Dayton Laboratory personnel to this project are gratefully acknowledged: Analyses: F. D. Hileman D. E. Kirk *1C*4<CI COMPANY CONFIDENTIAL When no longer needed, or upon request, return this report to Central Pile*, Dayton, OiW 081603 HARTOLDMON0035127 02S7/k INTRODUCTION One water and one biological sludge sample were received from An niston for the analysis of 2,3,7,8-tetrachlorodibenao-p-dioxin (TCDD), The samples were assigned MRC Log Number 1-83-09-13-05. SAMPLE PREPARATION The water samples were prepared by extracting one liter of water with three 60mL portions of methylene chloride (CH2C12). This included rinsing the bottle with CH2C12 to ensure complete recovery of any TCDD which may have adhered to the glass. The CH2C12 ex tract was concentrated and exchanged to hexane and then chromato graphed through a multiple stage column consisting of silica, sil ica plus concentrated sulfuric acid and silica plus potassium hy droxide. The eluant from this column passed directly onto a Woelm B alumina column which strongly retains The TCDD. This, alumina column is then eluted with 2% CH2Cl2/hexane to remove PCBs and this fraction is discarded. The column is then eluted with 50% CH2Cl2/hexane to strip off the TCDD and the solvent is concentrated to 10 (jL and submitted for GC/MS analysis. The sludge samples were prepared in a somewhat similar manner. Ten grams of sludge was extracted with a mixture of 15mL of meth anol and 150L of hexane. The extract was decanted from the sludge and then partitioned against organic free water and then concentrated sulfuric acid to remove impurities, This cleaned-up hexane was then run through a similar column arrangement as the water and submitted for GC/MS analysis. SAMPLE ANALYSES The GC/MS analyses were carried out on a Hewlett Packard 5985 B GC/MS system using a 60m SP-2330 capillary column for the separa tion of the 2,3,7,8-TCDD from other interferents. The mass spec trometer was operated in the selected ion monitoring mode follow ing ions characteristic of 2,3,7,8-TCDD and the isotopically la beled TCDDs which were used as surrogates for quantitation. RESULTS AND DISCUSSION The result* of the analyses are shown in Tables 1 and 2. No TCDD was found in the water or the sludge at the method detection lim its. Quality control information is also provided in these tables. Note that the results for the water sample are listed as part per trillion (ppt) or one part in 10*2. The results for the sludge are parts per billion (ppb) or one part in 10ft. D$M 081*08 1 HARTOLDMON0035128 0257/1 TABLE 1. ANALYSIS OF DISCHARGE WATER FOR 2,3,7,8 TETRACHLORODIBENZO-P-DIOXIN Sample Discharge Water Discharge Water (Rep) Discharge Water (Spike) Discharge water (Spike) Blank Method Detection Limit ppt 2,3,7,8-TCDD found ND* ND 0.9 9.0 ND 0.5 T ND * none detected at the method detection limit PPt 2,3,7,8-TCDD added * - 1.0 10 - - 2 45W 081609 HARTOLDMON0035129 02S7/F TABLE 2, ANALYSIS OF BIOLOGICAL SLUDGE FOR 2,3,7,8TETRACHLORODIRENZO-P-DIOXIN Sample Sludge Sludge (Replicate) Sludge (Spike) Sludge (Spike) Blank Method Detection Limit ppb 2,3,7,Q-TCDD found ND* ND 0.9 a.s ND 0.5 ND none detected at the Method Detection Limit "ppb 2,3,7,8-TCDD added 0,9 9,5 - osw oaifeio 3 HARTOLDMON0035130 HARTOLDMON0035131 78 5/uJt HARTOLDMON0035132 HARTOLDMON0035133 ?* SjuJX HARTOLDMON0035134 HARTOLDMON0035135 HARTOLDMON0035136 HARTOLDMON0035137 HARTOLDMON0035138 HARTOLDMON0035139 HARTOLDMON0035140 HARTOLDMON0035141 HARTOLDMON0035142 HARTOLDMON0035143 HARTOLDMON0035144 HARTOLDMON0035145 HARTOLDMON0035146 HARTOLDMON0035147 HARTOLDMON0035148 HARTOLDMON0035149 HARTOLDMON0035150 HARTOLDMON0035151 HARTOLDMON0035152 HARTOLDMON0035153 HARTOLDMON0035154 HARTOLDMON0035155 HARTOLDMON0035156 HARTOLDMON0035157 HARTOLDMON0035158 HARTOLDMON0035159 HARTOLDMON0035160 t& k 1 HARTOLDMON0035161 HARTOLDMON0035162 HARTOLDMON0035163 HARTOLDMON0035164 HARTOLDMON0035165 HARTOLDMON0035166 HARTOLDMON0035167 HARTOLDMON0035168 HARTOLDMON0035169 Monsanto Robert L. Cheever - Anniston - 1060 Ext. 292 June 11, 1985 Stormwater Permits J. L. Brown E. j. Jorevic PLAINTIFF'S jr_ D. 3. Redington - C2SB Attached please find the Anniston Plant's stormwater discharge permit application for your review and for corporate signature. If you have any questions or need further info: :ation, please give me a call. /sag Attachment Robert L. Cheever N.V JDSM 107197 Accident Prevention Demands Constant Attention HARTOLDMON0035170 ***** >ltkrw#J ifniriti .trTmaw'M'a tfnapwftmiuwm;--fcniwCrftta T"fPSr*T taw tt* OK tJ ym mmm "yw" to my tart "JT b * In * ftH tem* w Mi v if taa tarn Y ar wmt *** V tw B8rr * MW ft *M*t (* Ml * M ; j i l"" l 1 "1 "1 r ! 1 1 1 l"li "TTMT^T PT""1 TIPT",'T'-TPP,"T"F"^^ 'CHEEVER, ROBERT SR* E K V. SPEC. 2o5 236 6 381 t* MaUTVUAl UM AOOfttS _ r* *.~ nr-r-i t -- t * ' i-t Y^2fIf o . & clx_ 2 A 9, i fcc nEZZ"i PT G 2. S T 0 N T WIMIMI Ut4t QESa * i J VLfckenJTYlOCATJO* *. mirr. vturt *. mu i>uinc tumric -rnr ii i i i i i i i i "? T-" * i i t- i i i i--r- i i ~r~t" g T ft V i V '................................................... ? n. 7 . .V r .q T 1 fi f V c f. g. r r. - ** OSM i iii i - & r. w n it k' 7 t r i i"r,i1 i i i tiircMt t UyW 8BBT I' I I '1 * XV.s.T.sr r K. mtaiaili OONTIMUt Oft ftlvlm* HARTOLDMON0035171 kwerttonstBflo*whieiwB of* wan** *! we mile h*rertproprnrbewdifi The meawjRrfww a6lnaf fee teDty,0 leaden of atft of iaaifdntwtf pweoadlafcntfichinpBrveamadieflai*artouie* floflid*dad)aff Aertltinji'Srtltidi<*diry0d. Mudtdl rfqtrtNri tf o8 --1-- borfitt interne via. Ssetoemiedoni far ' ULKATUKiOP gg'ge aeBtfUM^n ( 1 Agricultural Chemicals? Organic Chemicals; Inorganic Chemicals . xntcuRwcanoaf/ Famtym4K`pmtitr&lmm*metiwmp9wrmtt cfafa6wMtfeffrfwrtadkntMBolkmkfnrant **0*im*o*mr hqetr if *m pimm krnmdkatf n^onmbk tarobaia&to Montmion terni/w* in ** lfmfath**Mli*iiMChiTtn*,iecunatr*eBrpk*.ttittrmntml>inir*ar>fficanrp*mMmhr*idrrlttf i,Mbantipoaibmftffhrmdin0tiaMvmit Txssn mo**. f **nmmr*SSj! rcmssfssr It 1*11 i*o uvmi DSM i?1" HARTOLDMON0035172 MONSANTO COMPANY ANNISTON, ALABAMA EPA I.D. NUMBER ALD004019048 FORM-1, ITEM X EXISTING ENVIRONMENTAL PERMITS 1. AIR EMISSION PERMITS The following listed air emission permits were issued by the Alabama Air Pollution Control Commission. MANUFACTURING/UTILITY UNIT PERMIT NUMBER DATE ISSUED Boiler 3-01-0007-2003 05/08/78 Parathion 3-01-0007-2008 02/06/79 Paranitrophenol 3-01-0007-2006 08/17/78 Paranitrochlorobenzene Unloading Dock Acetone Storage Tank 3-01-0007-2005 3-01-0007-2004 11/30/77 05/08/78 Phosphorus Pentasulfide 3-01-0007-2007 . 11/30/77 Polypfcenyl Manufacturing Process 3-01-0007-2002 02/23/60 Phosphorus Pentasulfide Casting 3-01-0007-Z009 04/24/80 Boiler 3-01-0007-2010 12/24/80 2. DISCHARGE PERMITS: a. NPDES - AL0001201 (001)(004)(005)(006) - April 1, 1980 and March 31, 1981. The permit vas issued by Water Improvement Commission of the State of Alabara. Permit application for new permits was submitted m a timely manner? however, no action has been taken to date.. b. State Indirect Discharge Permit (002) - This permit governs the discharge of pretreated wastewater from Monsanto Anniston's Industrial Wastewater Treatment Facility to the City of Anniston POTW: April 1, 1980, March 31, 1981 and August 26, 1983. This indirect discharge permit was issued by the Water Irprcvement Commission of the State of Alabama. Perrit application for new permit was submitted in a timely manner? however, no action has been taken to date. /sac ' oS* IQ7200 HARTOLDMON0035173 3fic ,c S.'t.1* '96 HARTOLDMON0035174 STORMWATER DISCHARGES Discharge Serial N'o. 007 Drainage area consists of approximately 16*j acres of light industrial property. The stormwater discharges into Snow Creek. The stormwater receives no treatment. The following materials are used or manufactured at this facility and may be discharged in the stormwater: methyl parathion parathion benzene phosphorus pentasulfide sulfuric acid methylene chloride 4-nitrophenol Discharge Serial Ko. 008 , Drainage area consists of approximately 5.5 acres of light industrial property. The stormwater discharges into Snow Creek. The stormwater receives no treatment. The following material are used or manufactured at this facility and cay be discharged in the stormwater: methyl parathion parathion benzene ` phosphorus pentasulfide sulfuric acid methylene chloride 4-nitro?henol ' . Discharge Serial No. 009 Drainage area consists of approximately 9 acres of light industrial property. The stormwater discharges into Snow Creek. The stormwater receives no treatment. The following materials are used or manufactured at this facility and ray be discharged in the stormwater: methyl parathion parathion benzene phosphorus pentasulfide sulfuric acid methylene chloride 4-nitrophenol DSn 10720* HARTOLDMON0035175 Discharce Serial No. 010 Drainage area consists of approximately 4 acres of office building and parking lot property. The stormwater discharges into Snow Creek. The stormwater receives no treatment. Discharge Serial No. Oil Drainage area consists of approximately 16 acres of roadway right-of-way, undeveloped forest land and closed landfill cells. The stormwater discharges into Snow Creek. The stormwater receives no treatment. Discharce Serial No. 012 Drainage area consists of approximately 11 acres of undeveloped forest land and closed landfill cells. The stormwater discharges into Snow Creek. The stormwater receives no treatment. Discharce Serial No. 013 Drainage area consists of approximately 8 acres of undeveloped forest'land and active landfill cells. The stormwater discharges into Snow Creek. The stormwater receives no treatment. lc?lQ3 HARTOLDMON0035176  I tanRimi Monsanto MQN&Hi&'tOftMItt/MYtON UMJIMOftY / OAYtON. 0HKM54W ESC/MYTCH |DtpitU(At/ttcn<ii) 'M(o 3^ MMLVTtChL liy^i #t Report) uroT w.t JOB/PROJECT *0.1 pjyjll PERIOD COVtREDi TlTtXi " *>' 19 J1k IMS JUl 1T19E6 r N* Ll;- *?%> AMAtrm roii W w iou swus s>1 AUTHORS I a. a. J9h B .if AinMCti toll oerpleo fro* tho Anniston plant vers enelyted for pcooibU eoncontrotiono of polychlorirulsd biphenyls. lbs rooulto of th# r.*]yi ro shewn In this rsport. TSCBNICAL APPROVAL! P L. (htma If* Reeeereh Croup leader APPROVED BYi ---------------------------- - Environmenter'Sclencea Center Service Project Manager s E approval dates ___?*!%. it"_______ RESTRICTED DISTRIBUTION! (tee over) ..................... COMPANY CONFIDENTIAL This NciMU it the property of Montonto fofitny end the recipient is responsible for its eststsspinp and disposition: St eWtlJotTUl SJtfORIUTlQN which nuot not he reproduce^,.rsvseUjd to mwthoriisd poreono or sent nultlde' Mensinto Oonpeny without props r evthorlistico. HONS 023^^2 HARTOLDMON0035177 COfYWMW I. J ** IXnni$tcnt t. *. n. N*)ht UJJO) J. Ik. t. Ivory llJSO) 4. Technical Safaris Library l*JC> 5. Central rile* WSTMCTQNLY A. Molternenn KOUt Distribution of this riport it riilrittil. bequests for Additional copies should ho nada tfcrouglt the principal contact at the Monsanto location involved or tha Manager# Environmental Sciences Cantor, Dayton laboratory, Dayton# Ohio. ACKXOWOQEm Contributions of tha following Dayton laboratory personnel to this project art gratefully acknowledged* Analysaai a. n. Hughes 0. NeKenata 0. Ifllllaa* C. Trane COMPANY^CONF.IDENTMVL HONS 023*63 HARTOLDMON0035178 MUTfif itrocv WTIc 7-e-i5 IOC SU-Jfit HCJtCJ HOi 7*0.11 - 217 tO< lmUt)/lrry rioili ImirMWMtil itltwii tenter ItoMMt* Cepear/9trtan liliriiinr ISIS IIchalet lea* ftapten. Okie *541 Shone lei (SIS) 2M-14U Title* SelrcblerlnateX biphenrle l lint Annieten Sell Ivilli StanXerX Stealing BelhoX *e(i)i Starlet i-iffllil hr the Ann!aton Slant. Sti(ir< extraction HetheX lt(i)i KE12I (tinlirl tMlyali Bat hH la{|)i ICAHOl Final Bapart File le(e)t *21711 Table File leleli >1171# Ulna anil eeaplee wara ricalftl Iran the Annleton Slant far SCI analrala. laarlri mn srapart! far analrala ualng SlenXarX extraction lethal SC1MI. SC/IC analrala* ualng StanXer* Analrala HetheX CCAN02, ahewaX tbit eavertl al the aanplaa canttint4 SCBa ranging (ran S ta 1211 ag/g. Table 1 aaraariaaa the valuer abtalnal far Araclar tornuletienei 1242, 1241. an4 12*0. Table 1 alaa reporta the total concentration of SCba praaant aa tka aw a( 4)20, A)2l, an* A1234. Alaa IncluXeX In thle report arai 11 A copr f Lag-ln inlarnation (trieratea. 2) A capr of the SlenXarX Analyila flathad, an4 tka Sta<irl Extraction notheX uaaX In analraaa. SI A caps, or ckeln-or-cuttaXr InferMtlen far tkla project. 4) A copr of tka ESC/tMf CIS Manual which txplalna euelltp control proeaXarea utiliaaX tr CSC. AMALTST (S)t I. Raton Ru|kao. Cbt Tran*. OavIX HcKanala, an*. Barbara Vllllapa. HONS 023464 HARTOLDMON0035179 TAttI I* fvm*rr af PC# Cncantrmor.f W QA/QC far AmUtan Salt ((fit*. D*tti Mr o. i**s Sirplt 1.0. Surratata t*cav#r arisen* 2. 4.4-Cl)-htphonyl 5-4-J#-15-01-01 sr-4-i#-#5-oi 1-4-10-#5-02-01 $-4*1#-#5-01-01 S-4-l#-#S- 04-01 tfl'4-!l-#5*0!(Sito4) S-4-10-IS-05-01 S-t-lS-IS-OS-Ol(OUP) i-o-14-45-04-01 lfl-4-14-45-01(11to4) Rathe# lltnlt -(C> HI -to 104 00 101 105 100 0 107 04 -(e) 104 -(c) 124 101 105 107 104 102 100 05 PC# Al 242 41241(4)41240 Taiel 524.0 000(4) 100.0 714.0 NtXa) mu mu N0(a> 022.0 000(4) 410(4) 44.4 NO(a) * 7.0 mu 12.0 10.1 i.i mu m 211.0 1211.0 11.0 121.0 5.1 12.1 MX*) NtXa) 5.2 17.2 4.4 14.0 2.0 5.1 mu mu m Not1wo Splklni Ooto InuiI A! 254 Splkod (/#) Anaunt PcttCtpd (u|/|) tf 1-4-14-45-01 (tit# 4) if sri-i-ii-s-oi(Siu 1) >$ 1.1 0.0 1.0 0.1 (xpla-'.atlan of Tihlat Unit of dataetian (tOD) *1.0 ut/| Kpiictu iMinii our. , . LI Iom lovol native ipikn(a) NS kl|k ltvtl nativt iplktft) rootr.ctf (i): t k - )D An opt (fltctif ot tho LOO. eetinatad LOP for particular Areclar farnulatlent in tho rroocnct of elhar Areclar fereulatiene ot hither levala. C - RVoCcSovorioo of aurretete coooounOo cool# not he etlcitUul d - PbuOp*uofif!ntjfameroatnrltytihoootilouinittinrhUprlw*trl#cwnholrAetrrodechilluiePtreheden12Iyn4l2ceeerdnndetern12eto4re1p. ioiKttnhUeoatwtrut, JnKtaheaoyUturr-ooaref!afolo;tlaerroerhnAt`Uvhirrolleoftcnf.lApoaeroa'nts1tt2ejex4lr1Sndi-am-5-fS-r-ar.td!-o*ssaitd-lo-*i.o-isni-ni.u.r_ctih-n<:oK,sihlf_hVae!vJ,t JGte,ktt'l*J,n!Ra--y : ctod d - #ootUAC/kpnnonuof fer*u*HtV control criteria. TAKE flLdNOl HONS 0*3465 HARTOLDMON0035180 Tho (illnini mih liseriN iMlrtlnl Itwit iilitutltn iimnUI for tMi project. MOHS 023466 HARTOLDMON0035181 tim >tM - <i$oti*ni wmjjtn tmmmrm ubwutoot wttoMyttt iciweii cum NUITI1I ItQCtft MTU 4/70/IS iiqvctmi amium 100 *0i l-BS-00-20-01 r*wta Kit uo.ii - m ~ trout it suiti toi hles/hecs. tvoit, sheahar, hocus. hceeneu. trahc akaitsis iequcets tun rot mil. ivoit. muum. kikhes. itcttnii *' 5*nru new it< nc*m urnt locAtiom luuoirc 2 ui 21 ..................... swirtt Ktcumoi roi -- sawies lARPlI lOCKtinCATIOK stvntet or ionics CSC nnm(s> s-4*ii*e-oi-oi syb-i-ib-bs-oi esm i> S-4*IB* 1*02.01 S-4*ll-BS-0)-0l S-l-ll-BB-Ot-OI iri-*-ii*j-oi isin > S-4-lB-BB-OB-Ol S-A-li-IS-M-Ol srs-c-u-ss-oi (1ITI > mi hod blame, 1 rt. rcMiu 1 rt. rco-im. rcs-mt-is I rt. ru-lisi 1 rt. rct-uso l rt. KB-mo 1 rt* rci-mi. rci-isii-is 1 rt. rci-m2. rcs-mi-wr 1 rt. KB-m4 I rt. KB-1HS KB-I14I recorded iti ncf.na11 RtCVlRtO AMLTSCSt KB* ANALYTICAL UCKRlQVtSl TECHNIQUE (CH) I-- cc/tc (IB) DATE coantTCO TECMNlQUfCEN) -- ec/iis < ) MU cwin mo Quumunni t REOllitEBOA/OCt UK COOfclAOOMTOftf MUCTKtS HAMVAL COMPUtlM MIC MWCSTtOt comcinsi sAiinc DisresmoNi -1010 roc oo mis __ SAfttt ntuimoMS: stc sire laboratort practices kamuai ANALYSIS ItOVtST.mt KAHEI AAtltiLI MONS 023^67 HARTOLDMON0035182 (tltwl*| H|l OitrlM SlaMtrtf MmcUm Ihllttli iM SiMr< ImIhIi B*th4* ml fw tfcla kiJhI. i MONS 023*60 HARTOLDMON0035183 tu Standard Catractlan Rathod (SOI) TITVIi PC2a In >an>CC Aetlva Batrtcaa KA7II<X),<ctS)i Soil# ml tlkit non*(C ictlvi olid* *nd aalvant* ISC Standard (ilriellM IUIM fai PCII21 typical sAnni size <) typical utaact VOIUKC (all TYPICAL AAALTTtSi Araclara 1212. 1242, I2S. 12S4. 1240, 1242. trlohlara* biyhanyl laaoara ikrtml biyhanyl Itoaara iXTUrCACNCISi Any alactraa caytarlnt ayacla* In th* ratantlon tlM ration r trlcklorablyhanyl itoaara throath clKMwMp)H*yl liMwn that li non *cld MrtiytiMt 0.1 - 1.0 10 CSC standard Analyala lfcthod Moat tCAROl, ICAM02 TYPICAL SUAAOCATCS TYPICAL AlCOVtAltl (41 yanttchlorobantana JO . 120 Z.4,t-tr Ichlory biyhanyl SO - 120 APPAAATIIS ASS HAHAlAlfi Igrdlck and Jackaon Santana ar banana for aanyla attraction ar dilution. PI area rial*. Sulfuric acid at varying concentration*. Vltraaonlc kitk. Olayotabla tlaatuara. (Saa flaw aMat far thia astractfon aathad In PCfSZl.) LltllTATlOOSt Bathad ayyliaa anly ta natrlcaa uhleh da not cantaln Intarfarlng laclran cayturlnt ayactai In th* tfIchloroblyhany] throufb actaehlarablyhanyl laooar ratantlon tlna rattan. SAHTY PACCAiniOMt Cm PCS handllnt protocol* in laboratory aafaty aanual. DATS* Of WTNOO CAUTIOO A W6AS 12/11/04 ' HONS 023469 HARTOLDMON0035184 out fliut rout r OC BTMOiM ATMO Kll}| sAnri .........-........--....................................... itt time? --..............--..................................- IOC IOi.......... DTUCT10I OATI M TIM* --...................................................... IAH7LI (Mi MO DISCKiniOi......................-..................-.......... vucn otn Mini xino a 14 m ao i rinci VIAl uxni men- SUMOCATt true or fAiiric AW) 10.0 L KNUNt to SAiirix. VlTRASONICATt SAItfll rot m hour in a SOUND IATM. FUCt I l Of TNI EXTRACT INTO I 1 ll VIAI ADD 2 H .......... SVimiC ACID AND SHAKE AlLOO fMAStS TO ItFAAATl REMOVE 1 L FOR ANAirSIS. . (J 10.0 l FINAL VOLMil -.................... tXTRACT NOt----------------------OATE/TlMt conntTitf......................... ANALTSTl----------- ............................ ESt ^00 NOi ----------------------------- ----- MOHS 023470 HARTOLDMON0035185 CSC Standard Arsalytla (SAX) null Araalar r*ravl*tl** i* Salvent* CSC Standard Analyalt flatbed Mi ICAdOl ajuitticai mrmtrr mo koi or oriMTiwi xr-soio c*ym*ry *t/tc iat*r- 4Iwi t* an KP-SJSl-US tiStritir; Date irttH 1TTHCA A5UITTC TTMCAl INCnUHCKT irvu 7 0Or KTCC I I (LOO) Aroelor ferauletlana 12)2, 12*1, 120. US*. 13*0. 4*4 U2 0.1 nrictt MCCItlOi I 101 LOO <*> SO miCAt ACCVMCT I 101 LOO <t> so . IKTCftfCSCNCCS AW llltlTATSOMSi Any altctr** capturing tpaclaa In the ratan- tie* tIm r*|l*n of trlcMerablyhenyl throvah act achlorablphtnyl laaaara *ra ycttntlal Interference*. teact retention cir. b* attaints fro* tha analytic of Arocler :40i (emulation*. Mac* I]<l, of aaet Araalar likely KK leaner* 1254 ar Aroclor 0 2CMXC-jtTOSXAmlC COlUKNi SO-aater futed all lea JOB Dl-S ( . S ufl) |th 0 2wide bare ( . S a). COLL** TWIftATVkl HOCIAMt 1)0(11/4/SOO IHJCCT10* mil Salltloea 4CAimATlOb ADO STAIOAHOUATlOMi Uae Internal etan ari euantltatlen technique ant calibrate Inetrianant ratyente (actara fra* authentic AraeUr f emulation 10 rcl 4ataneare*. Ilea a at nine* af laaaara far the ateralnatlan af fnraw- 1 at Jon Identity and event tty. CALCSUTlOHSi rarawlatlan concentration (teaser UtFHIaonar eraa/lnternal etanderd area) !iaret Air la the relative raaeeaaa factor far the aaaraarlota PCI laaaar In a given f emulation. roravletlan caneantra 10tion la ahtalnad fra* the *vr*t* of at laeat ouch cal culation*. SAfCTT PXCCAUTlOKSt Sat PCI handling yrotocele In laborotary jafety^eneel. 10 2 2 850201 117WirOf RCTHOO CXlATlOdi / S/I). /S/M Tl*a Staay - < . )> HONS 023471 HARTOLDMON0035186 Dm UIInIri mi*' itMM dMl*la(Mti4|i UlirutlH ftr tkli pr*>ct. HONS 023%72 HARTOLDMON0035187 QUALITY ASSUUMCC fMH #1 SAWlt TWWITUt ICTKR ii*"^*^** ^ \+m- MMaoa^na* * :ite*t__ KWSAJflJ_________________ Project Title __._MCr|**.............. UU; snipped ___________ Shipped by . _. _ ... M?pti from _____________ ____ _______ __________ ______ ... ............................................. >Mpp< to JX<k:\ JZ$l___________ ______ - Attention of ti f tdditlonel shipping infornitloo or con eats _jjr'LzJ**iSo*ft'* &**... _____S**t*J. ?&.--J^e^L-i/l Z':-JJ* si L`"________ ____ _______ M at% a 9m *m m jtj .n e lorwon m n io r# w ca* v * r r ^ a * 1*5':?.l!_4?tc [1 Pli? C0je_. __________ ____ ... ............. ........... Ccfjnenu . . `iu-Ar (.--.............. aL-*&j6<r!il.JkL}________ 91____________ o2r<i L____________ <Jtz*Xr. r- L..- S-C'R lrS'OS .g/,_____________________________________________ ____ . s-6-/r-Sr. of~_________________ /J Ar r-t. w fitfh'At ... gy*o/ CsX t )-------------.......................... ...... Staples received by Otonsenio representative C Oet* tootef received ____ 'ir/jc" ?<*_........................ . Retvro letter,received b/ eontrect toboretory______________ *> . .X bote HONS 023A73 HARTOLDMON0035188 Dm rtltMlil ti i (if! tf Ut IK/tU HM UNritin fr*etleo ImmI. MOMS 023474 HARTOLDMON0035189 coco uvoMTocT nucnctj mnuu A*tu U Crtf1/frQltr Aiwmp tttiitiwi lUrcfc im Cr*f I. A. VihiiMU K>M|tr, (ntrtrOM<ul Itlntu tnttr Itturi . ** _ JU/J05 A bVifHMltll ItlWM tofts* Utaiitity toftsst Chi* 4540? MOMS 023475 HARTOLDMON0035190 I OVjKlifM It f<*H HI AmIrU A. KctlwJa . QA/QC Kafras l Sn(U htHinln i> MttM IlHM v. bfiimii t. IMUI I. iiuljuti QA/QC . Xamaamatlau k. lwmlL* t. ^titltillH Itinul ItiitiK 4, ItiitiHl C. Di|lni i( ^tuttmUt 1. Qualitative iHlMil i. iHtnln V. C*i(|nt< 2. litelyala ). (mmIimIti ft. Quality Cliltlil ill tmliil Act la* 1. Queltty CfItavia a. Ilaafca V. ftecavaitaa c. MkIiIm 4. Halt # Ntactics a. Accuracy 2. IcMtflct Aetlaa IV Qata V taayl* Oliyoaal news ZittSi 1 (ample.#! CC/M Lato#a pas# 2 taaupla il 6C/BC U|kMl HI* 1 (staple af tlec/Iapa Ujboit yaga t*u 1 l!W 5 H HONS 023476 HARTOLDMON0035191 1. ftjttfeii Tk* Nil MjKtliH *1 tk* (luittwi AMlyila ClHf quality llltflltl/tlllllty (Otiiil >T*1TN *t*i l) u MI Ikit Nt lakoratary t**rat*a M|k (wilt) titglti) M 1) t* wliuti tk* accaaaary r*cor*a tkat 4twnl )ltl*tWl(l< II. ltW IW *<*H of till m*v1 IwIWm irm of CIf mi ayaclfltally tMniiil to tk* Itc MCllH MM1 *14 U)lfl4l )* *tttl* *Mi* Vklft QA/QC MKlItll fiffar frra tfcoa* toatrlk** to tk* iKtin uiwl, It I* totmto* t* % ut4 |*ii| vltk tk* a*ctlto wwi) t* imM* craylm ytctvr* *1 tk* CD vttkto th* Vltnttic* An*ly*l* ti*). 111. UmItiU Tk* |*n*t*tlM *r analytical riiulti vitkto tk* 81tr*tr*c* Analytic Crray mtlMl) UwlvM tvo )Ik*iiiii nifli iiifintlit ill luttwutil iul)ili. (U)l* )H)ritl*i !! tot *t toft of o fi(t*t| of t*(knlt*i Ik1W|ii| otiictltoi illvttoo, tcU/kttt mk** colwto ckrto*t*trayhy, emctatrttto* i auottto* otktr t*cka<to** M ti#4*t tk* iiayl* to o mfUkl* eoafltloa for tnatrmtot*! coaly*!*. loatrmaotal imI)*I* t*M* tk* *lt*U) yiapart* Mt)lt u4 lotratocaa it fato at *oa!yIleal itutwitt to oa*ur* tk* 4*tlt*| pat*pra*ra*kt*l*r(a**)t.ko4lo*tk**)o]f*<tkn**t*))p*ro)ct**ia)i*tncl*a iVM* t4kitociralV(s4ntVt)* elaaily 4*fia*i * 1*4 ioatrmantal analytic attho** (IAN*). DKl * XAHa li) k (0*Htt4 to auar*ut my* (4i)i4lt| apoa tk* Mttn of tk* it)I*> nf tk* i*ii of tk* caatoa*r) t* yt*4u<* o *tt***fal ra*lytt*l protnol. for nmyl*. *) ilfftrmt into My k* w4 to proto** *wyl** tk*t *r wttiUi tot *a*ly!a ky *t*|l* 1AH. tk* Mitwt** toeorpotat** lot* **ck of tk** )nl*ntl prot*a**t t* *oavt* tk*t * i*iiiiMit of tk* tmlfty of tk* TMult* eta k* **4* craatltut* tk* QA/QC yr*|t* f*r project. Tk* fallaviai mk**ttf*** 4**ertk tk* almanta f tk *Mly*t* pro**** A. Mttkoi* Natkoto at* tk* wtittw tocaaaatatlM tkat iucrfk* tk* analytical yrc**. lkty ctotaia awffielmt 4tll rack tkat * ctoyattot actntlat or t*cl*!clM tn rullly partora tk* t*titi4 *o*ly*a*. tk* wall prattle* li to kni.attMi tkat fmcrlk* tk* ***pl* prapomlot pro**** (Oita) oai Mtkoto tk*t ia*rlk tk* la*t?*- mtol OMlyci* ft*ea*o (Uk). Sack Mtko* 4**lot*4 vitkfo tk* Pltratrac* Anolyaia Ctmpo t* h*<|m4 * aatbo* amber l**tmil la tk* t$e fact Ira MmmI. ' K*tko4* at* obtain** fro* t1o** * i*cla*to| to-km** *mlop> at* M*!flc*ttra/*4*put!m *f Iltaratur* ottkoto* or *ycfffc protocol Mtkoi* 4lct*t** ky gmertorat *|**c!*. Matko** My k tonally mlf4*t*4 ky o **rl** of *><rtoeat* tkat toacrlk* a el leal mlltotlo* yrotoeol or Myik* 1*** vltorouoly ptorn ovtot to factor* rack fra*aoey or . cwatraat iiti* nl1 1 HONS 023477 HARTOLDMON0035192 HMt/ttaUfc (MttUtiMi, b nap UM i tMt mas t epflle4 tic mi;w mew u prmiee e ittwririm fMtity it ' ite tiNlu. ww i QA/9C |H|t le iiimiIM ty i Nfdiii ffntecnl (*! IM Mnii l tail ititmDi certain UiiM tyJ<K mmuii (byi*<b| K tM uiljnia tn) leeerpetetel lit* *11 WtHttMi ^rtjKtt. At bllivlit hliiettH iectriWe tM Ntmitti QA/QC program I. QA/gc fregrm An iffeetlee QA/QC ymta iecerporette rbttt tMt yttvUt iiftnttlM ttlttltt ( wd tl lb (tUwiti ymtlNM <]) An tltrt rap bbiiUUt Ittl|ttw4 it niiMiutlN tilt will UftiMii tM tinttil (1) H*v n^tA(iUl ni tM liwliit ( Iw mil era the raolpte he iicnitiA ftra the iitfli netrUt (4) tAet le tM Kelt if 4etectlee for CM enelpelet (5) WMt le the 4pnrale rente ef the enelpelef (I) Vhet le tM Mcwiey ef the enelpelet All el there fiiitteu ere e44reeee4 hp proper)? eclectlftt/epplplnt the we ef hlenle, repllcitee, epltee eo4 etnletli in e QA/QC pregren. TM llecwelra ef the eee ef tMee QA/QC teehelgwee ee they apply to Vltretrece Anelpafa Oteep ectivitlaa le heat ieee hp cenoMtrfng tM aeeple preperatlee l inetrveentel enelpele proceeiee eeperetelp. 1. Saaple Fteperetlee QA/QC e. MtM hleeie gepraaeatetlvo tleinuii eelvente id teagwte ate ea4 with aeeple eetrieea Aich ere elnller te tMee for lAtch raaelte are Ming reperte4, pat 4e net centa in tM eeelptae ef letereet. Kethol hlaeM are enelpaei at a fra%weacp tfial te 191 ef tM raalpaaA aaeplee fet aaepl* rata which are aultlplea ef 19. At lean raa nethel hlan* la enelpaei far aaepla aeta ceetelaieg hetman I an4 9 eeeplee* h. tepllcetee - If owfflcleat eeeple emmte Mm Men ewMlttel fee aaelpafo* replicate freemeep le tM eaea ee the tecM hlene freevaecp. If et all peeeibie, rapllcatea about4 M ehtaleal free tM aaee aeapla Mttle te er4er te pfalelM aeeple Inheeeteneltp prnhleee 4ue te aeeplea Ming teien at allghtlp tlfferaet tieeo. a, fpIMa Xf evfffclant aeeple la etellehle far each tanple type* tM aeeple la apllt an4 aplM4 at: tm lerele with' 2 HON$ 023h7* HARTOLDMON0035193 tu wtlrr aaaltte(k); .'* 1W\rMti ;avg trvi(4llf MOW) 1(4 Ml (kl|k) tka aatlalMCel letattlea Halt < Mm M i tMtei^.rr.Mti-. uatla| (to Halt af <iti(Un far tack aetrla.T Tkcac lav tt4 kl|k ayltae in (MiiKtW It fnivno KWl ta tka IhtW IIiik (fifWK;. Okvtauel? iflU| vltk tka ntivi iMlyti tiuot k lata fit vlnicn ml|iti dace tMi ruMfpmi lnli<|i if tka Utit| af tkt aaclyte(a) la tka BMyla. Otkat iUU| tidalfiH in nil ti imImm tk ntnc tln/nnni) afftctaactee fn ike ih1|1i<i) af litimt, lleelly mrictln/ticnni efftcieuclae in litintnl far aack aaayla, aleca, la rrlKlfla, aack (tafia 11; iifniait a llffaraat aatita. Tkla tu ka 1m vary eetlly vkae tka letactlea tnlaltu la ueaa atmnaatiT If a* leatarlctlly lakelal varelaa af tkt aMlyte(a) la avallakla. tiMaMitlu af aatrectlaa/recavar? affiliatelea la tat requital far aack autii If tka mfli aatrla far a aat af aaaplaa fa coaateat. kovwar, far a eaafla aat far vklck tka eiatlarlty af atariaa la aat kam, aM far uklek efaquete aaafla la avallakla* aack aaafle avat ka aflit ail ay1tel vltk a kaava aaaaat af tka aealyte(a) af lataraat ta letervlae axtraetlaa affiliate?* If Maquete aufla alaa la aat avallakla at tka lleatltf af tka aaalytaU) la aat taava kcfara tka fact (l.a. vUaacaa aealyala), auriatata analog covyauMe **7 ka aaaf ta aaaaaa aatracttaa affldaaclaa la aack aaarla vltkevt actually arlklag aack aaayla vltk tka aoalyta(a) af lataraat* Tka ckalca af tka avrregeta arlkial ceayeuM la telletal far aack eaalyta. Tkla aurratata auat ka ckaaaa aa tfcat It ta aitkar ckculcally llaetlcal ta tka aaalyta af lataraat (far wiyli ualag laataylcally lakalal aaalacuac af tka aaalytaa). ar la claaaly alallar la tarua af Mtull/littl rattltlaa yteymlea. ckaalcal raacttaa yrayertlaa, aaluaa alutlaa yreyettlae ar atkar aatrls laolatlaa yreyertlee vklak era uaa4 ta laalata tka aaalytaCa) fraa tka aaarla aatrla. toetkar yteyem af tka aurratata afltlat cevywiM la tkat It aat ka ftaaaat ta tka aiafla kalag tMlyiel. leetruaeatel Analytic QA/QC Tka flaal eta? la aktalalac aaalytleal raaulta lawlvea tka uaa af aa ayrrafflata laatnaaaatal tackaltua ta yrMuct tka aaalytleal lata, lavaral QA/QC yraatlcaa auat ka lacaryaratal la tkla ftucaaa ta aaaura tallllty af tka lata. a. laattuaaatatlaa Careful Jecuuaatattea af laatr\ast uaega. eallkratlua. aM Mlntauauea- la eaecatlel far tka ganeratlen af ktgk quality raaulta. tack major luatruaeut uttklu tka attetrtce AnUyila Ctouf vtll ka tka taalgnM raaraualkllltylaf .a arafaaalaual auylayaa Itelgoetal aa tka Xaatnuant Itevarl. |ka.Xeatn*et ttavail la retyoaeikle far uaklug aura tkat fcfbuli aka avall akla aM yreyerlj conflate! ky laetrwaeatfaaete.l It ta tka > HONS 023k?9 HARTOLDMON0035194 vwyMttllttj af each MW4hI Mlif IW tl ratari til tM <IU ragalrad U IM lagkaan. An natli tf HI* (in OC/X# lagtaafc 1a |tv la ri|ti * tl*t af K/K la|W*k I* |hi la ftgan I. vlll ta calibrated MrUi| ta tk iiitta* neat awfKtmi' iHciNutim w Mtnlbi U tka atfcad being iii4 vltk tka lutrnt. A lag ( inetrv- Mt tilbmlM will k MiltlM with Ui totwwt. Tb lMtwHt Itwiil will k ihhmIUi fat n<tU| Uit rnvuti and corrective mImiuki rt*|M tti tinlk Nt an all iuirwiwti 4w Ui/kt If a eyadflc pUa la MtH k aa laatnaaat aaar 11 ohawld ha Mtcd la tha-l#|Weli nl tk Iiatmit ItMtl aatlflad aa that tntartliti tarractlva actlaa caa k taken. fc. Henke A aalvaat bleak will ha aoelyted at a frequency navel ta tka ttM Uuk Ik nothed Monk eaa aarwa aa tk aalvaat bleak provided It la titan ta the araa af tfca anelyta(a) af lataraat. Tkia practice cltelaetee tka yeaelblllty af background Inotrw cental eentaalnation. c. Quantitation Internal Standard A gventltetlaa Internal ataaderd will ha added ta rack iiafla fallawtag iiafli preparation kit friar ta inetrunentel analyala. TKla compound vlll aarva tar detanlalng ralatlva rcrpaaaa factara and far carractlni far varlatlaaa la eavple Injactlaa valwaaa and evaporation af enlveate. d. Staadarda Itaadarda ara aalatlaaa af tka aaelyte(e) af lataraat waad ta datanlna tka reepaaae af tka dttactar avar tka range af analfta coateatretlean fawnd ta tka eaapleo* far Quantitative aaalyaee. auffltlant ataadarda and replication af atandarda will k m ta daaoaatrata linearity and preclilem af tka dataatar reepoaee avar tka raaga at analyte caacantratlaaa. Kkauld eaeple cancentratlana fall aatalda tka dananatratad linear ranga* altkar addltlanal ataadarda art prepared t* aapaad tka ra*|*i or appropriate dllatlaa/eaaeeatratlan af tfca aaapla la daaa ta flat* it la tka praper range. P(|ree at Quantitation The infarwtian fiwliM far .any pirtleulet Me lye la la tailored ta tka seedi of tho cuetemer. la actuol yreettca tkoao aeoda vary acrooo tka kraed coatlauun fran tka ireeily tuelltatlve ta tka yradaaly Quantitative. It la lofermatlvo t* examine abet la invalvad in providing tka varying degreea of gwontitetioe reavlrod ky aar euetomere. 4 HONS 023460 HARTOLDMON0035195 **'--__ _ . HP 5985A it__ Inim UtklMKIWHl Ml- . -- MXClM M JJMC now i. mu (m t*iwa w HONS 0234**1 HARTOLDMON0035196 MXR nr see >h __________ I. kHMktdrmiM tatirnt------------------------ *H__.............. .........M I]()< MRC-Dt ricwi I. tiaifl* *1 OC/K U|lMk HtHONS 023^92 HARTOLDMON0035197 1, Qualitative Qualitative mlfiti lapltea m {veatftetlaa it *1) tot niter itiki aalp tto Uutlt; if III caapavto(a) praaeat. 6C/MI la Mttiulirlif applicable ta thte type * tralli*. Tto [;M* af MiaUfidilMa cat to iilai a. Taatatlv* A teatetfva MatUficatiH ta Mia aa tto totii ( tto eMlpat'a jiliiaait af a uttl totvaea tto a*** epectrua frit tha eaaple ato a Maa apectrua frea a tafereac* llViaiti Tkla la aftaa ftia fat tka lar|a iwlir af catfatifa facial ta a vllaacaa argaatc aaelyele. k. Caaftrael A caaftrael ilentlflcatlaa ta^afraa that tto chreaat*graphic rataatlaa ttaa aal tto Maa epactrua af tto vakncva caapowto attch ttoaa af a tetau* atatoerl af tto teatetfvalp ilaatlflal ceapaato. Thfa la aftaa laaa la vllaacaa maljiia vhan atatoarla caa to ahtalaal fat taatatfvelp llaattflal caapavale that ara af caacara. Tka aarael QA/QC requira'acnta far ttalitatita aaalgrata ara (1) aaalyata af a hleat, (}) aaalpale af Ivpltcata eaaplee ato ()) aaa af a althra ttaa caapavto (utvtllp toctflvaTauiph*aplpheaphl%, DHTP) ta aaaara that tto aaaa epactraaater vtll produce aaaa apectre that eaa to cuaperal vtth llkrari epactra. I. lal>Qv*ntttettv* Analyela Seaf-Quaetltetlva Aaalpale axtaala tha lafaraatlaa tnviltl hp fnlttatlva aaalpale ta laclule aaaa aatUata af tha aaauat af aaalgrta(a) preaaat. Tha aathol af aaaftMtttatlaa tavalvaa tto caayatlaaa af latactat raepaaae af tha *Mlpta(e) vtth that af n tataraal attalari. Tha aatiaatal caaaaatrattaa fa ahtalaal hgr aaavatai a valt taaaaaaa factat totvaaa tha aaalyta(a) ato tha tataraal etealerl(e), Aa falfcattaa af taaavatp fro* tto aaapla Mtrla la ahtalaal fraa tto tacavargr af tha avrraiata tataraal etaalarl(a). ). Qualitative Aaaljrata Quaatltatlv* Aaalpale* prevllee far tha accurate aaaaaaant af tha aaauat af aaelptafe) preaaat ta a aaatla. Ta to ahla ta la !*! tattva aaalpela vm auat toav tha llaatttgr af tha aaalyta aa that atatoarla eaa to prayer*! far *M*lai aal * tto lasarattaa af callhrattaa curve*. Tha aathal af tuaatltetfaa la total aa a thru-pa**1 callhrattaa eurva aal*| atatoarla af tto aaalpte(t) af. tataraal war tto raata af eaacaattatlaaa la tha aaaplaa. A **yatat callhrattaa Mttol caa ha vael (aa vtth tto laharatarp lata HONS 023*83 HARTOLDMON0035198 Cretan) ftrrlM lUt IlMitlly Iti Wn MuirnW ever iw mtntutiM ef tic MBflcc wtM ataalene cl tic aulvte(t) at lira# ta the iM|t. Thia nUWittM carve t twa aael ta rrevlle ceaeaatratieae ef tla iail;ti(i) la tie atari via a ntirul ataalarla miM at aara ftafarahlf via latent! ((Marla HtM. far tti leteanal ataalarla aatkel, the imtuti* tlaa Inured atanlarl ta alia! ta each af tha ataalarla aa vlth tha auflta) friar la leetrwMaul aaalfata aal relative rreM factara are lauralutl. far 'aaatltettve aaalfata tla aaaa afactraaatar ta aftratal aa a |a (IraaatairafhK latactar. Via m la tharafera tueal aal afaratal ta a Manat afecifial la tla (ffraval aatlal rather tlaa n|i| a cal lira* tiaa caaraval aa ra'alrel far tvalllattva aaalfaaa. Quality Critarta an! taaaltal ictlaa Tla teclualea af QA/QC aaeaurte lata aa aaalfata frairaa laa llttla aaaatai ualeee tla raavlte ara tatarfratal aal affrafrtaia aettaa ta tahaa when aacaaaatf. Tla altlltf ta la tlla aiiaa aaaa eat af criteria flat vlll trt||ar a raafaaaa ar rcaallal aettaa. Tla fellevina eubeactlaae laaartla tla critarta tlat ara ueel in tla Vltratrace Anal fata Cray? ta cvalaata vtiaa eualttf caatral lata taltcata a aaal far carraettva aaaauraa aal vkal tanal la1 aettaa vlll |a taaaa. I. QuelItf Criteria ' Tla averrllini (ualttf crltarlaa alava all atlara tai te tit rtaulja aaat tla aaal a af jhj caataaar. Ufa lateraiaatfaa villba"nale * jatatlfbetvcaa tha caataaar aal tie aaalfat. The aaalfat auat aaarctaa cauttaa ta aat allavlai tla caataaar ta everatete, alatater* fret at uafataat taaal If atarafraaaat tla lata, la alllttaa ta tMa print cMlttf crttarlaa, tha fellavtat caalittaaa auat W aati a. Ilaaha * la tha avaat tlat a llaak ftalvcaa a faaittva valve, it Mf aat la aaal aa a valtl llaak If It aaceala 191 af anf rcfartal value far a aaafta. I. ftecevertea * kaeavartaa fat all aurraiata anl aativa eftkaa aval Ita ta tha tu| af $Mlacavarfl)OI. e. fracialaa - fractatea will he caKulatal lead aa the racavartaa af aurraiata internal ataalarla. Averata racavartaa vtll ha ealculatal vlth t ataalatl lavlatlaa fat each ataria aat. iafll* fata aaalfaaa aal lav aal blah native aftha racavartaa Mf alaa la aaal ta frevile allttteaal Infernallea/laet|ht lata tha iraefafaa af the aMlftte.I I HONS 023^8^ HARTOLDMON0035199 4. llftll af P*tttU* . Jta Halt tf litKtlM (Ul) fltl nitiUr U MitW II H tw ilM af tt* laa 1ml aatioa tftta If 11 1* ftCCVtttf Ml IMMlfUVIlt fkovld Ilk* IW llfll Wtltf ayllt **t kt itcat#taf, iM im Mil w tutaf \ tkt MU* af tka M|k 1ml Ml It* ifllt If It I* racavcraf mi ftMtiflakla. IkMll ulttet tylU U iMtiiWf i daclal** wt kt aada nprltii Ik* miMklllu if rtyractailaf tki M*ylt. ikMll *11 unfit* cMtato mk lt* taaatttla* tf iW aatlytaU) tut tkt 1t1* tf tU !* mi kl|k tylkta trt l*tlfl*lflct*t (<l(t) ky tH|ir(Nt tU nlu tf tk* IM tocaata Ittt laftrtmt mi St atayly tttttf tt tU IM far tU Uttrutntal aatlyala yrtctit dtttratotd ky tkt tttlyt1* tf attaftrla mi tk* akility tt rtcovtr tkt artt|tt ayliat. t. Aecuraty - Tk* accuracy tf tkt tulyttl it katt litmtul ky tMlyilti mm attylt Mick cmtalat tk* ttalytt tt toa* yrtdttaralttf Itrtl (t.|> t* VIS itMlidliil attylt). If tki* tyy* tf ataalarl It tat trtlltklt tkt* tkt law Ural U kl|k Ittal tylktt cm kt attf at a Mtrata tf tkt tcttracy tf tkt tulyttt. laaaltt Mtt fall vltkla a vat|t tf lit tt 1)11 tf tkt tacayttd vtlta far tkt ttalytta ta kt CM tldtrtf t*a I1I. If tha tkavt tttllty criteria art tat ut tkt aaalytt till lcctdltttly aittit tU ml ftr tnl Mint tf tMtdial acttM tUt aty U atcttitty. a. tCMltal UtlM TU ftrat ctarat tf tctlM will kt far tkt ttalytt tal/tr iravy ltaltr ta CMtact tka cwaioaar mi dlacvtt tU rttaltt ytfatl*| tat tb HaliatlMt tf tU Ittt iafitataf ky tkt tttllty cMtrtl ratalti. At tklt yaltl tka atarrMitf taality critartoa af cattoatr aatlt till kt aHrtattf flrtt. It cavil U tUt tU cvitwir'i utli trt mi vltUwt atattei im at aara af tka atktt crlttrla. ta auk a eact m rMilltl actlM la auttttry. It cavil alia ka tkat tU caatMtr U tvck t laatal ftr ti|ktattt la tk* rtatlt* tUt kit utdt art tat mi tvc* tkat|k tka atUr ttallty criteria art. tkia tatli tritiar further aaalyaaa witk tllktar faality CMtraS Itciftal arttal tU rttaltt tkttlatl (a.|.t rcylicttitaa tf yaaitivat ta Uttar tttakllak yrtciaiM ar ayittt af aa> lattertf Maylaa ta Uttar Mttkliak tka llait af IctutiM). ta CMtaStatiM vitk tU caatoMt tllititatl wytrtotal* will kt Ittitaal tocltltei tkt tyyrtyrlttt *ullty ceatrat u *lttoat#ly yralto tka rttaltt af mfficicat faality ta atat tkt euataatr** attla. IV. fitu Tkia atetiat li.lt tritk tU auVJaft tf Ittt t*4 kew tUy trt tkttiMi, rtcarltd tad rtdteid ta at ta U #*#>!* to t rtyar* mi yat rttdlly ttalltklt ftr rtltccl mt iatytctltt. HONS 023485 HARTOLDMON0035200 1M Msylaa Vlll to IlMH ittl I l*t stof * aaayla lagla ttc*(4ii| ta IH ytacafara faacrltof U tto CSC btliM V Sim), m 4dlt*4 ta tto iiimmiUi h>m*i tM M.*fiii sty IM iniIm afflttasal latolto| liml aacaa* aary. Alt iMIUmiI liWUi| U1 M 4kimk4 Ii UWtttii; U|W*t mI/k wiMI. TMaa ii4 aatiWaka vlll M mi4 ky tM IUI7111 ta racarf ]) H'tUtH mtI u4 MHltl aktatoaf (tn (M infill. tM liktntttj Mtttoeka vfll M ftllaf nt to accarlaaca vttk hiinti Ml far* feutook rrMHim. All rav 4iti |ii<ntt4 far i |lin ftijitt, Aid ct*t Vi caavaafaatly ylacaf to tM latoratary MtdMl (i.|,, ckraaatairaaa, m^tit avtyvt* ate.)* will to did *4ii mw yraacrltof ttfar <l.a. tag avaMr) to a caatral Ilia w4tt tM aayarvtaoa af tM hajact U(4at aaf/ar (t ftyaclaltat. Mat af tM fata gaaatataf ky tM Vltratraca Aaalyata Gravy ara cavyvtar fata ataraf a* M|aattc 4laca. la atfar ta atckfva ttoaa fata tM ayaeffta flla mm aaf flat auaVar aatoclataf vitk tM iMlyata will M vrlttaa faw ta tM laMratary aatatoot aaf/ar iMtratant lagtoak. VMa tM ffac fa cacylataly fall af fata aa aatfra vnafltaf flat lsk|a ar cayy af tM ftlaa aa tM flat trill M traaafartaf ta ai|iUt tM- A lattoak vlll M kayt fat racarftag tM flat mWi, aaai aaf ytafto aaaact* ataf vitk it, alaa| vltk tM aaaatfataf taya aaf ffla auator ta Aid tM flat vaa traaafartaf. to aaaayla af avek a lagtoak fa |i*aa fa ft|vra 1. VMa tM fata ata traaafartaf a varIfteat lav yraitaa fa Maf ta eMek all traaafartaf tacarfa fat eartacraaaa. VMa tayaa ara ftllaf ft My tyyfeally Mil itvn ta taa flat fvagta) tMy abawlf M ataraf to a fftaytaaf vault. All calealatlaai af tM taaalta af tM fata vlll M antilUf Is tM aatMf aaf. Thaaa caltalatfaaa will M aatatai fa tM aaalytta laMratary aataMak aalata tMy ra caayatar gtaarataf. 1a tkfa caaa, a cayy af tM caayutar aatyat vfll W fflaf vfth tM rav fata. TM Frsjact taafar vfll M raayaaalkla far ckackfng tM carrtctnaai af tM fata. terliiUeif! ftsylaa vlll M ffayaaaf af fa accarfaaca rid tM toatractfaaa aa tM Asalyafa tagvaat fan. tto aaly aacaytfaa ta tkia vaalf raavlt Ma tM aaalyata ravaala a yratlas did ra'vfraa aaayla ftayaaal to a saaaar atMr tMa tMt artttaally ayaefftaf. If tM Frajact Uafar aataa fraa tM raaalta af tM aaalyala tMt a yottottally taafe yrafuct vaa yrtaaat ta tM aa*ylaa tMa tM aasFlaa vlll M ffayaaaf af to a saaaar faasaf aafa ky tM lafaty Myarcaaat. TM fata af aaayla ffayaaal aaf tM saaaar atovlf M aataf aa tM ragvtat fata ataraf vltk tM rav fata caaylatfai tM eMto af caatafy af tM aaayla. HONS 023AS6 10 HARTOLDMON0035201 Htm* hitfitiw) imll* lm * Vtu n /* (*> vy&*** 'Aywy bonnnx >/ij/o C^Wfi o\ ituytu) t10 W^u 11' CbtlCQ fix. <JU*J - `r 6*twj /W 0*3> g**k> t>< /^V*^w r^*?/6 '*' V/r* Gfc*Vf> (p fsO 'V/l **W os <*6t*fi irfft Ow m Ut*) *** j^A> tsc l>1 (t$ Ca) >n 4N*tl <rAC wo J. i>f s*' >*1.-0 / MfecpMO r. - 4rvftOlV4l*Ail?7ftf4lK. /O Wu*} s*3 $*> iAb /N <touy)r<Q * ^ flSJl i J' 'sfalt* i/*j, n 'i * font!) Gt>V(s\ folMvj on o(tfttntHn)(Mt O W yhtkj&K .s*fr W3(4l (Mil) t* iV# 'Ae*o fo. /y*. 6f6>0 /Y> (Wo*) ,Y/ Way) ft *5^*5 4* * wo WD &VMV <U Gd-WfiTj >U_ '*<*) , /**> ftw*) / 1*1 /VH**) I tn (hJ sasii 1 -*t> Y//3 a q*ifts ra 4/tAi >13 Qy o (a 4} *^t**vcJ 4*4 fc/*>Aj $** <0 ^5# aij *I*Ay.*OX **S 6>9M$ i (fa3 Am* i^i^i JA"t #*0 I aO f*w> ^ i a^|< iMwh* .ftcMPAiAdn); # J runt J. Kakl* ( fttSC/1M U|te*l Ml* HONS 023487 II HARTOLDMON0035202 Monsanto r -W from {NAMC-LOCATIO* -HONt, r. f. Ivory-EA5C-Dayton-1250-ext. 417_____________________ OAT* 9UBJCCT : January 20, 1981 : ANALYSIS OF SAMPLES FOR PCB CONTENT D. J. Dahm-1250 C. s. Friedman-1250 RCFIH EMCC : MRC Job #408.1010 TO : J. Brown 1060 Anniston Three fluid samples were analyzed for their PCB content by MRC Method MRC-08-GC-RO. The samples were screened for PCB Aroclors 1242, 1254, and 1260. The sample chromato grams were compared to standards of these Aroclors, for identification and quantitation, run under similar condi tions. The method has a lower detection limit of 1 yg/mL (ppm). Results of these analyses are listed in the following table. PCB Content in Samples Sample ID PCB Level yg/mL (ppm) HLD Flush Material HB-40 Vent Material HB-40 Sump Pit Material 5 NDa 108 aND = not detected, if present concentration is <1 ppm. If you have any guestions, please contact me. f^.t- f -------- y Robert F. Ivory "Xj EASC Service Project Manager bh osw 022540 IK - IO - KEV 8 HARTOLDMON0035203 _ 1 // AJ CA,, ., / y^ff-- -t-S fi- //' 5 r^ ^ /T ` - J /^ ' '_,. A--, cW o/" / vi . -,, ,, x> f /'- 7 "?. tj /Z&- -4 <*97 -' \ <ZL~r&*- /U^L /-" r-- <:' ^a rv -..* ,--?V* ' ^ r- , . <-_- **' tv, V 5V- - ; . .'.< ' .zn ____ ..~w/ OSH 023281 HARTOLDMON0035204 UNITED STATES ENVIRONMENTAL protection ir.rurv Apr o 5 issi 349 COURTLANQ STREET N.EATLANTA. GEORGIA 30349 Mr. Robert Jonas Monsanto Chemical company 300 Birmingham Highway Anniston, Alabama 36201 Re: EPA Contract No. 68-W9-<$040; Work Assignment No. R04-11-03; Monsanto chaaieal Company, Anniston, Alabama; EPA ID No. ALD004019048; Visual Sits Inspection Agenda Daar Mr. Jones: The Environmental Protection Agency (EPA) Region IV is conducting a RCRA Facility Assessment (RFA) of the Monsanto 4 Chemical company in Anniston, Alabama. The 1984 Hazardous and Solid waste Amendments (HSWA) provide EPA authority under RCRA to require comprehensive corrective actions on releases of hazardous constituents to air, surface water, ground water, and soil at facilities which menage hazardous waste. The RFA includes a review of the RCRA, CZRCLA, Air, and water files at the EPA Region IV and Alabama Department of Environmental Management (ADEM) offices, as well as a Visual Site Inspection (VSI), and, if necessary, a sampling visit (SV). A VSI of the Monsanto facility is scheduled f 1991. The VSI will be conducted by A.T. Kea Contract No. 68-W9-0040. The objectives of identify all Solid Waste Management Units (Si Areas of Concern (AOCs) at the facility and potential for past or ongoing releases constituents. Enclosure A is the Proposed RCRA VSI Agenda which includes a list of potential SWMUs and AOCs (Table l) identified from the preliminary file review. Enclosure B is a summary of the general information gaps identi#*R<* ** mvIrm. *% enclosures will be reviewed wit at the beginning of the vsi. A1 be adjusted as needed to facil expeditious inspection of all ] storage, treatment, and dispo< include all indoor or outdoor and transfer points in operatic photographs will be taken to doc of all SWMUs and AOCs, as v management practices. RECEIVED APR 08 1981 Ais'tf......... OSH 081582 HARTOLDMON0035205 Mr. Robert Jonas Pag* 2 in preparation for tha VSI, tha contractor is required to identify any potentially hazardous conditions likely to be encountered during the VSI, and, if necessary, prepare a safety plan to deal with anticipated hazards. The contractor will contact you prior to the VSI to obtain specific information regarding materials handled and the level of personal protective equipment required for entry into the facility. The A.T. Kearney inspection team will consist of representatives of EPA Region IV and the Alabama Department of Environmental Management, as well as individuals from the A.T. Kearney Team. If you have any questions concerning the VSI, please contact the EPA Region IV Work Assignment Manager, Ms. Nancy Bethune, who vcan be reached at (404) 347-3433. Sincerely Yours, Beverly f. Williams, Qiief AL/MS unit ' Waste Engineering Section XSk Federal Facilities Branch Enclosures cc: Jerzy Bohannon, ADEM OSW 061583 HARTOLDMON0035206 enclosure A PROPOSED RCRA VISUAL SITS INSPECTION MIVDA Facility: Monsanto Chemical company Anniston, Alabama EPA ID No.: ALD004019048 Facility Contact: Robert Jf. Jonas 300 Birmingham Highway Anniston, Alabama 36201 Facility Address: west 10th Street Highway 202 Anniston, Alabama 36201 Inspection Date: April 17-18, 1991 Inspection Team: Denise Turner, A.T. Kearney Jasmine Schliesmann, A.T* Kearney Nancy Bethune, D.S. EPA Region IV Jerry Bohannon, ADEM OBJECTIVE OF VISUAL SITS IMSPBCTZOEl The Hazardous and solid Haste Amendments (KSHA) of 1984 broaden EPA's authority under RCRA to require corrective action for releases of hazardous and solid wastes containing hazardous constituents at facilities that manage hazardous wastes. The corrective action authority extends to all Solid Haste Management Units (SHMUs) at the facility. The first phase of the corrective action program as established by EPA is performance of a RCRA Facility Assessment (RFA). The steps in the RFA process include a preliminary review of available file information, a visual site inspection (VSI) of the facility, and if necessary, a sampling visit (SV). a preliminary review of file materials has been performed for this facility, and it has been determined that a VSI is necessary. The purpose of the VSI is: 1. To collect all available, relevant information on solid waste management practices that have been used on the site; 2. To gain first-hand information as to the identification, location, construction, configuration, function served, method of operation, and condition of each SWMU; QSU 061584 HARTOLDMON0035207 3. To-confirm, by visual inspection, information collected during the review of file asterials; 4. To survey the site for additional SWMUs and other Areas of Concern (AOCs) not identified in the review of the file materials; 5. To identify potential sample points for possible future sampling activities; 6. To review the site information and collect additional information to address the information needs identified during the PR; and 7. To take photographs of all SWMUs and other AOCs. IMSPSCTXOV FLAX AMD BOODOLMt EPA's contractor will send a two-member field team to perform the visual Site Inspection. A two-day Inspection is anticipated; however, the field team is prepared to extend the VSI through April 19, 1991, if necessary. The team will inspect all past and current solid waste and hazardous waste handling, storage, treatment, and disposal areas on site, outdoor and indoor waste generation, collection, and accumulation areas will be inspected as necessary to acquire a complete understanding of waste streams, waste flows, and waste handling procedures. The team also will identify, inspect, and document potential pathways for release of hazardous constituents into the environment. Facility staff will possibly be interviewed to develop a better understanding of past and current waste management practices. At this time, the facility may present updated environmental monitoring or sampling data that may not be in the current EPA or State files. Data nay include any soil characterization, hydrogeologic data, air quality data, or any other supporting studies. . The overall rationale of this inspection is to enable the teas to trace the waste flow through the entire facility from the points of generation to ultimate disposal. The following schedule has been prepared based on the preliminary file review, and is intended as an outline for a thorough and efficient inspection of all SWMUs and AOCs on the site. Some adjustments to the proposed agenda may be necessary to accommodate facility staff, location of units, operational constraints, or unforeseen conditions. This proposed schedule will be reviewed during the introductory meeting and adjusted, if necessary, at that time. The VSI field teas will sake every reasonable effort to conform to the facility's normal hours of operation. 061585 HARTOLDMON0035208 A general--schedule for the VS I has bssn dsvslopsd basad on tha infomation gatharad during tha PR. Dua to tha fiald team's lack of inforaation ralating to sxact locations, it is suggastad that a facility sap bs available during tha introductory nesting so that ths inspection schedule can bs finalized batvaan tha inspection taaa and facility representatives. Also, at tha introductory nesting, the SWMU list and inforaation needs will be reviewed with facility representatives to resolve any remaining issues or questions. 0S 0*1586 HARTOLDMON0035209 ZXB2 APRIL 17 , 1991 8:00 - 8:30 8:30 - 12:00 V 12;oo - 1:00 1:00 - 5:00 APRIL 18, 1991 8:00 - 12:00 12:00 - 1:00 1:00 - 4:00 4:00 - 5:00 APRIL 19, 1991 9B0P0SID VSI SCHSDUl* M0M8AOTO grraTCAL COMPANY April 18-19, 1991 ACTIYIXI Introductory meeting with facility representatives; discuss aganda, safaty and haalth considarationa, and transportation arrangaaants. Discuss past and prasant facility operations, vasts streams, vasts floVa, generation, collection, treatment, and disposal methods. Identify any SMKDs and AOCs not identified in file review. Lunch break. Begin tour of the facility. Inspect vasts generation areas, vasts collection devices and systems, and vasts accumulation areas. Continue tour of the facility. Inspect vasts generation areas, vasts collection devices and systems, and vasts accumulation areas. Lunch break. continue tour of facility. Inspect vasts generation areas, vasts collection devices and systems, and vasts accumulation areas. Closing meeting vith facility representatives. Discuss information needs generated by V8I* Obtain any additional information on SWMOs or AOCs. Reserved, if additional time is needed. To be determined by VSI Team Laader. OSH 061587 HARTOLDMON0035210 TABLI 1 SOLID WAITS MANAGEMENT OMIT* AID OTSSK ABSAI OF CONCERN MONSANTO CHIMICAL COMPANY SOLID WASTE MANAG :.UMITS LANDFILLS 1. Inactive Cell IE 2. Inactive Call 2E 3. Inactive cell iw 4. inactive Call 219 5. Inactive Cell 2WA ' 6. inactive cell 3W 7. closed cell 4tf 8* Cell 3E 9. Closed Cell 4E 10. Closed cell 5E 11. Mixed industrial Waste Disposal Area SURFACE IMPOUNDMENTS 12. 13. 14. 15 - 18. 19. closed Neutralization Basin Old Neutralization Basins (2) Closed Liaestone Bed Surface lapoundaent Landfill catchment Basins (4) Landfill Runoff Retention Area (if constructed) STORAGE AREAS 20. Closed Limestone Bed Storage Area 21. closed Neutralization Basin Storage Area 22. Closed Warehouse Building No. 2 Storage Area 23. 90-Day Storage Area 24. Hazardous Materials Storage Area 25. waste Pile/container storage Area No. 1 26. Waste Pile/Container Storage Area No. 2 27. Used Nickel Catalyst Storage Area SATELITE STORAGE AREAS 28. Laboratory Duapster 29. Agricultural Warehouse Dock Duapster 30. Niran Duapster 31. . Pentasulfide Duapster 32. Hold Tank Area Duapster 33. Basin Wall Recycle Duapster 34. Niran Recycle Duapster 35. PNP Duapster . . OSM 061518 HARTOLDMON0035211 TMLI 1 SOLID VAST! KAXAaXXXVT UNITS AMD OTHER ARIAS Of CONCERN MONSANTO CHEMICAL COMPANY (continued) THERMAL TREATMENT 36. Old Trash Incinsrator 37. Reuse-as-ruel Boiler BIOLOGICAL TREATMENT SYSTEM 38. 39 - 40. 41 - 48. 49 - 52. Procsss Wastewater Ssvsr Hold Tanks (2) Asration Basins (8) clarifiars (4) TANKS 53. Laachata Intaraadlata Storage Tank 54. Hazardous tfaste Aboveground Storaga Tank 55. Hazardous tfasta Belowground Storaga Tank SUMPS 56 58. 59 61. 62. 57. Boilar Suaps (2) Call 5E Suap 60. French Drain Piping Systaas (2) Neutralization Basin suap Neutralization Basin Undardrain Suap CORRECTIVE ACTION SYSTEMS 63. Western Landfill corrective Action Systaa 64. Northern Landfill corrective Action Systaa 65. Plant Corrective Action Systaa 66. Liaaatona Bad Xapoundaent corrective Action Systaa MISCELLANEOUS . 67. Paranitrochlorobenzene Unloading Dock 68. Acetone Recovery Column 69. Trash Duapsters 70. Snow Creek Drainage Ditch 71. Storawater Drainage Systaa oramab. .spycaaf A. Product Storage Tank Spillage Area B. snow Creek PCS contaaination Area C. Foraer Off-Site Landfill ASH 061589 HARTOLDMON0035212 ATTACBOlfT B - K7X xmfoxjkatxob mibds 1. Provide description of vasts management practices and dates implemented. 2. Provide type and volume of waste generated. 3. Provide most recent biennial report. 4. Provide surrounding land use information (e.g.r distance to population centers). 5. Provide description of drum storage areas: Location Type and volume of waste secondary containment Frequency of pick-up for disposal/treatment Treatment/disposal method 6* For each accumulation area, provide: Description Length of time waste normally stored Secondary containment Type and number of containers Type waste generated Waste management procedures Spill/release history 7. Provide any sampling reports of analysis performed on the sediments or water in Snow Creek. . 8. For each SWHO and AOC listed, please give: Date unit began operating Date operations ceased {if applicable) Dimensions of unit Location of unit in facility Description of waste handled Unit function Katerial of construction Release controls History of release 9. Provide recent stapling results: Groundwater Soil wastestreams 10. Provide a site map of suitable scale to show boundaries of all contiguous property which can be used to show the locations of the SWHOs and AOCs on the property. 11. Provide sanitary, stormwater, and industrial sever maps. OSM 061590 HARTOLDMON0035213 ATTAdxnrr KVA ZXT01UCATI0W X1IDS (continued) 12. Provide a currant list of permitted emissions, tha results of tha Boat recant inspection by tha Air Pollution Authorities, and documentation of any violations. 13. Explain tha NPDES permit status of tha facility. Provide tha results of tha most recant compliance monitoring test results and documentation of any violations. 14. Provide a history of pollutant spills/releases for the facility. Information should include: . ' Date of. release Quantity of release or extent of release Location Description of product corrective action taken Soil/water analysis results 15. Hov are domestic refuse and sanitary wastes handled by the facility? - 16. Provide information on all manufacturing processes which have been and are currently being conducted on the property [flow diagrams would be most helpful]. ' 17. Provide a site map of suitable scale identifying the location of all facility monitoring wells. . 18. Identify past or present SWMOs and AOCs which have not been identified in the VSI Agenda. Include a brief description of the wastes managed in these units, the period of operation, and a physical description. Units include, but are not limited to, the following: Aboveground end underground waste storage tanks Abandoned storage tanks Haste storage units for solid and hazardous wastes which fall under the 90-day exemption from RCRA . All waste handling areas and associated activities including loading zones, transfer areas, and waste accumulation areas Runoff collection sumps 19. Identify sources of drinking water in the area. Where does the facility obtain its drinking and process water? 20. Provide documentation on how all former process units were disposed of. OSH OA1991 HARTOLDMON0035214 . JtrracsxuRr j ' BfA IMTOItK&TXO* XlIDfl (continued) Provide the start-up date of the facility and subait a history of the facility prior to the start-up date, including foraer owners, aits uses, aanufacturing processes used, waste generated, and existing buildings and/or structures. OSM 061192 HARTOLDMON0035215 Monsanto \ . i i . TO W. F. Taffee - Anniston, Alabama November 6, 1975 PCB DISPOSAL DATA JRS Request 10/31/75' J. R. Savage - B2SL St, Louis J. L. Brown G. L. Jessee W. L, Kraus B. 0, Severson ^ E. Voss Jim, per our telephone conversation this morning you will find attached copies of all the plant liquid effluent analytical data which we still have in our files for the period 1/1/71 through 6/30/75. 1. Effluent to Snow's Creek la reported through October 1972. See attached letter from Alabama Water Improvement Commission dated 13 November 1972. All available data for the period 1/1/71 through 10/31/72 is included. 2, Data on fish samples taken by Cunning and Sutkus are enclosed. 3; We can find no indication here of any sediment analyses. 4. No data here on receiving water analyses. IN ! l' 1 UhW OJttb90 HARTOLDMON0035216 ^7 Monsanto r0 ft location. D. Gerald Glasgow-EASC-Dayton-1250 <Tf$ <-T7r-rv- C?<v*'u<i L^rtX - SfC. ft sujrc r January 18, 1979 PCB CONTENT OF OIL SAMPLES D. J. Dahm F. N. Hodgson A. J. Wright MRC JOB NO. 408.0671 and 415.0920 TO J. L. Brown Anniston The samples of oil which you submitted recently on three occassions for determination of PCB content were analyzed under the conditions given below. The PCB concentrations below (calculated as Aroclor 1242) were found. Date Received 14 Dec. 1978 18 Dec. 1978 9 Jan. 1979 Oil Identification Sample HB-40 oil Therminol 66 from Santowax system Therminol from HB-40 system Sump HB-40 vent tank Therminol 6fe HB-40 plant PCB level, EES 260 1 210 280 7 50 The oil was diluted with hexane and analyzed by electron capture gas chromatography under the following conditions: GC Model: Column: Column Temperature: Injection Port Temp.: Detector Temperature: Carrier Gas: PCB Screened for: Varian Model 3700 61 x 1/4" glass packed with 4% XE-60 200*C 220C . 350*C N* at 45 ml/min Aroclor 1254 and Aroclor 1242 The PCB present was identified by comparing the sample chromatogram to those of Aroclor 1242 and 1254 to establish which of these two was the most likely PCB present. The PCB level was then calculated using the corresponding calibration curve. Please contact me at Ext. 328 if you have any questions. DGG/bap D. A&C400H/ D. Gerald Glasgow EASC Project Manager OSM 022941 in . n v J 72 HARTOLDMON0035217 "y iml mvcrs, m. d. STATE health OFFICER Stats of Alabama Department of Public Health State Offici Building Msntgomery, Alabama mho January 22, 1980 MEMORANDUM TO: Mr. Alfred S. Chipley, Director Division of Solid Waste & Vector Control FROM: Darrell A. Baker, Public Health Engineer - Division of Solid Waste & Vector Control RE: Monitoring Wells for Monsanto, Anniston PLAINTIFF'S as.EXHIBIT 1 met with Mr. Jerry Brown of Monsanto and Mr. Paul Moser of the Alabama Geologic Survey on January 10, 1980 to discuss implacement of monitoring wells for Monsanto's disposal site. After a visit to the site, Mr. Moser recommended that the wells be implaced as per the attached map (1-upgradient, 5-downgradient). I sketched the proposed construction of the monitoring wells, which is also attached. I also obtained a copy of a soil study made at the disposal site in 1973 (attached). I believe that the sites chosen for the monitoring wells are well located and should give a good indication of any ground water contamination. While inspecting the disposal site, I noticed that the dam which surrounds the parathion waste pit has broken at the lower extremity. Mr. Brown said that this will be corrected when drier, weather permits. I also discovered an underground spring which surfaces from a hill west of the catch basins and north of the biological solids disposal area (downgradient from the bio solids area). The water was filled with a substantial amount of brown algae. This may be an indication of phosphate contamination from the biological solids area. All drainage from the area empties into Snow Creek. DAB:se Attachments M24775 HARTOLDMON0035218 Monsanto -r - ** - ' .tC** O* J. B. Moon - Anniston February 8, 1980 * T -*twO TO J. L. Brown Our current solids problems in waste treatment are of major concern to me at the moment. I feel that a somewhat fresh approach must be taken to analyzing this problem. I know that you have considerable back ground in this area and also have developed natural biases. Please try to put aside those biases and look at our existing data to see if there are clues to pre dict when we are headed for upsets. Our approach must change from one of telling people that they have a problem to that of telling them, 1) they are headed for a problem and what is causing this direction, and 2) how, once the problem materializes, it can be readily corrected. Please document to me your plans in developing a new approach to solids problems. . JtAwv. J. B. Moon /md OSW lOkHlS r. f HARTOLDMON0035219 'client: MONSANTO Sample: 90229 Lab ID: 8804MS12 PCS FRACTION Date Extracted: Date Analyzed: Time Analyzed: Analyst: 04/26/88 04/28/88 17:38 MCR Coroound Chrom. Ret. Time Col, 1 Col. 2 * (in,) Sample Concentration (ug/Xg) Aroclor-1016 Aroclor-1221 Aroclor-1232 Aroclor-1242 Aroclor-1248 Aroelor-1254 Aroclor-1260____________ 11-24_______________ BOL BOL BOL BOL BOL BOL 58500 Surrogate 2.2'.3.3'.6.6'-HCB Recovery: 154Z MOL (ug/Kg) 14000 14000 14000 14000 14000 28100 28100 NOTES: MQL: SQL: *: ** : B: MS : Method Quantitation Limit Belov Quantitation Limit Col. 1: 6 ft x 2 hi 3X SP-2250 Below Quantitation Limit, but Detected Detected in Blank at Level Indicated Matrix Spike Compound DSU 022307 ENVIRONMENTAL INDUSTRIAL RESEARCH ASSOCIATES, INC. HARTOLDMON0035220 |i M ' 2*2-c. * - 0 ** 3 1 c 5.. 1.35 3 37 0. -7 S "c 9. :*-- :S. 95-- :2.35-- * 4. *5" 15.33-- 17.9* :5. 35-- 50. 20 i7. Is * - I * * 15 * i i * * **m *3.50 *7. ;3 o 374 ?. 07 *4-753. *' 15075.93 '5794.32 00631.*3 75391.34 .ii3iZ.it 1*325.2* :7i:i4.ac *< sW -**V<>B r i v *3323.33 1791 ^3. 59' 11 *311.09 6 3 5 5 3 S. i y ;5 L*3*0*3.93 325793.39 33c 103,33 "2:56. 3y -a - - 6h*<l 2.12 375 1cc ~rt ic r 0Stf 02250* 2:3 w* "*5 HARTOLDMON0035221 HARTOLDMON0035222 cr H- C 33899 S SAMPLE J 17 nSE.fi V. ffpLiS INJECTION 8 I5i3i fi.PR 28 > 13 CG3c s 8334nSi3 ^ AtLizcjC pyr <2')5iq$ 1983 R7 -Rift TYRE. ARi.fi \ 1.33 5.96 6.46 9. :3" 10.9911.2312.84- i i9k 14.45" 15.58-- [ 15.95-- 29.27 22.2329.12 35.63 33.49 43.56 48.11 3355.79 P? 13299.40 PV 17306.*0 YP 51345.90 VV 58938.49 VV 32396.40 VV 77017.60 VV 124924.90 VV 116514.90 VV 126052.30 VV 67633.90 VV 232353.00 VV 249627.90 8H 953952.00 HH 89523.30 HH 92643.30 HH 53823.29 ft HH 0.147 0.5*13 0.7:3 ' 2.116 2.431 3.395 3.174 5.111 4.301 5.194 3.611 9.343 10.287 39.274 3.31? 3.318 2.218 OSM 022510 TOTAL ARIA * 2426660.00 *ul":?l:e= i _ *5.6 c? HARTOLDMON0035223 r ENVIRONMENTAL INDUSTRIAL RESEARCH ASSOCIATES, INC 161 James Drive Nest, Suite 100 St, Rose, Louisiana 70087 (504) 469*0333 METHODS Inorganic Analyses on Water and Wastewater: 1. Standard Methods for the Evaluation of Water and Wastewater. APHA, AWWA, WPCF, 16th Edition. 2. USEPA Contract Laboratory Program. Statement of Inorganics Analysis. Multi Media, Multi-Concentration, SOW 787. Soils, Sediments and Hazardous Waste Evaluation Procedures: 1. Test Methods for Evaluating Solid Waste. Physical/Chemical Methods, SW-846, USEPA Second Edition, Revised April, 1984. Organic Analyses on Water and Wastevater: 1, "Methods for Organic Chemical Analysis of Municipal and Industrial Wastewater", 40 CFR Part 136, Appendix A, USEPA, Amended . June 30, 1986. PCB Fraction Method 600 OSU 022J11 Quality Assurance Manager Date ENVIRONMENTAL INDUSTRIAL RESEARCH ASSOCIATES, INC. HARTOLDMON0035224