Document 2jJwv2KbOK51LgJwzRq8BQbLr
Page 1
IN THE CIRCUIT COURT FOR ETOWAH COUNTY, ALABAMA
(Transferred from the Circuit Court of
Calhoun County, Alabama)
SABRINA ABERNATHY, et al.,
Plaintiffs,
versus
CIVIL ACTION NUMBER
CV-2001 -832
MONSANTO COMPANY, et al., (Consolidated)
Defendants.
/
DEPOSITION OF WILLIAM TAYLOR CAMBRON
The deposition of William Taylor Cambron
was taken before Misty Perry Sanders, as
Commissioner, commencing at 9:00 a.m., on January
4th, 2002, by the Plaintiffs, at the law offices
of Fite, Field & Miller, LLC, 1000 Quintard
Avenue, Anniston, Alabama, pursuant to the
stipulations set forth herein.
Regional Reporting Service, Inc.
755 Walnut Street
Gadsden, Alabama 35901-0755
Page 3
1 STIPULATIONS 2 IT IS STIPULATED AND AGREED, by and 3 between the parties, through their respective 4 counsel, that the deposition of William Taylor 5 Cambron, may be taken before Misty Perry Sanders, 6 as Commissioner and Notary Public, Alabama at 7 Large, at Anniston, Alabama, on January 4th, 2002, 8 commencing at 9:00 a.m. 9 IT IS STIPULATED AND AGREED that the 10 signature to and reading of the deposition by 11 the witness is waived, the deposition to have 12 the same force and effect as if full compliance 13 were had with all laws and rules of Court 14 relating to the taking of depositions. 15 IT IS STIPULATED AND AGREED that it 16 shall not be necessary for any objections to be 17 made by counsel to any questions except as to 18 form or leading questions and that counsel may 19 make objections and assign grounds at the time 20 of trial or at the time said deposition is 21 offered in evidence or prior thereto. 22 IT IS STIPULATED AND AGREED that notice 23 of filing by the Commissioner is waived.
1 APPEARANCES
2
For the Plaintiffs:
3
CHARLES L. CUNNINGHAM, Esq.
4 ATTORNEY AT LAW
6010 Brownsboro Park Boulevard, Ste. G
5 Louisville, Kentucky 40207-1294
6 For the Defendants:
7 LARRY MYERS, Esq.
SMITH, HELMS, MULLISS & MOORE
8 1355 Peachtree Street, NE, Ste. 750
Atlanta, Georgia 30309
9
10
INDEX
11 Page
12 Stipulations
3
Reporter's Certificate
93
13
14
EXAMINATION
15
Witness: WILLIAM TAYLOR CAMBRON
Page
16
BY MR. CUNNINGHAM
4
17
18
EXHIBITS
19
Plaintiffs'
Marked Offered
20
Exhibit One
75
21
22
No other exhibits were marked for identification,
23 offered, or attached as exhibits hereto.
Page 2
Page 4
1 STATE OF ALABAMA, CITY OF ANNISTON
2 JANUARY 4, 2002
3
4 WILLIAM TAYLOR CAMBRON,
5 after having been first duly sworn, was
6 examined and testified as follows:
7
8 THE COURT REPORTER: Usual
9 stipulations?
10 MR. CUNNINGHAM: Yes, ma'am.
11 MR. MYERS: Yes, ma'am.
12
13 EXAMINATION
14 BY MR. CUNNINGHAM:
15 Q. Sir, my name is Charlie Cunningham. And
16 I'm here today to ask you some questions to
17 find out what factual knowledge you may
18 have that will help the parties in a
19 lawsuit styled Abernathy, et al., versus
20 Monsanto, et al., that's been filed here in
21 Calhoun County. 1 represent about
22 thirty-five hundred folks that have sued
23 Monsanto, and 1 assume you know that?
Pages 1 - 4
HARTOLDMONO013935
1 A. 2 Q. 3 4 A. 5 6 7 8 Q. 9 A. 10 Q. 11 12 13 A. 14 15 16 Q. 17 18 A. 19 Q. 20 21 22 23
Page 5
Yeah.
1 A.
I'm going to -- have you ever been deposed 2
before?
3 Q.
Yeah. 1 think it was a few years ago
4 A.
actually up here and one time in -- was it
5 Q.
Delaware? 1 believe it was Delaware,
6
yeah. It was cold. 1 remember that part.
7 A.
That was probably in the insurance case?
8 Q.
Yeah.
9
And then you're saying you think you were 10
deposed once here, and that probably was 11 A.
in the Owens case?
12 Q.
1 don't know which one it was. 1 know it
13 A.
was in Arthur Fite's office.
14
MR. MYERS: It was.
15
And other than that, have you ever been in 16
depositions?
17
Uh-uh (indicating no).
18 Q.
You know, then, the drill because you've
19
been through it twice. But I'm going to
20 A.
tell you two things about me that you may
21 Q.
not have encountered before. The first
22 A.
bad habit of mine is that I'll ask you a
23 Q.
Page 7
William Taylor Cambron. Bill is really what 1 go by.
Okay. And where do you live, Mr. Cambron? 230 Shamrock Road, Anniston, 36207. 1 am not familiar with Shamrock Road. What part of Anniston is that in? That's over in Golden Springs. Golden Springs. 1 know where that is. And tell me how long you've lived there, please. We've lived there about three years. And before that, where did you reside? On -- well, actually, we moved in my parents' house up on 22nd for about a year. It was a bad move. But when they died, we just -- and we lived on Allen Dale Road before that. And what part of town is Allen Dale Road in? It's out in the Coldwater area. Okay. And before that? Brindley Road in Saks. Okay. And before that?
1 2 3 4 5 6 7 8 9 10 11 A. 12 Q. 13 14 15 16 17 18 19 20 21 A. 22 Q. 23
Page 6
question, and you'll give me an answer,
1 A.
and I'll think you're finished when you're
2
not. And I'll go on to another question,
3 Q.
and by doing so, 1 will have prevented you
4 A.
from giving a complete answer. Sometimes 5
1 just have this burst of inspiration, and
6 Q.
1 fire a question off and again have cut
7
you off. So if 1 do that, let us know
8
because we want you to have a chance to
9
give complete answers.
10
Okay.
11
The second bad habit of mine is I'll ask a
12 A.
question, and I'll phrase it, and it
13 Q.
sounds for all the world like 1 know what
14
I'm talking about, and 1 really don't. So
15
if 1 say something, and it sounds like
16 A.
it's not true compared to what you know,
17 Q.
let me know that. Don't assume 1 know
18 A.
what I'm talking about because 1 may not.
19 Q.
Okay?
20 A.
Okay.
21 Q.
All right. Let's start off easy. Would
22 A.
you tell us your full name, please?
23 Q.
Page 8
Before that, 1 was in -- on Wilmer Avenue in Anniston.
And in what part of Anniston is Wilmer? Well, it was 2912 Wilmer. It was in the north part. The reason 1 go through all of this is just to see if you might have had environmental exposure to the PCBs, as opposed to the occupational exposure. It doesn't sound like you've ever lived particularly close to the plant? No. You're married, 1 assume? You talked about we when you talked about where you lived. Uh-huh (indicating yes). What's your wife's name? Shirley. What's her maiden name? Carroll. Has she ever had her PCB level checked? Her? Uh-huh (indicating yes).
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HARTOLDMONO013936
1 A. 2 Q. 3 A. 4 Q. 5 A. 6 Q. 7 A. 8 Q. 9 A. 10 Q. 11 A. 12 Q. 13 A. 14 Q. 15 16 17 A. 18 Q. 19 A. 20 Q. 21 22 23
Page 9
No. 1 Q.
Do you have children?
2
I've got three, and she's got two.
3
If you would, tell me yours, please.
4 A.
Debby.
5 Q.
And what's her last name these days?
6 A.
Brooks now.
7 Q.
Okay. Go ahead.
8
And William, Jr. -- Wiliam T., Jr.
9 A.
Okay.
10
And Barry.
11
Any of them ever had PCB levels checked? 12 Q.
No. 13
If 1 ask you for a list of adult relatives
14
by blood or marriage who live in Etowah
15 A.
County --
16 Q.
Etowah County?
17
Etowah County, the Gadsden area.
18
Uh-huh (indicating yes.)
19
-- basically who might be potential jurors
20 A.
when this case gets tried up there using
21 Q.
an Etowah County jury panel, would that be 22
a long list or a short list?
23
Page 11
Have you reviewed anything, looked at any documents or your transcript from your earlier depositions?
In preparation for this? Uh-huh (indicating yes). No, sir. Do you remember reading those transcripts at some point in the past? 1 don't even think 1 got - after 1 did that, 1 don't think 1 read anything about it. Okay. Do you have any idea what you might testify about in this case if you were called as a witness by Monsanto? Do 1 have any idea why I'm here? Yeah. We found your name on a witness list, and we're just curious as to what you might be testifying about, if you know. 1 guess because 1 worked at Monsanto. As 1 talk to you today and ask you questions, I'm going to assume since you haven't spoken to anybody or looked at
1 A. 2 Q. 3 4 A. 5 Q. 6 A. 7 Q. 8 9 A. 10 11 Q. 12 A. 13 Q. 14 15 16 A. 17 Q. 18 19 20 21 A. 22 23
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It would be a short list.
1
Can you tell me, then, who those folks
2
are?
3
My brother lives over there, Charles.
4 A.
Okay.
5 Q.
And his wife, Jean.
6
Okay. Do they have any adult children 7
who's still living in the county?
8
Yeah. They've got one adult child that
9
lives in Gadsden. Beth Hill.
10
Beth Hill?
11
Uh-huh (indicating yes).
12
Okay. In getting ready to come over
13 A.
today, did you speak with anyone other 14 Q.
than Mr. Myers?
15
No. It was too early.
16 A.
Well, even before today --1 mean, for 17
instance, in the last couple of weeks,
18 Q.
from the time you found out this would
19 A.
happen.
20 Q.
The only one I've talked to was Mr. Mike 21 A.
Kelly. And all he did was tell me the
22
date and time.
23
Page 12
anything that every answer you give me is going to be based on your own independent recollection of things. Okay?
Right. If when 1 ask you a question, though, it makes you remember that last year, you talked to So-and-so and he said such-and-such, that's great. I'd like to know that too. Just let me know that that's the source, okay, so we all know what's recollection and what's something coming from another direction. All right? Okay. Tell me, if you would, please, what education you have. I've got a college degree from Jacksonville State, major in accounting. And when did you obtain that degree? 1975. That would be a BS, 1 assume? Uh-huh (indicating yes).
MR. MYERS: You need to say yes or no and not uh-huh because it's
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HARTOLDMONO013937
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hard for her to take down.
1
Now, you strike me as a guy who's maybe
2 Q.
just a tad older than somebody who would
3
have gone straight from high school to
4
college and getting a degree in '75.
5
Right.
6 A.
Where did you graduate high school?
7 Q.
Anniston High School, 1957.
8
Okay.
9 A.
And, yes, sir, there was a delay.
10 Q.
I've got you. Did you have any other kind
11 A.
of college course work, other than the
12
work you did at JSU, to get your
13
accounting degree?
14 Q.
No. 1 went on the Gl Bill.
15 A.
Was that a - I'm guessing you were
16
probably working while you were going to
17 Q.
school?
18
Uh-huh (indicating yes).
19
So it might not have been a classical
20 A.
four-year effort, and you might have
21
needed more time than that to get the
22
degree?
23 Q.
Page 15
Lejeune in North Carolina. Let me take you through your work history
before Monsanto or after Monsanto, everything you did for gainful employment other than work at Monsanto. Okay.
And 1 presume that would have started when you got out of the Marines in '59?
Uh-huh (indicating yes). What was the first job you had when -The first job when 1 got out? 1 worked at a GE plant that's no longer here, but it was down in Oxford. Making vacuum tubes? Yeah. 1 worked in the resistor department. Just as a matter of routine, what sort of things did you do in the resistor department? 1 just --1 started out as a service operator. And whenever - I'd just pick up production every hour and -You weren't exposed to any kind of
1 A. 2 Q. 3 A. 4 5 Q. 6 7 8 A. 9 Q. 10 A. 11 Q. 12 A. 13 Q. 14 A. 15 Q. 16 17 18 A. 19 Q. 20 A. 21 Q. 22 A. 23
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1 think 1 did it pretty much --
1
In four years?
2 A.
It might have been like four and a half.
3 Q.
1 don't remember.
4 A.
Okay. Let me take you if 1 can, please,
5 Q.
through your -- you said Gl Bill, so I'm
6 A.
guessing you served in the military?
7 Q.
Yeah. 1 was in the Marines.
8 A.
When did you serve in the corps?
9 Q.
'57 to '59.
10
Straight out of high school?
11 A.
Uh-huh (indicating yes).
12 Q.
Yes?
13 A.
Yes, yes.
14
What did you do as a Marine? Aside from a 15 Q.
lot of running and grunting, what was your
16
official -
17 A.
1 was in the infantry.
18 Q.
Infantry?
19 A.
Uh-huh (indicating yes).
20 Q.
And where did you serve?
21
Well, 1 was at Paris Island, of course,
22 A.
for basic, and then, 1 went to Camp
23 Q.
Page 16
chemicals or anything, then, on the job? No. How long did that job last? It lasted probably about nine months. Okay. And then, 1 got hired at Monsanto. And was that the last job you ever -Uh-huh (indicating yes). Okay. That makes that easy. How's your health, Mr. Cambron? It's good. Ever had any surgeries? 1 had one surgery in my whole life, and
that was gallbladder. Ever been diagnosed with cancer of any
sort? No. Do you consume alcoholic beverages? No, sir. Do you smoke tobacco or use any kind of
tobacco product? No. Have you ever historically consumed
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alcohol or tobacco?
1
Yes, for a short period.
2
From '57 to '59, I'll bet?
3 Q.
Yes, and little bit afterwards.
4
Nothing wrong with that. I'm from
5
Kentucky, so we like people who consume
6 A.
both of those every once in a while.
7 Q.
1 don't agree with you on that, but that's
8
fine.
9
Well, 1 don't either, quite candidly. Do
10 A.
you presently work at Monsanto, or are you 11
retired?
12
I'm retired.
13 Q.
When did you retire?
14
December of '97.
15 A.
Do you still receive any sort of economic
16 Q.
benefits from Monsanto?
17
Well, yeah. 1 mean, you know -- well, 1
18 A.
took my retirement in a lump sum. And
19 Q.
it's not with them any longer, but they
20
provided it.
21 A.
Do you receive a subsidized health
22 Q.
insurance benefit?
23
Page 19
of thing, basically the same thing all the union presidents do.
In contrast to one of the fellows who was the vice president because the vice president said not much when -
Right. But the president, that's where the rubber meets the road. You were the contact man with management, right? Right. Well, me and the committee, but basically, the president done most of the And 1 assume you took that responsibility seriously? Oh, yeah. That was a position you were elected to by the rank and file? Uh-huh, yes. Not uh-huh, but yes. Did you hold any position in the national unit? No. Am 1 correct in understanding that the rank and file received a regular medical
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1 pay, you know --
1
You pay some of it, and they pay some o f 2 A.
it for the monthly premium?
3 Q.
Now?
4
Yes.
5 A.
1 don't know if they do or not. 1 know 1
6 Q.
do. 7
Were you ever a member of the
8 A.
International Chemical Workers' Local?
9
125. 1 was president.
10 Q.
You're the first guy who's had the numbe T1
right at the tip of his tongue, and being 12 A.
the president, that would figure. Okay. 13
When were you president?
14
A couple of years, '69 to '70, 1 think.
15
Did you hold any other positions when -- 16
1 was a securer for several years.
17 Q.
Okay. Tell me what your role was as
18 A.
president of the local. What sort of
19 Q.
things did you do?
20 A.
Well, you know, 1 kind of looked out for 21 Q.
the welfare of the hourly people. And
22
we'd have grievances and all of that sort 23
Page 20
examination? Yes, annually. And did you avail yourself of that? Did you have an annual physical out there? You didn't have a choice. Okay. Tell me what you remember being involved in that. How did 1 remember being involved in the physicals? What took place? What were the components of that medical examination? Oh. They would check your--it was a pretty complete physical. They'd do an x-ray every year of the lungs. They'd do a prostate exam. You know, regular stuff, blood work. Ask you questions? Blood pressure. Check your eyes, check your ears? Yeah, 1 had a hearing test every year. Was that much of a problem out there at that plant? You know, that was back when we had a lot of railroaders who had
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hearing problems from working on the railroad. 1 had a hearing problem, but 1 got it from the Marine Corps. 1 was a rifle range coach for a while, and my ears started ringing then.
And I'm sure they didn't give you hearing protection out on the range? Not then.
Yeah, right, not then. And you could put cotton in your ears, but they didn't have the -And this was every year that you were out at Monsanto? 1 mean, it was already in place when you started working in '60? The hearing test? Yeah, the whole -- the medical examination? Oh, yeah. And every year you were there, you had one? Every year for thirty-seven years. Okay. And 1 understand that was
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Well, they've hired a lot of new ones, so it's not as many as it used to be. But one of my good friends that 1 hang around with all the time works there.
Who would that be? Wayne Carden. Wayne Carten? C-a-r-d-e-n. Carden. Okay. And do you get the Bama Briefs? Yeah. Okay. I'm now ready to talk about what you actually did there for Monsanto. And 1 take it you started there in 1960 or thereabouts? March of '60. March of '60. What was the title of the first position you held there? The first job 1 started at was operator. And was that in a particular department of the plant? It was in the Aroclor department. And what did you do as an operator in the
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administered by the plant doctor and the
1
plant nurse?
2 A.
Right, yes. Is right okay?
3
Yes. Do you ever remember in thirty-seven 4 Q.
years them pointing something out to you
5
and saying, we found this out when we did
6
this, and you ought to know about it?
7
Just a hearing decrease.
8
The hearing?
9 A.
Yes. This sounds like --1 was over at
10
the VA a couple of weeks ago answering
11 Q.
some of the same questions trying to get
12
some hearing aids.
13
Okay. And 1 assume it never cost you
14
anything for this? This was paid for by
15 A.
Monsanto?
16 Q.
Absolutely.
17
Having just retired about four years ago,
18
I'm presuming you may still have friends
19 A.
and acquaintances who work at the
20
facility?
21 Q.
Yeah, I've still got a few out there.
22
Would it be a handful or dozens?
23 A.
Page 24
Aroclor department when you started there? We just made, you know, different types of Aroclor. It would be liquid or solid. 1 would assume that there were different places one could work, different tasks that you could be assigned, and that there wasn't one operator in the Aroclor department? Well, 1 started out as a chlorinator operator and moved on to still operator. Some fellows have discussed cross-training, where you tried to learn all of the different jobs in the department? You did. Yeah, 1 learned them all. Okay. Tell me about the waste streams that you would have, stuff coming off of that department that you know about. Well, as far as -- of course, you'd have drains on the bottom. Of the stills and the chlorinators, you mean? Well, just in the bottom floor of the
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HARTOLDMONO013940
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department.
1 A.
Oh, okay.
2 Q.
Just like it is everywhere else.
3
And if something got spilled, that would
4 A.
be washed into the drain?
5
Yeah. And it would go into a pit outside,
6 Q.
and then, it would be cleaned out
7
occasionally. And then, any overflow,
8 A.
basically clear stuff, would go to the
9 Q.
limestone pit.
10 A.
Right. The wastewater from that part of
11 Q.
the plant went to a limestone pit on the
12
east side of things?
13 A.
Right, the east side of the plant.
14 Q.
Okay.
15
And that filtered the rest of it out.
16 A.
Are you saying that you know that no PCB 17
was in that water as it left the plant
18 Q.
because of this pit that you've told us
19
about in the limestone, or that was your
20
assumption?
21 A.
1 didn't say that. 1 don't know.
22
That's what I'm trying to get at.
23
Page 27
Yeah. A couple of hundred degrees centigrade, depending upon what type you were making? I'm not sure about the temperature, but it It was hot, and you wouldn't want to touch it No. -- because it would burn you? Yeah. And that stuff would be to cool, obviously? Sure. And it's going to be emitting some vapor while it cools, correct? Yeah. They were kind of closed up with lids. They had a big lid on them. So you didn't need any ventilation anywhere because you never had any fume coming off of anything? It seems like we had a -- some ventilation fans. But I'm not -- that was forty-two years ago.
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Page 26
It was not supposed to be in it, you know,
1 Q.
because it was pretty well filtered.
2
There wasn't that much, you know, that
3
washed down that 1 thought.
4
And what other sort of waste stream might
5 A.
there be from this process of making
6
Aroclor?
7 Q.
That was it.
8
Was there cooling water used?
9
Yeah.
10
Any contact with that cooling water with
11
any sort of chlorinated biphenyl at any
12 A.
point in the process?
13 Q.
When you say "cooling water," you don't -- 14
do you mean, like we used cooling water to 15 A.
cool the stills?
16 Q.
Right.
17
That never did hardly come in contact.
18
That was just cooling. It didn't come in
19
contact with --
20
What about vapors? When the product came 21 A.
off of the still, 1 sense that it was
22 Q.
pretty hot?
23 A.
Page 28
What about the still bottoms? I've heard people tell me about still bottoms as a waste stream that came off the Aroclor department. Do you ever remember -When you say "waste stream," what are you talking about?
I'm pretty simple when it comes to these chemical plants. 1 like the black box approach, which is the black box on the paper, and you draw stuff going in and stuff coming out. Yeah, okay.
And we can talk about what you do inside the box, and I'm curious about that. Yeah.
But 1 also like the simplicity of what's going in and what's coming out. So 1 know, 1 think, what goes into the box of the Aroclor department. It's biphenyl from the biphenyl department?
Right. And chlorine from the chlorine department? Right.
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HARTOLDMONO013941
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Page 29
And some electricity and probably some
1
steam?
2 A.
Right.
3 Q.
And some cooling water?
4
Right.
5
And that's about it. Coming out of the
6
department, you've got some Aroclor?
7 A.
Right, which was pumped through tanks.
8 Q.
You've got some muriatic acid?
9
(Witness nods head affirmatively.)
10 A.
You've got some wastewater, which may or 11 Q.
not have had some PCB in it?
12
Right.
13
And you've got some --
14 A.
Bottoms.
15
-- fume and some bottoms?
16
Right.
17
Those are what 1 want to know about. If
18 Q.
there's more, I'd love for you to tell me.
19
You've pretty much got it.
20
So do you have any idea if there was
21 A.
anything done as far as controlling the
22 Q.
fume or trying to collect that fume, as
23
Page 31
kind of on the west side of things? Yes. And they say lake, but I'm sure people didn't take sailboats out there and go swimming. This is like a pond, looked like a farm pond? Yeah. But it was, you know, mostly solid. Just some water there to kind of cool it off? Yeah, when it rained. 1 mean, you could have just as easily laid it on the open ground. Why would you put it in the lake, if you know? 1 don't know. 1 know that they eventually dug it up and put it -- we had a melting pot over there. We would melt it up, and they made another product off of it. Again, what I'm trying to find out is: With these bottoms -- which would have had some chlorinated biphenyl in it, correct? 1 don't know. 1 assume. We're trying to figure out where that went. So some of it, you think, got
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Page 30
opposed to just venting it to the open
1
air? 2 A.
Well, like 1 say, we had some --
3
Hoods?
4
Down at the bottom of the still on some of
5
the -- some of the products, you'd have
6
what we call drawing bottoms, which just
7 Q.
opened a valve, and it had a rotating arm
8 A.
that would fill up a drum and seal it off
9
and let it cool for a few days. And then,
10 Q.
there was some -- it seems like 1 remember 11 A.
a fan in that hood that would take care of
12
those fumes.
13
Okay.
14
But I'm not sure about that.
15
Do you know what was done with those
16 Q.
bottoms?
17
1 know they were put out there to cool,
18
and they would harden. They'd be very
19
hard. And they either hauled them off, or
20 A.
they carried them to a place we call
21 Q.
Klegorn's (phonetic) Lake.
22
Now, 1 think 1 know where that is. That's
23
Page 32
drummed up and put into the landfills? It could have possibly gone to the
landfill. They might have shipped it to --1 can't think of the name of that other place in Alabama that they carried it.
Emelle? Yeah. I'm not sure about that, and that's the reason 1 can't answer it. All right. My memory is not as sharp as it used to be. But the one -- up at Klegorn's (phonetic) Lake, 1 mean, it would harden immediately. It wasn't like it was just out there bubbling and -And that's -- so you would take some of the bottoms over there. And again, that's located within the fence line of the plant on the west side of things? Right. And then --1 guess we've covered all of the waste streams that you know about. How long did you work as an operator in
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HARTOLDMONO013942
1 2 A. 3 Q. 4 5 A. 6 7 Q. 8 A. 9 10 11 12 Q. 13 A. 14 Q. 15 16 17 A. 18 Q. 19 20 A. 21 Q. 22 23 A.
Page 33
the Aroclor department?
1
About five years.
2 Q.
So at some point in 1965, 1 think you
3 A.
went --
4
1 went from operator to chief operator in 5 Q.
that department.
6
Okay. When did that happen?
7
I'm thinking '64 or '65 because 1 went to 8
maintenance right -- right along that
9
period. So I'd say --1 was probably
10 A.
chief a year.
11
And that would have been a promotion? 12
Yeah.
13 Q.
And still doing shift work, but you're the 14
top operator for the shift that you're
15
there?
16
Right.
17 A.
What's the -- and that was still in
18 Q.
Aroclor?
19
Uh-huh, yes.
20 A.
And what's the next position that you helc121
with Monsanto?
22
1 went to pipe fitter in the maintenance 23 Q.
Page 35
primary maintenance. Okay. And there was a lot of construction going
on. Were there many occasions where pipes or
valves or fittings would break, and you'd have to come repair those, as opposed to preventive maintenance where you did it before it broke? No. It might plug, or cold weather would cause it to crack, or a gasket would leak or something like that.
I'm assuming that if there was a rupture or some sort of a leak, that cleaning up whatever might spill from that was not part of the pipe fitter's Sometimes it was.
Sometimes it was. And did that happen sometimes when Well -
MR. MYERS: Let him finish his question first. Okay?
-- when Aroclor would leak or spill?
1 2 Q. 3 4 A. 5 Q. 6 A. 7 Q. 8 A. 9 Q. 10 11 12 A. 13 Q. 14 A. 15 Q. 16 17 A. 18 19 20 Q. 21 22 23 A.
Page 34
department.
1 A.
And this would have been sort of
2
plant-wide?
3
Uh-uh, yes.
4
And this was in 1965?
5 Q.
Yeah.
6
'66, somewhere along in there?
7 A.
Yes.
8
And what would have been the reason for
9
you to go from being a chief operator to
10
pipe fitter?
11
Increase in pay and day shift.
12
That's two good reasons.
13
Day shift probably.
14
Tell me what your duties were as a pipe
15
fitter.
16 Q.
Well, we just, you know, fabricated pipe
17 A.
and replaced pipe and cleaned out clogged 18 Q.
pipes and all of that stuff.
19
Was there a lot of new equipment going on 20
line, a lot of new construction, or was it
21 A.
more keeping what was already in place?
22 Q.
It was basically maintenance of the --
23
Page 36
We were plant-wide. 1 assume that --1 know in parathion or -- that's where the biggest plant was -- we did --1 worked mostly in that section of the plant.
All right. What's the next position that you held with the company?
1 did -- what they did back in --1 can't remember the year. But they shut down -cut back on the parathion, so it was cut back on maintenance. So 1 went - 1 volunteered to be a maintenance -- they call it a maintenance operator, really. But it was a good name for a laborer. But it would allow me to stay on day shift and start college and go to college.
Was that plant-wide that you would -Plant-wide. Okay. Now, you said that that enabled you to start college. So I'm guessing you must have done that roughly in '71? '70 or'71. 1 can't remember. So you were a pipe fitter for about five years?
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1 A. 2 Q. 3 4 A. 5 Q. 6 7 8 A. 9 10 Q. 11 A. 12 13 Q. 14 A. 15 16 Q. 17 A. 18 Q. 19 A. 20 Q. 21 22 23
Page 37
Somewhere in that neighborhood.
1
Okay. And what would you do as a
2
maintenance operator?
3 A.
Everything. We just--
4
Just kind of like a utility infielder on a
5
baseball team, wherever they needed a warm 6 Q.
body?
7
We'd cut grass. We'd clean the rest rooms 8 A.
and, you know, clean the building and -
9
Uh-huh (indicating yes). Let me --
10
-- clean up pipe and carry it to the
11
decontamination pit.
12
What was the decontamination pit?
13 Q.
That was where you carried things from
14
parathion.
15 A.
Okay.
16 Q.
And they had a big pit there that you'd --
17
That would neutralize the -
18
Neutralize it.
19
Okay. As a pipe fitter in the late '60s,
20
were you involved in putting together the
21 A.
equipment for the expansion of the Aroclor 22 Q.
department?
23 A.
Page 39
with Monsanto after you were a maintenance operator? Well, as soon as 1 got my degree, about a month after 1 got it, they promoted me to the night superintendent.
And that would be for the entire plant, 1 assume?
Uh-huh (indicating yes), on the off shifts and weekends. We'd just supervise. They had one person in the plant then that was the night superintendent. There was four of us.
And you were basically the top person there when you were there? Yeah.
Okay. Would one of your jobs as a superintendent be to just occasionally do a walk around the plant looking for signs of things that might not be being done right? Sure.
Would you do that every shift? That was part of the job.
1 A. 2 3 Q. 4 5 A. 6 7 Q. 8 9 10 11 12 A. 13 Q. 14 15 A. 16 Q. 17 18 A. 19 Q. 20 A. 21 22 23 Q.
Page 38
1 might have worked - 1 remember working
1 Q.
over there doing some piping.
2 A.
1 know you said you were primarily in
3 Q.
parathion.
4
Yeah. But we did some work over there
5
because 1 remember that --
6
It seems to me that one of the fellows
7 A.
yesterday said that the expansion involved
8 Q.
bigger chlorinators and a tank. Those are
9
the two things that stand out in my mind.
10 A.
Do you remember --
11 Q.
That was part of the expansion, yes.
12 A.
Do you have any recollection of working on 13 Q.
either of those projects?
14
Yeah.
15
He thought that was like maybe in 1969.
16 A.
Do you have any feel for -
17 Q.
1 cannot remember the dates.
18 A.
Okay.
19
It was --1 just can't remember the dates.
20
It would have to be along in there
21 Q.
somewhere.
22
Okay. What's the next job that you had
23 A.
Page 40
Okay. Every department, every aspect of it. And as an example, if you were doing a walk around, and you observed somebody without a hard hat on, what would you do about that? Tell them to put it on. And if they said they didn't feel like wearing a hard hat, what would you do? They felt like it. Very good. That was a requirement for the job. So if they didn't feel like it, they'd have to find something else to do for a living? Yes. And if You know, not one occasion. But they -but 1 never did have anybody question wearing a hard hat. People wanted to be safe; isn't that a fair statement, as a general proposition? Yes.
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Page 41
Now, what if you were doing a walk around, 1 Q.
and you found a puddle of chemicals
2
sitting on the ground, what would you do?
3
Well, you know, you contact the chief
4
operator in each department. Generally,
5
they take care of it themselves. You
6 A.
know, they're conscious about cleaning it
7 Q.
up. 8
But you would want to see to it that that
9 A.
was taken care of?
10 Q.
Oh, yeah, sure.
11
In a fairly quick order?
12 A.
Sure.
13 Q.
And if you were walking around, and you
14
smelled something that you weren't used to 15
smelling at the plant, what would you do
16 A.
about that?
17 Q.
We would inquire about it, you know, if it
18
was unusual.
19
And what would you do if somebody came to 20
the plant and told you that they lived
21 A.
nearby and they were smelling something or 22 Q.
seeing something that was unusual?
23
Page 43
And if you found something leaking, be it a barrel or a pipe or a tank or a pit, that would be something that you would expect to have addressed and have addressed in a timely fashion? Of course.
Now, 1 assume y'all had a laboratory there at the plant?
Uh-huh, yes. As the night superintendent or superintendent -- is that the right word? Night superintendent. -- night superintendent, 1 assume you had people working in the lab even on the night shift? Right. So that if something was going on -- if nothing else, just production, you had to have somebody there to check the products to make sure you were in specifications? Oh, yeah. And part of your bailiwick would be the lab, then, for those eight hours?
1 A. 2 Q. 3 4 5 A. 6 7 8 9 10 11 12 13 Q. 14 A. 15 16 17 18 19 20 21 22 23
Page 42
If they came to the plant?
1 A.
Yeah. If you got word somehow, someway 2 Q.
that there was something outside the fence
3
line --
4
Yeah. Okay. When we were night
5
superintendents, you know, occasionally,
6 A.
we would get what we call odor complaints
7 Q.
from the parathion. And we were told by
8
supervision to go where these people lived
9 A.
that they complained from and go every
10
time to where they lived and try to detect
11
odors.
12
To see what it was?
13
Yeah. And sometimes, people would be out 14
there and talk to you. But it was -- we'd
15
handle it, report it, and leave a memo.
16
We just -- if we ever smelled anything, a
17 Q.
lot of times, it just -- they were
18
smelling it, and we weren't. But it was
19
thoroughly investigated. And the next
20
day, our report would go to the
21
environmental people, and they would check 22 A.
it out.
23 Q.
Page 44
Right. Okay. Now, did you ever have occasion in doing your walk around to see a situation involving a release of something getting off of the plant site? 1 can't remember any. Okay. What's the next position that you held with the company? Well, they completely shut down parathion this time. And they cut out the night superintendents, so 1 went back -- my major was in accounting, and 1 went to the accounting department and did accounting there for --1 don't know. It was about a year, probably. And then, my final job was when they -- we had a full-time -Well, let me stop you here for a second. I'm assuming in '75 when you graduated and moved tonight superintendent, you ceased being a member of the union, and you became management? Right. Salary - when you went to the accounting
Pages 41 - 44
HARTOLDMONO013945
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Page 45
department, you were still a salary
1
employee, 1 assume?
2 A.
Yes.
3 Q.
Do you recall roughly when that happened? 4
'86. 5 A.
'86. And that was due to downsizing. And 6
what sort of things were you handling in
7
the accounting department? Did you have a 8
particular area that you worked?
9
Well, 1 did primarily some cost
10
accounting, and 1 was in charge of plant
11
utilities and allocating everything in
12
different departments.
13
And I've seen some paperwork that would 14
lead me to conclude that Monsanto was
15
pretty rigorous, to use a nice word, about
16 Q.
keeping track of how many pennies of
17 A.
electricity they spent to make a gallon of
18
Aroclor and how many pennies of lead they 19 Q.
used to make a batch of biphenyl and so on 20
and so forth. 1 mean, they knew all of
21 A.
these things that were flowing into the
22
box and all that was coming out?
23
Page 47
of particular products? Right. Okay. And then, you said you went to your last job, which was what? Well, like 1 was saying, 1 was in
accounting. 1 was still in the same area there, but we had an information technology guy that was -- you know, he was -- that was his major and all of that. And the plant got so small, and they transferred him to another plant. And instead of bringing in another one, they trained me to do that. And that's what 1 did until 1 retired. 1 was in charge of all of the computers in the plant.
And when did you start as the IT guy? I'd say somewhere around '87 or '88 until '97. Okay. Did you have any involvement as the IT staff person with archiving records? Well, we saved, you know, everything on our --1 think the computer in the main frame -- those that could, and a lot of
1 A. 2 3 4 Q. 5 6 7 8 9 A. 10 Q. 11 A. 12 Q. 13 14 15 A. 16 17 Q. 18 19 A. 20 Q. 21 22 23
Page 46
Most corporations do. Monsanto was --
1
they were vigorous there and in a lot of
2 Q.
other areas, like safety and housekeeping.
3
Safety and housekeeping. You, as a cost
4 A.
accountant, what you were doing is, for
5
instance, taking the electric bill and
6
figuring out where are we using this
7
electricity and --
8 Q.
Right.
9
-- putting it with the different products?
10
Yes.
11
And if 1 understood some testimony 1 got
12
earlier in the week, there were daily, if
13 A.
not hourly, meter readings recorded?
14 Q.
Yeah. That's where we got our information
15
from.
16 A.
And that's what you'd do? You'd take
17
those meter readings, and --
18 Q.
Right.
19
-- you'd know where that electricity had
20
gone? Because Monsanto was spending money 21
for that, and they wanted to know how to
22
account for it and put it towards the cost
23 A.
Page 48
paperwork was archived in boxes. Was it kept there at the plant
historically? Most of it was there, I'm pretty sure. And, of course, they kept some of it off-site in case of a fire, but 1 don't know where. Okay. Let me talk to you for a moment about the contact you may have had physically with Aroclor or PCB or Montars, all of which 1 understand are somewhat synonymous terms for the same stuff? Yeah. Tell me when you might have physically come into contact with that stuff. From '60 to '65, and maybe a little, you know, in pipe fitting. 1 don't know. And what's the -- if you had to sit here and describe to somebody how you would have come into contact with it as an operator, just describe for somebody how it would get on you. Well, you know, when you make Aroclor --
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HARTOLDMONO013946
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Page 49
well, I'm not going to get into how we
1
make it. You probably already know
2 A.
anyhow. But we take samples on a regular
3 Q.
basis to check to see when it finished.
4 A.
And it was to clean up and all of that,
5 Q.
empty buckets.
6
When you're drawing a sample, you're
7
taking it out the reactor vessel, right --
8
the still?
9
Yeah, the valve there, and you just pour
10 A.
it into a flask and --
11
But I'm assuming it's coming out at
12
temperature?
13
Right.
14 Q.
And you would not draw very many samples 15
and let it hit your skin before you
16 A.
learned not to let it hit your skin?
17 Q.
Well, it was hot, yeah.
18
1 mean, you weren't really getting it on
19
you when you did that?
20 A.
You weren't supposed to get it on you. 1
21 Q.
mean, you had on gloves and all.
22 A.
So even when you were an operator in the 23
Page 51
coveralls, basically? They provided everything. So you were basically covered head to toe? Right. And as a chief operator, if you were working in your Aroclor department, and somebody wasn't using the appropriate equipment, you would have said something to them, 1 presume? Right. That was one thing Monsanto was very big was on was safety and housekeeping. That was a big priority. They didn't tolerate it. They didn't want their workforce getting hurt? Getting hurt or any other -And you were -- you had facilities for you to wash up before you went home, and you changed back into your clothes? Oh, yeah. And you'd leave the dirty clothes there? Leave the clothes there, and they had free laundry, you know. And we had our own
1 2 3 4 A. 5 6 Q. 7 8 9 A. 10 11 12 Q. 13 A. 14 15 Q. 16 17 18 19 20 A. 21 22 23 Q.
Page 50
Arocolor department, you wouldn't have had 1
a lot of exposure to Aroclor; isn't that a
2
fair statement?
3 Q.
1 would say we had a fair amount of
4
exposure.
5
And that's what I'm trying to find out.
6 A.
And 1 don't understand how when you draw a 7 Q.
sample --
8 A.
Well, that wasn't the only thing you did.
9 Q.
You cleaned up, and you got empty buckets 10 A.
sometimes and --
11
Okay.
12 Q.
And then, on the stills, you'd have to
13
sample that and --
14 A.
Okay. Tell me about -- you mentioned a
15
second ago about having gloves on and
16
such. What sort of personal protective
17
equipment did you routinely use as an
18 Q.
Aroclor operator?
19 A.
We had on, of course, a hard hat, safety
20
glasses, safety shoes, gloves, sometimes
21
face shields.
22
And as 1 understand it, they provided
23 Q.
Page 52
bathhouse where we'd shower, and they furnished soap, showers.
Somebody was telling me that they thought there was even bottled water there at the plant at some point in time. That, 1 don't remember.
Don't remember? No. Okay. Bottled water wasn't even out there, as far as 1 know. Were you allowed to eat or smoke in the department around the Aroclor? We had our own, you know, little lunchroom or whatever you want to you call it. But 1 recall people smoking in the control room, yeah. Was there Aroclor in the control room? Basically, you just had your instrument. You would bring Aroclor in there to, you know, stir your samples and all of that in a sink. Okay. Tell me what kind of information
Pages 49 - 52
HARTOLDMONO013947
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Page 53
you were provided when you started there
1
as an operator in the Aroclor department
2
about the toxicity of this product you
3
were making.
4 A.
MR. MYERS: Object to the form. You
5 Q.
can answer. 1 just objected to
6
his question, but you can answer
7
his question.
8
Well, when you start to work at a chemical
9
plant, they make you aware of all of the,
10
you know, dangers and hazards.
11
1 understand. That's what I'm asking.
12
And if you would, tell me what you
13
understood they were with respect to
14
Aroclor.
15
Well, that was a long time ago, but, you
16
know, they told us about the hazards of
17 A.
it. 18 Q.
To pick a crazy example, I'm assuming they 19
didn't tell you that if you put your hand
20
in Aroclor, you'd wind up with eight
21
fingers?
22
No. They told us if you put your hand in
23
Page 55
document, and 1 want to ask you if you knew this when you started working with this stuff. Okay.
"Experimental work in animals shows that prolonged exposure to Aroclor vapors evolved at high temperatures or by repeated oral ingestion will lead to systemic toxic effects. Repeated bodily contact with the liquid Aroclors may lead to an acne-form skin eruption." Is that anything you knew back when you were working with it?
MR. MYERS: Object to the form. Tell him if you know, if you can answer it.
I've never seen that before. Okay. Now, it goes on to say in the next paragraph: "Suitable draft ventilation to control the vapors evolved at elevated temperatures, as well as protection by suitable garments from extensive bodily contact with the liquid Aroclors, should
1 2 3 4 Q. 5 6 7 8 9 10 11 A. 12 13 14 15 16 17 18 Q. 19 20 A. 21 22 23 Q.
Page 54
it, you'd get burned. But they didn't
1
have to tell you that because common sense 2
told you that.
3
Right. And that's what I'm trying to find
4 A.
out. What beyond common sense and what 5
beyond don't touch stuff that's hot, and
6 Q.
don't get something on you that you don't
7
have to get on you -- what beyond that
8
common sense level, if anything, were you
9
told about this specific chemical?
10
The fact that --1 think it was -- this
11
specific chemical, 1 don't remember, to be
12
truthful with you. 1 just know that they
13
made us all very aware of the dangers of a
14 Q.
chemical plant. You know, some products
15 A.
can explode, and some can burn you like
16 Q.
that.
17 A.
Did you have any reason to think that
18
Aroclor was explosive?
19 Q.
No. 1 knew it would burn. 1 knew
20
biphenyl would. And 1 knew benzene, of
21
course, was very flammable.
22
Let me read you something here from an old 23
Page 56
prevent any untoward effects." Now, you had that, correct?
MR. MYERS: Same objection. Right. We had long-sleeved clothing, yoi know, the whole works, and ventilation. Have you subsequently learned anything about the specific concerns that some people in the scientific community have about what PCBs can do to people?
MR. MYERS: Let me object to the form and ask: Subsequent to when he worked in the department or since his retirement?
Since you were in the department. When 1 was in the department of Aroclor? Yeah. Never heard it until recently, you know, when I've been reading all of this. Okay. If 1 asked you when -- have you ever heard -- let's start with something easy.
Have you ever heard allegations about PCBs causing problems for people
Pages 53 - 56
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Page 57
with their skin, other than what 1 just
1 A.
read to you? Before that, had you
2
heard --
3
No is the answer because 1 worked there
4 Q.
for thirty-seven years, and 1 never knew
5
of anybody out there having any problems
6
with their skin. And we were in contact
7
with it daily, around the clock.
8
So you had people working in it
9
twenty-four hours a day?
10 Q.
Well, they wouldn't work twenty-four.
11
They would get cleaned up and go home? 12
We worked seven twenty-fours is what we 13 A.
did. 14
But I'm saying: No individual worked
15
twenty-four seven?
16 Q.
No. 17
But they worked forty hours?
18
We had four groups that rotated around the 19
clock, seven days a week.
20 Q.
Yeah. Ever heard anything about that PCBs 21
cause problems with people's livers?
22 A.
MR. MYERS: Object to the form.
23 Q.
Page 59
I've never heard that, except what I've read in the recent years about the rats or whatever that was.
Okay. About rats. And you're convinced that it couldn't cause problems in people because you've never seen it in people out at the plant?
MR. MYERS: Object to the form. That's not what he said.
Well, then, you tell me: How is it that you know that it can't possibly cause these problems in people?
I've been basing it on my experience and the people 1 worked with for thirty-seven years.
Tell me what the drainage ditches looked like outside the plant where water would flow away from the facility.
MR. MYERS: At what point? At any point that you have personal knowledge. Clear. Clear? Okay. Any kind of life in the
1 2 A. 3 Q. 4 A. 5 6 7 8 Q. 9 A. 10 Q. 11 12 13 14 15 16 17 A. 18 19 20 21 Q. 22 23
Page 58
Tell him if you know.
1
No. I've not heard of anything that --
2 A.
As you sit here today --
3 Q.
You've named off all of that, but I've
4 A.
never heard of anything from anybody at 5
Monsanto in thirty-seven years being sick 6 Q.
over PCBs.
7 A.
That wasn't my question.
8 Q.
Okay. What was it?
9
My question was: Did anybody ever -- 10
you're sitting here today in 2002, and
11
you're saying you've never heard anything 12
suggesting that PCBs could cause liver 13 A.
problems in people?
14
MR. MYERS: He wants to know if
15
you've ever heard that.
16
I've never heard that. The only thing
17 Q.
I've heard is just what I've told you.
18
The rash, 1 read in the Anniston Star or 19
whatever.
20 A.
Okay. What about the fact that some
21 Q.
people think they cause cancer in people? 22 A.
MR. MYERS: Same objection.
23
Page 60
ditches? Any kind of what? Life. Minnows, frogs? 1 never did really look for fish or anything in there. Okay. I'm assuming they were there. Was it your perspective that when you would do walk arounds at the plant and look at these ditches that as long as they were running clear, there wasn't a problem? We also sampled them on a pretty regular basis when 1 was night superintendent to make sure that they were clean. The people from the lab would do that. What were the levels of PCB in the east ditch as it left the plant in 1975 when you were serving as night superintendent? 1 don't know. Do you know if it was sampled for? 1 know that the lab was sampling all of the ditches on a regular basis just for
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HARTOLDMONO013949
1 2 3 4 5 6 Q. 7 8 9 A. 10 Q. 11 12 13 A. 14 Q. 15 16 17 18 19 20 21 22 23
Page 61
environmental protection. But 1 didn't --
1
you know, 1 never did go to the lab and
2
say, well, what did you find out and what
3
was -- all of their information went to
4 Q.
someone else.
5
Have you ever heard of a professor named 6 A.
Denzel Ferguson from Mississippi State
7
University?
8
No. 9
Heard anything about the study that he was 10 Q.
hired by Monsanto to do of the waters
11 A.
coming off of the plant?
12 Q.
Sure didn't.
13
If you had been night superintendent and
14
received a report that the wastewater
15 A.
coming out of the plant killed fish within
16
a matter of minutes, that it was toxic to
17
fish, even in a thousand-to-one dilution,
18
that it posed a danger to children and
19
animals downstream, would you, as night
20
superintendent, have taken steps to clean
21 Q.
up that waste stream?
22 A.
MR. MYERS: Object to the form.
23
Page 63
and they'd take care of it immediately. If there was something that 1 could do, of course.
Let me ask you to tell me why you say Monsanto was keenly aware of these things? No. 1 didn't say that. 1 said Monsanto was on top of anything that -- any kind of release or exposure, and they took care of that in a professional manner.
And why do you say that? Because 1 saw it happen, you know. Tell me about it. 1 don't know it, and 1 need you to tell me. 1 literally don't know about that. 1 know one time when --1 think it was Santowax or biphenyl -- there was a line that ruptured. That's what it was. And it released some smoke into the air and across the highway, and they were on top of that just within minutes. When was that? It was harmless, but it -- oh, 1 don't know. It was in the late -- I'd say in
1 A. 2 3 Q. 4 5 6 7 8 9 10 11 12 13 14 A. 15 16 Q. 17 18 19 20 21 A. 22 23
Page 62
1 never did run into that. 1 wouldn't
1
have believed it.
2
All right. Again, what I'm asking you for
3
the sake of this question is to assume
4
that Monsanto -- not some plaintiff's
5
lawyer, but Monsanto hired a professor to
6
come in and test this wastewater, and he
7 Q.
reported back to Monsanto in writing that
8
it had these effects, and that came back
9 A.
to you as a night superintendent, would
10
you have felt some obligation to take some 11 Q.
action?
12
MR. MYERS: Object to the form.
13 A.
If it came directly to me from him; is
14 Q.
that what you're saying?
15 A.
No. If you were made aware of these
16 Q.
facts -- or would that just have been
17
something you couldn't have done anything 18
about?
19 A.
MR. MYERS: Object to the form.
20 Q.
Well, it would have been handled by
21
Monsanto, first of all, because they were
22
keenly aware of any situation like that,
23
Page 64
the '90s sometime. But that was one -the wind was blowing just right that it was going across the highway, and it kind of was -- it looked like white. And they just wanted to clean it up. Or if they had a --
Isn't it true -MR. MYERS: Let him finish.
Yeah. They would secure the area and have someone up there. And any --
I'm sorry. When -- they would secure what area when what happened? What we were just talking about.
Oh, with these -Yeah. Because that happened repeatedly, didn't it?
MR. MYERS: Object to the form. No, it didn't happen repeatedly. So if there's a memo in the record of this case talking about this fog drifting across 202 repeatedly where people can't even drive down 202, that document must
Pages 61 - 64
HARTOLDMONO013950
1 2 3 4 Q. 5 A. 6 7 8 9 Q. 10 11 A. 12 13 Q. 14 A. 15 16 17 18 19 20 21 Q. 22 23
Page 65
be -- a Monsanto document, by the way --
1
that document must be in error --
2
MR. MYERS: Object to the form.
3
-- because it only happened once?
4
1 didn't -
5
MR. MYERS: Hold on a second. You
6
don't have to accept what he says
7
as true.
8
And 1 told you that at the very beginning
9
of the deposition.
10
What I'm telling you is what 1 witnessed
11
the one time.
12
Okay.
13 Q.
You know, 1 don't think it happened on a
14 A.
regular basis. They were up there, and
15 Q.
any residue that was left, they'd clean it
16 A.
up. And they'd even put it in a drum and
17 Q.
secure it and handle it in the proper way.
18
Monsanto was always -- they looked out for 19 A.
the community and their employees.
20
And I'm asking you to tell me why somebody 21 Q.
should believe you when you say that. And 22
I'm not saying you're lying. 1 believe
23 Q.
Page 67
odor complaints or anything like that, to go out to where the complaint came from and check it out and report details on what -- if we detect any odor or if it was legit, to talk to the people, if they were there. And 1 think they felt responsibility, and they gave a lot to the communities around too, you know, as far as monetary, schools and everything. It's not like -- well, 1 guess, in your case, you think they're an irresponsible bunch, but 1 know better.
When did they clean up Snow Creek? When did they clean it up? Yeah. You're talking about for PCBs? Yeah.
MR. MYERS: Object to the form. It was in the late '90s, 1 guess. You're talking about recently, that cleanup? Just whatever you know about it.
MR. MYERS: If you know, tell him. If you know. Don't -- if you don't know,
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Q. 17 18 19 20 21 22 A. 23
Page 66
that you believe that. But 1 want you to
1
explain to me why a jury should believe
2 A.
that Monsanto looked out for the
3 Q.
community.
4
MR. MYERS: Wait a second. Let me
5
object to the form of the
6 A.
question. He's not required to
7
answer what a jury should or
8 Q.
should not believe. 1 object to
9 A.
the form of the question. And
10
he's told you because he observed
11
it. 12
MR. CUNNINGHAM: He hasn't told me 13
what he observed other than one
14
thing.
15 Q.
You've told me about one incident in the
16
'90s. I'm asking you, please, to tell me
17
what information you know of from personal 18
observation that leads you to conclude
19
that Monsanto cared about the community
20
and took care of it?
21 A.
Because, as 1 told you earlier, as a night
22
superintendent, we were told that with any
23
Page 68
that's fine. 1 don't know the exact date. When did they learn that Snow Creek was
contaminated? MR. MYERS: Object to the form.
See, you're talking about -- you need to talk to the higher-ups to find that out.
Okay. In the '90s, when 1 was working on computers, 1 had nothing to do with the plant outside, except, you know, going out and changing out computers and doing maintenance on them. You already know the answers, I'm sure, but 1 don't. I'm just trying to find out what you know. And the facts are, if I'm understanding correctly, that you really don't know when they learned that Snow Creek might be contaminated, and you don't know when they cleaned it up? 1 know approximately, and, you know, that's what 1 told you. That's pretty obvious if you get the paper and if you
Pages 65 - 68
HARTOLDMONO013951
1 2 3 Q. 4 5 6 7 8 Q. 9 10 11 A. 12 Q. 13 14 A. 15 Q. 16 A. 17 Q. 18 19 A. 20 Q. 21 22 23
Page 69
believe everything you read in the Star,
1 A.
but 1 don't. But that's another story.
2
Don't get me started on the Star. What
3
about Choccolocco Creek? Do you have any 4 Q.
personal information or knowledge about
5 A.
the condition of Choccolocco Creek?
6
MR. MYERS: When?
7 Q.
At any point in time, relative to PCB
8 A.
contamination.
9
MR. MYERS: Object to the form.
10 Q.
Just what 1 read in the paper.
11 A.
Have you ever gone fishing in Choccolocco 12
Creek?
13 Q.
No. 14 A.
Do you fish?
15
No. 16 Q.
Did you ever eat fish that were caught in
17
Choccolocco Creek?
18
1 don't think so. 1 don't know.
19
Do you know that there's a fishing
20 A.
advisory for Choccolocco Creek, that
21 Q.
people aren't supposed to eat fish they
22
catch there -- beneath Snow Creek, anyway, 23
Page 71
1 wouldn't have a clue. 1 went up there to visit the computer department at the plant.
What is your serum PCB level, Mr. Cambron? 1 don't know. They tested it out at the plant, and 1 think it was in the nineties. You don't remember what your reading was? 1 can't remember. It was on the high side, 1 think. Do you recall why your blood got tested? Well, they tested a lot of people, you know. It was voluntary, as 1 understand it? Yeah. In fact, 1 think Monsanto initiated it. It might have been Solutia then. Mr. Chattam --1 don't know if you know Mr. Chattam. 1 think he's one guy in particular who still works out there. He's a black gentleman. Chatman? Chatman. I'm sorry. You're right. He suggested that that had been done at the request of the union.
1 2 A. 3 Q. 4 A. 5 Q. 6 7 8 9 10 11 A. 12 Q. 13 14 15 16 A. 17 18 Q. 19 A. 20 Q. 21 22 23
Page 70
because of concerns about PCBs?
1 A.
(Witness shakes head negatively.)
2 Q.
Didn't know that?
3
No. 4 A.
Do you recall ever participating in a
5
study of worker mortality at the Anniston
6 Q.
plant, basically trying to look at people
7
who worked there and how many of them died 8 A.
versus how many of them were alive?
9 Q.
MR. MYERS: Object to the form.
10
1 don't ever recall that.
11 A.
Do you ever recall hearing about a study
12 Q.
like that done on Aroclor workers at the
13
Krummrich plant in Sauget, Illinois?
14 A.
MR. MYERS: Object to the form.
15 Q.
1 heard something about a study they did
16 A.
up there.
17
Did you ever visit the Krummrich plant?
18
Yeah.
19
If 1 wanted to talk to you about how they
20 Q.
made Aroclor versus how you did it down
21 A.
here in Anniston, how they handled their
22 Q.
waste streams, how the workers --
23 A.
Page 72
1 don't recall. Could be; might not be? You just don't know? Could have been and could not have been. 1 just don't know. By that point, you were kind of working with the computers, as you say? Yeah, at that point. And not getting out and about as much in the plant? Right. Now, you elected to have your blood tested, correct? 1 what? You chose to have them test your blood? Yeah. 1 think --1 can't remember if it was -- if you asked for it, or they just gave out a list saying you need to have it tested. Were you curious? Was 1 what? Were you curious to know? 1 never did really think about it that
Pages 69 - 72
HARTOLDMONO013952
1 2 Q. 3 4 5 A. 6 7 Q. 8 A. 9 Q. 10 11 12 A. 13 14 15 16 17 Q. 18 19 20 A. 21 22 Q. 23
Page 73
much. 1 guess 1 was. 1 don't remember. 1
What sort of follow-up took place? In
2
other words, after the blood got tested,
3
what happened then?
4
They just told us what it was, told us the 5
results. But 1 can't remember that.
6
Do you remember --
7
And then, they had a meeting.
8
I'm sorry. Before you go to the meeting, 9
you said "they" told you. Do you recall
10 Q.
who they is?
11
1 know it was some experts from --1 think 12
it was --1 don't know. 1 don't know
13
whether they were with the environmental 14
people or Monsanto. 1 keep wanting to 15
think it was Monsanto, but I'm not sure. 16
Fair enough. And then, you were getting 17
ready to tell me about a meeting, and 1
18
cut you off.
19 A.
Well, they just had a meeting to tell us 20
what it was all about it, and that was it. 21
1 have seen a -- basically, a typed
22
transcript of a question and answer
23
Page 75
treatment, and the southern plant didn't get any because we made the same thing that Krummrich did.
MR. CUNNINGHAM: We'll make this Exhibit One to his deposition. (Plaintiffs' Exhibit Number One was marked for identification and attached as an exhibit hereto.)
Were you ever given an explanation that you can remember that was satisfactory to you as to why they tested the folks up north but not at the southern plant?
MR. MYERS: Object to the form. They did test them at the southern plant.
MR. CUNNINGHAM: He's talking about back in the '70s.
Yeah. That's the only thing that bothered me, was the difference between how they treated St. Louis and then Anniston. It wasn't the fact that 1 was concerned about --
1 2 3 4 5 6 A. 7 Q. 8 9 10 11 12 13 A. 14 Q. 15 A. 16 Q. 17 18 19 A. 20 21 22 23
Page 74
session. And I've highlighted on here
1 Q.
some that say "Cambron." It looks like
2
some of the questions are being asked by
3 A.
Cambron. And I'm going to ask you to take
4 Q.
a moment and read this and see if that --
5
Just read what 1 asked?
6
Well, the whole thing, if you want. 1
7
don't care. You might read the whole
8
thing and see if it helps you remember the
9
meeting - if that's the meeting you're
10
talking about.
11
And how old are you, Mr. Cambron?
12
Sixty-two, nearly sixty-three.
13
Okay.
14
Yeah, that was the --
15
Okay. And according to this, you asked
16 A.
the question: "Why is Monsanto just now
17
making these studies?"
18 Q.
Well, my primary concern was the -- it
19
wasn't why were they just now, but why
20
they had tested up north and not where
21 A.
everybody had made it. 1 was kind of
22 Q.
wondering why they got preferential
23 A.
Page 76
When they started? If you're going to start, start it at both places, basically?
Right. Yeah. Now, when they drew that blood, they had everybody fill out a questionnaire. And I've been trying to figure out -- they haven't told us who those folks are to protect your privacy. It's just by an ID number. And I'm going to try to figure out, based on your age and how many years you worked there, which one of these might be you.
In 1996, when these samples were drawn - in June of 1996, how old would you have been?
In '96, 1 would have been about fifty-seven.
Okay. Let's go through a few here and see if we can find yours. See if that might be you (indicating). Well, it sounds like me.
Okay. That's number ten ten? Let's see here. That's not my writing,
Pages 73 - 76
HARTOLDMONO013953
1 2 Q. 3 4 5 6 A. 7 8 9 10 11 12 13 14 15 16 17 Q. 18 19 20 21 22 A. 23 Q.
Page 77
but somebody else might have done it.
1
Well, let me take a -- what about the
2 A.
height and the weight? Is that what you
3
think of yourself as being height and
4 Q.
weight wise?
5
Well, that's about -- that's my height.
6
My weight --1 always think 1 weighed
7 A.
about a hundred and sixty, but 1 know it's
8
not that.
9
MR. MYERS: All of these are in the
10
same hand, aren't they?
11 Q.
MR. CUNNINGHAM: A lot of them are. 12
That's why 1 think --
13
THE WITNESS: They might have just
14 A.
asked the questions and written
15 Q.
it themselves.
16 A.
If you are number ten ten, the blood
17
result that 1 have been provided for ten
18 Q.
ten is sixty-six ppb. Now, you had
19
indicated you recalled it being on the
20
high side?
21
1 remember it being a six something.
22 A.
So this is probably you, then.
23 Q.
Page 79
about a guy with liver abnormalities? 1 remember the meeting, but 1 don't remember the -The meeting, in the sense that there was a meeting to talk about the fact that
someone had come down with liver problems? No. 1 didn't hear the liver. 1 heard -1 heard somebody - 1 don't remember -
said they had some kind of rash, but it didn't last.
Another guy said he carried melted PCB to the dump. Do you recall who was doing that kind of work?
No. Probably the I'm sorry. What was the answer? No was the answer, but -- no, 1 don't know who. Okay. Lab work doing air samples. Do you have a specific recollection of an individual who was working in the lab on air samples? On air samples? Uh-huh (indicating yes).
1 2 3 4 5 6 7 8 9 10 11 12 13 14 A. 15 Q. 16 17 18 19 A. 20 21 Q. 22 23
Page 78
Now, there were some comments on
1 A.
some of these questionnaires. And 1 don't
2
know if you can help me figure out who
3 Q.
some of these people are or not, but I'm
4
going to run these comments by you, and
5
see if that rings a bell as to who did
6 A.
that or had that. Okay? One of them
7 Q.
mentioned that he has chloracne
8
frequently. 1 just know it's number one
9 A.
oh oh six, but he put on his comment that
10 Q.
he has chloracne frequently. Do you
11
recall who at the plant had chloracne
12
frequently?
13
No. 14 Q.
There's another fellow who put down a rash 15
on arms and hands. Do you recall any of
16 A.
the fellows out there having rashes on
17
their arms and hands?
18 Q.
1 really didn't -- you know, 1 didn't keep
19 A.
up with anybody's illnesses.
20
Another fellow said he had an abnormal
21 Q.
liver test five years ago, and that would
22 A.
have been 1991. Do you remember anything 23 Q.
Page 80
It could have been many of them. 1 don't know.
Okay. Did you ever have any involvement with operating any of the incinerators there at the plant? Just as night superintendent.
Would have fallen into your bailiwick, so to speak? Yes.
Do you know what went into the parathion incinerator?
MR. MYERS: Working as the night superintendent?
I'm assuming you don't know about it any other Well, actually, it was when 1 was in maintenance.
As a pipe fitter? When 1 got to be night superintendent, they cut that out. They had gone to the recycle? Recycle, that's right. That's right; that's right.
Pages 77 - 80
HARTOLDMONO013954
1 A. 2 3 Q. 4 5 6 7 A. 8 Q. 9 10 11 12 A. 13 14 Q. 15 16 17 18 19 20 A. 21 Q. 22 A. 23 Q.
Page 81
In maintenance, 1 changed out, you know, burners to it and everything.
My sense is, although 1 don't know that I've got this nailed down yet from anybody, that bottoms from one of the parathion processes -Yeah, sulfur. And what about the tepee up on the landfill? Was that around at any point when you had occasion to be up there and see it? 1 saw it, but 1 was never involved in that.
Okay. Were you at all involved with when they stopped selling Aroclor and making it, for that matter -- in the early '70s, Monsanto had a program in place to take back scrap from the customers and incinerate that in Sauget?
No. You don't know anything about that? 1 don't know nothing about that. We've seen some documents that suggest
1 A. 2 3 4 5 Q. 6 7 8 A. 9 10 Q. 11 A. 12 13 Q. 14 15 A. 16 17 Q. 18 19 20 21 A. 22 23
Page 83
It was just a huge area there that had -it was just like a typical landfill, you know. It had - we'd carry -- we'd pick up, you know, paper and wood.
Would you take those kinds of things to the tepee to burn them, or would you burn them in the pit?
No. We'd just carry them up there, and they'd cover them up with bulldozers.
Who's "they"? It was a contracting firm. 1 can't remember who it was. Okay. All right. And was it one big pit or various pits or -Various areas. You know, they'd cover up one, and they'd go to the next. So they had one operating face at any one time where you would dump stuff until that got full, and then, they'd start somewhere else? Right. As soon as we'd dump it, of course, they'd come in there and cover it up.
1 2 3 4 5 6 A. 7 Q. 8 9 10 11 A. 12 Q. 13 14 A. 15 16 17 Q. 18 19 A. 20 Q. 21 22 A. 23 Q.
Page 82
that Anniston was like a collection point
1 Q.
for some of that. When you were night
2
superintendent in '75, do you ever
3 A.
remember stuff coming back to the plant
4 Q.
that y'all had stored for a while for --
5 A.
Not on --1 didn't notice it.
6 Q.
If 1 wanted to talk about the condition of
7
the dump or the landfill south of the
8
plant across 202, were you ever up there
9
to see it to know what it looked like?
10 A.
Yeah.
11
Tell me when you would have had occasion 12
to be up there.
13 Q.
1 went up there as a maintenance operator, 14
laborer. Sometimes we carried trash up
15
there, you know.
16
And that would have been in the time frame 17
of '70-71?
18 A.
Somewhere in that neighborhood.
19 Q.
Okay. Tell me what it looked like when
20
you were up there.
21
What it looked like?
22
Yes.
23
Page 84
Okay. What about ponded water? Did you ever see ponded water up there? You mean, water laying in the pits?
Yes, sir. Rainwater and -Water of any kind. 1 mean, 1 don't know how you'd tell what's rainwater and what's not. But if you can, let me know where it came from? We didn't pump water up there or anything. But I'm assuming when it rained, there was water in there. And 1 think that's a logical assumption. I'm just wondering, since you were actually up there and saw it, do you have a recollection as you sit here today of seeing ponded water in the pit? No recollection of it. Okay. When you were an operator and chief operator in the Aroclor department, did you ever have a batch that just couldn't fit within the specifications, and you just couldn't get it right?
Pages 81 - 84
HARTOLDMONO013955
1 A. 2 Q. 3 4 5 6 A. 7 Q. 8 9 10 11 A. 12 Q. 13 14 15 16 A. 17 18 19 20 21 Q. 22 23 A.
Page 85
1 can't remember any.
1
You mentioned before about the testing
2 A.
that took place for the wastewater
3 Q.
streams, and you said that happened daily,
4
as 1 recall?
5
Yeah, by the lab.
6
What role, if any, did you have in picking
7
up samples, be it of water, soil, fish,
8 A.
air, other than the product itself, is
9 Q.
what I'm looking for?
10
Did 1 pick up samples?
11 A.
Right. Did you have any role in either
12 Q.
collecting the samples, analyzing the
13 A.
samples, supervising people doing either
14
of those things?
15 Q.
Well, on night shift, we was in charge of
16
everybody at the plant. But the lab
17 A.
was - you know, they were kind of a
18 Q.
different breed of cat, and they did their
19 A.
job. 20 Q.
As we sit here, I'm presuming from what
21 A.
you -
22
1 didn't go over there and say -- you
23 Q.
Page 87
plant? Yeah, north. North and west. Now, there's been some discussion about a separate lab that was set up for a while to do PCB testing, and that was sent back --1 think the person thought to St. Louis at some point? I'm not aware of that. Okay. Were you ever provided results of those tests? No. Okay. You know, they went to the lab supervisor and then to the environmental people. Who was the environmental person while you were night superintendent? What is that guy's name? If 1 said Jerry Brown, would -Childers. Childers? Jerry Brown and Bob Childers. This is just night superintendent, right? Right. When's the first time you remember
1 2 Q. 3 4 5 6 A. 7 Q. 8 A. 9 10 Q. 11 A. 12 13 Q. 14 15 A. 16 Q. 17 18 A. 19 Q. 20 A. 21 22 23 Q.
Page 86
know, because 1 didn't really know, so --
1
And that's what I'm getting at. You
2
didn't know what samples they were
3 A.
collecting and wouldn't know how to make
4
sure they'd done it or not?
5
Well, 1 saw them doing it.
6 Q.
What did you see them do?
7
Collecting samples from where the water
8 A.
was exiting the plant.
9
Did they go down by the fence line?
10
They'd sample the fence line, outside the
11 Q.
fence line, and inside the fence.
12 A.
And this would have been the wastewater 13
stream?
14
Yeah.
15
Okay. And when you say "they," again, 1
16 Q.
have to ask you to --
17
Lab.
18
Lab people?
19
Lab people. Now, our waste treatment
20
operator was also -- also would catch some 21
samples along those lines.
22 A.
Okay. Out of the ditch going north of the
23 Q.
Page 88
there being an environmental person at the plant? With that title, 1 don't know exactly when. But there was always somebody involved in it.
Who do you think in the '60s, then, was involved in it? 1 know Red Taffee was at one time. The old memory ain't what it used to be. Of course, Jerry Brown, and Robert Jones now.
My question -There were some people that worked there when 1 first went there that 1 didn't know as much because 1 was new too. And 1 wasn't involved with them. One last set of questions, and 1 can let you be a free man.
Have you heard in reading the Star or talking to people that PCBs have allegedly been found in a number of residential properties around the plant?
I've read it. Okay. Have you heard that it has been
Pages 85 - 88
HARTOLDMONO013956
1 2 3 A. 4 5 Q. 6 A. 7 8 9 Q. 10 11 12 13 A. 14 Q. 15 16 17 A. 18 19 Q. 20 21 22 23
Page 89
alleged that a number of people around the
1
plant have found the PCBs in their blood?
2 A.
1 read that, although 1 don't believe it
3 Q.
was very high.
4 A.
Okay.
5
1 mean, I've just read --1 bet if you
6 Q.
compared theirs with mine, thiers would be
7
minuscule.
8 A.
Would it surprise you to learn that I've
9 Q.
got clients with readings much higher than
10 A.
yours?
11 Q.
MR. MYERS: Object to the form.
12
It would surprise me very much.
13
Did it surprise you when you heard that
14
people were claiming to have found PCBs in 15
these yards around the plant?
16
Yeah. Did it surprise me when the people 17
found them or --
18 Q.
Well, let me put it this way: Have you
19 A.
heard that Monsanto found it when they
20 Q.
went out and sampled and that the EPA
21
found it when they went out and sampled
22
it? 23 A.
Page 91
Answer his question. Did it surprise me? Uh-huh (indicating yes). 1 just didn't really believe that there was that much release of any PCBs. Have you heard about the EPA Superfund people coming to town? 1 read that in the paper. Did that surprise you? What's the Superfund? Well, that -- it's a particular department within the EPA designed to come and deal with the worst abandoned waste sites in the country.
MR. MYERS: Object to the form, if that's a question. 1 don't know that it is.
You don't know what Superfund is? No. Again, my question is fairly simple. When you heard about them coming to town, did it surprise you or not? 1 just --1 don't know. 1 just read about
1 2 A. 3 4 5 6 Q. 7 8 A. 9 10 11 Q. 12 13 14 A. 15 Q. 16 17 18 19 A. 20 21 Q. 22 23
Page 90
MR. MYERS: Object to the form.
1
All 1 read was what was in the paper. The
2
more 1 read, the more 1 knew it was all
3 Q.
about people out in the community wanting
4
to get money.
5
So you don't believe it, and you don't
6
think it's out there?
7
1 don't know. 1 mean, the paper said it,
8
and 1 assume that there's got to be
9 A.
something there.
10
Well, my question is even a little bit
11
simpler as to whether -- not so much do
12
you believe it, but were you surprised?
13
Yes.
14
That's -- okay. And you didn't even --
15
you haven't until today heard about the
16
fish advisory, if 1 understood your
17
earlier testimony?
18
1 think 1 -- you know, 1 read about it in
19
the paper.
20
Did that surprise you when you heard that 21
the fish down there were contaminated?
22
MR. MYERS: Object to the form.
23
Page 92
all of this in the paper and just thought it was overblown.
Well, that's my last question. Is it fair for me to say that as to all of these things, your perspective on it is that you're not concerned, and you think it's all overblown?
MR. MYERS: Object to the form. 1 do.
MR. CUNNINGHAM: Okay. That's all 1 have.
(AND FURTHER DEPONENT SAITH NOT.)
Pages 89 - 92
HARTOLDMONO013957
Page 93
1 1 do hereby certify that the witness whose 2 attached deposition was taken before me was by me 3 first duly cautioned and sworn to tell nothing but 4 the truth in the cause aforesaid; that the 5 testimony contained herein was by me reduced to 6 writing in the presence of said witnesses by means 7 of stenography and afterwards transcribed by means 8 of computer aided transcription. The foregoing is 9 a true and accurate transcript of the whole of the 10 testimony given by said witness, as aforesaid. 11 Ido further certify that 1 am not 12 connected by blood or marriage with any of the 13 parties or their attorneys or agents and that 14 lam not an employee of any of them, nor 15 interested in the matter of controversy. 16 IN WITNESS WHEREOF, 1 have hereunto 17 set my hand and affixed my notarial seal at 18 Gadsden, Alabama, County of Etowah, this 12th 19 day of January, 2002. 20 21 22 Misty Perry Sanders
Notary Public, Alabama-at-Large 23 My Commission Expires: 11-01-2003
Page 93
HARTOLDMONO013958
[& - answer]
&
& 1:1 2:7_______________
1
1000 1:1
11-01-2003 93:23
125 18:10
12th 93:18
1355 2:8
1957 13:8
1960 23:14
1965 33:3 34:5
1969 38:16
1975 12:1960:18
1991 78:23
1996 76:13,14_____________
2
2001-832 1:1
2002 1:1 3:7 4:2 58:11 93:19
202 64:22,23 82:9
22nd 7:14
230 7:4
2912 8:4__________________
3
3 2:12
30309 2:8
35901-0755 1:1
36207 7:4__________________
4
4 2:16 4:2
Transcript Word Index
40207-1294 2:5
4th 1:1 3:7______________
5
57 14:10 17:3
59 14:10 15:8 17:3
6
60 21:1523:16,1748:16
6010 2:4
60s 37:20 88:6
64 33:8
65 33:8 48:16
66 34:7
69 18:15_______________
7
70 18:15 36:21 82:18
70s 75:1881:16
71 36:20,21 82:18
75 2:20 13:5 44:18 82:3
750 2:8
755 1:1_________________
8
86 45:5,6
87 47:17
88 47:17_______________
9
9:00 1:1 3:8
90s 64:1 66:17 67:19 68:9
93 2:12
96 76:16
97 agree
17:1547:18______________ 17:8
a agreed
a.m. 1:1 3:8
abandoned
3:2,9,15,22 ahead
9:8
91:13
aided
abernathy 1:1 4:19
abnormal 78:21
abnormalities
93:8 aids
22:13 ain't
88:9
79:1 absolutely
air 30:2 63:18 79:18,21,22
22:17
85:9
accept
al
65:7 account
1:1,1 4:19,20 alabama
46:23 accountant
1:1,1,1,1 3:6,7 4:1 32:5 93:18,22
46:5 accounting
12:17 13:1444:12,13,13,23 45:8,11 47:6 accurate
alcohol 17:1
alcoholic 16:18
alive
93:9 70:9
acid 29:9
acne 55:11
acquaintances
allegations 56:22
alleged 89:1
allegedly
22:20
88:20
action 1:1 62:12
addressed 43:4,5
administered
alien 7:16,18
allocating 45:12
allow
22:1 adult
36:14 allowed
9:14 10:7,9 advisory
69:21 90:17
52:12 amount
50:4
affirmatively 29:10
analyzing 85:13
affixed
animals
93:17 aforesaid
93:4,10 age
76:10
55:5 61:20 anniston
1:1 3:7 4:1 7:4,6 8:2,3 13:8 58:19 70:6,22 75:21 82:1 annual
agents
20:4
93:13 ago
5:4 22:11,18 27:23 50:16 53:16 78:22
annually 20:2
answer 6:1,5 12:1 32:9 53:6,7 55:16 57:4 66:8 73:23
HARTOLDMONO013959
[answer - burn]
answer (cont.)
assign
basis
bodily
79:15,1691:1
3:19
49:4 60:14,23 65:15
55:9,22
answering
assigned
batch
body
22:11
24:6
45:20 84:21
37:7
answers
assume
bathhouse
bothered
6:10 68:14
4:23 6:18 8:13 11:22 12:20 52:1
75:19
anybody
19:13 22:14 24:4 31:21
beginning
bottled
11:23 40:19 57:6 58:5,10
36:1 39:7 43:7,13 45:2 62:4 65:9
52:4,10
81:5
90:9
believe
bottom
anybody's
assuming
5:6 65:22,23 66:1,2,9 69:1 24:20,23 30:5
78:20
35:13 44:18 49:12 53:19
89:3 90:6,13 91:4
bottoms
anyway
60:7 80:14 84:11
believed
28:1,2 29:15,16 30:7,17
69:23
assumption
62:2
31:1932:1781:5
approach
25:21 84:13
bell
boulevard
28:9 atlanta 78:6 2:4
appropriate
2:8
beneath
box
51:7 attached 69:23
28:8,9,14,18 45:23
approximately
2:23 75:8 93:2
benefit
boxes
68:21
attorney
17:23
48:1
archived
2:4
benefits
break
48:1
attorneys
17:17
35:6
archiving
93:13
benzene
breed
47:20
avail
54:21
85:19
area
20:3 bet
briefs
7:20 9:18 45:9 47:6 64:9,12 avenue
17:3 89:6
23:10
83:1
1:1 8:1
beth
brindley
areas
aware
10:10,11
7:22
46:3 83:15
53:10 54:14 62:16,23 63:5 better
bring
arm
87:8
67:12
52:20
30:8 b
arms 78:16,18
aroclor 23:22 24:1,3,7 26:7 28:3,19 29:7 33:1,19 35:23 37:22
back 20:22 5119 81:18
bad
36:7,9,10 44:11 55 12 62 8 9 75 82:4 87:6
18
45:19 48:10,23 50:2,19
5:23 6:12 7:15
51:6 52:13,18,20 53:2,15 53:21 54:19 55:6 56:15 70:13,21 81:15 84:20 aroclors 55:10,23
bailiwick 43 22 807
bama 23:9
barrel
arocolor
432
50:1 arounds
barry Q-11
60:9 arthur
5:14 aside
14:15 asked
56:19 72:17 74:3,6,16 77:15 asking 53:12 62:3 65:21 66:17 aspect 40:2
baseball 37:6
based 12 2 76 10
basic 14:23
basically 9:20 19:1,11 25:9 34:23 3913 511 3 52 19 70 7 73:22 76:2
basing 59:13
beverages
bringing
16:18
47:12
beyond
broke
54:5,6,8
35:9
big brooks
27:1737:1751:11,12 83:13 9:7
bigger
brother
38:9 10:4
biggest
brown
36:3 87:18,21 88:10
bill brownsboro
7:1 13:15 14:6 46:6
2:4
biphenyl
bs
26:12 28:19,20 31:20 45:20 12:20
54:21 63:16
bubbling
bit 32:15
17:4 90:11
buckets
black
49:6 50:10
28:8,9 71:19
building
blood
37:9
9:1520:16,18 71:1072:12 bulldozers
72:15 73:3 76:4 77:17 89:2 83:9
93:12
bunch
blowing
67:11
64:2
burn
bob 27:9 54:16,20 83:6,6
87:21
HARTOLDMONO013960
[burned - connected]
burned 54:1
burners 81:2
burst 6:6
c
calhoun 1:1 4:21
call 30:7,21 36:12 42:7 52:15
called
11:14 cambron
1:1,1 2:153:54:4 7:1,3 16:10 71:4 74:2,4,12 camp 14:23 cancer 16:15 58:22 candidly 17:10 carden 23:6,9 care 30:12 41:6,10 63:1,8 66:21 74:8 cared 66:20 Carolina 15:1 carried 30:21 32:5 37:14 79:11 82:15 carroll 8:20 carry 37:11 83:3,8 carten 23:7 case 5:8,129:21 11:1348:6 64:21 67:10 cat 85:19 catch 69:23 86:21 caught 69:17 cause 35:11 57:22 58:13,22 59:5 59:11 93:4 causing 56:23 cautioned 93:3
ceased 44:19
centigrade 27:2
certificate 2:12
certify 93:1,11
chance 6:9
changed 51:1981:1
changing 68:12
charge 45:11 47:14 85:16
Charles 2:3 10:4
Charlie 4:15
chatman 71:20,21
chattam 71:16,17
check 20:12,19,19 42:22 43:19 49:4 67:3
checked 8:21 9:12
chemical 18:9 28:8 53:9 54:10,12,15
chemicals 16:1 41:2
chief 33:5,11 34:1041:451:5 84:19
child 10:9
Childers 87:19,20,21
children 9:2 10:7 61:19
chloracne 78:8,11,12
chlorinated 26:12 31:20
chlorinator 24:9
chlorinators 24:21 38:9
chlorine 28:22,22
choccolocco 69:4,6,12,18,21
choice 20:5
chose
coming (cont.)
72:15
29:6 45:23 49:12 61:12,16
circuit
82:4 91:7,21
1:1,1
commencing
city 1:1 3:8
4:1 comment
civil 78:10
1:1 comments
claiming
78:1,5
89:15
commission
classical
93:23
13:20
commissioner
clean
1:1 3:6,23
37:8,9,11 49:5 60:15 61:21 committee
64:5 65:16 67:13,14
19:10
cleaned
common
25:7 34:18 50:10 57:12
54:2,5,9
68:20
communities
cleaning
67:8
35:1441:7
community
cleanup
56:8 65:20 66:4,20 90:4
67:20
company
clear
1:1 36:6 44:8
25:9 59:22,23 60:11
compared
clients
6:17 89:7
89:10
complained
clock
42:10
57:8,20
complaint
clogged
67:2
34:18
complaints
close
42:7 67:1
8:11 complete
closed
6:5,1020:13
27:16
completely
clothes
44:9
51:19,21,22
compliance
clothing
3:12
56:4 components
clue
20:10
71:1 computer
coach
47:22 71:2 93:8
21:5
computers
cold
47:15 68:10,12 72:7
5:7 35:10
concern
coldwater
74:19
7:20 concerned
collect
75:22 92:6
29:23
concerns
collecting
56:7 70:1
85:13 86:4,8
conclude
collection
45:15 66:19
82:1 condition
college
69:6 82:7
12:16 13:5,12 36:15,15,19 connected
coming
93:12
12:12 24:17 27:20 28:11,17
HARTOLDMONO013961
[conscious - drifting]
conscious 41:7
consolidated 1:1
construction 34:21 35:3
consume 16:18 17:6
consumed 16:23
contact 19:8 26:11,18,20 41:4 48:9 48:15,20 55:10,23 57:7
contained 93:5
contaminated 68:4,19 90:22
contamination 69:9
contracting 83:11
contrast 19:3
control 52:16,18 55:20
controlling 29:22
controversy 93:15
convinced 59:4
cool 26:1627:11 30:10,1831:8
cooling 26:9,11,14,15,19 29:4
cools 27:15
corporations 46:1
corps 14:9 21:4
correct 19:22 27:15 31:20 56:2 72:13
correctly 68:17
cost 22:14 45:10 46:4,23
cotton 21:11
counsel 3:4,17,18
country 91:14
county 1:1,1 4:21 9:16,17,18,22
county (cont.)
deal
10:8 93:18
91:12
couple
debby
10:18 18:1522:11 27:2
9:5
course
december
13:12 14:22 24:19 43:6
17:15
48:5 50:20 54:22 63:3
decontamination
83:22 88:10
37:12,13
court
decrease
1:1,1 3:134:8
22:8
cover
defendants
83:9,15,22
1:1 2:6
coveralls
degree
51:1 12:16,18 13:5,14,23 39:3
covered
degrees
32:21 51:3
27:2
crack
delaware
35:11
5:6,6
crazy
delay
53:19
13:10
creek
denzel
67:13 68:3,18 69:4,6,13,18 61:7
69:21,23
department
cross
15:16,19 23:20,22 24:1,8
24:12
24:14,18 25:1 28:4,19,20
Cunningham
28:22 29:7 33:1,6 34:1
2:3,164:10,14,1566:13
37:23 40:2 41:5 44:13 45:1
75:4,17 77:12 92:10
45:8 50:1 51:6 52:13 53:2
curious
56:12,14,15 71:2 84:20
11:17 28:14 72:20,22
91:11
customers
departments
81:18
45:13
cut depending
6:7 36:9,9 37:8 44:10 73:19 27:3
80:20
deponent
cv 92:13
1:1 deposed
d 5:2,11
daily
deposition
46:13 57:8 85:4 dale
1:1,1 3:4,10,11,20 65:10 75:5 93:2
7:17,18 danger
61:19 dangers
5311 5414
depositions 3:145:17 11:3
describe 48:19,21
designed
date
91:12
10 23 68 2 dates
details 67:3
38:18,20 day
34:12,14
36:14
42:21
57:10
detect 42:11 67:4
diagnosed
9319
16:15
days 9:6 30:10 57:20
died 7:16 70:8
difference 75:20
different 24:2,4,5,13 45:13 46:10 85:19
dilution 61:18
direction 12:12
directly 62:14
dirty 51:21
discussed 24:11
discussion 87:3
ditch 60:18 86:23
ditches 59:16 60:1,10,23
doctor 22:1
document 55:1 64:23 65:1,2
documents 11:2 81:23
doing 6:4 33:14 38:2 40:3 41:1 44:3 46:5 68:12 79:12,18 85:14 86:6
downsizing 45:6
downstream 61:20
dozens 22:23
draft 55:19
drain 25:5
drainage 59:16
drains 24:20
draw 28:10 49:15 50:7
drawing 30:7 49:7
drawn 76:14
drew 76:4
drifting 64:21
HARTOLDMONO013962
[drill - finished]
drill
emelle
exhibit
5:19 32:7 2:20 75:5,6,9
drive
emitting
exhibits
64:23
27:14
2:22,23
drum
employee
exiting
30:9 65:17
45:2 93:14
86:9
drummed
employees
expansion
32:1
65:20
37:22 38:8,12
due
employment
expect
45:6 15:4 43:4
dug
empty
experience
31:15
49:6 50:10
59:13
duly
enabled
experimental
4:5 93:3
36:18
55:5
dump
encountered
experts
79:12 82:8 83:18,21
5:22
73:12
duties
entire
expires
34:15
39:6
93:23
e environmental explain
earlier 11:3 46:13 66:22 90:18
early 10:1681:16
ears 20:1921:5,11
easily 31:11
east 25:13,1460:17
easy 6:22 16:9 56:21
eat 52:12 69:17,22
economic 17:16
education
8:8 42:22 61:1 73:14 87:14 66:2
87:15 88:1
explanation
epa 75:10
89:21 91:6,12
explode
equipment
54:16
34:20 37:22 50:18 51:8 explosive
error
54:19
65:2 exposed
eruption
15:23
55:11
exposure
esq 8:8,9 50:2,5 55:6 63:8
2:3,7
extensive
et 55:22
1:1,1 4:19,20
eyes
etowah
20:19_________________
1:1 9:15,17,18,22 93:18 eventually
f fabricated
12:15 effect
3:12 effects
55:9 56:1 62:9 effort
31:14 everybody
74:22 76:5 85:17 evidence
3:21 evolved
34:17 face
50:22 83:17 facilities
51:17 facility
13:21 eight
55:7,20 exact
22:21 59:18 fact
43:23 53:21 either
68:2 exactly
54:11 58:21 71:14 75:22 79:5
17:10 elected
30:20
38:14
85:12,14
88:3 exam
19:16 72:12 electric
20:15 examination
46:6 electricity
4:1320:1,11 21:18 examined
facts 62:17 68:16
factual 4:17
fair 40:22 50:3,4 73:17 92:3
29:1 45:18 46:8,20 elevated
4:6 example
fairly 41:1291:20
55:20
40:3 53:19
fallen
80:7
familiar 7:5
fan 30:12
fans 27:22
far 24:19 29:22 52:11 67:8
farm 31:6
fashion 43:5
feel 38:17 40:8,13
fellow 78:15,21
fellows 19:3 24:11 38:7 78:17
felt 40:10 62:11 67:6
fence 32:1842:3 86:10,11,12,12
ferguson 61:7
field 1:1
fifty 76:17
figure 18:13 31:22 76:7,10 78:3
figuring 46:7
file 19:17,23
filed 4:20
filing 3:23
fill 30:9 76:5
filtered 25:16 26:2
final 44:15
find 4:17 31:18 40:14 50:6 54:4 61:3 68:7,15 76:19
fine 17:9 68:1
fingers 53:22
finish 35:21 64:8
finished 6:2 49:4
HARTOLDMONO013963
[fire - hearing]
fire form (cont.)
6:7 48:6
68:5 69:10 70:10,15 75:14
firm 89:12 90:1,23 91:15 92:8
83:11
forth
first
1:1 45:21
4:5 5:22 15:10,11 18:11 forty
23:18,19 35:22 62:22 87:23 27:22 57:18
88:13 93:3
found
fish 10:19 11:1622:641:2 43:1
60:4 61:16,18 69:15,17,22 88:20 89:2,15,18,20,22
85:8 90:17,22
four
fishing
13:21 14:2,3 22:18 39:11
69:12,20
57:10,11,16,19
fit fours
84:22
57:13
fite frame
1:1 47:23 82:17
fite's
free
5:14 51:22 88:17
fitter
frequently
33:23 34:11,16 36:22 37:20 78:9,11,13
80:18
friends
fitter's
22:19 23:3
35:16
frogs
fitting
60:3
48:17
full
fittings
3:12 6:23 44:16 83:19
35:6 fume
five 27:19 29:16,23,23
4:22 33:2 36:22 78:22
fumes
flammable
30:13
54:22
furnished
flask
52:2
49:11
further
floor
92:13 93:11
24:23 flow
59:18 flowing
45:22 fog
64:21 folks
4:22 10:2 75:12 76:8 follow
73:2 follows
4:6 force
3:12 foregoing
93:8 form
3:18 53:5 55:11,14 56:11 57:23 59:8 61:23 62:13,20 64:18 65:3 66:6,10 67:18
g
gadsden 1:1 9:18 10:1093:18
gainful 15:4
gallbladder 16:14
gallon 45:18
garments 55:22
gasket 35:11
ge 15:12
general 40:22
generally 41:5
gentleman 71:19
georgia 2:8
getting 10:13 13:5 44:4 49:19 51:14,16 72:9 73:17 86:2
g> 13:15 14:6
give 6:1,10 12:1 21:7
given 75:10 93:10
giving 6:5
glasses 50:21
gloves 49:22 50:16,21
go 6:3 7:2 8:6 9:8 25:6,9 31:4 34:10 36:15 42:9,10,21 57:12 61:2 67:2 73:9 76:18 83:16 85:23 86:10
goes 28:18 55:18
going 5:2,20 11:22 12:2 13:17 27:14 28:10,17 34:20 35:3 43:17 49:1 64:3 68:11 74:4 76:1,9 78:5 86:23
golden 7:7,8
good 16:11 23:3 34:13 36:13 40:11
graduate 13:7
graduated 44:18
grass 37:8
great 12:8
grievances 18:23
ground 31:1241:3
grounds 3:19
groups 57:19
grunting 14:16
guess 11:20 32:21 67:10,19 73:1
guessing 13:16 14:7 36:19
guy 13:2 18:11 47:8,16 71:17 79:1,11
guy's 87:17____________________
h
habit 5:23 6:12
half 14:3
hand 53:20,23 77:11 93:17
handful 22:23
handle 42:16 65:18
handled 62:21 70:22
handling 45:7
hands 78:16,18
hang 23:3
happen 10:20 33:7 35:18 63:11 64:19
happened 45:4 64:12,16 65:4,14 73:4 85:4
hard 13:1 30:20 40:5,9,20 50:20
harden 30:19 32:13
harmless 63:22
hat 40:5,9,20 50:20
hauled 30:20
hazards 53:11,17
head 29:10 51:3 70:2
health 16:10 17:22
hear 79:7
heard 28:1 56:17,20,22 57:3,21 58:2,5,12,16,17,18 59:1 61:6,10 70:16 79:7,8 88:18 88:23 89:14,20 90:16,21 91:6,21
hearing 20:20 21:1,3,7,16 22:8,9,13
HARTOLDMONO013964
[hearing - krummrich]
hearing (cont.) 70:12
height 77:3,4,6
held 23:18 33:21 36:6 44:8
helms 2:7
help 4:18 78:3
helps 74:9
hereto 2:23 75:9
hereunto 93:16
high 13:4,7,8 14:11 55:7 71:8 77:21 89:4
higher 68:7 89:10
highlighted 74:1
highway 63:19 64:3
hill 10:10,11
hired 16:6 23:1 61:11 62:6
historically 16:23 48:3
history 15:2
hit 49:16,17
hold 18:16 19:1965:6
home 51:1857:12
hood 30:12
hoods 30:4
hot 26:23 27:6 49:18 54:6
hour 15:22
hourly 18:22 46:14
hours 43:23 57:10,18
house 7:14
housekeeping 46:3,4 51:12
how's
inquire
k
16:9
41:18
keenly
huge
inside
62:23 63:5
83:1
28:13 86:12
keep
huh
inspiration
73:15 78:19
8:16,23 9:19 10:12 11:5
6:6
12:21,23 13:19 14:12,20 instance
keeping 34:22 45:17
15:9 16:8 19:18,18 33:20
10:18 46:6
37:10 39:8 43:9 79:23 91:3 instrument
kelly 10:22
hundred
52:19
kentucky
4:22 27:2 77:8
insurance
2:5 17:6
hurt
5:8 17:23
kept
51:15,16
interested
48:2,5
93:15
killed
idea 11:12,1529:21
identification
international 18:9
investigated
61:16 kind
13:11 15:23 16:20 18:21
2:22 75:8 illinois
42:20 involved
27:16 31:1,8 37:5 52:23 59:23 60:2 63:7 64:3 72:6
70:14 illnesses
78:20
20:7,8 37:21 38:8 81:12,14 74:22 79:9,13 84:6 85:18
88:5,7,15
kinds
involvement
83:5
immediately 32:14 63:1
47:19 80:3 involving
klegorn's 30:22 32:12
incident 66:16
incinerate 81:19
incinerator
44:4 irresponsible
67:11 island
14:22
knew 45:21 54:20,20,21 55:2,12 57:5 90:3
know 4:235:13,13,196:8,14,17
80:11
____________ J__________
6:18,18 7:8 11:19 12:9,9,10
incinerators
Jacksonville
17:18 18:1,6,6,21 20:15,22
80:4
12:17
22:7 24:2,18 25:17,22 26:1
increase
january
26:3 28:18 29:18 30:16,18
34:12
1:1 3:7 4:2 93:19
30:23 31:7,13,14,14,21
independent
jean
32:22 34:17 36:2 37:9 38:3
12:2 10:6 40:18 41:4,7,18 42:6 44:14
indicated
jerry
46:20,22 47:8,21 48:7,17
77:20
87:18,21 88:10
48:17,23 49:2 51:23 52:11
indicating
job
52:14,21 53:11,17 54:13,15
5:18 8:16,23 9:19 10:12
15:10,11 16:1,3,7 23:19
55:15 56:5,17 58:1,15
11:5 12:21 13:19 14:12,20 38:23 39:23 40:12 44:15
59:11 60:20,21,22 61:2
15:9 16:8 37:10 39:8 76:20 47:4 85:20
63:11,12,14,15,23 65:14
79:23 91:3
jobs
66:18 67:8,12,21,22,23,23
individual
24:13 39:16
68:2,11,13,15,17,19,21,21
57:15 79:20
jones
69:19,20 70:3 71:5,12,16
infantry
88:10
71:16 72:3,5,22 73:12,13
14:18,19
jr
73:13 77:8 78:3,9,19 79:16
infielder
9:9,9
80:2,10,14 81:1,3,21,22
37:5 jsu
82:10,16 83:3,4,15 84:6,8
information
13:13
85:18 86:1,1,3,4 87:13 88:3
46:15 47:7 52:23 61:4
june
88:8,13 90:8,19 91:16,18
66:18 69:5
76:14
91:23
ingestion
jurors
knowledge
55:8 9:20 4:17 59:21 69:5
initiated
jury
krummrich
71:14
9:22 66:2,8
70:14,18 75:3
HARTOLDMONO013965
[lab - mississippi]
I
lab 43:14,23 60:16,22 61:2 79:18,20 85:6,17 86:18,19 86:20 87:4,13
laboratory 43:7
laborer 36:13 82:15
laid 31:11
lake 30:22 31:3,13 32:13
landfill 32:3 81:9 82:8 83:2
landfills 32:1
large 3:7 93:22
larry 2:7
lasted 16:4
late 37:20 63:23 67:19
laundry 51:23
law 1:1 2:4
laws 3:13
lawsuit 4:19
lawyer 62:6
laying 84:3
lead 45:15,19 55:8,10
leading 3:18
leads 66:19
leak 35:11,14,23
leaking 43:1
learn 24:12 68:3 89:9
learned 24:15 49:17 56:6 68:18
leave 42:16 51:21,22
left 25:18 60:18 65:16
legit 67:5
lejeune 15:1
level 8:21 54:9 71:4
levels 9:1260:17
lid 27:17
lids 27:17
life 16:13 59:23 60:3
limestone 25:10,12,20
line 32:18 34:21 42:4 63:16 86:10,11,12
lines 86:22
liquid 24:3 55:10,23
list 9:14,23,23 10:1 11:17 72:18
literally 63:13
little 17:4 48:16 52:14 90:11
live 7:3 9:15
lived 7:9,11,168:10,1541:21 42:9,11
liver 58:13 78:22 79:1,6,7
livers 57:22
lives 10:4,10
living 10:8 40:15
lie
1:1 local
18:9,19 located
32:18 logical
84:13 long
7:9 9:23 16:3 32:23 53:16 56:4 60:10 longer 15:12 17:20
look marked
60:4,10 70:7
2:19,22 75:7
looked
marriage
11:1,23 18:21 31:5 59:16
9:15 93:12
64:4 65:19 66:3 82:10,20 married
82:22
8:13
looking
matter
39:18 85:10
15:1761:1781:1693:15
looks
mean
74:2 10:17 17:1821:1424:22
lot 26:1531:11 32:1345:21
14:16 20:23 23:1 34:20,21 49:19,22 84:3,6 89:6 90:8
35:3 42:18 46:2 47:23 50:2 means
67:7 71:11 77:12
93:6,7
louis
medical
75:21 87:7
19:23 20:11 21:17
louisville
meeting
2:5 73:8,9,18,20 74:10,10 79:2
love 79:4,5
29:19
meets
lump
19:8
17:19
melt
lunchroom
31:16
52:14
melted
lungs
79:11
20:14
melting
lying
31:15
65:23
member
m 18:8 44:20
ma'am
memo
4:10,11 maiden
8:19 main
47:22 maintenance
42:16 64:20 memory
32:11 88:9 mentioned
50:15 78:8 85:2 meter
33:9,23 34:23 35:1,8 36:10 36:11,12 37:3 39:1 68:13 80:17 81:1 82:14 major 12:17 44:12 47:9 making
46:14,18 mike
10:21 military
14:7 miller
15:14 26:6 27:3 53:4 74:18 81:15 man 19:8 88:17
1:1 mind
38:10 mine
management 19:9 44:21
manner 63:9
march 23:16,17
marine 14:1521:4
5:23 6:12 89:7 minnows
60:3 minuscule
89:8 minutes
61:17 63:20 mississippi
marines
61:7
14:8 15:8
HARTOLDMONO013966
[misty - paperwork]
misty
ne
objected
okay (cont.)
1:1 3:5 93:22
2:8
53:6 82:20 83:13 84:1,19 86:16
moment
nearby
objection
86:23 87:9,12 88:23 89:5
48:8 74:5
41:22
56:3 58:23
90:15 92:10
monetary
nearly
objections
old
67:9
74:13
3:16,19
54:23 74:12 76:14 88:9
money
necessary
obligation
older
46:21 90:5
3:16
62:11
13:3
monsanto
need
observation
once
1:1 4:20,23 11:14,20 15:3,3 12:22 27:18 63:13 68:6
66:19
5:11 17:7 65:4
15:5 16:6 17:11,17 21:14
72:18
observed
ones
22:16 23:13 33:22 39:1
needed
40:4 66:11,14
23:1
45:15 46:1,21 51:10 58:6
13:22 37:6
obtain
open
61:11 62:5,6,8,22 63:5,6 negatively
12:18
30:1 31:12
65:1,19 66:3,20 71:14
70:2
obvious
opened
73:15,16 74:17 81:17 89:20 neighborhood
68:23
30:8
montars
37:1 82:19
obviously
operating
48:10
neutralize
27:12
80:4 83:17
month
37:18,19
occasion
operator
39:4 new
40:18 44:2 81:10 82:12
15:21 23:19,23 24:7,10,10
monthly
23:1 34:20,21 88:14
occasionally
32:23 33:5,5,15 34:10
18:3 nice
25:8 39:17 42:6
36:12 37:3 39:2 41:5 48:21
months
45:16
occasions
49:23 50:19 51:5 53:2
16:4 night
35:5 82:14 84:19,20 86:21
moore
39:5,11 42:5 43:10,12,13 occupational
opposed
2:7 43:1544:1060:14,1961:14 8:9 8:9 30:1 35:7
mortality
61:20 62:10 66:22 80:6,12 odor
oral
70:6
80:19 82:2 85:16 87:16,22 42:7 67:1,4
55:8
move
nine
odors
order
7:15
16:4
42:12
41:12
moved
nineties
offered
ought
7:13 24:10 44:19
71:6
2:19,23 3:21
22:7
mulliss
nods
office
outside
2:7
29:10
5:14
25:6 42:3 59:17 68:11
muriatic
north
offices
86:11
29:9
8:5 15:1 74:21 75:13 86:23 1:1
overblown
myers
87:2,2
official
92:2,7
2:7 4:11 5:15 10:15 12:22 notarial
14:17
overflow
35:21 53:5 55:14 56:3,10
93:17
oh
25:8
57:23 58:15,23 59:8,19 notary
19:1520:1221:1925:2 owens
61:23 62:13,20 64:8,18
3:6 93:22
41:11 43:21 51:20 63:22
5:12
65:3,6 66:5 67:18,22 68:5 notice
64:14 78:10,10
oxford
69:7,10 70:10,15 75:14
3:22 82:6
okay
15:13
77:10 80:12 89:12 90:1,23 number
91:15 92:8
1:1 18:11 75:6 76:9,22
nailed 81:4
name
n
77:17 78:9 88:20 89:1 nurse
22:2
o
4:156:23 8:17,199:6 11:16 object
32:4 36:13 87:17
53:5 55:14 56:10 57:23
named
59:8 61:23 62:13,20 64:18
58:4 61:6
65:3 66:6,9 67:18 68:5
national
69:10 70:10,15 75:14 89:12
19:19
90:1,23 91:15 92:8
6:11,20,21 7:3,21,23 9:8,10
P
10:5,7,13 13:9 14:5
11:12 12:3,10,13 15:6 16:5,9 18:13
page 2:11,15
18:18 20:6 21:23 22:3,14 paid
23:9,12 24:16 25:2,15 28:12 30:14 33:7 35:2,22
22:15 panel
36:18 39:16 47:19
37:2,16,20 38:19,23 40:1 42:5 44:2,7 47:3 48:8 50:12,15 52:9
9:22 paper
28:10
68:23
69:11
83:4
52:23 55:4,18 56:19 58:9 58:21 59:4,23 60:6 65:13
90:2,8,20 91:8 92:1 paperwork
68:8 74:14,16 76:18,22
45:14 48:1
78:7 79:18 80:3 81:14
HARTOLDMONO013967
[paragraph - properties]
paragraph
personal
please (cont.)
prevent
55:19
50:17 59:20 66:18 69:5
66:17
56:1
parathion
perspective
plug
prevented
36:2,9 37:15 38:4 42:8 44:9 60:8 92:5
35:10
6:4
80:10 81:6
phonetic
point
preventive
parents
30:22 32:13
11:8 26:13 33:3 52:5 59:19 35:8
7:14 phrase
59:20 69:8 72:6,8 81:9 82:1 primarily
paris
6:13 87:7 38:3 45:10
14:22
physical
pointing
primary
park
20:4,13
22:5
35:1 74:19
2:4
physically
pond
prior
part
48:10,14
31:5,6
3:21
5:7 7:6,18 8:3,5 25:11
physicals
ponded
priority
35:16 38:12 39:23 43:22
20:9
84:1,2,17
51:12
participating
pick
posed
privacy
70:5
15:21 53:19 83:3 85:11
61:19
76:8
particular
picking
position
probably
23:20 45:9 47:1 71:18
85:7
19:16,19 23:18 33:21 36:5 5:8,11 13:17 16:4 29:1
91:11
pipe
44:7
33:10 34:14 44:15 49:2
particularly
33:23 34:11,15,17,18 35:16 positions
77:23 79:14
8:11
36:22 37:11,20 43:2 48:17 18:16
problem
parties
80:18
possibly
20:21 21:3 60:12
3:3 4:18 93:13
pipes
32:2 59:11
problems
pay
34:19 35:5
pot
21:1 56:23 57:6,22 58:14
18:1,2,2 34:12
piping
31:16
59:5,12 79:6
pcb
38:2
potential
process
8:21 9:12 25:17 29:12
pit
9:20 26:6,13
48:10 60:17 69:8 71:4
25:6,10,12,19 37:12,13,17 pour
processes
79:11 87:5
43:2 83:7,13 84:17
49:10
81:6
pcbs
pits
ppb
product
8:8 56:9,23 57:21 58:7,13 83:14 84:3
77:19
16:21 26:21 31:17 53:3
67:16 70:1 88:19 89:2,15 place
preferential
85:9
91:5
20:10 21:15 30:21 32:5
74:23
production
peachtree
34:22 73:2 81:17 85:3
premium
15:22 43:18
2:8 places
18:3 products
pennies
24:5 76:2
preparation
30:6 43:19 46:10 47:1
45:17,19
plaintiffs
11:4
54:15
people
1:1,1 2:2,19 75:6
presence
professional
17:6 18:22 28:2 31:3 40:21 plaintiff's
93:6
63:9
42:9,14,22 43:14 52:16
62:5
presently
professor
56:8,9,23 57:9 58:14,22,22 plant
17:11
61:6 62:6
59:5,6,12,14 60:16 64:22
8:11 15:12 20:22 22:1,2 president
program
67:5 69:22 70:7 71:11
23:21 25:12,14,18 32:18
18:10,13,14,19 19:4,5,7,11 81:17
73:15 78:4 85:14 86:19,20 34:3 36:1,3,4,16,17 39:6,10 presidents
projects
87:14 88:12,19 89:1,15,17 39:18 41:16,21 42:1 43:8
19:2
38:14
90:4 91:7
44:5 45:11 47:10,11,15 pressure
prolonged
people's
48:2 52:5 53:10 54:15 59:7 20:18
55:6
57:22
59:1760:9,1861:12,16 presume
promoted
period
68:11 70:7,14,18 71:3,6
15:7 51:9
39:4
17:2 33:10
72:10 75:1,13,16 78:12 presuming
promotion
perry
80:5 82:4,9 85:17 86:9 87:1 22:19 85:21
33:12
1:1 3:5 93:22
88:2,21 89:2,16
pretty
proper
person
plants
14:1 20:13 26:2,23 28:7
65:18
39:10,13 47:20 87:6,15
28:8
29:20 45:16 48:4 60:13 properties
88:1 please
68:22
88:21
6:23 7:10 9:4 12:14 14:5
HARTOLDMONO013968
[proposition - rooms]
proposition
rainwater
red
residential
40:22
84:5,7
88:8
88:21
prostate
range
reduced
residue
20:15
21:4,8
93:5
65:16
protect
rank
regional
resistor
76:8
19:17,23
1:1
15:15,18
protection
rash
regular
respect
21:8 55:21 61:1
58:19 78:15 79:9
19:23 20:15 49:3 60:13,23 53:14
protective
rashes
65:15
respective
50:17
78:17
relating
3:3
provided
rats
3:14 responsibility
17:21 50:23 51:2 53:1
59:2,4
relative
19:1367:7
77:18 87:9
ray
69:8
rest
public
20:14
relatives
25:16 37:8
3:6 93:22
reactor
9:14 result
puddle
49:8 release
77:18
41:2 read
44:4 63:8 91:5
results
pump
11:10 54:23 57:2 58:19 released
73:6 87:9
84:10
59:2 69:1,11 74:5,6,8 88:22 63:18
retire
pumped
89:3,6 90:2,3,19 91:8,23 remember
17:14
29:8 reading
5:7 11:7 12:6 14:4 20:6,8 retired
pursuant
3:10 11:7 56:1871:7 88:18 22:4 28:4 30:11 36:8,21
17:12,1322:1847:14
1:1
readings
38:1,6,11,18,20 44:6 52:6,7 retirement
put
46:14,18 89:10
54:12 71:7,8 72:16 73:1,6,7 17:1956:13
21:11 30:18 31:12,15 32:1 ready
74:9 75:11 77:22 78:23 reviewed
40:7 46:23 53:20,23 65:17 10:1323:1273:18
79:2,3,8 82:4 83:12 85:1
11:1
78:10,15 89:19
really
87:23
rifle
putting
6:15 7:1 36:12 49:19 60:4 repair
21:4
37:21 46:10
68:17 72:23 78:19 86:1
35:7
right
q 91:4
question 6:1,3,7,13 12:5 35:22 40:19 53:7,8 58:8,10 62:4 66:7,10 73:23 74:17 88:11 90:11 91:1,16,20 92:3
reason 8:6 32:9
reasons 34:13
recall
34:9
54:18
questionnaire
45:4 52:16 70:5,11,12
76:6 questionnaires
78:2 questions
3:17,184:16 11:22 20:17
71:10 72:1 73:10 78:12,16 79:12 85:5 recalled 77:20 receive
22:12 74:3 77:15 88:16 quick
41 12 quinta rd
1:1 quite
17:16,22 received
19:23 61:15 recollection
12:3,11 38:13 79:19 84:16 84:18
17:10
record 64:20
r recorded
repeated 55:8,9
repeatedly 64:16,19,22
replaced 34:18
report 42:16,21 61:15 67:3
reported 62:8
reporter 4:8
reporter's 2:12
reporting 1:1
represent 4:21
request 71:23
required
6:22 12:4,12 13:6 18:12 19:6,9,1021:1022:3,3 25:11,14 26:17 28:21,23 29:3,5,8,13,17 32:10,20 33:9,9,17 36:5 39:20 43:11 43:16 44:1,22 46:9,19 47:2 49:8,14 51:4,10 54:4 56:4 62:3 64:2 71:21 72:11 76:3 80:22,23,23 83:13,21 84:23 85:12 87:22,23 rigorous 45:16 ringing 21:6 rings 78:6 road 7:4,5,17,18,22 19:8 robert 88:10 role
railroad
46:14
66:7
18:18 85:7,12
21:2
records
requirement
room
railroaders
47:20
40:12
52:17,18
20:23
recycle
reside
rooms
rained
80:21,22
7:12
37:8
31:1084:11
HARTOLDMONO013969
[rotated - sound]
rotated 57:19
rotating 30:8
roughly 36:20 45:4
routine 15:17
routinely 50:18
rubber 19:7
rules 3:13
run 62:1 78:5
running 14:1660:11
rupture 35:13
ruptured 63:17
s
sabrina
1:1 safe
40:21 safety
46:3,4 50:20,21 51:11 sailboats
31:4 saith
92:13 sake
62:4 saks
7:22 salary
44:23 45:1 sample
49:7 50:8,14 86:11 sampled
60:13,21 89:21,22 samples
49:3,15 52:21 76:13 79:18 79:21,22 85:8,11,13,14 86:3,8,22 sampling 60:22 sanders 1:1 3:5 93:22 santowax 63:16 satisfactory 75:11
sauget
set
site
70:1481:19
1:1 87:4 88:16 93:17
44:5 48:6
saved
seven
sites
47:21
21:22 22:4 57:5,13,16,20
91:13
saw
58:6 59:14 76:17
sitting
63:11 81:12 84:15 86:6 shakes
41:3 58:11
saying
70:2 situation
5:10 22:6 25:17 47:5 57:15 shamrock
44:3 62:23
58:12 62:15 65:23 72:18
7:4,5
six
says
sharp
77:19,22 78:10
65:7
32:11
sixty
school
shields
74:13,13 77:8,19
13:4,7,8,18 14:11
50:22
skin
schools
shift
49:16,17 55:11 57:1,7
67:9 33:14,15 34:12,14 36:14 sleeved
scientific
39:22 43:15 85:16
56:4
56:8 shifts
small
scrap
39:8 47:10
81:18
shipped
smelled
seal 32:3 41:1542:17
30:9 93:17
shirley
smelling
second
8:18
41:16,22 42:19
6:12 44:17 50:16 65:6 66:5 shoes
smith
section
50:21
2:7
36:4 short
smoke
secure
9:23 10:1 17:2
16:20 52:12 63:18
64:9,11 65:18
shower
smoking
securer
52:1
52:16
18:17
showers
snow
seeing 52:2 67:13 68:3,18 69:23
41:23 84:17
shows
soap
seen
55:5 52:2
45:14 55:17 59:6 73:22 shut
soil
81:23
36:8 44:9
85:8
selling
sick
solid
81:15
58:6
24:3 31:7
sense
side
solutia
26:22 54:2,5,9 79:4 81:3
25:13,14 31:1 32:19 71:9
71:15
sent
77:21
somebody
87:5
signature
13:3 40:4 41:20 43:19
separate
3:10
48:19,21 51:7 52:3 65:21
87:4 signs
77:1 79:8 88:4
seriously
39:18
someway
19:14
simple
42:2
serum
28:7 91:20
somewhat
71:4 simpler
48:11
serve
90:12
soon
14:9,21
simplicity
39:3 83:21
served
28:16
sorry
14:7 sink
64:11 71:21 73:9 79:15
service
52:22
sort
1:1 15:20
sir
15:17 16:16 17:16 18:19,23
serving
4:15 11:6 13:10 16:1984:4 26:5,12 34:2 35:14 45:7
60:19
sit
50:17 73:2
session
48:18 58:3 84:16 85:21
sound
74:1 8:10
HARTOLDMONO013970
[sounds - thereabouts]
sounds 6:14,16 22:10 76:21
source 12:10
south 82:8
southern 75:1,13,16
speak 10:14 80:8
specific 54:10,12 56:7 79:19
specifications 43:20 84:22
spending 46:21
spent 45:18
spill 35:15,23
spilled 25:4
spoken 11:23
springs 7:7,8
St 75:21 87:6
staff 47:20
stand 38:10
star 58:19 69:1,3 88:18
start 6:22 36:15,19 47:16 53:9 56:20 76:2,2 83:19
started 15:7,20 21:5,15 23:14,19 24:1,9 53:1 55:2 69:3 76:1
state 4:1 12:1761:7
statement 40:22 50:3
stay 36:14
ste 2:4,8
steam 29:2
stenography 93:7
steps 61:21
stills 24:21 26:16 50:13
stipulated 3:2,9,15,22
stipulations 1:1 2:124:9
stir 52:21
stop 44:17
stopped 81:15
stored 82:5
story 69:2
straight 13:4 14:11
stream 26:5 28:3,5 61:22 86:14
streams 24:16 32:22 70:23 85:4
street 1:1 2:8
strike 13:2
studies 74:18
study 61:10 70:6,12,16
stuff 20:15 24:17 25:9 27:11 28:10,11 34:1948:12,15 54:6 55:3 82:4 83:18
styled 4:19
subsequent 56:11
subsequently 56:6
subsidized 17:22
sued 4:22
suggest 81:23
suggested 71:22
suggesting 58:13
suitable 55:19,22
sulfur 81:7
sum 17:19
superfund 91:6,10,18
superintendent
tank
39:5,11,1743:10,11,12,13 38:9 43:2
44:1960:14,1961:14,21 tanks
62:10 66:23 80:6,13,19
29:8
82:3 87:16,22
tasks
superintendents
24:5
42:6 44:11
taylor
supervise
1:1,1 2:153:44:4 7:1
39:9 team
supervising
37:6
85:14
technology
supervision
47:8
42:9
tell
supervisor
5:21 6:23 7:9 9:4 10:2,22
87:13
12:14 18:1820:6 24:16
supposed
28:2 29:19 34:15 40:7
26:1 49:21 69:22
48:14 50:15 52:23 53:13,20
sure
54:2 55:15 58:1 59:10,16
21:727:4,13 30:1531:3
63:4,12,13 65:21 66:17
32:8 39:21 41:11,13 43:20 67:22 73:18,20 82:12,20
48:460:1561:1368:14
84:7 93:3
73:16 86:5
telling
surgeries
52:3 65:11
16:12
temperature
surgery
27:4 49:13
16:13
temperatures
surprise
55:7,21
89:9,13,14,17 90:21 91:2,9 ten
91:22
76:22,22 77:17,17,18,19
surprised
tepee
90:13
81:8 83:6
swimming
terms
31:5 48:12
sworn
test
4:5 93:3
20:20 21:16 62:7 72:15
synonymous
75:15 78:22
48:12
tested
systemic
71:5,10,11 72:13,19 73:3
55:9 74:21 75:12
tad 133
t
testified 4:6
testify 11:13
888 taken
1:1 3:541:1061:21 93:2 talk
11:21 23:12 28:13 42:15 48:8 67:5 68:7 70:20 79:5 82:7 talked 8:13,14 10:21 12:7 talking 6:15,19 28:6 64:13,21 67:16,20 68:6 74:11 75:17
testifying 11:18
testimony 46:12 90:18 93:5,10
testing 85:2 87:5
tests 87:10
theirs 89:7
thereabouts 23:15
88:19
HARTOLDMONO013971
[thereto - washed]
thereto
told (cont.)
trying (cont.)
valve
3:21
54:3,10 58:18 65:9 66:11
50:6 54:4 68:15 70:7 76:6 30:8 49:10
thiers
66:13,16,22,23 68:22 73:5 tubes
valves
89:7
73:5,10 76:7
15:14
35:6
thing
tolerate
twenty
vapor
19:1,1 50:9 51:10 58:17
51:13
57:10,11,13,16
27:14
66:15 74:7,9 75:2,19
tongue
twice
vapors
things
18:12
5:20
26:21 55:6,20
5:21 12:3 15:18 18:20
tonight
type
various
25:13 31:1 32:19 37:14
44:19
27:3
83:14,15
38:10 39:19 45:7,22 63:5 top
typed
ventilation
83:5 85:15 92:5
33:15 39:13 63:7,19
73:22
27:18,21 55:19 56:5
think
touch
types
venting
5:4,106:2 11:9,10 14:1
27:6 54:6
24:2
30:1
18:15 28:18 30:23 31:23 town
typical
versus
32:4 33:3 47:22 54:11,18
7:18 91:7,21
83:2
1:1 4:19 70:9,21
58:22 63:15 65:14 67:6,11 toxic
u vessel
69:19 71:6,9,14,17 72:16
55:9 61:17
72:23 73:12,16 77:4,7,13 toxicity
uh 5:18,18 8:16,23 9:19 10:12
49:8 vice
84:13 87:6 88:6 90:7,19
53:3
11:5 12:21,23 13:19 14:12 19:4,4
92:6 track
14:20 15:9 16:8 19:18,18 vigorous
thinking
45:17
33:20 34:4,4 37:10 39:8
46:2
33:8 trained
43:9 79:23 91:3
visit
thirty
47:13
understand
70:18 71:2
4:22 21:22 22:4 57:5 58:6 training
21:23 48:11 50:7,23 53:12 voluntary
59:14
24:12
71:13
71:13
thoroughly
transcribed
understanding
volunteered
42:20 thought
93:7 transcript
19:22 68:16 understood
36:11
w
26:4 38:16 52:3 87:6 92:1
11:2 73:23 93:9
46:12 53:14 90:17
wait
thousand
transcription
union
66:5
61:18
93:8
19:2 44:20 71:23
waived
three 7:11 9:3 74:13
transcripts 11:7
unit 19:20
3:11,23 walk
time
transferred
university
39:18 40:4 41:1 44:3 60:9
3:19,20 5:5 10:19,23 13:22 1:1 47:11
61:8
walking
23:4 42:11 44:10,16 52:5 trash
untoward
41:14
53:16 63:15 65:12 69:8 82:17 83:18 87:23 88:8 timely
82:15 treated
75:21
56:1 unusual
41:19,23
walnut 1:1
want
43:5
treatment
ups
6:9 27:6 29:18 41:9 51:14
times
75:1 86:20
68:7
52:15 55:1 66:1 74:7
42:18
trial
use
wanted
tip
3:20
16:20 45:16 50:18
40:21 46:22 64:5 70:20
18:12
tried
usual
82:7
title
9:21 24:12
4:8
wanting
23:17 88:3
true
utilities
73:15 90:4
tobacco 16:20,21 17:1
6:17 64:7 65:8 93:9 truth
45:12 utility
wants 58:15
today
93:4 37:5 warm
4:16 10:14,17 11:21 58:3 58:11 84:16 90:16 toe 51:3 told 25:19 41:21 42:8 53:17,23
truthful
54:13
try va
42:11 76:10
2211
trying
vacuum
22:12 25:23 29:23 31:18,22 15:14
V
37:6 wash
51:18 washed
25:5 26:4
HARTOLDMONO013972
[waste - yesterday]
waste
wind
24:16 26:5 28:3,5 32:22
53:21 64:2
61:22 70:23 86:20 91:13 wise
wastewater
77:5
25:11 29:11 61:1562:7 witness
85:3 86:13
2:153:11 11:14,16 29:10
water
70:2 77:14 93:1,10,16
25:1826:9,11,14,1529:4 witnessed
31:8 52:4,10 59:17 84:1,2,3 65:11
84:6,10,12,17 85:8 86:8 witnesses
waters
93:6
61:11
wondering
wayne
74:23 84:14
23:6,7
wood
wearing
83:4
40:9,20
word
weather
42:2 43:11 45:16
35:10
words
week
73:3
46:13 57:20
work
weekends
13:12,13 15:2,5 17:11
39:9 20:16 22:20 24:5 32:23
weeks
33:14 38:5 53:9 55:5 57:11
10:1822:11
79:13,18
weighed
worked
77:7 11:20 15:11,1536:3 38:1
weight
45:9 56:12 57:4,13,15,18
77:3,5,7
59:14 70:8 76:11 88:12
welfare
worker
18:22
70:6
went
workers
13:15 14:23 25:12 31:23
18:9 70:13,23
33:4,5,8,23 36:10 44:11,12 workforce
44:23 47:3 51:18 61:4 71:1 51:14
80:10 82:14 87:13 88:13 working
89:21,22
13:1721:1,1538:1,13
west
43:14 51:6 55:2,13 57:9
31:1 32:19 87:2
68:9 72:6 79:20 80:12
we've
works
7:11 32:21 81:23
23:4 56:5 71:18
when's
world
87:23
6:14
whereof
worst
93:16
91:13
white
writing
64:4 62:8 76:23 93:6
wide
written
34:3 36:1,16,17
77:15
wife
wrong
10:6 17:5
wife's
8:17 y'all
william 1:1,1 2:153:44:4 7:1 9:9,9
43:7 82:5 yards
wilmer
89:16
8:1,3,4
y
yeah 5:1,4,7,9 10:9 11:16 14:8 15:15 17:18 19:1520:20 21:10,17,1922:22 23:11 24:15 25:6 26:10 27:1,10 27:1628:12,15 31:7,10 32:8 33:13 34:6 38:5,15 39:1541:11 42:2,5,14 43:21 46:15 48:13 49:10,18 51:20 52:17 56:16 57:21 64:9,15 67:15,17 70:19 71:14 72:8,16 74:15 75:19 76:4 81:7 82:11 85:6 86:15 87:2 89:17
year 7:15 12:6 13:21 20:14,20 21:13,20,22 33:11 36:8 44:15
years 5:4 7:11 14:2 18:15,17 21:22 22:5,18 27:23 33:2 36:23 57:5 58:6 59:2,15 76:11 78:22
yesterday 38:8
HARTOLDMONO013973