Document 3JVZdQqOar3b6JY8g5ME7d3OE
Page 204
1 In The Superior Court
2 Of The State Of Delaware
3 In And For New Castle County 4 -x
-
5 Monsanto Company,
:
6 Plaintiff, :
7 : Civil Action Number
8 v.
: 88c-ja-118-1-cv
9 Aetna Casualty & Surety Company, : Non-arbitration
10 et al. ,
: Case
11 Defendants. :
12 ----------------------------------x
13 Deposition Of James R. Savage ( Volume 2 )
14 Wilmington, Delaware
15 Wednesday, May 19, 1993
16 Deposition of James R. Savage, called for further
17 examination pursuant to agreement by counsel, at the law
18 offices of Smith, Katzenstein and Furlow, 1220 Market
19 Street, Fifth Floor, at 9: 50 a. m. before Kristine A.
20 O'connor, Court Reporter, when were present on behalf of the
21 respective parties:
22 -- continued --
Page 206
1 CONTENTS
2 Witness
Examination
3 James R. Savage ( Resumed )
4 by Mr. Brock
207
5 EXHIBITS
6 Savage Deposition Number
Identified
7 Exhibits 39 through 45 - Correspondence
207
8 Exhibit 46 - Anniston plant map
264
9 Exhibit 47 - 4/7/70 Memorandum
278
10 Exhibit 48 -11/2/71 Memorandum
280
11 Exhibit 49 -11/5/71 Memorandum
285
12 Exhibit 50 - 7/2/71 Memorandum
287
13 Exhibit 51 -85/71 Memorandum
289
14 Exhibit 52 - 11/30/71 Memorandum
292
15 Exhibits 53 and 54 -12/2/71 & 12/8/71 Memo
294
16 Exhibits 55 and 56- 1/4/72 & 1/13/72 Memorandum 299
17 Exhibits 57 through 84 - Correspondence
303
18 Exhibit 85 - Standard Manufacturing Process
19 for Aroclors-department 246
20 Exhibits 86 and 87 - 7/10/72 & 8/22/73 Memorandum 372
21 Exhibit 88 - 10/24/74 Memorandum
377
22 Exhibits 89 and 90 - 5/22/75 Memorandum
23
and 5/28/75 Memorandum
380
24 Exhibit 91 - Monsanto 1. a submission
382
25 Exhibits 92 and 93 - 11/6/75 & 12/5/75 Memo
384
26 Exhibit 94 - Pcb Emergency Plan
390
27 Exhibit 95 - 2/3/76 Memorandum
390
28 Exhibits 96 and 97 - 8/1/72 Memorandum
394
29 Exhibit 98 - 8/6/70 Memorandum
399
30 Exhibit 99 - 9/1/72 Memorandum
401
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1 Appearances: James F. Burnett, Esq.
1 PROCEEDINGS 2 Whereupon,
2 Potter, Anderson & Corroon
3 James R. Savage 4 resumed the stand and, having been previously duly sworn,
3 350 Delaware Trust Building
5 was examined and testified further as follows:
4 902 Market Street
6 Examination ( continued ) 7 ( Savage Exhibits 39 through 45
5 Wilmington, Delaware 19801
8 identified. ) 9 By Mr. Brock:
6 On behalf of Plaintiff Monsanto Company.
10 Q Good morning again, Mr. Savage.
7 Stephen F. Brock, Esq.
11 For the record, I've had a number of documents 12 marked as exhibits. They're Exhibits 39 through 45, and
8 Manta and Welge
13 I'd like to start with Exhibit 39. That's dated December 14 5, 1958 and the Bates numbers -- or the Bates number is
9 One Commerce Square 10 Thirty-seventh Floor
15 Ann 1539115. 16 Let me know when you've had a chance to look 17 through that, Mr. Savage.
11 2005 Market Street
18 ( Witness reviewed the document. ) 19 A Okay.
12 Philadelphia, Pennsylvania 19103 13 On behalf of Liberty Mutual Insurance Company.
20 21 22
Q Can you identify what this is for us? A Pardon me? Q Can you identify what this is for us?
Savage, James (Aroclor Dept employee) in AETNA (2)
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HARTOLDMON0010153
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1 A What this --
1 in the plant and 1 think in the city as well.
2 Q Right, what the document is?
2 Q When you say there were bad odors that were
3 A It's a letter from Cliff Stutz to Professor
3 coming out, was that an ongoing thing or was that something
4 Eliassen at Mit.
4 that happened -- strike that.
5 Q It makes a reference to J. R. Savage, pollution
5 Was that an ongoing thing?
6 control engineer. Do you see that?
6 A It was at least a frequent thing. 1 don't
7 A Yes.
7 remember whether it was continuous or not.
8 Q Were you pollution control engineer at the
8 Q I'm trying to distinguish it from the situation
9 Anniston plant in December of 1958?
9 of was this a new situation or was it something that dated
10 A No, 1 never had that title.
10 back a ways?
11 Q Do you know why there's a reference, why there's
11 A Well, 1 think it began as of the start-up of the
12 a discussion of you as a pollution control engineer here?
12 parathion department which was just before 1 got there.
13 A Cliff was encouraging me to take that career
13 Q Do you recall what your involvement was in the
14 direction and perhaps it was wishful thinking on his part.
14 odor reduction tests?
15 Q Can you describe for me how he went about
15 A 1 took samples and took them to the lab or
16 encouraging you to take that career direction?
16 carried out various things that Cliff had defined.
17 A Just in discussions that we had.
17 Q Was it ever resolved what the odors consisted of?
18 Q Do you recall the discussions and what they
18 A 1 don't remember that the materials were
19 consisted of?
19 identified as to specific chemicals. They were typical
20 A No, it was just very casual.
20 sulfur compounds.
21 Q Did you ever take any courses or instruction
21 Q Were there changes made to the operations of the
22 relating to the subject of pollution control around that
22 Niran plant as a result of those odor reduction tests?
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1 time?
1 A We installed the chlorination tower so that the
2 A No.
2 waste would be chlorinated before it went -- well, before
3 Q What was your reaction when Cliff Stutz tried to
3 it left the operating department, it would have been
4 encourage you to take that career direction?
4 upstream of the limestone bed.
5 A It didn't interest me.
5 Q Were there any other changes instituted as a
6 Q Did Mr. Stutz make the same approach to others at 6 result of those tests?
7 the Anniston plant that you recall?
7 A No. The limestone tower -- excuse me, the
8 A 1 don't know.
8 chlorination tower eventually proved to be quite efficient
9 Q The document references odor reduction tests to
9 and nothing else was considered to be necessary.
10 be made on the Niran wastes from the Anniston plant. Do
10 Q There's a statement that this work is beyond the
11 you see that?
11 scope of the investigation you had been doing for Monsanto
12 A Yes.
12 and the city of Anniston. That's in the next-to-last
13 Q Do you recall there being odor reduction tests
13 paragraph in the memo. Do you see that?
14 around that time frame?
14 A Yes, 1 see that but 1 don't know anything about
15 A There was an odor reduction effort going on and 1
15 it.
16 was working with Cliff on that and 1 do remember that there 16 Q Do you recall, did you work with Dr. Eliassen on
17 were some studies done with Dr. Eliassen, but that's about
17 any other projects?
18 all 1 remember about that. 1 don't remember sending these 18 A No, 1 never met him that 1 know of.
19 samples, although probably 1 did.
19 Q There's a reference in the next paragraph to
20 Q Do you recall what the impetus was for the odor
20 mixing -- it appears to reference mixing of Niran wastes
21 reduction tests?
21 with dye wastes ; do you see that?
22 A There was a bad odor that came out of the sewers
22 A Yes, 1 see that.
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1 Q Do you know what the dye wastes were?
1 project. It was Cliff's project. He worked with Fritz
2 A They were not from the Monsanto plant.
2 Rosenberg who's mentioned in this memo and also Bill
3 Q Do you know what that refers to, does that refer
3 Garlette in designing the chlorination tower and 1 didn't
4 to something at the Anniston waste treatment plant?
4 have very much to do with it.
5 A 1 don't know.
5 Q Who was Fritz Rosenberg?
6 Q Let's go to Exhibit 40 and again, this is
6 A Fritz Rosenberg was in organic division
7 something called an authentication. Can you identify what 7 engineering in St. Louis. He had been project manager for
8 the document is for us?
8 the installation of the Niran plant and had continued to
9 A It's a memo from John Mullendore to Cliff Stutz.
9 provide project management for some of the improvement
10 Q And you're listed as a copy recipient?
10 projects. Bill Garlette worked for him.
11 A Yes.
11 Q There's a statement" since the reporting of the
12 Q Just for the record, the Bates number is
12 present data by Eliassen to the City could be damaging to
13 Ann 1539114. This makes a reference to extending the study 13 Monsanto, it is imperative that we find a solution to the
14 to oxidizing agents other than chlorine. Do you see that?
14 odor problem."
15 A Yes.
15 Do you know what the - strike that.
16 Q Do you recall what other oxidizing agents, if
16 Do you recall concerns coming up about whether
17 any, were tested for other than chlorine?
17 the reporting of the data could be damaging to Monsanto?
18 A I'm not aware of any other testing.
18 A No.
19 Q And there's a question down below at the bottom
19 Q Do you know what that refers to, in what way the
20 of the second paragraph," how is a test for color
20 reporting could be damaging to Monsanto?
21 conducted "? Do you recall how the test for color was
21 A 1 could only speculate on what he means by this
22 conducted?
22 sentence. 1 don't know what was going on between Monsanto
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1 A No, 1 don't know.
1 and the city.
2 Q Let's go to Exhibit 41. For the record, the
2 Q Do you recall any discussions along the lines of
3 Bates number of this is Ann 1539113. Can you identify what 3 simply whether to give the data to the city or not?
4 this is for us, Mr. Savage?
4 A No. 1 would not have been involved in a
5 A This is a memo from Cliff Stutz to John
5 discussion like that. 1 was a small fish in this pond.
6 Mullendore.
6 One year out of school.
7 Q In the second paragraph towards the middle,
7 Q The memo ends with the statement" Perhaps 1 was
8 there's a statement that the odor level of the samples he
8 too brief in my explanation to Jim Savage when 1 called him
9 studied was 500. Do you know what that means?
9 to arranging for the samples to be sent to Eliassen."
10 A 1 don't know what he specifically means. A
10 Do you see that?
11 typical way of testing of odor would be with progressive
11 A Yes.
12 dilutions. Perhaps this represents some threshold of
12 Q Do you recall what explanation was given to
13 dilution but 1 don't know what the number itself signifies.
13 you --
14 Q The next sentence talks about considering the
14 A No.
15 possibility of conducting the study by plant personnel. Do
15 Q - concerning background of the project?
16 you recall any discussions along those lines?
16 A No.
17 A No.
17 Q Do you have an understanding as to why the
18 Q Who was involved in the study regarding odor
18 project was, why you were assigned to the project?
19 control of Niran liquid wastes? You said you took the
19 A 1 was the only person available. 1 was -- by
20 samples and 1 take it they were sent to Dr. Eliassen. Who
20 December, 1 was the only person with a technical assignment
21 else was involved, if anybody?
21 at the plant. The start-up crew had departed.
22 A 1 was just doing some legwork on that particular
22 Q Let's go to Exhibit 42. For the record, it's a
Savage, James (Aroclor Dept employee) in AETNA (2)
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1 March 31, 1959 memo attaching a December 31,1958 memo and
1 A No.
2 the Bates numbers are Ann 1539111 and 112.
2 Q Do you recognize the name Paul Krobs?
3 Mr. Savage, after you've had a chance to look
3 A I've heard the name before. 1 don't know if 1
4 through these, could you let me know.
4 ever met him.
5 (Witness reviewed the document.)
5 Q 1 take it you don't recall working with him on
6 A Okay.
6 any particular projects?
7 Q Can you, again, identify what these are for the
7 A No.
8 record.
8 Q The second paragraph talks about an extension of
9 A Yes, the first is a memo from John Mullendore to
9 the scope of the investigation. Do you recall the scope of
10 Wayland Klemme and the second is a letter from Cliff Stutz
10 the investigation concerning?
11 to Paul Krobs of Birmingham.
11 A No.
12 Q Who is R. W. Wobus?
12 Q Just so the record will be clear -
13 A Rheiny Wobus, he was in manufacturing. 1 think
13 A No, 1 don't recall.
14 his title at that time was technical production manager.
14 Q In the third paragraph there's a reference to
15 He was in St. Louis.
15 " textile mill wastes," do you know what that refers to?
16 Q Do you know what, if any, involvement he had in
16 A There were textile mills in the city.
17 the odor reduction project?
17 Q That doesn't make a reference to Monsanto wastes,
18 A No.
18 Itake it?
19 Q Who is W. W. Klemme, K-l-e-m-m-e?
19 A No.
20 A Wayland Klemme was chief chemist at the plant at
20 Q And again, the first paragraph has a sentence,
21 that time.
21 " The report seems to be in order and we see no reason for
22 Q There's a reference to " fresh waste " in the
22 not releasing it to the city and the water commission."
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1 second paragraph. What was fresh waste?
1 Do you see that reference?
2 A It has no specific connotation. The implication
2 A Yes.
3 is simply that they're samples that have been freshly
3 Q Does that refresh your recollection about any
4 taken, which would be the technically correct thing to do.
4 conversations about whether to release information to
5 Q There's some handwriting down below that says
5 the -
6 " memo to Savage 4/9." Do you see that?
6 A No, 1 wasn't involved in those relationships.
7 A Yes.
7 Q To the city water commission? Did you have any
8 Q Do you know whose handwriting that is?
8 dealings with the water commission during that time?
9 A Looks like Mullendore's.
9 A I'm not sure how the city was organized. 1 did
10 Q Do you know what that refers to?
10 investigate the city waste treatment plant on one or two
11 A The memo?
11 occasions.
12 Q The note?
12 Q Do you recall what those occasions were? I'm not
13 A 1 have no idea.
13 referring to date, I'm referring to what was the impetus
14 Q Let's go to the next page, the December 31, 1958
14 for them?
15 letter. In the first paragraph, there's a reference to a
15 A 1 think they related to some kind of difficulties
16 draft of final report of the special sewer commission. Do
16 that the city had with treatment and we simply went to talk
17 you know what the special sewer commission was?
17 to them. 1 remember being there but 1 don't remember the
18 A No.
18 discussion.
19 Q Do you recall being on any sewer commissions?
19 Q Were those the discussions that resulted in
20 A No.
20 Monsanto building its own waste treatment plant?
21 Q Do you recall seeing a draft of a final report
21 A No, that decision had been taken pretty early at
22 concerning the Anniston -- concerning the sewers?
22 a much higher level than me.
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1 Q Do you recall what, if anything, came out of the
1 the objectives, yes.
2 discussions?
2 Q Do you recall what, if any - strike that.
3 A No.
3 Do you recall any specific objectives that you
4 Q Do you recall who else was involved?
4 thought were important at that time?
5 A 1 think 1 went there with Cliff Stutz.
5 A No, that's too long ago.
6 Q Who was J. E. Standridge who's referenced at the
6 Q One of the objectives or it says - strike that.
7 bottom of the page?
7 In the first paragraph, it talks about things
8 A He worked for the city and he was supervisor of
8 that the Tsd department did in past years and one of them
9 the city's waste treatment plant.
9 is " practiced and publicized safety."
10 Q Do you recall having dealings with him?
10 Do you recall what, if anything, you did along
11 A Just that 1 met him when 1 visited the waste
11 those lines during the time you were at the Anniston plant?
12 treatment plant.
12 Ain the area of safety?
13 Q Do you know what the " J. E." stands for?
13 Q Right. Practice and publicize safety.
14 A 1 think his first name was Jim, but I'm not sure.
14 A Well, our role typically would be to respond to
15 Q Let's go to Exhibit 43. After you've had a
15 any perceived safety problem that required an engineering
16 chance to look through that, Mr. Savage, could you identify
16 solution. In that respect, some of the projects 1 worked
17 what that is for us.
17 on had a goal of correcting some safety problem. 1 also
18 ( Witness reviewed the document. )
18 served on various accident investigation committees,
19 A It's a memo from Bob Hedworth to Bob Pohl.
19 near-miss accident investigation committees.
20 Q And it's setting forth the Tsd objectives for
20 Q Do you recall any of the safety problems that
21 1959 ; is that correct?
21 needed correction at that time that you worked on projects
22 A That's right.
22 for?
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1 Q For the record, the Bates numbers of this are
1 A During the three years that 1 worked in the
2 0546027 through 0546030.01 and Mr. Savage, you're listed as
2 parathion department doing technical work, we had several
3 a copy recipient of this ; is that correct?
3 incidents that could have been quite serious. A couple of
4 A That's correct.
4 incidents that did cause some property damage and others
5 Q And the arrow indicates that this was a copy that
5 where, what we characterized as a near-miss, where some
6 was sent to you?
6 conditions existed that could have caused a serious
7 A Yes.
7 incident but due to good fortune that incident didn't occur
8 Q Who was R. C. Sprague?
8 and our practice always was to appoint - the plant manager
9 A Russ Sprague was the maintenance superintendent
9 would appoint an investigation committee and if it was in
10 of the plant at that time.
10 the parathion department, usually 1 was on that committee.
11 Q What about C. A. Sweets?
11 And we would conduct our investigation as to the
12 A That's Clarence Sweets, was personnel
12 causes and if any of our recommendations required
13 superintendent.
13 engineering improvements and those improvements were of a
14 Q And M. M. Silver, who was that?
14 size that could be handled as a plant project, then 1 would
15 A He was another engineer in Tsd.
15 be the engineer to install whatever those improvements
16 Q Were these Tsd objectives promulgated on an
16 were.
17 annual basis?
17 Q You said there were some matters that caused
18 A Yes, 1 think they were.
18 property damage. Do you recall what those were?
19 Q During the time that you were at the Anniston
19 A There was at least one where there was an
20 plant, did you have any input into what the Tsd objectives
20 overpressure in a reactor due to the reaction getting out
21 should be?
21 of control. Another in a still where there was a sudden
22 A Well, 1 would work with my boss in formulating
22 temperature runaway. 1 recollect that there were some
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1 others but 1 don't remember specifically what they were.
1 no normal function.
2 Q Okay. And the first one, the overpressure to the
2 Q What was done with the material that collected
3 reactor, what type of property damage resulted from that?
3 there?
4 A It was confined to an immediate process system,
4 A If there was a discharge into the trench, which
5 blew some piping apart.
5 was quite rare, then the water in the trench would have to
6 Q And what action was taken in response to that
6 be slowly pumped to the waste treatment plant at a pace
7 situation?
7 that the waste treatment plant could treat and any solid
8 A 1 don't remember exactly. It was some
8 material left in the bottom would have to be dug out and
9 improvement to control system.
9 placed in disposal containers.
10 Q What property damage resulted from the
10 Q Do you know what happened to the disposal
11 temperature runaway situation?
11 containers?
12 A Again, it blew apart some fairly expensive
12 A No, 1 don't know where they went.
13 piping.
13 Q Do you recall there being occasions on which the
14 Q Do you recall what was done in response to that
14 solid was dug out?
15 situation?
15 A 1 know it was dug a few times but 1 have no idea
16 A Yes, that turned out to be a surprising design
16 how often.
17 booby trap that had not been suspected previously. The
17 Q You mentioned that there were several incidents
18 pressure relief on those vessels was accomplished with a
18 that could have been quite serious. Where were you or can
19 graphite rupture disk, which is a frangible disk which is
19 you describe those incidents?
20 designed to break at a pressure well below the designed
20 A No, 1 don't remember. The process was known to
21 pressure of the vessel. And the discharge line from that
21 be, to involve intermediates that were unstable and the
22 rupture disk extended into a trench below the reactors that
22 crude mass and the chlorinators and stills was thermally
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1 was put there for the specific purpose of receiving such
1 unstable and therefore any unusual incident where
2 discharges.
2 temperature behaved in an unusual way was always
3
And that discharge line had been submerged in the
3 investigated to determine whether there was some suspected
4 water and had a very small hole in it to prevent any
4 hazard and 1 don't remember what those were all about.
5 possibility of water siphoning back into the reactor or
5 Q You mentioned that you were on some accident
6 water getting into the still. Because water getting into
6 investigation committees. Do you recall there being
7 the still was known to be something that would cause a
7 investigations of any situations involving exposure of
8 runaway. It turned out that that hole designed as a safety
8 workers to chemicals in the Niran department?
9 break was far too small, which 1 proved with an experiment, 9
A 1 can remember two. 1 mentioned yesterday having
10 and therefore we changed the configuration of that line.
10 installed a device that contained an eye irritant from one
11 Q What went through the discharge line?
11 of the tanks, that that project came from an investigation
12 A The contents of the still, which was ethyl Pet or
12 of an incident where a worker sustained sufficient eye
13 methyl Pet depending on which of the products we were
13 irritation that he went to the dispensary.
14 running at that time. 1 don't recall.
14 Q And 1 believe you said you didn't recall who that
15 Q Where did that discharge line discharge to?
15 worker was?
16 A To this trench that ran underneath the reactors.
16 A No.
17 Q Where did the trench go?
17 Q And what was the second situation?
18 A It didn't go anywhere. It simply contained water
18 A The second was one in which a maintenance worker
19 and other than changing the water from time to time if it
19 was working on the filter press which was used to filter
20 became stagnant and got frogs in it and so forth, it was
20 the finished parathion product. And he was new to the
21 just there as a sink to quench any material that came out
21 experience, he had only been on the job for a day or two
22 of the reactors. It was strictly a safety back-up. It had
22 and 1 don't remember what his assignment was, but at any
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1 rate, the filter still had pressure in it at the time that
1 Q Under the " general" category below, referring to
2 he was working in it, so that when he released the locking
2 the objectives for 1959, C is " keep abreast with new
3 ring that kept it closed, it came open and he was sprayed
3 developments and new techniques by reading literature."
4 with parathion. That was considered to be a very serious
4
During your tenure at the Anniston plant, did you
5 matter because parathion is extremely toxic.
5 keep abreast with technical or engineering literature?
6 Q How did you learn that parathion was extremely
6 A Well, I've always read some of the professional
7 toxic?
7 magazines associated with chemistry and chemical
8 A Well, the product is an insecticide, it's known
8 engineering.
9 to be extremely toxic.
9 Q Have you ever been a member of a trade
10 Q Meant to be?
10 association?
11 A Yes.
11 A I've been a member of American Institute of
12 Q And do you recall who that maintenance worker
12 Chemical Engineers since 1956 and still am.
13 was?
13 Q What does it take to become a member of that
14 A No.
14 organization? How does one become a member?
15 Q Were any process changes instituted as a result
15 A Normally a degree in chemical engineering.
16 of that situation?
16 Actually when 1 began, 1 was an associate member because
17 A No. We made some mechanical and procedural
17 the full membership requires a certain number of years of
18 changes but 1 don't remember what they were.
18 experience. 1 don't remember how many. I'm a full member
19 Q Do you recall there being any claims or
19 now and have been for a long time.
20 complaints by people outside of Monsanto that Monsanto's 20 Q You've been a member of that organization
21 operations were resulting in unsafe conditions?
21 continuously since that time?
22 A No.
22 A Yes.
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1 Q Exhibit 43, discussing the things that the Tsd
1 Q Have you received literature from that
2 department had done in the past makes a reference to
2 organization?
3 improving public relations. Did you have any public
3 A They have a monthly magazine which 1 have
4 relations duties or activities during that time?
4 received all that time.
5 A 1 can remember doing things like speaking at a
5 Q Do you recall what that's called?
6 career day at the high school, things like that, nothing
6 A Chemical engineering progress.
7 more specifically directed toward Pr than that.
7 Q Have you received that continuously since --
8 Q Did any of your public relations efforts relate
8 A Yes.
9 to waste disposal or pollution or environmental matters?
9 Q -- you've been a member? Do you recall any
10 A No.
10 specific articles that you had occasion to make reference
11 Q There's a reference to training courses. Did you
11 to from that periodical?
12 take or teach training courses while at the Anniston plant?
12 A 1 don't remember specifically.
13 A No.
13 Q Do you recall -- does that periodical discuss
14 Q Do you know what type of training courses, if
14 environmental or waste disposal matters?
15 any, were taught to Tsd personnel at the Anniston plant
15 A Yes.
16 during your tenure there?
16 Q Do you recall any articles that you may have read
17 A There was some statistics training, 1 think. 1
17 in there along those lines?
18 don't remember anything other than that.
18 A Not specifically.
19 Q Do you recall training courses regarding waste
19 Q What other professional magazines or periodicals
20 disposal or environmental matters ever being instituted
20 have you received during your tenure with Monsanto?
21 there?
21 A There's a trade magazine called Chemical Week. 1
22 A No, 1 don't remember that there were any.
22 have not read all of these all the time obviously. There's
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1 one called Chemical and Engineering News that's published
1 material.
2 by Acs, American Chemical Society ; European Chemical News.
2 Q When you say information in the plant, are you
3 For a while 1 got Japan Chemical Week. There may be some
3 referring to things like material safety data sheets?
4 others.
4 A Yes.
5 Q You mentioned American Chemical Society. Have
5 Q What other material, if any?
6 you been a member of that organization?
6 A Well, of course, in recent years there's been an
7 A No.
7 official government format for material safety data
8 Q Does Monsanto, during your tenure with Monsanto,
8 sheets. That did not exist at the time but we had our own
9 did Monsanto have representatives to that organization?
9 company format for material safety data, and we would
10 A Yes. The president of Acs was Al Heiniger
10 normally have a sheet like that and perhaps some additional
11 during, 1 think, his last year or two with Monsanto.
11 written material about all the raw materials, intermediates
12 Q And what general time frame was that?
12 and finished goods processed in each department.
13 A Within the last five years.
13 Q Did those Monsanto sheets have a name?
14 Q Can you give me just a general time frame of when
14 A I'm sure they did but 1 don't remember what it
15 you got these periodicals?
15 was.
16 A No, 1 don't know.
16 Q Do you recall whether or not the Anniston library
17 Q For Chemical Week, 1 mean ' 50s,' 60s,' 70s?
17 had materials concerning the behavior or migration of
18 A 1 can't remember. Usually the department that 1
18 chemicals in soil or water?
19 was a part of would subscribe to some of these magazines
19 A Not that 1 recall.
20 and they'd be available on a rack and that's certainly part
20 Q Did the Krummrich plant have a similar library?
21 of what went on at Anniston but which magazines they were,
21 A The Krummrich plant had a better library, bigger
22 1 don't remember.
22 plant, more people. Working at Krummrich also, we had
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1 Q Did the Anniston plant have a technical library
1 access to the central library at the general office, which
2 for this kind of thing?
2 was very large and comprehensive.
3 A We had a very rudimentary library at this point
3 Q Did you have occasion to use the Krummrich
4 in 1958. A little later we developed a better one.
4 library during the time you were there?
5 Q When was the better one developed, during your
5 A I'm sure 1 did.
6 tenure there?
6 Q Do you recall any specific matters?
7 A Yes, Mr. Hedworth was replaced by Jim Larkin who
7 A No.
8 wanted to improve the professionalism of the department and 8
Q When you say it had a bigger and better library,
9 improving the library was one of these projects.
9 can you just describe for me generally what that library
10 Q Do you know how far back that library dated, when
10 consisted of?
11 it started?
11 A 1 don't remember.
12 A No.
12 Q Back on Exhibit 43, under the " general" category,
13 Q Generally during the time you were there, what
13 is " expand the technical service department procedure
14 did it consist of?
14 manual."
15 A Magazines, a lot of vendor literature, which was
15 What was that manual?
16 very useful to a design engineer, some handbooks.
16 A 1 don't remember. 1 just remember we had one,
17 Q Do you recall it containing materials about the
17 but 1 don't remember.
18 toxicity of chemicals used and generated in Monsanto's
18 Q Was there such a manual for the Krummrich plant
19 operations?
19 during the time you worked there?
20 A That would not have been in the library. We had
20 A Yes.
21 information on the toxicity of the chemicals used in the
21 Q What did that consist of?
22 plant but that would not have been general library
22 A It was largely a plant guideline or design
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 232 - 235
HARTOLDMON0010160
Page 236
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1 guidelines for various kinds of equipment.
1 Q The references under the " Santowax" heading, were
2 Q Do you recall having any input into the contents
2 you involved in any of those projects?
3 of that?
3 A No.
4 A 1 don't recall it.
4 Q Are you familiar with there being plans for the
5 Q I'm talking about things or subjects that you
5 renovation of the Santowax department during that time
6 drafted or generated, materials.
6 frame?
7 A There might have been but 1 don't remember.
7 A 1 can remember Santowax renovation projects but
8 Q Do you recall consulting that procedure manual
8 whether 1 knew anything about it at that time, 1 don't
9 for any matters relating to discharges of chemicals or
9 remember.
10 toxicity of chemicals?
10 Q Do you have an understanding as to what the
11 A 1 don't recall that.
11 impetus for those projects was?
12 Q If you go on to the next page, category li is
12 A No.
13 " biphenyl."
13 Q Do you recall any Santowax projects during that
14 A That's right.
14 time frame relating to waste disposal matters?
15 Q Were you involved at that time in increasing
15 A No.
16 biphenyl production capacity at the Anniston plant?
16 Q Later on at the Anniston plant, the Hb-40
17 A No.
17 operations were under your purview?
18 Q There's a reference in category number 1 to
18 A As a production supervisor, that's right.
19 " eliminating the benzene and the still feed." Do you know 19 Q Were you involved in any of the projects
20 what that refers to?
20 referenced on this page, on the third page of the exhibit
21 A 1 do from later experience but not from anything
21 regarding Hb-40?
22 that was going on at that time.
22 A The first one regarding a hydrogen compressor, 1
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1 Q Based on your later experience, what does that
1 started that up as supervisor. That was somewhat later
2 refer to?
2 than this writing.
3 A Benzene is the raw material for making biphenyl
3 Q What was the impetus for starting that up?
4 and the next step after synthesis is to separate unreacted
4 A Prior to that project, the hydrogen supply for
5 benzene from biphenyl and if that was not done thoroughly 5 the Hb-40 department came from the biphenyl department
6 enough, it adversely affected the capacity of the
6 because there was by-product hydrogen available both from
7 downstream steps.
7 biphenyl and from the chlorine plant. And it was
8 Q Do you recall what the impetus was for wanting to
8 determined that the hydrogen available from the chlorine
9 eliminate the benzene in the still feed?
9 plant was of higher purity than that was being used from
10 A No.
10 the biphenyl plant and in order to utilize it, it was
11 Q Were you involved in any type of project like
11 necessary to install a compressor and we did that.
12 that after December 1958?
12 Q Do you recall there being any occasions on which
13 A 1 was eventually concerned about capacity of the
13 the quality of the impurity of biphenyl hydrogen
14 biphenyl plant as a manufacturing manager in the early
14 necessitated the product being somehow disposed of in a way
15 '70s.
15 other than selling it to customers?
16 Q These operations were not under your purview
16 A No. The impetus to get rid of those impurities
17 during the time at the Anniston plant that you had
17 was to reduce catalyst usage as you can see at the top
18 responsibilities for the Aroclor department?
18 here. The goal was to reduce catalyst usage. The
19 A No.
19 consumption of catalyst is directly affected by impurities
20 Q Were there projects here towards the elimination
20 in the hydrogen.
21 of benzene in the still feed in the early ' 70s?
21 Q Were you involved in the second project regarding
22 A No, that problem no longer existed at that time.
22 the sodium treatment of Santowax?
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 236 - 239
HARTOLDMON0010161
Page 240 1 A No, 1 remember hearing about that but as far as 1 2 know that's not something that we did.
Page 242 1 material during the process where the soda ash was opened 2 and dumped by hand?
3 Q Why was that?
3 A No, there was a big, a large funnel for doing
4 A 1 don't know.
4 it. It was a reasonably orderly operation.
5 Q Were you involved in any of the muriatic acid
5 Q What does soda ash contained of?
6 projects referenced here?
6 A Sodium carbonate, which is a common name for
7 A No, this project was before 1 was production
7 sodium carbonate. It's a dry powder. Sometimes called
8 supervisor.
8 washing soda.
9 Q Under" miscellaneous," it talks about
9 Q And H refers to simplify operation of
10 development, demonstration and production of new Monsanto 10 incinerator. Do you know what that entailed?
11 plant products. Were you involved in any projects or work
11 A 1 don't know exactly what that project was about.
12 along those lines?
12 Q Do you know what materials were sent to the
13 A No, 1 don't know what this refers to.
13 incinerator at that time from the Niran department?
14 Q Underthe " Niran and methyl parathion," B is
14 A Yes. The incinerator was in the department down
15 " demonstrate excess P2s5 process." What was the excess 15 at one end. It really served two functions. One was to
16 P2s5 process?
16 dispose of still residue which was a liquid containing
17 A We were having some difficulty controlling the
17 solid sulfur. The other was to dispose of hydrogen
18 first step of the process, which is a reaction between P2s5
18 sulfide, which was a by-product of the first step of the
19 and either ethyl alcohol or methyl alcohol, depending on
19 process and gaseous hydrogen sulfide entered the fire box
20 which product is being made. And research had devised a 20 from the side through a pipe.
21 process in which as it says, an excess of P2s5 was present 21 Q After the incineration of such materials, would
22 in the reactor which would ensure that the reaction went to
22 there be a residue left in the incinerator?
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1 completion. And demonstrating it simply means that a test
1 A No. The whole idea was to get complete
2 was carried out in the plant to show whether it would work
2 combustion.
3 correctly in the plant.
3 Q For example, there wouldn't be ashes or something
4 Q What does the reference to " excess P2s5 " mean? 4 like that?
5 A That just refers to a change in the process where
5 A 1 don't recall that there was any ash.
6 more P2s5 is present than is required to act with all the
6 Q On the next page, under the " Aroclor department,"
7 alcohol present.
7 it talks about" reducing Bod loading to the city sewer by
8 Q After the reaction, would some of the P2s5 be
8 improving yields and by incinerating waste acetone brine."
9 therefore left over?
9 Do you see that?
10 A Yes, but it would be left in the reactor for the
10 A Yes.
11 next batch which was a solid.
11 Q Do you know what was done to reduce Bod loading
12 Q Did that ever have to be gotten rid of?
12 to the city sewer?
13 A No, it would just always be there as what was
13 A Well, it's really hard to recall. 1 can see what
14 called the heel for the next batch.
14 this says, improving yields and incinerating wastes acetone
15 Q G talks about a soda ash conveyor. Do you know
15 brine. Improving yields was something we wanted to do
16 what that was, what the soda ash was?
16 anyway and we did. 1 don't recall what the linkage was to
17 A Soda ash was another one of the raw materials.
17 Bod loading. There would be an effect, but 1 don't
18 At the time we were buying soda ash in bags and the bags
18 remember.
19 were being opened and dumped by hand into a tank that was 19 Q Do you recall there being concerns about Bod
20 used in the process. The purpose of the conveyor was to
20 loading to the city sewer at that time?
21 simplify and automate that task.
21 A Bod is the way that you measure organic loading
22 Q Do you recall there being any spillage of
22 on a waste treatment plant. It stands for biological
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 240 - 243
HARTOLDMON0010162
Page 244 1 oxygen demand and there's a specific test run in the 2 laboratory to measure biological oxygen demand and higher
Page 246 1 engineer in the department but 1 don't remember when. 2 Q You said you didn't know whether the acetone
3 Bod means more load, which impacts billing, that is, they 4 were charging us for Bod, but also reflects what load is 5 being put on the plant and therefore what difficulty they 6 might experience. 7 Q Do you recall there being any occasions on which 8 the thought was expressed that the amount or the 9 concentration of materials being sent from Monsanto to the 10 city of Anniston sewers was simply too much for efficient 11 treatment by the sewers and therefore pollution had 12 resulted from the effluent from the city sewers? 13 A Well, the reason for building our own treatment 14 plant was to reduce the loading on the city sewer because 15 it was -- it had been determined by somebody that the city 16 waste treatment plant was not big enough to reliably handle 17 the combined load of the city for the domestic waste plus 18 other wastes were going into it plus our own. 19 But 1 was never part of any discussion of what 20 impact that actually had on the city sewer or whether they 21 were able to treat or not. 22 Q What is waste acetone brine?
3 brine was incinerated or not. Do you mean you don't know 4 whether this step was instituted? 5 A That's right. 6 Q What was done with the waste acetone brine before 7 this time? 8 A It was drained to the sewer. 9 Q The next reference is " develop corrosion data for 10 all steps in the process." Were you involved in that? 11 A 1 was involved in some of that. 12 Q Do you know what that entailed? 13 A There's a very standard procedure for doing that, 14 which involves what are called coupons or small specimens 15 of various kinds of metals. And normally those are mounted 16 on a rack and placed inside the process vessel. And after 17 exposure of a few weeks, the rack is removed and given a 18 metallurgical examination to determine which of the metals 19 are most appropriate for that step of the process. 20 Q Do you recall what the impetus for that step was 21 for developing the corrosion data? 22 A 1 think that that was a fairly routine step for a
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1 A I'm not sure 1 can place this situation in time
1 new department, to make sure that we had the right
2 very accurately. When the plant first started up, there
2 materials in all spots.
3 was a problem with acetone. Acetone was used as a solvent 3
Q Was there a concern that corrosion of materials
4 to dissolve one of the raw materials and then was recovered 4 had led to -- or equipment had led to discharges to the
5 from the reactor after the reaction step. And it was a
5 environment?
6 surprise that the acetone was accumulating moisture as it
6 A It was perceived as a maintenance problem. 1
7 was used and reused and reused. And to correct that, a
7 don't recall that corrosion specifically led to discharges
8 temporary system was installed whereby calcium chloride was 8 in the environment.
9 used as a drying agent to dry the acetone.
9 Q The next step is " establish heat and material
10 And it worked reasonably well but after the
10 balance for entire process." Were you involved in the
11 acetone was dried, there would be a separate layer in the
11 establishing of a material balance for the entire process?
12 tank of calcium chloride solution that had some acetone
12 A Yes.
13 dissolved in it. 1 don't remember whether we incinerated
13 Q Can you describe for me what that entailed.
14 that brine or not. The problem was later solved in another
14 A That's a standard chemical engineering exercise
15 way.
15 in which one measures all the material inputs and outputs
16 Q How was it later solved?
16 to a process, calculates what the theoretical conversion
17 A We installed a distillation column to dry the
17 should be and as a result one is able to find whether
18 acetone and that worked very well. Dry acetone from the
18 there's opportunities for yield improvement.
19 top of the column and the waste from the bottom of the
19 Q Do you recall what the impetus was for
20 column was pure water.
20 establishing that as an objective with regard to the Niran
21 Q Do you know when that was installed?
21 operations at that time?
22 A No. It was during the time that 1 was an
22 A That's quite a normal thing to do for any
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 244 - 247
HARTOLDMON0010163
Page 248
Page 250
1 process. We knew that overall yield was far from theory
1 unstable and would tend to decompose for a time and
2 and so we were confident that there were opportunities to
2 therefore we did a number of relatively small things to
3 save money and the purpose of running material balance is 3 speed up the cycle time, which shedded large leverage on
4 to find those opportunities so that something can be done.
4 yield.
5 Q Do you recall why it was that overall yield was
5 Q Any others that you recall?
6 far from theory, was that ever determined?
6 A No.
7 A The process had been developed and researched to 7
Mr. Brock: This is a good time for a short
8 the best of their ability. It was the best they could do
8 break.
9 at the time.
9 ( Recess. )
10 Q Did that have anything to do with materials being
10
By Mr. Brock:
11 discharged from the process rather than going into the
11 Q Let's go to the Aroclors. 1 thought you told me
12 final product?
12 yesterday you were involved in the starting up of a
13 A Well, again, those are just statements of the
13 continuous chlorination process for the Aroclors at the
14 same phenomenon. If the raw material isn't winding up in
14 Anniston plant; is that correct?
15 the product, then it's going somewhere else. That's the
15 A Yes. This memo refers to the original
16 principle of the material balance.
16 installation of a continuous chlorination. What 1 did
17 Q Okay. Was it ever determined where -- describing
17 later on as a production supervisor was extend the use of
18 that -- strike that.
18 that continuous process to another product, another
19 Was it ever determined or investigated as to
19 Aroclor.
20 whether more of the material than Monsanto would have liked 20 Q It says " estimate and justify." Do you recall
21 was being discharged somehow to the environment, either
21 what the justification was for that?
22 through the air or through the soil?
22 A Increased capacity.
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1 A The idea was -- of course, the purpose of this
1 Q Under" technical assistance," it says " reduced
2 work was to find whether there were practical opportunities
2 lime addition in the step to reduce furnace coil burnouts
3 to reduce the amount of loss and there were.
3 and pump failure." Do you see that?
4 Q Do you recall what those were?
4 A Yes.
5 A That was what the majority of my job was at the
5 Q What were furnace coil burnouts?
6 time, was to figure out what those were and to institute
6 A Let me point out 1 was not involved at that time
7 projects to correct them. And there were a lot of them.
7 but based on my later experience as production supervisor,
8 Q Do you recall any of the specific ones that
8 each of the stills had a furnace. The crude product in the
9 involved reduction of discharges to soil, air or water?
9 still pot was pumped out of the still pot and through the
10 A There weren't any discharges to air that
10 coil of the furnace and then back into the furnace - or
11 represented an economic, an amount that would be of
11 back into the still pot from the furnace. The furnace
12 economic concern. The losses that were of economic concern 12 consisted of a cylindrical vessel with a brick lining and a
13 were either recoverable materials that were in the liquid
13 coil inside.
14 waste going to the incinerator or were present in the
14 Stills ran at a very high temperature and those
15 aqueous wastes going to the treatment plant.
15 coils would burn out from time to time and likewise the
16 Q Do you recall any specific process changes that
16 pumps would fail. The pumps were submerged pumps in the
17 were instituted to reduce either of those?
17 still pot. As to the amount of lime added was reduced, 1
18 A There were a number of them that in the early
18 don't know.
19 stage of the process is where most of the yield loss
19 Q In the event of a coil burnout, what would happen
20 occurred. We determined through statistical methods that
20 to the material in the furnace? Was something else done
21 it was largely a function of the processing time, which was
21 with it?
22 plausible because we knew that the materials were thermally 22 A No, because these stills operated under vacuum so
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 248 - 251
HARTOLDMON0010164
Page 252
Page 254
1 if the coil failed, the air would be sucked into the system
1 concerning historical waste disposal practices?
2 rather than product going out. So it would be impossible
2 A No.
3 to continually run the still and so it would be shut down.
3 Q Do you know who it was that handled putting that
4 Q And after that happened was that product disposed 4 material in skips and removing it by truck to be dumped
5 of in some way?
5 during the time that you were production supervisor?
6 A No, because the furnace was actually mounted on a 6 A Well, the responsibility for draining the still
7 slightly higher level than the still pot, so when it was
7 residue from the stills into the skips was that of the
8 turned off, all the material that was in the furnace coil
8 operators and laborers who were in my department. Once
9 just drained back into the still pot. After repairs were
9 that was done, then it was the responsibility of the
10 made, it was simply started back up again.
10 shipping department to take it away.
11 Q Do you recall there being a concern about pump
11 Q Do you recall anybody in the shipping department
12 failures?
12 whose responsibility that was?
13 A Yes, that was a maintenance problem.
13 A 1 remember some of the workers. The only name 1
14 Q Do you recall there being a concern that pumps
14 remember is Homer Broadwell, who was one of the drivers, a
15 were failing too often in the Aroclor operations?
15 kind of colorful character, that's why 1 remembered him.
16 A These particular pumps were a very difficult
16 Q Do you know whether Mr. Broadwell is still alive?
17 service since they were submerged in the still and operated 17 A No. He would be about 70 now, 1 suppose.
18 at a very high temperature. So there would be failures of
18 Q When you say he was a " colorful character," in
19 what were called foot bearings which would require shutting 19 what sense?
20 down and removing the pump and repairing it.
20 A An enjoyable person to talk to.
21 Q And when there were failures of that type, would
21 Q Do you know whether he was still employed by
22 materials, would that result in the discharge of materials?
22 Monsanto in the ' 60s or' 70s?
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1 A No, because the pump was submerged in the vessel. 1 A Well, in the ' 60s, yes. While 1 was still at the
2 Q D is " follow project to completion for disposal
2 Anniston plant but.
3 of still residue and to skips to be removed by truck and
3 Q But you don't know after that time?
4 dumped." Do you see that?
4 A When he might have left to retire, 1 don't know.
5 A Yes.
5 Q The next entry for E references something called
6 Q Do you recall what that project was?
6 Attasorb Lvm. What is that?
7 A Well, at the time that 1 took over the
7 A That's a form of diatomaceous earth, clay.
8 department, 1 think that most of that still residue was
8 Q What was that used for? 1 see that it says
9 being handled in a fashion described here, putting into a
9 " improving Aroclor quality," how did that work?
10 skip, which is a container a little bit like a dumpster
10 A The last step of the Aroclor process was what was
11 that would be attached to the back of a truck.
11 called clay treatment and filtration and that involved
12 Q Do you know whether anything was different--
12 putting clay into a tank where the distilled Aroclor
13 anything different was done with the still residues before
13 agitated for a certain period of time and then pumped that
14 December of 1958?
14 through a filter and the purpose of that was to remove last
15 A Well, this sentence implies it but 1 don't know
15 traces of what were called ionizable impurities.
16 what it was.
16 The premier application still was an electrical
17 Q Have you ever been involved in any investigation
17 effluence and the electrical properties of the fluid were
18 into the historical waste disposal practices with regard to
18 profoundly affected by amounts of impurities too small to
19 the Aroclor operations at the Anniston plant?
19 measure, chemically measure. And the test that was done
20 A No.
20 was an electrical test called resistivity and the purpose
21 Q When you came on board as production supervisor 21 of the clay treatment was to increase the resistivity,
22 in that department, were you provided with information
22 hopefully much better than specification, so as to be sure
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 252 - 255
HARTOLDMON0010165
Page 256
Page 258
1 the product was still good when it arrived to the customer.
1 microscope, you can see that that's what it is, so it's
2 Q And what was done -- 1 take it the clay would
2 silica, things like that.
3 absorb some of the ionizable impurities?
3 Q 1, a reference number, letter 1 is " revamp
4 A Ideally, all of them.
4 Aroclor still room." And number 2 under that," Improve
5 Q And what was done with the -- would the clay
5 material handling bin by centralization of drumming station
6 eventually become saturated with those?
6 and providing better accessibility for removing drums." Do
7 A The clay was only used one time, each amount of
7 you see those references?
8 clay went into a batch, was filtered out and then was
8 A Yes.
9 discarded.
9 Q Was the Aroclor still room revamped in that
10 Q Do you know how it was discarded?
10 fashion?
11 A In the same fashion as the still residue.
11 A 1 don't remember. 1 don't remember a separate
12 Q Would the still residues and the clay and other
12 control room for the stills. Could be, but 1 don't
13 materials be gathered and all put in one type of container
13 remember.
14 and taken away collectively?
14 Q Do you recall there being concerns about the
15 A 1 don't remember. 1 don't think so.
15 material handling with respect to the drumming involved in
16 Q For example, would they be put into separate
16 the process?
17 containers?
17 A 1 don't know whether this project took place or
18 A The operation was in a little bit different part
18 not. At the time that 1 took over the department, we had
19 of the department, so 1 can't visualize that it would be
19 reasonable material handling with roller conveyors and so
20 the same container but 1 don't remember specifically.
20 forth.
21 Q When you say ionizable impurities, what were
21 Q Do you recall concerns being expressed with
22 those?
22 respect to the possibility or the frequency of spills
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1 A This would be sodium chloride, perhaps Hcl.
1 during the drumming?
2 There is a large class of compounds that could cause a
2 A No.
3 lower resistivity and since the amounts involved were too
3 Q And you also subsequently had responsibilities
4 small to be chemically measured, one could never be sure
4 for the chlorine operations at the Anniston plant?
5 what it was that was being taken out. The quantities were 5 A Yes.
6 extremely small.
6 Q B makes a reference to " liaison with division
7 The difficulty was that simply for use in
7 engineering." Did you have any responsibility along those
8 capacitors, it was necessary to get the resistivity of the
8 lines during your tenure at Anniston?
9 fluid extremely high and while we knew that very tiny
9 A Liaise with division engineering, yes, in terms
10 amounts of materials like chlorides could cause a drop in
10 of the Niran department. But in terms of the chlorine
11 resistivity, we were never really sure what it was that was
11 department, the project referred to here, to installing
12 being taken out.
12 additional mercury amalgam cells had already been completed
13 Q Did you have the understanding as to whether or
13 at the time 1 took over the department.
14 not the clay itself had any sort of harmful or toxic
14 Q And C refers to " continued study of improving
15 effects?
15 cell linings." What does that refer to?
16 A I'd be reasonably confident it didn't.
16 A The cells, as they were originally constructed,
17 Q Do you know what it consisted of chemically?
17 they were built in Italy, the linings were stone, slabs of,
18 A The term" diatomaceous earth " refers to a small
18 1 think, granite and that turned out to be not as durable
19 form of life that's called a diatom, which is a little
19 as had been hoped for, so there were attempts to put
20 bitty microbe that grows in the ocean and diatomaceous
20 various coatings on the stones to increase their life.
21 earth is actually the kind of fosso-exoskeletons of those
21 Q What was the chlorine liquification system
22 little critters. If you look at that earth under a
22 referenced in letter D?
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 256 - 259
HARTOLDMONOOIOI66
Page 260 1 A The chlorine, as produced in the cells, is a gas 2 and most of the time that gas -- at the Anniston plant that
Page 262 1 go to Exhibit 44. Can you identify for us what this is? 2 A It's a memo from Cliff Stutz to Fritz Rosenberg
3 gas was used directly in the Aroclor department without
3 reporting on a visit he had made to Anniston.
4 liquification. There was a liquification system present
4 Q The first paragraph of this references a meeting
5 with the idea that if the requirements of the Aroclor
5 with Mayor Morris regarding charges being made by the city
6 department fell below the production rate in the chlorine
6 for treating the Niran wastes.
7 department, it would be possible to liquify part of the
7 Do you recall such a meeting?
8 output and thereby store it so that it could be used later
8 A No.
9 so that's what that system is -- was.
9 Q Did you know Major Morris?
10 Q J states " determine capacity of waste neutral
10 A Mayor Morris.
11 system and design improved system if required." What does 11 Q I'm sorry, Mayor Morris.
12 a reference to a " waste neutral system " mean?
12 A 1 don't think 1 ever met him.
13 A That was part of the brine area. There was a
13 Q Number 4 states " The need for a long range
14 piece of equipment called the waste neutral tower. 1 don't
14 program on Anniston was pointed out to the mayor."
15 remember how that worked.
15 Do you see that?
16 Q What does the phrase " waste neutral," what does
16 A Yes.
17 that mean?
17 Q Do you recall being involved in the formulation
18 A It's a rather awkward set of words actually but
18 of any long-range program for waste treatment with regard
19 the intention was that the waste leaving the bottom of that
19 to the Niran plant?
20 tower would be neutral in ph, meaning it's neither acid nor
20 A No.
21 alkali.
21 Q Do you know who was -- strike that.
22 Q You said that system consisted of a tower?
22 Do you recall such a plan being developed?
Page 261
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1 A Yes.
1 A 1 don't know if there was such a plan.
2 Q Did it consist of anything else?
2 Q Down below, after the numbered paragraphs,
3 A There were some pumps and vacuum jets involved, 3 there's a sentence which reads " At a meeting with Jim
4 but 1 don't remember how that was all connected together.
4 Mullendore, Jim Savage and myself, the following program
5 Q What was sent to that system?
5 was set up for the waste treatment pilot lagoon." Do you
6 A The spent brine leaving the cells was saturated
6 see that?
7 with chlorine and that chlorine had to be removed before
7 A Yes.
8 the brine was further processed to resaturate it. And the
8 Q Do you recall being involved in discussions
9 chlorine was removed from the spent brine by placing the
9 concerning a waste treatment pilot lagoon?
10 brine under a vacuum while it passed down through a packed 10 A 1 don't recall the discussions. 1 remember the
11 tower. So coming from the top of that packed tower was a
11 pilot lagoon.
12 stream of wet chlorine gas and the waste neutral system was 12 Q What was the pilot lagoon?
13 provided to process that wet chlorine gas. Most of it
13 A That was one of the ideas that was tested as a
14 wound up back in the product chlorine. 1 don't remember
14 way of treating waste. Lagoon treatment is probably the
15 why, but for some reason there was some of it that had to
15 simplest way to treat wastes. The word describes what it
16 be scrubbed.
16 is and one relies on sufficient oxygen transfer from the
17 Q And the material that did not go back into the
17 atmosphere down into the surface of the lagoon to
18 process, where did that go?
18 accomplish a biochemical oxidation.
19 A That was neutralized in this tower called the
19 Q Do you recall what the impetus was for the
20 waste neutral tower with a small amount of caustic, and so
20 initiation of that waste treatment pilot lagoon?
21 it went to the sewer as sodium hypochlorite.
21 A Well, as 1 recall, we had decided that we would
22 Q Mercifully, I'm finished with that one. Can we
22 provide some treatment of the waste inside the plant and
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 260 - 263
HARTOLDMON0010167
Page 264
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1 this was a first test of one method.
1 that pilot plant and took samples and so forth to generate
2 ( Savage Exhibit 46 identified. )
2 data for Cliff Stutz so that he could design a full-sized
3 By Mr. Brock:
3 activated sludge unit.
4 Q I'm having marked as Exhibit 46 a one-page
4 Q Do you recall whether any lagoons were used for
5 document with the Bates number Ann 1211651 and it's a map 5 treatment of Niran wastes?
6 of the Anniston plant.
6 A Could be. It could be we had a lagoon for an
7 Mr. Savage, just by reference to what we've had
7 interim period or something but 1 don't remember that.
8 marked as Exhibit 46, 1 was wondering whether you could
8 Q You don't recall any being used on a more
9 indicate where that pilot lagoon -- the waste treatment
9 permanent basis?
10 pilot lagoon was set up?
10 A 1 remember the test lagoon and whether that
11 A At the time that we had a lagoon, the plant
11 was -- 1 don't know whether that was used on an extended
12 layout was a little different from this. This map seems to
12 basis or not.
13 be from a time after 1 left the plant. The way 1 remember
13 Q Do you recall whether lagoons were used for any
14 it, it would have been just to the northeast of the
14 wastes coming from the Aroclor department there?
15 rectangle with a line through the middle labeled " hold
15 A As far as 1 know that was never done.
16 tanks." So on the map it would be down and to the right a
16 Q What about the chlorine department?
17 little ways.
17 A There was no Bod from the chlorine department to
18 Q Can you indicate, just draw a circle or a square
18 treat.
19 or a box or something where that would have been and with 19 Q Are you familiar with lagoons being used for
20 an arrow, put waste treatment plant pilot lagoon?
20 wastes coming from any of the other departments at the
21 A 1 started to write --
21 Anniston plant?
22 Q That's fine.
22 A No.
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1 A --" test lagoon."
1 Q Down on the bottom of the first page of Exhibit
2 Q Testlagoon. And just for clarity of the record,
2 44, there's a reference to separating the strong from the
3 if you'd like, you can put late 1950s.
3 weak wastes. What do the references to " strong and weak
4 A Okay.
4 wastes " refer to?
5 Q Was a permanent lagoon set up?
5 A 1 don't know what he was specifically referring
6 A No. It was determined that a lagoon system would 6 to.
7 not be a satisfactory way of doing a treatment.
7 Q And there's some handwriting to the left of that
8 Q Why was it -- what was the reason for that
8 that says " Savage, do you " and there's another word that 1
9 determination?
9 can't read and is it" enough "?
10 A 1 think the original idea was that it might be a
10 A That's John Mullendore's writing and 1 think it
11 low cost way of achieving a significant reduction in Bod.
11 says " Savage, do you need another Mro " and Mro was a
12 The test data didn't support that so we had to do something 12 maintenance - or a minor repair order and it was simply a
13 more elaborate.
13 way of authorizing, spending some money for whatever 1
14 Q When you say" the test data didn't support that,"
14 needed to get done.
15 were the test data that it was expensive or that it didn't
15 Q And on the next page there's some handwriting
16 reduce Bod?
16 that also says " Jim Savage." Can you read that
17 A It didn't sufficiently reduce Bod.
17 handwriting?
18 Q Do you recall what steps were eventually taken?
18 A 1 think it says " Jim Savage, what samples require
19 A Yes. Right about this time, perhaps shortly
19 special sampling?"
20 after the period of these memos we began a study of the
20 Q Do you know what that refers to?
21 activated sludge process and a pilot-activated sludge unit
21 A No.
22 was erected right next to the hold tanks and 1 operated
22 Q Number two, it talks about routine sampling of
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 264 - 267
HARTOLDMONOOIOI68
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1 the lagoon wastes will be placed on a weekly basis. Do you 1 Q If you turn to page 3 up at the top, there's a
2 see that?
2 reference to a meeting with the city sewage treatment plant
3 A Yes.
3 superintendent. Do you know who that was?
4 Q Would " special sampling " be referring to
4 A 1 presume that refers to Mr. Standridge.
5 something other than or in addition to that?
5 Q Do you recall meeting with Mr. Standridge in or
6 A That's what the words mean, but 1 don't remember
6 about that time?
7 which of these samples might have been considered special. 7
A No.
8 Q What was the upper pond?
8 Q Do you know who would have been at that meeting?
9 A Well, as mentioned earlier in this same memo,
9 A No.
10 there was a partition placed through the lagoon, so this
10 Q Number two talks - it says " the plant was
11 must refer to the two parts of the lagoon as a pond. But 1
11 alerted regarding a change in the process in the
12 don't know why there would have been different samples from 12 manufacture of Niran."
13 the two parts.
13 Do you know what that change was?
14 Q So the upper pond and lower pond just refer to
14 A No, 1 don't remember.
15 different parts of the test lagoon?
15 Q Number three talks about the disposal of lime
16 A 1 think so.
16 sludge in the south hold tank. Do you know what the south
17 Q There are references to Pnp under the upper pond
17 hold tank was?
18 and lower pond and also on the previous page talking about 18 A 1 presume that refers to some part of a city
19 reduction of Pnp. What was Pnp?
19 treatment plant. 1 don't recall anything - well, 1 don't
20 A Paranitrophenol.
20 know. It may have been with the city treatment plant or
21 Q Was that used in the Niran operations at the
21 they might be referring to something at the Anniston plant
22 Anniston plant?
22 but 1 don't recall something called a hold tank.
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1 A Yes, it was one of the raw materials.
1 Q If you look back at Exhibit 46, the area where
2 Q Was that discharged in the aqueous wastes from
2 you marked the test pilot plant is in an area where you
3 the Niran department?
3 mentioned that there were dividing lines between the hold
4 A Yes.
4 tanks.
5 Q And there are references under the lower pond to
5 A Perhaps that's what it refers to.
6 nitrates and phosphates. Were those also raw materials in 6
Q Do you recall there being lime sludge from the
7 the Niran operations?
7 Niran operations?
8 A No. None of the raw materials were nitrates or
8 A Not from the Niran operation but the
9 phosphates.
9 neutralization pit used limestone and there would be a
10 Q Were those materials that were discharged?
10 sludge left from that. 1 don't recall if that sludge would
11 A 1 don't know. Those are things that they would
11 have necessarily been in the hold tank.
12 reasonably be analyzed for, but whether they were present, 12 Q Do you know what lime sludge, if any, would have
13 1 don't know.
13 been in the hold tanks?
14 Q Why would they be reasonably analyzed for with
14 A No.
15 respect to the Niran operations?
15 Q It says " the superintendent agreed to handle this
16 A Well, Cliff Stutz had a background in sanitary
16 through their sewers but would bypass the plant." Does
17 engineering and he would be interested in what nutrients
17 that refresh your recollection at all as to what the lime
18 were available for the organisms that were there and in
18 sludge was?
19 order to facilitate biological oxidation and nitrates and
19 A No, 1 don't remember this event at all.
20 phosphates would be not only potential pollutants but also
20 Q Do you know what that refers to, the reference to
21 nutrients for the organisms so it would be important to
21 the superintendent agreeing to handle it through their
22 know what quantities were present.
22 sewers but bypassing the plant?
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 268 - 271
HARTOLDMON0010169
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1 A Well, 1 could interpret that sentence but 1 don't
1 were for the next month or two or perhaps the next quarter.
2 know anything about it.
2 Q Do you recall making any such presentations
3 Q What would your interpretation of the sentence
3 concerning environmental or waste disposal matters?
4 be?
4 A I'm sure 1 did. 1 can't remember the subject
5 A That when that material arrived at the plant
5 matter of any of them in particular.
6 through the sewers, they would divert it around their
6 Q Linder Aroclors," the first program is revise
7 treatment plant.
7 design data for disposal of still residue." Do you see
8 Q And why would that have been done?
8 that?
9 A 1 don't know.
9 A Yes.
10 Q There's a reference down below to " the discharges 10 Q Do you recall that going on in or about 1959?
11 of sludge will be done after 10: 00 p. m. so that any odor
11 A No, 1 was involved in Aroclor at the time.
12 associated with the sludge will not be noticed."
12 Q The phrase " design " -- " revise design data," does
13 Do you recall that being done?
13 that refer to or -- strike that.
14 A No. There's no reason why 1 would know what was 14
What does that refer to?
15 being done at the city treatment plant.
15 Mr. Burnett: Object to the form of the
16 Q Do you interpret that to be discharge from the
16 question. Lack of foundation.
17 city treatment plant?
17 By Mr. Brock:
18 A Well, 1 can't add anything to the words that are
18 Q Do you know what that refers to?
19 in the paragraph.
19 A No.
20 Q Let's go to Exhibit 45. Again, can you identify
20 Q During your employment with Monsanto have you
21 what that is for us?
21 used the term" design data "?
22 A This is a memo from Bob Hedworth, which was the
22 A Sure.
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1 minutes of an engineering planning meeting held on February 1 Q When you've used the term, what have you used it
2 9, 1959.
2 to refer to?
3 Q And the arrow in the top right-hand corner
3 A Design data usually refers to the information
4 indicates that this was a copy that was sent to you ; is
4 needed to prepare a design ; design data becomes part of the
5 that correct?
5 design for a project.
6 A That's right.
6 Q Do you recall there being contemplations of
7 Q Who is J. H. Starr, S-t-a-r-r?
7 revisions in the way that still residues were to be
8 A Hugh Starr was at that time the supervisor of the
8 disposed of around that time?
9 Aroclor department.
9 A No.
10 Q Do you recall attending engineering planning
10 Q When you took -- or when the Aroclor department
11 meetings during that time?
11 came under your purview as production supervisor, were
12 A Yes. Those were -- something doesn't quite fit
12 there revisions going on to the way that Aroclor still
13 here for me because the people listed here are Pohl,
13 residues were disposed of?
14 Edelbut, Sprague and Hedworth and what 1 recall was that
14 A 1 just remember that we had the skip system in
15 the engineering planning meetings were held when there was 15 place. 1 don't remember that there were revisions made
16 a visitor from St. Louis who was responsible for the
16 during my time.
17 technical program at the Anniston plant and 1 don't see
17 Q Did you have discussions about revisions that had
18 such a person listed among those present so 1 don't quite
18 been made before you took on that department?
19 understand this.
19 A 1 don't remember.
20 Q When you attended engineering planning meetings, 20 Q And under the Niran department your name is
21 what did those meetings generally consist of?
21 referenced to the right?
22 A A series of presentations about what our plans
22 A Yes.
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 272 - 275
HARTOLDMON0010170
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1 Q Does that indicate to you that the matters
1 Mr. Brock: Off the record.
2 referenced for the Niran department were assigned to you? 2
( Discussion off the record. )
3 A Yes.
3 ( Savage Exhibit 47 identified. )
4 Q Do you recall doing a survey of the Niran
4 By Mr. Brock:
5 department?
5 Q I've marked as Exhibit 47 a two-page document
6 A Yes, that was routine.
6 dated April 7, 1970 with Bates numbers 0291924 and 25.
7 Q Do you recall what that consisted of?
7 Mr. Savage, is this a copy of a memo that you
8 A 1 would think the material balance that we
8 received in the ordinary course of your employment with
9 referred to earlier.
9 Monsanto in or about April of 1970?
10 Q How would you go about surveying the department
10 A Yes, it appears to be.
11 just as a matter of practice?
11 Q There's a category near the bottom of the first
12 A To determine for potential savings?
12 page regarding known losses to sewer in March. Do you see
13 Q Right.
13 that?
14 A The first step always was the material balance ;
14 A Yes.
15 after that, an analysis of the cost reports which would lay
15 Q Do you recall how that terminology was to come
16 out all the other elements of cost other than -- in
16 about?
17 addition to raw materials and from that try to determine
17 A 1 don't know why that expression was used. In
18 what costs could be reduced and whether it could be done in 18 this context it really refers to specific incidents that
19 a cost-effective way.
19 occurred during the month.
20 Q Do you recall looking into the cost-effectiveness
20 Q Why do you say that?
21 of the waste disposal methods used in the Niran department? 21 A Well, it just says " Department 243, 55 pounds
22 A No. 1 did some technical work in connection with
22 estimate. Department 251, 600 pounds estimated." There
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1 the eventual waste disposal plant that was installed, but 1
1 must have been a basis for such an estimate.
2 don't recall any opportunities for cost reduction. The
2 Q Do you know how it was determined whether
3 work was entirely on the question of making it as effective
3 something would be put under the known loss heading or
4 as possible.
4 category?
5 Q Do you recall what, if anything, you did with
5 A No.
6 respect to Pnp recovery and I'm referring to item 3?
6 Q The next page makes a reference to " the routine
7 A As 1 recall it, Pnp recovery was an idea that was
7 loss from Department 246 " and that's in the second
8 not implemented.
8 paragraph?
9 Q Why was that not implemented?
9 A Yes.
10 A 1 think we found ways to improve the once-through
10 Q Do you see that?
11 yield that reduced Pnp losses to the point that a recovery
11 A Yes.
12 project would not be economical.
12 Q Do you know what the reference to " routine loss
13 Q The Pnp losses that you referred to, what did
13 from Department 246 " refers to?
14 those consist of? Were they aqueous, were they solids?
14 A From the context, it refers to the continuing
15 A Entirely aqueous.
15 loss from the department that was being experienced.
16 Q Did they go to the sewers?
16 Q And in your understanding that was from the
17 A Yes.
17 normal operations of the department?
18 Q Do you recall what, if anything, did you do with
18 A Yes.
19 respect to following excess P2s5 demonstration?
19 Q That sentence talks about a reduction of the
20 A Well, we carried out the demonstration. 1 don't
20 routine loss by installing a drain line from the vapor
21 remember whether that process change was permanently
21 header immediately upstream from the drowning jet.
22 adopted or not.
22 Can you just describe for me - or explain to me
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 276 - 279
HARTOLDMON0010171
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1 what that's referring to?
1 A 1 think 1 mentioned yesterday the plant is very
2 A I'm not sure 1 can explain it all because 1 don't
2 old, and the sewer system has been repaired, and additions
3 remember well enough. The drowning jet would have been a 3 have been made to it several times during the life of the
4 scrubbing jet that -- a water scrubber, handling air from
4 plant, and therefore it's fairly complicated. Some parts
5 the blow tanks. As to the rest of the statement, 1 can't
5 of it are quite old and that made it difficult to carry out
6 add anything to what the sentence says, that it was " a
6 our sampling program in such a way as we could determine
7 drain line installed from the vapor header."
7 the origins of the Pcbs in the waste.
8 Q Where it says " any liquid in this header is
8 This paragraph refers to a facet of that, but 1
9 caught in a drum and was taken to the dump." Do you know 9 don't remember that particular facet.
10 what that liquid would have consisted of?
10 Q Do you recall there being an investigation into
11 A It would have consisted of biphenyl and lightly
11 the reason for the sewer problems?
12 chlorinated biphenyl.
12 A No, 1 wasn't involved in that.
13 Q Do you know when the procedure was set up of
13 Q Down below that it says " a major project is being
14 taking that to the dump?
14 prepared to replace the sewer system in the area." Do you
15 A No.
15 see that?
16 Q Were you familiar with that during your --strike
16 A Yes.
17 that.
17 Q Are you familiar with a major project being
18
Do you know whether that was in place during the
18 undertaken to replace the sewer system in the area?
19 time you were at the Krummrich plant?
19 A 1 remember there was a sewer project, but 1 don't
20 A This report says it had been installed presumably
20 remember how big it was or exactly what the purpose was.
21 in the month it's being reported on.
21 Q Do you recall the sewers from the Aroclor
22 ( Savage Exhibit 48 identified. )
22 operations being replaced?
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1 Mr. Brock: 1 have marked as Exhibit 48 a
1 A No.
2 memorandum dated November 2, 1971.
2 Q Who would have been involved in that replacement
3 By Mr. Brock:
3 of the sewers?
4 Q Mr. Savage, is this a memorandum that was sent to 4 A Well, the maintenance department certainly, and
5 you in the ordinary course of your employment with
5 probably the utilities department.
6 Monsanto?
6 Q Do you recall discussing replacement of the
7 A Yes.
7 sewers with anybody from the maintenance department or the
8 Q If you look in the second paragraph under the
8 utilities department?
9 letter A, it states " it was discovered that the underground
9 A No.
10 sewer system and sewer boxes in area are leaking very
10 Q Was there somebody within the maintenance
11 badly." Do you see that?
11 department or utilities department with specific
12 A Yes.
12 responsibilities regarding the sewers?
13 Q And up above that in the very first paragraph in
13 A Well, that would be normal in terms of the way a
14 the text under the heading, it talks about" Aroclor sewer
14 plant is organized but 1 don't know who it would be.
15 loss." Do you see that?
15 Q If 1 could turn you to page 3 of the exhibit
16 A Yes.
16 under" program status." It states " Pcb task force formed
17 Q Do you recall it being discovered that the
17 with members of production, maintenance, Tsd and the
18 underground sewer system and sewer boxes from the Aroclor 18 environmental group." Do you see that?
19 operations were leaking very badly?
19 A Yes.
20 A 1 remember there were sewer problems but 1 don't
20 Q Do you recall there being a Pcb task force
21 remember any more than that.
21 formed?
22 Q What do you recall about the sewer problems?
22 A Not specifically.
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 280 - 283
HARTOLDMON0010172
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1 Q Do you recall being a member of any Pcb task
1 you see that reference?
2 force?
2 A That's right.
3 A That's a little bit -- I'm stuck a little bit on
3 Q And 1 neglected to ask you this on the previous
4 semantics. Of course 1 was working on Pcb matters as part 4 document. There's a reference to cross flow between the
5 of the business group team, but 1 don't remember whether
5 sewer system and the underground water being possible.
6 any group that 1 was involved with was called a task force.
6 What does that refer to?
7 Q To me that just indicates that a separate entity,
7 A Well, it's a logical consequence of the leaks
8 some sort of group was set up at this time, is that how you
8 that are described there. As 1 mentioned before, 1 don't
9 would --
9 specifically remember leakage of these sewers per se as
10 A Yes, but based at the plant. And 1 was not at
10 being a specific problem.
11 the plant at that time.
11 Q 1 would interpret the reference to cross flow
12 Q Do you recall dealing with any entity that was
12 meaning -- to refer to mixing of the water or the materials
13 referred to in words or substance as a Pcb task force at
13 in the sewer with the materials in the underground water,
14 the Krummrich plant?
14 would that be a fair interpretation?
15 A No, normally 1 had one contact at each plant that
15 A 1 would interpret it the same way. But 1 just
16 1 would talk to about this sort of thing. Atthis
16 don't remember the incident.
17 particular time, it was Ed Stewart.
17 Q Does that refresh your recollection at all as
18 Q If you turn to the last page of the exhibit.
18 to -- strike that.
19 There's a reference, it says " Fr2 will be sent to the
19 Do you recall there being an investigation as to
20 Wgk plant for incineration." Do you see that?
20 whether or not there was such a cross flow or mixture?
21 Oh, you must have a different last page.
21 A No.
22 ( Discussion off the record. )
22 Q Do you know whether it was determined whether or
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1 By Mr. Brock:
1 not there was -- because this makes a reference that such a
2 Q Or do you recall something called Fr2?
2 cross flow being possible. Do you recall whether it was
3 A Fr2 is the name of one grade ofTherminol.
3 determined whether in fact such a cross flow had been
4 Q Do you recall that being sent to the incinerator
4 taking place or not?
5 at the Krummrich plant?
5 A No. This is the sort of problem 1 would have
6 A 1 remember that some Therminol was sent to the
6 expected the plant to deal with.
7 incinerator. 1 don't remember anything specific about Fr2.
7 Q On the second page of Exhibit 49, this again
8 Q Do you know whether anything was done with Fr2
8 talks about, under entry of 2429, that again talks about a
9 other than sent -- well, Therminol residues other than
9 major sewer to be installed to north. Do you know whether
10 being sent to the incinerator?
10 that refers to the same project or a different project from
11 A No.
11 the sewer replacement project being referenced on the
12 ( Savage Exhibit 49 identified. )
12 previous page?
13 Mr. Brock: Exhibit 49 is a memorandum dated
13 A 1 don't know. It sounds different but 1 don't
14 November 5, 1971 with Bates numbers 0248547 through 50. 14 know.
15 By Mr. Brock:
15 Q Do you recall whether there were any types of
16 Q Mr. Savage, is this a memorandum in which you
16 leaks or leakage discovered with respect to the -- a sewer
17 transmitted the information in Exhibit 48 to Mr. Papageorge
17 going to the north from the Aroclor operations?
18 along with some other information?
18 A No.
19 A Yes.
19 ( Savage Exhibit 50 identified. )
20 Q This also makes a reference to the discovery that
20
By Mr. Brock:
21 the underground sewer system and sewer boxes in the area 21 Q Exhibit 50 is dated July 2, 1971.
22 were leaking very badly, and that's on the first page. Do
22
Mr. Savage, is this a memorandum that you
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 284 - 287
HARTOLDMON0010173
Page 288
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1 received from Mr. Stewart in the ordinary course of your
1 A 1 don't know. Even in 1971 1 was speculating.
2 employment at Monsanto?
2 So I'd have to speculate further now.
3 A Yes.
3 Q Do you know was there an investigation to
4 Q B talks about" plant exit losses as measured from
4 determine whether or not any rise in the amount of Aroclor
5 the 24 - and 30-inch plant sewers." Are you familiar with
5 losses from the Anniston plant could be attributed to high
6 those sewers?
6 levels of rain?
7 A No.
7 A 1 don't remember that kind of investigation.
8 Q Are you familiar with there being two separate
8 Q The next page makes a reference to a " Montar draw
9 sewer systems going from the Aroclor department?
9 outline." Do you know what that was?
10 A No.
10 A 1 don't remember the incident. Montar was the
11 Q If you turn to the next page under" program
11 name given to Aroclor still residue when it was sold.
12 status," it talks about a discrepancy between plant exit
12 Q Do you know what the draw outline was?
13 and treatment plant influent. Do you see that?
13 A Well, 1 can infer from the words that it was a
14 A Yes.
14 line used to remove Montar from the still, but 1 don't know
15 Q Do you recall there being such a discrepancy in
15 that for sure.
16 the sampling results around that time?
16 Q Do you recall any times during which the line
17 A Not specifically but it's part of a general
17 used to remove Montar from the still was unplugged?
18 pattern that we had difficulty in getting good
18 A Montar was a fairly high-melting solid, so 1
19 measurements.
19 would presume that it had to be unplugged every time it was
20 Q Do you recall what was done to correct that
20 used.
21 situation?
21 Q Do you know what the department sump pit was, the
22 A Mainly it was a matter of finding more precise
22 Aroclor department sump pit?
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1 sampling methods. We were eventually successful in doing 1 A At some point we installed a kind of interceptor
2 that.
2 pit in the department sewer in the Aroclor department as a
3 Q When you say that, is that the project you talked
3 way of being sure that any spill did not leave the
4 about yesterday involving placing the sampling devices into 4 department.
5 streams and with certain steps being taken?
5 Q Do you know when that was put in place?
6 A Yes, that was the sample project. We were taking
6 A No, 1 don't remember.
7 samples in a number of different places and fighting
7 Q Was that in place during your tenure at the
8 similar problems in each one of those places.
8 Anniston plant?
9 ( Savage Exhibit 51 identified. )
9 A No, it was installed during the time 1 was
10 By Mr. Brock:
10 manufacturing manager.
11 Q Exhibit 51 is dated August 5, 1971.
11 Q Was there an awareness in connection with the
12
Mr. Savage, is this a memorandum that you sent to
12 installation of that, in the past, Aroclors had been
13 Mr. Papageorge in the course of your employment?
13 leaving the department?
14 A Yes.
14 A Well, by that time, we knew it from analytical
15 Q At the bottom of the second page of the
15 results, but it's my recollection that the purpose of the
16 memorandum under the heading for the Anniston plant, it
16 pit was really just extra insurance so that if we did have
17 states " The month of July had an unusual amount of
17 a spill, we could be better assured that that spill would
18 intermittent rain which may have caused a normal flow to go 18 not leave the plant.
19 above 1.0 pounds per day." Do you see that?
19 Q Do you recall there being any investigation or
20 A Yes.
20 study with respect to when Aroclors - strike that.
21 Q Why would rain cause the Aroclor losses from the
21
Do you recall there being an investigation or
22 Anniston plant to rise?
22 study in connection with the Anniston plant addressing a
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 288 - 291
HARTOLDMON0010174
Page 292 1 subject of how much Aroclor may have been lost from the 2 Aroclor operations there during different years or
1 2
Page 294 A No.
( Savage Exhibits 53 and 54 identified. )
3 different periods of time? 4 A No. 5 Q Sort of an historical -- 6 A 1 don't know how that could have been done 7 retrospectively. 8 ( Savage Exhibit 52 identified. ) 9 By Mr. Brock: 10 Q Exhibit 52 is a memorandum dated November 30, 11 1971. It has Bates numbers of 0134909 and 910. 12 Mr. Savage, is this a memorandum from Gerald 13 Bratsch to F. J. Holzapfel that you received in the ordinary 14 course of your employment with Monsanto? 15 A Yes. 16 Q Do you know what prompted this report from -- to 17 Mr. Holzapfel? 18 A No. It's a little unusual since Gerry Bratsch 19 was the plant manager. Fred Holzapfel was his boss. 20 Q Do you have an understanding as to the background 21 of this unusual type of report being called for or being 22 done?
3 Mr. Brock: Exhibit 53 is a memorandum dated 4 December 2, 1971, has Bates numbers 0248542 through 546. 5 Number 54 is dated December 8, 1971 with Bates numbers 6 0008737 through 740. 7 By Mr. Brock: 8 Q Mr. Savage, is Exhibit 53 a memorandum that was 9 sent to you in the ordinary course of your employment with 10 Monsanto? 11 A Yes. 12 Q And in 54 you transmitted that information along 13 with some other information to Mr. Papageorge ; is that 14 correct? 15 A Yes. 16 Q That's your handwriting on Exhibit 53? 17 A Yes. 18 Q It looks to me -- the second paragraph on 19 Exhibit 53, there's some lines through that? 20 A Yes. 21 Q That doesn't - that language doesn't appear in 22 your transmission to Mr. Papageorge. Do you know why you
Page 293
Page 295
1 A From the first paragraph, obviously Fred had
1 took that out?
2 asked for it, but 1 don't know why he asked for it.
2 A That would have been just part of my normal
3 Q In the bottom paragraph of the first page, the
3 editing process.
4 last sentence starts " work continues through Art's group
4 Q In the indented paragraph on the first page of
5 and the environmental control group. Sewer rats to pin
5 Exhibit 53 there's a statement" higher losses were evident
6 down sources as well as develop more reliable sewer
6 early in the month when major sewer failures in the
7 samples." Do you see that?
7 department were discovered and subsequently partially
8 A Yes.
8 repaired." Do you see that?
9 Q Were you familiar with the term " sewer rats "?
9 A Yes.
10 A No. Perhaps Gerry just made it up.
10 Q It goes on to say " additional measures, sewer
11 Q Had you ever heard that term used in connection
11 repairs are needed and should be expedited in December."
12 with the Pcb investigations at the Krummrich plant?
12 Do you see that?
13 A Not that 1 remember.
13 A Yes.
14 Q Do you recall anybody having responsibility for
14 Q And that information is submitted to
15 going down into the sewers and investigating what was going 15 Mr. Papageorge in Exhibit 54?
16 on there?
16 A Yes.
17 A No.
17 Q Does that refresh your recollection as to major
18 Q Do you recall Mr. Holzapfel or Mr. Bratsch asking
18 sewer failures being discovered in the Aroclor sewers
19 for a more overall investigation of what was going on with
19 around that time?
20 respect to the Pcb contamination, investigations and
20 A No.
21 actions in addition to the reports that you were submitting
21 Q Does that refresh your recollection as to any of
22 to Papageorge?
22 the repair work that was done?
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 292 - 295
HARTOLDMON0010175
Page 296
Page 298
1 A No, that kind of problem could be handled by the
1 see that?
2 plant. There's no reason why 1 would have any interest
2 A Yes.
3 other than that they did it.
3 Q 1 should have noted that earlier. Does that
4 Q On the second page of Exhibit 53 under the first
4 refresh your recollection as to a cross flow being found in
5 heading it says on 11/26," a known cross flow between the 5 fact between the sewer water and the underground water?
6 main sewer was corrected so that the individual sewer
6 A That paragraph appears to refer to a different
7 results are reflected on the source." Do you see that?
7 situation than the one on the subsequent paragraph. One
8 A Yes.
8 seems to make it more clear that in the second entry, the
9 Q Does that refresh your recollection as to there
9 one we discussed earlier, that that does refer to something
10 in fact being a cross flow discovered between the various
10 other than cross flow between sewer water and underground
11 sewers?
11 water.
12 A It's consistent with my recollection that the
12 Q Does that refresh your recollection at all as to
13 sewer system was complicated and it was therefore difficult 13 cross flow between -
14 to understand the analytical results in the early days, and
14 A No.
15 this represents some progress on that problem.
15 Q But do you know what modifications were done to
16 Q Do you interpret that reference to mean cross
16 the sewers in Department 246?
17 flows between different sewers?
17 A No.
18 A Yes.
18 Q And the next reference is to " upgrade sewer in
19 Q I'm drawing a distinction between that kind of
19 Second Street." Do you know what was done along those
20 cross flow and the cross flow, the possible cross flow that
20 lines?
21 was referenced in the earlier document between sewers and 21 A No.
22 the underground water.
22 Mr. Brock: Off the record.
Page 297
Page 299
1 A The sentence is defective in that it says" a
1 ( Discussion off the record. )
2 known cross flow between the main sewer" and it doesn't say
2
( Savage Exhibits 55 and 56 identified. )
3 between that and what else, but 1 would interpret this to
3 By Mr. Brock:
4 mean a cross flow between one sewer and another one.
4 Q Exhibit 55 is dated January 4, 1972. Bates
5 Q Does that refresh your recollection at all as to
5 numbers 0248700 through 702. Exhibit 56 is dated January
6 whether a cross flow between the sewers and the underground
6 13, 1972 with Bates numbers 0008693 through 696.
7 water was ever discovered?
7 Mr. Savage, is Exhibit 65 a January 4, 1972
8 A No.
8 memorandum that you received in the course of your
9 Q On the third page of Exhibit 53 under the program
9 employment with Monsanto?
10 status, there's again a reference to the Pcb task force,
10 A Yes.
11 and it says it's meeting biweekly. Do you see that?
11 Q And in Exhibit 56 you transmitted that
12 A Yes.
12 information along with some other information to
13 Q Does that refresh your recollection as to any
13 Mr. Papageorge ; correct?
14 contacts you may have had with the Pcb task force?
14 A Yes.
15 A No.
15 Q And at the bottom of the first page of Exhibit
16 Q Let's stay on this page up above that, and under
16 55, the January 4, 1972 memorandum, there's a reference
17 the estimate number 3438, the first entry is " modify sewers
17 again to extensive sewer repair work, the progress in the
18 in Department 246." Do you see that?
18 department to better control Pcb losses within the system.
19 A Yes.
19 Does that refresh your recollection as to any such repair
20 Q And that states " altered and repaired
20 work being done?
21 departmental sewer system to eliminate cross flow of sewer
21 A No.
22 water and underground water within the department." Do you
22 Q If you go to the next page, entry number 1.
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 296 - 299
HARTOLDMON0010176
Page 300 1 A Yes. 2 Q It talks about" diversion of the sewer streams 3 from the Aroclor department such that all department flow 4 was directed to the north and not permitted to flow into 5 the internal plant sewer system which exits at the 24-inch 6 and 36-inch sewers." Do you see that? 7 A Yes. 8 Q Can you explain to me what that means? 9 A No, I can't add anything to what it says there. 10 Obviously, they were doing some kind of a test to try to 11 analyze the sewer flows, but I don't recall any further 12 detail about it. 13 Q And does that refresh your recollection as to 14 what the sewer directed to the north was? 15 A No. 16 Q Let'sgo to the Exhibit 56, page 3 of that. 17 Under the heading for the Anniston plant where it says " the 18 total Aroclor losses " -- or it gives figures for them and 19 then it says " the Aroclor losses " - it makes reference to 20 them being reported to the Epa and the state of Alabama. 21 Do you see that? 22 A Yes.
Page 302 1 A As far as I remember there was no difference. 2 Q Do you recall there being any discussions about 3 whether to report these matters to Monsanto's insurance 4 companies? 5 A I have no idea. There's no reason why I would 6 have been involved in that. 7 ( Whereupon, at 12: 50 p. m. , the deposition was 8 recessed, to be reconvened at 2: 00 p. m. this same day. )
Page 301
Page 303
1 Q Do you recall the reasons that those Aroclor
1
Afternoon Session
(2: 05 p. m. )
2 losses from the Anniston plant were reported to the Epa and 2 Whereupon,
3 the state?
3 James R. Savage
4 A They had aparticular methodology that they
4 resumed the stand and, having been previously duly sworn,
5 specified relating to certain of the individual homologues
5 was examined and testified further as follows:
6 in Aroclor; that is, the particular chemical species in
6
Examination ( Continued )
7 Aroclor. That methodology gave different numbers than what 7
( Savage Exhibits 57 through 84
8 we would have defined as total Pcbs, total Aroclor.
8
identified. )
9 Q When you say" they specified," who do you mean? 9
By Mr. Brock:
10 A Epa.
10 Q During the lunch break, I had a number of
11 Q Do you know whether the results of the Pcb
11 exhibits marked. And the first is Exhibit 57, which I
12 testing at the Krummrich plant were reported to the state?
12 meant to give to you earlier, actually. We couldn't find
13 A No, I don't know.
13 it at the time. For the record, the Bates numbers are
14 Q What about the Epa? I meant toinclude that.
14 Ann 1539108 and 109.
15 A Well, I presume that anything we did with the
15 Mr. Savage, is this a memorandum that you
16 federal Epa with respect to the Anniston plant would have
16 received in the course of your employment with Monsanto?
17 also been done for the Krummrich plant, but I don't
17 A It appears to be, but it's incomplete. I only
18 remember specifically how that reporting was done.
18 have one page of it here. There must be a second page.
19 Q Do you recall whether there were any discussions
19
Mr. Burnett: My copy has two pages.
20 concerning whether the testing done at Krummrich should be 20
( Discussion off the record. )
21 handled differently from the testing done at Anniston with
21
The Witness: Yes, this is a memo from John
22 respect to reporting to the governmental agencies?
22 Mullendore.
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 300 - 303
HARTOLDMON0010177
Page 304
1 By Mr. Brock:
1 responsibilities at that time?
2 Q In the second paragraph it references a call from
2 A That's right.
Page 306
3 Jim Standridge and it says he asked " what is Monsanto doing 3
Q At the bottom of the second page, the last two
4 to us. The mayor has received numerous calls on the odor 4 sentences, it states " To prevent a recurrence, these solids
5 at the treatment plant. More lawsuits will be filed." Do
5 should be sent to the sewer gradually over an extended
6 you see that?
6 period of time at a rate that will not cause objectionable
7 A Yes.
7 odors at the treatment plant. The method for doing this
8 Q Are you aware of any lawsuits that have been
8 will be discussed with Savage and Studz during the latter's
9 filed concerning odor at the waste treatment plant, other
9 visit of January 6."
10 than the lawsuit you mentioned yesterday about the damage 10
Do you recall addressing or discussing that
11 to the paint on people's houses?
11 subject-
12 A No, I'm not aware of any lawsuit like that.
12 A No.
13 That's, again, not something 1 would have known about
13 Q - around this time frame?
14 necessarily.
14 A No.
15 Q Down below there's a paragraph " 1 picked up Jim
15 Q Do you recall addressing that subject -- strike
16 Savage on the way to the treatment plant since the
16 that.
17 complaint sounded serious and this was the first one we had 17
Addressing around this time frame the subject of
18 received in several months." Do you see that?
18 how best to eliminate odors from the waste treatment plant?
19 A Yes.
19 A No.
20 Q First of all, do you recall receiving complaints
20 Q Let's go to Exhibit 58. Is this a January 1972
21 about the odors from the treatment plant at or about this
21 memorandum, a copy of which you received in connection with
22 time?
22 your employment with Monsanto?
Page 305
Page 307
1 A No, 1 don't remember this incident.
1 A Yes.
2 Q Whether or not you remember this specific
2 Q It starts with the comment" We have reviewed the
3 incident, do you recall as a general matter there being
3 existing sampling system to control Pcb losses within the
4 complaints about the odors from the waste treatment plant
4 plant and to provide historical data related to the
5 during your early years at the Anniston plant?
5 effectiveness of the Pcb control program." Do you see
6 A 1 don't remember anything specific about odors at
6 that?
7 the treatment plant.
7 A Yes.
8 Q The statement" this was the first one we had
8 Q Do you recall there being an effort to go back
9 received in several months," do you recall there being
9 and provide historical data concerning the effectiveness of
10 complaints typically within the space of several months of
10 the Pcb control program?
11 each other concerning -
11 A This is written in 1972. To my knowledge the Pcb
12 A No.
12 program, the control program had been in effect for perhaps
13 Q Do you recall discussing with Mr. Mullendore or
13 three years at the most. So historical would have only
14 Mr. Standridge or Mr. Edelblut the subject of whether
14 been within that context.
15 lawsuits were likely to be filed concerning odor at the
15 Q Do you recall any effort to go back and provide
16 waste treatment plant?
16 historical data with respect to Pcb emissions dating back
17 A No.
17 further than that?
18 Q Was there someone at the Anniston plant who would 18 A No.
19 have been responsible for helping put together Monsanto's
19 Q Do you recall any discussions about whether or
20 response with respect to any such lawsuits?
20 not there should be an effort made to investigate further
21 A 1 don't know.
21 back than that?
22 Q 1 take it that was not one of your
22 A No.
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 304 - 307
HARTOLDMON0010178
Page 308
Page 310
1 Q Do you have an understanding as to why this was
1 A Yes.
2 sent to Art Leisy?
2 Q Were variations like that something that would
3 A 1 think Art Leisy was the production
3 have caught your attention during that time?
4 superintendent at that time. I'm not sure, but 1 think so.
4 A It does seem anomalous. 1 don't remember this
5 Q I'm curious because it seems that a lot of the
5 particular occasion, but it's the kind of thing that would
6 memos have been from Engman and Stewart to you, and you 6 have caught my attention at the time.
7 forward the information to Papageorge.
7 Q Do you recall there being variations like that or
8 A That's right.
8 of that magnitude?
9 Q This seems to be a separate -- at least a
9 A Yes.
10 separate direction and I'm curious as to why this -- do you
10 Q Do you recall investigations into the reasons for
11 have an understanding as to why this type of information
11 that, for such variations other than addressing sampling
12 would have been sent to Leisy rather than to you and
12 accuracy?
13 Papageorge?
13 A We would always attempt to investigate the reason
14 A No, 1 don't.
14 for the variation, and sometimes it would be due to some
15 Q Let's go to Exhibit 59 which is dated February 2,
15 abnormal condition in the plant.
16 1972. And, again, is this a memo to you that you received
16 Q The next paragraph states that higher than normal
17 in the course of your employment with Monsanto?
17 losses from the department are attributed primarily to two
18 A Yes.
18 causes. And the first, it says " Aroclor 1105 was produced
19 Q Linder the letter -- the indented paragraph
19 until 2/7 and during this period all of the off gas was
20 lettered A there's a reference to " discontinuance of
20 sewered." How would that result in higher than normal
21 routine sampling from the Aroclor department." Do you see 21 losses of Aroclor from the department?
22 that?
22 A Because the off gas contained some Pcb, and
Page 309
Page 311
1 A Yes.
1 normally that did not go to the sewer.
2 Q Do you recall sampling being discontinued from
2 Q Was the production of Aroclor 1105 discontinued?
3 that department in or around this time frame?
3 A Aroclor 1105 was not a routine product. There
4 A No, but this entire paragraph is consistent with
4 were a couple of unusual materials that were made on a test
5 what I've said before, that we discovered our sampling --
5 basis during this period, 1105 being one of them. And in
6 our sample gathering systems were not as effective as they 6 each case, it was a special run to produce test quantities
7 should be. We eventually changed to more effective
7 of a different product. As far as 1 know, neither of those
8 methods.
8 became regular products, but 1 don't know whether there was
9 Q Was there any reason that you recall for the
9 ever another 1105 run after this one or not.
10 discontinuance of the sampling besides sampling accuracy? 10 Q Later it states " also during the period 2/7 and
11 A No.
11 2/19 excess off gas was sewered at Department 246 area."
12 Q Was there a time during which samples were not
12 What does that refer to, specifically the -- strike that.
13 taken?
13 Do you have an understanding as to why excess off
14 A 1 don't remember that there was. There may have
14 gas would have been sewered from that area?
15 been.
15 A Well, the implication of excess is that more off
16 Q Let's go to Exhibit 60 and start off with -- is
16 gas was being produced than could be consumed in the using
17 it a March 3, 1972 memorandum that you received in the
17 department, so it had to go somewhere.
18 course of your employment with Monsanto?
18 Q Was that a frequent occurrence?
19 A Yes.
19 A No, at this time 1 don't think it was frequent at
20 Q The first paragraph contains a reference stating
20 all.
21 that" The February losses from the plant were about 3-1/2
21 Q Do you have an understanding or belief as to how
22 times greater than the previous month." Do you see that? 22 often that would take place?
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 308 - 311
HARTOLDMON0010179
Page 312 1 A My recollection is that it was rare by this time, 2 but 1 can't quantify that.
Page 314 1 Q Do you know whether it was ever determined when 2 those materials had leached or may have leached from the
3 Q When you say" rare," would it have been more than 4 once a year or less than once a year? I'm just trying to 5 put some general parameters on it. 6 A Certainly less than once a month, but perhaps 7 more than once a year. 8 Q Let's go to Exhibit 61. Is that an April 4 -- it 9 appears to be 1972. Well, is this a memorandum that was 10 directed to you during the course of your employment with 11 Monsanto? 12 A Yes. 13 Q Can you read the second indented paragraph to 14 yourself and let me know when you've had a chance to do 15 that. 16 A The one beginning " routine pollution control"? 17 Q That's right, yes. 18 ( Witness reviewed the document. ) 19 A Okay. 20 Q There's a reference to an emission investigation, 21 and that's in quotes and it's also capitalized. Do you see 22 that?
3 adjacent ground area? 4 A No. 5 Q The term " leach," did you understand that to 6 relate to a more gradual process than - do you have an 7 understanding that that relates to a gradual process? 8 Mr. Burnett: 1 object to the form of the 9 question. Vague. Go ahead. You can answer it if you can. 10 The Witness: The term " leaching " is a common 11 term in chemical engineering which usually refers to 12 contact of a liquid with a solid during which some material 13 is dissolved out of the solid into the liquid. If leaching 14 is carried out as a deliberate process, it might be pretty 15 rapid, but leaching from the ground might also be fairly 16 slow. 17 By Mr. Brock: 18 Q You don't have -- do you have any reason to 19 believe this was carried out as a deliberate process? 20 A No. 21 Q And the leaching from a normal -- or from a 22 natural process would typically be slower than deliberate
Page 313
Page 315
1 A Yes.
1 leaching?
2 Q Was that a particular term that was used within
2 A No.
3 Monsanto?
3 Q It would depend upon how fast they wanted the
4 A 1 think it's analogous to an accident
4 deliberate leaching to take place ; right?
5 investigation, but 1 don't remember the term specifically.
5 A It would depend on a lot of physical parameters.
6 Q Do you recall there being excavations in the new
6 Temperatures and concentrations and so forth.
7 Pna area around that time?
7 Q Do you know what the adjacent ground area around
8 A 1 remember that there was construction to build a
8 the Pna area, the new Pna area consisted of?
9 new Pna plant, which construction would normally include
9 A It's my recollection that the new Pna department
10 excavation.
10 was built in an area fairly remote from the Aroclor
11 Q Did you have any responsibilities relating to the
11 department, but since 1 was not directly involved in the
12 construction of the new Pna plant?
12 project, 1 can't pinpoint the place.
13 A No.
13 Q Let's go to Exhibit 62. Again, is this a
14 Q There's a statement" these waters contain Pcb
14 memorandum, a copy of which was directed to you during the
15 leached from the adjacent ground area." Do you see that? 15 course of your employment with Monsanto?
16 A Yes.
16 A Yes.
17 Q Do you recall there being any investigation into
17 Q For the record, the date on it is April 6, 1972.
18 how those Pcbs had leached from the adjacent ground area? 18
Can you read the first paragraph to yourself, and
19 A No.
19 let me know when you've had a chance to do that.
20 Q Did you have an understanding as to how those
20 ( Witness reviewed the document. )
21 Pcbs had leached from the adjacent ground area?
21 A Okay.
22 A 1 don't remember anything about it.
22 Q Do you recall there being a discussion or concern
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 312-315
HARTOLDMONOOIOI8O
Page 316
Page 318
1 about the subject of the Office of Science and Technology,
1 A 1 think there's a substantial amount of
2 perhaps recommending that Pcb levels and effluent streams
2 speculation on Ed's part in this statement. 1 have no idea
3 be virtually reduced to zero?
3 how he arrived at that number. The general idea that there
4 A My recollection is more vague and general than
4 might be residual Pcb in the soils that would continue to
5 that. 1 don't have any recollection about what part of the
5 be leached into the sewers for a period of time was no
6 federal government would be making new recommendations or
6 particular surprise, but 1 don't know how that could have
7 what specific targets it would recommend, but 1 do remember
7 been quantified.
8 increasing the likelihood of federal regulation.
8 Q Why do you say that was no particular surprise?
9 Q Do you recall being aware of the possibility
9 A Because in our analytical program, we had by this
10 that - or the concern that the federal government would
10 time determined that the amount from assignable sources was
11 recommend that Pcb levels in streams be reduced virtually
11 smaller than the total amount leaving the plant.
12 to zero?
12 Q Do you know what the ratio was generally?
13 A 1 think we expected very low - that very low
13 A No, 1 don't remember.
14 levels would be tolerable, and the numbers were not of
14 Q And again, page 4 of this, the page with the
15 great significance to the actions that we were taking at
15 number 4, again makes a reference to measure repair to main
16 the time because we were doing everything we could to
16 sewer from department to eliminate cross flow of
17 eliminate every loss we could identify.
17 groundwater. And again, does that refresh your
18 Q Why did you expect the numbers to be very low?
18 recollection at all as to that type of repair being done or
19 A There appeared to be a strong public concern and
19 that type of cross flow existing?
20 a concern in the federal government about Pcbs, and we
20 A No, 1 don't remember it.
21 simply expected that we would have to meet various
21 Q Let's go to Exhibit 63. Is this a memorandum
22 difficult targets.
22 that was directed to you during the course of your
Page 317
Page 319
1 Q Was there discussion about what would happen if
1 employment with Monsanto?
2 the standards were set very low and Monsanto wouldn't be 2 A A copy of it was directed to me.
3 able to reach those standards?
3 Q I've seen a lot of references to this document
4 A 1 don't know that we spent a lot of time
4 and in documents dated later. Do you recall this report
5 concerning ourselves as to exactly what sanctions would be 5 from Engman to Bratsch being considered a significant event
6 levied against us. We simply felt that we had to do the
6 at the Krummrich plant?
7 best we can because we could expect very strict
7 Mr. Burnett: Object to the form of the
8 regulations.
8 question.
9 Q Do you recall whether the subject of the
9 Go ahead.
10 possibility of a lawsuit or lawsuits was ever discussed in
10 The Witness: This just seems to be another step
11 that regard?
11 in the program which several projects are summarized in the
12 A No, not specifically. 1 think our feeling was
12 attachment.
13 that we could expect strong regulation and that if we
13 By Mr. Brock:
14 wanted to stay in business, we should simply do everything 14 Q Do you recall the plant manager making a request
15 that we could.
15 to be -- a request for there to be such a summary of all
16 Q On page 2 at the very top there's a statement" it
16 the Pcb-related projects?
17 is conceivable and highly probable that residual Pcb in
17 A No, but it's part of the plant that he was
18 Wgk's soil and sewers will continue to be leached for
18 responsible for so it's not unreasonable that he would ask
19 months to come. This amount could approach a daily average 19 for such a report.
20 of five pounds per day." Do you see that?
20 Q Let's go to the attached chart, the categories of
21 A Yes.
21 sources, sources of loss. Did you consider those to be
22 Q Was that your understanding at the time?
22 routine losses from the Aroclor department during that
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 316-319
HARTOLDMON0010181
Page 320
Page 322
1 time?
1 they would be sent to the sewer, was that its function?
2 Mr. Burnett: Object to the form of the
2 A 1 think that you're referring to an answer 1 gave
3 question. Vague and ambiguous.
3 you about Anniston, whether there was a similar basin for a
4 The Witness: Would you repeat the question.
4 similar purpose.
5 By Mr. Brock:
5 Q Okay. Can you describe for me the way that the
6 Q Did you consider those to be routine losses from
6 settling basin was set up. First of all, was it a settling
7 the Aroclor department around that time?
7 basin in connection with the Aroclor department?
8 A The first one --
8 A That's what 1 recall.
9 Q Routine losses of Aroclor from the plant at that
9 Q Can you describe for me what it consisted of?
10 time?
10 A 1 don't remember that one. 1 remember it as
11 A The first one, in fact, was a fairly rare
11 being similar to the Anniston one, but 1 can't recall what
12 situation because it refers to losses when the gas was
12 it looked like or anything like that.
13 drowned, and that was abnormal and did not happen very
13 Q Do you know how big it was?
14 often.
14 A No.
15 Q But that was - I'm sorry.
15 Q If you go to the pages with the Bates numbers 247
16 A The others are ongoing losses of one kind or
16 through 251, you can see that there are certain projects
17 another.
17 listed, and they're divided up between production,
18 Q When you say when the gas was drowned, that was 18 maintenance and technical services. Do you see that?
19 something that Monsanto would do intentionally ; correct?
19 A Yes.
20 A Well, when the action was taken, it would be
20 Q How was that type of division made, meaning
21 taken intentionally, but the policy was that this was not
21 concerning who -
22 to be the way to operate.
22 A Just according to the capabilities of the various
Page 321
Page 323
1 Q Let's go to Exhibit 64. For the record, it's
1 groups, things like routine operation, making measurements
2 dated May 2, 1972.
2 and taking samples would more likely be done by production,
3 Is this a memorandum that was directed to you
3 whereas technical work or project work would more likely be
4 during the course of your employment with Monsanto?
4 done by technical services. Installation was always done
5 A Yes.
5 by the maintenance department.
6 Q At the bottom of page 2, there's a reference to a
6 Q If you look on the last, or the page that ends in
7 project being prepared to pump from north settling basin to 7 Bates number 250 under the maintenance section, there's a
8 the south unit. Do you see that?
8 reference to " repair sewer at Second Street." Do you see
9 A Which page?
9 that?
10 Q The second page of the document. At the bottom.
10 A Yes.
11 A Okay, yes.
11 Q Do you know what that sewer refers to?
12 Q Do you know what the north settling basin was?
12 A No.
13 A No.
13 Q Do you know whether - we've seen some sewers
14 Q Do you know what the south unit was?
14 referenced earlier, that reference to the sewers in the
15 A No, by this time we had some kind of settling
15 Aroclor department. Do you know whether this is a separate
16 basin in the department, but 1 don't remember that it had
16 sewer or the same?
17 more than one compartment or anything like that.
17 A No, 1 don't.
18 Q Do you know when that settling basin was
18 Q Let's go to Exhibit 65. Is this a July 7, 1972
19 constructed?
19 memorandum directed to you during the course of your
20 A No.
20 employment with Monsanto?
21 Q 1 thought you described that -- and you can
21 A Yes.
22 correct me if I'm wrong - as settling out materials before
22 Q In the reference to Aroclor department in A,
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 320 - 323
HARTOLDMON0010182
Page 324
Page 326
1 there's a reference to new sewer and sampling station and
1 you can see that that references the earlier document that
2 operation 622.
2 went from Engman to Bratsch. Do you see that?
3 A Yes.
3 A Yes.
4 Q Did you continue to visit the Aroclor operations
4 Q Do you recall there being any type of meetings or
5 at the Krummrich plant around this time?
5 discussions around that time involving Engman and Bratsch
6 A Yes.
6 concerning how to go about addressing the Pcb situation
7 Q Was a new sewer and sampling station there, was
7 from that time on?
8 that something that you would have visited?
8 A No.
9 A Probably not a sewer project, but 1 would have
9 Q The next page, the page that ends in Bates number
10 been interested in a sampling system. We had regular
10 689, makes a reference to " activities in progress to
11 meetings at the plant, in the plant office, and if there
11 assemble desired information, formally programmed for
12 was significant progress on projects, 1 would typically go
12 dealing with federal authorities in the near future with
13 out in the plant and look at it.
13 regard to Pcbs in the environment." Do you see that?
14 Q If there were -- why would you not have been
14 A Yes.
15 interested in the new sewer?
15 Q Other than the materials that you were sending,
16 A Because it wasn't anything that 1 could do
16 receiving from the Krummrich plant and then sending to
17 anything about. It was other people's responsibility.
17 Papageorge, were you involved in any attempts to assemble
18 Q You couldn't say the sewer should be fixed?
18 information for dealing with federal authorities on that
19 A Oh, if there was a defective sewer and the
19 issue?
20 problem was not being dealt with properly by the plant, 1
20 A 1 may have been requested to do that, but 1 don't
21 would have certainly been in a position to complain about
21 remember it.
22 that and insist that it get attention. But as long as it
22 Q You don't recall any particular type of
Page 325
Page 327
1 was being dealt with by the proper people, it's not
1 information you were requested to get?
2 something that really concerned me.
2 A No.
3 Q In the first paragraph under" Pcb levels in
3 Q Let's go to Exhibit 66. Is this a copy of a
4 sewers," there's a reference to " knowing losses," do you
4 December 1, 1972 memorandum that was sent to you in
5 see that?
5 connection with your employment with Monsanto?
6 A Yes.
6 A Yes.
7 Q And that same reference is made on the next page, 7 Q Do you know whose writing that is up at the top?
8 and again it says " knowing losses." It's the first
8 A Looks like mine.
9 paragraph. Again, it's in quotes. Do you know why that - 9
Q Number 2 appears to read " Srs file Aroclor
10 1 guess why you put that in quotes?
10 pollution."
11 A Well, this is a letter to me.
11 A " Jrs file."
12 Q I'm sorry. Do you know why that was put in
12 Q What was that?
13 quotes?
13 A That was my file. This would have been
14 A Because it was an unusual term and it seems an
14 instructions to my secretary ; number one, make a copy for
15 unusual choice of words. 1 don't know why they used those 15 Bill Papageorge and number two, put this in my file.
16 words. 1 would have used a term like identified losses.
16 Q Does that refresh your recollection as to keeping
17 Q Does that refer to losses that Monsanto knew
17 a file concerning Aroclor pollution situation?
18 about and had identified?
18 A 1 would probably have had a file about that, but
19 A Yes, and my interpretation of this is these are
19 1 don't remember it specifically. This does indicate that
20 losses where we identified a source, presumably we were
20 1 did have such a file.
21 working on it.
21 Q Let me ask you to turn to the third page of the
22 Q And under the lii where it says " program status,"
22 document. It's the page with the Bates number 376. Linder
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 324 - 327
HARTOLDMON0010183
Page 328 1 " Wgk strategy" it states " no plans to contact Epa until 2 Pcb is declared toxic substance." Do you see that?
Page 330 1 governmental authorities concerning Pcb matters at the 2 Anniston and Krummrich plants?
3 A Yes.
3 A No.
4 Q Do you know how that decision was arrived at?
4 Q Let's go to Exhibit 67. Is that a copy of a
5 A No, and it seems a little strange to me that
5 February 7, 1973 memorandum that was directed to you in the
6 Mr. Stewart would be commenting about that since that was 6 course of your employment with Monsanto?
7 not a plant matter.
7 A Yes.
8 Q How would it be decided or how would it have been 8 Q Can you read the first paragraph of that to
9 decided within Monsanto around that time whether to contact 9 yourself and let me know when you've had a chance to do
10 the Epa with regard to the Pcb situation at Krummrich?
10 that.
11 A That kind of a decision would be taken somewhere
11
( Witness reviewed the document. )
12 above my level.
12 A Okay.
13 Q Who would have - when you say above your level,
13 Q Do you know why starting in February of 1973 the
14 do you have any particular people in mind?
14 status of the Pcb environmental control program was to be
15 A 1 would expect that Mr. Bergen and Mr. Papageorge 15 reported by the environmental control group at the
16 and some of our attorneys would be involved, perhaps
16 Wgk plant?
17 others, perhaps the division general manager.
17 A No.
18 Q Who was the division general manager?
18 Q Do you recall a change as to who would be
19 A I'm not sure. When 1 joined the business group,
19 reporting being instituted?
20 John Mason was the general manager. At some point he was 20 A No, 1 don't remember.
21 replaced by Mr. Corey, but I'm not sure which one would
21 Q Who was J. Grant, G-r-a-n-t, his name is up above
22 have been on the job at this particular time.
22 next to Art Leisy?
Page 329
Page 331
1 Q What was Mr. Corey's first name?
1 A 1 don't remember who that is.
2 A He was called Wink. 1 think his initials were
2 Q Do you know who D. C. Otto was?
3 W. R. 1 don't know what his real name was.
3 A That's Don Otto. 1 remember him as being the
4 Q Are you aware of any discussions around this time
4 head of the personnel department and if that's so, 1 have
5 concerning the subject of whether the Epa should be
5 no idea why he has a copy.
6 contacted with regard to the Pcb situation at Krummrich?
6 Q Did you attend plant strategy meetings concerning
7 A No, 1 should point out incidental to that there's
7 the strategy for the Krummrich plant's dealing with the Pcb
8 also an Illinois Epa and that this plant is in Illinois so
8 situation?
9 this statement is perhaps ambiguous to that extent.
9 A 1 don't know that we had meetings that were
10 Q Right. And 1 guess when I'm referring to Epa,
10 called strategy meetings. We had planning meetings when we
11 I'm referring to the federal Epa -- or the state Epa?
11 would decide what was to be done. 1 don't remember using
12 A Right, and 1 don't know which of these
12 the word " strategy" to describe plant meetings.
13 Mr. Stewart might have been referring to.
13 Q On the third page, the reason 1 asked the
14 Q Do you know whether there was any instruction
14 question that way, on the third page under Wgk strategy, it
15 given to the effect of Mr. Stewart's statement in the memo? 15 just starts off, it states " plant strategy meeting to be
16 A No.
16 held again when additional information is received from
17 Q Do you have any reason to believe that that
17 Epa." And then it goes on. Do you recall attending
18 statement is not accurate as of the writing - as of the
18 meetings of that type?
19 time of this memo?
19 A 1 have attended meetings that could be described
20 A 1 have no idea about it one way or the other.
20 that way. 1 don't remember using the word strategy to
21 Q Does this refresh your recollection at all as to
21 describe them but that's not an unreasonable way to
22 any type of different handling of contacts with
22 describe them.
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 328 - 331
HARTOLDMON0010184
Page 332 1 Q Fair enough. Who would be at those meetings 2 typically?
1 the course of your employment with Monsanto? 2 A Yes.
Page 334
3 A Well, by this time Clarey Buckley, probably Art
3 Q Where it says " file Aroclor pollution " up at the
4 Leisy. Paul Heisler, 1 think, had responsibility for
4 top, is that your writing?
5 overall plant pollution matters by that time, at least at
5 A Yes.
6 some time he got that responsibility. Probably the
6 Q Let's turn to the second page under" disposal of
7 department supervisor would be there, who 1 think at that
7 Aroclor drums," where it states " the contractor's operation
8 time was Bob Mccutchan and perhaps Engman or some of the 8 was inspected." Do you see that?
9 Tsd engineers who were working in the area.
9 A Yes.
10 Q Do you recall the subject of possible claims or
10 Q Do you know what contractor that refers to?
11 lawsuits against Monsanto with respect to the Pcb situation 11 A I'm not sure but I'm only aware of at the time
12 coming up at any of those meetings?
12 one contractor who did drum reconditioning. 1 don't
13 A Not plant meetings, no.
13 remember the name of it but there was a company to the
14 Q When you say not plant meetings, do you recall
14 south of downtown St. Louis that was in that business.
15 that coming up in some other kind of meeting?
15 Q Okay, you mentioned drum reconditioning and this
16 A Well, in meetings of the business group,
16 references disposal of Aroclor drums.
17 sometimes people would mention things like the silo
17 A Yes, that's right. And perhaps this is something
18 lawsuit.
18 different than what I'm thinking of, but 1 don't know of a
19 Q And the silo lawsuit was what again?
19 drum disposal contractor.
20 A The silo lawsuit was a case in, 1 think in Ohio
20 Q Number 3 on that same page, talking about" Pcb
21 where a silo had been coated with material that had Pcb in
21 residual levels, samples have been obtained at Anniston and
22 it. And it was alleged that the milk from the cows that
22 analysis is in progress." Do you see that?
Page 333
Page 335
1 had eaten from that silage was contaminated.
1 A Yes.
2 Q Let's go to Exhibit 68. Is that a March 2, 1973
2 Q Do you recall there being an analysis of Pcb
3 memorandum directed to you during the course of your
3 residual levels in connection with the Anniston plant?
4 employment with Monsanto?
4 A 1 don't remember what that means.
5 A Yes.
5 Q 1 thought you earlier had explained what your
6 Q If you'd turn to the second page, you can see
6 understanding of what residual Pcbs were.
7 that the name of a J. A. Munoz, Julio Munoz has been added, 7
A Well, that requires a little more context than
8 do you see that?
8 what this sentence gives me. 1 don't know what it means
9 A Yes.
9 without any context.
10 Q Do you recall him coming on to work?
10 Q Let's go to Exhibit 70. Is this a September 20,
11 A Yes, as 1 recall he was a technician, perhaps an
11 1974 memorandum that was directed to you during the course
12 engineer who reported to Clarey Buckley.
12 of your employment with Monsanto?
13 Q Do you recall what he did in connection with the
13 A Yes.
14 Pcb environmental control program?
14 Q Who is A. Gallion, G-a-l-l-i-o-n, who's
15 A 1 think he helped with sampling programs and the
15 referenced in the right-hand column?
16 like.
16 A 1 remember that name, but 1 can't connect it with
17 Q Do you recall having any dealings with him on the
17 anything else.
18 subject?
18 Q Do you know what the A, what his first name was?
19 A 1 remember that 1 knew him but 1 don't remember
19 A 1 remember it was something like Arley or Arnie
20 what passed between us.
20 but again, 1 can't make any more connection than that.
21 Q Let's go to Exhibit 69. You've got a copy of an
21 Q Linder" program status " there's a reference or
22 April 5, 1974 memorandum which was directed to you during 22 there's a sentence which reads that" sewer system appears
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 332 - 335
HARTOLDMON0010185
Page 336
Page 338
1 to smooth out the peaks and valleys from the department
1 A 1 can't comment on this meeting specifically.
2 losses to some extent." First of all, do you see that
2 Our policy in general was to try to maintain open
3 reference?
3 communication with the regulatory agencies and tell them
4 A Yes.
4 what we knew about the problem.
5 Q Can you explain what that means to me?
5 Q Were you ever contacted to give information in
6 A Well, the wording is a little obtuse. My
6 connection with the meeting between Monsanto personnel and
7 interpretation would be that whatever improvements had been
7 Epa personnel? And I'm including the Illinois Epa.
8 made to sewers had reduced the variability in losses.
8 A 1 don't recall ever being - ever participating
9 Q Why would the improvements in the sewers have
9 in such a meeting or being requested to do so.
10 reduced the variability in losses?
10 Q Who was K. Warren Easley? He's referenced in
11 A In my view it would have reduced the variability
11 Monsanto's Washington office.
12 in the measured losses simply because the measurements were
12 A 1 think he was the head of the Monsanto
13 more meaningful.
13 Washington office at the time or at least that's where his
14 Q Let's go to Exhibit 71. Is this a copy of an
14 office was.
15 April 28, 1972 memorandum which was sent to you along with
15 Q Was that just an office facility or were there
16 an attachment?
16 production operations ongoing there?
17 A Yes.
17 A There weren't any production facilities there.
18 Q And the arrow indicates that this was a copy that
18 The Washington office existed as a convenience for handling
19 was directed to you ; is that correct?
19 various contacts with the government. The only contact
20 A That's right.
20 that 1 had with the Washington office routinely was for
21 Q And is that your writing up in the top right-hand
21 help in getting visas and that sort of thing.
22 corner?
22 Q There's a reference to a " task force for Pcbs
Page 337
Page 339
1 A Yes.
1 with representatives from various federal agencies,
2 Q On the second page of the exhibit there's a
2 including Fda, Epa, Usda and coordinated through the office
3 reference to a meeting of April 13, 1972 in the Epa offices
3 of science and technology." Do you see that?
4 in Washington, D. C. Do you see that?
4 A Yes.
5 A Yes.
5 Q Do you recall ever having any dealings with any
6 Q Can you read the paragraph down below of
6 people on such a task force?
7 " background of meeting " to yourself and let me know when 7
A Not that 1 recall.
8 you've had a chance to do that.
8 Q Did you ever deal with the Fda or the Usda
9 ( Witness reviewed the document. )
9 concerning Pcb matters?
10 A Okay.
10 A 1 don't think so.
11 Q Do you recall there being a meeting between
11 Q Did you ever deal with them concerning
12 Monsanto and the Epa personnel in or about April of 1972
12 operations -- concerning Monsanto operations?
13 concerning the Pcb situation?
13 A No.
14 A 1 was aware that Monsanto met with various
14 Q On pages 3 and 4 it references comments that were
15 government officials from time to time, and 1 was probably
15 made by various people at the meeting and it talks about
16 aware of this meeting at the time but 1 don't remember this
16 Art Leisy and Dick Blowers and on page 4, it talks about
17 meeting specifically.
17 Bill Engman and Dr. Buckley. Do you see that?
18 Q Do you have an understanding as to who initiated
18 A Yes.
19 this meeting, the Epa or Monsanto?
19 Q Do you recall speaking with any of those people
20 A No.
20 about an upcoming Epa meeting concerning the Pcb situation?
21 Q Do you have an understanding as to why this
21 A No.
22 meeting was initiated?
22 Q Let's go to Exhibit 72. Is this a copy of a May
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 336 - 339
HARTOLDMON0010186
Page 340
Page 342
1 30, 1972 memorandum that was directed to you and others
1 the business group, including the products that contained
2 concerning Epa policy on Pcbs?
2 Pcbs, so he had responsibility for all the customer issues,
3 A Yes.
3 customer contacts, concerns that customers might have.
4 Q Do you recall receiving guidelines concerning the
4 Q And who was E. V. John?
5 Epa's policy with respect to Pcbs?
5 A 1 think he was an attorney.
6 A No, 1 don't remember this.
6 Q Do you know what his first name was?
7 Q There's a statement, this is in the third
7 A Ed, 1 think.
8 paragraph in the first page," 1 also suspect that the Epa
8 Q Do you know whether he specialized in any area of
9 will use available legal means, such as grand juries to
9 law, for example, environmental law?
10 obtain customer information from Monsanto to identify
10 A 1 only remember his name. 1 don't remember him
11 potential Pcb polluters." Do you see that?
11 personally or what he did.
12 A Yes.
12 Q And P. S. Park, that's Phocion Park ; is that
13 Q Do you recall there being concern about the Epa
13 correct?
14 using legal means such as grand juries to identify
14 A Phocion Park, Monsanto attorney.
15 potential Pcb polluters?
15 Q Do you recall why lawyers were brought into this
16 A No, 1 don't remember a concern about that.
16 matter around this time?
17 Q The memo ends with the statement" note that Epa
17 A Well, obviously there were legal issues,
18 is aware and will consider the effects of residual Pcb due
18 regulation.
19 to past losses." Do you see that?
19 Q Does that refresh your recollection at all as to
20 A Yes.
20 discussion or consideration given to the possibility of
21 Q Do you recall being informed that the Epa would
21 claims or lawsuits being asserted against Monsanto?
22 go back and take a look at past losses in addition to
22 A No.
Page 341
Page 343
1 reducing the standards for ongoing Pcb losses?
1 Q Do you recall what you did with this information,
2 A Not in terms of trying to quantify anything.
2 if anything?
3 That would be an unreasonable thing to try to do since we
3 A 1 don't recall specifically and 1 don't see
4 couldn't do it, 1 don't know how they could do it.
4 anything in this document that was inconsistent with the
5 Q Do you recall being - putting quantities aside,
5 plans that we already had in place.
6 do you recall being informed that the Epa was - or do you
6 Q Let's go to Exhibit 73. Is this a copy of a
7 recall discussions concerning whether the Epa would take
7 June 1, 1972 memorandum that was sent to you in the course
8 some type of action with respect to past Ep - past Pcb
8 of your employment with Monsanto, sent to you and some
9 losses?
9 others?
10 A No.
10 A Yes.
11 Q Who is T. L. Gossage?
11 Q On the second page, the last paragraph reads
12 A Tom Gossage was our director of marketing at that
12 " strategy for dealing with federal authorities in the near
13 time in the business group, reporting to Howard Bergen, who 13 future ( and probably Illinois authorities later) needs to
14 is now chairman of the board of Hercules.
14 be developed. We suggest that the Wgk plant arrange for a
15 Q Is that here in Wilmington?
15 meeting at which this strategy can be discussed." Do you
16 A Yes.
16 see that?
17 Mr. Brock: Off the record.
17 A Yes.
18 ( Discussion off the record. )
18 Q Were you involved in coming up with strategies
19 By Mr. Brock:
19 for dealing with the federal authorities or the Illinois
20 Q Do you know what his involvement was in
20 authorities on the Pcb issues?
21 addressing the Pcb situation at Monsanto's plants?
21 A 1 don't remember being involved in those
22 A He had responsibility for all of our marketing in
22 contacts. The custom was that contact with federal
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 340 - 343
HARTOLDMON0010187
Page 344
Page 346
1 authorities were handled by people at the general office
1 Q Do you know who they were contacting in the law
2 and frequently contacts with state authorities would be
2 department, was that John and - E. V. John and Phocion
3 handled by people from the plant that was located in that
3 Park?
4 state.
4 A The one 1 remember clearly is Phocion Park.
5 Q Why was that the custom?
5 There may have been others.
6 A The latter part of it?
6 Q Do you recall ever speaking to Phocion Park about
7 Q Well, the reasoning behind having the people in
7 the situation?
8 the general office contact the federal people and the
8 A 1 knew him but 1 don't remember any specific
9 people at the plant contact the state people.
9 conversation.
10 A 1 think it was a matter of -- as far as the
10 Q You recall Phocion Park being involved in the
11 people at the general office, it was a matter of competence
11 early ' 70s?
12 that they had attorneys who could give them the proper
12 A Yes.
13 advice on howto deal with federal authorities and so
13 Q Let's go to Exhibit 75. Is this a copy of a
14 forth. In the case of the states, the states are generally
14 December 19, 1972 memorandum that was sent to you and some
15 more responsive to people from that state.
15 others in connection with your employment with Monsanto?
16 Q Do you recall attending any meetings of the type
16 A Yes.
17 referenced here to set forth strategy for dealing with the
17 Q Who was Jack Hume, H-u-m-e?
18 federal or state authorities?
18 A Jack Hume was in production. At one time he was
19 A No, 1 don't remember that.
19 at the Krummrich plant as an operating superintendent.
20 Q Let's go to Exhibit 74. Is that a copy of a
20 Later on he had some position at the general office. 1
21 June 16, 1972 memorandum that was sent to you and some 21 don't recall where he was at this particular time.
22 others?
22 Q There's a statement up above that" Mr. Walter
Page 345
Page 347
1 A Yes.
1 Romanek of the federal Epa had requested testimony from
2 Q Under lii there, the second paragraph states
2 Monsanto on mercury losses." Do you see that?
3 " written documents that will be submitted to the federal
3 A Yes.
4 authorities will have legal approval." Do you see that?
4 Q And it references a hearing in Collinsville,
5 A Yes.
5 where is Collinsville?
6 Q And earlier we saw the names of E. V. John and
6 A Collinsville is in Illinois near East St. Louis.
7 Phocion Park on some of the documents?
7 Q Was that in connection with the Krummrich plant,
8 A Yes.
8 do you recall?
9 Q Do you recall the law department being brought in
9 A Apparently so.
10 at some point to deal with the outside entities with
10 Q Do you recall the Epa requesting testimony
11 respect to the Pcb situation?
11 concerning mercury losses at the Krummrich plant?
12 A My recollection is that from the time that 1
12 A No.
13 joined the business group in 1970 that we were regularly
13 Q Do you recall the Epa expressing concerns about
14 consulting with Monsanto attorneys about the Pcb problem. 14 possible mercury losses from the Krummrich plant?
15 Q Generally what was the involvement of the law
15 A No. 1 should point out that this memo is dated
16 department in that situation?
16 1972 and a later part of the memo refers to Pcbs and that's
17 A 1 don't know, 1 didn't do it.
17 no doubt the reason why 1 received a copy.
18 Q You say-
18 Q Did you ever have any involvement addressing
19 A 1 was not the one making contact with the law
19 mercury discharges from the Krummrich plant?
20 department.
20 A Indirectly at a much earlier time during the time
21 Q Do you know who was?
21 that 1 was at the Krummrich plant between ' 63 and ' 67 1 had
22 A Mr. Papageorge, Mr. Bergen.
22 technical responsibility for the chlorine plant. One of
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 344 - 347
HARTOLDMONOOIOI88
Page 348 1 the two cell houses was a mercury cell house and the 2 control of mercury losses was part of our program at that
Page 350 1 any way was C. F. Moore, that's Chester Moore. He had in 2 fact worked for me when 1 was at the Krummrich plant in the
3 time.
3 chlorine operation and 1 believe he was still involved in
4 Q Do you recall any third parties or governmental
4 the chlorine operation at this time in 1972. 1 suspect
5 agencies expressing concern with respect to mercury losses 5 that one of the others was a production person who was
6 from that department?
6 involved in that but 1 wouldn't know which one.
7 A No, the motivation for our work at that time was
7 Q Was mercury used or generated at the Krummrich
8 economic. Mercury is expensive.
8 plant other than in the chlorine operation?
9 Q Do you have any knowledge concerning why the Epa 9 A Not that 1 know of.
10 had requested testimony in the 1972 time frame concerning 10
Mr. Brock: Off the record.
11 mercury losses?
11 ( Recess. )
12 A No. 1 had no involvement with that operation at
12 By Mr. Brock:
13 that time.
13 Q Mr. Savage, let me skip somewhat out of order and
14 Q Let's go to the second page. In the second
14 ask you to turn to what 1 believe was marked as Exhibit
15 paragraph, there's a statement that Mr. Pratt indicated he
15 87.
16 was " not concerned about the unusual circumstances such as 16
( Discussion off the record. )
17 this, but the regular discharge without extenuating
17 Exhibit 85, without reading through this in great
18 circumstances." Can you let me know when you've found that 18 detail, can you identify what this is for us?
19 sentence?
19 A Yes, this is the standard manufacturing process
20 A Yes.
20 for the Aroclors department at the Krummrich plant of 1966
21 Q Okay, recognizing that that paragraph appears to
21 together with a collection of amendments.
22 talk about mercury discharges, was it your understanding
22 Q Was this the one in effect during the time that
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Page 351
1 that the Epa was concerned about the same type of thing
1 you were at the Krummrich plant?
2 with respect to Pcb discharges, meaning regular discharges
2 A This date is during the time that 1 was at the
3 without extenuating circumstance?
3 Krummrich plant since 1 was there from ' 64 through ' 67 -
4 A 1 don't know of any connection.
4 ' 63 through ' 67.
5 Q Well, when you say you don't know of any
5 Q Let me ask you to turn to the page that ends in
6 connection, I'm interested in knowing whether or not your
6 Bates number 841 and that has a microfilm number of 2042.
7 understanding of the Epa stance at that time was similar
7 You can see that that's the beginning of a tentative
8 with respect to Pcbs in the sense -
8 amendment J, and there's a copy of it that was sent to you?
9 A No. 1 have no idea how the Epa might have
9 A That's right.
10 weighted unusual discharges versus more continuing
10 Q What was your involvement in amendments to the
11 discharges.
11 standard manufacturing procedures for the Aroclor
12 Q The next paragraph mentions a problem in area 3,
12 department at the Krummrich plant in the 1970 time frame?
13 do you see that?
13 A At that time 1 was manufacturing manager, so 1
14 A Yes.
14 was one of those who would approve an amendment before it
15 Q Do you know what area 3 was?
15 would be put into effect.
16 A No.
16 Q Did you have any involvement in approving or
17 Q If you look at the list of cc's to this
17 dealing with those after you left the Krummrich plant?
18 memorandum, who would have been involved in - or who would
18 A Yes. This was after 1 left the Krummrich plant,
19 have had responsibility for mercury discharges from the
19 this is during my time as a manufacturing manager, this
20 Krummrich plant at that point in time?
20 memo.
21 A In looking at this list, the only one 1 know of
21 Q I'm getting my dates confused. I'm sorry. And
22 who was involved in chlorine operations or technology in
22 on the next page, the page that ends in Bates number 842,
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 348 - 351
HARTOLDMON0010189
1 that's your signature at the bottom ; is that correct? 2 A Yes.
Page 352
Page 354 1 decision was made. 2 Q But when you say technical production manager,
3 Q Let me ask you to turn to the page that ends in 4 Bates number 944. 5 A Okay. 6 Q And the heading on that page is " Atmospheric 7 discharge -- waste disposal." Do you see that? 8 A Yes. 9 Q The first document 1 showed you 1 think was in 10 1957, standard manufacturing process for the production of 11 Aroclor at the Anniston plant. We talked about a category 12 like this not being in that 1957 document. Does this 13 refresh your recollection as to such a category being added 14 to the standard manufacturing processes sometime between 15 1957 and 1966? 16 A Well, obviously it had been added, but 1 don't 17 recall the event. 18 Q Do you have any knowledge as to what the 19 background or impetus was for adding categories like this 20 in the manufacturing procedures? 21 A Well, clearly standards were changing at that 22 time as to the importance of matters like this. It's no
3 are you referring to a department or a particular person? 4 A No. When 1 became a manufacturing manager in 5 1970, that 1 think was the first time that that title was 6 used. Before that some of the same people were in similar 7 positions and they were called technical production 8 managers at that time. 9 Q Do you know who the technical production managers 10 were in the 1960s? 11 A 1 think Rheiny Wobus was one. At some point Paul 12 Edwards became one. 1 think John Smith was one, Ron Wiese 13 was a Tpm at that time. 14 Q How do you spell his last name? 15 A W-i-e-s-e. 16 Q Any others that you recall in the 1960s? 17 A Well, Dez Hosmer had that title at one time but 18 by the time we're referring to, he was the boss of all of 19 the technical production managers and his title, 1 think, 20 was manager of manufacturing technology. 21 Q Anybody else? 22 A Those are the only ones that 1 remember.
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1 surprise that such a category would have been added during 1 Q Let me ask you to turn to the page that ends in
2 the '60s.
2 Bates number 947.
3 Q Does the fact that this was added as a category 3 Down towards the bottom of that page there's a
4 to the standard manufacturing procedure for Aroclor
4 heading for toxicity. Do you see that?
5 indicate to you that there was some concern about
5 A Yes.
6 atmospheric discharges and methods of waste disposal for 6 Q And it states " this material is a liquid under
7 Pcbs before Dr. Riseborough's study came out in the late
7 normal conditions and has a medium toxicity range for
8 1960s?
8 liquid ingestion and high toxicity for vapor inhalation."
9 A No, 1 don't think so because the content of a
9 Do you see that?
10 standard manufacturing process was prescribed by a standard 10 A Yes.
11 procedure, a standard format. And 1 should think that if
11 Q Does that indicate to you that there was some
12 it had been added to this one, it was probably added to all
12 awareness within Monsanto in the 1960s of effects of
13 others at about the same time.
13 Aroclor with regard to toxicity?
14 Q Do you have any knowledge why it was added -- and 14 A 1 don't know. This very page is inconsistent
15 1 have seen it in a number of others - do you have any
15 because you'll observe up above, under toxicity, item 5, it
16 knowledge as to why a category like that was added
16 says " toxicity does not present a serious problem." 1
17 generally to the manufacturing procedures around that time? 17 don't know how to explain that contradiction.
18 A 1 don't recall it being done. The content and
18 Q But it also says " instructions are also issued to
19 format of the standard manufacturing process was under the 19 avoid actual skin contact with biphenyl and Aroclor as much
20 control of technical production manager organization in
20 as possible and to wash hands and face before eating." Do
21 St. Louis and 1 was still at the plants during the ' 60s.
21 you see that?
22 So as far as 1 know 1 didn't participate in whatever
22 A Yes. Those are normal precautions that we would
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 352 - 355
HARTOLDMON0010190
Page 356 1 recommend handling any chemical material. 2 Q Were those precautions issued -- strike that.
1 the Aroclor department at the Anniston plant? 2 A Yes, 1 think so. We always instructed the
Page 358
3 Why were those precautions normally issued with 4 respect to chemicals? 5 A 1 think it was just considered prudent. 6 Q Was that in recognition of the possibility that 7 the chemicals could present some sort of hazard if skin 8 contact was not avoided? 9 A No, 1 don't know of any recognized hazard related 10 to skin contact. 11 Q Down below where it talks about Aroclor having a 12 medium toxicity range, what does the phrase " medium 13 toxicity range " mean to you? 14 A That doesn't mean very much to me. 1 don't know 15 what it means. 16 Q During the 1960s do you know whether you reviewed 17 the standard manufacturing processes for the Aroclor 18 department at the Krummrich plant? 19 A 1 don't remember doing so. 20 Q That would not have been something that you were 21 required to do in connection with your job 22 responsibilities?
3 operators that they should minimize skin contact, clean up 4 if they did have skin contact. 5 Q Did you have the understanding that that type of 6 understanding within Monsanto predated your stint as 7 production supervisor of the Aroclor department at the 8 Anniston plant? 9 A Yes, 1 believe that we had some safety data 10 sheets on Aroclor that indicated that. 1 don't know how 11 old the information was but 1 think it did predate my time 12 as production supervisor. 13 Q Let's go back to Exhibit 76. Is this a copy of a 14 September 1973 memorandum that was sent to you and some 15 others in connection with your employment at Monsanto? 16 A Yes. 17 Q And it states " on September 7, 1973 Epa published 18 their first' List of Toxic Pollutants.'" Do you see that? 19 A Yes. 20 Q And in the second paragraph it begins with the 21 statement" Pcbs were of course on the list." Do you see 22 that?
Page 357
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1 A The writing of standard manufacturing processes
1 A Yes.
2 was the responsibility of production supervision, and 1 was
2 Q Do you recall this list of toxic pollutants
3 inTsd. It would have not been unusual for production to
3 coming out?
4 ask for assistance from me or from my engineers, but it
4 A 1 remember that there was such a list. 1 don't
5 still would not have been our direct responsibility.
5 remember the event of its coming out.
6 Q If you turn to the next page, which is the page
6 Q Do you know why the reference is to Pcbs of
7 with the Bates ending in 948. There's a heading " other
7 course being on the list?
8 hazards " and it states " this material can cause dermatitis, 8 A 1 think Pcbs by that time had achieved some
9 systemic poisoning from the fumes, and yellow atrophy of
9 notoriety and therefore we just assumed that the Epa would
10 the liver. They are skin, mucous membranes and eye hazards 10 have to deal with it.
11 encountered in handling this material."
11 Q There's a reference in the first paragraph to a
12 Do you see that?
12 suit by an environmental group after which the Epa entered
13 A Yes.
13 into a consent decree to publish proposed effluent
14 Q Did you have that understanding in the 1960s?
14 standards.
15 A 1 don't remember anything specific from that
15 A Yes, 1 see that.
16 period of time.
16 Q Do you recall being aware of such a suit by an
17 Q Does this indicate to you that there was some
17 environmental group?
18 recognition within Monsanto of hazards that could be
18 A No.
19 presented by Aroclors prior to the 1969, 1972 time frame?
19 Q Do you recall there being any discussions within
20 A 1 think we recognized that it was somewhat toxic.
20 Monsanto about whether Monsanto might be sued by an
21 Q Do you know whether there was such a recognition 21 environmental group with respect to the Pcb situation?
22 during the time that you were a production supervisor of
22 A No, 1 don't remember.
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 356 - 359
HARTOLDMON0010191
Page 360
Page 362
1 Q Who was V. Brawley, B-r-a-w-l-e-y, referenced at
1 Q And P. G. Benignus?
2 the top?
2 A Paul Benignus reported to Cumming Paton at that
3 A Virgil Brawley was the foreman in the Krummrich
3 time.
4 Aroclor department.
4 Q On page 2 entry number 5 references " inability of
5 Q Let's go to Exhibit 77. Is this a copy of a
5 industry to conform with the suggested low effluent limit.
6 February 14, 1974 memorandum that was sent to you and some
6 Steps being taken for relief. Needs for all to respond to
7 others in connection with your employment at Monsanto?
7 Washington." Do you see that?
8 A Yes.
8 A Yes.
9 Q There's a reference to an Eia task force meeting,
9 Q Do you know what steps Monsanto was taking for
10 do you see that up at the very top?
10 relief?
11 A Oh, yes, yes.
11 A No.
12 Q Do you recognize the name Electronic Industries
12 Q On the page that ends in Bates number 061 and the
13 Association?
13 third paragraph it states " 1 was told that when Monsanto
14 A No, but 1 knew that there was an organization of
14 develops a super-duper non-pcb to let the committee know."
15 these companies.
15 A Yes.
16 Q Did you ever have any dealings with the Eia?
16 Q Does that refer to a dielectric fluid?
17 A Not as an organization. 1 had some dealings with
17 A Dielectric fluid, yes.
18 some of these companies.
18 Q Did Monsanto ever develop such a non-pcb
19 Q Did any of your dealings with those companies
19 dielectric fluid?
20 address Pcb pollution matters?
20 A We developed a non-pcb dielectric fluid but it
21 A Yes.
21 apparently was not super-duper because it was not accepted.
22 Q What were the nature of your dealings with those
22 Q Let's go to Exhibit 78. Is this a copy of a
Page 361
Page 363
1 companies on that subject?
1 February 26, 1974 memorandum that was sent to you and some
2 A This only occurred at some time during my time as
2 others in connection with your employment at Monsanto?
3 a manager. We invited the customers to come in for some 3 A Yes.
4 kind of meeting and one part of the meeting was that 1 made 4 Q Category number 2 is disposal of Aroclor drums.
5 a presentation on those parts of our plant pollution
5 Do you see that?
6 control efforts that might be applicable to their plants
6 A Yes.
7 where they used Aroclors. Not all of these companies did
7 Q And it says " visit Evans." Do you see that?
8 attend it and 1 don't remember which ones did attend.
8 A Yes.
9 Q Did anybody work with you on your presentation?
9 Q Does that refresh your recollection as to who the
10 A Probably so but 1 don't remember.
10 contractor may have been who's responsible for disposal of
11 Q Do you recall the substance of your presentation?
11 Aroclor drums?
12 A Only in a very general way. We talked about
12 A The implication is that it's somebody named Evans
13 things like catch basins and sampling methods. Most of the 13 but that, 1 don't recollect that name.
14 control efforts that we had in manufacturing process would
14 Q Do you recall alternative - alternate methods
15 be irrelevant to the customers.
15 being developed with respect to disposal of Aroclor drums
16 Q Did the subject come up of whether they or
16 around that time?
17 Monsanto could be sued for Pcb pollution?
17 A No.
18 A No. My presentation was entirely about practical
18 Q Let's go to the page that ends in Bates number
19 aspects of controlling pollution.
19 223 under the category B, items to obtain goal 3 and the
20 Q Who was a C. Paton, P-a-t-o-n?
20 reference is to " losses to river," do you see that in the
21 A That's Cumming Paton. He was product manager for 21 middle of the page?
22 functional fluids at that time.
22 A Yes.
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 360 - 363
HARTOLDMON0010192
Page 364
Page 366
1 Q Are you aware of any way that the Pcbs from the
1 of this exhibit that I'm listed as having attended that
2 plant reached the river other than through the sewers?
2 meeting and 1 find that kind of startling because 1 don't
3 A No, 1 don't know of any other way.
3 remember.
4 Q Let's go to Exhibit 79. Is this a December - a
4 Q Does that refresh your recollection at all as to
5 copy of a December 9, 1974 memorandum that was sent to you
5 having any involvement in an epidemiological study by Niosh
6 and some others in connection with your employment with
6 or by any other organization?
7 Monsanto?
7 A No.
8 A Yes.
8 Q Let's go to Exhibit 80. Do you see your name
9 Q Who is G. F. Fort, F-o-r-t?
9 listed in handwriting?
10 A Garth Fort. Fie was a pollution specialist. He's
10 A Yes.
11 been involved in pollution control environmental matters
11 Q Do you know whose handwriting that is?
12 for all the time I've known him, but 1 don't know what his
12 A That has the initials Hsb at the bottom which
13 position was at this time.
13 would be Howard Bergen.
14 Q Was he at the Krummrich plant or was he in
14 Q Does that indicate to you that you received a
15 St. Louis or strike that. Do you know where he was
15 copy of this in or about July of 1975?
16 located?
16 A Yes.
17 A No, 1 don't.
17 Q Do you recall what you did with this information,
18 Q Do you recall there being a meeting between
18 if anything?
19 Monsanto personnel and Niosh personnel -
19 A Well, this is a statement by the customer
20 A No.
20 organization of the Epa. 1 don't recall that 1 took any
21 Q - concerning Pcb matters?
21 action and 1 don't even know why Howard would have sent me
22 A No.
22 a copy.
Page 365
Page 367
1 Q 1 take it you never had any contact with Niosh
1 Q When you said customer organization, 1 thought
2 personnel concerning that?
2 you said Epa. Did you mean Eia?
3 A No, not personally.
3 A Eia to the Epa, excuse me.
4 Q Do you recall there being a study conducted of
4 Q Were you ever involved in any lobbying efforts
5 the - of Monsanto employees with respect to the effects of 5 with respect to Pcb standards or other Pcb matters?
6 work place exposure to Pcbs?
6 A Not that 1 recall.
7 A 1 remember that there was an epidemiological
7 Q Does this refresh your recollection as to any
8 study. 1 don't recall any particular result.
8 dealings you may have had with Eia people concerning Pcb
9 Q Do you recall when the epidemiological study was
9 matters?
10 conducted?
10 A No.
11 A No.
11 Q Let's go to Exhibit 81. Is this a copy of an
12 Q Do you recall who was tested?
12 October 15, 1975 memorandum that was sent to you and some
13 A Well, it was workers in the Aroclor departments.
13 others in connection with your employment with Monsanto?
14 1 think at both Krummrich and Anniston.
14 A Yes.
15 Q Do you recall how you learned about that study?
15 Q This refers to a national symposium on Pcbs. Do
16 A No.
16 you see that?
17 Q Do you know who was responsible within Monsanto 17 A Yes.
18 for handling that study?
18 Q And it says, states the following people
19 A Well, we had a group under Dr. Wheeler which
19 attended," subject, Monsanto meeting," and you're one of
20 included, 1 notice George Lavinskas is listed here and some 20 the people listed?
21 others, they would have orchestrated such a study because 21 A Yes.
22 they were the experts in that. 1 notice in the last part
22 Q Do you recall attending such a national symposium
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 364 - 367
HARTOLDMON0010193
Page 368 1 on Pcbs around this time frame? 2 A This memo is minutes of an internal meeting in
1 2
Page 370 A No. Q Do you recall making a request of that type
3 Monsanto which apparently was in preparation. You'll 4 notice the memo is dated October 15 and the symposium is 5 listed as being a month later. So this apparently referred 6 to a meeting to prepare for that later symposium. 7 Q Fair enough, you're right. Do you recall being 8 involved in the preparations for a national symposium about 9 Pcbs? 10 A No. 11 Q Who is D. R. Bishop? 12 A Dan Bishop was in Prat that time. 13 Q What about T. L. Gossage? 14 A That's Tom Gossage, who was marketing director. 15 Q How about R. E. Keller? 16 A Bob Keller was in the applied sciences group, 1 17 think, research. 18 Q Who was W. W. Withers? 19 A Wayne Withers is an attorney. 20 Q Do you know what area of law, if any, he 21 specialized in? 22 A No. He was a general attorney.
3 around this time frame? 4 A 1 don't know about the time frame. No, 1 don't 5 remember doing this. 6 Q Do you recall trying to find out what the waste 7 disposal methods had been for Pcbs at the Anniston plant 8 other than to the sewer? 9 A No, 1 don't know of any reason connected to my 10 regular duties that would have made me need this historical 11 information. 12 Q Let's go to the end of the second page and it 13 ends with the statement," Since 1 understood from our 14 telephone conversation that you would clear these data 15 through the legal department and other appropriate people, 16 1 have not reviewed the data with anyone outside of the 17 Monsanto plant." Do you see that? 18 A Yes. 19 Q Does that refresh your recollection as to any 20 reason why you would have made such a request at that time? 21 A 1 would have had no immediate use for the data, 22 so the only reason 1 would have asked for data like this is
Page 369
Page 371
1 Q He was in Monsanto's law department; correct?
1 that someone else had asked me for it but 1 don't know who
2 A Yes.
2 that would be.
3 Q Do you know why attorneys, or an attorney in
3 Q Do you have an understanding as to why you would
4 Monsanto's law department was involved in the preparations
4 have cleared the data with the legal department?
5 for the symposium?
5 A No. Because we exchanged this kind of data
6 A No.
6 between the plant and myself routinely and 1 did not clear
7 Q Who is D. Wood?
7 it with the legal department.
8 A That's David Wood. He was product manager
8 Q Do you recall discussing with him whether or not
9 reporting to Cumming Paton involved in functional fluids.
9 the data should be revealed to anyone outside of the
10 Q Let's go to Exhibit 82. Is this a copy of a
10 Anniston plant?
11 November 10, 1975 memorandum sent to you in connection with
11 A 1 don't remember asking him for the data so 1
12 your employment with Monsanto?
12 don't remember that.
13 A Yes.
13 Q Let's skip one and let's go to Exhibit 84. Is
14 Q And the first sentence reads " This memo supplies
14 this a copy of a November 8, 1975 memorandum that was sent
15 the last of the data available to fulfill your request for
15 to you and some others in connection with your employment
16 air sample analyses, water, effluent analysis and flow and
16 with Monsanto?
17 waste disposal other than sewer." Do you see that?
17 A Yes.
18 A Yes.
18 Q And there's an asterisk by your name?
19 Q And W. T. Tafey, he was at the Anniston plant at
19 A Yes.
20 this time, wasn't he?
20 Q And that indicates you were present at a
21 A Yes.
21 dielectric task force meeting?
22 Q Do you recall making such a request to him?
22 A Yes. It's a Santosalt-dielectric. Santosaltwas
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 368 - 371
HARTOLDMON0010194
Page 372
Page 374
1 not a dielectric so apparently the meeting was about both
1 A They were no longer marketed or used for one
2 of those subjects.
2 reason or another.
3 Q What is Santosalt?
3 Q Do you recall whether there was any discussion as
4 A Santosalt was a trade name that we used for some
4 to whether or not something else should be done with them?
5 functional fluids that were developed as Pcb replacements
5 A No.
6 as a solvent for use in carbonless copy paper.
6 Q Can you read the writing, the handwriting down
7 Q Do you recall being a member of a
7 below?
8 Santosalt-dielectric task force?
8 A 1 think 1 can make it out. This appears to be a
9 A No, but 1 remember working on those subjects.
9 note from Paul Heisler. It says " Mike, please advise if
10 Q Can you describe for me the work that you did on
10 you visualize serious problems. Assume you " -- and some
11 those subjects?
11 name beginning with H --" will set up some reasonable
12 A Well, these new fluids were being developed in
12 method of handling."
13 research and 1 worked with research to provide some
13 Q Up above, there's a name Harry Rayfield. It
14 economic guidance on the various substitutes to help them
14 appears in handwriting?
15 come up with the most economic products they could and then 15 A Yes. And it looks like the name down below is
16 after the products had been developed, then 1 worked out
16 Harry.
17 plans to manufacture the new products.
17 Q Who was Harry Rayfield?
18
( Savage Exhibits 86 and 87 identified. )
18 A 1 remember the name, but 1 don't remember what
19 By Mr. Brock:
19 his position was.
20 Q Let's go to Exhibit 86. Is it a copy of a July
20 Q Do you recall there being any discussions around
21 10, 1972 memorandum sent to you and some others in
21 that time about whether or not problems could be presented
22 connection with your employment with Monsanto?
22 by discarding solid Aroclors to the landfill?
Page 373
Page 375
1 A Yes.
1 A No, 1 don't remember any discussion like that.
2 Q Who was Elmo Campbell?
2 Q Do you have an understanding why this memorandum
3 A He was in the shipping department or the
3 would have originally been sent to the names that are
4 warehouse department at the Krummrich plant.
4 typewritten and then additionally to the other names that
5 Q Do you know whether he's still alive?
5 are referenced?
6 A No.
6 A Well, it appears that this originally went --
7 Q Do you recall having any dealings with
7 this particular copy originally went to Paul Heisler
8 Mr. Campbell concerning Aroclors?
8 because there seems to be an arrow next to his name. And
9 A No.
9 then he sent it onto the additional four people listed at
10 Q Do you recall there being an instruction around
10 the top by hand. Mike Foresman was involved in the
11 the 19 -- strike that. In the early 1970s to discard to
11 environmental area, Jim Dalton 1 think was a production
12 the landfill solid Aroclors warehoused at the Wgk plant?
12 superintendent at that time, Clarey Buckley was involved in
13 A No.
13 environmental control.
14 Q 1 take it you don't recall or know what the --
14 Q Let's go to Exhibit 87. There's a reference --
15 strike that.
15 the first sentence reads " the disposal alternatives
16 Do you have an understanding as to why this
16 discussed with Central Foundry are all environmentally
17 instruction referenced in this memorandum was given?
17 acceptable." Do you see that?
18 A These products had become obsolete.
18 A Yes.
19 Q When you say obsolete, does that mean there was
19 Q Up at the top in the re: line there's a reference
20 no longer a market for them -- strike that.
20 to Pcb sludge. Do you see that?
21
When you say" obsolete," what do you mean by
21 A Yes.
22 " obsolete"?
22 Q Do you recognize the name Central Foundry?
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 372 - 375
HARTOLDMON0010195
Page 376
Page 378
1 A That's a part of General Motors, one of our
1 By Mr. Brock:
2 customers.
2 Q I've marked as Exhibit 88 - or I've marked
3 Q Do you recall what disposal alternatives had been
3 Exhibit 88, Mr. Savage. Is this a copy of an October 24,
4 discussed with them?
4 1974 memorandum sent to you and some others in connection
5 A No, 1 don't know.
5 with your employment with Monsanto?
6 Q In the third paragraph it states " if for business
6 A Yes.
7 reasons we decide that we will actively help Central
7 Q It states " Pcb losses at the Sauget Village
8 Foundry and offer them our plant facilities, we should
8 outfall have been erratic since the first week in
9 immediately discuss this with Jim Savage because this
9 October." Do you see that?
10 service will be an unusual activity and require special
10 A Yes.
11 handling at the plant." Do you see that?
11 Q Do you know what the reference to Sauget Village
12 A Yes.
12 outfall refers to?
13 Q Do you recall being involved in any discussions
13 A Sauget Village is the name of a small municipal
14 of whether or not Monsanto should offer its plant
14 where the Krummrich plant is. This refers to the treatment
15 facilities to Central Foundry?
15 plant that handles waste from the Krummrich plant. The
16 A No.
16 outfall would be the place where the effluent from the
17 Q Do you know whether that was in fact done?
17 treatment plant went into the river.
18 A 1 don't think so. Papageorge nominates me in
18 Q Down below it makes some recommendations and the
19 this case simply because 1 was the normal interface with
19 first is to " discontinue sampling at the Sauget Village
20 the plant.
20 outflow until waste treatment plant construction is
21 Q Do you recall discussions about whether or not
21 completed and our former sampling system is reinstituted."
22 use of the Krummrich toxic dump should be offered for
22 A Yes.
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1 customers who wanted to dispose of Pcb matters?
1 Q The reference to " our former sampling system
2 A 1 don't recall discussing it.
2 being reinstituted," what does that refer to?
3 Q Do you recall discussions at any time concerning
3 A Well, if you observe the second paragraph of this
4 whether Monsanto should stop using the Krummrich toxic dump
4 memo he talks about a slow speed sampler being used. We
5 for its own Pcb wastes?
5 had learned by this time very well that that was an
6 A Not before the fact. Just in recent years 1 have
6 inadequate way of measuring, so his recommendation numbei
7 had casual conversations with Jack Molloy who was the plant
7 one is to just stop until a proper sampler can be put back
8 manager at the time that the dump was closed, about that
8 in place.
9 decision, but it was casual conversation long after the
9 Q And recommendation number two is " discard from
10 fact.
10 our records all data at the Svo after 10/9/74." Do you see
11 Q Do you recall at all what the casual
11 that?
12 conversation, the substance of the casual conversation?
12 A Yes.
13 A Just that he felt that it was a good decision
13 Q Do you recall why the recommendation was given to
14 that he had made to close it.
14 discard data after that date?
15 Q He told you it was his decision?
15 A No, but it follows very logically from item 1
16 A Yes.
16 that that data would be meaningless.
17 Q Did he say why he felt that was a good decision?
17 Q Why would the data be meaningless?
18 A No, 1 don't think so.
18 A Because it had been taken with an improper
19 Q Did the subject of pollution or possible
19 sampling device.
20 pollution from the toxic dump come up?
20 Q Do you know whether that was in fact done, the
21 A No.
21 discarding of the records?
22 ( Savage Exhibit 88 identified.)
22 A No, 1 don't.
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 376 - 379
HARTOLDMON0010196
Page 380 1 Q Do you recognize the name Bernard C. Bosse, 2 B-o-s-s-e? It's not on that document.
Page 382 1 whether or not to use the landfills as temporary 2 expedients, why were the landfills being considered as
3 A No, it doesn't ring any bells with me. 4 Mr. Brock: Off the record. 5 ( Discussion off the record. ) 6 ( Savage Exhibits 89 and 90 identified. ) 7 By Mr. Brock: 8 Q 1 have marked as Exhibits 89 and 90 or I've 9 marked those exhibits. Mr. Savage, is Exhibit 89 a copy of 10 a May 27, 1975 memorandum that was sent to you and some 11 others in connection with your employment at Monsanto? 12 A Yes. 13 Q And is Exhibit 90 a copy of a May 28, 1975 14 memorandum that you sent to Howard Bergen in connection 15 with your employment at Monsanto? 16 A Yes. 17 Q Is the writing up at the top where it says " file 18 Aroclor pollution " in both documents, is that your writing? 19 A Yes. 20 Q Referring first to Exhibit 90, what 21 responsibilities, if any, did you have with regard to a 22 decision of whether or not to temporarily dispose of Montar
3 temporary expedients? 4 A One of the primary justifications for the 5 incinerator was to have a good way of destroying Montar 6 residue and we would not be pleased to do anything 7 different than that. So the fact that it was being sent to 8 a landfill would be considered temporary. 9 Q Do you recall when the consideration of the use 10 of incinerators first came up? 11 A No. It was somewhere around 1971,' 72. It was 12 early in our considerations of the Pcb problems. 13 Q In connection with the consideration of the use 14 of incinerators for the destruction of Pcbs, are you aware 15 of any investigation that was done to determine whether 16 Aroclors had leaked or somehow migrated from the Krummrich 17 landfill? 18 A No. 19 ( Savage Exhibit 91 identified. ) 20 By Mr. Brock: 21 Q I've marked as Exhibit 91 Monsanto's 22 paragraph 1. a submission regarding the Krummrich site.
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1 at the Texas Ecologists landfill?
1 Mr. Savage, rather than have you read through the entire
2 A 1 think 1 was simply responding to Mr. Hosmer's
2 document, maybe it's quicker if 1 could just lead you to
3 memo, Exhibit 89, where he was asking if anybody
3 specific sections. Let me ask you to turn to the third
4 disagreed. 1 was just letting Howard know that 1 agreed.
4 page of the exhibit and that talks about something called a
5 Q Do you recall why you expressed agreement with
5 site G. Can you just read through the description of that
6 that?
6 and let me know whether you're familiar with that area?
7 A No.
7 ( Witness reviewed the document. )
8 Q As a general matter in the 1975 time frame, what
8
If it helps you, there's a mapattached to the
9 were the nature of your responsibilities, if any, with
9 end. There's a G.
10 regard to disposal of Montar or Montar residues in
10 A Yes, 1 see on the map. 1 don't recognize that
11 landfills?
11 area.
12 A Montar is the name we gave to still residue from
12 Q Okay, in the fourth paragraph underthe heading
13 the Aroclor process and the normal procedure at that time
13 for site G, there's a statement that" soil sampling at this
14 was to burn the residue in the incinerator. It proved to
14 site revealed high concentrations of organics, particularly
15 be quite difficult. So it's referred to here as some
15 Pcbs." Do you see that?
16 temporary expedient until that operation can be approved -- 16 A Yes.
17 improved. But 1 don't remember the specifics of this
17 Q Does that refresh your recollection at all as to
18 incident of this particular memo.
18 Pcbs having been found to have migrated or leached from any
19 Q Aside from the use of landfills for disposal of
19 off-site disposal area associated with the Krummrich plant?
20 Montars as a temporary expedient, do you recall any
20 A No. 1 never had anything to do with any off-site
21 discussions of whether -- strike that.
21 disposal area.
22 When you say you were involved in decisions of
22 Q Did it ever come to your attention that Pcbs had
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 380 - 383
HARTOLDMON0010197
Page 384
Page 386
1 been found to have migrated or leached from any off-site 1 production at Anniston.
2 disposal area associated with either the Krummrich or 2 Q When you were production supervisor at the
3 Anniston plant?
3 Anniston plant, what was the impetus for you being provided
4 A No.
4 with information concerning discharges of Pcbs to Snow
5 Q What about the Newport plant, did migration or 5 Creek?
6 leaching of Pcbs from an off-site disposal area come to 6 A 1 don't remember that 1 had any data while 1 was
7 your attention in connection with the Newport plant?
7 production supervisor.
8 A No.
8 Q And again, what would have been the route by
9 (Recess.)
9 which the Aroclors from the Anniston Aroclor department
10
(Savage Exhibits 92 and 93 identified.)
10 reached Snow Creek?
11 By Mr. Brock:
11 A It would have been through the plant sewers and
12 Q I've marked Exhibits 92 and 93 for the record. 12 then through the limestone bed in the front yard, a
13 Mr. Savage, is Exhibit 92 a copy of a November 6, 1975 13 discharge to the limestone bed went into Snow's Creek which
14 memorandum to you concerning Pcb disposal data?
14 was across the highway, as 1 recall.
15 A Yes.
15 Q Number 2 refers to data on fish samples taken by
16 Q Could 1 ask you also to pull out what had been 16 Gunning and Sutkus. Do you see that?
17 marked as Exhibit 82 previously.
17 A Yes.
18 A Okay.
18 Q Do you recall requesting or receiving data on
19 Q Exhibit 92 starts off with the sentence " Jim, per 19 fish samples in connection with the Anniston plant?
20 our telephone conversation this morning you will find 20 A No, 1 was familiar with the existence of such
21 attached copies of all of the plant liquid effluent
21 data but 1 don't recall asking for it.
22 analytical data which we still have in our files for the
22 Q Who were Gunning and Sutkas?
Page 385
Page 387
1 period 1/1/71 through 6/30/75." Do you see that?
1 A They're consultants.
2 A Yes.
2 Q Did you ever deal with them?
3 Q When we were talking about Exhibit 82 which is
3 A No.
4 dated four days later, 1 think you stated you didn't recall
4 Q Did those refer to individuals?
5 making such a request. Does looking at Exhibit 92 refresh 5 A Yes, 1 think those are two people who are -- who
6 your recollection about making a request to Mr. Tafey to
6 were partners in some kind of a consulting firm.
7 generate Pcb disposal data with respect to the Anniston
7 Q Do you know what the consulting firm was, what
8 plant?
8 the name of it was?
9 A This appears to be responsive to the same request
9 A 1 think that was the name of it, Gunning and
10 but 1 don't remember making it.
10 Sutkas.
11 Q There's a reference to effluent to Snow's Creek,
11 Q There's handwriting at the bottom that appears to
12 is reported through October of 1972?
12 me to say" Jim, disposal to landfill follows." Do you see
13 A Yes.
13 that?
14 Q Do you see that?
14 A Yes.
15 A Yes.
15 Q Do you recognize that handwriting?
16 Q Do you recall being supplied at any time with
16 A 1 don't exactly recognize the handwriting but
17 information concerning the discharge of Pcbs from the
17 that little symbol on the end 1 think is a stylized T. And
18 Anniston plant to Snow Creek?
18 1 think that's a way that Bill Tafey may have signed an
19 A 1 think that at the time Anniston was producing
19 informal comment like this.
20 Pcbs and 1 was manufacturing manager, that they gave me 20 Q Do you know what that refers to," disposal to
21 that kind of data on a routine basis. This memo being
21 landfill follows"?
22 dated in 1975 was considerably after we had stopped
22 A 1 think it refers to the memo of November 10
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 384 - 387
HARTOLDMON0010198
Page 388
Page 390
1 where he gives me data on disposal to the landfill.
1 Q Do you recall there being an investigation into
2 Q Fair enough.
2 the disposal of chlorinated terphenyls to the landfill
3 Do you recall asking for or being supplied with
3 associated with the Anniston plant?
4 any sediment analysis or water analyses?
4 A 1 don't remember any specific investigation.
5 A No.
5 Q Let's go to the second page of the exhibit where
6 Q Referring to Exhibit 93, that appears to be a
6 it states " none of the information has been reviewed by
7 memorandum dated December 5, 1975 from Tafey to Art Leisy
7 legal or business group." Did you have the understanding
8 at the Krummrich plant regarding Pcb/epa?
8 around this time frame, meaning 1975, that Monsanto's legal
9 A Yes.
9 department was looking into the questions of whether and
10 Q Do you recall there being interactions between
10 how much Monsanto - whether Monsanto had disposed of Pcbs
11 Tafey and Art Leisy at the Krummrich plant regarding
11 or chlorinated terphenyls to landfills and how much?
12 Pcbs - regarding Pcbs around this time frame?
12 A No, 1 don't know why Bill made that comment.
13 A 1 don't know about the time frame but bill and
13 Q And business group, what does that refer to?
14 art knew each other and I'm not surprised that they had
14 A Business group referred to Howard Bergen and his
15 such an interaction.
15 staff, which included me.
16 Q Down below - what are chlorinated terphenyls?
16 Q In Exhibit 92 up in the top right-hand corner
17 A We made two different lines of Aroclor. One was
17 there's some handwriting where it says " Fepa," is that your
18 chlorinated biphenyl and usually was sold with a four-digit
18 handwriting?
19 number beginning at 12, such as 1242 and so forth. We had
19 A 1 don't think so.
20 another line of Aroclors which were not - which were
20 ( Savage Exhibits 94 and 95 identified.)
21 chlorinated terphenyl. And those were generally sold with
21 By Mr. Brock:
22 numbers beginning with 54 such as 5460. So they were made
22 Q I've marked Exhibits 94 and 95 for the record.
Page 389
Page 391
1 in some of the same equipment and made in a similar way but 1
Mr. Savage, I'd like you to take a moment just to
2 they were chemically different.
2 glance through Exhibit 94. And if it speeds your review,
3 Q Had the concerns that had been raised with
3 your name is referenced on the page that ends in Bates
4 respect to -- strike that.
4 number 682. Once you've had a chance to do that, can you
5 Had the environmental concerns that had been
5 identify what this is for us.
6 raised with respect to polychlorinated biphenyls also been
6 A It's an emergency plan by John Zeman and several
7 raised with respect to chlorinated terphenyls?
7 other people written in early 1976. It appears to be a
8 A Not in the same way. As far as 1 know
8 contingency plan for the possible event of a ban on Pcbs.
9 chlorinated terphenyls were never found in the environment, 9
Q If you look on page-the page that ends in
10 meaning in fish samples and such.
10 Bates number 682, the category for the letter G is " defined
11 Q Did you have an understanding one way or the
11 detailed decontamination procedure for use at Krummrich
12 other about whether chlorinated terphenyls would behave
12 and " other --" and possible adaptation for customers." And
13 differently in the environment?
13 it says " responsibility, J. R. Savage." Do you see that?
14 A Chlorinated terphenyls were generally solids,
14 A Yes.
15 whereas chlorinated biphenyls were generally liquids.
15 Q Let's take a look at Exhibit 95. Is that your
16 That's not an absolute distinction because a highly
16 outline in response to being assigned that responsibility?
17 chlorinated biphenyl could be a solid and a low chlorinated
17 A Yes.
18 terphenyl could be a liquid. But in general, that was the
18 Q Do you recall how you came to be assigned the
19 distinction and since the chlorinated terphenyls were
19 task of defining decontamination procedures for use at the
20 generally solids, it was -- there didn't seem to be any
20 Krummrich plant?
21 reasonable way that that material would wind up in an
21 A Not exactly. Sometime in late 1975 the specialty
22 aquatic environment.
22 products group was merged with another business group, John
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 388 - 391
HARTOLDMON0010199
Page 392
Page 394
1 Zeman was a part of that other business group. There were 1 Q The purpose of the incinerator at the Krummrich
2 two manufacturing managers, Bob Pohl and me and one of us 2 plant, the Aroclor incinerator was to deal with liquid
3 was redundant and that turned out to be me. By 1976 1 did 3 wastes from the Aroclor operations ; correct?
4 not have a permanent assignment so 1 assume this was some 4
A Yes, but that conflicts a little bit with what 1
5 kind of temporary assignment.
5 just said. We did dispose of the Montar from the Krummrich
6 Q Do you recall coming up with this decontamination
6 operation in that incinerator by keeping it very hot and
7 plan?
7 mixing it with some liquid waste. By that time we were
8 A Now that 1 see it, 1 recall having worked on
8 getting some return material from customers which we could
9 something like this, yes. 1 had forgotten about it.
9 mix with the Montar to make it a little easier to handle.
10 Q Do you recall what you did to come up with the
10 Q Before the incinerator was constructed at the
11 decontamination plan?
11 Krummrich plant, had the liquid wastes that were
12 A 1 would have developed this information by
12 subsequently handled in the incinerator, had those been
13 consulting with the plants where we had already taken
13 sent to the landfill, to your knowledge?
14 certain Pcb equipment out of service and therefore would
14 A Well, 1 don't recall that we had liquid waste.
15 have had to go through a procedure like this.
15 This sounds a bit confused. The Montar could be handled as
16 Q Under the third entry under category B in Exhibit
16 a liquid by keeping it very hot. But when it was hauled to
17 95 where it says " drums to be disposed of and approved
17 a landfill, it was hauled in solid state. 1 really never
18 landfill." Do you see that?
18 witnessed what became of the material when it was taken.
19 A Yes.
19 Presumably it went to the landfill.
20 Q Do you know why that was recommended? And I'm 20
( Savage Exhibits 96 and 97 identified. )
21 thinking in light of your earlier statements that
21 Mr. Brock: For the record I've marked as
22 incineration was being investigated at around this time.
22 exhibits, Exhibits 96 and 97. Both are dated August 1,
Page 393
Page 395
1 A Well, if you'll refer to item 2 just above
1 1972.
2 " solids to be placed in drums along with used gloves,
2 By Mr. Brock:
3 rags " and so forth, 1 think the third item," drums to be
3 Q Referring first to Exhibit 96, Mr. Savage, is
4 disposed of in approved landfill" refers to the drum in
4 this a memorandum from E. E. Stewart to yourself along with
5 that item 2 containing solids. The incinerator that we had
5 some others with an attachment that was sent to you or
6 built at Krummrich plant was only designed for liquid feed
6 directed to you during the course of your employment with
7 and therefore could not take this kind of material.
7 Monsanto?
8 Q By this time had Monsanto - strike that.
8 A Yes.
9
Around this time frame was Monsanto disposing of
9 Q Is that your writing up in the top right-hand
10 liquid Aroclor wastes in any landfills that you know about
10 corner?
11 associated with the Krummrich or Anniston plant?
11 A Yeah, that appears to be my writing.
12 A 1 don't know.
12 Q There's a paragraph that reads " the attached memo
13 Q In the early - in the late ' 60s and early ' 70s
13 was prepared as a document that could be passed to the
14 do you know whether Monsanto was disposing of liquid
14 federal authorities in the event we were asked ' what have
15 wastes - liquid Aroclor wastes at the Krummrich or
15 you done at Wgk in the past to control Pcb entrances into
16 Anniston landfills? I'm taking the question back to the
16 the environment. '" Do you see that?
17 earlier time frame.
17 A Yes.
18 A Not that 1 know of. Montar still residue was
18 Q And then down below it makes a reference to
19 drawn from the stills as a liquid but it had a very high
19 having the " document (in hand )" to give to the federal
20 melting point so it would be a solid at the time that it
20 authorities in the event that Monsanto was asked for such a
21 was disposed of. That's the only waste from the Aroclor
21 document. Do you see that?
22 department that 1 can recall having gone to the landfill.
22 A Yes.
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 392 - 395
HARTOLDMONO010200
Page 396
Page 398
1 Q Do you recall what the impetus was for coming up
1 them?
2 with a prepared statement to give to the federal
2 A As far as 1 know, no.
3 authorities in that event?
3 Q Let's go to Exhibit 97. Is this a copy of an
4 A No, 1 don't know of any reason to expect -- for
4 August 1, 1972 memorandum from E. E. Stewart to you in the
5 the plant to have expected to be asked for that.
5 course of your employment with Monsanto?
6 Q And again this makes reference to things that had
6 A Yes.
7 been done in the past at the Wgk plant. Does this refresh
7 Q Who is G. A. Hippe, H-i-p-p-e, if 1 pronounce his
8 your recollection as to whether or not there was any
8 name correctly?
9 concern that the Epa was going to be focusing on discharges 9
A Yes, that's correct, Gail Hippe.
10 that had gone on in the past at the Wgk plant?
10 Q What was his position?
11 A Well, it appears that the time span of this
11 A 1 think he was a production superintendent at the
12 attachment begins in 1969 and covers events from then
12 plant at that time. 1 don't know why he's got a copy of
13 through the date of the memo, so 1, as far as 1 can
13 this.
14 interpret this, it was a fairly recent series of events
14 Q Can 1 turn you to the page that ends in Bates
15 that they were summarizing.
15 number 669. Stewart mentions that he had prepared a
16 Q 1 would agree with that. In fact on the page
16 " chronological history of actions taken at Wgk to reduce
17 that ends in Bates number 202 it starts with the sentence
17 Pcb entrances into the environment." Do you see that?
18 " during the past three years, varied actions have been
18 It's up at the very top of the page.
19 implemented at the W. G. Krummrich manufacturing facilities 19 A Yes.
20 to restrict and reduce Pcb entrance into the environment."
20 Q Do you recall having any role in the preparation
21 Do you see that?
21 of that chronological history of actions?
22 A Yes.
22 A No, 1 don't recall.
Page 397
Page 399
1 Q Do you know how it was chosen to go back three
1 Q Do you recall what, if anything, you did with the
2 years?
2 information that was provided to you?
3 A No, 1 don't.
3 A No.
4 Q On the page that ends in Bates number 203,
4
( Savage Exhibit 98 identified. )
5 there's a reference to an educational program being
5 By Mr. Brock:
6 " directed to the operating personnel related to good
6 Q Mr. Savage, is Exhibit 98 an August 6, 1970
7 housekeeping and the need for care to control and contain
7 memorandum that was sent to you and some others in the
8 Aroclor wastes in the manufacturing areas." Do you see
8 course of your employment?
9 that?
9 A Yes.
10 A Yes.
10 Q Who was Milton Beaudine?
11 Q Do you know what that educational program
11 A Milt Beaudine was at the Krummrich plant at that
12 consisted of?
12 time. 1 don't know what his responsibility was.
13 A No.
13 Q In the second indented paragraph under--in the
14 Q Do you recall there being additional educational
14 number one section there's a statement" returned drummed
15 efforts along those lines being made around this time
15 material from customers is being collected on the south lot
16 frame?
16 to be held until the incineration unit is on line." Do you
17 A No, that would have been done at the plant and 1
17 see that?
18 would not necessarily be involved in that.
18 A Yes.
19 Q Do you know whether this information was in fact
19 Q Do you know what that reference to the south lot
20 ever requested by the federal or state authorities?
20 refers to?
21 A Not that 1 know of.
21 A No, it's just some empty space in the plant.
22 Q So to your knowledge it was never provided to
22 Mr. Brock: Off the record.
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 396 - 399
HARTOLDMONO010201
Page 400
Page 402
1 ( Discussion off the record. )
1 torrential rains as one possible reason for an upward trend
2 By Mr. Brock:
2 in the Pcb losses for the month of August, 1972. Would you
3 Q Mr. Savage, let me ask you to take a look back at
3 interpret this the same way?
4 Exhibit 91. The second page of that, number 2 discusses
4 A Yes it's a speculation apparently.
5 something called " south lot drumsite." Do you see that?
5 Q I called it a postulation. Are you aware of any
6 A Yes.
6 discussions along the lines of whether rains - whether
7 Q Looking at that do you believe that the reference
7 discharges from the plant - from the sewers meaning
8 to the south lot drumsite in Exhibit 91 is the same south
8 discharges from the sewers rather than to the sewers had
9 lot?
9 increased as a result of heavy rains? That was one effect
10 A It seems likely.
10 of the rains? Let me rephrase.
11 Q From your time at the Krummrich plant or from
11 Mr. Burnett: Yes. It's kind of confusing.
12 your subsequent responsibilities, were you familiar with
12 Mr. Brock: I agree with that.
13 the operations or activities in that south lot area?
13 By Mr. Brock:
14 A No.
14 Q Do you recall there being any discussions about
15 Q Were you familiar with the fact that it was used
15 whether heavier than normal rains had been attributed to or
16 for a storage of drums?
16 correlated with or the cause of any discharges of Aroclors
17 A Yes, I knew there was such a place but I would
17 or Pcbs from the sewers, meaning in terms of leakage or
18 have no reason to be concerned about it.
18 that type of thing?
19 Q Why was that?
19 Mr. Burnett: I object to the form of the
20 A Well, drum storage was handled by the
20 question. I think it's vague and confusing, but you can
21 shipping/warehouse department and not by any department 21 answer if you can.
22 that I had any responsibility for.
22 The Witness: I don't think I can answer it.
Page 401
Page 403
1 ( Savage Exhibit 99 identified. ) 2 By Mr. Brock:
1 This is just a hypothesis and I don't recall having
3 Q Mr. Savage, is Exhibit 99 a copy of a September
2 discussed that as a specific reason for losses going up or
4 1,1972 memorandum sent to you or directed to you from E. E
5 Stewart in the course of your responsibilities with
3 down.
6 Monsanto? 7 A Yes. 8 Q Let me ask you to turn to the second page of the
4 By Mr. Brock: 5 Q Do you know whether that hypothesis was ever
9 exhibit. The end of the first paragraph on that page 10 contains a sentence which reads " torrential rains may have
6 checked out?
11 resulted in groundwater flows to sewers and sewer system
7 A No.
12 purging actions." Do you see that? 13 A Yes.
8 Mr. Brock: All right. Now is probably a good
14 Q What are sewersystem purging actions? 15 A That's not a term that would normally be used 16 about sewers. It seems to imply that the unusual flow from
9 time to stop. 10 ( Whereupon, at 5: 50 p. m. , the deposition was
17 the groundwater - from the rain resulted in flows 18 sufficient to flush out anything that was present in the 19 sewer that might otherwise have accumulated there.
11 adjourned, to reconvene at 9: 30 a. m. , on Thursday, May 20, 12 1993. )
20 Q Do you know whether the concern had ever been 21 expressed - strike that.
13
----------------------------
22 As I interpret this, this is postulating the
14
James R. Savage
Savage, James (Aroclor Dept employee) in AETNA (2)
Pages 400 - 403
HARTOLDMONO010202
[& - 292]
Transcript Word Index
& 11/30/71
1958 (cont.)
2/3/76
& 204:9 205:2 206:15,16,20 206:25
0
206:14 11/5/71
206:11 11/6/75
206:25
233:4 237:12 253:14 1959
216:1 220:21 230:2 273:2 274:10 1960s
206:27 2/7
310:19311:10 20
335:10 403:11
00 272:11 302:8
0008693 299:6
1105 310:18 311:2,3,5,9
112 216:2
353:8 354:10,16 355:12 356:16 357:14 1966 350:20 352:15
2005 205:11
202 396:17
0008737
118-1
1969
203
294:6 0134909
292:11 0248542
294:4
204:8 12
302:7 388:19 12/2/71
206:15
357:19 396:12 1970
278:6,9 345:13 351:12 354:5 399:6 1970s
397:4 2042
351:6 207
206:4,7
0248547 285:14
0248700
12/5/75 206:25
12/8/71
373:11 1971
281:2 285:14 287:21
223 363:19
24
299:5 0291924
278:6 05
303:1
206:15 1211651
264:5 1220
204:18
289:11 290:1 292:11 294:4 288:5 300:5 378:3
294:5 382:11
2429
1972
287:8
299:4,6,7,16 306:20 307:11 243
308:16 309:17 312:9
278:21
0546027
1242
315:17 321:2 323:18 327:4 246
221:2 0546030.01
221:2 061
388:19 13
299:6 337:3 14
336:15 337:3,12 340:1 343:7 344:21 346:14 347:16 348:10 350:4 357:19 372:21 385:12
206:19 279:7,13 297:18 298:16311:11 247 322:15
362:12
360:6
395:1 398:4 401:4 402:2 25
1 15
1973
278:6
1
367:12 368:4
330:5,13 333:2 358:14,17 250
206:24 299:22 327:4 343:7 1539108
1974
323:7
379:15 382:22 394:22
303:14
333:22 335:11 360:6 363:1 251
398:4 401:4
1539111
364:5 378:4
278:22 322:16
1.0
216:2
1975
26
289:19
1539113
366:15 367:12 369:11
363:1
1/1/71
213:3
371:14 380:10,13 381:8 264
385 1
1539114
384:13 385:22 388:7 390:8 206:8
1/13/72
212:13
391:21
27
206:16
1539115
1976
380:10
1/4/72
207:15
391:7 392:3
278
206:16
16
19801
206:9
10
344:21
205:5
28
272:11 369:11 372:21
19
1993
336:15 380:13
387:22
204:15 346:14 373:11
204:15 403:12
280
10/24/74
19103
2 206:10
206:21 10/9/74
379:10 109
303:14 11/2/71
206:10 11/26
296:5
205:12
2
285
1950s 265:3
204:13 258:4 281:2 287:21 294:4 302:8 303:1 308:15
206:11 287
1956
317:16 321:2,6 327:9 333:2 206:12
230:12 1957
352:10,12,15 1958
207:14 208:9 216:1 217:14
362:4 363:4 4004 2/19 31111
386:15
393:1,5
289 206:13
292 206:14
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMONO010203
[294 - 88]
294 41 58 70s
206:15
213:2
306:20
232:17 237:15,21 254:22
299 42
59
346:11 393:13
206:16
215:22
308:15
71
3 43
6 336:14
220:15 229:1 235:12
ft
72
270:1 277:6 283:15 300:16 309:17 334:20 339:14 349:12,15 363:19 30
44 262:1 267:2
45 206:7 207:7,12 272:20
306:9 315:17 384:13 399:6 6/30/75
385:1 60
339:22 382:11 73
343:6 74
288:5 292:10 340:1 403:11 46
309:16
344:20
303 206:17
31 216:1,1 217:14
3-1/2
206:8 264:2,4,8 271:1 47
206:9 278:3,5 48
206:10 280:22 281:1
600 278:22
60s 232:17 254:22 255:1 353:2 353:21 393:13
740 294:6
75 346:13
76
309:21
285:17
61
358:13
3438 297:17
49 206:11 285:12,13 287:7
312:8 62
77 360:5
350 205:3
36
5
5 207:14 285:14 289:11
315:13 622
324:2
78 362:22
79
300:6
333:22 355:15 362:4 388:7 63
364:4
372
403:10
318:21 347:21 351:4
8
206:20
5/22/75
64
8
376
206:22
321:1 351:3
294:5 371:14
327:22
5/28/75
65
8/1/72
377
206:23
299:7 323:18
206:28
206:21
50
66
8/22/73
380
204:19 206:12 285:14
327:3
206:20
206:23
287:19,21 302:7 403:10 669
8/6/70
382 500
398:15
206:29
206:24
213:9
67
80
384 50s
330:4 347:21 351:3,4
366:8
206:25
232:17
68
81
39 51
333:2
367:11
206:7 207:7,12,13
206:13 289:9,11
682
82
390 52
391:4,10
369:10 384:17 385:3
206:26,27
206:14 292:8,10
689
84
394 53
326:10
206:17 303:7 371:13
206:28
206:15 294:2,3,8,16,19 69
841
399
295:5 296:4 297:9
333:21
351:6
206:29
54
696 842
4 A
262:13 299:4,7,16 312:8 318:14,15 339:14,16 4/7/70 206:9 4/9 217:6 40 212:6 238:16,21 239:5 401 206:30
206:15 294:2,5,12 295:15 388:22 546 294:4 5460 388:22 55 206:16 278:21 299:2,4,16 56 206:16 299:2,5,11 300:16 57 206:17 303:7,11
299:6
351:22
7 85
7 278:6 323:18 330:5 358:17
7/10/72 206:20
7/2/71
206:18 350:17 85/71
206:13 86
206:20 372:18,20
206:12 70
254:17 335:10 702
299:5
87 206:20 350:15 372:18 375:14
88 206:21 377:22 378:2,3
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMONO010204
[88c - analytical]
88c acceptable
204:8
375:17
89 accepted
206:22 380:6,8,9 381:3
362:21
9 access
9 235:1
204:19 273:2 364:5 403:11 9/1/72
206:30 90
accessibility 258:6
accident 222:18,19 227:5 313:4
206:22 380:6,8,13,20
accomplish
902 205:4
91 206:24 382:19,21 400:4,8
910
263:18 accomplished
224:18 accumulated
401:19
292:11
accumulating
92 206:25 384:10,12,13,19
245:6 accuracy
385:5 390:16 93
206:25 384:10,12 388:6
309:10 310:12 accurate
329:18
94 206:26 390:20,22 391:2
accurately 245:2
944 352:4
947
acetone 243:8,14 244:22 245:3,3,6 245:9,11,12,18,18 246:2,6
355:2 948
achieved 359:8
357:7
achieving
95 206:27 390:20,22 391:15 392:17
96 206:28 394:20,22 395:3
265:11 acid
240:5 260:20 acs
232:2,10
97 act
206:28 394:20,22 398:3 98
206:29 399:4,6 99
206:30 401:1,3___________
241:6 action
204:7 224:6 320:20 341:8 366:21 actions
293:21 316:15 396:18
a 398:16,21 401:12,14
ability
activated
248:8
265:21,21 266:3
able
actively
244:21 247:17 317:3
376:7
abnormal
activities
310:15 320:13
229:4 326:10 400:13
abreast
activity
230:2,5
376:10
absolute
actual
389:16
355:19
absorb
adaptation
256:3
391:12
add 272:18 280:6 300:9
added 251:17 333:7 352:13,16 353:1,3,12,12,14,16
adding 352:19
addition 251:2 268:5 276:17 293:21 340:22
additional 234:10 259:12 295:10 331:16 375:9 397:14
additionally 375:4
additions 282:2
address 360:20
addressing 291:22 306:10,15,17 310:11 326:6 341:21 347:18
adjacent 313:15,18,21 314:3 315:7
adjourned 403:11
adopted 277:22
adversely 237:6
advice 344:13
advise 374:9
aetna 204:9
afternoon 303:1
agencies 301:22 338:3 339:1 348:5
agent 245:9
agents 212:14,16
agitated 255:13
ago 222:5
agree 396:16 402:12
agreed 271:15 381:4
agreeing 271:21
agreement 204:17 381:5
ahead 314:9 319:9
air 248:22 249:9,10 252:1 280:4 369:16
al 204:10 232:10
alabama 300:20
alcohol 240:19,19 241:7
alerted 270:11
alive 254:16 373:5
alkali 260:21
alleged 332:22
altered 297:20
alternate 363:14
alternative 363:14
alternatives 375:15 376:3
amalgam 259:12
ambiguous 320:3 329:9
amendment 351:8,14
amendments 350:21 351:10
american 230:11 232:2,5
amount 244:8 249:3,11 251:17 256:7 261:20 289:17 290:4 317:19318:1,10,11
amounts 255:18 257:3,10
analogous 313:4
analyses 369:16 388:4
analysis 276:15 334:22 335:2 369:16 388:4
analytical 291:14296:14318:9 384:22
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMONO010205
[analyze - august]
analyze
applicable
aroclor (cont.)
associate
300:11
361:6
352:11 353:4 355:13,19
230:16
analyzed
application
356:11,17 358:1,7,10 360:4 associated
269:12,14
255:16
363:4,11,15 365:13 380:18 230:7 272:12 383:19 384:2
anderson
applied
381:13 386:9 388:17
390:3 393:11
205:2
368:16
393:10,15,21 394:2,3 397:8 association
ann
appoint
aroclors
230:10 360:13
207:15 212:13 213:3 216:2 223:8,9
206:19 250:11,13 274:6 assume
264:5 303:14
approach
291:12,20 350:20 357:19
374:10 392:4
anniston
209:6 317:19
361:7 373:8,12 374:22
assumed
206:8 208:9 209:7,10
appropriate
382:16 386:9 388:20
359:9
211:12212:4 217:22
246:19 370:15
402:16
assured
221:19 222:11 229:12,15 approval
arrange
291:17
230:4 232:21 233:1 234:16 345:4
343:14
asterisk
236:16 237:17 238:16
approve
arranging
371:18
244:10 250:14 253:19
351:14
215:9
atmosphere
255:2 259:4,8 260:2 262:3 approved
arrived
263:17
262:14 264:6 266:21
381:16 392:17 393:4
256:1 272:5 318:3 328:4 atmospheric
268:22 270:21 273:17
approving
arrow
352:6 353:6
289:16,22 290:5 291:8,22 351:16
221:5 264:20 273:3 336:18 atrophy
300:17 301:2,16,21 305:5 april
375:8
357:9
305:18 322:3,11 330:2
278:6,9 312:8 315:17
art
attached
334:21 335:3 352:11 358:1 333:22 336:15 337:3,12
308:2,3 330:22 332:3
253:11 319:20 383:8
358:8 365:14 369:19 370:7 aquatic
339:16 388:7,11,14
384:21 395:12
371:10 384:3 385:7,18,19 389:22
articles
attaching
386:1,3,9,19 390:3 393:11 aqueous
231:10,16
216:1
393:16
249:15 269:2 277:14,15 art's
attachment
annual
arbitration
293:4
319:12 336:16 395:5
221:17
204:9
ash
396:12
anomalous
area
241:15,16,17,18 242:1,5 attasorb
310:4
222:12 260:13 271:1,2
243:5
255:6
answer
281:10 282:14,18 285:21 ashes
attempt
314:9 322:2 402:21,22
311:11,14313:7,15,18,21
243:3
310:13
anybody
314:3 315:7,8,8,10 332:9 aside
attempts
213:21 254:11 283:7
342:8 349:12,15 368:20
341:5 381:19
259:19 326:17
293:14 354:21 361:9 381:3 375:11 383:6,11,19,21
asked
attend
anyway
384:2,6 400:13
293:2,2 304:3 331:13
331:6 361:8,8
243:16
areas
370:22 371:1 395:14,20 attended
apart
397:8
396:5
273:20 331:19 366:1
224:5,12
arley
asking
367:19
apparently
335:19
293:18 371:11 381:3
attending
347:9 362:21 368:3,5 372:1 arnie
386:21 388:3
273:10 331:17 344:16
402:4
335:19
aspects
367:22
appear
aroclor
361:19
attention
294:21
237:18 243:6 250:19
assemble
310:3,6 324:22 383:22
appearances
252:15 253:19 255:9,10,12 326:11,17
384:7
205:1
258:4,9 260:3,5 266:14 asserted
attorney
appeared
273:9 274:11 275:10,12
342:21
342:5,14 368:19,22 369:3
316:19
281:14,18 282:21 287:17 assignable
attorneys
appears
288:9 289:21 290:4,11,22 318:10
328:16 344:12 345:14
211:20 278:10 298:6
291:2 292:1,2 295:18 300:3 assigned
369:3
303:17 312:9 327:9 335:22 300:18,19 301:1,6,7,8
215:18276:2 391:16,18 attributed
348:21 374:8,14 375:6
308:21 310:18,21 311:2,3 assignment
290:5 310:17402:15
385:9 387:11 388:6 391:7 315:10 319:22 320:7,9
215:20 227:22 392:4,5
august
395:11 396:11
322:7 323:15,22 324:4
assistance
289:11 394:22 398:4 399:6
327:9,17 334:3,7,16 351:11 251:1 357:4
402:2
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMONO010206
[authentication - built]
authentication
basins
212:7
361:13
authorities
basis
326:12,18 330:1 343:12,13 221:17 266:9,12 268:1
343:19,20 344:1,2,13,18
279:1 311:5 385:21
345:4 395:14,20 396:3
batch
397:20
241:11,14256:8
authorizing
bates
267:13
207:14,14212:12213:3
automate
216:2 221:1 264:5 278:6
241:21
285:14 292:11 294:4,5
available
299:4,6 303:13 322:15
215:19 232:20 239:6,8
323:7 326:9 327:22 351:6
269:18 340:9 369:15
351:22 352:4 355:2 357:7
average
362:12 363:18 391:3,10
317:19
396:17 397:4 398:14
avoid
bearings
355:19
252:19
avoided
beaudine
356:8
399:10,11
aware
bed
212:18 304:8,12 316:9
211:4 386:12,13
329:4 334:11 337:14,16 began
340:18 359:16 364:1
210:11 230:16 265:20
382:14 402:5
beginning
awareness
312:16 351:7 374:11
291:11 355:12
388:19,22
awkward
begins
260:18__________________ 358:20 396:12
b behalf
back 210:10 225:5,22 233:10 235:12 251:10,11 252:9,10 253:11 261:14,17271:1 307:8,15,16,21 340:22
204:20 205:6,13 behave
389:12 behaved
227:2
358:13 379:7 393:16 397:1 behavior
400:3 background
215:15 269:16 292:20 337:7 352:19 bad
234:17 belief
311:21 believe
227:14 314:19 329:17
209:22 210:2 badly
281:11,19285:22 bags
241:18,18
350:3,14 358:9 400:7 bells
380:3 benignus
362:1,2
balance
benzene
247:10,11 248:3,16 276:8 276:14
236:19 237:3,5,9,21 bergen
ban 391:8
based
328:15 341:13 345:22 366:13 380:14 390:14 bernard
237:1 251:7 284:10 basin
380:1 best
321:7,12,16,18 322:3,6,7
248:8,8 306:18 317:7
better
boss
233:4,5 234:21 235:8
221:22 292:19 354:18
255:22 258:6 291:17
bosse
299:18
380:1
beyond
bottom
211:10
212:19 220:7 226:8 245:19
big 260:19 267:1 278:11
242:3 244:16 282:20
289:15 293:3 299:15 306:3
322:13
321:6,10 352:1 355:3
bigger
366:12 387:11
234:21 235:8
box
bill 242:19 264:19
214:2,10 327:15 339:17 boxes
387:18 388:13 390:12
281:10,18 285:21
billing
bratsch
244:3
292:13,18 293:18 319:5
bin 326:2,5
258:5
brawley
biochemical
360:1,3
263:18
break
biological
224:20 225:9 250:8 303:10
243:22 244:2 269:19
brick
biphenyl
251:12
236:13,16 237:3,5,14 239:5 brief
239:7,10,13280:11,12
215:8
355:19 388:18 389:17
brine
biphenyls
243:8,15 244:22 245:14
389:6,15
246:3,6 260:13 261:6,8,9
birmingham
261:10
216:11
broa dwell
bishop
254:14,16
368:11,12
brock
bit 205:7 206:4 207:9 250:7,10
253:10 256:18 284:3,3
264:3 274:17 278:1,4 281:1
394:4,15
281:3 285:1,13,15 287:20
bitty
289:10 292:9 294:3,7
257:20
298:22 299:3 303:9 304:1
biweekly
314:17319:13320:5
297:11
341:17,19 350:10,12
blew
372:19 378:1 380:4,7
224:5,12
382:20 384:11 390:21
blow
394:21 395:2 399:5,22
280:5
400:2 401:2 402:12,13
blowers
403:4,8
339:16
brought
board
342:15 345:9
253:21 341:14
buckley
bob 332:3 333:12 339:17
220:19,19 272:22 332:8
375:12
368:16 392:2
build
bod 313:8
243:7,11,17,19,21 244:3,4 building
265:11,16,17266:17
205:3 219:20 244:13
booby
built
224:17
259:17 315:10 393:6
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMONO010207
[burn - close]
burn
carried
chance (cont.)
chlorine (cont.)
251:15381:14
210:16 241:2 277:20
391:4
261:12,13,14266:16,17
burnett
314:14,19
change
347:22 349:22 350:3,4,8
205:1 274:15 303:19 314:8 carry
241:5 270:11,13 277:21 choice
319:7 320:2 402:11,19
282:5
330:18
325:15
burnout
case
changed
chosen
251:19
204:10 311:6 332:20
225:10 309:7
397:1
burnouts
344:14 376:19
changes
chronological
251:2,5
castle
210:21 211:5 228:15,18
398:16,21
business
204:3
249:16
circle
284:5 317:14 328:19
casual
changing
264:18
332:16 334:14 341:13
208:20 377:7,9,11,12
225:19 352:21
circumstance
342:1 345:13 376:6 390:7 casualty
character
349:3
390:13,14 391:22 392:1
204:9
254:15,18
circumstances
buying
catalyst
characterized
348:16,18
241:18
239:17,18,19
223:5
city
bypass
catch
charges
210:1 211:12214:12215:1
271:16
361:13
262:5
215:3 218:16,22 219:7,9,10
bypassing
categories
charging
219:16 220:8 243:7,12,20
271:22
319:20 352:19
244:4
244:10,12,14,15,17,20
c category
chart
262:5 270:2,18,20 272:15
calcium
230:1 235:12 236:12,18
319:20
272:17
2458 12 calculates
278:11 279:4 352:11,13 checked 353:1,3,16 363:4,19 391:10 403:6
city's 220:9
247:16 call
304:2
392:16 caught
280:9 310:3,6
chemical
civil
230:7,12,15 231:6,21 232:1 204:7
232:2,2,3,5,17 247:14
claims
called 204:16 212:7 215:8 231:5
cause 223:4 225:7 257:2,10
301:6 314:11 356:1 chemically
228:19 332:10 342:21 clarence
231:21 232:1 241:14 242:7 289:21 306:6 357:8 402:16 255:19 257:4,17 389:2
221:12
246:14 252:19 255:5,11,15 255:20 257:19 260:14 261:19 270:22 284:6 285:2 292:21 329:2 331:10 354:7 383:4 400:5 402:5
caused 223:6,17 289:18
causes 223:12 310:18
caustic
chemicals 210:19 227:8 233:18,21 234:18 236:9,10 356:4,7
chemist 216:20
clarey 332:3 333:12 375:12
clarity 265:2
class
calls
261:20
chemistry
257:2
304:4 Campbell
373:2,8 capabilities
322:22
cc's 349:17
cell 259:15 348:1,1
cells
230:7 Chester
350:1 chief
216:20
clay 255:7,11,12,21 256:2,5,7,8 256:12 257:14
clean 358:3
capacitors 257 8
capacity 236:16 237:6,13 250:22 260 10
259:12,16 260:1 261:6 central
235:1 375:16,22 376:7,15 centralization
258:5
chloride 245:8,12 257:1
chlorides 257:10
chlorinated
clear 218:12298:8 370:14371:6
cleared 371:4
clearly
capitalized
certain
211:2 280:12 388:16,18,21 346:4 352:21
31221 carbonate
230:17 255:13 289:5 301:5 389:7,9,12,14,15,17,17,19 cliff
322:16 392:14
390:2,11
208:3,13 209:3,16 210:16
242:6,7 carbonless
372:6
certainly
chlorination
232:20 283:4 312:6 324:21 211:1,8 214:3 250:13,16
chairman
chlorinators
212:9 213:5 216:10220:5 262:2 266:2 269:16 cliff's
care 397:7
341:14 chance
226:22 chlorine
214:1 close
career
207:16 216:3 220:16
212:14,17 239:7,8 259:4,10 377:14
208:13,16 209:4 229:6
312:14 315:19 330:9 337:8 259:21 260:1,6 261:7,7,9
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMONO010208
[closed - content]
closed
company
condition
consist
228:3 377:8
204:5,9 205:6,13 234:9
310:15
233:14 235:21 261:2
coated
334:13
conditions
273:21 277:14
332:21
compartment
223:6 228:21 355:7
consisted
coatings
321:17
conduct
208:19210:17235:10
259:20
competence
223:11
251:12257:17260:22
coil
344:11
conducted
276:7 280:10,11 315:8
251:2,5,10,13,19 252:1,8 complain
212:21,22 365:4,10
322:9 397:12
coils
324:21
conducting
consistent
251:15
complaint
213:15
296:12 309:4
collected
304:17
confident
constructed
226:2 399:15
complaints
248:2 257:16
259:16 321:19 394:10
collection
228:20 304:20 305:4,10 configuration
construction
350:21
complete
225:10
313:8,9,12 378:20
collectively
243:1
confined
consultants
256:14
completed
224:4
387:1
Collinsville
259:12 378:21
conflicts
consulting
347:4,5,6
completion
394:4
236:8 345:14 387:6,7
color
241:1 253:2
conform
392:13
212:20,21
complicated
362:5
consumed
colorful
282:4 296:13
confused
311:16
254:15,18
compounds
351:21 394:15
consumption
column
210:20 257:2
confusing
239:19
245:17,19,20 335:15
comprehensive
402:11,20
contact
combined
235:2
connect
284:15 314:12 328:1,9
244:17
compressor
335:16
338:19 343:22 344:8,9
combustion
238:22 239:11
connected
345:19 355:19 356:8,10
243:2
conceivable
261:4 370:9
358:3,4 365:1
coming
317:17
connection
contacted
210:3 214:16261:11
concentration
276:22 291:11,22 293:11
329:6 338:5
266:14,20 332:12,15
244:9
306:21 322:7 327:5 333:13 contacting
333:10 343:18 359:3,5
concentrations
335:3,20 338:6 346:15
346:1
392:6 396:1
315:6 383:14
347:7 349:4,6 356:21
contacts
comment
concern
358:15 360:7 363:2 364:6 297:14 329:22 338:19
307:2 338:1 387:19 390:12 247:3 249:12,12 252:11,14 367:13 369:11 371:15
342:3 343:22 344:2
commenting
315:22 316:10,19,20
372:22 378:4 380:11,14 contain
328:6
340:13,16 348:5 353:5
382:13 384:7 386:19
313:14 397:7
comments
396:9 401:20
connotation
contained
339:14
concerned
217:2
225:18 227:10 242:5
commerce
237:13 325:2 348:16 349:1 consent
310:22 342:1
205:9
400:18
359:13
container
commission
concerning
consequence
253:10 256:13,20
217:16,17 218:22 219:7,8 215:15 217:22,22 218:10
286:7
containers
commissions
234:17 254:1 263:9 274:3 consider
226:9,11 256:17
217:19
301:20 304:9 305:11,15
319:21 320:6 340:18
containing
committee
307:9 317:5 322:21 326:6 considerably
233:17 242:16 393:5
223:9,10 362:14
327:17 329:5 330:1 331:6 385:22
contains
committees
337:13 339:9,11,12,20
consideration
309:20 401:10
222:18,19 227:6
340:2,4 341:7 347:11 348:9 342:20 382:9,13
contaminated
common
348:10 364:21 365:2 367:8 considerations
333:1
242:6 314:10
373:8 377:3 384:14 385:17 382:12
contamination
communication
386:4
considered
293:20
338:3
concerns
211:9 228:4 268:7 319:5 contemplations
companies
214:16 243:19 258:14,21
356:5 382:2,8
275:6
302:4 360:15,18,19 361:1,7 342:3 347:13 389:3,5
considering
content
213:14
353:9,18
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMONO010209
[contents - decided]
contents
copy
course (cont.)
damaging
225:12 236:2
212:10 221:3,5 273:4 278:7 284:4 288:1 289:13 292:14 214:12,17,20
context
303:19 306:21 315:14
294:9 299:8 303:16 308:17 dan
278:18 279:14 307:14
319:2 327:3,14 330:4 331:5 309:18 312:10 315:15
368:12
335:7,9
333:21 336:14,18 339:22
318:22 321:4 323:19 330:6 data
contingency
343:6 344:20 346:13
333:3 334:1 335:11 343:7 214:12,17 215:3 234:3,7,9
391:8
347:17 351:8 358:13 360:5 358:21 359:7 395:6 398:5 246:9,21 265:12,14,15
continually
362:22 364:5 366:15,22
399:8 401:5
266:2 274:7,12,21 275:3,4
252:3
367:11 369:10 371:14
courses
307:4,9,16 358:9 369:15
continue
372:6,20 375:7 378:3 380:9 208:21 229:11,12,14,19
370:14,16,21,22 371:4,5,9
317:18 318:4 324:4
380:13 384:13 398:3,12 court
371:11 379:10,14,16,17
continued
401:3
204:1,20
384:14,22 385:7,21 386:6
204:22 207:6 214:8 259:14 corey
covers
386:15,18,21 388:1
303:6
328:21
396:12
date
continues
corey's
cows
219:13315:17351:2
293:4
329:1
332:22
379:14 396:13
continuing
corner
creek
dated
279:14 349:10
273:3 336:22 390:16
385:11,18 386:5,10,13
207:13 210:9 233:10 278:6
continuous
395:10
crew
281:2 285:13 287:21
210:7 250:13,16,18
correct
215:21
289:11 292:10 294:3,5
continuously
217:4 220:21 221:3,4 245:7 critters
299:4,5 308:15 319:4 321:2
230:21 231:7
249:7 250:14 273:5 288:20 257:22
347:15 368:4 385:4,22
contractor
294:14 299:13 320:19
cross
388:7 394:22
334:10,12,19 363:10
321:22 336:19 342:13
286:4,11,20 287:2,3 296:5 dates
contractor's
352:1 369:1 394:3 398:9
296:10,16,20,20,20 297:2,4 351:21
334:7
corrected
297:6,21 298:4,10,13
dating
contradiction
296:6
318:16,19
307:16
355:17
correcting
crude
david
control
222:17
226:22 251:8
369:8
208:6,8,12,22 213:19
correction
cumming
day
223:21 224:9 258:12 293:5 222:21
361:21 362:2 369:9
227:21 229:6 289:19 302:8
299:18 307:3,5,10,12
correctly
curious
317:20
312:16 330:14,15 333:14
241:3 398:8
308:5,10
days
348:2 353:20 361:6,14
correlated
custom
296:14 385:4
364:11 375:13 395:15
402:16
343:22 344:5
deal
397:7
correspondence
customer
287:6 339:8,11 344:13
controlling
206:7,17
256:1 340:10 342:2,3
345:10 359:10 387:2 394:2
240:17 361:19
corroon
366:19 367:1
dealing
convenience
205:2
customers
284:12 326:12,18 331:7
338:18
corrosion
239:15 342:3 361:3,15
343:12,19 344:17 351:17
conversation
246:9,21 247:3,7
376:2 377:1 391:12 394:8 dealings
346:9 370:14 377:9,12,12 cost
399:15
219:8 220:10 333:17 339:5
384:20
265:11 276:15,16,19,20 cv
360:16,17,19,22 367:8
conversations
277:2
204:8
373:7
219:4 377:7
costs
cycle
dealt
conversion
276:18
250:3
324:20 325:1
247:16
counsel
cylindrical
december
conveyor
204:17
251:12
207:13 208:9 215:20 216:1
241:15,20 conveyors
258:19 coordinated
339:2 copies
384:21
county 204:3
couple 223:3 311:4
coupons 246:14
course 234:6 249:1 278:8 281:5
d
daily 31719
dalton 375 11
damage 223:4,18 224:3,10 304:10
217:14237:12253:14 294:4,5 295:11 327:4 346:14 364:4,5 388:7 decide 331:11 376:7 decided 263:21 328:8,9
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMONO010210
[decision - discuss]
decision
department (cont.)
determine (cont.)
digit
219:21 328:4,11 354:1
323:15,22 331:4 332:7
382:15
388:18
377:9,13,15,17 380:22
336:1 345:9,16,20 346:2 determined
dilution
decisions
348:6 350:20 351:12 354:3 239:8 244:15 248:6,17,19 213:13
381:22
356:18 358:1,7 360:4 369:1 249:20 265:6 279:2 286:22 dilutions
declared
369:4 370:15 371:4,7 373:3 287:3 314:1 318:10
213:12
328:2
373:4 386:9 390:9 393:22 develop
direct
decompose
400:21,21
246:9 293:6 362:18
357:5
250:1
departmental
developed
directed
decontamination
297:21
233:4,5 248:7 262:22
229:7 300:4,14 312:10
391:11,19392:6,11
departments
343:14 362:20 363:15
315:14 318:22 319:2 321:3
decree
266:20 365:13
372:5,12,16 392:12
323:19 330:5 333:3,22
359:13
depend
developing
335:11 336:19 340:1 395:6
defective
315:3,5
246:21
397:6 401:4
297:1 324:19
depending
development
direction
defendants
225:13 240:19
240:10
208:14,16 209:4 308:10
204:11
deposition
developments
directly
defined
204:13,16 206:6 302:7
230:3
239:19 260:3 315:11
210:16301:8 391:10
403:10
develops
director
defining
dermatitis
362:14
341:12 368:14
391:19
357:8
device
disagreed
degree
describe
227:10 379:19
381:4
230:15
208:15 226:19 235:9
devices
discard
delaware
247:13 279:22 322:5,9
289:4
373:11 379:9,14
204:2,14 205:3,5
331:12,21,22 372:10
devised
discarded
deliberate
described
240:20
256:9,10
314:14,19,22 315:4
253:9 286:8 321:21 331:19 dez
discarding
demand
describes
354:17
374:22 379:21
244:1,2
263:15
diatom
discharge
demonstrate
describing
257:19
224:21 225:3,11,15,15
240:15
248:17
diatomaceous
226:4 252:22 272:16
demonstrating
description
255:7 257:18,20
348:17 352:7 385:17
241:1
383:5
dick
386:13
demonstration
design
339:16
discharged
240:10 277:19,20
224:16 233:16 235:22
dielectric
248:11,21 269:2,10
departed
260:11 266:2 274:7,12,12 362:16,17,19,20 371:21,22 discharges
215:21
274:21 275:3,4,4,5
372:1,8
225:2 236:9 247:4,7 249:9
department
designed
difference
249:10 272:10 347:19
206:19 210:12 211:3 222:8 224:20,20 225:8 393:6
302:1
348:22 349:2,2,10,11,19
223:2,10 227:8 229:2
designing
different
353:6 386:4 396:9 402:7,8
232:18 233:8 234:12
214:3
253:12,13 256:18 264:12
402:16
235:13 237:18 238:5 239:5 desired
268:12,15 284:21 287:10 discontinuance
239:5 242:13,14 243:6
326:11
287:13 289:7 292:2,3
308:20 309:10
246:1 247:1 253:8,22 254:8 destroying
296:17 298:6 301:7 311:7 discontinue
254:10,11 256:19 258:18
382:5
329:22 334:18 382:7
378:19
259:10,11,13 260:3,6,7 destruction
388:17 389:2
discontinued
266:14,16,17 269:3 273:9 382:14
differently
309:2 311:2
275:10,18,20 276:2,5,10,21 detail
301:21 389:13
discovered
278:21,22 279:7,13,15,17 300:12 350:18
difficult
281:9,17 287:16 295:7,18
283:4,5,7,8,11,11 288:9 detailed
252:16 282:5 296:13
296:10 297:7 309:5
290:21,22 291:2,2,4,13
391:11
316:22 381:15
discovery
295:7 297:18,22 298:16 determination
difficulties
285:20
299:18 300:3,3 308:21
265:9
219:15
discrepancy
309:3 310:17,21 311:11,17 determine
difficulty
288:12,15
315:9,11 318:16 319:22
227:3 246:18 260:10
240:17 244:5 257:7 288:18 discuss
320:7 321:16 322:7 323:5 276:12,17 282:6 290:4
231:13 376:9
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMON0010211
[discussed - effort]
discussed
diversion
dried
early (cont.)
298:9 306:8 317:10 343:15 300:2
245:11
393:13,13
375:16 376:4 403:2
divert
drivers
earth
discusses
272:6
254:14
255:7 257:18,21,22
400:4
divided
drop
easier
discussing
322:17
257:10
394:9
229:1 283:6 305:13 306:10 dividing
drowned
easley
371:8 377:2
271:3
320:13,18
338:10
discussion
division
drowning
east
208:12215:5 219:18
214:6 259:6,9 322:20
279:21 280:3
347:6
244:19 278:2 284:22 299:1 328:17,18
drum
eaten
303:20 315:22 317:1
document
280:9 334:12,15,19 393:4 333:1
341:18 342:20 350:16
207:18 208:2 209:9 212:8 400:20
eating
374:3 375:1 380:5 400:1
216:5 220:18 264:5 278:5 drummed
355:20
discussions
286:4 296:21 312:18
399:14
ecologists
208:17,18213:16215:2
315:20 319:3 321:10 326:1 drumming
381:1
219:19 220:2 263:8,10
327:22 330:11 337:9 343:4 258:5,15 259:1
economic
275:17 301:19 302:2
352:9,12 380:2 383:2,7 drums
249:11,12,12 348:8 372:14
307:19 326:5 329:4 341:7 395:13,19,21
258:6 334:7,16 363:4,11,15 372:15
359:19 374:20 376:13,21 documents
392:17 393:2,3 400:16
economical
377:3 381:21 402:6,14
207:11 319:4 345:3,7
drumsite
277:12
disk
380:18
400:5,8
ed
224:19,19,22
doing
dry
284:17 342:7
dispensary
211:11 213:22 223:2 229:5 242:7 245:9,17,18
edelblut
227:13
242:3 246:13 265:7 276:4 drying
305:14
disposal
289:1 300:10 304:3 306:7 245:9
edelbut
226:9,10 229:9,20 231:14 316:16 356:19 370:5
due
273:14
238:14 253:2,18 254:1
domestic
223:7,20 310:14 340:18 editing
270:15 274:3,7 276:21
244:17
dug
295:3
277:1 334:6,16,19 352:7 don
226:8,14,15
ed's
353:6 363:4,10,15 369:17 331:3
duly
318:2
370:7 375:15 376:3 381:10 doubt
207:4 303:4
educational
381:19 383:19,21 384:2,6 347:17
dump
397:5,11,14
384:14 385:7 387:12,20 downstream
280:9,14 376:22 377:4,8,20 edwards
388:1 390:2
237:7
dumped
354:12
dispose
downtown
241:19 242:2 253:4 254:4 effect
242:16,17 377:1 380:22
334:14
dumpster
243:17 307:12 329:15
394:5
dr
253:10
350:22 351:15 402:9
disposed
209:17211:16213:20
duper
effective
239:14 252:4 275:8,13
339:17 353:7 365:19
362:14,21
276:19 277:3 309:6,7
390:10 392:17 393:4,21 draft
durable
effectiveness
disposing
217:16,21
259:18
276:20 307:5,9
393:9,14
drafted
duties
effects
dissolve
236:6
229:4 370:10
257:15 340:18 355:12
245:4
drain
dye
365:5
dissolved
279:20 280:7
211:21 212:1
efficient
245:13 314:13 distillation
245:17 distilled
255:12 distinction
296:19 389:16,19 distinguish
210:8
drained 246:8 252:9
draining 254:6
draw 264:18 290:8,12
drawing 296:19
drawn 393:19
e 211:8 244:10
earlier 268:9
276:9
296:21
298:3,9
effluence 255:17
303:12 323:14 326:1 335:5 345:6 347:20 392:21 393:17
effluent 244:12 316:2 359:13 362:5 369:16 378:16 384:21
early 219:21 237:14,21 249:18
385:11 effort
295:6 296:14 305:5 346:11 209:15 307:8,15,20
373:11 382:12 391:7
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMON0010212
[efforts - exist]
efforts
encouraging
ep
examination
229:8 361:6,14 367:4
208:13,16
341:8
204:17 206:2 207:6 246:18
397:15
ends
epa
303:6
eia
215:7 323:6 326:9 340:17 300:20 301:2,10,14,16
examined
360:9,16 367:2,3,8
351:5,22 352:3 355:1
328:1,10 329:5,8,10,11,11 207:5 303:5
either
362:12 363:18 370:13
331:17 337:3,12,19 338:7,7 example
240:19 248:21 249:13,17
391:3,9 396:17 397:4
339:2,20 340:2,8,13,17,21 243:3 256:16 342:9
384:2
398:14
341:6,7 347:1,10,13 348:9 excavation
elaborate
engineer
349:1,7,9 358:17 359:9,12 313:10
265:13
208:6,8,12 221:15 223:15 366:20 367:2,3 388:8 396:9 excavations
electrical
233:16 246:1 333:12
epa's
313:6
255:16,17,20
engineering
340:5
excess
electronic
214:7 222:15 223:13 230:5 epidemiological
240:15,15,21 241:4 277:19
360:12
230:8,15 231:6 232:1
365:7,9 366:5
311:11,13,15
elements
247:14 259:7,9 269:17
equipment
exchanged
276:16
273:1,10,15,20 314:11
236:1 247:4 260:14 389:1
371:5
eliassen
engineers
392:14
excuse
208:4 209:17 211:16
230:12 332:9 357:4
erected
211:7 367:3
213:20 214:12 215:9
engman
265:22
exercise
eliminate
308:6 319:5 326:2,5 332:8 erratic
247:14
237:9 297:21 306:18
339:17
378:8
exhibit
316:17318:16
enjoyable
esq
206:8,9,10,11,12,13,14,18
eliminating
254:20
205:1,7
206:21,24,26,27,29,30
236:19
ensure
establish
207:13 212:6 213:2 215:22
elimination
240:22
247:9
220:15 229:1 235:12
237:20
entailed
establishing
238:20 262:1 264:2,4,8
elmo
242:10 246:12 247:13
247:11,20
267:1 271:1 272:20 278:3,5
373:2
entered
estimate
280:22 281:1 283:15
emergency
242:19 359:12
250:20 278:22 279:1
284:18 285:12,13,17 287:7
206:26 391:6
entire
297:17
287:19,21 289:9,11 292:8
emission
247:10,11 309:4 383:1
estimated
292:10 294:3,8,16,19 295:5
312:20
entirely
278:22
295:15 296:4 297:9 299:4,5
emissions
277:3,15 361:18
et
299:7,11,15 300:16 303:11
307:16
entities
204:10
306:20 308:15 309:16
employed
345:10
ethyl
312:8315:13318:21 321:1
254:21
entity
225:12 240:19
323:18 327:3 330:4 333:2
employees
284:7,12
european
333:21 335:10 336:14
365:5
entrance
232:2
337:2 339:22 343:6 344:20
employment
396:20
evans
346:13 350:14,17 358:13
274:20 278:8 281:5 288:2 entrances
363:7,12
360:5 362:22 364:4 366:1,8
289:13 292:14 294:9 299:9 395:15 398:17
event
367:11 369:10 371:13
303:16 306:22 308:17
entry
251:19271:19319:5
372:20 375:14 377:22
309:18 312:10 315:15
255:5 287:8 297:17 298:8 352:17 359:5 391:8 395:14 378:2,3 380:9,13,20 381:3
319:1 321:4 323:20 327:5 299:22 362:4 392:16
395:20 396:3
382:19,21 383:4 384:13,17
330:6 333:4 334:1 335:12 environment
events
384:19 385:3,5 388:6 390:5
343:8 346:15 358:15 360:7 247:5,8 248:21 326:13
396:12,14
390:16 391:2,15 392:16
363:2 364:6 367:13 369:12 389:9,13,22 395:16 396:20 eventual
395:3 398:3 399:4,6 400:4
371:15 372:22 378:5
398:17
277:1
400:8 401:1,3,9
380:11,15 395:6 398:5
environmental
eventually
exhibits
399:8
229:9,20 231:14 274:3
211:8 237:13 256:6 265:18 206:7,15,16,17,20,22,25,28
empty
283:18 293:5 330:14,15
289:1 309:7
207:7,12,12 294:2 299:2
399:21
333:14 342:9 359:12,17,21 evident
303:7,11 372:18 380:6,8,9
encountered
364:11 375:11,13 389:5
295:5
384:10,12 390:20,22
357:11
environmentally
exactly
394:20,22,22
encourage
375:16
224:8 242:11 282:20 317:5 exist
209:4
387:16 391:21
234:8
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMON0010213
[existed - follows]
existed
extending
fashion
finished
223:6 237:22 338:18
212:13
253:9 256:11 258:10
227:20 234:12 261:22
existence
extension
fast
fire
386:20
218:8
315:3
242:19
existing
extensive
fda
firm
307:3 318:19
299:17
339:2,8
387:6,7
exit
extent
february
first
288:4,12
329:9 336:2
273:1 308:15 309:21 330:5 216:9 217:15218:20
exits
extenuating
330:13 360:6 363:1
220:14 222:7 224:2 238:22
300:5
348:17 349:3
federal
240:18 242:18 245:2 262:4
exoskeletons
extra
301:16 316:6,8,10,20
264:1 267:1 274:6 276:14
257:21
291:16
326:12,18 329:11 339:1
278:11 281:13 285:22
expand
extremely
343:12,19,22 344:8,13,18 293:1,3 295:4 296:4 297:17
235:13
228:5,6,9 257:6,9
345:3 347:1 395:14,19
299:15 303:11 304:17,20
expect
eye
396:2 397:20
305:8 309:20 310:18
316:18 317:7,13 328:15
227:10,12 357:10_________ feed
315:18 320:8,11 322:6
396:4
f
236:19 237:9,21 393:6
325:3,8 329:1 330:8 335:18
expected 287:6 316:13,21 396:5
face 355:20
feeling 317:12
336:2 340:8 342:6 352:9 354:5 358:18 359:11
expedient 381:16,20
expedients
facet 282:8,9
facilitate
fell 260:6
felt
369:14 375:15 378:8,19 380:20 382:10 395:3 401:9 fish
382:2,3 expedited
269:19 facilities
317:6 377:13,17 fepa
215:5 386:15,19 389:10 fit
295:11 expensive
224:12 265:15 348:8
338:17 376:8,15 396:19 facility
338:15
390:17 fifth
204:19
273:12 five
232:13 317:20
experience 227:21 230:18 236:21
fact 287:3 296:10 298:5 320:11
fighting 289:7
fixed 324:18
237:1 244:6 251:7
350:2 353:3 376:17 377:6 figure
floor
experienced 279:15
experiment 225:9
experts
377:10 379:20 382:7 396:16 397:19 400:15 fail 251:16 failed
249:6 figures
300:18 file
327:9,11,13,15,17,18,20
204:19 205:10 flow
286:4,11,20 287:2,3 289:18 296:5,10,20,20,20 297:2,4 297:6,21 298:4,10,13 300:3
365:22
252:1
334:3 380:17
300:4 318:16,19 369:16
explain 279:22 280:2 300:8 336:5 355:17
explained 335:5
failing 252:15
failure 251:3
failures
filed 304:5,9 305:15
files 384:22
filter
401:16 flows
296:17300:11 401:11,17 fluid
255:17 257:9 362:16,17,19
explanation 215:8,12
exposure 227:7 246:17 365:6
expressed
252:12,18,21 295:6,18 fair
286:14 332:1 368:7 388:2 fairly
224:12 246:22 282:4
227:19,19 228:1 255:14 filtered
256:8 filtration
255:11
362:20 fluids
361:22 369:9 372:5,12 flush
401:18
244:8 258:21 381:5 401:21 290:18 314:15 315:10
final
focusing
expressing 347:13 348:5
320:11 396:14 familiar
217:16,21 248:12 find
396:9 follow
expression 278:17
extend
238:4 266:19 280:16 282:17 288:5,8 293:9 386:20 400:12,15
383:6
214:13 303:12 finding
247:17 248:4 249:2 366:2 370:6 384:20
253:2 following
263:4 277:19 367:18
250:17 extended
far 225:9
233:10
240:1
248:1,6
288:22 fine
follows 207:5 303:5 379:15 387:12
224:22 266:11 306:5
266:15 302:1 311:7 344:10 264:22
387:21
353:22 389:8 396:13 398:2
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMON0010214
[foot - greater]
foot
frame (cont.)
252:19
370:4 381:8 388:12,13
force
390:8 393:9,17 397:16
283:16,20 284:2,6,13
frangible
297:10,14 338:22 339:6
224:19
360:9 371:21 372:8
fred
foreman
292:19 293:1
360:3
frequency
foresman
258:22
375:10
frequent
forgotten
210:6311:18,19
392:9
frequently
form
344:2
255:7 257:19 274:15 314:8 fresh
319:7 320:2 402:19
216:22 217:1
formally
freshly
326:11
217:3
format
fritz
234:7,9 353:11,19
214:1,5,6 262:2
formed
frogs
283:16,21
225:20
former
front
378:21 379:1
386:12
formulating
fulfill
221:22
369:15
formulation
full
262:17
230:17,18 266:2
fort fumes
364:9,10
357:9
forth
function
220:20 225:20 258:20
226:1 249:21 322:1
266:1 315:6 344:14,17
functional
388:19 393:3
361:22 369:9 372:5
fortune
functions
223:7
242:15
forward
funnel
308:7
242:3
fosso
furlow
257:21
204:18
found
furnace
277:10 298:4 348:18
251:2,5,8,10,10,11,11,20
383:18 384:1 389:9
252:6,8
foundation
further
274:16
204:16 207:5 261:8 290:2
foundry
300:11 303:5 307:17,20
375:16,22 376:8,15
future
four
326:12 343:13
375:9 385:4 388:18
fourth 383:12
gail
398 9
fr2 284:19 285:2,3,7,8
gallion 335:14
frame 209:14 232:12,14 238:6,14
garlette 214:3,10
306:13,17 309:3 348:10 garth
351:12 357:19 368:1 370:3 364:10
g
gas go (cont.)
260:1,2,3 261:12,13 310:19 314:9315:13318:21 319:9
310:22311:11,14,16
319:20 321:1 322:15
320:12,18
323:18 324:12 326:6 327:3
gaseous
330:4 333:2,21 335:10
242:19
336:14 339:22 340:22
gathered
343:6 344:20 346:13
256:13
348:14 358:13 360:5
gathering
362:22 363:18 364:4 366:8
309:6
367:11 369:10 370:12
general
371:13 372:20 375:14
230:1 232:12,14 233:22
390:5 392:15 397:1 398:3
235:1,12 288:17 305:3
goal
312:5 316:4 318:3 328:17 222:17 239:18 363:19
328:18,20 338:2 344:1,8,11 goes
346:20 361:12 368:22
295:10331:17
376:1 381:8 389:18
going
generally
209:15 214:22 236:22
233:13 235:9 273:21
244:18248:11,15249:14
318:12 344:14 345:15
249:15 252:2 274:10
353:17 388:21 389:14,15
275:12 287:17 288:9
389:20
293:15,15,19 396:9 403:2
generate
good
266:1 385:7
207:10 223:7 250:7 256:1
generated
288:18 377:13,17 382:5
233:18 236:6 350:7
397:6 403:8
george
goods
365:20
234:12
gerald
gossage
292:12
341:11,12368:13,14
gerry
gotten
292:18 293:10
241:12
getting
government
223:20 225:6,6 288:18
234:7 316:6,10,20 337:15
338:21 351:21 394:8
338:19
give
governmental
215:3 232:14 303:12 338:5 301:22 330:1 348:4
344:12 395:19 396:2
grade
given
285:3
215:12 246:17 290:11
gradual
329:15 342:20 373:17
314:6,7
379:13
gradually
gives
306:5
300:18 335:8 388:1
grand
glance
340:9,14
391:2
granite
gloves
259:18
393:2
grant
go 330:21
212:6 213:2 215:22 217:14 graphite
220:15 225:17,18 236:12
224:19
250:11 261:17,18 262:1 great
272:20 276:10 277:16
316:15350:17
289:18 299:22 300:16
greater
306:20 307:8,15 308:15
309:22
309:16311:1,17 312:8
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMON0010215
[ground - implies]
ground
hard
high
hydrogen (cont.)
313:15,18,21 314:3,15
243:13
229:6 251:14 252:18 257:9 242:17,19
315:7
harmful
290:5,18 355:8 383:14
hypochlorite
groundwater
257:14
393:19
261:21
318:17401:11,17
harry
higher
hypothesis
group
374:13,16,17
219:22 239:9 244:2 252:7 403:1,5
283:18 284:5,6,8 293:4,5 hauled
295:5 310:16,20
328:19 330:15 332:16 341:13 342:1 345:13 359:12,17,21 365:19
394:16,17 hazard
227:4 356:7,9
highly 317:17 389:16
highway
idea 217:13 226:15 243:1 249:1 260:5 265:10 277:7 302:5
368:16 390:7,13,14 391:22 hazards
386:14
318:2,3 329:20 331:5 349:9
391:22 392:1 groups
323:1 grows
257:20
357:8,10,18 hb
238:16,21 239:5 hcl
257:1
hippe 398:7,9
historical 253:18 254:1 292:5 307:13,16 370:10
307:4,9
ideally 256:4
ideas 263:13
identified
guess
head
history
206:6 207:8 210:19 264:2
325:10 329:10 guidance
331:4 338:12 header
398:16,21 hold
278:3 280:22 285:12 287:19 289:9 292:8 294:2
372:14 guideline
235:22
279:21 280:7,8
264:15 265:22 270:16,17
heading
270:22 271:3,11,13
238:1 279:3 281:14 289:16 hole
299:2 303:8 325:16,18,20 372:18 377:22 380:6 382:19 384:10 390:20
guidelines 236:1 340:4
296:5 300:17 352:6 355:4 225:4,8
357:7 383:12
holzapfel
394:20 399:4 401:1 identify
gunning
heard
386:16,22 387:9__________ 218:3 293:11
h hearing
292:13,17,19 293:18 homer
254:14
207:20,22 212:7 213:3 216:7 220:16 262:1 272:20 316:17 340:10,14 350:18
hand 241:19 242:2 273:3 335:15
240:1 347:4 heat
homolog ues 301:5
391:5 ii
336:21 375:10 390:16
247:9
hoped
236:12
395:9,19 handbooks
233:16 handle
244:16 271:15,21 394:9
heavier 402:15
heavy 402:9
hedworth
259:19 hopefully
255:22 hosmer
354:17
iii 325:22 345:2
illinois 329:8,8 338:7 343:13,19 347:6
handled
220:19 233:7 272:22
hosmer's
immediate
223:14 253:9 254:3 296:1 301:21 344:1,3 394:12,15 400:20 handles 378:15
273:14 heel
241:14 heiniger
232:10
381:2 hot
394:6,16 house
348:1
224:4 370:21 immediately
279:21 376:9 impact
244:20
handling 258:5,15,19 280:4 329:22 338:18 356:1 357:11 365:18 374:12 376:11
hands
heisler 332:4 374:9 375:7
held 273:1,15331:16399:16
help
housekeeping 397:7
houses 304:11 348:1
howard
impacts 244:3
imperative 214:13
impetus
355:20
338:21 372:14 376:7
341:13 366:13,21 380:14
209:20 219:13 237:8
handwriting 217:5,8 267:7,15,17 294:16
helped 333:15
381:4 390:14 hsb
238:11 239:3,16 246:20 247:19 263:19 352:19
366:9,11 374:6,14 387:11 387:15,16 390:17,18 happen
helping 305:19
helps
366:12 hugh
273:8
386:3 396:1 implemented
277:8,9 396:19
251:19 317:1 320:13 happened
383:8 hercules
hume 346:17,18
implication 217:2311:15363:12
210:4 226:10 252:4
341:14
hydrogen
implies
238:22 239:4,6,8,13,20
253:15
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMON0010216
[imply - involving]
imply
including
initials
interface
401:16
338:7 339:2 342:1
329:2 366:12
376:19
importance
incomplete
initiated
interim
352:22
303:17
337:18,22
266:7
important
inconsistent
initiation
intermediates
222:4 269:21
343:4 355:14
263:20
226:21 234:11
impossible
increase
input
intermittent
252:2
255:21 259:20
221:20 236:2
289:18
improper
increased
inputs
internal
379:18
250:22 402:9
247:15
300:5 368:2
improve
increasing
insecticide
interpret
233:8 258:4 277:10
236:15 316:8
228:8
272:1,16286:11,15296:16
improved
indented
inside
297:3 396:14 401:22 402:3
260:11 381:17
295:4 308:19 312:13
246:16 251:13 263:22
interpretation
improvement
399:13
insist
272:3 286:14 325:19 336:7
214:9 224:9 247:18
indicate
324:22
investigate
improvements
264:9,18 276:1 327:19
inspected
219:10307:20310:13
223:13,13,15 336:7,9
353:5 355:11 357:17
334:8
investigated
improving
366:14
install
227:3 248:19 392:22
229:3 233:9 243:8,14,15 indicated
223:15 239:11
investigating
255:9 259:14
348:15 358:10
installation
293:15
impurities
indicates
214:8 250:16 291:12 323:4 investigation
239:16,19 255:15,18 256:3 221:5 273:4 284:7 336:18 installed
211:11 218:9,10 222:18,19
256:21
371:20
211:1 227:10 245:8,17,21
223:9,11 227:6,11 253:17
impurity
indirectly
277:1 280:7,20 287:9 291:1 282:10 286:19 290:3,7
239:13
347:20
291:9
291:19,21 293:19 312:20
inability
individual
installing
313:5,17 382:15 390:1,4
362:4
296:6 301:5
259:11 279:20
investigations
inadequate
individuals
institute
227:7 293:12,20 310:10
379:6
387:4
230:11 249:6
invited
inch
industries
instituted
361:3
288:5 300:5,6
360:12
211:5 228:15 229:20 246:4 involve
incident
industry
249:17 330:19
226:21
223:7,7 227:1,12 286:16
362:5
instructed
involved
290:10 305:1,3 381:18
infer
358:2
213:18,21 215:4 219:6
incidental
290:13
instruction
220:4 236:15 237:11 238:2
329:7
influent
208:21 329:14 373:10,17
238:19 239:21 240:5,11
incidents
288:13
instructions
246:10,11 247:10 249:9
223:3,4 226:17,19 278:18 informal
327:14 355:18
250:12251:6 253:17
incinerated
387:19
insurance
255:11 257:3 258:15 261:3
245:13 246:3
information
205:13 291:16 302:3
262:17 263:8 274:11
incinerating
219:4 233:21 234:2 253:22 intention
282:12 283:2 284:6 302:6
243:8,14
275:3 285:17,18 294:12,13 260:19
315:11 326:17328:16
incineration
295:14 299:12,12 308:7,11 intentionally
343:18,21 346:10 349:18
242:21 284:20 392:22
326:11,18 327:1 331:16
320:19,21
349:22 350:3,6 364:11
399:16
338:5 340:10 343:1 358:11 interaction
367:4 368:8 369:4,9 375:10
incinerator
366:17 370:11 385:17
388:15
375:12 376:13 381:22
242:10,13,14,22 249:14
386:4 390:6 392:12 397:19 interactions
397:18
285:4,7,10 381:14 382:5
399:2
388:10
involvement
393:5 394:1,2,6,10,12
informed
interceptor
210:13216:16341:20
incinerators
340:21 341:6
291:1
345:15 347:18 348:12
382:10,14
ingestion
interest
351:10,16 366:5
include
355:8
209:5 296:2
involves
301:14 313:9
inhalation
interested
246:14
included
355:8
269:17 324:10,15 349:6 involving
365:20 390:15
227:7 289:4 326:5
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMON0010217
[ionizable - layer]
ionizable
july (cont.)
know (cont.)
krummrich (cont.)
255:15 256:3,21
366:15 372:20
272:2,9,14 274:18 278:17 396:19 399:11 400:11
irrelevant
june
279:2,12 280:9,13,18
I
361:15 irritant
343:7 344:21 juries
283:14 285:8 286:22 287:9 287:13,14 290:1,3,9,12,14
lab 210:15
227:10 irritation
227:13 issue
326:19
340:9,14 justification
250:21 justifications
382:4
290:21 291:5 292:6,16 293:2 294:22 298:15,19 301:11,13 305:21 311:7,8 312:14 314:1 315:7,19 317:4 318:6,12 321:12,14
labeled 264:15
laboratory 244:2
laborers
issued
justify
321:18 322:13 323:11,13
254:8
355:18 356:2,3 issues
342:2,17 343:20 italy
259:17
250:20
katzenstein 204:18
keep
k
323:15 325:9,12,15 327:7 328:4 329:3,12,14 330:9,13 331:2,9 334:10,18 335:8,18 337:7 341:4,20 342:6,8 345:17,21 346:1 348:18
lack 274:16
lagoon 263:5,9,11,12,14,17,20 264:9,10,11,20 265:1,2,5,6
item
230:2,5
349:4,5,15,21 350:6,9
266:6,10268:1,10,11,15
277:6 355:15 379:15 393:1 393:3,5
keeping 327:16 394:6,16
353:22 354:9 355:14,17 356:9,14,16 357:21 358:10
lagoons 266:4,13,19
items 363:19
j
keller 368:15,16
kept
359:6 362:9,14 364:3,12,15 365:17 366:11,21 368:20 369:3 370:4,9 371:1 373:5
landfill 373:12 382:17
374:22 381:1 382:8 387:12,21 388:1
ja 204:8
228:3 kind
373:14 376:5,17 378:11 379:20 381:4 383:6 387:7
390:2 392:18 393:4,22 394:13,17,19
jack 346:17,18 377:7
james
219:15 233:2 254:15 257:21 290:7 291:1 296:1 296:19 300:10 310:5
387:20 388:13 389:8 390:12 392:20 393:10,12 393:14,18 396:4 397:1,11
landfills 381:11,19382:1,2 390:11 393:10,16
204:13,16 205:1 206:3 207:3 303:3 403:14
320:16 321:15 328:11 332:15 361:4 366:2 371:5
397:19,21 398:2,12 399:12 399:19 401:20 403:5
language 294:21
january
385:21 387:6 392:5 393:7 knowing
large
299:4,5,7,16 306:9,20 japan
232:3 jet
279:21 280:3,4
402:11 kinds
236:1 246:15 klemme
216:10,19,20
325:4,8 349:6 knowledge
307:11 348:9 352:18 353:14,16 394:13 397:22 known
235:2 242:3 250:3 257:2 largely
235:22 249:21 larkin
233:7
jets knew 225:7 226:20 228:8 278:12 late
261:3
238:8 248:1 249:22 257:9
jim 291:14 325:17 333:19
215:8 220:14 233:7 263:3,4 338:4 346:8 360:14 388:14
267:16,18 304:3,15 375:11 400:17
376:9 384:19 387:12
know
279:3 296:5 297:2 304:13 364:12 kristine 204:19 krobs
265:3 353:7 391:21 393:13 latter's
306:8 lavinskas
365:20
job 227:21 249:5 328:22 356:21
john 212:9 213:5 216:9 267:10
207:16 208:11 209:8 211:14,18212:1,3,5 213:1 213:9,10,13214:15,19,22 216:4,16217:8,10,17218:3 218:15 220:13 226:10,12
216:11 218:2 krummrich
234:20,21,22 235:3,18 280:19 284:14 285:5 293:12 301:12,17,20 319:6
law 204:17 342:9,9 345:9,15,19 346:1 368:20 369:1,4
lawsuit 304:10,12 317:10 332:18
303:21 328:20 342:4 345:6 226:15 229:14 232:16
324:5 326:16 328:10 329:6 332:19,20
346:2,2 354:12 391:6,22 joined
233:10 236:19 240:2,4,13 241:15242:10,11,12
330:2 331:7 346:19 347:7 347:11,14,19,21 349:20
lawsuits 304:5,8 305:15,20 317:10
328:19 345:13 jrs
327:11
243:11 245:21 246:2,3,12 251:18 253:12,15 254:3,16 254:21 255:3,4 256:10
350:2,7,20 351:1,3,12,17 351:18 356:18 360:3 364:14 365:14 373:4
332:11 342:21 lawyers
342:15
julio 333:7
257:17 258:17 262:9,21 263:1 266:11,15 267:5,20
376:22 377:4 378:14,15 382:16,22 383:19 384:2
lay 276:15
july 268:12 269:11,13,22 270:3 388:8,11 391:11,20 393:6 layer
287:21 289:17 323:18
270:8,13,16,20 271:12,20
393:11,15 394:1,5,11
245:11
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMON0010218
[layout - management]
layout
levels (cont.)
liquids
losses
264:12
334:21 335:3
389:15
249:12277:11,13278:12
leach
leverage
liquification
288:4 289:21 290:5 295:5
314:5
250:3
259:21 260:4,4
299:18 300:18,19 301:2
leached
levied
liquify
307:3 309:21 310:17,21
313:15,18,21 314:2,2
317:6
260:7
319:22 320:6,9,12,16 325:4
317:18 318:5 383:18 384:1 liaise
list
325:8,16,17,20 336:2,8,10
leaching
259:9
349:17,21 358:18,21 359:2 336:12 340:19,22 341:1,9
314:10,13,15,21 315:1,4 liaison
359:4,7
347:2,11,14 348:2,5,11
384:6
259:6
listed
363:20 378:7 402:2 403:2
lead liberty 212:10221:2 273:13,18 lost
383:2
205:13
322:17 365:20 366:1,9
292:1
leakage
library
367:20 368:5 375:9
lot
286:9 287:16 402:17
233:1,3,9,10,20,22 234:16 literature
233:15 249:7 308:5 315:5
leaked
234:20,21 235:1,4,8,9
230:3,5 231:1 233:15
317:4 319:3 399:15,19
382:16
life
little
400:5,8,9,13
leaking
257:19 259:20 282:3
233:4 253:10 256:18
louis
281:10,19 285:22
light
257:19,22 264:12,17 284:3 214:7 216:15273:16
leaks
392:21
284:3 292:18 328:5 335:7 334:14 347:6 353:21
286:7 287:16
lightly
336:6 387:17 394:4,9
364:15
learn
280:11
liver
low
228:6
liked
357:10
265:11 316:13,13,18 317:2
learned
248:20
load
362:5 389:17
365:15 379:5
likelihood
244:3,4,17
lower
leave
316:8
loading
257:3 268:14,18 269:5
291:3,18
likewise
243:7,11,17,20,21 244:14 lunch
leaving
251:15
lobbying
303:10
260:19 261:6 291:13
lime
367:4
Ivm
318:11
251:2,17270:15271:6,12 located
255:6
led
271:17
344:3 364:16
m
247:4,4,7
limestone
left 211:4,7271:9 386:12,13
211:3 226:8 241:9,10
limit
242:22 255:4 264:13 267:7 362:5
271:10351:17,18
line
locking 228:2
logical 286:7
logically
magazine 231:3,21
magazines 230:7 231:19 232:19,21 233:15
legal
224:21 225:3,10,11,15
379:15
magnitude
340:9,14 342:17 345:4 370:15 371:4,7 390:7,8 legwork 213:22 leisy
264:15 279:20 280:7 290:14,16 375:19 388:20 399:16 lines 213:16 215:2 222:11
long 222:5 230:19 262:13,18 324:22 377:9
longer 237:22 373:20 374:1
310:8 main
296:6 297:2 318:15 maintain
338:2
308:2,3,12 330:22 332:4
231:17 240:12 259:8 271:3 look
339:16 388:7,11
294:19 298:20 388:17
207:16 216:3 220:16
letter
397:15 402:6
257:22 271:1 281:8 323:6
208:3 216:10 217:15 258:3 lining
324:13 340:22 349:17
259:22 281:9 308:19
251:12
391:9,15 400:3
maintenance 221:9 227:18 228:12 247:6 252:13 267:12 283:4,7,10 283:17 322:18 323:5,7
major
325:11 391:10
linings
looked
262:9 282:13,17 287:9
lettered 308:20
259:15,17 linkage
322:12 looking
295:6,17 majority
letting 381:4
level
243:16 liquid
213:19 242:16 249:13
276:20 349:21 385:5 390:9 400:7 looks
249:5 making
237:3 274:2 277:3 316:6
213:8 219:22 252:7 328:12 328:13
280:8,10 314:12,13 355:6,8 217:9 294:18 327:8 374:15 384:21 389:18 393:6,10,14 loss
319:14 323:1 345:19 369:22 370:2 385:5,6,10
levels
393:15,19 394:2,7,11,14,16 249:3,19 279:3,7,12,15,20 management
290:6 316:2,11,14 325:3
281:15 316:17 319:21
214:9
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMON0010219
[manager - mind]
manager
materials (cont.)
meeting (cont.)
mentioned (cont.)
214:7 216:14 223:8 237:14 276:17286:12,13311:4
332:15 337:3,7,11,16,17,19 268:9 271:3 282:1 286:8
291:10292:19319:14
314:2 321:22 326:15
337:22 338:1,6,9 339:15,20 304:10 334:15
328:17,18,20 351:13,19 matter
343:15 360:9 361:4,4
mentions
353:20 354:2,4,20 361:3,21 228:5 274:5 276:11 288:22 364:18 366:2 367:19 368:2 349:12 398:15
369:8 377:8 385:20
305:3 328:7 342:16 344:10 368:6 371:21 372:1
mercifully
managers
344:11 381:8
meetings
261:22
354:8,9,19 392:2
matters
273:11,15,20,21 324:11 mercury
manta
223:17 229:9,20 231:14
326:4 331:6,9,10,10,12,18 259:12347:2,11,14,19
205:8
235:6 236:9 238:14 274:3 331:19332:1,12,13,14,16 348:1,2,5,8,11,22 349:19
manual
276:1 284:4 302:3 330:1
344:16
350:7
235:14,15,18 236:8
332:5 339:9 352:22 360:20 melting
merged
manufacture
364:11,21 367:5,9 377:1
290:18 393:20
391:22
270:12 372:17
mayor
member
met
manufacturing
262:5,10,11,14 304:4
230:9,11,13,14,16,18,20
211:18218:4 220:11
206:18 216:13 237:14
mccutchan
231:9 232:6 284:1 372:7
262:12 337:14
291:10350:19351:11,13
332:8
members
metallurgical
351:19 352:10,14,20 353:4 mean
283:17
246:18
353:10,17,19 354:4,20
232:17 241:4 246:3 260:12 membership
metals
356:17 357:1 361:14
260:17 268:6 296:16 297:4 230:17
246:15,18
385:20 392:2 396:19 397:8 301:9 356:13,14 367:2
membranes
method
map
373:19,21
357:10
264:1 306:7 374:12
206:8 264:5,12,16 383:8,10 meaning
memo
methodology
march
260:20 286:12 322:20
206:15,25 211:13212:9
301:4,7
216:1 278:12 309:17 333:2 349:2 389:10 390:8 402:7 213:5 214:2 215:7 216:1,1 methods
marked
402:17
216:9 217:6,11 220:19
249:20 276:21 289:1 309:8
207:12 264:4,8 271:2 278:5 meaningful
250:15 262:2 268:9 272:22 353:6 361:13 363:14 370:7
281:1 303:11 350:14 378:2 336:13
278:7 303:21 308:16
methyl
378:2 380:8,9 382:21
meaningless
329:15,19 340:17 347:15
225:13240:14,19
384:12,17 390:22 394:21
379:16,17
347:16 351:20 368:2,4
microbe
market
means
369:14 379:4 381:3,18
257:20
204:18 205:4,11 373:20
213:9,10 214:21 241:1
385:21 387:22 395:12
microfilm
marketed
244:3 300:8 335:4,8 336:5 396:13
351:6
374:1
340:9,14 356:15
memorandum
microscope
marketing
meant
206:9,10,11,12,13,14,16,20 258:1
341:12,22 368:14
228:10 301:14 303:12
206:21,22,23,27,28,29,30 middle
mason
measure
281:2,4 285:13,16 287:22 213:7 264:15 363:21
328:20
243:21 244:2 255:19,19
289:12,16 292:10,12 294:3 migrated
mass
318:15
294:8 299:8,16 303:15
382:16 383:18 384:1
226:22
measured
306:21 309:17 312:9
migration
material
257:4 288:4 336:12
315:14 318:21 321:3
234:17 384:5
225:21 226:2,8 234:1,3,5,7 measurements
323:19 327:4 330:5 333:3 mike
234:9,11 237:3 242:1 247:9 288:19 323:1 336:12
333:22 335:11 336:15
374:9 375:10
247:11,15 248:3,14,16,20 measures
340:1 343:7 344:21 346:14 milk
251:20 252:8 254:4 258:5 247:15 295:10
349:18 358:14 360:6 363:1 332:22
258:15,19 261:17 272:5 measuring
364:5 367:12 369:11
mill
276:8,14 314:12 332:21
379:6
371:14 372:21 373:17
218:15
355:6 356:1 357:8,11
mechanical
375:2 378:4 380:10,14
mills
389:21 393:7 394:8,18
228:17
384:14 388:7 395:4 398:4 218:16
399:15
medium
399:7 401:4
milt
materials
355:7 356:12,12
memos
399:11
210:18233:17234:11,17 meet
265:20 308:6
milton
236:6 241:17 242:12,21
316:21
mention
399:10
244:9 245:4 247:2,3 248:10 meeting
332:17
mind
249:13,22 252:22,22
262:4,7 263:3 270:2,5,8 mentioned
328:14
256:13 257:10 269:1,6,8,10 273:1 297:11 331:15
214:2 226:17 227:5,9 232:5
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMONO010220
[mine - numbers]
mine
monsanto's
name (cont.)
niran (cont.)
327:8
228:20 233:18 302:3
378:13 380:1 381:12 387:8 262:6,19 266:5 268:21
minimize
305:19 338:11 341:21
387:9 391:3 398:8
269:3,7,15 270:12 271:7,8
358:3
369:1,4 382:21 390:8
named
275:20 276:2,4,21
minor
montar
363:12
nitrates
267:12
290:8,10,14,17,18 380:22 names
269:6,8,19
minutes
381:10,10,12 382:5 393:18 345:6 375:3,4
nominates
273:1 368:2
394:5,9,15
national
376:18
miscellaneous
montars
367:15,22 368:8
non
240:9
381:20
natural
204:9 362:14,18,20
mit
month
314:22
normal
208:4
274:1 278:19 280:21
nature
226:1 247:22 279:17
mix
289:17 295:6 309:22 312:6 360:22 381:9
283:13 289:18 295:2
394:9
368:5 402:2
near
310:16,20 314:21 355:7,22
mixing
monthly
222:19 223:5 278:11
376:19 381:13 402:15
211:20,20 286:12 394:7
231:3
326:12 343:12 347:6
normally
mixture
months
necessarily
230:15 234:10 246:15
286:20
304:18 305:9,10 317:19
271:11 304:14 397:18
284:15 311:1 313:9 356:3
modifications
moore
necessary
401:15
298:15
350:1,1
211:9 239:11 257:8
north
modify
morning
necessitated
287:9,17 300:4,14 321:7,12
297:17
207:10 384:20
239:14
northeast
moisture
morris
need
264:14
245:6
262:5,9,10,11
262:13 267:11 370:10
note
molloy
motivation
397:7
217:12 340:17 374:9
377:7
348:7
needed
noted
moment
motors
222:21 267:14 275:4
298:3
391:1
376:1
295:11
notice
money
mounted
needs
365:20,22 368:4
248:3 267:13
246:15 252:6
343:13 362:6
noticed
monsanto
mro
neglected
272:12
204:5 205:6 206:24 211:11 267:11,11
286:3
notoriety
212:2 214:13,17,20,22
mucous
neither
359:9
218:17 219:20 228:20
357:10
260:20 311:7
november
231:20 232:8,8,9,11 234:13 mullendore
neutral
281:2 285:14292:10
240:10 244:9 248:20
212:9 213:6 216:9 263:4
260:10,12,14,16,20 261:12 369:11 371:14384:13
254:22 274:20 278:9 281:6 303:22 305:13
261:20
387:22
288:2 292:14 294:10 299:9 mullendore's
neutralization
number
303:16 304:3 306:22
217:9 267:10
271:9
204:7 206:6 207:11,14
308:17 309:18 312:11
municipal
neutralized
212:12213:3,13 230:17
313:3 315:15 317:2 319:1
378:13
261:19
236:18 249:18 250:2 258:3
320:19 321:4 323:20
munoz
new
258:4 262:13 264:5 267:22
325:17 327:5 328:9 330:6 333:7,7
204:3 210:9 227:20 230:2,3 270:10,15 289:7 294:5
332:11 333:4 334:1 335:12 muriatic
240:10 247:1 313:6,9,12
297:17 299:22 303:10
337:12,14,19 338:6,12
240:5
315:8,9 316:6 324:1,7,15
318:3,15 323:7 326:9 327:9
339:12 340:10 342:14,21 mutual
372:12,17
327:14,15,22 334:20 351:6
343:8 345:14 346:15 347:2 205:13
newport
351:6,22 352:4 353:15
355:12 357:18 358:6,15
n 384:5,7
355:2 362:4,12 363:4,18
359:20,20 360:7 361:17 name
news
379:6,9 386:15 388:19
362:9,13,18 363:2 364:7,19 365:5,17 367:13,19 368:3 369:12 370:17 371:16
218:2,3 220:14 234:13 242:6 254:13 275:20 285:3 290:11 329:1,3 330:21
232:1,2 niosh
364:19 365:1 366:5
391:4,10 396:17 397:4 398:15 399:14 400:4 numbered
372:22 376:14 377:4 378:5 380:11,15 390:10,10 393:8
333:7 334:13 335:16,18 342:6,10 354:14 360:12
niran 209:10 210:22 211:20
263:2 numbers
393:9,14 395:7,20 398:5
363:13 366:8 371:18 372:4 213:19 214:8 227:8 240:14 207:14 216:2 221:1 278:6
401:6
374:11,13,15,18 375:8,22
242:13 247:20 259:10
285:14 292:11 294:4,5
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMONO010221
[numbers - paragraph]
numbers (cont.)
odors (cont.)
operations (cont.)
oxidation
299:5,6 301:7 303:13
306:7,18
287:17 292:2 324:4 338:16 263:18 269:19
316:14,18 322:15 388:22 offer
339:12,12 349:22 394:3 oxidizing
numerous
376:8,14
400:13
212:14,16
304:4
offered
operators
oxygen
nutrients
376:22
254:8 358:3
244:1,2 263:16___________
269:17,21________________ office
opportunities
P
o
object 274:15 314:8 319:7 320:2 402:19
235:1 316:1 324:11 338:11 338:13,14,15,18,20 339:2 344:1,8,11 346:20 offices
247:18 248:2,4 orchestrated
365:21 order
249:2
277:2
p2s5 240:15,16,18,21 277:19
pace
241:4,6,8
objectionable 306:6
objective 247:20
objectives 220:20 221:16,20
222:1,3,6
204:18 official
234:7 officials
337:15 oh
337:3
218:21 239:10 267:12 269:19 350:13 orderly 242:4 ordinary 278:8 281:5 288:1 292:13
226:6 packed
261:10,11 page
217:14 220:7 236:12 238:20,20 243:6 264:4
230:2 observe
284:21 324:19 360:11 Ohio
294:9 organic
267:1,15 268:18 270:1 278:5,12 279:6 283:15
355:15 379:3 obsolete
373:18,19,21,22 obtain
340:10 363:19 obtained
334:21 obtuse
332:20
214:6 243:21
okay
organics
207:19 216:6 224:2 248:17 383:14
265:4 312:19 315:21
organisms
321:11 322:5 330:12
269:18,21
334:15 337:10 348:21
organization
352:5 383:12 384:18
230:14,20 231:2 232:6,9
old 353:20 360:14,17 366:6,20
284:18,21 285:22 287:7,12 288:11 289:15 290:8 293:3 295:4 296:4 297:9,16 299:15,22 300:16 303:18 303:18 306:3 317:16 318:14,14 321:6,9,10 323:6 325:7 326:9,9 327:21,22 331:13,14 333:6 334:6,20
336:6 obviously
282:2,5 358:11 once
367:1 organized
337:2 339:16 340:8 343:11 348:14 351:5,22,22 352:3,6
231:22 293:1 300:10 342:17 352:16 occasion 231:10 235:3 310:5 occasions 219:11,12226:13239:12
254:8 277:10 312:4,4,6,7 391:4 ones 249:8 354:22 361:8 ongoing 210:3,5 320:16 338:16
219:9 283:14 original
250:15 265:10 originally
259:16 375:3,6,7 origins
355:1,3,14 357:6,6 362:4 362:12 363:18,21 370:12 383:4 390:5 391:3,9,9 396:16 397:4 398:14,18 400:4 401:8,9 pages
244:7 occur
223:7 occurred
249:20 278:19 361:2 occurrence
341:1 open
228:3 338:2 opened
241:19 242:1 operate
282:7 otto
331:2,3 outfall
378:8,12,16 outflow
303:19 322:15 339:14 paint
304:11 papageorge
285:17 289:13 293:22 294:13,22 295:15 299:13
311:18 ocean
257:20 o'connor
204:20 October
320:22 operated
251:22 252:17 265:22 operating
211:3 346:19 397:6 operation
378:20 outline
290:9,12 391:16 output
260:8 outputs
308:7,13 326:17 327:15 328:15 345:22 376:18 paper 372:6 paragraph 211:13,19212:20 213:7
367:12 368:4 378:3,9 385:12
242:4,9 256:18 271:8 323:1 247:15 324:2 334:7 348:12 350:3,4 outside
217:1,15 218:8,14,20 222:7 262:4 272:19 279:8 281:8
odor 209:9,13,15,20,22 210:14 210:22 213:8,11,18214:14
350:8 381:16 394:6 operations
210:21 228:21 233:19
228:20 345:10 370:16 371:9 overall
281:13 282:8 293:1,3 294:18 295:4 298:6,7 304:2 304:15 308:19 309:4,20
216:17 272:11 304:4,9 305:15
237:16 238:17 247:21 252:15 253:19 259:4
248:1,5 293:19 332:5 overpressure
310:16312:13315:18 325:3,9 330:8 337:6 340:8
odors
268:21 269:7,15 271:7
223:20 224:2
343:11 345:2 348:15,21
210:2,17 304:21 305:4,6
279:17 281:19 282:22
349:12 358:20 359:11
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMONO010222
[paragraph - plant]
paragraph (cont.)
pcb
permanent
places
362:13 376:6 379:3 382:22 206:26 283:16,20 284:1,4 265:5 266:9 392:4
289:7,8
383:12 395:12 399:13
284:13 293:12,20 297:10 permanently
placing
401:9
297:14 299:18 301:11
277:21
261:9 289:4
paragraphs
307:3,5,10,11,16 310:22 permitted
plaintiff
263:2
313:14 316:2,11 317:17
300:4
204:6 205:6
parameters
318:4 319:16 325:3 326:6 person
plan
312:5 315:5
328:2,10 329:6 330:1,14
215:19,20 254:20 273:18
206:26 262:22 263:1 391:6
paranitrophenol
331:7 332:11,21 333:14
350:5 354:3
391:8 392:7,11
268:20
334:20 335:2 337:13 339:9 personally
planning
parathion
339:20 340:11,15,18 341:1 342:11 365:3
273:1,10,15,20 331:10
210:12 223:2,10 227:20
341:8,21 343:20 345:11,14 personnel
plans
228:4,5,6 240:14
349:2 359:21 360:20
213:15221:12229:15
238:4 273:22 328:1 343:5
pardon
361:17 362:14,18,20
331:4 337:12 338:6,7
372:17
207:21
364:21 367:5,5,8 372:5
364:19,19 365:2 397:6
plant
park
375:20 377:1,5 378:7
ph
206:8 208:9 209:7,10 210:1
342:12,12,14 345:7 346:3,4 382:12 384:14 385:7 388:8 260:20
210:22212:2,4 213:15
346:6,10
392:14 395:15 396:20
phenomenon
214:8 215:21 216:20
part
398:17 402:2
248:14
219:10,20 220:9,12 221:10
208:14 232:19,20 244:19 pcbs
Philadelphia
221:20 222:11 223:8,14
256:18 260:7,13 270:18
282:7 301:8 313:18,21
205:12
226:6,7 229:12,15 230:4
275:4 284:4 288:17 295:2 316:20 326:13 335:6
phocion
233:1,22 234:2,20,21,22
316:5 318:2 319:17 344:6 338:22 340:2,5 342:2
342:12,14 345:7 346:2,4,6 235:18,22 236:16 237:14
347:16 348:2 361:4 365:22 347:16 349:8 353:7 358:21 346:10
237:17 238:16 239:7,9,10
376:1 392:1
359:6,8 364:1 365:6 367:15 phosphates
240:11 241:2,3 243:22
partially
368:1,9 370:7 382:14
269:6,9,20
244:5,14,16 245:2 249:15
295:7
383:15,18,22 384:6 385:17 phrase
250:14 253:19 255:2 259:4
participate
385:20 386:4 388:12,12
260:16 274:12 356:12
260:2 262:19 263:22 264:6
353:22
390:10 391:8 402:17
physical
264:11,13,20 266:1,21
participating
pet
315:5
268:22 270:2,10,19,20,21
338:8
225:12,13
picked
271:2,16,22 272:5,7,15,17
particular
peaks
304:15
273:17 277:1 280:19 282:1
213:22 218:6 252:16 274:5 336:1
piece
282:4 283:14 284:10,11,14
282:9 284:17 301:4,6 310:5 Pennsylvania
260:14
284:15,20 285:5 287:6
313:2 318:6,8 326:22
205:12
pilot
288:4,5,12,13 289:16,22
328:14,22 346:21 354:3 people
263:5,9,11,12,20 264:9,10 290:5 291:8,18,22 292:19
365:8 375:7 381:18
228:20 234:22 273:13
264:20 265:21 266:1 271:2 293:12 296:2 300:5,17
particularly
325:1 328:14 332:17 339:6 pin
301:2,12,16,17 304:5,9,16
383:14
339:15,19 344:1,3,7,8,9,9 293:5
304:21 305:4,5,7,16,18
parties
344:11,15 354:6 367:8,18 pinpoint
306:7,18 307:4 309:21
204:21 348:4
367:20 370:15 375:9 387:5 315:12
310:15313:9,12 318:11
partition
391:7
pipe
319:6,14,17 320:9 324:5,11
268:10
people's
242:20
324:11,13,20 326:16 328:7
partners
304:11 324:17
piping
329:8 330:16 331:6,12,15
387:6
perceived
224:5,13
332:5,13,14 335:3 343:14
parts
222:15 247:6
pit
344:3,9 346:19 347:7,11,14
268:11,13,15 282:4 361:5 period
271:9 290:21,22 291:2,16 347:19,21,22 349:20 350:2
passed
255:13 265:20 266:7 306:6 place
350:8,20 351:1,3,12,17,18
261:10 333:20 395:13
310:19311:5,10318:5
245:1 258:17 275:15
352:11 356:18 358:1,8
paton
357:16 385:1
280:18 287:4 291:5,7
361:5 364:2,14 369:19
361:20,21 362:2 369:9
periodical
311:22 315:4,12 343:5
370:7,17 371:6,10 373:4,12
pattern
231:11,13
365:6 378:16 379:8 400:17 376:8,11,14,20 377:7
288:18
periodicals
placed
378:14,15,15,17,20 383:19
paul
231:19232:15
226:9 246:16 268:1,10
384:3,5,7,21 385:8,18
216:11 218:2 332:4 354:11 periods
393:2
386:3,11,19 388:8,11 390:3
362:2 374:9 375:7
292:3
391:20 393:6,11 394:2,11
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMONO010223
[plant - profoundly]
plant (cont.)
possible
present (cont.)
procedure (cont.)
396:5,7,10 397:17 398:12 260:7 277:4 286:5 287:2
356:7 371:20 401:18
391:11 392:15
399:11,21 400:11 402:7
296:20 332:10 347:14
presentation
procedures
plants
355:20 377:19 391:8,12
361:5,9,11,18
351:11 352:20 353:17
330:2 341:21 353:21 361:6 402:1
presentations
391:19
392:13
postulating
273:22 274:2
process
plant's
401:22
presented
206:18 224:4 226:20
331:7
postulation
357:19 374:21
228:15240:15,16,18,21
plausible
402:5
president
241:5,20 242:1,19 246:10
249:22
pot
232:10
246:16,19247:10,11,16
please
251:9,9,11,17252:7,9
press
248:1,7,11 249:16,19
374:9
potential
227:19
250:13,18 255:10 258:16
pleased
269:20 276:12 340:11,15 pressure
261:13,18 265:21 270:11
382:6
potter
224:18,20,21 228:1
277:21 295:3 314:6,7,14,19
plus
205:2
presumably
314:22 350:19 352:10
244:17,18
pounds
280:20 325:20 394:19
353:10,19 361:14 381:13
pna
278:21,22 289:19 317:20 presume
processed
313:7,9,12 315:8,8,9
powder
270:4,18 290:19 301:15
234:12 261:8
pnp
242:7
pretty
processes
268:17,19,19 277:6,7,11,13 pr
219:21 314:14
352:14 356:17 357:1
pohl
229:7 368:12
prevent
processing
220:19 273:13 392:2
practical
225:4 306:4
249:21
point
249:2 361:18
previous
produce
233:3 251:6 277:11 291:1 practice
268:18 286:3 287:12
311:6
328:20 329:7 345:10
222:13 223:8 276:11
309:22
produced
347:15 349:20 354:11
practiced
previously
260:1 310:18311:16
393:20
222:9
207:4 224:17 303:4 384:17 producing
pointed
practices
primarily
385:19
262:14
253:18 254:1
310:17
product
poisoning
pratt
primary
227:20 228:8 239:6,14
357:9
348:15
382:4
240:20 242:18 248:12,15
policy
precautions
principle
250:18 251:8 252:2,4 256:1
320:21 338:2 340:2,5
355:22 356:2,3
248:16
261:14 311:3,7 361:21
pollutants
precise
prior
369:8
269:20 358:18 359:2
288:22
239:4 357:19
production
polluters
predate
probable
216:14236:16238:18
340:11,15
358:11
317:17
240:7,10 250:17 251:7
pollution
predated
probably
253:21 254:5 260:6 275:11
208:5,8,12,22 229:9 244:11 358:6
209:19 263:14 283:5 324:9 283:17 308:3 311:2 322:17
312:16 327:10,17 332:5 premier
327:18 332:3,6 337:15
323:2 338:16,17 346:18
334:3 360:20 361:5,17,19 255:16
343:13 353:12 361:10
350:5 352:10 353:20 354:2
364:10,11 377:19,20
preparation
403:8
354:7,9,19 357:2,3,22
380:18
368:3 398:20
problem
358:7,12 375:11 386:1,2,7
polychlorinated
preparations
214:14 222:15,17 237:22
398:11
389:6
368:8 369:4
245:3,14 247:6 252:13
products
pond
prepare
286:10 287:5 296:1,15
225:13 240:11 311:8 342:1
215:5 268:8,11,14,14,17,18 275:4 368:6
324:20 338:4 345:14
372:15,16,17 373:18
269:5
prepared
349:12 355:16
391:22
position
282:14 321:7 395:13 396:2 problems
professional
324:21 346:20 364:13
398:15
222:20 281:20,22 282:11
230:6 231:19
374:19 398:10
prescribed
289:8 374:10,21 382:12 professionalism
positions
353:10
procedural
233:8
354:7
present
228:17
professor
possibility
204:20 214:12 240:21
procedure
208:3
213:15 225:5 258:22 316:9 241:6,7 249:14 260:4
235:13 236:8 246:13
profoundly
317:10 342:20 356:6
269:12,22 273:18 355:16
280:13 353:4,11 381:13
255:18
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMONO010224
[program - recall]
program
providing
quarter
reactor
262:14,18 263:4 273:17
258:6
274:1
223:20 224:3 225:5 240:22
274:6 282:6 283:16 288:11 prudent
quench
241:10 245:5
297:9 307:5,10,12,12 318:9 356:5
225:21
reactors
319:11 325:22 330:14
public
question
224:22 225:16,22
333:14 335:21 348:2 397:5 229:3,3,8 316:19
212:19 274:16 277:3 314:9 read
397:11
publicize
319:8 320:3,4 331:14
230:6 231:16,22 267:9,16
programmed
222:13
393:16 402:20
312:13 315:18 327:9 330:8
326:11
publicized
questions
337:6 374:6 383:1,5
programs
222:9
390:9
reading
333:15
publish
quicker
230:3 350:17
progress
359:13
383:2
reads
231:6 296:15 299:17
published
quite
263:3 335:22 343:11
324:12 326:10 334:22
232:1 358:17
211:8 223:3 226:5,18
369:14 375:15 395:12
progressive
pull
247:22 273:12,18 282:5
401:10
213:11
384:16
381:15
real
project
pump
quotes
329:3
214:1,1,7,9 215:15,18,18
251:3 252:11,20 253:1
312:21 325:9,10,13
really
216:17 223:14 227:11
321:7
r 242:15 243:13 257:11
237:11 239:4,21 240:7
pumped
rack
278:18291:16325:2
242:11 253:2,6 258:17 259:11 275:5 277:12
226:6 251:9 255:13 pumps
232:20 246:16,17 rags
394:17 reason
282:13,17,19 287:10,10,11 251:16,16,16252:14,16
289:3,6 315:12 321:7 323:3 261:3
324:9
pure
projects
245:20
211:17214:10218:6
purging
393:3 rain
289:18,21 290:6 401:17 rains
401:10402:1,6,9,10,15
218:21 244:13 261:15 265:8 272:14 282:11 296:2 302:5 309:9 310:13 314:18 329:17 331:13 347:17 370:9,20,22 374:2 396:4
222:16,21 233:9 237:20
401:12,14
238:2,7,11,13,19 240:6,11 purity
raised 389:3,6,7
400:18 402:1 403:2 reasonable
249:7 319:11,16 322:16 324:12 prompted 292:16 promulgated 221:16 pronounce 398:7 proper 325:1 344:12 379:7 properly 324:20 properties
239:9 purpose
225:1 241:20 248:3 249:1 255:14,20 282:20 291:15 322:4 394:1 pursuant 204:17 purview 237:16 238:17 275:11 put 225:1 244:5 256:13,16 259:19 264:20 265:3 279:3
ran 225:16 251:14
range 262:13,18 355:7 356:12,13
rapid 314:15
rare 226:5 312:1,3 320:11
rate 228:1 260:6 306:6
ratio 318:12
258:19 374:11 389:21 reasonably
242:4 245:10 257:16 269:12,14 reasoning 344:7 reasons 301:1 310:10 376:7 recall 208:18209:7,13,20 210:13 211:16212:16,21 213:16 214:16215:2,12 217:19,21
291:5 305:19 312:5 325:10 rats
218:5,9,13219:12220:1,4
255:17 property
223:4,18 224:3,10 proposed
325:12 327:15 351:15 379:7 putting 253:9 254:3 255:12 341:5
293:5,9 raw
234:11 237:3 241:17 245:4 248:14 269:1,6,8 276:17
220:10 222:2,3,10,20 223:18 224:14 225:14 226:13 227:6,14 228:12,19 229:19231:5,9,13,16
359:13 proved
211:8 225:9 381:14 provide
214:9 263:22 307:4,9,15 372:13 provided 253:22 261:13 386:3
q
quality 239:13 255:9
quantified 318:7
quantify 312:2 341:2
quantities
rayfield 374:13,17
reach 317:3
reached 364:2 386:10
reaction 209:3 223:20 240:18,22
233:17 234:16,19 235:6 236:2,4,8,11 237:8 238:13 239:12241:22 243:5,13,16 243:19 244:7 246:20 247:7 247:19 248:5 249:4,8,16 250:5,20 252:11,14 253:6 254:11 258:14,21 262:7,17 262:22 263:8,10,19,21
397:22 399:2
257:5 269:22 311:6 341:5 241:8 245:5
265:18 266:4,8,13 270:5,19
270:22 271:6,10 272:13
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMONO010225
[recall - relating]
recall (cont.)
recognizing
reduced (cont.)
refers
273:10,14 274:2,10 275:6 348:21
316:3,11 336:8,10,11
212:3 214:19217:10
276:4,7,20 277:2,5,7,18 recollect
reducing
218:15 236:20 240:13
278:15 281:17,22 282:10
223:22 363:13
243:7 341:1
241:5 242:9 250:15 257:18
282:21 283:6,20 284:1,12 recollection
reduction
259:14 267:20 270:4,18
285:2,4 286:19 287:2,15
219:3 271:17286:17
209:9,13,15,21 210:14,22 271:5,20 274:18 275:3
288:15,20 290:16 291:19
291:15 295:17,21 296:9,12 216:17 249:9 265:11
278:18 279:13,14 282:8
291:21 293:14,18 300:11
297:5,13 298:4,12 299:19 268:19 277:2 279:19
287:10314:11 320:12
301:1,19 302:2 304:20
300:13 312:1 315:9 316:4,5 redundant
323:11 334:10 347:16
305:3,9,13 306:10,15 307:8 318:18 327:16 329:21
392:3
367:15 378:12,14 386:15
307:15,19 309:2,9 310:7,10 342:19 345:12 352:13
refer
387:20,22 393:4 399:20
313:6,17 315:22 316:9
363:9 366:4 367:7 370:19 212:3 237:2 259:15 267:4 reflected
317:9 319:4,14 322:8,11
383:17 385:6 396:8
268:11,14 274:13,14 275:2 296:7
326:4,22 330:18 331:17 recommend
286:6,12 298:6,9 311:12 reflects
332:10,14 333:10,11,13,17 316:7,11 356:1
325:17 362:16 379:2 387:4 244:4
335:2 337:11 338:8 339:5,7 recommendation
390:13 393:1
refresh
339:19 340:4,13,21 341:5,6 379:6,9,13
reference
219:3 271:17286:17
341:7 342:15 343:1,3
recommendations
208:5,11 211:19,20 212:13 295:17,21 296:9 297:5,13
344:16 345:9 346:6,10,21
223:12 316:6 378:18
216:22 217:15218:14,17
298:4,12 299:19 300:13
347:8,10,13 348:4 352:17 recommended
219:1 229:2,11 231:10
318:17 327:16 329:21
353:18 354:16 359:2,16,19 392:20
236:18 241:4 246:9 258:3 342:19 352:13 363:9 366:4
361:11 363:14 364:18
recommending
259:6 260:12 264:7 267:2 367:7 370:19 383:17 385:5
365:4,8,9,12,15 366:17,20 316:2
270:2 271:20 272:10 279:6 396:7
367:6,22 368:7 369:22
reconditioning
279:12 284:19 285:20
regard
370:2,6 371:8 372:7 373:7 334:12,15
286:1,4,11 287:1 290:8
247:20 253:18 262:18
373:10,14 374:3,20 376:3 reconvene
296:16 297:10 298:18
317:11 326:13 328:10
376:13,21 377:2,3,11
403:11
299:16 300:19 308:20
329:6 355:13 380:21
379:13 381:5,20 382:9
reconvened
309:20 312:20 318:15
381:10
385:4,16 386:14,18,21
302:8
321:6 323:8,14,22 324:1 regarding
388:3,10 390:1 391:18
record
325:4,7 326:10 335:21
213:18 229:19 238:21,22
392:6,8,10 393:22 394:14 207:11 212:12213:2
336:3 337:3 338:22 359:6 239:21 262:5 270:11
396:1 397:14 398:20,22
215:22 216:8 218:12 221:1 359:11 360:9 363:20
278:12 283:12 382:22
399:1 402:14 403:1
265:2 278:1,2 284:22
375:14,19 378:11 379:1
388:8,11,12
received
298:22 299:1 303:13,20
385:11 395:18 396:6 397:5 regular
231:1,4,7,20 278:8 288:1
315:17321:1 341:17,18
399:19 400:7
311:8 324:10 348:17 349:2
292:13 299:8 303:16 304:4 350:10,16 380:4,5 384:12 referenced
370:10
304:18 305:9 306:21
390:22 394:21 399:22
220:6 238:20 240:6 259:22 regularly
308:16 309:17 331:16
400:1
275:21 276:2 287:11
345:13
347:17 366:14
records
296:21 323:14 335:15
regulation
receiving
379:10,21
338:10 344:17 360:1
316:8317:13342:18
225:1 304:20 326:16 340:4 recoverable
373:17 375:5 391:3
regulations
386:18
249:13
references
317:8
recess
recovered
209:9 238:1 255:5 258:7 regulatory
250:9 350:11 384:9
245:4
262:4 267:3 268:17 269:5 338:3
recessed
recovery
304:2 319:3 326:1 334:16 reinstituted
302:8
277:6,7,11
339:14 347:4 362:4
378:21 379:2
recipient
rectangle
referred
relate
212:10221:3
264:15
259:11 276:9 277:13
229:8 314:6
recognition
recurrence
284:13 368:5 381:15
related
356:6 357:18,21
306:4
390:14
219:15 307:4 319:16 356:9
recognize
reduce
referring
397:6
218:2 360:12 375:22 380:1 239:17,18 243:11 244:14
219:13,13 230:1 234:3
relates
383:10 387:15,16
249:3,17 251:2 265:16,17 267:5 268:4 270:21 277:6 314:7
recognized
396:20 398:16
280:1 322:2 329:10,11,13 relating
356:9 357:20
reduced
354:3,18 380:20 388:6
208:22 236:9 238:14 301:5
251:1,17276:18277:11
395:3
313:11
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMONO010226
[relations - right]
relations
removed
require
responsible
229:3,4,8
246:17 253:3 261:7,9
252:19 267:18 376:10
273:16305:19319:18
relationships
removing
required
363:10 365:17
219:6
252:20 254:4 258:6
222:15 223:12 241:6
responsive
relatively
renovation
260:11 356:21
344:15 385:9
250:2
238:5,7
requirements
rest
release
repair
260:5
280:5
219:4
267:12 295:22 299:17,19 requires
restrict
released
318:15,18 323:8
230:17 335:7
396:20
228:2
repaired
resaturate
result
releasing
282:2 295:8 297:20
261:8
210:22 211:6 228:15
218:22
repairing
research
247:17 252:22 310:20
reliable
252:20
240:20 368:17 372:13,13
365:8 402:9
293:6
repairs
researched
resulted
reliably
252:9 295:11
248:7
219:19224:3,10 244:12
244:16
repeat
residual
401:11,17
relief
320:4
317:17 318:4 334:21 335:3 resulting
224:18 362:6,10
rephrase
335:6 340:18
228:21
relies
402:10
residue
results
263:16
replace
242:16,22 253:3,8 254:7
288:16291:15296:7,14
remember
282:14,18
256:11 274:7 290:11
301:11
209:16,18,18 210:7,18
replaced
381:12,14 382:6 393:18 resumed
219:17,17 224:1,8 226:20 233:7 282:22 328:21
residues
206:3 207:4 303:4
227:4,9,22 228:18 229:5,18 replacement
253:13 256:12 275:7,13 retire
229:22 230:18 231:12
283:2,6 287:11
285:9 381:10
255:4
232:18,22 234:14 235:11 replacements
resistivity
retrospectively
235:16,16,17 236:7 238:7,9 372:5
255:20,21 257:3,8,11
292:7
240:1 243:18 245:13 246:1 report
resolved
return
254:13,14 256:15,20
217:16,21 218:21 280:20
210:17
394:8
258:11,11,13260:15261:4 292:16,21 302:3 319:4,19 respect
returned
261:14 263:10 264:13
reported
222:16 258:15,22 269:15
399:14
266:7,10 268:6 270:14
280:21 300:20 301:2,12
277:6,19 287:16 291:20 reused
271:19 274:4 275:14,15,19 330:15 333:12 362:2
293:20 301:16,22 305:20
245:7,7
277:21 280:3 281:20,21
385:12
307:16 332:11 340:5 341:8 revamp
282:9,19,20 284:5 285:6,7 reporter
345:11 348:5 349:2,8 356:4 258:3
286:9,16 290:7,10 291:6
204:20
359:21 363:15 365:5 367:5 revamped
293:13 301:18 302:1 305:1 reporting
385:7 389:4,6,7
258:9
305:2,6 309:14 310:4 313:5 214:11,17,20 262:3 301:18 respective
revealed
313:8,22 316:7 318:13,20 301:22 330:19 341:13
204:21
371:9 383:14
321:16 322:10,10 326:21
369:9
respond
review
327:19 330:20 331:1,3,11 reports
222:14 362:6
391:2
331:20 333:19,19 334:13
276:15 293:21
responding
reviewed
335:4,16,19 337:16 340:6 representatives
381:2
207:18 216:5 220:18 307:2
340:16 342:10,10 343:21
232:9 339:1
response
312:18315:20 330:11
344:19 346:4,8 354:22
represented
224:6,14 305:20 391:16
337:9 356:16 370:16 383:7
356:19 357:15 359:4,5,22 249:11
responsibilities
390:6
361:8,10 365:7 366:3 370:5 represents
237:18 259:3 283:12 306:1 revise
371:11,12 372:9 374:18,18 213:12 296:15
313:11 356:22 380:21
274:6,12
375:1 381:17 385:10 386:6 request
381:9 400:12 401:5
revisions
390:4
319:14,15 369:15,22 370:2 responsibility
275:7,12,15,17
remembered
370:20 385:5,6,9
254:6,9,12 259:7 293:14 rheiny
254:15
requested
324:17 332:4,6 341:22
216:13354:11
remote
326:20 327:1 338:9 347:1
342:2 347:22 349:19 357:2 rid
315:10
348:10 397:20
357:5 391:13,16 399:12
239:16241:12
remove
requesting
400:22
right
255:14 290:14,17
347:10 386:18
208:2 220:22 222:13
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMONO010227
[right - sewer]
right (cont.)
sampler
says (cont.)
sent (cont.)
236:14 238:18 246:5 247:1 379:4,7
282:13 284:19 296:5 297:1 244:9 261:5 273:4 281:4
264:16 265:19,22 273:3,6 samples
297:11 300:9,17,19 304:3 284:19 285:4,6,9,10 289:12
275:21 276:13 286:2 306:2 209:19 210:15 213:8,20
310:18 325:8,22 334:3
294:9 306:5 308:2,12 322:1
308:8 312:17 315:4 329:10 215:9 217:3 266:1 267:18 355:16,18 363:7 367:18
327:4 336:15 343:7,8
329:12 334:17 335:15
268:7,12 289:7 293:7
374:9 380:17 390:17
344:21 346:14 351:8
336:20,21 351:9 368:7
309:12 323:2 334:21
391:13 392:17
358:14 360:6 363:1 364:5
390:16 395:9 403:8
386:15,19 389:10
school
366:21 367:12 369:11
ring
sampling
215:6 229:6
371:14 372:21 375:3,9
228:3 380:3
267:19,22 268:4 282:6
science
378:4 380:10,14 382:7
rise
288:16 289:1,4 307:3
316:1 339:3
394:13 395:5 399:7 401:4
289:22 290:4
308:21 309:2,5,10,10
sciences
sentence
rise borough's
310:11 324:1,7,10 333:15 368:16
213:14214:22218:20
353:7
361:13 378:19,21 379:1,19 scope
253:15 263:3 272:1,3
river
383:13
211:11 218:9,9
279:19 280:6 293:4 297:1
363:20 364:2 378:17
sanctions
scrubbed
335:8,22 348:19 369:14
role
317:5
261:16
375:15 384:19 396:17
222:14 398:20
sanitary
scrubber
401:10
roller
269:16
280:4
sentences
258:19
santosalt
scrubbing
306:4
romanek
371:22,22 372:3,4,8
280:4
separate
347:1
santowax
se
237:4 245:11 256:16
ron
238:1,5,7,13 239:22
286:9
258:11 284:7 288:8 308:9
354:12
satisfactory
second
308:10 323:15
room
265:7
212:20 213:7 216:10217:1 separating
258:4,9,12
saturated
218:8 227:17,18 239:21
267:2
rosenberg
256:6 261:6
279:7 281:8 287:7 289:15 September
214:2,5,6 262:2
sauget
294:18 296:4 298:8,19
335:10 358:14,17 401:3
route
378:7,11,13,19
303:18 304:2 306:3 312:13 series
386:8
savage
321:10 323:8 333:6 334:6 273:22 396:14
routine
204:13,16 206:3,6 207:3,7 337:2 343:11 345:2 348:14 serious
246:22 267:22 276:6 279:6 207:10,17 208:5 213:4
348:14 358:20 370:12
223:3,6 226:18 228:4
279:12,20 308:21 311:3
215:8 216:3 217:6 220:16 379:3 390:5 399:13 400:4 304:17 355:16 374:10
312:16 319:22 320:6,9
221:2 263:4 264:2,7 267:8 401:8
served
323:1 385:21
267:11,16,18 278:3,7
secretary
222:18 242:15
routinely
280:22 281:4 285:12,16
327:14
service
338:20 371:6
287:19,22 289:9,12 292:8 section
235:13 252:17 376:10
rudimentary
292:12 294:2,8 299:2,7
323:7 399:14
392:14
233:3
303:3,7,15 304:16 306:8 sections
services
run
350:13 372:18 376:9
383:3
322:18 323:4
244:1 252:3 311:6,9
377:22 378:3 380:6,9
sediment
session
runaway
382:19 383:1 384:10,13
388:4
303:1
223:22 224:11 225:8
390:20 391:1,13 394:20 seeing
set
running
395:3 399:4,6 400:3 401:1 217:21
260:18 263:5 264:10 265:5
225:14 248:3
401:3 403:14
seen
280:13 284:8 317:2 322:6
rupture
save
319:3 323:13 353:15
344:17 374:11
224:19,22
248:3
selling
setting
russ
savings
239:15
220:20
221:9
276:12
semantics
settling
s saw
284:4
321:7,12,15,18,22 322:6,6
safety 222:9,12,13,15,17,20
225:8
345:6 says
225 22 234 3 7 9 358 9 sample
217:5 222:6 240:21 243:14 250:20 251:1 255:8 267:8
289:6 309:6 369:16
267:11,16,18270:10
sending 209:18 326:15,16
sense 254:19 349:8
sent
seventh 205:10
sewage 270:2
sewer
271:15 278:21 280:6,8,20 213:20 215:9 221:6 242:12 217:16,17,19 243:7,12,20
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMONO010228
[sewer - specimens]
sewer (cont.)
signifies
slower
sorry (cont.)
244:14,20 246:8 261:21
213:13
314:22
351:21
278:12281:10,10,14,18,18 silage
slowly
sort
281:20,22 282:2,11,14,18 333:1
226:6
257:14 284:8,16 287:5
282:19 285:21,21 286:5,13 silica
sludge
292:5 338:21 356:7
287:9,11,16 288:9 291:2
258:2
265:21,21 266:3 270:16 sounded
293:5,6,9 295:6,10,18
silo
271:6,10,10,12,18272:11
304:17
296:6,6,13 297:2,4,21,21
332:17,19,20,21
272:12 375:20
sounds
298:5,10,18 299:17 300:2,5 silver
small
287:13 394:15
300:11,14 306:5 311:1
221:14
215:5 225:4,9 246:14 250:2 source
318:16 322:1 323:8,11,16 similar
255:18 257:4,6,18 261:20 296:7 325:20
324:1,7,9,15,18,19 335:22 234:20 289:8 322:3,4,11
378:13
sources
369:17370:8 401:11,14,19 349:7 354:6 389:1
smaller
293:6 318:10 319:21,21
sewered
simplest
318:11
south
310:20 311:11,14
263:15
smith
270:16,16 321:8,14 334:14
sewers
simplify
204:18 354:12
399:15,19 400:5,8,8,13
209:22 217:22 244:10,11
241:21 242:9
smooth
space
244:12 271:16,22 272:6 simply
336:1
305:10 399:21
277:16 282:21 283:3,7,12 215:3 217:3 219:16 225:18 snow
span
286:9 288:5,6 293:15
241:1 244:10 252:10 257:7 385:18 386:4,10
396:11
295:18 296:11,17,21 297:6 267:12 316:21 317:6,14 snow's
speaking
297:17 298:16 300:6
336:12 376:19 381:2
385:11 386:13
229:5 339:19 346:6
317:18 318:5 323:13,14 sink
society
special
325:4 336:8,9 364:2 386:11 225:21
232:2,5
217:16,17 267:19 268:4,7
401:11,16402:7,8,8,17 siphoning
soda
311:6 376:10
shedded
225:5
241:15,16,17,18 242:1,5,8 specialist
250:3
site
sodium
364:10
sheet
382:22 383:5,13,14,19,20 239:22 242:6,7 257:1
specialized
234:10
384:1,6
261:21
342:8 368:21
sheets
situation
soil
specialty
234:3,8,13 358:10
210:8,9 224:7,11,15227:17 234:18 248:22 249:9
391:21
shipping
228:16 245:1 288:21 298:7 317:18 383:13
species
254:10,11 373:3 400:21
320:12 326:6 327:17
soils
301:6
short
328:10 329:6 331:8 332:11 318:4
specific
250:7
337:13 339:20 341:21
sold
210:19 217:2 222:3 225:1
shortly
345:11,16 346:7 359:21
290:11 388:18,21
231:10 235:6 244:1 249:8
265:19
situations
solid
249:16 278:18 283:11
show
227:7
226:7,14 241:11 242:17
285:7 286:10 305:2,6 316:7
241:2
size
290:18 314:12,13 373:12
346:8 357:15 383:3 390:4
showed
223:14
374:22 389:17 393:20
403:2
352:9
sized
394:17
specifically
shut
266:2
solids
213:10224:1 229:7 231:12
252:3
skin
277:14 306:4 389:14,20
231:18 247:7 256:20 267:5
shutting
355:19 356:7,10 357:10
393:2,5
283:22 286:9 288:17
252:19
358:3,4
solution
301:18311:12313:5
side
skip
214:13 222:16 245:12
317:12 327:19 337:17
242:20
253:10 275:14 350:13
solved
338:1 343:3
signature
371:13
245:14,16
specification
352:1
skips
solvent
255:22
signed
253:3 254:4,7
245:3 372:6
specifics
387:18
slabs
somebody
381:17
significance
259:17
244:15 283:10 363:12
specified
316:15
slightly
somewhat
301:5,9
significant
252:7
239:1 350:13 357:20
specimens
265:11 319:5 324:12
slow
sorry
246:14
314:16 379:4
262:11 320:15 325:12
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMONO010229
[speculate - sued]
speculate
stands
step (cont.)
strong
214:21 290:2
220:13 243:22
255:10 276:14 319:10
267:2,3 316:19 317:13
speculating
starr
Stephen
stuck
290:1
273:7,8
205:7
284:3
speculation
start
steps
studied
318:2 402:4
207:13210:11 215:21
237:7 246:10 265:18 289:5 213:9
speed
309:16
362:6,9
studies
250:3 379:4
started
stewart
209:17
speeds
233:11 239:1 245:2 252:10 284:17 288:1 308:6 328:6 study
391:2
264:21
329:13 395:4 398:4,15
212:13213:15,18259:14
spell
starting
401:5
265:20 291:20,22 353:7
354:14
239:3 250:12 330:13
Stewart's
365:4,8,9,15,18,21 366:5
spending
startling
329:15
studz
267:13
366:2
stills
306:8
spent
starts
226:22 251:8,14,22 254:7 stutz
261:6,9 317:4
293:4 307:2 331:15 384:19 258:12 393:19
208:3 209:3,6 212:9 213:5
spill
396:17
stint
216:10 220:5 262:2 266:2
291:3,17,17
state
358:6
269:16
spillage
204:2 300:20 301:3,12
stone
stylized
241:22
329:11 344:2,4,9,15,18
259:17
387:17
spills
394:17 397:20
stones
subject
258:22
stated
259:20
208:22 274:4 292:1 305:14
spots
385:4
stop
306:11,15,17316:1 317:9
247:2
statement
377:4 379:7 403:9
329:5 332:10 333:18 361:1
sprague
211:10213:8 214:11 215:7 stopped
361:16 367:19 377:19
221:8,9 273:14
280:5 295:5 305:8 313:14 385:22
subjects
sprayed
317:16 318:2 329:9,15,18 storage
236:5 372:2,9,11
228:3
340:7,17 346:22 348:15
400:16,20
submerged
square
358:21 366:19 370:13
store
225:3 251:16252:17253:1
205:9 264:18
383:13 396:2 399:14
260:8
submission
srs
statements
strange
206:24 382:22
327:9
248:13 392:21
328:5
submitted
St
states
strategies
295:14 345:3
214:7 216:15 273:16
260:10 262:13 281:9
343:18
submitting
334:14 347:6 353:21
283:16 289:17 297:20
strategy
293:21
364:15
306:4 310:16 311:10 328:1 328:1 331:6,7,10,12,14,15 subscribe
staff
331:15 334:7 344:14,14
331:20 343:12,15 344:17
232:19
390:15
345:2 355:6 357:8 358:17 stream
subsequent
stage
362:13 367:18 376:6 378:7 261:12
298:7 400:12
249:19
390:6
streams
subsequently
stagnant
stating
289:5 300:2 316:2,11
259:3 295:7 394:12
225:20
309:20
street
substance
stance
station
204:19 205:4,11 298:19
284:13 328:2 361:11
349:7
258:5 324:1,7
323:8
377:12
stand
statistical
strict
substantial
207:4 303:4
249:20
317:7
318:1
standard
statistics
strictly
substitutes
206:18 246:13 247:14
229:17
225:22
372:14
350:19 351:11 352:10,14 status
strike
successful
353:4,10,10,11,19 356:17 283:16 288:12 297:10
210:4 214:15 222:2,6
289:1
357:1
325:22 330:14 335:21
248:18 262:21 274:13
sucked
standards
stay
280:16 286:18 291:20
252:1
317:2,3 341:1 352:21
297:16 317:14
306:15 311:12 356:2
sudden
359:14 367:5
step
364:15 373:11,15,20
223:21
standridge
237:4 240:18 242:18 245:5 381:21 389:4 393:8 401:21 sued
220:6 270:4,5 304:3 305:14 246:4,19,20,22 247:9 251:2
359:20 361:17
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMONO010230
[sufficient - theory]
sufficient
surface
taken (cont.)
temperatures
227:12 263:16 401:18
263:17
386:15 392:13 394:18
315:6
sufficiently
surprise
398:16
temporarily
265:17
245:6 318:6,8 353:1
talk
380:22
suggest
surprised
219:16 254:20 284:16
temporary
343:14
388:14
348:22
245:8 381:16,20 382:1,3,8
suggested
surprising
talked
392:5
362:5
224:16
289:3 352:11 361:12
tend
suit
survey
talking
250:1
359:12,16
276:4
236:5 268:18 334:20 385:3 tentative
sulfide
surveying
talks
351:7
242:18,19
276:10
213:14 218:8 222:7 240:9 tenure
sulfur
suspect
241:15 243:7 267:22
229:16 230:4 231:20 232:8
210:20 242:17
340:8 350:4
270:10,15 279:19 281:14
233:6 259:8 291:7
summarized
suspected
287:8,8 288:4,12 300:2 term
319:11
224:17 227:3
339:15,16 356:11 379:4
257:18 274:21 275:1 293:9
summarizing
sustained
383:4
293:11 313:2,5 314:5,10,11
396:15
227:12
tank
325:14,16401:15
summary
sutkas
241:19 245:12 255:12
terminology
319:15
386:22 387:10
270:16,17,22 271:11
278:15
sump
sutkus
tanks
terms
290:21,22
386:16
227:11 264:16 265:22
259:9,10 283:13 341:2
super
svo
271:4,13 280:5
402:17
362:14,21
379:10
targets
terphenyl
superintendent
sweets
316:7,22
388:21 389:18
221:9,13 270:3 271:15,21
221:11,12
task
terphenyls
308:4 346:19 375:12
sworn
241:21 283:16,20 284:1,6 388:16 389:7,9,12,14,19
398:11
207:4 303:4
284:13 297:10,14 338:22
390:2,11
superior
symbol
339:6 360:9 371:21 372:8 test
204:1
387:17
391:19
212:20,21 241:1 244:1
supervision
symposium
taught
255:19,20 264:1 265:1,2,12
357:2
367:15,22 368:4,6,8 369:5 229:15
265:14,15 266:10 268:15
supervisor
synthesis
teach
271:2 300:10 311:4,6
220:8 238:18 239:1 240:8 237:4
229:12
tested
250:17 251:7 253:21 254:5 system
team
212:17263:13365:12
273:8 275:11 332:7 357:22 224:4,9 245:8 252:1 259:21 284:5
testified
358:7,12 386:2,7
260:4,9,11,11,12,22 261:5 technical
207:5 303:5
supplied
261:12 265:6 275:14
215:20 216:14 223:2 230:5 testimony
385:16 388:3
281:10,18282:2,14,18
233:1 235:13 251:1 273:17 347:1,10 348:10
supplies
285:21 286:5 296:13
276:22 322:18 323:3,4
testing
369:14
297:21 299:18 300:5 307:3 347:22 353:20 354:2,7,9,19 212:18213:11 301:12,20
supply
324:10 335:22 378:21
technically
301:21
239:4
379:1 401:11,14
217:4
tests
support
systemic
technician
209:9,13,21 210:14,22
265:12,14
357:9
333:11
211:6
suppose
systems
techniques
texas
254:17
288:9 309:6
230:3
381:1
sure
t technology
text
219:9 220:14 234:14 235:5 tafey
316:1 339:3 349:22 354:20 281:14
245:1 247:1 255:22 257:4 257:11 274:4,22 280:2 290:15 291:3 308:4 328:19
369:19 385:6 387:18 388:7 388:11 taken
telephone 370:14 384:20
tell
textile 218:15,16
theoretical
328:21 334:11 surety
217:4 219:21 224:6 256:14 257:5,12 265:18 280:9
338:3 temperature
247:16 theory
204:9
289:5 309:13 320:20,21
223:22 224:11 227:2
248:1,6
328:11 362:6 379:18
251:14 252:18
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMONO010231
[thermally - unit]
thermally
time (cont.)
top (cont.)
trust
226:22 249:22
225:14,19,19 228:1 229:4 395:9 398:18
205:3
therminol
230:19,21 231:4,22 232:12 torrential
try
285:3,6,9
232:14 233:13 234:8 235:4 401:10 402:1
276:17 300:10 338:2 341:3
thing
235:19 236:15,22 237:17 total
trying
210:3,5,6 217:4 233:2
237:22 238:5,8,14 241:18 300:18 301:8,8 318:11
210:8 312:4 341:2 370:6
247:22 284:16 310:5
242:13 243:20 245:1,22 tower
tsd
338:21 341:3 349:1 402:18 246:7 247:21 248:9 249:6 211:1,7,8 214:3 260:14,20 220:20 221:15,16,20 222:8
things
249:21 250:1,3,7 251:6,15 260:22 261:11,11,19,20
229:1,15 283:17 332:9
210:16 222:7 229:1,5,6
251:15 253:7 254:5 255:3 toxic
357:3
234:3 236:5 250:2 258:2
255:13 256:7 258:18
228:5,7,9 257:14 328:2 turn
269:11 323:1 332:17
259:13 260:2 264:11,13
357:20 358:18 359:2
270:1 283:15 284:18
361:13 396:6
265:19 270:6 273:8,11
376:22 377:4,20
288:11 327:21 333:6 334:6
think
274:11 275:8,16 280:19 toxicity
350:14 351:5 352:3 355:1
210:1,11 216:13219:15
284:8,11,17 288:16 290:19 233:18,21 236:10 355:4,7,8 357:6 383:3 398:14 401:8
220:5,14 221:18 229:17
291:9,14 292:3 295:19
355:13,15,16 356:12,13 turned
232:11 246:22 253:8
303:13 304:22 306:1,6,13 tpm
224:16 225:8 252:8 259:18
256:15 259:18 262:12
306:17 308:4 309:3,12
354:13
392:3
265:10 267:10,18 268:16
310:3,6311:19312:1 313:7 traces
type
276:8 277:10 282:1 308:3,4 316:16 317:4,22 318:5,10 255:15
224:3 229:14 237:11
311:19313:4316:13
320:1,7,10 321:15 324:5 trade
252:21 256:13 292:21
317:12 318:1 322:2 329:2 326:5,7 328:9,22 329:4,19 230:9 231:21 372:4
308:11 318:18,19 322:20
332:4,7,20 333:15 338:12 332:3,5,6,8 334:11 337:15 training
326:4,22 329:22 331:18
339:10 342:5,7 344:10
337:15,16338:13341:13
229:11,12,14,17,19
341:8 344:16 349:1 358:5
352:9 353:9,11 354:5,11,12 342:16 345:12 346:18,21 transfer
370:2 402:18
354:19 356:5 357:20 358:2 347:20,20 348:3,7,10,13
263:16
types
358:11 359:8 365:14
349:7,20 350:4,22 351:2,12 transmission
287:15
368:17 374:8 375:11
351:13,19 352:22 353:13
294:22
typewritten
376:18 377:18 381:2 385:4 353:17 354:5,8,13,17,18 transmitted
375:4
385:19 387:5,9,17,18,22
357:16,19,22 358:11 359:8 285:17 294:12 299:11
typical
390:19 393:3 398:11
361:2,2,22 362:3 363:16 trap
210:19213:11
402:20,22
364:12,13 368:1,12 369:20 224:17
typically
thinking
370:3,4,20 374:21 375:12 treat
222:14 305:10 314:22
208:14 334:18 392:21
377:3,8 379:5 381:8,13
226:7 244:21 263:15
324:12 332:2
third
385:16,19 388:12,13 390:8 266:18
u
218:14 238:20 297:9
392:22 393:8,9,17,20 394:7 treating
underground
327:21 331:13,14 340:7 348:4 362:13 376:6 383:3 392:16 393:3 thirty 205:10
396:11 397:15 398:12 399:12 400:11 403:9 times 226:15 282:3 290:16 309:22
262:6 263:14 treatment
212:4 219:10,16,20 220:9 220:12 226:6,7 239:22 243:22 244:11,13,16
281:9,18 285:21 286:5,13 296:22 297:6,22 298:5,10 underneath 225:16 understand
thoroughly
tiny
237:5
257:9
thought
title
222:4 244:8 250:11 321:21 208:10 216:14 354:5,17,19
335:5 367:1
told
249:15 255:11,21 262:18 263:5,9,14,20,22 264:9,20 265:7 266:5 270:2,19,20 272:7,15,17 288:13 304:5,9 304:16,21 305:4,7,16 306:7
273:19 296:14 314:5 understanding
215:17238:10257:13 279:16 292:20 308:1,11 311:13,21 313:20 314:7
three
250:11 362:13 377:15
306:18 378:14,17,20
317:22 335:6 337:18,21
223:1 270:15 307:13 396:18 397:1
tolerable 316:14
trench 224:22 225:16,17 226:4,5
348:22 349:7 357:14 358:5 358:6 371:3 373:16 375:2
threshold 213:12
thursday
tom 341:12 368:14
top
trend 402:1
tried
389:11 390:7 understood
370 13
403:11 time
239:17 245:19 261:11
209:3
270:1 273:3 317:16 327:7 truck
undertaken 282:18
209:1,14 216:14,21 219:8 334:4 336:21 360:2,10
253:3,11 254:4
unit
221:10,19222:4,11,21
375:10,19 380:17 390:16
265:21 266:3 321:8,14
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMONO010232
[unit - work]
unit (cont.) 399:16
unplugged 290:17,19
unreacted 237:4
unreasonable 319:18 331:21 341:3
unsafe 228:21
unstable 226:21 227:1 250:1
unusual 227:1,2 289:17 292:18,21 311:4 325:14,15 348:16 349:10 357:3 376:10 401:16
upcoming 339:20
upgrade 298:18
upper 268:8,14,17
upstream 211:4 279:21
upward 402:1
usage 239:17,18
usda 339:2,8
use 235:3 250:17 257:7 340:9 370:21 372:6 376:22 381:19382:1,9,13 391:11 391:19
useful 233:16
usually 223:10 232:18 275:3 314:11 388:18
utilities 283:5,8,11
utilize 239:10
V
vacuum 251:22 261:3,10
vague 314:9 316:4 320:3 402:20
valleys 336:1
vapor 279:20 280:7 355:8
variability 336:8,10,11
variation
washing
went
310:14
242:8
208:15211:2 219:16220:5
variations
Washington
225:11 226:12 227:13
310:2,7,11
337:4 338:11,13,18,20
232:21 240:22 256:8
varied
362:7
261:21 326:2 375:6,7
396:18
waste
378:17 386:13 394:19
various
211:2 212:4 216:22 217:1 wet
210:16 222:18 236:1
219:10,20 220:9,11 226:6,7 261:12,13
246:15 259:20 296:10
229:9,19 231:14 238:14 we've
316:21 322:22 337:14
243:8,22 244:16,17,22
264:7 323:13
338:19 339:1,15 372:14
245:19 246:6 249:14
wgk
vendor
253:18 254:1 260:10,12,14 284:20 328:1 330:16
233:15
260:16,19 261:12,20
331:14 343:14 373:12
versus
262:18 263:5,9,14,20,22
395:15 396:7,10 398:16
349:10
264:9,20 274:3 276:21
wgk's
vessel
277:1 282:7 304:9 305:4,16 317:18
224:21 246:16 251:12
306:18 352:7 353:6 369:17 wheeler
253:1
370:6 378:15,20 393:21
365:19
vessels
394:7,14
wiese
224:18
wastes
354:12
view
209:10 211:20,21 212:1 Wilmington
336:11
213:19218:15,17243:14
204:14205:5 341:15
village
244:18 249:15 262:6
wind
378:7,11,13,19
263:15 266:5,14,20 267:3,4 389:21
virgil
268:1 269:2 377:5 393:10 winding
360:3
393:15,15 394:3,11 397:8 248:14
virtually
water
wink
316:3,11
218:22 219:7,8 225:4,5,6,6 329:2
visas
225:18,19 226:5 234:18 wishful
338:21
245:20 249:9 280:4 286:5 208:14
visit
286:12,13 296:22 297:7,22 withers
262:3 306:9 324:4 363:7
297:22 298:5,5,10,11
368:18,19
visited
369:16 388:4
witness
220:11 324:8
waters
206:2 207:18 216:5 220:18
visitor
313:14
303:21 312:18314:10
273:16
wayland
315:20 319:10 320:4
visualize
216:10,20
330:11 337:9 383:7 402:22
256:19 374:10
wayne
witnessed
volume
368:19
394:18
204:13
ways
wobus
w 210:10 264:17 277:10
waiter 346:22
wantprl
weak 267:3,3
Wednesday
233:8 243:15 315:3 317:14 377:1
204:15 week
wanting
231:21 232:3,17 378:8
237:8 warehouse
weekly 268:1
373:4 400:21 warehoused
373:12
weeks 246:17
weighted
warren 338:10
349:10 welge
wash
205:8
355:20
216:12,13 354:11 wondering
264:8 wood
369:7,8 word
263:15267:8 331:12,20 wording
336:6 words
260:18 268:6 272:18 284:13290:13325:15,16 work 211:10,16 221:22 223:2 240:11 241:2 249:2 255:9 276:22 277:3 293:4 295:22
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMONO010233
[work - zero]
work (cont.) 299:17,20 323:3,3 333:10 348:7 361:9 365:6 372:10
worked 214:1,10 220:8 222:16,21 223:1 235:19 245:10,18 260:15 350:2 372:13,16 392:8
worker 227:12,15,18 228:12
workers 227:8 254:13 365:13
working 209:16 218:5 227:19 228:2 234:22 284:4 325:21 332:9 372:9
wound 261:14
write 264:21
writing 239:2 267:10 327:7 329:18 334:4 336:21 357:1 374:6 380:17,18 395:9,11
written 234:11 307:11 345:3 391:7
wrong 321:22__________________
y yard
386:12 yeah
395:11 year
215:6 232:11 312:4,4,7 years
222:8 223:1 230:17 232:13 234:6 292:2 305:5 307:13 377:6 396:18 397:2 yellow 357:9 yesterday 227:9 250:12 282:1 289:4 304:10 yield 247:18 248:1,5 249:19 250:4 277:11 yields 243:8,14,15______________
z zeman
391:6 392:1 zero
316:3,12
Savage, James (Aroclor Dept employee) in AETNA (2)
HARTOLDMONO010234