Document 3QYgvKDjBXjmL7j004oyJa2aJ

In Re: Solutia, et al., Vs...........................Case No. CV-03-PWG-134-E. McWane, et al. , 118 August 31, 2004 Videotaped Deposition of WILLIAM B. PAPGEORGE, Volume II Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050313 1 In the United States District Court 2 For the Northern District of Alabama 3 Magistrate Judge Green 4 5 Solutia, et al., 6 .............................. Plaintiffs 7 8 Vs.............................. Case No. CV-03-PWG-134-E. 9 10 McWane, et al. , 11 .............................. Defendants. 12 13 14 15 16 17 18 Videotaped Deposition of WILLIAM B. PAPAGEORGE, 19 Volume II, taken on behalf of the Defendants, at the 20 offices of Husch & Eppenberger, LLC, 190 Carondelet 21 Plaza, Suite 600, in the County of St. Louis, State of 22 Missouri, between the hours of 8:49 A.M. and 12:41 23 P.M. on the 31st day of August, 2004, before J. Bryan 24 Jordan, Certified Court Reporter and Notary Public. 119 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050314 1 APPEARANCES OF COUNSEL: 2 FOR THE PLAINTIFF: 3 Joseph G. Nassif, Esq. 4 HUSCH & EPPENBERGER, LLC 5 190 Carondelet Plaza, Suite 600 6 St. Louis, MO 63105-3441 7 Telephone: 314-480-1500 8 Direct (314) 480-1818 9 Fax 314-480-1505 10 j oseph.nassif@husch. com 11 12 FOR MEAD WESTVACO: 13 Wendlene M. Lavey, Esq. 14 SQUIRE, SANDERS & DEMPSEY, L.L.P. 15 4900 Key Tower 16 127 Public Square 17 Cleveland, OH 44114-1304 18 Direct (216) 479-8545 19 Fax: (216) 479-8780 20 wlavey@ssd.com 21 22 23 24 120 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050315 1 FOR SCIENTIFIC-ATLANTA, INC.: 2 Lynette Eaddy Smith, Esq. 3 TROUTMAN SANDERS LLP 4 NationsBank Plaza, Suite 5200 5 600 Peachtree Street, Northeast 6 Atlanta, GA 30308-2216 7 (885-3489 8 Fax (404) 962-6688 9 lynette.smith@troutmansanders.com 10 11 FOR PHELPS DODGE: 12 Lynne Stephens O'Neal, Esq. 13 LEHMAN, SIEGAL & PAYNE, P.C. 14 600 North 20th Street 15 Suite 400 16 Birmingham, AL 85203 17 (205-251-5900 18 Direct (202) 986-5023 19 Fax (205) 323-2197 20 sls@lsppc.com 21 22 23 24 121 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050316 1 FOR LEE BRASS: 2 John Scott, Esq. 3 HUCKABY, SCOTT & DUKES 4 2100 Third Avenue North 5 Birmingham, AL 35203 6 (205) 251-2300 7 8 FOR HURON VALLEY STEEL: 9 Karen Pilat, Esq. 10 BUTZEL LONG 11 100 Bloomfield Parkway, Suite 200 12 Bloomfield Hills, MI 48304-2949 13 (248) 258-1616 14 Fax (248) 258-1439 15 pilat@butzel.com 16 17 FOR GII INDUSTRIES: 18 Raakhee Biswas, Esq. 19 BAKER BOTTS L.L.P. 20 The Warner, 1299 Pennsylvania Avenue, N.W. 21 Washington, District of Columbia 20004-2400 22 Telephone: 202-639-7707 23 Fax: 202-639-7832 24 raakhee.biswas@bakerbotts.com 122 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050317 1 FOR SOUTHERN TOOL: 2 Ms. Stacey H. Myers, Esq. 3 RESOLUTION LAW GROUP, P.C. 4 5335 Wisconsin avenue, N.W, Suite 305 5 Washington, DC 20015 6 (202) 686-4844 7 Fax 9202) 686-4843 8 shm@reslawgrp.com 9 10 FOR McWANE, FMC, AND UNITED DEFENSE: 11 Jarred O. Taylor, II, Esq. 12 MAYNARD, COOPER & GALE, P.C. 13 1901 Sixth Avenue North 14 Suite 2400 AmSouth/Harbert Plaza 15 Birmingham, AL 35203-2618 16 (205) 254-1061 17 Fax 9205) 254-1999 18 j taylor@mcglaw.com 19 20 21 22 23 24 123 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050318 1 FOR WALTER INDUSTRIES AND U.S. PIPE AND FOUNDRY 2 COMPANY: 3 James A Langlais, Esq. 4 ALSTON & BIRD, LLP 5 One Atlantic Center 6 1201 West Peachtree Street 7 Atlanta, GA 30309-3424 8 (404) 881-7000 9 Fax (404) 253-8695 10 jlanglais@alston.com 11 12 FOR DATRON AND ANCHOR METALS: 13 Michael S. McMahon, Esq. 14 McMAHON, DeGULIS, HOFFMANN & LOMBARDI, LLP 15 The Caxton Building - Suite 650, 812 Huron Road 16 Cleveland, OH 44115-1126 17 (Cuyahoga Co.) 18 Telephone: 216-621-1312 19 Telecopier: 216-621-0577 20 mcmahon@mdhl.net 21 22 23 24 124 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050319 1 THE VIDEOGRAPHER: 2 Curt Shaw, Legal Videographer 3 GORE PERRY GATEWAY & LIPA REPORTING COMPANY 4 515 Olive Street, Suite 700 5 St. Louis, MO 63101 6 (314) 241-6750 7 (314) 241-5070 Fax INDEX 10 Examination by Ms. Lavey (cont'd) .... .... 128 11 12 EXHIBITS 13 Defendant's Exhibit 9 ............................................... .... 137 14 Defendant's Exhibit 10 ............................................... .... 162 15 Defendant's Exhibit 11 ............................................... .... 163 16 Defendant's Exhibit 12 ............................................... .... 169 17 Defendant's Exhibit 13 ............................................... .... 207 18 Defendant's Exhibit 14 ............................................... .... 213 19 Defendant's Exhibit 15 ............................................... .... 216 20 Defendant's Exhibit 16 ............................................... .... 224 21 Defendant's Exhibit 17 ............................................... .... 226 22 Defendant's Exhibit 18 ............................................... .... 227 23 Defendant's Exhibit 19 ............................................... .... 232 24 Defendant's Exhibit 20 ............................................... .... 234 125 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050320 126 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050321 1 MS. LAVEY: Do we have everybody on the 2 phone that's going to be joining? Do you know, 3 Raakhee? 4 MS. BISWAS: I think not yet. I just sent 5 out the e-mail. I think there's one other person to 6 sign in. 7 MS. LAVEY: We're going to start anyway 8 because it's a quarter of. 9 MR. SCOT: This is John Scott. 10 MR. McMAHON: This is Mike McMahon. 11 MS. LAVEY: Is Karen Pilat on? 12 (No response) 13 MR. TAYLOR: Let's just get started, let 14 them dial in when they dial in. 15 MS. LAVEY: I just need it for the record 16 when they do dial in, they'll just be in at that 17 point. 18 MR. NASSIF: We can take their names at the 19 break as to who's on the phone. Let's go. 20 MS. LAVEY: Yeah, let's get started. 21 THE VIDEOGRAPHER: We're on the record at 22 8:49 A.M. Today's date is August 31st, 2004. My name 23 is Curt Shaw, legal videographer, along with Jerry 24 Jordan. We're at the offices of Husch Eppenberger. 25 The address is 190 Carondelet Plaza, Clayton, 127 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050322 1 Missouri. We're here to continue the deposition of 2 William B. Papageorge, to be taken in the case of 3 Solutia, et al., vs. McWane, et al., currently pending 4 in the Northern District of Alabama, Cause Number 5 CV-03-EWG-1345-E. 6 At this time, would counsel please identify 7 themselves for the record? 8 MS. LAVEY: Wendy Lavey, of Squire, Sanders 9 & Dempsey, representing Mead Westvaco. 10 MR. LANGLAIS: Jim Langlais, of Alston & 11 Bird, representing Walter Industries and United States 12 Pipe & Foundry. 13 MS. O'NEAL: Lynn O'Neal, Leitman, Siegal & 14 Payne, representing Phelps Dodge. 15 MS. MYERS: Stacey Myers, of Resolution Law 16 Group, representing Southern Tool, Inc. 17 MS. SMITH: Lynette Smith, at Troutman 18 Sanders, representing Scientific-Atlanta, Inc. 19 MR. TAYLOR: Jarred Taylor, of Maynard, 20 Cooper & Gale, representing McWane, FMC, and United 21 Defense. 22 MR. NASSIF: Joseph Nassif, representing 23 Solutia, et al. 24 MR. SCOTT: John Scott, for Lee Brass. 25 MR. McMAHON: Mike McMahon, for Datron and 128 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050323 1 Anchor Metals. 2 MS. BISWAS: Raakhee Biswas, for DII 3 Industries. 4 EXAMINATION (Continued) 5 BY MS. LAVEY: 6 Q. Mr. Papageorge, good morning. 7 A. Good morning. 8 Q. Welcome back. 9 A. Thank you. 10 Q. I wanted to start by asking you about some 11 additional personnel to see whether these names come 12 to mind when you hear them, from the Anniston Plant. 13 The first name is Dur Watson. Do you recall that 14 individual? Dur is D-u-r. 15 A. I do not. 16 Q. Okay. Marvin Nunnelly? 17 A. I don't recall him. 18 Q. Eugene Hill? 19 A. No. 20 Q. Walt Reed? 21 A. I recognize the name. I can't place the 22 person as an individual. 23 Q. Do you recall if he was with the Maintenance 24 Department? 25 A. I do not. 129 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050324 1 Q. Edwin Finley? 2 A. I don't know him. 3 Q. After we concluded yesterday and before we 4 began this morning, did you review any other--any 5 documents in preparation for today? 6 A. I did not. 7 Q. Did you do any other preparation prior to 8 this morning's deposition? 9 A. No. 10 Q. Understanding that I'm a lay person, I'd 11 like to try to understand the biphenyl production 12 process, and I'm going to try to walk through that 13 with you to explain how that production process worked 14 when you arrived at the Anniston Plant in 1965. 15 Before I do that, are there any other personnel 16 responsible for biphenyl production at Anniston that 17 you can think of today, other than Robert Moody? 18 A. I hesitate because my memory is not very 19 clear on this, but it seems to me I recall an 20 individual by the name of East something, replacing 21 Mr. Moody, but that is as close as I can get to 22 identifying that individual. 23 Q. Okay, do you recall any other individuals 24 who worked in that, in that group in the biphenyl 25 production process area? 130 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050325 1 A. Not at the moment. 2 Q. Now, the production of biphenyl would be the 3 first step before you could produce the chlorinated 4 biphenyls; correct? 5 A. I don't know what you mean by "first step." 6 Q. Well, in, in order to produce--in order to 7 manufacture the Aroclors, one had to first manufacture 8 the biphenyls; correct? 9 A. Have to have a source of. 10 Q. Have to have a source of the biphenyls? 11 A. Yes. 12 Q. For the Anniston Plant, they were 13 manufacturing the biphenyl at the Anniston Plant; 14 correct? 15 A. Yes. 16 Q. Okay, and do you recall the type of process 17 that was in place when you arrived in 1965 for 18 biphenyl production? 19 A. I just do not remember the technicalities 20 involved in this operation. It's been awhile. I just 21 do not remember it. 22 Q. Do you recall if that the lead pot process 23 was in place when you arrived in 1965? 24 A. I do not recall any mention of lead at all 25 in the Anniston Plant. 131 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050326 1 Q. What is your general understanding of how, 2 how the biphenyls were produced? I understand you 3 said you don't recall the, the details, but what is 4 your general understanding of, of biphenyl production 5 at Anniston? 6 A. Just depending on my understanding of 7 chemistry, in order to get two benzene rings to join, 8 each of those rings has to lose a hydrogen, and that's 9 as far as I can go in rec--recalling what happened in 10 the process. 11 Q. Do you recall what the raw materials were in 12 the process in order to produce biphenyl? 13 A. Benzene is the only raw material I recall. 14 Q. Okay, and was that in a liquid, benzol form? 15 A. Yes. 16 Q. Okay, and at some point in time, that would 17 have to--as part of the process, that would have to be 18 vaporized, correct? Be a benzene vapor? 19 A. Since I don't recall the process, I don't 20 know if it occurred, a liquid phase or a vapor phase. 21 Q. Okay, so you don't recall a series of, I'll 22 call them pots, for lack of a better word, through 23 which the benzol was, was moved to allow the process 24 to take place? 25 A. I recall these tanks which were called, 132 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050327 1 could be called pots-2 Q. Okay. 3 A. --in which reaction, chemical reaction was 4 taking place. Fairly common for many, many chemical 5 processes. 6 Q. Presumably, when you arrived there in 1965, 7 you did tour the biphenyl production area, did you 8 not? 9 A. Yes. 10 Q. Do you recall whether any of those biphenyl 11 units contained molten lead? 12 A. No, as I mentioned earlier, I just never 13 associated a plant with lead. 14 Q. Did you ever come to understand that the 15 lead pot process had been used at the Anniston Plant-16 A. No. 17 Q. --in the past? 18 A. The first time I've heard lead associated 19 with the Anniston Plant was at these discussions we've 20 had here. 21 Q. Well, I haven't brought them up yet, so what 22 discussions do you mean? 23 A. Well, you asked questions about them. 24 Q. Today. Okay. 25 A. That's the first time I've heard lead and 133 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050328 1 Anniston mentioned in the same discussion. 2 Q. Do you know if the lead pot process was in 3 use at the Krummrich? 4 A. No, I do not. 5 Q. And as you sit here today, you are unable to 6 identify any living individual who would have 7 knowledge about the biphenyl production process at the 8 Anniston Plant? 9 A. That is correct. 10 Q. Do you know for how long biphenyls were 11 produced at the Anniston Plant? 12 A. No, I do not. 13 Q. Are you familiar with documents referred to 14 as standard manufacturing processes, or SMPs? 15 A. Yes. 16 Q. Who would have the responsibility for 17 developing standard manufacturing processes? 18 A. I don't recall any specific individual or 19 job title that associated with that. It was generally 20 a, a group effort with the research chemist who 21 developed some idea of a process in the laboratory and 22 transferring that to something that could be used in a 23 larger scale in the plant, and then the individuals 24 representing manufacturing would contribute, based on 25 their experience, with other chemical manufacturers 134 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050329 1 regarding the size of these tanks or pots, as we 2 called them, and the frequency of starting a 3 particular batch of the material, and when is it 4 completed, what do you do with it after that, and so 5 on, so it's a group effort, really. I don't know of 6 any one person designated. 7 Q. Was it typically at the plant level that the 8 SMPs were generated or at the headquarters level? 9 A. I don't know that I'd--would use the word 10 "typical." It happened in both areas. 11 Q. Okay. 12 A. At random, almost. 13 Q. Do you recall when you arrived in 1965, I 14 know you said you don't--you are not, you are not 15 familiar with the actual production process. Do you 16 recall how many biphenyl units were in operation at 17 the time when you arrived? 18 A. Well, my definition of a unit is the entire 19 activity. 20 Q. Yes. 21 A. Just the one unit. 22 Q. Okay, so within--you don't have any picture 23 in your mind when you are looking at the biphenyl 24 production area,-25 A. Mm-hmm? 135 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050330 1 Q. --you don't have a picture in your mind of a 2 certain number of collections of pots that would 3 include preheaters, converters, fractionating columns, 4 and a series of close? 5 A. You asked if I have a certain number. No, 6 it's just a collection of-7 Q. Okay. 8 A. --typical manufacturing equipment for that 9 type of chemical process. 10 Q. Okay. 11 A. Several tanks, pipelines, pumps, columns to 12 conduct distillations, and so on. 13 Q. Specifically with the biphenyl production 14 area, again not talking yet about the Aroclor portion 15 of the process, are you familiar with the term 16 "preheater" being used with respect to those tanks? 17 A. I'm familiar with the expression "preheater" 18 because it's a very common function performed in many 19 ways. I do not associate it necessarily only with the 20 biphenyl unit. I-21 Q. How about the term "converter pot"? 22 A. That's another popular expression that 23 describes the piece of equipment where one chemical 24 joined with other chemicals produce the desired end 25 result or chemical. 136 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050331 1 Q. Do you associate that term with the biphenyl 2 production process at all? 3 A. Well, a little bit; not too, too much, no, 4 hmm-mm. 5 Q. But if I asked you what the conversion 6 products are in the production of biphenyl coming off 7 the converter pot, you don't recall that, I suppose? 8 A. Not the details, no. 9 Q. Do you recall that Santowax and biphenyl 10 were both conversion products? 11 A. I'm having difficulty with your using the 12 word "conversion." All chemical reactions are 13 conversions from one type of chemical to another, so 14 everything in a chemical plant is a conversion. 15 Q. Are you familiar with Santowax being one of 16 the byproducts of the biphenyl production process? 17 A. I'm familiar that it is a product produced, 18 but I don't think of it as a byproduct. It was made 19 deliberately-20 Q. Okay. 21 A. --and referred to as Santowax. 22 Q. What was the primary purpose of Santowax, 23 its use? Do you recall? 24 A. As best I recall, a plasticizer. 25 Q. Mr. Papageorge, I'm going to hand you a 137 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050332 1 document and ask that it be marked as Exhibit 9, ask 2 you to take a few minutes to look at it as soon as 3 we've marked it. 4 (Defendant's Exhibit 9 5 marked for 6 identification.) 7 (Witness peruses said 8 document.) 9 MS. LAVEY: For the record, the document 10 that we've marked as Exhibit 9 has Bates labels 11 numbers DSW 048614 through DSW 048654. The document 12 also has another Bates range sequence of MWV 018257 13 through MWV 018297, and the document is dated 14 September 17th, 1957; at least, the first pages. 15 (Witness peruses said 16 document.) 17 A. I have scanned the exhibit. 18 Q. Okay, thank you, Mr. Papageorge. Is this a 19 document that you have ever seen before today? 20 A. I don't remember seeing it, but it's typical 21 of this type of document. 22 Q. Okay. I'd like to try to identify a few 23 names on here, if I could, with you. If you would 24 return to the second page of the document, which is 25 DSW 048615, you'll see that page is a distribution 138 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050333 1 list. I know the type is hard to read. The first 2 item, here, is Director of Manufacturing, Organic 3 Chemicals Division, an H. L. and perhaps Hinckler? 4 A. Minckler. 5 Q. Minckler? 6 A. M-i-n-c-k-l-e-r. 7 Q. Do you know what the "H" stood for, first 8 name? 9 A. Howard. 10 Q. Howard? Do you recall over what period of 11 time Mr. Minckler was the Director of Manufacturing at 12 the Organic Chemicals Division, approximately? 13 A. Approximately? No, I don't remember 14 beginning dates or ending dates, so -- 15 Q. Was he a Director of Manufacturing when you 16 were at Anniston? 17 A. Yes. 18 Q. At the time you arrived in 1965 or sometime 19 later? 20 A. He was Director of Manufacturing when I 21 arrived at the Anniston Plant. 22 Q. Okay, was he still the Director of 23 Manufacturing when you left the Anniston Plant in late 24 1969? 25 A. Yes. 139 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050334 Q. Also listed under item 1 is R. S. Wobus? W-o-b-u-s, as best I can read it? Does that name sound familiar to you? A. It's familiar, but not in any real depth. The name is familiar, but I don't associate it with any specific activities or -- Q. You don't know if he was also the Director of Manufacturing in the Organic Chemicals Division? A. I do not. Q. Okay. The next one is Anniston Plant Manager, D. B. Hosmer. I know we spoke of him previously. He was the plant manager in Anniston prior to you; is that correct? A. Oh, yes. Q. Mr. Hosmer? Okay. A. Not immediately prior. Q. Okay. Who was --remind me, who was plant manager immediately prior to you? A. John McClain. Q. McClain, and Mr. Hosmer was plant manager prior to that? A. He was prior to that, but I don't know if there was another individual between the two. Q. Okay. The production superintendent is listed as a J. E. Crouch. Is that name familiar to 140 Papageorge, William; McWane (2) (Former Monsanto Employee WATER PCB-SD0000050335 1 you? 2 A. I recall being aware of that name, but I 3 don't have any recollection at all of meeting the man 4 or associating him with any activities I was involved 5 with. 6 Q. Do you know what the first name was? 7 A. I'd be guessing. No. 8 Q. Under "Biphenyl Plant Supervisor," there is 9 a name Jack Kleeghorn or Kleghorn. Is that name 10 familiar to you at all? 11 A. I've heard of the name, but I've never met 12 the person. 13 Q. Is that because he was a, a biphenyl plant 14 supervisor prior to your time as plant manager? 15 A. Yes. 16 Q. So to your knowledge, he was not there when 17 you arrived in 1965? 18 A. That's true. 19 Q. Numbers 8 and 9 on this page refer to a 20 Standards Department. What was the Standards 21 Department at the Anniston Plant? 22 A. It really represents an individual who was 23 assigned the task of keeping a--I'm going to call it a 24 library of all the procedures that were followed in 25 the plant and that were approved and became the 141 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050336 1 standard method. 2 Q. So it was not necessarily the people who 3 prepared the standards but more the, the keeper of the 4 records? 5 A. Yes, he's a custodian of the, the documents. 6 Q. On the next page, DSW 048616, there is a 7 reference in the top right-hand corner to the Safety 8 Review Committee. This page, for the record, is 9 referring to a 1964 amendment to the 1957 document. 10 Do you know what the Safety Review Committee is or 11 was? 12 A. I don't know at that point in time, 1957, 13 the members, but I'm aware of the type of activity 14 which is common, which was common in Monsanto's 15 plants, where individuals were appointed to serve on 16 the committee based on their knowledge, and 17 understanding, and experience as it might relate to 18 what was being considered, and it's also--it also 19 addresses the safety considerations, what materials 20 are used, are they explosive, are they harmful to 21 health, and so on, so that is a common activity for 22 every material handled by Monsanto at that time. 23 Q. Was there a Safety Review Committee at the 24 Anniston Plant in the period that you were there as 25 plant manager? 142 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050337 1 A. There was no standing committee. It was a 2 committee appointed for a specific review. 3 Q. Okay, so the committee could be composed of 4 different people for each different production process 5 that was under review? 6 A. That's correct. 7 Q. Okay. Would those individuals be drawn from 8 the production processes, the production 9 superintendents at that level at the plant, or are 10 these people drawn from Monsanto headquarters? 11 A. Both. 12 Q. If you turn two more pages, this would be at 13 page 3 of this amendment dated July 27th, 1964, which 14 I realize is prior to your arrival, it's DSW 048618. 15 Again, there's a list of names that are very difficult 16 to read. Some of these we have already identified and 17 talked about. You'll see, for example, plant manager 18 is listed as J. R. McClain as of 1964, which you had 19 identified as the plant manager prior to your time. 20 A. Yes. 21 Q. What was Mr. McClain's first name? 22 A. John. 23 Q. And then you will see a department 24 supervisor listed at the top. I'm not sure if you can 25 read that. 143 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050338 1 A. Yes. 2 Q. I'll let you try before I try to read it for 3 you. What name is there? 4 A. Bruce Severson. 5 Q. Bruce Severson: Okay, and what is a 6 department supervisor? 7 A. He is an individual assigned the task of 8 managing the operations related to a specific 9 department which, in turn, is involved with a specific 10 type of operation. 11 Q. In the hierarchy of the plant organization, 12 who would the department supervisor report to? 13 A. He reports to the production superintendent. 14 Q. Do you know which department Bruce Severson 15 was a supervisor in? Let me, let me take that one 16 back. Was Mr. Severson there when you arrived in 17 1965? 18 A. Yes. 19 Q. Now, do you--was he a department supervisor 20 at that time? 21 A. Yes. 22 Q. Okay, do you know what department he was 23 supervisor for? 24 A. He was responsible for the biphenyl 25 manufacturing department. 144 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050339 1 Q. Would his supervisory duties, if you know, 2 be limited to the biphenyl production area or would it 3 also include the Aroclor processes? 4 A. At this point in time, I don't know what 5 other departments he supervised. 6 Q. Do you know how long he was a department 7 supervisor? 8 A. I do not. 9 Q. Was he still a department supervisor when 10 you left in 1969? 11 A. I don't remember specifically. I believe by 12 then, he had another assignment, but I'm guessing 13 quite a bit, here. It was different than when I 14 arrived, is all I know. 15 Q. Do you know if Mr. Severson is still living? 16 A. I do not. No, I take that back. I think 17 he's deceased. He's deceased. 18 Q. Do you have any idea approximately how many 19 individuals would have worked for Mr. Severson as the 20 supervisor of the biphenyl department? 21 A. I do not. 22 Q. Later down that page, there's an 23 identification of an individual for Research Group 24 Leader. 25 A. I see that. 145 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050340 1 Q. Are you familiar with that name? 2 A. I recall the name. I do not recall the 3 person. 4 Q. Okay, I'm reading it as R. W. Bucknell. 5 A. Bucknell, yes. 6 Q. -nell with an "e"? 7 A. -n-e-1-1. 8 Q. Do you recall his first name? 9 A. No, I'd be guessing. 10 Q. Was he at the Anniston Plant when you 11 arrived in 1965? 12 A. No, he would be at Monsanto's Research 13 Center in St. Louis. 14 Q. The next name, the individual identified as 15 a research manager, an H. L. Hubbard, are you familiar 16 with that individual? 17 A. Harold Hubbard. 18 Q. Was he also in St. Louis? 19 A. Yes. He is Mr. Bucknell's supervisor. 20 Q. To your knowledge, did either Mr. Bucknell 21 or Mr. Hubbard work at the Anniston Plant? 22 A. I'm sorry? 23 Q. To your knowledge, did Mr. Hubbard or 24 Mr. Bucknell ever work at the Anniston Plant? 25 A. Not that I recall, no. 146 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050341 Q. The last name on here is identified as --I'm not sure I can read this, either--a something production manager, perhaps a technical production manager. The name is listed as J. A. Mullendor? A. Mullendor, John Mullendor. Q. Was Mr. Mullendor at the Anniston plant? A. He was at the Anniston Plant, yes. Q. So the reference to a technical production manager, that's a position in Anniston, rather than in St. Louis? A. It's my recollection he was part of the Technical Services Department. Q. Reporting to Mr. Fuhrmeister? A. Right, maybe not directly but in Mr. Fuhrmeister's group Q. As best you recall, was he part of the Technical Services Department when you arrived in 1965? A. Yes. Q. And was he still there when you left in 1969? A. No . Q. Do you know if Mr. Mullendor is still living? A. I do not. 147 Papageorge, William; McWane (2) (Former Monsanto Employee WATER PCB-SD0000050342 1 Q. I skipped a name I wanted to do on the 2 previous page. This is on DSW 048617. It's got a 3 page 2 up on the top, you'll see down at the bottom a 4 signature block says, "Originated by a J. H. Haupt? 5 Haupt? 6 A. Haupt, Vince Haupt. 7 Q. Vince Haupt. What was Mr. Haupt's position, 8 if you recall, in 1965, when you arrived at the plant? 9 A. He was a member of the Technical Services 10 Department, reporting to Mr. Fuhrmeister, assigned 11 this particular activity that's reported here that he 12 signed off on. 13 Q. Was it, was it--was that a typical job 14 responsibility of the Technical Services Department, 15 to compile the standard manufacturing processes and 16 their amendments? 17 A. I'm hesitating because I don't know what you 18 mean by "compile." It's not just a collection of 19 papers, it's a-20 Q. Develop or prepare; how about I use those 21 words instead? 22 A. An individual who studies the process, 23 understands what's going on and is requested to come 24 up with a different approach, and he then develops a 25 procedure that he signed off on just like Mr. Haupt 148 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050343 1 did on this one. 2 Q. Was Mr. Haupt still in the Technical 3 Services Department when you left in late 1969? 4 A. As best I remember, yes. 5 Q. Do you know if Mr. Haupt is still living? 6 A. I do not. 7 Q. Do you know how long he remained at the 8 Anniston Plant after you left? 9 A. I do not. 10 Q. I'd like to direct your attention, 11 Mr. Papageorge, to a particular page, and I'll ask 12 whether that flow drawing refreshes your recollection 13 at all of the biphenyl process. It is on DSW 048627. 14 I'm not quite halfway through the document. These are 15 not numbered. I'm afraid I can't --I think that's it 16 right there that you have on your--I think it's that 17 page. 18 A. 627? 19 Q. Yes. 20 A. I have it. 21 Q. Yes, sir. I know you reviewed the entire 22 document to see if it looked familiar to you, but I'd 23 like you to review this particular flow sheet for a 24 few minutes and then I'll ask you if, if that 25 refreshes your recollection at all as to the biphenyl 149 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050344 1 production process. 2 A. It shows features that I would expect in a 3 process of this type. I am personally very puzzled by 4 the reference to lead as shown in the rectangle area, 5 "lead trap." 6 Q. You have not heard of a lead trap before as 7 part of the biphenyl production process? 8 A. I never associated lead with anything at the 9 plant, so I have difficulty with that. 10 Q. We probably did this yesterday: What month 11 did you arrive at the Anniston Plant in 1965? 12 A. I don't remember the specific month. I 13 associate it with entering my children in school for 14 the Spring term. We had to rush to get them 15 registered, so it was early in the year is the best I 16 can come up-17 Q. But sometime in the first half of 1965? 18 A. Yes. 19 Q. Rather than the last half? 20 A. Yes. 21 Q. Okay. Are you familiar at all with the term 22 "lead dross," d-r-o-s-s? 23 A. No. Well, I've heard of the term but not 24 with, connected with my duties. 25 Q. In what context have you heard of the term? 150 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050345 1 A. I don't remember the specific occasion when 2 I heard of it; I just don't remember. In my mind, I 3 associate it with iron slag and-- 4 Q. Okay. 5 A. --a general term that would come up when 6 we'd discuss in general the kinds of processes that 7 exist in the world. 8 Q. If you could turn to the third-from-the-last 9 page, which is marked as DSW 048652 and it appears to 10 be some kind of form at the top of which says, 11 "Monsanto Chemical Company Production Cost Standards." 12 A. I see that, mm-hmm. 13 Q. I'm not asking particularly with this actual 14 document, but if you wiped out all the typed-up--with 15 the typewriting and looked at the form, have you seen 16 this type of form before? 17 A. Yes. 18 Q. Was that in use at the time you were at the 19 Anniston Plant? 20 A. Yes. 21 Q. Who would be responsible for producing--for 22 filling out this type of form? 23 A. The responsibility is--was centered on the 24 production superintendent involved with this 25 particular process. He, in turn, would assign 151 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050346 1 individuals with the proper information and knowledge 2 to contribute to this form the necessary information. 3 Like, for example, it shows amount of material, and 4 that would involve the production supervisor, or the 5 cost of the material, that would involve the 6 purchasing agent, so there would be different people 7 involved as a small group to come up with this 8 summary. 9 Q. What would happen to the form after it was 10 filled out? Would it go to a, a particular office 11 once it's filled in? 12 A. Oh, it'll be available to anybody that's 13 interested in this for various purposes, and it would 14 be part of that standards -- 15 Q. The, sort of the document repository-- 16 A. Yes,-- 17 Q. --of the Standards Department? 18 A. --it would be available in the, let's call 19 it the, the library that has this kind of information 20 available to those who have a need for it. 21 Q. And with that repos--would that library, so 22 to speak, retain these records for a period of time, 23 or would they be sent to Monsanto headquarters? 24 A. There was a, a record retention program. I 25 don't recall the specifics that applied to this type 152 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050347 1 of document, but it does refer to the types of 2 document, and time to keep it, and time to send it 3 forward, and so on,-- 4 Q. Okay. 5 A. --so there is a procedure. 6 Q. Was there--there was a written record 7 retention policy when you were in Anniston? 8 A. Yes. 9 Q. Was that a, was that a policy developed at 10 the Anniston Plant, or was that something that 11 Monsanto developed and passed around to all of its 12 individual plants? 13 A. It's a Monsanto Company program. 14 Q. Do you recall if that program changed in any 15 way when you were in Anniston? 16 A. I don't remember any specific changes, but I 17 do know changes do occur, have occurred. 18 Q. Okay. While you were the plant manager, 19 who, who is responsible for acquiring raw materials 20 needed for production processes at the plant? 21 A. I don't remember the name of the individual, 22 but there was a superintendent of warehousing,-23 Q. Okay. 24 A. --and he kept records on the inventory. He 25 had been given by the manufacturing management 153 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050348 1 suggestions on when to reorder, when his inventory 2 reached a certain level, he would inform the 3 purchasing agent to reorder material XYZ. 4 Q. When you say he would inform the purchasing 5 agent, you mean the superintendent of warehousing-- 6 A. Warehousing. 7 Q. --would inform-- 8 A. Or his helpers. 9 Q. --somebody within that department? 10 A. Yes. 11 Q. And I know, we talked about that department 12 yesterday, and you didn't recall the name of the 13 superintendent yesterday. 14 A. I still can't. 15 Q. You still don't today? 16 A. That's true. 17 Q. Okay, is the purchasing agent, then, 18 somebody who worked in a different department? Is 19 there a purchasing department? 20 A. Yes. I didn't mention that yesterday. 21 Mr. Phillips was the --I've forgotten his first name. 22 Phillips was the purchasing agent for the plant. 23 Q. So he was--he has the responsibility, then, 24 for purchasing all raw materials for all processes at 25 the Anniston Plant? 154 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050349 1 A. Yes. 2 Q. Did he have individuals who worked for him, 3 or is he a one-man show? 4 A. No, he had at least two people working for 5 him. 6 Q. And he was the purchasing agent when you 7 arrived in 1965? 8 A. Yes. 9 Q. Do you know how long he had been there? 10 A. No, I don't. 11 Q. Was he still there when you left in 1969? 12 A. Yes. 13 Q. I know you said you didn't recall his first 14 name. Do you know if Phillips is one "1" or two 15 "l's"? 16 A. Two "1' s . " 17 Q. And do you know if Mr. Phillips is still 18 living? 19 A. I do not. 20 Q. Do you have any idea how long he continued 21 to work at the Anniston Plant after you left? 22 A. I do not. 23 Q. Okay, did you have no further dealings with 24 Mr. Phillips once you were no longer plant manager? 25 A. That is correct. 155 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050350 1 Q. Okay. In the context of purchasing the raw 2 materials, you indicated that somebody at the 3 production area for the particular unit would let the 4 warehousing superintendent's office know that they 5 needed more of XYZ material and that then the 6 warehousing superintendent would contact the 7 purchasing agent and say go buy it. I think--is that 8 more or less accurate? If it's not, correct me. 9 I'm-- 10 A. Well, keep in mind that the warehousing 11 superintendent is not aware of any particular 12 ingredient that might be required in the plant until 13 he is told by the people who need it-14 Q. Mm-hmm? 15 A. --to make another product. When that need 16 is defined, it is passed on, then, to the purchasing 17 person for the first purchase, "I need ingredient 18 XYZ, " and once that gets to the warehouse, the 19 individual in charge of warehousing is told when that 20 material reaches this low level, please arrange to 21 contact the purchasing man to reorder. Also, when the 22 particular process is expanded where you made X pounds 23 for the past ten years, you are now going to go to Y 24 pounds, that change in need is relayed to both the 25 warehousing people who receive it, and store it, and 156 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050351 1 the purchasing people who order it. 2 Q. Okay. Do those requests come through you as 3 plant manager, or are you not in that, that loop of 4 requesting of the raw materials? 5 A. No, I'm not in that loop. The people 6 involved I hold responsible to do that. That's what 7 they're there for. 8 Q. So are there--if there are requisition forms 9 to be signed, that would be done at the production 10 level, not at your level as plant manager? 11 A. True. 12 Q. Okay. Does--are you familiar with the term 13 "carbon trap" in connection with the biphenyl process? 14 A. First I've heard of it. 15 Q. Okay. Are you aware of occasions when the 16 pipes or equipment in the biphenyl production area 17 would need to be periodically cleaned out? 18 A. I'm very aware of that type of situation 19 occurred in every chemical plant. The cause and the 20 material that causes blockages varies, but it's not an 21 uncommon activity, and that's the extent of it. The 22 people that are running the unit discover this defect 23 or this impediment to their production, and they take 24 the necessary actions to open up the pipeline or 25 whatever is involved. 157 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050352 1 Q. If there is a need for cleaning out of 2 pipes, and so forth, would that be handled, then, by 3 the production unit, or through the Maintenance 4 Department, or someone else? 5 A. It depends, again, on the type of blockage, 6 the material that's in there, and whether the unit is 7 designed in such a way that you can introduce 8 something to unblock, like high-pressure air or flush 9 it out water, or if they can't get to it with the 10 system as it's designed, they call the maintenance 11 people who will come in and disconnect the pipeline 12 and take it out somewhere where they can drill through 13 the obstacle or whatever is their problem, so it, it 14 will vary. 15 Q. Do you have any specific recollection of 16 that type of activity in connection with the biphenyl 17 operations ? 18 A. Not a specific regulation. It was almost a 19 routine part of running the process. 20 Q. Are you familiar with the buildup of carbon 21 deposits within the piping at the biphenyl production 22 unit? 23 A. I'm not familiar with the reference to 24 carbon. I do recall there were blockages. 25 Q. Do you recall what was done to clear those 158 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050353 1 blockages, whatever they were? 2 A. Not in detail, no. 3 Q. Do you recall the Flexi? 4 A. No. 5 Q. I believe you indicated yesterday the 6 biphenyl production process would operate 24 hours a 7 day, seven days a week; is that correct? 8 A. Yes. 9 Q. Were there occasions when during the time 10 that you were plant manager, that the biphenyl 11 production process was halted for some reason? 12 A. Oh, there were periods when production would 13 be halted, but I don't recall any, any incident that I 14 would call dramatic or very unusual. 15 Q. What type of events would cause the biphenyl 16 production process to, to need to halt? 17 A. Well, these blockages we talked about, 18 depending on the severity, instead of accomplishing 19 the, the cleanup in a day's time, it may take a week. 20 It'll vary with the type of problem. A failure of any 21 piece of equipment, especially a key piece that took 22 awhile to repair, might create a, a longer period of 23 time of non-production. I don't know how else to 24 describe that. It will vary. There are things that 25 happen that are unexpected, and there are incidences 159 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050354 that happen as part of the, the process Q. Do you recall any fires or explosions occurring at the biphenyl plant while you were plant manager? A. No . Q. Were there any strikes by the union during the time that you were plant manager? A. Yes. Q. When was that? A. I don't remember the exact period, but I'm going to say that it occurred about 1966-67 Q. Do you remember what the reason was for the strike? A. The only reason I know that what I had offered the union committee was not to their liking and they decided to impress me with a strike, and much of that, I think, was really a personal kind of thing, too. I don't know how to-- Q. What do you mean by that? A. The desegregation of the work force was the emotional issue, and I was perceived as the Yankee with the odd last name who came down to mix the black and the white workers, and that was an emotional issue that many in the plant could not accept, and this was part of the emotions that existed, and they decided to 160 Papageorge, William; McWane (2) (Former Monsanto Employee WATER PCB-SD0000050355 turn down my offer. Q. Were both black and white workers in the same union? A. Yes. Q. And the entire work force struck? A. It included--other than the supervisors and the foremen, the maintenance and production individuals, as well as custodians and whatever, were part of the union. Another group that was excluded was the guards. We had uniformed guards in the parking lots. They did not belong to the union. Q. How long did the strike last? A. I don't remember the exact time. A couple of weeks. It was more than a few days. Q. Did production continue throughout the, the strike? A. Yes. Q. Did you bring in other workers, or did the supervisors continue the production? A. The supervisors continued the production, shipping, all of the activities. Q. Did you, yourself, then run any of the production areas during that period of time? A. I didn't run that, but I chuckle because when I was not negotiating with the representatives of 161 Papageorge, William; McWane (2) (Former Monsanto Employee WATER PCB-SD0000050356 1 the union, I had some free time, so in addition to 2 going out and seeing how things were going and who 3 needed help, I ended up cleaning up restrooms. 4 Q. I could see why you chuckled. 5 (Witness laughs.) 6 Q. (Continuing) Do you remember the names of 7 the individuals who were part of the negotiating 8 committee that, that rejected your offer and led to 9 the strike? 10 A. I don't remember names, no, I don't. 11 Q. I should have asked you this yesterday, but 12 you didn't have an assistant plant manager, did you? 13 A. No. 14 Q. Okay. Did you have administrative staff 15 working for you, like a secretary when you were plant 16 manager? 17 A. I had a secretary, yes. 18 Q. Okay, who was your secretary? 19 A. I should remember her name. 20 Q. Does the name B. Henderson sound familiar? 21 B. Henderson? 22 A. No, she was a secretary in the office group, 23 but not to me. B.--no, I just cannot remember. 24 Q. Do you know who she was a secretary for? 25 B. Henderson? 162 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050357 1 A. B. Henderson. I'd be guessing. 2 Q. Okay. Did you have the same secretary 3 throughout the time you were plant manager? 4 A. Yes. 5 Q. Did she continue as the secretary after you 6 left for Mr. Jesse? 7 A. Yes. 8 Q. Had she been there prior to your arrival in 9 1965? 10 A. Yes. 11 Q. I know you don't recall her name, but do you 12 happen to know whether she is still living? 13 A. I do not. 14 Q. I'm going to hand another exhibit to you, 15 another document, Mr. Papageorge, and recognizing that 16 the cover sheet shows a date of 1948, I'm still going 17 to ask whether it's a document that you've seen before 18 in the--in connection with your duties as plant 19 manager of the Anniston Plant. We could mark this as 20 Exhibit 10. 21 (Defendant's Exhibit 10 22 marked for 23 identification.) 24 MS. LAVEY: For the record, Exhibit 10 has 25 Bates range numbers DSW 462477 through DSW 462620. 163 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050358 1 (Witness peruses said 2 document.) 3 BY MS. LAVEY: 4 Q. And certainly, I'm not suggesting that you 5 necessarily need to look through a hundred-plus pages, 6 but enough to feel comfortable to tell me whether or 7 not it's a document that you had occasion to see as 8 plant manager. 9 A. I see nothing in this document that helps me 10 recall ever seeing it. 11 Q. Okay. You can set that aside. 12 Although you are not familiar with the lead 13 pot process, are you familiar with the--a term 14 "tubular biphenyl reactor"? 15 A. I'm not. 16 Q. And we may move through these very quickly 17 if you've not seen any of them, but we'll go through 18 this process anyway. I'm going to hand you another 19 document we'll mark it as Exhibit 11. For the record, 20 the document is entitled "Process for the Manufacture 21 of Diphenyl & Santowax Compiled by E. Mather, November 22 1950, Bates range DSW 462055 through 462197. 23 (Defendant's Exhibit 11 24 marked for 25 identification.) 164 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050359 1 Q. (Continuing) Again, I'll ask you to take a 2 few moments to look at it and if you can, determine 3 whether or not it's a document you have seen before. 4 (Witness peruses said 5 document.) 6 A. I have scanned quickly the document, and I 7 cannot say I saw this exact document, because it 8 resembles so many in format involving not only the 9 Aroclor process but all processes at the plant. To 10 me, it's very typical of the kind of document that we 11 held at the plant that referred to each chemical 12 process at the plant. 13 Q. Do you know who E. Mather is or was? 14 A. I'm sorry, who? 15 Q. E. Mather. It's the individual's name on 16 the-17 MS. LAVEY: Oh, you've handed out a 18 different one. I'm sorry. Which one are we on? 19 MR. NASSIF: For the record, we're on 20 "Standard Manufacturing Process for Aroclor," issued 21 October 22nd, 1957. 22 MS. LAVEY: Let's go off the record for a 23 second. 24 MR. NASSIF: Reissued September 1966. 25 THE VIDEOGRAPHER: This will end tape number 165 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050360 1 1 of the deposition of William B. Papageorge. We are 2 off the record at 10:22 A.M. 3 (Recess.) 4 (Defendant's Exhibit 11 5 re-marked for 6 identification.) 7 (Mr. Michael Wetmore attends 8 the deposition.) 9 THE VIDEOGRAPHER: We're back on the record 10 at 10:12 A.M. This begins tape number 2 in the 11 deposition of William B. Papageorge. 12 BY MS. LAVEY: 13 Q. For the record, I want to clarify the 14 Exhibit 11, which is "Process for the Manufacture of 15 Diphenyl and Santowax, Compiled by E. Mather," dated 16 November 1950, Bates range DSW 462055 through DSW 17 462197. The witness was previously handed the wrong 18 document, so the questions and his answers, after we 19 last started talking about Exhibit 11, effectively 20 should be stricken. They were not on the right 21 document, so we'll start over on Exhibit 11. 22 MS. LAVEY: Mr. Papageorge, I'll again just 23 ask you to take a brief moment, here, to look at this 24 document, and when you've completed that brief review, 25 let me know whether it's a document that you had 166 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050361 1 occasion to receive or review as plant manager at the 2 Anniston Plant. 3 (Witness peruses said document.) 4 MR. NASSIF: Do you recall the question, 5 Bill? 6 THE WITNESS: No, I don't. 7 BY MS. LAVEY: 8 Q. The question pending was whether or not, 9 after you've taken a look at this document, whether it 10 is a document that you have seen before today. 11 A. I do not recall ever seeing this document. 12 Q. Is this the type of document also that would 13 have been, while it was in use, kept at the library, 14 so to speak, at Anniston? 15 A. I have difficulty answering that because of 16 the age-17 Q. Okay. 18 A. --the transfer could have occurred, but I 19 don't know that it did or not. 20 Q. Did the, what you refer to as the library in 21 Anniston, did it only retain copies of the standard 22 manufacturing processes and similar-type documents 23 that were in active use at the time, or was it also an 24 archive source? 25 A. It was also a matter of retaining some of 167 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050362 1 the older documents that at least a group of 2 individuals at the plant decided might prove valuable, 3 therefore keep them handy in the plant. Once the 4 group agreed that that is so antiquated, we can't 5 conceive ever needing it locally, send it to the 6 archives. 7 Q. Where was that archives located? 8 A. In the St. Louis area. 9 Q. Was there an individual responsible for the 10 library in Anniston when you were there as plant 11 manager? 12 A. There was an individual, but I at the moment 13 can't recall the specific person, but it came under 14 the Technical Services Department supervision. 15 Q. Do you recall the name E. Mather that's on 16 page 1 of this document? 17 A. I do not. 18 Q. Do you know the name A. M. Ellenberg? 19 A. I do not. 20 Q. How about C. B. Durgin? 21 A. I do not. 22 Q. Do you recall there being an issue at all 23 with biphenyl production of metals impurities in the 24 product? 25 A. No, never. Hmm-mm. 168 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050363 Q. Are you familiar with the term "entrainment" within the gas stream at the biphenyl production process? Does the term "entrainment" mean anything to you? A. I have an understanding of the meaning of the word "entrainment," but I do not associate that with any specific chemical process. It can happen whenever you have gas and liquid. Q. What is your understanding of entrainment? A. It's the presence of a gas in a liquid stream. Q. Do you know if water was used in connection with the biphenyl production process? A. I don't remember that, no. Q. Do you know if there was cooling water, water used in connection with the condensers? A. Well, cooling waters are associated with--I do not specifically recall it as it ties into the biphenyl process. Q. You can set that document aside. I'm going to hand you another document which we will now label as Exhibit 12, entitled "Standard Manufacturing Process for Aroclor Blends," issued August 1968. Bates range is DSW 053329 through DSW 053441. I'll ask you, Mr. Papageorge, to take a moment to look at it. My 169 Papageorge, William; McWane (2) (Former Monsanto Employee WATER PCB-SD0000050364 1 first question will be whether it's a document that 2 you have seen before once you've had a chance to 3 review it. 4 (Defendant's Exhibit 12 5 marked for 6 identification.) 7 (Witness peruses said 8 document.) 9 BY MS. LAVEY: 10 Q. (Continuing) Is that a document you've seen 11 before, Mr. Papageorge? 12 A. I do not recall seeing this specific 13 document with its detailed information, but it is very 14 similar to many other documents of a similar type 15 involving the processes at the plant, but this, the 16 details in this type of document are something I just 17 cannot remember. 18 Q. As the plant manager, would you typically 19 have received a standard manufacturing process 20 document that was developed when you were plant 21 manager? 22 A. I would receive the finished document, but 23 while it was being prepared, I would receive a 24 proposed document and then later, the appendices, and 25 additions, and amendments, so I was, in a way, tuned 170 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050365 1 into the process before the final version was issued. 2 Q. Okay, would you comment on its development 3 or were you just receiving copies? 4 A. Oh, I would comment if, if I read something 5 that I didn't understand or didn't approve of. 6 Q. Do you have any recollection specific, then, 7 to this standard manufacturing process for Aroclor 8 blends ? 9 A. I don't recall any. 10 Q. This indicates on the first page that it was 11 prepared by M. J. Williams as a p-r-o-d, I assume it's 12 production foreman. Do you recognize that name? 13 A. I remember Mr. Williams as the foreman, but 14 I just, I cannot remember his first name. 15 Q. What was he the foreman of? 16 A. The, at least the part of the Aroclor 17 process that would involve mixing it with other 18 ingredients to produce different products based on 19 what the customers are requesting. 20 Q. Do you know if Mr. Williams was at the 21 Anniston Plant when you arrived in 1965? 22 A. Yes. 23 Q. Was he still there when you left at the end 24 of 1969? 25 A. I don't remember that. 171 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050366 1 Q. Also on this first page, there's an 2 indication that it's reviewed by someone named 3 R. A. Haydel? 4 A. Haydel, mm-hmm. 5 Q. Do you recall that individual? 6 A. I recall the name, but I--and that's about 7 it. 8 Q. Based on your understanding of how standard 9 manufacturing processes were put together and 10 reviewed, the fact that Mr. Haydel is identified here 11 as someone who reviewed it, does that indicate to you 12 where he was a production supervisor? Can 13 you--knowing how these are put together, can you 14 identify what he would be a supervisor of? 15 A. Yes. He, he was, as I think I said earlier, 16 involved with part of the Aroclor process that 17 required mixing, blending with other ingredients 18 according to customers' needs, so that would be in a 19 way a branch of the Aroclor department. 20 Q. That's--I think that you had indicated that 21 with respect to Mr. Williams. Is there, is there a 22 difference between the production foreman and the 23 production supervisor? 24 A. Well, the foreman reports to the supervisor, 25 so you notice the foreman prepared it, and his boss, 172 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050367 1 the supervisor, looked it over-- 2 Q. Okay. 3 A. --and reviewed it. 4 Q. And the next name, there, is another 5 Mr. Williams? 6 A. Yes. 7 Q. An H. L. Williams. 8 A. Hilliard. 9 Q. Hilliard? 10 A. Hilliard Williams. 11 Q. And he was the production superintendent of 12 what, at least as of this point in time? 13 A. Of, I'm going to call it all of the 14 chemicals other than the parathion, malathion 15 activities. He is the person that took over the 16 position that Robert Moody had. 17 Q. Okay. Was he still in that position when 18 you left at the end of 1969? 19 A. I don't remember. 20 Q. Do you know what his prior position was 21 before he became production superintendent? 22 A. I don't remember. 23 Q. On the second page, you'll see a 24 distribution list, DSW 053330, the fourth person down 25 is just a title identified as "Plant Manager." At the 173 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050368 1 point in time, August 1968, that would be you; 2 correct? 3 A. Correct. 4 Q. If you go in a few pages, it's the fifth 5 page in, DSW 053333, which appears to be a tentative 6 Amendment C, dated July 28, 1970, by that time, 7 Mr. Papageorge, you were no longer at the Anniston 8 Plant; correct? 9 A. That is correct. 10 Q. This page states as an objective, quote, 11 "Make Aroclor blends to replace the plasticizer grade 12 liquid Aroclors which will be discontinued 31st of 13 August 1970." Do you know why plasticizer grade 14 liquid Aroclors were going to be discontinued as of 15 that date? 16 A. I don't have that reference. I'm confused. 17 What page is that? 18 Q. The bottom is listed as DSW 053333,-19 A. Oh. 20 Q. --there's a heading that says, "Objective." 21 A. Oh. What was your question, again? 22 Q. Do you know why the plasticizer grade liquid 23 Aroclors were intended to be discontinued as of that 24 date in 1970? 25 A. Aroclors were sold as plasticizers, and 174 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050369 1 generally, the use of those plasticizers were such 2 that control from escape into the environment was 3 virtually impossible. For example, they would appear 4 as an ingredient in the traffic lane paint on the 5 highways, so management decided in early--I'm 6 sorry--yeah, early 1970 to discontinue that sales 7 activity, and when that decision was instituted, there 8 was no need for some of those so-called 9 plasticizer-grade liquid Aroclors. 10 Q. Are there a particular numeric Aroclor 11 sequence assigned for plasticizer grade liquid 12 Aroclors ? 13 A. Not a particular one. Some are more popular 14 than others because of their color, or consistency, 15 other characteristics. 16 Q. These would be 1200, Aroclor 1200s? 17 A. Some are 1200s, some 4000s, some 5000s. 18 Q. The same page indicates an approval of a 19 Safety Review Committee. I know we spoke earlier 20 about what that Safety Review Committee might be. At 21 least in this context, it is--there are three 22 individuals on there we've already talked about: 23 Mr. Landwehr, the other two individuals are 24 P. K. Ward-25 A. Paul Ward. 175 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050370 Q. Paul Ward? A. Mm-hmm. Q. What was his position, if you recall? A. He was a member of the plant safety committee or group. Q. Was that a standing committee, or was that a committee that was in place throughout-A. It's more of an assignment. He is hired as a safety engineer to help the plant with safety matters. Q. And there's one individual who would have that position? A. As I remember, he reported to Mr. Schulte there. Q. What was Mr. Schulte's position? A. He was the head safety engineer, and Mr. Ward reported to him. Q. Okay, was there anybody else working within that safety group? A. Not that I remember. Q. Okay, were Mr. Ward and Mr. Schulte there in 1965 when you arrived? A. As best I remember, yes. Q. Did you tell me that Mr. Schulte's first name was? I'm sorry if you did. Do you remember what 176 Papageorge, William; McWane (2) (Former Monsanto Employee WATER PCB-SD0000050371 1 the "H" stood for? 2 A. Harvey. 3 Q. Harvey? Do you know if either Mr. Ward or 4 Mr. Schulte are living today? 5 A. I do not. 6 Q. Do you know who J. L. Corder is? 7 A. Corder, I don't recall him. 8 Q. How about G. W. Miller? 9 A. Gerald Miller was a member of the Technical 10 Services Department at the plant. I think he was 11 involved, as I remember, he was involved with the 12 chemical analytical testing programs. 13 Q. Do you recall if he was there in 1965 when 14 you arrived? 15 A. I think Mr. Miller arrived after I arrived. 16 Q. Do you know if Mr. Miller is still alive? 17 A. I do not. 18 Q. Were the individuals responsible for the 19 production of various Aroclor blends, would they all 20 be part of the Aroclor department or was that a 21 standalone department? 22 A. No, it would be the Aroclor department. 23 Q. Are you familiar with the term "Attapulgus 24 earth"? 25 A. Yes. 177 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050372 Q. What do you understand that to be? A. It's a type of naturally-occurring clay. Q. Do you recall how Attapulgus earth was utilized in the production process for the Aroclor blends ? A. I do not. Q. Do you recall where the Attapulgus earth was obtained? Who the supplier was? A. I do not. Q. I'm going to ask you to turn to page DSW 053346, so that's not quite twenty pages in, and there'11 be a Roman numeral III at the top titled "Process in Detail." That's the right page. A. Do I have the-- Q. That's the right page, yes. A. 346? Q. Yes. Yes, sir. In section 3.A, it refers to Pyranol mixes. Is Pyranol, is that a term that could be used for Aroclor blends generally? A. Pyranol is a General Electric trademark. The different Pyranols required by General Electric were blended at the Anniston Plant, in tank cars, before shipment. Q. Okay, and I believe you indicated the Inerteen was a Westinghouse-- 178 Papageorge, William; McWane (2) (Former Monsanto Employee WATER PCB-SD0000050373 1 A. Yes. 2 Q. --trademark; is that correct? 3 A. That is true. 4 Q. And Therminol was Monsanto's trademark; 5 correct? 6 A. Correct. 7 Q. How about Santicizer? Does that name mean 8 anything to you? 9 A. Santicizer? Yeah, that's a plasticizer. 10 It's a Monsanto trademark. 11 Q. Was that--that's an Aroclor blend, do you 12 recall? 13 A. I don't recall. 14 Q. On the page that we were looking at before, 15 page 053346, I'd like you--I'd ask you to read that 16 first paragraph to yourself and I'll then ask if that 17 helps you recall what the purpose was of the 18 Attapulgus earth. 19 (Witness peruses said 20 document.) 21 A. I've read it. 22 Q. Does that help you recall at all what the 23 earth was used for, what its purpose was? 24 A. Well, I was aware that Attapulgus earth is 25 used to filter many, many chemicals, and when you 179 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050374 1 asked the question, I thought you meant what material 2 were we removing by using Attapul--I don't know the 3 material they were removing by filtering through this 4 clay. 5 Q. Do you know whether what they were filtering 6 was generally classified as metals, or you have no 7 recollection at all of what was being filtered out? 8 A. I don't--I don't believe I ever knew. 9 Q. On this same section 3.A, what's the third 10 paragraph states "The quality of each mix is analyzed 11 by the laboratory and when approved, it is loaded into 12 tank cars or drawn out into drums." Do you know what 13 would happen if the mix was not approved by the lab? 14 A. Well, it depends on what defect in the 15 analysis was discovered, and the changes made to that 16 blend vary with that defect. It may require a little 17 more Aroclor number so and so, or it may require more 18 of the other fluid that's added, or it may require 19 such things as a color additive, so depending on the 20 defect that didn't meet the specification, they would 21 take appropriate action, and the defects were not so 22 great that they had to pump that material all the way 23 back and redistill and start all over again. It 24 wasn't that kind of a big difference. 25 Q. Okay. Do you recall the manner in which the 180 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050375 1 mixed material was loaded into tank cars, how it was 2 loaded into tank cars? 3 A. It's just a pipeline that dips into the tank 4 car opening. 5 Q. Okay. Was it--well, was the tank car placed 6 over by the Aroclor facility or did the material have 7 to be piped to another section of the plant? 8 A. It's--it had to be piped, but the distances 9 weren't great. 10 Q. Okay. 11 A. But it was piped over to where most of the 12 warehousing/shipping activities took place,-- 13 Q. Okay. 14 A. --away from the manufacturing site. 15 Q. Where the tank car loading occurred, do you 16 remember whether that was on a concrete pad or any 17 other type of, of flooring, or is it directly under a 18 railroad track? 19 A. Of course, the railroad track was there, and 20 as I recall, there was some concrete pavement on each 21 side of a--about the width of this table. 22 Q. Okay, and was there a roof over that loading 23 area? 24 A. I don't remember. 25 Q. The sentence that I had read earlier also 181 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050376 1 referred to in addition to loading into tank cars, 2 drawn out into drums. Was the drum loading done at 3 the Aroclor facility or elsewhere in the plant? 4 A. It was done at the, what I'm going to call 5 the warehousing center. 6 Q. Okay, and was this--so the material was 7 pumped from the Aroclor facility over to the 8 warehousing area? 9 A. Into a tank, mm-hmm. 10 Q. What's the distance, approximately, between 11 the Aroclor facility and the warehousing area? 12 A. I'm guessing a city block or so. 13 Q. If you could turn the page, I just need a 14 real quick chemistry lesson, here, to make sure I know 15 what the initials all stand for. This is a table on 16 page DSW 053347. Do you see across the top different 17 percentages indicated for different materials which 18 are used to produce the blend products that are down 19 the left-hand side, down the Y axis. Across the X 20 axis, toward the end, there, there's a percent PPO. 21 Do you recall what that is? I think it's phenoxy 22 propene oxy oxide (sic) or something like that, but 23 I'll--I'm really looking to you to make sure I have 24 this right. 25 A. My memory fails me there, too. I don't 182 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050377 1 remember 2 Q. Okay. TCB, the next one over, is that 3 trichlorobenzene? 4 A. I'm sorry, where is that, now? 5 Q. After the PPO. I'm reading across the top. 6 A. Oh, you are reading cross the top. 7 Q. Right. I can do all the Aroclor percents, 8 and then there's toluene, xylene, and then we have a 9 percent PPO, which you weren't sure of. The next one 10 was a percent TCB? 11 A. Trichlorobenzene. 12 Q. Okay, and the next one was TTCB. Is that 13 tritetrachlorobenzene? 14 A. Yes. 15 Q. Are those products you were making at the 16 plant in Anniston, or are those products that were 17 purchased? 18 A. As I remember, they were sent to the plant, 19 s ome o f them, from the Monsanto units. 20 Q. You mean elsewhere? 21 A. Yes. 22 Q. Not from Anniston but other Monsanto areas? 23 A. Right. 24 Q. Okay. The last one across this top, here, 25 well, we skipped over percent earth, but we've talked 183 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050378 1 about that one already. The last one is a percent EP 2 221. Do you know what that's a reference to? 3 A. No, I don't. 4 Q. Do you know if the Attapulgus earth which I 5 believe you described as a claylike material, was 6 that--for how long was that used as a filter in the 7 process? 8 A. I don't know. 9 Q. Was it in use when you arrived in 1965? 10 A. Yes. 11 Q. And was it still in use when you left in 12 1969? 13 A. Yes. 14 Q. I'd like you to turn to--this is getting 15 toward the back, now, it'll be DSW 053425, and when 16 you find that, the top will say "Appendix H, 17 Atmospheric & Stream Discharge & Waste Disposal." Are 18 you on that page, Mr. Papageorge? 19 A. Yes. 20 Q. Do you know if any analysis was done in 21 order to give, provide this information? 22 A. I do not. 23 Q. If you go three more pages to DSW 053428, 24 the top of which references Appendix J, "Safety and 25 Toxicity Data and Ask Accident Reports," under Item 2 184 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050379 1 , "Thermal Burns," and I'd like to direct your 2 attention down to Subparagraph F as in "Frank," which 3 is the last one on this page? 4 A. I see it. 5 Q. Okay. The first one says--well, the lead-in 6 is "The following operations are hazardous and should 7 be done with care." The first one listed is "Catching 8 samples at the Aroclor chlorinator circulating lines." 9 Do you know what would make that activity hazardous? 10 A. High temperatures. These are thermal burn 11 potential. 12 Q. What is "catching samples"? What is 13 "catching samples" referring to? 14 A. It's turning a valve to release the liquid 15 and catching it in a container. 16 Q. Is this to test the material to make sure it 17 met the specifications? 18 A. And you send that container with the 19 material to the laboratory where they test it. 20 Q. Okay, so that's a--done with a valve that's 21 got an "on" or an "off"? 22 A. Yes. 23 Q. Was there any sort of pan or, or catch basin 24 beneath that valve? 25 A. At this time, yes. 185 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050380 1 Q. Was there a time when there wasn't? 2 A. Oh, back in the Fifties, early Sixties, 3 before the PCB issue was raised, many times, any drips 4 out of that facet would be allowed to drip on the 5 floor instead of a catch basin. 6 Q. Is that what you would have called it? I 7 know I used if word "catch basin," but I don't want to 8 put words in your mouth. Would you call it something 9 else? 10 A. Drip pan or-- 11 Q. Okay. 12 A. --any device with walls around it to keep 13 the liquid from-- 14 Q. Do you know when the drip pans were put in 15 beneath the valves? 16 A. Early Seventies. 17 Q. Item 2 refers "The following operations are 18 hazardous and should be done with care." Number 2, 19 "Sampling the solid Aroclor still receiver," and what 20 would make that a hazardous activity? 21 A. Where--are we on the same page? 22 Q. Yeah, F-2. 23 A. Oh, F-2? 24 Q. Mm-hmm. 25 A. It's still the same kind of thing. It's a 186 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050381 1 hot material, liquid. That's why it's--otherwise, you 2 couldn't handle the solid. It would plug the line, 3 but anyway, the sample is taken, it's a very hot 4 liquid, and the caution, here, is be careful. 5 Q. Is it--although it references solid Aroclor, 6 you are saying at the time you are doing the sampling, 7 it's still a liquid? 8 A. Yes. 9 Q. And it becomes solidified, is it solid 10 Aroclor sometime later in the process? 11 A. When it's cooled, crushed, and ground, and 12 put in bags-13 Q. Okay. 14 A. --or containers. 15 Q. So the reference to solid Aroclor is for the 16 most part when it's room temperature, it's in a solid 17 state? 18 A. That is-- 19 Q. But as it goes through the process, it 20 remains a liquid? 21 A. Yes. 22 Q. And then the third one, here, refers to 23 drawing bottoms in the Aroclor stills. Can you 24 describe the process of drawing bottoms? 25 A. It's a process that's similar to drawing the 187 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050382 1 finished product off the top. Appropriate spigots are 2 turned on, and these hot liquids are collected in a 3 container and sent to the laboratory. 4 Q. Now, these--is there, is there a name for 5 these bottoms on these Aroclor stills? 6 A. Well, some of the bottoms are referred to as 7 Montars, whereas some of them just don't have a, a 8 name, they're just bottoms, and they're analyzed, and 9 if there's still some usable material in those 10 bottoms, they are reprocessed. If not, they are 11 discarded. 12 Q. Okay, where are they discarded? 13 A. In the, uh, landfills. 14 Q. During the period that you were plant 15 manager from 1965 through 1969, were these bottoms 16 that could not be utilized for something discarded in 17 one particular landfill? You said "landfills," 18 plural. I'm trying to nail down what landfill you are 19 talking about. 20 A. I thought I said "landfill." I-21 Q. Okay. 22 A. I--anyway, there was this plant landfill 23 which, in plant terminology, was referred to as the 24 dump, in which the containers that had these 25 materials, which had cooled off and now the material 188 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050383 1 is a solid in that container, were transported up into 2 that landfill site, covered eventually with soil, and 3 that's the disposal. 4 Q. Now, the drawing bottoms, you said that 5 again, there's sort of a spigot that you turn on or 6 off to draw the bottom. 7 A. Mm-hmm. 8 Q. Is there a hose connected to that, or is it 9 a spigot into a--into some kind of container? Could 10 you describe that a little bit more for me? 11 A. Well, the--some had hoses, short hoses to 12 allow some flexibility of where you directed the 13 fluid. Some of them just had a, a metal gooseneck, 14 I'm going to call it, an angle, a J-shaped spout that 15 they would turn the valve, collect the sample, shut 16 off the valve,-- 17 Q. Okay. 18 A. --and send it to the laboratory. 19 Q. Now, that's to remove a sample amount. 20 A. Yes. 21 Q. Was there a time when the entirety of the 22 bottoms needed to be removed from the still, not just 23 for a sample? 24 A. Well, yes. Now, that's a different 25 pipeline. 189 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050384 1 Q. Okay. 2 A. A different valve. 3 Q. Okay, so there's one spigot that is used to 4 pull a sample so that you can sample the still 5 bottom-6 A. Yes. 7 Q. --to see whether it can be used further or 8 versus being discarded, but there's a different 9 spigot, then, to actually withdraw all of the still 10 bottoms? 11 A. That is correct. 12 Q. Okay. Into what kind of container would the 13 still bottoms be emptied into? 14 A. For, for--oh, for destruction or disposal? 15 Q. If you are removing all of the still bottoms 16 at once, versus the sample. 17 A. It would be a steel drum, like the kind most 18 of us associate with drums of oil. 19 Q. Like a 55-gallon drum? 20 A. 55 with the vent opening and a fill opening: 21 Solid steel top, not the clamp-on type. 22 Q. Is the still elevated? 23 A. Oh, yes. 24 Q. Up off the ground-25 A. Oh, yeah. 190 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050385 1 Q. --so you can have a drum underneath it? 2 A. Yes. 3 Q. Okay, and was that area beneath where the 4 drum would sit concrete-5 A. Yes. 6 Q. --or earthen? 7 A. Concrete. 8 Q. Okay. Had there been a, a time, to your 9 knowledge , when there was not a concrete floor at 10 that-11 A. Not to my knowledge. 12 Q. On the spigot area where samples are drawn 13 from, again is that another area where as of the 14 1970's there's a drip plant--drip pan in place? 15 A. Yes. 16 Q. But prior to that point in time, there was 17 not a drip plan? 18 A. No, but there was a concrete floor. 19 Q. Do you know where the concrete floor drained 20 to? 21 A. When the department was hosed down, the 22 water would follow its--the normal drainage pattern 23 that every area has, and in the Aroclor department, it 24 ended up in the--a collection pit for neutralizing any 25 acid that might be present and for trapping any 191 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050386 1 Aroclor or heavy byproduct of Aroclor in this pit. 2 Q. And is that the drainage pathway throughout 3 the time you were at the plant as plant manager? 4 A. Oh, the pathway is a natural thing. We--we 5 have to live with it. We can't change it. 6 Q. But there was a, a pit receiving this wash 7 water, if you will,-8 A. Yes. 9 Q. --throughout the time you were there as the 10 plant manager? 11 A. Yes. 12 Q. Okay. Do you know when that pit was put 13 into place? 14 A. I do not. 15 Q. If you could turn the page on the document 16 we've been looking at, Exhibit 12, so we're now we 17 should be on DSW 053429, number 3 at the top of the 18 page refers to explosions. While you were a plant 19 manager, did any explosion ever occur in the Aroclor 20 facility? 21 A. No. 22 Q. To your knowledge, did one occur prior to 23 your arrival as plant manager? 24 A. No. 25 Q. Or subsequent to your departure in 1969, 192 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050387 1 were there any explosions, to your knowledge? 2 A. No. 3 Q. Were there any fires in the Aroclor 4 department during the time you were plant manager? 5 A. No. 6 Q. Before the time--are you aware of any before 7 you arrived in 1965? 8 A. I am not. 9 Q. Okay, or any fires after you left in 1969? 10 A. I did not hear of any. 11 Q. Number 4 talks about, refers to falls. It 12 states "Slipping on cement floors, stairs, Aroclor on 13 floor, ice conditions, et cetera." I want to focus on 14 the reference to Aroclor on floors. Why would there 15 be Aroclor on floor? 16 A. Well, there are a lot of possible sources. 17 Some of it is just the employees, themselves, walking 18 into a, a spot out in the operating unit and walking 19 into an area that had--the floors, here, apply to both 20 the grating-type floor, as well as the solid concrete 21 floors or tiled concrete in the instrument rooms. 22 Most of the floor materials was due to employees' 23 shoes bringing it in as they walked around. 24 Q. Where were they stepping into it in order to 25 get it on their shoes? 193 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050388 A. That's these small leaks that might occur, and they do--they did occur in odd places at odd times, and many times you--especially at night, you wouldn't know you're walking through it as you go from one spot to another, and they would track that around, and that s how the floors would pick up this material. Q. You mentioned two kinds of floors, grating floors and then the solid floors. Where are the grating floors? Is that upper levels, or is the first floor grating floors, as well? A. No, generally, the first floor was solid concrete The upper levels were generally the grating, except for those facilities like the instrument room, the rest room, the locker room, that kind of--if, if it existed at all in that department or that unit, would have a solid floor. Q. Okay, if the employees did get the Aroclor on their shoes in their--in tracking it around, are they wearing personal shoes or company shoes? A. I'm going to call them company issue. Q. Okay. A. They're issued the proper booties to--with the, the sides protecting part of the ankle, and so on, and then the, the sole would be resistant to deterioration as they walked through these various 194 Papageorge, William; McWane (2) (Former Monsanto Employee WATER PCB-SD0000050389 1 chemicals that they're involved with. 2 Q. What were the booties made of? Do you 3 recall? 4 A. I recall some of them with neoprene being 5 the preferred material. I don't recall any other 6 material used. 7 Q. Was there a point in time when the company 8 did not issue booties to the workers in the Aroclor 9 facility, to your knowledge? 10 A. I'm only guessing. I don't know what 11 happened back in the Forties and Fifties. 12 Q. When you arrived in 1965, though, issuance 13 of booties to the Aroclor workers was the standard 14 practice? 15 A. Yes, for those workers who would probably 16 have a need for 'em. 17 Q. Okay, what about people like Maintenance 18 Department or Technical Services Department who were 19 not assigned full-time as a worker in the Aroclor 20 facility? 21 A. They could pick up a pair as they went into 22 appropriate areas. 23 Q. And at the end of the day, did they discard 24 their company-issued booties? Any of the workers, 25 now. I'm not just speaking of technical service or 195 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050390 1 maintenance, but those who had the booties on. 2 A. Those who were issued booties as part of 3 their job kept them until they felt that they needed a 4 new pair. It was their decision in terms of 5 wearability, damage, and so on. 6 Q. Where did they keep them at the end of the-7 A. In their-8 Q. --at the end of their shift? 9 A. --lockers. They had, they had lockers for 10 their personal clothes and a locker for their working 11 clothes: Adjoining lockers. 12 Q. Now, you've testified in prior testimony, 13 haven't you, that you, yourself, would get Aroclor on 14 your shoes, and get into your car and get Aroclor in 15 your car; is that correct? 16 A. That is correct. 17 Q. So you didn't always put booties on? 18 A. I wasn't issued any booties. 19 (Laughter.) 20 A. (Continuing) No, I would pick 'em up as I 21 walked through the plant, and before I got in my car, 22 I'd kind of take a twig or something and clean off the 23 accumulation under my heel, but I would still find 24 marks on my kitchen floor when I got home. 25 Q. If you could turn to the next page, DSW 196 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050391 1 053430, still under 4, which is described as "Falls," 2 I'd like to direct your attention to paragraph D as in 3 "dog," and that states that "Spills must be cleaned up 4 immediately following their occurrence. Report any 5 spill that cannot be cleaned up within the shift to 6 the chief operator. Spills are to be reported in the 7 log book." Can you describe your understanding of how 8 spills were handled, to whom, to whom the spill was 9 reported, and who had the responsibility for cleaning 10 up? 11 A. Well, the normal way information is 12 transferred is--usually follows the organization, so 13 if the operator sees it, he calls the chief operator 14 and tells them. The chief operator makes a decision 15 are there enough hours for the shift to clean it or 16 not, or maybe we can do a partial cleanup and when the 17 next shift takes over, that chief operator connects 18 with the replacement chief operator, so the 19 communication continues. In addition, by logging it 20 on the paper work that's in the department, that 21 message is conveyed, and the logging really reports 22 the leak in a given area, cleanup completed, cleanup 23 in progress, whatever the status was. Generally, 24 that's as far as most cleanups go. If it's a much 25 more challenging problem, the chief operator would 197 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050392 report it to the foreman on the day shift, and the foreman, in turn, makes a decision "Do I involve my supervisor," so it goes up the--what do you call it--the chain of command. Q. What would be used to clean up any spills? A. It's really up to the individual doing the cleaning. Some of those spills were cleaned up using sand, if it was large enough and enough liquid available. Some of them were easily cleaned up just a rag. Some of them required some solvent, and the individuals would--for example, take some benzene and help absorb some of the more difficult stains, if you will, with materials like benzene. Q. If, um, if rags were used, where would the rags be discarded after cleaning up? A. The rags would be discarded in these landfills we talked about, the dumps. Q. Did they have a--I mean, was there a receptacle of some kind at the plant, itself, for the rags to go into before they got taken over to the-A. Yes, they had the-Q. --landfill? A. --steel drums with the open tops, not the kind with the openings like the liquid drums. Q. Mm-hmm. Were those dedicated for 198 Papageorge, William; McWane (2) (Former Monsanto Employee WATER PCB-SD0000050393 1 cleanup-type, contaminated rags and that type of 2 material? 3 A. Well, there was a distinction made between 4 throwing away waste paper records in one container and 5 an oily rag in this other container. Yeah, they were 6 distinguished-- 7 Q. Okay. 8 A. --just by their location. 9 Q. Okay, and if solvent was used, why would 10 solvent be needed to clean it up? 11 A. I'm sorry? 12 Q. Why would solvent be needed to clean it up? 13 A. You need something to, I'm going to call it 14 cut the grease effect. 15 Q. Okay. 16 A. Otherwise, it stays there, and in some 17 areas, you would like to get down to theoriginal 18 surface. In other areas, youdo the best you can and 19 tolerate the black color. 20 Q. Would that--is that visually the indicator 21 that there had been an Aroclor spill on the floor, the 22 black color? 23 A. Well, it's--I wouldn't say it's black. It's 24 oily looking. 25 Q. Okay. At some point, you also mentioned 199 Papageorge, William; McWane (2) (Former Monsanto Employee; WATER PCB-SD0000050394 1 that occasionally, the--water was used just to wash, 2 hose down the floors. Was that done as a regular 3 housekeeping practice or specific to spill occasions? 4 A. That's just regular hosing down not only for 5 these spills but for anything else that accumulates. 6 Q. And I think you said, then, the cleaning up 7 was the responsibility within the operating area. In 8 other words, there wasn't a separate cleanup crew 9 whose--who was tasked with wandering the plant, 10 cleaning up areas. Is that correct? 11 A. Well, there were some individuals in the 12 plant to clean up the general plant, mowing the lawns, 13 and so on, but if it involved a material from a 14 manufacturing process, that was the responsibility of 15 the individuals in that unit, in that manufacturing 16 unit. 17 Q. You also said that sand might be used to 18 clean up spills. Where, where was the sand obtained? 19 A. It was purchased. 20 Q. Do you know what type of sand it was? 21 A. By "type," you mean by technical name? I 22 can only go by the color. It's tan colored. It 23 wasn't white beach sand. 24 Q. Did it come in bags? 25 A. Some of it came in bags, but most of it came 200 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050395 1 in a dump truck. They would deliver and dump it in a 2 corner of the plant and it would be available. 3 Q. Were those company dump trucks bringing the 4 sand in? 5 A. No, they were suppliers' trucks. 6 Q. Where would the sand be stored within the 7 facility before being used for cleaning up a spill? 8 A. It was just dumped out in the open. It 9 wasn't stored anywhere. 10 Q. Was there single pile that contained sand 11 out in the yard somewhere? 12 A. Oh, it, it depended on the, the delivery 13 schedules, and if the pile still at the plant was a 14 reasonable size, they would not dump the new pile on 15 top, they'd go over another place and dump the second 16 pile, so there was no one spot specific to sand only. 17 Q. After the sand was used to clean up a spill, 18 where would the sand be taken? 19 A. It would be put in the steel containers, 20 open-top steel drums, eventually sealed and taken to 21 the landfills. 22 Q. To your knowledge, was any of that sand 23 obtained from foundries in Anniston? 24 A. I'm sorry. 25 Q. To your knowledge, was any of the sand 201 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050396 1 obtained from the foundries in Anniston? 2 A. I never heard that before, no. 3 Q. To your knowledge, they were not using 4 foundry sand for cleaning up spills; is that-5 A. That is true. 6 Q. Who would be responsible for acquiring the 7 sand? 8 A. Well, there again, it's the individual 9 responsible for receiving raw materials and-10 Q. The same process we talked about before with 11 the purchasing agents and the warehousing individual? 12 A. Yes. Yeah. 13 Q. If we could turn to the--probably really the 14 last page of the document, but there's an extra page 15 at the end, here, so let's go to the second-to-last 16 page, DSW 053440, please. It's--the top of the page 17 refers to Appendix N, "Miscellaneous," the heading 18 "Specialized Equipment." I'll give you a moment to 19 read the few sentences, there, to yourself before I 20 ask my question. 21 (Witness peruses 22 said document.) 23 A. I've read it. 24 Q. Okay. Do you recall there being an issue of 25 iron rust forming? 202 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050397 1 A. I don't know that I would describe it as an 2 issue. It was a desired precaution, because the 3 General Electric people didn't want that rust 4 introduced into the transformers and creating all 5 kinds of problems with the operation of the 6 transformer. 7 Q. This particular paragraph refers to a 8 zinc-tin lining to present rust in the Pyranol mix 9 tank and tank cars. Do you recall any other type of 10 galvanizing or lining used to prevent rust? 11 A. I do not. 12 Q. Do you know if any lead galvanizing was 13 used? 14 A. I never heard of that, no. 15 Q. You can set that document aside. 16 I'd like to back up to the Aroclor 17 production process. We've talked about biphenyl 18 production, we've talked about the last exhibit was 19 standard manufacturing process for Aroclor blends. 20 I'd like to turn now to Aroclors, themselves, and that 21 manufacturing process. Can you describe in your own, 22 in your own words to a lay person the production 23 process for Aroclor manufacturing when you arrived in 24 1965? 25 A. I will try. 203 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050398 1 Q. Okay. 2 A. You start with the biphenyl as a liquid, and 3 introduce into that liquid chlorine, and the chlorine 4 then combines with the biphenyl by replacing a 5 hydrogen and introducing chlorine. The time and 6 amount, the time the chlorine is introduced and the 7 amount introduced determines the, to a great degree, 8 the amount of chlorine that attaches itself to the 9 biphenyl group. The operators know either from 10 personal experience or information they receive from 11 the more experienced workers that after so many hours 12 and you are seeking a certain Aroclor mixture, takes 13 your sample and have this sample sent to the 14 laboratory and have them determine, at the laboratory, 15 determine some of the properties of that sample; what 16 is its specific gravity, what color is it, and so on, 17 some very preliminary kinds of testing, and if it 18 meets some minimal expectations, it's time to stop 19 chlorinating and send that mixture to a unit which 20 distills, and by distilling, we're talking about a 21 process that heats the material to form vapors. The 22 initial vapors are high in the residual chlorine. 23 It's still in that mixture, hasn't reacted, then there 24 is a phase when the hydrogen chloride, which was 25 formed when the hydrogen which was removed from the 204 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050399 1 biphenyl combined with the chlorine that was present 2 to make hydrogen chloride gas. That'll come off, and 3 eventually, you reach the point where most of these, 4 I'm going to call them byproduct materials are 5 removed, and then the Monsanto procedure called for 6 introducing, as I remember, sodium hydroxide--lye is 7 the common word, l-y-e--to neutralize any remaining 8 acid. The distillation then continues and the 9 material is checked in a product receiver instead of 10 the off-gas receiver, and when the operation reaches 11 either a time limit and/or a temperature limit, the 12 distillation is, for all practical purposes, 13 completed. The material that was collected from this 14 operation is now sampled, and that sample is sent to 15 the laboratory again, and this time, they conduct a 16 much more sophisticated analysis, looking for many 17 properties, specific gravity, color, and so on, and 18 when certain of these properties are met, they're 19 pretty confident that the material was the Aroclor 20 that was intended to be produced, say, the Aroclor 21 1242, and that becomes, then , the salable or usable 22 finished product. 23 Q. Is that--what, the product receiver you 24 refer to, is that a tank? 25 A. Yes. 205 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050400 1 Q. So the product, if it's passed the test, is 2 then drawn out of that tank? 3 A. It's attached to what? 4 Q. It's the--assuming that the sample came back 5 good,-6 A. Oh. 7 Q. --the product is then taken out of that, 8 that tank,-9 A. Right. 10 Q. --how is it removed from the tank? 11 A. Well, it has its own pumping system, 12 pipelines, valves, pumps, to send it either to a 13 storage tank for that material specifically or to 14 another storage tank where that material will be 15 blended, so it goes in two places: One to be shipped, 16 the other to be blended, and eventually shipped as a 17 blend. 18 Q. Okay. You indicated that it would either, 19 the material was either going--I'm not sure I have 20 this right, but the, the product receiver versus the 21 off-gas receiver. What's going in the off-gas 22 receiver? 23 A. The gases that are removed initially are run 24 through a system that uses water to scrub out the 25 soluble gases, and the intent, there, is to end up 206 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050401 1 with the hydrochloric gas, transferred into water, to 2 become hydrochloric acid, which is commonly called 3 muriatic acid, and that acid, there's a market for it. 4 It can be sold. 5 Q. So what's coming off initially is the 6 hydrochloric gas, if I understood you correctly, and 7 that is then going--being directed through a scrubber? 8 A. (Nods head in affirmative manner). 9 Q. Is the scrubber removing certain impurities, 10 or is it just adding water to turn into it 11 hydrochloric acid? 12 A. Well, I don't know of any impurities are 13 that volatile. The water will, of course, absorb the 14 hydrochloric gas and make the acid. 15 Q. Okay. Where was the--where would the water 16 come from? 17 A. The city water supply. 18 Q. Was there always a city water supply when 19 you were there as plant manager, or was there a point 20 in time when there was well water, or other water 21 source? 22 A. No, the city water supply was our only 23 source. 24 Q. When chlorine is introduced into the 25 process, that's introduced as a chlorine gas; is that 207 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050402 1 correct? 2 A. That is correct. 3 Q. Was a catalyst used in that first stage of 4 the chlorination process? 5 A. I'm not aware of any catalyst. 6 Q. I'll see if I can get the right documents 7 now. 8 MR. NASSIF: He needs to take a break. 9 THE VIDEOGRAPHER: Four minutes. 10 MS. LAVEY: Well, I can think about it for 11 three and a half minutes. 12 THE VIDEOGRAPHER: Let's go ahead and 13 change. 14 MS. LAVEY: Let's change. 15 THE VIDEOGRAPHER: This will end tape number 16 if 2 of the deposition of William B. Papageorge. 17 We're off the record at 11:28 A.M. 18 (Recess.) 19 THE VIDEOGRAPHER: We're back on the record, 20 11:37 A.M. This begins tame number 3 in the 21 deposition of William B. Papageorge. 22 BY MS. LAVEY: 23 Q. Mr. Papageorge, I'm going to hand you a 24 document which we will mark as Exhibit 13. 25 (Defendant's Exhibit 13 208 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050403 1 marked for 2 identification.) 3 BY MS. LAVEY: 4 Q. Mr. Papageorge, I'll ask you to take a look 5 at that document and let me know if you recognize it. 6 For the record, this is "Standard 7 Manufacturing Process for Aroclor, " has --states it 8 supersedes standard manufacturing process issued 9 October 22nd, 1957. This document has a date of 10 September 1966, Bates range DSW 303353 through DSW 11 303482. 12 Oh, I'm sorry. 13 MR. NASSIF: That's all right. 14 (A copy is handed to. 15 Mr. Nassif.) 16 (Witness peruses said 17 document.) 18 BY MS. LAVEY: 19 Q. Do you recall this document, Mr. Papageorge? 20 A. I recall the format. It's very typical to 21 other documents of a similar nature for all the 22 processes at the Anniston Plant. This is specific to 23 Aroclors. I do not recall the individual and very 24 specific items that are covered in this document. 25 Q. Based on your understanding of the standard 209 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050404 1 manufacturing process documents, would this document 2 accurately reflect, as of September 1966, the manner 3 in which Aroclors are produced at the Anniston Plant? 4 A. Yes. 5 Q. So the production units would use this as a 6 sort of guide to ensure a consistent manufacturing 7 process, batch to batch? 8 A. Yes. 9 Q. Do you--the first page of this indicates 10 it's superseding a 1957 standard manufacturing 11 process. Do you have any recollection of what was 12 different as of September 1966 and the previous 13 version? 14 A. No, I do not. 15 Q. Although the copy guality is very poor, I 16 want to direct your attention to DSW 303378. It's 17 about 25 pages in. It's a page you can't read very 18 well, the top of which says Roman numeral IV, 19 "Comments on the Process," Section A, "Liguid 20 Aroclors," number 1, "Chlorination," and under B, do 21 you see the section marked B, "Catalyst"? 22 A. Yeah, I note it reminds me I forgot to 23 mention iron. 24 Q. I was going to bring you there. 25 (Laughter.) 210 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050405 1 Q. (Continuing) Do you recall -- 2 A. Yes. 3 Q. --iron being used as a catalyst in the 4 chlorination? 5 A. Yes, now, I--very vividly. 6 Q. Why do you recall it so vividly? 7 A. Well, I, frankly, had forgotten it until I 8 read it again here,-- 9 Q. Okay. 10 A. --and it fit together very well. 11 Q. What, exactly, are iron turnings? 12 A. Just, they just take iron and, and grind it 13 up until it becomes like iron filings. 14 Q. Did the plant receive the iron turnings in 15 that state -- 16 A. Yes. 17 Q. --or were you doing that at the plant? 18 A. No, it was received as used. 19 Q. Do you know where the--from whom the iron 20 turnings were obtained? 21 A. I do not. 22 Q. Okay, and who would know that? Would that 23 be the purchasing agent and warehousing superintendent 24 that we've talked about before? 25 A. Those are logical places to ask, mm-hmm. 211 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050406 Q. Do you know if the iron turnings would be pure iron? A. I do not know the, the specifications as to contents Q. Do you know if it mattered to the process whether it was a pure iron or had other materials in the iron? A. No, I'm not qualified to say. Q. Was a--for each new batch of production, was a new basket of iron turnings utilized, or could you reuse the same basket of iron turnings over and over again in the process? A. As I remember, it's, it's a reusable source, and when it depletes through long usage, they replenish with the-Q. Because it's actually the iron turnings are used to produce ferric chloride which is, in fact, the actual catalyst; correct? A. Correct. Q. Okay. Did there come a time when the iron turnings had to be taken out of the basket to be replaced with fresh iron turnings? A. I'm not aware that they ever discarded the residual iron filings; they just added to it as long as there was iron present that satisfied the needs of 212 Papageorge, William; McWane (2) (Former Monsanto Employee WATER PCB-SD0000050407 1 the reaction. 2 Q. Do you recall the time frame during which 3 iron turnings were being used in order to produce the 4 ferric chloride as a catalyst? Is that something that 5 was occurring throughout your period as plant manager? 6 A. Yes. 7 Q. Okay, do you know if that was the process in 8 place prior to your arrival? 9 A. It was. 10 Q. Okay, was that the process, as far as you 11 know, from the beginning of Aroclor production, or is 12 that a more recent change in the production process? 13 A. It's my understanding it was present from 14 the very beginning. 15 Q. Okay. Do you know if ferric chloride was 16 ever added directly, rather than the use of the iron 17 turnings ? 18 A. I've never heard that, no. 19 Q. Okay, and that, that aspect of the process 20 continued after you left, as well? 21 A. Yes. 22 Q. Up until the cessation of all Aroclor 23 production? 24 A. Correct. 25 Q. And you can put that one aside, 213 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050408 1 Mr. Papageorge. 2 BY MS. LAVEY: 3 Q. I'm going to hand you another standard 4 manufacturing process document, Mr. Papageorge, which 5 we'll mark as Exhibit Number 14. 6 (Defendant's Exhibit 14 7 marked for 8 identification.) 9 BY MS. LAVEY: 10 Q. And I'll ask you to take a look at that, as 11 well, and advise me whether it's a document that you 12 have seen before in your position as plant manager. 13 (Witness peruses said 14 document.) 15 MS. LAVEY: For the record, this document is 16 entitled "Standard Manufacturing Process for Aroclors, 17 October 1968," Bates range DSW 392112 through DSW 18 392264 . 19 (Witness continues to 20 peruse said document.) 21 A. The--again, the document is very similar to 22 the types of specifications or process descriptions 23 common in the plant. The fact that I've signed this 24 document indicates that I did see it. I do not 25 remember the detailed specifics. 214 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050409 1 BY MS. LAVEY: 2 Q. Okay, and you are referring to your 3 signature on the second page, DSW 392113, correct? As 4 the plant manager? 5 A. Correct. 6 Q. Sir, does this document accurately reflect 7 the production process for Aroclors, at least as of 8 October 1968? 9 A. Yes. 10 Q. Do you have any recollection of how this 11 document was different than the one that had been 12 issued September 1966? 13 A. The only recollection I--that comes to mind 14 is the introduction of a method for chlorinating that 15 involved a series of tanks, and the chlorination would 16 occur as the material flowed through that series, 17 rather than key--keeping it in one container until the 18 end of the chlorination, and then-19 Q. So the chlorination used to take place in 20 one vessel? 21 A. One vessel, until the end. 22 Q. Okay. 23 A. This allowed, or was designed to permit the 24 flow as it went through the system to pick up the 25 chlorine so that by the time it reached the last tank, 215 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050410 1 it was close to completion. 2 Q. Would the sampling of that, initial sampling 3 you talked about before that was done to kind of 4 roughly see are we on track, here, with the right 5 amount of chlorine, would that occur at the end of the 6 sequence or at each one of the separate tanks along 7 the way? 8 A. Initially, it was each one until the 9 operators and the supervision became very familiar 10 with that approach, and then it became the last tank. 11 Q. And did that process --in fact, was that 12 process retained? In other words, you stayed with the 13 sequential tanks, you didn't return to the one-tank 14 system? 15 A. That's true. 16 Q. Okay. 17 A. Now, what I don't remember is whether all of 18 the production went through that system. Some of it 19 may still have been made in the older units. 20 Q. So you, you don't recall a complete 21 changeover from one system to the other, that you had 22 both of them operating in parallel? 23 A. As I recall, this was in addition. 24 Q. If you go five or six pages in to DSW 25 392118, there's a reference to AMENDMENT number A 216 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050411 1 described as "Packed bed treatment of electrical grade 2 Aroclors," date of May 18th, 1967, and the disposition 3 indicates that it was accepted. Do you recall that 4 particular amendment? 5 A. I do not. 6 Q. Do you know what is meant by "packed bed 7 treatment"? 8 A. No, that's my confusion. 9 Q. That's what you don't remember? 10 A. I don't remember that terminology. 11 Q. Okay. That's all I have on that document. 12 You can set that aside. 13 I'm going to hand you yet another standard 14 manufacturing process for Aroclors which will be 15 marked as Exhibit 15. 16 (Defendant's Exhibit 15 17 marked for 18 identification.) 19 BY MS. LAVEY: 20 Q. This document is entitled "Standard 21 Manufacturing Process for Aroclors, July 1969, " Bates 22 range DSW 543174 through DSW 543336. I'll again ask 23 you to take a look at that, Mr. Papageorge, and tell 24 me whether you recognize it. 25 (Witness peruses said 217 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050412 1 document.) 2 A. I have scanned the exhibit. I again don't 3 recall this specific, but it's a, again, a familiar 4 type of document. This appears to me to concentrate 5 particularly on--well, I shouldn't say that. It 6 covers both the liquid, as well as--PCBs, as well as 7 the terphenyls, chlorinated terphenyls. I don't know 8 what else to add to that. 9 Q. Okay. 10 A. It doesn't have any--it doesn't bring to 11 mind any particular occasion, or need, or -- 12 Q. And this document, since you were thumbing 13 through it, I'm sure you noticed there were a series 14 of what I referred to as tentative amendments at the 15 front portion of this document,-- 16 A. Yes. 17 Q. -most, if not all of which appear to 18 postdate your time frame as plant manager. 19 A. That's correct. 20 Q. When you moved to St. Louis, would you have 21 ceased receiving copies of these? 22 A. That is true. 23 Q. Okay. 24 A. Mm-hmm. (Nods head in affirmative manner). 25 Q. Okay, but not looking at the amendments, the 218 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050413 rest of the document that was issued July 1969, that would accurately reflect the production process in place at that time at the Anniston Plant. A. Yes. Q. Correct? On the--I would like to review s ome o f the names again. On the second page of the document, DSW 543175, we talked about Mr. Schulte before and Mr. Landwehr. There is also a T. W. Lawrence. Do you recall that individual? A. I do not. Q. Do you recall an individual named Gary L. Moore? A. I recall the name; I don't recall the individual or his participation. Q. If we could turn in a couple of pages to DSW 543178, there's a list of approvals and signatures. A. I see it. Q. At that point, the plant manager is Gene Jesse; correct? A. Correct. Q. The next name down is listed as the PR&D group leader, a J. L. Brown. What does "PR&D" stand for, if you know? A. It's a research and development activity. The "P" is--I think refers to product research and 219 Papageorge, William; McWane (2) (Former Monsanto Employee WATER PCB-SD0000050414 1 development, but I am not certain. 2 Q. And do you know who J. L. Brown refers to? 3 A. I'm sorry? 4 Q. Do you know who J. L. Brown is in that 5 position as PR&D group leader? 6 A. I do not. 7 Q. Would that be Jerry Brown, or is this a 8 different individual? 9 A. I hesitate because I don't associate Jerry 10 Brown as a researcher. I don't know. 11 Q. Also on that same page, the Research Group 12 Leader, a J. W. Baker, do you recall that individual? 13 A. No, I don't. 14 Q. Manager of Research and Development, 15 W. R. Richard? 16 A. I remember Bill Richard, yes. 17 Q. An was he in St. Louis? 18 A. He was, mm-hmm. 19 Q. The manufacturing manager is identified as 20 J. R. Savage? 21 A. James Savage, yes. 22 Q. Where was he located? Is that St. Louis or 23 Anniston? 24 A. St. Louis. 25 Q. Do you know how long Mr. Savage held that 220 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050415 1 position as manufacturing manager? 2 A. I do not. 3 Q. Do you know how long he was with the 4 company? 5 A. I don't. 6 Q. Continuing to the next page, you'll see DSW 7 543179 referred to a tentative Amendment G. I guess I 8 should have asked this earlier. When they, when they 9 say it's a tentative amendment, does that mean that it 10 may or may not be accepted into the SMP? 11 A. That is possible , yes, it may or may not, 12 mm-hmm. 13 Q. When it's first developed, it's a tentative 14 amendment; correct? 15 A. True. 16 Q. If the approval page is signed, does that 17 mean it has been accepted, or is it just approving the 18 test run, if you will? 19 A. Will you show me which page that is? 20 Q. For example, for Amendment G, it would be 21 page 6 of that document if you thumb through a few 22 pages. 23 A. Page 6. 24 MR. NASSIF: You can get that if you need to 25 pull that out. 221 Papageorge, William; McWane (2) (Former Monsanto Employee; WATER PCB-SD0000050416 1 BY MS. LAVEY: 2 Q. What I'm asking is, is the signatures on 3 this page, which are similar in form for other 4 amendments, is that an indicator that there is an 5 approval to proceed with this experiment, or test run, 6 or whatever the amendment is about, or does that 7 signify an approval that the amendment has been 8 accepted into the SMP? 9 A. The approval signature page applies to the 10 preceding documentation, and in this particular case, 11 they are referring to trying three to five batches, on 12 page 4, so that's what these individuals approve for 13 the trial. 14 Q. They're approving the trial? 15 A. That's the way I-16 Q. Okay. 17 A. --interpret this document. 18 Q. Okay. On page 4 that you were referring to, 19 it indicates the originator of this particular 20 amendment is a K. G. Hale. Do you know that name? 21 A. I do not know him. 22 Q. You can set that document aside, 23 Mr. Papageorge. 24 Could you describe physically the 25 distillation unit for the Aroclor production? Is this 222 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050417 1 a--are these a series of stills? Is it one big 2 contraption? 3 A. I don't recall the specifics of that 4 distillation system. 5 Q. Okay, do you know what the distillation took 6 place in? A distillation column, or a tank? 7 A. It's a, it's a column, but I don't know what 8 is in that column. 9 Q. Were there a sequence of columns? 10 A. I don't remember. 11 Q. Was there a difference in the process for 12 liquid Aroclor production versus solid Aroclor 13 production, or is it just a difference in how much 14 chlorination had been done to it? 15 A. Well, it's, it's a difference in the degree 16 of chlorination, as well as the fact that the solid 17 Aroclors were terphenyls, but at the temperatures of 18 the operations, all of the Aroclors, whether they be 19 terphenyls or polychlorinated biphenyls, are liquids. 20 The distillation columns, I, I don't recall how they 21 were designed internally, whether they had packing in 22 them or whether they had trays which the gas or vapor 23 bubbled through liquid and changed its properties as 24 it went up the column, I don't know that detail. 25 Q. It's the terphenyls, then, would not be a 223 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050418 1 1200 series. Is that right? 2 A. The terphenyls would be the 5000-3 Q. Okay. 4 A. --series. 5 Q. Okay, and the distillation system was kept 6 at an elevated temperature? Is that correct? 7 A. Correct. 8 Q. Was the distillation for solid Aroclors kept 9 at a higher temperature than distillation for liquid 10 Aroclors, or is there not a real difference? 11 A. You mean Aroclors or biphenyls? Chlorinated 12 biphenyls? 13 Q. The solid Aroclors versus the liquid 14 Aroclors. I was asking whether there's a temperature 15 difference in the distillation process. 16 A. There is a temperature difference, whether 17 they're terphenyls or biphenyls. 18 Q. When is there a temperature difference? 19 A. Well, in the biphenyls, the more chlorine 20 content, the higher the temperature. In the 21 terphenyls, being an entirely different chemical 22 family, they start off with a high temperature, and 23 then as the chlorination level increases, the 24 temperatures also rise. 25 Q. Were the solid Aroclors made in a different 224 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050419 1 set of distillation units? 2 A. Whew, I don't remember that. 3 Q. You don't remember whether the liquid 4 Aroclors were made in one place and the solid Aroclors 5 were made in another place? 6 A. I do not. 7 Q. Do you recall--strike the question. Let me 8 just hand you the document. 9 I'm going to hand you a document that we'll 10 mark as Exhibit 16, as DSW 392343. 11 (Defendant's Exhibit 16 12 marked for 13 identification.) 14 Q. (Continuing) And I recognize your name 15 doesn't appear on here, but I'd still like you to take 16 a look at it and let me know whether it's a memo that 17 you have seen before. 18 (Witness peruses said 19 document.) 20 A. I don't recall ever seeing this. 21 Q. Do you remember something referred to as a 22 clay addition pot? It's referred to in the end of 23 this document in the third paragraph. 24 A. I do not remember that. 25 Q. Do you remember dry clay being used in any 225 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050420 1 way in the process? 2 A. The only clay I recall is Attapulgus. I 3 don't know what type of clay it's referring to here. 4 Q. When the Attapulgus earth was used, how was 5 that added? Did you remember physically what it was 6 contained in? 7 A. No, I don't. 8 Q. I'm trying to determine whether it's 9 possible it's the same thing as this clay addition 10 pot, but this is just not a term you've heard; 11 correct? "Clay addition pot"? Okay. 12 A. I do not know. 13 Q. Okay. Set that aside. 14 Do you recall an Aroclor expansion project 15 at the end of your time as plant manager? 16 A. At the end of my time? 17 Q. Well, okay, during the time that you were 18 plant manager, was there a point in time where the 19 Aroclor production was expanded? 20 A. I recall a reference to expanding the 21 production, and I associate that with the introduction 22 of the step-wise chlorination process that was 23 introduced. 24 MS. LAVEY: I'm going to hand you another 25 document which we will have the court reporter mark as 226 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050421 1 Exhibit 17. 2 (Defendant's Exhibit 17 3 marked for 4 identification.) 5 BY MS. LAVEY: 6 Q. (Continuing) And this document has Bates 7 range DSW 577126 through 577150. 8 A. I have scanned the exhibit. 9 Q. Mm-hmm? 10 A. I do not have any recollection of seeing 11 this . 12 Q. Do you know who R. S. Yates is? 13 A. Robert Yates? 14 Q. Do you know what position Robert Yates had? 15 I guess I should narrow that down to the time when you 16 were plant manager. 17 A. I associate Mr. Yates as being a--as best I 18 remember, he was a member, an engineer in the 19 Corporate Engineering Department. 20 Q. Do you recall who the head of the 21 engineering department was at Corporate, the Corporate 22 level while you were in Anniston? 23 A. I do not. 24 Q. Do you recall any of the head top guys in 25 the engineering department? 227 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050422 1 A. I do not. 2 Q. Do you know the name J. W. Colgan, 3 C-o-l-g-a-n? 4 A. No. 5 Q. Mr. Papageorge, do you know if the Anniston 6 Plant employed any carpenters while you were plant 7 manager? 8 A. There were members of the maintenance group 9 that carried the title of carpenter. 10 Q. What would the carpenters be used for? Do 11 you recall? 12 A. I can't think of too many specific--they 13 were involved, for example, in arranging repairs in 14 the office buildings, and so on, but most of the time, 15 there was no basic carpentry to be done. They would 16 pinch hit as pipefitters and all the other categories 17 in the Maintenance Department. 18 BY MS. LAVEY: 19 Q. I'm going to hand you another document and 20 ask the court reporter to mark this as Exhibit 18. 21 (Defendant's Exhibit 18 22 marked for 23 identification.) 24 BY MS. LAVEY: 25 Q. (Continuing) I'll ask you to take a few 228 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050423 moments to review that, Mr. Papageorge, before I ask you questions. (Witness peruses said document.) A. I have read the document. BY MS. LAVEY Q. before? Do you recall ever seeing this document A. I do not. Q. Is this the type of document that as plant manager, you would normally expect to receive? A. Not necessarily. Q. Does it refresh your recollection about a proposed Aroclor expansion project in this time frame? The memo is dated 1967, while you were plant manager. A. Well, this was part of a discussion going on about the Aroclor facilities at the plant, and I don't know how else to describe it. It does refer to an approved project, CEA 1430, which involved the Anniston Plant. Q. Under the Anniston portion of this memo, I think the second page refers to Krummrich, but on the first page, in reference to Anniston, there is a discussion of a new tank farm. Do you recall whether that new tank farm was, in fact, put in? A. Yes. 229 Papageorge, William; McWane (2) (Former Monsanto Employee WATER PCB-SD0000050424 1 Q. How about the next item, number 2, a new 2 drumming station? Do you recall if that was put in? 3 A. That was installed, yes. 4 Q. Do you recall when? 5 A. The best of my recollection, about 1968. 6 Q. How about the tank farm? I forgot to ask 7 when that was you indicated-8 A. About the same time. 9 Q. 1968? 10 A. Yes. 11 Q. The next item refers to new flaking and 12 packaging facilities for solid Aroclors and biphenyl. 13 Do you recall if that was installed? 14 A. Yes. 15 Q. Do you recall what the--when it was 16 installed? 17 A. About the same time. 18 Q. And then the fourth item refers to a, a 19 warehouse that would be built which would, in fact, 20 contain the flaking, new flaking and packaging 21 facilities and the new drumming station. Was that 22 warehouse built? 23 A. Yes. 24 Q. Do you recall where the warehouse was 25 located? 230 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050425 1 A. I don't know quite how to describe it. It 2 was a city block away from the producing unit that I 3 referred to earlier. 4 Q. This document refers under number 2 to a 5 proposed warehouse at 6th and Parkwin Street. Does 6 that sound right for where the warehouse ultimately 7 was put? 8 A. As best as I recall, yes. 9 Q. This memo refers to the CEA as Aroclor 10 expansion. Do you recall any other production 11 facilities being added or expanded at this time frame, 12 1968, other than these four items that are listed 13 here? 14 A. I do not. 15 Q. Who is R. P. Stevens listed on this memo at 16 the very top in general offices? 17 A. Yes, he was a member of a Corporate 18 Engineering Department whose--who led the group that 19 was assigned this project. 20 Q. Do you know why a new tank farm was needed? 21 A. Increase production. 22 Q. Increase production of what? 23 A. Aroclors. 24 Q. Would this be solid, or liquid, or both? 25 A. Both, but primarily liquid. 231 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050426 Q. Was this activity in 1968, did that activity, once it was all installed, lead to a increase in the number of employees at the facility? A. I don't remember. Q. Do you know why a new drumming station was needed? A. As best I recall, it was due to the increased production and the need of a system that was more automated in terms of conveyor belts, filling lines, labeling facilities, rather than try to do it out of the corner of the operating unit, when-weatherpermitted kind of approach, so this was an attempt to, in essence, modernize their facility. Q. Before the warehouse was built to house the new drumming station and the new flaking and packaging facilities, these activities were not done in a, in a building? A. They were out in the open. Q. Over by the Aroclor production facility? A. Nearby, yes. Q. Okay. Do you recall where the tank farm was, the new tank farm, where was it located relative--A. Near this new warehouse. Q. Okay. Do you recall that that project, the 232 Papageorge, William; McWane (2) (Former Monsanto Employee WATER PCB-SD0000050427 1 expansion project, required the relocation of a 2 process sewer line? 3 A. Not specifically, no. 4 Q. I'm going to hand you another document and 5 ask the court reporter to mark this as Exhibit 19. 6 (Defendant's Exhibit 19 7 marked for 8 identification.) 9 Q. (Continuing) For the record, this appears 10 to be some type of progress report with a date of 11 March 27th, 1968, refers to CEA number 1430, Bates 12 range DSW 392485 through 392486. 13 (Defendant's Exhibit 19 14 marked for 15 identification.) 16 BY MS. LAVEY: 17 Q. If you could take a moment to review this 18 document, please. 19 (Witness peruses said 20 document.) 21 A. I have read it. 22 Q. You'll see on the first page, under 23 "Anniston Plant," your name. Do you recall receiving 24 this document? 25 A. When I saw my name, it brought back some 233 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050428 1 memory, yes. 2 Q. Okay. Does this document help you recall 3 anything about needing to relocate the 24-inch process 4 sewer? 5 A. Yes, I do remember a sewer job relating to 6 this, but I don't recall the exact location, nor do I 7 recall the--what facilities this process pipe 8 serviced. 9 Q. Was it being relocated simply because it was 10 in the way of where the tank farm was going to be, if 11 you recall? 12 A. I do not know. It was obviously in the way, 13 but I don't know for what purpose. 14 Q. Would that job relating to relocating the 15 sewer be done with Monsanto employees or would an 16 outside contractor have done that? 17 A. That type of job would have to be an outside 18 contractor. 19 Q. Do you recall any particular outside 20 contractors that were utilized in connection with the 21 expansion project generally or the sewer relocation 22 specifically? 23 A. Contractors were involved with both the 24 building, and the new facilities, and the sewer, but I 25 don't know which contractors and at what sequence. 234 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050429 1 Q. Do you know if they were local contractors 2 from Anniston or the Anniston area? 3 A. That, I don't know. 4 Q. Do you recall a 36-inch storm sewer needing 5 to be repaired as part of this expansion project? 6 A. No, I do not. 7 MS. LAVEY: I think we'll do this one last 8 document and then be done for the day, since we're at 9 12:30, here. 10 BY MS. LAVEY: 11 Q. I'll hand you another document and ask that 12 the court reporter mark this as Exhibit 20 and ask you 13 to take a few moments to look at that. 14 (Defendant's Exhibit 20 15 marked for 16 identification.) 17 MS. LAVEY: For the record, this is also 18 described as a progress report, referencing CEA number 19 1430 dated January 19, 1968, Bates range DSW 392491 20 through DSW 392492. 21 (Witness peruses said 22 document.) 23 A. I have read it. 24 Q. Okay. There's a hand--handwriting on the 25 first page that says, "CC" and a bunch of initials. 235 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050430 Does the "WBP" refer to you? A. I think so. I did not know anyone else with those same initials. Q. Okay. Do you have any recollection of receiving this progress report? A. Not this specific one, but one of many on these projects. Q. As the plant manager, you would routinely receive the progress reports on the approved projects? A. Not always. These would go to an individual in the plant. In this case, it went to Mr. Taffy, and he was the one to distribute it within the plant. Q. And who was Mr. Taffy? A. He was a member of--I'm going to call it the Technical Services Department General Engineering Advisory Team. Q. But within the Technical Services Department? A. At the plant, yes. Q. At the plant: Okay. He's an engineer by training, do you know? A. I'm sorry? Q. Was he an engineer by training, do you know? A. Yes. Yes. Q. Okay. Does the discussion on the second 236 Papageorge, William; McWane (2) (Former Monsanto Employee WATER PCB-SD0000050431 1 page under "Field work," which refers to repairing the 2 36-inch storm sewer, cause you to recall anything 3 about the, the need for the repair on the 36-inch 4 storm sewer? 5 A. I don't recall the, the details. I do know 6 that they had storm sewer process --or problem and a 7 process sewer problem. 8 Q. But you don't recall what the problem was? 9 A. No, I don't. 10 MS. LAVEY: Okay. I think we can-- 11 MR. NASSIF: Okay, are you making good time? 12 MS. LAVEY: --call it a day. Okay. 13 MR. NASSIF: Okay. 14 THE VIDEOGRAPHER: This will end today's 15 session of the deposition of William B. Papageorge. 16 We are off the record at 12:41 P.M. 17 (Whereupon, at 12:41 P.M., the 18 deposition was recessed to the 19 following day.) 20 21 22 23 24 25 237 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050432 COMES NOW THE WITNESS, WILLIAM B. PAPAGEORGE, and having read the foregoing transcript of the deposition taken on the 31st day of August, 2004, acknowledges by signature hereto that it is a true and accurate transcript of the testimony given on the date hereinabove mentioned. 238 WILLIAM B. PAPAGEORGE Subscribed and sworn to me before this day of , 2004. My Commission expires: . Notary Public DD Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050433 1 State of Missouri ) 2 ) SS. 3 City of St. Louis ) 4 I, J. Bryan Jordan, a Notary Public in 5 and for the State of Missouri, duly commissioned, 6 qualified and authorized to administer oaths and to 7 certify to depositions, do hereby certify that 8 pursuant to Notice in the civil cause now pending and 9 undetermined in the In the United States District 10 Court For the Northern District of Alabama, to be used 11 in the trial of said cause in said court, I was 12 attended at the offices of Husch & Eppenberger, LLC, 13 in the County of St. Louis, State of Missouri, by the 14 aforesaid witness and by the aforesaid attorneys, on 15 the 31st day of August, 2004. 16 The said witness, being of sound mind 17 and being by me first carefully examined and duly 18 cautioned and sworn to testify the truth, the whole 19 truth, and nothing but the truth in the case 20 aforesaid, thereupon testified as is shown in the 21 foregoing transcript, said testimony being by me 22 reported in shorthand and caused to be transcribed 23 into typewriting, and that the foregoing pages 24 correctly set forth the testimony of the 25 aforementioned witness, together with the questions 239 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050434 1 propounded by counsel and remarks and objections of 2 counsel thereto, and is in all respects a full, true, 3 correct and complete transcript of the questions 4 propounded to and the answers given by said witness; 5 that signature of the deponent was not waived by 6 agreement of counsel. 7 I further certify that I am not of 8 counsel or attorney for either of the parties to said 9 suit, not related to nor interested in any of the 10 parties or their attorneys. 11 Witness my hand and notarial seal at 12 St. Louis, Missouri, this 14th day of September, 2004. 13 14 15 J. Bryan Jordan 16 Certified Court Reporter No. 00532 17 State of Missouri 18 My License expires: January 1, 2005 19 20 21 22 23 24 240 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050435 1 COURT MEMO 2 IN THE UNITED STATES DISTRICT COURT 3 FOR THE NORTHERN DISTRICT OF ALABAMA 4 MAGISTRATE JUDGE GREEN 5 6 Solutia, et al. , 7 ................................ Plaintiffs vs Case No. CV-03-PWG-134-E. 9 McWane, et al. , 10 ................................ Defendants. 11 12 CERTIFICATE OF OFFICER AND 13 STATEMENT OF DEPOSITION CHARGES 14 Rule 57.03 (g) (2) (a) & Sec. 492.590 RSMO 1985) 15 16 VIDEOTAPED DEPOSITION OF WILLIAM B. PAPAGEORGE, VOLUME 17 2, TAKEN ON BEHALF OF DEFENDANTS, AUGUST 31, 2004 18 19 Name and address of person or firm having custody of 20 the original transcript: 21 SQUIRE, SANDERS & DEMPSEY, L.L.P. 22 4900 Key Tower 23 127 Public Square 24 Cleveland, OH 44114-1304 241 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050436 1 TAXED IN FAVOR OF: 2 SQUIRE, SANDERS & DEMPSEY, L.L.P. 3 4900 Key Tower 4 127 Public Square 5 Cleveland, OH 44114-1304 6 125 of orig. & copy @ $3.75 ................................ $468.75 7 Attendance of reporter & Jurat .................... $ 86.00 8 Delivery .................................................................................................. $ 9 Total ............................................................................................................. $ 10 11 TAXED IN FAVOR OF: 12 HUSCH & EPPENBERGER, LLC 13 190 Carondelet Plaza, Suite 600 14 St. Louis, MO 63105-3441 15 125 pages of copy @ $1.75 ..................................... $218.75 16 Delivery .................................................................................................. $ 17 Total ............................................................................................................. $ 18 19 20 21 22 23 24 242 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050437 1 TAXED IN FAVOR OF: 2 TROUTMAN SANDERS LLP 3 NationsBank Plaza, Suite 5200 4 600 Peachtree Street, Northeast 5 Atlanta, GA 30308-2216 6 125 pages of copy @ $1.75 ..................................... $218.75 7 Delivery .................................................................................................. $ 8 Total ............................................................................................................. $ 9 10 Upon delivery of transcripts, the above charges had 11 not yet been paid. It is anticipated that all charges 12 will be paid in the normal course of business. 13 14 GORE & PERRY REPORTING CO. 15 515 Olive Street, Suite 700 16 St. Louis, MO 63101 17 18 IN WITNESS WHEREOF, I have hereunto set my hand and 19 seal this 14th day of September, 2004. 20 21 22 J. Bryan Jordan 23 Notary Public State of Missouri 24 (St. Louis City) 25 My Commission expires January 14, 2007 243 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050438 [&-216-621-1312] Transcript Word Index & & 119:20 120:4,14 121:13 122:3 123:12 124:4,14 125:3 128:9,10,12,13,20 164:21 184:17,17 239:12 241:14,21 242:2,6,7,12 243:14________________ 0 00532 240:16 018257 138:12 018297 138:13 03 118:4 119:8 128:5 241:8 048614 138:11 048615 138:25 048616 142:6 048617 148:2 048618 143:14 048627 149:13 048652 151:9 048654 138:11 053329 169:24 053330 173:24 053333 174:5,18 053346 178:11 179:15 053347 182:16 053425 184:15 053428 184:23 053429 192:17 053430 197:1 053440 202:16 053441 169:24 14th 1969 240:12 243:19 1 140:1 166:1 168:16 210:20 15 240:18 125:19217:15,16 1.75 16 242:15 243:6 125:20 225:10,11 10 162 125:14 163:20,21,24 125:14 10:12 163 166:10 125:15 10:22 169 166:2 125:16 139:24 145:10 147:21 149:3 155:11 171:24 173:18 184:12 188:15 192:25 193:9 217:21 219:1 1970 174:6,13,24 175:6 1970's 191:14 1985 241:14 2 100 122:11 11 125:15 164:19,23 166:4,14 166:19,21 11:28 208:17 11:37 208:20 12 125:16 169:22 170:4 192:16 12:30 235:9 12:41 119:22 237:16,17 1200 175:16 224:1 1200s 175:16,17 1201 124:6 1242 205:21 125 242:6,15 243:6 127 120:16 241:23 242:4 128 125:10 1299 122:20 13 125:17 208:24,25 134 118:4 119:8 241:8 1345 128:5 137 125:13 14 125:18 214:5,6 243:25 1430 125:21 227:1,2 17th 138:14 18 125:22 228:20,21 18th 217:2 19 125:23 233:5,6,13 235:19 190 119:20 120:5 127:25 242:13 1901 123:13 1948 163:16 1950 164:22 166:16 1957 138:14 142:9,12 165:21 209:9 210:10 1964 142:9 143:13,18 1965 130:14 131:17,23 133:6 135:13 139:18 141:17 144:17 146:11 147:18 148:8 150:11,17 155:7 163:9 171:21 176:22 177:13 184:9 188:15 193:7 195:12 203:24 1966 165:24 209:10 210:2,12 215:12 1966-67 160:11 1967 217:2 229:14 1968 169:23 174:1 214:17 215:8 230:5,9 231:12 232:1 233:11 235:19 148:3 166:10 184:25 186:17,18,22,23 208:16 230:1 231:4 241:14,17 20 125:24 235:12,14 200 122:11 20004-2400 122:21 20015 123:5 2004 118:12 119:23 127:22 238:3,13 239:15 240:12 241:17 243:19 2005 240:18 2007 243:25 202 121:18 123:6 202-639-7707 122:22 202-639-7832 122:23 205 121:19 122:6 123:16 205-251-5900 121:17 207 125:17 20th 121:14 2100 122:4 213 125:18 216 120:18,19 125:19 216-621-0577 124:19 216-621-1312 229:18 233:11 235:19 124:18 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050439 [218.75 -a.m.] 218.75 242:15 243:6 221 184:2 224 125:20 226 125:21 227 125:22 22nd 165:21 209:9 232 125:23 234 125:24 24 159:6 234:3 2400 123:14 241-5070 125:7 241-6750 125:6 248 122:13,14 25 210:17 251-2300 122:6 253-8695 124:9 254-1061 123:16 254-1999 123:17 258-1439 122:14 258-1616 122:13 27th 143:13233:11 28 174:6______________ 3 3 143:13 192:17 208:20 3.75 242:6 3.a 178:17 180:9 30308-2216 121:6 243:5 30309-3424 124:7 303353 209:10 303378 210:16 303482 209:11 305 123:4 31 118:12241:17 314 120:8 125:6,7 314-480-1500 120:7 314-480-1505 120:9 31st 119:23 127:22 174:12 238:3 239:15 323-2197 121:19 346 178:16 35203 122:5 35203-2618 123:15 36 235:4 237:2,3 392112 214:17 392113 215:3 392118 216:25 392264 214:18 392343 225:10 392485 233:12 392486 233:12 392491 235:19 392492 235:20_______________ 4 4 193:11 197:1 222:12,18 400 121:15 4000s 175:17 404 121:8 124:8,9 44114-1304 120:17 241:24 242:5 44115-1126 124:16 462055 164:22 166:16 462197 164:22 166:17 462477 163:25 462620 163:25 468.75 242:6 479-8545 120:18 479-8780 120:19 480-1818 120:8 48304-2949 122:12 4900 120:15 241:22 242:3 492.590 241:14 5000 224:2 5000s 175:17 515 125:4 243:15 5200 121:4 243:3 5335 123:4 543174 217:22 543175 219:7 543178 219:16 543179 221:7 543336 217:22 55 190:19,20 57.03 241:14 577126 227:7 577150 227:7 6 6 221:21,23 600 119:21 120:5 121:5,14 242:13 243:4 627 149:18 63101 125:5 243:16 63105-3441 120:6 242:14 650 124:15 686-4843 123:7 686-4844 123:6 6th 231:5__________________ 7 700 125:4 243:15___________ 8 8 141:19 8:49 119:22 127:22 812 124:15 85203 121:16 86.00 242:7 881-7000 124:8 885-3489 121:7__________________ 9 9 125:13 138:1,4,10 141:19 9202 123:7 9205 123:17 962-6688 121:8 986-5023 121:18________________ a a.m. 119:22 127:22 166:2,10 208:17,20 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050440 [absorb - aroclor] absorb address amendment (cont.) appendix 198:12 207:13 127:25 241:19 222:7,20 184:16,24 202:17 accept addresses amendments applied 160:24 142:19 148:16 170:25 218:14,25 152:25 accepted adjoining 222:4 applies 217:3 221:10,17 222:8 196:11 amount 222:9 accident administer 152:3 189:19 204:6,7,8 apply 184:25 239:6 216:5 193:19 accomplishing administrative amsouth appointed 159:18 162:14 123:14 142:15 143:2 accumulates advise analysis approach 200:5 214:11 180:15 184:20 205:16 148:24216:10232:12 accumulation advisory analytical appropriate 196:23 236:16 177:12 180:21 188:1 195:22 accurate affirmative analyzed approval 156:8 238:5 207:8 218:24 180:10 188:8 175:18221:16222:5,7,9 accurately aforementioned anchor approvals 210:2 215:6 219:2 239:25 124:12 129:1 219:16 acid aforesaid angle approve 191:25 205:8 207:2,3,3,11 239:14,14,20 189:14 171:5 222:12 207:14 afraid ankle approved acknowledges 149:15 194:23 141:25 180:11,13229:18 238:4 age anniston 236:9 acquiring 167:16 129:12 130:14,16 131:12 approving 153:19 202:6 agent 131:13,25 132:5 133:15,19 221:17222:14 action 152:6 154:3,5,17,22 155:6 134:1,8,11 139:16,21,23 approximately 180:21 156:7 211:23 140:10,12 141:21 142:24 139:12,13 145:18 182:10 actions agents 146:10,21,24 147:6,7,9 archive 157:24 202:11 149:8 150:11 151:19 153:7 167:24 active agreed 153:10,15 154:25 155:21 archives 167:23 168:4 163:19 167:2,14,21 168:10 168:6,7 activities agreement 171:21 174:7 178:22 area 140:6 141:4 161:21 173:15 240:6 183:16,22 201:23 202:1 130:25 133:7 135:24 181:12232:16 ahead 209:22 210:3 219:3 220:23 136:14 145:2 150:4 156:3 activity 208:12 227:22 228:5 229:19,20,22 157:16 168:8 181:23 182:8 135:19 142:13,21 148:11 air 233:23 235:2,2 182:11 191:3,12,13,23 157:21 158:16 175:7 185:9 158:8 answering 193:19 197:22 200:7 235:2 186:20 219:24 232:1,2 al 167:15 areas actual 118:2,6 119:5,10 121:16 answers 135:10 161:23 183:22 135:15 151:13212:18 122:5 123:15 128:3,3,23 166:18 240:4 195:22 199:17,18 200:10 add 241:6,9 anticipated aroclor 218:8 alabama 243:11 136:14 145:3 165:9,20 added 119:2 128:4 239:10 241:3 antiquated 169:23 171:7,16 172:16,19 180:18212:24 213:16 alive 168:4 174:11 175:10,16 177:19 226:5 231:11 177:16 anybody 177:20,22 178:4,19 179:11 adding allow 152:12 176:18 180:17 181:6 182:3,7,11 207:10 132:23 189:12 anyway 183:7 185:8 186:19 187:5 addition allowed 127:7 164:18 187:3 188:22 187:10,15,23 188:5 191:23 162:1 182:1 197:19 216:23 186:4 215:23 appear 192:1,1,19 193:3,12,14,15 225:22 226:9,11 alston 175:3 218:17 225:15 194:17 195:8,13,19 196:13 additional 124:4 128:10 appearances 196:14 199:21 203:16,19 129:11 alston.com 120:1 203:23 204:12 205:19,20 additions 124:10 appears 209:7 213:11,22 222:25 170:25 amendment 151:9 174:5 218:4 233:9 223:12,12 226:14,19 additive 142:9 143:13 174:6 216:25 appendices 229:13,16 231:9 232:19 180:19 217:4 221:7,9,14,20 222:6 170:24 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050441 [aroclors - bottom] aroclors assuming back (cont.) better 131:7 174:12,14,23,25 206:4 208:19 233:25 132:22 175:9,12 203:20 209:23 atlanta bags big 210:3,20 214:16 215:7 121:1,6 124:7 128:18243:5 187:12 200:24,25 180:24 223:1 217:2,14,21 223:17,18 atlantic baker bill 224:8,10,11,13,14,25 225:4 124:5 122:19 220:12 167:5 220:16 225:4 230:12 231:23 atmospheric bakerbotts.com biphenyl arrange 184:17 122:24 130:11,16,24 131:2,13,18 156:20 attached based 132:4,12 133:7,10 134:7 arranging 206:3 134:24 142:16 171:18 135:16,23 136:13,20 137:1 228:13 attaches 172:8 209:25 137:6,9,16 141:8,13 144:24 arrival 204:8 basic 145:2,20 149:13,25 150:7 143:14 163:8 192:23 213:8 attapul 228:15 157:13,16 158:16,21 159:6 arrive 180:2 basin 159:10,15 160:3 164:14 150:11 attapulgus 185:23 186:5,7 168:23 169:2,13,19 203:17 arrived 177:23 178:3,7 179:18,24 basket 204:2,4,9 205:1 230:12 130:14 131:17,23 133:6 184:4 226:2,4 212:10,11,21 biphenyls 135:13,17 139:18,21 attempt batch 131:4,8,10 132:2 134:10 141:17 144:16 145:14 232:12 135:3 210:7,7 212:9 223:19224:11,12,17,19 146:11 147:17 148:8 155:7 attendance batches bird 171:21 176:22 177:14,15 242:7 222:11 124:4 128:11 177:15 184:9 193:7 195:12 attended bates birmingham 203:23 239:12 138:10,12 163:25 164:22 121:16 122:5 123:15 aside attends 166:16 169:23 209:10 biswas 164:11 169:20 203:15 166:7 214:17 217:21 227:6 122:18 127:4 129:2,2 213:25 217:12 222:22 attention 233:11 235:19 bit 226:13 149:10 185:2 197:2 210:16 beach 137:3 145:13 189:10 asked attorney 200:23 black 133:23 136:5 137:5 162:11 240:8 bed 160:22 161:2 199:19,22,23 180:1 221:8 attorneys 217:1,6 blend asking 239:14 240:10 began 179:11 180:16 182:18 129:10 151:13222:2 august 130:4 206:17 224:14 118:12 119:23 127:22 beginning blended aspect 169:23 174:1,13 238:3 139:14213:11,14 178:22 206:15,16 213:19 239:15241:17 begins blending assign authorized 166:10 208:20 172:17 151:25 239:6 behalf blends assigned automated 119:19241:17 169:23 171:8 174:11 141:23 144:7 148:10 232:9 believe 177:19 178:5,19 203:19 175:11 195:19231:19 available 145:11 159:5 178:24 180:8 block assignment 152:12,18,20 198:9 201:2 184:5 148:4 182:12231:2 145:12 176:8 avenue belong blockage assistant 122:4,20 123:4,13 161:11 158:5 162:12 aware belts blockages associate 141:2 142:13 156:11 232:9 157:20 158:24 159:1,17 136:19 137:1 140:5 150:13 157:15,18 179:24 193:6 beneath bloomfield 151:3 169:6 190:18 220:9 208:5 212:23 185:24 186:15 191:3 122:11,12 226:21 227:17 awhile benzene book associated 131:20 159:22 132:7,13,18 198:11,13 197:7 133:13,18 134:19 150:8 axis benzol booties 169:17 182:19,20 132:14,23 194:22 195:2,8,13,24 196:1 associating 141:4 assume 171:11 b best 196:2,17,18 back 129:8 144:16 145:16 166:9 180:23 184:15 186:2 195:11 203:16 206:4 137:24 140:2 147:16 149:4 boss 150:15 176:23 199:18 172:25 227:17 230:5 231:8 232:7 bottom 148:3 174:18 189:6 190:5 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050442 [bottoms - clay] bottoms 187:23,24 188:5,6,8,10,15 189:4,22 190:10,13,15 botts 122:19 branch 172:19 brass 122:1 128:24 break 127:19 208:8 brief 166:23,24 bring 161:18210:24 218:10 bringing 193:23 201:3 brought 133:21 233:25 brown 219:22 220:2,4,7,10 bruce 144:4,5,14 bryan 119:23 239:4 240:15 243:22 bubbled 223:23 bucknell 146:4,5,20,24 bucknell's 146:19 building 124:15 232:17 234:24 buildings 228:14 buildup 158:20 built 230:19,22 232:14 bunch 235:25 burn 185:10 burns 185:1 business 243:12 butzel 122:10 butzel.com 122:15 buy 156:7 byproduct 137:18 192:1 205:4 byproducts causes 137:16 157:20 c caution call 132:22 141:23 152:18 158:10 159:14 173:13 182:4 186:8 189:14 194:20 187:4 cautioned 239:18 caxton 198:3 199:13 205:4 236:14 237:12 called 132:25 133:1 135:2 175:8 186:6 205:5 207:2 calls 197:13 124:15 cc 235:25 cea 229:18 231:9 233:11 235:18 ceased car 181:4,5,15 196:14,15,21 carbon 157:13 158:20,24 care 185:7 186:18 careful 187:4 218:21 cement 193:12 center 124:5 146:13 182:5 centered 151:23 certain carefully 239:17 carondelet 136:2,5 154:2 204:12 205:18 207:9 220:1 certainly 119:20 120:5 127:25 242:13 164:4 certificate carpenter 228:9 241:12 certified carpenters 228:6,10 carpentry 228:15 carried 228:9 cars 178:22 180:12 181:1,2 119:24 240:16 certify 239:7,7 240:7 cessation 213:22 cetera 193:13 chain 182:1 203:9 case 198:4 challenging 118:4 119:8 128:2 222:10 236:11 239:19 241:8 catalyst 208:3,5 210:21 211:3 212:18213:4 197:25 chance 170:2 change 156:24 192:5 208:13,14 catch 185:23 186:5,7 catching 185:7,12,13,15 categories 228:16 213:12 changed 153:14 223:23 changeover 216:21 changes cause 128:4 157:19 159:15 237:2 153:16,17 180:15 characteristics 239:8,11 caused 175:15 charge 239:22 156:19 charges 241:13243:10,11 checked 205:9 chemical 133:3,4 134:25 136:9,23,25 137:12,13,14 151:11 157:19 165:11 169:7 177:12 224:21 chemicals 136:24 139:3,12 140:8 173:14 179:25 195:1 chemist 134:20 chemistry 132:7 182:14 chief 197:6,13,14,17,18,25 children 150:13 chloride 204:24 205:2 212:17 213:4 213:15 chlorinated 131:3 218:7 224:11 chlorinating 204:19215:14 chlorination 208:4 210:20 211:4 215:15 215:18,19223:14,16 224:23 226:22 chlorinator 185:8 chlorine 204:3,3,5,6,8,22 205:1 207:24,25 215:25 216:5 224:19 chuckle 161:24 chuckled 162:4 circulating 185:8 city 182:12207:17,18,22 231:2 239:3 243:24 civil 239:8 clamp 190:21 clarify 166:13 classified 180:6 clay 178:2 180:4 225:22,25 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050443 [clay - couple] clay (cont.) coming confident contractors 226:2,3,9,11 137:6 207:5 205:19 234:20,23,25 235:1 claylike command confused contraption 184:5 198:4 174:16 223:2 clayton comment confusion contribute 127:25 171:2,4 217:8 134:24 152:2 clean comments connected control 196:22 197:15 198:5 210:19 150:24 189:8 175:2 199:10,12200:12,18 commission connection conversion 201:17 238:15 243:25 157:13 158:16 163:18 137:5,10,12,14 cleaned commissioned 169:12,16 234:20 conversions 157:17 197:3,5 198:7,9 239:5 connects 137:13 cleaning committee 197:17 converter 158:1 162:3 197:9 198:7,15 142:8,10,16,23 143:1,2,3 considerations 136:21 137:7 200:6,10 201:7 202:4 160:15 162:8 175:19,20 142:19 converters cleanup 176:5,6,7 considered 136:3 159:19 197:16,22,22 199:1 common 142:18 conveyed 200:8 133:4 136:18 142:14,14,21 consistency 197:21 cleanups 205:7 214:23 175:14 conveyor 197:24 commonly consistent 232:9 clear 207:2 210:6 cooled 130:19 158:25 communication contact 187:11 188:25 Cleveland 197:19 156:6,21 cooling 120:17 124:16 241:24 company contain 169:15,17 242:5 124:2 125:3 151:11 153:13 230:20 cooper close 194:19,20 195:7,24 201:3 contained 123:12 128:20 130:21 136:4 216:1 221:4 133:11 201:10 226:6 copies clothes compile container 167:21 171:3 218:21 196:10,11 148:15,18 185:15,18 188:3 189:1,9 copy colgan compiled 190:12 199:4,5 215:17 209:14210:15242:6,15 228:2 164:21 166:15 containers 243:6 collect complete 187:14 188:24 201:19 corder 189:15 216:20 240:3 contaminated 177:6,7 collected completed 199:1 corner 188:2 205:13 135:4 166:24 197:22 cont'd 142:7 201:2 232:11 collection 205:13 125:10 corporate 136:6 148:18 191:24 completion content 227:19,21,21 231:17 collections 216:1 224:20 correct 136:2 composed contents 131:4,8,14 132:18 134:9 color 143:3 212:4 140:13 143:6 155:25 156:8 175:14 180:19 199:19,22 conceive context 159:7 174:2,3,8,9 179:2,5,6 200:22 204:16 205:17 168:5 150:25 156:1 175:21 190:11 196:15,16200:10 colored concentrate continue 208:1,2 212:18,19 213:24 200:22 218:4 128:1 161:15,19 163:5 215:3,5 218:19 219:5,19,20 Columbia concluded continued 221:14 224:6,7 226:11 122:21 130:3 129:4 155:20 161:20 240:3 column concrete 213:20 correctly 223:6,7,8,24 181:16,20 191:4,7,9,18,19 continues 207:6 239:24 columns 193:20,21 194:12 197:19 205:8 214:19 cost 136:3,11 223:9,20 condensers continuing 151:11 152:5 combined 169:16 162:6 165:1 170:10 196:20 counsel 205:1 conditions 211:1 221:6 225:14 227:6 120:1 128:6 240:1,2,6,8 combines 193:13 228:25 233:9 county 204:4 conduct contractor 119:21 239:13 comfortable 136:12 205:15 234:16,18 couple 164:6 161:13219:15 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050444 [course - discard] course 181:19207:13243:12 court 119:1,24 226:25 228:20 233:5 235:12 239:10,11 240:16 241:1,2 cover 163:16 covered 189:2 209:24 covers 218:6 create 159:22 creating 203:4 crew 200:8 cross 183:6 crouch 140:25 crushed 187:11 currently 128:3 curt 125:2 127:23 custodian 142:5 custodians 161:8 custody 241:19 customers 171:19 172:18 cut 199:14 cuyahoga 124:17 cv 118:4 119:8 128:5 241:8 d damage 196:5 184:25 127:22 163:16 174:15,24 209:9 217:2 233:10 238:5 dated 138:13 143:13 166:15 174 6 229 14 235 19 dates 139:14,14 datron department (cont.) detailed 124:12 128:25 145:6,9,20 147:12,17 170:13214:25 day 148:10,14 149:3 152:17 details 119:23 159:7 195:23 198:1 154:9,11,18,19 158:4 132:3 137:8 170:16 237:5 235:8 237:12,19 238:3,13 168:14 172:19 177:10,20 deterioration 239:15 240:12 243:19 177:21,22 191:21,23 193:4 194:25 days 194:15 195:18,18 197:20 determine 159:7 161:14 227:19,21,25 228:17 165:2 204:14,15 226:8 day's 231:18236:15,18 determines 159:19 departments 204:7 dc 145:5 develop 123:5 departure 148:20 dealings 192:25 developed 155:23 depended 134:21 153:9,11 170:20 deceased 201:12 221:13 145:17,17 depending developing decided 132:6 159:18 180:19 134:17 160:16,25 168:2 175:5 depends development decision 158:5 180:14 171:2 219:24 220:1,14 175:7 196:4 197:14 198:2 depletes develops dedicated 212:14 148:24 198:25 deponent device defect 240:5 186:12 157:22 180:14,16,20 deposition dial defects 118:14 119:18 128:1 130:8 127:14,14,16 180:21 166:1,8,11 208:16,21 difference defendants 237:15,18 238:3 241:13,16 172:22 180:24 223:11,13 119:11,19241:10,17 depositions 223:15224:10,15,16,18 defendant's 239:7 different 125:13,14,15,16,17,18,19 deposits 143:4,4 145:13 148:24 125:20,21,22,23,24 138:4 158:21 152:6 154:18 165:18 163:21 164:23 166:4 170:4 depth 171:18 178:21 182:16,17 208:25 214:6 217:16 140:4 189:24 190:2,8 210:12 225:11 227:2 228:21 233:6 describe 215:11 220:8 224:21,25 233:13 235:14 159:24 187:24 189:10 difficult defense 197:7 203:1,21 222:24 143:15 198:12 123:10 128:21 229:17 231:1 difficulty defined described 137:11 150:9 167:15 156:16 184:5 197:1 217:1 235:18 dii definition describes 129:2 135:18 136:23 diphenyl degree descriptions 164:21 166:15 204:7 223:15 214:22 dips degulis desegregation 181:3 124:14 160:20 direct deliberately designated 120:8,18 121:18 149:10 137:19 135:6 185:1 197:2 210:16 deliver designed directed 201:1 158:7,10 215:23 223:21 189:12 207:7 delivery desired directly 201:12 242:8,16 243:7,10 136:24 203:2 147:14 181:17213:16 dempsey destruction director 120:14 128:9 241:21 242:2 190:14 139:2,11,15,20,22 140:7 department detail discard 129:24 141:20,21 143:23 159:2 178:13 223:24 195:23 144:6,9,12,14,19,22,25 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050445 [discarded - eppenberger] discarded document (cont.) dry effort 188:11,12,16 190:8 198:15 165:3,5,6,7,10 166:18,21 225:25 134:20 135:5 198:16 212:23 166:24,25 167:3,9,10,11,12 dsw either discharge 168:16 169:20,21 170:1,8 138:11,11,25 142:6 143:14 146:20 147:2 177:3 204:9 184:17 170:10,13,16,20,22,24 148:2 149:13 151:9 163:25 205:11 206:12,18,19 240:8 disconnect 179:20 192:15 202:14,22 163:25 164:22 166:16,16 electric 158:11 203:15 208:24 209:5,9,17 169:24,24 173:24 174:5,18 178:20,21 203:3 discontinue 209:19,24 210:1 214:4,11 178:10 182:16 184:15,23 electrical 175:6 214:14,15,20,21,24 215:6 192:17 196:25 202:16 217:1 discontinued 215:11 217:11,20 218:1,4 209:10,10210:16214:17 elevated 174:12,14,23 218:12,15219:1,7 221:21 214:17 215:3 216:24 190:22 224:6 discover 222:17,22 225:8,9,19,23 217:22,22 219:7,15 221:6 ellenberg 157:22 226:25 227:6 228:19 229:3 225:10 227:7 233:12 168:18 discovered 229:4,6,9 231:4 233:4,18 235:19,20 em 180:15 233:20,24 234:2 235:8,11 due 195:16 196:20 discuss 235:22 193:22 232:7 emotional 151:6 documentation dukes 160:21,23 discussion 222:10 122:3 emotions 134:1 229:15,23 236:25 documents duly 160:25 discussions 130:5 134:13 142:5 167:22 239:5,17 employed 133:19,22 168:1 170:14 208:6 209:21 dump 228:6 disposal 210:1 188:24 201:1,1,3,14,15 employees 184:17 189:3 190:14 dodge dumped 193:17,22 194:17 232:3 disposition 121:11 128:14 201:8 234:15 217:2 dog dumps emptied distance 197:3 198:17 190:13 182:10 doing dur ended distances 187:6 198:6 211:17 129:13,14 162:3 191:24 181:8 drainage durgin engineer distillation 191:22 192:2 168:20 176:9,16 227:18 236:20,23 205:8,12 222:25 223:4,5,6 drained duties engineering 223:20 224:5,8,9,15 225:1 191:19 145:1 150:24 163:18 227:19,21,25 231:18 distillations dramatic e 236:15 136:12 distilling 204:20 159:14 draw 189:6 eaddy 121 2 parlipr ensure 210:6 entering distills drawing 133:12 172:15 175:19 150:13 204:20 distinction 199:3 149:12 187:23,24,25 189:4 drawn 143:7,10 180:12 182:2 181 '25 221 '8 231 '3 early 150:15 175:5,6 186:2,16 entire 135:18 149:21 161:5 entirely distinguished 199:6 distribute 236:12 191:12 206:2 drill 158:12 drip earth 177:24 178:3,7 179:18,23 179:24 183:25 184:4 226:4 earthen 224:21 entirety 189:21 entitled distribution 186:4,10,14 191:14,14,17 191:6 164:20 169:22 214:16 138:25 173:24 drips district 186:3 119:1,2 122:21 128:4 239:9 dross 239:10 241:2,3 150:22 easily 198:9 east 130:20 217:20 entrainment 169:1,3,6,9 environment division drum edwin 175:2 139:3,12 140:8 document 182:2 190:17,19 191:1,4 drumming 130:1 effect ep 184:1 138:1,8,9,11,13,16,19,21 230:2,21 232:5,15 1QQ-14 eppenberger 138:24 142:9 149:14,22 drums 151:14 152:15 153:1,2 180:12 182:2 190:18 163:15,17 164:2,7,9,19,20 198:23,24 201:20 effectively 166:19 119:20 120:4 127:24 239:12 242:12 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050446 [equipment - foregoing] equipment expanding familiar (cont.) 136:8,23 157:16 159:21 226:20 150:21 157:12 158:20,23 202:18 expansion 162:20 164:12,13 169:1 escape 226:14 229:13 231:10 177:23 216:9 218:3 175:2 233:1 234:21 235:5 family especially expect 224:22 159:21 194:3 150:2 229:10 far esq expectations 132:9 197:24 213:10 120:3,13 121:2,12 122:2,9 204:18 farm 122:18 123:2,11 124:3,13 experience 229:23,24 230:6 231:20 essence 134:25 142:17 204:10 232:21,22 234:10 232:13 experienced favor et 204:11 242:1,11 243:1 118:2,6 119:5,10 128:3,3 experiment fax 128:23 193:13 241:6,9 222:5 120:9,19 121:8,19 122:14 eugene expires 122:23 123:7,17 124:9 129:18 238:15 240:18 243:25 125:7 events explain features 159:15 130:13 150:2 eventually explosion feel 189:2 201:20 205:3 206:16 192:19 164:6 everybody explosions felt 127:1 160:2 192:18 193:1 196:3 ewg explosive ferric 128:5 142:20 212:17213:4,15 exact expression field 160:10 161:13 165:7 234:6 136:17,22 237:1 exactly extent fifth 211:11 157:21 174:4 examination extra fifties 125:10 129:4 202:14 186:2 195:11 examined f filings 239:17 example facet 1864 211:13212:24 fill 143:17 152:3 175:3 198:11 221:20 228:13 facilities 194:13 229:16 230:12,21 190:20 filled excluded 231:11 232:10,16 234:7,24 152:10,11 161:9 exhibit 125:13,14,15,16,17,18,19 facility 181:6 182:3,7,11 192:20 195:9,20 201:7 232:3,13,19 filling 151:22 filter 232:9 125:20,21,22,23,24 138:1,4 138:10,17 163:14,20,21,24 164:19,23 166:4,14,19,21 169:22 170:4 192:16 fact 172:10212:17214:23 21611 223 16 229 24 230 19 179:25 184:6 filtered 180:7 filtering 203:18 208:24,25 214:5,6 fails 180:3,5 217:15,16218:2 225:10,11 227:1,2,8 228:20,21 233:5 233:6,13 235:12,14 exhibits 182:25 failure 15920 fairly final 171:1 find 184:16 196:23 125:12 133:4 finished exist 151:7 falls 193:11 197:1 170:22 188:1 205:22 finley existed 160:25 194:15 familiar 134:13 135:15 136:15,17 130:1 fires expanded 156:22 226:19 231:11 137:15,17 140:3,4,5,25 141:10 146:1,15 149:22 160:2 193:3,9 firm 241:19 first 129:13 131:3,5,7 133:18,25 138:14 139:1,7 141:6 143:21 146:8 150:17 154:21 155:13 156:17 157:14 170:1 171:10,14 172:1 176:24 179:16 185:5 185:7 194:9,11 208:3 210:9 221:13 229:22 233:22 235:25 239:17 fit 211:10 five 216:24 222:11 flaking 230:11,20,20 232:15 flexi 159:3 flexibility 189:12 floor 186:5 191:9,18,19 193:13 193:15,20,22 194:10,11,16 196:24 199:21 flooring 181:17 floors 193:12,14,19,21 194:6,7,8 194:8,9,10 200:2 flow 149:12,23 215:24 flowed 215:16 fluid 180:18 189:13 flush 158:8 fmc 123:10 128:20 focus 193:13 follow 191:22 followed 141:24 following 185:6 186:17 197:4 237:19 follows 197:12 force 160:20 161:5 foregoing 238:2 239:21,23 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050447 [foreman - heading] foreman full going h 171:12,13,15 172:22,24,25 195:19 240:2 127:2,7 130:12 137:25 hale 198:1,2 function 141:23 148:23 156:23 222:20 foremen 136:18 160:11 162:2,2 163:14,16 half 161:7 further 164:18 169:20 173:13 150:17,19208:11 forgot 155:23 190:7 240:7 174:14 178:10 182:4 halfway 210:22 230:6 g 189:14 194:20 199:13 149:14 forgotten ga 205:4 206:19,21 207:7 halt 154:21 211:7 form 121:6 124:7 243:5 gale 208:23 210:24 214:3 217:13 225:9 226:24 159:16 halted 132:14 151:10,15,16,22 152:2,9 204:21 222:3 format 165:8 209:20 formed 123:12 128:20 gallon 190:19 galvanizing 203:10,12 228:19 229:15 233:4 234:10 236:14 good 129:6,7 206:5 237:11 gooseneck 159:11,13 hand 137:25 142:7 163:14 164:18 169:21 182:19 208:23 214:3 217:13 225:8 204:25 forming gary 219:11 189:13 gore 225:9 226:24 228:19 233:4 235:11,24 240:11 243:18 202:25 forms gas 169:2,8,10 205:2,10 206:21 125:3 243:14 grade handed 165:17 166:17209:14 157:8 forth 158:2 239:24 forties 195:11 forward 153:3 foundries 201:23 202:1 foundry 124:1 128:12 202:4 four 208:9 231:12 fourth 173:24 230:18 fractionating 136:3 frame 206:21 207:1,6,14,25 223:22 gases 174:11,13,22 175:9,11 217:1 grating 206:23,25 gateway 193:20 194:7,9,10,13 gravity 125:3 gene 219:18 general 132:1,4 151:5,6 178:20,21 200:12 203:3 231:16 236:15 generally 204:16 205:17 grease 199:14 great 180:22 181:9 204:7 green 119:3 241:4 grind 134:19 175:1 178:19 180:6 194:11,12 197:23 234:21 211:12 ground generated 135:8 187:11 190:24 group gerald 123:3 128:16 130:24 handle 187:2 handled 142:22 158:2 197:8 handwriting 235:24 handy 168:3 happen 152:9 159:25 160:1 163:12 169:7 180:13 happened 132:9 135:10 195:11 harbert 123:14 hard 139:1 harmful 213:2 218:18 229:13 231:11 frank 177:9 getting 184:14 134:20 135:5 145:23 142:20 147:15 152:7 161:9 162:22 harold 168:1,4 176:5,19 204:9 146:17 185:2 frankly 211:7 free 162:1 frequency 135:2 fresh 212:22 front 219:22 220:5,11 228:8 gii 122:17 give 184:21 202:18 given 231:18 guards 161:10,10 guess 153:25 197:22 238:5 240:4 go 127:19 132:9 152:10 156:7 156:23 164:17 165:22 174:4 184:23 194:4 197:24 221:7 227:15 guessing 141:7 145:12 146:9 163:1 182:12 195:10 guide harvey 177:2,3 haupt 148:4,5,6,6,7,25 149:2,5 haupt's 148:7 haydel 172:3,4,10 hazardous 185:6,9 186:18,20 218:15 fuhrmeister 198:20 200:22 201:15 202:15 208:12 216:24 210:6 guys head 176:16 207:8 218:24 147:13 148:10 fuhrmeister's 236:10 goes 227:24 227:20,24 heading 147:15 187:19 198:3 206:15 174:20 202:17 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050448 [headquarters - internally] headquarters hit indicates (cont.) 135:8 143:10 152:23 228:16 ice 214:24 217:3 222:19 health hmm 193:13 indication 142:21 135:25 137:4 151:12 idea 172:2 hear 156:14 168:25 172:4 176:2 134:21 145:18 155:20 indicator 129:12 193:10 182:9 186:24 189:7 198:25 identification 199:20 222:4 heard 211:25 218:24 220:18 138:6 145:23 163:23 individual 133:18,25 141:11 150:6,23 221:12 227:9 164:25 166:6 170:6 209:2 129:14,22 130:20,22 134:6 150:25 151:2 157:14 202:2 hoffmann 214:8 217:18 225:13 227:4 134:18 140:23 141:22 203:14 213:18 226:10 124:14 228:23 233:8,15 235:16 144:7 145:23 146:14,16 heats hold identified 148:22 153:12,21 156:19 204:21 157:6 143:16,19 146:14 147:1 168:9,12 172:5 176:11 heavy home 172:10 173:25 220:19 198:6 202:8,11 209:23 192:1 196:24 identify 219:9,11,14220:8,12 heel hose 128:6 134:6 138:22 172:14 236:10 196:23 189:8 200:2 identifying individuals held hosed 130:22 130:23 134:23 142:15 165:11 220:25 191:21 ii 143:7 145:19 152:1 155:2 help hoses 118:15 119:19 123:11 161:8 162:7 168:2 175:22 162:3 176:9 179:22 198:12 189:11,11 iii 175:23 177:18 198:11 234:2 hosing 178:12 200:11,15222:12 helpers 200:4 immediately individual's 154:8 hosmer 140:16,18 197:4 165:15 helps 140:11,15,20 impediment industries 164:9 179:17 hot 157:23 122:17 124:1 128:11 129:3 henderson 187:1,3 188:2 impossible inerteen 162:20,21,25 163:1 hours 175:3 178:25 hereinabove 119:22 159:6 197:15 impress inform 238:6 204:11 160:16 154:2,4,7 hereto house impurities information 238:4 232:14 168:23 207:9,12 152:1,2,19 170:13 184:21 hereunto housekeeping inch 197:11 204:10 243:18 200:3 234:3 235:4 237:2,3 ingredient hesitate howard incidences 156:12,17 175:4 130:18 220:9 139:9,10 159:25 ingredients hesitating hubbard incident 171:18 172:17 148:17 146:15,17,21,23 159:13 initial hierarchy huckaby include 204:22 216:2 144:11 122:3 136:3 145:3 initially high hundred included 206:23 207:5 216:8 158:8 185:10 204:22 164:5 161:6 initials 224:22 huron increase 182:15 235:25 236:3 higher 122:8 124:15 231:21,22 232:3 installed 224:9,20 husch increased 230:3,13,16 232:2 highways 119:20 120:4 127:24 232:8 instituted 175:5 239:12 242:12 increases 175:7 hill husch.com 224:23 instrument 129:18 120:10 index 193:21 194:14 hilliard hydrochloric 125:9 intended 173:8,9,10 207:1,2,6,11,14 indicate 174:23 205:20 hills hydrogen 172:11 intent 122:12 132:8 204:5,24,25 205:2 indicated 206:25 hinckler hydroxide 156:2 159:5 172:20 178:24 interested 139:3 205:6 182:17 206:18 230:7 152:13 240:9 hired indicates internally 176:8 171:10 175:18210:9 223:21 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050449 [interpret - lead] interpret jerry kind (cont.) label 222:17 127:23 220:7,9 189:9 190:12,17 194:15 169:21 introduce jesse 196:22 198:19,24 216:3 labeling 158:7 204:3 163:6 219:19 232:12 232:10 introduced jim kinds labels 203:4 204:6,7 207:24,25 128:10 151:6 194:7 203:5 204:17 138:10 226:23 introducing jj 238:23 kitchen 196:24 laboratory 134:21 180:11 185:19 204:5 205:6 jlanglais kleeghorn 188:3 189:18204:14,14 introduction 124:10 141:9 205:15 215:14 226:21 job kleghorn lack inventory 134:19 148:13 196:3 234:5 141:9 132:22 153:24 154:1 234:14,17 knew landfill involve john 180:8 188:17,18,20,22 189:2 152:4,5 171:17 198:2 122:2 127:9 128:24 140:19 know 198:22 involved 143:22 147:5 127:2 130:2 131:5 132:20 landfills 131:20 141:4 144:9 151:24 join 134:2,10 135:5,9,14 139:1 188:13,17 198:17201:21 152:7 157:6,25 172:16 132:7 139:7 140:7,11,22 141:6 landwehr 177:11,11 195:1 200:13 joined 142:10,12 144:14,22 145:1 175:23 219:8 215:15 228:13 229:18 136:24 145:4,6,14,15 147:23 lane 234:23 joining 148:17 149:5,7,21 153:17 175:4 involving 127:2 154:11 155:9,13,14,17 langlais 165:8 170:15 jordan 156:4 159:23 160:14,18 124:3 128:10,10 iron 119:24 127:24 239:4 162:24 163:11,12 165:13 large 151:3 202:25 210:23 211:3 240:15 243:22 166:25 167:19 168:18 198:8 211:11,12,13,14,19212:1,2 joseph 169:12,15 171:20 173:20 larger 212:6,7,10,11,16,20,22,24 120:3 128:22 174:13,22 175:19 177:3,6 134:23 212:25 213:3,16 joseph.nass if 177:16 180:2,5,12 182:14 late issuance 120:10 184:2,4,8,20 185:9 186:7 139:23 149:3 195:12 jtaylor 186:14 191:19 192:12 laughs issue 123:18 194:4 195:10 200:20 203:1 162:5 160:21,23 168:22 186:3 judge 203:12 204:9 207:12 209:5 laughter 194:20 195:8 202:24 203:2 119:3 241:4 211:19,22 212:1,3,5 213:7 196:19210:25 issued july 213:11,15217:6 218:7 lavey 165:20 169:23 171:1 143:13 174:6 217:21 219:1 219:23 220:2,4,10,25 221:3 120:13 125:10 127:1,7,11 194:22 195:24 196:2,18 jurat 222:20,21 223:5,7,24 127:15,20 128:8,8 129:5 209:8 215:12 219:1 242:7 225:16 226:3,12 227:12,14 138:9 163:24 164:3 165:17 item k 228:2,5 229:17 231:1,20 165:22 166:12,22 167:7 139:2 140:1 184:25 186:17 230:1,11,18 karen 122:9 127:11 232:5 234:12,13,25 235:1,3 170:9 208:10,14,22 209:3 236:2,21,23 237:5 209:18214:2,9,15215:1 items 209:24 231:12 it'll 152:12 159:20 184:15 keep 153:2 156:10 168:3 186:12 1966 keeper knowing 172:13 knowledge 134:7 141:16 142:16 217:19 222:1 226:24 227:5 228:18,24 229:5 233:16 235:7,10,17 237:10,12 law iv 142:3 146:20,23 152:1 191:9,11 123:3 128:15 210:18 jack 141:9 j keeping 141:23 215:17 kept 153:24 167:13 196:3 224:5 192:22 193:1 195:9 201:22 201:25 202:3 krummrich 134:3 229:21 lawns 200:12 lawrence 219:9 james 224:8 1 lay 124:3 220:21 january key 120:15 159:21 215:17 l.l.p. 120:14 122:19 241:21 130:10 203:22 lead 235:19 240:18 243:25 jarred 241:22 242:3 kind 242:2 lab 131:22,24 133:11,13,15,18 133:25 134:2 150:4,5,6,8 123:11 128:19 151:10 152:19 160:17 165:10 180:24 186:25 180:13 150:22 164:12 185:5 203:12 232:2 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050450 [leader - materials] leader list (cont.) looking manager (cont.) 145:24 219:22 220:5,12 219:16 135:23 179:14 182:23 167:1 168:11 170:18,21 leak listed 192:16 199:24 205:16 173:25 188:15 192:3,10,19 197:22 140:1,25 143:18,24 147:4 218:25 192:23 193:4 207:19 213:5 leaks 174:18 185:7 219:21 loop 214:12215:4 218:18 194:1 231:12,15 157:3,5 219:18220:14,19221:1 led little lose 226:15,18 227:16 228:7 162:8 231:18 137:3 180:16 189:10 132:8 229:10,14 236:8 lee live lot managing 122:1 128:24 192:5 193:16 144:8 left living lots manner 139:23 145:10 147:20 134:6 145:15 147:24 149:5 161:11 180:25 207:8 210:2 218:24 149:3,8 155:11,21 163:6 155:18 163:12 177:4 louis manufacture 171:23 173:18 182:19 lie 119:21 120:6 125:5 146:13 131:7,7 164:20 166:14 184:11 193:9 213:20 119:20 120:4 239:12 146:18 147:10 168:8 manufacturers legal 242:12 218:20 220:17,22,24 239:3 134:25 125:2 127:23 leitman Up 121:3 124:4,14 243:2 239:13 240:12 242:14 243:16,24 manufacturing 131:13 134:14,17,24 136:8 121:13 128:13 loaded low 139:2,11,15,20,23 140:8 lesson 180:11 181:1,2 156:20 144:25 148:15 153:25 182:14 loading I's 165:20 167:22 169:22 level 181:15,22 182:1,2 155:15,16 170:19 171:7 172:9 181:14 135:7,8 143:9 154:2 156:20 local lsppc.com 200:14,15 203:19,21,23 157:10,10 224:23 227:22 235:1 121:20 209:7,8 210:1,6,10 214:4 levels locally lye 214:16217:14,21 220:19 194:9,12 168:5 205:6 221:1 library located lynette march 141:24 152:19,21 167:13 168:7 220:22 230:25 121:2 128:17 233:11 167:20 168:10 232:22 lynette.smith mark license location 121:9 163:19 164:19208:24 240:18 199:8 234:6 lynn 214:5 225:10 226:25 liking locker 128:13 228:20 233:5 235:12 160:15 194:14 196:10 lynne marked limit lockers 121:12 138:1,3,5,10 151:9 163:22 205:11,11 limited 145:2 line 196:9,9,11 log 197:7 logging m magistrate 119:3 241:4 164:24 166:5 170:5 209:1 210:21 214:7 217:15,17 225:12 227:3 228:22 233:7 233:14 235:15 187:2 233:2 lines 197:19,21 logical 127:5 maintenance 185:8 232:10 lining 203:8,10 lipa 211:25 lombardi 124:14 long 129:23 158:3,10 161:7 195:17 196:1 228:8,17 making 183:15237:11 125:3 122:10 134:10 145:6 149:7 malathion liquid 155:9,20 161:12 184:6 132:14,20 169:8,10 174:12 212:14,24 220:25 221:3 174:14,22 175:9,11 185:14 longer 186:13 187:1,4,7,20 198:8 155:24 159:22 174:7 173:14 man 141:3 155:3 156:21 management 198:24 204:2,3 210:19 look 153:25 175:5 218:6 223:12,23 224:9,13 138:2 164:5 165:2 166:23 market 207:3 marks 196:24 marvin 129:16 material 132:13 135:3 142:22 152:3 152:5 154:3 156:5,20 157:20 158:6 180:1,3,22 181:1,6 182:6 184:5 185:16 185:19 187:1 188:9,25 194:6 195:5,6 199:2 200:13 225:3 231:24,25 liquids 188:2 223:19 list 139:1 143:15 173:24 167:9 169:25 209:4 214:10 217:23 225:16 235:13 looked 149:22 151:15 173:1 140:11,12,18,20 141:14 142:25 143:17,19 146:15 147:3,4,9 153:18 155:24 157:3,10 159:10 160:4,7 162:12,16 163:3,19 164:8 204:21 205:9,13,19 206:13 206:14,19215:16 materials 132:11 142:19 153:19 154:24 156:2 157:4 182:17 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050451 [materials - neoprene] materials (cont.) mention modernize name (cont.) 188:25 193:22 198:13 131:24 154:20 210:23 232:13 160:22 162:19,20 163:11 202:9 205:4 212:6 mentioned molten 165:15 168:15,18 171:12 mather 133:12 134:1 194:7 199:25 133:11 171:14 172:6 173:4 176:25 164:21 165:13,15 166:15 238:6 moment 179:7 188:4,8 200:21 168:15 message 131:1 166:23 168:12 219:13,21 222:20 225:14 matter 197:21 169:25 202:18 233:17 228:2 233:23,25 241:19 167:25 met moments named mattered 141:11 185:17205:18 165:2 229:1 235:13 172:2 219:11 212:5 metal monsanto names matters 189:13 142:22 143:10 151:11 127:18 129:11 138:23 176:10 metals 152:23 153:11,13 179:10 143:15 162:6,10 219:6 maynard 124:12 129:1 168:23 180:6 183:19,22 205:5 234:15 narrow 123:12 128:19 method monsanto's 227:15 mcclain 142:1 215:14 142:14 146:12 179:4 nassif 140:19,20 143:18 mi montars 120:3 127:18 128:22,22 mcclain's 122:12 188:7 165:19,24 167:4 208:8 143:21 michael month 209:13,15 221:24 237:11 mcglaw.com 124:13 166:7 150:10,12 237:13 123:18 mike moody nationsbank mcmahon 127:10 128:25 130:17,21 173:16 121:4 243:3 124:13,14,20 127:10,10 miller moore natural 128:25,25 177:8,9,15,16 219:12 192:4 mcwane minckler morning naturally 118:6 119:10 123:10 128:3 139:4,5,11 129:6,7 130:4 178:2 128:20 241:9 mind morning's nature mdhl.net 129:12 135:23 136:1 151:2 130:8 209:21 124:20 156:10215:13218:11 mouth near mead 239:16 186:8 232:24 120:12 128:9 minimal move nearby mean 204:18 164:16 232:20 131:5 133:22 148:18 154:5 minutes moved necessarily 160:19 169:3 179:7 183:20 138:2 149:24 208:9,11 132:23 218:20 136:19 142:2 164:5 229:11 198:18 200:21 221:9,17 miscellaneous mowing necessary 224:11 202:17 200:12 152:2 157:24 meaning missouri mullendor need 169:5 119:22 128:1 239:1,5,13 147:4,5,5,6,23 127:15 152:20 156:13,15 meant 240:12,17 243:23 muriatic 156:17,24 157:17 158:1 180:1 217:6 mix 207:3 159:16 164:5 175:8 182:13 meet 160:22 180:10,13 203:8 mwv 195:16 199:13218:11 180:20 mixed 138:12,13 221:24 232:8 237:3 meeting 181:1 myers needed 141:3 mixes 123:2 128:15,15 153:20 156:5 162:3 189:22 meets 204:18 178:18 mixing n 196:3 199:10,12 231:20 232:6 member 171:17 172:17 1234 needing 148:9 176:4 177:9 227:18 231:17 236:14 members mixture 204:12,19,23 mm n.w. 12220 nail 168:5 234:3 235:4 needs 172:18 208:8 212:25 142:13 228:8 135:25 137:4 151:12 18818 negotiating memo 225:16 229:14,20 231:9,15 156:14 168:25 172:4 176:2 182:9 186:24 189:7 198:25 name 127:22 129:13,21 130:20 161:25 162:7 nell 241:1 memory 211:25 218:24 220:18 221:12 227:9 139:8 140:2,5,25 141:2,6,9 141:9,11 143:21 144:3 146:6 neoprene 130:18 182:25 234:1 mo 146:1 '2,8,14 147:1,4 148:1 195:4 120:6 125:5 242:14 243:16 153:21 154:12,21 155:14 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050452 [neutralize - pages] neutralize 205:7 neutralizing 191:24 new 196:4 201:14212:9,10 229:23,24 230:1,11,20,21 231:20 232:5,15,15,22,24 234:24 night 194:3 nods 207:8 218:24 non 159:23 normal 191:22 197:11 243:12 normally 229:10 north 121:14 122:4 123:13 northeast 121:5 243:4 northern 119:2 128:4 239:10 241:3 notarial 240:11 notary 119:24 238:19 239:4 243:23 note 210:22 notice 172:25 239:8 noticed 218:13 november 164:21 166:16 number 128:4 136:2,5 165:25 166:10 180:17 186:18 192:17 193:11 208:15,20 210:20 214:5 216:25 230:1 231:4 232:3 233:11 235:18 numbered 149:15 numbers 138:11 141:19 163:25 numeral 178:12210:18 numeric 175:10 nunnelly 129:16 o oaths 239:6 objections 240:1 objective 174:10,20 obstacle 158:13 obtained 178:8 200:18 201:23 202:1 211:20 obviously 234:12 occasion 151:1 164:7 167:1 218:11 occasionally 200:1 occasions 157:15 159:9 200:3 occur 153:17 192:19,22 194:1,2 215:16216:5 occurred 132:20 153:17 157:19 160:11 167:18 181:15 occurrence 197:4 occurring 160:3 178:2 213:5 October 165:21 209:9 214:17 215: odd 160:22 194:2,2 offer 161:1 162:8 offered 160:15 office 152:10 156:4 162:22 228:14 officer 241:12 offices 119:20 127:24 231:16 239:12 oh 120:17 124:16 140:14 152:12 159:12 165:17 171:4 174:19,21 183:6 186:2,23 190:14,23,25 192:4 201:12 206:6 209:1 241:24 242:5 oil 190:18 oily operator 199:5,24 197:6,13,13,14,17,18,25 okay operators 129:16 130:23 131:16 204:9 216:9 132:14,16,21 133:2,24 order 135:11,22 136:7,10 137:20 131:6,6 132:7,12 157:1 138:18,22 139:22 140:10 184:21 193:24 213:3 140:15,17,24 143:3,7 144:5 organic 144:22 146:4 150:21 151:4 139:2,12 140:8 153:4,18,23 154:17 155:23 organization 156:1 157:2,12,15 162:14 144:11 197:12 162:18 163:2 164:11 orig 167:17 171:2 173:2,17 242:6 176:18,21 178:24 180:25 original 181:5,10,13,22 182:6 183:2 199:17241:20 183:12,24 185:5,20 186:11 originated 187:13 188:12,21 189:17 148:4 190:1,3,12 191:3,8 192:12 originator 193:9 194:17,21 195:17 222:19 199:7,9,15,25 202:24 204:1 outside 206:18 207:15 211:9,22 234:16,17,19 212:20 213:7,10,15,19 oxide 215:2,22 216:16217:11 182:22 218:9,23,25 222:16,18 oxy 223:5 224:3,5 226:11,13,17 182:22 232:21,25 234:2 235:24 P 236:4,20,25 237:10,11,12 p.c. 237:13 older 121:13 123:3,12 p.m. 168:1 216:19 olive 125:4 243:15 once 152:11 155:24 156:18 119:23 237:16,17 packaging 230:12,20 232:15 packed 217:1,6 168:3 170:2 190:16 232:2 o'neal packing 223:21 121:12 128:13,13 open 157:24 198:23 201:8,20 pad 181:16 page 232:18 opening 181:4 190:20,20 openings 198:24 operate 138:24,25 141:19 142:6,8 143:13 145:22 148:2,3 149:11,17 151:9 168:16 171:10 172:1 173:23 174:5 174:10,17 175:18 178:10 178:13,15 179:14,15 159:6 operating 193:18 200:7 216:22 232:11 operation 182:13,16 184:18 185:3 186:21 192:15,18 196:25 202:14,14,16,16 210:9,17 215:3 219:6 220:11 221:6 221:16,19,21,23 222:3,9,12 131:20 135:16 144:10 203:5 205:10,14 operations 144:8 158:17 185:6 186:17 222:18 229:21,22 233:22 235:25 237:1 pages 138:14 143:12 164:5 174:4 223:18 178:11 184:23210:17 216:24 219:15 221:22 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050453 [pages - plasticizers] pages (cont.) particularly person (cont.) pipes 239:23 242:15 243:6 151:13218:5 141:12 146:3 156:17 157:16 158:2 paid parties 168:13 173:15,24 203:22 piping 243:11,12 240:8,10 241:19 158:21 paint passed personal pit 175:4 153:11 156:16 206:1 160:17 194:19 196:10 191:24 192:1,6,12 pair pathway 204:10 place 195:21 196:4 192:2,4 personally 129:21 131:17,23 132:24 pan pattern 150:3 133:4 176:7 181:12 191:14 185:23 186:10 191:14 191:22 personnel 192:13201:15213:8 pans paul 129:11 130:15 215:19 219:3 223:6 225:4,5 186:14 175:25 176:1 peruse placed papageorge pavement 214:20 181:5 119:18 128:2 129:6 137:25 181:20 peruses places 138:18 149:11 163:15 payne 138:7,15 164:1 165:4 167:3 194:2 206:15 211:25 166:1,11,22 169:25 170:11 121:13 128:14 170:7 179:19 202:21 plaintiff 174:7 184:18 208:16,21,23 pcb 209:16 214:13 217:25 120:2 209:4,19 214:1,4 217:23 186:3 225:18 229:3 233:19 plaintiffs 222:23 228:5 229:1 237:15 pcbs 235:21 119:6 241:7 238:1,10241:16 218:6 phase plan paper peachtree 132:20,20 204:24 191:17 197:20 199:4 121:5 124:6 243:4 phelps plant papers pending 121:11 128:14 129:12 130:14 131:12,13 148:19 128:3 167:8 239:8 phenoxy 131:25 133:13,15,19 134:8 papgeorge Pennsylvania 182:21 134:11,23 135:7 137:14 118:14 122:20 Phillips 139:21,23 140:10,12,17,20 paragraph people 154:21,22 155:14,17,24 141:8,13,14,21,25 142:24 179:16 180:10 197:2 203:7 142:2 143:4,10 152:6 155:4 phone 142:25 143:9,17,19 144:11 225:23 156:13,25 157:1,5,22 127:2,19 146:10,21,24 147:6,7 148:8 parallel 158:11 195:17 203:3 physically 149:8 150:9,11 151:19 216:22 perceived 222:24 226:5 153:10,18,20 154:22,25 parathion 160:21 pick 155:21,24 156:12 157:3,10 173:14 percent 194:6 195:21 196:20 157:19 159:10 160:3,3,7,24 parking 182:20 183:9,10,25 184:1 215:24 162:12,15 163:3,18,19 161:11 percentages picture 164:8 165:9,11,12 167:1,2 parkway 182:17 135:22 136:1 168:2,3,10 170:15,18,20 122:11 percents piece 171:21 173:25 174:8 176:4 parkwin 183:7 136:23 159:21,21 176:9 177:10 178:22 181:7 231:5 performed pilat 182:3 183:16,18 188:14,22 part 136:18 122:9,15 127:11 188:23 191:14 192:3,3,10 132:17 147:11,16 150:7 period pile 192:18,23 193:4 196:21 152:14 158:19 160:1,25 139:10 142:24 152:22 201:10,13,14,16 198:19200:9,12,12201:2 161:9 162:7 171:16 172:16 159:22 160:10 161:23 pinch 201:13 207:19 209:22 177:20 187:16 194:23 188:14213:5 228:16 210:3 211:14,17213:5 196:2 229:15 235:5 periodically pipe 214:12,23 215:4 218:18 partial 157:17 124:1 128:12 234:7 219:3,18 226:15,18 227:16 197:16 periods piped 228:6,6 229:9,14,16,19 participation 159:12 181:7,8,11 233:23 236:8,11,12,19,20 219:14 permit pipefitters plants particular 215:23 228:16 142:15 153:12 135:3 148:11 149:11,23 permitted pipeline plasticizer 151:25 152:10 156:3,11,22 232:12 157:24 158:11 181:3 137:24 174:11,13,22 175:9 175:10,13 188:17 203:7 perry 189:25 175:11 179:9 217:4 218:11 222:10,19 125:3 243:14 pipelines plasticizers 234:19 person 136:11 206:12 174:25 175:1 127:5 129:22 130:10 135:6 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050454 [plaza - purpose] plaza preceding process products 119:21 120:5 121:4 123:14 222:10 130:12,13,25 131:16,22 137:6,10 171:18 182:18 127:25 242:13 243:3 preferred 132:10,12,17,19,23 133:15 183:15,16 please 195:5 134:2,7,21 135:15 136:9,15 program 128:6 156:20 202:16 preheater 137:2,16 143:4 148:22 152:24 153:13,14 233:18 136:16,17 149:13 150:1,3,7 151:25 programs plug preheaters 156:22 157:13 158:19 177:12 187:2 136:3 159:6,11,16 160:1 164:13 progress plural preliminary 164:18,20 165:9,12,20 197:23 233:10 235:18 188:18 204:17 166:14 169:3,7,13,19,23 236:5,9 plus preparation 170:19 171:1,7,17 172:16 project 164:5 130:5,7 178:4,13 184:7 187:10,19 226:14229:13,18231:19 point prepare 187:24,25 200:14 202:10 232:25 233:1 234:21 235:5 127:17 132:16 142:12 148:20 203:17,19,21,23 204:21 projects 145:4 173:12 174:1 191:16 prepared 207:25 208:4 209:7,8 210:1 236:7,9 195:7 199:25 205:3 207:19 142:3 170:23 171:11 210:7,11,19212:5,12213:7 propene 219:18 226:18 172:25 213:10,12,19214:4,16,22 182:22 policy presence 215:7216:11,12217:14,21 proper 153:7,9 169:10 219:2 223:11 224:15 226:1 152:1 194:22 polychlorinated present 226:22 233:2 234:3,7 237:6 properties 223:19 191:25 203:8 205:1 212:25 237:7 204:15 205:17,18 223:23 poor 213:13 processes proposed 210:15 pressure 133:5 134:14,17 143:8 170:24 229:13 231:5 popular 158:8 145:3 148:15 151:6 153:20 propounded 136:22 175:13 presumably 154:24 165:9 167:22 240:1,4 portion 133:6 170:15 172:9 209:22 protecting 136:14 218:15 229:20 pretty produce 194:23 position 205:19 131:3,6 132:12 136:24 prove 147:9 148:7 173:16,17,20 prevent 171:18 182:18212:17 168:2 176:3,12,15 214:12 220:5 203:10 213:3 provide 221:1 227:14 previous produced 184:21 possible 148:2 210:12 132:2 134:11 137:17 public 193:16 221:11 226:9 previously 205:20 210:3 119:24 120:16238:19 postdate 140:12 166:17 producing 239:4 241:23 242:4 243:23 218:18 primarily 151:21 231:2 pull pot 231:25 product 190:4 221:25 131:22 133:15 134:2 primary 137:17 156:15 168:24 pump 136:21 137:7 164:13 137:22 188:1 205:9,22,23 206:1,7 180:22 225:22 226:10,11 prior 206:20 219:25 pumped potential 130:7 140:13,16,18,21,22 production 182:7 185:11 141:14 143:14,19 163:8 130:11,13,16,25 131:2,18 pumping pots 173:20 191:16 192:22 132:4 133:7 134:7 135:15 206:11 132:22 133:1 135:1 136:2 196:12213:8 135:24 136:13 137:2,6,16 pumps pounds probably 140:24 143:4,8,8 144:13 136:11 206:12 156:22,24 150:10 195:15202:13 145:2 147:3,3,8 150:1,7 purchase ppo problem 151:11,24 152:4 153:20 156:17 182:20 183:5,9 158:13 159:20 197:25 156:3 157:9,16,23 158:3,21 purchased pr&d 237:6,7,8 159:6,11,12,16,23 161:7,15 183:17200:19 219:21,22 220:5 problems 161:19,20,23 168:23 169:2 purchasing practical 203:5 169:13 171:12 172:12,22 152:6 154:3,4,17,19,22,24 205:12 procedure 172:23 173:11,21 177:19 155:6 156:1,7,16,21 157:1 practice 148:25 153:5 205:5 178:4 203:17,18,22 210:5 202:11 211:23 195:14 200:3 procedures 212:9 213:11,12,23 215:7 pure precaution 141:24 216:18 219:2 222:25 212:2,6 203:2 proceed 223:12,13 226:19,21 purpose 222:5 231:10,21,22 232:8,19 137:22 179:17,23 234:13 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050455 [purposes - relayed] purposes range (cont.) recall (cont.) reed 152:13 205:12 166:16 169:24 209:10 178:7 179:12,13,17,22 129:20 pursuant 214:17 217:22 227:7 180:25 181:20 182:21 refer 239:8 233:12 235:19 195:3,4,5 202:24 203:9 141:19 153:1 167:20 put raw 209:19,20,23 211:1,6 213:2 205:24 229:17 236:1 172:9,13 186:8,14 187:12 132:11,13 153:19 154:24 216:20,23 217:3 218:3 reference 192:12 196:17201:19 156:1 157:4 202:9 219:9,11,13,13220:12 142:7 147:8 150:4 158:23 213:25 229:24 230:2 231:7 reach 223:3,20 225:7,20 226:2,14 174:16 184:2 187:15 puzzled 205:3 226:20 227:20,24 228:11 193:14 216:25 226:20 150:3 reached 229:6,23 230:2,4,13,15,24 229:22 pwg 154:2 215:25 231:8,10 232:7,21,25 references 118:4 119:8 241:8 reaches 233:23 234:2,6,7,11,19 184:24 187:5 pyranol 156:20 205:10 235:4 237:2,5,8 referencing 178:18,18,20 203:8 reacted recalling 235:18 pyranols 204:23 132:9 referred 178:21 reaction receive 134:13 137:21 165:11 q 133:3,3 213:1 qualified 212:8 239:6 reactions 137:12 quality 180:10210:15 quarter reactor 164:14 read 1278 question 139:1 140:2 143:16,25 144:2 147:2 171:4 179:15 167:4,8 170:1 174:21 180:1 202:20 225:7 questions 179:21 181:25 202:19,23 210:17 211:8 229:4 233:21 235:23 238:2 133 23 166 18 229 2 239:25 240:3 reading 146:4 183:5,6 quick 182:14 quickly real 140:4 182:14 224:10 realize 164:16 165:6 quite 143:14 really 145:13 149:14 178:11 231:1 135:5 141:22 160:17 182:23 197:21 198:6 quote 202:13 174:10 reason 159:11 160:12,14 r reasonable 156:25 167:1 170:22,23 182:1 188:6,23 218:14 204:10211:14229:10 221:7 225:21,22 231:3 236:9 referring received 142:9 185:13 215:2 222:11 170:19211:18 222:18 226:3 receiver refers 186:19 205:9,10,23 206:20 178:17 186:17 187:22 206:21,22 192:18 193:11 202:17 receiving 203:7 219:25 220:2 229:21 171:3 192:6 202:9 218:21 230:11,18 231:4,9 233:11 233:23 236:5 237:1 receptacle reflect 198:19 210:2 215:6 219:2 recess refresh 166:3 208:18 229:12 recessed refreshes 237:18 149:12,25 recognize regarding 129:21 171:12 209:5 135:1 217:24 225:14 registered recognizing 150:15 163:15 regular recollection 200:2,4 141:3 147:11 149:12,25 regulation raakhee 201:14 158:15 171:6 180:7 210:11 158:18 122:18 127:3 129:2 rec 215:10,13 227:10 229:12 reissued raakhee.biswas 132:9 230:5 236:4 165:24 122:24 recall record rejected rag 129:13,17,23 130:19,23 127:15,21 128:7 138:9 162:8 198:10 199:5 131:16,22,24 132:3,11,13 142:8 152:24 153:6 163:24 relate rags 132:19,21,25 133:10 164:19 165:19,22 166:2,9 142:17 198:14,15,16,20 199:1 134:18 135:13,16 137:7,9 166:13 208:17,19 209:6 related railroad 137:23,24 139:10 141:2 214:15 233:9 235:17 144:8 240:9 181:18,19 146:2,2,8,25 147:16 148:8 237:16 relating raised 152:25 153:14 154:12 records 234:5,14 186:3 155:13 158:24,25 159:3,13 142:4 152:22 153:24 199:4 relative random 160:2 163:11 164:10 167:4 rectangle 232:23 135:12 167:11 168:13,15,22 150:4 relayed range 169:18 170:12 171:9 172:5 redistill 156:24 138:12 163:25 164:22 172:6 176:3 177:7,13 178:3 180:23 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050456 [release - sand] release replacement resistant rise 185:14 197:18 194:24 224:24 relocate replacing reslawgrp.com road 234:3 130:20 204:4 123:8 124:15 relocated replenish resolution robert 234:9 212:15 123:3 128:15 130:17 173:16227:13,14 relocating report respect roman 234:14 144:12 197:4 198:1 233:10 136:16 172:21 178:12210:18 relocation 235:18 236:5 respects roof 233:1 234:21 reported 240:2 181:22 remained 148:11 176:13,17 197:6,9 response room 149:7 239:22 127:12 187:16 194:14,14,14 remaining reporter responsibility rooms 205:7 119:24 226:25 228:20 134:16 148:14 151:23 193:21 remains 233:5 235:12 240:16 242:7 154:23 197:9 200:7,14 roughly 187:20 reporting responsible 216:4 remarks 125:3 147:13 148:10 130:16 144:24 151:21 routine 240:1 243:14 153:19 157:6 168:9 177:18 158:19 remember reports 202:6,9 routinely 131:19,21 138:20 139:13 144:13 172:24 184:25 rest 236:8 145:11 149:4 150:12 151:1 197:21 236:9 194:14219:1 rsmo 151:2 153:16,21 160:10,12 repos restrooms 241:14 161:13 162:6,10,19,23 152:21 162:3 rule 169:14 170:17 171:13,14 repository result 241:14 171:25 173:19,22 176:13 152:15 136:25 run 176:20,23,25 177:11 representatives retain 161:22,24 206:23 221:18 181:16,24 183:1,18 205:6 161:25 152:22 167:21 222:5 212:13214:25 216:17 representing retained running 217:9,10 220:16 223:10 128:9,11,14,16,18,20,22 216:12 157:22 158:19 225:2,3,21,24,25 226:5 134:24 retaining rush 227:18 232:4 234:5 represents 167:25 150:14 remind 141:22 retention rust 140:17 reprocessed 152:24 153:7 202:25 203:3,8,10 reminds 210:22 remove 189:19 removed 189:22 204:25 205:5 206:10,23 removing 180:2,3 190:15 207:9 reorder 154:1,3 156:21 repair 159:22 237:3 repaired 235:5 repairing 237:1 repairs 228:13 replace 174:11 replaced 212:22 188:10 requested 148:23 requesting 157:4 171:19 requests 157:2 require 180:16,17,18 required 156:12 172:17 178:21 198:10233:1 requisition 157:8 research 134:20 145:23 146:12,15 219:24,25 220:11,14 researcher 220:10 resembles 165:8 residual 204:22 212:24 return s 138:24 216:13 reusable safety 142:7,10,19,23 175:19,20 212:13 176:4,9,9,16,19 184:24 reuse 212:11 review salable 20521 sales 130:4 142:8,10,23 143:2,5 1756 149:23 166:24 167:1 170:3 175:19,20 219:5 229:1 233:17 sample 187 3 18915 19 23 190 4 4 190:16204:13,13,15 reviewed 205:14 206:4 149:21 172:2,10,11 173:3 richard 220:15,16 right sampled 205 14 samples 1858 12 13 191 12 142:7 147:14 149:16 sampling 166:20 178:13,15 182:24 183:7,23 206:9,20 208:6 186:19 187:6 216:2,2 sand 209:13 216:4 224:1 231:6 rings 198:8 200:17,18,20,23 201:4,6,10,16,17,18,22,25 132:7,8 202:4,7 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050457 [sanders - solidified] sanders seeing severson 120:14 121:3 128:8,18 138:20 162:2 164:10 144:4,5,14,16 145:15,19 241:21 242:2 243:2 167:11 170:12 225:20 sewer santicizer 227:10 229:6 233:2 234:4,5,15,21,24 179:7,9 seeking 235:4 237:2,4,6,7 santowax 204:12 shaped 137:9,15,21,22 164:21 seen 189:14 166:15 138:19 151:15 163:17 shaw satisfied 164:17 165:3 167:10 170:2 125:2 127:23 212:25 170:10214:12225:17 sheet savage send 149:23 163:16 220:20,21,25 153:2 168:5 185:18 189:18 shift saw 204:19 206:12 196:8 197:5,15,17 198:1 165:7 233:25 sent shipment saying 127:4 152:23 183:18 188:3 178:23 187:6 204:13 205:14 shipped says sentence 206:15,16 148:4 151:10 174:20 185:5 181:25 shipping 210:18 235:25 sentences 161:21 181:12 scale 202:19 shm 134:23 separate 123:8 scanned 200:8 216:6 shoes 138:17 165:6 218:2 227:8 September 193:23,25 194:18,19,19 schedules 138:14 165:24 209:10 196:14 201:13 210:2,12215:12240:12 short school 243:19 189:11 150:13 sequence shorthand schulte 138:12 175:11 216:6 223:9 239:22 176:13,21 177:4 219:7 234:25 show schulte's sequential 155:3 221:19 176:15,24 216:13 shown scientific series 150:4 239:20 121:1 128:18 132:21 136:4 215:15,16 shows scot 218:13 223:1 224:1,4 150:2 152:3 163:16 127:9 serve shut scott 142:15 189:15 122:2,3 127:9 128:24,24 service sic scrub 195:25 182:22 206:24 serviced side scrubber 234:8 181:21 182:19 207:7,9 services sides seal 147:12,17 148:9,14 149:3 194:23 240:11 243:19 168:14 177:10 195:18 siegal sealed 236:15,17 121:13 128:13 201:20 session sign sec 237:15 127:6 241:14 set signature second 164:11 169:20 203:15 148:4 215:3 222:9 238:4 138:24 165:23 173:23 217:12 222:22 225:1 240:5 201:15 202:15 215:3 219:6 226:13 239:24 243:18 signatures 229:21 236:25 seven 219:16 222:2 secretary 159:7 signed 162:15,17,18,22,24 163:2,5 seventies 148:12,25 157:9 214:23 section 186:16 221:16 178:17 180:9 181:7 210:19 severity signify 210:21 159:18 222:7 similar 167:22 170:14,14 187:25 209:21 214:21 222:3 simply 234:9 single 201:10 sir 149:21 178:17215:6 sit 134:5 191:4 site 181:14 189:2 situation 157:18 six 216:24 sixth 123:13 sixties 186:2 size 135:1 201:14 skipped 148:1 183:25 slag 151:3 slipping 193:12 sis 121:20 small 152:7 194:1 smith 121:2 128:17,17 smp 221:10 222:8 smps 134:14 135:8 sodium 205:6 soil 189:2 sold 174:25 207:4 sole 194:24 solid 186:19 187:2,5,9,15,16 189:1 190:21 193:20 194:8 194:11,16223:12,16224:8 224:13,25 225:4 230:12 231:24 solidified 187:9 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050458 [soluble - supply] soluble spill (cont.) started strikes 206:25 201:17 127:13,20 166:19 160:6 solutia spills starting struck 118:2 119:5 128:3,23 241:6 197:3,6,8 198:5,7 200:5,18 135:2 161:5 solvent 202:4 state studies 198:10 199:9,10,12 spoke 119:21 187:17211:15 148:22 somebody 140:11 175:19 239:1,5,13 240:17 243:23 subparagraph 154:9,18 156:2 spot statement 185:2 soon 193:18 194:5 201:16 241:13 subscribed 138:2 spout states 238:12 sophisticated 189:14 119:1 128:11 174:10 subsequent 205:16 spring 180:10 193:12 197:3 209:7 192:25 sorry 150:14 239:9 241:2 suggesting 146:22 165:14,18 175:6 square station 164:4 176:25 183:4 199:11 120:16 241:23 242:4 230:2,21 232:5,15 suggestions 201:24 209:12 220:3 squire status 154:1 236:22 120:14 128:8 241:21 242:2 197:23 suit sort ss stayed 240:9 152:15 185:23 189:5 210:6 239:2 216:12 suite sound ssd.com stays 119:21 120:5 121:4,15 140:3 162:20 231:6 239:16 120:20 199:16 122:11 123:4,14 124:15 source St steel 125:4 242:13 243:3,15 131:9,10 167:24 207:21,23 119:21 120:6 125:5 146:13 122:8 190:17,21 198:23 summary 212:13 146:18 147:10 168:8 201:19,20 152:8 sources 218:20 220:17,22,24 239:3 step superintendent 193:16 239:13 240:12 242:14 131:3,5 226:22 140:24 144:13 151:24 southern 243:16,24 Stephens 153:22 154:5,13 156:6,11 123:1 128:16 stacey 121:12 173:11,21 211:23 speak 123:2 128:15 stepping superintendents 152:22 167:14 staff 193:24 143:9 speaking 162:14 stevens superintendent's 195:25 stage 231:15 156:4 specialized 208:3 stills supersedes 202:18 stains 187:23 188:5 223:1 209:8 specific 198:12 stood superseding 134:18 140:6 143:2 144:8,9 stairs 139:7 177:1 210:10 150:12 151:1 153:16 193:12 stop supervised 158:15,18 168:13 169:7 stand 204:18 145:5 170:12 171:6 200:3 201:16 182:15 219:22 storage supervision 204:16 205:17 209:22,24 standalone 206:13,14 168:14216:9 218:3 228:12 236:6 177:21 store supervisor specifically standard 156:25 141:8,14 143:24 144:6,12 136:13 145:11 169:18 134:14,17 142:1 148:15 stored 144:15,19,23 145:7,9,20 206:13 233:3 234:22 165:20 167:21 169:22 201:6,9 146:19 152:4 172:12,14,23 specification 170:19 171:7 172:8 195:13 storm 172:24 173:1 198:3 180:20 203:19 209:6,8,25 210:10 235:4 237:2,4,6 supervisors specifications 214:3,16 217:13,20 stream 161:6,19,20 185:17 212:3 214:22 standards 169:2,11 184:17 supervisory specifics 141:20,20 142:3 151:11 street 145:1 152:25 214:25 223:3 152:14,17 121:5,14 124:6 125:4 231:5 supplier spigot standing 243:4,15 178:8 189:5,9 190:3,9 191:12 143:1 176:6 stricken suppliers spigots start 166:20 201:5 188:1 127:7 129:10 166:21 strike supply spill 180:23 204:2 224:22 160:13,16 161:12,16 162:9 207:17,18,22 197:5,8 199:21 200:3 201:7 225:7 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050459 [suppose - transferring] suppose 137:7 sure 143:24 147:2 182:14,23 183:9 185:16 206:19 218:13 surface 199:18 sworn 238:12 239:18 system 158:10 206:11,24 215:24 216:14,18,21 223:4 224:5 232:8 t table 181:21 182:15 taffy 236:11,13 taken 119:19 128:2 167:9 187:3 198:20 201:18,20 206:7 212:21 238:3 241:17 talked 143:17 154:11 159:17 175:22 183:25 198:17 202:10203:17,18211:24 2163 2197 talking 136:14 166:19 188:19 20420 talks 19311 tame 20820 tan 200:22 tank 178:22 180:12 181:1,2,3,5 181:15 182:1,9 203:9,9 205:24 206:2,8,10,13,14 215:25 216:10,13 223:6 229:23,24 230:6 231:20 232:21,22 234:10 tanks 132:25 135:1 136:11,16 215:15 216:6,13 tape 165:25 166:10 208:15 task 141:23 144:7 tasked 200 9 taxed 242:1,11 243:1 taylor thermal titled 123:11 127:13 128:19,19 185:1,10 178:12 tcb therminol today 183:2,10 179:4 130:5,17 133:24 134:5 team thing 138:19 154:15 167:10 236:16 160:17 186:25 192:4 226:9 177:4 technical things today's 147:3,8,12,17 148:9,14 159:24 162:2 180:19 127:22 237:14 149:2 168:14 177:9 195:18 think told 195:25 200:21 236:15,17 127:4,5 130:17 137:18 156:13,19 technicalities 145:16 149:15,16 156:7 tolerate 131:19 160:17 172:15,20 177:10 199:19 telecopier 177:15 182:21 200:6 toluene 124:19 208:10 219:25 228:12 183:8 telephone 229:21 235:7 236:2 237:10 tool 120:7 122:22 124:18 third 123:1 128:16 tell 122:4 151:8 180:9 187:22 top 164:6 176:24 217:23 225:23 142:7 143:24 148:3 151:10 tells thought 178:12 182:16 183:5,6,24 197:14 180:1 188:20 184:16,24 188:1 190:21 temperature three 192:17201:15,20 202:16 187:16 205:11 224:6,9,14 175:21 184:23 208:11 210:18 227:24 231:16 224:16,18,20,22 222:11 tops temperatures throwing 198:23 185:10 223:17 224:24 199:4 total ten thumb 242:9,17 243:8 156:23 221:21 tour tentative thumbing 133:7 174:5 218:14 221:7,9,13 218:12 tower term ties 120:15 241:22 242:3 136:15,21 137:1 150:14,21 169:18 toxicity 150:23,25 151:5 157:12 tiled 184:25 164:13 169:1,3 177:23 193:21 track 178:18 226:10 time 181:18,19 194:5 216:4 terminology 128:6 132:16 133:18,25 tracking 188:23 217:10 135:17 139:11,18 141:14 194:18 terms 142:12,22 143:19 144:20 trademark 196:4 232:9 145:4 151:18 152:22 153:2 178:20 179:2,4,10 terphenyls 153:2 159:9,19,23 160:7 traffic 218:7,7 223:17,19,25 224:2 161:13,23 162:1 163:3 175:4 224:17,21 167:23 173:12 174:1,6 training test 185:25 186:1 187:6 189:21 236:21,23 185:16,19 206:1 221:18 191:8,16 192:3,9 193:4,6 transcribed 222:5 195:7,19 204:5,6,18 205:11 239:22 testified 205:15 207:20 212:20 transcript 196:12 239:20 213:2 215:25 218:18 219:3 238:2,5 239:21 240:3 testify 226:15,16,17,18 227:15 241:20 239:18 228:14 229:13 230:8,17 transcripts testimony 231:11 237:11 243:10 196:12 238:5 239:21,24 times transfer testing 186:3 194:3,3 167:18 177:12 204:17 tin transferred thank 203:8 197:12207:1 129:9 138:18 title transferring thereto 134:19 173:25 228:9 134:22 240:2 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050460 [transformer - wanted] transformer turnings undetermined various 203:6 211:11,14,20 212:1,10,11 239:9 152:13 177:19 194:25 transformers 212:16,21,22 213:3,17 unexpected vary 203:4 twenty 159:25 158:14 159:20,24 180:16 transported 178:11 uniformed vent 189:1 twig 161:10 190:20 trap 196:22 union version 150:5,6 157:13 type 160:6,15 161:3,9,11 162:1 171:1 210:13 trapping 131:16 136:9 137:13 unit versus 191:25 138:21 139:1 142:13 135:18,21 136:20 156:3 190:8,16 206:20 223:12 trays 144:10 150:3 151:16,22 157:22 158:3,6,22 193:18 224:13 223:22 152:25 157:18 158:5,16 194:16 200:15,16 204:19 vessel treatment 159:15,20 167:12,22 222:25 231:2 232:11 215:20,21 217:1,7 170:14,16 178:2 181:17 united videographer trial 190:21 193:20 199:1,1 119:1 123:10 128:11,20 125:1,2 127:21,23 165:25 222:13,14 239:11 200:20,21 203:9 218:4 239:9 241:2 166:9 208:9,12,15,19 trichlorobenzene 226:3 229:9 233:10 234:17 units 237:14 183:3,11 typed 133:11 135:16 183:19 videotaped tritetrachlorobenzene 151:14 210:5 216:19 225:1 118:14 119:18241:16 183:13 types unusual vince troutman 153:1 214:22 159:14 148:6,7 121:3 128:17 243:2 typewriting upper virtually troutmansanders.com 151:15 239:23 194:9,12 175:3 121:9 typical usable visually truck 135:10 136:8 138:20 188:9 205:21 199:20 201:1 148:13 165:10 209:20 usage vividly trucks typically 212:14 211:5,6 201:3,5 135:7 170:18 use volatile true u 134:3 135:9 137:23 148:20 207:13 141:18 154:16 157:11 u.s. 151:18 167:13,23 175:1 179:3 202:5 216:15 218:22 124:1 184:9,11 210:5 213:16 221:15 238:4 240:2 uh uses truth 239:18,19,19 188:13 ultimately 206:24 usually try 231:6 197:12 130:11,12 138:22 144:2,2 um utilized 203:25 232:10 198:14 178:4 188:16212:10 trying 188:18 222:11 226:8 unable 134:5 234:20 V ttcb unblock valley 183:12 158:8 122:8 tubular uncommon valuable 164:14 157:21 168:2 tuned underneath valve 170:25 191:1 185:14,20,24 189:15,16 turn understand 190:2 143:12 144:9 151:8,25 130:11 132:2 133:14 171:5 valves 161:1 178:10 182:13 184:14 189:5,15 192:15 178:1 understanding 186:15 206:12 vapor 196:25 198:2 202:13 130:10 132:1,4,6 142:17 132:18,20 223:22 203:20 207:10 219:15 169:5,9 172:8 197:7 209:25 vaporized turned 213:13 132:18 188:2 turning understands 148:23 vapors 204:21,22 185:14 understood varies volume 118:15 119:19241:16 vs 118:4 119:8 128:3 241:8 w waived 240:5 walk 130:12 walked 193:23 194:25 196:21 walking 193:17,18 194:4 walls 186:12 wait 129:20 waiter 124:1 128:11 wandering 200:9 want 166:13 186:7 193:13203:3 210:16 wanted 129:10 148:1 207:6 157:20 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050461 [ward - zinc] ward wetmore workers 175:24,25 176:1,17,21 166:7 160:23 161:2,18 195:8,13 177:3 we've 195:15,24 204:11 warehouse 133:19 138:3,10 175:22 working 156:18 230:19,22,24 231:5 183:25 192:16 203:17,18 155:4 162:15 176:18 231:6 232:14,24 211:24 196:10 warehousing whereof world 153:22 154:5,6 156:4,6,10 243:18 151:7 156:19,25 181:12 182:5,8 whew written 182:11 202:11 211:23 225:2 153:6 warner white wrong 122:20 160:23 161:2 200:23 166:17 wash 192:6 200:1 Washington 122:21 123:5 waste 184:17 199:4 water width 181:21 william 118:14 119:18 128:2 166:1 166:11 208:16,21 237:15 238:1,10241:16 williams X xylene 1838 xyz 154:3 156:5,18 y 158:9 169:12,15,16 191:22 171:11,13,20 172:21 173:5 yankee 192:7 200:1 206:24 207:1 173:7,10 160:21 207:10,13,15,17,18,20,20 wiped yard 207:22 151:14 201:11 waters Wisconsin yates 169:17 123:4 227:12,13,14,17 watson wise yeah 129:13 226:22 127:20 175:6 179:9 186:22 ways withdraw 190:25 199:5 202:12 136:19 190:9 210:22 wbp witness year 236:1 138:7,15 162:5 164:1 165:4 150:15 wearability 166:17 167:3,6 170:7 years 196:5 179:19 202:21 209:16 156:23 wearing 214:13,19217:25 225:18 yesterday 194:19 229:3 233:19 235:21 238:1 130:3 150:10 154:12,13,20 weather 239:14,16,25 240:4,11 159:5 162:11 232:11 week 159:7,19 weeks 243:18 wlavey 120:20 wobus zinc 203:8 z 161:14 140:1 welcome word 129:8 132:22 135:9 137:12 169:6 wendlene 186:7 205:7 120:13 words wendy 148:21 186:8 200:8 203:22 128:8 216:12 went work 195:21 215:24 216:18 146:21,24 155:21 160:20 223:24 236:11 161:5 197:20 237:1 west worked 124:6 130:13,24 145:19 154:18 westinghouse 155:2 178:25 worker westvaco 195:19 120:12 128:9 Papageorge, William; McWane (2) (Former Monsanto Employee) WATER PCB-SD0000050462