Document 7eq4g7pGp82eqGoeyGneEMma
^ jFoshee & Turner, i . Condenselt! TM
lTbn
jr^ ______ Joe Webb
1 IN THE UNITED STATE5 DISTRICT COURT 2 northern district of Alabama 3 EASTERN DIVISION
1 APPEARANCES 2 3 Appearing For The Plaintiffs:
A
Page 3
WALTER OKENS, at al.r
6
Plaintiffs,
7
9 vs.
i CIVIL ACTION NO.
9 i CV-P-440-E
10 MONSANTO COMPANY,
11
Defendant-
12
13 DEPOSITION OF: JOE WEBB
14
IS In accordance with Rule 5 (d) of The
16 Alabama Rules of Civil Procedure, as Amended#
17 effective May 15, 19B9, I, TAMMY JENNINGS
IB GREGORY, am hereby delivering to MR. DREW WRIGHT
19 the oriclxial transcript of the oral testimony
20 taken or. the 3rd day of November, 1999, along
21 with exhibits.
22 Please be advised that this is the same and
23 not retained, by the court reporter, nor filed
5 MITHOFF & JACKS, LLP 6 By: Drew Wright, Esquire 7 and Laura Ruth, Esquire 8 111 Congress Avenue, Suite 1010 9 Austin, Texas 78701 10 11 Appearing For The Defendant: 12 13 SMITH, HELMS, MULLISS & MOORE 14 By: Michael E. Kelly Esquire 15 300 North Greene Street 16 Suite 1400 17 Greensboro, North Carolina 27401 18 19 Court Reporter: 20 Tammy R. Jennings Gregory 21 22 23
Page 2
1 with the Court.
1 INDEX
2 The deposition of Joe Webb was taken before
2
3 Tammy R. Jennings Gregory, commencing at 10:00
3 Witness: Joe Webb
4 A.M. on the 3rd day of November, 1999, by the
4 Stipulations...........................page 5
5 Plaintiffs, at the law offices of Fite & Miller,
5 Examination by Mr. Wright............. page 7
6 Anniston, Alabama pursuant to the stipulations
6 Examination by Mr. Kelly...............page 98
7 set forth herein.
7 Further Examination by Mr. Wright..... page 99
8 8 Reporter's Certificate.................page 103
99
10 10
11 11
12 12
13 13
14 14 EXHIBITS
15 15
16 16 Plaintiffs' No. 27...................page 17
17 17
18 18
19 19
20 20
21 21
22 22
23 23
Page 4
Page 1 - Page 4
HARTOLDMON0044414
Foshec & Turner
Condenselt! TM
Joe Webb
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Page 7
l STIPULATIONS
1 STATE OF ALABAMA, CITY OF ANNISTON,
2 3 IT IS STIPULATED AND AGREED by and
2 NOVEMBER 3, 1999, 3 10:00 P.M.,
4 between the parties through their respective
4
5 counsel that the deposition of Joe Webb may be
5
JOE WEBB,
6 taken before Tammy R. Jennings Gregory, at the
6 having been first duly sworn, was examined and
7 law offices of Fite & Miller, Anniston, Alabama
7 testified as follows:
8 on the 3rd day of November, 1999.
8
9 9 COURT REPORTER: Usual stipulations
10 10 okay?
11 IT IS FURTHER STIPULATED AND AGREED that 11
MR, WRIGHT: Yes.
12 the signature to and the reading of the
12 MR. KELLY: Yes.
13 deposition by the witness is waived, the
13
14 deposition toTiave the same force and effect as
14 EXAMINATION BY MS. WRIGHT:
15 if full compliance had been had with all laws and
15 Q.Mr. Webb, could spell your name for the
16 rules of court relating to the taking of
16 record?
17 depositions.
17 A. First, last, middle?
18 18 Q. First and last. 19 19 a. J-o-s-e-p-h, Joseph Webb, W-e-b-b.
20 IT IS FURTHER STIPULATED AND AGREED that 20 Q.And that's just -- and let me just explain.
21 it shall not be necessary for any objections to
21 Have you ever taken a deposition before?
22 be made by counsel to any questions, except as to
22 A. (Witness shakes head.)
23 form or leading questions, and that counsel for
23 Q. Let me just explain to you. Tammy is going
Page 6
Page 8
l the parties may make objections and assign
1 to try to write down everything that I say
2 grounds at the time of trial or at the time said
2 and everything that you say, and I'll just
3 deposition is offered in evidence or prior
3 show you what it's going to come out looking
4 thereto.
4 like.
5 5 It's going to be printed up like
6 6 this, and when I ask a question -- that's
7 IT IS FURTHER STIPULATED AND AGREED that
7 actually another Mr. Wright, That's my
8 the notice of filing of the deposition is waived.
8 brother, Larry -- and everything I say will
9 9 be printed up as a question, and everything
1C 10 you say will be printed up as an answer after
11 ll "A".
12 12 And so, it will help you and me if
13 13 we'll both try to say things that are easy to
14 14 write. Like, rather than say uh-huh
15 15 (indicating yes) or huh-uh (indicating no),
16 16 which are hard to write, if you'll help me
17 17 say yes or no and if you'll promise me that
18 18 you'll answer yes or no.
19 -----
19 A. All right.
20 20 Q.Or all right. That's fine too.
21 21 Also, if there is a question that I
22 22 ask, and I often do ask these kind of
23 23 questions, if there's one that is hard for
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HARTOLDMON0044415
Foshee & Turner
Condcnsclt! TM
Joe Webb
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l you to understand, please stop me and tell me
1 I understand that.
2 you don't understand it, and we'll get it
2 A. Well, I've been an operator a couple of
3 cleared up so we can let Tammy write it
3 different occasions.
4 down. Is that okay too?
4 Q.Okay.
5 A. Fine.
5 A. Okay. First time I was in operation from
6 Q.Okay. When did you start working for
6 1965 up through 1980.
7 Monsanto?
7 Q.Okay.
8 A. April 1st, 1965.
8 A. As far as in operations now. Not all being
9 Q. Okay. And do you still work for Monsanto?
9 an operator, but -
10 A. Yes.
10 Q. Right. Until 1990 was it, 1980?
ll Q.I guess it's Solutia?
ll A. 1980.
12 A. Solutia.
12 Q. 1965 to 1980. And you weren't an operator
13 Q. Right. Have you always been at the Anniston
13 that whole time, were you --
14 plant? ~
14 A. I was chief operator couple times.
15 A.Yes.
15 Q. You were chief operator. Okay. Was that all
16 Q. What did you start doing April 1st, 1965?
16 in biphenyl aroclor?
17 A. Well, I was an operator trainee in the
17 A. Yes. Now, biphenyl aroclor -- they had a
18 biphenyl aroclor department.
18 separation of it in the fall of '65, and 1
19 Q. Operator trainee. What type of job does an
19 went to the aroclor side of it.
20 operator trainee -- or did an operator
20 Q.Okay. In the fall of '65, it split up into
21 trainee do then?
21 biphenyl and then aroclor?
22 A. Well, out of the jobs they had, they were
22 A.Uh-huh (indicating yes).
23 each job listed under it's name.
23 Q.That's correct?
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Page 12
l Q. Right.
l A. Yes, two separate departments.
2 A. I started out then what they call HB4C.
2 Q.And then -- and you went into aroclor?
3 Q.Okay.
3 A.Right.
4 A. Which was just a matter of learning the
4 Q.How long did you say in aroclor from the fall
5 process, learning to run the process --
5 of 1965?
6 Q.Okay.
6 A, Around first of September, 1965 until June of
7 A.--of that particular job.
7 '12.
8 Q.The biphenyl job?
8 Q.Okay. And that was -- what happened in June
9 A. In that department, yes, which then was known
9 of '122
10 as biphenyl aroclor.
10 A. That was the final shutdown of aroclor
11 Q.Okay. So it was biphenyl aroclor at that
11 department.
12 time?
12 Q.Okay. And you were an operator that whole
13 A. Yes.
13 time?
14 Q. How long were you an operator trainee? I
14 A. Yes.
15 guess you weren't a trainee for very long,
15 Q.Did you become a chief operator in the
16 were you?
16 aroclor department?
17 A. Until we got our probationary period, which
17 A. Not in aroclor.
18 then was ninety days.
18 Q.Okay. So from the fall of'65 through June
19 Q. About ninety days. And after that, you were
19 of'72?
20 an operator?
20 A.Uh-huh (indicating yes), yes.
21 A. Yes.
21 Q. Okay. And it's hard, and I know that because
22 Q. How long were you an operator, if you
22 I say uh-huh (indicating yes) and huh-uh
23 remember? I mean, it's been a long time, and
23 (indicating no) when I'm talking too.
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HARTOLDMON0044416
Foshec & Turner
Condenselt!TM
Joe Webb
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Page 15
i You were an operator in aroclor.
1 Q. Okay. And where were you assigned in
2 In June of ' 72, what did you become then
2 operations?
3 after the shutdown?
3 A. Biphenyl.
4 A. I was assigned to the niran department.
4 Q. Biphenyl. So you were an operator in
5 Q. Okay.
5 biphenyl?
6 A. And I spent one week there.
6 A. Right.
7 Q. Okay.
7 Q. Okay. In '86. And what did you -- did you
8 A. And I was transferred back to the biphenyl
8 stay there until now or --
9 department.
9 A. No, I stayed there until around middle of
10 Q. Biphenyl then. So biphenyl from July or so
10 '90.
ll of'72?
ll Q.186 to '90. Okay. What happened then?
12 A. Right.
12 A. Transferred to the warehouse.
13 Q.And are you still in biphenyl department?
13 Q.Okay. What was your job description?
14 A. No, huh-uK (indicating no).
14 A. Warehouse. Relief operator is what they
15 Q. Okay. What was the next change after you
15 called it.
16 were moved?
16 Q. What does a warehouse relief operator do?
17 A. I went to maintenance.
17 A. Worked shipping, raw materials, unloading raw
18 Q.Okay. When did you go to maintenance from
18 materials. I was also relieving in the
19 biphenyl?
19 biphenyl department.
20 A. Around '80, 1980.
20 Q. Okay. Okay. That gets us up, I guess, to
21 Q. Okay. What was your job description in
21 '90. How long were you a warehouse relief
22 maintenance?
22 operator?
23 A. Maintenance mechanic.
23 A.Still a warehouse operator. I don't relieve
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1 Q. Okay. What did you do as a maintenance
1 anymore.
2 mechanic? 3 A. I was combination of pipe fitter millwright.
2 Q. So you're still a warehouse operator? 3 A. Right.
4 Q. Okay. And we had Mr. Robertson here before.
4 Q. With Solutia?
5 and he said there was a time when pipe
5 A.Yes.
6 fitters and millwrights were combined. Were
6 Q.And are your jobs still the same, still
7 they combined at that time?
7 unloading, shipping, with raw materials?
8 A. I was one of the first ones that went in as a
8 A. Unloading, shipping, loading finished goods,
9 maintenance mechanic.
9 unloading raw materials is the same. As far
10 Q. Yeah, he said the crafts were combined?
10 as relief operations, no, I don't do that
ll A.Right.
11 anymore.
12 Q.Was that about 1980?
12 Q.Okay. I am going to ask you a few questions
13 A. Yeah, in that neighborhood.
13 about your job as an operator. Really let's
14 Q. In that neighborhood. But before that, they
14 just talk about your job as an operator in
15 had --
15 the aroclor department.
16 A. -- separate classifications, yes.
16 A. Okay.
17 Q. Separate classifications. Okay. And how
17 Q.And that started, I think, in the fall of
18 long were you a pipe fitter millwright with
18 '65; is that right?
19 the maintenance department?
19 A. Right.
20 A.From '81 to '86. '80 to '86.
20 Q. We have an exhibit that I'm going to show
21 Q. '80 to '86. And what happened in '86 then?
21 you, which is an aerial photograph from 1969,
22 A.Parathion department was shut down, and I was
22 I think.
23 cut back to operations again.
23 And let me first show it to Mr.
Page 13 - Page 16
HARTOLDMON0044417
Foshee & Turner
Condcnselt! TM
Joe Webb
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Page 19
1 Kelly. And it's -
1 you?
2 MS. RUTH: This is the same one,
2 A. Yes.
3 Drew. I'm not sure which one's easier for
3 Q.And to 202 curves around?
4 this purpose.
4 a. Yes.
5 MR. WRIGHT: Okay. Yeah, actually
5 Q.That's correct. Now, where was the aroclor
6 I'll show -- there's another photograph of
6 department at this time? Do you -- I know
7 the same area, and this is actually the one I
7 it's been thirty something years.
8 want to work on because I think it may be a
8 A. It was actually considered the south,
9 little easier to orient. And you see the
9 southeast part of the plant.
10 date at the top says 3 T 0-69; is that
10 Q.Okay.
11 correct?
11 A. Not in the complete eastern part but in the
12 A. Yes.
12 south part of the plant.
13 MR. WRIGHT: And let's mark this as
13 Q.Okay. And we've had testimony before that
14 an exhibit,"and let's just ask Tammy what's
14 said the plant was divided up actually into a
15 the next number?
15 north and a south plant; is that correct?
16 COURT REPORTER: 27.
16 A.That's the way it was, you know. Everybody
17 MR. WRIGHT: 27.
17 just said that's the north side of the plant,
18 18 south side of the plant.
19 (Plaintiffs' Exhibit Number 27 was
19 Q.Okay.
20 marked for identification and
20 A. Which probably Fifth Street was the dividing
21 copy of same is attached
21 point, yes.
22
hereto.)
22 Q.And aroclor at that time was south -- was in
23 Q.And it's been labeled 27; is that correct?
23 the south plant?
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i A. Yes.
l A. Yes.
2 Q. Okay. Does that look like -- and I'm not
2 Q.And it was the southeast side?
3 sure how we need to orient it. I'm not
3 A. Southeast of Fifth and Duncan.
4 exactly sure where the Monsanto plant is.
4 Q. Around Fifth and Duncan?
5 A.This is the old Highway 202.
5 A.That's the way they used to call the
6 Q.Okay.
6 streets. They were streets really at one
7 A. This is the south side; this is the north
7 time.
8 side.
8 Q. Okay. And was it something that you could
9 Q.Okay.
9 mark on this map? I don't know - I know
10 A. This is east.
10 it's been a long time.
11 Q. Okay. We've got it oriented now so the
11 A. Best I can see it.
12 3-10-69 is facing you so you can read it; is
12 Q.Okay.
13 that correct?
13 A. Well, this is Fifth Street coming across
14 A. Right.
14 here.
15 Q. Okay. And where would the Monsanto plant be?
15 Q. Okay. Can you mark Fifth Street -- can you
16 A. This area right here (indicating), west of
16 mark an "X" for Fifth Street just on top of
17 Highway 202.
17 it?
18 Q.Okay. And it seems to be the biggest group
18 A. Actually coming right through there
19 of buildings on the map; is that true?
19 (indicating).
20 A. Yes. This area here from the railroad to the
20 Q. Okay. And where do you think the aroclor
21 curve in 202.
21 plant would be?
22 Q. Okay. And the railroad seems to be
22 A. Be in this area right here (indicating).
23 diagonally across the - I guess the top for
23 Q.Let's circle the aroclor plant.
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HARTOLDMON0044418
Foshee & TurnerCondcnselt! TMJoe Webb
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1 A. Okay.
1 A.That's where the --
2 Q.And I don't know if it's going to show up or
2 Q. -- operating control room?
3 not. Maybe a blue will show up a little
3 a. Operating -- well, the operating control room
4 better.
4 was on the second level.
5 A. In between.
5 Q.Okay.
6 Q. Yeah, it's tough on black and white. Maybe
6 A. Most of the vessels was considered to be on
7 green will help.
7 the second level.
8 A.I don't know. I believe yellow might be the
8 Q. Okay. And what was on the first level?
9 best.
9 A. Pumps for tanks -- you pump tanks out with.
10 Q. Yeah, we can highlight around it which will
10 Q. Uh-huh (indicating yes).
11 help on the overhead -- I mean on the
31 A. Flaking, bagging, drumming area, storage of
12 original.
12 bags, drums, several other things. Flaking
13 A. (Witness drawing.)
13 areas, drumming areas.
14 Q.And that w'as the aroclor plant right there?
14 Q. As an operator, where did you spend most of
15 A. Yeah.
15 your time in that building?
16 Q.And you've marked that with a yellow
16 A. On the second level the majority of the time
17 hi-liter; is that correct?
17 and in the operating area and control room.
18 A. Right.
18 Q. Would you from time to time go down to the
19 Q. So it appears to be just to the south side of
19 first floor?
20 Fifth Street?
20 A. Oh, yeah, you had to go downstairs all during
21 A.Yes.
21 the shift, I mean, but you didn't stay on the
22 Q. Is that right?
22 bottom floor. It was just going down there,
23 A.Yes.
23 like, to start a vessel pumping out or to get
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1 Q. Okay. What did the aroclor plant contain at
i material to put on the elevators to send to
2 that time, if you remember?
2 the second floor.
3 A. Are you talking about vessels or --
3 Q. Okay. And we haven't had too many people
4 Q.Well, let's go to the buildings first.
4 talk about the third floor. Did you spend
5 A. We called it the aroclor building -
5 much time on --
6 Q.Okay.
6 A. It actually - I don't guess you consider it
7 A. -- which was the only building actually in
7 a floor. It was just platforms.
8 what we considered the aroclor department.
8 Q.Okay.
9 Q. Right.
9 A. Steel girders with open mesh -
10 A. Which consisted of the operating area,
10 Q. Platforms that you walked on?
11 control room, a maintenance shop on the lower
11 A. -- metal grating with handrails that you
12 floor, control room being on the second floor
12 walk. And these jets were just mounted for
13 of the building.
13 the height in the top of the building.
14 Q.Okay. So one building that was two stories?
14 Q. Okay. And they were like catwalks?
i 5 A. Just a long building, actually multistory.
15 A. Catwalks, yes.
16 You could probably say it was three story.
16 Q. Was there anything on the roof that you
17 Q. Three stories?
17 remember?
18 A. Yeah.
18 A. Not on the roof of the building.
19 Q. What was on the third story?
39 Q.Okay. Okay. Was there anything outside of
20 A. Operating department was where the jets,
20 the building that was also an additional part
21 vacuum jets, were located, which would be in
21 of the building, anything that you all
22 the highest part of the building.
-
22 utilized that was outside of the building?
23 Q.Okay. And what was on the second floor?
23 A. We had tanks that was outside of the
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HARTOLDMON0044419
' ,. i<>
Fo.shee & TurnerCondenselt! TM__________________________________________ _______ _____________Joe Webb
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l building, like, on the second floor, set
l Q.Okay. Was it always 1142 in these roof
2 outside of the building --
2 tanks?
3 Q.Okay.
3 A. In one of them particularly it was always.
4 a. -- over the roof of the first level.
4 Q.Okay.
5 Q. Okay. So they were under roof, but they were
5 A. The other one you could put different
6 actually --
6 products in it.
7 A.No, this tank was actually out in the open,
7 Q. Does that mean that most of what you made was
8 but it was mounted outside of the building
8 1142 and/or 1242?
9 structure --
9 A. I would say yes. The biggest production
10 Q.Okay.
10 volume wise of liquid aroclor, yes, was 1242
li a. -- on steel beams holding it up.
11 finished good, 1242.
12 Q. And what did it contain?
12 Q. Right. What other types of, 1 guess,
13 A. Aroclor 1242. Which we called it a roof
13 formulas of aroclor would have been in this
14 tank, which was a feed tank for the aroclor
14 other roof tank? And is formula a good way
15 stills.
15 to --
16 Q. So the roof tank was really off to the side;
16 A. Well, we didn't use -- we didn't use that one
17 is that correct?
17 a whole lots because didn't have to have the
18 A. To the outside, the east side of the
18 capacity for it, so a lot of times, it would
19 building.
19 set there empty.
20 Q.East side. How many -- there was one roof
20 Q. Empty. Would you put other aroclor mixtures
21 tank?
21 in there when you were making those?
22 A. Two.
22 A. Very -- I mean, very rarely. I can't
23 Q. Two roof tanks. So the roof tanks weren't
23 remember really putting much in it because
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i technically on the roof; is that correct?
1 other stuff we'd just feed out of the other
2 A.No, they weren't on the roof. .They were
2 tanks.
3 supported on their own structure. There was
3 Q. You wouldn't really need to put it in a
4 a loading dock platform or the lower floor of
4 holding tank?
5 the building, which was roofed in. They were
5 A. Huh-uh (indicating yes).
6 actually cantilevered, I guess you'd say, on
6 Q. Does that mean you wouldn't make that big a
7 the outside of the building over the roof.
7 batch of the other aroclor mixtures?
8 Q. On the top of the loading dock?
8 A. We wouldn't be making that production of
9 A. Uh-huh (indicating yes), over it.
9 that.
10 Q. And they were about second floor?
10 Q.Okay.. Another thing you mentioned on the
11 A. Yes, you walked - well, one roof tank, it
11 bottom floor was, I think, a flaking
12 was almost what you'd called almost third
12 operation?
13 level because it was outside a building, and
13 A. Yes, there was what you called two flakers.
14 you had to go up a flight of stairs to get to
14 One of them was a solid aroclor flaker.
15 it.
15 Q.Okay.
16 Q. And you said aroclor 1242 was in the holding
16 A. One of them was a biphenyl flaker.
17 tanks?
17 Q.Okay. Can you just tell me the difference
18 A. 1142. I made a mistake when I said 1242.
18 between the solid aroclor flaker and the
19 Q.Okay.
19 biphenyl flaker? Were they pretty much the
20 A. Crude aroclor was 1142.
20 same, or were they very different or --
21 Q. Right. And when it becomes distilled, it
21 A. Different. The biphenyl was just a -- about
22 becomes 1242?
22 a three foot probably twenty-four inch in
23 A. 1242.
23 diameter drum, rotating dram, that --
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HARTOLDMON0044420
Foishee & TurnerCondenselt! TMJoe Webb
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1 Q.Okay.
1 Q. Right. So it was wider at the top than at
2 A. -- that the biphenyl just went out on. It
2 the bottom?
3 came out, and it was put in a bag right off
3 A. Sloping down.
4 the drum. As it came off the drum, it went
4 Q.Okay.
5 in a bag.
5 A. Well, as the product came through the screw
6 The aroclor fl alter, bigger, close
6 or auger --
7 to five foot -
7 Q.Okay.
8 Q.Okay.
8 A. -- was mounted to the chute for the bag. And
9 A. -- long. About the same in diameter. Solid
9 the only thing it done was as the product
10 aroclor came down on it and then went through
10 fell down out of the chute, it brought it
11 a set of crushers or fingers to break it
11 into the bag chute.
12 on -- it went down. And it had a screw type
12 Q.Okay. And there was a bag attached to it?
13 bagger on it with a hopper.
13 A. It was just a screw. Yes, it had a nozzle,
14 It had a hopper in under it because
14 and they just slipped the bag sleeve -- the
15 there was more production on that flaker than
15 bag being made with a sleeve on it -- up onto
16 it was the other.
16 the nozzle, open valve, started the screw,
17 Q.Mr. Rich and actually Laura Ruth talked about
17 and it put the flaked product into the bag.
18 this process a little yesterday. They said
18 Q. Okay. So you could turn nozzle on and off?
19 it was kind of like a rolling pin where it
19 A. Oh, yes.
20 would pick up the flour? 21 A. They had a pan underneath them. The drum
20 Q. Okay. And when you would take the bag on and 21 off, what would happen? Would you -- well,
22 being where it could just come down and come
22 let me just ask you what would happen as you
23 in contact with the liquid.
23 took the bag on and off?
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1 Q. And the drum was like a rolling pin? It was
l A. Slipped it off, folded the sleeve in.
2 rather long --
2 Q. And then would you seal it up? Would you
3 A. Yes, it had a drive on it -
3 staple it?
4 Q.Okay.
4 A. No, it seals itself. It folded inside.
5 A. -- with cooling on the inside coming through
5 Q.Okay.
6 the inside of it, and it would just pick it
6 A.Folded inside. And they'd pick it up and
7 up out of the pan and bring it over the top.
7 weigh it and stack it on the pallet.
8 Q. And there was a blade on the other side that
8 Q. And I think Mr. Rich said that these bags
9 would scrape it off?
9 were about fifty pounds a piece?
10 A. On both of them.
10 a. When I first started, they were hundred .
ll Q. And it was on biphenyl and the aroclor. Were
11 pounds. Then they dropped back to fifty.
12 you ever an operator of those?
12 Q.Do you know when they dropped from a hundred
13 A.Not the biphenyl flaker. Aroclor flaker,
13 to "
14 yeah.
14 A. I don't remember.
15 Q. You were an operator of the aroclor flaker?
15 Q. Right. Do you remember if the flakings would
16 A. (Witness nods head.)
16 fall out of the bag as you were folding them
17 Q.Let's talk about that flaker a little bit
17 back under?
18 then. You said there was a screw type -- I
18 A. Not so much falling out of the bag I would
19 guess it's a pusher at the bottom? Let me
19 say. Some would fall off the chute.
20 let you describe it.
20 Q. It would come off the chute?
21 A. The product came down in a hopper --
21 A.They'd stopped the screw--
22 Q.Okay.
22 Q.Right, they'd stop -
23 A. -- with a sloped bottom in it.
23 A. -- and they might be a few flakes fall off.
Page 29 - Page 32
HARTOLDMON0044421
Fofshee & TurnerCondensclt!TM__________________________
Joe Webb
Page 33
Page 35
i Q. Okay. What about the hopper, how big was the
i let's just back up a little bit.
2 hopper compared to the roller. Would it
2 What was -- what were these flakes? Was it
3 catch all the flakes --
3 solid aroclor?
4 A. Oh, yes.
4 A. Solid aroclor.
5 Q. -- or would some fall off?
5 Q. Could it have been - was it 5460?
6 A. Everything went in the hopper.
6 A. 5460.
7 Q. It was bigger than that. About how many bags
7 Q. Was it 5460 every time, or were there any
8 do you figure you would fill in a day? And
8 other --
9 let's go with fifty-pound bags.
9 A. We flaked 5460 solid aroclor.
i o A. Probably about three hundred.
10 Q.Okay,
ll Q. About three hundred?
11 A. We done some 1268.
12 A. In that neighborhood.
12 Q. 1268 was also a solid aroclor?
13 Q.And was this running all the time?
13 A. It was considered a solid aroclor, yes.
14 A, Yes.
14 Q.How -- was it different from 5460?
15 Q.And I assume you had three shifts?
15 A. Yeah.
16 a. Yeah.
16 Q.How was it different, I guess?
17 Q. Would it run --
17 A. Well, was it a mixture of santowax --
18 A.It wouldn't run every shift. There would be
18 Q.Okay.
19 some shifts where maybe it would run part
19 A. -- and biphenyl.
20 time. Some shifts it may not run. Just
20 Q.Okay.
21 according to how much product you had.
21 A. And 5460 was just santowax.
22 Q. So for every bag, they would do the same
22 Q.Okay. So was it thinner than 5460? Was
23 process of pulling it off the nozzle?
23 it -
Page 34
Page 36
l A. Yeah, same thing.
1 A. It had a much higher solidification point.
2 Q.And you think for every one of those bags, a
2 It got much harder.
3 few flakes would fall on the ground?
3 Q. Okay. So it was less -- was it less brittle
4 A. Sure.
4 when you say, "harder"?
5 MR. KELLY: Object to the form.
5 A. Well -
6 Q. (By Mr. Wright) Mr, Kelly may want to
6 Q.And I don't want to put words in your mouth.
7 explain to you what he's doing. He's
7 A.It's hard to explain.
8 objecting to my form of the question, but you
8 Q. Right.
9 can answer it.
9 A. Because the two products didn't look alike.
10 . MR. WRIGHT: Is that right, Mr.
10 Okay?
11 Kelly?
ll Q. What did they look like? Let's start with
12 MR. KELLY: Correct.
12 that.
13 Q. (By Mr. Wright) And I don't want you to
13 A, 5460, if you run some out in a pan, it would
14 answer anything you feel uncomfortable about
14 look like a pane of glass --
15 answering. But Mr. Kelly will advise you on
15 Q.Okay.
16 it.
16 A. -- when it solidified. You could see through
17 MR. KELLY: Those are for the
17 it. A thinner coat, not a great big thick
18 record, and you can go ahead and answer
18 coat, a thin coat. And you could actually do
19 unless I tell you not to answer.
19 it like this (indicating).
20 THE WITNESS: Sure, there would be
20 Q. I think Mr. Rich said it was kind of yellow?
21 a few flakes fall out, like I say, every
21 A. Yellow color, yes.
22 time.
22 Q, Are you familiar with the word opaque? I
23 Q. (By Mr, Wright) Okay. Every time. And
23 mean, it's kind of like when your windows fog
Page 33 - Page 36
HARTOLDMON0044422
'**(*''
Fosbee & TurnerCondenselt! TMJoe Webb
Page 37
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1 up in the morning.
1 Q.Okay.
2 A. No, it was clear.
2 A. I wasn't down there all the time watching
3 Q.It was clear. So you could really see
3 them move it.
4 through it with a yellow tint. It was more
4 Q. Do you know where it was moved out to?
5 like sunglasses?
5 A, Some of it may have went to the landfill. I
6 A. Right.
6 don't know.
7 Q. What did 1268 look like then?
7 Q. Okay. Do you assume that it went to the
8 A. Before it was flaked and all, it had a
8 landfill?
9 grayish tint to it, but once it was flaked.
9 A. Anything that was thrown away, yeah, went to
10 it went to a whitish powder, where -- we're
10 the landfill.
11 talking about flaking -- 5460 flaked; 1268
11 Q. At that time went to the landfill. Okay.
12 peeled off in like powders. Well, in flakes.
12 Now, we've heard some talk about
13 It was ground to make it like a powder.
13 sampling of aroclor product, and I don't want
14 Q. So it was more powdery?
14 to talk about the solid aroclor now. I want
15 A. In the finished product.
15 to talk about the liquid aroclor.
16 q.Do you know what those products were used
16 How would you figure out how strong
17 for?
17 or what type of mixture of aroclor you had, I
18 A. I have no idea.
18 guess, at the distilling process?
19 Q.Yeah.
19 And if you don't understand, I
20 A. I mean, I heard might be used in glue and
20 mean, that's a little bit confusing.
21 other stuff. I don't know.
21 A. I don't understand the questions you're
22 Q. Okay.
22 asking.
23 A. I have no idea.
23 Q.Okay. That's fine. And please tell me if
Page 38
Page 40
1 Q. So the 1268 was a little finer - or was
1 you don't every time, and that's fine.
2 finer -- than the 5460; is that correct?
2 A. When you talk about grade, are you asking how
3 A. Oh, yes.
3 did we determine what grade of aroclor we
4 Q.Okay. Now, let's go back to the process
4 were running.
5 where they take the bag off the hopper and
5 Q.That's a better question, yeah. How did you
6 you said that a few flakes would fall off
6 do that?
7 each time that they take the bag off; is that
7 A. We were instructed to run specific types of
8 correct?
8 aroclor.
9 A. Yes.
9 Q. Okay. So someone would ask you to run a
10 Q. What would happen to those flakes? I assume
10 specific --
11 they fell on the ground?
ll A. - chlorinator operator.
12 A. No. Normally they kept a lid or drum lid or
12 Q. Right. Would ask you -
13 something like that there for them to fall
13 A.No. He was the one that made it. The stills
14 on, and they'd pick it up and dump it into a
14 only run what they got.
15 drum.
15 Q.Okay.
16 Q.Okay. So they kept a catch pan down there?
16 A.They didn't determine it. They run what they
17 A. Yeah.
17 got.
18 Q. And when it got full?
18 Q. Okay. Who would determine what you were
19 A. They had drums they would put it in.
19 going to run?
20 Q. Okay. What happened with the drums then when
20 A. Supervision determined what we was going to
21 they got full?
21 run. Like I say, we were running 1142 most
22 A. We reworked some of it. Some of it was moved
22 all the time. The others is what I'm saying
23 out, you know.
23 they determined that production.
Page 37 - Page 40
HARTOLDMON0044423
Foshee & Turncr
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________ Joe Webb
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Page 43
1 Q. Right. But they - so a supervisor would
1 to ask you the same questions we have
2 come to you - would he come to you at the
2 answered.
3 beginning of a shift and say this shift we're
3 The chlorinator was heated; is that
4 gonna run 1142 or 1121?
4 correct?
5 A.Normally he'd put it in a logbook if it was
5 A. They could be heated.
6 going home time or if it changed during the
6 Q.Okay. Was it generally if you're making
7 time he was there -
7 1142?
8 Q.Okay.
8 A. No.
9 A. -- he'd come up and say the next
9 Q. It was not?
10 chlorinators, charge them back for so and so
10 A. (Witness shakes head.)
11 aroclor.
11 Q. Okay. When would it be heated?
12 Q. Okay. And it would be -- the so and so would
12 A. As far as batch chlorinators, the
13 be the numbers?
13 chlorination process produced its own heat.
14 A. Right.
14 Q.Okay.
15 Q. Okay, So you knew what you were going to
15 A. Okay. You didn't worry about 1142 freezing
16 run. Say 1140. How would you determine that
16 up.
17 that's what you were running?
17 Q. Right. Were there any type numbers that
18 MR. KELLY: You mean 1142?
18 would freeze up?
19 Q. (By Mr. Wright) Well, or 1142.
19 A. Oh, yes. The higher chlorinated materials
20 A. You run it by specific gravity.
20 would -- I wouldn't say freeze up, but they
21 Q.Okay. How would you do that?
21 would get so viscus that they wouldn't flow.
22 A. You would go to the chlorinator.
22 Q. Like 1160 maybe?
23 Q.Okay.
23 A.Yes.
Page 42
Page 44
1 A. Catch a sample.
1 Q. Yeah. When you had -- when you were running
2 Q. Okay.
^
2 a batch of the 1160, would you heat up the
3 A. Carry it inside, cool it down, and use a
3 chlorinator then?
4 hydrometer to check the specific gravity of
4 A.Not as far as the chlorinator heating it up.
5 it.
5 no.
6 Q. Okay. Did you ever send anything -- so you
6 Q. The system - the process would?
7 would do that all in the aroclor building?
7 A. Downstream you keep it hot so you could use
8 A. Yes.
8 it, yes.
9 Q. Did you ever send anything out to a lab or
9 Q. Where would you keep it hot?
10 somewhere outside the aroclor building to
10 A. Usually in the blowing tanks.
11 sample it?
11 Q.The blowing tanks. And how would you heat it
12 A. Finished products, after the aroclor was
12 there?
13 distilled and put in the storage tanks, then
13 A. Steam,
14 the lab checked it. We had the lab check it
14 Q, Steam. Was there -- was it steam from all
15 to see if it met shipping specifications.
15 over the plant?
16 Q.Okay.
16 A. Steam coils from the boiler, you know.
17 A. Production specifications we -- on
17 Q. Was the boiler there in the aroclor building?
18 chlorinator ran in the department.
18 A.No.
19 Q. Just in the aroclor building?
19 Q. It was from somewhere else in the plant?
20 A. Yes.
20 A. At that particular time, the boiler was over
21 Q. Okay. And I'm going to jump around a little
21 next to the niran department.
22 bit, and it's mainly because we've got some
22 Q.And it sent steam all over the --
23 of this testimony already, and I'm trying not
23 A. -- all over the plant.
Page 41 - Page 44
HARTOLDMON0044424
Foshee & TurnerCondenselt! TMjoe Webb
Page 45
Page 47
] Q. The plant. There was a -- was there a pump
l would leak?
2 on the chlorinator?
2 A. Well, your packing type pump, you would pull
3 A. Yes.
3 snug up on the packing to stop it.
4 Q. Would the pump leak at times?
4 Q. Add more packing?
5 A. Yes,
5 A. And then we kept on, you know, if it didn't
6 Q. What kind of pump was it? Let's just
6 snug up, then should add that packing to it.
7 describe it.
7 Q. Okay.
8 A. When I first went out, most of them they
8 A. Stop it from leaking.
9 called a Durco pump, impeller type pump.
9 Q. Would it ever leak out onto the floor?
10 Q. You said another word, Durco?
10 A. Yes, at times it would.
11 A. That's the brand name of the pump.
11 Q. And is there any way you would catch those
12 Q. Could you spell that?
12 leaks?
13 A.D-u-r-c-o. That just being a brand name of a
13 A. Most all of them had a little drip pan --
14 pump. '
14 Q. Was the drip pan under the --
15 Q. And you said when you started, they were all
15 A. - set in under the pump housing to catch it.
16 --or they were all Durco. I don't want to
16 Q. Okay. And whose job was it to empty out the
17 mischaracterize.
17 drip pans?
18 A. They installed different types of
18 A. The operator on the job.
19 manufactured pumps at different times.
19 Q. So you did that?
20 Q, So that was about 1965 they were --
20 A. Yeah.
21 A.Yes.
21 Q.How often would you empty a drip pan?
22 Q. And you called them-impeller pumps?
22 A. It varied.
23 A. An impeller type pump. In other words.
23 Q. Varied on the pump?
Page 46
Page 48
i that's what moved the product with the pump
1 A. When you made your rounds finishing a batch
2 turning. It's just a series of curved blades
2 or just checking the area and you seen one
3 that picks the product up and slings it
3 that was that way, you'd empty it into a
4 around the housing of the pump to get it to
4 bucket.
5 pump.
5 Q.Okay.
6 Q. Okay. And I've heard an impeller described
6 A. Put it in a drum, you know, empty it out into
7 kind of like a propeller inside.
7 a drum.
8 A. With a solid plate.
8 Q. So you have drums on that station? I guess
9 Q. Is that accurate?
9 this is on the second floor; is that right?
10 A. Yes.
10 A.No, pumps on the ground level.
11 Q. And how did it connect to the, I guess, the
11 Q. Okay. And so you had drums that you would
12 chlorinator then?
12 empty these leakings into -
13 a. Piped to it.
13 A. (Witness nods head.)
14 Q. It was a pipe. Was there a gasket in
14 q.~ there?
15 between?
15 A. (Witness nods head.)
16 A. Yes.
16 MR. KELLY: You have to say yes or
17 Q. And was that gasket what leaked?
17 no.
18 A. No. Most leaks like that you have will maybe 18 THE WITNESS: Yes.
19 be-around the shaft.
19 Q. (By Ms. Wright) I'm sorry. I need to remind
20 Q. Around the shaft as the shaft enters the
20 you. Mr. Kelly is much better at reminding
21 pump?
21 people than I am.
22 A. Yeah.
22 And so it was the operator's job to
23 Q. Okay, And what would happen if one of those
23 empty these out?
Page 45 - Page 48
HARTOLDMON0044425
Foshcc & TurnerCondenselt! TMJoe Webb
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l A. Right.
1 A.I mean, you didn't let something leak that
2 Q. Into the drum?
2 much is what I'm saying.
3 A. (Witness nods head.)
3 Q. Okay. Do you think you'd fill one up a week,
4 Q. What did you do with them when you got --
4 one a month?
5 let's say you got a full drum?
5 A. I couldn't answer you. It wouldn't be one a
6 A. Seal them up and moved them out on the dock.
6 week.
7 and they were disposed of.
7 Q.Okay.
8 Q.Okay, And how many of these drip pans were
8 A. May not even be one a month.
9 there?
9 Q.Okay. Okay. And you said that when you got
10 A. Well, there was --
10 the barrels filled up, you'd haul them out to
11 Q. And I assume -- we've heard there was an
11 the loading dock and then you dispose of
12 expansion.
12 them?
13 A. I can't --
13 A. Right.
14 Q. We heard there was an expansion later on --
14 Q. And that meant that maintenance laborers or
15 A. There was eight --
15 someone would take them to the --
16 Q.~ in '65?
16 A. Usually it was shipping laborers.
17 A.-- eight small chlorinators. There was eight
17 Q. Shipping laborers would take them to the
18 pumps on them.
18 landfill; is that correct?
19 Q. So they would each of had
19 A. Right.
20 A.Each one of them. But all the other pumps
20 Q.Do you know where the landfill was at?
21 that was moving products would have one too,
21 A. Yes.
22 you know.
22 Q. Where was that? And maybe we should mark
23 Q.A11 over the aroclor building?
23 this on the map if it's on the 1969 map.
Page 50
Page 52
1 A. Yeah.
l A. This area right here right across Highway
2 Q.Okay. Just an estimate. So we've got those
2 202.
3 eight. How many other drip pans do you think
3 Q. Okay. Can you -- let's try to make a square
4 there were, if you know?
4 around that area?
5 A. Had to be between fifteen and twenty.
5 A. (Witness drawing.)
6 Q. Fifteen and twenty.
6 Q.Okay.
7 A. Yeah.
7 A. In that area right there (indicating).
8 Q. And how many barrels do you think you would
8 Q. And maybe even write on the outside, this
9 fill up in a day or a shift?
9 white area, maybe if we could write landfill
10 A. Oh, you wouldn't fill one up in a shift.
10 over here and then point to it.
11 Q. Not one in a shift?
11 A. (Witness drawing.)
12 A. You wouldn't fill one up in a day.
12 Q. Okay. And let's draw it over onto the map a
13 Q.Okay. So from all these fifteen, you
13 little bit. I know it's not going to show up
14 wouldn't fill up one barrel in a day?
14 too well.
15 A. No.
15 A. (Witness drawing.)
16 Q.How many days do you think it would take to
16 Q.Okay. You've drawn landfill on there;
17 fill one barrel?
17 correct?
18 A. I have no idea.
18 A. Right.
19 Q.Okay. And I guess it kind of varied, didn't.
19 Q. And you've pointed an arrow to where the
20 it? Sometimes you get more; sometimes less
20 landfill was. Mr. Kelly pointed out there is
21 sometimes?
21 a road from the Monsanto plant to the
22 A. Well, you hardly ever filled one up. -
22 landfill. Can you highlight that, too?
23 Q. Right.
23 A. (Witness drawing.)
Page 49 - Page 52
HARTOLDMON0044426
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____ Joe Webb
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Page 55
l Q.Okay. And as an operator, I assume you
l went to the one that they put the pipe in
2 didn't go to the landfill?
2 that, you know, if it was pipe, and that's
3 A. No.
3 where we put it in it.
4 Q. Did you ever go over there?
4 Q. What did you do when a pit got full?
5 A. Yes, I've been over there -- was there, yes.
5 A. I assume they covered it up. I don't know.
6 Q. Were you there at this time, I guess, between
6 I couldn't comment on it because I don't know
7 '65 and '80 that you remember?
7 what they done.
S A.I was there in the '70s. After '72.
8 Q.l guess you did come at different times and
9 Q.Okay.
9 there would be different pits that you'd be
10 A.Probably maybe '74, '75. Something like
10 told to dump into; right? .
11 that.
ll A.I only dumped into one all the times I was
12 Q. What were you doing up there?
12 over there, so, you know, that's the only one
13 A. I was in a cut back situation. I was working
13 I dumped into.
14 with maintenance laborers.
14 Q.And it was up there in that area that you --
15 Q.And so you disposed of things in the landfill
15 A. In that area (indicating).
16 around '12 then?
16 Q. -- circled? Do you know of any other
17 A. Yes.
17 landfills that the plant was using?
18 Q.How were things disposed of in the landfill?
18 A. Not at that time.
19 A. What are you talking about? Different
19 Q. Either then -- do you know any others they've
20 things.
20 used any other times?
21 Q.Okay. Let's talk about the barrels then.
21 A. I've got no personal knowledge of any of the
22 A. I never moved any barrels.
22 others.
23 Q. What did you move?
23 Q.Okay. That's fine. Have you ever heard of
Page 54
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l A, Decontaminated pipe, trash.
1 the West End Landfill?
2 Q.Okay. What would you do with them?
2 A. In last few years, I did.
3 A. Decontaminated pipe went into one of the
3 Q. Where is that, do you know?
4 landfill pits.
4 A. Somewhere in this area right over here. I
5 Q.l guess would you load it up -- would you
5 don't know exactly other than it was right
6 load it up in a truck at the plant?
6 outside the plant property where the power
7 A. Trucks, had trailers.
7 company had some stuff.
8 Q.Okay. And then you'd drive it over to the
8 Q. Could you put, I guess, maybe a triangle with
9 landfill?
9 hi-liter around where you think the West End
10 A, Drive across the road to the landfill.
10 Landfill was?
ll Q.And what would you do then?
11 A. (Witness drawing.) Best of my knowledge.
12 A. Dump it out.
12 Q.And let's write over on the side West End
13 Q.How would you dump it out?
13 Landfill and maybe put another arrow
14 A. A lot of times we threw it off by hand.
14 directing to that.
15 Sometimes we'd had to take - if it was a
15 A. (Witness drawing.)
16 bigger piece, had to have a small crane to
16 Q.And are you sure about this?
17 pick it up.
17 A.No, I'm not sure. I'm just -- I can't tell
18 Q. Who was operating the crane?
18 enough about this photograph here to say.
19 A. Usually one of the maintenance people or one
19 Q. Okay. Did you ever hear of a place called
20 of us that was qualified to operate it.
20 Clegom Lake *-
21 Q. Right. And you said that you put it in the
21 A, Yes.
22 pits. How many pits were there?
-
22 Q.-- as part of the plant? Do you think it's
23 A.I don't know exactly, I mean normally, we
23 on this map, which is Plaintiffs' Exhibit 27?
Page 53 - Page 56
HARTOLDMON0044427
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Joe Webb
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1 A. Yes.
1 Q. Well, you tell me. As an operator - so
2 Q, Where do you think it is?
2 operator included different jobs?
3 A. Right there (indicating).
3 a. Yes, there was different jobs in the
4 Q. Okay. Can you - I guess let's circle that
4 department. I mean, wasn't just one job.
5 in highlight too.
5 Q. Right. What type of jobs -- what jobs did an
6 A. (Witness drawing.)
6 operator do?
7 Q.And maybe write on the side Clegom Lake over
7 A. One of them ran the chlorinators.
8 on the side and kind of point to it too.
8 Q.Okay.
9 A. (Witness drawing.)
9 A. One of them ran acid plant.
10 Q.And what was Clegom Lake?
10 Q.Okay.
11 A. It was a pit, pond, dact (phonetic), earthen
11 A. Assisted on the chlorinator.
12 dact pit, that bottoms from the santowax
12 Q.Okay.
13 distillation was pumped to.
13 A. Had two operators on aroclor stills.
14 Q.Is Clegom Lake still there?
14 Q. Okay. If you were a -- and I assume you did
15 A. No.
15 all of those?
16 Q.Do you know what happened to Clegom Lake?
16 A. At one time or another, yes.
17 A. They cleaned it out and filled it in.
17 Q. If you were the operator of the chlorinator.
18 Q.Do you remember when that happened?
18 at the end of your shift, what would you do?
19 A. I remember, but I don't remember what year it
19 A. We had a logbook we'd write up on how many
20 was.
20 batches we finished.
21 Q.Okay. Let's see if we can maybe -- was it
21 Q.Do you remember usually how many batches
22 while you were still an operator in the
22 you'd finish?
23 aroclor plant?
23 A. Could go from three to four to thirteen or
Page 58
Page 60
1 A. No, it was later than that.
i fourteen.
2 Q. So it was after '72, after they closed
2 Q.Okay.
3 aroclor? Was it while you were an operator
3 A. According to what was running.
4 in biphenyl?
4 Q. So you write in the logbook how many batches.
5 A. Yes.
5 What else would you do?
6 Q. Which I think was between '72 and '80?
6 A. You had some of the storage tank levels that
7 A. Yes.
7 you would enter into the logbook.
8 Q.And I'm not trying to play --
8 Q.Okay.
9 A. It may be the second go around - I mean the
9 A. Not only storage tank, tank levels.
10 second time I was over there. It was
10 Q.Okay.
ll probably later than that. I don't remember.
11 A. Mostly just what times you finished a batch,
12 Q. That's fine if you don't remember. That's
12 how much you pumped out, where you pumped it
13 fine. Now, let's go back to when you're an
13 to.
14 operator in the aroclor building.
14 Q.Okay. Maybe if you loaded some off --
15 When your shift's over, what did
15 A. Well, the acid plant operator was the only
16 you do? Just tell me everything you did.
16 one that done any loading in that department.
17 Your shift's over, and, I assume, they were
17 Q.Okay.
13 eight-hour shifts?
18 A. Or if we'd drummed, we'd put down how many
19 a. Yes.
19 drums they drummed.
20 Q. Would you log in how much aroclor you'd
20 Q.Okay.
21 produced in that time? And let's talk about
21 A. Or the laborers was drumming.
22 operator with the liquid aroclor now.
22 Q. What else would you do if you were a
23 A. What job are you talking about?
123 chlorinator operator at the end of a shift?
Page 57 - Page 60
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l A. Relief comes in, tell them what was going on,
1 what would they do at the end of the shift?
2 go to the house.
2 A. Same thing.
3 Q. Did you clean the floor? Did you clean the
3 Q. Would they log how much?
4 area?
4 A. Batches they finished, where they pumped it
5 A. That was throughout the shift. You didn't do
5 to.
6 it at -- I mean, you just cleaned up, you
6 Q. Okay. Would they have spills at their
7 know, through your shift.
7 operations too?
8 Q. What did cleaning up imply? What did you do
8 A. I guess, yeah, all of them have.
9 when you were cleaning up?
9 Q. Okay. And they do the same kind of thing.
10 A. You picked up anything that had fell, a nut.
10 Would they put sand on it?.
11 bolt, gasket. If you had product -- if you
11 A. Well, yes. Some of it was thick enough you
12 seen a product leak, you'd put some sand on
12 could just shovel it up by itself.
13 it, clean it up.
13 Q. And again, they'd put them in the -- boxes?
14 If it was a leak, you know, put an
14 A. May have in the drums or skips.
15 MRO in to get it fixed if you couldn't
15 Q. Okay. And Mr. Webb, we've got candy there if
16 tighten it up with your channel locks.
16 you-
17 Q.What is an MRO?
17 A. I wouldn't care for anything.
18 A. Maintenance request order.
18 Q. And if you ever want to take a break, just
19 Q. Maintenance request order. Okay. And how
19 tell me if you need to go to the bathroom,
20 would you clean the leaks? You mentioned you
20 get some water, anything. It's not going to
21 put sand on it.
21 take a whole lot longer.
22 A.To dry it up. Shovel it up, put it in a
22 Do you remember an expansion to the
23 wheelbarrow and dump it in the skip.
23 aroclor plant around 1969, 1970?
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1 Q. What's a skip?
1 A. Yeah.
2 A. Metal container, box type container that the
2 Q. Can you briefly describe that?
3 truck would pick up to move.
3 A. Well, they installed a couple of new
4 Q. Where would they move it?
4 chlorinators.
5 A. Move it to the landfill.
5 Q.Okay.
6 Q. Landfill. What if it was a bigger spill?
6 A. Solid chlorinators. Built a tank farm.
7 Well, did you ever have spills that you
7 Q.Okay.
8 couldn't clean up with sand?
8 A. Put in additional aroclor -- solid aroclor
9 A. Not that I was ever around, you know.
9 still with pipes and this, that, and the
10 Q. And we've heard there were other things that
10 other. They installed a 1268 flaker that
11 you used to clean it up besides sand. There
11 never ran.
12 was -- I can't remember the name, but it was
12 Q. You say it never ran?
13 like kitty litter.
13 A.Never made any to go in it. Never made
14 A.Drys It --
14 anymore to go in it.
15 Q. Right.
15 Q. Why was it never --
16 A. -- was the trade name of one particular type.
16 A.They wasn't selling the product.
17 Q. Would you ever do anything else to clean it
17 Q.Okay.
18 up? Would you hose it down?
18 A. Done some improvements. Expanded the control
19 A. Sure. There was times after you get all that.
19 room. Stuff like that.
20 up you wash it down to remove all the stuff
20 Q. Do you remember when those -- that expansion
21 off the floor.
21 was finished?
22 Q.Now, this is -- that's a chlorinator
22 A.Not the particular date. Somewhere around
23 operator. What were the still operators,
23 late, you know, late '69, '70.
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1 Q.This -- and I'm looking at Plaintiffs'
1 Q. -- what happened with -- what happened when
2 Exhibit 27. The date on that says 3-10-69.
2 it was dismantled. I assume they took it
3 Can you tell just eyeballing it if the area
3 apart?
4 you circled as the aroclor unit was expanded
4 A. Took it apart.
5 at that time or is it that before the
5 Q. What did they do with the equipment?
6 expansion?
6 A. I have no idea.
7 A. I can't tell.
7 Q. Okay. Do you know what they did with the
8 Q.Okay. That's fine. Yeah, it's pretty hard
8 building?
9 to tell anything.
9 A. They just tore it down. I don't know what
10 A. Well, I see the tank farm over there.
10 they done with it.
ll Q.Okay.
11 Q. Sure. And you said the tank farm was not
12 a. Somewhere, yeah, probably is. I think that's
12 dismantled?
1 3 the catwalk across the road right there.
13 A.No.
14 Q.Okay.
14 Q. What happened to the tank farm?
15 A. So more than likely, it's on that one there.
15 A. It's still in existence.
16 Q. Where is the tank farm?
16 Q. Still in existence today. What is it used
17 A. Right north of Fifth Street. Right across
17 for now, do you know?
18 Fifth Street.
18 A. It's used for other storage now.
19 Q. Just north -- so it's across Fifth Street
19 Q.Okay. What do they store in it, any idea?
20 from the rest of the aroclor?
20 A.Therminol 66, therminol BP1, DPO, diphenyl
21 A. Right.
21 oxide, mostly just therminol products, I
22 Q. Is it included in the area that you circled?
22 mean, different grades of therminol.
23 A.No.
23 Q.Okay. Have you ever heard of a product
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1 Q. Can you highlight that, I guess, the tank
l called montar?
2 farm?
2 A. Yes.
3 A. (Witness drawing.)
3 Q. What is montar?
4 Q. Okay. So when this picture was taken, the
4 A. Was the bottoms off aroclor still
5 tank farm was either being built or it was
5 distillation or residue. We called them
6 completed; is that correct?
6 bottoms.
7 A. Yes.
7 Q. Okay. And it was the product left over after
8 Q. And that was part of the expansion?
8 a few distilling processes?
9 A. Yes.
9 A. After final distillations, yes.
10 Q.Now, when the aroclor division -- I guess it
10 Q. What was - was it used for anything? You
11 shut down in 1972; is that correct?
11 may not know.
12 A. Final shutdown, yeah.
12 A. Liquid montars, no.
13 Q. Final shutdown. What happened then? What
13 Q.Okay. What was done with the liquid montars?
14 happened with these facilities?
14 A.Drummed out.
15 a. Well, we took them out of service.
15 Q. Okay. How would you drum them out of the
16 Q.Okay.
16 stills?
17 A. Prepared them to be dismantled.
17 A. Well, to start with we, just lined the drums
18 Q. And was it dismantled?
8 up underneath the drumming hood.
19 A. The operating department was. The tank farm
19 Q.Okay.
20 wasn't, but the operating area was.
20 A. And we just --
21 Q.That building that was two, three stories
21 Q. Where was the drumming hood --
22 that you described -
22 A. - fill them up.
23 A. Yes, uh-huh (indicating yes).
23 Q.-- underneath the stills; is that correct?
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1 A. The drumming hood now was under number one
l A. It may be five; may be seven.
2 aroclor still.
2 Q.Okay. So around there. What was the process
3 Q.Okay.
3 for making solid aroclors, I guess 5460,
4 A. Later on they had a runway with a different
4 which is also -- 5460 is also santowax; is
5 place to drum it off, and it had a roller
5 that right?
6 type conveyor to carry the drums out from
6 A, Right, santowax.
7 under the filler spout and out of the
7 Q.Right, It's s-a-n-t-a-w-a-x?
8 building on the dock.
8 A.T-o-w-a-x.
9 Q. Okay. How much montar would you drain out of
9 Q.Okay.
10 a still, do you remember?
10 a. Essentially the same process.
11 A. It varied.
11 Q.Okay.
12 Q. Would it be one barrel?
12 A. But it was just --
13 A. More than that.
13 Q. So they go through the chlorinator -
14 q.Two barrefs?
14 A. The chlorinator.
15 A. It would be ten.
15 Q. -- and run through the still?
16 Q.Ten?
16 A. Still. Then it was - as it was distilled
17 A. Smaller still you may get four. Big still,
17 over and condensed back down, it came out as
18 solid still, you may get twenty, twenty-five.
18 what we called 5460 or solid aroclor.
19 q.How often would you drain these bottoms, this
19 Q.Okay. So it was just thicker than 1142?
20 montar out of the still?
20 A. Yeah. You're talking about liquid as opposed
21 A. Liquid still was after every ten batches.
21 to solid. When we say, "solid," means it
22 Q. Okay. After every ten batches?
22 will set up solid.
23 A. Ten batches.
23 Q. Right. After it gets distilled.
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1 Q.And you could get maybe ten barrels at that
l A. After it gets --
2 point?
2 Q.Obviously it's not solid in the still.
3 A,Not - usually wouldn't get ten barrels off
3 A. No.
4 the liquid still. I'm talking about liquid
4 Q. Could you tell as it was going through the
5 still now.
5 process that it was solid versus liquid? And
6 Q.Right. Let's talk about the liquid still,
6 I guess that's hard to describe because all
7 yeah.
7 this process is closed, isn't it? You really
8 A. You probably get maybe five drums, something
8 can't see inside.
9 like that.
9 A. What I'm saying - I'm going to tell you, it
10 Q. Okay. And what would you do with that, or
10 wasn't solid until it went over that flaker.
11 what was done then with this?
11 Then it became solid.
12 A. Moved to the dock and moved out.
12 Q. Right. As it gets around room temperature?
13 Q.Okay. Was this dumped into Clegorn Lake, do
13 a. Rest of the time it was liquid. It stayed
14 you know?
14 liquid because it was kept heated.
15 A.Not when it was put in drums it wasn't.
15 Q.And I guess my question is: Is heated liquid
16 Q. If they were put in drums, where were they
16 5460 - does it look the same as heated
17 taken?
17 liquid which is always liquid, 1140 or
18 A. Carried to the landfill.
18 something?
19 Q. To the landfill. About how many barrels do
19 A.NO.
20 you think you would get out of each liquid
20 Q. What did it look like? What did 5460 look
21 still?
21 like when it's heated and when it's liquid?
22 A. It varied on what product you was running.
22 A. It was a yellow liquid.
23 Q.Okay.
23 Q.Okay, Was it thicker than one of the liquid
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1 ones?
1 Q.And I know it's been a long time.
2 A. Yes.
2 A. Looks like it was what they called an annual
3 Q. Okay. I guess that's really all I was
3 plant inspection.
4 asking.
4 Q.Uh-huh (indicating yes).
5 A. Yeah.
5 A. And the recommendations from the 1968
6 MR. WRIGHT: Can we take a break
6 inspection listed housekeeping number two.
7 for about ten minutes?
7 "Emphasis placed on insulation in department
8 MR. KELLY: Sure.
8 expansion,"
9 MR. WRIGHT: I probably only have
9 Q. When they say "emphasis placed," do you think
10 about twenty more minutes left.
10 they wanted more insulation?
11 (Short recess. )
J1 A. More than likely, yes.
12 Q.(By Mr. Wright) Mr. Webb, I'm going to hand
12 Q. It may have just been cold.
13 you --I'll hand to Mr. Kelly first -- an
13 A. (Witness nods head.)
14 exhibit we'used with Mr. Rich.
14 Q. There's another -- I'm going to turn it
15 It's Exhibit Number 26. It is
15 around real quick. I'm having trouble
16 numbers DSW085378 through 085433 and it says
16 reading upside down.
17 "Welcome to the Anniston plant" at the top
17 Okay. Can I ask you also about the
18 of it.
18 same page DSW085433? There's a bullet, and
19 You may want to look at that. Your
19 it's labeled safety number three "Major
20 name is on there, and I know this is going to
20 project underway to eliminate bum hazards."
21 be a blast from the past and you may not have
21 Do you remember that?
22 seen it since 1969, but I just want to ask
22 A. Oh, yes. That was program to eliminate
23 you a few things about that. If you just
23 personnel from getting burned.
Page 74
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J want to take a minute or two to look over it
1 Q. Okay.
2 -- yeah, and your name is right there -- you
2 A. Because everything was so hot, especially
3 can just familiarize yourself with it.
3 around the solid aroclors. All lines having
4 MR. WRIGHT: We can go off the
4 to be heated --
5 record.
5 Q.To keep it solid?
6 (Discussion off the record.)
6 A.-- with something besides steam cause steam
7 Q. (By Mr. Wright) Mr. Webb, I really just
7 will bum you just as bad as anything or
8 wanted to ask you about a couple things.
8 tubing, but this is using different type
9 First of all, your name is on this --
9 heats, and that was the focus.
1C A. Yes.
10 I mean, at that time, we'd probably
11 Q.~ is it not? That's your name Joe Webb
11 more than likely had several people with
12 which looks like it's on page thirty-five,
12 first aid bums, bumped against it.
13 which is also DSW085434?
13 Q. So when they say, "bums," they mean
14 A. Yes.
14 temperature burns rather than chemical bums?
15 Q. And let me ask you specifically about this
15 A, Yeah.
16 housekeeping number two, which is on page
16 Q. Let me just -- one more thing. Okay. I
17 thirty-four DSW085433. Could you read that
17 think those are the only questions I have for
18 for the record?
18 that. Before -- let me just go back over a
19 A. "Emphasis placed on insulation in department
19 couple things we've talked about.
20 expansion."
20 You said that you were -- when you
21 Q. Do you remember what that particular event
21 went to the still -- to the still. I'm
22 meant? Were you a part of that? -
22 sorry, -- to the landfills, one of the things
23 A. Well --
23 that you unloaded into the landfill was --
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] and let me make sure I've got this right - -
l Q. Right.
2 decontaminated pipes; is that correct?
2 A. And these bugs was, I guess, trained to eat
3 A. Yes.
3 parathion, you know what I mean.
4 Q. What were decontaminated pipes?
4 Q. How big were these basins?
5 A.That's what we called pipes that was moved
5 MR. KELLY: I'll get you a few
6 from the parathion area.
6 depositions.
7 Q.Okay, And what was -- was there a process by
7
MR. WRIGHT: From the bugs?
8 which they were decontaminated?
8 THE WITNESS: They're big. They
9 A. Yes. Some of them were washed, steamed.
9 were big.
10 Some even put in the waste treatment basins
10 Q.(By Mr. Wright) Okay. Where is this waste
11 for parathion.
ll treatment plant? Was it in existence in 1969
12 Q.Okay.
12 on this map?
13 A. Then was taken out, washed, all this, that.
13 A.Not the one I'm talking about.
14 and the other. Decontaminating them with --
14 Q.Okay.
15 Q. - the parathion?
15 A. But the other one -
16 A. The parathion off of them.
16 Q.It may not even be on the map.
17 Q.So a pipe that had been used in parathion -
17 A.It's on here, but it's hard to distinguish on
18 A. Yes.
18 these pictures and all here. There's the old
19 Q.~ those were the only ones which were
19 - two of the waste treatment basins right
20 decontaminated?
20 there.
21 A.That's the only ones that I moved.
21 Q.Okay.
22 Q. That you moved. Okay. And have you heard of
22 A.That's all they had at that particular time.
23 Mr. -- well, let me just tell you. Mr.
23 Later on they built more, but this is all
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1 Robertson this morning talked about a
l they had.
2 decontamination pit that was used for some
2 Q.Let's highlight those.
3 things. Do you remember anything like that?
3 A. Well, that's not the ones I'm talking about.
4 A.That was over around the niran area.
4 Q. Okay. But those were -- and let's also write
5 Q.Okay.
5 -- they're over toward the Plaintiffs'
6 A. And later on when I was involved with
6 Exhibit marker, and maybe if we can put one
7 maintenance and all that, they didn't use --
7 other arrow, and you might just call those
8 they didn't have the pit. They was using the
8 waste treatment. Okay.
9 basins and whatnot.
9 Waste treat there with an arrow.
10 Q.Do you remember the pit?
10 And what you've highlighted were basins at
11 A. I don't remember it, no.
ll that time; correct?
12 Q.Okay. What were decontamination basins then?
12 A.Uh-huh (indicating yes).
13 A, Really they was waste treatment because
13 Q. Decontamination basins?
14 everything that came out -- the plant had
14 A. We called them basins. They were actually
15 their own and still got their own waste
15 concrete basins, pits, but they were just
16 treatment plant.
16 slightly above ground level.
17 Q.Okay.
17 Q. Could they have been called decontamination
1_8 A. And it was just one of the basins they -- one
18 pits, or is that different?
19 Tih'talking about put it in the basins --
19 A.No, no.
20 they would put it in there, and the bugs in
20 Q.That was different?
21 that basin would eat up all the parathion.
21 A.Through the plant, there's several different
22 Q. Okay. The bugs. Do you mean real bugs?
22 places that had decontamination points where
23 A. Waste treatment plant works on bugs.
23 they would decontaminate the -- even the
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] shops had them where they carried pieces of
1 A. (Witness nods head.) Lot of associated
2 equipment in to work where they would
2 equipment and holding tanks, clarifiers.
3 decontaminate them before they carried them
3 basins, air raters, you know.
4 in to work on them.
4 Q.Okay. We've mentioned--when we put montar
5 Q.Okay.
5 into drums, you mentioned that if they were
6 A. Which all of that cleanup, steam, water, and
6 put into drums, they were taken to the
7 all that went to a line that went to waste
7 landfill?
8 treatment.
8 A. Liquid aroclor bottoms, yes.
9 Q. Okay. Now, did all steam water cleanups in
9 Q. Right. Okay. Were there ever any bottoms
] 0 the plant go to waste treatment?
10 that you know of taken to Clegom Lake?
11 A. No.
11 A. Yes, at one time they were.
12 Q. What about in the aroclor building, for
12 Q.Were they drummed?
13 example?
13 A. No, they were put in what they call a buggy.
14 A. No.
'
14 Q. What was a buggy?
15 Q. Where did they go?
15 A. Just a little two-wheel trailer with a tank
16 a. They went to the sewer and presumably out of
16 on it.
17 the plant.
17 Q. Okay. So like a small tank car?
18 Q.Okay.
18 A. Yeah.
19 A. When you say waste treatment, this was to the
19 Q. Okay. And I want to talk now when you were
20 parathion area, pnp, and all that.
20 taking decontaminated pipes and some of the
21 Q. So parathion is really -- are those the only
21 other things to the landfill places. The
22 wastes that you know of that went to the
22 different pits that things were dropped into.
23 waste treatment in '69 for example?
23 how big were they, do you remember, or were
Page 82
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1 A. At that time, yeah.
1 they different sizes, different --
2 Q. Okay. Let's talk a little bit about those
2 A. They were different -- you know, the one I
3 waste treatment basins. So were they used
3 seen -- some of the others, you know, I seen
4 exclusively with parathion? And I want to
4 that they were putting other stuff in other
5 talk later than 169 now, I think, about the
5 than the one we were putting in, different
6 time that you were working with the
6 sizes.
7 decontaminated pipes and taking them to the
7 Q. So at the time you were taking decontaminated
8 landfill.
8 pipes and the other things that you described
9 A. Later on, they tied in some other portions to
9 to the one pit, there were also people taking
10 the plant.
10 other things to other pits; is that correct?
11 Q.Okay.
11 A. Oh, yeah.
12 A. At '69, it was strictly used for pnp
12 Q. Do you know were they broken up? You would
13 department-
13 take some things to one pit?
14 Q.Okay.
14 A. I don't know because like I say, I didn't --
15 A. -- places around -- they had a couple places
15 Q. Right.
16 around the maintenance shop where they
16 A.-- do this under a regular basis. I was
17 decontaminated equipment that went to the pnp
17 temporary in the job that I was working.
18 sewers that wound up to the waste treatment.
18 Q. And they just told you take this to this pit?
19 Q.Okay. And a waste treatment basin, is it
19 A. (Witness nods head.)
20 kind of like the water plant --
20 Q. And you said you only dumped things into that
21 A. Exactly the same.
21 one pit?
22 Q. -- out on the interstate? Okay. And those
22 A, Well, the pipe and stuff, you know, trash and
23 are what the basins are?
23 stuff like that, it went somewhere else, you
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1 know.
l A. Yes.
2 Q. Where did the trash go?
2 Q.Do you remember how many if you had any PCBs
3 A. The paper trash and wood trash we had - at
3 in your blood?
4 that time, they had a TP incinerator that
4 A. Yes.
5 they put paper and wood and stuff in.
5 Q. What was that -- do you remember how much?
6 Q. What time was this, what time period?
6 A. A hundred and five.
7 A. I was over there back and forth several
7 Q. A hundred and five. When was this tested?
8 times, but I was just temporary for a few
8 A. Two or three years ago.
9 days when I was there.
9 Q. Why did you have it tested?
10 Q. Where was this incinerator? Was it up near
10 A. Well, we seen everybody else was having
11 the landfill?
ll their's tested.
12 A. It was in the landfill.
12 Q. People at the plant; is that correct?
13 Q. It was in the landfill?
13 A. Well, outside the plant.
14 A. Yeah.
14 Q. Outside. Where did you have it tested?
15 Q. And you called it TP?
15 A. In the plant.
16 A. Well, that was the shape of it.
16 Q.In the plant. We've heard -- I guess Mr.
17 Q, It looked like a TP, like an Indian TP? How
17 Rich yesterday said he had it done at the
18 did it work, do you remember?
18 dispensary.
19 A. Just carried -- put the stuff inside of it.
19 A.That's where they drew it at, yes.
20 set it on fire, and it burned is all I know.
20 Q.Okay. And did they tell everybody in the
21 Q.Okay. Do you remember what kind of--you
21 plant you could get your blood tested for
22 put things in there?
22 PCBs, or was it something that you talked to
23 A. Yeah.
23 the people at the dispensary about or --
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1 Q.Did you?
1 A. Well, it came out we asked to have it tested,
2 A. (Witness nods head.)
2 especially the ones that had worked in it.
3 Q. What type of things did you put in there?
3 Q.In aroclor?
4 And I think you've already said it, but I
4 A. And when they set up a schedule to test the
5 just want to --
5 blood, they got people that had worked in it,
6 A. It was wood.
6 ones that had never worked in it, ones that
7 Q. Wood?
7 were there in the plant at the time but
8 A, Broke up shipping boxes that some mechanical
8 didn't work in aroclor or, you know, didn't
9 equipment had come in in.
9 work in a department. I guess you would call
10 Q. Paper?
10 it a cross section.
11 A. Paper and stuff like that.
ll Q.Okay.
12 Q.Did you ever take anything from the parathion
12 A. People that worked in the lab or anything
13 plant there?
13 like that and tested ever how many people it
14 A.No.
14 was.
15 Q.Did you ever take anything from the aroclor
15 Q.Mr. Rich said you had a meeting at the plant
16 plant there?
16 where you talked about some of these things.
17 A.No.
17 and he actually said that somebody from the
18 MR. KELLY: Speak up.
18 home office came down for that meeting. Do
19 THE WITNESS: No.
19 you remember that meeting?
20 Q.(By Mr. Wright) I'm sorry. I need to get
20 A. Yeah, there was a couple of them.
21 you doing that.
21 Q. When were those meetings?
22 Have you ever had your blood tested
22 A. It was after we -- about the time we got the
23 for PCBS?
23 results on the test.
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1 Q.Two or three years ago?
l three years?
2 A. Yeah, about the time the whole deal started.
2 A. For PCB?
3 Q. Do you remember who held those meetings?
3 Q. For PCB.
4 A.No.
4 A.No.
5 Q. Do you remember anybody who spoke at those
5 Q.Did this doctor and/or the other people at
6 meetings?
6 these meetings about two or three years ago
7 A. I don't remember their names.
7 about talk about any of the health effects of
8 Q.Do you remember as Mr. Rich did that there
8 PCBs that you remember?
9 was somebody from the home office in St.
9 A. Yeah. They highlighted them, but --
]0 Louis that came down?
10 Q. What did they talk about, do you remember?
] 1 A. I wouldn't say -- it was a doctor of some --
11 A.Chloracne.
12 I wouldn't say he was from the home office.
12 Q.Chloracne?
13 Q.Okay.
13 A. Yeah. I don't remember the others.
14 A. And I guess that would be another word for
14 Q. You don't remember anything else?
15 St. Louis. I don't know.
15 A.No, huh-uh (indicating no).
16 Q. Okay. How do you know he was a doctor? I
16 Q.Do you remember them talking about cancer?
17 assume it was a he.
17 A. Only thing they said was it's suspected.
18 A. I don't know whether he was a medical doctor
18 Q. Okay. Do you remember them talking about
19 or Ph.D,
19 respiratory problems or anything like that?
20 Q. But you remember someone referring to him as
20 A.No.
21 doctor?
21 Q. You mentioned two or three years ago, and you
22 A. His title was doctor, you know.
22 said when all this started happening, I think
23 Q. Do you remember anything he talked about?
23 you said?
Page 90
Page 92
1 A. They just went through the explanation of
1 A. When we heard about the test was after they
2 studies that had been made, tests had been
2 tested the people that lived in west Anniston
3 made, and told us we would be called to the
3 across the street from the plant.
4 dispensary to get the results of our test.
4 Q. Okay. When did you start -- or was this
5 Q. What type of studies did he talk about, do
5 about the time you started hearing about PCBs
6 you remember?
6 outside the plant, or did you ever hear about
7 A.That they'd been run at a couple of different
7 PCBs outside -
8 places that was users of axoclor. I don't
8 A, Oh, I heard about PCBs from, you know, well
9 remember where it was General Electric,
9 back.
10 Hooker, or who it was.
10 Q.Mr. Robertson said he read about it in the
11 Q.Do you remember any -- did he talk about any
11 "Anniston Star." Did you ever hear about it
12 results of those studies?
12 anywhere else?
13 A. Well, he was talking about, you know, some it
13 A. I heard about PCBs from -- I can't tell you
14 was; some it didn't, and levels was up and
14 how many years back. I read articles about
15 down. I don't remember what all he said.
15 it.
16 Q. You said he talked about tests. Did he, say,
16 Q. You don't remember when?
17 talk about tests at your plant?
17 A.No, huh-uh (indicating no).
18 A.No.
18 Q. Was it in this decade? Was it in the '90s?
19 Q. Did you ever have your blood tested before
19 A. Before that.
20 two or three years ago for aroclor?
20 Q. Before that?
21 A.No.
21 A. In the '70s, you know.
22 Q, Did you ever have the opportunity at Monsanto
22 Q. Was it in this area or just --
23 or Solutia to have it tested before two or
23 A,Not in this area.
Page 89 - Page 92
HARTOLDMON0044436
Foshec & Turner
Condenselt! TM
Joe Webb
Page 93
Page 95
1 Q.Not in this area. Do you remember when you
1 other and all, and then we went to the
2 first heard about PCBs in this area?
2 dispensary or got a letter as to effect of
3 MR. KELLY: Object to the form.
3 how much -- how many parts we had or if we
4 THE WITNESS: No.
4 had any.
5 Q.(By Mr. Wright) Okay.
5 That was the meeting I was talking
6 MR. KELLY: And my only objection
6 about, that one right there.
7 there, when you say, "in this area," if you
7 Q. Did they ever tell you what they thought was
8 could define --
8 an elevated level of PCBs in your blood?
9 MR. WRIGHT: That is vague.
9 A. Twenty parts.
1C Q.Let me re-ask that question, and we'll try to
10 Q.They said twenty parts?
11 make it a little clearer. Do you remember
11 A. Yeah.
12 when you first heard about pcb contamination
12 q.Do you remember getting information about
13 in the area around the plant?
13 this meeting through e-mail?
14 A. No.
14 A.I don't remember how it was communicated.
15 MR. WRIGHT: Okay. Can we take
15 Q. Okay. Do you receive e-mail in the plant?
16 just a couple seconds?
16 A. Yes.
17 MR. KELLY: Okay.
17 Q.Do you remember when you first started
18 (Short recess. )
18 receiving e-mail at the plant?
19 Q. (By Mr. Wright) Okay. Mr. Webb, I just have
19 A. (Witness shakes head.)
20 a couple other questions.
20 Q. Would it have been -- let me just look over
21 Actually, Mr. Rich and Mr.
21 your history. This won't take long.
22 Robertson both said that they were -- they
22 A. I don't keep up with when they installed
23 might have been informed about these
23 e-mail.
Page 94
Page 96
{ meetings. 1 don't want to mischaracterize
1 Q. Was it after you were a biphenyl operator.
2 what they say.
2 which I think ended about 1990?
3 So if I would tell you Mr. Rich and
3 A. Yeah.
4 Mr. Robertson had said they might have been
4 Q.It would have been after that. Do you
5 informed about these general meetings
5 remember if it was -- so it was after 1990.
6 concerning PCB and blood work, if they would
6 Do you remember if it was --
7 have been informed about them through e-mail,
7 A. I was in the warehouse when we had the
8 would you agree with that? Would this be
8 meetings. I mean. I've been there that long.
9 something you might have been informed about
9 I mean, that's what I told you a while ago.
10 through e-mail?
10 Q. Sure. I understand. I understand.
11 A. I don't understand really what you're saying.
11 A. You know, the only thing I can say is after
12 Q.Okay. That's an awful question.
12 they tested the people outside the plant, we
13 We've talked about some meetings
13 had ours tested, and that's when we got it.
14 that I think you said you attended, where
14 Q.The question I'm asking you now is a little
15 they talked about health issues of PCBs or
15 bit different. I'm just trying to figure out
16 maybe just about your blood donation in
16 when you started getting e-mail in the
17 PCBS.
17 plant.
18 And I may be mischaracterizing you,
18 A. You'll have to ask them. Don't ask me.
19 and'I don't want to do that.
19 Q. Okay. So you get e-mail in the warehouse; is
20 A. We had our blood tested -
20 that right, now?
21 Q. About two or three years ago.
21 A. Yes.
22 a. -- results came back in; they had a meeting
22 Q. How do you get it in the warehouse?
23 to explain the tests and this, that, and the
23 A. On the computer.
Page 93 - Page 96
HARTOLDMON0044437
Foshee & Turner
Condenselt!TM
Joe Webb
Page 97
Page 99
l Q. Is there one -- do you have your own
l you were talking about Clegom Lake?
2 computer?
2 A. Yeah.
3 A.No.
3 Q.And there was a question about taking drums
4 Q. Is there one computer for the whole
4 of bottoms to Clegom Lake. And I think you
5 warehouse?
5 talked about it being in a buggy?
6 A. Right.
6 A. Right.
7 Q.And does the e-mail come addressed
7 Q. What was the product or material in those
8 specifically to Joe Webb, or is it
8 drums that you were taking to Clegom Lake or
9 specifically addressed to everybody in the
9 these bottoms?
10 warehouse?
10 A. We didn't carry drums now. We emptied it out
l l A. According to what type of e-mail it is. If
ll of the buggy.
12 it's general, for the whole plant, it goes to
12 Q.And what was that product or material?
13 the whole plant.
13 A. Solid aroclor bottoms.
14 Q.Okay. ~
14 Q. Was it 5460?
15 A. If it's mine in particular or to an
15 A. Yes.
16 abbreviated list, it goes to them.
16 Q.Okay.
17 Q.Okay. How often do you check your e-mail?
17
18 A. Usually every day.
18 FURTHER EXAMINATION BY MR. WRIGHT:
19 Q.Once a day. Do you know -- do you keep your
19 Q.Let me just ask a couple other questions on
20 e-mail? Like, do you have e-mail from two
20 that. So it wasn't montars that were going
21 weeks ago?
21 into Clegom Lake?
22 A. No, I trash it.
'
22 A. We classified all bottoms as montar.
23 Q. You trash it. Do they tell you to trash it?
23 Q.Okay.
Page 98
Page 100
1 In other words, is there a Solutia policy for
1 A. As montar one, two, three, four, five.
2 getting rid of e-mail?
,
2 Q. So it could have been 5460 montar?
3 A. No, not as I know of.
3 A. Which we would call montar five.
4 Q. Could you keep it longer?
4 Q.Okay. I think that's all.
5 A. I could print it out or leave it in there.
5 Wait a second. Let me ask you --
6 Q. How long could you leave it in there, do you
6 back on the record - let me ask you just one
7 know?
7 other question about the blood testing of the
8 A.Until I wanted to take it out I guess or
8 PCBs.
9 until the system overloaded.
9 You said that we -- I think you
10 Q.No set time?
10 said we asked for it; is that right?
11 A.No.
11 A. We had our union committee go to them and
12 Q.Okay. I think that's all.
12 tell them if they were testing blood outside.
13 MR. WRIGHT: Do you have any.
13 we wanted our's tested.
14 Laura?
14 Q. It was the union committee. Was there -- do
15 MS. RUTH: No.
15 you remember the shop foreman then?
16 Q. (By Mr. Wright) Those are the only questions
16 A. Well, the President was Bryan Thrasher.
17 we have today, and I appreciate it. You've
17 Q. Bryan Thrasher. B-r-y-a-n?
l_8 been very helpful.
18 A. Yeah.
19 ' MR. KELLY: I have one if I can.
19 Q.Is he still there at Monsanto?
20 MR. WRIGHT: Okay.
20 A. Right.
21 21 Q.And was he the one who actually went to
22 EXAMINATION BY MR. KELLY:
22 management and asked?
23 Q. Shortly before Drew finished his questions,
23 A.I really don't know whether he's the one that
Page 97 - Page 100
HARTOLDMON0044438
Foshcc & Turner
Condensclt! TM
Joe Webb
Page 101
Page 103
1 asked or one of the others did.
1 CERTIFICATE
2 Q. Who were the other -- were the other -- do
2
3 you think it was other representatives of
3 STATE OF ALABAMA )
4 y1 all? He was the President of the union at
4 CALHOUN COUNTY )
5 the time?
5
6 A. Yes.
6 I HEREBY CERTIFY that the above and
7 Q. Is he still President of the union?
7 foregoing transcript was taken down by me in
8 A. Yes.
8 stenotype, and the questions and answers thereto
9 Q.Okay. What's the union?
9 were transcribed by means of computer-aided
10 A.lCUWLoeal 125.
10 transcription, and that the foregoing represents
11 Q.ICEW?
11 a true and correct transcript of the testimony
12 A.ICUW.
12 given by said witness.
13 Q. Local 125?
13 I FURTHER CERTIFY that I am neither
14 A. Local 125.'
14 of counsel, nor of any relation to the parties to
15 Q. Who were the other officers that might have
15 the action, nor am I anywise interested in the
16 gone and asked?
16 result of said cause.
17 A. I don't know. Like I say, I know he was the
17
18 President at the time, and that's the way we
18
19 handled things like that was through them.
19
20 Q. Okay. And you had a union meeting? 21 A. No. Just the ones of us that was --
20
TAMMY R. JENNINGS GREGORY 21 Notary Public, State of Alabama
22 Q.Okay. That's it. Thank you very much.
22 MY COMMISSION EXPIRES: 9-12-2001
23_____________ --oOo--__________________________________ 23
1 (Deposition concluded at 11:50 a.m.) 2 FURTHER THE DEPONENT SAITH NOT. 3 4 5 6 7 8 9
10 11 12 13 14 15 16 17
Page 102
18 19 '
20 V
21
22
23
Page 101 - Page 103
HARTOLDMON0044439
Foshee & Turner
'65 [6] 11:18
12:18 16:18 53:7
'69 [4] 64:23
82:5 82:12
'70 m 64:23 '70s [2] 53:8
'72 p] 12:7
12:19 13:2 53:8 53:16 58:6
'74 [i] 53:10
'75 [i] 53:10 '80 [5] 13:20
14:21 53:7
'81m 14:20 '86 m 14:20
14:21 14:21 15:11
'90 [3] 15:10
15:21
'90s [i] 92:18
11:20 49:16
81:23
92:21 12:9 13:11 58:2
14:20 58:6
f4:20 15:7
15:11
-0085433 [i] 73:16
-1-
1010 [i] 3:8 103 [i] 4:8 10:00 [2]
7:3
111m 3:8 1121 [i] 41:4 1140 [2] 41:16
1142 [ii] 26:20 27:1 40:21 41:4 41:19 43:7 71:19
1160 [2] 43:22 11:50 [i] 1242 [8] 25:13
26:18 26:22 27:8 27:10
125 m 101:10
101:14
2:3
72:17 26:18 27:8 41:18 43:15
44:2 102:1 26:16 26:23 27:11 101:13
1268 m 35:11 37:7 37:11 64:10
1400 [i] 3:16 15[i] 1:17 17 [i] 4:16 1965 m 9:8
11:6 11:12 -12:6 45:20
1968 [i] 75:5 1969 [5] 16:21
63:23 73:22
1970 [i] 63:23 1972 [l] 66:11
35:12 38:1
9:16 12:5
51:23 79:11
1980 [6] 11:6 11:11 11:12
14:12
1988 [l] 1:17
1990 m 11:10
96:5
1999 [4] 1:20
5:8 7:2
1 St [2] 9:8
11:10
13:20
96:2 2:4 9:16
-2-
202 [S] 18:5 18:21 19:3
26 [i] 73:15 27 m 4:16
17:17 17:19 56:23 65:2
27401 [1]
18:17 52:2
17:16 17:23
3:17
-3-
3 [i] 7:2 3-10-69 [3]
18:12 65:2
300 m 3:15 3rd [3] 1:20
5:8
17:10 2:4
-5-
5 [2] 1:15 5460 [i7]
35:6 35:7 35:14 35:21 36:13 37:11 71:3 71:4 72:16 72:20
100:2
4:4
35:5 35:9 35:22 38:2 71:18 99:14
66 [i]
6- -
67:20
-7-
7 [1] 4:5 78701 [1]
3:9
-9-
9-12-2001 [i] 98 [1] 4:6 99 [1] 4:7
103:22
-A-
a.m [2] 2:4
102:1
abbreviated [i] 97:16
above p]
103:6
80:16
accordance m 1:15
according [3] 33:21 60:3 97:11
accurate m 46:9
acid [2] 59:9 60:15
action [2] 103:15
1:8 '
Condcnselt! TM
add [2] 47:4
additional [2] 64:8
addressed p] 97:9
advise m
advised m
aerial [i]
again p] 63:13
against m
ago [8] 87:8 90:20 91:6 94:21 96:9
agree [i] 94:8
AGREED [4] 5:11 5:20
ahead m
aid[i] 76:12
air[i] 83:3
al[i] 1.5
Alabama [7] 1:16 2:6 7:1 103:3
alike [i] 36:9
almost [2] 26:12
along [i]
always [4] 27:1 27:3
Amended m
Anniston p] 5:7 7:1 73:17 92:2
annual m
answer p] 8:18 34:9 34:18 34:19
answered [i]
answering [i]
answers [i]
anywise [i]
apart [2] 67:3
Appearing [z] 3:11
appreciate [l]
April p] 9:16
area [28] 17:7 18:20 20:22 23:11 23:17 52:1 52:4 52:9 55:14 56:4 61:4 65:22 66:20 78:4 81:20 92:23 93:1 93:7 93:13
areas p] 23:13
aroclor ps]
10:10 10:11 11:17 11:19 12:2 12:4 12:16 12:17
47:6 24:20
97:7
34:15 1:22 16:21 14:23
76:12 89:1 91:21 97:21
5:3 6:7 34:18
1:2 5:7 103:21
26:12
1:20 9:13 72:17 1:16 2:6 9:13 92:11 75:2 8:10 34:14 51:5 43:2 34:15 103:8 103:15 67:4 3:3
98:17 9:8
18:16 22:10 48:2 52:7 55:15 65:3 77:6 92:22 93:2
23:13 9:18 11:16 11:21 12:10 13:1
16:15 20:20 22:1
25:13 26:20 27:20 28:18 30:11 35:3 35:12 39:14
40:3 42:7 42:19 57:23 58:20 63:23 65:4 68:4 81:12 88:3 90:20
19:5 20:23 22:5 25:14
27:10 28:7 29:6 30:13 35:4
35:13 39:15 40:8 42:10 44:17 58:3 58:22
64:8 65:20 69:2
83:8 88:8 99:13
aroclors [2] 76:3
arrow [4] 56:13 80:7
articles m
assign m
assigned pj 15:1
Assisted [i]
associated m
assume [io] 38:10 39:7 53:1 55:5 59:14 67:2
attached [2] 31:12
attended m
auger [i]
Austin [i]
Avenue m
away [i] 39:9
awful [1]
19:22 21:14 22:8 26:16 27:13 28:14 29:10 30:15 35:9 39:13 39:17 41:11 42:12 49:23 58:14 59:13 64:8 66:10 71:18 86:15 90:8
71:3
52:19 80:9 92:14 6:1 13:4
59:11 83:1 33:15 49:11 58:17 89:17 17:21
94:14 31:6 3:9 3:8
94:12
-B-
B [i] 4:14 B-r-y-a -n[i]
bad [i] 76:7
bag [is] 29:3 31:8 31:11 31:14 31:15 31:20 31:23 32:18 33:22 38:7
bagger [i] bagging m
bags [5] 23:12 33:7 33:9
barrel [3] 50:17 69:12
barrels [8] 51:10 53:21 69:14 70:1 70:19
basin [2]
100:17
29:5 31:12 31:17 32:16 38:5
29:13 23:11 32:8 34:2 50:14
50:8 53:22 70:3
78:21
V 65 - bottom Joe Webb
82:19
basins [i4] 78:9 78:12 78:19 79:4 80:10 80:13 80:15 82:3 83:3
77:10 78:18 79:19 80:14
82:23
basis m 84:16
batch [5] 43:12 44:2 60:11
batches m 59:21 60:4 69:21 69:22
bathroom m
28:7 48:1
59:20 63:4 69:23 63:19
beams m
became [i] become PI
13:2
25:11 72:11 12:15
becomes [2] 26:22
beginning m
best [3j 20:11 56:11
better [3] 40:5 48:20
between pj
21:5 28:18 50:5 53:6
big [8j 28:6 36:17 69:17 79:8 79:9
bigger [4] 33:7 54:16
biggest [2] 27:9
biphenyl [zs] 10:8 10:10 11:16 11:17 13:8 13:10 13:13 13:19 15:4 15:5 28:16 28:19 29:2 30:11 35:19 58:4
bit [7] 39:20 82:2
30:17 42:22 96:15
black [i]
blade m
blades m
blast [i] 73:21
26:21
41:3 21:9
21:4
5:4 46:15 58:6 33:1 79:4 83:23 29:6 62:6 18:18
9:18 10:11 11:21 13:10 15:3 15:19 28:21 30:13 96:1 35:1 52:13
21:6 30:8 46:2
blood [ii] 87:3 87:21 90:19 94:6 94:20 95:8 100:12
86:22 88:5 94:16 100:7
blowing p] 44:11
44:10
blue [i] 21:3
boiler p] 44:17 44:20
bolt [i] 61:11
bottom [5] 28:11 30:19 31:2
44:16
23:22 30:23
Index Page 1
HARTOLDMON0044440
Foshee & Turner
bottoms [io] 68:4 68:6 83:8 83:9 99:9 99:13
box [l] 62:2
boxes [2] 86:8
BP1 [l] 67:20
brand [2] 45:13
break [3] 63:18 73:6
briefly m
bring [i]
brittle [i]
Broke [i]
broken [i]
brother pj
brought [i]
Bryan p] 100:17
bucket [i]
buggy [4] 83:14 99:5
bugs [6] 78:20 78:22 78:23 79:7
building [29] 22:7 22:13 22:15 22:22 24:13 24:18 24:21 24:22 25:2 25:8 26:5 26:7 42:7 42:10 44:17 49:23 66:21 67:8 81:12
buildings [2] 22:4
built [3] 64:6 79:23
bullet [ij
bumped [i]
burn [2] 75:20
burned [2] 85:20
bums [4] 76:13 76:14
57:12 69:19 99:4 99:22
63:13
45:11
29:11
64:2 30:7 36:3 86:8 84:12 8:8 51:10 100:16
48:4 83:13 99:11 78:22 79:2
22:5 22:14 23:15 24:20 25:1 25:19 26:13 42:19 58:14 69:8
18:19
66:5
75:18 76:12 76:7 75:23
76:12 76:14
-o
C[3] 3:1 103:1
103:1
CALHOUN [ij 103:4
cancer [i]
91:16
candy [i]
63:15
cantilevered [i] .26:6
capacity [i] 27:18
carp] 83:17
carep] 63:17
Carolina [i] 3:17
carried [4] 81:1 81:3
70:18 85:19
carry [3] 42:3 99:10
69:6
catch [5] 38:16 42:1 47:15
33:3 47:11
catwalk [i]
65:13
catwalks [2] 24:15
24:14
Certificate [i] 4:8
CERTIFY p] 103:6 103:13
change [i]
13:15
changed [i] 41:6
channel [i]
61:16
charge p]
41:10
check p]
42:4
42:14 97:17
checked pj 42:14
checking p] 48:2
chemical p] 76:14
chief p] 11:14 11:15 12:15
Chloracne [2] 91:11 91:12
chlorinated [i] 43:19
chlorination p] 43:13
chlorinator [i4j 40:11 41:22 42:18 43:3 44:3 44:4 45:2 46:12 59:11 59:17 60:23 62:22 71:13 71:14
chlorinators [6] 41:10 43:12 49:17 59:7 64:4 64:6
chute [5] ` 31:10 31:11 32:20
31:8 32:19
circle pj 57:4
20:23
circled pj
55:16
65:4 65:22
CITY [i]
7:1
Civil p] l :8
1:16
clarifiers p] 83:2
classifications p] 14:16 14:17
classified p] 99:22
clean pj 61:3 61:13 62:8 62:11
61:3 61:20 62:17
cleaned [2] 61:6
57:17
cleaning [2] 61:9
61:8
cleanup m
81:6
cleanups p] 81:9
clear p] 37:2 37:3
cleared pj
9:3
clearer pj
93:11
Clegom pi]
57:7 57:10 57:16 70:13
1
56:20 57:14
83:10
Condenselt!
99:1 99:4 99:8 99:21
close [1] 29:6
closed p] 72:7
58:2
coat [3] 36:17 36:18 36:18
coils [L] 44:16
COld[l] 75:12
Color p] 36:21
combination p] 14:3
combined [3] 14:6 14:7 14:10
coming [3] 20:13 20:18 30:5
commencing p] 2:3
comment p] 55:6
COMMISSION [i] 103:22
committee [2] 100:11 100:14
communicated p] 95:14
company [2] 1:10 56:7
compared p] 33:2
complete p] 19:11
completed p] 66:6
compliance [i] 5:15
computer [3] 96:23 97:2 97:4
computer-aided p] 103:9
concerning p] 94:6
concluded p] 102:1
concrete [i] 80:15
condensed p] 71:17
confusing p] 39:20
Congress p] 3:8
connect p] 46:11
consider [i] 24:6
considered [4] 19:8 22:8 23:6 35:13
consisted [i] 22:10
contact [i] 29:23
contain [2] 25:12
22:1
container [2] 62:2 62:2
contamination p] 93:12
control [6]
22:11
22:12 23:2 23:3
23:17 64:18
conveyorp] 69:6
coolp] 42:3
cooling [i] 30:5
COpyp] 17:21
correct p3] 11:23 17:11 17:23 18:13 19:5 19:15 21:17
| 25:17 1 38:2 | 51:18
66:11 80:11 103:11
26:1 38:8 52:17 68:23 84:10
34:12 43:4
66:6 77:2 87:12
counsel [4] 5:22 5:23
5:5 103:14
COUNTY [i] 103:4
couple [ip 11:14 64:3 76:19 82:15 90:7 93:16 99:19
11:2 74:8 88:20 93:20
court [7] 1:1 2:1 3:19 7:9 17:16
1:23 5:16
covered pj
55:5
crafts [ij
14:10
crane p] 54:18
54:16
cross [i] 88:10
Crude p]
26:20
crushers p] 29:11
curve [i]
18:21
curved p]
46:2
curves pi
19:3
Cut [2] 14:23 53:13
CV-P-440-E P) 1:9
-D-
d[2] 1:15 4:1
D-u-r-c-o [i] 45:13
dact [2] 57:11 57:12
date [3] 17:10 64:22 65:2
days [4] 10:18 10:19 50:16 85:9
dealp] 89:2
decade p]
92:18
decontaminate [2] 80:23 81:3
decontaminated [ioj 54:1 54:3 77:2 77:4 77:8 77:20 82:7 82:17 83:20 84:7
Decontaminating [i] 77:14
decontamination [5] 78:2 78:12 80:13 80:17 80:22
Defendant [2] 1:11 3:11
define [i]
93:8
delivering pj 1:18
department [23] 9:18
10:9 12:11 12:16 13:4 13:9 13:13 14:19 14:22 15:19 16:15 19:6 22:8 22:20 42:18 44:21 59:4 60:16 66:19 74:19 75:7 82:13
bottoms - doctor Joe Webb
88:9
departments p] 12:1
DEPONENT m 102:2
deposition [] 2:2 5:5 5:14 6:3 7:21 102:1
1:13 5:13 6:8
depositions [2] 5:17 79:6
describe [4] 45:7 64:2
described [3] 66:22 84:8
30:20 72:6
46:6
description p] 13:21 15:13
determine [4] 40:3 40:16 40:18 41:16
determined [2] 40:20 40:23
diagonally p] 18:23
diameter p] 29:9
28:23
difference p] 28:17
different [26]
27:5 28:20 35:14 35:16 45:19 53:19 55:9 59:2 67:22 69:4 80:18 80:20 83:22 84:1 84:2 84:5 96:15
11:3 28:21 45:18 55:8 59:3
76:8 80:21 84:1 90:7
diphenyl [ij 67:20
directing p] 56:14
Discussion p] 74:6
dismantled [4] 66:17 66:18 67:2 67:12
dispensaiy [4] 87:18 87:23 90:4 95:2
dispose [i]
51:11
disposed [3] 49:7 53:15 53:18
distillation pj 57:13 68:5
distillations p] 68:9
distilled [4] 26:21 42:13 71:16 71:23
distilling [2] 39:18 68:8
distinguish p] 79:17
DISTRICT pj 1:1 1:2
divided p]
19:14
dividing [ij 19:20
division [2] 66:10
1:3
dock [6] 26:4 49:6 51:11 70:12
26:8 69:8
doctor [6]
89:11
89:16 89:18 89:21
Index Page 2
HARTOLDMON0044441
Foshcc & Turner
89:22 91:5
donation [i] 94:16
done [9] 31:9 55:7 60:16 67:10 68:13 87:17
35:11 64:18 70:11
down [25] 9:4 14:22 23:22 29:10 29:22 30:21 31:10 38:16 42:3 60:18 62:20 66:11 71:17 75:16 89:10 90:15
8:1 23:18 29:12 31:3 39:2 62:18 67:9 88:18 103:7
downstairs [i] 23:20
Downstream [i]
44:7
DPO [l] 67:20
drain [2] 69:9 69:19
drawn] 52:12
drawing [io] 52:5 52:11 52:23 56:11 57:6 57:9
21:13 52:15 56:15 66:3
drawn [i]
drew pj 1:18 17:3 87:19
52:16
3:6 98:23
drip [6] 47:13 47:17 47:21 50:3
47:14 49:8
drive [3J 30:3 54:10
54:8
dropped [3] 32:11 32:12 83:22
drum [i4] 28:23 29:4 29:21 30:1 38:15 48:6 49:2 49:5 69:5
28:23 29:4 38:12 48:7 68:15
drummed [4] 60:18 60:19 68:14 83:12
drumming [6] 23:11 23:13 60:21 68:18 68:21 69:1
drums [17] 38:19 38:20 48:11 60:19 68:17 69:6 70:15 70:16 83:6 99:3 99:10
23:12 48:8 63:14
70:8 83:5 99:8
dry pj 61:22
Drys [i] 62:14
DSW085378 [i]
73:16
DSW085433 [2]
74:17 75:18
DSW085434 [1]
74:13- .. _
dulyp] 7:6
dump 5] 54:12 54:13
61:23
38:14 55:10
dumped [4] 55:11
55:13 70:13
Duncan p]
20:4
DurcO[3]
45:10 45:16
during p]
41:6
84:20 20:3
45:9
23:20
-E-
E[7]
3:14 103:1
3:1 4:1 103:1
3:1 4:14
e-mail p4] 94:10 95:13 95:18 95:23 96:19 97:7 97:17 97:20 98:2
94:7 95:15 96:16 97:11 97:20
earthen h i easier p]
17:9
57:11 17:3
east p] 18:10 25:18 25:20
eastern pj 19:11
1:3
easyp] 8:13
eatp] 78:21 79:2
effect [2] 95:2
5:14
effective [ij 1:17
effects [ij
91:7
eight [4] 49:15 49:17 49:17 50:3
eight-hour [ij 58:18
either p] 66:5
55:19
Electric [i] 90:9
elevated [i] 95:8
elevators pj 24:1
eliminate p] 75:20 75:22
emphasis [3] 74:19 75:7 75:9
emptied m 99:10
empty [s]
27:20 47:16 48:3 48:6 48:23
27:19 47:21 48:12
end [6] 56:1 56:12 59:18 63:1
56:9 60:23
ended pj
96:2
enter pj 60:7
enters nj
46:20
equipment pj 67:5 81:2 82:17 83:2 86:9
especially pj 76:2 88:2
Esquire p]
3:7 3:14
3:6
Essentially [i] 71:10
estimate [i] 50:2
et[i] 1:5
Condenselt! TM
eventpj
74:21
everybody [4] 19:16 87:10 87:20 97:9
evidence p] 6:3
exactly [4] 54:23 56:5
18:4 82:21
Examination [6] 4:5 4:6 4:7
7:14 98:22 99:18
examined p] 7:6
example [2] 81:23
81:13
except [i]
5:22
exclusively pj 82:4
exhibit p] 17:14 17:19 65:2 73:14 80:6
16:20 56:23 73:15
exhibits pi 1:21
existence p] 67:15 67:16 79:11
expanded [2] 64:18 65:4
expansion p] 49:14 63:22 65:6 66:8 75:8
49:12 64:20 74:20
EXPIRES [i] 103:22
explain pj 7:23 34:7 94:23
7:20 36:7
explanation p] 90:1
eyeballing p] 65:3
-F-
F[i] 103:1
facilities p] 66:14
facing [i]
18:12
fall [i3] 11:18 12:4 12:18 32:16 32:19 33:5 34:3 38:6 38:13
11:20 16:17 32:23 34:21
falling [i]
32:18
familiar [i] 36:22
familiarize p] 74:3
far [4] 11:8 43:12 44:4
16:9
farm [8] 64:6 65:16 66:2 66:19 67:11
65:10 66:5 67:14
feed pj 25:14 28:1
fell p] 31:10 38:11 61:10
fewpo] 16:12 34:3 34:21 56:2 68:8 79:5 85:8
32:23 38:6 73:23
fifteen p]
50:5
50:6 50:13
Fifth [io]
20:3 20:4 20:15 20:16 65:17 65:18
19:20 20:13 21:20 65:19
fifty p] 32:9 32:11
fifty-pound [i] 33:9
figure [3]
33:8
39:16 96:15
filed [i] 1:23
filing [i]
6:8
fill pj 50:10 50:17
33:8 50:12 51:3
50:9 50:14 68:22
filled [3]
50:22
51:10 57:17
filler [i] 69:7
final [4] 12:10 66:12 66:13 68:9
fine [8] 8:20 39:23 40:1 58:12 58:13
9:5 55:23 65:8
finer [2] 38:1 38:2
fingers PI finish [i]
29:11 59:22
finished p]
27:11 37:15 59:20 60:11 64:21 98:23
16:8 42:12 63:4
finishing p] 48:1
fire [i] 85:20
first [i9] 7:6
7:18 11:5 14:8 16:23 23:8 23:19 32:10 45:8 74:9 76:12 93:12 95:17
7:17 12:6 22:4 25:4
73:13 93:2
Fite p] 2:5 5:7
fitter [2] 14:3 14:18
fitters [i]
14:6
five [7] 29:7 71:1 87:6 100:1 100:3
70:8 87:7
fixed [i 61:15
flaked pj 35:9 37:8 37:11
31:17 37:9
flaker [12]
28:16 28:18 29:6 29:15 30:13 30:15 64:10 72:10
28:14
28:19 30:13 30:17
flakers [1]
flakes [8] 33:3 34:3 35:2 37:12 38:10
28:13
32:23 34:21 38:6
flaking W
23:11
23:12 28:11 37:11
flakings p] 32:15
flight pj
26:14
floor p6] 22:12 22:23 23:22 24:2 24:7 25:1 26:10 28:11 48:9 61:3
22:12 23:19 24:4 26:4 47:9 62:21
flour p 29:20
flow [1] 43:21
donation - guess Joe Webb
focus [1]
76:9
fogp] 36:23
folded p] 32:4 32:6
32:1
folding [i]
32:16
follows [1]
7:7
foot [2] 28:22 29:7
force [l] 5:14
foregoing pj 103:10
foreman pj
103:7 100:15
form p] 5:23 34:8 93:3
34:5
formula [i] 27:14
formulas p]
forth p] 2:7
four p] 59:23 100:1
27:13 85:7 69:17
fourteen p] 60:1
freeze p] 43:20
43:18
freezing p] 43:15
full p] 5:15 38:21 49:5
38:18 55:4
-G-
gasket p] 46:17 61:11
general pj 94:5 97:12
generally p] girders pj given [i] glass [i] 36:14 gluep] 37:20 goes [2] 97:12 gone pj 101:16 gonna p] good p] 27:11 goods [i] grade p]
40:3 grades p] grating [i] gravity [2]
42:4 grayish p] great p] 36:17
46:14
90:9
43:6 24:9 103:12
97:16
41:4 27:14 16:8 40:2
67:22 24:11 41:20
37:9
green p]
21:7
Greene p]
3:15
Greensboro pj 3:17
Gregory p] 2:3 3:20 103:21
1:18 5:6
ground pj 37:13 38:11 80:16
34:3 48:10
grounds p] 6:2
group [i]
18:18
guess [30]
9:11
10:15 15:20 18:23
Index Page 3
HARTOLDMON0044442
Foshee & Turner
Condenselt! TM
24:6 30:19
46:11 53:6 56:8 66:1 72:6 79:2 89:14
26:6
35:16 48:8 54:5 57:4
66:10 72:15 87:16 98:8
27:12 39:18 50:19 55:8 63:8 71:3 73:3 88:9
-H-
H[i] 4:14
band pi 54:14 73:13
handled m
handrails [i] happening [i]
hard m 8:16 12:21 36:7 72:6 79:17
harder p] 36:4
hardly [i]
haul[l] 51:10
hazards [i]
HB40 [i]
he'dp] 41:5
head pi]
30:16 43:10 48:15 49:3 83:1 84:19 95:19
health [2] 94:15
hear p] 56:19 92:11
heard [is]
39:12 46:6 49:14 55:23 67:23 77:22 92:1 92:8 93:2 93:12
hearing [i]
heat [3] 43:13 44:11
heated [8] 43:5 43:11 72:15 72:16 76:4
heating [i]
heats [i] 76:9
height [i]
held [l] 89:3
HELMS [i]
help [4] 8:12 21:7 21:11
helpful [i]
hereby [2] -103:6
herein [i]
hereto [i]
hi-liter [2] 56:9
higher [2]
73:12
101:19 24:11 91:22 8:23 65:8
36:2
50:22
75:20 10:2 41:9 7:22 48:13 75:13 86:2
91:7
92:6
37:20 49:11 62:10 87:16 92:13
92:5 44:2
43:3 72:14 72:21
44:4
24:13
3:13 8:16
98:18 1:18
2:7 17:22 21:17
36:1
43:19
highest [i]
22:22
highlight [5] 52:22 57:5 80:2
21:10 66:1
highlighted pi 80:10 91:9
Highway [3] 18:17 52:1
18:5
history [i]
95:21
holding [4] 26:16 28:4
25:11 83:2
home [4] 88:18 89:9
41:6 89:12
hood [3] 68:18 68:21 69:1
Hooker [i]
90:10
hopper p] 29:14 30:21 33:2 33:6
29:13 33:1 38:5
hosep] 62:18
hot [3] 44:7 76:2
44:9
house [i]
61:2
housekeeping [2] 74:16 75:6
housing p] 47:15
46:4
huh-uh [6] 12:22 13:14 91:15 92:17
8:15 28:5
hundred [6] 32:12 33:10 87:6 87:7
32:10 33:11
hydrometer [i] 42:4
-I-
ICEW [i]
101:11
ICUWp) 101:12
101:10
idea [5] 37:18 37:23 50:18 67:6 67:19
identification [11 17:20
impeller [4] 45:9 45:22 45:23 46:6
imply [i]
61:8
improvements [i] 64:18
inch[i] 28:22
incinerator [2] 85:4 85:10
included p] 65:22
59:2
Indian [i]
85:17
indicating p2] 8:15 8:15 11:22 12:20 12:22 12:23 13:14 18:16 20:19 20:22 23:10 26:9 28:5 36:19 52:7 55:15 57:3 66:23 75:4 80:12 91:15 .92:17
information [i] 95:12
informed [4] 94:5 94:7
inside [8] 30:6 32:4 42:3 46:7 85:19
inspection pi 75:6
installed [4] 64:3 64:10
instructed [i]
insulation pj 75:7 75:10
interested [i]
interstate [i]
involved [i]
issues [i] itself p] 32:4
93:23 94:9 30:5 32:6 72:8
75:3
45:18 95:22 40:7 74:19
103:15 82:22 78:6 94:15 63:12
-J-
J-o-s-e--p-h [i] 7:19
JACKS [i]
3:5
Jennings pi 1:17
2:3 3:20 5:6
103:21
lets pi 22:20 22:21 24:12
job [i4] 10:7 15:13 47:16 58:23
9:19 10:8 16:13
47:18 59:4
9:23 13:21 16:14 48:22 84:17
jobs p] 9:22 59:2 59:3 59:5
16:6 59:5
Joe p] 1:13 4:3 5:5 74:11 97:8
2:2 7:5
Joseph [1]
7:19
July [i] 13:10
jump [1)42:21
June [4] 12:6 12:18 13:2
12:8
-K-
keep [6] 44:7 76:5 95:22 98:4
Kelly [23] 4:6 7:12 34:5 34:6 34:12 34:15 41:18 48:16 52:20 73:8 79:5 86:18 93:6 93:17 98:22
kept pi 38:12 47:5 72:14
kind pi] 29:19 36:20 45:6 46:7 57:8 63:9 85:21
kitty [l] 62:13
44:9 97:19
3:14 17:1 34:11 34:17 48:20 73:13 93:3 98:19
38:16
8:22 36:23 50:19 82:20
knew [i] knowledge [2]
56:11
known [i]
41:15 55:21
10:9
-L-
L[i] 5:1
lab [4] 42:9 42:14 88:12
labeled pi 75:19
laborers pj 51:16 51:17 60:21
Lake pi] 57:7 57:10 57:16 70:13 99:1 99:4 99:21
landfill po] 39:8 39:10 51:18 51:20 52:16 52:20 53:2 53:15 54:4 54:9 56:1 56:10 62:5 62:6 70:19 76:23 83:7 83:21 85:12 85:13
landfills [2] 76:22
Larry [i]
last p] 7:17 56:2
late [2] 64:23
Laura p] 29:17 98:14
law [2] 2:5
laws [l] 5:15
leading [i]
leak [6] 45:4 47:9 51:1 61:14
leaked m
leaking [i]
leakings [i]
leaks [3] 46:18 61:20
learning p] 10:5
leave p] 98:5
left [2] 68:7
less p] 36:3 50:20
letter pj95:2
level [9] 23:4 23:8 23:16 26:13 48:10 95:8
levels p] 60:9 90:14
lid [2] 38:12
likely p] 75:11 76:11
42:14
17:23
51:14 53:14
56:20 57:14 83:10 99:8
39:5 39:11 52:9 52:22 53:18 54:10 56:13 70:18 82:8 85:11
55:17
8:8 7:18
64:23 3:7
5:7
5:23 47:1 61:12
46:17 47:8 48:12 47:12
10:4
98:6 73:10 36:3
23:7 25:4 80:16
60:6
38:12 65:15
H - mark Joe Webb
line [i] 81:7
lined [i] 68:17
lines [i] 76:3
liquid [22] 29:23 39:15 68:12 68:13 70:4 70:4
70:20 72:13 72:17 72:22
71:20 72:14 72:17 72:23
list [i] 97:16
27:10 58:22 69:21 70:6 72:5 72:15 72:21 83:8
listed p] 75:6
9:23
litter [1] 62:13
lived [1] 92:2
LLP [i] 3:5
load [2] 54:5 54:6
loaded [i]
60:14
loading pj 26:4 26:8 60:16
Local pj 101:13 101:14
16:8 51:11
101:10
located [i]
22:21
locks [i]
61:16
log [2] 58:20 63:3
logbook [4] 59:19 60:4
41:5 60:7
longer pj 98:4
63:21
look [li] 18:2 36:11 36:14
72:16 72:20 73:19 74:1
36:9 37:7 72:20 95:20
looked [i]
looking [2] 65:1
85:17 8:3
looks [2] 75:2
74:12
lotS[i] 27:17
Louis p] 89:15
89:10
lower [2] 26:4
22:11
Im-T
maintenance [is] 13:17 13:18 13:22
13:23 14:1 14:9 14:19 22:11 51:14 53:14 54:19 61:18 61:19 78:7 82:16
Major [i]
75:19
majority [i] 23:16
management [i] 100:22
manufactured [11 45:19
map [8] 18:19 51:23 51:23 56:23 79:12
20:9 52:12
79:16
mark p] 17:13 20:9 20:15 20:16 51:22
Index Page 4
HARTOLDMON0044443
Foshee & Turner
Condenselt! TW
marked [2] 21:16
17:20
marker [l]
80:6
material p] 24:1 99:7 99:12
materials [3] 15:18 16:7 43:19
15:17 16:9
matter p]
10:4
may r2oi 1:17 6:1 17:8 34:6 39:5 58:9 63:14 69:17 69:18
71:1 73:19 75:12 79:16
5:5 33:20 51:8
68:11
71:1 73:21 94:18
mean [22]
21:11 23:21 27:22 28:6 37:20 39:20 51:1 54:23 59:4 61:6 76:10 76:13 79:3 96:8
10:23 27:7 36:23 44:18 58:9 67:22 78:22 96:9
means [2] 103:9
71:21
meant [2] 74:22
51:14
mechanic p] 13:23 14:2 14:9
mechanical [i] 86:8
medical [i]
89:18
meeting p]
88:18 88:19 95:5 95:13
88:15 94:22
101:20
meetings m 89:3 89:6 94:1 94:5 96:8
88:21
91:6 94:13
mentioned p] 28:10
61:20 83:4 83:5 91:21
mesh [i] 24:9
met[i] 42:15
metal [2] 62:2
24:11
Michael pj 3:14
middle [2] 15:9
7:17
might [gj 32:23 37:20 93:23 94:4 101:15
21:8
80:7 94:9
Miller [2] 5:7
2:5
millwright pj 14:3
14-1 Q
millwrights [i] 14:6
mine [i] 97:15
minute [i]
74:1
minutes [2] i 73:10
73:7
mischaractcrize [2] | 45:17 94:1
mischaracterizing [i] 94:18
mistake p]
26:18
MITHOFFeu 3:5
mixture [2] 39:17
35:17
mixtures [2] 28:7
27:20
Monsanto [8] 9:7 9:9 18:15 52:21 100:19
1:10 18:4 90:22
montar p]
68:3 69:9 83:4 99:22 100:2 100:3
68:1 69:20 100:1
montars [3] 68:12 68:13 99:20
month [2] 51:8
51:4
MOORE [i] 3:13
morning p] 78:1
37:1
most p) 23:6 27:7 40:21 46:18 47:13
23:14 45:8
mostly PI 67:21
60:11
mounted p] 24:12 25:8 31:8
mouth HI
move [5] 53:23 62:3 62:5
36:6
39:3 62:4
moved [ii] 38:22 39:4
49:6 53:22
70:12 77:5
77:22
13:16 46:1 70:12 77:21
moving [1] ' 49:21
MRO [2] 61:17
61:15
Ms [4] 7:14 17:2 48:19 98:15
MULLISS [i] 3:13
multistory [i] 22:15
-N-
N [3] 5:1
3:1
name [io] 9:23 45:11 62:12 62:16 74:2 74:9
names [i]
nearpj 85:10
necessary [i]
need [5] 18:3 48:19 63:19
4:1
7:15 45:13 73:20 74:11 89:7
5:21 28:3 86:20
neighborhood [3] 14:13 14:14 33:12
neither m
103:13
never pj 64:11 64:12 64:13 64:15
53:22 64:13 88:6
new [i] 64:3
next [4] 13:15 17:15 41:9 44:21
ninety [2] 10:19
10:18
niran p] 13:4 78:4
44:21
nods [8] 30:16 48:15 49:3 83:1 84:19
48:13 75:13 86:2
nor p] 1:23 103:15
103:14
normally [3] 38:12 41:5 54:23
north [7] 3:17 18:7 19:17 65:17
3:15 19:15 65:19
NORTHERN [i] 1:2
Notary [i] notice [i j
103:21 6:8
November [4] 1:20 2:4 5:8 7:2
now p2] 11:8 15:8 18:11 38:4 39:12 58:13 58:22
66:10 67:17 69:1 70:5 82:5 83:19 96:20 99:10
11:17 19:5 39:14 62:22
67:18 81:9 96:14
nozzle [4]
31:13
31:16 31:18 33:23
number [7] 17:19 69:1 74:16 75:6
17:15 73:15 75:19
numbers [3] 41:13 43:17 73:16
nut[i] 61:10
-O-
O [1] 5:1
Object [2] 93:3
objecting [1]
objection [i]
objections rzi 6:1
Obviously [i]
occasions [i]
off[26] 29:4 31:21 32:19 33:5 38:5 54:14 68:4 74:4
25:16 30:9 31:23 32:20 33:23 38:6 60:14 69:5 74:6
offered [ij
office [3] 89:9 89:12
officers p]
offices [2] 5:7
often [4] 8:22
34:5
34:8 93:6 5:21
72:2 11:3 29:3 31:18 32:1 32:23 37:12 38:7 62:2] 70:3 77:16 6:3 88:18
101:15 2:5
47:21
69:19 97:17
old [2] 18:5 79:18
once [2] 37:9 97:19
one [68] 8:23 14:8 17:2 20:6 22:14 26:11 27:3 27:16 28:14 34:2 40:13 48:2 49:20 50:10 50:11 50:14 50:17 51:3 51:4
51:8 54:3 54:19 55:1 55:12 59:4 59:9 59:16 62:16 65:15 69:12 72:23 76:22 78:18 79:13 79:15 83:11 84:2 84:9 84:13 95:6 97:1 98:19 100:1 100:21 100:23
13:6 17:7 25:20 27:5 28:16 46:23 49:21 50:12 50:22 51:5 54:19 55:11 59:7 60:16 69:1 76:16 78:18 80:6 84:5 84:21 97:4 100:6 101:1
one's pi
17:3
ones p] 14:8 77:19 77:21 88:2 88:6 101:21
73:1 80:3 88:6
onto p] 31:15 47:9 52:12
0O0 p] 101:23
opaque PI open p] 24:9
31:16
36:22 25:7
operate PI
operating pj 22:20 23:2 23:3 23:17 66:19 66:20
54:20
22:10 23:3 54:18
operation [2] 11:5 28:12
operations p] 11:8 14:23 15:2 16:10 63:7
operator [4i] 9:19 9:20 10:14 10:20 11:2 11:9 11:14 11:15 12:15 13:1 15:14 15:16 15:23 16:2 16:14 23:14
30:15 40:11 53:1 57:22 58:14 58:22
59:2 59:6 60:15 60:23 96:1
9:17 9:20 10:22 11:12 12:12 15:4 15:22 16:13 30:12 47:18
58:3 59:1 59:17 62:23
operator's [i] 48:22
operators [2] 59:13 62:23
opportunity p] 90:22
opposed pi OTal [i] 1:19
71:20
marked - PCBs
Joe Webb
order p] 61:18 61:19
orient [2] 18:3
17:9
oriented p] 18:11
original [21 21:12
1:19
OUr'sp] 100:13
OUTSpj 96:13
outside p7] 24:22 24:23
25:8 25:18 26:13 42:10
56:6 87:13 92:6 92:7 100:12
24:19 25:2
26:7
52:8 87:14 96:12
overhead pi 21:11
overloaded p] 98:9 OWENS [i] 1:5
own p] 26:3 43:13 78:15 78:15 97:1
oxide [i]
67:21
-P-
Ppi 3:1 5:1
3:1
P.M [i] 7:3
packing [4] 47:2 47:3 47:4 47:6
page [9] 4:4 4:6 4:7 4:16 74:12
75:18
4:5 4:8 74:16
pallet [i]
32:7
pan [7] 29:21 30:7
36:13 38:16 47:13 47:14 47:21
pane pj 36:14
pans p] 47:17 49:8 50:3
paper [4]
85:3
85:5 86:10 86:11
parathion [12] 77:6 77:11 77:16 77:17 79:3 81:20 82:4 86:12
14:22
77:15 78:21 81:21
part [9] 19:9 19:12 22:22
33:19 56:22 74:22
19:11 24:20 66:8
particular [7] 44:20 62:16 74:21 79:22
10:7 64:22 97:15
particularly p] 27:3
parties [3]
5:4
6:1 103:14
parts [3] 95:3 95:9 95:10
past [i] 73:21
PCB m 91:2 91:3 93:12 94:6
PCBs [13] 87:2 87:22 92:5 92:7 92:13 93:2
86:23 91:8 92:8 94:15
Index Page 5
HARTOLDMON0044444
Foshec & Turner
94:17 95:8 100:8
peeled [i]
37:12
people [i3] 48:21 54:19 84:9 87:12 88:5 88:12 91:5 92:2
24:3 76:11 87:23 88:13 96:12
period [2] 85:6
10:17
personal [i] 55:21
personnel [i] 75:23
Ph.D [l] 89:19
phonetic m 57:11
photograph [3] 16:21 17:6 56:18
pick [6] 29:20 32:6 38:14 62:3
30:6 54:17
picked [i]
61:10
picks [i]
46:3
picture [ij
66:4
pictures m 79:18
piece p] 32:9 54:16
pieces [i]
81:1
pin p] 29:19 30:1
pipe [io] 14:3 14:18 46:14 54:3 55:1 77:17 84:22
14:5 54:1 55:2
Piped [i]
46:13
pipes [7] 77:2 77:4 82:7 83:20
64:9 77:5 84:8
pit [10] 57:12 78:10 84:18
55:4 78:2 84:9 84:21
57:11 78:8 84:13
pits [8] 54:4 54:22 55:9 80:18 83:22
54:22 80:15 84:10
place [2] 69:5
56:19
placed [3] 75:7 75:9
74:19
places [5] 82:15 82:15 90:8
80:22 83:21
Plaintiffs pj 1:6 2:5 3:3
Plaintiffs' [5] 4:16 17:19 56:23 65:1 80:5
plant [57] 18:4 18:15 19:12 19:14 19:17 19:18 20:21 20:23 22:1 44:15 -44:23 45:1 54:6 --55:17 56:22 57:23 60:15 63:23 75:3 78:14 78:23 79:11 81:10 81:17 82:20 86:13
9:14 19:9 19:15 19:23 21:14 44:19 52:21 56:6 59:9 73:17 78:16 80:21 82:10 86:16
87:12 87:16 88:15 92:6 95:18 97:12
87:13 87:21 90:17 93:13 96:12 97:13
87:15 88:7 92:3 95:15 96:17
plate [i] 46:8
platform [i] 26:4
platforms [2] 24:7 24:10
playp] 58:8
PNP[3] 81:20 82:12 82:17
point [S] 19:21 36:1 52:10 57:8 70:2
pointed [2] 52:20
52:19
points [i]
80:22
policy [i]
98:1
pond [i] 57:11
portions [i] 82:9
pounds [2] 32:11
32:9
powder [2] 37:13
37:10
powders [i] 37:12
powdery [ij 37:14
power [i]
56:6
Prepared [i] 66:17
President pj 100:16 101:4 101:7 101:18
presumably [l] 81 16
pretty [2] 65:8
28:19
print [i] 98:5
printed p] 8:5 8:9 8:10
probationary [i] 10:17
problems [i] 91:19
Procedure [i] 1:16
process [i3] 10:5 29:18 38:4 39:18 44:6 71:2 72:5 72:7
10:5 33:23 43:13 71:10 77:7
processes [i] 68:8
produced [2] 43:13 58:21
product [l?] 31:5 31:9 33:21 37:15 46:1 46:3 61:12 64:16 68:7 70:22 99:12
30:21 31:17 39:13 61:11 67:23 99:7
production [S] 27:9 28:8 29:15 40:23 42:17
products [6] 36:9 37:16 49:21 67:21
27:6 42:12
program [i] 75:22
project [i]
75:20
Condensclt! TM
promise [i]
propeller [i]
property [i]
Public [i]
pull [1] 47:2
pulling [i]
pump [16]
45:1 45:4
45:9 45:14 46:4 47:2
45:9 45:23 46:5 47:15
pumped [4]
60:12 60:12
pumping [i]
pumps [1
45:19 45:22
49:18 49:20
purpose [i]
pursuant [i]
pusher [1] put [37] 24:1
27:20 28:3 31:17 36:6
41:5 42:13 54:21 55:1
56:8 56:13 61:12 61:14
61:22 63:10
64:8 77:10
80:6 83:13 85:22
70:15 78:19 83:4
85:5 86:3
putting p]
84:4 84:5
8:17 46:7 56:6 103:21
33:23 23:9 45:6 45:11 46:1 46:21 47:23
57:13 63:4 23:23 23:9 48:10
17:4
2:6 30:19 27:5 29:3 38:19 48:6 55:3 60:18 61:21 63:13 70:16 78:20 83:6 85:19
27:23
qualified [i]
questions ri2i 5:23 8:23 39:21 43:1 93:20 98:16 99:19 103:8
quick [i]
54:20 5:22 16:12 76:17 98:23
75:15
-R-
R[6] 2:3 3:20 5:6 103:21
railroad [2] 18:22
ran pj 42:18 59:9 64:11
rarely [i]
raters m
rather [3] 30:2 76:14
raw [4] 15:17 16:7 16:9
re-ask [i]
read [4] 18:12 92:10 92:14
reading [2] 75:16
3:1 103:1
18:20
59:7 64:12 27:22 83:3 8:14
15:17
93:10 74:17
5:12
real [2] 75:15 78:22
really [i3]
20:6 25:16 28:3 37:3 73:3 74:7 81:21 94:11
16:13 27:23 72:7 78:13 100:23
receive [1]
95:15
receiving [i] 95:18
recess p] 93:18
73:11
recommendations [i] 75:5
record [] 34:18 74:5 74:18 100:6
7:16 74:6
referring [ij 89:20
regular [i] relating [i]
84:16 5:16
relation [i]
103:14
relief p] 15:16 15:21 61:1
15:14 16:10
relieve [1] relieving [i]
15:23 15:18
remember p3i 22:2 24:17 32:14 32:15
57:18 57:19 58:11 58:12 62:12 63:22 69:10 74:21 78:3 78:10 83:23 85:18 87:2 87:5
89:3 89:5 89:8 89:20 90:6 90:9 90:15 91:8 91:13 91:14 91:18 92:16 93:11 95:12 95:17 96:5 100:15
10:23 27:23 53:7 57:19 59:21 64:20 75:21 78:11 85:21 88:19 89:7 89:23 90:11 91:10 91:16 93:1 95:14
96:6
remind [11
48:19
reminding [i] 48:20
remove [i]
reporter [4] 3:19 7:9
62:20
1:23 17:16
Reporter's [l] 4:8
representatives [i] 101:3
represents m 103:10
request [21 61:19
61:18
residue [1]
68:5
respective [i] 5:4
respiratory [i] 91:19
rest [2] 65:20 72:13
result [i]
103:16
results [4]
88:23
90:4 90:12 94:22
retained pj 1:23
reworked m 38:22
Rich [9] 29:17 32:8 36:20 73:14 87:17
peeled - S Joe Webb
88:15 89:8 94:3
93:21
rid [i] 98:2
right [7i]
8:20 9:13 11:10 12:3 14:11 15:6 16:18 16:19 18:16 20:18 21:14 21:18 22:9 26:21 29:3 31:1 32:22 34:10 37:6 40:12 41:14 43:17 49:1 50:23 51:19 52:1 52:7 52:18 55:10 56:4 57:3 59:5 65:13 65:17 65:21 70:6 71:6 71:7 72:12 74:2 79:1 79:19 84:15 95:6 97:6 99:6 100:20
8:19 10:1 13:12 16:3 18:14
20:22 21:22
27:12 32:15 36:8 41:1 48:9 51:13 52:1 54:21 56:5 62:15 65:17 71:5 71:23 77:1 83:9 96:20 100:10
road p] 52:21 65:13
Robertson p] 78:1 92:10 94:4
54:10
14:4 93:22
roller [z] 69:5
33:2
rolling [2] 30:1
29:19
roof [15] 24:16 25:4 25:5
25:16 25:20 25:23 26:1 26:7 26:11 27:14
24:18 25:13 25:23 26:2 27:1
roofed [1]
room [7] 22:11 23:2 23:3 64:19 72:12
26:5
22:12 23:17
rotating [ij 28:23
rounds [1] Rule [i] 1:15
48:1
rules [2] 1:16
run rm 10:5
33:18 36:13 40:14 40:21
33:19 40:7
40:16 41:4
41:20 71:15
5:16
33:17 33:20 40:9 40:19 41:16 90:7
running pj 40:4 40:21 44:1 60:3
33:13 41:17 70:22
runway [i]
69:4
Ruth [4] 3:7
17:2
29:17 98:15
S[4] 5:1
-s-
3:1 5:1
4:14
Index Page 6
HARTOLDMON0044445
Foshcc & Turner
s-a-n-t-a-w-a--X[I] 71:7
safety [i]
75:19
SAITH [i]
102:2
sample [2] 42:11
42:1
sampling [i] 39:13
sand [5] 61:12 61:21 62:8 62:11 63:10
santowax p] 35:21 57:12 71:6
35:17 71:4
says [3] 17:10 65:2 73:16
schedule [i] 88:4
scrape [i]
30:9
screw [] 30:18 31:5 31:16 32:21
29:12 31:13
seal [2] 32:2 49:6
seals [i] 32:4
second [12] 22:23 23:4 23:16 24:2 26:10 48:9 58:10 100:5
22:12 23:7 25:1 58:9
seconds [i] 93:16
section [i]
88:10
see m
36:16 57:21
17:9
37:3 65:10
20:11 42:15 72:8
selling [l]
64:16
send [3] 24:1 42:9
42:6
sent[i] 44:22
separate [3] 12:1 14:16 14:17
separation [ij 11:18
September [i] 12:6
series m
46:2
service [ij
66:15
set [9] 27:19 71:22
98:10
2:7 29:11 85:20
25:1 47:15 88:4
seven pj
71:1
several [4]
23:12
76:11 80:21 85:7
sewer [i]
81:16
sewers [i]
82:18
shaft [3] 46:19 46:20 46:20
shakes [3]
7:22
43:10 95:19
Shall [l] 5:21
shape [i]
85:16
shift [12] 33:18 41:3 50:9 50:10 59:18 60:23 61:7 63:1
23:21 41:3 50:11 61:5
shift's [2] 58:17
58:15
shifts [4]
33:15
33:19 33:20 58:18
shipping [7] 16:7 16:8 51:16 51:17
15:17 42:15
86:8
shop [3] 22:11 82:16 100:15
shops [i]
81:1
Short p] 93:18
73:11
Shortly [i]
98:23
shovel [2] 63:12
61:22
show [7] 8:3 16:23 17:6 21:3 52:13
16:20 21:2
shut [2] 14:22 66:11
shutdown [4] 12:10 13:3 66:12 66:13
side [i4] 11:19 18:8 19:17 20:2 21:19 25:18 25:20 56:12 57:7
18:7 19:18 25:16 30:8 57:8
signature m 5:12
situation [i] 53:13
sizes [2] 84:1 84:6
skip [2] 61:23 62:1
skips [i]
63:14
sleeve pj 31:15 32:1
31:14
slightly [i]
80:16
slings [i]
46:3
slipped [2] 32:1
31:14
sloped [i]
30:23
Sloping [i]
31:3
small [3]
49:17
54:16 83:17
Smaller [i]
69:17
SMITH [i] 3:13
snug [2] 47:3 47:6
Solid [25]
28:18 29:9 35:4 35:9 35:13 39:14 64:6 64:8 71:3 71:18 71:21 71:22 72:5 72:10 76:3 76:5
28:14 35:3 35:12 46:8 69:18 71:21 72:2 72:11 99:13
solidification [1] 36:1
solidified [i] 36:16
Solutia [5] 9:12 16:4 98:1
9:11 90:23
someone pj 40:9 51:15 89:20
sometimes [4] 50:20 50:20 50:21 54:15
somewhere m 42:10 44:19 56:4 64:22 65:12 84:23
sorry p] 48:19 76:22 86:20
Condcnselt! TM
south [S] 19:8 19:12 19:18 19:22 21:19
18:7
19:15 19:23
southeast p] 19:9 20:2 20:3
Speak [i]
86:18
specific [4] 40:7 40:10 41:20 42:4
Specifically p] 74:15 97:8 97:9
specifications p] 42:15 42:17
spell [2] 7:15 45:12
spend [2] 24:4
23:14
spent [ij
13:6
spill [i] 62:6
Spills [2] 63:6
62:7
split [i] 11:20
spoke [ij
89:5
SpOUt [1]
69:7
square m
52:3
St [2] 89:9 89:15
Stack [l] 32:7
stairs [i]
26:14
staple [i]
32:3
Starp] 92:11
start p] 9:6 9:16
23:23 36:11 68:17 92:4
started [ioj 16:17 31:16 45:15 89:2 92:5 95:17
10:2
32:10 91:22 96:16
State p] 7:1 103:21
103:3
STATES [i] 1:1
station [ij
48:8
stay p] 15:8 23:21
stayed [2] 72:13
15:9
steam p] 44:14 44:14 44:22 76:6 81:6 81:9
44:13 44:16 76:6
steamed [i] 77:9
Steel [2] 24:9 25:11
stenotype [i] 103:8
still p2] 9:9
15:23 16:2 16:6 57:14 62:23 64:9 67:16 68:4 69:10 69:17 69:38 69:20 70:4 70:5 70:21 71:15 72:2 76:21
78:15 100:19
13:13 16:6 57:22
67:15 69:2
69:17 69:21 70:6
71:16 76:21 101:7
Stills [5] 25:15 40:13 59:13 68:16 68:23
STIPULATED [4]
5:3 5:11 5:20
s-a-n-t-a-w-a-x - tighten Joe Webb
6:7
stipulations [3] 2:6 4:4 7:9
stop [4] 9:1 32:22 47:3 47:8
stopped [i] 32:21
storage p] 42:13 60:6 67:18
23:11 60:9
store [i] 67:19
stories [3]
22:14
22:17 66:21
Story p] 22:16 22:19
street [ioj 19:20 20:13 20:16 21:20 65:18 65:19
3:15 20:15 65:17 92:3
streets [2] 20:6
20:6
strictly [i]
82:12
strong [i]
39:16
structure [2] 25:9 26:3
studies [3]
90:2
90:5 90:12
Stuff [11] 37:21 56:7 64:19 84:4
84:23 85:5 86:11
28:1 62:20 84:22 85:19
Suite [2] 3:8 3:16
sunglasses p] 37:5
Supervision [i] 40:20
supervisor [i] 41:1
supported [i] 26:3
suspected [i] 91:17
sworn [i]
7:6
system [2] 98:9
44:6
-T-
T [5] 4:14 5:1 5:1 103:1 103:1
T-o-w--a-x [i] 71:8
taking [7j
5:16
82:7 83:20 84:7
84:9 99:3 99:8
Tammy pj 2:3 3:20 7:23 9:3 103:21
1:17
5:6 17:14
tank pi] 25:7 25:14 25:16 26:11 27:14
60:6 60:9
25:14 25:21 28:4
60:9
64:6 65:10 65:16 66:1 66:5 66:19 67:11 67:14 83:15
83:17
tanks [i2]
23:9 24:23 25:23 26:17 28:2 42:13 44:11 83:2
23:9 25:23 27:2
44:10
technically [i] 26:1
temperatuie pj 72:12
76:14
temporary p] 84:17
85:8
ten [s] 69:15 69:16 69:21 69:22 69:23 70:1 70:3 73:7
test [4] 88:4 88:23 90:4 92:1
tested [is]
86:22
87:7 87:9 87:11
87:14 87:21 88:1
88:13 90:19 90:23
92:2 94:20 96:12
96:13 100:13
testified [i] 7:7
testimony [4] 1:19 19:13 42:23 103:11
testing [2] 100:12
100:7
tests [4] 90:2 90:16 90:17 94:23
Texas [i]
3:9
Thank [i]
101:22
their's [i]
87:11
thereto PI 103:8
6:4
therminol [4] 67:20 67:20 67:21 67:22
they've [i] 55:19
thick p] 36:17 63:11
thicker PI 72:23
71:19
thin [i] 36:18
thinner PI 36:17
35:22
third [3] 22:19 24:4 26:12
thirteen [i] 59:23
thirty [i]
19:7
thirty-five [i] 74:12
thirty-four [i] 74:17
thoughl- [i] Thrasher p]
100:17
95:7 100:16
three [i?] 22:17 28:22 33:11 33:15 66:21 75:19 89:1 90:20
91:6 91:21 100:1
22:16 33:10
59:23 87:8
91:1 94:21
threw [l]
54:14
through po]
11:6 12:18 29:10 30:5 36:16 37:4 71:13 71:15
5:4
20:18 31:5 61:7 72:4
73:16 80:21 90:1 94:7 94:10 95:13
101:19
throughout [i] 61:5
thrown Ii]
39:9
tied [i] 82:9
tighten [i]
61:16
Index Page 7
HARTOLDMON0044446
Foshec & Turner
times [i2] 27:18 45:4 47:10 54:14
55:11 55:20 62:19 85:8
11:14 45:19 55:8 60:11
tint [2] 37:4 37:9
title [i] 89:22
[today [2]
67:16
98:17
|tOO[l0] 12:23 52:14 57:8
8:20 24:3 52:22 63:7
9:4 49:21 57:5
|took[4] 31:23 66:15 67:2 67:4
top [8] 20:16 30:7
17:10 18:23 24:13 26:8 31:1 73:17
tore[i] 67:9
tough [i]
21:6
toward [i] 80:5
TP [4] 85:4 85:15 85:17 85:17
{trade [i] 62:16
trailer [i]
83:15
trailers m 54:7
trained [i] 79:2
trainee [6]
9:17
9:19 9:20 9:21
10:14 10:15
transcribed [l] 103:9
transcript [3] 1:19 103:7 103:11
transcription [i] 103:10
transferred [2] 13:8 15:12
trash [8] 54:1 85:2 85:3 97:22 97:23
84:22 85:3 97:23
treat [i] 80:9
treatment [i4] 78:13 78:16 79:11 79:19 81:8 81:10 81:23 82:3 82:19
77:10 78:23 80:8 81:19 82:18
trial [i] 6:2
triangle [i]
56:8
trouble [I]
75:15
truck [2 54:6 62:3
Trucks [i]
54:7
true p] 18:19 103:11
try [4] 8:1
8:13
52:3 93:10
trying [3]
42:23
58:8 96:15
tubing i]
76:8
tumpp 31:18 75:14
turning [i]
46:2
twenty [*] 50:6 69:18
95:9 95:10
50:5 73:10
twenty -five [l] 69:18
twenty-four [i] 28:22
two [22] 12:1 25:22 25:23 36:9 59:13 69:14 74:1
75:6 79:19 89:1 90:20 91:6 91:21 97:20 100:1
22:14 28:13 66:21 74:16 87:8 90:23 94:21
two-wheel [i] 83:15
type [16] 9:19 30:18 39:17 45:9 45:23 59:5 62:2 69:6 76:8 90:5 97:11
29:12 43:17 47:2 62:16 86:3
types [3]
27:12
40:7 45:18
-u-
U[l] 5:1
uncomfortable [i] 34:14
under [9] 25:5 29:14 47:14 47:15 69:7 84:16
9:23 32:17 69:1
underneath [3] 29:21 68:18 68:23
understand [8] 9:1 9:2 11:1 39:19 39:21 94:11 96:10 96:10
underway [i] 75:20
union [6]
100:11
100:14 101:4 101:7
101:9 101:20
unit[i] 65:4
UNITED [i] 1:1
unless [i]
34:19
unloaded [i] 76:23
unloading [4j 15:17 16:7 "1"6:8 16:9
Up [71]
8:10
11:20 21:2 26:14 31:15 35:1 41:9 43:20 46:3 49:6 50:12 51:3 53:12 54:17 59:19 61:9 61:16 62:3 62:18 68:18 78:21 85:10 88:4
8:5 9:3 15:20 21:3 29:20 32:2
37:1 43:16 44:2 47:3 50:9 50:14
51:10 54:5 55:5 61:6 61:10 61:22 62:8
62:20 68:22
82:18 86:8 90:14
8:9 11:6 19:14
25:11 30:7 32:6 38:14
43:18 44:4 47:6 50:10 50:22
52:13 54:6 55:14 61:8 61:13 61:22 62:11 63:12 71:22 84:12 86:18 95:22
upside [i]
75:16
Condenselt!
used [i3] 37:16 37:20 62:11 67:16 68:10 73:14 78:2 82:3
users [i]90:8
using p] 76:8 78:8
Usual [i]
usually [6] 51:16 54:19 70:3 97:18
utilized [i]
20:5 55:20 67:18 77:17 82:12
55:17
7:9 44:10 59:21
24:22
-V-
vacuum [i]
vague [i] valve [i] varied [sj
47:23 50:19 70:22
versus jij vessel [i] vessels p]
23:6 viscus [i]
volume [i] VS[1] 1:8
22:21 93:9 31:16 47:22 69:11
72:5 23:23 22:3
43:21 27:10
-w-
W-e-b-b [i]
Wait[i] 100:5
waived p] 6:8
walk [i] 24:12
walked [2] 26:11
WALTER [i]
15:14
15:23 96:19 97:10
15:16 16:2 96:22
wash [l] 62:20
washed pi 77:13
waste [is] 78:13 78:15 79:10 79:19 80:9 81:7 81:19 81:23 82:18 82:19
wastes [i]
watching [i]
water [4] 81:6 81:9
Webb [131
2:2 4:3
7:5 7:15 63:15 73:12 74:11 93:19
week p] 13:6 51:6
weeks [i]
7:19
5:13
24:10
1:5 15:12 15:21 96:7 97:5
77:9
77:10 78:23 80:8 81:10 82:3
81:22 39:2 63:20 82:20 1:13 5:5 7:19 74:7 97:8 51:3
97:21
| weigh fi]
32:7
Welcome [i] 73:17
west[5] 18:16 56:1 56:9 56:12 92:2
whatnot [i] 78:9
wheelbarrow [i] 61:23
white [2] 52:9
21:6
whitish Pi
37:10
whole [8] 12:12 27:17 89:2 97:4 97:13
11:13 63:21 97:12
wider [i]
31:1
windows [i] 36:23
wise [i] 27:10
witness psj
5:13 7:22 30:16 34:20
48:13 48:15 49:3 52:5 52:15 52:23 56:15 57:6 66:3 75:13 83:1 84:19 86:19 93:4 103:12
4:3 21:13 43:10 48:18 52:11
56:11 57:9 79:8 86:2 95:19
wood [4]
85:3
85:5 86:6 86:7
word [3] 36:22 45:10 89:14
words [3] 45:23 98:1
36:6
worked [5] 88:2 88:5
88:12
15:17 88:6
works [i]
78:23
worry [i]
43:15
wound [i]
82:18
Wright [32]
3:6 4:5 7:11 7:14 17:5 17:13 34:6 34:10 34:23 41:19 73:6 73:9 74:4 74:7 79:10 86:20 93:9 93:15 98:13 98:16 99:18
1:18 4:7 8:7 17:17 34:13
48:19 73:12
79:7 93:5
93:19 98:20
write [xi] 8:14 8:16 52:8 52:9 57:7 59:19 80:4
8:1 9:3 56:12 60:4
X [3]
20:16
-X-
4:1
4:14
-Y-
y'all [i] 101:4 year[i] 57:19
times - yourself
Joe Webb
years [ioj 56:2 87:8 90:20 91:1 91:21 92:14
19:7 89:1 91:6 94:21
yellow p] 21:16 36:20 37:4 72:22
21:8 36:21
yesterday p] 29:18 87:17
yourself [i] 74:3
Index Page 8
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HARTOLDMON0044448