Document 855wGyDgpDN95ek1BaKonX0ea

1 1 In Re: 2 Solutia, et al. , 3 4 vs Case No. CV-03-PWG-134-E 5 6 McWane, et al., 7 8 9 10 11 12 April 28, 2005 13 14 30(b) (6) Deposition of SOLUTIA, INC. 15 (Witness: ROBERT GEORGE KALEY, II 16 17 18 19 20 21 22 23 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045599 2 1 In the United States District Court 2 For the Northern District of Alabama 3 Magistrate Judge Green 4 5 Solutia, et al., 6 .............................. Plaintiffs 7 8 vs................................. Case No. CV-03-PWG-134-E. 9 10 McWane, et al., 11 .............................. Defendants. 12 13 14 15 16 30(b) (6) Deposition of SOLUTIA, INC. (Witness: ROBERT 17 GEORGE KALEY, II), taken on behalf of the Defendants, 18 at the offices of Husch & Eppenberger, LLC, 190 19 Carondelet Plaza, Suite 600, in the County of 20 St. Louis, State of Missouri, between the hours of 21 9:14 A.M. and 2:11 P.M. on the 28th day of April, 22 2004, before J. Bryan Jordan, Certified Court Reporter 23 No. 00532 and Notary Public, State of Missouri. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045600 3 1 APPEARANCES OF COUNSEL: 2 FOR THE PLAINTIFF: 3 Joseph G. Nassif, Esq. 4 Richard P. Jacobs, Esq. 5 HUSCH & EPPENBERGER, LLC 6 190 Carondelet Plaza, Suite 600 7 St. Louis, MO 63105-3441 8 Telephone: 314-480-1500 9 Direct (314) 480-1818 10 Fax 314-480-1505 11 j oseph.nassif@husch.com 12 richard.j acobs@husch.com 13 14 FOR WALTER INDUSTRIES AND U.S. PIPE AND FOUNDRY 15 COMPANY: 16 James A. Langlais, Esq. 17 ALSTON & BIRD, LLP 18 One Atlantic Center 19 1201 West Peachtree Street 20 Atlanta, GA 30309-3424 21 (404) 881-7000 22 Fax (404) 253-8695 23 jlanglais@alston.com Kaley, Robert; Solutia 30 (b)( ); McWane WATER PCB-SD0000045601 4 1 FOR McWANE, FMC, AND UNITED DEFENSE: 2 D. Bart Turner, Esq. 3 MAYNARD, COOPER & GALE, P.C. 4 1901 Sixth Avenue North 5 Suite 2400 AmSouth/Harbert Plaza 6 Birmingham, AL 35203-2618 7 (205) 254-1238 8 Fax 9205) 254-1999 9 dturner@maynardcooper.com 10 11 FOR MEAD WESTVACO: 12 Wendlene M. Lavey, Esq. (Appearing via telephone) 13 SQUIRE, SANDERS & DEMPSEY, L.L.P. 14 4900 Key Tower 15 127 Public Square 16 Cleveland, OH 44114-1304 17 Direct (216) 479-8545 18 Fax: (216) 479-8780 19 wlavey@ssd.com 20 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045602 5 1 FOR HURON VALLEY STEEL: 2 Stephanie Rutledge, Esq. (Appearing via telephone) 3 BUTZEL LONG 4 100 Bloomfield Parkway, Suite 200 5 Bloomfield Hills, MI 48304-2949 6 (248) 258-1616 7 Fax (248) 258-1439 8 rutledge@butzel.com 9 10 FOR SCIENTIFIC-ATLANTA, INC.: 11 Timothy J. Kozik, Esq. (Appearing via telephone) 12 TROUTMAN SANDERS LLP 13 NationsBank Plaza, Suite 5200 14 600 Peachtree Street, Northeast 15 Atlanta, GA 30308-2216 16 Direct (404) 885-3266 17 Fax (404) 962-6622 18 timothy.kozik@troutmansanders.com 19 20 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045603 6 1 FOR PHELPS DODGE: 2 Lynne Stephens O'Neal, Esq. (Appearing via telephone) 3 LEITMAN, SIEGAL & PAYNE, P.C. 4 600 North 20th Street 5 Suite 400 6 Birmingham, AL 85203 7 (205-251-5900 8 Direct (202) 986-5023 9 Fax (205) 323-2197 10 sls@lsppc.com 11 12 FOR SOUTHERN TOOL: 13 Ms. Allison E. McAdam, Esq. (Appearing via telephone) 14 RESOLUTION LAW GROUP, P.C. 15 3717 Mount Diablo Road, Suite 200 16 Lafayette, CA 94549 17 (925) 284-0840 18 Fax (925) 284-0870 19 allison.mcadam@resolutionlawgroup.com 20 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045604 7 1 2 INDEX 3 4 Examination by Mr. Langlais 5 6 7 8 EXHIBITS 9 10 DEFENDANT'S DEPOSITION EXHIBITS 11 Solutia 1 ................................................................................................. 28 12 Solutia 2 ................................................................................................. 30 13 Solutia 3 ................................................................................................. 50 14 Solutia 4 ................................................................................................. 50 15 Solutia 5 ................................................................................................. 69 16 Solutia 6 ................................................................................................. 106 17 Solutia 7 ................................................................................................. 97 18 Solutia 8 ................................................................................................. 93 19 Solutia 9 ................................................................................................. 127 20 Solutia 10 ................................................................................................. 133 21 Solutia 11 ................................................................................................. 136 22 Solutia 12 ................................................................................................. 150 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045605 ROBERT KALEY II, of lawful age, having been first duly sworn to testify the truth, the whole truth, and nothing but the truth in the case aforesaid, deposes and says in reply to oral interrogatories propounded as follows, to-wit: EXAMINATION QUESTIONS BY MR. LANGLAIS: Q. Would you, please, state your full name for the record? A. Robert George Kaley II. Q. Mr. Kaley, my name is Jim Langlais, and I represent United States Pipe & Foundry Company and Walter Industries, Inc. This is Bart Turner. Bart Turner represents several different clients. MR. TURNER: Yes, FMC, United Defense, McWane, and Ransom. BY MR. LANGLAIS: Q. Now, you are --you have been designated by Solutia as a corporate representative to speak about certain matters in this deposition; is that correct? A. It's my understanding, yes. Q. And I guess the first one, you are here to speak about the history and description of operations, chemical manufacturing processes, products, periods of production, byproducts and waste at the Anniston Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045606 9 1 facility, specifically involving PCBs; is that 2 correct? 3 A. I think parts of that. I'm not sure it was 4 all of that. 5 MR. NASSIF: He's here to talk about the 6 PCB--the history of PCB production in terms of what 7 conjuners and what Aroclors were made over a period of 8 time at the Anniston Plant. Jerry Brown is going to 9 do more of the actual process information of all the 10 products and all the processes at Anniston over an 11 historical period. 12 MS. RUTLEDGE: Excuse me, but I can barely 13 hear you. 14 MS. LAVEY: This is Wendy. I really 15 couldn't hear anything, either, although I could hear 16 Joe just now pretty clearly. 17 MR. LANGLAIS: We'll try to speak louder. 18 MR. KOZIK: This is Tim Kozik here. Same 19 thing: Can't hear very well. 20 MR. LANGLAIS: Joe, I just want to make sure 21 I'm clear. In that topic 1, I thought he was, he was 22 going to speak not about, obviously, all the other 23 processes but the PCB, all of that information 24 relating to the PCB products at the plant. Now, was 25 that not what he's-- Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045607 10 1 MR. NASSIF: He's going to speak about--he's 2 not going to speak about the PCB process in terms of 3 how it worked and all that, all that elements, Jim. 4 What he's going to speak about is all the products 5 that were made over what period of time, the different 6 PCB products that were made at the Anniston plant over 7 what period of time. 8 MR. LANGLAIS: So he's not going to talk 9 about byproducts and waste associated with those? 10 MR. NASSIF: No, Jerry Brown is going to do 11 that because he has the--he was actually there at the 12 manufacturing of the plant, has all that background 13 information. 14 MR. LANGLAIS: So he's only going to--just 15 so I'm clear, he's only going to say things like 16 Aroclor 1268 was manufactured from this period of time 17 to this period of time? 18 MR. NASSIF: Right. Right. 19 MR. LANGLAIS: And that's it. 20 MR. NASSIF: Yeah, and basically, 21 information relating to when they started, what they 22 were used for, particular Aroclors were used for, and 23 that kind of thing. 24 MR. LANGLAIS: But if I ask him about--to 25 describe the process, he's not going to be able to Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045608 11 1 tell me? 2 MR. NASSIF: Well, he has information on it, 3 but he's not the 30(b) (6) witness for that. Jerry 4 Brown, who actually was the process chemist for the 5 process, is going to do all that. 6 MR. LANGLAIS: Okay, I think I misunderstood 7 that part of it. He is here to speak about the lead 8 pot process. 9 MR. NASSIF: Yes, he is. 10 MR. LANGLAIS: And there is a litany of 11 things, A through K, involving the lead pot process. 12 Everything listed in that number 4 on our notice-- 13 MR. NASSIF: I'll take a look at that. 14 MR. TURNER: That's obviously going to bleed 15 over into the process. 16 MR. NASSIF: Right, and to that extent, 17 Jerry Brown, who has all the background information, 18 was assigned to the process for a number of years, is 19 going to talk about that. 20 MR. TURNER: Okay. 21 MR. NASSIF: But Bob is going to talk about 22 the lead pot process. The lead pot process actually 23 stopped before Jerry Brown started at the plant. Bob 24 is going to talk about the lead pot process because he 25 actually did a study associated with that. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045609 12 1 MR. TURNER: Okay. 2 MR. NASSIF: Not a study where he wrote a 3 paper or anything, but he actually looked into it and 4 got information on that. That's how we divided it up. 5 MR. TURNER: Okay. 6 MR. NASSIF: Okay? Let me look at Number 4. 7 This one here. 8 MR. LANGLAIS: Yeah. 9 MR. NASSIF: Under Exhibit A, Jim? 10 MR. LANGLAIS: Yeah. Instead of reading it, 11 reading it out, it's a matter of record. I mean, we 12 can just-- 13 MR. NASSIF: He will talk about--to the 14 extent the lead pot process is involved in all of 15 these A through K, Bob will talk about it. 16 MR. LANGLAIS: Okay. 17 MR. NASSIF: Okay. 18 BY MR. LANGLAIS: 19 Q. Mr. Kaley, this is your first deposition as 20 a corporate witness; is that correct? 21 A. First in this case or first ever? 22 Q. First, first ever. 23 A. No, that's not correct. 24 Q. Okay. On how many occasions have you 25 testified as a corporate witness before? Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045610 13 1 A. At least once. 2 Q. Okay. 3 A. Once that I can recall. 4 Q. And was that for Solutia? 5 A. I believe it was for Monsanto at the time. 6 Q. Okay. 7 A. If you are using those, I mean if you are using those interchangeably, as I think we agreed last 9 time-- 10 Q. Yeah. 11 A. Yes, it was for Monsanto/Solutia. 12 Q. Yeah, and that was the point I was going to 13 make, that throughout the course of this deposition, 14 if I refer to Monsanto, I mean the, what you all refer 15 to as the "old Monsanto," the company that, that 16 became--that spun off the Solutia Company and the 17 Pharmacia Company. I'm not talking about the new 18 entity. That's agreeable with you? 19 A. That's fine, yes. 20 Q. Okay. Do you recall when you testified for 21 Monsanto in the past? 22 A. As a corporate representative. 23 Q. Yes. 24 A. Um, I would say it's seven to ten years ago. 25 Q. Do you recall what kind of case that was in? Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045611 14 1 A. It was a personal injury case under which 2 Monsanto had been third partied. 3 Q. What kinds of topics were you testifying 4 about? 5 A. Basically, health and safety warnings of 6 Monsanto products. PCBs, not all of Monsanto 7 products. 8 Q. Did it involve someone --did it involve the 9 injury of an employee of Monsanto? 10 A. No. 11 Q. Okay. What, what--who was injured in that 12 case? 13 A. Some employees of a junior college in New 14 Jersey. 15 Q. Okay, do you recall how, how they were 16 inj ured? 17 MR. NASSIF: Allegedly injured. 18 A. Allegedly injured? It had to do with the 19 use of PCBs as a plasticizer and in some ceiling tiles 20 in that building. 21 BY MR. LANGLAIS: 22 Q. Okay. You've been deposed several times 23 before, not just as a corporate witness but as in your 24 individual capacity; correct? 25 A. That's correct. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045612 15 1 Q. So you kind of know the, what's going to 2 happen here, today, with the court reporter and my 3 asking you questions? 4 A. Yes, I do. 5 Q. Okay. In fact, do you remember me? I 6 deposed you as part of your testimony as a fact 7 witness in this case. 8 A. I do remember you, yes. 9 Q. Okay. I don't know if that's good or bad, 10 but you remember me; that's good. Would you prefer 11 that I refer to you as "Dr. Kaley" or is "Mr. Kaley" 12 okay? 13 A. "Bob" is fine. 14 Q. Okay. If I ask you a question and you don't 15 understand it, please tell me, because if you answer 16 it, I'm going to assume that you've understood the 17 question that I've asked. Is that agreeable? 18 A. That's fine. 19 Q. Before you begin, I recall last time, you 20 don't work for Solutia anymore; is that correct? 21 A. That's correct. 22 Q. But you do consulting work for Solutia. 23 A. That's correct. 24 Q. You also do consulting work for Pharmacia? 25 A. That's correct. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045613 16 1 Q. And how about the new Monsanto, the new 2 entity? 3 A. Only to the extent that, you know--well, the 4 answer is no, I do not do consulting work for the 5 agricultural business, the new Monsanto. 6 Q. And am I correct that you are paid a set 7 monthly fee, regardless of whether you perform 8 consulting services for any of those entities we just 9 mentioned? 10 A. That's correct. 11 Q. And what is--how much is that? 12 A. $13,500 a month. 13 Q. Okay, has that changed since the last time 14 we talked at-15 A. No, it-- 16 Q. --your last depo? 17 A. I'm sorry. No, it has not. 18 Q. Let's talk about the biphenyl production and 19 the lead pot process. How did you prepare for your 20 testimony here, today, concerning the lead pot 21 process ? 22 A. I reviewed my previous deposition, and I 23 reviewed the documents that were submitted in response 24 to EPA's, I think it's 104(e) request on, on 25 Monsanto's use of lead in the Anniston facility. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045614 17 1 Q. Did you look at any other documents? 2 A. No. 3 Q. Did you request any other documents? 4 A. No. 5 Q. Okay. Who did you speak with in preparation 6 for your testimony today? 7 A. I spoke briefly with Jerry Brown and then 8 attorneys. 9 Q. Were the attorneys present when you spoke to 10 Jerry Brown? 11 A. No. 12 Q. Do you recall what, specifically, you and 13 Jerry discussed? 14 A. Just to be sure that the information I 15 provided in my previous deposition was, was correct 16 according to both Jerry's memory and with regard to 17 his conversations with former employees. 18 Q. In reviewing your deposition, did you--and 19 speaking with Jerry, did you encounter anything in 20 your deposition that is incorrect, as far as you can 21 tell? 22 A. There were a couple of minor points that I 23 don't know that it was incorrect. I said I didn't 24 know a couple of things, and now I think I do know 25 those things. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045615 18 1 Q. Do you recall what points those were? 2 A. Yes. I think there was some discussion of 3 whether Monsanto used the lead pot process to produce 4 biphenyl at any other facility, and I believe I said I 5 don't know. I know now that they did, there was one 6 lead pot unit at the Newport, Wales facility, and I 7 believe there was also a question as to whether 8 Monsanto used the lead pot process at any other plants 9 for any other purpose besides producing biphenyl, and 10 I now know that Monsanto did use the lead pot process 11 or a lead pot process at the Texas, Texas City 12 facility to --as part of a petroleum cracking 13 operation. 14 Q. Now, was any other process at the Anniston 15 facility, did any other process at the Anniston 16 facility use the lead pot process or some similar 17 process ? 18 A. No, just the biphenyl. 19 Q. Just for the biphenyl? 20 A. That's correct. 21 Q. And you said that the Newport facility in 22 the United Kingdom had, had one unit? 23 A. That's correct. 24 Q. And we'll get into the details later, but 25 that one unit consists of the three lead pots, right? Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045616 19 1 A. You are correct. 2 Q. You've got the two preheater pots and then 3 the converter pot? 4 A. That's correct. 5 Q. Okay. Did you see that in any documents or 6 did you--were you told that by Jerry Brown? 7 A. I believe I saw it in documents. 8 Q. And are those documents in the stack that 9 you provided to us here today? 10 A. Yes. 11 Q. Were there any other points that you saw in 12 your testimony that, that you feel now you have more 13 accurate information? 14 A. No. 15 Q. Did you speak with any other former Monsanto 16 employees about the lead pot process? 17 A. Not personally, no. 18 Q. Have you ever? 19 A. No. 20 Q. Just your discussions have involved just 21 discussions with Jerry Brown; is that right? 22 A. That's correct. 23 Q. Do you know who Jerry Brown spoke with? 24 A. I know, I believe, a couple of the names, 25 yes . Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045617 20 1 Q. Okay, and what are their names? 2 A. I think there was Gene Arnette and Thomas 3 Lackey, and there may have been another, but I don't 4 recall the name. 5 Q. Now, is it your recollection that those two 6 individuals were employed at the facility during the 7 time the lead pot process was being utilized? 8 A. Yes. 9 Q. Do you know if either of these gentlemen 10 actually was involved in the lead pot process? The 11 biphenyl production? 12 A. I don't recall. I don't think so. I don't 13 recall specifically. 14 Q. Have you--have--has Monsanto identified 15 anybody who was actually part of the lead pot process 16 to produce biphenyls? 17 A. My understanding is that Jerry Brown 18 contacted those people who he thought could best 19 answer those questions, and those were the names that 20 he came up with and that he spoke to, so to the extent 21 that he didn't identify any other names, I believe 22 there are not people available. 23 Q. After learning that the Newport facility 24 utilized the lead pot process to manufacture 25 biphenyls, did you make any--first of all, is the UK Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045618 21 facility still in existence? A. The facility, itself, is. They, obviously, no longer make PCBs there. Q. Right. Did you make any inquiry of the Newport facility to determine if they had any documents relating to their use of a lead pot process to produce biphenyl? A. No. Q. Do you, in fact, know if, if the United Kingdom has documents relating to the lead pot process -- A. No. Q. --to manufacture biphenyl? A. No, I don't know. Q. Do you know if Jerry Brown spoke to anyone in the UK about the biphenyl lead pot process? A. Not to my knowledge. Q. Do you know why you were selected to speak about the lead pot process, as opposed to Jerry Brown? MR. NASSIF: Wait a minute, Bob. I'll object on the basis that's privileged information. MR. LANGLAIS: You are going to instruct him not to answer? MR. NASSIF: Yes. Now, if you want to ask him if he had any prior experience about the lead pot Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045619 22 process or any of that, but I think the selection of a witness as a 30(b) (6) deposition involves attorney work product. MR. LANGLAIS: Okay, let me ask it this way. BY MR. LANGLAIS: Q. How long have you known about the lead pot process ? When did you first learn of that? A. Sometime prior to a letter I wrote to the Alabama Department of Environmental Management in the year 2000 Summer of 2000 would be my best estimate. Q. Do you know when Jerry Brown acquired his knowledge about the lead pot process? A. I assume soon after he joined the plant in 1967 . Q. Do you feel you are more qualified to speak about the lead pot process than Jerry Brown? A. As I sit here today, yes. Q. So is it your, is it your testimony that you believe that all the information that Jerry Brown has about the lead pot process, he's downloaded to you? A. I believe that, yes. Q. And that information you believe is accurate? A. I do, yes. Q. When were you first notified about being the Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045620 23 1 corporate witness for the 30--for the lead pot 2 process ? 3 A. I don't recall specific date. Maybe two 4 months ago is my best guess. 5 Q. And in connection with the lead pot process, 6 how long did you prepare for the testimony you are 7 giving here today? 8 A. Well, I, I mean that's a difficult question 9 to answer. I spent much time in 2000 reviewing SMPs 10 and documents to prepare for that letter. Subsequent 11 to that, specifically for today, a day or so. 12 Q. And we'll come back to the letters, or the 13 letter sent to ADEM that you are referring to later in 14 this depo. So am I correct that in addition to Jerry 15 Brown, you relied upon the standard manufacturing 16 procedures and the standard operating instructions for 17 the lead pot process in preparing for your depo here 18 today? 19 A. Primarily, yes. 20 Q. And what other, what other documents --I'm 21 going to look through those documents during a break, 22 but what other documents do you recall looking at in 23 preparing for your depo? 24 A. That's primarily it. There were some that I 25 wouldn't--there were process descriptions which Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045621 24 1 weren't officially process, you know, standard 2 operating procedures, but they fall largely into 3 that--contain that same information and largely into a 4 that same category. 5 Q. Am I correct that the lead pot process at 6 Anniston operated from approximately 1928 through 7 1964? 8 A. Yes, although in the last three years from 9 1961 to 1964, it operated only sporadically. 10 Q. What do you mean by "sporadic"? 11 A. I don't know specifically, but I know that 12 there is information that it was pretty much shut down 13 in 1962 and that it may have been reinstituted for 14 short periods up to 1964 if there were need, but I 15 don't know specifically how often or to what extent. 16 Q. Are you able to tell me what the production 17 levels were for biphenyl over the history of the lead 18 pot process? 19 A. Not in any great detail, although there 20 are --there is information in those documents, numbers 21 like ten to twenty million pounds a year in high 22 production years. 23 Q. And do you recall--you said that the 24 operation was sporadic from '64--'61 to '64. Do you 25 know how much the production level dropped off during Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045622 25 1 that time? 2 A. Well, the production level for biphenyl 3 didn't drop off-- 4 Q. Right. 5 A. --because they went to a different process. 6 I don't know the split between what would have been 7 manufactured by the updated process and the 8 biphenyl--and the lead pot process. 9 Q. You didn't encounter any documents that show 10 what the production levels were during that time 11 period, the '61-to-'64 time period? 12 A. Not splitting out the information of--for 13 the lead pot process specifically, no. 14 Q. So you might see a number for biphenyl in 15 '62, but that doesn't necessarily mean that that 16 amount was produced through the lead pot process, it 17 was either through the lead pot process or--how did 18 they refer to the process after the lead pot process? 19 A. Tubular process. 20 Q. Right. Does the, does the Solutia facility 21 still produce biphenyl? 22 A. It does. 23 Q. And do they still use the tubular process 24 that you just referred to? 25 A. Yes, I believe they do, yes. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045623 26 1 Q. Now, biphenyl is, over the history of its 2 manufacture, biphenyl was a raw material for PCBs, 3 correct? 4 A. That was one of its uses, yes. 5 Q. But it was also sold as a product? 6 A. That's correct. 7 Q. And it was sold to, to other Monsanto 8 plants? 9 A. Well, certainly. 10 Q. Or transferred, however you want to define 11 it? 12 A. Yes. Yes, it was. 13 Q. And those other plants would make PCB 14 products from that biphenyl? 15 A. Well, a single plant, the Sauget plant in 16 Illinois, used biphenyl for that purpose, yes. 17 Q. Do you know who the UK plant was selling 18 their biphenyl to? 19 A. My understanding is that it was all used 20 internally to manufacture PCBs. 21 Q. Okay. Now, biphenyl was also a product, 22 itself, that was sold to non-Monsanto companies, 23 correct? 24 A. That's correct. 25 Q. Do you know what, what those companies used Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045624 27 1 it for? 2 A. There were several uses. The largest use 3 and the use today is as a heat transfer fluid. It was 4 also used as a fungistat on--for packing citrus 5 fruits. Those are the two that I know for sure. 6 Q. Are you aware of any other companies that 7 made PCBs from that biphenyl? 8 A. No. 9 Q. In your--the documents that you produced, do 10 you have any maps that show the location of where the 11 lead pot process occurred? 12 A. I believe there is one, yes. 13 MR. LANGLAIS: Okay, can we, maybe, go off 14 the record for that while he looks for that map? 15 MR. NASSIF: Do you want to go find it or 16 can you find it? 17 THE WITNESS: Yeah, I think so. It's in 18 there. 19 MR. NASSIF: Why don't you hand him that 20 binder there? 21 MR. TURNER: This is the top one. 22 THE WITNESS: I don't know which binder it's 23 in. 24 MR. NASSIF: Okay. 25 THE WITNESS: I don't think it's the top Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045625 28 1 one, but it might have been. 2 MR. TURNER: I tell you what: I'll grab, 3 look through-4 THE WITNESS: It's attached to Craig 5 Branchfield's letter to ADEM. 6 MR. TURNER: Okay. 7 THE WITNESS: It's going to be a short 8 document. 9 MR. TURNER: In 2000? 10 THE WITNESS: Yeah, would have been Spring 11 of 2001. 12 MR. LANGLAIS: Let's go off the record until 13 we locate that. 14 (Discussion of the 15 record.) 16 MR. LANGLAIS: Let's get back on the record. 17 (Defendant's Deposition 18 Exhibit Solutia 1 mark'd 19 for identification.) 20 BY MR. LANGLAIS: 21 Q. Mr. Kaley, I'm going to hand you what we'll 22 mark as Solutia Exhibit 1, and it's DSW 044183 and 23 appears to be a layout of the Monsanto facility. 24 Would you agree with that? The date on there is 1993. 25 A. Um, yes, I would. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045626 29 1 Q. Okay. Now, were you able--I'll hand you my 2 pen--are you able to mark on there the location of 3 where the lead pot process occurred-- 4 A. Roughly. 5 Q. --at the facility? Okay. 6 A. It's roughly within this blue circled area. 7 Q. And would you just put, just put "Lead pot" 8 next to that? 9 A. Obviously, in 1993, it was not there,-- 10 Q. Sure. 11 A. --but it was in that same general area where 12 biphenyl is manufactured today. 13 Q. Now, there are structures there now, right? 14 A. Yes . 15 Q. And what's manufactured there now? 16 A. Biphenyl. 17 Q. Okay. Do you recall whether, whether the 18 lead pot process was anywhere else at this facility, 19 any other location? 20 A. My understanding is that it was not. That 21 was the location where the lead pot process resided. 22 Q. We'll leave this out because it may help. 23 I'm going to hand you six, six aerial photographs that 24 were produced to us by Monsanto in this case, and for 25 the sake of the people on the phone, I'll go ahead and Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045627 30 1 read out the Bates numbers. ADAD7-000040; 2 ADAD7-000041; same, same general Bates number, the 3 next one is, ends in 65. The next one is 77. The 4 next one is 83, and the last one is 157, and we'll 5 just, we'll just keep these together as Solutia 6 Exhibit Number 2. 7 (Defendant's Deposition 8 Exhibit Solutia 2 mark'd 9 for identification.) 10 BY MR. LANGLAIS: 11 Q. What I'd like you to do is to look through 12 these aerial photographs and to the extent you can, 13 circle and put "LP" next in the area that you believe 14 the lead pot process occurred. 15 (Witness complies.) 16 Q. (Continuing) Now, in Exhibit 1, this here 17 (Indicating), is this Highway 202? 18 A. Yes, it is. 19 MR. LANGLAIS: For the sake of the people on 20 the phone, in Solutia Exhibit 1, he has marked a 21 location that borders Highway 202. 22 (Witness peruses and marks 23 on photographs comprising 24 Solutia Exhibit 2.) 25 A. On 41, I don't believe that the process is Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045628 31 1 shown, so I'm going to put an "NS"-- 2 BY MR. LANGLAIS: 3 Q. Okay. 4 A. --on the bottom of that one. As I orient 5 myself, I can't locate it. 6 (Witness continues to 7 peruse photographs.) 8 A. (Continuing) On 65, I don't believe 9 there's--I can't--it's a more close-up shot, and I 10 don't have good reference point. Highway 202 is my 11 reference point. I'm going to circle an area and put 12 a question mark by it. I'll put "LP" question mark. 13 Q. Does the train spur shown on that photo help 14 you at all? 15 A. Yeah, to some extent. I mean I'm, I'm 16 fairly sure where it is, because of the curving 17 railroad spur, but I'm just--I don't want to say I'm 18 totally positive, and I don't know the year of that 19 map. Again, I'm assuming that these maps are from 20 years in which the lead pot process was operating. 21 I'm basically circling where the biphenyl operation 22 is, so depending on which year this map is, then 23 that's going to-24 Q. Sure. 25 A. --adjust my answer. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045629 32 1 (Witness continues to 2 peruse photographs.) 3 A. (Continuing) Okay, I've completed marking 4 the aerials. 5 Q. Now, can you describe for me the, the 6 structure that the biphenyl process took place in? 7 A. My understanding has been that it was, it 8 was basically an, an open area, and that is pretty 9 much confirmed--well, it looks, here, that there is 10 some sort of building associated with, with, 11 certainly, the biphenyl PCB process area, and I'm not 12 sure exactly whether the lead pots were in the 13 building or not. I believe they were because 14 certainly, a concrete floor is described in the lead 15 pot process area in some of the documents, and so I 16 believe it was in the front part of this building. 17 I'm looking at 77 now. 18 Q. And that's, that's dated, what appears to be 19 dated 3:30:53? 20 A. That's correct. So my, my clearest answer 21 is that the lead pot process was in the bottommost 22 portion of the building shown in the circled area. 23 Q. Okay, and your--I know you've looked at the 24 photo, but in your review of documents, was there any 25 description of the building where the, where the Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045630 33 1 process was performed? 2 A. I don't recall. 3 Q. Now, am I correct that I believe you 4 testified last time that it was a building that had a 5 roof but no walls? 6 A. That was my assumption, and I don't--this--I 7 mean, if I look at this building, it clearly has 8 walls, and I also believe in the documents, it does 9 talk about ventilators in the roof, so it must have 10 been a building. I recall concrete floors, and there 11 were ventilators in the roof, so it must be this 12 building, and it apparently does have walls, so that's 13 really the best I can do at this point. 14 Q. Do you know if the phenyl-15 A. And I'm sorry, let me correct one more 16 thing. When I was talking about that open-air process 17 with no walls, I believe I was talking more about PCBs 18 than the lead pot process. I don't recall exactly 19 where that was, but that doesn't really change the 20 answer I've just given today, which is my best 21 understanding as I sit here today. 22 Q. Do you recall what kind of structure was in 23 place when, when Swan Chemical Company first started 24 to manufacture biphenyl using the lead pot process in 25 1929? Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045631 34 A. I've not seen any information to--that would give me any specific information whether it changed prior to this 1953 document. Q. Do you know if the floor has always been concrete? A. That's my understanding. Q. Now, do you know if there were ever any buildings at the facility that had, had dirt floors? A. I don't know. Q. Now, I think you testified last time that at one point, there was curbing installed around the structure where the lead pot process occurred? A. I don't recall that. Again, my recollection would be that would have been the PCB process, but that's just my recollection as I sit here. I don't recall that specific piece of information. Q. Do you know if any portion of the, the biphenyl production building was dismantled at any time? A. I don't. Q. You don't--you can't testify as to how that building might have changed over the years? A. I cannot. Q. In your discussions with Jerry Brown, did he have any indication as to how the biphenyl process was Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045632 35 1 housed? 2 A. That wasn't an area we discussed. 3 Q. Do you recall any of the companies that 4 Monsanto sold the biphenyl to other than Monsanto? 5 A. No, I didn't look into specific company 6 names. 7 Q. Let's get into the details of the process, 8 itself. Now, liquid benzene would arrive at the 9 Anniston facility by tank car; is that correct? 10 A. That's my understanding, yes. 11 Q. And then that liquid benzene would be 12 siphoned to storage tanks? 13 A. That's correct. 14 Q. Okay, and then at some point, isopropyl 15 alcohol was added to the liquid benzene? 16 A. At some, for some part of the process. 17 Also, acetone was used during some years. I believe 18 that was the mid 1950's. 19 Q. What was the purpose of the isopropyl 20 alcohol? 21 A. It was called a promoter. It acted in a 22 way, apparently, according to the documents, that 23 people didn't understand, but somehow, it facilitated 24 the conversion of benzene to biphenyl in the reactor, 25 so it was, in some sense, a catalyst. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045633 36 1 Q. How-- 2 A. Go ahead. 3 Q. And was the acetone also a promoter? 4 A. Yes. It was used in--as a substitute for 5 isopropyl alcohol later in the years. 6 Q. Do you know why isopropyl alcohol was 7 substituted with acetone? 8 A. I think it was a cost and safety 9 considerations, but I don't recall specifically. 10 Q. What were the safety considerations with 11 using the alcohol? 12 A. I don't remember. I just seem to recall 13 that was one of the justifications for the change. 14 Q. Now, did you come across any documents to 15 indicate how the lead was brought into the Anniston 16 facility? 17 A. Other than ingots, other than that it was 18 brought in ingots, no, I don't know. 19 Q. Do you know where the lead ingots were 20 stored? 21 A. I don't. 22 Q. You didn't come across any documents to 23 indicate where they were stored? 24 A. No. 25 Q. Jerry Brown didn't have any information? Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045634 37 1 A. I don't believe we discussed that 2 specifically. 3 Q. You think that that may have been something 4 that was stored outside? 5 A. I would have to speculate. I have no idea. 6 Q. And who did Monsanto purchase lead from over 7 the years? 8 A. I'm sorry, there was a company mentioned in 9 the documents. I don't remember which company it was, 10 and I don't know whether that was the sole supplier. 11 All I do is I remember, I do remember one company. 12 Q. Does National Lead Company ring a bell? 13 A. No, but you asked me about that in the 14 previous deposition, and it was not National Lead 15 because when I saw the name, I recalled your question 16 before. It was not National Lead. 17 Q. Was it St. Joseph? 18 A. That does sound familiar, frankly, yes. 19 Q. Okay, can you tell me about the, the amounts 20 of lead that the Anniston facility purchased? 21 A. No. No information on that kind of purchase 22 records or anything like that. 23 Q. Did you search purchase records for lead 24 purchases ? 25 A. Frankly, the purchase records from that time Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045635 38 1 frame don't exist within Monsanto anymore. We've 2 looked at them for other issues around PCBs and they 3 do not, they don't exist. 4 Q. So for the time frame of 1929 through 1964, 5 there are no purchase records reflecting purchases of 6 lead? 7 A. None that I know of, no. 8 Q. Do you know who undertook the effort to make 9 that determination? 10 A. Would have been the attorneys in various 11 litigation. 12 Q. Do you know who the Newport plant purchased 13 lead from? 14 A. No, I do not. 15 Q. So out of these, these storage tanks, the 16 liquid benzene would be drawn through a pipe coil 17 vaporizer; is that right? 18 A. Yes. Pumped through, yes. 19 Q. And that's located in a flue gas exhaust 20 stack? 21 A. I believe that's correct, yes. 22 Q. Okay, and what is the purpose of that part 23 of the process? 24 A. It's primarily just to get benzene into 25 the--from the liquid state into the vapor state. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045636 39 1 Q. And then the benzene is then bubbled through 2 the bottom of, of the molten lead pots? I mean, I'm 3 sorry, the lead spots? 4 A. That's correct. 5 Q. Now, each biphenyl unit consists of three 6 pots; correct? 7 A. That's correct. 8 Q. Now, there's two preheater pots and there's 9 a converter pot? 10 A. You are correct. 11 Q. Are you able to tell me how many of those 12 units the Anniston facility had over the course of, of 13 the lead pot process from 1929 to 1964? 14 A. The maximum--my understanding is that the 15 maximum number of units in use at any--at any time 16 would have been 12. There were actually 13 units, but 17 for whatever reason, the, the number one unit 18 apparently was not used, so really, the number of 19 maximum production was 12 units. I don't know that 20 they were, all 12 were used at all times, but that was 21 the maximum number. 22 Q. Can you describe for me how the--how the 23 molten lead was--how that setup occurred? Now, they 24 obviously take the ingots from some location at the 25 Anniston facility and they, they melt, they melt those Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045637 40 1 ingots. Can you describe for me how that occurred? 2 A. My understanding is that they put them in 3 the, the pots that the process occurred in and turned 4 on the heat and the lead melted in those pots. 5 Q. Okay, so they didn't, they didn't melt them 6 in another location and then ladle them into those 7 lead pots? 8 A. That's correct. It is correct that they did 9 not do that. They were melted in the pots. 10 Q. And over time, additional lead had to be 11 added into those lead spots; is that right? 12 A. That's my understanding, yes. 13 Q. And those were steel pots? 14 A. Yes. 15 Q. Do you know what the life, lifespan of those 16 steel pots were in the early, in the early, the 17 1930's, 194 0 ' s ? 18 A. In the earlier years, I don't know the 19 answer to that. 20 Q. Was it in any of the documents that you 21 looked at? 22 A. Not for the early years. 23 Q. Okay, what--did you recall any discussion of 24 a lifespan of the steel pots? 25 A. Yes. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045638 41 1 Q. Okay, and for what years do you recall that 2 discussion? 3 A. I believe it was in the 1950 time frame. 4 Q. Okay, in the 1950 time frame, what was the, 5 what was the useful life of those steel pots? 6 A. About two years. 7 Q. Okay, do you know what was done with those 8 steel pots when they were no longer useful? 9 A. I believe they were cleaned and sold for 10 salvage, but I, I'm not real specific on that. 11 Q. They were cleaned at the Monsanto facility? 12 A. Yes. 13 Q. They were sold to some salvage company? 14 A. That was my understanding. 15 Q. Do you recall the names of any, any salvage 16 companies ? 17 A. No. In fact, I think some of the pots were 18 repaired, so it wasn't --I mean when a pot, quote, 19 "reached the end of its useful life," I believe in the 20 documents, it does say that some of them could be 21 repaired and they were, but the ones that weren't, I 22 believe, were salvaged. 23 Q. Now, the--this unit of three pots, it sounds 24 like the purpose of, of the first two pots was to ramp 25 up the temperature of the molten--of the molten lead? Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045639 42 1 A. Well-- 2 Q. What was the purpose of those two initial 3 preheaters? 4 A. To ramp up the temperature of the benzene. 5 Q. Okay, ramp up the temperature of the 6 benzene, so by the time it reached the third pot, it 7 was at the correct temperature? 8 A. For conversion, that's correct. 9 Q. Okay, what temperature was that? 10 A. I believe was around 750 to 850--to 800 11 degrees Centigrade. 12 Q. Do you know lead, at what point lead 13 vaporizes ? 14 A. I believe about 1,700 degrees Centigrade. 15 Q. There was also high pressure in these 16 systems; is that right? 17 A. They were somewhat pressurized, yes. 18 Q. So these were, these were covered pots, they 19 were pressurized? 20 A. (Nods head in affirmative manner). 21 Q. Now, I saw several discussions of lead 22 vapors from these pots. Is that, is that--were there 23 lead vapors that came off these pots? 24 A. I don't recall seeing those discussions. 25 I--I mean, I don't know what a lead vapor would look Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045640 43 1 like. I mean, I'm sure there was in some of the pots, 2 there was probably some evaporated lead in the head 3 space in the pots, but as far as lead vapor coming off 4 those pots, I don't recall that. 5 Q. Okay, why would there--now, what--you said 6 the temperature was 800 degrees? 7 A. Yes. 8 Q. And you said that lead becomes a vapor at 9 1,700? 10 A. Well, that's the boiling point. 11 Q. Okay. 12 A. I mean, lead will become a vapor throughout 13 the temperature range. 14 Q. Right. 15 A. I mean, just like water, water will become a 16 vapor throughout the temperature range. It's just 17 when it starts boiling is when it is undergoing that, 18 that phase conversion completely. 19 Q. Okay, so just because you don't get to 1,700 20 doesn't mean that there aren't--that lead vapors can't 21 form. Like you said, it's throughout the entire range 22 of the boiling that lead vapors can form? 23 A. Yes. 24 Q. Now, after leaving the converter pot, the 25 benzene vapor--and there are conversion products that Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045641 44 then pass through a lead trap; is that right? A. That's correct. Q. Now, describe for me--the documents refer to conversion products. Describe for me what those are A. Biphenyl and other higher chlor--or higher polymerized biphenyls. Q. Orthodiphenyl benzene? A. That would be one, yes. Q. Metadiphenyl benzene? A. Yes . Q. Paradiphenyl benzene? A. Yes . Q. Tetraphenyl? A. Terphenyls, I guess, tetraphenyl may, I would know what a tetraphenyl would be. I have not seen that term, but-- Q. Terphenyl tars? A. Presumably there might be some low amounts in there, yes . Q. And carbon? A. Yes, my understanding is carbon was formed. Q. Do you recall any others? A. No, I don't. Q. How about Santowax? Is Santowax, would that be one of the, one of the chemical names I've just Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045642 45 1 described? 2 A. Santowax would include--Santowax is 3 primarily made up of the terphenyls which, in what you 4 just read me, were the, were the dibenzobenzenes or 5 polydiphenyl benzene is the same as terphenyl, so 6 that's primarily Santowax was that, was that cut. 7 Q. Now, Santowax, is that a trade name? 8 A. Yes. 9 Q. Okay, that's like the--like Monsanto had the 10 trade name "Aroclor" to describe the PCBs. 11 A. Yes. 12 Q. It would have the "Santowax" to describe the 13 mixture that you just described? 14 A. Well, yes, the Santowax--Santowax, there 15 were a number of Sanatowaxes. 16 Q. Okay. 17 A. Okay? The first Santowax that came out of 18 the process was the distillation bottoms from 19 distillation of the crude biphenyl to form pure 20 biphenyl. 21 Q. Okay, and we'll get to that. Now, this lead 22 vapor and these conversion products, as they, they 23 pass--obviously, they're passing through a lead trap. 24 That must mean they contain some amount of lead, 25 right? Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045643 46 1 A. That's correct. 2 Q. Did you see anywhere in the documents to 3 discuss what those lead levels were? 4 A. I did not. 5 Q. Did you see any discussion of any kind of 6 testing that Monsanto did to determine what the lead 7 levels were? 8 A. In the lead trap? 9 Q. In the benzene vapor and the conversion 10 products that passed through the lead trap. 11 A. I did see one analysis of a crude biphenyl, 12 which would have been what you were referring to as 13 the conversion mixture. 14 Q. Do you recall what the lead concentration 15 was ? 16 A. The lead concentration was reported as a 17 fraction of, of a, of a percent of the ash that was 18 remaining after the crude materials had been burned in 19 a laboratory to do the metals analysis. 20 Q. And was that in the documents that you 21 looked at in preparing? 22 A. Yes. 23 Q. Do you believe that was in one of the SMPs, 24 the standard manufacturing procedures? 25 A. My recollection of it is that it was not. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045644 47 1 Q. Okay. 2 A. That it was in a, it was in some sort of a 3 process review or something. That's my recollection. 4 Q. Where was the lead captured in the lead 5 trap? Where was that lead disposed of? 6 A. It was put back into the pots. 7 Q. And you--where did you get that information? 8 A. It's in those documents. I don't--I believe 9 it's in either one of the process descriptions or in 10 the SMP. I believe it's in one of the process 11 descriptions and from, from people that, that Jerry 12 Brown talked to, they also -- that was their 13 recollection of what happened to that lead. 14 Q. Now, does the, does the lead trap--did the 15 lead trap capture all of the lead that remained in 16 these--in the, in the--these conversion products, the 17 biphenyl and the other, the other phenyl products that 18 we discussed? 19 A. Well, I mean judging from the fact that 20 trace levels were detected in the crude biphenyl which 21 I, I am assuming was captured after the lead trap, I 22 would say it captured all but some very trace levels. 23 Q. Now, is it safe to say that the--that all of 24 these, all of these conversion products had trace 25 levels of lead in them after, after they went through Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045645 48 the distillation process? A. Well, no. Q. Okay. Did--I mean, you just said that there would be trace levels of lead in the crude, in the crude bottoms, right? A. In the crude biphenyl, the crude conversion product is the one, the one analysis that I did see was for crude biphenyl. Q. Do you know, did Monsanto test these conversion products, including the biphenyl, for lead content? A. Well, that was the only analysis I saw. Q. Okay. A. And you know, the levels were so trace that I would assume that they did not, but I don't know that for sure. Q. Based upon, based upon what you've seen in these documents, is it your belief that these conversion products contained no lead? A. Well, we need to be more specific about what you are talking about as conversion products. Q. Okay. A. I mean, what you originally described as a conversion product was the output of the--which is basically what I'm calling crude biphenyl, prior to Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045646 49 1 any future refining. 2 Q. Okay. 3 A. Obviously, that crude biphenyl did contain 4 trace levels of lead. 5 Q. That's probably a good point. Let's--so 6 these--this crude biphenyl, then, goes to the bottom 7 of a fractionating column, right? 8 A. Yes. 9 Q. And as part of--and that fractionating 10 column causes the different, the different converter 11 products, converted products, to separate out based 12 upon, based upon boiling point? 13 A. That's correct. 14 Q. And do you know how those were--how that 15 material was collected? 16 A. Not specifically. I do know, I do recall 17 seeing that there were four fractions collected: A, 18 a heads, basically, which was the remaining benzene, 19 was collected first, then there was a, I think 20 basically a mix of biphenyl and benzene was collected, 21 then the main biphenyl cut, and finally, the still 22 bottoms, but specifically how they were removed from 23 the column, into what kind of receptacle they were 24 collected, I don't know that, although it may be 25 reflected, my guess is it's reflected in those Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045647 50 1 documents, in the process documents, but I don't have 2 a specific recollection. 3 MR. LANGLAIS: Okay, I'm going to--why don't 4 we take a five-minute break. I'm going to introduce 5 some documents. It will give me a chance to get those 6 together, give you a chance to grab a cup of coffee or 7 whatever. 8 THE WITNESS: Okay. 9 MR. NASSIF: That's fine. 10 MR. LANGLAIS: Okay. 11 (Recess.) 12 (Defendant's Deposition 13 Exhibits Solutia 3 and 4 14 mark'd for 15 identification.) 16 BY MR. LANGLAIS: 17 Q. Dr. Kaley, I'm going to actually hand you 18 two exhibits, one that's been marked Solutia Exhibit 19 3, and it's Bates labeled ADA 000632 through ADA 20 000905. Solutia Exhibit 4 is DSW 462477 through DSW 21 462620. Would you, please, for now, just look at 22 Solutia Exhibit 3? 23 (Witness peruses said 24 document.) 25 Q. (Continuing) And feel free to look through Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045648 51 1 it. I'm going to ask you some--point to you certain 2 locations and ask you some questions. 3 A. Okay. 4 Q. This Exhibit 3 is entitled "Diphenyl and 5 Chlorinated Diphenyl Derivatives, June 1935." Is that 6 correct? 7 A. That's correct. 8 Q. Now, this appears to be, in my search, this 9 was the first SMP for the biphenyl process; is that 10 correct? The lead pot process? 11 A. Okay, I do not believe it's correct to 12 specifically call this an SMP. 13 Q. Okay. 14 A. It's what I would call a description of the 15 process,-16 Q. Okay. 17 A. --but I don't believe it's an SMP. It would 18 be labeled as such. 19 Q. And just so the record is clear, diphenyl 20 and biphenyl are the same, those are just used 21 interchangeably; right? 22 A. That's correct. 23 Q. What's the purpose, in your mind, of this 24 document? You said it's not--you wouldn't describe it 25 as an SMP, or standard manufacturing procedure, just a Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045649 52 1 description. What's the purpose of it? 2 A. My understanding of this document is that it 3 was prepared by the Anniston facility to describe the 4 process preparatory to installation of a biphenyl 5 process at the Sauget plant, what's now called the 6 Sauget plant in Illinois. 7 Q. It looks like--it's difficult to read the 8 name, but on the second page of this, it--there is a, 9 not a signature but a--looks like a signature block. 10 It says, "E. M. Buford." Do you see that? 11 A. I see what you are referring to, yes. 12 Q. Have you ever seen that name before? 13 A. Other than on this document, no. 14 Q. Okay, that name hasn't come up in your 15 review of other documents? 16 A. No. 17 Q. Do you know who prepared this? 18 A. The whole document? 19 Q. Yeah. 20 A. Other than that name, no. 21 Q. Was this produced as part of your, your 22 2000, October 2000 letter to--you said it was to ADEM? 23 A. Yes. 24 Q. Okay, this particular SMP was an exhibit to 25 that? Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045650 53 A. I believe not. Q. Okay, what was this an exhibit to -- A. I believe it was an Exhibit to the 104(e) request. Q. And is 104(e) request was dated October 2004? A. You know, I don't know the answer to that. Q. We'll get to that. Was this attached to Monsanto s Solutia 104(e) response? A. I believe it was, yes. Q. And in that response, this is the earliest document that describes the lead pot process that you are aware of? A. I don't know that for sure, but I'll--assuming you've looked at all those, I'll take your word for it. I don't know that for sure. Q. Is it the first? It's dated 1935. A. It's--I cannot point to you an earlier document Q. Okay, that's my point. If you would turn to ADA 000639 for me -- A. I'm there. Q. Okay, the second full paragraph, it discusses carbon form. It says, "Carbon form tends to float on the lead surface or be carried out to a Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045651 54 1 conveniently located trap rather than to plug the 2 apparatus." Are they referring, based upon your 3 review of these documents, are they referring to the 4 carbon trap that's located at the bottom of the 5 fractionating column? 6 A. I believe that's correct. I would have to 7 look at the description to be sure, but--the diagram, 8 but I believe that is correct, yes. 9 Q. Am I correct that throughout this process, 10 there was what's called carbon formation occurring in 11 the various pipes and in different locations 12 throughout this--the equipment in this process? 13 A. My understanding was that it was the carbon 14 was formed in the, in the conversion process, itself, 15 but that it, in fact, did deposit in some of those 16 various pipes throughout the process. 17 Q. All right, and am I correct that it 18 deposited, this carbon deposited itself between the 19 converter and the lead trap? The piping between those 20 two? 21 A. I believe some of it did, yes. 22 Q. And that carbon contained lead; is that 23 correct? 24 A. I believe it is, yes. 25 Q. And then, of course, there are --am I correct Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045652 55 1 that carbon would also form in the lead trap, itself? 2 A. It would be collected in there some. I 3 don't think it would form-- 4 Q. It would adhere. 5 A. --in there. 6 Q. Right. I guess I'm using the wrong--the 7 carbon would adhere within the lead trap, itself? 8 A. I believe some did, yes. 9 Q. And that carbon would contain lead? 10 A. Some amount, yes. 11 Q. And then from the lead trap, it would--there 12 would be piping from the lead trap to the distillation 13 column or the fractionating column; is that correct? 14 A. Yes. 15 Q. And carbon would adhere on the piping 16 between the lead trap and the fractionating column, as 17 well; correct? 18 A. I believe that's correct. 19 Q. And isn't it true that that carbon also 20 contained lead? 21 A. I don't know. If it did, it would be very 22 small amounts. I don't know. 23 Q. It's not your testimony that the lead trap 24 captured all of the, all of the lead, is it? 25 A. I would think it could capture a significant Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045653 56 1 amount. I don't know that it captured every molecule, 2 but--or every atom. 3 Q. Would the carbon also adhere within the 4 fractionating column, itself? 5 A. I don't recall seeing that. I don't know. 6 Q. At the bottom of the fractionating column 7 was, was the carbon trap. 8 A. Yes. 9 Q. Between the column and the, and the--well, 10 strike that. Why would there be a carbon trap at the 11 bottom of the column, fractionating column? 12 A. Well, because presumably, the carbon was a 13 solid, and the fractionating column was basically 14 operating under a gaseous phase, so solids are going 15 to go to the bottom. 16 Q. Okay, so that would--so do you still think 17 that there was no carbon formed in the fractionating 18 column? 19 A. I don't think it was formed in there. I 20 think there may have been some entrained carbon that 21 was being removed during the distillation process. 22 Q. Do you know if that carbon contained lead? 23 A. I've never seen results one way or the other 24 on that. I would think if it did, it was very, very 25 small amounts. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045654 57 1 Q. What do you consider small amounts? 2 A. I don't know. 3 Q. You don't--you can't quantify-- 4 A. I'm just going based on, you know, like I 5 said, the one analysis I've seen that would suggest 6 that the lead levels in the crude biphenyl were very 7 low, so that the levels any place after that 8 pro--after that lead trap, the levels would be very, 9 very low. 10 Q. What were the lead levels in the crude 11 biphenyl? 12 A. I think it's, you know, like tens of parts 13 per million. 14 Q. Okay, and that--now, what if you 15 produce--how much crude biphenyl did the facility 16 produce per year? 17 A. I don't know. I mean, I--the numbers are, 18 you know, twenty million pounds a month, so I don't 19 know. I mean, I haven't done the calculation. 20 Presumably it could be, you know, guesstimated. 21 Q. Would you agree with me that even a small 22 amount of lead, if you are producing a lot of the 23 material, then you could get some significant amount 24 of lead out of that material if you are producing, you 25 said how much? Twenty, twenty million? Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045655 58 1 A. I believe that's the numbers, 20 million 2 pounds a month. 3 Q. Per month, and they produced this from 1929 4 till 1964? 5 A. Well, till 1961, but I don't know that that 6 amount was produced every year. I'm saying I know it 7 was not. The levels in the early years were much 8 lower. Those were pretty much levels, as I recall, 9 during the Sixties. 10 Q. So you would have produced more as time went 11 on? 12 A. Yes, around the 20 million, we produced less 13 in earlier times. 14 Q. But even--would you agree with me that even 15 a small amount, even in small parts per million in the 16 crude biphenyl, if you are producing a lot of it, if 17 you do a simple calculation and take the total amount 18 of biphenyl produced and you multiply it by the lead 19 concentration, you can come up with a pretty 20 significant amount of lead? Would you agree? 21 A. You will get a number. I mean, what's -- 22 Q. You might not consider it significant, but -- 23 A. Your number and my definition of 24 "signif icant " -- 25 Q. Sure. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045656 59 1 A. --may not agree. You will get a number,-- 2 Q. But that's how-3 A. --certainly. 4 Q. That's how--I mean, you are a chemist. 5 That's how you would calculate how much, how much 6 total lead was in all the production of crude 7 biphenyl. 8 A. That's how I would make a crude estimate, 9 yes . 10 Q. Mm-hmm, because you know the concentration, 11 know the amount produced, and-12 A. Sure. 13 Q. Basic algebra, right? 14 A. It's probably not even that; it's probably 15 arithmetic. 16 Q. Sure. 17 (Laughter.) 18 Q. (Continuing) And in 1935, how much of these 19 biphenyl units did the Anniston facility have? 20 A. I don't, I don't recall that specifically. 21 Q. How--what was the integrity of the steel pot 22 to the lead pots, the steel pots that contain the 23 molten lead, what was the integrity of those pots, 24 based upon your review of this 1935 document? 25 A. Can you point to me to the same thing you Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045657 60 1 are looking at? I mean, an integrity is basically 2 the--all I can tell you is what my understanding of 3 the integrity of the pots is is how well they were 4 holding up. 5 Q. Right, and that's, that's what I'm saying. 6 Did they leak? 7 A. Occasionally. 8 Q. Did the joints leak? 9 A. Occasionally. 10 Q. Now, what leaked out of there? 11 A. Presumably whatever is in there. Benzene, 12 probably some small amounts of lead. 13 Q. Lead vapors? 14 A. Um, presumably, some small amounts, sure. 15 Q. Some liquid lead? 16 A. Sometimes. 17 Q. And you said small amounts would leak out. 18 I mean, that's just your--is that an educated guess, 19 or did you see anything to indicate how much lead 20 vapor would come out of these leaking pots? 21 A. Well, I've never seen any numbers, but 22 clearly, in the documents, it talks about the fact 23 that if there were leaks, the benzene would catch fire 24 and it would have to be put out almost immediately 25 because it was a fire danger and the leaks would be Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045658 61 1 fixed, so, you know, there would be very small amounts 2 of benzene because they stopped that and the lead 3 would be less than the benzene, so that's the basis of 4 my characterization of small amounts of lead. I have 5 not seen numerical analyses of how much lead may have 6 been released during any particular leak. 7 Q. Now, there would be times when, when 8 the--when these lead pots would have to be opened. Is 9 that right? 10 A. That's correct. 11 Q. And during that time, would you expect there 12 to be some lead vapor loss? 13 A. There, there would probably be some, sure. 14 Q. And you haven't seen anything that 15 quantifies that? 16 A. No, I have not. 17 Q. And based upon your review of the documents, 18 does it seem that Monsanto--that was even something 19 that Monsanto looked at? Was Monsanto--did they make 20 any effort to determine lead vapor losses during 21 instances where you would open up these lead vats? 22 A. Not that I'm aware of, no. 23 Q. Now, there were also times when, when the 24 pots had to be cleaned; right? 25 A. That's my understanding, yes. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045659 62 1 Q. And there were times when they would have to 2 go in and they would have to clean out this carbon 3 that adhered to the piping and the trap--in the traps; 4 is that right? 5 A. That's my understanding, yes. 6 Q. And do you know what they would do with that 7 carbon material? 8 A. My understanding is that it went to the 9 landfill. 10 Q. And we had discussed earlier that the carbon 11 material likely contained amounts of, certain amounts 12 of lead? 13 A. Some amount, depending on where the carbon 14 came from in the process, but it certainly would have 15 contained possibly some amount. 16 Q. Sure, and if it came--if there was carbon 17 that adhered between the converter pot and the lead 18 trap, you would expect to find higher amounts of lead 19 in that carbon versus the carbon that had adhered in 20 the piping from the lead trap to the fractionating 21 column, right? 22 A. I believe that's correct. 23 Q. Because that was the whole purpose of the 24 lead trap, itself. 25 A. That is, I believe, a correct conclusion. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045660 63 1 Q. So as you go further through the process, 2 would you agree with me that it was likely that, that 3 the, that the level of lead in each of the adhered 4 carbon would decrease throughout the process? 5 A. Well, until at some point in the process 6 where it got so low, you couldn't machine it at all. 7 Q. But that ultimately, some of it would end up 8 in the crude biphenyl? 9 A. Well, in the crude biphenyl yes, I believe 10 that is true. 11 Q. And that crude biphenyl is, when we refer to 12 crude biphenyl, we're talking about the material prior 13 to putting it up on the distillation column? 14 A. That's correct. 15 Q. Once those, once those, the different, the 16 different products came off that distillation column 17 and they were put in the various containers--and we'll 18 get into that in a moment--did Monsanto look at 19 whether there was any lead contained in those 20 distillation products? 21 A. I've not seen measurements of that, no. 22 Q. So there were no measurements--did 23 Monsanto--I'm going to jump ahead a little bit. 24 Did--and then those distillation products, you would 25 have biphenyl in one of those distillation products, Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045661 64 1 right? 2 A. Yes. 3 Q. And that biphenyl would be chlorinated to 4 create polychlorinated biphenyls. 5 A. Some of it, yes. 6 Q. Right. The material that wasn't sold to 7 Monsanto or these other companies that we discussed 8 would, would be used at that facility to make PCBs? 9 A. Yes. 10 Q. Did Monsanto, did you see any documents that 11 indicated whether Monsanto did any testing of the PCB 12 products to determine lead levels? 13 A. I've not seen anything. 14 Q. So you can't testify today that there were 15 no lead in the PCB products, right? 16 A. I can't testify that there was not a single 17 molecule. If there were lead in there, it was in 18 very, very low amounts based upon the amounts in the 19 crude biphenyl and knowing that the purification 20 stages that biphenyl went to before it ever became 21 PCBs, so -- 22 Q. And you and I probably have different 23 meanings on what's significant and what's 24 insignificant, but, but certainly, you can't say there 25 wasn't lead in those PCB products because Monsanto Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045662 65 1 didn't test. 2 A. I can say that based on the chemistry 3 and--of lead, and PCBs, and biphenyl, and distillation 4 processes, all that, if it was there, it was probably 5 at nondetectable levels. 6 Q. Would lead have affected the performance of 7 the PCBs, or do you know? 8 A. I don't know specifically. 9 Q. What is, what is a product called Santocel? 10 A. Santocel? 11 Q. Yes. 12 A. I don't know. I mean, I've seen the name. 13 It was, it was a product manufactured in one of our 14 New Jersey plants. I don't know specifically what its 15 use was. 16 Q. It was never manufactured at Anniston? 17 A. No. 18 Q. Now, Anniston, there was some testing of 19 soils at Anniston; is that right? 20 A. Correct. 21 Q. And I recall that there was a discussion 22 there was some levels where it exceeded a hundred ppm, 23 and I think in one of the documents, it said it went 24 as high as 200, 250 ppm. Do you recall that? 25 A. Yes, I do. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045663 66 Q. And how long has the--was there a facility at this location prior to Monsanto? A. A facility? Q. Well, I guess before Swan, what was at this location? A. Well, there were other, there was a facility also owned by Swan that had different names. Q. Okay, and do you know how long that facility--that there was a company operating where the Solutia plant currently is now? A. My recollection is it was, like, 1917 or something like that Q. Where do you believe--well, strike that. Can you tell me what--if I tell you--if I ask you what background lead levels are, do you know what I'm talking about? A. Yes . Q. Okay, what is the typical background lead level in Anniston? A. I don't know Anniston specifically. In the country, you see numbers, I think one document that we found says the levels range from a few parts per million to 700 parts per million. Q. You think that 700 parts per million is background? Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045664 67 1 A. I believe that document documents that, yes. 2 It's a U.S. Geological Survey document that talks 3 about 700 parts per million as being within the 4 background range. 5 Q. Why did--what's the cleanup level for lead 6 in Anniston? 7 A. The action level for the time-critical 8 removal is 400 parts per million. 9 Q. Where do you think the 250 ppm that was--of 10 lead that was detected at the Anniston Plant came 11 from? Do you think that's background? 12 A. Could very well be, yes. I believe it is. 13 Q. Could it be from the lead pot process? 14 A. If it were --you know, I don't know. If it's 15 within background, you really can't talk about where 16 it came from because you don't have a reference point. 17 Q. We're going to go back to this document 18 later. Before I move on, I want to, I want to show 19 you one thing. Turn to ADA 000699. 20 (Witness peruses said 21 document.) 22 A. Okay, I'm there. 23 Q. Okay. If you look in that, it's the first 24 paragraph, it's not a full paragraph? 25 A. Okay. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045665 68 1 Q. But let me see: One, two --second full 2 sentence down, "When the potentiometer indicates that 3 the boiling point of diphenyl has been reached, the 4 delivery pipe is swung to another pan." Do you see 5 that sentence right there? 6 A. I do. 7 Q. Why don't you go ahead and read, read that 8 entire sentence and let me know when you are finished. 9 (Witness peruses said 10 document.) 11 A. Okay, now, I believe what they are referring 12 to, here, is this is part of the distillation process, 13 and what they're saying--and you may have to go back a 14 little--what they are saying is that as each, as each 15 distillate comes off the fractionating column, the 16 product is--a delivery pipe puts that material into a 17 pan, and as the next distillate product comes off the 18 fractionating column, they swing that pipe over and 19 put it in another pan, and they keep moving it until 20 they remove the different distillate fractions. 21 A. Urn-- 22 Q. Is that what that appears to be? 23 A. Yes, but I think after the one described 24 here, there is probably not another pan after that, 25 because then what's left after the diphenyl is the Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045666 69 1 still bottoms, so you wouldn't--I mean, they would be 2 left in the still. 3 Q. Sure. 4 A. So what's described here is the last--is the 5 actual collection of the purified diphenyl, so they're 6 collecting prefractions and then they swing it to 7 another pan to collect the diphenyl, and then--you 8 know, your question I heard is presuming there would 9 be other swingings to other pans. I don't believe 10 that was the case. 11 Q. Right, but I guess my only point is it was 12 more than just the biphenyl fraction that they were, 13 that they were collecting. What they were doing, they 14 were taking the different fractions off and putting it 15 in pans in order to get to that, that biphenyl that 16 they were looking for. Is that right? 17 A. Yes. 18 Q. Jump ahead to page ADA 000703. I'm going to 19 go ahead and mark this as--this picture as a separate 20 exhibit. I'm going to mark this as Exhibit 5. 21 (Defendant's Deposition 22 Exhibit Solutia 5 mark'd 23 for identification.) 24 BY MR. LANGLAIS: 25 Q. And this appears to be--it's a very crude Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045667 70 1 picture, but you can see, you can see that there are 2 four, there are four of these pans that were described 3 in that paragraph, and in the second pan, it looks 4 like there's material coming out of that swing pipe 5 that they refer to? 6 A. Yes. 7 Q. Now, it looks to me like that's--they just 8 simply--it's kind of like filling champagne glasses; 9 they're simply, as the--as they reach the next 10 distillate, they simply swing the arm over into the 11 next pan. Is that what appears to you? 12 A. It does. 13 Q. Now, these pans, these pans, you can see 14 there are gaps, there are gaps between these pans, 15 right? 16 A. Yes. 17 Q. And so I don't--I didn't see any reference 18 in there to them stopping the, the distillation 19 process in order to make sure that no material got 20 down between these pans. I mean, this doesn't look 21 like a very clean process to me. 22 MR. NASSIF: I'll object to the form of the 23 question. 24 MR. LANGLAIS: That's fine. 25 BY MR. LANGLAIS: Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045668 71 1 Q. (Continuing) I mean, would you, would you 2 agree that there's gaps between these, between these 3 pans? 4 A. There appear to be. 5 Q. And did you see any reference in there that 6 they actually stopped, they actually stopped the 7 removal of the distillates as they transferred the arm 8 from one to another? 9 A. No. 10 Q. So it appears appeared what they did is they 11 simply, they simply moved it along and as they got to 12 the next distillate level, they swung it over to the 13 next pan? 14 A. That-- 15 MR. NASSIF: Objection. That calls for 16 speculation. 17 MR. LANGLAIS: Well, I don't want him to 18 speculate. It says, "When the boiling point of the 19 diphenyl has been reached, the delivery pipe is swung 20 to another pan." 21 MR. NASSIF: Okay. 22 MR. LANGLAIS: I would expect that if they 23 had shut off the process or turned a nozzle off to 24 make sure none of the product, none of the distillate 25 comes out, they would have mentioned that in the Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045669 72 1 instructions. 2 MR. NASSIF: Calls for speculation: Same 3 obj ection. 4 BY MR. LANGLAIS: 5 Q. (Continuing) But they don't mention that in 6 the instructions, do they? 7 A. There's no mention of that, no. 8 Q. Okay, so would you agree with me that it's 9 conceivable that if they are swinging this arm with 10 product coming--with these distillate fractions coming 11 out of it, it was likely some of that material dropped 12 between these pans? 13 MR. NASSIF: Same objection: Calls for 14 speculation. 15 A. It's conceivable. 16 BY MR. LANGLAIS: 17 Q. If you would look at what's been marked 18 Exhibit 4, which I believe is right here, this 19 document, which is Exhibit 4, has been--this document 20 is entitled "Revision of Phosphate Division 21 Engineering Department Report Number 117 on 12-unit 22 biphenyl plant at Anniston, Alabama," and it's dated 23 December 23rd, 1948. 24 A. Yes. 25 Q. Now, is this--would you consider this one of Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045670 73 1 these instructive-type reports, as opposed to an SMP? 2 A. Um, yes. 3 Q. Was this a document that you reviewed 4 previously? 5 A. I don't believe so. 6 Q. You don't believe that this was--do you want 7 to look at the response that you sent to ADEM in 2004 8 and see if this was one of the, one of the documents 9 that was provided to them? 10 A. I'm sure it was not one of the attachments. 11 Q. Okay. Would you agree that this document 12 discusses the, the biphenyl process, although it uses 13 the term "diphenyl," we've already established that 14 those words are interchangeable? 15 A. Yes. 16 Q. And at least at this time, at least in 1948, 17 there were 12 biphenyl units? 18 A. That's correct. 19 Q. And there would be, there would be a total 20 of 36 of these lead pots, because we discussed earlier 21 that there were three, three pots per unit; is that 22 correct? 23 A. Yes. Let me --could I clarify that last 24 answer? 25 Q. Sure. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045671 74 1 A. Because--and it does mention this in here. 2 and I just didn't know what the timing was. On page 3 462481, they talk about the fact that two of the units 4 differed from the rest in that they had, instead of 5 one of the preheater pots, they had a heat exchanger. 6 Q. Okay. 7 A. So at least two of the units only had two 8 lead pots; maybe not a big issue, but I did want to 9 clarify that. 10 Q. No, I appreciate that. So there were 34 of 11 these lead pots, and the heat exchangers were--did the 12 same thing as the--really, it's just preheating the 13 benzene; correct? 14 A. That's correct. 15 Q. If you'd look for me on, on page 462481, I 16 believe the page you are on, at the top, it discusses 17 carbon formation fouling the tubes. 18 A. Yes. 19 Q. Okay. Now, I want to go down to-20 A. I mean--and again, that's with reference to 21 the use of the heat exchanger specifically. 22 Q. Right. 23 A. So apparently, apparently, it didn't foul 24 the tubes in the non-heat-exchanger units-25 Q. Okay. Well-- Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045672 75 1 A. --because it says the use of the heat 2 exchanger --I mean, the sentence says, "The heat 3 exchanger effected gas savings but it proved 4 impractical due to carbon formation fouling the tubes 5 and the idea was abandoned on subsequent units," so 6 that's why they went back to the lead pots because the 7 heat exchangers were causing carbon buildup. 8 Q. Right, but there's also carbon buildup in 9 the three-unit biphenyl, biphenyl unit, right? The 10 three, the three-tank or the three-lead-pot biphenyl 11 unit? There's carbon formation after--once you leave 12 the converter; correct? 13 A. There is carbon formation in the conversion 14 process. One of the byproducts of this conversion of 15 benzene to biphenyl is carbon. It's an unwanted 16 byproduct and it did occur, but I would say that it 17 didn't occur in these units as much as it did with 18 the --in the three-pot units as much as did with the 19 two because they didn't have the problem of fouling 20 the tubes and went back to the three, but I'm not 21 arguing the fact that there was carbon formation in 22 the process. 23 Q. Right. There would be--would you agree with 24 me that there's, there's piping between each of the 25 pots, correct? That's how, that's how the transfer is Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045673 76 1 made. 2 A. That's correct. 3 Q. There was carbon formation--let's, let's not 4 discuss those units with a heat exchanger. Let's 5 focus on the, the majority of the units that had the 6 three pots. Between, between the two preheater pots, 7 there was piping. 8 A. Yes. 9 Q. Correct? 10 A. Yes. 11 Q. And there would be carbon that would adhere 12 in that piping. 13 A. To some extent or another, yes. 14 Q. And that carbon would contain lead? 15 A. To some extent or another, yes. 16 Q. And then between the second preheater and 17 the converter, there would be piping, and again, there 18 would be carbon formation that would contain lead in 19 the piping between those two units; is that right? 20 A. Same answer. Some formation--some 21 collection of carbon which contained some level of 22 lead. 23 Q. Because it says, if you look down at the 24 third paragraph, it says in the second sentence, "A 25 considerable amount of carbon adheres to the pipes Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045674 77 1 between the converter and the lead trap and the lead 2 trap and the fractionating column, necessitating 3 removal and cleaning of the pipes every one to six 4 months." 5 A. That is what that says, yes. 6 Q. Did you see--now, that seems pretty broad, 7 to me, that there's such a wide range of when these 8 pipes were cleaned. Would you expect that carbon 9 formation to be any different throughout the course of 10 the biphenyl process, throughout its history? I mean, 11 was there anything done differently that would 12 decrease carbon formation? 13 A. Other than using lead pots instead of heat 14 exchangers, I didn't see anything specific, no. 15 Q. Right, but, but there was--there was a 16 problem, here, with, with carbon adhering in the, the 17 non-heat-exchanger units. 18 A. Well, I don't know that it was a problem. 19 It was an integral part of the process that carbon was 20 formed and did collect in certain parts of the 21 process, yes. 22 Q. And we discussed that that material was, 23 that material was tossed into the landfill. 24 A. That's my understanding, it was collected 25 and put in the landfill. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045675 78 1 Q. Just for a point of reference, could you 2 look back at this first exhibit and identify where the 3 landfills were in relation to the lead pot--the 4 biphenyl production area where the lead pot process 5 occurred? 6 A. Well, the west, what is now called the west 7 landfill was used up till about 1960, so for 8 essentially the whole life of the lead pot process, 9 the west landfill was used. 10 Q. Okay, and where, where is that? Can you put 11 "WL" where that is on this Exhibit 1? 12 A. Um, I mean I know generally where it is. 13 It's generally up in this blank area here 14 (Indicating). 15 Q. Okay. At some point, did Highway 2002, was 16 it constructed through that landfill? 17 A. No. Highway 202 was constructed through 18 what's called the south landfill or the Cold Water 19 Mountain landfill. It was not constructed through the 20 west landfill. 21 Q. Can you tell me where the, where the--let's 22 call it the south landfill--where that was located in 23 relation to the lead pot process? 24 A. It's across Highway 2002, basically where 25 WMA-1 is located on this map and then extending Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045676 79 further east. Q. I'll just go ahead and circle that and put an arrow. A. Fine. Q. Now, that, this south landfill, what was the operation history of this south landfill? A. My understanding is it began to be used as a landfill in about 1960, when the west landfill was, was closed, and continued to be a landfill until about the late 1980's, when it was RCRA closed, R-C-R-A closed. Q. So the south landfill was still in existence when the lead pot process was, was occurring. Is that right? A. Just, just barely. Q. Right. Well-A. I mean, maybe for a year. Q. And then, and then--but it was still, from '61 to '64, you said although it decreased, the lead pot process was still occurring? A. But very minimally. I mean, there is a document which talks about shutting down the lead pots in 1962, so, you know, I don't know, I don't have any information that they were ever used after 1962. I don't think they were dismantled till 1964. They may Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045677 80 or may not have been; I don't know, but my assumption is that they specifically shut them down in '62, they were used for, you know, '61 and '62, that would have been the only two years during the operation of the south landfill. Q. When did the tubular--what do you call the, the process that came after the lead pot process? A. "Tubular" is fine. Q. The tubular, when did the tubular process come on-line? A. The first unit was put in in 1961. Q. Okay, and although there was, there was still some production through the lead pot process, it was less because you had these new, this new tubular process coming on-line? A. That's correct. Q. With what part of the--now, montars are formed as part of the production of biphenyl; is that correct? A. Some montars are. Q. Okay, and where, at what point--were the montars formed during the fractionating portion, when you are fractionating out the distillates? A. Yes . Q. And those are the heavier, the heavier ends? Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045678 81 1 A. Well, they're what's called the still 2 bottoms. They're, they're really not--I mean, "ends" 3 suggests that they were still part of the collective 4 fraction. They weren't. They were the still bottoms. 5 Q. Okay, those still bottoms were sold, were 6 they not? 7 A. Some amounts were. 8 Q. And do you know what percentage of the 9 montars that were produced were sold? 10 A. I don't know specifically. 11 Q. Does 10 percent sound, sound correct? 12 A. I wouldn't--I would be speculating to even 13 give you a number or agree with a number you gave me. 14 Q. The montars that weren't sold were 15 landfilled; correct? 16 A. Some of them were landfilled--well, and some 17 of them were actually later used to convert to another 18 product. 19 Q. Okay, and what, what were the montars used 20 in that instance, to convert to another product? 21 A. They were used to make a product called 22 what's now called HB-40. 23 Q. And what is HB-40? 24 A. It's a hydrogenated polyphenyl product. 25 Q. And what is that used for? Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045679 82 1 A. Heat transfer system primarily, somewhat, 2 somewhat used as plasticizer. 3 Q. And those contained PCBs? 4 A. No. 5 Q. No? What is, what is--have you seen any 6 documents that show, like, MSDS sheets for HB-40 and 7 what the different constituents are? 8 A. I haven't seen them. I'm sure they do. 9 Q. Is that a product that's still produced? 10 A. Yes. 11 Q. And have you seen more recent--by that, I 12 mean in the 1990's, 2000--more recent MSDS sheets for 13 HB-40? 14 A. No. 15 Q. Presumably, they exist. 16 A. Yes. They surely exist. 17 Q. Do you know if Monsanto, at any point during 18 the production of this HB-40, tested, tested this 19 material for lead content? 20 A. Not that I'm aware of. 21 Q. Now, there was some, some material, some of 22 these products and benzene vapors condensed in the 23 fractionating column; is that right? It doesn't 24 actually, it doesn't actually come off as a distillate 25 fraction? Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045680 83 A. I, I don't know what you are referring to. no. MR. LANGLAIS: Can we take a five-minute break? MR. NASSIF: Fine. (Recess.) (Mr. Richard P. Jacobs attends the deposition.) (Defendant's Deposition Exhibits Solutia 6 and 7 mark'd for identification.) BY MR. LANGLAIS Q. Okay, if you would, let's go back to Solutia Exhibit 3 for a moment, the 1935 diphenyl instruction or report. Can you look at page ADA 000643 for a moment? 643. A. Oh. Q. Go ahead, and why don't you read the first paragraph to yourself, because that's the one I want to talk to. (Witness peruses said document.) A. Okay. Q. Okay. Now, I guess the first thing, it Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045681 84 1 references technical diphenyl. Now, that's the 2 distilled diphenyl or biphenyl phenyl product, as 3 opposed to the crude biphenyl you were referring to. 4 Is that right? 5 A. No, technical is usually the nondistilled. 6 Q. Okay, technical is the nondistilled. 7 A. Correct. 8 Q. Okay, so it looks like this is referring to 9 a biphenyl unit producing 8,000 pounds of technical 10 diphenyl per day, so that's basically 8,000 pounds of 11 the crude biphenyl? 12 A. That's my reading, yes. 13 Q. And is there a way, do you know a percentage 14 of how much of that, that crude biphenyl, how much 15 distilled biphenyl is produced from that crude 16 biphenyl? 17 MR. JACOBS: Objection. It's vague. Can 18 you--do you understand his question? 19 THE WITNESS: I think so. 20 BY MR. LANGLAIS: 21 Q. I can rephrase it. The technical diphenyl 22 or the crude diphenyl, that later goes on to be, to be 23 distilled? 24 A. That's correct. 25 Q. To create, to create that, the finished Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045682 85 1 product, the finished biphenyl product; right? 2 A. Yes. 3 Q. Now, if--do you know what percentage of the 4 crude biphenyl becomes the finished product biphenyl, 5 the distilled biphenyl? 6 A. Well, the next sentence says 78 percent. 7 Q. Okay, so we could, we could take these 8 numbers and 78 percent of 8,000, whatever that, 9 whatever that happens to come out to, will give me the 10 amount of distilled diphenyl produced per day per 11 unit. 12 A. Give or take some losses in the distillation 13 unit or something, yes, but approximately correct, 14 yes . 15 (Mr. Nassif leaves the deposition.) 16 Q. And now, am I correct that the--assuming 17 there were no shutdowns, this is a 24-hour-a-day 18 operation, this biphenyl operation? 19 A. That's my understanding, yes. 20 Q. In the lead pot process? 21 MR. JACOBS: Objection. Are you referring 22 to a specific year or all years of operation? 23 BY MR. LANGLAIS: 24 Q. Well, was it, was it a 24-hour-a-day--did 25 you find anything to indicate that it wasn't 24 hours Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045683 86 1 a day that this process occurred during the entire 2 course of the lead pot process? 3 A. No. 4 Q. And presumably, if there is no shutdowns, it 5 would be every day of the year, including Sundays, 6 that, that this lead pot process would be taking 7 place, right? 8 MR. JACOBS: Objection, vague. You said 9 "presumably." Are you asking him to assume something? 10 MR. LANGLAIS: What I'm asking him to do 11 is--yeah, I'm asking him to assuming there are no 12 shutdowns -- 13 BY MR. LANGLAIS: 14 Q. (Continuing) I mean, was this Monsanto 15 plant operating seven days a week? Were there workers 16 there on Sunday? 17 A. That's my understanding, yes. 18 Q. And the biphenyl would have been operated on 19 the weekends in addition to the weekdays. 20 A. That's my understanding, yes. 21 MR. LANGLAIS: That's all I was getting at. 22 I just want to make, I want to make clear on the 23 record that this wasn't a nine-to-five production 24 process five days a week. 25 MR. JACOBS: And the source of my objection Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045684 87 1 was once you get into "presumably," then I'm concerned 2 you are asking him an expert type of opinion question. 3 BY MR. LANGLAIS: 4 Q. So to calculate best case, best case 5 scenario would be that there would be 8,000 pounds of 6 this distilled, this--I mean, this crude biphenyl per 7 unit, and there were 12 units, so it would be 8,000 8 times 12, that would give me the number per day of 9 crude biphenyl; correct? 10 MR. JACOBS: Objection. "Best guess" is 11 vague and ambiguous. 12 BY MR. LANGLAIS: 13 Q. (Continuing) I think the document, I think 14 the document says enough. I can calculate, I can 15 calculate a rough estimate of how much crude biphenyl 16 was produced per day, based upon these numbers. Would 17 you agree with that? 18 A. You could do that. I'm not sure that would 19 be the best estimate. 20 BY MR. LANGLAIS: 21 Q. Do you know of a better way for me to 22 calculate, based upon the documents you've reviewed, 23 how much crude biphenyl was produced per day, per 24 unit, at the--at this facility? 25 A. Yes, there are documents in that set, there, Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045685 88 1 that talk about how much was produced on a yearly 2 basis, so I would, I would use those numbers because 3 those are actual production numbers. 4 Q. Okay, but I guess what I'm talking about is 5 capacity. You understand the difference between 6 actual production and capacity? 7 A. Yes. 8 Q. And so I can--the capacity of this, these 9 biphenyl units is 8,000 per, per biphenyl unit--and 10 there's 12--per day, and we've already, we've already 11 said this biphenyl process has the capacity to operate 12 24 hours a day, seven days a week; correct? 13 A. Yes. 14 MS. LAVEY: Jim, this is Wendy Lavey. I'm 15 only--I guess I'm interjecting because I'm concerned 16 whether, when you read that typewritten number and you 17 are calling it 8,000 pounds, I'm wondering whether 18 your copy is different than my copy and whether you 19 can really read that as an "8" and not, say, maybe a 20 "3 . " 21 BY MR. LANGLAIS: 22 Q. Would you look, would you look at that and 23 tell me what it looks like to you? 24 A. Well, I think she has a good point. 25 MS. LAVEY: It's perhaps -- Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045686 89 1 A. (Continuing) I'll tell you why, because I 2 think the "78" in the fourth line is a much clearer 3 "8" and it looks different. 4 BY MR. LANGLAIS: 5 Q. Okay. 6 A. And I think it--you know, I appreciate that 7 because I--it looks more like a "3" or a "5" to me. 8 Q. Okay. I'm not trying to mislead anybody. 9 A. I know. 10 Q. You've got better eyes than I do. 11 MS. LAVEY: Jim, maybe if I could direct you 12 ultimately to ADA 000700? 13 MR. LANGLAIS: Yeah, I'm going there next. 14 MS. LAVEY: And the 90,000-per-month number, 15 that gets you to what the digit is supposed to be. 16 MR. LANGLAIS: Yeah. 17 BY MR. LANGLAIS: 18 Q. If you would look at the, the very last part 19 of that page 700? 20 A. Yes. 21 Q. It's --on the very last sentence, it's got a 22 heading "Capacity," and the diphenyl unit has a 23 capacity of 90,000 pounds technical diphenyl per 24 month. 25 MR. JACOBS: I'm sorry, just to be clear, Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045687 90 1 ADA 700? 2 MR. LANGLAIS: ADA 000700. Very last 3 paragraph. 4 MR. JACOBS: Okay. 5 A. Yes, I see it. 6 BY MR. LANGLAIS: 7 Q. Okay, so that right there has given me the 8 amount of one of the 12 biphenyl units, it will 9 produce 90,000 pounds of the crude biphenyl each 10 month? 11 A. No, I would say that by "diphenyl unit," I 12 think that's the whole operation. My understanding 13 would be that 90,000 pounds a month is for all units 14 operating. 15 Q. You think that means all 12? 16 A. Yeah, I think by the "diphenyl unit," 17 they're talking about the whole department. Without 18 going back and checking a bunch of stuff, that would 19 be my reading. 20 MR. JACOBS: Also, objection to the extent 21 it's not clear that that's a "9," but it's hard to 22 tell exactly what that number is, 90,000 or some other 23 number. 24 BY MR. LANGLAIS: 25 Q. My read of these documents, a unit is--now, Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045688 91 1 it described that there were 12, there were 12 units 2 and a unit consisted of the three tanks, so it is what 3 it is. I'm telling you that my take on it is that a 4 unit is--there are 12 units which consist of, in most 5 cases, three tanks, with the exception of numbers 4 6 and 5, which consist of the heat exchanger, but I 7 think the documents are clear on that, and if you 8 disagree with me, that's fine. We can move on. 9 MR. JACOBS: Are you asking him a question 10 or just-11 BY MR. LANGLAIS: 12 Q. Yeah, do you still think, when it says, 13 "Diphenyl unit," it's referring to all of the 12? 14 A. What was that page reference, the previous 15 one? Do you know what the previous one was where we 16 got into the discussion about whether it's 3,000 or 17 8,000? I'm sorry. 18 Q. That's okay. 19 MS. LAVEY: 000643. 20 THE WITNESS: 643? Thank you. 21 A. So--okay, I --can I clarify my answer? 22 BY MR. LANGLAIS: 23 Q. Sure. 24 A. All right, and I'm just going to say what I 25 think these documents say, and it's basically agreeing Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045689 92 1 with you, and it says a unit produces, and I'm going 2 to say that's 3,000 pounds a day. 3 Q. Sure. 4 A. If you've got 30 days in a month, that's 5 90,000 pounds a month, so I think there's internal 6 consistency with that reading. 7 Q. Sure, and how about-8 A. But I would go back to my previous answer 9 and say if you really want to know what was being 10 produced, go to the production numbers and divide by 11 the number of days in a year. 12 Q. Right, but do you still feel that when they 13 say "unit," they're talking about the entire process? 14 A. Well, based on what I just told you, no. I 15 think that is "a" unit, not "the" unit. 16 Q. Okay. Okay. 17 A. But I think there is some ambiguity there. 18 Q. Could you look at page 000698, just a couple 19 of pages before that? 20 A. Okay. 21 Q. There is a discussion of three stills. It's 22 actually 698 and crosses over on 699, there's a, looks 23 like a benzol still, a diphenyl still. 24 MR. JACOBS: Are you looking at the bottom? 25 Which part of that page are you looking at? Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045690 93 1 MR. LANGLAIS: These two pages identify 2 three stills under the headings. 3 MR. JACOBS: Okay. 4 MR. LANGLAIS: There's been--looks like 5 benzol still, the diphenyl still, and high boiler 6 still. 7 BY MR. LANGLAIS: 8 Q. Do you see those? 9 A. Yes, I do. 10 Q. Are these part of the fractionating column, 11 or are these stills after the fractionating column? 12 A. The diphenyl, my understanding is the 13 diphenyl still is the fractionating column. 14 Q. Okay. Now, how does the benzol still fit 15 into--where does the benzol still fit into 16 the--this--what I'm going to do is I'm going to hand 17 you this flow diagram, and I've marked a couple of 18 other exhibits which I haven't shown you, but I'm 19 going to mark this one Solutia Exhibit 8, and it's DSW 20 462578. 21 (Defendant's Deposition 22 Exhibit Solutia 8 mark'd 23 for identification.) 24 Q. (Continuing) That's part of the, part of 25 one of the documents. I just give you that. What I Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045691 94 1 want to try to understand is where these three stills 2 come into play on this flow diagram, if at all. 3 MR. JACOBS: Object to form, just to the 4 extent it's not clear the source, the source of this 5 document isn't clear. 6 BY MR. LANGLAIS: 7 Q. What's the number on that again? 8 A. I'm sorry? 9 Q. What's the--let me see that for a second. 10 A. Yeah, I don't see a Bates number. 11 Q. We can do it this way. Let me hand you 12 what's marked "Biphenyl Flow Sheet." Would you take a 13 look at that? Does that, in your opinion, depict the 14 process flow diagram for the production of biphenyl 15 using the lead pot process? 16 A. Well, that's what it purports to document, 17 yes . 18 Q. And am I correct that the lead pot process 19 with, with some exceptions, which, which I'll clarify, 20 remain relatively the same throughout the course of 21 its history? 22 MR. JACOBS: Objection, vague. 23 BY MR. LANGLAIS: 24 Q. (Continuing) The basic process -- 25 A. I understand. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045692 95 1 Q. --stayed the same; is that right? 2 A. Yes. Yes. 3 THE WITNESS: Is there a question pending? 4 MR. JACOBS: Is there a question pending? 5 BY MR. LANGLAIS: 6 Q. Yeah. I want to know how these three stills 7 that are discussed on 000698 and 000699, how they play 8 into the process flow diagram, how they play into the 9 lead pot process. I'm not sure if this is, if this is 10 before, or after- 11 MR. JACOBS: When you say "this," you mean 12 Solutia Exhibit 8? 13 MR. LANGLAIS: No, these three stills. 14 MR. JACOBS: Do you understand his-15 THE WITNESS: Yes, I understand his 16 question. 17 MR. JACOBS: Do you-- 18 A. And I would, frankly, to give the straight 19 answer, I probably would need to spend some more time 20 with some other documents. Let me tell you what I 21 think. 22 BY MR. LANGLAIS: 23 Q. Okay. 24 A. I think the Solutia 8, the biphenyl flow 25 sheet, is a more or less simplified diagram, and I Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045693 96 1 believe that the document eighty--whatever it is, 2 Exhibit 3, page 698, describes three separate stills, 3 but I believe at least two of them are basically the 4 same as the fractionating column here, that there is 5 a, that there is a --one part of the still removes the 6 benzene, which there's still a high percentage of 7 benzene in the conversion products. The second still 8 removes the biphenyl, and a third still, which is 9 probably not shown on the flow sheet, is used to 10 distill the still bottoms to produce the Santowax, the 11 high boilers. 12 Q. Okay. 13 A. That's my understanding, so my--what's shown 14 on column on your flow sheet is probably actually a 15 combination of three separate stills. That's my 16 reading, subject to different times, you know, whether 17 one of them is more representative of one time frame 18 versus another, but that's my understanding as I sit 19 here right now looking at those. 20 Q. I understand that if the documents say 21 something different, then obviously, you would defer 22 to what the document says. 23 A. Right. 24 Q. Stay on page 699. At the very top, it 25 refers to, it refers to--remember the pans we Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045694 97 1 discussed earlier? 2 A. Yes, I do. 3 Q. It refers to those pans being made of 4 galvanized iron. Do you know what the iron pans were 5 galvanized with? 6 A. No. 7 Q. I've got some additional photographs. I'm 8 just--before we go to lunch, I'm just going back to 9 some of the things we discussed earlier. I'm going to 10 produce what's been marked Solutia Exhibit 7, and they 11 contain aerial photographs and they're Bates labeled 12 ADAD7-000278 through 283. I've got copies for you. 13 A. Okay. 14 MR. JACOBS: Are you done with Exhibit 3? 15 MR. LANGLAIS: Yes, for now, yeah. 16 BY MR. LANGLAIS: 17 Q. Have you seen--of course, take an 18 opportunity to look at them, but have you seen these 19 before? 20 MR. JACOBS: Is your question has he seen 21 each one? 22 MR. LANGLAIS: Yes. 23 A. I have not seen all of these. I may have 24 seen one or two of them. I've seen something similar, 25 but I don't know that I've seen all of these. I think Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045695 98 I have not. BY MR. LANGLAIS: Q. Now, there are labels for, for several of the buildings throughout the, what's been marked Exhibit 7. Do you know who had signed those labels to these aerial photographs? A. No. Q. Would you go through each of those, and if it's on the picture, would you mark where the lead pot process occurred during the relevant time period of 1929 through, through '64? MR. JACOBS: Okay. I still have your other one. MR. LANGLAIS: Okay. A. Do you want me to talk you through it as I'm going-BY MR. LANGLAIS Q. Yeah, why don't you-- A. -- so the record is clear, or -- Q. Let's first look at the one that's labeled ADAD-7000278, and it appears to be, it's labeled "1938 through 1947 . " A. Right, and I'm going to circle the topmost part of where there's, there's a label that says "Aroclor Unit" in the top left of the photograph, and Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045696 99 1 on the top side of that, it would be where the lead 2 pot process was, the biphenyl process was in basically 3 the same building, and just in front of the, the 4 Aroclor process. 5 Q. So it was just--so it was just south of the 6 Aroclor unit, correct? 7 A. That's correct. 8 Q. Let's look now at the picture labeled 9 "1953 . " 10 A. Okay, and this document--this--yes, 279, in 11 this page, it's going to be in the center of the 12 document, just below center is the Aroclor unit, and 13 in this case, it's going to be the bottom section of 14 that building or series of buildings; again, the 15 south, southmost side. 16 Q. Sure, and then the next one is 1957 through 17 1960? 18 A. Yeah, it's a similar picture. 19 Q. Same photograph? 20 A. Yes . 21 Q. Just different time frame? 22 A. Right. 23 Q. Nothing--do you know --I don't, 24 really--and I know obviously, you can't sit and 25 analyze this photograph, but I don't see that there's Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045697 100 1 much difference between the '53 and the 1957. 2 MR. JACOBS: Are you asking him a question? 3 MR. LANGLAIS: Yeah. 4 A. The only difference I really see is the 5 organic residue incinerator. 6 BY MR. LANGLAIS: 7 Q. Sure, and I was just focused on the location 8 where the lead pot process -- 9 A. No. No. 10 Q. And in fact, if you look at the next one, 11 which is 1960 to 1962, it actually has "Lead pot area" 12 identified. 13 A. Correct. 14 Q. Now, the next one is 1967, and by that time, 15 the lead pot process was no longer used. 16 A. Correct, but biphenyl manufacture was still 17 going on in the same area. 18 Q. What is--if you look down, I guess it is 19 just below the Aroclor unit in the polyphenyl unit,-- 20 A. Yes? 21 Q. --what was, what was made there? 22 A. Well, higher polymers of benzene. 23 Q. Okay, that's got nothing to do with the lead 24 pot process. 25 A. Well, when-- Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045698 101 1 Q. Well,-- 2 A. When, when the lead pots were being used, 3 the polyphenyls were the high boilers-4 Q. Right. 5 A. --from the biphenyl process. 6 Q. Okay. 7 A. So -- 8 Q. Okay. 9 A. --in 1967, it didn't have anything to do 10 with it. 11 Q. Right, and if you look at--it's kind of cut 12 off, but I think it's 1975, the very next one, which 13 is the last one, can you locate on here where the, the 14 lead pot process occurred? 15 MR. JACOBS: In 1975? 16 MR. LANGLAIS: No, I understand it didn't 17 occur in 1975, but just circle on here where 18 historically it had occurred. 19 (Witness complies.) 20 A. Okay, I've circled basically a bare area and 21 labeled it "Former LP." 22 Q. Can I look at that one for a second? So it 23 appears that by 1975, the, the structures where the 24 lead pot process were manufactured had been razed? 25 A. Yes. That was part of the removal of the Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045699 102 1 Aroclor process. 2 Q. And what's, what's in the place--what's in 3 place of that now, or is it a grassy area? 4 A. It's a chatted area, stone, stone area. 5 There's nothing there, there's no buildings there, 6 it's -- 7 Q. Okay, nothing else has been put in its 8 place? 9 MR. JACOBS: When you--objection. Do you 10 mean now? Do you mean right now, or -- 11 MR. LANGLAIS: Yeah, like today. 12 MR. JACOBS: --or in the photo? 13 MR. LANGLAIS: Today, because in the photo, 14 it's clear that the, it's clear that the building 15 where the lead pot process took place had been razed. 16 I want to know-- 17 MR. JACOBS: I'm just clarifying what he's, 18 what he's -- 19 A. And I want to clarify my answer. I think 20 it's an asphalt cover. 21 MR. LANGLAIS: Okay. 22 BY MR. LANGLAIS: 23 Q. Do you know when they put that asphalt cover 24 on there? 25 A. My recollection is it was as soon as the Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045700 103 1 plant was --the Aroclor plant was removed. 2 MR. JACOBS: Are you done with these photos? 3 MR. LANGLAIS: Yeah. 4 (Pause.) 5 MR. LANGLAIS: I want to make sure I already 6 produced that to you. 7 BY MR. LANGLAIS: 8 Q. If you would turn to Exhibit 4, DSW 462481. 9 MR. JACOBS: 462481? 10 MR. LANGLAIS: Yeah. 11 BY MR. LANGLAIS: 12 Q. At the top, I think if you read that partial 13 paragraph-let me know when you are finished; I want 14 to follow up on something that we covered earlier. 15 MR. JACOBS: At the very top? 16 MR. LANGLAIS: Yeah, beginning with 17 "However." You can read it to yourself. 18 A. Yeah, I recall reading it. 19 BY MR. LANGLAIS: 20 Q. Okay. Now, after reading this, does this 21 kind of confirm what we discussed earlier, that when 22 they refer to a biphenyl unit, they are referring to 23 not the whole process but a unit of the three pots, or 24 in the case of numbers 4 and 5, a heat exchanger and 25 two pots. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045701 104 1 MR. JACOBS: Object to form. Go ahead. 2 A. Okay, in this context, there's no question 3 that your interpretation is correct. 4 BY MR. LANGLAIS: 5 Q. Okay. 6 A. I'm not sure about the context of the other 7 one, but as we discussed earlier, I think things are 8 consistent with your, with your description. 9 Q. If you would turn to page DSW, in this same 10 exhibit, Exhibit 4, DSW 462484,-11 A. Yes. 12 Q. --particularly in that first paragraph, it 13 says, "The carbon formed in the diphenyl units partly 14 deposits in the pipe after the converter units, 15 through the lead trap, in the pipe after the lead 16 trap, and in the fractionating column." Do you see 17 that? 18 A. I do. 19 Q. Remember I had asked you earlier, you said 20 you were uncertain whether or not there was carbon 21 adherence in the fractionating column, itself? Do you 22 recall that? 23 A. Yes. 24 Q. This seems to indicate that there was. Do 25 you agree with that? Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045702 105 1 A. Some amount or another, yes. 2 Q. And it says, "These pipes plugged with 3 carbon and must be dismantled and cleaned every one to 4 six months." 5 A. That's correct. 6 Q. Okay, and then below that, then, the very 7 next sentence says, "The lead trap and fractionating 8 column are cleaned out at more frequent intervals." 9 A. "More infrequent." 10 Q. I'm sorry, "more infrequent intervals. This 11 so-called"--"This so-called carbon deposit analyzes as 12 follows," and it says, "Lead, 56.5 percent." Do you 13 see that? 14 A. Yes . 15 Q. Now, after seeing--had you seen this, this 16 before, this 56.5 percent lead concentration before? 17 A. No. 18 Q. Okay, does this in any way change your 19 opinion about whether or not this material contained, 20 as you put it, low levels of lead? 21 MR. JACOBS: Object to form. 22 A. Um, it's a number higher than I would have 23 expected. 24 BY MR. LANGLAIS: 25 Q. And again, just to clear up something we Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045703 106 1 were discussing earlier about capacity, the very last 2 paragraph of this says "The diphenyl units produce 3 crude diphenyl by continuous process with a 4 24-hour-a-day operation." 5 A. That, you read that correctly. 6 Q. And that, that fits in line with what I was 7 saying before about capacity. You agree with that? 8 The capacity of the unit is 24--the unit conceivably 9 can operate 24 hours a day? 10 A. Subject to the possibility of shutdowns, 11 that is correct. 12 Q. Okay, and I think that's what you said 13 earlier; I just wanted to, I just wanted to make 14 clear. Okay, if you go to Exhibit 6 -- 15 A. I don't think you've given me that. 16 Q. I'm going to hand you what's been marked 17 Solutia Exhibit 6. It's entitled "Process for the 18 Manufacture of Diphenyl and Santowax" and is dated 19 November 1950. Have you seen this document before? 20 A. Yes. 21 Q. And was this document part of the documents 22 that that Monsanto produced as part of its 2004 CERCLA 23 104(e) response, if you recall? 24 A. Yes, I believe it was. 25 Q. And this was one of the documents that you Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045704 107 relied upon in preparing for your testimony here, today, about the lead pot process? A I did review it, yes. Q If you would look for me at DSW 462152, and if you would read what's marked there, what's marked number 7, "Lead Trap," there are, there are two paragraphs to that. If you go ahead and make yourself familiar with that, I want to ask you a few questions. (Witness peruses said document.) A I've read those two paragraphs. Q Okay, the first one I thing I want to focus on, it looks like at some point, new biphenyl units were put on line that had larger lead traps. Do you see that in the second sentence of the second paragraph? A Yes, it says that. Q Okay, and we were discussing earlier, this is one of the instances where although the basic process of biphenyl stayed the same, this is one instance where, where there was a change as time went on, and this appears to be in 1950, so at least by 1950, there was--they increased the size of the lead, of the lead traps. Do you see that? MR. JACOBS: Object to the form. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045705 108 1 A. Yes. 2 BY MR. LANGLAIS: 3 Q. Do you know why that was done? 4 A. No, not specifically. 5 Q. If you look at the second-to-the-last 6 sentence, it says, "In a trap." Do you see that 7 sentence that starts there? 8 A. Yes. 9 Q. "In a trap seen November '50," which I 10 think--"Nov/50," which I think is November 1950, "the 11 layer of entrained lead was 14 inches deep and there 12 was considerable solid debris as well." Do you see 13 that? 14 A. Yes. 15 Q. Do you know what they're--they're saying 16 that the layer of entrained lead in the lead trap was 17 14 inches deep? Is that what they are saying there? 18 A. That would be my reading, yes. 19 Q. Now, the last, the last section is a note on 20 emptying the lead trap. Would you go ahead and 21 read--I think it jumps over, it jumps over a page, but 22 go ahead and read the one, two, the three paragraphs 23 associated with that section and let me know when you 24 are finished. 25 (Witness peruses said Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045706 109 1 document.) 2 A. Okay. 3 Q. Okay, it appears what, what happens is once 4 this, this lead trap becomes entrained with the lead, 5 the--in order to empty or clean out this, this 6 entrained lead, they literally have to use flames to 7 melt the lead inside that trap? Is that how you read 8 this? 9 A. Yes, I do. 10 Q. Do you see where it says "They use flames of 11 natural gas played on the pot until the lead runs out 12 onto the table and down into a lead melting pot"? 13 A. Yes. 14 Q. Now, had you ever--had you seen any other 15 documents where, where this is discussed? I'm trying 16 to figure out what they're referring to when they, 17 they have a table set up just for this, or -- 18 MR. JACOBS: Object to form. 19 A. Well, if you refer to the page you've 20 skipped, which is the diagram-- 21 BY MR. LANGLAIS: 22 Q. That might help. 23 A. It shows the lead--it shows the heating 24 table and leading to the melting pot. I mean, I think 25 it's diagrammed fairly clearly there. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045707 110 1 Q. Do you know how the lead that was on the 2 table--well, do you know if any lead remained on the 3 table after this process? 4 A. I don't know. 5 Q. And do you know if there was an opportunity 6 for any lead to leak out of this, of this table? 7 A. Presumably not, but I don't know 8 specifically. 9 Q. And do you know what happened to this, this 10 lead after it was--does this document say what 11 happened to this lead after it entered the melting 12 pot? 13 A. Yes. 14 Q. And what does it say? 15 A. It said, back on 462154, the top sentence, 16 it says it "... runs out under the table into the lead 17 melting pot from which it can be run off at 18 convenience into molds like those used to empty the 19 pots." 20 Q. Okay, so what they would do is they would 21 take this, this melted lead and put it into molds and 22 make those ingots -- 23 A. Yes. 24 Q. --that we discussed? 25 A. Yes. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045708 Ill 1 Q. Is there any discussion here on how--strike 2 that. I'm just trying to clean up a few things before 3 we break for lunch. Exhibit 3, which I think your 4 attorney put to the side-5 MR. JACOBS: The June 1935? 6 MR. LANGLAIS: Yeah. 7 BY MR. LANGLAIS: 8 Q. Turn to page ADA 000700. 9 A. Okay. 10 Q. Okay, there is--the paragraph above the 11 section labeled "Capacity", it discusses still 12 residues in the second sentence, consisting 13 principally of tars and carbon is drawn out and 14 discarded? 15 A. Yes. 16 Q. Is this referring to what I've seen some 17 documents call montars or Montar 9? 18 MR. JACOBS: Object to form. 19 BY MR. LANGLAIS: 20 Q. The tars that are referred to there-21 A. I'm just trying-22 Q. Yeah. 23 A. --I'm just trying to be sure before I answer 24 your question, it's talking specifically about the 25 still bottoms, the high boilers from the high boiler Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045709 112 1 still, and that would be, my understanding would be 2 one of the montars. I believe 9 is correct in this 3 case. 4 Q. How many--do you recall how many montars the 5 facility, the facility would, would manufacture? Like 6 how many--there was one reference to Montar 9 in some 7 of the documents. Do you recall that? 8 MR. JACOBS: Objection. We're getting a 9 little bit off now. 10 MR. LANGLAIS: No, this is one of the 11 fractions in the lead pot process. 12 BY MR. LANGLAIS: 13 Q. Am I right, montar is a fraction as part of 14 the lead pot process, the distillate? 15 A. Montar 9 is, yes. 16 Q. Okay. Are there other montars that the 17 company refers to that aren't part of the lead pot 18 process ? 19 A. Yes. 20 Q. Okay, is Montar 9 the only montar connected 21 with the lead pot process that you've seen? 22 A. Well, let me, let me--in a way, they're all 23 connected with the lead pot process. 24 Q. Okay. 25 A. Montars 9 and 10 are connected with the Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045710 113 1 nonchlorinated polyphenyl manufacture, which is, of 2 course, directly related to the lead pot process. 3 Q. Sure. 4 A. The montars 1 through--they're, they're 1 5 through 8, but I'm not sure every number is 6 represented--are from the chlorinated biphenyl 7 process, so they're only indirectly related. 8 Q. The Montars 1 through 8 are not a distillate 9 in the lead pot process? 10 A. That is-- 11 MR. JACOBS: Object to form, but go ahead. 12 A. (Continuing) Well, none of them are 13 distillates. They're still bottoms. They are not 14 still bottoms from the lead pot process, that is 15 correct. 16 BY MR. LANGLAIS: 17 Q. If you would, turn in Exhibit 6 to page DSW 18 462072. 19 A. I'm sorry, could you repeat the page number 20 again? 21 Q. It's DSW 462072. 22 A. Okay. 23 Q. You see the reference in the one, two three, 24 four, five--the sixth paragraph. 25 MR. JACOBS: The biggest paragraph? Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045711 114 1 MR. LANGLAIS: The sixth paragraph. It's 2 the paragraph that begins, "The converter rooms"? 3 A. Yes. 4 BY MR. LANGLAIS: 5 Q. You see the second sentence, "It is not at 6 all unusual to have escaping vapors burning around the 7 cover of the converter pot, especially now some of the 8 converters are being run at over 20 psig"? Do you see 9 that? 10 A. I see that. 11 Q. What vapors are they referring to? Do you 12 know? 13 A. Benzene. 14 Q. Now, if benzene vapors are escaping from the 15 pot, would you agree with me that there is a strong 16 likelihood that lead vapors are also escaping from the 17 pot? 18 MR. JACOBS: Object to form. We're getting 19 into expert areas. 20 BY MR. LANGLAIS: 21 Q. (Continuing) If you know. 22 A. Some small amount. 23 MR. LANGLAIS: This is probably a good time 24 to break for lunch, if you want to. 25 MR. JACOBS: Okay. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045712 115 1 MR. LANGLAIS: What time is it now? 2 MR. TURNER: Twenty after. 3 MR. JACOBS: We're off the record now? 4 MR. LANGLAIS: Yeah, we can go off the 5 record. 6 (Luncheon recess.) 7 AFTERNOON SESSION 8 MR. LANGLAIS: For those on the phone, I'm 9 going to go ahead and get started. Is anybody there? 10 MS. LAVEY: This is Wendy. I'm here. 11 MR. KOZIK: This is Tim. I' m here. 12 MS. McADAM: This is Allison . I'm here 13 MS. 0'NEAL: This is Lynne. I'm here. 14 MR. LANGLAIS : Hey, Lynne. How is your 15 daughter? 16 MS. O'NEAL: Much better, thanks. She's 17 just not pleased with her appearance. 18 (Discussion off the record.) 19 BY MR. LANGLAIS: 20 Q. Mr. Kaley, could you look at Exhibit 3 for 21 me again? Some final questions on Exhibit 3 and then 22 we can put it aside. If you'd look at page 000712-23 A. I'm there. 24 Q. Okay, in that last paragraph, in the last 25 sentence before it continues over on to the next page, Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045713 116 1 it discusses "blow back of lead." Do you see that? 2 A. I see that. 3 Q. Okay, do you know what they mean by, by 4 "blow back of lead"? 5 A. Can I read-- 6 Q. Oh, yeah. Yeah. 7 A. Let me see what the whole paragraph says. 8 Q. I understand. 9 (Witness peruses said 10 document.) 11 A. Yes. I mean, this, it's basically telling 12 you the order in which to release the--this is a 13 pressurized system, and all three are pressurized, and 14 it's telling you the order in which you depressurize 15 the lead pots, saying do the converter first, and the 16 second--and the preheater second because if you did it 17 in the opposite order, the pressure in the, in the 18 converter would blow the lead back from the converter 19 pot into the lines, into the second preheater pot. 20 Q. Okay. Now, if you go a couple of pages 21 ahead to DS --I'm sorry, ADA 000714 -- 22 A. Okay. 23 Q. Now, there are several things mentioned in 24 the first four paragraphs, and I'll tell you, you can 25 go ahead and read, read those and then I want to talk Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045714 117 1 to you about them. 2 A. Okay. 3 Q. Now, the first thing that's mentioned in the 4 first--I guess it's the--it depends on how you look at 5 it, I guess. It's the first paragraph discusses pipe 6 breakage. 7 A. Yes. 8 Q. Do you know what pipes, are they referring 9 to the pipes that connect, that connect the preheater 10 pots to each other and to the converter pot? Do you 11 know what piping they are referring to? 12 A. Well, I think it's in the distributor 13 system, which is the distribution of the benzene into 14 the lead pot system, so I think it's the benzene 15 delivery system. 16 Q. Okay, and how about where it says, 17 "Thermocouple well failure"? It says "Thermocouple 18 well failure due to vibration and indicated by leakage 19 around the connection at the top of the pot." 20 MR. JACOBS: And what, what's your question? 21 BY MR. LANGLAIS: 22 Q. (Continuing) Do you know what thermocouple 23 well failure they're referring to? Do you know-- 24 A. Well, the thermocouple is--the temperature 25 measuring devices are inserted into wells, depressions Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045715 118 1 in the covers of the pots. 2 Q. In each of the three, the three lead pots? 3 A. I would believe that's correct, yes. 4 Q. Now, if there was a thermocouple failure, is 5 it "well" or "wall"? Can you see that? 6 A. I think it's "well." 7 Q. Okay. 8 A. Well, I don't know. 9 Q. It looks like an "e," but -- 10 A. It looks like an "e" to me, too, and I 11 believe they are actually in the, in the--in little 12 depressions, like I said,-- 13 Q. It discusses -- 14 A. --so I think it is. 15 Q. I'm sorry. It discusses leakage around the 16 connection at the top of the pot. Now, what would 17 leak out? 18 A. Primarily, benzene. 19 Q. Would you also have some, some lead vapors 20 leak out? 21 MR. JACOBS: Objection: Getting into expert 22 area. 23 A. I mean, to whatever extent there is -- 24 MR. LANGLAIS: Well, he knew--I guess my 25 only point is he's familiar with this process, and Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045716 119 1 this is a highly technical process, so I think, and 2 we're--we identified this to discuss the potential for 3 lead losses, and what I'm asking him is if he knows if 4 there--I mean, he knew there would be--he speculated 5 there would be benzene vapor losses. He didn't have a 6 problem with that. 7 MR. JACOBS: So what is your question? 8 BY MR. LANGLAIS: 9 Q. I want to know if there is benzene vapor 10 losses, would you also expect there to be some loss of 11 lead vapors through that thermocouple? 12 MR. JACOBS: Objection. Are you asking him 13 if he knows or if he's--you are asking him to opine if 14 there would be lead losses? 15 MR. LANGLAIS: I'm asking him if it's 16 likely. You can call it what you want, opine or -- 17 MR. JACOBS: No, you are asking the 18 question. 19 MR. LANGLAIS: Really, everything he's 20 talking about here today, he's opining. He wasn't 21 there to do the lead pot process. Would you agree? I 22 mean, he's not -- I'm asking Monsanto. I'm asking 23 Monsanto, and so he really is taking on the knowledge 24 of everyone that's ever done this process and everyone 25 that is involved with this. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045717 120 1 MR. JACOBS: I'm not going to argue over 2 exactly-3 MR. LANGLAIS: Okay. 4 MR. JACOBS: --what he's required to do-5 MR. LANGLAIS: Okay. 6 MR. JACOBS: --in a 30(b) (6), but I'm just, 7 I'm just making sure he-8 MR. LANGLAIS: Okay. 9 MR. JACOBS: --your question is clear so he 10 understands -- 11 MR. JACOBS: --what he's got to answer. 12 BY MR. LANGLAIS: 13 Q. Would you also think there would be at least 14 some loss of lead vapor through that thermocouple 15 failure, or the leak created by that? 16 MR. JACOBS: Same objection. You can go 17 ahead and answer. 18 A. To the extent there are lead vapors in the 19 benzene, there's potential for some lead loss. 20 BY MR. LANGLAIS: 21 Q. Okay, and then the next one, it says, "Pot 22 failure indicated by lead running out of the fire box 23 door." 24 A. Yes. 25 Q. Do you see that? Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045718 121 A. I see that. Q. Have you noticed that reference about pot failures in any of the documents that you reviewed? A. There are discussions of, of a variety of pot failures in other documents, yes. Q. Was pot failure in connection with the, with the lead pot process a recurring problem over the history of the lead pot process? A. It was an occurrence that was--you know, I don't see the frequency, but it clearly happened. Q. Do you know-have you seen any indication of what the company did with that lead that ran out of the fire box door? A. Well, I think there is some documentation, and I think in discussing with Jerry, the people that observed it was that when it hit the floor, it would solidify, and then it was chipped off and put back in the pots or collected and put back in the bottoms. Q. In the next section, it says "Whenever a pot is opened, it is essential that the lead be measured and any necessary makeup added." Right? A. That's what it says. Q. Now, that goes back to our discussion that although this--this was a process that required Monsanto to add lead as time went on, right? To these Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045719 122 1 lead pots? Because the amount of molten lead would 2 decrease over time. 3 A. Yes. 4 Q. And in your review of documents, you weren't 5 able to get any indication of how much lead Monsanto 6 was purchasing? 7 A. I don't recall seeing that. 8 A. No, I don't. 9 Q. Now, if you would look at -- 10 MR. JACOBS: Are you done with this exhibit? 11 MR. LANGLAIS: Yeah, I'm done with that one. 12 I'm sorry. 13 BY MR. LANGLAIS: 14 Q. Solutia Exhibit 6. 15 A. Okay. 16 Q. Page DSW 462071. 17 A. Okay. 18 Q. Under the section that says, "Health" -- 19 A. Yes, sir. 20 Q. --in the last sentence, it says, "We are 21 warned that lead vapours may be evolved during the 22 burning out of lead traps and carbon traps." 23 A. Yes. 24 Q. So that, that seems to indicate 25 that--remember the, remember the burning out of the Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045720 123 1 lead trap that we discussed earlier, where the lead 2 would be burned out on that table? 3 A. Yes. 4 Q. And then the tier would flow down into the, 5 into the melting pot? 6 A. Yes. 7 Q. There would be at least some lead vapor loss 8 associated with that process? 9 A. Well, I mean they're certainly warning of 10 that potential. I mean, they do use the word "may," 11 so -- 12 Q. Sure. If you would look at DSW 462073, in 13 the section heading "Fire," and it looks like it says, 14 "Fire, continued," the very last paragraph of that 15 refers to blowing out of gaskets on the converter 16 cover. 17 MR. JACOBS: Is there a question? 18 MR. LANGLAIS: Yeah. I want--I'm just 19 directing him to that paragraph, and then I'll ask the 20 question. 21 A. Yes, I see that paragraph. 22 BY MR. LANGLAIS: 23 Q. Now, the converter, the converter pot, the 24 converter cover that they're referring to is the cover 25 on the, the last of the lead pots in the biphenyl Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045721 124 1 process, right? 2 A. That's correct. 3 Q. During--when--now it says, it says, here, 4 that there's a greater risk of blowing out the gasket 5 on the converter. Have you seen any documentation to 6 show that gasket blowouts were a problem or occurred 7 with, with any frequency as part of this biphenyl 8 process ? 9 MR. JACOBS: Object to form. 10 A. I've not seen any further discussion of that 11 issue. 12 BY MR. LANGLAIS: 13 Q. But this is similar to the last point, that 14 they're just advising them that if the pressure gets 15 too high, a gasket could blow out? 16 A. Yes. 17 Q. Is that how you read this? 18 A. That is how I read it, yes. 19 Q. Now, when we refer--when we've been 20 referring to lead vapor throughout the course of this 21 deposition, is lead vapor, in your mind, the same as 22 lead oxide? 23 A. Certainly not. 24 Q. Okay, how is, how is--what is lead oxide? 25 A. Lead is a molec--lead oxide is a molecule, Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045722 125 1 is a compound of lead made up of lead atoms and oxygen 2 atoms. It's--iron oxide is rust. As iron plus oxygen 3 go together to make rust, lead oxide is the same 4 physical combination. You've changed lead from a 5 metallic lead into a combined form with oxygen, so in 6 a sense, it's lead rust. 7 Q. Okay, so it's a solid, it's a solid 8 material, as opposed to a gaseous? 9 A. Yes. 10 Q. Could you look at page DSW 462078? 11 A. Okay. 12 Q. It says, "Lead is known to escape sometimes 13 through the cover joints on the pots at Anniston. It 14 may form lead oxide outside the pot, and this lead 15 oxide may attack the outer surfaces of the pot." Do 16 you see that? 17 A. You've read that, yes, correctly. 18 Q. Have you seen any indication on how the 19 Anniston facility would deal with addressing the lead 20 oxide that forms on the outside of pots occasionally? 21 MR. JACOBS: Object to form. 22 A. No, I've not. 23 BY MR. LANGLAIS: 24 Q. DSW 462095? 25 A. Okay. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045723 126 1 Q. In the second-the-last paragraph, there's a 2 reference to dumping the ingots. The second-to-last 3 paragraph. Yeah, there you go. 4 A. Oh, okay, yes. 5 Q. These are lead ingots they're referring to? 6 A. Yes. 7 Q. Do you--did you find any reference in any of 8 the other documents on where these lead ingots were 9 placed, where were they dumped? 10 A. No, I did not. No, I don't know 11 specifically--well-12 (Witness continues to 13 peruse said document.) 14 A. "A few yards away," well, I would be 15 speculating. It says a few yards away. 16 Q. Right. 17 A. I suppose that could get you out of the 18 building, rather than still in the building. I don't 19 really--I'm speculating. I don't know. 20 Q. You don't know whether it's inside or 21 outside the building that they are referring to when 22 they say this? 23 A. Not--no, I don't. 24 Q. And I don't want you to, I don't want you to 25 guess. If you don't know, that's fine. If you would Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045724 127 1 look at DSW 462098, particularly the second-to-last 2 paragraph,-- 3 A. Okay. 4 Q. --it references splashing of the lead onto 5 the walls. Do you see that reference? 6 A. Yes. 7 Q. What walls --are they referring to the, the 8 pot walls? 9 A. The inside walls of the pot, yes. 10 (Defendant's Deposition 11 Exhibit Solutia 9 mark'd 12 for identification.) 13 BY MR. LANGLAIS: 14 Q. I hand you what's been marked Solutia 15 Exhibit 9. 16 MR. LANGLAIS: For those on the phone, it's 17 Bates labeled ADA 001050 through 001090, and this is 18 a, what purports to be a standard manufacturing 19 process for biphenyl, dated 1957, September 17th, 20 1957 . 21 (Witness peruses said 22 document.) 23 Q. (Continuing) Have you seen this document 24 before? 25 A. Yes. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045725 128 1 Q. Okay, was this, was this a document that you 2 relied upon in preparing for your deposition here, 3 today? 4 A. I believe there was one included in the 5 104(e) production, yes. 6 Q. The only thing I want to talk to you about 7 on this, in this document is on page ADA 001081. 8 A. I'm on that page. 9 Q. Okay, in particular, there is a--the section 10 labeled "Lead Dross." 11 A. Yes. 12 Q. How was--are you familiar with what lead 13 dross is in connection with the biphenyl process? 14 A. Yes, I believe so, yes. 15 Q. Where would the lead dross be formed? In 16 what step of the biphenyl process? 17 A. Well, it would be formed during the 18 conversion of benzene in the lead pots. 19 Q. So it would be--it's actually the material 20 that floats to the top of the molten lead? 21 A. Yes. 22 Q. And in your mind, is that material--is that 23 the impurities in the lead coming out of solution? 24 A. No, I don't think it's computers in lead, I 25 think it's byproducts of the reaction of lead with the Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045726 129 materials-Q Okay. A --in the reaction, that there's going to be a little bit of oxygen in there even though it's supposed to be excluded, so there's going to be some metallic reaction products. Q. Now, this refers to when this--it says "When this contamination occurs, the lead in the top of the pot is dipped out and fresh lead added." Do you know what the facility did with that lead dross that was dipped out of the lead pots? A My understanding is it was landfilled. Q And did that lead dross contain lead as one of the components? A I'm sure it did, yes. MR. JACOBS: Are you done with this one? MR. LANGLAIS: Yeah. BY MR. LANGLAIS: Q Are you familiar with lead being present in the furnaces as part of the lead pot process? MR. JACOBS: Object to form. A I'm not sure what you are referring to. BY MR. LANGLAIS: Q Okay. If you would--I hate to do this to you--go back to Exhibit 6 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045727 130 1 A. I've got it. 2 Q. Okay, look on page DSW 462078. 3 A. Okay. 4 Q. The very last sentence says, "There is no 5 point in trying to detect lead in the stack gases 6 because there is always some lead lying about in the 7 furnaces." 8 A. Okay. 9 Q. Is this the first time you've seen that 10 reference to lead being in the furnaces? 11 A. I mean, I've read this paragraph before. I 12 didn't recall it specifically. 13 Q. Does this refresh your memory? 14 A. Well, the furnaces are what is used to heat 15 the lead pots. 16 Q. Sure. Do you know if the facility cleaned 17 out those, those furnaces? 18 A. I, I don't recall seeing a reference to that 19 specifically. 20 Q. Of that same exhibit, a few pages back, DSW 21 4 62 07 5 -- 22 A. Okay. 23 Q. In the very last sentence, it references 24 molten lead being baled about on the operating floor. 25 A. Yes. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045728 131 Q. Do you know what they are referring to in that statement? MR. JACOBS: Object to form. A I don't specifically, no, I don't know that. BY MR. LANGLAIS: Q Is this the first time you had seen any reference to molten lead being baled out into the operating floor? A I had read that paragraph before, and I didn't understand what it meant at the time. Q Now, these lead pots would have to be cleaned out occasionally MR. JACOBS: Object to form. BY MR. LANGLAIS: Q Would these lead pots ever be cleaned out? A Yes, they would. Q Do you know what, what Anniston did with any of the contents of these lead pots? A To the extent that it was lead in them, they, they took it out of the pots and put it in ingots and put it back in the pots for reuse. Q And you base that upon discussions with Jerry Brown? A Well, I mean it's in this document,-Q Okay. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045729 132 1 A. --I think. I mean, it talks, talks about 2 taking the lead out of the pots and putting it in 3 molds and filling the, the ingot molds. Yeah. I 4 mean, I'm on page 097. "The lead ingots usually leave 5 the molds easily, they're stacked near the end of the 6 unit until a new pot is in place, then they are 7 packed, on end, in the pot, and melted down, and any 8 lead needed for make-up is added," and there's that, 9 in the paragraph before that is that "bale out" term 10 again. It's still not totally clear, although it may 11 just mean removing lead from the ingots, what they're 12 calling "bale out." 13 Q. Well, you would be guessing on that point, 14 right? 15 A. Well, it's not a total guess because it says 16 the usual procedure if the pot is moved--yeah, the 17 usual--"the lead would be allowed to solidify before 18 the pot was moved. The usual procedure is to bail out 19 the lead as described above," which is what is 20 described above is scooping out the lead and putting 21 it in the ingots, so it's more than an assumption; I 22 think it's a logical conclusion from usage. 23 Q. Now, you had testified earlier that they 24 detected lead in the crude biphenyl. 25 A. Yes, that's true. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045730 133 1 Q. Now, did--is there anything in the process 2 to indicate--did Monsanto take any steps to try to 3 remove that lead from the crude biphenyl before 4 proceeding with its--before proceeding in distilling 5 that product? 6 A. No. 7 (Defendant's Deposition 8 Exhibit Solutia 10 9 mark'd for 10 identification.) 11 BY MR. LANGLAIS: 12 Q. I'm going to hand you what's been marked 13 Solutia Exhibit 10. 14 For those on the phone, this is a 15 single-page document and it's Bates labeled ADA 16 002352. 17 You can go ahead and read that and let me 18 know when you are, when you are finished. 19 (Witness peruses said 20 document.) 21 A. There you go. I'm finished. 22 Q. Okay, in there, it references the use of old 23 acid tanks that were torn down and the lead linings 24 from those tanks were reclaimed? 25 A. Yes. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045731 134 1 Q. Are they referring to lead acid tanks at the 2 Anniston Plant? 3 A. Yes. 4 Q. Okay, and--so do you know what those, those 5 old acid tanks were used for? I mean, I know they 6 stored--did they store acid, and if so, for what 7 process ? 8 A. I believe the phosphoric acid process. 9 Q. Was it--have you come across any other 10 documents to indicate that something other than the 11 high-grade pig lead that they reference in there was 12 used as part of the lead pot process? 13 MR. JACOBS: Are you in the first paragraph? 14 Okay. 15 MR. JACOBS: I object to form. I'm sorry. 16 Go on. 17 A. I was going to say, this is the only 18 specific reference I recall. 19 BY MR. LANGLAIS: 20 Q. Do you recall having seen this before? 21 A. I have seen this document, yes. 22 Q. Was this one of the documents you reviewed 23 in preparing for your depo today? 24 A. Anniston 104(e) set, yes. 25 Q. And this was --yes, this was part of the Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045732 135 104(e) that you sent in 2004? A. Well -- Q. 104 (e) response? A. Yes . Q. Do you know if any kind of process water was associated with the biphenyl production process, the lead pot process? A. The only water that I know associated with it is in the, in the cooling condensers for the stills. Q. It would be noncontact water? A. Non-contact water, yes. Q. Do you know if they may have--did you see any indication that the Anniston Plant cooled the lead ingots with water to increase the rate at which they solidified? A. I've not seen that. Q. This goes back to the, the discussion we just had about the acid tanks, the led-lined acid tanks that were used. It's my understanding that there were also lead pipes at the Anniston Plant. Do you know if those lead paps were melted and used as part of the, the biphenyl process? A. My understanding from Jerry Brown is that they were landfilled, they were not melted and put Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045733 136 1 into the process. I believe that demolition actually 2 occurred after the lead pot process had been shut 3 down. 4 Q. Okay, that's what I thought. I just, I 5 wanted to make clear. 6 MR. JACOBS: Do you want to break a couple 7 of minutes, let you guys talk? 8 MR. LANGLAIS: Yeah, why don't we do that? 9 MR. JACOBS: All right, we'll excuse 10 ourselves for about five minutes. 11 (Recess.) 12 (Defendant's Deposition 13 Exhibit Solutia 11 14 mark'd for 15 identification.) 16 BY MR. LANGLAIS: 17 Q. I'm going to hand you what's been marked 18 Solutia Exhibit 11. It's a single page. It's marked 19 ADA 002337, and it's entitled "Montar/Santotar 9 waste 20 Production 1936 to 1964." Have you seen that 21 particular document before? 22 A. I believe I've seen it, yes. 23 Q. Do you know, did you help prepare that 24 document? 25 A. No. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045734 137 1 Q. Do you know who did? 2 A. No. 3 Q. Was that document produced as part of 4 CERCLA's 104(e) response, if you recall? 5 A. I believe it was. That would have been 6 where I would have seen it, I believe. 7 Q. Is Santotar 9, is that name, Santotar, the 8 same as Montar 9? 9 A. Yes. 10 Q. It's just a different name? 11 A. Yes. 12 Q. And that document purports to show pounds of 13 biphenyl production. I presume that when they say 14 "biphenyl production," they are referring to the 15 distilled biphenyl? 16 A. That's correct. 17 Q. And then in the next column is pounds of 18 Santowax produced? 19 A. Santowax C. 20 Q. Santowax C. 21 A. Yes. 22 Q. What is the "C," what--does the "C" mean 23 anything as part of that? 24 A. Well, I could speculate as to what it means. 25 Q. If you don't know-- Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045735 138 1 A. It's just a name. You know, I mean, I think 2 it means crude. 3 Q. And that's one of the distillate fractions 4 that comes off as part of the biphenyl process ? 5 MR. JACOBS: Objection as to form. 6 A. That's the still bottoms of the distillate-7 BY MR. LANGLAIS: 8 Q. The still bottoms,-- 9 A. --for the production-- 10 Q. --okay. 11 A. --of biphenyl, yes. 12 Q. And that last section is the pounds of the 13 Montar 9 produced? 14 A. Yes. 15 Q. Why is it--am I to read--the title of that 16 says, "Montar/Santotar 9 Waste Production." Am I to 17 read that as to conclude that this last column wasn't 18 product that was sold? It was, in fact, waste, waste 19 of--waste produced? 20 MR. JACOBS: Object to form. 21 A. The, the Montar/Santotar materials were 22 still bottoms which were waste up until the point 23 someone found another use for them. 24 BY MR. LANGLAIS: 25 Q. I understand. They were wastes until you Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045736 139 1 could--until you found another use for it, or 2 potential buyer? 3 A. Some of them ended up as wastes and were 4 landfilled. Some of them were recovered and used for 5 other processes. 6 Q. In your review of documents, are you able to 7 tell me at what point that other use came to light? 8 MR. JACOBS: Objection. 9 BY MR. LANGLAIS: 10 Q. When this stuff went from being a waste to 11 finding this, this possible use, do you know when that 12 occurred? 13 A. I don't think there was a when. It was a 14 sometime yes, sometime no thing. I think we talked 15 earlier this morning about the production of HB-40, 16 when they went into production, more of it became a 17 raw material for the production of HB-40 versus a 18 waste. 19 Q. Okay. In reviewing documents, did you come 20 across anything that showed how often lead had to be 21 replenished into the, the preheater or the converter 22 lead pots? 23 A. No, other than the reference we talked about 24 earlier that measured--I didn't see any recommendation 25 on frequency or designation of frequency. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045737 140 1 Q. In reviewing the documents, did you come 2 across anything that would tell me the frequency of 3 pot failures, lead pot failures? 4 A. I don't recall anything specific, no. 5 Q. The furnaces that, that heat up these pots 6 of molten lead, was there, based upon your review of 7 documents, was there a stack that came off of those 8 filters ? 9 MR. JACOBS: Object to form. 10 BY MR. LANGLAIS: 11 Q. (Continuing) Do you understand my question? 12 MR. JACOBS: Do you understand his question? 13 A. Well, I think you mis--you mean off the 14 furnaces? 15 BY MR. LANGLAIS: 16 Q. Yeah. 17 A. Not off the filters? I don't recall. 18 Q. So in your review, does it--I guess what I'm 19 trying, I'm trying to picture these furnaces. Is this 20 like an open-pit fireplace? 21 A. My understanding from the documents is that 22 early on, they were direct-fired brick furnaces. 23 Later on, I believe, they were heated with a heat 24 transfer system, so a heating fluid would have been 25 pumped around coils around the pots to heat them. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045738 141 1 Q. At the time that these furnaces were still 2 used, these flame furnaces --strike that. We discussed 3 earlier that there was some reference to lead being in 4 the furnace, these furnaces. 5 A. I remember that reference, yes. 6 Q. Now, is there any--was there anything to 7 indicate that, that the lead was being burned up and 8 vaporized as part of, as part of the, the use of these 9 furnaces? 10 A. No, I saw nothing to reflect that. 11 Q. All right, let's move on to the second topic 12 that you were presented for. Now, it's my 13 understanding that you were--you have been presented 14 to testify about the, the products at the Anniston 15 facility that contained PCBs and the, the time periods 16 of each of those products; is that correct. 17 MR. JACOBS: Your Exhibit A, number 1, 18 "Identification of specific PCB conjuners and Aroclors 19 in periods of production." 20 MR. LANGLAIS: Right. 21 BY MR. LANGLAIS: 22 Q. A conjuner is just --I'll use an example. 23 1242 versus 1254, those are two different PCB 24 conjuners, are they not? 25 A. No, that is incorrect. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045739 142 Q. Okay, what is a conjuner? A. A conjuner, in the common scientific usage, is one of the 209 individual separate chemicals that comprise the set of PCBs, polychlorinated biphenyls. Q. Okay. Are you able to, to tell me what the first, what the first PCB or PCB conjuner that the Anniston Plant produced? A. Well, the Anniston Plant did not produce PCB conjuners Q. Okay. A. It produced products which were mixtures of various PCB conjuners Q. Okay. A. We never --and by that, I don't mean we made this conjuner, and that conjuner, and that conjuner. and mixed them together. Q. Right. A. We chlorinated biphenyl, which resulted in a mixture of conjuners, and that's what we manufactured as products. Q. So just as an example, I know that Monsanto produced Aroclor 1254; is that correct? A. That's correct. Q. And so that would be, that "54" designates the average percentage of chlorination in that, in Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045740 143 1 that product; is that correct? 2 A. That's correct. 3 Q. So it wasn't--it's not--it wasn't--it's not 4 saying that, that 54 percent of the, of the carbons 5 are chlorinated, it's saying the mixture consists of 6 what? 54 percent what? 7 A. Chlorine. 8 Q. Okay. On average? 9 A. On average, right. 10 Q. Okay, can you tell me what the first--well, 11 let's talk about what, just generally tell me what 12 PCB-containing products the Anniston Plant produced. 13 A. Well, it produced the whole series of 14 PCB-containing products, beginning with Aroclor 1221, 15 which was 21 percent chlorinated, through Aroclor 16 1268, which was 68 percent chlorinated, then there 17 were various products in between there, 42, 54, 60, 18 and others. 19 Q. Is there a document in the documents that 20 you reviewed in preparation for your deposition here, 21 today, that lists all the, all the Aroclor products 22 that the facility produced and the time frames? 23 A. Frankly, I didn't review any documents in 24 preparation for the PCB questions. I'm relying on my 25 institutional knowledge. I mean, I could list them Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045741 144 1 for you if you want them listed. 2 Q. The Monsanto plant produced Aroclor 1221? 3 A. Correct. 4 Q. Do you know from what, what time frame the 5 plant produced that material? 6 A. My understanding is it was produced from 7 early on in the process, beginning about 1929, through 8 1971, when the Anniston Plant quit making PCBs. 9 Q. And if I was to go and list other Aroclors, 10 would that be the same answer? 11 A. Yes. 12 Q. Now, there's Aroclor 1232 they produced? 13 A. Probably little of that. Most of that was 14 produced at Krummrich, frankly, actually. 15 Q. Aroclor 1242? 16 A. Correct. 17 Q. Aroclor 1248? 18 A. Correct. 19 Q. Aroclor 1254? 20 A. Correct. 21 MR. JACOBS: Just to be clear, are you 22 saying he's these were produced at the plant? Is that 23 your question which he's answering? 24 MR. LANGLAIS: Yeah. 25 MR. JACOBS: Okay. Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045742 145 1 MR. LANGLAIS: He was, he was put up to be 2 someone who could tell us -- 3 MR. JACOBS: Yeah, I know. It was a little 4 vague as to what was being asked. 5 MR. LANGLAIS: Okay. 6 BY MR. LANGLAIS: 7 Q. Aroclor 1254? 8 A. Yes. 9 Q. Aroclor 1260? 10 A. Yes. 11 Q. Aroclor 1262? 12 A. Correct. 13 Q. What other Aroclors were produced at the, at 14 the Anniston facility? 15 A. There was Aroclor 1268. 16 Q. Mm-hmm? 17 A. I believe Aroclor, Aroclors 1269, 70, and 71 18 were investigated as products but probably never 19 produced with any volume, represented volume at all, 20 and those were the PCB products, okay? There were 21 also a variety of polychlorinated terphenyl products 22 produced that had the Aroclor trade name, and there 23 were some products that were mixtures of PCBs and 24 PCTs, which are the polychlorinated terphenyls. 25 Q. Is there an Aroclor, is there an Aroclor Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045743 146 1 series that starts with 54? 2 A. Yes. 3 Q. And what is that? 4 A. Those are polychlorinated terphenyls. 5 Q. Okay, so although they're called Aroclors, 6 they're not the PCB products? 7 A. Right. Aroclor was the trade name for 8 polychlorinated polyphenyls. 9 Q. Okay. 10 A. Not just PC-------not just biphenyls. 11 Q. What's Therminol? What's Therminol? 12 A. Therminol is a Monsanto trade name for heat 13 transfer fluids. 14 Q. And those heat transfer fluids contained 15 PCBs ? 16 A. Some of them did. 17 Q. Can you tell me the names of the Therminol 18 products that contained PCBs? 19 A. Yes, any product that says "Therminol FR" 20 followed by a number contained PCBs. 21 Q. What's the "F" stand for, if you know? 22 A. "FR" stands for flame retardant, 23 fire-resistant. 24 Q. And how about Pydraul? 25 A. Pydrauls were--was the Monsanto trade name Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045744 147 1 for fire retardant hydraulic fluids. 2 Q. We've already discussed Montars 9 and 10. 3 A. Which were not chlorinated. 4 Q. They're not chlorinated? 5 A. Correct. 6 Q. Okay. Sanatowaxs R is not chlorinated. 7 A. That's correct. 8 Q. How long were the--was the Pydraul 9 manufactured? What's the, what's the operating time 10 for that, for that? 11 A. Okay, Pydraul was never, quote, 12 "manufactured." Pydraul is a blend-- 13 Q. Okay. 14 A. --of, in some cases, PCBs with other fluids. 15 Q. Okay. 16 A. In some cases, no PCBs, and it was not 17 blended at Anniston. 18 Q. Where was it blended? 19 A. Primarily, either at the Krummrich Plant or 20 the Queeny Plant here in St. Louis. 21 MR. JACOBS: Objection. You shouldn't make 22 that comparison. That's okay, go ahead. 23 BY MR. LANGLAIS: 24 Q. Well, I see the name "Pydraul" show up, and 25 I just want to--and what you are telling me is Pydraul Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045745 148 1 is not an Anniston product. 2 MR. JACOBS: Yeah. I didn't tell him not to 3 answer, but go ahead. 4 MR. LANGLAIS: Okay. 5 A. That, that is correct. 6 BY MR. LANGLAIS: 7 Q. Okay. 8 A. Now, again, I would clarify that some of the 9 PCBs that went into Pydrauls were Anniston products. 10 but-- 11 Q. Right. 12 A. --that, that packaged and-- 13 Q. The blending wasn't done, the blending of 14 that product wasn't done at Annniston,-15 A. That is correct. 16 Q. --that was done at another plant? 17 A. That is correct. 18 Q. Therminol VP-1, what does that contain PCBs? 19 A. No. 20 Q. How about Therminol 75? 21 A. No. 22 Q. 59? 23 A. None of the Therminols contained PCBs unless 24 they had the FR designation with the exception of 25 Therminol 77 had trace amounts of PCBs in it from the Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045746 149 1 manufacturing process. 2 Q. And Therminols were manufactured, as opposed 3 to being blended, or -- 4 A. Largely, that's true. I mean, the Therminol 5 FR series was just PCBs with a Therminol name on it. 6 Q. Are there any other Aroclor series, and by 7 that, I mean, you know, a starting number like the 8 Aroclor 12 series, is there another Aroclor series 9 that contained PCBs? 10 A. Yes. 11 Q. What series would that be? 12 A. Well, there is an Aroclor 1100 series, which 13 were the crude materials that were distilled to make 14 the Aroclor 1200 series. 15 Q. So Aroclor 1142 was distilled to make 16 Aroclor 1242, so you'll see that designation. The 17 same with the terphenyls; there was an Aroclor 5000 or 18 Aroclor 50 series was the crude chlorinated terphenyls 19 that were distilled to make the product Aroclor 5400 20 series. Okay? There were two others. There was an 21 Aroclor 2500 series and an Aroclor 4400 series which 22 were mixtures of polychlorinated biphenyls and 23 polychlorinated terphenyls. 24 Q. How long were the 2500 and--how long was the 25 2500 Aroclor series manufactured or blended? Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045747 150 1 A. I believe that was --I believe that was 2 blended pretty much through the whole '29 to '71 time 3 frame. I could be mistaken on that, but -- 4 Q. And how about the --I'm sorry, go ahead. 5 A. I was going to say the same would be true of 6 the 4400 series; they were very minor products, and I 7 don't know that production history, as well. 8 Q. How about the Aroclor 1100 series? 9 A. Well, that was always made -- 10 Q. Okay. 11 A. --because that's how you got to 1200. 12 Q. Right, and is there--am I--I thought I saw 13 something of an Aroclor 1000 series? 14 A. Okay, Aroclor 1016 is a unique product that 15 was manufactured only at the Krummrich Plant, and it 16 was manufactured very late, after 1971. 17 Q. Okay. Now, Aroclor 1221, am I correct that 18 it was the only Aroclor product formulated with PCBs 19 at the Anniston Plant? 20 A. That question doesn't make any sense to me. 21 Q. Okay, it says here --let me just go ahead and 22 hand you this document. I'm going to mark this as 23 Solutia Exhibit 12. 24 (Defendant's Deposition 25 Exhibit Solutia 12 mark'd Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045748 151 for identification.) MR. JACOBS: What part do you want him to read? MR. LANGLAIS: It is ADA 000271. (Witness peruses said document.) A Okay. BY MR. LANGLAIS: Q It's page 5 of this document. On the very bottom, there's a double asterisk A Yes . Q And it says Aroclor 1221 was the only Aroclor product formulated with PCBs manufactured at the Anniston Plant in 1971. A I see that. Q Okay, so, so would the other ones, is that just saying that the others were terminated prior to 1971? A Yes . Q And that that was the final, that was the final product, the final Aroclor that contained PCBs that was manufactured at Anniston? A That is correct. Q Now, are there any other, any other PCB-containing products either manufactured or blended Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045749 152 1 at the Anniston Plant that we haven't mentioned? 2 A. No. Well, yeah, let me correct, in that 3 there were some--we manufactured some PCB products 4 that we put General Electric and/or Westinghouse's 5 trade name on, but they were the same as our Aroclor 6 materials. 7 Q. So you basically took one of your Aroclors 8 and you just put on another trade name. Do you recall 9 what those trade names were? 10 A. Well, General Electric is Pyranol, 11 P-y-r-a-n-o-1. Westinghouse is Inerteen, 12 I-n-e-r-t-e-e-n, and most of those were blends of PCBs 13 with other materials, and sometimes we did the 14 blending ourselves. 15 Q. Do you recall any other instances where, 16 where you would take a Anniston PCB product and put 17 someone else's trade name on it other than those two 18 that you mentioned? 19 A. No, I have no--do not believe that occurred. 20 Q. Does the product called Sterox contain PCBs? 21 A. No--well, it was manufactured at Anniston. 22 No, it does not. 23 MR. LANGLAIS: I think that's all, that's 24 all you guys are putting him up for, is to do what 25 what he's just done, he's identified all the -- Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045750 153 1 MR. JACOBS: Well, basically after the last 2 comma on your paragraph 1, Exhibit A. 3 MR. LANGLAIS: Okay. 4 MR. JACOBS: Did you guys want to talk over, 5 see if anybody else has any-- 6 MR. TURNER: Why don't we just take a few 7 minutes. 8 MR. JACOBS: Five minutes? 9 MR. TURNER: Yeah, I think we can just clean 10 up there and see what-11 MR. JACOBS: See if you have any final 12 questions; maybe they have some questions. 13 MR. TURNER: I think that's probably more of 14 a coordinated effort that way, so it makes sense. 15 MR. JACOBS: Okay, we'll be back in five. 16 (Recess.) 17 BY MR. LANGLAIS: 18 Q. There is an Aroclor 1800 series, and I'll 19 just show you, this is part of the 1935 document. One 20 is Aroclor 1819, and one is Aroclor 1848. We don't 21 need to make these exhibits, but I'll go ahead and 22 read the--it's ADA 000884 and 885. 23 MR. JACOBS: And what's your question? 24 MR. LANGLAIS: Just this is a product that 25 we didn't mention this series, and I was just curious Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045751 154 1 about-2 MR. JACOBS: Are you asking if he's familiar 3 with these products? 4 MR. LANGLAIS: I want him to look at it 5 first and then I'll ask him, or you can ask him. 6 Either way. 7 MR. JACOBS: That's all right, thanks. 8 A. I'm not familiar with these products other 9 than the way they're described on the, on the 10 specification. 11 BY MR. LANGLAIS: 12 Q. So these-13 A. I haven't seen reference to them before, so 14 as far as I know, they were never significantly 15 marketed but they're, they're out of the, the 16 biphenyl--I mean the chlorinated biphenyl process, so 17 it says 1848 is a middle cut from the distillation of 18 Aroclor 1148, so it's, it's similar to 1248, and 1819 19 is a mixture of para and orthochlorodiphenyl, which 20 means it's very low chlorinated, so other than that, 21 I, frankly, don't know anything more about them. 22 Q. The only other thing I want to ask you is it 23 looks like there's a reference--do you see that? I 24 don't want to mispronounce it. Comatook (Phonetic) 25 and Wescott? Do you know what that might be? Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045752 155 1 A. Well, I would read it as Comstock. 2 Q. Comstock: Okay. I'm reading it upside 3 down. I didn't know if maybe-4 A. You know, I think that's the quality 5 control, I think that goes on to be the control test. 6 I think it's somehow how it's tested. 7 Q. Okay, so maybe-8 A. The grade is based on this Comstock and 9 Wescott C control test,-10 Q. Okay. 11 A. --but I don't know that specifically. 12 Q. Okay, and the last question, that 1935 13 document has a list of schedule of drawings, beginning 14 at page ADA 000894 through 896, and I don't think--you 15 can just glance at that. What I'm curious about is 16 have you seen the drawings that are referenced in this 17 1935 document? 18 A. No. 19 MR. LANGLAIS: Okay. 20 MR. TURNER: I don't have anything else. 21 MR. LANGLAIS: Anyone on the the phone have 22 any questions? 23 MS. O'NEAL: This is Lynne. None for me. 24 MR. JACOBS: I assume by nobody else 25 speaking, nobody else has questions. I don't have any Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045753 156 1 questions. 2 MR. LANGLAIS: All right. Thank you for 3 your time. 4 THE WITNESS: You are welcome. 5 MR. JACOBS: Okay. See you guys later. 6 Bye-bye. 7 MR. LANGLAIS: Bye-bye. 8 (Whereupon, at 2:11 P.M., the 9 deposition was concluded.) 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045754 157 1 State of Missouri. ) 2 ) SS. 3 City of St. Louis ) 4 I, J. Bryan Jordan, a Notary Public in 5 and for the State of Missouri, duly commissioned, 6 qualified and authorized to administer oaths and to 7 certify to depositions, do hereby certify that 8 pursuant to Notice in the civil cause now pending and 9 undetermined in the United States District Court for 10 the Northern District of Alabama 11 ,Magistrate Judge Green, to be used in the trial of 12 said cause in said court, I was attended at the 13 offices of Husch & Eppenberger, LLC, in the County of 14 St. Louis, State of Missouri, by the aforesaid witness 15 and by the aforesaid attorneys, on the 28th day of 16 April, 2005. 17 The said witness, being of sound mind 18 and being by me first carefully examined and duly 19 cautioned and sworn to testify the truth, the whole 20 truth, and nothing but the truth in the case 21 aforesaid, thereupon testified as is shown in the 22 foregoing transcript, said testimony being by me 23 reported in shorthand and caused to be transcribed 24 into typewriting, and that the foregoing pages 25 correctly set forth the testimony of the Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045755 158 1 aforementioned witness, together with the questions 2 propounded by counsel and remarks and objections of 3 counsel thereto, and is in all respects a full, true, 4 correct and complete transcript of the questions 5 propounded to and the answers given by said witness; 6 that signature of the deponent was not waived by 7 agreement of counsel. 8 I further certify that I am not of 9 counsel or attorney for either of the parties to said 10 suit, not related to nor interested in any of the 11 parties or their attorneys. 12 Witness my hand and notarial seal at 13 St. Louis, Missouri, this 10th day of May, 2005. 14 15 16 J. Bryan Jordan 17 Certified Court Reporter 18 State of Missouri 19 My License expires: January 1, 2006 20 21 22 23 24 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045756 1 Gore Perry Gateway & Lipa Reporting 2 3 4 Joseph G. Nassif, Esq. 5 Husch & Eppenberger, L.L.C. 6 190 Carondelet Plaza, Suite 600 7 St. Louis, MO 63105-3441 8 9 Enclosed please find the Original Signature pages 10 and errata sheets for the deposition of: 11 ROBERT G. KALEY, III taken 4/28/2005 in the case of: 12 Solutia, et al., vs. McWane, et al. 13 Please read your copy of the transcript, noting 14 any corrections on the enclosed erratta sheets, 15 and return all pages for filing in court to: 16 James A. Langlais, Esq. 17 Alston & Bird, LLP 18 1201 West Peachtree Street 19 Atlanta, GA 30309-3424 20 21 Your prompt cooperation will be appreciated. 22 Sincerely, 23 24 Gore Perry Gateway & Lipa Reporting 25 159 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045757 1 Page Line Should Read: 2 Reason for change: 3 4 Page Line Should Read: 5 Reason for change: 6 7 Page Line Should Read: 8 Reason for change: 9 10 Page Line Should Read 11 Reason for change: 12 13 Page Line Should Read 14 Reason for change: 15 16 Page Line Should Read 17 Reason for change: 18 19 Page Line Should Read 20 Reason for change: 21 22 Page Line Should Read 23 Reason for change: 160 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045758 1 Page Line Should Read: 2 Reason for change: 3 4 Page Line Should Read: 5 Reason for change: 6 7 Page Line Should Read: 8 Reason for change: 9 10 Page Line Should Read 11 Reason for change: 12 13 Page Line Should Read 14 Reason for change: 15 16 Page Line Should Read 17 Reason for change: 18 19 Page Line Should Read 20 Reason for change: 21 22 Page Line Should Read 23 Reason for change: 161 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045759 1 Comes now the witness, ROBERT G. KALEY, III, 2 and having read the the foregoing transcript 3 of the deposition taken on the 4/28/2005, 4 acknowledges by signature hereto that it is a 5 true and accurate transcript of the testimony given 6 on the date hereinabove mentioned. 7 8 9 10 ROBERT G. KALEY, III 11 12 Subscribed and sworn to me before this 13 day of ,2005. 14 My Commission expires 15 16 17 18 Notary Public 19 20 21 22 23 162 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045760 30(b) (6) Deposition of SOLUTIA, INC. 162 1 Comes now the witness, ROBERT G. KALEY, jH 2 and having read the the foregoing transcript 3 of the deposition taken on the 4/28/2005, 4 acknowledges by signature hereto that it is a 5 true and accurate transcript of the testimony given 6 on the date hereinabove mentioned. 7 8 9 ' (/ 10 ROBERT G. KALEY, L-E-T" JT _ 11 12 Subscribed and sworn to me before this 13 day of____________________________ ,22000055.. 14 My Commission expires 15 16 17 18 Notary Public 19 20 21 22 23 24 25 Gore Perry Gateway & Lipa St. Louis, MO (314)241-6750 621-4790 621-2571 621-8883 WATER PCB-SD0000045761 30(b) (6) Deposition of SOLUTIA, INC. 1 Page f Line of eAaes Should Read: _ j [[ fSfc 187 2 Reason for change: -fy^^PHlcAL ^oC 3 Page \ Line~7 Should Read : C & lA^j Q K)C WJr? 4 5 Reason for change: /J/y) Qj 6 7 Page I Line /^Should Read : Qp/~1T-E AAftfct, 8 Reason for change : t)Ce.) hftOhd 9 Page 10 Line _3 Should Read: ltd J po-fs 11 Reason for change: -y-j pTIOfJ 12 13 Page Line !P> Should Read : / p> ^yj 14 Reason for change: pnOA/ 15 16 Page^-^Line ) Should Read : (~PAA~f"OcxJ 3)CC.l? 17 Reason for change: 18 - ) i__ id19 Page (^3 Line (p Should Read : Clou y> 4" ^e36D R \*r 20 Reason for change : -^jP5 c - \fr?o$ 21 Page i^jhine^^ Should Read : \ JTy ) /rsp>u 22 2 3 Reason for change : T~(LA*VP70a/ 24 In 25 Gore Perry Gateway & Lipa St. Louis, MO (314) 241-6750 621-4790 621-2571 621-8883 WATER PCB-SD0000045762 30(b) (6) Deposition of SOLUTIA, INC. ________________ ___________________________________________ 1 Page |30,l in e }$ Should Read : baje_ h 2 Reason for change: 3 Ml4 Page Lin e Should Read : C<z7(ACj<3)9<?'P 5 Reason for change : ^3feuLf N6 6 ),, &>, 3 ; i e 7 Page /^f<3 Lin e/> Should Read: 17 CoOC]einzrM 8 Reason for change: ^ ?ZA-L > N & 9 10 Page)^ Lin e Should Read : 11 Reason for change: -j' fc A/</4e pnW 12 13 Page J^Ohin e ""~J Should Read: DS-i-CT]^, a&mNsA 14 Reason for change : -p vW3>Cfi-1 PL7/7/V 15 16 Page /(^C-Lin e2^)0 should Read: 17 Reason for change : IT 18 19 Page Lin e Should Read: 20 Reason for change: 21 22 Page Lin e Should Read: 23 Reason for change: 24 25 Gore Perry Gateway & Lipa St. Louis, MO (314) 241-6750 621-4790 621-2571 621-8883 186 WATER PCB-SD0000045763 I COURT MEMO 2. 34 5 Solutia, et al., vs. McWane, et al. 6 CV-03-PWG-134-E 7 8 CERTIFICATE OF OFFICER AND 9 STATEMENT OF DEPOSITION CHARGES 10 II DEPOSITION OF ROBERT G. KALEY, III 12 TAKEN ON BEHALF OF THE DEFENDANT 13 4/28/2005 14 Name and address of person or firm having custody of 15 the original transcript: 16 James A. Langlais 17 Alston & Bird, LLP 18 One Atlantic Center, 1201 West Peachtree 19 Atlanta, 20 21 GA 30309 22 23 24 163 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045764 1 ORIGINAL TRANSCRIPT TAXED IN FAVOR OF: 2 Wendlene M. Lavey 3 Squire, Sanders & Dempsey 4 4900 Society Center, 127 Public Square 5 Cleveland, OH 44114 6 Total: 7 1 ONE COPY - TAXED IN FAVOR OF: 8 Joseph G. Nassif 9 Husch & Eppenberger 10 190 Carondelet Plaza, Suite 600 11 St. Louis, MO 63105 12 Total: 13 1 ONE COPY - TAXED IN FAVOR OF: 14 James A. Langlais 15 Alston & Bird, LLP 16 One Atlantic Center, 1201 West Peachtree 17 Atlanta, GA 30309 18 Total: 19 1 ONE COPY - TAXED IN FAVOR OF: 20 D. Bart Turner 21 Maynard, Cooper & Gale 22 , 23 Birmingham, AL 24 Total: 25 1 ONE COPY - TAXED IN FAVOR OF: 164 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045765 1 Stephanie Rutledge (Butzel Lon 2 Unknown 3 UnKnown, UnKnown 4 UnKnown, 5 Total: 6 1 ONE COPY - TAXED IN FAVOR OF: 7 Timothy J. Kozik 8 Troutman Sanders LLP 9 600 Peachtree St, NE, Nations Bank Plaza, 10 Atlanta, GA 30308 11 Total: 12 1 ONE COPY - TAXED IN FAVOR OF: 13 Lynne Stephens O'Neal (Leitman 14 Leitman, Siegal, & Payne P.C. 15 600 North 20th Stree, Suite 400 16 Birmingham, AL 85203 17 Total: 18 1 ONE COPY - TAXED IN FAVOR OF: 19 Allison E. McAdam (Resolution 20 Resolution Law Group 21 3717 Mount Diablo Rd, Suite 200 22 Lafayette, CA 23 Total: 24 25 Upon delivery of transcripts, the above 165 Kaley, Robert; Solutia 30 (b)(6 ); McWane WATER PCB-SD0000045766 1 charges had not been paid. It is anticipated 2 that all charges will be paid in the normal course 3 of business. 4 GORE PERRY GATEWAY & LIPA REPORTING COMPANY 5 515 Olive Street, Suite 700 6 St. Louis, Missouri 63101 7 IN WITNESS WHEREOF, I have hereunto set 8 my hand and seal on this day of 9 Commission expires 10 11 Notary Public 12 13 14 15 16 17 18 19 20 21 22 23 24 25 166 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045767 [& -1993] Transcript Word Index & 1 (cont.) 1254 & 158:19 159:1 160:1 161:1 2:18 3:5,174:3,136:3 8:12 162:1 163:1 164:1,1,1,1,1 157:13 159:1,1,1,1 163:1 165:1,1,1,1 166:1 164:1,1,1,1 165:1 166:1 1,700 42:14 43:9,19 0 10 141:23 142:22 144:19 145:7 1260 145:9 1262 145:11 000271 7:20 81:11 112:25 133:8,13 1268 151:4 147:2 159:1 160:1 161:1 10:16 143:16 145:15 000632 162:1 163:1 164:1 165:1 1269 50:19 000639 53:21 000643 166:1 100 5:4 1000 145:17 127 4:15 7:19 164:1 13 83:1691:19 150:13 39:16 159:1 160:1 161:1 000698 92:18 95:7 000699 67:19 95:7 1016 150:14 104 16:24 53:3,5,9 106:23 162:1 163:1 164:1 165:1 166:1 13,500 16:12 000700 128:5 134:24 135:1,3 137:4 133 89:12 90:2 111:8 000703 69:18 000712 106 7:16 10th 158:13 7:20 134 1:4 2:8 163:1 136 115:22 000714 116:21 000884 11 7:21 7:21 136:13,18 159:1 160:1 14 161:1 162:1 163:1 164:1 108:11,17 159:1 160:1 165:1 166:1 161:1 162:1 163:1 164:1 153:22 1100 165:1 166:1 000894 155:14 000905 50:20 001050 149:12 150:8 1142 149:15 1148 154:18 15 159:1 160:1 161:1 162:1 163:1 164:1 165:1 166:1 150 7:22 127:17 001081 117 72:21 157 30:4 128:7 001090 127:17 12 16 7:22 39:16,19,20 72:21 159:1 160:1 161:1 162:1 73:17 87:7,8 88:10 90:8,15 163:1 164:1 165:1 166:1 002337 91:1,1,4,13 149:8 150:23 17 136:19 002352 133:16 00532 150:25 159:1 160:1 161:1 162:1 163:1 164:1 165:1 166:1 1200 159:1 160:1 161:1 162:1 163:1 164:1 165:1 166:1 17th 127:19 2:23 149:14 150:11 18 03 1:4 2:8 163:1 044183 28:22 1201 3:19 159:1 163:1 164:1 1221 143:14 144:2 150:17 159:1 160:1 161:1 162:1 163:1 164:1 165:1 166:1 1800 153:18 097 151:12 1819 132:4 1232 153:20 154:18 1 144:12 1848 1 7:11 9:21 28:18,22 30:16 30:20 78:11,25 113:4,4,8 141:17 148:18 153:2 1242 141:23 144:15 149:16 1248 144:17 154:18 153:20 154:17 19 159:1 160:1 161:1 162:1 163:1 164:1 165:1 166:1 Kaley, Robert; Solutia 30 (b)(6); McWane 190 2:18 3:6 159:1 164:1 1901 4:4 1917 66:11 1928 24:6 1929 33:25 38:4 39:13 58:3 98:11 144:7 1930's 40:17 1935 51:5 53:17 59:18,24 83:15 111:5 153:19 155:12,17 1936 136:20 1938 98:21 1940's 40:17 1947 98:22 1948 72:23 73:16 1950 41:3,4 106:19 107:22,23 108:10 1950's 35:18 1953 34:3 99:9 1957 99:16 100:1 127:19,20 1960 78:7 79:8 99:17 100:11 1961 24:9 58:5 80:11 1962 24:13 79:23,24 100:11 1964 24:7,9,14 38:4 39:13 58:4 79:25 136:20 1967 22:14 100:14 101:9 1971 144:8 150:16 151:14,18 1975 101:12,15,17,23 1980's 79:10 1990's 82:12 1993 28:24 29:9 WATER PCB-SD0000045768 [2-6] 7:12 30:6,8,24 159:1 160:1 161:1 162:1 163:1 164:1 165:1 166:1 2:11 2:21 156:8 20 58:1,12 114:8 159:1 160:1 161:1 162:1 163:1 164:1 165:1 166:1 200 5:4 6:15 65:24 165:1 2000 22:10,10 23:9 28:9 52:22 52:22 82:12 2001 28:11 2002 78:15,24 2004 2:22 53:6 73:7 106:22 135:1 2005 1:12 157:16 158:13 162:1 2006 158:19 202 6:8 30:17,21 31:10 78:17 205 4:7 6:9 205-251-5900 6:7 2400 4:5 248 5:6,7 25 159:1 164:1 165:1 166:1 250 65:24 67:9 2500 149:21,24,25 253- 8695 3:22 254- 1238 4:7 254-1999 4:8 258-1439 5:7 258-1616 5:6 279 99:10 28 1:127:11 283 97:12 284-0840 6:17 284-0870 6:18 28th 2:21 157:15 29 150:2 142:3 20th 6:4 165:1 21 143:15 159:1 160:1 161:1 162:1 163:1 164:1 165:1 166:1 216 4:17,18 22 159:1 160:1 161:1 162:1 163:1 164:1 165:1 166:1 23 159:1 160:1 161:1 162:1 163:1 164:1 165:1 166:1 23rd 72:23 24 85:17,24,25 88:12 106:4,8 106:9 159:1 163:1 164:1 165:1 166:1 3 3 7:13 50:13,19,22 51:4 83:15 88:20 89:7 96:2 97:14 111:3 115:20,21 159:1 160:1 161:1 162:1 163:1 164:1 165:1 166:1 3,000 91:16 92:2 3:30:53 32:19 30 1:142:167:12 11:3 22:2 23:1 92:4 120:6 30308 165:1 30308-2216 5:15 30309 163:1 164:1 30309-3424 314 462152 3:9 107:4 314-480-1500 462154 3:8 110:15 314-480-1505 462477 3:10 50:20 323-2197 462481 6:9 74:3,15 103:8,9 34 462484 74:10 104:10 35203-2618 462578 4:6 93:20 36 462620 73:20 50:21 3717 479-8545 6:15 165:1 4:17 4 4 7:14 11:12 12:6 50:13,20 72:18,19 91:5 103:8,24 104:10 159:1 160:1 161:1 162:1 163:1 164:1 165:1 166:1 4/28/2005 159:1 162:1 163:1 479-8780 4:18 480-1818 3:9 48304-2949 5:5 4900 4:14 164:1_______________ 5 40 5 81:22,23 82:6,13,18 139:15 7:15 69:20,22 89:7 91:6 139:17 103:24 151:9 159:1 160:1 400 161:1 162:1 163:1 164:1 6:5 67:8 165:1 165:1 166:1 404 50 3:21,22 5:16,17 7:13,14 108:9,10 149:18 41 5000 30:25 149:17 42 515 143:17 166:1 4400 5200 149:21 150:6 5:13 44114 53 164:1 100:1 44114-1304 54 4:16 142:24 143:4,6,17 146:1 462071 5400 122:16 149:19 462072 56.5 113:18,21 105:12,16 462073 59 123:12 148:22__________________ 462075 130:21 462078 125:10 130:2 462095 125:24 462098 127:1 6 6 1:142:167:16 11:3 22:2 83:10 106:14,17 113:17 120:6 122:14 129:25 159:1 160:1 161:1 162:1 163:1 164:1 165:1 166:1 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045769 [60 - alabama] 60 8 (cont.) able adheres 143:17 95:12,24 113:5,8 159:1 10:25 24:16 29:1,2 39:11 76:25 600 160:1 161:1 162:1 163:1 122:5 139:6 142:5 adhering 2:19 3:6 5:14 6:4 159:1 164:1 165:1 166:1 accurate 77:16 164:1 165:1,1 8,000 19:13 22:23 162:1 adjust 61 84:9,10 85:8 87:5,7 88:9,17 acetone 31:25 24:24 25:11 79:19 80:3 91:17 35:17 36:3,7 administer 62 800 acid 157:6 25:15 80:2,3 42:10 43:6 133:23 134:1,5,6,8 135:19 advising 63101 83 135:19 124:14 166:1 30:4 acknowledges aerial 63105 850 162:1 29:23 30:12 97:11 98:6 164:1 42:10 acquired aerials 63105-3441 85203 22:11 32:4 3:7 159:1 6:6 165:1 acted affirmative 64 881-7000 35:21 42:20 24:24,24 25:11 79:19 98:11 3:21 action aforementioned 643 885 67:7 158:1 83:17 91:20 153:22 actual aforesaid 65 885-3266 9:9 69:5 88:3,6 8:4 157:14,15,21 30:3 31:8 5:16 ada afternoon 68 896 50:19,19 53:21 67:19 69:18 115:7 143:16 155:14 83:1689:1290:1,2 111:8 age 69 7:15 698 92:22 96:2 699 92:22 96:24 7 7 7:17 83:10 97:10 98:5 107:6 159:1 160:1 161:1 162:1 163:1 164:1 165:1 166:1 70 145:17 700 66:23,24 67:3 89:19 90:1 166:1 7000278 98:21 71 145:17 150:2 75 148:20 750 42:10 77 30:3 32:17 148:25 78 85:6,8 89:2 8 9 9 7:1990:21 111:17 112:2,6 112:15,20,25 127:11,15 136:19 137:7,8 138:13,16 147:2 159:1 160:1 161:1 162:1 163:1 164:1 165:1 166:1 9:14 2:21 90,000 89:14,23 90:9,13,22 92:5 9205 4:8 925 6:17,18 93 7:18 94549 6:16 962-6622 5:17 97 7:17 986-5023 6:8 a a.m. 2:21 abandoned 116:21 127:17 128:7 133:15 136:19 151:4 153:22 155:14 adad 98:21 adad7-000040 30:1 adad7-000041 30:2 adad7-000278 97:12 add 121:25 added 35:1540:11 121:21 129:9 132:8 addition 23:14 86:19 additional 40:10 97:7 address 163:1 addressing 125:19 adem 23:13 28:5 52:22 73:7 adhere 55:4,7,15 56:3 76:11 adhered 62:3,17,19 63:3 adherence 8:2 ago 13:24 23:4 agree 28:24 57:21 58:14,20 59:1 63:2 71:2 72:8 73:11 75:23 81:13 87:17 104:25 106:7 114:15 119:21 agreeable 13:18 15:17 agreed 13:8 agreeing 91:25 agreement 158:7 agricultural 16:5 ahead 29:25 36:2 63:23 68:7 69:18,19 79:2 83:19 104:1 107:7 108:20,22 113:11 115:9 116:21,25 120:17 133:17 147:22 148:3 150:4 150:21 153:21 air 33:16 al 1:2,6 2:5,10 4:6 6:6 159:1,1 163:1,1 164:1 165:1 alabama 8 75:5 104:21 2:2 22:9 72:22 157:10 7:4,18 88:19 89:3 93:19,22 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045770 [alcohol - based] alcohol answer (cont.) arnette attached 35:15,20 36:5,6,11 40:19 53:7 73:24 76:20 20:2 28:4 53:8 algebra 91:21 92:8 95:19 102:19 aroclor attachments 59:13 111:23 120:11,17 144:10 10:16 45:10 98:25 99:4,6 73:10 allegedly 148:3 99:12 100:19 102:1 103:1 attack 14:17,18 answering 142:22 143:14,15,21 144:2 125:15 allison 144:23 144:12,15,17,19 145:7,9,11 attended 6:13 115:12 165:1 answers 145:15,17,22,25,25 146:7 157:12 allison.mcadam 158:5 149:6,8,8,12,14,15,16,17 attends 6:19 anticipated 149:18,19,21,21,25 150:8 83:8 allowed 166:1 150:13,14,17,18 151:12,13 attorney 132:17 anybody 151:21 152:5 153:18,20,20 22:2 111:4 158:9 alston 20:15 89:8 115:9 153:5 154:18 attorneys 3:17 159:1 163:1 164:1 anymore aroclors 17:8,9 38:10 157:15 158:11 alston.com 15:20 38:1 9:7 10:22 141:18 144:9 authorized 3:23 apparatus 145:13,17 146:5 152:7 157:6 ambiguity 54:2 arrive available 92:17 apparently 35:8 20:22 ambiguous 33:12 35:22 39:18 74:23,23 arrow avenue 87:11 appear 79:3 4:4 amount 71:4 ash average 25:16 45:24 55:10 56:1 appearance 46:17 142:25 143:8,9 57:22,23 58:6,15,17,20 115:17 aside aware 59:11 62:13,15 76:25 85:10 appearances 115:22 27:6 53:13 61:22 82:20 90:8 105:1 114:22 122:1 amounts 37:19 44:18 55:22 56:25 57:1 60:12,14,17 61:1,4 62:11,11,1864:18,1881:7 148:25 amsouth 4:5 analyses 61:5 analysis 46:11,1948:7,12 57:5 analyze 99:25 analyzes 105:11 anniston 8:25 9:8,10 10:6 16:25 18:14,15 24:6 35:9 36:15 37:20 39:12,25 52:3 59:19 65:16,18,19 66:19,20 67:6 67:10 72:22 125:13,19 131:17 134:2,24 135:14,21 141:14 142:7,8 143:12 144:8 145:14 147:17 148:1 148:9 150:19 151:14,22 152:1,16,21 annniston 148:14 answer 15:15 16:4 20:19 21:23 23:9 31:25 32:20 33:20 3:1 asked b appeared 71:10 15:17 37:13 104:19 145:4 asking back 23:12 28:16 47:6 67:17 appearing 4:12 5:2,11 6:2,13 15:3 86:9,10,11 87:2 91:9 100:2 119:3,12,13,15,17,22 68:13 75:6,20 78:2 83:14 90:18 92:8 97:8 110:15 appears 28:23 32:18 51:8 68:22 69:25 70:11 71:10 98:21 119:22 154:2 asphalt 102:20,23 116:1,4,18 121:17,18,23 129:25 130:20 131:21 135:18 153:15 101:23 107:22 109:3 appreciate assigned 11:18 background 10:12 11:1766:15,18,25 74:10 89:6 appreciated associated 10:9 11:25 32:10 108:23 67:4,11,15 bad 159:1 123:8 135:6,8 15:9 approximately 24:6 85:13 april assume 15:16 22:13 48:15 86:9 155:24 bail 132:18 bale 1:122:21 157:16 area 29:6,11 30:13 31:11 32:8 32:11,15,22 35:2 78:4,13 assuming 31:19 47:21 53:15 85:16 86:11 assumption 132:9,12 baled 130:24 131:7 bank 100:11,17 101:20 102:3,4,4 33:6 80:1 132:21 165:1 118:22 areas 114:19 argue asterisk 151:10 atlanta 3:20 5:10,15 159:1 163:1 bare 101:20 barely 9:12 79:15 120:1 164:1 165:1 bart arguing 75:21 atlantic 3:18 163:1 164:1 4:2 8:13,13 164:1 base arithmetic 59:15 atom 56:2 131:22 based arm 70:10 71:7 72:9 atoms 125:1,2 48:17,1749:11,1254:2 57:4 59:24 61:17 64:18 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045771 [based - capacity] based (cont.) best (cont.) block bryan 65:2 87:16,22 92:14 140:6 87:4,4,10,19 52:9 2:22 157:4 158:16 155:8 better bloomfield bubbled basic 87:21 89:10 115:16 5:4,5 39:1 59:13 94:24 107:19 big blow buford basically 74:8 116:1,4,18 124:15 52:10 10:20 14:5 31:21 32:8 biggest blowing building 48:25 49:18,20 56:13 60:1 113:25 123:15 124:4 14:20 32:10,13,16,22,25 78:24 84:10 91:25 96:3 binder blowouts 33:4,7,10,12 34:18,22 99:3 99:2 101:20 116:11 152:7 27:20,22 124:6 99:14 102:14 126:18,18,21 153:1 biphenyl blue buildings basis 16:18 18:4,9,18,1920:11 29:6 34:8 98:4 99:14 102:5 21:21 61:3 88:2 21:7,13,16 24:17 25:2,8,14 bob buildup bates 25:21 26:1,2,14,16,18,21 11:21,23 12:15 15:1321:20 75:7,8 30:1,2 50:19 94:10 97:11 27:7 29:12,16 31:21 32:6 boiler bunch 127:17 133:15 32:11 33:24 34:18,25 35:4 93:5 111:25 90:18 began 35:24 39:5 44:5 45:19,20 boilers burned 79:7 46:11 47:17,20 48:6,8,10 96:11 101:3 111:25 46:18 123:2 141:7 beginning 48:25 49:3,6,20,21 51:9,20 boiling burning 103:16 143:14 144:7 52:4 57:6,11,15 58:16,18 43:10,17,22 49:12 68:3 114:6 122:22,25 155:13 59:7,19 63:8,9,11,12,25 71:18 business begins 64:3,19,20 65:3 69:12,15 borders 16:5 166:1 114:2 72:22 73:12,17 75:9,9,10 30:21 butzel behalf 75:15 77:10 78:4 80:18 bottom 5:3 165:1 2:17 163:1 84:2,3,9,11,14,15,16 85:1,4 31:4 39:2 49:6 54:4 56:6,11 butzel.com belief 85:4,5,18 86:18 87:6,9,15 56:15 92:24 99:13 151:10 5:8 48:18 87:23 88:9,9,11 90:8,9 bottommost buyer believe 94:12,14 95:24 96:8 99:2 32:21 139:2 13:5 18:4,7 19:7,24 20:21 100:16 101:5 103:22 bottoms bye 22:19,21,22 25:25 27:12 107:13,20 113:6 123:25 45:18 48:5 49:22 69:1 81:2 156:6,6,7,7 30:13,25 31:8 32:13,16 124:7 127:19 128:13,16 81:4,5 96:10 111:25 113:13 byproduct 33:3,8,17 35:17 37:1 38:21 132:24 133:3 135:6,23 113:14 121:18 138:6,8,22 75:16 41:3,9,19,22 42:10,14 137:13,14,15 138:4,11 box byproducts 46:2347:8,1051:11,17 142:18 154:16,16 120:22 121:13 8:25 10:9 75:14 128:25 53:1,3,10 54:6,8,21,24 55:8 biphenyls 55:18 58:1 62:22,25 63:9 20:16,25 44:6 64:4 142:4 66:13 67:1,12 68:11 69:9 146:10 149:22 72:18 73:5,6 74:16 96:1,3 bird 106:24 112:2 118:3,11 3:17 159:1 163:1 164:1 128:4,14 134:8 136:1,22 birmingham 137:5,6 140:23 145:17 4:6 6:6 164:1 165:1 150:1,1 152:19 bit bell 63:23 112:9 129:4 37:12 blank benzene 78:13 35:8,11,15,24 38:16,24 bleed 39:1 42:4,6 43:25 44:7,9,11 11:14 45:5 46:9 49:18,20 60:11 blend 60:23 61:2,3 74:13 75:15 147:12 82:22 96:6,7 100:22 114:13 blended 114:14 117:13,14 118:18 147:17,18 149:3,25 150:2 119:5,9 120:19 128:18 151:25 benzol blending 92:23 93:5,14,15 148:13,13 152:14 best blends 20:18 22:10 23:4 33:13,20 152:12 branchfield's c 28:5 break 23:21 50:4 83:4 111:3 114:24 136:6 breakage ca 6:16 165:1 calculate 59:5 87:4,14,15,22 ralmlatinn 117:6 brick 140:22 briefly 57:19 58:17 call 51:12,14 78:22 80:6 111:17 119:16 17:7 called broad 77:6 brought 36:15,18 35:21 52:5 54:10 65:9 78:6 78:18 81:1,21,22 105:11,11 1465 15220 calling brown 48:25 88:17 132:12 9:8 10:10 11:4,17,23 17:7 17:10 19:6,21,23 20:17 calls 71:15 72:2,13 21:15,1922:11,16,1923:15 34:24 36:25 47:12 131:23 capacity 14:24 88:5,6,8,11 89:22,23 135:24 106:1,7,8 111:11 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045772 [capture - compound] capture 47:15 55:25 captured 47:4,21,22 55:24 56:1 car 35:9 carbon 44:20,21 53:24,24 54:4,10 54:13,18,22 55:1,7,9,15,19 56:3,7,10,12,17,20,22 62:2 62:7,10,13,16,19,19 63:4 74:17 75:4,7,8,11,13,15,21 76:3,11,14,18,21,25 77:8 77:12,16,19 104:13,20 105:3,11 111:13 122:22 carbons 143:4 carefully 157:18 carondelet 2:19 3:6 159:1 164:1 carried 53:25 case 1:4 2:8 8:4 12:21 13:25 14:1,12 15:7 29:24 69:10 87:4,4 99:13 103:24 112:3 157:20 159:1 cases 91:5 147:14,16 catalyst 35:25 catch 60:23 category 24:4 cause 157:8,12 caused 157:23 causes 49:10 causing 75:7 cautioned 157:19 ceiling 14:19 center 3:18 99:11,12 163:1 164:1 164:1 centigrade 42:11,14 cercla 106:22 cercla's 137:4 certain 8:20 51:1 62:11 77:20 certainly 26:9 32:11,14 59:3 62:14 64:24 123:9 124:23 certificate 163:1 certified 2:22 158:17 certify 157:7,7 158:8 champagne 70:8 chance 50:5,6 change 33:19 36:13 105:18 107:21 160:1,1,1,1,1,1,1,1 161:1,1 161:1,1,1,1,1,1 changed 16:13 34:2,22 125:4 characterization 61:4 charges 163:1 166:1,1 chatted 102:4 checking 90:18 chemical 8:24 33:23 44:25 chemicals 142:3 chemist 11:4 59:4 chemistry 65:2 chipped 121:17 chlor 44:5 chlorinated 51:5 64:3 113:6 142:18 143:5,15,16 147:3,4,6 149:18 154:16,20 chlorination 142:25 chlorine 143:7 circle 30:13 31:11 79:2 98:23 101:17 circled 29:6 32:22 101:20 circling 31:21 citrus 27:4 city 18:11 157:3 civil 157:8 clarify 73:23 74:9 91:21 94:19 102:19 148:8 clarifying 102:17 clean 62:2 70:21 109:5 111:2 153:9 cleaned 41:9,11 61:24 77:8 105:3,8 130:16 131:12,15 cleaning 77:3 cleanup 67:5 clear 9:21 10:15 51:19 86:22 89:25 90:21 91:7 94:4,5 98:19 102:14,14 105:25 106:14 120:9 132:10 136:5 144:21 clearer 89:2 clearest 32:20 clearly 9:16 33:7 60:22 109:25 121:10 Cleveland 4:16 164:1 clients 8:14 close 31:9 closed 79:9,10,11 coffee 50:6 coil 38:16 coils 140:25 cold 78:18 collect 69:7 77:20 collected 49:15,17,19,20,24 55:2 collected (cont.) 77:24 121:18 collecting 69:6,13 collection 69:5 76:21 collective 81:3 college 14:13 column 49:7,10,23 54:5 55:13,13 55:1656:4,6,9,11,11,13,18 62:21 63:13,16 68:15,18 77:2 82:23 93:10,11,13 96:4,14 104:16,21 105:8 137:17 138:17 comatook 154:24 combination 96:15 125:4 combined 125:5 coming 43:3 70:4 72:10,10 80:15 128:23 comma 153:2 commission 162:1 166:1 commissioned 157:5 common 142:2 companies 26:22,25 27:6 35:3 41:16 64:7 company 3:158:12 13:15,16,17 33:23 35:5 37:8,9,11,12 41:1366:9 112:17 121:12 166:1 comparison 147:22 complete 158:4 completed 32:3 completely 43:18 complies 30:15 101:19 components 129:14 compound 125:1 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045773 [comprise - crude] comprise 142:4 comprising 30:23 computers 128:24 comstock 155:1,2,8 conceivable 72:9,15 conceivably 106:8 concentration 46:14,16 58:19 59:10 105:16 concerned 87:1 88:15 concerning 16:20 conclude 138:17 concluded 156:9 conclusion 62:25 132:22 concrete 32:14 33:10 34:5 condensed 82:22 condensers 135:9 confirm 103:21 confirmed 32:9 conjuner 141:22 142:1,2,6,15,15,15 conjuners 9:7 141:18,24 142:9,12,19 connect 117:9,9 connected 112:20,23,25 connection 23:5 117:19 118:16 121:6 128:13 consider 57:1 58:22 72:25 considerable 76:25 108:12 considerations 36:9,10 consist 91:4,6 consisted 91:2 consistency conveniently correct (cont.) 92:6 54:1 137:16 141:16 142:22,23 consistent conversations 143:1,2 144:3,16,18,20 104:8 17:17 145:12 147:5,7 148:5,15,17 consisting conversion 150:17 151:23 152:2 158:4 111:12 35:24 42:8 43:18,25 44:4 corrections consists 45:22 46:9,13 47:16,24 159:1 18:25 39:5 143:5 48:6,10,19,21,24 54:14 correctly constituents 75:13,14 96:7 128:18 106:5 125:17 157:25 82:7 convert cost constructed 81:17,20 36:8 78:16,17,19 converted counsel consulting 49:11 3:1 158:2,3,7,9 15:22,24 16:4,8 converter country contact 19:3 39:9 43:24 49:10 66:21 135:12 54:19 62:17 75:12 76:17 county contacted 77:1 104:14 114:2,7 116:15 2:19 157:13 20:18 116:18,18 117:10 123:15 couple contain 123:23,23,24 124:5 139:21 17:22,24 19:24 92:18 93:17 24:3 45:24 49:3 55:9 59:22 converters 116:20 136:6 76:14,18 97:11 129:13 114:8 course 148:18 152:20 cooled 13:13 39:12 54:25 77:9 contained 135:14 86:2 94:20 97:17 113:2 48:19 54:22 55:20 56:22 cooling 124:20 166:1 62:11,15 63:19 76:21 82:3 135:9 court 105:19 141:15 146:14,18 cooper 2:1,22 15:2 157:9,12 146:20 148:23 149:9 4:3 164:1 158:17 159:1 163:1 151:21 cooperation cover containers 159:1 102:20,23 114:7 123:16,24 63:17 coordinated 123:24 125:13 containing 153:14 covered 143:12,14 151:25 copies 42:18 103:14 contamination 97:12 covers 129:8 copy 118:1 content 88:18,18 159:1 164:1,1,1,1 cracking 48:11 82:19 165:1,1,1 18:12 contents corporate craig 131:18 8:19 12:20,25 13:22 14:23 28:4 context 23:1 create 104:2,6 correct 64:4 84:25,25 continued 8:20 9:2 12:20,23 14:24,25 created 79:9 123:14 15:20,21,23,25 16:6,10 120:15 continues 17:15 18:20,23 19:1,4,22 critical 31:6 32:1 115:25 126:12 23:14 24:5 26:3,6,23,24 67:7 continuing 32:20 33:3,15 35:9,13 crosses 30:16 31:8 32:3 50:25 38:21 39:4,6,7,10 40:8,8 92:22 59:18 71:1 72:5 86:14 42:7,8 44:2 46:1 49:13 51:6 crude 87:13 89:1 93:24 94:24 51:7,10,11,22 54:6,8,9,17 45:19 46:11,18 47:20 48:4 113:12 114:21 117:22 54:23,25 55:13,17,18 61:10 48:5,6,6,8,25 49:3,6 57:6 127:23 140:11 62:22,25 63:14 65:20 73:18 57:10,15 58:16 59:6,8 63:8 continuous 73:22 74:13,14 75:12,25 63:9,11,12 64:19 69:25 106:3 76:2,9 80:16,19 81:11,15 84:3,11,14,15,22 85:4 87:6 control 84:7,24 85:13,16 87:9 87:9,15,23 90:9 106:3 155:5,5,9 88:12 94:18 99:6,7 100:13 132:24 133:3 138:2 149:13 convenience 100:16 104:3 105:5 106:11 149:18 110:18 112:2 113:15 118:3 124:2 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045774 [cup - distillation] cup defer described diphenyl 50:6 96:21 32:14 45:1,13 48:23 68:23 51:4,5,19 68:3,25 69:5,7 curbing define 69:4 70:2 91:1 132:19,20 71:19 73:13 83:15 84:1,2 34:11 26:10 154:9 84:10,21,22 85:10 89:22,23 curious definition describes 90:11,16 91:13 92:23 93:5 153:25 155:15 58:23 53:12 96:2 93:12,13 104:13 106:2,3,18 currently degrees description dipped 66:10 42:11,1443:6 8:23 32:25 51:14 52:1 54:7 129:9,11 curving delivery 104:8 direct 31:16 68:4,1671:19 117:15 165:1 descriptions 3:94:175:166:8 89:11 custody demolition 23:25 47:9,11 140:22 163:1 136:1 designated directing cut dempsey 8:18 123:19 45:6 49:21 101:11 154:17 4:13 164:1 designates directly cv department 142:24 113:2 1:4 2:8 163:1_____________ 22:9 72:21 90:17 designation dirt d danger 60:25 date 23:3 28:24 162:1 dated 32:18,19 53:5,17 72:22 106:18 127:19 daughter 115:15 day 2:21 23:11 84:10 85:10,17 85:24 86:1,5 87:8,16,23 88:10,12 92:2 106:4,9 157:15 158:13 162:1 166:1 days 86:15,24 88:12 92:4,11 deal 125:19 debris 108:12 decern ber 72:23 decrease 63:4 77:12 122:2 decreased 79:19 deep 108:11,17 defendant 163:1 defendants 2:11,17 defendant's 7:10 28:17 30:7 50:12 69:21 83:9 93:21 127:10 133:7 136:12 150:24 defense 4:1 8:15 depending 31:22 62:13 depends 117:4 depict 94:13 depo 16:16 23:14,17,23 134:23 deponent 158:6 deposed 14:22 15:6 deposes 8:4 deposit 54:15 105:11 deposited 54:18,18 deposition 1:142:167:108:20 12:19 13:13 16:22 17:15,18,20 22:2 28:17 30:7 37:14 50:12 69:21 83:8,9 85:15 93:21 124:21 127:10 128:2 133:7 136:12 143:20 150:24 156:9 159:1 162:1 163:1,1 depositions 157:7 deposits 104:14 depressions 117:25 118:12 depressurize 116:14 derivatives 51:5 describe 10:25 32:5 39:22 40:1 44:3 44:4 45:10,12 51:24 52:3 139:25 148:24 149:16 detail 24:19 details 18:24 35:7 detect 130:5 detected 47:20 67:10 132:24 determination 38:9 determine 21:5 46:6 61:20 64:12 devices 117:25 diablo 6:15 165:1 diagram 54:7 93:17 94:2,14 95:8,25 109:20 diagrammed 109:25 dibenzobenzenes 45:4 differed 74:4 difference 88:5 100:1,4 different 8:14 10:5 25:5 49:10,10 54:11 63:15,16 64:22 66:7 68:20 69:14 77:9 82:7 88:18 89:3 96:16,21 99:21 137:10 141:23 differently 77:11 difficult 23:8 52:7 digit 89:15 34:8 disagree 91:8 discarded 111:14 discuss 46:3 76:4 119:2 discussed 17:13 35:2 37:1 47:18 62:10 64:7 73:20 77:22 95:7 97:1,9 103:21 104:7 109:15 110:24 123:1 141:2 147:2 discusses 53:24 73:12 74:16 111:11 116:1 117:5 118:13,15 discussing 106:1 107:18 121:15 discussion 18:2 28:14 40:23 41:2 46:5 65:21 91:16 92:21 111:1 115:18 121:23 124:10 135:18 discussions 19:20,21 34:24 42:21,24 121:4 131:22 dismantled 34:18 79:25 105:3 disposed 47:5 distill 96:10 distillate 68:15,17,20 70:10 71:12,24 72:10 82:24 112:14 113:8 138:3,6 distillates 71:7 80:23 113:13 distillation 45:18,19 48:1 55:12 56:21 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045775 [distillation - exhibit] distillation (cont.) double eighty escape 63:13,16,20,24,25 65:3 151:10 96:1 125:12 68:12 70:18 85:12 154:17 downloaded either escaping distilled 22:20 9:15 20:9 25:17 47:9 114:6,14,16 84:2,15,23 85:5,10 87:6 dr 147:19 151:25 154:6 158:9 especially 137:15 149:13,15,19 15:11 50:17 electric 114:7 distilling drawings 152:4,10 esq 133:4 155:13,16 elements 3:3,4,16 4:2,12 5:2,11 6:2 distribution drawn 10:3 6:13 159:1,1 117:13 38:16 111:13 else's essential distributor drop 152:17 121:20 117:12 25:3 employed essentially district dropped 20:6 78:8 2:1,2 157:9,10 24:25 72:11 employee established divide dross 14:9 73:13 92:10 128:10,13,15 129:10,13 employees estimate divided ds 14:13 17:17 19:16 22:10 59:8 87:15,19 12:4 116:21 empty et division dsw 109:5 110:18 1:2,6 2:5,10 159:1,1 163:1 72:20 28:22 50:20,20 93:19 103:8 emptying 163:1 document 104:9,10 107:4 113:17,21 108:20 evaporated 28:8 34:3 50:24 51:24 52:2 122:16 123:12 125:10,24 enclosed 43:2 52:13,18 53:12,19 59:24 127:1 130:2,20 159:1,1 evolved 66:21 67:1,2,17,21 68:10 dturner encounter 122:21 72:19,19 73:3,11 79:22 4:9 17:1925:9 exactly 83:23 87:13,14 94:5,16 due ended 32:12 33:18 90:22 120:2 96:1,22 99:10,12 106:19,21 75:4 117:18 139:3 examination 107:10 109:1 110:10 duly ends 7:4 8:6 116:10 126:13 127:22,23 8:2 157:5,18 30:3 80:25 81:2 examined 128:1,7 131:24 133:15,20 dumped engineering 157:18 134:21 136:21,24 137:3,12 126:9 72:21 example 143:19 150:22 151:6,9 dumping entered 141:22 142:21 153:19 155:13,17 126:2 110:11 exceeded documentation e 121:14 124:5 p^rlipr documents 40:18 53:18 58:13 62:10 16:23 17:1,3 19:5,7,8 21:6 73:20 97:1,9 103:14,21 21:10 23:10,20,21,22 24:20 25:9 27:9 32:15,24 33:8 35:22 36:14,22 37:9 40:20 1047 19 106 1 13 10718 123:1 132:23 139:15,24 141:3 41:20 44:3 46:2,20 47:8 48:18 50:1,1,5 52:15 54:3 earliest 5311 60:22 61:17 64:10 65:23 67:1 73:8 82:6 87:22,25 early 40:16,16,22 58:7 140:22 90:25 91:7,25 93:25 95:20 144:7 96:20 106:21,25 109:15 111:17 112:7 121:3,5 122:4 126:8 134:10,22 139:6,19 easily 132:5 entire 43:21 68:8 86:1 92:13 entities 16:8 entitled 51:4 72:20 106:17 136:19 entity 13:18 16:2 entrained 56:20 108:11,16 109:4,6 environmental 22:9 epa's 16:24 eppenberger 65:22 exception 91:5 148:24 exceptions 94:19 exchanger 74:5,21,24 75:2,3 76:4 77:17 91:6 103:24 exchangers 74:11 75:7 77:14 excluded 129:5 excuse 9:12 136:9 exhaust 140:1,7,21 143:19,23 dodge 6:1 doing 69:13 door 120:23 121:13 79:1 educated 6018 effected 753 effort 38:8 61:20 153:14 2:18 3:5 157:13 159:1 164:1 equipment 54:12 errata 159:1 erratta 159:1 38:19 exhibit 12:9 28:18,22 30:6,8,16,20 30:24 50:18,20,22 51:4 52:24 53:2,3 69:20,20,22 72:18,19 78:2,11 83:15 93:19,22 95:12 96:2 97:10 97:14 98:5 103:8 104:10,10 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045776 [exhibit - frequency] exhibit (cont.) fairly first (cont.) 106:14,17 111:3 113:17 31:16 109:25 98:20 104:12 107:12 115:20,21 122:10,14 fall 116:15,24 117:3,4,5 130:9 127:11,15 129:25 130:20 24:2 131:6 134:13 142:6,6 133:8,13 136:13,18 141:17 familiar 143:10 154:5 157:18 150:23,25 153:2 37:18 107:8 118:25 128:12 fit exhibits 129:19 154:2,8 93:14,15 7:8,10 50:13,18 83:10 far fits 93:18 153:21 17:20 43:3 154:14 106:6 exist favor five 38:1,3 82:15,16 164:1,1,1,1,1 165:1,1,1 50:4 83:3 86:23,24 113:24 existence fax 136:10 153:8,15 21:1 79:12 3:10,22 4:8,18 5:7,17 6:9 fixed expect 6:18 61:1 61:11 62:18 71:22 77:8 fee flame 119:10 16:7 141:2 146:22 expected feel flames 105:23 19:12 22:15 50:25 92:12 109:6,10 experience figure float 21:25 109:16 53:25 expert filing floats 87:2 114:19 118:21 159:1 128:20 expires filling floor 158:19 162:1 166:1 70:8 132:3 32:14 34:4 121:16 130:24 extending filters 131:8 78:25 140:8,17 floors extent final 33:10 34:8 11:16 12:14 16:3 20:20 115:21 151:20,21,21 flow 24:15 30:12 31:15 76:13,15 153:11 93:17 94:2,12,14 95:8,24 90:20 94:4 118:23 120:18 finally 96:9,14 123:4 131:19 49:21 flue eyes find 38:19 89:10 27:15,16 62:18 85:25 126:7 fluid f 159:1 27:3 140:24 farilitatpri finding fluids 35:23 139:11 146:13,14 147:1,14 facility fine fmc 91 16 25 18 4 6 12 15 16 18:21 20:6,23 21:1,2,5 25:20 28:23 29:5,18 34:8 13:19 15:13,18 50:9 70:24 4:1 8:15 79:4 80:8 83:5 91:8 126:25 focus finished 76:5 107:12 35:9 36:16 37:20 39:12,25 41:11 52:3 57:15 59:19 64 8 661 3 6 9 87 24 112 5 112:5 125:19 129:10 68:8 84:25 85:1,4 103:13 108:24 133:18,21 fire 60:23,25 120:22 121:13 focused 100:7 follow 103:14 130:16 141:15 143:22 123:13,14 146:23 147:1 followed 145:14 fact 15:5,6 21:9 41:17 47:19 54:15 60:22 74:3 75:21 fired 140:22 fireplace 140:20 146:20 follows 8:5 105:12 foregoing 100:10 138:18 firm 157:22,24 162:1 failure 117:17,18,23 118:4 120:15 163:1 first form 43:21,22 45:19 53:24,24 12022 121 '6 failures 8:2,22 12:19,21,21,22,22 20:25 22:7,25 33:23 41:24 55:1,3 70:22 94:3 104:1 105:21 107:25 109:18 121:3,5 140:3,3 45:1749:1951:9 53:17 67:23 78:2 80:11 83:19,25 111:18 113:11 114:18 124:9 125:5,14,21 129:21 form (cont.) 131:3,13 134:15 138:5,20 140:9 formation 54:10 74:17 75:4,11,13,21 76:3,18,20 77:9,12 formed 44:21 54:14 56:17,19 77:20 80:18,22 104:13 128:15,17 former 17:17 19:15 101:21 forms 125:20 formulated 150:18 151:13 forth 157:25 foul 74:23 fouling 74:17 75:4,19 found 66:22 138:23 139:1 foundry 3:148:12 four 49:17 70:2,2 113:24 116:24 fourth 89:2 fr 146:19,22 148:24 149:5 fraction 46:17 69:12 81:4 82:25 112:13 fractionating 49:7,9 54:5 55:13,16 56:4,6 56:11,13,1762:20 68:15,18 77:2 80:22,23 82:23 93:10 93:11,13 96:4 104:16,21 105:7 fractions 49:17 68:20 69:14 72:10 112:11 138:3 frame 38:1,4 41:3,4 96:17 99:21 144:4 150:3 frames 143:22 frankly 37:18,25 95:18 143:23 144:14 154:21 free 50:25 frequency 121:10 124:7 139:25,25 140:2 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045777 [frequent - husch.com] frequent getting green heated 105:8 86:21 112:8 114:18 118:21 2:3 157:11 140:23 fresh give group heating 129:9 34:2 50:5,6 81:13 85:9,12 6:14 165:1 109:23 140:24 front 87:8 93:25 95:18 guess heavier 32:16 99:3 given 8:22 23:4 44:14 49:25 55:6 80:25,25 fruits 33:20 90:7 106:15 158:5 60:18 66:4 69:11 83:25 help 27:5 162:1 87:10 88:4,15 100:18 117:4 29:22 31:13 109:22 136:23 full giving 117:5 118:24 126:25 hereinabove 8:8 53:23 67:24 68:1 158:3 23:7 132:15 140:18 162:1 fungistat glance guessing hereto 27:4 155:15 132:13 162:1 furnace glasses guesstimated hereunto 141:4 70:8 57:20 166:1 furnaces go guys hey 129:20 130:7,10,14,17 27:13,15 28:12 29:25 36:2 136:7 152:24 153:4 156:5 115:14 140:5,14,19,22 141:1,2,4,9 56:15 62:2 63:1 67:17 68:7 h high further 63:1 79:1 124:10 158:8 future 49:1 __________________g___________ ga 3:20 5:15 159:1 163:1 164:1 165:1 gale 4:3 164:1 galvanized 97:4,5 aaos 70:14,14 71:2 gas 38:19 75:3 109:11 gaseous 56:14 125:8 gases 130:5 gasket 124:4,6,15 gaskets 123:15 gateway 159:1,1 166:1 gene 20:2 general 29:11 30:2 152:4,10 generally 78:12,13 143:11 gentlemen 20:9 geological 67:2 george 1:152:178:10 68:13 69:19 74:19 79:2 83:14,19 92:8,10 97:8 98:8 hand 27:19 28:21 29:1,23 50:17 24:21 42:15 65:24 93:5 96:6,11 101:3 111:25,25 104:1 106:14 107:7 108:20 108:22 113:11 115:4,9 116:20,25 120:16 125:3 93:16 94:11 106:16 127:14 133:12 136:17 150:22 158:12 166:1 124:15 134:11 higher 44:5,5 62:18 100:22 105:22 126:3 129:25 133:17,21 134:16 144:9 147:22 148:3 happen 15:2 highly 119:1 150:4,21 153:21 goes 49:6 84:22 121:23 135:18 happened 47:13 110:9,11 121:10 happens highway 30:17,21 31:10 78:15,17,24 hills 155:5 going 85:9 109:3 harbert 5:5 historical 9:8,22 10:1,2,4,8,10,14,15 10:25 11:5,14,19,21,24 13:12 15:1,1621:22 23:21 4:5 hard 90:21 9:11 historically 101:18 28:7,21 29:23 31:1,11,23 50:3,4,17 51:1 56:14 57:4 hate 129:24 history 8:23 9:6 24:17 26:1 77:10 63:23 67:17 69:18,20 89:13 90:18 91:24 92:1 93:16,16 hb 81:22,23 82:6,13,18 139:15 79:6 94:21 hit 121:8 150:7 93:19 97:8,9 98:16,23 139:17 121:16 99:11,13 100:17 106:16 115:9 120:1 129:3,5 133:12 134:17 136:17 150:5,22 head 42:20 43:2 heading hmm 59:10 145:16 holding good 15:9,10 31:10 49:5 88:24 114:23 gore 89:22 123:13 headings 93:2 heads 60:4 hour 85:17,24 106:4 hours 159:1,1 166:1 49:18 2:20 85:25 88:12 106:9 grab 28:2 50:6 grade 134:11 155:8 health 14:5 122:18 hear 9:13,15,15,19 housed 35:1 hundred 65:22 grassy heard huron 102:3 great 69:8 heat 5:1 husch 24:19 greater 27:3 40:4 74:5,11,21,24 75:1,2,7 76:4 77:13,17 82:1 2:18 3:5 157:13 159:1 164:1 124:4 91:6 103:24 130:14 140:5 140:23,25 146:12,14 husch.com 3:11,12 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045778 [hydraulic - justifications] hydraulic indication instructions jacobs (cont.) 147:1 34:25 121:11 122:5 125:18 23:16 72:1,6 114:18,25 115:3 117:20 hydrogenated 135:14 instructive 118:21 119:7,12,17 120:1,4 81:24 indirectly 73:1 120:6,9,11,16 122:10 113:7 integral 123:17 124:9 125:21 idea individual 77:19 129:16,21 131:3,13 134:13 37:5 75:5 14:24 142:3 integrity 134:15 136:6,9 138:5,20 identification 28:19 30:9 50:15 69:23 83:12 93:23 127:12 133:10 individuals 20:6 industries 59:21,23 60:1,3 interchangeable 73:14 139:8 140:9,12 141:17 144:21,25 145:3 147:21 148:2 151:2 153:1,4,8,11 136:15 141:18 151:1 identified 20:14 100:12 119:2 152:25 identify 3:148:13 inerteen 152:11 information interchangeably 13:8 51:21 interested 158:10 153:15,23 154:2,7 155:24 156:5 james 3:16 159:1 163:1 164:1 20:21 78:2 93:1 9:9,23 10:13,21 11:2,17 interjecting january ii 1:152:178:1,10 12:4 17:14 19:1321:21 88:15 22:19,22 24:3,12,20 25:12 internal 158:19 jerry iii 159:1 162:1,1 163:1 34:1,2,16 36:25 37:21 47:7 92:5 79:24 internally 9:8 10:10 11:3,17,23 17:7 17:10,13,19 19:6,21,23 illinois 26:16 52:6 immediately infrequent 105:9,10 ingot 26:20 interpretation 104:3 20:1721:15,1922:11,16,19 23:14 34:24 36:25 47:11 121:15 131:23 135:24 60:24 impractical 132:3 ingots interrogatories 8:5 jerry's 17:16 75:4 impurities 128:23 36:17,18,19 39:24 40:1 110:22 126:2,5,8 131:21 132:4,11,21 135:15 intervals 105:8,10 introduce jersey 14:1465:14 jim inches 108:11,17 initial 42:2 50:4 investigated 8:11 10:3 12:9 88:14 89:11 jlanglais incinerator 100:5 include injured 14:11,16,17,18 injury 145:18 involve 14:8,8 3:23 joe 9:16,20 45:2 included 14:1,9 inquiry involved joined 12:14 19:20 20:10 119:25 22:13 128:4 including 21:4 inserted involves 22:2 joints 60:8 125:13 48:10 86:5 117:25 involving jordan incorrect 17:20,23 141:25 increase inside 109:7 126:20 127:9 insignificant 9:1 11:11 iron 97:4,4 125:2,2 2:22 157:4 158:16 joseph 3:3 37:17 159:1 164:1 135:15 increased 107:23 index 64:24 installation 52:4 installed isopropyl 35:14,19 36:5,6 issue 74:8 124:11 joseph. nassif 3:11 judge 2:3 157:11 7:2 34:11 issues judging indicate 36:15,23 60:19 85:25 104:24 122:24 133:2 134:10 141:7 instance 81:20 107:21 instances 61:21 107:19 152:15 38:2_____________________ 47:19 j jacobs 3:4 83:7 84:17 85:21 86:8 jump 63:23 69:18 jumps indicated institutional 86:25 87:10 89:25 90:4,20 108:21,21 64:11 117:18 120:22 indicates 143:25 instruct 91:9 92:24 93:3 94:3,22 95:4,11,14,17 97:14,20 june 51:5 111:5 68:2 indicating 21:22 instruction 98:12 100:2 101:15 102:9 102:12,17 103:2,9,15 104:1 junior 14:13 30:17 78:14 83:15 105:21 107:25 109:18 111:5,18 112:8 113:11,25 justifications 36:13 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045779 [kaley - leaves] k known langlais (cont.) lead (cont.) kaley 22:6 125:12 114:23 115:1,4,8,14,19 58:18,20 59:6,22,23 60:12 1:152:178:1,10,11 12:19 knows 117:21 118:24 119:8,15,19 60:13,15,1961:2,4,5,8,12 15:11,11 28:21 50:17 119:3,13 120:3,5,8,12,20 122:11,13 61:20,21 62:12,17,18,20,24 115:20 159:1 162:1,1 163:1 kozik 123:18,22 124:12 125:23 63:3,19 64:12,15,17,25 keep 5:11 9:18,18 115:11 165:1 127:13,16 129:17,18,23 65:3,6 66:15,18 67:5,10,13 30:5 68:19 krummrich 131:5,14 133:11 134:19 73:20 74:8,11 75:6,10 key 144:14 147:19 150:15 136:8,16 138:7,24 139:9 76:14,18,22 77:1,1,13 78:3 4:14 1 140:10,15 141:20,21 78:4,8,23 79:13,19,22 80:7 kind l.l.c. 144:24 145:1,5,6 147:23 80:13 82:19 85:20 86:2,6 10:23 13:25 15:1 33:22 159:1 148:4,6 151:4,8 152:23 94:15,18 95:9 98:9 99:1 37:21 46:5 49:23 70:8 l.l.p. 153:3,17,24 154:4,11 100:8,11,15,23 101:2,14,24 101:11 103:21 135:5 4:13 155:19,21 156:2,7 159:1 102:15 104:15,15 105:7,12 kinds label 163:1 164:1 105:16,20 107:2,6,14,23,24 14:3 98:24 largely 108:11,16,16,20 109:4,4,6 kingdom labeled 24:2,3 149:4 109:7,11,12,23 110:1,2,6 18:22 21:10 50:19 51:18 97:11 98:20,21 larger 110:10,11,16,21 112:11,14 knew 118:24 119:4 99:8 101:21 111:11 127:17 128:10 133:15 107:14 largest 112:17,21,23 113:2,9,14 114:16 116:1,4,15,18 know labels 27:2 117:14 118:2,19 119:3,11 15:1,9 16:3 17:23,24,24 98:3,5 late 119:14,21 120:14,18,19,22 18:5,5,10 19:23,24 20:9 laboratory 79:10 150:16 121:7,8,12,20,25 122:1,1,5 21:9,14,15,1822:11 24:1 46:19 laughter 122:21,22 123:1,1,7,25 24:11,11,15,25 25:6 26:17 lackey 59:17 124:20,21,22,24,25,25 26:25 27:5,22 31:18 32:23 20:3 lavey 125:1,1,3,4,5,6,12,14,14,19 33:14 34:4,7,9,17 36:6,18 ladle 4:12 9:14 88:14,14,25 126:5,8 127:4 128:10,12,15 36:19 37:10 38:7,8,12 40:6 89:11,14 91:19 115:10 128:18,20,23,24,25 129:8,9 39:1940:15,1841:7 42:12 lafayette 42:25 44:15 48:9,14,15 6:16 165:1 164:1 law 129:10,11,13,13,19,20 130:5,6,10,15,24 131:7,11 49:14,16,24 52:17 53:7,7 landfill 6:14 165:1 131:15,18,19 132:2,4,8,11 53:14,16 55:21,22 56:1,5 62:9 77:23,25 78:7,9,16,18 lawful 132:17,19,20,24 133:3,23 56:22 57:2,4,12,17,18,19 78:19,20,22 79:5,6,8,8,9,12 8:2 134:1,11,12 135:7,14,21,22 57:20 58:5,6 59:10,11 61:1 80:5 62:6 65:7,8,12,14 66:8,15 landfilled layer 108:11,16 136:2 139:20,22 140:3,6 141:3,7 66:20 67:14,14 68:8 69:8 81:15,16 129:12 135:25 layout leading 74:2 77:18 78:12 79:23,23 139:4 28:23 109:24 80:1,3 81:8,10 82:17 83:1 landfills lead leak 84:13 85:3 87:21 89:6,9 78:3 91:15 92:9 95:6 96:16 97:4 langlais 11:7,11,22,22,24 12:14 16:19,20,25 18:3,6,8,10,11 60:6,8,1761:6 110:6 118:17,20 120:15 97:25 98:5 99:23,24 102:16 3:16 7:4 8:7,11,17 9:17,20 18:16,25 19:1620:7,10,15 leakage 102:23 103:13 108:3,15,23 10:8,14,19,24 11:6,10 12:8 20:24 21:6,10,16,19,25 117:18 118:15 110:1,2,4,5,7,9 114:12,21 12:10,16,18 14:21 21:22 22:6,12,16,20 23:1,5,17 leaked 116:3 117:8,11,22,23 118:8 22:4,5 27:13 28:12,16,20 24:5,17 25:8,13,16,17,18 60:10 119:9 121:9,11 126:10,19 30:10,19 31:2 50:3,10,16 27:11 29:3,7,18,21 30:14 leaking 126:20,25 129:9 130:16 69:24 70:24,25 71:17,22 31:20 32:12,14,21 33:18,24 60:20 131:1,4,17 133:18 134:4,5 72:4,16 83:3,13 84:20 34:12 36:15,19 37:6,12,14 leaks 135:5,8,13,22 136:23 137:1 85:23 86:10,13,21 87:3,12 37:16,20,23 38:6,13 39:2,3 60:23,25 137:25 138:1 139:11 142:21 144:4 145:3 146:21 87:20 88:21 89:4,13,16,17 90:2,6,24 91:11,22 93:1,4,7 39:13,23 40:4,7,10,11 41:25 42:12,12,21,23,25 learn 22:7 149:7 150:7 154:14,21,25 94:6,23 95:5,13,22 97:15 43:2,3,8,12,20,22 44:1 learning 155:3,4,11 97:16,22 98:2,14,17 100:3 45:21,23,24 46:3,6,8,10,14 20:23 knowing 100:6 101:16 102:11,13,21 46:16 47:4,4,5,13,14,15,15 leave 64:19 knowledge 102:22 103:3,5,7,10,11,16 103:19 104:4 105:24 108:2 47:21,25 48:4,10,19 49:4 29:22 75:11 132:4 51:10 53:12,25 54:19,22 leaves 21:1722:12 119:23 143:25 109:21 111:6,7,19 112:10 55:1,7,9,11,12,16,20,23,24 85:15 112:12 113:16 114:1,4,20 56:22 57:6,8,10,22,24 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045780 [leaving - mean] leaving little louder mark (cont.) 43:24 63:23 68:14 112:9 118:11 9:17 69:20 93:19 98:9 150:22 led 129:4 144:13 145:3 louis mark'd 135:19 lie 2:20 3:7 147:20 157:3,14 28:18 30:8 50:14 69:22 left 2:18 3:5 157:13 158:13 159:1 164:1 166:1 83:11 93:22 127:11 133:9 68:25 69:2 98:25 lip low 136:14 150:25 leitman 3:17 5:12 159:1 163:1 44:18 57:7,9 63:6 64:18 marked 6:3 165:1,1 164:1 165:1 105:20 154:20 30:20 50:18 72:17 93:17 letter locate lower 94:12 97:10 98:4 106:16 22:8 23:10,13 28:5 52:22 28:1331:5 101:13 58:8 107:5,5 127:14 133:12 letters located Ip 136:17,18 23:12 38:19 54:1,4 78:22,25 30:1331:12 101:21 marketed level location lsppc.com 154:15 24:25 25:2 63:3 66:19 67:5 27:10 29:2,19,21 30:21 6:10 marking 67:7 71:12 76:21 39:24 40:6 66:2,5 100:7 lunch 32:3 levels locations 97:8 111:3 114:24 marks 24:17 25:10 46:3,7 47:20 51:2 54:11 luncheon 30:22 47:22,25 48:4,14 49:4 57:6 logical 115:6 material 57:7,8,10 58:7,8 64:12 65:5 132:22 lying 26:2 49:15 57:23,24 62:7 65:22 66:15,22 105:20 Ion 130:6 62:11 63:12 64:6 68:16 license 165:1 lynne 70:4,19 72:11 77:22,23 158:19 long 6:2 115:13,14 155:23 165:1 82:19,21 105:19 125:8 life 5:3 22:6 23:6 66:1,8 147:8 m 128:19,22 139:17 144:5 40:15 41:5,19 78:8 149:24,24 machine lifespan 40:15,24 light longer 21:341:8 100:15 look 63'6 magistrate 2:3 157:11 139:7 likelihood 11:13 12:6 17:1 23:21 28:3 30:11 33:7 35:5 42:25 main 49:21 114:16 line 80:10,15 89:2 106:6 107:14 50:21,25 54:7 63:18 67:23 70:20 72:17 73:7 74:15 76:23 78:2 83:16 88:22,22 majority 765 makeup 160:1,1,1,1,1,1,1,1 161:1,1 89:18 92:18 94:13 97:18 1 pi pi materials 46:18 129:1 138:21 149:13 152:6,13 matter 12:11 matters 8:20 maximum 39:14,15,19,21 maynard 161:1,1,1,1,1,1 lined 135:19 lines 116:19 linings 133:23 lipa 159:1,1 166:1 liquid 35:8,11,15 38:16,25 60:15 list 143:25 144:9 155:13 listed 11:12 144:1 lists 143:21 litany 98:20 99:8 100:10,18 making 4:3 164:1 101:11,22 107:4 108:5 115:20,22 117:4 122:9 1207 1448 management maynardcooper.com 4:9 123:12 125:10 127:1 130:2 22:9 mcadam 154:4 looked 12:3 32:23 38:2 40:21 manner 4220 manufacture 6:13 115:12 165:1 mewane 1:6 2:104:1 8:16 159:1 46:21 53:15 61:19 looking 23:22 32:17 60:1 69:16 92:24,25 96:19 20:24 21:13 26:2,20 33:24 100:16 106:18 112:5 113:1 manufactured 10:1625:729:12,1565:13 163:1 mead 4:11 mean looks 65:16 101:24 142:19 147:9 12:11 13:7,14 23:8 24:10 27:14 32:9 52:7,9 70:3,7 84:8 88:23 89:3,7 92:22 93:4 107:13 118:9,10 123:13 154:23 147:12 149:2,25 150:15,16 151:13,22,25 152:3,21 manufacturing 8:24 10:12 23:15 46:24 25:15 31:15 33:7 39:2 41:1842:25 43:1,12,15,20 45:24 47:19 48:3,23 57:17 57:19 58:21 59:4 60:1,18 loss 51:25 127:18 149:1 65:12 69:1 70:20 71:1 61:12 119:10 120:14,19 74:20 75:2 77:10 78:12 11:10 literally 109:6 litigation 38:11 123:7 losses 61:20 85:12 119:3,5,10,14 lot 57:22 58:16 27:14 31:19,22 78:25 maps 27:10 31:19 mark 28:22 29:2 31:12,12 69:19 79:17,21 81:2 82:12 86:14 87:6 95:11 102:10,10 109:24 116:3,11 118:23 119:4,22 123:9,10 130:11 131:24 132:1,4,11 134:5 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045781 [mean - nov] mean (cont.) minutes montars near 137:22 138:1 140:13 136:7,10 153:7,8 80:17,20,22 81:9,14,19 132:5 142:14 143:25 149:4,7 mis 111:17 112:2,4,16,25 113:4 necessarily 154:16 140:13 113:8 147:2 25:15 meanings mislead month necessary 64:23 89:8 16:12 57:18 58:2,3 89:14 121:21 means mispronounce 89:24 90:10,13 92:4,5 necessitating 90:15 137:24 138:2 154:20 154:24 monthly 77:2 meant missouri 16:7 need 131:10 2:20,23 157:1,5,14 158:13 months 24:14 48:20 95:19 153:21 measured 158:18 166:1 23:4 77:4 105:4 needed 121:20 139:24 mistaken morning 132:8 measurements 150:3 139:15 new 63:21,22 misunderstood mount 13:17 14:13 16:1,1,5 65:14 measuring 11:6 6:15 165:1 80:14,14 107:13 132:6 117:25 mix mountain newport melt 49:20 78:19 18:6,21 20:23 21:5 38:12 39:25,25 40:5 109:7 mixed move nine melted 142:16 67:1891:8 141:11 86:23 40:4,9 110:21 132:7 135:22 mixture moved nods 135:25 45:13 46:13 142:19 143:5 71:11 132:16,18 42:20 melting 154:19 moving non 109:12,24 110:11,17 123:5 mixtures 68:19 26:22 74:24 77:17 135:12 memo 142:11 145:23 149:22 msds nonchlorinated 163:1 mm 82:6,12 113:1 memory 59:10 145:16 multiply noncontact 17:16 130:13 mo 58:18 135:11 mention 72:5,7 74:1 153:25 mentioned 16:9 37:8 71:25 116:23 117:3 152:1,18 162:1 metadiphenyl 44:9 metallic 125:5 129:6 metals 46:19 mi 5:5 mid 35:18 middle 154:17 million 24:21 57:13,18,25 58:1,12 58:15 66:23,23,24 67:3,8 mind 51:23 124:21 128:22 157:17 minimally 79:21 minor 17:22 150:6 minute 21:20 50:4 83:3 3:7 159:1 164:1 n nondetectable molds name 65:5 110:18,21 132:3,3,5 molec 124:25 8:8,11 20:4 37:15 45:7,10 52:8,12,14,20 65:12 137:7 137:10 138:1 145:22 146:7 nondistilled 84:5,6 normal molecule 56:1 64:17 124:25 146:12,25 147:24 149:5 152:5,8,17 163:1 166:1 north molten 39:2,23 41:25,25 59:23 names 19:24 20:1,19,21 35:6 4:4 6:4 165:1 northeast 122:1 128:20 130:24 131:7 41:15 44:25 66:7 146:17 5:14 140:6 moment 63:18 83:15,17 monsanto 13:5,11,14,15,21 14:2,6,6,9 16:1,5 18:3,8,10 19:15 20:14 26:7,22 28:23 29:24 152:9 nassif 3:3 9:5 10:1,10,18,20 11:2 11:9,13,16,21 12:2,6,9,13 12:17 14:1721:20,24 27:15 27:19,24 50:9 70:22 71:15 71:21 72:2,13 83:5 85:15 northern 2:2 157:10 notarial 158:12 notary 2:23 157:4 note 162:1 166:1 35:4,4 37:6 38:1 41:11 45:9 159:1 164:1 108:19 46:6 48:9 61:18,19,19 63:18,23 64:7,10,11,25 66:2 82:17 86:14 106:22 119:22,23 121:25 122:5 national 37:12,14,16 nations 165:1 notice 11:12 157:8 noticed 121:2 133:2 142:21 144:2 146:12 nationsbank notified 146:25 513 22:25 monsanto's 16:25 53:9 montar 111:17 112:6,13,15,20,20 136:19 137:8 138:13,16,21 natural 109:11 ne 165:1 noting 159:1 nov 108:10 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045782 [november - paradiphenyl] november occurring olive orthodiphenyl 106:19 108:9,10 54:10 79:13,20 166:1 44:7 nozzle occurs once outer 71:23 129:8 13:1,3 63:15,15 75:11 87:1 125:15 ns October 109:3 output 31:1 52:22 53:5 o'neal 48:24 number officer 6:2 115:13,16 155:23 165:1 outside 11:12,18 12:6 25:14 30:2,6 163:1 ones 37:4 125:14,20 126:21 39:15,17,18,21 45:15 58:21 offices 41:21 151:16 owned 58:23 59:1 72:21 81:13,13 2:18 157:13 open 66:7 87:8 88:16 89:14 90:22,23 officially 32:8 33:16 61:21 140:20 oxide 92:11 94:7,10 105:22 107:6 24:1 opened 124:22,24,25 125:2,3,14,15 113:5,19 141:17 146:20 oh 61:8 121:20 125:20 149:7 4:16 83:18 116:6 126:4 operate oxygen numbers 164:1 88:11 106:9 125:1,2,5 129:4___________ 24:20 30:1 57:17 58:1 okay operated 60:21 66:21 85:8 87:16 11:6,20 12:1,5,6,16,17,24 24:6,9 86:18 88:2,3 91:5 92:10 103:24 13:2,6,20 14:11,15,22 15:5 operating numerical 15:9,12,14 16:13 17:5 19:5 23:16 24:2 31:20 56:14 61:5 20:1 22:4 26:21 27:13,24 66:9 86:15 90:14 130:24 o 28:6 29:1,5,17 31:3 32:3,23 131:8 147:9 oaths 35:14 37:19 38:22 40:5,23 operation 157:6 object 41:1,4,7 42:5,9 43:5,11,19 18:13 24:24 31:21 79:6 45:9,16,17,21 47:1 48:3,13 80:4 85:18,18,22 90:12 21:21 70:22 94:3 104:1 105:21 107:25 109:18 111:18 113:11 114:18 48:22 49:2 50:3,8,10 51:3 106:4 51:11,13,16 52:14,24 53:2 operations 53:20,23 56:16 57:14 66:8 8:23 124:9 125:21 129:21 131:3 131:13 134:15 138:20 66:18 67:22,23,25 68:11 opine 71:21 72:8 73:11 74:6,19 119:13,16 140:9 objection 71:15 72:3,13 84:17 85:21 74:25 78:10,15 80:12,21 opining 81:5,19 83:14,24,25 84:6,8 119:20 85:7 88:4 89:5,8 90:4,7 opinion 86:8,25 87:10 90:20 94:22 102:9 112:8 118:21 119:12 91:18,21 92:16,16,20 93:3 87:2 94:13 105:19 93:14 95:23 96:12 97:13 opportunity 120:16 138:5 139:8 147:21 objections 98:12,14 99:10 100:23 97:18 110:5 101:6,8,20 102:7,21 103:20 opposed 158:2 104:2,5 105:6,18 106:12,14 21:19 73:1 84:3 125:8 observed 121:16 obviously 107:12,18 109:2,3 110:20 111:9,10 112:16,20,24 113:22 114:25 115:24 149:2 opposite 116:17 9:22 11:14 21:2 29:9 39:24 45:23 49:3 96:21 99:24 occasionally 60:7,9 125:20 131:12 116:3,20,22 117:2,16 118:7 oral 120:3,5,8,21 122:15,17 8:5 124:24 125:7,11,25 126:4 order 127:3 128:1,9 129:2,24 69:15 70:19 109:5 116:12 occasions 130:2,3,8,22 131:25 133:22 116:14,17 12:24 occur 75:16,17 101:17 occurred 134:4,14 136:4 138:10 organic 139:19 142:1,5,10,13 143:8 100:5 143:10 144:25 145:5,20 orient 146:5,9 147:6,11,13,15,22 31:4 27:11 29:3 30:14 34:12 148:4,7 149:20 150:10,14 original 39:23 40:1,3 78:5 86:1 98:10 101:14,18 124:6 150:17,21 151:7,16 153:3 159:1 163:1 164:1 153:15 155:2,7,10,12,19 originally 136:2 139:12 152:19 occurrence 156:5 old 48:23 orthochlorodiphenyl 121:9 13:15 133:22 134:5 154:19 P p.c. 4:3 6:3,14 165:1 p.m. 2:21 156:8 packaged 148:12 packed 132:7 packing 27:4 page 52:8 69:18 74:2,15,16 83:16 89:19 91:14 92:18,25 96:2,24 99:11 104:9 108:21 109:19 111:8 113:17,19 115:22,25 122:16 125:10 128:7,8 130:2 132:4 133:15 136:18 151:9 155:14 160:1 160:1,1,1,1,1,1,1 161:1,1,1 161:1,1,1,1,1 pages 92:19 93:1 116:20 130:20 157:24 159:1,1 paid 16:6 166:1,1 pan 68:4,17,19,24 69:7 70:3,11 71:13,20 pans 69:9,15 70:2,13,13,14,20 71:3 72:12 96:25 97:3,4 paper 12:3 paps 135:22 para 154:19 paradiphenyl 44:11 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045783 [paragraph - possibility] paragraph pcbs phase plant (cont.) 53:23 67:24,24 70:3 76:24 9:1 14:6,19 21:3 26:2,20 43:18 56:14 66:10 67:10 72:22 86:15 83:20 90:3 103:13 104:12 27:7 33:17 38:2 45:10 64:8 phelps 103:1,1 134:2 135:14,21 106:2 107:16 111:10 64:21 65:3,7 82:3 141:15 6:1 142:7,8 143:12 144:2,5,8 113:24,25 114:1,2 115:24 142:4 144:8 145:23 146:15 phenyl 144:22 147:19,20 148:16 116:7 117:5 123:14,19,21 146:18,20 147:14,16 148:9 33:14 47:17 84:2 150:15,19 151:14 152:1 126:1,3 127:2 130:11 131:9 148:18,23,25 149:5,9 phone plants 132:9 134:13 153:2 150:18 151:13,21 152:12 29:25 30:20 115:8 127:16 18:8 26:8,13 65:14 paragraphs 152:20 133:14 155:21 plasticizer 107:7,11 108:22 116:24 pets phonetic 14:19 82:2 parkway 145:24 154:24 play 5:4 peachtree phosphate 94:2 95:7,8 part 3:19 5:14 159:1 163:1 72:20 played 11:7 15:6 18:1220:15 164:1 165:1 phosphoric 109:11 32:16 35:16 38:22 49:9 pen 134:8 plaza 52:21 68:12 77:19 80:17,18 29:2 photo 2:193:64:55:13 159:1 81:3 89:18 92:25 93:10,24 pending 31:13 32:24 102:12,13 164:1 165:1 93:24 96:5 98:24 101:25 95:3,4 157:8 photograph please 106:21,22 112:13,17 124:7 people 98:25 99:19,25 8:8 15:15 50:21 159:1,1 129:20 134:12,25 135:23 20:18,22 29:25 30:19 35:23 photographs pleased 137:3,23 138:4 141:8,8 47:11 121:15 29:23 30:12,23 31:7 32:2 115:17 151:2 153:19 percent 97:7,11 98:6 plug partial 46:17 81:11 85:6,8 105:12 photos 54:1 103:12 105:16 143:4,6,15,16 103:2 plugged particular percentage physical 105:2 10:22 52:24 61:6 128:9 81:8 84:13 85:3 96:6 125:4 plus 136:21 142:25 picture 125:2 particularly perform 69:19 70:1 98:9 99:8,18 point 104:12 127:1 16:7 140:19 13:1231:10,11 33:1334:11 partied performance piece 35:14 42:12 43:10 49:5,12 14:2 65:6 34:16 51:1 53:18,20 59:25 63:5 parties 158:9,11 performed 33:1 pig 134:11 67:16 68:3 69:11 71:18 78:1,15 80:21 82:17 88:24 partly period pipe 107:13 118:25 124:13 104:13 9:7,11 10:5,7,16,1725:11 3:148:1238:1668:4,16,18 130:5 132:13 138:22 139:7 parts 25:11 98:10 70:4 71:19 104:14,15 117:5 points 9:3 57:12 58:15 66:22,23 periods pipes 17:22 18:1 19:11 66:24 67:3,8 77:20 8:24 24:14 141:15,19 54:11,16 76:25 77:3,8 polychlorinated pass perry 105:2 117:8,9 135:21 64:4 142:4 145:21,24 146:4 44:1 45:23 159:1,1 166:1 piping 146:8 149:22,23 passed person 54:19 55:12,15 62:3,20 polydiphenyl 46:10 163:1 75:24 76:7,12,17,19 117:11 45:5 passing personal pit polymerized 45:23 14:1 140:20 44:6 pause personally place polymers 103:4 19:17 32:6 33:23 57:7 86:7 102:2 100:22 payne peruse 102:3,8,15 132:6 polyphenyl 6:3 165:1 31:7 32:2 126:13 placed 81:24 100:19 113:1 pc peruses 126:9 polyphenyls 146:10 30:22 50:23 67:20 68:9 plaintiff 101:3 146:8 pcb 83:22 107:9 108:25 116:9 3:2 portion 9:6,6,23,24 10:2,6 26:13 127:21 133:19 151:5 plaintiffs 32:22 34:17 80:22 32:11 34:14 64:11,15,25 petroleum 2:6 positive 141:18,23 142:6,6,8,12 18:12 plant 31:18 143:12,14,24 145:20 146:6 Pharmacia 9:8,24 10:6,12 11:23 22:13 possibility 151:25 152:3,16 13:17 15:24 26:15,15,17 38:12 52:5,6 106:10 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045784 [possible - pumped] possible prefractions probably produced (cont.) 139:11 69:6 43:2 49:5 59:14,14 60:12 82:9 84:15 85:10 87:16,23 possibly preheater 61:13 64:22 65:4 68:24 88:1 92:10 103:6 106:22 62:15 19:2 39:8 74:5 76:6,16 95:19 96:9,14 114:23 137:3,18 138:13,19 142:7 pot 116:16,19 117:9 139:21 144:13 145:18 153:13 142:11,22 143:12,13,22 11:8,11,22,22,24 12:14 preheaters problem 144:2,5,6,12,14,22 145:13 16:19,20 18:3,6,8,10,11,16 42:3 75:19 77:16,18 119:6 121:7 145:19,22 19:3,16 20:7,10,15,24 21:6 preheating 124:6 produces 21:10,16,19,25 22:6,12,16 74:12 procedure 92:1 22:20 23:1,5,17 24:5,18 preparation 51:25 132:16,18 producing 25:8,13,16,17,18 27:11 17:5 143:20,24 procedures 18:9 57:22,24 58:16 84:9 29:3,7,18,21 30:14 31:20 preparatory 23:16 24:2 46:24 product 32:15,21 33:18,24 34:12 52:4 proceeding 22:3 26:5,21 48:7,24 65:9 39:9,13 41:18 42:6 43:24 prepare 133:4,4 65:13 68:16,17 71:24 72:10 51:10 53:12 59:21 62:17 16:19 23:6,10 136:23 process 81:18,20,21,24 82:9 84:2 67:13 75:10,18 78:3,4,8,23 prepared 9:9 10:2,25 11:4,5,8,11,15 85:1,1,4 133:5 138:18 79:13,20 80:7,13 85:20 52:3,17 11:18,22,22,24 12:14 16:19 143:1 146:19 148:1,14 86:2,6 94:15,18 95:9 98:9 preparing 16:21 18:3,8,10,11,14,15 149:19 150:14,18 151:13 99:2 100:8,11,15,24 101:14 23:17,23 46:21 107:1 128:2 18:16,17 19:1620:7,10,15 151:21 152:16,20 153:24 101:24 102:15 107:2 134:23 20:24 21:6,11,16,1922:1,7 production 109:11,12,24 110:12,17 present 22:12,16,20 23:2,5,17,25 8:25 9:6 16:18 20:11 24:16 112:11,14,17,21,23 113:2,9 17:9 129:19 24:1,5,18 25:5,7,8,13,16,17 24:22,25 25:2,10 34:18 113:14 114:7,15,17 116:19 presented 25:18,18,19,23 27:11 29:3 39:19 59:6 78:4 80:13,18 116:19 117:10,14,19 141:12,13 29:18,21 30:14,25 31:20 82:18 86:23 88:3,6 92:10 118:16 119:21 120:21 pressure 32:6,11,15,21 33:1,16,18 94:14 128:5 135:6 136:20 121:2,5,6,7,8,19 123:5,23 42:15 116:17 124:14 33:24 34:12,14,25 35:7,16 137:13,14 138:9,16 139:15 125:14,15 127:8,9 129:9,20 pressurized 38:23 39:13 40:3 45:18 139:16,17 141:19 150:7 132:6,7,16,18 134:12 135:7 42:17,19 116:13,13 47:3,9,10 48:1 50:1 51:9,10 products 136:2 140:3,3 presumably 51:15 52:4,5 53:12 54:9,12 8:24 9:10,24 10:4,6 14:6,7 potential 44:18 56:12 57:20 60:11,14 54:14,16 56:21 62:14 63:1 26:14 43:25 44:4 45:22 119:2 120:19 123:10 139:2 82:15 86:4,9 87:1 110:7 63:4,5 67:13 68:12 70:19 46:10 47:16,17,24 48:10,19 potentiometer presume 70:21 71:23 73:12 75:14,22 48:21 49:11,11 63:16,20,24 68:2 137:13 77:10,19,21 78:4,8,23 63:25 64:12,15,25 82:22 pots presuming 79:13,20 80:7,7,9,13,15 96:7 129:6 141:14,16 18:25 19:2 32:12 39:2,6,8 69:8 85:20 86:1,2,6,24 88:11 142:11,20 143:12,14,17,21 40:3,4,7,9,13,16,24 41:5,8 pretty 92:13 94:14,15,18,24 95:8 145:18,20,21,23 146:6,18 41:17,23,24 42:18,22,23 9:16 24:12 32:8 58:8,19 95:9 98:10 99:2,2,4 100:8 148:9 150:6 151:25 152:3 43:1,3,4 47:6 59:22,22,23 77:6 150:2 100:15,24 101:5,14,24 154:3,8 60:3,20 61:8,24 73:20,21 previous 102:1,15 103:23 106:3,17 promoter 74:5,8,11 75:6,25 76:6,6 16:22 17:15 37:14 91:14,15 107:2,20 110:3 112:11,14 35:21 36:3 77:13 79:22 101:2 103:23 92:8 112:18,21,23 113:2,7,9,14 prompt 103:25 110:19 116:15 previously 118:25 119:1,21,24 121:7,8 159:1 117:10 118:1,2 121:18 73:4 121:24 123:8 124:1,8 propounded 122:1 123:25 125:13,20 primarily 127:19 128:13,16 129:20 8:5 158:2,5 128:18 129:11 130:15 23:19,24 38:24 45:3,6 82:1 133:1 134:7,8,12 135:5,6,7 proved 131:11,15,18,20,21 132:2 118:18 147:19 135:23 136:1,2 138:4 144:7 75:3 139:22 140:5,25 principally 149:1 154:16 provided pounds 111:13 processes 17:15 19:9 73:9 24:21 57:18 58:2 84:9,10 prior 8:24 9:10,23 65:4 139:5 psig 87:5 88:17 89:23 90:9,13 21:25 22:8 34:3 48:25 produce 114:8 92:2,5 137:12,17 138:12 63:1266:2 151:17 18:3 20:16 21:7 25:21 public ppm privileged 57:15,16 90:9 96:10 97:10 2:23 4:15 157:4 162:1 65:22,24 67:9 21:21 106:2 142:8 164:1 166:1 prefer pro produced pumped 15:10 57:8 25:16 27:9 29:24 52:21 38:18 140:25 58:3,6,10,12,18 59:11 81:9 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045785 [purchase - relied] purchase question read (cont.) reference 37:6,21,23,25 38:5 15:14,17 18:723:831:12 161:1,1,1,1,1,1 162:1 31:10,11 67:16 70:17 71:5 purchased 31:12 37:15 69:8 70:23 reading 74:20 78:1 91:14 112:6 37:20 38:12 84:18 87:2 91:9 95:3,4,16 12:10,11 84:12 90:19 92:6 113:23 121:2 126:2,7 127:5 purchases 97:20 100:2 104:2 111:24 96:16 103:18,20 108:18 130:10,18 131:7 134:11,18 37:24 38:5 117:20 119:7,18 120:9 155:2 139:23 141:3,5 154:13,23 purchasing 123:17,20 140:11,12 real referenced 122:6 144:23 150:20 153:23 41:10 155:16 pure 155:12 really references 45:19 questions 9:1433:13,19 39:1867:15 84:1 127:4 130:23 133:22 purification 8:7 15:3 20:19 51:2 107:8 74:12 81:2 88:19 92:9 referred 64:19 115:21 143:24 153:12,12 99:24 100:4 119:19,23 25:24 111:20 purified 155:22,25 156:1 158:1,4 126:19 referring 69:5 quit reason 23:13 46:12 52:11 54:2,3 purports 144:8 39:17 160:1,1,1,1,1,1,1,1 68:11 83:1 84:3,8 85:21 94:16 127:18 137:12 quote 161:1,1,1,1,1,1,1,1 91:13 103:22 109:16 purpose 41:18 147:11 recall 111:16 114:11 117:8,11,23 18:9 26:16 35:19 38:22 r 13:3,20,25 14:15 15:19 123:24 124:20 126:5,21 41:24 42:2 51:23 52:1 railroad 62:23 pursuant 157:8 31:17 ramp 41:24 42:4,5 put 29:7,730:1331:1,11,12 ran 121:12 40:2 47:6 60:24 63:17 68:19 77:25 78:10 79:2 80:11 102:7,23 105:20 range 43:13,16,21 66:22 67:4 77:7 107:14 110:21 111:4 115:22 121:17,18 131:20 ransom 8:16 131:21 135:25 145:1 152:4 152:8,16 puts rate 135:15 raw 68:16 putting 26:2 139:17 razed 63:13 69:14 132:2,20 152:24 101:24 102:15 rcra pwg 79:10 1:4 2:8 163:1 pydraul 146:24 147:8,11,12,24,25 rd 165:1 reach pydrauls 709 17:12 18:1 20:4,12,13 23:3 127:7 129:22 131:1 134:1 23:22 24:23 29:17 33:2,10 137:14 33:18,22 34:13,16 35:3 refers 36:9,12 40:23 41:1,15 96:25,25 97:3 112:17 42:24 43:4 44:22 46:14 123:15 129:7 49:16 56:5 58:8 59:20 refining 65:21,24 103:18 104:22 49:1 106:23 112:4,7 122:7 reflect 130:12,18 134:18,20 137:4 141:10 140:4,17 152:8,15 reflected recalled 49:25,25 37:15 reflecting receptacle 38:5 49:23 refresh recess 130:13 50:11 83:6 115:6 136:11 regard 153:16 17:16 reclaimed regardless 133:24 16:7 recollection reinstituted 20:5 34:13,15 46:25 47:3 24:13 47:13 50:2 66:11 102:25 related recommendation 113:2,7 158:10 146:25 148:9 pyranol 152:10 q qualified 22:15 157:6 quality 155:4 quantifies 61:15 quantify 57:3 queeny 147:20 reached 41:1942:6 68:3 71:19 reaction 139:24 record 8:9 12:11 27:14 28:12,15 128:25 129:3,6 28:16 51:19 86:23 98:19 reactor 35:24 read 30:1 45:4 52:7 68:7,7 83:19 115:3,5,18 records 37:22,23,25 38:5 recovered 88:16,19 90:25 103:12,17 139:4 106:5 107:5,11 108:21,22 109:7 116:5,25,25 124:17 recurring 121:7 124:18 125:17 130:11 131:9 133:17 138:15,17 refer 13:14,14 15:11 25:1844:3 151:3 153:22 155:1 159:1 160:1,1,1,1,1,1,1,1 161:1,1 63:11 70:5 103:22 109:19 124:19 relating 9:24 10:21 21:6,10 relation 78:3,23 relatively 94:20 release 116:12 released 61:6 relevant 98:10 relied 23:15 107:1 128:2 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045786 [relying - seen] relying 143:24 remain 94:20 remained 47:15 110:2 remaining 46:18 49:18 remarks 158:2 remember 15:5,8,10 36:12 37:9,11,11 96:25 104:19 122:25,25 141:5 removal 67:8 71:7 77:3 101:25 remove 68:20 133:3 removed 49:22 56:21 103:1 removes 96:5,8 removing 132:11 repaired 41:18,21 repeat 113:19 rephrase 84:21 replenished 139:21 reply 8:4 report 72:21 83:16 reported 46:16 157:23 reporter 2:22 15:2 158:17 reporting 159:1,1 166:1 reports 73:1 represent 8:12 representative 8:19 13:22 96:17 represented 113:6 145:19 represents 8:14 request 16:24 17:3 53:4,5 required 120:4 121:24 resided right (cont.) santowax 29:21 99:22 101:4,11 102:10 44:24,24 45:2,2,6,7,12,14 residue 112:13 121:21,25 124:1 45:14,17 96:10 106:18 100:5 126:16 132:14 136:9 137:18,19,20 residues 141:11,20 142:17 143:9 sauget 111:12 146:7 148:11 150:12 154:7 26:15 52:5,6 resistant 156:2 savings 146:23 ring 75:3 resolution 37:12 saw 6:14 165:1,1 risk 19:7,11 37:1542:21 48:12 resolutionlawgroup.com 124:4 141:10 150:12 6:19 road saying respects 6:15 58:6 60:5 68:13,14 106:7 158:3 robert 108:15,17 116:15 143:4,5 response 1:152:168:1,10 159:1 144:22 151:17 16:23 53:9,11 73:7 106:23 162:1,1 163:1 says 135:3 137:4 roof 8:4 52:10 53:24 66:22 rest 33:5,9,11 71:18 75:1,2 76:23,24 77:5 74:4 rooms 85:6 87:14 91:12 92:1 resulted 114:2 96:22 98:24 104:13 105:2,7 142:18 rough 105:12 106:2 107:17 108:6 results 87:15 109:10 110:16 116:7 56:23 roughly 117:16,17 120:21 121:19 retardant 29:4,6 121:22 122:18,20 123:13 146:22 147:1 run 124:3,3 125:12 126:15 return 110:17 114:8 129:7 130:4 132:15 138:16 159:1 running 146:19 150:21 151:12 reuse 120:22 154:17 131:21 runs scenario review 109:11 110:16 87:5 32:24 47:3 52:15 54:3 rust schedule 59:24 61:17 107:3 122:4 125:2,3,6 155:13 139:6 140:6,18 143:23 rutledge scientific reviewed 5:2,8 9:12 165:1 5:10 142:2 16:22,23 73:3 87:22 121:3 s 134:22 143:20 reviewing 9Cl1 c 4723 17:1823:9 139:19 140:1 revision 72:20 richard safety 14:5 36:8,10 sake 29 25 30 19 3:4 83:7 salvage richard.jacobs 3:12 41:10,13,15 salvaged right 41 22 10:18,18 11:16 18:25 19:21 sanatowaxes 21:4 25:4,20 29:13 38:17 4515 40:11 42:16 43:14 44:1 45:25 48:5 49:7 51:21 sanatowaxs 1476 54:17 55:6 59:13 60:5 61:9 sanders 61:24 62:4,21 64:1,6,15 65:1968:5 69:11,1670:15 413 512 1641 1651 santocel 72:18 76:19 74:22 77:15 75:8,9,23 79:14,16 82:23 65:9,10 santotar 84:4 85:1 86:7 90:7 91:24 92:12 95:1 96:19,23 98:23 136:19 137:7,7 138:16,21 scooping 132:20 seal 158:12 166:1 search 37:23 51:8 second 52:8 53:23 68:1 70:3 76:16 76:24 94:9 96:7 101:22 107:15,15 108:5 111:12 114:5 116:16,16,19 126:1,2 127:1 141:11 section 99:13 108:19,23 111:11 121:19 122:18 123:13 128:9 138:12 seeing 42:24 49:17 56:5 105:15 122:7 130:18 seen 34:1 44:16 48:17 52:12 56:23 57:5 60:21 61:5,14 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045787 [seen - spoke] seen (cont.) show (cont.) size sound 63:21 64:13 65:12 82:5,8 124:6 137:12 147:24 107:23 37:1881:11,11 157:17 82:11 97:17,18,20,23,24,24 153:19 skipped sounds 97:25 105:15 106:19 108:9 showed 109:20 41:23 109:14 111:16 112:21 139:20 sis source 121:11 124:5,10 125:18 shown 6:10 86:25 94:4,4 127:23 130:9 131:6 134:20 31:1,13 32:22 93:18 96:9 small south 134:21 135:17 136:20,22 96:13 157:21 55:22 56:25 57:1,21 58:15 78:18,22 79:5,6,12 80:5 137:6 154:13 155:16 shows 58:1560:12,14,1761:1,4 99:5,15 selected 109:23,23 114:22 southern 21:18 shut smp 6:12 selection 24:12 71:23 80:2 136:2 47:10 51:9,12,17,25 52:24 southmost 22:1 shutdowns 73:1 99:15 selling 85:17 86:4,12 106:10 smps space 26:17 shutting 23:9 46:23 43:3 sense 79:22 society speak 35:25 125:6 150:20 153:14 side 164:1 8:19,23 9:17,22 10:1,2,4 sent 99:1,15 111:4 soils 11:7 17:5 19:1521:18 23:13 73:7 135:1 siegal 65:19 22:15 sentence 6:3 165:1 sold speaking 68:2,5,8 75:2 76:24 85:6 signature 26:5,7,22 35:4 41:9,13 64:6 17:19 155:25 89:21 105:7 107:15 108:6,7 52:9,9 158:6 159:1 162:1 81:5,9,14 138:18 specific 110:15 111:12 114:5 signed sole 23:3 34:2,16 35:5 41:10 115:25 122:20 130:4,23 98:5 37:10 48:20 50:2 77:14 85:22 separate significant solid 134:18 140:4 141:18 49:11 69:19 96:2,15 142:3 55:25 57:23 58:20,22,24 56:13 108:12 125:7,7 specifically September 64:23 solidified 9:1 17:1220:1323:11 127:19 significantly 135:16 24:11,15 25:13 36:9 37:2 series 154:14 solidify 49:16,22 51:12 59:20 65:8 99:14 143:13 146:1 149:5,6 similar 121:17 132:17 65:14 66:20 74:21 80:2 149:8,8,11,12,14,18,20,21 18:16 97:24 99:18 124:13 solids 81:10 108:4 110:8 111:24 149:21,25 150:6,8,13 154:18 56:14 126:11 130:12,19 131:4 153:18,25 simple solutia 155:11 services 58:17 1:2,142:5,167:11,12,13,14 specification 16:8 simplified 7:15,16,17,18,19,20,21,22 154:10 session 95:25 8:19 13:4,11,16 15:20,22 speculate 115:7 simply 25:20 28:18,22 30:5,8,20 37:5 71:18 137:24 set 70:8,9,1071:11,11 30:24 50:13,18,20,22 53:9 speculated 16:6 87:25 109:17 134:24 sincerely 66:10 69:22 83:10,14 93:19 119:4 142:4 157:25 166:1 159:1 93:22 95:12,24 97:10 speculating setup single 106:17 122:14 127:11,14 81:12 126:15,19 39:23 26:1564:16 133:15 136:18 133:8,13 136:13,18 150:23 speculation seven siphoned 150:25 159:1 163:1 71:16 72:2,14 13:24 86:15 88:12 35:12 solution spend sheet sir 128:23 95:19 94:12 95:25 96:9,14 122:19 somewhat spent sheets sit 42:17 82:1,2 23:9 82:6,12 159:1,1 22:17 33:21 34:15 96:18 soon splashing short 99:24 22:13 102:25 127:4 24:14 28:7 six sorry split shorthand 29:23,23 77:3 105:4 16:17 33:15 37:8 39:3 25:6 157:23 sixth 89:25 91:17 94:8 105:10 splitting shot 4:4 113:24 114:1 113:19 116:21 118:15 25:12 31:9 sixties 122:12 134:15 150:4 spoke show 58:9 sort 17:7,9 19:23 20:20 21:15 25:9 27:10 67:18 82:6 32:10 47:2 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045788 [sporadic - term] sporadic steel (cont.) substituted systems 24:10,24 59:21,22 36:7 42:16____________________ sporadically step suggest t 24:9 128:16 57:5 table spots 39:3 40:11 Stephanie 5:2 165:1 suggests 81:3 109:12,17,24 110:2,3,6,16 123:2 spring Stephens suit taken 28:10 spun 13:16 6:2 165:1 steps 133:2 158:10 suite 2:19 3:6 4:5 5:4,13 6:5,15 2:17 159:1 162:1 163:1 talk 9:5 10:8 11:19,21,24 12:13 spur 31:13,17 square 4:15 164:1 sterox 159:1 164:1 165:1,1 166:1 152:20 summer stills 22:10 92:21 93:2,11 94:1 95:6,13 Sunday 12:15 16:18 33:9 67:15 74:3 83:21 88:1 98:15 116:25 128:6 136:7 143:11 153:4 squire 96:2,15 135:10 86:16 talked 4:13 164:1 ss stone 102:4,4 Sundays 86:5 16:14 47:12 139:14,23 talking 157:2 ssd.com stopped 11:23 61:2 71:6,6 supplier 37:10 13:17 33:16,17 48:21 63:12 66:16 88:4 90:17 92:13 4:19 St 2:20 3:7 37:17 147:20 stopping 70:18 storage suppose 126:17 supposed 111:24 119:20 talks 60:22 67:2 79:22 132:1,1 157:3,14 158:13 159:1 164:1 165:1 166:1 35:12 38:15 store 89:15 129:5 sure tank 35:9 75:10 stack 19:8 38:20 130:5 140:7 stacked 134:6 stored 36:20,23 37:4 134:6 9:3,20 17:14 27:5 29:10 31:16,24 32:12 43:1 48:16 53:14,16 54:7 58:25 59:12 tanks 35:12 38:15 91:2,5 133:23 133:24 134:1,5 135:19,20 132:5 stages straight 95:18 59:1660:1461:1362:16 69:3 70:19 71:24 73:10,25 tars 44:17 111:13,20 64:20 stand 146:21 stree 165:1 street 82:8 87:18 91:23 92:3,7 95:9 99:16 100:7 103:5 104:6 111:23 113:3,5 120:7 taxed 164:1,1,1,1,1 technical 165:1,1,1 standard 3:19 5:14 6:4 159:1 166:1 23:15,16 24:1 46:24 51:25 strike 123:12 129:15,22 130:16 surely 84:1,5,6,9,21 89:23 119:1 telephone 127:18 stands 56:1066:13 111:1 141:2 82:16 strong surface 3:84:125:2,11 6:2,13 tell 146:22 114:15 53:25 11:1 15:15 17:21 24:16 started 10:21 11:23 33:23 115:9 starting structure 32:6 33:22 34:12 structures surfaces 125:15 survey 28:2 37:19 39:11 60:2 66:14,14 78:21 88:23 89:1 90:22 95:20 116:24 139:7 149:7 starts 43:17 108:7 146:1 state 29:13 101:23 study 11:25 12:2 stuff 67:2 swan 33:23 66:4,7 swing 140:2 142:5 143:10,11 145:2 146:17 148:2 telling 91:3 116:11,14 147:25 2:20,23 8:8 38:25,25 157:1 90:18 139:10 68:18 69:6 70:4,10 temperature 157:5,14 158:18 statement 131:2 163:1 states subject 96:16 106:10 submitted 16:23 swinging 72:9 swingings 69:9 41:25 42:4,5,7,9 43:6,13,16 117:24 ten 13:24 24:21 2:1 8:12 157:9 subscribed sworn tends stay 96:24 162:1 subsequent 8:2 157:19 162:1 swung 53:24 tens stayed 95:1 107:20 23:10 75:5 substitute 68:4 71:12,19 system 57:12 term steel 5:1 40:13,16,24 41:5,8 36:4 82:1 116:13 117:13,14,15 140:24 44:16 73:13 132:9 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045789 [terminated - ultimately] terminated think (cont.) timothy.kozik trap 151:17 49:19 55:3,25 56:16,19,20 5:18 44:1 45:23 46:8,10 47:5,14 terms 56:24 57:12 65:23 66:21,24 title 47:15,21 54:1,4,19 55:1,7 9:6 10:2 67:9,11 68:23 79:25 84:19 138:15 55:11,12,16,23 56:7,10 terphenyl 87:13,13 88:24 89:2,6 today 57:8 62:3,18,20,24 77:1,2 44:17 45:5 145:21 90:12,15,16 91:7,12,25 15:2 16:20 17:6 19:9 22:17 104:15,16 105:7 107:6 terphenyls 92:5,15,17 95:21,24 97:25 23:7,11,1827:3 29:12 108:6,9,16,20 109:4,7 44:14 45:3 145:24 146:4 101:12 102:19 103:12 33:20,21 64:14 102:11,13 123:1 149:17,18,23 104:7 106:12,15 108:10,10 107:2 119:20 128:3 134:23 traps test 108:21 109:24 111:3 143:21 62:3 107:14,24 122:22,22 48:9 65:1 155:5,9 117:12,14 118:6,14 119:1 told trial tested 120:13 121:14,15 128:24 19:6 92:14 157:11 82:18,18 155:6 128:25 132:1,22 138:1 tool troutman testified 139:13,14 140:13 152:23 6:12 5:12 165:1 12:25 13:20 33:4 34:10 153:9,13 155:4,5,6,14 top troutmansanders.com 132:23 157:21 third 27:21,25 74:16 96:24 98:25 5:18 testify 14:2 42:6 76:24 96:8 99:1 103:12,15 110:15 true 8:2 34:21 64:14,16 141:14 thomas 117:19 118:16 128:20 55:19 63:10 132:25 149:4 157:19 20:2 129:8 150:5 158:3 162:1 testifying thought topic truth 14:3 9:21 20:18 136:4 150:12 9:21 141:11 8:3,3,3 157:19,20,20 testimony three topics try 15:6 16:20 17:6 19:12 18:25 24:8 39:5 41:23 14:3 9:17 94:1 133:2 22:18 23:6 55:23 107:1 73:21,21 75:9,10,10,10,18 topmost trying 157:22,25 162:1 75:20 76:6 91:2,5 92:21 98:23 89:8 109:15 111:2,21,23 testing 93:2 94:1 95:6,13 96:2,15 torn 130:5 140:19,19 46:6 64:11 65:18 103:23 108:22 113:23 133:23 tubes tetraphenyl 116:13 118:2,2 tossed 74:17,24 75:4,20 44:13,14,15 tier 77:23 tubular texas 123:4 total 25:19,23 80:6,8,9,9,14 18:11,11 tiles 58:17 59:6 73:19 132:15 turn thank 14:19 164:1,1,1,1 165:1,1,1,1 53:20 67:19 103:8 104:9 91:20 156:2 till totally 111:8 113:17 thanks 58:4,5 78:7 79:25 31:18 132:10 turned 115:16 154:7 tim tower 40:3 71:23 thereto 9:18 115:11 4:14 turner 158:3 time trace 4:2 8:13,14,15 11:14,20 therminol 9:8 10:5,7,16,17 13:5,9 47:20,22,24 48:4,14 49:4 12:1,5 27:21 28:2,6,9 115:2 146:11,11,12,17,19 148:18 15:19 16:13 20:7 23:9 25:1 148:25 153:6,9,13 155:20 164:1 148:20,25 149:4,5 25:10,11 33:4 34:10,19 trade twenty therminols 37:25 38:4 39:15 40:10 45:7,10 145:22 146:7,12,25 24:21 57:18,25,25 115:2 148:23 149:2 41:3,4 42:6 58:10 61:11 152:5,8,9,17 type thermocouple 67:7 73:16 95:19 96:17 train 73:1 87:2 117:17,17,22,24 118:4 98:10 99:21 100:14 107:21 31:13 typewriting 119:11 120:14 114:23 115:1 121:25 122:2 transcribed 157:24 thing 130:9 131:6,10 141:1,15 157:23 typewritten 9:19 10:23 33:16 59:25 143:22 144:4 147:9 150:2 transcript 88:16 67:19 74:12 83:25 107:12 156:3 157:22 158:4 159:1 162:1,1 typical 117:3 128:6 139:14 154:22 times 163:1 164:1 66:18 things 14:22 39:20 58:13 61:7,23 10:15 11:11 17:24,25 97:9 62:1 87:8 96:16 104:7 111:2 116:23 timing think 74:2 9:3 11:6 13:8 16:24 17:24 timothy 18:2 20:2,12 22:1 27:17,25 5:11 165:1 34:10 36:8 37:3 41:17 transcripts 165:1 transfer 27:3 75:25 82:1 140:24 146:13,14 transferred 26:10 71:7 u u.s. 3:14 67:2 uk 20:25 21:16 26:17 ultimately 63:7 89:12 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045790 [um - work] um updated vibration wells 13:24 28:25 60:14 68:21 25:7 117:18 117:25 73:2 78:12 105:22 upside volume wendlene uncertain 155:2 145:19,19 4:12 164:1 104:20 usage vp wendy undergoing 132:22 142:2 148:18 9:1488:14 115:10 43:17 use vs went understand 14:19 16:25 18:10,1621:6 1:4 2:8 159:1 163:1 25:5 47:25 58:10 62:8 15:15 35:23 84:18 88:5 25:23 27:2,3 39:15 65:15 w 64:20 65:23 75:6,20 107:21 94:1,25 95:14,15 96:20 101:16 116:8 131:10 138:25 140:11,12 understanding 8:21 20:17 26:19 29:20 74:21 75:1 88:2 109:6,10 123:10 133:22 138:23 139:1,7,11 141:8,22 useful 41:5,8,19 wait 21:20 waived 158:6 wales 121:25 139:10,16 148:9 wescott 154:25 155:9 west 3:19 78:6,6,9,20 79:8 159:1 32:7 33:21 34:6 35:10 uses 39:14 40:2,12 41:14 44:21 26:4 27:2 73:12 52:2 54:13 60:2 61:25 62:5 usual 62:8 77:24 79:7 85:19 132:16,17,18 86:17,20 90:12 93:12 96:13 usually 96:18 112:1 129:12 135:20 84:5 132:4 135:24 140:21 141:13 utilized 144:6 20:7,24 understands V 120:10 understood 15:16 undertook 38:8 undetermined 157:9 unique 150:14 unit 18:6,22,25 39:5,17 41:23 72:21 73:21 75:9,9,11 80:11 84:9 85:11,13 87:7 87:24 88:9 89:22 90:11,16 90:25 91:2,4,13 92:1,13,15 92:15 98:25 99:6,12 100:19 100:19 103:22,23 106:8,8 132:6 united 2:1 4:1 8:12,15 18:22 21:9 157:9 units 39:12,15,16,19 59:19 73:17 74:3,7,24 75:5,17,18 76:4,5 76:19 77:17 87:7 88:9 90:8 90:1391:1,4 104:13,14 106:2 107:13 unknown 165:1,1,1,1 unusual 114:6 unwanted 75:15 vague 84:17 86:8 87:11 94:22 145:4 valley 5:1 vapor 38:25 42:25 43:3,8,12,16 43:25 45:22 46:9 60:20 61:12,20 119:5,9 120:14 123:7 124:20,21 vaporized 141:8 vaporizer 38:17 vaporizes 42:13 vapors 42:22,23 43:20,22 60:13 82:22 114:6,11,14,16 118:19 119:11 120:18 vapours 122:21 variety 121:4 145:21 various 38:1054:11,1663:17 142:12 143:17 vats 61:21 ventilators 33:9,11 versus 62:19 96:18 139:17 141:23 18:6 wall 118:5 walls 33:5,8,12,17 127:5,7,8,9 waiter 3:148:13 want 9:20 21:24 26:10 27:15 31:1767:18,18 71:1773:6 74:8,19 83:20 86:22,22 92:9 94:1 95:6 98:15 102:16,19 103:5,13 107:8 107:12 114:24 116:25 119:9,16 123:18 126:24,24 128:6 136:6 144:1 147:25 151:2 153:4 154:4,22,24 wanted 106:13,13 136:5 warned 122:21 warning 123:9 warnings 14:5 waste 8:25 10:9 136:19 138:16,18 138:18,19,22 139:10,18 wastes 138:25 139:3 water 43:15,15 78:18 135:5,8,11 135:12,15 week 86:15,24 88:12 weekdays 86:19 weekends 86:19 welcome 156:4 163:1 164:1 westinghouse 152:11 westinghouse's 152:4 westvaco 4:11 we've 38:1 73:13 88:10,10 124:19 147:2 whereof 166:1 wide 77:7 wit 8:5 witness 1:152:16 11:3 12:20,25 14:23 15:7 22:2 23:1 27:17 27:22,25 28:4,7,10 30:15 30:22 31:6 32:1 50:8,23 67:20 68:9 83:22 84:19 91:20 95:3,15 101:19 107:9 108:25 116:9 126:12 127:21 133:19 151:5 156:4 157:14,17 158:1,5,12 162:1 166:1 wl 78:11 wlavey 4:19 wma 78:25 wondering 88:17 word 53:16 123:10 words 73:14 work 15:20,22,24 16:4 22:3 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045791 [worked - years] worked 10:3 workers 86:15 wrong 55:6 wrote 12:2 22:8________________ y yards 126:14,15 yeah 10:20 12:8,10 13:10,12 27:1728:1031:1552:19 86:11 89:13,16 90:16 91:12 94:10 95:6 97:15 98:18 99:18 100:3 102:11 103:3 103:10,16,18 111:6,22 115:4 116:6,6 122:11 123:18 126:3 129:17 132:3 132:16 136:8 140:16 144:24 145:3 148:2 152:2 153:9 year 22:10 24:21 31:18,22 57:16 58:6 79:17 85:22 86:5 92:11 yearly 88:1 years 11:18 13:24 24:8,22 31:20 34:22 35:17 36:5 37:7 40:18,22 41:1,6 58:7 80:4 85:22 Kaley, Robert; Solutia 30 (b)(6); McWane WATER PCB-SD0000045792