Document 856NdVY2V3Xe42y68NaZ1noOa

FOSHEE & TURNER COURT REPORTERS 1 IN THE UNITED STATES DISTRICT COURT 2 NORTHERN DISTRICT OF ALABAMA 3 EASTERN DIVISION 4 5 WALTER OWENS, et al., ) 6 Plaintiffs, ) 7 8 vs. ) ) CIVIL ACTION NO. 9 ) CV-P-440-E 10 MONSANTO COMPANY, ) 11 Defendant. ) 12 13 DEPOSITION OF: BILL CAMBRON 14 15 In accordance with Rule 5 (d) of The 16 Alabama Rules of Civil Procedure, as Amended, 17 effective May 15,1988,1, TAMMY JENNINGS 18 GREGORY, am hereby delivering to MR. LARRY WRIGHT 19 the original transcript of the oral testimony 20 taken on the 22nd day of October, 1999, along 21 with exhibits. 22 Please be advised that this is the same and 23 not retained by the court reporter, nor filed OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035490 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 2 FOSHEE & TURNER COURT REPORTERS 1 with the Court. 2 The deposition of Bill Cambron was taken 3 before Tammy R. Jennings Gregory, commencing at 4 9:15 A.M. on the 22nd day of October, 1999, by 5 the Plaintiffs, at the law offices of Fite & 6 Miller, Anniston, Alabama pursuant to the 7 stipulations set forth herein. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035491 22 23 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 3 FOSHEE & TURNER COURT REPORTERS 1 APPEARANCES 2 3 Appearing For The Plaintiffs: 4 MITHOFF & JACKS, LLP 5 By: Larry Wright, Esquire 6 111 Congress Avenue, Suite 1010 7 Austin, Texas 78701 8 9 Appearing For The Defendant: 10 LIGHTFOOT, FRANKLIN & WHITE 11 By: Buddy Cox, Esquire 12 The Clark Building 13 400 20th Street North 14 Birmingham, Alabama 35203-3200 15 16 FITE & MILLER 17 By: Arthur Fite, Esquire 18 The SouthTrust Bank Building 19 Suite 400 OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035492 20 Anniston, Alabama 36201 21 22 Court Reporter: 23 Tammy R. Jennings Gregory 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 4 FOSHEE & TURNER COURT REPORTERS 1 INDEX 2 3 Witness: Bill Cambron 4 Stipulations...........................page 5 5 Examination by Mr. Wright............. page 7 6 Reporter's Certificate................ page 94 7 8 9 10 11 12 13 EXHIBITS 14 15 Plaintiffs'No. 8................... page 21 16 17 OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035493 18 19 20 21 22 23 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 5 FOSHEE & TURNER COURT REPORTERS 1 STIPULATIONS 2 3 IT IS STIPULATED AND AGREED by and 4 between the parties through their respective 5 counsel that the deposition of Bill Cambron may 6 be taken before Tammy R. Jennings Gregory, at the 7 law offices of Fite & Miller, Anniston, Alabama 8 on the 22nd day of October, 1999. 9 10 11 IT IS FURTHER STIPULATED AND AGREED that 12 the signature to and the reading of the 13 deposition by the witness is waived, the 14 deposition to have the same force and effect as 15 if full compliance had been had with all laws and OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035494 16 rules of court relating to the taking of 17 depositions. 18 19 20 IT IS FURTHER STIPULATED AND AGREED that 21 it shall not be necessary for any objections to 22 be made by counsel to any questions, except as to 23 form or leading questions, and that counsel for 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 6 FOSHEE & TURNER COURT REPORTERS 1 the parties may make objections and assign 2 grounds at the time of trial or at the time said 3 deposition is offered in evidence or prior 4 thereto. 5 6 7 IT IS FURTHER STIPULATED AND AGREED that 8 the notice of filing of the deposition is waived. 9 10 11 12 13 OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035495 14 15 16 17 18 19 20 21 22 23 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 7 FOSHEE & TURNER COURT REPORTERS 1 STATE OF ALABAMA, CITY OF ANNISTON, 2 OCTOBER 22, 1999, 3 9:15 AM., 4 5 BILL CAMBRON, 6 having been first duly sworn, was examined and 7 testified as follows: 8 9 COURT REPORTER: Usual stipulations 10 okay? 11 MR. WRIGHT: Yes, ma'am. OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035496 12 MR. PECK: That's fine. 13 14 EXAMINATION BY MR. WRIGHT: 15 Q. Mr. Cambron, thank you for coming in. Have 16 you ever given a deposition before? 17 A. Yeah. I was telling Adam I went to Delaware. 18 Q. Delaware. You were one of the group that 19 went to Delaware? 20 A. Yeah. 21 Q. Do you remember when that was? 22 A. I remember it was cold. I would say -- no -- 23 I'd say at least seven, eight years ago. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 8 FOSHEE & TURNER COURT REPORTERS 1 Q. Okay. 2 A. I really don't know. 3 Q. How long did that deposition last? 4 A. Forme? 5 Q. Yes, sir. 6 A. It lasted all day one day. We went in the 7 morning and finished up that afternoon, and 8 they said they would probably get back with 9 me, but they never did, and I was glad. OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035497 10 Q. Yeah, I bet. 11 A. Unless they were going to come south. 12 Q. What--do you remember the kind of questions 13 they asked you? 14 A. Yeah, you know, just general knowledge of the 15 plant in certain areas. 16 Q. Which areas did they ask you about? 17 A. Seemed like I remember keying in on the 18 montar pit. I remember that was one of them. 19 Q. Anything else? 20 A. Probably some about parathion. I'm not 21 really sure about it. I think they did. I 22 think we just generally covered, you know, 23 where I worked and everything in the plant. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 9 FOSHEE & TURNER COURT REPORTERS 1 Q. Okay. Because you've had a deposition 2 before, I'm going to give you the short 3 version of the little speech. 4 The only two things I'd like for 5 you to make sure of is that if I ask you a 6 question that you don't understand that you 7 stop me and let me know. OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035498 8 Just say Larry, I didn't understand 9 your question; could you ask it a different 10 way, and I'll try to do it until both you and 11 I understand each other. 12 Second thing is if you'd answer out 13 loud so that she can write it down. It's 14 hard for them, and they don't like to write 15 down head nods and things like that. 16 MR. PECK: Yes and no. 17 Q. (By Mr. Wright) And then the only other 18 thing is I'm sure you remember that the 19 testimony you're giving is under oath, and 20 it's the same oath you take in front of a 21 Judge and a jury if you were in a 22 courtroom -- 23 A. Okay. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 10 FOSHEE & TURNER COURT REPORTERS 1 Q. -- even though this is a somewhat informal 2 proceeding. When did you -- I assume you're 3 retired? 4 A. (Witness nods head.) 5 Q. When did you retire? OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035499 6 A. I retired December 1st of'97. 7 Q. Okay. When did you start with Monsanto? 8 A. March the 21st or 20th -- let's see -- 1960. 9 I think it was the 21 st. 10 Q. 1960? 11 A. Uh-huh (indicating yes). 12 Q. How old were you when you started with them? 13 A. I was twenty-one. 14 Q. Okay. Had you worked anywhere before you 15 went to work for Monsanto? 16 A. Well, I graduated from high school, and I 17 went right in the Marine Corp, and when I got 18 out, I worked at GE down here. 19 We had a General Electric plant 20 here in Oxford, and I worked there for nine 21 months until Monsanto called, and I've been 22 there ever since. Or I was there ever since. 23 Q. Right. What was your first job at Monsanto? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 11 FOSHEE & TURNER COURT REPORTERS 1 A. I started out in the aroclor department as an 2 operator. 3 Q. As a regular operator? OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035500 4 A. Uh-huh (indicating yes). 5 Q. How long were you in that job? 6 A. I was operator for about five years, and then 7 I made chief operator. 8 Q. Okay. And how long were you in that job? 9 A. That was probably only about six months 10 because at that time, the plant was growing, 11 and there was a big turnover. And I got into 12 maintenance as a pipe fitter. 13 Q. Okay. So you went to maintenance in'65? 14 A. Yeah,'65,'66. Somewhere around in there. 15 Q. How long did you stay in that position? 16 A. I stayed in maintenance until 1976. 17 Q. Okay. 18 A. Actually in that period, I was a pipe fitter, 19 and then they had a downsize of the plant, 20 and I went into -- I went back to college. 21 And in order to go to college, I 22 put in for a day j ob, and I went to plant 23 laborer at that time and worked there until I 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 12 FOSHEE & TURNER COURT REPORTERS 1 got my degree. OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035501 2 Q. In '76? 3 A. Yeah. I got my degree in '75, and then in 4 '76,1 was promoted to night superintendent. 5 Q. Okay. I've lost you. '65 you went to 6 maintenance as a pipe fitter? 7 A. Right. 8 Q. And so you were still at maintenance when 9 put in for the day job? 10 A. Yeah. 11 Q. Okay. I got you. So -- 12 A. And I was in shipping for one summer. 13 Q. Okay. What was your degree in? 14 A. I majored in accounting. 15 Q. Where did you go? 16 A. Jacksonville State. 17 Q. Where did you go -- what job did you go tc 18 '76 then? 19 A. Night superintendent. 20 Q. And how long did you stay in that job? 21 A. Ten years. 22 Q. Night superintendent over what? 23 A. Over the plant on all shifts. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 13 FOSHEE & TURNER COURT REPORTERS OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035502 1 Q. The whole plant? 2 A. Uh-huh (indicating yes). 3 Q. Okay. 4 A. At night, they, you know, there wasn't any 5 supervision there, so they determined they 6 needed someone there, so I got over the whole 7 plant on nights and weekends. 8 Q. Then which job did you go to? 9 A. '85 or 6 when they shut down the parathion 10 department and didn't need night 11 superintendent, they knew my major was in 12 accounting, so they moved me to an office in 13 the accounting department. 14 And then shortly thereafter, our 15 permanent IT man, computer man, transferred 16 to Chocolate Bayou. And they decide they 17 needed somebody to be a computer man, and I 18 had a computer at home. 19 Q . So you got elected? 20 A. And all of a sudden, I was a computer expert, 21 and that's what I did when I left. 22 Q . For the last ten years or so? 23 A. Yeah. I had to go to school, different 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 14 OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035503 FOSHEE & TURNER COURT REPORTERS 1 things, networking, and different mainframes 2 we had. 3 Q. Okay. Let me start with that one, then I'll 4 go back to a couple of your other jobs. I 5 assume over that ten years, the use of 6 computers at Monsanto increased like it did 7 everywhere else? 8 A. Oh, yeah. 9 Q. Did -- who has their own computers now? 10 A. Just about everybody. When I say, 11 "everybody," everybody in the office, that 12 includes accounting, personnel, safety, 13 engineers, and all that. 14 And then we put them out in the 15 control rooms in every department, in the 16 shops and, you know, we got a network now. 17 When I first went over there, it was just 18 stand alone computers. 19 Q. I assume you can e-mail St. Louis, and St. 20 Louis can e-mail you? 21 A. Right. 22 Q. How long has that been in effect? 23 A. Oh, me. Probably -- I'd say ten years. OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035504 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 15 FOSHEE & TURNER COURT REPORTERS 1 Maybe eight. Somewhere along in there. 2 Q. How big is the environmental department in 3 Anniston now days? 4 A. How big is it? 5 Q. How many people? 6 A. I don't know now. I know about -- 7 Q. When you left? 8 A. Of course you've got Alan Faust -- or I guess 9 you know. 10 Q . Right. 11 A . Those people in the trailer, and there was 12 about, I'd say, six in there, and then we got 13 our people. 14 We had Robert Jones and Jerry 15 Hopper, Jerry Brown involved in it when I was 16 -- when I was there. 17 Q . Did they office near where you officed? 18 A . Yes. 19 Q . Okay. I know this isn't your area, but since 20 you're here and nobody else is, I'm going to 21 ask you about it even though you're probably 22 not the person to ask about it. OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035505 23 A. Probably not. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 16 FOSHEE & TURNER COURT REPORTERS 1 Q. But, how did the environmental office change 2 in terms of personnel from -- let's see. You 3 first went into the offices in -- 4 A. --'76. Well, our office -- I went over there 5 in '86, but night sups had an office there in 6 another building in '76. 7 When you're working evening and 8 midnights, you don't see much of the day 9 people. 10 Q. That's why I was thinking -- 11 A. In '86 basically when I went over there. 12 Q. Let's talk about that from'86 to'97. Who 13 was in the environmental section in '86? 14 A. I can't think of his name. Robert -- I don't 15 know. I know, but -- I know his face, but I 16 can't -- 17 Q. It may come to you. Was he the head? 18 A. Huh? 19 Q. Was he the head of it? 20 A. Uh-huh (indicating yes). OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035506 21 MR. WRIGHT: Do you know who he's 22 talking about, Adam? 23 MR. PECK: I probably -- if he said 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 17 FOSHEE & TURNER COURT REPORTERS 1 his name, I'd probably know, but it doesn't 2 hit me. 3 THE WITNESS: I'll think about it. 4 Q. (By Mr. Wright) Robert somebody? 5 A. Cheevers. 6 Q. Robert Cheevers. Was he the head of it? 7 A. Yeah, he was over environmental. Like I say, 8 Jerry Brown has always been involved. I 9 think Robert probably reported to him. 10 Q. How long had Jerry been there? 11 A. Has Jerrybeen at Monsanto? 12 Q. Yeah. 13 A. Probably--1 don't know, 1970. I really 14 don't know. He's been there a while. Very 15 knowledgeable. 16 Q. So Jerry Brown, Robert Cheevers. Who else in 17 '86 was involved in the environmental 18 department? OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035507 19 A. I'm thinking Hopper was there, but there 20 might have been someone before Hopper. I'm 21 not sure. But they're -- 22 Q. Then who joined next? 23 A. I think after Cheevers, I believe it was 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 18 FOSHEE & TURNER COURT REPORTERS 1 Robert Jones. 2 Q. Okay. 3 A. I'm trying to think of someone in between, 4 but I don't believe there was. 5 Q. Then who? 6 A. Then who? 7 Q. Yeah. Anybody else? 8 A. Robert's still there. 9 Q. Okay. But, I mean, has anybody else come in 10 to help him? Have they expanded and added 11 personnel or anything? 12 A. I think they reassigned new -- I think Robert 13 Port is plant manager now versus reporting to 14 Jerry Brown. And, of course, they've 15 expanded, like I say, out there in the 16 trailer, but that's -- OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035508 17 Q. What's Jerry position now, Jerry Brown's 18 position? 19 A. I don't know. I don't go out there much. 20 Q. Okay. Are the e-mails preserved anywhere? 21 A. Are they preserved? 22 Q. Yeah, are there backup tapes that are kept? 23 A. Well, you don't want to keep tapes. I 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 19 FOSHEE & TURNER COURT REPORTERS 1 usually kept abouta year's worth as far as 2 on a monthly basis, then I'd backup daily, 3 you know. 4 Then I'd do an incremental daily, 5 and then I'd do a full backup weekly, and I'd 6 keep that weekly until I ran out of tape, you 7 know. Probably -- I'd probably have about a 8 year's worth. 9 Q. Now, that was just for you, or was that for 10 the whole system? 11 A. Well, I was -- I was in charge of the whole 12 system. That was the mainframe where we had 13 the storage on it. And I'm not sure if they 14 backed up St. Louis or not. OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035509 15 Q. Okay. Now, going back to 1960, what exactly 16 was your job as operator in the aroclor 17 department when you first started? 18 A. Well, I ran -- when I first started, I ran 19 the chlorinators. 20 Q. Okay. 21 A. And made aroclor. 22 Q. These are the exhibits that we walked through 23 yesterday with Mr. Hughes. He kind of gave 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 20 FOSHEE & TURNER COURT REPORTERS 1 me the layout of the place, and let me see if 2 I can put all these together. 3 Does that make sense to you? 4 A. Yeah. 5 Q. Okay. 6 A. I didn't run the acid that much. 7 Q. Here's the chlorinators here. 8 A. All right. 9 Q. Did you work -- did your shifts rotate? 10 A. Uh-huh (indicating yes). 11 Q. So you -- how long did you stay on one 12 rotation? OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035510 13 A. Two weeks. 14 Q Mr. Hughes gave us a list of people that 15 worked in the aroclor department. Would you 16 take a little while and go over that list and 17 tell me if you can think of any other people? 18 Let me explain what these things 19 mean. If there is a "D", it means it's 20 deceased. If there's a question mark, it 21 means he didn't know. 22 A. He's deceased. 23 Q Don Wilson is? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 21 FOSHEE & TURNER COURT REPORTERS 1 A. Yeah. 2 Q. And so if you could -- any of the gaps you 3 could fill in -- 4 A. You mean of people who worked there? 5 MR. PECK: Do you want him to add 6 what he knows about current status? 7 MR. WRIGHT: Yeah. What I'm 8 thinking is: Why don't we make a Xerox of 9 this real quick, and he can have his own list 10 and just add to that. OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035511 11 (Short recess.) 12 MR. PECK: Are you going to make 13 that a new exhibit? 14 MR. WRIGHT: Yeah. 15 16 (Plaintiffs' Exhibit Number 8 was 17 marked for identification and 18 copy of same is attached 19 hereto.) 20 THE WITNESS: You mean add someone 21 that -- 22 MR. WRIGHT: Yeah. 23 MR. PECK: Do you want me to 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 22 FOSHEE & TURNER COURT REPORTERS 1 reflect -- 2 MR. WRIGHT: Yeah. 3 MR. PECK: Why don't we put -- put 4 a 8 on there if you would. 5 THE WITNESS: Here? 6 MR. PECK: Yeah. 7 Q. (By Mr. Wright) What I'd like for you to do 8 on Exhibit Number 8 there -- Exhibit Number 8 OWENS 05- 15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035512 9 is a list Mr. Hughes made for us yesterday 10 afternoon, and it reflects the people that he 11 remembered that worked in aroclor 12 department. 13 A. Okay. 14 Q. And he put a "D" by the people that were 15 deceased, that he believed were deceased. 16 A. Do you want me to add to this? 17 Q. Yes, sir. 18 A. Okay. 19 Q. And so what you're going to do is go through 20 the list and anybody that you know -- 21 A. Still working is that the "W"? 22 Q. "W" means working. That's exactly right. 23 Anybody that you know to be deceased, go 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 23 FOSHEE & TURNER COURT REPORTERS 1 ahead and put a "D" by their -- 2 A. I don't know about these two still working. 3 They're out there, but they're not working. 4 What is the "L"? 5 Q. Laborers. They were laborers. 6 A. Okay. Okay. Well, do you want me to start OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035513 7 another -- 8 Q. Yeah, let's go ahead, and we can keep our 9 numbering system. That would be number 10 thirty-one, I guess. 11 A. Okay. Everyone I can think of is deceased. 12 You're not talking about any foremen or 13 anything like that? 14 Q. Foremen? I'm sorry? 15 MR. PECK: Do you want foremen? 16 MR. WRIGHT: Yeah, let's go ahead 17 and put foremen down there, but let's just 18 put in parentheses off to the side that they 19 were foremen. 20 Q. Would they have spent a lot of time in the 21 aroclor department? 22 A. Yeah. 23 Q. Foremen? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 24 FOSHEE & TURNER COURT REPORTERS 1 A. I mean, they would be in the department. As 2 far as, you know, doing the labor or 3 anything, they wouldn't be doing that. 4 Q. Okay. OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035514 5 A. I think that's about all I can remember right 6 now. 7 Q. Okay. 8 A. When I first went out there, we had one big 9 department, and it was combined in biphenyl, 10 but they worked down on the other end, so it 11 wasn't really the aroclor. 12 Q. The biphenyl guys? 13 A. (Witness nods head.) 14 MR. PECK: When you finalize these, 15 will you put the names of the deponents on 16 these stickers just mainly for my file so I 17 don't get them all messed up? 18 COURT REPORTER: Yes. 19 Q. (By Mr. Wright) How do you spell your last 20 name? 21 A. C-a-m-b-r-o-n. 22 Q. Did your dad used to work at the plant? 23 A. Fifty years. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 25 FOSHEE & TURNER COURT REPORTERS 1 Q. That explains a mystery then. I've got a 2 1958 plant inspection, and your name is on OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035515 3 it. 4 A. He was the first one in the history of the 5 company to retire with fifty years. 6 Q. Is he still alive? 7 A. No. He died about three years ago. 8 Q. What department did he work in? 9 A. He was a pay master, worked in accounting. 10 Q. So he worked in the office area? 11 A. Yeah. When he first went out there, it was 12 Swann Chemical. He worked in the lab just a 13 little bit, then they promoted him. 14 Q. Y'all must have worked out there together for 15 many years? 16 A. Yeah. 17 Q. Looking at your list, which is now marked as 18 Exhibit Number 8, you added eight names. Joe 19 Adcock? 20 A. Uh-huh (indicating yes). 21 Q. And he's deceased? 22 A. He was my first chief operator. 23 Q. So he was your immediate supervisor when you 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 26 FOSHEE & TURNER COURT REPORTERS OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035516 1 first started? 2 A. Right. On shift. 3 Q. Then Tom Townsend? 4 A. Uh-huh (indicating yes). 5 Q. Jack Sprayberry, Virgil McGullian? 6 A. McGullian. 7 Q. McGullian. Bill Twymon? 8 A. He was a laborer. I forgot to put that down. 9 Q. And all of those fellows are deceased? 10 A. Yes. 11 Q. D. L. Lackey, he's still alive? 12 A. Uh-huh (indicating yes). 13 Q. Does he live in this area? 14 A. Right. 15 Q. Mark Williams? 16 A. He's still alive and lives here. 17 Q. JackMolloy? 18 A. Jack's is in St. Louis, or he was. I don't 19 know if he's retired or not. 20 Q. What did he do? 21 A. He was my supervisor. He was over the 22 department, and then foremen, you know, were 23 under him. And the rest of us were under -- 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 27 OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035517 FOSHEE & TURNER COURT REPORTERS 1 but he was just head man. 2 Q. For how many years? 3 A. I don't know. He wasn't there long because 4 he was really a mover. 5 Q. Okay. So he got moved up to the head office 6 pretty quick? 7 A. (Witness nods head.) Good supervisor. 8 Q. Now, I'm going to ask you something that you 9 really may not know, but do you know any of 10 these guys that had cancer? 11 A. Ones with a "D"? 12 Q. Well, really any of them. Even the ones that 13 may still be alive. 14 MR. PECK: I'm going to object to 15 the form of the question because I'm sure 16 you're using it just for discovery, but I 17 don't know if he's qualified to evaluate 18 that. 19 MR. WRIGHT: Well, he can say what 20 he's heard. 21 MR. PECK: Obviously I'm going let 22 him answer. 23 THE WITNESS: I think Jim Boling 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035518 1-800-888-DEPO 28 FOSHEE & TURNER COURT REPORTERS 1 did, but I'm not sure. All the rest of them 2 died a normal death. One committed suicide. 3 Q. (By Mr. Wright) Which one was that? 4 A. Joe Adcock. 5 Q. Okay. I'm sorry. You were saying the only 6 one that you know of that had cancer was who? 7 A. Yeah, the rest of them lived to be, you know, 8 fairly old. 9 Q. Okay. Which one of them was it that did have 10 cancer? 11 A. Jim Boling. 12 Q. Okay. And then any of the other guys, 13 whether they're alive or dead, that you know 14 of that had cancer? 15 A. Now? 16 Q. Uh-huh (indicating yes). Well, not 17 necessarily that they have it right now but 18 that they've ever had it. 19 A. Oh. 20 MR. PECK: Object to the form of 21 the question. 22 THE WITNESS: No. 23 Q. (By Mr. Wright) In this 1958 plant OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035519 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 29 FOSHEE & TURNER COURT REPORTERS 1 inspection that your dad got CC'd on -- 2 A. Got what? 3 Q. Got copied on. 4 A. Oh, CC. I got you. 5 Q. See, his name was right up there at the top? 6 A. Uh-huh (indicating yes). 7 Q. I'm going to ask you who some of these people 8 were that were also listed here. Jack 9 Clegorn? 10 A. He was supervisor like Jack Malloy when I 11 first went to work there. And he was there 12 about a week after I went to workthere and 13 had a heart attack. 14 Q. And died? 15 A. Uh-huh (indicating yes). 16 Q. So he died in 1960. The next guy, T. W. 17 Collier? 18 A. T. W. Collier was -- I think he was in 19 maintenance. D. B. Curry was -- he was 20 biphenyl supervisor, where Mark Williams was 21 aroclor supervisor. OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035520 22 Q. Okay. 23 A. And he's still living. He's about ninety 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 30 FOSHEE & TURNER COURT REPORTERS 1 something, nearly a hundred. 2 Q. Did he work out there for fifty years? 3 A. No, he didn't work there fifty, about forty 4 something though. 5 Q. Okay. The next -- 6 A. W. J. Dougharty, I don't know. Or the Dover, 7 I don't know him. 8 W. B. Dunlap, now he's still alive. 9 In fact, I saw him last night. And he was in 10 the lab, doing something in the lab. I don't 11 know. 12 A. J. Finley was Nick Finley. He 13 was foreman of the chlorine plant. H. L. 14 Grey was theshipping supervisor. Name's Pap 15 Grey. 16 Les Hammer, I've heard that name, 17 but I don't know what he was because that was 18 before mytime. B. M. Hathorn was electrical 19 foreman. OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035521 20 Bob Hedworth, he wasn't there when 21 I was there. I just know I've heard that 22 name. 23 Q. Okay. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 31 FOSHEE & TURNER COURT REPORTERS 1 A. Lumpkin was in maintenance as a foreman. 2 Q. You're telling me when they're still alive; 3 right? 4 A. Huh? 5 Q. Were you telling me all of them you know are 6 still alive? 7 A. Curry is alive; Dunlap's alive. So far, 8 that's the only two. 9 Q. Okay. 10 A. I don't know Mahley. I don't know 11 Mullendore, Pelletier. Harry Phillips, I 12 think he's dead. He was purchasing agent. 13 Q. Okay. 14 A. J. Harris Powell's alive. He was the 15 shipping foreman. Milt Silver, he was there 16 before I was. 17 Q. Let me stop you again and go back to Mr. OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035522 18 Powell. He was the shipping foreman when you 19 first started? 20 A. Yes. 21 Q. In'60 to'65? 22 A. Uh-huh (indicating yes). 23 Q. Were they in charge of the landfill back in 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 32 FOSHEE & TURNER COURT REPORTERS 1 those days? 2 A. I don't know who was in charge of it. 3 Q. Okay. Go ahead. I'm sorry to interrupt 4 you. 5 A. J. H. Starr was maintenance foreman. Beldon 6 Twymon is -- I called him Bill. That's what 7 everybody called him then. He wasa laborer 8 in aroclor department. He's dead,and so is 9 Starr. 10 M. J. Williams is one I got on the 11 list here, Mark Williams. He was aroclor 12 foreman. 13 P. W. Wilson, I don't know. Ben 14 Ward -- let's see. I think he was a biphenyl 15 operator, and he's still alive. OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035523 16 These others are just plant 17 manager, production superintendent, and 18 maintenance superintendent, and all that, and 19 they're all -- they've been long gone as far 20 as transferring. Whether they're dead, I 21 don't know. 22 Q. I'll just -- we were looking at the cover 23 page for a report of plant inspection made 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 33 FOSHEE & TURNER COURT REPORTERS 1 2-12-58, and the Bate's Number is MONS 2 035301. 3 When y'all had spills or leaks 4 there in the aroclor department, how were 5 they dealt with? 6 A. Well, on the chlorinators, we had -- under 7 the pump, we hadsomething called drip pans, 8 and that would catch any of the, you know, 9 like if you had a pump leaking, it would 10 catch that. And we'd empty them several 11 times in a shift in a bucket or a drum. 12 When the bucket, you know, got 13 full, we'd empty it into the drum and pump it OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035524 14 back up in the charge tank and rework it. 15 Q . Okay. I mean, what other kind of spills or 16 leaks would you have from time to time? I 17 mean, I guess somebody could kick over a 18 bucket -- 19 A.. Oh, yeah. 20 Q . -- or trip over the pan or something? 21 A.. Well, you know, you might have a gasket leak 22 on a pipe or a valve leaking, but we always 23 kept a bucket under each one of those 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 34 FOSHEE & TURNER COURT REPORTERS 1 chlorinators under the sample valve, and 2 that's where we used to sample. 3 And then -- but used -- you know, 4 we'd just throw sand on it if we got any on 5 the floor or throw sand on it and scrape it 6 up and put it in a drum. They'd carry it to 7 -- when the drum got full of that, they'd 8 carry it to the landfill. 9 And sometime, you know, some of the 10 -- at the end of each shift, we'd always 11 wash up, what we called wash it up and wash OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035525 12 it down. 13 Q. With a hose? 14 A. Uh-huh (indicating yes). 15 Q. Hot water or cold water? 16 A. It was mixed, you know, we used--we had a 17 steam mixer there. We could use hot if we 18 wanted it. Something with steam. 19 Q. So you could either use steam to clean it- 20 A. -- or just mix the water till it got to the 21 temperature you wanted it. 22 Q. Or hot water or cold water? 23 A. Yeah. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 35 FOSHEE & TURNER COURT REPORTERS 1 Q. And you'd wash down the whole area? 2 A. Yeah, it'd go down into the sewer, you know. 3 From there, it went to the limestone pit. 4 Q. Now, Mr. Hughes called that the cooling water 5 ditch because he said that the cooling water 6 would also circulate through the chlorinators 7 and was routed into this ditch? 8 A. Probably. I don't -- 9 Q. You don't have a recollection of that? OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035526 10 A. I remember water being in there. 11 Q. There was water all the time in this ditch? 12 A. Generally, yeah. 13 Q. Did you ever work in the--now, this was in 14 later years, so you may not have been there 15 -- but work in the area where they did the 16 flaking and drumming of the solid aroclors? 17 A. Yeah. 18 Q. You worked over there? 19 A. Yeah, that's an aroclor department, yeah. 20 Now, they had another -- later years like you 21 say -- they were in a warehouse part, and I 22 never worked over there. 23 Q. But when you were there, that was still a 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 36 FOSHEE & TURNER COURT REPORTERS 1 part of the old aroclor department? 2 A. Right. They had a biphenyl flaker and 3 aroclor flaker. 4 Q. Where was that in relation to all these other 5 things? 6 A. Where have you got the stills? 7 Q. These are the stills here. OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035527 8 A. It was down -- well, actually, the -- you got 9 the filter here, and right over here, you got 10 the solid aroclor flaker. And right above 11 it, you've got the tank where we pumped it. 12 And then down below, I'd say right 13 in between two or right under it somewhere 14 right in here, was a biphenyl flaker. You'd 15 flake that and put it in a bag. 16 Q. Okay. How did the flaker work? That's 17 something we -- I haven't had described yet. 18 A. A flaker was a big drum full of water. 19 Actually, the flaker itself was a big drum 20 that just rotated. 21 Inside the drum had, you know, 22 water, cold water, and then we would have a 23 flaking tank up above full of aroclor, and we 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 37 FOSHEE & TURNER COURT REPORTERS 1 would just -- under the flaker would be a 2 pan, and we'd let the aroclor down until we 3 got the level we wanted it. 4 And it was hot, so when that drum 5 came around and got it, it would pick up that OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035528 6 aroclor, and it would solidify on that drum. 7 And when it got over to the other side, you 8 know, after it picked it up, it would -- it 9 would fall off that drum. 10 And we had some, you know, knives 11 -- not knives but teeth things turning over 12 and over -- I can't think of what we called 13 them now -- and it would kind of crush it up, 14 and it would go down into a hopper. 15 And then we had one of the laborers 16 down there below bagging it out. 17 Q. You put that stuff in bags? 18 A. Yeah, because it was solid then. 19 Q. Okay. I think I understand what you're 20 saying, but I'm not sure. 21 There would be the -- what I guess 22 would be molten aroclor -- 23 A. Well, we had different types of aroclor, you 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 38 FOSHEE & TURNER COURT REPORTERS 1 know, finished by specific gravity -- 2 Q. Right. 3 A. -- or by melting point, so the higher you OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035529 4 got, the -- this particular aroclor that was 5 flaking was melting point stuff where you 6 could just put more -- I don't guess I need 7 to tell you any of the process, but -- 8 Q. Was that your 1254 and 1260? 9 A. No. 10 Q. Which ones did you flake? 11 A. We flaked 5460. 12 Q. Okay. 13 A. And the other you couldn't flake because it 14 was more liquid. 15 Q. Even the 1260? 16 A. Yeah. 60 was thick, but it wasn't like this. 17 Like I say, when that drum with water and the 18 hot -- it just kind of stuck to the drum 19 until it got over there, and it kind of -- it 20 was real thin, you know. 21 So by the time that drum made a 22 complete rotation and got over there where 23 the teeth were, it was flaking off. That's 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 39 FOSHEE & TURNER COURT REPORTERS 1 the reason they called it flaking. OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035530 2 Q. How big was the drum? 3 A. About like a fifty-five gallon drum. 4 Q. That's all? 5 A. That's all. 6 Q. Just one drum? 7 A. Yeah. 8 Q. Okay. And you said it was filled with water? 9 A. Yeah. Had water going through it. 10 Q. Water circulating through it? 11 A. Circulating, yeah. 12 Q. And how fast would it rotate around? 13 A. As fast as you wanted it or slow as you 14 wanted it. 15 See, sometimes the temperature of 16 the material or the drum, you couldn't go 17 real fast because it would still be stuck to 18 the drum, but you just had to get the right 19 combination where it was flaking off there 20 the way you wanted it. 21 Q. And that was part of the operator's job was 22 figuring out what the right combination was? 23 A. Yeah. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 40 FOSHEE & TURNER COURT REPORTERS OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035531 1 Q. Now, you said that was in the -- 2 A. -- the control room. The control room was 3 here; flaker's right out here. 4 Q. Okay. And then -- 5 A. That was on the second level up here with the 6 stills, and then on the first level was the 7 biphenyl flaker. 8 Q. What was the floor like of this second floor 9 area? 10 A. Concrete. 11 Q. Did it have drains in it? 12 A. Drains? I'm sure it did. I'm sure it did. 13 We never did really -- I just can't 14 remember -- 15 Q. Okay. 16 A. -- to be truthful with you. We never did 17 really wash down up there because that was a 18 different type procedure under vacuum, but 19 I'm sure we had drains. 20 Q. You would sweep up there more than wash? 21 A. Yeah, yeah. We had an air hose we would blow 22 down. Just -- the product just didn't get 23 out up there, you know. It was just -- you 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 41 OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035532 FOSHEE & TURNER COURT REPORTERS 1 can put it in the stills, and it went over to 2 a 3 Q. I'm just wondering about the flaking and 4 drumming. Because what I'menvisioning is 5 like -- well, flakes. 6 A. Well, the drum -- it had a hood over it, you 7 know. 8 Q. Okay. 9 A. You close the door, and all that went into a 10 hopper down there. 11 Q. Was the hopper on the first floor? 12 A. Well, the bagging thatthey did was at the 13 bottom hopper. They'd standdown there with 14 the bag, and the hopper was like going up to 15 the ceiling here. 16 Q. Right. 17 A. And up above it was a flaker. When it came 18 off the flaker, it went into the hoppers. 19 Q. Was the bagging on the first floor? 20 A. Yeah, bagging was on the first floor. 21 Q. Because I've never seen a bagging operation 22 that, you know, some didn't spill here and 23 there. OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035533 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 42 FOSHEE & TURNER COURT REPORTERS 1 Because what I hear you saying is a 2 man would hold a bag under the bottom of the 3 hopper, and when it got filled up, he, I 4 guess, shut the trap and closed the bag up? 5 A. Right. 6 Q. And I can't imagine that that could have been 7 done without some floating off to the side of 8 the bags and ending up on the floor somehow. 9 A. Well, I'm sure there was downstairs. 10 Q. Okay. 11 A. But not that much. I mean, they kept i 12 cleaned up, swept up. 13 Q. Okay. And that was -- 14 A. And then you reworked that too. 15 Q. Where was the downstairs? 16 A. Where was it? 17 Q. Well, that was a bad question. It was 18 downstairs. I know that. 19 But, I mean, what else was in the 20 area of the -- where the hopper and the 21 bagger were? 22 A. Just had pallets to put those bags on. OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035534 23 Q. Did they have a sewer drain or a ditch like 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 43 FOSHEE & TURNER COURT REPORTERS 1 was in the chlorinator area? 2 A. Gosh, I don't know. I didn't work down there 3 much because that was mainly, you know, 4 laborers. 5 Back in the '60s all the laborers 6 were like, you know, black guys to be 7 truthful with you. Of course, all that's 8 changed, but that's the way it was then. 9 Q. That was their operation? 10 A. Uh-huh (indicating yes). 11 Q. And as an operator, you didn't get involved 12 in that? 13 A. Not really unless -- if I was running the 14 flaker, I'd tell them I'm going to shut the 15 flaker down. 16 Q. Okay. 17 A. Then if you start it back up, you tell them. 18 Q. Okay. Who would -- well, who was responsible 19 for housekeeping in that area? 20 A. All of us. OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035535 21 Q. In that particular area? 22 A. In other words, if you worked around the 23 stills upstairs, then you kept that clean, 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 44 FOSHEE & TURNER COURT REPORTERS 1 and then the flaking people kept that clean. 2 Q. That's what I meant in the flaking area. 3 A. Yeah, the laborers did. And then if we had, 4 like, visitors coming, we'd just all pitch 5 in. But even in 1960, you know, safety and 6 housekeeping was pretty big. 7 Q. Okay. In this 1958 inspection, I see a 8 reference to something that Dicky Walker was 9 telling me about. 10 Down here on page 035306, they're 11 talking about the aroclor department and item 12 "A". "Floor is covered in places with tarry 13 product." Dicky mentioned that from time to 14 time, that stuff would build up and get 15 packed down? 16 A. Yeah, that could be coming from one of the 17 stills over here also. 18 When we'd finish a still, you know, OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035536 19 pump it out, when the receiver's filled, you 20 pump it over, but then you'd have to drain 21 your bottom. And that was like a tarry 22 product, but you drained it in the drum. 23 You might have some leakage there, 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 45 FOSHEE & TURNER COURT REPORTERS 1 but it would be very little. And then what 2 we normally do there, like, it would dry 3 hard, you know, just really hard and brittle, 4 but you had to put sand on it. 5 And we had scrapes there where we 6 scraped it up out of the floor and put it in 7 drums, and they'd landfill it. 8 Q. Dicky mentioned sometimes they'd to have put 9 fire on it to help break it up. Do you 10 remember that? 11 A. Yeah. That was the 1960s. 12 Q. I didn't get a good picture of how that 13 worked. Would you describe that process? 14 A. Well, like I was telling you, that stuff 15 would be hard as concrete really, and you'd 16 get there with a scrape, and it just wouldn't OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035537 17 come up. So we had, you know, we'd have a 18 gas hose with a nozzle on it. 19 And now then, or in the '70s even, 20 an open flame or something was -- you didn't 21 have. I mean, but back then, we would heat 22 that -- 23 Q . Was it like a cutting torch? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 46 FOSHEE & TURNER COURT REPORTERS 1 A. No, no. It was like we had a gas line there 2 with a hose and like a piece of pipe on it 3 where it would just heat that stuff up. 4 Q. And the flame would be at the end of the 5 metal pipe? 6 A. Yeah. 7 Q. Okay. I just couldn't envision how the flame 8 was -- 9 A. As soon as we got the stuff where we could 10 scrape it up, we'd just scrape it up or 11 shovel it up and put it in a drum. 12 Q . Okay. Now, the -- talks about a jet 13 platform. What was the jet platform? 14 A. The jet platform was up above the stills OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035538 15 there, and we had steam jets. Because on the 16 stills, of course, you had to have a vacuum. 17 And when we would pump the 18 chlorinated biphenyl in those stills, then 19 we'd have to put a vacuum on the still and 20 still it. And the jets were up on that 21 platform. 22 Q. Okay. 23 A. It was up on, I guess, you call it third 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 47 FOSHEE & TURNER COURT REPORTERS 1 level. 2 Q. What was montar? 3 A. Montar was what I was telling you about the 4 still bottoms that we used to have to -- when 5 we finished the still, we still had those 6 bottoms there. We had to do something with 7 them where we'd have an empty still. 8 There would be a big hood down 9 below the still, and we'd just have a circle 10 of drums there with a pipe that just 11 rotated. And then you'd have -- one of the 12 laborers would get down there inside the hood OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035539 13 with, you know, proper safety equipment on, 14 and the operator would open the valve there 15 and let those bottoms out. 16 And then they'd stay there until 17 they got hard, of course, and then they'd go 18 to the landfill. 19 And we also had, you know, montar 20 off of the santowax still that we pumped. 21 Q. What was santowax? 22 A. Santowax was -- we'd take -- it was off 23 polyphenol stills. We would distill the 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 48 FOSHEE & TURNER COURT REPORTERS 1 polyphenol, and the bottomsoff of that was 2 santowax. 3 And then we'd put it through a 4 process and make therminol. But santowax -- 5 bottoms off of santowax was montar. 6 Q. So all of the bottoms -- 7 A. Those bottoms there, we didn't drum them. 8 Those went to Clegorn's Lake we called it. 9 We just pumped them. 10 Q. That was the pit over there on the -- I OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035540 11 guess -- 12 A. -- west side. 13 Q. West side? 14 A. Uh-huh (indicating yes). And we pumped it 15 over there. It solidified, so it didn't go 16 anywhere either. 17 And they'd clean it out from time 18 to time. 19 Q. Were you able to -- I mean, would it pump 20 over there to Clegom'sLake? 21 A. Would it? 22 Q. Yeah, it pumped? 23 A. Yeah. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 49 FOSHEE & TURNER COURT REPORTERS 1 Q. You can pump it through a pipe? 2 A. Yeah. See, it was hot then when it first-- 3 when the batch finished, it was hot, really 4 hot. 5 Q. So it was liquid enough to go through the 6 pipe, and once it dumped out into the lake, 7 it would solidify? 8 A. Yeah. OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035541 9 Q. Okay. What else went into Clegom's Lake? 10 A. That's all I know of. Just still bottom. 11 Q. Did montar go over there too? 12 A. That was montar. 13 Q. Okay. Well -- 14 MR. PECK: Santowax montar. 15 Q. (By Mr. Wright) So you just call -- all 16 still bottoms you call montar? 17 A. Yeah, basically. 18 MR. PECK: But there's two kinds. 19 You got that? 20 MR. WRIGHT: Right. 21 MR. PECK: There's santowax and 22 aroclor. 23 MR. WRIGHT: Right. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 50 FOSHEE & TURNER COURT REPORTERS 1 MR. PECK: I'm just trying to be 2 helpful. 3 MR. WRIGHT: I know you're trying 4 to be helpful. But I did get that. 5 Q. And what happened to the aroclor still 6 bottoms? OWENS 05- 15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035542 7 A. They would be in those drums -- 8 Q. Uh-huh (indicating yes). 9 A. -- and, you know, you couldn't move them for 10 a day maybe. 11 Q. While they cooled? 12 A. Right. And then we'd put the -- they'd be 13 just like montar. They'd be solid. And we'd 14 put them in -- the lids on and carry them to 15 the landfill. 16 Q. Who was responsible -- 17 A. Sometimes they would carry some drums to -- I 18 can't remember what type it was, but there 19 would be some drums there that they would 20 carry to Clegorn's Lake, you know, chop them 21 open with an ax and put them in there. 22 Because at one time, they were 23 thinking about reclaiming all that and 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 51 FOSHEE & TURNER COURT REPORTERS 1 putting it in a melting pot and reworking it 2 for a new product, but I don't know whatever 3 came of that. 4 Q. So they were kind of storing it in Clegorn's OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035543 5 Lake? 6 A. Well, not -- Clegorn's Lake was a storage for 7 montar, but at one time, they had some drums 8 over there, you know. I don't remember what 9 type it was, whether it was aroclor bottoms 10 or what. 11 I just remember they were going to 12 rework -- try to melt up those bottoms, and 13 they were thinking about some new product, 14 but I don't think it ever materialized. 15 Q. Do you remember when that was? 16 A. Between '60 and '97. 17 Q. Okay. 18 A. It was probably in the '70s. 19 Q. Early '70s? 20 A. I just don't know. That's about the best 21 answer I know. 22 Q. And where were those drums that you're 23 talking about now kept? Were they stacked 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 52 FOSHEE & TURNER COURT REPORTERS 1 over there by Clegorn's Lake? 2 A. No. Generally those drums went to, you know, OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035544 3 the bottoms went to the landfill, but the 4 ones they had over there, I don't know. I 5 just don't remember that much. 6 Q. Who would know more about that than you? 7 A. I don't know if Mark Williams would or not. 8 I just don't-9 Q. Okay. 10 A. But Clegorn's Lake was inside the plant, you 11 know. It wasn't, like, outside the plant. 12 Everything was in the confounds of the plant. 13 Q. By "inside of the plant" - 14 A. When you say "lake," you're not talking about 15 a liquid, you know, like a -- 16 Q. No. I've seen it. 17 A. Just a solid black-- 18 Q. I've seen an overhead picture of it. 19 A. It was just like you'd look down there and 20 see a solid tar what it looked like. 21 Q. Okay. 22 A. No odor, you know. 23 Q. When it rained, I mean, would there be a 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 53 FOSHEE & TURNER COURT REPORTERS OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035545 1 layer of water on top of it? 2 A. Yeah. 3 Q. Pretty much all the time? 4 A. I don't know about that. I guess just like 5 there would be water on that grass out there 6 if it rained. Evaporate. 7 Q. Well, I guess what I'm asking is: From the 8 picture that I saw, it's -- I mean, it's kind 9 oflikeabowl. There was a depression there 10 that the bottoms were put into to hold them. 11 And it was open to the atmosphere. 12 And so if it rained, obviously rain would 13 land in the bowl just like the still bottoms 14 landed in the bowl. 15 A. Right. 16 Q. And was there -- and if it rained enough and 17 the bowl filled up, the water's got to go 18 somewhere. 19 A. No, there was plenty of room. 20 Q. Okay. 21 A. There was plenty of room. It was big. 22 Q. So if it rained enough, the water would land 23 in there and -- 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 54 OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035546 FOSHEE & TURNER COURT REPORTERS 1 A. -- stay. 2 Q. Stay. So was there usually water -- a layer 3 of water in the lake? 4 A. After it rained. 5 Q. Okay. 6 A. I mean, it wasn't like it would be there all 7 the time, no. 8 Q. That's what I was asking. Do you know of any 9 photographs or videos or super8 movies of the 10 aroclor department? 11 A. No. 12 MR. PECK: Back in those days not 13 everybody had a camcorder. 14 THE WITNESS: They didn't know what 15 it was. 16 MR. PECK: Can we take a quick 17 break? 18 MR. WRIGHT: Sure. Sure. 19 (Short recess.) 20 Q. (By Mr. Wright) I've got a 1969 inspection 21 package, and I'm not really going to talk 22 about the inspection, but it's got a list of 23 products here. And Iwanted to walk through 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035547 1-800-888-DEPO 55 FOSHEE & TURNER COURT REPORTERS 1 these with you because I assume the products 2 in '69 were probably about the same that you 3 worked on when you were there in the 4 department. 5 A. When did they shut that down? 6 MR. PECK: They shut liquid aroclor 7 down in '71 and terphenyls in '72. 8 THE WITNESS: Okay. 9 Q. (By Mr. Wright) Okay. I'm looking here at 10 page DSW085399, which is an exert from the 11 1969 plant inspection package. And it 12 describes -- the page is entitled "Products, 13 Raw Materials, Major Uses." And it talks 14 about the biphenyl -- 15 A. Uh-huh (indicating yes). 16 Q. -- and then the santowaxes that we've talked 17 about. What do these letters mean, do you 18 know? 19 A. That's the chemical breakdown of santowax. 20 If you distill a certain part of it, that's 21 the "O", and then another bit's "M", and it's 22 just -- you'd have to ask a chemist about 23 that. OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035548 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 56 FOSHEE & TURNER COURT REPORTERS 1 Q. Okay. And then liquid aroclors, and it lists 2 1221 3 A. Right. 4 Q. - 1242, 1248, 1254, 1260, 1262 and 1268. 5 A. Right. 6 Q. Did y'all make all of those -- 7 A. Yes. 8 Q. -- when you were in the department? 9 A. Uh-huh (indicating yes). 10 Q. Can you kind of rank them for me in terms of 11 which one you made the most of? 12 A. 1242 we made the most of. 13 Q. By a big margin? 14 A. I'd say. 15 Q. Okay. 16 A. But it just varied on basically on what 17 people wanted, but if I was betting, I'd say 18 we made more 1242 than anything. 19 Q. Okay. 20 A. And in ranking them, basically all that 21 they're ranked by is specific gravity, how OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035549 22 much chlorine you put in it. And that was, 23 you know, that's just like you took biphenyl 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 57 FOSHEE & TURNER COURT REPORTERS 1 and just -- kind of like an egg sunny side up 2 -- you didn't put very much in it. And, of 3 course, they got higher and higher and 4 thicker and thicker. 5 And then this one here, 1268, was 6 probably the least that was made. And it was 7 the hardest to make because you finished it 8 by something called a holding point versus -- 9 and it was -- you really didn't have much 10 leeway. 11 See, these had a range where you 12 could finish them at. Like specific gravity 13 would be, you know,1520 or 1560, and this 14 one you had to get-- 15 Q. Okay. So you made more -- you think you made 16 more 1242 than anything else? 17 A. Yes. 18 Q. What would be next on the list? 19 A. Probably -- I don't know 54 and 60. 1254 and OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035550 20 60. 21 Q. Okay. Then what would be the next lowest? 22 A. The least we made would be the two on each 23 end. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 58 FOSHEE & TURNER COURT REPORTERS 1 Q. 1221 and 1268? 2 A. Uh-huh (indicating yes). 3 Q. Okay. 4 A. And -- well, 1262 wasn't very -- we didn't 5 make it much. 6 Q. Okay. 7 A. 48 was pretty common. I'd say -- if I was 8 ranking them, I'd say one -- 9 Q. 1242 was one. 10 A. One. Probably these two would probably be 11 tied, two and three. 12 Q. 1254 and 1260 would be tied for two and 13 three? 14 A. Yeah. And then 48, and then 21 and 68. 15 Q. Okay. Now, did y'all actually make therminol 16 there at the plant? 17 A. Well, we made therminol, yes, but not in OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035551 18 aroclor. Therminol was made in the biphenyl 19 department. 20 Q. Okay. 21 A. Whichwas like a next-door neighbor. 22 Q. Okay. 23 A. You know, like, here are the chlorinator's 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 59 FOSHEE & TURNER COURT REPORTERS 1 right here, five, six, seven, eight. 2 Q. Yeah. 3 A. There was a street right here, and right over 4 here was therminol -- Imean HB40. 5 Q. Okay. 6 A. Santowax. 7 Q. Okay. 8 A. Then. Now they're in a different location. 9 Well, the santowax is. 10 Q. One thing that's been puzzling me all along, 11 and I know the answer is in the documents, 12 but I just haven't sat down and studied it 13 yet-14 A. Just one thing? 15 Q. It is just one thing right now. What was OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035552 16 therminol made out of? 17 A. Well, am I supposed to answer the process and 18 all that? I mean, I don't care. 19 MR. PECK: Yeah, I mean, yeah. 20 THE WITNESS: Therminol 21 Q. (By Mr. Wright) I mean, I don't want secrets 22 or anything. 23 A. No, it was just made out of what I told you a 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 60 FOSHEE & TURNER COURT REPORTERS 1 while ago. You charged a tank with 2 autoclave, and then you would hydrogenate 3 that. 4 The autoclave had an agitator in 5 it, and you just, you agitated the santowax 6 in there and added hydrogen, and you finished 7 it -- well, we used to finish it in gravity 8 and then went to refractive index. 9 Q. I guess what I'm really concerned about is 10 not necessarily the process, but is therminol 11 only hydrogenated biphenyl with no 12 chlorinate? 13 A. Not biphenyl. It was santowax. OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035553 14 Q. Okay. 15 A. Therminol's 66, whichis main product. 16 Q. Right. Did it have any chlorine in it is 17 what I'm asking? 18 A. Zero. Zero. 19 Q. Okay. Now, what was pydraul? 20 A. What? 21 Q. Pydraul, P-y-d-r-a-u-1? 22 A. I don't know. 23 Q. Y'all sent aroclors to St. Louis? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 61 FOSHEE & TURNER COURT REPORTERS 1 A. I think so, yeah. I wasn't involved in the 2 shipping. 3 Q. Did they mix all that in St. Louis? 4 A. See, aroclor's made here and in -- 5 MR. PECK: Wasn't there an aroclor 6 that was a heat transfer fluid? I think is 7 what you're getting at. 8 MR. WRIGHT: Yeah, there was a 9 pydraul series, like, pydraul 150, pydraul 10 this, pydraul that. 11 THE WITNESS: Wasn't when I was OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035554 12 there. 13 MR. PECK: I don't know the answer 14 to your question. It may just not have been 15 done at this point. 16 MR. WRIGHT: That's what I'm 17 thinking. 18 THE WITNESS: Some of the aroclor, 19 you know, is considered heat transfer also, 20 but not like therminol. 21 Q. (By Mr. Wright) This pydraul was a mixture 22 of aroclors with some other stuff, but I 23 think that was done in St. Louis. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 62 FOSHEE & TURNER COURT REPORTERS 1 A. That was after my time. I never even heard 2 of it. 3 Q. Okay. So all that y'all did here is make 4 these different aroclors, and then as far as 5 you were concerned, that was a final product 6 ready to be shipped out to the customer? 7 A. Right. Once they were distilled or flaked, 8 they were bagged. 9 If they were distilled, they went OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035555 10 to a storage tank, and there was a tank car. 11 We'd load them on a tank car or either drum 12 them out. 13 Q. Now, were some of the montars sold rather 14 than just being landfilled? 15 A. I can't remember. I really don't--1 think 16 -- no, I don't know. 17 Q. Here on page DSW08-- 18 A. They probably could have been though. 19 Q. - 085400 20 A. They tried to recover everything. 21 Q. -- it describes the montars, and then it has 22 in parentheses 1,2,3,4,5,6,7,8 -- well, 6,7, 23 and 9. What do those numbers signify, if you 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 63 FOSHEE & TURNER COURT REPORTERS 1 know? 2 A. I think they're just based on where the 3 bottoms were from. Like montar nine would be 4 santowax or something. Montar one might have 5 been aroclor bottom. 6 Q. Okay. 7 A. But after reading this, I do remember them OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035556 8 using that for that later -- 9 Q. For the roofing? 10 A. Yeah. But that was what I was telling you 11 about Clegorn's Lake. They decided that 12 could be used. 13 I remember that part now. I was 14 telling you a while ago they'd melt that 15 stuff up, and I think they drummed it out 16 into a finishedproduct, youknow, whatever. 17 I don't know. I wasn'tinvolved in that, so 18 I just-- 19 Q. I mean, did they kind of mine Clegorn's Lake 20 or -- and take old stuff out of Clegorn's 21 Lake and-- 22 A. -- put it in a melting pot? 23 Q. Yeah. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 64 FOSHEE & TURNER COURT REPORTERS 1 A. Either that or those drums, or both. 2 Q. And by the "drums," you're talking about 3 these set of drums that -- 4 A. I don't know where they came from. They were 5 within the plant, but they were in storage OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035557 6 somewhere, I guess. 7 Q. But where were they? That's what I'm 8 wondering. 9 A. Well, I don't know. That's what I told you. 10 I don't know. 11 Q. You just remember there being some-- 12 A. They built a melting pot up there by 13 Clegom's Lake with burners on it, and this 14 solid material's put in there and melted. 15 Q. Put in the melting pot? 16 A. You know, it was originally liquid and then 17 we pumped itover there, and it was solid, 18 and then they discovered a use for it for the 19 customer and drummed it out. 20 Now, I don't know the process 21 except I remember the melting pot, and I do 22 remember at one time -- I wasn't even in 23 aroclor at that time. I was in the 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 65 FOSHEE & TURNER COURT REPORTERS 1 maintenance. But I can remember seeing them, 2 you know, with an ax or whatever, open up 3 those drums of solid and put it in that OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035558 4 melting pot. 5 And I remember them cleaning 6 Clegorn's Lake, and I think they did put that 7 in there too, you know, put it in a melting 8 pot. 9 Q. How did they clean Clegorn's Lake? 10 A. Backhoe. 11 Q. Just scooping out the -- 12 A. Yeah. 13 Q. -- stuff? 14 A. (Witness nods head.) It was, you know, 15 solid. 16 Q. What happened to Clegorn's Lake? 17 A. It~ 18 Q. Because it's not there now, is it? 19 A. Right. No. I think it was cleaned out 20 and -- 21 Q. Do you remember when? 22 A. No. 23 Q. Or about when? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 66 FOSHEE & TURNER COURT REPORTERS 1 A. I'd say -- no, I don't. You'll have to ask OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035559 2 somebody else those questions. That's one of 3 those hazy ones I can't -- 4 Q. Now, we talked about the liquid aroclors. 5 The solid aroclors 4465, 5460, and 5060, 6 would you rank those from the most poplar? 7 A. This is the least. 8 Q. 4465 was the least? 9 A. Yeah. 5060 was one that we used to make over 10 here that's primarily on number one and two 11 chlorinators, and that's the one we finished 12 with a melting point, you know. 13 And then when we pumped it up to 14 the still, when we distilled it, it became 15 5460, and that's when we would pump it to the 16 flaking tank that I was telling you about and 17 flake it. 18 Q. Right. And that was 5460 primarily? 19 A. When it was distilled, it was 5460. Just the 20 chlorinated product was 5060. 21 Q. How did you make 5460 because I don't have a 22 good -- 23 A. You don't have a feel for that? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 67 FOSHEE & TURNER COURT REPORTERS OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035560 1 Q. I don't have a good feel for that. 2 A. Well, let's just say the melting point was a 3 hundred and nine or whatever, you know, then 4 we knew it was finished, and we'd cut the 5 chlorine off and pump it to the still -- or 6 pump it to a holding tank, and then we'd 7 charge the still. 8 Q. I guess what I'm asking is: I think I 9 understand the liquid aroclors, that 10 continuum that, you know, you would add 11 chlorine to biphenyl until you got the 12 desired chlorine content or what you call 13 specific gravity. 14 A. Right. 15 Q. But what are the ingredients of 5460? Is it 16 simply biphenyl and chlorine or -- 17 A. That's what I was telling you. The 5060 -- 18 Q. Right. 19 A. -- was chlorinated biphenyl. 20 Q. Okay. 21 A. And we would chlorinate it until we got a 22 melting point, just kept -- you know, it was 23 a longer process. And then -- 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 68 OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035561 FOSHEE & TURNER COURT REPORTERS 1 Q. So if 1268 is 68 percent chlorine, what would 2 5060 be? More than that? 3 A. I don't know if that was 68 percent. If 4 that's what they said. I don't know what the 5 percentage -- 6 Q. That's my understanding of what those numbers 7 mean. 8 A. I don't know. 9 Q. That it's 68 percent chlorine by weight. 10 A. Yeah. It would be like--it would be a lot 11 more than that. I don't know what. 12 Q. Okay. So 5060 had more chlorine than 1268? 13 A. Definitely. 14 Q. Okay. But that's all it had was just--it 15 was just biphenyl that was morechlorinated 16 than 1268? 17 A. Right. 18 Q. Okay. 19 A. And then when you pumped it, when that 20 finished, then you pumped that to the still. 21 And you added lime to kind of neutralize it. 22 And it agitated or circulated with 23 a vacuum on it.And when it distilled -- OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035562 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 69 FOSHEE & TURNER COURT REPORTERS 1 well, when you put it up there, it was 5060. 2 It was just black, and when you distilled it, 3 it was yellow looking. 4 And then the other chlorinator 5 products were black until you chlorinated 6 them, and then they were -- see all these 12s 7 here were 11 s in the chlorinators. 8 Q. Right. 9 A. I didn't tell you that while ago. 10 Q. I got that. 11 A. It would be 1121, but when you distill it, it 12 becomes another number. 13 Q. I got that yesterday, so I understood that. 14 Okay. 15 A. I told you wrong while ago on 5060. 5060 is 16 chlorinated santowax, not biphenyl. I told 17 you biphenyl, but it's santowax. 18 Q. Okay. 19 A. All other materials is chlorinated. 20 Q. But isn't santowax a biphenyl product itself? 21 A. Yeah, yeah. 22 Q. So it would be a chlorinated biphenyl? OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035563 23 A. Well, in a sense, yeah. Santowax is the 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 70 FOSHEE & TURNER COURT REPORTERS 1 bottoms off of a biphenyl still. 2 Q. And it also indicates -- well, it says raw 3 materials are for -- the solid aroclors are 4 biphenyl, santowax are, and chlorine. So 5 would -- 6 A. I think the 4465 is probably -- I didn't make 7 any of that. I think that was -- that might 8 have been a biphenyl product. 9 Q. And then 4560 and 5060 were made with 10 santowax and chlorine? 11 A. That's right, yeah. And 5060 was -- I mean 12 5460 was just 5060 distilled. 13 Q. Okay. And again, santowax is simply biphenyl 14 that's been distilled? 15 A. No. 16 Q. Okay. 17 A. When you distill--you had--you have sump, 18 which they called it, that comes from your 19 tube units. Used to be lead plated, and they 20 feed that sump into a biphenyl still or OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035564 21 column and distill it and make biphenyl. 22 Well, the bottoms off of that, 23 instead of pumping the Clegom's Lake, 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 71 FOSHEE & TURNER COURT REPORTERS 1 they're not that type of material. You pump 2 them to the -- or used to -- pump them to the 3 santowax department and make santowax out of 4 it. 5 And then the bottoms off the 6 santowax, montar. 7 Q. Okay. 8 MR. PECK: Which you pumped to 9 Clegorn's Lake. 10 THE WITNESS: Which you pumped to 11 Clegom's Lake. 12 Q. (By Mr. Wright) And HB40 was hydrogenated 13 santowax? 14 A. That's right. That, the therminol, they 15 finished it by different -- just like they 16 do. 17 Q. Okay. Who else do you know that went up to 18 Delaware and gave a deposition? I've talked OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035565 19 to a couple of them, Dicky Walker and Nolen 20 Sims. 21 A. Jerry Sanford, Nolen -- I can't remember. I 22 think Mark Williams went up there. I don't 23 know anybody else unless -- I don't know if 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 72 FOSHEE & TURNER COURT REPORTERS 1 Don Curry went or not. 2 They would have a list I'm sure 3 that would. 4 Q. What was your understanding of why they were 5 having people go up there to give 6 depositions? 7 MR. PECK: Just a second. If your 8 only understanding of why you were going up 9 there to give a deposition came from 10 conversations with counsel, then I think that 11 would be privileged. If you have an 12 understanding you acquired elsewhere -- 13 Q. (By Mr. Wright) If anybody else except a 14 lawyer told you why. 15 MR. PECK: In other words, don't 16 tell him about communications you had with OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035566 17 Monsanto's attorneys, but if you know from 18 other ways, then tell him. 19 MR. WRIGHT: That's fair. I'm not 20 sure that that's the only way, but for the 21 deposition purposes, I'm not gonna argue 22 about it. 23 THE WITNESS: Only thing I knew 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 73 FOSHEE & TURNER COURT REPORTERS 1 about it was that this happened long after we 2 were operating. It was just some kind of 3 lawsuit. I don't know -- 4 Q. (By Mr. Wright) That's what I'm wondering. 5 Do you know who the lawsuit was between? 6 A. I don't really remember. 7 Q. Who asked you to go up there? 8 A. I think it was -- I'm sure it was my boss, 9 but I think -- I can't remember. I think it 10 might have been Jerry Brown or somebody like 11 that. 12 Q. Did Jerry Brown go up there and give a 13 deposition? 14 A. I don't know. OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035567 15 Q. Okay. Where were you working when the 16 aroclor plant shut down? 17 A. In'71? 18 Q. '71 or'72. 19 A. Probably in maintenance. Probably -- let's 20 see. I was in -- doing the laborers job 21 where I could go to -- 22 Q. What kind of things did you do? 23 A. -- school. 2001 PARK PLACE,SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 74 FOSHEE & TURNER COURT REPORTERS 1 Q. Did you work as a laborer in the aroclor 2 department? 3 A. No, that was different labor. Basically, we 4 just cut grass and clean up the offices and 5 stuff. Emptied -- anything that required 6 manual labor. 7 Q. Did you have to clean up spills and things 8 like that? 9 A. No. What we'd do was pick up trash and stuff 10 after them and carry it to the landfill or 11 whatever. 12 Q. Did you go to the landfill on a regular OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035568 13 basis? 14 A. We'd go up there occasionally, you know. 15 We'd carry trash and stuff up there on a big 16 wagon and empty it. 17 Q. When was the TP working? 18 A. TP? 19 Q. Yeah, TP incinerator? 20 A. I don't know the dates. They just -- like 21 paper and cardboard and stuff. 22 Q. Did you feed it from time to time? 23 A. No, never did feed it. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 75 FOSHEE & TURNER COURT REPORTERS 1 Q. Who was in charge of it? 2 A. I don't know who was in charge of the 3 landfill, really, unless -- Jerry Brown would 4 be the one you'd have to ask about that kind 5 of stuff. 6 It was a long way from being a 7 laborer to being in charge of anything, you 8 know. We were in charge of the wagon. 9 Q. When you say, "wagon," you mean a truck or -- 10 A. It was a big old long wagon with, you know, OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035569 11 where you pull it with a tractor. You get a 12 lot of stuff -- a lot of drums on it. 13 Q. And that's how you would move it is put it on 14 this big old wagon and then pull it with a 15 tractor up there? 16 A. Yeah. 17 Q. How would you get it off into the pit? 18 A. Manually. 19 Q. Just chunk those drums in the pit? 20 A. Sometimes, you know, we'd keep the drums 21 because it would just be wood and paper and 22 stuff. 23 Q. Just dump the drums out into the landfill? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 76 FOSHEE & TURNER COURT REPORTERS 1 A. Yeah. 2 Q. Did you ever take anything that you know went 3 to the incinerator? 4 A. To the TP? 5 Q. Yeah. 6 A. I'm sure we did. I don't remember that. 7 Q. You just don't have a recollection of that? 8 A. No, I really don't. OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035570 9 Q. Do you ever remember seeing it working? 10 A. I don't remember it being there long, or if 11 it was, I don't -- I just don't have that 12 recollection. Must have been in a period 13 there where I wasn't either -- 14 Q. When you were in a different job? 15 A. Yeah. 16 Q. Was anything else burned? 17 A. (Witness shakes head.) 18 Q. Were there any other trash fires or -- 19 A. No. 20 Q. -- anything like that? 21 A. (Witness shakes head.) 22 Q. I know there was an incinerator in the niran 23 facility. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 77 FOSHEE & TURNER COURT REPORTERS 1 A. Oh, yeah, inside the plant there. 2 Q. What was burned in that? 3 A. Well, I didn't work in niran. It was 4 residue, I think. 5 Q. Was it the kind of incinerator that you could 6 put something into, or was it simply that the OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035571 7 residue was piped into the incinerator? 8 A. Piped. 9 Q. I mean, it didn't have a door you could open 10 and throw stuff in? 11 A. No, no. 12 Q. Okay. 13 A. That was replaced by -- 14 Q. I'm sorry? 15 A. That was replaced by something called recycle 16 department. Eliminated anything. It was-- 17 Monsanto spent a lot of money on that. 18 Q. On the recycling process? 19 A. Yeah. 20 Q. When did that start coming in? 21 A. That was probably mid'70s. Something like 22 that. I don't know. 23 Q. Were you ever involved in sampling in the 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 78 FOSHEE & TURNER COURT REPORTERS 1 ditches, for example, or Snow Creek or 2 anything like that? 3 A. No, that would be the lab personnel. When I 4 was night superintendent, you know, I might OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035572 5 go out there with them just to observe 6 sometime. 7 Q. Go out there with who, the lab people? 8 A. Yeah. 9 Q. What were they sampling at night? 10 A. At night, nothing. I think -- we had a 11 continuous sampling twenty-four hours, and 12 they go out there, I think, early in the 13 morning and get a composite of it. 14 Q. What was it sampling? 15 A. The water leaving the plant. 16 Q. Now, is this the water that went into the 17 drainage ditch and went out under Clydesdale? 18 A. Now, you're referring to parathion, or are 19 you referring to aroclor? 20 Q. I'm referring to aroclor right now. 21 MR. PECK: Just to reorient you, 22 Larry, when he was superintendent, it was in 23 '76 or so. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 79 FOSHEE & TURNER COURT REPORTERS 1 MR. WRIGHT: I know, but I'm just 2 wondering if anybody ever sampled that water OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035573 3 then. 4 THE WITNESS: They sampled the 5 water everywhere. They were very, you know, 6 proactive. 7 Q. (By Mr. Wright) So some of the samples that 8 you would have seen them taking were samples 9 of the water going out the drainage ditch 10 under Clydesdale and on down to the river? 11 A. They sampled different points, yeah. 12 Q. Where do you remember them sampling in the 13 '70s after the aroclor department had shut 14 down? 15 A. Like I say, I went out with them a couple 16 times. They always sampled outside the plant 17 over there on -- close to the railroad track. 18 There was a point there they 19 sampled, and then every morning they'd sample 20 at the limestone pit in front of the plant. 21 Q. Taking it out of the limestone pit? 22 A. There was a pit down there they sampled 23 before it left the plant. I really didn't 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 80 FOSHEE & TURNER COURT REPORTERS OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035574 1 get involved in that that much. You would 2 see them sampling. 3 Q. Did they sample before the pit or in the pit 4 or after the pit? 5 A. I don't know. 6 Q. Okay. 7 A. You'd have to ask somebody in the lab that, 8 and they would be able to tell you more about 9 that. 10 Q. Somewhere in the area of the pit though? 11 A. Yeah. 12 MR. WRIGHT: That would be nice to 13 have a lab kind of guy next week because 14 that's one area -- 15 THE WITNESS: Don Yates used to do 16 that a lot. He's retired now. 17 Q. (By Mr. Wright) Is he still in the area? 18 A. Yeah. 19 MR. PECK: Don Yates would have 20 been a lab sampler? 21 THE WITNESS: That was his primary 22 duty. 23 MR. PECK: Is he on the list yet? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 81 OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035575 FOSHEE & TURNER COURT REPORTERS 1 MR. WRIGHT: I don't know. Let's 2 put him on there. 3 MR. FITE: I bet he will be. 4 THE WITNESS: I think I just put 5 him on it. 6 Q. (By Mr. Wright) Can you think of any others 7 in case we can't get him? 8 A. Any other what? 9 Q. Any other lab type people? 10 MR. PECK: Samplers. 11 THE WITNESS: Samplers? 12 Q. (By Mr. Wright) I don't want to just limit 13 it to samplers. 14 A. I'll tell you the person that would be - 15 keep using his name, but he was -- Jerry 16 Brown is - 17 Q. Yeah, I'm trying to figure out who else 18 besides Jerry Brown because I'm going to have 19 to depose him.He's been deposed a couple 20 times, and I'm trying to kind of save him for 21 last. 22 A. I would to. He's an Auburn man anyhow. 23 I think David Norton, he's in 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035576 1-800-888-DEPO 82 FOSHEE & TURNER COURT REPORTERS 1 charge of lab now, and he used to do that. 2 Q. Was he around in the 70s? 3 A. Probably. 4 Q. Any other guys from the '60s and 70s? 5 A. Yates would be your best bet. 6 Q. Okay. When did you hear about the aroclor 7 plant shutting down? 8 A. When did you say, 71? 9 Q. Was it right before it shut down? 10 A. Yeah. 11 Q. What did you hear about why it was shutting 12 down? 13 A. I don't know if it was--they were going to 14 make it at one plant like Krumrich and just 15 business reasons or what. Something along 16 those lines. 17 Q. When did you first hear about PCB 18 contaminationoff the plant site? 19 A. Probably in the "Anniston Star" in the last 20 few years, I guess. 21 Q. That's the first you remember hearing about 22 it? 23 A. Yeah. OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035577 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 83 FOSHEE & TURNER COURT REPORTERS 1 Q. Did you know that there was aroclor residue 2 in the drainage ditch and the creek 3 downstream down there by the railroad tracks 4 you were mentioning? 5 A. No, no. 6 Q. Nobody ever told you that to the best of your 7 recollection? 8 A. No. We figured any that went down the drain 9 would, you know, be probably in the limestone 10 pit. 11 Q. I need to object nonresponsive. What I was 12 asking is: Did anybody--nobody told you 13 that? 14 A. Told me that there was some in the ditch? 15 Q. Yeah. 16 A. No. 17 Q. Okay. Did you ever spend any time in the 18 neighborhood there around the plant? 19 A. No. Well, when I was night sup, and we'd 20 get, youknow, any kind of odor complaint, 21 that was our j ob to go out to whoever called, OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035578 22 and maybe sometime we'd talk to them. 23 Q. Do you remember doing that? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 84 FOSHEE & TURNER COURT REPORTERS 1 A. Do I remember doing it? 2 Q. Yeah. 3 A. Yeah, that was part of my job. And then we'd 4 go over there and see if we could detect any 5 odor. Because a lot of times it would be 6 just people wanting something out of 7 Monsanto, you know, free, and there wouldn't 8 be any odor over there. 9 A lot of times -- twice a year, 10 we'd have a turnaround, and they'd shut the 11 whole plant down, and they'd call while it 12 was down, you know. Y'all are going to have 13 to shut that -- of course you had to go over 14 there to be diplomatic about it, assure them 15 of everything. But, yeah, that's the only -- 16 Q. How many times do you think you went over 17 there and talked to people in the community? 18 A. In ten years, you know, I don't know. I'd 19 say -- most of the time, you didn't talk to OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035579 20 them. 21 One time a guy was waiting out in 22 the middle of the street on me, so I had to 23 talk to him. But -- 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 85 FOSHEE & TURNER COURT REPORTERS 1 MR. PECK: You mean you wouldn't 2 talk to them when you went into the 3 neighborhood? 4 THE WITNESS: No. We'd just go 5 where the address was. 6 Q. (By Mr. Wright) And see if you could smell 7 anything? 8 A. And see if we could smell anything and write 9 it up in our logbook. 10 Q. Okay. 11 A. And then if they happened to be out there, 12 we'd try to -- 13 Q. I guess I'm just wondering how many times you 14 remember talking to somebody in the 15 community? 16 A. Well, see, when you say, "community," -- 17 Q. In the neighborhood. OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035580 18 A. -- we might get complaints from, you know, it 19 might be on this side of the plant one time 20 and this side. I probably didn't make -- I'd 21 talk to them on the phone most of the time 22 when they'd call raising cane, and then I'd 23 tell them we'd come out and check on it. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 86 FOSHEE & TURNER COURT REPORTERS 1 I'd drive out there in a -- it had 2 a Monsanto emblem on it. Sometimes they 3 would come out. 4 Q. Can you remember -- I mean, was it a handful 5 of times, or was it twenty or thirty times? 6 A. Any time we got an odor complaint. I would 7 say not that often, but usually the same 8 people. A lot of the same people. 9 Q. Did you talk to those same people, or was 10 it~ 11 A. If I didn't have to, I didn't. 12 Q. Okay. About how many times do you remember 13 talking to people? 14 A. I don't know, you know. Any time they would 15 call with any kind of odor complaint. That's OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035581 16 all it was, and then, of course, that 17 diminished greatly. 18 Q. What were the main odors? Was it the sulfur 19 dioxide or hydrogen sulfide? 20 A. Both of those. 21 Q. Any other odors other than just those sulfur 22 type odors? 23 A. No, just mostly parathion odors, sulfur type. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 87 FOSHEE & TURNER COURT REPORTERS 1 Nothing that would hurt them, but it would be 2 -- in fact, most of the time when you got 3 over there, you couldn't smell it. 4 Occasionally, you could, and the whole world 5 knew it. 6 But from the -- it got less and 7 less, you know, as time went on because we 8 got better at it. 9 Q. What did parathion smell like? 10 THE WITNESS: Can you write this 11 down? 12 Q. (By Mr. Wright) Is there anything you can 13 relate it to? OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035582 14 A. Yeah. A lot of people say it smelled like 15 rotten cabbage, but it smelled, you know, it 16 didn't have a good - 17 Q. Kind of a sulfury smell too? 18 A. A little bit, but it was a mixture of smells. 19 Just mostly inside the plant though. Part of 20 the releases. 21 Q. Do you ever remember there being any air 22 monitoring for PCBs in the air? 23 A. We had monitors. Again, that was not my bag 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 88 FOSHEE & TURNER COURT REPORTERS 1 there. 2 Q. I know. 3 A. We had monitors for H2 add; we had monitors 4 for any kind of odors, and we had them -- in 5 fact, they actually paid people, you know, to 6 put them in their yards where they can -- 7 because Monsanto was good about community 8 type stuff. 9 Q. But do you know whether that was -- 10 A. You wouldn't really have to monitor PCB odors 11 because there wasn't any. OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035583 12 Q. I'm not talking about odors. I'm talking 13 about PCB content in the air. Do you 14 remember any monitoring? 15 A. I don't know. I don't remember any because 16 there really wasn't any -- it wasn't like 17 parathion. You would never smell it outside 18 the department, much less the plant. 19 Q. Did -- I assume -- well, let me not assume. 20 Did you hear anything about PCBs being an 21 environmental contaminant around the time 22 when the aroclor plant shut down? 23 A. Probably might have heard something in the 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 89 FOSHEE & TURNER COURT REPORTERS 1 news or something like that. I don't 2 remember it being -- 3 Q. You don't remember Monsanto saying anything 4 about it? 5 A. Best I can remember, it was like they shut it 6 down for -- because they didn't need to make 7 it at two locations, and Krumrich -- we 8 always thought we made the best. 9 In fact, we did make the best. A OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035584 10 lot of people designated they wanted Anniston 11 aroclor, but the Yankees won. 12 Q. K-r-u-m-r-i-c-h, I believe. 13 A. It was Krumrich or Queeny one. I think it 14 was Krumrich. 15 Q. It is Krumrich. I think you answered my 16 first question and not my second question. 17 A. What was your second one? 18 Q. My second one was: Did you hear anything 19 about PCBs being anenvironmental contaminant 20 around the time the plant was shut down? 21 A. Only if, you know, like it was in the news or 22 something like that. 23 Q. Okay. So your only source was newspaper or 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 90 FOSHEE & TURNER COURT REPORTERS 1 TV or magazines or something? It didn't come 2 from Monsanto? 3 A. It could have. I don't know. 4 Q. You don't remember? 5 A. I don't remember, no. That wasn't something 6 that I marked down. 7 Monsanto was good about keeping us OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035585 8 well informed of things though, you know. 9 Q. But you don't remember them informing you 10 about PCBs and health or environmental -- 11 A. They could have, and I might have heard it, 12 you know, on TV or whatever. I don't 13 remember exactly where I heard it. 14 Q. You don't remember any plant meetings or 15 anything like that to talk about the issue? 16 A. If it was an issue, we probably had a 17 meeting. 18 Q. Well, that's what I'm asking. Do you 19 remember it being an issue and having a 20 meeting? 21 A. That's what I'm telling you. I don't 22 remember. 23 Q. Okay. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 91 FOSHEE & TURNER COURT REPORTERS 1 A. But it wasn't like -- if it was an issue, it 2 wouldn't be, like, hidden because they were 3 always open about anything that was a problem 4 or something we needed to do to -- 5 Q. Well, that's what I'm asking. Monsanto had OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035586 6 meetings and presentations -- 7 A. Oh, yeah. 8 Q. -- about various things that -- 9 A. Right. 10 Q. -- it wanted to advise everybody about? 11 A. Right. And that might have been the case. I 12 just -- you call it having a senior moment. 13 I can't remember. 14 Q. I understand. What are the other things that 15 you remember Monsanto having meetings about 16 or presentations about over the years, just 17 some-- 18 A. Any time, you know, any kind of safety 19 problem, like you say, environmental problem, 20 new products, department shutting down, 21 whatever, they'd have a meeting and explain 22 in detail what was going on. 23 Q. Okay. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 92 FOSHEE & TURNER COURT REPORTERS 1 A. One I remember in particular. One Friday 2 went out there and a guy in there from St. 3 Louis said that's the end of parathion, so -- OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035587 4 I mean it was that quick. 5 Q. You remember that one? 6 A. I definitely remember that. 7 Q. What was the reason they gave for shutting 8 down parathion? 9 A. I think it was just -- it was either 10 environmental or too many -- I don't remember 11 that. I don't remember the exact reason. I 12 just remember it was huge. 13 Q. It was huge news? 14 A. It was huge. Two hundred people was laid 15 off. 16 Q. Yeah. You don't remember something similar 17 for the aroclor? 18 A. No. 19 Q. Okay. I think we're about finished. Let me 20 take about two minutes and check my memory 21 cells. 22 A. Okay. 23 (Short recess.) 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 93 FOSHEE & TURNER COURT REPORTERS 1 Q. (By Mr. Wright) I think I'm done. Thank OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035588 2 you. 3 4 (Deposition concluded at 11:30 a.m.) 5 FURTHER THE DEPONENT SAITH NOT. 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 94 FOSHEE & TURNER COURT REPORTERS OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035589 1 CERTIFICATE 2 3 STATE OF ALABAMA ) 4 CALHOUN COUNTY ) 5 6 I HEREBY CERTIFY that the above and 7 foregoing transcript was taken down by me in 8 stenotype, and the questions and answers thereto 9 were transcribed by means of computer-aided 10 transcription, and that the foregoing represents 11 a true and correct transcript of the testimony 12 given by said witness. 13 I FURTHER CERTIFY that I am neither 14 of counsel, nor of any relation to the parties to 15 the action, nor am I anywise interested in the 16 result of said cause. 17 18 19 20 21 TAMMY R. JENNINGS GREGORY Notary Public, State of Alabama 22 MY COMMISSION EXPIRES: 9-12-2001 23 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO OWENS 05-15-1988 Cambron, Bill.Vl.txt[8/22/2017 3:40:05 PM] HARTOLDMON0035590