Document 9Jr39d3025KXbxRRRd2pgMEwD

ERRATA SHEET The City of Bloomington ) ) Plaintiff ) CAUSE NO. IP83-9-C ) vs. ) ) Westinghouse Electric ) Corporation, et al, ) ) Defendants. ) (Deposition of William R. Gaffey) I wish to make the following changes for the following reasons: Page Line 5 16 Change: "Rausch" should be "Roush." Reason: Misspelling. Page Line 7 7 Change: "Lenshaw" should be "Henshaw." Reason: Misspelling. Page Line 22 22 Change: "trail" should be "trial." Reason: Misspelling. WATER PCB-00044649 Page Line 23 Page Line 38 11 Page Line 57 10 Page Line 57 14 Change: "trail" should be "trial." Reason: Misspelling, Change: ".035" should be ".05." Reason: Transcription error. Change: "close" should be "chose." Reason: Transcription error, Change: "Having made no literature search..." should be "Having made a literature search..." Reason: Transcription error. -2WATER PCB-00044650 Page Line 80 21 Page Line 88 16 Page Line 89 4 Page Line 100 11 Change: "manufacture" should be "man." Reason: Transcription error. Change: "antidotal" should be "anecdotal." Reason: Transcription error. Change: "symtomology" should be "symptomatology." Reason: Transcription error. Change: "Bomgardner" should be "Bumgarner." Reason: Misspelling. -3WATER PCB-00044651 Page Line 128 22 Change: "That's what they say" should be "They say that PCB's may represent a cancer risk to humans, not that they do represent such a risk." Reason: To reflect accurately what the studies say. Page Line 132 10 Change: "Yes, I do" should be "In fact, A the authors indicate that the^e may be a risk of cancer, not that there is a risk. In any case, I disagree with their conclusion." Reason: The question misstated what the Brown and Jones studies say. Page Line 134 5 Change: "Yes" should be "No, he found an increase that was not statistically significant." -4WATER PCB-00044652 Page Line 134 16 Page Line 134 17 Page Line 171 5 Reason: To reflect accurately what the study found. Change: "Yes, but a a different cancer site" should be "No, he found an increase that was not statistically significant, and that was at a different cancer site." Reason: To reflect accurately what the studies found. Change: "differ" should be "different." Reason: Transcription error. Change: "That's what they say, yes" should be "That was the conclusion in their first study, but they made no such conclusions in their second study." -5WATER PCB-00044653 Page Line 172 22 Page Line 188 5 Page Line 191 4 Reason: To reflect accurately what the studies say. Change: "And with the EPA" should be "And I disagree with the EPA when it uses risk assessment as if it were a scientific prediction of real risk rather than a non-scientific expression of policy." Reason: To make the answer clear. Change: "...and in those four studies..." should be "...and if in those four studies..." Reason: Transcription error. Change: "That's right" should be "One of the Jacobson studies addressed some neurological problems, but the second Jacobson study did not." -6- WATER PCB-00044654 Reason: To reflect accurately what the Jacobson studies addressed. Page Line 191 10 Change: "Neurologicalproblems" should be "neurological problems in their first study." Reason: To reflect accurately what the Jacobson studies addressed. Page Line 191 jl Change: "...measured was the baby's..." should be "...measured in the second study was the baby's..." Reason: To reflect accurately what the Jacobson studies addressed. Page Line 191 20 Change: "That'scorrect" should be"One of the Jacobson studies addressed some neurological problems, but the second Jacobson study did not." -7WATER PCB-00044655 Page Line 192 1 Page Line 193 2 Page Line 205 3 Reason; To reflect accurately what the Jacobson studies addressed. Change: That's their conclusion" should be "That's their conclusion in the first study." Reason: To describe Jacobson studies accurately. Change: "Sure" should be "I accept that IARC has established criteria and has used those criteria to classify various substances. I do not agree that the label 'probable human carcinogen' accurately describes the criteria established by IARC as Category 2." Reason: To state accurately my views about the IARC criteria. Change: "dye" should be "die. -8- WATER PCB-00044656 Reason; Transcription error. Page 205 Line 23 Change: "Yes" should be "I disagree that the EPA's characterization represents a scientific description of the actual carcinogenic potential of the substance; rather, it is a non-scientific policy decision. Many people in the EPA agree with me that the EPA's characterization is not a scientific judgment." Reason: To reflect accurately the nature and extent of my disagreement with some people at the EPA, and my agreement with other people at the EPA. Page Line 207 3 Change: "popur" should be "pour." Reason: Transcription error. Page Line 209 13 Change: If they have so called it, yes" should be "If they have so called it, yes, -9- WATER PCB-00044657 Page Line 213 19 Page Line 224 19 Page Line 228 12 but as far as I am aware, NIOSH has never classified PCB's as a probable human carcinogen." Reason: To reflect that the premise in the question - that NIOSH has classified PCB's as a probable human carcinogen - is not correct as far as I am aware. Change: "Ligginson" should be "Higginson. Reason: Misspelling. Change: "Singer" should be "Senger." Reason: Misspelling. Change: "...pcb a carcinogen by act of Congress" should be "...pcb a hazardous substance by act of Congress." -10- WATER PCB-00044658 Page Line 228 16 Page Line 228 21 Reason: To reflect accurately the Toxic Substances Control Act, which does not refer to PCB's as a carcinogen or make any judgment about PCB's as a carcinogen. Change: "PCB's are a carcinogen by..." should be "PCB's are a hazardous substance by..." Reason; Same as preceding change. Change: "...carcinogen" should be "hazardous substance." Reason; Same as preceding change. Deponent's signature -11- WATER PCB-00044659