Document GKyYJm2dKvaooj1wkBw6kKqpN

1 In Re: 2 Solutia, et al., 3 4 Vs. Case No. CV-03-PWG-134-E. 6 McWane, et al., 7 9 10 11 12 August 30, 2004 13 14 Videotaped Deposition of WILLIAM B. PAPAGEORGE, Volume I 15 16 17 18 19 20 21 22 23 24 1 Papageorge, William; McWane (Former Monsanto Employee; WATER PCB-SD0000050135 1 In the United States District Court 2 For the Northern District of Alabama 3 Magistrate Judge Green 4 5 Solutia, et al., 6 .............................. Plaintiffs 7 8 Vs.................................Case No. CV-03-PWG-134-E. 9 10 McWane, et al. , 11 .............................. Defendants. 12 13 14 15 16 17 18 Videotaped Deposition of WILLIAM B. PAPAGEORGE, taken 19 on behalf of the Defendants, at the offices of Husch & 20 Eppenberger, LLC, 190 Carondelet Plaza, Suite 600, in 21 the County of St. Louis, State of Missouri, between 22 the hours of 1:15 P.M. and 4:53 P.M. on the 30th day 23 of August, 2004, before J. Bryan Jordan, Certified 24 Court Reporter and Notary Public. 2 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050136 1 APPEARANCES OF COUNSEL: 2 FOR THE PLAINTIFF: 3 Joseph G. Nassif, Esq. 4 HUSCH & EPPENBERGER, LLC 5 190 Carondelet Plaza, Suite 600 6 St. Louis, MO 63105-3441 7 Telephone: 314-480-1500 8 Direct (314) 480-1818 9 Fax 314-480-1505 10 j oseph.nassif@husch. com 11 12 FOR MEAD WESTVACO: 13 Wendlene M. Lavey, Esq. 14 SQUIRE, SANDERS & DEMPSEY, L.L.P. 15 4900 Key Tower 16 127 Public Square 17 Cleveland, OH 44114-1304 18 Direct (216) 479-8545 19 Fax: (216) 479-8780 20 wlavey@ssd.com 21 22 23 24 3 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050137 1 FOR SCIENTIFIC-ATLANTA, INC.: 2 Lynette Eaddy Smith, Esq. 3 TROUTMAN SANDERS LLP 4 NationsBank Plaza, Suite 5200 5 600 Peachtree Street, Northeast 6 Atlanta, GA 30308-2216 7 (885-3489 8 Fax (404) 962-6688 9 lynette.smith@troutmansanders.com 10 11 FOR PHELPS DODGE: 12 Lynne Stephens O'Neal, Esq. 13 LEITMAN, SIEGAL & PAYNE, P.C. 14 600 North 20th Street 15 Suite 400 16 Birmingham, AL 85203 17 (205-251-5900 18 Direct (202) 986-5023 19 Fax (205) 323-2197 20 sls@lsppc.com 21 22 23 24 4 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050138 1 FOR LEE BRASS: 2 John Scott, Esq. 3 HUCKABY, SCOTT & DUKES 4 2100 Third Avenue North 5 Birmingham, AL 35203 6 (205) 251-2300 7 8 FOR HURON VALLEY STEEL: 9 Karen Pilat, Esq. 10 BUTZEL LONG 11 100 Bloomfield Parkway, Suite 200 12 Bloomfield Hills, MI 48304-2949 13 (248) 258-1616 14 Fax (248) 258-1439 15 pilat@butzel.com 16 17 FOR GII INDUSTRIES: 18 Raakhee Biswas, Esq. 19 BAKER BOTTS L.L.P. 20 The Warner, 1299 Pennsylvania Avenue, N.W. 21 Washington, District of Columbia 20004-2400 22 Telephone: 202-639-7707 23 Fax: 202-639-7832 24 raakhee.biswas@bakerbotts.com 5 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050139 1 FOR SOUTHERN TOOL: 2 Ms. Stacey H. Myers, Esq. 3 RESOLUTION LAW GROUP, P.C. 4 5335 Wisconsin avenue, N.W, Suite 305 5 Washington, DC 20015 6 (202) 686-4844 7 Fax 9202) 686-4843 8 shm@reslawgrp.com 9 10 FOR McWANE, FMC, AND UNITED DEFENSE: 11 Jarred O. Taylor, II, Esq. 12 MAYNARD, COOPER & GALE, P.C. 13 1901 Sixth Avenue North 14 Suite 2400 AmSouth/Harbert Plaza 15 Birmingham, AL 35203-2618 16 (205) 254-1061 17 Fax 9205) 254-1999 18 j taylor@mcglaw.com 19 20 6 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050140 FOR WALTER INDUSTRIES AND U.S. PIPE AND FOUNDRY COMPANY: Douglas S. Arnold, Esq. ALSTON & BIRD LLP One Atlantic Center, 1201 West Peachtree Street Atlanta, Georgia 30309-3424 (Fulton Co. ) Telephone: 404-881-7000 Telecopier 404-881-7777 darnold@alston.com FOR DATRON AND ANCHOR METALS: Michael S. McMahon, Esq. McMAHON, DeGULIS, HOFFMANN & LOMBARDI, LLP The Caxton Building - Suite 650, 812 Huron Road Cleveland, OH 44115-1126 (Cuyahoga Co Telephone: 216-621-1312 Telecopier 216-621-0577 mcmahon@mdhl.net 7 Papageorge, William; McWane (Former Monsanto Employee WATER PCB-SD0000050141 INDEX Examination by Ms. Lavey .................................................. 10 EXHIBITS Defendant's Exhibit1 ........................................................... 25 Defendant's Exhibit2 .......................................................... 61 Defendant's Exhibit3 .......................................................... 65 Defendant's Exhibit4 ........................................................... 81 Defendant's Exhibit5 .......................................................... 83 Defendant's Exhibit6 ........................................................... 88 Defendant's Exhibit7 .......................................................... 89 Defendant's Exhibit8 ........................................................... 98 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050142 1 THE VIDEOGRAPHER: We're on the record at 2 1:15 P.M. Today's date is August 30th, 2004. We're 3 at the offices of Husch Eppenberger. The address is 4 190 Carondelet Plaza, Clayton, Missouri. My name is 5 Curt Shaw, legal videographer, along with Jerry 6 Jordan, Certified Court Reporter, here today for the 7 deposition of William B. Papageorge, in the case of 8 Solutia, et al. vs. McWane, et al., currently pending 9 in the Northern District of Alabama, Cause Number 10 CV-03-PWG-1345-E. At this time, would counsel please 11 identify themselves for the record? 12 MS. LAVEY: This is Wendy Lavey, of Squire, 13 Sanders & Dempsey, representing defendant Mead 14 Westvaco Corporation. 15 MS. O'NEAL: Lynne O'Neal, from the Lietman, 16 Siegal & Payne firm in Birmingham, Alabama, 17 representing Phelps Dodge. 18 MS. MYERS: Stacey Myers, representing 19 Southern Tool. 20 MS. SMITH: Lynette Smith, of Troutman 21 Sanders, representing Scientific-Atlanta, Inc. 22 MR. TAYLOR: Jarred Taylor, with Maynard, 23 Cooper & Gale, representing McWane, FMC, and United 24 Defense. 25 MR. NASSIF: I'm Joe Nassif. I'm with Husch 9 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050143 1 Eppenberger, and I'm representing Pharmacia and 2 Solutia in the case. 3 MR. NASSIF: And the folks on the phone? 4 MR. SCOTT: John Scott, for Lee Brass. 5 MS. PILAT: Karen Pilat, for Huron Valley 6 Steel. 7 MR. ARNOLD: Doug Arnold, for Walter 8 Industries and U.S. Pipe. 9 MS. BISWAS: Raakhee Biswas, for DII 10 Industries. 11 MR. NASSIF: Michael McMahon, are you still 12 on the phone? 13 MR. McMAHON: Yes, I am. I was still in 14 mute. Sorry. Michael McMahon for Datron and Anchor 15 Metals. 16 THE VIDEOGRAPHER: Very good. Jerry, would 17 you, please, swear in the witness? 18 WILLIAM B. PAPAGEORGE, 19 of lawful age, having been first duly sworn to testify 20 the truth, the whole truth, and nothing but the truth 21 in the case aforesaid, deposes and says in reply to 22 oral interrogatories propounded as follows, to-wit: 23 EXAMINATION 24 QUESTIONS BY MS. LAVEY: 25 Q. Mr. Papageorge, my name is Wendy Lavey. I'm 10 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050144 1 an attorney with Squire, Sanders & Dempsey, located in 2 Cleveland. I represent Mead Westvaco Corporation, 3 which is one of a number of defendants being sued by 4 Solutia and Pharmacia in a lawsuit that relates to 5 operations in Anniston, Alabama. A couple of 6 preliminaries. I--we have agreed in advance with 7 Husch & Eppenberger that the--your deposition will be 8 restricted to half days, so we would expect to go 9 until an appropriate time today, 5:00 o'clock-ish, and 10 in addition, we had agreed in advance to waive the 11 seven-hour limitation, and hopefully, we will finish 12 on Wednesday morning. That's the goal. We will begin 13 again tomorrow at 9:00 A.M., again as only a half a 14 day. 15 I know you've been deposed before, but I 16 would ask that you be sure to speak clearly so that 17 the court reporter can hear you, as well as the 18 videographer. If you don't understand my question, 19 please ask me to clarify, let me know that you don't 20 understand the question. Otherwise, I'm going to 21 assume that you do understand the question. 22 If you need a break, let me know. 23 Otherwise, I would expect that we'll take a break when 24 the video needs changed, in about an hour and twenty 25 minutes, we'll take a break at that point, but if you 11 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050145 1 need a break sooner than that, just let us all know. 2 I gather that you are being represented 3 today by legal counsel from Husch & Eppenberger, 4 Mr. Nassif? 5 A. That is correct. 6 Q. Mr. Papageorge, what is your date of birth? 7 A. September 7, 1922. 8 Q. Where do you live, currently? 9 A. In the Town & Country, Missouri, which is a 10 suburb of St. Louis. 11 Q. What is the mailing address? 12 A. 63141. Oh, you want the whole address. I'm 13 sorry. 321 Pebble Valley Drive, St. Louis, Missouri, 14 63141-8039. 15 Q. Do you have an existing relationship with 16 Solutia, Pharmacia, or Monsanto? 17 A. Yes. 18 Q. What is that relationship? 19 A. The relationship with Solutia involves 20 medical coverage during my retirement, a term life 21 insurance. That's all that comes to mind now. With 22 Monsanto, I have a relationship relating to the 23 pension I receive. 24 Q. The pension is through Monsanto? 25 A. Yes. 12 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050146 Q. Are you currently serving as a consultant or a paid professional in any way for Solutia, Pharmacia, or Monsanto? A. In any way? Q. Yes. A. I'm serving as a consultant to a law firm which is involved with Monsanto and Solutia. Q. Okay. What is your consultant role? A. It's to relate to interested parties my experience with assignments in, originally, Monsanto, the old Monsanto, from the time I joined Monsanto until I retired, 1951 to 1986. Q. Are you on a paid retainer? A. With this law firm? Q. Yes. A. Yes. Q. What is the amount of that retainer? A. A thousand dollars a month. Q. Mr. Papageorge, did you review any written material in preparation for today's deposition? A. Written material? Q. Yes, sir. A. I hesitate because the only document I reviewed was my curriculum vitae,-Q. Okay. 13 Papageorge, William; McWane (Former Monsanto Employee WATER PCB-SD0000050147 1 A. --to see if it still is appropriate. 2 Q. Did you do anything else in preparation for 3 today's deposition, speaking with other individuals? 4 A. I spoke with attorneys. 5 Q. Okay. Anyone other than lawyers? 6 A. No. 7 Q. How much time overall would you say you 8 spent preparing for today's deposition? 9 A. I hesitate because you are not counting 10 travel time and all that involvement? 11 Q. No, I wasn't. 12 (Laughter.) 13 A. I thought so. I'm going to estimate about 14 eight to ten hours. 15 Q. Which lawyers did you meet with? Don't--I'm 16 not asking for the substance of your conversation, but 17 what lawyers did meet with in preparation? 18 A. I met with Mr. Mike Kelly. 19 Q. Is he with Husch & Eppenberger? 20 A. No. 21 Q. Who is he with? Do you know? 22 A. He's with Smith, Moore, LLP, Greensboro, 23 North Carolina. 24 Q. Hence, the traveling. Did you have to 25 travel to North Carolina? 14 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050148 1 A. No. 2 Q. Oh, okay. Anyone else? 3 A. Joseph Nassif. 4 Q. Mr. Papageorge, do you still have any 5 personal files or documents that relate to your time 6 of employment with Monsanto that you have in your 7 possession at home? 8 A. No, I do not keep any documents. 9 Q. I'd like to ask a few questions about your 10 education and training. We'll try, we'll do this 11 fairly quickly because I know you've testified as to 12 your education on a number of occasions, but could you 13 just trace briefly for us your higher education after 14 high school? 15 A. I have a Bachelor of Science Degree, a major 16 in chemical engineering from Washington University in 17 St. Louis, and that was awarded in 1943. I have a 18 Master of Science in chemical engineering from 19 Washington University that was awarded in 1947. 20 Q. Did you take any formal course work after 21 receiving your Master's of Science? 22 A. I have difficulty with the definition of the 23 word "formal." 24 Q. Did you begin, at the conclusion of 25 receiving your Master's Degree, did you begin studies 15 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050149 toward a further degree, a Ph.D., for example, at that point in time? A. I attended courses at Oklahoma, at that time it was called Oklahoma A&M in Stillwater, with the intent to pursue a Doctor of Science Degree. I also attended courses at Washington U., I think it was in 19, middle 1950's, or late 1950's, at Washington University in the business school for credits toward a business administration degree. Q. The course work at Oklahoma was in what area of study? A. Chemical engineering. Q. Did you receive any formal certification, as in a Professional Engineer's certificate or similar professional certificate? A. I was registered, and I'm still registered. Q. You are a Registered Professional Engineer? A. Professional Engineer in the State of Missouri Q. When did you become a Registered Professional Engineer? Do you recall the year? A. Late Fifties, early Sixties. Q. And does maintaining your Registered Professional Engineer status require that you take continuing education courses over some period of time? 16 Papageorge, William; McWane (Former Monsanto Employee WATER PCB-SD0000050150 1 A. I am currently emeritus member, so I don't 2 have to take any further courses. 3 Q. When did you go on emeritus status? 4 A. In the early 1990's. 5 Q. And prior to going on emeritus status in the 6 early 1990's, what type of continuing education was 7 required to maintain your registration as a 8 Professional Engineer? 9 A. I don't remember the details. I remember 10 filling out forms, and so on. It's been awhile. 11 Q. That's fine. After you obtained your 12 Master's Degree in chemical engineering, I think you 13 said, in 1947, did you become employed at that point 14 in time? 15 A. Yes. 16 Q. Where did you first go for employment? 17 A. I went to Bartlesville, Oklahoma, working 18 for the Phillips Petroleum Company. 19 Q. Was that in 1947? 20 A. Yes. 21 Q. How long were you at Phillips Petroleum? 22 A. Until November 1951. 23 Q. I'm going to do this as a quick overview and 24 then we'll step back. When you left Phillips 25 Petroleum November of 1951, where were you employed 17 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050151 1 next? 2 A. Monsanto Company in St. Louis. 3 Q. And for how long were you employed by 4 Monsanto? Or rather than doing the math, I'll ask you 5 what year did you leave Monsanto? 6 A. December 31st, 1986. 7 Q. Could you take us through the different 8 locations of your employment at Monsanto, beginning 9 with 1951? 10 A. Locations? Initially, St. Louis, Missouri, 11 area, and then the Sauget, S-a-u-g-e-t, Illinois, 12 location. 13 Q. And when you-14 A. Annis--I' m sorry. 15 Q. Go ahead. 16 A. Anniston, Alabama, and back to St. Louis. 17 Q. When you started at St. Louis, were you at 18 headquarters or at a manufacturing plant? 19 A. When I started? 20 Q. Yes. 21 A. It was at a manufacturing plant. 22 Q. And which plant was that? 23 A. The plant called John F. Queeny Plant. 24 Q. How long were you at the John F. Queeny 25 Plant? 18 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050152 1 A. Until, as best I remember, 1963-ish. 2 Q. Okay, and then you said you went to the 3 Sauget--am I pronouncing that right? 4 A. That is correct. 5 Q. The Sauget location, is that the Krummrich 6 Plant? 7 A. Yes. 8 Q. How long were you at the Krummrich Plant? 9 A. About a year. 10 Q. 1964 time frame? 11 A. I think it went through '63 and '64. It's 12 almost two years, mm-hmm. 13 Q. And then you said you next went to the 14 Anniston, Alabama, plant? 15 A. Yes. 16 Q. What was the period of time at the Anniston 17 Plant? 18 A. 1965 to the end of 1969. 19 Q. Okay, and then you indicated you returned to 20 St. Louis? 21 A. Yes. 22 Q. Was that to--that was to headquarters; 23 correct? 24 A. Yes. 25 Q. And from 1970 all the way through December 19 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050153 1 31st, 1986, then you were at the Monsanto headquarters 2 in St. Louis? 3 A. Yes. 4 Q. Going back to Phillips Petroleum, 1947-1951 5 time frame, describe generally for me your job 6 responsibilities at Phillips Petroleum. 7 A. In a general way, there are two types. 8 Initially, I was in, assigned to Phillips' research 9 department, involved with different studies related to 10 what is known as secondary recovery. This is when 11 water is introduced into a well system to push out the 12 oil in the producing wells. 13 Q. Mm-hmm. 14 A. That lasted about two years, and then the 15 final two years with Phillips, I was in the 16 engineering department that designed processes and 17 types of equipment used in petroleum processing. 18 Q. During any of the time at Phillips 19 Petroleum, did you have any involvement in or 20 responsibilities relating to PCBs? 21 A. No. 22 Q. Returning to the Queeny Plant, nineteen 23 fifty--late 1951 through 1963 or so, because I'm not 24 familiar with the area, where, where is the Queeny 25 Plant? 20 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050154 1 A. I don't know quite how to describe it. It's 2 near the Mississippi River, near an area that locally 3 is called the Soulard district. I don't know how else 4 to describe it. It's--it was on, I forget, 1800 South 5 Second Street or some such address. 6 Q. Is that plant still there? 7 A. To the best of my knowledge, yes. 8 Q. Can you walk us through the different 9 positions that you held at the Queeny Plant, beginning 10 in late 1951? 11 A. Initially, I was assigned to an engineering 12 design department, working on the design of equipment 13 to be used in processing chemicals. I was then 14 assigned as a supervisor in a production unit. 15 Q. Which production unit? 16 A. A unit that produced chemicals generally 17 known as plasticizers. These are materials that are 18 added to plastics to make them flexible, pliable, 19 instead of brittle. 20 Q. Did these particular plasticizers for which 21 you were a production supervisor contain PCBs? 22 A. No. 23 Q. Then I know I interrupted your train of 24 thought, but after the production supervisor position, 25 what came next? 21 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050155 1 A. I was sent, or assigned to the plant 2 engineering unit, where I supervised a team of 3 technicians, engineers, who were working on technical 4 problems related to producing units out in the plant. 5 Q. Was that in connection with a particular 6 production process, or for the entire Queeny Plant? 7 A. It was involved with a group of products 8 that were made out in the plant. 9 Q. Which group of products? 10 A. For example, the unit where I was 11 supervisor, making plasticizers, that would be one of 12 them. There was an assignment to two departments that 13 made ingredients that go in the plasticizers. One of 14 the units was one that I designed equipment for 15 earlier. There were several more, but at the moment, 16 I can't recall them specifically. 17 Q. Was the Queeny Plant manufacturingPCBs? 18 A. I'm sorry? 19 Q. Did the Queeny Plant manufacturePCBs at 20 that time period? 21 A. Whew. Will you help me with the word 22 "manufacture "? 23 Q. Were they--well, the production process, as 24 I understand it, once the biphenyls are produced, is 25 to then add the chlorine to chlorinate it. Is that a 22 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050156 1 production process that existed at the Queeny Plant? 2 A. No. 3 Q. It was Queeny Plant making any products that 4 contained PCBs while you were at the Queeny Plant? 5 A. Yes. 6 Q. Which products were they making? 7 A. There were a series of hydraulic fluids that 8 consisted of blends of PCBs with other ingredients. 9 That's all that comes to mind at present. 10 Q. So while the Queeny Plant was not making the 11 PCBs themselves, they were blending different PCB 12 materials to create a product? Is that correct? 13 A. That is correct. 14 Q. Going back to the time frame within the 15 Queeny Plant, you had indicated that you were 16 supervising a group of people who were responsible for 17 addressing different problems or different aspects of 18 productions out in the plant. Is there a title for 19 that, that job you were describing? 20 A. There was a title; as best as I recall, the 21 Technical Services Superintendent or some such, such 22 title. 23 Q. Do you remember the time frame for this 24 particular job description? 25 A. About 1963-ish. 23 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050157 1 Q. Now, you indicated that you left the Queeny 2 Plant in 1963-ish. Was that the last position that 3 you held? I'm not trying to test you on your memory 4 of the resume'. I'm just trying to line up the order, 5 here. 6 A. The dates don't come to mind clearly. 7 Q. Let me do it a different way, then. The 8 dates aren't that critical. After you were production 9 supervisor, was there a period of time when you were 10 within the Maintenance Department? 11 A. Yes. 12 Q. And was that prior to this Technical 13 Services Superintendent? 14 MR. NASSIF: Let me make a suggestion. 15 Bill's got a copy of his resume' in his pocket. Why 16 doesn't he just pull his resume' out and maybe that 17 will help? 18 MS. LAVEY: That would be fine. Do you want 19 to mark it as Exhibit-20 MR. NASSIF: Sure. That's fine. 21 MS. LAVEY: --1? 22 MR. NASSIF: I'm sure it's been in his other 23 depositions, but-24 MS. LAVEY: I don't have it with me or I'd 25 pull it out and make it Exhibit 1 for you. 24 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050158 1 MR. NASSIF: Why don't you do that? 2 (Defendant's Exhibit 1 3 marked for 4 identification.) 5 BY MS. LAVEY: 6 Q. May I take a quick look at what-7 A. Yes. 8 Q. --we've marked as Exhibit 1? 9 MS. LAVEY: For the record, then, Exhibit 1 10 is the curriculum vitae of Mr. Papageorge. 11 BY MS. LAVEY: 12 Q. Mr. Papageorge, looking at that, to continue 13 to clarify the different positions at the Queeny 14 Plant, let's go back and, and make sure we got this 15 right. Time frame as the--as a design engineer, I 16 believe, is the first one you talked about. Using 17 Exhibit 1 to the extent you need to to refresh your 18 recollection, what's the time frame for the design 19 engineer position? 20 A. The design engineer initially? 21 Q. Yes, sir. 22 A. 1951 through 1954. 23 Q. And is the production supervisor next in the 24 chronology? 25 A. Well, I'd like to make a,-- 25 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050159 1 Q. Go ahead. 2 A. --an addition to that statement. 3 Q. Okay. 4 A. The time period in '54, I still had the same 5 type of j ob, but I was promoted to Senior Chemical 6 Engineer, and that-7 Q. Okay. 8 A. --continued until 1955. 9 Q. Okay, and so for that time period, you were 10 designing equipment used in the processing of 11 different chemicals? 12 A. Correct. 13 Q. Correct? 14 A. Correct. 15 Q. Okay, then the next job that you held at the 16 Queeny Plant was what? 17 A. Production Supervisor. 18 Q. And that's when you were responsible for the 19 plasticizers group of chemicals? 20 A. That is correct. 21 Q. Okay, and for how long were you Production 22 Supervisor? 23 A. About a year. 1956. 24 Q. Following Production Supervisor, what was 25 your next job description? 26 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050160 1 A. Maintenance Supervisor. 2 Q. Can you describe generally for me what your 3 job duties were as Maintenance Supervisor? 4 A. As Maintenance Supervisor, I was assigned a 5 team of mechanics that installed equipment in small 6 projects, a pump and some pipeline, or some electric 7 wiring and some switches, that kind of thing; the 8 small jobs. 9 Q. All right, what followed your position as 10 Maintenance Supervisor? 11 A. I was made the Maintenance Superintendent. 12 Q. How did your duties change if they changed 13 when you became Maintenance Superintendent? 14 A. Well, this activity not only included the 15 small, new equipment installations but also included 16 the repair of the equipment in service throughout the 17 plant, the whole plant. 18 Q. While you were with--well, was there a 19 Maintenance Department-20 A. Yes. 21 Q. --at that time? While you were with the 22 Maintenance Department, did you have occasion to work 23 with any PCB-containing equipment such as transformers 24 or other electrical equipment? 25 A. I hesitate, because when you say "work 27 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050161 1 with," I did not personally put my hands on the 2 compressor or the heat exchanger. 3 Q. That's why you were the supervisor and the 4 superintendent. 5 A. I had--that's right. I had several hundred 6 people in that team that branched out and took care of 7 all those things. 8 Q. But the Queeny Plant did have some 9 PCB-containing equipment used in its--used in its 10 operations for which the Maintenance Department was 11 responsible to maintain? 12 A. That is correct. 13 Q. Did you have any specific obligations with 14 respect to handling of PCBs or conducting repair of 15 PCB-containing equipment? In other words, were you, 16 as superintendent, charged with the responsibility of 17 knowing how to handle PCBs by the Maintenance 18 Department workers? 19 A. Yes, but no different than all the hundreds 20 of other chemicals. 21 Q. That, that's fine, but--so correct me if I'm 22 wrong, but it sounds that--it sounds like your first 23 contact with PCBs as a class of chemicals wasn't until 24 you became a member of the Maintenance Department at 25 the Queeny Plant. 28 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050162 1 A. I don't recall any earlier contact, no. 2 Q. Okay, and the time period in the Maintenance 3 Department, either supervisor or superintendent, is 4 what? 5 A. From 1957 to 1959. 6 Q. And what is the next position, then, that 7 you held? 8 A. This is the position that we earlier talked 9 about where I supervised engineers and technicians in 10 working on engineering and technical problems for 11 certain operations out in the plant. 12 Q. Okay. Did any of those--you mentioned the 13 responsibility involved different groups of products. 14 You mentioned plasticizers, certain ingredients that 15 went into plasticizers. Did any of those 16 responsibilities involve the blending of any Aroclors 17 with other products? 18 A. Not that I recall. 19 Q. And how long were you Technical Services 20 Superintendent? 21 A. 1959 to 1961. 22 Q. What was your next job responsibility or job 23 title? 24 A. General superintendent of warehousing, 25 inventories, utilities. 29 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050163 1 Q. Could you describe generally what that 2 position entailed? 3 A. These are, these are the activities that 4 supported the manufacturing units in warehousing their 5 incoming raw material, or their shipping out of the 6 finished product, and it also involved the supplying 7 of what was called the utilities--electricity, steam, 8 gas--to the manufacturing units. 9 Q. In your role as general superintendent, 10 would you--did you have much involvement in dealing 11 with customers of the finished products at the Queeny 12 Plant? 13 A. No. 14 Q. Do you recall if there were any major 15 customers of the--you mentioned earlier hydraulic 16 oils. Were there major customers of the hydraulic 17 oils that you were shipping to from the warehouse? 18 A. I don't recall specific customers. 19 Q. Okay. Was that the last position that you 20 had at the Queeny Plant? 21 A. Yes. 22 Q. And after that, I believe you indicated you 23 went to the Krummrich Plant in Illinois? 24 A. Correct. 25 Q. Why did you leave the Queeny Plant? 30 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050164 1 A. Well, my supervisor told me go there. I 2 followed orders. 3 Q. Okay, what was your position at the 4 Krummrich Plant when you first arrived? 5 A. I was assigned a group of products produced 6 at the Krummrich Plant, in one of five different 7 manufacturing groups in the plant. 8 Q. Okay, let me step back, then, and ask first, 9 what were the five different groups that were within 10 the plant? 11 A. Huh. I don't re -- 12 Q. If you recall. 13 A. I don't remember 'em by the terms used at 14 that time. They--in general, I do remember three of 15 them were involved with products that were at that 16 time assigned to a group called the Inorganic--I mean 17 Organic, I'm sorry, Organic Chemicals Division. One 18 of them was involved with products that are referred 19 to as agricultural products, and another unit was 20 assigned to products called Inorganic. 21 Q. Were you assigned to one of those three 22 groups -- 23 A. Yes. 24 Q. --that you just identified? 25 A. Yes. 31 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050165 1 Q. Which group were you assigned to? Which of 2 the groups were you assigned to? The Organic, 3 Inorganic, or the Agricultural? 4 A. One of the--I'm sorry, one of the three in 5 the Organic Division-6 Q. Okay. 7 A. --was my group. 8 Q. And which was that? 9 A. I don't know that it had a unique name or 10 specific name, of just a cluster of separate, 11 unrelated operations. 12 Q. Which products were made out of that group? 13 A. Whew. 14 Q. Or can you generally classify the types of 15 products? It's not--I'm not asking a 16 product-by-product litany, but-17 A. I just don't remember specifically. 18 Q. Was it the Krummrich Plant manufacturing 19 PCBs ? 20 A. Yes. 21 Q. Was that an operation for which you had any 22 responsibility? 23 A. No. 24 Q. Did you have any responsibility for the 25 manufacturing of biphenyls? 32 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050166 1 A. No. 2 Q. Do you recall any of the names of the type 3 of products that were in the cluster of products for 4 which you were responsible? 5 A. No, I do not. 6 Q. While you were at Krummrich, did you have 7 any dealings at all with manufacturing at the biphenyl 8 plant or the Aroclor facility? 9 A. No. 10 Q. Do you recall the name of the Krummrich 11 Plant manager at that time? 12 A. No, I would be guessing. 13 Q. That's fine. Do you remember the name of 14 the individual who held your corresponding position 15 for the biphenyl production operations? 16 A. No, I do not. 17 Q. Do you have any knowledge of the process by 18 which biphenyls were produced at Krummrich? 19 A. No. 20 MR. NASSIF: A clarification: You mean 21 biphenyls or polychlorinated biphenyls? 22 MS. LAVEY: I meant biphenyls. 23 MR. NASSIF: Okay. 24 MS. LAVEY: 25 Q. Same answer? Still no? 33 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050167 1 A. Yes. 2 Q. I think you indicated you were at the 3 Krummrich Plant for approximately one year? Is that 4 correct? 5 A. Yes. 6 Q. And following that, that job, you then went 7 on to the Anniston Plant? Is that correct? 8 A. That is correct. 9 Q. When did you arrive at the Anniston Plant? 10 Do you recall the, the month? 11 A. Early part of the year. 12 Q. This is 1965, correct? 13 A. Yes. 14 Q. So early in 1965, and what, what was your 15 position when you arrived at the Anniston Atlanta? 16 A. Plant manager. 17 Q. Was there any--why did you move from the 18 Krummrich Plant to the Anniston Plant? 19 A. The boss said go, and I obeyed. 20 Q. Can you describe generally your job 21 responsibilities, please, as plant manager at the 22 Anniston Plant? 23 A. Well, I always felt it boils down to "buck 24 stops here." Everything that happened at the plant 25 was under my--was in my responsibilities. 34 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050168 1 Q. So your job responsibilities included having 2 an understanding of all the products that are 3 manufactured at the Anniston Plant at that time 4 period? 5 A. Have as much of an understanding as I could 6 possibly get. 7 Q. Did you go through any training when you 8 first arrived at the Anniston Plant? 9 A. You mean a formal training, or just a sort 10 of a walk-through, talk about? 11 Q. I'll start with the formal training, but I 12 think I know where this is going. 13 A. No, there was no formal training. It was a 14 day-by-day exposure and a continuing learning process. 15 Q. Okay. Did your job responsibilities require 16 that you have knowledge of, of sales and customer 17 relationships as plant manager? 18 A. It required knowledge, but I was not in the 19 same position, for example, as the marketing man who 20 sold to a group of customers in an area. I had an 21 idea of generally what customers were involved in 22 different parts of the country and the world, but not 23 very specific. 24 Q. How was, how was the marketing set up? In 25 other words, was it--is there a marketing department 35 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050169 1 that's reporting to you at the Anniston Plant or was 2 that handled at the headquarters level? 3 A. Marketing was handled at the headquarters 4 level. 5 Q. Did you have marketing staff at the Anniston 6 Plant? 7 A. No. 8 Q. Or sales, salespeople generally at the 9 Anniston Plant? 10 A. No. 11 Q. No. As the plant manager, then, you would 12 have had--your job responsibilities would have also 13 required that you have knowledge of the nature of 14 different waste streams and how they're managed at the 15 Anniston Plant? 16 A. I would have a broad knowledge of the 17 general scheme of things. I would leave the details 18 up to individuals in the plant who reported to me. 19 Q. To whom did you report as the plant manager? 20 A. I reported to the Director of Manufacturing 21 located in St. Louis. 22 Q. And who was that individual when you started 23 at the Anniston Plant in 1965? 24 A. Robert Soden, S-o-d-e-n. 25 Q. Was he still the Director of Manufacturing 36 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050170 1 when you left the Anniston Plant? 2 A. I don't remember the timing. 3 Q. You don't remember reporting to any other 4 individual as your direct line of report while you 5 were Anniston Plant manager? 6 A. I just don't recall the details. 7 Q. Obviously, we'll come back and talk about 8 the Anniston Plant some more, but I want to get a 9 little lay of the land after you left the Anniston 10 Plant. What was the, the month when you left the 11 Anniston Plant? I don't know if that's on Exhibit 1 12 or not, but when did you leave the Anniston Plant and 13 go back to St. Louis? 14 A. I don't remember the exact date, but there 15 was a period of time when I was officially assigned to 16 the Anniston Plant, but between jobs, I was going to 17 St. Louis fairly often in the late part of '69. 18 Q. Do you mean you were no longer the plant 19 manager of Anniston at that point and had taken on a 20 different job with Monsanto but just had not 21 relocated? 22 A. We were in a transition stage. I was 23 turning over the plant to the newly-assigned 24 individual. In the meantime, I was trying to get 25 organized back in St. Louis on a totally new job, so 37 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050171 there was a period, there, when I, I guess I was, in essence, wearing a couple of hats. Q. And was the--your successor at the Anniston Plant, is that Mr. Jesse? A. Yes. Q. Do you know if Mr. Jesse is still living? A. I do not. Q. Why did you leave the Anniston Plant and return to St. Louis? A. There was a perceived need by the management at Monsanto to assign someone to the specific task of following the PCB issue, which was evolving, and since I was more generally involved with PCBs, as distinguished from analytical, and sampling, and the detail work, management thought that I was the best candidate to serve as the individual within Monsanto who could follow the issue and sort of left--let the left hand know what the right is doing within Monsanto and keep abreast of all the developments occurring worldwide on this new issue. Q. At that point in time, PCBs were being manufactured at the Anniston Plant and Krummrich? Is that correct? A. Uh-- Q. Let me cancel that question. Let me just 38 Papageorge, William; McWane (Former Monsanto Employee WATER PCB-SD0000050172 1 ask, at that point in time when you went back to 2 St. Louis for this position you are, you are starting 3 to describe, where was Monsanto manufacturing PCBs at 4 that time? 5 A. In the United States? 6 Q. Yes, sir, in the United States. 7 A. Anniston and the Krummrich Plant, Sauget, 8 Illinois. 9 Q. Okay. Now, walk--I would like to walk 10 through your different positions, then, back at--in 11 St. Louis. This is in the headquarters office,-12 A. Yes. 13 Q. --I assume? Okay, and what was the--what 14 was the first position that you held, or you've been 15 describing this, this overall responsibility for the 16 evolving PCB issue. Did that come with a job title? 17 A. Well, the job title did not mention PCBs, 18 but it's the first job within Monsanto where the title 19 contains the word "environment." 20 Q. Okay. 21 A. Manager, Environmental Control. 22 Q. Were your responsibilities broader than 23 those associated with the evolving PCB issues? 24 A. At that time, specific to PCBs. 25 Q. And how long was that your job 39 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050173 1 responsibility, this Manager of Environmental Control? 2 A. Until 1973. 3 Q. And how did your job change in 1973? 4 A. There was two changes. One is the, the 5 group that used to be called the Organic Division was 6 entitled "Monsanto Industrial Chemical Company," and I 7 was assigned all the products in that company, in 8 addition to PCBs, and given the title Manager-Product 9 Acceptability." 10 Q. And what, generally, were your job 11 responsibilities as the Manager of Product 12 Acceptability? 13 A. My job responsibility was to make sure that 14 the products assigned to Monsanto Industrial Chemical 15 Company met the known criteria for acceptable products 16 in terms of safety, purity, proper usage, proper 17 handling, the whole gamut. 18 Q. Other than PCBs and PCB-related products, 19 what other type products were within this, the--what 20 you've described as the Monsanto Industrial Chemicals 21 Company? 22 A. There's so many, I know-23 Q. Can they be generally classified? I don't 24 need to know the detailed listing, but-25 A. Well, generally, that's what the title 40 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050174 1 "Industrial Chemicals"-2 Q. Okay. 3 A. --implies. There were the plasticizers we 4 talked of earlier. I just don't remember them all. 5 There's -- 6 Q. That would be the organic, the organic 7 chemicals? 8 A. I'm sorry. 9 Q. These, all of them, would involve organic 10 chemicals, or was there some inorganics? 11 A. Most of them were the original organic 12 chemicals grouping, but as I remember, they picked up 13 additional chemicals from other parts of Monsanto. 14 Q. Did it include some of the agricultural 15 products ? 16 A. I don't think so, no. 17 Q. Was the Monsanto Industrial Chemicals 18 Company a standalone--an independent company separate 19 from Monsanto Chemical Company? 20 MR. NASSIF: I'm going to object on lack of 21 foundation. Go ahead if you can answer. 22 A. I have--I don't have information that helps 23 explain that. 24 BY MS. LAVEY: 25 Q. Okay. 41 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050175 1 A. This is an upper management decision to use 2 these groupings and their titles. 3 Q. Who were you reporting to as the Manager of 4 Product Acceptability for Monsanto Industrial 5 Chemicals Company? Let me narrow the time period for 6 you. That may not help you, but I'm asking at the 7 beginning of this time, so it's 1973. 8 A. Mm: I'd be guessing. I don't remember. 9 Q. With respect to PCBs, did your job 10 responsibilities change between when you were focused 11 only on PCBs as Manager of Environmental Control and 12 then in 1973, you picked up other chemicals, as well? 13 Just looking at the PCB part, did your job 14 responsibilities change from 1970 to 1973? 15 A. They changed to a degree. As I remember, 16 there was an individual within Monsanto who picked up 17 the PCB issues within the company. I maintained the 18 responsibilities relating to the rest of the world and 19 PCBs; foreign producers, foreign governments, 20 foreign--or outside laboratories, and the like. 21 Q. Who was the individual, then, that assumed 22 the responsibilities within the company? 23 A. John Craddock. 24 Q. How do you spell the last name? 25 A. C-r-a-d-d-o-c-k. 42 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050176 1 Q. Was he located in St. Louis? 2 A. Yes. 3 Q. How long were you the Manager of Product 4 Acceptability? 5 A. It would be less than a year, about a year. 6 Q. Okay, what was the next position, then? 7 A. The next position was entitled Director, 8 Environmental Operations for that same Chemical 9 Intermediates Company. 10 Q. You said that same chemical intermediates 11 company, is this a new name at that point in time? 12 A. No, that's the same as the one back in 1977. 13 Q. Okay, I don't think we talked about 1977. 14 We were --in 1973, you became Manager of Product 15 Acceptability for Monsanto Industrial Chemicals 16 Company. 17 A. Correct. 18 Q. Okay. 19 A. Oh. 20 Q. Did we skip a step? I don't know what the 21 intermediate company is. 22 A. That was another change within Monsanto in 23 naming the different parts,-24 Q. Okay. 25 A. --and that happened in 1977. 43 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050177 1 Q. All right, and then in 1977, you were named 2 the Director For Environmental Operations for Monsanto 3 Intermediate Chemicals Company? 4 A. Chemical Intermediates Company. 5 Q. Okay, and could you describe your, your 6 responsibilities as the Director of Environmental 7 Operations as of 1977? 8 A. It included the responsibilities as it 9 relates to product acceptability, and also added to 10 that was a responsibility as it related to industrial 11 hygiene, both to customers, employees, and Monsanto 12 employees, and the general public. 13 Q. What do you mean by "industrial hygiene"? 14 What's that phrase mean to you? 15 A. To me, it means the awareness of what 16 different materials handled in the plant by the 17 workers are, and what they can do if improperly 18 handled in terms of health effects. 19 Q. What was your next position after Director 20 of Environmental Operations For Chemicals, 21 Intermediate ? 22 A. The next position was, again, a Monsanto 23 reorganization and renaming. The unit that was --to 24 which I was assigned was then called Monsanto 25 Industrial Chemicals Company. 44 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050178 1 Q. Okay. Did your job responsibilities change 2 or was this just a change in name? 3 A. The responsibilities as described didn't 4 change, but the products that were assigned to that 5 were changed. Some products remained with the team I 6 had and new products were added, and some of the older 7 products were transferred to another part of Monsanto. 8 Q. By this point in time, PCBs were no longer 9 being manufactured; correct? 10 A. That's true. 11 Q. So presumably, they were not in your job 12 responsibility at that point in terms of production 13 operations. 14 A. They were not included as it relates to a 15 product manufactured, sold, shipped, and handled 16 elsewhere, but they were related to inquiries, 17 questions from anywhere relating to PCBs, and they 18 were related to addressing the presence of PCBs in 19 those facilities that, at one time within Monsanto, 20 handled them. 21 Q. Was that the last position, or--I'm not sure 22 if we're done through the end, here. Let's see: This 23 was Director of Environmental Operations for Monsanto 24 Industrial Chemicals. Was there any subsequent 25 position? 45 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050179 1 A. Yes. In '86, I was assigned to what was 2 called Occupational Health. This is what we earlier 3 called Industrial Hygiene, this is products and effect 4 on workers within Monsanto, and this particular 5 assignment put me in the position where I dealt with 6 Monsanto's Medical Department in making the necessary 7 communications between all of the plants in Monsanto 8 and the Medical Department. This did not limit itself 9 to pieces of Monsanto. 10 Q. Did you continue, then, to have, in 1986, 11 responsibility on the PCB issues? 12 A. If it came up, yes, it would come to me, 13 mm-hmm. 14 Q. So throughout the time frame of 1970 through 15 1986, when you were back at Monsanto's headquarters in 16 St. Louis, throughout that--for that span of time, you 17 had responsibility that included following and 18 responding to PCB-related issues that came up? 19 A. Yes, following, but I also had some 20 assistance in my team to help me. 21 Q. Sure. I'm just trying to get an 22 understanding that that responsibility, although you 23 had different people working with you over time, 24 continued over that span and you had other jobs coming 25 and going, as well, that I'm less interested in, but 46 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050180 1 there's a continuous period, really, of 1970 through 2 1986 when on your list of things to do, PCBs were on 3 that list. 4 A. Yes. 5 MR. NASSIF: I object to the form. 6 THE WITNESS: Hmm? 7 MR. NASSIF: You are fine. I was trying to 8 figure out with that was a question. 9 MS. LAVEY: It just means I didn't ask a 10 very good question. 11 THE WITNESS: I thought she was summarizing. 12 MS. LAVEY: I had something mine head, and 13 that's all I needed at the moment. 14 BY MS. LAVEY: 15 Q. After relocating to St. Louis, did you have 16 occasion to return to the Anniston Plant at any time? 17 A. Yes. 18 Q. Um, do you recall how often you 19 returned--well, let me strike that. 20 Do you recall the first time that you 21 returned to the Anniston Plant once you had relocated 22 back to St. Louis? 23 A. The specific date, I don't remember, but it 24 was in '71 time period. 25 Q. About how often did you return to the 47 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050181 1 Anniston Plant? 2 A. When you said "About," that's the best I can 3 do. I can't remember. I didn't keep any score sheet, 4 but--whew, I don't know, three, three to six times. 5 Q. Over what span of time? I mean, three to 6 six times over the whole period after you had left, or 7 is that a per-year number, or -- 8 A. No, the whole -- 9 Q. Okay. 10 A. --since I left. 11 Q. Okay. When is the last time you were in 12 Anniston, Alabama? 13 A. Again, I'm guessing a bit. Three to five 14 years ago. 15 Q. When you first went to St. Louis in 1970, 16 was there a primary point of contact back at the 17 Anniston Plant for you? 18 A. I have trouble with the word "primary." My 19 primary, of course, is the plant manager, but that 20 didn't mean that I avoided his team. I could go 21 directly to them to get the specifics of the 22 activities. 23 Q. Maybe it would help me if I figure out the 24 organization at Anniston, then. When you first 25 arrived at the Anniston Plant in 1965 as the plant 48 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050182 1 manager, can you describe how, how the management team 2 was structured at that time? In other words, who's 3 reporting to you? 4 A. I'll try,-5 Q. Okay. 6 A. --as best as my memory will help me. I had 7 two manufacturing superintendents, Art Leisy and 8 Robert Moody. 9 Q. Do you remember how to spell Mr. Leisy's 10 last name? 11 A. I'm sorry? 12 Q. Do you recall the spelling of Mr. Leisy, I 13 think you said? 14 A. L-e-i-s-y. 15 Q. I won't hold you to it if that's not right. 16 A. It's either -e-i or -i-e. That's why I 17 hesitate. 18 Q. They were both manufacturing 19 superintendents-- 20 A. Yes. 21 Q. --for you in 1965? 22 A. Correct. 23 Q. Did they have different areas of the plant 24 that they were responsible for? 25 A. Yes. Mr. Leisy had the unit that produced 49 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050183 1 the boll weevil insecticide, and Mr. Moody had the 2 rest of the operations. 3 Q. So that would include the Aroclor facility, 4 the biphenyl production-5 A. Yes. 6 Q. --was all Mr. Moody? 7 A. Yes. 8 Q. Was he at the plant prior to your arrival, 9 do you recall? 10 A. Yes. 11 Q. Was he still the manufacturing 12 superintendent when you left at the end of 1969? 13 A. No. 14 Q. Did somebody else have that job 15 responsibility, then, during your tenure as plant 16 manager? 17 A. Yes. I'm trying to recall who it was. I 18 can't think of his name at the moment. 19 Q. That's okay. Do you know if Mr. Moody is 20 still living? 21 A. No, he is deceased. 22 Q. As you said, you had two manufacturing 23 superintendents reporting directly to you. 24 A. Correct. 25 Q. And then I'm sure I interrupted you. Who 50 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050184 1 else was reporting to you? 2 A. There was at that time called a personnel 3 superintendent, Jack Aldridge. 4 Q. What were his job responsibilities? 5 A. He's the individual that concerned himself 6 with hiring people. 7 Q. Was the Anniston Plant a union shop? 8 A. Yes. 9 Q. Would Mr. Aldridge have had the 10 responsibility for negotiating with the union and 11 addressing union grievances, for example? 12 A. He would set up the grievances and would be 13 involved in initiating renewal of contracts. 14 Q. Okay, who else had a direct report to you? 15 A. Lou Fuhrmeister. -m-e-i-s-t-e-r, I think, 16 is the way he spells it, F-u-h-r-m-e-i-s-t-e-r. He 17 was the superintendent in charge of the group called 18 Technical Services: Engineering, chemical, laboratory 19 testing. 20 Q. By that, you mean all of the engineers were 21 within the Technical Services Group? 22 A. Well, there were many engineers that were 23 also production supervisors, there were many engineers 24 were maintenance supervisors, so I can't say all 25 engineers, but the engineers actively pursuing 51 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050185 1 engineering problems. 2 Q. Let me step back and ask if you could give 3 me a general description of the purpose of the 4 Technical Services Group or Department. 5 A. That department was to support the plant in 6 any scientific matters that would help make better 7 products, also produce more products. If you required 8 another pump, or another tank, or a different process 9 that made more material than the old process using the 10 same starting material; that kind of activity. 11 Q. So the Technical Services Department 12 reported directly to you or to St. Louis? 13 A. The one in the plant reported to me through 14 Mr. Fuhrmeister. 15 Q. Okay. Was Mr. Fuhrmeister the 16 superintendent of that group for the entire period 17 when you were plant manager? 18 A. No. No. 19 Q. Was there a subsequent individual in that 20 position? 21 A. Yeah, he was replaced by Joseph Landwehr. 22 Q. L-a-n-d-w-e-h-r? 23 A. -h-r. Correct. 24 Q. Do you recall what year he, Mr. Landwehr, 25 became the superintendent? 52 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050186 1 A. No, I don't. 2 Q. It was while you were plant manager, though? 3 A. Yes. 4 Q. Was he still in that position when you left? 5 A. Yes. 6 Q. Do you know if Mr. Fuhrmeister is still 7 living? 8 A. The last I heard, he was, but that doesn't-9 Q. I understand. 10 A. That's not recent. 11 Q. How about Mr. Landwehr? 12 A. I understand Mr. Landwehr is deceased. 13 Q. Do you know if the Technical Services Group 14 continued in existence after you left as plant 15 manager? 16 A. Yes. 17 Q. Do you recall the names of any subsequent 18 superintendents after you left Anniston? 19 A. Any subsequent who? 20 Q. Superintendents. 21 A. Superintendents? 22 Q. Of the Technical Services Group. 23 A. No . 24 Q. Anyone else who's got a direct report to you 25 as plant manager that we haven't covered? We have two 53 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050187 manufacturing superintendents, the personnel superintendent, technical services superintendent-- A. I'm trying to recall the name of the maintenance superintendent, and at the moment, I just cannot recall it. MS . LAVEY: Is he waving? MR. NASSIF: Yeah, time to stop the tape. MS . LAVEY: Why don't we take a five-minute break? MR. NASSIF: Okay. MS . LAVEY: At our midway point, here, width. THE VIDEOGRAPHER: This will end tape number 1 in the deposition of William B. Papageorge. We're off the record at 2:35 P.M. (Recess.) THE VIDEOGRAPHER: We're back on the record at 2:38 p.m. This is tape number 2 in the deposition of William Papageorge. BY MS. LAVEY: Q. Mr. Papageorge, we were talking through the different organizational positions that had a direct report to you as plant manager in Anniston. I just want to be sure that we ended up covering all of them There were the two manufacturing superintendents, a 54 Papageorge, William; McWane (Former Monsanto Employee WATER PCB-SD0000050188 1 personnel superintendent, superintendent of Technical 2 Services, and a maintenance superintendent. Is there 3 any other job responsibility that was a direct report 4 to you? 5 A. Yes, there was a, uh, individual in charge 6 of warehousing, shipping, waste hauling. He was the 7 individual that assisted the Manufacturing Group in 8 areas other than maintenance. I cannot remember his 9 name. The best I remember, it started with an "s." 10 Q. Well, that narrows it down. 11 (Laughter.) 12 A. That arrows it down. Only takes the other-- 13 Q. Okay, but that person in that position 14 directly reported to you, as well as -- 15 A. Yes. 16 Q. Okay. Do you remember the position that 17 held at any point in time? 18 A. It was the same person-- 19 Q. Okay. 20 A. --for years and years. 21 Q. Any other positions that directly reported 22 to you as plant manager? 23 A. Well, there was the part-time plant 24 physician. 25 Q. Okay. Any other positions? 55 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050189 1 A. I can't recall any at the moment. 2 Q. Do you remember any written organizational 3 charts describing the organizational structure at the 4 Anniston Plant? 5 A. Do I recall the organization chart? 6 Q. Were there any written charts? 7 A. I just don't remember seeing one. 8 Q. I'd like to go back and try to get the 9 succession of plant managers in order. They 10 have--obviously, you were plant manager at the 11 Anniston Plant in 1965 through somewhere in late 1969. 12 You indicated earlier you were then replaced by 13 Mr. Jesse. 14 A. Correct. 15 Q. Do you recall who the plant manager was 16 before you? 17 A. John McClain, M-c capital C-l-a-i-n. 18 Q. Do you know if he is still living? 19 A. I do not. 20 Q. Do you recall any plant managers prior to 21 Mr. McClain? 22 A. Yes, I do remember: Desmond Hosmer, 23 D-e-s-m-o-n-d, H-o-s-m-e-r. I don't know the dates, 24 though, just whether Mr. McClain followed him or not, 25 but I know Mr. Hosmer was a plant manager there. 56 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050190 1 Q. Do you know if Mr. Hosmer is still living? 2 MR. NASSIF: He's deceased. 3 MS. LAVEY: Thank you? 4 A. I think he's deceased, yeah. That's why I 5 want to make sure. 6 BY MS. LAVEY: 7 Q. Do you know how long Mr. Jesse was plant 8 manager at Anniston Plant? 9 A. No, I don't. I don't remember. 10 Q. Do you know who became plant manager after 11 Mr. Jesse? 12 A. No. 13 Q. Do you recall any other individuals who had 14 the position as the superintendent of the Technical 15 Services Department other than Mr. Fuhrmeister, 16 Mr. Landwehr? 17 A. That's all I remember. 18 Q. How many people were in the Technical 19 Services Group? 20 A. I don't remember. 21 Q. Could you approximate if it's less than ten, 22 more than 25? Roundabout approximation? 23 A. It's just pure guess. 24 Q. Okay. 25 A. I -- 57 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050191 1 Q. Who would have had--did somebody have 2 responsibilities related to environmental matters 3 while you were plant manager? 4 A. Yes, that fell in the domain of 5 Mr. Fuhrmeister, Mr. Landwehr, and they, of course, 6 had individuals reporting to them who followed the 7 details. 8 Q. Do you remember the names of any of those 9 individuals? 10 A. I remember a Gene Cooley. I think he 11 spells it C-double-o-l-e-y, but I'm not certain. 12 Q. Do you remember a Eugene Wright? 13 A. Yes. Eugene Wright followed Mr. Cooley. 14 Q. And Mr. Wright, Mr. Cooley would have 15 reported to September of the Technical Services 16 Department? Is that correct? 17 A. Correct. 18 Q. Do you recall any other individuals with 19 responsibilities relating to environmental matters? 20 A. I recall a Jerome Brown, Jerry Brown, but I 21 don't recall the exact assignment he had, and I recall 22 a individual the last name of Turner who became the 23 analytical chemist on PCBs. 24 Q. I think you mentioned that the--there--did 25 you say that there was a lab, laboratory function 58 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050192 1 within the Technical Services Department? 2 A. Yes. 3 Q. And was there an on-site lab? 4 A. Yes. 5 Q. What was the lab used for? 6 A. Oh, to analyze the finished products or the 7 intermediates, to see that they were ready for further 8 processing. They also analyzed, on occasion, the raw 9 materials that arrived, to see that they met the 10 specifications we asked for. 11 Q. Was there a person responsible overall for 12 the laboratory function? 13 A. Yes, Gerald Miller rings a faint bell. I 14 associate him with the laboratory. 15 Q. I know you said you didn't recall the name 16 of the superintendent of the Maintenance Department. 17 Do you recall the names of any individuals in the 18 Maintenance Department while you were plant manager? 19 A. Not at the moment, no. 20 Q. Do you remember something called the 21 Corporate Development Committee? 22 A. Yes, I remember the title. It was a 23 high-level committee of--containing members of top 24 management in Monsanto. 25 Q. So it was in St. Louis? 59 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050193 1 A. Yes. 2 Q. Do you recall the purpose of the Corporate 3 Development Committee? 4 A. I don't know that I can describe it the way 5 that they would describe it. They--I perceive them as 6 being the top management group that made decisions 7 concerning the corporate aims, objectives, 8 organization, practices. They made all the 9 suggestions that the corporate board of directors 10 would consider and approve, or disapprove, or modify. 11 Q. Were you ever a member of the Corporate 12 Development Committee? 13 A. No. 14 Q. Do you recall any people, any individuals 15 who were a member of the Corporate Development 16 Committee? 17 A. I'd be guessing. That's -- 18 Q. Did you ever make any--have any occasion to 19 make any presentations to the Corporate Development 20 Committee, whether in writing or oral? 21 A. I believe, yeah, I was involved, at least 22 one presentation. 23 Q. And what kind of presentation was that? 24 A. This was a presentation relating to the PCB 25 evolving issues, and it would also include 60 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050194 1 recommendations regarding some activities that could 2 take place rather in a hurry, and then it also made 3 recommendations to progress in certain steps that I 4 have forgotten now. 5 Q. Was this a written presentation? 6 A. It was written in that I read from notes, 7 but the audience just received the verbal discussion. 8 Q. Do you remember the time period for this 9 presentation? 10 A. I'm sorry? 11 Q. Do you recall when this presentation was 12 given? 13 A. It was after I was appointed the--with the 14 job title Manager, Environmental Control, so that 15 would have been in 1970. 16 Q. Mr. Papageorge, I'm going to hand you a 17 document that I'll ask the court reporter to mark as 18 Exhibit 2, ask you to take a look at it, take your 19 time, and when you've finished looking it over, tell 20 me whether you recognize it. 21 (Defendant's Exhibit 2 22 marked for 23 identification.) 24 (Witness peruses said 25 document.) 61 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050195 1 MS. LAVEY: While Mr. Papageorge is looking 2 it over, I'll state for the record Exhibit 2 is, has 3 the Bates number range of MONS, M-O-N-S, 035310 4 through 035331. 5 MS. LAVEY: Also for the record, I will note 6 that page 10 of the document appears to be missing, so 7 there is no MONS 035323 in this exhibit. 8 BY MS. LAVEY: 9 Q. Is that a document that you recognize at 10 all, Mr. Papageorge? 11 A. I remember it. 12 Q. Did you prepare this document? 13 A. No. 14 Q. Do you know who did? 15 A. I do not. 16 Q. In what context do you remember seeing it, 17 then? 18 A. I don't remember specifically when I saw it, 19 but I related to the review I made when I was assigned 20 as a Manager, Environmental Control, on the PCB issue, 21 in which I saw other summaries of what was known at 22 the time and what recommendations had been made to the 23 top management. That's what I relate this particular 24 document to. 25 Q. So the, the time frame is when you, 62 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050196 1 yourself, were putting together a presentation, that 2 you came upon this? 3 A. No, it was before I was appointed. 4 Q. Before that? The document that I handed you 5 on the first page says that the rough draft dated 6 November 10, 1969. Do you know if you saw a final? 7 A. I recall seeing a document that summarized 8 what was related to the top management team, but I 9 don't know if that document was the final version of 10 this or whether they contained similar data. 11 Q. I'm only going to ask you to identify some 12 individuals for now. If you could return to the third 13 page of that document, Bates number MONS 035312, 14 you'll see those numbers at the bottom part of the 15 page. This page refers to something called an Ad Hoc 16 Committee, consisting of M. Ferrar, H. Hodges, 17 E. John, W. Richard, and E. Wheeler. Do you know who 18 M. Ferrar is? 19 A. Yes. 20 Q. Who is that? 21 A. He was Director of Research for the 22 Marketing Group referred to as--I think it's mentioned 23 in here as Plasticizer Group? Yes, Plasticizer Group. 24 Q. What is the--what is his first name? 25 A. Martin. 63 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050197 1 Q. Martin? How about P. Hodges? Do you know 2 who that individual is? 3 A. Paul Hodges represented the Organic Division 4 of Monsanto's Manufacturing Group. 5 Q. How about E. John? 6 A. Ed John, public relations. 7 Q. W. Richard? 8 A. William Richard was the Director of Research 9 for the Fluids Group, as distinguished from the 10 Plasticizer Group. 11 Q. And E. Wheeler? 12 A. Elmer Wheeler represented the Corporate 13 Medical Department. 14 Q. Were all these individuals located in 15 St. Louis? 16 A. Yes. 17 Q. Were you familiar with something called the 18 Ad Hoc Committee that this page is referencing? Do 19 you know what committee this is--have you ever heard 20 of this group of people being put together on 21 something called the Ad Hoc Committee? 22 A. That is the Ad Hoc Committee, mm-hmm. 23 Q. Were you ever--did you ever have occasion to 24 make a presentation to this committee regarding the 25 evolving PCB issues? 64 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050198 1 A. Not to this group as an Ad Hoc Committee, 2 no. 3 Q. Did it at some point turn into a different 4 committee? 5 A. The individuals listed were involved in 6 subsequent committees relating to the subject of PCBs, 7 so I did--was able to communicate with them. 8 Q. Do you recall the names of any of those 9 committees, if they had formal names? 10 A. I don't remember. They--I-- 11 Q. This is something different than the 12 Corporate Development Committee; correct? 13 A. Correct. 14 Q. You can set that aside. That's all I have 15 on that exhibit for now. 16 I'm also going to hand you an organizational 17 chart that is undated and simply ask if it's something 18 you recognize, if we could mark this as Exhibit 3, as 19 well. For record, it is Bates stamped DSW 001400. 20 (Defendant's Exhibit 3 21 marked for 22 identification.) 23 BY MS. LAVEY: 24 Q. Is that an organizational chart that you've 25 ever seen before? 65 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050199 1 A. I don't recall ever seeing this chart. 2 Q. Looking at it, do you have any way of 3 knowing whether it is for the Anniston Plant or 4 Krummrich Plant? 5 A. I cannot tell. 6 Q. You can put that aside. You had indicated 7 one personnel superintendent's name that you recalled: 8 Jack Aldridge? Is that correct? 9 A. Yes. 10 Q. Do you recall any other personnel 11 superintendents at the Anniston Plant? 12 A. Yes, Thomas Tucker. 13 Q. Was he before, or after Mr. Aldridge? 14 A. After. 15 Q. Do you know when he became the personnel 16 superintendent? 17 A. I'd be guessing. 18 Q. Do you recall any other superintendents of 19 personnel at the Anniston Plant? 20 A. I do not. 21 Q. Is there a corporate-level Environmental 22 Affairs Department at Monsanto in the, let's pick the 23 1960's for now, when you were plant manager. Was 24 there any, any, any corporate-level department in 25 St. Louis that had responsibility for environmental 66 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050200 1 affairs? 2 A. Not to my knowledge. 3 Q. Did there come a point in time when there 4 was an Environmental Affairs Department in Monsanto? 5 A. I don't recall a group specifically 6 appointed and described as an environmental, 7 environmental group. I do recall a vice president 8 having that responsibility at the corporate level. 9 Q. What was that position? Vice president of 10 what? 11 A. Oh, I don't know his total title, but the 12 environment was part of his responsibilities. 13 Q. Who was that individual? 14 A. Monte, M-o-n-t-e, Throdahl, T-h-r-o-d-a-h-1. 15 Q. And what time period was his vice president 16 duties including, inclusive of environmental? 17 A. After 1966, but I don't have any specific 18 year in mind. 19 Q. Was there a vice president prior to that 20 time who had responsibility for environmental? 21 A. Not to my knowledge. 22 Q. Do you know if there was a corporate audit 23 committee? Did you ever hear of an audit committee at 24 the corporate level of Monsanto? 25 A. What types of audits? Financial audits, 67 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050201 1 or-- 2 Q. Yes, charged with responsibility for the 3 financial reports, and so forth. 4 A. I'm not familiar with that activity,-- 5 Q. Okay. 6 A. --so I can't comment. 7 Q. Was there a particular committee or group of 8 individuals charged with strategic planning at the 9 corporate level? 10 A. Strategic planning: Again, I'm not familiar 11 with that activity. 12 Q. Was there somebody, one or more individuals 13 at Monsanto's headquarters who were charged with the 14 overall responsibilities relating to PCB 15 manufacturing? 16 A. At what point in time? 17 Q. Well, I'll start with the time that you were 18 plant manager. Well, let me back up. PCBs were being 19 manufactured at both the Krummrich and the Anniston 20 Plant. Where I'm trying to get an understanding is 21 whether there was--who were the individuals who were 22 above both plants that had overall responsibilities 23 for the PCB manufacturing operations. 24 A. The manufacturing operation? 25 Q. Yes, sir. 68 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050202 1 A. Of course, the plant managers of the two 2 plants, and the superintendents assigned those 3 products at the plants, they were responsible. The 4 plant managers, of course, are responsible to the 5 Director of Manufacturing, who in turn had a staff 6 assisting him. 7 Q. Okay, that's right, we identified one 8 Director of Manufacturing that you relate earlier now, 9 that I-10 A. Mr. Hosmer? 11 Q. Mr. Hosmer, correct. Okay. You are right. 12 I apologize. We did go down that road already. Are 13 you familiar with the grievance procedures that were 14 in place at all at the Anniston Plant while you were 15 plant manager? 16 A. You mean grievance from the union work force 17 into management? 18 Q. Yes. 19 A. Yes, I-- 20 Q. Can you describe generally how that, how 21 that worked? 22 A. I can't describe the details of how the 23 union handled it, but we, as representing the plant, 24 would receive from the union officials, officers and 25 all, the complaint about an issue. That would, of 69 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050203 1 course, go to the personnel superintendent, the 2 Aldridge and Tom Tucker people. Mr. Aldridge and 3 Mr. Tucker would try to resolve it at that level. If 4 the union was dissatisfied with that, they would ask 5 for a formal grievance meeting at which the person who 6 filed the grievance would be present, along with the 7 rest of the union committee and members of management, 8 the plant manager, the superintendent of personnel, 9 and the superintendent in charge of the activity, 10 maintenance, production, shipping, they would be 11 present in the room, and there would be a discussion 12 on what the issue is, what the problem is, and what 13 was unsatisfactory to the union, and we would try to 14 resolve it then. 15 Q. If it wasn't resolved at that level, was 16 there another step? 17 A. Well, there, there were opportunity, or 18 there was a procedure, if necessary and when 19 necessary, to appoint some individual as an 20 arbitrator, a person outside of the plant, but that 21 never came about while I was there. 22 Q. Do you remember what union was representing 23 the, the plant workers? 24 A. Yeah, the Chemical Workers Local 21. 25 Q. Do you recall the name of the president of 70 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050204 1 that local union during your time as plant manager? 2 A. I don't remember. I know--I can picture 3 him, but I can't--his name escapes me. 4 Q. I want to go back and clarify one thing 5 because I jumped on a name you gave before. The 6 Director of Manufacturing that you had identified 7 earlier was a gentleman named Robert Soden, SOW-den 8 (Phonetic) ? 9 A. Oh. Robert Soden, he was way up there at 10 the top, reporting to the vice president of--he was a 11 top person. 12 Q. A few moments ago, when I was trying to 13 remember who the Director of Manufacturing was in 14 St. Louis to whom the plant managers reported,-- 15 A. Yeah. 16 Q. --you mentioned Mr. Hosmer. You said 17 earlier Mr. Hosmer is a plant manager -- 18 A. Yes. 19 Q. --in the chain of title. Was he also a vice 20 president of manufacturing-- 21 A. He was not -- 22 Q. --at some point? 23 A. --a vice president -- 24 Q. Correct. 25 A. --he was a manufacturing director reporting 71 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050205 1 to Mr. Soden. 2 Q. Oh, he was? Okay. Is this--was this the 3 case at the time when you were plant manager? That 4 Mr. Hosmer was a manufacturing-- 5 A. Yes. 6 Q. --director who reported to Mr. Soden? 7 A. Yes. 8 Q. You mentioned Gene Jesse became the plant 9 manager after you left. Had he been at the Anniston 10 Plant while you were plant manager? 11 A. No. 12 Q. Do you know where he came from prior to 13 being employed as plant manager? 14 A. I don't remember. 15 Q. But he was not at the Anniston Plant prior 16 to becoming plant manager? 17 A. That is correct. 18 Q. Do you recall Gene Arnette? Do you remember 19 who that individual is? 20 A. The name I recall, now that you mention it. 21 I, I cannot recall the individual. 22 Q. You mentioned Jerry Brown earlier. Do you 23 recall what his position was at the time when you were 24 plant manager? 25 A. All I recall is that he worked in this 72 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050206 1 Technical Services Department, but that's the best I 2 can do on Jerry. 3 Q. Okay. How about Charles Chatman? 4 A. I don't remember that name. 5 Q. Robert Cheever? 6 A. I don't remember him, hmm-mm. 7 Q. Alan Faust? 8 A. I do not remember him. 9 Q. Some of these people may have been after 10 your time, as well. I don't know the chronology, 11 here. Robert Jones? 12 A. I don't know him. 13 Q. Robert Kaley (Phonetic)? 14 A. Yes, Robert Kaley, I remember him as being 15 in St. Louis, involved with environmental matters. I 16 don't recall specifically having worked very closely 17 with him, but I know that he was involved in-- 18 Q. He was not at the Anniston Plant ever, to 19 your knowledge? 20 A. No . 21 Q. How about Tom Lackey? 22 A. Tom Lackey: I don't remember 23 Q. William Taffy? 24 A. William Taffy I remember, yes 25 Q. Who was he? 73 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050207 1 A. He was at the Anniston Plant. He had 2 several different types of assignments in 3 manufacturing and in Technical Services. At this 4 point in time, I don't remember just when and 5 specifically what those assignments were. 6 Q. He did not directly report to you? 7 A. No. 8 Q. So he was never the director or the 9 superintendent of Technical Services? 10 A. No. 11 Q. Eugene Wright we mentioned earlier as 12 someone who had some environmental responsibilities 13 within the Technical Services Group? Is that correct? 14 A. Yes. 15 Q. During the time frame that you were plant 16 manager at Anniston--I know this is a broad question, 17 and I want to try to narrow it in, but I have to start 18 broad. Can you tell us what the products or 19 byproducts were that you were producing at the 20 Anniston Plant that contained PCBs during that 21 five-year period that you were plant manager? 22 A. The products that were PCBs sold by Monsanto 23 went under the trade name Aroclors with a four-digit 24 number. The Aroclor 1200 group were the PCB groups. 25 There was 1221 which was a monochlor, not a polychlor. 74 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050208 1 Q. So that means one chlorine -- 2 A. Mono is one chlorine per the double biphenyl 3 structure. There was 1242, and a blend of 21 and 42 4 was sold as 1232. 1248, 1254, 1260, and 1268. The 5 last two digits of all of those four-digit numbers 6 represent the percent of chlorine in the total 7 mixture, derived by an old, I'm going to call it 8 old-fashioned method of analysis that determined 9 chlorine without exotic instruments. 10 Q. So all of those 1200 series were all sold 11 under the name Aroclors; correct? 12 A. Correct. 13 Q. And those Aroclors are all 100 percent PCBs, 14 rather than a PCB blend? 15 A. I am confused by the use of the word 16 "blend." 17 Q. It probably means I got it wrong. That's 18 okay. There, is there--was there not a category of 19 products that were referred to as Aroclor blends, or 20 does that phrase not mean anything to you? 21 A. Well, like I said, the 1232 was a blend 22 mixing 1221, which is the monochlor, with the 1242. 23 That's the only one I'm personally familiar with as 24 being a deliberate blend of two separate products. 25 Q. Is the--was the--when you arrived in 1965, 75 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050209 1 was the Aroclor production facility located at one 2 part of the plant separate from the non-PCB 3 production? 4 A. Well, it's separate, but then they're all 5 neighbors of each other in a way. There's usually a, 6 I'm going to call it a road between, to allow forklift 7 trucks and other vehicles to traverse around a 8 facility, so in a way, it was a little bit of an 9 island with roadways around each production unit. 10 Q. What, what were the non-PCB products that 11 were being produced at the Anniston Plant when you 12 were plant manager? 13 A. Well, there was biphenyl, chlorine, 14 hydrogenated biphenyl, and the boll weevil 15 insecticides I mentioned earlier, phosphorus 16 pentasulfide, terphenyls, chlorinated terphenyls. 17 Q. What's the difference between the biphenyls 18 and the terphenyls, chemically? 19 A. The benzene ring is represented graphically 20 as a hexagon-shaped configuration. Two of them make 21 biphenyl. Each one is called a phenyl. Two of them 22 are the biphenyl, three of them are the terphenyls. 23 Q. Were the chlorinated terphenyls made in a 24 different location than the chlorinated biphenyls? 25 A. Yes, a separate group of pots and pans, so 76 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050210 1 to speak. 2 Q. Okay, any other non-PCB-based products that 3 you can think of while you were plant manager? 4 A. I can't think of any right now, but I 5 suspect I may have missed some. 6 Q. You mentioned biphenyls. Were the biphenyls 7 sold as a finished product to anyone else, or were 8 they all used as an intermediary to produce the 9 hydrogenated--you mentioned hydrogenated--hygenated 10 (sic) biphenyls and the PCBs? In other words, was the 11 biphenyl all used internally? 12 A. Yes. 13 Q. Would the--the phrase "Aroclor facility," 14 would that refer, if it refers to anything, just to 15 the PCB manufacturing, or does it encompass the 16 biphenyl production area, as well? 17 A. The term "Aroclor facility" was generally 18 used--there's no official definition written down 19 anywhere, but generally used to describe those pieces 20 of equipment as a group that made either the chlor-21 Aroclor 1200 series, which is the biphenyls, or the 22 Aroclor 5000 series, which is the chlorinated 23 terphenyls. They were both loosely referred to as 24 Aroclor facilities. 25 Q. Were biphenyls manufactured at Anniston and 77 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050211 1 used at the Krummrich Plant, to your knowledge? 2 A. I'm not aware of any shipment of biphenyl 3 going to Krummrich Plant. I don't recall any. 4 Q. Are there any other Aroclor series besides 5 the 1200s and the 5000s? 6 A. Well, there's one that was a 4452, which was 7 a blend of one of the terphenyls--I don't remember 8 exactly which one--along with Aroclor 1242. 9 Q. What does "Therminol" refer to? 10 A. Therminol is a trade name to describe a PCB 11 that is used to transfer heat in a manufacturing 12 process. 13 Q. Was that manufactured at the Anniston Plant, 14 Therminols ? 15 A. Well, the, the ingredient, chlorinated 16 diphenyl, was. I'm not aware of any other plant being 17 involved with those drums that were labeled Therminol, 18 containing the chlorinated biphenyl. 19 Q. Was Therminol a trade name of Monsanto's or 20 of another company? 21 A. It's Monsanto's trade name. 22 Q. Is there any difference between diphenyls 23 and biphenyls? 24 A. No, not really. 25 Q. What does Santovac -- 78 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050212 1 A. I'm sorry? 2 Q. Santovac, S-a-n-t-o-v-a-c. 3 A. Santovac. Oh. 4 Q. What does that refer to? 5 A. It's a hydraulic fluid used to operate 6 vacuum pumps. 7 Q. Is that a Monsanto trade name? 8 A. Yes. 9 Q. Was that manufactured at Anniston? 10 A. I don't--I don't remember which plant 11 packaged it and sold it. Hmm-mm. 12 Q. Do you recall which Aroclor series 13 were--makes up Santovac? 14 A. I do not. 15 Q. What does Pydraul referto, P-y-d-r-a-u-1? 16 A. Pydraul is a Monsanto trademark, trade name 17 for liquids used in hydraulic-operated equipment. 18 Q. Was that manufactured at Anniston? 19 A. No. 20 Q. Do you know what its composition was? 21 A. I do not remember. 22 Q. What does "Pyranols"refer to? 23 A. Pyranol is a General Electric trade name for 24 a liquid used in General Electric capacitors or 25 transformers. 79 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050213 1 Q. Was Pyranol packaged at the Anniston Plant-- 2 A. No. 3 Q. --under the name "Pyranol"? 4 A. No. 5 Q. What is Montar? 6 A. Montar is a byproduct of the manufacture of 7 chlorinated biphenyls. It's really what is left over 8 after they distill off the usable liquid, and at the 9 bottom of the pot, so to speak, there is this thick 10 residue that looks very much like road asphalt, black 11 tar, and it was used in several applications by 12 several customers. 13 Q. What applications are you aware of that 14 Montar was used for? 15 A. I'm only aware of paving applications, but-- 16 Q. Did the Anniston Plant use Montar for paving 17 within the plant? 18 A. No. 19 Q. Are you familiar with the term "lampblack"? 20 A. The term "lampblack"? Well, I've read and 21 seen the word in print, but-- 22 Q. Do you know what lampblack is? 23 A. To me, it's the carbon that is obtained when 24 a flame is produced and all of its carbon is not 25 consumed but emitted as a byproduct of the flame. 80 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050214 Q. Are you familiar with the term "lampblack" in connection with the production operations at Anniston? A. No . Q. Or a byproduct or product called Lampblack Number 2? A. I never heard that. Q. What is Santowax? A. Santowax? Q. Wax. A. I'm familiar with the term, but I do not know what it's made with or from. Q. How about the term "Santocel," S-a-n-t-o- 0 --1 1 CD 1 O 1 A. I've never heard that before. Q. I'm going to hand you a document and ask if this helps you recall the term "lampblack" if we could mark this as Exhibit, Defendant's Exhibit Number 4. Thank you It's Bates number DSW 173620. (Defendant's Exhibit 4 marked for identification.) BY MS. LAVEY Q. (Continuing) Take a moment to look at that document, Mr. Papageorge. 81 Papageorge, William; McWane (Former Monsanto Employee WATER PCB-SD0000050215 1 (Witness peruses said? 2 document.) 3 A. I have read the document. 4 Q. Okay. That's your name at the bottom of the 5 letter; correct? 6 A. Yes. 7 Q. Do you recall writing the letter? 8 A. No, I don't. 9 Q. Does it help you refresh your memory at all 10 as to Lampblacks as a Monsanto product? 11 A. Not really, but that's what it says. 12 Q. You can set that aside for now? 13 MS. LAVEY: Can we can we go off the record 14 for a second? 15 THE VIDEOGRAPHER: Off the record at 3:48 16 P.M. 17 (Discussion off the 18 record.) 19 MS. LAVEY: We'll mark this as Exhibit 5. 20 We can go back on. 21 THE VIDEOGRAPHER: We're back on the record 22 at 3:50 P.M. 23 BY MS. LAVEY: 24 Q. Again, I'm going to ask you to take a look 25 at a series of letters. I'm not going to ask about 82 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050216 1 the content particularly, just at the moment, to see 2 whether or not that refreshes your recollection at all 3 about the product series referred to as Santocels if 4 we could mark that as Exhibit 5, please. 5 (Defendant's Exhibit 5 6 marked for 7 identification.) 8 (Witness peruses said 9 document.) 10 MS. LAVEY: For the record, the--what's been 11 marked as Exhibit 5 is a collection of different pages 12 with the following Bates numbers, DSW 173352, DSW 13 173720, DSW 173555, DSW 173331, and DSW 173740. 14 BY MS. LAVEY: 15 Q. Mr. Papageorge, does that cause you to 16 recall at all anything about the product Santocel and 17 whether or not it was manufactured in Anniston? 18 A. It does recall the presence of Santocel, but 19 I don't recall Santocel with Anniston. I'm having 20 difficulty remembering where it was manufactured in 21 Monsanto. 22 Q. Okay, but right now, you don't think it was 23 manufactured at Anniston, as far as you recall? 24 A. As far as I recall, it was not. 25 Q. Other than the Montar, are there any other 83 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050217 1 byproducts of the chlorinated biphenyl production 2 process that were sold to customers? 3 A. Not that I know of. 4 Q. How about muriatic acid, or hydrochloric 5 acid? 6 A. Yes. There was acid as a, as a byproduct, 7 yes. 8 Q. Was that marketed under any particular trade 9 name that you recall? 10 A. No, just "muriatic acid." 11 Q. Do you recall how many people worked at the 12 Anniston Plant while you were plant manager? 13 A. I have numbers that I associate with the 14 plant. They, they're not exact to the perfect single 15 individual, but when I arrived, it was 150 employees. 16 When I left, there were 350. 17 Q. What was the cause for such a dramatic 18 increase in the number of employees? 19 MR. NASSIF: I'll object to the form. Go 20 ahead, Bill. 21 THE WITNESS: I'm sorry? 22 MR. NASSIF: I objected to the form. 23 THE WITNESS: To the form. 24 A. Well, it's a result of increased production 25 on the existing products, the introduction of new 84 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050218 1 products such as if one I mentioned earlier, 2 phosphorus pentasulfide, the increase in technical 3 personnel that were hired. That's it. 4 BY MS. LAVEY: 5 Q. What was, if you can, when you arrived 6 at--in 1965 with approximately 150 employees, what was 7 the ratio between salaried versus hourly, if you 8 recall? 9 A. I just don't remember that. 10 Q. Any clearer idea when it had increased to 11 350, what the ratio was between hourly and salaried? 12 A. No. No, I don't. 13 Q. How many employees of the 150 were 14 associated with the biphenyl Aroclor production area? 15 A. I don't, I don't know that I ever knew. 16 Q. When you first arrived, as I understood it, 17 there is the biphenyl and Aroclor production 18 operations, there is also a pesticide formulation 19 area, as well. Do you know approximately the split in 20 personnel between those two production process areas? 21 A. No. No, I didn't. Hmm-mm. 22 Q. What was the primary source of power to the 23 Anniston Plant during the 1965 to '69 time frame when 24 you were plant manager? 25 A. Electrical power? 85 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050219 1 Q. Yes, sir. 2 A. Alabama Power Company. 3 Q. Did they have a substation within your, 4 within your plant? 5 A. They had a facility. I don't know if they 6 called it a substation, but there was a distribution 7 system adjacent to the Anniston Plant. 8 Q. Putting aside the biphenyls, the terphenyls, 9 chlorinated biphenyls, chlorinated terphenyls, is the 10 only other product category being made at Anniston the 11 pesticide formulations? 12 A. Well, we hydrogenated biphenyls. 13 Q. What was hydrogenated biphenyls used for? 14 Do you know the primary application? 15 A. I don't recall. I just associate H--it's HB 16 40. 17 Q. HB 40? 18 A. Hydrogenated biphenyls. I associate that as 19 a plasticizer, and as I remember, the best of my 20 memory, it was an ingredient in carbonless copy paper 21 application. 22 Q. Do you recall the trade names of the 23 pesticides that were being formulated at Anniston? 24 A. I'm sorry? 25 Q. The trade names of the pesticides that were 86 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050220 1 being formulated or manufactured at the Anniston Plant 2 while you were there as plant manager. 3 A. There were two common terms, parathion and 4 malathion. 5 Q. Is that M-a-l-a-- 6 A. M-a-l-a-t-h-i-o-n. 7 Q. Okay. Was lead used in any way as a raw 8 material, an additive, or catalyst in the production 9 of pesticides at the Anniston Plant? 10 A. Not to my knowledge. 11 Q. Before I forget to ask this, when you were 12 the plant manager in Anniston, where did you live? 13 A. Where did I live? Well, there's a route 14 called Tenth Street, up Tenth Street Mountain. 15 Q. On the east side of town? 16 A. I think it is. I'm kind of disoriented, 17 but-- 18 Q. I'll help you out. Do you recall your 19 street address? Do you recall the street address on 20 Tenth Street? 21 A. Street address: Try Crestview Road, and I 22 think it was 612, but it's been thirty years since I 23 tried to remember it. 24 Q. I'm going to ask you if you can locate it on 25 the map. If you can't do that on the map, that's 87 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050221 CO CO 1 fine. We'll give it a shot. 2 MR. NASSIF: Watch yourself. You're plugged 3 in. 4 MS. LAVEY: Thank you. 5 MR. NASSIF: That's all right. I was going 6 to attempt to raise it as an objection but I didn't 7 know how to phrase it. Objection to your blouse being 8 torn by the microphone. 9 MS. LAVEY: There you go . 10 (Witness peruses said 11 document.) 12 A. I think I have found Crestview Road. 13 BY MS. LAVEY: 14 Q. Did you live at the Crestview Road address 15 the entire time that you were plant manager? 16 A. Yes. 17 Q. I'm going to ask you to circle, and then 18 we'll mark it as an exhibit so we don't lose track. 19 If you could, circle the general location where you 20 lived while you were plant manager for me, please. 21 (Witness complies.) 22 A. Somewhere in that area. 23 MS. LAVEY: Okay. We should mark this as 24 Exhibit 6. 7? 6. 25 (Defendant's Exhibit 6 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050222 1 marked for 2 identification.) 3 BY MS. LAVEY: 4 Q. Mr. Papageorge, I'm going to hand you a 5 drawing and ask you to take a few minutes to locate 6 the Monsanto facility on it and let me know if it 7 looks familiar to you, and I'd like to mark that as 8 Exhibit 7. 9 (Defendant's Exhibit 7 10 marked for 11 identification.) 12 MS. LAVEY: Just for identification purposes 13 and the record, this is a drawing with a label on it 14 that's not Bates numbered, labeled from the Sanborn 15 Library, has a year of 1967 written on the Sanborn 16 Library's marking. 17 (Witness peruses said 18 document.) 19 BY MS. LAVEY: 20 Q. (Continuing) Have you found Monsanto on 21 there? It's labeled down in the southeast corner, to 22 help you out: 23 (Witness continues to peruse 24 said document.) 25 Q. (Continuing) I realize it's extremely hard 89 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050223 1 to read, and I'm only going to talk general layout, 2 not tiny writing. 3 A. Yeah, other than the notes on this map 4 referring to Monsanto Chemical Company, I find nothing 5 to help me orient myself, street names, and so on. I 6 see Adams, but I don't associate that with Monsanto. 7 First Avenue. I'm looking for Clydesdale. I see the 8 reference to Alabama Power. 9 Q. Do you see in the very--if it's okay with 10 Mr. Nassif if I point him to one part-- 11 MR. NASSIF: Sure. 12 BY MS. LAVEY: 13 Q. --of the map, see if this helps. If it 14 doesn't, then we'll be done, but down here--I don't 15 know if you can read that writing--I'm reading the 16 word "Aroclor." I don't know if that gets you 17 bearings for the Aroclor facility or not, absent 18 street names. Ultimately, what I want to ask you, 19 whether the layout is familiar to you and--in terms of 20 the area up here and this area down here (Indicating), 21 and if it's no, it's no. 22 (Witness peruses said 23 document.) 24 A. Well, I do see the reference to Aroclor. I 25 have a hard time relating to the word "development 90 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050224 1 building" and the reference to a pilot plant and 2 reference to sodium phosphorus building. 3 Q. Okay. 4 A. Those are strange to me. I've never heard 5 of those before. 6 Q. Okay. We can-- 7 A. I have a hard time relating to the plant as 8 1 knew it,-- 9 Q. That's fine. 10 A. --other than the word "Aroclor." 11 Q. The only one I could come up with, so if 12 it's not helpful, it's not helpful. That's okay. 13 THE VIDEOGRAPHER: This will end tape number 14 2 in the deposition of William B. Papageorge. We're 15 off the record at 4:09 P.M. 16 (Recess.) 17 THE VIDEOGRAPHER: Back on the record at 18 4:18 P.M. This begins tape number 3 in the deposition 19 of William Papageorge. 20 BY MS. LAVEY: 21 Q. Can you describe generally the production 22 process for the phosphorus pentasulfide, the raw 23 materials that went into that process and how it was 24 manufactured? 25 A. I just don't remember. 91 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050225 1 Q. Do you remember what the raw materials were? 2 A. No, I don't. 3 Q. Where in the plant was that manufactured? 4 A. I don't know how to describe it. It was as 5 I looked toward the parathion producing unit, it was 6 off to the right and toward the parathion unit, and 7 I'm standing probably at the Aroclor producing unit, 8 looking toward the parathion unit. 9 Q. Is the Aroclor producing unit in the 10 southern portion of the facility and the parathion is 11 to the north? Or maybe-- 12 A. Well,-- 13 Q. --I'll ask you the question. What's the 14 layout? 15 A. --I never did orient myself geographically, 16 north, east, south, west. It's just "up there" kind 17 of thing. 18 Q. Up is often north. 19 A. Yeah. 20 Q. Okay. So-- 21 A. I just don't remember the raw materials or 22 the-- 23 Q. Is it--was it in a separate building or 24 collection of buildings from the parathion or the 25 Aroclor producing units? 92 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050226 1 A. Actually, there were no buildings. These 2 were open structures. 3 Q. This was true for all of the processes at 4 the Anniston Plant, or you are just speaking of the 5 phosphorus pentasulfide? 6 A. I think it's true for all of the 7 manufacturing processes, they were open structures 8 except for enclosed rooms that contained the 9 instruments to control the process, and restrooms, and 10 other than that, the chemicals were produced out in 11 the open. 12 Q. When was--when did production begin for 13 phosphorus pentasulfide? 14 A. About the middle of my tenure there. I 15 don't recall the exact date. 16 Q. Was it still being manufactured when you 17 left at the end of 1969? 18 A. Yes. 19 Q. Do you recall what its primary use or 20 application was? 21 A. It was the ingredient, it was an ingredient 22 used in parathion production. 23 Q. Was the phosphorus pentasulfide produced at 24 Anniston used solely in the parathion production or 25 was it sold to third parties, as well? 93 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050227 1 A. As best I remember, it was used solely in 2 the production of parathion. 3 Q. Was the--so the Aroclor-producing unit, as 4 well, was in an open-type structure? 5 A. Yes. 6 Q. Rather than an enclosed building? 7 A. Yes. 8 Q. Was there a roof over the overall production 9 area? 10 A. Yes. 11 Q. But no walls? 12 A. Correct, except for, like I said, the 13 selected areas, instrument room, and so on. 14 Q. What was the floor? Was it dirt, or 15 concrete, or, or what? 16 A. The first floor? 17 Q. Yes, sir. 18 A. Well, the floor inside the manmade structure 19 was concrete. Now, the area around it was the 20 original soil, dirt, dirt, grass, gravel, so on. 21 Q. During the time that you were plant manager, 22 do you recall whether the plant roads within the plant 23 were paved or unpaved? 24 A. To the best of my memory, they were paved, 25 and I hesitated because there were some routes that 94 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050228 1 trucks took to perform some special function that were 2 not paved, just one- or two-time-a-year use; easement, 3 so to speak. 4 Q. What was the--when you went--when you were 5 plant manager at Anniston, off of what road was the 6 main entrance for the Anniston Plant? 7 A. I think it was Clydesdale. 8 Q. Do you recall a time period when Route 202 9 was relocated? 10 A. Do I recall a time? That implies I was 11 there when it was done. 12 Q. I don't think you were. 13 A. No. 14 Q. It's a question of whether you had any 15 knowledge of 202 being relocated after you left and 16 returned to St. Louis. 17 A. Yes, I was aware of this new road which 18 disoriented me initially. When I went -- 19 Q. It still disorients me. 20 A. When I went back to visit and saw that road, 21 it was new to me, and after subsequent visits, of 22 course, I expected it; it was there. 23 Q. Did the Monsanto property go all the way 24 down to the original, the original 202 prior to the 25 relocation? 95 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050229 A. I don't know that I understand your question. Q. Did the property line butt up against the old 202, Old Highway 202? A. I'm confused, because I never thought of an "Old 202." Q Old Birmingham Highway? A Hmm? Q The Birmingham Highway. A Birmingham Highway was 78 to me. Q Okay. That's okay, wait. (Pause.) MS. LAVEY: As it is now. No, we'll come back. BY MS. LAVEY: Q Do you remember when--you mentioned you had heard the 202 had relocated, had moved and it threw you off when you came back to Anniston. Do you know if Route 202 cut off Monsanto's property, cut across its property? A The 202 cutting across? Q Yes. A Yes, I understand that, mm-hmm. Q That there is Monsanto property on the other side of 202? 96 Papageorge, William; McWane (Former Monsanto Employee WATER PCB-SD0000050230 1 A. On both, yeah, on both sides. 2 Q. On both sides? 3 A. Mm-hmm. (Nods head in affirmative manner). 4 Q. Okay. Were you involved, are you aware of 5 any issues in connection with that relocation project 6 of 202? 7 A. No. 8 Q. Okay. When you went, became plant manager 9 at Anniston, you mentioned you sort of learned on the 10 job, rather than formal training in terms of the 11 production processes in Anniston. Were all those 12 production processes new to you, or had you been 13 familiar with them at Krummrich? 14 A. They were new to me, all of them. 15 Q. How did you go about the task, then, of 16 understanding the biphenyl and Aroclor production 17 area? 18 A. I don't know that I remember specifics, but 19 I do recall being escorted by the supervisor and-- 20 superintendent of manufacturing and the supervisor, 21 and they'd point to a, a tank, or a pipeline and say 22 "This does this, and here's where we add this," and 23 take me through the department, take me to the 24 instrument room and show me, "Now, this instrument 25 tells us this," and I, I didn't learn everything the 97 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050231 1 first trip. It took subsequent trips to--and then I 2 reached the point where I understood enough about the 3 process where I could talk with the operators, and 4 they gave me lot of the details, what buttons they 5 pushed, and what valves they turned, and this is sort 6 of the way I went about learning it. There was no 7 sit-down, formal session. 8 Q. Did you have occasion to study the, the 9 history of the Anniston Plant and its operations prior 10 to your time as plant manager? 11 A. To a degree; not totally. I didn't go back 12 all the way to the pre-Swan Chemical Company era. 13 Q. I'm going to hand you a document and ask you 14 to take a look at it, see whether it's a document 15 you've seen before, in which case I'll ask you to 16 identify it. We'll mark this as Exhibit Number 8, 17 please. 18 (Defendant's Exhibit 8 19 marked for 20 identification.) 21 (Witness peruses said 22 document.) 23 MS. LAVEY: For the record, this is--this 24 document has Bates numbered DSW 088087 through DSW 25 088092. It is not dated. 98 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050232 1 (Witness continues to 2 peruse exhibit.) 3 BY MS. LAVEY: 4 Q. (Continuing) Is that a document you have 5 ever seen before? 6 A. I have not seen it before. 7 Q. Have you read similar-type histories of the 8 Anniston Plant historic operations? 9 A. I don't recall seeing any. 10 Q. Okay. Can you think of any former, any 11 former employees who would have knowledge about the 12 production processes prior to 1965, the not--I'm 13 sorry, let me rephrase that: The historic operations 14 that did not relate to biphenyls and PCB production 15 but more the former phosphorus, the inorganic 16 activities that took place at Anniston? 17 A. I just don't recall any individual that fits 18 that, that description. 19 Q. Do you have any understanding as to where 20 the inorganic production processes once took place at 21 the Anniston Plant? 22 A. No. I have no -- 23 Q. The inorganic, maybe I have this wrong, but 24 the inorganics were no longer being manufactured by 25 the time you came in 1965; correct? 99 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050233 1 A. That's true. 2 Q. Only the organics, the biphenyls, 3 chlorinated or the parathion, and so forth? 4 A. Yeah, which became agriculture, mm-hmm. 5 Q. Right. Okay. In addition to Robert Moody 6 that you identified as one of your manufacturing 7 superintendents, thinking about the part of the plant 8 that he's responsible for, which as I understood was 9 everything except the insecticide, parathion 10 production area, do you recall the individuals that 11 then worked beneath him? I don't know if "supervisor" 12 is the right word or "foreman." I'm trying to get a 13 handle on the organizational structure beneath him, 14 within his area of responsibility. 15 A. I know Mr. Moody was replaced. I recall 16 that, but I don't recall the individual that replaced 17 him, and I don't recall the other members in 18 manufacturing. At this moment, I just -- 19 Q. How many shifts were operating in the 20 biphenyl and Aroclor area? How many--is it three 21 shifts, 24 hours a day, or -- 22 A. Yeah, 24, seven days a week, three shifts a 23 day. 24 Q. Three shifts a day? Were they manufacturing 25 during each of the three shifts? They were producing 100 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050234 1 during each of those three shifts? 2 A. Oh, yes. 3 Q. Okay. 4 A. Mm-hmm. 5 Q. And is that true throughout the time frame 6 that you were plant manager? 7 A. Yes. 8 Q. Was there a regular downturn or shutdown 9 period for scheduled maintenance that occurred on a 10 regular basis? 11 A. Not in these operations, no. They occurred 12 only as needed. 13 Q. Would there have been different foremen for 14 each of the different shifts? 15 A. No, the foremen would be available primarily 16 during the day, but at times, they would come out in 17 the evening shift and the midnight shift. The 18 operations were really run by individuals referred to 19 as chief operators. 20 Q. And would each chief operator then have 21 responsibility for a given part of the production 22 process? 23 A. Yes. 24 Q. Okay. Do you recall the names of any of 25 those chief operators? 101 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050235 1 A. No, I don't, no. 2 Q. You knew I was going to ask that next. 3 (Laughter.) 4 Q. (Continuing) Again, staying with the 5 biphenyl and PCB Aroclor facility, I'm not talking 6 about the parathion area, do you know about how many 7 chief operators there were? 8 A. No, I don't. Hmm-mm. 9 Q. Were there individuals who are referred to 10 as supervisors? 11 A. Yes. 12 Q. It's somebody different than these chief 13 operators ? 14 A. Correct. 15 Q. Were they above the chief operator? 16 A. The supervisors were above the foremen, and 17 the foremen were above the chief operators, and the 18 supervisors reported to the manufacturing 19 superintendent. 20 Q. Mr. Moody? 21 A. Mr. Moody and his successor. 22 Q. Okay, but that, that's the area you don't 23 recall any names for, the supervisors, or the 24 foreman's , or the chief operator's? 25 A. No . 102 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050236 1 Q. Okay. Did any of your other family members 2 work at the Monsanto Anniston Plant? 3 A. My family members? 4 Q. Yes. 5 A. No. 6 Q. Did any of your family members work at any 7 of the foundries in Anniston? 8 A. No. 9 Q. Did you have any other family living in the 10 Anniston area other than your own immediate family? 11 A. No. 12 Q. Did you, yourself, use any foundry sand as 13 fill at your residence on Crestview? 14 A. No. 15 Q. Do you recall size of the Maintenance 16 Department while you were plant manager, approximately 17 how many individuals? 18 A. No, I don't. 19 Q. And the name of the superintendent hasn't 20 come to you in the last two hours, has it? 21 A. No, it hasn't. 22 MS. LAVEY: Okay. I'm debating launching 23 into a series of exhibits that will take more time 24 than we have left. 25 MR. NASSIF: How long would it take? Thirty 103 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050237 1 minutes? 2 MS. LAVEY: At least, so we might be better 3 off--yeah, I could cover that. All right, we'll skip 4 over those documents for now. 5 BY MS. LAVEY: 6 Q. Was the Anniston Plant using PCB-containing 7 products in its own--at its own facility? 8 A. The only use that I recall was in electrical 9 distribution transformers and capacitors. 10 Q. And which product was being used in those, 11 in those pieces of equipment? 12 A. It depends on whether it was--where it was 13 purchased, from which manufacturer, and what that 14 manufacturer called the liquid in his product. 15 Q. Do you recall any of the product names 16 specifically? 17 A. Which product? The transformers and 18 capacitors,-19 Q. Yes, sir. 20 A. --or the fluids? 21 Q. Let's go with the transformers and 22 capacitors. 23 A. Westinghouse, General Electric--whew; I've 24 forgotten the others. Up in New England, there were 25 several capacitor manufacturers. 104 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050238 1 Q. And while you were plant manager, there were 2 transformers and capacitors that contained a PCB-based 3 fluid? 4 A. Correct. 5 Q. Okay. Do you recall--well, how many, how 6 many transformers would you say, if you can, when you 7 were the plant manager, were spread about the Anniston 8 Plant? 9 A. I would be guessing. I don't remember. 10 Q. Same question on capacitors. Do you have 11 any recollection of how many? 12 A. I had no idea. All the fluorescent tubing 13 systems, and-14 Q. All of the fluorescent-15 A. Motors. 16 Q. --tubing systems were what? 17 A. They had capacitors -- 18 Q. Okay. 19 A. --of the old, the old type, mm-hmm. 20 Q. I'm not familiar with, maybe because it's 21 the old type, I'm not familiar with the use of 22 capacitors in connection with fluorescent tubing. 23 What kind of --can you describe the capacitor? What 24 size are we talking about? 25 A. Well, it's -- 1 don't know how to describe it. 105 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050239 1 They come in different shapes, of course, but inside 2 is a coil, wire, and aluminum, and foil, and it's 3 immersed in a liquid. 4 Q. Is this like an electrical--like an 5 electrical switch? 6 A. Well, in a way, I guess it's a switch, 7 because it stores enough electricity to start, and the 8 current then keeps the light lit, so you need that 9 initial surge of power -- 10 Q. How about a-- 11 A. --which-- 12 Q. --starter? Is a that better phrase for me 13 to use instead of a switch? 14 A. That's a good word, it's a starter. 15 Q. Okay. 16 A. It's --and there are many electric motors 17 that have capacitors that need that initial surge to 18 start it, and then it keeps running on the power 19 being-- 20 Q. Would you have these starters all over the 21 plant, or is there a particular area that you are 22 thinking of? 23 A. They're all over the plant, right with the 24 motor or the tubing, the lighting. It's scattered. 25 Q. And connected with each one of these 106 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050240 1 starters is some type of oil contained--oil container? 2 A. No, these are sealed-- 3 Q. You had mentioned they were immersed in an 4 oil. That's what I'm trying to get at. 5 A. The coil that is inside the little can, and 6 the can, itself, contains that oil -- 7 Q. Okay. 8 A. --and it's sealed, and the only thing that 9 comes out of it are electric connections. 10 Q. Okay, is that oil a PCB oil that you are 11 referring to? 12 A. PCB mixture. 13 Q. Okay. Is there a particular product name 14 associated with that, that use of PCB mixture? 15 A. Well, the product that these electrical 16 equipment manufacturers call it, Inerteen, Pyranol, 17 they all had their, their names for these things. 18 Q. Is there a particular 1200 series Aroclor 19 that would be associated with this particular use? 20 A. It was primarily twelve forty--Aroclor 1242. 21 Q. How about the transformers? Is there--what 22 Aroclor 1200 series would that be, typically, if you 23 know? This is at the Anniston Plant. 24 A. 1254 is the more common. Some of them used 25 to be, but they would eventually change, 1248s. 107 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050241 1 Q. Do you know whether there came a point in 2 time where the Anniston Plant began a program to 3 change out its PCB-containing transformers to non-PCB? 4 A. I'm not familiar with that, that type of 5 phaseout program. 6 Q. Who had the responsibility for maintaining 7 the transformers and capacitors at the Anniston Plant? 8 Is that a separate department? 9 A. It's the Maintenance Department. 10 Q. Was there an area within the plant where 11 transformers and capacitors were stored for use later? 12 A. I'm certain that there was, there was no 13 storage of transformers. My hesitation has to do with 14 the possibility that capacitors, being small as they 15 are, could be in a Maintenance Department cabinet, or 16 box, or on the shelf. 17 Q. Were there large capacitors, as well? Banks 18 of capacitors? 19 A. I'm not aware of any banks of capacitors. 20 Some of them are about the size of that water bottle, 21 and others are about the size of this switch, here. 22 MR. NASSIF: For the record, Mr. Papageorge 23 was referring to the switch on the microphone which is 24 approximately two inches long and a half inch high. 25 BY MS. LAVEY: 108 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050242 1 Q. Was there hydraulic equipment at the plant? 2 A. I'm sorry? 3 Q. Was there hydraulic equipment at the 4 Anniston Plant? 5 A. Yes, I'm aware of compressors, air 6 compressors. That's all that comes to mind right now, 7 but -- 8 Q. Do you know if any hydraulic equipment was 9 using a PCB-based fluid? 10 A. Any who? I'm sorry. 11 Q. Any of the hydraulic equipment, whether it 12 was using a PCB-based fluid. 13 A. Yes. 14 Q. The air compressors you were -- 15 A. Yes. 16 Q. --you are referring to? 17 A. That's the one I have in mind. 18 Q. Where were the air compressors located? 19 A. I don't recall the specific applications. 20 Q. Were there occasions where there would be 21 leaks from the hydraulic equipment, where the 22 hydraulic fluid would, would leak out? 23 A. I never saw any. 24 Q. If there were any leaks, who would have the 25 responsibility for addressing that? 109 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050243 1 A. Of course, the user, the production 2 management would be closest to it, and if there was a 3 leak, they would contact the Maintenance Department to 4 send over the proper type of mechanic to handle it, 5 whether it was a pipe leak, or an electrical leak, or 6 whatever. 7 Q. Were there--was there any other use of a 8 heat, heat transfer fluids at the Anniston Plant? 9 A. Not that I know of. 10 Q. Any other use of any PCB, liquid or solid, 11 other than transformers, capacitors, the switches we 12 talked about, and hydraulic equipment such as air 13 compressors? 14 A. I can't think of anymore. 15 MS. LAVEY: I think this is probably a good 16 break point before we pick up tomorrow. 17 MR. NASSIF: Okay. You guys want to s 18 at 8:30 tomorrow. 19 MS . LAVEY: That's up to you. 20 MR. NASSIF: Is that all right? 21 MR. TAYLOR: It's fine with me. 22 MR. NASSIF: What about for your court 23 reporters? Can you start at 8:30? 24 THE COURT REPORTER: Tell us when, we'll be 25 here 30 minutes early. 110 Papageorge, William; McWane (Former Monsanto Employee; WATER PCB-SD0000050244 1 MR. NASSIF: Yeah, start at 8:30 and then- 2 MS. LAVEY: Is the receptionist here, he can 3 get in at 8:00 o'clock? 4 MR. NASSIF: Oh, yeah. Yeah, there'll be 5 somebody here. 6 MS. LAVEY: Raakhee, are you on the phone? 7 Are we off the record now? 8 THE VIDEOGRAPHER: We can go off the record 9 now. 10 MS. LAVEY: We can be off the record. 11 THE VIDEOGRAPER: This will end today's 12 session of deposition of William Papageorge. We're 13 off the record at 4:53 P.M. 14 (Whereupon, at 4:53 P.M., the 15 deposition was recessed to the 16 following day.) 17 18 19 20 21 22 23 24 25 Ill Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050245 COMES NOW THE WITNESS, WILLIAM B. PAPAGEORGE, and having read the foregoing transcript of the deposition taken on the 30th day of August, 2004, acknowledges by signature hereto that it is a true and accurate transcript of the testimony given on the date hereinabove mentioned. 112 WILLIAM B. PAPAGEORGE Subscribed and sworn to me before this day of , 2004. My Commission expires: . Notary Public 11 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050246 1 State of Missouri ) 2 ) SS. 3 City of St. Louis ) 4 I, J. Bryan Jordan, a Notary Public in 5 and for the State of Missouri, duly commissioned, 6 qualified and authorized to administer oaths and to 7 certify to depositions, do hereby certify that 8 pursuant to Notice in the civil cause now pending and 9 undetermined in the In the United States District 10 Court For the Northern District of Alabama, to be used 11 in the trial of said cause in said court, I was 12 attended at the offices of Husch & Eppenberger, LLC, 13 in the County of St. Louis, State of Missouri, by the 14 aforesaid witness and by the aforesaid attorneys, on 15 the 13th day of September, 2004. 16 The said witness, being of sound mind 17 and being by me first carefully examined and duly 18 cautioned and sworn to testify the truth, the whole 19 truth, and nothing but the truth in the case 20 aforesaid, thereupon testified as is shown in the 21 foregoing transcript, said testimony being by me 22 reported in shorthand and caused to be transcribed 23 into typewriting, and that the foregoing pages 24 correctly set forth the testimony of the 25 aforementioned witness, together with the questions 113 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050247 1 propounded by counsel and remarks and objections of 2 counsel thereto, and is in all respects a full, true, 3 correct and complete transcript of the questions 4 propounded to and the answers given by said witness; 5 that signature of the deponent was not waived by 6 agreement of counsel. 7 I further certify that I am not of 8 counsel or attorney for either of the parties to said 9 suit, not related to nor interested in any of the 10 parties or their attorneys. 11 Witness my hand and notarial seal at 12 St. Louis, Missouri, this 13th day of September, 2004. 13 14 15 J. Bryan Jordan 16 Certified Court Reporter No. 00532 17 State of Missouri 18 My License expires: January 1, 2005 19 20 21 22 23 24 114 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050248 1 COURT MEMO 2 IN THE UNITED STATES DISTRICT COURT 3 FOR THE NORTHERN DISTRICT OF ALABAMA 4 MAGISTRATE JUDGE GREEN 5 6 Solutia, et al. , 7 ................................... Plaintiffs vs Case No. CV-03-PWG-134-E. 9 McWane, et al. , 10 ................................... Defendants. 11 12 CERTIFICATE OF OFFICER AND 13 STATEMENT OF DEPOSITION CHARGES 14 Rule 57.03 (g) (2) (a) & Sec. 492.590 RSMO 1985) 15 16 VIDEOTAPED DEPOSITION OF WILLIAM B. PAPAGEORGE, VOLUME 17 1, TAKEN ON BEHALF OF DEFENDANTS, AUGUST 30, 2004 18 19 Name and address of person or firm having custody of 20 the original transcript: 21 SQUIRE, SANDERS & DEMPSEY, L.L.P. 22 4900 Key Tower 23 127 Public Square 24 Cleveland, OH 44114-1304 115 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050249 1 TAXED IN FAVOR OF: 2 SQUIRE, SANDERS & DEMPSEY, L.L.P. 3 4900 Key Tower 4 127 Public Square 5 Cleveland, OH 44114-1304 6 117 of orig. & copy @$ $ 7 Attendance ofreporter& Jurat ................................ $ 86.00 8 Delivery ........................................................................................................... $ 9 Total ....................................................................................................................... $ 10 11 TAXED IN FAVOR OF: 12 HUSCH & EPPENBERGER, LLC 13 190 Carondelet Plaza, Suite 600 14 St. Louis, MO 63105-3441 15 117 pages of copy @$ $ 16 Delivery ........................................................................................................... $ 17 Total ....................................................................................................................... $ 18 19 20 21 22 23 24 116 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050250 1 TAXED IN FAVOR OF: 2 TROUTMAN SANDERS LLP 3 NationsBank Plaza, Suite 5200 4 600 Peachtree Street, Northeast 5 Atlanta, GA 30308-2216 6 117 pages of copy @$ $ 7 Delivery ........................................................................................................... $ 8 Total ....................................................................................................................... $ 9 10 Upon delivery of transcripts, the above charges had 11 not yet been paid. It is anticipated that all charges 12 will be paid in the normal course of business. 13 14 GORE & PERRY REPORTING CO. 15 515 Olive Street, Suite 700 16 St. Louis, MO 63101 17 18 IN WITNESS WHEREOF, I have hereunto set my hand and 19 seal this 13th day of September, 2004. 20 21 22 J. Bryan Jordan 23 Notary Public State of Missouri 24 (St. Louis City) 25 My Commission expires January 14, 2007 117 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050251 [& - 3:50] Transcript Word Index & 1254 & 75:4 107:24 2:193:4,144:135:3 6:12 1260 7:4,149:13,16,23 11:1,7 75:4 12:3,9 14:19 113:12 115:14 1268 115:21 116:2,6,7,12 117:14 75:4 127 0 3:16 115:23 116:4 001400 1299 65:19 5:20 00532 114:16 03 1:4 2:8 9:10 115:8 134 1:4 2:8 115:8 1345 9:10 035310 13th 62:3 035312 63:13 035323 113:15 114:12 117:19 14 117:25 150 62:7 84:15 85:6,13 035331 62:4 088087 98:24 173331 83:13 173352 83:12 088092 98:25 173555 83:13 1 173620 1 81:19 8:9 24:21,25 25:2,8,9,17 173720 37:11 54:14 114:18 115:17 83:13 T15 173740 2:22 9:2 83:13 10 1800 8:3 62:6 63:6 21:4 100 19 5:11 75:13 16:7 117 190 116:6,15 117:6 2:20 3:5 9:4 116:13 1200 1901 74:24 75:10 77:21 107:18 6:13 107:22 1922 1200s 12:7 78:5 1943 1201 15:17 7:5 1947 1221 15:19 17:13,19 74:25 75:22 1947-1951 1232 20:4 75:4,21 1950's 1242 75:3,22 78:8 107:20 16:7,7 1951 1248 13:12 17:22,25 18:9 20:23 75:4 21:10 25:22 1248s 1954 107:25 25:22 1955 2004 26:8 1:12 2:23 9:2 112:3,13 1956 113:15 114:12 115:17 26:23 117:19 1957 2005 29:5 114:18 1959 2007 29:5,21 117:25 1960's 202 66:23 4:18 6:6 95:8,15,24 96:4,4 1961 96:6,17,19,21,25 97:6 29:21 202-639-7707 1963 5:22 19:1 20:23 23:25 24:2 202-639-7832 1964 5:23 19:10 205 1965 4:195:66:16 19:18 34:12,14 36:23 48:25 205-251-5900 49:21 56:11 75:25 85:6,23 4:17 99:12,25 20th 1966 4:14 67:17 21 1967 70:24 75:3 89:15 2100 1969 5:4 19:18 50:12 56:11 63:6 216 93:17 3:18,19 1970 216-621-0577 19:25 42:14 46:14 47:1 7:19 48:1561:15 216-621-1312 1973 7:18 40:2,3 42:7,12,14 43:14 24 1977 100:21,22 43:12,13,25 44:1,7 2400 1985 6:14 115:14 248 1986 5:13,14 13:12 18:6 20:1 46:10,15 25 47:2 8:9 57:22 1990's 251-2300 17:4,6 5:6 2 2 8:10 54:18 61:18,21 62:2 81:6 91:14 115:14 2:35 5415 2'38 54-18 254-1061 6:16 254-1999 6:17 258-1439 5:14 258-1616 5:13 200 3 511 3 20004-2400 8:11 65:18,20 91:18 5:21 3:48 20015 82:15 6:5 3:50 82:22 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050252 [30 - affairs] 30 1:12 110:25 115:17 30308-2216 4:6 117:5 30309-3424 7:6 305 6:4 30th 2:22 9:2 112:3 314 3:8 314-480-1500 3:7 314-480-1505 3:9 31st 18:6 20:1 321 12:13 323-2197 4:19 350 84:16 85:11 35203 5:5 35203-2618 6:15______________ 4 4 8:12 81:18,20 4:09 91:15 4:18 91:18 4:53 2:22 111:13,14 40 86:16,17 400 4:15 404 4:8 404-881-7000 7:8 404-881-7777 7:9 42 75:3 44114-1304 3:17 115:24 116:5 44115-1126 7:16 4452 78:6 479-8545 3:18 479- 8780 3:19 480- 1818 3:8 48304-2949 5:12 4900 3:15 115:22 116:3 492.590 115:14__________ 5 5 8:13 82:19 83:4,5,11 5:00 11:9 5000 77:22 5000s 78:5 515 117:15 5200 4:4 117:3 5335 6:4 54 26:4 57.03 115:14 6 6 8:14 88:24,24,25 600 2:20 3:54:5,14 116:13 117:4 61 8:10 612 87:22 63 19:11 63101 117:16 63105-3441 3:6 116:14 63141 12:12 63141-8039 12:14 64 19:11 65 8:11 650 7:15 686-4843 6:7 686-4844 6:6 69 37:17 85:23 7 7 8:15 12:7 88:24 89:8,9 700 117:15 71 47:24 78 96:10________________ 8 8 8:16 98:16,18 8:00 111:3 8:30 110:18,23 111:1 81 8:12 812 7:15 83 8:13 85203 4:16 86 46:1 86.00 116:7 88 8:14 885-3489 4:7 89 8:15_________________ 9 9:00 11:13 9202 6:7 9205 6:17 962-6688 4:8 98 8:16 986-5023 4:18 a a&m 16:4 a.m. 11:13 able 65:7 abreast 38:19 absent 90:17 acceptability 40:9,12 42:4 43:4,15 44:9 acceptable 40:15 accurate 112:5 acid 84:4,5,6,10 acknowledges 112:4 actively 51:25 activities 30:3 48:22 61:1 99:16 activity 27:14 52:10 68:4,11 70:9 ad 63:15 64:18,21,22 65:1 adams 90:6 add 22:25 97:22 added 21:18 44:9 45:6 addition 11:1026:2 40:8 100:5 additional 41:13 additive 87:8 address 9:3 12:11,1221:5 87:19,19 87:21 88:14 115:19 addressing 23:1745:1851:11 109:25 adjacent 86:7 administer 113:6 administration 16:9 advance 11:6,10 affairs 66:22 67:1,4 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050253 [affirmative - back] affirmative anchor area assisting 97:3 7:12 10:14 16:10 18:11 20:24 21:2 69:6 aforementioned annis 35:20 77:16 85:14,19 88:22 associate 113:25 18:14 90:20,20 94:9,19 97:17 59:14 84:13 86:15,18 90:6 aforesaid anniston 100:10,14,20 102:6,22 associated 10:21 113:14,14,20 11:5 18:16 19:14,16 34:7,9 103:10 106:21 108:10 39:23 85:14 107:14,19 age 34:15,18,22 35:3,8 36:1,5,9 areas assume 10:19 36:15,23 37:1,5,8,9,11,12 49:23 55:8 85:20 94:13 11:21 39:13 ago 37:16,19 38:3,8,22 39:7 arnette assumed 48:1471:12 47:16,21 48:1,12,17,24,25 72:18 42:21 agreed 51:7 53:18 54:23 56:4,11 arnold atlanta 11:6,10 57:8 66:3,11,1968:19 7:3 10:7,7 4:1,6 7:6 9:21 34:15 117:5 agreement 69:14 72:9,15 73:18 74:1 aroclor atlantic 114:6 74:16,20 76:11 77:25 78:13 33:8 50:3 74:24 75:19 76:1 7:5 agricultural 79:9,18 80:1,16 81:3 83:17 77:13,17,21,22,24 78:4,8 attempt 31:1932:341:14 83:19,23 84:12 85:23 86:7 79:12 85:14,17 90:16,17,24 88:6 agriculture 86:10,23 87:1,9,12 93:4,24 91:10 92:7,9,25 94:3 97:16 attendance 100:4 95:5,6 96:18 97:9,11 98:9 100:20 102:5 107:18,20,22 116:7 ahead 99:8,16,21 103:2,7,10 aroclors attended 18:15 26:1 41:21 84:20 104:6 105:7 107:23 108:2,7 29:16 74:23 75:11,13 16:3,6 113:12 aims 109:4 110:8 arrival attorney 60:7 answer 50:8 11:1 114:8 air 33:25 41:21 arrive attorneys 109:5,14,18 110:12 answers 34:9 14:4 113:14 114:10 al 114:4 arrived audience 1:2,6 2:5,104:165:5 6:15 anticipated 31:4 34:15 35:8 48:25 59:9 61:7 9:8,8 115:6,9 117:11 75:25 84:15 85:5,16 audit alabama anymore arrows 67:22,23 2:2 9:9,16 11:5 18:16 19:14 110:14 55:12 audits 48:12 86:2 90:8 113:10 apologize art 67:25,25 115:3 69:12 49:7 august alan appearances aside 1:122:23 9:2 112:3 115:17 73:7 3:1 65:14 66:6 82:12 86:8 authorized aldridge appears asked 113:6 51:3,9 66:8,13 70:2,2 62:6 59:10 available allow application asking 101:15 76:6 86:14,21 93:20 14:16 32:15 42:6 avenue alston applications aspects 5:4,20 6:4,13 90:7 7:4 80:11,13,15 109:19 23:17 avoided alston.com appoint asphalt 48:20 7:10 70:19 80:10 awarded aluminum appointed assign 15:17,19 106:2 61:13 63:3 67:6 38:11 aware amount appropriate assigned 78:2,16 80:13,15 95:17 13:17 11:9 14:1 20:8 21:11,14 22:1 27:4 97:4 108:19 109:5 amsouth approve 31:5,16,20,21 32:1,2 37:15 awareness 6:14 60:10 37:23 40:7,14 44:24 45:4 44:15 analysis approximate 46:1 62:19 69:2 awhile 75:8 57:21 assignment 17:10 analytical 38:14 58:23 analyze 59:6 analyzed 59:8 approximately 22:12 46:5 58:21 34:3 85:6,19 103:16 108:24 assignments approximation 13:10 74:2,5 57:22 assistance arbitrator 46:20 70:20 assisted 55:7 b harhplnr 1515 back 17:24 18:16 20:4 23:14 25:14 31:8 37:7,13,25 39:1 39:10 43:12 46:15 47:22 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050254 [back - chatman] back (cont.) biphenyls (cont.) broader carefully 48:16 52:2 54:17 56:8 76:17,24 77:6,6,10,21,25 39:22 113:17 68:18 71:4 82:20,21 91:17 78:23 80:7 86:8,9,12,13,18 brown Carolina 95:20 96:14,18 98:11 99:14 100:2 58:20,20 72:22 14:23,25 baker bird bryan carondelet 5:19 7:4 2:23 113:4 114:15 117:22 2:20 3:5 9:4 116:13 bakerbotts.com birmingham buck case 5:24 4:16 5:5 6:15 9:16 96:7,9 34:23 1:4 2:8 9:7 10:2,21 72:3 banks 96:10 building 98:15 113:19 115:8 108:17,19 birth 7:15 91:1,2 92:23 94:6 catalyst bartlesville 12:6 buildings 87:8 17:17 biswas 92:24 93:1 category based 5:18 10:9,9 business 75:18 86:10 77:2 105:2 109:9,12 bit 16:8,9 117:12 cause basis 48:13 76:8 butt 9:9 83:15 84:17 113:8,11 101:10 black 96:3 caused bates 80:10 buttons 113:22 62:3 63:1365:1981:19 blend 98:4 cautioned 83:12 89:14 98:24 75:3,14,16,21,24 78:7 butzel 113:18 bearings blending 5:10 caxton 90:17 23:11 29:16 butzel.com 7:15 becoming blends 5:15 center 72:16 23:8 75:19 byproduct 7:5 began bloomfield 80:6,25 81:5 84:6 certain 108:2 5:11,12 byproducts 29:11,1458:11 61:3 108:12 beginning blouse 74:19 84:1 certificate 18:8 21:9 42:7 88:7 begins board 91:18 60:9 behalf boils 2:19 115:17 34:23 believe boll 25:16 30:22 60:21 50:1 76:14 bell boss 59:13 34:19 beneath bottle 100:11,13 108:20 benzene bottom 76:19 63:14 80:9 82:4 best botts 19:1 21:7 23:20 38:15 48:2 5:19 49:6 55:9 73:1 86:19 94:1 box 94:24 108:16 better branched 52:6 104:2 106:12 28:6 bill brass 84:20 5:1 10:4 bill's break 24:15 11:22,23,25 12:1 54:9 biphenyl 110:16 33:7,15 50:4 75:2 76:13,14 briefly 76:21,22 77:11,16 78:2,18 15:13 84:1 85:14,17 97:16 100:20 brittle 102:5 21:19 biphenyls broad 22:24 32:25 33:18,21,21,22 36:16 74:16,18 c 16:14,15 115:12 cabinet 108:15 certification 16:13 call 75:7 76:6 107:16 called certified 2:23 9:6 114:16 certify 16:4 18:23 21:3 30:731:16 31:20 40:5 44:24 46:2,3 113:7,7 114:7 chain 51:2,17 59:20 63:15 64:17 64:21 76:21 81:5 86:6 71:19 change 87:14 104:14 27:12 40:3 42:10,14 43:22 cancel 38:25 candidate 45:1,2,4 107:25 108:3 changed 11:24 27:12 42:15 45:5 38:16 capacitor 104:25 105:23 capacitors changes 40:4 charge 51:17 55:5 70:9 79:24 104:9,18,22 105:2,10 charged 105:17,22 106:17 108:7,11 108:14,17,18,19 110:11 capital 56:17 28:16 68:2,8,13 charges 115:13 117:10,11 Charles carbon 73:3 80:23,24 carbonless chart 56:5 65:17,24 66:1 8620 care charts 56:3,6 28:6 chatman 73:3 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050255 [cheever - cover] cheever closest concrete 73:5 110:2 94:15,19 chemical cluster conducting 15:16,18 16:12 17:1226:5 32:10 33:3 28:14 40:6,14 41:19 43:8,10 44:4 Clydesdale configuration 51:18 70:24 90:4 98:12 90:7 95:7 76:20 chemically coil confused 76:18 106:2 107:5 75:15 96:5 chemicals collection connected 21:13,1626:11,1928:20,23 83:11 92:24 106:25 31:1740:2041:1,7,10,12 Columbia connection 41:13,1742:5,1243:15 5:21 22:5 81:2 97:5 105:22 44:3,20,25 45:24 93:10 coming connections chemist 46:24 107:9 58:23 comment consider chief 68:6 60:10 101:19,20,25 102:7,12,15 commission consisted 102:17,24 112:15 117:25 23:8 chlor commissioned consisting 77:20 113:5 63:16 chlorinate committee consultant 22:25 59:21,23 60:3,12,16,20 13:1,6,8 chlorinated 63:16 64:18,19,21,22,24 consumed 76:16,23,24 77:22 78:15,18 65:1,4,12 67:23,23 68:7 80:25 80:7 84:1 86:9,9 100:3 70:7 contact chlorine committees 28:23 29:1 48:16 110:3 22:25 75:1,2,6,9 76:13 65:6,9 contain chronology common 21:21 25:24 73:10 87:3 107:24 contained circle communicate 23:4 63:10 74:20 93:8 88:17,19 65:7 105:2 107:1 city communications container 113:3 117:24 46:7 107:1 civil company containing 113:8 7:2 17:18 18:2 40:6,7,15,21 27:23 28:9,15 59:23 78:18 clarification 41:18,18,1942:5,17,22 104:6 108:3 33:20 43:9,11,16,21 44:3,4,25 contains clarify 78:20 86:2 90:4 98:12 39:19 107:6 11:1925:1371:4 complaint content class 69:25 83:1 28:23 complete context classified 114:3 62:16 40:23 complies continue classify 88:21 25:12 46:10 32:14 composition continued clayton 79:20 26:8 46:24 53:14 9:4 compressor continues clearer 28:2 89:23 99:1 85:10 compressors continuing clearly 109:5,6,14,18 110:13 16:25 17:6 35:14 81:24 11:1624:6 concerned 89:20,25 99:4 102:4 Cleveland 51:5 continuous 3:17 7:16 11:2 115:24 concerning 47:1 116:5 60:7 contracts closely conclusion 51:13 73:16 15:24 control 39:21 40:1 42:11 61:14 62:20 93:9 conversation 14:16 cooley 58:10,13,14 cooper 6:12 9:23 copy 24:15 86:20 116:6,15 117:6 corner 89:21 corporate 59:21 60:2,7,9,11,15,19 64:12 65:12 66:21,24 67:8 67:22,24 68:9 corporation 9:14 11:2 correct 12:5 19:4,23 23:12,13 26:12,13,14,20 28:12,21 30:24 34:4,7,8,12 38:23 43:17 45:9 49:22 50:24 52:23 56:14 58:16,17 65:12 65:13 66:8 69:11 71:24 72:17 74:13 75:11,12 82:5 94:12 99:25 102:14 105:4 114:3 correctly 113:24 corresponding 33:14 counsel 3:1 9:10 12:3 114:1,2,6,8 counting 14:9 country 12:9 35:22 county 2:21 113:13 couple 11:5 38:2 course 15:20 16:10 48:19 58:5 69:1,4 70:1 95:22 106:1 110:1 117:12 courses 16:3,6,25 17:2 court 2:1,24 9:6 11:1761:17 110:22,24 113:10,11 114:16 115:1,2 cover 104:3 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050256 [coverage - district] coverage day department (cont.) difference 12:20 2:22 11:14 35:14,14 100:21 64:13 66:22,24 67:4 73:1 76:17 78:22 covered 100:23,24 101:16 111:16 97:23 103:16 108:8,9,15 different 53:25 112:3,13 113:15 114:12 110:3 18:7 20:9 21:8 23:11,17,17 covering 117:19 departments 24:7 25:13 26:11 28:19 54:24 days 22:12 29:13 31:6,9 35:22 36:14 craddock 11:8 100:22 depends 37:20 39:10 43:23 44:16 42:23 dc 104:12 46:23 49:23 52:8 54:22 create 6:5 deponent 65:3,11 74:2 76:24 83:11 23:12 dealing 114:5 101:13,14 102:12 106:1 credits 30:10 deposed difficulty 16:8 dealings 11:15 15:22 83:20 crestview 33:7 deposes digit 87:21 88:12,14 103:13 dealt 10:21 74:23 75:5 criteria 46:5 deposition digits 40:15 debating 1:142:189:7 11:7 13:20 75:5 critical 103:22 14:3,8 54:14,18 91:14,18 dii 24:8 deceased 111:12,15 112:3 115:13,16 10:9 current 50:21 53:12 57:2,4 depositions diphenyl 106:8 december 24:23 113:7 78:16 currently 18:6 19:25 derived diphenyls 9:8 12:8 13:1 17:1 decision 75:7 78:22 curriculum 42:1 describe direct 13:24 25:10 decisions 20:5 21:1,4 27:2 30:1 34:20 3:8,184:1837:451:14 curt 60:6 39:3 44:5 49:1 60:4,5 69:20 53:24 54:22 55:3 9:5 defendant 69:22 77:19 78:10 91:21 directly custody 9:13 92:4 105:23,25 48:21 50:23 52:12 55:14,21 115:19 defendants described 74:6 customer 2:11,19 11:3 115:10,17 40:20 45:3 67:6 director 35:16 defendant's describing 36:20,25 43:7 44:2,6,19 customers 8:9,10,11,12,13,14,15,16 23:19 39:15 56:3 45:23 63:21 64:8 69:5,8 30:11,15,16,18 35:20,21 25:2 61:21 65:20 81:18,20 description 71:6,13,25 72:6 74:8 44:11 80:12 84:2 83:5 88:25 89:9 98:18 23:24 26:25 52:3 99:18 directors cut defense design 60:9 96:19,19 6:10 9:24 21:12,12 25:15,18,20 dirt cutting definition designed 94:14,20,20 96:21 15:22 77:18 20:16 22:14 disapprove cuyahoga degree designing 60:10 7:17 15:15,25 16:1,5,9 17:12 26:10 discussion cv 42:15 98:11 desmond 61:7 70:11 82:17 1:4 2:8 9:10 115:8 degulis 56:22 disoriented darnold 710 data 63:10 d 7:14 deliberate 75:24 delivery 116:8,16 117:7,10 dempsey detail 87:16 95:18 38:15 disorients detailed 95:19 40:24 dissatisfied details 70:4 17:9 36:17 37:6 58:7 69:22 distill 9 2 12 6 3714 47 23 93 15 1125 3:149:13 11:1 115:21 116:2 dated den 63 5 98 25 71:7 dates department 24 6 8 56 23 20:9,1621:1224:1027:19 27:22 28:10,18,24 29:3 rlatrnn 7:12 10:14 35:25 46:6,8 52:4,5,11 57:15 58:16 59:1,16,18 98:4 determined 75:8 development 59:21 60:3,12,15,19 65:12 90:25 developments 38:19 80:8 distinguished 38:14 64:9 distribution 86:6 104:9 district 2:1,2 5:21 9:9 21:3 113:9 113:10 115:2,3 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050257 [division - familiar] division easement engineer's examined 31:17 32:5 40:5 64:3 95:2 16:14 113:17 doctor east england example 16:5 87:15 92:16 104:24 16:1 22:1035:1951:11 document ed entailed exchanger 13:23 61:17,25 62:6,9,12 64:6 30:2 28:2 62:24 63:4,7,9,13 81:16,25 education entire exhibit 82:2,3 83:9 88:11 89:18,24 15:10,12,13 16:25 17:6 22:6 52:16 88:15 8:9,10,11,12,13,14,15,16 90:23 98:13,14,22,24 99:4 effect entitled 24:19,25 25:2,8,9,17 37:11 documents 46:3 40:6 43:7 61:18,21 62:2,7 65:15,18 15:5,8 104:4 effects entrance 65:20 81:18,18,20 82:19 dodge 44:18 95:6 83:4,5,11 88:18,24,25 89:8 4:11 9:17 eight environment 89:9 98:16,18 99:2 doing 14:14 39:19 67:12 exhibits 18:4 38:18 either environmental 8:7 103:23 dollars 29:3 49:16 77:20 114:8 39:21 40:1 42:11 43:8 44:2 existed 13:18 electric 44:6,20 45:23 58:2,19 23:1 domain 27:6 79:23,24 104:23 61:14 62:20 66:21,25 67:4 existence 58:4 106:16 107:9 67:6,7,16,20 73:15 74:12 53:14 double electrical eppenberger existing 58:11 75:2 27:24 85:25 104:8 106:4,5 2:20 3:4 9:3 10:1 11:7 12:3 12:15 84:25 doug 107:15 110:5 14:19 113:12 116:12 exotic 10:7 electricity equipment 75:9 douglas 30:7 106:7 20:1721:1222:1426:10 expect 7:3 elmer 27:5,15,16,23,24 28:9,15 11:8,23 downturn 64:12 77:20 79:17 104:11 107:16 expected 101:8 em 109:1,3,8,11,21 110:12 95:22 draft 31:13 era experience 63:5 emeritus 98:12 13:10 dramatic 17:1,3,5 escapes expires 84:17 emitted 71:3 112:15 114:18 117:25 drawing 80:25 escorted explain 89:5,13 employed 97:19 41:23 drive 17:13,25 18:3 72:13 esq exposure 12:13 employees 3:3,13 4:2,12 5:2,9,18 6:2 35:14 drums 44:11,12 84:15,18 85:6,13 6:11 7:3,13 extent 78:17 99:11 essence 25:17 dsw employment 38:2 extremely 65:1981:1983:12,12,13,13 15:6 17:16 18:8 estimate 89:25 83:13 98:24,24 dukes 5:3 duly 10:19 113:5,17 duties 27:3,12 67:16 e eaddy 42 earlier 22:1529:1,8 30:1541:4 46:2 56:12 69:8 71:7,17 72:22 74:11 76:15 85:1 early 16:22 17:4,6 34:11,14 110:25 enclosed 14:13 f 93:8 94:6 encompass 77:15 ended et 1:2,6 2:5,10 9:8,8 115:6,9 eugene 58:12,13 74:11 facilities 45:19 77:24 facility 33:8 50:3 76:1,8 77:13,17 54:24 evening 86:5 89:6 90:17 92:10 engineer 16:17,18,21,24 17:8 25:15 25:19,20 26:6 engineering 101:17 eventually 107:25 evolving 102:5 104:7 faint 59:13 fairly 15:16,18 16:12 17:1220:16 38:12 39:16,23 60:25 64:25 15:11 37:17 21:11 22:2 29:1051:18 52:1 exact 37:14 58:21 84:14 93:15 familiar 20:24 64:17 68:4,10 69:13 engineers exactly 22:3 29:9 51:20,22,23,25 78:8 75:23 80:19 81:1,11 89:7 90:19 97:13 105:20,21 51:25 examination 8:3 10:23 108:4 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050258 [family - grievances] family five 103:1,3,6,9,10 31:6,9 48:13 54:8 74:21 far flame 83:23,24 80:24,25 fashioned flexible 75:8 21:18 faust floor 73:7 94:14,16,18 favor fluid 116:1,11 117:1 79:5 105:3 109:9,12,22 fax fluids 3:9,19 4:8,19 5:14,23 6:7 23:7 64:9 104:20 110:8 6:17 fluorescent fell 105:12,14,22 58:4 fmc felt 6:10 9:23 34:23 focused ferrar 42:10 63:16,18 foil fifties 106:2 16:22 folks fifty 10:3 20:23 follow figure 38:17 47:8 48:23 followed filed 27:9 31:2 56:24 58:6,13 70:6 following files 26:24 34:6 38:12 46:17,19 15:5 83:12 111:16 fill follows 103:13 10:22 filling force 17:10 69:16 final foregoing 20:15 63:6,9 112:2 113:21,23 financial foreign 67:25 68:3 42:19,19,20 find foreman 90:4 100:12 fine foreman's 17:11 24:18,20 28:21 33:13 102:24 47:7 88:1 91:9 110:21 foremen finish 101:13,15 102:16,17 11:11 forget finished 21:4 87:11 30:6,11 59:6 61:19 77:7 forgotten firm 61:4 104:24 9:16 13:6,14 115:19 forklift first 76:6 10:19 17:16 25:16 28:22 form 31:4,8 35:8 39:14,18 47:20 47:5 84:19,22,23 48:15,24 63:5,24 85:16 formal 90:7 94:16 98:1 113:17 15:20,23 16:13 35:9,11,13 fits 65:9 70:5 97:10 98:7 99:17 former 99:10,11,15 forms generally (cont.) 17:10 34:20 35:21 36:8 38:13 formulated 40:10,23,25 69:20 77:17,19 86:23 87:1 91:21 formulation gentleman 85:18 71:7 formulations geographically 86:11 92:15 forth georgia 68:3 100:3 113:24 7:6 forty gerald 107:20 59:13 found 88:12 89:20 gii 5:17 foundation give 41:21 52:2 88:1 foundries given 103:7 40:861:12 101:21 112:5 foundry 114:4 7:1 103:12 go four 11:8 17:3,16 18:1522:13 74:23 75:5 25:14 26:1 31:1 34:19 35:7 frame 37:13 41:21 48:20 56:8 19:10 20:5 23:14,23 25:15 69:12 70:1 71:4 82:13,20 25:18 46:14 62:25 74:15 84:19 88:9 95:23 97:15 85:23 101:5 98:11 104:21 111:8 fuhrmeister goal 51:15 52:14,15 53:6 57:15 11:12 58:5 going full 11:20 14:13 17:5,23 20:4 114:2 23:14 35:12 37:16 41:20 fulton 46:25 61:16 63:11 65:16 7:7 75:7 76:6 78:3 81:16 82:24 function 82:25 87:24 88:5,17 89:4 58:25 59:12 95:1 90:1 98:13 102:2 further good 16:1 17:2 59:7 114:7 10:1647:10 106:14 110:15 g ga 46 1175 gale 6 12 9 23 gamut 4017 gas 308 gather 12:2 gene 58:10 72:8,18 general 20:7 29:24 30:9 31:14 36:17 44:12 52:3 79:23,24 88:19 90:1 104:23 generally gore 117:14 governments 42:19 graphically 76:19 grass 94:20 gravel 94:20 green 2:3 115:4 greensboro 14:22 grievance 69:13,16 70:5,6 grievances 51:11,12 20:5 21:16 27:2 30:1 32:14 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050259 [group - individuals] group health hmm (cont.) 6:3 22:7,9 23:16 26:19 31:5 44:18 46:2 102:8 105:19 31:16 32:1,7,12 35:20 40:5 hear hoc 51:17,21 52:4,16 53:13,22 11:1767:23 63:15 64:18,21,22 65:1 55:7 57:19 60:6 63:22,23 heard hodges 63:23 64:4,9,10,20 65:1 53:8 64:1981:7,1591:4 63:16 64:1,3 67:5,7 68:7 74:13,24 76:25 96:17 hoffmann 77:20 heat 7:14 grouping 28:2 78:11 110:8,8 hold 41:12 held 49:15 groupings 21:9 24:3 26:15 29:7 33:14 home 42:2 39:14 55:17 15:7 groups help hopefully 29:13 31:7,9,22 32:2 74:24 22:21 24:17 42:6 46:20 11:11 guess 48:23 49:6 52:6 82:9 87:18 hosmer 38:1 57:23 106:6 89:22 90:5 56:22,25 57:1 69:10,11 guessing helpful 71:16,17 72:4 33:12 42:8 48:13 60:17 91:12,12 hour 66:17 105:9 helps 11:11,24 guys 41:22 81:17 90:13 hourly 110:17___________________ hereinabove 85:7,11 h half 11:8,13 108:24 hand 38:1861:1665:1681:16 89:4 98:13 114:11 117:18 handed 63:4 handle 28:17 100:13 110:4 handled 36:2,3 44:16,18 45:15,20 69:23 handling 28:14 40:17 hands 28:1 happened 34:24 43:25 harbert 6:14 hard 89:25 90:25 91:7 hats 38:2 hauling 55:6 hb 86:15,17 head 47:12 97:3 headquarters 18:18 19:22 20:1 36:2,3 39:11 46:1568:13 112:6 hereto 112:4 hereunto 117:18 hesitate 13:23 14:9 27:25 49:17 hesitated 94:25 hesitation 108:13 hexagon 76:20 high 15:14 59:23 108:24 higher 15:13 highway 96:4,7,9,10 hills 5:12 hired 85:3 hiring 51:6 historic 99:8,13 histories 99:7 history 98:9 hmm 19:12 20:13 46:13 47:6 64:22 73:6 79:11 85:21 96:8,23 97:3 100:4 101:4 hours 2:22 14:14 100:21 103:20 huckaby 5:3 huh 31:11 hundred 28:5 hundreds 28:19 huron 5:8 7:15 10:5 hurry 61:2 husch 2:19 3:4 9:3,25 11:7 12:3 14:19 113:12 116:12 husch.com 3:10 hydraulic 23:7 30:15,16 79:5,17 109:1,3,8,11,21,22 110:12 hydrochloric 84:4 hydrogenated 76:14 77:9,9 86:12,13,18 hygenated 77:9 hygiene 44:11,13 46:3 idea 35:21 85:10 105:12 identification 25:4 61:23 65:22 81:22 identification (cont.) 83:7 89:2,11,12 98:20 identified 31:24 69:7 71:6 100:6 identify 9:11 63:11 98:16 ii 6:11 illinois 18:11 30:23 39:8 immediate 103:10 immersed 106:3 107:3 implies 41:3 95:10 improperly 44:17 inch 108:24 inches 108:24 include 41:14 50:3 60:25 included 27:14,15 35:1 44:8 45:14 46:17 including 67:16 inclusive 67:16 incoming 30:5 increase 84:18 85:2 increased 84:24 85:10 independent 41:18 index 8:1 indicated 19:19 23:15 24:1 30:22 34:2 56:12 66:6 indicating 90:20 individual 33:14 36:22 37:4,24 38:16 42:16,21 51:5 52:19 55:5,7 58:22 64:2 67:13 70:19 72:19,21 84:15 99:17 100:16 individuals 14:3 36:18 57:13 58:6,9,18 59:17 60:14 63:12 64:14 65:5 68:8,12,21 100:10 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050260 [individuals - lavey] individuals (cont.) 101:18 102:9 103:17 industrial 40:6,14,20 41:1,17 42:4 43:15 44:10,13,25 45:24 46:3 industries 5:17 7:1 10:8,10 inerteen 107:16 information 41:22 ingredient 78:15 86:20 93:21,21 ingredients 22:13 23:8 29:14 initial 106:9,17 initially 18:1020:8 21:11 25:20 95:18 initiating 51:13 inorganic 31:16,20 32:3 99:15,20,23 inorganics 41:10 99:24 inquiries 45:16 insecticide 50:1 100:9 insecticides 76:15 inside 94:18 106:1 107:5 installations 27:15 installed 27:5 instrument 94:13 97:24,24 instruments 75:9 93:9 insurance 12:21 intent 16:5 interested 13:9 46:25 114:9 intermediary 77:8 intermediate 43:21 44:3,21 intermediates 43:9,10 44:4 59:7 internally jobs know (cont.) 77:11 27:8 37:16 46:24 97:18 100:11,15 102:6 interrogatories joe 105:25 107:23 108:1 109:8 10:22 9:25 110:9 interrupted john knowing 21:23 50:25 5:2 10:4 18:23,24 42:23 28:17 66:3 introduced 56:17 63:17 64:5,6 knowledge 20:11 joined 21:7 33:17 35:16,18 36:13 introduction 13:11 36:16 67:2,21 73:19 78:1 84:25 jones 87:10 95:15 99:11 inventories 73:11 known 29:25 jordan 20:10 21:17 40:15 62:21 involve 2:23 9:6 113:4 114:15 krummrich 29:1641:9 117:22 19:5,8 30:23 31:4,6 32:18 involved joseph 33:6,10,18 34:3,18 38:22 13:7 20:9 22:7 29:13 30:6 3:3 15:3 52:21 39:7 66:4 68:19 78:1,3 31:15,1835:21 38:1351:13 joseph. nassif 97:13 60:21 65:5 73:15,17 78:17 3:10 97:4 jtaylor involvement 6:18 14:1020:1930:10 judge involves 2:3 115:4 12:19 jumped ish 71:5 11:9 19:1 23:25 24:2 jurat island 116:7 76:9 k issue 38:12,17,20 39:16 62:20 kaley 73:13,14 69:25 70:12 issues 39:23 42:17 46:11,18 60:25 karen 5:9 10:5 keep 64:25 97:5 15:8 38:19 48:3 j keeps 1 l.l.p. 3:14 5:19 115:21 116:2 lab 58:25 59:3,5 label 89:13 labeled 78:17 89:14,21 laboratories 42:20 laboratory 51:18 58:25 59:12,14 lack 41:20 lackey 73:21,22 jack 106:8,18 lampblack 51:3 66:8 kelly 80:19,20,22 81:1,5,17 january 14:18 lampblacks 114:18 117:25 key 82:10 jarred 3:15 115:22 116:3 land 6:11 9:22 kind 37:9 jerome 27:7 52:10 60:23 87:16 landwehr 58:20 92:16 105:23 52:21,24 53:11,12 57:16 jerry knew 58:5 9:5 10:16 58:20 72:22 73:2 85:15 91:8 102:2 large jesse know 108:17 38:4,6 56:13 57:7,11 72:8 11:15,19,22 12:1 14:21 lasted jj 112:23 15:11 21:1,3,23 32:9 35:12 20:14 37:11 38:6,18 40:22,24 late job 43:20 48:4 50:19 53:6,13 16:7,22 20:23 21:10 37:17 20:5 23:19,24 26:5,15,25 56:18,23,25 57:1,7,10 56:11 27:3 29:22,22 34:6,20 35:1 59:15 60:4 62:14 63:6,9,17 laughter 35:15 36:12 37:20,25 39:16 64:1,1966:1567:11,22 14:12 55:11 102:3 39:17,18,25 40:3,10,13 71:2 72:12 73:10,12,17 launching 42:9,1345:1,11 50:1451:4 74:16 79:20 80:22 81:12 103:22 55:3 61:1497:10 84:3 85:15,19 86:5,14 88:7 lavey 89:6 90:15,16 92:4 96:1,18 3:13 8:3 9:12,12 10:24,25 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050261 [lavey - manufactured] lavey (cont.) 24:18,21,24 25:5,9,11 33:22,24 41:24 47:9,12,14 54:6,8,11,20 57:3,6 62:1,5 62:8 65:23 81:23 82:13,19 82:23 83:10,14 85:4 88:4,9 88:13,23 89:3,12,19 90:12 91:20 96:13,15 98:23 99:3 103:22 104:2,5 108:25 110:15,19 111:2,6,10 law 6:3 13:6,14 lawful 10:19 lawsuit 11:4 lawyers 14:5,15,17 lay 37:9 layout 90:1,19 92:14 lead 87:7 leak 109:22 110:3,5,5 leaks 109:21,24 learn 97:25 learned 97:9 learning 35:14 98:6 leave 18:5 30:25 36:17 37:12 38:8 lee 5:1 10:4 left 17:24 24:1 37:1,9,10 38:17 38:18 48:6,10 50:12 53:4 53:14,18 72:9 80:7 84:16 93:17 95:15 103:24 legal 9:5 12:3 leisy 49:7,12,25 leisy's 49:9 leitman 4:13 letter 82:5,7 letters 82:25 level 36:2,4 59:23 66:21,24 67:8 67:24 68:9 70:3,15 library 89:15 library's 89:16 license 114:18 lietman 9:15 life 12:20 light 106:8 lighting 106:24 limit 46:8 limitation 11:11 line 24:4 37:4 96:3 liquid 79:24 80:8 104:14 106:3 110:10 liquids 79:17 list 47:2,3 listed 65:5 listing 40:24 lit 106:8 litany 32:16 little 37:9 76:8 107:5 live 12:8 87:12,13 88:14 lived 88:20 living 38:6 50:20 53:7 56:18 57:1 103:9 lie 2:20 3:4 113:12 116:12 Up 4:3 7:4,14 14:22 117:2 local 70:24 71:1 locally 21:2 locate 87:24 89:5 located 11:1 36:21 43:1 64:14 76:1 109:18 location 18:12 19:5 76:24 88:19 locations 18:8,10 lombardi 7:14 long 5:10 17:21 18:3,24 19:8 26:21 29:19 39:25 43:3 57:7 103:25 108:24 longer 37:18 45:8 99:24 look 25:6 61:18 81:24 82:24 98:14 looked 92:5 looking 25:1242:1361:1962:1 66:2 90:7 92:8 looks 80:10 89:7 loosely 77:23 lose 88:18 lot 98:4 lou 51:15 louis 2:21 3:6 12:10,13 15:17 18:2,10,16,17 19:20 20:2 36:21 37:13,17,25 38:9 39:2,11 43:1 46:16 47:15 47:22 48:15 52:12 59:25 64:15 66:25 71:14 73:15 95:16 113:3,13 114:12 116:14 117:16,24 lsppc.com 4:20 lynette 4:2 9:20 lynette.smith 4:9 lynne 4:129:15 m magistrate 2:3 115:4 mailing 12:11 main 95:6 maintain 17:7 28:11 maintained 42:17 maintaining 16:23 108:6 maintenance 24:1027:1,3,4,10,11,13,19 27:22 28:10,17,24 29:2 51:24 54:4 55:2,8 59:16,18 70:10 101:9 103:15 108:9 108:15 110:3 major 15:1530:14,16 making 22:11 23:3,6,10 46:6 malathion 87:4 man 35:19 managed 36:14 management 38:10,15 42:1 49:1 59:24 60:6 62:23 63:8 69:17 70:7 110:2 manager 33:11 34:16,21 35:17 36:11 36:19 37:5,19 39:21 40:1,8 40:11 42:3,11 43:3,14 48:19 49:1 50:16 52:17 53:2,15,25 54:23 55:22 56:10,15,25 57:8,10 58:3 59:18 61:14 62:20 66:23 68:1869:1570:8 71:1,17 72:3,9,10,13,16,24 74:16 74:21 76:12 77:3 84:12 85:24 87:2,12 88:15,20 94:21 95:5 97:8 98:10 101:6 103:16 105:1,7 managers 56:9,20 69:1,4 71:14 manmade 94:18 manner 97:3 manufacture 22:19,22 80:6 manufactured 35:3 38:22 45:9,15 68:19 77:25 78:13 79:9,18 83:17 83:20,23 87:1 91:24 92:3 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050262 [manufactured - names] manufactured (cont.) mead miller monsanto (cont.) 93:16 99:24 3:129:13 11:2 59:13 103:2 manufacturer mean mind monsanto's 104:13,14 31:16 33:20 35:9 37:18 12:21 23:9 24:6 67:18 46:6,15 64:4 68:13 78:19 manufacturers 44:13,14 48:5,20 51:20 109:6,17 113:16 78:21 96:19 104:25 107:16 69:16 75:20 mine montar manufacturing means 47:12 80:5,6,14,16 83:25 18:18,21 22:17 30:4,8 31:7 44:15 47:9 75:1,17 minute monte 32:18,25 33:7 36:20,25 meant 54:8 67:14 39:3 49:7,18 50:11,22 54:1 33:22 minutes month 54:25 55:7 64:4 68:15,23 mechanic 11:25 89:5 104:1 110:25 13:18 34:10 37:10 68:24 69:5,8 71:6,13,20,25 110:4 missed moody 72:4 74:3 77:15 78:11 93:7 mechanics 77:5 49:8 50:1,6,19 100:5,15 97:20 100:6,18,24 102:18 27:5 missing 102:20,21 map medical 62:6 moore 87:25,25 90:3,13 12:20 46:6,8 64:13 mississippi 14:22 mark meet 21:2 morning 24:1961:1765:1881:18 14:15,17 missouri 11:12 82:19 83:4 88:18,23 89:7 meeting 2:21 9:4 12:9,13 16:19 motor 98:16 70:5 18:10 113:1,5,13 114:12,17 106:24 marked member 117:23 motors 25:3,8 61:22 65:21 81:21 17:1 28:24 60:11,15 mixing 105:15 106:16 83:6,11 89:1,10 98:19 members 75:22 mountain marketed 59:23 70:7 100:17 103:1,3 mixture 87:14 84:8 103:6 75:7 107:12,14 move marketing memo mm 34:17 35:19,24,25 36:3,5 63:22 115:1 19:12 20:13 42:8 46:13 moved marking memory 64:22 73:6 79:11 85:21 96:17 89:16 24:3 49:6 82:9 86:20 94:24 96:23 97:3 100:4 101:4 muriatic martin mention 102:8 105:19 84:4,10 63:25 64:1 39:17 72:20 mo mute master mentioned 3:6 116:14 117:16 10:14 15:18 29:12,14 30:15 58:24 63:22 modify myers master's 71:16 72:8,22 74:11 76:15 60:10 6:2 9:18,18 15:21,25 17:12 77:6,9 85:1 96:16 97:9 material 107:3 112:6 13:20,21 30:5 52:9,10 87:8 met materials 14:18 40:15 59:9 21:17 23:12 44:16 59:9 metals 91:23 92:1,21 7:12 10:15 math method 18:4 75:8 matters mi 52:6 58:2,19 73:15 5:12 maynard michael 6:12 9:22 7:13 10:11,14 mcclain microphone 56:17,21,24 88:8 108:23 mcglaw.com middle 6:18 16:7 93:14 mcmahon midnight 7:13,14,20 10:11,13,14 101:17 mcwane midway 1:6 2:106:109:8,23 115:9 54:11 mdhl.net mike 7:20 14:18 moment n 22:15 47:13 50:18 54:4 56:1 59:19 81:24 83:1 100:18 moments 71:12 mono 75:2 monochlor 74:25 75:22 mons 62:3,7 63:13 monsanto 12:16,22,24 13:3,7,10,11 13:11 15:6 18:2,4,5,8 20:1 37:20 38:11,16,18 39:3,18 40:6,14,2041:13,17,19 n.w 6:4 n.w. 5:20 name 9:4 10:25 32:9,10 33:10,13 42:24 43:11 45:2 49:10 50:18 54:3 55:9 58:22 59:15 63:24 66:7 70:25 71:3,5 72:20 73:4 74:23 75:11 78:10,19,21 79:7,16 79:23 80:3 82:4 84:9 103:19 107:13 115:19 named 44:1 71:7 nampQ 42:4,16 43:15,22 44:2,11 44:22,24 45:7,19,23 46:4,7 46:9 59:24 66:22 67:4,24 74:22 79:7,16 82:10 83:21 89:6,20 90:4,6 95:23 96:24 33:2 53:17 58:8 59:17 65:8 65:9 86:22,25 90:5,18 101:24 102:23 104:15 107:17 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050263 [naming - p.m.] naming notary 43:23 2:24 112:19 113:4 117:23 narrow note 42:5 74:17 62:5 narrows notes 55:10 61:6 90:3 nassif notice 3:3 9:25,25 10:3,11 12:4 113:8 15:3 24:14,20,22 25:1 november 33:20,23 41:20 47:5,7 54:7 17:22,25 63:6 54:10 57:2 84:19,22 88:2,5 number 90:10,11 103:25 108:22 9:9 11:3 15:12 48:7 54:13 110:17,20,22 111:1,4 54:18 62:3 63:13 74:24 nationsbank 81:6,18,1984:1891:13,18 4:4 117:3 98:16 nature numbered 36:13 89:14 98:24 near numbers 21:2,2 63:14 75:5 83:12 84:13 necessary 46:6 70:18,19 need 11:22 12:1 25:17 38:10 40:24 106:8,17 needed 47:13 101:12 needs 11:24 negotiating 51:10 neighbors 76:5 new 27:15 37:25 38:20 43:11 45:6 84:25 95:17,21 97:12 97:14 104:24 newly 37:23 nineteen 20:22 nods 97:3 non 76:2,10 77:2 108:3 normal 117:12 north 4:14 5:4 6:13 14:23,25 92:11,16,18 northeast 4:5 117:4 northern 2:2 9:9 113:10 115:3 notarial 114:11 o oaths 113:6 obeyed 34:19 object 41:20 47:5 84:19 objected 84:22 objection 88:6,7 objections 114:1 objectives 60:7 obligations 28:13 obtained 17:11 80:23 obviously 37:7 56:10 occasion 27:22 47:16 59:8 60:18 64:23 98:8 occasions 15:12 109:20 occupational 46:2 occurred 101:9,11 occurring 38:19 o'clock 11:9 111:3 office 39:11 officer operation 115:12 32:21 68:24 officers operations 69:24 11:5 28:1029:11 32:11 offices 33:15 43:8 44:2,7,20 45:13 2:199:3 113:12 45:23 50:2 68:23 81:2 official 85:18 98:9 99:8,13 101:11 77:18 101:18 officially operator 37:15 101:20 102:15 officials operators 69:24 98:3 101:19,25 102:7,13,17 oh operator's 3:177:16 12:12 15:2 43:19 102:24 59:6 67:11 71:9 72:2 79:3 opportunity 101:2 111:4 115:24 116:5 70:17 oil oral 20:12 107:1,1,4,6,10,10 10:22 60:20 oils order 30:16,17 24:4 56:9 okay orders 13:8,25 14:5 15:2 19:2,19 31:2 26:3,7,9,15,21 29:2,12 organic 30:19 31:3,8 32:6 33:23 31:17,1732:2,5 40:541:6,6 35:15 39:9,13,20 41:2,25 41:9,11 64:3 43:6,13,18,24 44:5 45:1 organics 48:9,11 49:5 50:19 51:14 100:2 52:15 54:10 55:13,16,19,25 organization 57:24 68:5 69:7,11 72:2 48:24 56:5 60:8 73:3 75:18 77:2 82:4 83:22 organizational 87:7 88:23 90:9 91:3,6,12 54:22 56:2,3 65:16,24 92:20 96:11,11 97:4,8 100:13 99:10 100:5 101:3,24 organized 102:22 103:1,22 105:5,18 37:25 106:15 107:7,10,13 110:17 orient Oklahoma 90:5 92:15 16:3,4,10 17:17 orig old 116:6 13:11 52:9 75:7,8 96:4,4,6 original 96:7 105:19,19,21 41:11 94:20 95:24,24 older 115:20 45:6 originally olive 13:10 117:15 outside once 42:20 70:20 22:24 47:21 99:20 overall o'neal 14:7 39:15 59:11 68:14,22 4:129:15,15 94:8 open overview 93:2,7,11 94:4 17:23 operate 79:5 operated 79:17 operating 100:19 P p.c. 4:136:3,12 p.m. 2:22,22 9:2 54:15,18 82:16 82:22 91:15,18 111:13,14 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050264 [packaged - point] packaged pcb (cont.) peruses planning 79:11 80:1 110:10 61:24 82:1 83:8 88:10 68:8,10 page pcbs 89:17 90:22 98:21 plant 62:6 63:5,13,15,15 64:18 20:20 21:21 22:17,19 23:4 pesticide 18:18,21,22,23,23,25 19:6 pages 23:8,11 28:14,17,23 32:19 85:18 86:11 19:8,14,17 20:22,25 21:6,9 83:11 113:23 116:15 117:6 38:13,21 39:3,17,24 40:8 pesticides 22:1,4,6,8,17,19 23:1,3,4 paid 40:1842:9,11,1945:8,17 86:23,25 87:9 23:10,15,18 24:2 25:14 13:2,13 117:11,12 45:18 47:2 58:23 65:6 petroleum 26:16 27:17,17 28:8,25 pans 68:18 74:20,22 75:13 77:10 17:18,21,25 20:4,6,17,19 29:11 30:12,20,23,25 31:4 76:25 peachtree ph.d. 31:6,7,10 32:18 33:8,11 papageorge 4:5 7:5 117:4 16:1 34:3,7,9,16,18,18,21,22,24 1:14 2:18 9:7 10:18,25 12:6 pebble Pharmacia 35:3,8,17 36:1,6,9,11,15,18 13:19 15:4 25:10,12 54:14 12:13 10:1 11:4 12:16 13:2 36:19,23 37:1,5,8,10,11,12 54:19,21 61:1662:1,10 pending phaseout 37:16,18,23 38:4,8,22 39:7 81:25 83:15 89:4 91:14,19 9:8 113:8 108:5 44:1647:16,21 48:1,17,19 108:22 111:12 112:1,10 Pennsylvania phelps 48:25,25 49:23 50:8,15 115:16 5:20 4:11 9:17 51:7 52:5,13,17 53:2,14,25 paper pension phenyl 54:23 55:22,23 56:4,9,10 86:20 12:23,24 76:21 56:11,15,20,25 57:7,8,10 parathion pentasulfide Phillips 58:3 59:18 66:3,4,11,19,23 87:3 92:5,6,8,10,24 93:22 76:16 85:2 91:22 93:5,13 17:18,21,24 20:4,6,8,15,18 68:18,20 69:1,4,14,15,23 93:24 94:2 100:3,9 102:6 93:23 phone 70:8,20,23 71:1,14,17 72:3 parkway people 10:3,12 111:6 72:8,10,10,13,15,16,24 5:11 23:16 28:6 46:23 51:6 phonetic 73:18 74:1,15,20,21 76:2 part 57:18 60:14 64:20 70:2 71:8 73:13 76:11,12 77:3 78:1,3,13,16 34:11 37:17 42:13 45:7 73:9 84:11 phosphorus 79:10 80:1,16,17 84:12,12 55:23 63:14 67:12 76:2 perceive 76:15 85:2 91:2,22 93:5,13 84:14 85:23,24 86:4,7 87:1 90:10 100:7 101:21 60:5 93:23 99:15 87:2,9,12 88:15,20 91:1,7 particular perceived phrase 92:3 93:4 94:21,22,22 95:5 21:20 22:5 23:24 46:4 38:10 44:14 75:20 77:13 88:7 95:6 97:8 98:9,10 99:8,21 62:23 68:7 84:8 106:21 percent 106:12 100:7 101:6 103:2,16 104:6 107:13,18,19 75:6,13 physician 105:1,7,8 106:21,23 107:23 particularly perfect 55:24 108:2,7,10 109:1,4 110:8 83:1 84:14 pick plants parties perform 66:22 110:16 46:7 68:22 69:2,3 13:9 93:25 114:8,10 95:1 picked plasticizer parts period 41:1242:12,16 63:23,23 64:10 86:19 35:22 41:13 43:23 16:25 19:16 22:20 24:9 picture plasticizers paul 26:4,9 29:2 35:4 37:15 38:1 71:2 21:17,20 22:11,1326:19 64:3 42:5 47:1,24 48:6 52:16 pieces 29:14,1541:3 pause 61:8 67:15 74:21 95:8 46:9 77:19 104:11 plastics 96:12 101:9 pilat 21:18 paved perry 5:9,15 10:5,5 plaza 94:23,24 95:2 117:14 pilot 2:20 3:5 4:4 6:14 9:4 paving person 91:1 116:13 117:3 80:15,16 55:13,18 59:11 70:5,20 pipe please payne 71:11 115:19 7:1 10:8 110:5 9:10 10:17 11:1934:21 4:13 9:16 personal pipeline 83:4 88:20 98:17 pcb 15:5 27:6 97:21 pliable 23:11 27:23 28:9,15 38:12 personally place 21:18 39:16,23 40:18 42:13,17 28:1 75:23 61:2 69:14 99:16,20 plugged 46:11,18 60:24 62:20 64:25 personnel plaintiff 88:2 68:14,23 74:24 75:14 76:2 51:2 54:1 55:1 66:7,10,15 3:2 pocket 76:10 77:2,15 78:10 99:14 66:19 70:1,8 85:3,20 plaintiffs 24:15 102:5 104:6 105:2 107:10 peruse 2:6 115:7 point 107:12,14 108:3,3 109:9,12 89:23 99:2 11:25 16:2 17:1337:19 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050265 [point - range] point (cont.) president production (cont.) purposes 38:21 39:1 43:11 45:8,12 67:7,9,15,19 70:25 71:10 81:2 84:1,24 85:14,17,20 89:12 48:16 54:11 55:17 65:3 71:20,23 87:8 91:21 93:12,22,24 pursuant 67:3 68:16 71:22 74:4 presumably 94:2,8 97:11,12,16 99:12 113:8 90:10 97:21 98:2 108:1 45:11 99:14,20 100:10 101:21 pursue 110:16 primarily 110:1 16:5 polychlor 101:15 107:20 productions pursuing 74:25 primary 23:18 51:25 polychlorinated 48:16,18,19 85:22 86:14 products push 33:21 93:19 22:7,9 23:3,6 29:13,17 20:11 portion print 30:11 31:5,15,18,19,20 pushed 92:10 80:21 32:12,15 33:3,3 35:2 40:7 98:5 position prior 40:14,15,18,1941:1545:4 put 21:24 24:2 25:19 27:9 29:6 17:5 24:12 50:8 56:20 45:5,6,7 46:3 52:7,7 59:6 28:1 46:5 64:20 66:6 29:8 30:2,19 31:3 33:14 67:19 72:12,15 95:24 98:9 69:3 74:18,22 75:19,24 putting 34:15 35:19 39:2,14 43:6,7 99:12 76:10 77:2 84:25 85:1 63:1 86:8 44:19,22 45:21,25 46:5 probably 104:7 pwg 52:20 53:4 55:13,16 57:14 75:17 92:7 110:15 professional 1:4 2:8 9:10 115:8 67:9 72:23 problem 13:2 16:14,15,17,18,21,24 pydraul positions 70:12 17:8 79:15,16 21:9 25:13 39:10 54:22 problems program pyranol 55:21,25 22:4 23:17 29:10 52:1 108:2,5 79:23 80:1,3 107:16 possession procedure progress pyranols 15:7 70:18 61:3 79:22 possibility 108:14 possibly 35:6 pot 80:9 pots 76:25 power 85:22,25 86:2 90:8 106:9 106:18 practices 60:8 pre 98:12 preliminaries 11:6 preparation 13:20 14:2,17 prepare 62:12 preparing 14:8 procedures project q 69:13 process 97:5 projects qualified 1136 22:6,23 23:1 33:17 35:14 27:6 52:8,9 78:12 84:2 85:20 promoted 91:22,23 93:9 98:3 101:22 26:5 processes pronouncing 20:16 93:3,7 97:11,12 19:3 99:12,20 proper processing 40:16,16 110:4 20:1721:1326:1059:8 property produce 95:23 96:3,19,20,24 52:7 77:8 propounded produced 10:22 114:1,4 21:16 22:24 31:5 33:18 public 49:25 76:11 80:24 93:10,23 2:24 3:16 44:12 64:6 producers 112:19 113:4 115:23 116:4 42:19 117:23 producing pull queeny 18:23,24 20:22,24 21:9 22:6,17,19 23:1,3,4,10,15 24:1 25:13 26:16 28:8,25 30:11,20,25 question 11:18,20,21 38:2547:8,10 74:16 92:13 95:14 96:2 105:10 questions 1024 159 4517 11325 114:3 quick 17 23 25 6 quickly 1511 20:12 22:4 74:19 92:5,7,9 24:16,25 92:25 94:3 100:25 pump product 27:6 52:8 quite 21:1 23:12 30:6 32:16,16 40:8 pumps r presence 40:11 42:4 43:3,14 44:9 79:6 raakhee 45:18 83:18 45:15 77:7 81:5 82:10 83:3 purchased 5:18 10:9 111:6 present 83:16 86:10 104:10,14,15 104:13 raakhee.biswas 23:9 70:6,11 104:17 107:13,15 pure 5:24 presentation production 57:23 raise 60:22,23,24 61:5,9,11 63:1 21:14,15,21,24 22:6,23 purity 88:6 64:24 23:1 24:8 25:23 26:17,21 40:16 range presentations 26:24 33:15 45:12 50:4 purpose 62:3 60:19 51:23 70:10 76:1,3,9 77:16 52:3 60:2 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050266 [ratio - retainer] ratio recommendations relocation representing 85:7,11 61:1,3 62:22 95:25 97:5 9:13,17,18,21,23 10:1 raw record remained 69:23 70:22 30:5 59:8 87:7 91:22 92:1 9:1,11 25:9 54:15,17 62:2,5 45:5 require 92:21 65:19 82:13,15,18,21 83:10 remarks 16:24 35:15 reached 89:13 91:15,17 98:23 114:1 required 98:2 108:22 111:7,8,10,13 remember 17:7 35:18 36:13 52:7 read recovery 17:9,9 19:1 23:23 31:13,14 research 61:6 80:20 82:3 90:1,15 20:10 32:17 33:13 37:2,3,14 41:4 20:8 63:21 64:8 99:7 112:2 refer 41:12 42:8,15 47:23 48:3 residence reading 77:14 78:9 79:4,15,22 49:9 55:8,9,16 56:2,7,22 103:13 90:15 reference 57:9,17,20 58:8,10,12 residue ready 90:8,24 91:1,2 59:20,22 61:8 62:11,16,18 80:10 59:7 referencing 65:10 70:22 71:2,13 72:14 reslawgrp.com realize 64:18 72:18 73:4,6,8,14,22,24 6:8 89:25 referred 74:4 78:7 79:10,21 85:9 resolution really 31:18 63:22 75:19 77:23 86:19 87:23 91:25 92:1,21 6:3 47:1 78:24 80:7 82:11 83:3 101:18 102:9 94:1 96:16 97:18 105:9 resolve 101:18 referring remembering 70:3,14 recall 90:4 107:11 108:23 109:16 83:20 resolved 16:21 22:16 23:20 29:1,18 refers renaming 70:15 30:14,18 31:12 33:2,10 63:15 77:14 44:23 respect 34:10 37:6 47:18,20 49:12 refresh renewal 28:14 42:9 50:9,17 52:24 53:17 54:3,5 25:17 82:9 51:13 respects 56:1,5,15,20 57:13 58:18 refreshes reorganization 114:2 58:20,21,21 59:15,17 60:2 83:2 44:23 responding 60:14 61:11 63:7 65:8 66:1 regarding repair 46:18 66:10,18 67:5,7 70:25 61:1 64:24 27:16 28:14 responsibilities 72:18,20,21,23,25 73:16 registered rephrase 20:6,20 29:16 34:21,25 78:3 79:12 81:17 82:7 16:16,16,17,20,23 99:13 35:1,15 36:12 39:22 40:11 83:16,18,19,23,24 84:9,11 registration replaced 42:10,14,18,22 44:6,8 45:1 85:8 86:15,22 87:18,19 17:7 52:21 56:12 100:15,16 45:3 51:4 58:2,19 67:12 93:15,19 94:22 95:8,10 regular reply 68:14,22 74:12 97:19 99:9,17 100:10,15,16 101:8,10 10:21 responsibility 100:17 101:24 102:23 relate report 28:16 29:13,22 32:22,24 103:15 104:8,15 105:5 13:9 15:5 62:23 69:8 99:14 36:19 37:4 51:14 53:24 39:1540:1,1344:1045:12 109:19 related 54:23 55:3 74:6 46:11,17,22 50:1551:10 recalled 20:9 22:4 40:18 44:10 reported 55:3 66:25 67:8,20 68:2 66:7 45:16,18 46:18 58:2 62:19 36:18,20 52:12,13 55:14,21 100:14 101:21 108:6 receive 63:8 114:9 58:15 71:14 72:6 102:18 109:25 12:23 16:13 69:24 relates 113:22 responsible received 11:4 44:9 45:14 reporter 23:16 26:18 28:11 33:4 61:7 relating 2:24 9:6 11:1761:17 49:24 59:11 69:3,4 100:8 receiving 12:22 20:20 42:18 45:17 110:24 114:16 116:7 rest 15:21,25 58:19 60:24 65:6 68:14 reporters 42:18 50:2 70:7 receptionist 90:25 91:7 110:23 restricted 111:2 relations reporting 11:8 recess 64:6 36:1 37:3 42:3 49:3 50:23 restrooms 54:1691:16 relationship 51:1 58:6 71:10,25 117:14 93:9 recessed 12:15,18,19,22 reports result 111:15 relationships 68:3 84:24 recognize 35:17 represent resume 61:20 62:9 65:18 relocated 11:2 75:6 24:4,15,16 recollection 37:21 47:21 95:9,15 96:17 represented retainer 25:18 83:2 105:11 relocating 12:2 64:3,12 76:19 13:13,17 47:15 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050267 [retired - sixties] retired rule sealed shelf 13:12 115:14 107:2,8 108:16 retirement run sec shift 12:20 101:18 115:14 101:17,17 return running second shifts 38:9 47:16,25 63:12 106:18__________________ 21:5 82:14 100:19,21,22,24,25 101:1 returned s secondary 101:14 19:19 47:19,21 95:16 returning 20:22 review 13:1962:19 reviewed 13:24 richard 63:17 64:7,8 right 19:3 25:15 27:9 28:5 38:18 44:1 49:15 69:7,11 77:4 83:22 88:5 92:6 100:5,12 104:3 106:23 109:6 110:20 ring 76:19 rings 59:13 river 21:2 road 7:15 69:12 76:6 80:10 87:21 88:12,14 95:5,17,20 roads 94:22 roadways 76:9 robert 36:24 49:8 71:7,9 73:5,11 73:13,14 100:5 role 13:8 30:9 roof 94:8 room 70:11 94:13 97:24 rooms 93:8 rough 63:5 roundabout 57:22 route 87:13 95:8 96:19 routes 94:25 rsmo 115:14 safety 40:16 salaried 85:7,11 sales 35:16 36:8 salespeople 36:8 sampling 38:14 sanborn 89:14,15 20:10 seeing 56:7 62:16 63:7 66:1 99:9 seen 65:25 80:21 98:15 99:5,6 selected 94:13 send 110:4 senior 26:5 sent sand 103:12 sanders 3:14 4:3 9:13,21 11:1 115:21 116:2 117:2 santocel 81:1383:16,18,19 santocels 83:3 santovac 78:25 79:2,3,13 santowax 81:8,9 sauget 18:11 19:3,5 39:7 saw 62:18,21 63:6 95:20 109:23 says 10:21 63:5 82:11 scattered 106:24 scheduled 101:9 scheme 36:17 school 15:14 16:8 science 15:15,18,21 16:5 scientific 4:1 9:21 52:6 score 48:3 scott 5:2,3 10:4,4 seal 114:11 117:19 22:1 separate 32:10 41:18 75:24 76:2,4 76:25 92:23 108:8 September 12:7 58:15 113:15 114:12 117:19 series 23:7 75:10 77:21,22 78:4 79:12 82:25 83:3 103:23 107:18,22 serve 38:16 service 27:16 services 23:21 24:13 29:19 51:18,21 52:4,11 53:13,22 54:2 55:2 57:15,19 58:15 59:1 73:1 74:3,9,13 serving 13:1,6 session 98:7 111:12 set 35:24 51:12 65:14 82:12 113:24 117:18 seven 11:11 100:22 shaped 76:20 shapes 106:1 shaw 9:5 sheet 48:3 shipment 78:2 shipped 45:15 shipping 30:5,17 55:6 70:10 shm 6:8 shop 51:7 shorthand 113:22 shot 88:1 show 97:24 shown 113:20 shutdown 101:8 sic 77:10 side 87:15 96:25 sides 97:1,2 siegal 4:139:16 signature 112:4 114:5 similar 16:14 63:10 99:7 simply 65:17 single 84:14 sir 13:22 25:21 39:6 68:25 86:1 94:17 104:19 sit 98:7 site 59:3 six 48:4,6 sixth 6:13 sixties 16:22 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050268 [size - superintendent] size speak 103:15 105:24 108:20,21 11:16 77:1 80:9 95:3 skip speaking 43:20 104:3 14:3 93:4 sis special 4:20 95:1 small specific 27:5,8,15 108:14 28:13 30:18 32:10 35:23 smith 38:11 39:24 47:23 67:17 4:2 9:20,20 14:22 109:19 soden specifically 36:24 71:7,9 72:1,6 22:16 32:17 62:18 67:5 sodium 73:16 74:5 104:16 91:2 specifications soil 59:10 94:20 specifics sold 48:21 97:18 35:20 45:15 74:22 75:4,10 spell 77:7 79:11 84:2 93:25 42:24 49:9 solely spelling 93:24 94:1 49:12 solid spells 110:10 51:1658:11 solutia spent 1:2 2:5 9:8 10:2 11:4 12:16 14:8 12:19 13:2,7 115:6 split somebody 85:19 50:14 58:1 68:12 102:12 spoke 111:5 14:4 sooner spread 12:1 105:7 sorry square 10:14 12:13 18:1422:18 3:16 115:23 116:4 31:1732:441:8 49:11 squire 61:10 79:1 84:21 86:24 3:149:12 11:1 115:21 99:13 109:2,10 116:2 sort ss 35:9 38:17 97:9 98:5 113:2 soulard ssd.com 21:3 3:20 sound St 113:16 2:21 3:6 12:10,13 15:17 sounds 18:2,10,16,17 19:20 20:2 28:22,22 36:21 37:13,17,25 38:9 source 39:2,11 43:1 46:16 47:15 85:22 47:22 48:15 52:12 59:25 south 64:15 66:25 71:14 73:15 21:4 92:16 95:16 113:3,13 114:12 southeast 116:14 117:16,24 89:21 stacey southern 6:2 9:18 6:1 9:19 92:10 staff sow 36:5 69:5 71:7 stage span 37:22 46:16,24 48:5 stamped streams 65:19 36:14 standalone street 41:18 4:5,147:5 21:5 87:14,14,19 standing 87:19,20,21 90:5,18 117:4 92:7 117:15 start strike 35:11 68:17 74:17 106:7,18 47:19 110:17,23 111:1 structure started 56:3 75:3 94:4,18 100:13 18:17,19 36:22 55:9 structured starter 49:2 106:12,14 structures starters 93:2,7 106:20 107:1 studies starting 15:25 20:9 39:2 52:10 study state 16:11 98:8 2:21 16:1862:2 113:1,5,13 subject 114:17 117:23 65:6 statement subscribed 26:2 115:13 112:12 states subsequent 2:1 39:5,6 113:9 115:2 45:24 52:19 53:17,19 65:6 status 95:21 98:1 16:24 17:3,5 substance staying 14:16 102:4 substation steam 86:3,6 30:7 suburb steel 12:10 5:8 10:6 succession step 56:9 17:24 31:8 43:20 52:2 successor 70:16 38:3 102:21 Stephens sued 4:12 11:3 steps suggestion 61:3 24:14 Stillwater suggestions 16:4 60:9 stop suit 54:7 114:9 stops suite 34:24 2:20 3:5 4:4,15 5:11 6:4,14 storage 7:15 116:13 117:3,15 108:13 summaries stored 62:21 108:11 summarized stores 63:7 106:7 summarizing strange 47:11 91:4 superintendent strategic 23:21 24:13 27:11,13 28:4 68:8,10 28:16 29:3,20,24 30:9 50:12 51:3,17 52:16,25 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050269 [superintendent - train] superintendent (cont.) talked 54:2,2,4 55:1,1,2 57:14 25:16 29:8 41:4 43:13 59:16 66:16 70:1,8,9 74:9 110:12 97:20 102:19 103:19 talking superintendents 54:21 102:5 105:24 49:7,19 50:23 53:18,20,21 tank 54:1,25 66:11,18 69:2 52:8 97:21 100:7 tape superintendent's 54:7,13,1891:13,18 66:7 tar supervised 80:11 22:2 29:9 task supervising 38:11 97:15 23:16 taxed supervisor 116:1,11 117:1 21:14,21,24 22:11 24:9 taylor 25:23 26:17,22,24 27:1,3,4 6:11 9:22,22 110:21 27:10 28:3 29:3 31:1 97:19 team 97:20 100:11 22:2 27:5 28:6 45:5 46:20 supervisors 48:20 49:1 63:8 51:23,24 102:10,16,18,23 technical supplying 22:3 23:21 24:12 29:10,19 30:6 51:18,21 52:4,11 53:13,22 support 54:2 55:1 57:14,18 58:15 52:5 59:1 73:1 74:3,9,13 85:2 supported technicians 30:4 22:3 29:9 sure telecopier 11:16 24:20,22 25:14 40:13 7:9,19 45:21 46:21 50:25 54:24 telephone 57:5 90:11 3:7 5:22 7:8,18 surge tell 106:9,17 61:1966:5 74:18 110:24 suspect tells 77:5 97:25 swan ten 98:12 14:14 57:21 swear tenth 10:17 87:14,14,20 switch tenure 106:5,6,13 108:21,23 50:15 93:14 switches term 27:7 110:11 12:20 77:17 80:19,20 81:1 sworn 81:11,13,17 10:19 112:12 113:18 terms system 31:1340:1644:1845:12 20:11 86:7 87:3 90:19 97:10 systems terphenyls 105:13,16 76:16,16,18,22,23 77:23 t taffy 73:23,24 taken 2:18 37:19 112:3 115:17 talk 35:10 37:7 90:1 98:3 78:7 86:8,9 test 24:3 testified 15:11 113:20 testify 10:19 113:18 testimony time (cont.) 112:5 113:21,24 55:23 61:8,19 62:22,25 testing 67:3,15,20 68:16,17 71:1 51:19 72:3,23 73:10 74:4,15 thank 85:23 88:15 90:25 91:7 57:3 81:19 88:4 94:21 95:2,8,10 98:10 thereto 99:25 101:5 103:23 108:2 114:2 times therminol 48:4,6 101:16 78:9,10,17,19 timing therminols 37:2 78:14 tiny thick 90:2 80:9 title thing 23:18,20,22 29:23 39:16,17 27:7 71:4 92:17 107:8 39:18 40:8,25 59:22 61:14 things 67:11 71:19 28:7 36:17 47:2 107:17 titles think 42:2 16:6 17:12 19:11 34:2 today 35:1241:1643:1349:13 9:6 11:9 12:3 50:18 51:15 57:4 58:10,24 today's 63:22 77:3,4 83:22 87:16 9:2 13:20 14:3,8 111:11 87:22 88:12 93:6 95:7,12 told 99:10 110:14,15 31:1 thinking tom 100:7 106:22 70:2 73:21,22 third tomorrow 5:4 63:12 93:25 11:13 110:16,18 thirty tool 87:22 103:25 6:1 9:19 thomas top 66:12 59:23 60:6 62:23 63:8 thought 71:10,11 14:1321:24 38:1547:11 torn 96:5 88:8 thousand total 13:18 67:11 75:6 116:9,17 117:8 three totally 31:14,21 32:4 48:4,4,5,13 37:25 98:11 76:22 100:20,22,24,25 tower 101:1 3:15 115:22 116:3 threw town 96:17 12:9 87:15 throdahl trace 67:14 15:13 time track 9:10 11:9 13:11 14:7,10 88:18 15:5 16:2,3,25 17:14 19:10 trade 19:16 20:5,18 22:20 23:14 74:23 78:10,19,21 79:7,16 23:23 24:9 25:15,18 26:4,9 79:23 84:8 86:22,25 27:21 29:2 31:14,16 33:11 trademark 35:3 37:15 38:21 39:1,4,24 79:16 42:5,7 43:11 45:8,19 46:14 train 46:16,23 47:16,20,24 48:5 21:23 48:11 49:2 51:2 54:7 55:17 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050270 [training - wells] training 15:1035:7,9,11,1397:10 transcribed 113:22 transcript 112:2,5 113:21 114:3 115:20 transcripts 117:10 transfer 78:11 110:8 transferred 45:7 transformers 27:23 79:25 104:9,17,21 105:2,6 107:21 108:3,7,11 108:13 110:11 transition 37:22 travel 14:10,25 traveling 14:24 traverse 76:7 trial 113:11 tried 87:23 trip 98:1 trips 98:1 trouble 48:18 troutman 4:3 9:20 117:2 troutmansanders.com 4:9 trucks 76:7 95:1 true 45:10 93:3,6 100:1 101:5 112:4 114:2 truth 10:20,20,20 113:18,19,19 try 15:10 49:4 56:8 70:3,13 74:17 87:21 trying 24:3,4 37:24 46:21 47:7 50:17 54:3 68:20 71:12 100:12 107:4 tubing 105:12,16,22 106:24 tucker united (cont.) visit 66:12 70:2,3 115:2 95:20 turn units visits 65:3 69:5 22:4,14 30:4,8 92:25 95:21 turned university vitae 98:5 15:16,19 16:8 13:24 25:10 turner unpaved volume 58:22 94:23 1:14 115:16 turning unrelated vs 37:23 32:11 1:4 2:8 9:8 115:8 twelve 107:20 unsatisfactory 70:13 w twenty 11:24 upper 42:1 9611 type usable 17:6 26:5 33:2 40:19 94:4 80:8 1110 99:7 105:19,21 107:1 108:4 usage 110:4 40:16 types use 20:7,17 32:14 67:25 74:2 42:1 75:15 80:16 93:19 1145 walk 21:8 35:10 39:9,9 typewriting 113:23 95:2 103:12 104:8 105:21 106:13 107:14,19 108:11 9411 typically 107:22 110:7,10 user 71 107 u u.s. 7:1 10:8 uh 38:24 55:5 110:1 usually 76:5 utilities 29:25 30:7 12:12 24:18 37:8 54:24 57:5 71:4 74:17 90:18 110:17 warehouse 30:17 ultimately V warehousing 90:18 vacuum 29:24 30:4 55:6 um 79:6 warner 47:18 valley 5:20 undated 5:8 10:5 12:13 Washington 65:17 valves 5:21 6:5 15:16,19 16:6,7 understand 98:5 waste 11:18,20,21 22:24 53:9,12 vehicles 36:14 55:6 96:1,23 76:7 watch understanding verbal 88:2 35:2,5 46:22 68:20 97:16 61:7 water 99:19 version 20:11 108:20 understood 63:9 waving 85:16 98:2 100:8 versus 54:6 undetermined 85:7 wax 113:9 vice 81:10 union 67:7,9,15,19 71:10,19,23 wearing 51:7,10,11 69:16,23,24 video 38:2 70:4,7,13,22 71:1 11:24 Wednesday unique videograper 11:12 32:9 111:11 week unit videographer 100:22 21:14,15,1622:2,1031:19 9:1,5 10:16 11:1854:13,17 weevil 44:23 49:25 76:9 92:5,6,7,8 82:15,21 91:13,17 111:8 50:1 76:14 92:9 94:3 videotaped wells united 1:142:18 115:16 20:12 2:1 6:10 9:23 39:5,6 113:9 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050271 [wendlene - years] wendlene worked 3:13 69:21 72:25 73:16 84:11 wendy 100:11 9:12 10:25 workers went 28:18 44:17 46:4 70:23,24 17:17 19:2,11,1329:15 working 30:23 34:6 39:1 48:15 17:1721:1222:3 29:10 74:23 91:23 95:4,18,20 46:23 97:8 98:6 world west 35:22 42:18 7:5 92:16 worldwide westinghouse 38:20 104:23 wright westvaco 58:12,13,14 74:11 3:12 9:14 11:2 writing we've 60:20 82:7 90:2,15 25:8 written wheeler 13:19,21 56:2,6 61:5,6 63:1764:11,12 77:18 89:15 whereof wrong 117:18 28:22 75:17 99:23________ whew 22:21 32:13 48:4 104:23 width 54:12 william 1:142:189:7 10:1854:14 54:19 64:8 73:23,24 91:14 91:19 111:12 112:1,10 115:16 wire 106:2 wiring 27:7 Wisconsin y yeah 52:21 54:7 57:4 60:21 70:24 71:15 90:3 92:19 97:1 100:4,22 104:3 111:1 111:4,4 year 16:21 18:5 19:9 26:23 34:3 34:11 43:5,5 48:7 52:24 67:18 74:21 89:15 95:2 years 19:12 20:14,15 48:14 55:20 55:20 87:22 6:4 wit 10:22 witness 10:17 47:6,11 61:24 82:1 83:8 84:21,23 88:10,21 89:17,23 90:22 98:21 99:1 112:1 113:14,16,25 114:4 114:11 117:18 wlavey 3:20 word 15:23 22:21 39:19 48:18 75:15 80:21 90:16,25 91:10 100:12 106:14 words 28:15 35:25 49:2 77:10 work 15:20 16:10 27:22,25 38:15 69:16 103:2,6 Papageorge, William; McWane (Former Monsanto Employee) WATER PCB-SD0000050272