Document J3oQZxX1rD9NKyDD1bndx42XB
1
1; IN THE UNITED STATES DISTRICT COURT ; FOR THE EASTERN DISTRICT 0 F PENNSYLVANIA
2|
3;
4
5 I n re:
MDL DOCKET N 0 . 764
6; TEXAS EASTERN TRANSMISSION CORPORATION PCB
7 CONTAMINATION INSURANCE COVERAGE LITIGATION .
8
9 ------
Deposition of:
ROGER E. HATTON, Ph . D .
Volume I
10 11 12 13 14 15 TRANSCRIPT of testimony as taken by 16 and before TOMMY LARUE MILLER, a Certified 17 Shorthand Reporter and Notary Public, at the 18 offices of HUSCH, EPPENBERGER, DONOHUE 19 CORNFELD & JENKINS, 100 North Broadway , Suite 20 1300, St. Louis, Missouri, on Wednesday, 21 January 24, 1990, commencing at 10:10 in the 22 forenoon. 23 24 25
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PEARANCES:
2 COVINGTON & BURLING 1201 Pennsylvania Avenue, N . W .
3 Washington, D. C. 20044 BY: LAIRD HART, ESQ.
4 For the Plaintiff
5 SMITH, HELMS MULL I S S & MOORE 500 NCNB Building
6 P.O. Box 21927 Greensboro , North Carolina 2 7 4 2 0
7 BY : GERARD H . DAVIDSON, JR., ESQ. For Monsanto andthe witness ,
8 Roger E. Hatton
9 HASKELL & PERRIN 200 West Adams Street
1 0 Suite 2600 Chicago, Illinois 60606
1 1 BY: DAVID W . PIERDINOCK, ESQ. For Continental Casualty Insurance
1 2 Company
1 3 PRETZEL & STOUFFER, Chartered One South Wacker Drive
1 4 Suite 2500 Chicago, Illinois 60606-4673
1 5 BY : MICHAEL R . GREGG, ESQ. For Prudential Reinsurance Company
16 SHEFT & SWEENEY
1 7 11 Broadway New York, New York 10004
1 8 BY : MARY C . BENNETT, ESQ. For American Home Assurance Company ,
1 9 Highlands Insurance Group, Insurance Company of the State of Pennsylvania,
2 0 Lexington Insurance Company , Ranger Insurance Company , Republic Insurance
2 1 Company, Stonewall Underwriters, Inc.
22
23
24
25
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1 ! A P P EAR A N C E S : (Continued)
2 : RIVKIN, RADLER, DUNNE & B A Y H E A B Plaza
3 Unio ndale, New York 11556-0111 BY : DONALD V. PUPKE, JR., ESQ
4 For Associated Electric Sc Gas I n s u ranee Servi ces. Ltd. and
5 N a t i o n a 1 Surety Corporation
6 CARR , G00DS0N & LEE, P.C. 19 19 Pennsylvan i a Avenue
7 Suit e 7 0 0 Wash i n g t o n , D . C . 2 0 0 0 6
8 BY : GREGORY A. KRAUSS, ESQ. MICHAEL P. HOOKS, ESQ.
9 For Fidelity & Casualty In s u r a Comp any
11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
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1 ' INDEX
2 ; WITNESS
DIRECT
3 ROGER E. HATTON
4 Mr. Krauss
12
5
6
7 i EXHIBITS
8 NUMBER
DESCRIPTION
IDENTIFICATION
9 Hatton-1 I0 II 12
Letter to
W.M.
Stephens from D.F.
Smith, dated
August 2 2 , 1 9 6 8
two pages. Bates
Nos. 000907285
through 000907286
70
13 Hatton-2 14 15
Documents entitled, "Facts About FireResistant L u b r i cants". Bates Nos . TEX 000330 through 0 0 0 3 3 7
75
1 6 Hatton- 3
17
18
19 Hatton- 4
20
21
22
PROTECTED E x h i b it
80
Letter to R . E . Moore
from W.M. S t e p h ens, dated
June 2 8 , 1 9 6 8 , Bates Nos.
010037983 throu g h
010037986
Memo t o T . L . Go s s a g e from C . L . B r a d f o r d , dated Dec ember 1 5 , 19 7 1, Re: Sant o v a c 1 and 2/Turbino 1 15 3, Bates Nos. TEX 000797 through 0 0 0 8 0 0
85
24 25
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1 EXHIBIT
2 ! (Continued)
3 NUMBER
DE S CR I P T I0 N
IDENTIFICATION
4 Hatton-5/6 5 6;
Call Re by R.E. Februar Bates N through
ort No. 1972-11 Hatton, dated
1 1 , 19 7 2 s. TEX 000879 000883
97
7 (THIS Exhibit WAS INITIALLY MARKED A S HATTON-5 , THEN WITHDRAWN AND
8 REMARKED A S E xhibit HATTON-6)
9 Hatton-5 10 11
Call Report No. 1 9 7 2 - 1 by R.E. Hatton, dated February 8 , 1 9 7 2 , Bates Nos. TEX 000315 through 000317
99
12.Hatton-6 13 14
Call Report No. 1 9 7 2 - 1 1 by R.E. Hatton, dated February 1 1 , 19 7 2 Bates Nos. TEX 000879 through 000883
1 10
15 Hatton-7
16
17
18
19 Hatton-8
20
21
22
PROTECTED Exhibit
1 15
Memo to Files, Subject :
File 3.20 - Monsanto
Turbine Lubricant
MCS 1 2 2 3 by A . B . Jarnagin,
dated February 4, 1972
Bates Nos. 000531567
through 000531568
Call Report-Organic
118
Division to C.L. Bradford
from John G . Frederiksen
date of call February 4,
1972, Bates Nos. TEX 000876
through 000878
23
24
25
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EXHIBITS
2 i (Continued)
3 NUMBER
DESCRIPTION
IDENTIFICATION
Hatton-9
6 7/ .
Hatton-10 8
9i
10 Hatton-11
11
12
13
14 Hatton-12
15
I6
17
18
19 Hatton-13
20
21
22
Call Report-Organic
124
Division to Cumming Paton
from John G. Frederiksen
date of call July 24,
19 7 2 , Bates Nos . TEX 000897
thro ugh 000898
Call Report No. 1 9 7 2 - 2 3 by R . E . Hatton , dated July 2 4 , 1 9 7 2 , Bates Nos. TEX 000866 thro ugh 000869
1 29
PROTECTED Exhibit Document entitled "Membership List Study Group on Fire-Resistant Turbine Fluids , Tech C, ASTM D- 2, undated. Bates No. 000907826
1 48
PROTECTED Exhibit Minutes of Meeting Fire-Resistant Turbine Fluids Study Group, Technical Committee C , ASTM Committee D- 2 dated June 25, 1963, Bates Nos. 0009078915 through 000907825
151
PROTECTED Exhibit Typewritten memo to "Earl" , dated January 2 3 , 1 9 8 1 , Bates No. 010037863
1 60
23
24
25
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1 2 3iNUMBER 4 Hatton- 1 4 5 6
1 7 Hatton- 1 5 8 9 1 0 Hatton- 1 6 11 12'
7
EXHIBITS
(Continued)
DESCRIPTION
IDENTIFICATION
PROTECTED Exhibit
1 63
Letter to Dr. Roger E.
Hatton from C1if Williams r dated December 1, 1975,
Bates No. 000844865
PROTECTED Exhibit Letter to C 1 if Williams from R.E. Hatton, dated December 8, 1975, Bates No. 000844861
163
Memo to T.L. Gossage from C.L. Bradford/N.T. Johnson, dated November 17, 1971, Bates Nos. TEX 000303 through 000306
16 6
14 15 16 17 18 19 20 21 22 23 24 25
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1:
MR.
KRAUSS: Good morning,
2;Mr. Hatton. I'm Gregg Krauss, representing
3 Fidelity and Casualty of New York, and Boston
4 Old Colony Insurance Company in litigation
5 against Texas Eastern Transmission Company .
6 I do appreciate your taking your
7 time today to come talk to us.
8 At this time I'd like to go
9 around the table and have everybody identify
10 themselves for the record.
1 1 MR. HOOKS : Dr. Hatton , my name
12 is Michael Hooks. I represent the same
13 companies that Gregg represents .
14
MR. PIERDINOCK :
Goodmorning,
15 my name is David Pierdinock, and I come from
16 the law firm of Haskell & Perrin, and we
17 represent Continental Casualty.
18 MR. GREGG : Doctor, my name is
19 Michael Gregg, and we representPrudential
2 0 Reinsurance Company .
2 1 MR. PUPKE: My name is Don Pupke
2 2 andI ' m
with the firm of Rivkin, R a d 1 e r,
2 3 Dunne & B a y h and we represent AEGIS and
2 4 National Surety .
2 5 MS. BENNETT : My name is Mary
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Bennett . I'm with the law firm of S h e f t and
Sweeney . We represent several exc ess
carriers .
MR. HART: I'm Laird Hart. I
represent Texas Easter n Transmissi o n
6 Corporation.
7 MR. DAVIDSON : My name is Gerard
8 Davidson . I'm with the firm of Smith , Helms ,
9 M u 1 1 i s s and Moore in Greensboro, North
10 Carolina . I represent Monsanto and Dr.
.
1 1 Hatton .
1 2 I ' d like to just put so meth i n g
1 3 on the record a t this point so that we're all
14 clear that the genesis of this deposition was
15 a Rule 30(b)(6) notice served on Monsanto
1 6 back last fall, with some des ignated areas of
1 7 inquiry, served by the insurance carrier
1 8 parties .
1 9 D r . Hatton is a retired Monsanto
2 0 employee, and i s being designated by Monsanto
2 1 t o testify as t o certain of those subject
2 2 matter areas .
2 3 I n particular, my unders tanding
24 is that attorneys for the insurance carriers ,
2 5 or Mr. Hooks , has indicated that specifically
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!
10
l|as the relationship between Monsanto and
I
2|Texas Eastern for the development and use of
3; PCS lubricating oil for use in natural gas
4 compressors, and the relationship between
5 Monsantoand Texas E a s tern on or about the
6; time Monsanto announced it would no longer
7: sell PCS lubricating oil for use in natural
8 gas compressors, that those are the general
9 areas of inquiry today .
10
Counsel for the insurance
.
11: companies were informed that more than one
12: witness would be necessary to cover all of
13 the areas originally des ignated in the
1 4 3 0 (b) (6) notice, and that Dr. Hatton was not
15 the proper person to cover all those subject
16 matters originally noticed. '
.
17 And we were told that at this
1 8 point, that is today, Counsel wanted to go
19 forward with the deposition of Dr. Hatton and
2 0 then make further decisions a s to whether
21 other witnesses should be designated, or
2 2 served and noticed .
2 3 A subpoena was served - - w
2 4 I'm sorry. was forwarded to in-house Mon
2 5 Counsel, I t h i ok day before yesterday , . a
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1!was handed to Dr. Hatton yesterday. He has
2 \that subpoena. It asked for him to bring to
3 ; this deposition his personal files a s it
4 relates to the subject matter of the
5 deposition .
6 Without waiving any objections
7' to the lateness of that subpoena service, or
8 t h e correctness of the subpoena service, let
9; me say for the record that Dr. Hatton has
10 indicated that he has no personal files
.
11, pertaining to the subject matter of this
12!deposition; the turbine lubricant fuels,
1 3 fluids , or any such a s that, other than
14 several product brochures prepared for that
15 type of product, that are the same a s the
1 6 product brochures that have already been
17 produced to the parties by Monsanto. There
1 8 are no documents that he has in his
19 possession personally that you do not already
20 have.
2 1 And that's all I have.
2 2 MR. KRAUSS: Okay. And that
2 3 comports with our understanding, a s well.
2 4 MR. DAVIDSON : Okay.
2 5 R 0 G ER
E . H A T T 0 N, Ph.D.,
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R. E. Hatton
l
12
1! 406 Claybrook Lane, Kirkwood, Missouri
2 63122, having been duly sworn by the
3 ! Notary , testifies a s follows :
4 DIRECT .EXAMINATION BY MR. KRAUSS:
5 1 Q Dr ,, Hatton, w o u 1 d you
6! give us a brief backgrou n d o f your
7: after high school?
8 A.
Okay. I have a Bachelor of Arts
9 degree from Univers ity of Omaha in 1940. A
10 Master of Science degree, actually from
.
11 Perdue University, in organic chemistry . And
12a Ph.D. from Perdue University in 1 9 4 4 , `also
13 in organic chemistry .
14 Q. Have you had any special
1 5 training .or education relating specifically
16 to polychlorinated biphenyls?
17 A.
The informationthat
I gained was
18 on-the-job training type of thing. The PCBs
19 were a tMonsanto when
I got there, and were
2 0 one of the many products that I worked with
21 while I was there .
2 2 Q . Okay. Have you had any special
2 3 training or education with respect to turbo
2 4 machinery , such a s turbines or centrifugal
2 5 compressors?
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1;A.
I've had no formal education. Again,
2; since we were interested in the field, and I
3 had numerous contacts with the producers of
4 such equipment, I -- -
5 Q . Could you tell me --
6 A.
-- learned, myself, what was required ,
7 a n d listened to other people talk about it.
8 But no educational -- no formal
9 courses in the subject .
1 0 Q . What producers of such equipment
1 1 have you been in contact with?
12 A.
General Electric ; Westinghouse, to
1 3 some extent; Solar.
1 4 Somehow it seems like there were
1 5 other smaller ones, but those are the major
16 ones that I remember a t the moment .
1 7 Q . Do you recall being in contact,
1 8 or speaking to anybody from Clark Brothers ,
19 manufacturers of centrifugal compressors? .
20 A .
Compressors, yes.
2 1 Now, on the compressor side it
2 2 was Clark, and Cooper Bessemer. And there
2 3 was a third one. And I -- that I dealt with
2 4 directly, and I cannot remember that name.
25 Q. W. ould it be DeLaval?
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Hatton
14
A . Sound s right , yes.
2: Q Do you recall
a t the centr i f u g a 1 compress
i t was that you cam e in con
i t '1 s been a number of years
A . I do not.
7 i Q . Okay. Have you ever been
8 deposed before?
9 A.
Oh, yes.
10: Q . How many times?
.
Ilk.
I don't know that I can give you a n
12, exact number . It's somewhere in the range of
13 ten to 15.
14 Q . Would you please give a
1 5 background of your employment after you
1 6 received your Ph.D from Perdue in 1 9 4 4.
1 7 A.
Yes.
1 9 4 4 through '4 6 I stayed a t
18 Perdue University and worked on theManhattan
19 project, on a program they had on campus .
2 0 In 1 9 4 6 I joined Monsanto a s a
21 research chemist and worked for Monsanto then
2 2 until 1 9 8 2 when I retired .
2 3 Since retirement I have been
2 4 doing a minor amount of consulting work.
2 5 . And what is the subject matter
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R. E. Hatton
15
1 1 o f the cons u 1 t i n g work?
2i A 3;
F u n c t i o n a 1 fluids Q What was y o u r first p o s i t i o n
4 w i t h M o n s a n to -- I'm so r r y , you said
5 r e s e a r c h c h emist?
6 A 7:
R e s e arch c h e m i s t , Y e s . Q Did your p o sit ion c h a n g e at all
8 with in Mons anto?
9 A
Yes, c o n s i d e r a b 1 y
10
Q
What was y o u r next posit ion
-
1 1 a f t e r you w ere a r e s e a r c h c h e m i s t ?
1 2` A
G r o u p lead e r in the r e s e a r c h
1 3 department .
1 4 Q And what we r e your
1 5 r e s p o n sibil i t i e s a s a g r o u p lead e r in the
1 6 research department?
17 A
B a s i c a 1 1 y the sup e r v i s i o n and
1 8 a d m i n i s t r a t ion of a g r o u p o f res e a r c h
1 9 c h e m i s t s , d o i n g v a r i o u s pro j e c t s with in the
2 0 o r g a n i c c h e m i c a 1 s depart men t .
2 1 Q Were those pro j e c t s a t that tim
2 2 d e a 1 i n g with synthetic f 1 u i d s , f u n c t i o n a 1 23 f1uids7
24 A
Yes.
Also some w i t h
-- -- in so m e
2 5 closely related areas .
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R . E Hatton
16
1 Q. Did you have any positions after
2 you were a group leader?
3 A.
Yes. In 1960 I transferred from the
4 research department to the -- it. was called
5 the development department, w i t h in Monsanto .
6 Development meant within the company, the
7 development of new products outside the
8 laboratory, mainly with customers.
9 We learned a customer's
1 0 requirements , w e did market research. we t o o.k
1 1 new products out t o the field and saw that
1 2 they were properly applied, or a t least tried
1 3 to. And then we saw that the products were
1 4 prop e r1y handled and introduced until the
1 5 time that they were transferred to marketing .
1 6 Q . And did you have that -- were
1 7 you in that position for the rest of your
1 8 career, or did you --
19 A.
No.
2 0 Q. -- did you have other titles
2 1 other than that?
22 A .
In 1968 I trans ferred to the marketing
2 3 department . The company wished to make the
2 4 marketing department s tronger technically,
2 5 and there were a number of us who ended up
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' R . E . Hatton
i
1 i working under
marketing,
even
though
we
2 j continued to do the development project --
3; development work I just talked about, a s well
4 as supporting those commercial products which
5 were already out in the field .
6. If somebody had trouble with a
7 product, we acted in what would be called in
8 some companies a s technical service
9 representatives , that type of activity .
1 0 So it w a s varied, but that
11 c o vers p r e tty much w h a t I did from then on
1 2 , u n til the time t h a t I retired in 1982.
1 3 I had m a n y titles during that
1 4 t i m e , tech n i c a 1 s e r v i c e manager, product
1 5 s u p e r v i s o r and so o n . They are not really
1 6 t h at i m p o r t a n t bee a u s e the function never
1 7 changed .
-
1 8 Q Okay. How was your position
19 1968 when you were in the marketing
2 0 department, how did that differ than the
2 1 position that you had in the research
2 2 department from 1 9 6 0 to 1 9 6 8 ?
2 3 A.
Well, I was in the development
24 department from 1960 to '68, which
was -
2 5 within the organization of Monsanto was a
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R. E. Hatton
18
1 separate department from research .
2 We had research, we had
3 development, we had marketing. So those were
4 three steps within -- major divisions within
5 the company.
6 Within research you worked in
7 the laboratory with the products and got your
8 hands dirty .
9 In the development department
1 0 you got your hands dirty with the customers ,
1 1 rather than the laboratory.
1 2 Q . Okay. And then how was the
1 3 development department different than the
1 4 marketing department?
1 5 A.
Well, the development department never
1 6 took orders. The marketing department did.
1 7 Q. But your day-to-day contact with
1 8 the customer was similar between the two?
1 9 A.
It was similar, but the emphasis was
2 0 on products which had already been introduced
2 1 a s commercial products .
2 2 Q. I see. Throughout your course
2 3 of employment a t Monsanto, were you ever on
2 4 any committees relating to lubricants?
2 5 MR. DAVIDSON: You mean
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R. E
Hatton
19
1:committees within Monsanto or with any?
2 : MR. KRAUSS: Within or without
3 . of Mon santo
4 5 A.
Q Within the industry. The answer is yes. I worked
6 p a r t i c u1 a r1y with ASTM.
7 8 A.
Q . And what does ASTM stand for? A m e r i c a n Society of Standards and
9 M a t e r i a 1 s , I think -- of Testing and
1 0 M a t e r i a 1 s , yes, rather than Standards.
11 12; A.
Q . Okay. A m e r i c a n Society of Testing and
13 Materia1s .
14 15 A.
Q - What was -- You tend t o refer to these things by
1 6 a c r o n y m n s . You don't very often have to
1 7 recite the full name of technical societies
18 Q. And what year were you
19 associated with that committee?
20 A.
I could not remember the exact dates ,
21 but it was a t least ten or 15 years ; some
2 2 during research, some during development , and
2 3 some during marketing . I t stretched most of
24 my career .
2 5 I also was a member of A.S.L.E.,
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R. E. Hatton
i : which is the American Society of Lubrication
2 ! Engineers .
:
3: Q
That ' s a tech W e r e you o n
4 associated with that tech
5: A,
They had groups that were involved in
6 hydraulic fluids and power generation ,
7 synthetic lubricants and aviation fluids .
I
8 was a member of all those panels a t one time
9 o r another .
I 0 Q. Did the ASTM committee which y o-u
II were a member of have a specific name?
12 A.
Yes. I t was called Technical
13 Committee N of Committe D- 2 .
14 The subject of the committee was
1 5 hydraulic fluids was
-- or the title .
1 6 Q . Did that committee have any
1 7 special goals that theywere working on, any
18 special projects?
19 A .
That ' s a -- we ' r e C O V e r i ng a
2 0 t r e m e n dous area of gro u n d o f w h a t sue
2 1 Tech n i cal Committee wo u 1 d C O V e r .
2 2 Q . Well, do you recall the
2 3 why th e committee was form e.d ?
2 4 MR. HART: D o e s h e h a v e
2 5 understanding about why it was formed?
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R . E . Hatton
21
1 ! object to the form as stated .
2!A.
The purpose of ASTM was to develop
3 test methods for all kinds, of products, and I
4.mean all kinds. So that people could run a
5 1 given test and get a n answer which they could
6 then feel quite sure that the next person
7 that ran that test would get the same answer,
8 or a t least within the precision of the test
9 method. That was the basic reason for the
10 formation of ASTM, and it must be a hundred .
11 years or more old.
12, Technical Committee N was set up
13 to do this kind of work on hydraulic fluids,
14 both petroleum based and synthetic .
1 5 Q Was the c 0 m m i t t e e 1' s work geared 1 6 toward any specific end use 0 f the product,
1 7 0 r was i t more generali zed?
18 'A.
The committee a s set u p had specific
19 groups working, I believe it was in four
2 0 areas ; industrial fluids , aviation aerospace
21 fluids , marine fluids and, I believe the
2 2 fourth one was automotive fluids , 1 i m i t e
2 3 course. t 0 the hydraul ic fluids use.
2 4 Q . Was that com m i t t e e further 2 5 broken down into anything called a study
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R. E. j
1 group,
Hatton if you recall 7
22
2! A.
Well, we had a series of
3 s u b c o m mittees. The p r operties of the
4 h y d r a u lie fluid are s i gnificantly broad that
5 you wo u1d study one p r operty a t a time, you
6 would develop a test f or one property at a
7 time.
And therefore r specific groups were
8 set up by properties
9 Q . And w e r e you a member of any of
1 0 these subcommittees?
11: A .
All of them.
12 13 A.
Q.
Yes .
All of t h e m . In the e a rly days the committee
14 was quite small .
1 5 Q Do you r e call being a member of
16 a study group on fair resistant turbine
17 fluids?
18 A.
Yes, I w as a m e mber of that group,
1 9 And that, I b e 1 i e v e , w a s under Technical
2 0 Comm i t t e e C ins t e a d o f N .
2 1 Q . W h at a r e those designations; 2 2 Tech n i c a 1 Co m m i 11 e e N , Technical Committee C,
2 3 what do they s t and for , if anything?
24 A .
They are s i m ply a way of dividing up
2 5 the field of P e t r o 1 e u m products, which is the
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1; title of committee D - 2 , into handleable
2; sections.
3 We all know that petroleum is so
4: broadly used there is no way you can handle
5 it unless you start fragmenting it into
6 parts. And the D-2 broke things down into two
7 general ways of looking a t it: One, which
8 was by application, and those were the letter
9 numbers, such a s A, B, C , on up the line.
10
They then broke it down by
.
11: properties which crossed over between
12' applications. And you might have a n
1 3 oxidation committee of viscosity study area,
14 and they, back when we started, were
15 generally given numbers .
16 Since then the designations have
17 all been changed . But that ' s what they were
18 a t the time we're concerned about.
19 Q . Okay. And the subject of
2 0 Subcommittee N , I think youstated
was
21 hydraulic fluids?
22 A .
Yes.
2 3 Q . And I don't recall what you said
2 4 the subject of Committee C was.
25 A .
Technical Commit t, e e C had to do with
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1 I t u r b i n e 1 u b r i c ants. It's a b road fie 1 d .
2 P r i m a r i 1 y t h o s e were petroleu m based a t that 3 , t i m e that w e ' r e cone erned a b o u t .
4 Q W as the study g r o u p that I
5 r e f e r red to e a r 1 i e r , then, a subgroup o f
6 T e c h n i c a 1 Comm i 11 e e C ?
7 A.
I c a n n o t answer the ex act d e s i g n a t i o n
8 o f t h a t s t u d y group. whether it was a
9 s u bgr o u p or a study group, or what t h e
1 o: d e fin i t i o n was . I t functione d as a s t u d y
1 1 : group 12! Q
B u t it was some subset o f
1 3 Subcommittee C .
14 A.
Yes.
15 Q . Okay .
16 A .
Yes.
17 Q. Any other committees besides the
1 8 ASTM and the A . S . L. E . ones that you referred
19 to?
20 A.
Well, may I ask a question here?
2 1 Q . Sure.
22 A .
You're referring to my memberships ,
2 3 solely, or to my places where I was active?
2 4 Q . We'll stick to places where you
2 5 were active to narrow the field.
.
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1 A.
I s e r v e d w ith the Navy 0 n an advisory
- 2 | g r 0 u p 0 n flu ids a n d lubricants f or a number
3 0 f yea r s .
4 Q . Do y 0 u recall what years?
5 A.
Not w i t h 0 u t checking r e c 0 r d s .
6 7 A.
Q . Okay W e d e alt p rimarily with a d v i sin g the
8 t r i P a r tide g roup. so-called, whi c h were the
9 n a v i e s 0 f t h e U . S . , Canada, and England on
1 0 : f 1 u i d s and 1 ubric ants they used. Trying to
1 1 f i g u r e out w ays t 0 make one f 1 ui d work in
1 2 e v e r y b ody ' s Navy was the goal.
1 3 Q Was this during the course of
1 4 y 0 u r e m p 1 0 y m e n t a t Monsanto --
15 A.
Yes
1 6 Q -- that y ou were 0 n this?
17 A.
Mon s a n 10 sponsored me 0 n that.
1 8 Q . What exactly is a f ire-resistan
1 9 1 u b r i c ant? What' s meant by that term?
2 0 MR . HART: A s the w itness uses
21 it?
2 2 M R . DAVIDSON : As the witness
23 us ed i t .
24 A .
Wei 1 , i t -- the product must meet a t
2 5 1 e a s t two c r i t e r i 0 n . One is that it must be
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1 fire-resistant, and by fire-resistant we
2 meant that it would be difficult to burn and
3 to ignite .
4 Secondly, it must be a
5 lubricant, and we would define being a
6 lubricant in terms of the requirements of the
7 application.
8 The term lubricant is so broad
9 that you could not just say the product is a
1 0 lubricant . 11 is a lubricant for gears , it'.s
1 1 a lubricant for bearings, it's a lubricant
1 2 for whatever, down the line.
1 3 Q. Did Monsanto manufacture
1 4 fire-resistant lubricants?
1 5 MR. DAVIDSON : A t what time
1 6 period are you talking about?
1 7 MR. KRAUSS: During thecourse
1 8 of Dr. Hatton ' s employment .
i i
i--J
o
c
19 A.
Yes, T u r b i
T u r b i n o 1 series were
2 0 1 u b r i c a n t s . Some of the other p r oducts that
2 1 we made had 1 u b r i eating f u n c t i o n s
22
Q. '
Were you - -
23 A .
That was a r e q u i r e m e n t .
2 4 Q Were you in v o 1 v e d i n working 2 5 with f i r e - r e s i s t a n t 1 u b r i c a n t s w h e n you first
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1; joined Monsanto?
2| A.
No.
3; Q . In what position a t Monsanto did
4:you first become involved in any capacity
5 with fire-resistant lubricants?
6k.
I was assigned to a group leader in
71948 who covered the area of phosphate ester,
8 and fluids, and plasticizers, and several
91 related products . And it was his decision a t
10 that time that I get involved with the fluid, s
11: program a t Monsanto, and that ' s how I became
12 involved.
13 Q. Do you recall what the first
1 4 fire - r e s i s t ant lubricant was t h a t y o u were
1 5 invo 1Ved wi th?
16 A.
I ' m a little bothered by the term
1 7 Tubr i c ant i n that any of the flu ids . that we
1 8 made h a d a degree of lubricating a b i 1 i t y .
1 9 Q Would it be better to s a y 2 0 some t h i n g m ore generic like func t i o n a 1 21 f1uids?
22 A .
Yes.
2 3 Q Okay.
24 A .
The reason being that you can not eve
2 5 run a hydra u 1 i c pump unless the f 1 u i d i s a
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1 i lubricant, to a c e r t a i n extent .
And
28
2 ; therefore, it w o u 1 d not make much of
3 ' hydraulic flu id w i t h o u t being able to
4 lubricate the s y s tern.
So - - a more
5 term, I think , i s what we're looking
6 Q Okay . And what was the
7 product , then , t h a t you were involved
8 A.
A product which eventually became
9 trade named Skydrol.
10 Q. And what year was that?
11 A.
1948. S - k
1 2 You c a n see how w
1 3 me at Monsanto .
14 Q. Do you recall what the
15 composition of Skydrol was?
16 A.
Oh, absolutely . Skydrol was all
17 phosphate ester fluid. I t was developed
1 8 primarily for use in aircraft, and came about
19 through efforts of Monsanto Company and
2 0 Douglas Aircraft to solve a fire problem
2 1 aboard commercial aircraft .
2 2 The product is still sold today ,
2 3 in different forms, with improvements to the
24 product over the years .
2 5 And I was involved in some way
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1 wi th i
2:
Skydro1 Q.
f r o m 19 4 8 until 0 k a y . And what
I wa
3 pr o d u c t , then. that you were i n
29
4 A.
T h e next product that w e
5 d e v e lop. or to produce , r e s e a r c
6 ' f i r e - r e s i s t a n t hydrauli c fluids
7 th e r e f o r e the r e s u1t of my e f f o
8 area resulted in Pydraul F 9 .
9 Q. Has this when you were still in
10 the research department?
.
11 A.
Oh, yes. This was early 1950
-- or
1 2` I'm not sure whether it was ' 5 0 or '51, but
13 in that time period .
14 Q. And you said the product was
15 Pydraul F 9 ?
16 A.
Yes.
17
- Q.
Do you recall what the
18 composition of Pydraul F 9 was?
19 A .
11 came out of my laboratory a s
2 0 formulationnumber 9 ,
and my research
21 notebook, and it was a 5 0 percent of a n
2 2 Aroclorin, and5 0 percent of a tricresyl
23 phosphate.
-
24 Q. What do you mean by the term
2 5 Aroclor?
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11 A. !
Aroclor was our tradename a t that time
2! for polychlorinated biphenyls.
3 Q. And what's a tricresyl --
4 A.
Tricresyl phosphate - -
5 Q. -- phosphate .
6 : A.
-- is a synthetic material made from
7 ; cresylic acid and phosphorus intermediates ,
8 which was readi iy a v a i 1 a b 1 e a t that time. 9 Q . I s t h a t the same a s a phosphate
1 0 ester?
11 A.
11 is a phosphate ester .
1 2 : Q . Okay.
13 A.
One of many.Phosphate ester
is a
1 4 generic term. Tricresyl phosphate is a
1 5 member of that class .
1 6 Q. Okay. I s that phosphate ester
1 7 the same a s the phosphate ester used in
1 8 Skydrol?
1 9 A.
No way.
2 0 Q. How do they differ?
21 A.
I don't want to give a chemistry
2 2 lesson, but --
2 3 MR. HART: You must get tired of
2 4 that.
25 A .
-- we generally look a t things by
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1|drawing pictures of them. And the easiest
2 ! way to t a 1 k about this is t o say that the
3 ' phosphate e s ter group serves a s a n u c 1 e u s ,
4 . kind of h ere . I t has stuck on it t h r e e
5 groupings , o f f to the side. Q. Three bonding spots?
Three bonding spots, good term.
And those three bonding spots
9 : can be filled with many types of hydrocarbon
10' fractions.
11 : .
Q . Functional groups ?
12. A.
No. These are basically hydrocarbon
13 type groups, one of which is cresyl, which we
14 defined a s a benzine ring attached to the
15 phosphorus through a C H 2 group . I f there
16 are three there, then it would be tricresyl
17 phosphate .
18 Now, those can vary with all
19 sorts of substituents on those particular
2 0 groups , a s well a s the three groups can
2 1 vary.
2 2 Skydrol was made of one which
2 3 contained very different groups than
24 tricresyl phosphate because of the
2 5 requirements for viscosity and other uses.
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! R. E. HHaattttoonn i i
1 Q . Okay.
32 Let me see if -- just so
2 we can avoid the chemistry lesson, the groups
i
3 ithat are bonded to the phosphate will change
4 t h e properties of the fluid . And you would,
5 depending on the function of the fluid, you
6 j would alter the compos ition of the tricresyl
7 i phosphate .
8 A.
Yes.
9 10i A.
Q Yes.
Fair?
11| 12: A.
Q Okay. Okay.
1 3 : Q After 14 F 9 were you involved in developingany other
15 synthetic functional fluids?
16 A.
Yes, I stayed active in that field all
1 7 along and worked on the programs , and
1 8 generated some of them myself .
19 Q . What was the next fluid that you
2 0 were involved in the development of after
2 1 Pydrau1 F9?
22 A .
I find it rather difficult to put the
23 . Pydraul development in a n exact time frame .
2 4 But one of the areas we worked on was
2 5 variations to Pydraul F9 . Some hydraulic
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1 ! requirements are different than others ,
2 | obviously, and we tried to develop a line of
3 , products that would be -- would satisfy the
4 j needs .
5 Q. Were these all the Pydraul line
6 of products?
7! A.
Well, when they we re developed they
8 were never called Pydrauls . They were called
9 Pydrauls when they went out the door and were
1 0 ! sold. Many different code numbers , notebook-
111 pages , numbers and what have you were used to
12; designate them for internal work until they
1 3 were ready to go.
1 4 Also looked for -- may I
1 5 backtrack?
1 6 When products were taken out to
1 7 the field to be tried in a n application , if
1 8 the user found that the product didn't meet
1 9 the requirements exactly , and he wished a
2 0 little different viscosity, or he wished a
2 1 different density, or he wished some
2 2 different property , then it would come back
2 3 to the laboratory and we would vary the
2 4 composition, and take it back to him and let
2 5 him look a t it.
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i
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E.
Hatton
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1 1 In doing such type of work we
2 also were very actively looking for other
3:applications of this type of product besides
4 hydraulic fluids. And one of those that we
5 picked a t that time was a s a steam turbine
6 lubricant .
7 Q. And which product was this?
8' A.
The first product in that line was OS
9 ; 5 8-1.
10 Q 11 compositi o n ,
n d what was OS 5 8 - 1 ' s
12 A.
11 w a
1 3 F 9 , and a 1 1
1 4 it c o n t a i n e d
1 5 phosphate 16 Q
Was this a different tricresyl
1 7 phosphate t h
18 A. 19
No Q
So, the difference between the
2 0 two was w hat
21 A.
Ch ang
2 2 additives 23 Q 2 4 included i n
What type of additives would be
2 5 fluids?
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1j A.
|
Two, usually, that are of primary
2!importance. I
One is a viscosity index '
3:improver, and the other would be a rust
35
4 inhibitor.
5 Q. Do you recall what year this OS
6. 5 8-1 was d e v e
7 A.
A round
8 Q. What was the next synthetic
9 f u n c t i o n a 1 fluid that you were involved in
1 0 the development of?
1 1 : MR. HART:: I 1' m g o i ng to object
12; t o the form. It's my impression that the
13 witness was involved in a variety of fluids
14 simultaneously .
15 If I ' m mistaken in that, then I
16 would withdraw my objection . But, I just
17 state it for the record.
1 8 A.
That is quite true, that I worked many
19 areas simultaneously.
I also had people
2 0 working with me, for me, who were working in
21 similar areas .
2 2 Q . Okay. Rather than ask what the
2 3 next one was. I'll ask what other synthetic
2 4 functional fluids were you involved in the
2 5 development of?
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1j A.
The follow on
j
2 | A n d these would have
!
3 Turbinol fluids .
products to OS 58-1. eventually ended up a s
4; I was also involved in further
5: developments in the Skydrol fluids . I was
6 involved in silicate ester chemistry . I was
I
71 involved in polyphenyl ether chemistry.
8: I also had a chemist working for
i
9; me who worked in very esoteric types of
10; fluids, which never became commercial . So, .
11| it is a n extremely broad range that I had.
1 2; Q . These follow on, or what you
1 3 refer to a s follow on fluids from 0 S 58-1
14 that eventually became Turbinols, was one of
1 5 those 0 S- 8 1 ?
16 A.
The next - - the next member of that
1 7 family was 0 S - 8 1 which followed 0 S 58-1.
1 8 Q . And what was thecomposition of
19 0 S- 8 1 when it was first developed?
20 A .
I t was about 9 0 percent Aroclor and
2 1 ten percent tricresyl phosphate --
2 2 Q . Did that composition for 0 S- 8 1
2 3 a s marketed, did that change over the course
2 4 of time a t all?
25 A .
Not to my knowledge .
Not to my
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1 !memory, I
I ! Q.
2
s hou 1d
You
say.
testified
earlier
!
3 OS 58-1 was d e v e loped and marketed
that the for steam
4 turbines - -
5 A.
No, it w a s not marketed , it was
!
6 developed f o r .
And it was field tested
in a
7 steam turbi n e , s mall s team t u r b i n e a t D u c a n e
8 Power and L igh t ,
And that's where w e found
9 ' that we nee d e d s o m e d i f f e r e n c e s , a n d that ' s
1 0 ;why OS-81 w as p u t t o g e t h e r .
11 :
Q I s e e . So, then 0 S- 8 1 was then
1 2 developed a n d m a rketed --
13 A .
Yes.
1 4 Q for steam turbines . 1 5 Was OS-81 marketed to any other
1 6 industrial users ?
17 A.
Yes. W e knew that the types of
1 8 bearings th a t we re involved in steam engines
1 9 were also i n v o 1 v e d in huge indus trial gas
2 0 turbines , s o we went after the gas turbine
2 1 market.
2 2 Q. And what companies in s p e c i f i c
2 3 did you market this 0 S- 8 1 to?
2 4 A.
Primarily to General Electric
2 5 although we took the product to all of the
i
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1ipeople that you have mentioned
i
2; terms of turbine suppliers.
before
in
3 Q. Was this fluid accepted by the
41 turbine manufacturers for use in their
5 turbines?
6 A.
It was given sufficient approval that
7 ; it was put into field use.
8 Q. Did you also market OS-81 to the
9 end users , the people that actually owned and
1 0 operated the turbines?
.
11:
Yes.
12; Q. And what companies were those?
1 3 Texas Eastern primarily .
1 4 Q. Any others?
1 5 A.
We co n t a c ted many, b u t w e -- we --
1 6 the only fie Id u s e was by T e x a s E a stern .
1 7 Q . W h a t specifica 11 y w a s it about
1 8 these synthe tic functional flu i d s that would
1 9 be attractiv e t o the end us e r ?
2 0 M R . HART: Obj e c t i o n to form.
2 1 Q Let me state that - - that when 2 2 Mr. Hart obj e c t s , it d o e s n ' t m e a n that you
2 3 should not a n s w e r .
2 4 M R . DAVIDSON: 2 5 the question ?
D o y o u understan
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1j
THE WITNESS
No, I'm not sure
2 I do. 3i
Q
Well, I'll ask it this way.
4 then.
5 : Before 0 S - 8 1 came onto the
6 market. 7 Eastern
8 A.
A
9 petroleu
10 Q
1 1 that w o u
And what was it about your OS -8.1
1 2 from pet
13 14 A .
MR. HART: Objection to form. 0 S - 8 1 is fire-resistant. That ' s why
1 5 we marketed it
1 6 Q. Were there any other 1 7 characteristics of the synthetic - fluid that
1 8 would have been particularly attractive to a n
19 end user, if you know?
20 A.
Besides fire resistance?
2 1 Q. Besides fire resistance.
22 A .
The products were extremely stable in
23 use --
24 Q . What do you mean by stable?
25 A .
I t means that there was little change
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in properties with time and in use.
I
2! Q . What types of products?
3 A.
Primarily concerned with the oxidative
4 reaction with oxygen, or air. Reactions
5 i caused by heat.
6 | Q . Would that be --
7 A.
Reactions with water --
8 Q. Thermal stability?
9 A.
Thermal stability . Hydraulitic
1 0 i stability.
1 1 By stability we generally mean 1 2 ! unaffected or slightly affected by the
1 3 : environment in which the product is used.
1 4 . Q. Were these products, I take it
1 5 if they are interested in thermal stability,
1 6 oxidative stability, that they were used in
1 7 high temperature applications .
18 A.
Yes.
1 9 Q. Would a high boiling poi n t or
2 0 low vapor pressure also be of interes t ?
2 1 MR. HART: Objection.
22 A.
Not necessarily .
2 3 Q . Did the products that y o u
2 4 marketed for this use have a high boi ling
2 5 .point, relatively high? Do you know
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1 A.
Compared to what?
2 Q . Yes. Okay. I unders tan d . High
3 is a relative term, I'm sorry.
4 I'll scratch the questio n .
5 Strike the question .
6 Were any other products after
7 0 S- 8 1 developed and marketed to Texas
8 Eastern?
9 A.
Yes. A product called M C S - 1 5 3 was - -
10
Q.
What was the composition o f
1 1 MCS-153?
'
12 A.
--dev e 1 o p e d -- it was a much more
1 3 complicated c o m p osition, b u t it did c 0 n t a i n
1 4 phosphate est e r , A r o c 1 o r , v i s c o s i t y i n d e x
1 5 improver, and I believe a rust i n h i b i tor.
1 6 Q D o you recall s p e c i f i c a 1 1 y how
1 7 MCS-153 diffe red from 0 S- 8 1 ?
1 8 A.
Yes. The additive p a c k a g e was
1 9 different, to b e gin with.
2 0 Sec o n d 1 y , the P C B c o m p o s i t i o n
2 1 was changed t o i mprove the low t e m p e r a t u r e
2 2 properties of the formulation.
2 3 Q. What do you mean by the P C B
2 4 composition?
25 A .
PCS is a family of fluids , and
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1 | depending on which
I 2 ! you have different
!
particular p r o p e r t ies
one you of that
use
3 I particular, s o-c a 11 e d PCB, which is u s u a 1 1 y
4 : still a mixture . A n d you can pick t h e
5 : properties that the mixture has, it d e p e n d s
6 ; o n the speci fic one .-- material s you use to
7; formulate it with.
8 Q You're talking the differences 9 from one PCB composition to the other being i o: the chemical structure of the PCB?
11: A.
Yes.
I guess a good way to say it is
1 2 ; that the a m o unt of chlorine the product
13 contains, and when we talk polychlorinated
14 biphenyls we mean putting a n amount of
15 chlorine on the biphenyl molecule . The
1 6 properties of the resulting mater ials depend
1 7 upon that amount of chlorine.
1 8 Q And so one of the di fferences 19 between 0 S- 81 , if I ' m unders tanding you
2 0 correctly, is that it had a different
21 polychlorinated biphenyl in it than that in
22 MCS- 1 53 .
2 3 A.
11 certainly contained some different
24 ones.
2 5 Now, whether there was any
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1 ! overlap between the two, in terms of the
2 ' specific fractions of PCBs, I don't -- can't
3 ; remember without considerable looking a t
4 formulations and so on. But yes, it was - -
5 : was significantly different .
6 : Q. Were there any other differences
7 ' besides the additive package and the
8 particular poly -- ratio of polychlorinated
9 biphenyls in it?
10 I
MR. HART: Differences in
-
1 1 : composition?
1 2 : A.
Composition? 0 r --
1 3 Q. Any other differences in
1 4 composition .
15 A.
No.
16 Q . Was --
17 A .
' That ' s a very -- I mean, by the time
18 you've listed the things that you just
19 listed, that ' s a major part of the
2 0 composition, actually .
21 Q. Well, the only remaining
2 2 component I guess would be the tricresyl
2 3 phosphate, and that was the same.
24 A .
Yes.
25
Q.
Okay.
When you refer to the
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1 ; s t a b i 1it y of MCS-153, I guess that in a sense
2 : i s a relative terminol o g y, as well, j u s t like
3 : h i g h boiling point wou Id be. Is that a fair
4 statement?
5: A.
Well, yes. Any property can be
6 compared with fluids and how you talk about
7 more or less of a given property in a
8 material.
9 Q So, to say that something
i o; extremely stable. it's stable within t h
11! realm with which its used a s a certain 1 2 j application . I s that a fair statement?
1 3 M R . HART: I'll object to
14 form.
15 A.
Stability -- the general term
16 stability when used in connection with fluids
17 is almost always in terms of a specific test
18 or a specific use. -
19 Q . Well, would you have
2 0 characterized the MCS-153 that went to Texas
21 Eastern ' s application a s being unchangeable ,
2 2 or indestructible, or very close to being
2 3 unchangeable or indestructible?
24
MR. HART:
I object to the form.
2 5 MR. DAVIDSON : I f you're going
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1 t 0 quest! on him about something 11
2 w r i 11 e n d o c u m e n t or letter. I ' d
i
3 I b e able t o see that.
that like
is i n a hi m t o
4 M R . KRAUSS : Y e s . He did n ' t - -
5 t h is one. I'm j ust seeing i f he agrees w i t h
6 1 that .
7 i M R . HART: Wei 1 , I object t o the
8 t e n s e o f the q u estion. Are you asking would
9 i h e now do that? Did he eve r d o - -
1 0 i Q . A t the time t h a t MCS-153 w a s
11! d e v e 1 o p e d and m arketed to T e x a s Eastern r and 1 2 w i thin t h e a p p 1 ications of Texas Easter n , was
1 3 i t the n e x t t h i n g t o being indestructible and
1 4 un changeab1e?
1 5 M R . HART: Sam e o b j e c t i o n .
16 A. 17 it
I f by y o ur question -- do you me a n was -- d i d i t h a v e a long 1 i f e i n that
1 8 applicati on? I would a n s w e r yes 1 9 Q w h a t do you me an by - - I don't 2 0 understan d what you mean by a long life 2 1 M R . HART: Wei 1 , then ask - -
2 2 Q W h a t do you me a n by a long 1 i f e 2 3 a s you us e d t.ha t term just now? Do you mean
2 4 that the MCS-153 would not decompose?
2 5 M R . HART: 0 b j e c t i o n to f o r m --
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1| A.
No, I - -
2! M R . HART: I ' m s 0 r r y .
3; A.
I d 0 not mean that the product would
4 ; n e v e r d isappear , 0 r would n e v e r degrade , 0 r
5 ! w 0 u1d never c h a nge in use . w e all know
6 ! b e tter than t h a t .
7 ; T h ings d 0 we a r 0 u t , even the
8 b e s t 0 f the m . And 10 put a 1 ife factor 0 n
9 a n y flu id i s a 1 most impos s i b 1 e because you do 10 n 0 t h a v e c 0 n t r 0 1 over how i t ' s used, 0 r what
11: P e 0 p 1 e d 0 t 0 it . S 0 , the r e f 0 re you can not -- 1 2 i w h e n I say a 1 0 n g life, I m e a n compared t 0
1 3 a n other pro duct in the s a me a pplication
1 4 Q 0 k a y . Why w 0 u 1 d oxidative
1 5 s t a b i 1 i t y a n d thermal s t a b i 1 i t y be im p 0 r t a n t
1 6 t 0 the end user
17: M R . HART: Objec t i 0 n t 0 f 0 r m .
1 8 M R . DAVIDSON : I f you know
1 9 Q I f you know.
20 A.
We were told that in the turbine
2 1 application the bearings and the s u r f a c e s ran
2 2 hot, and that air was present a t all times.
2 3 Therefore those properties would be
24 important .
2 5 Q . A t the time that you were
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1 i n v o 1 v e d in the development of the OS-81,
2 m o re spec i f i c ally in the marketing of it t
3 ; T e x a s E a s tern r were you familiar with all 4 ; T e x a s E a s tern ' S applications for that f1ui
5 1
6 ] deve1oping 7!
MR . it ?
MR .
HART: A t the time he was KRAUSS: Developing and
8 m a rketing 9 : M R . HART: Well, I object to 1 0 n o t i o n t h at i t was being applied a t the t i
1 1 : t h a t it w a s b e i ng developed.
1 2 : M R . DAVIDSON : Now, I'm not s
1 3 i t ' s fair t 0 a s k him whether he knows all
1 4 a b out the ope r a tio n s of Texas Eastern . I
1 5 m e an, he was 1 o o k i n g a t a specific type of
1 6 applicati o n .
17 A.
I thin k I would --
18 1 9 then
Q --
W e 1 1 , let me ask it this way
20 A.
-- w e were given general criteria
2 1 f o r the i n d u s t r y, I would say -- that wou
2 2 b e r e q u i r e d i n steam turbines and gas
2 3 t u r b i n e s and other equipment. And we
24 developed the fluid in terms of those
2 5 requirements .
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1 ; Q . Okay.
2! A.
But requirements , not any specific
3: customer..
4
-Q.
Okay.
And where did you get the
5 information or the requ irements for the
6 fluid? What was the so urce of that
7 information?
8 A.
Most of them cam e from discussions
9 with experts in the fie Id, through committee
1 0; contacts, and through c alls on equipment
1 1 : manufacturers .
1 2:
Q. Were those equipment
`
1 3 manufacturers the ones that you listed
14 earlier?
15 A.
P 1 us other P e o p 1 e, who were --
1 6 s u p p 1 i e d accessor i e s t o those units.
1 7 Q When y o u w ere involved in the
1 8 d e v e 1 o p m e n t d e p a r t m ent , did you ever make any
19 customer visits to the customers ' locations?
20 A. 21
Oh sure.
Yes
Q Did you e v e r visit a Texas
2 2 Eastern c ompressor s tat ion in that capacity?
23 A .
Ye s .
2 4 Q . Do you r e c all which compres sor
2 5 station?
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i : A.
N o , I do not.
2 ; Q Was there more than one 3 compres s o r station that you visited?
4 A.
T o the best of my memory, yes.
5 Q 6 station ?
You don't recall the name of the
7 A.
No .
8 Q Do you recall what state the
9 station w a s in?
10 A.
Sou th of St. Louis.
1 1 MR. HART: Off the record.
1 2 (A discussion takes place off
1 3 the rec ord ) 1 4 Q Do you recall the purpose of
1 5 your v i sit s t o Texas Eastern compressor
1 6 station s ?
1 7 MR. HART: This is during the
1 8 time he w a s in the development department?
1 9 MR. K R A U S S : Yes.
20 A.
11 would have been in the ' 6 0 to ' 6 8
2 1 period .
2 2 Primarily to see what the actual
2 3 equipment looked like.
24 2 5 well.
Q Let me backtrack a minute, as Did you ever visit a Texas Eastern
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compressor station prior to 1960? Prior to
2 i the time that you were in the development
!
3 : department?
4: A.
I t h ink I accompan i e d the man who
5 ! in developm e n t a t that t i m e , working in
6 | area -- on c e .
7 j Q Who was the man that was in
8 development a t that time. that you were
9 j referring to?
10! A.
Jim Davis .
11;
0 . Do you recall what station that
1 2 was?
13; A.
No.
1 4 Q Do you recall what year that
1 5 was?
16 A.
No.
1 7 G Was this before t h e time that
1 8 OS-81 was available to the mark e t ?
1 9 MR. DAVIDSON : Are you talking
2 0 about did the visit take place - -
2 1 MR. KRAUSS: The v i s i t .
22
MR. DAVIDSON :
-- take place
2 3 before 0 S - 8 1 - -
2 4 MR. KRAUSS: Yes. 2 5 Q - Did you go there --
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1 ; A.
All right .
2 Q - - as part of the development 3 . OS-81, duri n g that project t o see what the
4 application was to help y o u r development
5 project?
6 A.
The purpose of the visit was to
7 observe the types of environment the fluid
8 would possibly be exposed to. And to confirm
9 what we had learned from visits to the
1 0 manufacturers , such a s G E and o t h e r --
1 1 Q. Was 0 S- 8 1 a product o n the
1 2 market already a t that t i me when you w e
13 make that visit?
14 A.
Yes.
15 Q. And what, specifically, was
16 Texas Eastern ' s application for this fluid?
17 A.
As the lubricant in a gas fired
18 turbine , industrial type.
And a s a
19 compressor fluid -- or a compressor
20 lubricant on the natural gas compressor that
21 was attached to the turbine .
2 2 Q. Are you familiar with the
2 3 lubrication system on natural gas
24 compressors? Centrifugal compressors, let me
2 5 narrow that.
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|
2! then.
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52
MR. HART: Well, I'll object,
See if the witne ss is familiar with
3 i the distinctions . I o b ject to the form.
4 MR. KRAUSS : Let me strike the
5 question.
.6 i Q . When you v isited the turbine
7 ; station, do you recall what type of
8 c o m p r e ssor was a t that station?
9: A.
I t was a centrif u g a 1 compressor .
I do
1 0 : not rememb er the m a n u f a c t u r e r .
.
1 1 , Q Okay. And you stated that this
1 2 synthetic functional f 1 uid or synthetic
1 3 lubricant was going to be used as a lubricant
1 4 within the centri f u g a 1 compressor?
1 5 MR. HART: Objection to form,
16 A.
I w a s told that it was going to be
1 7 there .
-
1 8 Q Were you f a m i 1 i a r with the
1 9 lubricatin g systems on such centrifugal
2 0 compressor s ?
21 A.
I w o u 1 d like a d efinition of the word
2 2 familiar.
2 3 Q Well, with in your job of
2 4 marketing. or anticipat ing the needs of
2 5 industry, and developin g fluids for the
. (
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1 industry, were you f a m i 1 iar with the end
2 uses?
3 A.
The equipment man ufacturers had
4 s u p p 1 i e d us with s c h e m a t ics of the
5 1 u b r i eating systems . A n d I was familiar with
6 that type -- with d e t a i 1 a t that level , with
7 h o w the fluid was used a n d what it would be
8 I was not i n v o 1 v e d with piping
9 d i agrams, e x a c t pipe run s and that type of
1 0 o f the s y stem. But I w a s p r o v i d e d with
1 1 i n formati on, s chematic d r a w i n g s that showed
12: where the fluid went a r o u n d the system.
13 Q . Yes.
14 A.
What it was expos e d to, and where --
1 5 and where, in that schem a t i c .
16 Q . Okay. And this is all still
1 7 pre-1960.. that we're talk ing about?
18 A .
I -- it was eith e r pre-1960, or when
19 I went to development . 2 0 development I also
When I went to
wed these same sorts
2 1 of programs , and I
trouble deciding
2 2 whether this is ear
0 s or late '50s that
2 3 this was bei n g done
24 Q. Okay. Do y o u have a n
25 understanding for all of the purposes of
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1 I lubricant in a centrifugal compressor?
2;
MR. HART:
I need that question
3 back.
4 (The pending question is read
5 back by the reporter . )
6
MR. HART :
You want to rephrase
7: it?
8
MR. KRAUSS:
Not really.
9:
MR. HART:
lobjecttothe
10 form.
.
1 1 MR. DAVIDSON: Do you understand
12; the question?
13
THE WITNESS :
I'm not sure that
14 I quite do.
1 5 Q . Okay. Let me ask, what are the
1 6 purposes of a lubricant within a centrifugal
1 7 compressor, if you know,
based on your
1 8 familiarity with them, that you developed
19 from reading 1 iterature from the compressor
2 0 manufacturers?
21 A.
I n general terms, it must lubricate
2 2 the bearings, and must function a s a seal oi
2 3 for the gas being compressed in the system.
2 4 Q . What do you mean by a seal oil?
25 A .
The gas is compressed to high
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1 pressures, and it must keep the -- you must
2 maintain that gas within the system somehow,
3 and a liquid seal is one way of doing that.
4 And the lubricant, so-called lubricant often
5 functions that way.
6 Q. Do you have a n understanding if
7 that was one of the functions of the
8 lubricant within the application a t Texas
9 Eastern?
1 0 MR. HART: I'll object to the
1 1 form.
1 2 MR. KRAUSS: Well, are you
13 implyingthat there
is something different
14 between what manufacturers were telling him
15 and showing him, and what Texas Eastern --
1 6 is that what you're getting at?
1 7 MR. KRAUSS : No. He mentioned
18 something in general that he said sometimes
19 fluid acts a s the seal. And I want to know
2 0 if he has a n understanding that that was one
2 1 of the uses a t Texas Eastern.
2 2 MR. DAVIDSON : Okay.
23 A .
It s tate d in a paper that Texas
2 4 Eastern wrote that that was one of theuses,
2 5 a s a seal oil.
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1 Q, What paper are you referring to,
2 if you know?
3 A.
One by Earl Farmer.
4 Q D o y o u r e c a 1 1 the title of that
5 paper?
6 A.
Not an e x a c t title . It was e xperienc
7 w ith fire-resista n t 1 u b r i cants was the
8 g eneral subject.
9 Q . You mentione d that t h e fluid c a
1 0 a ct as a seal to keep the high p r e s s u r e d gas.
1 1 i n the system. D o you ha v e a f a m i 1 i a r i t y
1 2 w ith how that act u a 1 1 y wo r k s ?
13 A.
Only to th e extent of s e e i n g a
1 4 s chematic. How i t would actually work in a
1 5 P iece of equipmen t , I'm n o t sure I c a n 1 6 e x p1 ain it to you 1 7 Q . With in the s eal syste m do you
1 8 h a v e a n unders tan ding of whether o r not the 1 9 s e a 1 oil contacts the gas ?
20 A.
The schema tic show s that, y e s , that
2 1 the fluid is put at high pressure b y means o
2 2 a hydraul ic type pump. And a t high pres sure
23 it does contact the -- whatever is being
24 pumped by the compressor.
25 Q. Do you have an understanding of
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1 what the pressure is relative to the gas
2 pipeline pressure?
3 A.
I don't remember what I was told in
4 that case, specific numbers .
5 Q. In order for the fluid to
6 f u n c t ion a s a seal. i s i t your understandi n g
7 that the press u r e s could be equal, the sea 1
8 oil v e r s u s the natural g a s pressure?
9 MR. HART: Objection to form.
1 0 MR. DAVIDSON : Gregory , we have
1 1 not put him forward a s a knowledgeable
1 2 witness on the phys ical functioning of a gas
1 3 pipeline and compressors, but for the
1 4 function of the fluid in those, and I --
1 5 MR. KRAUS 3 : I understand that.
1 6 MR. DAVIDSON: -- as long as we
1 7 stay on what h e understood were the
1 8 r e q u i r e m e n t s n e cessary for the f 1 u i d to
1 9 f u n c t ion, we ' r e willing to let him testify as
2 0 to that. But I think we're getting into how
2 1 does this thing work.
2 2 MR. KRAUSS: I understand that.
2 3 And I believe that the witness testified that
2 4 he had to become familiar with the
2 5 application as part of the development of the
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1 different fluids . And I just want to know
2 how familiar the witness was with the
3 specificapplication.
.
4 MR. DAVIDSON: I understand .
5 that. What I'm trying to say is that someone
6 from Texas Eastern is probably the most
7 knowledgeable person with respect to how the
8 pipeline and the compressors work.
9 What Dr. Hatton knows is, given
1 0 a specific set of requirements , or
1 1 specifications, or characteristics we tried
1 2 to make a fluid that would do that.
And I
1 3 understand that may melt over into some
1 4 understanding as to what and how the system
1 5 functioned.
1 6 MR. KRAUSS: Okay.
1 7 MR. DAVIDSON: But as to
1 8 relative vapor pressures and so forth, I
1 9 think we may be getting a little far afield
2 0 of what he can be expected to know.
21
MR. KRAUSS:
Okay. Well, then
2 2 if he doesn't have an understanding of that,
2 3 then he should justanswer that he
doesn't.
2 4 A.
Okay. I do not have an understanding
2 . of the exact function of that system.
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Q Okay 2 M R . DAVIDSON : I think the
3 record will reflect that he said this is
4 information bei ng told to me about what was
5 required. So I think --
6 M R . KRAUSS : Right.
7
M R . DAVIDSON :
-- that's fine
8 M R . KRAUSS : You're correct.
9 M R . DAVIDSON : I don't want to
1 0 get too far off 1 1 M R . KRAUSS :
He reviewed the
1 2 schematic diagrams .
1 3 M R . DAVIDSON. : Exactly.
1 4 M R . KRAUSS : Okay. I think I'
1 5 like to take a ten minute break, if that ' s
1 6 okay with everybody else.
17 A.
Fine.
1 8 (There is a recess . )
1 9 ( A discussio n takes place off
2 0 the record.)
2 1 M R . KRAUSS : Back on the
2 2 record .
2 3 Q. With respect to the pre-1960
24 Texas E a s tern station visits that you made,
2 5 how many visits did you make before I 9 6 0 ?'
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1 A.
I -- I can't remember that. In those
2 days I was doing a lot of traveling, and I
3 d o n ' t - - I -- -- 3 0 years ago. I c a n ' t
4 r e m ember w h ere I w ent when, and o n what
5 P r o j e c t , be cause I was also i n v o 1 ved in many 6 Pro j ects . 7 Q D o y o u recall wh o at Texas 8 E a s tern t h a t you s poke to?
9 A
One name I remember, 0 . M . Fletcher,
1 0 0 1 1 i e F 1 e t c her.
1 1 Q D o y o u know what M r . Fletcher ' s
1 2 P o s i t i o n w a s at t h e time?
13 A.
He was in the engineering department.
14 I do not know his title --
1 5 Q. Did you meet --
16 A.
_-- any more.
17 Q. - - meet any station personnel at
18 that time?
19 A.
One doesn't visit a station without
20 getting introduced to the people that are
21 there, so I have to answer yes. But I do not
2 2 remember the names .
23 Q. Do you know if there is anybody
24 else from the engineering department, besides
2 5 Mr. Fletcher, that was on that visit? -
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1 A.
N o . Again , I cannot reme m b e r .
. 2 Q Do y ou recall what you did when 3 you were a t the s t a t i o n ?
4 A.
L o o k e d a r o und ,
5 Q What did you see?
6 A.
As ked ques ti ons .
7 Q What did you see?
8 A.
I s a w a g a s pumping stati on. You
9 k n o w , w i t h the e q uipment o p e r a t i n g .
1 0 Q Did they have any unoperati n g 11 turbines there that you could look at?
12 A.
I don't remember . `
13 Q, What about compressors? Did
1 4 they have a compres sor for you to look a t
1 5 that wasn't operating?
16 A.
A g a i n , I can't remember .
1 7 Q Not specifically relating t o
1 8 station visits, but in general, in this time
19 frame prior to 1960, who else from Texas
2 0 Eastern were you dealing with with respect to
2 1 this 0 S - 8 1 ?
22 A.
My contacts were almost completely
2 3 with 0 1 1 i e Fletcher .
24 Q. I know you testified that you
25 can't recall the name of the station, but do
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you recall the reason -- was there a
part icular rea son why you went to the
that you went to?
4 A.
.To the best of my memory, it was
5 general information.
6 Q . Did Texas Eastern pick the
7 station for you to go to to view?
8 A.
Texas Eastern was my host. yes.
9 Q Do you recall if it was the St 1 0 Francisville station 7
11 A
I do not
1 2 Q D o y o u r e c all i f o n e o f the'
1 3 reasons for the v i s it w a s that i t was the
1 4 site of the big f i r e t h a t led t o the need
1 5 these fire-resistant lubes?
16 A.
I don't remember being told that.
1 7 Q. Was the composition of OS-31,
18 was that a trade secret?
19 A .
Yes.
20
Q . Wasitpatented?
.
2 1 A.
No. I t was impossible to patent
22 phosphate ester Aroclor mixtures, as such.
23 Total compositions could be patented, based
24 primarily on the additives used.
2 5 Texas Eastern, were they awar
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1 of the composition of theOS-81?
2 MR. HART: Objection to form.
3 Q . In 1 9 5 8 ?
4 MR. HART: Restate the
5 objection .
6 A.
I do not -- I don't know.
7 Q . With respec t t o station vi sit s
8 t h a t - - T exas Eastern s t a t i o n v i s i t s that
9 y o u made a fter I960, how w ere they d i f f ere n t
1 0 t h a n the o nes you made b e f ore 1 9 6 0, a s far a.
1 1 t h e p u r p o s e of the visit
1 2 MR. HART: I o b j e c t to the
13 f0rm .
I t assumes that the y w ere d i f f e r e n t /
1 4 a n d there is no foundati o n 1 5 Q Were the v i s i t s differ e n t ?
1 6 MR. HART: D o you mean did they 1 7 ha v e a different purpose ? I mean, they w e r e
18 clearly different visits.
19 I object to the form.
20 A.
The purpose of the visit was the same;
21 to generallyobserve what
was going on, and
22 to talk about the properties of our products.
2 3 Q, Do you know if any records of
24 these visits were kept by Monsanto?
25 A.
I doubt it. But I do not know.
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1 Q. Do you recall dealing with
64
2 a n y b o d y who you dealt with in the '50s,
3 1 9 6 0 , from Texas Eastern, who you dealt 4 wi th7 -
5 A.
My dealings were primarily with the
6 engineering department in Shreveport . And I
7 e m e m b e r two names that I dealt with, one was
8 a 1 ter Woods , and the other one was -- I
9 o n ' t know h is ini tia 1s , but he was commo n 1 y
1 0 known as Buck Jarnagin.
1 1 I m e t many o t h er people at Texas
1 2 Eastern, but tho s e are the only two that were
1 3 -- that I seem t o be able to dredge u p .
1 4 MR. KRAUSS: I'm going to
1 5 recommend that we break for lunch now,
1 6 because I want to review where I've been and
1 7 where I'm going.
1 8 MR. HART: Off the record .
1 9 (A discussion takes place off
2 0 therecord.)
2 1 (Luncheon Recess . )
2 2 (Afternoon Session. )
2 3 CONTINUED DIRECT EXAMINATION BY. MR. KRAUSS :
2 4 Q. Dr. Hatton, earlier we were
2 5 talking about the use of MCS-153 as a sealing
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1 liquid, or a component of a seal system of
2 centrifugal compressors .
3 Do you have an understanding as
4 to what it's a seal between? Between what
5 and what? What i
it s e a 1 i n g ?
6 A.
The schema c would show i t a s
7 between the -- w
t e v e r f 1 u i d was b e i
8 compressed and t h outside a t m o sphere.
9 Q. In the case of Texas Eastern,
10 what was the fluid being compressed, if you
11 can recall?
12
MR. HART:I object
to the
13 form.
14 MR. DAVIDSON: What was the
15 fluid being compressed?
16 MR. KRAUSS: He referred to a
1 7 fluid being compressed.
18 A .
Fluid
was natural gas.
19 Q. And where would this natural gas
20 tend to go if there wasn't a seal?
2 1 MR. HART: Objection to form .
22 A.
Escape into the atmosphere .
23 Q . So, to your knowledge, the seal
24 prevents the gas from going to the
25 atmosphere.
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1 M R . H A R T : Objection to form,
2 A.
(The witness nod s his head.)
3 Q Now, is t h e gas somehow pushing 4 a g a inst this sealing lu bricator?
5 MR. HART: I object. Counsel,
6 you have had - -
7 MR. KRAUSS Laird, you can
8 o b j e c t -- I don't want a speech on the
9 rec ord .
1 0 MR. HART: Well, I have a right
1 1 t 0 make my objection on the record. I've
1 2 bee n r e s t r a i nedso far.
1 3 The witnes s' Counsel admonished
1 4 you before the lunch b r eak that yo u ' r e here
1 5 pur s u a n t to a 3 0(b) 6 ) notice for deposition
1 6 o f Monsanto.
I think y ou're going way beyond
1 7 the paramete rs of that notice. I think it's
1 8 d u p1 icative of discover y that carriers have
1 9 had earlier. on repeate d occasions. I'm
2 0 stating for the record
2 1 MR. P U P K E : May I state for the
2 2 r e c o r d, Mr. Hart, I can appreciate your
2 3 con cern with the sco p e of the testimony .
2 4 According to the Case Management
2 5 0 r d e r in t h i s case, Mr. Hart, you have an
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1 o b j e c t i on to form. All another objections
2 a r e res e r v e d , to be d e t rmined later,
3 Andplease state your objection
to form. n o speeches
the record, and we'll
move a 1 o t quicker.
6 MR. HART: I appreciate --
7 MR.PUPKE: For the benefit of
8 us all.
9
MR. HART:
I appreciate your
10 point, Don.
11 Itseemst o me that the
12 precedent for the objec tions to form in the
13 context of whether a qu estion is going beyond
1 4 the bounus of a 3 0(b) (6 ) notice was laid by
1 5 the carrier s w h e n they were defending their
1 6 3 0(b)(6) d e posit ions --
1 7 M R . PUPKE : Mr. Hart --
1 8 M R . HART: -- and I don't think
1 9 this colloq u y is h e 1 p i n g anybody proceed.
2 0 M R . PUPKE : If Mr. Hatton's
2 1 attorney fe els that it' s beyond the 30(b)(6),
2 2 I'm sure he will object to that point .
2 3 M R . K R A U S S : Furthermore, I
2 4 understand that Dr. Hat ton is not a n e x p e r t
2 5 on seal oil systems .
H o w e v e r , h e has bee n
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1 significantly involved in the development of
2 the fluids that are used in those systems,
3 and he's already testified that as part of
4 his job at Monsanto, he became -- it was
5 within his realm to becomefamiliar
with the
6 appl ications of the fluids . And that ' s the
7 only area I'm going to. I think it's fair
8 game. I know he's not a n expert on the
9 system.
1 0 MR. HART: I think you just
1 1 mischaracterized his testimony . I don't
1 2 think he's evertestified
that that was
1 3 within his job.
I f you want to ask himabout
1 4 that, that would be fine.
Butyou haven ' t
1 5 done that.
1 6 MR. PUPKE : Let's move on.
1 7 please .
1 8 MR. KRAUSS: Would you please
1 9 read back the part before Mr. Hart ' s
2 0 objections , please.
2 1 (The following question is read
2 2 back by the reporter :
2 3 "QUESTION: So, to your
2 4 knowledge, the seal prevents the gas from
2 5 going to the atmosphere. ")
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1 MR. HART: Counsel, I also might
2 object to the question on the grounds that
3 it's leading, among other things.
4 MR. KRAUSS: I think there w a s a
5 d i f f e r e n t q u estion pendin g
I t h ink h e m i g h t
6 h a v e o b j e c t e d to that que s t i o n . But I t h i n k
7 he objected to another question. I think
8 there is a question pending.
9 MR. PUPKE: Why don't you just
10 reask the question.
11
MR.
KRAUSS: I'll just reask the
12 question.
13 Q. Does the gas somehow push on the
14 sealing oil in the seal oil system, to your
1 5 knowledge , and with the familiarity that you
16 have with the systems that you've testified
17 to earlier?
18 MR. HART: Objection to form.
19 A.
If you're asking the question of what
20 were the requirements placed on the fluid by
2 1 the seal system, we were told by the
2 2 producers of the seal oil system that it must
2 3 function a s a high pressure, hydraulic
24 fluid. And we used those parameters in the
2 5 designing of the product .
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1 MR. KRAUSS: Could we please
2 mark this as Hatton Exhibit number one,
3 please.
.
4 (Letter to W . M . Stephens from D.
5 F . Smith, dated August 2 2 , 1968, two pages ,
6 Bates Nos. 000907285 through 000907286
7 is marked Hatton-1 for identification . )
Q I ' m handing you what ' s been marked f o r our purposes today as Hatton
E x h i b i t n umber one.
11 This is a document that was
12 produced to the insurance carriers by Texas
13 Eastern, and it bears the Bates stamp number
14 000907285 and 000907286.
15 Could you please take a moment
16 to review that letter, please.
.
17 A .
(The witness reads the document . )
1 8 Q. Okay.
19 A .
I have read the letter .
2 0 Q. This letter was written by D.F.
21 Smith
Do you know a D.F. Smith?
2 2 MR. HART: I'll object to the
2 3 form o f the quest ion,, That letter appears to
2 4 have b e e n written b y Mr. Smith.
25 A.
I know Dal e F , Smith .
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Okay. And did you work with him
2 at Monsanto?
3 A.
Yes.
4 Q. This le.tter appears to have been
5 written to a W.M. Stephens from Texas
6 Eastern. Have you ever met W.M. Stephens?
7 A.
I don't remember .
8 Q. You don't know if he was one of
9 the people that you would have been involved
10 in, in your relationship --
11 A.
No.
12 QQ .. -- with Texas Eastern?
13 A .
No
1 4 Q . The letter also refers to an
1 5 Earl Farmer .
Are you familiar with a Mr.
1 6 Earl Farmer?
17; A
Yes.
1 8 Q. Do you know by whom he was
19 employed?
20 A.
Texas Eastern.
2 1 Q . When did you first meet
22 Mr. Farmer, do you recall?
23 A.
No, I do not recall the date. It was
24 on one of the many trips to Texas Eastern.
25 Q. On the second page, the first
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1 full paragraph and thefirst
sentence of that
2 paragraph, do you agree with Mr. Smith's
3 characterization of MCS-153 as stated there?
4 MR. HART: I object t.o the
5 form. The question is ambiguous, it assumes
6 a foundation that has not been shown to
7 exist.
8 MR. PIERDINOCK : Excuse me,
9 Gregg, what paragraphdo you mean?
1 0 THE WITNESS : "When surfaces
11 which come in contact --
1 2 Q . My mistake. I thought that was
13 a continuation paragraph
1 4 I'm sorry, it's the second full
15 paragraph , the first sentence . My mistake.
16 A.
I ' did not author this particular
1 7 paragraph --
1 8 Q. I understand that.
19 A.
I would have stated it in -- more
2 0 directly in terms of application and use in
2 1 that application, which I think Dale assumed
2 2 was understood .
2 3 Q . Okay. Why do you say you would
2 4 have applied it more to the application?
25 A .
Wel.h, due to my training from the
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1 laboratory, I tend to speak more precisely
2 than a salesman does.
3 Q. Okay. So, how would you have
4 phrased this with respect to the application
5 that Texas E a s tern had?
6 MR. HART: Objection.
7 A.
I would have stated it generally in
8 turbine use.
And I would have said under
9 normal conditions, turbine applications, the
1 0 product is satisfactory for service for long
1 1 periods of time.
1 2 Q. With respect to whether it's
1 3 indestructible, would that be referring to
1 4 its characteristics of thermal stability ,
1 5 oxidativestability?
1 6 MR. DAVIDSON: I'm going to
1 7 object . He didn't have any idea --
1 8 A.
I did not write this. I do not know
1 9 what Dale meant, exactly, by indestructible.
2 0 MR. HART: In addition to the
2 1 objection as stated, I object to your using
2 2 the concept of indestructible, rather than
2 3 the document , which says "the next thing to
24 it
2 5 MR. KRAUSS: Okay.
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1! Q. I believe you testified earlier
2: that MCS-153 was a trade secret. Do you know
3 i Texas Eastern was ever informed that it
4: contained polychlorinated biphenyls?
5 MR. HART: Talking about
6 MCS-153?
7 MR. KRAUSS: Yes
8 MR. HART: All right.
9 A
Excuse me a minute.
1 0 ; (A discussion takes place off
1k the record between the witness and his
12; attorney. )
1 3 ; A . * I believe that they were well aware of
14 the fact that there was chlorinated materials
15 in both OS-81 and in MCS-153.
16 And I know that by 1970 that
1 7 Earl Farmer wrote a paper in which he states
18! that the product contained chlorinated
19 biphenyls .
20 MR. PUPKE: Would you please
21 repeat that
2 2 (The last answer is read back by
23 the reporter.)
2 4 MR. KRAUSS: Would you please
25 mark that as Exhibit 2
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1 | (Document entitled, "Facts About
2\Fire-Resistant Lubricants" Bates Nos. TEX
3 000330 through 000337, is marked Hatton-2 for
4 identification.)
5 MR. KRAUSS: Beforewegetinto
6 this particular exhibit.
Q Let me ask, do you know when 8 Mr. Farmer became aware that the MCS-153
9 c o n t a i n e d p olychlorinated b i p h e n y 1 s ?
10 A.
N o , I do not.
11 Q 1 2 by Mon santo
Do you know i f he w a s told s u c h
13 A.
I do not know the s o u r c e o f Ear 1 - -
1 4 any of Earl Farmer's info r m a t i o n 1 5 Q Did Mr. Farmer cons u 1 t w i t h you 1 6 regard ing that paper that you re f e r r e d t o 9
17 A.
After the paper was given / w e
1 8 r e q u e s ted permission to i n c 1 u d e i t i n one O f
1 9 our bulleti ns -- excerpt s from t h e pa per i n
20 the bulletin
2 1 I did not make that contact,
22 someone else did. But the company was in
23 contact.
24 Q. Did Monsanto -- in 1970 did
25 Monsanto still consider the composition of
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1 the MCS-153 to be a trade secret?
2 MR. DAVIDSON: If you know.
3 A.
A t that time we did not publish this
4 information in our technical bulletins. But
5 our sales people, and others within the
6 company did talk about them that way.
7 Q . So, the sales people were in a
8 position to divulge the composition of the
9 product to the customer?
1 0 MR. HART: I object to the form.
1 1 A.
I don't know what exactly they were
1 2 told. But they knew.
1 3 Q . Was there a time within the
1 4 company that it was -- that the salesmen
1 5 were given clearance to reveal that
1 6 information, if you know?
17 A.
That I do not know.
1 8 Q. I'm handing you what's been
1 9 marked for our purposes today a s Hatton
2 0 exhibit number 2. Is this the product
2 1 brochure to which you referred to earlier?
22 A.
This is a product brochure.
And the
2 3 only code date that I can find on it is
2 4 8/70.
2 5 Q Could you please take a moment
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1 to review the document.
2 A.
(The witness reviews the document . )
3 Q . Is the paper that's referred to
4 here by Earl Farmer, titled, "Fire-resistant
5 Lubricants in Gas Turbines" the paper that
6 you referred to earlier in your testimony?
7 A,
Yes.
8 Q . Under the heading -- on the
9 second page of this exhibit, under the
1 0 heading "Texas Eastern Tries Synthetics" in .
1 1 the last part of the first sentence it
1 2 characterizes the synthetic as a phosphate
1 3 ester based fluid.
1 4 I s that consistent with the true
1 5 nature of that product?
1 6 MR. DAVIDSON : Well, I object .
1 7 Thatdoesn'tnecessarily say that
it refers
1 8 to MCS-153 or anything else.
1 9 Q. Do you have an understanding as
2 0 towhether or
not --
21 A.
Let me make a statement a s to the
2 2 general classification of fire-resistant
2 3 fluids . 'I A
*4
Now, in the work which w e ha v e
2 5 mentioned briefly, such a s with ASTM,
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1 fire-resistant fluids were divided into
2 phosphate esters, sometimes called whole
3 phosphate esters, butphosphate ester.
4 Phosphate ester based was a term
5 to cover any mixture of phosphate ester and
6 chlorinated material.
7 Q . So the fact that it says
8 based --
9 A.
Petroleum.
1 0 Q . -- based does not necessarily .
1 1 mean that it was the major component?
1 2 A.
Not necessarily the major component.
1 3 If it was a component there --
1 4 Q. Does the --
1 5 A.
They were put in that class because
1 6 the chlorinated materials changed the
1 7 properties sufficiently that you needed a
1 8 separate class for working with this.
1 9 These were then -- these two
2 0 classes were then followed by many classes of
2 1 other types of chemical products, such as
2 2 water oil emulsions , water glycol solutions ,
2 3 silicate esters, silicones, and many other O A y ypes of products. And always including 2 5 petroleum oil a s one of the s tandards to work
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1 from.
2 Q . Other than Mr. Farmer's article
3 that you testified earlier to, which was your
4 answer to a question regarding if Texas
5 Eastern knew that --
6 A.
Uh-huh.
7 Q . -- MCS-153 contained PCBs, do
8 Il you have any other knowledge of Texas 9 j employees knowing that they contained
Eastern --
1 0 that the MCS-153 contained PCBs?
.
1 1 MR. DAVIDSON: Excuse me one
1 2 minute.
1 3 (A discussion takes plac e off
14; the record.)
1 5 j MR . DAVIDSON: Go ahead and
16; answer i
17! A.
it. Wear e
t alking
what
time
frame ?
1 8 I Q . W e 11, I belie ve that you s a i d
m e r ' s article was 1970. And I ' m
P r ior to 1970 , if you ha v e any a n ybody at Te xas Eastern knowing
ion of either the OS-81, o r the
2 3, MCS-153 .
24; A .
I do not know, but I am aware of the
25 fact that our drum labels generally contained
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1 a s t a t e m e n t which said they c ontained
2 c h 1 o r i n ated compounds.
3 Q Chlorinated comp o u n d s , out n o t
4 a n y t h i n g more specific than that?
5 A.
A t that time we d id no t use the te r m
6 P 1 y c h 1 o r i n a t e d biphenyl , o r P C B s .
7 Q Did you eve r d e a 1 with a man a t
8 T e x a s E a s tern named R.E. Moor e ?
9 A.
R . E. Moore sat in on a meeting or two.
1 0 I b e 1 i e v e . And I think he w a s the
1 1 v i c e - pr e s ident of engine e r i n g 1 2 Q Now, do you r e c a 11 when t h o s e
1 3 m e e t i n g s took place?
14 A.
P r obably early '7 2 .
1 5 MR. KRAUSS: W o u Id you pleas e
1 6 m a r k t h i s as Hatton Numb e r 3 .
1 7 (Letter to R.E. Moore f r o m W . M .
1 8 S t eph e n s , dated June 28, 19 6 8 , Bates Nos.
1 9 : 0 1 0 0 3 7 9 8 3 through 010037986, is mark e d
2 0 H a 11 o n - 3 for identificat ion.)
2 1 Q Dr. Hatton, let me dire c t y o u r 2 2 a t t e n t i o n to the section of this doc u m e n t - -
2 3 MR. KRAUSS: By the way for the
2 4 r e cor d / this document is a do c u m e n t p r o d u c e d 2 5 t o t h e c a rriers by Texas East e r n, be a r i n g the
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Bates number 010037983 through 010037986.
MR. DAVIDSON: Have you had an
opportunity to read through it?
4
THE WITNESS :
No, not all the
5 way.
6 M R . HART: Could I , on the
7 record, ask that we take a b r e a k at this .
8 point. I'd like to go off the record .
9 ( A discussi on take s place off
1 0 the record. ) 1 1 M R . KRAUSS :
We're going to ask
1 2 to withdraw the last e x h i b i t u n til we resolv
1 3 some --
14
THE WITNESS :
0kay .
15
M R . KRAUSS :
-- is sues
1 6 regarding i t .
1 7 M R . HART: And I want to state
1 8 for the rec ord what the issues are.
1 91 2
Texas Eastern produced materials
20 under a Protective Order requiring
21 confidentiality of documents so designated,
22 and all Texas Eastern produced documents were
2 3i designated confidential.
24 I did not bring a copy of the
25 Protective Order with me to this deposition.
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1 I also was -- I don't believe,
2: advised prior to the deposition that Counsel
3 for the carriers intended to use as exhibits
4I! !any documents 5|Monsanto.
other
than
those
produced
by
6 The introduction of documents
7 produced directly by Texas Eastern has raised
8!questions about the proper use of those
j
9 j exhibits in this deposition, and what,
1 0 j exactly, is required by the Protective 1 1 | Order.
.
1 2 And a s I understand it, we are
1 3 deferring those issues until such time a s
14 anybody here can get a copy of the Protective
15; Order in front of us.
j
16! MR. KRAUSS:
I apologize for the
17] delay. I'
18j
Q.
" Dr. Hatton, did there come a
1 9! time when Monsanto decided that they would no
2 0 longer sellM C S - 1 5 3
to Texas Eastern?
21 A.
Yes, nor toanyone else.
2 2: Q . Was there anybody else that was
2 3: using M C S - 1 5 3 a t that time?
2 4. A.
I did not have the sales records , but
2 5 we had been
-- we had introduced it to a lot
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1 of people. It was out -- available to a lot
2 of people. Whether they were buying or not.
3 I don't -- I can't tell you that.
4 5 A.
Q . All right. I do n't keep sale s figures in m y
6 mind.
7 MR. HART: Can we go off the
8 record for a second? This is an objection to
9 form, but I don't want to waste the record
1 0 doing it .
.
1 1 (A discussion takes place off
1 2 the record.)
1 3 Q . Did you have any substantive
1 4 involvement in advising Texas Eastern that
1 5 this product would be withdrawn from the
1 6 market?
1 7 A.
I attended the meeting. I was less
1 8 actively involved in fire-resistant
1 9 industrial types of lubricants at that point,
2 0 and hydraulic fluids. But I -- I did come
2 1 back into the program and visit at Texas
2 2 Eastern .
2 3 Q . Were you involved in any <" *A strategical discussion o^ wI < i1 i ii xc/Nyv*c--i\xv>u. .l4"
2 5 possible alternatives to provide to Texas
l i
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1 Eastern a t the time that MCS-153 was
2 withdrawn?
3 M R . HART: I object to the
4 form. I'm sorry. Counsel
5 M R . DAVIDSON : Let me clarify.
6 also, that at the time t h a t I think you're
7 referring to, the pro duc t name had been
8 changed to a trad e n a m e k n own as Turbinol, and
9 it was no longer known as MCS-153.
10
M R . KRAUSS : Okay.
.
11 A.
We' re talk i n g -- your question refers
1 2 to the specific time that
it was taken --
1 3 withdrawn? 1 4 ! Q.
Well, in anticipation of the
1 5 : withdrawal .
1 6 I A.
No.
i
17; replacement i
i 8; Turbinols.
Iwas not products
directly involved for Pydrauls and
in
1 9 ! Q. Do you knowif there was ever
2 0 any thought to helping out Texas Eastern with
2 1 regard to the withdrawal, and providing
2 2 ; incineration or alternative fluids?
2 3 ' MR. HART: Objection to form.
24i A.
Those were management decisions, and X
2 5 was not necessarily involved.
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1 M R . DAVIDSON: Off the record.
2 (A discussion takes place off
3 the record.)
4
i 5 the
next
MR. KRAUSS: Exhibit.
Please mark that as
6
i
7 Bradford,
(Memo to T.L. G o s s a g e from dated December 15, 1971, Re:
C.L.
8 Santovac 1 and 2/Turbinol 153, Bates Nos. TEX
9 000797 through 000800 is marked Hatton-4 for
1 0 identification.)
1 1 MR. KRAUSS : So we have a clear
1 2 record, let me just state that we've marked
1 3 | an Exhibit as number 4. 14! Exhibit number 3, there are some
1 5 i issues pending whether or not it will be able 1 6 I to be used today, and we're going to go ahead
1 7 | anyway and 1 8 ! the r e c o r d
mark will
this one as number refl ect whether or
4. not
And we've
1 9 i used Number 3.
2 0 Q. Please review this document.
2 1 Exhibit.
2 2 A.
(The witness re views the document.)
2 3 Q Does E x h i bit number 4 refresh 2 4 your r e c o llection as t o your involvement in
2 5 the antic i p a t o r y w i t h d r a w a 1 of Turbinol 15 3
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86
1 from the market?
2 A.
Y e s , it d o e s .
3 Q . Who was C.L. Bradford?
4 A.
j
5 j at
the
Larry time.
h e was my direct supervisor
6 Q.
j
7 |I paragraph
I t refers to, in the this document refers to
first -- on
the
8 1 page of this Exhibit marked TEX 000798, which i
9 I believe are Monsanto's Bates numbers, or
10j stamp numbers for these documents, it refers,
1 1 to Texas Eastern as "our only customer for
1 2 Turbinol 153".
1 3 Was Turbinol 153 generally not
1 4 accepted by the other natural gas pipelines 15! f o r u s e ?
1 6 MR. HART: Objection to form.
1 7 A.
Well, purchasing customers, I'm sure
1 8 that was right . Texas Eastern was the only
1 9 customer a t that point.
2 0 Development activities had
2 1 continued when I was off the program for
2 2 awhile, with other potential customers.
2 3 Q . 0 n the next page of the Exhibit
TEX 000799, it refers to chlorine/bearing
2 5 problems .
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1 Do you recall what was meant by
2 that terminology a s you us e d it in this
3 document?
4 A.
Some f u 1 1 scale tests. and some v e r y
5 limited field data had s h o w n dirty system s
6 and chi o r i n a t e d material s of all s o r t s d i d
7 not 1 i V e well together . And it w a s c o n c e i v e d
8 by people out in the industry that this was a
9 problem. It did not show up in many -- many
1 0 tests. Very isolated circumstances, but
-
1 1 enough to make it a problem that had to be
1 2 attacked.
1 3 Q . Do you know if it was -- at
1 4 this time that it was general knowledge that
1 5 Texas Eastern knew that their product
1 6 contained PCBs?
17
MR. HART:
I object to the form.
1 8 Q. Turbinol 153 contained PCBs?
19
MR. HART:
I object to the form.
2 0 MR. DAVIDSON: Do you understand
2 1 the question?
22 A .
This is following the Earl Farmer
2 3 article where it was spelled out.
They must
2 4 have.
2 5 This was the -- Christmas/New
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1 Year season of '71, and I had been off
2 working on aviation fluids.
3 I was brought back into this
4 program and another program to provide the
5 best information within the company as to
6 what would be the requirements to carry out
7 the management decision to withdraw PCBs.
8 Q. Were PCBs withdrawn for other
9 uses before this date, December 13th, 1971?
1 0 A.
I was not actively involved in other,
1 1 withdrawals.
1 2 MR. HART: And I object to the
1 3 form of the question.
1 4 Q . But to your knowledge, were such
1 5 other products withdrawn from the market?
1 6 Other PCB containing products.
1 7 A.
Yes, they were. But I am not that
1 8 familiar with the chronology to say exact
1 9 dates .
2 0 Q . What - -
2 1 A.
And in fact, a t this same
2 2 Christmastime period, I was involved in
2 3 withdrawing Santovac 1 and 2 from the market,
2 4 and those were PCB containi n g fluids .
2 5 Q.- What were the end uses of
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Santovac 1 and Santovac 2?
A. Vacuum pump lubricants.
Q . When Monsanto made a decision to
withdraw PCB containing materials from the
market, did Monsanto make a distinction
between the end use application of the
liquid?
MR. DAVIDSON: Are you saying as
to whether it would be withdrawn, or how it
1 0 would be withdrawn?
11 MR. KRAUSS: Yes.
1 2 `MR. DAVIDSON: Is that what
1 3 you' re t a 1 k i ng about?
1 4 MR. KRAUSS: Yes.
15 A.
Yes. I know they did, but I'm not
1 6 awar e of all the ins and outs of that
1 7 d e c i sio n and implementation.
1 8 Q Do you know what the distincti
1 9 between the end uses was --
20 A.
No, I don't.
2 1 Q -- that was the basis for the
22 deci s ion?
23. A .
No .
2 4 Q Do you know if it was whether 2 5 not the a p p1 ication was a controlled usage
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1 versus a non-controlled use?
2 MR. HART: Objection to form.
3 A.
Those are very broad categories, and I
4 don't know that I can -- how to answer it.
5 i You obviously are going to
6 withdraw any product, market by market if you
7 have a multi-purpose product. Therefore
8 there has to be some sort of lineup.
9 Q. Do you recall if Monsanto made a
1 0 distinction between closed system and open .
1 1 system?
12
MR. HART:
Objection to form.
13| |
A.
I 'm not sure which we
-- the
1 4 | categories.
15! Q.
i6I which you
Do you wrote the
recall the purpose for two memos that make up
17I |
Exhibit
number
4?
1 8 i A.
Well, the purpose was to provide
1 9 ! management with the best guidance that I
2 0 could, and any pitfalls they might run into
2 1 in withdrawing Turbinol 153. That was the
2 2 purpose of the first memo, was to detail the
2 3 information.
2 4 And the second memo was to
2 5 devise a suitable work plan.
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1 MR. DAVIDSON: Okay. Let me
2 point out that the --
3 A.
Or program.
4
MR. DAVIDSON:
-- the second
5 memo was not authored by Dr. Hatton.
6 MR. PUPKE: The first page on
7 that, I believe, addresses that. The first
8 page of this Exhibit addresses that.
9 MR. DAVIDSON: I understand.
1 0 But this second memo is signed by C.L.
.
1 1 Bradford.
12
MR. KRAUSS:
I understand.
1 3 MR. DAVIDSON: There are
1 4 actually three memos; two are by Larry
1 5 Bradford, and one is by Dr. Hatton.
16
THE WITNESS :
Yes.
1 7 Q . Was your advice a s set forth
1 8 here in this memorandum given to Mr. Bradford
1 9 in anticipation of a particular meeting with
2 0 Texas Eastern?
21 A.
11 was supplied to Larry so that he
2 2 could go to management people and devise the
2 3 program .
2 4 Q. You mentioned earlier that you
2 5 did have some involvement in a meeting with
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Texas Eastern regarding the withdrawal. Do
you recall when that meeting was?
A. Well, it's the one that is given in
4 j Larry Bradford's work plan, or withdrawal I
5 plan as of the first of -- well, the 14th
6 day of January, 1972.
7 Q. Did you attend that meeting?
8 A.
Yes.
9 ( Q. Do you recall who else from
1 0 Monsanto a 11 ended that meet
11 A .
I k n o w for sure that
1 2 was with m e .
i
W e -- there was in attendance,
s 13 j also, a person from the local
sales office in
i
14| Shreveport, who normally called on the Texas
15 Eastern account. And I am not sure whether
16; -- you
know, there is -- a number of people
17| serve there, and I !
18|in '71, '72 here.
don't
know
who
was
there
19! I'm sure that if there were --
20 if -- these names are on call reports.
21 Q. Do you know how many people, all
22: told, from Monsanto attended?
2 3! A .
Well, I've named a t least three.
24: Q.Three?
25 A .
There may have been another. . .
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1 Q . Okay . How about a
2 M r . Frederiksen?
3 A.
He was the local representative.
4 Q . H e w a s the person --
5 A.
Yeah.
6 Q - - - t h at you referred to before.
7 A.
Yes.
8 Q . Okay. How about a Mr. Stegen ,
9 D . W . Stegen?
10 A.
Stegen.
1 1 Q . Stegen?
1 2 A.
Don was a sort of an area supervisor
1 3 in the marketing department. He would have
1 4 been John Frederiksen's superior.
1 5 Q . Do you recall who from Texas
1 6 Eastern attended the meeting?
1 7 A.
Well, a room full. A few more than in
1 8 here today.
1 9 Q. Was Mr. Fletcher still around
2 0 with Texas Eastern a t that time, do you
2 1 recall?
2 2 A.
I do not believe that Mr. Fie tcher was
2 3 present at this meeting. I believe that by
2 4 that point in time he was elsewhere within
2 5 Texas Eastern.
!, ,'
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1 Q. Do you recall what was told to
2 Texas E a s tern a t the meeting?
3 A.
Not in huge detail. But, we covered
4 at least several subjects, one of which was
5 the removal of the PCB containing products
6 from them, and from supplying them to them.
7 The other was a discussion of
8 ! alternate products that Monsanto could
9 provide for this same application, and --
1 0 Q. What were the other ultimate
1 1 products?
12 A.
-- many, many other subjects .
1 3 A t this stage it would appear
1 4 from my memo, d a ted - - that we just read,
1 5 that it was MCS 12 2 3
1 6 Q . How did MCS 1223 differ from the
17 I Turb i n o 1 15 3?
18| A,
MCS 1223 was a so-called pure
19! phosphate ester fluid, which means it
2 0 contained nothing, except phosphate esters
2 1 and minor amounts of additives .
2 2|
Q . Okay. Do you recall what else
23; what other topics were covered, other than
2 4i replacement fluids?
25 A.
Not in detail .
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Q . Was there any provision made
for -- or any means by which Texas Eastern
3 j could continue to purchase Turbinol 153 after
the date of this meeting?
A . I believe this was discussed and it
was handled by Larry Bradford.
Q . Do you know if Texas E a s tern was
given the opportunity to sign a hold harmless
9| agreement?
10 A.
I understand they were.
11 MR. HART: I object to the
1 2 form. You can go ahead .
1 3 MR. DAVIDSON: Go ahead and
1 4 answer.
15 A.
I understand that they were, yes.
1 6 Q . Do you know if Texas Eastern
1 7 sign t h at hold harmless agreement? .
18 A.
I understand they did not.
1 9 Q . Do you recall any reasons gi
2 0 by T e x a s Eastern - -
21 A.
No .
2 2 Q . -- a t the time, or what the
2 3 reason was that --
24 A.
No .
2 5 Q. -- they would not sign that
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1 agreement?
2 A.
I really did not handle that part of
3 the program. I was there as the technical
4 expert.
5 Q, Okay. Do you recall if Texas
6 Eastern attempted to purchase remaining
7 fluids outside the guise of the proposed hold
8 harmless agreement?
9 MR. HART: Objection to the
1 0 form.
.
11 A.
I --
1 2 MR. HART: I don't know what you
1 3 meanby guise
--
14 A.
No.
1 5 MR. HART: I don't know what you
1 6 mean by remaining. It's a very ambiguous
1 7 question.
1 8 MR. KRAUSS: Let me rephras e it,
1 9 then.
2 0 A.
Yeah.
.
2 1 Q . Do yourecall if Texas Eastern
2 2 attempted to purchaseTurbinol
153, despite
2 3 the
factthat they did not sign the hold
2 4 harmless agreement?
2 5 MR. HART: Objection .
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1 A.
I was not directly involved in that
2 kind of a negotiation.
3 MR. KRAUSS: Would you please
4 mark this a s Hatton Exhibit number 5.
5 (Call Report N q. 1 9 7 2 - 1 1 by R.E.
6 Hatton, dated February 1 1 , 1 9 7 2 , Bates Nos.
7 TEX 000879 through 000883 is marked Hatton-5
8 for identification.)
9
(ThisExhibit
is subsequently
1 0 withdrawn and remarked on page 107 of the
-
1 1 transcript a s Exhibit Hatton-6 . )
1 2 Q . You've been handed what's been
1 3 marked for ourpurposes today as Hatton
1 4 Exhibit number 5. And I'd like you to take
1 5 an opportunity to read it.
16 A.
(The witness reads the document . )
1 7 Q. Are you through reviewing the
1 8 document?
19 A.
Yes .
2 0 Q. Did you author this document?
2 1 A.
Yes.
2 2 Q . Did you author this document in
2 3 the regular course of your business a s a
2 4 Monsanto employee?
2 5 A.
Yes.
It was customary for people in
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1 the -- either technical marketing areas, or
: i
;
2 in the development department to prepare
3 summaries of the various visits we made.
4 This was the one to Texas Eastern, a s dated .
5 Q . Does reviewing this document
6 refresh your recollection with regard to
7 Texas Eastern attempting to purchase
8 additional fluid outside the mechanism of
9 the
10 A.
I didn't read it that carefully .
.
1 1 Q. -- hold harmless agreement?
1 2 MR. HART: I object to the form
1 3 of that question.
1 4 Q. I'll direct you to page 2 of
1 5 your memo, which is TEX 000316.
1 6 MR. HART: Counsel, I think
1 7 you've marked the wrong document . Exhibit 5
1 8 is numbered Bates number TEX 000315 --
1 9 A.
879 is the one I was reading.
2 0 MR. PUPKE: I have 879, also.
2 1 MR. HART: I'm sorry, 879
2 2 through 883.
2 3 MR. KRAUSS: Well, I certainly
2 4 have a diff erent one than you do. Let me get
2 5 the proper Exhibit. Why don't we go off the
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99
1 record.
2 (A discussion takes place off
3 the record . )
4 (There is a recess.)
5 (The Exhibit previously marked
6 as Hatton-5 bearing Bates Nos. TEX 000879
7 through 000883 is withdrawn.)
8 (Call Report No. 1972-1 by R.E.
9 Hatton, dated February 8, 1972, Bates Nos.
1 0 TEX 000315 through 000317 is marked Hatton -5.
1 1 for identification. )
1 2 Q . You've been handed what's been
1 3 marked for our purposes today as a remarked
14; Exhibit number 5 .
i
15 j
Did you author this document.
16! i
i
17| 1
Dr. A.
Hatton? Yes, I
did.
1 8 i Q. And did you author this in the
1 9 ! regular course of your business as an
2 0 , employee of Monsanto?
2 1 A.
22;
Yes, I did. Q . Does this document accurately
2 3 reflect the meeting that took place between
2 4 ; Texas Eastern and Monsanto on January 14th,
25 1972?
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1 MR. HART: I'll object.
2 A.
I f I put it on paper , it's what I
3 remembered a t the time I wrote the document,
4 not necessarily what I remember 3 0years
5 later.
6 Q . The document refers to General
7 Electric approval of a replacement fluid.
8 Why was it i m p o r t a n t or necessary to get
9 General Electric approval, if you know?
10 A.
The answer to this requires just a
.
1 1 little bit of background.
1 2 The general control of the
1 3 functional fluid and lubricant that is used
1 4 within mechanical equipment is generally
1 5 recommended and/or controlled by the maker of
1 6 the mechanical equipment.
They must satisfy
1 7 themselves that what they put in is usable .
1 8 Simple example is the lubricant
1 9 you use
in a n automobile. It's approved by
2 0 the maker of the automobile .
2 1 The turbines that Texas Eastern
2 2 was using a t this time were produced b Y
2 3 General Electric in the gas turbine
2 4 department, and therefore it was very
2 5 important, in fact, necessary to get either a
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1 direct approval from General Electric, or a
2 no objection statement.
3 Q . With respect to the Turbinol
4 153, was it approved, or was it not objected
5 to by General Electric, if you know?
6 MR. HART: Objection, compound .
7 A.
We had approval to use it.
8 Q. It was approved.
9 A.
Yes.
1 0 Q. What about -- is an analogous .
1 1 situation with the centrifugal compressor
1 2 manufacturers? Is there an analogous
1 3 situation that they have to provide approval?
1 4 A.
Either approval or no objection, yes.
1 5 Q. Okay. And with respect to the
1 6 Turbinol 153, do you recall if -- or do you
1 7 know if Clark Compressors approved or did not
1 8 object?
19 A.
I do not recall the -- supply -- a
2 0 machinery supplier, by supplier, who approved
2 1 and who didn't. Who said it was all right
2 2 and who didn't.
2 3 Q. Okay. Does page 2 of this
2 4 Exhibit, which is TEX 000316, refresh your
2 5 recollection regarding Texas Eastern's desire
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10 2
1 to purchase additional fluid before the hold
2 harmless agreement would be in effect?
3 M R . HART: Could you say wh i c h
4 paragraph yo u ' r e referring to?
5 M R . KRAUSS: The top block,
6 starts with time of depletion, and then the
7 next sentence . - - next two sentences .
8 i MR.HART: Thank you. Can I
9 hear the pending question back?
1 0 (The pending question is read .
1 1 back by the reporter.)
12 A.
Yes .
13 j
Q . Do you have an understanding why
1 4 | Texas Eastern desired to !
1 5 - - or additional fluid?
purchase
remaining
16j A.
I did not negotiate this part of the
1 7 discussion with them. This was primarily
1 8 Larry i!
19
Bradford. This
Call
Report
represents
the
2 0 development department -- or the -- I
2 1 should say the marketing department. And
2 2 : Larry and I
i
2 3 I wrote the
attended a s report.
representatives ,
and
2 4 Q . Do you know if Mr. Bradford is
2 5 still alive?
j ; !
i
;
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10 3
1 A.
I do not know, no. I haven't heard
2 from him in years .
3 Q. You don't know if he's still
4 with Monsanto?
5 A.
I know he is not with Monsanto . He
6 changed companies before I retired.
7 Q. Do you know where he resides?
8 A.
I do no t .
9 Q . Again, on page 2 of Exhibit 5,
1 0 the first full paragraph , it's the second
.
1 1 paragraph on the page refers to the,
1 2 "environmental situation." Do you have an
1 3 understanding of what you meant by the
1 4 environmental situation?
1 5 A.
I did not make a presentation on this
1 6 section. This-was handled primarily by
1 7 Larry. But I did understand that there were
1 8 environmental concerns, and that the products
1 9 were being withdrawn.
2 0 Q. To the best of your
2 1 recollection, at the meeting were
2 2 environmental concerns of Texas Eastern
2 3 discussed?
OL, *A4 A.
I do not remember.
2 5 MR. KRAUSS: Off the record .
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10 4
1 (A discussion takes place off
2 the record. )
3 MR. DAVIDSON: On behalf of
4 Dr. Hatton, he and I agree that we can be
5 bound by the terms of the Protective Order
6 that has been presented t o us here today, to
7 respect these documents a s confidential.
8 MR. HOOK: Off the record.
9 ( A discuss ion takes place off
1 0 the record,)
.
1 1 Q . Dr. Hatton, I believe when we
1 2 were discussing Exhibit number 4, that you
1 3 mentioned that you were not particularly
1 4 involved in the Turbinol 153 program at
1 5 that time that you were asked to participate
1 6 in it --
1 7 | A. I
18 '
Yes. Q.
-- is that a fair summary?
1 9 A.
Yes.
2 0 Q. After the time that Turbinol 153
2 1 was withdrawn from the market , did you then
2 2 become substantially involved in the
2 3 marketing of a replacement fluid to Texas
2 4 Eastern?
2 5 A.
During the introduction of the fluid.
i
;
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10 5
1 and s o m e o f the early activitie s , I was
2 i n v o 1 ved, a 1 ong with m y other j o b s , as a
3 as a p e r s o n to make v i sits and to m a i n t a i n a
4 conti n u o u s c ontact. B u t it was not a f u 1 1
5 time job.
6 Q . And what sort of a c t i v i ties w ere
7 you i n v o 1 ved in with r espect to the
8 repla c e m e n t fluids?
9 A.
M o n s a n t o had a program under way f o r a
1 0 n u m b e r of Y e a r s to exp and their line o f 1 1 f u n c t i o n a 1 f 1uid s to a new type , a n e w c 1 a s s
1 2 of p h o s p h ate esters , w hich they were
1 3 i n t e n ding t o market so me day as comp a n i o n
1 4 p r o d u c t s t o the Pydrau Is and so me of the s e
1 5 other thi n g s that cont a i n E C B s .
1 6 That prog ram was s p e e d e d up r and 1 7 out o f it t h en came th ese so-ca lied s t r a i g h t
1 8 or p u re p h o s phate este r fluids , one of w h i c h
1 9 was e vent u a 1 1 y d e s i g n a ted a s a T u r b i n o 1 .
20 21 A.
Q Okay. Th i s work was o bviously being don e by
2 2 r e s e a rch , pr i m a r i 1 y , a t that p o i n t .
2 3 Q Do you re call ever v i s i ting
2 4 ; Texas E a s ter n at the t im e that they were
2 5 s e e k i n g a r e placement fluid for t h e i r
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1 06
1 Turbinol 153?
2 MR. HART: Objection to form.
3 A.
In Exhibit 5 it was indicated that we
4 would present data to them on the phosphate
5 ester fluid, and I was asked to do that.
So,
6 I obviously went back to talk to them.
7 Q . Do you recall when you went
8 back?
9 A.
Within a relatively short period of
1 0 time.
.
1 1 (A discussion takes place off
1 2 the record.)
1 3 Q . Do you recall what sort of
1 4 concerns Texas Eastern had regarding the
1 5 replacement fluids?
1 6 MR. HART: You mean what
1 7 concerns Texas Eastern may have expressed, or
1 8 any representative of Texas Eastern may have
1 9 expressed?
2 0 MR. KRAUSS: Yes. Concerns --
2 1 Q. What sort of issues would be
2 2 involved in changing out from Turbinol 153 to
2 3 a replacement product, on behalf of Texas
2 4 Eastern?
2 5 MR. HART: Objection.
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1 A.
Now, let's back up and answer your
2 first question; what concerns were expressed
3 as what they wished to see in the product.
4 This included such things as
5 approvals by the proper people; a complete
6 set of our laboratory data a s compared to
7 other products, both ours and the competitive
8 products. General properties, that type of
9 thing .
1 0 Q . Okay. What about compatibility,
1 1 with the Turbinol 153?
1 2 MR. HART : Obj ection to
1 3 Q. Would that be an issue? 1 4 MR. HART: Obj ection to
1 5 A.
Well, compatibility with exis
1 6 fluids in s y stems is always an issue
1 7 was d.i s c u s s e d .
1 8 Q. Do you recall whether T 19s Eastern was seeking the replacement fluid as
20 | merely a fluid to top off the existing tanks
2 1 in use a t their stations , or I should say,
2 2! lubricating oil tanks , or whether or not they
23 desired to have a complete change out? . i
24 MR. HART: Objection to form.
25 Ambiguous , compound, lack of foundation .
i
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1 08
1 A.
I do not remember being fully aware of
2 what they were -- how they were going to
3 handle that.
4 Q . Would there have been any
5 problems , or would there have been any
6 concerns if Texas Eastern had a desire to
7 merely buy the replacement fluid a s a topping
8 off fluid, a s opposed to one that would be
9 completely changed out of their system?
10
MR. HART: Objection.
.
1 1 MR. DAVIDSON: Well, concerns by
1 2 who?
1 3 MR. KRAUSS : By Texas Eastern .
1 4 MR. HART: I restate my
1 5 objection
1 6 MR. DAVIDSON: I object because
1 7 he has no way of knowing what was in Texas
1 8 Eastern's mind.
19 Q 2 0 Monsanto?
What about concerns about
2 1 MR. HART: Concerns about what?
2 2 Can we have the question back?
23 A .
I need a specific question .
2 4 MR. KRAUSS: Would you read back
2 5 the question, please.
1
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!
R. E. Hatton
1 09
1 (The following question is read,
2 back by the reporter:
3 "QUESTION: Would there have been
4 any problems, or would there have been any
5 concerns if Texas Eastern had a desire to
6 merely buy the replacement fluid a s a topping
7 off fluid, as opposed to one that would be
8 completely changed out of their system?") 9 MR. HART: You want to rephrase
1 0 the question now?
.
11 Q. 1 2 direct.
Why don't I be a little more
1 3 11 14; using
their
Did Monsanto r replacement flu
1 5 topping off fluids?
1 6 MR. HART: I o
1 71
j
18'
Q. Do you recall?
MR. HART:
-- object to your
1 91 use of the word merely.
20 A.
Somewhere in this report I think it
2 1 suggests that they drain and refill with new
22: fluid.
2 3,
Q.
Somewhere in which report?
24 ( A discussion takes place off
25 the record.)
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Hatton
110
1 A.
Okay. Something I just read. But
;
2 that ' s b a s i c a 1 1 y it. 3 (Call Report No. 1972-11 by R.E. 4 H a 11 o n , dated February 11, 1972, Bates Nos. 5 TEX 000879 th rough 000883, is marked Hatton-6 6 for i d e n t i f i c a t i o n . )
|;
;'
j !: !
;
' !! ' !
7 Q You've been h anded what's been 8 mark e d for o u r purposes he re today as Hatton 9 E x h i bit 6 , w h ich is a memo randum which was
j
j I !
1 0 prod u c e d by M onsanto to th e carriers.
.
11
The numbers a re TEX 000879
;
1 2 thro ugh TEX 0 00883.
13 A.
I thin k I had read this in a previous
1 4 des ignati on .
1 5 Q . That's the -
16 A. .
It's the same one.
1 7 Q . -- Exhibit th a t was --
18 A.
Yes.
1 9 0 . -- given to y ou before --
20 A.
Yes.
21 22 A.
Q - -- and was wi t h d r a w n . That's correct.
2 3 Q . Do the last t wo sentences
2 4 r e f r esh, your recollection regarding any
2 5 a d v i c e from Monsanto regar ding whether to
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n o 3
1 pletely drain their s y stems , or to jus t
2 top off their systems?
3 MR. HART: I o b j e c t to the
4 for m. The document doesn ' t s a y "complete iy 5 d r a in".
6 The document says , "drain uni t s
7 a s well a s possible . "
' 8
MR. DAVIDSON :
G o ahead.
9 A.
The wording of thi s -- these last t w
1 0 sen tences is what we used in a n y chan g e o u t s-
1 1 fro m fluids to fluids.
1 2 Q. So, when you say "that w e us e d
1 3 i n a change out from flui d to fluid, " are y o
1 4 say ing that Monsanto had some sort of a
1 5 p o s ition on this? Was t h at a corpora t e
16 pos ition?
17 A.
I f somebody was us ing a petrol e u m oil
1 8 i n his system and wanted to s h i f t to a
1 9 fir e-resistant fluid, thi s is basical 1 y the
2 0 inf ormation we gave him a s far as, he ought
2 1 t o drain the unit a s well as p o s s i b 1 e b e f ore
2 2 ; h e put in the new fluid.
2 3 - And the comp a t i b i 1 i t y s e n t e n c e s 2 4 and statements ahead of that. of what w e
2 5 w o u Id normally do and so on, i n f o r m a t ion w e '
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1 be looking for is what we would do any time
2 anybody changed from any lubricant or
3 hydraulic fluid over to one of our
4 fire-resistant fluids .
5 Q. And what's the reason for that
6 position?
7 MR. HART: Wait a minute .
8 A.
Because if you do not have compatible
9 materials , you end up with mixtures . And
1 0 predicting the performance, and life, and
.
1 1 usabilities of mixtures is a much more
1 2 difficult job than trying to predict on new
1 3 fluids. Therefore, you must know something
1 4 about the mixture .
1 5 Q. Okay. In this particular
1 6 instance, was there any other reason besides
1 7 performance?
18 A.
Yes. The last sentence says that
1 9 primarily on ecology considerations.
2 0 Q. And what did you mean by ecology
2 1 considerations a t the time that you wrote
2 2 this memorandum?
2 3 A.
Basic reason for withdrawing the
2 4 polychlorinated biphenyls was because of
2 5 getting in .the environment.
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113
1 Q . Was there any specific concern
2 with respect to Texas Eastern's use of this
3 fluid that would have raised ecology
4 considerations?
5 MR. HART: Objection to form.
6 MR. DAVIDSON: You mean
7 different from any other PCB user? You're
8 distinguishing between all --
9
MR. KRAUSS:
Texas Eastern's use
1 0 of Turbinol 153 and the change out here.
.
1 1 MR . DAVIDSON: -- all other
1 2 uses?
1 3 MR. HART: I object to the form
1 4 of the question
as stated.
15 A.
I f you mean was there anything
1 6 different about this recommendation than we
1 7 made to other people? The answer is no.
1 8 This recommendation was made to all change
1 9 overs .
20
Q.
Yes. Was there any special
2 1 consideration or special concerns with
2 2 respect to Texas Eastern, if you know?
2 3 A.
Not that I expressed, that I can
2 4 remember .
2 5 Q. Do you recall if one of your
I
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1 14
1 reasons for recommending the drainage of the
2 units as well as possible would be to prevent
3 Texas Eastern from operating with a lubricant
4 | containing
i 5
PCBs for years to come? MR. HART: Objection to
form.
6 A.
The reason for suggesting draining the
7 system completely was that the new prod u c t
8 ; was a new I
9 | Electric,
product being approved by Gen era based o n their testing . And t h a
10! in order to get the best chance pos s i b 1 e o
1 1 performing in the field. we wanted as m u c h
1 2 that fluid as possible in the machine a s
1 3 possible. That was the performance reason
1 4 for suggesting it.
.
1 5 Q. But, did you advise against
1 6 | operating with a lubricant i
1 7 | for years to come?
containing PCBs '
1 8 'i 19: A.
MR. HART: I object to the form. I -- that statement I -- I -- I
2 0 don't know.
2 1 MR. KRAUSS: Will you please
2 2 ; mark this as Hatton-7 .
2 3 ' (Memo to Files , "Subect: File
2 4 3.20 - Monsanto Turbine Lubricant MCS 1223"
2 5 by A.B. Jarnagin, dated February 4, 1972,
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115
1 Bates Nos. 000531567 through 000531568,
i
2 marked Hatton-7 for identification.)
is
3 MR. HART: Off the record.
4i
| 5 marked
Q. for
You have been handed what was our purposes today a s Hatton
6 Exhibit number 7, which I'll represent to you
7 I was produced by Texas Eastern to the
8 ;| carriers. 9!
MR. KRAUSS: It's a Texas
1 0 | Eastern document, and it's my understanding j
1 1 |Ii that this is going to be marked as i
1 2 | protected.
13' |
1 4 stamp
I t bears Texas Eastern ' s Bates numbers 000531567 through 531568.
1 5 A.
Yes.
1 6 Q. Based on your review of this
1 7 document, do you understand it to be a
1 8 summary of the February 4th, 1972 meeting
1 9 that is also the subject of Hatton Exhibit
2 0 number 6?
2 1 MR. HART: I object to the
2 2 form.
23
MR. DAVIDSON :
I object, too.
I
2 4 mean, this is not something he authored, and
2 5 it is what it says it is, I suppose.
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1 MR. KRAUSS: Well, I said based
2 on his review.
3 Q. This document appears to be a
4 Texas Eastern memorandumsummarizing the
5 February 4th,1972 meeting,
which is also the
6 subject of Hatton Exhibit number 6.
7
MR. HART:
The document speaks
8 for itself.
9 Q. Does numerated paragraph Number
1 0 3 refresh his recollection as to advising
.
1 1 Texas Eastern against operating with a
1 2 lubricant containing PCBs for years to come?
1 3 MR. DAVIDSON: I'm going to
1 4 enter an objection, because I don't think you
1 5 can refresh your recollection with a document
1 6 he didn't create or have anything to do
1 7 with.
1 8 You've asked him, and refreshed
1 9 his recollection with his document
What
2 0 somebody else remembered about the meeting is
2 1 just totally irrelevant to what he may have
2 2 recollected.
2 3 MR. HART: And I want to state a
2 4 further point for the record, that there is
2 5 no indication in this document that that
ji
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1 17
1 concern was raised by anybody other than
2 Texas E a s tern employees.
3 Q. Well, did you attend the
4 February 4th, 1972 meeting with Texas
5 Eastern?
6 A.
Obviously.
7 Q. Well, apparently --
8 MR. DAVIDSON: Just answer yes
9 or no.
1 0 MR. KRAUSS: Apparently some
1 1 Counsel doesn't find it so obvious.
12
THE WITNESS:
Okay.
1 3 Q . Do you recall advising Texas
1 4 Eastern against operating with a lubricant
1 5 containing PCBs for years to come?
1 6 MR. HART; Objection to form.
1 7 A.
The statement made would have been
1 8 that w e wan ted to prevent PCBs from gettin g 1 9 into the e n vironment. The interpretation o f
2 0 that. a s T e x a s Eastern put it, is here.
2 1 MR. HART: I'm going to move t o
2 2 strike as nonresponsive to the question, a n d
2 3 elaborate my concern about whether that is a
2 4 fair characterization of the document.
2 5 I n any event, the witness was n ' t
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R . E . Hatton
1 a s k e d to c h a
1 18
2 t 0 s trike .
3 (Call Report - Organic Division
4 j to C . L . Bradford from John G. Frederiksen,
5 date of call , February 4, 1972, Bates Nos.
6 TEX 000876 through 000878 is marked Hatton -8
7 for identifi cation.)
8 A.
(The witness reads the document . )
9 MR. DAVIDSON: Okay.
1 0 Q . Well, you've been handed what f S1 1 been marked as Hatton Exhi bit number 8. And
1 2 j have you reviewed it?
13 ! A .
Yes.
14 j
Q
A 1 1 right .
D o you recall
1 5 | advising Texas Eastern that i t would probably
1
16 be possible to use M C S 12 2 3 by adding it to
17| Turbinol 153 as a top off material, but that I
18 i from an environmental standpoint it would be
191 to their advantage to change the materials
20 out completely?
21 A.
What is said here by John Frederiksen
2 2 from his report of the meeting, same meeting
23, that we've already covered in Exhibits 6 and
24 7, that is the statement that was made. And
2 5 it certainly reflects what I remember .
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1 19
Q . And who is -- I think you
testified earlier that Mr. Frederiksen was a
local sales representative?
A. Yes. And you will note if you will go
back that he is listed as an attendee on both
the Exhibits I just cited. -
Q . Looking back now a t Hatton1 2
8 E x hibit numb e r 6 , there is a 1 ist of people
9 w h o were pre sent for Texas Eas tern.
1 0 D o you recall wha t Mr. Means'
1 1 po sition was a t the time that this meeting
1 2 t o ok place? D o you know what it was?
13 A.
No, I d o not recollect a Mr. Means .
1 4 Q D o you know what any of these 1 5 p e ople being 1 i s ted as present for Texas
1 6 E a stern, what their positions were a t the
1 7 t i me of the meet i n g ?
18 A.
I don't know what their titles were,
19' but I know that Walter Woods and Buck
2 0 Jarnagin were in the engineering department
2 1 primarily . And I don't know what division of
2 2 engineering, but concerned with lubricants .
2 3 And I believe that Bill Hartman
2 4 was concerned with the actual station
2 5 maintenance, and operation and scheduling.
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12 0
1 and that type of thing .
2 Q Do you rec all a t that meeting 3 w h e t h e r Mr . Woods expre ssed a desire to know
4 the effect s of Turbinol 1223 on the land if
5 i t is s p i 1 led?
6 A. 7 8 A.
Yes Q . Do you rec I ' m -- it is in dicated that here --
9 t h a t way. and yes, he d i d .
1 0 And at a 1 ater date we supplied,
1 1 the p h o s p h ate ester dat a that was available,
1 2 S t . Louis .
1 3 Q Do you hav e an understanding as 1 4 t O why he would have t h a t particular concern
1 5 with respe c t to Turbino 1 1223?
16
MR. HART;
I didn't get the
17; tense. Counsel. |
1 8 i understanding at
Did the
he have such a n ti me? Does he have
an
1 9 understanding today?
2 0 MR . KRAUS S : Does he have a n
21 understanding today.
22 A .
Do I have a n und erstanding? How was
23 the sentence worded?
24 Q. Did you ha v e a n understanding a t
2 5 the time that you were a t this meeting on
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1 February 4th, 1972, why Mr. Woods would have
2 such a concern regarding the specific effects 3 of Turbinol 1223 on the land if it is
4 spilled?
5i A.
! 6! just
Yes. I been told
could understand that he could no
it. He had longer get
7 I the lubricants that he was using because of
8 e n v i ronmental concerns. And one of the fir s t
9 q u e s t i o n s that would pop in anybody ' s mind
1 0 would be. what is the new product goi n g to b.e
1 1 like in that respect?
1 2 Q Do you know if Mr. Woods 1 3 e x p r e s s e d any particular incidents th at Texas
1 4 East e r n m a y have had that would im p a c t on
1 5 e n v i r o n m e n t a 1 effects?
16 A. 17
No -
MR. HART: Objection.
18 A.
I don't remember.
1 9 Q In the appl ication of Tu r b i n o 1 2 0 15 3 as it was used by Texas Eastern, would i t
2 1 have been used up?
2 2 i MR. HART: Are you done with the
23. ques t ion?
2 4 MR. KRAUSS: Yes.
2 5 MR. HART: I object to the
: ;
1 :
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12 2
1 form.
2 A.
I do not remember specific data.
3 However, any time you use a fluid in a system
4 there is some use, some consumption of
5 material .
6 Q . And how is this material -- how
7 would a material like this be consumed?
8 A.
Mostly in terms of leakage, untight
9 joints, bad seals, things such as this.
1 0 Q . Bad seals where, if you know?
1 1 MR. HART: Objection to form.
12 A.
Pump shafts , rotating machinery,
1 3 statics , seals in ordinary piping .
1 4 Q . The seal oil system itself on a
1 5 centrifugal compressor?
1 6 MR. HART: I object to the
1 7 beating that you're doing throughout this
1 8 deposition. Counsel . This is not a n adverse
1 9 witness .
2 0 MR. PUPKE : Is there a question
2 1 pending?
22
THE WITNESS :
Yeah.
2 3 MR . KRAUSS : Yes, there is.
2 4 ( A discussion takes place off
2 5 the record between the wit ness and his
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12 3
1 attorney. )
2 A.
My answer to this is that any system
3 that has any potential opening will have some
4 leakage at some time or other.
5 Q. Do you have an understanding as
6 to what would be - - within a usage in a
7 centrifugal compressor usage of your Turbinol
8 153, what would be a normal rate at which the
9 Turbinol 153 would be consumed?
1 0 A.
I do not have that kind of data.
-
1 1 Q. Do you know if the consumption
1 2 of 11,000 gallons of Turbinol 153 over a six
1 3 month period would be excessive?
1 4 MR. HART: I object to the form
1 5 of the question.
1 6 MR. DAVIDSON : I object.
17 A.
That - -
1 8 MR. DAVIDSON: That's --
19 A
In order --
20
MR. DAVIDSON :
that ' s just
2 1 too much of --
2 2 A.
I n order that --
2 3 MR. DAVIDSON : Depends on how
2 4 much machinery you're talking about, how
2 5 long, how far, how big the -- how bi g the
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12 4
1 reservoires are, and all that --
2 A.
How many hours they operated, what
3 have you.
4 MR. KRAUSS: Why don't we take a
5 quick break, please.
6 (There is a recess.)
7 MR. KRAUSS : Would you please
8 ! mark this a s the next Exhibit .
9 (Call Report - Organic Division
1 0 to Gumming P a t o n from John G. Frederiksen, .
1 1 Date of Call July 2 4 , 1 9 7 2 , Bates Nos. TEX
1 2 000897 through 000898 is marked Hatton-9 for
1 3 | identification.)
i
14I
Q. Dr.Hatton,
you've been handed
1 5 what's been marked for our purposes today as !
1 6 Hatton Exhibit number 9. This appears to be
1 7 | a Call Report referencing a July 24th, 1972
1 8 call by Monsanto on Texas Eastern.
1 9 A.
Yes.
2 0 Q. Do you have an understanding -
2 1 I'm sorry. Have you reviewed this document?
2 2 ' A.
Yes.
23 ;
Q.
Do you have anunderstanding
as
2 4 to who would have prepared a document such as
2 5 this within Monsanto?
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12 5
1 A.
It w a s a standard Call Report by the
2 mar < e t i n g d e partment, and the author would be
3 the s a 1 e s m a n i n the upper right-hand corner.
4 Q And in this case that ' s J . G .
5 Freder i k s e n ?
6 A.
Yes.
7 G - And would he h a v e p r e p a red this
8 i n the o r d i n ary course of bus i n e s s ?
9 A.
Yes.
10 11 A.
Q 0 f Monsanto? All c alls were covered by a r eport .
1 2 Q Wer e documents s u c h as this Call 1 3 Hep ort m a i n t a i n e d in the ordi nary c o u r s e of
1 4 bus i n e s s by M o n s anto, and mai n t a i n e d
1 5 s o m e w h ere in f i 1 e s ?
16 A.
I ass u m e s o .
17
I 18I A.
0 Who was Gumming Baton? C u m m i n g P a t o n was in the mark e t i n g
1 9 ! department. I think a t this time he headed
2 0 up the group I was in.
21 22i A.
Q And who is J . A r mentor? He w a s t h e one who too k S t e g e n ' s place
2 3 . out o f H o u s t on a s Frederiksen ' s s u p e r v i s o r .
2 4 0 . D o you recall th is v i s i t with
2 5 Tex a s Easter n ?
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12 6
1 A.
After having seen this document, yes.
2 Q . Do you recall Texas Eastern
3 representing to you that they had used 11,000
4 gallons of your Turbinol 153 in a six month
5 period?
6 A.
I did not remember that today . I read
7 it here.
8
Q.
Youmentioned earlier that
there
9 is always some amount of use of a fluid
1 0 within a system.
.
1 1 With respect to Texas Eastern ' s
1 2 application, do you have any knowledge as to
1 3 where the used fluid would go?
1 4 MR. DAVIDSON: I'd like to
1 5 reiterate on the record that Dr. Hatton has
1 6 not been des ignated a s any sort of expert, or
1 7 even knowledgeable with respect to the
1 8 system-, or the operation of the system, or
1 9 the results of the use of the fluid in the
2 0 system a t Texas Eastern.
2 1 MR. HART: I, too, would like to
22: object to the form of that question, I think
2 3. it's extraordinarily ambiguous .
;
2 4 Q . Dr. Hatton, I'll take a n answer,
25 please.
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12 7
1 A.
I f you're asking if I was surpris e d a t
2 the time, I do not recollect whether I was o r
3 not . And I was not familiar enough with all
4 o f the units in operation to know where i t
5 would have gone.
6 Q . Do you recall W alter Woods
7 bringing up a question of what responsibility
8 Monsanto would take if the EPA told Texas
9 Eastern to stop using Turbinol 153
1 0 immediately?
1 1 A.
I have a vague recollection of Walter
1 2 asking questions . Such questions a t this
1 3 period of time were always referred back to
1 4 the group within Monsanto that was handling
1 5 the P C B .
1 6 Q. And what was the group within
1 7 Monsanto that was handling it?
1 8 A.
See, I think this one would have gone
1 9 directly from me to Bill Papageorge. I'm not
2 0 exactly sure of that --
2 1 Q. Well - -
2 2 A.
-- because -- you know, it was
2 3 actually a group of people .
2 4 Q. Yes.
2 5 A.
But the questions that I got from the
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12 8
1 field would have been referred back to this
2 group who were working on the PCB situation.
3 Q. What was Mr. Papageorge ' s
4 position, do you know?
5 A.
Some -- he headed up a good deal of
6 the coordination effort that was required.
7 Information collecting, all of this sort of
8 thing were handled through one office, and he
9 was in charge of that office. I do not
1 0 remember his title.
.
1 1 Q . 0 n the second page it indicates
1 2 a list of future actions, and one of the
1 3 future actionsstates establish
Monsanto ' s
1 4 position on "ETA/PCB? ASAP" . Are those your
1 5 initials next to that - -
1 6 A.
Yes.
1 7 Q. -- future action?
1 8 A.
Yes.
1 9 Q. And does that designate you to
2 0 be responsible for that future action?
2 1 A.
Theaction
a s stated was not my
2 2 responsibility . My responsibility was to
2 3 refer i t to the proper people ASAP. And that
2 4 I did o n return to St. Louis . 2 5 Q ., And would the communication back
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1 to Texas Eastern regardingMonsanto's
2 position also have been through you?
3 A.
No.
4 Q. Who would that have been from,
5 do you know?
6 A.
It could have been -- I don't know
7 who replied to this particular inquiry.
8 Normal procedure would have been
9 for either Bill Papageorge to reply, or to
1 0 relay the reply back to the field salesmen t-o
1 1 take in to the customer.
1 2 MR. KRAUSS: Mark this as the
1 3 next Exhibit please.
1 4 (Call Report No. 1 9 7 2 - 2 3 by R . E .
1 5 Hatton, dated July 2 4 , 1 9 7 2 , Bates Nos. TEX
1 6 000866 through 000869 is marked Hatton-10 for
1 7 identification.)
1 8 Q . Dr. Hatton, you've been handed
1 9 what's been marked for our purposes today as
2 0 Hatton Exhibit number 10.
2 1 Did you author this document?
2 2 A.
Yes.
2 3 Q . And did you author this in the
2 4 ordinary course of business as an employee of
2 5 Monsanto?
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130
1 A.
Yes.
2 Q. Were records such as this
3 maintained by Monsanto in the ordinary course
4 of its business?
5 A.
I assume so.
6 Q . Did you have a chance to
7 adequately review this?
8 A.
Pretty well.
9 Q . Okay. 0 n the top of page 3,
1 0 which is document TEX 000868 --
.
11 A.
Yes.
1 2 Q A t the end of the f i r s t 1 3 r a g r a p h there i t mentions that , "It is
1 4 eir -- " and I b e 1 ie v e it means Texas
1 5 stern ' s "pres e n t intention to continue to
1 6 operate with Turbinol 153, moving it from
1 7 station to station until it is essentially
1 8 all consumed . "
1 9 Do you have an understanding of
2 0 what you meant by "essentially all consumed"?
21 A.
I'm not absolutely sure what I meant
2 2 by that phrase . But I think it meant until
2 3 the supply was insufficient to lubricate a
2 4 turbine.
2 5 Q . And this is after the date that
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1 Monsanto withdrew Turbinol 153 from the
2 market; is that correct?
3 A.
Yes.
4 Q . Now, you testified earlier that
5 Turbinol 153 is very stable, oxidatively
6 stable, thermally stable?
7 A.
Yes.
8 Q . Do you have an understanding as
9 to where Turbinol 153 would go if it was.
1 0 "consumed"?
1 1 MR. HART: I object to the
1 2 form
1 3 MR. DAVIDSON: Well, I think he
1 4 just told you that he's talking consumed the
1 5 4 9,0 00 gallons they had on hand. Isn't that
1 6 what he just s aid?
17
MR. KRAUSS: Right.
1 8 Q. But where would it end up after
1 9 it was consumed, if you know?
20 A.
I do not know Texas Eastern ' s
2 1 housekeeping and maintenance practices.
2 2 Q . Did you find it unusual that
2 3 this very stable compound, which was marketed
2 4 for its stability was being, "consumed"?
2 5 MR. HART: Objection to form.
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1 A.
I f you mean is it normal for products
2 to be depleted in use in a piece of
3 machinery, then the answer is no, I'm not
4 surprised . Because it is true that machinery
5 does manage to use up fluid by leakage, by
6 foaming, by maybe air containment, by many
7 different schemes .
8 And the other products that
9 Monsanto marketed a t this time for hydraulic
1 0 applications and others were also in this
.
1 1 class, and very stable materials, but our
1 2 customers kept buying more.
1 3 Q . I f it' s very stable and it was 1 4 not being oxidized -- do you know if it was
1 5 being oxidized within Texas Eastern ' s
1 6 application?
1 7 MR. HART: I object to the
1 8 form. I think it's -- I gather. Counsel ,
1 9 you withdrew the first part of that question
2 0 and then --
2 1 MR. KRAUSS: I did.
2 2 MR. HART: Okay.
2 3 Q. Do you know if Turbinol 153 was
2 4 being oxidized in Texas Eastern's
2 5 application?
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1 A.
Over a period of time samples of used
2 lubricant were examined, and they certainly
3 did not indicate any large degree of
4 oxidation .
5 Q . Do you know if Turbinol 153 was
6 being vaporized in the application of Texas
7 Eastern?
8 MR. DAVIDSON : Again, Counsel ,
9 he's not offered a s a n expert on what was
1 0 happening on the Texas Eastern pipeline
.
1 1 system, and in their compressors, and on
1 2 their turbines. And he's already told you
1 3 that he was not familiar with their
1 4 housekeeping and the operation of their
1 5 system.
1 6 I think you're barking up a tree
1 7 that's already been answered.
1 8 MR. KRAUSS: Well, it's my
1 9 understanding , and I don'' t wish to become
2 0 hostile here. by any stretch of the
2 1 imagination.
2 2 But it's my understanding that
2 3 Dr. Hatton has a large degree of familiarity
2 4 with the system because he was involved in
2 5 developing the fluid that would be used in
t
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1 the applications. And I'm just trying to
2 explore that area.
3 MR. DAVIDSON : Well, I don't
4 mean to -- if I did, I didn't mean to sound
5 hostile, either.
6 But I think from the very
7 b e g i n n i n g this morn i n g Y ou've been told that 8 what h e knew w a s w h a t h e was told about the
9 r e q u i r e m e n t s of the s y s t e m , and so m e
1 0 observations that he made. The questions
1 1 you're asking seem to me to go to a fairly
1 2 intricate knowledge of how it operated, and
1 3 what its problems were, and where it leaked,
1 4 if it did. Questions that would be more
1 5 appropriately directed to people at Texas
1 6 Eastern who have that knowledge. That ' s my
1 7 point .
1 8 MR. KRAUSS; Okay. Let me --
1 9 MR. DAVIDSON: Go ahead and
2 0 answer it, if you can.
2 1 A.
Well, my major concern was in
2 2 establishing the requirements of the
2 3 lubricant in terms of properties, performance
2 4 and so on, not in monitoring actual units to
2 5 see what happened to them in use.
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1 Q. All right . But, with the
2 knowledge that Texas E a s tern has given you;
3 what their application is going to be, and
4 the requirements of their fluid, do you know
5 if it was desirable to them to have one that
6 would not vaporize in their system?
7 MR. HART: Objection to the
8 form.
9 A.
None of the requirements spelled out
1 0 related to terms of vapor pressure or
.
1 1 vaporization. That was not a consideration
1 2 of the requirements given us.
1 3 Q . Okay .
1 4 (A discussion takes place off
1 5 the record.)
.
1 6 Q . You've been handed what's been
1 7 marked earlier a s Exhibit number 3 .
18
MR. KRAUSS:
This document was
1 9 produced to the carriers by Texas Eastern,
2 0 and is protected material . It bears
2 1 Bates stamp number 010037983 through
2 2 010037986.
2 3 Earlier we were discussing Texas
2 4 Eastern ' s knowledge that of -- when Texas
2 5 Eastern acquired the knowledge that Turbinol
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1 153 contained PCBs. And I believe that at
2 that time we established that it was -- that
3 based on an article by Earl Farmer you have
4 put the date at 1970.
5 MR. HART: I'm going to object
6 to the characterization.
7 (A discussion takes place off
8 the record between the witness and his
9 attorney.)
10
MR. HART: I n any event,
1 1 Counsel, why don't you move --
1 2 M R . DAVIDSON : Let me stay on
1 3 the record that what the witness has
1 4 indicated is that certain logic indicated by
1 5 a n article t h a t was prepared by Mr. Farmer --
1 6 M R . KRAUSS: Okay.
1 7 M R . DAVIDSON : -- placed the
1 8 time a t some p o i n t in 19 7 0 - -
1 9 M R . KRAUSS : He did not --
2 0 M R . DAVIDSON : -- in 1 9 7 0 - -
2 1 THE WITNESS : Yes.
2 2 M R . KRAUSS : Okay. That's
2 3 fine.
2 4 Q . T h i s appears to be a letter 2 5 written by W. M . Stephens to R.E. Moore.
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1 Did you have any dealings with
2 W . M . Stephens from Texas Eastern?
3 A.
Ever?
4 Q . Ever.
5 A.
I'm
sure I met him and talked to him
6 I don't remember any specific instance .
7 Q . Do you recall, you know, what
8 dates , what time frame you're talking
9 about --
10 A.
No.
1 1 Q meeting Mr. Stephens?
1 2 No .
1 3 Q . Did you ever inform Mr. Stephens
1 4 that Turbinol 153 or M C S- 1 5 3 contained
1 5 polychlorinated biphenyls?
1 6 MR. HART: I'm going to object
1 7 to the form.
18 A.
I don't remember.
1 9 Q . I s there a difference between a
2 0 chlorinated polyphenyl and a polychlorinated
2 1 biphenyl?
2 2 MR. HART: In general?
23
THE WITNESS:
Yes.
2 4 Q . I n general .
25 A.
Chlorinated polyphenyl actually covers
i
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1 a much wider range of chemicals than
2 chlorinated biphenyl.
3 Chlorinated polyphenyl can be
4 anything from two to 200 benzine rings hooked
5 together, which are then treated with
6 chlorine, some ofthe hydrogen replaced with
7 chlorine.
So polyphenyl is a whole wide
8 world of materials.
9 Biphenyl is the one which has
1 0 two rings, and that's the one that's commonly
1 1 known a s P C B s .
1 2 Q . Are you familiar with the
1 3 product P y d r a u 1 135?
1 4 A.
P y d r a u 1 135 is a development that I
1 5 was a w a r e of, but did not actively
1 6 participate in.
1 7 Q - D o y o u have any k n o w 1 e d g e o f 1 8 what the c o m p o sit ion o f P y d r a u 1 135 was ?
19 A.
A very gen era 1 k n o w 1 e d g e >
2 0 Q A n d w h a t is that k nowledge ?
2 1 you know what it's composed of?
Do
22 A.
11 was a mixture which contained
2 3 petroleum oil, some of the Aroclors, and a
2 4 phosphate ester.
2 5 Q . Was the Arocloric contained in
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1 Pydraul 135 the same Aroclor that was
2 contained in MCS-153?
3 A.
I do not know.
4 Q. Do you know if the phosphate
5 ester was the same phosphate ester?
6 A.
Not positively, no. That is, I don't
7 know whether it was or not. It may have
8 been.
9 MR. HART: Let me state for the
1 0 record an objection to the second previous
1 1 question which is, I think you implied there
1 2 was only one Aroclor.
1 3 MR. PUPKE: Can I try to guess
1 4 which question you're objecting to there?
1 5 MR. HART: Not the immediately
1 6 previous question, but the question prior to
1 7 that one.
1 8 MR. PUPKE : Are you sure?
1 9 MR. HART: I believe so.
2 0 MR. PUPKE : Okay.
2 1 MR . HART : I think it should
2 2 have been Aroclors, pi ural.
23
THE WITNESS :
I hoped I said
2 4 that.
2 5 Q. Would you please take a minute
i
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1 to review the part of this Exhibit regarding
2 thermal and oxidative stability on the second
3 page.
4 A.
(The w i t n e s s re views the document.)
5 Yes.
6 Q Okay. 11 states here in this 7 letter that the 1 i g h t e r constituent of
8 P y d r a u 1 13 5 had a boil ing point of 450
9 degrees F .
1 0 Do you have an understanding as-
1 1 to what the boiling point of the Arocloric
il 1 2 | component of MCS-153 was?
1 3 A.
No. That's a number I don't remember.
1 4 Q . Do you know if it was greater
1 5 than
j
1 6 A.
or less than 450 degrees F? No, not without consulting
the
data.
1 7 | Q. Do you know generally whether I
j
1 8 ! Aroclors have boiling points greater than 450
1 9 degrees F?
2 0 A.
I don't remember that -- the boiling
2 1 point data of all of Aroclors that were made
2 2 and sold. And i -- I cannot answer your
2 3 ; question.
2 4 Turbinol 153 had a vapor
2 5 pressure of 200 degrees F of 0 2 5
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1 millimeters.
2 Q . And you're referring to --
3 A.
I'm referring to Exhibit number 2.
4 Listed below that is the boiling
5 point of the total fluid as 625 degrees F.
6 MR. HART:Could the record
7 reflect what page you're looking at?
8 MR. DAVIDSON: TEX 000332.
9 Q. Now, knowing that the total
1 0 fluid of Turbinol 153 had a boiling point of.
1 1 625 degrees F, are you able to make a
1 2 judgment as to whether or not the constituent
1 3 proponents had a higheror lower boiling
1 4 point than that, than 625 degrees F?
1 5 MR. DAVIDSON: I'm not sure I
1 6 understand the question.
17
MR. HART:
I'm certain I don't
1 8 understand the question.
1 9 A.
Are you still trying to get back to
2 0 the boiling points of the materials?
2 1 Q. 0 f the constituent components ,
2 2 yes.
2 3 Now, knowing that the --
2 4 MR. DAVIDSON : The A r o c 1 o r
2 5 components? Or are you including all the --
;
j
i |
j
ii !
I !
j
j | j 1 : ;
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1 MR. KRAUSS: I'm going to ask
2 about the other one later, so we can do it
3 both.
4 MR. HART: Also, the components
5 of what?
6 MR. KRAUSS : 0 f Turbinol 153.
7 MR. HART: You started with the
8 components of Pydraul 135.
9
MR. KRAUSS:
I did change.
I
1 0 didchange.
.
1 1 MR. HART: All right.
1 2 A.
Boiling points of mixtures are related
1 3 to the boiling points of the individual
1 4 components. But there is no direct method
1 5 can think of, of taking a given boil i n g p o
1 6 and going backwards to the boiling points of
1 7 individual components,
1 8 I would have to have that
1 9 information, a s such, to answer your
2 0 question.
2 1 Q. Okay. Now, under the discussion
2 2 of thermal and oxidative stability in Hatton
2 3 Exhibit number 3 , it s t a tes that, "Under our
.
2 4 operating conditions, th is lower boiling
2 5 component" which they re ferred to earlier as
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1 having a boiling point of 450 degrees,
2 "should experience very little
3 vaporization . "
4 Knowing that regarding Texas
5 Eastern's operations, do you have any opinion
6 as to whether or not the Turbinol 153 would
7 vaporize under the sameoperating
8 conditions?
9 MR. DAVIDSON : I'm going to
1 0 object tothat.
Are you asking him to accept
1 1 as a hypothetical a statement made by Mr.
1 2 Stephens asa result of his own tests and
1 3 evaluation?
1 4 This is not a test run by
1 5 Monsanto or by Dr. Hatton.
1 6 If you are posing some
1 7 h y pothetical situation, he's already
1 8 testified that he didn't know about the
1 9 P y d r a u1 13 5, what it was or why it was
2 0 presented in there, or under the
2 1 circumstances in which it was presented to
2 2 Texas Eastern.
2 3 And you are apparently also
2 4 asking him for a n opinion, is that just a
2 5 layman's opinion?
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1
MR KRAUSS
Just a layman
2 opinion.
3 MR. DAVIDSON: Are you
4 qualifying him as an expert or what?
5 MR. KRAUSS: No, a layman's
6 opinion.
7 MR. HART: I - -
8 MR. DAVIDSON: Do you understand
9 the question?
10
THE WITNESS :
Not -- I'm not .
1 1 sure that I do.
12 Q . Let me ask it this way, then. 13|
If we can take it on faith here
i 4 : that the operating conditions of Texas
1 5 Eastern are such that a 450 degree -- a
1 6 j fluid with 450 degree F boiling point would
1 7 i not vaporize, do you know if Turbinol 153
1 8 i would vaporize under the same operating
1 9 conditions?
2 0 MR. HART: Well, I object to the
2 1 form
2 2 And Counsel , I a m sorry --
2 3 could you show me where in the document there
2 4 is any basis for what I think you describe as
2 5 a leap of faith that under Texas Eastern's
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1 operating conditions there would be no
2 vaporization at 450 degree s Fahrenheit?
3 MR . KRAUSS ; I didn't
4 characterize that as a lea p of faith. That's
5 clear in the document.
6 MR. HART: Wh ere?
7 MR. KRAUSS: I said we would
8 rely on that under thermal and oxidative
9 stability.
1 0 M R . HART: Right .
1 1 M R . KRAUSS;: Second paragraph
1 2 M R . HART: Right .
1 3 M R . KRAUSS : The 11th line
1 4 down.
"Under our operating conditions, this
1 5 lower boiling component should experience
1 6 very little vaporization."
1 7 MR. DAVIDSON: I think we're
1 8 getting -- let me just make this
1 9 statement --
20
THE WITNESS :
Well - -
21
MR. DAVIDSON:
-- the reference
2 2 is to apparently one constituent called the
2 3 lighter constituent of P y d r a u 1 135 --
24
MR. KRAUSS :
I t has - -
2 5 MR. DAVIDSON: -- has a boiling
I
i i
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1 point --
2 MR. KRAUSS: My question --
3 MR. DAVIDSON: We've already
4 told you we don't know what' the other
5 constituents are. Your comparables are -- it
6 might be talking about phosphate ester, if
7 there is one in there. You're taking Pydraul
8 135, and comparing it to Turbinol 153, which
9 is a blend, and which Dr. Hatton already told
1 0 you about the boiling point of that.
.
1 1 I'm sorry, under the lower
1 2 boiling component -- you're just talking one
1 3 part, and we don't even know what part we're
1 4 talking about.
1 5 MR. KRAUSS: I u n derstand that.
1 6 And they are talking about the petroleum part
1 7 of Pydraul 135.
1 8 MR. DAVIDSON: How do you know
1 9 that?
2 0 MR. KRAUSS: Well --
2 1 MR. DAVIDSON : Petroleum boils
2 2 at 400 -- impossible.
2 3 MR. HART: I - -
2 4 MR. DAVIDSON : Wouldn't
2 5 petroleum boil
i
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1 THE WITNESS : Benzine boils
2 a 1 mos t a t room temperature, it comes from
3 petroleum.
4 MR. HART: I would also like to
5 state my objection to this whole line of
6 questioning, because now that I understand
7 the predicate in the document that's led you
8 off on this, it doesn't say "no
9 vaporization," it says, "very little
1 0 vaporization."
-
1 1 MR. KRAUSS : Let me find the
1 2 reference to identifying the lower boiling
1 3 component as the petroleum part first, then
1 4 we'll deal with that.
1 5 Well, let me see if we can ask
1 6 it a different way, then.
1 7 Q . If a component of fluid used in
1 8 Texas Eastern's application, a synthetic
1 9 fire-resistant lubricant, if a certain
2 0 component that boiled at 450 degrees F did
2 1 not vaporize when it was used in Texas
2 2 Eastern's application, do you know if
2 3 Turbinol 153 would vaporize under those
2 4 conditions?
2 5 MR. . HART: Objection . No
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1 48
2 A.
If you specify that we're talking
3 about the exact same conditions in the unit,
4 I would expect the MCS-153 to show less
5 vaporization than the component you're
6 talking about in this memo here. Exhibit 3 .
7 Q . Okay. Thank you.
8 Earlier we discussed your
9 participation in a study group on
1 0 fire-resistant turbine fluids. Do you recall
1 1 if anybody from Texas Eastern was involved in
1 2 that same study gr o`u p ?
1 3 A.
I do not have specific memory of
1 4 that.
But the meetings were generally open
1 5 and could be attended by anyone who desired
1 6 to come. They were not closed meetings by
1 7 any means.
1 8 Q . Okay.
1 9 MR. KRAUSS: Please mark this as
2 0 the next Exhibit. 2 1 (Document entitled, "Membership
2 2 List Study Group on Fire Resistant Turbine
2 3 Fluids, Tech C, AST, D-2, undated. Bates No.
2 4 000907826 is marked Hatton-11 for
2 5 identification . )
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1 Q. You've been handed what's been
2 marked today for our purposes as Hatton
3 Exhibit 11.
4 This appears to be a Membership
5 List.
.
6 MR. KRAUSS: This is protected.
7 Q. Of the study group on
8 fire-resistant turbine fluids , Tech C, A S T M
9 D-2 .
1 0 MR. KRAUSS: And this is a Texas
1 1 Eastern document Bates numbered 000907826.
1 2 And it's protected under the Protective
1 3 Order.
1 4 A.
Okay. I glanced through it.
1 5 Q. Does this refresh your
1 6 recollection a s to whether or not anybody
1 7 from Texas Eastern was a member of the study
1 8 group on fire-resistant turbine fluids?
1 9 A.
Yes, it does. O.M. Fletcher is
2 0 listed.
2 1 It also refreshes my memory that
2 2 I served a s secretary of that group for
2 3 awhile, which I had forgotten .
2 4 Q. What were your duties a s
2 5 secretary , if you recall?
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1 A.
Gordon Night, who was chairman, ran
2 the meeting, andit was up to me
to prepare a
3 set of minutes of the meetings, and then see
4 that -- I also had to see that they were
5 circulated to the attendees, whether they
6 were members of the group
or not. And those
7 who didn't attend that meeting, who were
8 members, got copies of the minutes.
9 Q . How frequently did this study
1 0 group meet?
1 1 MR. HART: Are you asking about
1 2 a particular time?
1 3 Q . Well, a t the timethat you were
1 4 on the study group, how frequently did it
1 5 meet?
1 6 A.
Periodic meetings were held every six
1 7 months in connection with meetings of Tech C
1 8 and D- 2 .
1 9 Generally a week of meetings was
2 0 held, and a n hour was set aside during that
2 1 for a study group, or a subcommittee, or a
2 2 working group, whatever you had, to conduct
2 3 your business .
2 4 Q. And were minutes of these
2 5 meetings kept each time?
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1 A.
Any formal, scheduled meeting was
2 documented, and minutes issued.
3
MR. KRAUSS:
Please mark that a s
4 the next Exhibit.
5 (Minutes of Meeting,
6 Fire-Resistant Turbine Fluids Study Group,
7 Technical Committee C, A S T M Committee D - 2 ,
8 dated June 2 5 , 1 9 6 3 , Bates Nos. 0009078915
9 through 000907825 ismarked Hatton-12 for
1 0 identification . )
1 1 Q. You've been handed what's been
1 2 marked for our purposes today a s Hatton
1 3 Exhibit 1 2 .
1 4 I'd like to direct your
1 5 attention to -- well, first of all, are
1 6 these minutes of a meeting such a s the type
1.7 that you kept when you were secretary of the
1 8 study group on fire-resistant turbine fluids?
19 A.
Yes.
2 0 Q. Would you please refer to the
2 1 fourth page from -- I 'm sorry --
22 A.
Yeah, I signed this particular set,
2 3 too, a s secretary .
2 4 Q. You did?
25 A.
Yes.
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1 Q 2 document?
Did you author this par t i c u 1 a r
3 A.
Yes, I did, then.
4 Q I'd like to d irect your 5 attention to the section e numerated as number
6 2, and have you review tha t , please . It's on
7 000907817 .
8 A.
(The witness reads the docume n t . )
9 MR. DAVIDSON: Off the record.
1 0 (A discussion takes pla c e off
1 1 the record.)
12 A.
I've read all of se ction two. now.
13 14 A.
Q Okay. N o f u rther.
I say no further than
1 5 section two - -
16! i
17 A. 1
18!
G . Right -- -- a t the moment.
Q Fine. Now, s ection two i s
1 9 headed, "Use of Fire-resis tant Fluid s in Gas
2 0 Turbines." And it reports that 0.M. Fletcher
2 1 of Texas Eas tern reported on their e xperience
2 2 with fire-re sistant turbin e lubrican t s .
2 3 Do you recall the prese n t a t i o n
2 4 by Mr. Fletc her?
25 A .
N o t i n detail, no.
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1
Q. Do you have anydoubt
that
2 what's written here accuratelyreflects the
3 presentation of Mr. Fletcher?
4 A.
No. It reflects what I heard at the
5 time, and what I would have reported as such.
6 Q . Okay. On the top of page 4
7 there is a discussion about compatibility or
8 the potential for attack by the
9 fire-resistant lubricants . And it states
1 0 that the tachometer generator was coated with
1 1 epoxy materials, and that there were no
1 2 problems.
.
1 3 Do you have any idea of what a
1 4 tachometer generator is?
1 5 A.
Well, the definition of the word
1 6 tachometer is something that measures speed.
1 7 But I don't know the term
1 8 generator, how it was connected.
1 9 Q . All right.Was compatibility
2 0 with the pipeline components a general
2 1 concern to the industry with regard to using
2 2 synthetic lubricants?
23
MR. HART:
Objection to form.
24 A.
Capability of materials with the fluid
2 5 always presented a major concern to us
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because if the fluid attacked any of these
materials that were used in building the
machine, then you would be in difficulties
with deterioration of the materials.
Q . Which particular -- or which
components, if you know, would there be
concern about attack? Which components
within a pipeline system?
MR. HART: Objection to form.
10 A.
I d o n ' t -- I am not
11 familiar w i t h what ' s in the
1 2 can't answ e r that question.
1 3 We generally looked at
1 4 compatibility with paints, sealants, hose
1 5 ; materials, coatings.
i
1 6 I Q. Components that came in contact
1 7 j with --
H*
CD
A . W i t h -- we g enerally were concerned
1 9 j about the organic m aterials that came in
2 0 : contact w ith our fl u i d s . 2 1 Maybe that's a very general
2 2 ; answer, but that c o vers all of the things
23 O *A A .
Q Yes?
--
I
listed,
V-V 1
y
u, ,
^o
TmT, -cVa. n y
mo r @ B
25
Q.
Okay.
Also at the top of pag
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1 there is an indication that Mr. Fletcher
2 reported that Tex as Eastern's pipeline is i
3 internally coated with epoxy materials, and
4 iI! that the particular ones they 5 ! satisfactory, and have caused
used no
are
quite
6 | difficulties .
Do you have an understanding as
8 to why the internal coating of a pipeline
9 would be of concern with respect to
1 I fire-resistant lubricants?
11! MR. HART: I object to the form
12! of that because I don't see the use of the 1
131 word "concern" here. I don't know whose
1 1 4 ; concern that question refers to.
1 5 I MR. KRAUSS: Just object and
1 6 | that ' s it.
17j 18| A.
MR. DAVIDSON: If you know. I can only indicate that attack of any
19; kind of a coating by the fluid would be of
2 0 ; concern to us as fluid producers. And we
2 1 would run tests on any coating that we were
2 2 asked to, whether we knew where it went or
2 3 not.
2 4 Q Okay. And this particular 2 5 coating here is stated as being internally
l
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1 -- an internal coating of the pipeline.
Is
2 that an indication that your lubricants were
3 going to get into the pipeline?
4 MR. HART: Objection to form.
5 A.
We were asked to evaluate these
6 I particular epoxy materials . !
7 | aware of why we were asked .
I a m not well We were just
8 told to do it.
9 Q. Okay. During the -- did you
1 0 have an understanding of why Mr. Fletcher
1 1 would have reported this particular fact,
1 2 that their pipeline is internally coated with
1 3 epoxy materials, and that the particular ones
1 4! that
J 15: have
they used caused no
are quite satisfactory, and difficulties with respect to
1 6 j the topic of his presentation, which is the
17; fire-resistant fluids they use?
18| MR. HART: Did he have such an
19| understanding? Does he have one today? Can
20: he figure one out?
21 MR. HOOK: You may object to the
22: form of the question. 2 3 ! Q Did h e have one at the time it OC'-At w. , as~ ITi a. d. 0 f at the t i me the p r essntation was 25 made?
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1 MR. KRAUSS; Does he have an
2 understanding of what? Why that was a part
3 of Mr. Fletcher's presentation?
4 MR. HART: I object to the form.
5 | A.
I would not
i
6 I| Fletcher ' s mind to
put myself in Mr. determine what he
was
7! thinking
ii 8|
then. And
Ican
only
suppose
that
if
9 | the previous speaker had talked long and loud
1 0 | about effects of fluids , fire-resistant
fluids on materials, that Mr. Fletcher would
1 2 | have .covered that in his presentation in some
X,|
form or other.
14!
Q.
Okay.
Do you know if there was
1 5 an understanding within the industry, and the
1 6 ! industry I'm referring to here is those
1 7 represented on the study group of
1 8 ; fire-resistant turbine fluids .
1 9 i Do you know if there was an
2 0 understanding that these synthetic
2 1 lubricants, when used in natural gas
2 2 centrifugal compressors would find their way
2 3 into the pipeline?
o nC V- U J.
25 A
I have no way of answering that
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1 question as to what they knew or didn't know.
2 Q, Did you have any knowledgethat
3 -- at this time, in 1963, that there was an
4 issue regarding the compatibility of the
5 synthetic fire-resistant lubricants and the
6 internal coatings of a pipeline?
7 MR. HART: Objection.
8 A.
I can't remember specific discussions,
9 beyond a request for compatibility data,
1 0 concerning the coating. That type of work
1 1 was quite commonly undertaken by Monsanto on
1 2 theirproducts.
.
1 3 Q. Okay. Did you at any time learn
1 4 that Turbinol 153 or MCS-153, or OS-81 found
1 5 its way into Texas Eastern's pipeline?
16
MR. HART:
Objection to form.
1 7 A.
I -- I don't remember such
1 8 information.
1 9 Q. Not at any time?
20
MR. HART:
Objection to form.
2 1 A.
It's impossible to say, or to cover in
2 2 any way all the things that were discussed
2 3 over the period of time that I was in contact
2 4 with Texas Eastern. I do not remember all
2 5 the subjects that were covered, by any means.
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1 i MR. PUPKE: May I ask for a five
2 | minute break here? 3 I MR. KRAUSS:
Yes.
4 . (There is a recess.)
5 Q . Dr. Hatton?
6! A
Yes.
7 ; Q . Okay.
8 A.
I was reviewing these minutes. I find
9 ! them very interesting.
1 0 Q . Did you ever hear about the
1 1 i incident regarding PC B s being found in the
1 2 natural gas pipeline on Long Island in 1981?
1 3 MR. HART: Can I have that
1 4 back?
1 5 (The pending question is read
1 6 back by the reporter.)
17 1 8 form.
MR. HART: Objection to the
1 9 A.
Well, my only knowledgethat I can
2 0 bring to mind on that subject was what I read
2 1 in the newspapers at the time.
2 2 Q. Were you ever consulted by Texas
2 3 Eastern regarding means by which to cleanse Z A<"\ PCBs from their pipeline?
2 5 MR. HART: Objection to form.
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i6a
1 ; M R . DAVIDSON: Ever? At any
2 time?
3 A.
My answer - -
4 : M R . DAVIDSON: At any time?
5 A.
Yeah. Is that your question, ever
6 i any t i me?
7 M R . KRAUSS : Well, after 1981
8 M R . DAVIDSON : After 1981?
9 j Okay.
0: A.
Answering this on a personal basis,
1 1 | no
i
1 2 Q You don't recall being asked
13 what a good solvent would be for cleansing
14PCB from a pipeline?
15 MR. HART: Objection.
16 A.
At that point in time such questions
17. would have been referred to the company in
18 general and not to me specifically.
19 MR. KRAUSS; Mark this as the
20 next Exhibit.
21 (Typewritten memo to "Earl"
22 dated January 23, 1981, Bates No. 010037863
23 is marked Hatton-13 for identification.)
24 Q. You've been handed what's been
25 marked for our purposes today as Hatton
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1 | Exhibit number 13.
2 i This appears to be an internal
3: memorandum from Texas Eastern. It was
4 produced to the carriers by Texas Eastern,
5; and it's Bates stamped 010037863.
6: Have you had a chance to review
7; this?
8 A.
Yes .
9; Q. Do you recall giving the
1 0 information listed here in this document
lli regarding solvents for PCBs?
1 2; A .
I have no recollection at all of
13 having done this.
1 4 Q. Okay.
15 A
I have no recollection of -- of
16 performing that action.
17 Q . Okay. Were you involved with
18 Texas Eastern at this period of time? The
19 document is dated 12/23/81. Did you have any
20 involvement with Texas Eastern at this time?
21 A.
I do not remember any. And at this
22^ period of time I was working primarily on
23 heat transfer fluids.
24
Okay .
n n d \i n 11 h a \i *=> a n \/
25 involvement with Texas Eastern after the date
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1! of this document, January 23rd, 1981, | I
2| than with respect to this particular
other
3' litigation, or this deposition?
4, A.
No.
5 Q. !
6! regarding
Were you consulted at all means to clean up PCBs f r o m soil,
7: or in any capacity?
i 8A .
No.
9; Q. Do you know when your last
10 substantive involvement with Texas Eastern I
111 was, to the best of your recollect ion?
1 2; A .
I cannot fix an exact date.
But the
13: contacts with Texas Eastern had be en turned
i
14 over to other people by about the time that
15 they began to field trial MCS 1122 , o r
16 Turbinol 1122, the same product.
17; That program was handled by
18; someone else.
19
MR.
PIERDINOCK : Can you repeat
20 his answer for me?
21 (The last answer is read back by
22 the reporter.)
23 MR. KRAUSS: Off the record for
24 a minute. 25
(A discussion takes place off
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ljthe record.)
2! !
i
3 as
the
next
MR. KRAUSS : two Exhibit s .
Please
mark
these
4 1l
5 I from
Clif
(Letter to Dr. Roger E. Hatton Wi lliams, dat ed December 1, 1975,
6 Bates No. 00 0844865 is marked Hatton-14 for 7 | identificati on.)
8 ; (Letter to Clif Williams from
9 ! R.E. Hatton, dated Dece mber 8, 1975, Bates l 0 : No. 00084486 1 is marked Hatton-15 for
1 1 | identificati on.)
1 2 i Q Dr. Hatton , you've been handed 1 3 two Exhibits , 14 and 15 , and these are --
1 4 Exhibit 14 i s 000844865 , and Exhibit 15 is
1 5 ' 000844861 .
1 6 ! MR. KRAUSS : These were produced
1 7 ; by Texas Eas tern to the carriers, and are
-
1 8 : subject to the Protecti v e Order.
1 9 Q Do you rec all being contacted by 2 0 Texas Easter n regarding disposing of a large
2 1 quantity of MCS-153?
22 A.
Exhibit 14 indie ates that -- quotation
23 marks, "disposing of a large quantity of
z< pi u ii s a iu u pi l a - i j j j. r -a c j. esistant lubricant,
25 My memory does not bring this up
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164
11 as an event that I remember.
2 Q Yes.
A3 .
But I ' m quite sure that if a letter
4 , was s e n t to me, I got it.
5: Q . And do you recall when the
6 M C S - 1 5 3 was withdrawn from the mark e t ?
7 A.
It w a s, I think January 14th , 1972 was
8 the c a 11 - -
9j 10 A.
Q . Okay. -- re port that
-- it's in o n e of
11 ! these E x h i b i ts back here that talke d about
12: it .
1 3 Q So this is some four y ears
1 4 later - -
15 A .
Uh-huh .
16 Q 1 7 you ho w to
-- that Texas Eastern is asking -- or if you can be of any
1 8 assist a n c e i n disposing of a large quantity
1 9 of Mon santo MCS-153?
2 0 MR. HART: Is there a question
2 1 pendin g? 22
MR; KRAUSS: No.
2 3 Q Did Monsanto provide s u c h a
O L*
A-X
s erv i c e
as
i indicated
ir
this
doc um0nt ?
25 A .
Yes.
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1 Q. Did other companies that
2 utilized your PCB containing fluids avail
3 themselves --
4 A.
Certainly.
5 Q. -- of this service?
6 A.
C ertainly. General letters of
7 notification on the availability of this
8 service were sent out to all Pydraul
9 customers, I believe in '12 or '73.
1 0 Q . Yes.
1 1 A.
And were -- it was indicated that
1 2 such a service was available.
1 3 I'm not sure of the exact date
1 4 that this service first became available, but
1 5 we did have a group within Monsanto that were
1 6 charged with being sure that the materials
1 7 came ba ck right, and that they got to the
1 8 incinerator.
And then there was another
1 9 group that managed and operated the
2 0 incinerator.
2 1 Q. Yes. Do you recall if Monsanto
2 2 charged for this service?
2 3 A, W 0 27 0
I do not remember how muc h , but there
--
th6r6
W 3. S
a.
C ]~i cl P CJ 0
1 HVO
1
_L
v
e
d
.
2 5 Q. Okay. Do you recal 1 if free
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1 incineration was offered to Texas Eastern at
2 any time?
3 A.
I do not, no.
4 MR. KRAUSS : Would you please
5 mark this as the next Exhibit.
6 (Memo to T.L. Gossage from C.L.
7 Bradford/N.T. Johnson, dated November 17,
8 1971, Bates Nos. TEX 000303 through 000306 is
9 marked Hatton-16 for identification.)
1 0 Q . You've been handed what's been
1 1 marked for our purposes today as Hatton
1 2 Exhibit number 16.
1 3 This document was produced to
1 4 the carriers by Monsanto. It's TEX 000303
1 5 through 306. And it appears to be a Monsanto
1 6 memorandum to a T.L. Gossage.
1 7 _ Who is Mr. Gossage?
1 8 A.
I'm not sure of his exact title.
1 9 Titles back then are hard to recall. But he
2 0 was the top man in the organic -- or, let's
2 1 say in the fluids area at this time. And I'm
2 2 sure he had other responsibilities. But he
2 3 would have been our man up the ladder several
24 S t0ps
2 5 Q . Okay. And what about N.T.
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- PROTECTED you recall iwhat
his
posi'tion
16 7 was
2 | at the t i me?
3 A.
Y e s . Norm was on e of our prod u c t
4 manage r s i n the sales de partment, and would
5 have b e e n i n volved with Turbinols, hydraulic
6 : fluids , h eat transfer fl uids and so o n .
7 I
8 2.
Q I direct yo ur attention to page
9 A.
Uh-huh .
1 0 Q Towards the middle of t h a t 1 1 ! p a r a g r a p h i t states, "In addition, we
i 2 ; r e c o m m end M o nsanto absor bing the cost t o
1 3 ; i n c i n e rat e their current charge of Tu r b i n o 1 1 4 : 15 3 ( e s t i mat ed at 54,000 gallons - a cost to
1 5 M o n s a n t o for incineratio n and freight
1 6 e q u a 1 i n g $27 , 0 0 0 ) . "
1 7 Do you know whether such a n 1 8 offer was m a de to Texas Eastern?
19 A.
T h i s document is -- was writt e n by
2 0 Larry Bra d f o rd , and was the proposal that he
2 1 was m a kin g a s to a way i n which this could b(
2 2 handle d a t T exas Eastern . I do not k now
2 3 w h e t h e r i t w1 a s ever r e 1 a yed to Texas OL* *A1 Easter n - --
2 5 Q. You don't know --
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1 A.
-- as such.
2! Q. -- whether such an offer was
3 made 4 A.
No, I don't know.
5 Q. Do you know who within Monsanto
6 would know that?
7 A.
Beyond Larry Bradford, I' m not sure.
8 1 Q . Okay. All ri g h t . That's as far
9 as I ' m going to go this ev e n i n g .
So we can
1 0 : go o ff the record.
1 1 (A discussion takes place off 1 2 the record . )
1 3 MR. HART: I think my attempt to
1 4 e f f ectuate --
1 5 MR. DAVIDSON: I wo uld like to
1 6 make it clear that we are a d j o u r n i n g the
1 7 d e p o sition at about 5:15. That the deponent
1 8 is h ere and available for q u e s t i oning. That
1 9 we h ave indicated we will start back at nine
20 tomorrow morning. And that I have previously
21 indicated that we would need to conclude
22 hopefully, or adjourn otherwise by four
23 tomorrow afternoon.
24 And that my schedule and others
25 don't permit us to continue on this Friday.
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And I don't believe the notice included any
further than these two days, or at least
indicated these two days at this session.
MR. HOOK: That's correct.
5;
MR. PUPKE:
Can I just address
6 si that before you go, Larry?
Thank you.
7 | Mr. Davidson, I appreciate your
8 : taking your time out to be here.
9 j Mr. Hatton, I appreciate you
i o; taking yo u r tin
11 S p 1 2; clients, I can i 3; assuredly c o n c 1
1 4 that you need t
1 5 tomorrow. We'l
1 6 that won' t be a 17 We 1 8 whatever time t 1 9 : convenien t . We
2 0 possible. if e v
2 1 could sta rt at
2 2 whatever time a
23 At
2 4 probably better
2 5 cull out materi
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1 so that there is very little duplication of
2 what's been gone over today, and I think that
3 this process of breaking at 5:20 would be
4 appropriate.
5 MR. DAVIDSON: I appreciate
6 that.. Don, and I know I have duly noted the
7 Judge's admonition in the Order governing
8 these depositions that you will not be
9 repetitive, or will be minimally repetitive,
1 0 and I intend to hold you to that.
1 1 MR. PUPKE: Okay.
1 2 MR. HART: I'd like to state on
1 3 the record Texas Eastern's objection to
1 4 concluding at this early hour.
1 5 Texas Eastern will insist on a
1 6 full and fair opportunity for conducting its
1 7 own examination. I, too, agree that under
1 8 the circumstances we should adjourn no later
1 9 than four o'clock tomorrow afternoon, but
2 0 want to express my understanding that if we
2 1 can't conclude by then and we need to
2 2 adjourn, that we will have a further
2 3 opportunity down the line to resume the
2 4 deposition of Dr. Hatton.
2 5 And I've gotten the impression
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from everybody that that's i n the cards for
2 i us i
3 : to
i f we s tate
can't finish tomor row . And I want that understanding o n the r e c o r d .
4 MR. DAVIDSON: Well, we don't i
5 have any intention of cutting anybody i
6 I or cutting your examination short and
short, not
7i letting them have their due opportunity i!
8 : within the confinesof the Order governing
9 I the deposition.
10 i
s 1 1 ! short
i
I would like to keep this as as possible, and not get strung out
12:i over a long
period of time, and of course it
1 3 would be subject to rescheduling of Dr. !
1 4 ; Hatton according tohis schedule and when
he
1 5 can continue.
i6:
'(The deposition is
concluded at
1 7 i 5:20 in the evening.)
i 19 20 21 22
23 24 25
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172
1j JURAT
2| I
3 I, ROGER E. HATTON, do hereby
4 certify that I have read the foregoing
5 transcript of i
6124, 1990, and
my testimony, taken on January have signed it. I have listed
7; the following changes or corrections to that
8 transcript below.
1 0 ; PAGE 11
LINE
CHANGE/CORRECTION
12: . 13!
14: 15' . 16
17 !
l.j
19'
Date:
_______________________________
20
Sworn to and subscribed
21 before me this
day of
, 19 9 0
22
Notary Public
_______________________________
23
24
25
waga and spinelli certified shorthand reporters
405 Northfield Avenue West Orange, N. J. 07052 201-731-9666
WATER PCB-SD0000061888
17 3
1 CERTIFICATE
2
3 I, TOMMY LARUE MILLER, Notary
4 Public and Certified Shorthand Reporter of
5 the State of New Jersey, do hereby certify
6 that prior to the commencement of the
7 examination ROGER E. HATTON, was duly sworn
8 by me to testify to the truth.
9 I DO FURTHER CERTIFY that the
1 0 foregoing is a true and accurate transcript
1 1 of the testimony as taken stenographically by
1 2 and before me at the time, place and on the
1 3 date hereinbefore set forth.
1 4 I DO FURTHER CERTIFY that I am
1 5 neither a relative nor employee nor Counsel
1 6 of any of the parties to this action, and
1 7 that I am neither a relative nor employee of
1 8 such counsel, and that I am not financially
1 9 interestedintheaction.
20
2 1 Notary Public ePf the State of New Jersey My Commission expires May 18, 1993
2 2 - License No. XI00806
23
2 4 Dated;
January 26, 1990
25
waga and spinelli
certified shorthand reporters
405 Northfield Avenue West Orange, N. J. 07052 201-731-9666
WATER PCB-SD0000061889
ALL-STATE LEGAL SUPPLY CO. ONE COMMERCE DRIVE, CRANFORD, NEW JERSEY 070'.6
(2)
EDBR'i IS
/ \r
WATER PCB-SD0000061890
Monsanto
COMPANY
A ugus t 22, 1963
Mr. W. M. Stephens Superintendent Design and Construction Texas Eastern Transmission Corporation P. 0. Box 1612 Shreveport, Louisiana 71102 Dear Mr. Stephens: In a recent conversation with Earl Farmer, he suggested we write to you outlining various control limits for MC3-153, the safety fluid used in remote controlled gas turbines on Texas Eastern's pipeline system. Earl indicated this information would be useful to station operating personnel especially in view of the frequent changes in manpower. A formal technical bulletin on MCS-153 has not been published and this letter would fill the need. MC3,-153 is a straight synthetic fire-resistant gas turbine lubricant which provides safety and excellent lubrication and is compatible with all common metals of construction, such as brass, bronze, steel, iron, aluminum, etc. usually found in hydraulic and various lubrication systems. The number one recommendation for seals and gaskets particularly dynamic elastomers is Vlton. Silicone, Fluorel, Teflon are equally compat ible but often not available in desired configurations. Butyl rubber elastomers and-EPR are acceptable but service life with MCS-153 may be reduced depending upon operating conditions. Temperature Is an important variable when using the less acceptable seals and packing materials.
000907285
WATER PCB-SD0000061891
DO138098
Mr. W. M. Stephens Page 2
August 22, 1968
When surfaces which could come In contact with the fluid
are to be painted, we recommend cured epoxy, cured phenolic
and nylon base paints. The enclosed booklet "Converting
to Pydraul Fluids" contains Information on seals, paints,
hoses, couplings, etc. applicable to MCS-153. We are sending
extra oopies should you desire to circulate them to station
personnel.
I
As to the fluid Itself, we do not claim it to be unchangeable or indestructible--Just the next thing to it. MCS-153 with normal use and periodic filtration will provide satisfactory service indefinitely. There is nothing to wear out in MCS-153 thus it can be virtually considered as a permanent part of the system. Occasionally minor shear down in viscosity is found in sample analysis. The main property to check in
MCS-153 is specific gravity. Specific gravity is the most unchangeable part of MCS-153 and will be altered only by the addition of a solvent or lesser viscosity fluid such as petroleum oil. Such contamination is easy to spot on the frequent checks of fluid from your various stations.
Our laboratory personnel are alert to the importance of picking up any major deviation in fluid quality in samples from Texas Eastern stations. They are quick to report any such changes and we in turn will be in direct contaot with you or other Texas Eastern personnel recommending necessary adjustments.
Hopefully this information will provide some general guide lines to operating personnel at Texas Eastern's many stations
using MCS-153--now and future. If we may provide additional information or service, please let us know immediately.
Senior Produot Specialist Functional Fluids
cci Walter Woods, Head of Turbins Section Engineering ' Earl Farmer, Engineering Department Ted Harrison, Asst. Purchasing Agent, Ho^Jg^Jffice
DO1 3 8 0 9 ?
WATER PCB-SD0000061892
; u-
CD (
Facts About Fire-Resistant
TurBinoL
TURBINE LUBRICANT BY
O/FF-23
TEX CCC33C
WATER PCB-SD0000061893
Introduction
Monsanto's Turbinol 153 is a fire resistant synthetic fluid spe cially designed for turbine systems. Turbinol 153 has years of safe, continuous operation as both the lubricant and control fluid in commercial pipe line gas turbines. The unique chemistry of Turbinol 153 offers excellent thermal-oxidative and hydrolytic stability.
The following abridged excerpts are from a paper titled, "Fire Resistant Lubricants In Gas Turbines," by Earl P. Farmer, Jr., of Texas Eastern Transmission Corporation. The paper was pre sented during the annual meeting of the American Society of Lubrication Engineers (ASLE), Power Generation Council Tech nical Session, in Chicago on May 4-7, 1970. It will appear as an article in Lubrication Engineer, the official ASLE magazine.
Hazards of Petroleum Lubricating Oils
The potential hazards inherent in using petroleum lubricating oils in high speed, high temperature gas turbine installations prompted Texas Eastern to investigate the applications of fire-resistant lubricants in our gas turbine installations. From our ex periences, several potentially disas trous lube oil fires were prevented by alert operators who happened to be in the right place when turbine failures occurred. In another case, a turbine failure caused a lube oil fire, resulting in a complete station outage. A load compressor failure was responsible for another lube oil fire, which re sulted in damages far more critical in the station operation than the com pressor failure.
Still another hazard exists in the use of centrifugal pipe line com pressors. These units require highpressure seal oil systems with con siderable external piping and controls. Even minor control and piping failures initiate emergency shut-down condi tions, which, when using petroleum
oil, necessitate the immediate shut
down of oil pumps to prevent feeding
of possible fires. This means the high
speed rotating elements must coast
down with no lubrication, resulting
in the strong possibility of wiped
bearings. If the bearings are wiped
badly, additional internal damage to
the rotating elements and seals can
result. Thus a minor failure can lead
to a major station outage.
Advancing technology combined
with rising operating costs led to the
development and rapidly increasing
use of automatic, remotely controlled,
unmanned pipeline compressor sta
tions. Obviously, this type of installa
tion becomes most vulnerable to the
potential hazards of lube oil fires. The
obvious solution to these potential
hazards is the use of fire-resistant
lubricants.
Texas Eastern Tries Synthetics
In 1958, Texas Eastern pioneered the use of fire-resistant lubricants in large, industrial gas turbines when we installed four 13,400 HP @ 8Q:F. units with the phosphate ester based fluid as the only lubricant.
Today, we have twenty industrial ; type gas turbines in service using the fire resistant fluid in the oil systems. These twenty units, with a total of 323,800 HP, have operated in excess of 410,000 hours without any failures attributed to the fire resistant fluid.
Our operating experience over the past twelve years has proven the fire resistant fluid used in our gas turbines to be extremely stable, both thermally and oxidatively. None of the units using this lubricant have experienced an oil change because of excessive oxidation. Periodic tests have indi cated little change in the neutraliza tion number. A coupling guard leak- i age at one station provided a practical i test of the oil's fire resistance by j
spraying oil against a 700 F. exhaust j housing with no fire resulting. Modi- i fications and repairs by welding on oil piping within the oil tanks further demonstrated fire resistance.
Because of the added safety factor and the proven reliability and stability of the fire resistant fluid, it has be come the standard lubricant in all our industrial type gas turbine installa tions placed in service since 1958.
TcA C0G321
WATER_PCB-SD0000061894
D0505739
D0505740
Typical Properties of Turbinol
PHYSICAL PROPERTIES
Appearance
Specific Gravity, variation with temperature:
Neutralization Number (Acidity) (Mg KOH/gm) Moisture (Max.) Viscosity
Saybolts (SSU) Measured: @
Absolute-centipoise: @
Pour Point Vapor Pressure
(mm Hg 9 200F.)
Boiling Point Secant Bulk Modulus
(psi) @ 100F.
Coefficient of Thermal Expansion cc/cc/F.
Solubility In Water
Clear, amber colored oily liquid
40'F./60SF. 1005F./60F. 200CF./60:F.
1.356 1.325 1.273 0.02-0.1
.0.15%
40;F. 100:F. 210=F. 40;F. 100:F. 210=F.
2160 108 37.1 469 29.7 4.1
0=F. 0.025
625:F. 412,000
0.00037
Negligible
TX CCCJ44
WATER PCB-SD0000061895
VISCOSITY. SAYBOLT UNIVERSAL SICONBS
1s
is Si
*
e|
3
S5
|!
i
: 2
2 gg s i* s i
||
IIII
3
g 2s
O2 con 2o O cn cn > "J 2 -O
| 1
1
1 I1 [
1
t
i
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TEMPERATURE OEGREES FAHRENHEIT
ii
I*
i i ii
2
IIS;
112
|tt t ixi
VISCOSITY. SAYBOLT UNIVERSAL SECONDS
f
aa TEX CCC333
WATER_PCB-SD0000061896
LUBRICATION PROPERTIES
Typical Premium SftO
TmMmI 1S3
TtwhtaeOU
Pew-Ball Wear Test (mm scar diameter) 620 rpm, 167 F,, 1 hr.
Steel/steel 10 kg 40 kg
Steel/bronze 10 kg
0.23 0.53 0.92
0.6 to 1.0 2.0 to 3.0
Timken Test Passing Load, lbs.
40 15
Faiex Load Jaw Load, lbs. Torque, lb. inches
4050 . 60
880 27
STABILITY AND CORROSION PROPERTIES
Typfcal Premium KOO
TutUmI 153
Turbina Oil
ASTM Rust Test D-665 140F. Distilled Water
Pass
Pass
ASTM Emulsion Test D-1401 ml Emulsion after 30 minutes
0
0
ASTM Foam Test D-892 Sequence 1 Sequence 2 Sequence 3
Pass Pass , Pass
Pass Pass Pass
ASTM Turbine Oil Stability Test D-943 (Modified*)
Mrs. to reach 2.0 mg KOH/g
>2000
2000
Hydrolytic Stability Test (MILH 19457--Beverage Bottle Test)
200sF. water, 48 hrs., Cu strip
Pass
Pass
Oxidation/Corrosion Test 168 hrs., 250'F., air
Metal Attack, mg/cm* Al
Mg Cu Fe Cd
-0.01 -0.01 -0.04
0.0 -0.01
0.0 0.0 0.0 0.0 0.0
Viscosity % Change, 100'F. % Change, 2103F.
+8.5 +0.6
+ 1.7 + 1.1
Acidity, TAN Change
+0.02
+0.41
Because of the higher specific gravity of Turbinol, water used in the test
would not settle to the bottom of the test cylinder. Hence, oxygen stream
was saturated with water before being bubbled through the test fluid.
FIRE RESISTANCE PROPERTIES
High-Pressure Spray Test (AMS 3150-C and Federal Test Method Std. 791)
Localized flashing in contact with flame but self-extinguishing.
Low Pressure Spray Test
Slight increase in flame intensity.
Hot Manifold Test (Federal Test Method Std. 791)
1300'F. Tube
Intermittent flashing on tube. Does not propogate flame to pan below.
950F. Tube
Does not flash.-
Molten Metal Ignition (Aluminum alloy
9 1200F.)
Does not ignite spon taneously. Flashes intermittently with ignition source, but self-extinguishes.
ALCOR DEPOSITION TEST
48 hours, 250F. fluid, 1000 ml/min. air flow @ 400-475:F. tube temperature.
Total Deposit Rating Filter, mg. Acidity, TAN
Change
TurMnsMSS Pstrekum Oil
10.5 10.5
10 13
+ 0.03
- 0.02
TX CGG33h
MONSAN IO
D0505742
WATER PCB-SD0000061897
Seals and Packings
Information
Materials compatible with Turbinol are necessary for dynamic or moving seals. For static seals they are preferred, but not essential. TTie following table indicates ma terials recommended. Packing ma
terials such as impregnated asbestors are usually satisfactory
with Turbinol. Consult your Mon santo fluid specialist for specific recommendations.
This list of component manufacturers is a guide to obtaining seals
compatible with Turbinol. Please contact your equipment manufacturer
or seal supplier for their most current recommendations.
Acushnet Process Company 776 Belleville Avenue New Bedford, Massachusetts 02745
Anchor Packing Company 401 North Broad Street Philadelphia, Pennsylvania 19108
Bearings, Inc. 3634 Euclid Avenue Cleveland, Ohio 44115
A. W. Chesterton Company Everett Massachusetts 02149
'
Chicago Rawhide Manufacturing Company 1311 Elston Avenue Chicago, Illinois 60622
C. E. Conover & Company, Inc. 333 Passaic Avenue Fairfield, New Jersey 07006
Crane Packing Company 6400 Dakton Street Morton Grove, Illinois 60053
Garlock Packing Company Palmyra New York 14522
Goshen Rubber Company, Inc. P.O.Box 416 Goshen, Indiana 46526
Greene, Tweed & Company North Wales Pennsylvania 19454
Hercules Packing Corporation 11061 Walden Road Alden, New York 14004
International Packing Corporation Bristol New Hampshire 03104
Johns-Manville 22 East 40th Street New York, New York 10016
C. W. Marsh Company 36 Hudson Street Muskegon, Michigan 49441
Minnesota Rubber Company 3630 Wooddale Avenue Minneapolis, Minnesota 55416
Parker Seal Company 10567 Jefferson Boulevard Culver City, California 90230
Plastic & Rubber Engineering, Inc. 756 East Florence Avenue los Angeles, California 90001
Plastic & Rubber Products Company 2100 Hyde Park Boulevard Los Angeles, California 90047
Precision Rubber Products Corporation Hartmann Drive Lebanon, Tennessee 37087
Raybestos-Manhattan, Inc. Packing Division Passaic, New Jersey 07055
Reliable Rubber Products Eddyington Pennsylvania 19020
Rockwell Mechanical Packing Company, Inc. 1634 Long Beach Avenue Los Angeles, California 90021
W. S. Shamban Company 116)7 West Jefferson Boulevard Culver City, California 90230
Vellumoid Company Rockdale Street and Beaman Avenue Worchester, Massachusetts 01606
The James Walker Packing Company, Inc. P. 0. Box 75 Chicago Heights, Illinois 60411
Filters and
Hoses
FILTERS Most standard oil filters are satisfactory. You can use active earth or clay types. Filter manu facturers include:
Briggs Filtration Division Bowser Corporation Cookeville, Tennessee 38501
Capital Engineering Company 5839 Ashland Avenue Chicago, Illinois 60610
Commercial Filters Corporation (Honan-Crane) Lebanon, Indiana 46052
Cuno Engineering Corporation Sub. of American Machine & Foundry 4627 S. Vine Street Meriden, Connecticut 06450
Dollmger Corporation 20 Centre Park Rochester, New York 14608
Fulflo Specialties Company, Inc. 410 Fancy Avenue Blanchesttr, Ohio 45107
Hilliard Corporation 98 W. Fourth Street Elmira, New York 14903
Marvel Engineering Company 7227 North Hamlin Avenue Chicago, Illinois 60645
Pall Corporation 32 Sea Cliff Avenue Glen Cove, L. I., New York 11542
Purolator Products 1000 New Brunswick Avenue Rahway, New Jersey 07065
Rosaen Filter Corporation 1776 E. Nine Mile Road Hazel Park, Michigan 48030
Schrotder Bros. Corporation 101 Nichol Avenue McKees Rocks, Pennsylvania 15136
Serfilco Division Service Filtration Corporation 7408 North Milwaukee Niles, Illinois 60048
HOSES Butyl, nylon, Viton or Teflon are preferred when new hoses are installed. Suppliers in clude :
Anchor Coupling Company 3600 N. Fourth Street Libertyville, Illinois 60048
Eastman Mfg. Company (See Imperial-Eastman Corp.) Department T. R. 6300 West Howard Street Chicago, Illinois 60648
Electric Hose & Rubber Co. 1201 Duro Street Wilmington, Delaware 19899
Gates Rubber Company 999 South Broadway Denver, Colorado 80217
Imperial Eastman Corp. 6300 W. Howard Street Chicago, Illinois 60648
Lewis Products Hohenwald, Tennessee 38462
Samuel Moore Co. Mantua, Ohio 44255
Resistoflex Corp. Roseland New Jersey 07068
Stratoflex, Inc. 222 Roberts Cutoff Rd. Fort Worth, Texas 76114
Weatherhead Corp. 302 E. 131st Street Cleveland, Ohio 44108
TEX GGG335
MONSANTO
D0505743
WATER PCB-SD0000061898
D0505744
Other Components
SWIVEL COUPLINGS
Systems for Turbinol fluids often contain swivel couplings. Some suppliers are:
Chiksan Division FMC Corporation 332 N. Brea Boulevard Brea, California 92621
PIPE JOINT SEALERS ... can be bought from:
American Sealants Company (See loctite Corporation) 115 N. Mountain Road Hartford, Connecticut 06111
Crane Packing Company 6410 Oakfon Street Morton Grove, Illinois 60053
Dow Corning Corporation Midland, Michigan 48640
Friesland Plastics Company Friesland, Wisconsin 53935
General Electric Company Insulating Materials Department 1 Campbell Road Schenectady, New York 12306
Permatex Company Department T. R. Flagler Court Building West Palm Beach, Florida 33401
W. S. Shamban & Company 11617 W. Jefferson Boulevard Culver City, California 90230
Shell Chemical Company 110W. 51st Street New York, New York 10019
'
ACCUMULATORS ... some systems for Turbinol con tain an accumulator which uses a bladder to separate the fluid from air or nitrogen pressure. For these, a rubber compatible with the fluid is necessary. Suppliers include:
Greer Hydraulics, Inc.
5930 W. Jefferson Boulevard Los Angeles, California 90016
PAINTS . resistant to Turbinol are sup plied by:
Amercoat Corporation Department T Brea, California 92621
Andrew Brown Paint Company 5413 S. District Boulevard Los Angeles, Cai>:ornia 90022
Carboline Company 32-R Hanley Industrial Court St. Louis, Missouri 63130
Carrol Products 148 Macine Street Farmingdale, New York 11735
Finch Paint 4 Chemical Company Torrence, California 90507
W. P. Fuller & Company 1645 W. Valencia Drive Fullerton, California 92633
The Glidden Company 900 Union Commerce Building Cleveland, Ohio 44114
Interchemical Corporation Finishes Division 1255-T Broad Street Clifton, New Jersey 07011
Lowe Brothers Company Third & Madison Streets Dayton, Ohio 45426
Magna Coatings & Chemical Corporation 1785 N. Eastern Avenue Los Angeles, California 90032
Nycote Laboratories 15002 Delano Street Van Nuys, California 91401
Pittsburgh Plate Glass Company One Gateway Center Pittsburgh, Pennsylvania 15222
Rinshed-Mason Company 5935 Milford Detroit, Michigan 48210
Royalty Paint & Varnish Company Pasadena, California 91101
Saran Protective Coatings Company 2415 Burdette at Reed Ferndale, Michigan 48220
Sherwin-Williams Company 101 Prospect Avenue, N. W. Cleveland, Ohio 44115
Titanine, Inc. Seagrave Corporation Elmwood & Morris Avenues Union, New Jersey 07087
U. S. Pa int, Lacquer 4 Chemical Comoany 2101 Singleton St. Louis Missouri 63103
SOLUBILITY WITH OTHER FLUIDS
Other Phosphate Ester and Phosphate Ester-Base
Soluble in all proportions
Petroleum Oils
Soluble in all proportions, but petroleum oil can reduce the fluid's fire resistance.
HEAT TRANSFER PROPERTIES
Specific Heat BTU/lb/F
60 F. 100F. 150F. 200F.
Thermal Conductivity BTU/F./ft/hr
60F. 100F.
150F.
200F.
ELECTRICAL PROPERTIES
Dielectric Constant @ 255C. @ 60 cycles/sec. @ 1000 cycles/sec.
Power Factor @ 2SC^ % @ 60 cycles/see.
<S> 1000 cycles/sec.
Specific Resistivity (ohm-cm) @ 25C. @ 100C.
TfcA CC0336
0.297 0.304 0.318 0.327
0.061 0.061 0.060 0.060
6.52 5.94
52.00
3.45
1.7 x 10' 2.0 x 10"
WATER PCB-SD0000061899
OISTRICT SALES OFFICES ALL DIVISIONS
AKRON, OHIO 44313
260 Springtide Drive Montrose Development Park Tel (216) 666-4111
ATLANTA, GEORGIA 30326
Lenox Towers Cast 3400 Paaeritraa Pd. N. 6. - Suite 1711 Tei. (404) S77-2260
BOSTON, MASSACHUSETTS 02149
Everett Station Tel. (617) 387-5010
CHICAGO, ILLINOIS
3158 Dea Plaines Ave. Det Plaines, Illinois 60019 Tel. (312) 296-6668
CINCINNATI, OHIO 45206
1501 Madison Poad Tel. (513) 751-6707
DETROIT. MICHIGAN 48235
500 Northland Towers East Tel. (313) 357-0910
HONOLULU, HAWAII 96812
205 Paeifie International Bldg. 677 Ala Moans Bh/d.. P. 0. Box 3824 Tel. (BOB) 531-2744
HOUSTON. TEXAS 77027
1301 Post Oak Tower 5051 Westheimer Poad Tel. (713) 621-9550
LOS ANGELES. CALIFORNIA 90022
6670 . FbtMe St TaL (213) 723-2492
NEW ENGLAND AREA
Hydrocarbons 6 Polymers Dry. 730 Worcester St.. Indian Orchard. Mass. 01051 Tel. (413) 788-6911 Plastic Products 8 Batins Dhr. P. 0. Box 2130. Springfield. Mass. 01101 Tel. (413) 788-6911
NEW YORK. NEW YORK 10017
277 Park Avenue Tel. (212) 922-4111
ST. LOUIS, MISSOURI 63166
800 N. Undbeegh Bhd. TaL (314) $94-1000
SAN FRANCISCO BAY AREA
2710 Lafayette. Sente Clara. Ca/d. 95052
TaL (408) 243-0414
SEATTLE. WASHINGTON 98121
2112 Third Avenue TaL (208) 622-4203
WILMINGTON. DELAWARE 19803
2005 Concord Pike. Fairfax Tel (302) 658-6531
Additional District Offices are maintained by :
AQriltBrel BMsias
ALLENTOWN. PENNSYLVANIA 1S1M Pvt Piolaeaionv Budding 2200 Harndton Stmt TaL (211) 417.M71
OECATUB. ILLINOIS 82S23 207 Oacatur Prefeeaional Building IBS South Mom Street TV. (217) 423.8031
OCS MOINES. IOWA 80310 312 Mario Hay Tower TV. (818) 278-8801
FPEMONT. NEBRASKA 88028 1 SO South MVn Street TV. (402) 727-1230
INDIANAPOLIS. INDIANA 48208 Suite 218. 4000 Meadow* Drive Budding TV. (317 ) 847-8148
KANSAS CITY. MISSOURI 84133 701 Blue Ridge Tower 4240 Blue Ridge Boulevard TV. (816) 183 8080
LULINO. LOUISIANA 70070 P. 0. Bob 174 TV. (SM) 784-6283
MANKATO. MINNESOTA 88001 111 MedAon Eott TV. (807) 387-1408
MEMPHIS. TENNESSEE 381M 301 Union Plau Budding 1838 Union Aeonue TV. (801) 276-7611
MUSCATINE. IOWA 82761 P 0. Bob 471 TV. (118) 283-1331
Hv4r8C8rfc8M i PalyMars Divitiao-liaa Oil
EL DORADO. ARKANSAS 71710 Uon Oil Budding TV. (801) 883-1111
JACKSON. MISSISSIPPI 38208 P. 0. Bob 10817. Weetlond Ststna TV. (SOI) 382-3848
N. LITTLE ROCK. ARKANSAS 72118 410 Weet 8th Siren. P. 0. Bob 8821 TV. (SOI) 176-2437
MEMPHIS. TENNESSEE 3S111 1023 Rivenrda Drive. P 0. Bob 13248 TV. (801) 848-4481
Offsets OMtiea (Baiter laitremeats)
AKRON. OHIO 44311 820 Brown Street P. 0. Bob 2307 TV. (216) 434-1882
Heatic PtedeeSs & Rosin Bimtai
EUGENE. OREGON 87401 P 0. Bob ISIS 888 Seneca Rood TV. (803) 142-7201
KENILWORTH. NEW JERSEY 07033 North Seventh St. 6 Monroe Ave. TV. (201) 276-2800
Taitiln lisisisB
ATLANTA GEORGIA 30303 Atlanta Merchandise Mart 240 Peachtree St. N. W. TV. (4M) 877-2280
CHARLOTTE. NORTH CAROLINA 28210 8230 Fnmsw Road. Suds 400 TV. (7M) 364-0110
GREENVILLE. SOUTH CAROLINA 28808 MeAdsut Plau P. 0. Bob 8884. Station 8 TV. (803) 238-8171
NEW YORK. NEW YORK 10001 ISO PMth Ave. TV. (212) 888-8100
MONSANTO
D0505745
I
I
fMt 1onsant1o
T EX coc:
Monsanto Company / Functional Fluids /800 North Lindbergh Blvd. / St. Louis. Missouri 63166
lOi -IIA~ Oft70
WATER PCB-SD0000061900
TEXAS jASTCR?; SVitaiKS
5HKEV.0RT. .C.:S;a.\A
To: Mr. ?.. Z. Moore
Subject: Lvaluaticr of the Fire Resistant Lubricant Pydraul 135
Monsanto Chemical Company has introduced Pydraul 135 as a candidate for application as a fire resistant lubricant in gas turbines. This fluid was evaluated in the fall of 1966 and ths results were forwarded ir. my memos dated October 11, 1966 and November 23, 1966.
A recent visit was made with Monsanto in their 3t. Louis facilities to discuss ths properties and application of this fluid in our system. This memo will present a resume of the data collected to date and the recommendations of this department.
Historical rackrrovnd
MCS-153, our present gas turbine lubricant standard, is formulated with a chlorinated polypheny! (Chlorinated aromatic hydrocarbon) and a rhcsr.hs.te "ester. The halogen, chlorine, is added to the hydrocarbon ring through chemical reaction to increase the fire resistant properties of the fluid. Additional chlorine molecules could be added to further increase the fire resistance, but ths viscosity of the fluid would increase rapidly. The phosphate aster, also a fire resistant lubricant, is added to increase the lubricity and viscosity/temperature characteristics of the mixture.
Phosphate esters exhibit excellent lubricating properties in film lubrication, good viscosity/temperature characteristics and excellent fire resistancy. The chlorinated polyphenyls exhibit poor viscosity/temperature characteristics, excellent thermal and oxidative stability, excellent fire resistance, and excellent ET1 or boundary lubrication. Therefore, the proper formulation of the two fluids creates a superior lubricant exhibiting the desired properties of both fluids.
Pydraul 135 is a chemical mixture of the chlorinated polypheny!, a phosphaoo ester, and petroleum oil. The petroleum oil was added to primarily lower the fluid cost, but it also enhanced the viscosity/temperature characteristics of the mixture.
010037983
WATERPCB-SD0000061901
VlOl !
]`s. 2. Mocr-3
June 23, 1913 Page 2
Physical Properties
A complete list of physical properties for booh MCS-1 53 and Pydraul 1;~ can
be furnished if desired. However, the basic differences in zhvsical crorertiss
exist in the viscosity/temperature characteristics, density, and the specific
heat. For our applications, the differences in the above prorerties favor
the Pydra'ul 135.
**
Lubricity
In all lubricating tests, Pydraul 135 exhibited superior rubricating properties over MCS-153, which equalled or exceeded petroleum oils in the sane tests.
Thermal and oxidative Stability
Because of its major constituent, chlorinated polypheny!, MCS-153 has proven to be extremely stable, both thermally and oxidatively. To date, none of the units using MCS-153 on our system have experienced an oil change because of excessive oxidation. Periodic tests have indicated little change in the neutralization number.
All laboratory tests on oxidation and thermal stability performed by Monsanto
have indicated that the Pydraul 135 should approach the stability of MCS-153.
Under extreme oxidative and thermal conditions, the lighter constituent of
Pydraul 135, which has a boiling point of A50^F, could be depleted by
vaporization. This condition is noted by an increase in the viscosity,
measured at 100?, of the fluid. However, the viscosity measured at ICC^'F
would increase fifty to seventy five percent, but the viscosity measured at
210F would increase only some ten to twenty percent. The .
39
returned ot its original composition by adding a small amour --
^ -- rc
boiling component. This was proven in laboratory test. Ur.: ' our opera:
conditions, this lower boiling component should experience :y little
vaporization. In the event sufficient vaporization does acc . C-i-.3_.-3 Jviscosity measured at ICO1*? to double its original value, a 1 O C11--= U T-V *
of the lower boiling component can be aided to the system, tne reoy res-o
the fluid to its original state. This means that the fluid 111 not rec
changing as we originally thought. Actually with normal mat no sjid cur
operating conditions, the life of the Pydraul 135 may equal or exceed 1CS-
Only actual operating test can determine this factor.
Fire Resistant Properties
Among all fluid properties, fire resistance is the most difficult to measure and the most controversial. There have been many attempts to standardize fire test methods, and although several similar test types have emerged from these attempts, there is still essentially no standardization.
010037984
WATER PCB-SD0000061902
Mr. R. E. Moors June 28, 19o3 Page 3
The fire resistant rating of a fluid can not be established by one or two tears alone, but must be evaluated from all ohe possible rests than are usuallv ran. For example, the AIT (Autogenous Ignition Temperature) for MIS--t =3 is 1 MOM while that, for Pydraul 135 is 760: . However, the AIT for Benoene, a
specialized fuel, is 12Q0F. Looking at the AIT only, ore would rate Benzene as the most firs resistant, but it is highly flamable and its heat of combustion is more than sufficient for Benzene to be self propagating. The flash point of .MCS-153 and Pydraul 135 is 360T for both fluids, while the firs ooint of Pydraul 135 is greater than 725F as compared to only =60? for MCS-1 53. .
For our purposes, the Hot Manifold Test is a good test for judging the fire
resistancy of a fluid. From our visual witness of this test at St. Louis, it
was apparent that MCS-153 has the advantage over Pydraul 135 by about 11 CM.
The Pydraul 135 would flash at aoouz 920-^7 v/ndls MCS--"53 wou-ld
-ibou"
1030?. However, at both temperatures and past 13C~F, neither fl'uid would car
flames to the fluid containing pan just below the manifold. This is explained
by the fact that both fluids are endothermic compounds. This means that heat
or flame must be applied for the fluids to burn. They do not emit sufficient
heat upon combustion to propagate flames.
Again, as in the case of thermal stability, we are locking at conditions that
should not be encountered in our system. The exhaust gases of the non
regeneratove turbines exit near 10C0F, but the exhaust piping is insulated and
jacketed to protect personnel. In most cases, temperatures in excess of 9C3?
are encountered only in case of a drastic failure, in which case the temperatures
encountered will also be in excess of ICC
The-re.or; the fire resistancy
of the Pydraul 135 is more than adequate for cur normal operations, and in case
of a drastic failure, the MCS-153 would also be subject to temperatures above
the fire resistant fluids are used in our gas turbine systems to afford aduutier.c_
protection when a disaster or failure occurs, ,`je iseu tr.at eutner f_uua vilu supply this protection in our system, "Wo :ydraul 135 is -isteu ov tne oncer-
writers laboratory as fire resistant.
Ads 2,nd Dls9.dv2r1b3.29s
Compared to MCS-153, Pydraul 135 is a better lubricant and represents a substantial savings in cost ($2.55/C-al vs 33-65/gsl LTL) . Also, this fluid
will be a standard stock item, while the MCS-153 usually is formulated when ordered.
The MCS-153 fluid appears to offer a slightly more stable compound and does require a somewhat higher temperature for combustion. This fluid is more viscous and requires special handling when at low temperatures. However, this has not presented any unusual problems to date. Both of the first' two advantages may not be significant in our applications.
Recommendations
V/e strongly recommend that the Pydraul 135 be given extensive field tests
010037385
WATER PCB-SD0000061903
Mr. R. E. Moore June 2S, 1963 Page 4
in one of our gas turbines. Since the las oo -unit
e:h:3E-:
to data, this would be the ideal menine t o use f or zeszlp.g zh$ fluid o
stability, and performance.i Monsanto has offered to supply the fluid, te
assistance, and a complete testing program for field casting this fluid . oarr
unsatisfactory preliminary results, the test should be run for several vears
to accurately determine the stability of the fluid.
The Pydraul 135 has been used by British Petroleum. in several steam tur with excellent results. Copies of the British Petroleum field tests ar'e avau for study.
Original S* V. Ni. STEPHENS
S?:jd
J. J. Ball F. P. Gertson F. V. Gordon C. V. Marvin D. S. Walsh V/alter Woods
W. M. Stephens
k
010037986
WATER PCB-SD0000061904
Monsanto
com ,.! * uocat,on. c . L. Bradford - 0. 0.
E
aerEBENCt
December 15, 1971
SANTOVAC 1 and 2/TURBINOL 153 TRANSITION PROGRAM
TO :
T. L. Gossage
Tom, attached are two memos to me from Roger Hatton outlining the steps that will be necessary to get out of the Santovac 1 and 2 business and the Turblnol 153 business. We will start on the Santovac 1 and 2 program as soon as you tell us the date we should get out of the business. Turblnol 153 will be coordinated with our total Pydraul program.
Your comments, please
/pep Attachments
C. L. Bradford
MONSANTO
D 0 5 0 6 181
1N O a V lie?
TEX CCC79?
WATER PCB-SD0000061905
MONSANTO
D0506182
Monsanto
-OW NAME & LOCATION.
R. E. Hatton - Q. 0.
T6 Subject
December 13* 1971 TURBINOL 153 PROGRAM
F E CNC t
TO
C. L. Bradford
A
- *v
/ , yr, f
s
The program to stop supplying PCB containing Turbinol 153 to Texas Eastern Transmission Corp. (our only customer) involves the following basic steps: a. inform them by personal visit that Turbinol 153 will not be available after June 1, 1972 (except under "hold harmless" conditions if necessary), b. sell them and General Electric on converting to MCS 1223 (all phosphate ester fluid) and c. assist in conversion and disposal of used fluid.
Successful accomplishment of this program involves a number of actions which are detailed below.
Visit to Texas Eastern should involve appropriate Monsanto personnel and Texas Eastern purchasing, operations and engineering groups. This visit should be scheduled to coincide with or closely follow the general Monsanto PCB announcements. ~
b. The cut-off date of June 1, 1972 should be firm. However, if turbine and gas com pressor change over from Turbinol 153 cannot be accomplished by then, a "hold harmless" agreement must be negotiated.
c. Conversion to MCS 1223 in gas turbines will require both General Electric and Texas Eastern approvals. Ve will probably need Texas Eastern help in expediting G. E. approval. Gas compressor OEM acceptance and/or approvals will be required but less difficulties are expected.
d. To Insure G. E. cooperation, their technical, engineering, production and marketing should be informed of our program promptly after the Texas Eastern visit.
>n io ecv ii es
Ttx CuG 79e
WATER PCB-SD0000061906
MONSANTO
D0506183
e. We should cooperate fully with Texas Eastern during the conversion and subsequent start-ups. Proper disposal of used Turblnol 153 must be arranged.
f. Field sales and turbine manufacturers other than 0. E. should be Informed of these actions and their reasons, 1) to prevent continued damage to our Image by "more chlorine/bearIng problems" and 2; to be sure all potential Turblnol 153 customers do not design to use this fluid and are aware of our all phosphate ester turbine lubricants.
/pep
R. E. Hatton
TEA GUO 799
WATER PCB-SD0000061907
CL(3
D0506184
C. L. Bradford
January 7* 1972 TURBDfOL 153 WITHDRAWAL PLAN
R. E. Hatton
REH Memo to CLB - 12/13/71 ,, CLB Memo to TM - 12/15/71
Turblnol 153 Program
* Santovac 1 & 2/Turblnol 153
Transition Program
T. L. Oossage B25L
. /'
\
Tom, supplementing Roger Hatton's and my previous memos to you, following is our plan for moving Texas Eistern Transmission Corporation away from Turblnol 153 and hopefully to one of our own substitute fluids.
Date
Action
1/14/72
Present our hold harmless agreement to Texas Eastern indicating that we will sell them no
more fluid after January 15* 1972 unless they sign this agreement, and In any case,, we will not sell them any Turblnol 153 after June 30, 1972. On that same date we would hope to present them a substitute fluid.
2/15/72
Start a field trial on an alternate fluid in one of Texas Eastern's turbines.
6/3/72
Begin selling Texas Eastern our new fluid and stop sales of Turblnol 153
Attached Is a copy of the hold harmless agreement which we expect to have Texas Eastern sign.
/pep
Attachment
C. L. Bradford
IfcA CCCeOC
WATER PCB-SD0000061908
MONSANTO INDUSTRIAL CHEMICALS CO St. Louis, Missouri
February 8, 1972
CALL REPORT NO. 1972-1
TEXAS EASTERN TRANSMISSION CORP. Milam at McNeil P. 0. Box 1612 Shreveport, La. 71130
cc : C . L. Bradford /
T. L. Gossage J. F. Herber L. R. Stark W. R. Richard
J. G. Frederiksen D. W. Stegen H. R. Ford P. L. Slayton D. R. Hansen E. L. Shimley
Date of Call: Present for Texas Eastern:
January 14, 1972
Walter Woods A. B. Jarnagin B. R. Purgitorio E. P. Farmer R. E. Moore D. H. Sloan E. C. Riall, Jr. Jack Simpon J. Y. Briggs
1 EXH,B^
1 d - T~
Present for Monsanto:
C. L. Bradford D. W. Stegen J. G. Frederiksen R. E. Hatton
!
SUMMARY:
Texas Eastern Engineering and Operational personnel were informed that Turbinol 153 will no longer be available to them without signing a Special Agreement letter. Texas Eastern will not sign such a letter and has sufficient material to finish out the current season. However, they will change from Turbinol 153 to another fire resistant turbine lubricant and expressed a willingness to work with Monsanto. They will provide one or more test units, pending G.E. approval, to field trial our product and to gain some operating experience before their entire system is changed
over from Turbinol 153
DETAILS:
The purpose of this call was to review with Texas Eastern Engineering and Operating personnel the situation caused by the discontinuance of Turbinol 153* Previous contact had been made with the Purchasing Department and a copy of a proposed Agreement had been submitted.
Texas Eastern personnel had reviewed their lubricant supply
<
situation and had determined they had at least sufficlent Turbinol 153 to complete winter and summer operations. A
more careful analysis will be made to determine the exact
IfcA OGUiib
n U N o M R I \J
D0505723
WATER PCB-SD0000061909
Call Report No. 1372-1
j
Texas Eastern Transmission Coro. !
Page 2
'i
time or depletion. This will be done on a statlon-bystation basis and include transferring new fluid around as required. A desire was expressed to order a small amount of additional fluid if it could be obtained before the deadline of signing the Agreement letter. However this was not possible and no additional fluid was supplied to Texas Eastern following our visit.
The environmental situation with the PCB containing
Turbinol 153 was discussed irt detail. Texas Eastern stated
that they would not sign the special Agreement letter. They
felt they would be able to continue to operate for a
sufficient period of time to make an orderly and satis-
factory changeover to another fluid.
We were asked concerning our replacement fluid and reviewed our total phosphate ester program aimed at providing chlorine-free hydraulic fluids and lubricants. It was stated that information on a replacement product would be available in 1-2 weeks and would be supplied in terms of a comparison with Turbinol 153* It was pointed out that these are relatively new products and that we do not have a large background of service, experience. They requested that we supply our test data as rapidly as possible.
One area of considerable concern was conversion procedures required to change from Turbinol 153 to any new product they select. Therefore, adequate data on compatibility between our new all phosphate ester fluid and Turbinol 153 must be obtained. It was their feeling that they could clean and drain their gas turbine units so that about 10# of the original fluid would remain in the system.
One necessary step before conversion is General Electric approval or at least acquiescence for the particular product to replace Turbinol 153. It was indicated that work is under way with General Electric, that they were aware of our phosphate ester program and had examined some samples of our material. Texas Eastern will also be in contact with General Electric to determine what mechanical changes may be made necessary in existing turbines. It was indicated that materials compatibility should be satisfactory but that the two fluids would have different densities and viscosities. Questions were asked concerning heat transfer characteristics since this is important in sizing coolers. It was emphasized by Texas Eastern that Monsanto should work very closely with General Electric to be sure that complete information exchange is obtained. In addition, they suggested contact with Clark, Cooper Bessemer, DeLaval and Westlnghouse for their approval on our new fluids. The
MONSANTO
D05057 24
TEX CCC3 It
WATER PCB-SD0000061910
Call Report No. 1972-1
Texas Eastern Transmission Corp. Page 3
first three companies supply the hatural gas compressors which are driven by the gas turbines, both using Turblnol 153 from a common reservoir. Westlnghouse has supplied one gas turbine which Is lubricated with Turblnol 153.
During the discussion, the Vice President of Engineering asked his people as to what steps would be involved in going back to petroleum fluids. Both Operating and Engineering personnel affirmed that fire resistance was the important characteristic and that they have no desire to use flammable lubricants at unmanned units. There also appeared to be a desire to cooperate with Monsanto on a new fire resistant product.
D0505725
/pep
R. E. Hatton
TEX G0Q317
WATER PCB-SD0000061911
MC >ANTO INDUSTRIAL CHEMICALS CO. St. Louis, Missouri February 11, 1972
CALL REPORT NO. 1972-11 TEXAS EASTERN TRANSMISSION CORP. Shreveport, La.
cc: C. L. Bradford T. L. Goasage - B2SL
J. F. Herber - T30 L. R. Stark - W4A W. R. Richard - T3A J. G. Frederlksen - 1460 D. W. Stegen - 1460 H. R. Ford - 1070 P. L. Slayton - 1650 D. R. Hansen - 1800 E. L. Shimley - 1010
Date of Call: Present for T. E.:
Present for Monsanto:
February 4, 1972
Walter Woods A. B. Jarnagin Bill Hartman Ben Means
John Frederlksen R. E. Hatton
SUMMARY:
Monsanto'8 all phosphate ester turbine lubricant MCS 1223 was discussed in considerable detail and compared with Turblnol 153 in a meeting held at the request of Texas -eastern, it was Indicated basically that this product should perform In their turbines and that General Electric
was aware of the product but that their approval would depend upon Texas Eastern's position.
Competitive fluids are also being considered by this group. They are also quite Interested In looking at a fluid in the 150 SSU range. Texas Eastern has been in contact with Trans Canada Pipelines concerning their experience with various fire resistant lubricants in gas turbines and is completely aware of the programs under development.
Texas Eastern has made no definite commitment as yet as to which fluids they will use to replace Turblnol 153. Continued attention to this account in terms of visits and additional data and coordination of efforts with their suppliers will be required.
DETAILS:
.
This meeting was called by Walter Woods to review the information provided on Monsanto1s all phosphate ester turbine lubricant MCS 1223 compared to Turblnol 153. This information
TcA CCuo7s
nuiM bA N I U
D0506263
WATER PCB-SD0000061912
Call Report No. 1972-11 Texas Eastern Transmission Corp Page 2
had been provided In bulletin form earlier in the week by John Prederlksen and resulted in this request for further discussion by the undersigned.
The meeting followed the format of a review of the properties of MCS 1223# particularly in terms of how they might relate to performance in Oeneral Electric gas turbines. It was quite apparent from the questions asked and from the information files that the attendees had with them that the competitive fluids are also being evaluated and that these are primarily the Fyrquel products.
The results of the undersigned's visit to the General
Electric Gas Turbine group in Schenectady were reviewed. It was pointed out that this group will probably not give approval but will hopefully indicate no objections to running actual turbine testa on MCS 1223 or other synthetic phosphate esters. It was also indicated that the G.E. Medium Steam Turbine-Generator group at Lynn had given Turblnol 50 approval for use in their electrohydraulic control units and that the Gas Turbine Department generally considered such approvals sufficient for their purposes
(control units only).
Each of the properties in the brochure were discussed In more detail and only the highlights will be reviewed here.
One particular area of concern seemed to be the rust inhibition characteristics. They indicated that they understood rust inhibitors had been added to MCS 153 sometime during its history. Since this was unable to be confirmed or denied by the undersigned, it was agreed that the past history would be reviewed on this subject. The rust seems to occur primarily on idle machines and Walter Woods and Bill Hartman both indicated that they had seen large amounts of rust on gears when Turblnol 153 was used. However, they do not really know that this has been a major or real problem and, as far as they know, has not affected operations in any way. Buck Jarnagln Indicated that he had been discussing the Trans Canada Pipeline experience with Paul Knight. Apparently these discussions have been quite extensive and frequent. He stated that Paul Knight says that Pullers Earth does not remove the rust inhibitors that are put in the competitive fluids. I indicated that this may be true if sufficient make-up fluid is added or if rust inhibitors of low acidity are used. Based upon these discussions it would appear that we need to be sure that
coordination between the Texas Eastern and Trans Canada test programs be full and open and that we work closely with both
D0506264
TfcX CCCeaC
WATER PCB-SD0000061913
D0506265
I
Call Report No. 1972-11 Texas Eastern Transmission Corp Page 3
groups. We must also examine the requirements and performance of rust Inhibitors In our proposed turbine lubricants.
Walter Woods pointed out that there appear to be some differences In fire resistance between MCS 1223 and Turbinol 153* This opening was used to Indicate why we had stayed so long with the chlorinated materials In spite of the opposition by certain units of General Electric. We indicated that the fire resistance of our MCS 1223 type fluids were equivalent in performance type tests to those of competitive products. Walter asked If we would be willing to run such comparisons in our laboratory for their observation. It was indicated that the laboratory would be made available together with personnel any time that they cared to come and watch or run such tests,
The area of stability and its meaning was reviewed with emphasis upon the Alcor test and the oxidation-corrosion data. This did not seem to raise any particular problems but neither did it seem overly important to them. However, it was pointed out that such type of testing Is extremely important to Trans Canada and will undoubtedly become more Important as higher powered machines such as the Frame 7000 G.E. units are put in operation. It was also indicated that the Trans Canada Westinghouse units were particularly critical in terms of such type stability as measured by coking in bearing housings.
In the area of lubrication it was pointed out that the LFW-1 test was considered to be of some importance by General Electric and that they might discover on discussing it with them that there was some difference as to test results. I Indicated that our results show that metallurgy and surface finish were important in determining comparative ratings of the fluids. I also indicated that this was only one laboratory teat and was not really indicative of field performance.
It was emphasized that we did not prepare "me too" fluids and did not expect our new phosphate esters to be equivalent in all respects to the competitive cresylic acid base products The advantages of our approach in terms of total stability and availability were emphasized and these points seemed to be of considerable interest to some of the ope rat ions people present.
The question of price came up and this group was told that MCS 1223 would be no higher in price than Turbinol 153.
TEX OGOeti 1
WATER PCB-SD0000061914
99290900
r\ I M W O M H I.I
Call Report; No. 1971-J.1 Texas Eastern Transmission Corp. Page 4
They asked for written confirmation of this and it will be handled through John Prederiksen and Don Stegen with the group in Shreveport as well as the Purchasing group in Houston.
Toward the end of the discussion the question of viscosity requirements for the General Electric units was brought up. Texas Eastern was told that we were working on a 220 Saybolt second fluid (MCS 1223) at the direct instigation of General Electric since this was their recommended viscosity level. Walter Woods stated that most of the units operating in the field that he had heard about were running on a 150 Saybolt second fluid and indicated that this discrepancy would have to be cleared up with General Electric. He asked if we could provide a 150 Saybolt second fluid and was assured that we would be most happy to do so and that we had done preliminary work on such fluids. A short data sheet on MCS 1121 and MCS 1122 was left with them. These two products are the ones which are under consideration by Paul Knight for use in the Trans Canada Pipeline fluid test and I had the distinct impression that they had been discussed between Jamagln and Knight. It was pointed out that we do not have complete data on these products since Trans Canada is primarily concerned with the results of the National Research Council testing as compared to other information which we could provide. It would appear that we should be prepared to offer Texas Eastern this type of product together with additional data.
At the end of the discussion Walter Woods indicated that they plan to get together very shortly with General Electric to determine exactly what needed to be done in order to shift from Turbinol 153 to the phosphate ester fluids. There was considerable discussion among the Texas Eastern group con cerning the necessity of changing impellers on the lubricant and hydraulic pumps. They do not feel that there will be any on the natural gas compressors on changing the lubricants. At the present time they are working out a program of how many and which units should be changed out and should be used as trial machines on phosphate ester fluids to cause minimum operational upset to their total system and also the timing Involved.
It was quite obvious that competitors are working hard to obtain selection of their fluid by Texas Eastern. However, there was no indication that a positive commitment had been made to any fluid at this time.
JbX CGuoec
WATER PCB-SD0000061915
I?
Call Report No. 197^-11
1
Texas Eastern Transmission Corp.
Page 5
One particular area of concern Is that of compatibility of the materials In the present Turblnol 153 turbines and the compatibility between MCS 1223 and Turblnol 153. Texas Eastern was told that they could top up the Turblnol 153 with MCS 1223 If this Is the way they desired to proceed. It was reported that after standing, mixtures of the two products in 10:90, 50:50 and 90:10 ratios showed a trace of material rising to the top which was identified as defoamer. This material separation was explained on the basis of the differing solubility of the silicone materials In the two base stocks. This related directly to experiences they had previously had and therefore created no problems. It was stated unequivocably that all the materials they have been using with Turblnol 153 can also be used with MCS 1223. During this compatibility discussion It was pointed out that Monsanto's basic position would be that they ought to drain the units as well as possible and then start operations on the new fluid. It was pointed out that this recommendation is based primarily on ecology considerations
and not on performance.
/pep
R. E. Hatton
MONSANTO
D0506267
I fc X C C G 0 <5 j
WATER PCB-SD0000061916
I
TSXAS SASTSE3*
INTER-OFFIC
c. c. *tAU.. jn.
SUPCRINTENOCN-T.
COMPRESSOR STATIONS
PP.HOON. EBO4X24-I0C1U11
OUice: Shreveport, Louisiana Date: February' 4, 1972
TO: Memo to Files
SUBIECT: File 3.20 - Monsanto Turbine Lubricant MCS 1223
On February 4, 1972 representatives of Monsanto and Texas Eastern met to discuss the above lubricant. Attendance was as follows:
Monsanto
Texas Eastern
Dr. Roger Hatton Mr. John Fredericksen
Mr. Bill Hartman Mr. Walter Vibods Mr. Benny Means Mr. A. B. Jarnagin
The attached brochure was discussed at length and the following points of interest -were brought out:
1. The new lubricant Monsanto is proposing to take the place of Turbinoil 153 is MCS 1223- '
2. MCS 1223 is a 220 grade lubricant. Monsanto stated that General Electric had expressed a preference for 220 grade lubricant as opposed to a 150 grade. The viscosity of a 220 grade lubricant may cause problems on start-up with cold oil. Monsanto can supply 150 grade lubricant also.
3. The MCS 1223 can be used with Turbinoil 153 as make up. This may not be advisable however since we would be operating with a lubricant containing PG3s for years to come. There would be no problem in changing from Turbinoil 153 to MCS 1223 as far as compatibility is concerned according to Monsanto.
D0307142
\
WATER PCB-SD0000061917
Memo to Files
2- -
Fe'crucry
1972
4. The MCS 1223 has not been used in turbines as of this date. Trans-Canada Pipeline is planning to test this product in
' one turbine starting this summer.
5. The price of MCS 1223 has not been established as of this ' date except that it will not be higher than Turbinoil 153
which is as follows (F.O.B. Ft. Louis):
2.000 gal. min. in bulk 24.000 lb. min. in drums Less than truck load drams
$3.55/gal. 3-75/gal. 3.85/gal.
!
ABJ:jnd
00307143
WATER PCB-SD0000061918
Monsanto r
JSS'V. iii i jj(....I .
CAtl REPORT-ORGANIC QIvlsioH
DICTATE IN SEQUENCE.-
1. HEAOING INFORMATION
2. NAMES OF ADDRESSEES
3. NAMES OF CARBONEES
4. IMMEDIATE ACTION NEEDED
5. REPORT ON CALL
"
CUSTOMER NAME
DATE OP Cau.
CITY ANO STAT?
OArE-MCEiveo
2/4/72
2AI6 TYPED
RHRFVF.'PrtR.T, LA______________________
2/1Q/72
CUSTOMER MAILING LIST CHANGES - SERVICE CENTER USE ONLY
NAME ANO title
Ijjr
ON
MP |MAG. CATEGORY CCCES
REPORT CAPTIONS:
1. OBJECTIVE 2. PERSONS CONTACTED 3. RESULTS 4. ACTION REQUIRED
Q v~W -
REGION
SOUTHERN
JO C. L. BRADFORD - ST. LOUIS
SERVICE CENTER
HOUSTON
CC D. W. STEGEN R. E. HATTON
SALESMAN
---------------- oo :c
IT G FREDERIKSEN Pr
oI dcor>::
CD -
O(
CONTACT: BUCK. JARNIGAN - OP. ENG . __ WALTER WOODS - ASS_!_T_CH^ENG___ JACK HARTMAN - ASS'T MGR COMPRESSOR STATIONS BEN MEANS - SR ENG.
CALLED WITH R. E. HATTON
OBJECTIVE: DISCUSS MCS~1223
RESULTS - MCS 1223 - Roger did an excellent job of discussing the comparison
between MCS 1223 and Turbinol 153. Time was quite short for Texas Eastern
people, so it was necessary to be very direct and to the point. In dis
cussing the typical properties, fire resistance, and performance properties
several points were given special attention by Texas Eastern people. They
were as follows;
1. Viscosity - They questioned the differences in low and high temperatui
viscosity versus 153. They also questioned whether pump impellers would
have to be changed using 1223. The concensus was that most of the pumps
used in their stations were positive displacement pumps versus centrifica.
pumps - however they were not sure. This was one point Texas Eastern was
going to check with G.E.
2. Additives - Roger stressed that this was a straight Phosphate Ester
with no chlorine, but which did contain an additive package. They asked
whether we had a rust inhibitor and was told "no" because fuller's earth
filters the rust inhibitor, they expressed that they want to have one
added to 1223 because of the large amounts of rust that form in the turbii
-d-ag-i-ag the--summer months.--They
rm* nnin that doasLJfajaJSffi--a--SalLLsj
1 exh.b,^ HAmkj
I - CENTRAL OFFICE COPY
TfcX CCC67t
WATER PCB-SD0000061919
Monsamrrr
DICTATE IN SEQUENCE:
1. HEADING INFORMATION
2. NAMES OF ADDRESSEES
3. NAMES OF CARBONEES
4. IMMEDIATE ACTION NEEDED
5. REPORT ON CALL
'
CALI REPORT-ORGANIC OiVISI
CUSTOMER NAME
TEXAS EASTERN TRANS.
CITY ANO STATE
PAGE TWO
~
SHREVEPORT
DATE RECEDED
DAT! Qf CAU. Date typed
CUSTOMER MAILING LIST CHANGES - SERVICE CENTER USE ONLY
name ANO TITLE
sir
MP MAG. CATEGORY CC0E5
REPORT CAPTIONS:
1. OBJECTIVE 2. PERSONS CONTACTED 3. RESULTS 4. ACTION REQUIRED
TO __________
earth filter.
REGION
SERVICE CENTER
cc
SALESMAN
O2
OO
Ui Z
O CO
CO >
rOo)
z
-t
-* O
3. Fire Resistance - The basic test for this were discussed very
birefly. Walter Woods expressed a possible desire of Texas Eastern
people to come to St. Louis to_see the fire resistance tests actually
performed on MCS 1223 and other Phosphate Esters. We indicated that
there would be no problem in doing this, and that they were to let us
know when they would like to visit St. Louis if they wished to do so,
4. ENVIRONMENTAL EFFECTS: F 1223 - Woods expressed a desire to know
the specific effects of 1223 on the land if it is spilled, the water,
air if it evaporates, or air if it burns.;^
5. Pricing and supply fcyii timing: They were very curious as to fcw what
our pricing would be, and_when we could deliver material. We indicated__
the price would be no more than for Turbinol 153, and thatwe would most
likely be able to deliver material within four to five weeks after the __
order is placed. There was some discussion regarding our material, which
is a 220 second material, versus a 150 second material.__ Woods was quite
confused on this particular point, thinking that MCS 1223 was a 150 second
material and that G.E. wanted Texas Eastern to use a 150 second material
Hatton indicated G.E. had recommended to him that They wanted a 220 second
material used in their turbins. This will be confirmed by Texas Eastern
with G.E., and we indicated we could make a 150 second liquid if_ required.
6. CHANGE-OVER - The question was raised whether MCS 1223 couId be added
S-J3I (UV. 12/M)
1 - CENTRAL OFFICE COPY
TEA CCCU 7 7
WATER PCB-SD0000061920
.r
DICTATE IN SEQUENCE:
1. HCADING INFORMATION
2. NAMES OF ADDRESSEES' 3. NAMES OF CARBONEES
4. IMMEDIATE ACTION NEEDED
5. REPORT ON CALL
"
CUSTOM NAME CITY ANO STATi
REPORT CAPTIONS:
1. OBJECTIVE 2. PERSONS CONTACTED 3. RESULTS 4. ACTION REQUIRED
REGION
REPORT- ORGANIC DfVf:
TEXAS EASTERN- - SHREVEPORT
PAGE THREE
DATE DECEIVE!)
DATE OF CAU
1
OAIE TYPED
name ano title
TUT
ON
oW
MP MAG
Category cooes
SERVICE CENTER
SALESMAN
TOCC _ __ AS TOP OFF material for Turbinol 153. Roger indicated he thought it would
probably be possible to do this,, but from an environmental standpoint, it
_ would be to their advantage to change the materials out completely.
Roger stressed our advantages of our independent synthetic source of raw_mater
ials, our superior thermal stability, and our reduced amount of residue as
shown_by_the Alcor test. Though rather rushed, it seemed the group was quite
satisfied with the information supplied to them. The next step is Texas Eastern
going_to_G.E. to have other guestions answered.
It was rather obvious from discussions that those attending had done their home
work on other Phosphate MasSas esters, and that 1223 was being compared directly
to them. Woods indicated that price would not be amajor factor, but that it
may^ come into play. Woods also said he_recognized our advantages _in thermal _
stability.
________
_ . ___ . .
___ . .
FUTURE ACTION JGFCheck with Woods for progress
Mid Feb
JGF/pr
____John G. Frederiksen _ CO_ /&uUi_
MONSANTO
D0506262
S MI (DEV. 12/64)
1 - CENTRAL OFFICE COPY
TEX CCCo 7o
WATER PCB-SD0000061921
MonsanBr^r
CALL REPORT-ORGANIC Dl
DICTATE IN SEQUENCE:
|. HEADING INFORMATION
2. NAMES OF ADDRESSEES
3. NAMES OF CARBONEES
4. IMMEDIATE ACTION NEEDED
5. REPORT ON CALL
"
CUSTOMER NAME
DAfE OP CAU
Texas Eastern Transmission Coro.
CITY ANO STATE
'
0AT6 RgCEiVEO
7-24-72
oati rvpgD
Shreveport. La._____________________________ 8-3-72____ 8-3-72___
CUSTOMER MAILING LIST CHANGES - SERVICE CENTER USE ONLY
NAME ANO TITLE
^ J g/J 1
|MP |maC
CATEGOPv C00E5
REPORT CAPTIONS:
1. OBJECTIVE 2. PERSONS CONTACTED 3. RESULTS 4. ACTION REQUIRED
REGION
Southern
JO Cummjhg patprf - St. Louis __ cc
SERVICE CENTER
Houston
SALESMAN
J. G. Frederiksen/em
J. Armentor - Houston R. E. Hatton -8it. Louis
CONTACTED: Walter Woodsy Asst. Chief Engineer
Buck Jarnigan - Operations
Ben Means - Sr. Engineer
__
Called with R. E. Hatton
f EXHIBIT 1
OBJECTIVE: Cbtainarf initial" trial of Turbinoi 1122.
RETSULTST~TURBINOET11T2: We presented-two pieces of information regarding Turbinoi 1122:
1-. General Electric had established that they favored a 150 second fluid and'that we recommend'Turbinoi 1122 to Texas Eastern.
2- Turbino!- 1122 does have rust inhibitor package added to it which
keeps_the fluid clear, will probably not be filtered out by Fullers earth filter, and which-enhances the stability of the product.
All concerned'were very inter ested~~in the information, and it was received
very favorably. It came very clear that both operations and engineering
were both in favor of" trying Turbinoi 1122. They have both decided to
recommend Turbinoi 1122 be ;used in replacing Turbinoi 153 at the Barton,____
Ala. pump station. This will require 3400 gal. fluid as the fill, plus
about 1500 |al. of flush fluid. Woods, however, cautioned us not to be __
absolutely certain we would" have this fill because his recommendations to
upper management were no_t always taken. Operations said they would proceed
with filling the Barton Station with 1122 until they were told not to.
Peesently, Barton will be changed out sometime in September^
__________
Woods is quite anxious to try different types of fluids so that Texas________ _ Eastern can purchase the best, as we11 as to maintain competition in the turbin lubricant field. He mentioned several times that he thought we____ __ would" Rave"an advantage over Stauffer rs fluid, and was anxious to try it. .
Woods'brought up one crftfcalTquestioh - what "responsibility would Monsanto take if the Environmental Protective Agency--told Texas Eastern to stop uslhg `Turbinot 153 Immediately. This question heeds to be answered. They have -cuusuwud n,Udt) gals. of Turbinoi 153 in six months, and have now
49",Odd gals, in inventory.
Woods" requested a price quote for Turbinoi 1122 in which the rust inhibitor
_ should_he_ mentioned^ He. asked_for_ sl pticje_E0B. plant_and also a delivered -- Barton. Ala, plant price because Stauffer1s prices are on a delivered basis.
131 ,"EV' '3/4"
1 - CENTRAL OFFICE COPY
T EX CCC89 7
WATER PCB-SD0000061922
Wwisairtr^* ^- ^CAli REPORT -- ORGANIC DIvTsiO?
DICTATE IN SEQUENCE:
1. HEADING INFORMATION
2. NAMES OF ADDRESSEES.
3. NAMES OF CARBONEES
4. IMMEDIATE action needed
5. REPORT on CALL
'
REPORT CAPTIONS:
1. OBJECTIVE 2. PERSONS CONTACTED 3. RESULTS 4. ACTION REQUIRED
CUSTOMS NAME
,
Texas Eastern Transmission Com.
, DATE OP Cau"
1 7-24-72
CITY ANO STATE
OATE RECEIVED
3a!E rr-PEO
8-3-72
8-3-72
CUSTOMER MAILING LIST CHANGES - SERVICE CENTER USE ONLY
NAMg ANO TITLE
PUT ON
^ | MP MAG 1
CATEGORY CCCES
j'
REGION
SERVICE CENTER
SaiESmaN
J. G.
j;
Frederiksen/em
TO Page 2.___________ ________ ______ CC_______________________________
_ ___ . _
FUTURE ACTION: REH -_E_s tablish-Monsanto/ s position,.on_. ETA/PCB.1. ASAP____
REH - Letter to Woods carljon copy_Riall_ summarizing_rust. inhibitor in 1122 - ASAP
"" JGF - Letter to Woods copy to Rial! re 1122 pricing - ASAP
JGF - Check Stauffer price to Texas Eastern with Riall week of July 31.____________________________________________________
JGF/em
n I M W O M A I,
S-331 (REV. I2/4|
o-
cn
O
05
ro
CD
ro
- CENTRAL OFFICE COPY
TEA CCUoSo
WATER PCB-SD0000061923
MONSANTO INDUSTRIAL St. Loui3, Missouri August 2, 1972
CALL REPORT NO. 1972-23 TEXAsTaSTERN TR Sheaveport-y -LouisianaDate of Call: Present for Texas Eastern:
Present for Monsanto:
-c: T. L. Gossage
C. Paton
J. H. Davidson
W. R. Richard - T3A
.
L. R. Stark - W4A
J. F. Berber - T3G
J. G. Prederlkaen - 1460
J. Armentor - 1460
H. R. Ford
July 24, 1972
Walter Woods Ben Means Buck Jamigan
John Prederlkaen Roger Hatton
ixHisy^ f-fajJn U~ JO
MONSANTO
D0506250
SUMMARY:
Operations and engineering working levels at Texas Eastern
are Interested In using Monsanto's Turbinol 1122 or 1223
in a field trial In the next gas turbine to be converted
from Turbinol 153. This will probably be the unit at Barton,
Alabama sometime In September. This decision is subject
to review by their management. Price, trade relations and
Monsanto's position on the PCB problem are Involved. We
must continue efforts to Insure a field trial of our products.
DETAILS:
The purpose of this call was to present the latest Information on Monsanto's phosphate ester turbine lubricants and to deter mine Texas Eastern's Intentions on a field trial.
Monsanto recent activities on gas turbine fire resistant
lubricants were reviewed. Texas Eastern personnel were particularly concerned with the reports of my visits to
General Electric. It was pointed out to them that the gas turbine groups at G.E. have finally settled on a 150 SUS at 100*P. fluid such as Monsanto's Turbinol 1122. General
Electric personnel have made this selection based upon viscos ity similarities to their present petroleum lubricant and
the fact that bearing losses are approximately 45ft greater for a 220 SUS phosphate ester fluid and 15ft greater for the 150 SUS fluid as compared to the petroleum oil. It was pointed out that the original G.E. preferences for the 220 SUS fluid had been greatly influenced by the group at Lynn who are more concerned with gear lubrication than with Journal bearing lubri cation. It Is still generally agreed throughout General
Electric that the heavier fluid would be more satisfactory from the gear lubrication standpoint. Texas Eastern indicated that they would probably go along with the General
Electric recommendation but that they were still Interested in Monsanto's Turbinol 1223, a 220 SUS fluid.
IcX GGGobo
WATER PCB-SD0000061924
M U N S A N IU
D0506251
Call Report No.1972-23 Texas Eastern Transmission Pago 2
Remaining questions from previous visits were discussed. One concerned the possibilities of wire wooling with phosphate esters and it was reported that General Electric had only raised this as a question and that no data are available on any of the phosphate esters. The differences in product performance in the bench scale LFW-1 test were noted. General Electric now believes that this test may not be completely meaningful and are conducting a series of low speed "turning gear" tests on all competitive products. The group at Texas Eastern was not aware of this work.
..
Some comments were made during the discussion concerning the change in General Electric attitudes toward the fire resistant lubricants in gas turbines. Texas Eastern personnel stated positively that General Electric did not have any objections to using our fluids and were quite Interested in obtaining field tests on them.
Texas Eastern reported that they have changed out two units from Turblnol 153 to the Pyrquel fluids. They are using Fyrquer"2S<[R`>n4-0 in the Huntsville unit. At the time of . changeover, some mechanical modifications were made in the compressor area. They have had some difficulties in main taining lubricating system pressure with the pumps recommended by General Electric. At this stage Texas Eastern does not believe this is due to the field. They are using Pyrquel 150R and 0 in the Yazoo unit. Here no mechanical changes were made and operations have been quite satisfactory. However, Texas Eastern was quick to point out that there has not been sufficient time to develop any real operating experience. They feel that at least 6 months will be required to get meaningful data.
It was reported to Texas Eastern that Turblnol 1122 is now formulated with a rust inhibitor and that combined with Its already good oxidation characteristics it is a superior "R40" fluid to the Pyrquel R and 0 products. Oxidation corrosion test data were presented on Turblnol 1122 and the competitive products* Performance in the General Electric film tenacity test was described and it was indicated that Turblnol 1223 passes this test without additional additives and that we will therefore supply Turblnol 1223 without an additional rust inhibitor. Texas Eastern was quite pleased to learn that we did have products which were good on rust inhibition and offered Increased stability. Walter Woods volunteered that he felt, based on all the data, that the Monsanto turbine lubricants were the most stable products on the market and that he would like to see them run in a turbine.
t
TfcA uCGoc J
WATER PCB-SD0000061925
Call Report No. 1972-23 Texas Eastern Transmission Page 3
Walter Woods posed a direct question as to what Monsanto'3 responsibility would be, along with Texas Eastern's, If the EPA banned PCB's and told Texas Eastern that they would have to change out all remaining units. It was Indicated that this problem would have to be discussed with our management and that we would provide an answer. During this discussion they Indicated that they have reduced their stock of Turblnol 153 from approximately 60,000 gallons as of January 1 to 49,000 gallons. It Is their present Intention to continue to operate with Turblnol 153 moving It from station to station until It Is essentially all consumed.
Walter Woods requested that we give him a price quotation In writing for Turblnol 1122 and Turblnol 1223. They would like this In terms of P.O.B. plant and P.O.B. delivered, for example to Barton, Alabama. We confirmed the previous statements that the prices would be no higher than those for Turblnol 153* It was Intimated this figure was probably somewhat high compared to competition because of differences in delivery costs and ways in which prices are being quoted. We stated that we could have product available In a week but would like 30 days notice if possible. They Indicated that they had used about 1500 gallons of Pyrquel as a flushing charge which will be used to flush other turbines and will eventually be worked off In actual operation. The charge in the turbine is about 1500 - 2000 gallons.
Walter Woods stated that both Mobil and Humble have contacted Texas Eastern promoting their fire resistance turbine lubricants and that both are applying pressure to Texas Eastern to purchase through them. Both companies are distributors for the Pyrquel fluids and Texas Eastern Is well aware of this. Both Mobil and Humble are major customers of Texas Eastern. During these discussions Walter stated that he would like to try at least two different types of products and therefore would recommend a Monsanto product trial.
At the conclusion of the meeting Jarnlgan indicated that we would get a field trial unless somebody specifically told them not to. Walter Woods said that he would recommend our product but that this did not necessarily guarantee a field trial. Totally it appears that the operations and engineering people at the working level are convinced that we have good products and are very Interested in having a field trial occur. If there is any opposition it must be at some higher level and efforts will be made to determine if this is the case.
TEA CCCetJb
WATER PCB-SD0000061926
D0506252
".ill Report No. 1972-23 Texas Eastern Transmission Page 4
On the basis of the discussions three things must be done. First, a price quotation must be furnished in about a week. Second, a letter must be written to Walter Woods summarizing our discussions and third, Monsanto's stature in terms of the PCB government problem must be resolved.
/pep
R. E. Hatton
MONSANTO
D0506253
3
TEX G C C d 69
WATER PCB-SD0000061927
1
MEMBERSHIP LIST Study group on Fire-Resistant Turbine Fluids
Tech C, ASTM D-2
Ch. Sec. .
Name
Knight, R. G. Hatton, R. E. Cantrell, T. L. Fletcher, 0. M. Furby, N. W. Glassman, N. Katzensteln, Wm. Kottcamp, C. F. Lewis, H. D. Manley, L. W.
Mathe, J. A. McBride, R. B. Megahan, F. N. Millett, W. H. Shatynski, J. J. Shibe, W. J. Skoglund, R. D. Teeter, F. C. Vona, J. A. Whirl, S. F. Zabetakis, M. G.
Affiliation
Duquesne Light
Monsanto
Gulf Research
Texas Eastern Transmission
California Research
U.S. NEES
General Aniline and Film
Gulf Research
Consolidated Edison
_
Socony
l
E. F. Houghton
General Electric
Philadelphia Electric
Uhion Carbide
Celanese
Hollingshead
Texaco
Sinclair Research
Celanese
Duquesne Light
USBM
D0138134
(
000907826
WATER PCB-SD0000061928
I- exhibit!
Ifk&d'ii.
MINUTES OP MEETING
FIRE-RESISTANT TURBINE FLUIDS STUDY GROUP
I
Technical Committee C ASTM Committee D-2
Atlantic City, New Jersey June 25, 1963
The Fire-Resistant Turbine Fluids Study Group met June 25, 1963 in Atlantic City with 65 members and guests in attendance. Chairman R. G. Knight presided.
Minutes of the previous meeting heId June 28, 1961 were read and approved. The membership list of the Study Group was presented and additions and corrections made.
Chairman Knight indicated that the meeting would be devoted to discussions of experience with fire-resistant turbine
lubricants in a prepared agenda. These minutes include brief abstracts of the various presentations and summarize the discussion from the floor.
. >
1) Laboratory Tests for Effects of Fluids on Electrical Insulation
Mr. J. C. Botts of the Westinghouse Electric Corporation reviewed the area of electrical insulation with respect to its influence on the use of fire-resi3tant fluids. It was pointed out that insulation is always subject to accidental exposure by the fluid and that a number of factors are involved in determining fluid-elastomer com patibility. Problems with currently Installed machines would be much more difficult than those with newly built
machines. Both mechanical design and new insulation systems can make the compatibility problem easier to
handle.
Mr. Botts pointed out that insulations in the older machines include shellac bonded micas and a number of varnishes. Many of these materials are not resistant to the fire-resistant fluids. In recent years various syn thetic resins have been developed which are nearly as resistant to fire-resistant lubricants as asphalt is to
petroleum oils. Only two approaches exist to the
000SC7S15
D0138123
WATER PCB-SD0000061929
Page 2
problem---one involves coating the entire windings which must give 100% coverage and in obtaining satisfactory co-efficients of expansion for all materials. The second approach is to use resistant materials.
Mr. Botts believes that there would be no more problems with current insulations and fire-resistant lubricants than those previously existing with petroleum oil. Westlnghouse will work with anyone who desires such lubricants, but the customer must accept some of the cost and risk.
Mr. R. B. McBride of the General Electric Company presented
a review of their work with fire-resistant turbine lubri
cants, starting with initial screening in 1953. A number
of departments have continued to work in this area. Based
on their initial screening, it appeared that the phosphate
ester and phosphate ester-chlorinated hydrocarbon formu
lations offered the most promise for fulfilling turbine
requirements. Most General Electric work has been focused
on these types although others have been examined. Con
siderable study has been made of the effects of such
-
fluids on generator insulating materials. The tests use<
have varied from simple exposure immersion tests to large-
scale electrical and mechanical tests of major components.
The introduction of new insulation systems resistant to
fire-resistant fluids plus the knowledge gained concerning
satisfactory substitutes for minor items makes the picture
much brighter, and General Electric is confident that new
machines can be built that would satisfactorily withstand
these fluids. Changeover of machines now in service is
not recommended.
General Electric does not feel that protective coatings are the answer to the compatibility problems of older equipment. Mr. McBride pointed out that, although they felt that the problem of insulating generators was well in hand, problems in other areas have been uncovered which have prevented the installation of commercial units. One involves severe scoring of shafts under some conditions with fire-resistant lubricants. He indicated that they do not have complete understanding of the phenomena but have considerable evidence that the scoring is started by foreign material. Once the process is started, it feeds on Itself, causing increasingly severe scoring. The scoring problem is elusive because it only occasionally occurs and is very difficult to reproduce. This area is continuing to be studied.
000907816
00138124
WATER PCB-SD0000061930
i
Page 3
Mr. McBride also reported 3ome difficulties with rusting when using fire-resistant turbine lubricants. The rust ing occurred only in those sections from which the fluid had drained. Wherever the fluid was trapped, there was no rusting. Suitable rust inhibitors are under investi gation and are being evaluated in various tests, until such a time as these problems have been solved, General Electric is postponing any commitments to customers to actually install units with fire-resistant lubricants.
Laboratory test procedures were discussed. General
Electric indicated that they run exposure tests in
laboratory and in full-scale components at room tempera
ture and 100C. Westinghouse indicated that their tests
involve various dip and spray methods on test panels.
Actual sections are also tested in vapors, bulk liquid,
and sprays. Westinghouse also has run some tests on
insulation materials in motors, particularly with regard
to carbon dust pick-up.
-
Most of the work on rusting has been done with the ASTM v method or in full-scale components.
2) Use of Fire-Resistant Fluids in Gas Turbines
Mr. 0. M. Fletcher of Texas Eastern Transmission Corpor ation reported on their experience with fire-resi3tant turbine lubricants in gas turbine-compressors used in natural gas transmission. Texas Eastern started their * work in 1958 because of the hazards involved and because of the requirement to maintain all units on the line since no spare equipment exists. Mr. Fletcher stated that all new gas turbines Installed by Texas Eastern will use fire-resistant turbine lubricants. The gas turbine and the compressor use the same fluid system. Full-flow
filters are used before the fluid goes to the bearings and seals. Micronic filtration is also used on the seal and control systems. In four units which have bare metal throughout the system, no rust has been experienced. These unit3 breathe air while standing idle for 7-8 months of the year. Mr. Fletcher presented a table which sum marized their experience with gas turbine operation and
this table is attached to these minutes. Each of the installations was reviewed in detail. Mr. Fletcher stated that some difficulties had been experienced but that all of the so-called failures which had originally been blamed on fluid were found to be due to other causes.
'
000907817
o
u CD
K
WATER PCB-SD0000061931
Page 4
The tachometer generator on these units was coated with
epoxy materials and had no problems with attack by the
fire-resistant lubricants. Foaming difficulties were
corrected by providing the proper vents and by the use
of foam suppressors. Their pipeline is internally coated
with epoxy materials; the particular ones they use are
quite satisfactory and have caused no difficulties. Mr.
Fletcher also indicated that they have as yet never dis
carded any of the fire-resistant fluid because of
deterioration.
Mr. Fletcher feels that circumstances have occurred which would have resulted in fires if petroleum oil were being used. However, they have been unable as yet to obtain any reduction in insurance for the use of this material. In answer to questions from the floor, Mr. Fletcher pointed out that there had been no shear with the fluid and that their lubrication system operated at around 60 psl and the seal system at about 1,000 psl.
3) Application of Fire-Resistant Fluids in Lubrication and i
. Control Systems of Steam Turbo-Generators
'
Mr. E. G. Noyes, Westinghouse Electric Corporation, pointed out their experiences with the use of fireresistant lubricants. Mr. Noyes stated that in the mid30's they had used Aroclor in the control systems of unit3 at Philadelphia Electric Company and at Public Service Company of New Jersey. Performance was satis factory but viscosity-temperature relationships were poor and there were some questions with regard to toxicity. Westinghouse is presently studying fire-resistant fluids in new types of control systems operating at 1600-1800 psi with vane pumps. The first two fluids studied sheared too much. A fluid which does not contain a VT improver is now being evaluated.
Mr. Noyes indicated that the increased density of these fluids gives problems in the lubrication area. Increased heat losses, which amount to as much as 20-30 BTU's per kilowatt are caused by the higher density.
Mr. Noyes indicated that they have been operating a boiler feedwater purr$> for five years on a fluid which does not contain a viscosity index improver. Performance has been satisfactory thus far and they plan to use a similar product in their control system. Westinghouse plans to
000907S18
D0138126
WATER PCB-SD0000061932
Page 5
provide units having oil in the lubrication system and firerresistant fluid in the control system. Major prob
lems to acceptance of fire-resistant lubricants throughout the system are reduction in the heat rate and contamination problems.
A number of questions from the floor were discussed by the speakers. Mr. McBride said that the scoring problems occurred under very heavy loads and that they felt that contamination was certainly a major factor. The good solvent characteristics of the fluid also entered into this. The heat loss problem was reviewed by the Westinghouse representatives. It was suggested from the floor that the lubrication system might be redesigned so as to reduce this loss. It was reported that a pipeline in Canada using synthetic lubricants in their gas turbines had to shift to a lower viscosity grade in order to obtain satisfactory operations.
4) Comments by Fluid Suppliers
.
Dr. Hatton of Monsanto Chemical Company Indicated that current field experience with Monsanto's fire-resistant
turbine lubricants has been in gas turbines operated by Texas Eastern as reviewed by Mr. Fletcher. Rust inhibitors were said to be available which will operate in lubrication systems and work is underway to evaluate some of these more completely. It was also pointed out that the toxicity of these fluids has been studied and that the necessary pre cautions have been recommended to all users. Monsanto plans to continue their work in this field and is quite hopeful of obtaining large-scale steam turbine use.
Mr. J.'A. Mathe of E. F. Houghton 3s Company pointed out that this is an extremely slow-moving field and that the major problem appears to be a lack of field activity. Customers have just not given active participation in the program. Mr. Mathe questioned the use of current rust tests and felt that work should be undertaken by Technical Committee C to develop rust procedures which are more applicable to the fire-resistant type of materials.
Mr. T. G. Smith of the Celanese Chemical Company reported that a phosphate ester fluid is being used in pipeline applications with gas turbines in Canada. Eventually, sixteen stations will be in operation with several turbines
000907S13
D0138127
WATER PCB-SD0000061933
I
Page 6
per station. They are now using a 150 SSU fluid. Mr.
Smith feels the remaining problems are insulation com patibility and rusting. Rust inhibitors are available which perform satisfactorily in the fluid phase but none have yet been developed for vapor phase rust protection. Mr. Smith also pointed out that various European-built turbines are operating with fire-resistant fluids in their control systems.
5) Report on Field Test3
Mr. Fletcher reported that in addition to those applica tions he had discussed, phosphate ester fluids are being used in a number of Cooper-Bessemer RT-248 units in pipe line service. It is thought that three such units are now in operation.
Mr. Knight Indicated that their test work on two fluids in boiler feedwater pumps is continuing and that operations have been completely successful. Chairman Knight plans to issue a summary of applications of fire-resistant tur-*
bine lubricating fluids and requested additional input from the Study Group members.
Considerable comment was made concerning the problems of
dirt in the systems. Filters are used in many cases. General Electric plans to use a filter before each bearing with fire-resistant lubricant to surmount some of these problems. Mr. Fletcher pointed out that Texas Eastern had had the same problems as with petroleum oil and
generally followed the same practices, which include full-flow filtration. Special filtration, including some magnetic type filters, is used on the seal oil and
control systems.
Mr. Botts pointed out that what is really needed from the equipment manufacturers viewpoint is motivation to do the work. Equipment with fire-resistant lubricants will cost more money at the present time, but primarily because of the large development cost3 Involved.
6) Discussion of Future Work
Chairman Knight reviewed the past history and past aims of the Group, pointing out that development of fireresistant turbine lubricants was undertaken in 1954 as the result of some rather serious fires and some very
000907820
D 0 1 3 8 1 28
WATER PCB-SD0000061934
Page 7
Intensive interest by the utilities. A number of comments were received from the floor as to the future activities of. the Study Group. It was generally agreed that the meetings of the Study Group should be continued because they have served as an excellent way to distribute lnformation and to keep people up-to-date on current develop ments. It was pointed out that much of the selection of fluids had been based on tests developed for petroleum type products. Probably new tests specifically designed for fire-resistant types of fluids will be required.
Mr. R. Q. Sharpe, Chairman of Technical Committee N,
Section II on Industrial Uses, stated that his group was
reviewing test procedures used for fire-resistant materials.
He felt that the requirements in the turbine lubricant
and hydraulic fluid applications are somewhat similar
and that there is a need for exchange of information
between the two groups. Section II has recently prepared
a report indicating status and need of various types of
tests and this report was made available to the Study
Group. A copy is attached to the minutes.
It was agreed that the Study Group should be continued and that a meeting should be held in 1-2 years to review progress and problem areas.
/pz
R. E. Hatton, Secretary R. G. Knight, Chairman
D0138129
000807821
WATER PCB-SD0000061935
Socoay Mobi. " Oil Company, Inc. 150 East 42nd Street New York 17, New York
June 26, 1963
MEMBERS SECTION II TECHNICAL COMMITTEE N
ce: Members Advisory Committee - Tech N Members Technical Committee C
At the January, 1963 meeting of Section XX, it was agreed that the writer would appoint a small study group to again review existing ASTM methods and their applicability to the round-robin
test fluids involved in Technical Committee N activities. This study group consisted of:
R. Q. Sharpe, Chairman - Socony Mobil Oil Company, Inc. K. Q. Henrikson - Socony Mobil Oil Company, Inc.
John Shatynski - Celanese Corporation John Hkaga - Union Carbide Company
The committee comments refer to the applicability of test methods to the following test fluids:
1- A-l 2- B-l 3- C-l 4- D-l 5- D-l 6- E-l -
Petroleum Oil Water Base Phosphate Ester Halogenated Base Phosphate Base Oil Emulsion
It should he emphasized that these comments are not Intended to cover other fluids or other fields of application that may not ordinarily be categorized as industrial.
Attached is a brief summary of comments concerning the approval of existing test methods, or the indicated need for additional information or work in connection with the principal chemical or physical properties of the lubricants involved.
It will be very much appreciated if you will provide us with your comments concerning the attachment. It will be our intention to consolidate suggestions that are received for correction or addi tion and prepare a complete release for discussion at the next meeting of Section II in Atlantic City in January, 1964.
During the panel discussion of Technical Committee C on their experiences with fire-resistant fluids, it was indicated that they would be interested in essentially the same products and methods falling within the scope of Section II. We are therefore providing the Secretary of Technical Committee C with sufficient copies of this letter and attachment for distribution to their members
RQS/es Attachment
Technical Committee N
WATER PCB-SD0000061936
D0138130
I
SUMMARY AND COMMENT ON TEST METHODS INVOLVING INDUSTRIAL HYDRAULIC FLUIDS
CHEMICAL OR PHYSICAL PROPERTY API Gravity 0 60 P Viscosity SUS <9 100 F Viscosity Centiatokes 6 100 F Viscosity Conversion Viscosity Temperature Chart Viscosity Index Color Flash Pour Point Rust Resistance
Liquid Phase Vapor Phase Corrosion
Oxidation Stability
Thermal Stability Neutralization Value
ASM TEST D-287 D-aa D-445 D-446 D-3^1 0-567 0=1500 D-92 0-97
COtftfENT
O.K.
O.K.
O.K.
O.K.
O.K.
O.K.
O.K.
O.K. for non-aqueous fluids.
O.K.
-
D-665 --
D-9^3
-- D-664
O.K. for non-aqueous fluids.
An acceptable test method required. Refer to Section IX.
Should be a standard method to determine weight loss, pitting, or other forms of chemical attack applicable to metals commonly found in hydraulic systems. 'Refer to Section IX.
Ask Section VIII for an up-todate report on their work and discussion of the applicabi lity to industrial test fluids A short-term test is highly desirable.
Mark by Section VIII should continue.
Reasonably acceptable, but one supplier is studying an indi cated need for better repro ducibility and definition of end point of D-664 and D-97^ with synthetic fluids.
000907823
D013813
WATER PCB-SD0000061937
2
CHEMICAL OR PHYSICAL PROPERTY Hydrolytic Stability
Compatibility Rubber or Elastomer SveU Tests
With Other Environmental Materials
With Other Fluids
Lubricating Properties
Fire Resistance A.I.T Spray Flaamability Static Liquid Flammability Bench Test
Toxicity Foam Test Shear Stability
ASM TEST --
COMMENT
A report from Section VIII Is required as to whether they are ready to recommend the beverage bottle test as a standard. Work should continue on other methods that evaluate fluid stability in the presence of water.
D-286
-- D-892 --
An up-to-date report on the status of this work is required.
An up-to-date report of the
status of this work is
required.
-
%
No new recommendation deemed necessary--continue general screening test reported in 1961.
Work should continue--need still exists. Need clarifi
cation as to whether Tech L is actively pursuing the development of methods for bench testing that would be applicable to industrial hydraulic test fluids.
Need better method. RD XIII reviewing modified method now.
Need for method still exists.
Need for method still exists.
Need for method still exists.
Not within the scope of Tech N.
o.K. 000907824
Wbrk should continue--need still exists for a simple bench method to define this. Research Division VII should be advised.
DO1 5 8 1 3 2
WATER PCB-SD0000061938
CHEMICAL OR PHYSICAL PROPERTY
Vapor Pressure
'
3
ASTM TEST ---
COMMSMT
A method is needed that is applicable to both petroleum and synthetic industrial fluids.
D0138133
B. Q. Sharpe June, 1963
000^07825
VJ -- - *
WATER PCB-SD0000061939
Earl,
X+lAiimi - !j
J
Roger Hatton of Monsanto gave the following information about solvents for PCS:
1. Kerosine has been used for flushing heat transfer equipment involved in PCS related operations.
2. Kerosine or higher boiling hydrocarbons are better solvents than methanol. However, the kerosine or hydrocarbons should be as aromatic as oossible, i.e highly paraffinic materials are not effective sol vents for PCS.
3. Any solvent is only as good as the contact we can achieve. Mechanical aspect of the flushing opera
tion is very important.
4. Make sure the solvent will not attack the coating of pipeline.
5. Disposal of the solvent after use would be a poten
tial problem.
"
/
D034614
010037863
C-i
WATER_PCB-SD0000061940
Consideration is being given to disposing of a large quantity of Monsanto MCS-153 fire resistant lubricant. We are concerned with how to properly detoxify or dispose of this material due to its polychlorinated biphenyl (PCB) content.
We have been advised that Monsanto at one time provided a disposal service for such material at your St. Louis, Missouri, installation. Will you please let us know if Monsanto still provides this or some other approved disposal service for this material at St. Louis or at another location. If you provide such a service, please advise us the details of how we may avail ourselves of the service.
Any assistance you can give us in this matter will be greatly appreciated.
Very truly yours,
Original Signed CUF WILLIAMS
Clif Williams
CW:eo bxc: l.Y. Briggs
`'itT E. Moore W. T. Young
12-3-75 - ELC Distribution: Mr. E. C. Riall Mr. Gerald Walker Operating Department Reading File
000844865
WATER PCB-SD0000061941
00142502
Monsanto
MONSANTO INDUSTRIAL CHEMICALS CO. 800 N. Lindbsrgh Boulevard St. Louis. Missouri G3I66 Thone: (314) 694-1000
OfC 1 v 1375
Vjij
SPCCIALTr a PPOCCSS chcuicals chvision
December -8, 1975
Mr. Clli' Williams Texas Eastern Transmission Corp. ryZ'j Milam
P. 0. Box 1612 Shreveport, Louisiana 71130
- BXHIBjjr^
( t/j&hlfcJS'
Dear Mr'. Williams:
Your recent letter requests information concerning the
disposal of Turbinol 153 (MCS 153) fire resistant turbine lubricant. This lubricant as vou indicated does have polychlorinated biphenyls (PC3) as a major ingredient and
proper disposal is recommended.
Monsanto does offer an incineration service for PCB con taining materials. Attached is a copy of a letter usually sent with labels to those wishing to use the disposal service. Mr. Clif Field is the coordinator of the program and can orovide you further details. 'His phone number is
(314) 6.94-3024.
If you have further questions, please contact Clif Field, Ken Rosenberg (314) 694-4357) or myself.
Very truly yours.
R. F.. Hatton Technical Manager Hydraulics & Lubricants
cc: C. R. Field - Monsanto Co.
DO1 4 2 4 9 8
a untl of Monsanio Company
' 000844861 WATER PCB-SD0000061942
Moii>anto
....................
r
L. Bradford/N. T. Johnson November 17, 1971 CHLORINATED TSP.FHENYL3
TO T. L. Gosaage
? EXHIBIT ,
I/ / ^
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i __
We have given considerable thought to your posed question what would happen should v;e completely remove polychlorinated biphenyls and polychlorinated terphenyls from our industrial fluids. Following are our observations.
TURBINOL 153
We have one customer for this ?C3-containlng product, Texas Eastern Transmission Corporation. They use it a3 a lubricant in 18 or so turbine-compressor combinations, each installation being worth $l!7 or more. They ara the major supplier of natural gas to the East Coast including New York City.
To our knowledge, there is no approved fire resistant lubricant that can directly replace Turbine1 153* The best candidate would be a straight phosphate e3ter, but for a reasonable change-over General Electric (the turbine manufacturer) should first approve the product and then Texas Eastern would probably require 5,COO hours of running time before agreeing to the switch.
it*. e ev i se
TEX G0U3Ci
WATER PCB-SD0000061943
2" To avoid the possibility of shutting this pipeline down, and/or causing such a great expense to this customer that they would sue us, we recommend giving them 8 months grace from the time G. E. has approved an alternate fire resistant fluid - hopefully our own straight phosphate ester. In addition, we recommend Monsanto absorbing the cost t incinerate their current charge of Turbinol 153 (estimated at 54,000 gallons - a cost to Monsanto for incineration and freight equaling $27,000) plus providing them a free charge of straight phosphate ester, should they decide to remain with us. Our 1972 budget for this product is 325,000 pounds at $107,000 - all of which we expect to lose if we withdraw from the market with less than the notice recommended above.
IfcX CCC3C*
WATER PCB-SD0000061944
WATER PCB-SD0000061945
TiX CcCiCb
WATER PCB-SD0000061946