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IN THE MATTER OF: TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY Cause No. 94-CI90145 Deposition of DA VID WOOD NOVEMBER 10, 1995 Gore & Perry Reporting Company 100 North Broadway, Suite 1175 Saint Louis, Missouri 63102 ..... (314) 241-6750 621-4790 (800) 878-6750 Full GLOSSARY included with this DepoScript WATER PCB-SD0000024893 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY Deposition of DAVID WOOD NOVEMBER 10, 1995 _______ ' Page 195 C OMMONWEALTH OF KENTUCKY ROWAN CIRCUIT COURT CIVIL BRANCH TENNESSEE GAS PIPELINE COMPANY. Plaintiff. vs. NO. 94-090145 _______ Page 199 Ml DAVID WOOD, (2i of lawful age, MONSANTO COMPANY. having been first duly sworn to pi testify Defendant. ' Continued deposition of DAVID WOOD, taken on hehalf of the Plaintiff, at the offices of Gore & Perry Reporting Company, 100 North Broadway, in the City of St. Louis, Suite of Missouri, on the 10th day of November 1995 before Ronald A. Gore, Registered Professional Reporter and Notary Public. the truth, the whole truth, and nothing but [4] the truth in the case aforesaid, deposes and says in {ij reply to oral interrogatories propounded as follows, tl to-wit: m EXAMINATION (8i QUESTIONS BY MR. DUFF. (9i Q: Good morning, Mr. Wood. [loi A: Good morning, :Page 196 APPEARANCES OF COUNSEL: tiii Q: I wanted to remind you this morning that you [121 are still under oath. FOR THE PLAINTIFF: Mr. Kevin B. Duff Hedlund, Hanley & John Sears Tower Suite 5700 Chicago, Illinois 60606 ' FOR THE DEFENDANT: Mr. Roily L. Chambers Smith, Helms. MuUiss A Moore 237 North Tryon Street Charlotte, North Carolina 28202 Do you understand that? [i3|A: Yes, I do. [i4|Q: Mr. Wood, what did you do to prepare for nsj your deposition that took place both yesterday and iisi is going to take place today? . (i7i A: I met for a two or three hour . session with iiq Mr. Chambers. [i9] Q: When was that? [mi A: On Wednesday. 121] Q: Did you look at any documents during that [221 two to three hour time period? [23i A: We glanced at some of the documents that you [24] had indicated that INDEX PAGE ________________ Page 197you might be presenting to me, ps]just to freshen my memory some of this period many Examination by MR. DUFF 199 Page 200 liiyears ago. EXHIBITS pi Q: Did you review any transcripts of pi depositions or trial testimony? Exhibit No. 285 Exhibit No. 286 Exhibit No. 287 Exhibit No. 288 Exhibit No. 289 Exhibit No. 290 Exhibit No. 292 Exhibit No. 293 Exhibit No. 294 Exhibit No. 295 Exhibit No. 296 Exhibit No. 297 Exhibit No. 298 Exhibit No. 299 Exhibit No. 300 Exhibit No. 301 Exhibit No. 302 Exhibit No. 303 Exhibit No. 304 Exhibit No. 305 Exhibit No. 306 207 210 214 219 220 222 227 247 249 254 262 270 278 284 291 298 Page 198 300 308 314 323 328 [4jA: I didn't review them. He indicated that you [5] had requested, I think, a transcript of the [6| testimony I gave in the Transwestem trial. I m didn't look through it. Pi Q: Did anybody go through that testimony with pi you in the Transwestem case? [101 A: No. (inQ: Did anybody go through any testimony that [121 you had given previously? [is] A: No. [Hi MR. CHAMBERS: Let me interpose an [is] objection. I assume you're not asking about any [ii consultation that Mr. Wood had with counsel? (i7) MR. DUFF: I'm not asking you to divulge any nq attorney/client discussions or anything that would [191 otherwise be privileged. 1201 MR. CHAMBERS: Okay. 1211 MR. DUFF: Do you understand that? 1221 A: I understand that, yes. [23i Q: Did you have any discussions with anyone 1241 besides Mr. Chambers regarding your deposition in 1251 this case? (il A: No. _________________Page 201 (2i Q: Did you discuss your deposition with Mr. piPaton? [4[ A: No. [si Q: Did you tell Mr. Paton that you were being isi deposed yesterday and today? m A: Yes. Pi Q: Did you tell him anything else about your pi deposition here? [io[ A: Yes. [inQ: What else did you tell him? [i2] A: That it was going slowly. [isi Q: Anything else? (i4i A: No. [isi Q: When did you first meet Mr. Paton? [i6l A: In late 1973. (i7) Q: How do you recall that it was at that time? [isi A: Why do I recall that it was in late '73? [i9] Q: Yes. (2oi A: Because he talked to me about my moving from pn Brussels to the United States with Monsanto to work [221 for him, and I moved in February of 1974, so I [23[ recall that the first discussion and the first (241 meeting I had with him was late in 1973. [25i Q: And when you returned to St. Louis in the ______ _______ Page 202 (il beginning of 1974 you reported to Cumming Paton? pi A: When I went to St. Louis. I didn't return pito St. Louis. (4i Q: Excuse me. When you went to St. Louis in (sj the beginning of 1974 did you report at that time to [6i Cumming Paton? pi A: Yes, I did. pi Q: What was his position at that time? [9[ A: He was a market manager. That may not be no] the precise title. But he was a manager in the [in marketing department of the specialty chemicals or [121 functional fluids group, whichever it was called at ipi that point in time. U4| Q: Was he the business director for the 1151 functional fluids group? [16] A: I don't recall whether he was a business ijtj director at that point or whether he was a manager, (isi Hierarchial management changes these titles rather iwi fluidly, and I say, I don't Gore & Perry Reporting Co. St. Louis, Missouri (314)241-6750 621-4790 Page 195 - Page 202 WATER PCB-SD0000024894 Deposition of DAVID WOOD NOVEMBER 10, 1995_____ TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY recall whether he had a (201 director title at that point. 1211Q: When you moved to St. Louis in the beginning (221 of 1974 you were the international market manager, [231 correct? 124|A: That's correct. {25| MR. CHAMBERS: I object to the form. I Page 203 til think it's international market manager, [21 dielectrics. Maybe I'm wrong. [3] MR. DUFF: Functional fluids, I believe. (4|MR. CHAMBERS: You're correct. I stand 13i corrected. Thank you. [61 MR. DUFF: I'd like to return your attention m to the time period that we were focusing on [si yesterday afternoon, in 1966 and 1967. Did Dr. pi Kelly - strike that. Did you have many [101 conversations with Dr. Kelly during that time [i 11 period? [121 A: No. ..... 113] Q: Did you have less than ten conversations [uiwith Dr. Kelly during the time period from November nsjof '66 to the end of 1967? [i6] A: It was certainly less than 20, it was more 1171 than five. Whether it was less than ten, I can't [is] recall. [9] Q: Do you recall if during that time period Dr. [201 Kelly ever told you that -- strike that. Do you (211 recall if during that time period Dr. Kelly ever (221 expressed an opinion regarding Jensen's findings? 1231 MR. CHAMBERS: I object to the form. [24i A: I don't recall any specific statement that [23] he made of a personal feeling about Jensen's work. Page 204 m MR. DUFF: Did he ever express a (2i professional feeling about that? [3i A: Are you talking in a telephone conversation 14) as opposed to in a written communication or -- [S]Q: Either. li A: If it was in a written communication, it's m probably on the record somewhere. I don't remember [8] in our telephone calls having a formal discussion of pi any sort with him where he laid out for me any (ioi professional opinion about the quality of Jensen's nuwork. [121Q: In 1966 and 1967 am I correct in saying that [is] Dr. Hardy was Dr. Kelly's counterpart in London? iMi A: You are partially correct. Dr. Kelly headed [i3] up the medical function at Monsanto headquarters in (ii St. Louis. Dr. Hardy's role was more of a one man [17] band situation in Europe. It was a much smaller [isi department, therefore. But to the extent that he (i9| had some of the similar responsibilities for [20| supporting the Monsanto operations with giving [211 support in the areas of product safety and [221 toxicology, yes, you could say that he was a mi counterpart. More an extension than a counterpart. 1241Q: Prior to your move to Brussels you and Dr. [2Ji Hardy were in the same office, correct? Page 205 m A: Yes. [21Q: And when you moved to Brussels, did he stay pi in London? Pi A: Yes. [5] Q: After you moved to Brussels, you continued [6i to correspond with Dr. Hardy on a regular basis in m 1966 and 1967, correct? [8i A: No. I corresponded with Dr. Hardy when I (91 needed his support. [ioi Q: Did you correspond with Dr. Hardy regularly mi on the subject of Jensen's findings in 1966 and [12] 1967? [i3i A: I was not aware of Jensen's findings until [i4i the end of 1966, not through -- I'm just trying to im be accurate here. (ioi Q: I understand. [i7] A: From the time that. [is] Q: I'll rephrase the question. (i9i A: From the time that I became aware of [201 Jensen's study through 1967, then from time to time pi|1 would be in communication as the -- as things [22] evolved with Dr. Hardy. [23i Q: Who was Robert Keller? [24] A: I know the name. I'm finding it difficult [23] to place Bob in the Monsanto organization at that Page 206 (il point in time. I think he was in St. Louis. And I pi know he was a scientist. But his specific role, I [3] don't recall at this point. (4]Q: What type of scientist was he? [3] A: I don't know what his educational background [6] was. p] Q: Do you know what his responsibilities were (si within Monsanto at that time? l] A: Notclearly.no. (ioi Q: Do you know what type of science he was mi involved with at Monsanto at that time? (i2|A: No. (13] Q: Do you recall any conversations with Dr. [i4] Keller in 1966 or 1967? [i3] A: No, I don't. [16] Q: Who was Scott Tucker? [17] A: Scott Tucker was another scientist within [isithe Monsanto U.S. organization who became involved, ii9| and I don't know exactly when he became involved, in (201 the development and evaluation of analytical [211 technology. [221Q: What do you mean by analytical technology? 1231 A: The detection, categorization and [24i quantification of chemical materials. [25] Q: Did that include PCBs? Page 207 Hi A: I know that at a point in time -- and, [2] again, I don't remember exactly when -- Scott was pi very heavily involved in chlorinated biphenyl work. [4] Q: Do you recall when the first time that you is] spoke with Scott Tucker was? [6i A: No, I don't. I know I have spoken with m Scott Tucker. But when was the first time I spoke [si to him, no, I don't recall. [9] Q: Please mark this as Exhibit 285. [ioi ( Plaintiff's Exhibit 285 [in marked for identification). [i2] MR. DUFF: Mr. Wood, this document has been [i3| marked as Plaintiffs Exhibit 285 and bears [i4i production number TRAN 056615. Do you recognize [151 this document? [16] A: Not clearly. [17] Q: Have you seen it before? [is] A: I believe I have, but I'm not sure. (i9i Q: Did you see this document in preparing for [20] your deposition? [2i] A: Again, I have, over the years, seen so many (22] documents from various institutions, I believe I [231 have seen this document, I believe it may have been [24] one that passed across my sightline while I was [23] preparing, but -- Page 208 (il Q: Could you please identify this document for pi the record? pi A: I have been handed Exhibit 285, which is a m letter from the Ministry of Technology in London to (si Dr. Hardy at Monsanto Chemicals Limited at their [6] office building in Victoria Street, London, and it's m dated 23rd of February 1967. Pi Q: Do you recall if Dr. Hardy gave you a copy [9] of this letter? (ioi A: No, I don't. duQ: Do you know who J.O'G. Tatton is? [12] A: No, I don't. [13] Q: Are you familiar with the Laboratory of the (i4j Government Chemist? us] A: I know it exists. [i6] Q: Are you familiar with the work that they do [17] at that laboratory? [is] A: They're involved in advising the Page 202 - Page 208 Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 WATER PCB-SD0000024895 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY Deposition of DAVID WOOD NOVEMBER 10, 1995 British ini government on technology peaks on gas chromatograms when using matters. [isi electron capture detectors? |30| Q: Is this the leading laboratory in [iq A: I became aware of that, but I London -- [21] strike that. Is this the cannot claim [i7] that I can recall leading laboratory in Great 1221 Britain? specifically on what date and by iisi what 1221 A: No. media I became aware of that. [24i Q: Is it one of them? Strike that. [i9i Q: Did you become aware of that In 1967 |23i was it one of the leading fact shortly [201 after February 27, 1967? laboratories in Great [211 A: I don't know. Page 209 [221Q: Please mark this as Exhibit 286. mi Britain? [23] ( Plaintiff's Exhibit 286 [241 marked 12] MR. CHAMBERS: I object to the for identification). form. (231 MR. DUFF: Actually, I'd like to I3i A: I find it difficult to appraise the return to hi standards of quality of English Page 211 laboratories in 1966 |5] and '67, so, I [i] Exhibit 285 for just a moment. can't give an objective evaluation of [q Directing your [21 attention to a phrase where they would rank in the hierarchy that's used in the middle of pi the of (7i laboratories. second paragraph, do you know -- isi MR. DUFF: Did you respect the [4i A: Second paragraph, the one that work of this [9j laboratory in 1967? starts "As [si you are aware"? [ioi A: I had no reason to be [6i Q: That's correct. What is an disrespectful of it. mil mean, I couldn't electron capture pi detector? say that I regarded it highly or 1121 -- I [8i A: I'm not familiar enough with mean, one would hope that a that technology [9| to give you a clear government 1121 laboratory had a certain layman's description. I know it [ioi is a level of reliability, but I iui think that piece of equipment which is involved in one has seen over the years that [151 the [in detection of organic or inorganic government laboratories are not always compounds in [121 analytical technology. flawless. [i3i Q: Do you know if Monsanto 116IQ: Were you aware that the possessed such a (ui detector in Februaiy Laboratory of the (171 Government of 1967? Chemist in London had been doing -- H5i A: I don't know. had [isi been examining selected food, [i6l Q: I'm handing you a document human tissue, wildlife (191 and other that's been (i7| marked as Plaintiffs things for organochlorine pesticide [201 Exhibit 286. And I apologize, [i8]I residues for some years prior to the date don't have a -- actually, I guess I of this [211 letter? already gave [i9iyou an extra copy. This [221 A: I became aware of it. document bears production taoi number [22i Q: How did you become aware of TRAN 055798. Mr. Wood, do you that? recognize this [21] document? [24[ A: By discussion with Dr. Hardy. [221 A: I have seen it before. [23i Q: What did Dr. Hardy tell you I23i Q: Do you recall when you saw this about that fact? document? Page 210 [24i A: No. [il A: I'm sorry, can you repeat that? [2si Q: Did you see this document in [21Q: What did Dr. Hardy tell you preparing for about that fact? __^Page 212 [2| A: That he had had some lil your deposition? communication with the w Laboratory [21 A: Yes. of the Government Chemist and that they pi MR. DUFF: Off the record, m isi had, indeed, had some activity in the (Discussion off the record). area of [6] examining tissue for pesticide [si MR. DUFF: Mr. Wood, I'd like to residues. direct your [6] attention to Exhibit 277, (7i Q: Did he tell you anything else? which we marked pi yesterday. Do you [8i A: Not that I -- not that I can recall have that in front of you? today. [8|A: Yes, I do. (9i Q: Did he tell you that he had [91Q: Directing your attention to the received this [101 letter from the -- strike third [ioi paragraph of this letter, do you that. Were you aware mi that the see where it says [111 "Added to this letter Laboratory of the Government Chemist you will find a pre-print of nzi the in [121 London had found that wildlife in synopsis of our publication which will particular often [i3i contains a number of appear in 1131 Actachem. Scand.", which compounds which produce a mi series of is A-c-t-a-c-h-e-m. [i4i S-c-a-n-d. "in the summer of 1967", do you see that? 1151 A: Yes, I do. [iqQ: And does that refer to what's been marked as [171 Plaintiff's Exhibit 286? (isi MR. CHAMBERS: I object to the form. [i9i MR. DUFF: If you know. [20|A: I don't know. As I recall from my testimony [211 yesterday, I told you I wasn't familiar with this (221 letter, and I told you a moment ago that I had seen 1231 this, but I can't make any connection between the [24i two exhibits. [25i Q: Exhibit 286 -- __.Page 213 [II A: Are we finished with 277? [2i Q: You can set that aside. Exhibit 286 is the [3] exhibit that we just marked a moment ago. [4i A: I see. [5i Q: And this is a document which is titled [6] "Pesticide analysis, presence of polychlorinated m biphenyls at residue analysis of biological [si samples", correct? [9] A: That's what my copy shows. (ioi Q: And it's a synopsis by Soren Jensen and (niGunnar Widmark, is that correct? [121 A: That's what it states. [i3[ Q: And this synopsis states that at analysis of iui samples from the Swedish wildlife fauna by means of [isi gas chromatography, using both electron capture [iq detector and micro coulometric detector, a large [171 number of unknown, but clorine-containing compounds (isi have been detected together with the ordinary (i9j pesticides? [2oi A: That's the first sentence, yes. [2i] Q: And the synopsis goes on to say that mass (221 spectra of some of these compounds obtained at a [231 combined gas chromatograph mass spectrometer [24] (LKB-9000) indicate that most of the unknown [25] compounds are polychlorinated biphenyls, potentiated ^.Page 214 HI somewhat in nature towards those of higher degree of [21 chlorination.. Pi A: That's what it states. [4i Q: And this synopsis also states that a large [5] number of samples have been examined and iq polychlorinated biphenyls are found especially in m fish and in sea birds, but also in needles of (si conifers and in some samples of human depot fat? [9i A: That's the opening sentence of the second (ioi paragraph. li 11 MR. CHAMBERS: You're not going to read the [121 rest of the document, I take it? Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Page 208 - Page 214 WATER PCB-SD0000024896 Deposition of DAVID WOOD NOVEMBER 10, 1995 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY [i3i MR. DUFF: I'd like to have this document (ui marked as Plaintiff's Exhibit 287. [i5]( Plaintiffs Exhibit 287 [ii marked for identification). (iTi MR. DUFF: Mr. Wood, this document has been (isi marked as Plaintiff's Exhibit 287 and bears (wi production numbers TRAN 055792 through 94. Please [201 take as much time as you need to familiarize 1211 yourself with this document. (22|A: Yes. 1231Q: Do you recognize this document? [24] A: Today I do, yes. (25) Q: Would you please identify this document for Page 215 [ilthe record? [2i A: This is a letter from the Institute of (3[ Analytical Chemistry at the University of Stockholm, pi Sweden, and it's dated February 27, 1967, and it was [5i addressed to Mr. Gene C. Wilde in the plasticizer [6] sales department of Monsanto Company in St. Louis, pi Missouri, and it was signed by Gunnar Widmark. (8i Q: Did you receive a copy of this letter on or pi about February 27, 1967? lioiA: I don't believe I did. mi Q: Why is that? [i2i A: Because I have many of the letters that [i3i we've examined, I recall when I did receive, you [i4] know, a copy of them. This was a particular [is] correspondence that I find it difficult to recall n<n having received a copy at that time. I've become [i7] familiar with this document because I've been shown [is] this document on a number of occasions, but I don't [i9] recall having received a copy of this letter in [201 February of 1967. t2ii Q: Did you know in February 1967 that (22) chromatograms such as the one attached to this (23) letter demonstrated the increase of higher (24) chlorinated PCBs through a food chain and the (25] decrease of lower ones? Page 216 in MR. CHAMBERS: I object to the form. [2] A: I was aware that in various summaries of pi Jensen's work that I had seen at that period of time (4i that one of the statements that routinely appeared [5] talked about an experience which Jensen described as [i potentiation of higher chlorinated species, and that pi was puzzling to me. Pi Q: Widmark was Jensen's mentor, is that (9i correct? [101 As As I understand it, Professor Widmark was a [indepartmental head and Mr. Jensen was one of his (121 graduate students. Whether they would have [i3| described at that time that as a mentoring role, [ui certainly it would be a sponsorship role. It's not [is] uncommon in science that a departmental head's name (iqwill appear on the papers of his research students. [i7iQ: What was Eugene Wilde's position at that [is] time? [i9i A: I had been familiar with Mr. Wilde for many [201 years throughout my career in Monsanto. What his [21] role was in February of 1967, I can only make a [221 supposition that Dr. Widmark was writing to him in rsi his capacity as described in the letter of being [24] involved in the plasticizer sales department of psi Monsanto at that point in time. But Eugene held __ Page 217 [i 1 responsibilities over the years in many different [21 Monsanto divisions. - ui Q: Are you familiar with the lindane theory [4| that is referred to in this letter? [5i A: Can you draw my attention to the reference? [6] Q: It's at the bottom of the first paragraph, pi Do you see where it says "The chromatograms added to pi this letter demonstrates that the increase of the (9i higher chlorinated PCBs through a food chain and the [ioi decrease of the lower ones, this is against the mi lindane theory"? [121 A: I don't know of a theory by the name of the mi lindane theory. [ui Q: Are you -- strike that. Were you aware of [is] a theory relating to lindane that existed around [i<s] this time that was discussed in the context of [i7] Jensen's findings? (isi A: No. (19) Q: What is lindane? [201 A: Lindane was a chlorinated pesticide. Its [211 precise formula, I can't remember. [221Q: Did Monsanto manufacture lindane? I23i A: I believe not. [24i Q: This letter indicates that Ola Palm met with [251 Jensen in January 1967, is that right? Page 218 m A: The letter that, referring to Exhibit 287, (21 Widmark states that while he was in Germany Mr. Palm pj had contacted Soren Jensen, and -[4i Q: Did you meet with Soren Jensen at the same (si meeting? [6] A: Mr. Palm, from our discussion yesterday, had pi a number of meetings with Jensen. I had a meeting (si with Jensen. Whether the meeting that Widmark is pi alluding to was the one that Palm and I attended (ioi together, I don't know. [ill Q: Do you know if Palm met with Jensen at any [121 time when you were not present? mi A: Oh, yes. [i4| MR. CHAMBERS: I object to the form. mi A: No, but I mean, I am aware because I asked [i6i Palm for follow-up information and he met Jensen to [17] obtain that follow-up information. (isi MR. CHAMBERS: I understand. I understood mi that that was clear enough from from your prior [201 testimony. [21] A: Well, I thought so, too. (221 MR. CHAMBERS: But if you can clear it mi further we'll take the time to do so. I24i A: Let's make sure that we're clear on this. [25i MR. CHAMBERS: Correct. Page 219 in MR. DUFF: I just want to establish the pi reference in this letter and whether or not that pj refers in any way to a meeting that you may have had |4| with Mr. Jensen. [5] A: I think had it been the specific meeting ii that I had with Jensen it would have been likely pi that Widmark is a precise enough gentleman he would pi have said at the meeting with Mr. Palm and a member pi of your Brussels staff. So my supposition, but it's [101 purely that, is that, no, this was one of the (in meetings that Mr. Palm had with Jensen not in my (121 presence, mi Q: When you did meet with Jensen and -- strike mi that. When you meet with Jensen in January of 1967, [isi Ola Palm was with you, correct? di A: Yes, he was. [i7i Q: Did that conversation take place in English (isi or Swedish? (i9i A: Both. I do not speak Swedish. The meeting [201 was conducted in English with Mr. Palm and Mr. [211 Jensen having exchanges in Swedish, if a question I [221 asked was not clear or if a response was confusing, mi Q: Please mark this as Exhibit 288. mi ( Plaintiffs Exhibit 288 psi marked for identification). Page 220 Hi MR. DUFF: Mr. Wood, this document has been pi marked as Plaintiffs Exhibit 288 and bears pi production number TRAN 085999. Please take a moment pi to familiarize yourself with this document. Pi A: Yes. Page 214 - Page 220 Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 WATER PCB-SD0000024897 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY Deposition of DAVID WOOD NOVEMBER 10, 1995 16) Q: Do you recognize this document? [7] A: I recognize this document as a document m which I've seen in the process of being deposed. I [9ido not recognize this document as a letter which I iiojsaw in 1967. nuQ: Were you aware, in the spring of 1967, of a u:i meeting that Professor Widmark had with Bayer in |i3j Germany? [mi A: No, I wasn't, ns! Q: Were you aware on or about March 16, 1967 (i6] that to that point the only U.S. publication that (j7j had carried the story relating to Jensen's findings iisi was a publication called Chemical Engineering? MW A: No, I wasn't. [2oi Q: Please mark this as Exhibit 289. mi ( Plaintiff's Exhibit 289 1221 marked for identification). [23i MR. DUFF: Mr. Wood, this is a document that [241 has been marked as Plaintiffs Exhibit 289 and bears psj production numbers TRAN 056026 through 30. __________________ Page 221 [1] A: I have this document. [21Q: Do you recognize this document? [3] A; No, I don't. [4] Q: Do you know what the IUPAC commission is? I5i A: No, I don't. 16] Q: Are you familiar with H. Egan, secretary to pi the commission, the Laboratory of the Government m Chemist? |9| A: No, I'm not. lioi Q: I'd like to direct your attention to the [ii] third page of this document, which is TRAN 056028. [i2]Do you see the synopsis which is little B in p3j parentheses? [u|A: I see it. iisi Q: Titled "Possible interference by chlorinated no biphenyls by G. Widmark"? [in A: My copy says the same, iisi Q: Were you aware of this publication which 119] referred to work by Professor Widmark? [20) MR. CHAMBERS: I object to the form. What (211 publication are you referring to? This publication [22] being the thing we're looking at or this publication taj being -- [24] MR. DUFF: Exhibit 289. [25] MR. CHAMBERS: He just said he didn't Page 222 in recognize this. [2] MR. DUFF: And I'm asking if you were aware pi of it? 14] A: Oh, I see. No, I was not aware of it. [5] Q: In other words, did anybody tell been published yet. So pi it's not in its you about [<si this publication? final published form. I don't know [6] Pi A: No. Not that I recall, no. whether Exhibit 286 is an earlier draft, [si Q: Did anybody tell you about -- the draft pi which they're talking about strike that. [9| Please mark this as being in press or the isj article that was Exhibit 290. [ioi( Plaintiffs Exhibit 290 finally published. I mean, there pi ini marked for identification). seems to be a connection between the [12] MR. DUFF: Mr. Wood, this content, but I no] can't claim that one is, document that I've iiajjust handed you indeed, the other. has been marked as Plaintiff's [i4] [111Q: Directing your attention to Exhibit 290 and bears production Exhibit 289, and 1121 specifically the third numbers TRAN 056031 [is] through 32, page of that document, once mi again, and is another copy of the page in (i6) this is -- this page has production Plaintiffs Exhibit 289, or pages in number [i4| TRAN 056028. Were you Plaintiff's ]i7)Exhibit 289 which have aware in 1967 that there was [i5] research the numbers 1069 and 1070 at tis] the top that stated, quote, "Most of the unknown of that publication. Do you see that? [i6]compounds" -- strike that. Were [i9i A: Are we talking about Exhibit you aware in 1967 [17] that there was 290 at the po] present time? research that indicated that, quote, [is] [21] Q: Actually, both 290 and 289. "Mass spectro of -- strike that. Were [22] A: Exhibit 290 appears to be a copy you aware [19] in 1967 that there was of two [23] pages from Exhibit 289. research published which [201 stated that, [24] Q: And just for clarification of date quote, "A large number of unknown, here, [25] because the copy in Exhibit 289 but 121) clorinated-containing compounds is not clear, if you have been detected [221 in addition to Page 223 ordinary pesticides in the analysis [231 of [i] refer to the second page of Exhibit samples, using both electron capture 290, do you see [2] that the date of this and the [24] microcoulometric detector. publication was 1967, in the pi upper Mass spectro of some of [25] these right-hand comer? compounds obtained with a combined 14) A: It's not clear in Exhibit 290, and gas it's pi clipped off in the copy that I have Page 225 of Exhibit 289. in chromograph-mass spectrometer [61Q: You don't agree that on the (LKB-9000) indicated 12] that most of the second page of pj Exhibit 290 that it unknown compounds are pi says 1967 at the top? polychlorinated biphenyls, potentiated [8] A: It says 19 something, but -- it somewhat in m nature towards those of says volume [9] 15, number 5, and higher degree of [5] chlorination. A there's a date, which I can detect [10119 large number of samples have been [6] and then there's a blur. examined. Polychlorinated biphenyls Hi]Q: Also directing your attention to are found p] especially in fish and in sea the [i2] references that are on the second birds, but also in (sj conifer needles and page of Exhibit p3j 290, do you see the in some samples of human depot [9] fat". first reference in that? do] MR. CHAMBERS: I object to the [i4] A: The one that contains an asterisk form. You're unjust reading that to the ns] left? portion about the summary of [121 [16] Q: Yes. professor Widmark's work? Is that Ii7i A: Yes. That's a reference to the where you're at [13] in the document? paper that iibj Jensen and Widmark, in an (i4i MR. DUFF: Yes. I was quoting earlier exhibit, said that [19] they were that [is] language. Were you aware of publishing in Actachem. Scand. that research in 1967? 120] Q: And is it your understanding that [i6] A: I was aware that Jensen and that's pi] Exhibit 286? Widmark had [17] carried out research [22] MR. CHAMBERS: I object to the which -- the results of which [isi had not form. That 123] the paper is Exhibit 286 at that stage been published by them. or that the reference to 124] the publication And [i9] in terms of -- I later learned on of the paper is 286? releasing certain poi information to [25] MR. DUFF: The latter. Monsanto in St. Louis they had [211 _________________s_p_e_c_i_fi_c_a_l_lyPtoaglde 2u2s4that we couldn't m A: No, I can't confirm that, because publish their (221 work. So, if you're the [2] reference contained in Exhibit 290 asking me at that point in time [231 was I talks reference pi one is the aware that research had been published, Jensen-Widmark Actachem. Scand. in no, I [24] was aware that a research press, [4] which sort of said it hasn't program had been carried [25] out and that Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Page 220 - Page 225 WATER PCB-SD0000024898 Deposition of DAVID WOOD NOVEMBER 10, 1995 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY some of those results had been _.Page 226 in communicated, pre-publication, to individual pi scientists active in the pesticide residue area, pi But that's all I can -- I can't take you any [4[ further, Kevin. [31Q: Were you aware that the results of Jensen wand Widmark's work were as stated in the synopsis pi contained on the page bearing TRAN 056028? [si A: 28? pi Q: Yes. [ioi A: I was aware that the general media had ini pre-published, as I said, some information about mi their work, which had led to there being a link (131 drawn between polychlorinated biphenyls and their [uiwork, but I personally was still unclear as to (iji whether they really were finding residues of n<si commercial polychlorinated biphenyls. I was still [i7i diligently searching at that point in time to try to [is] find out what exactly they were claiming and whether [19] this was valid or not. [20) Q: Were you familiar in 1967 with the Journal [211 of the AOAC? [22i A: No. [23] Q: Do you know what AOAC stands for? 124) A: I believe it stands for the Association of [231 Organic Chemists or something -- the American Page 227 in Association of Organic Chemists, or something of 121 that nature. [3i Q: But this was not a publication that you were w familiar with? [3i A: It's not a publication I was familiar with, wit certainly wasn't a publication of which I was a pi regular reader or a subscriber, pi Q: Please mark this as Exhibit 291. pi ( Plaintiffs Exhibit 291 (101 marked for identification), mi MR. DUFF: Mr. Wood, this document has been [12] marked as Plaintiff's Exhibit 291 and bears [i3j production number TRAN 056457. ii4|A: Yes. [iji Q: Do you recognize this document? [i) A: Yes. This is a memo that was written to me 11-75 by Dr. Kelly in 1967. [i8i Q: And by this memo Dr. Kelly thanked you for [i9| the information you sent him pursuant to his memo of [201 February 10, 1967, correct? [21] A: He thanks me for having sent information to (221 him. [23i Q: Do you recall if that was the information (241 that he had asked of you in his memo of February 10, [2si 1967? Page 228 m A: I assume it was. [2i Q: Do you recall if you had sent any other pi information to Dr. Kelly in a document form in the w spring of 1967? (3i A: At that particular -- at that period of w time, during the December 1966 and 1977, as I've pi already testified, there were a number of written (8) and spoken communications between myself and Dr. pi Kelly. Which particular piece of information that [ioi he had requested and I had then gathered and [ii| forwarded to him, I don't recall exactly what was [121 attached to the memo that he refers and is thanking [i3i me for the information. It is almost certainly one [uj of the things that we have reviewed. [iji Q: Dr. Kelly told you in this memorandum that [ii he was having Monsanto's analytical people as well [171 as a customer, NCR, evaluate that information, [is] correct? [i9] A: That's what he states in the first [201 paragraph. [211Q: Do you know why -- strike that. Do you [221 know who among Monsanto's analytical people was [23] undertaking this evaluation? [24i A: No, I don't. And I had no need to know at [23] that time. I mean, I was directing the information Page 229 [i] to the people that I had been advised to -- were pi capable of dealing with this, and I wanted it dealt (31 with, and I was reassured because Kelly said he was [4] having the analytical people. I didn't need to know [si who specifically, because he was better qualified to [i know who was best able to do this work. pi Q: Do you know what NCR stands for? [8] A: National Cash Register. [9] Q: And that was a customer of Monsanto's at (ioi that time, is that right? [in A: They were a customer of Monsanto at that (121 time. [i3] Q: Do you know what business NCR was in? [i4i A: NCR was in the business - Well, they were nsi in a number of businesses. [ii Q: Let me ask you -- let me try to rephrase [17] the question for you. Do you know what business -- (isj strike that. Do you know what product of Monsanto's [191 NCR purchased? [201 A: I believe they at that point in time were (21] purchasing a lower chlorinated chlorinated biphenyl. [22] Q: Do you know the name of the product they 1231 were purchasing? 124] A: I don't know if they had a specific [23i proprietary name for the material which they used. _____________ .Page 230 ml mean, they were very security conscious. In 121 retrospect, I believe that they were purchasing a pi product that we designated as Aroclor 1242. [41Q: And do you know how NCR was using Aroclor [si 1242 in 1967? [61 A: I believe that they were using it as a pi solvent for coloring materials in a system which [si they had developed for producing a multi-sheet pi carbonless copying paper. [ioi Q: Do you know why NCR was given the mi information that you had passed along to Dr. Kelly? [121 MR. CHAMBERS: I'm going to object to the [131 form. But if you're able to answer, you may. [mi A: I believe one of the earlier .. ....... exhibits that [iji we looked at had said that NCR had asked questions [i<si of Monsanto. But I believe, equally, that exhibit [17] was an exhibit that I had not seen at that time and [isi was not copied in, I can't remember in the sequence mi that we've gone through. But NCR - [20] Q: I'm asking you -- 1211 A: NCR were a user of chlorinated biphenyls, (221 and a company that if there were sort of questions [231 of this sort about is chlorinated biphenyl in the [24] environment, I'm sure they would have been (23) interested and talking to Monsanto about that at Page 231 dlthat point in time. [21Q: Do you know if Monsanto had sent any of the (31 information that you had sent to Dr. Kelly on to m customers who had asked about the effect of [3] polychlorinated biphenyls on the environment? [i MR. CHAMBERS: I object to the form. pi A: I was made aware by this memo that they had pi shared some of the information that I had sent to [9| Dr. Kelly with NCR. They did not routinely tell me [ioi and list in any form companies that they had sent [in information to. [121 MR. DUFF: Were you aware there were any mi other companies with which Monsanto shared the [U] information that you had sent Dr. Kelly? [13] A: No. [ii Q: In the spring of 1967? [i7] A: No. [isi Q: In this memo Dr. Kelly told you >1 Page 226 - Page 231 Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 WATER PCB-SD0000024899 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY that with [i9i respect to confusing and interchanging the [201 experience on chlorinated biphenyl, chlorinated pi] napthylene and a combination of both, quote, "This [22] really is not too important and there is no question [231 but that Aroclor does possess a certain amount of [241 toxicity", correct? I25i A: That's what he says. And the fact that we Page 232 Ml presented supporting data in all our technical (21 literature about safeguards to be observed in using pi Aroclor in its appropriate applications certainly [4| indicated our recognition that PCBs, if abused, |5| could have toxic consequences. But this is not to (i assume the fact that if you take something as simple [7| as table salt, if you take too much of it, you can ra get -- I mean, everything that we use and come into [9| touch with in our daily lives has toxic [icq consequences. So, I think this was a straight [in forward statement, Aroclor has toxicity, salt has [121 toxicity, scotch has toxicity. [i3j Q: Not everything has toxicity? [i4i A: Everything has toxicity. [i5[ Q: Does water have toxicity? [i6i A: Yes. [in Q: At what point does water become toxic to a (ib) human? [i9i A: If you drink too many gallons of water. If [201 you go back to certain questioning techniques used pt] in dictatorships over time where they force water [221 tubes down people's throat and force water into p3j them. Water can be claimed to have adverse effects [24i on the human system if used in certain bad ways. [251 I'm trying to just put in perspective here that Page 233 in let's not make more of that statement than Dr. Kelly (21 intended. He's saying we don't claim that there are pi -- there is no toxic effect, that it is totally [4] clear of it. Nothing is. [5i Q: And, in fact, he mentioned in this I6i memorandum that that was pointed out in Monsanto's rn literature, is that correct? pi A: I'm sorry, he pointed out -[9i Q: That toxicity of polychlorinated biphenyls iioiwas -- [in A: Yes, he points this out. [121Q: And Dr. Kelly also told you in this [13] memorandum that he thought that Monsanto should |i4] fight the battle of the analytical method first [isj before getting too involved with the toxicology, is (ii that correct? [i7] A: The final paragraph makes that statement. I [is] interpret that statement, and did interpret that [i9] statement to sort of say that to do any meaningful 1201 toxicological work you have to have a secure (211 analytical base, and so there's some resolution that [221 needs to be done about confirming the analytical [221 technology before you start doing tests on animals 124] that -- or any type of toxicological study where [251 you can't measure the effect of what you're doing. Page 234 in But this, in the period of the 1960s and the 1970s, (21 as the chemical industry, its customers and the pi public at large were becoming aware that there was a [4] need for better analytical techniques so that one, pi indeed, could start to measure if there were n presence of materials in the environment and then rn carry out intelligent, appropriate testing to be m able to appropriately consider the consequences of [9) such presence, no) Q: Please mark this as Exhibit 292. nil ( Plaintiffs Exhibit 292 [121 marked for identification). [i3] MR. DUFF: Mr. Wood, this document has been [i4] marked as Plaintiffs Exhibit 292 and bears nsi production numbers TRAN 055945 through 47. Please [i6i take a moment to familiarize yourself with this [17] document. [i8l A: Yes. [i9) Q: This document is an article titled pot "Organochlorine pesticides in seals and porpoises", pncorrect? [22) A: That's the heading on the middle of the [23i first page, which I purport is what's being copied [241 here. (25iQ: It's authored by A.V. Holden and K. Marsden, Page 235 [il correct? [2i A: That's what it states. Pi Q: Do you recognize this document? [4| A: No. [5i Q: Were you aware of this document in 1967? [61 A: Couldn't have been, pi Q: Why is that? [si A: Because it wasn't received for publication [9| until December of '67. [101Q: Were you aware of this document in 1968? ini A: No. [121Q: Did you ever become aware of this document? [pi A: I believe I became aware of this document's [ui existence, never reading it in-depth, in the mid [isi 1970s. [i6i Q: How is it that you recall that date? Deposition of DAVID WOOD ____________ NOVEMBER 10, 1995 [i7i A: When I moved-- you'll recall that when we [isi reviewed my curriculum vitae that at the end of 1967 [i9i I was transitioning to a different assignment within 120] Monsanto Europe which was not involved in any sense 1211 with PCBs, and so I certainly had not seen this 1221 document before I made that career change. In 1974 (231 when I moved to an appointment in the United States, [24i I had some renewed contact with PCBs, and as part of [251 refreshing my own memory as to what had happened in _Page 236 fij the period that I had not been involved with PCBs, [21 I'm fairly sure at that point in time I became aware pi of this particular report. I don't recall having [4] read it in detail. [5i Q: Do you recall why you became aware of this [6i report at that time? rn A: Now we're talking about in 1974 or '5? [8i Q: Yes. [9i A: Because I had a renewed involvement in (101 products within Monsanto which contained chlorinated (in biphenyls, and as part of educating myself over time [12] I read material that had been published pertinent to [i3j PCBs. [i4] Q: How did you go about educating. yourself in [isi 1974 relating to PCBs? (16) A: I think I mentioned that this was really [171 '75, was the statement I made, so -- [i8i Q: How did you go about educating yourself in ni 1975 about PCBs? [20] A: I asked colleagues in Monsanto if they could pn give me folders from 9U their files which contained [221 material which they felt might be helpful to give me [23i an overview of the evolving PCB situation. I mean, [241 that was -- people briefed me on some specific [251 issues, I did some general reading. How does one _________________________ [il educate ones self? Pi Q: Which colleagues did you ask for materials? pi A: I asked Paul Benignus for materials. I m can't recall whether Papageorge was involved at that [5i time, but he certainly was, over the years, a source [i of background reading which I needed in all cases to m glance at, if not necessarily fully -- to fully [si read. Dr. Paton gave me some materials to read. I [9] talked to people in Monsanto's research [io] departments. They, again, gave me some background [in information and some reading material. I had access [121 to a number of functions within Monsanto that were [13] Gore & Perry Reporting Co. St. Louis, Missouri (314)241-6750 621-4790 Page 231 - Page 237 WATER PCB-SD0000024900 Deposition of DAVID WOOD NOVEMBER 10, 1995 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY able to help me understand PCBs in in the dielectrics area. 1975. (9| Q: Who replaced you in the [|4|Q: Do you recall who specifically dielectrics area? gave you (isi materials from their files? [ioi A: Peter Marsh. 116) A: I know I had material from Dr. (mi Q: Even after you moved into the Paton and I (i7i know I had material from Mr. Benignus. I know I had (isi material from Dr. Munch. Those are the people food and fine (121 chemicals area in January of 1968 you continued to (131 stay in the loop of information relating to that (i9i I recall having been helpful to Jensen's [ui findings, correct? my self-instruction. (isi MR. CHAMBERS: I object to the i2oiQ: I'd like to return to the period form. we were 1211 talking about previously, [161 A: But I can answer the question? which was the end of 12211967. And you [i7i MR. CHAMBERS: Sure. had stated that at the end of 1967 [23] that [isi A: No, I didn't. There was one you had changed positions, and occasion when I (i9]was asked, and I still referring back 124] to your curriculum don't quite know why I was 1201 asked vitae which has been marked as pj] once I was in the food and fine job to (211 Exhibit 273, this document indicates reinsert myself for a very temporary that you period into the [221PCB loop. But, no, I Page 238 described when we went through [231 my til actually moved to your new position curriculum vitae that the breadth and in the food and [2] fine chemicals area in scope of (24) the job I was undertaking in January of 1968, is that pi right? the food and fme [251 chemical area, I [4j A: Specifically, it states that I could not do that job and keep ...... moved to that (ji -- the announcement Page 240 was made, the change became (<1 formal [i] casual loop interest in the PCB area. on January 7th, the beginning of January I had to be (21 able to turn that over to Pi 1968. Again, just as context, it's my successor. not abnormal (S) that you know of a job pi Q: In December or January -- in move some little period pi before it's December of [4] 1967 or January of 1968 actually announced on the board. I uoi were you aware that (5) pesticides could mean, they don't surprise you as they accumulate in the tissues of [6] animals? surprise the p 11 public at large sometimes pi A: No. by announcements that are (12] made in Pi Q: Were you aware that any large organization. And there is [131 organochlorine could pi accumulate in normally a transition where you're the tissues of animals? trying to gather [14] information about [ioi MR. CHAMBERS: I object to the your new assignment so you can hit (isi form. that one running and you're doing [in A: I was aware at that point in time double duty that [ii you're trying not to that in [121 some of the public relax your activities for the [in areas that communications about [i3] you were previously accountable for. organochlorine-containing pesticides But (isi there is a transition period. So, that people (141 were beginning to evolve in December of (1911967 I was already theories of bioaccumulation (isi through beginning to familiarize myself (201 with the release of those pesticides into [i6i the responsibilities that I would waterways and, therefore, material undertake in [21] my new assignment. could accumulate [i7] through fish and -- 1221Q: But you continued to have fish eating species. But, [isr again, you responsibilities (231 through at least know, we are at a period in history, [ii January 6, 1968 in the dielectric [241 again, that anybody involved with the fluids area? chemical (201 industry was obviously (23i A: I was really turning over that beginning to understand some (211 of this period to the new terminology, the new theories ' ____________________ Page 239 involving [221 chemical dispersion. This [i 1 person who was to replace me in the was a radically and very (231 quickly dielectrics (21 area, so many things that changing area. would appear on my desk at pi that [24) Q: Were you aware at this time that point in time, straight commercial stuff PCBs could [23i bioaccumulate in certain as (4) well as chlorinated biphenyl species? materials of the type pi we've been Page 241 reviewing, I would have marked up, in A: No. sort (i of saying you need to involve [21Q: Did you become aware of that at yourself in this and m passed it on to my some time in pi the future? -- the person who was replacing pi me pi A: I became aware that -- in 1974 and 1975 that pi PCBs had a capability of bioaccumulation. And, iq again. I'd ask you to note that now we are getting Pi into some better technology when I became more -- (si when I refamiliarized myself with this, now we have pi a term like bioaccumulation whereas one in 1101 retrospect, purely hindsight, you consider that what [in Jensen was talking about as potentiation may have [121 been a first struggling intellectual search towards [131 bioaccumulation theory. But now I'm talking, again, [ui from a 1974, '75 perspective. [isi Q: Mr. Wood, this document has been previously (iq marked as Plaintiff's Exhibit 199. ii7i A: You said previously marked? [isi Q: Previously marked. This document bears (i9| production numbers TRAN 086029 through 30. Are you [201 familiar with this document? pi] A: Wait a minute, I've got two memos here which [221 appear to be the same. Should this be a one sheet [221 or a two sheet document? [24i Q: This document was produced to us as a two [25] page document. Do you agree that the second page Page 242 in appears to be a duplicate or a -- [21 A: Yes. That's why I turned over to read the pi second page and it appears to be a copy. [4j Q: Another copy of the first page? [5i A: Of the first page. [lQ: We'll just discuss the first page unless you pi find it easier or -(8i A: I find it easier to read the second page. I [9] was trying to make sure that I didn't need a copy, [ioi because the front cover is very unclear. Okay, I [m have it. [i2i Q: And this is-- could you please identify [i3| this document for the record? [ui A: This is a memo from Dr. Hardy in London to [i5] Dr. Richard in St. Louis. And I am copied on this, [iei even though this post-dates my change of [i7] assignment. And the sub-heading is Aroclors, and [isi it's dated 23rd of February 1968. (i9| Q: Was this a document you received on or about [201 February 23, 1968? [211 A: I received it, and I think I would have [22] passed it straight on to my successor in the (231 dielectrics business. [24i Q: By this memorandum Dr. Hardy informed you [231 that he had seen nothing further with respect to Page 243 Hi Jensen and Widmark's work over the past year, 121 correct? & Page 237 - Page 243 Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 WATER PCB-SD0000024901 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY Deposition of DAVID WOOD NOVEMBER 10, 1995 I3|A: That's under heading A. [4| Q: And is that what he told you? [si A: That's what he wrote. As I said, at that [<s] point in time I was very busily engaging myself in, pi and I am pretty sure I would have passed this memo pi on to my successor in dielectrics. So, he told me. pi Did I hear it? Probably not. hoi Q: Was it your practice to read all ini correspondence that was addressed to you? 1121 A: I read all correspondence that was addressed [i3| to me. Would it register deeply? I speed read, [ui And so if it was something which was better handled iisi by somebody else and more appropriately handled by [i6j somebody else, I wouldn't thoroughly digest the [i7i document, I would send it to the person who should [ib] be handling it with a request, deal with it. [i9] Q: But it was your practice to read everything [201 that was addressed to you? 1211 A: Oh, yes. [22] Q: And Dr. Hardy also informed you in this [23] memorandum that Tatton's work confirmed the work of [24i Jensen, is that correct? [23] A: Again, he communicated' to a group of people, Page 244 in including myself, that information in this memo. (21 Did I tune in and receive that communication? I pi believe not. [4] Q: In this document that you received from Dr. is) Hardy he wrote that Tatton's paper, quote, "Confirms [6] the work of Jensen, and in particular shows close pi similarity between gas liquid chromatograms of [si extracts of kestral liver oil and commercial ii polychlorobyphenyl resin", correct? [ioi A: Well, I mean, if we've already got this (ui particular memo entered in the record, and I've (12] already stated that I did not take it in in detail, (13] do we gain anything by my confirming that you're [i4] reading it very accurately? fui Q: We gain something -- I believe we gain n<n something by showing that you were informed of these [i7] points. [ig] A: Okay. Therefore, let me respond by saying I [i9|was informed by this memo by Dr. Hardy of that fact. (2oi Q: And in this memorandum Dr. Hardy further 1211 informed you that Richardson's work and 1221 correspondence with him show that he was satisfied 1231 that, that is, Richardson was satisfied that p4] octochloro biphenyl was present and that his results [25] were substantially in line with those of Tatton, .Page 245 incorrect? [2i A: On rereading this memo in November of 1995, pi I can confirm that it appears that Mr. Hardy was [4] communicating to a group of people that he believed [5] at that point in time that what you state is [6] correct, as a good reading of paragraph C. [7] Q: Are you familiar with the River Witham (8| that's referred to in the -- [9] A: The River Witham is a river in England. Am [1011 very familiar with it? No. mi Q: Are you familiar with the valley of the [i2] River Witham? (i3i A: By personal visit, knowledge or historical [i4| study, no. I know very vaguely where the River fisi Witham is. [i6i Q: Where is it? [i7] A: In East Anglia. [is] Q: And did Monsanto have a manufacturing [i9] facility in the valley of the River Witham? 1201 A: Boy, if we did, it was a very secret pi] installation. I never knew about it. [22] Q: Are you aware if Monsanto had any facilities [23] near the valley of the River Witham? [24i A: I don't believe we did. [25] Q: Do you recall if Monsanto had any customers ' Page 246 HI that were located in the valley of the River Witham? pi A: For the products that I was responsible for, pi I cannot recall there being any customer in that [4] part of the country. [5] Q: Were you aware of any customers that used [6] other products other than dielectrics who were m located in that part of the country? [8] A: Yes. [9] Q: Which companies do you recall? [ioi A: There was a company called Brotherhood in a (incity called Peterboro, who used small amounts of [i2] organic silicate. And I'm sure there were packaging [13] companies in that part of the country which used (i4] some plastics. But, again, I fail to see the (is] relevancy of my going through a complete Monsanto [i6] London 1977 product catalog, which I can see us tm headed towards doing, and going through a customer [isi list of all products just to prove did anybody in (i9| that corner of England buy any product from 1201 Monsanto. pi] Q: I'm just exploring the reference that's in [221 this document to the valley of the River Witham. [23] A: And I've already told you I'm not familiar 124] with this memo. [2ji Q: In this document Dr. Hardy informed you that _________________________ [i 1 Richardson believed that there was contamination of (21 bird life in the valley of the River Witham, [3] correct? [4] A: Again, as I read this in November 1995, it pi appears that that was what Dr. Hardy tried to inform [6] me of in February of 1968. Pi Q: Please mark this as Exhibit 293. Pi ( Plaintiffs Exhibit 293 [91 marked for identification), do] MR. DUFF: Mr. Wood, this document has been [it] marked as Plaintiffs Exhibit 293 and bears a2] production number 058004. Do you recognize this (131 document? [ui A: This is a memo from a gentleman called Colin [15] Coleman, addressed to a gentleman called J.M.M. [ioi Thompson, a copy to P.J. A. Marsh and myself, dated [17] the 11th of June 1968. [is] Q: Do you recall receiving this memo? [19] A: No. 120] Q: Who was Colin Coleman? [2i] A: Colin Coleman was a physicist who was a [221 specialist in capacitor dielectric technology and [23] who was located in our technical service laboratory 1241 in Ruabon, North Wales. [25] Q: Who was J.M.M. Thompson? Page 248 in A: Mike Thompson was the salesman in Great (zi Britain responsible for the sale of transformer and (3| capacitor dielectric materials. (4] Q: Do you know what Colin Coleman was referring [5] to when he wrote "The only reference I have to the [6] pollution of the atmosphere and rivers by m chlorinated biphenyl is a New Scientist article"? Pl MR. CHAMBERS: I object to the form. [9] A: I'm not aware of the question that had been (io) posed to Colin Coleman, I presume by J.M.M. [in Thompson, which had led him to write this memo to (121 J.M.M. Thompson on this subject. [i3] Q: Do you recall if you did anything on the [i4] issue of Pyroclor disposal on or about June 11, [is] 1968? 116] A: No, I don't. [i7] Q: Do you recall speaking with Mike Thompson on (ibi or about June 11, 1968? [i9] A: No, I don't. pa] Q: Do you recall if Colin Coleman Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Page 243 - Page 248 WATER PCB-SD0000024902 Deposition of DAVID WOOD NOVEMBER 10, 1995 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY called you in 1211 reference to this issue? [22|A: No, I don't. [23i MR. DUFF: Off the record. (241 (Recess). [23i MR. DUFF: Please mark this as Exhibit 294. .Page 249 ill ( Plaintiff's Exhibit 294 pi marked for identification). I3| MR. DUFF: Mr. Wood, this document has been m marked as Plaintiff's Exhibit 294 and bears [sj production number TRAN 058757. Do you recognize [si this document? [7i A: Yes, I do. [si Q: Were you shown this document in preparation [9] for your deposition? [101 A: I don't remember. Mi]Q: Will you please identify this document for [121 the record? [i3| A: This was a memo from Scott Tucker. It's un dated January 30, 1969, addressed to me in Brussels, [15] Belgium, with copies to a Mr. R.E. Keller, W.R. ni Richard and E. Wheeler. [i7]Q: And did you receive this document on or [is] about January 30, 1969? [i9i A: Unless something went very wrong with the 1201 mail, yes, I did. (21) Q: Who is E. Wheeler? 1221 A: That seems to ring a bell. That was Elmer [231 Wheeler, who was working for Monsanto in St. Louis [24] associated with the product safety, industrial [231 health area. Page 250 Ml Q: Was he associated with the medical [2] department? [3i A: I don't recall whether he was part of the [4] medical department or whether he was actually a (S| medical doctor or whether he was in one of the [<5i associated groups which were professional rn technologists who were involved in the product (si safety area. (9) Q: The subject matter of this memorandum was [101 chlorinated biphenyl in wildlife, correct? [ill A: That's the title in the memo. [121Q: Dr. Tucker asked you to bring him and others [131 up-to-date on chlorinated biphenyl in wildlife, is [i4i that right? [is] A: That was his request. MSI Q: What did you do when you received this [i7i request? [i8i A: I think I would have given the memo to Peter [i9| Marsh. [2oi Q: Do you recall doing so? (2iiA: No. [22] Q: Do you recall if you had had previous [231 conversations with Dr. Tucker before receiving this (241 memorandum? 123] A: No, I don't. ______________ ______ Page 251 in Q: Were you aware at the time of this pi memorandum why Dr. Keller was asking -- excuse me. 01 Were you aware at the time of this memorandum why hi Dr. Tucker was asking you to bring him up-to-date on [3] chlorinated biphenyl in wildlife? ii MR. CHAMBERS: I object to the form. rn A: When we started talking about my change of pi job when I entered the food and fme business area, pi I told you that there had been occasion to - that (101 people had reached out to me in my new position and nneither had not been advised that I changed my job or [121 they were new and in getting the files contacted me, [i3iand those -- at infrequent intervals while I was (i4| involved with the food and fine area people did [i3] reach out to me from the European organization and mi from the U.S. organization, and in most of those [i7] cases I referred their inquiries over to the [is] appropriate people who carried those (i9i responsibilities at that time for the dielectrics 120] area. But 1 would not have just pitched any memo pn straight in the waste paper basket without making [22] sure that it was redirected to somebody who [231 appropriately could take action on it. (24) Q: Were you aware how activity in the United [231 States had increased at this time with respect to _____________________ Page 252 MlPCBs in wildlife? [21 A: No. pi Q: Did you ask anybody after you received this [4] memorandum from Dr. Tucker what he was referring to [5] when he made that point? []A: No. rn Q: Were you familiar with the analytical and (8| biological work that was under way at Monsanto to pi see if Aroclor was present in wildlife? [toiA: No. Mil Q: Were you aware that Dr. Tucker was involved (121 in any research along those lines? [i3l A: At some point while I was in the food and (i4| fine area Dr. Tucker and I did speak, so sometime in ns] that period of my food and fine involvement I became [i6] aware that an individual called Dr. Scott Tucker had [17] become involved in PCB work. Did we routinely (isi discuss PCBs? No. [i9i Q: When did you and Dr. Tucker meet to [201 discuss -- [2ii A: Again, I don't recall the date. I know [221 sometime in the period that I was involved in the 1231 food and fme area Dr. Tucker asked for my help. [241 And I think it was in association with Jensen, [23i because I had met Jensen. But I don't recall the Page 253 mi specifics, and I said, you know, this was an [21 abnormal event, very much out of the course of my pi day-to-day activities, and during the period that I [4] was involved in the food and fine area I was not [5j actively engaged in chlorinated biphenyls. [6i Q: Did Dr. Tucker call you or did you meet with rn him? Pi A: Again, I don't recall. I'm sure that we pi have some communication documents that we will get [101 to in the fullness of time which will clarify for [111 both of us whether it was a telephone call or a [121 meeting. [isi Q: Did you facilitate Dr. Tucker's....... getting in [i4j touch with Soren Jensen? (isi A: 1 think that was a request I made, and I ni think I may have inteijected myself with Palm and [i7] Rising and Strand to try to, because I was one of [is] the few people in the European organization who had [i9| actually met Soren Jensen. [2oi Q: You received this memo from Dr. Tucker [21] approximately 26 months after you had first heard of [221 Jensen's work from Ola Palm, correct? [23i A: If 26 is -- December of '66. Yes, it would [241 be about 26 months. (23i Q: Please mark this as Exhibit 295. ;Page 254 Ml (Plaintiffs Exhibit 295 [21 marked for identification). Pi MR. DUFF: Mr. Wood, this document has been pi marked as Plaintiffs Exhibit 295 and bears isi production number TRAN 058495. Do you recognize [6] this document? pjA: Yes. rn Q: Did you receive this document -- strike pi that. Did you author this document on February 4, [1011969? MU A: Yes, I did. [121Q: Did you review this document in preparation (i3| for your deposition today? [14] A: No, not specifically. I mean, it was M^i probably in the stack of documents that we leafed 6i through, but I didn't review it in detail. 1171Q: And did you write this memorandum to Scott [isi Tucker in response to the memorandum he had sent you (191 which has been marked as Plaintiffs Exhibit 294? [2oi A: Yes. That was his memo of Page 248 - Page 254 Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 WATER PCB-SD0000024903 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY Deposition of DAVID WOOD NOVEMBER 10, 1995 January 30th. [211 Okay. [22i Q: By this memo you recapped for Dr. Tucker the [231 consideration that had been given to Soren Jensen's [241 work when it was first published in Sweden, correct? [25|A: Yes. _Page 255 (ii Qr And you told Dr. Tucker that when he first [21 published his work you met with him in Sweden, [3| correct? [4i A: And in hindsight, accurately, I used the (3) term at the time that Jensen in Sweden first [i published his assertions about the presence of yr\ Aroclor, they were published on his behalf by the [si LKB Productor people in the newspaper. |9|Q: So you-- [ioi A: I just want to make the point that Jensen at (1 ij the time that I met with him had not formally [121 published. But that's -- [i3] Q: But it was at the time that you received a [mi copy of the presentation he had given at the (iji Wenner-Gren Centre on November 22, 1966? [is] A: Remember, I got that in January, I think it [i7jwas, or February of 1967. But we're talking about [is] the same period of time. Okay? H9i Q: One of the things that you told Dr. Tucker poi in this memorandum was that, quote, "I don't think pijat that time we questioned that he had in actual 1221 fact found chlorinated biphenyl in the sea eagle's clivers", correct? [24i A: And, again, what I was saying by that, we (2J1 didn't know enough about his work. When I met with Page 256 in Jensen we were trying to find out what he had done [21 and what he had found. We did not get pi confrontational and say to him you have not found (4| chlorinated biphenyls. At that stage we were in, as isi I described earlier to you, the fact finding mode of [61 trying to find out exactly what, was the aim, pi direction, procedures and the quality of the work m that Jensen had done. It would have served no [91 purpose for us to get into a verbal conflict with 1101 him about saying there's no way these are (inchlorinated biphenyls. I certainly had a lot of 1121 questions in my own mind in 1966 and '67, as I [1si described, as did many people in Monsanto. But ti4] that's the way it was. [isi Q: In this memo of February 4, 1969 you wrote, (i6) quote, "I don't think at that time we questioned [17] that he had in actual fact found chlorinated (iq biphenyl in the sea eagles' livers", engaging in a media [131 debate at that correct? time. And in that context we let the iwi [i9| A: That's what I said, and I've just matter rest. amplified [201 that comment for you. [isi Q: Should Monsanto have been (211Q: Another thing that you told Dr. engaged in a [i6i debate within the Tucker was [221 that at that time you had scientific community regarding [in questioned -- and at that (231 time was in Jensen's findings? the beginning of 1967, you had (241 (isi MR. CHAMBERS: I object to the questioned the quotation of certain form. medical [251 information by Jensen, [i9i A: Monsanto should not have been correct? involved in a [201 debate at that point in ___________________ti_m__e_i_n_s_idPeagtehe25s7cientific (21) community. in A: Yes, I state that in this memo. Monsanto should, as it did, have started [21Q: You then also told Dr. Tucker [22] to review the work, and on the basis that since pi Jensen had appreciated this of supporting [231 document and good point, you let the [4] matter rest, not scientific discussion have engaged (24| in wanting to stir up further [5| agitation in discourse with the scientific other countries, correct? community, as we [251 did, in terms of [61 A: That's what I said in this memo. what was appropriate action to [7i Q: And Monsanto had let the matter Page 259 rest, as you pi said in this memo, [i l begin to set a framework for because it did not want to get (9j too identification, pi clarification, testing of involved in the issue of PCBs residues. accumulating in [ioi the environment, pi Q: Did Monsanto set a framework correct? for [4| identification, clarification and HU MR. CHAMBERS: I object to the testing of [5j residues in the beginning of form. 1967? [121 A: I'm not sure I understand your [6i MR. CHAMBERS: I object to the question. form. [i3i Q: What did you mean by "let the [7i A: Yes, we did. matter rest"? is) MR. DUFF: How did Monsanto do [i4] A: When I met with Jensen, one of that? the areas of [151 discussion was the fact PI A: We started to-- at the beginning that, forgetting for a [iei moment his of 1967, [ioi as you observed from the report about his analytical research [itj documents that we've been [iij rigorously work, he had or had allowed that work reviewing, we had involved the [121 to be [isi associated with some statements applications! arms of Monsanto, we had about toxicological uq matters, which involved the [131 medical arm of was not his area of expertise, and (201 Monsanto, we had involved product (i4[ which were inaccurate, but which had safety arm of Monsanto, we had been emphasized [211 and further distorted involved the its] commercial arm and the in the daily media in Sweden. [221 It's my general management arms of ii6i experience that when inaccurate reports Monsanto, we had had our scientific are [231 published in the press, you've specialists, in (i7jsome cases without my normally got two p4j potential courses of knowledge, in some cases with, [isi in action, you can remain silent (251 on the issue or you can get into a strong letter discussion with Widmark, we had been responsive (191 to requests for isomers Page 258 which they felt -- or 1201 addressing their in writing to editors campaign to sort request for isomers which were ph of say this pi isn't right. Since we were difficult to get. We had begun at that not even sure what it pi was that Jensen was finding at that time, it would [4] time, and [221 over the period -- I mean, I began to hear things [231 from Scott have been totally inappropriate for Monsanto to [5] start a debate with the Tucker who was brought in to add further [241 power behind Monsanto's press about the toxicology i of chlorinated biphenyls at very low levels where we pi already knew that test work related to effects of [i chlorinated analytical efforts in this [251 area. So, these are all beginning to build a ____________________ _____ Page 260 [il framework. So, yes. Did it spring biphenyls at those low levels didn't pi exist, had never been done and the techniques to do (io) such work had not yet been developed, so we could im only further stir speculation without being [121 practically useful to society by whole formed pi into creation on December 30, 1966? No, it didn't, pi Was it appropriately addressed? Yes. [4iQ: Was it possible to test Jensen's hypothesis [5] and his findings without the benefit of a combined (6i gas Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Page 254 - Page 260 WATER PCB-SD0000024904 Deposition of DAVID WOOD NOVEMBER 10, 1995 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY chromatograph mass spectrometer? on to Peter [21 Marsh. No, I actually 17] MR. CHAMBERS: I object to the sort of asked somebody some pi form. questions and responded directly to mi A: I don't know. I told you earlier Scott. So, I'm [4| proud of myself. But that mi although I have an undergraduate did I get so thoroughly p] involved that I degree in (ioi chemistry, I certainly am wanted to find out in great major [i not an expert in ini analytical technology. detail exactly what had been done at So, having raised the issue (i2|of that point? pi No. I had other Jensen's research, there were people responsibilities at that time. within [i3] Monsanto who were qualified [8] Q: Please mark this as Exhibit 296. to decide how that [ui information pi ( Plaintiffs Exhibit 296 (101 marked should be given appropriate internal [isi for identification). review. [i 11 MR. DUFF: Mr. Wood, this [i6i Q: Do you agree that in the document has been [12] marked as beginning of 1967 [i7i Monsanto entered Plaintiffs Exhibit 296 and bears (131 the discourse of hypothesis testing (isi of production number TRAN 058769. Jensen's work? Please take a moment [ui to peruse this (i9i MR. CHAMBERS: I object to the document. form. [is] A: Yes. i2oi A: I don't understand the question, [i<n Q: Do you recognize this document? mu Particularly, I have trouble with [i7i A: Yes, I do. questions that [221 begin "Do you agree". [isi Q: Would you please identify this Can you ask me a straight [231 forward document for [191 the record? question? [20] A: This is a memo from Elmer [24] MR. DUFF: Did Monsanto begin Wheeler, and here [2111 see he does claim to -- perhaps mi you just answered this to be part of the medical (221 department, by the last question, but so to R.E. Soden, S-o-d-e-n, in Brussels, Page 261 mi I am copied on this memo, which nil understand and the record is clear, was dated April 16, [24] 1969 and entitled did Monsanto [21 begin to test Jensen's "Polychlorinated biphenyls in the mi hypothesis in the beginning pi of 1967? environment". And there were many [4i MR. CHAMBERS: I object to the other people in form. Page 263 UI A: Yes. Again, I object to the form ID the European organization copied on of the [6] question, too. Because did this particular a memo, Monsanto test the Jensen pi hypothesis? pi Q: Who was R.E. Soden? Well, did Monsanto begin the internal [4j A: R.E. Soden was an American [8i dialogue of how -- what was the expatriot heading [5] up the -- either the significance of the pi Jensen work, what whole of Monsanto Europe at [i that should Monsanto do to responsibly [ioi time or the chemical side of Monsanto absorb the data and move forward? Europe at m that time. Yes, we did. If nn that's what you mean [8] Q: Did you have any contact with by test the hypothesis, then [121 the him in [9] Brussels? answer is yes. Did we go out and buy hoi A: From time to time. Not an LKB [13] Productor machine? You frequently. I was (instill -- had not asked me that yesterday and [ui I said I achieved a position of eminence [121 didn't know. which allowed me daily contact with [is] Q: By the time of your memo dated Bob. February 4, [i6i 1969, had Monsanto [i3i Q: Do you recall what his position determined that the results of [171 Jensen's was exactly [i4| -- or his title, rather? research were valid? (i5) A: I can't remember at that time [isi MR. CHAMBERS: I object to the whether he was [i6i president Monsanto form. Europe or president chemicals rrn [i9i A: No, I can answer that. Monsanto Europe. I mean, he was a [201 MR. CHAMBERS: Sure. senior executive [isj of Monsanto Europe. [2ii A: I mean, I intervened when I [i9i Q: How long had he been in that received Scott [221 Tucker's memo of position? January 30th that, in fact, the mi fact that [201 MR. CHAMBERS: I object to the we found that I responded with the form. memo of mi the 4th of February says [211 A: I don't have Bob's curriculum that I was even more mi conscientious in vitae. I mean mi I don't remember when my new job than I thought I had he came to Europe and when he mi went _Page 262 back to St. Louis. in been. I told you thought I passed it [24[ MR. DUFF: In this memo Dr. Wheeler -- is mi it Dr. Wheeler or Mr. Wheeler? '_________________________ Page 264 [ii A: I thought it was Mr. Wheeler. If I do you a pi discourtesy, Elmer, I'm sorry. ui Q: In this memo Mr. Wheeler tells Soden that [4i your people in Europe were the original contacts in [3] late 1966 and early 1967 with scientists and [6] university and government laboratories who pi identified PCBs as interfering substances when [8] determining chlorinated pesticide residues in fish, [9] sea eagles, pine needles, et cetera, correct? [101 A: That is so, as we've look at it in [i 11 exhausting detail. (121Q: By the term your people, he was referring to [i3i you in particular, is that correct? [hi MR. CHAMBERS: I object to the form. [i5]A: No. No. No. I mean, I don't know. I [i6i mean, what he was saying is your people, and I [i7i understand him to mean by your people people in the [18] Monsanto European staff, which included me and [19] colleagues of mine, again, that we've researched [201 documents here and sort of said -- I was not lonely [211 as a cloud in this thing. [22] Q: My question was, that included you and mi others, is that correct? mi A: It included me and others, yes. mi Q: And do you recall what government ;Page 265 [ii laboratories that you made contact with? Pi A: I didn't make contact with government pj laboratories. [4i Q: Do you recall who in Monsanto Europe did so? Pi A: Yes. It's that good man Dr. Hardy, whose [6| memos we keep sort of reviewing about his contacts pjwith government laboratories. [8] Q: Were there scientists at other universities [9i besides Stockholm with whom you spoke in December of (101 1966 or in 1967? [in A: Is "you" David Wood or "you" collective (121 Monsanto Europe or -- [i3i Q: You, David Wood. [hi A: I didn't talk to anybody else at that point [isj in time. [i6i Q: In this memo Mr. Wheeler told you that the [17] story relating to identification of PCBs in wildlife [i8i first broke in the U.S. public press in February [19] 1969, correct? mi A: Where are we looking here? PH MR. CHAMBERS: Paragraph two. I Page 260 - Page 265 Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 WATER PCB-SD0000024905 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY Deposition of DAVID WOOD NOVEMBER 10, 1995 if he's not 1221 pointing it out to you. [23i MR. DUFF: I'm looking for it myself. I [241 think it's the second paragraph. Ii5i A: Okay. Until February of this year. I was Page 266 m looking for 1969. 121 MR. CHAMBERS: That's where I picked up 01 '69. hi A: The memo is 1969, and since it's February of [si this year and he's sort of talking about the story [6i breaking in the public press in the United States, pi That's what he states. And he was here in St. Louis (si reading the newspapers, I was in Brussels not (9) reading the American newspapers. [101Q: Were you familiar with the story that was mi published in the U.S. public press in February 1969? li2|A: No, I wasn't. Ii3l Q: Did you become aware of an article published (uiin the U.S. public press in February '69 at a later mi date? 116I A: Not that I could quote today which paper it ri7] appeared in and what it said. It was probably as mi part of a lexicon of PCB documents, it's probably [i9i passed across my desk at some point since 1974, but (2011 can't surface it for. I've read millions of pages 121] of PCB information over the years. 1221Q: Were you aware of Monsanto's effort that [231 began in July or August 1969 in the organic division [24] and in consulting laboratories to protect the sales i23i and uses of Monsanto's PCBs? ;Page 267 m A: No. [2i Q: Did you advise Mr. Wheeler or anybody else pi in St. Louis as to whom they should meet with at [4] Bayer in Leverkusen? [5] A: I don't recall, because I don't remember if [i I even knew at that time who had corporate pi responsibility for dielectrics or chlorinated [si biphenyls in the Bayer organization. I mean, I pi would have known that earlier in time, because on 1101 certain technical issues about dielectric standards mi and the like, electrical performance, it would be in [121 order for us to have knowledge of who ran those [isj businesses in Bayer and Prodelec. Certainly, it (i4i would not be normal for me in a commercial function [isi to have contact, otherwise I would have had some of [iqyou gentlemen lawyers hot on my tail for potential [i7| antitrust activity. (isi Q: If you had advised Mr. Wheeler or others as [i9| to whom they should see at Bayer, who would that (201 have been? [21] A: And as I just told you, I don't recall that [2211 was able to help him with this. If I did, I [23i certainly don't remember who I referred him to now. [24| Q: In other words, do you recall the names of 1251 the scientists at Bayer who would have been able to :Page 268 [ii answer this question? [2] A: No. (3| MR. CHAMBERS: I object to the form, it's [4| been asked and answered about three or four times ui now. (6i MR. DUFF: Prior to the date of this [7] memorandum had you spoken with anybody at Bayer [8] previously, prior to this date about the [9] identification of PCBs in wildlife? [io] A: No, I hadn't. (illQ: At this time in April of 1969 was Monsanto [12] concerned about potential problems for the marketing (i3| of PCBs or products containing PCBs? [i4] MR. CHAMBERS: I object -- [isi A: I'm sorry -- [i6] MR. CHAMBERS: I object to the form. Go ri7j ahead. [isi A: Repeiat the question. I think I'm going to [i9i object to the form, too, but -- 120] MR. DUFF: Would you please repeat the (21] question for the witness. [221 (The requested portion of the [231 record read by the reporter). [24|A: I can't make any quantification for you of [231 concern or unconcern in response to your question. Page 269 (u As I said, at this point in time I was in a work ra area totally divorced from PCBs, I was dragged back pi mentally from time to time infrequently and m sporadically because of contacts that I had made in [5) the late 1966, early 1967 period through the end of [6i 1967- So, am I capable of making any meaningful pi response to the question of Monsanto's level of [si concern in a business area that I was divorced [9| from? No, I am not. [101 MR. CHAMBERS: That's a fancy way of [i 11 objecting to the lack of ~ foundation to that (121 question. [i3i A: If you would just sort of say lack of [i4i foundation and that's a neat lawyer's way of doing iisjit, then that's fine, but -- [i6i MR. DUFF: Do you recall discussing with Dr. [in Kelly in March of 1969 the issues that are set forth [isi in this memorandum dated April 16, 1969? [i9i A: Not in detail. As I say, when - if and poi when Kelly was in Brussels, we had had enough (211 telephone conversations over that previous period of (221 '66 and '67 that it would be very unusual that he [231 wouldn't have stopped by just to have a cup of 124] coffee and to shake hands and to smile at each [231 other. And in that period he may have made a few -- Page 270 (iiyou know, we did not have in any sense a formal 121 meeting to review and discuss to my knowledge -- oiI'll tell you this, I was not involved at that (4| time. I almost apologetically had to say to people, [5iyou know, I'm an aspirin man or a vanalin man now. [6i Q: Do you recall that you had a conversation m with Dr. Kelly in which you went into some detail, [si however, in February 1969? [9] A: No. [101 MR. CHAMBERS: I believe the testimony just (iiiwas, less than two minutes ago, that he didn't [12] recall discussing this with Dr. Kelly. Am I (131 incorrect about that? [ui A: You are correct in that. [15] MR. CHAMBERS: AH right. So that question [ii has been asked and answered. [17] MR. DUFF: Thank you. (isi MR. CHAMBERS: You may not have heard it, 1191 but it was asked and answered. [201 MR. DUFF: Off the record. 1211 (Discussion off the record). [221 (Noon Recess). {23i MR. DUFF: Would you please mark this (241 document as Plaintiffs Exhibit 297. [23i ( Plaintiffs Exhibit 297 ______________ Page 271 dl marked for identification). (2i MR. DUFF: Mr. Wood, this document has been 01 marked as Plaintiff's Exhibit 297 and bears [4i production number TRAN 058014. Please take as much [5] time as you need to familiarize yourself with this (i document, pi A: Yes. (8i Qs Could you please identify this document for [9i the record? (101 A: This is a memo from a Mr. Kup, K-u-p, at [in Monsanto's Ruabon, R-u-a-b-o-n, location. It's [121 addressed to V.J. Heroufosse, that's [i3i H-e-r-o-u-f-o-s-s-e, who was a Monsanto employee in [i4| Brussels. The subject of the memo is Santotherm, (isi S-a-n-t-o-t-h-e-r-m. It's dated 8th of September [>6| 1967, and I, David Wood, am on the list of copyees. [i7i Q: Did you receive this document on or about (i8i September 8, 1967? [i9|A: Yes. [201Q: Who is R.P.W. Kup? Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Page 265 - Page 271 WATER PCB-SD0000024906 Deposition of DAVID WOOD NOVEMBER 10, 1995 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY [211 A: I know the name. I can't put a face to it. [2211 think he was a technology individual in our (231 technical service area in Ruabon, North Wales, who 1241 would answer technical questions sometimes if Dr. izsi Hardy was not available. product was chemically distinguished. [20] Q: Was there an active ingredient in [211 Santotherm? (221 A: No. [23i MR. CHAMBERS: I object to the form. |24| A: Santotherms were chemicals _________________w_h_i_c_h__w_e__reP[2a51geba2s7i2cally inactive, and lij Q; Who was B.J. Heroufosse? that's why they had good [2| A: Jim Heroufosse was a Belgian ;Page 274 citizen working pi for Monsanto in (H thermal stability. But they did not Brussels, who had responsibilities w at contain -- the pi products that are that time in the area of marketing referred to in this memo contained pi no transfer [51 fluids. chlorinated biphenyls. [61Q: What is Santotherm? (4i Q: Were Santotherm products [7[ A: Santotherm is a trademark of fire-resistant? Monsanto m Europe. It relates to a [5i A: No. product range of fluid [91 products which [6i Q: I'd like to direct your attention are used to provide efficient [io[ industrial heat transfer. to the (7) last paragraph of this memorandum. Maybe it will m help if [i 11Q: When you speak of industrial I ask, did -- strike that. In the last pi heat transfer, [121 what do you mean? paragraph do you see where Mr. Kup [is] A: Many industrial processes writes "There is no] very little require to operate (wi at elevated ____ information in M. Schuitema's note as to temperatures. You could, obviously, (ii) how the Santotherm is being handled put [i5i a fire under the vessel. There are and what its use (121 is in connection with inherent dangers (i6i with many of the the W-kerk ships, but it is [131 very solvents used in industry if you [i7[ were important that the Aroclor should not to do that. But if you put a second be in [i4i contact with skin because they jacket or [is] a coil around the vessel in may be absorbed (isi through it and which the reaction is [191 going and then systematically they can be liver (ii circulate a heated fluid around that, m poisons", do you see that? you can provide heat to the reaction. (i7i A: I'm sorry, read that, starting Obviously, a [211 fluid which provides from the (isi penultimate line again. that service of transferring (221 heat from (i9] Q: They may be absorbed through it an isolated location where it can be (231 and [201 systematically -- safely heated to deliver that heat to a (21) A: No, it doesn't say reaction (24) vessel where you don't want systematically. It says 1221 systemically. heat contact is an (251 industrial indirect (23iQ: I'm sorry. heat transfer system. [24] A: I just want to make sure we get Page 273 this right. in Q: There's a reference in the second (25i Q: You're right, it does say paragraph (21 to Santotherm 130 or 190, systemically they do you see that? Page 275 (31 A: Yes, I do. in can be liver poisons. When I read (4i Q: What is the difference between this it suggests (21 to me that Santotherm Santotherm (si 130 or 190 -- and 190? has Aroclor in it. Am I [3i failing to [6i A: Santotherm 130 was one understand something? chemical material pi with a certain level (4i A: Yes, you are. of heat stability and viscosity (si and heat (5i Q: Could you please explain? transfer characteristics. Santotherm 190 (6i A: In the Santotherm range there (9| was a different chemical entity with were fluids v\ which had designations a different (101 viscosity, a different range Santotherm FR fluids, pi fire-resistant of heat transfer mi operation. fluids, so if you had a fluid (9| [121Q: Did Santotherm 130 contain application where you needed not only Aroclor? the fluid's no] thermal stability, but you (i3[ A: No. needed a fire-resistant (hi element, then (i4( Q: Did Santotherm 190 contain you might be considering the use of a (121 Aroclor? polychlorinated biphenyl based heat Ii5i A: No. transfer fluid. [13] But that would not be (i6i Q: What did Santotherm contain? one of the ones they were [ui alluding to [i7i A: I told you Santotherm was a here. But Jim Heroufosse was asking (isi range of (tsi fluids. They were questions about the safe handling of chemically different, each (191 individual Santotherm 130 [i6iand Santotherm 190, which were non-chlorinated (171 biphenyl fluids. Mr. Kup, in answering that (isi question, knowing that there were Santotherm FR [191 fluids, chose to just make sure that Jim understood 1201 there were differences, that all chemicals are not [2i] equal, like all animals are not equal, and, (221 therefore, chose to write the memo in the frame he 1231 did. So the implication that no, these were PCB [24| fluids is not a good assumption. 1 (25i Q: So there were Santotherm fluids that were __________________________ Page HI fire-resistant that contained polychlorinated (21 biphenyls, correct? Pi A: That is correct, yes. (4i Q: And those were designated as Santotherm FR, isi correct? (6i A: Those were designated as Santotherm FR. m Now, again, Santotherm was the European trademark (8i for Monsanto's heat transfer fluid range. I' m sure pjthat you' ve come ___ across the term Therminol, which is [ioj the Monsanto's U.S. heat transfer trademark, u 11 Therminol was not available to us in Europe because [121 of a close trademark conflict, so we used the [isi Santotherm trademark in Europe. [mi Q: Thank you. So when Mr. Kup is -- is it Mr. (151 or Dr. Kup? (i6) A: I don't remember. Again, you know, I do (i7i apologize on the record to these people at not (i8) remembering what their academic titles are. I seem (i9) to suspect he was a Doctor. In fact, I seem to [201 suspect that he was the plant doctor at the Ruabon (211 plant, and, ) therefore, in the absence of Doug Hardy (22) he would have, just as the other medical (231 practitioner, he would have been -- he would have (241 been, you know, asked to step in and back up Doug (25i Hardy if Doug Hardy was on vacation. Important note _Page 277 in that we didn't let the fact that we allowed doctors [2] to have vacations to prevent us answering questions. (3i Q: So when Dr. Kup was referring to the fact (4i that it is very important that Aroclor should not be (si in contact with skin because they may be absorbed [6i through it and systemically they can be liver pi poisons, he was referring to Santotherm FR fluids, m correct? Pi MR. CHAMBERS: I object to the form. [101 A: I don't know what was in his mind when he [111 made that comment. I suspect that he had gone back [121 to the technical brochures where we recommended that (i3| skin contact be Page 271 - Page 277 Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 WATER PCB-SD0000024907 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY Deposition of DAVID WOOD NOVEMBER 10, 1995 avoided, where possible, and we told imi people what type of gloves should be worn and -- iisiQ: Did you have an understanding when you nq received this memorandum how Aroclors could [i7i systemically be liver poisons? iisi A: No. I knew that there were earlier papers 1191 which Monsanto knew, read, understood that in the ia>] '40s and '50s that there had been the use of pi] combinations of chlorinated biphenyls and |22] chlorinated napthylenes in certain cable compounds (23] in fire-resistant cabling installed in ships at war mi time, and that there had been observations that if [2J| people wallowed around in such fluids, combination Page 278 [i i fluids, that they had a jaundiced appearance which ri was compatable with some temporary uptake in the pi liver. Now, how long that lasts or anything else, w but -- so, it made a lot of sense to say if you're pi working with these fluids, and these are heat (] transfer fluids so you could come into contact with [7] them at elevated temperatures, that one protected pione's -- one wore protective garb to prevent the (9i possibility of absorption through the skin, since tioi there had been these earlier observations. But (i i| that's nothing to do with -- in fact, in retrospect, 1121 most of that activity and skin sensitivity leading ii3] to jaundiced appearance was laid at the door of (i4| chlorinated napthylenes, not the chlorinated iij] biphenyl part. But here, you know, we're going back ui into areas of good industrial hygiene practice where [i7] Monsanto is making very secure recommendations to mi people. [i9| Q: Please mark this as Plaintiff s Exhibit [2oj298. 1211 ( Plaintiffs Exhibit 298 1221 marked for identification). [23i MR. DUFF: Mr. Wood, this document has been (241 marked as Plaintiffs Exhibit 298 and bears 12S1 production number TRAN 057807. Page 279 m A: Yes. 12] Q: Could you please identify this document for pi the record? [4| A: This is a memo from Eton Roush, R-o-u-s-h, m from the St. Louis general office of Monsanto, dated i March 26, 1968, addressed to me, David Wood, in pi Brussels with copies to a number of people, one is] underlined, which I can't see here, and it relates (9| to Therminol/Santotherm and talks about cooking oil (101 and potato crisps, which we in the U.S. refer to as mi potato chips. ]i2] Q: Did you receive a copy of this document on [i3ior about March 26, 1968? [Mi A: Appears so, yes. iisi Q: Who is M. Schuitoma? [16] A: Martin Schuitoma. [i7i Q: I wasn't even close. iisi A: You really weren't on that one, Kevin. [i9] Martin was a salesman in Monsanto in Holland. And (201 we excuse the fact that you don't speak Dutch. [211Q: You're right. Who was T. Denton-Roberts? [22] A: Treavor was a specialist heat transfer (23] salesman based in England, but who acted, because of [24] his specialist heat transfer knowledge, as a support [25i person for the other European sales people. He was Page 280 in a chemical engineer with specialist knowledge in (21 heating systems, indirect heating systems. 01Q: And affixed to this memorandum originally w when it was sent to you, Dr. Roush -- was it Dr. [5] Roush? [6] A: No. No. No. PiQ: Mr. [8i A: Don Roush and, again, I owe him no apology, [91 was a down to earth chemical engineer, he had no [101 doctorate, but what he didn't know about heat mi transfer wasn't worth knowing. [121Q: Was he the guru of heat transfer? [i3| A: No. I mean, he was one of our -- I mean, [mi Monsanto is an excellent chemical engineering (i5i company, we had lots of good chemical engineers. (i6i Don was one of them. [17] Q: When Mr. Roush sent you this memorandum, he iisi attached two reports from Dr. Keller's group on the [19] subject of cooking oil contamination, correct? [20] A: I have no reason to disbelieve that he [211 didn't attach the reports he mentions in the memo. [221Q: Do you recall those reports? (231 A: No. [24] Q: Was contamination of cooking oil something [251 that you were interested in in March of 1968? Page 281 Hi A: No. The use of Therminol, our U.S. (2| trademark and Santotherm, our European trademark (3) products in heat transfer was of -- we felt we had i4j a world leadership in that technology, of delivering [5i indirect heat with stable fluids. The cooking -- (6j the food producing industry had expressed interest (7| in this type of technology, since the process food m industry needed to heat products indirectly. We m recognized that any time that you are delivering no] heat through a fluid through a jacketed vessel, if mi there were to be a leak into the reaction vessel 1121 where you're cooking food, now you're talking about (131 ingestion of chemicals that were not intended to be [mi there, and so the possibility to detect leaks and [15] presence of fluid in foods that were being processed mi at elevated temperatures was significantly important [i7i to us, because if we could not reliably develop iisi methods to detect if there had been an entry of the (i9| heating fluid, no matter what the chemistry of the [20] heating fluid was, into the foodstuff, then we were [211 getting into a whole different area of possible 1221 hazard. So, let's understand where we were coming [231 from when we talk about the need to detect heat [24] transfer fluids, whatever their chemistry. [25] Q: Was the issue of cooking oil contamination Page 282 [i] something that was related to your responsibilities [21 when you were being market supervisor for food and pi fine chemicals at Brussels? [4] A: No. [si Q: So heat transfer fluids for use in food [6] processing equipment was not something that was m related to your responsibilities as the -- your [8i responsibilities in the food and fine chemicals (9j group? [io] A: No. (in Q: Do you recall if you had asked Dr. Keller to [121 provide you with the reports that are referenced in [131 the first sentence of this memorandum? [i4i MR. CHAMBERS: I object to the . form. iisi A: I don't believe so. I don't have any clear [iei recollection of this particular incident, and, [in again, why I was involved in this one. I don't (isi recall. Again, can I ask your indulgence to allow (i9| me to go back here to the curriculum vitae? (2oi Q: Certainly. [211 A: You're right, there I am in food and fine. (221 And, again, I cannot -- [23i Q: So this was about two and a hal f months mi after you had gone into food and fine chemicals, (251 right? ____________________ Page 283 in A: Hey, the two and a half months after I got (2| into food and fine did not eliminate the fact that pi there were Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Page 277 - Page 283 WATER PCB-SD0000024908 Deposition of DAVID WOOD NOVEMBER 10, 1995 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY people that I had met, encountered, (4| spoken to in St. Louis when 1 was in the earlier (si fluids job in its broader sense who would think [i well, who do I know in Europe, [ will -- I'll mcontact Dave. I8i Q: Were you aware of the analytical equipment (9| that was being used, by Dr. Keller's group in 1968? (io|A: No. imQ: Do you recall what problem Monsanto had with (i 21 chlorinated biphenyl contamination in the food ini processing industry? [i4| A: No. Other than that it didn't matter nsj whether we were talking Therminol FR fluids or the [[<n other Therminol fluids or the Santotherm equivalent, [171 if you were involved in a food application, you nsi needed to be sure that if there were a breakthrough [19] that it was detectible. (201Q: Were heat transfer fluids such as Therminol (211 and Santotherm used in closed systems? [221 A: Yes. They were systems that were [231 essentially designed as closed systems, that was (241 their beauty. Any time you expose an organic psi chemical to air at elevated temperature it's capable Page 284 in of oxydative degradation, and so you are using these [2] fluids and maintaining their stability and integrity pi by using them in closed systems. Now, a closed [4] system is designed as such. A closed system can be pi breached as if you drop your carton -- Pepsi cube iq off your wagon at the supermarket and it cracks a pi comer of a can, so what's supposed to be a closed pi can leaks. So there is a possibility that a closed pi system can be breached. [101Q: Please mark this document as Exhibit 299. [iu( Plaintiffs Exhibit 299 [121 marked for identification). [i3i MR. DUFF: Mr. Wood, this document has been (ui marked as Plaintiff's Exhibit 299 and bears the [is] Bates number BIR 002173. There is also another [iei exhibit sticker that says 179 and is dated 8/12/87. [i7i A: Yes, I see those. The second one refers to [isi what, the attached memo or -- no, it's a single [i9imemo. 120] Q: The other Plaintiffs Exhibit, I believe, [211 refers to the fact that this document was marked as [221 an exhibit in a previous deposition. [23| A: Oh. [24] Q: In a different case. [23i MR. CHAMBERS: Is this noted on the list of Page 285 HI documents that you furnished to us 123] A: Yes, do I. earlier, Kevin? [24i Q: Are you familiar with the [21 MR. DUFF: It is noted in the cover Monsanto black 1231 book? letter m to that list. [4j MR. CHAMBERS: Are you talking ____________________ [i]A: Oh, yes. Page 287 about the [5] generic reference to [21Q: What is that? documents previously marked as [<.1 [3i A: The Monsanto black book is the exhibits and produced for Mr. Wood in technical [4| brochure related to the use Transwestern pi Nevada Power and and maintenance of [5] transformer fluids Birmingham Fire? containing chlorinated biphenyls ra PI MR. DUFF: Yes. which was prepared and produced by Pi MR. CHAMBERS: Is that the Monsanto and was pi a well used reference? booklet in the electrical installation [8i [ioi MR. DUFF: I believe this and maintenance industries. document was [i 1) marked in the [9i Q: Did you have any input into the Birmingham Fire Insurance case. information [101 contained in the black [121 MR. CHAMBERS: All right. book? [isi MR. DUFF: Mr. Wood, please take [i 11 A: I wish I could claim such. No, I as much [i4| time as you need to didn't. familiarize yourself with this [isi [i2i Q: Do you see in the first paragraph document. of this [isi memorandum where the author [i6i A: Yes. refers to a source that [uj contains a table [171Q*. Just so the record is clear, this of decomposition of products of [isi document [isi bears -- or has the Bates.... transformer askarel showing that 0.01 .. number BIR 002173 through [19174. Mr. percent of [i6i phosgene is produced in an Wood, could you please identify this [201 electric arc through air [171 saturated document for the record? askarel at 25 degrees centigrade? [211 A: This appears to be a memo from [isj A: Yes, I see that. C.R. Coleman [221 of Monsanto England [i9] Q: The author also said that it was in Ruabon to Paul Benignus, [231 most [20] disturbing to come across that B-e-n-i-g-n-u-s, of Monsanto in St. information, [211 particularly because that Louis, and it [24i copies myself in was at variance with [221 information on Brussels, Mike Thompson in London [231 the same subject in France and [23] and Ralph Munch, Dr. Ralph Munch in Germany, correct? St. Louis. And [24i A: Not only was it in contradiction ;_____________________w__it_h__[2P3]aingefo2r8m6ation in France and in it covers the issue of the generation Germany, it was in of phosgene [2] when a transformer Page 288 askarel is decomposed under a pi high [i] contradiction with information in the intensity electric arc. Monsanto black [21 book. [4i Q: What is phosgene? pi Q: Do you know why that [3) A: Phosgene is an organic low information was at odds m with the molecular weight [6i gas, COCL information in France, Germany and the something or other, which is an [3] Monsanto black book? extremely pi active gaseous product [6] A: I do, and I found out a lot later, which has a number of (8i extremely and I [7] can't remember the precise acute toxic properties which made it a answer. But, again, I pi have to give [9] poison gas in military use in World you a minor context here. Chlorinated War I. [9i biphenyl used as a dielectric was an (ioi Q: Did you receive this document invention of [ioi the General Electric on or about mi August 5, 1968? Company. We can't, at [inMonsanto, [121 A: Again, I have ultimate faith in claim that we invented chlorinated (121 the European [isj mail system, I have to biphenyls. That was a development of believe I did. Frank Clark at [i3| General Electric. We [ui Q: Do you know how phosgene is ultimately made it. But in (141 terms of generated from [i3] the decomposition of the performance of chlorinated askarel? biphenyls as [isi dielectrics, GE knew (161 A: No. more than anybody in the world [i6i about [i7i Q: Do you see -- in the middle of their dielectric performance. So when the first (isi page of this document there we find [i7] that of the people who are some columns, do you [191 see that? finished up manufacturing [is] these [201 A: Yes, I see that. materials invented by GE say that in all [211Q: Do you see the column titled their 119) tests when you subject Aroclor "Monsanto black [221 book"? to a strong electric [201 arc that no a ) \ j .1 Page 283 - Page 288 Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 WATER PCB-SD0000024909 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY Deposition of DAVID WOOD NOVEMBER 10, 1995 phosgene is produced, and then you find 1211 that there's a sudden published article that says [221GE, who invented it, have published an article which [231 says they found a very small amount of phosgene, (2<i then you have to say hey, now, wait a minute. 1211 Anybody would agree that phosgene is a pretty Page 289 in undesirable substance, even in small 121 concentrations. So, Colin was an easily disturbed 131 person, but I can understand why he was most w disturbed in coming across this article in 1968 [5i which seemed to contradict valid test protocols that [i we and other major producers of the fluid had rn carried out which said no phosgene is produced under [8] arc conditions. And the answer comes down to high ra levels of oxygen and aeration while you strike the iioiarc, which are not conditions you would find in real nu life. So they had arc'd under rather theoretical [121 conditions and rather extreme conditions that would [13] not be found in service. [mi Q: They being GE? [in A: They being GE. [i6i Q: In the test -- in the results that are [171 referred to in this 1951 publication? [i8i A: Yes. So this was something that ultimately [i9]was cleared up, I understand, to everybody's po] satisfaction. You know, I mean, what we're saying pi] is correct, and what they're saying is correct under [221 the very specific and special conditions which they [231 had set up for an entirely different reason of a (ai different application that they were considering the (25i use of askarels. Page 290 in Q: Please mark this document as Plaintiffs [21 Exhibit 300. pi( Plaintiffs Exhibit 300 ra marked for identification). Pi MR. DUFF: Mr. Wood, this document has been [ei marked as Plaintiffs Exhibit 300 and bears pi production number TRAN 009685 through 94. And for [8]the record, another version of this document was pi previously marked as Exhibit 85. [io] A: Yes. [iilQ: Mr. Wood, could you please identify this [12] document for the record? Ii3i A: This is a document produced and published [i4] out of Monsanto Chemicals Limited in England and [15] published by Dr. Hardy. It talks about product (14 toxicology of the Aroclors, and it is dated May 15, (i7j 1969. [i8i Q: Did you receive a copy of this report on or (191 about May 15, 1969? (2oi A: Yes. 1211Q: Do you recall receiving this report? 1221 A: No. [23i Q: By this report Dr. Hardy summarized the [241 present knowledge concerning chlorine-containing [251 residues in wildlife, correct? Page 291 in A: That's what the sub-title says, pi Q: In this document Dr. Hardy informed you that pi gas liquid chromatography -- and let me direct your [4j attention to the second paragraph on the second [$i page. In this document Dr. Hardy informed you that [6] gas Liquid chromatography using electron capture or pi microcoulometric detection has become established as ra the most suitable technique. It appears that the ra chromatograms of the residues showed not only the (101 peaks corresponding to the insecticides and their [111 known metabolites, but additional peaks of unknown [121 chlorine-containing substances, correct? [13] MR. CHAMBERS: I object to the form. [14] A: Again, reading this in 1995, that is what [15] paragraph 2 of page 2 says. [lq MR. DUFF: Directing your attention to the [17] third paragraph on this page. Dr. Hardy also told irayou in this document that towards the end of 1965 [i9] these unknown substances were identified by Soren [201 Jensen under the direction of Gunnar Widmark, [211 correct? [22] A: Yes. Doug was always one for the proper 1231 scientific courtesy. (24i Q: And Dr. Hardy stated that Jensen and Widmark [2S] used a combined gas chromatograph mass spectrometer, Page 292 li) correct? ra A: Yes, he says that. In fact, he actually pi identifies it as the LKB-9000. [4] Q: Which was the device -- ra A: Which Soren Jensen himself had told us he ra was using, yes. rn Q: And was manufactured by LKB Productor, ra correct? ra A: Unless somebody was infringing their [to] trademarks, I would think that's likely so. HUQ: And Dr. Hardy told you that Jensen and (121 Widmark used this device and showed that the peaks [13) that they were finding of the unknown substances (mi were due to polychlorinated biphenyls or PCBs, [isi correct? [i6] A: He states that, yes. ini Q: And he also said in this paragraph that the [isi evidence and reasoning of Jensen and Widmark and [wi their conclusion could hardly be in doubt, correct? [201 A: That was Dr. Hardy's opinion. [211Q: And I'd like to direct your attention to the [221 list of scientific establishments that are set out 1231 on page 3 of this. [24] A: Can't we actually just touch on the [25] paragraph after the one we've just been dealing Page 293 [ii with? . [2]Q: For now I'd like to direct your attention - 13] A: I'd just like to add to my answer, I think rathat Doug's opinion about the conclusions and their [5i doubt or lack of doubt is equally sociable with his ra announcements of the sensational statements pi concerning the poisonous nature of the PCBs, so that ra we have a complete sort of -- either put the ra complete document in or pick and chose, it's up to [101 you. [it]Q: I move to strike as non-responsive. [121 Directing your attention to the list of [131 establishments on the third page of this document. [i4j Do you see those? [isi A: The which of which? [i6] Q: This is -- li7] A: Page three. T m on page three. [isiQ: And I'm referring to, there's eight [ra scientific establishments that are listed on this [201 page. Do you see them? pi] MR. CHAMBERS: I object to the form. [22] They're not scientific establishments. Some are [231 universities, some are laboratories. (24i A: One is a museum. [25i MR. DUFF: Okay. I stand corrected. Do you Page 294 in see the list of establishments that appear on page 3 ra of this document? pi A: Yes, sir. ra Q: Dr. Hardy told you that the original work of ra Jensen and Widmark had been extended and generally [6] confirmed by the eight establishments that are pi listed on this page, correct? ra A: Where does it tell me that? Okay. Would rayou restate the question that Kevin just asked me? [io] Q: Would you please repeat the question for the n>] witness?. 1121 (The requested portion of the tra record read by the reporter). [i4] A: Yes. I think that Doug probably used the 115] word generally confirmed advisedly. Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Page 288 - Page 294 WATER PCB-SD0000024910 Deposition of DAVID WOOD NOVEMBER 10, 1995 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY [i6i Q: And these establishments the statement in the document itself included the [i7i Laboratory of the which (i4|can be preserved on the record Government Chemist, Freshwater (isi by us thoroughly [isi reading it or just by Fishers Laboratory and the Tinstall alluding to the page numbers, [i6iyes. Laboratories? (i7) Q: And Dr. Hardy provided a [i9i A: I'll take it as read that I accept summary of what he [isi knew at this time the list [20] of eight that you referred to is on page four, is that correct? the one that pii appears on page 3. [i9| MR. CHAMBERS: I object to the [22|Q: Yes. But so our transcribed form. record is [23| complete, 1 would like to [201 A: As I read this and it refreshes my have that in the written [24| record. memory, [211 it seems to be a summary of 125] A: But you're going to have this Dr. Hardy's (221 interpretation of what he attachment in had drawn from various (231 meetings. I __________________d_o__n_'t__k_n_oPwagwe h2e9t5her these were his [241 in the record, aren't you? conclusions of the meetings that he was [2] Q: This is a part -- present at, [251 the conclusion coming out [3| A: Of the records. So why do we of meetings of a group of need to read hi it again? Why don't we Page 297 just say, you know, as jsi described in in people after they had had meetings attachment 300, page 3? We'll m with a group of 121 things -- I mean, I stipulate to that. . see there is something that pi purports m MR. CHAMBERS: Certainly, I to be a summary of what they found will. The [8] document says what it says. from the [4] meetings alluded to in the [9j MR. DUFF: You were also aware first paragraph on page pi four of that Doctors no] Keller, Wheeler -- or Exhibit 300. Doctors Keller and Hardy and nii Mr. (61Q: And among the points made in Wheeler visited all of the his summary he pi wrote "There can be establishments either [121 together or no doubt that traces of PCBs, [si independently that are listed on page 3 Aroclors, are to be found in wildlife, [i3j of the document? fish and pi certain items of human diet", [i4|A: No, I wasn't. correct? [isi MR. CHAMBERS: I object to the [io] A: He wrote it or dictated it to his form. secretary, nnyes. [i6] A: No. I knew that certain people [i2] Q: And that was a point that he from St. [i7i Louis were visiting informed you of [13] in this document, England, we've already reviewed [isi a correct? document which described that (14) A: It seems so. progression. The ii9] eventual party and [isi Q: Another point that he made the detailed itinerary was not [201 shared under this [14 summary was that a with me, so I don't know which, if considerable Monsanto effort will [171 be any, of [211 these particular necessary to obtain the necessary establishments listed on page 3 of (221 analytical and [isi toxicological Exhibit 300 were visited by the people information for dealing with this |i9) that you're [231 alluding to. threat to our commercial operations, [24] Q: Oil the top of page 4 of this correct? document Dr. psi Hardy informed you 1201 A: Yes. And I think it's that either himself or Dr. Keller appropriate that he pi1 draws their ' Page 296 attention that if we're in this pzi [i 1 or Mr. Wheeler had visited with or business, we'd better address it planned to visit [21 the -- several of the properly. And I [23] think it's important establishments listed on page pi three, because in Section 2 of the p4| summary, correct? which we lightly skated over, he says [4] A: Specifically, the establishments there psi is little evidence to show how one, two [5i and three. serious this ii Q: Which were the Laboratory of ^Page 298 the Government pi Chemist, the lu biocontamination will prove to be, Freshwater Fishers Laboratory and the but what evidence pi there is is [8i Tinstall Laboratories, correct? reassuring. pi A: Again, you know, I'm prepared Pl Q: Would you please read the to stipulate [101 that Doug is not lying answer back? hi (The requested portion about who went to which of [ii| these of the in record read by die reporter). laboratories. But I don't know and ii MR. DUFF: I move to strike - have no iizi reason to remember at this Pi A: The whole thing? time who visited which of (131 them. So isi Q: Everything after the word properly. |9| A: Was properly in my answer? [101Q: Yes, it was. ini A: Then we'll strike the whole answer and we'll [121 start over. You take my answer as complete, but you im don't start picking and choosing on my answer. I'm ii4iprepared to readdress the question, but I'm not (151 prepared to have you sort of take me out of context. [i6i MR. DUFF: Go off the record. ii7) (Discussion off the record). [is] MR. DUFF: Please mark this as Exhibit 301. [i9i( Plaintiffs Exhibit 301 [20] marked for identification). [211 MR. DUFF: Mr. Wood, this document that has [22] been placed before you is Plaintiffs Exhibit 301, [231 and bears production numbers TNGS 016104 through 124106. [25i A: Yes. Page 299 in Q: Mr. Wood, do you recognize this document? (21 A: No. Pi Q: This document was produced as being located hi in your files. [5i MR. CHAMBERS: I object to the form and the [6| characterization of that. That's not correct. Pi MR. DUFF: I believe it is correct. Pi MR. CHAMBERS: I don't think it is. You'd pi better go back and Look at the discovery responses. (101 MR. DUFF: Well[in MR. CHAMBERS: But let's proceed. [i2] MR. DUFF: I'll bring in the production [131 folder that has Mr. Woods' name on it, if you'd [i4] like, if that's the best way to proceed. [isi MR. CHAMBERS: I don't dispute that there [ii were documents produced to you. I object to your [171 characterization of those documents as coming from [isi the files of Mr. Wood. That's not what the [191 responses were. [201 MR. DUFF: Mr. Wood, this document was 1211 produced in an inspection folder by Monsanto that [221 has your name on it. 123] A: I still feel quite comfortable with my i24] responses. I don't recognize this document. I psi don't recall ever having seen it before. Page 300 in Q: Do you recall any conversations with J. R. [2i Fallon regarding incineration of chlorinated wastes pi in 1969? Hi A: No. I didn't even know Jack Fallon in 1969. isi Q: Were you involved in any discussions (i concerning the Page 294 - Page 300 Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 WATER PCB-SD0000024911 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY incineration of PCB-containing wastes [7i in 1969? [5i Q: When you refer to customer preparation of [i fluids, do you mean M A: To my recollection, none. that customers would send fluids rn back i*i Q: Were you involved in any which were somehow contaminated? conversations in hoi 1969 related to [8] A: No. If -- to give you an reclamation of PCB-containing mi fluids? example of a [9] situation, if a utility Ii2i A: Not that I can recall. somewhere had been doing 1101 some [12] Q: Are you familiar with a company maintenance on their distribution called 114| Findet? system and mi had found a couple of mi A: Today, yes. In 1969, no. transformers where the fluid [121 seemed [i6i Q: When did you first become to be -- have a high acidic level or [isj familiar'with [iti Findet? something, and so they decided to they iixi A: Sometime after I came to St. wished to put [uj new fluid to replace the Louis in 1974. fluid in the transformer, fi5i so they had [i9i MR. DUFF: Off the record. (201 appropriately withdrawn the old fluid [i6] (Discussion off the record). from that transformer. Now, they had [211 MR. DUFF: Please mark this as then drums of ii7| fluid which they had to Exhibit 302. 1221 ( Plaintiffs Exhibit 302 decide what they were going [i8] to do [23i marked for identification). with, say, fifty, a hundred gallons of [191 124| MR. DUFF: Mr. Wood, this dielectric fluids, which were document -- predominantly [201 chlorinated biphenyl. 1251 A: Hey, we leap forward in time. And we were undertaking in [211 support __________________ _______ Page 301 of the dielectric customers and their [221 [ii Q: Yes, we do. To 1975. This ongoing limited business at that time to document has (21 been marked as incinerate 1231 these materials in our plant Plaintiffs Exhibit 302, and bears 01 incinerator in St. [24i Louis. But what we production numbers TRAN 074047 did not want to see was bad [251 through 56. Are you w familiar with performance in people putting these this document? fluids which [51 A: Yes. Page 303 [6i Q: Would you please identify this [il they had withdrawn from document for m the record? transformers into corroded (2) old drums, [8i A: This is a memo from David loading them loosely into a small carrier Wood, dated May [9i29, 1975, "Subject, [3] where they were not tied down well, PCB incineration", directed to a noi not putting [4] protective liners on the primary list of my supervisor, truck base so that if there [si were any Cumming Paton, and a mi number of minor spillage that it could be easily (6i other people in the Monsanto cleaned. We did not want to create organization, (12) and a subsidiary set of additional m potential environmental copyees. burden of PCBs by the pi transportation [13] Q: This document was authored by of waste PCBs. And so I recommended you, correct? (9i and put out this memo establishing a [i4| A: Yes, it was. policy of how (101 we would handle this [i5i Q: What was your role with respect issue of people responsibly mi preparing to PCB [i6i incineration in 1975? shipments of waste material if we were [17] A: We were, in 1975, receiving to [121 consider accepting them into our Aroclors and [isiinnerteens and pyronols incinerator. from people who had been [191 repairing [i3i Q: So this was a policy for returns or taking electrical equipment out of [20] of used (mi dielectric fluids for service, and we were at that stage incineration, is that correct? destroying that [211 material in the (isi A: That's correct. incinerator that we had constructed [221 at [i6i Q: Did Monsanto have a policy our W.J. Krummrich plant. We were with respect to [in what types of concerned that [231 customers for PCB-containing fluids it would accept dielectric materials and users of 124] [18] for incineration? dielectric equipment containing aging [i9i A: We did. And probably part of chlorinated (251 biphenyls were not all that is [201 involved in this document, or equally responsible in the other documents which (211 we can - Page 302 review. I don't remember it HI way that they prepared those fluids line-by-line. [221 It was a fairly complex which they [21 wished us to incinerate in and well thought through (231 detailed terms of returning it to [3] us in a manner policy structure. which it would not create a potential [41 [24i Q: Was that a policy structure that release hazard in transportation. you played [2Si a role in setting? Deposition of DAVID WOOD NOVEMBER 10, 1995 ______ ___________________ Page 304 Ml A: Refining, rather than setting. I think, you pi know, that the basic fundamental policy of what we [3| would accept had already been set when I got [4i involved, as typified by the particular Exhibit [5i 302. I was exposing at that point certain concerns [6i that I had because of abuse of the policies, and so pil was sort of saying we need to extend that policy [si in this way once I've got your comments and [9i suggestions for modifying it, tightening it, [101 changing it, and publishing it so that everybody mi knew what we would do and what we wouldn't do. 112] Q: Now, did Exhibit 302 specifically relate to (131 dielectric fluids or did it also relate to other [mi PCB-containing fluids? (isi A: I don't recall. I'd have to read this in (i6)detail. And I'm prepared to do that, if you let im me. But it was largely aimed at the ongoing [isi business, which at that stage was only dielectrics, mi and related, therefore, to waste generated in the (20) manufacture of dielectric equipment or waste arising (211 from the use of dielectric equipment. [221Q: Were you aware at this time of the [23] possibility that there were Monsanto customers who (24] had used PCB-containing fluids for applications [25] other than dielectrics that -- would you please Page 305 111 repeat how I started the question? 121 (The requested portion of the 01 record read by the reporter). [4] MR. DUFF: Strike that. Were you aware that [5] there were customers who had used PCB-containing [6] fluids in applications other than dielectric who may m have PCB containing fluids in 1975. pi MR. CHAMBERS: I object to the form. It may m help just to break it down. . [to] MR. DUFF: How would you suggest? mi MR. CHAMBERS: Whether he was aware there 1121 were users who had used PCB-containing products mi other than dielectrics before 1975. Depending on (i4) the answer to that, I would then ask the latter part [isi of whatever you were trying to get to, which escaped [i6i me. [it] A: I think I can handle the question [isi MR. CHAMBERS: Okay. [i9i A: -- you asked. There were still systems in (2011975 in service or in suspended service in [211 applications Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Page 300 - Page 305 WATER PCB-SD0000024912 Deposition of DAVID WOOD NOVEMBER 10, 1995 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY other than electrical applications [221 continue to be acting in commerce with which contained PCBs. This particular Monsanto [201 in the continuing policy that [23] we're talking about here related specifically to imj wastes production and maintenance of [211 dielectric -- of electrical equipment associated with dielectrics, people who containing [221 chlorinated biphenyl had [23i earlier been responsible for our dielectrics. exiting other PCB [231Q: Do you know if a letter like this ___________________ Pawgeas30e6ver [24] sent out to dielectric [ii applications had established policies customers? related to pi waste disposal as those [25] A: Yes, it was. equipments were taken out of [3) service. Page 308 [41Q: Were you familiar with [ii Q: Do you know if a letter like this Monsanto's policy [Ji with respect to was ever pi sent out to Pydraul PCB incineration for PCB-containing [6i customers? fluids other than dielectric fluids in [3i A: I don't know. 1975? 14] Q: Please mark this as Exhibit 303. m A: I was in 1975. I'mnotnow. I (si ( Plaintiff's Exhibit 303 [6] marked can't recall [8] how they differed. I for identification), know they differed. pi MR. DUFF: Mr. Wood, this [9i Q: Were you responsible for -- document has been rs] marked as strike that, noi Who else was involved in Plaintiffs Exhibit 303 and bears pi setting and enforcing im Monsanto's production number TRAN 080447. PCB policy with respect to incineration [io|A: Yes. [121 of PCB-containing fluids other than mi Q: Do you recognize this document? dielectric [131 fluids? [121 A: Yes. [i4i A: I think Cumming Paton would ns] Q: Did you review this document in have had more of (131 a role than I would preparation (ui for your deposition? at that particular point in time [iei relative [is] A: No. to the policies for fluids of a [17] [i6i Q: Would you please identify this non-dielectric nature. document for (i7i the record? [i8| Q: Anyone else? [isi A: This is a memo from myself, (i9i A: There were others, but that's -- dated February (i9|24, 1976, addressed 1 mean, [201 I'm sure that my now to D.L. Sliney, subject, PCB poj partner, Cumming Paton, had 1211 some incineration, with copies to Cumming involvement in the legacy area of the [221 Paton, Bob pi] Potter and Warren Easley. non-dielectric business, which, by [22] Q: Do you recall sending a letter to 1975, when I [231 became involved in customers (231 inquiring about dielectrics, was essentially 124) incineration of PCB fluids around [24| this discontinued. time? - " [231Q: I'd like to direct your attention (25) A: I'm not sure that we sent a letter to the to Page 307 Page 309 [ii pages in this document that bear [ii customers at that time. I think this production numbers [21 TRAN 074054? -- I attached [2] to this memo a copy of [3jA: 54? the letter that we would send (31 to [4|Q: And 55. Which is attachment D customers who were inquiring about to this (5i document. Do you have that incineration (4i of PCB fluids which had in front of you? been prepared sometime [5] previously. [61 A: Yes, I do. This was not something new which was pi Q: You drafted this document, is [6]just being done then. that correct? PlQ: Do you recall when that letter [si A: I believe so, yes. was sent? (9i Q: And by that, I mean you drafted [8] A: Not exactly. this [101 attachment D, correct? [9] Q: Do you recall what year that [ui A: I'm pretty sure I did. letter was [io] sent? [121Q: In fact, your name appears at the [in A: I suspect it was sent in '75 or bottom of [i3i 074055, correct? '76. [i4| A: It does. And I normally sign [i2] Q: Do you recall which customers things that I [isi drafted. that it was [13] sent to? [i6i Q: What was this document, [ui A: I think the letter we're talking attachment D? about, in ns] fact, is the letter -- one of [i7] A: Okay. This was a suggested the letters which [16] form part of this letter to U.S. [island Canadian dielectric May 29th, 1975 - customers who were approved [19] to [i7] Q: In Exhibit 302? [isi A: I believe -- I think we're talking some of [i9[ the correspondence forms that we were developing in [201 Exhibit 302. pi) Q: Is there a part of Exhibit 302 that you [221 believe is the reference in Exhibit 303? (23i A: There's document TRAN 074049. [24] Q: Is it your recollection that TRAN 074049 psi through 50 is the letter that is referenced in the Page 310 in first paragraph of Exhibit 303? pi A: No. Because attachment B, which is TRAN pi 074051, is a suggested new letter, and I think that hi in actual fact the letter exemplified by 074051 and [512, maybe with minor editorial refinement, replaced [6i the one that we -- that immediately preceded it. [7i Q: So, is it your recollection that attachment [8| B, or something close to it, was attached to Exhibit pi 303? [io] A: Yes. [inQ: And directing your attention to point two in (izi Exhibit 303, is it your recollection that the last (131 page of Exhibit 302 was also attached to Exhibit [141303? [i5] A: You can see that the last page of Exhibit [i6] 302 has some scoring out and is obviously still at a [i7] preliminary draft stage. The label which we would [isi have attached to the memo in Exhibit 303 would have [191 been the final label which was the outcome of the [29] preparatory work shown on the last page of Exhibit pi] 302. [22] Q: Do you know if a letter in the form of [23] attachment B to Exhibit 302 was ever sent to Pydraul [241 customers? [25] A: I don't know. Page 311 ui Q: Do you know if return labels such as the [2] last page to Exhibit 302 was ever sent to Pydraul pi customers? Hi A: I'm not clear on that. I said because there [5] were policies which were different from the policy [] laid out in 302 which would have related to any Pi returns which were accepted, under what conditions, (8| from residual users of equipment still containing pi PCBs of a non-dielectric nature. I don't recall [101 exactly how that tied in to this policy. I'm sure mi that if there were -- what I don't recall, if [121 returns were still being accepted. If returns were [13] being accepted, then a letter very similar to that [14] contained here with the label. I'm sure, would have (iribeen sent. (161Q: Was there a point in time when Monsanto [171 ceased to accept Pydraul Page 305 - Page 311 Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 WATER PCB-SD0000024913 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY returns for incineration? iisiA: Again, I do not recall that. I the bed of the truck. [121 If it was a wooden -- old wooden floor, we might mean, we |i9[ were largely through the [Pi have to rip out the truck floor bed Pydraul transformation when 12011 got and replace it, [ui because somebody had involved. I'm sure there were still some not taken adequate care to put iisia 1211 equipments out there. I did not couple of restraining rods in to bolster engage heavily in (221 any issues related to the [i6i truck's cargo in the first place. Pydraul returns. There are (23) people So, in that [i7] situation you'd get the better able to guide you on the policy road authorities, the [isi transportation and 1241 the practice in the Pydraul area. authorities, the customer, the truck [i9| 125] Q: What type of a wall chart did owner and the Monsanto operators you keep with totally frustrated [201 with why are we Page 312 trying to do the right thing here [211 when (i| respect to PCB returns for somebody is not prepared to take the incineration? trouble to [221 cooperate and do this right, (2| A: You're talking about the wall at great expense, and [231 -- you know, chart that we |3| allude to in item 3 of once you start spilling the PCB fluid [24j Exhibit 303? and extending it, then the cleanup, that hiQ: Yes. residual 1251 cleanup becomes that much (5i A: That was a wall chart which more difficult. If you would be on a [<n plastic type material Page 314 which would go up into the pi shipping (11 contain it properly in the first place, dock area of somebody who had a need you hand it (21 from point A to point B to [si ship, with our approval, and incinerate it, boom, pi gone. PCB-containing fluid back [9] to us, and W Q: Do you know if a wall chart it gave them instructions on what type of such as referred pi to in Exhibit 303 was [101 drums to select, how to put them on ever sent to Pydraul pi customers? pallets [inappropriately, how to protect Pl A: I don't know. I know that in the pallets from any [121 minor spillage, 1975 I found p] it to be a very helpful not to overfill the drums, how to [ui thing to send. bolster the drums if there were only a pj Q: To dielectric customers? partial (i4i container load so there was no 1101 A: Yes. But, again, it would only movement which could [isi result in go to [incustomers who had, you know, damage to the drums and leakage. It indicated that they [12] wished to return was a [lei guide to how to responsibly some PCBs and understood that there [i3i prepare and drum m material and then were going to be certain ground rules to how to prepare those drums for [isi safe exercise [14] and operate to do that. And shipment back to Monsanto. And so this was not something [is] that we that the [191 shipping people, the launched like -- sort of like getting junk operators could not sort of say [201 that (ti mail in your mail box at home that information resided somewhere in an saying everybody, [inhere, if you ever [211 environmental group's files, but they want to return some PCBs, here's [isi as operators [221 had never been properly what you should do. instructed on how to [221 actually do the (i9i Q: Please mark this document as job. Exhibit 304.1201 ( Plaintiffs Exhibit 304 (24|Q: It was important to properly 1211 marked for identification). contain and [251 send back [221 MR. DUFF: Mr. Wood, this PCB-containing fluids for incineration, document has been 123) marked as is Plaintiffs Exhibit 304 and bears [24| ___________________ Page 313 production numbers TRAN 028069 [i 1 that right? through 71. (2[ A: If a truck arrived at Krummrich, 125] A: Yes. say it was pj a common carrier's truck, Page 315 and there had been hi inadequate in Q: Do you recognize this document? stowage of drums in the truck body, so pi A: Yes, I do. Pi that drums had moved in shipment PlQ: Did you author this document? and had cracked a tq seam and fluid had [4| A: Yes, I did. leaked into the wooden floor of pi the [5] Q: Would you please identify the truck. Now, it's a common carrier's document for [<i the record? truck he pi uses for carrying all sorts of (7) A: This is a memo written by materials, so we m would have to myself, dated July [8] 18, 1974, where I rigorously place that truck in a [101 was preparing and distributing a [9j concrete surrounded area with sumps to minute of a committee of which I was a collect, [ii] steam clean and solvent clean member [101 concerning a seminar which Deposition of DAVID WOOD ____________ NOVEMBER 10, 1995 we hoped to be able to [in present in September of 1974. . [121Q: I'm sorry, did you say that these -- that ii3i this document is the minutes of a meeting? [14J A: I was a member of what is described here as us] the dielectric seminar program committee, and as the [i6i most newly arrived member of that team I was (171 appointed to prepare a minute of the team's (isi deliberations. I think we all know how that works. [i9] Q: And at this meeting did you discuss -- [20i strike that. When did this meeting take place? 1211 A: I believe it actually took place in [22) September or October. It may have stood a month, but [2311 believe the meeting did take place, as I recall. [24i Q: Is this document the minutes of a meeting psi for preparation of another meeting? Page 316 in MR. CHAMBERS: Let me object to the form. I 121 think you're right. I think we're miscommunicating pion which meetings. You were referring to the pi seminar having been in September or October, right? isi A: There was a 17th July meeting of a program iq committee which was to prepare a program for a rn planned seminar which was to occur in September of pi 1974. [9j MR. DUFF: I understand. So there was -- [io] A: As a member of that program deliberation (i 11 planning committee, I was appointed by acclaim to (121 prepare the minutes and circulate them to the rest [i3i of the committee saying this is what we decided is a [hi good tentative agenda, would you please comment on [15] this, does it reflect what you really said at the [16] meeting and can we proceed to the next stage of [i7j planning on the basis of this directionally is where [isi we wish to go with the dielectric seminar which we [191 would plan to hold in September of '74. [201Q: So this document. Exhibit 304, is the (21] minutes of a meeting that took place on July !7th, 12211974, correct? [23) A: Yes. [24) Q: And at that meeting do you recall discussing psi the definition of the environmental problems Page 317 ni surrounding PCBs? pi A: The committee sort of said that obviously, pi part of that seminar should be a definition of, yes, [4] the environmental problems surrounding PCBs. Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Page 311 - Page 317 WATER PCB-SD0000024914 Deposition of DAVID WOOD NOVEMBER 10, 1995 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY [5i Q: Do you recall discussing that at the meeting [qon July 17, 1974? [7i A: I remember it was discussed. I don't is) remember point-by-point things that were raised. (9iI'm not sure having -- if we go through this we'll no] probably find some of the issues. [ill Q: Do you recall any of the issues that were [121 discussed with respect to the environmental problems mi surrounding PCBs at the July 17, 1974 meeting? [Mi A: I'm sorry, I was reading and I wasn't ns] listening. I do apologize. (i6l Q: I'll have the question read back for you. [i7i But do you need sometime to familiarize yourself [i8i with this document? [ini A: I'd just like to go through here again to [201 remind myself of what were the major topics that we [211 covered at that meeting. [22| Q: Please take as much time as you need. [231 A: Okay. I'm ready. I'm sorry, I needed to [24|just look through that and -- 1251Q: Certainly. Would you please repeat the last Page 318 [i l question posed to the witness? [21 (The requested portion of the pi record read by the reporter). Pi A: The views on this particular issue are [si expressed in the minute in item one and item two of (i my memo of July 18th. Item one sort of said that we pi essentially should give an update status report on [si how PCBs in the environment were being viewed around [9i the world, because there certainly was no unanimity uoi in views on PCB issues in different countries around [ii] the world. And we felt that we could put that [in forward in a summary form using Monsanto speakers mi rather than let this, right from the outset of the (i4| seminar, develop into a free opinion discussion, [isi although we allowed time for questions, so that we [i<si would give some people a framework which they could (171 agree with or then they could specifically sort of (isi say no, you haven't understood, that's pertinent to [i9i Holland or Germany or something. The second bullet [201 or the second heading in here said that we should [211 try to cover some of the issues which were a concern [221 to people at that time, sort of saying okay, there mi is PCB in the environment, and it is not good to [241 have more PCBs in the environment, but if we go back [251 to the PCBs that are already in the environment what Page 319 [il have we learned about biodegradation, how fast do [21 PCBs go away, what is the significance of isomer 131 differentiation. There are lots of different [41 isomers, the different isomers biodegrade at (51 different rates, but let's sort of get some clarity (6iof thinking into that area. There's lots of still [7i uncertainty about the best methodology to test for [8i PCBs. And I'm not talking now about some of the (9| earlier areas that we had touched on about the use [ioi of electron detectors and that sort of thing. Here n 11 we' re sort of saying that if you're looking for PCB [i2] levels in mineral oil transformers, then the mi interferences are very different, so the method of mi sampling, the method of testing, the type of column [isi in the chromatograph that you have to use has to be [iq very different. So we're trying to give people a im view that there isn't a one solution fits all for nsi testing for PCBs in every substrate. We've got to [191 talk about migration. If PCB is locked in the 1201 bottom of a river, do you do more good by dredging (211 it up and digging it out, or does that merely spread [221 it around more, or if the river bed geologically is mi a certain type, then is the stuff stuck so hard that [24] it's not going anywhere, it's not getting carried up i25i into the water. But there are a number of issues '_________________ Page 320 inhere that are important to people in understanding (21 the practical management of the PCB situation that pi the country was perceiving. (4i Q: What was known as of July 1974 with respect pi to the migration -- strike that. What did you know iq with respect to migration of PCBs as of July 1974? Pi A: Very little. I very recently arrived from m Europe in February of 1974 and had been away from pi the PCB scene, as part of my reorientation in a new no)job in a new country. In a later period I was made (i 1] a member of this particular committee, and this was (i2) part, as we discussed earlier, of my gradual mi re-education about PCBs, which continued through (ui 1974, into 1975, and I'm still learning things about [isi PCB today. So, was I an expert specifically in uq migration? No. That's why we asked that there be [17] speakers like Scott Tucker and A1 Bodin who had been (isi working as scientists in that area to talk to that [i9] issue at the seminar. mi Q: You gave the example a moment ago about PCBs (211 getting into a stream and whether or not one should (221 let them be or dredge the bottom of the stream, mi What did you know about which of those two courses [24] should be followed with respect to PCBs in a stream 1251 as of July 1974? Page 321 m A: A little. Not as much as I knew by 1976 and pi 1977. At the time that later EP regulations were pi being established there were many vociferous fights [4] on this issue. Is it better to leave them or dredge [5] them? I got my personal opinion on that, but as in [q many of these cases, it didn't prevail, ultimately. Pi Q: What was your personal opinion? [8| A: As far as I'm concerned, if you had a good pi clay bottom in the river, and PCBs were firmly (101 adhered to that clay at the bottom of the river, you [i 11 were better just to leave them there. But I said, (121 you know, in case after case, the EPA eventually mi managed to stimulate dredging operations which I [i4i still believe today sort of worsened the issue [15] rather than improved the issue. [i6i Q: Directing your attention to the second page [171 of Exhibit 304. nsi A: Yes. [i9i Q: And specifically number 3 at the top of the mi page, "Methods of testing PCB in effluent streams". 1211 Do you see that? [22i A: Yes. mi Q: At the July 17, 1974 meeting did you agree (24] that the topic of testing PCB in effluent streams (251 should be divided into four sections? Page 322 HI A: I wasn't in a position to agree at that [21 point in time that this was necessarily the best. I pi was the minute taker of this particular meeting, I pi was not yet educated enough to necessarily be a isi driving force on the decision. But I respected the [q people who were making that decision. Pi Q: The committee agreed, then? [8] A: The committee came to a conclusion that this i<n seemed to be an effective way to discuss this issue, no] Q: Do you recall what Monsanto ideas for n 11 controlling PCB at customer locations were (121 discussed? nsi A: I'm sorry? (i4i Q: I'm looking at 3-B on page 2 of this [i5i document. My question is, do you recall what was (iq discussed at the July 17, 1974 meeting with respect [171 to Monsanto ideas for controlling PCB at customer [iei locations? if Page 317 - Page 322 Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 WATER PCB-SD0000024915 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY ini A: There was not necessarily at that meeting on 1201 July 17th a prescribed script for each of these nu sessions. The committee, the planning committee was [221 saying what should be the content and then it would mi appoint people to prepare the -- under those p4| section headings. So, essentially, what was being |2J] said at that time, we can tell people what we had to Page 323 in do to tighten up controls in our own manufacturing 121 plant to make sure that we were -- essentially were pi leak-free. Now, not all those things which apply to I4| a chemical processing plant which will apply equally pi to a capacitor production plant or a transformer ti production plant, and that's what we were talking pi about at customer locations, we were talking about m capacitor and transformer and manufacturing m facilities. This seminar was to be directed at the 1101 dielectrics manufacturers, using and electrical im equipment manufacturing industries. But there were (121 a lot of little things which we had discovered [ui ourselves were neat tricks in terms of particular iui gasket materials and that sort of thing which gave iisiyou a much better avoidance of inadvertent releases lie] of fluid in your process. And so we would have had [i7| somebody from our manufacturing location or from the usi engineering group, probably from both, involved in |i9] preparing the detailed item 3-B to be presented. (20] Q: Please mark this document as Exhibit 305. 1211 ( Plaintiffs Exhibit 305 1221 marked for identification). [23i MR. DUFF: Mr. Wood, this document has been (24] marked as Plaintiffs Exhibit 305. It is a document 1251 dated November 7, 1974 and has a Bates number at the ;Page 324 [i 1 bottom of 3002612. ui MR. CHAMBERS: Let me ask just for a moment, i3j Kevin, do you know which case this was from? [4| MR. DUFF: I believe this exhibit was [5] introduced in the Bloomington - I'm sorry, the iiBirmingham Fire Insurance case. m MR. CHAMBERS: Okay. Thanks, isi MR. DUFF: I note that down at the bottom of [9] the page it also says Bloomington, and has 1101 apparently an exhibit number written, but I don't mi believe we made -- that we identified this document miwith respect to the Bloomington case. ini MR. CHAMBERS: Okay. I didn't see that, iw These were BER document I.D. numbers on the earlier mi exhibit that I didn't see here, that's what made me |is] wonder which one it was from. We can proceed, im A: Yes. [isi MR. DUFF: Mr. Wood, are you familiar with (191 this document? [20] A: Yes. [2i 1Q: Please identify this document for the [22i record? [23| A: This is a memo that I wrote on November 7, [2411974 to my supervisor, Cumming Paton, just reporting [25] to him that I received a call from John Britain of Page 325 (i 1 Westinghouse at Bloomington asking about effluent [2] sampling programs. Pi Q: And what type of effluent sampling program |4] did Monsanto have at this time? [j] A: We didn't have it at that time. We were ii beginning to discuss, as I recall, that we needed [7] certain trap cells that we could put into people's isj plant outlets so that over a period of time they w would collect a measured amount of water, so that [101 you could then test those samples from that (m particular standardized cell for PCB content and get [121 a weighted average of had they been releasing some mi minor amounts of PCBs at some steady rate and, if iui so, what were they. But, equally, that could, as [i5i improved, become an alert high level system that if [[] they got a peak in the measurement of that cell that 117] they know that they had a potential greater release tisi problem. This was, again, sort of effluent (191 management which was becoming something which, as we 1201 controlled our own plant efluents, we were becoming 1211 more knowledgeable about. 122] Q: Did Monsanto institute an efluent sampling (231 program at some point in time? [24i A: Yes, we did. [23i Q: When was that? _Page 326 111 A: I don't remember exactly when it was, but I [21 do know that we did have ~ we designed the sample pi collection cells and methodology for sampling. [4] Q: Why did Monsanto institute an effluent is] sampling program? lei A: Why did we? piQ: Yes. is] MR. CHAMBERS: I object to the form. But pi you should respond, if you're able. Deposition of DAVID WOOD ____________ NOVEMBER 10, 1995 do] A; Because in the period that we're in, 1974, ini'75, '76, Monsanto at that stage, continuing to [121 produce dielectric chlorinated biphenyls, but under [isi caution to our customers that this wouldn't be a [i4| forever situation, we were essentially being told by [isithem, Monsanto, you can't cease manufacturing of PCB [i6i dielectrics at this point because that would bring m the electrical distribution system of the United [isi States and several other countries to a halt. And ipj we sort of said look, if we're going to continue to 1201 produce, then there has to be some responsibility on [211 your part that you're going to make sure that you're 1221 not releasing any -- I mean, you claim that the [23] risk is minimal because you're putting our PCBs into [24| closed equipment. Now, you're, therefore, really [23] going to have to be able to account for every pound Page 327 UI of fluid that we send you if we're going to continue 12] to supply it. And you're going to have to button piyour plant up as closely as we've got ours buttoned piup. And they said well, you know more about isi detecting and measuring PCBs than we do, so if you [6] want us to check our effluents, then help us develop rn an effluent sampling program. PiQ: So was this Monsanto's effort to ensure that [9] its customers were not allowing PCBs to escape to [101 the environment? mi A: This was Monsanto's support of helping our [121 customers live up to their contractual undertaking [is] to Monsanto that they would not release PCBs to the fi4l environment. [isi Q: Do you know if Monsanto offered an effluent tie) sampling program to its Pydraul customers at any ii7] time? OS] A: I don't know. I mean, once we developed an ii9i effluent sampling program, if a customer had asked 1201 of us do you have one, we would have acknowledged pii that we had one. And it was not very complex 122] technology. So if somebody who had a non-electrical 1231 application sort of said hey, we'd still better be 1241 sort of addressing issues and let's see if Monsanto [23] has got something that would be helpful to us, I Page 328 Hi mean, we wouldn't have sort of said no, you're not a 121 dielectric customer so you can't have any pi information about this. [4] Q: Please mark this as Exhibit 306. 15]( Plaintiffs Exhibit 306 ii marked Gore & Perry Reporting Co. St. Louis, Missouri (314)241-6750 621-4790 Page 322 - Page 328 WATER PCB-SD0000024916 Deposition of DAVID WOOD NOVEMBER 10, 1995 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY for identification), material and the French materia], but m MR. DUFF: Mr. Wood, this not in (4i the Monsanto material, well, document has been [8| marked as you know, what's pi different about Plaintiff's Exhibit 306 and bears [9i that. And what would be the [<1 pressure production number TRAN 073175. or significance of their being in that pi lioi A: Yes. product, rather, and not in our product. ini Q: Please identify this document [8] Q: What did you leam? for the [i2i record? [9i A: Bill told me that his information (i'3i A: This is a memo written by Bill was that [101 chlorinated dibenzofurans Papageorge iuiand sent to Jim Mieure, are highly toxic [inmaterials, which and it was sent to a number (isi of side would have many effects on birds [121 and copyees, and a Xerox copy of this animals. They were originally memo was [iei sent to me for information attributed to [i3| PCBs, later be found to purposes. I was not on (i7i the original be due to a furan content, iuiso you're list of people requested to comment. I talking about furans in the biphenyl, [151 [isi had a question about the paper which which got chlorinated along with the I hand wrote [i9] and sent it back to the biphenyl. ui There is currently no originator of the memo, Bill (201 regulatory pressure to reduce, [171 but it Papageorge, and Bill wrote a response is an emotional subject and it could to my question [211 and sent it back to me. result [isi in further processes to (221Q: Is that your handwriting, the -- eliminate furans. The [191 question I was [23i A: The handwriting which starts really coming from on that point was, "Bill, briefly" [241 is my handwriting. [20] you know, when we talk about [25i Q: And what was your question to __ potential toxicity of a [211 chlorinated ... Mr. biphenyl, are we looking at the toxicity Page 329 [221 of a highly toxic furan contaminant in Papageorge? or are we (231 looking at the inherent [21 A: What is the significance of toxicity of a chlorinated mi biphenyl? Is chlorinated pi dibenzofurans when there another extraneous toxicology [251 material was found in w Bayer/Prodelec issue that we are not attending? product, what was pressure to [5i reduce. Page 331 [6] Q: What did you mean by that [i]Q: Did Monsanto's PCB-containing question? products [2i contain a furan content? Pi A: There are several questions 01 MR. CHAMBERS: I object to the within that m question. Which question form. If (4| you're able to answer - do you wish to address? [5] A: The work that was reported pi Q: What information were you here, I think, (6i suggested that ours seeking to gather [101 from Mr. didn't. I think other work that nwas Papageorge? carried out suggested that in more highly ini A: Okay. My understanding from (si chlorinated Monsanto materials there the paper which [121 had been attached, was a furan (9) content. But not in the the Kimbrough copy paper, was (oi that lower chlorinated materials (10) that we she was referring to the presence in some were commercially supplying at that [14] European PCBs of chlorinated time. dibenzofurans, and 11151 was not too im MR. DUFF: When you refer to familiar with the chemistry of [i6i higher (121 chlorinated materials, what do benzofurans, so I wanted to know well, you mean? what is the [171 significance of them being (i3i A: Six chlorines, on average, up. there or not being [isi there. Is this [i4] Q: Would that be -- something which is part of [19] [is] A: Aroclor 1260 up. manufacturing PCBs or have they got a (i6i Q: Would that include Aroclor 1254? different [201 contaminated source of (17) A: I think 1254 was sort of the biphenyl that when they mi chlorinate it, crossover point (isi between null and they chlorinate the furan, which is a [221 some. And when I'm saying some, [i9] contaminant in the biphenyl, and if so, real small. Again, we're knocking on what is the (231 importance of this the limits of (201 detection capability at particular chemical entity, which pm is this point with this work. not chlorinated biphenyl. I mean, just [2ij Q: Who was Dr. Rene Kimbrough? help me (251 understand why is ~ what (22i A: Renata. does Kimbrough feel is (23i Q: I have failed to pronounce a ______________________ Page 330 name correctly mi again. in important and significant about these PS] A: Rene --1 mean, she would be materials, m And, secondly, since they incensed if she seem to be found in the pi German Page 332 HI felt she was being called Rene. Renata is a fine (21 woman. Dr. Kimbrough, as I recall, was at that time (3| working for the Atlanta Disease Control Center, CDC, (41 and was doing work surrounding chlorinated isi compounds. 161 MR. DUFF: We can take a short break. [7i (Discussion off the record). (8) MR. DUFF: Mr. Wood, what's your familiarity (91 with the corporate development committee or the (101 corporate management committee at Monsanto? (in A: The corporate management committee was a [121 senior level executive committee made up of tni executives from around the corporation in different mi functions who were able to give an overview in 1151 determining Monsanto corporate policy to certain [isi issues. im Q: Were you ever a member of the corporate [isi management committee? [i9] A: No. [201Q: When did you first become aware of the [211 corporate management committee? [22i A: Oh, I was aware of it vaguely when I was in (231 Europe, and certainly I was aware of it when I was [24] in the United States. [25jQ: When did you first have contact with the Page 333 dl corporate management committee? [2] A: Direct contact that I would attend their 01 meetings? [4i Q: Let me ask another question for you. Did [51 you ever attend a meeting of the corporate [6] management committee? pi A: I may have attended one, but this was not a [si routine. I may have been part of a group that had pi been called to report a particular issue and brief [toi the corporate management committee on an issue, if mi that was on their agenda at that particular meeting. [121Q: When was that meeting? [13] A: Again, I don't recall what particular issue (ui or what particular subject I went to the corporate [isi management committee meeting on. I mean, most times [16] the corporate management committee briefing would be [i7i done, oh, by -- Cumming would sometimes be involved, (is) Tom Gossich, say, would certainly be involved. It (i9i would be the exception rather than the rule that I (201 would be called upon to personally be present or [2i] lead a briefing to the corporate management [221 committee. I Page 328 - Page 333 Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 WATER PCB-SD0000024917 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY Deposition of DAVID WOOD NOVEMBER 10, 1995 1231Q: Do you ever recall leading a briefing to the ^corporate management committee? (25i A: No. I remember being, [ say, probably on a Page 334 in support group. But, again, I'd need reminding and pi refreshing as to the particular occasion and the m particular issue. mi Q: What role did you have with respect to the pi use of PCBs in Japan? pi A: None. 17) Q: Were you ever involved in an issue with pi respect to incineration of PCBs in Japan? mi A: That rings bells, but I don't -- I can't [to] recall specifically how I was involved. But in) incineration in Japan strikes some very faint chords [121 in my memory. ini Q: Did you play any role with respect to the [Mijoint venture between Monsanto and a Japanese [isi corporation, the goal of which was to manufacture [i6i PCBs in Japan? [i7i A: No, I did not. 118] Q: Did you ever travel to Japan on Monsanto [191 business? !20| A: Yes, I did. [211Q: When was that? [221 A: I made one visit to Japan, I believe it was [23] in 1974. [24| Q: And why was that? [25i A: I recall that was to discuss Skydraul Page 335 in aviation fluids with Nippon Airlines, Japan [21 Airlines, and to hold a discussion with one of the pi major offshore drillers who was involved with mi commissioning drilling rigs to be built in the pi Japanese shipyards for drilling in the China Seas, [6| who required information about Pydraul ELT. rn Q: Did Pydraul ELT contain chlorinated isi hydrocarbons? Pi A: No, it didn't. [101Q: Skydraul did not contain chlorinated [in hydrocarbons, correct? [121 A: No, it didn't. But, again, I would remind [i3iyou, this was the period when I was in that role of iuj international marketing manager, and so this was in [isi 1974. Ii4iQ: What role did you play with respect to [171 legislation relating to PCBs in the 1970s? [is] MR. CHAMBERS: I object to the form. [19) MR. DUFF: Let me rephrase the question. 1201 A: Would you? That's a big question. [211Q: What role did you play with respect to [221 federal legislation relating to PCBs in the 1970s? (23i MR. CHAMBERS: For purposes of the record, I [24| have to object to the form. But, certainly, if you (25ican respond, you should. Page 336 m A: Well, I'm going to have to ask you to break 121 that down some, because we could spend about another pi whole day talking about regulation, relationships [4] with industry committees, relationships to (si dielectric customers, relationships with EPA, (i discussions, say, with General Electric, rn Westinghouse about what positions they would be [si taking in terms of equipment, discussions on EPA (9| hearings relative to decommissioning heat transfer [101 systems and regulations that would be set about [in that, discussions with EPA about incineration (121 technology. Boy, you know, we really could spend a [131 lot of time unless we focus it. I did a fair amount [ui of work in the 197 -- late 75, '76, 'll period on (isi working with various agencies and industry groups in (nsi terms of management of PCB in use. [i7i Q: What technical or trade associations were [isiyou a member of while you were employed by [191 Monsanto? Let me break that down, because that [201 could be a wide range. [2i] A: You're going to have to. [221Q: When you were in Europe working with [231 dielectric fluids, what technical or trade [24| associations were you a member of? [25i A: Really wasn't. There is not quite the Page 337 [il extensive association network in Europe. You would [21 talk -- the electrical distribution industry, for pi example, in Great Britian at that time was [4) nationalized, and so if there was an electrical isi distribution question you would be talking, by and [] large, to the nationalized electrical utility m organization, which was a state-owned organization, (si And so they didn't need a separate association. [9] There were a very limited number of large electrical [101 equipment manufacturers, and we dealt with those mi independently, there was no need for an [121 association. British Standards Institute, we had [i3i membership through our technical groups in standard imi setting committees, but I was not a member of those [isi committees. (isi Q: So do you recall any associations or (i7i committees that you were a member of while you were [isi in Europe? [i9i A: No. Europe, it was not a big committee [201 culture. [2i] Q: During the period 1974 through and including [2211979, what technical and/or trade associations were (23] you a member of? [24| A: I was a member and a committee member of the 1251EIA, Electronic Industries Association. I was __________________________ [il occasionally called upon as a non-member to help and [21 assist EPRI. And I can't even remember what EPRI [3] stands for now. Electrical Producers Research mi Institute sounds right. Occasionally, I'd get a [S] call from one of the ANSI committees asking me for [4] any information I could send to them to help their [7] evaluations. But the ANSI type of membership would is] be more routinely handled from our research pi department where we would have somebody like a Dr. (101 Munch attend and give the proper level of technical [ii] content to that discussion. [12] Q: Can you recall any other technical or trade [131 associations? [i4i A: Those were the ones that were the major [isiones. I'm trying to remember, which was the -- [141 there was the famous Chicago convention, which we [i7j may get to, which reviewed the national PCB (isi electrical situation. And I'm not sure which of the ii9| .associations sponsored that. [201Q: Do you recall your membership in any other [211 committees or associations? [221 A: No. Those were the main those were the [231 main ones. [24] MR. DUFF: Off the record. [25] (Discussion off the record). Page 339 Hi (Deposition Recessed) [21 pi [4| [si fl PI 181 Pi 1101 [111 1121 nsi im nsi ni [171 [181 [19) [20! [211 (221 (23J [2<| (251 Page 340 m COMES NOW THE WITNESS, DAVID WOOD, and having [21 read the foregoing transcript of the deposition pi taken on the 10th day of November, 1995, [4i acknowledges by signature hereto that it is a true [si and accurate transcript of the testimony given on |4] the date hereinabove mentioned, pi pi (91 [ioj DAVID WOOD mi [121 Subscribed and sworn to me before this [131__________ day of_____________ , 1995. [i4i My Commission expires:__ ____ [151 [tl (171___________ Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Page 333 - Page 340 WATER PCB-SD0000024918 Deposition of DAVID WOOD NOVEMBER 10, 1995 [181 Notary Public [i9| iaoj pm [221 rg (23] 124] (251 ;Page 341 [11 State of Missouri [21SS. (3| City of St. Louis [4)1, Ronald A. Gore, a Notary Public in and for tsi the State of Missouri, duly commissioned, qualified [6] and authorized to administer oaths and to certify to pi depositions, do hereby certify that pursuant to [si Notice in the civil cause now pending and pi undetermined in the Commonwealth of Kentucky, Rowan not Circuit Court, Civil Branch, to be used in the trial [in of said cause in said court, 1 was attended at the [121 offices of Gore & Perry Reporting Company, 100 North [i3i Broadway, in the City of St. Louis, State of mi Missouri, by the aforesaid witness; and by theusi aforesaid attorneys; on the 10th day of November, [i6i 1995. [i7i The said witness, being of sound mind and being mi by me first carefully examined and duly cautioned [inland sworn to testify the truth, the whole truth, and [201 nothing but the truth in the case aforesaid, [211 thereupon testified as is shown in the foregoing [221 transcript, said testimony being by me reported in [231 shorthand and caused to be transcribed into (241 typewriting, and that the foregoing pages correctly psi set forth the testimony of the aforementioned Page 342 in witness, together with the questions propounded by izi counsel and remarks and objections of counsel pi thereto, and is in all respects a full, true, w correct and complete transcript of the questions (si propounded to and the answers given by said witness; [6] that signature of the deponent was not waived by m agreement of counsel, pi I further certify that 1 am not of counsel or [9] attorney for either of the parties to said suit, not [101 related to nor interested in any of the parties or mi their attorneys. [121 Witness my hand and notarial seal at St. Louis, [pi Missouri, this______ day of [i4i, 1995. [i5i My Commission expires June 20, 1998. [i6i [17] Notary Public in and for the [is] State of Missouri [i9] [201 [211 [221 [23] [241 [251 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY Page 340 - Page 342 Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 WATER PCB-SD0000024919 TENNESSEE GAS PIPELINE CO. vs MONSANTO COMPANY -0- 0.01 287:15; 002173 284:15;285:18; 009685 290:7; 016104 298:23; 028069 314:24; 055792 214:19; 055798 211:20; 055945 234:15; 056026 220:25; 056028 221:11 ;224:14;226:7; 056031 222:14; 056457 227:13; 056615 207:14; 057807 278:25; 058004 247:12; 058014 271:4; 058495 254:5; 058757 249:5; 058769 262:13; 073175 328:9; 074047 301:3; 074049 309:23 ;309:24; 074051 310:3 ;310:4; 074054 307:2; 074055 307:13; 080447 308:9; 085999 220:3; 086029 241:19; -11-" 100 341:12; 1069 222:17; 1070 222:17; 10th 340:3,341:15; 11th 247:17; 1242 230:3 ;230:5; 1254 331:16;331:17; 1260 331:15; 130 273:2;273:5;273:6; 273:12;275:15; 179 284:16; 17th 316:5;316:21:322:20; 18th 318:6; 190 273:2;273:5;273:5; 273:8;273:14;275:16; 1951 289:17; 1960s 234:1; 1965 291:18; 1966 203:8;204:12;205:7; 205:11;205:14;206:14; 209:4;228:6;255:15; 256:12;260:2;264:5; 265:10,269:5; 1967" 212:14;203:8;203:15 204:12;205:7;205:12 205:20;206:14;208:7 208:24;209:9 ;210:20 211:14;215:4;215:9; 215:20;215:21;216:21; 217:25;219:14;220:10; 220:11;220:15;223:2; 223:7;224:14;224:16; 224:19;225:15;226:20; 227:17;227:20;227:25; 228:4;230:5;231:16; 235:5 ;235:18;237:22 237:22;238:19 ;240:4 255:17;256:23 ;259:5 259:9;260:16;261:3; 264:5;265:10;269:5; 269:6;271:16;271:18; 1968 235:10;238:2;238:7; 238:23 ;239:12;240:4; 242:18 ;242:20;247:6; 247:17;248:15;248:18; 279:6;279:13 ;280:25; 283:9;286:11;289:4; 1969 249:14;249:18;254:10; 256:15;261:16;262:24; 265:19 ;266:1 ;266:4; 266:11,266:23 ;268:11; 269:17;269:18;270:8; 290:17;290:19;300:3; 300:4;300:7;300:10; 300:15; 1970s 234:1 ;235:15;335:17; 335:22; 1973 201:16;201:24; 1974 201:22;202:1 ;202:5; 202:22;235:22;236:7 236:15;241:4;241:14 266:19;300:18;315:8 315:11;316:8;316:22 317:6;317:13;320:4; 320:6;320:8;320:14; 320:25;321:23;322:16; 323:25;324:24;326:10; 334:23 ;335:15;337:21; 1975 Deposition of DAVID WOOD NOVEMBER 10, 1995 236:19;237:13;241:4; 301:1 ;301:9;301:16; 301:17;305:7;305:13; 305:20;306:6;306:7; 306:22;309:16;314:7; 320:14; 1976 308:19 ;321:1; 1977 228:6;246:16;321:2; 1979 337:22;336:14; 1995 245:2;247:4;291:14; 340:3 ;340:13 ;341:16; 342:14; 1998 342:15;241:16; 23rd 208:7;242:18; , 273 237:25; 277 212:6;213:1; 285 207:9;207:10;207:13; 208:3 ;211:1; 286 210:22;210:23 ;211:17; 212:17;212:25;213:2; 223:21 ;223:23 ;223:24; 224:6; 287 214:14;214:15;214:18; 218:1; 288 219:23 ;219:24;220:2; 289 220:20;220:21 ;220:24; 221:24;222:16;222:17; 222:21 ;222:23;222:25; v. 223:5;224:11; 290 222:9;222:10;222:14; 222:19;222:21;222:22; 223:1 ;223:4;223:7; 223:13;224:2; 291 227:8;227:9;227:12; 292 234:10;234:11 ;234:14; 293 247:7;247:8;247:11; 294 248:25;249:1;249:4; 254:19; 295 253:25;254:1 ;254:4; 296 262:8;262:9;262:12; 297 270:24;270:25;271:3; 298 278:20;278:21 ;278:24; 299 284:10;284:11;284:14; 29th 309:16; "1 3-B 322:14;323:19; 3002612 324:1 ;290:2;290:3; 290:6;295:5 ;295:22; 297:5; 301 298:18;298:19;298:22; 302 300:21;300:22;301:2; 304:5 ;304:12;309:17; 309:20;309:21;310:13; 310:16;310:21 ;310:23; 311:2;311:6; 303 308:4;308:5;308:8; 309:22;310:1;310:9; 310:12;310:14;310:18; 312:3 ;314;5; 304 314:19;314:20;314:23; 316:20;321:17; 305 323:20;323:21 ;323:24; 306 328:4;328:5;328:8; 30th 254:20;261:22; a 40s 277:20; 4th 261:24; C 50s 277:20; -7/- 7th 238:6; -O" 8/12/87 284:16; 8th 271:15; AA * ' A-c-t-a-c-h-e 212:13; able 229:6;230:13 ;234:8; 237:13;240:2;267:22; 267:25;311:23;315:10; 326:9;326:25;331:4; 332:14; abnormal 238:7;253:2; absence 276:21; absorbed 274:14;274:19;277:5; 261:10; absorption 278:9; abused 232:4;304:6; academic 276:18; accepted 311:7;311:12;311:13; accepting 303:12;294:19;303:17; 304:3;311:17; access 237:11; acclaim 316:11; accountable 238:17:326:25; accumulate 240:5 ;240:9;240:16; accumulating 257:9; accurately 244:14;255:4;205:15; 340:5; achieved 263:11; acidic 302:12; acknowledged 327:20; acknowledges 340:4; across 207:24;266:19;276:9; 287:20;289:4; Actachem 212:13;223:19;224:3; acted 279:23; acting 307:19; action 251:23 ;257:24;258:25; actively 253:5;226:2;273:20; 286:7; activities 238:16;253:3; activity 210:5;251:24;267:17; 278:12; Actually 210:25 ;222:21; actually 211:18;238:1 ;238:9; 250:4;253:19 ;262:2; 292:2;292:24;312:23; 315:21 ;255:21 ;256:17; 310:4; acute 286:8; added 212:11;217:7; additional 291:11 ;303:6 ;224:22; addressed 215;5;243:11 ;243:12; 243:20;247:15 ;249:14; 260:3 ;271:12;279:6; 308:19; addressing 259:20;327:24;297:22; 329:8;259:23;293:3; adequate 313:14; adhered 321:10; administer 341:6; adverse 232:23; advisedly 294:15;229:1 ;251:11; 267:18;267:2; advising 208:18; aeration 289:9; affixed 280:3; aforementioned Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 0.01 - aforementioned WATER PCB-SD0000024920 Deposition of DAVID WOOD NOVEMBER 10, 1995 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY 341:25; aforesaid 199:4;341:14;341:15; 341:20; afternoon 203:8; Again 207:21 ;238:7;243:25; 247:4;252:21;253:8; 261:5;276:16;282:18; 286:12;291:14;296:9; 311:18;331:19;333:13; against 217:10;207:2;224:13; 237:10;240:18;240:19; 241:6;241:13 ;246:14; 255:24;264:19;274:18; 276:7;280:8;282:17; 282:22;288:7;295:4; 314:10;317:19;325:18; 331:24;334:1;335:12; agencies 336:15; agenda 316:l4;333:l 1; 199:2; aging 301:24; agitation 257:5; ~ .." ago 200:1;212:22;213:3; 270:11;320:20; agree" 260:22; agreed 322:7; agreement 342:7;223:6;241:25; 260:16;288:25;318:17; 321:23;322:1; ahead 268:17; aimed 304:17;256:6; Airlines 335:1;335:2; air 283:25;287:16; alert 325:15; allowed 257:17;263:12;277:1; 318:15; allowing 327:9;282:18; alluded 297:4;312:3; alluding 218:9 ;275:14;295:23; 296:15; almost 228:13;270:4; along 230:11 ;252:12;330:15; already 211:18 ;228:7;238:19; 244:10;244:12;246:23; 258:7;295:17;304:3; 318:25; although 260:9;318:15; always 209;15;291:22; American 226:25;263:4;266:9; among 228:22;297:6; amounts 246:11 ;325:13 ;231:23; 288:23 ;325:9;336:13; amplified 256:19; analysis 213:6;213:7;213:13; 224:22; Analytical 215:3; analytical 206:20;206:22;211:12; 228:16;228:22;229:4; 233:14;233:21;233:22; 234:4;252:7;257:16; 259:24;260:11;283:8; 297:17; and/or 337:22; Anglia 245:17; animals 233:23 ;240:6;240:9; 275:21;330:12; announced 238:9; announcements 238:11 ;293:6;238:5;.......... Ansi 338:5;338:7; answered 260:25 ;268:4;270:16; 270:19; answering 275:17;277:2; antitrust 267:17; Anybody 288:25; anybody 200:8;200:11 ;222:5; 222:8;240:19;246:18; 252:3 ;265:14;267:2; 268:7;288:15; Anyone 306:18; anyone 200:23; anywhere 319:24; Aoac - 226:21,226:23; apologetically 270:4; apologize 211:17;276:17;317:15; apology 280:8; apparently 324:10; appearance 278:1;278:13; appeared 216:4;266:17; Appears 279:14; appears 222:22;242:1;242:3; 245:3 ;247:5;285:21; 291:8;294:21 ;307:12; 212:12;216:16;239:2; 241:22;294:1; applicational 259:12; applications 232:3;304:24;305:6; 305:21 ;305:21 ;306:1; 275:9 ;283:17;289:24; 327:23; apply 323:3;323:4; appointed 1 315:17;316:11; appointment 235:23 ;322:23; appraise 209:3; appreciated 257:3; appropriately 234:8;243:15;251:23; 260:3 ;302:15;312:11; 232:3;234:7;251:18; 258:25;260:14;297:20; approval 312:8; approved 307:18; approximately 253:21; April 262:23 ;268:11;269:18; arc'd 289:11;286:3;287:16;------ 288:20 ;289:8 ;289:10; areas 204:21 ;238:17;257:14; 278:16;319:9;210:5; 226:2;238:2;238:24; 239:2;239:8;239:9; 239:12,239:25 ;240:1; 240:23 ;249:25;250:8; 251:8;251:14;251:20; 252:14;252:23;253:4; 257:19;259:25 ;269:2; 269:8;271:23 ;272:4; 281:21 ;306:21 ;311:24; 312:7;313:10;319:6; 320:18; arising 304:20; arms 259:12;259:15;259:13; 259:14;259:15; Aroclor 230:3 ;230:4;231:23; 232:3 ;232:11;252:9; 255:7;273:12;273:14; 274:13;275:2;277:4; 288:19;331:15;331:16; Aroclors 242:17;277:16;290:16; 297:8;301:17; around . 217:15;272:18;272:19; 277:25;308:23 ;318:8; 318:10;319:22;332:13; arrived 313:2;315:16;320:7; article" ' 248:7;224:8;234:19; 266:13;288:21;288:22; 289:4; aside 213:2; askarels 289:25 ;286:2;286:15; 287:15;287:17; aspirin 270:5; assertions 255:6; assignment 235:19 ;238:14;238:21; 242:17; assist 338:2; associated 249:24;250:1 ;250:6; 257:18;305:24; Association 226:24;227:1;337:25; associations 336:17;336:24;337:16; 337:22;338:13 ;338:19; 338:21;252:24;337:1; 337:8 ;337:12; assume 200:15;228:1;232:6; assumption 275:24; asterisk 223:14; Atlanta 332:3; atmosphere 248:6; attached 215:22;228:12;280:18; 284:18;309:1 ;310:8;------310:13;310:18;329:12; attachment 294:25 ;295:5;307:4; 307:10;307:16;310:2; 310:7;310:23;280:21; attended 218:9;333:7;341:11; attending 330:25 ;333:2;333:5; 338:10; attention 203:6;211:2;212:6; 212:9;217:5;221:10; 223:11;224:11;274:6; 291:4;291:16;292:21; 293:2;293:12;297:21; 306:25 ;310:11 ;321:16; attorney/client 200:18; attorneys 341:15;342:11;342:9; attributed 330:12; August 266:23;286:11; authored 234:25 ;301:13; authorities 313:17;313:18; authorized 341:6;254:9;287:13; 287:19;315:3; available 271:25 ;276:11; average 325:12;331:13; aviation 335:1; avoidance 323:15; avoided 277:13; aware" 211:5 ;205:13;205:19; 209:16;209:22;209:23; 210:10;210:16;210:18; 210:19;216:2;217:14; 218:15;220:11;220:I5; 221:18;222:2;222:4; 224:14;224:16;224:18; 225:15 ;225:16 ;225:23; 225:24;226:5;226:10; 231:7 ;231:12;234:3; 235:5;235:10;235:12; 235:13;236:2;236:5; 240:4;240:8;240:11; 240:24;241:2;241:4; 245:22;246:5;248:9; 251:1;251:3;251:24; 252:11;252:16;266:13; 266:22;283:8;295:9; 304:22;305:4;305:11; 332:20;332:22;332:23; away 319:2;320:8; -B- B-e-n-i-g-n-u 285:23; background 206:5 ;237:6;237:10; 232:20;237:23 ;263:23; 269:2;276:24;277:11; 278:15;282:19;298:3; 299:9;302:7;312:8; 312:18 ;312:25 ;317:16; 318:24;328:19;328:21; bad 232:24;302:24; band 204:17; based 275:12;279:23;233:21; 303:4; basically 273:25;304:2; basis 205:6;258:22;316:17; basket 251:21; Bates 284:15 ;285:18 ;323:25; battle 233:14; Bayer 220:12;267:4;267:8; 267:13;267:19;267:25; 268:7; Bayer/prodelec 329:4; bearing 226:7; bears 207:13;211:19;214:18; 220:2;220:24;222:14; 227:12;234:14;241:18; 247:11;249:4;254:4; 262:12;271:3;278:24; 284:14;285:18;290:6; 298:23 ;301:2;308:8; 314:23 ;328:8;307:1; beauty 283:24; became 205:19;206:18;206:19; 209:22;210:16;210:18; 235:13;236:2;236:5; 238:5;241:4;241:7; 252:15;306:23; becomes 313:25 ;209:23;210:19; 215:16;232:17;235:12; 241:2;252:17;266:13; 1 | 1 . 1 i | .1 ! . Ji ' 1 Gore & Perry Reporting Co. St. Louis, Missouri aforementioned - becomes (314) 241-6750 621-4790 WATER PCB-SD0000024921 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY 291:7;300:16;325:15; 332:20; becoming 234:3;325:19;325:20; bed 313:11 ;313: L3;319:22; began 259:22;266:23; beginning 202:1 ;202:5;202:21; 238:6;238:19;240:14; 240:20;256:23;259:5; 259:9;259:25;260:16; 261:2;325:6;259:1; 260:22;260:24;261:2; 261:7; begun 259:21; behalf 255:7; behind 259:24; Belgian 272:2; Belgium 249:15; believed 245:4;247:1 ;203:3; 207:18 ;207:22;207:23; 215:10;217:23 ;226:24; 229:20;230:2;230:6; 230:14;230:16;235:13; 244:3 ;244:15;245:24; 270:10;282:15;284:20; 285:10 ;286:13 ;299:7; 307:8;309:18;309:22; 315:21;315:23 ;321:14; 324:4;324:11;334:22; bells 334:9;249:22; benefit 260:5; Benignus 237:3 ;237:17;285:22; benzofurans 329:16; besides 200:24;265:9; best 229:6;299:14;319:7; 322:2; better 229:5;234:4;241:7; 243:14 ;297:22;299:9; 311:23;321:4;321:11; 323:15;327:23; big 335:20;337:19; Bill 328:13 ;328:19;328:20; 330:9; bill 328:23; bioaccumulate 240:25; bioaccumulation 240:14;241:5;241:9; 241:13; biocontamination 298:1; biodegradation 319:1; biodegrade 319:4; biological 213:7;252:8; biphenyls 213:7;213:25;214:6; 221:16;225:3;225:6; 226:13;226:16;230:21; 231:5;233:9;236:11; 253:5;256:4;256:11; 258:6;258:8;262:24; 267:8 ;274:3 ;276:2; 277:21 ;287:5 ;288:12; 288:14;292:14;301:25; 326:12;207:3;229:21; 230:23;231:20;239:4; 244:24;248:7;250:10; 250:13 ;251:5 ;255:22; 256:18 ;275:12;275:17; 278:15 ;283:12;288:9; 302:20;307:22;329:20; 329:22;329:24;330:14; 330:15;330:21 ;330:24; Bir 284:15;285:18;324:14; birds 214:7;225:7;330:11; 247:2; Birmingham 285:7;285:11;324:6; black 286:21 ;286:24;287:3; 287:10;288:1;288:5; Bloomington 324:5;324:9;324:12; 325:1; blur 223:10; board 238:9; Bob 205:25;263:12;308:20; Bob's 263:21; Bodin 320:17; body 313:4; bolster 312:13,313:15; book" 286:22; booklet 287:7;286:25 ;287:3; 287:10;288:2;288:5; boom 314:2; Both 219:19; both 199:15;213:15;222:21; 224:23 ;231:21 ;253:11; 323:18; bottom 217:6;307:12;319:20; 320:22;321:9;321:10; 324:1;324:8; box 314:16; Boy 245:20;336:12; Branch 341:10; breached 284:5;284:9; breadth 239:23; breaking 266:6; breakthrough 283:18;305:9;332:6; 336:1 ;336:19; briefed 236:24; briefing 333:16;333:21 ;333:23; briefly 328:23 ;333:9; bring 250:12;251:4;299:12; 326:16; Britain 208:22;209:1 ;248:2; 324:25; Britian 337:3; British 208:18 ;337:12; broader 283:5; Broadway 341:13; brochures 277:12;287:4; broke 265:18; Brotherhood 246:10; brought 259:23; Brussels 201:21 ;204:24;205:2 ; 205:5 ;219:9 ;249:14; 262:22,263:9;266:8; 269:20;271:14;272:3; 279:7 ;282:3 ;285:24; building 208:6;259:25; built 335:4; bullet 318:19; burden 303:7; busily 243:6; businesses 229:15;267:13;202:14; 202:16;229:13;229:14; 229:17;242:23;251:8; 269:8;297:22;302:22; 304:18;306:22;334:19; buttoned 327:3;327:2; buy 246:19;261:12; -c- cable 277:22; cabling 277:23; ritlloH 202:12;220:18;246:10; 246:11 ;247:14;247:15; 248:20;252:16;300:13; 332:1 ;333:9;333:20; 338:1; calls 204:8;253:6;253:11; 324:25^338:5; came 263:22;300:18;322:8; campaign 258:1; Canadian Deposition of DAVID WOOD NOVEMBER 10, 1995 307:18; capability 241:5;331:20; capable 229:2;269:6;283:25; capacitor 247:22;248:3 ;323:5; 323:8; capacity 216:23; capture 210:15;211:6,213:15; 224:23 ;291:6; carbonless 230:9; career 216:20;235:22; 1 carefully 341:18,313:14; cargo 313:16; carried 220:17;225:17;225:24; 251:18;289:7;319:24; 331:7; carrier's 313:3;313:7;303:2; carrying 313:8;234:7; carton 284:5; cases 237:6;251:17;259:17; 259:17;321:6;199:4; 200:9;200:25;284:24; 285:11;321:12;321:12; 324:3 ;324:6;324:12; 341:20; Cash 229:8; casual 240:1; catalog 246:16; categorization 206:23; caused 341:23; cautioned 341:18-^26:13; Cdc 332:3; ceased 311:17;326:15; cells 325:7;326:3;325:11; 325:16; Center 332:3; centigrade 287:17; Centre 255:15; Certainty 267:13 ;282:20;295:7; 317:25; certainly 203:16;216:14;227:6; 228:13;232:3;235:21; 237:5;256:11;260:10; 267:23;318:9;332:23; 333:18;335:24;209:13 225:19;231:23;232:20 232:24;240:25;256:24 267:10;273:7;277:22; 295:16;297:9;304:5; 314:13;319:23,325:7; 332:15; certify 341:6;341:7;342:8; cetera 264:9; chain 215:24;217:9; Chambers 199:18;200:14;200:20; 200:24;202:25 ;203:4; 203:23 ;209:2;212:18; 214:11;216:1;218:14; 218:18;218:22;218:25; 221:20;221:25;223:22; 225:10;230:12;231:6; 239:15 ;239:17;240:10; 248:8;251:6;257:11; 258:18;259:6;260:7; 260:19;261:4;261:18; 261:20;263:20;264:14; 265:21;266:2;268:3; 268:14;268:16;269:10; 270:10;270:15;270:18; 273:23;277:9;282:14; 284:25 ;285:4;285:9; 285:12;291:13 ;293:21; 295:7;295:15;296:19; 299:5;299:8;299:11; 299:15 ;305:8 ;305:11; 305:18;316:1 ;324:2; 324:7;324:13;326:8; 331:3 ;335:18;335:23; changed 237:23,251:11; changes 202:18;235:22;238:5; 242:16;251:7; changing 240:23 ;304:10; characteristics 273:8; characterization 299:6;299:17; chart 311:25 ;312:2;312:5; 314:4; check 327:6; Chemical 220:18; chemically 273:18,273:19; Chemicals 208:5;290:14; chemicals 202:11;23 8:2;23 9:12; 263:16;273:24;275:20; 281:13;282:3;282:8; 282:24;206:24;234:2; 239:25;240:19,240:22; 263:6 ;273:6 ;273:9; 280:1 ;280:9;280:14; 280:15;283:25;323:4; 329:23; Chemist 208:14;209:17;210:4; 210:11;221:8;294:17; 296:7; Chemistry 215:3; chemistry 260:10;281:19;281:24; 329:15; Chemists 226:25 ;227:1; Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 becomes - Chemists WATER PCB-SD0000024922 Deposition of DAVID WOOD NOVEMBER 10, 1995 Chicago 338:16; China 335:5; chips 279:11; Chlorinated 288:8; chlorinated 207:3;215:24:216:6; 217:9;217:20;221:15; 229:21 ;229:21 ;230:21; 230:23 ;231:20;231:20; 236:10;239:4;248:7; 250:10;250:13 ;251:5; 253:5 ;255:22;256:4; 256:11;256:17;258:6; 258:8 ;264:8;267:7; 274:3 ;277:21;277:22; 278:14;278:14;283:12; 287:5 ;288:11;288:14; 300:2;301:24;302:20; 307:22;326:12;329:2; 329:14;329:24;330:10; 330:15;330:21;330:23; 331:8;331:9;331:12; 332:4;335:7;335:10; 329:21;329:21; chlorination. ................. 214:2;225:5; chlorine-containi ng 290:24;291:12; chlorines 331:13; choosing 298:13; chords 334:11; chose 275:19;275:22;293:9; chromatograms 210:14;215:22;217:7; 244:7;291:9; chromatography 213:15;291:3;291:6; 213:23 ;260:6;291:25; 319:15; chromograph-mass 225:1; Circuit 341:10; circulate 272:19;316:12; citizen 272:2; City 341:3,341:13; city 246:11; Civil 341:10; civil 341:8; claimed 232:23; claiming 226:18;210:16;224:10; 233:2;262:21;287:11; 288:11;326:22; clarification 222:24;259:2;259:4; clarify 253:10; clarity 319:5; Clark 288:12; clay 321:9;321:10; cleaned 303:6; cleanup 313:24;313:25 ;313:11; 313:11; cleared 289:19; clearly 206:9;207:16;211:9; 218:19;218:22;218:24; 219:22 ;222:25 ;223:4; 233:4;261:1 ;282:15; 285:17;311:4; clipped 223:5; clorinated-containing 224:21; clorine-containing 213:17; closed 283:21;283:23 ;284:3; 284:3;284:4;284:7; 284:8;326:24; closely 327:3;244:6;276:12; ..... 279:17;310:8; cloud 264:21; Cocl 286:6; coffee 269:24; coil 272:18; Coleman 247:15;247:20;247:21; 248:4;248:10;248:20; 285:21; Colin 247:14;247:20;247:21; 248:4;248:10;248:20; 289:2; colleagues 236:20;237:2;264:19; collection 326:3; collective 265:11;313:10;325:9; coloring 230:7; columns 286:18;286:21;319:14; combinations 277:21 ;231:21 ;277:25; combined 213:23 ;224:25;260:5; 291:25; comfortable 299:23; coming 281:22;289:4;296:25; 299:17;330:19; comments 304:8;256:20;277:11; 316:14;328:17; commerce 307:19; commercially 331:10;226:16;239:3; 244:8;259:15;267:14; 297:19; Commission 340:14;342:15; commissioned 341:5; commissioning 335:4;221:4;221:7; committees 336:4;337:14;337:15; 337:17;338:5;338:21; 315:9;315:15;316:6; 316:11;316:13;317:2; 320:11 ;322:7;322:8; 322:21 ;322:21;332:9; 332:10;332:11;332:12; 332:18;332:21 ;333:1; 333:6;333:10;333:15; 333:16;333:22;333:24; 337:19;337:24; Commonwealth 341:9; common 313:3 ;313:7; communicated 226:1;243:25; communicating 245:4; communications 228:8;240:12;204:4; 204:6;205:21;210:3; 244:2;253:9; community 258:16;258:21;258:24; companies 231:10;231:13;246:9; 246:13; Company 215:6;288:10;341:12; company 230:22;246:10;280:15; 300:13; compatable 278:2; complete 246:15;293:8;293:9; 294:23 ;298:12;342:4; complex 303:22;327:21; compounds 210:13;211:11;213:17; 213:22;213:25;224:16; 224:21 ;224:25;225:2; 277:22;332:5; concentrations 289:2; concerned 268:12;301:22;321:8; concerning 290:24;293:7;300:6; 315:10; concerns 304:5 ;268:25;269:8; 318:21; conclusions 293:4;296:24;292:19; 296:25;322:8; concrete 313:10; conditions 289:8;289:10;289:12; 289:12;289:22;311:7; conducted 219:20; confirmed 243:23 ;294:6;294:15; confirming 233:22;244:13; confirms TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY 244:5;224:1 ;245:3; conflict 256:9 ;276:12; confrontational 256:3; confusing 219:22;231:19; conifers 214:8;225:8; connection 212:23;224:9;274:12; conscientious 261:25; conscious 230:1; consequences 232:5;232:10;234:8; considerable 297:16; consideration 254:23; considering 275:11 ;289:24;234:8; 241:10;303:12; constructed 301:21; consultation 200:16; consulting .... .... 266:24; contacted 218:3 ;251:12; contacts 264:4;265:6;269:4; 235:24;263:8;263:12; 265:1 ;265:2;267:15; 272:24;274:14;277:5; 277:13;278:6;283:7; 332:25 ;333:2; contained 224:2;226:7;236:10; 236:21 ;274:2;276:1; 287:10;305:22;311:14; container 312:14; containing 268:13 ;287:5 ;301:24; 305:7,307:21 ^311:8; contains 210:13;223:14;287:14; 273:12;273:14;273:16; 274:1;312:24;314:1; 331:2;335:7 ;335:10; contaminant 329:22;330:22; contaminated 302:7^29:20; contamination 247:1;280:19;280:24; 281:25;283:12; content 224:9;322:22;325:11; 330:13;331:2;331:9; 338:11; context 217:16;238:7;258:13; 288:8;298:15; continued 205:5;238:22;239:12; 320:13;307:19;326:19; 327:1; continuing 307:20;326:11; contractual 327:12; contradiction 287:24;288:1;289:5; Control 332:3; controlled 325:20; controlling 322:11 ;322:17; controls 323:1; convention 338:16; conversations 203:10;203:13;206:13; 250:23;269:21;300:1; 300:9;204:3;219:17; 270:6; cooking 279:9;280:19;280:24; 281:5 ;281:12;281:25; cooperate 313:22; copied 230:l8;234:23;242:15; 262:23 ;263:1; copies 249:15;279:7;285:24; 308:20; copyees 271:16;301:12;328:15; copying 230:9;208:8;211:19; 213:9;215:8;215:14; 215:16;215:19;221:17; 222:15;222:22;222:25; 223:5 ;242:3 ;242:4; 242:9 ;247:16;255:14; 279:12;290:18;309:2; 328:15;329:12; corner 223:3 ;246:19;284:7; corporate 267:6;332:9;332:10; 332:11;332:15;332:17; 332:21 ;333:1 ;333:5; 333:10;333:14;333:16; 333:21;333:24; corporation 332:13;334:15; corrected 203:5;293:25; correctly 331:23;341:24; corresponded 205:8; correspondence 215:15,243:11;243:12; 244:22;309:19; corresponding 291:10;205:6;205:10; corroded 303:1; Couldn't 235:6; couldn't 209:11;225:21; coulometric 213:16; counsel 200:16;342:2;342:2; 342:7;342:8; counterpart 204:13;204:23;204:23; countries 257:5 ;318:10;326:18; country 246:4;246:7;246:13; Chicago - country Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 WATER PCB-SD0000024923 TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY 320:3 ;320:10; couple 302:11;313:15; courses 257:24;320:23 ;253:2; Court 341:10; courtesy 291:23,341:11; covered 317:21; covers 286:1 ;242:10;285:2; 318:21; cracked 313:5; cracks 284:6; create 302:3 ;303:6; creation 260:2; crisps 279:10; crossover 331:17; cube 284:5; culture 337:20; Cumming 202:1;202:6;301:10; 306:14;306:20;308:20; 324:24;333:17; cup 269:23; -currently 330:16; curriculum 235:18;237:24;239:23; 263:21;282:19; customers 231:4;234:2;245:25; 246:5;301:23;302:6; 302:21 ;304:23 ;305:5; 307:18;307:24;308:2; 308:22;309:1;309:3; 309:12;310:24;311:3; 314:6;314:9 ;314:11; 326:13 ;327:9;327:12; 327:16;336:5;228:17; 229:9;229:11 ;246:3; 246:17;302:5;313:18; 322:11 ;322; 17;323:7; 327:19;328:2; -D- daily 232:9;257:21;263:12; damage 312:15; dangers 272:15; data 232:1;261:10; dated 208:7;215:4;242:i8; 247:16;249:14;261:15; 262:23 ;269:18;271:15; 279:5;284:16;290:16; 301:8;308:18;315:7; 323:25;209:20;210:17; 222:24;223:2;223:9; 235:16;252:21;266:15; 268:6;268:8;340:6; Dave 283:7; David 199:1 ;265:11 ;265:13; 271:16;279:6;301:8; 340:1;340:10; day-to-day 253:3;336:3;340:3; 340:13 ;341; 15 ;342:13; dealing 229:2;292:25 ;297:18; dealt 229:2;337:10;243:18; debate 25 8:5 ;258:13 ;258:16; 258:20; December 228:6;235:9;238:18; 240:3 ;240:3;253:23; 260:2;265:9; decided 302:13 ;316:13 ;260:13; 302:17; decision 322:5;322:6; decommissioning 336:9; decomposed 286:2; decomposition 286:15;287:14; decrease 215:25;217:10; deeply 243:13; definition 316:25;317:3; degradation 284:1; degrees 287:17;214:1;225:4; 260:9; deliberations 315:18;316:10; delivering . 281:4;281:9 ;272:23; demonstrated 215:23; demonstrates 217:8; Denton-roberts 279:21; departmental 216:11;216:15; departments 237:10;202:11;204:18; 215:6;216:24;250:2; 250:4;262:22;338:9; Depending 305:13; deponent 342:6; deposed 201:6;220:8; deposes 199:4; depositions 200:3 ;341:7;199:15; 200:24;201:2;201:9; 207:20;212:1 ;249:9; 254:13;284:22;308:14; 339:1 ;340:2; depot 214:8;225:8; described 216:5 ;216:13;216:23; 239:22;256:5;256:13; 295:5;295:18;315:14; description 211:9; designated 230:3 ;276:4;276:6; designations 275:7; designed 283:23 ;284:4;326:2; desk 239:2;266:19; destroying 301:20; detailed 295:19;303:23;323:19; 236:4;244:12;254:16; 262:6;264:11;269:19; 270:7;304:16; detected 213:18;224:21; detectible 283:19; detecting 327:5; detection 206:23;211:11;291:7; 331:20; detectors 210:15;319:10;211:7; 211:14;213:16;213:16; 224:24;223:9;281:14; 281:18;281:23; determined 261:16; determining 264:8;332:15; developed 230:8;258:10;327:18; developing 309:19; development 206:20;288:12;332:9; 281:17;318:14;327:6; device 292:4;292:12; dialogue 261:8; dibenzofurans 329:3 ;329:14;330:10; dictated 297:10; dictatorships 232:21; dielectrics 203:2;239:1;239:8; 239:9;242:23;243:8; 246:6;251:19 ;267:7; 288:15;304:18;304:25; 305:13,305:24;306:23; 307:22;323:10;326:16; 238:23 ;247:22;248:3; 267:10;288:9;288:16; 301:23 ;301:24;302:19; 302:21 ;303:14;304:13; 304:20,304:21 ;305:6; 306:6;306:12;307:18; 307:21 ;307:24;314:9; 315:15;316:18;326:12; 328:2;336:5;336:23; diet" 297:9; differed 306:8;306:8; differences 275:20;273:4; differentiation Deposition of DAVID WOOD NOVEMBER 10, 1995 319:3 ;217:1;235:19; 273:9 ;273:9 ;273:10; 273:18 ;281:21 ;284:24; 289:23 ;289:24;311:5; 318:10;319:3;319:4; 319:5 ;319:13;319:16; 329:19;330:5;332:13; difficult 205:24;209:3 ;215:15; 259:21;313:25; digest 243:16; digging 319:21; diligently 226:17; Direct 333:2; directed 301:9;323:9; Directing 211:1;212:9;224:11; 291:16;293:12;321:16; directing 223:11;228:25 ;310:11; directionally 316:17;256:7;291:20; directly 262:3; director 202:14;202:17;202:20; 212:5;221:10;274:6; 291:3 ;292:21 ;293:2; 306:25; disbelieve 280:20; discontinued 306:24; discourse 258:24;260:17; discourtesy 264:2; discovered 323:12; discovery 299:9; discussed 217:16;317:7;317:12; 320:12;322:12;322:16; discussing 269:16;270:12;316:24; 317:5; discussions 200:18;200:23 ;300:5; 336:6;336:8;336:11; 201:23;204:8;209:24; 212:4 ;218:6;257:15; 258:23 ;259:18;270:21; 298:17;300:20;318:14; 332:7^35:2^38:11; 338:25 ;201:2;242:6; 252:18;252:20;270:2; 315:19;322:9;325:6; 334:25; Disease 332:3; dispersion 240:22; disposal 248:14;306:2; dispute 299:15; disrespectful 209:10; distinguished 273:19; distorted 257:21; distributing 315:8; distribution 302:10;326:17;337:2; 337:5; disturbed 289:2;289:4; disturbing 287:20; divided 321:25; divisions 217:2;266:23; divorced 269:2;269:8; divulge 200:17; dock 312:7; Doctor 276:19; doctorate 280:10; Doctors 295:9 ;295:10; doctors 277:1 ;250:5;276:20; document's 235:13; documents 199:21 ;199:23;207:22; 253:9;254:15;259:10; 264:20;266:18;285:1; 285:5 ;299:16;299:17; 303:20;207:12;207:15; 207:19;207:23 ;208:1; 211:16;211:19;211:21; 211:23 ;211:25;213:5; 214:12;214:13;214:17; 214:21 ;214:23 ;214:25; 215:17;215:18;220:1; 220:4;220:6;220:7; 220:7;220:9;220:23; 221:1 ;221:2;221:11; 222:12;224:12;225:13; 227:11;227:15;228:3; 234:13 ;234:17;234:19; 235:3 ;235:5 ;235:10; 235:12;235:22;237:25; 241:15,241:18;241:20; 241:23 ;241:24;241:25; 242:13;242:19;243:17; 244:4;246:22;246:25; 247:10;247:13 ;249:3; 249:6;249:8;249:11; 249:17;254:3;254:6; 254:8;254:9;254:12; 258:23;262:11;262:14; 262:16;262:18;270:24; 271:2;271:6;271:8; 271:17;278:23 ;279:2; 279:12;284:10;284:13; 284:21;285:10;285:15; 285:17;285:20;286:10; 286:18;290:1;290:5; 290:8;290:12;290:13; 291:2;291:5;291:18; 293:9;293:13;294:2; 295:8;295:13;295:18; 295:24;296:13;297:13; 298:21 ;299:1 ;299:3; 299:20;299:24;300:24; 301:1;301:4;301:6; 301:13;303:20;307:1; Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 country - documents WATER PCB-SD0000024924 Deposition of DAVID WOOD NOVEMBER 10, 1995 307:5 ;307:7 ;307:16; 308:7;308:11,308:13; 308:16;309:23 ;314:19; 314:22;315:1;315:3; 315:5;315:13;315:24; 316:20;317:18;322:15; 323:20;323:23;323:24; 324:11;324:14;324:19; 324:21 ;328:7;328:11; done 233:22;256:1 ;256:8; 258:9;262:6;309:6; 333:17; door 278:13; double 238:15; doubt 292:19;293:5 ;293:5; 297:7; Doug 276:21076:24076:25; 291:22;294:14;296:10; Doug's 293:4; down 232:22;280:9;289:8; 303:3 ;305:9;324:8; 336:2;336:19; drafted 307:7;307:9;307:15; 224:6;224:6;310:17; dragged 269:2; drawn 226:13;296:22; draws 297:21 ;217:5; dredge 320:22;321:4; dredging 319:20;321:13; drillers 335:3; drilling 335:4;335:5; drink 232:19; driving 322:5; drop 284:5; drums 302:16;303:2;312:10; 312:12;312:13;312:15; 312:17;313:4;313:5; 312:16; due 292:14;330:13; Duff 199:8 ;200:17;200:21; 203:3;203:6;204:1; 207:12;209:8;210:25; 212:3 ;212:5;212:19; 214:13;214:17;219:1; 220:1;220:23;221:24; 222:2;222:12;223:25; 225:14;227:11 ;231:12; 234:13;247:10;248:23; 248:25;249:3 ;254:3; 259:8;260:24;262:11; 263:24;265:23 ;268:6; 268:20;269:16;270:17; 270:20;270:23;271:2; 278:23;284:13 ;285:2; 285:8 ;285:10;285:13; 290:5 ;291:16;293:25; 295:9;298:6;298:16; 298:18;298:21;299:7; 299:10 ;299:12 ;299:20; 300:19;300:21 ;300:24; 305:4;305:10;308:7; 314:22;316:9 ;323 ;23; 324:4;324:8;324:18; 328:7 ;331:11;332:6; 332:8 ;335:19;338:24; duly 199:2;341:5;341:18; duplicate 242:1; During 337:21; during 199:21;203:10;203:14; 203:19 ;203:21 ;228:6; 253:3; Dutch 279:20; duty 238:15; -E- each 269:24;273:18;322:20; eagle's ............. 255:22; eagles 256:18064:9; earlier 223:18;224:6;230:14; 256:5;260:8;267:9; 277:18;278:10;283:4; 285:1;305:25;319:9; 320:12;324:14; early 264:5;269:5; earth 280:9; easier 242:7;242:8; easily 289:2;303:5; Easley 308:21; East 245:17; eating 240:17; editorial 310:5; editors 258:1; educated 322:4;237:1; educating 236:11;236:14;236:18; educational 206:5; effective 322:9; effects 232:23;258:7;330:11; 231:4;233:3;233:25; efficient 272:9; effluents 327:6;321:20;321:24; 325:1;325:3;325:18; 326:4;327:7;327:15; 327:19; efforts 259:24;266:22;297:16; 327:8; efluents 325:20;325:22; Egan 221:6; Eia 337:25; eight 293:18;294:6;294:20; Either 204:5; either 251:11;263:5;293:8; 295:11 ;295:25 ;342:9; Electric 288:10;288:13;336:6; Electrical 338:3; electrical 267:11;287:7;301:19; 305:21 ;307:21 ;323:10; 326:17;337:2;337:4; 337:6;337:9;338:18; 286:3 ;287:16;288:19; Electronic 337:25; electron 210:15;211:6;213:15; 224:23 ;291:6;319:10;----element 275:11; elevated 272:14;278:7;281:16; 283:25; eliminate 283:2;330:18; Elmer 249:22;262:20;264:2; else 201:8;201:11;201:13; 210:7;243:15;243:16; 265:14;267:2;278:3; 306:10,306:18; Elt 335:6;335:7; eminence 263:11; emotional 330:17; emphasized 257:20; employed 336:18; employee 271:13; encountered 283:3; end 203:15;205:14;235:18; 237:21 ;237:22;269:5; 291:18; enforcing 306:10; engaged 253:5;258:15;258:23; 311:21; engaging 243:6;258:12; Engineering 220:18; engineering 280:14;323:18; engineers 280:15;280:1;280:9; England 245:9;246:19;279:23; TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY 285:22;290:14;295:17; English 209:4;219:17;219:20; enough 211:8;218:19;219:7; 255:25;269:20;322:4; ensure 327:8; entered 244:1 l;25l :8;260:17; entirely 289:23; entitled 262:24; entity 273:9;329:23; entry 281:18; environment" 262:25; environmental 303:7;312:21 ;316:25; 317:4;317:12030:24; 231:5 034:6057:10; 318:8;318:23 ;318:24; 318:25 ;327:10;327:14; Epa 321:12;336:5 ;336:8; 336:11; -........-......... Epri 338:2;338:2; equally 230:16;293:5;301:25; 323:4;325:14;275:21; 275:21; equipments 306:2;311:21 ;211:10; 282:6;283:8;301:19; 301:24;304:20;304:21; 307:21 ;311:8;323:11; 326:24;336:8;337:10; equivalent 283:16; escaped 305:15;327:9; especially 214:6;225:7; essentially 283:23;306:23;318:7; 322:24;323:2;326:14; established 291:7;306:1021:3; establishing 303:9; establishments 292:22;293:13;293:19; 293:22;294:1 ;294:6; 294:16;295:11;295:21; 296:2;296:4;219:1; Eugene 216:17;216:25; Europe 204:17;235:20;263:5; 263:6;263:16;263:17; 263:18;26302064:4; 265:4;265:12;272:8; 276:11 ;276:13 ;283:6; 320:8;332:23;336:22; 337:1037:18037:19; European 251:15;253:18;263:1; 264:18;276:7;279:25; 281:2;286:12029:14; evaluate 228:17; evaluations 338:7;206:20;209:5228:23; ' ' Even 239:11; eventually 321:12;295:190530- 242:16058:2;261:24; 267:6079:17-289:1; 300:4-038:2; ' everybody's 289:19004:10014:16; Everything 232:14098:8; everything 232:8 032:13 043:19; 319:18026:25; evidence 292:18097:25098:1; evolved 205:22040:14; evolving 236:23; exactly 206:19 007:2026:18; 228:11-056:6062:6; 263:13 009:8011:10; 326:1; Examination 199:7; -------- ------- examined 214:5015:13025:6; 341:18; examining 209:18010:6; example 302:8020:20037:3; excellent 280:14; exception 333:19; exchanges 219:21; Excuse 202:4; excuse 251:2079:20; executives 332:13063:17032:12; exemplified 310:4; exercise 314:13; exhausting 264:11; Exhibit ~ 207:9007:10007:13; 208:301002010:23; 211:1011:17012:6; 212:17012:25013:2; 214:14014:15014:18; 218:1019:23019:24; 220:2020:20020:21; - 220:24021:24022:9; 222:10022:14022:16; 222:17022:19022:22; 222:23022:25023:1; 223:4023:5023:7; 223:12023:21023:23; 224:2024:6-024:11; 227:8027:9027:12; 234:10034:11034:14; 237:25 041:16047:7; 247:8047:11048:25; 249:1049:4053:25; 254:1054:4054:19; 262:8062:9062:12; [ > | j J , j -j ' , ; 1 documents - Exhibit Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 WATER PCB-SD0000024925 TENNESSEE GAS PIPELINE CO. vs MONSANTO COMPANY 270:24;270:25;271:3; 278:19 ;278:21 ;278:24; 284:10;284:11 ;284:14; 284:20;290:2;290:3; 290:6;290:9;295:22; 297:5 ;298:18;298:19; 298:22:300:21 ;300:22; 301:2;304:4;304:12; 308:4;308:5;308:8; 309:17;309:20;309:21; 309:22;310:1 ;310:8; 310:12;310:13 ;310:13; 310:15;310:18;310:20; 310:23,311:2;312:3; 3 14:5 ;314:19 ;314:20; 314:23 ;316:20;321:17; 323:20;323:21 ;323:24; 328:4;328:5;328:8; exhibits 212:24;230:14;285:6; 213;3;223:18;230:16; 230:17;284:16;284:22; 324:4;324:10;324:15; existed 217:15; existence 235:14; exists 208:15;258:9; exiting 305:25; expatriot 263:4; expense 313:22; experience 216:5 ;231:20;257:22; expertise 257:19;260:10;320:15; expires 340:14;342:15; explain 275:5; exploring 246:21; expose 283:24; exposing 304:5; expressed 203:22;281:6;318:5; 204:1; extended 294:5; extending 313:24;304:7; extension 204:23; extensive 337:1; extent 204:18; extracts 244:8; extraneous 330:24;211:19; extremely 286:6;286:8;289:12; -F- face 271:21; facilitate 253:13; facilities 245:22;323:9; facility 245:19; fact 209:25 ;210:2;210:19; 231:25;232:6;233:5; 244:19;255:22;256:5; 256:17;257:15;261:22; 261:23 ;276:19;277:1; 277:3 ;278:11 ;279:20; 283:2;284:21 ;292:2; 307:12;309:15;310:4; failed 331:23; failing 275:3;246:14; faint 334:11; fairly 236:2;303:22;336:13; faith ' 286:12; Fallon 300:2;300:4; familiarity 332:8; familiarize 214:20;220:4;234:16; 238:19;271:5;285:14; 317:17;208:13 ;208:16; 211:8;212:21;215:17; 216:19;217:3;221:6; 226:20;227:4;227:5; 241:20;245:7;245:10; 245:11;246:23;252:7; 266:10;286:24;300:13; 300:16;301:4;306:4; 324:18;329:15; famous 338:16; fancy 269:10; far 321:8; fast 319:1; fat" 225:9;214:8; fauna 213:14; February 201:22;208:7;210:20; 211:14;215:4;215:9; 215:20;215:21;216:21; 227:20;227:24;242:18; 242:20;247:6;254:9; 255; 17;256:15;261:15; 261:24;265:18;265:25; 266:4;266:11 ;266:14; 270:8;308:18 ;320:8; federal 335:22; feeling 203:25 ;204:2;299:23; 329:25; felt 236:22;259:19;281:3; 318:11,332:1; few 253:18;269:25; fifty 302:18; fights 321:3 ;233:14; files 236:21 ;237:15;251:12; 299:4;299:18;312:21; finally 224:8;224:5;233:17; 310:19; Findet 300:14;300:17; findings 203:22;205:11;205:13; 217:17;220:17;239:14; 258:17;260:5;205:24; 226:15 ;256:5 ;25 8:3; 292:13 ;209:3 ;212:11; 215:15;226:18;242:7; 242:8;256:1;256:6; 262:5;288:16;288:20; 289:10;317:10; fine 238:2;239:11;239:20; 239:24;251:8;251:14; 252:14;252:15;252:23; 253:4;269:15;282:3; 282:8;282:21;282:24; 283:2;332:1; finished 213:1 ;288:17; Fire 285:7;285:11;324:6; fire-resistant 274:4;275:8;275:10; 276:1 ;277:23;272:15; firmly 321:9; first 199:2 ;201:15;201:23; 201:23;207:4;207:7; 213:20;217:6;223:13; 228:19;233:14;234:23; 241:12;242:4;242:5; 242:6;253:21 ;254:24; 255:1 ;255:5;265:18; 282:13;286:17;287:12; 297:4;300:16;310:1; 313:16;314:1;332:20; 332:25 ;341:18; Fishers 294:18;296:7; fish 214:7;225:7;240:17; 240:17;264:8;297:8; fits 319:17; five 203:17; flawless 209:15; floor 313:6;313:12;313:13; fluid's 275:9; fluidly 202:19; fluids 202:12;202:15;203:3; 238:24;272:5;273:18; 275:6;275:7;275:8; 275:17;275:19;275:24; 275:25;277:7;277:25; 278:1;278:5;278:6; 281:5;281:24;282:5; 283:5 ;283:15;283:16; 283:20;284:2;287:5; 300:11;302:1;302:6; 302:6;302:19;302:25; 303:14;303:17;304:13; 304:14;304:24;305:6; 305:7;306:6;306:6; 306:12;306:13;306:16; Deposition of DAVID WOOD NOVEMBER 10, 1995 308:23 ;309:4;312:25; 335:1 ;336:23;272:8; 272:19 ;272:21 ;275:8; 275:12;276:8;281:10; 281:15;281:19;281:20; 289:6,302:11;302:14; 302:14;3 02:15;302:17; 312:8;313:6;313:23; 323:16;327:1; focusing 203:7:336:13; folders 236:21;299:13;299:21; follow-up 218:16;218:17; followed 320:24; follows 199:5; foodstuff 281:20 ;281:15 ;209:18; 215:24;217:9;238:1; 239:11 ;239:20;239:24; 251:8;251:14;252:13; 252:15;252:23;253:4; 281:6;281:7;281:12; 282:2;282:5;282:8; 282:21 ;282:24;283:2; 283:12;283:17; force 232:21 ;232:22;322:5; foregoing 340:2;341:21;341:24; forever 326:14; forgetting 257:15; formally 255:11;204:8;238:6; 270:1; formed 260:1; forms 309:19; formula 217:21 ;202:25;203:23; 209:2;212:18;216:1; 218:14;221:20;223:22; 224:5;225:10 ;228:3; 230:13;231:6;231:10; 239:15;240:10;248:8; 251:6;257:11 ;258:18; 259:6;260:7;260:19; 261:4;261:5 ;261:18; 263:20;264:14;268:3; 268:16;268:19 ;273:23; 277:9;282:14;291:13; 293:21;295:15;296:19; 299:5;305:8;309:16; 310:22;316:1;318:12; 326:8;331:3;335:18; 335:24; forth 269:17;341:25; forwarded 228:11 ;232:11 ;260:23; 261:10;300:25;318:12; foundation 269:11;269:14;210:12; 214:6;225:6;255:22; 256:2;256:3;256:17; 261:23;288:6;288:23; 289:13 ;297:3 ;297:8; 302:11 ;314:7 ;329:3; 330:2;330:13; four 268:4;296:18;297:5; 321:25; framework 259:1,259:3 ;260:1; 318:16:275:22; France 287:22;287:25;288:4; Frank 288:12; free 318:14; French 330:3; frequently 263:10; freshen 199:25; Freshwater 294:17;296:7; front 212:7;242:10;307:5; frustrated 313:19; fullness 253:10; fully 237:7;237:7 ;342:3; Functional 203:3; functional 202:12:202:15; functions 237:12;332:14 ;204:15; 267:14; fundamental 304:2; furans 330:14;330:18;329:21; 330:13 ;330:22;331:2; 331:8; furnished 285:1; further 218:23 ;226:4;242:25; 244:20;257:4;257:21; 258:11;259:23;330:18; 342:8; future 241:3; -G- gain 244:13;244:15;244:15; gallons 232:19,302:18; garb 278:8; gaseous 286:7; gasket 323:14;210:14;213:15; 213:23 ;224:25 ;244:7; 260:6;286:6;286:9; 291:3 ;291:6;291:25; gathered 228:10;238:13 ;329:9; gave 200:6;208:8;211:18; 237:8;237:10;237:14; 312:9;320:20;323:14; Gene 215:5; General 288:10;288:13;336:6; generally 294:5 ;294:15;226:10; Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Exhibit - generally WATER PCB-SD0000024926 Deposition of DAVID WOOD NOVEMBER 10, 1995 236:25 ;259:15;279:5; generated 286:14;304:19; generation 286:1; generic 285:5; gentleman 219:7;247:14;247:15; gentlemen 267:16; geologically 319:22; German 330:3; Germany 218:2;220:13;287:23; 287:25 ;288:4;318:19; given 200:12;230:10;250:18; 254:23 ;255:14;260:14; 340:5;342:5; giving 204:20; glanced 199:23 ;237:7; gloves 277:14; goal 334:15; goes 213:21; Good 199:9;199:10; good 245:6;258:23;265:5; 273:25 ;275:24;278:16; 280:15;316:14;318:23; 319:20;321:8; Gore 341:4;341:12; Gossich 333:18; Government 208:14;209:17;210:4; 210:11;221:7;294:17; 296:6; government 208:19 ;209:12;209:15; 264:6;264:25;265:2; 265:7; gradual 320:12; graduate 216:12; Great 208:21 ;208:25;248:1; 337:3; greater 325:17;262:5;313:22; ground 314:13; group's 312:21; groups 250:6;336:15;337:13; 202:12;202:15;243:25; 245:4;280:18;282:9; 283:9 ;296:25;297:1; 323:18;333:8;334:1; guess 211:18; guide 311:23 ;312:16; Gunnar 213:11;215:7;291:20; guru 280:12; -H- H-e-r-o-u-f-o-s-s 271:13; hadn 268:10; half 282:23;283:1; halt 326:18; handed 208:3;222:13; handing 211:16; handled 243:14;243:15;274:11; 338:8;303:10;305:17; handling 243:18;275:15; hands 269:24; handwriting 328:22;328:23;328:24; 314:1 ;328:18;342:12; happened 235:25; hardly ............. 292:19; Hardy 204:13;204:25;205:6; 205:8 ;205:10;205:22; 208:5 ;208:8 ;209:24; 209:25;210:2;242:14; 242:24;243:22;244:5; 244:19;244:20;245:3; 246:25;247:5 ;265:5; 271:25;276:21;276:25; 276:25;290:15;290:23; 291:2;291:5;291:17; ' 291:24;292:11 ;294:4; 295:10;295:25;296:17; Hardy's 204:16;292:20;296:21; hard 319:23; hasn't 224:4; haven't 318:18; hazard 281:22;302:4; head's 216:15; headed 204:14;246:17; headings 322:24;234:22;243:3; 263:4;318:20; headquarters 204:15;216:11; health 249:25; heard 253:21;270:18; hearings 336:9 ;243:9;259:22; heated 272:19;272:23; heating 280:2;280:2;281:19; 281:20;272:10;272:11; 272:20;272:22;272:23; 272:24;272:25;273:7; 273:8;273:10;275:12; 276:8;276:10;278:5; 279:22;279:24;280:10; 280:12;281:3;281:5; 281:8 ;281:10;281:23; 282:5 ;283:20;336:9; heavily 207:3;311:21; held 216:25; helpful 236:22;237:19;314:8; 327:25; helping 327:11;237:13;252:23; 267:22;274:8;305:9; 327:6;329:24;338:1; 338:6; hereby 341:7; hereinabove 340:6; hereto 340:4; Heroufosse 271:12;272:1 ;272:2; 275:14; Hierarchial 202:18; hierarchy .......... 209:6; higher 214:1;215:23;216:6; 217:9 ;225:4;331:11; highly 209:11;330:10;330:22; 331:7;286:3 ;289:8; 302:12;325:15; himself 292:5 ;295:25; hindsight 241:10;255:4; historical 245:13; history 240:18; hit 238:14; Holden 234:25; hold 316:19;335:2; Holland 279:19;318:19; home 314:16; hoped 315:10;209:12; hot 267:16; hour 199:17;199:22; human 209:18;214:8;225:8; 232:18;232:24;297:9; hundred 302:18; hydrocarbons 335:8;335:11; hygiene 278:16; hypothesis 260:4;260:17;261:2; 261:7 ;261:11; -I- ideas TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY 322:10;322:17; identification) 207:11;210:24;214:16; 219:25 ;220:22;222:11; 227:10;234:12;247:9; 249:2;254:2;262:10; 271:1 ;278:22;284:12; 290:4;298:20;300:23; 308:6;314:21 ;323:22; 328:6;259:1;259:4; 265:17;268:9; identified 264:7;291:19;324:11; identifies 292:3; identify 208:1;214:25;242:12; 249:11;262:18;271:8; 279:2;285:19;290:11; 301:6;308:16;315:5; 324:21;328:11; immediately 310:6; implication 275:23; importance 329:23; Important 276:25;............... .............. important 231:22 ;274:13 ;277:4; 281:16;297:23 ;312:24; 320:1;330:1; improved 321:15;325:15; in-depth 235:14; inaccurate 257:20;257:22; inactive 273:25; inadequate 313:4; inadvertent 323:15; inappropriate 258:4; incensed 331:25; incident 282:16; incinerate 302:2;302:22;314:2; incineration" 301:9;300:2;300:6; 301:16;303:14;303:18; 306:5;306:11;308:20; 308:23;309:3;311:17; 312:1;312:25;334:8; 334:11;336:11; incinerator 301:21;302:23;303:12; included 264:18;264:22;264:24; 294:16;206:25;331:16; including 244:1;337:21; incorrect 270:13; increased 251:25;215:23;217:8; indeed 210:5;224:10;234:5; independently 295:12;337:11; indicated 199:24 ;200:4;224:17; 225:1;232:4;314:11; indicates 217:24;237:25;213:24; indirectly 281:8 ;272:25;280:2; 281:5; individual 226:1;252:16;271:22; 273:19; ' indulgence 282:18; industrial 249:24;272:10;272:11; 272:13;272:25;278:16; Industries 337:25; industries 287:8;323:11; industry 234:2;240:20;272:16; 281:6;281:8;283:13; 336:4;336:15;337:2; information 218:16;218:17;225:20; 226:11;227:19;227:21; 227:23 ;228:3;228:9; 228:13;228:17;228:25; 230:11 ;231:3 ;231:8; ... 231:11 ;231:14;237:11; 238:14;239:13;244:1; 256:25;260:14;266:21; 274:10;287:9;287:20; 287:22 ;287:25;288:1; 288:3 ;288:4;297:18; 312:20;328:3 ;328:16; 329:9;330:9;335:6; 338:6; informed 242:24;243:22;244:16; 244:19;244:21 ;246:25; 291:2;291:5 ;295:25; 297:12;247:5; infrequently 269:3;251:13; infringing 292:9; ingestion 281:13; ingredient 273:20; inherent 272:15;330:23; innerteens 301:18; inorganic 211:11; input 287:9; inquiries 251:17; inquiring 308:23 ;309:3; insecticides 291:10; inside 258:20; inspection 299:21; installation 245:21 ;287:7; installed 277:23; Institute 215:2;337:12;338:4; institute generally - institute Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 i WATER PCB-SD0000024927 TENNESSEE GAS PIPELINE CO. vs MONSANTO COMPANY 325:22;326:4; institutions 207:22; instructed 312:22; instructions 312:9; Insurance 285:11;324:6; integrity 284:2; intellectual 241:12; intelligent 234:7; intended 233:2;281:13; intensity 286:3; interchanging 231:19; interested 230:25;280:25;342:10; 240:1;281:6; interferences 319:13;221:15; interfering 264:7; interjected 253:16; internal 260; 14;261:7; international 202:22;203:1;335:14; interpose 200:14; interpretation 296:22;233:18;233:18; interrogatories 199:5; intervals 251:13; intervened 261:21; into 232:8;232:22;239:11; 239:21;240:15;241:7; 256:9 ;257:25;260:2; 270:7;278:6;278:16; 281:11;281:20;281:21; 282:24;283:2;287:9; 303:1 ;303:2;303:12; 312:6;313:6;318:14; 319:6;319:25;320:14; 320:21 ;321:25 ;325:7; 326:23;341:23; introduced 324:5; invented 288:11;288:18;288:22; invention 288:9; involved 206:11;206:18;206:19; 207:3 ;208:18;211:10; 216:24;233:15;235:20; 236:1;237:4;240:19; 250:7;251:14;252:11; 252:17;252:22;253:4; 257:9 ;258:19;259:11; 259:I2;259:13;259:14; 262:5;270:3;282:17; 283:17;300:5;300:9; 303:20;304:4;306:10; 306:23 ;311:20;323:18; 333:17;333:18 ;334:7; 334:10,335:3; involvement 236:9;252:15;306:21; 239:6; involving 240:21; isolated 272:22; isomers 259:19;259:20;319:4; 319:4;319:2; issues 236:25;267:10;269:17; 311:22;317:10;317:11; 318:10;318:2l;319:25; 327:24;332:16;248:14; 248:21 ;257:9;257:25; 260:11 ;281:25 ;286:1; 303:10;318:4;320:19; 321:4;321:14;321:15; 322:9;330:25;333:9; 333:10;333:13;334:3; 334:7; Item 318:6; items 297:9;312:3;318:5; 318:5;323:19; itinerary 295:19; itself 296:13; lupac 221:4; -J- J.m 247:15;247:25;248:10; 248:12; J.o 208:11; Jack 300:4; jacketed 281:10;272:17; January 217:25;219:14;238:2; 238:6;23 8:6;238:23; 239:12;240:3;240:4; 249:14;249:18;254:20; 255:16;261:22; Japan 334:5 ;334:8;334:11; 334:16;334:18;334:22; 335:1; Japanese 334:14;335:5; jaundiced 278:1;278:13; Jensen 213:10;216:5;216:11; 217:25;218:3;218:4; 218:7;218:8;218:11; 218:16;219:4;219:6; 219:11;219:13;219:14; 219:21;223:18;225:16; 226:5;241:11;243:1; 243:24;244:6;252:24; 252:25;253:14;253:19; 255:5;255:10;256:1; 256:8;256:25;257:3; 257:14;258:3 ;261:6; 261:9;291:20;291:24; 292:5;292:11;292:18; 294:5; Jensen's 203:22;203:25;204:10; 205:11;205:13;205:20; 216:3;216:8;217:17; 220:17;239:13;253:22; 254:23 ;258:17;260:4; 260:12;260:18;261:2; 261:17; Jensen-widmark 224:3; Jim 272:2 ;275:14;275:19; 328:14; job 238:8;239:20;239:24; 239:25 ;25l:8;251:ll; 261:25;283:5;312:23; 320:10; John 324:25; joint 334:14; Journal 226:20; July 266:23 ;315:7;316:5; 316:21;317:6;317:13; 318:6;320:4;320:6; 320:25 ;321:23;322:16; 322:20; June 247:17;248:14;248:18; 342:15; junk 314:15; -K- K-u 271:10; k66p ' 239:25;265:6;311:25; Keller ~ 205:23 ;206:14;249:15; 251:2;282:11 ;295:10; 295:10;295:25; Keller's 280:18;283:9; Kelly 203:9;203:10;203:14; 203:20;203:21 ;204:14; 227:17;227:18;228:3; 228:9;228:15;229:3; 230:11;231:3;231:9; 231:14;231:18;233:1; 233:12;269:17;269:20; 270:7;270:12; Kelly's 204:13; Kentucky 341:9; kestral 244:8; Kevin 226:4;279:18;285:1; 294:9;324:3; Kimbrough 329:12;329:25;331:21; 332:2; knew 245:21 ;258:7;267:6; 277:18;277:19;288:15; 295:16;296:l8;304:ll; 321:1; knocking 331:19; knowing 275:18;280:11; Deposition of DAVID WOOD NOVEMBER 10, 1995 knowledgeable 325:21 ;245:13 ;259:17; 267:12;270:2;279:24; 280:1;290:24; known 267:9;291:11;320:4; Krummrich 301:22 ;313:2; Kup 271:10;271:20;274:9; 275:17;276:14;276:15; 277:3; -L- labels 311:1 ;310:17;310:19; 311:14; Laboratories 294:18;296:8; laboratories 208:25 ;209:4;209:7; 209:15;264:6;265:1; 265:3 ;265:7;266:24; 293:23;296:11; Laboratory 208:13 ;209:16;210:4; 210:11;221:7;294:17; 294:18;296:6;296:7; laboratory 208:17 ;208:20;208:21; 209:9 ;209:13 ;247:23; Idck 269:11;269:13;293:5; laid 204:9 ;278:13 ;311:6; language 225:15; largely 304:17;311:19;213:16; 214:4;224:20;225:5; 234:3 ;238:11;238:12; 337:6,337:9; lasts 278:3 ;260:25;274:7; 274:8;310:12;310:15; 310:20;311:2;317:25; later 225:19;266:14;288:6; 320:10;321:2;330:13; 201:16;201:18;201:24; 264:5;269:5;336:14; latter 223:25 ;305:14; launched 314:15; lawful 199:2; lawyer's 269:14; lawyers 267:16; layman's 211:9; leadership 281:4; leading 208:20;208:21 ;208:25; 278:12;333:23;333:21; leafed 254:15; leak-free 323:3; leakage 312:15; leaked 313:6; 281:14;284:8;281:11; leap 300:25; learned 225:19;319:1; learning 320:14;330:8; least 238:23; leave 321:4:321:11; led 226:12:248:11; left 223:15; legacy 306:21; legislation 335:17:335:22; less 203:13 ;203:16;203:17; 270:11; lottore 215:12;309:15;208:4; 208:9 ;209:21 ;210:10; 212:10;212:11 ;212:22; 215:2;215:8;215:19; 215:23 ;216:23;217:4; 217:8 ;217:24;218:1; 219:2;220:9;257:25; 285:2;307:17;307:23; 308:1 ;308:22;308:25; 309:2 ;309:7;309:9; 309:14;309:15;309:25; 310:3 ;310:4;310:22; 311:13; levels 258:6;258:8;289:9; 319:12;209:13;269:7; 273:7;302:12;325:15; 332:12;338:10; Leverkusen 267:4; lexicon 266:18; life 247:2;289:11; lightly 297:24; likely 219:6;292:10; Limited 208:5;290:14; limited 302:22;337:9; limits 331:19; Lindane 217:20; lindane 217:3 ;217:11;217:13; 217:15;217:19;217:22; line-by-line 303:21; liners 303:4; lines 252:12;244:25;274:18; link 226:12; liquid 244:7;291:3:291:6; listed 293:19;294:7;295:12; 295:21;296:2; Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 institute - listed WATER PCB-SD0000024928 Deposition of DAVID WOOD NOVEMBER 10, 1995 listening 317:15 ;231:10 ;246:18; 271:16;284:25 ;285:3; 292:22;293:12;294:1; 294:19;301:10;328:17; literature 232:2;233:7; little 221:12;238:8;274:10; 297:25 ;320:7;321:1; 323:12; livers" 255:23 ;256:18;244:8; 274:15 ;275:1 ;277:6; 277:17;278:3; lives 232:9;327:12; Lkb 255:8;261:12;292:7; Lkb-9000 292:3; lkb-9000 213:24;225:1; loading 303:2;312:14; located 246:1;246:7;247:23; 299:3; locations 322:11;322:18;323:7; 271:11;272:22;323:17; locked 319:19; London 204:13;205:3;208:4; 208:6;208:20;209:17; 210:12;242:14;246:16; 285:24; lonely 264:20; long 263:19;278:3; looked 230:15; looking 221:22;265:20;265:23; 266:1;319:11;322:14; 330:21 ;330:23; 199:21; 200:7;264:10;299:9; 317:24;326:19; loop 239:13;239:22 ;240:1; loosely 303:2; lots 280:15 ;319:3 ;319:6; 256:11 ;278:4;288:6; 323:12;336:13; Louis 201:25;202:2;202:3; 202:4;202:21 ;204:16; 206:1 ;215:6 ;225:20; 242:15;249:23 ;263:23; 266:7;267:3;279:5; 283:4;285:23 ;285:25; 295:17;300:18;302:24; 341:3 ;341:13;342:12; lower 215:25;217:10;229:21; 331:9;258:6;258:8; 286:5; lying 296:10; "iVl" machine 261:13; mail 249:20;286:13;314:16; 314:16; maintaining 284:2; maintenance 287:4:287:8:302:10; 307:20;338:22;338:23; major 262:5;289:6;317:20; 335:3:338:14; makes 233:17; making 251:21;269:6;278:17; 322:6; managed 321:13; management 202:18;259:15;320:2; 325:19 ;332:10;332:11; 332:18;332:21 ;333; 1; 333:6;333:10;333:15; 333:16 ;333:21 ;333:24; 336:16; manager 202:9;202:10;202:17; 202:22:203:1;335:14; manner 302:3; manufactured 292:7; manufacturers 323:10;337:10;217:22; 304:20:334:15; manufacturing 245:18;288:17;323:1; 323:8;323:11;323:17; 326:15;329:19; Many 272:13; many 199:25 ;203:9;207:21 215:12;216:19;217:1 232:19;239:2;256:13 262:25 ;272:16;321:3 321:6;330:11;204:16 265:5;270:5;270:5; March 220:15;269:17;279:6; 279:13;280:25; marked 207:11;207:13;210:24; 211:17;212:6;212:16 213:3 ;214:14;214:16 214:18;219:25;220:2 220:22;220:24;222:11; 222:13;227:10;227:12; 234:12;234:14;237:24; 239:5;241:16;241:17; 241:18;247:9;247:11; 249:2;249:4;254:2; 254:4;254:19;262:10; 262:12;271:1 ;271:3; 278:22;278:24;284:12; 284:14;284:21 ;285:5; 285:11 ;290:4;290:6; 290:9;298:20;300:23; 301:2;308:6;308:8; 314:21 ;314:23 ;323:22; 323:24;328:6;328:8; marketing 202:11 ;268:12;272:4; 335:14;202:9;202:22; 203:1 ;282:2;207:9; 210:22:219:23 ;220:20; 222:9;227:8;234:10; 247:7;248:25 ;253:25; 262:8;270:23;278:19; 284:10;290:1 ;298:18; 300:21;308:4;314:19; 323:20;328:4; Marsden 234:25; Marsh 239:10;247:16;250:19; 262:2; Martin 279:16;279:19; Mass 224:24; mass 213:21;213:23;224:18; 260:6,291:25; materials 206:24;230:7;234:6; 237:2;237:3 ;237:8; 237:15;239:4;248:3; 288:18;301:23 ;302:23; 313:8;323:14;330:1; 330:11 ;331:8;331:9; 331:12;229:25;236:12 236:22;237:11;237:16 237:17;237:18 ;240:16 273:6;301:21 ;303:11; 312:6;312:17 ;329:3; 330:3;330:3;330:4; matters 208:19;257:19;250:9; 257:4;257:7;257:13; 258:14;281:19;283:14; May 290:16;290:19;301:8; 309:16; Maybe 203:2;274:7; maybe 310:5 ;202:9;207:23; 219:3;230:13;241:11; 253:16;269:25;270:18; 274:14;274:19;277:5; 305:6;305:8 ;315:22; 333:7;333:8;338:17; meaningful 233:19;269:6; means 213:14;206:22;209:11; 209:12;218:15;224:8; 228:25;230:1;232:8; 236:23;238:10;244:10 254:14;257:13;259:22 26l:ll;26l:2l;263:l7 263:21 ;264:15;264:16 264:17;267:8;272:12; 280:13;280:13;289:20 297:2;302:6;306:19; 307:9;311:18;326:22; 327:18 ;328:1 ;329:6; 329:24;331:12;331:25; 333:15; measured 325:9; measurement 325:16;233:25;234:5; measuring 327:5; media 210:18;226:10;257:21; 258:12; medical 204:15;250:1 ;250:4; TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY 250:5;256:24;259:13; 262:21;276:22; meetings 218:7:219:11;296:23; 296:24;296:25;297:1; 297:4;316:3;333:3; 201:24;218:5;218:7; 218:8;219:3;219:5; 219:8;219:19;220:12; 253:12;270:2;315:13; 315:19;315:20;315:23; 315:24;315:25 ;316:5; 316:16;316:21;316:24; 317:5 ;317:13;317:21; 321:23 ;322:3 ;322:16; 322:19;333:5;333:11; 333:12;333:15;201:15; 218:4;219:13;219:14; 252:19 ;253:6 ;267:3; membership 337:13 ;338:7;338:20; 219:8;315:9;315:14; 315:16;316:10;320:11; 332:17;336:18;336:24; 337:14;337:17;337:23; 337:24;337:24; memorandum 228:15;233:6;233:13; 242:24;243:23;244:20; 250:9;250:24;251:2; 25 V :3;252:4;254:17; 254:18;255:20;268:7; 269:18 ;274:7;277:16; 280:3 ;280:17;282:13; 287:13; memory 199:25 ;235:25;296:20; 334:12; memos 241:21;265:6;227:16; 227:18;227:19;227:24; 228:12;231:7;231:18; 242:14;243:7;244:1; 244:11 ;244:19;245:2; 246:24;247:14;247:18; 248:11 ;249:13 ;250:11; 250:18;251:20;253:20; 254:20;254:22;256:15; 257:1;257:6;257:8; 261:15;261:22;261:23; 262:20;262:23;263:2; 263:24;264:3;265:16; 266:4;271:10;271:14; 274:2;275:22;279:4; 280:21;284:18;284:19; 285:21;301:8;303:9; 308:18;309:2;310:18; 315:7;318:6;324:23; 328:13;328:15;328:19; mentally 269:3; mentioned 233:5;236:16;340:6; mentions 280:21; mentoring 216:13;216:8; merely 319:21; metabolites 291:11; methodology 319:7;326:3; methods 281:18;321:20;233:14; 319:13;319:14;199:17; 217:24;218:11;218:16; 252:25 ;253:19 ;255:2; 255:11;255:25;257:14; 283:3; microcoulometric 224:24;291:7;213:16; middle 211:2;234:22;286:17; 235:14; Mieure 328:14; might 199:24;236:22;275:11; 313:12; migration 319:19;320:5;320:6; 320:16; Mike 248:1;248:17;285:24; military 286:9; millions 266:20; mind 256:12;277:10;341:17; mineral 319:12:264:19; minimal 326:23; Ministry 208:4; minor 288:8;303:5;310:5; 312:12:325:13; minutes 270:1 l;315:13;3i5:24; 316:12;316:21;241:21; 288:24;315:9 ;315:17; 318:5;322:3; miscommunicating 316:2; Missouri 215:7;341:1;341:5; 341:14;342:13 ;342:18; mode 256:5; modifying 304:9; molecular 286:5; moment 211:1 ;212:22;213:3; 220:3 ;234:16;257:16; 262:13;320:20;324:2; Monsanto 201:21;204:15;204:20; 205:25;206:8;206:11; 206:18;208:5;211:13; 215:6;216:20;216:25; 217:2;217:22;225:20; 229:11;230:16;230:25; 231:2;231:13;233:13; 235:20;236:10;236:20; 237:12;245:18;245:22; 245:25;246:15;246:20; 249:23 ;252:8;256:13; 257:7;258:4;258:15; 258:19;258:21;259:3; 259:8 ;259:12;259:13; 259:14;259:16;260:13; 260:17;260:24;261:1; 261:6;261:7;261:9; 261:16;263:5 ;263:6; 263:16;263:17;263:18; 264:18 ;265:4;265:12; 268:11;271:13;272:3; listening - Monsanto Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 WATER PCB-SD0000024929 TENNESSEE GAS PIPELINE CO. vs MONSANTO COMPANY 272:7;277:19;278:17; 279:5;279:19;280:14; 283:11 ;285:22;285:23; 286:24;287:3 ;287:6; 288:1;288:5;288:11; 290:14;297:16;299:21; 301:11 ;303:16;304:23; 307:19;311:16;312:18; 313:19;318:12;322:10; 322:17:325:4:325:22; 326:4;326:11;326:15; 327:13;327:15;327:24; 330:4;331:8;332:10; 332:15;334:14;334:18; 336:19; Monsanto's 228:16;228:22;229:9; 229:18;233:6;237:9; 259:24;266:22;266:25; 269:7:271:11:276:8; 276:10;306:4;306:11; 327:8;327:11 ;331:1; monsanto 286:21; months 253:21;253:24;282:23; 283:1;315:22; More 204:23; more 203:16;204:16;233:1; 241:7 ;243:15 ;261:24; 288:15;306:14;313:25; 318:24 ;319:20;319:22; 325:21;327:4;331:7; 338:8; morning 199:9;199:10; 199:11; most 213:24 ;224:15;225:2; 251:16;278:12;287:19; 289:3 ;291:8;315:16; 333:15; moved 201:22;202:21 ;205:2; 205:5 ;235:17;235:23; 23 8:1 ;238:4;239:11; 313:5; movement 312:14;204:24;238:8; 261:10;293:11 ;298:6; moving 201:20; much 204:17;214:20;232:7; 253:2;271:4;285:13; 313:25;317:22;321:1; 323:15; multi-sheet 230:8; Munch 237:18;285:25 ;285:25; 338:10; museum 293:24; myself 228:8;236:11 ;238:19; 239:21 ;241:8;243:6; 244:1 ;247:16;253:16; 262:4;265:23 ;285:24; 308:18;315:7;317:20; names 267:24;205:24;216:15; 217:12;229:22;229:25; 271:21 ;299:13 ;299:22; 307:12;331:23; napthylenes 277:22;278:14;231:21; National 229:8; nationalized 337:4;337:6;338:17; nature 214:1 ;225:4;227:2; 293:7;306:17;311:9; Ncr 228:17;229:7;229:13; 229:14;229:19;230:4; 230:10;230:15;230:19; 230:21 ;231:9; near 245:23; neat 269:14;323:13; necessarily 237:7;322:2;322:4; 322:19; necessary 297:17;297:17; needed 205:9 ;237:6;275:9; 275:10;281:8 ;283:18; 317:23 ;325:6; needles 214:7;225:8;264:9; needs 233:22;214:20;228:24; 229:4;234:4;239:6; 242:9 ;271:5;281:23; 285:14;295:3 ;304:7; 312:7;317:17;317:22; 334:1;337:8;337:11; network 337:1; Nevada 285:7; New 248:7; newly 315:16; newspapers 266:8 ;266:9;255:8; 238:1 ;238:14;238:21; 240:21 ;240:21;251:10; 251:12;261:25;302:14; 309:5;310:3 ;320:9; 320:10; next 316:16; Nippon 335:1; n on-chlorinated 275:16; non-dielectric 306:17;306:22;311:9; non-electrical 327:22; non-member 338:1; non-responsive 293:11; None 334:6; none 300:8; noon 270:22; normally 238:13;257:23;307:14; 267:14; North 247:24;271:23 ;341:12; nor 342:10; notarial 342:12; Notary 340:18;341:4;342:17; noted 284:25;285:2;241:6; 274:10;276:25;324:8; Nothing 233:4; nothing 199:3 ;242:25;278:11; 341:20; Notice 341:8; November 203:14;245:2;247:4; 255:15;323:25;324:23; 340:3 ;341:15; null 331:18; numbers 214:19;220:25;222:14; 222:17;234:15;241:19; 296:15;298:23;301:3; 307:1 ;314:24;324:14; 207:14;210:13;211:20; 213:17;214:5 ;215:18; 218:7;220:3 ;223:9; 224:13 ;224:20;225:5; 227:13 ;228:7;229:15; 237:12;247:12;249:5; 254:5;262:13;271:4; 278:25;279:7;284:15; 285:18;286:7;290:7; 301:11;308:9;319:25; 321:19;323:25;324:10; 328:9;328:14;337:9; -nu* oaths 341:6; 199:12; objecting 269:11; objections 342:2;200:15; objective 209:5;202:25;203:23; 209:2;212:18;216:1; 218:14;221:20;223:22; 225:10;230:12;231:6; 239:15;240:10;248:8; 251:6;257:11;258:18; 259:6;260:7;260:19; 261:4;261:5;261:18; 263:20;264:14;268:3; 268:14;268:16;268:19; 273:23 ;277:9;282:14; 291:13;293:21 ;295:15; 296:19;299:5;299:16; 305:8;316:1;326:8; 331:3 ;335:18 ;335:24; observations 277:24;278:10; observed 232:2;259:10; obtained 213:22;224:25;218:17; 297:17; Obviously 272:20; obviously 240:20;272:14;310:16; Deposition of DAVID WOOD NOVEMBER 10, 1995 317:2; Occasionally 338:4; occasionally 338:1; occasions 215:18;239:18;251:9; 334:2; occur 316:7; October 315:22;316:4; octochloro 244:24; odds 288:3; Off 212:3 ;248:23;270:20; 300:19;338:24; offered 327:15; offices 341:12;204:25;208:6; 279:5; offshore 335:3;212:4;223:5; 270:21;284:6;298:16; 298:17;3 00:20;332:7; 338:25; often 210:12; oil 244:8;279:9;280:19; 280:24;281:25;319:12; Ola 217:24;219:15;253:22; old 302:15;303:2;313:12; once 224:12;239:20;304:8; 313:23 ;327:18; one's 278:8; ones 215:25;217:10;237:1; 275:13;338:14;338:15; 338:23; ongoing 302:22;304:17; only 216:21 ;220:16;248:5; 258:11 ;275:9;287:24; 291:9;304:18;312:13; 314:10; opening 214:9; operate 272:13^14:14; operations 204:20;297:19;321:13; 273:11; operators 312:19;312:21;313:19;_ opinion 203:22;204:10;292:20; 293:4;318:14;321:5; 321:7; opposed 204:4; oral 199:5; order 267:12; ordinary 213:18;224:22; Organic 226:25;227:1; organic 211:11 ;246:12;266:23; 283:24;286:5; organization 205:25 ;206:18 ;238:12; 25I:15;251:I6;253:18; 263:1 ;267:8;301:11; 337:7;337:7; organochlorine-containir 240:13;209:19;234:20; 240:8; originally 280:3 ;330:12;264:4; 294:4;328:17; originator 328:19; others 250:12;264:23-.264:24; 267:18;306:19; otherwise 200:19;267:15; ourselves 323:13; outcome 310:19; outlets 325:8; outset 318:13; overfill 312:12; overview 236:23 ;332:14;207:21; 209:14;217:1 ;232:21; 236:11;237:5;238:25; 240:2;242:2;243:1; 251:17 ;259:22 ;266:21; 269:21;297:24;298:12; 325:8; owner 313:19 ;235:25 ;256:12; 323:1 ;325:20; oxydative 284:1; oxygen 289:9; -P- Pj 247:16; packaging 246:12; Page 293:17; pages 222:16;222:23;266:20; 307:1 ;341:24;221:11; 222:15;223:1 ;223:6; 223:12;224:12;224:13; 226:7;234:23;241:25; 241:25 ;242:3 ;242:4; 242:5 ;242:6;242:8; 286:18 ;291:5 ;291:15; 291:17 ;292:23 ;293:13; 293:17;293:20 ;294:1; 294:7;294:21 ;295:5; 295:12;295:21 ;295:24; 296:2;296:15 ;296:18; 297:4;310:13;310:15; 310:20;311:2;321:16; 321:20;322:14;324:9; pallets 312:10;312:11; Palm 217:24;218:2;218:6; Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 Monsanto - Palm WATER PCB-SD0000024930 Deposition of DAVID WOOD NOVEMBER 10, 1995 218:9;218:11;218:16; 219:8;2L9:11 ;2 L 9:15; 219:20;253:16;253:22; Papageorge 237:4;328:13;328:20; 329:1 ;329:10; papers 216:16;277:18;223:17; 223:23 ;223:24;230:9; 244:5 ;251:21 ;266:16; 328:18 ;329:11 ;329:12; Paragraph 265:21; paragraph 211:3;211:4;212:10; 214:10;217:6;228:20; 233:17;245:6;265:24; 273:1 ;274:7;274:9; 287:12;291:4;291:15; 291:17;292:17;292:25; 297:4;310:1; parentheses 221:13; partially 204:14;312:13; Particularly 260:21; particularly 287:21 ;210:12;215:14; 228:5;228:9;236:3; 244:6,244:11 ;263:1; 264:13;282:16;295:21; 304:4;305:22;306:15; 318:4^320:11;322:3; 323:13;325:11;329:23; 333:9;333:11 ;333:13; 333:14;334:2;334:3; parties 342:9;342:10; partner 306:20; party 295:19;235:24;236:11; 246:4;246:7;246:13; 250:3 ;262:21;266:18; 278:15;295:2;303:19; 305:14;309:16;309:21; 317:3;320:9;320:12; 326:21 ;329:18;333:8; passed 207:24;230:11;239:7; 242:22;243:7;262:1; 266:19; past 243:1; Paton 201:3;201:5;201:15; 202:1;202:6;237:8; 237:16;301:10;306:14; 306:20;308:20;324:24; Paul 237:3;285:22; Pcb 236:23 ;239:22;240:1; 252:17;266:18;266:21; 275 -.23 ;301:9;301:15; 305:7;305:25 ;306:5; 306:11;308:19;308:23; 309:4;312:1;313:23; 318:10;318:23;319:11; 319:19;320:2;320:9; 320:15;321:20;321:24; 322:11 ;322:17;325:11; 326:15;336:16;338:17; Pcb-containing 300:6;300:10;303:17; 304:14;304:24;305:5; 305:12;306:5;306:12; 312:8 ;312:25 ;331:1; Pcbs 206:25;215:24;217:9; 232:4;235:21 ;235:24; 236:1 ;236:13 ;236:15; 236:19;237:13;240:24; 241:5;252:1;252:18; 257:9 ;264:7;265:17; 266:25 ;268:9;268:13; 268:13;269:2;292:14; 293:7;297:7;303:7; 303:8;305:22;311:9; 314:12;314:17;317:1; 317:4;317:13;318:8; 318:24;318:25;319:2; 319:8;319:18;320:6; 320:13;320:20;320:24; 321:9;325:13;326:23; 327:5;327:9;327:13; 329:14;329:19;330:13; 334:5;334:8;334:16; 335:17;335:22; peaks 210:14;291:10;291:11; 292:12;325:16; pending 341:8; penultimate 274:18; people's 232:22;325:7;228:16; 228:22;229:1 ;229:4; 236:24;237:9;237:18; 240:13;243:25;245:4; 251:10;251:14;251:18; 253:18;255:8;256:13; 260:12;262:25;264:4; 264:12;264:16;264:17; 264:17;270:4;276:17; 277:14;277:25;278:18; 279:7;279:25;283:3; 288:17 ;295:16;295:22; 297:1;301:11;301:18; 302:25 ;303:10;305:24; 311:23 ;312:19;318:16; 318:22;319:16;320:1; 322:6;322:23;322:25; 328:17; Pepsi 284:5; perceiving 320:3; percent 287:15; performance 267:11;288:14;288:16; 302:25; perhaps 260:24; period 199:22; 199:25 ;203:7; 203:11;203:14;203:19; 203:21 ;216:3 ;228:5; 234:1 ;236:1 ;237:20; 238:8;238:18;238:25; 239:21;240:18;252:15; 252:22;253:3;255:18; 259:22;269:5;269:21; 269:25;320:10;325:8; 326:10;335:13;336:14; 337:21; Perry 341:12; personally 226:14;333:20;203:25; 245:13;321:5;321:7; 239:1 ;239:7;243:17; 279:25;289:3; perspective 232:25;241:14; pertinent 236:12;318:18; peruse 262:14; pesticides 213:19;224:22;234:20; 240:5;240:13;240:15; 209:19;210:6;213:6; 217:20;226:2;264:8; Peter 239:10;250:18 ;262:1; Peterboro 246:11; Phosgene 286:5; phosgene 286:1;286:4;286:14; 287:16;288:20;288:23; 288:25 ;289:7; phrase 211:2; physicist 247:21; picked 266:2; picking 298:13;293:9; piece 211:10;228:9; pine 264:9; pitched 251:20; placed 298:22; 199:15;199:16; 205:25;219:17;313:9; 313:16;314:1;315:20; 315:21;315:23;316:21; Plaintiff's 207:10;207:13;210:23; 211:17;212:17;214:14; 214:15;214:18;219:24; 220:2;220:21 ;220:24; 222:10;222:13;222:16; 222:16;227:9;227:12; 234:11 ;234:14;241:16; 247:8;247:11;249:1; 249:4;254:1 ;254:4; 254:19;262:9;262:12; 270:24;270:25;271:3; 278:19;278:21;278:24; 284:11 ;284:14;284:20; 290:1 ;290:3 ;290:6; 298:19;298:22;300:22; 301:2;308:5;308:8; 314:20;314:23;323:21; 323:24;328:5 ;328:8; planned 296:1-^16:7; planning 316:11;316:17;322:21; plant 276:20;276:21;301:22; 302:23 ;323:2;323:4; 323:5;323:6;325:8; 325:20;327:3;316:19; plasticizer 2l5:5;216:24; plastics 246:14;312:6; TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY played 303:24;334:13;335:16; 335:21; Please 207:9;210:22;214:19; 219:23 ;220:3;220:20; 222:9;227:8;234:10; 234:15;247:7;248:25; 253:25 ;262:8;262:13; 271:4;278:19;284:10; 290:1 ;298:18;300:21; 308:4;314:19 ;317:22; 323:20;324:21;328:4; 328:11; please 208:1;214:25;242:12; 249:11;262:18;268:20; 270:23 ;271:8;275:5; 279:2;285:13;285:19; 290:11;294:10;298:3; 301:6;304:25,308:16; 315:5;316:14;317:25; point-by-point 317:8; pointed 233:6;233:8; pointing 265:22; ____________ points 233:11;244:17;297:6; 202:13;202:17;202:20; 206:1 ;206:3 ;207:1; 216:25;220:16;225:22; 226:17;229:20;231:1; 232:17;236:2;239:3; 240:11 ;243:6;245:5; 252:5;252:13;255:10; 257:3;258:20;262:6; 265: J 4 ;266:19 ;269:1; 297:12;297:15;304:5; 306:15;310:11;311:16; 314:2;314:2;322:2; 325:23 ;326:16;330:19; 331:17;331:20; poisonous 293:7; poisons" 274:16;275:1;277:7; 277:17;286:9; policies 304:6;306:1 ;306:16; 311:5; policy 303:9 ;303:13 ;303:16; 303:23 ;303:24;304:2; 304:7;305:22;306:4; 306:11 ;311:5 ;311:10; 311:23 ;332:15; pollution 248:6; Polychlorinated 225:6; polychlorinated 213:6;213:25;214:6; 225:3 ;226:13 ;226:16; 231:5;233:9;262:24; 275:12;276:1 ;292:14; polychlorobyphenyl 244:9; porpoises" 234:20; portion 225:11 ;268:22;294:12; 298:4;305:2;318:2; posed 248:10;318:1; positions 237:23 ;336:7;202:8; 216:17;238:1 ;251:10; 263:11;263:13;263:19; 322:1; possessed 211:13 ;231:23; possibility 278:9 ;281:14;284:8; 304:23; possible 221:15;260:4;277:13; 281:21; post-dates 242:16; potato 279:10;279:11; potential 257:24;267:16;268:12; 302:3 ;303:7;325:17; 330:20; potentiated 213:25;225:3; potentiation 216:6:241:11; Potter 308:21; pound .. 326:25; Power 285:7; power 259:24; practically . 258:12;320:2; practice 243:10;243:19;278:16; 311:24; practitioner 276:23; pre-print 212:11; pre-publication 226:1; pre-published 226:11; preceded 310:6; precise 202:10;217:21;219:7; 288:7; predominantly 302:19; preliminary 310:17; preparation 249:8;254:12;302:5; 308:13;315:25; preparatory 310:20; prepared 287:6;296:9;298:14; 298:15;302:1;304:16; 309:4;3l3:21;199:14; 312:16;312:17;315:17; 316:6;316:12;322:23; preparing 207:19;207:25;211:25; 303:11 ;315:8;323:19; prescribed 322:20; presence 213:6;219:12;234:6; 234:9;255:6;281:15; 329:13; presentation Palm - presentation Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 WATER PCB-SD0000024931 TENNESSEE GAS PIPELINE CO. vs MONSANTO COMPANY 255:14; presented 232:1 ;323:19; presenting 199:24;218:12;222:20; 244:24;252:9;290:24; 296:24:315:11;333:20; preserved 296:14; president 263:16;263:16; pressure 329:4;330:6;330:16; 224:3 ;224:7;257:23; 258:5;265:18;266:6; 266:11;266:14; presume 248:10; pretty 243:7;288:25;307:11; prevail 321:6; prevent 277:2;278:8; Previously 241:18; previously 200:12;237:21 ;238:17; 241:15 ;241:17;268:8; 285:5;290:9;309:5; 250:22;269:21 ;284:22; primary 301:10; Prior 204:24;268:6; prior 209:20;218:19;268:8; privileged 200:19; Probably 243:9; probably 204:7;254:15;266:17; 266:18;294:14;303:19; 317:10;323:18;333:25; problems 268:12;316:25 ;317:4; 317:12;283:11;325:18; procedures 256:7; proceed 299:11;299:14;316:16; 324:16; processed 281:15; processes 272:13;330:18; processing 282:6;283:13;323:4; 220:8;281:7;323:16; Prodelec 267:13; produced 241:24;285:6;287:6; 287:16;288:20;289:7; 290:13;299:3;299:16; 299:21; Producers 338:3; producers 289:6;210:13;326:12; 326:20; producing 230:8;281:6; production 207:14,211:19;214:19; 220:3;220:25 ;222:14; 224:13 ;227:13 ;234:15; 241:19;247:12;249:5; 254:5;262:13;271:4; 278:25 ;290:7;298:23; 299:12;301:3;307:1; 307:20;308:9;314:24; 323:5;323:6;328:9; Productor 255:8;261:13;292:7; products 236:10;246:2;246:6; 246:18;268:13;272:9; 274:2;274:4;281:3; 281:8;287:14;305:12; 331:1;204:21;229:18; 229:22;230:3;246:16; 246:19;249:24;250:7; 259;13;272:8;273:19; 286:7;290:15;329:4; 330:7;330:7; professional 204:2;204:10;250:6; Professor 216:10;220:12;221:19; professor 225:12; programs 325:2;225:24;315:15; 316:5 ;316:6;316:10; 325:3 ;325:23 ;326:5; 327:7;327:16;327:19; progression 295:18; pronounce 331:23; properly 297:22;298:8;298:9; 312:22;312:24;314:1; properties 286:8;291:22;338:10; propounded 199:5;342:1;342:5; proprietary 229:25; protected 278:7; protective 278:8;303:4;266:24; 312:11; protocols 289:5; proud 262:4; prove 246:18,298:1; provided 296:17; provides 272:21 ;272:9;272:20; 282:12; Public 340:18;341:4;342:17; publication 212:12;220:16;220:18; 221:18;221:21;221:21; 221:22;222:6;222:18; 223:2;223:24;227:3; 227:5;227:6;235:8; 289:17;234:3 ;238:11; 240:12;265:18;266:6; 266:11;266:14; published 224:4;224:5;224:8; 224:19;225:18;225:23; 236:12;254:24;255:2; 255:6;255:7;255:12; 257:23 ;266:11;266:13; 288:21;288:22;290:13; 290:15; publishing 223:19 ;304:10;225:21; purchased 229:19; purchasing 229:21;229:23;230:2; purely 219:10;241:10; purports 297:3;234:23; purposes 328:16;335:23 ;256:9; pursuant 227:19;341:7; putting 302:25 ;303:3;326:23; 232:25;271:21 ;272:14; 272:17;293:8;302:13; 303:9;312:10;313:14; 318:11;325:7; puzzling 216:7; Pydraul 308:2;310:23 ;311:2; 311:17;311:19;311:22; 311:24;314:5;327:16; 335:6;335:7; Pyroclor . 248:14; pyronols 301:18; n qualified 229:5 ;260:13;341:5; quality 204:10;209:4;256:7; quantification 206:24;268:24; questioned 255:21 ;256:16;256:22; 256:24; questioning 232:20; quickly 240:23; quite 239:19;299:23;336:25; quotation 256:24; quote 224:15;224:17;224:20; 231:21;244:5;255:20; 256:16;266:16; quoting 225:14; -xnv- R-o-u-s 279:4; R-u-a-b-o 271:11; R.p 271:20; radically 240:22; raised 260:11;317:8; Ralph 285:25;285:25; range 272:8;273:10;273:17; Deposition of DAVID WOOD NOVEMBER 10, 1995 275:6;276:8;336:20; rank 209:6;267:12; rates 319:5;325:13; rather 202:18;263:14;289:11; 289:12;304:1;318:13; 321:15 ;330:7;333:19; re-education 320:13; reached 251:10;251:15; reaction 272:18 ;272:20;272:23; 281:11; readdress 298:14; reader 227:7; reading 225:11;235:14;236:25; 237:6;237:11;244:14; 245:6;266:8;266:9; 291:14;296:15;317:14; ready 317:23;214:11;236:4; 236:12;237:8;237:8; 242:2;242:8;243:10; 243:12;243:13;243:19; 247:4;266:20;268:23; 274:17;275:1;277:19; 294:13 ;294:19;295:3; 296:20;298:3 ;298:5; 304:15;305:3;317:16; 318:3,340:2; Really 336:25; really 226:15;231:22;236:16 ! 238:25;279:18;316:15 326:24;330:19;336:12 289:10;331:19; reasoning 292:18;209:10;280:20; 289:23 ;296:12; reassured 229:3; reassuring 298:2; recall 201:17;201:18;201:23 ; 202:16;202:19;203:18 203:19;203:21 ;203:24 ; 206:3 ;206:13;207:4; 207:8;208:8;210:8; 210:17;211:23;212:20; 215:13;215:15;215:19; 222:7;227:23;228:2; 228:11;235:16;235:17; 236:3 ;236:5;237:4; 237:14;237:19;245:25; 246:3;246:9;247:18; 248:13;248:17;248:20; 250:3 ;250:20;250:22 252:21 ;252:25;253:8 263:13 ;264:25;265:4 267:5;267:21 ;267:24 269:16;270:6;270:12 280:22;282:11;282:18; 283:11 ;290:21 ;299:25; 300:1 ;300:12;304:15; 306:7;308:22;309:7; 309:9;309:12;311:9; 311:11;311:18;315:23; 316:24;317:5;317:11; 322:10;322:15 ;325:6; 332:2;333:13;333:23; 334:10;334:25 ;337:16; 338:12;338:20; recapped 254:22; received 210:9;215:16;215:19; 235:8;242:19;242:21; 244:4;250:16;252:3; 253:20;255:13 ;261:21; 277:16;324:25 ;215:8 215:13;244:2;249:17 254:8;271:17;279:12 286:10;290:18; receiving 247:18;250:23;290:2l; 301:17; recently 320:7; Recess) 270:22; recess) 248:24; Recessed 339:1; reclamation 300:10; recognition 232:4; recognized 281:9;207:14;211:20; 214:23 ;220:6;220:7; 220:9;221:2;222:1; 227:15;235:3;247:12; 249:5;254:5;262:16; 299:1;299:24;308:11; 315:1; recollection 282:16;300:8;309:24; 310:7;310:12; recommendations 278:17; recommended 277:12;303:8; record) 212:4;270:21;298:17; 300:20;332:7;338:25; records 295:3;204:7;208:2; 212:3;215:1 ;242:13; 244:11;248:23 ;249:12; 261:1 ;262:19;268:23 270:20;271:9;276:17 279:3 ;285:17;285:20 290:8;290:12;294:13 294:22;294:24;295:1 296:14;298:5;298:16 300:19;301:7;305:3; 308:17;315:6;318:3; 324:22;328:12;335:23; 338:24; redirected 251:22; reduce 329:5;330:16; refamiliarized 241:8; referenced 282:12;309:25; references 223:12;217:5;219:2; 223:13;223:17;223:23; 224:2;224:2;246:21; 248:5;248:21 ;273:1; 285:5;285:9;309:22; Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 presentation - references WATER PCB-SD0000024932 Deposition of DAVID WOOD NOVEMBER 10, 1995 referred 217:4;221:19;245:8; 251:17 ;267:23 ;274:2; 289:17 ;294:20;314:4; referring 218:1;221:21:237:23; 248:4;252:4;264:12; 277:3;277:7;293:18; 316:3;329:13; refers 219:3;228:12;284:17; 284:21;287:13;212:16; 223:1:279:10:302:5; 331:11; refinement 310:5; Refining 304:1; reflect 316:15; refreshes 296:20; refreshing 235:25;334:2; regarded 209:11; regarding 200:24;203:22;258:16; 300:2; .................. Register 229:8; register 243:13; regularly 205:10;205:6;227:7; regulations 321:2;336:10;336:3; regulatory 330:16; reinsert 239:21; related 258:7;282:1;282:7; 287:4;300:10;304:19; 305:23 ;306:1;311:6; 311:22;342:10; rnldtoc 272:8;279:8;304:12; 304:13; relating 217:15;220:17;236:15; 239:13 ;265:17;335:17; 335:22; relationships 336:3 ;336:4;336:5; relative 306:16;336:9; relax 238:16; releases 323:15;240:15;302:4; 325:17;327:13; releasing 225:19;325:12;326:22; relevancy 246:15; reliability 209:13; reliably 281:17; remain 257:24; remarks 342:2; Remember 255:16; remembering 276:18;204:7;207:2; 217:21 ;230:18 ;249:10; 263:15 ;263:22 ;267:5; 267:23 ;276:16;288:7; 296:12;303:21 ;317:7; 317:8 ;326:1 ;333:25; 338:2;338:15; reminding 334:1; 199:11 ;317:20; 335:12; Renata 331:22;332:1; Rene 331:21 ;331:25;332:1; renewed 235:24 ;236:9; reorientation 320:9; repairing 301:19; Repeat 268:18; repeat 210:1;268:20;294:10; 305:1;317:25; rephrase 205:18 ;229:16;335:19; replaced ........... 239:9;310:5;239:1; 302:14;313:13; replacing 239:7; reply 199:5; reported 202:1 ;331:5;341:22; reporter) 268:23 ;294:13 ;298:5; 305:3 ;318:3; Reporting 341:12; reporting 324:24; reports 257:22;280:18;280:21; 280:22;282:12;202:5; 236:3 ;236:6;257:16; 290:18;290:21 ;290:23; 318:7;333:9; requested 200:5;228:10;268:22; 294:12;298:4;305:2; 318:2;328:17; requests 259:19;243:18;250:15; 250:17;253:15;259:20; required 335:6;272:13; rereading 245:2; Research 338:3; researched 264:19;216:16;224:15; 224:17;224:19;225:15; 225:17;225:23;225:24; 237:9;252:12;257:16; 260:12;261:17;338:8; resided 312:20; residual 311:8;313:24; residues 209:20;210:6;226:15; 259:2;259:5;264:8; 290:25 ;291:9;213:7; 226:2; resin" 244:9; resolution 233:21; respected 322:5; respects 342:3 ;209:8;231:19; 242:25;251:25:301:15; 303:16 ;306:5 ;306:11; 312:1;317:12;320:4; 320:6;320:24;322:16; 324:12;334:4;334:S; 334:13;335:16;335:21; responded 261:23 ;262:3;244:18; 326:9;335:25; responses 299:9;299:19;299:24; 219:22;254:18;268:25; 269:7;328:20; responsibilities 204:19;206:7;217:1; 23 8:20;23 8:22 ;251:19; 262:7;272:3 ;282:1; 282:7;282:8; responsibility 267:7;326:20; responsible 246:2;248:2;301:25; 305:25 ;306:9; responsibly 261:9;303:10;312:16; responsive 259:18; rest" 257:13; restate 294:9; restraining 313:15;214:12;257:4; 257:7;258:14;316:12; results 225:17;225:25 ;226:5; 244:24;261:16;289:16; 312:15;330:17; retrospect 230:2;241:10;278:11; returned 201:25; returning 302:2; returns 303:13;311:7;311:12; 311:12;311:17;311:22; 312:1;202:2;203:6; 210:25;237:20;311:1; 314;12;314:17; reviewed 228:14;235:18;295:17; 338:17; reviewing 239:5;259:11;265:6; 200:2;200:4;254:12; 254:16;258:22;260:15; 270:2;303:21;308:13; Richard 242:15;249:16; Richardson 244:23 ;247:1; Richardson's 244:21; right-hand 223:3 ;217:25;229:10; TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY 238:3;250:14;258:2; 270:15 ;274:24;274:25; 279:21 ;282:21;282:25; 285:12;313:1;313:20; 313:22;316:2;316:4; 318:13 ;338:4; rigorously 259:11;313:9; rigs 335:4; rings 334:9;249:22; rip 313:13; Rising 253:17; risk 326:23; River 245:7;245:9;245:12; 245:14;245:19 ;245:23; 246:1 ;246:22;247:2; rivers 248:6;245:9;319:20; 319:22 ;321:9;321:10; road 313:17; Robert 205:23; --------------rods 313:15; role 204:16;206:2;216:13; 216:14;216:21;301:15; 303:25 ;306:15;334:4; 334:13 ;335:13;335:16; 335:21; Ronald 341:4; Roush 279:4;280:4;280:5; 280:8;280:17; routinely 216:4;231:9;252:17; 338:8;333:8; Rowan 341:9; Ruabon 247:24;271:11;271:23; 276:20;285:22; rules 314:13;333:19; running 238:15; -s- S-a-n-t-o-t-h-e-r 271:15; S-c-a-n 212:14; S-o-d-e 262:22; safeguards 232:2; safely 272:23; safety 204:21 ;249:24;250:8; 259:14;275:15;312:18; salesman 248:1 ;279:19;279:23; 215:6;216:24;266:24; 279:25;248:2; salt 232:7;232:11; same 204:25 ;218:4:221:17; 241:22;255:18;287:22; samples" 213:8;213:14;214:5; 214:8 ;224:23 ;225:5; 225:8;325:10;326:2; sampling 319:14;325:2;325:3; 325:22;3 26:3 ;326:5; 327:7;327:16;327:19; Santotherm 271:14 ;272:6;272:7; 273:2;273:4;273:6; 273:8;273:12;273:14; 273:16;273:17;273:21; 274:4;274:11;275:2; 275:6 ;275:7 ;275:15; 275:16;275:18;275:25; 276:4;276:6;276:7; 276:13 ;277:7;281:2; 283:16;283:21; Santotherms 273:24; satisfaction 289:20; satisfied 244:22;244:23; saturated 287:17; saw 211:23;220:10; saying 204:12;233:2;239:6; 244:18;255:24;256:10; 264:16;289:20;289:21; 304:7;314:16;316:13; 318:22,319:11;322:22; 331:18; Scand 212:13;223:19;224:3; scene 320:9; Schuitema's 274:10; Schuitoma 279:15;279:16; science 206:10,216:15; scientific 258:16;258:20;258:23; 258:24;259:16;291:23; 292:22;293:19;293:22; Scientist 248:7; scientists 226:2;264:5;265:8; 267:25;320:18;206:2; 206:4;206:17; scope 239:23; scoring 310:16; scotch 232:12; Scott 206:16;206:17;207:2; 207:5 ;207:7;249:13; 252:16;254:17;259:23; 261:21 ;262:3 ;320:17; script 322:20; seals 234:20;342:12; seam 313:6; searching IP ' referred - searching Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 WATER PCB-SD0000024933 TENNESSEE GAS PIPELINE CO. vs MONSANTO COMPANY 226:17:241:12: Seas 335:5; sea 214:7;225:7;255:22; 256:18;264:9; Second 211:4; secondly 330:2:21 1:3;214:9; 223:1 ;223:6;223:12; 241:25:242:3:242:8; 265:24;272:17;273:1; 284:17:291:4:291:4; 318:19;318:20;321:16; secretary 221:6:297:10:245:20; Section 297:23; sections 321:25;322:24; secure 233:20:278:17; security 230:1; seeking 329:9: seemed 289:5;302:12;322:9; oapmc 224:9;249:22;296:21; 297:14;276:18;276:19; 330:2; selected 209:18;312:10; self-instruction 237:19; seminar 315:10;315:15;316:4; 316:7;316:18 ;317:3; 318:14;320:19;323:9; sending 308:22;243:17;302:6; 309:2;312:25;314:8; 327.1;338:6; senior 263:17;332:12; sensational 293:6; sense 235:20;270:1;278:4; 283:5; sensitivity 278:12; sentence 213:20;214:9;282:13; 227:19;227:21;228:2; 23 1:2;23 1:3 ;231:8; 231:10;231:14;254:18; 280:4;280:17:307:24; 308:2;308:25 ;309:7; 309:10;309:11 ;309:13; 310:23 ;311:2;311:15; 314:5;328:14;328:14; 328:16;328:19;328:21; separate 337:8; September 271:15;271:18;315:11; 315:22;316:4;316:7; 316:19; sequence . 230:18; series 210:14; serious 297:25; served 256:8; service 247:23;271:23:272:21; 289:13;301:20;305:20; 305:20;306:3; sessions 322.-21; 199:17; setting 303:25;304:1 ;306:10; 337:14;213:2;259:1; 259:3;269:17;289:23; 292:22;301:12;304:3; 336:10;341:25; several 296:2;326:18;329:7; shake 269:24; shared 231:8;231:13;295:20; sheet 241:22;241:23; shipments 303:11;312:18;313:5; shipping 312:7;312:19; ships 274:12;277:23; shipyards 335:5:312:8; shorthand 341:23; shortly 210:19;332:6; showed 291:9;292:12; showing 244:16:287:15; shown 215:17 ;249:8;310:20; 341:21; shows 213:9;244:6;244:22; 297:25; side 263:6,328:15; sightline 207:24; signature 340:4;342:6; signed 215:7; significance 261:8;319:2;329:2; 329:17;330:6; significantly 281:16;330:1 ;307:14; silent 257:24; silicate 246:12; similarity 244:7;204:19;311:13; simple 232:6; single 284:18; situation 204:17;236:23 ;302:9; 313:17;320:2;326:14; 338:18; Six 331:13; skated 297:24; Skydraul 334:25:335:10; Sliney 308:19; slowly 201:12; smaller 204:17 ;246:11 ;288:23; 289:1 ;303:2;331:19; smile 269:24; sociable 293:5; society 258:12; Soden 262:22;263:3 ;263:4; 264:3; - solution 319:17; solvents 272:16;230:7;313:11: somebody 243:15 ;243:16;251:22; 262:2;292:9;312:7; 313:14;313:21 ;323:17; 327:22;338:9; somehow 302:7; something 223:8;226:25 ;227:1; 232:6;243:14;244:15; 244:16;249:19;275:3; 280:24;282:1 ;282:6; 286:6;289:18;297:2; 302:13 ;309:5;310:8; 314:14;318:19;325:19; 327:25;329:18; Sometime 300:18; sometimes 238:11;271:24;333:17; 252:14;252:22;309:4; 317:17; somewhat 214:1 ;225:3; somewhere 204:7;302:9;312:20; Soren 213:10;218:3;218:4; 253:14;253:19;254:23; 291:19 ;292:5; sorry 210:1;233:8;264:2; 268:15;274:17;274:23; 315:12;317:14;317:23; 322:13;324:5; - sorts 313:8;204:9;224:4; 230:22;230:23 ;233:19; 239:5;258:1;262:2; 264:20;265:6;266:5; 269:13 ;293:8 ;298:15; 304:7;312:19;314:15; 317:2;318:6;318:17; 318:22;319:5;319:10; 319:11 ;321:14;323:14; 325:18;326:19 ;327:23; 327:24;328:1;331:17; sounds . 338:4;341:17; - source 237:5,287:13;329:20; speakers 318:12,320:17; speaking Deposition of DAVID WOOD NOVEMBER 10, 1995 248:17:219:19;252:14; 272:11;279:20; specialists 259:16;247:22;279:22; 279:24;280:1; specialty 202:11;289:22; species 216:6;240:17;240:25; Specifically 238:4;296:4; specifically 210:17 ;224:12;225:21; 229:5;237:14;254:14; 304:12;305:23;318:17; 320:15;321:19;334:10; specifics 253:1 ;203:24;206:2; 219:5 ;229:24;236:24; 289:22; spectrometer 213:23 ;225:1;260:6; 291:25 ;213:22;224:18; 224:24; speculation 258:11; speed 243:13; spend 336:2;336:12; spillage 303:5;312:12; spilling 313:23; spoken 207:6;228:8;268:7; 283:4 ;207:5 ;207:7; 265:9; sponsored 338:19; sponsorship 216:14; sporadically 269:4; spread 319:21; spring 220:11;228:4;231:16; 260:1; stability 273:7;274:1 ;275:10; 284:2; stable 281:5; stack 254:15; staff 219:9 ;264:18; stage 225:18;256:4;301:20; 304:18;310:17;316:16; 326:11; standardized 325:11; Standards 337:12; standards 209:4;267:10;337:13; stands 226:23 ;226:24;229:7; 338:3; started 251:7;258:21 ;259:9; 305:1; starting 274:17; starts 21 1:4;328:23;233:23; 234:5 ;258:5;298:12; 298:13 ;313:23; State 341:1 ;341:5;341:13; 342:18; state-owned 337:7; stated 224:15;224:20;226:6; 237:22;244:12:291:24; statements 216:4;257:18;293:6; 203:24;232:11 ;233:1; 233:17 ;233:18;233:19; 236:17:296:13; States 201:21:235:23 ;25l:25; 266:6;326:18:332:24; states 213:12;213:13;214:3; 214:4;218:2;228:19; 235:2;238:4;266:7; 292:16;245:5 ;257:1; status 318:7; stay 205:2;239:13: steady 325:13; steam 313:11; step 276:24; sticker 284:16; still 199:12 ;226:14;226:16; 239:19;263:11;299:23; 305:19;310:16;311:8; 311:12;311:20;319:6; 320:14;321:14;327:23; stimulate 321:13; stipulate 295:6;296:9; stir 257:4;258:11; Stockholm 215:3:265:9; stood 315:22; stopped 269:23; story 220:17;265:17;266:5; 266:10; stowage 313:4; straight 232:10;239:3;242:22; 251;21;260:22; Strand 253:17; streams" 321:20;321:24;320:21; 320:22;320:24; Street 208:6; Strike 208:24;305:4; CtfilfM 334:11;203:9;203:20; 208:21,-210:10;217:14; 219:13 ;222:8;224:16; Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 searching - strikes WATER PCB-SD0000024934 Deposition of DAVID WOOD NOVEMBER 10, 1995 224:18;228:2l ;229:18; 254:8;274:8;289:9; 293:1 l;298:6;298:l l; 306:9;3 15:20;320:5; strong 257:25:288:19: structure 303:23:303:24; struggling 241:12; stuck 319:23; students 216:12;216:16: study 205:20;233:24;245:14; stuff 239:3 ;319:23; sub-heading 242:17; sub-title 291:1; subject 205:11 ;248:12;250:9; 271:14;280:19;287:22; 288:19;30l :9;308:19; 330:17;333:14; Subscribed 340:12; ......... subscriber 227:7; subsidiary 301:12; substances 264:7;291:12;291:19; 292:13 ;289:1; substantially 244:25; substrate 319:18; successor 240:2;242:22;243:8; sudden 288:21; suggested 307:17;310:3 ;331:6; 331:7; suggestions 304:9; suggests 275:1;305:10; suitable 291:8;342:9; summaries 216:2; summarized 290:23; summary 225:11;296:17;296:21; 297:3;297:6;297:16; 297:24;318:12; summer 212:14; sumps 313:10; supermarket 284:6; supervisor 282:2;301:10;324:24; supplying 331:10;327:2; supporting 204:20;232:1 ;258:22; 204:21 ;205:9;279:24; 302:21 ;327:11 ;334:1; supposed 284:7; supposition 216:22:219:9; Sure 239:17;261:20; sure 207:18;218:24;230:24; 236:2;242:9;243:7; 246:12;251:22;253:8; 257:12;258:2;274:24; 275:19;276:8;283:18; 306:20;307:11;308:25; 311:10;311:14;311:20; 317:9;323:2;326:21; 338:18; surface 266:20; surprise 238:10;238:10; surrounded 313:10; surrounding 317:1 ;317:4;317:13; 332:4; suspect 276:19;276:20;277:11; 309:11; suspended 305:20; ....................... Sweden 215:4;254:24;255:2; 255:5 ;257:21; Swedish 213:14;219:18;219:19; 219:21; sworn 199:2;340:12;341:19; synopsis 212:12;213:10;213:13; 213:21 ;214:4;221:12; 226:6; systematically 274:15;274:20;274:21; systemically 274:22;274:25;277:6; 277:17; systems 280:2;280:2;283:21; 283:22;283:23 ;284:3; 305:19;336:10;230:7; 232:24;272:25 ;284:4; 284:4;284:9;286:13; 302:10;325:15;326:17; "TJ. ". table 232:7;287:14; tail 267:16; taker 322:3; talked 201:20;216:5;237:9; talking 204:3;222:19;224:7; 230:25 ;236:7;237:21; 241:11 ;241:13 ;251:7; 255:17;266:5 ;281:12; 283:15 ;285:4;305:23; 309:14;309:18;312:2; 319:8;323:6;323:7; 330:14;336:3;337:5; talks 224:2;279:9;290:15; 265:14;281:23 ;319:19; 320:18;330:20;337:2; Tatton 208:11:244:25; Tatton's 243:23;244:5; team's 315:17:315:16; technical 232:1 ;247:23;267:10; 271:23;271:24;277:12; 287:3;336:17:336:23; 337:13;337:22;338:10; 338:12; techniques 232:20;234:4;258:9; 291:8; technologists 250:7; Technology 208:4; technology 206:21;206:22;208:19; 211:8;211:12;233:23; 241:7 ;247:22;260:11; 271:22;281:4;281:7; 327:22 ;336:12; telephone 204:3 ;204:8;253:11; 269:21; tells ............... 264:3; temperatures 272:14;278:7;281:16; 283:25; temporary 239:21 ;278:2; tentative 316:14; terminology 240:21; terms 225:19;258:25;288:14; 302:2;323:13;336:8; 336:16;241:9,255:5; 264:12;276:9; testified 228:7;341:21; testify 199:3 ;341:19; testimony 200:3;200:6;200:8; 200:11 ;212:20;218:20; 270:10;340:5;341:22; 341:25; testing 234:7;259:2;259:4; 260:17;319:14;319:18; 321:20;321:24; tests 233:23 ;288:19;258:7; 260:4;261:2;261:6; 261:11 ;289:5;289:16; 319:7;325:10; thanked 227:18; thanking 228:12; Thanks 324:7; thanks 227:21; theoretical 289:11; theories 240:14;240:21; theory" 217:11;217:3;217:12; TENNESSEE GAS PIPELINE CO. vs. MONSANTO COMPANY 217:13 ;217:15;241:13; Therefore 244:18; therefore 204:18;240:16;275:22; 276:21;304:19;326:24; thereto 342:3; thereupon 341:21; thermal 274:1:275:10; Therminol 276:9;276:11;281:1; 283:15 ;283:16;283:20; Therminol/santotherm 279:9; They're 208:18:293:22; they're 224:7;289:21; thinking 319:6; third 212:9 ;221:11;224:12; 291:17 ;293:13; Thompson 247:16;247:25 ;248:1; 248:11;248:I2;248:17; 285:24; thoroughly 243:16;262:4;296:14; thought 218:21 ;233:13 ;261:25; 262:1 ;264:1 ;303:22; 242:16; threat 297:19; three 199:17;199:22;268:4; 293:17;293:17;296:3; 296:5; throat 232:22; throughout 216:20; tied 303:3;311:10; tightening 304:9;323:1; times 268:4;333:15; Tinstall 294:18;296:8; tissues 240:5;240:9;209:18; 210:6; Titled 221:15; titled 213:5 ;234:19;286:21; titles 202:18;276:18;202:10; 202:20;250:11 ;263:14; Tngs 298:23; to-wit 199:6; Today 214:24;300:15; today 199:16;201:6;210:8; 254:13;266:16;320:15; 321:14; together 213:18;218:10;295:12; 342:1: told 203:20:212:21,212:22: 225:2l;228:15;231:18: 233:12;243:4;243:8; 246:23;251:9;255:1; 255:19;256:21;257:2; 260:8;262:1;265:16; 267:21 ;273:17;277:13: 291:17;292:5;292:11: 294:4;326:14;330:9; Tom 333:18; took 199:15;315:21;316:21: topics 317:20;321:24;222:18; 223:7;295:24;321:19; totally 233:3;258:4;269:2; 313:19; touched 3 19:9 ;232:9;253: L 4; 292:24; towards 214:1 ;225:4;24l :12; 246:17 ;291:18; toxicity" 231:24;232:11 ;232:12; 232:12;232:13 ;232:14; 232:15;233:9;330:20; 330:21;330:23; toxicological 233:20;233:24;257:18: 297:18; toxicology 204:22;233:15;258:5; 290:16;330:24;232:5; 232:9;232:17;233:3; 286:8;330:10;330:22; traces 297:7; trademarks 292:10;272:7;276:7; 276:10;276:12;276:13; 281:2;281:2;336:17; 336:23 ;337:22;338:12; Tran 207:14;211:20;214:19; 220:3;220:25;221:11; 222:14;224:14;226:7; 227:13 ;234:15 ;241:19; 249:5 ;254:5;262:13; 271:4;278:25 ;290:7; 301:3 ;307:2;308:9; 309:23 ;309:24;310:2; 314:24;328:9; transcribed 294:22;341:23; transcripts 200:2;200:5;340:2; 340:5;341:22;342:4; transferring 272:21 ;272:4;272:10; 272:11;272:25;273:8; 273:10;275:12;276:8; 276:10;278:6;279:22; 279:24;280:11;280:12; 281:3 ;281:24;282:5; 283:20;336:9; transformation 311:19; transformers 302:11;303:1;319:12; 248:2;286:2;287:5; 287:I5;302:14;302:16; Gore & Perry Reporting Co. St. Louis, Missouri strikes - transformers (314) 241-6750 621-4790 WATER PCB-SD0000024935 TENNESSEE GAS PIPELINE CO. vs MONSANTO COMPANY 323:5:323:8; transitioning 235:19:238:13:238:18; transportation 302:4:303:8:313:18; Trans western 200:6;200:9;285:6; trap 325:7; travel 334:18; Treavor 279:22; trial 200:3:200:6:341:10: tricks 323:13; tried 247:5; trouble 260:21:313:21; truck's 313:16;303:4;313:2; 3I3:3;313:4;313:7; 313:7:313:9:313:11; 313:13;313:18; true 340:4:342:3; truth 199:3;199:3;199:4; 341:19;341:19;341:20; trying 205:14:232:25 ;238:13; 238:16;242:9;256:1; 256:6;305:15;313:20; 319:16;338:15;226:17; 229:16;253:17;318:21; tubes 232:22; Tucker 206:16;206:17;207:5; 207:7 ;249:13 ;250:12; 250:23;251:4;252:4; 252:11 ;252:14;252:16; 252:19;252:23 ;253:6; 253:20;254:18;254:22; 255:1;255:19;256:21; 257:2;259:23;320:17; Tucker's 253:13:261:22; tune 244:2; turned 242:2; turning 238:25;240:2; two 199:17:199:22:212:24; 222:22:241:21;241:23; 241:24;257:23;265:21; 270:11;280:18;282:23; 283:1;296:4;310:11; 318:5:320:23; types 303:17; typewriting 341:24;206:4;206:10; 233:24;239:4;277:14; 281:7,311:25;312:6; 312:9;319:14;319:23; 325:3:338:7; typified 304:4; -IuT- ultimately 288:13:289:18:321:6; 286:12; unanimity 318:9; uncertainty 319:7; unclear 226:14:242:10; uncommon 216:15; unconcern 268:25; undergraduate 260:9; underlined 279:8; understood 218:18;275:19;277:19; 314:12:318:18; undertake 238:20; undertaking 228:23;239:24;302:20; 327:12; undesirable 289:1; undetermined 341:9; United 201:21:235:23 ;251:24; 266:6;326:17;332:24; universities 265:8;293:23; University 215:3; university 264:6; unknown 213:17;213:24;224:15; 224:20;225:2;291:11; 291:19:292:13; Unless 249:19;292:9; unless 242:6:336:13; unusual 269:22; up-to-date 250:13;251:4; update 318:7; upon 333:20;338:1; upper 223:3; uptake 278:2; used 211:2;229:25;232:20; 232:24;246:5;246:11; 246:13;255:4;272:9; 272:16;276:12;283:9; 283:21 ;287:7;288:9; 291:25;292:12;294:14; 303:13;304:24;305:5; 305:12;341:10; useful 258:12; users 301:23;305:12;311:8; 230:21; uses 266:25;313:8; using 210:14;213:15;224:23; 230:4;230:6;232:2; 284:1:284:3:291:6; 292:6;318:12;323:10; utility 302:9:337:6; - vV - vacations 277:2;276:25; vaguely 245:14:332:22; valid 226:19;261:17;289:5; valley 245:11;245:19;245:23; 246:1;246:22;247:2; vanalin 270:5; variance 287:21; various 207:22;216:2;296:22; 336:15; venture 334:14; verbal 256:9; version 290:8; vessel 272:15;272:18;272:24; 281:10;281:11; Victoria 208:6; viewed 318:8; views 318:4;318:10;319:17; viscosity 273:7;273:10; visited 295:11;295:22;296:1; 296:12; visiting 295:17 ;245:13 ;296:1; 334:22; vitae 23 5:18 ;237:24;239:23; 263:21;282:19; vociferous 321:3; volume 223:8; -ww- W-kerk 274:12; wagon 284:6; Wait 241:21; wait 288:24; waived 342:6; Wales 247:24;271:23; wallowed 277:25;311:25;312:2; 312:5;314:4; War 286:9; Warren 308:21; war 277:23; wastes Deposition of DAVID WOOD NOVEMBER 10, 1995 300:2;300:6;305:24; 25 1:21 ;303:8;303:11; 304:19;304:20;306:2; Water 232:23; waterways 240:16;232:15 ;232:17; 232:19;232:2l ;232:22; 3 19:25 ;3 25:9; ways 232:24;219:3;252:8; 256:10;256:14;269:10; 269:14,299:14;302:1; 304:8;322:9; Wednesday 199:20; weighted 325:12;286:5; Wenner-gren 255:15; weren't 279:18; Westinghouse 325:1 ;336:7; what's 212:16;234:23 ;284:7; 330:4;332:8; Wheeler 249:16;249:21 ;249:23; 262:20;263:24 ;263:25; 263:25;264:1;264:3; 265:16;267:2;267:18; 295:10;295:11 ;296:1; whereas 241:9; whichever 202:12; whole 199:3 ;260:1;263:5; 281:21,298:7,298:11; 336:3 ;341:19; whose 265:5; wide 336:20; Widmark 213:11;215:7;216:8; 216:10;216:22;218:2; 218:8;219:7;220:12; 221:19 ;223:18 ;225:16; 259:18;291:20;291:24; 292:12;292:18;294:5; Widmark" 221:16; Widmark's 225:12;226:6;243:1; Wilde 215:5,216:19; Wilde's 216:17; wildlife 209:18;210:12;213:14; 250:10,250:13 ;251:5; 252:1 ;252:9;265:17; 268:9 ;290:25;297:8; wished 302:2;302:13,314:12; 287:11 ;316:18;329:8; Witham 245:7;245:9 ;245:12; 245:15 ;245:19;245:23; 246:1 ;246:22;247:2; withdrawn 302:15 ;303: l; within 206:8;206:17;235:19; 236:10;237:12:258:16: 260:12;329:7; without 251:21:258:1 1 ;259:17; 260:5; Witness 340:1 ;342:12; witness? 294:1 1 ;268:21 ;3 18:1; 341:14;341:17;342:1; 342:5; woman 332:2; wonder 324:16; Wood 199:1; 199:9;199:14; 200:16;207:12 ;21 1:20; 212:5;214:17;220:1; 220:23;222:12;227:11; 234:13 ;241:15;247:10; 249:3 ;254:3;262:11; 265:11 ;265:13 ;271:2 27[:16;278:23;279:6 284:13 ;285:6;285:13 285:19;290:5;290:11 298:21 ;299:1;299:18 299:20;300:24;301:8 308:7;314:22;323:23 324:18 ;328:7;3 32:8; 340:1;340:10; wooden 313:6;313:12 ;313:12; Woods 299:13; words 222:5;267:24;294:15; 298:8; wore 278:8; working 249:23 ;272:2;278:5; 320:18;332:3;336:15; 336:22; works 315:18 ;201:21 ;203:25; 204:11 ;207:3;208:16; 209:8;216:3;221:19; 225:12 ;225:22 ;226:6 226:12;226:14;229:6 233:20;243:1 ;243:23 243:23;244:6;244:21 252:8 ;252:17;253:22 254:24;255:2;255:25 256:7 ;257:17 ;257:17 258:7;258:10;258:22 260:18 ;261:9 ;269:1; 294:4;310:20;331:5; 331:6;331:20;332:4; 336:14; World 286:9; world 281:4;288:15;3 18:9; 318:11; worn 277:14; worsened 321:14; worth 280:11; writes 274:9 ;248:11 ;254:17; 275:22; writing 216:22;258:1; Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 transformers - writing WATER PCB-SD0000024936 written - yesterday Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 WATER PCB-SD0000024937 Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 WATER PCB-SD0000024938 Gore & Perry Reporting Co. St. Louis, Missouri (314) 241-6750 621-4790 WATER PCB-SD0000024939