Document KR43Y0gOb7OJpxM3JO32VJ1NN

Page 647 1 In The Superior Court 2 Of The State Of Delaware 3 In And For New Castle County 4 -------------------------------------- x 5 Monsanto Company, : 6 Plaintiff, : 7 : Civil Action Number 8 v. : 88c-ja-118-1-cv 9 Aetna Casualty & Surety Company, : Non-arbitration 10 et al. , : Case 11 Defendants. : 12 --------------------------------------x 13 Deposition Of James R. Savage ( Volume 4 ) 14 Wilmington, Delaware 15 Friday, May 21, 1993 16 Deposition of James R. Savage, called for further 17 examination pursuant to agreement by counsel, at the law 18 offices of Smith, Katzenstein and Furlow, 1220 Market 19 Street, Fifth Floor, at 9: 20 a. m. before Kristine A. 20 O'connor, Court Reporter, when were present on behalf of the 21 respective parties: 22 - continued -- Page 649 1 CONTENTS 2 Witness Examination 3 James R. Savage ( Resumed ) 4 by Mr. Brock 650 5 by Mr. Burnett 784 6 by Mr. Brock 785 7 EXHIBITS 8 Savage Deposition Number Identified 9 Exhibit 133 - Drawing 651 10 Exhibit 134 - 4/27/71 memorandum 652 11 Exhibit 135 - Project expenditures 662 12 Exhibit 136 - 3/24/69 report 670 13 Exhibit 137 - Status memorandum 676 14 Exhibits 138 and 139 - Appendices C and D 687 15 Exhibit 140 -11/15/71 progress report 702 16 Exhibit 141 -10/14/75 memorandum 707 17 Exhibit 142 - 2/6/75 memorandum 710 18 Exhibit 143 - 10/6/70 memorandum 712 19 Exhibit 144 - 12/9/70 memorandum 716 20 Exhibit 145 - 8/7/70 memorandum 718 21 Exhibit 146 -11/11/71 meeting summary 724 22 Exhibit 147 - 5/19/66 memorandum 727 23 Exhibit 148 - June 1971 monthly report 731 24 Exhibits 149, 150 and 151 - Report documents 734 25 Exhibits 152 through 158 - Monthly reports 752 26 Exhibit 159 - 2/12/70 progress report 765 27 Exhibit 160 - 9/13/67 progress report 768 28 Exhibit 161 - 7/30/74 progress report 770 29 Exhibit 162 -11/15/71 progress report 777 30 Exhibit 163 - 9/11/67 process improvement plan 782 Page 648 Page 650 1 Appearances: James F. Burnett, Esq. 2 Potter, Anderson & Corroon 1 PROCEEDINGS 2 Whereupon, 3 James R. Savage 3 350 Delaware Trust Building 4 resumed the stand and, having been previously duly sworn, 4 902 Market Street 5 was examined and testified further as follows: 6 Examination ( Continued ) 5 Wilmington, Delaware 19801 7 By Mr. Brock: 6 On behalf of Plaintiff 8 Q Mr. Savage, let me show you a piece of paper. Is 9 this the piece of paper in which you described, you drew 7 Monsanto Company. 8 Stephen F. Brock, Esq. 9 Manta and Welge 10 out for Charlie Meyer the processes associated with the 11 Anniston waste treatment plant yesterday? 12 A Yes. 13 Mr. Brock: I just want to mark it for the record 10 One Commerce Square 11 Thirty-seventh Floor 14 and make it an exhibit. 15 Mr. Burnett: That's fine. I think there was 16 one, at least one little circle or something that Mr. Meyer 12 2005 Market Street 17 put on there and you just want to maybe make sure that the 18 witness agrees with whatever it was that Mr. Meyer put on. 13 Philadelphia, Pennsylvania 19103 19 Mr. Brock: That's fine. 14 On behalf of Liberty Mutual 20 Mr. Burnett: I forget which one it was. 21 The Witness: This little mark here described as 15 Insurance Company. 22 " lagoon/pond." Savage, James (Aroclor Dept employee) in AETNA (4) Pages 647 - 650 HARTOLDMONO010334 Page 651 Page 653 1 By Mr. Brock: 1 the Bates number of 322. First of all, can you see the 2 Q What if 1 give you a pen and you can put 2 reference up at the top in handwriting to attachment number 3 " Mr. Meyer" by it if that's not a problem? 3 1? 4 Mr. Burnett: That's fine, just so the witness 4 A Yes. 5 can verify he would put the lagoon pond in the same place. 5 Q Have you ever seen this general pile of materials 6 By Mr. Brock: 6 before? 1 mean, as you glance through you can see that 7 Q Would you put the lagoon pond in the same place? 7 page says " attachment number 1 " and the page that ends in 8 A Yeah, 1 would have represented it a little 8 Bates number 328 says" attachment number 2," and there are 9 different because what 1 remembered it as a test pond which 9 various other references to attachments. Do you recall 10 was a side stream and not part of the main flow, but it's 10 ever seeing these materials before? 11 in approximately the right place. 11 A No. The subject matter is reasonably familiar to 12 Mr. Brock: With that I'll just have it marked. 12 me, but 1 don't remember these particular documents. 13 ( Savage Exhibit 133 identified. ) 13 Q When you say " the subject matter is reasonably 14 By Mr. Brock: 14 familiar," what are you referring to? 15 Q One other cleanup thing. 1 think it was two days 15 A Mercury losses from Denora cells. 16 ago that you mentioned to me the name of Homer Broadwell 16 Q Do you recall there being attempts to identify 17 and he was a driver. What plant was he a driver at? 17 the mercury losses from the Denora cells at the Krummrich 18 A At the Anniston plant. 18 plant? 19 Q To your knowledge he would have been one of the 19 A Yes. 20 people responsible for taking materials to off-site 20 Q What do you recall along those lines? 21 disposal areas or landfills? 21 A Well, mercury is an expensive material. The 22 A Yes. Well, he would have done any kind of 22 Denora cell house at Krummrich was several times larger Page 652 Page 654 1 driving for the shipping department. It would have 1 than the one at Anniston so there was a significant 2 included that kind of thing. 2 economic impact resulting from mercury losses. And 3 ( Savage Exhibit 134 identified. ) 3 therefore, there was always a motivation to study that 4 Mr. Brock: I've marked as Exhibit 134 a 4 question and try to reduce any mercury losses we could 5 multipage document, the first page of which is dated April 5 identify. 6 27,1971. It has Bates numbers Wgk 4608315 through 6 Q Were there such studies or investigations ongoing 7 4608454. 7 when you took on your responsibilities regarding the Denora 8 By Mr. Brock: 8 operations at the Krummrich plant? 9 Q Mr. Savage, I'd like you to just glance generally 9 A 1 don't remember if they were already underway at 10 through this. If it speeds your review, 1 believe your 10 the time that 1 arrived there. 11 name appears on the page that ends in the Bates number 11 Q Let's turn to the page that ends in Bates number 12 322. Let me know when you've had a chance to glance 12 322. Up at the top there are some names. Who is R. M. 13 through that, sir. 13 Scott? 14 ( Witness reviewed the document. ) 14 A That is Roy Scott. He worked for me. 15 A Okay. 15 Q What was his position? 16 Q Do you recall generally there being an attempt to 16 A 1 think at that time he was a supervising 17 compile literature pertaining to mercury in or about the 17 engineer. 18 early 1970s time frame in association with the Krummrich 18 Q And who was J. A. Heilala? 19 plant? 19 A John Heilala was the production supervisor, 1 20 A No. I'd left the Krummrich plant in 1967. 1 20 think, of the Denora cell house. 21 don't remember literature study. 21 Q Who were C. E. Woodward and W. J. Gresham? 22 Q Let me ask you to turn to the page that ends in 22 A Cliff Woodward was an engineer in my group, 1 Savage, James (Aroclor Dept employee) in AETNA (4) Pages 651 - 654 HARTOLDMONO010335 Page 655 Page 657 1 think at that time reporting to Roy Scott. Walt Gresham 1 Q Would the same be true for the clarifier 2 was chief chemist of the plant. 2 overflow? 3 Q If you look at the problem to be addressed by 3 A 1 believe so. The clarifier was another step 4 this particular attachment, it says " To analyze the various 4 which 1 think was used to settle any undissolved material 5 water, brine, gas and caustic streams for mercury." Do you 5 in the saturated brine. 6 see that? 6 Q What would that undissolved material consist of? 7 A Yes. 7 A Rock salt contains sodium sulfate, which is 8 Q Can you identify what those streams were? And 8 commonly called gyp in this process, g-y-p, and some of 9 we'll start with the water streams from the Denora 9 that would be left behind in the saturator. Some of it 10 operations. What did those consist of? First of all, 10 would be carried along with the brine and settled out of 11 where did they go, in other words? 11 the clarifier. 12 A Well, it was a big, complicated process and I'm 12 Q Is that what the clarifier bottoms would be? 13 not sure 1 would remember all the water streams. The only 13 A 1 don't remember. It was probably a sludge of 14 obvious one to analyze would be the flow from the cell end 14 gyp and water. 15 boxes and the mercury pump tanks. 15 Q Were the clarifier bottoms disposed of somehow? 16 Q Did you say" cell end boxes "? 16 A Yes. 17 A Yes. There may have been others. 17 Q How were they disposed of? 18 Q What were the cell end boxes? 18 A 1 don't remember. 19 A Very similar to the Anniston construction. The 19 Q Number 4, would that be gyp? 20 mercury entered the cell through the inlet end box, left 20 A Yes. That's the solid material which was 21 the cell through the outlet end box and then weirs, stone 21 principally sodium sulfate, as 1 recall. Perhaps calcium 22 weirs separated the end boxes from the cell proper. 22 sulfate now that 1 think about it. Just a common impurity Page 656 Page 658 1 Q Do you know when the Denora operations at the 1 in rock salt. 2 Krummrich plant had been set up? 2 Q Was that disposed of somehow? 3 A About a year or two before 1 arrived there. 3 A Yes. 4 Around '61 or' 62. 4 Q How was that disposed of? 5 Q If you look on the page that ends in Bates number 5 A 1 don't know. 6 323, up at the top it says " The mercury level and losses in 6 Q Let's go to number 8, the sewer trap overflow. 7 Denora operations have not been determined previously." 7 What was a sewer trap? 8 Does that comport with your recollection as of about the 8 A 1 don't remember. 9 1963 time frame? 9 Q There's a reference to " mercury pit." Do you see 10 A Oh, 1 don't know. 10 that? 11 Q Let's see if we can go through the items listed, 11 A Yes. 12 the points listed in the experimental work down below. 12 Q What was that? 13 What was a saturator overflow? 13 A 1 don't know. 14 A A saturator was a large cylindrical tank with a 14 Q Number 9 is Naoh and Koh storage tanks. Do you 15 conical bottom. It was called a saturator because it was 15 recall those? 16 used to saturate the brine and salt. Solid salt would be 16 A Yes. 17 put into the top of it and depleted brine circulate through 17 Q Do you recall there being any leaks or spills 18 it. The brine leaving the saturator through an overflow 18 from those? 19 would be saturated with salt. 19 A No. That was just a finished product storage. 20 Q Is there anything else that would generally 20 Q And the'" P ' line," where it says " mercury pump 21 overflow from that other than salt? 21 tank vent to the atmosphere," what was that? 22 A It would be brine, saturated brine. 22 A 1 don't remember the term'" P ' line." The Savage, James (Aroclor Dept employee) in AETNA (4) Pages 655 - 658 HARTOLDMONO010336 Page 659 Page 661 1 mercury pump tanks were vented to the atmosphere. 1 Q What was your understanding of the fashion in 2 Q Would that vent mercury to the atmosphere? 2 which mercury was leaving? 3 A There should have been no flow in that line. It 3 A For instance, in the water from the end boxes. 4 was just to allow thermal breathing, but whatever vapor was 4 Q Any other ways that you recall? 5 in that line would be, 1 think, would contain mercury 5 A It was not unusual to find some mercury in the 6 vapor. 6 bottom of caustic storage tanks. That would not go to soil 7 Q Do you recall there being any claims or 7 or water, though, because we would check from time to time, 8 complaints to the effect that Monsanto had been releasing 8 draw it off and put it back in the process. 9 mercury to the atmosphere, including soil or water from the 9 Q The release of water from the end boxes or the 10 operations at the Krummrich plant? 10 release of water and whatever materials was in the water 11 A No. 11 from the end boxes, how frequently would that take place? 12 Q You had the understanding during the time you 12 A That was continuous. 13 worked at the Krummrich plant that mercury was a toxic 13 Q Do you recall there ever being concerns expressed 14 chemical; is that correct? 14 that any mercury being released from the Krummrich plant 15 A Yes. 15 could be causing damage to property or organic life? 16 Q Did you have the understanding that mercury had 16 A 1 think perhaps in the context of a larger 17 been known to be a toxic chemical for quite some time? 17 concern at some point in the ' 60s, 1 believe mercury had 18 A Yes, it's the classic case in toxicology. 18 been identified in fish in various parts of the world and 19 Q Are you aware of anyinvestigationsubsequent to 19 the mercury process for chlorine and caustic had been 20 the 1965 time frame into the question of whether mercury 20 implicated as a source of that mercury. And so at 21 was being released from the operations of the Krummrich 22 plant into the air, soil or water? 21 approximately this time, anyone who had a mercury cell 22 house became concerned about the subject, began to Page 660 1 A The subject was investigated at various levels of 1 investigate it more carefully. Page 662 2 intensity almost all the time. It was somewhat confused by 3 the fact that at about this time there were some 4 substantial thefts of mercury from the plant and the true 2 Q Do you recall whether there were any contacts 3 with regulatory agencies concerning possible mercury 4 releases at the Krummrich plant? 5 inventory and the fate of what might be missing was the 5 A 1 don't remember. 6 subject of some concern. 6 Q Were there process changes instituted as a result 7 Q When you say it was being investigated at various 7 of the concern about mercury in fish? 8 levels all the time, who was doing the investigation? 8 A 1 believe there were at some point, but 1 don't 9 A Typically the production supervisor or foreman 9 remember what they were. 10 with assistance from Tsd is required. 10 Q Do you recall how you learned about the concern 11 Q Did you have any involvement in those 11 about mercury in fish in the 1960s time frame? 12 investigations? 12 A 1 don't remember specifically, but it was being 13 A Not direct. The engineers reporting to me worked 13 mentioned in the industry literature. 14 on that subject and 1 may have given them some advice. 14 Q Do you recall of any reports or memoranda or 15 Q Do you recall it ever being reported to you that 15 correspondence within Monsanto concerning -- 16 mercury was being released from the Krummrich operations to 16 A 1 think there were such reports and memorandums, 17 the soil or water? 17 but 1 don't remember them specifically. 18 A Well, it was evident from the fact that it was 18 ( Savage Exhibit 135 identified. ) 19 necessary to continue adding mercury to the cells just as 19 Mr. Brock: I've marked as Exhibit 135 a 20 it had been at Anniston. And since there's no chemical 20 multipage document with Bates numbers Wgk 5001575 through 21 mechanism for consumption of mercury within the process, 21 579. 22 it's evident that mercury was leaving in some fashion. 22 By Mr. Brock: Savage, James (Aroclor Dept employee) in AETNA (4) Pages 659 - 662 HARTOLDMONO010337 Page 663 Page 665 1 Q My first question, Mr. Savage, is just whether or 1 the Krummrich plant? 2 not you recognize the form of this document? 2 A No. 3 A It's just a tabulation. 1 don't recognize it as 3 Q Are you familiar with something called the " Route 4 any specific point. 4 3 drum site "? And for your reference I'll refer you to 5 Q Up at the top of the first page you can see 5 what we had previously marked as Exhibit 91 and there's a 6 there's a reference to " 1989 environmental remedial action 6 description of a Route 3 drum site on the second page. 7 project expenditures." Do you see that? 7 A 1 know where Route 3 is, but 1 don't remember a 8 A Yes. 8 site with that name. 9 Q Is the term " Erap " familiar to you? 9 Q Are you familiar with any area west of Route 3 to 10 A I've heard it, but 1 don't remember what it 10 which Monsanto took materials from the Krummrich plant for 11 stands for. It seems to stand for the heading of this 11 burial? 12 report. 12 A No. 13 Q That's right. Do you recall having any 13 Q Do you have an understanding or belief as to who 14 involvement in the preparation or generation of Erap during 14 would be knowledgeable on that subject? 15 your tenure with Monsanto? 15 A Perhaps plant management or the shipping 16 A The date of this report is long after I'd left 16 department. 17 manufacturing. 17 Q On the next page of Exhibit 135, the second page 18 Q Have you ever seen this before? 18 of that, the Erap number 17 refers to a landfill study 19 A 1 don't remember it. 19 program. Are you familiar with any landfill study program 20 Q The reference to a " Rivers Edge lawsuit." Are 20 that was going on in the 1989 time frame? 21 you familiar with a Rivers Edge lawsuit in connection with 21 A No. 22 the Krummrich plant? 22 Q Do you have a belief as to who within Monsanto Page 664 Page 666 1 A No. 1 would be knowledgeable about such a program associated 2 Q Are you familiar with any Wgk landfill mitigation 2 again with the Krummrich site? 3 costs associated with the Krummrich plant? 3 A Well, it would be someone who was at the 4 A 1 had heard that there was a project like that, 4 Krummrich plant in this time frame. 1 don't know who that 5 but 1 didn't have anything to do with it. 5 would be. 6 Q Can you tell me what you heard about that 6 Q 1 had asked you about Anniston. Are you familiar 7 project? 7 with any lawsuits alleging pollution or contamination from 8 A Only that it existed. 8 the operations of the Krummrich plant? 9 Q Do you recall who it was that you heard from? 9 A No. 10 A No. 10 Q For example, had you ever heard of a lawsuit by 11 Q 1 take it you had no involvement in setting up 11 the state of Illinois against Monsanto sometime in the 12 reserves or cost matters with respect to that project? 12 early 1980s? 13 A No. 13 A 1 think there may have been some bulletin board 14 Q Did you hear about any project regarding lagoons 14 announcements about some legal action between Monsanto and 15 in pits associated with the Krummrich plant at around this 15 the state of Illinois that was posted at the general 16 timeframe? 16 office. But 1 don't remember any more than that. 17 A No. 17 Q While we have Exhibit 91 in front of us, let me 18 Q Let's go to the projects down below. Are you 18 ask you about some of the areas referenced. On the first 19 familiar with a project regarding contaminated soil that 19 page there's a description given for Rivers Edge Landfill 20 was ongoing in the 1989 time frame? 20 and 1 think you said you weren't familiar with the lawsuit 21 A No. 21 relating to that. Are you familiar with that area as 22 Q What about wastewater monitoring associated with 22 described in Exhibit 91? Savage, James (Aroclor Dept employee) in AETNA (4) Pages 663 - 666 HARTOLDMONO010338 Page 667 Page 669 1 A 1 don't think 1 ever visited there. 1 Q What leads you to believe that that's your 2 Q Down below in the second paragraph there's a 2 recollection? 3 reference to chlorobenzenes and aniline derivatives being 3 A It was just kind of part of the folklore at the 4 detected in monitoring wells there. 4 plant. 5 A Yes. 5 Q What area of the plant do you believe that that 6 Q Were you familiar with chlorobenzenes or aniline 6 part of Dead Creek passed under? 7 derivatives being taken to a landfill from the Krummrich 7 A 1 don't remember. 8 site? 8 Q Do you recall seeing a creek on the Cerro Copper 9 A No. 9 Company's property? 10 Q Some of these areas we've already covered so 10 A No. 11 let's go to site H, which is on the fourth page of the 11 Q Do you recall or are you familiar with a creek 12 document. Can you just read through the description given 12 lying between Queeny Avenue and Judith Lane in Sauget and 13 for that site and let me know whether you're familiar with 13 Cahokia, Illinois? 14 that area. And again, for your reference there's a map on 14 A No. 15 the last page of the exhibit. 15 Q Had you ever heard or learned that Monsanto was 16 ( Witness reviewed the document. ) 16 claimed to have -- let me strike that question. 17 A No. 17 Do you recall there being any times in which it 18 Q Were you familiar with the Cerro Copper Products 18 was claimed that the portion of Dead Creek that flowed on 19 property? 19 to the Monsanto plant had been polluted or contaminated? 20 A Only to the extent in driving to work 1 would go 20 A No. 21 past the site which, at the time 1 worked there, had a sign 21 Q That's all you knew about Dead Creek, was that -- 22 out front that said Cerro Copper. That's all. 22 A Yes. Page 668 Page 670 1 Q My understanding is that was adjacent to the 1 Q You heard that part of it flowed under the 2 Monsanto property ; is that correct? 2 Monsanto plant? 3 A 1 believe that's right. 3 A Yes. 1 may have seen that on a map of the 4 Q Are you familiar with any claims or allegations 4 Monsanto plant. 5 by the Cerro Copper Company that Monsanto had somehow been 5 ( Savage Exhibit 136 identified. ) 6 causing contamination to its property or the soil or ground 6 Mr. Brock: I've marked as 136 a multipage 7 thereunder? 7 document with Bates numbers Wgk 3012314 through 366. 8 A No. 8 By Mr. Brock: 9 Q Are you familiar with site K as described in the 9 Q Mr. Savage, once you've had a chance to generally 10 exhibit? 10 glance through the document, could you let me know. 11 A No. 11 ( Witness reviewed the document. ) 12 Q What about site L, the surface impoundment? 12 A Okay. 13 A No. 13 Q You can see that you're listed as a copy 14 Q Let's skip to the numbers 10 and 11 for the 14 recipient on the second page ; is that correct? 15 nonowned site, Dead Creek sector A and Dead Creek sector 15 A Yes. 16 B. Were you familiar with Dead Creek? 16 Q Does that indicate to you that you received a 17 A 1 remember that term. 17 copy of this report in or about the 1969 time frame? 18 Q Did you ever go to Dead Creek? 18 A Yes. 19 A It's my recollection that there was a portion of 19 Q Do you recall there being an investigation into 20 Dead Creek that passed through the main part of the plant 20 the continuous production of paranitroaniline around this 21 and it was underground in a storm sewer. 1 may be mistaken 21 time frame? 22 about that, but that's all 1 remember about Dead Creek. 22 A Yes. Savage, James (Aroclor Dept employee) in AETNA (4) Pages 667 - 670 HARTOLDMONO010339 Page 671 Page 673 1 Q Can you tell me what you recall about that? 1 Pncb per 100 pounds of Pna must be disposed of in this 2 A During the time that 1 was at the Krummrich plant 2 manner." Does that comport with your recollection of the 3 paranitroaniline was made batchwise, and at that time 3 general ratio of Pncb residue produced per amount of Pna 4 Mr. Fields was working on the paranitroaniline process and 4 produced? 5 we reached the conclusion that it would be feasible to 5 A 1 don't remember. 6 develop a continuous process. And it was to some extent my 6 Q Pncb was a residue ; correct? 7 initiative when this investigation started. By the time of 7 A Pncb was the main raw material. The expression 8 this report 1 was at the Queeny plant and Mr. Fields had 8 " unreacted Pncb " means that that's the part that was not 9 continued to work on a new process. This report reflects 9 converted. 10 the conclusion of that work. 10 Q So the 2 to 2.5 pound reference to Pncb, would it 11 Q So you initiated this during the time you were at 11 be your understanding that refers to unreacted Pcb that had 12 the Krummrich plant? 12 to be disposed of? 13 A Yes, together with some others. 13 A Pncb. 14 Q What others, if you recall? 14 Q Pncb, I'm sorry. We've talked so much about 15 A Well, for such a piece of work to begin, it 15 Pcbs. 16 essentially was a very large project, it would have 16 Do you know whether unreacted Pncb was disposed 17 required the approval of whoever was the technical 17 of at the toxic dump in association with the batchwise 18 production manager at the time. I'm not sure who that was 18 production of Pna at the Krummrich plant? 19 because those people changed several times. 19 A 1 believe so. 20 Q When you say you would have initiated this with 20 Q Do you know whether the ratios of unreacted Pncb 21 some others during your tenure at the Krummrich plant, 21 that had to be disposed of to the toxic dump or the 22 would that have been during the later period as production 22 percentage of that to the Pna produced changed from the 1 superintendent? Page 672 1 batchwise process to the continuous process? Page 674 2 A 1 was a Tsd superintendent. It would have been 3 during that time. 4 Q Can you tell me what the impetus was for the 2 A 1 presume it changed somewhat, but 1 don't 3 remember. 4 Q This document, the first two pages reference a 5 initiation of this project? 5 tentative process for the continuous production of Pna. Do 6 A We thought it would be a more economical 6 you recall whether this process was implemented? 7 process. 1 don't remember the details. 7 A Yes. The plant was built. 8 Q Do you recall whether it resulted in any changes 8 Q Was that after you left the Krummrich plant? 9 in waste disposal methods associated with the Pna 9 A Oh, yes. It was after this report. 10 operations? 10 Q True. Do you recall generally when it was that 11 A 1 think it was our intention to redesign the 11 that permanent plant was implemented, when it began 12 whole process, which would have included anything that 12 operations? 13 related to waste. 13 A No, it wasn't a long time after this report. 14 Q Let me turn you to the last page of the exhibit. 14 Q Let's turn back to the last page and up at the 15 That has a heading of" pollution control." Do you see 15 top that talks about the " sewering of Ammonia and Ammonium 16 that? 16 compounds." Were you familiar with the sewering of those 17 A Yes. 17 materials from the Pna operations at the Krummrich plant? 18 Q The last paragraph states " Unreacted Pncb must be 18 A 1 was aware of it. 1 don't recall that 1 was 19 drummed off and disposed of in the toxic dump." Do you see 19 familiar in detail, but 1 was aware of it. 20 that? 20 Q Do you know where the sewers from the Pna 21 A Yes. 21 operations went? 22 Q And it gives a figure of" From 2 to 2.5 pounds of 22 A They went into the general plant sewers. Savage, James (Aroclor Dept employee) in AETNA (4) Pages 671 - 674 HARTOLDMONO010340 Page 675 Page 677 1 Q Are you familiar with any occasions on which 1 at the top on the right-hand side there's a date stamped on 2 those sewers, in which there was found to be leakage from 2 of January 29, 1974. Do you see that? 3 any of those sewers? 3 A Yes. 4 A No. 4 Q What responsibilities did you have in that time 5 Q Do you recall there being any complaints about 5 frame for the status of St. Louis wastes to landfills? 6 the discharge of ammonia or ammonium compounds from the 6 A 1 was manufacturing manager for specialty 7 sewers in the Pna operations? 7 products. Some of our products were made at the Queeny and 8 A There were complaints within the plant from 8 Krummrich plants and to the degree that they generated 9 operators in other departments. 9 material that was going on the landfill, it would be up to 10 Q What were the nature of those complaints? 10 me to sponsor whatever technical effort or project 11 A Well, the smell of ammonia is quite unpleasant 11 expenditure was required to alleviate the problem. 12 and if ammonia-bearing water in the sewers would meet 12 Q When you say " the landfill," what landfill are 13 alkaline water coming from another department, the result 13 you referring to? 14 would be that ammonia gas would be released in the sewers 14 A Even at that time 1 don't recall being familiar 15 and come out into areas where people were working. 15 with the physical location of a landfill. But the issue of 16 Q Did that happen from time to time? 16 " the landfill" had been identified by the manufacturing 17 A Yes. That was a source of the complaints. 17 organization as a problem. We were instructed to stop 18 Q When did you learn of those complaints? Was it 18 sending material to the landfill and therefore we were 19 during your time at the Krummrich plant? 19 doing the things described in this memo. 20 A Yes. 20 Q When you say " the landfill," are you referring to 21 Q How frequently would that happen? 21 the landfill associated with the Krummrich site? 22 A 1 don't remember. 22 A It's my understanding that that was administered Page 676 Page 678 1 Q Do you recall there being any injuries claimed as 1 by the Krummrich site. 2 a result of that? 2 Q When this document is talking about St. Louis 3 A 1 don't remember if there were. 3 wastes to landfill, is it referring to St. Louis wastes to 4 Q Do you recall any people outside of Monsanto, for 4 the landfill associated with the Krummrich site? 5 example, neighboring companies or properties, complaining 5 A Yes. 6 about releases of ammonium gas? 6 Q When you say the issue of that landfill had been 7 A No, 1 don't remember that. 7 identified as a problem, what do you mean by that? 8 ( Savage Exhibit 137 identified. ) 8 A 1 don't remember where the impetus came from. 1 9 Mr. Brock: 1 have marked as 137 a one-page 9 just recall that we had to stop sending material to that 10 document with the Bates number 0091170 Pep. 10 landfill. 11 By Mr. Brock: 11 Q Do you recall what the nature of the problem was 12 Q Mr. Savage, could you let me know when you've 12 then identified by the 1974 time frame? 13 looked through the document? 13 A No. 14 A Some of it is pretty hard to read. 14 Q What was your understanding of why -- the reason 15 Q 1 agree. 15 Monsanto had to stop sending wastes to that landfill? 16 ( Witness reviewed the document. ) 16 A 1 don't remember. 17 A Okay. 17 Q At around that time frame had you heard or 18 Q Is this a memorandum that you wrote concerning 18 learned of any claims of migration of chemicals or leakage 19 " St. Louis Wastes to Landfill" in connection with your 19 from that landfill? 20 employment with Monsanto? 20 A I'm not sure 1 can connect all of what you said 21 A Yes. 21 into one answer. 1 had heard just as kind of a grapevine 22 Q 1 agree that some of it is not easy to read. Up 22 thing that there was seepage from a landfill that Monsanto Savage, James (Aroclor Dept employee) in AETNA (4) Pages 675 - 678 HARTOLDMONO010341 Page 679 1 had used on the bank of the Mississippi River, but whether 2 that was the landfill that we were using at the time of 3 this memo, 1 don't know. 4 Q Do you recall the general time frame that you 5 heard that through the grapevine? 6 A No, 1 don't. 7 Q Do you recall, for example, whether it was in the 8 ' 70s or the ' 80s, that type of thing? Page 681 1 Q Who was Roger Beal? 2 A Our business group accountant at that time. No, 3 he was, 1 think his title was planning manager, planning 4 and control manager or something like that, or manager of 5 planning control. 6 Q What type of responsibilities did he have? 7 A Financial planning. 8 Q Do you recall why you copied Mr. Beal on this 9 A 1 think the ' 70s, but 1 don't know. 10 Q Did you have any -- 11 A It wouldn't have been the ' 80s because 1 had 9 type of memorandum? 10 A He would have been at that time responsible for 11 tracking capital expenditures and the possibility of 12 nothing to do with manufacturing by that time. 13 Q Did you have any responsibilities for dealing 14 with that situation at the time? 15 A No. 16 Q Your memo talks about a July 1 deadline on 17 hauling of residues to the landfill from Queeny and 18 Krummrich. Do you know what that refers to? 19 A 1 just remember there was one. 1 don't remember 20 who imposed that deadline or for what reason. 21 Q And there are two types of wastes identified as 22 major contributors? 12 earnings or nonearnings projects. Since this memo 13 describes a couple of such projects, it would have been a 14 concern to him. 15 Q Who was R. M. Kountz, K-o-u-n-t-z? 16 A Bob Kountz was our engineering manager. 17 Q Do you know whether he had responsibilities 18 regarding landfills to which Monsanto sent materials? 19 A Not directly. The reason for copying him on a 20 memo like this was if the contemplated projects were larger 21 than projects that could be handled at the plant, it would 22 be up to him to organize those projects in the engineering Page 680 Page 682 1 A Yes. 1 department. 2 Q Can you identify for me what the first one is. 2 Q There's a statement in the memo and it's in the 3 A The heading is " Ee Building." The double E 3 third paragraph that" We also must further reduce phenol 4 building was a facility to Queeny plant where we made 4 loading to the sewer over the next 2-3 years." Do you see 5 phosphate esters. 5 that? 6 Q What were the wastes from that building? 6 A Yes. 7 A The waste described here is a phenol residue. 7 Q What was the reason for that? 8 Q What form did that take? 8 A The Queeny plant had had a program for reducing 9 A As 1 recall it was a heavy liquid. 9 phenol loads to the sewers that had really been instituted 10 Q What is Penta wastes referred to in the memo? 10 during my time at the Queeny plant in the late ' 60s, and it 11 What does that refer to? 11 had been reasonably successful, but the plant saw a 12 A Penta was our trade name for pentachlorophenol, 12 necessity to continue to further reduce that load. 13 which our business group sold at the time, which was 13 Q You said that you were aware of the issue 14 manufactured at the Krummrich plant. 14 concerning the landfill referring to the Krummrich 15 Q So the reference in the memo to penta wastes, 15 landfill. Were you at this time aware of similar issues 16 does that refer to wastes from the Krummrich plant? 16 regarding other landfills used by Monsanto? 17 A Yes. 17 A 1 don't know what 1 was aware of at that time. 1 18 Q What form did that waste take? 18 have been aware of landfill issues at various plants at 19 A 1 don't remember. 19 various times. Again, just kind of a general knowledge of 20 Q There's a person named Beal up at the top. Do 20 what was going on in the company. 21 you see that? 21 Q Can you describe for me, when you say" landfill 22 A That's Roger Beal. 22 issues," what are you referring to? Savage, James (Aroclor Dept employee) in AETNA (4) Pages 679 - 682 HARTOLDMONO010342 Page 683 Page 685 1 A Well, in recent years Superfund issues, which of 1 A Well, in general the standard for landfills had 2 course are well known when they arise because they 2 been tightened up. 3 represent a lot of money. 3 Q Were you aware of standards for landfills during 4 Q What about in earlier years? 4 your time as manufacturing manager? 5 A Well, this memo is an example of being aware of a 5 A Not specifically. It's not a subject that 1 had 6 landfill issue. 1 really can't pinpoint any others. 6 any particular expertise in. 7 Q What Superfund issues are you aware of with 7 Q Did you have dealings with somebody who was more 8 respect to landfills used by Monsanto? 8 knowledgeable on that subject? 9 A Just very recently an engineer or a manager who 9 A Well, the people at the plant had investigated 10 worked for me transferred to Texas to become manager of the 10 what was required and at that time described that landfill 11 Brio site. 11 to me in general terms. And while 1 had been up in that 12 Q What other Superfund issues did you become aware 12 general area in previous years, 1 can't make any particular 13 of? 13 connection between the two. 14 A 1 can't even specify what they are, but it was 14 Q When you say" the people at the plant," what 15 bulletin board kind of stuff. Things that Monsanto was 15 plant was this? 16 involved in. 16 A This was at the Anniston plant. As 1 recall, 17 Q During the time that you were manager of 17 Bill Tafey led that effort. 18 manufacturing, do you recall what the landfill issues were 18 Q Do you recall whether Mr. Tafey was familiar with 19 that you were aware of? 19 landfill standards around that time frame? 20 A The only one that occurs to me right now was at 20 A 1 presume that he had made himself familiar. 21 Anniston. While 1 was manufacturing manager for specialty 22 products, the Anniston plant decided to put a fence around 21 Q Do you recall anybody at the Krummrich or Nitro 22 plants who were familiar with the landfill standards around Page 684 Page 686 1 the property on the other side of the highway and it was a 1 that time frame? 2 project, 1 believe, to upgrade that landfill that required 2 A We certainly had pollution specialists at both 3 my approval or sponsorship. 3 those plants at that time. 1 presume that they would have 4 Q What's your understanding of the reason for 4 been familiar with such standards, but 1 don't know who it 5 putting a fence around that landfill? 5 would be. 6 A It was deemed desirable to prevent public access 6 Q Did you have dealings with the pollution 7 to it. 7 specialists at the Nitro plant during that time frame? 8 Q Why was that? 1 mean, why was it deemed 8 A Not directly. 9 desirable to prevent public access? 9 Q What about indirectly? 10 A 1 think some people were still using the rifle 10 A During my time as manufacturing manager, during 11 range in an unauthorized way. 11 part of that time 1 had responsibility for paper chemicals 12 Q Following your example? 12 which for part of the existence of that business group, 13 A Yes. 13 paper chemicals had been among the specialty products. So 14 Q Do you recall what the impetus was for the 14 as a manufacturing manager 1 traveled to Nitro from time to 15 decision to upgrade that landfill? 15 time to review operations. 16 A No. I'm sure it was explained to me at the time, 16 Q I'm going to come back to Nitro later. Sticking 17 but 1 don't remember. 17 with Krummrich for the moment, were you familiar with the 18 Q What did you mean by" upgrade "? 18 closure of the Krummrich landfill in or about the late 19 A 1 think to put a clay cap on parts of it that may 19 1970s? 20 have been uncovered. 20 A I'm not familiar with it. I'm aware of it. 21 Q Why was that deemed a desirable thing to do at 21 Q When you say you're aware of it, how did you 22 the time? 22 become aware of it? Savage, James (Aroclor Dept employee) in AETNA (4) Pages 683 - 686 HARTOLDMONO010343 Page 687 Page 689 1 A Somebody told me. 1 organization? 2 Q Did you have an understanding as to why it was 2 A Yes. 3 being closed? 3 Q Do you recall what the impetus was for 4 A No. 4 determining the quantity of waste material sent to sanitary 5 Mr. Brock: Off the record. 5 landfill around that time frame? 6 ( Discussion off the record. ) 6 A No. 7 ( Savage Exhibits 138 and 139 identified. ) 7 Q Do you recall whether there was any particular 8 Mr. Brock: I've marked Exhibits 138 and 139 for 8 event that motivated Monsanto's coming up with this 9 the record. For the record, these appear to be -- 138 is 9 inventory? 10 an appendix C and 139 is an appendix D. The Bates numbers 10 A No, this seems to be a routine survey. It 11 appear to be sequential so these are not necessarily two 11 describes the previous 12-month period. 12 separate documents. They may be part of one document, but 12 Q When you say" routine," were these conducted on 13 1 thought it would be clearer to mark them separately. The 13 some sort of routine schedule? 14 Bates numbers of 138 are K&e 0019057 through 071 and the 14 A 1 don't remember. 15 Bates numbers of appendix D are K&e 0019072 through 9116. 15 Q Let me turn you back to the first page of the 16 By Mr. Brock: 16 exhibit. There's a reference to an October 27, 1975 memo 17 Q Mr. Savage, could you first just glance through 17 concerning the lepa landfill inspection, and that's the 18 exhibit C or appendix C, Exhibit 138. And if it speeds 18 first document in the appendix. Do you recall generally an 19 your review, 1 believe your name is referenced on the page 19 Illinois Epa inspection of the Krummrich landfill in or 20 that ends in the Bates number the K&e Bates number of 069. 20 about the 1975 time frame? 21 ( Witness reviewed the document. ) 21 A No. 22 A Okay. 22 Q Earlier 1 had showed you a memorandum that you Page 688 Page 690 1 Q Let's start -- or do you see your name referenced 1 wrote that was in 1974. And you said during that time you 2 on that page, the page ending in Bates number 069 under the 2 were aware of certain landfill issues. During the 1974, 3 " John F. Queeny Plant," the second column? 3 ' 75 time frame did you have any understanding that the 4 A Yes. 4 Illinois Epa had expressed concerns relating to potential 5 Q If you look up above the date on that particular 5 pollution from the Krummrich landfill? 6 page is July 24 and it appears to be 1968. Do you see 6 A 1 don't remember. 7 that? 7 Q Let's go to the pages that end in Bates numbers 8 A Yeah, that looks right. 8 060 to 062. 9 Q What, if any, responsibilities did you have in 9 A Okay. 10 the 1968 time frame for waste disposal at sanitary 10 Q And that's a listing of waste materials disposed 11 landfills? 11 of at the Monsanto/sauget landfill site ; is that correct? 12 A 1 was general superintendent of technical 12 A Yes. 13 services and lab at the Queeny plant at that time. 13 Q Can you tell me which of these wastes you're 14 Mr. Solari worked for me and Mr. Nemeth worked for 14 familiar with. For example, stabilizing residue, are you 15 Mr. Solari. Mr. Nemeth is the author of this report. My 15 familiar with that? 16 responsibility was a general one. 1 had all the old 16 A No, 1 don't know what that is. 17 technical organization of the plant under me and the 17 Q What about spent vanadium catalyst, are you 18 pollution control group is part of that. 18 familiar with that? 19 Q When you say" technical organization of the 19 A 1 have a rough idea of what that is. 1 think 20 plant," what plant? 20 that refers to catalyst from the manufacture of sulfuric 21 A Tsd at the Queeny plant. 21 acid. 1 was never associated with that operation. 22 Q And the Queeny plant also had a pollution control 22 Q Would that be at the Krummrich plant? Savage, James (Aroclor Dept employee) in AETNA (4) Pages 687 - 690 HARTOLDMONO010344 Page 691 Page 693 1 A Yes. 1 just go through the list and tell me which of these you're 2 Q What about vacuum distillation residues, where 2 familiar with and what operations they would be from. 3 would that have come from? 3 A We got down through number 6. Number 7 might 4 A Let me back up a second. I'm familiar with two 4 have come from anywhere. 1 don't know what that is. 5 kinds of vanadium catalyst. There's the one that's used 5 Number 8 is chlor-alkali sludge. We discussed that 6 for sulfuric acid. There's also a catalyst that's used in 6 earlier. Number 9, 1 don't know what that is. 7 the manufacture of maleic anhydride which contains 7 Q The chlor-alkali sludge, just so I'm clear, that 8 vanadium. Maleic anhydride was manufactured at one time at 8 would be from the Denora operations? 9 the Queeny plant. That was stopped a long time ago. But 9 A That might have been from either Denora or from 10 it's possible that vanadium catalyst might refer to either 10 the Hooker cells. Although 1 believe at the time that this 11 one of those. 11 was written, the Hooker cells had been by then shut down. 12 Q What about vacuum distillation residue, are you 12 Q Okay. 13 familiar with that? 13 A 1 don't know what the filter mud, 9, is. The 14 A From the composition described, 1 would presume 14 number 10, 1 think came from a department of Krummrich that 15 that had to do with the rubber chemical operation. That's 15 used phenacetin. That was a raw material, but 1 don't 16 the only place 1 know of that potassium carbonate was used. 16 remember what it was. Number 11, still residue, mentions 17 Q Would that be at the Krummrich plant? 17 methyl salicylate. That was the Queeny plant. Number 12 18 A Yes. 18 is the Queeny plant. Number 13 is Queeny plant. Also 19 Q What about phosphate ester residues, where would 19 number 14. 1 don't know what number 15 is. 20 those have come from? 20 Q When you said " also number 14," you mean from the 21 A Possibly either Queeny or Krummrich. Phosphate 21 Queeny plant? 22 esters were made at both plants by different processes. 22 A Yes. Number 15 1 don't recognize. Number 16 is Page 692 1 They were different processes and different esters. The Page 694 1 the Queeny plant. Number 17 1 don't know. Number 18 1 2 term " phosphate ester residue " implies a still residue 3 which would imply a Krummrich source because there was a 4 distillation step at Krummrich and not at Queeny. 2 don't know. Number 19 1 don't know. Number 20 1 think is 3 Queeny plant. Number 21 is Queeny plant. Number 22 1 4 don't know. Number 23 is Queeny plant. 5 Q Generally do you recall how this information was 6 come up with? 7 A 1 have no idea. 8 Q The memo that precedes that list appears to have 9 been written by a Robert L. Harness. Do you recall 10 Mr. Harness? 11 A 1 knew him. He was in the pollution group at 12 Krummrich, but 1 think it was after 1 was there. 13 Q Do you know whether he's still alive? 14 A 1 believe he's still involved in pollution work 15 at Monsanto. 16 Q Is that at the Krummrich plant? 17 A No, 1 don't think so. 18 Q What is " Phosphorus Pentasulfide-scrap Product"? 19 A 1 don't know what the scrap is. There was a 20 department at the Krummrich plant that made phosphorus 21 pentasulfide. 22 Q Let's see if we can do it this way. Ifyou could 5 Q Do you know any method by which any of these 6 materials would have been taken to the Krummrich landfill 7 other than being trucked and dumped in the landfill? 8 A 1 know 1 don't know any other way. 9 Q Do you recall ever seeing this appendix before? 10 A No. 11 Q Let's go to Exhibit 139, the appendix B. Do you 12 ever recall seeing that before? 13 A No. 14 Q Let me ask you to turn to the Bates - the page 15 with the Bates number that ends in 9106. 16 A Okay. 17 Q Do you see your name referenced or at least part 18 of your name referenced up in the top right-hand corner? 19 A Yes. 20 Q Does that indicate to you that you received a 21 copy of this in or about 1970 ; is that correct? 22 A Yes. Savage, James (Aroclor Dept employee) in AETNA (4) Pages 691 - 694 HARTOLDMONO010345 Page 695 1 Q Do you recall being involved in a determination 2 of the volume and disposal costs of all Wgk solid chemical 3 wastes disposed of at the Wgk landfill around this time? 4 A 1 believe this report was addressed to me in 5 error because it's dated August of 1970 and by that time 1 6 was no longer at the Queeny plant. This apparently was 7 addressed to me at the Queeny plant. 8 Q Do you recall generally there being a solid waste Page 697 1 S-p-r-a-n-d-e-l? 2 A Lou Sprandel was an engineer at the Krummrich 3 plant. He was, as 1 recall, the head of the plant 4 improvement group. 5 Q During what time frame? 6 A Certainly during the time that 1 was at Krummrich 7 plant and for some period of time after that. 8 Q Do you know whether he's still alive? 9 disposal survey of this type in or about the 1969 time 10 frame? 11 A No. 9 A No, 1 don't. 10 Q There's a heading for" Interviews." Were you 11 familiar with people being interviewed concerning the 12 Q If you look through the information on that page 13 and the next two pages, do you know how that information 14 was come up with? 15 A No. This is Krummrich plant work and 1 had left 16 there in 1967. 17 Q Fair enough. Did you review these types of 18 materials while you were manufacturing manager? 19 A Only if it posed some particular issue for our 20 business group's operation. 21 Q Do you recall any landfill issues posing 22 particular issues for the business group operations under 12 nature of materials taken to the Krummrich landfill? 13 A No. 14 Q And there's a statement in the second paragraph 15 " Prior to landfill material was dumped on the 16 W. G. Krummrich Plant site." 17 A Yes. 18 Q Were you familiar with materials being dumped on 19 the Krummrich plant site? 20 A No, but Mr. Sprandel was at the Krummrich plant 21 for many years before 1 was. 22 Q Do you know what the F parking lot is? 1 your purview? Page 696 1 A No. Page 698 2 A We previously talked about the closure of the 3 landfill which resulted in our having to take some steps to 4 eliminate some materials that had been going there. Other 2 Q There's a reference to " P4, phenol, Oncb were 3 dumped there." Are you familiar with any dumping of those 4 materials? 5 than that, 1 don't remember anything. 6 Q Do you recall dealing with Mike Pierle or 7 Clarence Buckley concerning materials going to the 8 Krummrich landfill? 9 A No. 1 know them both very well and I've had many 10 conversations with them, but 1 don't remember anything in 11 particular about this. 12 Q Do you recall conversing with them about 13 materials going to the landfill? 14 A No. 15 Q Let me turn you back to the Bates numbers at the 16 bottom that end in 094 through 097. These are some 17 handwritten notes? 18 A Yes. 19 Q The handwriting on page 094, do you recognize 20 that? 21 A No. 22 Q Are you familiar with a Mr. Sprandel, 5 A No. 6 Q Who was B. Moody? 7 A Bob Moody was at Queeny and then at Anniston and 8 then at Krummrich. 9 Q Do you know whether he's still alive? 10 A He's dead. 11 Q So 1 guess we can't depose him. The next page 12 there's a reference to an L. Reeves and it says " retired in 13 village." Do you know who L. Reeves is? 14 A No. 15 Q What about Jim Smith? 16 A 1 seem to remember that name, but 1 can't connect 17 it with anything. 18 Q The reference to " day operator of landfill," does 19 that help you at all? 20 A 1 wouldn't have known an operator at the 21 landfill. 22 Q There's a reference below that to Chuck Duebner, Savage, James (Aroclor Dept employee) in AETNA (4) Pages 695 - 698 HARTOLDMONO010346 Page 699 Page 701 1 D-u-e-b-n-e-r; is that a name that's familiar to you? 1 A 1 don't know specifically. Normally, in melting 2 A Yes, he was in the maintenance department at the 2 that kind of material there's some kind of slag at the 3 Krummrich plant. He was a maintenance superintendent at 3 surface, but 1 don't recall observing that. 4 the time 1 believe that 1 was there. 4 Q So you just don't recall whether that lead was 5 Q Was he also an engineer? 5 gotten rid of somehow or another? 6 A He was an engineer before that. 6 A No, 1 never did anything specific related to that 7 Q Do you know whether he had any responsibilities 7 cell rebuilding operation. 8 regarding the landfill? 8 Q The page in the exhibit with the Bates number of 9 A No, 1 don't know. 9 096, do you recognize whose handwriting that is? 10 Q Let's go to the next page. On the right-hand 10 A No. 11 side there's some handwriting and there's two names and the 11 Q Can you read the last statement on that page? 12 first appears to me to be Paul Heisler and then there's a 12 A 1 can -- 1 think 1 can make it out, but 1 don't 13 name under that. Do you recognize the name under that? 13 know what it means. 1 believe it says " outside sales in 14 A No. 14 mines but maybe before 1950." That doesn't mean anything 15 Q And there's some handwriting in quotes that 15 to me. 16 appears to say" no lead." Were you ever familiar with any 16 Q Were there any mines that you're aware of 17 concern about lead being disposed of in landfills? 17 associated with the Krummrich plant? 18 A No. 18 A No. There's coal mining in that area and the 19 Q Was lead something that was used or produced or 19 Krummrich plant at one time bought coal from those mines, 20 somehow involved in the operations in the Krummrich, 20 but it still doesn't make any connection for me. 21 Anniston or Nitro plants? 21 Q Do you have any knowledge of what the term 22 A Yes, at the Krummrich plant. 22 " mines " would mean there aside from reference to coal Page 700 Page 702 1 Q How was lead involved at the Krummrich plant? 1 mines? 2 A In the Hooker cell operation each cell had an 2 A No. 3 anode assembly consisting of a number of blades, vertical 3 Q The next page references a memo to file. It says 4 blades of graphite. Those vertical blades of graphite were 4 " Attached is Xerox of information sent to government on 5 set in lead so each time that the cell was rebuilt that 5 waste streams. Much of the information was obtained from 6 replace the anodes after they had been consumed by the 6 my files." 7 reaction, the lead would be melted out of the base of the 7 Are you aware of any people who were keeping 8 cell. New anodes would be put in place and lead would be 8 files concerning landfill issues or information sent to 9 poured around the anodes to hold them in place. That 9 governmental agencies concerning landfills in the 1975 time 10 operation was done in a small shop next to the Hooker cell 10 frame? 11 house. 11 A No. 12 Q What was that operation called, to your 12 ( Savage Exhibit 140 identified. ) 13 knowledge? 13 Mr. Brock: I've marked as Exhibit 140 a 14 A 1 think it was called the cell rebuilding area or 14 multipage document with Bates numbers Mco 8411400 through 15 something like that. 15 410. 16 Q Was there ever a need to get rid of any of that 16 By Mr. Brock: 17 lead? 17 Q Mr. Savage, let me know when you've had a chance 18 A My recollection is that the lead was melted down 18 to look through this document. 19 and reused. 1 don't know of any reason to get rid of any 19 ( Witness reviewed the document. ) 20 of it. 20 A Okay. 21 Q When the lead was melted down, would there 21 Q You can see you're listed as a copy recipient? 22 sometimes come to be impurities in the lead? 22 A Yes. Savage, James (Aroclor Dept employee) in AETNA (4) Pages 699 - 702 HARTOLDMONO010347 Page 703 Page 705 1 Q And is this a progress report issued by the 1 A Not that 1 recall. But since 1 was so closely 2 Krummrich plant Tsd department in or about the 1971 time 2 involved with Pcbs, that was very vivid in my mind and 1 3 frame? 3 wouldn't have necessarily responded to similar problems in 4 A Yes. 4 other areas. 5 Q Do you recall there being investigations going on 5 Q Do you know whether by this time frame, meaning 6 at that time in order to reduce the sewer losses from 6 the 1971 time frame, there had been any claims of pollution 7 Department 236 and 237? 7 or contamination resulting from discharges to the sewers in 8 A 1 remember work of that sort, yes. 8 the chlorophenol operations at the Krummrich plant? 9 Q And again those were the chlorophenol 9 A No. 10 departments ; is that correct? 10 Q Let me ask you to turn to the second and third 11 A Yes. 11 page of the exhibit. Those are the pages with the Bates 12 Q What do you recall about the work that was 12 numbers of 401 and 402 and there's a table 1 on those 13 ongoing along those lines? 13 pages. Do you see that? 14 A 1 really don't remember any detail about it at 14 A Yes. 15 all. 15 Q And there's a category of" routine losses." Do 16 Q Do you recall what the impetus was for it? 16 you see that? 17 A No. 1 think it just was routine that by that 17 A Yes. 18 time frame, pollution issues or losses were of general 18 Q What does that refer to? 19 concern in any operation. 19 A Well, 1 can only infer that from the context that 20 Q Why was that? 20 there's a column labeled " routine " and another labeled for 21 A Just because the increasing emphasis by the 21 "nonroutine." 1 presume that the nonroutine column were 22 government and within our company. 22 those things that resulted from some exceptional incident Page 704 Page 706 1 Q When you talk about an increasing emphasis by the 1 such as a mechanical failure. And routine would be 2 government and the company, how did that increasing 3 emphasis manifest itself during the early ' 70s? 4 Mr. Burnett: Objection ; vague. 2 everything else. 3 Q What were the nature of your responsibilities or 4 job activities with respect to sewer losses from the 5 Go ahead. 5 chlorophenol operations at the Krummrich plant during this 6 The Witness: 1 don't remember exactly when 6 time frame? 7 various steps were put in place, but over the last couple 7 A Penta and Pcbs -- or Pep were products sold by 8 of decades there's been escalating concern and the company 8 our business group. So 1 would have the usual 9 setting new targets that had gone underway, 1 think, in the 9 manufacturing manager responsibility for work going on in 10 late ' 60s. But 1 don't remember any particular benchmarks. 10 the department which would include their entire technical 11 By Mr. Brock: 11 program. A program to reduce sewer losses would simply be 12 Q When you say" the last couple of decades," you 12 a part of the technical program. 13 mean from today dating back a couple decades or from that 13 Q Do you recall having any input into such a 14 time dating back? 14 program? 15 A From today dating back a couple decades. 15 A 1 had regular meetings at the Krummrich plant to 16 Q Do you recall what the reason or impetus was for 16 discuss the technical program, so I'm sure 1 had an 17 that concern growing in the late 1960s? 17 opportunity to review and comment on this. 18 A It was a social trend in the country, 1 think. 1 18 Q Do you recall any specific meetings that 19 think Monsanto's experience in such areas as Pcbs was 19 addressed sewer losses? 20 emphasized within Monsanto. 20 A 1 went there every month, but 1 don't remember 21 Q Did Monsanto have similar experiences in 21 specifically this topic came up. 22 additional areas other than Pcbs? 22 Q Do you recall there being any -- other than Pcbs, Savage, James (Aroclor Dept employee) in AETNA (4) Pages 703 - 706 HARTOLDMONO010348 Page 707 Page 709 1 do you recall there being any claims or allegations or 1 Q If you turn to the second page, up at the top it 2 notices or lawsuits to the effect that discharges to sewers 2 says " The sewering of Ona with the mother liquor is a major 3 from the operations at the Krummrich plant had resulted in 3 cause of sewer pluggage in the area." Do you see that? 4 contamination or pollution? 4 A Yes. 5 A No, 1 don't. 5 Q Why was that a cause of sewer pluggage? 6 Q Let's go to the first page of the document. Who 6 A This paragraph seems to contradict what 1 just 7 are J. E. Rabbitt, R-a-b-b-i-t-t, and D. C. Armstrong? 7 said. It appears that it's Ona rather than Oncb that was 8 A John Rabbitt had been an engineer in Tsd and 1 8 being recovered. Oncb was being used as a way of 9 believe at one time was a production supervisor. 1 don't 9 recovering the Ona. But anyway, in answer to your 10 remember which job he had at the time of this report. 10 question, Ona has a high melting point so it would become a 11 Because he's listed as the personnel writing this report, 1 11 solid in contact with cooler water. That could plug a 12 presume it was while he was still in Tsd. What was the 12 sewer. 13 other name? 13 Q Do you recall any occasions on which that 14 Q D. C. Armstrong? 14 happened? 15 A Dallas Armstrong was a group leader in the-- 15 A No. 16 Dallas Armstrong had been a group leader in the plant 16 Q Do you recall any times in which a sewer in the 17 research and development organization, what we called 17 Ona operations needed to be replaced or repaired as a 18 Pr&d. At some point he became a Tsd group leader and again 18 result of -- 19 because his name is shown here in parentheses, it implies 19 A No. 20 that that had occurred by the time this report was written. 20 Q - pluggage? 21 ( Savage Exhibit 141 identified. ) 21 A No. 22 Mr. Brock: I've marked as Exhibit 141 documents 22 Q What would the effect of pluggage in those sewers Page 708 1 with the Bates numbers Wgk 3253483 through 486. 1 be? 1 mean, what would happen? Page 710 2 By Mr. Brock: 3 Q Mr. Savage, could you let me know when you've had 4 a chance to look through the exhibit. 2 A What would happen when any sewer plugs up, water 3 would back up. 4 Q How was that situation, how were the pluggage 5 ( Witness reviewed the document. ) 5 situations taken care of? 6 A Okay. 6 A 1 presume somebody would clean it. 1 don't know. 7 Q Let's go to the attachment first, the last three 7 Q Do you recall there being any claims that 8 pages of the exhibit. Is this a progress report generated 8 pluggage of sewers had led to leakage of that kind of 9 by you and R. L. Fields in the 1965 time frame? 9 material from the sewers? 10 A It would have been written by R. L. Fields. My 10 A No, 1 don't recall that. 11 name is mentioned because he worked for me at that time. 11 Q Do you know what those sewers were made of? 12 Q Do you recall there being a project undertaken in 12 A Not these specific ones, no. 13 the 1965 time frame concerning the recovery of sewered Ona? 13 ( Savage Exhibit 142 identified. ) 14 A 1 just vaguely remember this project. 14 Mr. Brock: I've marked as Exhibit 142 a February 15 Q What do yourecall about it? 15 6, 1975 cover memo with an attachment and it has Bates 16 A Only that there was one. 16 numbers 0092231 Pep through 0092247 Pep. 17 Q Do you recall what the reason for undertaking 17 By Mr. Brock: 18 this project was? 18 Q Mr. Savage, after you've had a chance to glance 19 A It was to recover raw material for recycle. 19 through the document, could you let me know. 20 Q And that was raw material that previously had 20 ( Witness reviewed the document. ) 21 been discharged through the sewer? 21 A Okay. 22 A 1 believe so. 22 Q Do you recall there being year-end status reports Savage, James (Aroclor Dept employee) in AETNA (4) Pages 707 - 710 HARTOLDMONO010349 Page 711 1 concerning water pollution control at the Krummrich plant? 2 A No. 3 Q Do you recall receiving documents of this type in 4 the mid 70s? Let me -- 5 A Generally, that's true. 1 don't remember this 6 specifically. 7 Q Was it your understanding there were yearly 8 status reports on water pollution control in connection Page 713 1 employment with Monsanto? 2 A Yes. 3 Q 1 had asked you about the possibility of 4 lawsuits. Do you see the reference in the bottom of the 5 first paragraph to the possibility that Monsanto might 6 become involved in legal actions? Do you see that? 7 A Yes. 8 Q Let me turn you to page, the Bates number that 9 with the Krummrich plant? 10 A Not specifically. 11 Q What was the nature of your responsibilities, if 9 ends in 292 down at the bottom where it says " legal." Do 10 you see that? 11 A 292? 12 any, in the 1975 time frame with respect to water pollution 13 control at the Krummrich plant? 14 A Since as manufacturing manager 1 had 15 responsibility for some operations at the Krummrich plant, 16 1 would probably receive a report like this if any of my 17 operations were involved in the subject matter. 18 Q The arrow on the cover of this document appears 19 to indicate that this particular copy went to Phocion 20 Park. Do you see that? 21 A Yes. 22 Q Do you have an understanding as to why lawyers 12 Q 392, I'm sorry. 13 A Yes. 14 Q That references two lawsuits alleging losses due 15 to excessive Pcb contained in milk. 16 A Yes. 17 Q And 1 believe we've already talked about those? 18 A Yes. 19 Q Aside from those lawsuits, do you recall the 20 subject of the possibility of lawsuits against Monsanto in 21 connection with Pcbs being raised in or about the 1970 time 22 frame? Page 712 1 within -- or a lawyer at least within Monsanto was sent 1 Page 714 A No, 1 can't place anything in that time frame. 2 copies of year-end status reports like this with respect to 3 water pollution control at the Krummrich plant? 4 A Well, you observe that the content of the report 2 Q When you say you can't place anything in that 3 time frame, and again I'm excluding the milk claims that 4 we've seen referenced, did the possibility of lawsuits or 5 makes a number of references to federal regulations. It's 5 legal claims against Monsanto relating to Pcbs come to your 6 my understanding Phocion was involved in interpreting those 6 attention at some other time frame? 7 regulations for us. 7 A 1 think 1 mentioned previously having been 8 Q Do you know whether Mr. Park was involved in 8 deposed previously in some lawsuits and two of those, 1 9 Monsanto's response to lawsuits or threats of lawsuits 9 believe, were lawsuits against Monsanto. 10 concerning water pollution control matters? 10 Q Fair enough. When was the first time that it 11 A No, 1 don't know. 11 came to your attention that there was a possibility of 12 ( Savage Exhibit 143 identified. ) 12 legal action against Monsanto with respect to the Pcb 13 Mr. Brock: I've marked as Exhibit 143 a 13 situation at either the Krummrich or Anniston sites, aside 14 multipage document with Bates numbers 0164390 through 402 14 from your depositions and aside from the milk claims? 15 By Mr. Brock: 15 A 1 think that at the time that 1 joined the 16 Q Mr. Savage, this will go back to our favorite 16 business group in early 1970 that the subject of lawsuits 17 subject, Pcbs. Can you let me know when you have had a 17 was a current topic. But 1 don't remember when 18 chance to glance through this. 18 specifically 1 learned about any specific suit. 19 ( Witness reviewed the document. ) 19 Q When you say it was a current topic, what do you 20 A Okay. 20 mean? 21 Q Is this a copy of an October 6, 1970 memorandum 21 A The silo case, for instance. 22 directed to you and some others in connection with your 22 Q If 1 remember correctly, that was one of the milk Savage, James (Aroclor Dept employee) in AETNA (4) Pages 711 - 714 HARTOLDMONO010350 Page 715 Page 717 1 cases ; is that correct? 1 Bates number 427. 2 A Yes. 2 A Okay. 3 Q Was there discussion to the effect that there 3 Q In the first indented paragraph of the page 4 might be additional claims asserted against Monsanto with 4 there's a statement that" since the legal threats are more 5 respect to Pcbs? 5 imminent and the problems more visible." Do you see that? 6 A 1 don't remember. 6 A 1 see that, yes. 7 Q Do you recall whether there was any discussion as 7 Q Do you recall what you meant by legal threats 8 to whether a governmental agency might assert a claim 8 being more imminent in or about this time frame with 9 against Monsanto with respect to the Pcb situation? 9 respect to the Pcb situation? 10 A Not a claim specifically. There was considerable 10 A This memo appears to be minutes written by me of 11 discussion about a possibility or likelihood of regulatory 11 a meeting of a number of people mainly from the business 12 action such as by the Epa. 12 group who were involved in the decisionmaking process. And 13 Q What type of regulatory action? 13 as far as 1 can see, I'm simply quoting what Mr. Papageorge 14 A At that time there was discussion of the 14 said. 15 possibility of regulations regarding Pcb content of 15 Q Do you recall Mr. Papageorge bringing up the 16 wastewater and also at some time fairly early in the 1970s, 16 subject of potential legal threats concerning the Pcb 17 there was discussion of a possibility that the government 17 situation? 18 might ban the use of Pcbs altogether. 18 A Well, any possible legal threats were part of 19 Q Let me turn you to the page that ends in Bates 19 Bill's responsibility in those days. 1 don't remember this 20 number 398 of this document. There's a category there for 20 meeting. 21 regulatory action. Do you see that? 21 Q There's a statement, it says " Bill Papageorge 22 A Yes. 22 stated that the Law and Medical Departments and others Page 716 Page 718 1 Q Do you recall there being contacts being made 1 would welcome a decision to shut down Anniston liquid 2 with the Alabama Water Improvement Commission concerninc 2 Aroclor." 3 the Pcb situation around the 1970s time frame? 3 A Yes. 4 A 1 was aware indirectly because the plant would 4 Q Do you recall the law department favoring 5 keep me informed. 1 wasn't directly involved. 5 shutting down Anniston liquid Aroclor operations? 6 Q Do you recall there being any discussion of 6 A No. In fact, we did. But at the present time 1 7 concern about the possibility that the Alabama Water 7 don't remember the reasons that went into that decision. 8 Improvement Commission might take some sort of legal actior 8 Q The reference up above to " recent Illinois 9 against Monsanto with respect to the Pcb situation? 9 regulatory activity," do you know what that refers to in or 10 A 1 think we anticipated the possibility of state 10 about this time frame? 11 regulatory action at either Krummrich or Anniston, but 1 11 A No. 12 don't remember the specific state bodies or what action 12 ( Savage Exhibit 145 identified. ) 13 they might take. 13 Mr. Brock: I've marked as Exhibit 145 a document 14 ( Savage Exhibit 144 identified. ) 14 with Bates numbers 0005665 through 668. 15 Mr. Brock: I've marked as Exhibit 144 a document 15 By Mr. Brock: 16 with Bates numbers 0005425 through 428. 16 Q Mr. Savage, could you let me know when you've had 17 By Mr. Brock: 17 a chance to look through it. 18 Q Mr. Savage, is this a copy of a December 9, 1970 18 ( Witness reviewed the document. ) 19 memorandum that you authored in connection with your 19 A Okay. 20 employment with Monsanto? 20 Q Is this a copy of an August 7, 1970 memorandum 21 A Yes. 21 that was sent to you and some others in connection with 22 Q Let me turn you first to the page that ends in 22 your employment with Monsanto? Savage, James (Aroclor Dept employee) in AETNA (4) Pages 715-718 HARTOLDMONO010351 Page 719 Page 721 1 A Yes. 1 Q On Exhibit 145 there's a line that reads 2 Q The subject is called " Anniston-pcb-cleanup 2 " Confidential - Fyi and Destroy." Do you see that? 3 program." Do you recall there being a program to clean up 3 A Yes. 4 Pcb contamination at the Monsanto - at the Anniston or 4 Q Why would this type of document, why would there 5 Krummrich sites in or about this time frame? 5 be an instruction to destroy this type of document? 6 A 1 believe that term meant, in that time frame, 6 A That would be quite unusual. 1 don't know. 1 7 reducing losses rather than remediation. It was just a 7 guess there's an implication that somebody thought the 8 general term, not some specific short-term campaign. 8 information was sensitive, but that was not a usual 9 Q Are you aware of any decision taken at a 9 practice for us. Obviously, it was an instruction that 10 subsequent time to clean up or remediate Pcb contamination 10 wasn't obeyed in this case. 11 in connection with the Krummrich or Anniston plants? 11 Mr. Brock: Off the record. 12 A At the time that we completely shut down our Pcb 12 ( Discussion off the record. ) 13 and Pet operations at Anniston, dismantled the equipment 13 By Mr. Brock: 14 and so forth, there was an effort to, just to restore the 14 Q Did you, from time to time, receive instructions 15 site to a level condition and dispose of the scrap from the 15 that certain documents that you received should be 16 department that involved decontaminating material that had 16 destroyed? 17 been dismantled. That's all 1 recall from it at the time 17 A Well, in two ways. One is that there's a company 18 that 1 had any responsibility. 18 records retention policy such that we were instructed that 19 Q Was that generally referred to as the Aroclor 19 at least once a year we should go through files and throw 20 dismantling? 20 away routine memos that were more than two years old. 21 A Yes. 21 There were exceptions to that instruction that we might get 22 Q If my memory serves, was that sometime in the 22 an instruction from the law department that any document Page 720 Page 722 1 1976 time frame or thereabouts? 1 that was subject to controversy shouldn't be destroyed as 2 A 1 think it was finished after 1 left the business 2 part of that routine, and also we were allowed to keep 3 group. 3 documents relating to ongoing transactions where we need to 4 Q From your description of it, my understanding is 4 keep history of a negotiation or something like that. 5 that that involved decontaminating certain equipment that 5 The other circumstance in which we have 6 had been used? 6 instructions to destroy something would be if someone had 7 A Yes. 7 written a memo that turned out to be an error - to contain 8 Q Did it also involve attempts to decontaminate 8 an error and sometimes we would get a replacement copy with 9 soil or water that had become contaminated? 9 instructions, please destroy the previous copy. 10 A 1 don't remember that it did. It could be. 10 Q As 1 see this, this is different from both of 11 Q Are you aware of any efforts that have been 11 those? 12 undertaken at any time to decontaminate soil or water 12 A Yes, this is quite unusual. 13 contaminated by Pcbs in connection with the Krummrich or 13 Q The document retention program that you talked 14 Anniston plants? 14 about, that would be a generic thing saying destroy certain 15 A 1 really don't know. The shutdown at Krummrich 15 types of documents? 16 was after my time in the operation and the Anniston 16 A Yes. 17 dismantling was complete, 1 think, after my time. So 1 17 Q And the other situation would not be the document 18 would not have been aware, 1 think, of anything specific. 18 itself saying destroy this document? 19 Q Do you recall being involved in any discussions 19 A Yes, yes. So this is an exceptional situation. 20 concerning whether or not such a cleanup or remediation 20 Q You talked about the possibility that it might 21 should take place? 21 contain sensitive information? 22 A No, 1 don't remember that. 22 A That's just a guess. 1 can't think of any other Savage, James (Aroclor Dept employee) in AETNA (4) Pages 719 - 722 HARTOLDMONO010352 Page 723 Page 725 1 reason why that would be done. 1 Q Were you kept apprised of those meetings? 2 Q Do you recall receiving this document? 2 A 1 would receive things like these minutes or 3 A No. 3 sometimes in Bill Papageorge's monthly report, there would 4 Q Do you recall receiving any documents during your 4 be some summary ofthe outcome of such a meeting. 5 tenure at Monsanto with an instruction on the face of the 5 Q Let me ask you to turn back to the second page of 6 document to destroy this document? 6 the document. There's a statement that" Mr. White had two 7 A No, that just was not a normal practice. 7 primary areas for concern." Do you see that? 8 Q When you referred to the possibility that it 8 A Yes. 9 might contain sensitive information, what did you mean by 9 Q And it states " The Federal Department of Justice 10 sensitive information? 10 has apparently recommended that suit be initiated against 11 A Just information that was considered highly 11 the Anniston plant for Pcb emission under the Federal 12 confidential and was not to be spread beyond the parties 12 Refuse Act." Do you see that? 13 receiving. 1 really don't know. This is just quite 13 A Yes. 14 unusual. 14 Q Do you recall learning that the Federal 15 Q Do you have an understanding as to why the 15 Department of Justice had recommended a lawsuit against 16 information in this would not be -- or why Monsanto would 16 Monsanto with respect to Pcb emissions from the Anniston 17 take steps to prevent the dissemination of this information 17 plant? 18 outside the company? 18 A No. 19 A No, because we had a procedure for confidential 19 Q Do you believe you received a copy of this 20 information. If a document was mentioned -- was marked 20 memorandum in the course of your employment with Monsanto? 21 company confidential or some earlier nomenclature for the 21 A I'm sure 1 did. 22 same thing, then it was understood that it was not to be 22 Q Does that reference refresh your recollection Page 724 Page 726 1 released outside the company. This is just not the way 1 that generally the subject of potential lawsuits against 2 such things are normally handled. 2 Monsanto with respect to Pcb emissions had come up by this 3 ( Recess. ) 3 time frame? 4 ( Savage Exhibit 146 identified. ) 4 A It doesn't remind me of anything specific. The 5 Mr. Brock: I've marked as Exhibit 146 a document 5 general climate was one of anticipating various 6 dated November 11, 1971. 6 governmental actions and therefore we had many different 7 By Mr. Brock: 7 efforts going to reduce emissions and so forth. So this 8 Q Mr. Savage, after you've had a chance to look 8 fits the climate as 1 recall it, but 1 don't remember 9 through this, could you let me know. 9 anything specific. 10 ( Witness reviewed the document. ) 10 Q Do you recall that climate, including discussions 11 A Okay. 11 of potential lawsuits or claims? 12 Q Let me ask you to turn to the second page of the 12 A No. 13 exhibit. First of all, do you recall there being meetings 13 Q For example, any discussion concerning what 14 between Monsanto personnel and personnel with the state of 14 Monsanto should do in the event of a lawsuit or claim, do 15 Alabama and the Southwest Regional Epa in the 1971 time 15 you recall discussions along those lines? 16 frame regarding the Pcb situation at the Anniston plant? 16 A My recollection is that the driving force 17 A 1 remember in general there were meetings between 17 primarily was the concern about regulation. 18 the Epa and the state authorities in Monsanto about Pcb 18 Q 1 take it you don't have any recollection as to 19 products both at Anniston and at Krummrich. 19 further developments along -- or concerning the Justice 20 Q What do you recall about those meetings? 20 Department's apparent recommendation that suit be 21 A Just that they took place. 1 didn't attend any 21 initiated? 22 of those meetings. 22 A No, 1 don't remember. Savage, James (Aroclor Dept employee) in AETNA (4) Pages 723 - 726 HARTOLDMONO010353 Page 727 Page 729 1 Q Do you recall any discussions along the lines of 1 time to time. This is a joint meeting between the two 2 attempting to -- strike that. 2 plants and at such maybe one-of-a-kind meeting. 3 Do you recall any discussions along the lines of 3 Q Let me turn you to the page that ends in Bates 4 having Monsanto's insurance companies pay for any of the 4 number 221. It's page 4 of the document. The paragraph in 5 actions Monsanto was taking with regard to the Pcb 5 the middle begins with the sentence " Jim Savage outlined 6 situation? 6 the Krummrich plant's investigation program." Do you see 7 A No, 1 don't remember that. 7 that? 8 ( Savage Exhibit 147 identified. ) 8 A Yes. 9 Mr. Brock: Exhibit 147 is a document with Bates 9 Q What was the investigation program with respect 10 numbers 0196218 through 222 and it's dated May 19, 1966. 10 to Aroclors at the Krummrich plant at that time? 11 By Mr. Brock: 11 A 1 think that just refers to the general technical 12 Q Mr. Savage, could you let me know when you've had 12 program that we had going on in the Aroclor department at 13 a chance to look through it. 13 the time. At this time 1 was -- 1 worked at the Krummrich 14 ( Witness reviewed the document. ) 14 plant as a Tsd superintendent. 15 A Okay. 15 Q What sort of things would the technical program 16 Q Is this a memorandum directed to you and some 16 with respect to Aroclors entail at the time? 17 others in May 1966 in the course of your employment with 17 A 1 don't think 1 can add anything to what's listed 18 Monsanto? 18 here. 19 A Yes. 19 Q This makes a reference to " investigation 20 Q Who was O. E. Dolin, D-o-l-i-n? 20 program." Do you recall what, if anything, was being 21 A Owen Dolin, 1 believe at that time was chief 22 chemist at Anniston. 21 investigated with respect to the Aroclor operations at the 22 Krummrich plant at that time? Page 728 Page 730 1 Q Who was John Luecken, L-u-e-c-k-e-n? 1 A 1 think the term is used pretty broadly. It just 2 A He was a chemist at the Krummrich plant, the 2 refers to the technical program going on at the time. 3 Krummrich plant laboratory. 3 Q Do you know whether that entailed anything other 4 Q What about John Macpherson, M-a-c-p-h-e-r-s-o-n? 4 than investigation into chlorination temperature and 5 A 1 don't recognize that. 5 removal of catalyst baskets? 6 Q Jim Bryant, do you recognize that name? 6 A No, 1 don't remember. 7 A Jim Bryant was a chemist at the Anniston plant. 7 Q What was the significance of chlorination 8 Q And G. W. Miller, who was that? 8 temperature? 9 A Gerry Miller, he was either a chemist or a 9 A Chlorination temperature had an effect on product 10 chemical engineer. He was at the Anniston plant. 10 quality. It was too low. That was one of the ways 11 Q Who was Jerry Veazey, V-e-a-z-e-y? 11 poor-quality Aroclor could be made. 12 A He was an engineer at the Anniston plant. 1 12 Q And would poor-quality Aroclor, would that be 13 remember he was a mechanical engineer, but I'm not sure of 13 disposed of rather than sent to customers? 14 that. 14 A It was totally unacceptable to make Aroclor of 15 Q The reference to Prd meeting, what does that 15 that quality. We simply didn't do it. We knew what 16 refer to? 16 conditions were required to prevent it. We ran that way. 17 A 1 think that stands for process research and 17 Q Were there any occasions on which Aroclor was 18 development. 18 produced that was of such a quality that it couldn't be 19 Q Do you recall there being process research and 19 sent to customers to your knowledge? 20 development meetings concerning Aroclor in or about the 20 A Sometimes a batch of Aroclor would be 21 1966 time frame? 21 unacceptable for an electrical customer and therefore would 22 A Each of the plants would have such a meeting from 22 be sent to a customer that used it in some other way. 1 Savage, James (Aroclor Dept employee) in AETNA (4) Pages 727 - 730 HARTOLDMONO010354 Page 731 Page 733 1 don't recall ever having made Aroclor that was unacceptable 1 A It's only one letter. 1 can't tell. 2 for any customer. 2 Q Do you recall - 3 Q So you don't recall any occasions on which a 3 A It really doesn't look like the way 1 would write 4 decision was made that Aroclor couldn't be sold and 4 a B, but it's very hard to tell from one letter. 5 therefore it had to be gotten rid of some other way? 5 Q Do you recall receiving information concerning 6 A No. 6 the Aroclor situation at the Anniston plant and forwarding 7 Q And in reference to removal of a catalyst basket, 7 the information in these type of reports along to 8 what does that refer to? 8 Papageorge? 9 A The chlorinators had a metal basket inside which 9 A Yes. Yes, 1 think we've seen some other examples 10 contained chunks of iron. They actually were turnings 10 of that. 11 purchased from people who made railroad car wheels and this 11 Q Right. Having that in mind, would this appear to 12 was the material that was removed in machining the wheels. 12 be - or does that impact on your statement as to whether 13 And the iron turnings were there to act as a packing for 13 or not that's your writing? 14 gas distribution and also to provide a secondary source of 14 A Well, that's something 1 routinely did. It still 15 ferric chloride catalyst. It turned out that was really 15 doesn't look like the way 1 write a B. 16 not necessary for the process. 16 Q There's a reference to " normal level" of Aroclor 17 Q And the reference to " proved advantageous," does 17 losses. Do you see that? 18 that refer to taking out something that was not necessary 18 A Yes. 19 to the process? 19 Q Do you know what that refers to," normal level"? 20 A Yes. 20 A 1 think it's only there to distinguish it from 21 ( Savage Exhibit 148 identified. ) 21 the next item of digging in the Hcl neutralization pit, 22 Mr. Brock: 1 have marked as Exhibit 148 a 22 which would not have been a routine operation. Page 732 1 one-page document with Bates number of 0248695. 1 Page 734 Q So normal level would be losses due to the 2 By Mr. Brock: 2 routine operations of the plant? 3 Q Mr. Savage, is this an Anniston plant technical 3 A 1 think that's the implication, but 1 would guess 4 services department monthly report directed to you and some 4 it was determined by difference. 5 others in connection with your employment with Monsanto? 6 A Yes. 7 Q Again, we can see that the instruction on the 8 right-hand side where it says " confidential, read and 9 destroy." Do you see that? 10 A Yes. 11 Q Does that refresh your recollection as to why 12 that instruction would appear? 13 A No, but it obviously wasn't obeyed. That was not 14 a normal procedure. 15 Q There's a reference to -- strike that. First of 16 all, does the arrow on the left-hand side indicate that 17 this was a copy that was in fact sent to you? 18 A Yes. 19 Q To the left of" Current Level" there's a " B." Do 20 you see that? 21 A Yes. 22 Q Is that your handwriting? 5 Q When you say" determined by difference," you're 6 just contrasting it to the other item? 7 A Yes. 8 Q Do you recall there being digging in the Hcl 9 neutralization pit at the Anniston plant? 10 A 1 don't remember this specific incident. 11 Mr. Brock: Off the record. 12 ( Discussion off the record. ) 13 ( Recess. ) 14 ( Savage Exhibits 149, 150, and 151 15 identified. ) 16 Mr. Brock: For the record, I've marked Exhibits 17 149 through 151. Exhibit 149 has Bates numbers of 0248685 18 through 86. 19 By Mr. Brock: 20 Q Mr. Savage, is this Anniston plant Tsd monthly 21 report directed to you and some others in connection with 22 your employment with Monsanto? Savage, James (Aroclor Dept employee) in AETNA (4) Pages 731 - 734 HARTOLDMONO010355 Page 735 Page 737 1 A Yes. 1 Area Monitoring." Then there's a reference to " Pcb removal 2 Q Now there's some handwriting on this one. Is 2 from any area from our fence to Choccolocco." Do you see 3 that your handwriting? 3 that? 4 A Yes, it appears to be. That's a little strange 4 A Yes. 5 because the arrow over on the side seems to indicate that 5 Q Are you aware or do you recall the subject of 6 this is Papageorge's copy, but that does look like my 6 cleaning up Snows Creek and removing Pcbs from any area 7 writing. 7 associated with the Anniston plant coming up in or about 8 Q And again there's a instruction " confidential, 8 1971? 9 read and destroy." Does that refresh your recollection as 9 A No. 10 to what that might refer to or the reason for it? 10 Q Do you have an understanding as to why 11 A No, 1 obviously didn't take it very seriously. 11 Mr. Landwehr might have sent you a memorandum addressing 12 Q Or Mr. Papageorge, 1 don't know. Under" Spills " 12 these subjects in or about January of 1971? 13 there's a reference to " Minor leaks were contained by use 13 A Well, as manufacturing manager 1 would have had 14 of sand and disposal in drums." Do you see that? 14 responsibility for cost control and so any special 15 A Yes. 15 expenditures would be a subject that 1 would be concerned 16 Q Do you know how those drums were disposed of? 16 about. This document seems to be a financial forecast of 17 A No. 17 sorts. 18 Q Let's go to Exhibit 150. This was a copying 18 Q When you said " special expenditure," what did you 19 glitch that 1 had try to see whether 1 could correct it. 19 mean by" special expenditure "? 20 I've not yet been able to do it. But this is page 3. For 20 A Something that wouldn't have been provided for in 21 the record, the Bates number is 0248231 and the full 21 the budget. You'll notice the label on the bottom line is 22 document is 0248229 through 31. For the record, it appears 22 " total potential budget overrun " and a budget overrun is Page 736 Page 738 1 to me that the full document is a document dated January 1 something 1 would be concerned about. 2 21, 1971 from J. C. Landwehr, L-a-n-d-w-e-h-r, to Mr. Savage 2 Q Realizing that you certainly don't have the 3 concerning Anniston-1971 Aroclor waste costs. 3 entire document in front of you, would it be your 4 Mr. Savage, looking at the page that we have 4 understanding that the items referenced on this page would 5 there's a reference to " Leaching problems-storm drain, pit 5 refer to potential budget overruns? 6 bypass, groundwater under Aroclor department, and abandoned 6 Mr. Burnett: I'm going to object to examining 7 dumps." Do you see that? 7 him on an incomplete document. But he can try to answer it 8 A Yes. 8 if he can. 9 Q Do you recall the subject of leaching problems 9 The Witness: You can only infer it from what it 10 coming up in connection with the operation of the Aroclor 10 says here. If it's being considered as an overrun, then 11 department at the Anniston plant in or about 1971 or so? 11 these must have been things that had not been provided for 12 A No. He mentions a mechanical expense of $2000 12 in the budget. The budget would have been prepared in 13 maximum which sounds like it must have been a very modest 13 perhaps August of the preceding year. 14 situation. 1 don't remember it. 14 By Mr. Brock: 15 Q Do you recall any situations coming up with 15 Q Let's go to Exhibit 151. Is this a copy of a 16 respect to Pcbs being found or claimed to be in the 16 progress report by the technical services department at the 17 groundwater under the Aroclor department at that time? 17 Anniston plant dated July 21, 1970 directed to you and some 18 A ! don't remember that. 18 others in connection with your employment with Monsanto? 19 Q The reference to abandoned dumps, do you know 19 A Yes. 20 what that refers to? 20 Q Let me ask you to turn to the page with the 21 A No. 21 ending Bates number 294. There's a reference down at the 22 Q The reference C is to " Clean up Snows Creek and 22 bottom of that page to " Limestone Pit being cleaned out." Savage, James (Aroclor Dept employee) in AETNA (4) Pages 735 - 738 HARTOLDMONO010356 Page 739 Page 741 1 Do you see that? 1 Q What was the component that Monsanto had an 2 A Yes. 2 interest in? 3 Q And there's an asterisk by it and there are 3 A Material that was called tall oil rosin acid. 4 asterisks by certain of the entries above. Do you see 4 Q That's r-o-s-i-n? 5 that? 5 A Yes. 6 A Yes. 6 Q What was the component that Emery had an interest 7 Q Do you recall an effort being made to clean out 7 in? 8 the limestone pit in or about the July 1970 time frame? 8 A It was called tall oil fatty acid. 9 A That was done periodically because of the 9 Q How long did you have job responsibilities 10 accumulation of material from the limestone that was not 10 relating to Monsanto's Nitro plant? 11 consumed by the acid. 1 don't remember this particular 11 A From the time that 1 just described until 1 left 12 time but certainly there had been occasions like this. 12 the business group in 1975. 13 Q What was done with the material that was cleaned 13 Q So that would be a total of about -- 14 out from the limestone pit? 14 A Three or four years. 15 A 1 don't know. It was hauled away. 15 Q Generally, what was the nature of your -- or to 16 Mr. Brock: Off the record. 16 be grammatical, 1 should say what were the nature of your 17 ( Discussion off the record. ) 17 job responsibilities as they related to the Nitro plant 18 By Mr. Brock: 18 during that time? 19 Q Mr. Savage, when did you first have 19 A As manufacture manager, so it was the same kind 20 responsibilities relating to Monsanto's Nitro plant? 20 of relationship that 1 had with the other plants. 21 A At the time that the paper chemicals products 21 Q Did all the operations that that plant come under 22 were added to the specialty products group. It was 22 purview -- under your purview or only some of them? Page 740 Page 742 1 sometime after 1 joined the specialty products group, but 1 1 A Just those specific operations that 1 mentioned, 2 don't remember exactly when. There had been a business 2 the Mersize department and to some degree the joint venture 3 group called Cellu-chem which had been run by John 3 operations. 4 Mullendore as business group director. And that group was 4 Q The joint venture operations, was that referred 5 disbanded sometime around 1971 or 1972 and certain products 5 to by a particular department name, for example, the tall 6 from that business group were added to the specialty 6 oil department? 7 chemicals group at that time. 7 A Yes, that's one name for it. 1 think the name of 8 Q So your first responsibilities regarding the 8 the venture was M-e Venture. 9 Nitro plant would have come sometime after 1971 or 1972? 9 Q When you said the tall oil department was one 10 A About that time because the paper size products 10 name for that operation, were there other names? 11 called Mersize were added to our business group at that 11 A Yes, M-e Venture or just M-e or Monsanto-emery. 12 time and also the responsibility for the joint venture at 12 Q Did you, in connection with your responsibilities 13 Nitro between Monsanto and Emery was added to our business 13 as manufacturing manager, go visit the Nitro plant? 14 group. 14 A Yes. 15 Q Emery, how do 1 spell Emery? 15 Q How many times did you do that? 16 A E-m-e-r-y. 1 think the name of the company 16 A Oh, perhaps 10 times all together. 17 actually is Emery Industries. 17 Q Generally what were the occasions for those 18 Q What was the nature of that joint venture? 18 visits? 19 A It was a joint venture for the distillation of 19 A That was routine reviews with the plant people of 20 tall oil. Tall oil is a product of the paper industry and 20 programs and budgets and the like. 21 Monsanto had interest in one component of that mixture and 21 Q Who reported to you from the Nitro plant? 22 Emery in the other. 22 A It was not a direct reporting relationship. It Savage, James (Aroclor Dept employee) in AETNA (4) Pages 739 - 742 HARTOLDMONO010357 Page 743 Page 745 1 was a dotted-line relationship, but it was Dave Tippey, 1 A There were pretty modest differences. The 2 T-i-p-p-e-y. 2 addition of fumaric acid was called fortification so that's 3 Q Anybody else during the time that you had 3 sometimes the generic description of the product, was 4 responsibilities for that department, for that plant? 4 fortified rosin size and for different price performance 5 A Not that 1 remember. There was also a production 5 there were varying degrees of fortification and dilution 6 supervisor, of course, and some engineers, but my 6 and the amount of neutralization with caustic soda or 7 relationship was mainly with Dave Tippey. 7 caustic potash. 8 Q Did you undertake to learn the operations of the 8 Q What was Mersize used for? 9 Mersize department and the tall oil operations there? 9 A It's an internal size used in the manufacture of 10 A 1 had a reasonable understanding of Mersize 10 paper. The function of sizing is so that when the paper is 11 operation. 1 had a very general understanding of tall 11 printed or written upon, that the ink doesn't blot and 12 oil. For the purposes of the Monsanto-emery venture, Dave 12 spread in the paper. 13 formally reported to Howard Bergen rather than me because 13 Q When Mersize came out of what you called the 14 there were some broader business management issues as well 14 reaction mass, what would its form be? 15 as simply manufacturing. 15 A A thick liquid. 16 Q When you say they formally reported to Howard 16 Q Do you know whether there were any residues or 17 Bergen, would personnel in that department as a functional 17 by-products from those operations during those years? 18 matter report to you about certain things? 18 A The entire contents of the reactor were product. 19 A Sometimes. If Howard had asked me to get 19 It was transferred to storage tank, to storage tanks and 20 involved in some manufacturing aspect of the tall oil 20 from there into tank cars which were shipped to the paper 21 operation. 21 mills. 22 Q I'm just trying to get the distinction down. 22 Q Do you recall there being any types of leaks or Page 744 Page 746 1 When you said they formally reported to Howard Bergen, what 1 spills or other types of process upsets in those processes 2 kind of matters would they report to him and what kind of 2 during those years? 3 matters to you? 3 A 1 don't remember anything specific. 4 A Well, from a formal standpoint it was entirely 4 Q Did you say the Mersize was shipped in tank cars? 5 under Howard rather than me. Since Howard had no 5 A Most of it was. There may have been small 6 manufacturing background, he would sometimes ask me to get 6 amounts shipped in drums. It would be very awkward to 7 involved if there was a specific manufacturing issue to be 7 handle it in drums so the preferred method was tank cars, 8 addressed. 8 possibly tank trucks. 9 Q Can you give me a general overview of the 9 Q Why was it awkward to handle in drums? 10 operations of the Mersize department during those years? 10 A Because it was thick material which was hard to 11 A The main raw material for Mersize was the tall 11 handle when it was cold. Whenitwasputinadrum.it 12 oil rosin acid from the tall oil plant. There were some 12 would have to be heated to get it out. 13 batch reactors and the tall oil was reacted with fumaric 13 Q When you said cold, did that include room 14 acid and as 1 recall it, a mixture of caustic soda and 14 temperature? 15 caustic potash. And that essentially was the process. The 15 A Yes. 16 whole reaction mass was the product. There was no refining 16 Q What was the process by which the Mersize reached 17 step or anything like that. 17 the tank cars? 18 Q And that reaction mass, that was a product, that 18 A Pumped. 19 was Mersize? 19 Q Pumped through pipelines? 20 A That was called Mersize. There were a large 20 A Yes. 21 number of different grades of Mersize. 21 Q What happened at the end of the pipeline? 22 Q What distinguished the various grades? 22 A Just went into a storage tank and likewise from a Savage, James (Aroclor Dept employee) in AETNA (4) Pages 743 - 746 HARTOLDMONO010358 Page 747 Page 749 1 storage tank it would be pumped into tank cars. 1 paper there's at some point a place where tall oil is 2 Q I'm envisioning some sort of pipe or hose being 2 skimmed off from a stream from which it would otherwise be 3 tunneled from the pipe or attached from the pipe to the -- 3 a waste product. 4 into the tank car. Is that the way it worked from the 4 Q So your understanding it would be skimmed off 5 pipes to the tank car? 5 from the stream at the paper - 6 A 1 don't remember that specific unit. It would 6 A At paper mills, that's right. 7 not have been a hose. A hose would not have been 7 Q When when you're talking about paper mills, you 8 compatible with that material. The usual practice was to 8 mean mills that are making paper? 9 have pipes with swivel joints that would be put into the 9 A Yes, mills that take in trees and put out paper. 10 top of the tank car. 1 assume it was done that way for 10 It's a specific kind of paper mill. There's different 11 Mersize but 1 don't remember specifically. 11 kinds of paper processes, but 1 don't remember which one. 12 Q Do you know how that material was put in drums? 12 Q How many paper mills did the Nitro plant receive 13 A No. 13 tall oil from? 14 Q Recognizing that you said you had not as 14 A 1 don't know. Several, but 1 don't know. 15 extensive an understanding of the tall oil operations at 15 Q Do you know the names of any of those mills? 16 the Nitro plant, can you give me an overview as to what 16 A No. 17 those operations consisted of? 17 Q When the tall oil came into the Nitro plant, what 18 A It was a fairly complicated set of distillation 18 would the Nitro plant do with it? 19 columns and 1 couldn't begin to sketch out how they were 19 A Well, that was the raw material. They would 20 connected together. The only thing distinctive that 1 20 unload it from the barge or the tank car and put it in 21 remember is that at least some of the columns were 21 storage tanks, and that was the raw material for the tall 22 something called steam distillation which means that rather 22 oil plant. Page 748 Page 750 1 than indirect heating, which is the normal way of 1 Q So the function of the tall oil plant at the 2 distilling, that steam was introduced directly into the 2 Nitro plant was to produce a raw material for the Mersize 3 column and in contact with the product. 3 department; is that correct? 4 Q Let's back up a step. What chemicals or 4 A The function of the venture was to take tall oil 5 materials were used in the tall oil operations? 5 from the paper mills and produce a raw material for 6 A Just the one raw material, the tall oil 6 Monsanto which was tall oil rosin acid and another raw 7 by-product from paper mills. 7 material for Emery, which was the fatty acid. The fatty 8 Q Tall oil would come in from paper mills to the 8 acid was sometimes referred to as Ufa, which stood for 9 Nitro plant? 9 unsaturated fatty acid, and at the plant they would call 10 A Yes. 10 the rosin acid Tora, which stood for tall oil rosin acid. 11 Q How did it reach the Nitro plant? 11 And on the accounting sheets you would sometimes see a 12 A 1 believe that some of it was in barges and some 12 reference to Torufa which was the two added together. 13 of it was in tank cars. 13 Mr. Brock: Off the record. 14 Q Tall oil, I'm envisioning an oil; is that what it 14 ( Discussion off the record. ) 15 was? 15 The Witness: There was also some smaller 16 A Yes. It was a thick, oily material. 16 by-products from tall oil, but 1 don't remember what they 17 Q How did the tall oil fit in with the operations 17 were. 18 of which it was a by-product, the paper operations, meaning 18 By Mr. Brock: 19 was it used in those operations or how was it produced in 19 Q Was the tall oil rosin acid used for any - used 20 those operations, if you know? 20 in any way other than as a raw material in the Mersize 21 A It's a natural by-product. I'm no expert on 21 department? 22 making paper, but in the processing of the pulp to make 22 A There was a related product which was developed Savage, James (Aroclor Dept employee) in AETNA (4) Pages 747 - 750 HARTOLDMONO010359 Page 751 Page 753 1 during the time that 1 was manufacturing manager which we 1 Q Generically speaking, Mr. Savage, can you 2 called Monsize which was - had the same purpose as Mersize 2 identify what these are for us? 3 but was a more efficient product. It was a dispersed rosin 3 A These are the monthly reports of the plant 4 size, meaning that a fortified material was dispersed in 4 manager of the Nitro plant written for a series of months 5 water. 5 beginning in January 1975. 6 Q When you use the term " fortified material," what 6 Q 1 take it the plant manager during that time 7 are you using that term to refer to? 7 period changed from B. G. Mcguire to R. M. Scott? 8 A It was a reaction product of rosin acid and 8 A That's right. 9 usually fumaric acid. Sometimes maleic anhydride was used 9 Q Do you know whether those men are still alive or 10 instead of fumaric for fortification in very low-cost, 10 those individuals are still alive? 11 low-grade products. 11 A 1 have not heard of Bill Mcguire for a long 12 Q Can you give me an overview of the Monsize 12 time. Roy Scott recently worked at the general office and 13 operations at the Nitro plant? 13 1 think has retired within the last two or three months. 14 A The first step was very similar to the beginning 14 Q What was his position at the general office 15 of making Mersize in that the rosin acid was reacted with 15 recently or from which he retired, I'm sorry? 16 fumaric acid fortified to a higher extent than normal, 16 A Roy was director of site administration. That 17 meaning more fumaric acid than normal. And then that 17 may have not been his exact title, but that's reasonably 18 molten reactor mass went into a homogenization system which 18 descriptive of what he did. 19 dispersed the material 1 just described, which we called 19 Q When you say" descriptive of what he did " - 20 adduct, a-d-d-u-c-t, at that point. It was dispersed into 20 A At the general office. 21 water to make a dispersion, that as 1 recall was about 30 21 Q Right. Generically speaking, what were his job 22 percent adduct in water. Formed a milky-looking material 22 duties in the general office? Page 752 Page 754 1 and that was the final product. 1 A For taking care of buildings and facilities on 2 Q And what was that final product used for? 2 site. 3 A The same thing as Mersize. It was just a more 3 Q Would that include the Nitro, Krummrich -- 4 cost-effective product. 4 A Oh, no, this was just at the general office in 5 Q From the Monsize operations were there any 5 St. Louis. 6 residues or by-products? 6 Q Do you know whether he still lives in the 7 A 1 don't recall that there were any. 7 St. Louis area? 8 Q Do you recall who the customers were for Mersize 8 A 1 think he does. 9 and Monsize? 9 Q Your name is on the distribution list at the back 10 A They were paper mills, not necessarily the same 10 of each of these documents? 11 ones that were the source of the tall oil, but it was paper 11 A Yes. 12 mills. 12 Q Does that indicate to you you received a copy of 13 Q Throughout the time that you had responsibilities 13 these in connection with your employment at manufacturing 14 relating to the Nitro plant, were there any other 14 manager? 15 operations there that were - for which you had job 15 A Yes. 16 responsibilities? 16 Q Let's go to the Exhibit 152, the page that ends 17 A No. 17 in Bates number 3008 at the bottom. 18 ( Savage Exhibits 152 through 158 18 A Okay. 19 identified. ) 19 Q That's a discussion of environmental control 20 Mr. Brock: For the record, I've marked Exhibits 20 matters with respect to the Nitro plant. Do you see that? 21 152 through 158. 21 A Yes. 22 By Mr. Brock: 22 Q And that references an Npdes permit, and down in Savage, James (Aroclor Dept employee) in AETNA (4) Pages 751 - 754 HARTOLDMONO010360 Page 755 Page 757 1 the next paragraph, a letter being sent to the Epa. Do you 1 and then died about two weeks later. 2 see that? 2 Q 1 hope no correlation. 3 A Yes. 3 A Charlie Smith was somewhere in manufacturing 4 Q Do you recall there being communications with the 4 management or perhaps a business director at that time. 1 5 Epa concerning the Nitro plant in or about this time frame? 5 don't remember, but he was at the general office. Gerry 6 A No. 6 Bratsch, 1 believe, was plant manager at Krummrich at that 7 Q Did you have any involvement or responsibilities 7 time, although he later became director of manufacturing. 8 for such communications with the Epa concerning the Nitro 8 It could have been by this time. W. R. Robirds was kind of 9 plant? 9 manufacturing responsibility at the general office for the 10 A No. 10 ag division operations. Arnie Obel was business director 11 Q There's a reference to a treatment plant. Do you 11 for rubber chemicals. 12 see that? 12 Howard Bergen was my boss, head of specialty 13 A Yes. 13 products. Dick Kozacka 1 believe at that time was - had a 14 Q Did you ever have any job responsibilities 14 high-level position in the organic engineering department. 15 regarding any treatment plant associated with the Nitro 15 Harry Kilbourne 1 believe was in rubber chemicals research 16 plant? 16 at Acra. W. R. Richard was our research director in 17 A No. 17 specialty products. Howard Mitchell was in personnel, but 18 Q Do you know whose responsibility that was? 18 1 don't know where. Des Hosmer was in manufacturing 19 A There was somebody on the plant manager's staff 19 management at the general office. Paul Edwards was 20 who had that responsibility, but 1 don't remember who it 20 manufacturing manager for rubber chemicals. Al Heininger 21 was. 21 was - 1 don't know what his title was. But he had a 22 Q If you look at the distribution list of this 22 director level job associated with new business development Page 756 1 document that's on page 3010, does looking at that refresh 1 at the general office. Page 758 2 your recollection as to who that would have been? 3 A It could have been Max Galloway, but I'm not 4 sure. 2 John Smith was a manufacturing manager for 3 plasticizers. Bill Kuhn was a manufacturing manager, but 1 4 don't remember in what area. 1 believe in 1975 he was ill 5 Q Can we do -- I'm sorry. 5 and had no direct responsibility, but was working when he 6 A Max Galloway, at least for some time, had some 6 could. Hastings 1 think was in accounting. Bill Ratliff 7 pollution responsibilities at the Nitro plant, 1 believe, 7 was in accounting. They were both at the general office, 1 8 but 1 can't say with any confidence that he would have been 8 believe. Cayard 1 believe was in the ag division, but 1 9 in charge of the waste treatment plant. 9 don't remember what his job was. Howard Tippee was 10 Q Can we do this, and I'd like to just do this as 10 involved in shipping and material handling at the general 11 quickly as possible, and 1 think the quickest way would be 11 office. Bill Mcguire, plant manager. Jack Munie was plant 12 for you just to run down the list of names and describe for 12 manager at Queeny. Bob Flint, 1 believe was plant manager 13 me whether or not you know the people and what their job 13 at Krummrich. 14 duties were with Monsanto, if you know, in or about the 14 George Knollmeyer, 1 believe, was plant manager 15 1975 time frame. 15 at Delaware River, which is in New Jersey. Bill Merman, 1 16 A H. H. Bible 1 believe is Harold Bible, was a vice 16 believe, was in Monsanto Canada at that time. 1 don't 17 president of the corporation. 1 have no idea why he's 17 remember what his job was. Vince Matteucci was in 18 listed here. Jim Springgate was at that time with the 18 manufacturing. 1 think he had a production responsibility 19 general office and 1 think was some kind of general manager 19 at Nitro at that time, but 1 don't remember what. 1 don't 20 but 1 don't remember what division. F. J. Fitzgerald was a 20 recognize Schaefer. Scott, we talked about before. He 21 vice president and was general manager of the division that 21 became plant manager 1 think at the time of this, this 22 we were in. He eventually became president of the company 22 writing he had some other kind of superintendent Savage, James (Aroclor Dept employee) in AETNA (4) Pages 755 - 758 HARTOLDMONO010361 Page 759 1 responsibility at Nitro. 2 J. T. Duggan is Jim Duggan, who at one time was at 3 Krummrich and another time at Nitro, but 1 don't know what 4 his job was at this time. Dave Tippey we talked about. 5 Q That's the Tippey that reported to you? 6 A Yes. 7 Q Go ahead. 8 A Hill Williams had some superintendent Page 761 1 Exhibit 154 that we're referring to. 2 There's a reference to Nitro environmental 3 group. Do you recall who was in that group at that point 4 in time? And you mentioned Max Galloway, but any other 5 people? 6 A That's the only one that 1 remember. 7 Q Did Max Galloway report to the plant manager? 8 A 1 don't think so. He was probably part of Tsd. 9 responsibility at Nitro. He may have been running Tsd at 10 that time, but I'm not sure. 1 don't recognize Dodd. Bob 11 Howard had a technical job. 1 don't know what it was. 9 Q Do you know who he reported to? 10 A No. 11 Q And the reference to " Engineers low flow study of 12 Max Galloway, 1 believe, was in Tsd doing pollution work. 13 Q R. L. Null, who was that? 14 A 1 don't know. 15 Mr. Brock: Off the record. 16 ( Discussion off the record. ) 17 By Mr. Brock: 18 Q Let's go to Exhibit 153 and the page that ends in 19 Bates number 024. Talking about environmental control 20 matters, that references " A pre-hearing conference to 21 discuss procedural matters of the Adjudicatory Hearing." 22 Do you see that? 12 the river," does that refresh your recollection as to there 13 being a study going on at that time? 14 A No. 15 Q 1 take it you had no involvement or 16 responsibilities for that study? 17 A That's right. 18 Q And there's a reference to Epa - or" The Epa has 19 identified certain parameters in our request for 20 adjudicatory hearings." Do you see that? 21 A Yes. 22 Q Does that refresh your recollection as to any 1 A Yes. Page 760 1 adjudicatory hearings going on with the Epa? Page 762 2 Q Do you recall there being any sort of hearing or 2 A No. 3 conference scheduled with the Epa concerning the operations 3 Q Let's go to the next exhibit, Exhibit 155. Let's 4 of the Nitro plant at this point in time? 4 go to the same page with the same subject," environmental 5 A 1 don't remember it. 6 Q There's a reference to Resource Analysis, Inc. of 7 Cambridge, Massachusetts, do you see that? 8 A Yes. 9 Q Did you have any dealings with Resource Analysis? 10 A No. 11 Q Were you aware that Resource Analysis, Inc. had 12 been retained? 13 A 1 don't remember. 14 Q What is the " five man committee "? 15 A 1 don't know. 16 Q Were you aware that there was a Corps of 17 Engineers study going on of the Kanawha River at that point 18 in time? 19 A No. 20 Q Let's go to the next exhibit. Let's turn again 21 to the page concerning environmental control and that ends 22 in Bates number 040. Just for the record, this is 5 control," and it ends in Bates number 048. 6 A Okay. 7 Q There's a statement that" The Tall Oil plant 8 accounted for 968 pounds per day of Bod5." Do you see 9 that? 10 A Yes. 11 Q What was Bod5, what does that refer to? 12 A We've previously discussed Bod as being an 13 analytical method for measuring organic loading in a waste 14 stream. Bod5 is a slightly more precise way of describing 15 that measurement. The 5 refers to five-day Bod, which is 16 the period of the test. It's five days. 17 Q And that measures the biological oxygen demand? 18 A Yes. 19 Q Within a five-day period? 20 A Yes. 21 Q There's a reference to a meeting with the West 22 Virginia Water Resources Division. Were you aware of Savage, James (Aroclor Dept employee) in AETNA (4) Pages 759 - 762 HARTOLDMONO010362 Page 763 Page 765 1 meetings going on between Monsanto and the West Virginia 1 permit? 2 Water Resources Division concerning the Nitro operations at 2 A No. 3 that time? 3 Q Did you have any involvement in the waste 4 A No. 4 treatment facilities expansion referenced? 5 Q Did you have any dealings -- strike that. 5 A Not that 1 remember. 6 Did you have any involvement in either preparing 6 ( Savage Exhibit 159 identified. ) 7 or the preparation of an Npdes permit for the Nitro plant 7 By Mr. Brock: 8 or Monsanto's compliance with such a permit? 8 Q I've marked as Exhibit 159 a document with Bates 9 A No. 9 numbers Nit 1066466 through 482. And Mr. Savage, once 10 Q 1 can see where this is going, but let's go to 10 you've had a chance to look through the document, could you 11 the next exhibit. The environmental control page is the 11 let me know. 12 page that ends in Bates number 056. And let me know when 12 ( Witness reviewed the document. ) 13 you've had a chance to turn to that page. 13 A Okay. 14 A Yes. 14 Q Is this a Nitro plant technical services progress 15 Q Are you aware of an Epa river study about the 15 report sent to you and some others in the February 1970 16 Nitro plant during that time frame? 16 time frame in connection with your employment with 17 A No. 17 Monsanto? 18 Q Do you know what the " Air Pollution Control 18 A Yes. 19 Commission " refers to? 19 Q Do you recall there being a survey of wastes and 20 A No. 20 disposal methods in connection with the Nitro plant in the 21 Q Were you aware of any odor compliance projects 22 involving the Nitro plant at that point in time? 21 early 1970s? 22 A The date of this report was the time 1 was still Page 764 Page 766 1 A No. We didn't have any in the paper chemicals 1 at the Queeny plant, and 1 would receive copies of all 2 operation. 2 reports from the technical service department at other 3 Q So that would have been -- you believe that would 3 plants. So 1 wouldn't have had any reason to pay 4 have been some other part of the Nitro plant? 4 particular attention to this report. 5 A 1 presume so. 5 Q You're saying you were not personally involved -- 6 Q Let's go to the next exhibit. The environment 6 A That's right. 7 control page is the page that ends in Bates number 064. 7 Q -- in these matters? 8 And again, do you recall there being a six-day river study 8 A That's right. 9 made of the plant by the Epa? 9 Q Do you recall ever being personally involved in a 10 A No. 10 survey or investigation of wastes and disposal methods at 11 Q Do you know what the emergency H2s flare was? 11 the Nitro plant? 12 A No. 1 remember the plant had a flare, but 1 12 A No. 13 don't know anything about it. 13 Q In connection with your duties as manufacturing 14 Q Do you recall there being visits by the Epa and 14 manager, did you undertake to learn what the wastes and 15 the state to inspect air pollution equipment? 15 disposal methods were at the Nitro plant? 16 A No. 16 A 1 would assume that 1 learned some general idea 17 Q Let's go to the next one, and the environmental 17 about it, but 1 don't remember it. 18 control page is the page that ends in Bates number 087. 18 Q Do you recall what, if anything, you may have 19 And this is exhibit -- for the record this is Exhibit 158. 19 done to get a general idea about those matters? 20 There's a reference to " Final details of the Npdes permit 20 A No. 21 had been resolved." Do you know -- are you familiar with 21 Q Who was W. D. Spoede, S-p-o-e-d-e? 22 the resolution of those -- of the issues pertaining to that 22 A Where do you see that? Savage, James (Aroclor Dept employee) in AETNA (4) Pages 763 - 766 HARTOLDMONO010363 Page 767 Page 769 1 Q It says " reported by." 1 project or a progress report from - issued by technical 2 A Oh, 1 don't know. 2 services at one of the plants, that would be circulated to 3 Q Can you identify who the people are under the 3 all technical service personnel? 4 Nitro plant category? And 1 think we've already talked 4 A No, a copy would be sent to each of the plant 5 about Dodd, Scott and Galloway. 5 technical service superintendents and if it appeared to 6 A Milke, 1 believe, was in the maintenance 6 have any relevance that would be of interest to somebody 7 department. Wally Kellogg was in Tsd, Vern Rhodes, 1 7 else in the department, 1, for instance, might pass it on. 8 believe was - well, at one time he was a Tsd engineer and 8 Q Did this have any relevance to your job duties in 9 another time he was a production supervisor in tall oil, 9 your - in the 1967 time frame other than that you were the 10 and 1 don't know which of those he might have been at the 10 Tsd superintendent? 11 time that this was written. Those are the only additional 11 A No, not that 1 can recall. 12 ones 1 can identify. 12 Q Let me run down some of these names again. Are 13 Q You don't know who B. J. Mcguire was -- or B. G. ? 13 you familiar with a J. E. Springgate? 14 A Yeah, that was Billy Mcguire, the plant manager. 14 A Yes, 1 know Jim Springgate. At one time he was 15 Q The summary on this page talks about" open pit 15 plant manager at Nitro and later on he was business 16 burning, dumping in waste liquid storage ponds, 16 director in rubber chemicals and still later he was in 17 incineration, and dumping in solid waste dump." Are you 17 Monsanto Electronic Materials Company. 1 think he was 18 familiar with any open pit burning at the Nitro plant? 18 president. I'm not sure what his job was in 1967, but the 19 A No, 1 don't remember that. 19 fact that he's listed here indicates he was probably - 20 Q What about dumping in waste liquid storage ponds? 20 that was probably the time when he was plant manager at 21 A 1 don't remember that. 21 Nitro. 22 Q And incineration? 22 Q Okay, Kellogg and Dodd we've talked about. Who Page 768 Page 770 1 A No. 1 was J. D. Garrison? 2 Q The reference to " solid waste dump," do you know 2 A Jack Garrison was in maintenance. 3 what that refers to? 3 Q Do you know what his position was in maintenance? 4 A No. 4 A No. 5 ( Savage Exhibit 160 identified. ) 5 Q Who was W. E. Lynch? 6 By Mr. Brock: 6 A 1 don't know. 7 Q I've marked as Exhibit 160 a document with Bates 7 Q Who was J. E. Bishop? 8 numbers Nit 1066680 through 686. 8 A 1 don't know. 9 Mr. Savage, I'll begin by asking whether this is 9 Q S. J. Stewart? 10 a Nitro plant technical services progress report directed 10 A 1 don't know. 11 to you and some others within Monsanto in the September 11 Q What about K. E. Smith, R. L. Sparks or T. R. Booh? 12 1967 time frame? 12 A 1 don't recognize any of those. 13 A Yes. 13 Q Who was W. J. Wilson? He's on the right-hand 14 Q Do you recall whether this was during the period 14 column under you. 15 that you were at the Krummrich plant or -- 15 A Bill Wilson at that time was general 16 A No, 1 was at Queeny. 16 superintendent of technical services at the Krummrich 17 Q Did you have any responsibilities with respect to 17 plant. 18 determining the time, place and amount of isopropanol 18 Q And Fuhrmeister was at the Anniston plant; is 19 losses in connection with the Nitro plant at that time? 19 that right? 20 A No, this was just a routine copy sent to me 20 A Yes. 21 because 1 was general superintendent at Queeny. 21 ( Savage Exhibit 161 identified. ) 22 Q Was the general practice to, when there was a 22 By Mr. Brock: Savage, James (Aroclor Dept employee) in AETNA (4) Pages 767 - 770 HARTOLDMONO010364 Page 771 Page 773 1 Q I've marked as Exhibit 161 a document with Bates 1 worked for Hill for the last several years, 1 recognize his 2 numbers Nit 1024129 through 148. 2 handwriting. 3 Mr. Savage, do you see your name listed as a copy 3 Q What was his job duty at that time, his position? 4 recipient of this document? 4 A 1 think he was the head of Tsd, but I'm not sure 5 A Yes. 5 about that. 6 Q And this was during the time that you were 6 Q If you turn to the second page of the document, 7 manufacturing manager; is that correct? 7 which has a Bates number - that ends in 130, under the 8 A That's right. 8 heading of" Pollution Problem " it states " The present Tall 9 Q For the record, the date of the document is July 9 Oil discharge averages about 750 pounds per day Bod5 and 10 30, 1974. Do you recall there being a project to eliminate 10 about 1500 pounds per day total organic carbon." Do you 11 river pollution from tall oil operations at the Nitro 11 see that? 12 plant? 12 A Yes. 13 A This project, yes, this project looks familiar. 13 Q Then it references a table 1 in appendix li and 14 Q Can you tell me what you recall about this 14 that appears on the page that ends in Bates number 141, 1 15 project? 15 believe, yes. 16 A Just in general terms that the use of direct 16 A Where's the numbers? 17 contact water was a route for some pollution to go to the 17 Q At the bottom of the page. 18 wastewater and therefore modification was made so that 18 A Oh, there it is in the middle. 19 direct contact water would not be used on a once-through 19 Q The microfilm number is 151. 20 basis. 20 A Okay. 21 Q When you use the term " direct contact water," 21 Q And that also references a total organic carbon, 22 what does that mean? 22 do you see that? Page 772 1 A Most of the time heat exchange, heat transfer is 1 A Yes. Page 774 2 accomplished in a chemical plant in an indirect way where a 3 coolant like water will be on one side of a surface and a 4 stream to be cooled will be on the other side of the 2 Q The reference to total organic carbon, what is 3 that? 4 A That's another way of measuring the organic 5 surface, like the inside and outside of a tube. A direct 5 loading in a stream. It's a little broader measurement 6 contact implies that the cooling water is directly 6 than Bod in that Bod only measures that part of the organic 7 contacted with a warm stream to cool it off. What's spoken 7 carbon that's biodegradable. 8 of here is jet losses. Jet in this context means a vacuum 8 Q How was this organic carbon generated from the 9 jet driven by steam and it was fairly common practice to 9 tall oil operations? 10 use something called a barometric condenser which would be 10 A 1 don't remember the process broadly enough to 11 a device for condensing the steam and the jet exhaust. 11 answer that. The immediate subject of this report on jet 12 Q The reference to river pollution, do you have an 12 losses are one path that 1 don't remember enough about the 13 understanding as to what river was being polluted, is that 13 process to describe it any other ways there might be. 14 the Kanawha River? 14 Q Can you describe for me the path involving the 15 A Yes. 15 jet losses that would lead to the discharge of organic 16 Q The handwriting up in the top right-hand corner 16 carbon from the tall oil operations? 17 where it says " File-tall Oil," do you recognize that 17 A Well, the use of direct cooling, direct contact 18 handwriting? 18 cooling in a barometric condenser would result in a stream 19 A It looks like Hill Williams's handwriting. 19 leaving the barometric condenser that contained any organic 20 Q 1 also see his name is circled. What was his 20 material that was in the vapor, the vacuum vapor stream 21 responsibility at that time? 21 going to the jet, and the usual way of handling that direct 22 A That leads me to think about Hill, but since I've 22 contact with cooling water was to handle it -- was to use Savage, James (Aroclor Dept employee) in AETNA (4) Pages 771 - 774 HARTOLDMONO010365 Page 775 Page 777 1 it one time and discharge it to the sewer. 1 Q What about J. L. Trauth, T-r-a-u-t-h? 2 Q And the sewer, 1 take it, went from the tall oil 2 A 1 don't know. 3 operations to the Kanawha River? 3 ( Savage Exhibit 162 identified. ) 4 A 1 don't remember the details. 1 believe that 4 By Mr. Brock: 5 went through a waste treatment plant on the way to the 5 Q I've marked as Exhibit 162 a document with Bates 6 river, but eventually reached the river. 6 numbers Nit 1066939 through 952. 7 Q So the organic carbon in that waste stream, did 7 Mr. Savage, could you let me know when you've had 8 that consist of materials dissolved in the water -- strike 8 a chance to look through the document. 9 that. 9 ( Witness reviewed the document. ) 10 In what form was that organic carbon discharged 10 A Okay. 11 from the tall oil operations? 11 Q Is this a copy of a November 1971 Nitro plant 12 A 1 don't know. 1 don't remember whether those 12 technical services progress report directed to you and some 13 materials were soluble in water or not. 13 others in connection with your employment with Monsanto? 14 Q Let's go to the last page of the exhibit, the 14 A Yes. 15 page that ends in Bates number 148. That talks about 15 Q Do you recall there being an investigation of the 16 questions and comments brought out during something called 16 use of a skimming pond in connection with tall oil water 17 the first scope review meeting. Do you see that? 17 pollution abatement for the Nitro plant in the early 1970s? 18 A Yes. 18 A No. 19 Q Do you know the answers to these questions? And 19 Q There's a reference in the paragraph under the 20 maybe it might be -- the quickest way to do it would just 20 summary where it states " it was decided that a skimming 21 say number 1, yes or no, and if you know an answer, tell 22 me. 21 pond would be the most economical' medium ' term solution to 22 Tall Oil water pollution abatement." Do you recall there Page 776 Page 778 1 A 1 don't know the answers to any of these. These 1 being any discussion of longer and shorter term methods of 2 are detailed questions about the operation of the proposed 2 dealing with the subject of water pollution abatement for 3 project. 1 don't know the answer to any of these. 3 the tall oil operations? 4 Q Going to number 13, do you recall any efforts at 4 A No. 5 chlorination of pond water in connection with pollution 5 Q Let's go to the page that ends in Bates number 6 abatement or pollution control efforts? 6 941. There's a category with Hi of" Alternate Pond 7 A No, 1 don't know what that's about. 7 Locations." Do you see that? 8 Q Let's stay on the exhibit for one second. The 8 A Yes. 9 names on the first page, again, under the heading of" Nitro 9 Q Do you recall there being any consideration of 10 plant," who was C. G. Weber? 10 alternatives with respect to where ponds could be located 11 A I'm not sure. 1 think that may be Chuck Weber, 11 to minimize pollution at the Nitro plant? 12 who 1 think was a mechanical engineer. 12 A No. 13 Q And who was M. L. Hutchison? 13 Q 1 take it you don't recall having any personal 14 A 1 don't know. 14 involvement in this project? 15 Q P. M. Dunnavant? 15 A No. 16 A 1 don't know. 16 Q Do you know whether this was during the time you 17 Q What about J. P. Hyland, J. E. Allison or G. P. 17 were a manufacturing manager? 18 Russell? 18 A Yes, yes, it was. 19 A 1 don't know. 19 Q Let's go through some of these names again. Who 20 Q Who was D. R. Eagleson? His name appears under 20 was F. J. Helmer? He's in the " reported " byline. 21 yours. 21 A Yes, Frank Helmer was a group leader or 22 A 1 don't know. 22 supervising engineer in Tsd in the Nitro plant. Savage, James (Aroclor Dept employee) in AETNA (4) Pages 775 - 778 HARTOLDMONO010366 Page 779 1 Q If you could quickly go through the names on the 2 second column under Nitro plant, excluding Mr. Tippey. 3 A R. E. Lindemann is Ralph Lindemann. He later 4 transferred to the general office and may still work for 5 Monsanto. 1 don't know for sure. That's the only one of 6 those names that 1 can shed any light on. 7 Q Do you recall there beingskimming ponds 8 installed at the Nitro plant? Page 781 1 examining the economics, for one thing. 2 Q What does that mean? 3 A Meaning that in studying the process looking for 4 potential reduced cost, any unnecessary raw material 5 consumption represented an opportunity for cost reduction. 6 Q You mentioned that there was a realization that 7 the operations were not perfect. During your tenure with 8 Monsanto, was there ever an operation that was perfect in 9 A No. 10 Q Does this refresh your recollection at all as to 11 there being concerns about pollution from the Nitro plant 9 the sense that you used the word " perfect," meaning that 10 there was 100 percent conversion of raw materials to final 11 product? 12 during the time that you were manufacturing manager? 1 13 mean, in your review of all the documents that we've seen? 14 A 1 think it was a matter of general knowledge that 15 there were some pollution problems at the Nitro plant. 16 This doesn't -- specifics of these reports don't add 17 anything to my understanding of that. 18 Q Do you recall what the nature of your general 19 knowledge was concerning pollution problems there during 20 the time you were manufacturing manager? 21 A No. 1 just knew that they had a pollution group 22 and that they had a number of things they were working on. 12 A You might argue that something like Mersize 13 satisfied that definition. It was not a very elegant 14 operation, but since everything that came out the reactor 15 went into the tank car, in that sense there wasn't any real 16 loss. 17 Q Any others? 18 A 1 think it was a general feature of the processes 19 1 can remember that they ran it at less than 100 percent of 20 their yield. 21 Q Are you familiar with the discharge of water 22 vapor from neutralizers in the Mersize operations at the Page 780 Page 782 1 Q By that time did you have any understanding that 1 Nitro plant? 2 pollution was a normal aspect of the operation of 2 A No. 3 Monsanto's plants? 3 Q Do you recall having any involvement in 4 A I'm not sure 1 understand that. 4 generating or approving of standard manufacturing processes 5 Mr. Burnett: 1 object to the question. 5 for the Mersize operations at the Nitro plant in the early 6 By Mr. Brock: 6 1970s? 7 Q By that time did you have the expectation that 7 A 1 think 1 may have had approval responsibility 8 there would be some type of pollution from the operations 8 for standard manufacturing processes at that time. 9 of Monsanto's manufacturing plants? 9 Q Do you recall what, if anything, you did in 10 A 1 think the potential for pollution is something 10 connection with those approval responsibilities? 11 that 1 understood to be present from the beginning of my 11 A 1 got dozens of standard manufacturing processes 12 time with Monsanto. By this time in 1971 we had become 12 from various plants to approve so 1 would usually look at 13 more sensitive to the consequences of pollution. 13 them to try to be confident that they were reasonably 14 Q Okay, what makes you say that you had the 14 complete. But 1 would not be able to make a judgment as to 15 realization from the time you started with Monsanto that 15 whether they were correct in detail. 16 Monsanto's operations presented the potential for 16 Mr. Brock: Off the record. 17 pollution? 17 ( Discussion off the record. ) 18 A Well, it was evident in the examination of any 18 ( Savage Exhibit 163 identified. ) 19 process that the processes weren't perfect, that not all 19 By Mr. Brock: 20 the raw material wound up in the product and that the 20 Q 1 have marked as Exhibit 163 a September 11, 1967 21 difference could be accounted for by various losses that 21 document with Bates numbers Nit 1090397 through 436. 22 went to water or land. It was a natural consequence of 22 After you look through the document briefly, Savage, James (Aroclor Dept employee) in AETNA (4) Pages 779 - 782 HARTOLDMONO010367 Page 783 1 Mr. Savage, could you tell me whether you recognize this 2 document at all. 3 ( Witness reviewed the document. ) 4 A It appears to be a fairly typical process 5 improvement plan, but 1 don't recall having had anything to 6 do with these products. 7 Q You mean thiofide and -- 8 A Thimor. 1 believe those were rubber chemicals. Page 785 1 company -- of the companies that any such persons 2 represented? 3 A 1 think it may have been Liberty Mutual. 4 Mr. Burnett: 1 have nothing further. 5 Examination 6 By Mr. Brock: 7 Q Do you know who it was, if anybody, who visited 8 the Monsanto plants from Liberty Mutual? 9 Q So during your tenure with Monsanto you don't 10 recall having any responsibilities with regard to these 11 products? 9 A Well, they were inspectors who came in on a 10 periodic basis once a year or once every two years to look 11 at such things as fire protection facilities and the like, 12 A No. 13 Q Do you recall having any responsibilities 14 regarding 2,4,5-t operations at the Nitro plant? 15 A No. 16 Q Do you have an understanding as to why -- or any 17 reasons why Nitro technical services progress reports would 18 have been forwarded to you in the June of 1968 time frame 19 regarding the 2,4,5-t operations? And if you'd like, I'd 20 be happy to show you a document, but 1 was just trying to 21 shortcut it. 22 A No, that would have just been the routine because 12 and they would make useful recommendations at the end of 13 their visit. 14 Q Do you know whether those representatives were 15 from Liberty Mutual or not? 16 A That's a name that 1 remember, but 1 can't be 17 sure. 18 Q So you might be recalling the name Liberty Mutual 19 from some other context? 20 A It could be. Insurance companies are pretty 21 well-known names. 22 Q And you don't recall the names of any of these 1 1 had Queeny Tsd and we exchanged reports. Page 784 1 people who came to visit the Monsanto plants? Page 786 2 Q Did you ever have any involvement that you recall 3 in evaluating incinerator needs with respect to wastes to 4 be disposed of from the Nitro plant? 2 A No. There were usually two or three people and 3 they would usually stay for about a week at the big plants. 4 Q What plants do you recall the people coming to 5 A No. 6 Q Mr. Savage, do you have an understanding as to 7 whether you will be asked to testify as a witness at the 8 trial of the lawsuit between Monsanto and its insurance 9 companies? 10 A That's never been mentioned to me. 11 Q If Monsanto asked you to be a witness, do you 12 believe that you would be available to testify at such a 13 trial in Wilmington? 14 A 1 think so. 15 Mr. Brock: 1 don't have any further questions. 16 Examination 17 By Mr. Burnett: 18 Q Mr. Savage, do you have any knowledge as to 19 whether representatives of insurance companies ever visited 20 the Anniston or Krummrich plants? 21 A Yes, 1 think they did. 22 Q Do you recall the names of any such insurance 5 see? 6 A Queeny, Krummrich, 1 think Anniston, but I'm less 7 certain about that. 8 Q What time frame did the people come to the Queeny 9 plant? 10 A During the time that 1 was on the plant manager 11 staff, which would have been the late ' 60s. 12 Q And what about Krummrich, what time frame did 13 they come? 14 A When 1 was at Krummrich. 15 Q And that was 1963 to 1967, that time frame? 16 A Yes. 17 Q And what about the Anniston plant? 18 A 1 don't know. 19 Q Did you meet or speak with those people? 20 A 1 remember doing so at Queeny. 21 Q What did your dealings with them consist of? 22 A Well, at the end of their visit they would meet Savage, James (Aroclor Dept employee) in AETNA (4) Pages 783 - 786 HARTOLDMONO010368 Page 787 Page 789 1 with the plant manager's staff and give their general 1 A If there was something they wanted to see, they 2 impressions and 1 would attend those meetings. 2 saw it. 3 Q Do you recall any subject of waste disposal 3 Q And how do you come to that understanding, 4 coming up during those meetings? 4 through personal knowledge? 5 A 1 don't remember. 5 A The way 1 remember it, and 1 remember it clearly 6 Q Do you recall whether those -- you used the term 6 only with respect to the Queeny plant, was that Jack Munie, 7 " inspections I'm going to use the term" visits." Do you 7 the plant manager, would discuss such a visit before it 8 recall whether those visits were geared towards primarily 8 took place and he took the position that we should view 9 workers' compensation matters? 9 their visit as an opportunity to learn something and should 10 A 1 don't remember that as the thrust of those 10 give them access to what they wanted to see. 11 visits. 11 Q Were you privy to any discussions between 12 Q Do you remember anything that they addressed 12 Monsanto and the people associated with the insurance 13 other than fire protection? 13 company or companies as to what areas of Monsanto's plants 14 A Yes. Things like inspections of pressure 14 they would see? 15 vessels, boilers. 15 A No. 16 Q Do you know whether these -- strike that. 16 Q Were requests from the insurance company people 17 Were these people employees of an insurance 17 to see any areas of the plants that you were associated 18 company? 18 with, were those directed to you? 19 A That's my recollection. 19 A No. 20 Q But you're not sure? 20 Q So you don't know what areas they would have 21 A Possibly a group of insurance companies, 1 don't 21 wanted to see? 22 know. 22 A No. Page 788 1 Q But you're not sure? 2 A No, I'm not sure. 3 Q Do you know whether they were associated with any 4 companies that issued boiler and machinery insurance to 1 2 3 Q Meaning my statement is correct? A That's correct. Q Other than fire protection matters and boilers, Page 790 5 Monsanto? 6 A 1 don't know. 7 Q Do you know who determined where at the Monsanto 8 plants these people would visit? 4 are you aware of any other matters that the people 5 associated with an insurance company or companies expressed 6 an interest in seeing? 9 A No. 7 A Pressure vessels in addition to boilers, but 10 Q Did you ever go around on one of the visits with 11 any of these people? 12 A 1 don't remember doing so. 8 that's all 1 remember. 9 Mr. Brock: 1 don't have anything further. 13 Q Was it generally Monsanto's policy not to let 10 Mr. Burnett: 1 have nothing further. 1 will 14 people from outside roam around its plants? 15 A Certainly. 16 Q And do you have any knowledge that Monsanto made 17 an exception for these people and let these people roam 11 designate the deposition and the exhibits to it as 12 confidential pursuant to the protective order in this 13 action. 18 around its plants? 19 A 1 recall that they were given a reasonably free 20 hand, but 1 can't tell you anything specific. 21 Q When you say" reasonably free hand," what do you 14 ( Whereupon, at 2: 40 p. m. , the deposition was 15 concluded.) 16 22 mean? 17 James R. Savage Savage, James (Aroclor Dept employee) in AETNA (4) Pages 787 - 790 HARTOLDMONO010369 [& -1989] & & 647:9 648:2 0 0005425 716:16 0005665 718:14 0019057 687:14 0019072 687:15 0091170 676:10 0092231 710:16 0092247 710:16 0164390 712:14 0196218 727:10 024 759:19 0248229 735:22 0248231 735:21 0248685 734:17 0248695 732:1 040 760:22 048 762:5 056 763:12 060 690:8 062 690:8 064 764:7 069 687:20 688:2 071 687:14 087 764:18 094 696:16,19 096 701:9 Transcript Word Index 097 696:16 1 1 653:3,7 679:16 705:12 775:21 10 668:14 693:14 742:16 10/14/75 649:16 10/6/70 649:18 100 673:1 781:10,19 1024129 771:2 1066466 765:9 1066680 768:8 1066939 777:6 1090397 782:21 11 668:14 693:16 724:6 782:20 11/11/71 649:21 11/15/71 649:15,29 118-1 647:8 12 689:11 693:17 12/9/70 649:19 1220 647:18 13 693:18 776:4 130 773:7 133 649:9 651:13 134 649:10 652:3,4 135 649:11 662:18,19 665:17 136 649:12 670:5,6 137 649:13 676:8,9 138 649:14 687:7,8,9,14,18 139 649:14 687:7,8,10 694:11 14 693:19,20 140 649:15 702:12,13 141 649:16 707:21,22 773:14 142 649:17 710:13,14 143 649:18 712:12,13 144 649:19 716:14,15 145 649:20 718:12,13 721:1 146 649:21 724:4,5 147 649:22 727:8,9 148 649:23 731:21,22 771:2 775:15 149 649:24 734:14,17,17 15 693:19,22 150 649:24 734:14 735:18 1500 773:10 151 649:24 734:14,17 738:15 773:19 152 649:25 752:18,21 754:16 153 759:18 154 761:1 155 762:3 158 649:25 752:18,21 764:19 159 649:26 765:6,8 16 693:22 160 649:27 768:5,7 161 649:28 770:21 771:1 162 649:29 777:3,5 163 649:30 782:18,20 17 665:18 694:1 18 694:1 19 694:2 727:10 19103 648:13 1950 701:14 1960s 662:11 704:17 1963 656:9 786:15 1965 659:20 708:9,13 1966 727:10,17 728:21 1967 652:20 695:16 768:12 769:9,18 782:20 786:15 1968 688:6,10 783:18 1969 670:17 695:9 1970 694:21 695:5 712:21 713:21 714:16716:18 718:20 738:17 739:8 765:15 1970s 652:18686:19715:16 716:3 765:21 777:17 782:6 1971 649:23 652:6 703:2 705:6 724:6,15 736:2,3,11 737:8 737:12 740:5,9 777:11 780:12 1972 740:5,9 1974 677:2 678:12 690:1,2 771:10 1975 689:16,20 702:9 710:15 711:12741:12753:5 756:15 758:4 1976 720:1 19801 648:5 1980s 666:12 1989 663:6 664:20 665:20 Savage, James (Aroclor Dept employee) in AETNA (4) HARTOLDMONO010370 [1993 -941] 1993 3010 647:15 756:1 2 3012314 2 653:8 672:22 673:10 670:7 31 790:14 2.4.5 783:14,19 2.5 672:22 673:10 735:22 322 652:12 653:1 654:12 323 656:6 2/12/70 3253483 649:26 2/6/75 649:17 20 647:19 694:2 708:1 328 653:8 350 648:3 2000 366 736:12 2005 670:7 392 648:12 21 647:15 694:3 736:2 738:17 713:12 398 715:20 22 4 694:3 4 221 647:13 657:19 729:4 729:4 4/27/71 222 649:10 727:10 40 23 790:14 694:4 401 2-3 705:12 682:4 402 236 705:12 712:14 703:7 410 237 702:15 703:7 427 24 717:1 688:6 428 27 716:16 652:6 689:16 436 29 782:21 677:2 4608315 292 652:6 713:9,11 4608454 294 652:7 738:21 482 3 3 665:4,6,7,9 735:20 3/24/69 765:9 486 708:1 5 649:12 5 30 762:15 751:21 771:10 5/19/66 3008 649:22 754:17 5001575 662:20 579 662:21 6 6 693:3 710:15 712:21 60s 661:17 682:10 704:10 786:11 61 656:4 62 656:4 650 649:4 651 649:9 652 649:10 662 649:11 668 718:14 670 649:12 676 649:13 686 768:8 687 649:14 7 7 693:3 718:20 7/30/74 649:28 702 649:15 707 649:16 70s 679:8,9 704:3 711:4 710 649:17 712 649:18 716 649:19 718 649:20 724 649:21 727 649:22 731 649:23 734 649:24 75 690:3 750 773:9 752 649:25 765 649:26 768 649:27 770 649:28 777 649:29 782 649:30 784 649:5 785 649:6 8 8 658:6 693:5 8/7/70 649:20 80s 679:8,11 8411400 702:14 86 734:18 88c 647:8 9 9 647:19 658:14 693:6,13 716:18 9/11/67 649:30 9/13/67 649:27 902 648:4 91 665:5 666:17,22 9106 694:15 9116 687:15 941 778:6 Savage, James (Aroclor Dept employee) in AETNA (4) HARTOLDMONO010371 [952 - arnie] 952 addressing 777:6 737:11 968 adduct 762:8 751:20,22 a adjacent abandoned 736:6,19 abatement 776:6 HIM,22 778:2 able 735:20 782:14 668:1 adjudicatory 759:21 761:20 762:1 administered 677:22 administration access 684:6,9 789:10 accomplished 772:2 accountant 681:2 753:16 advantageous 731:17 advice 660:14 aetna accounted 762:8 780:21 647:9 ag accounting 750:11 758:6,7 accumulation 739:10 acid 690:21 691:6 739:11 741:3 741:8 744:12,14 745:2 750:6,7,8,9,10,10,19 751:8 757:10 758:8 agencies 662:3 702:9 agency 715:8 ago 651:16691:9 agree 751:9,15,16,17 acra 676:15,22 agreement 757:16 act 647:17 agrees 725:12 731:13 action 647:7 663:6 666:14 714:12 715:12,13,21 716:8,11,12 650:18 ahead 704:5 759:7 air 790:13 actions 659:22 763:18 764:15 al 713:6 726:6 727:5 activities 647:10 757:20 alabama 706:4 activity 716:2,7 724:15 alive 718:9 add 729:17 779:16 added 739:22 740:6,11,13 750:12 692:13 697:8 698:9 753:9 753:10 alkali 693:5,7 alkaline adding 660:19 addition 745:2 790:7 additional 704:22 715:4 767:11 675:13 allegations 668:4 707:1 alleging 666:7 713:14 alleviate addressed 655:3 695:4,7 706:19 744:8 677:11 allison 787:12 776:17 allow anticipating 659:4 726:5 allowed anybody 722:2 685:21 743:3 785:7 alternate anyway 778:6 709:9 alternatives apparent 778:10 726:20 altogether apparently 715:18 695:6 725:10 ammonia appear 674:15 675:6,11,12,14 687:9,11 732:12 733:11 ammonium appearances 674:15 675:6 676:6 648:1 amount appeared 673:3 745:6 768:18 769:5 amounts appears 746:6 652:11 688:6 692:8 699:12 analysis 699:16709:7711:18 760:6,9,11 717:10 735:4,22 773:14 analytical 776:20 783:4 762:13 appendices analyze 649:14 655:4,14 appendix anderson 687:10,10,15,18 689:18 648:2 694:9,11 773:13 anhydride apprised 691:7,8 751:9 725:1 aniline approval 667:3,6 671:17684:3 782:7,10 anniston approve 650:11 651:18 654:1 782:12 655:19 660:20 666:6 approving 683:21,22 685:16 698:7 782:4 699:21 714:13 716:11 approximately 718:1,5 719:2,4,11,13 651:11 661:21 720:14,16 724:16,19 april 725:11,16 727:22 728:7,10 652:5 728:12 732:3 733:6 734:9 arbitration 734:20 736:3,11 737:7 647:9 738:17 770:18 784:20 area 786:6,17 665:9 666:21 667:14 669:5 announcements 685:12 700:14 701:18 666:14 709:3 737:1,2,6 754:7 anode 758:4 700:3 areas anodes 651:21 666:18 667:10 700:6,8,9 675:15 704:19,22 705:4 answer 725:7 789:13,17,20 678:21 709:9 738:7 774:11 argue 775:21 776:3 781:12 answers armstrong 775:19 776:1 707:7,14,15,16 anticipated arnie 716:10 757:10 Savage, James (Aroclor Dept employee) in AETNA (4) HARTOLDMONO010372 [aroclor - brine] aroclor attempts batch bill (cont.) 718:2,5 719:19 728:20 653:16 720:8 730:20 744:13 770:15 729:12,21 730:11,12,14,17 attend batchwise bill's 730:20 731:1,4 733:6,16 724:21 787:2 671:3 673:17 674:1 717:19 736:3,6,10,17 attention bates billy aroclors 714:6,11 766:4 652:6,11 653:1,8 654:11 767:14 729:10,16 august 656:5 662:20 670:7 676:10 biodegradable arrived 695:5 718:20 738:13 687:10,14,15,20,20 688:2 774:7 654:10 656:3 author 690:7 694:14,15 696:15 biological arrow 688:15 701:8 702:14 705:11 708:1 762:17 711:18 732:16 735:5 authored 710:15712:14713:8 bishop aside 716:19 715:19716:16717:1 770:7 701:22 713:19 714:13,14 authorities 718:14 727:9 729:3 732:1 blades asked 724:18 734:17 735:21 738:21 700:3,4,4 666:6 713:3 743:19 784:7 available 754:17 759:19 760:22 blot 784:11 784:12 762:5 763:12 764:7,18 745:11 asking avenue 765:8 768:7 771:1 773:7,14 board 768:9 669:12 775:15 777:5 778:5 782:21 666:13 683:15 aspect averages beat bob 743:20 780:2 773:9 680:20,22 681:1,8 681:16698:7 758:12 assembly aware bearing 759:10 700:3 659:19 674:18,19 682:13 675:12 boch assert 682:15,17,18 683:5,7,12,19 began 770:11 715:8 685:3 686:20,21,22 690:2 661:22 674:11 bod asserted 701:16 702:7 716:4 719:9 beginning 762:12,15 774:6,6 715:4 720:11,18 737:5 760:11,16 751:14 753:5 780:11 bod5 assistance 762:22 763:15,21 790:4 begins 762:8,11,14 773:9 660:10 awkward 729:5 bodies associated 746:6,9 behalf 716:12 650:10 664:3,15,22 666:1 672:9 677:21 678:4 690:21 701:17 737:7 755:15 757:22 788:3 789:12,17 790:5 association 652:18 673:17 assume 747:10 766:16 asterisk 739:3 asterisks 739:4 atmosphere 658:21 659:1,2,9 attached 702:4 747:3 attachment 653:2,7,8 655:4 708:7 b back 661:8 674:14 686:16 689 15 69T4 696 15 704:13,14,15 710:3 712:16 725:5 748:4 754:9 background 744:6 ban 715:18 bank 679:1 barge 74920 barges 748:12 ha rnmptrir 772:10 774:18,19 647:20 648:6,14 boiler belief 788:4 665:13,22 boilers believe 787:15 790:3,7 652:10 657:3 661:17 662:8 boss 668:3 669:1,5 673:19 684:2 757:12 687:19 692:14 693:10 bottom 695:4 699:4 701:13 707:9 656:15661:6 696:16713:4 708:22 713:17 714:9 719:6 713:9 737:21 738:22 725:19 727:21 748:12 754:17 773:17 756:7,16 757:6,13,15 758:4 bottoms 758:8,8,12,14,16 759:12 657:12,15 764:3 767:6,8 773:15 775:4 bought 783:8 784:12 701:19 benchmarks box 704:10 655:20,21 bergen boxes 743:13,17 744:1 757:12 655:15,16,18,22 661:3,9,11 beyond bratsch 710:15 attachments 653:9 attempt 652:16 attempting 727:2 700:7 basis 771:20 785:10 hackat 731'7 9 hackatc 730:5 723:12 bible 756:16,16 big 655:12 786:3 bill 685:17 717:21 725:3 753:11 758:3,6,11,15 757:6 breathing 659:4 briefly 782:22 brine 655:5 656:16,17,18,22,22 657:5,10 Savage, James (Aroclor Dept employee) in AETNA (4) HARTOLDMONO010373 [bringing - clean] bringing business (cont.) catalyst chemist 717:15 757:4,10,22 769:15 690:17,20 691:5,6,10 730:5 655:2 727:22 728:2,7,9 brio byline 731:7,15 chief 683:11 778:20 category 655:2 727:21 broader bypass 705:15 715:20 767:4 778:6 chlor 743:14 774:5 736:6____________________ cause 693:5,7 broadly c 709:3,5 chloride 730:1 774:10 broadwell 651:16 brock cahokia 669:13 calcium 657:21 causing 661:15 668:6 caustic 655:5 661:6,19 744:14,15 731:15 chlorination 730:4,7,9 776:5 chlorinators 648:8 649:4,6 650:7,13,19 651:1,6,12,14 652:4,8 662:19,22 670:6,8 676:9,11 687:5,8,16 702:13,16 704:11 707:22 708:2 call 750:9 called 647:16 656:15 657:8 665:3 700:12,14 707:17 719:2 745:6,7 cayard 758:8 cell 653:22 654:20 655:14,16 710:14,17712:13,15 740:3,11 741:3,8 744:20 655:18,20,21,22 661:21 731:9 chlorine 661:19 chlorobenzenes 667:3,6 chlorophenol 716:15,17718:13,15 721:11,13 724:5,7 727:9,11 745:2,13 747:22 751:2,19 772:10 775:16 700:2,2,5,8,10,14 701:7 cells 703:9 705:8 706:5 choccolocco 731:22 732:2 734:11,16,19 Cambridge 738:14 739:16,18 750:13 750:18 752:20,22 759:15 760:7 campaign 759:17 765:7 768:6 770:22 777:4 780:6 782:16,19 719:8 Canada 784:15 785:6 790:9 brought 775:16 bryant 728:6,7 buckley 758:16 cap 684:19 capital 681:11 car 696:7 budget 737:21,22,22 738:5,12,12 budgets 742:20 building 731:11 747:4,5,10 749:20 781:15 carbon 773:10,21 774:2,7,8,16 775:7,10 carbonate 648:3 680:3,4,6 buildings 754:1 built 674:7 bulletin 691:16 care 710:5 754:1 carefully 662:1 carried 653:15,17 660:19 693:10 737:2 693:11 chuck cellu 698:22 776:11 740:3 chunks cerro 731:10 667:18,22 668:5 669:8 circle certain 650:16 690:2 720:5 721:15 722:14 circled 739:4 740:5 743:18 761:19 772:20 786:7 circulate certainly 656:17 686:2 697:6 738:2 739:12 circulated 788:15 769:2 chance circumstance 652:12 670:9 702:17 708:4 722:5 710:18712:18718:17 civil 724:8 727:13 763:13 647:7 765:10 777:8 claim changed 715:8,10 726:14 671:19 673:22 674:2 753:7 claimed changes 669:16,18 676:1 736:16 662:6 672:8 claims charge 659:7 668:4 678:18 705:6 666:13 683:15 burial 665:11 burnett 648:1 649:5 650:15,20 651:4 704:4 738:6 780:5 784:17 785:4 790:10 burning 767:16,18 business 680:13 681:2 686:12 695:20,22 706:8 714:16 657:10 cars 745:20 746:4,7,17 747:1 748:13 case 647:10 659:18 714:21 721:10 cases 715:1 castle 647:3 casualty 756:9 Charlie 650:10 757:3 check 661:7 chem 740:3 chemical 659:14,17 660:20 691:15 695:2 728:10 772:2 chemicals 678:18 686:11,13 739:21 707:1 710:7 714:3,5,14 715:4 726:11 clarence 696:7 clarifier 657:1,3,11,12,15 classic 659:18 clay 684:19 clean 710:6 719:3,10 736:22 717:11 720:2 740:2,4,6,11 647:9 740:7 748:4 757:11,15,20 739:7 740:13 741:12 743:14 764:1 769:16 783:8 Savage, James (Aroclor Dept employee) in AETNA (4) HARTOLDMONO010374 [cleaned - conversing] cleaned company (cont.) 738:22 739:13 682:20 703:22 704:2,8 cleaning 721:17 723:18,21 724:1 737:6 740:16 756:22 769:17 cleanup 785:1 787:18 789:13,16 651:15 719:2 720:20 790:5 clear company's 693:7 669:9 clearer compatible 687:13 747:8 clearly compensation 789:5 787:9 cliff compile 654:22 652:17 climate complaining 726:5,8,10 676:5 closed complaints 687:3 659:8 675:5,8,10,17,18 closely complete 705:1 720:17 782:14 closure completely 686:18 696:2 719:12 coal compliance 701:18,19,22 763:8,21 cold complicated 746:11,13 655:12 747:18 column component 688:3 705:20,21 748:3 740:21 741:1,6 770:14 779:2 comport columns 656:8 673:2 747:19,21 composition coming 691:14 675:13 689:8 736:10,15 compounds 737:7 786:4 787:4 674:16 675:6 comment concern 706:17 660:6 661:17 662:7,10 comments 681:14 699:17 703:19 775:16 704:8,17 716:7 725:7 commerce 726:17 648:10 concerned commission 661:22 737:15 738:1 716:2,8 763:19 concerning committee 662:3,15 676:18 682:14 760:14 689:17 696:7 697:11 702:8 common 702:9 708:13 711:1 712:10 657:22 772:9 716:2 717:16 720:20 commonly 726:13,19 728:20 733:5 657:8 736:3 755:5,8 760:3,21 communications 763:2 779:19 755:4,8 concerns companies 661:13 690:4 779:11 676:5 727:4 784:9,19 785:1 concluded 785:20 787:21 788:4 790:15 789:13 790:5 conclusion company 671:5,10 647:5,9 648:7,15 668:5 condenser 772:10 774:18,19 condensing 772:11 condition 719:15 conditions 730:16 conducted 689:12 conference 759:20 760:3 confidence 756:8 confident 782:13 confidential 721:2 723:12,19,21 732:8 735:8 790:12 confused 660:2 conical 656:15 connect 678:20 698:16 connected 747:20 connection 663:21 676:19 685:13 701:20 711:8 712:22 713:21 716:19 718:21 719:11 720:13 732:5 734:21 736:10 738:18 742:12 754:13 765:16,20 766:13 768:19 776:5 777:13,16 782:10 consequence 780:22 consequences 780:13 considerable 715:10 consideration 778:9 considered 723:11 738:10 consist 655:10 657:6 775:8 786:21 consisted 747:17 consisting 700:3 construction 655:19 consumed 700:6 739:11 consumption 660:21 781:5 contact 709:11 748:3 771:17,19,21 772:6 774:17,22 contacted 772:7 contacts 662:2 716:1 contain 659:5 722:7,21 723:9 contained 713:15731:10735:13 774:19 contains 657:7 691:7 contaminated 664:19 669:19 720:9,13 contamination 666:7 668:6 705:7 707:4 719:4,10 contemplated 681:20 content 712:4 715:15 contents 745:18 context 661:16 705:19 772:8 785:19 continue 660:19 682:12 continued 647:22 650:6 671:9 continuous 661:12 670:20 671:6 674:1 674:5 contradict 709:6 contrasting 734:6 contributors 679:22 control 672:15681:4,5 688:18,22 711:1,8,13712:3,10 737:14 754:19 759:19 760:21 762:5 763:11,18 764:7,18 776:6 controversy 722:1 conversations 696:10 conversing 696:12 Savage, James (Aroclor Dept employee) in AETNA (4) HARTOLDMONO010375 [conversion - dick] conversion country dealings depositions 781:10 704:18 685:7 686:6 760:9 763:5 714:14 converted county 786:21 derivatives 673:9 647:3 decades 667:3,7 cool couple 704:8,12,13,15 des 772:7 681:13 704:7,12,13,15 december 757:18 coolant course 716:18 describe 772:3 683:2 725:20 727:17 743:6 decided 682:21 756:12 774:13,14 cooled court 683:22 777:20 described 772:4 647:1,20 decision 650:9,21 666:22 668:9 cooler cover 684:15 718:1,7 719:9 731:4 677:19 680:7 685:10 709:11 710:15711:18 decisionmaking 691:14741:11 751:19 cooling covered 717:12 describes 772:6 774:17,18,22 667:10 decontaminate 681:13689:11 copied creek 720:8,12 describing 681:8 668:15,15,16,18,20,22 decontaminating 762:14 copies 669:6,8,11,18,21 736:22 719:16 720:5 description 712:2 766:1 737:6 deemed 665:6 666:19 667:12 720:4 copper current 684:6,8,21 745:3 667:18,22 668:5 669:8 714:17,19 732:19 defendants descriptive copy customer 647:11 753:18,19 670:13,17 694:21 702:21 730:21,22 731:2 definition designate 711:19712:21 716:18 customers 781:13 790:11 718:20 722:8,9 725:19 730:13,19 752:8 degree desirable 732:17 735:6 738:15 cv 677:8 742:2 684:6,9,21 754:12 768:20 769:4 771:3 647:8 degrees destroy 777:11 cylindrical 745:5 721:2,5 722:6,9,14,18 copying 656:14 delaware 723:6 732:9 735:9 681:19 735:18 d 647:2,14 648:3,5 758:15 destroyed corner dallas demand 721:16 722:1 694:18 772:16 corporation 756:17 corps 760:16 707:15,16 damage 661:15 date 663:16 677:1 688:5 765:22 762:17 denora 653:15,17,22 654:7,20 655:9 656:1,7 693:8,9 department detail 674:19 703:14 782:15 detailed 776:2 details correct 771 '9 652:1 665:16 675:13 682:1 672:7 764:20 775:4 659:14 668:2 670:14 673:6 690:11 694:21 703:10 715:1 735:19 750:3 771:7 782:15 790:1,2 correctly dated 652 5 695 5 724 6 727 10 736:1 738:17 dating 704:13,14,15 692:20 693:14 699:2 703:2 detected 703:7 706:10 718:4 719:16 667:4 721:22 725:9,15 729:12 determination 732:4 736:6,11,17 738:16 695:1 742:2,5,6,9 743:4,9,17 determined 714:22 correlation 757:2 correspondence 662:15 dave 743:1,7,12 759:4 day 698 18 762 8 15 19 764 8 773 9 10 744:10 750:3,21 757:14 766:2 767:7 769:7 departments 675:9 703:10 717:22 department's 656:7 734:4,5 788:7 determining 689:4 768:18 develop 671:6 corroon days 726:20 developed 648:2 cost 651:15 717:19 762:16 dead depleted 656:17 750:22 development 664:12 737:14 751:10 752:4 781:4,5 costs 668:15,15,16,18,20,22 669:6,18,21 698:10 Hp^rllinp depose 698:11 deposed 707:17 728:18,20 757:22 developments 726:19 664:3 695:2 736:3 counsel 647:17 679 16 20 dealing 679:13 696:6 778:2 714:8 device deposition 772:11 647:13,16 649:8 790:11,14 dick 757:13 Savage, James (Aroclor Dept employee) in AETNA (4) HARTOLDMONO010376 [died - emery] died dispersion dodd duty 757:1 751:21 759:10 767:5 769:22 773:3___________________ difference disposal doing e 734:4,5 780:21 differences 651:21 672:9 688:10 695:2 660:8 677:19 759:12 695:9 735:14 765:20 786:20 788:12 eagleson 776:20 745:1 766:10,15 787:3 different dispose 651:9 691:22 692:1,1 719:15 722:10 726:6 744:21 745:4 disposed 749:10 657:15,17 658:2,4 672:19 dolin 727:20,21 dotted 743:1 double earlier 683:4 689:22 693:6 723:21 early 652:18 666:12 704:3 714:16 715:16 765:21 digging 673:1,12,16,21 690:10 680:3 777:17 782:5 733:21 734:8 dilution 745:5 direct 660:13 742:22 758:5 695:3 699:17 730:13 735:16 784:4 dissemination 723:17 dissolved dozens 782:11 drain 736:5 draw earnings 681:12 easy 676:22 economic 771:16,19,21 772:5 774:17 775:8 661:8 654:2 774:17,21 directed distillation 691:2,12 692:4 740:19 drawing 649:9 economical 672:6 777:21 712:22 727:16 732:4 734:21 738:17 768:10 777:12 789:18 747:18,22 distilling 748:2 drew 650:9 driven economics 781:1 edge directly distinction 681:19 686:8 716:5 748:2 743:22 772:9 driver 663:20,21 666:19 edwards 772:6 distinctive director 747:20 740:4 753:16 757:4,7,10,16 distinguish 651:17,17 driving 652:1 667:20 726:16 757:19 ee 680:3 757:22 769:16 disbanded 733:20 distinguished drum 665:4,6 746:11 effect 659:8 707:2 709:22 715:3 740:5 744:22 drummed 730:9 discharge 675:6 773:9 774:15 775:1 781:21 discharged 708:21 775:10 distribution 731:14 754:9 755:22 division 756:20,21 757:10 758:8 762:22 763:2 672:19 drums 735:14,16 746:6,7,9 due 713:14 734:1 747:12 effective 752:4 efficient 751:3 effort discharges document duebner 677:10685:17719:14 705:7 707:2 discuss 706:16 759:21 789:7 discussed 693:5 762:12 652:5,14 662:20 663:2 667:12,16 670:7,10,11 674:4 676:10,13,16 678:2 687:12,21 689:18 702:14 702:18,19 707:6 708:5 698:22 duggan 759:2,2 duly 650:4 739:7 efforts 720:11 726:7 776:4,6 either 691:10,21 693:9 714:13 discussion 687:6 715:3,7,11,14,17 716:6 721:12 726:13 734:12 739:17 750:14 754:19 759:16 778:1 710:19,20 711:18712:14 712:19 715:20 716:15 718:13,18 721:4,5,22 722:13,17,18 723:2,6,6,20 724:5,10 725:6 727:9,14 dump 672:19 673:17,21 767:17 768:2 dumped 694:7 697:15,18 698:3 716:11 728:9 763:6 electrical 730:21 electronic 769:17 782:17 729:4 732:1 735:22 736:1,1 dumping elegant discussions 720:19 726:10,15 727:1,3 737:16 738:3,7 756:1 765:8 698:3 767:16,17,20 765:10,12 768:7 771:1,4,9 dumps 781:13 eliminate 789:11 dismantled 719:13,17 773:6 777:5,8,9 782:21,22 736:7,19 783:2,3,20 dunnavant documents 776:15 696:4 771:10 emergency 764:11 dismantling 719:20 720:17 649:24 653:12 687:12 duties 707:22 711:3 721:15 722:3 753:22 756:14 766:13 emery 740:13,15,15,17,22 741:6 dispersed 722:15 723:4 754:10 769:8 742:11 743:12 750:7 751:3,4,19,20 779:13 Savage, James (Aroclor Dept employee) in AETNA (4) HARTOLDMONO010377 [emission - february] emission equipment excluding explained 725:11 719:13 720:5 764:15 714:3 779:2 684:16 emissions erap exhaust expressed 725:16 726:2,7 663:9,14 665:18 772:11 661:13 690:4 790:5 emphasis error exhibit expression 703:21 704:1,3 695:5 722:7,8 649:9,10,11,12,13,15,16,17 673:7 emphasized escalating 649:18,19,20,21,22,23,26 extensive 704:20 704:8 649:27,28,29,30 650:14 747:15 employees esq 651:13 652:3,4 662:18,19 extent 787:17 648:1,8 665:5,17 666:17,22 667:15 667:20 671:6 751:16 employment essentially 668:10 670:5 672:14 676:8 f 676:20 713:1 716:20 718:22 725:20 727:17 732:5 734:22 738:18 754:13 765:16 777:13 ends 671:16 744:15 ester 691:19 692:2 esters 680:5 691:22 692:1 687:18,18 689:16 694:11 701:8 702:12,13 705:11 707:21,22 708:4,8 710:13 710:14712:12,13 716:14 716:15718:12,13 721:1 face 723:5 facilities 754:1 765:4 785:11 facility 652:11,22 653:7 654:11 et 724:4,5,13 727:8,9 731:21 680:4 656:5 687:20 694:15 713:9 647:10 715:19 716:22 729:3 evaluating 731:22 734:17 735:18 738:15 754:16 759:18 fact 660:3,18 718:6 732:17 754:16 759:18 760:21 762:5 763:12 764:7,18 773:7,14 775:15 778:5 784:3 event 689:8 726:14 760:20 761:1 762:3,3 763:11 764:6,19,19 765:6,8 768:5,7 770:21 771:1 769:19 failure 706:1 engineer 654:17,22 683:9 697:2 eventually 756:22 775:6 775:14 776:8 777:3,5 782:18,20 fair 695:17714:10 699:5,6 707:8 728:10,12,13 evident 767:8 776:12 778:22 660:18,22 780:18 engineering exact exhibits 649:14,24,25 687:7,8 734:14,16 752:18,20 fairly 715:16 747:18 772:9 783:4 familiar 681:16,22 757:14 engineers 753:17 exactly 790:11 existed 653:11,14 663:9,21 664:2 664:19 665:3,9,19 666:6,20 660:13 743:6 760:17 704:6 740:2 664:8 666:21 667:6,13,18 668:4,9 761:11 entail 729:16 entailed 730:3 examination existence 647:17 649:2 650:6 780:18 686:12 784:16 785:5 expansion examined 765:4 650:5 expectation 668:16 669:11 674:16,19 675:1 677:14 685:18,20,22 686:4,17,20 690:14,15,18 691:4,13 693:2 696:22 697:11,18698:3 699:1,16 entered examining 780:7 764:21 767:18 769:13 655:20 entire 706:10 738:3 745:18 entirely 744:4 738:6 781:1 example 666:10 676:5 679:7 683:5 684:12 690:14 726:13 742:5 expenditure 677:11 737:18,19 expenditures 649:11 663:7 681:11 737:15 771:13781:21 far 717:13 fashion 660:22 661:1 entries 739:4 environment 764:6 environmental examples 733:9 exception 788:17 exceptional expense 736:12 expensive 653:21 experience fate 660:5 fatty 741:8 750:7,7,9 favoring 663:6 754:19 759:19 705:22 722:19 704:19 718:4 760:21 761:2 762:4 763:11 exceptions 764:17 721:21 experiences 704:21 favorite 712:16 envisioning 747:2 748:14 epa excessive 713:15 exchange experimental 656:12 expert feasible 671:5 feature 689:19 690:4 715:12 772:1 724:15,18 755:1,5,8 760:3 exchanged 748:21 expertise 781:18 february 761:18,18 762:1 763:15 784:1 685:6 710:14765:15 764:9,14 Savage, James (Aroclor Dept employee) in AETNA (4) HARTOLDMONO010378 [federal - governmental] federal flow (cont.) frame (cont.) generally 712:5 725:9,11,14 761:11 765:16 768:12 769:9 652:9,16 656:20 670:9 fence flowed 783:18 786:8,12,15 674:10 689:18 692:5 695:8 683:22 684:5 737:2 669:18 670:1 frank 711:5 719:19726:1 741:15 ferric folklore 778:21 742:17 788:13 731:15 669:3 free generated fields following 788:19,21 677:8 708:8 774:8 671:4,8 708:9,10 684:12 frequently generating fifth follows 661:11 675:21 782:4 647:19 650:5 friday generation figure force 647:15 663:14 672:22 726:16 front generic file forecast 666:17 667:22 738:3 722:14 745:3 702:3 772:17 737:16 fuhrmeister generically files foreman 770:18 753:1,21 702:6,8 721:19 660:9 full george filter forget 735:21 736:1 758:14 693:13 650:20 fumaric gerry final form 744:13 745:2 751:9,10,16 728:9 757:5 752:1,2 764:20 781:10 663:2 680:8,18 745:14 751:17 give financial 775:10 function 651:2 744:9 747:16 751:12 681:7 737:16 formal 745:10 750:1,4 787:1 789:10 find 744:4 functional given 661:5 formally 743:17 660:14 666:19 667:12 fine 743:13,16 744:1 funneled 788:19 650:15,19 651:4 formed 747:3 gives finished 751:22 furlow 672:22 658:19 720:2 forth 647:18 glance fire 719:14 726:7 further 652:9,12 653:6 670:10 785:11 787:13 790:3 fortification 647:16 650:5 682:3,12 687:17710:18712:18 first 745:2,5 751:10 726:19 784:15 785:4 790:9 glitch 652:5 653:1 655:10 663:1,5 fortified 790:10 735:19 666:18 674:4 680:2 687:17 745:4 751:4,6,16 fyi go 689:15,18 699:12 707:6 forwarded 721:2 655:11 656:11 658:6 661:6 708:7 713:5 714:10 716:22 783:18 717:3 724:13 732:15 forwarding 739:19 740:8 751:14 733:6 775:17 776:9 found fish 675:2 736:16 g galloway 756:3,6 759:12 761:4,7 767:5 664:18 667:11,20 668:18 690:7 693:1 694:11 699:10 704:5 707:6 708:7 712:16 721:19735:18738:15 742:13 754:16 759:7,18 661:18 662:7,11 fit four 741:14 770:1,2 760:20 762:3,4 763:10 764:6,17 771:17 775:14 748:17 fits 726:8 fitzgerald 756:20 five 760:14 762:15,16,19 flare 764:11,12 flint 758:12 floor 647:19 648:11 flow 651:10 655:14 659:3 fourth 667:11 frame 652:18 656:9 659:20 662:11 664:16,20 665:20 655:5 675:14 676:6 731:14 geared 787:8 general 653:5 666:15 673:3 674:22 778:5,19 779:1 788:10 going 665:20 677:9 682:20 686:16 696:4,7,13 703:5 706:9 726:7 729:12 730:2 666:4 670:17,21 677:5 679:4 682:19 685:1,11,12 738:6 760:17 761:13 762:1 678:12,17 679:4 685:19 686:1,7 688:10 689:5,20 688:12,16 703:18 719:8 724:17 726:5 729:11 763:1,10 774:21 776:4 787:7 690:3 695:10 697:5 702:10 703:3,18 705:5,6 706:6 708:9,13711:12713:22 743:11 744:9 753:12,14,20 753:22 754:4 756:19,19,21 757:5,9,19 758:1,7,10 gotten 701:5 731:5 government 714:1,3,6 716:3 717:8 718:10 719:5,6 720:1 766:16,19 768:21,22 770:15 771:16 779:4,14,18 702:4 703:22 704:2 715:17 governmental 724:16 726:3 728:21 739:8 781:18 787:1 702:9 715:8 726:6 755:5 756:15 763:16 Savage, James (Aroclor Dept employee) in AETNA (4) HARTOLDMONO010379 [grade - indicates] grade happy 751:11 783:20 grades hard 744:21,22 676:14 733:4 746:10 grammatical harness 741:16 692:9,10 grapevine harold 678:21 679:5 756:16 graphite harry 700:4,4 757:15 gresham hastings 654:21 655:1 758:6 ground hauled 668:6 739:15 groundwater hauling 736:6,17 679:17 group hcl 654:22 680:13 681:2 733:21 734:8 686:12 688:18 692:11 head 695:22 697:4 706:8 707:15 697:3 757:12 773:4 707:16,18 714:16 717:12 heading 720:3 739:22 740:1,3,4,4,6 663:11 672:15 680:3 740:7,11,14 741:12 761:3,3 697:10 773:8 776:9 778:21 779:21 787:21 hear group's 664:14 695:20 heard growing 663:10 664:4,6,9 666:10 704:17 669:15 670:1 678:17,21 guess 679:5 753:11 698:11 721:7 722:22 734:3 hearing gyp 759:20,21 760:2 657:8,14,19______________ hearings h 761:20 762:1 h2s 764:11 hand heat 772:1,1 heated 677:1 694:18 699:10 732:8 732:16 770:13 772:16 788:20,21 handle 746:7,9,11 774:22 handled 746:12 heating 748:1 heavy 680:9 heilala 681:21 724:2 handling 654:18,19 heininger 758:10 774:21 handwriting 757:20 heisler 653:2 696:19 699:11,15 701:9 732:22 735:2,3 772:16,18,19 773:2 handwritten 699:12 helmer 778:20,21 help 696:17 happen 698:19 high 675:16,21 710:1,2 happened 709:10 757:14 higher 709:14 746:21 751:16 highly illinois (cont.) 723:11 690:4 718:8 highway immediate 684:1 774:11 hill imminent 759:8 772:19,22 773:1 717:5,8 history impact 722:4 654:2 733:12 hold impetus 700:9 672:4 678:8 684:14 689:3 homer 703:16 704:16 651:16 implemented homogenization 674:6,11 751:18 implicated hooker 661:20 693:10,11 700:2,10 implication hope 721:7 734:3 757:2 implies hose 692:2 707:19 772:6 747:2,7,7 imply hosmer 692:3 757:18 imposed house 679:20 653:22 654:20 661:22 impoundment 700:11 668:12 howard impressions 743:13,16,19 744:1,5,5 787:2 757:12,17 758:9 759:11 improvement hutchison 649:30 697:4 716:2,8 783:5 776:13 impurities hyland 700:22 776:17 impurity 657:22 idea 690:19 692:7 756:17 766:16,19 incident 705:22 734:10 incineration identified 649:8 651:13 652:3 661:18 662:18 670:5 676:8 677:16 678:7,12 679:21 687:7 702:12 707:21 710:13 712:12716:14718:12 724:4 727:8 731:21 734:15 752:19 761:19 765:6 768:5 770:21 777:3 782:18 identify 767:17,22 incinerator 784:3 include 706:10 746:13 754:3 included 652:2 672:12 including 659:9 726:10 incomplete 653:16 654:5 655:8 680:2 753:2 767:3,12 iepa 689:17 ii 773:13 738:7 increasing 703:21 704:1,2 indented 717:3 indicate in 778:6 illinois 670:16694:20 711:19 732:16 735:5 754:12 indicates 666:11,15 669:13 689:19 769:19 Savage, James (Aroclor Dept employee) in AETNA (4) HARTOLDMONO010380 [indirect - knowledge] indirect 748:1 772:2 indirectly 686:9 716:4 individuals 753:10 industries 740:17 industry 662:13 740:20 infer 705:19 738:9 information 692:5 695:12,13 702:4,5,8 721:8 722:21 723:9,10,11 723:16,17,20 733:5,7 informed 716:5 initiated 671:11,20 725:10 726:21 initiation 672:5 initiative 671:7 injuries 676:1 ink 745:11 inlet 655:20 input 706:13 inside 731:9 772:5 inspect 764:15 inspection 689:17,19 inspections 787:7,14 inspectors 785:9 installed 779:8 instance 661:3 714:21 769:7 instituted 662:6 682:9 instructed 677:17 721:18 instruction 721:5,9,21,22 723:5 732:7 732:12 735:8 instructions 721:14 722:6,9 insurance issues kanawha 648:15 727:4 784:8,19,22 682:15,18,22 683:1,7,12,18 760:17 772:14 775:3 785:20 787:17,21 788:4 690:2 695:21,22 702:8 katzenstein 789:12,16 790:5 703:18 743:14 764:22 647:18 intensity item keep 660:2 733:21 734:6 716:5 722:2,4 intention items keeping 672:11 656:11 738:4 702:7 interest j 740:21 741:2,6 769:6 790:6 internal ja 647:8 745:9 interpreting 712:6 interviewed 697:11 jack 758 11 770 2 789 6 james 647:13,16 648:1 649:3 650:3 790:17 interviews kellogg 767:7 769:22 kept 725:1 kilbourne 757:15 kind 651:22 652:2 669:3 678:21 682:19 683:15 701:2,2 697:10 introduced 677:2 736:1 737:12 753:5 jerry 710:8 729:2 741:19 744:2,2 749:10 756:19 757:8 748:2 inventory 660:5 689:9 728:11 jersey 758:15 758:22 kinds 691:5 749:11 investigate 662:1 jet 772:8,8,9,11 774:11,15,21 knew 669:21 692:11 730:15 investigated 660:1,7 685:9 729:21 investigation jim 698:15 728:6,7 729:5 756:18 759:2 769:14 779:21 knollmeyer 758:14 659:19 660:8 670:19 671:7 729:6,9,19 730:4 766:10 job 706:4 707:10 741:9,17 know 652:12656:1,10 658:5,13 777:15 752:15 753:21 755:14 665:7 666:4 667:13 670:10 investigations 654:6 660:12 703:5 involve 720:8 involved 756 13 757 22 758 9 17 759:4,11 769:8,18 773:3 john 654:19 688:3 707:8 728:1,4 740:3 758:2 673:16,20 674:20 676:12 679:3,9,18681:17682:17 686:4 690:16 691:16 692:13,19 693:4,6,13,19 694:1,2,2,4,5,8,8 695:13 683:16 692:14 695:1 joined 696:9 697:8,22 698:9,13 699:20 700:1 705:2 711:17 712:6,8 713:6 716:5 717:12 719:16 720:5,19 743:20 744:7 758:10 766:5,9 involvement 714 15 740 1 joint 729:1 740:12,18,19 joints 747 Q 742:2,4 699:7,9 700:19 701:1,13 702:17 705:5 708:3 710:6 710:11,19712:8,11,17 718:9,16 720:15 721:6 723:13 724:9 727:12 730:3 660:11 663:14 664:11 755:7 761:15 763:6 765:3 778:14 782:3 784:2 involving 763:22 774:14 judgment 782 14 judith 669 12 july 733:19 735:12,16 736:19 739:15 745:16 747:12 748:20 749:14,14,15 753:9 754:6 755:18 756:13,14 757:18,21 759:3,11,14 iron 679:16 688:6 738:17 739:8 760:15 761:9 763:12,18 731:10,13 isopropanol 771 '9 june 764:11,13,21 765:11 767:2 767:10,13 768:2 769:14 768:18 issue 677:15 678:6 682:13 683:6 649:23 783:18 justice 725:9,15 726:19 770:3,6,8,10 775:12,19,21 776:1,3,7,14,16,19,22 777:2,7 778:16 779:5 785:7 695:19 744:7 785:14 786:18 787:16,22 issued k 788:3,6,7 789:20 703:1 769:1 788:4 k&e knowledge 687:14,15,20 651:19682:19700:13 Savage, James (Aroclor Dept employee) in AETNA (4) HARTOLDMONO010381 [knowledge - low] knowledge (cont.) landfill learned listing 701:21 730:19 779:14,19 664:2 665:18,19 666:19 662:10 669:15 678:18 690:10 784:18 788:16 789:4 667:7 676:19 677:9,12,12 714:18 766:16 literature knowledgeable 677:15,16,18,20,21 678:3,4 learning 652:17,21 662:13 665:14 666:1 685:8 678:6,10,15,19,22 679:2,17 725:14 little known 682:14,15,18,21 683:6,18 leaving 650:16,21 651:8 735:4 659:17 683:2 698:20 684:2,5,15 685:10,19,22 656:18 660:22 661:2 774:5 785:21 686:18 689:5,17,19 690:2,5 774:19 lives koh 690:11 694:6,7 695:3,21 led 754:6 658:14 696:3,8,13 697:12,15 685:17 710:8 load kountz 698:18,21 699:8 702:8 left 682:12 681:15,16 landfills 652:20 655:20 657:9 loading kozacka 651:21 677:5 681:18 663:16 674:8 695:15 720:2 682:4 762:13 774:5 757:13 682:16 683:8 685:1,3 732:16,19 741:11 loads kristine 688:11 699:17 702:9 legal 682:9 647:19 landwehr 666:14 713:6,9 714:5,12 located krummrich 736:2 737:11 716:8 717:4,7,16,18 778:10 652:18,20 653:17,22 654:8 lane letter location 656:2 659:10,13,21 660:16 669:12 733:1,4 755:1 677:15 661:14 662:4 663:22 664:3 large level locations 664:15 665:1,10 666:2,4,8 656:14 671:16 744:20 656:6 719:15 732:19 778:7 667:7 671:2,12,21 673:18 larger 733:16,19 734:1 757:14,22 long 674:8,17 675:19 677:8,21 653:22 661:16 681:20 levels 663:16674:13691:9 741:9 678:1,4 679:18 680:14,16 late 660:1,8 753:11 682:14 685:21 686:17,18 682:10 686:18 704:10,17 liberty longer 689:19 690:5,22 691:17,21 786:11 648:14 785:3,8,15,18 695:6 778:1 692:3,4,12,16,20 693:14 law life look 694:6 695:15 696:8 697:2,6 647:17 717:22 718:4 661:15 655:3 656:5 688:5 695:12 697:12,16,19,20 698:8 721:22 light 702:18 708:4 718:17 724:8 699:3,20,22 700:1 701:17 lawsuit 779:6 727:13 733:3,15 735:6 701:19 703:2 705:8 706:5 663:20,21 666:10,20 likelihood 755:22 765:10 777:8 706:15 707:3 711:1,9,13,15 725:15 726:14 784:8 715:11 782:12,22 785:10 712:3 714:13 716:11 719:5 lawsuits likewise looked 719:11 720:13,15 724:19 666:7 707:2 712:9,9 713:4 746:22 676:13 728:2,3 729:6,10,13,22 713:14,19,20 714:4,8,9,16 limestone looking 754:3 757:6 758:13 759:3 726:1,11 738:22 739:8,10,14 736:4 751:22 756:1 781:3 768:15 770:16 784:20 lawyer lindemann looks 786:6,12,14 712:1 779:3,3 688:8 771:13 772:19 kuhn lawyers line loss 758:3 711:22 658:20,22 659:3,5 721:1 781:16 1 lab 688:13 label 737:21 labeled 705:20,20 laboratory 728:3 lagoon 650:22 651:5,7 lagoons 664:14 land 780:22 leaching 737:21 743:1 736:5,9 lines lead 653:20 703:13 726:15 699:16,17,19 700:1,5,7,8 727:1,3 700:17,18,21,22 701:4 liquid 774:15 680:9 718:1,5 745:15 leader 767:16,20 707:15,16,18 778:21 liquor leads 709:2 669:1 772:22 list leakage 692:8 693:1 754:9 755:22 675:2 678:18 710:8 756:12 leaks listed 658:17 735:13 745:22 656:11,12 670:13 702:21 learn 707:11 729:17 756:18 675:18 743:8 766:14 789:9 769:19 771:3 losses 653:15,17 654:2,4 656:6 703:6,18 705:15 706:4,11 706:19713:14719:7 733:17 734:1 768:19 772:8 774:12,15 780:21 lot 683:3 697:22 lou 697:2 louis 676:19 677:5 678:2,3 754:5 754:7 low 730:10751:10,11 761:11 Savage, James (Aroclor Dept employee) in AETNA (4) HARTOLDMONO010382 [luecken - milky] luecken manufacturing (cont.) mco memorandums 728:1 744:6,7 751:1 754:13 757:3 702:14 662:16 lying 757:7,9,18,20 758:2,3,18 mean memory 669:12 766:13 771:7 778:17 653:6 678:7 684:8,18 719:22 lynch 779:12,20 780:9 782:4,8,11 693:20 701:14,22 704:13 memos 770:5 map 710:1 714:20 723:9 737:19 721:20 m 667:14 670:3 749:8 771:22 779:13 781:2 men machinery 788:4 machining mark 650:13,21 687:13 marked 783:7 788:22 meaning 705:5 748:18 751:4,17 753:9 mentioned 651:16662:13708:11 731:12 macpherson 728:4 main 651:10 668:20 673:7 744:11 651:12 652:4 662:19 665:5 781:3,9 790:1 714:7 723:20 742:1 761:4 670:6 676:9 687:8 702:13 means 781:6 784:10 707:22 710:14 712:13 673:8 701:13 747:22 772:8 mentions 716:15 718:13 723:20 meant 693:16 736:12 724:5 731:22 734:16 717:7 719:6 mercury 752:20 765:8 768:7 771:1 measurement 652:17 653:15,17,21 654:2 maintenance 699:2,3 767:6 770:2,3 major 679:22 709:2 making 748:22 749:8 751:15 777:5 782:20 market 647:18 648:4,12 mass 744:16,18 745:14 751:18 massachusetts 762:15 774:5 measures 762:17 774:6 measuring 762:13 774:4 mechanical 654:4 655:5,15,20 656:6 658:9,20 659:1,2,5,9,13,16 659:20 660:4,16,19,21,22 661:2,5,14,17,19,20,21 662:3,7,11 merman maleic 691:7,8 751:9 man 760:7 material 653:21 657:4,6,20 673:7 706:1 728:13 736:12 776:12 mechanism 758:15 mersize 740:11 742:2 743:9,10 760:14 management 677:9,18 678:9 689:4 693:15 697:15 701:2 660:21 medical 744:10,11,19,20,21 745:8 745:13 746:4,16 747:11 665:15 743:14 757:4,19 manager 671:18 677:6 681:3,4,4,16 683:9,10,17,21 685:4 686:10,14 695:18 706:9 711:14737:13741:19 742:13 751:1 753:4,6 754:14 756:19,21 757:6,20 708:19,20 710:9 719:16 717:22 731:12 739:10,13 741:3 medium 744:11 746:10 747:8,12 777:21 748:6,16 749:19,21 750:2,5 meet 750:7,20 751:4,6,19,22 675:12 786:19,22 758:10 774:20 780:20 meeting 781:4 649:21 717:11,20 725:4 materials 728:15,22 729:1,2 762:21 750:2,20 751:2,15 752:3,8 781:12,22 782:5 metal 731:9 method 694:5 746:7 762:13 methods 672:9 765:20 766:10,15 758:2,3,11,12,12,14,21 761:7 766:14 767:14 769:15,20 771:7 778:17 779:12,20 786:10 789:7 manager's 755:19 787:1 manifest 704:3 manner 673:2 manta 648:9 651:20 653:5,10 661:10 775:17 778:1 665:10 674:17 681:18 meetings methyl 690:10 694:6 695:18 696:4 706:15,18 724:13,17,20,22 693:17 696:7,13 697:12,18 698:4 725:1 728:20 763:1 787:2,4 meyer 748:5 769:17 775:8,13 melted 650:10,16,18651:3 781:10 700:7,18,21 microfilm matter melting 773:19 653:11,13711:17743:18 701:1 709:10 mid 779:14 memo 711:4 matters 677:19 679:3,16 680:10,15 middle 664:12 712:10 744:2,3 681:12,20 682:2 683:5 729:5 773:18 754:20 759:20,21 766:7,19 689:16 692:8 702:3 710:15 migration manufacture 690:20 691:7 741:19 745:9 787:9 790:3,4 matteucci 717:10 722:7 memoranda 678:18 mike manufactured 680:14 691:8 manufacturing 663:17 677:6,16 679:12 683:18,21 685:4 686:10,14 695:18 706:9 711:14 758:17 max 756:3,6 759:12 761:4,7 maximum 736:13 mcguire 662:14 memorandum 649:10,13,16,17,18,19,20 649:22 676:18 681:9 689:22 712:21 716:19 718:20 725:20 727:16 696:6 milk 713:15 714:3,14,22 milke 767:6 milky 737:13 742:13 743:15,20 753:7,11 758:11 767:13,14 737:11 751:22 Savage, James (Aroclor Dept employee) in AETNA (4) HARTOLDMONO010383 [mill - observe] mill monsanto (cont.) naoh nonowned 749:10 741:1 742:11 743:12 750:6 658:14 668:15 miller 756:14 758:16 763:1 natural nonroutine 728:8,9 765:17 768:11 769:17 748:21 780:22 705:21,21 mills 777:13 779:5 780:12,15 nature normal 745:21 748:7,8 749:6,7,8,9 781:8 783:9 784:8,11 785:8 675:10 678:11 697:12 723:7 732:14 733:16,19 749:12,15 750:5 752:10,12 786:1 788:5,7,16 789:12 706:3 711:11 740:18 734:1 748:1 751:16,17 mind monsanto's 741:15,16 779:18 780:2 705:2 733:11 689:8 704:19 712:9 727:4 necessarily normally mines 739:20 741:10 763:8 780:3 687:11 705:3 752:10 701:1 724:2 701:14,16,19,22 702:1 780:9,16 788:13 789:13 necessary notes minimize monsize 660:19 731:16,18 696:17 778:11 751:2,12 752:5,9 necessity notice mining month 682:12 737:21 701:18 689:11 706:20 need notices minor monthly 700:16 722:3 707:2 735:13 649:23,25 725:3 732:4 needed november minutes 734:20 753:3 709:17 724:6 777:11 717:10 725:2 months needs npdes missing 753:4,13 784:3 754:22 763:7 764:20 660:5 moody negotiation null mississippi 698:6,7 722:4 759:13 679:1 mother neighboring number mistaken 709:2 676:5 647:7 649:8 652:11 653:1,2 668:21 motivated nemeth 653:7,8,8 654:11 656:5 mitchell 689:8 688:14,15 657:19 658:6,14 665:18 757:17 motivation neutralization 676:10 687:20,20 688:2 mitigation 654:3 733:21 734:9 745:6 693:3,3,5,6,14,16,17,18,19 664:2 mud neutralizers 693:19,20,22,22 694:1,1,2 mixture 693:13 781:22 694:2,3,3,4,15 700:3 701:8 740:21 744:14 mullendore new 712:5 713:8 715:20 717:1 modest 740:4 647:3 671:9 700:8 704:9 717:11 729:4 732:1 735:21 736:13 745:1 multipage 757:22 758:15 738:21 744:21 754:17 modification 652:5 662:20 670:6 702:14 nit 759:19 760:22 762:5 771:18 712:14 765:9 768:8 771:2 777:6 763:12 764:7,18 773:7,14 molten munie 782:21 773:19 775:15,21 776:4 751:18 758:11 789:6 nitro 778:5 779:22 moment mutual 685:21 686:7,14,16 699:21 numbers 686:17 648:14 785:3,8,15,18 739:20 740:9,13 741:10,17 652:6 662:20 668:14 670:7 money n 742:13,21 747:16 748:9,11 687:10,14,15 690:7 696:15 683:3 name 749:12,17,18 750:2 751:13 702:14 705:12 708:1 monitoring 664:22 667:4 737:1 monsanto 647:5 648:7 659:8 662:15 663:15 665:10,22 666:11 651:16 652:11 665:8 680:12 687:19 688:1 694:17,18698:16699:1,13 699:13 707:13,19 708:11 728:6 740:16 742:5,7,7,10 752:14 753:4 754:3,20 755:5,8,15 756:7 758:19 759:1,3,9 760:4 761:2 763:2,7,16,22 764:4 765:14 765:20 766:11,15 767:4,18 710:16712:14716:16 718:14 727:10 734:17 765:9 768:8 771:2 773:16 777:6 782:21 o 666:14 668:2,5 669:15,19 754:9 771:3 772:20 776:20 768:10,19 769:15,21 obel 670:2,4 676:4,20 678:15,22 681:18 682:16 683:8,15 785:16,18 named 771:11 776:9 777:11,17 778:11,22 779:2,8,11,15 757:10 obeyed 690:11 692:15 704:20,21 712:1 713:1,5,20 714:5,9 714:12 715:4,9 716:9,20 680:20 names 654:12 699:11 742:10 782:1,5 783:14,17 784:4 nomenclature 723:21 721:10 732:13 object 738:6 780:5 718:22 719:4 723:5,16 724:14,18 725:16,20 726:2 749:15 756:12 769:12 776:9 778:19 779:1,6 non 647:9 objection 704:4 726:14 727:5,18 732:5 784:22 785:21,22 nonearnings observe 734:22 738:18 740:13,21 681:12 712:4 Savage, James (Aroclor Dept employee) in AETNA (4) HARTOLDMONO010384 [observing - pentasulfide] observing once overflow parentheses 701:3 670:9 721:19 765:9 771:19 656:13,18,21 657:2 658:6 707:19 obtained 785:10,10 overrun park 702:5 ones 737:22,22 738:10 711:20 712:8 obvious 710:12 752:11 767:12 overruns parking 655:14 ongoing 738:5 697:22 obviously 654:6 664:20 703:13 722:3 overview part 721:9 732:13 735:11 open 744:9 747:16 751:12 651:10 668:20 669:3,6 occasions 767:15,18 owen 670:1 673:8 686:11,12 675:1 709:13 730:17 731:3 operation 727:21 687:12 688:18 694:17 739:12 742:17 690:21 691:15 695:20 oxygen 706:12 717:18 722:2 761:8 occurred 700:2,10,12 701:7 703:19 762:17 764:4 774:6 707:20 720:16 733:22 736:10 P particular occurs 683:20 o'connor 742:10 743:11,21 764:2 776:2 780:2 781:8,14 operations p4 698:2 packing 653:12 655:4 685:6,12 688:5 689:7 695:19,22 696:11 704:10711:19 647:20 October 689:16 712:21 odor 763:21 office 654:8 655:10 656:1,7 659:10,21 660:16 666:8 672:10 674:12,17,21 675:7 686:15 693:2,8 695:22 699:20 705:8 706:5 707:3 709:17711:15,17718:5 731:13 page 652:5,11,22 653:7,7 654:11 656:5 663:5 665:6,17,17 666:19 667:11,15 670:14 672:14 674:14 676:9 739:11 742:5 766:4 parties 647:21 723:12 parts 661:18 684:19 pass 666:16 753:12,14,20,22 754:4 756:19 757:5,9,19 719:13 729:21 734:2 741:21 742:1,3,4 743:8,9 687:19 688:2,2,6 689:15 694:14 695:12 696:19 769:7 passed 758:1,7,11 779:4 offices 647:18 oh 656:10 674:9 742:16 754:4 744:10 745:17 747:15,17 748:5,17,18,19,20 751:13 752:5,15 757:10 760:3 763:2 771:11 774:9,16 775:3,11 778:3 780:8,16 698:11 699:10 701:8,11 702:3 705:11 707:6 709:1 713:8 715:19 716:22 717:3 724:12 725:5 729:3,4 732:1 735:20 736:4 738:4,20,22 668:20 669:6 path 774:12,14 paul 699:12 757:19 767:2 773:18 oil 740:20,20 741:3,8 742:6,9 743:9,12,20 744:12,12,13 747:15 748:5,6,8,14,14,17 749:1,13,17,22 750:1,4,6 781:7,22 782:5 783:14,19 operator 698:18,20 operators 675:9 opportunity 754:16 756:1 759:18 oav 760:21 762:4 763:11,12,13 764:7,7,18,18 767:15 773:6 773:14,17 775:14,15 776:9 778:5 pages 727:4 766:3 pcb 673:11 713:15714:12 715:9,15 716:3,9 717:9,16 719:2,4,10,12 724:16,18 750:10,16,19 752:11 762:7 767:9 771:11 772:17 773:9 774:9,16 775:2,11 777:16 777:22 778:3 oily 748:16 okay 652:15 670:12 676:17 687:22 690:9 693:12 694:16 702:20 708:6 710:21 712:20 717:2 718:19 724:11 727:15 754:18 762:6 765:13 769:22 773:20 777:10 780:14 old 688:16 721:20 ona 708:13 709:2,7,9,10,17 oncb 706:17 781:5 789:9 order 703:6 790:12 organic 661:15 757:14 762:13 773:10,21 774:2,4,6,8,15 774:19 775:7,10 organization 677:17 688:17,19 689:1 707:17 organize 681:22 outcome 725:4 outlet 655:21 outlined 729:5 outside 676:4 701:13 723:18 724:1 674:4 690:7 695:13 705:11 725:11,16 726:2 727:5 705:13 708:8 papageorge 717:13,15,21 733:8 735:12 papageorge's 725:3 735:6 737:1 pcbs 673:15 704:19,22 705:2 706:7,22 712:17 713:21 714:5 715:5,18 720:13 paper 650:8,9 686:11,13 739:21 740:10,20 745:10,10,12,20 748:7,8,18,22 749:1,5,6,7,8 749:9,10,11,12 750:5 752:10,11 764:1 736:16 pep 676:10 pet 719:13 pen 737:6 706:7 710:16,16 paragraph 667:2 672:18 682:3 697:14 651:2 Pennsylvania 709:6 713:5 717:3 729:4 755:1 777:19 parameters 761:19 paranitroaniline 670:20 671:3,4 648:13 penta 680:10,12,15 706:7 pentachlorophenol 680:12 pentasulfide 698:2 709:7,8 772:5 788:14 692:18,21 Savage, James (Aroclor Dept employee) in AETNA (4) HARTOLDMONO010385 [people - pr&d] people piece plant (cont.) pollution (cont.) 651:20 671:19 675:15 650:8,9 671:15 739:20 740:9 741:10,17,21 688:18,22 690:5 692:11,14 676:4 684:10 685:9,14 pierle 742:13,19,21 743:4 744:12 703:18 705:6 707:4 711:1,8 697:11 702:7 717:11 696:6 747:16 748:9,11 749:12,17 711:12712:3,10 756:7 731:11 742:19 756:13 pile 749:18,22 750:1,2,9 751:13 759:12 763:18 764:15 761:5 767:3 786:1,2,4,8,19 653:5 752:14 753:3,4,6 754:20 771:11,17 772:12 773:8 787:17 788:8,11,14,17,17 pinpoint 755:5,9,11,15,16,19 756:7 776:5,6 777:17,22 778:2,11 789:12,16 790:4 683:6 756:9 757:6 758:11,11,12 779:11,15,19,21 780:2,8,10 percent pipe 758:14,21 760:4 761:7 780:13,17 751:22 781:10,19 747:2,3,3 762:7 763:7,16,22 764:4,9 pond percentage pipeline 764:12 765:14,20 766:1,11 650:22 651:5,7,9 776:5 673:22 746:21 766:15 767:4,14,18 768:10 777:16,21 778:6 perfect pipelines 768:15,19 769:4,15,20 ponds 780:19 781:7,8,9 746:19 770:17,18 771:12 772:2 767:16,20 778:10 779:7 performance pipes 775:5 776:10 777:11,17 poor 745:4 747:5,9 778:11,22 779:2,8,11,15 730:11,12 period pit 782:1,5 783:14 784:4 786:9 portion 671:22 689:11 697:7 753:7 658:9 733:21 734:9 736:5 786:10,17 787:1 789:6,7 668:19 669:18 762:16,19 768:14 738:22 739:8,14 767:15,18 plants posed periodic pits 677:8 682:18 685:22 686:3 695:19 785:10 664:15 691:22 699:21 719:11 posing periodically place 720:14 728:22 729:2 695:21 739:9 651:5,7,11 661:11 691:16 741:20 766:3 769:2 780:3,9 position permanent 700:8,9 704:7 714:1,2 782:12 784:20 785:8 786:1 654:15 753:14 757:14 674:11 720:21 724:21 749:1 786:3,4 788:8,14,18 789:13 770:3 773:3 789:8 permit 768:18 789:8 789:17 possibility 754:22 763:7,8 764:20 plaintiff plant's 681:11 713:3,5,20 714:4,11 765:1 647:6 648:6 729:6 715:11,15,17716:7,10 person plan plasticizers 722:20 723:8 680:20 649:30 783:5 758:3 possible personal planning please 662:3 691:10 717:18 778:13 789:4 681:3,3,5,7 722:9 756:11 personally plant plug possibly 766:5,9 650:11 651:17,18652:19 709:11 691:21 746:8 787:21 personnel 652:20 653:18 654:8 655:2 pluggage posted 707:11 724:14,14 743:17 656:2 659:10,13,22 660:4 709:3,5,20,22 710:4,8 666:15 757:17 769:3 661:14 662:4 663:22 664:3 plugs potash persons 664:15 665:1,10,15 666:4,8 710:2 744:15 745:7 785:1 668:20 669:4,5,19 670:2,4 pna potassium pertaining 671:2,8,12,21 673:18674:7 672:9 673:1,3,18,22 674:5 691:16 652:17 764:22 674:8,11,17,22 675:8,19 674:17,20 675:7 potential phenacetin 680:4,14,16 681:21 682:8 pncb 690:4 717:16 726:1,11 693:15 682:10,11 683:22 685:9,14 672:18 673:1,3,6,7,8,10,13 737:22 738:5 780:10,16 phenol 685:15,16 686:7 688:3,13 673:14,16,20 781:4 680:7 682:3,9 698:2 688:17,20,20,21,22 690:22 point potter Philadelphia 691:9,17 692:16,20 693:17 661:17 662:8 663:4 707:18 648:2 648:13 693:18,18,21 694:1,3,3,4 709:10 749:1 751:20 760:4 pound phocion 695:6,7,15 697:3,3,7,16,19 760:17 761:3 763:22 673:10 711:19712:6 697:20 699:3,22 700:1 points pounds phosphate 701:17,19 703:2 705:8 656:12 672:22 673:1 762:8 773:9 680:5 691:19,21 692:2 706:5,15 707:3,16 711:1,9 policy 773:10 phosphorus 711:13,15712:3 716:4 721:18 788:13 poured 692:18,20 724:16 725:11,17 728:2,3,7 polluted 700:9 physical 728:10,12 729:10,14,22 669:19 772:13 pr&d 677:15 732:3 733:6 734:2,9,20 pollution 707:18 736:11 737:7 738:17 666:7 672:15 686:2,6 Savage, James (Aroclor Dept employee) in AETNA (4) HARTOLDMONO010386 [practice - raw] practice probably progress putting 721:9 723:7 747:8 768:22 657:13711:16761:8 649:15,26,27,28,29 703:1 684:5 772:9 769:19,20 708:8 738:16 765:14 q prd 728:15 pre 759:20 precedes 692:8 preceding problem 651:3 655:3 677:11,17 678:7,11 773:8 problems 705:3 717:5 736:5,9 779:15 779:19 procedural 768:10 769:1 777:12 783:17 project 649:11 663:7 664:4,7,12,14 664:19 671:16 672:5 677:10 684:2 708:12,14,18 769:1 771:10,13,13,15 quality 730:10,11,12,15,18 quantity 689:4 queeny 669:12671:8 677:7 679:17 680:4 682:8,10 688:3,13,21 738:13 precise 762:14 preferred 746:7 preparation 663:14 763:7 prepared 738:12 preparing 763:6 present 759:21 procedure 723:19 732:14 process 649:30 655:12 657:8 660:21 661:8,19 662:6 671:4,6,9 672:7,12 674:1,1 776:3 778:14 projects 664:18 681:12,13,20,21,22 763:21 proper 655:22 properties 688:22 691:9,21 692:4 693:17,18,18,21 694:1,3,3 694:4 695:6,7 698:7 758:12 766:1 768:16,21 784:1 786:6,8,20 789:6 question 654:4 659:20 663:1 669:16 674:5,6 717:12 728:17,19 676:5 731:16,19744:15746:1,16 property 709:10 780:5 questions 774:10,13 780:19 781:3 783:4 processes 661:15 667:19 668:2,6 669:9 684:1 proposed 775:16,19 776:2 784:15 quickest 756:11 775:20 647:20 718:6 773:8 780:11 presented 650:10 691:22 692:1 746:1 776:2 749:11 780:19 781:18 protection quickly 756:11 779:1 780:16 president 756:17,21,22 769:18 pressure 787:14 790:7 presume 782:4,8,11 processing 748:22 produce 750:2,5 produced 785:11 787:13 790:3 protective 790:12 proved 731:17 provide quite 659:17 675:11 721:6 722:12 723:13 quotes 699:15 quoting 674:2 685:20 686:3 691:14 673:3,4,22 699:19 730:18 731:14 705:21 707:12 710:6 764:5 748:19 provided 717:13 pretty product 737:20 738:11 r 676:14 730:1 745:1 785:20 658:19 692:18 730:9 public rabbitt prevent 740:20 744:16,18 745:3,18 684:6,9 707:7,8 684:6,9 723:17 730:16 748:3,7,18,21 749:3 750:22 pulp railroad previous 751:3,8 752:1,2,4 780:20 748:22 731:11 685:12 689:11 722:9 781:11 pump raised previously production 655:15 658:20 659:1 713:21 650:4 656:7 665:5 696:2 654:19 660:9 670:20 pumped ralph 708:20 714:7,8 762:12 671:18,22 673:18674:5 746:18,19 747:1 779:3 price 707:9 743:5 758:18 767:9 purchased ran 745:4 products 731:11 730:16781:19 primarily 667:18 677:7,7 683:22 purpose range 726:17 787:8 686:13 706:7 724:19 751:2 684:11 primary 739:21,22 740:1,5,10 purposes ratio 725:7 745:17 750:16 751:11 743:12 673:3 principally 752:6 757:13,17 783:6,11 pursuant ratios 657:21 program 647:17 790:12 673:20 printed 665:19,19 666:1 682:8 purview ratliff 745:11 706:11,11,12,14,16719:3,3 696:1 741:22,22 758:6 prior 722:13 729:6,9,12,15,20 put raw 697:15 730:2 650:17,18 651:2,5,7 656:17 673:7 693:15 708:19,20 privy programs 661:8 683:22 684:19 700:8 744:11 748:6 749:19,21 789:11 742:20 704:7 746:11 747:9,12 750:2,5,6,20 780:20 781:4 749:9,20 781:10 Savage, James (Aroclor Dept employee) in AETNA (4) HARTOLDMONO010387 [reach - remediation] reach recall (cont.) records refers (cont.) 748:11 708:12,15,17 709:13,16 721:18 690:20 718:9 729:11 730:2 reached 710:7,10,22 711:3 713:19 recover 733:19 736:20 762:15 671:5 746:16 775:6 715:7 716:1,6 717:7,15 708:19 763:19 768:3 reacted 718:4 719:3,17 720:19 recovered refining 744:13 751:15 723:2,4 724:13,20 725:14 709:8 744:16 reaction 726:8,10,15 727:1,3 728:19 recovering reflects 700:7 744:16,18 745:14 729:20 731:1,3 733:2,5 709:9 671:9 751:8 734:8 736:9,15 737:5 739:7 recovery refresh reactor 744:14 745:22 751:21 708:13 725:22 732:11 735:9 756:1 745:18 751:18 781:14 752:7,8 755:4 760:2 761:3 recycle 761:12,22 779:10 reactors 764:8,14 765:19 766:9,18 708:19 refuse 744:13 768:14 769:11 771:10,14 redesign 725:12 read 776:4 777:15,22 778:9,13 672:11 regard 667:12 676:14,22 701:11 779:7,18 782:3,9 783:5,10 reduce 727:5 783:10 732:8 735:9 783:13 784:2,22 785:22 654:4 682:3,12 703:6 regarding reads 786:4 787:3,6,8 788:19 706:11 726:7 654:7 664:14,19 681:18 721:1 recalling reduced 682:16699:8 715:15 real 785:18 781:4 724:16 740:8 755:15 781:15 receive reducing 783:14,19 realization 711:16 721:14 725:2 682:8 719:7 regional 780:15 781:6 749:12 766:1 reduction 724:15 realizing received 781:5 regular 738:2 670:16 694:20 721:15 reeves 706:15 really 725:19 754:12 698:12,13 regulation 682:9 683:6 703:14 720:15 receiving refer 726:17 723:13 731:15 733:3 711:3 723:2,4,13 733:5 665:4 680:11,16 691:10 regulations reason recess 705:18 728:16 731:8,18 712:5,7 715:15 678:14 679:20 681:19 724:3 734:13 735:10 738:5 751:7 762:11 regulatory 682:7 684:4 700:19 704:16 recipient reference 662:3 715:11,13,21 716:11 708:17 723:1 735:10 766:3 670:14 702:21 771:4 653:2 658:9 663:6,20 665:4 718:9 reasonable recognize 667:3,14 673:10 674:4 related 743:10 663:2,3 693:22 696:19 680:15 689:16 698:2,12,18 672:13 701:6 741:17 reasonably 699:13 701:9 728:5,6 698:22 701:22 713:4 718:8 750:22 653:11,13682:11 753:17 758:20 759:10 770:12 725:22 728:15 729:19 relating 782:13 788:19,21 772:17 773:1 783:1 731:7,17 732:15 733:16 666:21 690:4 714:5 722:3 reasons recognizing 735:13 736:5,19,22 737:1 739:20 741:10 752:14 718:7 783:17 747:14 738:21 750:12 755:11 relationship rebuilding recollection 760:6 761:2,11,18 762:21 741:20 742:22 743:1,7 700:14 701:7 656:8 668:19 669:2 673:2 764:20 768:2 772:12 774:2 release rebuilt 700:18 725:22 726:16,18 777:19 661:9,10 700:5 732:11 735:9 756:2 761:12 referenced released recall 761:22 779:10 787:19 666:18 687:19 688:1 659:21 660:16 661:14 652:16 653:9,16,20 657:21 recommendation 694:17,18 714:4 738:4 675:14 724:1 658:15,17 659:7 660:15 726:20 765:4 releases 661:4,13 662:2,10,14 recommendations references 662:4 676:6 663:13 664:9 669:8,11,17 785:12 653:9 702:3 712:5 713:14 releasing 670:19 671:1,14 672:8 recommended 754:22 759:20 773:13,21 659:8 674:6,10,18 675:5 676:1,4 725:10,15 referred relevance 677:14 678:9,11 679:4,7 record 680:10 719:19 723:8 742:4 769:6,8 680:9 681:8 683:18 684:14 650:13 687:5,6,9,9 721:11 750:8 remedial 685:16,18,21 689:3,7,18 721:12734:11,12,16 referring 663:6 692:5,9 694:9,12 695:1,8 735:21,22 739:16,17 653:14 677:13,20 678:3 remediate 695:21 696:6,12 697:3 750:13,14 752:20 759:15 682:14,22 761:1 719:10 701:3,4 703:5,12,16 704:16 759:16 760:22 764:19 refers remediation 705:1 706:13,18,22 707:1 771:9 782:16,17 665:18 673:11 679:18 719:7 720:20 Savage, James (Aroclor Dept employee) in AETNA (4) HARTOLDMONO010388 [remember - salt] remember reporter responsibilities (cont.) right (cont.) 652:21 653:12 654:9 647:20 741:17 742:12 743:4 753:8,21 761:17 766:6,8 655:13 657:13,18 658:8,22 reporting 752:13,16 755:7,14 756:7 770:13,19 771:8 772:16 662:5,9,12,17 663:10,19 655:1 660:13 742:22 761:16 768:17 782:10 river 665:7 666:16 668:17,22 reports 783:10,13 679:1 758:15 760:17 669:7 672:7 673:5 674:3 649:25 662:14,16 710:22 responsibility 761:12 763:15 764:8 675:22 676:3,7 678:8,16 711:8 712:2 733:7 753:3 686:11 688:16 706:9 771:11 772:12,13,14 775:3 679:19,19 680:19 684:17 766:2 779:16 783:17 784:1 711:15717:19719:18 775:6,6 689:14 690:6 693:16 696:5 represent 737:14 740:12 755:18,20 rivers 696:10 698:16 703:8,14 683:3 757:9 758:5,18 759:1,9 663:20,21 666:19 704:6,10 706:20 707:10 representatives 772:21 782:7 roam 708:14 711:5 714:17,22 784:19 785:14 responsible 788:14,17 715:6 716:12 717:19 718:7 represented 651:20 681:10 robert 720:10,22 724:17 726:8,22 651:8 781:5 785:2 restore 692:9 727:7 728:13 730:6 734:10 request 719:14 robirds 736:14,18 739:11 740:2 761:19 result 757:8 743:5 746:3 747:6,11,21 requests 662:6 675:13 676:2 709:18 rock 749:11 750:16 755:20 789:16 774:18 657:7 658:1 756:20 757:5 758:4,9,17,19 required resulted roger 760:5,13 761:6 764:12 660:10 671:17 677:11 672:8 696:3 705:22 707:3 680:22 681:1 765:5 766:17 767:19,21 684:2 685:10 730:16 resulting room 774:10,12 775:4,12 781:19 research 654:2 705:7 746:13 785:16 786:20 787:5,10,12 707:17 728:17,19 757:15 resumed rosin 788:12 789:5,5 790:8 757:16 649:3 650:4 741:3 744:12 745:4 750:6 remembered reserves retained 750:10,10,19 751:3,8,15 651:9 664:12 760:12 rough remind residue retention 690:19 726:4 673:3,6 680:7 690:14 721:18 722:13 route removal 691:12 692:2,2 693:16 retired 665:3,6,7,9 771:17 730:5 731:7 737:1 residues 698:12 753:13,15 routine removed 679:17 691:2,19 745:16 reused 689:10,12,13 703:17 731:12 752:6 700:19 705:15,20 706:1 721:20 removing resolution review 722:2 733:22 734:2 742:19 737:6 764:22 652:10 686:15 687:19 768:20 783:22 repaired resolved 695:17 706:17 775:17 routinely 709:17 764:21 779:13 733:14 replace resource reviewed roy 700:6 760:6,9,11 652:14 667:16 670:11 654:14 655:1 753:12,16 replaced resources 676:16 687:21 702:19 rubber 709:17 762:22 763:2 708:5 710:20 712:19 691:15757:11,15,20 replacement respect 718:18 724:10 727:14 769:16 783:8 722:8 664:12 683:8 706:4 711:12 765:12 777:9 783:3 run report 712:2 714:12 715:5,9 716:9 reviews 740:3 756:12 769:12 649:12,15,23,24,26,27,28 717:9 725:16 726:2 729:9 742:19 running 649:29 663:12,16 670:17 729:16,21 736:16 754:20 rhodes 759:9 671:8,9 674:9,13 688:15 768:17 778:10 784:3 789:6 767:7 russell 695:4 703:1 707:10,11,20 respective richard 776:18 708:8 711:16 712:4 725:3 647:21 732:4 734:21 738:16 responded 743:18 744:2 761:7 765:15 705:3 765:22 766:4 768:10 769:1 response 774:11 777:12 712:9 reported responsibilities 757:16 rid 700:16,19 701:5 731:5 rifle 684:10 right Sttl6S 701:13 salicylate 693:17 s 660:15 742:21 743:13,16 744:1 759:5 761:9 767:1 778:20 654:7 677:4 679:13 681:6 681:17 688:9 699:7 706:3 711:11 739:20 740:8 741:9 651:11 663:13 668:3 677:1 683:20 688:8 694:18 699:10 732:8 733:11 749:6 656:16,16,19,21 657:7 658:1 Savage, James (Aroclor Dept employee) in AETNA (4) HARTOLDMONO010389 [sand - sodium] sand secondary seventh simply 735:14 731:14 648:11 706:11 717:13730:15 sanitary sector sewer 743:15 688:10 689:4 668:15,15 658:6,7 668:21 682:4 703:6 sir satisfied seeing 706:4,11,19 708:21 709:3,5 652:13 781:13 653:10 669:8 694:9,12 709:12,16 710:2 775:1,2 site saturate 790:6 sewered 651:20 665:4,6,8 666:2 656:16 seen 708:13 667:8,11,13,21 668:9,12,15 saturated 653:5 663:18 670:3 714:4 sewering 677:21 678:1,4 683:11 656:19,22 657:5 733:9 779:13 674:15,16 709:2 690:11 697:16,19 719:15 saturator seepage sewers 753:16 754:2 656:13,14,15,18 657:9 678:22 674:20,22 675:2,3,7,12,14 sites sauget sending 682:9 705:7 707:2 709:22 714:13719:5 669:12 690:11 677:18 678:9,15 710:8,9,11 situation savage sense shed 679:14710:4 714:13715:9 647:13,16 649:3,8 650:3,8 781:9,15 779:6 716:3,9 717:9,17 722:17,19 651:13 652:3,9 662:18 sensitive sheets 724:16 727:6 733:6 736:14 663:1 670:5,9 676:8,12 721:8 722:21 723:9,10 750:11 situations 687:7,17 702:12,17 707:21 780:13 shipped 710:5 736:15 708:3 710:13,18 712:12,16 sent 745:20 746:4,6 six 716:14,18 718:12,16 724:4 681:18 689:4 702:4,8 712:1 shipping 764:8 724:8 727:8,12 729:5 718:21 730:13,19,22 652:1 665:15 758:10 size 731:21 732:3 734:14,20 732:17 737:11 755:1 shop 740:10 745:4,9 751:4 736:2,4 739:19 752:18 765:15 768:20 769:4 700:10 sizing 753:1 765:6,9 768:5,9 sentence short 745:10 770:21 771:3 777:3,7 729:5 719:8 sketch 782:18 783:1 784:6,18 separate shortcut 747:19 790:17 687:12 783:21 skimmed saw separated shorter 749:2,4 682:11 789:2 655:22 778:1 skimming saying separately show 777:16,20 779:7 722:14,18 766:5 687:13 650:8 783:20 skip says September showed 668:14 653:7,8 655:4 656:6 658:20 768:11 782:20 689:22 slag 698:12 701:13 702:3 709:2 sequential shown 701:2 713:9 717:21 732:8 738:10 687:11 707:19 slightly 767:1 772:17 series shut 762:14 schaefer 753:4 693:11 718:1 719:12 sludge 758:20 seriously shutdown 657:13 693:5,7 schedule 735:11 720:15 small 689:13 serves shutting 700:10 746:5 scheduled 719:22 718:5 smaller 760:3 service side 750:15 scope 766:2 769:3,5 651:10 677:1 684:1 699:11 smell 775:17 services 732:8,16 735:5 772:3,4 675:11 scott 688:13 732:4 738:16 sign smith 654:13,14 655:1 753:7,12 765:14 768:10 769:2 667:21 647:18 698:15 757:3 758:2 758:20 767:5 770:16 777:12 783:17 significance 770:11 scrap set 730:7 snows 692:18,19 719:15 656:2 700:5 747:18 significant 736:22 737:6 second setting 654:1 social 665:6,17 667:2 670:14 664:11 704:9 silo 704:18 688:3 691:4 697:14 705:10 settle 714:21 soda 709:1 724:12 725:5 773:6 657:4 similar 744:14 745:6 776:8 779:2 settled 655:19 682:15 704:21 sodium 657:10 705:3 751:14 657:7,21 Savage, James (Aroclor Dept employee) in AETNA (4) HARTOLDMONO010390 [soil - surety] soil specifically (cont.) stated study (cont.) 659:9,22 660:17 661:6 715:10 747:11 717:22 760:17761:11,13,16 664:19 668:6 720:9,12 specifics statement 763:15 764:8 solari 779:16 682:2 697:14 701:11 717:4 studying 688:14,15 specify 717:21 725:6 733:12 762:7 781:3 sold 683:14 790:1 stuff 680:13 706:7 731:4 speeds states 683:15 solid 652:10 687:18 672:18 725:9 773:8 777:20 subject 656:16 657:20 695:2,8 spell status 653:11,13660:1,6,14 709:11 767:17 768:2 740:15 649:13 677:5 710:22 711:8 661:22 665:14 685:5,8 soluble spent 712:2 711:17712:17713:20 775:13 690:17 stay 714:16 717:16 719:2 722:1 solution spills 776:8 786:3 726:1 736:9 737:5,15 762:4 777:21 658:17 735:12 746:1 steam 774:11 778:2 787:3 somebody spoede 747:22 748:2 772:9,11 subjects 685:7 687:1 710:6 721:7 766:21 step 737:12 755:19 769:6 spoken 657:3 692:4 744:17 748:4 subsequent somewhat 772:7 751:14 659:19719:10 660:2 674:2 sponsor Stephen substantial sorry 677:10 648:8 660:4 673:14 713:12 753:15 sponsorship steps successful 756:5 684:3 696:3 704:7 723:17 682:11 sort sprandel stewart suit 689:13 703:8 716:8 729:15 696:22 697:2,20 770:9 714:18 725:10 726:20 747:2 760:2 spread sticking sulfate sorts 723:12 745:12 686:16 657:7,21,22 737:17 springgate stone sulfuric sounds 756:18 769:13,14 655:21 690:20 691:6 736:13 square stood summary source 648:10 750:8,10 649:21 725:4 767:15 661:20 675:17 692:3 St stop 777:20 731:14 752:11 676:19 677:5 678:2,3 754:5 677:17 678:9,15 superfund southwest 754:7 stopped 683:1,7,12 724:15 stabilizing 691:9 superintendent sparks 690:14 storage 672:1,2 688:12 699:3 770:11 staff 658:14,19 661:6 745:19,19 729:14 758:22 759:8 speak 755:19 786:11 787:1 746:22 747:1 749:21 768:21 769:10 770:16 786:19 stamped 767:16,20 superintendents speaking 677:1 storm 769:5 753:1,21 stand 668:21 736:5 superior special 650:4 663:11 strange 647:1 737:14,18,19 standard 735:4 supervising specialists 685:1 782:4,8,11 stream 654:16 778:22 686:2,7 standards 651:10 749:2,5 762:14 supervisor specialty 685:3,19,22 686:4 772:4,7 774:5,18,20 775:7 654:19 660:9 707:9 743:6 677:6 683:21 686:13 standpoint streams 767:9 739:22 740:1,6 757:12,17 744:4 655:5,8,9,13 702:5 sure specific stands street 650:17655:13671:18 663:4 701:6 706:18 710:12 663:11 728:17 647:19 648:4,12 678:20 684:16 706:16 714:18 716:12 719:8 start strike 725:21 728:13 756:4 720:18 726:4,9 734:10 655:9 688:1 669:16 727:2 732:15 763:5 759:10 769:18 773:4 742:1 744:7 746:3 747:6 started 775:8 787:16 776:11 779:5 780:4 785:17 749:10 788:20 671:7 780:15 studies 787:20 788:1,2 specifically state 654:6 surety 662:12,17 685:5 701:1 647:2 666:11,15716:10,12 study 647:9 706:21 711:6,10 714:18 724:14,18 764:15 652:21 654:3 665:18,19 Savage, James (Aroclor Dept employee) in AETNA (4) HARTOLDMONO010391 [surface - transactions] surface technical (cont.) think (cont.) time (cont.) 668:12 701:3 772:3,5 766:2 768:10 769:1,3,5 692:17 693:14 694:2 736:17 739:8,12,21 740:7 survey 770:16 777:12 783:17 700:14 701:12 703:17 740:10,12 741:11,18 743:3 689:10 695:9 765:19 tell 704:9,18,19 714:7,15 751:1 752:13 753:6,12 766:10 664:6 671:1 672:4 690:13 716:10 720:2,17,18 722:22 755:5 756:6,15,18 757:4,7 swivel 693:1 733:1,4 771:14 728:17 729:11,17 730:1 757:8,13 758:16,19,21 747:9 775:21 783:1 788:20 733:9,20 734:3 740:16 759:2,3,4,10 760:4,18 sworn temperature 742:7 753:13 754:8 756:11 761:4,13 763:3,16,22 650:4 730:4,8,9 746:14 756:19 758:6,18,21 761:8 765:16,22 767:8,9,11 system tentative 767:4 769:17 772:22 773:4 768:12,18,19 769:9,14,20 751:18___________________ 674:5 776:11,12 779:14 780:10 770:15 771:6 772:1,21 t tenure 781:18 782:7 784:14,21 773:3 775:1 778:16 779:12 table 705:12 773:13 tabulation 663:3 663:15 671:21 723:5 781:7 785:3 786:6 783:9 thiofide term 783:7 658:22 663:9 668:17 692:2 third 779:20 780:1,7,12,12,15 782:8 783:18 786:8,10,12 786:15 times tafey 701:21 719:6,8,8 730:1 682:3 705:10 653:22 669:17 671:19 685:17,18 taken 751:6,7 771:21 777:21 778:1 787:6,7 thirty 648:11 682:19 709:16 742:15,16 tippee 667:7 694:6 697:12 710:5 719:9 talk terms 685:11 771:16 test thought 672:6 687:13 721:7 threats 758:9 tippey 743:1,7 759:4,5 779:2 704:1 talked 651:9 762:16 testified 712:9 717:4,7,16,18 three title 681:3 753:17 757:21 673:14 696:2 713:17 722:13,20 758:20 759:4 767:4 769:22 650:5 testify 784:7,12 708:7 741:14 753:13 786:2 today throw 704:13,15 721:19 told talking 678:2 749:7 759:19 texas 683:10 thrust 787:10 687:1 top talks thefts tightened 653:2 654:12 656:6,17 674:15 679:16 767:15 775:15 tall 740:20,20 741:3,8 742:5,9 743:9,11,20 744:11,12,13 660:4 thereabouts 720:1 thereunder 668:7 685:2 663:5 674:15 677:1 680:20 time 694:18 709:1 747:10 652:18 654:10,16 655:1 772:16 656:9 659:12,17,20 660:2,3 topic 660:8 661:7,7,21 662:11 706:21 714:17,19 747:15 748:5,6,8,14,17 thermal 664:16,20 665:20 666:4 tora 749:1,13,17,21 750:1,4,6 750:10,16,19 752:11 762:7 767:9 771:11 772:17 773:8 774:9,16 775:2,11 777:16 777:22 778:3 659:4 thick 745:15 746:10 748:16 thimor 783:8 667:21 670:17,21 671:2,3,7 750:10 671:11,18 672:3 674:13 torufa 675:16,16,19 677:4,14 750:12 678:12,17 679:2,4,12,14 total 680:13 681:2,10 682:10,15 737:22 741:13 773:10,21 tank 656:14 658:21 745:19,20 746:4,7,8,17,22 747:1,1,4,5 747:10 748:13 749:20 781:15 thing 651:15 684:21 747:20 things 652:2 678:22 679:8 722:14 723:22 752:3 781:1 682:17 683:17 684:16,22 774:2 685:4,10,19 686:1,3,7,10 totally 686:11,14,15688:10,13 730:14 689:5,20 690:1,3 691:8,9 toxic 693:10 695:3,5,9 697:5,6,7 659:13,17 672:19 673:17 tanks 677:19 683:15 705:22 699:4 700:5 701:19 702:9 673:21 655:15 658:14 659:1 661:6 745:19 749:21 724:2 725:2 729:15 738:11 743:18 779:22 785:11 703:2,6,18 704:14 705:5,6 toxicology 706:6 707:9,10,20 708:9,11 659:18 targets 704:9 technical 787:14 think 650:15 651:15 654:16,20 708:13 711:12 713:21 tracking 714:1,3,6,10,15 715:14,16 681:11 716:3 717:8 718:6,10 719:5 trade 671:17 677:10 688:12,17 688:19 706:10,12,16 655:1 657:4,22 659:5 661:16 662:16 666:13,20 719:6,10,12,17 720:1,12,16 680:12 720:17 721:14,14 724:15 transactions 729:11,15 730:2 732:3 667:1 672:11 679:9 681:3 726:3 727:21 728:21 729:1 722:3 738:16 759:11 765:14 684:10,19690:19692:12 729:1,10,13,13,16,22 730:2 Savage, James (Aroclor Dept employee) in AETNA (4) HARTOLDMONO010392 [transfer - weeks] transfer typical use visit 772:1 783:4 715:18 735:13 751:6 742:13 785:13 786:1,22 transferred typically 771:16,21 772:10 774:17 788:8 789:7,9 683:10 745:19 779:4 660:9 774:22 777:16 787:7 visited trap u useful 667:1 784:19 785:7 658:6,7 ufa 785:12 visits trauth 750:8 usual 742:18 764:14 787:7,8,11 777:1 traveled unacceptable 730:14,21 731:1 706:8 721:8 747:8 774:21 788:10 usually vivid 686:14 unauthorized 751:9 782:12 786:2,3 705:2 treatment 684:11 V volume 650:11 755:11,15 756:9 765:4 775:5 trees uncovered 684:20 underground vacuum 691:2,12 772:8 774:20 vague 647:13 695:2 w wally 749:9 668:21 704:4 767:7 trend understand vaguely wait 704:18 780:4 708:14 655:1 trial 784:8,13 understanding 659:12,16 661:1 665:13 vanadium 690:17 691:5,8,10 want 650:13,17 trucked 668:1 673:11 677:22 vapor wanted 694:7 678:14 684:4 687:2 690:3 659:4,6 774:20,20 781:22 789:1,10,21 trucks 711:7,22 712:6 720:4 various warm 746:8 723:15 737:10 738:4 653:9 655:4 660:1,7 661:18 772:7 true 743:10,11 747:15 749:4 682:18,19 704:7 726:5 waste 657:1 660:4 674:10 711:5 772:13 779:17 780:1 744:22 780:21 782:12 650:11 672:9,13 680:7,18 trust 783:16 784:6 789:3 varying 688:10 689:4 690:10 695:8 648:3 understood 745:5 702:5 736:3 749:3 756:9 try 654:4 735:19 738:7 782:13 723:22 780:11 undertake veazey 728:11 762:13 765:3 767:16,17,20 768:2 775:5,7 787:3 trying 743:8 766:14 vent wastes 743:22 783:20 undertaken 658:21 659:2 676:19 677:5 678:3,3,15 tsd 708:12 720:12 vented 679:21 680:6,10,15,16 660:10 672:2 688:21 703:2 707:8,12,18 729:14 734:20 undertaking 708:17 659:1 venture 690:13 695:3 765:19 766:10,14 784:3 759:9,12 761:8 767:7,8 underway 740:12,18,19 742:2,4,8,8 wastewater 769:10 773:4 778:22 784:1 654:9 704:9 742:11 743:12 750:4 664:22 715:16 771:18 tube undissolved verify water 772:5 turn 657:4,6 unit 651:5 vern 655:5,9,13 657:14 659:9,22 660:17661:3,7,9,10,10 652:22 654:11 672:14 747:6 767:7 675:12,13 709:11 710:2 674:14 689:15 694:14 unload vertical 711:1,8,12712:3,10 716:2 696:15 705:10 709:1 713:8 749:20 700:3,4 716:7 720:9,12 751:5,21,22 715:19 716:22 724:12 unnecessary vessels 762:22 763:2 771:17,19,21 725:5 729:3 738:20 760:20 781:4 787:15 790:7 772:3,6 774:22 775:8,13 763:13 773:6 unpleasant vice 776:5 777:16,22 778:2 turned 675:11 756:16,21 780:22 781:21 722:7 731:15 unreacted view ways turnings 731:10,13 672:18 673:8,11,16,20 unsaturated 789:8 village 661:4 721:17 730:10 774:13 type 750:9 698:13 weber 679:8 681:6,9 695:9 711:3 unusual vince 776:10,11 715:13 721:4,5 733:7 780:8 661:5 721:6 722:12 723:14 758:17 week types 679:21 695:17 722:15 upgrade 684:2,15,18 Virginia 762:22 763:1 786:3 weeks 745:22 746:1 upsets visible 757:1 746:1 717:5 Savage, James (Aroclor Dept employee) in AETNA (4) HARTOLDMONO010393 [weirs - yield] weirs workers 655:21,22 787:9 welcome working 718:1 671:4 675:15 758:5 779:22 welge world 648:9 661:18 wells wound 667:4 780:20 went write 674:21,22 706:20 711:19 733:3,15 718:7 746:22 751:18 775:2 writing 775:5 780:22 781:15 707:11 733:13 735:7 west 758:22 665:9 762:21 763:1 written we've 692:9 693:11 707:20 667:10 673:14 713:17 708:10 717:10 722:7 714:4 733:9 762:12 767:4 745:11 753:4 767:11 769:22 779:13 wrote wgk 676:18 690:1 652:6 662:20 664:2 670:7 695:2,3 708:1 wheels 731:11,12 white xerox 702:4 X y 725:6 yeah williams 651:8 688:8 767:14 759:8 year Williams's 656:3 710:22 712:2 721:19 772:19 738:13 785:10 Wilmington yearly 647:14 648:5 784:13 711:7 wilson years 770:13,15 682:4 683:1,4 685:12 witness 697:21 721:20 741:14 649:2 650:18,21 651:4 744:10 745:17 746:2 773:1 652:14 667:16 670:11 785:10 676:16 687:21 702:19 yesterday 704:6 708:5 710:20 712:19 650:11 718:18 724:10 727:14 yield 738:9 750:15 765:12 777:9 781:20 783:3 784:7,11 woodward 654:21,22 word 781:9 words 655:11 work 656:12 667:20 671:9,10,15 692:14 695:15 703:8,12 706:9 759:12 779:4 worked 654:14 659:13 660:13 667:21 683:10 688:14,14 708:11 729:13 747:4 753:12 773:1 Savage, James (Aroclor Dept employee) in AETNA (4) HARTOLDMONO010394