Document LJdyqN3VZ90ZKadyo3vDDL543

Page 1 IN THE CIRCUIT COURT FOR ETOWAH COUNTY, ALABAMA (Transferred from the Circuit Court of Calhoun County, Alabama) SABRINA ABERNATHY, et al., Plaintiffs, versus CIVIL ACTION NUMBER CV-2001 -832 MONSANTO COMPANY, et al., (Consolidated) Defendants. / DEPOSITION OF WILLIE FRANCIS BYRD, JR. The deposition ofWillie Francis Byrd, Jr., was taken before Misty Perry Sanders, as Commissioner, commencing at 11:00 a.m., on January 4th, 2002, by the Plaintiffs, at the law offices of Fite, Field & Miller, LLC, 1000 Quintard Avenue, Anniston, Alabama, pursuant to the stipulations set forth herein. Regional Reporting Service, Inc. 755 Walnut Street Gadsden, Alabama 35901-0755 Page 3 1 STIPULATIONS 2 IT IS STIPULATED AND AGREED, by and 3 between the parties, through their respective 4 counsel, that the deposition of Willie Francis 5 Byrd, Jr., may be taken before Misty Perry 6 Sanders, as Commissioner and Notary Public, 7 Alabama at Large, at Anniston, Alabama, on January 8 4th, 2002, commencing at 11:00 a.m. 9 IT IS STIPULATED AND AGREED that the 10 signature to and reading of the deposition by 11 the witness is waived, the deposition to have 12 the same force and effect as if full compliance 13 were had with all laws and rules of Court 14 relating to the taking of depositions. 15 IT IS STIPULATED AND AGREED that it 16 shall not be necessary for any objections to be 17 made by counsel to any questions except as to 18 form or leading questions and that counsel may 19 make objections and assign grounds at the time 20 of trial or at the time said deposition is 21 offered in evidence or prior thereto. 22 IT IS STIPULATED AND AGREED that notice 23 of filing by the Commissioner is waived. 1 APPEARANCES 2 For the Plaintiffs: 3 CHARLES L. CUNNINGHAM, JR., Esq. 4 ATTORNEY AT LAW 6010 Brownsboro Park Boulevard, Ste. G 5 Louisville, Kentucky 40207-1294 6 For the Defendants: 7 LARRY MYERS, Esq. SMITH, HELMS, MULLISS & MOORE 8 1355 Peachtree Street, NE, Suite 750 Atlanta, Georgia 30309 9 10 11 INDEX Page 12 Stipulations 3 13 Reporter's Certificate 116 14 15 EXAMINATION 16 Witness: WILLIE FRANCIS BYRD, JR. Page 17 BY MR. CUNNINGHAM 4 18 19 20 No exhibits were marked for identification, 21 offered, or attached as exhibits hereto. 22 23 Page 2 Page 4 1 STATE OF ALABAMA, CITY OF ANNISTON 2 JANUARY 4, 2002 3 4 WILLIE FRANCIS BYRD, JR., 5 after having been first duly sworn, was 6 examined and testified as follows: 7 8 THE COURT REPORTER: Usual 9 stipulations? 10 MR. CUNNINGHAM: Yes, ma'am. 11 MR. MYERS: Yes, ma'am. 12 13 EXAMINATION 14 BY MR. CUNNINGHAM: 15 Q. Mr. Byrd, my name is Charlie Cunningham, 16 and I'm here today to ask you some 17 questions about factual knowledge you may 18 have that would be relevant to a lawsuit 19 where 1 represent about thirty-five 20 hundred folks who have sued Monsanto and 21 Solutia. 22 Have you ever been deposed before? 23 A. Yes. Pages 1 - 4 HARTOLDMONO013659 1 Q. 2 3 4 5 A. 6 Q. 7 8 9 10 11 12 13 14 15 16 17 18 19 A. 20 Q. 21 22 23 Page 5 Okay. So you understand the lady to your 1 left needs to take down your answers, and 2 1 need you to make a verbal response 3 Q. rather than a shaking of the head? 4 Yes. 5 A. Good. I'm going to tell you a couple of 6 odd things about me that you may not have 7 Q. encountered in the previous testimony. 8 A. One bad habit of mine is you'll be giving 9 me an answer, and I'll either think that 10 Q. you have finished and cut you off and go 11 on with another question, or I'll get this 12 A. thought in mind, and I'll throw another 13 Q. question at you, and you won't have had a 14 A. chance to complete your answer. If 1 do 15 Q. either of those things, just let us know 16 because we do want you to have a chance to 17 give a complete answer. 18 Certainly. 19 The second bad habit 1 have is I'll ask 20 you a question, and it'll sound like 1 21 know what I'm talking about and that 1 22 A. know something, and that isn't necessarily 23 Q. Page 7 Owens. MR. CUNNINGHAM: Thank you. Let's start with some easy stuff. Would you tell us your full name, please? Willie, i-e, Francis, i-s, Byrd, B-y-r-d, Jr. And your address? Pelham, P-e-l-h-a-m, Road North, Jacksonville, Alabama 36265. Okay. And how long have you resided there on Pelham Road in Jacksonville? Approximately twelve years. Before that, where did you reside? On East 22nd Street in Anniston. Okay. 1 don't need a street address. That's fine. East 22nd Street in Anniston. Now, 1 don't profess to be an expert in Anniston geography, but I'd put that up by the -- not the Northeast Regional Medical Center but the other hospital? Correct. It's north of Stringfellow. Yeah. And how long did you live there? 1 2 3 4 5 6 7 A. 8 Q. 9 10 11 12 A. 13 Q. 14 15 A. 16 Q. 17 18 19 20 21 22 A. 23 Page 6 so. 1 may not know what I'm talking 1 A. about. If 1 ask you a question and it 2 Q. doesn't sound right, please don't presume 3 that 1 am correct, and tell me that 4 A. doesn't sound right or that doesn't make 5 sense based on what you know. Okay? 6 Q. Okay. Sure. 7 Great. Your previous deposition 8 testimonies, were they involved in 9 litigation involving Monsanto too, as far 10 as you know? 11 A. As far as 1 know, yes, sir. 12 And was that once or twice that you were 13 Q. deposed in the past? 14 A. Once, 1 think. 15 Q. And there's two different cases where I've 16 encountered some workers who were deposed ;17 A. one is the Owens' case, and one is what we 18 Q. call the insurance case. And I'm betting 19 you probably don't have a clue as to which 20 it might have been? 21 A. Correct. 1 have no idea. 22 Q. MR. MYERS: Yes, sir. It was 23 Page 8 Approximately two years. Okay. And before that, where did you reside? 1 moved around quite a bit, so it's going to be difficult to -Let me try to simplify it. What I'm trying to -- if you ever resided in Etowah County, that would be of interest to me because we're going to poll a jury from Etowah County. 1 did reside in Glencoe, Alabama, in the '80s. That's in the southern part of the county? Correct. Any other places in Etowah County that you resided in? No, sir. Okay. And then, also, if you ever lived close to the plant, that would be something 1 need to know about. Close, as to -Well, let's take the East 22nd Street address. That, I'm going to guess, if we Pages 5 - 8 HARTOLDMONO013660 1 2 3 A. 4 Q. 5 6 A. 7 8 Q. 9 10 A. 11 Q. 12 A. 13 Q. 14 A. 15 Q. 16 A. 17 Q. 18 A. 19 20 Q. 21 22 A. 23 Q. Page 9 looked at a map, is probably -- what do 1 Q. you think -- three or four miles? 2 A. Probably. 3 Q. Okay. Ever lived closer than that to the 4 plant? 5 1 lived in Saks, but I'm not certain as to 6 how far that was. 7 But you never lived within a mile of the 8 plant -- 9 No. 10 -- or two miles? 11 A. No. 12 Q. We're pretty safe on saying that? 13 Correct. 14 A. Are you married, Mr. Byrd? 15 Q. Yes. 16 And what is your wife's name? 17 Constance, C-o-n-s-t-a-n-c-e, Sims, 18 A. S-i-m-s. 19 Q. Do you know if her PCB level has ever been 20 checked? 21 No, 1 don't. 22 And do you have children? 23 Page 11 Correct. No one. Okay. It's very short. Okay. 1 want to ask you for a moment about things you may have done to get ready for today; such as, have you spoken with someone about, hey, I'm getting ready to be deposed again in this Monsanto stuff; what do you remember about such; how did it go with you, that sort of thing? No. Have you looked at anything, viewed any documents, read something? No. So do you have any idea why you might be called as a witness in this case by Monsanto? Other than working there? Yeah. 1 mean, you haven't had a conversation with somebody saying, you know, we need to try and prove this; will you be a witness for us and talk about that? 1 A. 2 Q. 3 A. 4 5 6 Q. 7 8 9 10 11 A. 12 Q. 13 14 15 16 17 18 19 20 A. 21 Q. 22 A. 23 Page 10 Yes. 1 A. And what are their names? 2 Allen Clark -- and 1 don't recall his last 3 Q. name -- and David Patrick. They were 4 adopted by my exwife's husband. 5 Okay. I'm with you. 1 probably don't 6 have to worry about your exwife being 7 biased against my clients because of your 8 precedence in the case, but just in case, 9 what's her new married name? 10 1 don't remember. 11 Okay. That's fine. Then 1 don't think 1 12 have to worry about bias there. And one 13 thing we will be looking for is folks who 14 might reside in Etowah County who might 15 show up on our jury panel; therefore, 16 A. adults, and who are related to you by 17 Q. blood or marriage. Would that be a long 18 list of folks or a short list of folks? 19 A. Is that two parts or -- 20 One. 21 Do they live in Etowah County, and are 22 Q. they related to me? 23 A. Page 12 No. No one has told me we're trying to prove anything. All right. I'm going to assume for the sake of your answers today that everything you tell me is your own independent recollection since you haven't looked at anything else or talked to anyone else. And that's fine. That's what we want. But if when 1 ask you something, it triggers a recollection that at a Christmas party, 1 was talking to So-and-so, and he said this or something like that, by all means, let us know. We'd like to know that too. Just let us know the source. Okay. All right. Now, would you tell me, please, what education you've obtained? 1 have an associate degree. That would be two years of college. Plus, 1 continue going to Jacksonville State University. And what was your degree conferred in? Fire science. Pages 9-12 HARTOLDMONO013661 1 Q. 2 3 4 A. 5 6 Q. 7 8 9 10 11 12 A. 13 14 Q. 15 A. 16 Q. 17 18 A. 19 Q. 20 21 A. 22 Q. 23 A. Page 13 What department at the university was in 1 A. charge of overseeing that course work and 2 administering that degree? 3 That was at Gadsden State Community 4 College. 5 Q. Okay. And again, what department within 6 Gadsden State administered the fire 7 A. science? You're the first guy I've ever 8 Q. met with a degree in fire science, so I'm 9 kind of clueless as to what one even 10 A. studies to do fire science. 11 Q. I'm not certain that they have departments 12 at Gadsden State. 13 A. Are you a volunteer firearm? 14 1 have been. 15 Q. Was that the basis for your interest in 16 A. that? 17 Q. No. 18 Okay. I'm assuming you have a high school 19 A. diploma from somewhere? 20 Q. Yes. 21 When and where did you obtain that? 22 1961, Fowler, F-o-w-l-e-r, Indiana. 23 Page 15 It was correspondence. They would send me the course, and I'd study the course, and there would be proctored exams here locally. And you haven't been conferred a degree yet at this point from them, 1 take it? No. Is there a certificate of some sort, perhaps, that you qualified for? No. And when did you receive your associate degree from Gadsden State? 1984 or 1985, somewhere in that time frame. Mid '80s? Mid '80s. Were you working and going to school part-time when you obtained that? Right. And the subsequent work that you've taken at Jacksonville State is in the same realm of course work, fire science, emergency management kind of stuff? 1 Q. 2 3 4 A. 5 Q. 6 A. 7 Q. 8 A. 9 Q. 10 A. 11 Q. 12 A. 13 14 Q. 15 16 A. 17 Q. 18 19 20 A. 21 Q. 22 23 Page 14 Now you're getting up my way. Have you 1 A. done any college course work other than at 2 Q. Gadsden State and Jacksonville State? 3 Yes. 4 Okay. 5 A. Thomas Edison State College. 6 Q. Okay. And where is that located? 7 In New Jersey. 8 A. And what did you study there? 9 Q. Emergency disaster management. 10 And when did you do that? 11 A. Middle to late '90s, somewhere in that 12 Q. time frame. 13 Let me skip ahead for a moment. What 14 years have you worked for Monsanto? 15 1965 through 1998. 16 So were you still working with Monsanto 17 when you took this course work in New 18 A. Jersey? 19 Q. Yes. 20 Okay. Was this something where you would 21 go up and spend several weeks intensively, 22 A. or was it correspondence? 23 Q. Page 16 Correct. Do you find that the faculty up there at Jacksonville State is competent generally when you take your courses there? Yes. Been pleased with the education you've been able to get there? Yes, sir. They have a pretty good library, as 1 recall? Yes. Let me -- before we talk about what you did for Monsanto, let me talk to you for a moment, if we might, about other things you've done for a living aside from your work at Monsanto. When you got out of high school -- and when was that? 1961 ? Graduated in 1961. So we've got a four-year gap there. Tell me what you did first when you got out of high school. Three years in the U.S. Army. Okay. Pages 13-16 HARTOLDMONO013662 1 A. 2 Q. 3 A. 4 Q. 5 6 7 8 9 A. 10 11 12 13 Q. 14 15 A. 16 Q. 17 18 A. 19 Q. 20 21 22 23 A. Page 17 And one year at Union Foundry. 1 What did you do at Union Foundry? 2 Cleanup. 3 Now, I'm guessing they could make a lot of 4 Q. messes at a place like Union Foundry. So 5 A. tell me, if you can: Were there specific 6 Q. things you were cleaning up or just all 7 over the place? 8 1 was classified probably as a general 9 laborer. 1 worked third shift and cleaned 10 A. up what they call Union Number One 11 Q. Foundry. 12 Okay. Now, what were they making at this 13 A. particular foundry? 14 Q. Soil pipe. 15 And when you say "soil pipe," are you 16 talking about iron pipe? 17 Cast iron. 18 A. Cast iron. Okay. And when you were doing 19 Q. cleanup, were you - 1 know they use sand 20 in the molds for that stuff. Were you 21 with a broom and shovel cleaning up sand? 22 A. A broom and a shovel cleaning up sand. 23 Q. Page 19 being processed. And we'd just shovel it up, and it would be black-looking sand. That's all 1 can tell you. Okay. It was used. And do you know if there was ever any did you ever see any indication that that sand was contaminated with PCBs or Aroclors? No. And you left Union Foundry to go to work at Monsanto? Correct. And 1 assume that was a better paying job; in other words, you didn't get fired from Union Foundry, you were happy to make that switch? Right. You mentioned that you worked -- or you've served in the military for three years in the U.S. Army? Yes. What was your - 1 forget the designation. 1 Q. 2 3 A. 4 5 6 Q. 7 8 A. 9 Q. 10 11 12 A. 13 Q. 14 15 A. 16 Q. 17 18 19 20 21 22 A. 23 Page 18 And what would you do with that sand when 1 A. you were done with it? 2 Q. Most of the time, we put it on a conveyor 3 A. belt, and we shoveled it back to a 4 conveyor belt that took it someplace. 5 Q. Did this sand have a particular 6 appearance? 7 A. Dirty. 8 Q. Dirty. Okay. Color-wise, was it 9 light-colored sand, medium, dark, depend 10 from day to day? 11 Dark. 12 Dark sand. And when you say "dirty," what 13 A. was dirty about it? 14 The color because it was dark. 15 Dirty as in it's got dirt on it, which is 16 Q. brown; dirty because it's got oil on it, 17 which is black; dirty because it's got 18 flecks of other material in it? I'm 19 trying to figure out what you mean 20 A. by dirty. 21 Q. The sand that we shoveled up would be what 22 would come off the pipe, 1 guess, after 23 Page 20 MOS? Uh-huh, MOS. Chemical biological radiological laboratory specialist. And I'm going to bet that you served at Fort McClellan? Correct. Don't tell us anything that you'd have to shoot us after you tell us, but tell us what you did as a lab specialist in the chemical biological radiological department. Primarily checked impregnated clothing for completeness of coverage of the impregnating materials. And when you say "impregnated," this was textiles that had had an application to it so that nerve gases couldn't penetrate that textile; correct? Essentially, yes. And if it was only ninety-nine percent impregnated, just as good as not impregnated at all? Pages 17-20 HARTOLDMONO013663 1 A. 2 Q. 3 4 A. 5 Q. 6 A. 7 8 Q. 9 A. 10 Q. 11 12 A. 13 14 15 Q. 16 17 A. 18 Q. 19 A. 20 Q. 21 22 23 A. Page 21 I'm not sure. But the bottom line is you were trying to make sure it was completely sealed up? Correct. And you did that for three years? 1 did that for two years. And then, 1 spent a year in Germany. What did you do in Germany? 1 was a chemical staff specialist. And what sort of responsibility did you have as a chemical staff specialist? 1 was excess, so 1 covered a lot of jobs, such as mail clerk, RNR, NCO, training NCO. Got you. What rank did you achieve in the Army? Specialist, Fourth Class. Honorable discharge? Yes. Did you get any -- you obviously went to basic training. Where did you do your basic? Fort Knox, Kentucky. 1 2 3 4 A. 5 Q. 6 7 8 9 10 A. 11 Q. 12 13 14 15 16 A. 17 Q. 18 A. 19 Q. 20 A. 21 Q. 22 A. 23 Q. Page 23 precursors to the VX nerve agent here at the Anniston plant at least for a while. Do you know anything about that? 1 know no facts about that. Ever hear anything when you were at Fort McClellan about them having done research here in Anniston at one point in the '50s when they were producing and developing the processes for making a nerve agent? Repeat that again, please. Yeah. Have you ever heard anything to suggest that some of the research that was done over here in the United States about how to produce nerve agents was done at the Anniston Monsanto facility? No. Okay. How is your health, Mr. Byrd? Good. Ever had any surgeries? Yes. What have you had done surgically? Internal hemorrhoids, vasectomy, hernia. That's good enough. Anything less than 1 Q. 2 3 A. 4 Q. 5 6 7 A. 8 Q. 9 10 11 A. 12 13 14 15 Q. 16 A. 17 Q. 18 19 20 21 22 A. 23 Q. Page 22 Great place. And where did you go after 1 that? 2 Fort McClellan. 3 A. And you took some training there, 1 4 Q. presume, before they actually put you 5 A. in -- 6 Q. Correct. 7 A. Tell me what kind of training you had 8 Q. prior to actually taking on the task of 9 A. checking these -- 10 Q. We had the MOS training. And 1 don't 11 A. recall how many weeks it was, but 12 Q. essentially, it's classroom and literary 13 A. training. 14 Was this something that you chose? 15 Q. Yes. 16 A. And what was it about this particular worl<17 Q. that intrigued you, made you want to 18 select that, as opposed to any other MOS 19 A. you might have tried to get into in the 20 Q. Army? 21 A. 1 like chemistry. 22 Q. Okay. 1 understand they made one of the323 A. Page 24 that -- and 1 apologize. 1 really didn't need to know about those. Okay. Ever have cancer? No. Do you consume any alcoholic beverages? Occasionally. Use any tobacco products? Yes. What is your tobacco of choice? Cigarettes. Okay. When did you start smoking? 1 was around fourteen or fifteen years old. And you're a native of Indiana? 1 was born in Arkansas. Okay. Grew up in Indiana? Went to high school in Indiana? Went to high school in Indiana. What did your father do for a living? I'm not sure. Okay. Ever tried to quit smoking? Yes. Pages 21 - 24 HARTOLDMONO013664 1 Q. 2 3 A. 4 Q. 5 6 A. 7 Q. 8 A. 9 Q. 10 A. 11 Q. 12 13 A. 14 Q. 15 16 A. 17 Q. 18 A. 19 20 Q. 21 A. 22 Q. 23 Page 25 Like Mark Twain said, it's easy; done it 1 Q. lots of times? 2 Yeah. 3 A. Do you currently receive any sort of 4 Q. financial benefits from Monsanto? 5 Such as retirement? 6 A. Uh-huh (indicating yes). 7 Q. Yes. 8 Pension and subsidized health insurance? 9 A. Yes. 10 Q. Were you ever a member of the 11 International Chemical Workers Local 125? 12 A. Yes. 13 Q. And did you ever hold any positions, such 14 as officer or committeeman? 15 Yes. 16 Tell me about that. 17 A. 1 was trustee a few times. I'm not sure 18 Q. how many times, probably three or four. 19 An elected position? 20 A. Yes. 21 Q. And the trustee, if 1 understand it 22 correctly, basically monitors the 23 A. Page 27 Okay. So this was an ICW training facility in Cincinnati? Yes. And their headquarters is in northern Ohio, as 1 recall? 1 think so. I'm not sure. And you went up there and took some course work there? Correct. And do you recall roughly when that occurred? In the '80s. And you, in turn, would come back to this region and travel to various local and help train entire workforces or just representatives of the union? Both. In health and safety, primarily hazardous material procedures? Correct. And how long did you serve in that capacity? To the best of my recollection, five or 1 2 A. 3 Q. 4 A. 5 Q. 6 7 A. 8 9 10 11 12 Q. 13 14 15 16 17 A. 18 19 20 21 22 23 Page 26 financial status of the organization? 1 Correct. 2 Q. Ever hold any positions with the national? 3 Yes. 4 What did you -- what position did you hold 5 A. with the national NCW? 6 Q. 1 was --1 don't know the correct 7 A. terminology, but 1 was the international 8 Q. representative for, 1 guess, the southeast 9 A. region for health and safety -- I'm not 10 Q. sure of the terminology for it. 11 Let me see if 1 am understanding. The 12 international would have had a committee 13 for health and safety, and they would 14 bring in people from different regions to 15 sit on this committee? 16 Let me see if 1 can explain it. 1 was 17 trained by the international training 18 A. center in Cincinnati, Ohio. And my 19 Q. function was to meet with unions, in 20 whatever region 1 was assigned to, to 21 A. assist them in training primarily for 22 Q. hazardous materials. 23 A. Page 28 six years. Okay. Did you ever move from being a rank-and-file ICW member to a member of management as a salary employee? Yes. And when did that happen? 1996, 1 think. Just a couple of years before you retired? Correct. Okay. Let me talk to you for a moment, if 1 might, about the medical monitoring, medical surveillance program in place at Monsanto. Tell me, if you can, what you recall being involved in the annual physicals that y'all got. MR. MYERS: Object to the form. Go ahead and answer. Okay. Pulmonary function test. Would they actually have you breathe into the Right, correct. Okay. A fit test for your respirator and your - Pages 25 - 28 HARTOLDMONO013665 1 Q. 2 A. 3 Q. 4 A. 5 6 Q. 7 8 9 10 A. 11 Q. 12 A. 13 14 15 16 17 Q. 18 19 20 21 22 23 Page 29 I'm sorry. A which kind of test? 1 A fit test, F-i-t. 2 Q. Okay. Go ahead. 3 A. Hearing test, eye test, had several forms 4 Q. to fill out. 5 And those would have been designed to 6 elicit changes in your health history in 7 the preceding year that the doctors might 8 want to be aware of? 9 Correct. 10 A. Okay. Ever take blood? 11 Q. Blood tests. They kept up with our shots. 12 1 don't recall which shots they were. And 13 then, the nurse would question us about 14 A. some things. And then, of course, we 15 Q. would see the physician. 16 A. Okay. This is a difficult question, but 17 Q. you may be the one guy that might better 18 A. answer it. In the entire time that you 19 were there at Monsanto, do you recall that 20 Q. changing much? Can you recall any 21 A. specific additions or deletions to the 22 Q. protocol for the annual exam? 23 Page 31 was at regular intervals. More frequently than annual? Yes. Any other kind of routine regular medical monitoring of the surveillance that you can recall that took place at the facility? MR. MYERS: Object to the form. Go ahead. None that 1 recall. And do you ever recall learning anything about your particular health status as a result of these annual physicals? Yes. Tell me about what it revealed for you. The EKG is another one they performed. Okay. 1 had a --1 would have what they call PVCs occasionally in the heartbeat. Were you referred to a cardiologist? 1 was given the name of a cardiologist. Okay. Have you, in fact, spoken with a cardiologist about this particular aspect 1 A. 2 3 4 Q. 5 6 A. 7 8 9 Q. 10 11 A. 12 Q. 13 14 15 16 17 A. 18 Q. 19 20 21 22 23 A. Page 30 The basic stayed pretty much as it was 1 when 1 first went there. They did add 2 A. some things. 3 Q. Is it fair to say that most of that was 4 A. stuff they were doing in the mid '60s? 5 Q. Correct, although they would add things. 6 As 1 said, they did add the fit test for 7 A. the APRs. 8 Q. Were they doing pulmonary function back in 9 A. the mid '60s? 10 1 don't recall. 11 Q. You're the first guy that's mentioned it. 12 A. That's the only reason 1 was wondering. 13 Q. And plus, do you recall where you took 14 A. that test? Did they have pulmonary 15 function? 16 It was there at the plant. 17 Q. Okay. And one fellow mentioned them 18 taking blood every six weeks when you 19 A. worked in parathion to check the 20 cholinesterase levels. Did they ever do 21 that with you? 22 Q. Yes. 1 don't recall the intervals. It 23 Page 32 with your heartbeat? No. How long ago did that happen? In the '80s. Any other revelations that came to light through this medical monitoring? My cholesterol was high. Okay. And the ratio between the HDL and LDL was out -Not what they --- too high. Yeah, it was too high. Okay. And some of the other blood work was not in the normal range. And 1 couldn't tell you what those were. It sounds like none of this ever particularly perturbed you or worried you? No. The doctor made suggestions and gave me guidance on how to straighten it out, so -And 1 assume you didn't have to pay anything for this service? Pages 29 - 32 HARTOLDMONO013666 1 A. 2 Q. 3 4 5 A. 6 Q. 7 A. 8 Q. 9 A. 10 Q. 11 12 13 14 15 16 17 A. 18 19 20 21 Q. 22 23 Page 33 No. 1 A. Do you still have friends and 2 Q. acquaintances who work there at the 3 facility? 4 Yes. 5 Would it be a handful, dozen, dozens? 6 A. Probably a dozen. 7 Q. Do you get the Bama Briefs? 8 Yes. 9 A. Do you ever recall anything in the Bama 10 Q. Briefs where the plant tried to advise the 11 A. workforce and the retirees what was going 12 on out there with respect to the PCB 13 Q. contamination, kind of their side of the 14 A. story? 15 Q. MR. MYERS: Object to the form. 16 A. 1 don't know if it was so much their side 17 Q. of the story. They just did have an 18 article or two, 1 think, in there about 19 it. 20 A. Okay. Let's talk about the stuff you did 21 there at Monsanto. And if I'm recalling 22 correctly, you started in '65. So tell me 23 Q. Page 35 Correct. And your job, 1 guess, as much as anything, was to make sure the electrical balance was right, the right amount of electricity flowing through? Yes. And was there a waste stream generated in that process? Yes. What sort of waste streams did you have? Water, some hydrogen, 1 think, and some brine. Okay. What did you do with the hydrogen? 1 don't really recall. What did you do with the water? It went out of the department. You don't know to what extent, if any, it received treatment for possible mercury contamination, by way of example? No. 1 know there was a specific place that it had to flow and go out and all of that. Okay. Do you know -- was there a way to 1 2 3 A. 4 Q. 5 6 A. 7 Q. 8 A. 9 Q. 10 11 A. 12 Q. 13 14 15 A. 16 Q. 17 18 A. 19 20 21 22 Q. 23 Page 34 what was the official job title you held 1 when you first got there. 2 1 was a process operator or operator. 3 Operator. And my sense is that you would 4 A. be an operator in a particular department? 5 Correct. 6 And what department did you begin in? 7 Q. Chlorine. 8 And that would have been from '65 until 9 roughly when? 10 1 couldn't tell you the dates. 11 A. Any feel for whether you would measure 12 your service there in months versus years 13 Q. versus decades? 14 The chlorine department was years. 15 A. Okay. And tell me what you did as an 16 operator in the chlorine department. 17 Q. 1 was the primary operator and the cell 18 room operator. Essentially, we took 19 brine, put it through an electrolysis 20 process, and made chlorine and caustics. 21 One of the electrodes that that brine was 22 run over was mercury, was it not? 23 A. Page 36 make up brine? Obviously, you just put more brine into the vat, 1 assume, if it ran down? It was a continuous process, so we had to make sure our levels stayed the same. So it was a makeup with water and salt. What about the mercury? Would it eventually go somewhere, or was it just steady stated, just always there, never had to worry about the mercury? No. There were times where we had to add mercury. And what kind of a makeup rate did you have on the mercury? I'm not sure. 1 know we reclaimed mercury -That's what I'm trying to figure out. If we draw a black box to represent the plant, we know that there was mercury coming in occasionally from some supplier. 1 mean, y'all didn't make it there at the plant, did you? No. It was purchased, I'm sure. Pages 33 - 36 HARTOLDMONO013667 1 Q. 2 3 4 5 6 7 A. 8 9 Q. 10 11 12 13 14 15 16 17 A. 18 19 20 Q. 21 22 23 A. Page 37 Isn't it fair to say that whatever 1 quantity you had to purchase and bring in, 2 A. that would represent -- there had to be a 3 waste stream coming out of the box, so to 4 speak, with a comparable quantity of 5 mercury? 6 Q. Yes. But how --1 don't know how much or 7 anything like that. 8 If we went to the cost accounting sheets 9 that they maintained where they said, 10 here's how much NACL salt we use to make 11 chlorine; here's how much water; here's 12 how much electricity; here's how much 13 A. mercury per unit, might that give us a 14 Q. fair idea of how much mercury consumption 15 there was in the plant? 16 I'd just have to make an assumption and 17 A. say yes. 1 don't know all of the 18 Q. chemistry that all of that involved. 19 But you did say, to be fair, that y'all 20 sometimes were able to recapture some of 21 this stuff and reuse it? 22 A. We tried to recapture. We had systems set 23 Q. Page 39 did in the Therminol department. Okay. Again, 1 was an operator. And 1 processed the raw materials that come in and make the heat transfer, the liquid side. 1 haven't had anybody yet just tell me they worked in the Therminol department. It was always the Aroclor department. Was Therminol a separate department; in other words, you'd get Aroclor from the Aroclor department and make Therminol, or were you a subset of the Aroclor department? 1 guess you can call it a subset. You were in the same building. But your particular still, you were running out the stuff that would be used for Therminol? Heat transfer fluid. Yeah. As opposed to maybe running out the stuff that they would make for transformers, for instance, or hydraulic fluids? 1 thought it was all the same. Okay. You mentioned raw materials. And 1 1 2 3 Q. 4 5 A. 6 7 Q. 8 A. 9 Q. 10 A. 11 Q. 12 13 A. 14 Q. 15 16 17 18 19 20 21 22 A. 23 Q. Page 38 up so that if we physically lost it, it's 1 supposed to recapture it. 2 All right. What was the second thing you 3 did there at Monsanto? 4 A. From there, 1 went to the Therminol 5 Q. department. 6 A. Still as an operator? 7 Q. Still as an operator. 8 Any idea as to when that occurred? 9 Whenever chlorine shut down. 10 A. Okay. That answered that. And how long 11 do you think you worked in Therminol? 12 Q. Probably a couple of years. 13 And 1 would have asked you why you 14 shifted, but you've answered that 15 question. There wasn't a chlorine 16 department anymore. 17 A. All right. Therminol, 1 understand 18 Q. to be -- and 1 want you to correct me if 19 I'm wrong -- was the heat transfer product 20 made with Aroclor? 21 Correct. 22 A. Okay. And tell me, if you will, what you 23 Page 40 think 1 know what the raw materials are for Aroclor generically, and that would be the biphenyl coming in and the chlorine? Yes. And that's pretty much it? Right. And you'd have cooling water, and you'd have heat through steam. But basically, it's those two things? Correct. The biphenyl and the chlorine was it. Okay. Now, if we're making Therminol, when we pull off the particular specific gravity Aroclor we want, do we add anything else to it to make it Therminol, or is that pretty much it? My part, that was it. You said, "your part." Was there somebody down the line who was adding something else to this product to make it the finished Therminol? Some of it, 1 think, would go -- it was a long time ago. 1 ran the chlorinators. Pages 37 - 40 HARTOLDMONO013668 1 2 3 Q. 4 5 6 A. 7 Q. 8 9 10 11 12 13 A. 14 Q. 15 16 A. 17 18 19 20 Q. 21 22 A. 23 Q. Page 41 And we passed the majority of it on to the stillers. Okay. So if there's another thing to add, that's even yet another step beyond what you were doing -Correct. -- at the chlorinator? Now, you're sitting there at the chlorinator, and you've got a feed of biphenyl, and you get a feed of chlorine. Was this a continuous operation or batch feed when you were doing it? Yes. Good answer. They made the changeover while you were there? No. We -- depending on which chlorinators 1 was running, we had some chlorinators that were continuous and some that were batch. All right. So you'd have this stuff going, and then, out would come Aroclor -Yeah. -- chlorinated biphenyl? 1 A. 2 Q. 3 4 A. 5 Q. 6 A. 7 Q. 8 9 A. 10 Q. 11 12 13 14 15 A. 16 17 Q. 18 19 A. 20 Q. 21 22 23 A. Page 43 No. Was Therminol still in existence when you did that? 1 think so. Okay. So why did you make that change? 1 have no idea. Okay. And how long did you work as an operator in parathion? Probably a couple of years. We're getting to the point where there wasn't any PCB being made out there. It seems like, if I'm following the timing here. Does that sound consistent with your recollection? Yeah. At some time, the PCBs went away. 1 don't know when. All right. Tell me what you did as an operator in the parathion department. 1 ran the washing columns. And was this a piece of equipment that kind of cleaned up the finished product after it came out of the reactor vessel? It was not a -- yeah, 1 guess it was a 1 A. 2 Q. 3 4 A. 5 Q. 6 7 A. 8 Q. 9 A. 10 11 Q. 12 13 14 A. 15 Q. 16 17 18 19 A. 20 Q. 21 A. 22 23 Q. Page 42 Yes. 1 And was there any waste stream coming out 2 of the chlorinator? 3 The vapors being given off. 4 Which 1 understood to be a hydrogen 5 chloride gas -- 6 Q. Correct. 7 -- that you all were turning -- 8 A. Right. That was captured and sent up to 9 Q. the acid plant. 10 And that got passed on. Did you have a 11 A. still bottom coming out of the chlorinator 12 like they did out of the still? 13 No. 14 Q. So you didn't have any waste streams 15 A. really to fiddle with? Y'all liked 16 Q. everything that came out of the 17 chlorinator? 18 A. We liked everything. 19 Okay. What's the next thing that you did? 20 Q. 1 think 1 went to parathion as an 21 A. operator. 22 Again, any idea when that happened? 23 Q. Page 44 finished product. There was a lot of steps in making parathion, and 1 had just a small part of the steps. But essentially, yeah, 1 took probably the impurities out. Was there a waste stream generated in the step that you were involved with? Yes. And tell me about that waste stream, if you would, please. It was the materials that 1 had washed out of the parathion, and it went to the waste treatment part. The biological waste treatment basins? Correct. And what did this stuff look like that you were washing out? A --1 guess you would call it a light-brownish liquid. Okay. What's the next job that you had? 1 think 1 went to para-nitrophenol, PNP, as a chief operator. And that would be a promotion, 1 presume? Pages 41 - 44 HARTOLDMONO013669 1 A. 2 3 Q. 4 5 6 7 8 9 10 11 A. 12 13 14 Q. 15 16 17 18 A. 19 Q. 20 21 A. 22 Q. 23 Page 45 Well, let's see. 1 was a chief operator 1 Q. in parathion also. 2 A. Okay. 1 don't know how long you were 3 there. You said just a couple of years. 4 1 mean, parathion was actually done away 5 Q. with, but it seems like that should have 6 A. been still around a couple of years after 7 Q. you started. So I'm just curious why you 8 would have switched to PNP. Was it just 9 A. to learn more positions at the plant? 10 Q. 1 like to learn. And as you said, 11 there's --1 wanted to know a little bit 12 about everything. 13 A. And the guys said there was a concept they 14 Q. had out there called cross-training where 15 they wanted people to know as much as 16 A. possible. 17 Right. 18 Q. It wasn't that you were necessarily afraid 19 of being around parathion? 20 No, no. 21 And how long do you think you worked as a 22 A. chief operator in PNP? 23 Q. Page 47 What's the next job that you had? It was -- at that time, 1 believe that's when 1 went to maintenance as an electrician. Is that plant-wide? Plant-wide. And the reason for that was -- why would you want to make that change? 1 just wanted to be an electrician. Okay. Nothing wrong with that. And how long do you think you were an electrician in the maintenance department? Three years. What sorts of things did you actually do there? Everything from run conduit to troubleshoot instruments. Okay. I'm not sure if they would have still been doing Aroclor at that point in time. Do you have any recollection as to whether or not it existed? 1 don't think it did. You don't have any recollection of being 1 A. 2 Q. 3 4 5 A. 6 Q. 7 8 9 10 A. 11 12 13 14 15 Q. 16 A. 17 18 19 Q. 20 21 22 23 A. Page 46 Probably a couple of years there too. 1 Okay. And did you have a particular role 2 to play there? I'm assuming you did all 3 the tasks that were in the PNP department? 4 1 was trained in them. 5 Is that the department where they said 6 A. there's really only two jobs; one was 7 Q. running the reactor, and one was running 8 the waste stream? 9 Well, you run the reactors, and the other 10 A. one is you run the belt filter and the - 11 1 can't remember who runs the acidifier. 12 Q. But there's essentially only two or three 13 jobs over there. 14 And you'd do all of those? 15 Well, 1 was trained in them. 1 wouldn't 16 do - 1 was chief of the two guys that was 17 on my shift. 18 Got you. And the waste stream that was 19 generated in PNP, if 1 understand 20 A. correctly, was a liquid stream that was 21 sent to the biological treatment? 22 Q. Correct. 23 A. Page 48 involved in either expanding the Aroclor department, as we understand happened in the late '60s, or tearing it down, as happened in the early '70s, as an electrician? 1 don't think so. Okay. Did you ever have to fiddle with an automatic sampler when you were an electrician? Explain what you mean by automatic sampler. I've seen a document from the early '70s, a Monsanto memo to the maintenance about making sure that their samplers cross-sampled every day, and like if it got cold like today, you keep a light bulb burning inside the little cabinet so it would stay warm. That's about all 1 know about it. Okay. Yes, 1 have worked on automatic samplers. Tell me where those were located. 1 recall one 1 worked on was an automatic Pages 45 - 48 HARTOLDMONO013670 1 2 3 Q. 4 5 A. 6 Q. 7 8 9 10 A. 11 Q. 12 13 14 15 16 A. 17 18 19 20 Q. 21 22 A. 23 Page 49 sampler at the outflow of our waste 1 treatment plant. 2 What was it that you were doing on it, as 3 best you recall? 4 A. 1 had to change the tubing. 5 Okay. That doesn't sound terribly 6 electrical, but I'm guessing that if it 7 didn't work, the electrician got to fix 8 it? 9 Normally. 10 If 1 wanted to talk to you about what kind 11 of sample they drew and how often they 12 drew a sample and where that sample went, 13 Q. do you have any knowledge about any of 14 that? 15 1 can tell you it was continuous. It went 16 to a jug where the waste treatment 17 operator collected the sample and took it 18 A. to the lab. 19 When you say "continuous;" in other words, 20 Q. it's drawing a couple of drops a second? 21 I'm not sure what rate it is, but it would 22 continually sample the flow. 23 Page 51 was the new motor control center a pollution control project to your way of thinking? They had added some new pollution control equipment, new motors, those types of things that would be associated with the motor control center. 1 guess you can call it an expansion. There was one system we put in that had to do with the vapors, and 1 don't recall exactly what that was. It was over toward the -again, the parathion department. You said a system dealing with vapors. Is this a -- if 1 mention Brink coaleser, would that mean anything to you? Have you ever heard of that? Do you know what that is? I've heard it, but 1 don't remember what it was. So you don't know what it was; you just remember you would help them install something to control vapors coming off the parathion process? 1 Q. 2 3 A. 4 Q. 5 6 7 8 9 A. 10 Q. 11 12 13 A. 14 Q. 15 16 17 18 19 A. 20 Q. 21 A. 22 23 Q. Page 50 And you say a jug. How big a jug are you 1 A. talking about? 2 Five gallons, approximately. 3 Q. Are you aware of any other locations 4 A. within the facility where a sampler like 5 this might have been located? 6 MR. MYERS: At what point? 7 Q. MR. CUNNINGHAM: At any time. 8 No. 9 Do you have any knowledge as to when a 10 sampler such as this was first utilized at 11 A. the facility? 12 Q. No. 13 A. Okay. Any other projects that you recall 14 Q. being involved with, when you were in 15 A. maintenance as an electrician, that dealt 16 Q. with pollution control, as you perceived 17 it? 18 Yes, there were several. 19 Okay. Tell me what those were, please. 20 A. One was putting in a new motor control 21 Q. center for parathion. 22 Okay. I'm sorry. Before you move on, how 23 A. Page 52 1 can't remember if it was P2S5 or parathion. Okay. 1 know I've worked on several projects. But to tell you exactly what they were for or the specifics of them -Okay. That's fine. You've remembered some new stuff. You've been helpful. What's the next job you had after you were an electrician? It was chief operator. Of Plant-wide. Plant-wide. And how long did you do that? Probably about six years or so. Is there anything that stands out in your mind as a benchmark that we could use to try to figure out what six years on the calendar that was? No. Okay. And why did you shift from being an electrician to being a chief operator? More money. Pages 49 - 52 HARTOLDMONO013671 1 Q. 2 3 4 5 6 A. 7 8 9 10 11 Q. 12 13 14 A. 15 16 17 Q. 18 19 20 A. 21 22 Q. 23 Page 53 Okay. Tell me what you did as a chief 1 operator. And that --1 realize you'd 2 been a chief operator before. In that 3 A. particular point in time, what were you 4 doing? 5 Q. As a plant-wide chief operator, we had 6 responsibility for the plant during off 7 A. shifts, holidays, weekends, and all of 8 that. We were pretty much the person in 9 charge out in the plant. 10 Would there have been a chief operator in 11 Q. the parathion department at the same time 12 A. you were on-site? 13 Q. No. They had made the -- the plant-wide 14 chief operator came after the department 15 A. chief operators. 16 Q. They got rid of a lot of departmental 17 chief operators and made one plant-wide 18 A. chief operator? 19 They changed the work designation, 1 20 Q. guess. 21 A. So you weren't the production foreman that 22 I've heard some people talk about? 23 Q. Page 55 contamination? MR. MYERS: Object to the form. I've had to assign folks to work on jobs that might have been. Give me an example of one that you think might have been related to Aroclor. There was a pit that we pumped out and had some stuff in it, so we got a crew to go in there and put it in waste drums and take care of it that way. Was this a sump? You could, 1 guess, consider it a sump. I'm more asking what you considered it. Describe it for me. 1 call it a collection pit. Collection pit. Okay. And where was it in the plant geographically? Across the street from the production office building. Across the street to the north? To the south of the production office building. Okay. What was your understanding of what 1 A. 2 3 Q. 4 5 6 7 A. 8 Q. 9 10 11 12 13 14 A. 15 Q. 16 17 A. 18 19 20 Q. 21 22 23 Page 54 No. You can equate a chief operator to a 1 leadman. 2 Okay. Are you pretty confident that this 3 A. would have been in the time frame when 4 Q. Aroclor was no longer being made at the 5 facility? 6 Yes. 7 A. And 1 take it if there was a problem with 8 Q. Aroclor still on the site, in terms of 9 A. being in the sewers, in the soil, in the 10 Q. dumps, that wouldn't have been anything 11 you, as a chief operator, would have been 12 A. responsible for dealing with? 13 Not directly. 14 Q. Okay. That answer suggests to me that you 15 were indirectly? 16 A. If we had to assign someone to work on 17 something out of the ordinary, that's how 18 Q. we would be involved with it. 19 A. Okay. And 1 take it -- well, 1 shouldn't 20 Q. presume it. Do you ever recall having to 21 A. assign someone such an out of the ordinary 22 Q. project to address some sort of Aroclor 23 Page 56 was collected in this collection pit historically? Storm water. Okay. Storm water at the facility, to my way of thinking, classically drains south to north? Yeah. And was this open to the air? Yes. Okay. And it was collecting storm water, and it was made of concrete? 1 think it was lined with brick. I'm not sure. Okay. And what was inside of it that had to be cleaned out? Primarily water and then some other material that was in there. Sediment? Yeah, you can call it sediment. Mud? Yeah, essentially. And what you're saying is, it's conceivable that some of that mud might Pages 53 - 56 HARTOLDMONO013672 1 2 A. 3 Q. 4 5 6 A. 7 Q. 8 9 10 A. 11 Q. 12 A. 13 14 Q. 15 16 17 18 19 20 21 A. 22 Q. 23 Page 57 have had PCB in it? 1 Q. Yeah, it's conceivable. 2 The surface water -- storm water, 1 think 3 was the phrase used, would some of that 4 had been coming from the south landfill? 5 No. 6 A. Where would that storm water have hit the 7 Q. ground before it made its way to this 8 collection pit? 9 1 would say in the east area of the plant. 10 Okay. 11 And when 1 say "east," I'm talking about 12 the railroad track dividing east and west. 13 And do you have any idea at all, in terms 14 of the year or decade, when you think that 15 A. happened? 16 MR. MYERS: When they cleaned it 17 out, or when the water -- 18 MR. CUNNINGHAM: When they cleaned 19 it out. 20 Q. No. 21 Was this a recurring situation? 1 mean, 22 A. did this thing need to be cleaned out 23 Page 59 If it was just dirt and just sediment that come in with the rain, do you think there's any reason you wouldn't have just put that off somewhere on the ground out of the pit? No. And again, I'm not trying to put words in your mouth. I'm just trying to understand. It would seem to me like if that's all that was in there, you would just get it out of the pit, as far as with a shovel, and throw it, basically. It makes me think somebody must have suspected -- No. We did not do anything like that at the plant. 1 mean, if there was -- it didn't matter what it was, we put it in receptacles. 1 mean, they were very stringent on housekeeping. Okay. But the receptacles of choice in this case were sealed drums? I'm not going to say always. But usually anything that we put in a drum, we put a 1 2 A. 3 Q. 4 5 6 7 A. 8 Q. 9 10 11 12 A. 13 Q. 14 15 16 17 A. 18 Q. 19 A. 20 21 Q. 22 23 A. Page 58 every so often? 1 No. 2 Q. Was there something unique about the time 3 you -- something that happened that caused 4 you to have to clean it out on the 5 occasion that you recall? 6 A. Yes, but 1 can't remember what. 7 Q. Okay. Any other projects that you can 8 recall, as you sit here today, you think 9 A. might have involved some Aroclor 10 Q. situation? 11 No. 12 Is it the fact that you remember that 13 stuff being put in drums and taken to the 14 landfill why you think maybe that was an 15 A. Aroclor situation? 16 Q. It wasn't taken to the landfill. 17 Oh, I'm sorry. Where did it go? 18 A. 1 don't know. But at that time -- well, 1 19 don't know. 20 Q. How do you know they weren't taken to the 21 landfill? 22 A. 1 think our landfill was closed. 23 Q. Page 60 lid on. And you just don't recall where these drums got sent, but you had a recollection that you didn't think it was at the landfill? Yeah. Okay. What's the next job you held after being the chief operator, slash, leadman? Training resource person. Now, you're the first training resource person we've had. So we're going to have to inquire a little bit about that. I'm assuming that was a plant-wide kind of thing also? Correct. Do you recall how many years you served in that capacity? From the time 1 was chief operator until 1 went to salary. Okay. So you were still a rank-and-file, paid by the hour ICW guy -Yes. -- while you were a training resource Pages 57 - 60 HARTOLDMONO013673 1 2 3 A. 4 5 6 Q. 7 8 9 10 A. 11 Q. 12 13 14 A. 15 Q. 16 A. 17 Q. 18 19 A. 20 Q. 21 22 23 Page 61 person? What was the motivation for going from chief operator to that new position? It was something I've always been involved in, and 1 had the opportunity to go into that field. And was this the stuff that we've kind of picked up on what you did in the Army, what you studied at school, what the union kind of trained you for? Correct. The training that you were a resource for was helping people understand how to work around hazard chemicals? Health, safety, OSHA regulations. Response? Correct. Okay. And tell me what a typical day would consist of for you in that capacity. Developing training, presenting training. Did you do that pretty much exclusively with and for the workforce in Anniston for Monsanto, or did you do any travel to other Monsanto plants? 1 2 3 4 A. 5 6 7 8 9 10 11 12 Q. 13 14 15 16 A. 17 18 Q. 19 20 21 22 23 Page 63 were you taught, and then what, in turn, did you pass on -- and I'm guessing those are the two -Right. Because the plant was so involved in safety and health, 1 had the opportunity to, as you said, go to several school seminars such as that. And that was my primary responsibility at that time when 1 was the training resource person, was to pass that information on to the workforce at the plant. In other words, you didn't go there, learn stuff, decide 1 don't believe that stuff, 1 think I'll teach them the Fran Byrd way of doing things? No. There's regulations that you have to follow. All right. And what would you have taught people to do if they had found out that there were hazardous materials -- and by "hazardous," 1 mean stuff that by federal regulations list as hazardous, emanating from the plant -- 1 A. 2 Q. 3 4 5 A. 6 Q. 7 A. 8 9 Q. 10 11 12 13 A. 14 Q. 15 A. 16 Q. 17 18 A. 19 Q. 20 21 A. 22 23 Q. Page 62 A little traveling. 1 It strikes me that you might have been a 2 Q. rather uniquely qualified person to do 3 that? 4 Monsanto has a lot of them. 5 Okay. 6 1 don't think I'm any better than anyone 7 else. 8 Well, you had worked with the Army in this 9 kind of field. You've had college 10 A. education in this field. Did it have a 11 fire brigade out there at the plant? 12 Yes. 13 Were you on the fire brigade? 14 Yes. 15 I'll bet Monsanto sent you to some 16 seminars? 17 Yes, they did. 18 So you had about all the training somebody 19 could have for this, didn't you? 20 Q. No, there's a lot more training. I'll 21 admit, 1 had a lot of training. 22 Okay. What did you train people -- what 23 A. Page 64 MR. MYERS: At what point in time? At the point that you were a training resource person -- that if they found out through a sample, through observation, through someone coming and telling them that, hey, there's PCB in this wastewater, what would you tell them they should do about that? MR. MYERS: Object to the form. Well, you threw the PCB in there -- as with anything that didn't belong, they would have to treat it according to the guideline that we have. 1 mean, we have -- they have procedures, a book of procedures that have to be followed for health and safety and also for department-wise. And so that's -- that's what they're strained -- we go through the procedures. Were you familiar with the NPDES system, National Pollutant Discharge Elimination System? 1 am familiar with it. Pages 61 - 64 HARTOLDMONO013674 1 Q. 2 3 4 A. 5 Q. 6 A. 7 Q. 8 9 10 11 A. 12 Q. 13 14 15 16 17 A. 18 19 Q. 20 21 22 A. 23 Q. Page 65 And that that sets numerical limits for 1 the release of various types of 2 pollutants? 3 Correct. 4 A. And did the facility have such a permit? 5 Yes. 6 And was it your understanding that if 7 chemicals other than allowed by that 8 Q. permit were discharged, they had to be 9 reported? 10 Correct. 11 And who were you all reporting to there ini 2 A. Anniston? If you became aware of a 13 Q. release, who did you understand and who 14 did you teach people should be contacted 15 A. about that? 16 Q. We taught the people to notify the 17 environmental department. 18 Okay. And who was running the 19 A. environmental department in your tenure 20 Q. there as a training resource person? 21 At that time, it was Jerry Brown. 22 And basically, Jerry had the training and 23 Page 67 MR. MYERS: When he was in the training resource job? MR. CUNNINGHAM: Yes. Okay. In the training resource job, I would not have been a part of that. That would have been strictly health, safety, and environmental. So you're just sort of like, here's how we're going to deal with things inside of the fence line? MR. MYERS: Object to the form. Training. You're training people how to operate as workers inside the fence? Correct. Your job was not to really deal with what happens if stuff gets outside of the fence? Not as a trainer resource person, no. If I'm correct in understanding when you studied in New Jersey or did the correspondence work out of New Jersey, that was hazardous response? 1 2 3 A. 4 Q. 5 6 7 8 A. 9 10 11 Q. 12 13 14 15 A. 16 Q. 17 18 19 20 21 22 23 Page 66 the expertise to know who to call, what to 1 A. do, was it even an issue? 2 Q. I'm going to assume so. 3 Yeah. That the rank-and-file guys working 4 as operators and laborers in the plant 5 really wouldn't know this kind of 6 information? 7 A. Right. They were taught if they had any 8 Q. question whatsoever, to notify their 9 supervisor. 10 And you didn't try to train them to know 11 all of these limits and such; you trained 12 A. them that if you're in doubt, you report 13 this up the line? 14 Q Correct. 15 Okay. What did your training tell you and 16 your education tell you needed to be done 17 if you learned of a release that was 18 off-site that had gotten away from the 19 A. facility itself? What sort of training 20 Q had you gotten about what to do for folks 21 who might come into contact with a release 22 such as that? 23 A. Page 68 Emergency disaster management. Emergency disaster management. And that, I'm assuming, dealt with if things really went to heck in a handbasket, how do you stay on top of it and have an orderly, effective response? Correct. Was any of that training or education involved with a scenario involving a release of a hazardous toxic substance away from the manufacturing facility? The courses that I took from Thomas Edison? Uh-huh (indicating yes), or anywhere. That one because of the name of it would lead me to conclude it might have, but anywhere that - Monsanto seminars, stuff a JSU, anywhere that you've been trained? Yes. Okay. So you do know something about wha' should be done if you think there's been a release outside the fence line? Yes, sir. Pages 65 - 68 HARTOLDMONO013675 1 Q. 2 3 4 A. 5 Q. 6 7 8 A. 9 Q. 10 A. 11 Q. 12 13 14 15 16 17 A. 18 19 Q. 20 A. 21 22 Q. 23 Page 69 Tell me what that is. 1 A. MR. MYERS: Object to the form. 2 Q. That's overly broad. 3 Call all available resources to mitigate. 4 Those resources, 1 assume, would include 5 A. municipal authority, such as fire 6 Q. departments? 7 A. Correct. 8 Q. Environmental authorities? 9 Correct. 10 What about trying to communicate to 11 potentially impacted residents in the area 12 A. of the release? What did your training 13 Q. tell you was the appropriate way to deal 14 with that? 15 MR. MYERS: Object to the form. 16 To deal with residents around the plant 17 A. site? 18 Q. Yeah, uh-huh. 19 A. As a training resource person, 1 didn't 20 get into that. 21 Okay. What's the last job that -- I'm 22 guessing there was one more? 23 Page 71 Yes. But there were no in-plant personnel involved in that? Was it all people from St. Louis? 1 was not involved in it. Okay. Was your department involved in it? No, 1 was not involved in it. But was your department involved with it? The department that -- to use your phrase, was designed to keep the workers safe and healthy? Probably. You said there were a lot of headaches with the job. What sort of things created the headaches for that particular position? Paperwork. Okay. Making certain that everything was the way it was supposed to be. Monsanto was very safety conscious, health conscious, and 1 had a lot of forms and a lot of information to keep up with to make sure 1 A. 2 Q. 3 A. 4 Q. 5 A. 6 Q. 7 A. 8 Q. 9 A. 10 Q. 11 12 A. 13 Q. 14 15 A. 16 17 Q. 18 19 A. 20 Q. 21 22 A. 23 Q. Page 70 That was safety and health technician. 1 That would have been plant-wide, 1 assume? 2 Q. Correct. 3 And that was when? 4 '96 through '98. 5 A. And that was a salaried position? 6 Q. Correct. 7 A. Promotion then, 1 presume? 8 Q. 1 considered it so. 9 Why wouldn't everybody consider it a 10 promotion? 11 A. A lot of headache. 12 Q. Oh, okay. What did you do as a safety and 13 health technician? 14 A. Made sure everybody in the plant stayed 15 Q. safe and healthy. 16 Okay. Do you know when in '96 you became 17 A. a safety and health technician? 18 Q. Not the exact date. 19 Were you involved in the sampling of a lot 20 A. of the workforce's blood for PCB? 21 Q. No. 22 A. Are you aware that happened? 23 Q. Page 72 everything was done correctly. Were you at all involved in the community right to know compliance work there at the plant? Part of it. What part did you have to play in that? Tier two reports. Okay. Do you ever remember preparing reports that would have put someone on notice of PCBs emanating from the plant? No. So even as late as 1998, that wasn't in y'all's community right to know paperwork? No. That wasn't my part. Oh, okay. So you finished as a safety and health technician? Correct. All right. And what was the health component of that job? Taking air monitoring samples -Okay. -- for the personnel. Now, how was that done? Tell me what kind Pages 69 - 72 HARTOLDMONO013676 1 2 3 A. 4 5 6 7 8 Q. 9 10 A. 11 12 13 14 15 16 17 18 19 Q. 20 21 A. 22 23 Q. Page 73 of equipment, where you set up, how long 1 Q. you were doing it, that sort of thing. 2 Of course, 1 had guidelines 1 had to 3 A. follow from corporate. Corporate would 4 come down, and we'd go over what we had, 5 Q. what type of samples. And then, I'd go 6 out and do those samples. 7 And was this a high-volume air sampler, 8 A. suck a lot of air through a filter? 9 Right. We had - whatever type tube was 10 Q. necessary to use, we had that. We put the 11 A. sampler on the person. Most of ours were 12 the TWA/TOB-type samplers. And so I'd 13 Q. calibrate the sampler, put it on the 14 person, come back and calibrate it, do the 15 paperwork, send the sample off, and then 16 A. come back, and I'd enter the information 17 Q. into the database. 18 Do you know what parameters y'all were 19 checking for when you did that sample? 20 At that time 1 did. 1 had a guide to go 21 A. by. 22 Q. Okay. What were you looking for? 23 Page 75 Tell me what personal exposure you would have had to PCBs or Aroclor to Montars. During the time 1 was operating in the Therminol department. And just again, how would you get PCB into your body working as an operator in the Therminol department? When I'd catch a sample, if 1 happened to spill it. Okay. If 1 happened to breathe the fumes maybe of the sample. And there would be some fumes coming off of it when it's hot like that particularly, as 1 understand it? On some of them, yes. What about steps that were taken to minimize that kind of exposure? First off, 1 assume you tried to be careful, tried not to spill stuff? Correct, uh-huh. And that you had personal protective equipment? 1 A. 2 3 4 5 Q. 6 7 8 A. 9 Q. 10 11 12 13 14 A. 15 Q. 16 17 18 19 A. 20 21 Q. 22 23 A. Page 74 Levels of -- if it was a welder, I'd be 1 A. looking for levels of cadmium, maybe when 2 he was welding. At PNP, I'd be looking 3 for the amount of PNCB. 4 Do you ever remember setting up an air 5 Q. monitor in an effort to take a sample for 6 A. ambient PCB levels around the plant? 7 No. 8 Q. Were you aware in this time frame, from 9 A. '96 to '98, that there was a problem, or 10 Q. at least allegations of a problem with 11 PCBs in the community? 12 A. MR. MYERS: Object to the form. 13 Q. Yes. 14 Did you ever see the air samplers that 15 were put in several locations around the 16 plant, such as over by the detention pond 17 and up on the south landfill? 18 1 was aware of them. 1 never looked at 19 them. 20 A. You weren't involved in any way in that 21 Q. kind of sampling? 22 No. 23 Page 76 We had personal protective equipment. The company furnished us what we call muzzles, which were air respirators, gloves, overshoes. Kind of coveralls? We were supposed to wear our sleeves rolled down. Okay. Face shields? Face shields. So in a sense, you were covered from head to toe as an operator? We were supposed to be, yeah. And I'm assuming -- as you say, Monsanto was a diligent company concerned about health and safety, and even yourself, during certain periods of time as a diligent health and safety technician, you would do everything you could to make sure people complied with those rules? Yes. And if somebody wasn't wearing what they were supposed to wear, was spilling stuff needlessly, they would be talked to about Pages 73 - 76 HARTOLDMONO013677 1 2 A. 3 Q. 4 5 A. 6 Q. 7 8 9 A. 10 Q. 11 12 13 14 A. 15 16 17 Q. 18 19 A. 20 Q. 21 22 23 Page 77 that -- 1 Correct. 2 -- in however stern of terms were 3 necessary? 4 Right. 5 And 1 assume y'all had ventilation there 6 in the area where you'd be working arounc1 7 this stuff? 8 Yes. 9 And as 1 understand it, there were 10 facilities for changing clothes. If you 11 got some on your clothes, you didn't have 12 to wear that home -- 13 A. Right. And -- yeah. If you got something 14 on you, you were supposed to go take a 15 Q. shower and change clothes -- 16 You didn't even wait for the end of the 17 A. day? 18 No. 19 Okay. Did y'all go to bottled water in 20 the plant at some point? Did they start 21 providing bottled water there at the plant 22 Q. at some point? 23 Page 79 "Experimental work in animals shows that prolonged exposure to Aroclor vapors evolved at high temperatures or by repeated oral ingestion would lead to systemic toxic effects. Repeated bodily contact with the liquid Aroclors may lead to an acne-form skin eruption," close quote. Was that something that you ever recall being told when you were working in Therminol? MR. MYERS: Object to the form. 1 remember reading that, but 1 don't recall when. Okay. Do you think you can pick a decade when you might have known that? It would have been in the '60s. But the company was always good about telling you what you were working with. 1 mean, that was part of our indoctrination in our safety meetings. Okay. Let me read you this next paragraph. It says, "Suitable draft 1 A. 2 Q. 3 A. 4 Q. 5 A. 6 7 8 9 Q. 10 11 12 13 14 A. 15 Q. 16 17 18 19 A. 20 21 22 Q. 23 Page 78 In a couple of places. But, no -- 1 No? 2 No. 3 So they didn't provide it in -- 4 Now, they brought some in, but that was in 5 a training trailer while 1 was there 6 because it didn't have a water fountain in 7 it. 8 Okay. What were you told about the 9 toxicity of PCBs when you went to work as 10 a Therminol operator a couple of years 11 A. after 1965? 12 Q. MR. MYERS: Object to the form. 13 1 don't recall. 14 Do you think you were told something about 15 their particular toxicity as opposed to 16 any other compound? 17 A. MR. MYERS: Same objection. 18 Q. 1 don't know if it was singled out. We 19 were just --1 remember being told about 20 safety procedures. 21 Okay. Let me read you something from an 22 Q. older document about Aroclor. Quote, 23 Page 80 ventilation to control the vapors evolved at elevated temperatures, as well as protection by suitable garments from extensive bodily contact with the liquid Aroclors, should prevent any untoward effects." Now, am 1 correct in understanding from your testimony that, in fact, you all had draft ventilation in there, and you had suitable garments? Yes. When do you think you first learned that PCBs could cause -- or there were allegations that PCBs might cause or contribute to skin problems for people? MR. MYERS: Object to the form. 1 have no idea. As you sit here today, have you heard that before? 1 mean, 1 just read it just now. But before that, had you ever heard that? MR. MYERS: Heard what? That PCBs, in the mind of some scientists, have the ability to cause skin problems Pages 77 - 80 HARTOLDMONO013678 1 2 3 A. 4 Q. 5 6 7 8 9 10 A. 11 Q. 12 13 A. 14 Q. 15 16 A. 17 Q. 18 A. 19 Q. 20 21 A. 22 23 Q. Page 81 for people? 1 MR. MYERS: Object to the form. 2 A. 1 have no idea when nor where. 3 Q. What about the liver problems? Have you 4 ever been informed that -- again, at least 5 some scientists believe that in some ways, 6 PCBs may have the ability to cause liver 7 problems for people? 8 A. MR. MYERS: Object to the form. 9 1 have read that. 10 And again, do you have any idea when or 11 Q. where? 12 The '70s. 13 Okay. Kidney problems? 14 MR. MYERS: Same objection. 15 A. 1 read that. 16 In the '70s? 17 Correct. 18 Q. Cancer? 19 MR. MYERS: Same objection. 20 And same answer. I've read that in the 21 '70s. 22 A. Thyroid problems? 23 Q. Page 83 head for biography, you head for science? Pretty much. Okay. Did you just happen to come across these articles that talked about PCB, you think, or was it maybe you thought, 1 think I'll try to find out something about these? It was the same interest that 1 went and looked up polyphenyl, parathion, jet fuel, gasoline. I'm sorry. Maybe I've missed something about your background. What caused you to be particularly interested in the toxicity of jet fuel? I've always been interested in it, in chemistry. 1 think 1 told you that when 1 started out. Okay. Did you ever have any occasion to personally observe the condition of the drainage ditches leading off from the plant? Yes. When would you have done that? 1 2 A. 3 Q. 4 5 A. 6 Q. 7 8 A. 9 Q. 10 11 A. 12 13 Q. 14 A. 15 16 17 Q. 18 19 20 A. 21 Q. 22 23 Page 82 MR. MYERS: Same objection. 1 A. 1 don't recall thyroid problems. 2 Q. Okay. And neurodevelopmental problems? 3 MR. MYERS: Same objection. 4 Same answer. 1 read that in the '70s. 5 A. And do you have any recollection of what 6 Q. you might have read it in? 7 A. Several different articles. 8 Q. And where do you think you would have come! 9 across these articles? 10 A. In the library, the plant. Yeah, the 11 Q. library and the plant. 12 A. In which library? 13 At Jacksonville State and Anniston or --1 14 Q. guess -- what's the name of our library? 15 The public library. 16 A. Was it your habit to go to these libraries 17 Q. and read, or did you make a special trip, 18 as you recall, to look into PCBs? 19 It was not special. It's something 1 do. 20 You told me earlier you have an interest 21 A. in chemistry. Are you one of these guys 22 Q. when you walk in the library, you don't 23 Page 84 As chief operator, operator. And let me be sure you're clear about what I'm asking. I'm talking beyond the fence line. Oh, beyond the fence line? Yes. No. Did you ever have occasion to examine or see Snow Creek? Yes. Tell me when that would have been, please. A couple of times after extremely heavy rainfalls. And can you give me decades or a decade when you would have been doing this? '80s and '90s. And what was it that -- were you deliberately going out to observe Snow Creek after a heavy rainfall, or was it just coincidental? No. 1 was going out to look at it. And was this as part of being a Monsanto employee? Pages 81 - 84 HARTOLDMONO013679 1 A. 2 Q. 3 4 A. 5 Q. 6 7 8 A. 9 Q. 10 11 12 13 14 A. 15 16 Q. 17 18 19 20 A. 21 22 23 Page 85 Yes. 1 And what is it that you were trying to 2 A. observe? 3 Q. To see if it would turn yellow. 4 A. And that would have been an indication to 5 Q. you that some of the PNP waste had gotten 6 out? 7 A. Right, uh-huh. 8 Q. And what was it about a heavy rainfall 9 A. that would make it more likely on that day 10 Q. than any other day that that might have 11 A. occurred? 12 Q. MR. MYERS: Object to the form. 13 The hydraulic load being more than what 14 A. the land would handle. 15 Q. Okay. And as with many municipal sewage 16 A. treatment plants, you all had to bypass 17 Q. when the storm water caused you to get 18 over faster? 19 A. No. It would just run off and run down to 20 Q. Snow Creek. Instead of running into our 21 sewers -- our sewer would be so full, it 22 A. would just run past the sewer. 23 Page 87 Creek? No. Have you ever fished in Choccolocco Creek? No. Do you fish? Let's start with an easy one. Oh, yes. Have you ever fished in Choccolocco? Yes, as a matter of fact. When do you think you did that? Late '60s, early '70s. Now, were you out there sport fishing, or were you picking up samples for Monsanto? Sport fishing. Would you eat what you catch? Sure. Would you eat fish caught out of Choccolocco Creek today? Sure. But you haven't caught fish down there in about thirty years? No. 1 haven't been fishing down there since my boys got old. 1 Q. 2 3 4 5 A. 6 7 Q. 8 9 A. 10 Q. 11 12 13 A. 14 15 Q. 16 17 18 A. 19 Q. 20 A. 21 Q. 22 A. 23 Q. Page 86 Where would it pick up the yellow PNP 1 Q. waste, if it was just running along the 2 ground? 3 A. MR. MYERS: Object to the form. 4 Q. If there was any on the ground, then it 5 could pick it up. 6 But you wouldn't have left any laying on 7 A. the ground, would you? 8 Q. Hopefully not. 9 Well, what made you think there was a 10 chance it was going to get out in the 11 creek and turn the creek yellow? 12 That's what we were doing, making sure it 13 didn't. 14 A. Okay. But what would ever give you the 15 Q. idea that it would? 16 MR. MYERS: Object to the form. 17 Potential. 18 Had you seen it yellow before? 19 A. Yeah. 20 Q. Okay. 21 Yes. Sorry about the yeah. 22 That's all right. What about Choccolocco 23 Page 88 Are you aware of the fish advisory that's been posted down there? Yes. So you just basically don't -- that wouldn't dissuade you from eating the fish? No. Is that the sort of approach that you'd used when you'd try to train people out there at the plant about how to comply with rules and regulations and health and safety guidelines? MR. MYERS: Object to the form. No. You would agree with me, would you not, that that kind of recommendation from the state agency should be complied with by workforce in a plant like Monsanto's? Yes. Do you know if you ever participated in a study of the mortality of workers at the Anniston plant in an effort to determine the death rates out there? Pages 85 - 88 HARTOLDMONO013680 1 2 A. 3 Q. 4 5 6 7 8 9 10 A. 11 Q. 12 13 14 15 16 17 A. 18 19 20 Q. 21 22 A. 23 Q. Page 89 MR. MYERS: Object to the form. 1 Would you repeat that one? 2 A. Yes, sir. To your knowledge, did you ever 3 Q. participate in -- either as a statistic or 4 maybe even gathering information, an 5 A. effort to assess the death rates, the 6 Q. mortality rates of the Anniston Monsanto 7 workers? 8 MR. MYERS: Same objection. 9 Okay. I'm just not sure. 10 That's fair. Did you ever hear about the 11 A. results of such a mortality study on 12 workers who worked in the Aroclor 13 Q. departments at the Krummrich plant in 14 Sauget, Illinois? 15 MR. MYERS: Object to the form. 16 A. 1 remember the study, but 1 don't recall 17 what was in it, the points they brought 18 out. 19 Okay. Have you ever been to the Sauget 20 plant? 21 Yes. 22 Was it in a time frame where if 1 wanted 23 Page 91 double digits, triple digits? 1 think it was less than a hundred. Less than a hundred. Okay. And why did you have that tested? Curiosity. Okay. And what sort of follow-up occurred; in other words, after the blood was drawn, what's the next thing that happened with respect to that sample? 1 mean, how did you find out the number? They gave me a sheet that had the number on it. Okay. And was that it? They just handed you the sheet, and that was the last time it was ever discussed? 1 can't recall what was on the sheet. There was some discussion that occurred when they - 1 don't remember who gave me the sheet. But when 1 was handed the sheet with my results on it, there was some discussion about it, and that's the last thing that happened. You know, 1 don't think 1 did anything with it. 1 2 3 4 5 A. 6 7 Q. 8 A. 9 Q. 10 11 A. 12 Q. 13 A. 14 Q. 15 16 A. 17 Q. 18 A. 19 Q. 20 21 22 A. 23 Q. Page 90 to talk to you about how they made PCBs 1 Q. versus how you all did and how they 2 disposed of waste versus how you all did, 3 are you going to know anything about that? 4 A. No. 1 was there at a seminar, so it was 5 Q. not a plant visit or anything like that. 6 And was it in the '90s? 7 Yeah, late '80s, early '90s. 8 Have you ever had your body tested for 9 PCBs? 10 A. Yes. 11 Q. When was that? 12 Mid '90s, 1 guess. 13 Okay. When a lot of other guys out there 14 A. at the plant did, as well? 15 Q. Right, correct. 16 What was your serum level? 17 A. 1 don't recall. 18 Q. And was that the only time, to your 19 knowledge, you've ever had your body 20 tested for PCB? 21 A. Yes. 22 Q. Do you recall if it was single digits, 23 Page 92 Were you present when there was a question and answer session with a group of the workers? Yes. Okay. I'd seen the transcript of that. 1 didn't see your name listed as one of the people who asked questions. Do you remember asking a question at that particular -No, 1 didn't ask a question. And what did your doctor - your personal doctor tell you about your PCB level when you talked to him or her about it? 1 don't think 1 talked to them about it. Okay. I'm assuming you have seen a doctor since the mid '90s? Oh, yeah. I'm going to try and figure out, if we can, what your blood level was. I've got a set of that data Okay. -- but they didn't give us everybody's names to protect their privacy. You also Pages 89 - 92 HARTOLDMONO013681 1 2 3 4 5 A. 6 Q. 7 8 A. 9 10 Q. 11 12 A. 13 Q. 14 A. 15 Q. 16 A. 17 18 Q. 19 20 21 22 23 Page 93 did a questionnaire. Do you recall maybe 1 being asked questions or maybe even 2 filling it out yourself, a little one-page 3 sheet? 4 No, 1 don't recall. 5 Okay. How old would you have been in June 6 of 1996? 7 A. Okay. I'm fifty-eight now. September is 8 my birth month. Fifty-two. 9 A. Okay. Let's see what we find in here. 10 Q. How tall are you? 11 A. Six one, six two. 12 Q. Maybe six one and a half? 13 Yeah. 14 A. Weigh about two fifty-eight? 15 Q. 1 did then. And I'm fast approaching that 16 again. 17 See if that looks like it might be you. 18 A. And 1 will tell you that the concentration 19 Q. reported for that worker, one oh oh two, 20 was a hundred and five. Now, that is 21 inconsistent with your recollection that 22 A. you thought it was under a hundred. But 23 Page 95 found that intriguing because of my sense that that was something that -- as you said, if your clothes got soaked, you were supposed to change right away. Let's start with something simple. Do you think that person is still alive today? Uh-huh (indicating yes). MR. MYERS: Is that a yes? Yes. I'm sorry. Does he still work at the plant? 1 don't think so. Do you think he lives within a hundred miles of Gadsden, Alabama? Yes. Well, let's not worry about it right now. 1 may call Larry and ask him to ask you to tell me who that person is. Okay. Let's see if we can find another one. I've got lots to choose from. We'll find another one. Okay. My weight in '96 was around two hundred pounds. 1 2 3 4 5 6 A. 7 8 Q. 9 10 A. 11 12 13 Q. 14 15 A. 16 Q. 17 A. 18 Q. 19 A. 20 Q. 21 22 23 Page 94 that's the first one 1 came to that kind 1 Q. of fits you in terms of the size and the 2 weight and the years that you were doing 3 it. And it says you were an operator. 4 A. You're a smoker. 5 Q. If that's our employee numbers, 1 don't 6 think that's mine. 7 No. It's a special number just for this 8 A. data set. 9 Q. The only thing that throws me off is that 10 1 worked in the Aroclor department from 11 '65 to '72, seven years -- 12 And it was really less than that, wasn't 13 it? 14 Yeah. 1 know who this sounds like. 15 Who does that sound like? 16 I'd prefer not to say. 17 Okay. 18 Can 1 do that? 19 Well, here's the only reason 1 say -- now, 20 he says he had his clothes soaked in it. 21 And that was one of my - there weren't 22 A. many where 1 made a special comment, but 1 23 Page 96 This is somebody six oh height; weighed a hundred and eighty-five; doesn't smoke, so -Uh-uh (indicating no). -- and 1 have a lot where we just didn't get a questionnaire. So height, seventy-three and a half inches? About six one. About six one and a half; weight, two ten. Quit smoking approximately two weeks ago. How long have you worked at Monsanto? Thirty-one years. 1 don't know. This says operator from '77 - that doesn't look like you to me. But you look at it, and you tell me. MR. MYERS: Do we have any idea what time the chlorine department shut down? MR. CUNNINGHAM: 1 want to say'67, but 1 don't profess to be sure about that. A lot of that fits, except for the years in Aroclor. Pages 93 - 96 HARTOLDMONO013682 1 Q. 2 3 A. 4 Q. 5 A. 6 Q. 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Page 97 Yeah. That one, ten forty, had a serum 1 A. level of eight. 2 (Witness shakes head negatively.) 3 Q. That's too low? 4 I'm pretty sure. 5 Well, let me just do this: Let me go 6 through -- there's a couple of these where 7 I'm kind of interested, this number one oh 8 A. oh six, this individual wrote under other 9 Q. information, his chloracne breaks out 10 quite frequently. Could you take a look 11 A. at that person in terms of that 12 Q. information there and see if you have a 13 A. feel for who that might be? 14 Q. MR. MYERS: Let me caution you here, 15 Mr. Byrd. The --1 don't think 16 you're required to disclose the 17 identity of any specific 18 individual; on the other hand, 19 you were asking questions earlier 20 of other witnesses, Charlie, were 21 you aware of anybody who had 22 chloracne at about that period of 23 Page 99 Maybe two. And without a doctor's report, I'm not -- what 1 call chloracne -- Believe me, 1 understand. And I'm writing it down, maybe had chloracne. Do you know if either of those individuals who you think maybe had that still work at the facility? No. Do you know if either of them are still alive? Yes. You think they both are? Yes, 1 think they're both still alive. Okay. I'm going to ask the question, and then your lawyer can instruct you not to answer. But 1 will ask you to tell me the names of those two individuals, please? MR. MYERS: Yeah, you can tell him that. Let me just make clear what the instruction is. He is not to identify in the current instance who patient ten zero six is. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Q. 19 20 A. 21 Q. 22 23 Page 98 time? And 1 think that's fair 1 game. But 1 don't think you're 2 required to identify the 3 individuals whose privacy has 4 been protected by giving a 5 A. numeric identifier. So you may 6 Q. want to ask him a different 7 A. question. 8 MR. CUNNINGHAM: You've instructed 9 him, 1 take it, not to answer 10 Q. the question? 11 MR. MYERS: I'm instructing him that 12 he is not -- if he knows who ten 13 A. zero six is, he's not to disclose 14 Q. that to you. 15 MR. CUNNINGHAM: Okay. Then 1 will 16 ask another question. 17 A. Do you know of anyone at the plant who had 18 Q. chloracne? 19 Yes. 20 A. Okay. Was it a single individual, or did 21 Q. you know more than one individual who had 22 chloracne? 23 A. Page 100 MR. CUNNINGHAM: Fair enough. MR. MYERS: But he can tell you who he believes those two people to be. Bill Hughes. Okay. And I'm trying to think of his name. Can 1 come back, if 1 think of his name, and tell you? Sure, absolutely. What makes you think that Bill Hughes had chloracne at some point in history? Did you see it? Just observation. Okay. Do you know if Mr. Hughes ever worked in the Aroclor or Therminol departments there at the plant? Yes. What job did he have that would have exposed him to Aroclor, as best you know? He was an operator. Okay. And he's retired but still alive, as far as you know? As far as 1 know. Pages 97-100 HARTOLDMONO013683 1 Q. 2 3 A. 4 Q. 5 6 7 A. 8 Q. 9 10 A. 11 12 Q. 13 A. 14 Q. 15 16 17 A. 18 19 Q. 20 A. 21 Q. 22 23 Page 101 And there may be a second person, but that name's not coming to you right now? Right. There's another person identified on here, and again, we won't try to figure out who -- do you know how old Mr. Hughes is? Approximation, fifty-eight. How big a person is he? MR. MYERS: You can tell him that. Well, that's going to match up to what's on the paper. It might not. Okay. He's -1 found one that matched you real well. And 1 can't say it's you, so it really doesn't lock it in. Okay. 1 don't want one of these guys coming and beating me up. 1 don't want that either. Bill is about six two to six three. The next one that 1 was curious about was a fellow who had an abnormal liver test about five years ago, which, at this point 1 Q. 2 3 4 5 6 A. 7 8 Q. 9 A. 10 Q. 11 12 13 A. 14 Q. 15 16 A. 17 Q. 18 A. 19 20 21 Q. 22 23 Page 103 Okay. And you say "the opportunity." Did somebody say, hey, get this stuff out of here, and you said, I'll take it? Or you just didn't have a task; you just wandered up to look? No. I'm going up to the dump; do you want to ride with me? Okay. And what were you taking up there? A half-track. Okay. And was this a routine thing? Was this half-track used routinely to haul stuff up there? No. Why were you using the half-track on that particular occasion? We were hiding it. You were hiding a half-track? We had a corporate inspection coming in, so we were hiding it from the inspection team. Now, when 1 think of a half-track, I'm thinking of a three-and-a-half-ton military vehicle of World War II with 1 2 3 4 A. 5 Q. 6 7 8 9 A. 10 11 Q. 12 13 A. 14 Q. 15 A. 16 Q. 17 A. 18 Q. 19 20 21 22 23 A. Page 102 in time, would have been about 1991. Do 1 you know of a worker at the plant who had 2 an abnormal liver test in the early '90s? 3 Not that 1 recall. 4 A. There's another person here who put down 5 Q. that he carried melted PCB to the dump. 6 Do you know who at the plant carried 7 melted PCB to the dump? 8 A. Anyone in the shipping department, 1 9 Q. guess. 10 A. Okay. Did you ever have an occasion to go 11 Q. up and look at the dumps, the landfills? 12 Twice. 13 A. What was the reason for that? 14 Q. Curiosity. 15 Okay. When was that? 16 A. Probably '68 and late '70s. 17 Q. All right. Let me take those one at a 18 A. time. The one in '68, was there any 19 particular event that sparked your 20 Q. curiosity, or was it just a general 21 curiosity -- 22 A. 1 had the opportunity to go up there. 23 Q. Page 104 regular tires on the front axle and treads on the back. And you had one of those sitting around there? Yes. Was it just something somebody was working on in their spare time at the plant, or did you use it at the plant? We used it at the plant. And what did you use it for? To move railcars. Okay. It was like your -- what they call a yard engine? Correct. And why would you care if corporate saw that? It wasn't very pretty looking. What color was it? 1 don't know if 1 can describe the green color that it was. Okay. So you were just getting it out of sight because it was unsightly? Right. And you hid it somewhere up on the hill? Pages 101 -104 HARTOLDMONO013684 1 A. 2 Q. 3 4 5 A. 6 Q. 7 8 9 A. 10 Q. 11 A. 12 Q. 13 14 A. 15 Q. 16 A. 17 Q. 18 19 A. 20 21 Q. 22 23 A. Page 105 Yeah. We took it up to the dump. 1 Q. May 1 safely assume from that that when 2 the folks came down from St. Louis, they 3 didn't bother to go up on the hill? 4 A. 1 don't know. 5 Q. Okay. And what did you see? What do you 6 remember when you went up there on the 7 hill? What did you see of the dump? 8 A. A big pit. 9 A single large pit? 10 Where we went, yeah, that was all. 11 Q. Okay. Did you see anything in the bottom 12 A. of the pit? 13 Q. I'm not sure if 1 looked in the pit. 14 A. Do you recall if this was night or day? 15 Q. It was daytime. 16 A. Daytime. Do you remember ponded water 17 Q. maybe? 18 No. Like 1 said, 1 don't think 1 looked 19 in the pit. 20 Okay. The second occasion in the late 21 '70s, why were you up on the landfill? 22 A. Again, 1 had asked the question of where 23 Q. Page 107 What 1 have read suggests they just kind of backed up to the edge and pushed it off? Correct. Did you have an opportunity to see -again, was there just a large hole up there? This particular place we stopped at, it was, again, a pit, and that was it, just a pit. What did you see inside the pit? Drums. Drums? Okay. Fiber drums. Fiber drums. Okay. Several deep? Yes. It was more than one layer. Okay. And you could --1 presume you could put those things in there like artillery shells in nice, neat rows stacked on top of each other, or you could just kind of push them off the back or -The just pushed them off the back. And let nature sort it out from there? 1 2 3 4 5 6 Q. 7 8 9 A. 10 11 12 Q. 13 14 A. 15 Q. 16 17 18 A. 19 Q. 20 21 22 A. 23 Page 106 they took the drums and what they did with 1 A. them, and one of the employees was taking 2 Q. a truckload of drums up. And when 1 say 3 "drums," I'm talking about the fiber 4 drums, cardboard drums. 5 A. And, if you would, when you say you had 6 Q. asked, what were you doing? What was your 7 job at that particular point in time? 8 I'm trying to remember if 1 was the chief 9 of PNP or an operator - chief of PNP 10 or --1 was somewhere in the west plant. 11 So it sounds like this, again, was 12 curiosity? 13 A. It was. It was curiosity. 14 It was not like you had to know the answer 15 Q. to that because you had been able to do 16 your job for years without knowing that? 17 Oh, yeah. 18 Okay. What, if anything, do you remember 19 A. about observing that operation on that 20 Q. occasion? 21 We needed a better way of getting drums 22 off the truck. 23 Page 108 Yes. What about that water? On that occasion, do you have any recollection of seeing any ponded water? No, no water. Okay. Other than the time that you worked on the sampler that we talked about earlier, do you recall any involvement or any role that you had in collecting, analyzing, or interpreting PCB samples, whether it be of soil, water, air, or animals? Other than just routine sampling that 1 would do to test to see? Product or -- it's clear to me that as an operator, you daily, on multiple occasions during the day, would draw a sample of PCB product, Aroclor, for the lab to analyze? Correct. And 1 don't need to bother you with knowing about all of that. I'm talking about samples that were taken to look for the presence of PCB, again, in water, Pages 105-108 HARTOLDMONO013685 1 2 A. 3 Q. 4 5 6 7 8 A. 9 10 Q. 11 12 13 A. 14 15 Q. 16 17 A. 18 Q. 19 20 21 22 A. 23 Q. Page 109 soil, air, or animals in -- 1 No. 2 A. Okay. And 1 may have inferred that the 3 Q. sampler you worked on was - that they 4 A. would look for PCB, but you don't know 5 Q. what that was necessarily analyzed for, 6 right? 7 A. Right. The sampler in waste treatment? 8 Q. No. 9 A. Okay. Let me ask you if you know about 10 Q. samples that you picked up and maybe just 11 don't know what they were looking for? 12 A. The samples -- no, I'm not sure what they 13 Q. were looking for. 14 And you told us about the air samples that 15 you collected in-house? 16 Right. 17 A. And you mentioned a few of the parameters 18 that you think that was checked for. As 19 Q. far as you know, you never picked up 20 samples like that to be analyzed for PCB? 21 No. 22 This is the last area of questioning, and 23 Page 111 it? Correct. Same source of information, the media? Yes. Have you heard about the EPA Superfund department coming to town? Yes. And how did you learn about that? The media. Did any of these four events surprise you when you heard about it? Yes. Let me take them one at a time. The fact it was found in a lot of yards, did that surprise you? MR. MYERS: Object to the form. Let me ask you what you mean by "surprise." There's a lot of surprises. Yeah. 1 don't know in what format you first heard it. 1 assume you were reading a newspaper, let's say, the Anniston Star, and you see an article, and it says: "Neighbors sue Monsanto, allege that 1 2 3 4 5 6 7 A. 8 Q. 9 A. 10 Q. 11 12 13 14 A. 15 Q. 16 A. 17 18 19 Q. 20 21 A. 22 Q. 23 Page 110 we're done. 1 Have you heard about allegations 2 that PCBs have been found in a lot of 3 yards in the neighborhoods around the 4 A. plant? 5 Q. MR. MYERS: Object to the form. 6 Yes. 7 Okay. And how did you hear about that? 8 The media. 9 A. Have you heard allegations that PCBs have 10 Q. been found in the bodies of a number of 11 people who live out there around the 12 plant? 13 Yes. 14 Is that also through media reports? 15 Media and also -- when 1 say "media," I'm 16 A. talking about not only outside media; I'm 17 Q. talking about through Monsanto media. 18 Right. The Bama Briefs that you 19 mentioned? 20 Right. 21 And 1 think 1 asked you about the fish 22 A. advisory, and you told me you knew about 23 Q. Page 112 there's PCB in their yards." Did that happen someday? Did you read something like that someday? 1 did read something like that. And all I'm wondering is: When you heard that, did you say, 1 could have saved them the trouble; 1 could have told them it was there? No. 1 didn't expect anything like that. Didn't expect it? Okay. That's fair. Have you heard that when Monsanto's gone out and looked and when the EPA has gone out to look, they have found it in residential areas around the plant? MR. MYERS: Object to the form. Again, 1 didn't expect it. Let me move to it being found in people, blood work like you -- same lab, as a matter of fact, for that matter. Did that surprise you? MR. MYERS: Object to the form. Yes. When you heard about the fish advisory, Pages 109-112 HARTOLDMONO013686 1 2 3 4 5 A. 6 7 8 9 10 11 12 Q. 13 14 15 16 17 A. 18 Q. 19 20 A. 21 Q. 22 23 Page 113 that the State had concluded that the fish 1 A. had PCBs in them and people shouldn't eat 2 Q. them, did that come as a surprise to you? 3 MR. MYERS: Object to the form. 4 A. No, because that occurred after the other. 5 The thing that surprised me or was 6 Q. unexpected was because of --1 didn't 7 A. know. You know, it amazed me that it had 8 gotten out - and 1 don't guess amazed is 9 the right word, but it was just 10 unexpected. 11 Unexpected. Okay. And when the EPA 12 showed up with the Superfund people - 13 now, a guy earlier said, what's Superfund, 14 but I'm guessing you know what Superfund 15 is? 16 Right. 17 Did that surprise you when they came to 18 town? 19 Personally, yes. 20 Because 1 assume while you were there 21 working, you felt that y'all had things 22 under good control? 23 Page 115 Concerned. And lastly, when the Superfund came to town? Yeah, 1 was very much concerned about that. For who? The people and the company. MR. CUNNINGHAM: That's all 1 have. Thank you. (AND FURTHER DEPONENT SAITH NOT.) 1 A. 2 Q. 3 4 5 6 7 8 9 10 11 12 13 14 15 A. 16 Q. 17 A. 18 Q. 19 20 21 22 A. 23 Q. Page 114 Page 116 Yes, very much so. 1 1 do hereby certify that the witness whose Last set of questions. With respect to these four different events, 1 want to know if they caused you any concern, if you're worried about it. And 1 don't mean in the sense that somehow you personally had something to worry about, but worried for the company, worried for the people. Okay? You tell me if any or all apply. 2 attached deposition was taken before me was by me 3 first duly cautioned and sworn to tell nothing but 4 the truth in the cause aforesaid; that the 5 testimony contained herein was by me reduced to 6 writing in the presence of said witnesses by means 7 of stenography and afterwards transcribed by means 8 of computer aided transcription. The foregoing is 9 a true and accurate transcript of the whole of the 10 testimony given by said witness, as aforesaid. 11 Ido further certify that 1 am not When you heard that it was in 12 connected by blood or marriage with any of the residential neighborhoods in the soil, did 13 parties or their attorneys or agents and that that cause any concern in your mind? 14 lam not an employee of any of them, nor MR. MYERS: Object to the form. Yes. For who? The people and the company. Fair enough. What about when you heard that it was in people's bodies? Same answer? 15 interested in the matter of controversy. 16 IN WITNESS WHEREOF, 1 have hereunto 17 set my hand and affixed my notarial seal at 18 Gadsden, Alabama, County of Etowah, this 12th 19 day of January, 2002. 20 21 MR. MYERS: Object to the form. Yes. 22 Misty Perry Sanders Notary Public, Alabama-at-Large The fish advisory? Less so? 23 My Commission Expires: 11-01-2003 Pages 113-116 HARTOLDMONO013687 [& - answers] & & 1:1 2:7__________ 1 1000 1:1 11:00 1:1 3:8 11-01-2003 116:23 116 2:13 125 25:12 12th 116:18 1355 2:8 1961 13:23 16:17,18 1965 14:16 78:12 1984 15:13 1985 15:13 1991 102:1 1996 28:7 93:7 1998 14:16 72:12 2 2001-832 1:1 2002 1:1 3:84:2 116:19 22nd 7:14,16 8:22 3 3 2:12 30309 2:8 35901-0755 1:1 36265 7:9______________ 4 4 2:17 4:2 40207-1294 2:5 Transcript Word Index 4th 1:1 3:8_________________ 5 50s 23:7___________________ 6 6010 2:4 60s 30:5,10 48:3 79:17 87:11 65 33:23 34:9 94:12 67 96:19 68 102:17,19______________ 7 70s 48:4,12 81:13,17,22 82:5 87:11 102:17 105:22 72 94:12 750 2:8 755 1:1 77 96:13__________________ 8 80s 8:12 15:15,16 27:12 32:4 84:16 90:8_____________ 9 90s 14:12 84:16 90:7,8,13 92:16 102:3 96 70:5,17 74:10 95:22 98 70:5 74:10 a a.m. 1:1 3:8 abernathy 1:1 ability 80:23 81:7 able 16:7 37:21 106:16 abnormal 101:22 102:3 absolutely 100:10 accounting agreed 37:9 3:2,9,15,22 accurate ahead 116:9 14:1428:1729:331:9 achieve aided 21:15 116:8 acid air 42:10 56:8 72:20 73:8,9 74:5,15 acidifier 76:3 108:11 109:1,15 46:12 al acne 1:1,1 79:7 alabama acquaintances 1:1,1,1,1 3:7,7 4:1 7:9 8:11 33:3 95:13 116:18,22 action alcoholic 1:1 24:6 add alive 30:2,6,7 36:11 40:14 41:3 95:6 99:10,13 100:21 added allegations 51:4 74:11 80:14 110:2,10 adding allege 40:19 111:23 additions alien 29:22 10:3 address allowed 7:7,15 8:23 54:23 65:8 administered amazed 13:7 113:8,9 administering ambient 13:3 74:7 admit amount 62:22 35:4 74:4 adopted analyze 10:5 108:18 adults analyzed 10:17 109:6,21 advise analyzing 33:11 108:10 advisory animals 88:1 110:23 112:23 114:23 79:1 108:12 109:1 affixed anniston 116:17 1:1 3:7 4:1 7:14,17,18 23:2 aforesaid 23:7,15 61:21 65:13 82:14 116:4,10 88:22 89:7 111:21 afraid annual 45:19 28:14 29:23 31:2,13 agency answer 88:17 5:10,15,1828:1729:19 agent 41:14 54:15 81:21 82:5 23:1,9 92:2 98:10 99:16 106:15 agents 114:20 23:14 116:13 answered ago 38:11,15 32:3 40:23 96:10 101:23 answers agree 5:2 12:4 88:15 HARTOLDMONO013688 [anybody - brought] anybody 39:6 97:22 anymore 38:17 apologize 24:1 appearance 18:7 application 20:17 apply 114:10 approach 88:8 approaching 93:16 appropriate 69:14 approximately 7:12 8:1 50:3 96:10 approximation 101:7 aprs 30:8 area 57:10 69:12 77:7 109:23 areas 112:14 arkansas 24:16 army 16:22 19:21 21:16 22:21 61:7 62:9 aroclor 38:21 39:8,10,10,12 40:2 40:14 41:21 47:19 48:1 54:5,9,23 55:6 58:10,16 75:2 78:23 79:2 89:13 94:11 96:23 100:15,19 108:18 aroclors 19:9 79:6 80:5 article 33:19 111:22 articles 82:8,10 83:4 artillery 107:19 aside 16:15 asked 38:14 92:7 93:2 105:23 106:7 110:22 asking 55:13 84:3 92:8 97:20 aspect balance 31:23 35:4 assess bama 89:6 33:8,10 110:19 assign based 3:19 54:17,22 55:3 6:6 assigned basic 26:21 21:21,22 30:1 assist basically 26:22 25:23 40:8 59:12 65:23 associate 88:4 12:19 15:11 basins associated 44:14 51:6 basis assume 13:16 12:3 19:14 32:22 36:2 66:3 batch 69:5 70:2 75:19 77:6 105:2 41:11,19 111:20 113:21 beating assuming 101:18 13:19 46:3 60:13 68:3 believe 76:13 92:15 47:2 63:13 81:6 99:3 assumption believes 37:17 100:3 atlanta belong 2:8 64:11 attached belt 2:21 116:2 18:4,5 46:11 attorney benchmark 2:4 52:17 attorneys benefits 116:13 25:5 authorities best 69:9 27:23 49:4 100:19 authority bet 69:6 20:5 62:16 automatic better 48:8,10,20,23 19:14 29:18 62:7 106:22 available betting 69:4 6:19 avenue beverages 1:1 24:6 aware beyond 29:9 50:4 65:13 70:23 74:9 41:4 84:3,5 74:19 88:1 97:22 bias axle 10:13 104:1 biased b back 18:4 27:13 30:9 73:15,17 100:8 104:2 107:21,22 backed 1072 background 8312 bad 10:8 big 50:1 101:8 105:9 bill 100:5,11 101:20 biography 83:1 biological 20:3,11 44:14 46:22 5:9,20 biphenyl 40:3,10 41:9,23 birth 93:9 bit 8:4 45:12 60:12 black 18:18 19:2 36:18 blood 10:1829:11,1230:1932:14 70:21 91:7 92:19 112:18 116:12 bodies 110:11 114:19 bodily 79:5 80:4 body 75:6 90:9,20 book 64:14 born 24:16 bother 105:4 108:20 bottled 77:20,22 bottom 21:2 42:12 105:12 boulevard 2:4 box 36:18 37:4 boys 87:23 breaks 97:10 breathe 28:19 75:11 brick 56:12 briefs 33:8,11 110:19 brigade 62:12,14 brine 34:20,22 35:12 36:1,2 bring 26:15 37:2 brink 51:14 broad 69:3 broom 17:22,23 brought 78:5 89:18 HARTOLDMONO013689 [brown - coming] brown 18:17 65:22 brownish 44:19 brownsboro 2:4 building 39:14 55:19,22 bulb 48:16 burning 48:17 bypass 85:17 byrd 1:1,1 2:16 3:5 4:4,15 7:5 9:15 23:17 63:14 97:16 c cabinet 48:17 cadmium 74:2 calendar 52:19 calhoun 1:1 calibrate 73:14,15 call 6:19 17:11 31:1839:13 44:18 51:8 55:15 56:19 66:1 69:4 76:2 95:16 99:2 104:11 called 11:1645:15 cancer 24:4 81:19 capacity 27:22 60:1761:18 captured 42:9 cardboard 106:5 cardiologist 31:20,21,23 care 55:10 104:14 careful 75:19 carried 102:6,7 case 6:18,19 10:9,9 11:16 59:21 cases 6:16 cast 17:18,19 catch 75:8 87:15 caught 87:17,20 cause 80:13,14,23 81:7 114:13 116:4 caused 58:4 83:12 85:18 114:4 caustics 34:21 caution 97:15 cautioned 116:3 cell 34:18 center 7:20 26:19 50:22 51:1,7 certain 9:6 13:1271:1976:16 certainly 5:19 certificate 2:13 15:8 certify 116:1,11 chance 5:15,1786:11 change 43:5 47:8 49:5 77:16 95:4 changed 53:20 changeover 41:14 changes 29:7 changing 29:21 77:11 charge 13:2 53:10 Charles 2:3 Charlie 4:15 97:21 check 30:20 checked 9:21 20:13 109:19 checking 22:10 73:20 chemical 20:3,11 21:9,11 25:12 chemicals classified 61:1365:8 17:9 chemistry classroom 22:22 37:19 82:22 83:16 22:13 chief clean 44:22 45:1,23 46:17 52:11 58:5 52:22 53:1,3,6,11,15,16,18 cleaned 53:1954:1,1260:8,1861:2 17:10 43:21 56:15 57:17,19 84:1 106:9,10 57:23 children cleaning 9:23 17:7,22,23 chloracne cleanup 97:10,23 98:19,23 99:2,4 17:3,20 100:11 clear chloride 84:2 99:19 108:15 42:6 clerk chlorinated 21:13 41:23 clients chlorinator 10:8 41:7,8 42:3,12,18 close chlorinators 8:19,21 79:7 40:23 41:16,17 closed chlorine 58:23 34:8,15,17,21 37:12 38:10 closer 38:1640:3,1041:1096:17 9:4 choccolocco clothes 86:23 87:3,8,18 77:11,12,16 94:21 95:3 choice clothing 24:10 59:20 20:13 cholesterol clue 32:7 6:20 cholinesterase clueless 30:21 13:10 choose coaleser 95:20 51:14 chose coincidental 22:15 84:20 Christmas cold 12:11 48:16 cigarettes collected 24:11 49:18 56:1 109:16 Cincinnati collecting 26:19 27:2 56:10 108:9 circuit collection 1:1,1 55:15,16 56:1 57:9 city college 4:1 12:20 13:5 14:2,6 62:10 civil color 1:1 18:9,15 104:17,19 dark colored 10:3 18:10 class columns 21:17 43:19 classically coming 56:5 36:20 37:4 40:3 42:2,12 51:22 57:5 64:5 75:13 HARTOLDMONO013690 [coming - deep] coming (cont.) concluded conversation cross 101:2,18 103:18 111:6 113:1 11:20 45:15 48:15 commencing concrete conveyor Cunningham 1:1 3:8 56:11 18:3,5 2:3,17 4:10,14,15 7:2 50:8 comment condition cooling 57:19 67:3 96:19 98:9,16 94:23 83:19 40:7 100:1 115:8 commission conduit corporate curiosity 116:23 47:16 73:4,4 103:18 104:14 91:5 102:15,21,22 106:13 commissioner conferred correct 106:14 1:1 3:6,23 12:22 15:5 6:4,22 7:22 8:14 9:14 11:1 curious committee confident 16:1 19:1320:7,1921:4 45:8 101:21 26:13,16 54:3 22:7 26:2,7 27:9,20 28:9,21 current committeeman connected 29:10 30:6 34:6 35:1 38:19 99:21 25:15 116:12 38:22 40:10 41:6 42:7 currently communicate conscious 44:15 46:23 60:15 61:10,16 25:4 69:11 71:21,21 65:4,11 66:15 67:15,20 cut community consider 68:7 69:8,10 70:3,7 72:17 5:11 13:4 72:2,13 74:12 55:12 70:10 75:21 77:2 80:7 81:18 cv company considered 90:16 104:13 107:4 108:19 1:1 1:1 76:2,14 79:18 114:8,17 55:13 70:9 115:7 consist comparable 61:18 37:5 consistent 111:2 correctly 25:23 33:23 46:21 72:1 correspondence daily 10816 d competent 16:3 complete 5:15,18 completely 21:3 completeness 20:14 compliance 3:12 72:3 complied 76:19 88:17 comply 88:10 43:13 consolidated 1:1 Constance 9:18 consume 24:6 consumption 37:15 contact 66:22 79:6 80:4 contacted 65:15 contained 14:23 15:1 67:22 18:10,12,13,15 cost 37:9 counsel 3:4,17,18 county data 92 20 94 9 database 7318 date 1:1,1 8:8,10,13,15 10:15,22 7019 116:18 couple dates 3411 5:6 28:8 38:13 43:9 45:4,7 46:1 49:21 78:1,11 84:12 david 10-4 97:7 course day 18:11 11 48:15 61:17 77:18 13:2 14:2,18 15:2,2,22 27:7 00 CiJ < p,, o cn ! o 00 1 component 72:19 compound 78:17 computer 116:8 conceivable 56:23 57:2 concentration 93:19 concept 45:14 concern 114:5,13 concerned 76:14 115:1,4 conclude 68:16 116:5 29:15 73:3 contaminated courses 19:8 16:4 68:12 contamination court 33:14 35:19 55:1 1:1,1 3:134:8 continually coverage 49:23 20:14 continue coveralls 12:20 76:5 continuous covered 36:4 41:10,18 49:16,20 21:1276:10 contribute created 80:15 71:14 control creek 50:17,21 51:1,2,4,7,22 80:1 84:9,19 85:21 86:12,12 113:23 87:1,3,18 controversy crew 116:15 55:8 11619 daytime 10516 17 deal 67:9,16 69:14,17 dealing 51:13 54:13 dealt 50:16 68:3 death 88 23 89 6 decade 57:15 79:15 84:14 decades 34:14 84:14 decide 6313 deep 107:15 HARTOLDMONO013691 [defendants - etowah] defendants dirt drawn elected 1:1 2:6 18:16 59:1 91:8 25:20 degree dirty drew electrical 12:19,22 13:3,9 15:5,12 18:8,9,13,14,16,17,18,21 49:12,13 35:3 49:7 deletions disaster drops electrician 29:22 14:1068:1,2 49:21 47:4,9,11 48:5,9 49:8 50:16 deliberately discharge drum 52:10,22 84:18 21:18 64:21 59:23 electricity department discharged drums 35:5 37:13 13:1,6 20:12 34:5,7,15,17 65:9 55:9 58:14 59:21 60:3 electrodes 35:16 38:6,17 39:1,7,8,9,11 disclose 106:1,3,4,5,5,22 107:12,13 34:22 39:12 43:18 46:4,6 47:12 97:17 98:14 107:14,15 electrolysis 48:2 51:12 53:12,15 64:17 discussed duly 34:20 65:18,20 71:6,8,9 75:4,7 91:15 4:5 116:3 elevated 94:11 96:17 102:9 111:6 discussion dump 80:2 departmental 91:17,21 102:6,8 103:6 105:1,8 elicit 53:17 disposed dumps 29:7 departments 90:3 54:11 102:12 elimination 13:12 69:7 89:14 100:16 depend 18:10 depending 41:16 deponent 115:11 deposed 4:22 6:14,17 11:7 deposition dissuade 88:5 ditches 83:20 dividing 57:13 doctor 32:1992:11,12,15 doctors 29:8 e parlipr 82:21 97:20 108:8 113:14 early 48:4,12 87:11 90:8 102:3 6BSt 7:14,16 8:22 57:10,12,13 easy 7:3 25:1 87:5 64:21 emanating 63:22 72:10 emergency 14:10 15:22 68:1,2 employee 28:4 84:23 94:6 116:14 employees 106:2 encountered 1:1,1 3:4,10,11,20 6:8 116:2 depositions 3:14 describe 55:14 104:18 designation 19:23 53:20 designed 29:6 71:10 doctor's 87:15,17 113:2 99:1 eating document 885 48:12 78:23 documents 11:13 doing edge 1072 edison 14 6 68 13 17:1930:5,941:5,1247:19 education 49:3 53:5 63:15 73:2 84:15 86:13 94:3 106:7 12:18 16:6 62:11 66:17 5:8 6:17 engine 104:12 enter 73:17 entire 27:15 29:19 environmental 65:18,20 67:7 69:9 epa detention 74:17 determine double 91:1 doubt effect 312 111:5 112:12 113:12 equate 54:1 88:22 66:13 developing dozen 23:8 61:19 33:6,7 different dozens 6:16 26:15 82:8 98:7 114:3 33:6 difficult draft 8:5 29:17 79:23 80:9 digits drainage 90:23 91:1,1 83:20 diligent drains 76:14,17 56:5 diploma draw 13:20 36:18 108:17 directly drawing 54:14 49:21 686 pffprtc 79 5 80 6 effort 74:6 88:22 89:6 eight 93 8 15 97 2 1017 eighty 96:2 either 5:10,16 48:1 89:4 99:5,9 101 '19 ekg 31:16 equipment 43:20 51:5 73:1 75:23 76:1 eruption 79:7 esq 2:3,7 essentially 20:20 22:13 34:19 44:4 46:13 56:21 et 1:1,1 etowah 1:1 8:7,10,15 10:15,22 116:18 HARTOLDMONO013692 [event - forth] event 102:20 events 111:10 114:4 eventually 36:8 everybody 70:10,15 everybody's 92:22 evidence 3:21 evolved 79:3 80:1 exact 70:19 exactly 51:10 52:5 exam 29:23 examination 4:13 examine 84:8 examined 4:6 example 35:19 55:5 exams 15:3 excess 21:12 exclusively 61:20 exhibits 2:20,21 existed 47:21 existence 43:2 expanding 48:1 expansion 51:8 expect 112:9,10,16 experimental 79:1 expert 7:18 expertise 66:1 expires 116:23 explain 26:17 48:10 exposed felt fit 100:19 113:22 28:23 29:2 30:7 exposure fence fite 75:1,18 79:2 67:10,14,18 68:22 84:3,5 1:1 extensive fiber fits 80:4 106:4 107:14,15 94:2 96:22 extent fiddle five 35:17 42:16 48:7 4:19 27:23 50:3 93:21 96:2 extremely field 101:23 84:12 1:1 61:5 62:10,11 fix exwife fifteen 49:8 10:7 24:13 flecks exwife's fifty 18:19 10:5 93:8,9,15 101:7 flow eye figure 35:21 49:23 29:4_____________________ 18:20 36:17 52:18 92:18 flowing f 101:5 35:5 face file fluid 76:8,9 facilities 28:3 60:20 66:4 filing 39:17 fluids 77:11 facility 3:23 fill 39:21 folks 23:15 27:2 31:7 33:4 50:5 50:12 54:6 56:4 65:5 66:20 29:5 filling 68:11 99:7 fact 31:22 58:13 80:8 87:9 111:13 112:19 facts 23:4 93:3 filter 46:11 73:9 financial 25:5 26:1 find factual 16:2 83:6 91:10 93:10 4:20 10:14,19,19 55:3 66:21 105:3 follow 63:17 73:4 91:6 followed 64:15 following 43:12 follows 4:17 faculty 16:2 fair 95:19,20 fine 7:16 10:12 12:8 52:7 finished 4:6 force 3:12 foregoing 30:4 37:1,15,20 89:11 98:1 5:11 40:21 43:21 44:1 100:1 112:10 114:18 familiar 64:20,23 far 6:10,12 9:7 59:11 100:22 72:15 fire 12:23 13:7,9,11 15:22 62:12,14 69:6 firearm 116:8 foreman 53:22 forget 19:23 form 100:23 109:20 fast 93:16 faster 85:19 13:14 fired 19:15 first 4:5 13:8 16:20 30:2,12 34:2 3:18 28:16 31:8 33:16 55:2 64:9 67:11 69:2,16 74:13 78:13 79:7,12 80:16 81:2,9 85:13 86:4,17 88:13 89:1 89:16 110:6 111:16 112:15 father 24:20 federal 63:21 feed 41:9,10,11 50:11 60:10 75:18 80:12 94:1 111:20 116:3 fish 87:5,17,20 88:1,6 110:22 112:23 113:1 114:23 fished 112:21 113:4 114:14,21 format 111:19 forms 29:4 71:22 fort feel 34:12 97:14 87:3,8 fishing 20:6 21:23 22:3 23:5 forth fellow 87:12,14,22 1:1 30:18 101:22 HARTOLDMONO013693 [forty - helms] forty gas graduated happened 97:1 42:6 16:18 42:23 48:2,4 57:16 58:4 found gases gravity 70:23 75:8,11 91:9,22 63:1964:3 95:1 101:14 20:18 40:14 happens 110:3,11 111:14 112:13,17 gasoline great 67:17 foundry 83:10 6:8 22:1 happy 17:1,2,5,12,14 19:11,16 gathering green 19:16 fountain 89:5 104:18 haul 78:7 general grew 103:11 four 17:9 102:21 24:17 hazard 9:2 16:1925:19 111:10 generally ground 61:13 114:3 16:3 57:8 59:4 86:3,5,8 hazardous fourteen generated grounds 26:23 27:18 63:20,21,22 24:13 35:7 44:6 46:20 3:19 67:23 68:10 fourth generically group hdl 21:17 40:2 92:2 32:9 fowler geographically guess head 13:23 55:17 8:23 18:23 26:9 35:2 39:13 5:4 76:10 83:1,1 97:3 frame geography 43:23 44:18 51:7 53:21 headache 14:13 15:14 54:4 74:9 7:18 55:12 82:15 90:13 102:10 70:12 89:23 georgia 113:9 headaches fran 2:8 guessing 71:13,15 63:14 germany 17:4 49:7 63:2 69:23 headquarters francis 21:7,8 113:15 27:4 1:1,1 2:163:44:4 7:5 getting guidance health frequently 11:7 14:1 43:10 104:20 32:20 23:17 25:9 26:10,14 27:18 31:2 97:11 106:22 guide 29:7 31:12 61:14 63:5 friends give 73:21 64:16 67:6 70:1,14,18 33:2 5:18 37:14 55:5 84:14 guideline 71:21 72:16,18 76:15,17 front 86:15 92:22 64:13 88:11 104:1 given guidelines healthy fuel 31:21 42:4 116:10 73:3 88:12 70:1671:11 83:9,14 full giving 5:9 98:5 guy 13:8 29:18 30:12 60:21 hear 23:5 89:11 110:8 3:12 7:4 85:22 glencoe 113:14 heard fumes 8:11 guys 23:11 51:16,18 53:23 80:18 75:11,13 gloves 45:14 46:17 66:4 82:22 80:20,21 110:2,10 111:5,11 function 76:3 90:14 101:17 111:20 112:5,11,23 114:11 26:20 28:18 30:9,16 furnished 76:2 further 115:11 116:11 g gadsden 1:1 13:4,7,13 14:3 15:12 95:13 116:18 gallons 50:3 game 98:2 gap 16:19 garments 80:3,10 go h 5:11 11:9 14:22 19:11 22:1 28:16 29:3 31:9 35:21 36:8 habit 5:9,20 82:17 40:22 55:8 58:18 61:4 63:6 63:12 64:18 73:5,6,21 77:15,20 82:17 97:6 102:11 102:23 105:4 going half 93:13 96:7,9 103:9,11,14 103:17,21,22 hand 97:19 116:17 5:6 8:4,9,23 12:3,21 15:17 handbasket 20:5 33:12 41:21 59:22 60:11 61:1 66:3 67:9 84:18 68:4 handed 84:21 86:11 90:4 92:18 99:14 101:10 103:6 good 91:13,19 handful 33:6 5:6 16:9 20:22 23:18,23 41:14 79:18 113:23 handle 85:15 gotten happen 66:19,21 85:6 113:9 28:6 32:3 83:3 112:2 114:18 hearing 29:4 heartbeat 31:1932:1 heat 38:20 39:4,17 40:8 heavy 84:12,19 85:9 heck 68:4 height 96:1,6 held 34:1 60:7 helms 2:7 HARTOLDMONO013694 [help - kidney] help 27:15 51:21 helpful 52:8 helping 61:12 hemorrhoids 23:22 hereto 2:21 hereunto 116:16 hernia 23:22 hey 11:6 64:6 103:2 hid 104:23 hiding 103:16,17,19 high 13:19 16:17,21 24:17,19 32:7,12,12 73:8 79:3 hill 104:23 105:4,8 historically 56:2 history 29:7 100:12 hit 57:7 hold 25:14 26:3,5 hole 107:6 holidays 53:8 home 77:13 honorable 21:18 hopefully 86:9 hospital 7:21 hot 75:14 hour 60:21 house 109:16 housekeeping 59:19 hughes 100:5,11,14 101:6 huh indirectly intriguing 20:2 25:7 68:14 69:19 54:16 95:1 75:21 85:8 95:7 individual involved hundred 97:9,19 98:21,22 6:9 28:14 37:19 44:7 48:1 4:20 91:2,3 93:21,23 95:12 individuals 50:1554:1958:1061:3 95:23 96:2 98:4 99:5,17 63:4 68:9 70:20 71:3,5,6,7 husband indoctrination 71:8 72:2 74:21 10:5 79:20 involvement hydraulic inferred 108:8 39:20 85:14 109:3 involving hydrogen information 6:10 68:9 35:11,1342:5 63:10 66:7 71:23 73:17 iron 89:5 97:10,13 111:3 17:17,18,19 icw 27:1 28:3 60:21 idea 6:22 11:15 37:15 38:9 42:23 43:6 57:14 80:17 81:3,11 86:16 96:16 identification 2:20 identified 101:4 identifier 98:6 identify 98:3 99:21 identity 97:18 ii 103:23 illinois 89:15 impacted 69:12 impregnated 20:13,16,22,23 impregnating 20:15 impurities 44:5 inches 96:7 include 69:5 inconsistent 93:22 independent 12:5 indiana 13:23 24:15,17,18,19 indicating 25:7 68:14 95:7 96:4 indication 19:7 85:5 informed issue 81:5 66:2 ingestion it'll 79:4 5:21_____________________ inquire j 60:12 inside 48:17 56:14 inspection 67:9,14 107:11 Jacksonville 7:9,11 12:21 16:3 82:14 january 14:3 15:21 103:18,19 install 1:1 3:7 4:2 116:19 jerry 51:21 instance 39:20 99:22 instruct 99:15 instructed 65:22,23 jersey 14:8,19 67:21,22 jet 83:9,14 job 98:9 instructing 98:12 instruction 99:20 instruments 19:14 34:1 35:2 44:20 47:1 52:9 60:7 67:2,4,16 69:22 71:14 72:19 100:18 106:8 106:17 jobs 21:12 46:7,14 55:3 47:17 insurance 6:19 25:9 intensively 14:22 interest 8:8 13:16 82:21 83:8 interested 83:13,15 97:8 116:15 internal jr 1:1,1 2:3,16 3:5 4:4 7:6 jsu 68:18 jug 49:17 50:1,1 june 93:6 jury 8:9 10:16________________ 23:22 international k 25:12 26:8,13,18 keep interpreting 48:16 71:10,23 108:10 kentucky intervals 2:5 21:23 30:23 31:1 kept intrigued 29:12 22:18 kidney 81:14 HARTOLDMONO013695 [kind - matter] kind larry 13:10 15:23 22:8 29:1 31:4 2:7 95:16 33:14 36:13 43:21 49:11 lastly 60:13 61:6,9 62:10 66:6 115:2 72:23 74:22 75:18 76:5 late 88:16 94:1 97:8 107:1,21 14:12 48:3 72:12 87:11 knew 90:8 102:17 105:21 110:23 law know 1:1 2:4 5:16,22,23 6:1,6,11,12 8:20 laws 9:20 11:21 12:13,14,15 3:13 17:20 19:6 23:3,4 24:2 26:7 lawsuit 33:17 35:17,20,23 36:15,19 4:18 37:7,18 40:1 43:16 45:3,12 lawyer 45:16 48:18 51:16,20 52:4 99:15 58:19,20,21 66:1,6,11 layer 68:20 70:17 72:3,13 73:19 107:16 78:19 88:20 90:4 91:22 laying 94:15 96:12 98:18,22 99:4 86:7 99:9 100:14,19,22,23 101:6 Idl 102:2,7 104:18 105:5 32:9 106:15 109:5,10,12,20 lead 111:19 113:8,8,15 114:4 68:16 79:4,6 knowing leading 106:17 108:21 3:18 83:20 knowledge leadman 4:17 49:14 50:10 89:3 54:2 60:8 90:20 learn known 45:10,11 63:12 111:8 79:16 learned knows 66:18 80:12 98:13 learning knox 31:11 21:23 left krummrich 5:2 19:11 86:7 89:14 level 1 9:20 90:17 92:12,19 97:2 lab 20:1049:19 108:18 112:18 laboratory 20:4 levels 30:21 36:5 74:1,2,7 libraries 82:17 laborer 17:10 laborers 66:5 lady library 16:9 82:11,12,13,15,16,23 lid 60:1 light 5:1 18:10 32:5 44:19 48:16 land 85:15 liked 42:16,19 landfill 57:5 58:15,17,22,23 60:5 74:18 105:22 limits 65:1 66:12 line landfills 102:12 21:2 40:19 66:14 67:10 68:22 84:4,5 large lined 3:7 105:10 107:6 116:22 56:12 liquid lost 39:4 44:19 46:21 79:6 80:4 38:1 list lot 10:19,19 63:22 17:4 21:12 44:1 53:17 62:5 listed 62:21,22 70:12,20 71:13,22 92:6 71:22 73:9 90:14 96:5,22 literary 110:3 111:14,18 22:13 lots litigation 25:2 95:20 6:10 louis little 71:4 105:3 45:12 48:17 60:12 62:1 louisville 93:3 2:5 live low 7:23 10:22 110:12 97:4_____________________ lived m 8:18 9:4,6,8 ma'am liver 81:4,7 101:22 102:3 4:10,11 mail lives 95:12 living 21:13 maintained 37:10 16:15 24:20 lie maintenance 47:3,12 48:13 50:16 1:1 load 85:14 majority 41:1 makeup local 25:12 27:14 36:6,13 making locally 17:13 23:9 40:12 44:2 15:4 located 14:7 48:22 50:6 locations 50:4 74:16 48:14 71:19 86:13 management 14:10 15:23 28:4 68:1,2 manufacturing 68:11 lock map 101:16 long 7:10,23 10:18 27:21 32:3 38:11 40:23 43:7 45:3,22 47:11 52:14 73:1 96:11 9:1 mark 25:1 marked 2:20 longer 54:5 look 44:16 97:11 82:19 84:21 96:14,14 102:12 103:5 108:22 marriage 10:18 116:12 married 9:15 10:10 match 109:5 112:13 101:10 looked 9:1 11:12 12:6 74:19 83:9 matched 101:14 105:14,19 112:12 looking 10:14 19:2 73:23 74:2,3 material 18:1927:1956:17 materials 104:16 109:12,14 looks 20:15 26:23 39:3,23 40:1 44:11 63:20 93:18 matter 59:17 87:9 112:19,19 HARTOLDMONO013696 [matter - numeric] matter (cont.) mind moved needlessly 116:15 5:13 52:17 80:22 114:13 8:4 76:23 mcclellan mine mud needs 20:6 22:3 23:6 5:9 94:7 56:20,23 5:2 mean minimize mulliss negatively 11:19 18:20 36:21 45:5 75:18 2:7 97:3 48:10 51:15 57:22 59:16,18 missed multiple neighborhoods 63:21 64:13 79:19 80:19 83:11 108:16 110:4 114:12 91:10 111:17 114:6 misty municipal neighbors means 1:1 3:5 116:22 69:6 85:16 111 :23 12:13 116:6,7 mitigate muzzles nerve measure 69:4 76:2 20:1823:1,9,14 34:12 molds myers neurodevelopmental media 17:21 2:7 4:11 6:23 28:16 31:8 82:3 110:9,15,16,16,17,18 111:3 moment 33:16 50:7 55:2 57:17 64:1 new 111:9 11:4 14:14 16:1428:10 64:9 67:1,11 69:2,16 74:13 10:10 14:8,18 50:21 51:1,4 medical money 78:13,18 79:12 80:16,21 51:5 52:8 61:2 67:21,22 7:20 28:11,12 31:4 32:6 52:23 81:2,9,15,20 82:1,4 85:13 newspaper medium monitor 86:4,17 88:13 89:1,9,16 111:21 18:10 74:6 95:8 96:16 97:15 98:12 nice meet monitoring 99:18 100:2 101:9 110:6 107:19 26:20 28:11 31:5 32:6 72:20 111:16 112:15,21 113:4 night meetings monitors 114:14,21________________ 105:15 79:21 melted 102:6,8 member 25:11 28:3,3 memo 48:13 mention 51:14 mentioned 19:19 30:12,18 39:23 109:18 110:20 mercury 34:23 35:18 36:7,10,12,14 36:16,19 37:6,14,15 messes 17:5 met 13:9 mid 15:15,16 30:5,10 90:13 92:16 middle 14:12 mile 9:8 miles 9:2,11 95:13 military 19:20 103:23 miller 1:1 25:23 n nine monsanto 1:1 4:20 6:10 11:8,17 14:15 14:17 16:13,16 19:1223:15 25:5 28:13 29:20 33:22 38:4 48:13 61:22,23 62:5 62:16 68:17 71:20 76:13 nacl 37:11 name 4:15 7:4 9:17 10:4,10 31:21 68:15 82:15 92:6 100:7,8 names 20:21 ninety 20:21 nitrophenol 44:21 normal 84:22 87:13 89:7 96:11 110:18 111:23 monsanto's 88:18 112:11 montars 75:2 month 93:9 months 34:13 moore 2:7 mortality 88:21 89:7,12 mos 20:1,2 22:11,19 motivation 61:1 motor 50:21 51:1,7 motors 51:5 mouth 59:8 move 10:2 92:23 99:17 name's 101:2 national 26:3,6 64:21 native 24:15 nature 107:23 nco 21:13,14 new 26:6 ne 2:8 neat 107:19 necessarily 5:23 45:19 109:6 necessary 3:16 73:11 77:4 need 5:3 7:15 8:20 11:21 24:2 57:23 108:20 needed 32:15 normally 49:10 north 7:8,22 55:20 56:6 northeast 7:19 northern 27:4 notarial 116:17 notary 3:6 116:22 notice 3:22 72:10 notify 65:17 66:9 npdes 64:20 number 1:1 17:11 91:10,11 94:8 97:8 110:11 numbers 94:6 numeric 28:2 50:23 104:10 112:17 66:17 106:22 98:6 HARTOLDMONO013697 [numerical - people] numerical Ohio operators 65:1 26:19 27:5 53:16,18 66:5 nurse oil opportunity 29:14____________________ 18:17 61:4 63:6 102:23 103:1 o okay 107:5 object 5:1 6:6,7 7:10,15 8:2,18 9:4 opposed 28:16 31:8 33:16 55:2 64:9 67:11 69:2,16 74:13 78:13 79:12 80:16 81:2,9 85:13 86:4,17 88:13 89:1,16 10:6,12 11:3,3 12:16 13:6 13:19 14:5,7,21 16:23 17:13,19 18:9 19:4 22:23 23:17 24:3,12,17,22 27:1 22:19 39:18 78:16 oral 79:4 orderly 110:6 111:16 112:15,21 113:4 114:14,21 objection 78:18 81:15,20 82:1,4 89:9 objections 3:16,19 28:2,10,18,22 29:3,11,17 68:5 30:18 31:17,22 32:8,13 ordinary 33:21 34:16 35:13,23 38:11 54:18,22 38:23 39:2,23 40:12 41:3 organization 42:20 43:5,7 44:20 45:3 26:1 46:2 47:10,18 48:7,20 49:6 os ha observation 64:4 100:13 observe 83:19 84:18 85:3 observing 106:20 50:14,20,23 52:3,7,21 53:1 54:3,15,20 55:16,23 56:4 56:10,14 57:11 58:8 59:20 60:7,20 61:17 62:6,23 65:19 66:16 67:4 68:20 69:22 70:13,17 71:6,18 61:14 outflow 49:1 outside 67:1768:22 110:17 overly obtain 13:22 72:8,15,21 73:23 75:10 69:3 76:8 77:20 78:9,22 79:15 overseeing obtained 12:18 15:18 obviously 21:20 36:1 occasion 79:22 81:14 82:3 83:3,18 13:2 85:16 86:15,21 89:10,20 overshoes 90:14 91:3,6,13 92:5,15,21 76:4 93:6,8,10 94:18 95:18,22 owens 98:16,21 99:14 100:6,14,21 6:187:1 58:6 83:18 84:8 102:11 101:13,17 102:11,16 103:1 P 103:15 105:21 106:21 108:2 occasionally 24:7 31:19 36:20 occasions 103:8,10 104:11,20 105:6 p2s5 105:12,21 106:19 107:13 107:15,17 108:6 109:3,10 110:8 112:10 113:12 114:9 old 52:1 naae 2:11,16 93:3 paid 108:16 occurred 24:14 87:23 93:6 101:6 older 60:21 panel 27:11 38:9 85:12 91:7,17 113:5 odd 5:7 78:23 once 6:13,15 open 10:16 paper 101:11 paperwork offered 2:21 3:21 office 55:19,21 officer 25:15 56:8 operate 67:13 operating 75:3 operation 71:17 72:13 73:16 para 44:21 paragraph 79:23 parameters offices 1:1 official 34:1 oh 41:11 106:20 operator 34:3,3,4,5,17,18,19 38:7,8 39:2 42:22 43:8,18 44:22 45:1,23 49:18 52:11,22 73:19 109:18 parathion 30:20 42:21 43:8,18 44:2 44:12 45:2,5,20 50:22 51:12,23 52:2 53:12 83:9 58:18 70:13 72:15 84:5 87:7 92:17 93:20,20 96:1 53:2,3,6,11,15,19 54:1,12 60:8,18 61:2 75:6 76:11 park 2:4 97:8,9 106:18 78:11 84:1,1 94:4 96:13 part 100:20 106:10 108:16 8:13 15:1840:17,1844:3 part (cont.) 44:13 67:5 72:5,6,14 79:20 84:22 participate 89:4 participated 88:20 particular 17:14 18:6 22:17 31:12,23 34:5 39:15 40:13 46:2 53:4 71:15 78:16 92:9 102:20 103:15 106:8 107:8 particularly 32:18 75:15 83:13 parties 3:3 116:13 parts 10:20 party 12:11 pass 63:2,10 passed 41:1 42:11 patient 99:22 Patrick 10:4 pay 32:22 paying 19:14 pcb 9:20 33:13 43:11 57:1 64:6 64:10 70:21 74:7 75:5 83:4 90:21 92:12 102:6,8 108:10 108:17,23 109:5,21 112:1 pcbs 19:8 43:15 72:10 74:12 75:2 78:10 80:13,14,22 81:7 82:1990:1,10 110:3 110:10 113:2 peachtree 2:8 pelham 7:8,11 penetrate 20:18 pension 25:9 people 26:15 45:16 53:23 61:12 62:23 63:19 65:15,17 67:13 71:3 76:1980:1581:1,8 88:9 92:7 100:3 110:12 112:17 113:2,13 114:9,17 HARTOLDMONO013698 [people - pulmonary] people (cont.) places positions procedures 115:7 8:15 78:1 25:14 26:3 45:10 27:19 64:14,15,19 78:21 people's plaintiffs possible process 114:19 1:1,1 2:2 35:18 45:17 34:3,21 35:8 36:4 51:23 perceived plant posted processed 50:17 8:19 9:5,9 23:2 30:17 33:11 88:2 19:1 39:3 percent 36:19,22 37:16 42:10 45:10 potential processes 20:21 47:5,6 49:2 52:13,14 53:6,7 86:18 23:9 performed 53:10,14,18 55:17 57:10 potentially proctored 31:16 59:16 60:13 62:12 63:4,11 69:12 15:3 period 63:23 66:5 69:17 70:2,15 pounds produce 97:23 71:2 72:4,10 74:7,17 77:21 95:23 23:14 periods 77:22 82:11,12 83:21 88:10 precedence producing 76:16 88:18,22 89:14,21 90:6,15 10:9 23:8 permit 95:10 98:18 100:16 102:2,7 preceding product 65:5,9 104:6,7,8 106:11 110:5,13 29:8 38:20 40:20 43:21 44:1 perry 112:14 precursors 108:15,18 1:1 3:5 116:22 plants 23:1 production person 61:23 85:17 prefer 53:22 55:18,21 53:9 60:9,11 61:1 62:3 63:9 play 94:17 products 64:3 65:21 67:19 69:20 46:3 72:6 preparing 24:8 73:12,15 95:6,17 97:12 please 72:8 profess 101:1,4,8 102:5 6:3 7:4 12:18 23:10 44:10 presence 7:17 96:20 personal 50:20 84:11 99:17 108:23 116:6 program 75:1,22 76:1 92:11 pleased present 28:12 personally 16:6 92:1 project 83:19 113:20 114:7 plus presenting 51:2 54:23 personnel 12:20 30:14 61:19 projects 71:2 72:22 pncb presume 50:14 52:4 58:8 perturbed 74:4 6:3 22:5 44:23 54:21 70:8 prolonged 32:18 pnp 107:17 79:2 phrase 44:21 45:9,23 46:4,20 74:3 pretty promotion 57:4 71:9 85:6 86:1 106:10,10 9:13 16:9 30:1 40:5,16 53:9 44:23 70:8,11 physically point 54:3 61:20 83:2 97:5 protect 38:1 15:6 23:7 43:10 47:19 50:7 104:16 92:23 physicals 53:4 64:1,2 77:21,23 prevent protected 28:1531:13 100:12 101:23 106:8 80:5 98:5 physician points previous protection 29:16 89:18 5:8 6:8 80:3 pick poll primarily protective 79:15 86:1,6 8:9 20:13 26:22 27:18 56:16 75:22 76:1 picked pollutant primary protocol 61:7 109:11,20 64:21 34:18 63:8 29:23 picking pollutants prior prove 87:13 65:3 3:21 22:9 11:21 12:2 piece pollution privacy provide 43:20 50:17 51:2,4 92:23 98:4 78:4 pipe polyphenyl probably providing 17:15,16,17 18:23 83:9 6:20 9:1,3 10:6 17:9 25:19 77:22 pit pond 33:7 38:13 43:9 44:4 46:1 public 55:7,15,16 56:1 57:9 59:5 74:17 52:1571:12 102:17 3:6 82:16 116:22 59:11 105:9,10,13,14,20 ponded problem pull 107:9,10,11 105:17 108:4 54:8 74:10,11 40:13 place position problems pulmonary 17:5,8 22:1 28:12 31:6 25:20 26:5 61:2 70:6 71:16 80:15,23 81:4,8,14,23 82:2 28:18 30:9,15 35:20 107:8 82:3 HARTOLDMONO013699 [pumped - reuse] pumped 55:7 purchase 37:2 purchased 36:23 pursuant 1:1 push 107:21 pushed 107:2,22 put 7:18 18:3 22:5 34:20 36:1 51:9 55:9 58:14 59:4,7,17 59:23,23 72:9 73:11,14 74:16 102:5 107:18 putting 50:21 pvcs 31:19 q qualified 15:9 62:3 quantity 37:2,5 question 5:12,14,21 6:2 29:14,17 38:16 66:9 92:1,8,10 98:8 98:11,17 99:14 105:23 questioning 109:23 questionnaire 93:1 96:6 questions 3:17,18 4:17 92:7 93:2 97:20 114:2 quinta rd 1:1 quit 24:22 96:10 quite 8 4 9711 quote 78:23 79:8 r radiological 20:3,11 railcars 104:10 railroad 57:13 rain 59:2 rainfall receive 84:19 85:9 15:11 25:4 rainfalls received 84:13 35:18 ran receptacles 36:3 40:23 43:19 59:18,20 range reclaimed 32:15 36:15 rank recollection 21:15 28:3 60:20 66:4 12:6,10 27:23 43:14 47:20 rate 47:23 60:3 82:6 93:22 36:13 49:22 108:3 rates recommendation 88:23 89:6,7 88:16 ratio recurring 32:9 57:22 raw reduced 39:3,23 40:1 116:5 reactor referred 43:22 46:8 31:20 reactors region 46:10 26:10,21 27:14 read regional 11:13 78:22 79:22 80:19 1:1 7:20 81:10,16,21 82:5,7,18 regions 107:1 112:2,4 26:15 reading regular 3:1079:13 111:20 31:1,4 104:1 ready regulations 11:5,7 61:1463:16,22 88:11 real related 101:14 10:17,23 55:6 realize relating 53:2 3:14 really release 24:1 35:14 42:16 46:7 66:6 65:2,14 66:18,22 68:10,22 67:16 68:3 94:13 101:15 69:13 realm relevant 15:21 4:18 reason remember 30:13 47:7 59:3 94:20 10:11 11:8 46:1251:18,21 102:14 52:1 58:7,13 72:8 74:5 recall 78:20 79:13 89:17 91:18 10:3 16:10 22:12 27:5,10 92:8 105:7,17 106:9,19 28:14 29:13,20,21 30:11,14 remembered 30:23 31:6,10,11 33:10 52:7 35:14 48:23 49:4 50:14 repeat 51:10 54:21 58:6,9 60:2,16 23:10 89:2 78:14 79:10,14 82:2,19 repeated 89:17 90:18,23 91:16 93:1 79:4,5 93:5 102:4 105:15 108:8 report recalling 66:13 99:1 33:22 reported recapture 65:10 93:20 37:21,23 38:2 reporter 4:8 reporter's 2:13 reporting 1:1 65:12 reports 72:7,9 110:15 represent 4:19 36:18 37:3 representative 26:9 representatives 27:16 required 97:17 98:3 research 23:6,12 reside 7:138:3,11 10:15 resided 7:10 8:7,16 residential 112:14 114:12 residents 69:12,17 resource 60:9,10,23 61:11 63:9 64:3 65:21 67:2,4,19 69:20 resources 69:4,5 respect 33:1391:9 114:3 respective 3:3 respirator 28:23 respirators 76:3 response 5:3 61:15 67:23 68:6 responsibility 21:10 53:7 63:8 responsible 54:13 result 31:13 results 89:12 91:20 retired 28:8 100:21 retirees 33:12 retirement 25:6 reuse 37:22 HARTOLDMONO013700 [revealed - sir] revealed safety (cont.) sealed 31:15 79:21 88:12 21:3 59:21 revelations saith second 32:5 115:11 5:20 38:3 49:21 101:1 rid sake 105:21 53:17 12:4 sediment ride saks 56:18,19 59:1 103:7 9:6 seeing right salaried 108:3 6:3,5 12:3,17 15:19 19:18 70:6 seen 28:21 35:4,4 38:3,18 40:6 salary 48:12 86:19 92:5,15 41:20 42:9 43:17 45:18 28:4 60:19 select 63:4,18 66:8 72:3,13,18 salt 22:19 73:10 77:5,14 85:8 86:23 36:6 37:11 seminar 90:16 95:4,15 101:2,3 sample 90:5 102:18 104:22 109:7,8,17 49:12,13,13,18,23 64:4 seminars 110:19,21 113:10,17 73:16,20 74:6 75:8,12 91:9 62:17 63:7 68:17 rnr 108:17 send 21:13 sampled 15:1 73:16 road 48:15 sense 7:8,11 sampler 6:6 34:4 76:10 95:1 114:6 role 48:8,11 49:1 50:5,11 73:8 sent 46:2 108:9 73:12,14 108:7 109:4,8 42:9 46:22 60:3 62:16 rolled samplers separate 76:7 48:14,21 73:13 74:15 39:9 room samples September 34:19 72:20 73:6,7 87:13 108:10 93:8 roughly 108:22 109:11,13,15,21 serum 27:10 34:10 sampling 90:17 97:1 routine 70:20 74:22 108:13 serve 31:4 103:10 108:13 sand 27:21 routinely 17:20,22,23 18:1,6,10,13 served 103:11 18:22 19:2,8 19:20 20:5 60:16 rows sanders service 107:19 1:1 3:6 116:22 1:1 32:23 34:13 rules sauget session 3:13 76:19 88:11 89:15,20 92:2 run saved set 34:23 46:10,11 47:16 85:20 112:6 1:1 37:23 73:1 92:20 94:9 85:20,23 saw 114:2 116:17 running 104:14 sets 39:15,1841:1746:8,8 saying 65:1 65:19 85:21 86:2 9:13 11:20 56:22 setting runs says 74:5 46:12 79:23 94:4,21 96:13 111:22 seven s scenario 94:12 sabrina 68:9 seventy 1:1 Sttf6 school 96:7 13:19 15:17 16:17,21 24:18 sewage 9:13 70:1671:10 safely 105:2 24:19 61:8 63:7 85:16 science sewer 12:23 13:8,9,11 15:22 83:1 85:22,23 safety 26:10,1427:1861:1463:5 scientists 80:22 81:6 sewers 54:10 85:22 64:16 67:6 70:1,13,18 seal shakes 71:21 72:15 76:15,17 78:21 116:17 97:3 shaking 5:4 sheet 91:11,14,16,19,20 93:4 sheets 37:9 shells 107:19 shields 76:8,9 shift 17:10 46:18 52:21 shifted 38:15 shifts 53:8 shipping 102:9 shoot 20:9 short 10:19 11:3 shots 29:12,13 shovel 17:22,23 19:1 59:12 shoveled 18:4,22 show 10:16 showed 113:13 shower 77:16 shows 79:1 shut 38:10 96:18 side 33:14,17 39:5 sight 104:21 signature 3:10 simple 95:5 simplify 8:6 sims 9:18 single 90:23 98:21 105:10 singled 78:19 sir 6:12,23 8:17 16:8 68:23 HARTOLDMONO013701 [sir - supposed] sir (cont.) 89:3 sit 26:16 58:9 80:18 site 53:13 54:9 66:19 69:18 sitting 41:8 104:3 situation 57:22 58:11,16 six 28:1 30:19 52:15,18 93:12 93:12,13 96:1,8,9 97:9 98:14 99:22 101:20,20 size 94:2 skin 79:7 80:15,23 skip 14:14 slash 60:8 sleeves 76:6 small 44:3 smith 2:7 smoke 96:2 smoker 94:5 smoking 24:12,22 96:10 snow 84:9,18 85:21 soaked 94:21 95:3 soil 17:15,1654:10 108:11 109:1 114:12 solutia 4:21 somebody 11:20 40:1859:1362:19 76:21 96:1 103:2 104:5 someday 112:2,3 someplace 18:5 sorry 29:1 50:23 58:18 83:11 86:22 95:9 sort 11:10 15:8 21:1025:4 35:10 54:23 66:20 67:8 sort (cont.) started 71:14 73:2 88:8 91:6 33:23 45:8 83:17 107:23 state sorts 4:1 12:21 13:4,7,13 14:3,3 47:14 14:6 15:12,21 16:3 82:14 sound 88:17 113:1 5:21 6:3,5 43:13 49:6 94:16 stated sounds 36:9 32:17 94:15 106:12 states source 23:13 12:15 111:3 statistic south 89:4 55:21 56:5 57:5 74:18 status southeast 26:1 31:12 26:9 stay southern 48:18 68:5 8:13 stayed spare 30:1 36:5 70:15 104:6 ste sparked 2:4 102:20 steady speak 36:9 37:5 steam special 40:8 82:18,20 94:8,23 stenography specialist 116:7 20:4,1021:9,11,17 step specific 41:4 44:7 17:6 29:22 35:20 40:13 steps 97:18 44:2,3 75:17 specifics stern 52:6 77:3 spend stillers 14:22 41:2 spent stipulated 21:7 3:2,9,15,22 spill stipulations 75:9,20 1:1 2:124:9 spilling stopped 76:22 107:8 spoken storm 11:6 31:22 56:3,4,10 57:3,7 85:18 sport story 87:12,14 33:15,18 St straighten 71:4 105:3 32:20 stacked strained 107:20 64:18 staff stream 21:9,11 35:7 37:4 42:2 44:6,9 46:9 stands 46:19,21 52:16 streams star 35:10 42:15 111:21 street start 1:1 2:8 7:14,15,16 8:22 7:3 24:12 77:21 87:5 95:5 55:18,20 strictly 67:6 strikes 62:2 stringent 59:19 stringfellow 7:22 studied 61:8 67:21 studies 13:11 study 14:9 15:2 88:21 89:12,17 stuff 7:3 11:8 15:23 17:21 30:5 33:21 37:22 39:16,19 41:20 44:16 52:8 55:8 58:14 61:6 63:13,13,21 67:17 68:17 75:20 76:22 77:8 103:2,12 subsequent 15:20 subset 39:12,13 subsidized 25:9 substance 68:10 suck 73:9 sue 111 :23 sued 4:20 suggest 23:12 suggestions 32:19 suggests 54:15 107:1 suitable 79:23 80:3,10 suite 2:8 sump 55:11,12 superfund 111:5 113:13,14,15 115:2 supervisor 66:10 supplier 36:20 supposed 38:2 71:20 76:6,12,22 77:15 95:4 HARTOLDMONO013702 [sure - transcribed] sure taught therminol time (cont.) 6:7 21:1,3 24:21 25:18 63:1,18 65:17 66:8 38:5,12,18 39:1,7,9,11,16 76:16 89:23 90:19 91:14 26:11 27:6 35:3 36:5,15,23 teach 40:12,15,21 43:2 75:4,7 96:17 98:1 102:1,19 104:6 47:18 48:14 49:22 56:13 63:14 65:15 78:11 79:11 100:15 106:8 108:6 111:13 70:15 71:23 76:18 84:2 team thing times 86:13 87:16,19 89:10 96:20 103:20 10:14 11:1038:341:3 25:2,18,19 36:11 84:12 97:5 100:10 105:14 109:13 tearing 42:20 57:23 60:14 73:2 timing surface 48:3 91:8,22 94:10 103:10 113:6 43:12 57:3 technician things tires surgeries 70:1,14,18 72:16 76:17 5:7,16 11:4 16:14 17:7 104:1 23:19 tell 29:15 30:3,6 40:9 47:14 title surgically 5:6 6:4 7:4 12:5,17 16:19 51:6 63:15 67:9 68:3 71:14 34:1 23:21 17:6 19:3 20:8,9,9 22:8 107:18 113:22 tob surprise 25:1728:1331:1532:15 think 73:13 111:10,15,18 112:20 113:3 33:23 34:11,16 38:23 39:6 5:106:159:2 10:1227:6 tobacco 113:18 43:17 44:9 48:22 49:16 28:7 33:19 35:11 38:12 24:8,10 surprised 50:20 52:5 53:1 61:17 64:7 40:1,22 42:21 43:4 44:21 today 113:6 66:16,17 69:1,14 72:23 45:22 47:11,22 48:6 55:5 4:16 11:5 12:4 48:1658:9 surprises 75:1 84:11 92:12 93:19 56:12 57:3,15 58:9,15,23 80:18 87:18 95:6 111:18 95:17 96:15 99:16,18 100:2 59:2,13 60:4 62:7 63:14 toe surveillance 100:9 101:9 114:9 116:3 68:21 78:15 79:15 80:12 76:11 28:12 31:5 telling 82:9 83:5,6,16 86:10 87:10 told suspected 64:5 79:18 91:2,23 92:14 94:7 95:5,11 12:1 78:9,15,20 79:10 59:14 temperatures 95:12 97:16 98:1,2 99:6,12 82:21 83:16 109:15 110:23 switch 79:3 80:2 99:13 100:7,8,10 103:21 112:7 19:17 ten 105:19 109:19 110:22 ton switched 96:9 97:1 98:13 99:22 thinking 103:22 45:9 tenure 51:3 56:5 103:22 top sworn 65:20 third 68:5 107:20 4:5 116:3 terminology 17:10 town system 26:8,11 thirty 111:6 113:19 115:3 51:9,13 64:20,22 terms 4:19 87:21 96:12 toxic systemic 54:9 57:14 77:3 94:2 97:12 thomas 68:10 79:5 79:5 terribly 14:6 68:12 toxicity systems 49:6 thought 78:10,16 83:13 37:23 test 5:13 39:22 83:5 93:23 track t 28:18,23 29:1,2,4,4 30:7,15 three 57:13 103:9,11,14,17,21 taken 1:1 3:5 15:20 58:14,17,21 75:17 108:22 116:2 talk 101:22 102:3 108:14 tested 90:9,21 91:4 testified 11:22 16:12,13 28:10 33:21 49:11 53:23 90:1 talked 12:7 76:23 83:4 92:13,14 108:7 4:6 testimonies 6:9 testimony 5:8 80:8 116:5,10 talking tests 5:22 6:1 12:11 17:17 50:2 57:12 84:3 106:4 108:21 29:12 textile 110:17,18 tall 93:11 20:19 textiles 20:17 task 22:9 103:4 thank 7:2 115:9 tasks thereto 46:4 3:21 9:2 16:22 19:20 21:5 25:19 trailer 46:13 47:13 96:7 101:20 78:6 103:22 train threw 27:15 62:23 66:11 88:9 64:10 trained throw 26:18 46:5,16 61:9 66:12 5:13 59:12 68:18 throws trainer 94:10 67:19 thyroid training 81:23 82:2 21:13,21 22:4,8,11,14 tier 26:18,22 27:1 45:15 60:9 72:7 60:10,23 61:11,19,19 62:19 time 62:21,22 63:9 64:2 65:21 3:19,20 14:13 15:13,18 65:23 66:16,20 67:2,4,12 18:3 29:19 40:23 43:15 67:13 68:8 69:13,20 78:6 47:2,20 50:8 53:4,12 54:4 transcribed 58:3,19 60:18 63:8 64:1 116:7 65:22 73:21 74:9 75:3 HARTOLDMONO013703 [transcript - wide] transcript tubing use war 92:5 116:9 49:5 17:20 24:8 37:11 52:17 103:23 transcription turn 71:9 73:11 104:7,9 warm 116:8 27:13 63:1 85:4 86:12 usual 48:18 transfer turning 4:8 washed 38:20 39:4,17 42:8 usually 44:11 transferred twa 59:22 washing 1:1 73:13 utilized 43:19 44:17 transformers twain 50:11 waste 39:20 25:1 V 35:7,10 37:4 42:2,15 44:6,9 travel twelve vapors 44:12,1446:9,1949:1,17 27:14 61:22 traveling 62:1 treads 104:1 7:12 twice 6:13 102:13 type 73:6,10,13 42:4 51:10,13,22 79:2 80:1 various 27:14 65:2 vasectomy 23:22 55:9 85:6 86:2 90:3 109:8 wastewater 64:6 water 35:11,15 36:6 37:12 40:7 treat 64:12 treatment types 51:5 65:2 typical vat 362 vehicle 56:3,4,10,16 57:3,3,7,18 77:20,22 78:7 85:18 105:17 108:2,4,5,11,23 35:18 44:13,14 46:22 49:2 49:17 85:17 109:8 trial 3:20 tried 61:17 u u.s. 16:22 19:21 uh 103:23 ventilation 77:6 80:1,9 verbal 5:3 ways 81:6 wear 76:6,22 77:13 wearing 22:20 24:22 33:11 37:23 75:19,20 triggers 12:10 trip 20:2 25:7 68:14 69:19 75:21 85:8 95:7 96:4,4 understand 5:1 22:23 25:22 38:18 46:20 48:2 59:9 61:12 versus 1:1 34:13,14 90:2,3 vessel 43:22 viewed 76:21 weekends 53:8 weeks 14:22 22:12 30:19 96:10 82:18 triple 91:1 trouble 112:7 troubleshoot 65:14 75:15 77:10 99:3 understanding 26:12 55:23 65:7 67:20 80:7 understood 42:5 11:12 visit 90:6 volume 73:8 volunteer weigh 93:15 weighed 96:1 weight 94:3 95:22 96:9 47:17 unexpected 13:14 welder truck 106:23 truckload 106:3 true 116:9 trustee 25:18,22 truth 116:4 try 8:6 11:21 52:18 66:11 83:6 88:9 92:18 101:5 trying 8:7 12:1 18:20 21:2 36:17 59:7,8 69:11 85:2 100:7 106:9 tube 73:10 113:7,11,12 union 17:1,2,5,11 19:11,1627:16 61:8 unions 26:20 unique 58:3 uniquely 62:3 unit 37:14 united 23:13 university 12:21 13:1 unsightly 104:21 untoward 80:5 vx 23:1 w 74:1 welding 74:3 went wait 21:20 24:17,19 27:7 30:2 77:17 35:16 37:9 38:5 42:21 waived 43:15 44:12,21 47:3 49:13 3:11,23 49:16 60:19 68:4 78:10 walk 83:8 105:7,11 82:23 west walnut 57:13 106:11 1:1 we've wandered 16:1960:11 61:6 103:4 whatsoever want 66:9 5:17 11:3 12:8 22:18 29:9 whereof 38:19 40:14 47:8 96:19 116:16 98:7 101:17,19 103:6 114:4 wide wanted 47:5,6 52:13,14 53:6,14,18 45:12,16 47:9 49:11 89:23 60:13 70:2 HARTOLDMONO013704 [wife's - zero] wife's wrote 9:17 97:9_____________________ willie y 1:1,1 2:163:44:4 7:5 wise y'all 28:15 36:21 37:20 42:16 18:9 64:17 witness 2:16 3:11 11:16,22 97:3 116:1,10,16 witnesses 73:19 77:6,20 113:22 y'all's 72:13 yard 104:12 97:21 116:6 wondering 30:13 112:5 word 113:10 words yards 110:4 111:14 112:1 yeah 7:23 11:1923:11 25:3 32:12 39:18 41:22 43:15,23 44:4 56:7,19,21 57:2 60:6 19:15 39:10 49:20 59:7 66:4 69:19 76:12 77:14 63:12 91:7 work 82:11 86:20,22 90:8 92:17 93:14 94:15 97:1 99:18 13:2 14:2,18 15:20,22 16:16 19:11 22:1727:8 32:14 33:3 43:7 49:8 53:20 105:1,11 115:4 year 106:18 111:19 54:17 55:3 61:12 67:22 72:3 78:10 79:1 95:10 99:6 16:19 17:1 21:7 29:8 57:15 years 112:18 worked 14:15 17:10 19:19 30:20 7:12 8:1 12:20 14:15 16:22 19:20 21:5,6 24:13 28:1,8 34:13,15 38:13 43:9 45:4,7 38:12 39:7 45:22 48:20,23 52:4 62:9 89:13 94:11 46:1 47:13 52:15,18 60:16 78:11 87:21 94:3,12 96:12 96:11 100:15 108:6 109:4 worker 96:22 101:23 106:17 yellow 93:20 102:2 workers 85:4 86:1,12,19 6:1725:1267:1471:10 88:21 89:8,13 92:3 zero workforce 98:14 99:22 33:1261:21 63:11 88:18 workforces 27:15 workforce's 70:21 working 11:18 14:17 15:1766:4 75:6 77:7 79:10,19 104:5 113:22 world 103:23 worried 32:18 114:5,8,9 worry 10:7,13 36:10 95:15 114:7 writing 99:3 116:6 wrong 38:20 47:10 HARTOLDMONO013705