Document OzyGy2Le6vdyQgqEeNO7Oy8kL

0001 1 IN THE UNITED STATES DISTRICT COURT 2 NORTHERN DISTRICT OF ALABAMA 3 EASTERN DIVISION 4 5 CASE NUMBER: CV-P-440-E 6 WALTER OWENS, et al., 7 Plaintiffs, 8 vs. 9 MONSANTO COMPANY, 10 Defendant. 11 12 STIPULATION 13 IT IS STIPULATED AND AGREED 14 by and between the parties through their 15 respective counsel, that the deposition 16 of JAMES RICHARD WALKER, SR., may be 17 taken before MICKEY TURNER, Commissioner, 18 at the offices of Fite & Miller at 4th 19 Floor SouthTrust Bank Building, Anniston, 20 Alabama, on the 14th day of October, 21 1999. 22 IT IS FURTHER STIPULATED AND 23 AGREED that the signature to and the 0002 1 reading of the deposition by the witness 2 is waived, the deposition to have the OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036879 3 same force and effect as if full 4 compliance had been had with all laws and 5 rules of Court relating to the taking of 6 depositions. 7 IT IS FURTHER STIPULATED AND 8 AGREED that it shall not be necessary for 9 any objections to be made by counsel to 10 any questions except as to form or 11 leading questions, and that counsel for 12 the parties may make objections and 13 assign grounds at the time of the trial, 14 or at the time said deposition is offered 15 in evidence, or prior thereto. 16 IT IS FURTHER STIPULATED AND 17 AGREED that the notice of filing of the 18 deposition by the Commissioner is waived. 19 20 21 22 23 0003 1 INDEX 2 EXAMINATION BY: PAGE NUMBER: 3 Mr. Wright 6 4 5 PLAINTIFF'S EXHIBITS: OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036880 6 1- Picture 27 7 2 - Picture 27 8 3 - Drawing 52 9 4 - Progress Report 81 10 11 12 13 14 15 16 17 18 19 20 21 22 23 0004 1 IN THE UNITED STATES DISTRICT COURT 2 NORTHERN DISTRICT OF ALABAMA 3 EASTERN DIVISION 4 5 CASE NUMBER: CV-P-440-E 6 WALTER OWENS, et al., 7 Plaintiffs, 8 vs. OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036881 9 MONSANTO COMPANY, 10 Defendant. 11 12 BEFORE: 13 MICKEY TURNER, Commissioner 14 APPEARANCES: 15 MITHOFF & JACKS, L.L.P., by 16 Mr. James L. Wright and Ms. Laura Ruth, 17 111 Congress Avenue, Suite 1010, Austin, 18 Texas 78701, appearing on behalf of the 19 Plaintiffs. 20 LIGHTFOOT, FRANKLIN & WHITE, 21 L.L.C., by Mr. William S. Cox, III, The 22 Clark Building, 400 20th Street North, 23 Birmingham, Alabama 35203, appearing on 0005 1 behalf of the Defendant. 2 SMITH, HELMS, MULLISS & 3 MOORE, by Mr. Michael E. Kelly, 300 North 4 Greene Street, Suite 1400, Greensboro, 5 North Carolina 27401, appearing on behalf 6 of the Defendant. 8 9 I, MICKEY TURNER, a Court 10 Reporter of Birmingham, Alabama, acting 11 as Commissioner, certify that on this OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036882 12 date, as provided by the Federal Rules of 13 Civil Procedure and the foregoing 14 stipulation of counsel, there came before 15 me at the offices of Fite & Miller, 4th 16 Floor SouthTrust Bank Building, 17 Anniston, Alabama, beginning at 2:00 18 p.m., JAMES RICHARD WALKER, SR., witness 19 in the above cause, for oral examination, 20 whereupon the following proceedings were 21 had: 22 23 0006 1 JAMES RICHARD WALKER, SR., 2 being first duly sworn, was examined and 3 testified as follows: 4 5 COURT REPORTER: Usual 6 stipulations? 7 MR. WRIGHT: Yes, ma'am. 8 9 EXAMINATION BY MR. WRIGHT: 10 Q. Good afternoon, Mr. Walker. 11 We met just briefly, chatting here before 12 the deposition. Have you ever given a 13 deposition before? 14 A. Yes. OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036883 15 Q. How many times? 16 A. Onetime. 17 MR. COX: And before you get 18 started, we have the same understanding 19 that y'all gave notice to Burr Forman 20 about the deposition and they elected, 21 for whatever reason, not to attend? 22 MR. WRIGHT: Everything is 23 the same. The stipulations and the 0007 1 speeches are the same as before in Mr. 2 Sims' deposition. Okay. What was I 3 asking? Deposition, yeah. 4 Q. Okay. When was that? 5 A. '92 or'93. I'm not real 6 sure which, but it was one of those 7 years. 8 Q. Did you go to Delaware, too? 9 A. Yes. 10 Q. Okay. What was that case 11 about? Mr. Sims wasn't real clear on 12 it. He said he thought you might have a 13 better idea. 14 A. I'm not real sure what it was 15 about either. 16 Q. Okay. 17 A. I just know I went up and OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036884 18 they asked questions. 19 Q. I guess Monsanto's lawyers 20 coordinated with you and told you about 21 it and sent you up there? 22 A. Uh-huh (indicating 23 affirmatively). 0008 1 Q. Were they using Alabama 2 lawyers or were they Delaware lawyers? 3 A. I don't know. I don't know 4 where the lawyers were from. 5 Q. You hadn't met them here, I 6 assume? 7 A. No, not here. I didn't meet 8 them until I got there. 9 Q. To Delaware. Okay. Do you 10 know, at least generally, what that case 11 was about? 12 A. I think it was pertaining to 13 landfill and how they handled materials 14 going to the landfill, but-- 15 Q. Was that the kind of 16 questions they asked you about mostly? 17 A. Well, how we operated the 18 department, you know, and materials that 19 were sent to the landfill. It was about 20 a day and a half long. OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036885 21 Q. Really? 22 A. There was just all kinds of 23 questions. 0009 1 Q. H'mm, okay. Did it have 2 anything to do with insurance coverage, 3 do you know? 4 A. My understanding was it was 5 something about insurance. There was an 6 insurance company involved or something. 7 Q. So Monsanto was on one side, 8 maybe, and the insurance company on the 9 other side? 10 A. I believe that's right. 11 Q. Do you remember any of the 12 names of any of the lawyers or law firms 13 or anything involved? 14 A. No, I don't. 15 Q. All right. Having been 16 through a deposition, you understand 17 that, first of all, that you are under 18 oath? 19 A. (Witness nods head.) 20 Q. And that the testimony that 21 you are going to give today can be used 22 in a trial, under certain circumstances, 23 just like you were sitting in the witness OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036886 0010 1 stand in front of a judge and a jury? 2 A. Yes. 3 Q. Basically, I just want to 4 get a background idea of both your career 5 and then, later on, we are going to kind 6 of expand and I am going to try to get a 7 broad understanding of how the plant 8 worked and what your role was. Okay? 9 A. Okay. 10 Q. When did you start with 11 Monsanto? 12 A. The 16th of March of'61. 13 Q. What was your first job? 14 A. I was an operator, relief 15 operator, they called it. 16 Q. In what part of the plant? 17 A. In the Aroclor Department. 18 Q. The Aroclor Department? 19 A. Yes. 20 Q. Was Mr. Sims there in the 21 Aroclor Department? 22 A. No, he wasn't in the Aroclor 23 Department at that time. 0011 1 Q. How long did you stay in that 2 job? OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036887 3 A. I was an operator until, I am 4 going to say around '66 or '67. 5 Q. So, a pretty good while, five 6 or six years? 7 A. Uh-huh (indicating 8 affirmatively). 9 Q. And, then, what was your next 10 job? 11 A. It was relief chief operator, 12 or chief operator. 13 Q. Still in the Aroclor 14 Department? 15 A. Uh-huh (indicating 16 affirmatively). 17 MR. COX: You need to answer 18 "yes" or "no," if you can, Dicky, so she 19 can make sure she takes it down. 20 THE WITNESS: Okay. 21 MR. COX: I know it's easier 22 to say "uh-huh," but you need to say 23 "yes" or "no." 0012 1 THE WITNESS: Okay. 2 MR. WRIGHT: I should have 3 reminded you of that. Usually I have to 4 tell everybody there three or four times, 5 because people just don't talk that way OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036888 6 in normal conversation. 7 THE WITNESS: Notin 8 Alabama. 9 MR. WRIGHT: Not anywhere. 10 Not in Texas, either. 11 MR. COX: He's from Texas. 12 They are used to it, too. 13 Q. I am sorry. I left off, your 14 job was supervising operator? 15 A. Yes. 16 Q. Chief operator? 17 A. Chief operator. We had 18 operators on the shift that worked with 19 me. 20 Q. All right. How long were you 21 in that job? 22 A. In that job in the Aroclor 23 Department until '72. I think it was 0013 1 April of'72. 2 Q. Let's say '67 to '72, you 3 were the chief operator or a chief 4 operator? 5 A. Yes. 6 Q. After '72, where did you go? 7 A. I went to the Parathion 8 Department. OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036889 9 Q. What was your job there? 10 A. Relief chief operator and 11 then chief operator. 12 Q. Until when? 13 A. I believe it was '76. 14 Q. Okay. Then where did you go? 15 A. I went to production foreman 16 in the Parathion Department. 17 Q. Okay. 18 A. In one part of the Parathion 19 Department. It had two parts at that 20 time, what they called the intermediate 21 side and the finished goods side. And I 22 was in the finished goods part of it. 23 Q. Okay. I am going to come 0014 1 back and ask you what your duties were, 2 but go ahead and tell me what your next 3 job description was after that. 4 A. First level supervisor. 5 Well, production foreman, and later they 6 changed that to what they call a first 7 level supervisor. It was the same job, 8 different title. 9 Q. Still there in the same part 10 of the Parathion Department? 11 A. Yes. OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036890 12 Q. And then your next job after 13 that? 14 A. It would have been in the 15 shipping department. 16 Q. Okay. 17 A. That was in, I want to say 18 '86,1 think, when Parathion shut down, 19 until I retired. 20 Q. When did you retire? 21 A. '95. 22 Q. '95. Okay. So you had 23 thirty-four years? 0015 1 A. Yes. 2 Q. Going back to finished 3 production supervisor, what was that 4 job? What were your day-to-day duties? 5 A. Scheduling production, 6 responsible for safety. 7 Q. In the whole plant? 8 A. No, just for that area, 9 the part that I was responsible for. 10 Q. Okay. I've got you. 11 A. And by safety, I mean safety 12 procedure, safety meetings, monthly 13 safety meetings, making out weekly work 14 schedules, vacation schedules, coordinate OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036891 15 work with all the shifts. 16 Q. And then your job in 17 shipping, what were your day-to-day 18 duties in that? 19 A. Responsible for loading 20 finished goods, unloading raw materials, 21 packaging finished goods, either in 22 drums, or if it flaked in bags, you know, 23 if it was in the flaking process, getting 0016 1 shipments out, getting orders, you know, 2 seeing that orders got together and got 3 shipped out. 4 Q. Is this plantwide? 5 A. No, the shipping department 6 was a department by itself. 7 Q. But I mean, you were shipping 8 -- you were dealing with everything that 9 the Anniston plant made? 10 A. Right. Right. 11 Q. I mean, it wasn't just 12 Parathion or biphenyl or -- 13 A. At the time I was in 14 shipping, Parathion was out of business. 15 They had closed down. That warehouse 16 wasn't used any more. 17 Q. Did you have anything to do OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036892 18 with the landfill? 19 A. No. 20 Q. Mr. Sims told us that 21 shipping dealt with the landfill, but 22 that may have been before '86. 23 A. They did. They did at one 0017 1 time when all those departments were 2 running, but after they shut down, we no 3 longer used that landfill. 4 Q. So as of'86, y'all weren't 5 putting any new things in the landfill to 6 the best of your recollection? 7 A. Right. I'm not exactly sure 8 which year they quit using it, but it was 9 right around in that time. 10 Q. But in any event, you never, 11 through your thirty-four years, you never 12 had any official involvement with the 13 landfill? 14 A. No. 15 Q. Did you ever go to the 16 landfill for any reason? 17 A. No. 18 Q. How did those Delaware boys 19 spend a day and a half asking you 20 landfill questions? OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036893 21 A. It wasn't just landfill 22 questions. 23 Q. I'm teasing. Going back now, 0018 1 to when you started in the Aroclor 2 Department, can you briefly describe what 3 your specific job was as an operator? 4 A. Well, I worked in -- they had 5 different jobs in that area. One was 6 chlorinators. I operated chlorinators. 7 And chlorinators is where you charge them 8 with biphenyl. You introduce chlorine to 9 them under -- you know, you had 10 controlled conditions, temperature and 11 all of that. And then you would sample 12 them and when they were at the right 13 gravity, you would pump them into what we 14 called a blow tank or holding tank. 15 And then there, they were run 16 through what we called the Aroclor 17 still. It was a distillation process 18 where the material was distilled. And 19 then it was put in storage tanks and then 20 either drums or loaded in tank cars or 21 tank trucks. 22 Q. Let's walk back then, 23 starting with the chlorinators. Can you OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036894 0019 1 describe the chlorinator for somebody 2 that never saw one? 3 A. Well, it was a round vessel, 4 tall, about three levels tall. 5 Q. By three levels, you mean 6 three stories tall? 7 A. Uh-huh (indicating 8 affirmatively). 9 Q. Okay. 10 A. And a story may not be eight 11 foot like a house, but it was a tall, 12 round piece of equipment. 13 Q. How big around would it be? 14 Or let's talk about diameter, I guess. 15 A. Five foot, four to five foot. 16 Q. If you were to stand up 17 inside it and stretch your arms out, 18 could you touch the sides? 19 A. It would be hard to stand up 20 inside of it, much less stretch your 21 arms. 22 Q. So it would look kind of tall 23 and thin? 0020 1 A. It had a pump at the bottom 2 and you circulate the material out the OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036895 3 bottom back up into the top. 4 Q. Was there a pipe on the 5 outside of it going up to the top? 6 A. Come to your pump and out of 7 your pump up to the top, back into the 8 top of it. 9 Q. Okay. 10 A. During the time, there would 11 be certain ladles you would be adding 12 chlorine to it, which that raised the 13 gravity. The longer your chlorination, 14 the higher your gravity became. It 15 depended on what you made, which product 16 as to how long you chlorinated it. 17 Q. How would you decide it was 18 to the right level of chlorination, 19 saying you were making 1260? 20 A. You catch a sample and cool 21 it to a certain temperature and put a 22 hydrometer in it and check your gravity. 23 When you got to a certain gravity, you 0021 1 cut the chlorine off and then you'd pump 2 it to one of the tanks to be distilled. 3 Q. Mr. Sims told us, I think, 4 there were eight chlorinators, is that 5 right? OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036896 6 A. We had what we call four 7 batch chlorinators and we had four that 8 was a continuous chlorination system. 9 You'd feed into one, feed some chlorine 10 to that and it overflowed to another one 11 and you feed chlorine to another one, you 12 know, at different stages. 13 Q. That didn't come until later, 14 though, right? 15 A. It was there when I went to 16 work there. 17 Q. The continuous chlorinators? 18 A. Uh-huh (indicating 19 affirmatively). 20 MR. COX: You need to say 21 "yes." 22 A. Yes. 23 Q. Okay. What was the big 0022 1 expansion in '69, then? What was added? 2 A. The best I recall, they 3 added two chlorinators and one more 4 still, Aroclor still. 5 Q. Added two -- 6 A. Two chlorinators. 7 Q. -- continuous chlorinators, I 8 assume? OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036897 9 A. No, these were batch. 10 Q. They added two batch in '69? 11 A. (Witness nods head.) 12 MR. COX: You need to answer 13 out loud. I know it's a little unusual, 14 but she's trying to take down every word 15 Q. Were they larger than the old 16 batch chlorinators? 17 A. They were. They were larger. 18 Q. Substantially larger? 19 MR. COX: Object to the form. 20 Q. Were they a whole lot larger? 21 MR. COX: Same objection. 22 A. I don't remember how much 23 larger. 0023 1 Q. Going back to before the 2 expansion, how many operators were there 3 on a shift before the expansion? 4 A. In the Aroclor Department, 5 there was three operators and a chief 6 operator. 7 Q. And then after the expansion 8 when the two new chlorinators were added, 9 how did the shift change? 10 A. I believe they increased it 11 by one operator. OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036898 12 Q. So they still had one chief 13 operator and instead of three operators, 14 you now had four operators on duty? 15 A. I believe that's correct. 16 Q. The stills, could you 17 describe the stills, also? 18 A. You had a still that you, or 19 a vessel, a large vessel that you would 20 pump your material into. And then you 21 would put it under vacuum and heat it. 22 And as it heated, it would start 23 distilling. You had a -- your material 0024 1 circulated through a coil that had a fire 2 box on it. It went inside of a fire box, 3 and you would light your burners, turn 4 your burners on and that's how it heated 5 up. 6 Once it reached a certain 7 temperature, it would distill through a 8 condenser. You had water on a condenser 9 and it would cool it back down and then 10 it would go into a receiver, what we 11 called a receiver. Then once that 12 receiver was full, we would pump it over 13 into another tank. 14 Q. Okay. OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036899 15 A. In that tank, we would add 16 what we called earth. It was a 17 powder-like material that we would add to 18 help with filtering it. We would agitate 19 it so long and then we would filter it 20 through a filter to take this earth out 21 of it. 22 Once it was filtered, we 23 would sample and the sample would come 0025 1 back good from the lab on it, we would 2 pump it into the storage tank. And from 3 there, we would load tank cars or tank 4 trucks, or drum it out, whichever, ever 5 how they were going to package it. 6 Q. And the operators were 7 involved in all of those processes? 8 A. Some operators could run what 9 I call all of the jobs. You had a 10 chiorinator operator. You had what we 11 called an acid operator. 12 Q. Acid operator? 13 A. We made muriatic acid. 14 Q. Okay. 15 A. And the HCL that came off the 16 chlorinating process, then water was 17 added to it and we made a muriatic acid, OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036900 18 which we sold. Then you had your Aroclor 19 still operator. You know, some of them 20 could run all, most all of them could run 21 all the different jobs. 22 Q. Where did the HCL off-gas 23 come from? 0026 1 A. It come off the chlorinators. 2 Q. Is that what you would mix 3 with the water to make the muriatic acid? 4 A. Right. 5 Q. When you had -- well, was 6 there excess HCL off-gas? 7 MR. COX: Object to the form. 8 A. What I recall is all of it 9 went to what we called a tower. And 10 that's where the water was added to it 11 and put in storage tanks. 12 Q. Okay. 13 A. I don't remember excess. 14 Q. I probably asked it wrong. 15 Was there excess water coming out of 16 that process? 17 MR. COX: Same objection. 18 A. I think so. 19 Q. Where did that water go? 20 A. Into a limestone pit to OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036901 21 neutralize it. 22 (Whereupon, a discussion was held 23 off the record.) 0027 1 (Whereupon, a brief recess was 2 taken.) 3 4 (Whereupon, Plaintiffs Exhibits 1-2 5 were marked for identification and 6 same are attached hereto.) 7 8 Q. Mr. Walker, I have got two 9 pictures, here. One of them is a smaller 10 scale to where you can see more land 11 around the plant. And then this one lets 12 you see the plant facilities a little bit 13 better (indicating). 14 MR. COX: Why don't we let 15 him see the original? 16 Q. We'll let you look at the 17 original, so you can get a better 18 resolution. I went through this a little 19 bit with Mr. Sims, so I have kind of got 20 an idea, but since you were there a whole 21 lot longer than he was, I think you will 22 be able to give me a better picture of 23 the Aroclor Department itself. OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036902 0028 1 MR. WRIGHT: Let's orient 2 these. Buddy, you are saying this would 3 be north, about like that (indicating)? 4 MR. COX: No, that's north 5 (indicating). 6 MR. WRIGHT: Okay. And here 7 would be -- 8 MR. COX: This is south, so 9 north would be here (indicating). 10 MR. WRIGHT: Now I'm 11 confused. 12 MR. COX: This is the same 13 orientation (indicating). 14 MR. WRIGHT: All right. 15 Q. Can you point to the Aroclor 16 Department on Exhibit 1? And Exhibit 1 17 is the larger scale. 18 MR. COX: That's the large 19 warehouse. 20 A. Right, and this was -- 21 MR. COX: Building 28. 22 A. Right, and this was the 23 Aroclor Department (indicating). 0029 1 Q. (BY MR. WRIGHT:) That would 2 be right in here? OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036903 3 A. Uh-huh (indicating 4 affirmatively). 5 Q. I am going to circle it in 6 red, the Aroclor Department. And, then, 7 Buddy mentioned this building here was 8 called building 28 (indicating)? 9 A. Uh-huh (indicating 10 affirmatively). 11 MR. WRIGHT: Was it called 12 anything else, Buddy? 13 MR. COX: That was the 14 designation. 15 A. Building 28. 16 Q. And then this big white 17 building here was the warehouse? 18 A. That's the warehouse, yes. 19 Q. Was this only the Aroclor 20 warehouse when the Aroclor Department was 21 operating, or did they use it for other 22 things as well? 23 A. It was mostly the Aroclor 0030 1 warehouse. They may have stored some 2 other material in it at one time. 3 Q. And then this building here, 4 this white building to the west of the 5 Aroclor Department, what would that have OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036904 6 been? 7 A. That would have been the 8 Chlorine Department. 9 Q. Okay. And then this big 10 white building to the northwest? 11 A. That was the Parathion 12 warehouse. 13 Q. And where was the Parathion 14 production facility? 15 A. Okay. It was right here 16 (indicating). 17 Q. Just south of the warehouse? 18 A. Yes. 19 Q. Where was the biphenyl 20 manufacturing? 21 A. At one time, part of it was 22 in here and then they built a new unit, 23 they called it. We called it a tube unit 0031 1 or a tubular unit. 2 Q. So at first it was part of 3 the Aroclor Department? 4 A. Right, it was the other end 5 of the building. 6 Q. Okay. 7 A. The Aroclor Department was 8 this way and what we referred to as lead OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036905 9 pot units or biphenyl stills was in this 10 area (indicating). 11 Q. Okay. 12 A. Then they built a tubular 13 unit up here sometime in the middle 14 sixties and they came back later and 15 built a second unit up there. They had 16 two units at one time. 17 Q. Let me describe this for the 18 record. The original location of the 19 biphenyl or the lead pot area was in the 20 south part of what we have got marked as 21 the Aroclor Department? 22 A. That's correct. 23 Q. And then, later on,they 0032 1 moved it a little bit to the southeast of 2 the Aroclor, what we have got marked as 3 the Aroclor Department and built a 4 tubular unit there? 5 A. Yes. 6 Q. Since this picture was taken 7 in '69, is that probably what we are 8 looking at right here (indicating)? 9 A. That would be the tubular 10 unit, yes. 11 MR. COX: That's due south of OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036906 12 building 28. 13 Q. Okay. Due south of building 14 28 is the new biphenyl production 15 facilities. When did they build those? 16 A. One of them was built in the 17 middle sixties, and I'm not sure of the 18 exact year. '65,'66. 19 Q. Okay. 20 A. It may have been '64, but in 21 the middle sixties. 22 Q. Okay. 23 A. I'm not sure when the second 0033 1 unit was put in. 2 Q. What are these tanks down 3 here to the south of the Aroclor 4 facility? 5 MR. COX: These, the larger 6 ones? 7 Q. The big ones, but also those 8 smaller ones there between the big ones 9 and the Aroclor Department. 10 A. We had some acid storage 11 tanks right in this area here, muriatic 12 acid storage tanks. And we had biphenyl 13 storage tanks behind those and when they 14 built the new tubular units of the big OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036907 15 tanks up here, one of them was a biphenyl 16 storage tank. The small tanks just to 17 the north of those, one or two of them 18 were benzene storage tanks where we would 19 unload benzene cars. I don't remember 20 what the others may have been. 21 Q. All right. Where were the 22 limestone pits that you talked about? 23 A. One of the limestone pits I 0034 1 remember before the tubular units were 2 built set in this area. Then, when they 3 built this unit, I believe they moved 4 them down, as best I recall, down in this 5 area. 6 Q. That kind of gully-looking 7 area where you have got your pen right 8 now? 9 A. Right. 10 Q. Mr. Sims thought that was 11 what y'all called Clegorn Lake. Does 12 that ring a bell? 13 A. That's not what I recall 14 being Clegorn Lake. 15 Q. What do you recall being 16 Clegorn Lake? 17 A. This area right here OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036908 18 (indicating). 19 Q. Okay. I was going to ask you 20 what that area is. 21 A. That was Clegorn Lake, what 22 that was referred to (indicating). 23 Q. Okay. Let's mark these 0035 1 then. I am going to circle this area and 2 call it limestone pits or limestone pit. 3 A. Okay. 4 Q. And then I am going to circle 5 this area and call it Clegorn Lake. That 6 makes more sense, then. Mr. Sims was 7 kind of unsure. Okay. What was Clegorn 8 Lake? 9 A. It was a pit where we would 10 pump bottoms off of our Santowax still 11 and bottoms off of the biphenyl still or 12 the biphenyl distillation process. The 13 line from the Santowax process went 14 across and tied into this line that came 15 from the biphenyl still up here. 16 Q. Okay. 17 A. I believe on the Santowax 18 still they would run about three batches, 19 distill three batches, which was a batch 20 charge still. You would pump to a OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036909 21 certain level in there, then you'd 22 distill that out. Then you'd charge back 23 to a certain level. Once you had done 0036 1 that three times -- 2 Q. You had to clean it out? 3 A. -- the impurities that come 4 out of the distillation were pumped over 5 to this lake (indicating). 6 Q. Is this what later became 7 known as the west end landfill, or is 8 that a separate area? 9 A. No, that was never a 10 landfill. 11 Q. Where was what is now called 12 the west end landfill, if you know? 13 A. I'm not familiar with -- 14 Q. With that term? 15 A. -- anything referred to as a 16 west end landfill. 17 Q. Okay. 18 A. The only landfill I'm 19 familiar with was the one across Highway 20 202. 21 Q. What is this area, all of 22 these little humps here (indicating)? It 23 looks like something is dumped there, but OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036910 0037 1 I can't tell what it might have been. 2 A. I don't recall anything being 3 there, other than just open area, you 4 know, open field. 5 Q. Doesn't it look like some 6 dirt work has been done there to you, if 7 you look up close? 8 A. It's difficult for me to tell 9 looking down on it. 10 Q. Yeah. 11 A. And I'm not familiar with 12 anything being in that area. 13 Q. What happened to Clegorn 14 Lake? I mean, it's not there any more, 15 right? 16 A. I don't know. 17 Q. That's a bad question. You 18 don't know whether it's still there? 19 A. I thought when I left they 20 were still using it to pump some bottoms 21 in, but I don't know that. I have been 22 away from that area for so long, I'm not 23 sure if they were still using that or 0038 1 not. 2 Q. Is this the Alabama Power OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036911 3 substation over here (indicating)? 4 A. Yes, this is the substation. 5 Q. Where did the still bottoms 6 from the Aroclor stills go? 7 A. The best I recall, we drawed 8 them out in drums. Then they were left 9 to set until they become hard, and they 10 were solid and they carried them to the 11 landfill up here and disposed of them 12 (indicating). 13 Q. Did you ever have to clean 14 out the stills or wash them out? 15 A. Do what we call draw bottoms. 16 Q. Just drained them? 17 A. Drain the impurities. Where 18 they pumped them to Clegorn's Lake, these 19 were dropped into drums. We had areas 20 under the stills where you could drain 21 them into drums. After they set and 22 cooled off, they got hard. Some of them 23 got -- I think one of them they crushed 0039 1 or ground up and packaged and shipped to 2 somebody. I don't know what they used it 3 for. 4 Q. Okay. 5 A. That would have been the ones OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036912 6 off the, what we called solid Aroclors. 7 Then the ones off the liquid Aroclors, 8 you put them in a drum and then they get 9 cold and stiff and hard, you know. 10 Again, depending on what the gravity of 11 the material was that you made. 12 Q. Where did they grind them up? 13 A. They had a place in one of 14 the old lead pot areas. What they would 15 do, they'd dump them out on the floor and 16 just bust them up with a little of 17 hammer. They used like the air hammer 18 type things or piece of flat plate on the 19 bottom of a rod or something, you know, 20 and just break them up in small pieces. 21 And then they would shovel them through a 22 screen. 23 Q. By hand, you mean? They 0040 1 would pound them up by hand? 2 A. By hand. 3 Q. Who did that? 4 A. People in the labor group. 5 We had a group they called Aroclor labor, 6 which done a lot of that type of work. 7 Q. Were they the ones that 8 primarily did the cleaning up when there OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036913 9 were spills and leaks and things? 10 A. Well, no, they primarily 11 done the cleaning of tank cars. They 12 would help operators draw bottoms on the 13 stills when we would draw them. I 14 mentioned flaking. They done some of the 15 flaking. 16 Q. Does flaking differ from what 17 you were just describing, the pounding 18 up? 19 A. Yes, the flaking. When we 20 flaked, we flaked a biphenyl, and this 21 was Aroclor before it was chlorinated. 22 They would flake the biphenyl and then we 23 flaked a material we called Santowax. 0041 1 They'd flake it and then we'd flake a 2 solid Aroclor, one of the solid Aroclors. 3 I want to say it was a 5460, they flaked 4 it. It was put in bags. All of those 5 were bagged. 6 Q. Where was that done, the 7 flaking operation? 8 A. It was done on the bottom 9 floor in the Aroclor department, what we 10 called the bottom floor, ground floor. 11 Q. Okay. OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036914 12 A. And the stills and all were 13 set out on the next level. So they were 14 able to drum out downstairs, what we 15 called downstairs, and do the flaking 16 down there, too. 17 Q. How did they actually flake 18 it? Did they have a machine like a 19 grinder or something? 20 A. No, you had like a big round 21 drum that turned. 22 Q. They heated it? 23 A. You had a pan in the bottom. 0042 1 You would feed that material into that 2 pan. As that drum would turn, it would 3 flake that material. And on the Aroclor 4 flaking, it went into a hopper. And they 5 would bag out of that hopper. 6 On the Santowax, they would 7 put a bag under a small chute off of that 8 flake and it would flake into that chute 9 and into the bag. And they would put it 10 in the bag and weigh it and tie it up and 11 stack it. 12 Q. Where did it go to get 13 shipped out? 14 A. Some of it went, the best I OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036915 15 remember it went to this warehouse here 16 (indicating). 17 Q. Okay. 18 A. They did carry some to this 19 warehouse and store it. It would be 20 stored and possibly shipped out from down 21 there. I wasn't involved in any of the 22 shipping part of it at that time. I 23 didn't go into the shipping department. 0043 1 Q. What is this here, these 2 tanks next to the big warehouse 3 (indicating)? 4 A. Okay, in one of the 5 expansions, we had a -- I'm not sure how 6 many tanks, two or three storage tanks 7 here (indicating). When we added, when 8 we had the expansion and increased 9 Aroclor production, we built a new tank 10 farm here (indicating) and they would 11 pump material into this tank farm and 12 then from here, it would go to this 13 warehouse and be drummed out. The 14 different Aroclors, of course, you had 15 different storage tanks for. 16 Q. Okay. 17 A. But that was the storage. OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036916 18 That was just an additional tank farm to 19 the small tank farm we had on this side 20 of the road at one time. 21 Q. Now, you were there in the 22 lead pot days some, weren't you? 23 A. A little while. 0044 1 Q. Describe that process for me, 2 if you would. 3 A. Ooh. 4 Q. To the best of your ability. 5 A. You would pump benzene. 6 Benzene would be fed into them and you 7 had lead in there. I'm not real sure how 8 the system worked, but you had lead in 9 the lead pot unit. 10 Q. Molten lead, right? 11 A. It was sort of a distillation 12 process in itself, but it was an old 13 system. I don't know how long it had 14 been in. But you had a furnace where you 15 would heat it, like most of your 16 distillation process. It had a 17 condenser, you know. You would take the 18 impurities out. You would make the 19 biphenyl and it would be put into -- it 20 would go to a catch tank. And then once OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036917 21 it was to a certain level, it would be 22 pumped to a storage tank. And I'm not 23 sure exactly the internal works of it or 0045 1 none of that. In itself, it was just an 2 old type distillation process. 3 Q. Where was it vented, or how 4 was it vented? 5 A. I don't know. 6 A. That's been so long, I don't 7 remember how that system was. 8 Q. Okay. 9 A. Because it was only there for 10 a few years and then they built the new 11 furnace and all those were tore out and 12 taken out. 13 Q. How was the Aroclor, the 14 chlorinators, how were they vented? 15 A. They were vented to the acid 16 plant. They went to the acid plant. 17 That's where we made our muriatic acid. 18 Q. That's the HCL off-gas we 19 were talking about? 20 A. Right, HCL. 21 Q. And, then, that's how we 22 started this whole thing. The water -- 23 A. The HCL gas went up to a OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036918 0046 1 tower. 2 Q. Can you point that tower 3 out? Can you see it? 4 A. I can't see it on there. 5 Q. Was it inside the building? 6 A. No, it was outside, around in 7 this area (indicating). 8 Q. You are pointing just-- 9 let's see. Let me get oriented. You are 10 pointing just to the south of the Aroclor 11 facility? 12 A. Right.That's correct. 13 Q. Okay. 14 A. You see these tank cars here 15 at the end of this? 16 Q. Yes. 17 A. This is where the acid was 18 loaded in the tank cars. 19 Q. Okay. 20 A. It sat right across. The 21 storage area for it and all sat right 22 across the road from the loading area. 23 Q. Muriatic acid. Okay. And 0047 1 that tower was where? 2 A. It was located, it would have OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036919 3 been south of the Aroclor/Biphenyl 4 Department. 5 Q. Just south of where these 6 tank cars are? 7 A. Right. 8 Q. Okay. 9 A. It was in the areawhere 10 those biphenyl storage tanks were. They 11 were all right in there together. 12 Q. Okay. And, then, the water 13 coming off of that was routed underground 14 over here to the limestone pits? 15 A. That's correct. 16 Q. And, then, from the limestone 17 pits, it went into this drainage -- it 18 went under the road? 19 A. That's correct. 20 Q. Off the plant property and 21 into this drainage ditch down here 22 (indicating)? 23 A. Right. 0048 1 Q. And then on down into Snow 2 Creek? 3 A. I guess that's where it went. 4 Q. Can you tell where Snow Creek 5 hits? Is it on that picture? OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036920 6 A. I don't know where Snow Creek 7 starts. 8 Q. Okay. 9 A. I'm not sure where they 10 designated the starting point. 11 Q. Okay. 12 A. But I know it drained out of 13 the plant, left out of the plant and went 14 under the road. 15 Q. Now, is that the same place 16 where the storm water was routed? The 17 storm water runoff, I mean. 18 A. The only storm water sewer 19 that I'm familiar with was over in this 20 area that went down somewhere 21 (indicating). 22 Q. You are pointing from the 23 chlorine area, from around the chlorine 0049 1 area? 2 A. Well, they had run-off water 3 here (indicating), and I'm not sure, I 4 know it run in -- in other words, they 5 had sewers in the roadway where water 6 could run in. 7 Q. Right, right. 8 A. But I'm not sure how the OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036921 9 sewers ran underground and to what point 10 they went out of the plant. Ido 11 remember we had one in this area 12 (indicating), a storm sewer that went 13 down, if I can find it on here, and 14 exited the plant somewhere down in here 15 (indicating). 16 Q. To the -- let's see which 17 direction that would be. 18 A. Well, it would have been 19 north of the plant. 20 Q. To the north of the plant? 21 A. Right. 22 Q. Okay. Now the Aroclor 23 Department had sewers or drains, right? 0050 1 A. Right. 2 Q. Were those drains from the 3 Aroclor plant routed to this limestone 4 tank? 5 A. The best I remember, they 6 were routed through this limestone pit. 7 Q. Do you know if it was the 8 same pipes as the HCL water? 9 A. I don't know. 10 Q. But to the best of your 11 understanding, they both ended up in the OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036922 12 same place? 13 A. That's correct. 14 Q. Now, who was responsible for 15 cleaning up the spills and the leaks and 16 the things like that? 17 A. If you had a spill or a 18 leak, the operator on the j ob was 19 responsible for it. 20 Q. Okay. 21 A. Now, other operators would 22 help him. 23 Q. I was going to ask if they 0051 1 helped. 2 A. The other operators, right, 3 they would join in and help, you know, to 4 get it cleaned up. 5 Q. Where did most of the leaks 6 and the spills come from, if you can 7 quantify it? 8 MR. COX: Object to the form. 9 A. All of your equipment had 10 pumps on it and had what we called a 11 packing gland. In other words, you would 12 put packing in there. 13 Q. Could you describe that? Mr. 14 Sims tried to describe it, and to be OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036923 15 honest, I just didn't quite get it. 16 Maybe you can describe it better since 17 you were there longer. 18 A. A packing gland you mean? 19 Q. Yeah, the pump and how the 20 packing gland fit in. 21 A. You had a motor. Your motor 22 sat at the back of the pump. 23 Q. Can you draw it. Would you 0052 1 mind drawing it? 2 A. I can try to draw it. I'm 3 not an artist. 4 Q. Why don't you just try it. 5 Nobody is going to grade you on it. 6 7 (Whereupon, a discussion was held 8 off the record.) 9 10 (Whereupon, Plaintiff s Exhibit 3 11 was marked for identification and 12 same is attached hereto.) 13 14 MR. WRIGHT: Let's go back 15 on. 16 A. If this were your pump, you 17 would have material that would come into OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036924 18 what we call the front of the pump. 19 Q. Okay. 20 A. You had a volute in there 21 that had veins on it and as that pump 22 turned -- the material would come in the 23 center and as that pump turned, it would 0053 1 force it out wherever it discharged, 2 whether it be the top or the side or 3 whatever. 4 Q. Right. 5 A. You had your motor that sat 6 here and you had a shaft that went into 7 your pump to turn that -- 8 Q. Turn the impeller? 9 A. Turn the impeller. 10 Q. Okay. 11 A. Here you had a packing gland. 12 And what it was, it was just a piece of 13 metal that would be shaped -- again, this 14 might not be exactly right, but your 15 shaft would be in the center of that. 16 You would have what I call a stud that 17 went, you know, here with nuts on it. 18 Q. Right, that bolted on? 19 A. You could loosen those, slide 20 that packing gland out, and you had, of OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036925 21 course, different pumps that carried 22 different size packing, but it was just a 23 fiber-type material. Whatever pieces you 0054 1 needed to go around that shaft, you would 2 put them in. 3 Q. And it was a fabric or fiber? 4 A. Fiber/fabric of type 5 material. It may have had some graphite 6 mixed in with it. We just called it 7 packing. 8 Q. Okay. 9 A. Whatever size packing, you 10 might put what we call four or five rings 11 of packing you could put in there, but 12 where it made a ring and come together, 13 you would alternate where your joints 14 were, you know. You just put packing in 15 there and you would tighten these up. 16 Over a period of time, your 17 packing would wear out. You might 18 develop a little leak. We had catch pans 19 under these pumps to catch leaks. And 20 you was always going out into the 21 department around catching samples and 22 you would always check for leaks to see 23 if your packing leaked, and if it was, OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036926 0055 1 you tightened it up a little bit. 2 And if the packing got bad, 3 you could add a ring of packing, or you 4 may have to shut it down until 5 maintenance come the next day and let 6 them take all the old packing out and put 7 new packing in. 8 Q. So maintenance was 9 responsible for that? 10 A. Maintenance and operators 11 both. On the off shifts or on the 12 weekend when maintenance wasn't there, 13 operators could add what we called a ring 14 of packing. We could add a ring of 15 packing. 16 Q. But you wouldn't do a 17 complete job? 18 A. You wouldn't do a complete 19 packing job on it, because they had 20 special tools to reach up and pull the 21 old packing out with and put new packing 22 in. 23 But those catch pans, if it 0056 1 had a drip, it would drip in that catch 2 pans. We would empty those into one of OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036927 3 the buckets where we sampled or either 4 over to the rework drum that we would 5 have, you know, where we could pour the 6 material back in. 7 But, you know, you could have 8 leaks there. You may have a sample valve 9 that might leak sometime. But, again, 10 there was a bucket placed under it. We 11 had a lot of pumps back then that carried 12 packing. And they were bad to leak at 13 times. 14 Q. How often would they have to 15 be completely reworked? I mean, monthly 16 or -- 17 A. I don't know. A lot of it 18 depended on what kind of shape the shaft 19 was in. If a shaft was bent, it might 20 wear the packing out, or if it was rough, 21 you know, had rough edges or something, 22 it could. But, normally, it would run 23 several days without having to even add 0057 1 any or tighten up on it. But over a 2 period of time, you would just have to 3 replace it. 4 Q. What did maintenance do with 5 the old packing? OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036928 6 A. They put it in trash drums. 7 Q. Okay. 8 A. Or carry it back to the shop, 9 maybe throw it in trash drums there. 10 They had some responsibility for cleaning 11 up wherever they worked, too, and they 12 would pick it up and carry it back with 13 them. Gaskets, things like that, they 14 would carry them back to their shop. 15 Q. Okay. Now, that's the 16 pumps. Where else would you get the 17 leaks from? You mentioned your sample 18 valves. 19 A. Sample valves? You could get 20 -- you know, one of them could leak a 21 little. Of course, you could have a line 22 rupture, you know. Or you could have a 23 gasket, maybe a gasket blow out. 0058 1 Q. I was going to ask you where 2 the gaskets were. 3 A. They were in flanges where 4 the pipes joined together. It wasn't 5 solid welded pipe, you know. 6 Q. You had joints? 7 A. They had joints. 8 Q. And the gaskets at the j oints OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036929 9 would sometimes go bad? 10 A. It could. 11 Q. Now, who replaced them? 12 A. Maintenance. 13 Q. Maintenance again? 14 A. Maintenance replaced them. 15 Q. I assume the same thing with 16 the gaskets, they would do the same thing 17 with them that they did with the old 18 packing? 19 A. Right. 20 Q. How many drains were there in 21 the floor of the Aroclor Department? Do 22 you have any idea? 23 A. I have no idea. 0059 1 Q. Were there a lot of them? 2 A. No. 3 Q. Is there any way you can try 4 to describe it? I mean, you were there 5 and I wasn't. Was there a drain every 6 six feet or every ten feet or -- 7 A. The only drain I recall being 8 on the floor in the Aroclor Department, 9 and I say in the floor, I am talking 10 about the bottom floor. 11 Q. That's what I'm talking OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036930 12 about. 13 A. It was probably where a sewer 14 passed under the floor, but it wasn't a 15 grated drain. It had a solid metal plate 16 over it. It wasn't a drain like we think 17 of a drain having a grate or just a grill 18 or something. It was a solid metal plate 19 that laid over it. That's the only one I 20 remember being in the bottom floor of 21 this building. 22 Q. I assume you would wash down 23 the floor or equipment even from time to 0060 1 time? 2 A. We washed down the floor out 3 in this area, and the chlorinator area. 4 We didn't in the still room, what I call 5 the still room, where they done the 6 flaking and all of that. We would sweep 7 up, and sometimes if material built up on 8 the floor, we might scrape it up, take a 9 scraper and scrape it up. But it wasn't 10 a liquid material. 11 Q. You never steam cleaned it in 12 there? 13 A. I don't recall ever steam 14 cleaning it. OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036931 15 Q. Okay. In the chlorinator 16 area, how many drains were there? 17 A. There was --1 will see if I 18 can kind of draw this. 19 Q. Okay. 20 A. You had a drain with grating 21 over it all the way across here 22 (indicating). And then you had -- I'm 23 thinking you had a little drainage -- 0061 1 Q. All the way around? 2 A. -- all the way around this 3 part of it. I'm not sure where it went 4 out. This pad in this area sat up off 5 the floor six inches, eight inches, 6 something like that, with this drainage 7 ditch below it with grating over it. And 8 in the middle of it, you had an indention 9 or a drainage like that went to either 10 side with grating over it. And then when 11 you would wash down,it would wash into 12 this part of it. 13 Q. Let me labelsome of these 14 things before we forget them. This is 15 the pump (indicating). This is the motor 16 of the pump (indicating). 17 A. Yes. OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036932 18 Q. This is the shaft 19 (indicating). This is the-- 20 A. That's what I call the pump, 21 the pump housing. 22 Q. The pump housing? 23 A. You've got the impeller 0062 1 inside of it. 2 Q. Well, no, I'm talking about 3 this right here (indicating). This is 4 where the packing was? 5 A. That would be where the 6 packing was, your packing box, I guess 7 they would call it. 8 Q. Or sleeve? 9 A. Packing gland. 10 Q. Packing gland is what you 11 called it to begin with. So let's -- 12 A. Okay. Packing gland. 13 Q. And this is a blow-up of 14 that, an expansion? 15 A. That's what I would call it, 16 yes. 17 Q. And this is the chlorinator 18 area (indicating)? 19 A. That's correct. 20 Q. I assume these eight things OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036933 21 are the chlorinators (indicating)? 22 A. Eight chlorinators 23 (indicating). 0063 1 Q. And, then, I guess we'll just 2 call this a drain (indicating)? 3 A. That's what it was. It was 4 just a drain off of this area. 5 Q. Okay. I will cross hatch the 6 drain areas. Was it around this side as 7 well (indicating)? 8 A. No, it was a walkway that 9 went this way (indicating). 10 Q. So, it was around three sides 11 and then down the middle? 12 A. That's right. 13 Q. But you don't know where 14 those drains emptied? Was it into the 15 sewer system? 16 A. My understanding, it was in 17 the sewer system somehow that went to the 18 limestone pit. 19 Q. The same place we were 20 talking about earlier? 21 A. Correct. I don't know the 22 exact pattern that it followed to get 23 there. OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036934 0064 1 Q. I've got you. Was this area 2 washed down every day (indicating), the 3 chlorinator area? 4 A. Supposedly every shift. 5 Q. So three times a day? 6 A. Every operator would wash 7 down at the end of his shift. 8 Q. Okay. 9 A. Clean up his area, be sure 10 all of his drip pans and sample buckets 11 were emptied, then wash the area down. 12 Q. And that's the way it was 13 from '61 to '72, the whole time? 14 A. The best I remember, that's 15 how it was. 16 Q. Now, Mr. Sims mentioned that 17 at some point y'all got new pumps. Do 18 you remember that? Or he thought you got 19 new pumps. 20 A. I don't remember. I don't 21 recall. 22 Q. The best of your recollection 23 -- well, you don't remember getting new 0065 1 pumps during that period? 2 A. I don't, no. OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036935 3 Q. Were there different kind of 4 pumps on the '69 expansion? 5 A. I don't recall. 6 Q. Okay. 7 A. And the reason I don't 8 recall is I didn't operate the pumps 9 after I went to chief operator. The 10 operators operated the pumps, and I 11 wasn't as closely involved, you know. 12 Q. After you went to chief? 13 A. After I went to chief. 14 Q. Now, let me just ask you 15 this and then we'll take a little break. 16 How did you get word that the Aroclor 17 Department was going to be shut down? 18 A. I believe it was through a 19 plantwide meeting. Of course, we had 20 known for a while that sales were down. 21 And we had really changed our mode of 22 operation there toward the end before it 23 completely shut down, where we did run 0066 1 seven days a week, three shifts a day. 2 Toward the end before it shut 3 down, we would only run like ten days 4 straight and then we would shut it down 5 for four days. The operators would be OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036936 6 off for four days and then they would 7 come back and start the department back 8 up and we would run for ten days and shut 9 down for four days. And we got word that 10 the department would shut down, we 11 wouldn't be making Aroclor any longer. 12 Q. Do you remember the meeting 13 or are you just thinking that's what 14 happened? 15 A. No, I don't remember 16 specifically. 17 Q. Do you remember who made the 18 announcement, what person made the 19 announcement? 20 A. No, I don't. 21 Q. Do you remember what they 22 said when they made the announcement? 23 A. No, I think I was more 0067 1 concerned about where I was going or if I 2 was going to have a job. I don't 3 remember exactly the time they told us or 4 how it was told, or even who told us. 5 Q. All right. What was the 6 reason given that they told you they were 7 shutting it down? 8 A. I don't remember exactly the OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036937 9 reason, if it was for business reasons. 10 I'm not positive. 11 Q. Was it for environmental 12 reasons or pollution reasons? 13 A. I don't recall them saying 14 that was the reason. 15 Q. Was that what y'all 16 understood around the plant? 17 A. I didn't understand that it 18 was environmental reasons, strictly 19 environmental reasons. 20 Q. What did you think was the 21 reason? 22 A. I really thought business 23 reasons. I know they had made it for 0068 1 many years there and I know how they find 2 other things or other products, you know, 3 to take the place. And I can't, I can't 4 say that I know for sure exactly what I 5 understood it to be. But in my mind, I 6 want to think I understood it to be 7 business reasons. And that is that the 8 material wasn't selling like it did. 9 Q. You may not know this or may 10 not even have an inkling, but why do you 11 think they shut down Anniston and kept OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036938 12 Krummrich going? 13 MR. COX: Object to the form. 14 A. I don't know. 15 Q. Do you remember there being 16 any discussion about why don't we shut 17 Aroclor in Krummrich down and keep 18 Anniston going? 19 A. I don't know. 20 Q. Was there any discussion 21 about the fact that they had just spent, 22 I believe it was a million dollars or 23 something, some substantial amount of 0069 1 money expanding the facilities in 2 Anniston, and then within a short period 3 of time shut the plant down? Was there 4 any discussion about that aspect of it? 5 MR. COX: Object to the form. 6 A. I guess the discussions we 7 made, we -- among some of the operators, 8 maybe. I'm not saying we were told this, 9 but when the expansion was put in, you 10 know, and they spent money like that, you 11 begin to think, well, you know, we are 12 going to be here a long, long time. We 13 think it makes our job secure. And then 14 all of a sudden, you know, you hear they OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036939 15 are shutting the department down. There 16 was some, you know, questions in our own 17 mind about, you know, they just spent on 18 this expansion and now they shut it down, 19 but I still don't recall that I knew the 20 exact reasons. 21 Q. What did you and the other 22 operators think the reasons to be? 23 A. I don't recall us discussing 0070 1 it that much. 2 Q. Don't you think you must have 3 discussed it? I mean, like we were just 4 saying, you know, here they had put a lot 5 of money into the plant. They have 6 geared up, expanded and then all of a 7 sudden they are shutting it down. Don't 8 you think that y'all talked about it and 9 wondered about it and tried to figure out 10 what was going on? 11 MR. COX: Object to the form. 12 A. I'm sure we wondered about 13 it, but I don't recall any specific 14 conversations with any specific person on 15 it. 16 Q. Do you recall any general 17 conversations about it? OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036940 18 A. Nothing other than they are 19 shutting down and I'm going over to this 20 department and I felt better knowing that 211 had a job, and was going to another 22 department. 23 Q. I'm sure about that. 0071 1 A. You know, we had had 2 different problems in different parts of 3 the plant with production shutting down. 4 You know, you would maybe have good 5 production runs and then you would cut 6 back or make less batches. The Parathion 7 Department, there had been times when, 8 you know, business was slow for it and it 9 would shut down and they would cut people 10 back and do other type work for several 11 months and then start back up. You know, 12 we had seen that happen. 13 Like I say, I assume it was 14 for business reasons, that it just wasn't 15 selling. But as far as the particular 16 reasons, say, we shut it down because of 17 this, I don't recall exactly what for. 18 Q. Well, were environmental and 19 pollution problems one of the reasons? 20 MR. COX: Object to the form. OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036941 21 Q. Even though that may not have 22 been the only reason? 23 A. It could have been, but I 0072 1 didn't have access to all of that 2 knowledge, the real reasons. 3 MR. WRIGHT: Okay. Why don't 4 we take a break? 5 6 (Whereupon, a brief recess was 7 taken.) 8 9 Q. What was Mr. McCarty's job 10 in the sixties and early seventies? 11 A. I'm not really sure. 12 Q. Did you know him or know who 13 he was? 14 A. I didn't have any -- I think 15 1 knew who he was. I want to say he 16 worked in the technical services part or 17 something. I was not acquainted with him 18 in Aroclor, the years I worked in the 19 Aroclor Department. 20 Q. Did you ever get involved -- 21 well, let me ask it this way: When did 22 you become aware of a pollution problem 23 relating to Aroclor? OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036942 0073 1 MR. COX: Object to the form. 2 A. I don't recall. 3 Q. All right. Can you give me a 4 best estimate? 5 A. Probably around late '72, 6 '73, when I really began to hear a lot 7 about PCBs. 8 Q. Now, by that time -- well, 9 when did the Aroclor production stop? 10 A. I believe late March or early 11 April of '72, because the best I recall, 12 1 went to Parathion in April of '72. 13 Q. So was it about when the 14 plant shut down is when you became aware 15 of pollution concerns? 16 A. I may have heard some 17 discussion on it at that time. 18 Q. Did you hear discussion after 19 that time, or was it just kind of a 20 little blip and then it was gone? 21 A. Of course, I heard more about 22 it after that time, but I did hear some 23 discussion on it along in there, you 0074 1 know, that they -- it would be in -- one 2 of the things I think that I recall first OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036943 3 hearing is it had effect on bird eggs or 4 something. 5 Q. Where did you hear that from? 6 A. At the plant, I guess, is the 7 only place I would have heard it, in some 8 kind of discussion there or something. 9 Q. Do you think that was before 10 or after they announced the shutdown of 11 the -- 12 A. I'm not sure. It could have 13 been before. 14 MR. COX: Make sure he 15 finishes his question before you jump in 16 to answer. 17 MR. WRIGHT: That's all 18 right. I was through. 19 Q. If it was before, is it your 20 impression that it was fairly shortly 21 before? 22 MR. COX: Object to the form. 23 A. Yes. 0075 1 Q. And then what's the next 2 thing you remember hearing, to the best 3 of your recollection? 4 A. The only thing that stands 5 out, it seems like I heard sometime after OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036944 6 that that they had a type waste treatment 7 that they could treat PCB waste with. I 8 know we discussed, well, that come too 9 late if that's the case. But, you know, 10 nothing, no technical information, just 11 talk around the plant. 12 Q. So you don't know what kind 13 of treatment it might have been? 14 A. No, I have no idea. 15 Q. What next do you remember? 16 A. I heard that it may cause 17 cancer. 18 Q. Who did you hear that from? 19 A. I don't recall who I heard it 20 from. I don't know if that was in part 21 of a report on it or some discussion, you 22 know, among workers there at the plant. 23 Q. You mentioned a report. Did 0076 1 you ever get a report? 2 A. No, I didn't get a report. 3 Q. Was there ever any official 4 announcement about PCBs by the people at 5 the plant or the people in St. Louis, or 6 anything to the employees there? 7 A. I don't recall. There could 8 have been, but I don't recall it. OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036945 9 Q. What's the next thing you 10 remember hearing about PCBs after the 11 could cause cancer? 12 A. I don't recall hearing 13 anything else, other than that same kind 14 of discussion. And then for years, you 15 know, not hearing anything about it. 16 Q. Now, let me ask you this kind 17 of parenthetically. I have seen in the 18 documents, there's some discussion about 19 a fish kill in Snow Creek or Chocclocca 20 Creek in, I think it was '68 or '69, 21 somewhere along in there, and they 22 related to it Parathion. What do you 23 remember about that? 0077 1 A. The only thing I remember 2 about it was it being in the paper. They 3 said they had a fish kill. I was not in 4 that department. I didn't work in that 5 department. I didn't have anything to do 6 with the waste treatment facility at that 7 time. Other than a lot of what I saw in 8 the newspaper and they were talking 9 about, you know, they had fish kill 10 caused from Parathion, that was all I 11 knew about it. OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036946 12 Q. Was there just one or was 13 there more than one? 14 A. That one is the one I recall. 15 Q. Were you ever involved, once 16 a PCB problem was raised, were you ever 17 involved in trying to remedy it somehow? 18 MR. COX: Object to the form. 19 A. No. 20 Q. Did you know any of the 21 people that were trying to figure out how 22 to eliminate or minimize PCB pollution? 23 MR. COX: Object to the form. 0078 1 A. No, I don't. 2 Q. Did management, or anybody in 3 management, ever come down and call the 4 operators together or the chief operators 5 and say, "Boys, we have got to stop 6 putting these PCBs out in the effluent or 7 minimize PCB losses," or anything like 8 that? 9 MR. COX: Object to the form. 10 A. I don't recall a meeting per 11 se for that particular purpose, but we 12 always tried to minimize any kind of 13 leaks or spills we had. We tried to 14 contain or catch or minimize that as part OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036947 15 of our day-to-day operation. 16 Q. But you don't ever remember 17 there being a special focus on it at any 18 time? 19 A. No, I don't. 20 Q. You don't ever remember them 21 really emphasizing it or calling your 22 attention to it, or anything like that? 23 MR. COX: Object to the form. 0079 1 A. Not saying they didn't do 2 it. You have to understand, this is many 3 years ago. I don't recall a particular 4 meeting for that. 5 Q. Well 6 A. Or -- 7 Q. Now, I'm not talking about 8 just a particular meeting. I'm talking 9 about a particular program or a 10 particular emphasis of them coming down 11 and saying, "This is our new way of doing 12 business. We are going to make these 13 changes," or anything like that. 14 A. I don't recall that. 15 Q. All right. Were you ever 16 involved in the caustic chlorine unit? 17 A. No, I never worked in that OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036948 18 department. 19 Q. Were you ever aware of a 20 mercury concern? 21 MR. COX: Object to the form. 22 A. I knew they had mercury in 23 that department and used it. I wasn't 0080 1 really aware of the effects of mercury on 2 human health. 3 Q. Did you hear about a mercury 4 pollution concern because of the use of 5 mercury there? 6 MR. COX: Object to the 7 form. 8 A. I don't remember hearing a 9 lot about it, other than, you know, they 10 had mercury and, of course, they tried to 11 contain it and keep it where it was 12 supposed to be. 13 Q. What do you remember hearing 14 about it? 15 A. Well, hearing it was 16 hazardous to your health or your system 17 could build up levels of mercury. Not 18 working in that department, you know, I 19 wasn't involved that much in it. Just 20 hearing talk around. OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036949 21 Q. Did you hear talk about 22 concerns about it being found outside the 23 plant? 0081 1 A. No, I didn't hear any 2 discussion on that. 3 MR. WRIGHT: I have got a 4 memo here from '69 from E.G. Wright. Let 5 me read the number. Actually, I think I 6 have got a clean copy of this one. Yeah, 7 here we go. We can go ahead and mark 8 this. 9 10 (Whereupon, Plaintiffs Exhibit 4 11 was marked for identification 12 and same is attached hereto.) 13 14 Q. Let me hand you this. Your 15 name is not on there, so I don't imagine 16 that you saw it, but I want to ask you 17 some questions about some things that are 18 in it. First of all, do you remember 19 seeing that memo or anything like it? 20 A. I don't remember seeing it. 21 Q. I wouldn't have expected you 22 to. I want to ask you about the people 23 up here at the top and see if you can OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036950 0082 1 tell me who they were and what their jobs 2 were back in those days, to the best of 3 your ability. And we can just start at 4 the top. J.N. Carpenter. 5 MR. COX: He's over here 6 (indicating). 7 A. All right. I've probably 8 heard of him. I can't say that I know 9 him that well. 10 Q. All right. You don't know 11 what his job was? 12 A. No. 13 Q. What about C.K. Eastman? 14 A. I remember him being there, 15 but I'm not -- there again, I don't 16 recall what his particular job was. 17 Q. L.L. Faulkner? 18 A. I know him. He, the best I 19 recall, was in the Engineering 20 Department. 21 Q. Is he still alive? 22 A. I don't know. 23 Q. R.A. Haydel. 0083 1 A. Haydel? 2 Q. Haydel? OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036951 3 A. He worked in the Aroclor 4 Department for a while. I think he 5 transferred to Louisiana. I don't know 6 about him. 7 Q. Do you know what his job was 8 in the Aroclor Department? 9 A. I would say supervisor. 10 Q. Who was your boss? 11 A. B.O. Severson was, I guess he 12 would be the department supervisor, as 13 they call it. 14 Q. Well, we'll come to him, 15 then, here in a minute. V.R. Haupt? 16 A. He was in the Engineering 17 Department. 18 Q. L.C. Lahman. 19 A. The best I recall, he was in 20 the Parathion Department or in that 21 area. I don't remember him working in 22 the Aroclor area. 23 Q. J.C. Landwehr? 0084 1 A. I remember Joe Landwehr, but 2 I don't remember -- I just remember him 3 being -- the best I recall they had a 4 Tech Service Department, Technical 5 Service Department, and a lot of these OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036952 6 worked out of those departments in 7 different parts of the engineering and 8 all. 9 Q. We talked about McCarty? 10 A. Right. 11 Q. G.W. Miller, do you remember 12 him? 13 A. I do remember him. I think 14 he worked in the lab at one time, or over 15 the lab. 16 Q. Papageorge, what was he? 17 A. He was the plant manager. 18 Q. B.O. Severson? 19 A. Okay, he was supervisor or 20 superintendent, I don't remember the 21 exact title, but over the Aroclor/ 22 Biphenyl Department when I went to work 23 there in'61. 0085 1 Q. Did he stay in that position 2 until you left, or did he move somewhere? 3 A. The best I remember, he was 4 in that position and, of course, Aroclor 5 shut down, but he still had the biphenyl 6 part of it until he retired, the best I 7 remember. 8 Q. It would have been when, do OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036953 9 you think? 10 A. I'm not sure what year he 11 retired. 12 Q. Is he still alive? 13 A. No, I think he died a couple 14 of years ago. 15 Q. W.S. 16 A. Taffee? Bill Taffee, William 17 Taffee. He worked in the technical 18 service part, in the drafting and 19 engineering part. 20 Q. H.L. Williams? 21 A. I believe he was production 22 superintendent at one time, the best I 23 remember. That was hi s j ob. 0086 1 Q. Is he still alive? Do you 2 know? 3 A. I have no idea. A lot of 4 these left and went to other plants, and 5 I don't know what happened to them. 6 Q. I assume you didn't know any 7 of the people up in St. Louis, is that 8 true? 9 A. I knew names, but I didn't 10 know faces. 11 Q. Bunky Wright, did you know OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036954 12 him? 13 A. Bunky Wright, yes. 14 Q. He mentions a couple of 15 things I want to ask you about. He talks 16 about Aroclor losses. And he says the 17 new warehouse drumming and flaking area. 18 Is that what you were describing earlier, 19 the flaking process? 20 A. Right. 21 Q. Drumming, is that the same as 22 flaking, or is he talking about something 23 else there? 0087 1 A. Drumming is where we put 2 material in 55-gallon drums. 3 Q. I thought you did that, 4 though, at the -- well, maybe I didn't 5 understand it. Where did you actually do 6 the drumming? 7 A. We used to drum on the bottom 8 floor of the old Aroclor building. 9 Q. That's the north side of the 10 Aroclor building? 11 A. Right, on the north end. 12 Q. Yeah. 13 A. And when they expanded, they 14 put in a drumming system down here. OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036955 15 Q. So that must be what he's 16 talking about, the new facility. He 17 talks about the new warehouse drumming 18 and flaking unit. 19 A. Okay, that would be what he 20 would be referring to. 21 Q. And then the remainder of 22 these organic losses comes from the 23 Aroclor still room sewer. Now, you 0088 1 mentioned that you didn't remember there 2 being a drain in the still room, or did I 3 misunderstand you? 4 A. Aroclor still room, he may be 5 talking the bottom floor, see. 6 Q. Right. 7 A. Because you had at least two 8 floors. 9 Q. Right. 10 A. I told you I recall a plate 11 over a sewer. 12 Q. Right. 13 A. But I don't recall it having 14 grating over it. 15 Q. Well, he seems to be implying 16 that something is going down the still 17 room sewer. OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036956 18 MR. COX: Object to the form. 19 Q. Can you think of where he 20 might be saying it's going? I guess let 21 mejustaskitthis way: Is it possible 22 there is a drain in there that you are 23 not remembering? 0089 1 MR. COX: Object to the form. 2 A. It's possible. 3 Q. The chlorinator sewer, I 4 think that's what we talked about over 5 here on our Walker Number 3? 6 A. Okay. 7 Q. And then the HCL Department, 8 we may have already talked about it, but 9 what do you believe that refers to? 10 A. I would think it was talking 11 about the line that went to the 12 limestone. 13 Q. Okay. The line we talked 14 about earlier? 15 A. Right. 16 Q. All right. Now, he mentioned 17 that somebody, I don't think he says 18 exactly who, went and looked in what he 19 is calling Snow Creek, a block from the 20 plant, and saw, I guess, Aroclor floating OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036957 21 in the water. Do you see where he's 22 talking about that next paragraph? 23 A. Right here (indicating). 0090 1 Q. Were you ever involved in 2 making that kind of survey? 3 A. No. 4 Q. Did you ever hear anybody 5 talking about making that kind of a 6 survey? 7 A. No. 8 Q. You don't know who might have 9 done it, or who did it, I guess I should 10 ask? 11 A. No, I don't know if it was 12 tech service people, or who may have done 13 it. I was not involved in doing any of 14 it. 15 Q. All right. At some point, 16 there was a carbon adsorption, I guess 17 you would call it a filter test project 18 run to see if they could filter Aroclor 19 out of the effluent. Were you ever aware 20 of that or involved in that in any way? 21 A. No. 22 Q. Let me ask you now some 23 questions I asked Mr. Sims. And I am not OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036958 0091 1 going to need to go in as great a detail 2 with you. I understand from him that all 3 of the employees had to have a yearly 4 physical? 5 A. Right. 6 Q. Do you remember that? Do you 7 remember the physicals? 8 A. I remember going for the 9 physical. 10 Q. Did they draw blood at the 11 physicals? 12 A. The best I remember, they 13 drew blood every time I went for a 14 physical. In the Parathion Department, 15 you went more often for a blood test than 16 just an annual physical. You went at 17 other times strictly for a blood test. 18 Q. Right. 19 A. But I remember, or the best I 20 remember, at every physical they took 21 blood, they drew blood. 22 Q. Before you went to the 23 Parathion Department? 0092 1 A. Every physical I had each 2 year when I worked there. OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036959 3 Q. Did they ever give you the 4 results of the blood tests? 5 A. I don't recall them giving 6 them to you at first. The first -- and I 7 don't recall how many years, but I do 8 remember in later years getting a notice 9 on them, getting results back on blood 10 tests, because as a first level 11 supervisor, I would get them and hand 12 them out to the employees. 13 Q. Okay. 14 A. Or they would put them in my 15 mailbox to go to them. 16 Q. Was that still while you were 17 still in the Aroclor Department or after 18 you had already left? 19 A. No, that was after I had left 20 there. 21 Q. Okay. 22 A. I don't recall them -- unless 23 there was a problem, I don't recall them 0093 1 ever saying anything about it. 2 Q. Okay. 3 A. Routinely giving you the 4 information. 5 Q. Did they test for PCBs in OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036960 6 your blood? 7 A. I don't recall what they 8 tested for. 9 Q. Did they ever, to your 10 knowledge, ever tell any of the guys that 11 they had PCBs in their blood or too much 12 PCBs in their blood or a lot of PCBs in 13 their blood or anything like that? 14 MR. COX: Object to the form. 15 A. I don't recall that. 16 Q. You don't remember them ever 17 telling anybody anything about PCBs in 18 the blood? 19 A. No. 20 Q. Did they ever tell anybody 21 about any liver results from the blood 22 tests? 23 MR. COX: Object to the form. 0094 1 A. I don't know about them 2 telling anybody else. They never told me 3 that I did. 4 Q. Okay. 5 A. I don't know what they may 6 have told others. 7 Q. I figured that, but I thought 8 I would just ask because maybe somebody, OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036961 9 maybe they talked about it. 10 A. I don't remember it being 11 talked about. 12 Q. Okay. Did anybody ever sit 13 you down and go through a health 14 questionnaire with you, either before or 15 after you retired? 16 A. Not after I retired, but we 17 had forms that we would fill out for our 18 annual physical that asked health 19 questions. 20 Q. Other than that, though, 21 nobody ever took you aside and asked you 22 a bunch of questions about your health or 23 anything like that? 0095 1 A. No. No. 2 Q. Iam going to ask you to do a 3 memory feat now. I would like for you to 4 tell me as many people as you remember 5 that worked in the Aroclor Department at 6 any level, any of their, any of the jobs. 7 And for each person, if you could, I 8 would like for you to tell me two 9 things. One, what his position was, to 10 the best of your recollection, and 11 secondly, if he's still alive or not and OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036962 12 still in the area, if you know. 13 A. William Kinnerly.And he's 14 dead. He got killed in a car wreck. 15 Q. What was his job? 16 A. He was a -- he operated the 17 acid plant and chlorinators. 18 Q. Okay. 19 A. William Key, and he operated 20 the still. He was the Aroclor still 21 operator. He's dead. 22 Early Smith, who was chief 23 operator. He's dead. 0096 1 Q. If you know how they died, go 2 ahead and tell me how they died. 3 A. Lord, I'm not sure how they 4 died. They were just old people. These 5 are old people I mean, retired just a few 6 years after I went there. 7 Q. I'm just saying if you know. 8 A. If I know? Okay. Joe Webb, 9 he ran the chlorinators and Aroclor 10 stills and he's still working at the 11 plant. 12 Doug Rich operated in the 13 Aroclor Department. He ran the 14 chlorinators, stills. He ran the acids OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036963 15 some. He's still working. 16 Bill Lloyd ran chiorinators 17 in the acid plant and he's retired, but 18 he's still living. 19 Q. In this area? 20 A. He lives in Oxford. 21 Q. Okay. 22 A. I can't think of his first 23 name, but it was a Lackey boy. Anyway, 0097 1 he retired. He's still living. 2 Q. His last name was Lackey? 3 A. Lackey. 4 MS. RUTH: Is that Fred? 5 A. No. I'm thinking it's Fred's 6 nephew. I will think of his name in a 7 little bit, but right off, I can't recall 8 his first name. 9 Q. Would Fred be one, though? 10 That might be one Mr. Sims gave use. 11 A. Fred was a relief chief 12 operator in the Aroclor/Biphenyl at the 13 time I went there. He's retired, but 14 he's still living. 15 Bill Hughes worked in the 16 Aroclor Department. He ran chiorinators 17 and he ran the acid and he just retired a OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036964 18 few months ago. He lives in Alexandria. 19 Bill Cameron worked in 20 Aroclor. He ran the stills and 21 chiorinators and the acid. And he 22 retired just here recently and he lives 23 here in Anniston. 0098 1 There was a man we referred 2 to as Dutch Amos. His last name was 3 Amos. He ran the chlorinators in the PCL 4 or the acid plant. He died, but I don't 5 know for what reason. 6 Morris Robertson worked in 7 there. He ran the chlorinators and acid. 8 Q. Robertson? 9 A. Robertson, 10 R-O-B-E-R-T-S-O-N. He retired just a 11 few months before I did and he lives in 12 Alexandria. 13 Ed Mason, he worked in the 14 Aroclor and he ran chlorinators and acid 15 and he just retired a year or two after I 16 did. He lives over close to Gadsden. 17 Southside, I think, is the area he lives 18 in. 19 Q. Southside is the name of the 20 town or -- OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036965 21 A. Well, it's a community or 22 area outside of Gadsden. 23 Q. You are beating the heck out 0099 1 of Mr. Sims, I want you to know. 2 A. Willie Frances Byrd, W.F. 3 Byrd, he worked in the Aroclor and he ran 4 chlorinators, and I think the acid 5 plant. And he retired, I was going to 6 say this year, but he lives in 7 Jacksonville. 8 Q. Jacksonville, Alabama? 9 A. Uh-huh (indicating 10 affirmatively). 11 Q. Okay. 12 A. Hamlin Martin. He ran the 13 chlorinators and acid and he retired, I 14 think, in December of'94. And he lives 15 up toward Alexandria, what they call 16 Peaks Hill community, but around 17 Alexandria and Ohatchee. 18 Tom Townsend was a chief 19 operator in that department. He was 20 operator on the Aroclor stills when I 21 went out there and then he went to chief 22 operator. He retired, and the best I 23 recall he's dead now. I don't know how OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036966 0100 1 he died. 2 Red Haynes, Lavon Haynes. 3 Q. What was his first name? 4 A. Lavon. We always called him 5 Red, but it was Lavon Haynes. He was a 6 chief operator in the Aroclor Department 7 some. And he retired and then moved to 8 South Alabama around Foley. He has died 9 since then with heart problems. He had 10 some heart problems. 11 Neil Steen. Neil Steen 12 worked in the Aroclor department some. 13 Q. S-T-E-E-N? 14 A. S-T-E-E-N.He trained me on 15 the chlorinators. And he's died since 16 then. I believe he had cancer. I 17 believe he died of cancer. I've about 18 run out of names. There was a Don 19 Robertson that worked there for a while. 20 Q. Robertson? 21 A. R-O-B-E-R-T-S-O-N. His was 22 spelled the same way as the other one 23 was. I'm not sure exactly which one of 0101 1 the jobs he ran, but he still works 2 there. But I remember him running the OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036967 3 flaker in that area at one time. I don't 4 know how much he ran one of the jobs, 5 but I remember he did work in that 6 department. 7 Q. Okay. 8 A. Tom Burkhart. He ran the 9 chlorinators, stills, acid plant. He 10 retired and he's still living. 11 Sam Caffey worked in that 12 department for a while. He got laid 13 off. And it may have -- I'm not sure if 14 it was when that department shut down, 15 but as far as I know, he's still living. 16 Q. Can you spell his last name? 17 A. C-A-F-F-E-Y, Caffey, I 18 believe is the way you spell it. 19 Q. Did he live in Anniston? 20 A. Uh-huh (indicating 21 affirmatively). That's about all I can 22 remember. 23 Q. That's pretty good. Let me 0102 1 ask you a couple of other names. I don't 2 think these guys worked in Aroclor. I 3 think I know where they worked, but let 4 me just get your take on it. J.T. Bell, 5 B-E-L-L? OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036968 6 A. What's the name? 7 Q. J.T., I don't know what his 8 first name was? 9 A. Thomas Bell. Okay. 10 Q. And J.L. Brown. 11 A. I think that's Jerry Brown. 12 Q. Jerry Brown? 13 A. Yeah, he's still there. He 14 still works there. He works in the lab, 15 or is over the lab, I think. 16 Q. Was he always in the lab? 17 A. I don't remember him working 18 out in the plant as an operator or 19 anything. 20 Q. Okay. 21 A. As long as I knew him or had 22 any dealings with him, he was in the lab. 23 Q. Was Bell in the lab, too? 0103 1 A. No, Bell was an operator. 2 Now, he may have worked in the Aroclor 3 Department some. 4 Q. Do you think that's a 5 different Bell? 6 MR. COX: Toby Bell is the 7 J.T Bell. Do you remember Toby? 8 THE WITNESS: I remember OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036969 9 Toby. 10 MR. COX: That's JT. 11 THE WITNESS: Okay. We had 12 a Bell, Thomas Bell. His initial may 13 have been T.H. 14 Q. (BY MR. WRIGHT:) Did he work 15 in the Aroclor Department? 16 A. I mostly remember him working 17 in the Biphenyl Department, what we 18 called the Biphenyl Department. 19 Q. J.L. Corder? 20 A. J.C. Corder. Yes, if I 21 remember, he was production 22 superintendent for awhile. 23 Q. Would he have been over the 0104 1 Aroclor Department? 2 A. He would have been over the 3 production for that, yeah, for that part 4 of the plant, the Aroclor/Biphenyl 5 Department. 6 Q. Is he dead now? 7 A. I don't know. He transferred 8 to another plant. I don't know. 9 Q. G.W. Miller? 10 A. What's the name? 11 Q. G.W. Miller. OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036970 12 MR. COX: That's the same guy 13 you talked about on Exhibit 4. 14 MR. WRIGHT: Yeah, it is. 15 MR. COX: That's Gerald 16 Miller. 17 MR. WRIGHT: You are right. 18 Is he still alive? 19 MR. COX: Yes. 20 A. Now, that's Gerald Miller, 21 but he give a different initial, didn't 22 he? 23 Q. G. 0105 1 A. Oh, G.W. I thought you said 2 T. W. Gerald Miller, yeah, okay. I 3 don't know. I think he left Monsanto. 4 Q. The other guys I know about. 5 MR. WRIGHT: Let's take a 6 few minutes break. 7 THE WITNESS: Okay. 8 MR. WRIGHT: And, then, I'm 9 pretty close to being done, although I 10 will probably think of a couple more 11 questions while I'm out in the hallway. 12 Oh, okay. Just before we go on the 13 break, there is an area that I want to 14 ask you about. OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036971 15 Q. Now, none of those guys that 16 you mentioned were what you would call 17 Aroclor laborers, right? 18 A. Don Robertson may have worked 19 in Aroclor as a cut back operator from 20 another department for a while. 21 Q. Okay. 22 A. He may have worked in that 23 department as a cutback laborer. 0106 1 Q. Okay. 2 A. None of the others that I 3 named were what I call in the laborer 4 group. 5 Q. Do you remember any of the 6 people that were in the Aroclor labor 7 group? 8 A. There was a Jesse Seay. 9 Q. Okay. 10 A. I believe he spelled it 11 S-E-A-Y. He was laborer. As far as I 12 know, he's dead now. Bill Twyman, I 13 believe was his name. He's dead. There 14 was a Fred Turner. I'm not sure if he's 15 dead or not. 16 There's some more that I can 17 see their faces, but I can't call their OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036972 18 names. Arthur Lanier. 19 Q. Arthur Lanier? 20 A. Arthur Lanier was a laborer. 21 Q. Do you know where he is? 22 A. He went on and worked in the 23 electrical group a while and retired. I 0107 1 don't know where he's at now. I think 2 he's still living. 3 Q. Was he in the Anniston area? 4 Did he live in the Anniston area? 5 A. He did, yes. Those are the 6 ones that I -- there was a Doyle Walker. 7 Q. Doyle? 8 A. Doyle. 9 Q. Okay. 10 A. And he worked in the labor 11 group. I believe he died from a heart 12 attack. And I'm not sure if he had 13 retired at that time. I think he had, 14 but I'm not positive. I couldn't be sure 15 about that. George Ware. 16 Q. Do you know how the last name 17 might have been spelled? 18 A. W-A-R-E. He retired and I'm 19 not sure if he's still living. Some of 20 these I see at the Quarter Century Club OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036973 21 and know they are able to be there. Some 22 of them may not come for some reason. 23 Not getting the local paper like I used 0108 1 to, I don't hear about a lot of the 2 deaths sometimes. 3 Q. What's the Quarter Century 4 Club? 5 A. That's for people that worked 6 there twenty-five years or more. They 7 have a meeting every December, all 8 retirees or active employees, whatever. 9 You have to be there twenty-five years to 10 be a full-time member to get to go every 11 year. But, now, if you are receiving a 12 ten year, fifteen year, twenty year 13 award, if that's your year to receive an 14 aware, you get to go, but you go every 15 year once you have been there for 16 twenty-five years. If s for retired 17 people. 18 Q. Is it a social function? 19 A. It is, uh-huh. 20 Q. Can you think of any more of 21 the labor group? 22 A. The labor group? Not right 23 off, no. OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036974 0109 1 Q. How many of them would there 2 be at any one time in the labor group? 3 A. The best I recall on the off 4 shift, by that, I mean, second shift, 5 third shift, weekends, we usually had, I 6 believe it was two per shift. 7 Q. And then on the daytime 8 shift? 9 A. Well, you might have had an 10 extra one there that could have possibly 11 been a vacation relief. Nobody was on 12 vacation. He may have been. But I 13 mostly remember usually having two per 14 shift. 15 Q. So there would be six with 16 some fill-ins at any one time? 17 A. Right. Right. 18 Q. Okay. 19 A. There could have been eight, 20 maybe. 21 Q. Who was incharge of them? 22 Did they have a specific supervisor or 23 did they answer to the operators? 0110 1 A. Well, the chief operator made 2 their work assignments, whatever he OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036975 3 wanted them to do on that shift. They 4 were assigned to a shift like an 5 operator, but they were just classified 6 as a labor group or in the labor group. 7 MR. WRIGHT: All right. Now 8 we can take a break. Thank you. 9 10 (Whereupon, a brief recess was 11 taken.) 12 13 Q. When the Aroclor plant shut 14 down, what happened to the plant 15 facilities, all of the equipment and the 16 pipes and all of that stuff? 17 A. They dismantled it, but I 18 wasn't in that department and I don't 19 know what they did with it other than I 20 would just see them dismantling it and 21 taking it down. I was out of that area 22 and wasn't involved in any of that. 23 Q. Was this area outside of the 0111 1 Aroclor building here, just to the north 2 of the Aroclor building and over here 3 near this tank farm? Was that concreted? 4 A. Yeah, this area is concreted 5 with a wall around it. OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036976 6 Q. When was it concreted? 7 A. When it was built. 8 Q. And that was '69? 9 A. Yes, the year they put it in. 10 Q. So that's the way they built 11 it when they put it in? 12 A. Right. 13 Q. Okay. 14 A. And it had a drainageditch 15 and all, but it had a valve. You only 16 drained it when you got ready to drain 17 it, so if you had any kind of spill, it 18 was contained. It didn't -- I mean, you 19 held it there until you could clean it up 20 or whatever. 21 Q. Now, the old tank farm, was 22 it concreted the same way? 23 A. I don't recall it being 0112 1 concreted the same way. And I don't 2 recall if those tanks just sat on 3 concrete piers. 4 Q. Okay. The loading and 5 unloading facilities. Was that 6 concreted? 7 A. No, those areas, the loading 8 -- the old loading facility was not OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036977 9 concreted. The new loading facility that 10 they put in when they built this 11 warehouse, they had some loading docks 12 there, they were not concreted. 13 Q. Going back to the cleaning 14 up spills and leaks and things like that, 15 how did they, or I say they, how did 16 y'all go about cleaning up spills and 17 leaks, for example, let's say in the 18 Aroclor still area? 19 A. If we had a spill, we would 20 put sand down, sort of dam it up with 21 sand. That was sprinkled on there until 22 we absorbed it. 23 Q. Sprinkle sand on there? 0113 1 A. Put sand on it and then 2 shovel it up and put it in drums. 3 Q. What about the part that you 4 couldn't shovel up? I mean, you know, I 5 assume it's like oil, isn't it? 6 A. Well, it was liquid, yeah. 7 Q. Like oil, though, oily-kind 8 of liquid? 9 A. You shovel it up and put more 10 sand or stuff on there to absorb it until 11 you had it dried up like, you know. OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036978 12 Q. I guess I was just, I am just 13 relating it to my own experience cleaning 14 up oil spills and things like that. You 15 don't ever get it all unless you use 16 that, I guess if you use that -- 17 A. Oil dry? 18 Q. That oil dry, you can scrape 19 it in there and-20 A. We put some of that on, but 21 usually we would scatter sand on it, 22 because we had sand in different areas, 23 you know, for leaks or spills or 0114 1 something that we could put it on. And, 2 you know, out around the chlorinator area 3 you had hot water, you would wash that 4 area down with hot water. 5 Q. Okay. 6 A. Some of the areas you could 7 wash down with hot water, you know. 8 Q. What areas could you wash 9 down? 10 A. You could wash down around 11 this chlorinator area. 12 Q. Right. 13 A. You could pull hoses into 14 this, what we call the still room. You OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036979 15 could -- we had steam hoses and stuff. A 16 lot of times, one of the ways that we may 17 clean the floor in there is we would lay 18 a gas torch down. We had a long hose 19 with a piece of pipe on it. Take an old 20 drum lid and lay it on the floor with 21 that flame under that drum lid, kind of 22 heat it up and then you could take a 23 scraper and you could scrape it up. 0115 1 Q. Could you explain that 2 again? I kind of lost you on that one, 3 the heating thing. 4 A. We had a gas hose, a piece of 5 pipe. 6 Q. By gas, you're talking about 7 natural gas? 8 A. Natural gas. You would just 9 turn the gas on light and you'd have a 10 little flame coming out then. You would 11 take an old metal drum lid and lay over 12 it and it would spread the flame out and 13 hold it next to the floor. And you could 14 warm that up a little and then you could 15 scrape it up. 16 Q. The Aroclor? 17 A. The solid-type Aroclor. OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036980 18 Again, we put sand and stuff on it and it 19 would absorb it. 20 Q. So you put flame on it and 21 when it got hot enough-- 22 A. It wouldn't take much heat 23 and you could scrape it up and we'd 0116 1 shovel that up and put it in drums. The 2 heat just helped it turn loose from the 3 floor. 4 Q. How often would you do that? 5 A. Once a month, or depending on 6 what kind of shape it got in. 7 Q. Did y'all have an 8 incinerator anywhere around the plant? 9 A. You mean to bum waste and 10 stuff in? 11 Q. Any kind of incinerator. 12 A. They had some type 13 incinerator at one time in Parathion. 14 Q. Over here (indicating)? 15 Yeah, I read about that. What burned in 16 that incinerator? 17 A. I don't recall. That was not 18a part of my area of responsibility and I 19 didn't have any dealings with it. I just 20 remember them having an incinerator OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036981 21 there. 22 Q. Were you aware of any other 23 incinerators? 0117 1 A. No, that was the only one 2 that I -- 3 Q. Or burning pits, for that 4 matter, just where they burned trash or 5 anything? 6 A. Uh-uh, I don't recall, other 7 than that one (indicating). That was a 8 residue or something off of one of the 9 products they made. 10 Q. Where did the hydrogen 11 sulfide come from? 12 A. It come from the manufacture 13 ofthioacid. When they would make the 14 thio acid, it would give off hydrogen 15 sulfide. 16 Q. Do you ever remember there 17 being a concern about too much hydrogen 18 sulfide in the atmosphere? 19 A. I remember they would, they 20 monitored around the areas. They had 21 some monitoring trailers, I guess you 22 would call it, set up in the community 23 and they would monitor the air. OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036982 0118 1 Q. Do you remember when that 2 was? 3 A. It was in the seventies and 4 eighties. I say eighties. I mean 5 seventies. It may have been late 6 seventies, early eighties. I'm not sure 7 when they put them out. 8 Q. I have read about air 9 monitoring for PCBs around the Aroclor 10 Department in the seventies. Do you 11 remember that? 12 A. I don't remember it, no. 13 Q. Do you ever remember them 14 checking the air for PCBs? 15 A. No, I don't, but the 16 monitoring would have been done by the 17 lab department, you know. It could have 18 been outside the plant and I wasn't aware 19 of them doing that or being there. 20 MR. WRIGHT: I think that's 21 all I have, Mr. Walker. I appreciate 22 your time. 23 FURTHER DEPONENT SAITH NOT 0119 1 2 CERTIFICATE OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036983 3 STATE OF ALABAMA 4 JEFFERSON COUNTY 5 6 I hereby certify that the 7 above and foregoing hearing was taken 8 down by me in stenotype and the colloquy 9 thereto were transcribed by means of 10 computer-aided transcription, and that 11 the foregoing represents a true and 12 correct transcript of the testimony given 13 by said witness upon said hearing. 14 I further certify that I am 15 neither of counsel, nor of kin to the 16 parties to the action, nor am I in 17 anywise interested in the result of said 18 cause. 19 20 21 MICKEY TURNER 22 23 OWENS 10-14-1999 Walker, James Richard Sr.TXT[8/22/2017 4:14:56 PM] HARTOLDMON0036984