Document RJVYgJkQre7B8NryogYgJkOzX

Depo of: WILLIAM PAPAGEORGE Monsanto v Aetna January 13, 1993 CR: 54034.0 Page 1 to Page 177 ACE-FEDERAL REPORTERS, INC. 202-347-3700 CONDENSED TRANSCRIPT & CONCORDANCE PREPARED BY: ACE-FEDERAL REPORTERS. INC. 1120 G STREET. NVV SUITE 500 WASHINGTON, DC 20005 Phone: 202-347-3700 FAX: 202-737-3638 WATER PCB-SD0000068667 BSA Depo of: WILLIAM PAPAGEORGE Monsanto v Aetna January 13, 1993 CR: 54034.0 XMAX(l) Page 1 [1] IN THE SUPERIOR COURT OF THE STATE OF DELAWARE [2] IN AND FOR NEW CASTLE COUNTY [31 [4] MONSANTO COMPANY. ) [5] i (f>] Plaintiff. ) [7] t [X] vs. i C.A. No. 88 CJA-118-1-CV [1] i [10] AETNA CASUALTY & SURETY 1 [111 COMPANY, et al. i [12] ' [13] Defendants, i [14] [15] VOLUME I [1ft] [17] Deposition of WILLIAM B. PAPAGEORGE. taken on [18] behalf of Defendants, at the Adams Mark Hotel, in the City [19] of St. Louis, State of Missouri, commencing at 10:00 a.m. on [20] tire 13th day of Januaiy, 1993. before J. Bryan Jordan, [21] eertitied shorthand reporter and notary public. [22] ' Page 2 [1] APPEARANCES: [2] [3] FOR THE PLAINTIFF MONSANTO COMPANY AND THE WITNESS: [4] Mr. Steven Sarfatti [5] Schwalb. Donnenfeld. Bray & Silbert [6] A Professional Corporation [7] Suite 300 [8] 1025 Thomas Jefferson Street, NAV. [9] Washington. D.C. 20006 [10] (202t 965-7910 [11] [12] FOR THE DEFENDANT LIBERTY MUTUAL INSURANCE CO. [13] Mr. Mark J. Manta [14] Manta & Welge [15] One Commerce Square, 37th Floor [16] Philadelphia. Pennsylvania 19103 [17] (2151 851-6600 [18] FAX CI51 851-6644 [19] [20] [21] [22] Page 3 [1] FOR THE DEFENDANT INTERNATIONAL (EIL1 [2] Mr. Janies A. Hughes [3] Orrick. Herrington. At Sutcliffe [4] Old Federal Reserve Bank Building. [5] 400 Sansome Street [ft] San Francisco. California 94111 [7] (415) 773-5529 [8] FAX (415) 772-5759 [9] [10] FOR THE DEFENDANT TRAVELERS INSURANCE COMPANY: [11] Mr. Broderick D. Johnson [12] Wiley, Rein A Fielding [13] 1776 K Street. NAV. " [14] Washington. D.C. 20006 [151 (202) 828-3163 [16] FAX (202) 429-7049 [17] , [18] [19] [20] [211 [22] Page 4 [1] FOR THE LONDON DEFENDANTS (CERTAIN UNDERWRITERS. [2] CERTAIN LONDON INSURANCE COMPANIES): [3] Ms. Jean M. Scott [4] Nussbaum & Wald [5] One Thomas Circle [6] Washington. D.C. 20005 [7] (202) 383-8900 [8] FAX (202) 466-5738 [9] ; [10] ; [11] : [121 [13] ! [14] [15] : [i6] i [17] ; [is] , [19] ; [20] : [2i] 1 [22]__________________ Page 5 [1] INDEX [2] PAGE [3] EXAMINATION BY MS. SANDBECK 5 [4] [5] [6] EXHIBITS [7] [8] Papageorge Deposition Exhibit 1 ....... . 39 P] Papageorge Deposition Exhibit 2 ....... . 74 [10] Papageorge Deposition Exhibit 3 ...... . 83 [11] Papageorge Deposition Exhibit 4 ...... . 92 [12] Papageorge Deposition Exhibit 5 ........ . 99 [13] Papageorge Deposition Exhibit 6 ....... . 108 [14] Papageorge Deposition Exhibit 7 ........ . 126 [15] Papageorge Deposition Exhibit 8 ........ . 133 [16] Papageorge Deposition Exhibit 9 ...... . 136 [17] Papageorge Deposition Exhibit 10 ..... .. 138 [18] Papageorge Deposition Exhibit 1 i ..... .. 153 [19] Papageorge Deposition Exhibit 12 ..... .. 160 [20] Papageorge Deposition Exhibit 13 ..... .. 171 [21] [22]_________________________________________ Page 6 [1] Whereupon. . . [2] WILLIAM B. P.APAGEORGE, P] of sound mind, having been first duly sworn to tell the [4] truth, the whole truth, and nothing but the truth in the [5] case aforesaid, testified upon his oath as follows, to-wit: [6] ; [7] ! [8] [9] . [10] | [11] EXAMINATION QUESTIONS BY MR. MANTA: Q. Good morning. Mr. Papageorge. A. Good morning. Q. My name is Mark Manta. Pm with the firm of Manta & Welge, and we represent Liberty Mutual Insurance 1 [12] Company in the Lawsuit that Monsanto has brottglu for | [13] insurance coverage. I would first like to ask when you were ! [14] first contacted by anyone regarding this case. I [15] A. It was about the middle of December, before the [16] holidays, a week or so before. I [17] Q. Can you tell me who contacted you? ' [18] A. A legal assistant with Monsanto Company, i [19] contacted me and I believe - I've never met the person, i [20] Her name, I believe, as I remember, was Joan Turk. [21] MR. JOHNSON: Excuse me. 1 think Joan Perk. [22] _______THE WITNESS: Perk?_____________________________ Page 7 [1] MR. JOHNSON: Yeah. [2] A. (Continuing) Okay, I wrote it down wrong. I P] never met her. She's the one that called me. [4] BY MR. MANTA: ' [5] Q dnd liow lone did you speak with Miss Perk or | [6] Ms. Perk? [7] A. I didn't dock it, of course. It was less than [8] five minutes. , [9] Q. Did the conversation revolve around schedtding? : [10] [11] ; [12] A. Yes. Q. Cati you tell nte what she said? A. I'll try to remember. These are not the exact ACE-FEDERAL REPORTERS, INC. 202-347-3700 Page l to Page 7 WATER PCB-SD0000068668 BSA Depo of: WILLIAM PAPAGEORGE Monsanto v Aetna January 13, 1993 CR: 54034,0 XMAX(2) [13] words, but in essence, she says, "Mr. David Sniveiey asked [1-4] me to call you and see if you could set aside the week of [15] January 11th for the insurance case in Delaware." I believe [16] that's what she said. [17] Q. Did you - what did you say to her? [IS] A. I said, "Let me look at my calendar." And I [19] said, "Well, it's open." [20] She said, "Would you mind blocking that out?" [21] And I said, "Okay, when will I hear more [22] details?" Page 8 [1] And she says, "Well, an attorney will call you, [2] and also the travel agent will call you to arrange for [3] your - whatever is necessary, airline tickets, and hotel, [4] and so on." [5] Q. At any time during that conversation, did she ask [6] you to come to Wilmington? [7] A. Not in those words. She did mention the trial, [8] the - yes, I thought I heard "The trial in Wilmington." [9] Q. Okay. [10] A. That's the impression 1 hung up with. [11] Q. At arty time dttring that conversation, did she [12] tell you that she would like you to come to Wilmington? [13] A. She didn't use those words, no. [14] Q. At any time during the conversation, did she say [15] that Motisanto would reimburse you for any expenses in [16] cotmection with coming to Wilmington? [17] A. Not in those words, but she had mentioned that [IS] the Maritz Travel Services, which does, makes travel [19] arrangements for Monsanto, would be contacting me regarding [20] making the right arrangements. [21] Q. When wav the next contact you had with Monsanto? [22] A. Oh, 1 called the Miss Perk on the Monday Page 9 [1] following the holidays, which was January the 4th, if I [2] remember correctly. [3] Q. Okay, and did litis conversation also concern [4] scheduling? [5] A. Not directly. My call was made to her because I [6] hadn't heard, I told her, "I haven't heard from anybody. [7] What's going on?" And she [8] Q. Excuse me. Before that time, did you have any [9] understanding as to where the deposition was going to take [10] place? [11] A. Oh, I wasn't aware it was a deposition. [12] Q. Okay. [13] A. What is the cpiestion, now? [14] Q. Okay, this January 4th, approximately, [15] conversation with a paralegal from Monsanto, at any time [16] during this conversation, did she say that "Monsaruo would [17] like you to come to Wilmington"? [18] A. I don't recall the exact words, I don't remember [19] the "Monsanto would like to have you come." The reference [20] was made to the - to Wilmington, Delaware, and the case, [21] mid 1 just assumed that whatever was going to take place [22] would be in Wilmington. Page 10 [1] Q. Did you have any understanding as to who would [2] pay for your expenses? [3] A. Oh, Monsanto. [4] Q. Did you - did Monsanto - did you indicate to [5] Monsanto in any way that you didn V want to go to [6] Wilmington ? [7] MR. SARFA'ITl: Are you referring to during [8] that [9] MR. MANTA: During the January 4th conversadon. [10] A. No, 1 didn't have enough information to make any [11] kind of decision. [12] BY MR. MANTA: [13] Q. What do you meantry that? [14] A. Well, it does make a difference if it's one day [15] nut of that week or the full week. [16] Q. Okay. [17] A. And it makes a difference to me, personally, if [IS] it's a trial, that I consider that somewhat different than a [19] deposition, so with those thoughts in mind, I feh that I [20] didn't really have enough information to, to comment in any [21] direction. [22] ______ Q. As of Jatutary 4th, Monsanto hadn't told you that Page 11 [1] it was a deposition? [2] A. I did not hear those words, that's right. [3] Q Okay, and as of January 4th, you didn't know how [4] long your schedule would be tied up ? [5] A. That's correct. [6] Q. The only information, if l can get the gist of [7] what you are saying, that Monsaruo gave you is tluu they [8] would like you to hold certain days open? [9] MR. SARFAlTl: Objection; mischaracterizes his [10] testimony. [11] A. That was part of theinformation. [12] BY MR. MANTA: [13] Q. Okay, what was the other pan of the information? [14] A. The reference to the insurance case, and the - I [15] am almost certain that I heard the word "trial." Otherwise, [16] I wouldn't have come up with that understanding. [17] Q. Did Ms. Perk at any time during tluu conversation [18] say that you didn't have to go to Wilmington? [19] A. No. [20] Q. As of Jatutary 4th, then, your utuier - you really [21] didn't know where whatever it was wnr going to take place? [22] _____ MR. SARFAlTl: Objection: mischaracterizes his________ Page 12 [1] prior testimony, asked and answered. [2] A. I knew that Delaware, Wilmington, Delaware, was [3] the, the location. [4] BY MR. MANTA: [5] Q. Okay, let me ask this. You lutd assianed, then, [6] that it was going to be in Delaware; is tluu right? [7] MR. SARFAlTl: Same objections. [8] A. I don't know whether it's an assumption. The [9] City of Wilmington, Delaware, was mentioned, and the fact [10] that a travel agency was going to arrange for the necessary [11] hotel, and airline tickets, and limousine service, and what [12] have you [13] BY MR. MANTA: [14] Q. You lutd assumed, though, that it was a trial? [15] A. Yes, sir. [16] Q. Wluu was the next contact you lutd with Monsaruo? [17] A. With Monsanto? That's it. [18] Q. Okay. [19] MR. SARFAlTl: Are youexcluding conversations [20] with counsel, or are you just keeping it internal to the [21] company? [22] ______MR. MANTA: I'm going to get to that._________________ Page 13 [1] MR. SARFATTl: Okay. [2] BY MR. MANTA: [3] Q. At any time on the - during the conversations of [4] mid December and January the 4th, did you request tluu [5] Monsanto provide you with an attorney? [6] A. No. [7] Q. At any time during the conversations in mid [8] December and Jatutary 4th, did Monsanto say they were going P] to provide an attorney for you? [10] A. No. [11] Q. Following the Jatutarv 4th conversation, wluu was [12] the next contact tluu you lutd regarding this case, from [13] either an attorney or anyone in-house at Monsanto? [14] A. I got a call from an attorney, and as best as I [15] recall, it was that January 4th, that afternoon. [16] Q. Okay, can you tell me who tluu person was? [17] A. Mr. Sarfatti. [18] Q. And at any time during the conversation with Mr. [19] Sarfatti, did you request tluu Mr. Sarfatti represent you? [20] A. I don't know that I'd call it a request. It was [21] a question whether, in his role that he was going to play, [22] here, that he would be in a position to represent me. That Page 14 [1] could be interpreted as a request. [2] Q. WluU mar the representation - or, the question? [3] I'm sorry. Page 7 to Page 14 202-347-3700 ACE-FEDERAL REPORTERS, INC. WATER PCB-SD0000068669 BSA Depo of: WILLIAM PAPAGEORGE Monsanto v Aetna January 13, 1993 CR: 54034,0 XMAX(3) [4] A. I forget the exact words, but in essence, [5] something to the effect that, "You'll be representing [6] Monsanto. Will you also represent me as an individual?" [7] And liis answer was. "Yes." [X] Q. At that time, did Mr. Satfatti indicate where the [9] deposition was going to take place or that it was a (It)] deposition? [11] A. There's two questions, there. [12] Q. Okay, did Mr. Satfatti indicate that it was a [13] deposition? [14] A. Yes. [15] Q. Did Mr. Satfatti indicate Miere the deposition [16] was to take place? [17] A. Yes. [18] Q. Did Mr. Satfatti make any effort to comince yon [19] to come to Wilmington? [20] A. Certainly, yes. [21] Q. What did lie say ? [22] _____ MR. SARFAl It: I'm going to let him answer this Page 15 [1] question because it's such a banal subject, but we have [2] established an attorney-client relationship and it would be [3] privileged, so I'll let him answer as long as that's not [4] interpreted as a waiver to the balance of the conversation, [5] which dealt with more substantive issues. [A] MR. MANTA: Okay, the - as I'm sure you are [7] aware, the scope of this questioning is permitted under the [8] case management order, and that's what I'm going to limit it [9] to. ~ [10] MR. SARFAl 11: To these travel scheduling [11] details? [12] MR. MANTA: To conversations concerning that type [13] of information, yes. [14] MR. SARFATTI: Okay, that type of information [15] being scheduling, traveling-type matters? [16] MR. MANTA: Those and the matters permitted under [17] the case management order, which I'd prefer, if you have an [18] objection when I'm asking the questions, you raise it at [19] that time. Okay? [20] MR. SARFATTI: Okay, we'll take it question by [21] question, then. [22] _____ BY MR. MANTA:____________________________________ Page 16 [1] Q. What did Mr. Satfatti say to comince you to come [2] to Wilmington? [3] A. I'm trying to recall the exact words. Of course, [4] I ciui't. Something to the effect that I was expected to be [5] there, that the people involved had been scheduled to be [6] there. I can't recall any other reasons. [7] Q. In essence, he told you that you had been [8] scheduled to appear in Wilmington for a deposition and that [9] other attorneys had been scheduled to appear in Wilmington [10] for the deposition? [11] A. I don't know that the word "attorneys" was used, [12] hut others would he. are involved in this. [13] Q. Prior to that, you, prior to the scheduling of [14] your deposition, had you been asked whether you would be [15] willing to come to Wilmington for a deposition? [16] ' A. No. [17] Q. In addition to tellutg you that the deposition [18] lutd been scheduled to take place in Wilmington and that [19] there would be others there, did Mr. Satfatti tell you [20] anything else to comince you to come to Wilmington? [21] A. I can recall that he was encouraging me to go to [22] Wilmington. In fact, at that point, he went to the trouble Page 17 [1] of getting a third party on the, on the line, this third [2] ]>arty being the travel agent representative, and at that [3] tiiue, dates of departure from St. Louis and departure from [4] Wilmington were mentioned to the travel agent, and the [5] nights that I would be staying at a hotel were mentioned. I [6] kind of interpret that as an encouragement kind of [7] conversation to let's get this on track and let's make it [8] happen. [9] Q. But you lutdn t been asked yet whether you warned [10] to go; is that riglu? I [11] j [12] A. Not in those words, no. I don't recall them, Q. And did you tell Mr. Satfatti that you would not [13] be willing to come to Wilmington at that time? [14] A. Not at that point, no. [15] Q. What - how did the conversation end with, in [16] regard to whether you would come to WHmuigton or not? [17] A. Well, I again don't recall the exact words, but [18] in my own mind, I said, "Well, I hear you, but I've got some [19] personal things to look at yet." I don't, I don't believe I [20] mentioned that to Mr. Sarfatti. He didn't know me [21] personally, and I didn't know him, and I didn't want to [22] burden him with personal stuff and 1 said, "Well, okay, Page 18 [1] let's, let's set up that schedule and we'll see what [2] happens" kind of thought run through my mind. P] Q. I guess I'm a little utwlear. Did you indicate [4] to Mr. Sarfatti that there was some chance that you may not [5] want to come to Wilmington? The possibility? [6] MR. SARFATTT: You are referring to that [7] conversation on January 4th? [8] MR. MANTA: Yes. [9] A. January 4th, I, I don't know if it was at that [10] particular conversation or a subsequent one. [U] BY MR. MANTA: [12] Q. When was the subsequent conversation? [13] A. That Friday of that week. [14] Q. Friday, Jatutary 8th? Would that be appropriate? [15] A. That, that sounds right, yes, sir. [16] Q. In your mind, as of January 4th, was it still [17] open as to where you were going to be for the deposition ? [18] A. In my mind, yes, sir. [19] Q. Okay. Had Mr. Satfatti given you any indication [20] that the deposition did not have to take place in Wilmington [21] at that time? [22] A. No. No, that's - Page 19 [1] Q. On Friday, January 8tli, what did you tell Mr. [2] Sarfatti with regard to the location of the deposition? [3] A. Again, I don't recall the exact words. I'll try [4] to remember the gist of it. I called Mr. Sarfatti early in [5] the morning to teO him that a whole week out of town was an [6] imposition on me personally, because I had problems at home [7] that I could not handle long distance over a period of a [8] week. [9] Q. lYaj it your understanding that die deposition was [10] gomg to take an entire week? [11] A. That's my understanding, yes, sir. [12] Q. Did Monsanto adiise you at any point that they [13] would pay any expenses or time lost from your work at that [14] time? [15] MR. SARFATTI: Objection. There's been no [16] testimony about his employment. Assumes facts not in [17] evidence. [18] MR. MANTA: Before we get into the substance of [19] things, I'd like to just note for the record that I think [20] that the Special Discovery Master has noted what objections [21] can and cannot be made at a deposition in the case. I think [22] that the order - and the order does say that objections Page 20 [1] other than to the form or privilege are not permitted and [2] that will be the game - they will be the ground rules for [3] this deposition, as well. [4] Could I have my question read back to me? [5] THE COURT REPORTER: [6] "Q. Did Monsanto advise you at any point that [7] they would pay any expenses or time lost from your work at [8] that time?" [9] MR. SARFATTI: Same objections. [10] A. That subject was not raised. ; [11] BY MR. MANTA: I [12] Q. Did Monsanto at anv lime ask if they could be of i [13] assistance with the problems that you had in order to make i [14] it possible for you to come to Wilmington? : [15] A. No. | [16] Q. Do you think they could have been of assistance? | [17] A. I'm positive they couldn't. ACE-FEDERAL REPORTERS, INC. 202-347-3700 Page 14 to Page 20 WATER PCB-SD0000068670 BSA___________________________Depo of: WILLIAM PAPAGEORGE Monsanto v Aetna January 13, 1993 CR: 54034.0 XMAX(4) [18] Q. Okay. Mr. Papageorge, prior to the deposition, [19] you handed ota your card, which indicates that your address [20] is J2I Pebble Valley Drive, St. Louis, Missouri, 63141. Is [21] that your current address? [22] _____ A. Yes, sir.___________________________________________ Page 21 [1] Q. How long has that been your address? [2] A. Since 1970. [3] Q. And do you foresee that address changing in the [4] fantre? [5] A. No, I don't. [6] Q. Have you ever been deposed before? [7] A. Yes, sir. [8] Q. Can you just give me a tlumtbnail sketch of the [9] depositions that you've given before, ui terms of number or [10] subject matter? [11] A. The subject matter has been predominantly [12] polychlorinated biphenyls. The number, I have not kept [13] score, but since 1970, I would suggest that I've had about a [14] couple of dozen depositions. [15] Q. Did any of the depositions that you gave prior to [16] this deposition have anything to do with hazardous wastes or [17] environmental problems? [18] A. Would you help me with some of those terms? [19] Hazardous waste in what context? [20] Q. Well, why don't you tell me first if there`s any [21] depositions that dealt with anything other than PCBs or PCB [22] contamination._______________________________________________ Page 22 [1] A. No. [2] Q. Prior to this deposition, did you review any [3] documents? [4] A. I was shown some copies of documents. I do not, [5] don't think I could call it a review. [6] Q. Can you tell me what those documents were? [7] MR. SARFATl'l: I'm going to object on the grounds [8] of the attorney-client work product privileges and instruct [9] the witness not to answer. [10] BY MR. MANTA: [11] Q. Were those documents shown to you before or after [12] January 4th? [13] A. After. [14] Q. Wien were they shown to you? [15] A. Yesterday. [16] Q. Did you have any meetings with Mr. Satfatti [17] following January 4th? [18] A. No. Wefl, yesterday. I'm sorry. [19] Q. How long did you meet with Mr. Sarfath? [20] A. It started about 10KX) or so in the morning and [21] we tinished about 5JO in the evening. [22] ____ Q. Could you briefly describe youreducational___________ Page 23 [1] background? [2] A. I attended Washington University, located in St. [3] Louis, and received two degrees; a Bachelor of Science in [4] chemical engineering in 1943 and a Master of Science in [5] chemical engineering in 1947. [6] Q. What did you do following getting your Master's [7] from the University of - Washington University of St. [8] Louis? [9] A. I worked for the Phillips Petroleum Company in [10] Oklahoma. [11] Q. What did you do for the Phillips Petroleum [12] Company? [13] A. There were two distinct types of assignments. [14] Initially, I was involved with research work relating to oil [15] field drilling and to secondary recovery of oil from [16] Phillips' exhausted, I'm going to call them, wells, wells [17] that were not producing under their own energy. [18] Q. .As part of your work at Phillips, did you become [19] familiar with the geology or hydrogeology of groundwater [20] and[21] A. Not really, no. [22] _____ Q. Did any of your work at Phillips have anything to Page 24 [1] do with the disposal of hazardous wastes or materials ? [2] A. Not in the - no. Hmm-mni. [3] Q. Did you have any other responsibilities other [4] than the oil field drilling and the other item, secondary [5] wells, was it? [6] A. Secondary recovery. [7] Q. Secondary recovery? [8] A. I was then assigned to the Engineering Department [9] of the refining part of Phillips, performing calculations [10] relating to the type of equipment that would be required to [11] produce petroleum fractions. [12] Q. What are petroleum fractions ? [13] A. They are the materials that result when crude [14] petroleum is processed either under pressure, or heat, or [15] catalyst, and they are separated from the original crude [16] petroleum and result in different streams, as desired, that [17] end up in, for example, gasoline, or as paint thinners or as [18] starting materials for other chemicals. [19] Q. How long did you continue in that position ? [20] A. A couple of years. [21] Q. What was your next position? And if you could, [22] give me the date of the next. Page 25 [1] A. I left Phillips Petroleum Company in 1951. [2] Q. And what did you do next? [3] A. I joined Monsanto Chemical Company. [4] Q. Could you describe in summary fashion the [5] positions you held at Monsanto from 1951 till the present? [6] A. m try. [7] My initial assignment was at a plant of [8] Monsanto's located in St. Louis, and 1 was assigned to the [9] Plant Engineering Department to design equipment which was [10] to be installed and used to refine a product that was [11] produced at the plant. [12] Q. What plant and what product are we talking about? [13] A. The plant is the John F. Queeny Plant, and the [14] product was phthabc, p-h-t-h-a-l-i-c, anhydride, [15] a-n-h-y-d-ri-d-e. [16] Q. Your next position ? [17] A. Following that assignment, I was assigned out in [18] the plant as an Assistant Supervisor in a department that [19] made plasticizers, and as best as I recall, that assignment [20] lasted about a year. [21] I was then assigned as the super [22] Q. If I could mtemtpt, if you could tell me what Page 26 [1] your title was. [2] A. I thought 1 mentioned; Assistant Supervisor. P] Q. Oh, I'm sorry. Okay. [4] A. 1 was then assigned as a supervisor of my own [5] department, of a department that refined a material into its [6] three parts, and each of these parts was eventually used as [7] a starting material to make, primarily, rubber additives. [8] Q. Can you tell me what the chemicals, the chemicals [9] that you worked with? [10] A. This was the ortho-, nitro-, and [11] paranitroclilorobenzene. [12] Q. You can continue. [13] A. That assignment, as I remember, lasted a couple [14] of years, so I'm now, 1 think, about 1956 or so. I was then [15] assigned to the Plant Maintenance Department as a supervisor [16] of a group that was responsible for what we call at the [17] plant minor or small projects, such as replacing a tank, [18] replacing a pump, or putting in a new pipeline or a new [19] instrument. [20] Q. Did any of the small projects have to do with [21] waste disposal? [22] A. No. _____________________________________________ Page 27 [1] In about 1958, as best I can recall - these are [2] not absolute dates, because I have never kept score on P] these - I was appointed as the Superintendent of the [4] Maintmance Department, responsible not only for the, the [5] small projects group that I originally had, but also the [6] total maintenance of the plant. [7] In 1961 or so, about 1961, I was then assigned [8] back to the Plant Engineering Department, which was at that Page 20 to Page 27 202-347-3700 ACE-FEDERAL REPORTERS, INC. WATER PCB-SD0000068671 BSA_________ Depo of: WILLIAM PAPAGEORGE Monsanto v Aetna January 13, 1993 CR: 54034.0 XMAX(5) [9] time called the Technical Services Department - now, all of [10] tills is the same plant - as a Superintendent, supervising [11] the technical team of anywhere from six to twelve engineers [12] mid three or so technicians who were responsible for doing [13] the engineering work required to respond to the Production [14] Department's needs, such as a need for a bigger tank, or a [15] bigger pipeline, or better instruments, or maybe an [16] additional tank, a bigger pump, whatever their engineering [17] needs were, this team would be assigned to study it, and [IS] make their recommendations and turn it over to the [19] maintenance people to install. [20] I don't want to give the impression that that [21] engineering activity covered the entire plant. It covered [22] nidy roughly a fourth of it. There were about four teams Page 28 [1] similar to mine. [2] In 1964, I was assigned the position of general [3] su|ierintendent of - and I don't recall the exact sequence [4] of this long title, but it included utilities, services, [5] warehousing, distribution: In other words, all of the [6] services other than maintenance that the production [7] departments required to carry out their, their assignments. [S] Q. Excuse me. Did this job have anything to do with [9] providing waste disposal services for the production [10] departments? [11] A. It did. [12] Q. Can yon tell me what those services were? [13] A. We provided the wherewithal for picking up waste [141 generated in departments - not all, wherever it was [15] generated; we had a pickup service, really. We either did [16] it in Monsanto equipment or we hired contract haulers to [17] haul the material away from the plant. [18] Q. Your deposition today and for the next few days [19] is with regard to Texas City. The questions I'm asking you [20] now are merely tor purposes of backgrotaid till iw get to Ul] (hose questions. I ilon V think the J. F. Queetiy Plant is at [22] issue. It may be one of the eighty sites, but I'm not Page 29 [1] certain, but as ivie get into Krummrich, and so forth, the [2] (fuestions I'm going to ask. you are going to be in siunmary [3] fashion to get background for the Texas City deposition. [4] You may, n\ay not be deposed with regard to the other sites. [5] so I just want to make that clear. [6] MR. SARFAl'll: So you want to move through these [7] areas very briefly and in a summary fashion? I think that's [8] understood hy the witness, since the tbcus is on Texas City, [9] not on St. Louis, or Krummrich, or Anniston, or West [10] Virginia, or any of these other sites at this time. [11] MR. MANTA: At this time. And to the extent. I [12] mean the knowledge gained at these sites is relevant to what [13] he did in his later positions, we may go into that later, [14] but tor right now, I'd like - and I'm not giving - I think [15] what you were doing was exacdy what I needed, but as we get [16] into these other plant areas, 1 just wanted to be clear to [17] Mr. Sarfatti that I'm not conducting discovery on the [18] Kmmmrich Plant, I'm just getting some background. [19] MR. SARFATTI: Okay. At this point, 1 agree with [20] you. not conducting discovery, we'll see - into these other [21] areas. We'll see how the rest of your composition goes, but [22] I appreciate that introduction._________________________________ Page 30 [1] BY MR. MANTA: [2] Q. You can continue. You were telling me that you [3] contracted with haulers and pickup services at the Queeny [4] Plant. [5] A. Some of them, some of them were contracted, yes. [6] Q. Were there any on-site disposal areas at the [7] Queeny Plant? [S'] A. No. [9] Q What was your next position? [10] A. I was. in 19 - l think I've lost a year or two. [Ill here. That assignment we,just described, the one that [12] provided services to the operating departments. 1 was more [13] Ilian likely assigned that either late '62 or early 1963. In [14] 1964, I was assigned to the Monsanto plant located in [15] Sauget, Illinois, S-a-u-g-e-t, known within Monsanto as the [16] William Krummrich Plant. K-r-u-m-m-r-i-c-h. [17] I was assigned as a - as one of half a dozen [18] general superintendents of manufacturing, with operating [19] responsibilities for roughly a sixth of the plant. [20] Q. Did you work at the Krummrich Plant? [21] A. Yes. [22] Q. I mean your office, it wasn't in St. Louis? Page 31 [1] A. No, I was reporting - my office was located in [2] Sauget, Illinois, at the plant. In 1965, I was assigned to [3] the Monsanto plant in Anniston, Alabama, as a plant manager, [4] and served as plant manager until the end of 1969. [5] In 1970, I came back to Monsanto's offices in St. [6] Louis - I shouldn't say came back, I was assigned to [7] Monsanto's offices in St. Louis with a title of Manager, [8] Environmental Control, to address the issue of [9] polychlorinated biphenyls in the environment. [10] Q. Were you the only Manager of Environmental [11] Control? [12] A. To my knowledge, yes, sir. [13] Q. Did you have responsibilities in addition to die [14] issue of PCBs in the environment? [15] A. At whatpoint in time? [16] Q. In 1970. [17] A. No. [18] Q. Who else did you work with as Manager of [19] Environmental Control in 1970? [20] A. You want people in Monsanto or throughout the [21] world? I don't know what [22] Q. Oh, in the department. I'm sorry if I Page 32 [1] misunderstood. I thought it was that you were Manager of [2] the Envirotmiental Control Department in St. Louis; is that [3] correct? [4] A. It was a one-man department. I was it. [5] Q. Who did you report to at that time? [6] A. I reported to Mr. Howard Bergen, B-e-r-g-e-n, who [7] was Director of the Business Group that was responsible for [8] the polychlorinated biphenyls. [9] Q. And who reported to you, if you recall? [10] A. No one at the time, unless you want to include [11] the part-time services of a secretary. [12] Q. Was this a foil-time job? [13] A. Yes, sir. [14] Q. Did you work with Jack Garrett at all? [15] A. At what point in time? [16] Q. At this point in 1970. [17] A. On occasion, yes. [18] Q. What were - did you deal with anything other [19] than PCBs in the environmem? [20] A. At that point in time? [21] Q. At that point in time. [22] ______A. No._____________________________________ Page 33 [1] Q. When did your responsilnlities as Manager of [2] Etwironmental Control expand beyond the issues of PCBs in [3] the environment? [4] A. About 1972, and that's - I may have missed that [5] by a year or so, my title was changed to Manager, [6] Environmental Protection, still addressing only PCB [7] situations. About 1973, I was assigned a group of other [8] Monsanto products. I'm trying to recall another date where [9] my title was again changed. As best I remember, about 1974, [10] my title was changed to Manager, Product Acceptability. I [11] retained the PCB issue and I was given a new, not totally [12] new, but some new products were added to my list of [13] responsibilities. [14] Q. If we could go back to 1972, where your title [15] changed to Manager of Environmental Protection, did the [16] department expand at that point, the Environmental [17] DepartmetU? [18] A. No. No, I was still the person there. [19] Q. in 1973, you said vou were assigned a group of, [20] another group of Monsatuo products. Were you still Manager [21] of Environmental Protection at that poitu? [22] A. In 1973? As best 1 remember, yes, sir. ACE-FEDERAL REPORTERS. INC. 202-347-3700 Page 27 to Page 33 WATER PCB-SD0000068672 BSA Depo of: WILLIAM PAPAGEORGE Monsanto v Aetna January 13, 1993 CR: 54034.0 XMAX(6) Page 34 f 1 ] Q. Were there - what were the products, the other [2] products you were assigned to? [3] A. I can't remember them all. They were, as best I [4] remember, and the dates are difficult to pinpoint, 1 was [5] assigned a group of chemicals referred to in Monsanto as [6] process chemicals, which included such things as the [7] phthahc anhydride I had mentioned earlier and a somewhat [S]related chemical, maleic anhydride, m-a-l-e-i-c, phenol I [9] remember, pentachloropbenol, sulphuric arid, there was [10] Q. Let nte ask you a few - I'll give you the names [11] of a number of chemicals, and I'm going to ask if you can [12] tell me if they are some of the chemicals that you were [13] assigned to at or about 1973. [14] Styrene? [15] A. No. [16] Q. Vinyl chloride? [17] A. No. [18] Q. Acrylonitrile? [19] A. No. [20] Q. Did your responsibilities in 1973 with regard to [21] the chemicals you had mentioned - well, let me ask this. [22] What were your responsibilities with regard to these Page 35 [1] chemicals in or about 1973? [2] A. It was my responsibility to determine as best I [3] could whether the materials were meeting the specifications [4] tliat were established for them, that they were property [5] packaged, they were properly labeled, that the appropriate [6] information relating to those products was forwarded or made [7] available to the customer. That about covers it. [8] Q. I notice your title is "Environmental [9] Protection, " and what you've described doesn't, in my mind, [10] mean environmental protection. Could you explain wlutt that [11] means? [12] A. This is the reason the title was changed to [13] product acceptability, because the scope of the job was more [14] than just the environment. [15] Q. Okay, when you say it was more than just the [16] environment, what were the environmental responsibilities? [17] A. Well, it covered such things as informing the [18] customer what it might - where information was available, [19] informing him what it might do to the environment if it was [20] not handled properly. That's, that's primarily the thrust [21] of it. [22] Q. Did you have atty responsibility with regard to Page 36 [1] waste disposal oilier than communications with customers ? [2] A. At that time, no. And I don't want to mislead: [3] 1 didn't - 1 wasn't the only one communicating to [4] customers. [5] Q. Could you tell me who had responsibility for VCM, [6] styrene or AN in that department in or about 1973? [7] A. I don't know. [8] Q. Was there anybody? [9] A. I don't know. [10] Q. Was there - were there others in the department [11] at that time in 1973? Environmental Protection Department? [12] A. There was no such department. I was reporting to [13] a, a business group that included those products under its [14] imuuigement when the title of Manager of Product [15] Acceptability was adopted, there were similar positions [16] established for other business groups, and they were [17] assigned to otherpeople. [18] Q. In 1974, when you became Manager of Product [19] Acceptability, you retained PCB responsibility and you were [20] given new products. Were any of those products VCM, styrene [21] or acrylonitrile? [22] A. No. Page 37 [1] Q. Did your responsibilities change in any way in [2] about 1974? [3] A. No. [4] Q. Whendid your responsibilities change next, or [5] your title? [6] A. I'm trying to recall the date. I believe it was [7] about 1976, Monsanto - it was nineteen seventy - 1975, [8] Monsanto reorganized and formed differait operating units. [9] I retained the title of Manager, Product Acceptability. I [10] retained the responsibilities for the polychlorinated [11] biphenyl environmental issue, but was assigned a group of [12] products, some of which I had previously been involved with. [13] I just can't recall what new products were added to my list. [14] Q. Could you tell me whether or not styrene, vinyl [15] chloride or acrylonitrile were among, were added to your [16] list? [17] A. I'm hesitating because I did eventually become [18] involved with acrylonitrile, but I don't recall the timing. [19] It might well have been that period, but I don't - I'm not [20] certain. [21] Q. What was your next position ? [22] _____A. In 1977, I was signed as a Director,_________________ Page 38 [1] Environmental Operations, of one of Monsanto's operating [2] units. [3] MR. MANTA: I noticed you took a quick look at [4] your watch. If at any time you want to take a break, you [5] get tired, let me know. If any personal troubles come up [6] during the deposition, please let me know and we'll try to [7] accommodate you. I don't want this to be a grueling [8] session, by any means, and you know, whenever you would like [9] to take a break, just let me know. It's been an hour. [10] THE WTTNESS: I appreciate that. [11] MR. SARFATTI: If you'd like to take a break now, [12] it's up to you. [13] A. It all depends on how much longer we go. I was [14] thinking of going [15] MR. SARFATTI: Why don't we shoot for noon, I [16] think. [17] MR. MANTA: All right. It doesn't matter to me. [18] MR. SARFATTI: Why don't you keep going. I'm [19] assure Bill will speak up. [20] THE WITNESS: I'll speak up if I have to go to [21] the restroom. [22] _____ MR. MANTA: For the time being, we'll go to noon. Page 39 [1] (Discussion off the record.) [2] BY MR. MANTA: [3] Q. Okay, in 1977, you were assigned the position of [4] Director of Environmental Operations for one of Monsanto's [5] operating units. Can you tell me what unit that was? [6] A. It was the Monsanto Chemical Intermediates [7] Company, [8] Q. What plants were within Monsanto Chemical [9] Intermediates? And I'm going to refer to it as MCI, if you [10] don't mind. [11] A. Okay, that's the acronym we used. [12] The John F. Queeny Plant, the William Kruuimrich [13] Plant, Texas City Plant, Chocolate Bayou Plant, Columbia, [14] Tennessee, Plant, Soda Springs, Idaho, Plant. I believe [15] I've covered them all. [16] MR. MANTA: This is the first exhibit. [17] (Papageorge Deposition Exhibit 1 marked for [18] identification.) [19] MR. SARFATTI: Can we go off the record a minute? [20] (Discussion off the record.) [21] BY MR. MANTA: [22] _____ Q. Looking at what has been marked for_________________ Page 40 [1] identification as Papageorge 1, it is an August 16, 1977, [2] bulletin bearing identification number MCA 0057502. P] If you would take a moment to look at that and [4] tell me, does that reflect the position that you had [5] indicated earlier that you were assigned to in 1977? [6] A. It does. m Q. Now, the documem alsoreferences the [8] establishment of the corporate environmental policy staff. [9] Could you tell me what that is? [10] A. This was a group of Monsanto individuals at the [11] corporate level, headed by vice-president whose overall [12] assignment for that entire group related to matters [13] concerning environmental issues and Monsanto's products and Page 34 to Page 40 202-347-3700 ACE-FEDERAL REPORTERS, INC. WATER PCB-SD0000068673 BSA Depo of: WILLIAM PAPAGEORGE Monsanto v Aetna January 13. 1993 CR: 54034.0 XMAX(7) [14] operations. [15] Q. H7i ivar litis vice-president? [16] A. Mnate Throdahi, T-h-r-o-d-a-h-1. [17] 0. The Director of Environmental Operations from the [18] various units, if l understand you correctly, or in charge [19] of the various units, reported to Mr. Throdahi? [20] ' A. No. [21] Q. Okay, could you explain the hierarchy of the [22] policy staff'? [1] A. I'll try. Page 41 ~ [2] MR. SARFATTI: We're talking 1977? [3] MR. MANTA: Approximately in 1977. [4] A. Mr. Throdahi was the, the head person of the [5] group assigned to the corporate organization. The Directors [6] of Environmental Operations were assigned to the operating [7] units. The relationship between the Directors of 18] Environmental Operations and Mr. Throdahl's team was what we [9] in Monsanto called a dotted-line relationship, as [10] distinguished from the solid line within the operating [11] company, which would indicate the direct supervision of the [12] activity. [13] BY MR. MANTA: [14] Q. Could you give me in practical terms how the [15] dotted-line version differs from the solid line? [16] A. Well. I'll try and use some lay terms, if 1 can [17] flunk of them. [18] Tlte solid line represents a situation where the [19] supervisor makes the assignments, appraises the performance, [20] decides whether to reward the person with salary increases, [21] and so it's a much more direct supervision of the job, [22] whereas the dotted line almost amounts to one of guidance. Page 42 [1] consulting, making certain that the operating unit, in its [2] performance, complies with corporate objectives and policy. [3] Q. Would it be consultation on an as-needed basis, [4] if you or someone else felt [5] A. That would be one of the - yes, sir, I would [6] make appointments to see Mr. Throdahi on matters. [7] Q. Was there any formal requirement of contacting [8] Mr. Throdahi on certain occasions or if certain issues came [9] up. or was it more or less an ad hoc type of relationship? [10] A. Well, if I understand your term "ad hoc," it was [11] on a perceived need basis. The door was always open. This [12] is not to say that Mr. Throdahi and his team did not conduct [13] regularly scheduled meetings or special meetings as [14] different occasions would arise, and invite individuals like [15] the environmental operations directors to attend. [16] Q. Were there regularly-scheduled, or regular [17] meetings of the corporate environmental policy staff headed [18] by Mr. Throdahi? [19] A. As I remember, yes, sir, there were. [20] Q. How regular were those meetings? [21] A. About one a month, depending on whether people [22] were traveling or available. Page 43 [1] Q. And would those meetings address issues raised by [2] the environmental operations directors? [3] A. Sometimes. [->] Q. Okay. Wereother issuesalso discussed? [5] A. Yes. sir. [6] Q. There w ere - could you tell me who attended [7] these monthly meetings, or approximately monthly meetings? [8] MR. SARFATTI: You are just speaking generally [9] now, not each and every meeting who attended each and every [10] meeting, hut types of people, not individuals? [11] MR. MANTA: Right. [12] A. Of course, members of Mr. Throdahl's staff, the 113] Directors of Environmental Operations, sometimes with [14] members of their team, on occasion, the Director of the [15] Environmental Operations could not attend a meeting, he 116] would send an alternate. There were public relations [17] individuals that would attend, there were - there was a [18] lawyer attending. Members of the corporate Medical [19] Department, either the director or his lieutenant, or both. [20] and as best I can recall, the door was always open to any [21] Monsanto vice-president who wanted to attend or could [22] attend, time permitting. Page 44 [1] Q. A vice-president would lye someone who would be [2] located in St. Louis, I take it? [3] MR. SARFATTI: What time frame are we talking [4] about, just tor the sake of the clarity of the record? ! [5] MR. MANTA: In about '77, when this was began, [6] through the late Seventies, I would say. [7] A. Yes, I remember all of the vice-presidents of [8] Monsanto were located if in St. Louis except the one that [9] was, had his offices in Washington, D.C. [10] BY MR. MANTA: [111 Q. How about, did plant persotmel attend these [12] meetings? [13] A. I don't recall if they did or not. It doesn't [14] mean they did or didn't, I just don't remember. [15] Q. Now, I'm not sure I understood who was on this [16] corporate environmental policy stiff. Did you tell me? [17] A. In what way? Titles, or - [18] Q. Yes. ' [19] A. People's names? [20] Q. People's names? [21] A. People's names? I'll try to remember. [22] _______ MR. SARFATll: You want to focus, again, on the Page 45 [1] 1977 name exchange. [2] MR. MANTA: 1977. [3] A. 1977. All right, there was, I don't know what [4] his formal first name is. We called him Wink Corey, [5] C-o-r-e-y. I think it was Wintrhop, but I wouldn't bet on [6] that. He was one of Mr. Throdahl's staff members. [7] BY MR. MANTA: [8] Q. What was his title? [9] A. Director, and the part I'm not certain of, he had [10] something to do with the Toxic Substances Control Act. I [11] don't know what his formal title was. Then there was - his [12] mime escapes me. A Gene .lessee, J-e-s-s double-e, he was [13] the individual, director assigned to, at that time, RCRA, [14] waste management kinds of problems. [15] Mike, M. A. Pierle, P-i-e-r-l-e, he was assigned [16] the - he was a director of and assigned to environmental [17] issues relating to water, waste water, primarily, and I'm [18] having difficulty remembering the other members. I know [19] there was an individual assigned to air pollution issues. I [20] can't recall his name at the moment. [21] Q. Did the corporate environmental policy staff [22] always have someone assigned to RCRA throughout the time Page 46 [1] [2] PI [4] [5] [6] m [8] P] [10] [11] [12] [13] [14] [15] [16] [17] [18] [19] ! [20] I [21] that you were at Monsanto? MR. SARFATTI: Objection; vagueness. A. To the best of my knowledge, yes, sir. BY MR. MANTA: Q. Was it always Mr. Jessee ? A. No. I had forgotten who his - who replaced him. Q. Do you know approximately when he would have been replaced? A. I just don't recall. Q. How about a director assigned to water issues: Was it always Mr. Pierle? A. No, eventually, Mr. Malloch, M-a-l-l-o-c-h, was assigned, as best as I can recall, to water issues. I have difficulty remembering what year that was. Q. You were not on the corporate emirotmtental policy staff, l take it, at no point? A. That's correct. Q. Could you describe what your responsibilities were as Director of Envtrotunental Operations for MCI? A. I'll try. I was responsible as a staff member of the operating unit to keep informed as to developments relating to environmental matters regarding solid wastes,______ Page 47 I [1] air, water. Also, I was responsible for keeping informed i [2] regarding the impact that Monsanto's products might or might I [3] not have on the environment. I was responsible for keeping ACE-FEDERAL REPORTERS, INC. 202-347-3700 Page 40 to Page 47 WATER PCB-SD0000068674 BSA Depo of: WILLIAM PAPAGEORGE Monsanto t Aetna January 13, 1993 CR: 54034.0 XMAX [4] informed relating to the employee exposure potential at the [5] plants who were handling the many materials, both raw [6] materials, intermediate products and final products. I had [7] assistance from members of my team to help me in this [8] matter. I was to share and coordinate information that was [9] passed on to the plants and also to keep my bosses informed [10] of developments in this entire area. [11] Q. Who war on your team? [12] A. Initially, it consisted of two individuals, Larry [13] Keating, K-e-a-t-i-n-g, and Mike Pierie, P-i-e-r-l-e. [14] Q. What ivas Mr. Keating's title? [15] A. I believe at the time, it was Manager, Industrial [16] Hygiene. I know he was a manager and 1 know he was assigned [17] industrial hygiene matters. 1 don't recall if that was his [18] official title. [19] Q. How abota Mike Pierie? [20] A. Mr. Pierie was Manager, Environmental Protection. [21] THE WITNESS: Is this a good place to recess? [22] _____ MR. SARFAt 'll: If that's what you say, that's__________ Page 48 [1] what goes. You want to take a break? [2] (Recess) [3] BY MR. MANTA: [4] Q. Okay, before the break, we were talking about [5] your position as Director of Environmental Operations, was [6] that? [7] A. In 1977. [8] Q. '77. [9] A. Yes. [10] Q. And you were a staff member of the MCI [11] operational unit and you were to keep informed as to [12] developments iti solid waste, air, water, et cetera. Can you [13] tell me how you kept informed of environmental issues [14] relative to the plains within MCI? [15] A. Would you mind repeating that? Kept [16] Q. No problem. You had mentioned that m your [17] position in and abota 1977, you were a staff member of an [18] operational tout. In other words, you sat on the MCI [19] operational tout in your position with a number of other [20] people. Is that riglu? [21] A. Yes. [22] _____ Q. And your responsibility, if l understood you___________ Page 49 [1] correctly, was to keep informed as to developments, [2] basically, in the environmental area. Is that riglu? [3] MR. SARFATTI: Objection as to form. [4] A. Well, I don't know whatyou mean by the use of [5] die word "basically." It was [6] BY MR. MANTA: [7] Q. Why don't I say this [8] A. - environmental as it related to air, water and [V] solid waste, but just as importantly, product considerations [10] and employee exposure considerations were, were part of the [11] responsibility. [12] Q. Okay, I understand that. What l -- my question [13] is, how did you do the part of your job that dealt with [14] keeping abreast of emironmental developments? [15] A. It included, of course, an awful lot of reading [16] of the appropriate journals, governmental documents, reports [17] of, from many, many sources, university reports, state and [18] federal documents, attending meetings as appropriate and as [19] time permitted, attending Monsanto-conducted meetings, [20] visiting the plants, discussing these matters with my staff, [21] communicating with the corporate departments within Monsanto [22] tliat had something to contribute. That about covers it.______ Page 50 [1] Talking with customers of people and talking with [2] competitors' representatives. [3] Q. Did you do anything as an initial matter to get [4] up to speed or to learn the emironmental issues that [5] related to the various plant sites? [6] A. I certainly, as time permitted, of course, [7] arranged for a personal visit to the plants. In the [8] meantime, I had my staff make the early contacts. They, in [9] turn, would come back and share with me with their [10] observations, their, their thoughts, their proposals. [11] Q. Would tlutt be Mr. Pierie aiul Mr. Keating ? [12] A. That was the first team, yes, sir, in 1977. [13] Q. What was the next team? [14] A. Shortly alter this announcement was made with Mr. [15] Pierie, it wasn't too long that Mr. Pierie transferred over [16] to the corporate staff. He was replaced by Mr. Weishaar, [17] W c-i-s-h douhle-a-a-r. That was about within six months of [18] this August '77 date, as best I recall. [19] Q- Did it, did the team change again? [20] A. Yes, we had another change in, as best I [21] remember, I added to the team a Manager of Product [22] Acceptability. I can't think of his name. It'll come to me Page 51 [1] later. [2] Q. That's okay. [3] A. And then at about mid 1978, we added another [4] individual, Michael Foresman, F-o-r-e-s-m-a-n. He was an [5] Environmental Protection Manager, as distinguished from a [6] Manager, Environmental Protection. [7] Q. Did the team change again, other than from [8] Manager of Environmental Protection to Environmental [9] Protection Manager? [10] A. That indicates a lower-level job. He was a [11] junior member. The poation of the word "Manager" means [12] something to the Personnel Department. [13] MR. SARFATTI: Have you established a cutoff [14] point for the witness' frame of reference? [15] MR. MANTA: Well, I'm going to - I mean, as long [16] as he's at Monsanto, during the time - [17] MR. SARFATTI: Up to his retirement? [18] MR. MANTA: At Monsanto, yeah. [19] MR. SARFATTI: Do you understand the time frame, [20] the continuum? [21] MR. MANTA: I'm just trying to find out who was [22L on the team throughout the time he was at Monsanto.__________ Page 52 [1] A. We're up to 1978. The team, the team stayed at [2] that staffing until Monsanto underwent another [3] reorganization. I was then assigned as Director, [4] Environmental Operations of the Monsanto Industrial [5] Chemicals Company, MIC. [6] BY MR. MANTA: [7] Q. Did your plaru responsibilitychange at tlutt [8] point? [9] A. Yes. [10] Q. Can you tell me how? Wlutt plants you were [11] responsible for? [12] A. I'll try to remember. There were more plants [13] involved. I retained the John F. Queeny Plant and the [14] William Knimmrich Plant, the Soda Springs Plant in Idaho, [15] the Columbia, Tennessee, Plant. I picked up the Avon, [16] California, Plant, Kearny, New Jersey, K-e-a-r-n-y, the [17] Everett, Massachusetts, Plant, the plant at Bridgeport, New [18] Jersey, the plant at, I think it's Addyston, [19] A-d-d-y-s-t-o-n, Ohio, Augusta, Georgia. I believe that was [20] all. 1 don't know that I got them all. [21] Q. Was Texas City in tluu group? [22] _______ A. No. __________________________________________ __ Page 53 [1] Q. Wlutt year was this? [2] A. 1983. P] Q. W)u> would tune been Director of Emironmental [4] Operations for the plants - for the Texas City Plant? In [5] other words, wlutt -- [6] A. In '83? [7] Q. Yes. [8] A. As best as my recollection will help me, I [9] believe it was Clayton Callis, C-a-l-l-i-. [10] Q. He assumed your responsibilities, then, in 1983 | [11] for the Texas City Plant, among others? | [12] [13] A. Yes. Q. Did you luive any contituting responsibility for [14] the Texas City Plant after 1983? * [15] A. No. Page 47 to Page 53 202-347-3700 ACE-FEDERAL REPORTERS, INC. WATER PCB-SD0000068675 BSA Depo of: WILLIAM PAPAGEORGE Monsanto v Aetna January 13, 1993 CR: 54034.0 XMAX(9) [161 Q- Were you, nonetheless, uformed of tilings that [171 'sere happening at the Texas Citv Plant in 1983 or following [181 1983? ' [191 A. I was informed to a degree; not thoroughly, but [201 Dr. Calks, during our meetings or private conversation, [21] would, on occasion, discuss matters. I was interested not [22] a direct - not having direct responsibilities, but in________ Page 54 [1] the event that I could learn something from their [2] experiences and apply it to the plants that I was [3] responsible for. [4] Q. And how long did you continue in that position [5] as - in the position you took in 1983 as Director of [6] Environmental Operations of MIC? [7] A. Until the end of - near the end of 1985. [8] Q. .ind what happened in 1985? [9] A. Another reorganization. [10] Q. And what happened to you? [11] A. 1 was then assigned as manager of - I'm trying [12] to remember the title. I've forgotten the official title. [13] It bad to do with workplace exposure and employees for the [14] newly-informed Monsanto Chemical Company. [15] Q. Did you have any environmental responsibilities? [16] And wium I'm taildng about environmental, I'm excluduig from [17] there employee exposure issues. [18] A. No, my responsibilities were limited to those [19] situations that affected workplace exposure. [20] Q. In 1985. did you have any responsibility with [21] respect to workplace exposure at the Texas City Plant? [22] _____ A. Yes._______________________________________________ Page 55 [1] Q. Would you tell me what those responsibilities [2] were? [3] A. I don't know that I can define them fully. [4] It's - it was primarily one of making certain that the [5] plant was addressing those exposure situations that I [6] believe should have, they should be addressing and that they [7] were communicating very closely with the industrial [8] hygienists from Monsanto's Corporate Department. [9] Q. Now, in your position as Director of [10] Environmental Operations for MIC - I'm sorry, MCI - you [11] mentioned that some of the ways that you kept informed of [12] the environmental issues with regard to plants such as the [13] Texas City Plant were to visit the platu, get information [14] from your staff, and conduct meetings with platu personnel? [15] Is that right? [16] A. Not only - not limited to plant personnel. [17] Q. Okay. I understand that, bia can you tell me [18] who. during the time you were Director of Environmental [19] Operations for MCI, who at the Texas City Plant did you have [20] dealings with ? [21] A. The plant manager, of course. I'm trying to [22] remember the first one I dealt with. Hmm. 1 just can't Page 56 [1] remember lhs name. The second one was Gene Tromblee. I [2] remember him. T-r-o-m-b-l-e-e. I don't recall his [3] predecessor. [4] I also worked - I forget his first name [5] Himes. H-i-m-e-s. [6] MR. HUGHES: Fred. [7] A. (Continuing) Fred. Fred Himes, yes, sir. He [8] had a group reporting to him. [9] 1 remember an Ed Hendricks. I think it's Ray Ann [10] Reid, she was one of the environmental engineers, and then [11] there's a McCauley. It might well have been others; I just [12] can't recall them all. [13] Q. Would you have had contact with the platu manager [14] or a platu manager throughout the time that you were [15] Director of Environmental Operations from - for MCI? [16] A. Certainly. [17] Q. And the same as for Mr. Fred Himes? [18] A. Yes. [19] Q. And Mr. EdHendricks? [20] A. Well, Ed Hendricks, it seems to me I recall he [21] retired somewhere in there. I initially worked very closely [22] with Mr. Hendricks, and eventually - and I forget when he Page 57 [1] retired, but he was no longer available and I was then [2] dealing with Miss Reid and Mr. McCauley. [3] Q. Now, when you say initially, that would be in the [4] period from nineteen seventy -- or, I'm sorry, is that [5] riglu? 1977? [6] A. Correct. [7] 0. Through '83. I ihitik it was? [8] A. Yes, sir. [9] Q. Unless Mr.Hendricksretired before that? [10] A. As best I recall, he retired before that. [11] Q. Okay. Now, when you say you worked very closely [12] with Mr. Hendricks, what do you mean by that? Can you [13] just - [14] A. I don't know how to describe it except that there [15] would be telephone conversations, there might be - and of [16] course, when I went to the plant, I made it a point to meet [17] with all of those folks, and Mr. Hendricks was the senior [18] man with the, all that experience that - [19] Q. All what experience? [20] A. His years at the plant. He knew, he knew a lot [21] of the plant history, so to speak, that the younger [22] engineers just had not experienced, so 1 relied a lot on Mr, Page 58 [1] Hendricks' input. [2] Q. Was he, / guess, one of the first persons, people [3] that you met at Texas City or that you contacted? [4] A. I don't believe he was the first person I met. I [5] met others on the plant manager's staff before 1 met Mr. [6] Hendricks. [7] Q. Can you give me an approximate date? Would it [8] have been within a year after you started? [9] A. Oh, within that year, yes, but initially, my [10] first visits to the plant were the plant manager and his [11] staff, at the general superintendent level. It's later, [12] when I got more knowledgeable about the plant and was [13] getting down to more specifics, 1 made it a point to get to [14] Mr. Himes and his team. That took several weeks or months [15] to get to that point. [16] Q. Would it be fair to say that by the end of the [17] first year or within the year of 1977, you would have [18] teamed aboiu Mr. Hendricks and what he !md - his history [19] at the plant? [20] A. Very likely, yes. [21] Q. And can you tell me, if you can, what his history [22] at the platu was?__________________ __________________________ Page 59 [1] A. I don't remember. I just recall that he was an [2] old-timer. [3] Q. Was he an old-timer that had some special [4] resource value in the environmental area? [5] MR. SARFATTI: Objection; vague. [6] BY MR. MANTA; [7] Q. I'll tell you what; I'm just trying to find om [8] why you worked very closely with Mr. Hendricks when you were [9] Director of Environmental Operations for MCI. [10] A. Well, I didn't let my position inhibit me from [11] talking to anybody that I thought might be helpful to me. I [12] relied quite a bit - in fact, almost totally - on my staff [13] to do the day-in, day-out kinds of communications, and [14] participation, and whatever was appropriate, but I also felt [15] that I would benefit by making a point to sit down with Mr. [16] Himes' team on a one-on-one basis and have lunch with them, [17] even, and [18] Q. Okay, why don't we go back to - I tlwuglu l [19] could clarify my question, but why don't we go back to the [20] question that was objected to on the grounds that it was [21] vague and have it read back. [22] THE COURT REPORTER: | Page 60 | [1] "Q. Was he an old-timer that had some special [2] resource value in the environmental area?" ; [3] MR. SARFATTI: Repeat the same objections. I [4] A. If we are both using the same understanding of | [5] the word "resource," I'd have to say yes, he was. [6] BY MR. MANTA: ACE-FEDERAL REPORTERS, INC. 202-347-3700 Page 53 to Page 60 WATER PCB-SD0000068676 BSA Depo of: WILIiAM PAPAGEORGE Monsanto v Aetna January 13, 1993 CR: 54034.0 XMAX(IO) [7] Q. Mr. Hendricks could give you some history on [X] emironmental issues at the Texas City Plant; is that right? [9] A. Yes, be was in a poatioo to give me some [10] history. I bad no way of knowing how accurate it was or how [11] thorough it was, but be was, he was a guy that was there [12] before Miss Reid, and Mr. McCauley, and even Mr. Himes. [13] Q. Would you ever contact Mr. Hendricks after he [14] retired, to find out information? [15] A. I never did, no. [16] Q. Would your staff also have worked closely with [17] Mr. Hendricks? [18] A. Oh, certainly. [19] Q. Did Mr. Hendricks have a title at the Texas City [20] Plant? [21] A. Oh, I'm sure he did. I just don't remember it. [22] Q. Now, Ms. Reid, you had also mentioned that you Page 61 [1] worked with Ms. Reid. Can you tell me approximately when [2] you would have first began working with Ms. Reid? [3] A. Of course, I don't recall the exact date, but it [4] seems to me that it happened in the early Eighties. It [5] wasn't the Seventies, so it was, the best guess 1 can, the [6] best estimate I can come up with is HO to '83, somewhere in [7] there. [8] Q. And did she basically take Ed Hendricks' place? [9] A. Oh, I don't know that she could ready take his [10] place. Assigned to the opening that occurred when Mr. [11] Hendricks was no longer available. [12] Q. She then, though, became one of the resources for [13] you at the Texas City Plant. Would that be correct? [14] A. Well, for me and my time, really, not just to me [15] alone. [16] MR. MANTA: Okay. We can break now. [17] (Luncheon recess from 12:10 to 1:25 p.m.) [18] AFTERNOON SESSION [19] MR. MANTA: Why don't we start by putting on the [20] record [21] MR. SARFATT1: The stipulation? [22] _____ MR. MANTA: No, what's going on. Page 62 [1] MR. SARFATTI: Oh, with the documents'? [2] MR. MANTA; Yeah. [3] MR. SARFAlTl: Okay. Have you guysdiscussed and [4] decided what you want to -- [5] MR. MANTA: We have, yes. What we are going to [6] do, here, is put on the record, at least, our position. [7] MR. HUGHES: Go ahead. [8] MR. SARFATTI: Let me state what theissue is. I [9] think we had our conversation before the break, off the [10] record. The situation is that in lieu of a seven-day list [11] tor the Papageorge deposition, we received it on Saturday, [12] by Federal Express, the documents that were designated on [13] the seven-day list. We were later informed Monday afternoon [14] that Mr. Manta's office had designated an additional [15] document, and we were informed on Friday by Mr. Hughes' [16] office that there were a series of additional documents that [17] were designated. We were assured that we would receive from [18] Mr. Hughes' office the additional documents on Saturday. We [19] did not. A letter was sent to Mr. Hughes' office to the [20] attention of Mr. Brown, advising him of that fact. [21] .An attempt was made yesterday to send us those [22] documents by telecopy to my hotel. Only a portion of the Page 63 [1] materials arrived, and apparently they are not yet [2] available. [3] With regard to Mr. Manta's document, that was [4] received yesterday, the day before the deposition. While [5] certainly 1 can understand while from time to time there may [6] be a need, after seven days, to designate additional [7] documents, in this case we're prepared to try to accommodate [8] defense counsel and allow the use of those documents, [9] subject to conditions. [10] One of them is that we have an opportunity to [11] consult with the witness about those documents with the [12] permission of defense counsel. [13] The second is that in the future, with regard to [14] a deposition (hat Monsanto may initiate, if we find that we [15] need to supplement one of our own seven-day list [16] designations, that we be permitted to do so without [17] objection by defense counsel. If those conditions are [18] acceptable to Defendants in this case, we'll be prepared to [19] allow you to use those documents. [20] MR. MANTA: Okay, the first condition is [21] acceptable. The second condition is not acceptable, and I'd [22] just like to put on the record that these depositions -_______ Page 64 [1] this has come up before, both Monsanto witnesses and [2] insurance company defendant witnesses, and in that m situation, in the situations where it has come up, it has [4] been addressed on a deposition-by-deposition basis, using a [5] rule of reason. Mr. Papageorge's witness file was in excess [6] of 25 boxes, or approximately 25 boxes. We had [7] substantially reduced the volume of material. I don't think os] we sent to Mr. Sarfatti more than two boxes. [9] In addition, the document that was sent to Mr. [10] Sarfatti on Tuesday, I believe, is less than thirty pages. [11] It's most certainly less than fifty pages, I think. [12] MR. SARFATTI: It is. [13] MR. MANTA: And I had indicated to Mr. Sarfatti [14] that I would be willing to identify the pages that I want to [15] use and that he could consult with the witness about those [16] pages. That offer was rejected. I don't feel that [17] MR. SARFATTI: No, no offer has been rejected, [18] I've just stated two conditions. One is that if you make an [19] exception to the seven-day requirement of the case [20] management order in this case, we expect that there will be [21] no objection in the case of any other one deposition where [22] we, Monsanto, face a similar situation, and unless you can Page 65 [1] give me that insurance, I don't see any reason why I would [2] should, why we should try to accommodate you. [3] MR. MANTA: What I'm saying is, I would not [4] accept those two conditions and made a counteroffer. [5] MR. SARFATTI: Condition number one. [6] MR. MANTA: Accepting condition number one, my [7] offer is, I will identify the particular pages within that [8] document that I'll use, and if that's satisfactory, we can P] go ahead, we'll use the document. [10] MR. SARFATTI: The fact that there may be only [11] certain portions of a document which you use is not of [12] particular concern or interest to me. What's of concern to [13] me is that if Monsanto accommodates Defendants' late [14] designation and late production of documents in this [15] instance, including a document that has yet to be produced [16] to us in its full form, we don't expect to face a similar [17] situation where we are required to supplement our [18] designation, yet receive objections from Defendants as to [19] the use of a handful of documents supplementary designated [20] at a deposition that we designate. If that's a problem, [21] then we have, you know, then there's a major issue here. [22] _____ MR. MANTA: Well, 1 think so.____________________ Page 66 [1] MR. SARFATTI: And I don't think that we're [2] prepared to create an exception unless we have an insurance [3] of reciprocity, and we're not asking for more than [4] reciprocity. [5] MR. MANTA: l think there's been reciprocity, but [6] ITI[7] MR. HUGHES: I'd like to say something for the [8] record, too, Steve. In our case, I believe it's an issue of P] four documents comprising about twelve pages. It was my [10] understanding that that supplemental list of four documents [11] was faxed out one day late, and I believe that Monsanto has [12] had adequate opportunity to pull those documents, those [13] twelve pages. [14] MR. SARFATTI: We received it, in fact, two days [15] late, I believe. [16] MR. HUGHES: It should have been one day late. I [17] can check on that fact. [18] In any event, I know there was also - I wasn't [19] there to take care of it - we did agree to get those [20] documents to you, and for whatever reason that that hasn't Page 60 to Page 66 202-347-3700 ACE-FEDERAL REPORTERS; INC. WATER PCB-SD0000068677 BSA Depo of: WILLIAM PAPAGEORGE Monsanto v Aetna January 13. 1993 CR: 54034.0 XMAX(ll) [21] occurred, so be it, and l certainly will still attempt to do [221 that.__________________________'______________________________ Page 67 [1] I'd also like to point out that we have been [2] accommodating, 1 believe, the defense group, in this very [3] deposition. 1 believe, through no fault of Mr. Papageorge, [4] I don't believe Monsanto adequately put him on notice as to [5] where he might be expected to be for this deposition, and [6] as - and how long he would be expected to be there, based [7] on his testimony this morning. We have agreed to come when [S] we were all expecting to be in Wilmington to come to St. [9] Louis and accommodaleed Monsanto on a very late change in [10] schedule when I believe Defendants could have taken the [11] position that we can't change it on such late notice and [12] we'll have to reschedule Mr. Papageorge, and Monsanto [13] doesn't get any credit days as a result, so we have we have [14] been accommodating. [15] I don't think you can ask either Mr. Manta, or [16] myself, or Mr. Johnson, to make any commitments on behalf of [17] the defense group, as you well know. You are asking for a [18] stipulation that would go to everything, and that is a [19] question that would have to be presented to the defense [20] group steering committee, as l think you know in having [21] dealt with Defendants in the past. If you are going to take [22] the position that we can't use the few documents that we_______ Page 68 [1] have, that's certainly a position you can take, and we'll [2] have to deal with that in the future. That's my statement [3] for the record. [4] (Brief interruption.) [5] MR. HUGHES: In any event. I think it is [6] something to be worked out on a case-by-case basis. One [7] reason I couldn't make any promises is currently, Monsanto [8] is only planning to take one deposition that we're concerned [9] with, and I can hardly make an agreement that would be [10] binding as to all depositions. [11] MR. SARFAll 1: Well, I'm not asking for a [12] commitment as to all depositions. I'm saying in the event [13] tile situation should arise with regard to a deposition that [14] Monsanto initiates, if there is a requirement or a situation [15] where Monsanto needs to supplement its seven-day list [16] designation with a number of documents roughly equivalent to [17] die number that you wish to include in your designations in [18] the Papageorge deposition, that, that we be accommodated, [19] and if you are not prepared to make that stipulation, I just [20] don't see why we should vary from the requirements of the [21] seven-day [22] _____ MR. MANTA: 1 just want to make it clear -___________ Page 69 [1] MR. SARFAl l 1: - provision. [2] MR. MANTA: - that we wouldn't accommodate [3] Monsanto, we're saying that we are not prepared right now to [4] enter and we cannot enter a blanket stipulation. [5] MR. SARFATT1: Okay, you reserve the right - [6] MR. MANTA: That is rewriting the case management [7] order, and I think - [8] MR. SARFAlTl: You are reserving the right - [9] well, we can stipulate to deal with, you know, exigencies [10] like this that occur from time to time. If you need to . [11] consult with your, your own defense group, then I think you [12] should make an effort to do that. I just, 1 just feel that [13] there is a certain unfairness where you are asking us to [14] make an accommodation without agreeing to accord us a [15] reciprocal accommodation if the need should arise. [16] MR. MANTA: I don't need to consult the defense [17] group, because we won't agree to that proposed stipulation. [18] MR. SARFATTI: Verywell, let's proceed. [19] MR. HUGHES: Let's get it clear. Is it going to [20] he. then, your posiuon we cannot use those documents? [21] MR. SARFATTI: Yes. [22] _____ MR. HUGHES: Okay. Well, you should expect the Page 70 [1] same kind of cooperation back. You asK what's the reason [2] you should stipulate? Cooperation in getting this very [3] difficult, very heavily scheduled case completed in a [4] relatively professional manner; and if you are not - I [5] would expect Monsanto to want to do this on a [6] deposition-by-deposition basis, so that there is no abuse by [7] Defendants where there is some mix-up, and I would think [8] that you would understand that Defendants, as well, would [9] want to consider it on a deposition-by-deposition basis. [10] MR. SARFATTI: Well, I beg to differ. The [11] premise of my request is to avoid possible abuse by defense [12] counsel where Monsanto finds itself in a situation where it [13] has to designate some additional documents, only to appear [14] at the deposition and find that defense counsel refused to [15] permit the witness to testify with regard to them. That's, [16] that's the objective of, of my request, to prevent discovery [17] abuse, not to lead to it. [18] MR. MANTA: Okay, can you tell me, do you know of [19] one situation where that's happened? [20] MR. SARFATTI: No, I don't know of one situation [21] they're where it's happened, and I can't tell you a specific [22] situation where it's been accommodated, and I just, I'm________ Page 71 [1] shocked that there's this level of opposition to my request PI for reciprocity. [3] MR. HUGHES: Well, are you saying, then, that [4] Monsanto is willing to stipulate that in any deposition, [5] you'll let Defendants use documents that they don't give to [6] you until the last day? [7] MR. SARFATTI: No, I'm simply requesting that in [8] the event it should occur, once in the future, involving a [9] similar quantity of documents which aren't produced at the [10] time as part of the seven-day procedure, that we be [11] accommodated without risk that the Defendants will, for some [12] reason, arbitrary or not, refuse us to have those documents [13] marked. I'm not asking for a blanket stipulation, just [14] reciprocity, which is one instance in the future, if it [15] should ever arise. I mean again, I'm shocked that I'm [16] getting this level of opposition. [17] MR. BRODERICK: Would that be in circumstances, [18] for example, where there was significant accommodation on [19] the part of Defendants to come to a location far away from [20] where it was originally expected? [21] MR. SARFATTI: No, that's a separate issue, and I [22] think and as will be brought out, I think, later in the__________ Page 72 [1] testimony, there is, there was an emergency situation that [2] necessitated this witness being in the St. Louis area during [3] this week. The question wasn't asked as to what the [4] emergency was, but when the opportunity arises, there'll be [5] further questions on that subject. [6] MR. MANTA: One last proposal. Could I use the [7] title page? The first page? [8] MR. SARFATTI: You know, to be perfectly honest, [9] I really, I couldn't tell you what the title page is. [10] During the next break, if you want to point it out to me, [11] I'll lake a look at it. [12] MR. MANTA: Okay. [13] MR. MANTA: Well, let's get started. [14] BY MR. MANTA: [15] Q. Could you tell me, Mr. Papageorge, what your [16] involvement was with Monsanto's world-wide environmental [17] guidelines? [18] A. I was privileged to see drafts as these [19] guidelines were being prepared. I was asked to comment. [20] Today, I don't remember what comments I made, but I was part [21] of the group that was asked to critique these thoughts and [22] help develop the final version.______________________________ Page 73 [1] Q. Why did Monsanto come up with these guidelines? [2] MR. SARFATTI: Objection; no foundation. [3] A. I can't speak for Monsanto in the way that I j [4] understand you mean. I just don't know whose thought it j was ! [5] that such guidelines should be prepared, so I don't know j [6] that - I can't answer it. i [7] BY MR. MANTA: | [8] Q. Was it done in cotmection with the Environmental I [9] Policy Committee? ACE-FEDERAL REPORTERS, INC. 202-347-3700 Page 66 to Page 73 WATER PCB-SD0000068678 BSA__________________________ Depo of: WILLiAAl PAPAGEORGE Monsanto v Aetna January 13, L993 CR: 54034.0 XMAX(12) [10] A. VVefl, they were certainly involved. I don't know [11] who the editor or author was. [12] Q. Who asked you to take a look at drafts? [13] A. I, today, don't know, don't remember. [14] Q. You don't recall what the purpose of these [15] guidelines was? [16] A. I think they were self-explanatory. If you read [17] the guidelines, I think they, they're pretty [18] self-explanatory. [19] Q. But you, as the Director of Environmental [20] Operations for MCI, don't ktww exactly why they came up with [21] these guidelines? [22] _____ A. 1 can't speak for the person or persons who_______ Page 74 [1] thought of the idea and promulgated the program and [2] guidelines. [3] MR. MANTA: We're up to 2. [4] (Papageorge Deposition Exhibit 2 marked for [5] identification.) [6] A. I don't remember this document. [7] BY MR. MANTA: [8] Q. I'll get to that. [9] Exhibit 2, Papageorge Exhibit 2, is an August SO, [10] 1977, memorandum. The subject is, "Worldwide Environmental [11] Protection Guidelines," and die identification numbers are [12] WGK 1202162-WGK 1202164. [13] On die right-hand column, there's a "cc" list and [14] it has "W. B. Papageorge. " Is diat referring to you ? [15] A. WeD, that's my name, yes, sir. [16] Q. You don't know of any odier Papageorge, do you? [17] A. Not that I - not with those initials. [18] Q. Is E3NJ your mailbox at St. Louis? [19] A. Essentially, that is my location, office [20] location. [21] Q. Now, you had said dial you don't recall seeing [22] this. Is diat right?__________________________________________ Page 75 [1] A. That is correct, yeah. It's been awhile. [2] Q. Can you look at die second sentence of die first [3] paragraph? Says, "I believe vwe all agree diat [4] implementation of these guidelines will reqidre significant [5] plant resources over die next five years. " [6] Can you tell me why implementation of die [7] guidelines would require a significant amount of resources? [8] A. WeD, that's Mr. Pierie's evaluation of the [9] situation. I, I don't really know what he had in mind in [10] terms ofwhat it took to do what these guidelines refer to. [11] Q. Do you have any idea why die guidelines would [12] cost a significatU or reqidre significaru plant resources [13] over the next five years? [14] A. At this point in time, I am in no position to [15] iinswer because I don't really recall, I honestly don't [16] recall what was in place to start with in order to determine [17] what else was needed to meet the objective. [18] Q. Can you tell me aboia die, die guidelbie [19] concerning plant assessments or plant-wide environmental [20] assessments? [21] A. I recall the program. I don't recall the [22] details._____________________________________________________ Page 76 [1] Q. What do you recall about die program? [2] A. As best as I recall, it had to do with an [3] evaluation to be made of the plant and its operations in the [4] various streams and emissions, to establish a, a data base [5] to help the management determine what, if anything, would be [6] required to make changes. [7] Q. Were diese plant assessments somediing that [8] started when you began as Director of Environmental [9] Operations widi MCI? [10] A. The program was instituted shortly after that, [11] yes, sir. Mm-hmm. [12] Q. Turning to page -- die next page, it looks as if [13] it's in die mtmbered heading "3," ''Mabitam Plant [14] Environmental Assessment Documents. " Did you maintain plant [15] environmental assessment documents as Director of [16] Environmental Operations for MCI? [17] A. Did I, personally? [18] Q. Yes. [19] A. No. [20] Q. Who did? [21] A. Somebody at the plant. It could be anyone the [22] plant manager designated.__________ Page 77 [1] Q. And what manager would diat have been? Would it [2] have been Mr. Pierte? [3] A. No, I said the plant manager. [4] Q. Oh,okay. Not your manager. [5] A. No. [6] Q. The first sentence says, "The guidelbie requires m die completion of uiidal environmental assessmem surveys [8] by January 1, 1980." PI To your knowledge, were assessment surveys [10] completed by January l, 1980, for the Texas City Plant? [11] A. I don't recall if all of them were completed on [12] that date, nor do I recall that some were not. I just don't [13] remember. [14] Q. Do you have any specific recollection aboia the [15] Texas City survey? [16] A. No, I don't [17] Q. Can you tell me if these surveys addressed areas [18] outside the plant? Waste disposal areas that the plant may [19] have used? [20] MR. SARFATT1: Objection; no foundation. [21] A. Again, I don't recall any reference to outside [22] areas. I just don't recall. Page 78 [1] BY MR. MANTA: [2] Q. Did you receive acopy of die plant assessments [3] as diey were done ? [4] A. I don't remember actually holding a copy in my [5] hand, but that doesn't mean it didn't happen. I just - [6] Q. Would it be part of your practice as Director of [7] Environmental Operations for MCI to review such documents? [8] And by diat, I mean die plant environmental impact m assessments. [10] A. Can you help me with "review"? Do you mean [11] peruse and become knowledgeable with it or to comment on it? [12] I- [13] Q. Well, I would, I would think bodt, but let me ask [14] it diis way. As part of your responsibilities as Director [15] of die Environmental Operations for MCI, one of die [16] responsibilities you had was to - and I'm paraphrasing [17] here, and you can tell me if I'm wrong, but basically, leam [18] the environmental issues at die plants for which you were [19] responsible for and keep up widi diem. Is diat correct? [20] A. To a degree, it's correct. I was not expected to [21] notice finite details of everything that occurred at that [22] plant regarding environmental issues. I was expected to Page 79 [1] know enough to be able to sense responsible behavior or [2] whether cooperation was there or not, and so on. I relied [3] primarily on the plant to do its job and I relied on my [4] staff to monitor and act in my behalf, so I was really sort [5] of almost three steps removed from the actual nitty-gritty [6] work that was going on. [7] Q. Do you diink you would have reviewed an [8] environmental impact assessment for die Texas City Plant? [9] A. I don't remember, really, the document, but I do [10] remember many documents. It's kind of a fuzzy picture at [11] the moment. [12] It just doesn't stand out in my memory. [13] Q. Reading any of diem ? [14] A. I recall reading some. I don't recall which [15] ones, I don't recall how many. [16] MR. MANTA: For the record, the document that I [17] provided to you, Mr. Sarfatti, I believe, is a Texas City [18] environmental impact assessment. Whether there's more than [19] one or that's it, I don't, I don't know. [20] BY MR. MANTA: [21] Q. Did you have any understanding as to die purpose [22] of die environmental impact assessments? Page 73 to Page 79 202-347-3700 ACE-FEDERAL REPORTERS, INC. WATER PCB-SD0000068679 BSA Depo of: WILLIAM PAPAGEORGE Monsanto v Aetna January 13, 1993 CR: 54034.0 XMAX(I3) Page 80 [1] A. I had an understanding, yes, sir. [2] Q. Okay, could you tell me what that was? [3] A. It was, in a way, a candid camera shot of where [4] (lie plant stood regarding its environmental affairs at that [5] particular time. [6] Q. Would you expect that it would identify major [7] issues of concern? P] MR. SARFATTI: Objection; opinion, and vague. [9] A. If I understand your question, you said "Would 110] you expect it to contain [11] BY MR. MANTA: [12] Q. Would you expect the environmental impact [13] assessment to identify the environmental issues of concern [14] at that time? [15] MR. SARFATTI: Same objections. [16] A. Well, it would identify the situation. Now, [17] whether they were matters of concern or not depends on a [18] second thought process on somebody's part back at the plant. [19] BY MR. MANTA: [20] Q. Okay, would it he back at the plant or would it [21] he something that would be relayed to people in St. Louis? [22] ______ A. The plant is responsible for its activities, its_________ Page 81 [1] operations; it stands on its own. It can use others to help [2] it arrive at decisions on what to do, it can use others to [3] get resources, but it remains a plant responsibility. [4] Q. Would you have been concerned or would you have [5] taken any action with regard to major issues identified in a [6] impact assessment? [7] MR. SARFATTI: Objection; hypothetical. ffl A. If my staff members came to me asking for my [9] assistance in getting resources or getting the proper [10] attention to a matter they thought was important, I would [11] then step in and try to help. Unless I received that [12] request, I would rely on the people assigned to do these [13] things at the plant to do them properly, and my staff would [14] monitor that activity, to see that it met the state or [15] federal regulations or Monsanto's policies, and so on. [16] BY MR. MANTA: [17] Q. For specific problem-solving tasks or solvbig a [18] particular environmental problem, is that something that you [19] would be involved m? [20] MR. SARFATTI: Objection; hypothetical. [21] A. If I'm invited to participate, certainly I'd be [22] involved. If I am informed that the matter isn't getting_____ Page 82 [1] appropriate attention, I would get involved. [2] BY MR. MANTA: [3] Q. Would you get involved if neither of the two [4] things that you just mentioned happened but you had reviewed [5] an impact assessmetu that raised some questions? [6] MR. SARFATTI: Objection; hypothetical, and [7] vague. [8] A. Raised some questions where? In the author's P>] mind, or - [10] BY MR. MANTA: [11] Q. I'm trying - all I'm trying to do is understand [12] if - what action you would take, personally, with regard to [13] an issue raised in an environmental impact assessment. [14] A. I would take no action until I had evidence that [15] the situation is not being addressed appropriately. Say a [16] long period of time goes by, nothing happens, or I would get [17] information from my staff or from the plant directly that [18] they bad applied for funding and the money hasn't been [19] appropriated yet and they couldn't move until they got so: [20] Under those conditions, I would step in and try to go to bat [21] for them. I would not meddle with the plant's affairs [22] directly, because that's the plant manager's responsibility Page 83 [1] and they don't like meddling from a home office. [2] Q. Was that true with areas other than [3] environmental? [4] A. That's generally true. Being a plant manager, I [5] can vouch for that. [6] MR. MANTA: This is Exhibit 3. [7] (Papageorge Deposition Exhibit 3 marked for [8] identification.) [9] BY MR. MANTA: [10] Q. Looking at Papageorge Exhibit 3, it is a draft [11] dated 6-9-78, bearing Bates number CBY 1303023- CBY1303049. [12] I'd tike you to take a moment and look through [13] this document, as well as the last few pages, which indicate [14] distribution, and tell me if, if you are familiar with this [15] doctanent. [16] MR. SARFATTI: This is an approximately 25-page [17] document. Do you want him to read page after page or just [18] skim through it? [19] MR. MANTA: I just want to know if he's familiar [20] with the document, if he's seen it before. [21] MR. SARFATTI: Very well. [22] (Witness peruses said document.) Page 84 [1] A. I can't place it. [2] BY MR. MANTA: [3] Q. There's references on the docitment to slides. It [4] appears to have been an outline of some sort of [5] presentation. The title of the document appears to be [6] "Environmental Operations MCI." Mr. Papageorge, do you [7] think if there was a presentation concerning environmental [8] operations of MCI, that you, as Director of Environmental [9] Operations MCI, would have attended? [10] A. That's a good likelihood, yes, sir. [11] Q. Now, I'd like to direct your attention to - it's [12] page 3 of the document. [13] A. The third sheet? [14] Q. Mm-limm. [15] A. Yeah, okay, I see it. [16] Q. And I'd like you to read the - in the middle [17] paragraph, slide 4, there's a statement, last sentence says, [18] quote, "Simply stated, the environmental policy staff has [19] the responsibility for developing corporate positions and [20] actions related to environmental matters through the [21] operating company. Environmental operations departments [22] insure consistency throughout the corporation." Page 85 [1] My question is, is it your understanding that the [2] Environmental Operations Department implemented policy [3] created by the environmental policy staff? [4] A. No, they monitored the implementation at the [5] plants, to assure consistency. They were sort of the [6] watchdogs. [7] Q. Who were the watchdogs? [8] A. The environmental operations team monitored [9] activities at the plants, to ensure consistency with [10] corporate positions and actions. [11] Q. Now, mas part of that monitoring the plant [12] environmental assessments? [13] A. I suppose that the plant environmental assessment [14] could be a starting point for the monitoring, a "Where do [15] you go next" kind of look-see. [16] Q. Where does who go next? [17] A. Where does the plant go. Here's your, your [18] candid camera shot; here's where you are today; where do you [19] want to be, what does it take to get there so that you [20] comply with the corporate policies and actions. [21] Q. Would you review the plant environmental [22] assessments to insure compliance with Monsanto's corporate Page 86 [1] policies? [2] A. Someone in my - on my team would review it, for [3] sure. I may, on occasion, see some of these assessments or [4] parts of assessments. [5] Q. Okay, l`d like to mm to page - and I'm going [6] to refer to the microfilm number on the right-hand side, CBY [7] 091626. [8] A. I have it. m Q. Does that refresh your recollection as to the [10] plant environmental assessments? [11] A. The, the statement about establishing and [12] maintaining assessments, I was tuned in on that one all [13] right, but the date, I see it, there, January 1, 1980, but I ACE-FEDERAL REPORTERS, INC. 202-347-3700 Page 80 to Page 86 WATER PCB-SD0000068680 BSA Depo of: WILLIAM PAPAGEORGE Monsanto v Aetna January 13, 1993 CR: 54034.0______________________XMAX(14) [14] really don't remember it. [15] Q. Now, you said you wouldn't maintain the [16] environmental assessments; is that right? [17] A. I wouldn't maintain it. [18] Q. You wouldn't keep a copy of the plant [19] environmental - [20] A. My staff would. The team would, in its files, [21] yes. [22] _____ Q. And this is part of Monsanto's Worldwide____________ Page 87 [1] Environmental Protection Guidelines, right? These plant [2] environmental assessments be conducted and maintained? Is [3] that right? [4] A, That's, that's the stated word here, yes, sir. [5] Q. Bia that doesn 't refresh your recollection as to [6] these, these assessments or documents? [7] A. I didn't say that. I know that there were [8] assessments made, I know that there was a policy relating to [9] those assessments. What I didn't - what I can't recall is [10] that January 1, 1980, date. [11] Q. Would you be in charge of seeing to it that the [12] assessments were completed? [13] A. No, that responsibility rested with the General [14] Manager of Manufacturing, to whom the plants reported. [15] Q. And wlu> would that be at that -- at, say, between [16] 1977 and 1983? [17] A. That would have been Earl Brasfieid. [18] . Q. Are you familiar with hydrogeological evaluations [19] that were separate and apart from the environmental [20] assessments? [21] A. Where? [22] _____ Q. In your position as Director of Environmental________ Page 88 [1] Operations for MCI, that various plants, in addition to [2] having environmental impact assessments, had [3] hydrogeological [4] A. You keep using the word "environmental impact [5] assessments." These assessments are not environmental [6] impact assessments. They are plant environmental [7] assessments. No attempt was made to determine the impact on [8] the environment. [9] Q. Okay. I'm sorry, l misspoke. [10] A. And, and I'm trying to remember your question, [11] now, regarding the - [12] Q. Hydrogeological surveys. Do you recall those [13] doettmetus? [14] A. With reference to hydrogeological surveys, I do [15] know that such surveys were made at several Monsanto sites [16] nt different times, through, over a decade that I was [17] involved. The execution of those surveys was a decision of [18] the plant, based on their assessment of the situation that [19] existed at each plant. If the management of the plant [20] decided that they needed such a survey, they would go ahead [21] and arrange for it. [22] _____ Q. Do you recall such a survey for the Texas City_______ Page 89 [1] Plata? [2] A. I do not, but that doesn't mean it happened or [3] didn't happen. I just don't recall that. [4] Q. Now, from what you said, 1 tmderstand that not [5] all plants had this type of survey done and that it was up [6] to the pla/U if they wanted to have one done? [7] A. No, no, it's up to the plant to decide whether [8] one was required, based on the conditions that existed at [9] each plant. [10] A plant that spins nylon fiber, for example, may [11] not perceive a need for a hydrogeological survey because [12] it's - their operation is such that it happens in a dry [13] room, and the wheels are spinning and the fiber is made. [14] Why do a hydrogeological survey? So it really is based on [15] the conditions that exist at the she. [16] Q. Do you know approximately when these [17] hydrogeological evaluations were completed? [18] A. No, I don't know this that they were - that one [19] can say they were ever completed. The conditions are I [20] monitored every day of the work week and some day, some i [21] someone may come up and say, "I need a study." [22]Q. Can you tell me what conditions would warrant a Page 90 [1] hydrogeological survey? [2] MR. SARFAt 11: Objection: lack of foundation, and [3] opinion. [4] A. Not being a hydrogeologist, I find myself in a [5] position where I really can't give you a good answer on [6] that, a meaningful answer. [7] BY MR. MANTA: [8] Q. You could tell me what conditions didn i warratu [9] a hydrogeological survey. [10] MR. SARFAT I t: Same objections. [11] BY MR. MANTA: [12] Q. And you were Director of Environmental Operations [13] for, among other plants, the Texas City Plata, and I would [14] take it that you are familiar with the operations at the [15] Texas City Plant. Is that right, generally? [16] A. Generally familiar,yes. [17] Q. Let me ask the question this way, then. What [18] about the Texas City Plant would warrant a hydrogeological [19] evaluation? [20] MR. SARFATIf: Same objections. Lack of PI] foundation, and opinion. [22]A. Well, again, I, not being a hydrogeologist, I Page 91 [1] don't know what conditions must exist underneath that plan [2] to require special attention being given to those substrata [3] formations. [4] MR. MANTA: I'm going to have to object to the [5] objections that are made by Counsel for Monsanto on the [6] grounds that I believe that they are improper coaching [7] objections, prohibited by the Special Discovery Master's [8] order in this case, and I think that those objections are in [9] violation of that order, and if it continues, I think we're [10] going to have to talk to the Special Discovery Master, [11] because I don't think that objections on the ground of [12] opinion, or foundation, or what have you are permitted, and [13] I think they are coaching objections. [14] MR. SARFATTI: Well, we disagree with you, and we [15] are prepared to state our objections and a brief ground for [16] them without getting involved in any colloquy. [17] MR. MANTA: I don't think colloquy was the issue, [18] but [19] BY MR. MANTA: P0] Q. Mr. Papageorge, do you have any opinion as to why PI] a hydrogeological evaluation of the Texas City Plata would [22] be warranted? Page 92 [1] MR. SARFATTI: Same objections. [2] A. 1 don't know that I have a personal opinion, I [3] would suggest that if the plant decided to have one, I would [4] have supported it. That's the position 1 was in at the [5] time. [6] BY MR. MANTA: [7] Q. Would you ever suggest that a plant have such an [8] evaluation, based upon your knowledge of the platu's [9] operations? [10] A. Oh, I wouldn't have enough knowledge to make such [11] a suggestion. [12] (Papageorge DepositionExhibit 4 marked for [13] identification.) [14] BY MR. MANTA: [15] Q. Mr. Papageorge, you've been slutwn what's been [16] marked for identification as Papageorge Exhibit 4. It's a [17] July 28, 1978, memorandum. Subject is "Known Curretu [18] Monsanto Environmental Issues. ' The Bates number is WHP [19] 0267022 - WHP 0267039. [20] I d ask you to take a look at this document, just PI] flip through it, and tell me if you've ever seen it before. [22](Witness peruses said document.) Page 93 [1] A. I don't recall it. I may or may not have seen [2] it. [3] Q. Did you - Page 86 to Page 93 202-347-3700 ACE-FEDERAL REPORTERS, INC. WATER PCB-SD0000068681 BSA Depo of: WILLIAM PAPAGEORGE Monsanto v Aetna January 13, 1993 CR; 54034.0 XMAX(15) [4] A. I just don't recall it. [5] Q. I'm sorry for interrupting. [ft] Do you think it would have been likely that you [7] would receive such a docianent as Director of Environmental [X] Operations for MCI? [9] A. It's possible, but I just, again, 1 don't know if [10] Mr. Jessee ever issued this, frankly. It might have been a [11] work product that he gave to his boss, and I just don't [12] know. [13] Q. Turning to page 5 of the attachment, there's a [14] heading, Roman numeral II, "Product Plant Emissions." Do [15] you have that? [16] A. What page was that, again? [17] Q. Page 5 of the attachment. [IX] A. I see it. I have it. [19] Q. It says, "Compliance with Resource Conservation <5 [20] Recovery Act," and across from that, "Issue Coordinator, " it [21] says, "Sayers. " Can you tell me who Mr. Sayers is, [22] S-a-y-e-r-s?_________________________________________________ Page 94 [1] A. Richard Sayers was the individual I couldn't [2] recall earlier today, a member of Mr. Throdahl's [3] environmental policy staff. [4] Q. And DEO's, who do they - who does that refer to? [5] A. That refers to the Directors of Environmental [ft] Operations. [7] Q. Would that include you? [X] A. Yes. [9] Q. Okay, that's under the heading of "Prime [10] Responsibility. " [11] A. Yes, as perceived by the author. [12] Q. Do you dispute the indication that DEO's had [13] prime responsibility for certain of the items listed here [14] under, under the Roman tutmeral II? [15] A. I'd have to read it more thoroughly than I am at [lft] the moment. [17] Q. Why don't I ask you this. Item B says, [IS] "Implenunu Environmental Practice GttideUne 2. Establish [19] Monsanto monitored and/or controlled disposition of all [20] wastes. " [21] Would you agree that the DEO's had prime [22] responsibility for that?_______________________________________ Page 95 [1] A. Well, first I'd have to refresh my memory on what [2] Guideline Number 2 was. [3] Q. tV7iy don't we look back on, I believe it's the [4] exhibit that's the overhead or the outline of the [5] presentation. I think it's in there. [ft] It's on the microfilm number 1624. [7] (Witness peruses said document.) [X] A. In my opinion, the prime responsibility for [9] implementing Guideline Number 2 was the plant manager at die [10] appropriate sites. [11] BY MR. MANTA: [12] Q. Why do you think Mr. Jessee would identify the [13] DEO's as having prime responsibility for that? [14] A. You are asking me to step in Mr. Jessee's shoes. [15] Q. .Vo, I'm not asking to you step inhis shoes. I [16] think mv question is just based upon your being a Director [17] of Environmental Operations and working with Mr. Jessee, why [IX] he would identify DEO's has having prime responsibility for [19] Environmental Practice GttideUne Number 2. [20] A. 1 don't know what he's thinking there. I do know [21] that DEO's - it was impossible for a DEO to do that. He [22] didn't have the resources. He didn't have the people, he . Page 96 [1] didn't have the shovels or whatever it took, the buckets to [2] put it in. He's sitting there m St. Louis, 800 miles away. [3] Tlint's, that is not a realistic assignment of [4] responsibility. [5] Q. How about for estabUshutg Monsaiuo-monitored [6] and/or controUed disposition of all wastes? [7] A. Well, that's what the Guideline Number 2 is all [X] about. [9] Q. Okay. So that would, that would be the plant [10] manager? [11] A. It would have to be. He's got the resources to [12] do it. [13] Q. How abotu ultimate responsibility, and not prime [14] responsibility? [15] MR. SARFAll I: Objection; vague. [16] BY MR. MANTA: [17] Q. Would you agree that DEO's had ubimate [18] responsibility? [19] MR. SARFAl'll: Objection: vague. [20] A. I have a problem with the word "ultimate.'' I [21] don't know what that means. If it doesn't get done, he gets [22] hung, or - Page 97 [1] BY MR. MANTA: [2] Q. Basically, yes. [3] MR. SARFAl It: That's the first good question [4] you've asked all day. [5] MR. HUGHES: Butnot literally. [6] A. I did not understand the system was working that [7] way when I was involved. [8] The ultimate responsibility of all activity in [9] Monsanto plants rests with the plant manager. [10] BY MR. MANTA: [11] Q. I'm trying to understand what you did as a [12] Director of Environmental Operations for MCI? [13] MR. SARFATTI: Is that aquestion? [14] MR. MANTA: Yes. [15] MR. SARFATTI: It'sa statement. [16] BY MR. MANTA: [17] Q. If you weren't ultimately or primarily [18] responsible for at least the activities that are identified [19] there, did you have atty responsibility with respect to those [20] activities? [21] MR. SARFAl 11: Objection: vague. [22] A. My responsibility was primarily one of Page 98 [1] communications up and down the organization. [2] The position of the Director of Environmental [3] Operations was perceived to be one that could be removed [4] from the daily pressures of the plant, concentrate on [5] environmental matters, and serve as a help to the plants [6] when they requested it and we could open some doors for [7] them, if necessary, go to bat for them with the upper [8] bosses, to give them support. That's the kind of role we [9] played, here. [10] BY MR. MANTA: [11] Q. Okay, let's turn to page 8 and down to mtmber 9, [12] Worldwide Etivironmental Protection Guideline Number 2. [13] Issue coordinator is Carpenter. Can you tell me who Mr. [14] Carpenter is? [15] A. Mr. Carpenter was the Director of Environmental [16] Operations for the Monsanto Agricultural Chemical Company, [17] Q. That did not include the Texas City PUmt, l take [18] it? [19] A. No. [20] Q. Looking down at D beneath 9, it says, "As [21] required, monitor the contauiment of on-site buried wastes [22] and take corrective action." And prime responsibility, Page 99 [1] again, is identified as DEO's. [2] Is it your understanding that the DEO's had prime P] responsibiUty for item D? [4] A. No, my understanding is that Mr. Jessee thought [5] it ought to be ours. [6] Q. And what's your understanding of who had prime [7] responsibility of item D? [8] A. The plant managers. I [9] Q. Can you tell me if item D refers to only existing i [10] waste disposal sites for buried waste, or does it also refer I [111 to past waste disposal sites? | [12] A. It refers to any waste buried on plant property I [13] within the plant fence. [14] Q. And that would inchtde past disposal at the ! [15] plant? | [16] A. Any buried waste. ACE-FEDERAL REPORTERS, INC. 202-347-3700 Page 93 to Page 99 WATER PCB-SD0000068682 BSA Depo of: WILLIAM PAPAGEORGE Monsanto v Aetna January 13, 1993 CR: 54034,0 XMAX(16) [17] (Papageorge Deposition Exhibit 5 marked for [18] identification.) [191 BY MR. MANTA: [20] Q. Looking at Exhibit 5, it is a September 26, 1978, [21] memorandum with Bates number CBY 2822759 - CBY 2822770. [22] _____ I'd like to direct your attention to the bottom_____________ Page 100 [1] of the page and ask you to tell me if that's your signature. [2] A. That is my signature. [3] Q. Do you lurve any reason to believe that you did [4] not prepare this document? [5] A. No, there's no reason to believe so. [6] Q. Do you recall preparing this document? [7] A. No, I don't, really. [8] Q. I'd like you to take a moment and read the first [9] two paragraphs and let me know if tltat refreshes your [10] recollection as to your involvement with the Worldwide [11] Environmental Protection Guideiuies. [12] A. I, I don't know that 1 said I was never involved [13] with them. I was involved with them. [14] Q. Oh, I'm sorry, 1 didn't mean to say, I don't [15] think I said that you were never involved. [16] A. You said to refresh my memory regarding [17] involvement with the guidelines. Wed, I know I was [18] involved. [19] Q. Can you tell me what your mvolvement was? [20] A. Wed, I was certainly involved as, as 1 mentioned [21] earlier, I believe, that 1 was given the opportunity to [22] review drafts as they were being developed, 1 was aware they Page 101 [1] were being developed [2] Q. Does it refresh your recollection at all as to [3] being uivotved in the implementation of the guidelines? [4] A. Wed, I certainly was involved in making certain [5] that the information was shared with the plants. I do [6] Q. Was it your responsibility tluu -- to see to it [7] that the guideiuies were implemented by the plants? [8] A. My true responsibility was making certain the [9] plants were aware of these guidelines, they were aware of [10] what was expected in terms of progress toward fulfilling ad [11] the requirements of the guidelines. The actual [12] implementation, as I had said earlier, was a responsibility [13] of the site managers. [14] Q. Site matiagers, you mean the plant managers? [15] A. Plant or site, yes, sir. [16] Q. In the second paragraph, the second-to-last [17] sentence reads, quote, "It is important that we integrate [18] the guideluie compliance program into the development of the [19] JRA's and goals for 1979 and subsequent years. ` [20] Why was it important to integrate the Worldwide [21] Emironmental Protection Guidelines into JRA s and goals for [22] 1979 and subsequent years?___________________________________ Page 102 [1] A. Wed, the reference to JRA's and goals refers to [2] Monsanto's program in place at the time for establishing [3] yearly objectives on the part of each employee and measuring [4] progress toward achieving those objectives, and since these [5] guidelines were perceived, first of ad, to be new, a new [6] idea, it was important that people preparing their JRA's and [7] goals for the coming year to include these new thoughts in [8] their goals. [9] Q. And these new thoughts are the Worldwide [10] Emironmental Protection Guideiuies? [11] A. Yes, that's what we're talking about. [12] Q. Okay, just so 1 understand it, so that the [13] guidelines could be carried out. it was necessary to have a [14] mechanism to do tluu. [15] A. Wed, that's one purposes of JRA's. The other is [16] to make certain that this new program becomes ready a way [17] of life within Monsanto, just as other expectations are. [18] Q. Would the JRA's and goals lurve been formulated at [19] the platu level? For the individuals. I'm speaking. [20] A. For plant people, it would be at the plant level. [21] Everybody in Monsanto has, or had them. [22] _____ Q. Biu this, this was a way to get the plant to___________ Page 103 I [1] incorporate some corporate guidelines and goals; is tluu [2] right? [3] A. That was the intent. i [4] Q. Do you have or did you have JRA's when you were l [5] at Monsanto? ' [6] | [7] A. Certainly. MR. MANTA: We have asked, Mr.Sarfatti, for Mr. ; [8] Papageorge's JRA's and goals and have not yet received it i [9] from Monsanto. I designated it, but we don't have it. I [10] Obviously, we can't use it if we don't have it. [11] MR. SARFATTI: We saw your request, which came in [12] by letter last week, and we forwarded it out to Monsanto to [13] inquire into what the status of the production of, of those [14] documents was, and I was advised today that those documents, [15] along with similar documents tor a number of other former [16] Monsanto employees, cannot be located. The search is [17] continuing, but I don't think you can expect that those [18] documents are going to be produced in the near term, if they [19] still exist. [20] BY MR. MANTA: [21] Q. Mr. Papageorge, do you, ui your personal [22] possession, have your JRA's from your employment at__________ Page 104 [1] Monsanto? [2] A. I do not. [3] Q.How about your results reviews? [4] A. I don't have any of that. I [5] Q. Is it your understanding that ultimately, the , [6] JRA's were used in tluu regard? I [7] MR. SARFATTI: Objection; no foundation. I [8] A. I can't speak for how extensively and effectively | [9] that recommendation was implemented, j [10] j [11] BY MR. MANTA: Q. Are you aware that it was rejected? : [12] | [13] MR. SARFATTI: Same objection. A. There again, I'm not aware of acceptance or ! [14] rejection, j [15] BY MR. MANTA: [16] Q. You can't say [17] A. It was not in my position to go over people's [18] JRA's to monitor that. [19] Q. Okay. Do you have any reason to believe that it [20] rejected? [21] MR. SARFATTI: Same objection. [22] _______ A. No more than a reason that it was accepted. I Page 105 [1] just have no reading at all. [2] BY MR. MANTA: [3] Q. Do you know whether your JRA included information [4] on implementation of Monsanto worldwide guideiuies? [5] A. I remember that, yes, there was, yeah. [6] Q. Your JRA did include tluu? [7] A. It had reference to the guidelines. I forget the [8] specific goal that I had picked regarding that guideline. [9] Q. Can you tell me what environmental problems you [10] were aware of at the Texas City Platu iti and about 1977? [11] A. In 1977? I was not aware of any in 1977. [12] Q. How aboiu 1978? [13] A. '78, first, I have a problem with the word [14] "environmental problems." Can you help me with that? Does [15] this mean a regulatory agency was giving them formal [16] documents, or was someone knocking at their door for some [17] purpose? What, what does that cover? [18] Q. Why don't you tell me what you mean by j [19] environmental problems. [20] A. It's a situation where a material is causing some | [21] undesirable effect by its presence. | [22] .______ Q. Okay, putting aside questions of employee____________ | Page 106 I [1] exposure, using your definition of environmental problems, [2] can you tell me what environmental problems you were aware [3] of at the Texas City Plant in about 1978? [4] A. Based on my definition I just gave you, I would [5] say none. [6] MR. HUGHES: Excuse me. Could I hear Mr. [7] Papageorge's definition back? I'm sorry. Page 99 to Page 106 202-347-3700 ACE-FEDERAL REPORTERS, INC. WATER PCB-SD0000068683 BSA Depo of: WTI IJAM PAPAGEORGE Monsanto v Aetna January 13. 1993 CR: 54034.0 XMAX(17) [X] MR. MANTA: Sure. [9] THE COURT REPORTER: [10] 'A. It's a situation where a material is causing [11] some undesirable effect by its presence." [12] MR. HUGHES: Thank you. [13] BY MR. MANTA: [14] Q. How about are you aware of arty govemmetual [15] agency or regulatory compliance issue with respect to the [16] Texas City Plant in about 1977 or '78 7 [17] A. I wsts aware of some interest on the part of the [18] state regulatory authorities regarding something to do with [19] existing disposal sites on plant property. I have [20] difficulty remembering just what year it was that I was made [21] aware of this, and frankly, I've forgotten all the details [22] of what the issue was all about. It had something to do______ Page 107 [1] with a material present in water. That's as good as my [2] memory can help me. [3] Q. Do you know if that is the - referring to the [4] North 80 site? [5] A. I'm not certain. It's either North 80 or South [6] 20, somewhere in that part of the plant. [7] BY MR. MANTA: [8] Q. Do you blow if the material was present in [9] surface water or groundwater? [10] A. I do not associate this particular issue with [11] groundwater. Surface water is what I as best recall. [12] Q. Do you recall if the Texas City environmental [13] impact assessment addressed regulatory compliance problems [14] with respect to the North 80? [15] A. I'm sorry, I didn't hear the first part. Do I [16] recall [17] Q If the plant, Texas City Plata environmental [18] impact assessmetu addressed problems of regulatory [19] compliance at the North 80. [20] A. No, I don't recall that. [21] Q. Okay. How would you have become aware of issues [22] regarding die North SO, or the South 20? Page 108 [1] A. WeD, obviously, somebody told me. I don't know [2] who and when. [3] Q. Would it be likely that it would be Ed Hendricks [4] who would have told you? [5] A. No more or no less likely thnn Mr. Himes, or Mr. [6] Weishaar, or Mr. Pierle, or any one of a dozen people within [7] Monsanto. [8] Q. Do you recall a uaste managemettt study was done [9] by Monsanto in about 1979? [10] A. No. I don't remember an activity by that title. [11] Papageorge Deposition Exhibit 6 marked for [12] identification.) [13] BY MR. MANTA: [14] Q. Looting at what has been marked for [15] identification as Exhibit 6 is a Jatutary J, 1979, study, or [16] mi.vO' management - the subject is waste management study, [17] and the Bates numbers are ANN 1124464.32 -.36. [18] Does this refresh your recollection as to a waste [19] management study completed -- conducted by Monsanto? [20] A. No, it doesn't. I just don't recall this [21] document at all. No. [22] _____ Q. Looting at the first page, there is a reference_________ Page 109 [1] to two. and one of the names listed there is [2] IV. B. Papageorge. Is that you ? [3] A. That's my name, yes. sir. [4] Q. Do you have any reason to believe that you didn't [5] get a copy of this documeru? [6] A. Well, again, no more than that I did get. That [7] jiLSt shows that as an addressee. I just don't recall Pi] receiving it and holding it in my hand, and [9] Q. No. I understand that you don't recall receiving [10] it. hut my question is iust a little differetu, and that is, [11] do you have any reason to believe Oiat you did not receive a [12] copy of this documetu? [13] MR. SARFAl'l I: Objection; asked and answered. [14] A. No more than that 1 did not receive. | [15] BY MR. MANTA: [16] Q. Did you -- / mean, wouldn't the fact that a [17] document is addressed to you, assuming that this is what it [18] appears to be, is there airy reason to think that you [19] wouldn't get documents addressed to you? [20] MR. SARFATTI: Objection; asked and answered. [21] A. Well, you are asking me to say that the mailing [22] system is foolproof and absolutely fauldess, and I don't______ Page 110 [1] know. P] Q. No, I'm not asking to say whether this particular [3] document wound up in your hands in January 3, 1979. I'm [4] asking if you have any reason to believe that you didn't get [5] a copy of it. [6] MR. SARFATTI: Objection; asked and answered [7] three prior times. [8] A. I thought I answered when I said I have no reason [9] to believe I didn't get it anymore than I have reason to [10] believe I did get it. [11] BY MR. MANTA: . [12] Q. The fact that it's addressed to you doesn't give [13] you indication that you would have gotten it? [14] A. WeD, there are lots of things addressed to me [15] that are never mailed. [16] Q. That are what? [17] A. That are never mailed out. The decision is made, [18] "Don't send it." [19] Q- So, then do you have a reason to believe, then, [20] that you - [21] A. No, not for that document, no, sir. [22] _______ Q. Well, you are saying that documents have been_______ Page 111 [1] addressed to you that were never mailed? [2] A. No, I am saying that in the business world that I p] participated in, there have been many situations in which [4] documents such as this are prepared but for some reason or [5] other are never sent out to those listed as potential [6] recipients. I have no way of knowing at this point in time [7] whether this document was actually put into the mail system, [8] that it actually arrived at my desk or someone else's desk [9] and was opened and put in my file for future reading. I [10] have no way of knowing that, nor do I know that that didn't [11] happen. I would be speculating all the way through, since [12] my memory doesn't go back that far. [13] Q. Would it be customary and usual for you to [14] receive documents that were addressed to you1 [15] A. Customary and usual: In the majority of cases, [16] yes, sir, but that does not account for the exceptions. [17] Q. Putting aside situations where documents were [18] prepared and never sent, would you, in the normal course of [19] business at Monsanto, have expected to have received a [20] document then was addressed to you? [21] A. I don't know how to measure that. You are asking [22] me the probability of a document like this, prepared as it Page 112 [1] is, to arrive at my mail basket. Is that the essence of [2] your question? P] Q 1 think my question is pretty clear. You can [4] have it read back, if you'd like. [5] THE WITNESS: Please. [6] THE COURT REPORTER: [7] "Q. Putting aside situations where documents [8] were prepared and never sent, would you, in the normal [9] course of business at Monsanto, have expected to have [10] received a document that was addressed to you?" [11] A. In the normal course of business, a document of [12] this type would likely arrive at my desk, as it indicates. [13] Likely. That doesn't mean it happens every time. [14] BY MR. MANTA: | [15] Q. Was there something flawed with Monsanto's | [16] internal mail system? [17] A. I'm in no position to evaluate the mailing i [18] system. It's a - [19] Q. Well, do you recall specific problems with j [20] Monsanto's mail system where you - I [21] A. Oh, many times I've had a secretary go looking ACE-FEDERAL REPORTERS. INC. 202-347-3700 Page 106 to Page 112 WATER PCB-SD0000068684 BSA Depo of: WILLIAM PAPAGEORGE Monsanto v Aetna January 13, 1993 CR: 54034.0 XMAXU8) [22] for a copy of something that 1 was supposed to have recaved Page 113 [1] from the originator of that document. That, that is not [2] unusual. [3] Q. Looking at the handwriting on the page, can you [4] tell me whose handwriting is that at the bottom? [5] A. I cannot. [6] Q. That says 'File, Environmental Solids, " can you [7] tell me that? [8] A. I do not know whose that is. [9] Q. How about "For your Info," looks to be "Jerry B. " [10] Can you tell me whose handwriting that is? [11] A. I'd be guessing. I don't know. [12] Q. How about up at the top of the page: Can you [13] tell me -- [14] A. There again - I'm sorry, what was your question? [15] Q. I just wanted to know ifyou could tell me you [16] recognize any of the handwriting on the top of the page. [17] A. I do not. [18] Q. I'd like you to take a look at the third page of [19] the document and take a look at the first paragraph and read [20] that to yourself, ifyou would, please. [21] A. The third page of the total document? This is [22] the section marked "Introduction"? Page 114 [1] Q. Right. [2] (Witness peruses said document.) [3] A. I have read it. [4] Q. Does that refresh your recollection as to a waste [5] matutgement study coiuiucted by Monsaiuo m and about December [6] 1978? [7] A. Not particularly. Studies were underway [8] constantly, and I can't differentiate, at this point, one [9] study from another. [10] Q. You don't recall a study that the purpose was to [11] establish the integrity and any potential problems related [12] to the present and past disposal of wastes from Monsanto's [13] manttfacturing operations? [14] A. Like I indicated, there were many studies made, [15] and the objectives, there, that you just stated were present [16] for all of these studies that I vaguely remember. The [17] purpose here is not unique just to this study; it's rather [18] universal for studies of this type. [19] I have no way of saying this is a study that is [20] unique or that it actually was made, and I don't see - this [21] is not a complete report anyway. I don't know, there must [22] be something missing, here. Page 115 [1] Q. The second paragraph of the document says, "78 [2] manufacturing sites, 20 animal product centers and three [3] research laboratories were included in the study. Each [4] location supplied information for the following active owned [5] and operated disposed systems, inactive owned systems, waste [6] disposal property sold, potential toxic contents of [7] systems, " and it goes on. [8] Would you agree that this is a fairly substantial [9] study that was done? [10] MR. SARFATTI: Objection; opinion. [11] A. I, I - it does cover many ideas, here, that are [12] listed. I don't know how to compare it with something else [13] to support the use of the word "substantial." It attempts [14] to cover the areas as listed. I don't know how else to [15] answer that. It's intended to be a good study. [16] BY MR. MANTA: [17] Q. Would it be die type of study that you, as [18] Director of Environmental Operations for MCI in December of [19] 1978, would have been aware of? [20] A. Certainly. [21] Q. Would you have participated in it? [22] A. I may not personally have participated, but my Page 116 [1] team or a member of my team would have been working with the [2] plants to respond to the needs of this study. [3] Q. What would you have done? [4] A. What would I have done? I would have done [5] nothing unless I sorsed that things were not going well, [6] that there was a delay, that there was disinterest, so I [7] would till in, really, where 1 felt I might be able to help [8] out, and otherwise, I would stay out of the way. m Q. You cited two situations; delay and disuiterest. [10] A. Well, that's not intended to be a complete list. [11] Q. I understand that. Would it be your [12] responsibility, then, to ensure duu die project was [13] completed on time? [14] MR. SARFATTI: What project are you referring to? [15] MR. MANTA: The December 1978 study referred to [16] in this exhibit. [17] A. It would not be my responsibility to see that the [18] project was completed on time. [19] BY MR. MANTA: [20] Q. Why would delay be of concern to you ? [21] A. Because I wanted the unit that I represented to [22] be perceived as a responsible group, doing the job property. Page 117 [1] I would somehow be made aware of this, to use the example, [2] delay. I would then make certain that the people who were [3] responsible for the actual execution were aware that they [4] were being perceived to be tardy in their response. I would [5] ask them either directly or through my staff member do they [6] need any kind of special help, what was their problem. If I [7] sensed that they needed more assistance, I would go to the [8] plant organization; to the top man, if necessary. I [9] wouldn't go there unless I felt I had to. [10] Q. You had some ultimate responsibility, dien, to 111] see dial the plants widtin your jurisdiction [12] A. I don't know how to [13] Q. - did what was necessary to complete die study? [14] A. No, the ultimate responsibility - I don't know [15] just exactly what you mean by that, but if the study were [16] not completed and I had done everything I could to stimulate [17] interest and get the study done, the ultimate responsibility [18] as perceived by Monsanto's management would be the plant [19] manager. My responsibility was to make certain that the [20] plant manager understood what was required, when it was [21] required, and to communicate the plant manager's needs to [22] others in the organization to help this plant manager if he Page 118 [1] felt he needed the help, like more people, or more time, or [2] whatever it took. [3] Q. Would you be in a position to reprimand a plant [4] manager duu had not complied? [5] A. I guess any of us would be in a position to [6] reprimand. It wouldn't mean anything. I'm just a staff [7] man. You can tell me "Adios," but [8] Q. It wouldn't be reflected in his evaluations or -- [9] A. Not necessarily, unless 1 felt that this person [10] was abusing that position, then I would go to his supervisor [11] and review it with him and sit down and have an appeal [12] process, whatever it takes to make it known that the problem [13] existed. [14] MR. SARFATTI: Before we go on further with the [15] examination about this particular document, let me just [16] raise a question and concern I have about this document. [17] I'm presuming that the documents that were delivered to me [18] on Saturday - that is last Saturday - in lieu of a [19] seven-day list, includes the documents that are on the [20] listing we received from the Orrick, Herrington firm last [21] week. Am I correct that those two are synonymous, or are [22] they independent lists?________________________________________ Page 119 [1] MR. MANTA: I don't think so. [2] MR. HUGHES: No, those are independent. [3] MR. SARFATTI: They're not intended to cross[4] reference one another? [5] MR. HUGHES: No. No. 1 knew that Mr. Manta had [6] reached an agreement with you to deliver documents in lieu [7] of a designation. I was not in a position to see the [8] documents for various reasons we needn't get into, so my [9] designation had to be independent. So the absence of a [10] document that Mr. Manta uses from my list indicates [11] nothing - Page 112 to Page 119 202-347-3700 ACE-FEDERAL REPORTERS, INC. WATER PCB-SD0000068685 BSA Depo of: WILLIAM PAPAGEORGE Monsanto y Aetna January i3, 1993 CR: 54034.0 XMAX(19) [12] MR. SARFATTI: Okay. [13] MR. HUGHES: - other than I didn't designate it. [14] MR. SARFATTI: Very well. The reason I raise it [15] is because I don't see it, either, on your list, and I don't [16] recall it from the materials that we received from your [IT] office. [18] MR. MANTA: I would hope that it would have been [19] there, because what I have copies of are copies of what was [20] sent to you, so I don't - unless there was some screw-up in [21] copying, which I don't - I'm not saying couldn't have [22] happened -_________________________________________________ Page 120 [1] MR. SARFATTI: I'll accept that. If this is an [2] exception, it sounds like it's inadvertent, and we'll see [3] from what whatever other documents you use whether there's a [4] pattern here. I'm not suggesting that there is; it's just [5] that this is not a document that I recall reviewing in the [6] two boxes of materials that we received last Saturday from [7] your office. [8] MR. MANTA: I believe it was in there, but then [9] again, I can't, I can't say. [10] MR. SARFATTI: I have no objection to you [11] proceeding with this particular document. [12] BY MR. MANTA: [13] Q. Mr. Papageorge, you had noted earlier that this [14] document seemed incomplete, and I would agree with you that [15] it does not seem complete. It seems to reference a much [16] more substantial study than is contained here. If I were to [17] want to find the rest of this document, assuming there is [18] more to it, where would be the best place to look? [19] A. Oh, I don't know about a place to look, but I [20] would suggest - I don't know where these things are stored, [21] personally, any longer, [22] _____ You are asking me where would I go to get__________ Page 121 [1] something like this? What is your question? [2] Q. That's fair. That's fair. [3] A. Huh? [4] Q. Where would you go to get something like this? [5] A. I'd go to Monsanto's Legal Department and see if [6] they had copies. [7] Q. Why Monsanto's Legal Department? [8] A. Well, I guess it's because of my experience with [9] PCB issues and all, that's the, that's the place I go for [10] documents, and I don't know if that's appropriate for this [11] case or not [12] Q. Did you have a -- [13] MR. SARFATTI: I think the witness may have had a [14] little bit more to say, and it's happened for a few times, [15] so if you could pause tor a few moments [16] MR. MANTA: I'm sorry. [17] MR. SARFATTI: - and let the witness complete [18] his response, it might be helpful. [19] MR. MANTA: I'm sorry, Mr. Papageorge. [20] THE WITNESS: I've forgotten, now, what else I [21] was going to say. [22] _____ MR. MANTA: This may be a good time to take a Page 122 [1] break. It's twenty after 3:00. We've been going at it for [2] a little while. [3] MR. SARFATTI: I'm not going to stand in your [4] way. [5] (Recess from 3:23 to 3:40.) [6] BY MR. MANTA: [7] Q. Mr. Papageorge, I'd like to contbuie with Exhibit [8] 6 ami direct your aitetuion to page 2 of the document, and [9] the first sentence [10] A. Numbered page 2? [11] Q. Yes, numnered page 2: I'm sorry. [12] The first sentence luuier the "Decisions and [13] Actions" heading says. "Sltallow, small bore test wells [14] strategically located at the periphery of landfills and [15] impoundments have beeti used effectively to monitor for [16] leachuig." [17] My question is, what sites were they used to [18] monitor for leaching? [19] A. I have absolutely no idea. [20] Q. Could you turn to the first page and tell me, [21] based upon your experience as Director of Environmental [22] Operations for MCI, who on this page would likely know,_______ Page 123 [1] other titan, of course, Mr. Jessee, the answer to my [2] question? [3] A. Reading that sentence that you included in your [4] question, I have no way of knowing whether that sentence [5] applies to Monsanto activity or to the, to the practices [6] being followed by others and the success they may have had [7] with that approach, so I have no way of knowing which of [8] these Monsanto people would be the ones to contact regarding [9] that particular sentence. [10] Q. So you are not sure if it refers to only [11] Monsanto - [12] A. In general. I have no way of knowing. That [13] sentence, there, is a conclusion of the author, but I don't [14] know what it refers to. [15] Q. If tve atm to the title page of the document [16] of the report, which is actually the second page of the [17] document - [18] A. All right. [19] Q. - it says, "Monsanto Waste Management Study," [20] dated December 1978. Would it seem reasonable to you that [21] the reference to the test wells to monitor leaching was for [22] Monsanto locations?__________________________________________ Page 124 [1] A. I find that I would be speculating, frankly. I [2] just - there's nothing in that paragraph to tells me that [3] this approach had actually been used. It sounds like a, an [4] opinion of the author which might fit into such a program. [5] I don't know [6] Q. Why don't - maybe the third sentence will help [7] us out, here. The third sentence on Page 2 reads, quote, [8] "Site assessment programs being conducted as part of the [9] Worldwide Environmental Protection Guidelines will dictate [10] additional needs for monitoring, itpgraduig, or closure of [11] disposal systems. " [12] Now, does that utdicale to you that the reference [13] in the first sentence to monitoring wells for - to monitor [14] leaclung from landfills and impowtdments was for Monsanto [15] locations? [16] MR. SARFATTI: Objection; opinion, no foundation. [17] A. I honestly don't know. [18] Those two sentences can stand alone. The site [19] assessments called for additional needs. Those needs could [20] include the first sentence, small test boring. [21] BY MR. MANTA: [22] _______ Q. Can you tell me what it means that site_______________ Page 125 [1] assessments will dictate additional needs for monitoring? [2] MR. SARFATTI: Same objections. [3] A. I don't quite know how to respond. This sentence [4] seems to me to explain itself. The author concluded that [5] these programs are going to result in these needs. I don't [6] know how else to describe that. [7] BY MR. MANTA: [8] Q. Could it - My readutg of this paragraph is that [9] wells had been installed to monitor leaching and that the [10] site assessments were going to dictate the needs for [11] additional monitoring. Is that a reasonable interpretation [12] of those sentences? [13] MR. SARFATTI: Same objections. [14] A. Well, I find myself interpreting that [15] differently. [16] BY MR. MANTA: [17] Q. Do you know if the site assessments would have [18] included the North 80 or the South 20? [19] A. The intent was to include them. [20] Q. How do you know that? [21] A. Well, just from knowing the program, there were j [22] no exceptions permitted.________ ____________________________ Page 126 . [1] Q. And by the program, you are referring to what? I [2] A. The guideline program we've been discussing ACE-FEDERAL REPORTERS, INC. 202-347-3700 Page 119 to Page 126 WATER PCB-SD0000068686 BSA Pepo of: Will JAM PAPAGEORGE Monsanto v Aetna January 13, 1993 CR: 54034,0 XMAX(20) [3] today. [4] Q. Why would the intent of the program, the [3] Worldwide Protection Guideline program, include the North 80 [6] and the South 20? [7] A. Well, those are on Monsanto property, they were [8] Monsanto owned and operated, and the program did not provide [9] for any exclusions; therefore, they would have been [10] included, [11] Q. Would it include non-Monsanto property? [12] A. I'm not aware of any non-Monsanto property that [13] was evaluated under this program. [14] Q. And by "this program," you are again referring to [15] the Worldwide Environmental Protection Guidelines? [16] A. Correct. [17] Q, You are not referring to this Monsanto Company [18] waste management study? [19] A. That is correct. [20] (Papageorge Deposition Exhibit 7 marked for [21] identification.) [22] ____ (Ms. Scott enters the deposition room.)_________________ Page 127 [1] BY MR. MANTA: [2] Q. Looking at what has been marked for P] identifcation as Exhibit, Papageorge Exhibit 7, it is a [4] March 27th, 1979, document, the subject of which is site [5] assessments, the Bates numbers are CBY 2707267 - CBY [6] 2707283. [7] The "cc" identification, there, has a reference [8] to a Mr. W. B. Papageorge. Would that be you, sir? [9] A. That's my name, yes, sir. [10] Q. The third paragraph of the document says, m the [11] first sentence, "We slwuld continue with our programs to [12] complete the first document by the end of 1980 or earlier, [13] per your JRA's. " [14] Does that indicate to you that your proposal or [13] recommendation that Monsanto's Worldwide Environmental [16] Protection Guidelines be incorporated into JRA's was [17] adopted? [18] MR. SARFAlTI: Objection; opinion. [19] A. I can't speak for Mr. Pierle. There is an [20] implication, there, but again, Mr. Pierle is the best one to [21] itsk that kind of question. He can for sure tell you where [22] be got that idea.___________________________________________ Page 128 [1] BY MR. MANTA: [2] Q. You would agree that the implication is that the [3] JRA's were then used as pan of it? [4] A. That's what this indicates. I have no way of [5] knowing how accurate it is. [6] Q. Can you tell me how often site assessments were [7] to be updated? [8] A. No, I don't remember it. [9] Q. Do you know if they were done more than once? [10] A. Again, I don't remember. [11] Q. As Director of the Environmetual Operations for [12] MCI and includuxg the Texas City Plant, would you expect [13] that they would be completed more than once? [14] A. Not necessarily. There's some of these [15] assessments were ongoing, constantly. You never finish, so [16] I can't say they're completed and redone or that they were [17] ever completed. [18] Q. Can you tell me whether the assessments were [19] designed to identify environmetual issues solely related to [20] Monsatuo's worldwide guidelbies or whether they were broader [21] and would incorporate regulatory issues, regulatory [22] emiroimtental issues?_______________________________________ Page 129 [1] MR. SARFAl 'll: Objecdon; vague. [2] A. I can tell you that when the guidelines were [3] first developed, to the best of my recollection, there were [4] no regulatory standards to be incorporated in those [5] guidelines. These were not available. I can also say that [6] whenever regulatory agencies, whether they be state or [7] federal, did promulgate some regulations, they were, of [8] course, incorporated in the thinking and planning of each [9] plant as it affected them. [10] BY MR. MANTA: [11] Q. And would those regulations and environmental [12] issues be incorporated into the assessmetu? [13] MR. SARFATTI: Same objecdon; vagueness. [14] A. I don't know what you mean, "incorporated." It [15] would certainly be a factor in sitting down and making an [16] assessment of where do we stand today, what needs to be [17] done, if anything. It does become a factor. [18] BY MR. MANTA: [19] Q- Would the assessments also incorporate issues of [20] grotatdwater contamination? [21] A. If it's appropriate, yes. [22] Q. When would it beappropriate? Page 130 [1] A. When there was information that leads the [2] managers of the plant to suspect that groundwater may be P] present, that the groundwater may be affected, or that new [4] regulations have evolved over a period of time that calls [5] for certain requirements. [6] Q. Was this just a public relations thing, the m environmental guidelines? I mean, or was it somethuig m Monsanto really wanted to find out if there were [9] environmental issues as a result of the assessments? [10] MR. SARFATTI: Objection; argumentative. [11] A. I personally never sensed a public relations [12] feature in this. They were not - the public relations [13] representatives were not that influential. The true intent [14] was to do what's right. [15] BY MR. MANTA: [16] Q. Before what got wunanageable? [17] A. Whatever issues may arise if you keep operating [18] in ignorance, so you make your assessment, find out where do [19] you stand. PO] Q. Would you consider the thing the right thing to [21] do to ideiuify areas ofpotential groiaidwater contamination? [22] A. Well, of course, you not only - that's an Page 131 [1] example. You not only determine is the water contaminated [2] or what, what is it contaminated with, to what degree, and [3] where is this groundwater going, what happens on its way to [4] that final destination, what effect, if any, is it having, [5] so it's very complex. It isn't just a matter of grabbing a [6] water sample and finding something. [7] Q. But it was a, a true goal of this program to [8] identify situations where there may be groundwater [9] contamination? Is that correct? [10] MR. SARFATTI: Objection; vague. [11] A. If the information available indicated that that [12] was the responsible way to go, that would be done, yes. [13] BY MR. MANTA: [14] Q. So if there were indication that at a plant, for [15] instance, that there was potential for groundwater [16] contamination or indeed, that it was likely that as part of [17] this program, Monsanto would want to address that issue? [18] MR. SARFATTI: Objection; hypothetical, vague. [19] A. It's, it's really based on the information [20] available to those responsible for the plant. 1 don't know [21] how else to describe it. It's, it's no different than [22] having something come out of the stack and you can see it or Page 132 [1] you eon measure it, and you find that you don't want that to [2] happen, you turn a valve or you put a scrubber in, well, the P] same thing goes with the groundwater bit. You don't just go [4] out grabbing water samples just for the heck of it. You [5] have to have a, a reasonable expectation that that [6] groundwater is going to be affected or could be affected. [7] BY MR. MANTA: P9 Q. And what could you tell me about the expectation P] that the groiaidwater at the Texas City Plant would be [10] affected? [11] MR. SARFATTI: Objection; no foundation. [12] A. Oh, I - that would take a hydrogeologist to [13] arrive at any decision regarding that kind of a, a. [14] Q. Can you tell me [15] A. - effect. Page 126 to Page 132 202-347-3700 ACE-FEDERAL REPORTERS, INC. WATER PCB-SD0000068687 BSA Depo of: WILLIAM PAPAGEORGE Monsanto v Aetna January 13. 1993 CR: 54034.0 XMAXP1) [16] Q. I'm sorry, am you tell me what you blow about [17] the hxdrogeology of the Texas City Plant area? [IS] A. 1 know nothing about it. [19] Q. You don't blow whether there's a high water table [20] nr a low water table? [21] A. No, I can only speculate. That's not, that's not [22] professional enough. I'm not qualified._____________________ Page 133 [1] Q. You didn't consider, then, that pan of your job [2] its Director of Environmental Operations for MCI to be [3] familiar with the hydrogeology of a particular platU area? [4] A. Oh, no more than 1 want to be a toxicologist [5] regarding the effect of chemicals on rats. [6] MR. MANTA: Off the record for a second. [7] (Papageorge Deposition Exhibit 8 marked for [8] identification.) [9] BY MR. MANTA: [10] Q. Loobng at what has beenmarked for [11] identification as Papageorge Exhibit 7 (sic), it is a [12] Febntary 7, 1983, tnerttorandttm. The subject is "Groundwater [13] Reviews. " [14] MR. SARFAl'll: I think we're talking about Number [15] 8. [16] MR. MANTA: I'm sorry, did I say 7? 1 meant 8. [17] I'm sorry. [18] BY MR. MANTA: [19] Q. Have you seen this document before, Mr. [20] Papageorge? [21] A. 1 don't recall it, sir. [22] _____ Q. I didn't read the Bates tutmber into the record._______ Page 134 [1] It is MCO 6308185. There's a list of people wito the [2] memorandum was presumably setu to. At the bottom of the [3] list, there is W. B. Papageorge. [4] Mr. Papageorge, is it your practice to make a [5] son of a lute through your name after you VC reviewed [6] something? [7] A. No, sir. [8] Q. Would it be your secretary s practice to - [9] A. No, I don't recall any of the secretaries doing [10] that. [11] Q. Do you blow why your name would have a little [12] jiggly line through it? [13] A. I do not. I don't know who did that. [14] Q. Do you recognize the handwriting on the [15] right-hand portion of the page? [16] A. I do not. [17] Q. Okay. I'd lib' you to tab a moment to read [18] through this, and then I'm going to ask you some questions. [19] (Witness peruses said document.) [20] A. I've read it. [21] BY MR. MANTA: [22] _____Q. Do you recall the groundwater reviews that__________ Page 135 [1] were -- that are referenced in this memorandtun? [2] A. Well, as best as 1 recall, there were several [3] reviews. I don't particularly recall the one that appears [4] to be referred to here. [5] Q. Do you recall the questions that were raised . [6] about the selection of certain pollutants with respect to [7] the groundwater monitoring program at Texas City? [8] A. I do not. [9] Q. Do you recall any criticism of the selection of [10] pollutants that were incorporated into tlu: groundwater [11] monitoring program tor Texas City? [12] A. I do not. [13] Q. Do you recall the groundwater - who the [14] groundwater review was presented by for the Texas City [15] Plant? [16] A. I do not. [17] Q. Can you give me some libty suspects? [18] A. No, that would be sheer guesswork on my part. It [19] could be any one of a dozen people. [20] Q. Would it be someone from the Texas City Platit, do [21] you believe? [22] _____ A. It need not be. They could have delegated to______ Page 136 [1] others. [2] Q. Who could they have delegated it to outside the P] plain? [4] A. There again, you are asking me to guess through a [5] long list of names. I would be guessing. [6] Q. Would it libty be people within the [7] Environmental Department at Texas City? [8] A. Not necessarily. [9] Q. Other than people in the Environmental [10] Departmetu, who would libty have made such a presentation? [11] A. You used the word "Ukeiy." Again, that's [12] guessing. The plant manager, any of his superintendents, a [13] consultant they hired, a manber from Monsanto's Engineering [14] Department, one of my guys could have been asked to do this [15] for them. Many people can do it. [16] (Papageorge DepositionExhibit 9 marked for [17] identification.) [18] BY MR. MANTA: [19] Q. Mr. Papageorge,looking at what has been marked P0] for identification as Exhibit 9, it is a document bearing PI] Bates number MCO 0085452 through MCO 0085493. [22]I'd lib you to tab a look at this document and Page 137 M tell me if you've ever seen it before. P] A. I don't recognize this document at all. To the p] best of my recollection, I have never seen it. [4] Q. Diming to the second page, there's a heading, [5] "Major MCI plants. ` Were these the plants that were within [6] your jurisdiction as the Director of Environmental [7] Operations for MCI? [8] A. For MCI; yes. [9] Q. Now, this appears, to nut, at least, to be an [10] otuluie of something, and possibly a presentation of some [11] bid. [12] The page with microfilm number MST 010375 [13] references groundwater, and there '.V a number of sites [14] located. Does this refresh your recollection at all as to [15] the - as to groundwater presentations? [16] A. No, it doesn't. I don't know what that has [17] reference to. [18] Q. Does it reference the fact, can you tell me if it [19] references the fact that there were groundwater issues or P0] concents relative to the Texas City Plant? [21] A. I don't know. [22] (Papageorge Deposition Exhibit 10 marked for Page 138 [1] identification.) [2] BY MR. MANTA: P] Q. htoking at what has been marbd for [4] identification as Exhibit 10, a July 1983 report entitled 15] "Task Force Study, Leaking Sewers," I'd like you to again [6] tab a moment and look for the document and tell me if m you \e ever seen it before. [8] (Witness peruses said document.) [9] A. I do not recall ever seeing this document. [10] Q. Would it iu>rmalty come to your attention, a study [11] such as this, in your position at - as Director of [12] Environmental Operations? [13] A. Well, I have some difficulty, here, because I [14] find references to different pages, here. I don't know if [15] they are part of the original document or whether they are [16] mistakenly included here. I see a 1982 memo and a 1981 - [17] Q. Why don`t we go to [18] A. - and so on. [19] Q. Why don't we go to the 1982 memorandum, and for [20] the record, l want to note, on the table or the index page [21] of this document, there's a reference to, under Roman [22] numeral X, Appendix l, sub A is 'Groundwater Program, Page 139 [l] M. A. Pierle, July 13, 1982. " P] Now. the title of this attaclmient or appendix is P] "Groundwater Program," and I'd lib to ask if you've ever [4] seen this document before, this memorandum. [5] A. I am having difficulty finding that. Is that [6] 1982, July 30? ACE-FEDERAL REPORTERS, INC. 202-347-3700 Page 132 to Page 139 WATER PCB-SD0000068688 BSA Depo of: WILLIAM PAPAGEORGE Monsanto v Aetna January 13, 1993 CR: 54034.0 XMAXQ2) [7] Q. July Milt. I'm sorry. PI A. 137 I haven't found it yet. [9] MR. SARFATTI: Could you give us a page [10] reference, Mark? [11] MR. MANTA: Let me use the microfilm. It's [12] easier. WGK 890455. [13] A. I found it. [14] BY MR. MANTA: [15] Q. Can you tell me if you've ever seen this document [16] before? [17] A. I do not recognize this document at aO. [18] Q. Looking at the first paragraph, the last sentence [19] reads, "Clean up costs and/or adverse public attention have [20] already occurred at the Muscatine, Texas City, Delaware [21] River, Santa Clara and Krummrich plants. " [22] Can you tell me what cleanup costs and/or adverse Page 140 [1] public attention had occurred at Texas City as of July 1982? [2] A. I don't recall the specifics as of that date at [3] all. I just don't know. I don't recall. [4] Q. How about if we take the date out of it, out of [5] the question and say, can you tell me vdiere cleanup costs [6] and/or adverse public opinion occurred with respect to Texas [7] City? [8] A. Texas City? [9] MR. SARFATTI: And you are asking at any time? [10] MR. MANTA: Yes. [11] A. I recall some activity regarding the the, either [12] the North 80 or South 20, or both. I seem to recall that [13] outside contractors or consultants were involved, but I [14] don't remember the details as to what was done, and where it [15] was done, and how it was done. That's as best as I can [16] remember. [17] BY MR. MANTA: [18] Q. Can you give me an approximate time period? [19] A. It's going to be a best estimate, as best as I [20] can come up with, 1 would suggest it happened sometime [21] between 1980 and 1983. [22] Q. That would have been during die time that you Page 141 [1] were Director of Environmental Operations for MCI? [2] A. For MCI, yes, sir. [3] Q. Now, the reference, here, is to plants in this [4] document. Do you recall cleanup costs or adverse public [5] attention directed at the Texas City Plant, itself, [6] regarding groundwater contanunation? [7] A. I'm puzzled by the question. I thought that's [8] what we were talking about. [9] Q. I'm speaking of the plant, itself, aside from [10] North 80 and South 20 -- [11] A. Oh. [12] Q. - which are, 1 guess, not at the plant address [13] atui where the manufacturing takes place. [14] A. In our, Monsanto's designation as a plant, those [15] were perceived to be part of the plant. [16] Q. I'm asking you to put aside your, the traditional [17] designation, and my question is regarding the manufacturing [18] facility, itself, and ifyou'd like me to ask the question [19] agaui, I'd be glad to. [20] A. I think we have a problem in that my definition [21] of a manufacturing facility is everything inside the plant [22] fence. Although a comer of it may be the active area and Page 142 [1] the rest is storage area, or idle, it's still the plant. [2] Q. Do you know if North 80 or South 20 are within [3] the fence, plant fence of the manufacturing area? [4] A. I don't recall a fence, but I'm under an [5] understanding that it's Monsanto property. [6] Q. But you don't know whether it's adjacent to the [7] manufacturing facility, itself? [8] A. Well, there's an area between the sites we're [9] talking about and the active producing area that is [10] unoccupied with any structures, to my recollection, that is [11] still considered part of the plant, in Monsanto terminology. [12] MR. SARFATTI: Could I make a suggestion? [13] MR. MANTA: Sure. [14] MR. SARFATTI: Why don't we use a map. [15] MR. MANTA: Off the record. [16] (Discussion off the record.) [17] BY MR. MANTA: [18] Q. Why don't we go back on and I'll ask the question [19] this way. Aside from North 80 and South 20, are you aware [20] of cleanup costs or adverse public attention with respect to | [21] arty other area at Texas City ? [22] _______MR. SARFAl'll: Again, at any time?____________________ Page 143 [1] MR. MANTA: At any time. [2] A. No. [3] BY MR. MANTA: [4] Q. Okay, let's turn the page, and I'd like to go to [5] the bottom of that page, and the last setuence reads, [6] "Operational practices which result in spills can m contaminate the upper layers of soil and evetuually with [8] rainfiilt, can contaminate the lower groundwater aqtufers. " P] Is it your understanding ? [10] MR. SARFATTI: I don't know how many pages you've [11] turned, but we've all turned one page and don't see what you [12] are talking about. [13] MR. MANTA: I'm sorry, it must be two pages. I'm [14] sorry, to the next - this page has "Groundwater" at the top [15] of the page. [16] MR. SARFATTI: A different document from the [17] Pierle memorandum we were talking about before? [18] MR. MANTA: I think these are all part of the [19] same general document, and I think they are appendices to [20] this sewer report tacked on, task force study on leaking [21] sewers. [221 ______ The microfilm number is WGK 890457.___________________ Page 144 [1] BY MR. MANTA: [2] Q. And my question about tluu sentence is that is it [3] your understanding tlutt the operatioiutl practices that [4] result in spills existed at Texas City? [5] MR. SARFATTI: Objection; lack of foundation. [6] A. I have no personal information to reach that [7] understanding. [8] Q. Turning the page, it says, "Additionally, earthen P] basins used to contain contaminated wastewater and other [10] materials will eventually leak and liquid will move into the [11] grouiuiwater. " [12] Would you agree with tlutt statemeiu? [13] MR. SARFATTI: Same objections, and opinion. [14] A. I'd have to know a lot more than what's given [15] here regarding that conclusion. I would attribute that to [16] the author's understanding of whatever he's writing about, [17] here. [18] BY MR. MANTA: [19] Q. The next sentence reads, "Thus, Monsanto tuts a [20] substantial number of sources existing at vimtally every [21] numttfacturing site which can contaminate the groimd." Would [221 you agree with that statement?__________________________________ Page 145 [1] MR. SARFATTI: Same objections. [2] A. Well, this, again, he's the author. [3] BY MR. MANTA: [4] Q. But you, as Director of Emironmentai Operations [5] for MCI, which would include the Texas City Plant, can't say [6] whether or not you agree or disagree with this statement? [7] A. I would have to know a lot more about the [8] material involved, the kind of ground that's under P] consideration, and many, many other things before I can [10] support that conclusion. [11] Q. I'm asking with a much broader view than each [12] specific plant area. Does tlutt help you? [13] A. Not really, because I don't have enough [14] information, first of all, to support the use of the word [15] "substantial," and I can't support the word "virtually," and [16] then there's the word, "which can contaminate," I don't know [17] how one arrives at that without having much more information [18] than I have at my disposal at this point. I really cannot [19] support that statement without having a lot more information [20] and expertise that I personally lack. Page 139 to Page 145 202-347-3700 ACE-FEDERAL REPORTERS, INC. WATER PCB-SD0000068689 BSA Depo of: WILLIAM PAPAGEORGE Monsanto v Aetna January 13, 1993 CR: 54034.0 XMAX(23) [21] Q. Okay, woidd you agree that that statement [22] aldresses a corporate-level concern? Page 146 [11 A. No, I can't do that. [2] Q. Okay. [3] A. That's the author's concern, whoever the author [4] is of this particular document. [5] Q. The next sentence says, "In addition, past [6] disposal practices" - and it says, paretuheses, "(the use [7] of Jumps and landfills), " close parentheses - "can also be [8] prime sources of groundwater contamination." Do you agree [9] \dth that statement? [10] MR. SARFATTI: Same objections. [11] A. Again, the comments I made to the previous [12] sentence applies to this one, in that itreflects one [13] person's conclusions. I personally need more information [14] ;uid more expertise than 1 possess to be able to agree with [15] that statement. I can't do it with what I now recall and [16] know. [17] BY MR. MANTA: [18] Q. Would you, at die time diat you were Director of [19] Environmental Operations for MCI, have had die information [20] to agree widi die statements contained in sentences I and 2? [21] A. No, sir. As an example, I'm not a [22] hydrogeologist. Page 147 [1] Q. Would you diuik dial it would take a [2] hydrogeologist to, to make these statements? [3] A. Certainly. You are talking here about [4] groundwater contamination, and you have to have an [5] understanding of hydrogeology to be able to come up with [6] this type of conclusion. [7] Q. Why? [8] A. Why? Because as I understand, what little I know [9] about it, that the type ofstrata that exist underneath the [10] operating units, the flow of waters through it, the kinds of [11] waters, where these waters go, what kind of materials are [12] being investigated and how they might And their way into [13] this water and to what degree are they soluble, what [14] concentrations can they reach, what volume of water flows, [15] mid at - how many different kinds of waters are there [16] underneath the surface. [17] Q. The next sentence, diird sentence reads, "Our [18] experience at several Monsanto plants confirms diis." Can [19] you tell me what dial experience was? [20] A. I don't know. [21] Q. Can you tell me any experience you had as [22] Director of Environmental Operations for MCI where you Page 148 [1] acquired any knowledge of die potential for groundwater [2] contamination at any Monsanto location in die country? [3] MR. SARFATTI: Objection; lack of foundation. [4] A. The answer to your question is that I am not [5] aware at this point in time of any groundwater contamination [6] at Monsanto's sites under the management of MCI back in that [7] period of time [8] Q. And by: That period of time" [9] A. - which were '77 through *83, in which materials [10] which could be traced back to Monsanto activities were found [11] in groundwater. I just don't remember any. [12] Q. The last sentence reads, "Among die plants which [13] are currently investigating situations are W. G. Krummrich, [14] Delaware River, Santa Clara, Texas City, Avon, and [15] Springfield. " Each of those plants are plants diat were [16] within your jurisdiction as Director of Emironmental [17] Operations for MCI: is diat correct? [18] A. That is not correct. [19] Q. Okay, which plants were not? [20] A. The Delaware plant was not. The Santa Clara [21] |ilant was not. Springfield was not. _ [22] _____ Q. Okay, The IV. G. Krummrich, Texas City and Avon Page 149 [1] plants were die plants dial were widiin your jurisdiction. [2] that right? [3] A. Correct. Correct. [4] Q. Can you tell me if Mr. Pierle was a [5] hydrogeologist? [6] A. No, Mr. Pierle was a graduate environmaital [7] engineer. [8] Q. What was his degree in? [9] A. Environmental engineering from Purdue University. [10] Q. Do you diink a person with a, an environmental [11] engineering degree could make die statements set forth in [12] die paragraph dial we\e been referring to? [13] MR. SARFATTI: Objection; hypothetical. [14] A. I don't know what courses Mr. Pierle studied. [15] BY MR. MANTA: [16] Q. I'd like to turn to die next page, under [17] subheading A, "Plant Investigations. " [18] "At the present time, virtually every Monsanto [19] location is examining die question of groundwater [20] contamination. " PI] Could you tell me what, what dial program [22] entailed? Page 150 [1] A. Not in detail, of course, but all plants were [2] informed of the interest in keeping groundwaters from being [3] contaminated, and they were encouraged very strongly to look [4] at their own situation and see if such a potential existed [5] at their plant sites. [6] Q. Was this examination a voluntary program that [7] Monsanto embarked on? [8] MR. SARFATTI: Objection; vague. Undefined term. [9] A. If, by "voluntary," you mean there was no [10] regulatory activity requiring it, I would say yes. In the [11] vast majority of the plants, there was not even a hint of [12] such pending regulatory activity. There were a few were, at [13] least the state agencies were interested, so there was this, [14] I'm going to call it pressure felt by the plants that they [15] better know more about their plant than the State people [16] did. [17] BY MR. MANTA: [18] Q. Was Texas City among diose plants that was [19] feeling regulatory pressure? [20] A. I would - yes, at some point in time, that [21] became a, a factor, yes. [22] ____ Q. How do you know diat? Page 151 [1] A. I was informed by the plant personnel that the [2] Texas regulatory people had approached them with some [3] information regarding groundwater. [4] Again, I just do not recall the specifics in [5] terms of exactly where and what material was determined to [6] be present in what quantities, and when all this happened. [7] That's just not clear in my mind. [8] Q. What was your role in diis groundwater program, [9] dtis corporate groundwater program? [10] A. It was no different than all other programs. I [11] monitored activities, I served as a, a rod where necessary, [12] or as an assistance where necessary. I communicated down [13] through the organization and up the organization as [14] appropriate regarding where I felt my comments would be of [15] some help. [16] Q. Were consultants used in connection with this [17] program ? [18] A. In some instances, yes. [19] Q. And were monitoring wells drilled, in some [20] instances? [21] A. I recall monitoring wells being required in some [22] instances, yes. Page 152 [1] Q. Sampling was done? [2] A. Naturally. That's why you have a monitoring [3] well, inm-hmm. [4] Q. And determinations made as to the nature and ;[5] extent of contamination ? 1 [6] [7] A. Yes. Q. And all of those activities, Monsanto, at least &] on your level, had decided to do on its own without ; [9] compunction from regulatory agencies? Is diat right? j [10] MR. SARFATTI: Objection; lack of foundation, i [11] A. All of the individuals in Monsanto that were ACE-FEDERAL REPORTERS. INC. 202-347-3700 Page 145 to Page 152 WATER PCB-SD0000068690 BSA Depo of: WILLIAM PAPAGEORGE Monsanto v Aetna January 13, 1993 CR: 54034.0 XMAX(24) [12] knowledgeable about these kinds of matters had arrived at a [13] consensus that was the responsible way to go, and really, [14] the most effective way in many respects, in efficiency, and [15] costs, and goodwill and what have you, all these factors [16] were considered in arriving at the decision to let's do it [17] before we are forced to. [18] BY MR. MANTA: [19] Q. And what was `it" that you were - [20] A. The study. [21] Q. Corporate-wide groundwater study? Is that right? [22] A. Correct. Page 153 [1] (Papageorge Deposition Exhibit 11 marked for ,[2] identification.) [3] (Witness peruses said document.) [4] BY MR. MANTA: [5] Q. Looking at what has been marked for [6] identification as Exhibit II, which is a January 25, 1984, [7] waste cleanup fact sheet bearing Bates number MCO 6194993 - [8] MCO 6194997, and the memorandum states that - well, first, [9] Mr. Papageorge, is your name referenced on this document? [10] A. I am shown on the cover memorandum as a, as an [11] addressee. [12] Q. Okay, cati you tell me what "B3NA " means? [13] A. That is my office location. [14] Q. Specifically, what does "B3NA " mean? [15] A. Building B, third floor, north wing, mail zone A. [16] Q. The memo says, 'Attached is the final version of [17] the fact sheet on Monsanto's voluntary waste site cleaiuip [18] program." [19] Is this part of the same voluntary groundwater [20] program that you had mentioned earlier? [21] MR. SARFATTI: Objection; vague. Undefined term. [22] _____ A. The groundwater program was designed to provide Page 154 [1] information to Monsanto. I don't recall this particular [2] document, but in briefly looking at it, it appears that [3] it's - we're talking about corrective action relating to a [4] few sites, some of them on plant property, and at least one [5] that I see here is off of plant property. [6] BY MR. MANTA: [7] Q. Again going back to the first page, can you tell [8] me what that squiggly line through your name means? [9] A. To me, that says that this copy goes to [10] Papageorge. And the next name would have been scriggled to [11] go to Mr. Park, and following, Mr. Pickard, and so on. This [12] is the author's way or his secretary's way of designating [13] whose copy it was. That's my understanding. [14] Q. Can you tell me wlut your secretary was at this [15] time? [16] A. 1984, Jane Audrain, A-u-d-r-a-i-n. [17] Q. Was she always your secretary? [18] A. No. ' [19] Q. Who was your first secretary? [20] MR. SARFATTI: .Are we going back to 1951? [21] BY MR. MANTA: [22] Q. I'm sorry, as Director of Environmental Page 155 [1] Operations starting in 1977. [2] A. Oh. [3] MR. SARFATTI: That sounds like a trivia [4] question. [5] A. Jane Audrain. [6] MR. MANTA: This Is Your Life." [7] BY MR. MANTA: [8] Q. - Jane Audrain continued up through [9] A. From '76 through '85. [10] Q. Do you know if Ms. Audrain is still around? [11] A. She's still around. 1 don't know what you mean. [12] Ls she still working? 1 don't know if she's still working [13] for Monsanto or has retired. I don't [14] Q. She's still living, to your knowledge? [15] A. Yes. [16] Q. Turning to the second page, the last paragraph, [17] there, it's actually the third page of the document, second [18] page of the notice, it says, "Similarly, the Texas City I [19] Plant spent about $100,000 to remove waste from a small, | [20] abandoned pit called the 'Anders Lane' site." Can you tell i PI] me what the Anders Lane site is? P2]________A. I don't remanber._______ ___________________________ Page 156 [1] Q. Do you know if there was a groundwater P] contamination at the Anders Lane site? [3] A. I just don't know anything about that. I don't [4] remember anything about it. [5] Q. You had said that the, Monsanto's environmental [6] guidelines - well, let me strike tluu and ask this. Was m the idea behind Monsanto's groundwater assessmetu program, [8] the corporate program, was to, as the name suggests, assess P] the condition cf the groundwater at \arious locations; is [10] that right? [11] A. At various Monsanto locations, yes. [12] Q. And to determine if there was contamination of [13] the groundwater at those Monsanto locations; is tluxt right? [14] A. That's one of the objectives, yes. [15] Q. Do you know what they made at the Texas City [16] Plata? [17] A. Not in total. I do know a few of - I remanber a [18] few of the products. [19] Q. Can you tell me wlujt they were? P0] A. Styrase, for one. I can't remanber others. [21] There are more there, yes. P2]________Q. Would you agree with me tluu the Texas City Plant Page 157 [1] is an organic chemical platU? [2] A. Well, I need a little help on the definition [3] "organic," so you and I both have the same definition. [4] Q. Well, I understand organic as containing carbon. [5] Is tluu your undersuttuling? [6] A. All right. AU right, I can agree to that. I [7] feel more comfortable personally calling it a petrochemical [8] plant. [9] Q. Okay, petrochemical platu; cotuauied, for the [10] most part, organic chemicals? [11] A. That is correct. Yes. [12] Q. If you were to assess or want to assess the [13] coiuiition of the groundwater at a petrochemical plant, wiuu [14] types of chemicals would you testfor? [15] MR. SARFATTI: Objection; lack of foundation. [16] A. Oh, God, I'd have the know aU of the processes, [17] afl the materials involved, the starting materials, the [18] intermediate materials produced, the end products, the [19] residues created, the catalyst used, the cleanup compounds [20] used, and so on. I'd need to know an awful lot more than PI] just petrochemicals. P2]_______ Q. Would you agree tluu you would test for organic______ Page 158 [1] chemicals? [2] MR. SARFATTI: Same objection. [3] A. If the information I had at my disposal led me to [4] suspect that organic chemicals could be in groundwater, I [5] would look for them. I don't know how else to explain that. [6] I might be looking for other materials, too, water-sohible [7] chemicals, and so on. [8] Q. Wluu other types of chemicals at a petrochemical [9] platu would you look for? [10] MR. SARFATTI: Same objection. [11] A. I don't pose to know them all, but there are [12] materials used to assist processes. Some of these materials [13] are not hydrocarbons. I'm trying to think of good examples. [14] I'm going to give as an example, suppose there was a need at [15] a plant for some phosphorus-containing material, or some [16] metal-containing material to assist in the process or take [17] part in it. Depending on how it was used, how carefully it [18] can be controlled from escape and all, I would - I can see [19] a somewhere where I might say I better look for this [20] material because of the conditions under which it was used, [21] it may or may not have gotten away from us, let's go look to P2] see if it is in that groundwater.______________________________ Page 159 [1] Q- dre you saying you would look for tlwse in P] addition to organic chemicals? Page 152 to Page 159 202-347-3700 ACE-FEDERAL REPORTERS, INC. WATER PCB-SD0000068691 BSA Depo of: WILLIAM PAPAGEORGE Monsanto v Aetna January 13, 1993 CR: 54034,0 XMAXC25) [3] A. Certainly. If I, again, if I didn't suspect [41 organic chemicals were there because they are highly [5] volatile, they evaporate easily, I wouldn't expect them to [6] end up going down into the ground, I would expect them to SO [7] up into the air, I wouldn't look for those, that kind of m hydrocarbon, so I'd have to know an awful lot about the PI characteristics of the materials to be able to come up with [10] a presumption on my part that they may be in that water, [11] therefore, I better go look for them. [12] Q. And yon don ! hiow itiose facts with regard to the [13] Texas City Plant. Is that right? [14] A. I personally don't know, no. [15] Q. And you didn't hiow them at the time that you [16] were Director of Etwironmental Operations? [17] A. That is correct. [18] MR. MANTA: Okay, it's 5:00. You want to stop? [19] MR. SARFATll: If the witness is up to it, I'd [20] say let's go to 5:30, just to ensure that we all get back [21] sometime on Friday. [22] ______ MR. MANTA: That's fine with me. The case__________ Page 160 [1] management order says 5:00. and it's up to you guys, and [2] I'll go with it. [3] MR. SARFATll: Unless I'm misjudging the progress [4] you've made. [5] MR. MANTA: Well, there are a number of other [6] locations. [7] MR. SARFATll: And other documents. m MR. HUGHES: Let's go to 5:30. [9] (Papageorge Deposition Exhibit 12 marked for [10] identification.) [11] (Witness peruses said document.) [12] BY MR. MANTA: [13] Q. Mr. Papageorge, looking at what has been marked [14] as Exhibit 12, it is a document dated October 25, 1984, [15] entitled "Grottndwater Assessment Summary" and bears Bates [16] number SIX} 1658243 - STG 1658260. [17] A. 1 don't recall this document at all. This is the [18] first time I've seen it. [19] Q. Well, you beat my question. [20] MR. HUGHES: He's trying to speed this up. [21] THE WITNESS: Oh, I'm sorry, I - [221 BY MR. MANTA:_____________________________________ Page 161 [1] Q. Can you tell me if this is a reflection of the [2] corporate grottndwater assessment program that you had [3] mentioned earlier? [4] MR. SARFATTI: Objection; lack of foundation. [5] A. Gee, 1, I don't know that I'd define it as [6] corporate. I would suggest that it looks to me like [7] someone's summary of that groundwater assessment program, [8] and they seem to be dated for different months, so it was PI not all done at one time. I don't know who the author is. [10] That's all I can really say except read what's already [11] there, and others can read as well as I can. [12] BY MR. MANTA: [13] Q. Can you tell me why it would be stamped "Company [14] Confidential" and "Do not duplicate or copy"? [15] A. I have no idea. [16] Q. War groundwater contanunation information [17] considered something that iwas, 1 don`t know, very [18] problematic for Monsanto in or abotU 1984? [19] MR. SARFATTI: Objection; vague. [20] A. 1 can't speak for everyone in Monsanto. I can [21] only speak for myself, and it was not problematic in the [22] sense that I think you are implying here,_____________________ Page 162 [1] Q. Why don't we turn to page 12. [2] A. Page 12. I have it. [3] Q. The last sentence of the paragraph wider "Site [4] History " reads, "Many process spills, tank leaks, [5] underground line and sewer leaks, impoundment, and [6] wastewater ditch seepage concerns on plant site." [7] Were you aware of those concerns in 1984? [8] A. I was aware of the type of leakage that one would I [9] normally associate with an active plant. I do not know who j [10] the author of this document is, so I don't know what he's [11] referring to in terms of the magnitude of the leaks and [12] spills he describes here. [13] Q. What leakage would you normally associate with an [14] operating plant? [15] A. Oh, there are many [16] MR. SARFATTI: Objection; hypothetical. [17] A. (Continuing) Well, there are leaks that are [18] generated because of failure, say, in a weld of a pipeline. [19] Now, that leak can be just a drip every half hour, but it's [20] still considered a leak. [21] There are leaks that are associated with [22] operating pumps where the seal is worn, as a shaft goes Page 163 [1] through the seal, some material could come out of that. [2] It's an awful lot, in many cases, like the drip of oil from [3] your automobile on your garage floor. There are many of [4] those that take place, so when they talk about leaks, it [5] isn't a deluge or a 10,000-gallon tank rupturing and [6] spilling all over the place. Those are wear, the big leaks [7] that would have to be a catastrophic failure or a fire or [8] some such incident. [9] Every attempt was made in Monsanto to shoot, to [10] target for zero material leaving the system, and as far as [11] the technology would permit it, that's what was the [12] objective. [13] Q. That was the objective when you were director? [14] A. It was the objective from day one with Monsanto [15] and during the time I was director, yes. [16] MR. MANTA: Could I have my question read back to [17] me, please? [18] THE COURT REPORTER: [19] "Q. What leakage would you normally associate [20] with an operating plant?" [21] BY MR. MANTA: [22] _______Q. Would you inclttde sewer leakage as leakage that Page 164 [1] would normally be associated with an operating plant? [2] MR. SARFATTI: Same objection; hypothetical, lack [3] of foundation. [4] MR. MANTA: I'm going to state again on the [5] record that I think you are going beyond the Special [6] Discovery Master's order with respect to coaching the [7] witness. I think we've had repeated objections on lack of [8] foundation, hypothetical, and a number of other grounds that [9] I think are only made as coaching attempts, and I think that [10] they, they are a violation of the order. [11] MR. SARFATTI: We've given our position on your [12] view before. I'm not going to repeat it now. [13] BY MR. MANTA: [14] Q- Now, my questionwas aboutsewer teaks. [15] A. Sewers? [16] MR. SARFATTI: Same objections. [17] A. Again, they are like pipelines only they're [18] underground, generally, so the technology is not perfected [19] to the point where on occasion, a sewer will fail, and [20] material that's intended to stay within the sewer system [21] does leak out of the system. The objective to reduce that [22] to zero still applies.________________________________________ Page 165 [1] BY MR. MANTA: [2] Q. But they were blown to occur, and they would have [3] been known to occur throughout the operafing history of the [4] plant; is that riglu? [5] MR. SARFATTI: Same objections. [6] A. They were known to occur. It's now a matter of [7] frequency and amount of material that leaves the system. [8] BY MR. MANTA: [9] Q. And the pump leaks that you had referenced [10] before, and lank leaks, and other underground lines would I [11] also be leaks or releases that would occur during the usual [12] course of Monsanto's business. Is that right? [13] MR. SARFATTI: Same objections. [14] A. WeD, that, to me, is the real world. It is not [15] a dairy, it isn't a sterile kitchen, it's a manufacturing ACE-FEDERAL REPORTERS. INC. 202-347-3700 Page 159 to Page 165 WATER PCB-SD0000068692 BSA Depo of: VVILUAM PAPAGEORGE Monsanto y Aetna January L3, 1993 CR: 54034.0 XMAX(26) [16] site, and every attempt is made to reduce all that, and the [17] day has not arrived yet where it can be zero. [18] BY MR. MANTA: [19] Q. Aid those type of releases would have occurred [20] throughoiu the operation of the plant; is that right? I [21] mean from the beginning of operation until a plant shut [22] down._______________________________________________________ Page 166 [1] MR. SARFATTI: Same objections. [2] A. Yes, sir. [3] BY MR. MANTA: [4] Q. And that the conditions that the environment at [5] the platit was exposed to as a result of the leaks, and the [6] spills, and the potential leaks in the sewer lines, would [7] continue from the time the plant started operating through [8] the time that it stopped; is that correct ? [9] MR. SARFATTI: Same objections. [10] A. You make it sound like it's a continual drippage, [11] and leakage and oozing. AH spills don't end up in the [12] environment. Many are contained. Many are mopped up, swept [13] up. [14] BY MR. MANTA: [15] Q. I'm not saying whether or not they enter any [16] other envirotunent other than the plant environment. [17] A. If you get an oily spot on the plant floor and [18] it's quickly picked up with sawdust or whatever, sand, and [19] that sand is properly disposed of, you don't really have an [20] environmental problem. You've got a dark spot on the [21] concrete floor. [22] _____ Q. Wlutt I'm asking, really, is the type of things_________ Page 167 [1] that are referetwed in litis sentence. Spills, tank leaks, [2] underground line and sewer leaks were the type of things [3] that happetted in the real world at a plant, througlwut its [4] operation, operating history; is that riglu? [5] MR. SARFATTI: Same objections. [6] A. Yes, and I was trying to distinguish between the [7] tnqjor failure and the occasional stain. [8] BY MR. MANTA: [9] Q. In fact, some level of sewer leakage was accepted [10] in the Fifties, Sixties and Seventies; isn V that true? [11] MR. SARFATTI: Objection; lack of foundation, [12] hypothetical. [13] A. I don't know (hat the word "accepted" is [14] appropriate. Where it was known that such a condition [15] occurred, the effect on the environment would, of course, be [16] noted. If you had a fish kill or something, you certainly [17] would be concerned, but if no effect was noted, based on the [18] technology of the day, whether in the Thirties, Forties, [19] Fifties, that really influenced the corrective action that's [20] taken. If no effect is noted, you repair the situation and [21] continue. If an effect is noted, you take whatever is [22] appropriate to prevent it happening again.___________________ Page 168 [1] BY MR. MANTA: [2] Q. My question has to do, to go to the real world [3] operation of a petrochemical plant such as Texas City. [4] A. That's what I'm talking about. [5] Q. Aid in that real world operation, it was known [6] that the sewers were not impervious all the time; is that [7] right? [8] MR. SARFATTI: Objection; lack of foundation. [9] A. The implication in your question is that it was [10] known that these sewers leaked like sieves. That is not the [11] understanding. There are occasional failures that, when [12] discovered, are corrected, and the corrective action is [13] based on the results of that failure that are unacceptable, [14] like the fish kill I mentioned as an example. [15] BY MR. MANTA: [16] Q. Could you tell me how a fish kill could result [17] from a sewer failure? [18] MR. SARFATTI: Same objection. [19] A. Well, I'D have to draw a hypothetical situation [20] where the sewer fails, the contaminated water, instead of [21] going to the proper treating plant, finds its way into a [22] body of water which contains fish. The next thing you know, Page 169 [1] there are fish floating on the surface. This has happened; [2] not for Monsanto, but in other places. If that [3] BY MR. MANTA: [4] Q. Are you referring to your experience at Anniston? [5] A. My experience in Anniston? [6] Q- Tour experience with fish kilts at Atuiiston. [7] A. I have never witnessed a fish kill at Anniston. [8] MR. SARFATTI: I think the witness was in the [9] middle of a response when you started asking him about [10] another [11] A. (Continuing) To continue with my example of that [12] fish kill, if the situation is perceived by the responsible [13] managers to be one that is difficult to prevent, then the [14] need is placed on their shoulders to come up with a way that [15] will reduce the effect of such a spin by putting in a catch [16] basin or some trap to keep that undesirable material from [17] getting out there where the fish are. [18] So what I'm trying to point out is that the [19] corrective action is, calls for a judgment decision on the [20] manager's part as to how to repair that leak and prevent [21] future problems, if called for. [22] BY MR. MANTA: Page 170 [1] Q. My question is, aside from sewer failures, wasn't [2] it known that sewers leaked and tluit some leakage was known [3] to occur, btu that it was not practical nor feasible to [4] repair every leak in every sewer that took place? [5] MR. SARFATTI: Same objections, and compound [6] question. [7] A. Oh, I - gee, I don't know that that is a fact. [8] That is speculation as to the frequency and irreparabiKty, [9] and the costliness, and aQ those things you mentioned. [10] MR. MANTA: Could I have my question read back? [11] THE COURT REPORTER: [12] "Q. My question is, aside from sewer failures, [13] wasn't it known that sewers leaked and that some leakage was [14] known to occur, but that it was not practical nor feasible [15] to repair every leak in evety sewer that took place?" [16] A. I don't know that it's impractical or unfeasible [17] to repair every sewer, every leak. I don't know that. [18] BY MR. MANTA: [19] Q. Okay, you can't say whether that's true or not; [20] is tiuu right? [21] A. That's true. [22] (Papageorge Deposition Exhibit 13 marked for Page 171 [1] identification.) [2] BY MR. MANTA: P] Q. Now looking at wlutt luts been nutrked for [4] identification as Papageorge Exhibit 13, it is a March 19, [5] 1979, document with Bates number WGK 1450815 - WGK 1450816. [6] Have you ever seen this document before, Mr. Papageorge? [7] A. I, I don't recall it. [8] Q. Is tlust your lutme in the upper right-hand colunm? [9] A. It is. [10] Q. Can you tell me where G4WA is? [11] A. It's my office in St. Louis. G Building, fourth [12] floor, west wing, mail zone A. [13] Q. Can you tell me why - why don't I direct your [14] atteiuion to the fourth dot beneath the first paragraph aid [15] ask you to read tiuu to yourself, please. [16] (Witness peruses saiddocument.) [17] A. I have read it. [18] Q. Can you tell me why some itutctive facilities, [19] Monsatuo believed some inactive facilities should be closed [20] prior to RCRA promulgation? [21] MR. SARFATTI:Objection; lack of foundation. [22] _____ A. I'd have to read the RCRA regulations to help me Page 172 [1] there. I don't remember what portion of the regulations [2] referred to procedures required to close facilities. [3] Q. Well, this says prior to RCRA promdgation. [4] A. It does. [5] Q. Riglu. Now, can you tell me why you would want Page 165 to Page 172 202-347-3700 ACE-FEDERAL REPORTERS, INC. WATER PCB-SD0000068693 BSA__________________________ Depo of: WILLIAM PAPAGEORGE Monsanto t Aetna January 13, 1993 CR: 54034.0 XMAX(27) [6] to close something prior to - or close inactive facilities [7] prior to RCRA being enacted? [8] MR. SARFATTI: Same objection. [9] A. I'd bare to see the regulation to determine what [10] paper work would be involved, if RCRA were involved, what [11] specifications must be met - [12] BY MR. MANTA: [13] Q. Would you agree - I'm sorry. [14] A. No, all these requirements are listed under RCRA [15] that if the facility is closed after promulgation, it must [16] be met. If it's closed before that, then it's [17] grandfathered. [18] Q- Would you agree Milt me, then, that the purpose [19] of closing inactive facilities would be to avoid lutving to [20] comply with the RCRA requirements? [21] MR. SARFAI'l 1: Same objection. [22] A. That is certainly a consideration, but the, the Page 173 [1] true intent is to close it responsibly without the excessive [2] costs that were perceived to be associated with RCRA [3] requirements. [4] BY MR. MANTA: [5] Q. Then it was to avoid having to engage in the [6] requirements of RCRA because of the excessive costs [7] associated with RCRA: is that right? [8] A. The costs that were perceived to be unnecessary; [9] really, politically motivated, rather than scientifically [10] driven. [11] Q. Turning the page, the second-to-last paragraph, [12] just one sentence says, 'For some locations, this program [13] will require a major effort, btu it is one which must be [14] expended ui order to protect the continuotts uninterrupted [15] matutfacturing ability of this site. " [16] Can you tell me how the contimtous unituerrupted [17] manufacturing ability of the site would be affected? [18] MR. SARFAITI: Same objections. [19] A. I'm rather surprised at the question, because if [20] you'll note the listing there, you'll see references to the [21] proper disposal under RCRA and the need for the plant to do [22] that, and you can't continue operating unless you can Page 174 [1] properly dispose of the material. They have reference to [2] permitted facilities, there's reference to identification of [3] wastes, upgrading of facilities, and so on. [4] BY MR. MANTA: [5] Q. So Monsaiuo's efforts at closing some facilities [6] prior to the promulgation of RCRA was an effort to protect [7] the continuous unintemipted manufacturing ability of the [8] sire; is that right? [9] A. No, no, that's a misunderstanding. That is only [10] oue dot of manv on this page. [11] Q. I understand that. [12] A. And that has nothing to do with continued [13] operations. You note it refers to inactive facilities. [14] Closing those facilities before RCRA promulgation has [15] nothing to do with the sentence you referred to about [16] uninterrupted manufacturing capability. The two are not [17] related. It's the other items that must be properly met to [18] satisfy RCRA early enough so that manufacturing can [19] continue. [20] Q. Let me - let's look at this. The sentence [21] beneath the Jots reads. "Based on die above and EPA schedule [22] for promulgation of regulations requiring 0 -- and then Page 175 [1] there's subsentences A. B and C - "Each plant must now [2] immediately evaluate its situation and develop action plans [3] to meet the following qoals." ' [4] Under dot 1, first dot. there, "Close all [5] inactive facilities pnor to 12/79. ' [6] Doesn't that indicate to you that closure of [7] these inactive facilities are sontething that could affect or [8] if they weren't closed prior to the enactment of RCRA. that [9] could affect the continuous, unituerrupted operation of the [10] plain? [11] MR. SARFATTI: Same objections. Objection as to [12] form. [13] A. The dosng of these inactive sites is, of [14] course, mentioned here, but there are other statements, [15] here, that more directly affect the ability to continue [16] manufacturing. For example, I see a statement, there, on [17] Page 2, the second and third buttons from the top or dots [18] from the top, "Qualify by performance testing disposal [19] facilities that do not meet design requirements." In other [20] words, upgrade them where necessary. [21] "Assure its location of a hazardous waste [22] disposal plant after promulgation of the RCRA regulations," Page 176 [1] There's a button at the bottom of Page 1 where it says, [2] "Declassify the nonhazardous category," and so on. [3] Q. Would you consider the program that is referenced [4] here that will require a major effort to be something that [5] Monsaiuo would engage in in the normal operations of its [6] business? [7] MR. SARFATTI: Same objections. Hypothetical. [8] A. Certainly, if the conditions require a major [9] effort, it's, it's done, but you'll note that that reference . [10] to requiring major effort is limited by the phrase, "for [11] some locations." It's not every location. [12] BY MR. MANTA: [13] Q. Would it be something that you would seek [14] insurance coverage for? [15] MR. SARFATTI: Objection to lack of foundation. [16] A. I know nothing about insurance coverage. [17] BY MR. MANTA: [18] Q. But I mean as Director of Etwironmetual [19] Operations. [20] A. What's that got to do with insurance? [21] Q. Well, would you consider seeking insurance [22] coverage?_________________________________________________ Page 177 [1] MR. SARFATTI: Same objection. [2] A. That's not my bailiwick. I - that's someone [3] else's responsibility. [4] BY MR. MANTA: [5] Q. Did you, at the time of this memorandum in 1979, [6] consider whether you could get insuratwe coverage to cover m the efforts associated with this? [8] A. Again, that's, that's not my responsibility at [9] all. [10] Q. You can't tell me whether or not you considered [11] insurance coverage? [12] A. It didn't even enter my mind. [13] MR. MANTA: That's all I have for today. It's [14] 5:30. [15] THE WITNESS: Thank you. [16] (Discussion off the record.) [17] (Whereupon, at 5:35 p.m., the deposition was [18] recessed to the following day.) [19] [20] [21] [22]_________________________________________ ACE-FEDERAL REPORTERS, INC. 202-347-3700 Page 172 to Page 177 WATER PCB-SD0000068694 BSA Look-See Concordance Report 2,417 UNIQUE WORDS 386 NOISE WORDS 28.823 TOTAL WORDS SINGLE FILE CONCORDANCE CASE SENSITIVE WORD RANGES @ BOTTOM OF PAGE -$- $100,000 [1] 155:19 -0- 0057502 [1] 40:2 0085452 [1] 136:21 0085493 [1] 136:21 010375 [1] 137:12 0267022 [1] 92:19 0267039 [1] 92:19 091626 [1] 86:7 -1- I [10] 5:8; 39:17; 40:1; 77:8, 10; 86:13; 87:10; 146:20; 175:4; 176:1 10 [3] 5:17; 137:22; 138:4 10,000-gallon [1] 163:5 1025 [1] 2:8 108 [1] 5:13 10:00 [2] 1:19; 22:20 II [3] 5:18; 153:1, 6 1124464.32 [1] 108:17 11th [1] 7:15 12 [5] 5:19; 160:9, 14; 162:1, 2 12/79 [1] 175:5 I202162-WGK [1] 74:12 1202164 [1] 74:12 126 [1] 5:14 12:10 [1] 61:17 13 [5] 5:20; 139:1, 8; 170:22; 171:4 1303023 [l] 83:11 1303049 [1] 83:11 133 [1] 5:15 136 [1] 5:16 138 [1] 5:17 13th [2] 1:20; 139:7 1450815 [1] 171:5 1450816 [1] 171:5 153 [1] 5:18 16 [1] 40:1 160 [1] 5:19 1624 [1] 95:6 1658243 [1] 160:16 1658260 [1] 160:16 171 [1] 5:20 1776 [1] 3:13 19 [2] 30:10; 171:4 19103 [1] 2:16 1943 [1] 23:4 1947 [1] 23:5 1951 [3] 25:1, 5; 154:20 1956 [1] 26:14 1958 [1] 27:1 1961 [2] 27:7 1963 [1] 30:13 1964 [2] 28:2; 30:14 1965 [1] 31:2 1969 [l] 31:4 1970 [6] 21:2, 13; 31:5, 16, 19; 32:16 Depo of: WILLIAM PAPAGEORGE Monsanto v Aetna January 13, 1993 CR: 54034.0 : 1972 [2] 33:4, 14 | 1973 [8] 33:7, 19, 22; 34:13, 20; 35:1; 36:6, 11 1974 [3] 33:9; 36:18; 37:2 1975 [1] 37:7 1976 [1] 37:7 1977 [21] 37:22; 39:3; 40:1, 5; 41:2, 3; 45:1, 2, 3; 48:7, 17; 50:12; 57:5; 58:17; 74:10; 87:16; 105:10, 11; 106:16; 155:1 j 1978 [10] 51:3; 52:1; 92:17; 99:20; 105:12; 106:3; 114:6; 115:19; 116:15; 123:20 1979 [8] 101:19, 22; 108:9, 15; 110:3; 127:4; 171:5; 177:5 1980 [6] 77:8, 10; 86:13; 87:10; 127:12; 140:21 1981 [1] 138:16 1982 [5] 138:16, 19; 139:1, 6; 140:1 1983 [10] 53:2, 10, 14, 17, 18; 54:5; 87:16; 133:12; 138:4; 140:21 1984 [5] 153:6; 154:16; 160:14; 161:18; 162:7 1985 [3] 54:7, 8, 20 1993 [1] 1:20 1:25 [1] 61:17 ---------------rr=----------------- 2 [17] 5:9; 74:3, 4, 9; 94:18; 95:2, 9, 19; 96:7; 98:12; 122:8, 10, 11; 124:7; 146:20; 175:17 20 [9] 107:6, 22; 115:2; 125:18; 126:6; 140:12; 141:10; 142:2, 19 20005 [1] 4:6 20006 [2] 2:9; 3:14 202 [5] 2:10; 3:15, 16; 4:7, 8 215 [2] 2:17, 18 25 [4] 64:6; 153:6; 160:14 25-page [l] 83:16 26 [1] 99:20 2707267 [1] 127:5 2707283 [1] 127:6 27th [l] 127:4 28 [1] 92:17 2822759 [1] 99:21 2822770 [1] 99:21 -3- 3 [8] 5:10; 76:13; 83:6, 7, 10; 84:12; 108:15; 110:3 30 [2] 74:9; 139:6 300 [1] 2:7 321 [1] 20:20 36 [1] 108:17 37th [1] 2:15 383-8900 [l] 4:7 39 [1] 5:8 3:00 [1] 122:1 3:23 [1] 122:5 3:40 [1] 122:5 -4- 4 [4] 5:11; 84:17; 92:12, 16 I 400 [1] 3:5 ! 415 [2] 3:7, 8 429-7049 [1] 3:16 i 466-5738 [1] 4:8 4th [15] 9:1, 14; 10:9, I 22; 11:3, 20; 13:4, 8, 11, I 15; 18:7, 9, 16; 22:12, 17 , -5- 5 [6] 5:3, 12; 93:13, 17; 99:17, 20 5:00 [2] 159:18; 160:1 5:30 [4] 22:21; 159:20; 160:8; 177:14 5:35 [1] 177:17 -6- 6 [4] 5:13; 108:11, 15; 122:8 6-9-78 [1] 83:11 6194993 [1] 153:7 6194997 [1] 153:8 62 [1] 30:13 6308185 [1] 134:1 63141 [1] 20:20 -7- 7 [6] 5:14; 126:20; 127:3; 133:11, 12, 16 74 [1] 5:9 76 [1] 155:9 77 [4] 44:5; 48:8; 50:18; 148:9 772-5759 [1] 3:8 773-5529 [1] 3:7 78 [3] 105:13; 106:16; 115:1 =n---------------- 8 [5] 5:15; 98:11; 133:7, 15, 16 80 [12] 61:6; 107:4, 5, 14, 19, 22; 125:18; 126:5; 140:12; 141:10; 142:2, 19 800 [1] 96:2 828-3163 [1] 3:15 83 [5] 5:10; 53:6; 57:7; 61:6; 148:9 85 [1] 155:9 851-6600 [1] 2:17 851-6644 [1] 2:18 88 [1] 1:8 890455 [1] 139:12 890457 [1] 143:22 8th [2] 18:14; 19:1 ITT"----------- 9 [5] 5:16; 98:11, 20; 136:16, 20 92 [1] 5:11 94111 [1] 3:6 965-7910 [1] 2:10 99 [1] 5:12 TTI A-d-d-y-s-t-o-n [1] 52:19 a-n-h-y-d-ri-d-e [1] 25:15 A-u-d-r-a-i-n [1] 154:16 a.m. [1] 1:19 abandoned [1] 155:20 ability [4] 173:15, 17; 174:7; 175:15 able [5] 79:1; 116:7; 146:14; 147:5; 159:9 abreast [1] 49:14 absence [1] 119:9 absolute [1] 27:2 absolutely [2] 109:22; 122:19 abuse [3] 70:6, 11, 17 abusing [1] 118:10 accept [2] 65:4; 120:1 Acceptability [5] 33:10; 36:15, 19; 37:9; 50:22 acceptability [1] 35:13 acceptable [3] 63:18, 21 acceptance [1] 104:13 accepted [3] 104:22; 167:9, 13 Accepting [1] 65:6 accommodate [4] 38:7; 63:7; 65:2; 69:2 accommodated [3] 68:18; 70:22; 71:11 accommodateed [1] 67:9 accommodates [1] 65:13 accommodating [2] 67:2, 14 accommodation [3] 69:14, 15; 71:18 accord [1] 69:14 account [1] 111:16 accurate [2] 60:10; 128:5 achieving [1] 102:4 acid [1] 34:9 acquired [1] 148:1 acronym [1] 39:11 Acrylonitrile [1] 34:18 acrylonitrile [3] 36:21; 37:15, 18 Act [2] 45:10; 93:20 act [1] 79:4 action [9] 81:5; 82:12, 14; 98:22; 154:3; 167:19; 168:12; 169:19; 175:2 Actions [1] 122:13 actions [3] 84:20; 85:10, 20 active [4] 115:4; 141:22; 142:9; 162:9 activities [7] 80:22 ; 85:9; 97:18, 20; 148:10; 151:11; 152:7 activity [9] 27:21; 41:12; 81:14; 97:8; 108:10; 123:5; 140:11; 150:10, 12 actual [3] 79:5; 101:11; 117:3 ad [2] 42:9, 10 Adams [1] 1:18 added [5] 33:12; 37:13, 15; 50:21; 51:3 addition [6] 16:17; 31:13; 64:9; 88:1; 146:5; 159:2 additional [10] 27:16; 62:14, 16, 18; 63:6; 70:13; 124:10, 19; 125:1, 11 Additionally [1] 144:8 additives [1] 26:7 address [8] 20:19, 21; 21:1, 3; 31:8; 43:1; 131:17; 141:12 addressed [13] 64:4; 77:17; 82:15; 107:13, 18; 109:17, 19; 110:12, 14; 111:1, 14, 20; 112:10 addressee [2] 109:7; 153:11 addresses [1] 145:22 addressing [3] 33:6; 55:5, 6 Addyston [1] 52:18 adequate [1] 66:12 adequately [1] 67:4 Adios [1] 118:7 adjacent [1] 142:6 adopted [2] 36:15; 127:17 adverse [5] 139:19, 22; 140:6; 141:4; 142:20 advise [2] 19:12; 20:6 advised [1] 103:14 advising [1] 62:20 AETNA [1] 1:10 Look-See(29) affairs [2] 80:4; 82:21 affect [3] 175:7, 9, 15 affected [7] 54:19; 129:9; 130:3; 132:6, 10; 173:17 aforesaid [1] 6:5 AFTERNOON [1] 61:18 afternoon [2] 13:15; 62:13 agencies [3] 129:6; 150:13; 152:9 agency [3] 12:10; 105:15; 106:15 agent [3] 8:2; 17:2, 4 agree [21] 29:19; 66:19; 69:17; 75:3; 94:21; 96:17; 115:8; 120:14; 128:2; 144:12, 22; 145:6, 21; 146:8, 14, 20; 156:22; 157:6, 22; 172:13, 18 agreed [1] 67:7 agreeing [1] 69:14 agreement [2] 68:9; 119:6 Agricultural [1] 98:16 air [5] 45:19; 47:1; 48:12; 49:8; 159:7 airline [2] 8:3; 12:11 al [1] 1:11 Alabama [1] 31:3 allow [2] 63:8, 19 alone [2] 61:15; 124:18 alternate [1] 43:16 amount [2] 75:7; 165:7 amounts [1] 41:22 Anders [3] 155:20, 21; 156:2 anhydride [3] 25:14; 34:7, 8 animal [1] 115:2 ANN [1] 108:17 Ann [1] 56:9 Anniston [6] 29:9; 31:3; 169:4, 5, 6, 7 announcement [1] 50:14 answer [11] 14:7, 22; 15:3; 22:9; 73:6; 75:15; 90:5, 6; 115:15; 123:1; 148:4 answered [5] 12:1; 109:13, 20; 110:6, 8 anybody [3] 9:6; 36:8; 59:11 anymore [1] 110:9 anyway [1] 114:21 anywhere [1] 27:11 apart [1] 87:19 apparently [1] 63:1 appeal [1] 118:11 appear [3] 16:8, 9; 70:13 APPEARANCES [1] 2:1 appears [6] 84:4, 5; 109:18; 135:3; 137:9; 154:2 appendices [1] 143:19 Appendix [1] 138:22 appendix [1] 139:2 applied [1] 82:18 applies [3] 123:5; 146:12; 164:22 apply [1] 54:2 appointed [1] 27:3 appointments [1] 42:6 appraises [1] 41:19 appreciate [2] 29:22; 38:10 approach [2] 123:7; 124:3 approached [1] 151:2 appropriate [13] 18:14; 35:5; 49:16, 18; 59:14; From $100,000 to appropriate WATER PCB-SD0000068695 BSA ________ _______ Depo of: WILLIAM PAPAGEORGE Monsanto v Aetna January 13, 1993 CR: 54034.0 Look-See(30) X2:l: 95:10; 121:10; 129:21, 22; 151:14; 167:14. 22 appropriated [11 82:19 appropriately (1) 82:15 approximate [21 58:7; 140:18 Approximately [11 41:3 approximately [7] 9:14; 43:7; 46:7; 61:1; 64:6; X3:16; 89:16 aquifers [11 143:8 arbitrary [11 71:12 area [141 47:10; 49:2; 39:4; 60:2; 72:2; 132:17; 133:3; 141:22; 142:1, 3, 8. 9, 21; 145:12 areas [10] 29:7, 16, 21; 30:6; 77:17, 18, 22; 83:2; 115:14; 130:21 aren't [11 71:9 argumentative [1] 130:10 arise [5] 42:14; 68:13; 69:15; 71:15; 130:17 arises [1] 72:4 arrange [3] 8:2; 12:10; 88:21 arranged [1] 50:7 arrangements [2] 8:19, 20 arrive [4] 81:2; 112:1, 12; 132:13 ,, arrived [41 63:1; 111:8; 152:12; 165:17 arrives [11 145:17 arriving [1] 152:16 as-ueeded [l] 42:3 Aside [11 142:19 aside [81 7:14; 105:22; 111:17; 112:7; 141:9, 16; 170:1, 12 ,, asking [21] 15:18; 28:19; 66:3; 67:17; 68:11; 69:13; 71:13; 81:8; 95:14, 15; 109:21; 110:2, 4; 111:21; 120:22; 136:4; 140:9; 141:16; 145:11; 166:22; 169:9 assess [3] 156:8; 157:12 .Assessment [2] 76:14; 160:15 assessment [20} 76:15; 77:7, 9; 79:8. 18; 80:13; 81:6; 82:5, 13; 85:13; 88:18; 107:13, 18; 124:8; 129:12, 16; 130:18; 156:7; 161:2, 7 assessments [34] 75:19, 20; 76:7; 78:2, 9; 79:22; 85:12, 22; 86:3, 4, 10, 12, 16; 87:2, 6, 8, 9, 12, 20: 88:2, 5, 6, 7; 124:19; 125:1. 10, 17; 127:5; 128:6. 15, 18; 129:19; 130:9 .Assigned [1] 61:10 assigned [36] 24:8; 25:8, 17, 21; 26:4, 15; 27:7, 17; 28:2; 30:13, 14, 17; 31:2, 6; 33:7, 19; 34:2, 5, 13; 36:17; 37:11; 39:3; 40:5; 41:5, 6; 45:13, 15, 16. 19. 22; 46:10, 13; 47:16; 52:3; 54:11; 81:12 assignment [7] 25:7, 17, 19; 26:13; 30:11; 40:12; 96:3 assignments [3] 23:13; 28:7; 41:19 assist [2] 158:12, 16 assistance [6] 20:13, 16; 47:7; 81:9; 117:7; 151:12 Assistant [2] 25:18; 26:2 assistant [1] 6:18 associate [4] 107:10; 162:9, 13; 163:19 associated [5] 162:21; 164:1; 173:2, 7; 177:7 assumed [4] 9:21; 12:5, 14; 53:10 Assumes [1] 19:16 assuming [2] 109:17; 120:17 assumption [1] 12:8 Assure [1] 175:21 assure [2] 38:19; 85:5 assured [1] 62:17 Attached [1] 153:16 attachment [3] 93:13, 17; 139:2 attempt [5] 62:21; 66:21; 88:7; 163:9; 165:16 attempts [2] 115:13; 164:9 attend [6] 42:15; 43:15, 17, 21, 22; 44:11 attended [4] 23:2; 43:6, 9; 84:9 attending [3] 43:18; 49:18, 19 attention [13] 62:20; 81:10; 82:1; 84:11; 91:2; 99:22; 122:8; 138:10; 139:19; 140:1; 141:5; 142:20; 171:14 attorney [5] 8:1; 13:5, 9, 13, 14 attorney-client [2] 15:2; 22:8 attorneys [2] 16:9, 11 attribute [1] 144:15 Audrain [4] 154:16; 155:5, 8, 10 August [3] 40:1; 50:18; 74:9 Augusta [1] 52:19 author [13] 73:11; 82:8; 94:11; 123:13; 124:4; 125:4; 144:16; 145:2; 146:3; 154:12; 161:9; 162:10 authorities [1] 106:18 automobile [1] 163:3 available [9] 35:7, 18; 42:22; 57:1; 61:11; 63:2; 129:5; 131:11, 20 avoid [3] 70:11; 172:19; 173:5 Avon [3] 52:15; 148:14, 22 aware [22] 9:11; 15:7; 100:22; 101:9; 104:11, 13; 105:10, 11; 106:2, 14, 17, 21; 107:21; 115:19; 117:1, 3; 126:12; 142:19; 148:5; 162:7, 8 awful [4] 49:15; 157:20; 159:8; 163:2 awhile [1] 75:1 - B- B-e-r-g-e-n [1] 32:6 B3NA [2] 153:12, 14 Bachelor [1] 23:3 background [4] 23:1; 28:20; 29:3, 18 bailiwick [1] 177:2 balance [1] 15:4 banal [1] 15:1 Bank [1] 3:4 base [1] 76:4 Based [2] 106:4; 174:21 based [101 67:6; 88:18; 89:8, 14; 92:8; 95:16; 122:21; 131:19; 167:17; 168:13 Basically [1] 97:2 basically [4] 49:2, 5; 61:8; 78:17 basin [1] 169:16 basins [1] 144:9 basis [7] 42:3, 11; 59:16; 64:4; 68:6; 70:6, 9 basket [1] 112:1 bat [2] 82:20; 98:7 Bates [10] 83:11; 92:18; 99:21; 108:17; 127:5; 133:22; 136:21; 153:7; 160:15; 171:5 Bayou [1] 39:13 bearing [4] 40:2; 83:11; 136:20; 153:7 bears [1] 160:15 beat [1] 160:19 becomes [1] 102:16 beg [1] 70:10 behalf [3] 1:18; 67:16; 79:4 behavior [1] 79:1 behind [1] 156:7 believe [35] 6:19, 20; 7:15; 17:19; 37:6; 39:14; 47:15; 52:19; 53:9; 55:6; 58:4; 64:10; 66:8, 11, 15; 67:2, 3, 4, 10; 75:3; 79:17; 91:6; 95:3; 100:3, 5, 21; 104:19; 109:4, 11; 110:4, 9, 10, 19; 120:8; 135:21 believed [1] 171:19 beneath [3] 98:20; 171:14; 174:21 benefit [1] 59:15 Bergen [1] 32:6 bet [1] 45:5 bigger [3] 27:14, 15, 16 Bill [1] 38:19 binding [1] 68:10 biphenyl [1] 37:11 biphenyls [3] 21:12; 31:9; 32:8 bit [3] 59:12; 121:14; 132:3 blanket [2] 69:4; 71:13 blocking [1] 7:20 body [1] 168:22 bore [1] 122:13 boring [1] 124:20 boss [1] 93:11 bosses [2] 47:9; 98:8 boxes [4] 64:6, 8; 120:6 Brasfield [1] .87:17 Bray [1] 2:5 break [9] 38:4, 9, 11; 48:1, 4; 61:16; 62:9; 72:10; 122:1 Bridgeport [1] 52:17 Brief [1] 68:4 brief [1] 91:15 briefly [3] 22:22; 29:7; 154:2 broader [2] 128:20; 145:11 BRODERICK [1] 71:17 Broderick [1] 3:11 Brown [1] 62:20 Bryan [1] 1:20 buckets [1] 96:1 Building [3] 3:4; 153:15; 171:11 bulletin [1] 40:2 burden [1] 17:22 buried [4] 98:21; 99:10, 12, 16 Business [1] 32:7 business [8] 36:13, 16; 111:2, 19; 112:9, 11; 165:12; 176:6 button [1] 176:1 buttons [1] 175:17 -C- C-a-l-l-i-s [1] 53:9 C-o-r-e-y [1] 45:5 C.A. [1] 1:8 calculations til 24:9 calendar [1] 7:18 California [2] 3;6; 52:16 call [10] 7:14; 8:1, 2; 9:5; 13:14, 20; 22:5; 23:16; 26:16; 150:14 calling [1] 157:7 Callis [2] 53:9, 20 calls [2] 130:4; 169:19 camera [2] 80:3; 85:18 candid [2] 80:3; 85:18 capability [1] 174:16 carbon [1] 157:4 card [1] 20:19 care [1] 66:19 carefully [1] 158:17 Carpenter [3] 98:13, 14, 15 carried [1] 102:13 carry [11 28:7 case [20] 6:5, 14; 7:15; 9:20; 11:14; 13:12; 15:8, 17; 19:21; 63:7, 18; 64:19, 20, 21; 66:8; 69:6; 70:3; 91:8; 121:11; 159:22 case-by-case [1] 68:6 cases [2] 111:15; 163:2 CASTLE [1] 1:2 CASUALTY [1] 1:10 catalyst [2] 24:15; 157:19 catastrophic [1] 163:7 catch [1] 169:15 category [1] 176:2 CBY [7] 83:11; 86:6; 99:21; 127:5 cc [2] 74:13; 127:7 centers [1] 115:2 certified [1] 1:21 cetera [1] 48:12 chance [1] 18:4 change [8] 37:1, 4; 50:19, 20; 51:7; 52:7; 67:9, 11 ,, changed [5] 33i5> 9, 15; 35:12 changes [1] 76:6 changing [1] 21:3 characteristics [1] 159:9 charge [2] 40:18; 87:11 check [1] 66:17 Chemical [5] 25:3; 39:6, 8; 54:14; 98:16 chemical [4] 23:4, 5; 34:8; 157:1 Chemicals [1] 52:5 chemicals [18] 24:18; 26:8; 34:5, 6, 11, 12, 21; 35:1; 133:5; 157:10, 14; 158:1, 4, 7, 8; 159:2, 4 chloride [2] 34:16; 37:15 Chocolate [1] 39:13 Circle [1] 4:5 circumstances [1] 71:17 cited [1] 116:9 City [581 1:18; 12:9; ; 28:19; 29:3, 8; 39:13; 52:21; 53:4, 11, 14, 17; 54:21; 55:13, 19; 58:3; j 60:8, 19; 61:13; 77:10, 15; 79:8, 17; 88:22; I 90:13, 15, 18; 91:21; ! 98:17; 105:10; 106:3, 16; | 107:12, 17; 128:12; 132:9, ! 17; 135:7, 11, 14, 20; 136:7; 137:20; 139:20; 140:1, 7, 8; 141:5; 142:21; 144:4; 145:5; 148:14, 22; 150:18; 155:18; 156:15, 22; 159:13; 168:3 CJA-118-1-CV [1] 1:8 Clara [3] 139:21; 148:14, 20 clarify [1] 59:19 clarity [1] 44:4 Clayton [l] 53:9 Clean [1] 139:19 cleanup [7] 139:22; 140:5; 141:4; 142:20; 153:7, 17; 157:19 clear [6] 29:5, 16; 68:22; 69:19; 112:3; 151:7 clock [1] 7:7 closed [4] 171:19; 172:15, 16; 175:8 Closing [1] 174:14 closing [3] 172:19; 174:5; 175:13 closure [2] 124:10; 175:6 CO [1] 2:12 coaching [4] 91:6, 13; 164:6, 9 colloquy [2] 91:16, 17 Columbia [2] 39:13; 52:15 column [2] 74:13; 171:8 comfortable [1] 157:7 coming [2] 8:16; 102:7 commencing [1] 1:19 comment [3] 10:20; 72:19; 78:11 comments [3] 72:20; 146:11; 151:14 Commerce [1] 2:15 commitment [1] 68:12 commitments [1] 67:16 Committee [1] 73:9 committee [1] 67:20 communicate [1] 117:21 communicated [1] 151:12 communicating [3] 36:3; 49:21; 55:7 communications [3] 36:1; 59:13; 98:1 COMPANIES [1] 4:2 COMPANY [4] 1:4, 11; 2:3; 3:10 Company [12] 6:12, 18; 23:9, 12; 25:1, 3; 39:7; 52:5; 54:14; 98:16; 126:17; 161:13 company [4] 12:21; 41:11; 64:2; 84:21 compare [1] 115:12 competitors [1] 50:2 complete [6] 114:21; 116:10; 117:13; 120:15; 121:17; 127:12 completed [13] 70:3; 77:10, 11; 87:12; 89:17, 19; 108:19; 116:13, 18; 117:16; 128:13, 16, 17 completion [1] 77:7 complex [1] 131:5 appropriated to complex WATER PCB-SD0000068696 BSA Compliance [1] 93:19 compliance [5] 85:22; 101:18; 106:15; 107:13, 19 complied [1] 118:4 complies [1] 42:2 comply [2] 85:20; 172:20 composition [L] 29:21 compound [1] 170:5 compounds [1] 157:19 comprising [1] 66:9 compunction [1] 152:9 concentrate [1] 98:4 concentrations [1] 147:14 concern [10] 9:3; 65:12; .80:7, 13, 17; 116:20; 118:16; 145:22; 146:3 concerned [3] 68:8; 81:4; 167:17 concerning [4] 15:12; 40:13; 75:19; 84:7 concerns [3] 137:20; 162:6, 7 concluded [1] 125:4 conclusion [4] 123:13; 144:15; 145:10; 147:6 conclusions [1] 146:13 concrete [1] 166:21 Condition [1] 65:5 condition [6] 63:20, 21; 65:6; 156:9; 157:13; 167:14 conditions [14] 63:9, 17; 64:18; 65:4; 82:20; 89:8, 15. 19, 22; 90:8; 91:1; 158:20; 166:4; 176:8 conduct [2] 42:12; 55:14 conducted [4] 87:2; 108:19; 114:5; 124:8 conducting [2] 29:17, 20 Confidential [1] 161:14 confirms [1] 147:18 connection [3] 8:16; 73:8; 151:16 consensus [1] 152:13 Conservation [1] 93:19 consider [7] 10:18; 70:9; 130:20; 133:1; 176:3, 21; 177:6 consideration [2] 145:9; 172:22 considerations [2] 49:9, 10 considered [5] 142:11; 152:16; 161:17; 162:20; 177:10 consisted [1] 47:12 consistency [3] 84:22; 85:5, 9 constantly [2] 114:8; 128:15 considt [4] 63:11; 64:15; 69:11, 16 consultant [1] 136:13 consultants [2] 140:13; 151:16 consultation [1] 42:3 consulting [1] 42:1 contact [6] 8:21; 12:16; 13:12; 56:13; 60:13; 123:8 contacted [4] 6:14, 17, 19: 58:3 contacting [2] 8:19; 42:7 contacts [1] 50:8 contain [2] 80:10; 144:9 contained [4] 120:16; 146:20; 157:9; 166:12 containing [1] 157:4 containment [1] 98:21 Depo of: WILLIAM PAPAGEORGE Monsanto v Aetna January 13, 1993 CR: 54034.0 Look-See(31) contains [1] 168:22 contaminate [4] 143:7, 8; 144:21; 145:16 contaminated [5] 131:1, 2; 144:9; 150:3; 168:20 contamination [15] 21:22; 129:20; 130:21; 131:9, 16; 141:6; 146:8; 147:4; 148:2, 5; 149:20; 152:5; 156:2, 12; 161:16 contents [1] 115:6 context [1] 21:19 continual [1] 166:10 continue [12] 24:19; 26:12; 30:2; 54:4; 122:7; 127:11; 166:7; 167:21; 169:11; 173:22; 174:19; 175:15 continued [2] 155:8; 174:12 continues [1] 91:9 Continuing [4] 7:2; 56:7; 162:17; 169:11 continuing [2] 53:13; 103:17 continuous [4] 173:14, 16; 174:7; 175:9 continuum [1] 51:20 contract [1] 28:16 contracted [2] 30:3, 5 contractors [1] 140:13 contribute [1] 49:22 Control [6] 31:8, 11, 19; 32:2; 33:2; 45:10 controlled [3] 94:19; 96:6; 158:18 conversation [19] 7:9; 8:5, 11, 14; 9:3, 15, 16; 10:9; 11:17; 13:11, 18; 15:4; 17:7, 15; 18:7, 10, 12; 53:20; 62:9 conversations [5] 12:19; 13:3, 7; 15:12; 57:15 convince [3] 14:18; 16:1, 20 Cooperation [1] 70:2 cooperation [2] 70:1; 79:2 coordinate [l] 47:8 Coordinator [1] 93:20 coordinator [1] 98:13 copies [4] 22:4; 119:19; 121:6 copy [10] 78:2, 4; 86:18; 109:5, 12; 110:5; 112:22; 154:9, 13; 161:14 copying [1] 119:21 Corey [1] 45:4 corner [1] 141:22 Corporate [1] 55:8 corporate [20] 40:8, 11; 41:5; 42:2, 17; 43:18; 44:16; 45:21; 46:15; 49:21; 50:16; 84:19; 85:10, 20, 22; 103:1; 151:9; 156:8; 161:2, 6 corporate-level [1] 145:22 Corporate-wide [1] 152:21 Corporation [1] 2:6 corporation [1] 84:22 corrected [1] 168:12 corrective [5] 98:22; 154:3; 167:19; 168:12; 169:19 correctly [3] 9:2; 40:18; 49:1 cost [1] 75:12 costliness [1] 170:9 costs 19] 139:19, 22; 140:5; 141:4; 142:20; 152:15; 173:2, 6, 8 Counsel [1] 91:5 counsel [6] 12:20; 63:8, 12, 17; 70:12, 14 : counteroffer [1] 65:4 country [1] 148:2 : COUNTY [1] 1:2 i couple [3] 21:14; 24:20; : 26:13 course [18] 7:7; 16:3; 43:12; 49:15; 50:6; 55:21; ; 57:16; 61:3; 111:18; ' 112:9, 11; 123:1; 129:8; ; 130:22; 150:1; 165:12; 167:15; 175:14 courses [1] 149:14 COURT [7] 1:1; 20:5; j 59:22; 106:9; 112:6; 163:18; 170:11 I cover [5] 105:17; 115:11, I 14; 153:10; 177:6 | coverage [6] 6:13; ! 176:14, 16, 22; 177:6, 11 covered [4] 27:21; 35:17; 39:15 covers [2] 35:7; 49:22 1 create [1] 66:2 created [2] 85:3; 157:19 credit [1] 67:13 J criticism [1] 135:9 j critique [1] 72:21 | cross-reference [1] 119:3 ' crude [2] 24:13, 15 I Current [1] 92:17 current [1] 20:21 ] currently [2] 68:7; 148:13 Customary [1] 111:15 | customary [1] 111:13 ! customer [2] 35:7, 18 ' customers [3] 36:1, 4; I 50:1 ! cutoff [1] 51:13 -D- ! D.C. [4] 2:9; 3:14; 4:6; j 44:9 i daily [1] 98:4 j dairy [1] 165:15 1 dark [1] 166:20 data [1] 76:4 date [11] 24:22; 33:8; 37:6; 50:18; 58:7; 61:3; 77:12; 86:13; 87:10; 140:2, 4 dated [4] 83:11; 123:20; , 160:14; 161:8 dates [3] 17:3; 27:2; 34:4 David [1] 7:13 day [13] 1:20; 10:14; 63:4; 66:11, 16; 71:6; 89:20; 97:4; 163:14; 165:17; 167:18; 177:18 day-in [1] 59:13 | dav-out [1] 59:13 days [5] 11:8; 28:18; 63:6; 66:14; 67:13 deal [3] 32:18; 68:2; 69:9 dealing [1] 57:2 dealings [1] 55:20 dealt [5] 15:5; 21:21; , 49:13; 55:22; 67:21 ; decade [1] 88:16 : December [7] 6:15; 13:4, ' 8; 114:5; 115:18; 116:15; 123:20 decide [1] 89:7 1 decided [4] 62:4; 88:20; j 92:3; 152:8 decides [1] 41:20 decision [6] 10:11; 88:17; 110:17; 132:13; 152:16; 169:19 Decisions [1] 122:12 decisions [1] 81:2 Declassify [1] 176:2 DEFENDANT [3] 2:12; 3:1, 10 defendant [1] 64:2 DEFENDANTS [1] 4:1 Defendants [12] 1:13, 18; 63:18; 65:13. 18; 67:10, 21; 70:7, 8; 71:5, 11, 19 defense [10] 63:8, 12, 17; 67:2, 17, 19; 69:11, 16; 70:11, 14 define [2] 55:3; 161:5 definition [6] 106:1, 4, 7; 141:20; 157:2, 3 degree [6] 53:19; 78:20; 131:2; 147:13; 149:8, 11 degrees [1] 23:3 DELAWARE [1] 1:1 Delaware [9] 7:15; 9:20; 12:2, 6, 9; 139:20; 148:14, 20 delay [4] 116:6, 9, 20; 117:2 delegated [2] 135:22; 136:2 deliver [l] 119:6 delivered [1] 118:17 deluge [1] 163:5 DEO [10] 94:4, 12, 21; 95:13, 18, 21; 96:17; 99:1, 2 Department [19] 24:8; 25:9; 26:15; 27:4, 8, 9, 14; 32:2; 33:17; 36:11; 43:19; 51:12; 55:8; 85:2; 121:5, 7; 136:7, 10, 14 department [9] 25:18; 26:5; 31:22; 32:4; 33:16; 36:6, 10, 12 departments [6] 28:7, 10. 14; 30:12; 49:21; 84:21 departure [2] 17:3 Depending [1] 158:17 depending [1] 42:21 depends [2] 38:13; 80:17 deposed [2] 21:6; 29:4 Deposition [27] 1:17; 5:8, 9, 10, 11, 12. 13, 14, 15, 16, 17, 18, 19, 20; 39:17; 74:4; 83:7; 92:12; 99:17; 108:11; 126:20; 133:7; 136:16; 137:22; 153:1; 160:9; 170:22 deposition [39] 9:9, 11; 10:19; 11:1; 14:9, 10, 13, 15; 16:8, 10, 14, 15, 17; 18:17, 20; 19:2, 9, 21; 20:3, 18; 21:16; 22:2; 28:18; 29:3; 38:6; 62:11; 63:4, 14; 64:21; 65:20; 67:3, 5; 68:8, 13, 18; 70:14; 71:4; 126:22; 177:17 deposition-by-deposition [3] 64:4; 70:6, 9 depositions [7] 21:9, 14, 15, 21; 63:22; 68:10, 12 describe [6] 22:22; 25:4; 46:18; 57:14; 125:6; 131:21 described [2] 30:11; 35:9 describes [1] 162:12 design [2] 25:9; 175:19 designate [4] 63:6; 65:20; 70:13; 119:13 designated [6] 62:12, 14, 17; 65:19; 76:22; 103:9 designating [1] 154:12 designation [7] 65:14, 18; 68:16; 119:7, 9; 141:14, 17 designations [2] 63:16; 68:17 designed [2] 128:19; 153:22 desired [1] 24:16 desk [3] 111:8; 112:12 destination [1] 131:4 detail [1] 150:1 details [6] 7:22; 15:11; 75:22; 78:21; 106:21; 140:14 determinations [1] 152:4 determine [7] 35:2; 75:16; 76:5; 88:7; 131:1; 156:12; 172:9 determined [1] 151:5 develop [21 72:22; 175:2 developed [3] 100:22; 101:1; 129:3 developing [1] 84:19 development [1] 101:18 developments [5] 46:21; 47:10; 48:12; 49:1, 14 dictate [3] 124:9; 125:1, 10 differ [1] 70:10 difference [2] 10:14, 17 differentiate [1] 114:8 differently [1] 125:15 differs [1] 41:15 difficult [3] 34:4; 70:3; 169:13 difficulty [5] 45:18; 46:14; 106:20; 138:13; 139:5 direct [8] 41:11, 21; 53:22; 84:11; 99:22; 122:8; 171:13 directed [1] 141:5 direction [1] 10:21 Director [42] 32:7; 37:22; 39:4; 40:17; 43:14; 45:9; 46:19; 48:5; 52:3; 53:3; 54:5; 55:9, 18; 56:15; 59:9; 73:19; 76:8, 15; 78:6, 14; 84:8; 87:22; 90:12; 93:7; 95:16; 97:12; 98:2, 15; 115:18; 122:21; 128:11; 133:2; 137:6; 138:11; 141:1; 145:4; 146:18; 147:22; 148:16; 154:22; 159:16; 176:18 director [6] 43:19; 45:13, 16; 46:10; 163:13, 15 Directors [4] 41:5, 7; 43:13; 94:5 directors [2] 42:15; 43:2 disagree [2] 91:14; 145:6 discovered [1] 168:12 Discovery [4] 19:20; 91:7, 10; 164:6 discovery [3] 29:17, 20; j 70:16 j discuss [1] 53:21 { discussed [2] 43:4; 62:3 I discussing [2] 49:20; j 126:2 Discussion [4] 39:1, 20; 142:16; 177:16 disinterest [2] 116:6, 9 From Compliance to disinterest WATER PCB-SD0000068697 BSA Depo of: WILLIAM PAPAGEORGE Monsanto v Aetna January 13, 1993 CR: 54034.0 disposal [19] 24:1; 26:21; i drippage [1] 166:10 28:9; 30:6; 36:1; 77:18; i Drive [1] 20:20 99:10. 11, 14: 106:19; ; driven [1] 173:10 114:12; 115:6; 124:11; 1 dry [1] 89:12 145:18; 146:6; 158:3; i duly [1] 6:3 173:21; 175:18, 22 dispose [11 174:1 dumps [1] 146:7 ! duplicate [1] 161:14 disposed [2] 115:5; 166:19 -E- disposition [21 94:19; 96:6 dispute [1] 94:12 distance [1] 19:7 distinct [1] 23:13 distinguish [1] 167:6 distinguished [2] 41:10; 51:5 distribution [2] 28:5; i E3NJ [11 74:18 Earl [1] 87:17 , early [5] 19:4; 30:13; | 50:8; 61:4; 174:18 earthen [1] 144:8 easier [1] 139:12 easily [1] 159:5 Ed [5] 56:9, 19, 20; 61:8; I 108:3 83:14 ditch [1] 162:6 document [82] 40:7; 62:15; 63:3; 64:9; 65:8, 9, 11, 15; 74:6; 79:9, 16; 83:13, 15, 17, 20, 22; 84:3, 5, 12; 92:20, 22; 93:7; 95:7; 100:4, 6; 108:21; 109:5, 12, 17; 110:3, 21; 111:7, 20, 22; 112:10, 11; 113:1, 19, 21; 114:2; 115:1; 118:15, 16; 119:10; 120:5, 11, 14. 17; 122:8; 123:15, 17; 127:4, 10, 12; 133:19; 134:19; 136:20, 22; 137:2; 138:6. 8, 9, 15, 21; 139:4, 15, 17; 141:4; 143:16, 19; 146:4; 153:3, 9; 154:2; 155:17; 160:11. 14, 17; 162:10; 171:5, 6, 16 Documents [1] 76:14 documents [51] 22:3, 4, 6, 11; 49:16, 18; 62:1, 12, 16, 18, 22; 63:7, 8, 11, 19; 65:14, 19; 66:9, editor [1] 73:11 educational [1] 22:22 effect [12] 14:5; 16:4; 105:21; 106:11; 131:4; 132:15; 133:5; 167:15, 17, 20, 21; 169:15 effective [1] 152:14 effectively [2] 104:8; 122:15 efficiency [1] 152:14 effort [7] 14:18; 69:12; ' 173:13; 174:6; 176:4, 9, 10 efforts [2] 174:5; 177:7 Eighties [1] 61:4 eighty [1] 28:22 E1L [1] 3:1 embarked [1] 150:7 emergency [2] 72:1, 4 Emissions [1] 93:14 emissions [1] 76:4 employee [5] 47:4; 49:10; 54:17; 102:3; 105:22 employees [2] 54:13; 103:16 employment [2] 19:16; i10, 12, 20; 67:22; 68:16; 103:22 69:20; 70:13; 71:5, 9, 12; | enacted [1] 172:7 76:15; 78:7; 79:10; 87:6; | enactment [1] 175:8 88:13; 103:14, 15, 18; 105:16; 109:19; 110:22; I encouraged [1] 150:3 | encouragement [1] 17:6 111:4, 14, 17; 112:7; 118:17, 19; 119:6. 8; 120:3; 121:10; 160:7 Doesn't [1] 175:6 doesn't [14] 35:9; 38:17; : encouraging [1] 16:21 i end [10] 17:15; 24:17; j 31:4; 54:7; 58:16; 127:12; ; 157:18; 159:6; 166:11 i energy [1] 23:17 j44:13; 67:13; 78:5; 79:12: engage [2] 173:5; 176:5 87:5; 89:2; 96:21; 108:20; I engineer [1] 149:7 110:12; 111:12; 112:13; 137:16 Donnenfeld [1] 2:5 door [3] 42:11; 43:20; 105:16 doors [1] 98:6 dot [4] 171:14; 174:10; 175:4 Engineering [4] 24:8; 25:9; 27:8; 136:13 engineering [7] 23:4, 5; 27:13, 16, 21; 149:9, 11 engineers [3] 27:11; : 56:10; 57122 : ensure [3] 85:9; 116:12; ! 159:20 dots [2] 174:21; 175:17 dotted [1] 41:22 dotted-line [2] 41:9, 15 double-a-a-r [1] 50:17 double-e [1] 45:12 dozen [4] 21:14; 30:17; 108:6; 135:19 Dr [1] 53:20 draft [1] 83:10 drafts [3] 72:18; 73:12; 100:22 draw [1] 168:19 drilled [l] 151:19 drilling [2] 23:15; 24:4 drip [2] 162:19; 163:2 , entailed [1] 149:22 i enter [4] 69:4; 166:15; j 177:12 enters [1] 126:22 i entitled [2] 138:4; 160:15 j environment [14] 31:9, i 14; 32:19; 33:3; 35:14, I 16, 19; 47:3; 88:8; 166:4. 12, 16; 167:15 Environmental [81] 31:8, 10, 19; 32:2; 33:2, 6, 15, 16, 21; 35:8; 36:11; 38:1; 39:4; 40:17; 41:6. 8; 43:13, 15; 46:19; 47:20; 48:5; 51:5, 6, 8; 52:4; 53J; 54:6; 55:10, 18; 56:15; 59:9; 73:8, 19; 74:10; 76:8, 14, 16; 78:7, 15; 84:6, 8, 21; 85:2; 87:1, 22; 90:12; 92:18; 93:7; 94:5, 18; 95:17, 19; 97:12; 98:2, 12, 15; 100:11; 101:21; 102:10; 113:6; 115:18; 122:21; 124:9; 126:15; 127:15; 128:11; 133:2; 136:7, 9; 137:6; 138:12; 141:1; 145:4; 146:19; 147:22; 148:16; 149:9; 154:22; 159:16; 176:18 environmental [77] 21:17; 35:10, 16; 37:11; 40:8, 13; 42:15, 17; 43:2; 44:16; 45:16, 21; 46:15, 22; 48:13; 49:2, 8, 14; 50:4; 54:15, 16; 55:12; 56:10; 59:4; 60:2, 8; 72:16; 75:19; 76:15; 77:7; 78:8, 18, 22; 79:8, 18, 22; 80:4, 12, 13; 81:18; 82:13; 83:3; 84:7, 18, 20; 85:3, 8, 12, 13, 21; 86:10, 16, 19; 87:2, 19; 88:2, 4, 5, 6; 94:3; 98:5; 105:9. 14, 19; 106:1, 2; 107:12, 17; 128:19, 22; 129:11; 130:7, 9; 149:6, 10; 156:5; 166:20 EPA [1] 174:21 equipment [3] 24:10; 25:9; 28:16 equivalent [1] 68:16 escape [1] 158:18 escapes [1] 45:12 essence [4] 7:13; 14:4; 16:7; 112:1 Essentially [1] 74:19 Establish [1] 94:18 establish [2] 76:4; 114:11 established [4] 15:2; 35:4; 36:16; 51:13 establishing [3] 86:11; 96:5; 102:2 establishment [1] 40:8 estimate [2] 61:6; 140:19 et [2] l;ll; 48:12 evaluate [2] 112:17; 175:2 evaluated [1] 126:13 evaluation [5] 75:8; 76:3; 90:19; 91:21; 92:8 evaluations [3] 87:18; 89:17; 118:8 evaporate [1] 159:5 evening [1] 22:21 event [5] 54:1; 66:18; 68:5, 12; 71:8 eventually .[6] 26:6; 37:17; 46:12; 56:22; 143:7; 144:10 Everett [1] 52:17 Everybody [1] 102:21 evidence [2] 19:17; 82:14 evolved [1] 130:4 exact [8] 7:12; 9:18; 14:4; 16:3; 17:17; 19J; 28:3; 61:3 exactly [4] 29:15; 73:20; 117:15; 151:5 EXAMINATION [2] 5:3; 6:6 examination [2] 118:15; 150:6 examining [1] 149:19 example [10] 24:17; 71:18; 89:10; 117:1; 131:1; 146:21; 158:14; 168:14; 169:11; 175:16 examples [1] 158:13 except P] 44:8; 57:14; 161:10 exception [3] 64:19; 66:2; 120:2 exceptions [2] 111:16; 125:22 excess [1] 64:5 excessive [2] 173:1, 6 exchange [1] 45:1 excluding [2] 12:19; 54:16 exclusions [1] 126:9 Excuse [4] 6:21; 9:8; 28:8; 106:6 execution [2] 88:17; 117:3 exhausted [1] 23:16 Exhibit [42] 5:8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20; 39:17; 74:4, 9; 83:6, 7, 10; 92:12, 16; 99:17, 20; 108:11, 15; 122:7; 126:20; 127:3; 133:7, 11; 136:16, 20; 137:22; 138:4; 153:1, 6; 160:9, 14; 170:22; 171:4 exhibit [3] 39:16; 95:4; 116:16 EXHIBITS [1] 5:6 exigencies [1] 69:9 exist [4] 89:15; 91:1; 103:19; 147:9 existed [5] 88:19; 89:8; 118:13; 144:4; 150:4 existing [3] 99:9; 106:19; 144:20 expand [2] 33:2, 16 expect [11] 64:20; 65:16; 69:22; 70:5; 80:6, 10, 12; 103:17; 128:12; 159:5, 6 expectation [2] 132:5, 8 expectations [1] 102:17 expected [9] 16:4; 67:5, 6; 71:20; 78:20, 22; 101:10; 111:19; 112:9 expecting [1] 67:8 expended [1] 173:14 expenses [4] 8:15; 10:2; 19:13; 20:7 experience [10] 57:18, 19; 121:8; 122:21; 147:18, 19, 21; 169:4, 5, 6 experienced [1] 57:22 experiences [1] 54:2 expertise [2] 145:20; 146:14 explain [4] 35:10; 40:21; 125:4; 158:5 exposed [1] 166:5 exposure [8] 47:4; 49:10; 54:13, 17, 19, 21; 55:5; 106:1 Express [1] 62:12 extensively [1] 104:8 extent [2] 29:11; 152:5 -F- F-o-r-e-s-m-a-n [1] 51:4 face [2] 64:22 ; 65:16 facilities [13] 171:18, 19; 172:2, 6, 19; 174:2, 3, 5, 13, 14; 175:5, 7, 19 facility [4] 141:18, 21; 142:7; 172:15 fact [15] 12:9; 16:22; Look-See(32) 59:12; 62:20; 65:10; 66:14, 17; 109:16; 110:12; 137:18. 19; 153:7, 17; 167:9; 170:7 factor [3] 129:15, 17; 150:21 factors [1] 152:15 facts [2] 19:16; 159:12 fail [1] 164:19 fails [I] 168:20 failure [5] 162:18; 163:7; 167:7; 168:13, 17 failures [3] 168:11; 170:1, 12 fair [3] 58:16; 121:2 fairly [1] 115:8 familiar [7] 23:19; 83:14, 19; 87:18; 90:14, 16; 133:3 fashion [3] 25:4; 29:3, 7 fault [1] 67:3 faultless [1] 109:22 FAX [4] 2:18; 3:8, 16; 4:8 faxed [1] 66:11 feasible [2] 170:3, 14 feature [1] 130:12 February [1] 133:12 Federal [2] 3:4; 62:12 federal p] 49:18; 81:15; 129:7 feel [3] 64:16; 69:12; 157:7 feeling [1] 150:19 felt [9] 10:19; 42:4; 59:14; 116:7; 117:9; 118:1, 9; 150:14; 151:14 fence [5] 99:13; 141:22; 142:3, 4 fiber [2] 89:10, 13 field [2] 23:15; 24:4 Fielding [1] 3:12 Fifties [2] 167:10, 19 fifty [1] 64:11 File [1] 113:6 file [2] 64:5; 111:9 files [1] 86:20 fill [1] 116:7 final [4] 47:6; 72:22; 131:4; 153:16 find [14] 51:21; 59:7; 60:14; 63:14; 70:14; 90:4; 120:17; 124:1; 125:14; 130:8, 18; 132:1; 138:14; 147:12 finding [2] 131:6; 139:5 finds [2] 70:12; 168:21 fine [1] 159:22 finish [1] 128:15 finished [1] 22:21 finite [1] 78:21 fire [1] 163:7 firm [2] 6:10; 118:20 first [42] 6:3, 13, 14; 21:20; 39:16; 45:4; 50:12; 55:22; 56:4; 58:2, 4, 10, 17; 61:2; 63:20; 72:7; 75:2; 77:6; 95:1; 97:3; 100:8; 102:5; 105:13; 107:15; 108:22; 113:19; 122:9, 12, 20; 124:13, 20; 127:11, 12; 129:3; 139:18; 145:14; 153:8; 154:7, 19; 160:18; 171:14; 175:4 fish [9] 167:16; 168:14, 16, 22; 169:1, 6, 7, 12, 17 fit [1] 124:4 five [3] 7:8; 75:5, 13 disposal to five WATER PCB-SD0000068698 BSA Hawed [1] 112:15 flip [1] 92:21 floating [1] 169:1 Floor [1] 2:15 floor [5] 153:15; 163:3; 166:17, 21; 171:12 flow [1] 147:10 flows [1] 147:14 focus [2] 29:8; 44:22 folks [1] 57:17 followed [1] 123:6 Following [2] 13:11; 25:17 following [8] 9:1; 22:17; 23:6; 53:17; 115:4; 154:11; 175:3; 177:18 follows [1] 6:5 foolproof [1] 109:22 Force [1] 138:5 force [1] 143:20 forced [1] 152:17 foresee [1] 21:3 Foresman [1] 51:4 forget [4] 14:4; 56:4, 22; 105:7 forgotten [4] 46:6; 54:12; 106:21; 121:20 form [4] 20:1; 49:3; 65:16; 175:12 formal [4] 42:7; 45:4, 11; 105:15 formations [l] 91:3 formed [1] 37:8 former [1] 103:15 formulated [1] 102:18 forth [2] 29:1; 149:11 Forties [1] 167:18 forwarded [2] 35:6; 103:12 found [3] 139:8, 13; 148:10 foundation [19] 73:2; 77:20; 90:2, 21; 91:12; 104:7; 124:16; 132:11; 144:5; 148:3; 152:10; 157:15; 161:4; 164:3, 8; 167:11; 168:8; 171:21; 176:15 four [3] 27:22; 66:9, 10 fourth [3] 27:22; 171:11, 14 fractions [2] 24:11, 12 triune [3] 44:3; 51:14, 19 Francisco [1] 3:6 frankly [3] 93:10; 106:21; 124:1 Fred [4] 56:6, 7, 17 frequency [2] 165:7; 170:8 ' Friday [5] 18:13, 14; 19:1; 62:15; 159:21 fulfilling [1] 101:10 full [2] 10:15; 65:16 full-time [1] 32:12 fully [1] 55:3 funding [1] 82:18 future [7] 21:4; 63:13; 68:2; 71:8. 14; 111:9; 169:21 fuzzy [1] 79:10 _________ - G - G4WA [1] 171:10 gained [1] 29:12 game [1] 20:2 garage [1] 163:3 Garrett [1] 32:14 gasoline [1] 24:17 gave [4] 11:7; 21:15; 93:11; 106:4 Depo of; WILLIAM PAPAGEORGE Monsanto v Aetna January 13, 1993 CR: 54034 0 Gee [1] 161:5 gee [1] 170:7 Gene [2] 45:12; 56:1 generated [3] 28:14, 15; 162:18 geology [1] 23:19 Georgia [1] 52:19 gets [1] 96:21 gist [2] 11:6; 19:4 give [17] 21:8; 24:22; 27:20; 34:10; 41:14; 58:7; 60:7, 9; 65:1; 71:5; 90:5; 98:8; 110:12; 135:17; 139:9; 140:18; 158:14 given [8] 18:19; 21:9; 33:11; 36:20; 91:2; 100:21; 144:14; 164:11 giving [2] 29:14; 105:15 glad [1] 141:19 goal [2] 105:8; 131:7 goals [9] 101:19, 21; 102:1, 7, 8, 18; 103:1, 8; 175:3 God [1] 157:16 goes [7] 29:21; 48:1; 82:16; 115:7; 132:3; 154:9; 162:22 goodwill [1] 152:15 gotten [2] 110:13; 158:21 governmental [2] 49:16; 106:14 grabbing [2] 131:5; 132:4 graduate [1] 149:6 grandfathered [1] 172:17 ground [6] 20:2; 91:11, 15; 144:21; 145:8; 159:6 grounds [4] 22:7; 59:20; 91:6; 164:8 Groundwater [5] 133:12; 138:22; 139:3; 143:14; 160:15 groundwater [46] 23:19; 107:9, 11; 129:20; 130:2, 3, 21; 131:3, 8, 15; 132:3, 6, 9; 134:22; 135:7, 10, 13, 14; 137:13, 15, 19; 141:6; 143:8; 144:11; 146:8; 147:4; 148:1, 5, 11; 149:19; 151:3, 8, 9; 152:21; 153:19, 22; 156:1, 7, 9, 13; 157:13; 158:4, 22; 161:2, 7, 16 groundwaters [1] 150:2 Group [1] 32:7 group [20] 26:16; 27:5; 33:7, 19, 20; 34:5; 36:13; 37:11; 40:10, 12; 41:5; 52:21; 56:8; 67:2, 17, 20; 69:11, 17; 72:21; 116:22 groups [1] 36:16 grueling [1] 38:7 guess [7] 18:3; 58:2; 61:5; 118:5; 121:8; 136:4; 141:12 guessing [3] 113:11; 136:5, 12 guesswork [1] 135:18 guidance [1] 41:22 Guideline [7] 94:18; 95:2, 9, 19; 96:7; 98:12; 126:5 guideline [5] 75:18; 77:6; 101:18; 105:8; J26:2 Guidelines [8] 74:11; 87:1; 100:11; 101:21; 102:10; 124:9; 126:15; 127:16 guidelines [27] 72:17, 19; 73:1, 5, 15, 17, 21; 74:2; 75:4, 7, 10, 11; 100:17; 101:3, 7, 9, 11; 102:5, 13; 103:1; 105:4, 7; 128:20; 129:2, 5; 130:7; 156:6 guy [1] 60:11 guys [3] 62:3; 136:14; 160:1 -H- H-i-m-e-s [1] 56:5 hadn't [3] 9:6; 10:22; 17:9 half [2] 30:17; 162:19 hand [2] 78:5; 109:8 handed [1] 20:19 handful [1] 65:19 handle [1] 19:7 handled [1] 35 JO handling [1] 47:5 hands [1] 110:3 handwriting [5] 113:3, 4, 10, 16; 134:14 happening [2] 53:17; 167:22 happens [5] 18:2; 82:16; 89:12; 112:13; 131:3 hardly [1] 68:9 hasn't [2] 66:20; 82:18 haul [1] 28:17 haulers [2] 28:16; 30:3 haven't [2] 9:6; 139:8 Hazardous [1] 21:19 hazardous [3] 21:16; 24:1; 175:21 head [1] 41:4 headed [2] 40:11; 42:17 heading [5] 76:13; 93:14; 94:9; 122:13; 137:4 hear [5] 7:21; 11:2; 17:18; 106:6; 107:15 heard [4] 8:8; 9:6; 11:15 heat [1] 24:14 heavily [1] 70:3 heck [1] 132:4 held [1] 25:5 help [20] 21:18; 47:7; 53:8; 72:22; 76:5; 78:10; 81:1, 11; 98:5; 105:14; 107:2; 116:7; 117:6, 22; 118:1; 124:6; 145:12; 151:15; 157:2; 171:22 helpful [2] 59:11; 121:18 Hendricks [18] 56:9, 19, 20, 22; 57:9, 12, 17; 58:1, 6, 18; 59:8; 60:7, 13, 17, 19; 61:8, 11; 108:3 Herrington [2] 3:3; 118:20 hesitating [1] 37:17 hierarchy [1] 40:21 high [1] 132:19 highly [1] 159:4 Himes [7] 56:5, 7, 17; 58:14; 59:16; 60:12; 108:5 hint [1] 150:11 hired [2] 28:16; 136:13 History [1] 162:4 history [7] 57:21; 58:18, 21; 60:7, 10; 165:3; 167:4 Hmm [1] 55:22 Hmm-mm [1] 24:2 hoc [2] 42:9, 10 hold [1] 11:8 holding [2] 78:4; 109:8 holidays [2] 6:16; 9:1 home [2] 19:6; 83:1 honest [1] 72:8 honestly [2] 75:15; 124:17 hope [1] 119:18 Hotel [1] 1:18 hotel [4] 8:3; 12:11; 17:5; 62:22 hour [2] 38:9; 162:19 Howard [1] 32:6 HUGHES [16] 56:6; 62:7; 66:7, 16; 68:5; 69:19, 22; 71:3; 97:5; 106:6, 12; 119:2, 5, 13; 160:8, 20 Hughes [4] 3:2; 62:15, 18, 19 Huh [1] 121:3 hung [2] 8:10; 96:22 hydrocarbon [1] 159:8 hydrocarbons [1] 158:13 Hydrogeological [1] 88:12 hydrogeological [10] 87:18; 88:3, 14; 89:11, 14, 17; 90:1, 9, 18; 91:21 hydrogeologist [6] 90:4, 22; 132:12; 146:22; 147:2; 149:5 hydrogeology [4] 23:19; 132:17; 133:3; 147:5 Hygiene [1] 47:16 hygiene [1] 47:17 hygienists [1] 55:8 Hypothetical [1] 176:7 hypothetical [10] 81:7, 20; 82:6; 131:18; 149:13; 162:16; 164:2, 8; 167:12; 168:19 -I- I'd [37] 13:20; 15:17; 19:19; 29:14; 60:5; 63:21; 66:7; 67:1; 81:21; 83:12; 84:11, 16; 86:5; 92:20; 94:15; 95:1; 99:22; 100:8; 113:11, 18; 121:5; 122:7; 134:17; 136:22; 138:5; 139:3; 141:19; 143:4; 144:14; 149:16; 157:16, 20; 159:8, 19; 161:5; 171:22; 172:9 I've [12] 6:19; 17:18; 21:13; 30:10; 39:15; 54:12; 64:18; 106:21; 112:21; 121:20; 134:20; 160:18 Idaho [2] 39:14; 52:14 idea [7] 74:1; 75:11; 102:6; 122:19; 127:22; 156:7; 161:15 ideas [1] 115:11 identification [26] 39:18; 40:1, 2; 74:5, 11; 83:8; 92:13, 16; 99:18; 108:12, 15; 126:21; 127:3, 7; 133:8, 11; 136:17, 20; 138:1, 4; 153:2, 6; 160:10; 171:1, 4; 174:2 identified [3] 81:5; 97:18; 99:1 identify [10] 64:14; 65:7; 80:6, 13, 16; 95:12, 18; 128:19; 130:21; 131:8 idle [1] 142:1 ignorance [1] 130:18 U [2] 93:14; 94:14 Illinois [2] 30:15; 31:2 immediately [1] 175:2 impact [15] 47:2; 78:8; 79:8, 18, 22; 80:12; 81:6; 82:5, 13; 88:2, 4, 6, 7; 107:13, 18 impervious [1] 168:6 _______________Look-See(33) Implement [1] 94:18 implementation [6] 75:4, 6; 85:4; 1013, 12; 105:4 implemented [3] 85:2; 101:7; 104:9 implementing [1] 95:9 implication [3] 127:20; 128J; 168:9 implying [1] 161:22 important [4] 81:10; 101:17, 20; 102:6 importantly [1] 49:9 imposition [1] 19:6 impossible [1] 95:21 impoundment [1] 162:5 impoundments [2] 122:15; 124:14 impractical [1] 170:16 impression [2] 8:10; 27:20 improper [1] 91:6 in-house [1] 13:13 inactive [9] 115:5; 171:18, 19; 172:6, 19; 174:13; 175:5, 7, 13 inadvertent [1] 120J incident [1] 163:8 include [13] 32:10; 68:17; 94:7; 98:17; 99:14; 102:7; 105:6; 124:20; 125:19; 126:5, 11; 145:5; 163:22 included [10] 28:4; 34:6; 36:13; 49:15; 105:3; 115:3; 123:3; 125:18; 126:10; 138:16 includes [1] 118:19 incomplete [1] 120:14 incorporate [3] 103:1; 128:21; 129:19 incorporated [6] 127:16; 129:4, 8, 12, 14; 135:10 increases [1] 41:20 independent [3] 118:22; 119:2, 9 INDEX [1] 5:1 index [1] 138:20 indicate [10] 10:4; 14:8, 12, 15; 18:3; 41:11; 83:13; 124:12; 127:14; 175:6 indicated [4] 40:5; 64:13; 114:14; 131:11 indicates [5] 20:19; 51:10; 112:12; 119:10; 128:4 indication [3] 18:19; 94:12; 110:13 indications [1] 131:14 individual [5] 14:6; 45:13, 19; 51:4; 94:1 individuals [7] 40:10; 42:14; 43:10, 17; 47:12; 102:19; 152:11 Industrial [2] 47:15; 52:4 industrial [2] 47:17; 55:7 influenced [1] 167:19 influential [1] 130:13 Info [1] 113:9 information [29] 10:10, 20; 11:6, 11, 13; 15:13, 14; 35:6, 18; 47:8; 55:13; 60:14; 82:17; 101:5; 105:3; 115:4; 130:1; 131:11, 19; 144:6; 145:14, 17, 19; 146:13, 19; 151:3; 154:1; 158:3; 161:16 informed [15] 46:21; 47:1, 4, 9; 48:11, 13; 49:1; 53:16, 19; 55:11; From flawed to informed WATER PCB-SD0000068699 BSA Depo of; WILLIAM PAPAGEORGE Monsanto v Aetna January 13, 1993 CR: 54034,0 Look-See (34) <>2:13, 15: 81:22; 150:2; 151:1 informing [2] 35:17, 19 inhibit [1] 59:10 initial [3] 25:7; 50:3; 77:7 Initially [2] 23:14; 47:12 initially [3] 56:21; 57:3; 58:9 initials [1] 74:17 initiate [1] 63:14 initiates [1] 68:14 input [1J 58:1 inquire [1] 103:13 inside [1] 141:21 install [1] 27:19 installed [2] 25:10; 125:9 instance [3] 65:15; 71:14; 131:15 instances [3] 151:18, 20, 22 instituted [1] 76:10 instruct [1] 22:8 instrument [1] 26:19 instruments [1] 27:15 INSURANCE [3] 2:12; 3:10; 4:2 Insurance [1] 6:11 insurance [12] 6:13; 7:15; 11:14; 64:2; 65:1; 66:2; 176:14, 16, 20, 21; 177:6, 11 insure [2] 84:22; 85:22 integrate [2] 101:17, 20 integrity [1] 114:11 intended [4] 115:15; 116:10; 119:3; 164:20 intent [5] 103:3; 125:19; 126:4; 130:13; 173:1 interest [4] 65:12; 106:17; 117:17; 150:2 interested [2] 53:21; 150:13 intermediate [2] 47:6; 157:18 Intermediates [2] 39:6, 9 internal [2] 12:20; 112:16 INTERNATIONAL [1] 3:1 interpret [1] 17:6 interpretation [1] 125:11 interpreted [2] 14:1; 15:4 interpreting [1] 125:14 interrupt [1] 25:22 interrupting [1] 93:5 interruption [1] 68:4 Introduction [1] 113:22 introduction [1] 29:22 investigated [1] 147:12 investigating [1] 148:13 Investigations [1] 149:17 invite [1] 42:14 invited [1] 81:21 involved [26] 16:5, 12; 23:14; 37:12, 18; 52:13; 73:10; 81:19, 22; 82:1, 3: 88:17; 91:16; 97:7; 100:12, 13, 15, 18, 20; 101:3, 4; 140:13; 145:8; 157:17; 172:10 involvement [4] 72:16; 100:10, 17, 19 involving [1] 71:8 irreparability [1] 170:8 Issue [2] 93:20; 98:13 issue [15] 28:22; 31:8, 14; 33:11; 37:11; 62:8; 65:21; 66:8; 71:21; 82:13; 91:17; 106:15, 22; 107:10; 131:17 issued [1] 93:10 Issues [1] 92:18 issues [30] 15:5; 33:2; 40:13: 42:8; 43:1, 4; 45:17, 19; 46:10, 13; 48:13; 50:4; 54:17; 55:12; 60:8; 78:18, 22 ; 80:7, 13; 81:5; 107:21; 121:9; 128:19, 21, 22; 129:12, 19; 130:9, 17; 137:19 It'll [1] 50:22 Item [1] 94:17 item [4] 24:4; 99:3, 7, 9 items [2] 94:13; 174:17 -J - J-e-s-s [1] 45:12 Jack [1] 32:14 James [1] 3:2 Jane [3] 154:16; 155:5, 8 j January [26] 1:20; 7:15; i 9:1, 14; 10:9, 22; 11:3, 20; 13:4, 8, 11, 15; 18:7, 9, 14, 16; 19:1; 22:12, | 17; 77:8, 10; 86:13; 87:10; 108:15; 110:3; I 153:6 Jean [1] 4:3 ' Jefferson [1] 2:8 Jerrv [1] 113:9 Jersey [2] 52:16, 18 Jessee |8] 45:12; 46:5; 93:10; 95:12, 14, 17; 99:4; 123:1 1 j>ggly HI 134:12 i Joan [2] 6:20, 21 i job [9] 28:8; 32:12; 35:13; 41:21; 49:13; 51:10; 79:3; 116:22; 133:1 John [3] 25:13; 39:12; ! 52:13 JOHNSON [2] 6:21; 7:1 Johnson [2] 3:11; 67:16 I joined [1] 25:3 ! Jordan [1] 1:20 . journals [1] 49:16 ' JRA [16] 101:19, 21; 102:1, 6, 15, 18; 103:4, 8, 22; 104:6, 18; 105:3, 6; 127:13, 16; 128:3 judgment [1] 169:19 Julv [6] 92:17; 138:4; 139:1. 6, 7; 140:1 junior [l] 51:11 jurisdiction [4] 117:11; 137:6; 148:16; 149:1 -K- K-e-a-r-n-y [1] 52:16 K-e-a-t-i-n-g [1] 47:13 : K-r-u-m-m-r-i-c-h [1] ! 30:16 Kearnv [1] 52:16 Keating [3] 47:13, 14; 50:11 keep [10] 38:18; 46:21; 47:9; 48:11; 49:1; 78:19; 86:18; 88:4; 130:17; 169:16 keeping [5] 12:20; 47:1, 3; 49:14; 150:2. ' Kept [1] 48:15 i kept [4] 21:12; 27:2; 48:13; 55:11 i kill [5] 167:16; 168:14, i 16; 169:7, 12 " ! kills [1] 169:6 , kinds [5] 45:14; 59:13; ! 147:10, 15; 152:12 ' kitchen [1] 165:15 | knocking [1] 105:16 knowing [8] 60:10; 111:6, 10; 123:4, 7, 12; 125:21; 128:5 knowledge [8] 29:12; 31:12; 46:3; 77:9; 92:8, 10; 148:1; 155:14 knowledgeable [3] 58:12; 78:11; 152:12 Krummrich [10] 29:1, 9, 18; 30:16, 20; 39:12; 52:14; 139:21; 148:13, 22 - L- labeled [1] 35:5 laboratories [1] 115:3 Lack [1] 90:20 lack [13] 90:2; 144:5; 145:20; 148:3; 152:10; 157:15; 161:4; 164:2, 7; 167:11; 168:8; 171:21; 176:15 landfills [3] 122:14; 124:14; 146:7 Lane [3] 155:20, 21; 156:2 Larry [1] 47:12 last [13] 71:6; 72:6; 83:13; 84:17; 103:12; 118:18, 20; 120:6; 139:18; 143:5; 148:12; 155:16; 162:3 lasted [2] 25:20; 26:13 late [9] 30:13; 44:6; 65:13, 14; 66:11, 15, 16; 67:9, 11 lawsuit [1] 6:12 lawyer [1] 43:18 lay [1] 41:16 layers [1] 143:7 leaching [5] 122:16, 18; 123:21; 124:14; 125:9 lead [1] 70:17 leads [1] 130:1 leak [8] 144:10; 162:19, 20; 164:21; 169:20; 170:4, 15, 17 leakage [9] 162:8, 13; 163:19, 22; 166:11; 167:9; 170:2, 13 leaked [3] 168:10; 170:2, 13 Leaking [1] 138:5 leaking [1] 143:20 leaks [15] 162:4, 5, 11, 17, 21; 163:4, 6; 164:14; 165:9, 10, 11; 166:5, 6; 167:1, 2 learn [3] 50:4; 54:1; 78:17 learned [1] 58:18 leaves [1] 165:7 leaving [1] 163:10 Legal [2] 121:5, 7 legal [1] 6:18 letter [2] 62:19; 103:12 level [8] 40:11; 58:11; 71:1, 16; 102:19, 20; 152:8; 167:9 LIBERTY [1] 2:12 Liberty [1] 6:11 lieu [3] 62:10; 118:18; 119:6 lieutenant [1] 43:19 Life [1] 155:6 life [1] 102:17 likelihood [1] 84:10 limit [1] 15:8 limited [3] 54:18; 55:16; 176:10 limousine [1] 12:11 i line [10] 17:1; 41:10, 15, j 18, 22; 134:5, 12; 154:8; 162:5; 167:2 lines [2] 165:10; 166:6 liquid [1] 144:10 list [16] 33:12; 37:13, 16; 62:10, 13; 63:15; 66:10; | 68:15; 74:13; 116:10; 118:19; 119:10, 15; 134:1, 3; 136:5 listed [6] 94:13; 109:1; 111:5; 115:12, 14; 172:14 listing [2] 118:20; 173:20 lists [1] 118:22 literally [1] 97:5 living [1] 155:14 located [9] 23:2; 25:8; 30:14; 31:1; 44 J, 8; 103:16; 122:14; 137:14 location [11] 12:3; 19:2; 71:19; 74:19, 20; 115:4; 148:2; 149:19; 153:13; 175:21; 176:11 locations [8] 123:22; 124:15; 156:9, 11, 13; 160:6; 173:12; 176:11 LONDON [2] 4:1, 2 look-see [1] 85:15 looks [3] 76:12; 113:9; 161:6 lost [3] 19:13; 20:7; 30:10 lot [9] 49:15; 57:20, 22; 144:14; 145:7, 19; 157:20; 159:8; 163:2 lots [1] 110:14 Louis [19] 1:19; 17:3; 20:20; 23:3, 8; 25:8; 29:9; 30:22; 31:6, 7; 32:2; 44:2, 8; 67:9; 72:2; 74:18; 80:21; 96:2; 171:11 low [1] 132:20 lower [1] 143:8 lower-level [1] 51:10 lunch [1] 59:16 Luncheon [1] 61:17 -M- m-a-l-e-i-c [1] 34:8 M-a-l-l-o-c-h [1] 46:12 magnitude [1] 162:11 mail [6] 111:7; 112:1, 16, 20; 153:15; 171:12 mailbox [1] 74:18 mailed [3] 110:15, 17; 111:1 mailing [2] 109:21; 112:17 Maintain [1] 76:13 maintain [3] 76:14; 86:15, 17 maintained [1] 87:2 maintaining [1] 86:12 Maintenance [2] 26:15; 27:4 maintenance [3] 27:6, 19; 28:6 Mqjor [1] 137:5 mqjor [8] 65:21; 80:6; 81:5; 167:7; 173:13; 176:4, 8, 10 majority [2] 111:15; 150:11 maleic [1] 34:8 Malloch [1] 46:12 man [3] 57:18; 117:8; 118:7 Management [1] 123:19 management [17] 15:8, 17; 36:14; 45:14; 64:20; 69:6; 76:5; 88:19; 108:8, ! 16, 19; 114:5; 117:18; i 126:18; 148:6; 160:1 i Manager [21] 31:7, 10, 18; 32:1; 33:1, 5. 10, 15, 20; 36:14, 18; 37:9; 47:15, 20; 50:21; 51:5, 6, 8, 9, 11; 87:14 manager [25] 31:3, 4; 47:16; 54:11; 55:21; 56:13, 14; 58:5, 10; 76:22; 77:1, 3, 4; 82:22; 83:4; 95:9; 96:10; 97:9; 117:19, 20, 21, 22; 118:4; 136:12; 169:20 managers [6] 99:8; 101:13, 14; 130:2; 169:13 manner [1] 70:4 MANTA [185] 6:7; 7:4; 10:9, 12; 11:12; 12:4, 13, 22; 13:2; 15:6, 12, 16, 22; 18:8, 11; 19:18; 20:11; 22:10; 29:11; 30:1; 38:3, 17, 22; 39:2, 16, 21; 41:3, 13; 43:11; 44:5, 10; 45:2, 7; 46:4; 48:3; 49:6; 51:15, 18, 21; 52:6; 59:6; 60:6; 61:16, 19,22; 62:2, 5; 63 JO; 64:13; 65:3, 6, 22; 66:5; 68:22; 69:2, 6, 16; 70:18; 72:6, 12, 13, 14; 73:7; 74:3, 7; 78:1; 79:16, 20; 80:11, 19; 81:16; 82:2, 10; 83:6, 9, 19; 84:2; 90:7, 11; 91:4, 17, 19; 92:6, 14; 95:11; 96:16; 97:1, 10, 14, 16; 98:10; 99:19; 103:7, 20; 104:10, 15; 105:2; 106:8, 13; 107:7; 108:13; 109:15; 110:11; 112:14; 115:16; 116:15, 19; 119:1, 18; 120:8, 12; 121:16, 19, 22; 122:6; 124:21; 125:7, 16; 127:1; 128:1; 129:10, 18; 130:15; 131:13; 132:7; 133:6, 9, 16, 18; 134:21; 136:18; 138:2; 139:11, 14; 140:10, 17; 142:13, 15, 17; 143:1, 3. 13, 18; 144:1, 18; 145:3; 146:17; 149:15; 150:17; 152:18; 153:4; 154:6, 21; 155:6, 7; 159:18, 22; 160:5, 12, 22; 161:12; 163:16, 21; 164:4, 13; 165:1, 8, 18; 166:3, 14; 167:8; 168:1, 15; 169:3, 22; 170:10, 18; 171:2; 172:12; 173:4; 174:4; 176:12, 17; 177:4, 13 Manta [9] 2:13, 14; 6:10, 11; 62:14; 63:3; 67:15; 119:5, 10 Manufacturing [1] 87:14 manufacturing [16] 30:18; 114:13; 115:2; 141:13, 17, 21; 142:3, 7; 144:21; 165:15; 173:15, 17; 174:7, 16, 18; 175:16 map [1] 142:14 March [2] 127:4; 171:4 Maritz [1] 8:18 Mark [4] 1:18; 2:13; 6:10; 139:10 marked [25] 39:17, 22; 71:13; 74:4; 83:7; 92:12, 16; 99:17; 108:11, 14; 113:22; 126:20; 127:2; 133:7, 10; 136:16, 19; informing to marked WATER PCB-SD0000068700 BSA Depo of: WILLIAM PAPAGEORGE Monsanto v Aetna January 13. 1993 CR: 54034.0 137:22; 138:3; 153:1, 5; 160:9, 13; 170:22; 171:3 Massachusetts [1] 52:17 Master [6] 19:20; 23:4, 6; 91:7, 10; 164:6 material [19] 26:5, 7; 28:17; 64:7; 105:20; 106:10; 107:1, 8; 145:8; 151:5; 158:15, 16, 20; 163:1, 10; 164:20; 165:7; 169:16; 174:1 materials [19] 24:1, 13, 18; 35:3; 47:5, 6; 63:1; 119:16; 120:6; 144:10; 147:11; 148:9; 157:17, 18; 158:6, 12; 159:9 matter [9] 21:10, 11; 38:17; 47:8; 50:3; 81:10, 22; 131:5; 165:6 matters [12] 15:15, 16; 40:12; 42:6; 46:22; 47:17; 49:20; 53:21; 80:17; 84:20; 98:5; 152:12 MCA [1] 40:2 McCauley [3] 56:11; 57:2; 60:12 MCI [34] 39:9; 46:19; 48:10, 14, 18; 55:10, 19; 56:15; 59:9; 73:20; 76:9, 16; 78:7, 15; 84:6, 8, 9; 88:1; 93:8; 97:12; 115:18; 122:22; 128:12; 133:2; 137:5, 7, 8; 141:1, 2; 145:5; 146:19; 147:22; 148:6, 17 MCO [5] 134:1; 136:21; 153:7, 8 mean [29] 10:13; 29:12; 30:22; 35:10; 44:14; 49:4; 51:15; 57:12; 71:15; 73:4; 78:5, 8, 10; 89:2; 100:14; 101:14; 105:15, 18; 109:16; 112:13; 117:15; 118:6; 129:14; 130:7; 150:9; 153:14; 155:11; 165:21; 176:18 meaningful [1] 90:6 means [7] 35:11; 38:8; 51:11; 96:21; 124:22; 153:12; 154:8 meant [1] 133:16 meantime [1] 50:8 measure [2] 111:21; 132:1 measuring [1] 102:3 mechanism [1] 102:14 meddle [1] 82:21 meddling [1] 83:1 Medical [1] 43:18 meet [5] 22:19; 57:16; 75:17; 175:3, 19 meeting [4] 35:3; 43:9, 10, 15 meetings [13] 22:16; 42:13, 17, 20; 43:1, 7; 44:12; 49:18, 19; 53:20; 55:14 member [8] 46:20; 48:10, 17; 51:11; 94:2; 116:1; 11.7:5; 136:13 Members [1] 43:18 members [6] 43:12, 14; 45:6, 18; 47:7; 81:8 memo [2] 138:16; 153:16 memorandum [12] 74:10; 92:17; 99:21; 133:12; 134:2; 135:1; 138:19; 139:4; 143:17; 153:8, 10; 177:5 memory [5] 79:12; 95:1; 100:16; 10712; 111:12 mention [1] 8:7 mentioned [18] 8:17; 12:9; 17:4, 5, 20; 26:2; 34:7, 21; 48:16; 55:11; 60:22 ; 82:4; 100:20; 153:20; 161:3; 168:14; 170:9; 175:14 metal-containing [1] 158:16 MIC [3] 52:5; 54:6; 55:10 Michael [1] 51:4 microfilm [5] 86:6; 95:6; 137:12; 139:11; 143:22 mid [3] 13:4, 7; 51:3 middle [3] 6:15; 84:16; 169:9 Mike [3] 45:15; 47:13, 19 miles [1] 96:2 mind [14] 6:3; 7:20; 10:19; 17:18; 18:2, 16, 18; 35:9; 39:10; 48:15; 75:9; 82:9; 151:7; 177:12 mine [1] 28:1 minor [1] 26:17 minute [1] 39:19 minutes [1] 7:8 mischaracterizes [2] 11:9, 22 misjudging [1] 160:3 mislead [1] 36:2 Miss [4] 7:5; 8:22; 57:2; 60:12 missed [1] 33:4 missing [1] 114:22 Missouri [2] 1:19; 20:20 misspoke [1] 88:9 mistakenly [1] 138:16 misunderstanding [1] 174:9 misunderstood [1] 32:1 mix-up [1] 70:7 Mm-hmm [2] 76:11; 84:14 mm-hmm [1] 152:3 moment [8] 40:3; 45:20; 79:11; 83:12; 94:16; 100:8; 134:17; 138:6 moments [1] 121:15 Monday [2] 8:22; 62:13 money [1] 82:18 monitor [9] 79:4; 81:14; 98:21; 104:18; 122:15, 18; 123:21; 124:13; 125:9 monitored [5] 85:4, 8; 89:20; 94:19; 151:11 monitoring [11] 85:11, 14; 124:10, 13; 125:1, 11; 135:7, 11; 151:19, 21; 152:2 MONSANTO [2] 1:4; 2:3 Monsanto [146] 6:12, 18; 8:15, 19, 21; 9:15, 16, 19; 10:3, 4, 5, 22; 11:7; 12:16, 17; 13:5, 8, 13; 14:6; 19:12; 20:6, 12; 25:3. 5, 8; 28:16; 30:14, 15; 31:3, 5, 7, 20; 33:8, 20; 34:5; 37:7, 8; 38:1; 39:4. 6, 8; 40:10, 13; 41:9: 43:21; 44:8; 46:1: 47:2; 49:21; 51:16, 18, 22; 52:2, 4; 54:14; 55:8: 63:14; 64:1, 22; 65:13; 66:11; 67:4, 9, 12; 68:7. 14, 15; 69:3; 70:5, 12; 71:4; 72:16; 73:1, 3; 81:15; 85:22; 86:22; 88:15; 91:5; 92:18; 94:19; 97:9; 98:16; 102:2, 17, 21; 103:5, 9, 12, 16; 104:1; 105:4; 108:7, 9, 19; 111:19; 112:9, 15, 20; 114:5, 12; 117:18; 121:5, 7; 123:5, 8, 11. 19, 22; 124:14; 126:7, 8, 17; 127:15; 128:20; 130:8; 131:17; 136:13; 141:14; 142:5, 11; 144:19; 147:18; 148:2, 6, 10; 149:18; 150:7; 152:7, 11; 153:17; 154:1; 155:13; 156:5, 7, 11, 13; 161:18, 20; 163:9, 14; 165:12; 169:2; 171:19; 174:5; 176:5 Monsanto-conducted [1] 49:19 Monsanto-monitored [1] 96:5 Monte [1] 40:16 month [1] 42:21 monthly [2] 43:7 months [3] 50:17; 58:14; 161:8 mopped [1] 166:12 morning [5] 6:8, 9; 19:5; 22:20; 67:7 motivated [1] 173:9 move [3] 29:6; 82:19; 144:10 MS [1] 5:3 Ms [8] 4:3; 7:6; 11:17; 60:22 ; 61:1, 2; 126:22; 155:10 MST [1] 137:12 Muscatine [1] 139:20 MUTUAL [1] 2:12 Mutual [1] 6:11 myself [4] 67:16; 90:4; 125:14; 161:21 -N- N.W. [2] 2:8; 3:13 name [19] 6:10, 20; 45:1, 4, 12, 20; 50:22; 56:1, 4; 74:15; 109:3; 127:9; 134:5, 11; 153:9; 154:8, 10; 156:8; 171:8 names [6] 34:10; 44:19, 20, 21; 109:1; 136:5 Naturally [1] 1523 nature [1] 152:4 necessitated [1] 72:2 needn't [1] 119:8 needs [12] 27:14, 17; 68:15; 116:2; 117:21; 124:10, 19; 125:1, 5, 10; 129:16 newly-informed [1] 54:14 nights [1] 17:5 nineteen [2] 37:7; 57:4 nitro [1] 26:10 nitty-gritty [1] 79:5 non-Monsanto [2] 126:11, 12 nonetheless [1] 53:16 nonhazardous [1] 176:2 noon [2] 38:15, 22 normal [4] 111:18; 112:8. 11; 176:5 normally [5] 138:10; 162:9, 13; 163:19; 164:1 North [11] 107:4, 5, 14, 19, 22; 125:18; 126:5; 140:12; 141:10; 142:2, 19 north [1] 153:15 notary [1] 121 note [5] 19:19; 138:20; 173:20; 174:13; 176:9 noted [6] 19:20; 120:13; 167:16, 17, 20, 21 notice [5] 35:8; 67:4, 11; 78:21; 155:18 noticed [1] 38:3 Number [6] 95:2, 9, 19; 96:7; 98:12; 133:14 number [27] 21:9, 12; 34:11; 40:2; 48:19; 65:5, 6; 68:16, 17; 83:11; 86:6; 92:18; 95:6; 98:11; 99:21; 103:15; 133:22; 136:21; 137:12, 13; 143:22; 144:20; 153:7; 160:5, 16; 164:8; 171:5 Numbered [1] 122:10 numbered [2] 76:13; 122:11 numbers [3] 74:11; 108:17; 127:5 numeral [3] 93:14; 94:14; 138:22 Nussbaum [1] 4:4 nylon [1] 89:10 -O- oath [1] 6:5 object [2] 22:7; 91:4 objected [1] 59:20 Objection [43] 11:9, 22; 19:15; 46:2; 49:3; 59:5; 73:2; 77:20; 80:8; 81:7, 20; 82:6; 90:2; 96:15, 19; 97:21; 104:7; 109:13, 20; 110:6; 115:10; 124:16; 127:18; 129:1; 130:10; 131:10, 18; 132:11; 144:5; 148:3; 149:13; 150:8; 152:10; 153:21; 157:15; 161:4, 19; 162:16; 167:11; 168:8; 171:21; 175:11; 176:15 objection [14] 15:18; 63:17; 64:21; 104:12, 21; 120:10; 129:13; 158:2, 10; 164:2; 168:18; 172:8, 21; 177:1 objections [32] 12:7; 19:20, 22; 20:9; 60:3; 65:18; 80:15; 90:10, 20; 91:5, 7, 8, 11, 13, 15; 92:1; 125:2, 13; 144:13; 145:1; 146:10; 164:7, 16; 165:5, 13; 166:1, 9; 167:5; 170:5; 173:18; 175:11; 176:7 objective [6] 70:16; 75:17; 163:12, 13, 14; 164:21 objectives [5] 42:2; 102:3, 4; 114:15; 156:14 observations [1] 50:10 Obviously [1] 103:10 obviously [1] 108:1 occasion [5] 32:17; 43:14; 53:21; 86:3; 164:19 occasional [2] 167:7; 168:11 occasions [2] 42:8, 14 occur [8] 69:10; 71:8; 165:2, 3, 6, 11; 170:3, 14 occurred [8] 61:10; 66:21; 78:21; 139:20; 140:1, 6; 165:19; 167:15 October [1] 160:14 offer [3] 64:16, 17; 65:7 office [12] 30:22; 31:1; 62:14, 16, 18, 19; 74:19; / Look-See(35) 83:1; 119:17; 120:7; 153:130171:11 offices/[3] 31:5, 7; 44:9 \ official [2] 47:18; 54:12 ) Oh [23] 8:22; 9:11; 103( 26-3; 31-32; 58:9; 60:18, 21; 61:9; 62:1; 77:4; 92:10; 100:14; 112121; 120:19; 132:12; 133:4; 141:11; 155:2; 157:16; 160:21; 162:15; 170:7 Ohio [1] 52:19 oil [4] 23:14, 15; 24:4; 163:2 oily [1] 166:17 Okay [61] 7:2, 21; 8:9; 9:3, 12, 14; 10:16; 11:3, 13; 12:5, 18; 13:1, 16; 14:12; 15:6, 14, 19, 20; 18:19; 20:18; 26:3; 29:19; 35:15; 39:3, 11; 40:21; 43:4; 48:4; 49:12; 55:17; 57:11; 59:18; 61:16; 62:3; 63:20; 69:5, 22; 70:18; 72.1 J. fi/l.J 20; 86:5; 88:9; 94:9; 96:9; 98:11; 102:12; 104:19; 105:22; 107:21; 119:12; 134:17; 143:4; 145:21; 146:2; 148:19, 22; 153:12; 157:9; 159:18; 170:19 okay [4] 17:22; 51:2; 77:4; 84:15 Oklahoma [1] 23:10 Old [1] 3:4 old-timer [3] 59:2, 3; 60:1 on-site [2] 30:6; 98:21 one-man [1] 32:4 one-on-one [1] 59:16 ones [2] 79:15; 123:8 ongoing [1] 128:15 oozing [1] 166:11 open [6] 7:19; 11:8; 18:17; 42:11; 43:20; 98:6 opened [1] 111:9 opening [1] 61:10 operated [2] 115:5; 126:8 operating [20] 30:12, 18; 37:8; 38:1; 39:5; 41:6, 10; 42:1; 46:21; 84:21; 130:17; 147:10; 162:14, 22; 163:20; 164:1; 165 -3; 166:7; 167:4; 173:22 operation [7] 89:12; 165:20, 21; 167:4; 168:3, 5; 175:9 Operational [1] 143:6 operational [4] 48:11, 18, 19; 144:3 Operations [46] 38:1; 39:4; 40:17; 41:6, 8; 43:13, 15; 46:19; 48:5; 52:4; 53:4; 54:6; 55:10, 19; 56:15; 59:9; 73:20; 76:9, 16; 78:7, 15; 84:6, 9; 85:2; 88:1; 90:12; 93:8; 94:6; 95:17; 97:12; 98:3, 16; 115:18; 122:22; 128:11; 133:2; 137:7; 138:12; 141:1; 145:4; 146:19; 147:22; 148:17; 155:1; 159:16; 176:19 operations [13] 40:14; 42:15; 43:2; 76:3; 81:1; 84:8, 21; 85:8; 90:14; 92:9; 114:13; 174:13; 176:5 opinion [13] 80:8; 90-3, 21; 91:12, 20; 92:2; 95:8; From Massachusetts to opinion WATER PCB-SD0000068701 BSA Depo of: WILLIAM PAPAGEORGE Monsanto v Aetna January 13, 1993 CR: 54034,0 115:10; 124:4, 16; 127:18; i [1] 26:11 140:6; 144:13 ' paraphrasing [1] 78:16 opportunity [4] 63:10; ' parentheses [2] 146:6, 7 66:12; 72:4; 100:21 I Park [1] 154:11 opposition [2] 71:1, 16 j part [33] 11:11, 13; order [14] 15:8, 17; I 23:18; 24:9; 45:9; 49:10, 19:22; 20:13; 64:20; 69:7; j 13; 71:10, 19; 72:20; 75:16; 91:8, 9; 160:1; | 78:6, 14; 80:18; 85:11; 164:6, 10; 173:14 86:22; 102:3; 106:17; organic [8] 157:1, 3, 4, 107:6, 15; 124:8; 128:3; 10, 22; 158:4; 159:2, 4 131:16; 133:1; 135:18; organization [6] 41:5; 138:15; 141:15; 142:11; 98:1; 117:8, 22; 151:13 143:18; 153:19; 157:10; original [2] 24:15; 138:15 158:17; 159:10; 169:20 originally [2] 27:5; 71:20 part-dme [1] 32:11 originator [1] 113:1 participate [1] 81:21 Orrick [2] 3:3; 118:20 participated [3] 111:3; ortho [1] 26:10 115:21, 22 ought [1] 99:5 participation [1] 59:14 ours [1] 99:5 parts [3] 26:6; 86:4 outline [3] 84:4; 95:4; party [2] 17:1, 2 137:10 passed [1] 47:9 outside [4] 77:18, 21; pattern [1] 120:4 136:2; 140:13 pause [1] 121:15 overall [1] 40:11 pay [3] 10:2; 19:13; 20:7 overhead [1] 95:4 PCB [5] 21:21; 33:6, 11; owned [3] 115:4, 5; 36:19; 121:9 126:8 PCBs [4] 21:21; 31:14; -P- 32:19; 33:2 Pebble [1] 20:20 p-h-t-h-a-l-i-c [l] 25:14 P-i-e-r-l-e [2] 45:15; 47:13 p.ra. [2] 61:17; 177:17 packaged [1] 35:5 PAGE [1] 5:2 Page [5] 93:17; 124:7; 162:2; 175:17; 176:1 page [45] 72:7, 9; 76:12; 83:17; 84:12; 86:5; 93:13, 16; 98:11; 100:1; 108:22; 113:3, 12, 16, 18, 21; 122:8, 10, 11, 20, 22; 123:15, 16; 134:15; 137:4, 12; 138:20; 139:9; 143:4, 5, 11, 14, 15; 144:8; 149:16; 154:7; 155:16, 17, 18; 162:1; 173:11; 174:10 pages [11] 64:10, 11, 14, 16; 65:7; 66:9, 13; 83:13; 138:14; 143:10, 13 paint [1] 24:17 PAPAGEORGE [2] 1:17; 6:2 Papageorge [62] 5:8, 9, 10. 11, 12, 13, 14, 15, 16, 17, 18, 19, 20; 6:8; 20:18; 39:17; 40:1; 62:11; 64:5; 67:3, 12; 68:18; 72:15; 74:4, 9, 14, 16; 83:7, 10; 84:6; 91:20; 92:12, 15, 16; 99:17; 103:8, 21; 106:7; 108:11; 109:2; 120:13; 121:19; 122:7; 126:20; 127:3, 8: 133:7, 11, 20; 134:3, 4; 136:16, 19; 137:22; 153:1, 9; 154:10; 160:9, 13; 170:22; 171:4, 6 paper [1] 172;10 paragraph [14] 75:3; 84:17; 101:16; 113:19; 115:1; 124:2; 125:8; 127:10; 139:18; 149:12; 155:16; 162:3; 171:14; 173:11 paragraphs [1] 100:9 paralegal [1] 9:15 paranitrochlorobenzene pending [1] 150:12 Pennsylvania [1] 2:16 pentachlorophenol [1] 34:9 People [3] 44:19, 20, 21 people [26] 16:5; 27:19; 31:20; 36:17; 42:21; 43:10; 48:20; 50:1; 58:2; 80:21; 81:12; 95:22; 102:6, 20; 104:17; 108:6; 117:2; 118:1; 123:8; 134:1; 135:19; 136:6, 9, 15; 150:15; 151:2 perceive [1] 89:11 perceived [11] 42:11; 94:11; 98:3; 102:5; 116:22; 117:4, 18; 141:15; 169:12; 173:2, 8 perfected [1] 164:18 perfectly [1] 72:8 : performance [3] 41:19; j 42:2; 175:18 j performing [1] 24:9 j period [8] 19:7; 37:19; 57:4; 82:16; 130:4; 140:18; 148:7, 8 periphery [1] 122:14 ! Perk [6] 6:21, 22; 7:5, 6; 8:22; 11:17 permission [1] 63:12 permit [2] 70:15; 163:11 permitted [9] 15:7, 16; 20:1; 49:19; 50:6; 63:16; I 91:12; 125:22; 174:2 j permitting [1] 43:22 I person [10] 6:19; 13:16; ! 33:18; 41:4, 20; 58:4; | 73:22; 118:9; 146:13; ! 149:10 j personal [7] 17:19, 22; 38:5; 50:7; 92:2; 103:21; I 144:6 personally [12] 10:17; 17:21; 19:6; 76:17; 82:12; 115:22; 120:21; 130:11; 145:20; 146:13; 157:7; 159:14 i Personnel [1] 51:12 personnel [4] 44:11; j 55:14, 16; 151:1 I persons [2] 58:2; 73:22 i peruse [1] 78:11 i peruses [9] 83:22; 92:22; i 95:7; 114:2; 134:19; ' 138:8; 153:3; 160:11; i 171:16 petrochemical [5] 157:7, 9, 13; 158:8; 168:3 petrochemicals [1] 157:21 Petroleum [3] 23:9, 11; 25:1 petroleum [4] 24:11, 12, 14, 16 phenol [1] 34:8 Philadelphia [1] 2:16 Phillips [7] 23:9, 11, 16, 18, 22; 24:9; 25:1 phosphorus-containing [1] 158:15 phrase [1] 176:10 phthalic [2] 25:14; 34:7 Pickard [1] 154:11 picked [3] 52:15; 105:8; 166:18 picking [1] 28:13 pickup [2] 28:15; 30J picture [1] 79:10 Pierle [18] 45:15; 46:11; 47:13, 19, 20; 50:11, 15; 75:8; 77:2; 108:6; 127:19, 20; 139:1; 143:17; 149:4, 6, 14 pinpoint [1] 34:4 pipeline [3] 26:18; 27:15; 162:18 pipelines [1] 164:17 pit [1] 155:20 place [21] 9:10, 21; 11:21; 14:9, 16; 16:18; 18:20; 47:21; 61:8, 10; 75:16; 84:1; 102:2; 120:18, 19; 121:9; 141:13; 163:4, 6; 170:4, 15 placed [1] 169:14 places [1] 169:2 PLAINTIFF [1] 2:3 Plaintiff [1] 1:6 plan [1] 91:1 planning [2] 68:8; 129:8 plans [1] 175:2 Plant [60] 25:9, 13; : 26:15; 27:8; 28:21; 29:18; : 30:4, 7, 16, 20; 39:12, 13, 14; 52:13, 14, 15, 16, I 17; 53:4, 11, 14, 17; I 54:21; 55:13, 19; 60:8, 1 20; 61:13; 76:13; 77:10; I 79:8; 89:1; 90:13, 15, 18; 91:21; 93:14; 98:17; 101:15; 105:10; 106:3, 16; 107:17; 128:12; 132:9, 17; 135:15, 20; 137:20; 141:5; 145:5; 149:17; I 155:19; 156:16, 22; j 159:13 j plant [151] 25:7, 11, 12, I 13, 18; 26:17; 27:6, 10, | 21; 28:17; 29:16; 30:14, 19; 31:2, 3, 4; 44:11; | 50:5; 52:7, 17, 18; 55:5, 1 13, 14, 16, 21; 56:13, 14; ' 57:16, 20, 21; 58:5, 10, i 12, 19, 22; 75:5, 12, 19; I 76:3, 7, 14, 21, 22; 77:3, i 18; 78:2, ! 8, 22; 79:3; 80:4, 18, 20, | 22; 81:3, 13; 82:17, 21, i 22; 83:4; 85:11, 13, 17, ; 21; 86:10, 18; 87:1; 88:6, 18, 19; 89:6, 7, 9, 10; 92:3, 7, 8; 95:9; 96:9; 97:9; 98:4; 99:8, 12, 13, 15; 101:14; 102:19, 20, , 22; 106:19; 107:6, 17; ! 117:8, 18, 20, 21, 22; | 118:3; 129:9; j 130:2; 131:14, 20; 133:3; ! 136:3, 12; 141:9, 12, 14, 15, 21; 142:1, 3, 11; 145:12; 148:20, 21; 150:5, 15; 151:1; 154:4, 5; 157:1, 8, 9, 13; 158:9, 15; 162:6, 9, 14; 163:20; 164:1; 165:4, 20, 21; 166:5, 7, 16, 17; 167:3; 168:3, 21; 173:21; 175:1, 10, 22 plant-wide [1] 75:19 plants [40] 39:8; 47:5, 9; 48:14; 49:20; 50:7; 52:10, 12; 53:4; 54:2; 55:12; 78:18; 85:5, 9; 87:14; 88:1; 89:5; 90:13; 97:9; 98:5; 101:5, 7, 9; 116:2; 117:11; 137:5; 139:21; 141:3; 147:18; 148:12, 15, 19; 149:1; 150:1, 11, 14, 18 plasticizers [1] 25:19 play [1] 13:21 played [1] 98:9 Please [1] 112:5 please [4] 38:6; 113:20; 163:17; 171:15 point [30] 16:22; 17:14; 19:12; 20:6; 29:19; 31:15; 32:15, 16, 20, 21; 33:16, 21; 46:16; 51:14; 52:8; 57:16; 58:13, 15; 59:15; 67:1; 72:10; 75:14; 85:14; 111:6; 114:8; 145:18; 148:5; 150:20; 164:19; 169:18 policies [3] 81:15; 85:20; 86:1 Policy [1] 73:9 policy [12] 40:8, 22; 42:2, 17; 44:16; 45:21; 46:16; 84:18; 85:2, 3; 87:8; 94:3 politically [1] 173:9 pollutants [2] 135:6, 10 pollution [1] 45:19 polychlorinated [4] 21:12; 31:9; 32:8; 37:10 portion [3] 62:22; 134:15; 172:1 portions [1] 65:11 pose [1] 158:11 position [36] 13:22; 24:19, 21; 25:16; 28:2; 30:9; 37:21; 39:3; 40:4; 48:5, 17, 19; 51:11; 54:4, 5; 55:9; 59:10; 60:9; 62:6; 67:11, 22; 68:1; 69:20; 75:14; 87:22; 90:5; 92:4; 98:2; 104:17; 112:17; 118:3, 5, 10; 119:7; 138:11; 164:11 positions [5] 25:5; 29:13; 36:15; 84:19; 85:10 positive [1] 20:17 possess [1] 146:14 possession [1] 103:22 possibility [1] 18:5 potential [9] 47:4; 111:5; 114:11; 115:6; 130:21; 131:15; 148:1; 150:4; 166:6 _________ Look-See(36) practical [3] 41:14; 170:3, 14 Practice [2] 94:18; 95:19 practice [3] 78:6; 134:4, 8 practices [4] 123:5; 143:6; 144:3; 146:6 predecessor [1] 56:3 predominantly [1] 21:11 prefer [1] 15:17 premise [1] 70:11 prepare [1] 100:4 prepared [12] 63:7, 18; 66:2; 68:19; 69:3; 72:19; 73:5; 91:15; 111:4, 18, 22; 112:8 preparing [2] 100:6; 102:6 presence [2] 105:21; 106:11 present [8] 25:5; 107:1, 8; 114:12, 15; 130:3; 149:18; 151:6 presentation [5] 84:5, 7; 95:5; 136:10; 137:10 presentations [1] 137:15 presented [2] 67:19; 135:14 pressure [3] 24:14; 150:14, 19 pressures [1] 98:4 presumably [1] 134:2 presuming [1] 118:17 presumption [1] 159:10 pretty [2] 73:17; 112:3 prevent [4] 70:16; 167:22; 169:13, 20 previous [1] 146:11 previously [1] 37:12 primarily [7] 26:7; 35:20; 45:17; 55:4; 79:3; 97:17, 22 Prime [1] 94:9 prime [10] 94:13, 21; 95:8, 13, 18; 96:13; 98:22; 99:2, 6; 146:8 Prior [2] 16:13; 22:2 prior [12] 12:1; 16:13; 20:18; 21:15; 110:7; 171:20; 172:3, 6, 7; 174:6; 175:5, 8 private [1] 53:20 privilege [1] 20:1 privileged [2] 15:3; 72:18 privileges [1] 22:8 probability [1] 111:22 problem [9] 48:16; 65:20; 81:18; 96:20; 105:13; 117:6; 118:12; 141:20; 166:20 problem-solving [1] 81:17 problematic [2] 161:18, 21 problems [14] 19:6; 20:13; 21:17; 45:14; 105:9, 14, 19; 106:1, 2; 107:13, 18; 112:19; 114:11; 169:21 procedure [1] 71:10 procedures [1] 172:2 proceed [1] 69:18 proceeding [1] 120:11 process [5] 34:6; 80:18; 118:12; 158:16; 162:4 processed [1] 24:14 processes [2] 157:16; 158:12 produce [1] 24:11 produced [5] 25:11; opportunity to produced WATER PCB-SD0000068702 BSA 65:15; 71:9; 103:18; 157:18 producing [2] 23:17; 142:9 Product [6] 33:10; 36:14, 18; 37:9; 50:21; 93:14 product [8] 22:8; 25:10, 12, 14; 35:13; 49:9; 93:11; 115:2 Production [1] 27:13 production [4] 28:6, 9; 65:14; 103:13 products [17] 33:8, 12, 20; 34:1, 2; 35:6; 36:13, 20; 37:12, 13; 40:13; 47:2, 6; 156:18; 157:18 Professional [1] 2:6 professional [2] 70:4; 132:22 Program [2] 138:22; 139:3 program [34] 74:1; 75:21; 76:1, 10; 101:18; 102:2, 16; 124:4; 125:21; 126:1, 2, 4, 5, 8, 13, 14; 131:7, 17; 135:7, 11; 149:21; 150:6; 151:8, 9, 17; 153:18, 20, 22; 156:7, 8; 161:2, 7; 173:12; 176:3 programs [4] 124:8; 125:5; 127:11; 151:10 progress [3] 101:10; 102:4; 160:3 prohibited [1] 91:7 project [3] 116:12, 14, 18 projects [3] 26:17, 20; 27:5 promises [1] 68:7 promulgate [1] 129:7 promulgated [1] 74:1 promulgation [7] 171:20; 172:3, 15; 174:6, 14, 22; 175:22 proper [3] 81:9; 168:21; 173:21 properly [8] 35:4, 5, 20; 81:13; 116:22; 166:19; 174:1, 17 property [9] 99:12; 106:19; 115:6; 126:7, 11. 12; 142:5; 154:4, 5 proposal [2] 72:6; 127:14 proposals [1] 50:10 proposed [1] 69:17 protect [2] 173:14; 174:6 Protection [20] 33:6, 15, 21; 35:9; 36:11; 47:20; 51:5, 6, 8, 9; 74:11; 87:1; 98:12; 100:11; 101:21; 102:10; 124:9; 126:5, 15; 127:16 protection [1] 35:10 provide [4] 13:5, 9; 126:8; 153:22 provided [3] 28:13; 30:12; 79:17 providing [1] 28:9 provision [1] 69:1 public [10] 1:21; 43:16; 130:6, 11, 12; 139:19; 140:1, 6; 141:4; 142:20 pull [1] 66:12 pump [3] 26:18; 27:16; 165:9 pumps [1] 162:22 Purdue [1] 149:9 purpose [6] 73:14: 79:21; 105:17; 114:10, 17; 172:18 purposes [2] 28:20; Depo of: WILLIAM PAPAGEORGE Monsanto r Aetna January 13, 1993 CR: 54034.0 102:15 Putting [2] 111:17; 112:7 putting [4] 26:18; 61:19; 105:22; 169:15 puzzled [1] 141:7 -Q- qualified [1] 132:22 Qualify [1] 175:18 quantities [1] 151:6 quantity [1] 71:9 Queeny [6] 25:13; 28:21; 30:3, 7; 39:12; 52:13 question [48] 9:13; 13:21; 14:2; 15:1, 20, 21; 20:4; 49:12; 59:19, 20; 67:19; 72:3; 80:9; 85:1; 88:10; 90:17; 95:16; 97:3, 13; 109:10; 112:2, 3; 113:14; 118:16; 121:1; 122:17; 123:2, 4; 127:21; 140:5; 141:7, 17, 18; 142:18; 144:2; 148:4; 149:19; 155:4; 160:19; 163:16; 164:14; 168:2, 9; 170:1, 6, 10, 12; 173:19 questioning [1] 15:7 QUESTIONS [1] 6:7 questions [11] 14:11; 15:18; 28:19, 21; 29:2; 72:5; 82:5, 8; 105:22; 134:18; 135:5 quick [1] 38:3 quickly [1] 166:18 quote [3] 84:18; 101:17; 124:7 - R- rainfall [1] 143:8 raise [3] 15:18; 118:16; 119:14 Raised [1] 82:8 raised [5] 20:10; 43:1; 82:5, 13; 135:5 rats [1] 133:5 raw [1] 47:5 Ray [1] 56:9 RCRA [18] 45:13, 22; 171:20, 22; 172:3, 7, 10, 14, 20; 173:2, 6, 7, 21; 174:6, 14, 18; 175:8, 22 reach [2] 144:6; 147:14 read [20] 20:4; 59:21; 73:16; 83:17; 84:16; 94:15; 100:8; 112:4; 113:19; 114:3; 133:22; 134:17, 20; 161:10, 11; 163:16; 170:10; 171:15, 17, 22 Reading [2] 79:13; 123:3 reading [5] 49:15; 79:14; 105:1; 111:9; 125:8 reads [9] 101:17; 124:7; 139:19; 143:5; 144:19; 147:17; 148:12; 162:4; 174:21 real [4] 165:14; 167:3; 168:2, 5 realistic [1] 96:3 reason [20] 35:12; 64:5; 65:1; 66:20; 68:7; 70:1; 71:12; 100:3, 5; 104:19, 22; 109:4, 11, 18; 110:4, 8, 9, 19; 111:4; 119:14 reasonable [3] 123:20; 125:11; 132:5 reasons [2] 16:6; 119:8 recall [85] 9:18; 13:15; 16:3, 6, 21; 17:11, 17; 19:3; 25:19; 27:1; 28:3; 32:9; 33:8; 37:6, 13, 18; 43JO; 44:13; 4530; 46:9, 13; 47:17; 50:18; 56:2, 12, 20; 57:10; 59:1; 61:3; 73:14; 74:21s 75:15, 16, 21; 76:1, 2; 77:11, 12, 21, 22; 79:14, 15; 87:9; 88:12, 22; 89:3; 93:1, 4; 94:2; 100:6; 107:11, 12, 16, 20; 108:8, 20; 109:7, 9; 112:19; 114:10; 119:16; 120:5; 133:21; 134:9, 22; 1353, 3, 5, 9, 13; 138:9; 1403, 3, 11, 12; 141:4; 142:4; 146:15; 151:4, 21; 154:1; 160:17; 171:7 receive [7] 62:17; 65:18; 78:2; 93:7; 109:11, 14; 111:14 received [12] 23:3; 62:11; 63:4; 66:14; 81:11; 103:8; 111:19; 112:10, 22; 118:20; 119:16; 120:6 receiving [2] 109:8, 9 Recess [2] 48:2; 122:5 recess [2] 4731; 61:17 recessed [1] 177:18 recipients [1] 111:6 reciprocal [1] 69:15 reciprocity [5] 66:3, 4, 5; 71:2, 14 recognize [4] 113:16; 134:14; 137:2; 139:17 recollection [12] 53:8; 77:14; 86:9; 87:5; 100:10; 101:2; 108:18; 114:4; 129:3; 137:3, 14; 142:10 recommendation [2] 104:9; 127:15 recommendations [1] 27:18 record [19] 19:19; 39:1, 19. 20; 44:4; 61:20; 62:6, 10; 63:22; 66:8; 68:3; 79:16; 133:6, 22; 138:20; 142:15, 16; 164:5; 177:16 Recovery [1] 93:20 recovery [3] 23:15; 24:6, 7 redone [1] 128:16 reduce [3] 164:21; 165:16; 169:15 reduced [1] 64:7 refer [5] 39:9; 75:10; 86:6; 94:4; 99:10 reference [20] 9:19; 11:14; 51:14; 77:21; 88:14; 102:1; 105:7; 108:22; 120:15; 123:21; 124:12; 127:7; 137:17, 18; 138:21; 139:10; 141:3; 174:1, 2; 176:9 referenced [5] 135:1; 153:9; 165:9; 167:1; 176:3 references [6] 40:7; 84:3; 137:13, 19; 138:14; 173:20 referred [5] 34:5; 116:15; 135:4; 172:2; 174:15 referring [11] 10:7; 18:6; 74:14; 107:3; 116:14; 126:1, 14, 17; 149:12; 162:11; 169:4 refers [7] 94:5; 99:9, 12; 102:1; 123:10, 14; 174:13 refine [1] 25:10 refined [1] 26:5 refining [1] 24:9 reflect [1] 40:4 reflected [1] 118:8 reflection [1] 161:1 reflects [1] 146:12 refresh [8] 86:9; 87:5; 95:1; 100:16; 1013; 108:18; 114:4; 137:14 refreshes [1] 100:9 refuse [1] 71:12 refused [1] 70:14 regard [16] 17:16; 19:2; 28:19; 29:4; 34:20, 22; 35:22; 55:12; 63:3, 13; 68:13; 70:15; 81:5; 82:12; 104:6; 159:12 regarding [21] 6:14; 8:19; 13:12; 46:22; 47:2; 78:22; 80:4; 88:11; 100:16; 105:8; 106:18; 10732; 123:8; 132:13; 133:5; 140:11; 141:6, 17; 144:15; 151:3, 14 regular [2] 42:16, 20 regularly [1] 42:13 regularly-scheduled [1] 42:16 regulation [1] 172:9 regulations [8] 81:15; 129:7, 11; 130:4; 171:22; 172:1; 174:22; 175:22 regulatory [14] 105:15; 106:15, 18; 107:13, 18; 128:21; 129:4, 6; 150:10, 12, 19; 151:2; 152:9 Reid [6] 56:10; 57:2; 60:12, 22; 61:1, 2 reimburse [1] 8:15 Rein [1] 3:12 rejected [4] 64:16, 17; 104:11, 20 rejection [1] 104:14 related [8] 34:8; 40:12; 49:8; 50:5; 84:20; 114:11; 128:19; 174:17 relating [8] 23:14; 24:10; 35:6; 45:17; 46:22 ; 47:4; 87:8; 154:3 relations [4] 43:16; 130:6, 11, 12 relationship [4] 15:2; 41:7, 9; 42:9 relative [2] 48:14; 137:20 relatively [1] 70:4 relayed [1] 80:21 releases [2] 165:11, 19 relevant [1] 29:12 relied [4] 57:22; 59:12; 79:2, 3 rely [l] 81:12 remains [1] 81:3 remember [46] 6:20; 7:12; 9:2, 18; 19:4; 26:13; 33:9, 22; 34:3, 4, 9; 42:19; 44:7, 14, 21; 50:21; 52:12; 54:12; 55:22; 56:1, 2, 9; 59:1; 60:21; 72:20; 73:13; 74:6; 77:13; 78:4; 79:9, 10; 86:14; 88:10; 105:5; 108:10; 114:16; 128:8, 10; 140:14, 16; 148:11; 155:22; 156:4, 17, 20; 172:1 remembering [3] 45:18; 46:14; 106:20 remove [1] 155:19 removed [2] 79:5; 98:3 reorganization [2] 52:3; 54:9 reorganized [1] 37:8 Look-See(37) repair [5] 167JO; 169:20; 170:4, 15, 17 Repeat [1] 603 repeat [1] 164:12 repeated [1] 164:7 repeating [1] 48:15 replaced [3] 46:6, 8; 50:16 replacing [2] 26:17, 18 report [5] 32:5; 114:21; 123:16; 138:4; 143JO reported [4] 32:6, 9; 40:19; 87:14 REPORTER [6] 20:5; 59:22; 106:9; 112:6; 163:18; 170:11 reporter [1] 1J1 reporting [3] 31:1; 36:12; 56:8 reports [2] 49:16, 17 represent [4] 6:11; 13:19, 22; 14:6 representation [1] 14:2 representative [1] 17J representatives [2] 50:2; 130:13 represented [1] 116J1 representing [1] 145 represents [1] 41:18 reprimand [2] 118:3, 6 request [9] 13:4, 19, 20; 14:1; 70:11, 16; 71:1; 81:12; 103:11 requested [1] 98:6 requesting [1] 71:7 require [7] 75:4, 7, 12; 91:2; 173:13; 176:4, 8 required [11] 24:10; 27:13; 28:7; 65:17; 76:6; 89:8; 98J1; 117J0, 21; 151J1; 172:2 requirement [3] 42:7; 64:19; 68:14 requirements [8] 68J0; 101:11; 130:5; 172:14, 20; 173 J, 6; 175:19 requires [1] 77:6 requiring [3] 150:10; 174:22; 176:10 reschedule [1] 67:12 research [2] 23:14; 115:3 Reserve [1] 3:4 reserve [1] 69:5 reserving [1] 69:8 residues [1] 157:19 Resource [1] 93:19 resource [3] 59:4; 60:2, 5 resources [8] 61:12; 75:5, 7, 12; 81:3, 9; 95:22; 96:11 respect [8] 54:21; 97:19; 106:15; 107:14; 135:6; 140:6; 142:20; 164:6 respects [1] 152:14 respond [3] 27:13; 116:2; 125-3 response [3] 117:4; 121:18; 169:9 responsibilities [19] 24:3; 30:19; 31:13; 33:1, 13; 34:20, 22; 35:16; 37:1, 4, 10; 46:18; 53:10, 22; 54:15, 18; 55:1; 78:14, 16 Responsibility [1] 94:10 responsibility [39] 35:2, 22; 36:5, 19; 48J2; 49:11; 52:7; 53:13; 54:20; 813; 82:22; 84:19; 87:13; 94:13, 22; 95:8, 13, 18; From producing to responsibility WATER PCB-SD0000068703 BSA Depo of; WILLIAM PAPAGEORGE Monsanto v Aetna January 13, 1993 CR: 54034,0 Look-See(38) `>6:4, 13, 14, 18; 97:8, 19, 22; 98:22; 99:3, 7; 101:6. 8. 12; 116:12, 17; 117:10, 14, 17, 19; 177:3, 8 responsible [19] 26:16; 27:4, 12; 32:7; 46:20; 47:1, 3; 52:11; 54:3; 78:19; 79:1; 80:22; 97:18; 116:22; 117:3; 131:12, 20; 152:13; 169:12 responsibly [1] 173:1 rest [3] 29:21; 120:17; 142:1 rested [1] 87:13 restroom [1] 38:21 rests [1] 97:9 result [9] 24:13, 16; 67:13; 125:5; 130:9; 143:6; 144:4; 166:5; 168:16 results [2] 104:3; 168:13 retained [5] 33:11; 36:19; 37:9, 10; 52:13 retired [6] 56:21; 57:1, 9, 10; 60:14; 155:13 retirement [1] 51:17 review [9] 22:2, 5; 78:7, 10; 85:21; 86:2; 100:22; 118:11; 135:14 reviewed [3] 79:7; 82:4; 134:5 reviewing [1] 120:5 Reviews [1] 133:13 reviews [3] 104:3; 134:22; 135:3 revolve [1] 7:9 reward [1] 41:20 rewriting [1] 69:6 Richard [1] 94:1 Right [3] 43:11; 114:1; 172:5 right [42] 8:20; 11:2; 12:6; 17:10; 18:15; 29:14; 38:17; 45:3; 48:20; 49:2; 55:15; 57:5; 60:8; 69:3, 5, 8; 74:22; 86:13, 16; 87:1, 3; 90:15; 103:2; 123:18; 130:14, 20; 149:2; 152:9, 21; 156:10, 13; 157:6; 159:13; 165:4, 12, 20; 167:4; 168:7; 170:20; 173:7; 174:8 right-hand [4] 74:13; 86:6; 134:15; 171:8 risk [1] 71:11 River [2] 139:21; 148:14 rod [1] 151:11 role [3] 13:21; 98:8; 151:8 Roman [3] 93:14; 94:14; 138:21 room [2] 89:13; 126:22 roughly [3] 27:22; 30:19; 68:16 rubber [1] 26:7 rule [1] 64:5 rules [1] 20:2 run [1] 18:2 rupturing [1] 163:5 _________ - S - S-a-u-g-e-t [1] 30:15 S-a-y-e-r-s [1] 93:22 sake [1] 44:4 salary [1] 41:20 sample [1] 131:6 samples [1] 132:4 Sampling [1] 152:1 San [1] 3:6 sand [2] 166:18, 19 SANDBECK [1] 5:3 Sansome [1] 3:5 Santa [3] 139:21; 148:14, 20 SARFATTI [150] 10:7; 11:9, 22; 12:7, 19; 13:1; 14:22; 15:10, 14, 20; 18:6; 19:15; 20:9; 22:7; 29:6, 19; 38:11, 15, 18; 39:19; 41:2; 43:8; 44:3, 22; 46:2; 47:22; 49:3; 51:13, 17, 19; 59:5; 60:3; 61:21; 62:1, 3, 8; 64:12, 17; 65:5, 10; 66:1, 14; 68:11; 69:1, 5, 8, 18, 21; 70:10, 20; 71:7, 21; 72:8; 73:2; 77:20; 80:8, 15; 81:7, 20; 82:6; 83:16, 21; 90:2, 10, 20; 91:14; 92:1; 96:15, 19; 97:3, 13, 15, 21; 103:11; 104:7, 12, 21; 109:13, 20; 110:6; 115:10; 116:14; 118:14; 119:3, 12, 14; 120:1, 10; 121:13, 17; 122:3; 124:16; 125:2, 13; 127:18; 129:1, 13; 130:10; 131:10, 18; 132:11; 133:14; 139:9; 140:9; 142:12, 14, 22; 143:10, 16; 144:5, 13; 145:1; 146:10; 148:3; 149:13; 150:8; 152:10; 153:21; 154:20; 155:3; 157:15; 158:2, 10; 159:19; 160:3, 7; 161:4, 19; 162:16; 164:2, 11, 16; 165:5, 13; 166:1, 9; 167:5, 11; 168:8, 18; 169:8; 170:5; 171:21; 172:8, 21; 173:18; 175:11; 176:7, 15; 177:1 Sarfatti [24] 2:4; 13:17, 19; 14:8, 12, 15, 18; 16:1, 19; 17:12, 20; 18:4, 19; 19:2, 4; 22:16, 19; 29:17; 64:8, 10, 13; 79:17; 103:7 sat [1] 48:18 satisfactory [1] 65:8 satisfy [1] 174:18 Saturday [5] 62:11, 18; 118:18; 120:6 Sauget [2] 30:15; 31:2 sawdust [1] 166:18 Sayers [3] 93:21; 94:1 saying [11] 11:7; 65:3; 68:12; 69:3; 71:3; 110:22; 111:2; 114:19; 119:21; 159:1; 166:15 schedule [4] 11:4; 18:1; 67:10; 174:21 scheduled [6] 16:5, 8, 9, 18; 42:13; 70:3 scheduling [5] 7:9; 9:4; 15:10, 15; 16:13 Schwalb [1] 2:5 Science [2] 23:3, 4 scientifically [1] 173:9 scope [2] 15:7; 35:13 score [2] 21:13; 27:2 Scott [2] 4:3; 126:22 screw-up [1] 119:20 scriggled [1] 154:10 scrubber [1] 132:2 seal [2] 162:22; 163:1 search [1] 103:16 second [13] 56:1; 63:13, 21; 75:2; 80:18; 101:16; 115:1; 123:16; 133:6; 137:4; 155:16, 17; 175:17 second-to-last 12] 101:16; 173:11 Secondary [2] 24:6, 7 secondary [2] 23:15; 24:4 secretaries [1] 134:9 secretary [7] 32:11; 112:21; 134:8; 154:12, 14, 17, 19 section [1] 113:22 seek [1] 176:13 seeking [1] 176:21 seepage [1] 162:6 selection [2] 135:6, 9 self-explanatory [2] 73:16, 18 send [3] 43:16; 62:21; 110:18 senior [1] 57:17 sense [2] 79:1; 161:22 sensed [3] 116:5; 117:7; 130:11 sentence [30] 75:2; 77:6; 84:17; 101:17; 122:9, 12; 123-3, 4, 9, 13; 124:6, 7, 13, 20; 1253; 127:11; 139:18; 1433; 1443, 19; 1463, 12; 147:17; 148:12; 162:3; 167:1; 173:12; 174:15, 20 sentences [3] 124:18; 125:12; 146:20 separate [2] 71:21; 87:19 separated [1] 24:15 September [1] 99:20 sequence [1] 28:3 series [1] 62:16 serve [1] 98:5 served [2] 31:4; 151:11 service [2] 12:11; 28:15 Services [2] 8:18; 27:9 services [7] 28:4, 6, 9, 12; 303, 12; 32:11 SESSION [1] 61:18 session [1] 38:8 seven [1] 63:6 seven-day [8] 62:10, 13; 63:15; 64:19; 68:15, 21; 71:10; 118:19 Seventies [3] 44:6; 613; 167:10 seventy [2] 37:7; 57:4 sewer [16] 143:20; 162:5; 163:22; 164:14, 19, 20; 166:6; 167:2, 9; 168:17, 20; 170:1, 4, 12, 15, 17 Sewers [2] 1383; 164:15 sewers [5] 143:21; 168:6, 10; 170:2, 13 shaft [1] 162:22 Shallow [1] 122:13 share [2] 47:8; 50:9 shared [1] 101:5 sheer [1] 135:18 sheet [3] 84:13; 153:7, 17 shocked [2] 71:1, 15 shoes [21 95:14, 15 shoot [2] 38:15; 163:9 shorthand [1] 1:21 shot [2] 80:3; 85:18 shoulders .[1] 169:14 shovels [1] 96:1 shows [1] 109:7 shut [1] 165:21 sic [1] 133:11 sieves [1] 168:10 signature [2] 100:1, 2 signed [1] 37:22 significant [5] 71:18; 75:4, 7, 12 Silbert [1] 2:5 sir [32] 12:15; 18:15, 18; 19:11; 20:22; 21:7; 31:12; 32:13; 33:22; 42:5, 19; 43:5; 463; 50:12; 56:7; 57:8; 74:15; 76:11; 80:1; 84:10; 87:4; 101:15; 109:3; 110:21; 111:16; 127:8, 9; 13331; 134:7; 141:2; 146:21; 1663 sit [2] 59:15; 118:11 Site [3] 101:14; 124:8; 162:3 site [20] 89:15; 101:13, 15; 107:4; 124:18, 22; 125:10, 17; 127:4; 128:6; 144:21; 153:17; 15530, 21; 1563; 162:6; 165:16; 173:15, 17; 174:8 sites [18] 2832; 29:4, 10, 12; 503; 88:15; 95:10; 99:10, 11; 106:19; 115:2; 122:17; 137:13; 142:8; 148:6; 1503; 154:4; 175:13 sitting [2] 96:2; 129:15 situation [23] 41:18; 62:10; 643, 22; 65:17; 68:13, 14; 70:12, 19, 20, 22; 72:1; 75:9; 80:16; 82:15; 88:18; 105:20; 106:10; 150:4; 16730; 168:19; 169:12; 175:2 situations [10] 33:7; 54:19; 55:5; 64:3; 111:3, 17; 112:7; 116:9; 131:8; 148:13 six [2] 27:11; 50:17 sixth [1] 30:19 Sixties [1] 167:10 sketch [1] 21:8 skim [1] 83:18 slide [1] 84:17 sUdes [1] 843 Sniveley [1] 7:13 Soda [2] 39:14; 52:14 soil [1] 143:7 sold [1] 115:6 solely [1] 128:19 solid [6] 41:10, 15, 18; 46:22; 48:12; 49:9 Solids [1] 113:6 soluble [1] 147:13 solving [1] 81:17 Somebody [1] 76:21 somebody [2] 80:18; 108:1 somehow [1] 117:1 Someone [1] 86:2 someone [9] 42:4; 44:1; 45:22; 89:21; 105:16; 111:8; 135:20; 161:7; 177:2 somewhat [2] 10:18; 34:7 somewhere [4] 56:21; 61:6; 107:6; 158:19 sorry [24] 14:3; 22:18; 26:3; 31:22; 55:10; 57:4; 88:9; 93:5; 100:14; 106:7; 107:15; 113:14; 121:16, 19; 122:11; 132:16; 133:16, 17; 139:7; 143:13, 14; 154:22; 160:21; 172:13 sort [4] 79:4; 84:4; 85:5; 134:5 sound [2] 6:3; 166:10 sounds [4] 18:15; 120:2; 124:3; 1553 sources [3] 49:17; 144:20; 146:8 South [8] 107:5, 22; 125:18; 126:6; 140:12; 141:10; 142:2, 19 I speak [10] 7:5; 38:19, 20; j 57:21; 733, 22; 104:8; | 127:19; 16130, 21 i speaking [3] 43:8; I 102:19; 141:9 Special [4] 19:20; 91:7, 10; 164:5 special [5] 42:13; 59:3; 60:1; 91:2; 117:6 specific [6] 70:21; 77:14; 81:17; 105:8; 112:19; 145:12 Specifically [1] 153:14 specifications [2] 353; 172:11 specifics [3] 58:13; 140:2; 151:4 . speculate [1] 132:21 speculating [2] 111:11; 124:1 speculation [1] 170:8 speed [2] 50:4; 16030 spent [1] 155:19 spill [1] 169:15 spilling [1] 163:6 Spills [1] 167:1 spills [6] 143:6; 144:4; 162:4, 12; 166:6, 11 spinning [1] 89:13 spins [1] 89:10 spot [2] 166:17, 20 Springfield [2] 148:15, 21 Springs [2] 39:14; 52:14 Square [1] 2:15 squiggly [1] 154:8 St [19] 1:19; 173; 20:20; 23:2, 7; 25:8; 29:9; 30:22; 31:5, 7; 32:2; 44:2, 8; 67:8; 72:2; 74:18; 80:21; 96:2; 171:11 stack [1] 131:22 staff [29] 40:8, 22; 42:17; 43:12; 44:16; 45:6, 21; 46:16, 20; 48:10, 17; 49:20; 50:8, 16; 55:14; 58:5, 11; 59:12; 60:16; 79:4; 81:8, 13; 82:17; 84:18; 85:3; 86:20; 94:3; 117:5; 118:6 staffing [1] 52:2 stain [1] 167:7 stamped [1] 161:13 stand [5] 79:12; 122:3; 124:18; 129:16; 130:19 standards [1] 129:4 stands [1] 81:1 start [2] 61:19; 75:16 started [6] 22:20; 58:8; 72:13; 76:8; 166:7; 169:9 starting [5] 24:18; 26:7; 85:14; 155:1; 157:17 STATE [1] 1:1 State [2] 1:19; 150:15 state [8] 49:17; 62:8; 81:14; 91:15; 106:18; 129:6; 150:13; 164:4 stated [4] 64:18; 84:18; 87:4; 114:15 statement [12] 68:2; 84:17; 86:11; 97:15; 144:12, 22; 145:6, 19, 21; 146:9, 15; 175:16 statements [4] 146:20; 147:2; 149:11; 175:14 responsible to statements WATER PCB-SD0000068704 BSA Depo of; WILLIAM PAfAGEORGE Monsanto v Aetna January 13, 1993 CR: 54034.0 states [1] 153:8 status [1] 103:13 stay [2] 116:8; 164:20 stayed [1] 52:1 staying [1] 17:5 steering [1] 67:20 step [4] 81:11; 82:20; 95:14, 15 steps [1] 79:5 sterile [1] 165:15 Steve [1] 66:8 Steven [1] 2:4 STG [2] 160:16 stimulate [1] 117:16 stipulate [3] 69:9; 70:2; 71:4 stipulation [6] 61:21; 67:18; 68:19; 69:4, 17; 71:13 stop [1] 159:18 stopped [1] 166:8 storage [1] 142:1 stored [1] 120:20 strata [1] 147:9 strategically [1] 122:14 streams [2] 24:16; 76:4 Street [3] 2:8; 3:5, 13 strike [1] 156:6 strongly [1] 150:3 structures [1] 142:10 studied [1] 149:14 Studies [1] 114:7 studies [3] 114:14, 16, 18 Study [2] 123:19; 138:5 study [26] 27:17; 89:21; 108:8, 15, 16, 19; 114:5, 9. 10, 17, 19; 115:3, 9, 15, 17; 116:2, 15; 117:13. 15. 17; 120:16; 126:18; 138:10; 143:20; 152:20. 21 stuff [1] 17:22 Styrene [2] 34:14; 156:20 stvrene [3] 36:6, 20; 37:14 sub [1] 138:22 subheading [1] 149:17 Subject [1] 92:17 subject [10] 15:1; 20:10; 21:10, 11; 63:9; 72:5; 74:10; 108:16; 127:4; 133:12 subseutences [1] 175:1 subsequent [4] 18:10, 12; 101:19, 22 substance [1] 19:18 Substances [1] 45:10 substantial [5] 115:8, 13; 120:16; 144:20; 145:15 substantially [l] 64:7 substantive [1] 15:5 substrata [1] 91:2 success [1] 123:6 suggest [6] 21:13; 92:3, 7; 120:20; 140:20; 161:6 suggesting [1] 120:4 suggestion [2] 92:11; 142:12 suggests [1] 156:8 Suite [1] 2:7 sidphuric [1] 34:9 Summary [1] 160:15 summary [4] 25:4: 29:2, 7; 161:7 super [1] 25:21 Superintendent [2] 27:3, 10 superintendent [2] 28:3; 58:11 superintendents [2] 30:18; 136:12 SUPERIOR [1] 1:1 supervising [1] 27:10 supervision [2] 41:11, 21 Supervisor [2] 25:18; 26:2 supervisor [4] 26:4, 15; 41:19; 118:10 supplement [3] 63:15; 65:17; 68:15 supplemental [1] 66:10 supplementary [1] 65:19 supplied [1] 115:4 support [6] 98:8; 115:13; 145:10, 14, 15, 19 supported [1] 92:4 suppose [2] 85:13; 158:14 supposed [1] 112:22 SURETY [1] 1:10 Surface [1] 107:11 surface [3] 107:9; 147:16; 169:1 surprised [1] 173:19 survey [8] 77:15; 88:20, 22; 89:5, 11, 14; 90:1, 9 surveys [7] 77:7, 9, 17; 88:12, 14, 15, 17 suspect [3] 130:2; 158:4; 159:3 suspects [1] 135:17 Sutcliffe [1] 3:3 swept [1] 166:12 sworn [1] 6:3 synonymous [1] 118:21 system [10] 97:6; 109:22; 111:7; 112:16, 18, 20; 163:10; 164:20, 21; 165:7 systems [4] 115:5, 7; 124:11 -T - T-h-r-o-d-a-h-1 [1] 40:16 T-r-o-m-b-l-e-e [1] 56:2 table [3] 132:19, 20; 138:20 tacked [1] 143:20 takes [2] 118:12; 141:13 talk [2] 91:10; 163:4 Talking [1] 50:1 talking [16] 25:12; 41:2; 44:3; 48:4; 50:1; 54:16; 59:11; 102:11; 133:14; 141:8; 142:9; 143:12, 17; 147:3; 154:3; 168:4 tank [7] 26:17; 27:14, 16; 162:4; 163:5; 165:10; 167:1 tardy [1] 117:4 target [1] 163:10 Task [1] 138:5 task [1] 143:20 tasks [1] 81:17 team [22] 27:11, 17; 41:8; 42:12; 43:14; 47:7, 11; 50:12, 13, 19, 21; 51:7, 22; 52:1; 58:14; 59:16; 85:8; 86:2, 20; 116:1 teams [1] 27:22 Technical [1] 27:9 j technical [1] 27:11 technicians [1] 27:12 I technology [3] 163:11; I 164:18; 167:18 telecopy [1] 62:22 telephone [1] 57:15 telling [2] 16:17; 30:2 tells [1] 124:2 Tennessee [2] 39:14; 52:15 term [4] 42:10; 103:18; 150:8; 153:21 terminology [1] 142:11 terms [8] 21:9, 18; 41:14, 16; 75:10; 101:10; 151:5; 162:11 test [5] 122:13; 123:21; 124:20; 157:14, 22 testified [1] 6:5 testify [1] 70:15 testimony [5] 11:10; 12:1; 19:16; 67:7; 72:1 testing [1] 175:18 Texas [57] 28:19; 29:3, 8; 39:13; 52:21; 53:4, 11, 14,17; 54:21; 55:13, 19; 58J; 60:8, 19; 61:13; 77:10, 15; 79:8, 17; 88:22; 90:13, 15, 18; 91:21; 98:17; 105:10; 1063, 16; 107:12, 17; 128:12; 132:9, 17; 135:7, 11, 14, 20; 136:7; 137:20; 13930; 140:1, 6, 8; 1413; 142:21; 144:4; 1453; 148:14, 22; 150:18; 151:2; 155:18; 156:15, 22; 159:13; 168:3 Thank [2] 106:12; 177:15 there'll [1] 72:4 They're [1] 119:3 they're [4] 70:21; 73:17; 128:16; 164:17 thinking [3] 38:14; 95:20; 129:8 thinners [1] 24:17 third [12] 17:1; 84:13; 113:18, 21; 124:6, 7; 127:10; 147:17; 153:15; 155:17; 175:17 Thirties [1] 167:18 thirty [1] 64:10 Thomas [2] 2:8; 4:5 thorough [1] 60:11 thoroughly [2] 53:19; 94:15 thoughts [5] 10:19; 50:10; 72:21; 102:7, 9 three [5] 26:6; 27:12; 793; 110:7; 115:2 Throdahl [11] 40:16, 19; 41:4, 8; 42:6, 8, 12, 18; 43:12; 45:6; 94:2 thrust [1] 35:20 thumbnail [1] 21:8 tickets [2] 8:3; 12:11 tied [1] 11:4 till [2] 25:5; 28:20 times [4] 88:16; 110:7; 112:21; 121:14 timing [1] 37:18 tired [1] 38:5 title [25] 26:1; 28:4; 31:7; 33:5, 9, 10, 14; 35:8, 12; 36:14; 37:5, 9; 45:8, 11; 47:14, 18; 54:12; 60:19; 72:7, 9; 84:5; 108:10; 123:15; 139:2 Tides [1] 44:17 to-wit [1] 6:5 total [3] 27:6; 113:21; 156:17 totally [2] 33:11; 59:12 town [1] 19:5 | Toxic [1] 45:10 toxic [1] 115:6 toxicologist [1] 133:4 traced [1] 148:10 track [1] 17:7 traditional [1] 141:16 transferred [1] 50:15 trap [11 169:16 Travel [1] 8:18 travel [6] 8:2, 18; 12:10; 15:10; 17:2, 4 TRAVELERS [1] 3:10 traveling [1] 42:22 traveling-type [1] 15:15 treating [1] 168:21 trial [5] 8:7, 8; 10:18; 11:15; 12:14 trivia [1] 155:3 Tromblee [1] 56:1 trouble [1] 16:22 troubles [1] 38:5 true [9] 83:2, 4; 101:8; 130:13; 131:7; 167:10; 170:19, 21; 173:1 truth [3] 6:4 Tuesday [1] 64:10 tuned [1] 86:12 Turk [1] 6:20 Turning [6] 76:12; 93:13; 137:4; 144:8; 155:16; 173:11 twelve [3] 27:11; 66:9, 13 twenty [1] 122:1 type [14] 15:12, 14; 24:10; 42:9; 89:5; 112:12; 114:18; 115:17; 147:6, 9; 162:8; 165:19; 166:22; 167:2 types [4] 23:13; 43:10; 157:14; 158:8 -U- ultimate [7] 96:13, 17, 20; 97:8; 117:10, 14, 17 ultimately [2] 97:17; 104:5 unacceptable [1] 168:13 unclear [1] 18:3 Undefined [2] 150:8; 153:21 underground [4] 162:5; 164:18; 165:10; 167:2 underneath [3] 91:1; 147:9, 16 understand [19] 40:18; 42:10; 49:12; 51:19; 55:17; 63:5; 70:8; 73:4; 80:9; 82:11; 89:4; 97:6, 11; 102:12; 109:9; 116:11; 147:8; 157:4; 174:11 understanding [23] 9:9; 10:1; 11:16; 19:9, 11; 60:4; 66:10; 79:21; 80:1; 85:1; 99:2, 4, 6; 104:5; 142:5; 143:9; 144:3, 7. 16; 147:5; 154:13; 157:5; 168:11 understood [4] 29:8; 44:15; 48:22; 117:20 underway [1] 114:7 underwent [1] 52:2 UNDERWRITERS [1] 4:1 undesirable [3] 105:21; 106:11; 169:16 . unfairness [1] 69:13 j unfeasible [1] 170:16 | uninterrupted [5] \ 173:14, 16; 174:7, 16; 175:9 unique [2] 114:17, 20 unit [7] 39:5; 42:1; 46:21; 48:11, 18, 19; 116:21 Look-See(39) units [7] 37:8; 38:2; 39:5; 40:18, 19; 41:7; 147:10 universal [1] 114:18 University [4] 23:2, 7; 149:9 university [1] 49:17 unmanageable [1] 130:16 unnecessary [1] 173:8 unoccupied [1] 142:10 unusual [1] 113:2 updated [1] 128:7 upgrade [1] 175:20 upgrading [2] 124:10; 174:3 upper [3] 98:7; 143:7; 171:8 uses [1] 119:10 usual [3] 111:13, 15; 165:11 utilities [1] 28:4 -V- vague [13] 59:5, 21; 80:8; 82:7; 96:15, 19; 97:21; 129:1; 131:10, 18; 150:8; 153:21; 161:19 vaguely [1] 114:16 vagueness [2] 46:2; 129:13 Valley [1] 20:20 value [2] 59:4; 60:2 valve [1] 132:2 vary [1] 68:20 vast [1] 150:11 VCM [2] 36:5, 20 version [3] 41:15; 72:22; 153:16 vice-president [4] 40:11, 15; 43:21; 44:1 vice-presidents [1] 44:7 view [2] 145:11; 164:12 Vinyl [1] 34:16 vinyl [1] 37:14 violation [2] 91:9; 164:10 Virginia [1] 29:10 virtually [3] 144:20; 145:15; 149:18 visit [2] 50:7; 55:13 visiting [1] 49:20 visits [1] 58:10 volatile [1] 159:5 VOLUME [1] 1:15 volume [2] 64:7; 147:14 voluntary [4] 150:6, 9; 153:17, 19 vouch [1] 83:5 vs [1] 1:8 - W- W-e-i-s-h [1] 50:17 waiver [1] 15:4 Wald [1] 4:4 wanted [7] 17:9; 29:16; 43:21; 89:6; 113:15; 116:21; 130:8 warehousing [1] 28:5 warrant [3] 89:22; 90:8, 18 warranted [1] 91:22 Washington [6] 2:9; 3:14; 4:6; 23:2, 7; 44:9 Waste [2] 77:18; 123:19 waste [25] 21:19; 26:21; 28:9, 13; 36:1; 45:14, 17; 48:12; 49:9; 99:10, 11, 12, 16; 108:8, 16, 18; 114:4; 115:5; 126:18; 153:7, 17; 155:19; 175:21 wastes [8] 21:16; 24:1; From states to waste WATER PCB-SD0000068705 BSA Depo of: WILLIAM PAPAGEORGE Monsanto v Aetna January 13. 1993 46:22; 94:20; 96:6; 98:21; 114:12: 174:3 wastewater [2] 144:9; 162:6 watch [1] 38:4 watchdogs [2] 85:6, 7 water [20] 45:17; 46:10, 13; 47:1; 48:12; 49:8; 107:1, 9, 11; 131:1, 6; 132:4, 19, 20; 147:13, 14; 159:10; 168:20, 22 water-soluble [1] 158:6 waters [4] 147:10, 11, 15 wavs [1] 55:11 We'll [1] 29:21 we'll [10] 15:20; 18:1; 29:20; 38:6, 22; 63:18; 65:9; 67:12; 68:1; 120:2 We're [3] 41:2; 52:1; 74:3 we're [10] 63:7; 66:1, 3; 68:8; 69:3; 91:9; 102:11; 133:14; 142:8; 154:3 We've [2] 122:1; 164:11 we've [4] 126:2; 143:11; 149:12; 164:7 wear [1] 163:6 week [12] 6:16; 7:14; 10:15; 18:13; 19:5, 8, 10; 72:3; 89:20; 103:12; 118:21 weeks [1] 58:14 WeLshaar [2] 50:16; 108:6 weld [1] 162:18 Welge [2] 2:14; 6:11 wells [9] 23:16; 24:5; 122:13; 123:21; 124:13; 125:9; 151:19, 21 weren't [2] 97:17; 175:8 West [1] 29:9 west [1] 171:12 WGK [5] 74:12; 139:12; 143:22; 171:5 wheels [1] 89:13 whenever [2] 38:8; 129:6 whereas [1] 41:22 Whereupon [2] 6:1; 177:17 wherever [1] 28:14 wherewithal [1] 28:13 whoever [1] 146:3 WHP [2] 92:18, 19 Wiley [1] 3:12 WILLIAM [2] 1:17; 6:2 William [3] 30:16; 39:12; 52:14 willing [4] 16:15; 17:13; 64:14: 71:4 Wilmington [26] 8:6, 8, 12, 16; 9:17, 20, 22; 10:6; 11:18; 12:2, 9; 14:19; 16:2, 8, 9. 15, 18, 20, 22; 17:4, 13, 16; 18:5, 20; 20:14; 67:8 wing [2] 153:15; 171:12 Wink [1] 45:4 Wintrhop [1] 45:5 wish [1] 68:17 WITNESS [9] 2:3; 6:22; 38:10, 20; 47:21; 112:5; 121:20; 160:21; 177:15 Witness [9] 83:22; 92:22; 95:7; 114:2; 134:19; 138:8; 153:3; 160:11; 171:16 witness [13] 22:9; 29:8; 51:14; 63:11; 64:5, 15; 70:15; 72:2; 121:13, 17; 159:19; 164:7; 169:8 witnessed [1] 169:7 I witnesses [2] 64:1, 2 j won't [1] 69:17 word [15] 11:15; 16:11; ! 49:5; 51:11; 60:5; 87:4; | 88:4; 96:20; 105:13; 115:13; 136:11; 145:14, 15, 16; 167:13 words [15] 7:13; 8:7, 13, 17; 9:18; 11:2; 14:4; 16:3; 17:11, 17; 19:3; 28:5; 48:18; 53:5; 175:20 work [14] 19:13; 20:7; 22:8; 23:14, 18, 22; 27:13; 30:20; 31:18; 32:14; 79:6; 89:20; 93:11; 172:10 worked [9] 23:9; 26:9; 56:4, 21; 57:11; 59:8; 60:16; 61:1; 68;6 working [6] 61:2; 95:17; 97:6; 116:1; 155:12 workplace [3] 54:13, 19, 21 world [6] 31:21; 111:2; 165:14; 167:3; 168:2, 5 world-wide [1] 72:16 Worldwide [10] 74:10; 86:22; 98:12; 100:10; 101:20; 102:9; 124:9; 126:5, 15; 127:15 worldwide [2] 105:4; 128:20 worn [1] 162:22 wouldn't [14] 11:16; 45:5; 69:2; 86:15, 17, 18; 92:10; 109:16, 19; 117:9; 118:6, 8; 159:5, 7 wound [1] 110:3 writing [1] 144:16 wrong [2] 7:2; 78:17 wrote [1] 7:2 -Y- Yeah [3] 7:1; 62:2; 84:15 yeah [3] 51:18; 75:1; 105:5 year [11] 25:20; 30:10; 33:5; 46:14; 53:1; 58:8, 9, 17; 102:7; 106:20 yearly [1] 102:3 years [7] 24:20; 26:14; 57:20; 75:5, 13; 101:19, 22 Yesterday [1] 22:15 yesterday [3] 22:18; 62:21; 63:4 you'd [3] 38:11; 112:4; 141:18 You'll [1] 14:5 you'll [4] 71:5; 173:20; 176:9 You've [1] 166:20 you've [12] 21:9; 35:9; 92:15, 21; 97:4; 134:5; ' 137:1; 138:7; 139:3, 15; 143:10; 160:4 younger [1] 57:21 yourself [2] 113:20; 171:15 -Z- zero [3] 163:10; 164:22; 165:17 zone [2] 153:15; 171:12 CR: 54034.0 i I wastes to zone Look-Se<`(40) WATER PCB-SD0000068706 Page i Line J iry 13-15, 1993 CORRECTIONS TO DEPOSITION _ Wixxiam B. Papageorge Correction:______________ _________________________________________________________ *f7 ' 5 O' I TaltmCf if Consisted of tuop >h ehuCJl oa h ( U./i^ LUSto ruffs' people. Qud Harry____________ co t'-I h__________ fei I ; U/g 111 -p r m e and m ^ f ea m t r ea I ly , n of Ag me~__________ ts< (S4 \ 1 : ! : ($8 ! i' (i ; /<2 ', 79 ! o( 0 n i luhat CDnd \ 0*s rm/S'f' eHist umd.ernea'hi that plant' m on 1 Tqrtfc/ ac^ivHies , X served as a prod where necessary T^a p n <f<> r tf e , find die neft name would been Syu, ggled fio a 5 i^uation Lulnere T mufh't Sa. lj ^ better loetC -fa) r *h) / $ l 63 (hi 6! 1 t ?> p /11 > / 7 0 roi^ the place. These ujete. not +U e buj Spifl$ Luo old be- tine result of a Cahsiroph i't failure en. a fine or 7.H 1 i3 O^cl there are- usas^s under (Is So rface. ; i ^ lo 4 $, i3 0 0 u*sed 'Hie coerd au/are.'* * T do no"! re ca 1') ana 3*9 Z 212- tn tvrmqtioi bo 5C. or} v exhume ble. \foor guesh Ovr IS . _ What doea he- do ? He. loemcs 3Mt> 2_ cu-el 1 be. th e. korth 80 (s the. prvpuL- designation 3*7 <9 9 bu4 Ci'hifr one. 'Hirsc luoold hare been a So^^ee erf : *t \ f & j____7 1 ndershpoef ; Sir . 776 j f5" : from _ _ q ,,*< I bop<- ^ t>aj "Hi* s, p^rw^c-e lf" ------------ f------------ ---------------------------- , ----------- --- -- ------- ---- ---------------------------------------------- I: ' M76 j Ha \ Correctly-. blepharospasms , fe-4-g - p-h-g- r-o-'S- p-A-5-w-'5 , 7^7; H77j m j Irip* 0/ # emergency n^l^re. 'Unpredictable., #.ngf `bhe1* yot I i j_ I! I WATER PCB-SD0000068707