Document V4gJN2bMRkrG6aGer2NX6nkq

Page 405 1 In The Superior Court 2 Of The State Of Delaware 3 In And For New Castle County 4 ------------------------------------ -x 5 Monsanto Company, : 6 Plaintiff, : 7 : Civil Action Number 8 v. : 88c-ja-118-1-cv 9 Aetna Casualty & Surety Company, : Non-arbitration 10 et al. , : Case 11 Defendants. : 12-------------------------------------x 13 Deposition Of James R. Savage ( Volume 3 ) 14 Wilmington, Delaware 15 Thursday, May 20, 1993 16 Deposition of James R. Savage, called for further 17 examination pursuant to agreement by counsel, at the law 18 offices of Smith, Katzenstein and Furlow, 1220 Market 19 Street, Fifth Floor, at 9: 50 a. m. before Kristine A. 20 O'connor, Court Reporter, when were present on behalf of the 21 respective parties: 22 -- continued -- Page 407 1 CONTENTS 2 Witness Examination 3 James R. Savage ( Resumed ) 4 by Mr. Brock 408 5 EXHIBITS 6 Savage Deposition Number Identified 7 Exhibit 100 - 10/2/72 memorandum 409 8 Exhibits 101, 102, and 103 - Correspondence 411 9 Exhibits 104 and 105 - 6/17/59 memorandum and 420 10 4/20/59 progress report 11 Exhibit 106 - 2/8/60 memorandum 430 12 Exhibit 107 - 10/27/61 progress report 442 13 Exhibit 108 - Supplemental information 448 14 Exhibit 109 - 9/21/61 memorandum 469 15 Exhibits 110 and 111 - 6/8/59 progress report and 473 16 6/23/59 memorandum 17 Exhibit 112 - 1/27/59 progress report 482 18 Exhibit 113 - 7/14/66 process document 489 19 Exhibit 114 - 9/30/71 progress report 505 20 Exhibit 115 -1/9/59 memorandum 541 21 Exhibit 116 - 2/11/59 memorandum 542 22 Exhibit 117 - 7/19/62 memorandum 542 23 Exhibit 118 -12/14/62 memorandum 542 24 Exhibit 119 -1/4/63 memorandum 542 25 Exhibit 120- 11/14/63 handwritten document 543 26 Exhibit 121 - 6/7/63 progress report 566 27 Exhibit 122 - 10/13/60 memorandum 578 28 Exhibit 123 - 6/15/59 memorandum 593 29 Exhibit 124 - Raw data sheet 596 30 Exhibit 125- 10/15/59 letter 599 31 Exhibit 126 - 4/20/66 memorandum 604 32 Exhibits 127, 128 and 129 - Correspondence 615 Page 406 Page 408 1 Appearances: James F. Burnett, Esq. 2 Potter, Anderson & Corroon 3 350 Delaware Trust Building 1 PROCEEDINGS 2 Whereupon, 4 902 Market Street 3 James R. Savage 5 Wilmington, Delaware 19801 4 resumed the stand and, having been previously duly sworn, 6 On behalf of Plaintiff Monsanto Company. 7 Stephen F. Brock, Esq. 8 Manta and Welge 5 was examined and testified further as follows: 6 Examination ( Continued ) 9 One Commerce Square 7 By Mr. Brock: 10 Thirty-seventh Floor 11 2005 Market Street 12 Philadelphia, Pennsylvania 19103 13 On behalf of Liberty Mutual Insurance Company. 8 Q Good morning, again. Mr. Savage, let me start 9 today with some things 1 maybe should have covered at the 10 very beginning but didn't. Where do you reside, sir? 14 Charles Meyer, Esq. 11 A In Kirkwood, Missouri. 15 Jackson & Campbell 16 One Lafayette Centre 17 1120 Twentieth Street, N. W. 12 Q What is the street address? 13 A 1461 Oak Bluff Lane. 18 Suite 300 South 14 Q Do you have any relatives who work for Monsanto? 19 Washington, D. C. 20036 15 A No. 20 On behalf of The American Home 21 Assurance Company, Birmingham 22 Fire Insurance Company, Granite 16 Q Do you have any relatives who have worked for 17 Monsanto in the past? 23 State Insurance Company, The 18 A No. 24 Insurance Company of the State 25 of Pennsylvania, Lexington 26 Insurance Company, and National 27 Union Fire Insurance Company of 19 Q Can you describe for me briefly what you did to 20 prepare yourself for your deposition in this case? 21 A Very little. Met for a couple of hours with 28 Pittsburgh, Pennsylvania. 22 Mr. Burnett the day before. Savage, James (Aroclor Dept employee) in AETNA (3) Pages 405 - 408 HARTOLDMONO010235 Page 409 Page 411 1 Q Did you review any documents? 1 Q Do you recall any investigation or study around 2 A Yes. We looked at some documents that he thought 2 this time into the question of whether there were, in fact, 3 we might see. 3 Pcbs in the ground around the Krummrich plant? 4 Q And approximately how many, or how big was the 4 A 1 don't remember that there were. 5 stack? 5 ( Savage Exhibits 101, 102, and 103 6 A 1 don't remember. Less than 50 documents, 1 6 identified. ) 7 think. 7 By Mr. Brock: 8 Q Have you spoken about your deposition with any of 8 Q For the record, I've marked three new exhibits, 9 your former colleagues at Monsanto -- 9 Exhibits 101 through 103. Exhibit 101 has Bates numbers of 10 A No. 10 Ann 1539040 and 041. Mr. Savage, can you explain to us 11 Q -- other than lawyers? 11 what this document is? 12 A No. 1 may have mentioned to them that 1 was 12 A 1 don't remember this specific form. It's 13 going to do it but that's all. 13 obviously some kind of work request that was filled out to 14 ( Savage Exhibit 100 identified. ) 14 begin a project. 1 worked with similar forms. 1 don't 15 By Mr. Brock: 15 remember this one. 16 Q I've marked Exhibit 100 for the record. 16 Q The objective of this is to develop design and 17 Mr. Savage, is this a copy of an October 2, 1972 memorandum 17 operating data for full-sized effluent pond? 18 sent to you and some others in the course of your 18 A That's what the objective of this project is, 19 employment with Monsanto? 19 that's right. 20 A Yes. 20 Q If you look to Exhibit 103, is that a memorandum 21 Q Could 1 direct your attention to the bottom of 22 the first page where it says " September rains were above 21 from you to Cliff Stutz and some others dated November 19, 22 1958 regarding pilot effluent pond? Page 410 Page 412 1 normal and probably was a factor in Pcb flow to waste 1 A Yes. 2 treatment plant as Pcbs from ground are leached with 2 Q Do these two documents relate to the same 3 rainwater." Do you see that? 3 project? 4 A Yes. 4 A Yes. 5 Q 1 asked several questions in the general area 5 Q Can you describe for me what the impetus was for 6 yesterday. Can you explain to me your understanding of why 6 undertaking this project with regard to a pilot effluent 7 September rains above normal would lead to the leaching of 7 pond? 8 Pcbs from the ground? 8 A Would you repeat that, please? 9 A Well, 1 don't recall that there was ever any 9 Q Could you describe for me what the impetus was 10 particular evidence of cause and effect here. So to some 10 for undertaking this project -- this project being 11 degree, this would be speculation on Mr. Stewart's part. 1 11 undertaken at the Anniston plant with regard to the pilot 12 think what he is speculating about is simply that there was 12 effluent pond? 13 enough Pcb material on the ground or in the ground that it 13 A There was an idea at the time that pond treatment 14 would be leached by an unusual flow of rainwater. 14 would be an economical way to treat the waste, reduce the 15 Q Do you know whether that was ever checked out, 15 waste load to an acceptable level to be discharged to the 16 the correlation between above-normal rainwater and leaching 16 city sewers for subsequent treatment by the city treatment 17 of Pcbs from the ground? 17 plant. 18 A 1 don't think there was ever any statistical 18 Q Do you know whether this project related to 19 study of that. Some anecdotal evidence is what it amounts 19 wastes from the Niran plant? 20 to. 20 A Yes. It certainly related to the Niran plant 21 Q Do you recall what anecdotal evidence? 21 since it refers to Pnp. That waste only came from the 22 A Like this. 22 Niran plant. Savage, James (Aroclor Dept employee) in AETNA (3) Pages 409 - 412 HARTOLDMONO010236 Page 413 Page 415 1 Q Before this pilot effluent pond project, do you 1 however." Do you recall there being an investigation of 2 know how those wastes were discharged? 2 whether Niran wastes were finding their way into Snow 3 A That was-the original design for the Niran 3 Creek? 4 waste was it would go through the limestone bed and then to 4 A No. But the remainder of this sentence is, 1 5 the city sewers and from there to the city waste treatment 5 think, reasonably convincing. It says there's not enough 6 plant. And that was still the practice at this time. 6 Pnp color in the water. Pnp is a material which creates a 7 Q So - 7 visible color and just one or two parts per million in the 8 A This work order is in July of 1958, which is only 8 water. So this statement on its face is fairly convincing. 9 three or four months after 1 arrived at Anniston. 9 Q Do you know whether it was ever determined where 10 Q So the pilot effluent pond was contemplated to be 10 that quantity of acid did originate from? 11 a step before the limestone bed? 1 mean the waste would go 11 A No, 1 don't remember. 12 to the pilot effluent pond before the limestone bed? 12 Q Let's go to Exhibit 102. First of all, do you 13 A As 1 recall it, it would go through the limestone 13 ever recall or do you recall receiving a copy of the cover 14 bed first and then to the pond. 1 didn't think the pond 14 memorandum? 15 was intended to carry the entire flow anyway, it was simply 15 A No, 1 don't remember that. 16 to take a side stream for test purposes. 16 Q That memorandum attaches a September 11, 1958 17 Q Do you recall testing being performed in Snow 17 progress report and you're listed as a copy recipient on 18 Creek in connection with this project? 18 that progress report; is that correct? 19 A The memo of November 19, Exhibit 103, seems to be 19 A Yes. 20 about two different subjects because the flow in Snow Creek 20 Q Do you recall there being a study undertaken by 21 is on the other side of the plant and as far as 1 know 21 Cliff Stutz in the September 1958 time frame regarding 22 there was no connection between that and Niran waste. And 22 Niran waste disposal at the Anniston plant? Page 414 Page 416 1 these flows, of course, are much larger than what the pond 1 A 1 know he was working on that subject at that 2 would have taken. I'm reasonably confident the second 2 time. 1 don't remember the structure of the study. 3 paragraph is a different subject. 3 Q Do you recall having any involvement in this 4 Q Do you recall what the impetus was for - this 4 study? 5 seems to refer to some sort of testing with respect to Snow 5 A Not specifically. During that time it was 6 Creek ; is that correct? The second paragraph of Exhibit 6 routine for me to take samples to the lab at Cliffs 7 103. 7 direction, and 1 presume that 1 would have done that, but 1 8 A The second paragraph is some data about flow in 8 don't remember doing it. 9 Snow Creek. The discussion here about a mark on the weir 9 Q There's a statement that" Studies are progressing 10 suggests that because the purpose of a weir is a way of 10 by Professor Jaffee on effects of other industrial wastes 11 measuring large flows in an open channel. 11 at Anniston." Do you see that? 12 Q Do you recall what the impetus was for the 12 A Yes. Excuse me. No, 1 don't. Where? 13 collection of that data regarding the flow in Snow Creek? 13 Q The second page of the exhibit. 14 A No. 14 A Yes, 1 see that. 15 Q Down below it talks about the " acidity of Stream 15 Q Were you aware of studies progressing by 16 No. 8, which is the ditch outside the fence." Do you know 16 Professor Jaffee concerning - 17 what that" Stream No. 8 " refers to? 17 A No, 1 don't remember who he is. 18 A No. It must relate to some kind of map but 1 18 Q 1 take it you don't recall having any dealings 19 don't know. 19 with him on the subject of waste disposal? 20 Q There's a statement down below that" This 20 A No. 21 represents a large quantity of acid and 1 do not know where 21 Q Let's go back to the first page. The subject of 22 it originates. It probably did not come from Niran, 22 that is " mercaptan odor," if 1 pronounced it correctly. Savage, James (Aroclor Dept employee) in AETNA (3) Pages 413-416 HARTOLDMONO010237 Page 417 Page 419 1 A Mercaptan. 1 A We did, in fact, later on take steps to improve 2 Q Mercaptan, thank you. What does that refer to? 2 the yield, meaning suppress the side reactions. But by the 3 A Mercaptans are a class of sulfur compounds that 3 time we achieved that the odor was no longer a problem. 4 are notoriously odorous. 4 Q What were the steps taken to improve the yield? 5 Q Do you recall there being mercaptan odors at the 5 A There were changes in the way the condensation 6 plant during this time frame? 6 step was operated, improvement and agitation in the vessel, 7 A There were odors that were characterized that 7 drying facilities for acetone, reduce the amount of water 8 way. Most chemists know what mercaptans smell like. 8 going to the condensation step. The water going to the 9 Without being very specific as to what particular mercaptan 9 condensation step turned out to be the cause of a side 10 it was, it was that kind of odor. 10 reaction and by reducing that, the yield improved. 11 Q Was that a frequent thing, for there to be 11 Therefore the amount of Pnp and so forth going to the sewer 12 mercaptan odors at the plant? For example, would you walk 12 was reduced. 13 in and be able to smell that? 13 Q What was the general time frame that that 14 A At the time of start-up and for a few months 14 situation was taken care of? 15 after start-up, that was common. 15 A 1 don't remember. It was during my time doing 16 Q You're talking about start-up of the Niran plant? 16 technical work in the Niran plant but 1 can't be any more 17 A Yes. 17 specific than that. 18 Q The cover memo contains a statement," There is 18 Q On the second page of the exhibit, that's the 19 one possibility which might result in a correlation between 19 first page of the progress report, there's a statement at 20 Pnp level and odor. This is side reaction in the 20 the bottom that" Pilot plant studies on treating Niran 21 condensation step. These would of course result in both 21 wastes in lagoons under way." Do you see that? 22 high unreacted Pnp and intermediate which would show up as 22 A Yes. Page 418 Page 420 1 soluble organics in the wash water. You may want to have 1 Q Does that refer to the same pilot project 2 Jim Savage look into this problem." Do you recall ever 2 referring to the effluent pond? 3 looking into that problem? 3 A 1 think that's the same project. 4 A No. 4 Q So there weren't separate projects for something 5 Q The reference to side reactions in the 5 called lagoon and something for -- 6 condensation step, what does that refer to? 6 A No, 1 think those were the same thing. 7 A The last step of chemistry in making parathion is 7 ( Savage Exhibits 104 and 105 identified. ) 8 a step that is called condensation. It's the reaction 8 Mr. Brock: I've marked Exhibits 104 and 105 for 9 between sodium paranitrophenate and the intermediate that 9 the record. 10 we discussed yesterday. What Fritz is talking about in 10 By Mr. Brock: 11 this paragraph is side reactions in that reaction which 11 Q Mr. Savage, is Exhibit 104 a copy of a June 17, 12 could interfere with the raw materials. 12 1959 memorandum from John Mullendore to Karl Edelblut with 13 Q Do you recall there ever being found a high level 13 a copy to you? 14 of unreacted Pnp and intermediate? 14 A Yes. 15 A That's a relative term as to " a high level of 15 Q And the arrow indicates that this was, in fact, a 16 unreacted Pnp." The Pnp that wound up in the waste leaving 16 copy that was sent to you? 17 the plant was unreacted Pnp from that step and 1 think that 17 A Yes. 18 what Fritz is doing in this paragraph is speculating as to 18 Q The subject is a telephone call from Jim 19 why that takes place, whether people are doing something 19 Standridge concerning odor at the municipal sewage 20 about it. 20 treatment plant. Do you see that? 21 Q Do you recall whether or not that hypothesis or 21 A Yes. 22 speculation was ever checked out? 22 Q Do you recall there being a phone call or phone Savage, James (Aroclor Dept employee) in AETNA (3) Pages 417 - 420 HARTOLDMONO010238 Page 421 Page 423 1 calls from Mr. Standridge concerning odors at the municipal 1 technical work that you described? 2 sewage treatment plant around this time? 2 A Yes. 3 A 1 can't place it in time. 1 know there were such 3 Q Do you recall specifically what his instructions 4 phone calls. 4 were to you? 5 Q Do you recall undertaking any activities to deal 5 A It began with his asking for some work to improve 6 with the concerns expressed in the phone calls? 6 the waste chlorinator and just routine discussion. We 7 A 1 remember doing technical work to solve the odor 7 would talk about the urgency of that work. 8 problem, which 1 knew was urgent, but 1 can't make a cause 8 Q Why was the work considered urgent? 9 and effect relationship between phone calls from 9 A The first waste chlorinator was installed on a 10 Mr. Standridge and the technical work. 10 crash basis and was made of vitrified clay sewer pipe, and, 11 Q Again, what was the technical work you did to 11 while it worked remarkably well, it was not mechanically 12 solve the odor problems? 12 sound and prone to leak and when it was leaking, sometimes 13 A Some improvements to the effluent chlorinator. 13 it could not be operated in a normal way and therefore what 14 Q There's a reference in the third paragraph, it 14 1 was doing was replacing it with one made of more durable 15 says " 1 asked him the status of the lawsuits of the people 15 materials and larger as well. 16 living around the treatment plant. There are seven 16 Q You referred to that as a vitrified clay sewer 17 individual suits with each party suing for 2500." 17 pipe? 18 A Yes. 18 A Yes. It was a small tower that had been put 19 Q Do you recall those lawsuits? 19 together just as something that could be done quickly. But 20 A No. 20 it was made out of materials that really were not intended 21 Q Do you believe that's a reference to the lawsuits 22 concerning paint damage to houses that you - 21 for that purpose. 22 Q Do you know when that clay sewer pipe had been 1 A No. Page 422 1 installed? Page 424 2 Q So you believe this is a separate 3 A The treatment plant was south of the city, 4 outside the valley. The houses that were alleged to be 2 A No. It was quite early in this period but 1 3 don't remember. 4 Q When you say" quite early," you mean the start-up 5 discolored were, 1 think, west of the plant within a half 5 of the Niran plant or earlier? 6 mile or so. So the two locations are separated by 3 or 4 6 A No. It was after the start-up of the Niran 7 miles. 7 plant, after the problem -- the odor problem was 8 Q Do you recall there being any lawsuits filed 8 discovered. 9 against Monsanto alleging odors from the Anniston plant? 9 Q When you say those pipes were bound to leak, how 10 A 1 don't remember that there were. 10 frequently would they leak? 11 Q It states " In closing the conversation, 1 asked 11 A 1 don't remember. 12 Standridge to ask Slovensky to notify either Jim Savage or 12 Q For example, would there be leaks more than once 13 me if he experiences problems either treatment or odor." 13 a month? 14 Do you recall being notified by Mr. Slovensky about 14 A 1 have no idea. 15 treatment problems or odor problems around this time frame? 15 Q In the second paragraph there's a statement," 1 16 A No, 1 don't recall having any contact directly 16 told him that Jim Savage had visited the treatment plant 17 from him. 17 the previous evening and was working with Jim Slovensky on 18 Q Do you recall having contact with people working 18 ways we could dove-tail our flow with the flows received 19 for him or at his behest concerning those subjects? 19 from other parts of the city to minimize problems and 20 A No. What 1 recall is that my instructions on the 20 treatment." And then it says "( not odor)." 21 subject came from John Mullendore. 21 A Yes. 22 Q And those instructions resulted in you doing the 22 Q Do you recall undertaking work along those lines Savage, James (Aroclor Dept employee) in AETNA (3) Pages 421 - 424 HARTOLDMONO010239 Page 425 1 to minimize treatment and problems -- or problems and 2 treatment other than odor? 3 A 1 don't remember that. 4 Q Let's go to Exhibit 105. Is this an engineering 5 department progress report regarding a mist eliminator and 6 scrubber for the incinerator at the Niran plant in 7 Anniston? 8 A Yes. Page 427 1 reinforced polyester fiberglass. 2 Q The term " mist eliminator and scrubber," after 3 the new equipment was installed, what exactly did that 4 consist of? 5 A You recall 1 previously used the term " Brink 6 demister." Mist eliminator is synonymous with that. 7 Q If you turn to the third page, reference number 5 8 or item number 5 is " Vapor between scrubber and mist 9 Q If you look on the right-hand column, your name 10 seems to be typed in without a specific box. Do you 11 recall- 9 eliminator will be analyzed by the plant for chlorides." 10 Do you see that? 11 A Yes. 12 A If you look just above my name, you'll see 13 there's a slash after Mr. Hedworth's name, so 1 think it 14 was the intention that that copy be for both of us. 15 Q What was a mist eliminator and scrubber for the 16 incinerator at the Niran plant? 17 A That was the equipment that was developed to 18 correct the problem with the P2o5 plume from the 19 incinerator stack. 20 Q Do you recall undertaking any work in connection 21 with this mist eliminator and scrubber project? 22 A Yes. 12 Q Were you involved in that? 13 A 1 would have been involved in taking the samples. 14 Q Do you recall there ever being found a problem 15 with the level of chlorides in that vapor? 16 A The fact that there was chlorides in the vapor 17 was not in itself a problem. It was an indication that the 18 chlorides could be expected to be collected as part of the 19 acid that was collected in the mist eliminator. 20 Q Was there a certain threshold for the level of -- 21 1 take it the mist eliminator would take out the chlorides 22 in the vapor, is that the way it worked? 1 Q What was the nature of your work? Page 426 1 Page 428 A The mist eliminator was there for the primary 2 A 1 operated the small pilot plant unit that was 3 used to prove the principle of that mist eliminator and 4 scrubber system and to generate the design data needed to 2 purpose of collecting the small aerosol particles, 3 phosphorus pentoxide, which in that situation, since it was 4 wet from the scrubber, would have been by then converted to 5 build the full-sized unit. 1 provided plant liaison for 6 installation of the original unit and replacement units 7 that were later on required. 1 collected operating data, 8 took samples, made studies to improve the reliability and 9 efficiency of the unit. 10 Q Who was O. A. Fenner, F-e-n-n-e-r? 11 A Otto Fenner was the corrosion specialist at the 12 Queeny plant. 13 Q Why was there a corrosion specialist involved in 14 this project? 15 A This particular progress report describes a 16 severe problem that was recognized after start-up of the 17 original full-sized mist eliminator and scrubber, it turned 18 out that the rubber lining in that equipment was being 19 attacked by the acid that was being collected and that 20 therefore the life of the equipment would be very short. 21 Q Do you recall what the new lining consisted of? 22 A The new equipment was not lined. It was 5 small droplets of phosphoric acid. The mist eliminator 6 would collect those tiny droplets of phosphoric acid and 7 any other water soluble materials that were present would 8 be absorbed into the phosphoric acid in the mist 9 eliminator. So the final answer to your question is yes, 10 the chlorides would be taken out and the mist eliminator 11 was somewhat 12 Q Was there a certain threshold for the level of 13 materials that could be reduced by the mist eliminator? 14 A I'm not sure 1 understand. 15 Q Do you understand with a I'm trying to get at? 16 A No. 17 Q For example, if the level of chlorides or aerosol 18 particles increased, was there a certain level above which 19 the mist eliminator was less effective at reducing or 20 taking out those particles? 21 A No. If there was an overload of, particularly of 22 phosphoric acid to the mist eliminator because we were Savage, James (Aroclor Dept employee) in AETNA (3) Pages 425 - 428 HARTOLDMONO010240 Page 429 Page 431 1 attempting to operate it at too high a rate, for instance, 1 February of 1960? 2 the way that would be manifested would be that the pressure 2 A Since 1 was a member of Tsd, 1 would have 3 drop would rise over the course of a couple of hours to the 3 responsibility for appropriation requests for projects of a 4 point that we couldn't continue to operate because the 4 size that could be handled at the plant, which generally 5 blowers couldn't generate enough pressure to overcome the 5 meant projects of less than $100,000. Since it was a small 6 pressure drop. 6 plant, it was very common, however, that we would cut off 7 Q Do you recall there ever being a time when there 7 at 40 - or $50,000 and any project bigger than that be 8 was concern expressed that the mist eliminator was not 8 handled by organic engineering. 9 being effective in removing particles in the vapors that 9 Q Who was J. P. Ekberg? 10 were sent to it? 10 A 1 don't recognize that name. 11 A Yes. What we found particularly on the first 11 Q Do you recall developing information with respect 12 couple of versus of the mist eliminator was that after a 12 to expansion of the Niran plant in or about February of 13 period of time, the efficiency fell off due to 13 1960? 14 deterioration of the glass fiber in the mist eliminator 14 A 1 don't remember the timing exactly but 1 did 15 cartridges and when that -- when the efficiency reached an 15 work with Bill Garlette to develop the data on our 16 unacceptable level, we would shut down and either put in 16 then-existing capacities in the various parts of the 17 new cartridges or repack the cartridges. 17 equipment so that decisions could be made as to which steps 18 Q When the efficiency of the mist eliminator fell 18 were the bottlenecks and therefore would have to be dealt 19 off, would those particles be released into the atmosphere? 19 with as part of an expansion. 20 A What you would then have was a situation similar 20 Q Let me ask you to turn to the second page of the 21 but of lesser extent, to the situation we had before we had 22 mist eliminator; some visible plume coming from the stack. 21 document, the page with Bates number 891. Under number 2, 22 the second paragraph starts with the sentence " The original Page 430 Page 432 1 Q Do you recall how frequently that happened after 1 design philosophy of isolation and remote operation of 2 the mist eliminator was installed? 2 hazardous units in the Niran Dept, will be continued in all 3 A We found that we always had to repack at 3 phases of this project." 4 intervals of less than one year. 1 remember six months but 4 A Yes. 5 1 can't be very precise about that. But at that point it 5 Q Do you know what those hazardous units were? 6 was a visible plume but a fairly tolerable one, nothing 6 A It was considered that each of the reactors 7 like the plume that existed before the mist eliminator was 7 required special treatment. To be more specific, the first 8 installed. 8 reactors there were thio acid reactors, that was the first 9 ( Savage Exhibit 106 identified. ) 9 step of the process, then there were chlorinators, then 10 Mr. Brock: I've marked Exhibit 106 for the 10 there were intermediate stills. There was still residue 11 record. The Bates numbers are Ann 1401890 through 898. 11 storage and a condensation reactor. All of those were in 12 By Mr. Brock: 12 isolated cubicles remotely operated. 13 Q Mr. Savage, could you let me know when you've had 13 Q Why were those referred to as hazardous units? 14 a chance to glance through this. 14 A Because there had been an explosion in the 15 ( Witness reviewed the document. ) 15 previous Niran unit at the Nitro plant and extremely 16 A Okay. 16 conservative design philosophy was adopted for the new 17 Q Is this acopy of appropriation request 17 plant at Anniston. 18 information sent to you and some others in connection with 18 Q Do you know when that explosion took place at the 19 your employment with Monsanto? 19 Nitro plant? 20 A Yes. 20 A Sometime in the summer of 1957. 21 Q What,if any, responsibilities did you have for 21 Q How did you learn about that explosion? 22 appropriation requests regarding the Niran plant in 22 A It was on the bulletin board and in the Savage, James (Aroclor Dept employee) in AETNA (3) Pages 429 - 432 HARTOLDMONO010241 Page 433 Page 435 1 newspapers. 1 was at the Queeny plant at the time. 1 A No, we recycled all the acetone. 2 Q Did you have any responsibilities with respect to 2 Q And the reference to H2s gas disposal, what did 3 dealing with that explosion? 3 that consist of? 4 A No. 4 A In the original design, H2s from a thio acid 5 Q You mentioned still residue storage, what did 5 reaction, first step, was piped to the incinerator 6 that consist of? 6 firebox. That was quite effective because it's easy to 7 A The distillation generated the still residue, 7 burn hydrogen sulfide. But that represented additional 8 which was to be fed to the incinerator. However, the 8 load on the firebox and therefore, both as a 9 stills operated batchwise and then, therefore, would 9 debottlenecking step and to improve the flexibility of 10 generate a significant increment of still residue at the 10 operations, at some point the H2s gas was disposed of with 11 end of each batch, whereas the incinerator ran continuously 11 a flare mounted at the top of the old stack rather than 12 at a slow rate. So there had to be a place to hold still 12 burning it in the firebox. 13 residue for feed to the incinerator. 13 Q Do you recall any times when the load of the H2s 14 Q Do you know whether anything was ever done with 14 gas on the firebox was such that not all of the H2s gas was 15 that still residue other than send it to the incinerator? 15 incinerated? 16 A No. 16 A 1 remember the incidents in which the H2s load to 17 Q There's a statement that" certain auxiliary 17 the firebox was larger than it should have been, but the 18 operations will be upgraded in order to improve operating 18 consequence was not that the H2s was not burned but rather 19 efficiency. Among these are soda ash handling, drying of 19 that a peculiar side reaction occurred which resulted in 20 recovered acetone, and H2s gas removal." Do you see that? 20 sulfur, elemental sulfur being formed in the firebox which 21 A Disposal, yes. 22 Q Disposal. I'm sorry. 21 plugged up the demister. 22 Q And what would happen when the demister was Page 434 Page 436 1 Mr. Brock: Off the record. 1 plugged? 2 ( Discussion off the record. ) 2 A It would be a partial pluggage and we would have 3 By Mr. Brock: 3 to slow down the operation of the incinerator and the 4 Q Let's start with soda ash handling. What did 4 demister for a period of time, perhaps a day or so while 5 that consist of or what did that entail at the plant? 5 the system cleaned itself up. The acid coming out of the 6 A As 1 mentioned previously, the original design 6 demister cartridges would eventually wash the sulfur off 7 was that soda ash was received in bags and those bags were 7 the outside. 8 manually dumped into a tank. What this refers to is an 8 Q Were there occasional releases of sulfur to the 9 essentially mechanical project to automate that, eliminate 9 environment as a result of that? 10 the labor-intensive step. 10 A Sulfur is a solid. It doesn't go anywhere. It's 11 Q And the drying of recovered acetone, what did 11 insoluble in water. 12 that entail? 12 Q If we go to the next page, the page that ends in 13 A It's my recollection that at the time that this 13 Bates number 892, there's a discussion with the letter c. 14 was written, we were already drying acetone by contact with 14 It talks about this project providing for a complete new 15 calcium chloride. That was not considered to be a very 15 chlorinator system and a complete new intermediate still 16 efficient way of doing it. And what 1 recollect is that 16 system. Can you tell me what the intermediate still system 17 this expansion project, or expansion project that resulted 17 consisted of? 18 from this report was the occasion when a drying column was 18 A Yes, that was the second step of the process -- 19 installed to replace the calcium chloride dry. 19 excuse me, third step, 1 guess. After the chlorination 20 Q The reference here is to recovered acetone, was 20 step the material we called intermediate, ethyl Pc-2 or 21 there also acetone which was a residue of the Niran plant 21 methyl Pc-2, would be distilled and that piece of equipment 22 process? 22 was called the intermediate still. Savage, James (Aroclor Dept employee) in AETNA (3) Pages 433 - 436 HARTOLDMONO010242 Page 437 Page 439 1 Q Why was it contemplated that there would be a 1 Q First of all, was that your understanding at the 2 complete new intermediate still system at that time? 2 time? 3 A In the original design there were two 3 A Yes. There had been appropriate tests run, 4 chlorinators and two stills, each chlorinator was paired 4 animal tests run on finished product and various 5 with a still, operated together as a unit batchwise. So to 5 intermediates. We had that data. So we understood the 6 expand we simply added a third chlorinator still system. 6 materials reasonably well. 7 Q Do you recall the reason why it was felt there 7 Q Do you know when those animal tests were run? 8 should be three chlorinator still systems rather than two? 8 A No. 9 A Well, that was 50 percent more capacity. 9 Q Do you know who it was that had run them? 10 Q Let me ask you to turn to the pages that end in 10 A The testing on parathion itself had been done 11 Bates numbers 897 and 898. There's a heading " pollution 11 many years ago. It was known to be very toxic material. 12 and toxicity problems." Do you see that? 12 Q Do you know whether those tests were run by 13 A Yes. 13 somebody outside of Monsanto or within Monsanto? 14 Q Do you recall addressing any pollution or 14 A Both. 15 toxicity problems in connection with your work with respect 15 Q And both had found the material to be toxic? 16 to the Niran expansion? 16 A Of course. 17 A 1 don't remember anything specific. This section 17 Q Was that information compiled somewhere within 18 in this report would be just a normal topic to cover such a 18 Monsanto, the hazards from toxic materials in those 19 report. 19 operations? 20 Q Why was that? 20 A 1 believe so. It would be normal, for instance, 21 A It would be routine in studying a question of 21 that the standard manufacturing process would include a 22 expansion to consider whether there were any new problems 22 material hazard data sheet on each one of the materials 1 in toxicity or pollution. Page 438 Page 440 1 used in the process, even those that are ordinarily items 2 Q There was a general recognition that the 3 chemicals involved in the Niran operations could present 4 some pollution and toxicity problems, is that a fair 2 of commerce. 3 Q At the end of the memo there's a reference to 4 " provision of means for disposal of' runaway ' batches of 5 statement? 6 A Well, since the product itself is extremely 7 toxic, of course. 8 Q Under" Atmospheric" it states " Total discharge of 9 wastes to the atmosphere from incineration of liquid 10 residues and H2s gas will increase by 50 percent." Do you 11 recall there being any concerns expressed about that 12 increase? 13 A No. That was simply a direct proportion to the 14 increase in production. 15 Q Do you recall there being any complaints about 16 increased liquid residues and H2s gas being discharged from 17 the plant around that time? 18 A No. 19 Q On the next page under the " Toxicity" heading it 20 states " Hazards from toxic materials in the Niran-methyl 21 parathion operation are well established." 22 A Yes. 5 material." Do you see that? 6 A Yes. 7 Q What were '" runaway ' batches of material"? 8 A The materials handled at several steps of the 9 process were thermally unstable and it was possible, either 10 because of an error in operation or because of a failure in 11 control systems, for temperatures to go above normal and if 12 that was not properly anticipated and dealt with - the 13 temperature is called an autothermal decomposition, meaning 14 that the decomposition generates heat and as the 15 temperature rises - the decomposition reaction 16 accelerates. It was known that that was possible. We had 17 instances of that having happened, so it was important that 18 the design provide for handling incidents like that. 19 Q How was that material disposed of? 20 A Most of the time that was pumped to the still 21 residue hold tank and incinerated. If the batch actually 22 ran away and an overpressure occurred, then it would wind Savage, James (Aroclor Dept employee) in AETNA (3) Pages 437 - 440 HARTOLDMONO010243 Page 441 Page 443 1 up in the water trench under the reactors. That happened a 1 while 1 was doing technical work in the parathion group. 2 few times. 2 Q When you say when you were doing " technical 3 Q Where did that water trench go? 3 work," do you mean before you became production supervisor? 4 A Normally didn't go anywhere. There was a static 4 A That's right. 5 trench full of water and it would normally just be there to 5 Q Do you recall working on such a project with W. B. 6 be available in case there was a discharge, other than 6 Dunlap and J. C. Larkin? 7 occasionally to change it if it became stagnant. It would 7 A Bill Dunlap was an engineer working in Tsd. At 8 get frogs in it and so forth. 8 this time, Mr. Larkin had replaced Mr. Hedworth as the head 9 Q When that water was changed, where was it taken? 9 of Tsd and his name in parentheses just means that's our 10 A It would be pumped to the -- into the sewers and 10 boss. The study in this report appears to be mostly 11 go to the limestone back. 11 analytical and statistical and probably was mostly 12 Q 1 thought you said there were several incidents 12 conducted by Mr. Dunlap. Statistics, at that point, was 13 that you recall involving runaway batches of materials? 13 his specialty. He had previously been the chief chemist at 14 A Yes. 14 the plant. 15 Q Can you describe what you recall about those for 15 Q What would your involvement have been? 16 me? 16 A 1 don't remember this study specifically but Bill 17 A Those were very notorious occasions, 1 think 1 17 and 1 worked together on a number of studies and the way we 18 described one or two of them yesterday, but in general 18 worked was that 1 would give him process guidance as to 19 those involved an instrument failure or an equipment 19 what to look for and then he would generate statistical 20 failure. 1 can't give you a detailed reconstruction of any 20 data and try to find a correlation to connect causes and 21 more than what I've previously mentioned. They were always 21 effects. 22 studied in great detail and some action was always taken 22 Q There's a statement under the second paragraph Page 442 Page 444 1 to -- usually it was a further elaboration of the control 1 under the summary," The major waste component is acetone. 2 system to try to head off a recurrence of the thing that 2 Acetone and Pnp originating in the washing operation 3 had just occurred. 3 account for the bulk of the load of the treatment plant." 4 Q On those occasions, what material was it that was 4 Do you see that? 5 constituting the runaway batches of material? 5 A 1 see that. 6 A The ones that 1 recall occurred in the 6 Q What was the washing operation? 7 chlorinators and the stills. 7 A At the end of the chemistry in the process, the 8 Q What was the material? 8 last step being condensation, there would be by-products 9 A That would be crude ethyl or methyl Pet. 9 present in the crude reaction mass, including sodium 10 ( Savage Exhibit 107 identified. ) 10 bicarbonate and so forth. So there was a substantial 11 Mr. Brock: I've marked Exhibit 107 for the 11 amount of water soluble material. Some of it solid in that 12 record. The Bates numbers are Ann 1402440 through 445. 12 reaction step, and that was separated from the product by 13 By Mr. Brock: 13 washing. 14 Q Mr. Savage, is this a Tsd progress report that 14 Q And how was acetone waste created in that 15 you worked on in connection with your employment with 15 process? 16 Monsanto at the Anniston plant? 16 A Acetone was used as a solvent in the condensation 17 A Yes, it appears to be. 17 step, and at the end of the condensation step acetone was 18 Q Do you recall undertaking the project to identify 18 distilled off for recycle, first at atmospheric pressure 19 the major components of parathion waste streams and 19 and then under a vacuum. If that was not 100 percent 20 locating their source in or about the 1961 time frame? 20 efficient, then there would be some acetone left in the 21 A 1 can't identify the time frame but that was a 21 crude reaction mass that went to washing. Since acetone is 22 subject that in general we worked on nearly all the time 22 water soluble, it would be extracted from the parathion and Savage, James (Aroclor Dept employee) in AETNA (3) Pages 441 - 444 HARTOLDMONO010244 Page 445 Page 447 1 wind up in the spent wash water. 1 from what? 2 Q What was done with it on those occasions? 2 A Well, if there were an excessive load, it would 3 A The spent wash water was the largest component of 3 be because something had not worked right in the plant, 4 waste flow going to the sewers, not in terms of gallons but 4 that there had been an incident or a period of time when 5 in terms of pounds of Bod. 5 yields were lower than normal. The importance of this 6 Q And how would Pnp wastes originate from that -- 6 relates to the problem of -- the problems an additional 7 the washing operations? 7 load would impose on the waste treatment plant. 8 A Because the reaction between the ethyl or methyl 8 Q Do you recall there being warnings or instances 9 Pet and sodium paranitrophenate did not go to 100 percent 9 of excessive loads in the waste streams from the Niran 10 completion. There would be some unreacted sodium 10 plant? 11 paranitrophenate in the crude reaction mass and under the 11 A I'm stuck on semantics here. There certainly was 12 conditions of washing, that would be extracted into the 12 variability in the load and that was a bit of a challenge 13 wash water and at that ph would become Pnp paranitrophenol 13 in successfully operating our waste treatment plant after 14 rather than sodium paranitrophenate. We referred to the 14 we had one. There was a potential that a really massive 15 presence of sodium Pnp and Pnp kind of interchangeably 15 overload would interrupt treatment in the -- that the 16 because what form the material was in was just dependent on 16 treatment plant would simply stop working but 1 don't 17 ph. So leaving the wash column it would be sodium Pnp but 17 remember that happening. 18 by the time it had mixed with other more acid wastes it 18 Q The reference to excessive loads -- 1 mean, in a 19 would be present as Pnp mostly by the time it got to the 19 Tsd progress report such as this, what would that reference 20 sewer. 20 mean? 21 Q On the next page, number 4 refers to a study 21 A 1 don't know. This was -- Bill authored this and 22 being contemplated to identify the minor components 22 I'm not sure 1 know what he means by that. Page 446 Page 448 1 locating their source and reducing their contribution to 1 Q For example, if we turn to table 1, 1 saw a 2 department waste load. Do you recall there being such a 2 reference there earlier in the document to a flow sheet of 3 study? 3 all waste sources. Is this what is referred to as a flow 4 A Not specifically. 1 certainly don't think we 4 sheet of waste sources? 5 ever identified the minor components. 5 A No. A flow sheet is normally a graphical 6 Q Did you have an understanding as to what the 6 diagram. 7 minor components of the waste load were? 7 Q Under the, for example, the acetone column, there 8 A We had a general idea based on the chemistry, but 8 are some references to 30,000 parts per minute -- or 30,000 9 not on analysis. 9 parts per million, I'm sorry, and there's a figure down 10 Q What would be your general idea based on the 10 below for 40,000 parts per million. Do you see those 11 chemistry? 11 figures? 12 A Hydrolysis products of the intermediate. 12 A Yes. 13 Q What would those be? 13 Q Would those figures be considered excessive? 14 A 1 don't remember. 14 A 1 have no idea. 15 Q If you turn to the page that ends in Bates number 15 Q If there were excessive figures on this, would 16 443. Under the heading of" monitoring the waste streams " 16 you recognize -- would you be able to recognize it? 17 there's a reference to a possibility of being warned of 17 A No, 1 don't recollect the meaning of those load 18 excessive loads. Do you see that? 18 numbers to the extent that 1 could tell you what was 19 A Yes. 19 excessive. 20 Q Do you recall any instances when there were 20 ( Recess. ) 21 excessive waste loads from the -- strike that. 21 ( Savage Exhibit 108 identified. ) 22 The reference to excessive loads, excessive loads 22 Mr. Brock: I've marked as Exhibit 108 Monsanto's Savage, James (Aroclor Dept employee) in AETNA (3) Pages 445 - 448 HARTOLDMONO010245 Page 449 Page 451 1 paragraph 1. a submission concerning the Anniston plant. 1 shop at the plant at the time that 1 was there. 2 By Mr. Brock: 2 Q If you look on Exhibit 46, a little bit south of 3 Q Mr. Savage, let me ask you to just read the first 3 the central shop there's a building that's referenced as 4 page of this, the description of the solid waste landfill 4 the Santowax Hb-40, do you see that? 5 area to yourself and let me know when you've had a chance 5 A Yes. 6 to do that. 6 Q During your tenure at the plant, were the 7 A You're referring to item 1? 7 Santowax operations at another location at the plant? 8 Q Yes. 8 A No, Santowax and Hb-40 were in approximately that 9 A Yes, I've read it. 9 spot. It's probably the same place. 10 Q Were you familiar with a landfill associated with 10 Q Where was the landfill that you're talking about 11 the Anniston plant? 11 in reference to that building? 12 A During the time 1 was there 1 walked around most 12 A To the northwest. 13 of the property and 1 was aware of several areas that had 13 Q What's on the map now where -- or what's on the 14 been used as landfill. I'm not sure from this description 14 map on Exhibit 46 where that landfill was during your 15 1 know exactly which piece of property is being referred 15 tenure at the plant? 16 to. The Anniston plant property, as 1 recall, is something 16 A 1 can't be very accurate. It was somewhere in 17 like four or five hundred acres, most of which is across 17 the area marked " central shop " or above that to the west, 1 18 the highway from the main part of the plant. Maybe it's 18 think it says Pnp. It was somewhere around there but none 19 less than that, 1 don't remember. It's quite a long time 19 of the things that are shown on this map existed when 1 was 20 ago. No, that's too much. It was less than that. But at 20 there in that area so 1 can't be very accurate about it. 21 any rate, the larger part of the real estate was actually 21 Q What materials were disposed of in that landfill 22 across the highway from the main part of the plant. 22 area during your tenure at the Anniston plant? Page 450 Page 452 1 Q Were -- when you say you were familiar with a 1 A The only thing 1 can recollect is various 2 number of pieces of land that were used as landfills, did 2 Santowax materials, fractions and still residues. Some of 3 you visit each one of those? 3 that, as a matter of fact, turned out to be valuable during 4 A To say 1 visited them is making it a little more 4 the time 1 was there and some of it was dug up and 5 specific than it was. Simply in walking around the 5 redistilled. 6 property at various times, 1 would observe that areas were 6 Q What were Santowax fractions? 7 being used as landfill. 7 A When biphenyl was produced, a substantial 8 Q And those areas were across the highway? 8 by-product stream which is just generally called Santowax. 9 A One of them was. 9 Originally it was considered a by-product but eventually a 10 Q Where was the other one? 10 substantial product line was developed using terphenyl, 11 A Near the Santowax department inside the plant. 11 which is the main component of Santowax, and we eventually 12 Q Let's go to Exhibit 46, it's the map of the 12 began operating the biphenyl furnaces in a different 13 plant. 13 fashion to deliberately increase the relative proportion of 14 A Okay. 14 this group of materials we generally called Santowax and 15 Q The landfill area that was near the Santowax 15 that, in fact, occurred after my time at the Anniston plant 16 department inside the plant, can you indicate for me on 16 but during the time that 1 was manufacturing manager, much 17 Exhibit 46 where that was during your tenure at the 17 later. 18 Anniston plant? 18 But at any rate, the Hb-40 department, for 19 A This map appears to have been drawn considerably 19 instance, used refined Santowax, which is mostly terphenyl, 20 after my time at the Anniston plant. What 1 recall is the 20 as a raw material and the so-called solid Aroclors used 21 area where there's Santowax somewhere to the west of the 21 Santowax as a raw material. But there were some other 22 block marked " central shop." There was no such central 22 materials that were considered waste at various times in Savage, James (Aroclor Dept employee) in AETNA (3) Pages 449 - 452 HARTOLDMONO010246 Page 453 Page 455 1 the history of the plant that at other times were 1 anything under that, 1 don't know. 2 considered valuable raw materials. 2 Q Was that landfill done away with at some point in 3 Santowax itself, so-called Santowax R, which is 3 time that you recall? 4 casually called terphenyl, is in fact a mixture. The two 4 A At the time that 1 began visiting the Anniston 5 biggest components, as 1 recall, are ortho and 5 plant again in the early ' 70s it's my recollection it 6 paraterphenyl, which are specific compounds, specific 6 wasn't there anymore, but I'm not sure of that. 7 isomers. There's also some meta terphenyl present and some 7 Q Do you have an understanding as to why that 8 higher polyphenyls and usually that was mostly quaterphenyl 8 landfill was done away with? 9 but we later on learned that we could distill further by 9 A 1 have no idea. 10 putting the still residue and isolate quaterphenyl and use 10 Q Were there other materials that were disposed of 11 it as raw material and the impurity in it was 11 in that landfill besides Santowax fractions? 12 quinquephenyl, which is a whole bunch of different isomers, 12 A 1 don't think so. 13 but all five benzene rings. 13 Q Do you know how far back the practice of 14 So at various times in history that stream was 14 disposing of Santowax fractions in that landfill dated? 15 taken apart in different ways and in the ' 50s there was a 15 A It substantially predates the time 1 was at the 16 particular mix of terphenyl isomers that was marketed as an 16 plant but 1 don't know any more than that. 17 organic coolant in nuclear reactors. Such a reactor was 17 Q Who was it that disposed of the Santowax 18 built in Canada, supplied from Anniston. So the fractions 18 fractions in the landfill? 19 left from shuffling these different isomer streams in 19 A 1 don't know. 1 never had any responsibility for 20 different ways were disposed of in this area and if their 20 the Santowax department while 1 was at the plant. 21 value changed later on, they might be dug up and distilled. 21 Q Do you know whether there were any steps taken by 22 Q What form did those fractions generally take? 22 Monsanto to prevent the migration or leaching of materials Page 454 Page 456 1 A They were dry, waxy solids, substantially 1 into the ground or water from that landfill? 2 unsoluble in water. 2 A No. No reason why 1 would know anything about 3 Q And how were they disposed of in the landfill 3 that. 4 area at the plant during your tenure there? 4 Q How did you become familiar with the other 5 A 1 only observed this a few times but there was 5 landfill, the landfill that was across the highway? 6 some kind of a container, and 1 don't remember what it was, 6 A There was an old rifle range in a little flat 7 but some kind of a container would be taken from the 7 area. The area across the highway was the slope of one 8 Santowax department to this area and material would run out 8 side of a mountain ridge and as 1 recall it was called 9 as a liquid and solidify immediately. 9 Horse Block Mountain and there was a flat area part way up 10 Q When you say it would " run out as a liquid," are 10 the slope that had been used as a rifle range and 1 went up 11 you talking about emptying it into the landfill? 11 there and used it for that purpose a few times. 12 A Yes. 12 Q When you were up there, you would see the 13 Q How big was that landfill? 13 landfill? 14 A 1 don't remember that it was very large, probably 14 A 1 saw that there was a landfill. The part that 15 75 or 100 feet on a side. 1 don't remember exactly. 15 was visible, as 1 recall it, from the rifle range area was 16 Q Was it square, round? 16 not at use at that time. 17 A It was irregularly shaped, as 1 recall. 17 Q What time frame was this? 18 Q Do you know what the bottom of it consisted of? 18 A That would have been in 1958, 1959. 19 A 1 have no idea. 19 Q Was that a landfill that had been in use earlier? 20 Q For example, do you know whether it was paved or 20 A It appeared to be an old landfill but 1 don't 21 lined in any way? 21 know. 22 A All 1 ever saw was dirt but whether there was 22 Q What did you see? What did that landfill look Savage, James (Aroclor Dept employee) in AETNA (3) Pages 453 - 456 HARTOLDMONO010247 Page 457 Page 459 1 like? 1 acid. 2 A 1 don't remember very much about it. It was kind 2 Q During your tenure at the Anniston plant, what 3 of a pit and 1 recall that there were some drums visible 3 did the wastewater flow from the parathion department to 4 but 1 didn't take particular notice of it so 1 don't 4 that limestone bed consist of? 5 remember any more than that about it. 5 A Do you mean in terms of origin or in terms of 6 Q When you say" drums visible," were there drums 6 chemical components? 7 sticking out of the ground? Were they laying on the 7 Q Well, let's start with chemical components. 8 ground? 8 A Certainly Hcl was present as dilute muriatic acid 9 A 1 don't remember. 9 in waste. There was quite a lot of sodium chloride or salt 10 Q How big was that landfill? Was that landfill -- 10 and there was sodium bicarbonate, sodium paranitrophenate 11 would that landfill have been 30 acres or thereabouts? 11 and some phosphorus compounds that were hydrolysis products 12 A 1 don't know. 12 of the intermediate material. Those are the ones that 13 Q Do you know what wastes or materials were taken 13 occur to me right now. 14 to that landfill? 14 Q And the phosphorus compounds, how did those 15 A No. 15 result from the - how did those come to be in the 16 Q Are you familiar with an approximately 30-acre 16 wastewater from the parathion operations? 17 landfill that the Anniston plant began using in the 1950s? 17 A They came from incomplete reaction at the 18 A No. 18 condensation step and subsequent hydrolysis of those 19 Q Are you familiar with any landfill to which 19 materials possibly in the condensation step or later on in 20 wastes from the parathion department were shipped? 20 the washer system. 21 A No. 21 Q How frequently, if you know, would those 22 Q Let's go to the second page of Exhibit 108. 22 materials come to be in the wastewater? Page 458 Page 460 1 There's a discussion there of a limestone bed, do you see 1 A Continuously. 2 that? 2 Q So there were always phosphorus compounds in the 3 A Yes. 3 wastewater? 4 Q That's the limestone bed or pit that we've talked 4 A The wash column operated continuously and was 5 about? 5 on-stream 80 or 90 percent of the time. 6 A Well, we've talked about two different limestone 6 Q And the sodium paranitrophenate, if 1 pronounce 7 beds. From the context of this paragraph it says it was - 7 it correctly, how would that come to be in the wastewater 8 it mentions parathion and paranitrophenol. 1 presume that 8 from the parathion operations? 9 this means the limestone bed associated with the Niran 9 A Same way. It was from an incomplete reaction in 10 department. 10 the condensation step subsequently washed out in the wash 11 Q What was your understanding of the function of 11 column. 12 that limestone bed? 12 Q And again, that would be something that happened 13 A The function was to neutralize acid in the stream 13 every time there was wastewater from the parathion 14 entering it. 14 operations? 15 Q Did you have the understanding that the limestone 15 A That happened at any time that the wash column 16 bed would remove any other materials from wastes sent there 16 was running, which was most of the time. 17 other than acidity? 17 Q Do you know whether any steps were taken to 18 A The purpose wasn't to remove anything. In 18 prevent the migration or leaching of those materials in the 19 neutralizing acidity, the alkaline materials in the 19 wastewaters from the limestone bed? 20 limestone would react with the acid material present, which 20 A 1 remember seeing the design drawings for the 21 in that case was predominantly Hcl. Nothing was thereby 21 limestone bed which showed a membrane below the earthen 22 removed. It was simply reacted so it would no longer be 22 surface at the bottom of the trench. But that had been Savage, James (Aroclor Dept employee) in AETNA (3) Pages 457 - 460 HARTOLDMONO010248 Page 461 Page 463 1 built before my arrival at Anniston, so 1 don't remember 1 1 don't know whether they did it in this particular case. 2 ever seeing -- it's called either a membrane or a lining. 2 By Mr. Brock: 3 The design for such a thing was the excavation that would 3 Q Did you ever hear or learn of any occasions on 4 exceed the final size of the bed, so that the lining or 4 which such a membrane had not prevented the leaching or 5 membrane could be put down and then a layer of clay put on 5 migration of chemicals from the limestone bed into the soil 6 top of that to protect it. 6 or water? 7 Q In what context did you see those design 7 A No, 1 don't remember hearing of that. 8 drawings? 8 Q Are you aware of any repair projects that needed 9 A All of the design drawings for the Niran 9 to be done with respect to the limestone bed or the 10 department were available to me and 1 was the custodian of 10 membrane? 11 those drawings after organic engineering left the site and 11 A 1 don't remember such a project. 12 1 routinely studied those drawings at any time that 1 was 12 Q If you look at Exhibit 108, there's a statement 13 attempting to do any kind of a study or modification of the 13 that analysis has indicated that" parathion and 14 plant. 14 paranitrophenol have entered the groundwater from this 15 Q Do you know who generated those drawings? 15 facility." It's on the second page of the exhibit under 16 A They were generated by the organic engineering 16 the heading " limestone bed." 17 department in St. Louis. 17 A Yes. 18 Q Do you know when they were generated? 18 Q Did you ever hear or learn that parathion had 19 A They were generated during the time that the 19 entered the groundwater from the limestone bed? 20 plant was being designed, which would have been the latter 20 A No, 1 don't remember hearing that or learning of 21 half of 1957. 21 it. 22 Q When you say the organic department in St. Louis, 22 Q During your employment with Monsanto, did you Page 462 Page 464 1 do you have any particular people in mind? 1 ever have any responsibilities for the paranitrophenol 2 A Organic engineering department. Fritz Rosenberg 2 department? 3 was the leader, Bill Garlette was the process engineer. 3 A No. 4 The drawings would actually have been prepared by draftsman 4 Q Did you ever hear or learn that paranitrophenol 5 or mechanical engineers working at the direction of 5 had entered the groundwater from the limestone bed? 6 Mr. Rosenberg or Mr. Garlette. 6 A No. 7 Q Do you know what type of membrane was called for 7 Q Were you aware of wastes from the paranitrophenol 8 in the limestone bed? 8 department being sent to the limestone bed? 9 A No, 1 don't remember. 9 A No. 1 had nothing to do with that operation. It 10 Q Do you know whether such a membrane was in fact 10 was built after 1 left. 11 installed? 11 Q You mentioned another limestone bed. Where was 12 A Oh, 1 think it was. The plant in its entirety 12 the other one? 13 was built from those drawings. 13 A The other one was the one in the front yard that 14 Q Were there inspections of that membrane? 14 discharged into Snow Creek. 15 A 1 don't know. 15 Q If 1 remember your testimony correctly, that was 16 Q If there had been inspections, whose 16 where the wastewater from the Aroclor department went? 17 responsibility would that have been? 17 A Yes. 18 Mr. Burnett: Objection. Lack of foundation. 18 Q Do you know what, if any, wastes from any other 19 You can answer, if you can. 19 departments went there? 20 The Witness: Inspections of equipment in general 20 A Muriatic department, department wastes, muriatic 21 were the responsibility, the joint responsibility of the 21 acid department wastes went in that direction. Anything on 22 production supervisor and the maintenance supervisor. But 22 that side of the plant would have gone in that direction Savage, James (Aroclor Dept employee) in AETNA (3) Pages 461 - 464 HARTOLDMONO010249 Page 465 Page 467 1 because there was a high place in the middle of the plant 1 entering the soil or groundwater from that limestone bed? 2 that would keep it from going to the other side. 2 A I'm not quite sure howto answer that. During my 3 Q What were the wastes that went there from the 3 time as manufacturing manager, we were routinely measuring 4 muriatic acid department? 4 the Pcb content of the water leaving the limestone bed to 5 A There was a large water flow from the muriatic 5 enter Snow Creek and 1 wouldn't characterize the water 6 acid department which would contain dilute Hcl, muriatic 6 itself as being groundwater, but since Snow Creek was 7 acid. 7 simply an open channel through clay soil, 1 suppose that 8 Q Anything else? 8 was a path the groundwater took. 9 A If there were any Aroclor entrained in the Hcl 9 Q That's fair enough. 1 should have excluded other 10 going from the Aroclor department to the muriatic acid 10 than the passage to Snow Creek. Are you aware of any 11 department, that material might find its way to that sewer. 11 concern that had been expressed? 12 Q When you say might, why do you use the term 12 A 1 don't remember that as a specific concern. 13 " might"? 13 Q Are you aware of any instances in which before 14 A Because of the flows in the department. The gas 14 the Pcb problems arose any investigations or studies into 15 flow went first to the muriatic acid absorber, so one would 15 whether materials were migrating or leaching into the soil 16 expect that if there were Aroclor in the Hcl, it would be 16 or groundwater from that limestone bed, other than to Snow 17 collected with the crude muriatic acid and then absorbed in 17 Creek? 18 the carbon treatment before the muriatic acid was shipped. 18 A No, 1 don't remember any study like that. 19 Q Do you know whether that limestone bed was lined? 19 Q If you look on the second entry, li of Exhibit 20 A It eventually was, but whether the original 20 108 there's an entry for Snow Creek. Do you see that? 21 version of it was or not, 1 don't know. 21 A Yes. 22 Q When you say eventually -- 22 Q And it says " Pcbs from the Aroclor unit were Page 466 Page 468 1 A I'm referring to my time as a manufacturing 1 found in sediments of Snow Creek and a related drainage 2 manager. 1 know that we had some projects to improve or 2 ditch downstream of the Monsanto plant." Do you see that? 3 possibly replace the limestone bed and enlarge it. My 3 A Yes. 4 recollection is that there was a lining in that one, but 4 Q Do you recall Pcbs from the Aroclor unit being 5 whether there had been a lining earlier, 1 don't know. 5 found in the sediments of Snow Creek? 6 Q What was the impetus for the project to improve 6 A No, 1 don't remember anyone making such a 7 or replace it? 7 measurement during my time. 8 A 1 don't remember. 8 Q I'm not just restricting it to the time you were 9 Q Did you have any involvement in that project? 9 at the Anniston plant. 10 A 1 probably approved it because that would have 10 A Or as a manufacturing manager, 1 don't recall 11 been the sequence for capital approval for such a project. 11 that. 12 Q One of the improvements was putting in a lining? 12 Q You don't recall that ever being brought to your 13 Mr. Burnett: Objection. 13 attention? 14 By Mr. Brock: 14 A We were quite concerned about the Pcb content of 15 Q Was one of the improvements putting in the 15 the water itself going to Snow Creek, of course. 16 lining? 16 Q But you're not aware of any time during which 17 A The new bed had a lining, but whether that 17 Pcbs were found in the sediments in Snow Creek? 18 represents a change from the previous design, 1 don't know. 18 Mr. Burnett: Asked and answered. 19 Q Either during the time that you were at the 19 You can answer it again. 20 Anniston plant or during your time as manufacturing 20 The Witness: 1 don't know. 21 manager, are you aware of any concerns that had been 21 By Mr. Brock: 22 expressed with respect to the possibility of materials 22 Q When did you first become concerned about the Pcb Savage, James (Aroclor Dept employee) in AETNA (3) Pages 465 - 468 HARTOLDMONO010250 Page 469 Page 471 1 content of the effluents to Snow Creek? 1 waste treatment processes used by Monsanto were obtained 2 A When 1 became manufacturing manager and the 2 from Mr. J. Savage, chemical engineer, Monsanto Chemical 3 Anniston plant became part of my responsibility. 3 Company, Anniston, Alabama ; and Mr. C. N. Studz, sanitary 4 Q Was that just as part of the overall Pcb 4 engineer." Do you see that? 5 situation you were addressing? 5 A Yes. 6 A Yes. 6 Q Do you recall collecting or providing such 7 Q There's a reference to Pcbs being found in a 7 production and waste treatment information in connection 8 drainage ditch downstream of the Monsanto plant. Do you 8 with investigation concerning the fish kill? 9 recall hearing or learning that Pcbs had been found in a 9 A No. Information about production on waste 10 drainage ditch? 10 treatment processes is something 1 would have known without 11 A No, 1 don't know what ditch that refers to. 11 having to investigate, so 1 would have been the logical 12 ( Savage Exhibit 109 identified. ) 12 person to ask, but 1 don't remember doing so. 13 Mr. Brock: I've marked as Exhibit 109 a 13 Q During the time that you were at the Anniston 14 September21, 1961 memorandum with a number of 14 plant, did you ever deal with Jack Garrett concerning the 15 attachments. The Bates numbers are Ann 1539644 through 15 operations of the Anniston plant? 16 663. 16 A Probably so. Mr. Garrett later on was my 17 By Mr. Brock: 17 neighbor, my partner and so forth and 1 know that 1 met him 18 Q Mr. Savage, I'd like you to just take a moment to 18 before he was my neighbor, but exactly when, 1 don't know. 19 glance through it. If it speeds your review, 1 believe 19 Q Do you recall working on any projects with him 20 your name is mentioned on the page that ends in Bates 20 concerning the operations at the Anniston plant? 21 number 655. And let me know when you've had a chance to 21 A No. But 1 had met him before 1 moved to 22 look through the document. 22 Kirkwood, so presumably it would have been in connection Page 470 Page 472 1 ( Witness reviewed the document. ) 1 with something at Anniston. 2 A Yes. 2 Q Do you recall doing any work in connection with 3 Q Have you ever seen this document before to your 3 the findings or allegation of a fish kill in this time 4 knowledge? 4 frame? 5 A 1 don't remember seeing it. 5 A No. 1 just remember hearing about it. 6 Q Do you recall learning about fish kills in the 6 Q Did you hear -- aside from your initial 7 Choccolocco Creek and Coosa River in or about 1961? 7 conversations in which you heard about it, did you 8 A 1 heard of such things secondhand. 1 don't 8 subsequently hear whether the fish kill could in fact be 9 remember who 1 heard it from. 9 attributed to the operations at the Anniston plant or not? 10 Q Do you recall what you heard secondhand? 10 A 1 may have, but 1 don't recall. 11 A The fact that fish kills had been alleged. 11 Q 1 take it you didn't see any analysis or 12 Q Did you hear that those fish kills had been 12 discussion of that that you recall? 13 attributed to Monsanto? 13 A 1 remember the laboratory talking about doing 14 A Well, that's why 1 would have heard of it, yes. 14 such analysis, but 1 don't remember what that analysis 15 1 heard it from somebody in Monsanto, but 1 don't know who. 15 might have shown. It was considered a rather unusual event 16 Q Let's go to the page ending in Bates number 655. 16 for the analytical lab to be working on fish. 17 There's a discussion of a Dr. Grsenda on that page. 17 Q Do you recall there being any other times in 18 A Yes. 18 which concern was brought to your attention as to whether 19 Q Do you recall dealing with a Dr. Grsenda 19 the operations of the Anniston plant were causing harm to 20 concerning the subject of those fish kills? 20 aquatic life or other wildlife, and I'm restricting this to 21 A No. 21 the time you were at the Anniston plant? 22 Q It states " The data regarding the production and 22 A What are you asking me about that? Savage, James (Aroclor Dept employee) in AETNA (3) Pages 469 - 472 HARTOLDMONO010251 Page 473 Page 475 1 Q We talked about the claims of a fish kill in the 1 Q Let's go to the second page where it lists the 2 Chocolocco Creek and Coosa River being brought to your 2 sources of odor and the first is waste disposal area. What 3 attention. Were there any other matters along those lines 3 does that refer to? 4 brought to your attention, for example, fish kills, harms 4 A 1 believe that this date is before the waste 5 to aquatic life orthat kind ofthing? 5 treatment plant was built. So at that time, we would 6 A 1 remember one letter to the editor of the 6 probably refer to the limestone bed and the tanks right 7 Anniston newspaper which 1 thought was kind of humorous in 7 next to the limestone bed as being the waste disposal 8 which the writer claimed that her father or grandfather had 8 areas. 9 fished in Snow Creek, and 1 thought that was humorous since 9 Q What was the outlet weir? 10 Snow Creek would not have any flow without the flow from 10 A Well, the outlet weir was a device to measure 11 the Anniston plant. 11 flow. It's obviously at the outlet of something, but 1 12 Q Do you recall any other concerns about harm to 12 don't remember -- 1 guess 1 do. It was at the outlet of 13 wildlife or aquatic life from the Anniston plant being 13 the concrete holding tanks, so it would have been the last 14 brought to your attention? 14 access to the stream before it entered the city sewer at 15 A No. 15 that time. 16 ( Savage Exhibits 110 and 111 identified.) 16 Q There's a reference to strong organic sulfide 17 ( Recess. ) 17 odors being noticed frequently. Do you recall how 18 By Mr. Brock: 18 frequently those odors were noticed? 19 Q Exhibit 110 has Bates numbers Ann 1540107 through 19 A No, 1 can't add anything to that statement. 20 109 and number 111 has a Bates number of Ann 1539917. 20 Q What was the P2s5 room? 21 Let's start with Exhibit 110. Mr. Savage, is that a Tsd 21 A That was within the Niran department. There was 22 progress report that you drafted along with some others 22 an area below the control room at ground level where bins Page 474 Page 476 1 concerning odor investigations at the Niran plant? 1 of P2s5 were emptied. That was also the room where bags of 2 A Yes. 2 soda ash were dumped. That was just known as the P2s5 3 Q Do you recall what the impetus was for this 3 room. Let me correct that. P2s5 room was a separate 4 investigation? 4 little room under the control room where P2s5 bins were 5 A No. 1 don't know of any occasion that triggered 5 emptied. 6 this work. 6 Q There's a statement" leakage of the thio acid 7 Q That was just an ongoing subject being 7 pump packing allows thio acid to accumulate on the floor." 8 investigated at that point in time? 8 Do you recall that happening? 9 A Yes. 9 A No. 10 Q Who are J. C. Johnson and Archie Sprague? 10 Q Do you recall any changes being made in the P2s5 11 A Jim Johnson was a mechanical engineer in the 11 room to stop that from happening? 12 department. His boss was Russ Sprague who was the 12 A No. 1 don't even remember there being a pump in 13 superintendent of the maintenance department. 13 that room, from the words here apparently there was. 14 Q Johnson's position was what in the maintenance 14 Q What was a condensation reactor vent? 15 department? 15 A Condensation reaction took place at atmospheric 16 A He was mechanical engineer. 1 don't know what 16 pressure. 1 don't remember the temperature conditions, but 17 his title was, but he was mechanical engineer. Is a 17 there was a vapor line leaving the reactor and the 18 mechanical engineer 1 should say. 18 condensor chilled with a refrigerant whose purpose it was 19 Q Something do you know what his input would have 19 to condense any acetone vapor leaving the reactor. The 20 been into this project? 20 vent, the condensation reactor vent would be the vent from 21 A 1 don't know specifically what he did on this 21 the condenser above the condensation reactor. 22 project. 22 Q Do you recall there being odors emitted from Savage, James (Aroclor Dept employee) in AETNA (3) Pages 473 - 476 HARTOLDMONO010252 Page 477 Page 479 1 the- 1 be installed over the entrance to the limestone pit and the 2 A Not specifically. 1 can see what it says here, 2 outlet weir." Do you recall why that was proposed? 3 but 1 don't remember. 3 A No, 1 don't recall this. 4 Q Do you recall there being odors emitted from the 4 Q Let's goto Exhibit 111. 5 other sources of odor listed, the " jet effluent beater 5 A Okay. 6 vent"? 6 Q Does this appear to you to be Cliff Stutz's 7 A That's header, h-e-a-d-e-r. 7 response to your June 8, 1959 Tsd report? 8 Q Header, I'm sorry. 8 A Yes. 9 A No, 1 don't remember the specific sources of odor 9 Q Are those your notes on the left-hand column? 10 in the department. 10 A Yes, that's my writing. 11 Q Do you recall there being complaints about odors 11 Q And Mr. Stutz writes " Apparently the odors at the 12 listed in the sources of odors listed here? 12 limestone pit and hold tanks are most severe when the waste 13 A 1 can recall being told of complaints from 13 treatment chlorination unit is not operating properly." Do 14 neighbors and sometimes the neighbors would believe they 14 you see that? 15 could pinpoint what exact pipe in the plant the odor had 15 A Yes. 16 come from. We were skeptical at such statements. 16 Q Did you agree with that statement? 17 Q Do you recall what, if any, pipes the neighbors 17 A Did 1 agree with it at the time? 18 identified? 18 Q Yes. 19 A They would identify the plume coming from the 19 A 1 don't know. 20 vacuum jets because it was a visible emission, but what was 20 Q Is it your recollection that that was the case? 21 visible was steam, condensate from steam. 21 A That what was the case? 22 Q Under odor control program, it talks about 22 Q That the odors at the limestone pit and hold Page 478 Page 480 1 " revisions to sewage chlorinator" and states " It is 1 tanks were most severe when the waste treatment 2 proposed that the existing stoneware column be replaced 2 chlorination unit was not operating properly? 3 with one of Haveg-7710," do you see that? 3 A Oh, certainly. 4 A Yes. 4 Q And the reference to not operating properly, what 5 Q The reference to existing stoneware, can you 5 would the upsets or breakdowns be? 6 describe that? 6 A My recollection it had to do with failures of the 7 A That's what 1 referred to earlier as vitrified 7 stone equipment, leaks and cracks which prevented it from 8 clay pipe. 1 guess stoneware is probably a more accurate 8 being operated properly. 9 description of the material, but it's ceramic. 9 Q And how often would that take place? 10 Q Let's go to the next page where it says " control 10 A 1 don't remember. 11 measures at waste disposal area " and there's a proposal 11 Q And under ( a ), Mr. Stutz writes " Provide dual 12 that" the existing obsolete caustic storage tank be 12 contact columns of adequate capacity so that treatment can 13 converted for hypochloride storage by application of a 13 be provided at all times." Can you explain to me what he's 14 suitable lining." Do you see that? 14 suggesting there? 15 A Yes. 15 A 1 think he was proposing that essentially there 16 Q In what sense was the caustic storage tank 16 be a spare column, since for ordinary purposes, only one 17 obsolete? 17 column would be needed. 18 A 1 don't remember. 18 Q And you write " I'm agin it."? 19 Q Do you recall whether the old tank had a lining 19 A Yes. 20 or not? 20 Q And it says "$ 2000 extra." Were cost factors a 21 A No. 21 significant factor in Monsanto's dealing with odor or waste 22 Q It states " It is also proposed that spray nozzles 22 disposal situations in the late 1950s? Savage, James (Aroclor Dept employee) in AETNA (3) Pages 477 - 480 HARTOLDMONO010253 Page 481 Page 483 1 A 1 think we were always conscious of what things 1 A Yes. 2 cost. 2 Q Do you recall this process or this type of 3 Q Did Monsanto attempt to implement the least 3 experiment being tested in the late 1950s? 4 expensive methods of waste disposal and waste control? 4 A Yes. 5 A No, 1 don't think so. 1 think our first concern 5 Q Tell me what you recall about it? 6 was that we provide facilities that would be effective, but 6 A 1 recall approximately what's reflected here on 7 we didn't want to spend money unnecessarily. 7 the front page, that it was partially successful, that the 8 Q Do you recall any waste disposal or pollution 8 organic loading in the stream could be substantially 9 abatement projects that were not put in place because of 9 reduced, but it didn't meet our objectives. 10 cost factors? 10 Q Why did it not meet Monsanto's objectives? 11 A No. This particular instance in my recollection 11 A We wanted to reduce the organic loading in the 12 we in fact only put in one column. 12 stream more than this. 13 Q So Mr. Stutz's suggestion was not adopted? 13 Q Can you tell me what the lagoons consisted of - 14 A Not that 1 recall. 14 strike that. 15 Q And down below there's a paragraph by Mr. Stutz 15 Do you know where they were at the plant? 16 that" if these improvements are made, it would seem that 16 A Roughly in the area of the limestone pit and the 17 the proposal to install hypochloride storage and spray 17 holding tank. We've marked that on a map yesterday. 18 equipment at the entrance to the limestone pit and over the 18 Q Marked the lagoon? 19 hold ponds would not be necessary." Do you see that? 19 A Well, lagoon and-- 20 A Right. 20 Q Right. We did mark temporary lagoon. 21 Q And you write " butit's cheaper." 21 A Yes, 1 think that's the same thing. 22 A Yes, 1 see that. 1don't remember having written 22 Q In some earlier exhibits today, there were some Page 482 1 these comments obviously they're my writing and they're 1 references to a pilot effluent pond. Page 484 2 also my style. 3 Q Do you recall what steps were adopted, if any, to 4 address this situation of odors at the limestone pit and 2 A This was the same thing. My recollection is that 3 over some period of time we modified and enlarged that pond 4 or lagoon, but 1 don't remember the reasons. 5 hold tanks? 6 A The only thing 1 remember clearly is that we 7 installed this new column and that it worked very well. 8 It's my recollection that this general problem area after 9 that was not of nearly so much concern. 10 Q Do you know whether the hydrochloride storage and 11 spray equipment referenced was installed? 12 A 1 don't remember that we did that. 13 ( Savage Exhibit 112 identified. ) 14 Mr. Brock: I've marked as Exhibit 112 a document 15 with Bates numbers Ann 1539264 through 266. 16 By Mr. Brock: 17 Q Mr. Savage, could you let me know when you've had 18 a chance to glance through this document. 19 ( Witness reviewed the document. ) 20 A Yes, okay. 21 Q It references an " Experimental treatment of Niran 22 wastes by lagooning." Do you see that? 5 Q Do you recall what the modifications were? 6 A Just to make it bigger. 7 Q Were there any other modifications to it? 8 A Not that 1 remember. Oh, yes, the original 9 lagoon was just a simple lagoon that got its oxygen 10 transfer just through the surface as any natural body of 11 water would. At some point we installed a compressor to 12 bubble air through the lagoon or pond. 1 don't remember at 13 what point that was done, but 1 remember that that was a 14 second step at some point. 15 Q Was that lagoon ever used on a permanent basis? 16 A It was used for an extended period of time. It's 17 my recollection that it was too small, far too small to 18 effectively treat all the wastes from the plant, but that 19 enough reduction was going on that it seemed useful to 20 continue its operation until the big waste treatment plant 21 was ready to put in service. So it's my recollection we 22 ran it for some extended period of time, but 1 don't Savage, James (Aroclor Dept employee) in AETNA (3) Pages 481 - 484 HARTOLDMONO010254 Page 485 1 remember how long. 2 Q Was it used for a time during which the big waste 3 treatment plant was also used? 4 A 1 don't think so. 1 don't think there would be 5 any reason to do that. 6 Q If you look on the second page of the exhibit 7 under" lagoon tests," there's a small -- or there's a 8 description of lagoons. Do you see that? Page 487 9 A Yes. 10 Mr. Burnett: Did you say " lagoons "? 11 Mr. Brock: A small lagoon. 12 By Mr. Brock: 13 Q Do you recall how many temporary lagoons or was 14 there one temporary lagoon or was there more than one? 15 A There was one lagoon that was actually operated 16 as two units by putting a partition in it at some point. 17 Q And were different materials sent to one side of 18 that lagoon than the other side? 19 A 1 think they were operated in sequence, believing 20 that that might be more efficient. 21 Q Do you know whether that lagoon was lined at all? 22 A 1 think it was. 1 ( Whereupon, at 12: 35 p. m. , the deposition was 2 recessed, to be reconvened at 1: 30 p. m. this same day. ) Page 486 Page 488 1 Q What do you think it was lined with? 1 Afternoon Session ( 1: 45 p. m. ) 2 A 1 don't know. 2 Whereupon, 3 Q What leads you to think that that was lined? 3 James R. Savage 4 A Because that would have been a fairly normal way 4 resumed the stand and, having been previously duly sworn, 5 to build something like that. 5 was examined and testified further as follows: 6 Q Did you ever see the design drawings for that 6 Mr. Brock: My understanding is that Monsanto's 7 lagoon? 7 counsel has agreed with us that Charlie Meyer can go out of 8 A 1 don't remember seeing those drawings. 8 turn and do his questioning and then 1 can return and do 9 Q Why would it have been fairly normal for such a 9 mine. Certainly I'll make every effort as long as there's 10 lagoon to be built with a lining at that time? 10 not duplicative questioning or repetitive questioning and 11 A So that it wouldn't leak. 11 that type of thing. 1 certainly intend to avoid and make 12 Q Do you know whether in fact that lagoon had a 12 every effort to avoid any such type of questioning. 13 lining? 13 Mr. Burnett: That's correct. And it's my 14 A I'm not sure. 14 understanding that both of you still believe that we'll be 15 Q Did you ever hear or learn that there had been 15 able to comfortably conclude the deposition sometime 16 migration of chemicals or leaks from that lagoon? 16 tomorrow. 17 A No. 17 Mr. Brock: Yes, at present that's my 18 Q Are you aware of any investigations or studies 18 understanding and intention. 19 into that subject? 19 Mr. Meyer: Well then, for the record, my name is 20 A No. 20 Charles Meyer with the law firm of Jackson & Campbell. 21 Mr. Brock: Now is probably a logical time for a 21 And, Mr. Savage, I'll be asking you some questions relating 22 lunch break. 22 to your tenure at the Anniston, Alabama facility. I'd like Savage, James (Aroclor Dept employee) in AETNA (3) Pages 485 - 488 HARTOLDMONO010255 Page 489 Page 491 1 to have introduced and marked as our next numbered exhibit 1 A It was done in a tower inside the Niran 2 a Monsanto document known as a manual of operating 2 department. 3 instructions for the waste treatment plant lagoon prepared 3 Q So the wastes were first chlorinated in the Niran 4 by Mr. Gene Coley dated as of July 14, 1966. 4 department and then they flowed to the waste treatment 5 ( Savage Exhibit 113 identified. ) 5 facility? 6 Examination 6 A Yes. Also there's a reference here to flow to 7 By Mr. Meyer: 7 lagoon as being a part of the ongoing process and 1 don't 8 Q Sir, with all the exhibits that I'll be 8 remember that. 9 introducing, what 1 would like for you to do is spend as 9 Q Now, sir, from the reference on page 2 of the 10 much time as you would like in reviewing them and when you 10 document to entries on first of all a lagoon and then also 11 feel to your satisfaction that you've had a chance to 11 a limestone pit, would 1 be fair in inferring from that 12 review them, look up and indicate to me that you're ready 12 that the two were separate installations? 13 for me to start my questioning. Naturally by so 13 A Yes, yes. 1 think so. 14 indicating, that doesn't preclude you from at any point 14 Q Were the hold tanks in existence when you were at 15 during the questioning stopping and and rereviewing a 15 the plant, sir? 16 document. Do you understand that? 16 A It's my recollection that the hold tanks were 17 A Yes. 17 part of the original Niran installation. So yes, they were 18 ( Witness reviewed the document. ) 18 there when 1 arrived. 19 Okay. 19 Q Finally, sir, how about the aeration basins? 20 Q Mr. Savage, 1 realize that this is authored a few 20 When you were at the plant, did the waste treatment 21 years after you left the Anniston plant for the record. 1 21 facility have aeration basins? 22 was wondering, sir, if the description of the waste 22 A The first aeration basins were built while 1 was Page 490 1 treatment plant lagoon is familiar with you based on your 1 at the plant. Page 492 2 prior experience at the plant? 3 A It's generally familiar, but there are some 4 features that were not present at the time 1 was at the 2 Q How many of them were there that were built at 3 that time? 4 A There were two at that time. 5 plant. 6 Q Could you please identify the features that were 7 not present? 8 A The Pnp department did not exist at the time that 9 1 was there. They brought in Pnp that was made in another 10 plant, so any reference here from waste from the Pnp 11 department is something that I'm not familiar with. 12 Q Because it would not have existed at the time 13 that you were at the plant? 14 A That's right. 15 Q How about the actual components of the waste 16 treatment system, were there any additions from the time 17 you had been at the plant, sir? 18 A Well, 1 notice for instance that chlorination is 19 done in a contact basin. My recollection is that didn't 20 exist at the time that 1 was there. 21 Q Where was the chlorination done when you were at 22 the plant? 5 Q Prior to the construction of those aeration 6 basins, was any effort made to oxygenate the waste? 7 A What 1 recall is that during the time that the 8 lagoon or pond was in operation that we aerated the pond or 9 lagoon. 1 don't recall that as handling the entire flow 10 however. 11 Q And that would go back to your previous testimony 12 before the lunch break that initially the lagoon through 13 the surface contact would oxygenate and later on some 14 installation was put into it? 15 A That's right. 16 Q When you said pond, were you using that 17 interchangeably with lagoon? 18 A Yes. 19 Q So those are one and the same? 20 A According to my recollection, yes. 21 Q Sir, do you recall what the construction of the 22 aeration basins was when you were at the plant, the ones Savage, James (Aroclor Dept employee) in AETNA (3) Pages 489 - 492 HARTOLDMONO010256 Page 493 Page 495 1 that had been constructed before you left? 1 Q What is your understanding of a trickling filter 2 A They were concrete. 2 system? 3 Q Were they built above-ground level then? 3 A A trickling filter is another kind of biological 4 A No. Ground was excavated and forms put in the 4 treatment plant, it's quite common. 5 ground much the way a concrete basement for a house would 5 Q So as opposed to inserting bacteria, this would 6 be built. 6 have some other way of filtering out the pollutants? 7 Q So you saw the construction? 7 A No. Bacteria are still involved. It's just 8 A Yes. 8 whereas in an activated sludge plant, the bacteria right in 9 Q Did you have anything to do with the design basis 9 sludge particles are settled in a settler and recycled with 10 for the aeration basins? 10 pumps. In a trickling filter, the bacteria reside in some 11 A No. 11 kind of sludge that's in a stationary phase and the waste 12 Q Who would have been responsible for designing the 12 is trickled across that sludge. 13 aeration basins? 13 Q Sir, to your knowledge did the Nitro facility 14 A Cliff Stutz was the lead engineer as 1 recall 14 have a site that was close to a large river? 15 from a process standpoint. He probably would not have been 15 A Nitro plant is situated on the Kanawha River. 16 the one to do the detailed design on the concrete. 1 don't 16 Q And is that river to your knowledge larger than 17 know who did that. 17 Snow Creek would have been in Anniston, Alabama? 18 Q Do you recall a Mr. Gene Coley? 18 A Certainly. 19 A Yes. 19 Q As part of designing a waste treatment facility 20 Q Could you tell me what you recall of Mr. Coley? 20 in this era, and we're discussing the late 1950s, early 21 A Mr. Coley at the time that 1 was at the plant, he 21 1960s, would the size of the receiving waters of an 22 may have started with a couple while 1 was at the plant. 1 22 effluent stream have mattered in terms of the design basis Page 494 Page 496 1 believe he was in the analytical lab when 1 knew him, but 1 for a treatment facility? 2 I'm not sure about that. 2 A Yes. But Snow Creek was not the receiving 3 Q Was the waste treatment facility at the Anniston 3 stream. Choccolocco Creek was the receiving stream. 4 plant also sometimes referred to as 0-2? 4 Q Well, but then the answer to my question is yes? 5 A Not to my recollection. 5 A Yes. 6 Q Do you recall what Mr. Coley's background was, 6 Q So the size of the receiving water would make a 7 sir, prior to joining Monsanto? 7 difference? 8 A No. 8 A 1 think that question really goes beyond my 9 Q And Mr. Stutz, sir, would have been at 9 expertise. 10 headquarters in some capacity? 10 Q All right. And you don't know how long Mr. Stutz 11 A He was a sanitary engineer working in organic 11 or the unit he worked for had been in existence prior to 12 engineering department in St. Louis. 12 your involvement with him? 13 Q How long had, to your knowledge, the organic 13 A When 1 met Mr. Stutz, he had already had 14 engineering department had a sanitary engineer department? 14 substantial experience in waste treatment. It's my 15 A Not very long. It's my recollection that 15 understanding that he had not been with Monsanto a long 16 Mr. Stutz may have been the first such engineer in organic 16 time. But previous to that, worked in waste treatment of 17 engineering. 17 domestic waste. 18 Q Now, sir, did the Niran facility in the plant at 18 Q So this would have been say with a municipally 19 Nitro, West Virginia have a waste treatment facility? 19 owned system? 20 A 1 was told that there was a trickling of filter 20 A 1 think so. 21 there, but whether that was a full-sized facility or some 21 Q Now, how about Mr. Coley, do you think he had a 22 kind of pilot facility, 1 don't know. 22 similar background in municipal treatment plants? Savage, James (Aroclor Dept employee) in AETNA (3) Pages 493 - 496 HARTOLDMONO010257 Page 497 Page 499 1 A 1 don't know what his background was. 1 that was off site that you were testifying to earlier 2 Q Sir, to your knowledge when you were at the 2 today? 3 plant, did a manual like the one that is embodied in 3 A Yes. 4 Exhibit 113 exist for the waste treatment facility? 4 Q Yes? 5 A 1 don't remember that it did. 5 A Yes. 6 Q Which department within the plant would have been 6 Q Sir, 1 believe it was your testimony earlier 7 responsible for operating the waste treatment facility? 7 today that you referred to a geographical feature across 8 A At the time that 1 was there, the Niran waste 8 the road on that Monsanto owned land as a horseshoe 9 treatment plant was considered to be a part of the Niran 9 Monsanto? 10 department. It was operated by the same supervision. 10 A Horse Block is the name 1 remember. 11 Q Now, in that time frame, sir, did each operating 11 Q Could it also- 12 department within the Anniston plant have its own 12 A Strange name. 13 maintenance group? 13 Q Could it also have been known as Cold Water 14 A The plant was functionally organized, meaning 14 Mountain? 15 that the plant manager's staff level there was a production 15 A 1 remember that name too. That may have been the 16 superintendent and a maintenance superintendent. And so 16 name of the larger feature. 1 don't know. 17 from the formal standpoint, all the maintenance people 17 Q Sir, do you recall anyone ever telling you 18 reported up to the maintenance superintendent. However, 18 whether or not that Monsanto owned property across the 19 within the maintenance department, there was a subdivision 19 road, had at one time had iron ore pits? 20 according to production departments so that at the 20 A Yes. That was part of the history of the plant 21 supervisor level there would be a certain production 21 that it was ore. 1 remember it being called ferromanganese 22 supervisor who was responsible for each part of the plant. 22 ore. Page 498 Page 500 1 Q And then would there have been Anniston log of 1 Q Were those pits then excavations in the ground? 2 maintenance supervisor that was attached to that particular 2 Mr. Burnett: What pits? 3 production department? 3 Mr. Meyer: The ferromanganese pits. 4 A Usually. 4 The Witness: If it was used for mining, 1 would 5 Q And was that true of the Niran department in that 5 presume that, but 1 never studied the land enough to reach 6 era? 6 any conclusion like that. 7 A That's my recollection, yes. 7 By Mr. Meyer: 8 Q And would that then also have been true for the 8 Q Well, let me ask you, sir. In the times you went 9 Aroclor biphenyl department? 9 over there, 1 believe you testified to do shooting, would 10 A 1 think so. 10 that have been skeet shooting? 11 Q Sir, to your knowledge was Snow Creek immediately 11 A No. 1 had a rifle and it was the very primitive 12 adjacent to the outfall at the Anniston plant? 12 type of target shooting, setting up tin cans and shooting 13 A Snow Creek was on the opposite side of Highway 13 at them. 14 202 from the limestone bed in the front yard that served 14 Q In those times that you went over there, do you 15 the Aroclor department. 15 ever recall seeing pits in the ground? 16 Q And approximately how far would that have been 16 A Yes. 1 think 1 mentioned that 1 saw something 17 then from the outfall to the, 1 believe you said across 202 17 that looked like a landfill where there were some drums in 18 where Snow Creek was? 18 evidence. 19 A Just the width of that right away. 1 don't know 19 Q How about something that might have looked like 20 what that would be. Perhaps 40 feet. 20 at one time it was a mining operation? 21 Q Now, would Alabama state Highway 202 also be the 21 A 1 don't remember that. I'm not sure 1 would know 22 road that divided the main plant from the landfill property 22 what a mining operation looked like anyway. Savage, James (Aroclor Dept employee) in AETNA (3) Pages 497 - 500 HARTOLDMONO010258 Page 501 Page 503 1 Q How did you gain the knowledge that at one time 1 there was a Santowax Omp, for instance, that was sold. In 2 there might have been some ferromanganese pits over there? 2 the Montars, as 1 recall it was, there was a number suffix, 3 A There was a written history of the plant that 3 it would be Montar 1 or 2 or something like that, which 4 anyone could have access to which described the Old 4 reflected the origin of that particular grade of Montar. 1 5 Southern Manganese Corporation, which was the original 5 don't recall which one went with which product. 6 owner -- not the original owner, but the original developer 6 Q Could there have been as many as nine numbered 7 of that property. 7 Montars, one through nine? 8 Q Which later on became Swan Chemical? 8 A Could be, 1 don't know. 9 A Yes, in between it was called the Federal 9 Q Sir, prior to the construction of Cleghorn's Lake 10 Phosphorus Company, but eventually became Swan Chemical. 10 and 1 believe you said it was a feature that already 11 Q Now, sir, 1 believe earlier today you were 11 existed when you arrived at the plant? 12 describing an on-site landfill. Could that have also been 12 A That's my recollection. 13 generally known within the plant as Cleghorn's Lake? 13 Q You don't know for how many years it had been in 14 A Yes. 1 remember that term. 14 existence, do you? 15 Q And Mr. Cleghorn as 1 understand it was at one 15 A No. 16 time the supervisor of the Aroclor department? 16 Q Do you know what was done with the still residues 17 A Yes. At the time that 1 arrived at the plant, he 17 prior to the construction of Cleghorn's Lake? 18 was supervisor of that entire area. 18 A No. 19 Q Including biphenyl? 19 Q Sir, was Cleghorn's Lake physically on the land 20 A Yes. 20 as you looked at it, in actuality, two physically distinct 21 Q Now, sir, going back to your description of what 21 impoundments to your recollection? 22 was being pumped to the Cleghorn's Lake configuration, 1 22 A Yes. Now that you ask that, 1 believe there was Page 502 Page 504 1 believe you described them as Santowax fractions ; is that 1 more than one place. 2 correct? 2 Q Do you recall, sir, if there was any effort made 3 A Yes. 3 to funnel one type of still bottom to one of the 4 Q Would that have also included a substance known 4 impoundments versus another, in other words, to keep them 5 as Montar? 5 segregated? 6 A It might have. Just because Montar, even though 6 A The only one 1 remembered clearly was the one 1 7 it was a trade name that we used when we sold certain 7 mentioned before and it was my understanding that it was 8 grades of still residue, it was also used pretty broadly 8 entirely Santowax material that went to that one. But 1 9 for any still residue from that part of the plant. So 9 have no comprehensive knowledge of what went to that place 10 Santowax still bottoms might have well been called Montar 10 Q Now, sir, what would the still bottoms from the 11 and Santowax still bottoms 1 think were placed in that 11 production of liquid Aroclor have been known as? 12 landfill. 12 A 1 think it would have been called Montar with 13 Q Now, wasn't Santowax also a trade name? 13 some number after it, maybe one of several numbers. 14 A Yes. 14 Q So would the still bottoms from solid Aroclor 15 Q So Montar was also a trade name? 15 production have also been known as a Montar? 16 A Yes. 16 A 1 think so. I'm not sure about that, but 1 think 17 Q So documents might have referred to one or the 17 so. 18 other interchangeably? 18 Q How about a substance known as Santotar? 19 A Well, when the products were sold, there was a 19 A Santotar, I'm 1 don't remember that term. 20 letter or number after it. Santowax R, for instance, was 20 Q Sir, do you recall from time to time when the 21 the name given to refined Santowax when it was sold and 21 Montar or Santowax was being placed in Cleghorn's Lake, 22 that was the usual Santowax product that was sold, but 22 that the hot Montar which was in liquid form as it was Savage, James (Aroclor Dept employee) in AETNA (3) Pages 501 - 504 HARTOLDMONO010259 Page 505 Page 507 1 being placed on top of the surface of Cleghorn's Lake, that 1 improvement programs that deferred certain projects as a 2 a vapor would arise, a very density cloud? 2 cost-saving measure? 3 A 1 don't remember that, but 1 only remember seeing 3 A Yes. We've had campaigns from time to time to 4 the Santowax type material. It's not just something that 1 4 reduce costs which sometimes involved deferral of expenses. 5 happened to have observed. 5 Q Would 1 be reading this correctly, sir, that 6 Mr. Meyer: 1 would like to have marked and 6 prior to the enactment of these various laws that are 7 introduced as our next numbered exhibit a Monsanto progress 7 referenced in the second paragraph of the executive 8 report from the technical services department at Anniston 8 summary, that the Anniston plant had planned several 9 dated September 30, 1971 and for the record its title is 9 pollution control and other projects, but that those had 10 " Plant improvement and environmental control" and the 10 been deferred on account of this profit improvement 11 witness is shown as having received a copy of the document. 11 program? 12 ( Savage Exhibit 114 identified. ) 12 A It seems to be a reasonable inference from this 13 By Mr. Meyer: 13 paragraph. 14 Q Sir, since this is a longer document, please take 14 Q Sir, 1 would like to direct your attention to the 15 your time to review and study and familiarize yourself with 15 fourth page of the document which for the record has a 16 it. 16 Anniston Bates number 1401854. Are you with me, sir? 17 ( Witness reviewed the document. ) 17 A Yes. 18 A Okay. 18 Q Under the general subject matter" water," there 19 Q Sir, do you generally recall the subject of the 19 is a description of various kinds of sewers at the Anniston 20 memorandum? 20 plant. And 1 was wondering, sir, if at the time you were 21 A In general. Each plant had a plant improvement 22 project of some kind. 21 at the Anniston plant, whether or not those four categories 22 of sewers existed? 1 Q Around this time, 1971? Page 506 1 Page 508 A 1 can recognize several of these categories. 1 2 A During most of my time in manufacturing this was 3 a standard procedure. 4 Q Sir, do you recall who Mr. Ankeny was? 2 don't remember that there was a storm sewer system, but it 3 could be. 1 have never been particularly familiar with the 4 sewer maps of the plant. 5 A No, 1 don't. 5 Q How about something known as an " acid sewer," did 6 Q How about Mr. Taffee, T-a-f-f-e-e? 6 the plant have an acid sewer when you were there? 7 A Bill Taffee was at the Anniston and had 7 A There were acid sewers, yes. As to whether there 8 previously been my boss at the Krummrich plant. 8 was a single system called acid sewer, 1 don't remember. 9 Q Do you recall what his function was at this time 9 Q And of course since when you were at the plant, 10 at the Anniston plant - 10 they didn't have a Pnp section yet. The sewer would have 11 A 1 think he had plant improvement responsibility. 11 been known probably only as a Niran sewer. Do you recall 12 Q - as well as environmental control? 12 if there was a Niran sewer? 13 A Yes. 1 think he was involved in both of those. 13 A Yes. 14 Q Sir, 1 want to direct your attention to the 14 Q And then finally, I'll assume that there was some 15 executive summary on page 1 and in the second sentence 15 sanitary sewers? 16 which begins " these projects." Are you with me? 16 A Of course. 17 A Yes. 17 Q Sir, 1 would like to direct your attention to 18 Q There's a reference to something known as a 18 page 7 of the document which bears a Bates stamp number 19 " profit improvement program" in 1969. Could you shed some 19 1401857," solid wastes," the general category. Are you 20 light on what that program might have been? 20 with me? 21 A 1 don't remember that specific program. 21 A Yes. 22 Q Did Monsanto from time to time have profit 22 Q Sir, was there some particular meaning back in Savage, James (Aroclor Dept employee) in AETNA (3) Pages 505 - 508 HARTOLDMONO010260 Page 509 Page 511 1 1971 to the phrase " a sanitary landfill" as described in 1 A We used them as a general contractor, but 2 that paragraph? 2 particularly projects that involved piping. They had some 3 A 1 think the term here is used to distinguish it 3 good welders. 4 from a less carefully operated facility. 4 Q Could that piping have also included sewer lines? 5 Q So the steps that are then described after that 5 A Might have. 6 description would to your mind be steps taken to improve 6 Q Do you recall a contractor named Bill Hall who 7 the operation of a landfill such as fencing? 7 was expert in the operation of a backhoe for digging line? 8 A Yes. 8 A No. 9 Q Now, sir, in the second paragraph in this solid 9 Q Sir, 1 would like to turn your attention to the 10 waste category, the reference is made to the fact that a 10 series of maps that are appended to this document. And 11 cost center had been established for the landfill. What 11 specifically, actually figure 1, which bears a Bates stamp 12 would the ramification of Monsanto establishing a cost 12 number 1401866, are you with me? 13 center for the landfill have been? 13 A Yes. 14 A That's an accounting action. Normally when it's 14 Q Sir, earlier today you were testifying to the 15 decided to establish a cost center, that's done either 15 fact that the Niran or parathion department had an 16 because the costs involved have become large enough that 16 incinerator, was that correct? 17 it's desirable to track the costs more carefully or 17 A Yes. 18 sometimes it's done because a certain facility is providing 18 Q As part of the incinerator, was there a 19 services for more than one department and what's needed is 19 neutralization pit associated with the parathion 20 a mechanism for allocating that cost between the 20 incinerator? 21 departments that are served. 21 A 1 think there eventually was. There was not in 22 Q Which do you think would have been the case with 22 the original installation of the incinerator because there 1 the landfill at Anniston, what purpose? Page 510 1 was no scrubber originally associated with it. Page 512 2 A It was based on the events at the time. It's 3 probably because it had become more expensive than it was 4 before. 2 Q Why would the scrubber have made a difference? 3 A Because the scrubber used city water which was 4 recycled to some extent, but there was a discharge stream 5 Q Sir, do you recall when you were at the plant a 5 from the scrubber which would have been a fairly dilute 6 Monsanto contractor known as either Anniston Concrete or 6 acid. 7 Anniston Paving owned by a Mr. Ed Mcguinness having some 7 Q Which would have required neutralization? 8 involvement with the landfill? 8 A That's right. 9 A No, 1 recognize that name, Ed Mcguinness, as 9 Q Now, before the scrubber was installed, would the 10 being somebody who lived in the town but 1 don't recognize 10 incinerator have had an acidic characteristic to the waste? 11 those two company names that you mentioned. 11 A Well, it was nonaqueous, so that the term acid is 12 Q Sir, was any replacement or repair of sewers done 12 not meaningful. 13 during the period that you were working at the Anniston 13 Q 1 see. So it was when the scrubber added a step 14 plant? 14 whereby a quenching of part of the waste was occurring that 15 A Well, probably so because 1 was there for five 15 the acid became a problem? 16 years, but 1 don't remember any specific project. 16 A That's right. 17 Q Well, that was a pretty broad question. Do you 17 Q Do you recall generally, sir, where the 18 recall a company known as Crestview Heating and Plumbing 18 neutralization pit that was added in later years would have 19 being a Monsanto contractor at the Anniston plant? 19 been located? And 1 can probably help you out. 20 A Yes, 1 worked with them on some projects. 20 A Yes, 1 think it was uphill to the west. 21 Q Could you tell me what that work would have 21 Q If you were to refer, sir, to a figure 3 in this 22 involved? 22 same document, which is a couple pages on, there's actually Savage, James (Aroclor Dept employee) in AETNA (3) Pages 509 - 512 HARTOLDMONO010261 Page 513 1 something that's labeled " parathion incinerator scrubber 2 neutralization pit." Are you with me? 3 A Yes. 4 Q Is that your recollection of where that was 5 located? 6 A Yes. 7 Q Would 1 be fair in assuming, sir, that the two 8 ovals that are - 1 don't have a directional symbol on this Page 515 1 pit eventually ending up at the Snow's Creek outfall; 2 correct? 3 A That's what it shows, yes. 4 Q Now, sir, as part of that flow, is it possible 5 that some traces of Pnp, which was a constituent of 6 parathion, could have ended up in the parathion incinerator 7 neutralization pit? 8 A 1 think that's pretty improbable. The feed to 9 figure, but to the left of the incineration scrubber 10 neutralization pit, could that have been Cleghorn's Lake? 11 A Could be. That's not part of the scrubber pit, 9 the incinerator was from steps that were upstream of the 10 point in the process where Pnp is introduced, so it's not 11 evident to me how that could happen. 12 at any rate. 13 Q Now, sir, was the scrubber neutralization pit 14 accomplishing neutralization using limestone? 15 A Yes. 16 Q Could you provide an estimate of its approximate 17 dimensions? 18 A No. The dotted line here that's labeled as 19 neutralization pit can be compared with those circles near 20 it, which 1 think are storage tanks, and give some idea how 21 big it is. 22 Q Well, how long -- 12 Q So this would have been at the stage where you're 13 still at the intermediate stills and the chlorinators and 14 all that? 15 A That's what 1 remember. 16 Q Sir, below the parathion incinerator on that 17 figure 1 of this exhibit is something, a little box known 18 as an Aroclor department sump. Are you with me? 19 A Not yet. 20 Q Could 1 point it out to you, sir? 21 A Yes, please. Okay, yes. 22 Q Do you recall, sir, in the tenure that you were Page 514 Page 516 1 A Maybe 30 by 40 feet or something like that. 1 in the Aroclor department, the Aroclor department having 2 Q So how large would those storage tanks, the 2 something known as a sump? 3 circles to the right of the pit, be typically? 3 A No. No, this diagram is in 1971. 1 don't recall 4 A 1 think those were 12 feet in diameter, I'm not 4 that when 1 was there there was such a thing. 5 sure. Maybe 15. 5 Q Was P2s5 produced at the plant while you were 6 Q All right then, for the record it would look as 6 still there? 7 though the neutralization pit would probably be about 30 7 A No. 8 feet wide then and perhaps -- 8 Q So that was added later? 9 A Perhaps 50 feet in the other direction, or 60. 9 A That's right. 10 Q Now, sir, after the neutralization had been 10 Q As well as the Pnp? 11 accomplished, to your knowledge, where did the liquid then 11 A That's right. 12 go? 12 Q So both of those feed stops were brought in from 13 A Well, 1 haven't even thought about this in 30 13 outside the plant to make parathion? 14 years. This diagram shows that material going to the other 14 A That's right. 15 side of the plant, and 1 believe that's correct. 15 Q Sir, 1 wanted to go back to figure 3, which was 16 Q And the other side of the plant would be 16 the map that we saw the parathion incinerator scrubber 17 sometimes known as the biphenyl limestone pit? 17 neutralization pit on. Are you with me? 18 A Yes. 18 A Yes. 19 Q Which is down near the Snow Creek outfall? 19 Q 1 believe it was your testimony, sir that the pit 20 A Yes. 20 that's shown down near the Snow's Creek outfall was known 21 Q And that might be further confirmed if we go back 21 as the biphenyl limestone pit. 22 to figure 1 which shows the flow from the neutralization 22 A Yes, usually. Savage, James (Aroclor Dept employee) in AETNA (3) Pages 513-516 HARTOLDMONO010262 Page 517 Page 519 1 Q Now, was there one or were there more than one 1 recollection is that the reason for that usually was some 2 pit down there? 2 mechanical failure in the muriatic acid department so that 3 A There was more than one, at least at different 3 it wasn't able to take the gas. 4 times, because we built or replaced the limestone pit at 4 Q So you don't recall any customer demand 5 some point or -- whether there was more than one existing 5 considerations factoring into that decision? 6 at the same time other than as a stage of construction, 1 6 A 1 don't remember that. It could have been but 1 7 don't remember. 7 don't remember that. 8 Q Was the concept of using a limestone pit for the 8 Q Do you recall a grade of muriatic acid known as 9 neutralization of acid wastes something that you would 9 Staley grade? 10 regard as generally a practice in the chemical industry? 10 A Yes. 11 A Yes. 11 Q Could you describe for me what you know of Staley 12 Q Was there any kind of literature on the design 12 grade? 13 basis for these limestone pits in this era in the late 13 A It's my recollection that that was a high quality 14 1950s? 14 grade. 15 A I'm not familiar with such literature. It would 15 Q What would high quality mean? 16 be reasonable to expect that there was such literature but 16 A 1 don't remember. There was a particular 17 I'm not familiar with it. 17 specification for that grade. 18 Q Would it make sense that someone would have been 18 Q What would it mean that it was extra potent, as 19 doing some testing to see how much limestone you needed as 19 in more than 20 percent Hcl? 20 a contact surface to neutralize so much volume of waste? 20 A 1 don't remember that. We did occasionally make 21 A Yes, but that might not be a matter that could be 21 different strengths of acid, but our muriatic acid absorber 22 covered in a general way because each waste tends to be 22 was rather difficult to operate, particularly if we Page 518 1 somewhat unique in all the components that are present, and Page 520 1 attempted to make stronger grades of acid. So my 2 while Hcl is very easy to neutralize with limestone, the 3 active parts of limestone being calcium carbonate and 4 magnesium carbonate, other kinds of acids don't react as 2 experience as a supervisor was to avoid making a stronger 3 grade of acid if 1 could avoid it. 4 Q Now, would that have been the coke scrubber that 5 quickly with those materials, and therefore, a correct 6 design to some extent would have to be premised on the 7 composition of a specific feed. 8 Q Now, sir, it's true, is it not, that the biphenyl 9 limestone pit received muriatic acid from the Hcl 10 department. 11 A Yes. 12 Q And it's true, is it not, that the practice 13 sometimes at Monsanto in the Anniston plant was to divert 14 the quenched Hcl off-gas from the Aroclor production down 15 something known as a ditch directly to the limestone pit? 16 A That's right. 17 Q And that sometimes when the Hcl or muriatic acid 18 department didn't have any particular customers, the 19 practice would be, since they couldn't use any more 20 off-gas, it would all be simply sent down to the limestone 21 pit? 22 A Sometimes it was sent to the limestone pit. My 5 was supposed to remove any entrained organics from the Hcl 6 off-gas? 7 A There was something called a coke scrubber 8 upstream of the absorber. It's my recollection that it was 9 always used, but I'm not sure of that. 10 Q Was it 100 percent successful in this period? 11 A 1 don't know. 12 Q Could Staley grade have also referred to a 13 customer not wanting any quantity or appreciable quantity 14 of organics in the muriatic acid? 15 A That might have been but 1 don't remember what 16 that specification was. 17 Q Now, sir, 1 believe earlier today you mentioned 18 that Hcl was also going to the limestone bed that was 19 associated with the Niran department. 20 A Yes. 21 Q Now, that would be Hcl as an off-gas coming from 22 the chlorination that was occurring in Niran? Savage, James (Aroclor Dept employee) in AETNA (3) Pages 517 - 520 HARTOLDMONO010263 Page 521 Page 523 1 A That's right. 1 more like a quart, or maybe more. But it's a fairly 2 Q Was the Niran department at all connected with 2 arbitrary package that contains 76 pounds. 3 the muriatic acid department? 3 Q Do you recall approximately what the price was 4 A No. 4 back when you were the production supervisor in the 5 Q Did it in the normal course of events produce an 5 chlorine plant? 6 appreciable quantity in relation to the Aroclor department 6 A It was on the order of $4 - to 600 a flask. 7 of this Hcl off-gas? 7 Q Do you recall, sir, as an item of expense when 8 A The Hcl produced in the Niran plant was less and, 8 you were the production supervisor in chlorine 9 substantially less than the amount produced in Aroclor but 9 approximately how many flasks you might have used in, say, 10 probably within the same order of magnitude. 10 a month? 11 Q All right. So just so 1 understand, it's my 11 A In order of magnitude, five or 10, 1 don't 12 understanding that at a certain period of time, the Aroclor 12 remember exactly. 13 department had eight chlorinators. Would that have been 13 Q Now, as the operation of the Denora cells 14 true when you were there? 14 occurred, was something known as a mercury butter or 15 A Yes, 1 think so. 15 amalgam created? 16 Q And 1 believe your testimony earlier today was 16 A Yes, sometimes. 17 that the Niran department started out with two and then 17 Q Could you describe for me what the butter or 18 went to three chlorinators ; is that correct? 18 amalgam consisted of? 19 A That's right. 19 A The butter, as the name implies, was a semisolid 20 Q So would the relationship of Hcl off-gas being 20 amalgam. My understanding is that it contains calcium as 21 produced in Niran have borne the relationship that the 21 well as mercury. Possibly some other metals. 22 number of chlorinators, which is to say, three to eight, 22 Q Was any effort made in this period when you were 1 would have borne? Page 522 Page 524 1 the supervisor to recover the mercury from the butter? 2 A No, 1 think that's irrelevant because the 2 A We certainly considered it and studied it, and we 3 chlorinators in Aroclor were much smaller pieces of 3 had some, we made some kind of primitive attempts to 4 equipment. And anyway, the flow rates were related to many 4 collect mercury from the butter. 1 don't remember that 5 engineering factors. The number of chlorinators was a 6 minor point. 7 Q To your knowledge, sir, why wasn't an effort made 8 to mix the Hcl off-gas coming from the parathion department 9 with water and convert that also into muriatic acid? 10 A It probably wasn't deemed to be worth the 11 trouble. Muriatic acid sold for a very low price. 12 Q Did you have any operating experience, sir, with 13 the chlorine department? 14 A Yes, 1 was the production supervisor for two 15 years. 16 Q During that period of time, sir, did you keep 17 track of mercury usage in the department? 18 A Yes. 19 Q And it's my understanding that a pint of mercury 20 weighed about 70 pounds? 21 A Well, it wasn't a pint. There was -- the unit of 22 commerce for mercury is called a flask. It, 1 think it's 5 that was particularly effective. During my time, 1 6 advocated the installation of a small still to recover 7 mercury. 1 don't remember if that was ever done. 8 Q What, sir, to your knowledge was done with the 9 amalgam or the butter as it was accumulating? 10 A 1 don't remember. 11 Q Where would it accumulate at the end of the 12 Denora cells? 13 A It accumulated in two places. One was a place 14 called the outlet end box. 15 Q Excuse me? 16 A The outlet end box, which was a compartment at 17 the outlet end of the cell, and the other place that it 18 sometimes accumulated was in the mercury pump tank, which 19 was below the cells. The butter would be found floating on 20 the surface of the mercury. It was heavy but not as heavy 21 as mercury. 22 Q So would someone have had the duty, then, to skim Savage, James (Aroclor Dept employee) in AETNA (3) Pages 521 - 524 HARTOLDMONO010264 Page 525 Page 527 1 the butter off from time to time? 1 Q Would this have been pure sulfur? 2 A Yes. 2 A The sulfur that formed in the incinerator and was 3 Q Do you recall what was done with the butter that 3 a pluggage problem, in my opinion, was probably pure 4 was skimmed off? 4 sulfur. The sulfur that formed in the chlorination 5 A No, 1 don't. 1 think we had some place where we 5 reaction would have been mixed up with a lot of other stuff 6 accumulated it because often it was -- just spontaneously a 6 and certainly would not have been described as pure. 7 mercury layer would be formed at the bottom of the butter 7 Q To your knowledge, sir, in 1971 did the Anniston 8 and could be recovered. We did some other things to try to 8 plant still have this incinerator? 9 encourage that but 1 don't remember what it was. 9 A 1 think it did but 1 had nothing to do with it at 10 Q So to your knowledge it was not sent to the 10 that time. But the only basis for my opinion of that was 11 landfill? 11 visiting the Anniston plant in those days relative to 12 A 1 don't remember doing that. 12 responsibilities on the so-called biphenyl side, and 1 13 Q Sir, when you were production supervisor, for 13 could see in the distance some of that equipment was still 14 instance, in Aroclor, could you describe for me the role 14 there. 15 the shipping department had in retrieving wastes from an 15 Q So it would be your testimony that appreciable 16 operating department? 16 quantities of sulfur would not have been sent to a 17 A My recollection is that they would bring in 17 landfill? 18 something called a skip, which was a little like a dumpster 18 A Not from any operation that I'm familiar with. 19 on chains on the back of a truck. The operators would 19 Q Well, sir, 1 wanted to go back to the design 20 drain still residue into the skip and the shipping 20 basis for the limestone pits. If an aqueous flow was going 21 department would take it away. 21 through a limestone pit that had suspended particles in it, 22 Q And that was in Aroclor? 22 would the suspended particles eventually have accumulated Page 526 Page 528 1 A That's what 1 remember. 1 on top of the limestone? 2 Q Now, when you were -- were you a supervisor for 2 A Possibly. You mean if there's suspended 3 production in Niran at all? 3 particles in the waste being fed to the limestone? 4 A No. 4 Q Correct. 5 Q At the time that you were at the Anniston plant, 5 A Depending on velocities and a lot of other 6 would the Niran plant have produced any appreciable 6 things, that's one of the things that might have happened, 7 quantities of solid sulfur waste? 7 is it would be found on the top of the limestone. 8 A The chlorination reaction to a great intermediate 8 Q Now, sir, did you ever actually see, let's start 9 called ethyl Pet or methyl Pet made sulfur as a 9 out with the biphenyl limestone pit, did you ever actually 10 by-product. There was something on the order of 2000 10 see it in operation when a charge of aqueous flow was going 11 pounds of sulfur made in every batch and that was 11 through it? 12 present -- that wound up in the still residue after 12 A Well, aqueous flow was always going through it. 13 distilling off the Pet, and so that sulfur would be in the 13 Q Could you estimate its depth in the limestone 14 form of small flakes or semiliquid gobs dispersed in the 14 pit, the flow of the aqueous substance? 15 still residue which was sent to the incinerator. 15 A No, 1 don't remember. 16 There was one other intermittent source of solid 16 Q Now, if a flow was always going through the 17 sulfur. In the event of improper operation of the 17 limestone pit, would the limestone have remained impervious 18 incinerator, some solid sulfur would form and tend to plug 18 to any channelization forces that the aqueous flow might 19 up the scrubber and the demister. And that would 19 have put upon it? 20 eventually be rinsed out of the system. 20 A 1 don't know. 21 Q So - 21 Q Is limestone an impervious type of substance? 22 A That was a small amount and occasional. 22 A This was crushed limestone, and simply as a Savage, James (Aroclor Dept employee) in AETNA (3) Pages 525 - 528 HARTOLDMONO010265 Page 529 Page 531 1 matter of random dumping of irregular particles, one 1 that was responsible? 2 normally expects that the flow tended to distribute itself 2 A It might have been. 3 reasonably uniformly. It's really a fairly complicated 3 Q But you don't know? 4 subject. 4 A The only alternatives was the maintenance 5 Q But it would have been studied when the decision 5 department or the shipping department, 1 should think. 6 was made as to what kind of limestone to put in? 6 Q Sir, going back to the shipping department, in 7 Mr. Burnett: Objection. Lack of foundation. 7 Aroclor, 1 believe you said that from time to time they 8 You can give an answer if you can. 8 would come by and pick up skiffs? 9 The Witness: 1 really don't know. There are 9 A Yes. 10 commercial grades of crushed limestone. 1 don't know that 10 Q Did they also from time to time pick up barrels? 11 there was any technical study as to which particle size to 11 A Yes, 1 think so. 12 purchase. 12 Q Could you describe for me what might have been in 13 By Mr. Meyer: 13 those barrels? 14 Q Well, sir, do you recall if limestone that might 14 A That would have also been Montars. 15 have been -- again, we're still on the biphenyl limestone 15 Q Might those barrels have been known as Carbide 16 pit -- that might have been placed there, would that have 16 barrels in reference to a product that at one time had been 17 been good for a year? 17 shipped from the Anniston plant known as Carbide, which was 18 A 1 don't think so. 18 of a specific gauge of steel? 19 Q Do you recall whether or not there was an ongoing 19 A 1 don't remember that but that could have been 20 maintenance program that required the excavation and 20 some old nomenclature. 21 replacement of limestone in the biphenyl limestone pit? 21 Q Sir, do you recall whether or not the Aroclor 22 A The limestone was consumed by the acidity in the 22 department had a filtration process in the stills or after Page 530 Page 532 1 waste and what 1 recollect was that this would depend on -- 1 the stills? 2 well, entirely on how much acid there was in the waste 2 A Yes, it did. 3 because each unit of acid would dissolve a certain amount 3 Q And was that for solid or liquid Aroclor? 4 of limestone and you could see that the limestone would 4 A Liquid. 5 slump downward and particularly right near the entrance as 5 Q And to your knowledge, what was done with the 6 the limestone was consumed, and as that progressed, 6 filtration paper after it had accomplished its purpose and 7 additional loads of limestone would be brought in and 7 was spent? 8 dumped on top. 8 A It was placed in some kind of container and 9 Q But to your knowledge, a whole charge of 9 hauled off. 10 limestone and -- for instance, the biphenyl limestone pit 10 Q Finally, sir, do you recall whether or not the 11 was not excavated all at once and replaced with a whole new 11 Aroclor department used lime in distilling? 12 one. 12 A Yes. 13 A That was done from time to time. 13 Q Could you tell me what the function of the lime 14 Q Could you provide an estimate of how often from 14 was? 15 time to time might have been? 15 A The lime was added to the still pot at the 16 A 1 don't know how often that was done. 16 beginning, 1 believe at the beginning of every batch. The 17 Q Who would have been responsible within the plant 17 lime was used as a chloride scavenger because it was fairly 18 for managing that? 18 well known that any ionizable impurity in the final product 19 A 1 don't know. 1 don't think it was the 19 would hurt the electrical properties of the fluid. So it 20 production supervisor because 1 didn't do it at the time 20 was a necessary step to getting good quality. 21 that 1 was a supervisor. 21 Q So that would have been for electrical grade 22 Q Could it have been the maintenance department 22 Aroclor? Savage, James (Aroclor Dept employee) in AETNA (3) Pages 529 - 532 HARTOLDMONO010266 Page 533 Page 535 1 A It was done for all liquid Aroclor because we 1 please. 2 didn't discriminate at the time of production as to whether 2 ( Witness reviewed the document. ) 3 the final product would be sold as electrical grade or some 3 A Okay. 4 other grade. 4 Q Sir, this, again, is a 1971 document and my 5 Q Oh, so it all had to meet the electrical grade 5 reading of that paragraph would seem to indicate that at 6 spec? 6 this point in time wastes going from the muriatic acid 7 A We attempted to make everything reach the 7 department for neutralization could have gone to one of two 8 electrical grade spec so we didn't have to keep track of 8 pits. Is that a fair reading of the document, sir? 9 inventory. 9 A Yes. 10 Q 1 understand. Sir, what happened to the lime, 10 Q Now, sir, there seems to be some suggestion in 11 was it consumed in the distillation process? 11 here that switching between the two pits was done in order 12 A Trivial amount would be consumed. Most of it 12 to reduce the amount of Pcbs that would have otherwise 13 would wind up in the Montar. 13 flowed through the pits and out into the outfall. And I'm 14 Q And then finally, sir, was one or the other of 14 wondering, sir, if you recall discussions that culminated 15 the Aroclors filtered through something known as Fuller's 15 in that operation decision. 16 or attapulgus earth? 16 A No, 1 read this paragraph the same way but 1 17 A Those are the same filters that you asked about 17 don't recall it. 18 before. There was a step called clay treatment after 18 Q 1 suppose, then, you don't remember your memo 19 distillation where diatomaceous earth was mixed with the 19 dated September 15, 1971. 20 Aroclor, and that was then filtered through filter paper, 20 A No, 1 don't. 21 and this was a platen frame filter press where pieces of 21 Q Why not? 22 paper are placed over frames and the clay would accumulate 22 A Because it's a long time ago. Page 534 Page 536 1 in the spaces between the paper, and when the filtration 1 Q 1 understand. 2 was finished, some kind of gas -- nitrogen, 1 think -- was 2 A As 1 mentioned earlier, this was an extremely 3 used to blow the free liquid out of the filter, and then 3 busy time and it was necessary to delegate things and not 4 the press would be opened and the paper and the clay 4 get involved in anything that 1 didn't have to get involved 5 dropped into some kind of container. 5 in. 6 Q And by clay, you're referring to diatomaceous 6 Q Well, sir, would the flow that was coming from 7 earth? 7 the muriatic acid department, would it have had solids in 8 A Yes. 8 the liquid, entrained in the liquid -- 1 guess it wouldn't 9 Q Also possibly known as Fuller's earth? 9 be entrained, but in the liquid itself? 10 A It's sometimes called that. 1 don't know that we 10 A Not likely. 11 called it that at the Anniston plant. 11 Q So you don't recall, sir, how the number one 12 Q Also known sometimes as attapulgus earth? 12 biphenyl limestone pit was rebuilt in 1970 in order to 13 A Yes, most of it comes from a town in Georgia. 13 conform to some plan of settling out solids? 14 Q Called Attapulgus? 14 A My opinion that these solids, the term" solids " 15 A Yes, there's a company there that uses that as 15 in this context refers to solids that actually originated 16 its trade name. 16 in the limestone pit. Limestone is not a pure material and 17 Q Sir, 1 wanted to go back to the exhibit and 1 17 it contains some materials such as silica that are not 18 wanted to direct your attention to page 8 of the text, 18 reactive, and therefore when limestone is consumed by 19 which has a Bates stamp number of 858. Are you with me, 19 reaction with acid, there is something left which would be 20 sir? 20 finely divided solids. It's my opinion that this is the 21 A Not yet. Okay. 21 solids that that refers to. 22 Q Could you take a few moments to study that, 22 Q So it's possible that Pets or Pcbs would have Savage, James (Aroclor Dept employee) in AETNA (3) Pages 533 - 536 HARTOLDMONO010267 Page 537 Page 539 1 become somewhat fixed or associated with those solids? 1 The secondary settler, solids would settle out, 2 A It's possible. 2 and in this particular plant as 1 recall it, all of the 3 Q Do you recall if Anniston plant personnel, and 3 solid was pumped back to the aeration basin because the 4 perhaps more specifically Mr. Gene Coley, did testing of 4 solids represented the carrier for biological organisms 5 Snow Creek to see if they could find globules of Aroclor in 5 that actually carried out treatment. Under a microscope, 6 the water? 6 you could examine the sludge and see that particularly when 7 A He may have but 1 don't know that he did. 7 treatment was going very well, a variety of different small 8 Q Now, sir, 1 believe you had mentioned that 8 living organisms, and those organisms somehow consumed the 9 several of the items we were mentioning in the Aroclor 9 various organic materials present and metabolize them. 10 department were being hauled off. Do you recall where they 10 Q Including Pnp? 11 were being hauled off to? 11 A Yes, Pnp was a very sensitive indicator since it 12 A No. 12 just takes a couple of parts per million of Pnp to be 13 Q But to your recollection it was a shipping 13 visible as a yellow color and waste. We could tell very 14 department that was doing the hauling? 14 well when the treatment plant was working well because the 15 A Yes. 15 feed would be bright yellow or perhaps so yellow it would 16 Q Do you recall who the supervisor of the shipping 16 look brown, and the effluent would be substantially 17 department was? 17 clearer. 18 A There was a gentleman called Pap Gray, H. L. Gray, 18 Q Sir, 1 believe you testified earlier this morning 19 who was in charge of shipping, and then there were one or 19 that you recalled a letter that was sent to the editor of 20 two foremen that reported to him. 1 don't remember their 20 the Anniston newspaper that amused you because someone was 21 names. 21 commenting that her husband was able to fish in Snow 22 Q Sir, could you describe for me how the biological 22 Creek. Page 538 1 treatment facility at Anniston as it was designed back when 1 A It was her father or grandfather as 1 recall. Page 540 2 you were there would have turned Pnp from, 1 guess, a toxic 3 substance into something relatively benign? 4 A Well, it was a biological treatment. The main 2 3 4 Mr. Burnett: Grandfather. By Mr. Meyer: Q And 1 believe it was your testimony that Snow 5 components of the process were the aeration basins and, as 5 Creek would not have existed but for the Monsanto plant. 6 1 recall, one secondary settler, although there may have 6 A It appeared to me to be an intermittent creek 7 been more than one. It was called secondary because in a 7 because in dry weather, upstream of the Monsanto outfall 8 large municipal treatment plant handling domestic waste, 8 there would be no flow. 9 there's also a primary settler that goes upstream. We 9 Q Sir, I'd like to direct your attention to the 10 didn't have one of those. We had only the secondary 10 exhibit that we saw earlier this morning that related to 11 settler. 11 Monsanto's description of what it seeks with respect to the 12 Waste would, after possibly some pretreatment 12 Anniston plant. I'm not sure 1 have the number. It's 13 such as ph adjustment, go into -- be fed to the aeration 13 got -- 14 basins through weirs along the side that would distribute 14 Mr. Burnett: 108. 15 the waste uniformly. The aeration basins, as the term 15 Mr. Meyer: 108. Thank you very much. 16 implies, had air spargers arrayed across the bottom of the 16 By Mr. Meyer: 17 basins, and a large quantity of air was pumped through so 17 Q And sir, 1 wanted to direct your attention to the 18 that the basins were vigorously agitated by the air bubbles 18 second page under the category li," Snow Creek." Are you 19 and -- could be seen, the liquid could be seen to be 19 with me? 20 rolling over in the basins and full of air bubbles. The 20 A Yes. 21 liquid would overflow another weir at the end of the basin 21 Q There's a discussion there that not only were 22 and go into the secondary settler. 22 Aroclor Pcbs found in sediments of Snow Creek but also a Savage, James (Aroclor Dept employee) in AETNA (3) Pages 537 - 540 HARTOLDMONO010268 Page 541 Page 543 1 related drainage ditch downstream of the Monsanto plant. 1 handwritten notes bearing a date Thursday November 14, 2 Could you shed some light on the distinction between Snow 2 1963. It was produced to us out of the headquarters of 3 Creek and the related drainage ditch that's described 3 Monsanto, so we know somehow or another it's not a Monsanto 4 there? 4 document, but it does not show, at least on its face, an 5 A No, 1 don't know what it refers to. 5 author or the circumstances that led to its creation. 6 Mr. Meyer: I'd like to have marked and 6 ( Savage Exhibit 120 identified.) 7 introduced as our next numbered exhibits sequentially, 7 By Mr. Meyer: 8 first a Monsanto memorandum dated January 9, 1 believe 1959 8 Q Mr. Savage, 1 would like for you to take a few 9 from a Mr. Boucher to a Mr. Green. 9 moments to study this welter and profusion of documents 10 The Witness: Could 1 take a coffee break? 10 that I've thrown at you and when you're ready, let me 11 Mr. Meyer: I'm sorry. Absolutely, yes. 11 know. 12 ( Recess.) 12 ( Witness reviewed the document.) 13 Mr. Meyer: I'd like to have introduced as our 13 Yes, 1 was going to direct your attention, sir, 14 next numbered exhibit, 115, a Monsanto memorandum dated 14 on the longer handwritten one. The page I'm most 15 January 9, 1959 from a Mr. Boucher to a Mr. Green, and its 15 interested in is the third page starting with " ventilation 16 general subject matter is disposal of Aroclor still residue 16 and residue handling." 17 bottoms. 17 A Okay. 18 ( Savage Exhibit 115 identified.) 18 Q Flave you had a chance to review these various 19 Mr. Meyer: Followed by a Monsanto memorandum 19 exhibits, sir? 20 dated February 11,1959 from a Mr. Boucher to a Mr. Pohl, 20 A Yes. 21 P-o-h-l, and its subject matter is" Meeting to discuss 21 Q Sir, could you tell me who Mr. Boucher was at the 22 overall plan for Aroclor department." 22 Anniston plant? Page 542 Page 544 1 ( Savage Exhibit 116 identified.) 1 A Ken Boucher was an engineer in the Anniston 2 Mr. Meyer: Followed by number 117, which is a 2 technical service department. 3 Monsanto memorandum out of Anniston dated July 19, 1962 to 3 Q So when you joined the plant, he would have been 4 a Mr. V. R. Haupt, H-a-u-p-t, from a Mr. W. L. Smull and its 4 in the same department as you? 5 general subject matter is " Aroclor disposal of still 5 A When 1 joined the plant, he was not there yet. 6 residues." 6 He came a year or two after me. He transferred from the 7 ( Savage Exhibit 117 identified.) 7 Queeny plant. 8 Mr. Meyer: For the record, the copy quality on 8 Q Do you recall, sir, who Mr. R. J. Green, the 9 117 is not very good. 9 recipient of Exhibit 115, is? 10 Mr. Burnett: 115 is not that great either. 10 A No, 1 don't recognize that name. 11 Mr. Meyer: Wait until you see 117. 11 Q Sir, 1 would like to direct your attention to 12 Followed by 118, which is a December 14, 1962 12 Exhibit 116. Are you with me? 13 Monsanto memorandum from a Burns 0. Severson to an 13 A Yes. 14 FI. L. Gray relating, again, to the disposal of liquid-solid 14 Q And specifically the discussion in subparagraph 15 Aroclor trappings. 15 A," disposal of still residue "? 16 ( Savage Exhibit 118 identified.) 16 A Yes. 17 Mr. Meyer: Followed by Exhibit 119 dated January 17 Q 1 was wondering, sir, if in 1959 you recall 18 4, 1963, Monsanto memorandum out of Anniston from a 18 whether or not the disposal of still residue in the Aroclor 19 Mr. E. W. Schramm to Burns 0. Severson. Again, the subject 19 department took up, as the author describes it, much of the 20 matter," disposal of liquid-solid Aroclor trappings." 20 available material handling space in the department? 21 ( Savage Exhibit 119 identified.) 21 A No, 1959, 1 didn't have anything to do with this 22 Mr. Meyer: And finally 120, which is a series of 22 area of the plant. Savage, James (Aroclor Dept employee) in AETNA (3) Pages 541 - 544 HARTOLDMONO010269 Page 545 Page 547 1 Q So you never visited it at that point? 1 some extent the same work force and overlapping in a lot of 2 A I'm sure 1 visited it, but 1 don't recall 2 ways, and so we had reached an agreement on what things he 3 anything specific about that period of time. 3 would look after and what things 1 would look after. So in 4 Q Well let's move on then, sir to Exhibit 118, 4 some ways, 1 was not doing all of the things that a 5 which 1 believe you are shown as having received a copy of, 5 production supervisor might do in that part of the plant. 6 and it's dated 1962. 6 Q Well, would that have included not keeping track 7 A Yes. 7 of costs? 8 Q Now, could you shed some light, sir, on what 8 A It would certainly have included keeping track of 9 Aroclor liquid-solid trappings means? 9 costs, but a few scrap drums would not have been a very big 10 A The term is familiar to me but 1 can't place 10 item. 11 where such material arose in the process. 11 Q So you don't recall, sir, in your production work 12 Q Would that have been another name for the still 12 in Aroclor, seeing collected pallets containing drums that 13 bottoms? 13 from time to time were retrieved by the shipping 14 A No. 14 department, loaded onto a truck with a fork load - 15 Q Could the trappings have been something that was 15 forklift, excuse me? 16 being collected? 16 A Oh, 1 can remember the image that you're 17 A Well, the term implies that, and if you'll see in 17 picturing, yes. 18 the second paragraph, it's described as a flammable 18 Q Could you describe that for me. How often, did 19 biphenyl material. The implication there is that it arose 19 that occur once a day? 20 fairly early in the process, perhaps in the off-gas and 20 A 1 don't know. It would have been a fairly 21 from the chlorinators. But I'm constructing that from this 21 routine thing. 22 sentence, not from recollection. 22 Q Where would the drums have been stored pending Page 546 Page 548 1 Q So you don't recall, sir, whether or not in this 1 their pickup by the shipping department? 2 period of time the Aroclor department needed approximately 2 A 1 don't know. 3 60 to 80 drums to collect these liquids? 3 Q Was there a platform at ground level outside of 4 A No, 1 don't remember that. 4 the Aroclor department building? 5 Q What position, again, would you have held in 1962 5 A 1 don't remember. 6 at the plant? 6 Q To your knowledge, sir, would most of the drums 7 A 1 was the production supervisor at that time. 7 that you just visualized, would they have been labeled in 8 Q For Aroclor biphenyl? 8 any way? 9 A Well, 1 had become chlorine supervisor in, 1 9 A 1 don't know. 10 think 1961, and at some point the liquid Aroclor, solid 10 Q Would any effort have been made to put tops on 11 Aroclor, Hb-40 area was added to my responsibility. Prior 11 the barrels? 12 to that time Burns Severson had responsibility for the 12 A 1 don't know. 13 entire biphenyl Aroclor area, and at some point his 13 Q Who within the department would have been 14 responsibility was divided in two and part of it added to 14 responsible for monitoring the flow of such barrels and 15 mine. But 1 don't know for sure whether that had already 15 asking for shipping to get them? 16 occurred on the date of this memo or not. Thefactthat 16 A One of the foremen. 17 I'm copied on the memo suggests that it had. 17 Q So they would have communicated directly with the 18 Q Well, as the supervisor, sir, would you have been 18 shipping department? 19 responsible for keeping track of expense items within the 19 A Yes. 20 department? 20 Q Now, sir, in the summary of this memorandum, 21 A As a general rule, yes, but Burns and 1 had a 21 Exhibit 118, there is the reference that the liquid-solid 22 somewhat awkward situation where we were supervising to 22 trappings, whatever they were, that were being put into Savage, James (Aroclor Dept employee) in AETNA (3) Pages 545 - 548 HARTOLDMONO010270 Page 549 Page 551 1 these used drums were, quote, going to be thrown " into the 1 shed some light on the quantities that are shown under 2 dump." Could you shed some light, sir, on what the author 2 subparagraph 4, ventilation and residue handling. What 3 might have meant by a dump? 3 does 180,000 pound symbol/year mean, to your knowledge? 4 Ain general terms, that would refer to a rather 4 A It implies that that's how much was sold in that 5 casual version of what we would now call landfill. 5 form, 180,000 pounds per year. 6 Q Now, earlier this morning you testified to two 6 Q So the pounds symbol means pounds? 7 landfills at the plant. One was on a site which we later 7 A Yes. 8 on pinned down to be Cleghorn's Lake and the other one was 8 Q Now, over to the right -- and the author has 9 across Alabama Highway 202. Could you identify which dump 9 collected those three subcategories of residue together - 10 you think the author intended in this particular 10 there is the phrase " one half to one " and then capital 11 memorandum? 11 letter with a bar over it M and then, again, the pound 12 A No, 1 have no idea. 12 symbol and again, slash, year. Could you shed some light 13 Q Let me ask you, do you ever recall seeing drums 13 on what Monsanto meant by a capital M with a bar over it? 14 in Cleghorn's Lake? 14 A The nomenclature has changed since that time, but 15 A 1 don't remember. 1 don't remember that there 15 at that time, the M with the bar over it referred to 16 weren't. 1 just don't remember. 16 million. So this would be one half to 1 million pounds per 17 Q 1 understand. Well it's been about 30 years. 17 year. 18 Let me ask you, sir, in your visits to the area across the 18 Q And what is the nomenclature today? 19 road where you believed at one time maybe dumping 19 A Today, we would use a simple capital M for 20 operations occurred and you did some shooting, do you 20 million and a K for thousand. In these days, we used an M 21 recall that area having an incinerator to burn trash? 21 without the bar for thousand and with the bar for million. 22 A 1 didn't see it. 22 Q Sir, below that there is a description of a Page 550 Page 552 1 Q How often, sir, would you say during your tenure 1 disposal method which 1 assumed relates to the distillers 2 at Anniston did you visit that facility across the road? 2 in the Aroclor department. Would 1 be correct in that 3 A 1 think it was just during the first year or two 3 assumption? 4 that 1 was there, and perhaps five times. 4 A Yes. 5 Q And the purpose, again, for all those visits was 5 Q So do you recall, sir, a procedure whereby at the 6 related to shooting? 6 end of a distillation run in the Aroclor department a drum 7 A Yes. 7 was placed under a ventilating hood and something known as 8 Q So -- 8 a drain valve was opened up? 9 A It was not authorized. 9 A This doesn't fit with my recollection for this 10 Q 1 see. 10 particular time. This is late 1963, which would be -- have 11 A 1 just did it. 11 been sometime around the end of my tenure at Anniston. 12 Q Well, we won't tell anyone and 1 guess you're 12 Probably a bit after 1 left. It was my recollection at 13 retired now so it doesn't matter. So none of your job 13 this time that we were using the skip method that 1 14 duties would have taken you up to that area? 14 mentioned earlier rather than using drums. 15 A No. 15 Q And that, again, was for the bottoms or still 16 Q Sir, 1 wanted to turn your attention to the 16 residue? 17 Exhibit Number 120, the handwritten one, and to 17 A Yes. 1 believe 1 left Anniston in September' 63. 18 specifically that page number 3. 18 Q Sir, 1 wanted to direct your attention again to 19 A Yes. 19 Exhibit 116. It's in that mass that 1 gave you all at 20 Q Now, again, we suffer under the disability that 20 once. It's the February 11, 1959 memo to Mr. Pohl. 21 we don't know who authored this or what the purpose of its 21 A 116 did you say? 22 preparation was, but 1 was wondering, sir, if you could 22 Q Yes, sir. Do you have it? Savage, James (Aroclor Dept employee) in AETNA (3) Pages 549 - 552 HARTOLDMONO010271 Page 553 Page 555 1 A Yes. 1 Q Now, I'm envisioning people getting big steel 2 Q Sir, in the paragraph B, there's a discussion of 2 drums and just banging them with sledgehammers. Is that ar 3 how apparently in 1959 solid Aroclors were poured into 3 accurate envisioning? 4 drums and allowed to solidify, and then later on, it was 4 A It's close. 5 necessary to break up the Aroclor with a sledgehammer. 5 Q Now did -- 6 When you became associated with Aroclor production, is that 6 A My recollection is that they were drums that had 7 your recollection of how certain solid Aroclors were 7 been split lengthwise and it was a matter of really of 8 retrieved and made useful? 8 casting material, pouring liquid material in there to cast 9 A 1 remember the sledgehammer operation, but at 9 a chunk, then this wet drum would be turned upside down and 10 some point we installed a flaker which was intended to 10 hit with a hammer to cause the material to drop out, and 11 eliminate that primitive kind of operation. Whether it had 11 then the drum would be taken away and the block of Aroclor 12 been completely eliminated at the time that 1 was 12 beaten to pieces with a hammer. 13 production supervisor, 1 don't recall. 1 believe that it 13 Q Now, to your knowledge, sir, was that splitting 14 had been eliminated when 1 was production supervisor but 14 and sledgehammer operation ever done with any of the 15 I'm not sure. 15 Montars? 16 Q Well, now, sir, what would the distinction have 16 A 1 don't recall it. It could have been. 17 been between liquid and solid Aroclor that made one solid 17 Q Sir, were you familiar in this period of time 18 and the other one stay liquid? 18 with whether or not Monsanto had a standard for worker 19 A Two different distinctions. As a convention, any 19 exposure to Aroclor in the ambient air of 1 milligram per 20 Aroclor derived from biphenyl was part of the liquid 20 cubic meter of air? 21 Aroclor line and any Aroclor derived from terphenyl 22 Santowax was considered to be part of the liquid Aroclor 21 A 1 don't remember that. 22 Q Do you recall any ambient air standard for worker Page 554 Page 556 1 line. But as a matter of -- 1 exposure to Aroclor fumes? 2 Q Excuse me, that was two liquids? 2 A 1 don't remember a quantitative measure. 3 A Excuse me, a solid liquid -- solid Aroclor line. 3 Q Do you remember any measure? 4 Q The one associated with Santowax was solid? 4 A No. As in any operation, there was an intention, 5 A That's right. That was a conventional 5 at least, to avoid exposure to fumes just as a general 6 nomenclature, but on the other hand, if biphenyl is 6 precaution, but 1 don't recall a quantitative standard at 7 chlorinated sufficiently, it becomes physically a solid. 7 that time. 8 For instance Aroclor 1268 was nominally part of the liquid 8 Q Who would have been responsible for setting such 9 Aroclor line but in fact it was a crystalline solid. 9 a standard, if one existed? 10 Q So would it be your testimony, in addition to the 10 A The medical department in St. Louis that handled 11 feedstock Santowax versus biphenyl, in addition, the 11 toxicology work. 12 quantity of chlorination would also determine whether or 12 Q Are you familiar with what function the Kettering 13 not the end Aroclor product would be a liquid or a solid? 13 Lab in Cincinnati might have performed from time to time 14 A That's right. 14 for Monsanto? 15 Q Since you mentioned 1268 in Exhibit 116, that is 15 A No, 1 don't remember it. We employed a number of 16 one of the solid Aroclors that would have been produced 16 outside laboratories. 17 from biphenyl but chlorinated to 68 percent? 17 Q Sir, during your tenure in the chlorine 18 A That's right. 18 department, do you recall any effort made to monitor 19 Q And that was a solid Aroclor which was going 19 mercury levels in the ambient air? 20 through this sledgehammer process? 20 A No, 1 don't remember that. Let me correct that. 21 A Originally, yes. It was a very high-melting 21 1 remember very vaguely some work with sampling tubes but 1 22 solid. 22 don't remember exactly what we were doing. Savage, James (Aroclor Dept employee) in AETNA (3) Pages 553 - 556 HARTOLDMONO010272 Page 557 Page 559 1 Q Do you think maybe these sampling tubes would 1 used for that purpose. They were called Therminol Fr, and 2 have in some way been measuring mercury concentrations? 2 for instance, Therminol Frl, Fr standard for fire 3 A Yes, 1 remember it in connection with mercury, 3 resistant. Frl was, in fact, identical to Aroclor 1242, 4 but 1 don't remember whether it was part of some general 4 and Fr2 was a higher grade of Aroclor. There was also an 5 program or a spot sample or what it was. 5 Fr3. 1 don't remember exactly how those corresponded to 6 Q Sir, in later years, if Monsanto had been 6 the number systems. But during the time that 1 was 7 sampling Snow Creek -- and specifically Mr. Coley -- for 7 supervisor of the Aroclor department, as 1 recall it, we 8 mercury concentrations, would there have been any 8 were shipping Therminol fluids, which in fact were Aroclors 9 department other than the chlorine department that could 9 with the designations of Frl, Fr2 and so forth. Then later 10 have been the source of any alleged mercury in Snow Creek? 10 on when we decided to end the sale of Pcbs as heat transfer 11 A Not that 1 know of. 11 fluids, the Fr series disappeared but the Therminol product 12 Q Could you shed some light on how you think maybe 12 line continued. 13 mercury might have gotten to Snow Creek from the chlorine 13 But even earlier than that, at the time that we 14 department? 14 were selling products called Frl and Fr2 and so forth, we 15 A The plausible path would be the overflow water 15 were also selling something called Therminol 66 which was 16 from the alkaline boxes. 16 relabeled Hb-40. It was a - it was not a fire resistant 17 Q And those were the alkaline boxes that we saw 17 fluid but was a very good heat transfer fluid and still 18 that went from the muriatic acid department down to the 18 sold for that purpose, and 1 think with the same name. 19 limestone bed? 19 Q Sir, during that period of time when you were in 20 A They entered that same sewer system, yes. 20 the Aroclor department and materials were being sold as, 1 21 Q So the chlorine department had a sewer system 22 that itself eventually connected to the muriatic acid 21 believe it was Frl and Fr2, did Monsanto have a policy 22 whereby customers of those products were allowed to return 1 department sewer system? Page 558 Page 560 1 so-called spent heat exchange fluids and then Monsanto 2 A My recollection is that that all came together in 3 a kind of tree configuration. But there might have been 4 some sequential flow from one department to another. 2 would turn around and send out a new batch that was fresh? 3 A Referring to the time that 1 was the production 4 supervisor? 5 Q Sir, 1 wanted to go back - oh, strike that. 6 Sir, in the late ' 60s and early ' 70s, do you 7 recall whether or not the organic chemicals division's 8 research department did research into efforts to modify 9 Aroclors from chlorination to the use of either bromine or 10 fluorine as the agent that was being applied to the 11 biphenyl Santowax? 12 A 1 can remember people talking about such a study 13 in later years but 1 was not familiar with it at the time. 14 Q Did the Therminol lines of heat exchange fluids 15 in later years replace Aroclor for certain product 16 purposes? 17 A That's not an exact characterization. Aroclors 18 were used for heat transfer fluids from some time before 1 19 started with the company. But at some point, a marketing 20 program to promote the use of Aroclors as heat transfer 21 fluid was undertaken, and as part of that, the Therminol 22 product line name was adopted to describe grades of Aroclor 5 Q Correct. 6 A 1 was not aware of it at the time. 1 believe 7 based on my later position as manufacturing manager that 8 some fluids were being returned by customers for 9 reprocessing but that was, as best 1 recall, not done at 10 the Anniston plant. 11 Q And that could have been done with some Aroclors 12 from other plants like Krummrich? 13 A Could have been. 14 Q But you're not sure? 15 A Well, we also shipped Aroclor called Therminol 16 Frl, 2 or 3 from the Krummrich plant. So if Therminol Frs 17 were being returned, they could have come from either 18 place. 1 don't know when that return program may have 19 begun or ended, but 1 remember that there was such a 20 practice. 21 Q Sir, when you joined the Anniston plant, to your 22 knowledge was the Aroclor department rated as a " toxic " Savage, James (Aroclor Dept employee) in AETNA (3) Pages 557 - 560 HARTOLDMONO010273 Page 561 Page 563 1 department within Monsanto? 1 Aroclor was being removed from the drums? 2 A 1 don't remember such a rating system. 2 A Well, the step of casting drums was no longer 3 Q At the Anniston plant or Monsanto-wide? 3 part of the process at that point. A flaker consisted of a 4 A 1 don't recall calling departments toxic 4 rotating drum with cooling water inside it and the rotating 5 departments or departments that weren't toxic. 5 drum would rotate through a pan that contained liquid feed 6 Q In later years did you become familiar with 6 of Aroclor 1268 or Aroclor 5460 and the solid material 7 Aroclor production at the Krummrich plant? 7 would coat the drum as it rotated out of the liquid. And 8 A Yes. 8 as the drum rotated it would pass under a blade called a 9 Q Did the Krummrich plant have a policy of 9 doctor blade which would scrape the flakes off the drum and 10 providing clean changes of clothes to the workers in the 10 the flakes would then fall into a hopper so that was a 11 Aroclor department each day to your knowledge? 11 process for one step converting the liquid into a 12 A 1 don't remember. 1 have worked at several 12 manageable solid. 13 plants, and 1 know there are some plants where certain 13 Q Now, sir, would that operation have occurred in a 14 departments are designated as toxic departments and there 14 warehouse? 15 are additional things provided to workers such as 15 A My recollection is that it occurred in the 16 additional changes of clean clothes but having been around 16 Aroclor department. 1 think there may have been a part - 17 for a long time and worked in a lot of places, 1 don't 17 a room in the Aroclor department that we may have called 18 remember which plant that was. 18 the warehouse for some reason. 19 Q Well, sir, going back to the bromine and fluorine 19 Q Now, would that same room have been used for 20 uses, to your knowledge did Monsanto ever have even bench 20 drumming of liquid Aroclors? 21 or pilot plant production of bromo-aroclor or arobrome? 22 A 1 remember those terms. In the early ' 70s when 21 A 1 don't remember. 22 Q Did the Aroclor department have a bagging machine Page 562 Page 564 1 we were very aggressively doing things to replace Aroclors 1 for placing solid Aroclor into bags? 2 from the product line, doing other things to minimize what 2 A Yes, a very simple one. 3 was then described as the Pcb problem. Materials of that 3 Q Did either the mechanism you just described for 4 kind were considered and 1 can recall conversations with 4 flaking as well as the bagging operation have any kind of 5 research where the term" arobrome " and so forth was used. 5 fume or vent control system? 6 1 believe that some materials like that were synthesized so 6 A 1 believe it did. 7 the properties could be determined. As far as 1 know we 7 Q Did that system then also have a scrubber that 8 never attempted to develop a process. 1 don't believe we 8 would take out and entrain solid particles? 9 ever commercialized a product like that. 9 A 1 don't remember that. 10 Mr. Meyer: Off the record. 10 Q Do you recall, sir, if the Aroclor building at 11 ( Discussion off the record. ) 11 Anniston had a trench sewer in the ground floor? 12 By Mr. Meyer: 12 A 1 think it did. 13 Q Sir, do you recall in the mid to late ' 50s 13 Q Would the trench sewer have had gratings so that 14 Monsanto and specifically a Mr. Ellenberg or Mr. Cleghorn 14 it could be opened up? 15 looking into the possibility of using Aroclor in paints? 15 A Yes. 16 A 1 don't recall those people being involved. 16 Q To your knowledge, sir, were there paved running 17 Q Do you recall any efforts that were being made at 17 areas or curbs outside of the Aroclor building? 18 the Anniston plant to use Aroclor in any kind of paints? 18 A Yes. There were paved areas. 1 don't remember 19 A No. 19 curbs in those days. 20 Q Sir, going back to Exhibit 116 in the solid 20 Q To your knowledge, sir, and recollection, was the 21 Aroclor that was being hammered out of these drums, how 21 Aroclor building a three-story building in this era? 22 would the flaking operation have changed how the solid 22 A 1 think it was. Savage, James (Aroclor Dept employee) in AETNA (3) Pages 561 - 564 HARTOLDMONO010274 Page 565 Page 567 1 Q And was it open on most sides? 1 piping in the Aroclor department and 1 was wondering, sir, 2 A Yes. 2 if that description is what you recall of the department at 3 Q And were the chlorinators outside? 3 that time? 4 A Yes. 4 A Yes, it seems to be. 5 Q And were they on their separate concrete pad? 5 Q Further on, sir, in paragraph d there's a 6 A Yes. 6 discussion of the fact that due to the high freezing point 7 Q And was that pad surrounded by a curb? 7 of solid Aroclors and the inadequacy of transfer piping 8 A 1 don't remember that it was. It's possible. 8 that the heating of all lines carrying solid Aroclors was 9 Q Do you recall, sir, where the trench that went 9 done with natural gas torches. Do you recall that 10 through the Aroclor building would have gone in terms of 10 practice, sir, in the department? 11 the kind of sewer that it was, if you go back to Exhibit 11 A Yes, 1 do. 12 114, which distinguishes between, 1 guess it was the Niran 12 Q Would you agree, sir, with the author's statement 13 sewer, the acid sewer as a storm sewers and the sanitary 13 that that practice, among other things, caused high 14 sewers. That was the long progress report, sir. 1 can 14 maintenance costs in the piping and fitting? 15 show you real fast if counsel has no objections so you 15 A Yes, it did. 16 don't have to root around. 16 Q Now, why would that be so? 17 A No, 1 don't know which sewer that would have gone 17 A The heat would, should 1 say, tort the piping and 18 into. 18 damage the bolts, damage the gaskets. In the case of 19 Q So 1 just wanted to confirm, sir, that the series 19 threaded pipe which was inappropriate anyway, it would burn 20 of memoranda that have been introduced 115 through 120 20 out the thread compound leading to leaks. 21 discussing generally the disposal of still bottoms and 21 Q While you were still at the Anniston plant, sir, 22 these trappings and so forth, you have no knowledge of the 22 was the Therminol heat transfer system mentioned in that Page 566 Page 568 1 dump or place that is referred to in those various 1 paragraph ever installed? 2 memoranda what the authors were talking about? 2 A 1 don't remember. 1 remember being strongly in 3 A No. It would be speculation on my part. 3 favor of it, but 1 don't remember whether it was done. 4 Mr. Meyer: I'd like to have introduced as our 4 Q And to confirm, sir, that would be a Therminol 5 next numbered exhibit, 121, a Monsanto progress report 5 heat exchange system as we were discussing a little while 6 dated as of June 7, 1963 and 1 apologize, 1 scribbled on 6 ago? 7 your copy, Jim. And its general subject matter is 7 A Yes. The date on this report is near the end of 8 long-range plans for the Aroclor department. And the 8 my time at the Anniston plant. 9 witness is shown as having received a copy of it. 9 Q Yes, 1 was going to assume that that would have 10 ( Savage Exhibit 121 identified. ) 10 been the case. Sir, did the Aroclor/biphenyl department at 11 ( Witness reviewed the document. ) 11 this time have its own cooling tower? 12 The Witness: Okay. 12 A 1 don't remember. Probably so, but 1 don't 13 By Mr. Meyer: 13 remember. 14 Q Sir, do you generally recall the subject matter 14 Q Sir, were you at all involved in procedures 15 of this memorandum? 15 leading to the installation of continuous chlorinators at 16 A The title is process improvement program. It was 16 the Anniston plant for Aroclor? 17 normal to have such a program for each of the departments. 17 A The installation was completed before 1 became 18 It covers fairly typical subject matter of such a plant. 18 production supervisor. This did not involve installing new 19 Q Sir, 1 wanted to direct your attention to page 3 19 chlorinators. As 1 recall, the project represented 20 of the report and specifically subparagraph c. 20 repiping some batch chlorinators so they could be operated 21 A Yes. 21 in a continuous mode. 22 Q There is a description in there about the process 22 Q Could those have been chlorinators five through Savage, James (Aroclor Dept employee) in AETNA (3) Pages 565 - 568 HARTOLDMONO010275 Page 569 1 eight? 2 A 1 believe that's right. 3 Q And as part of the continuous chlorination 4 process, did that result in larger quantities of entrained 5 materials in the off gas, the Hcl, to your recollection? 6 A 1 don't remember that. That equipment was 7 started up before 1 took over so if there was some change 8 in the nature of the operations, 1 wouldn't have observed Page 571 1 consistently applied. And they preferred not to take the 2 risk of having a second source. They liked the idea of 3 having a second source from the same point of reliability 4 of supply, but from a quality standpoint they generally 5 preferred to receive Anniston material is my understanding. 6 Q Would you have any knowledge, sir, of whether or 7 not until the very end Aroclor was a profitable item for 8 Monsanto? 9 it. 10 Q Would the continuous chlorinators have only been 11 used for Aroclor 1242? 9 A 1 believe it was profitable. 10 Q Would it have been more profitable, say, than 11 parathion? 12 A That was true nearly all of the time except that 13 we did one time make a run of a couple weeks in Aroclor 14 1248. 15 Q Sir, do you recall either in this period or later 16 on in your tenure at Monsanto who the single largest 17 customer for Aroclor was? 18 A 1 presume it was one of the electrical companies. 19 Q Could it have been General Electric? 20 A That seems likely. 21 Q Do you recall, sir, whether or not General 22 Electric had a standing practice where it only wished to 12 A 1 doubt it. 13 Q During the period you were at Anniston and later, 14 Monsanto did not have a specific patent protecting Aroclor; 15 is that true? 16 A That's true. 17 Q But at one time Swan did have a patent, is that 18 also true? 19 A 1 don't think so. 1 don't know that for sure 20 because 1 never studied the question, but it's my 21 understanding that the use of chlorinated biphenyl for 22 capacitors was actually invented by General Electric, so it 1 purchase Aroclor from the Anniston plant? Page 570 Page 572 1 seems to me a bit strange that Swan would have had a patent 2 A At one time they had expressed a preference for 3 the Anniston plant, but 1 also think that we did ship 4 General Electric from Krummrich plant on occasion. 2 unless perhaps it was a process patent. 3 Q To your knowledge -- 4 A This is all before 1 was born, incidentally. 5 Q Do you recall why it was that they preferred 5 Q Fair enough. To your knowledge did any other 6 Anniston Aroclor? 6 American companies produce polychlorinated biphenyls? 7 A There had been an incident a couple of years 7 A Not that 1 know of. 8 earlier before 1 started with the company. 1 don't 8 Q Did any companies in the rest of the world 9 remember exactly when it was, but it was a well-known story 9 produce them? 10 that General Electric had received some Aroclor from the 10 A Yes. 11 Anniston plant, 1 think, which proved to be unstable. 11 Q Could you tell me who those companies were? 12 Unstable in that context meant that some of the chlorine in 12 A Rhone-poulenc in France, Bayer in Germany, the 13 the molecule was present in a different structure than the 13 Japanese company, 1 believe it was Kanegafuchi. And 1 14 way it was supposed to be. Now, the result of that was 14 believe that some similar material was made in the Soviet 15 some capacitors that failed prematurely which cost General 15 Union. 16 Electric a lot of money, and this of course led to an 16 Q Probably still is. 17 investigation conducted by both General Electric and 17 A 1 hope not. 18 Monsanto which led to some more careful practices on the 18 Q Sir, was the trench that you were describing 19 way catalyst was added to the chlorinators. 19 earlier today where the bad batches of Niran fell out into, 20 And it's my understanding that General Electric 20 could that have also been known within the plant as a 21 had expressed a preference to have a single source to try 21 cubical trench? 22 to assure themselves that those new measures would be 22 A Yes. Let me correct part of the implication of Savage, James (Aroclor Dept employee) in AETNA (3) Pages 569 - 572 HARTOLDMONO010276 Page 573 Page 575 1 your question. It was not bad batches of Niran. That 1 A Dry chlorine is normally handled in carbon 2 would imply that it was batches from the condensation 2 steel. Wet chlorine is extremely corrosive. 3 reactor literally containing parathion. 1 don't know of 3 Q Did the chlorine in the chlorinators become wet 4 any batches from that reactor that ever were in fact put in 4 through the mixing with the Santowax or the biphenyl? 5 the trench. The incidents that 1 know of involved the 5 A It should not have. 6 intermediate. 6 Q So would it be your testimony that no special 7 Q Thankyou. Sir, going back to Exhibit 121, the 7 precautions needed to be taken with corrosion in the 8 general discussion in the first pages of some problem areas 8 chlorinators in the Aroclor? 9 in the Aroclor department. 9 A That's generally true. The chlorinators were 10 A Yes. 10 made of steel, including the chlorine distributor. If 11 Q And 1 was wondering, sir, if the reference to the 11 there was some error that resulted in moisture getting in 12 below standard process piping would be to your knowledge 12 the chlorinator, that would be a very serious problem, but 13 what we were seeing earlier on page 3 with respect to the 13 it didn't require any remarkable precautions that 1 14 irregular piping in the department? 14 remember of that happening. 15 A Yes. 15 Q Would the same have been true of the chlorinators 16 Q Do you think anything else was meant by the 16 in the Niran department? 17 author? 17 A Absolutely not. 18 A No. 18 Q Why was that? What was the difference? 19 Q Do you think, sir, the reference to heating is a 19 A That was a very corrosive environment. Those 20 reference to the installation later on of a Therminol 20 chlorinators were made of what's called a glass line 21 system as opposed to the open torch system? 21 steel. It's like glass. The internals were metal, 22 A 1 think it probably referred to a little more 22 expensive alloys like Monel, Hastelloy C and the agitators Page 574 Page 576 1 than that. Some of the materials that were handled in that 1 were also an expensive alloy. That was a much more 2 piping had melting points above the condensation 2 aggressive environment. 3 temperature of the steam available so while steam tracing 3 Q And is that because the chlorine that was being 4 was used on those lines it was futile because the steam was 4 used in the Niran chlorinators somehow or another was in a 5 not hot enough to actually accomplish the purpose and for 5 liquid form? 6 those lines a Therminol heating system or an electrical 6 A No, it had nothing to do with the form of the 7 heating system would have been necessary to really make any 7 chlorine. It was the product itself that was corrosive. 8 progress. There were other places in the department where 8 Q The thio acid? 9 simply upgrading steam jacketing or steam tracing could 9 A Thio acid or intermediate. 10 have been sufficient if it was done correctly. 10 Q Sir, the reference in g. to residue handling 11 Q Now, the chlorinators were jacketed with steam, 11 facilities of Exhibit 121, do 1 think that that most likely 12 weren't they, in the Aroclor department? 12 is a reference to the same subject that we saw on exhibits 13 A No. The process required cooling rather than 13 115 through 120? 14 heating. 14 A Yes. 15 Q I'm sorry, you're right. 15 Q Do you believe the author -- well, what do you 16 A Chlorination. 16 believe the author meant by that being a problem area? 17 Q So it was cooling water? 17 Mr. Burnett: Object to the form of the question. 18 A It was cooling water. At the moment I'm trying 18 The Witness: 1 don't see anything in the details 19 to remember whether there was a cooling coil or cooling 19 that sheds any light on that question. 1 can only assume 20 jacket. 1 don't remember which. 20 that this means that the problem had not been 21 Q Now, the chlorine would have been a fairly 21 satisfactorily resolved at this time. 22 corrosive substance, wouldn't it have? 22 By Mr. Meyer: Savage, James (Aroclor Dept employee) in AETNA (3) Pages 573 - 576 HARTOLDMONO010277 Page 577 Page 579 1 Q Sir, going back to Exhibit 108, which was the 1 A 1 don't recall this memorandum. 2 description by Monsanto of what it seeks in the lawsuit 2 Q Do you recall the general subject matter of the 3 with respect to the Anniston plant. Are you with me, sir? 3 memorandum? 4 A Yes. 4 A Yes. 5 Q Sir, at the bottom of the page in the description 5 Q Now, do you believe, sir that the limestone pit 6 of the solid waste landfill area the statement is made by 6 that is referenced in here would be the limestone bed that 7 Monsanto that" approximately 70 percent of the waste 7 was associated with the waste treatment facility at the 8 shipped to the landfill originated in the parathion 8 Niran department? 9 department." 9 A Yes. 10 Now, sir, based on your experience at the 10 Q And that would be distinguishable from the 11 Anniston plant, could you shed some light on what kinds of 11 incinerator neutralization scrubber pit? 12 waste would have been sent to a dump or landfill type 12 A Yes. 13 facility? 13 Q And still distinguishable yet another time from 14 A No, 1 can't. This document of course originated 14 the biphenyl limestone pit or pits? 15 in 1991. 15 A Yes. 16 Q Correct. 16 Q Now, what would the phrase " the bypassing " do you 17 A And 1 left the Anniston plant in 1963. 17 think have been intended by you at this time? 18 Q Yes, and my question was more going to be based 18 A 1 don't remember the problem, but just from the 19 on your operating experience and your experience in setting 19 context of this sentence it implies a channel in effect 20 up the plant and so forth. It would be my understanding as 20 whereby flow might get through without thoroughly 21 a lawyer but certainly not as a chemist or a chemical 21 contacting the limestone. 22 engineer or anyone who knows anything about chemistry that 22 Q Now, could that be similar to the questioning 1 Page 578 Page 580 1 the whole point of the parathion department was to treat 1 had earlier about the channelization of the limestone in 2 the wastes either in the incinerator or in the biological 2 beds? 3 treatment facility, which is why I'm surprised that the 3 A Same issue although 1 think at that time we were 4 bulk of the waste that apparently later on went to the 4 talking about the biphenyl bed. 5 landfill would have originated in that department. 5 Q Yes, sir. Now, sir, how would the ph level of 6 A Yes, 1 can only suppose that this reflects a 6 the effluent going through the limestone pit have been 7 change in practice from the time that 1 was at the Anniston 7 measured in this area? 8 plant. 8 A The measurement of ph is done with a simple 9 Q Fair enough, sir. Well, sir, I'd like to turn to 9 electronic instrument either by taking a sample and 10 our next numbered exhibit and again whenever you wish to 10 measuring it with a laboratory type instrument or sometimes 11 take a break, please let me know. 11 a continuous instrument is attached to the process so that 12 A Now is a good time. 12 there can be a continuous readout. 1 don't know which this 13 ( Recess. ) 13 was but the basic principle is the same in either case. 14 Mr. Meyer: Our next numbered exhibit will be 122 14 Q Sir, do you recall when you first joined the 15 which for the record is an October 13, 1960 Monsanto 15 plant there being a dispute or disagreement between the 16 memorandum out of Anniston from the witness to a 16 city of Anniston and Monsanto relating to sampling of 17 Mr. Stutz. 17 effluent that was going from the Niran plant to the city 18 ( Savage Exhibit 122 identified. ) 18 waste treatment facility? 19 ( Witness reviewed the document. ) 19 A No. 20 The Witness: Okay. 20 Q To your knowledge, sir, when the Niran plant was 21 By Mr. Meyer: 21 first opened up did the waste effluent from the Niran 22 Q Sir, do you recall the memorandum at all? 22 department go to the city for primary treatment? Savage, James (Aroclor Dept employee) in AETNA (3) Pages 577 - 580 HARTOLDMONO010278 Page 581 Page 583 1 A At the time that 1 arrived at the plant it had 1 arrows how you understood the waste treatment facility 2 been running for about a month and the waste was going to 2 worked at the Anniston plant? 3 the city sewer for treatment. That treatment would have 3 A In the Niran waste treatment facility? 4 been to my knowledge primary and secondary. 4 Q Yes, sir. 5 Q So the Monsanto plant had no facility of its own 5 A Yes, that's pretty simple. 6 at that early point in time? 6 ( Witness complied. ) 7 A Only the limestone bed to correct ph. 7 Mr. Meyer: Let the record reflect that the 8 Q Do you recall whether cost was a consideration in 8 witness has handed me a one-page drawing. 9 determining whether Monsanto decided to build a secondary 9 By Mr. Meyer: 10 treatment facility of its own as a first step in waste 10 Q Now, sir, in prior testimony today reference was 11 treatment from Niran? 11 made to something known as either a lagoon or a pond. Does 12 A My understanding at the time was that we decided 12 that particular structure appear on this drawing? 13 to build our own plant because the capacity of the city 13 A No. 14 plant was at best marginal handling waste from our plant as 14 Q Now, where, once that structure was added in this 15 well as the other wastes they had to receive, and we 15 process, would that have appeared? 16 expected there would be continuing problems if we didn't 16 A It would have been downstream of the limestone 17 alleviate that by building our own plant. There was a cost 17 bed and 1 think upstream of the aeration basins. My 18 impact in the sense that the bill that we paid to the city 18 recollection of the lagoon or the pond was that it was 19 was partly based on the Bod loading but on the other hand 19 built as a test unit considerably before the waste plant 20 when we built our own plant, we incurred a lot of new fixed 20 was built and was an experiment intended to find a more 21 variable costs which 1 suspect were at least as large. 22 Q So you don't recall circumstances -- any 21 economical way of treating and 1 also remember that it was 22 rebuilt at least once and its operation may have been Page 582 Page 584 1 disagreements between Monsanto and the city relating to Bod 1 continued as a way of reducing the overall load. But 2 testing when most of the flow or all of the flow was going 2 whether it continued during the extended period that the 3 to the city treatment facility? 3 large waste treatment plant was in operation, 1 don't 4 A 1 don't remember a testing issue. That's not 4 remember. 5 necessarily something 1 would have been involved in any 5 Q Sir, 1 would like for you to go back to the 6 way. 6 various maps that we looked at in Exhibit 114. Exhibit 114 7 Q Sir, 1 wanted to confirm on Exhibit 122 that the 7 was the progress report with the figures and maps that we 8 reference to the aeration basin is a reference to that 8 had looked at earlier. And the maps for your convenience 9 structure that we were discussing earlier where bubbles 9 are at the end. Sir, on the various maps 1 acknowledge 10 were basically inserted into the waste? 10 that there's difficulty with the copy quality, but if you 11 A Right. 11 look at page 20 or figure 5 which has a Bates stamp number 12 Q And do you recall, sir, at this time did the 12 1401870? 13 plant have more than one aeration basin? 13 A Yes. 14 A Yes, the original design of the waste treatment 14 Q Now, to orient ourselves, the incinerator 15 plant had two basins side by side. 15 scrubber neutralization pit that we saw earlier today is 16 Q In later years did that change at all? 16 off to the south and in fact is very close to something 17 A 1 believe that after 1 left the plant they added 17 that's captioned circled numbers indicate priority order. 18 more. 18 Going from there, yes, would you be able to identify where 19 Q But you weren't involved in that at all? 19 the aeration basins were or are on this map realizing, of 20 A No. 20 course, that this is a 1971 map and maybe we have more of 21 Q Sir, if 1 gave you a piece of paper, would it be 21 them to deal with? 22 possible for you to draw me with little boxes and little 22 A 1 believe the aeration basins kind of run off the Savage, James (Aroclor Dept employee) in AETNA (3) Pages 581 - 584 HARTOLDMONO010279 Page 585 Page 587 1 top of this drawing. 1 Q Right, but those parts that do appear? 2 Q Where are you? 2 A At the time that 1 was there, the waste 3 A Up in here. 3 chlorinator was - call that number one - was up here in 4 Q 1 see. So they are not depicted on the map? 4 the department. 5 A Well, there's an outline that 1 think is part of 5 Q Could you do a larger number, sir, on subsequent 6 the aeration basin but I'm not sure. 6 copies. That's not going to do too well. 7 Q How about the lagoon or the pond, is that a 7 A The limestone beds we'll call number two, I'll 8 configuration that appears on this figure? 8 just identify like this. Then the holding tanks number 9 A Just over, 1 believe this rectangular structure 9 three would be an area. Then, as 1 recall, there were 10 here is the compressor building and this thing over here, 10 pumps here to move the effluent over to the aeration basins 11 that's a regular object here that appears to be a pond, but 11 and it appears roughly the aeration basins are in this 12 that's not what 1 remember. The test pond that 1 remember 12 position. 13 is down here near the holding tanks. 1 may have just 13 Q Now, was all the piping, sir, that was 14 forgotten this. It seems like a rather large thing to 14 transporting what 1 assume was primarily a liquid waste 15 forget, but it doesn't ring a bell with me. 15 perhaps with some settled solids in it, were those 16 Q Now, are the holding tanks something that are 16 pipelines aboveground? 17 very visible on this map? 17 A 1 believe they were cast iron lines underground. 18 A Yes, they're down here. 18 I'm not sure of that. That would have been normal sewer 19 Q Could you do me a favor then, sir. Do you have a 19 practice. 20 pen? I'll hand you my pen. If you could circle the area 20 Q Do you recall, sir, before you left the plant in 21 that you have just identified as the holding tanks. And 21 1963 whether or not that perhaps might have been the acid 22 then off the to the side perhaps write " holding tanks " and 22 sewer line in the Niran department had to be replaced Page 586 Page 588 1 let the record reflect that that's what the witness is 1 because it had been corroded out? 2 doing. 2 A 1 don't remember that. That's possible. 3 Now, sir, is it possible to identify the 3 Q 1 believe you testified earlier today, sir, that 4 limestone bed on this particular map? 4 the clay pipe or vitrified pipe, was it? 5 A Yes, it's the -- 1 believe it's the curved 5 A Yes. Or what was a later exhibit called, stone 6 outline just above, just above the holding tanks. 6 wear? 7 Q So let the record reflect that the witness is 7 Q Yes. That that was being used with the 8 identifying the limestone beds on this particular map. 8 chlorinators for the waste treatment facility? 9 Now, was the secondary settler known as something 9 A No, this is a wet -- the original chlorinator 10 else? 10 which was put in as an urgent, almost stop-gap project. 11 A Not that 1 know of. It might have been just 11 Q That was the chlorinator for the effluent? 12 called a settler. Sometimes such a device is called a 12 A That was the effluent chlorinator which was made 13 thickener. 13 of some ceramic material which has been described as stone 14 Q Now, on this map that you drew me, 1 don't see 14 wear. As 1 recall it, that was of the construction called 15 the holding tanks. Where would they have been? 15 Bell & Spigot where there's a wide end on one end of the 16 A They were, 1 would have - 1 didn't show them 16 piece of the pipe and a narrower end on the next piece of 17 because they're essentially a wide spot line. They're 17 pipe and some packing is put in to seal the joint and that 18 downstream of the limestone bed. 18 was the temporary or expedient chlorinator that was 19 Q So if we go back to that figure, sir, could you 19 installed soon after start-up. It was later on replaced 20 draw little numbers to correspond to our little map that 20 with something better. 21 we've got here that you've drawn for me? 21 Q Sir, 1 wanted to go back to your testimony 22 A Well, not everything is on the map. 22 earlier today on the design basis for the Niran limestone Savage, James (Aroclor Dept employee) in AETNA (3) Pages 585 - 588 HARTOLDMONO010280 Page 589 Page 591 1 bed. There is some evidence to suggest, sir, as part of 1 limestone pit was in existence when you got to the plant; 2 some Garrett & Miller studies that were done in the 1980s 2 is that true? 3 that Monsanto had two limestone beds for the Niran plant. 3 A Yes. 4 Do you recall, sir, whether or not the waste treatment 4 Q So you don't recall its design basis? 5 facility as it was configured when you were there had one 5 A No. 6 or two limestone pits? 6 Q Did you ever see any drawings for it? 7 A 1 remember that they had one. 7 A No. 8 Q Do you think, sir, in later years when you had 8 Q Did you have any construction or other 9 oversight responsibilities -- 1 realize not so much with 9 supervisory responsibilities when the limestone bed was 10 Niran or parathion -- do you think that you recall the 10 constructed, the Niran one? 11 construction of a second limestone bed for Niran? 11 A No. 12 A No. Perhaps the study referred to the other 12 Q Do you recall if Monsanto employees did the 13 limestone bed that was used in conjunction with scrubber 13 construction? 14 water as being in general part of the Niran facility, as 14 A Most of the construction of the Niran plant was 15 being a second limestone bed. 15 done by contractors. There may have been certain parts of 16 Q Perhaps. 16 the plant that were built by Monsanto employees. The Niran 17 A Let me point out that in the oversight 17 plant construction was completed when 1 arrived at the 18 responsibilities 1 had as manufacturing manager in the 18 site, so 1 didn't witness who did any particular part of 19 early' 70s, 1 had no responsibility whatsoever for that 19 it. 20 side of the plant, so anything 1 learned about it would 20 Q So you couldn't shed some light on who would have 21 only have been a matter of casual personal interest. 21 been responsible primarily for the construction of a 22 Q Well, sir, going back to the design basis for the 22 limestone bed? Page 590 Page 592 1 Niran limestone bed that was installed, 1 believe it was 1 A No. 2 your testimony earlier today that you recalled seeing some 2 Q Sir, on the construction of the limestone bed for 3 drawings showing that limestone bed? 3 Niran 1 believe it was your testimony that there would have 4 A Yes. 4 been the membrane and then the clay as a bed and then 5 Q Now, was this a facility that was excavated into 5 finally the limestone was placed on top of that, is that a 6 the ground? 6 correct statement? 7 A Yes. 7 A That's right. That's a standard method of 8 Q And then was concrete placed into it like we saw 8 construction. That's what 1 remember is the way that one 9 with the aeration basins? 9 was constructed. 10 A No, 1 don't remember that there was any concrete 10 Q When you say" standard method of construction," 11 involved. 11 would that be for neutralization pits? 12 Q But you recall that there was some sort of liner 12 A Any time a membrane is used, it's common to place 13 membrane that was being put into it? 13 a clay or sand or some material like that on top simply so 14 A 1 remember seeing that on the ground. 14 that stones or sticks or whatever won't puncture the 15 Q Now, how would that have been shown on the 15 lining. 16 drawing? 16 Q Now, was the neutralization scrubber incinerator 17 A Just in a cross-section drawing. It would have 17 pit in existence when you arrived at the plant? 18 been shown as a line with some kind of identifying note. 18 A No. 19 Q But you can't shed any light on what you think 19 Q So that was added later? 20 the liner would have been made from? 20 A Yes. 21 A No. 21 Q But during your tenure at the plant? 22 Q Now, 1 believe you testified that the biphenyl 22 A Yes. Savage, James (Aroclor Dept employee) in AETNA (3) Pages 589 - 592 HARTOLDMONO010281 Page 593 1 Q Could you describe for me its construction? 2 A 1 don't have any recollection at all of how that 3 was constructed. 4 Q You don't recall seeing any drawings similar to 5 the one you saw with the Niran limestone bed? 6 A No. 7 Q Can't shed any light on who would have done the 8 work? Page 595 1 A Just represented in essence a new raw material 2 being used in the area, and it would have been fairly 3 routine to ask whether there was any particular precaution 4 that needed to be taken. 5 Q Now what area? 6 A In the Niran department. 7 Q Well, was this sodium hypochlorite manufactured 8 at the Anniston plant? 9 A No. 10 Q Do you believe that -- strike that question. 11 Mr. Meyer: 1 would like to have marked and 9 A There was a sodium hypochlorite by-product stream 10 that existed in the brine area of the chlorine plant. So 11 it's possible that it came from there rather than being 12 introduced as our next numbered exhibit a Monsanto 13 memorandum authored by the witness dated June 15, 1959 14 regarding sodium hypochlorite eye irritation. 15 ( Savage Exhibit 123 identified. ) 16 ( Witness reviewed the document. ) 17 The Witness: Okay. 18 By Mr. Meyer: 19 Q Sir, first of all do you recall the general 20 subject matter of the memorandum? 21 A Yes, just vaguely. 22 Q Now, do you recall, sir, as part of the operation 12 purchased, but 1 can't deduce that from this and 1 don't 13 remember. 14 Q Do you recall any specific instances where this 15 sodium hypochlorite was tested and workers complained of 16 eye irritation caused by its use? 17 A 1 don't remember that. 18 Q Do you recall, sir, whether or not in the Niran 19 department perhaps in the manufacture of the thio acid that 20 prolonged contact to that, to those fumes, caused eyeballs 21 to blister? 22 A We had a discussion yesterday about an eye Page 594 Page 596 1 of the Monsanto waste disposal facility the spraying of a 1 irritant. What 1 recall is that eye irritant was not the 2 hypochlorite solution? 2 thio acid but rather the ethyl Pet. 3 A 1 remember considering the possibility. Whether 3 Q So to your knowledge, sir, you don't recall if 4 we actually implemented this practice, 1 don't remember. 4 this sodium hypochlorite was used as a means of odor 5 Q Would that have been as an odor control method? 5 control at the waste disposal facility? 6 A Yes. What this speaks to is reducing the 6 A No, 1 don't remember. 7 concentration of sulfur fights in the air, which would have 7 Mr. Meyer: I'd like to have marked and 8 been an order issue. 8 introduced as our next numbered exhibit what appears to be 9 Q Before you used something like this hypochlorite, 9 a telegram sent to Mr. Stutz from the witness. 10 you wanted to get the input from the medical department as 10 ( Savage Exhibit 124 identified. ) 11 to its possible harmful effects? 11 Mr. Meyer: Its date is April 12, 1960. 12 A That's what this letter seems to indicate, just 12 ( Witness reviewed the document. ) 13 asking for advice. 13 The Witness: Yes. 14 Q Do you recall whether or not you got a response 14 By Mr. Meyer: 15 from Mr. Wheeler? 15 Q Well, sir, first of all 1 was wondering do you 16 A Dr. Wheeler, no, 1 don't know whether 1 got a 16 recall sending a telegram to Mr. Stutz on data of this 17 response. 17 kind? 18 Q So to your knowledge you don't know if you ever 18 A 1 telexed the people in organic engineering that 19 used this sodium hypochlorite for that purpose? 19 1 was working with very regularly with data, so this would 20 A No. 20 be part of a normal practice. 21 Q How did you know to ask Dr. Wheeler about eye 21 Q Now, why were you telexing the information to 22 irritations caused by this sodium hypochlorite? 22 St. Louis? Savage, James (Aroclor Dept employee) in AETNA (3) Pages 593 - 596 HARTOLDMONO010282 Page 597 Page 599 1 A Telex was the convenient and rapid method of 1 introduced as our next numbered exhibit a letter to 2 doing it. Obsolete now but the standard method at that 2 Mr. Ullmer at Dorr-oliver, Incorporated from the witness. 3 time. 3 1 guess that will be 125. 4 Q Now, do you recall, sir, what the wood tank was 4 ( Savage Exhibit 125 identified. ) 5 that's referred to in the text of your telex? 5 ( Witness reviewed the document. ) 6 A No. 6 The Witness: Okay. 7 Q So you don't recall the waste treatment facility 7 By Mr. Meyer: 8 in Niran having a wood tank? 8 Q Sir, do you recall Mr. Ullmer at a company called 9 A No. 1 don't remember there ever having been a 9 Dorr-oliver? 10 wood tank that was part of the regular department. 1 10 A I'm familiar with the Dorr-oliver Company. They 11 believe there may have been a wood tank that was part of 11 make waste treatment equipment. 12 the pilot plant, so this may reflect work that 1 did for 12 Q Do you believe, sir, that the correspondence you 13 Cliff on the pilot plant. 13 were directing to Mr. Ullmer would have been related to the 14 Q Okay, now in April of 1960 was the waste 14 waste treatment facility at Anniston then? 15 treatment facility at the Anniston facility up and running 15 A The text refers to a water trench which runs 16 or was it still in the pilot plant stage? 16 under a group of reactors, so 1 presume that's what we've 17 A 1 don't know. 17 been calling the cubical trench. 18 Q Sir, do you recognize the handwriting in the top 18 Q 1 believe it was your testimony this morning, 19 portion of the telex? 19 sir, that that trench always had water in it? 20 A That's mine. 20 A Yes. 21 Q So you recognize the writing? 21 Q And if there was a bad batch that would just be 22 A Yes, that's my handwriting. 22 simply released into the cubical trench, was that true? Page 598 Page 600 1 Q And would 1 be accurate in assuming that the 1 A If the bad batch reached the point that there was 2 reference to 1/8 Gpm is one eighth of a gallon per minute? 2 a rupture disk relieved, then the batch would without any 3 A That's right. 3 particular human intervention blow into the trench. 4 Q Sir, could you shed some light on what you might 4 Q But was it your testimony that the trench was an 5 have meant? And 1 know it's been a few years, but when you 5 enclosed area earlier today? 6 said," Dump everything, four drums, no more " - 6 A Yes. 7 A " Nutrient" is the word. 7 Q So it wasn't running anywhere? 8 Q Nutrient? 8 A That's what 1 remember. 9 A Well, 1 don't know what dump everything four 9 Q Now, further in the letter in the first paragraph 10 drums meant. But 1/8 gallon per minute feed certainly is 10 it mentions that the trench, which 1 assume again is a 11 consistent with the idea that this is pilot plant data. 11 cubical trench, was drained and cleaned by hand. Do you 12 And also - or at one time we were also testing a trickling 12 recall, sir, how the drain mechanism in the cubical trench 13 filter which was a pilot plant as well, but that was an 13 would have operated? 14 alternate treatment plan. 14 A What 1 remember was that there was a pump which 15 Q That's the one we saw with Nitro earlier today? 15 could be used to pump the water out, but it would not - 16 A Same kind of device, that's right. And in some 16 did not have any provision for handling the solid material. 17 of the pilot plant studies 1 don't know whether it was the 17 Q Now, do you recall, sir, where the material that 18 activated sludge or the trickling filter nutrient which is 18 was in aqueous form would have been pumped to? 19 really just fertilizer was added to support the biological 19 A 1 believe it was pumped to the sewer. 20 life. So this is all consistent with being some kind of 20 Q And would that have been the acid sewer? 21 pilot plant operation. 21 A It would have been the Niran sewer, whatever 22 Mr. Meyer: I'd like to have marked and 22 sewer was nearest, 1 should think. Savage, James (Aroclor Dept employee) in AETNA (3) Pages 597 - 600 HARTOLDMONO010283 Page 601 Page 603 1 Q Now, am 1 reading this correctly, sir, that you 1 A No, 1 don't remember being involved at the time 2 were asking the Dorr-oliver Company to devise some method 2 of this report, Exhibit 114. 1 was manufacturing manager 3 where you could remove the solids from the cubical trench? 3 based in St. Louis, and 1 would have been part of the 4 A That's how 1 interpret this letter. 4 approval chain for them to get the money to do whatever 5 Q Now, were relationships such that Dorr-oliver 5 they did. So they may have made some presentation to me on 6 would have provided technical support to Monsanto in 6 what they were designing, but 1 don't remember what it was. 7 designing a feature like this as part of a waste treatment 7 Q Who within Monsanto would have had the most 8 facility? 8 expertise on a sanitary landfill in 1971? 9 A They were just an ordinary vendor. 1 was trying 9 A 1 don't know. 10 to see if 1 could get some help of that sort. 10 Q So as compared to Mr. Stutz who was a readily 11 Q Now, other than Mr. Stutz, was there anybody else 11 identifiable expert within Monsanto on waste treatment 12 at Monsanto you could call upon who had design basis 12 facilities, you don't recall in 1971 whether Monsanto had 13 experience in waste treatment facilities at this time? 13 an analog person on sanitary landfills? 14 A Not that 1 knew of. There may have been. 14 A No. 15 Q Now, to confirm, the Niran plant at Nitro did not 15 ( Recess.) 16 use a system like this? 16 Mr. Meyer: Back on the record. And 1 think I've 17 A That's right. 17 only got about 10 more minutes of Anniston stuff. I'd like 18 Q Sir, 1 wanted to go back to your testimony on the 18 to have marked and introduced as our next numbered exhibit 19 chlorine plant. And it's my understanding that two kinds 19 a memorandum authored by Mr. Coley who we've seen earlier 20 of brine were used, Koh and Naoh ; is that correct? 20 today and it went to a Mr. Leisy, L-e-i-s-y, dated April 21 A Well, there are two kinds of brine. One was- 21 20, 1966 and its subject matter is " Streams Leaving the 22 Q Kcl? 22 Anniston Plant." Page 602 Page 604 1 A Kcl, muriatic potash, and salt. 1 Now, the witness obviously had left Anniston by 2 Q So that's true? 2 that time and was not even a recipient of the memo, but 3 A Yes. 3 we'll see where it goes. 4 Q When you provided your estimate of the quantity 4 ( Savage Exhibit 126 identified. ) 5 of mercury that was being used, was that an estimate for 5 ( Witness reviewed the document. ) 6 the entire chlorine plant running both kinds of brine feed 6 The Witness: Okay. 7 or would you have distinguished between brine feed based on 7 By Mr. Meyer: 8 potassium versus sodium? 8 Q Sir, do you recall who Mr. Leisy was in 9 A There would be no reason why 1 should distinguish 9 connection with the Anniston plant? 10 between the two. 10 A Art Leisy was a production superintendent. Art 11 Q Sir, in going back to Exhibit 114 which you 11 came to the Anniston plant 1 think as parathion supervisor, 12 recall was the 1971 progress report? 12 but 1 believe he became superintendent during the time he 13 A 117 you said? 13 was there. That's what 1 remember anyway. 14 Q 114, sir. 14 Q Sir, 1 would like to direct your attention to the 15 A Okay. 15 second page and specifically paragraph number 5," Stream 16 Q You'll recall that there was a reference in there 16 from Plant Dump." 17 to the creation of a cost center for the landfill, which at 17 A Yes. 18 this point was now designated as a sanitary landfill, do 18 Q Now, 1 believe you testified earlier today, sir, 19 you recall that? 19 that Pnp was an indicator waste because of its yellowish 20 A Yes. 20 color; is that true? 21 Q Sir, were you involved at all in the design basis 21 A Yes. 22 for what was now becoming known as a sanitary landfill? 22 Q Given the description, sir, in the paragraph that Savage, James (Aroclor Dept employee) in AETNA (3) Pages 601 - 604 HARTOLDMONO010284 Page 605 Page 607 1 this particular stream coming from the plant dump could at 1 it predated him. 2 times be quite yellow, 1 was wondering, sir, if you recall 2 A Could be. 3 during your tenure at Anniston seeing such a stream? 3 Q On the other hand, I've run into no other Sweets 4 A No. But since he describes it as only existing 4 so 1 think you probably are right. 5 after heavy rain, it would have been somewhat accidental if 5 A Because it was a small plant he had 6 I'd seen it. 6 responsibility for things other than just personnel, and 1 7 Q Let me ask you, sir. 1 infer from that 7 think things like yards were his responsibility in those 8 description that the Pnp would have originated at the plant 8 early days and that's how he somehow had his name attachec 9 dump. Am 1 missing something in my reading of his 9 to that. 10 statement? 10 Q Sir, when you first joined the plant what was it 11 Mr. Burnett: Object to the form of the 11 in 1957? 12 question. Lack of foundation. But I'm not directing you 12 A '58. 13 not to answer. 13 Q Do you recall there being a refuse area on the 14 The Witness: 1 think you have to just reach a 14 plant property itself where there might have been as much 15 conclusion from the paragraph on the basis of what it says. 15 as 10 or 12 feet high just with general rubbish? 16 By Mr. Meyer: 16 A You're connecting this with Sweets Valley? 17 Q Well, let me ask you, sir, is the landfill area 17 Q No. 18 that you identified as being off-site across the highway, 18 A It's possible, but 1 don't remember. 19 was that physically fairly close or was it closer to the 19 Q Do you recall an area in the plant known as Junk 20 biphenyl limestone pit than the Niran limestone pit? 20 Hollow? 21 A Oh, yes. 21 A No. 22 Q Significantly closer? 22 Q Do you recall an area at the plant known as High Page 606 Page 608 1 A That's the way 1 remember it. 1 Boiler Hill? 2 Q Could you provide an estimate of how far you 2 A No. 3 think the area was where you recalled seeing the pits and 3 Q If you fish long enough. Going back, sir, to 4 maybe some of those drums and you did the shooting and the 4 Sweets Valley, what do you recall of Sweets Valley? 5 biphenyl limestone pit? 5 A That was a place where used and spare equipment 6 A No, 1 could only guess. 6 was stored. Some of it was quite orderly and some 7 Q If one was walking from one place to the other, 7 disorderly. There were drums stored there of obsolete 8 would it have taken more than five minutes to walk between 8 material. 9 the two? 9 Q By its name, would it be fair to say that it was 10 A Which two? 10 in fact a valley or a depression in the land? 11 Q The biphenyl limestone pit and the area across 11 A It was a low place where there was some old 12 the road where you had done the shooting? 12 railroad tracks that 1 think it was actually the location 13 A Probably five minutes, yes. 13 of some buildings that had been torn down a few years 14 Q Sir, do you recall an area at the Anniston plant 14 earlier. 15 known as Sweet Valley? 15 Q Could those buildings have been at one time the 16 A Yes. 16 furnace department at the Anniston plant? 17 Q Could you describe for me what you recall of that 17 A It's quite likely. 18 area? 18 Q Sir, if we go back to Exhibit 114 if you'll 19 A 1 remember it as Sweets Valley. 1 believe it was 19 recall that's the one with the maps? 20 named after Clarence Sweets who was the superintendent at 20 A Yes. 21 onetime. 21 Q Choosing whichever map you can make the most 22 Q I've asked a few witnesses that and they thought 22 sense out of, could you generally identify the area where Savage, James (Aroclor Dept employee) in AETNA (3) Pages 605 - 608 HARTOLDMONO010285 Page 609 Page 611 1 you recalled Sweets Valley as having been. And ideally if 1 might have meant by the phraseology" wash water from the 2 you could make it on the same one where we were doing all 2 Santowax-hb-40 areas "? And perhaps 1 can phrase it so tha 3 those other identifications, that would be great? 3 it has more meaning. Did you ever have any production 4 A 1 remember it as this area down here where the 4 responsibilities in Santowax Hb-40? 5 old railroad tracks are. 5 A Hb-40, yes. 6 Q Could 1 do this, could 1 hand you my pen and have 6 Q Do you recall whether or not as part of 7 you circle the general area you recall as being 7 housekeeping or ordinary day-to-day operations the Hb-40 8 Sweets Valley and then writing off to the side that name. 8 autoclaves would have been washed down? 9 And let the record reflect that the witness has done that. 9 A 1 don't recall that as a daily operation. We 10 Thank you, sir. 10 cleaned up the area from time to time and would probably 11 Now, going to Exhibit 126 which is the 11 have done so with a hose. 1 don't know the frequency. 12 Coley/leisy memo, sir, 1 believe you've got it right 12 Q Sir, finally on the second page, paragraph 4 a 13 there. Why don't you leave the map out. Do you recall the 13 stream west of the Niran department in shipping warehouse. 14 stream that Mr. Coley was describing in paragraph 3 of 14 A Yes. 15 " Stream Located in Sweet Valley"? 15 Q Do yourecall, sir, whether or not the waste 16 A No. He refers to water from the nitrophenol 16 treatment air blowers -- and 1 assume those would have been 17 cooling system, for instance, which are facilities that as 17 associated with the aeration basins ; am 1 correct? 18 far as 1 know did not exist at any time that 1 was around 18 A Yes. 19 the plant. 19 Q Do you recallwhether or not that particular 20 Q Would cleaning of intermediate cars have been 20 facility required cooling water? 21 done when you were at the plant? 22 A We began selling intermediate near the end of the 21 A 1 don't remember cooling water on the blowers. 1 22 don't find that particularly surprising understanding big Page 610 Page 612 1 time that 1 worked in the Niran department. In fact, 1 1 blowers like that, but 1 don't remember that there were 2 think that was the last significant project that 1 worked 2 coolers. 3 on was some facilities so that we could sell intermediate 3 Q Sir, wouldn't it have been a standard practice to 4 as a finished product. And that operation then began just 4 send cooling water back to a cooling tower for recooling 5 about the time that 1 transferred into production. So such 5 after it had served its purpose to cool a particular 6 a thing may have gone on while 1 was still at the Anniston 6 process? 7 plant, but it would have been after 1 had any association 7 A That was the general practice. Sometimes where 8 with that department. 8 cooling was required at an isolated place it was easier to 9 Q Sir, turning to paragraph 2 of Exhibit 126, 9 use city or wellwater on a once-through basis. It was 10 captioned " Effluent to Snow Creek from the Biphenyl 10 normally only done if it was a small stream in a remote 11 Limestone Pit Area," 1 believe it was your testimony 11 place. 12 earlier today that no waste associated with parathion or 12 Q Was, in fact, the biological treatment facility a 13 Niran department went down through the biphenyl limestone 13 fairly remote place to the cooling water areas? 14 pit? 14 A The compressors were somewhat remote from the 15 A Yes, but in some subsequent discussion 1 was 15 rest of the operating area. 16 reminded of the scrubber waste that went through an upper 16 Q What about something known as Niran warm room, 17 limestone pit and that would have then gone to the biphenyl 17 particularly condensation, do you recall what the author 18 limestone pit area. 18 might have had in mind there? 19 Q So would you like to amend your prior testimony 19 A There was a warehouse building next to the Niran 20 of today to make -- 20 plant where parathion was stored after it was made before 21 A Yes. 21 it was shipped. Not Niran itself, which was the trade name 22 Q Sir, could you shed some light on what the author 22 for ethyl parathion, but methyl parathion was subject to Savage, James (Aroclor Dept employee) in AETNA (3) Pages 609 - 612 HARTOLDMONO010286 Page 613 Page 615 1 separation in cold weather. Methyl parathion was diluted 1 Q And once 1 had finished measuring it, would 1 2 with xylene to 80 percent so as to depress its freezing 2 then have a zero reading for both of those if it was 3 point because otherwise it would crystallize under ambient 3 completely neutralized? 4 conditions. But in extremely cold weather the xylene would 4 A If you would analyze itagain? 5 separate into a separate layer which caused a problem for 5 Q Yes. 6 customers. And we eventually put in a warm room which was 6 A 1 don't know. 7 simply a warmed-up area of the warehouse to let that 7 Q Maybe it's a meaningless question. 8 happen. 8 A It's not a logical question in terms of the way 9 Q Sir, maybe you went through this before and if 9 the test is run. 10 you did, please let me know, but could you shed some light 10 Mr. Meyer: All right. Well, sir, 1 believe that 11 on the difference between Bod and Cod? 11 does it for our Anniston-related questions. Do we want to 12 A Bod is a very conventional way of measuring waste 12 go off the record for a moment. 13 loads, particularly for domestic sewage, human waste and 13 ( Discussion off the record.) 14 the like. It means -- it stands for, 1 think 1 may have 14 ( Savage Exhibits 127 through 129 15 said earlier Biological Oxygen Demand, but perhaps the word 15 identified.) 16 is Biochemical Oxygen Demand. 16 Mr. Brock: I've marked three documents for the 17 At any rate, it's a measure of the organic 17 record. The first is dated December 21,1965 and the Bates 18 content of the stream and is usually measured in the 18 numbers are Wgk 2048923 and there's an attachment with a 19 presence of biological organisms and the depletion of 19 Bates number 2042409. 20 oxygen is measured so as to determine how much oxygen is 20 By Mr. Brock: 21 consumed by the organism in oxidizing the waste. Chemical 21 Q Mr. Savage, is Exhibit 127 - or it seems to be 22 oxygen demand is a somewhat simpler test that doesn't 22 two copies of the same memorandum to you dated December 21, Page 614 1 involve biological organisms and measures materials that Page 616 1 1965 from Clarence Buckley. Is that accurate, Exhibit 127? 2 are readily oxidized by oxygen in the absence of living 3 organisms. Either test is used for chemical wastes for 4 various reasons and gives somewhat different results. 2 A Yes. But 1 only see one copy. 3 Mr. Burnett: You just had an extra one stapled 4 there, 1 guess. 5 Q Which would be the one, if any, that would be 5 By Mr. Brock: 6 most associated with toxicity problems? 6 Q For the record, Exhibit 127 is only -- the first 7 A 1 wouldn't expect a direct correlation with 7 copy of the memo Wgk 2048923? 8 either one because it depends on how toxic something is and 8 A Yes. 9 the toxicity of something is not directly related to its 9 Q Is that a copy of a memorandum that Clarence 10 oxygen demand. 10 Buckley sent to you on December 21 of 1965? 11 Q Now, just so 1 understand, when we were 11 A Yes. 12 discussing how Pnp would be broken down through some 12 Q There's a reference in the middle paragraph. It 13 application of bacteria? 13 states " 1 believe that we could avoid the formidable task 14 A Well, there were microorganisms, whether there 14 of cleaning out toxic sludge from underground tanks if we 15 was bacteria is another question. 15 built new crude Neb storage tanks aboveground." Do you see 16 Q Through some application of microorganisms if Pnp 16 that? 17 was being broken down so it was no longer toxic? 17 A Yes. 18 A That's right. And if the flow was going in that 18 Q In or about the 1965 time frame was Monsanto 19 was measuring Pnp, would the Pnp have had a Bod and a Cod 19 facing a situation at the Krummrich plant of a possible 20 measurement? 20 need to clean out toxic sludge from underground tanks? 21 A You could make both measurements on such a 21 A The context of this letter or this memo fits an 22 stream, that's right. 22 expansion that was going on at that time, and 1 think the Savage, James (Aroclor Dept employee) in AETNA (3) Pages 613-616 HARTOLDMONO010287 Page 617 Page 619 1 issue that Clarey is addressing in this memo is what kind 1 A 1 believe it was a pipeline transfer, but I'm not 2 of storage tanks would be put in as part of the expansion. 2 sure. 3 1 don't think that he's reflecting any new requirement to 3 Q This makes a reference, it says " As we've 4 clean out sludge from the tanks. 4 previously discussed, with the justification for a solids 5 Q Can you describe for me what the expansion was 5 elimination system gone, efforts would be concentrated on 6 that was going on? 6 ways to clean the crude storage tanks." Do you see that? 7 A No, 1 don't remember exactly what it was. We 7 A Yes. 8 increased the capacity of that department several stages at 8 Q Do you know what the reference means to 9 about that time. 9 " justification for a solids elimination system gone "? 10 Q That was the nitrochlorobenzene department? 10 A No. We had just made a significant process 11 A That's right. Mr. Buckley was production 11 change which may have changed composition of the crude 12 supervisor at that time. 12 stream. But 1 don't remember this particular situation. 13 Q That was before he took on his pollution control 13 Q Do you recall what the change in the crude stream 14 responsibilities? 14 was? 15 A That's right. 15 A Yes. We had at about this time or perhaps just 16 Q Do you recall whether there had been any 16 before this time installed a stripping still to remove 17 instances when Monsanto had to clean out toxic sludge from 17 unreacted monochlorobenzene. That had changed the nature 18 underground tanks associated with that department? 18 of the operation in several useful ways. The crude stream 19 A 1 don't remember such an incident. 1 was not 19 was cleaner and easier to handle. 20 involved in production so 1 wouldn't necessarily be dealing 20 Q Do you know when that change was instituted, the 21 with such a problem. 22 Q Let's go to Exhibit 128. First of all, do you 21 stripping still? 22 A No. From the context it was prior to this memo. Page 618 1 recognize whose handwriting this is on the first page? 1 Q Where did that crude stream go? Page 620 2 A The memo is from Bob Fields, who worked for me at 3 the time, to Clarey Buckley. 4 Q And what was Mr. Fields, what was his job at that 2 A That was part of what was changing at the time. 3 This flow sheet was rearranged several times and at one 4 time the first step after - the first step of refining 5 time? 5 after crude was made was what was called a crude 6 A He was an engineer working for me. 6 crystallization which was simply a crystallization step and 7 Q Did he have an area of specialty? 7 after that various fractionations. 8 A Most of the time that he worked for me he worked 8 At around this time we were changing things 9 in the nitroanilines area, but this memo refers to the 9 around and 1 believe that we ended up changing so the first 10 nitrochlorobenzene department. They were somewhat related 10 step would be distillation rather than crystallization and 11 departments. 11 the requirements on a feed stream changed just because the 12 Q In what sense were the Ona and the 12 separation method was changing. 13 nitrochlorobenzene departments related? 13 Q The Mr. Fields handwritten memo continues " The 14 A Nitrochlorobenzenes were the raw materials for 14 sludge which builds up in these tanks is mostly Neb." Do 15 making nitroanilines. 15 you see that reference? 16 Q How did the Neb reach the Ona department? Ami 16 A Yes. 17 correct in saying the Ona department? 17 Q Does that refresh your recollection as to there 18 A There's two. There's Pncb and Oncb are raw 18 being a situation involving a buildup of sludge around 19 materials or Ona and Pna which are made in the same 19 tanks associated with the Neb storage department - or the 20 building considered to be separate departments. 20 Neb department? 21 Q How did the raw material from the Neb department 21 A No. 22 reach those departments? 22 Q There's a handwritten note up above that says Savage, James (Aroclor Dept employee) in AETNA (3) Pages 617 - 620 HARTOLDMONO010288 Page 621 Page 623 1 " still a problem " with a question mark. Do you see that? 1 presumably this refers to the crude storage tanks. 2 A Yes. 2 Q Where were those crude storage tanks located? 3 Q Do you know whose handwriting that is? 3 Ain that department, but 1 can't tell you exactly 4 A No, it's not mine. 4 where. 5 Q Can 1 ask you to turn to the last couple of pages 5 Q Do you have any knowledge about what they 6 that has Bates numbers 212 and 213. If you look at the 6 consisted of? 7 last page it appears to be a signature of C. F. Buckley, do 7 A They're horizontal steel tanks. 8 you see that? 8 Q Again, Clarence Buckley's handwritten memo at the 9 A Yes. 9 end of this exhibit refers to underground tanks. Do you 10 Q Do you recognize his handwriting? 10 recall those tanks being underground? 11 A Yes, this appears to be Clarey Buckley's 11 A 1 remember we had quite a few underground tanks 12 handwriting. 12 in that department. 1 suppose that the crude tanks were 13 Q And on the second to last page, the page with 13 underground. 14 Bates number 412, there's a reference to your name up in 14 Q Do you know whether they were encased in 15 the top right-hand column. Do you see that? 15 anything? 16 A Yes. 16 A 1 don't remember that. Underground storage at 17 Q And the re: line is " Cleaning Underground Tanks," 17 one time was a very conventional standard way of doing 18 do you see that? 18 chemical storage just as gasoline stations had underground 19 A Yes. 19 tanks and so forth. Practice these days is generally 20 Q Does this refresh your recollection at all as to 20 discontinued. 21 being involved in any projects involving cleaning of solids 21 Q When was the practice generally discontinued, to 22 from underground tanks associated with the Neb department 22 your understanding? Page 622 Page 624 1 around the mid -' 60s? 1 A 1 think probably the beginning or late ' 60s. 2 A No, 1 don't remember this. 2 Q Why was the practice discontinued as a general 3 Q Do you recall there being underground storage 3 matter in the late ' 60s? 4 tanks associated with the Neb department around this time 4 A It was found that in many materials, including 5 frame? 5 gasoline at gas stations and so forth that it was not 6 A Yes, 1 remember there were some. 6 uncommon to have a leak in such a tank which might just be 7 Q Do you recall how many there were? 7 from external corrosion rusting from groundwater. It was 8 A No. 8 often difficult to detect such a leak and the ground would 9 Q What went into those storage tanks? 9 be contaminated from a leak like that. So it was decided 10 A 1 think some of them were used for crude Neb and 10 that it was a troublesome practice that should be 11 some for finished product. Some were used for what were 11 discontinued. 1 think there are now some Epa standards for 12 called fractions, meaning materials that had been partly 12 underground tanks requiring double walls and so forth which 13 resolved into their components but not completely. The 13 of course did not exist at that time. 14 mined operation that makes nitrochlorobenzenes, 14 Q Do you know whether the storage tanks, the 15 orthonitrochlorobenzene and paranitrochlorobenzene is one 15 underground storage tanks associated with the Neb 16 of the most complicated I've ever seen and there are lots 16 department had double walls at that time? 17 of tanks. 17 A No, 1 don't know. 18 Q On the first page of the exhibit the reference to 18 Q Did Monsanto at the Krummrich plant undertake an 19 " The sludge which builds up in these tanks is mostly Neb," 19 overall program or project at some point of discontinuing 20 do you have an understanding as to what those tanks refers 20 storage in underground tanks? 21 to? 21 A 1 think we changed our standard such that, such 22 A The title of this is " Solids and Neb crude " so 22 that new tanks would not be put underground. 1 don't Savage, James (Aroclor Dept employee) in AETNA (3) Pages 621 - 624 HARTOLDMONO010289 Page 625 Page 627 1 remember if we've had a campaign to eliminate underground 1 A Oh, yes. 2 tanks or not. 1 have not worked in a plant for 15 years so 2 Q Were those storage tanks in different areas? 3 there may be such a program, but 1 don't know about it. 3 A 1 don't know. 4 Q When you say you believe that Monsanto changed 4 Q Do you recall ever hearing or learning that any 5 its standards, changed its standards in what way? 5 Mcb storage tanks had been leaking? 6 A In terms of the way a new department would be 6 A No. 7 built or the way a new storage tank would be designed. 7 Q Was Mcb, is that a corrosive material? 8 Q Do you recall specific changes in standards that 8 A No. Mcb is an article of commerce that's shipped 9 were implemented? 9 in steel tank cars. 10 A No. 10 Q Are you aware of any projects associated with the 11 Q Do you recall approximately when those changes in 11 nitrochlorobenzene operations at the Krummrich plant to 12 standards were implemented by Monsanto? 12 determine whether leakage from storage tanks was a problem? 13 A No. 13 A 1 remember that some of the underground storage 14 Q Let's go to Exhibit 129. First of all, do you 14 tanks in this department had to be replaced due to 15 see your name listed as a copy recipient up on the top 15 corrosion, but 1 don't know the circumstances of the 16 right-hand corner? 16 corrosion. 17 A Yes. 17 Q Do you recall when that was? 18 Q What is this exhibit? 18 A No. It was during my time at the Krummrich 19 A This is a work proposal. It was a standard form 19 plant. 20 that was filled out to request work from the plant, 20 Q Was that during the time you were a Tsd group 21 research and development laboratory. 22 Q What was your role in this type of work proposal 21 leader at the Krummrich plant? 22 A Yes. 1 just remember hearing about projects to Page 626 Page 628 1 in the 1965 time frame? 1 replace underground storage tanks. 2 A 1 didn't have any direct, any direct role to 2 Q Do you know who worked on those projects? 3 initiate or approve such a proposal. The fact that 1 am 3 A Ordinarily that would be the maintenance 4 included in the distribution indicates that somebody 4 engineering department doing simple replacements. 5 thought 1 might be interested in the results. 5 Q Do you know who if anybody from Tsd was involved 6 Q The first sentence reads " The Neb storage tank in 6 in that? 7 department F221 is leaking." Do you see that? 7 A No, 1 wouldn't anticipate that a Tsd engineer 8 A 1 think it's Mcb, which would stand for 8 would be involved in a tank replacement, not unless the 9 monochlorobenzene. 9 design was being changed for some reason. 10 Q 1 was just - 1 agree that does sort of look like 10 Q Were those underground storage tanks that were 11 an M. If you look up at the top it says," Product, crude 11 being replaced? 12 nitrochlorobenzene," do you see that? 12 A Yes. 13 A That's right. 13 Q Were they being replaced with other underground 14 Q Would your testimony still be that down below 14 storage tanks? 15 refers to monochlorobenzene? 15 A At that time 1 believe they were. 16 A Monochlorobenzene was a raw material to make 16 Q Was there a decision made to replace them with 17 crude nitrochlorobenzene so it's plausible that there would 17 underground storage tanks rather than aboveground tanks? 18 be an Mcb storage tank in that department. 1 don't 18 And 1 ask that because there's a reference in Exhibit 127 19 remember as a fact that there was. 19 to the possibility of using aboveground storage tanks 20 Q Were there separate storage tanks to your 20 rather than underground storage tanks. 21 knowledge for nitrochlorobenzene and monochlorobenzene and 21 A 1 don't remember any specific decision about 22 what was the other one, paronitrochlorobenzene? 22 that. Savage, James (Aroclor Dept employee) in AETNA (3) Pages 625 - 628 HARTOLDMONO010290 Page 629 Page 631 1 Q Do you recall which tanks the departments were 1 project involving the installation of aboveground storage 2 associated with that had to be replaced? 2 tanks for crude Neb? 3 A No. 3 A Well, 1 would have been somewhat connected with 4 Mr. Brock: Off the record. 4 the project. At the time we were doing various expansion 5 ( Discussion off the record. ) 5 projects and it related to this department and the large 6 ( Savage Exhibits 130 through 132 6 projects were being handled by some people from organic 7 identified. ) 7 engineering. Certain smaller projects were being handled 8 Mr. Brock: I've marked three new exhibits for 8 by a couple of my people. And 1 really don't know whether 9 the record. Exhibit 130 has Bates numbers Wgk 2042381 9 we did this piece or not. 10 through 382. Mr. Savage, could you let me know when you've 10 Q Who is J. K. , and 1 hope 1 don't mispronounce the 11 had a chance to look through that. That's dated January 11 name, Rodell, R-o-e-d-e-l? 12 25, 1965. 12 A John Roedel was a chemical engineer who was 13 ( Witness reviewed the document. ) 13 working for me at the time. He's now a patent attorney and 14 By Mr. Brock: 14 a partner in a firm in St. Louis. 15 Q Just for the record, 1 note that you're referring 15 Q 1 don't know whether that's a step up or down. 16 to a previous exhibit. What exhibit are you referring to? 16 A 1 thought it was down at the time. 17 A I'm looking at Exhibit 127 which seems to be a 17 Q Did he have any responsibilities regarding 18 memo on the same subject nearly a year later than 130. 1 18 underground or aboveground storage tanks at that time? 19 was just trying to make the connection. 19 A Not specifically. He was the process engineer 20 Q Good point. What is the significance to you of 20 that 1 had assigned to work in this area. 21 the timing of the two memos? 21 Q Was there anybody at the Krummrich plant within 22 A Simply that in Exhibit 130 Clarey Buckley is 22 the Tsd department who specialized in underground storage Page 630 Page 632 1 writing to me posing the problems of solids and crude Neb 1 tank matters? 2 and suggesting several possible solutions and Exhibit 127 2 A We would not have been that specialized. We did 3 which we looked at before he seems to have come to some 3 have some mechanical engineers in the department who were 4 conclusion about it. 4 competent in the area of storage tank design whether 5 Q Do you know whether the proposal embodied in 5 underground or not. 6 Exhibit 127 which is making the use of aboveground storage 6 Q And who were they? 7 tanks for crude Neb, do you know whether that was ever 7 A Mechanical engineer reporting to me named 8 implemented? 8 Mcconnell Magnetti. There was an unusual gentleman who was 9 A 1 believe it was. 9 a registered professional engineer who had never been to 10 Q Was that around the time of this memo, Exhibit 10 college and acquired registration as a professional 11 127? 11 engineer through his experience. Excellent engineer. 12 A Obviously, it would have been after that. It is 12 Q Do you know whether he's still alive? 13 approaching a time that 1 left the Krummrich plant. So 13 A No, 1 haven't heard of him in a long time. He 14 whether it was done when 1 was still there, 1 don't know. 14 would be, 1 think, over 80 years old now. 15 Q It was done approaching the time that you left 15 Q Let's go back to Exhibit 130. It starts "Our 16 the Krummrich plant? 16 present method of washing Crude Neb results in the 17 A This memo, Exhibit 127 is December 1965. If 1 17 precipitation of calcium and magnesium carbonates from city 18 remember exactly 1 guess it was 1967 when 1 left the 18 water together with oxides of iron from the iron salts 19 Krummrich plant so perhaps this had been implemented by the 19 present in the nitration process. This is carried forward 20 time 1 left. 1 recall that it was implemented, but 1 don't 20 with the streams leaving the process and settles as a 21 remember when. 21 sludge in storage tanks." 22 Q You didn't have any responsibilities regarding a 22 What were the streams leaving the process that Savage, James (Aroclor Dept employee) in AETNA (3) Pages 629 - 632 HARTOLDMONO010291 Page 633 Page 635 1 would carry that -- those chemicals forward? 1 A Yes. 2 A Nitration of monochlorobenzene to make crude 2 Q Okay. Do you recall that the presence of a 3 nitrochlorobenzene is done with a mixed acid of sulfuric 3 sludge presenting an almost unsurmountable problem for 4 and nitric acids. And after the nitration is completed 4 removal from an underground tank associated with that 5 there was a separation made simply by differences in 5 department? 6 specific gravity to separate the spent acid from the crude 6 A Just from this description it sounds very 7 nitrochlorobenzene. That's not a perfect separation so 7 difficult. 1 don't remember this particular problem. 8 there's some acid material in the crude nitrochlorobenzene 8 Q Do you remember there being difficulty in 9 that's removed in a washing step where alkaline wash water 9 removing sludge - when it says " removal from an 10 is contacted with the crude. What leaves the washing step 10 underground tank," does that refer to removing it from the 11 is spent wash water and crude nitrochlorobenzene. The 11 inside of the storage tank? 12 crude nitrochlorobenzene is wet. To my recollection 12 A Yes. 13 there's a dehydration step after that, but I'm not sure. 13 Q Do you recall that being a problem sometimes? 14 Q Where did that stream go? 14 A Well, it certainly would be -- Neb, the Nebs are 15 A Which one? 15 toxic materials. The only way to remove such a material 16 Q Okay, 1 thought you said there was a stream 16 probably is to put a person inside that tank and the 17 involving spent wash water and crude Neb? 17 precautions in doing that are quite complex and time 18 A No, two different streams leaving the wash step. 18 consuming. 19 One is crude Neb and the other one is spent wash water. 19 Q Why would that be the only way to remove that 20 Q Where did the crude Neb stream go? 20 from the tank? 21 A It's my recollection that it went through a 21 A Well, 1 think that's what Mr. Buckley is 22 dehydration still which simply was a vacuum treatment to 22 reflecting, at the present he has no other way and later on Page 634 Page 636 1 remove water and then to the still that 1 mentioned earlier 1 in this memo he presents some other ways. 2 called an Mob stripper which removed a few percents of 2 Q When did you first come to have the understanding 3 unreacted monochlorobenzene. The result of that was called 3 that Nebs were toxic materials? 4 crude Neb which went to storage tanks. 4 A When 1 was first introduced to the department. 5 Q And the spent wash water, did that go to the 5 Q Was that when you joined the - when you came 6 sewers? 6 into the Tsd department at the Krummrich plant or sometime 7 A Yes. 7 before that? 8 Q Would there be other -- what, if any, other 8 A Actually, before that because when 1 was at the 9 chemicals would be in that spent wash water other than just 9 Queeny plant right after 1 joined the company one of the 10 water? 10 projects that 1 worked with involved the use of 11 A 1 don't remember the details of that process 11 paranitrochlorobenzene as a raw material. So as part of my 12 well. There would be some sodium sulfate and some sodium 12 indoctrination into that operation, 1 learned about what we 13 nitrate representing the neutralization products of the 13 knew about toxicity. 14 acids that are present. Probably are some other things, 14 Q How did you come to learn that Nebs were toxic 15 but 1 don't remember the details of that process. 15 materials? 16 Q There's a reference or a sentence in the memo 16 A 1 think it was part of the instruction 1 received 17 which reads," When saturated with crude Neb, as this is, it 17 from my boss at the time that 1 began working in that 18 presents an almost insurmountable problem in removal from 18 department. 19 an underground tank." 19 Q Do you recall any occasions on which the sludge 20 The reference to when it says," When saturated 20 simply couldn't be removed from storage tanks associated 21 with crude Neb, as this is," the reference to " this," would 21 with the Neb operations at the Krummrich plant? 22 it be your understanding that that refers to the sludge? 22 A No. Savage, James (Aroclor Dept employee) in AETNA (3) Pages 633 - 636 HARTOLDMONO010292 Page 637 Page 639 1 Q Do you recall any occasions on which somebody 1 the Krummrich plant; correct? 2 went into those tanks to remove the sludge and suffered 2 A Yes. 3 some sort of ill effects? 3 Q Do you recall there being projects going on to 4 A No. 4 eliminate solids from crude Neb in or around the 1965 time 5 Q There's a reference down below in the next 5 frame? 6 paragraph to the sludge collecting in still bottoms and 6 A No. 7 eventually leaving the system as still residues. Do you 7 Q Do you recall there being efforts to eliminate 8 see that in the next paragraph of Exhibit 130? 8 the necessity of cleanouts of the tanks associated with 9 A Yes. 9 that department? 10 Q The reference to leaving the system as still 10 A No. This doesn't ring any bell with me. 11 residues, what does that process refer to, what is that 11 Q 1 thought you had mentioned earlier that Clarence 12 process? 12 Buckley was trying to address the situation of somebody 13 A This refers to this whole complex. 1 think much 13 needing to go down into the tanks? 14 earlier when we talked about the Queeny plant we talked 14 A 1 think that was my interpretation of his memo of 15 about operations at the Queeny plant that involved 15 January ' 65, but 1 don't recall specifically working on 16 materials that had come from Krummrich and went back again 16 that problem. 17 and so forth. The whole complex for sorting out the 17 Q Let me ask you to turn to Exhibit 132. 18 isomers of nitrochlorobenzene involved crystallization and 18 1 believe you talked about working on accident 19 distillations at both the Krummrich plant and at the Queeny 19 investigation committees earlier. If you look at the last 20 plant. And for those big systems to reach equilibrium 20 page of this there's a reference to " J. R. Savage, 21 might take a couple months as materials were moved back and 21 Chairman," do you see that? 22 forth. 22 A Yes. Page 638 Page 640 1 Q The reference to still residues, where did those 1 Q What did it mean to be a chairman of an 2 go? 2 investigation -- accident investigation committee? 3 A Where did they go? 3 A Well, obviously, 1 was a member of the committee 4 Q Right. 4 and in being named chairman that meant it was my 5 A 1 don't know. 5 responsibility to author the report and to call meetings 6 Q 1 thought you mentioned that this involved a -- 6 and so forth. 7 A Fractions were shipped back and forth between the 7 Q What separated a major accident from a minor 8 plants. The final distillation at either plant would 8 accident at the Krummrich plant in this time frame, meaning 9 eventually create a still residue which presumably was 9 October of 1965? 10 disposed of. 10 A I'm not very clear on that. But it's pretty 11 Q Would that be the materials that were taken off 11 definite that if anyone was hurt, that would be considered 12 by shipping? 12 a major accident. 13 A Yes, 1 suppose so. 13 Q Are you familiar with William Fultz, F-u-l-t-z? 14 Q Or do you know how that was disposed of? 14 A No, 1 don't remember him. 15 A No. 1 was not ever in operations at the 15 Q Let me ask you to take a look, just glance 16 Krummrich plant. That's not something that 1 would have 16 briefly through the second page of the document and read 17 been involved in. 17 through the bottom paragraph on that page and let me know 18 Q Let's go to Exhibit 131. You're listed as a copy 18 when you've had a chance to do that. 19 recipient up in the top right-hand corner of this ; is that 19 ( Witness reviewed the document. ) 20 correct? 20 A Okay. 21 A Yes. 21 Q Do you recall the general subject matter of any 22 Q Okay, and this is a work proposal associated with 22 workers at the Krummrich plant suffering injuries as a Savage, James (Aroclor Dept employee) in AETNA (3) Pages 637 - 640 HARTOLDMONO010293 Page 641 Page 643 1 result of exposure to nitrochlorobenzene? 1 A 1 think so. 2 A 1 had forgotten about this incident, but 1 2 Q Do you recall who that worker was? 3 vaguely remember having seen this report. 3 A No. 4 Q What was the crude distillation column? 4 Q When you said " operator," was that in a 5 A That was the name given to a very large 5 nitroanilines department? 6 distillation column which was one of the first steps in 6 A Yes. 7 separating the isomers. 7 Q At that time did you regard nitroanilines and 8 Q Can you describe for me the work that was going 8 their derivatives to be toxic chemicals? 9 on in the column at the time of this injury? 9 A Yes. 10 A 1 can't add anything to what the -- to what's in 10 Q When did you first come to have that 11 the document. They were making repairs that were necessary 11 understanding? 12 because of failure of a packing support. 12 A As soon as 1 began any kind of work with 13 Q Did you draft this accident report? 13 nitroanilines. During my time with Monsanto in 14 A Since 1 was a chairman 1 would assume 1 did, 14 manufacturing 1 was involved with numerous different 15 although 1 don't remember writing it. 15 operating units and my practice, which 1 think was general 16 Q The words near the bottom of the second page, and 16 in the company, was that one of the first things 1 would do 17 this is the next to last sentence," A blood test confirmed 17 in beginning work with a different operation was to learn 18 that he had been exposed to a toxic material such as 18 about the materials being handled, any hazards that might 19 nitrochlorobenzene." 19 have been associated with them. 20 A Yes. 20 Q When you say during your time with manufacturing, 21 Q Those would have been your words? 21 are you referring to the early time when you were at the 22 A 1 think so. 22 Queeny plant? Page 642 Page 644 1 Q Do you recall any other incidents of people at 1 A No. Any of my time in the first 15 or 20 years 2 the Krummrich plant suffering any injuries as a result of 2 with Monsanto. 3 exposure to toxic chemicals such as nitrochlorobenzene? 3 Q Do you recall when it was that you first had 4 A Yes. 4 occasion to learn about the toxicity of nitroaniline 5 Q What are the other incidents that you recall? 5 compounds and their derivatives? 6 A First of all, this is not necessarily incidents 6 A It would have been at the Krummrich plant. 1 had 7 that 1 had any direct or immediate knowledge of. 7 not had any previous experience with nitroanilines. 8 Obviously, this one where 1 had written up an accident 8 Q Do you recall any other incidents of worker 9 report was someone that 1 had understood in some detail. 1 9 exposure to toxic chemicals at the Krummrich plant 10 remember one other accident where 1 believe 1 was on the 10 resulting in injuries? 11 accident investigation committee, 1 don't know if 1 was 11 A 1 remember an incident in which a production 12 chairman or not. It occurred in the building that we 12 supervisor went into a piece of equipment and sustained 13 called the nitroanilines building in which an operator was 13 some kind of injury, either lung irritation or something. 14 sprayed with a mixture of some similar material that 1 14 1 had no involvement in that. Whenever there was an 15 believe it was nitrochlorobenzene or one of the 15 accident that was investigated, it was a routine practice 16 derivatives. And it's my recollection that he also got 16 to post and circulate the investigation reports so everyone 17 sick, although he was also burned by the hot material. 17 would read them. 18 Q Do you recall approximately when that took place? 18 Q Do you know what chemical or chemicals had caused 19 A It would have been during the time 1 was at the 19 that lung irritation? 20 Krummrich plant, but 1 can't be any more precise than that. 20 A It was in the sulfuric acid department, but 1 21 Q Do you know whether that was during the time you 21 don't know specifically what he was exposed to. 22 were a Tsd group leader? 22 Q Do you recall who that production supervisor was? Savage, James (Aroclor Dept employee) in AETNA (3) Pages 641 - 644 HARTOLDMONO010294 Page 645 1 A That was Jim Duggan, D-u-g-g-a-n. 2 Q D-u-g-g-a-n? 3 A Yes. 4 Q Do you know whether he's still alive? 5 A 1 think so. 6 Q Does he still work for Monsanto? 7 A 1 think he retired very recently. 8 Q Do you know where he resides? 9 A No. 10 Q Was he still at the Krummrich plant when he 11 retired? 12 A 1 don't think so. 13 Q Do you know where he was employed by Monsanto? 14 A No. 15 Mr. Brock: All right. Off the record. 16 ( Whereupon, at 6: 20 p. m. , the deposition was 17 adjourned, to reconvene at 9: 15 a. m. , on Friday, May 21, 18 1993. 19 20 James R. Savage Savage, James (Aroclor Dept employee) in AETNA (3) Page 645 HARTOLDMONO010295 [& -1993] Transcript Word Index & & 405:9 406:2,15 488:20 588:15 589:2____________ 0 041 411:10_________________ 1 1 448:1 449:1,7 487:2 488:1 503:3 506:15 511:11 514:22 515:17 551:16 555:19 1/27/59 407:17 1/4/63 407:24 1/8 598:2,10 1/9/59 407:20 10 523:11 603:17 607:15 10/13/60 407:27 10/15/59 407:30 10/2/72 407:7 10/27/61 407:12 100 407:7 409:14,16 444:19 445:9 454:15 520:10 100,000 431:5 101 407:8 411:5,9,9 102 407:8411:5415:12 103 407:8 411:5,9,20 413:19 414:7 104 407:9 420:7,8,11 105 407:9 420:7,8 425:4 106 407:11 430:9,10 107 407:12 442:10,11 108 407:13 448:21,22 457:22 463:12 467:20 540:14,15 577:1 109 1248 180,000 407:14 469:12,13 473:20 569:14 551:3,5 11 125 19 415:16 541:20 552:20 407:30 599:3,4 411:21 413:19542:3 11/14/63 126 19103 407:25 407:31 604:4 609:11 610:9 406:12 110 1268 1950s 407:15 473:16,19,21 554:8,15 563:6 457:17 480:22 483:3 111 127 495:20 517:14 407:15 473:16,20 479:4 407:32 615:14,21 616:1,6 1957 112 628:18 629:17 630:2,6,11 432:20 461:21 607:11 407:17 482:13,14 630:17 1958 1120 128 411:22413:8415:16,21 406:17 407:32 617:22 456:18 113 129 1959 407:18 489:5 497:4 407:32 615:14 625:14 420:12 456:18 479:7 541:8 114 13 541:15,20 544:17,21 407:19 505:12 565:12 578:15 552:20 553:3 593:13 584:6,6 602:11,14 603:2 130 1960 608:18 629:6,9,18,22 632:15 637:8 431:1,13 578:15 596:11 115 131 597:14 407:20 541:14,18 542:10 638:18 1960s 544:9 565:20 576:13 132 495:21 116 629:6 639:17 1961 407:21 542:1 544:12 14 442:20 469:14 470:7 552:19,21 554:15 562:20 489:4 542:12 543:1 546:10 117 1401854 1962 407:22 542:2,7,9,11 602:13 507:16 542:3,12 545:6 546:5 118 1401857 1963 407:23 542:12,16 545:4 508:19 542:18 543:2 552:10 566:6 548:21 1401866 577:17 587:21 118-1 511:12 1965 405:8 1401870 615:17616:1,10,18626:1 119 584:12 629:12 630:17 639:4 640:9 407:24 542:17,21 1401890 1966 12 430:11 489:4 603:21 487:1 514:4 596:11 607:15 1402440 1967 12/14/62 442:12 630:18 407:23 1461 1969 120 408:13 506:19 407:25 542:22 543:6 15 1970 550:17 565:20 576:13 514:5 535:19 593:13 625:2 536:12 121 644:1 645:17 1971 407:26 566:5,10 573:7 1539040 505:9 506:1 509:1 516:3 576:11 411:10 527:7 535:4,19 584:20 122 1539264 602:12 603:8,12 407:27 578:14,18 582:7 482:15 1972 1220 1539644 409:17 405:18 469:15 19801 123 1539917 406:5 407:28 593:15 473:20 1980s 124 1540107 589:2 407:29 596:10 473:19 1991 1242 17 577:15 559:3 569:11 420:11 1993 405:15 645:18 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMONO010296 [2 - abatement] 2 2 409:17 431:21 436:20,21 491:9 494:4 503:3 560:16 610:9 2/11/59 407:21 2/8/60 407:11 20 405:15 519:19 584:11 603:21 644:1 645:16 2000 480:20 526:10 20036 406:19 2005 406:11 202 498:14,17,21 549:9 2042381 629:9 2042409 615:19 2048923 615:18616:7 21 469:14 615:17,22 616:10 645:17 212 621:6 213 621:6 25 629:12 2500 421:17 266 482:15______________ 3 3 405:13 422:6 512:21 516:15 550:18 560:16 566:19 573:13 609:14 30 457:11,16 487:2 505:9 514:1,7,13 549:17 30,000 448:8,8 300 406:18 35 487:1 350 406:3 382 50,000 629:10__________________ 431:7 4 505 4 422:6 445:21 523:6 542:18 407:19 50s 551:2 611:12 4/20/59 407:10 4/20/66 407:31 40 453:15 562:13 541 407:20 542 407:21,22,23,24 543 431:7 451:4,8 452:18 498:20 514:1 546:11 559:16 611:2,4,5,7 40,000 448:10 408 407:25 5460 563:6 566 407:26 578 407:4 409 407:27 58 407:7 411 407:8 412 621:14 420 607:12 593 407:28 596 407:29 599 407:9 407:30 430 6 407:11 6 442 645:16 407:12 6/15/59 443 407:28 446:16 6/17/59 445 407:9 442:12 6/23/59 448 407:16 407:13 6/7/63 45 407:26 488:1 6/8/59 46 407:15 450:12,17 451:2,14 60 469 514:9 546:3 407:14 600 473 523:6 407:15 604 482 407:31 407:17 60s 489 558:6 622:1 624:1 ,3 407:18__________________ 615 5 407:32 5 63 427:7,8 584:11 604:15 50 405:19 409:6 437:9 438:10 514:9 552:17 65 639:15 655 469:21 470:16 66 559:15 663 469:16 68 554:17 7 7 508:18 566:6 7/14/66 407:18 7/19/62 407:22 70 522:20 577:7 70s 455:5 558:6 561:22 589:19 75 454:15 76 523:2 7710 478:3 8 8 414:16,17 479:7 534:18 80 460:5 546:3 613:2 632:14 858 534:19 88c 405:8 891 431:21 892 436:13 897 437:11 898 430:11 437:11___________ 9 9 405:19 541:8,15 645:17 9/21/61 407:14 9/30/71 407:19 90 460:5 902 406:4 a abatement 481:9 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMONO010297 [able - analyzed] able acid (cont.) adjacent alabama 417:13 448:16 488:15 476:6,7 508:5,6,7,8 512:6 498:12 471:3 488:22 495:17 519:3 539:21 584:18 512:11,15517:9518:9,17 adjourned 498:21 549:9 aboveground 519:2,8,21,21 520:1,3,14 645:17 alive 587:16 616:15 628:17,19 521:3 522:9,11 530:2,3 adjustment 632:12 645:4 630:6 631:1,18 535:6 536:7,19 557:18,22 538:13 alkaline absence 565:13 576:8,9 587:21 adopted 458:19 557:16,17 633:9 614:2 595:19 596:2 600:20 633:3 432:16 481:13 482:3 allegation absolutely 633:6,8 644:20 558:22 472:3 541:11 575:17 acidic advice alleged absorbed 512:10 594:13 422:4 470:11 557:10 428:8 465:17 acidity advocated alleging absorber 414:15 458:17,19 529:22 524:6 422:9 465:15 519:21 520:8 acids aerated alleviate accelerates 518:4 633:4 634:14 492:8 581:17 440:16 acknowledge aeration allocating acceptable 584:9 491:19,21,22 492:5,22 509:20 412:15 acquired 493:10,13 538:5,13,15 allowed access 632:10 539:3 582:8,13 583:17 553:4 559:22 475:14 501:4 acre 584:19,22 585:6 587:10,11 allows accident 457:16 590:9 611:17 476:7 639:18 640:2,7,8,12 641:13 acres aerosol alloy 642:8,10,11 644:15 449:17 457:11 428:2,17 576:1 accidental action aetna alloys 605:5 405:7 441:22 509:14 405:9 575:22 accomplish activated afternoon alternate 574:5 495:8 598:18 488:1 598:14 accomplished active agent alternatives 514:11 532:6 518:3 558:10 531:4 accomplishing activities aggressive amalgam 513:14 421:5 576:2 523:15,18,20 524:9 account actual aggressively ambient 444:3 507:10 490:15 562:1 555:19,22 556:19 613:3 accounting actuality agin amend 509:14 503:20 480:18 610:19 accumulate add agitated american 476:7 524:11 533:22 475:19641:10 538:18 406:20 572:6 accumulated added agitation amount 524:13,18 525:6 527:22 437:6 512:13,18 516:8 419:6 419:7,11 444:11 521:9 accumulating 532:15 546:11,14 570:19 agitators 526:22 530:3 533:12 524:9 582:17 583:14 592:19 575:22 535:12 accurate 598:19 ago amounts 451:16,20 478:8 555:3 addition 439:11 449:20 535:22 410:19 598:1 616:1 554:10,11 568:6 amused acetone additional agree 539:20 419:7 433:20 434:11,14,20 435:7 447:6 530:7 561:15 479:16,17 567:12 626:10 analog 434:21 435:1 444:1,2,14,16 561:16 agreed 603:13 444:17,20,21 448:7 476:19 additions 488:7 analysis achieved 490:16 agreement 446:9 463:13 472:11,14,14 419:3 address 405:17 547:2 analytical acid 408:12 482:4 639:12 air 443:11 472:16 494:1 414:21 415:10 426:19 addressing 484:12 538:16,17,18,20 analyze 427:19 428:5,6,8,22 432:8 437:14 469:5 617:1 555:19,20,22 556:19 594:7 615:4 435:4 436:5 445:18 458:13 adequate 611:16 analyzed 458:20 459:1,8 464:21 480:12 al 427:9 465:4,6,7,10,15,17,18 405:10 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMONO010298 [anderson - attapulgus] anderson apparently area (cont.) art 406:2 476:13 479:11 553:3 578:4 483:16 501:18 544:22 604:10,10 anecdotal appear 546:11,13 549:18,21 article 410:19,21 479:6 583:12 587:1 550:14 576:16 577:6 580:7 627:8 animal appearances 585:20 587:9 595:2,5,10 ash 439:4,7 406:1 600:5 605:17 606:3,11,14 433:19 434:4,7 476:2 ankeny appeared 606:18 607:13,19,22 aside 506:4 456:20 540:6 583:15 608:22 609:4,7 610:11,18 472:6 ann appears 611:10612:15613:7 618:7 asked 411:10430:11 442:12 442:17 443:10 450:19 618:9 631:20 632:4 410:5 421:15 422:11 469:15 473:19,20 482:15 585:8,11 587:11 596:8 areas 468:18 533:17 606:22 anniston 621:7,11 449:13 450:6,8 475:8 asking 412:11 413:9415:22 appended 564:17,18 573:8 611:2 423:5 472:22 488:21 416:11 422:9 425:7 432:17 511:10 612:13 627:2 548:15 594:13 601:2 442:16449:1,11,16450:18 application arobrome assigned 450:20 451:22 452:15 478:13614:13,16 561:21 562:5 631:20 453:18 455:4 457:17 459:2 applied aroclor associated 461:1 466:20 468:9 469:3 558:10 571:1 464:16 465:9,10,16 467:22 449:10458:9511:19512:1 471:3,13,15,20 472:1,9,19 appreciable 468:4 498:9,15 501:16 520:19 537:1 553:6 554:4 472:21 473:7,11,13 488:22 520:13 521:6 526:6 527:15 504:11,14 515:18516:1,1 579:7 610:12611:17614:6 489:21 494:3 495:17 approaching 518:14 521:6,9,12 522:3 617:18 620:19 621:22 497:12 498:1,12 505:8 630:13,15 525:14,22 531:7,21 532:3 622:4 624:15 627:10 629:2 506:7,10 507:8,16,19,21 appropriate 532:11,22 533:1,20 537:5,9 635:4 636:20 638:22 639:8 510:1,6,7,13,19 518:13 439:3 540:22 541:16,22 542:5,15 643:19 526:5 527:7,11 531:17 appropriation 542:20 544:18 545:9 546:2 association 534:11 537:3 538:1 539:20 430:17,22 431:3 546:8,10,11,13 547:12 610:7 540:12 542:3,18 543:22 approval 548:4 552:2,6 553:5,6,17 assume 544:1 550:2 552:11,17 466:11 603:4 553:20,21,21,22 554:3,8,9 508:14 568:9 576:19 560:10,21 561:3 562:18 approve 554:13,19 555:11,19 556:1 587:14600:10611:16 564:11 567:21 568:8,16 626:3 558:15,22 559:3,4,7,20 641:14 570:1,3,6,11 571:5,13 approved 560:15,22 561:7,11,21 assumed 577:3,11,17 578:7,16 466:10 562:15,18,21 563:1,6,6,16 552:1 580:16 583:2 595:8 597:15 approximate 563:17,22 564:1,10,17,21 assuming 599:14 603:17,22 604:1,9 513:16 565:10 566:8 567:1 568:10 513:7 598:1 604:11 605:3 606:14 approximately 568:16 569:11,13,17 570:1 assumption 608:16610:6 615:11 409:4 451:8 457:16 483:6 570:6,10 571:7,14 573:9 552:3 answer 498:16 523:3,9 546:2 577:7 574:12 575:8 assurance 428:9 462:19 467:2 468:19 625:11 642:18 aroclors 406:21 496:4 529:8 605:13 april 452:20 533:15 553:3,7 assure answered 596:11 597:14 603:20 554:16 558:9,17,20 559:8 570:22 468:18 aquatic 560:11 562:1 563:20 567:7 atmosphere anticipate 472:20 473:5,13 567:8 429:19 438:9 628:7 aqueous arose atmospheric anticipated 527:20 528:10,12,14,18 467:14 545:11,19 438:8 444:18 476:15 440:12 600:18 arrayed attached anybody arbitrary 538:16 498:2 580:11 607:8 601:11 628:5 631:21 523:2 arrival attaches anymore arbitration 461:1 415:16 455:6 405:9 arrived attachment anyway archie 413:9 491:18501:17 615:18 413:15 500:22 522:4 474:10 503:11 581:1 591:17 attachments 567:19 604:13 area 592:17 469:15 apart 410:5 449:5 450:15,21 arrow attacked 453:15 451:17,20,22 453:20 454:4 420:15 426:19 apologize 454:8 456:7,7,9,15 475:2 arrows attapulgus 566:6 475:22 478:11 482:8 583:1 533:16 534:12,14 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMONO010299 [attempt - biological] attempt back (cont.) batches believe (cont.) 481:3 525:19 527:19 531:6 440:4,7 441:13 442:5 488:14 494:1 498:17 499:6 attempted 534:17 538:1 539:3 558:5 572:19 573:1,2,4 500:9 501:11 502:1 503:10 520:1 533:7 562:8 561:19 562:20 565:11 batchwise 503:22 514:15 516:19 attempting 573:7 577:1 584:5 586:19 433:9 437:5 520:17521:16531:7 429:1 461:13 588:21 589:22 601:18 bates 532:16 537:8 539:18 540:4 attempts 602:11 603:16 608:3,18 411:9 430:11 431:21 541:8 545:5 552:17 553:13 524:3 612:4 632:15 637:16,21 436:13 437:11 442:12 559:21 560:6 562:6,8 564:6 attention 638:7 446:15 469:15,20 470:16 569:2 571:9 572:13,14 409:21 468:13 472:18 background 473:19,20 482:15 507:16 576:15,16 579:5 582:17 473:3,4,14 506:14 507:14 494:6 496:22 497:1 508:18511:11 534:19 584:22 585:9 586:5 587:17 508:17 511:9 534:18 540:9 backhoe 584:11 615:17,19 621:6,14 588:3 590:1,22 592:3 540:17 543:13 544:11 511:7 629:9 593:10 597:11 599:12,18 550:16 552:18 566:19 bacteria bayer 600:19604:12,18606:19 604:14 495:5,7,8,10 614:13,15 572:12 609:12610:11 615:10 attorney bad bearing 616:13 619:1 620:9 625:4 631:13 572:19 573:1 599:21 600:1 543:1 628:15 630:9 639:18 attributed bagging bears 642:10,15 470:13 472:9 563:22 564:4 508:18511:11 believed author bags beaten 549:19 543:5 544:19 549:2,10 434:7,7 476:1 564:1 555:12 believing 551:8 573:17 576:15,16 banging beater 485:19 610:22 612:17 640:5 555:2 477:5 bell authored bar becoming 585:15 588:15 639:10 447:21 489:20 550:21 551:11,13,15,21,21 602:22 bench 593:13 603:19 barrels bed 561:20 authorized 531:10,13,15,16548:11,14 413:4,11,12,14 458:1,4,9 benign 550:9 based 458:12,16 459:4 460:19,21 538:3 authors 446:8,10 490:1 510:2 560:7 461:4 462:8 463:5,9,16,19 benzene 566:2 577:10,18 581:19602:7 464:5,8,11 465:19 466:3,17 453:13 author's 603:3 467:1,4,16 475:6,7 498:14 best 567:12 basement 520:18 557:19 579:6 580:4 560:9 581:14 autoclaves 493:5 581:7 583:17 586:4,18 better 611:8 basic 589:1,11,13,15 590:1,3 588:20 automate 580:13 591:9,22 592:2,4 593:5 beyond 434:9 basically beds 496:8 autothermal 582:10 458:7 580:2 586:8 587:7 bicarbonate 440:13 basin 589:3 444:10 459:10 auxiliary 490:19 538:21 539:3 582:8 began big 433:17 582:13 585:6 423:5 452:12 455:4 457:17 409:4 454:13 457:10 available basins 609:22 610:4 636:17 484:20 485:2 513:21 547:9 441:6 461:10 544:20 574:3 491:19,21,22 492:6,22 643:12 555:1 611:22 637:20 avoid 493:10,13 538:5,14,15,17 beginning bigger 488:11,12 520:2,3 556:5 538:18,20 582:15 583:17 408:10 532:16,16 624:1 431:7 484:6 616:13 584:19,22 587:10,11 590:9 643:17 biggest aware 611:17 begins 453:5 416:15 449:13 463:8 464:7 basis 506:16 bill 466:21 467:10,13 468:16 423:10 484:15 493:9 begun 431:15443:7,16 447:21 486:18 560:6 627:10 495:22 517:13 527:10,20 560:19 462:3 506:7 511:6 581:18 awkward 588:22 589:22 591:4 behalf bins 546:22 601:12 602:21 605:15 405:20 406:6,13,20 475:22 476:4 b back 416:21 441:11 455:13 492:11 501:21 508:22 514:21 516:15 523:4 612:9 batch 433:11 440:21 526:11 532:16 560:2 568:20 599:21 600:1,2 behest 422:19 believe 421:21 422:2 439:20 469:19 475:4 477:14 biochemical 613:16 biological 495:3 537:22 538:4 539:4 578:2 598:19 612:12 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMONO010300 [biological - care] biological (cont.) bottom bubble c 613:15,19614:1 409:21 419:20 454:18 484:12 calcium biphenyl 460:22 504:3 525:7 538:16 bubbles 434:15,19 518:3 523:20 452:7,12 498:9 501:19 577:5 640:17 641:16 538:18,20 582:9 632:17 514:17 516:21 518:8 bottoms buckley call 527:12 528:9 529:15,21 502:10,11 504:10,14 616:1,10617:11 618:3 420:18,22 549:5 587:3,7 530:10 536:12 545:19 541:17 545:13 552:15 621:7 629:22 635:21 601:12 640:5 546:8,13 553:20 554:6,11 565:21 637:6 639:12 called 554:17 558:11 568:10 boucher buckley's 405:16 418:8 420:5 436:20 571:21 575:4 579:14 580:4 541:9,15,20 543:21 544:1 621:11 623:8 436:22 440:13 452:8,14,20 590:22 605:20 606:5,11 bound build 453:3,4 456:8 461:2 462:7 610:10,13,17 424:9 426:5 486:5 581:9,13 499:21 501:9 502:10 biphenyls box building 504:12 508:8 520:7 522:22 572:6 425:10 515:17 524:14,16 406:3 451:3,11 548:4 524:14 525:18 526:9 birmingham boxes 564:10,17,21,21 565:10 527:12 533:18 534:10,11 406:21 557:16,17 582:22 581:17585:10612:19 534:14 537:18 538:7 559:1 bit break 618:20 642:12,13 559:14,15 560:1,15 563:8 447:12 451:2 552:12 572:1 486:22 492:12 541:10 buildings 563:17 575:20 586:12,12 blade 553:5 578:11 608:13,15 588:5,14 599:8 620:5 563:8,9 breakdowns builds 622:12 634:2,3 642:13 blister 480:5 620:14 622:19 calling 595:21 briefly buildup 561:4 599:17 block 408:19 640:16 620:18 calls 450:22 456:9 499:10 bright built 421:1,4,6,9 555:11 539:15 453:18 461:1 462:13 campaign blood brine 464:10 475:5 486:10 625:1 641:17 595:10 601:20,21 602:6,7 491:22 492:2 493:3,6 517:4 campaigns blow bring 581:20 583:19,20 591:16 507:3 534:3 600:3 525:17 616:15 625:7 Campbell blowers brink bulk 406:15 488:20 429:5 611:16,21 612:1 427:5 444:3 578:4 Canada bluff broad bulletin 453:18 408:13 510:17 432:22 cans board broadly bunch 500:12 432:22 502:8 453:12 capacities bob brock burn 431:16 618:2 406:7 407:4 408:7 409:15 435:7 549:21 567:19 capacitors bod 411:7 420:8,10 430:10,12 burned 570:15 571:22 445:5 581:19 582:1 613:11 434:1,3 442:11,13 448:22 435:18 642:17 capacity 613:12614:19 449:2 463:2 466:14 468:21 burnett 437:9 480:12 494:10 body 469:13,17473:18482:14 406:1 408:22 462:18 581:13617:8 484:10 482:16 485:11,12 486:21 466:13 468:18 485:10 capital boiler 488:6,17 615:16,20 616:5 488:13 500:2 529:7 540:2 466:11 551:10,13,19 608:1 629:4,8,14 645:15 540:14 542:10 576:17 captioned bolts broken 605:11 616:3 584:17610:10 567:18 614:12,17 burning carbide born bromine 435:12 531:15,17 572:4 558:9 561:19 burns carbon borne bromo 542:13,19 546:12,21 465:18 575:1 521:21 522:1 561:21 busy carbonate boss brought 536:3 518:3,4 443:10 474:12 506:8 468:12 472:18 473:2,4,14 butter carbonates 636:17 490:9 516:12 530:7 523:14,17,19 524:1,4,9,19 632:17 bottlenecks brown 525:1,3,7 care 431:18 539:16 bypassing 419:14 579:16 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMONO010301 [careful - clear] careful central Charles choccolocco 570:18 450:22,22 451:3,17 406:14 488:20 470:7 496:3 carefully centre Charlie chocolocco 509:4,17 406:16 488:7 473:2 carried ceramic cheaper choosing 539:5 632:19 478:9 588:13 481:21 608:21 carrier certain checked chunk 539:4 427:20 428:12,18 433:17 410:15 418:22 555:9 carry 497:21 502:7 507:1 509:18 chemical Cincinnati 413:15633:1 521:12 530:3 553:7 558:15 459:6,7 471:2,2 501:8,10 556:13 carrying 561:13591:15631:7 517:10 577:21 613:21 circle 567:8 certainly 614:3 623:18 631:12 585:20 609:7 cars 412:20 446:4 447:11 459:8 644:18 circled 609:20 627:9 480:3 488:9,11 495:18 chemicals 584:17 cartridges 524:2 527:6 547:8 577:21 438:3 463:5 486:16 558:7 circles 429:15,17,17 436:6 598:10 635:14 633:1 634:9 642:3 643:8 513:19514:3 case chain 644:9,18 circulate 405:10 408:20 441:6 603:4 chemist 644:16 458:21 463:1 479:20,21 chains 443:13 577:21 circumstances 509:22 567:18 568:10 525:19 chemistry 543:5 581:22 627:15 580:13 chairman 418:7 444:7 446:8,11 city cast 639:21 640:1,4 641:14 577:22 412:16,16 413:5,5 422:3 555:8 587:17 642:12 chemists 424:19 475:14 512:3 casting challenge 417:8 580:16,17,22 581:3,13,18 555:8 563:2 447:12 chief 582:1,3 612:9 632:17 castle chance 443:13 civil 405:3 430:14 449:5 469:21 chilled 405:7 casual 482:18 489:11 543:18 476:18 claimed 549:5 589:21 629:11 640:18 chloride 473:8 casually change 434:15,19 459:9 532:17 claims 453:4 441:7 466:18 569:7 578:7 chlorides 473:1 casualty 582:16619:11,13,20 427:9,15,16,18,21 428:10 clarence 405:9 changed 428:17 606:20 616:1,9 623:8 catalyst 441:9 453:21 551:14 chlorinated 639:11 570:19 562:22 619:11,17620:11 491:3 554:7,17 571:21 clarey categories 624:21 625:4,5 628:9 chlorination 617:1 618:3 621:11 629:22 507:21 508:1 changes 436:19 479:13 480:2 class category 419:5476:10561:10,16 490:18,21 520:22 526:8 417:3 508:19 509:10 540:18 625:8,11 527:4 554:12 558:9 569:3 clay cause changing 574:16 423:10,16,22 461:5 467:7 410:10419:9 421:8 555:10 620:2,8,9,12 chlorinator 478:8 533:18,22 534:4,6 caused channel 421:13 423:6,9 436:15 588:4 592:4,13 567:13 594:22 595:16,20 414:11 467:7 579:19 437:4,6,8 478:1 575:12 clean 613:5 644:18 channelization 587:3 588:9,11,12,18 561:10,16616:20 617:4,17 causes 528:18 580:1 chlorinators 619:6 443:20 characteristic 432:9 437:4 442:7 515:13 cleaned causing 512:10 521:13,18,22 522:3,5 436:5 600:11 611:10 472:19 characterization 545:21 565:3 568:15,19,20 cleaner caustic 558:17 568:22 569:10 570:19 619:19 478:12,16 characterize 574:11 575:3,8,9,15,20 cleaning cell 467:5 576:4 588:8 609:20616:14621:17,21 524:17 characterized chlorine cleanouts cells 417:7 522:13 523:5,8 546:9 639:8 523:13 524:12,19 charge 556:17 557:9,13,21 570:12 clear center 528:10 530:9 537:19 574:21 575:1,2,3,10 576:3 640:10 509:11,13,15 602:17 576:7 595:10 601:19 602:6 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMONO010302 [clearer - considerably] clearer college completed concrete 539:17 632:10 568:17 591:17 633:4 475:13 493:2,5,16 510:6 clearly color completely 565:5 590:8,10 482:6 504:6 415:6,7 539:13 604:20 553:12 615:3 622:13 condensate cleghorn column completion 477:21 501:15 562:14 425:9 434:18 445:17 448:7 445:10 condensation cleghorn's 460:4,11,15 478:2 479:9 complex 417:21 418:6,8 419:5,8,9 501:13,22 503:9,17,19 480:16,17481:12482:7 635:17 637:13,17 432:11 444:8,16,17 459:18 504:21 505:1 513:10 549:8 621:15 641:4,6,9 complicated 459:19460:10476:14,15 549:14 columns 529:3 622:16 476:20,21 573:2 574:2 cliff 480:12 complied 612:17 411:21 415:21 479:6 comfortably 583:6 condense 493:14 597:13 488:15 component 476:19 cliff's coming 444:1 445:3 452:11 condenser 416:6 429:22 436:5 477:19 components 476:21 close 520:21 522:8 536:6 605:1 442:19 445:22 446:5,7 condensor 495:14 555:4 584:16 commenting 453:5 459:6,7 490:15 518:1 476:18 605:19 539:21 538:5 622:13 conditions closer comments composition 445:12 476:16 613:4 605:19,22 482:1 518:7 619:11 conducted closing commerce compound 443:12 570:17 422:11 406:9 440:2 522:22 627:8 567:20 confident clothes commercial compounds 414:2 561:10,16 529:10 417:3 453:6 459:11,14 configuration cloud commercialized 460:2 644:5 501:22 558:3 585:8 505:2 562:9 comprehensive configured coat committee 504:9 589:5 563:7 640:2,3 642:11 compressor confirm cod committees 484:11 585:10 565:19 568:4 582:7 601:15 613:11 614:19 639:19 compressors confirmed coffee common 612:14 514:21 641:17 541:10 417:15 431:6 495:4 592:12 concentrated conform coil communicated 619:5 536:13 574:19 548:17 concentration conjunction coke companies 594:7 589:13 520:4,7 569:18 572:6,8,11 concentrations connect cold company 557:2,8 443:20 499:13613:1,4 405:5,9 406:6,13,21,22,23 concept connected coley 406:24,26,27 471:3 501:10 517:8 521:2 557:22 631:3 489:4 493:18,20,21 496:21 510:11,18534:15558:19 concern connecting 537:4 557:7 603:19 609:12 570:8 572:13 599:8,10 429:8 467:11,12 472:18 607:16 609:14 601:2 636:9 643:16 481:5 482:9 connection coley's compared concerned 413:18,22 425:20 430:18 494:6 513:19603:10 468:14,22 437:15 442:15 471:7,22 colleagues compartment concerning 472:2 557:3 604:9 629:19 409:9 524:16 416:16420:19421:1,22 conscious collect competent 422:19 449:1 470:20 471:8 481:1 428:6 524:4 546:3 632:4 471:14,20 474:1 consequence collected compiled concerns 435:18 426:7,19 427:18,19 465:17 439:17 421:6 438:11 466:21 conservative 545:16 547:12 551:9 complained 473:12 432:16 collecting 595:15 conclude consider 428:2 471:6 637:6 complaints 488:15 437:22 collection 438:15477:11,13 conclusion considerably 414:13 complete 500:6 605:15 630:4 450:19 583:19 436:14,15 437:2 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMONO010303 [consideration - crude] consideration contains cool cost 581:8 417:18 523:2,20 536:17 612:5 480:20 481:2,10 507:2 considerations contaminated coolant 509:11,12,15,20 570:15 519:5 624:9 453:17 581:8,17 602:17 considered contemplated coolers costs 423:8 432:6 434:15 448:13 413:10 437:1 445:22 612:2 507:4 509:16,17 547:7,9 452:9,22 453:2 472:15 content cooling 567:14 581:21 497:9 524:2 553:22 562:4 467:4 468:14 469:1 613:18 563:4 568:11 574:13,17,18 counsel 618:20 640:11 context 574:19,19 609:17 611:20 405:17 488:7 565:15 considering 458:7 461:7 536:15 570:12 611:21 612:4,4,8,13 county 594:3 579:19 616:21 619:22 coosa 405:3 consist continue 470:7 473:2 couple 427:4 433:6 434:5 435:3 429:4 484:20 copied 408:21 429:3,12 493:22 459:4 continued 546:17 512:22 539:12 569:13 consisted 405:22 408:6 432:2 559:12 copies 570:7 621:5 631:8 637:21 426:21 436:17 454:18 584:1,2 587:6 615:22 course 483:13 523:18 563:3 623:6 continues copy 409:18 414:1 417:21 429:3 consistent 620:13 409:17415:13,17420:11 438:7 439:16 468:15 508:9 598:11,20 continuing 420:13,16 425:14 430:17 508:16 521:5 570:16 consistently 581:16 505:11 542:8 545:5 566:7,9 577:14 584:20 624:13 571:1 continuous 584:10 616:2,7,9 625:15 court constituent 568:15,21 569:3,10 580:11 638:18 405:1,20 515:5 580:12 corner cover constituting continuously 625:16 638:19 415:13417:18437:18 442:5 433:11 460:1,4 corporation covered constructed contractor 501:5 408:9 517:22 493:1 591:10 592:9 593:3 510:6,19511:1,6 correct covers constructing contractors 414:6 415:18 425:18 476:3 566:18 545:21 591:15 488:13 502:2 511:16 cracks construction contribution 514:15 515:2 518:5 521:18 480:7 492:5,21 493:7 503:9,17 446:1 528:4 552:2 556:20 560:5 crash 517:6 588:14 589:11 591:8 control 572:22 577:16 581:7 592:6 423:10 591:13,14,17,21 592:2,8,10 440:11 442:1 475:22 476:4 601:20 611:17618:17 create 593:1 477:22 478:10 481:4 638:20 639:1 638:9 consumed 505:10 506:12 507:9 564:5 correctly created 529:22 530:6 533:11,12 594:5 596:5 617:13 416:22 460:7 464:15 507:5 444:14 523:15 536:18 539:8 613:21 convenience 574:10 601:1 creates consuming 584:8 correlation 415:6 635:18 convenient 410:16 417:19 443:20 creation contact 597:1 614:7 543:5 602:17 422:16,18 434:14 480:12 convention correspond creek 490:19 492:13 517:20 553:19 586:20 413:18,20 414:6,9,13 415:3 595:20 conventional corresponded 464:14 467:5,6,10,17,20 contacted 554:5 613:12 623:17 559:5 468:1,5,15,17 469:1 470:7 633:10 conversation correspondence 473:2,9,10 495:17 496:2,3 contacting 422:11 407:8,32 599:12 498:11,13,18514:19515:1 579:21 conversations corroded 516:20 537:5 539:22 540:5 contain 472:7 562:4 588:1 540:6,18,22 541:3 557:7,10 465:6 convert corroon 557:13610:10 contained 522:9 406:2 crestview 563:5 converted corrosion 510:18 container 428:4 478:13 426:11,13 575:7 624:7 cross 454:6,7 532:8 534:5 converting 627:15,16 590:17 containing 563:11 corrosive crude 547:12 573:3 convincing 574:22 575:2,19 576:7 442:9 444:9,21 445:11 415:5,8 627:7 465:17616:15619:6,11,13 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMONO010304 [crude - desirable] crude (cont.) dated (cont.) demister depletion 619:18 620:1,5,5 622:10,22 603:20 615:17,22 629:11 427:6 435:21,22 436:4,6 613:19 623:1,2,12 626:11,17 630:1 day 526:19 deposition 630:7 631:2 632:16 633:2,6 408:22 436:4 487:2 547:19 denora 405:13,16 407:6 408:20 633:8,10,11,12,17,19,20 561:11 611:7,7 523:13 524:12 409:8 487:1 488:15 645:16 634:4,17,21 639:4 641:4 days density depress crushed 527:11 551:20 564:19 505:2 613:2 528:22 529:10 607:8 623:19 department depression crystalline deal 425:5 446:2 450:11,16 608:10 554:9 421:5 471:14 584:21 452:18 454:8 455:20 dept crystallization dealing 457:20 458:10 459:3 432:2 620:6,6,10 637:18 433:3 470:19 480:21 461:10,17,22 462:2 464:2,8 depth crystallize 617:20 464:16,20,20,21 465:4,6,10 528:13 613:3 dealings 465:11,14 474:12,13,15 derivatives cubic 416:18 475:21 477:10 490:8,11 642:16 643:8 644:5 555:20 dealt 491:2,4 494:12,14,14 497:6 derived cubical 431:18 440:12 497:10,12,19 498:3,5,9,15 553:20,21 572:21 599:17,22 600:11 debottlenecking 501:16 505:8 509:19 describe 600:12 601:3 435:9 511:15515:18516:1,1 408:19412:5,9 441:15 cubicles december 518:10,18 519:2 520:19 478:6 519:11 523:17 432:12 542:12 615:17,22 616:10 521:2,3,6,13,17 522:8,13 525:14 531:12 537:22 culminated 630:17 522:17 525:15,16,21 547:18 558:22 593:1 535:14 decided 530:22 531:5,5,6,22 532:11 606:17617:5 641:8 curb 509:15 559:10 581:9,12 535:7 536:7 537:10,14,17 described 565:7 624:9 541:22 544:2,4,19,20 546:2 423:1 441:18 501:4 502:1 curbs decision 546:20 547:14 548:1,4,13 509:1,5 527:6 541:3 545:18 564:17,19 519:5 529:5 535:15 628:16 548:18 552:2,6 556:10,18 562:3 564:3 588:13 curved 628:21 557:9,9,14,18,21 558:1,4,8 describes 586:5 decisions 559:7,20 560:22 561:1,11 426:15 544:19 605:4 custodian 431:17 563:16,17,22 566:8 567:1,2 describing 461:10 decomposition 567:10 568:10 573:9,14 501:12572:18609:14 customer 440:13,14,15 574:8,12 575:16 577:9 description 519:4 520:13 569:17 deduce 578:1,5 579:8 580:22 587:4 449:4,14 478:9 485:8 customers 595:12 587:22 594:10 595:6,19 489:22 501:21 507:19 518:18 559:22 560:8 613:6 deemed 597:10608:16610:1,8,13 509:6 540:11 551:22 cut 522:10 611:13617:8,10,18618:10 566:22 567:2 577:2,5 431:6 defendants 618:16,17,21 620:19,20 604:22 605:8 635:6 cv 405:11 621:22 622:4 623:3,12 design 405:8 deferral 624:16 625:6 626:7,18 411:16 413:3 426:4 432:1 d daily 611:9 damage 421:22 567:18,18 data 407:29411:17414:8,13 426:4,7 431:15 439:5,22 443 20 470 22 596 16 19 598 11 date 475:4 543:1 546:16 568:7 596:11 507:4 deferred 507:1,10 definite 640:11 degree 410:11 dehydration 633:13,22 delaware 405:2,14 406:3,5 delegate 536:3 deliberately 627:14 628:4 631:5,22 632:3 635:5 636:4,6,18 639:9 643:5 644:20 departments 464:19 497:20 509:21 561:4,5,5,14,14 566:17 618:11,13,20,22 629:1 depend 530:1 dependent 445:16 depending 528:5 depends 432:16 434:6 435:4 437:3 440:18 460:20 461:3,7,9 466:18 486:6 493:9,16 495:22 517:12 518:6 527:19 582:14 588:22 589:22 591:4 601:12 602:21 628:9 632:4 designated 561:14602:18 designations 559:9 designed 461:20 538:1 625:7 designing 411:21 455:14 489:4 505:9 452:13 614:8 535:19 541:8,14,20 542:3 demand depicted 542:17 545:6 566:6 593:13 519:4613:15,16,22 614:10 585:4 493:12495:19601:7 603:6 desirable 509:17 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMONO010305 [detail - dr] detail dimensions discussions distribution 441:22 642:9 513:17 535:14 626:4 detailed direct disk distributor 441:20 493:16 409:21 438:13 506:14 600:2 575:10 details 507:14 508:17 534:18 disorderly ditch 576:18634:11,15 540:9,17 543:13 544:11 608:7 414:16468:2 469:8,10,11 detect 552:18 566:19 604:14 dispersed 518:15541:1,3 624:8 614:7 626:2,2 642:7 526:14 divert deterioration directing disposal 518:13 429:14 599:13 605:12 415:22 416:19 433:21,22 divided determine direction 435:2 440:4 475:2,7 478:11 498:22 536:20 546:14 554:12 613:20 627:12 416:7 462:5 464:21,22 480:22 481:4,8 541:16 division's determined 514:9 542:5,14,20 544:15,18 558:7 415:9 562:7 directional 552:1 565:21 594:1 596:5 doctor determining 513:8 disposed 563:9 581:9 directly 435:10 440:19 451:21 document develop 422:16 518:15 548:17 453:20 454:3 455:10,17 407:18,25411:11 430:15 411:16431:15562:8 614:9 638:10,14 431:21 448:2 469:22 470:1 developed dirt disposing 470:3 482:14,18,19 489:2 425:17 452:10 454:22 455:14 489:16,18491:10505:11 developer disability dispute 505:14,17 507:15 508:18 501:6 550:20 580:15 511:10512:22 535:2,4,8 developing disagreement dissolve 543:4,12 566:11 577:14 431:11 580:15 530:3 578:19 593:16 596:12 development disagreements distance 599:5 604:5 629:13 640:16 625:21 582:1 527:13 640:19 641:11 device disappeared distill documents 475:10 586:12 598:16 559:11 453:9 409:1,2,6 412:2 502:17 devise discharge distillation 543:9 615:16 601:2 438:8 441:6 512:4 433:7 533:11,19 552:6 doing diagram discharged 620:10 638:8 641:4,6 416:8418:18,19419:15 448:6 514:14 516:3 412:15 413:2 438:16 distillations 421:7 422:22 423:14 diameter 464:14 637:19 434:16 443:1,2 471:12 514:4 discolored distilled 472:2,13 517:19 525:12 diatomaceous 422:5 436:21 444:18 453:21 537:14 547:4 556:22 562:1 533:19 534:6 discontinued distillers 562:2 586:2 597:2 609:2 difference 623:20,21 624:2,11 552:1 623:17 628:4 631:4 635:17 496:7 512:2 575:18 613:11 discontinuing distilling domestic differences 624:19 526:13 532:11 496:17 538:8 613:13 633:5 discovered distinct dorr different 424:8 503:20 599:2,9,10 601:2,5 413:20 414:3 452:12 discriminate distinction dotted 453:12,15,19,20 458:6 533:2 541:2 553:16 513:18 485:17 517:3 519:21 539:7 discuss distinctions double 553:19 570:13 614:4 627:2 541:21 553:19 624:12,16 633:18 643:14,17 discussed distinguish doubt difficult 418:10619:4 509:3 602:9 571:12 519:22 624:8 635:7 discussing distinguishable dove difficulty 495:20 565:21 568:5 582:9 579:10,13 424:18 584:10 635:8 614:12 distinguished downstream digging discussion 602:7 468:2 469:8 541:1 583:16 511:7 414:9 423:6 434:2 436:13 distinguishes 586:18 dilute 458:1 470:17 472:12 565:12 downward 459:8 465:6 512:5 540:21 544:14 553:2 distribute 530:5 diluted 562:11 567:6 573:8 595:22 529:2 538:14 dr 613:1 610:15615:13629:5 470:17,19 594:16,21 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMONO010306 [draft - enter] draft dump effective eliminator 641:13 549:2,3,9 566:1 577:12 428:19 429:9 435:6 481:6 425:5,15,21 426:3,17 427:2 drafted 598:6,9 604:16 605:1,9 524:5 427:6,9,19,21 428:1,5,9,10 473:22 dumped effectively 428:13,19,22 429:8,12,14 draftsman 434:8 476:2 530:8 484:18 429:18,22 430:2,7 462:4 dumping effects ellenberg drain 529:1 549:19 416:10 443:21 594:11 562:14 525:20 552:8 600:12 dumpster 637:3 embodied drainage 525:18 efficiency 497:3 630:5 468:1 469:8,10 541:1,3 dunlap 426:9 429:13,15,18 433:19 emission drained 443:6,7,12 efficient 477:20 600:11 duplicative 434:16 444:20 485:20 emitted draw 488:10 effluent 476:22 477:4 582:22 586:20 durable 411:17,22 412:6,12413:1 employed drawing 423:14 413:10,12 420:2 421:13 556:15 645:13 583:8,12 585:1 590:16,17 duties 477:5 484:1 495:22 539:16 employees drawings 550:14 580:6,17,21 587:10 588:11 591:12,16 460:20 461:8,9,11,12,15 duty 588:12610:10 employment 462:4,13 486:6,8 590:3 524:22 effluents 409:19 430:19 442:15 591:6 593:4 e 469:1 463:22 drawn parlipr effort emptied 450:19 586:21 424:5 448:2 456:19 466:5 488:9,12 492:6 504:2 522:7 476:1,5 drew 586:14 478:7 483:22 499:1,6 501:11 511:14 520:17 523:22 548:10 556:18 efforts emptying 454:11 drop 429:3,6 555:10 droplets 521:16 536:2 539:18 540:10 549:6 552:14 559:13 570:8 572:19 558:8 562:17 619:5 639:7 enactment eight 507:6 521:13,22 569:1 encased 428:5,6 dropped 573:13 580:1 582:9 584:8 584:15 588:3,22 590:2 eighth 598:2 623:14 enclosed 534:5 598:15 600:5 603:19 either 600:5 drum 552:6 555:9,11 563:4,5,7,8 563:9 drumming 563:20 604:18 608:14 610:12 613:15 634:1 637:14 639 11 19 early 424:2,4 455:5 495:20 422:12,13 429:16 440:9 encourage 461:2 466:19 509:15 510:6 525:9 542:10 558:9 560:17 564:3 ended 569:15 578:2 580:9,13 515:6 560:19 620:9 583:11 614:3,8 638:8 ends drums 545:20 558:6 561:22 581:6 644:13 436:12 446:15 469:20 457:3,6,6 500:17 546:3 547:9,12,22 548:6 549:1,13 552:14 553:4 555:2,6 562:21 563:1,2 598:6,10 606:4 608:7 589 19 607 8 643 21 earth 533:16,19 534:7,9,12 earthen 460:21 ekberg 431:9 elaboration 442:1 electric engineer 443:7 462:3 471:2,4 474:11 474:16,17,18 493:14 494:11,14,16 544:1 577:22 618:6 628:7 631:12,19 dry 434:19 454:1 540:7 575:1 drying 419:7 433:19434:11,14,18 dual easier 6128 619 19 easy 435:6 518:2 economical 569:19,22 570:4,10,16,17 632:7,9,11,11 570:20 571:22 engineering electrical 425:4431:8 461:11,16 532:19,21 533:3,5,8 569:18 462:2 494:12,14,17 522:5 574:6 596:18 628:4 631:7 480:11 412:14 583:21 electronic engineers due 429:13 567:6 627:14 ed 510:7,9 580:9 elemental 462:5 632:3 enlarge dug 452:4 453:21 duggan edelblut 420 12 editor 435:20 466:3 eliminate enlarged 434:9 553:11 625:1 639:4,7 484:3 645:1 duly 473 6 539 19 eliminated 553:12,14 entail 434:5,12 408:4 488:4 410:10421:9 579:19 elimination 619:5,9 enter 467:5 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMONO010307 [entered - extracted] entered estate excluded expansion 463:14,19 464:5 475:14 449:21 467:9 431:12,19434:17,17 557:20 estimate excuse 437:16,22 616:22 617:2,5 entering 513:16 528:13 530:14 416:12 436:19 524:15 631:4 458:14 467:1 602:4,5 606:2 547:15 554:2,3 expect entire et executive 465:16517:16614:7 413:15492:9 501:18 405:10 506:15 507:7 expected 546:13 602:6 ethyl exhibit 427:18581:16 entirely 436:20 442:9 445:8 526:9 407:7,11,12,13,14,17,18,19 expects 504:8 530:2 596:2 612:22 407:20,21,22,23,24,25,26 529:2 entirety evening 407:27,28,29,30,31 409:14 expedient 462:12 424:17 409:16411:9,20413:19 588:18 entrain event 414:6415:12416:13 expense 564:8 472:15 526:17 419:18 420:11 425:4 430:9 523:7 546:19 entrained events 430:10 442:10,11 448:21 expenses 465:9 520:5 536:8,9 569:4 510:2 521:5 448:22 450:12,17 451:2,14 507:4 entrance eventually 457:22 463:12,15 467:19 expensive 479:1 481:18 530:5 436:6 452:9,11 465:20,22 469:12,13 473:19,21 479:4 481:4 510:3 575:22 576:1 entries 501:10511:21 515:1 482:13,14 485:6 489:1,5 experience 491:10 526:20 527:22 557:22 497:4 505:7,12 515:17 490:2 496:14 520:2 522:12 entry 613:6 637:7 638:9 534:17 540:10 541:14,18 577:10,19,19601:13 467:19,20 evidence 542:1,7,16,17,21 543:6 632:11 644:7 environment 410:10,19,21 500:18 589:1 544:9,12 545:4 548:21 experiences 436:9 575:19 576:2 evident 550:17 552:19 554:15 422:13 environmental 515:11 562:20 565:11 566:5,10 experiment 505:10 506:12 exact 573:7 576:11 577:1 578:10 483:3 583:20 envisioning 477:15 558:17 578:14,18 582:7 584:6,6 experimental 555:1,3 exactly 588:5 593:12,15 596:8,10 482:21 epa 427:3 431:14 449:15 599:1,4 602:11 603:2,18 expert 624:11 454:15 471:18 523:12 604:4 608:18 609:11 610:9 511:7 603:11 equilibrium 556:22 559:5 570:9 617:7 615:21 616:1,6 617:22 expertise 637:20 623:3 630:18 622:18 623:9 625:14,18 496:9 603:8 equipment examination 628:18 629:9,16,16,17,22 explain 425:17 426:18,20,22 427:3 405:17 407:2 408:6 489:6 630:2,6,10,17 632:15 637:8 410:6411:10480:13 431:17 436:21 441:19 examine 638:18 639:17 explosion 462:20 480:7 481:18 539:6 exhibits 432:14,18,21 433:3 482:11 522:4 527:13 569:6 examined 407:8,9,15,32 411:5,8,9 exposed 599:11 608:5 644:12 408:5 488:5 420:7,8 473:16 483:22 641:18 644:21 era example 489:8 541:7 543:19 576:12 exposure 495:20 498:6 517:13 417:12 424:12 428:17 615:14 629:6,8 555:19 556:1,5 641:1 642:3 564:21 448:1,7 454:20 473:4 exist 644:9 error excavated 490:8,20 497:4 609:18 expressed 440:10 575:11 493:4 530:11 590:5 624:13 421:6 429:8 438:11 466:22 esq excavation existed 467:11 570:2,21 406:1,7,14 461:3 529:20 430:7 451:19 490:12 extended essence excavations 503:11 507:22 540:5 556:9 484:16,22 584:2 595:1 500:1 595:10 extent essentially exceed existence 429:21 448:18 512:4 518:6 434:9 480:15 586:17 461:4 491:14 496:11 503:14 547:1 establish excellent 591:1 592:17 external 509:15 632:11 existing 624:7 established excessive 431:16 478:2,5,12 517:5 extra 438:21 509:11 446:18,21,22,22 447:2,9,18 605:4 480:20519:18616:3 establishing 448:13,15,19 expand extracted 509:12 exchange 437:6 444:22 445:12 558:14 560:1 568:5 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMONO010308 [extremely - floor] extremely fairly (cont.) fertilizer firm 432:15 438:6 536:2 575:2 595:2 605:19 612:13 598:19 488:20 631:14 613:4 fall fiber first eye 563:10 429:14 409:22413:14415:12 593:14 594:21 595:16,22 familiar fiberglass 416:21 419:19423:9 596:1 449:10 450:1 456:4 457:16 427:1 429:11 432:7,8 435:5 439:1 eyeballs 457:19 490:1,3,11 508:3 fields 444:18 449:3 465:15 595:20___________________ 517:15,17527:18545:10 618:2,4 620:13 468:22 475:2 481:5 491:3 f 555:17 556:12 558:13 fifth 491:10,22 494:16 541:8 f221 626:7 561:6 599:10 640:13 familiarize 405:19 fights 550:3 573:8 580:14,21 581:10593:19596:15 face 415:8 543:4 facilities 419:7 481:6 576:11 601:13 603:12 609:17 610:3 505:15 far 413:21 455:13 484:17 498:16 562:7 606:2 609:18 fashion facility 463:15 488:22 491:5,21 494:3,18,19,21,22 495:13 495:19 496:1 497:4,7 509:4 509:18 538:1 550:2 577:13 578:3 579:7 580:18 581:5 452:13 fast 565:15 father 473:8 540:1 favor 581:10 582:3 583:1,3 589:5,14 590:5 594:1 588:8 596:5 568:3 feature 585:19 597:7,15,15 599:14 601:8 611:20 612:12 facing 616:19 fact 411:2 419:1 420:15 427:16 499:7,16 503:10601:7 features 490:4,6 february 431:1,12 541:20 552:20 fed 594:7 figure 448:9 511:11 512:21 513:9 514:22 515:17 516:15 584:11 585:8 586:19 figures 448:11,13,15 584:7 filed 422:8 filled 411:13 625:20 filter 494:20 495:1,3,10 533:20 533:21 534:3 598:13,18 filtered 533:15,20 filtering 495:6 filters 600:9 607:10615:17616:6 617:22 618:1 620:4,4,9 622:18 625:14 626:6 636:2 636:4 641:6 642:6 643:10 643:16 644:1,3 fish 470:6,11,12,20 471:8 472:3 472:8,16 473:1,4 539:21 608:3 fished 473:9 fit 552:9 fits 616:21 fitting 567:14 five 449:17453:13510:15 452:3,15 453:4 462:10 470:11 472:8 481:12 486:12 509:10 511:15 546:16 554:9 559:3,8 567:6 573:4 584:16 608:10 610:1 433:8 528:3 538:13 federal 501:9 feed 433:13 515:8 516:12 518:7 533:17 filtration 531:22 532:6 534:1 final 428:9 461:4 532:18 533:3 523:11 550:4 568:22 606:8 606:13 fixed 537:1 581:20 flaker 612:12 626:3,19 factor 410:1 480:21 factoring 519:5 factors 480:20 481:10 522:5 failed 570:15 failure 440:10 441:19,20 519:2 641:12 failures 480:6 fair 438:4 467:9 491:11 513:7 535:8 572:5 578:9 608:9 fairly 415:8 430:6 486:4,9 512:5 523:1 529:3 532:17 545:20 539:15 563:5 598:10 602:6 602:7 620:11 feedstock 554:11 feel 489:11 feet 454:15 498:20 514:1,4,8,9 607:15 fell 429:13,18 572:19 felt 437:7 fence 414:16 fencing 509:7 fenner 426:10,11 ferromanganese 638:8 finally 491:19 508:14 532:10 533:14 542:22 592:5 611:12 find 443:20 465:11 537:5 583:20 611:22 finding 415:2 findings 472:3 finely 536:20 finished 439:4 534:2 610:4 615:1 622:11 fire 406:22,27 559:2,16 firebox 553:10 563:3 flakes 526:14 563:9,10 flaking 562:22 564:4 flammable 545:18 flare 435:11 flask 522:22 523:6 flasks 523:9 flat 456:6,9 flexibility 435:9 floating 524:19 floor 547:20 566:18 574:21 499:21 500:3 501:2 435:6,8,12,14,17,20 405:19 406:10 476:7 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMONO010309 [floor - glance] floor (cont.) forth fresh 564:11 419:11 441:8 444:10 560:2 flow 471:17 559:9,14 562:5 friday 410:1,14413:15,20414:8 565:22 577:20 623:19 645:17 414:13 424:18 445:4 448:2 624:5,12 637:17,22 638:7 fritz 448:3,5 459:3 465:5,15 640:6 418:10,18 462:2 473:10,10 475:11 491:6 forward frogs 492:9 514:22 515:4 522:4 632:19 633:1 441:8 527:20 528:10,12,14,16,18 found front 529:2 536:6 540:8 548:14 418:13 427:14 429:11 464:13 483:7 498:14 558:4 579:20 582:2,2 430:3 439:15 468:1,5,17 frs 614:18 620:3 469:7,9 524:19 528:7 560:16 flowed 540:22 624:4 full 491:4 535:13 foundation 411:17426:5,17441:5 flows 462:18 529:7 605:12 494:21 538:20 414:1,11 424:18465:14 four fuller's fluid 413:9 449:17 507:21 598:6 533:15 534:9 532:19 558:21 559:17,17 598:9 fultz fluids fourth 640:13 558:14,18 559:8,11 560:1,8 507:15 fume fluorine fr 564:5 558:10 561:19 559:1,2,11 fumes followed frl 556:1,5 595:20 541:19 542:2,12,17 559:2,3,9,14,21 560:16 function follows fr2 458:11,13 506:9 532:13 408:5 488:5 559:4,9,14,21 556:12 force fr3 functionally 547:1 559:5 497:14 forces fractionations funnel 528:18 620:7 504:3 foremen fractions furlow 537:20 548:16 452:2,6 453:18,22 455:11 405:18 forget 455:14,18 502:1 622:12 furnace 585:15 638:7 608:16 forgotten frame furnaces 585:14 641:2 415:21 417:6419:13 452:12 fork 422:15 442:20,21 456:17 further 547:14 472:4 497:11 533:21 405:16 408:5 442:1 453:9 forklift 616:18 622:5 626:1 639:5 488:5 514:21 567:5 600:9 547:15 640:8 futile form frames 574:4 411:12 445:16 453:22 504:22 526:14,18 551:5 576:5,6,17 600:18 605:11 625:19 formal 497:17 formed 435:20 525:7 527:2,4 former 409:9 formidable 616:13 forms 411:14 493:4 533:22 france 572:12 free 534:3 freezing 567:6 613:2 frequency 611:11 frequent 417:11 frequently 424:10 430:1 459:21 475:17,18 g gain 501:1 gallon 598:2,10 gallons 4454 gap 588:10 garlette 431:15 462:3,6 garrett 471:14,16 589:2 gas 433:20 435:2,10,14,14 gas (cont.) 438:10,16 465:14 518:14 518:20 519:3 520:6,21 521:7,20 522:8 534:2 545:20 567:9 569:5 624:5 gaskets 567:18 gasoline 623:18 624:5 gauge 531:18 gene 489:4 493:18 537:4 general 410:5419:13438:2 441:18 442:22 446:8,10 462:20 482:8 505:21 507:18 508:19511:1 517:22 541:16 542:5 546:21 549:4 556:5 557:4 566:7 569:19 569:21 570:4,10,15,17,20 571:22 573:8 579:2 589:14 593:19 607:15 609:7 612:7 624:2 640:21 643:15 generally 431:4 452:8,14 453:22 490:3 501:13 505:19 512:17517:10565:21 566:14 571:4 575:9 608:22 623:19,21 generate 426:4 429:5 433:10 443:19 generated 433:7 461:15,16,18,19 generates 440:14 gentleman 537:18 632:8 geographical 499:7 georgia 534:13 germany 572:12 getting 532:20 555:1 575:11 give 441:20 443:18513:20 529:8 given 502:21 604:22 641:5 gives 614:4 glance 430:14 469:19 482:18 640:15 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMONO010310 [glass - horizontal] glass gravity handwriting (cont.) heard (cont.) 429:14 575:20,21 633:6 621:12 632:13 globules gray handwritten hearing 537:5 537:18,18 542:14 407:25 543:1,14 550:17 463:7,20 469:9 472:5 627:4 go great 620:13,22 623:8 627:22 413:4,11,13415:12416:21 441:22 526:8 542:10 609:3 happen heat 425:4 436:10,12 440:11 green 435:22 515:11 613:8 440:14 558:14,18,20 441:3,4,11 445:9 450:12 541:9,15 544:8 happened 559:10,17 560:1 567:17,22 457:22 470:16 475:1 ground 430:1 440:17 441:1 460:12 568:5 478:10 479:4 488:7 492:11 410:2,8,13,13,17411:3 460:15 505:5 528:6 533:10 heating 514:12,21 516:15 527:19 456:1 457:7,8 475:22 493:3 happening 510:18 567:8 573:19 574:6 534:17 538:13,22 558:5 493:4,5 500:1,15 548:3 447:17 476:8,11 575:14 574:7,14 565:11 580:22 584:5 564:11 590:6,14 624:8 harm heavy 586:19 588:21 601:18 groundwater 472:19 473:12 524:20,20 605:5 608:18 615:12 617:22 463:14,19 464:5 467:1,6,8 harmful hedworth 620:1 625:14 632:15 467:16 624:7 594:11 443:8 633:14,20 634:5 638:2,3,18 group harms hedworth's 639:13 443:1 452:14 497:13 473:4 425:13 gobs 599:16 627:20 642:22 hastelloy held 526:14 grsenda 575:22 546:5 goes 470:17,19 hauled help 496:8 538:9 604:3 guess 532:9 537:10,11 512:19601:10 going 436:19 475:12 478:8 536:8 hauling high 409:13 419:8,8,11 445:4 538:2 550:12 565:12 599:3 537:14 417:22418:13,15429:1 465:2,10 468:15 484:19 606:6 616:4 630:18 haupt 465:1 519:13,15 554:21 501:21 514:14 520:18 guidance 542:4 567:6,13 607:15,22 527:20 528:10,12,16 531:6 443:18 haveg higher 535:6 539:7 543:13 549:1 h 478:3 453:8 559:4 554:19 561:19 562:20 h2s hazard highway 568:9 573:7 577:1,18 580:6 433:20 435:2,4,10,13,14,16 439:22 449:18,22 450:8 456:5,7 580:17 581:2 582:2 584:18 587:6 589:22 602:11 608:3 609:11 614:18 616:22 617:6 639:3 641:8 good 435:18 438:10,16 half 422:5 461:21 551:10,16 hall 511:6 hazardous 432:2,5,13 hazards 438:20 439:18 643:18 hb 498:13,21 549:9 605:18 hill 608:1 history 453:1,14 499:20 501:3 408:8 511:3 529:17 532:20 hammer 451:4,8 452:18 546:11 hit 542:9 559:17 578:12 629:20 gotten 557:13 gpm 555:10,12 hammered 562:21 hand 425:9 479:9 554:6 581:19 559:16 611:2,4,5,7 555:10 hcl hold 458:21 459:8 465:6,9,16 433:12 440:21 479:12,22 518:2,9,14,17 519:19 520:5 481:19482:5 491:14,16 520:18,21 521:7,8,20 522:8 holding 598:2 grade 503:4 519:8,9,12,14,17 520:3,12 532:21 533:3,4,5 533:8 559:4 585:20 600:11 607:3 609:6 621:15 625:16 638:19 handed 583:8 handle 569:5 head 442:2 443:8 header 477:7,8 475:13483:17585:13,16 585:21,22 586:6,15 587:8 hollow 607:20 home grades 619:19 heading 406:20 502:8 520:1 529:10 558:22 grandfather handled 431:4,8 440:8 556:10 574:1 437:11 438:19 446:16 463:16 hood 552:7 473:8 540:1,2 granite 406:22 575:1 631:6,7 643:18 handling 433:19 434:4 440:18 492:9 headquarters 494:10 543:2 hear hope 572:17631:10 hopper graphical 448:5 538:8 543:16 544:20 551:2 576:10 581:14 600:16 463:3,18 464:4 470:12 472:6,8 486:15 563:10 horizontal gratings handwriting heard 623:7 564:13 597:18,22 618:1 621:3,10 470:8,9,10,14,15 472:7 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMON0010311 [horse - installed] horse identified (cont.) improvement indicating 456:9 499:10 469:12 473:16 477:18 419:6 505:10,21 506:11,19 489:14 horseshoe 482:13 489:5 505:12 507:1,10 566:16 indication 499:8 541:18 542:1,7,16,21 543:6 improvements 427:17 hose 566:10 578:18 585:21 421:13466:12,15481:16 indicator 611:11 593:15 596:10 599:4 604:4 impurity 539:11 604:19 hot 605:18 615:15 629:7 453:11 532:18 individual 504:22 574:5 642:17 identify inadequacy 421:17 hours 442:18,21 445:22 477:19 567:7 indoctrination 408:21 429:3 490:6 549:9 584:18 586:3 inappropriate 636:12 house 587:8 608:22 567:19 industrial 493:5 identifying incident 416:10 housekeeping 586:8 590:18 447:4 570:7 617:19 641:2 industry 611:7 ii 644:11 517:10 houses 467:19 540:18 incidentally infer 421:22 422:4 image 572:4 605:7 human 547:16 incidents inference 600:3 613:13 immediate 435:16 440:18 441:12 507:12 humorous 642:7 573:5 642:1,5,6 644:8 inferring 473:7,9 immediately incinerated 491:11 hundred 454:9 498:11 435:15 440:21 information 449:17 impact incineration 407:13430:18431:11 hurt 581:18 438:9 513:9 439:17 471:7,9 596:21 532:19 640:11 impervious incinerator initial husband 528:17,21 425:6,16,19433:8,11,13,15 472:6 539:21 impetus 435:5 436:3 511:16,18,20 initially hydrochloride 412:5,9 414:4,12 466:6 511:22 512:10 513:1 515:6 492:12 482:10 474:3 515:9,16 516:16 526:15,18 initiate hydrogen implement 527:2,8 549:21 578:2 626:3 435:7 481:3 579:11 584:14 592:16 injuries hydrolysis implemented include 640:22 642:2 644:10 446:12459:11,18 594:4 625:9,12 630:8,19,20 439:21 injury hypochloride implication included 641:9 644:13 478:13481:17 545:19 572:22 502:4 511:4 547:6,8 626:4 input hypochlorite implies including 474:19 594:10 593:14 594:2,9,19,22 595:7 523:19 538:16 545:17 444:9 501:19 539:10 inserted 595:9,15 596:4 551:4 579:19 575:10 624:4 582:10 hypothesis imply incomplete inserting 418:21 573:2 459:17 460:9 495:5 i importance 447:5 incorporated 599:2 inside 450:11,16491:1 563:4 412:13 424:14 446:8,10 448:14 454:19 455:9 513:20 549:12 571:2 598:11 ideally 609:1 important 440:17 impose 447:7 impoundments 503:21 504:4 improbable increase 438:10,12,14 452:13 increased 428:18 438:16 617:8 increment 433:10 incurred 635:11,16 insoluble 436:11 inspections 462:14,16,20 install 481:17 559:3 irlpntifiahlp 603:11 irtantifiratinnc 609:3 identified 407:6 409:14 411:6 420:7 430:9 442:10 446:5 448:21 515:8 581:20 improper indicate 526:17 450:16 489:12 535:5 improve 584:17 594:12 419:1,4 423:5 426:8 433:18 indicated 435:9 466:2,6 509:6 463:13 improved indicates 419:10 420:15 626:4 installation 426:6 491:17492:14 511:22 524:6 568:15,17 573:20 631:1 installations 491:12 installed 423:9 424:1 427:3 430:2,8 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMON0010312 [installed - kind] installed (cont.) interpret irrelevant 434:19 462:11 479:1 482:7 601:4 522:2 482:11 484:11 512:9 interpretation irritant 553:10 568:1 588:19 590:1 639:14 596:1,1 619:16 interrupt irritation installing 447:15 593:14 595:16 644:13,19 568:18 intervals irritations instance 430:4 594:22 429:1 439:20 452:19 intervention isolate 481:11 490:18 502:20 600:3 453:10 503:1 525:14 530:10 554:8 introduced isolated 559:2 609:17 489:1 505:7 515:10 541:7 432:12 612:8 instances 541:13 565:20 566:4 isolation 440:17 446:20 447:8 593:12 596:8 599:1 603:18 432:1 467:13 595:14 617:17 636:4 isomer instituted introducing 453:19 619:20 489:9 isomers instruction invented 453:7,12,16 637:18 641:7 636:16 571:22 issue instructions inventory 580:3 582:4 594:8 617:1 422:20,22 423:3 489:3 533:9 item instrument investigate 427:8 449:7 523:7 547:10 441:19 580:9,10,11 471:11 571:7 insurance investigated items 406:13,22,23,24,26,27 474:8 644:15 440:1 537:9 546:19 insurmountable 634:18 intend 488:11 intended 413:15 423:20 549:10 553:10 579:17 583:20 intensive 434:10 intention 425:14 488:18 556:4 interchangeably 445:15 492:17 502:18 interest 589:21 interested 543:15 626:5 interfere 418:12 intermediate 417:22 418:9,14 432:10 436:15,16,20,22 437:2 446:12 459:12 515:13 526:8 573:6 576:9 609:20 609:22 610:3 intermediates 439:5 intermittent 526:16 540:6 internals 575:21 investigation j 411:1 415:1 471:8 474:4 570:17 639:19 640:2,2 642:11 644:16 investigations ja 405:8 jack 471:14 467:14 474:1 486:18 involve 568:18 614:1 involved 426:13 427:12,13 438:3 jacket 574:20 jacketed 574:11 jacketing 441:19 495:7 506:13 507:4 574:9 509:16 510:22 511:2 536:4 536:4 562:16 568:14 573:5 582:5,19 590:11 602:21 603:1 617:20 621:21 628:5 628:8 636:10 637:15,18 jackson 406:15 488:20 jaffee 416:10,16 james 638:6,17 643:14 involvement 416:3 443:15 466:9 496:12 405:13,16 406:1 407:3 408:3 488:3 645:20 january 510:8 644:14 involving 541:8,15 542:17 629:11 639:15 441:13 620:18 621:21 japanese 631:1 633:17 ionizable 572:13 jet 532:18 iron 499:19 587:17 632:18,18 irregular 529:1 573:14 irregularly 477:5 jets 477:20 jim 418:2 420:18 422:12 424:16,17 474:11 566:7 454:17 645:1 job 550:13618:4 john 420:12 422:21 631:12 johnson 474:10,11 johnson's 474:14 joined 544:3,5 560:21 580:14 607:10 636:5,9 joining 494:7 joint 462:21 588:17 july 413:8 489:4 542:3 june 420:11 479:7 566:6 593:13 junk 607:19 justification 619:4,9__________________ k kanawha 495:15 kanegafuchi 572:13 karl 420:12 katzenstein 405:18 kcl 601:22 602:1 keep 465:2 504:4 522:16 533:8 keeping 546:19 547:6,8 ken 544:1 kettering 556:12 kill 471:8 472:3,8 473:1 kills 470:6,11,12,20 473:4 kind 411:13414:18417:10 445:15 454:6,7 457:2 461:13 473:5,7 494:22 495:3,11 505:22 517:12 524:3 529:6 532:8 534:2,5 553:11 558:3 562:4,18 564:4 565:11 584:22 590:18 596:17 598:16,20 617:1 643:12644:13 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMON0010313 [kinds - level] kinds known (cont.) landfill leader 507:19 518:4 577:11 508:5,11 510:6,18 514:17 449:4,10,14 450:7,15 462:3 627:21 642:22 601:19,21 602:6 515:17 516:2,20 518:15 451:10,14,21 454:3,11,13 leading kirkwood 519:8 523:14 531:15,17 455:2,8,11,14,18 456:1,5,5 567:20 568:15 408:11 471:22 532:18 533:15 534:9,12 456:13,14,19,20,22 457:10 leads knew 552:7 570:9 572:20 583:11 457:10,11,14,17,19498:22 486:3 421:8 494:1 601:14 636:13 586:9 602:22 606:15 500:17 501:12 502:12 leak know 607:19,22 612:16 509:1,7,11,13 510:1,8 423:12 424:9,10 486:11 410:15412:18413:2,21 knows 525:11 527:17 549:5 577:6 624:6,8,9 414:16,19,21 415:9416:1 577:22 577:8,12 578:5 602:17,18 leakage 417:8 421:3 423:22 430:13 koh 602:22 603:8 605:17 476:6 627:12 432:5,18 433:14 439:7,9,12 601:20 landfills leaking 447:21,22 449:5,15 454:18 kristine 450:2 549:7 603:13 423:12 626:7 627:5 454:20 455:1,13,16,19,21 405:19 lane leaks 456:2,21 457:12,13 459:21 krummrich 408:13 424:12 480:7 486:16 460:17 461:15,18 462:7,10 411:3 506:8 560:12,16 large 567:20 462:15 463:1 464:18 561:7,9 570:4 616:19 414:11,21 454:14 465:5 learn 465:19,21 466:2,5,18 624:18 627:11,18,21 495:14 509:16 514:2 538:8 432:21 463:3,18 464:4 468:20 469:11,21 470:15 630:13,16,19 631:21 636:6 538:17 581:21 584:3 486:15 636:14 643:17 471:17,18 474:5,16,19,21 636:21 637:16,19 638:16 585:14 631:5 641:5 644:4 479:19 482:10,17 483:15 639:1 640:8,22 642:2,20 larger learned 485:21 486:2,12 493:17 644:6,9 645:10 414:1 423:15 435:17 453:9 589:20 636:12 494:22 496:10 497:1 1 449:21 495:16 499:16 498:19 499:16 500:21 lab 569:4 587:5 503:8,13,16 519:11 520:11 528:20 529:9,10 530:16,19 531:3 534:10 537:7 541:5 416:6 472:16 494:1 556:13 labeled 513:1,18 548:7 largest 445:3 569:16 larkin 543:3,11 546:15 547:20 548:2,9,12 550:21 557:11 labor 434:10 443:6,8 late 560:18 561:13 562:7 laboratories 480:22 483:3 495:20 565:17 571:19 572:7 573:3 573:5 578:11 580:12 586:11 594:16,18,21 597:17 598:5,9,17 603:9 609:18611:11 613:10 556:16 laboratory 472:13 580:10 625:21 lack 462:18 529:7 605:12 517:13 552:10 558:6 562:13 624:1,3 law 405:17 488:20 laws 615:6 619:8,20 621:3 lafayette 507:6 623:14 624:14,17 625:3 627:3,15 628:2,5 629:10 630:5,7,14 631:8,15 632:12 638:5,14 640:17 642:11,21 644:18,21 645:4,8,13 406:16 lagoon 420:5 483:18,19,20 484:4,9 484:9,12,15485:7,11,14,15 485:18,21 486:7,10,12,16 lawsuit 577:2 lawsuits 421:15,19,21 lawyer 422:8 knowledge 470:4 494:13 495:13,16 497:2 498:11 501:1 504:9 514:11 522:7 524:8 525:10 527:7 530:9 532:5 548:6 489:3 490:1 492:9,12,17 585:7 lagooning 482:22 491:7,10 492:8 583:11,18 577:21 lawyers 409:11 layer 461:5 525:7 613:5 551:3 555:13 560:22 lagoons laying 561:11,20 564:16,20 565:22 571:6 572:3,5 419:21 483:13 485:8,10,13 lake 457:7 leached 573:12 580:20 581:4 594:18 596:3 623:5 626:21 642:7 501:13,22 503:9,17,19 504:21 505:1 513:10 549:8 549:14 410:2,14 leaching 410:7,16 455:22 460:18 known 439:11 440:16 471:10 land 450:2 499:8 500:5 503:19 463:4 467:15 lead 476:2 489:2 499:13 501:13 608:10 410:7 493:14 502:4 504:11,15,18 506:18 learning 463:20 469:9 470:6 627:4 leave 609:13 leaves 633:10 leaving 418:16 445:17 467:4 476:17,19 603:21 632:20 632:22 633:18 637:7,10 led 543:5 570:16,18 left 444:20 453:19 461:11 464:10 479:9 489:21 493:1 513:9 536:19 552:12,17 577:17 582:17 587:20 604:1 630:13,15,18,20 leisy 603:20 604:8,10 609:12 lengthwise 555:7 lesser 429:21 letter 407:30 436:13 473:6 502:20 539:19 551:11 594:12 599:1 600:9 601:4 616:21 level 412:15417:20418:13,15 427:15,20 428:12,17,18 429:16 475:22 493:3 497:15,21 548:3 580:5 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMON0010314 [levels - marketed] levels lining long making 556:19 426:18,21 461:2,4 466:4,5 449:19 485:1 488:9 494:13 418:7 450:4 468:6 520:2 lexington 466:12,16,17 478:14,19 494:15 496:10,15 513:22 618:15 630:6 641:11 406:25 486:10,13 592:15 535:22 561:17 565:14 manageable liaison liquid 566:8 608:3 632:13 563:12 426:5 438:9,16 454:9,10 504:11 longer manager liberty 504:22 514:11 532:3,4 419:3 458:22 505:14 452:16 466:2,21 467:3 406:13 533:1 534:3 536:8,8,9 543:14 563:2 614:17 468:10 469:2 560:7 589:18 life 538:19,21 542:14,20 545:9 look 603:2 426:20 472:20 473:5,13 546:10 548:21 553:17,18 411:20 418:2 425:9,12 manager's 598:20 553:20,22 554:3,8,13 555:8 443:19 451:2 456:22 497:15 light 563:5,7,11,20 576:5 587:14 463:12 467:19 469:22 managing 506:20 541:2 545:8 549:2 liquids 485:6 489:12 514:6 539:16 530:18 551:1,12 557:12 576:19 546:3 554:2 547:3,3 584:11 621:6 manganese 577:11 590:19 591:20 listed 626:10,11 629:11 639:19 501:5 593:7 598:4 610:22 613:10 415:17 477:5,12,12 625:15 640:15 manifested liked 638:18 looked 429:2 571:2 lists 409:2 500:17,19,22 503:20 manta lime 475:1 584:6,8 630:3 406:8 532:11,13,15,17 533:10 literally looking manual limestone 573:3 418:3 562:15 629:17 489:2 497:3 413:4,11,12,13441:11 literature lot manually 458:1,4,6,9,12,15,20 459:4 517:12,15,16 459:9 527:5 528:5 547:1 434:8 460:19,21 462:8 463:5,9,16 little 561:17 570:16 581:20 manufacture 463:19 464:5,8,11 465:19 408:21 450:4 451:2 456:6 lots 595:19 466:3 467:1,4,16 475:6,7 476:4 515:17 525:18 568:5 622:16 manufactured 479:1,12,22 481:18 482:4 573:22 582:22,22 586:20 louis 595:7 483:16 491:11 498:14 586:20 461:17,22 494:12 556:10 manufacturing 513:14 514:17 516:21 lived 596:22 603:3 631:14 439:21 452:16 466:1,20 517:4,8,13,19 518:2,3,9,15 510:10 low 467:3 468:10 469:2 506:2 518:20,22 520:18 527:20 living 522:11 608:11 560:7 589:18 603:2 643:14 527:21 528:1,3,7,9,13,17 421:16 539:8 614:2 lower 643:20 528:17,21,22 529:6,10,14 load 447:5 map 529:15,21,21,22 530:4,4,6 412:15 435:8,13,16 444:3 lunch 414:18450:12,19451:13 530:7,10,10 536:12,16,16 446:2,7 447:2,7,12 448:17 486:22 492:12 451:14,19483:17516:16 536:18 557:19 579:5,6,14 547:14 584:1 lung 584:19,20 585:4,17 586:4,8 579:21 580:1,6 581:7 loaded 644:13,19 586:14,20,22 608:21 583:16 586:4,8,18 587:7 547:14 m 588:22 589:3,6,11,13,15 loading marhinp 590:1,3 591:1,9,22 592:2,5 483:8,11 581:19 593:5 605:20,20 606:5,11 loads 563:22 magnesium 610:11,13,17,18 line 452:10 476:17 511:7 513:18 553:21 554:1,3,9 558:22 559:12 562:2 446:18,21,22,22 447:9,18 530:7613:13 located 512:19 513:5 609:15 623:2 locating 518:4 632:17 magnetti 632:8 magnitude 521:10 523:11 575:20 586:17 587:22 442:20 446:1 main 590:18621:17 lined location 451:7 608:12 449:18,22 452:11 498:22 538:4 426:22 454:21 465:19 485:21 486:1,3 liner locations 422:6 log maintenance 462:22 474:13,14 497:13 497:16,17,18,19 498:2 590:12,20 lines 498:1 logical 529:20 530:22 531:4 567:14 628:3 424:22 473:3 511:4 558:14 471:11 486:21 615:8 609:13 maps 508:4 511:10 584:6,7,8,9 608:19 marginal 581:14 mark 414:9 483:20 621:1 marked 409:16411:8 420:8 430:10 442:11 448:22 450:22 451:17469:13482:14 483:17,18 489:1 505:6 541:6 593:11 596:7 598:22 603:18615:16629:8 market 405:18 406:4,11 marketed 567:8 574:4,6 587:17 442:19 444:1 640:7,12 453:16 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMON0010315 [marketing - mist] marketing meaningful memoranda meyer (cont.) 558:19 512:12 565:20 566:2 540:3,15,16 541:6,11,13,19 mass meaningless memorandum 542:2,8,11,17,22 543:7 444:9,21 445:11 552:19 615:7 407:7,9,11,14,16,20,21,22 562:10,12 566:4,13 576:22 massive means 407:23,24,27,28,31 409:17 578:14,21 583:7,9 593:11 447:14 440:4 443:9 447:22 458:9 411:20415:14,16420:12 593:18 596:7,11,14 598:22 material 545:9 551:6 576:20 596:4 469:14 505:20 541:8,14,19 599:7 603:16 604:7 605:16 410:13 415:6 436:20 613:14619:8 542:3,13,18 548:20 549:11 615:10 439:11,15,22 440:5,7,19 meant 566:15 578:16,22 579:1,3 microorganisms 442:4,5,8 444:11 445:16 431:5 549:3 551:13 570:12 593:13,20 603:19 615:22 614:14,16 452:20,21 453:11 454:8 573:16 576:16 598:5,10 616:9 microscope 458:20 459:12 465:11 611:1 640:4 memos 539:5 478:9 504:8 505:4 514:14 measure 629:21 mid 536:16 544:20 545:11,19 475:10 507:2 556:2,3 mentioned 562:13 622:1 555:8,8,10 563:6 571:5 613:17 409:12 433:5 434:6 441:21 middle 572:14 588:13 592:13 measured 464:11 469:20 500:16 465:1 616:12 595:1 600:16,17 608:8 580:7 613:18,20 504:7 510:11 520:17 536:2 migrating 618:21 626:16 627:7 633:8 measurement 537:8 552:14 554:15 467:15 635:15 636:11 641:18 468:7 580:8 614:20 567:22 634:1 638:6 639:11 migration 642:14,17 measurements mentioning 455:22 460:18 463:5 materials 614:21 537:9 486:16 418:12 423:15,20 428:7,13 measures mentions mile 438:20 439:6,18,22 440:8 478:11 570:22 614:1 458:8 600:10 422:6 441:13 451:21 452:2,14,22 measuring mercaptan miles 453:2 455:10,22 457:13 414:11 467:3 557:2 580:10 416:22 417:1,2,5,9,12 422:7 458:16,19 459:19,22 613:12614:19615:1 mercaptans miller 460:18 466:22 467:15 mechanical 417:3,8 589:2 485:17 518:5 536:17 539:9 434:9 462:5 474:11,16,17 mercury milligram 559:20 562:3,6 569:5 574:1 474:18 519:2 632:3,7 522:17,19,22 523:14,21 555:19 614:1 618:14,19 622:12 mechanically 524:1,4,7,18,20,21 525:7 million 624:4 635:15 636:3,15 423:11 556:19 557:2,3,8,10,13 415:7 448:9,10 539:12 637:16,21 638:11 643:18 mechanism 602:5 551:16,16,20,21 matter 509:20 564:3 600:12 met mind 452:3 507:18 517:21 529:1 medical 408:21 471:17,21 496:13 462:1 509:6 612:18 541:16,21 542:5,20 550:13 556:10 594:10 meta mine 554:1 555:7 566:7,14,18 meet 453:7 488:9 546:15 597:20 621:4 579:2 589:21 593:20 483:9,10 533:5 metabolize mined 603:21 624:3 640:21 meeting 539:9 622:14 mattered 541:21 metal minimize 495:22 meetings 575:21 424:19 425:1 562:2 matters 640:5 metals mining 473:3 632:1 melting 523:21 500:4,20,22 mcb 554:21 574:2 meter minor 626:8,18 627:5,7,8 634:2 member 555:20 445:22 446:5,7 522:6 640:7 mcconnell 431:2 640:3 method minute 632:8 membrane 552:1,13 592:7,10 594:5 448:8 598:2,10 mcguinness 460:21 461:2,5 462:7,10,14 597:1,2 601:2 620:12 minutes 510:7,9 463:4,10 590:13 592:4,12 632:16 603:17 606:8,13 mean memo methods mispronounce 413:11 424:4 443:3 447:18 413:19417:18440:3 481:4 631:10 447:20 459:5 519:15,18 535:18 546:16,17 552:20 methyl missing 528:2 551:3 640:1 604:2 609:12 616:7,21 436:21 438:20 442:9 445:8 605:9 meaning 617:1 618:2,9 619:22 526:9 612:22 613:1 missouri 419:2 440:13 448:17 620:13 623:8 629:18 meyer 408:11 497:14 508:22 611:3 630:10,17 634:16 636:1 406:14 488:7,19,20 489:7 mist 622:12 640:8 639:14 500:3,7 505:6,13 529:13 425:5,15,21 426:3,17 427:2 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMON0010316 [mist - nitrochlorobenzene] mist (cont.) monsanto (cont.) names neutralize 427:6,8,19,21 428:1,5,8,10 578:15 580:16 581:5,9 510:11 537:21 458:13 517:20 518:2 428:13,19,22 429:8,12,14 582:1 589:3 591:12,16 naoh neutralized 429:18,22 430:2,7 593:12 594:1 601:6,12 601:20 615:3 mix 603:7,11,12616:18617:17 narrower neutralizing 453:16 522:8 624:18 625:4,12 643:13 588:16 458:19 mixed 644:2 645:6,13 national new 445:18 527:5 533:19 633:3 monsanto's 406:26 405:3 411:8 426:21,22 mixing 448:22 480:21 483:10 natural 427:3 429:17 432:16 575:4 488:6 540:11 484:10 567:9 436:14,15 437:2,22 466:17 mixture montar naturally 482:7 530:11 560:2 568:18 453:4 642:14 502:5,6,10,15 503:3,4 489:13 570:22 581:20 595:1 mode 504:12,15,21,22 533:13 nature 616:15 617:3 624:22 625:6 568:21 montars 426:1 569:8 619:17 625:7 629:8 modification 503:2,7 531:14 555:15 neb newspaper 461:13 month 616:15 618:16,21 620:14 473:7 539:20 modifications 424:13 523:10 581:2 620:19,20 621:22 622:4,10 newspapers 484:5,7 months 622:19,22 624:15 626:6 433:1 modified 413:9 417:14 430:4 637:21 630:1,7 631:2 632:16 nine 484:3 morning 633:17,19,20 634:4,17,21 503:6,7 modify 408:8 539:18 540:10 549:6 635:14 636:21 639:4 niran 558:8 599:18 nebs 412:19,20,22 413:3,22 moisture mountain 635:14 636:3,14 414:22 415:2,22 417:16 575:11 456:8,9 499:14 near 419:16,20 424:5,6 425:6,16 molecule mounted 450:11,15 513:19514:19 430:22 431:12432:2,15 570:13 435:11 516:20 530:5 568:7 585:13 434:21 437:16 438:3,20 moment move 609:22 641:16 447:9 458:9 461:9 474:1 469:18 574:18 615:12 545:4 587:10 nearest 475:21 482:21 491:1,3,17 moments moved 600:22 494:18 497:8,9 498:5 534:22 543:9 471:21 637:21 nearly 508:11,12511:15520:19 monel mullendore 442:22 482:9 569:12 520:22 521:2,8,17,21 526:3 575:22 420:12 422:21 629:18 526:6 565:12 572:19 573:1 money municipal necessarily 575:16 576:4 579:8 580:17 481:7 570:16 603:4 420:19 421:1 496:22 538:8 582:5 617:20 642:6 580:20,21 581:11 583:3 monitor municipally necessary 587:22 588:22 589:3,10,11 556:18 496:18 481:19 532:20 536:3 553:5 589:14 590:1 591:10,14,16 monitoring muriatic 574:7 641:11 592:3 593:5 595:6,18 597:8 446:16 548:14 459:8 464:20,20 465:4,5,6 necessity 600:21 601:15 605:20 monochlorobenzene 465:10,15,17,18 518:9,17 639:8 610:1,13611:13612:16,19 619:17 626:9,15,16,21 519:2,8,21 520:14 521:3 need 612:21 633:2 634:3 522:9,11 535:6 536:7 616:20 nitrate monsanto 557:18,22 602:1 needed 634:13 405:5 406:6 408:14,17 mutual 426:4 463:8 480:17 509:19 nitration 409:9,19 422:9 430:19 406:13 517:19 546:2 575:7 595:4 632:19 633:2,4 439:13,13,18 442:16 n 455:22 463:22 468:2 469:8 name 470:13,15471:1,2 481:3 425:9,12,13 431:10 443:9 489:2 494:7 496:15 499:8,9 499:18 505:7 506:22 469:20 488:19 499:10,12 499:15,16 502:7,13,15,21 509:12 510:6,19 518:13 540:5,7 541:1,8,14,19 542:3,13,18 543:3,3 551:13 510:9 523:19 534:16 544:10 545:12 558:22 559:18 607:8 608:9 609:8 555:18 556:14 557:6 559:21 560:1 561:1,3,20 612:21 621:14 625:15 631:11 641:5 562:14 566:5 569:16 named 570:18 571:8,14 577:2,7 511:6 606:20 632:7 640:4 needing 639:13 neighbor 471:17,18 neighbors 477:14,14,17 neutralization 511:19512:7,18 513:2,10 513:13,14,19 514:7,10,22 515:7 516:17 517:9 535:7 579:11 584:15 592:11,16 634:13 nitric 633:4 nitro 432:15,19 494:19 495:13 495:15598:15601:15 nitroaniline 644:4 nitroanilines 618:9,15 642:13 643:5,7,13 644:7 nitrochlorobenzene 617:10618:10,13626:12 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMON0010317 [nitrochlorobenzene - ordinary] nitrochlorobenzene (cont.) number (cont.) occurred open 626:17,21 627:11 633:3,7,8 504:13 507:16 508:18 435:19 440:22 442:3,6 414:11 467:7 565:1 573:21 633:11,12637:18641:1,19 511:12 521:22 522:5 452:15 523:14 546:16 opened 642:3,15 534:19 536:11 540:12 549:20 563:13,15 642:12 534:4 552:8 564:14 580:21 nitrochlorobenzenes 542:2 550:17,18 556:15 occurring operate 618:14 622:14 559:6 584:11 587:3,5,7,8 512:14 520:22 429:1,4 519:22 nitrogen 604:15615:19621:14 o'connor operated 534:2 numbered 405:20 419:6 423:13 426:2 432:12 nitrophenol 489:1 503:6 505:7 541:7,14 October 433:9 437:5 460:4 480:8 609:16 566:5 578:10,14 593:12 409:17 578:15 640:9 485:15,19 497:10 509:4 nomenclature 596:8 599:1 603:18 odor 568:20 600:13 531:20 551:14,18 554:6 numbers 416:22 417:10,20 419:3 operating nominally 411:9 430:11 437:11 420:19 421:7,12 422:13,15 411:17 426:7 433:18 554:8 442:12 448:18 469:15 424:7,20 425:2 474:1 475:2 447:13 452:12 479:13 non 473:19 482:15 504:13 477:5,9,15,22 480:21 594:5 480:2,4 489:2 497:7,11 405:9 584:17 586:20 615:18 596:4 522:12 525:16 577:19 nonaqueous 621:6 629:9 odorous 612:15643:15 512:11 numerous 417:4 operation normal 643:14 odors 432:1 436:3 438:21 440:10 410:1,7,16 423:13 437:18 nutrient 417:5,7,12 421:1 422:9 444:2,6 464:9 484:20 492:8 439:20 440:11 447:5 486:4 598:7,8,18_______________ 475:17,18 476:22 477:4,11 500:20,22 509:7 511:7 486:9 521:5 566:17 587:18 o 596:20 normally oak 408:13 441:4,5 448:5 509:14 529:2 object 575:1 612:10 northwest 576:17 585:11 605:11 objection 451:12 note 462:18 466:13 529:7 objections 590:18 620:22 629:15 notes 565:15 objective 479:9 543:1 notice 457:4 490:18 noticed 411:16,18 objectives 483:9,10 observe 475:17,18 notified 422:14 notify 422:12 notorious 450:6 observed 454:5 505:5 569:8 obsolete 478:12,17 597:2 608:7 obtained 441:17 notoriously 417:4 november 411:21 413:19 543:1 nozzles 471:1 obviously 411:13 475:11 482:1 604:1 630:12 640:3 642:8 occasion 434:18 474:5 570:4 644:4 478:22 nuclear occasional 436:8 526:22 453:17 number 405:7 407:6 427:7,8 431:21 occasionally 441:7 519:20 occasions 431:21 436:13 443:17 445:21 446:15 450:2 441:17 442:4 445:2 463:3 636:19 637:1 469:14,21 470:16 473:20 occur 473:20 502:20 503:2 459:13 547:19 477:12 479:11,22 482:4 offices 405:18 oh 462:12 480:3 484:8 533:5 547:16 558:5 605:21 627:1 okay 430:16 450:14 479:5 482:20 489:19 505:18 515:21 534:21 535:3 543:17 566:12 578:20 593:17 597:14 599:6 602:15 604:6 633:16 635:2 638:22 640:20 old 435:11 456:6,20 478:19 501:4 531:20 608:11 609:5 632:14 Oliver 599:2,9,10 601:2,5 omp 503:1 ona 618:12,16,17,19 oncb 618:18 once 424:12 530:11 547:19 552:20 583:14,22 612:9 615:1 ones 442:6 459:12 492:22 ongoing 474:7 491:7 529:19 523:13 526:17 527:18 528:10 535:15 553:9,11 555:14 556:4 562:22 563:13 564:4 583:22 584:3 593:22 598:21 610:4 611:9 619:18622:14636:12 643:17 operations 433:18 435:10 438:3 439:19445:7 451:7 459:16 460:8,14 471:15,20 472:9 472:19 549:20 569:8 611:7 627:11 636:21 637:15 638:15 operator 642:13 643:4 operators 525:19 opinion 527:3,10 536:14,20 opposed 495:5 573:21 opposite 498:13 order 413:8 433:18 521:10 523:6 523:11 526:10 535:11 536:12 584:17 594:8 orderly 608:6 ordinarily 440:1 628:3 ordinary 480:16 601:9 611:7 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMON0010318 [ore - path] ore overall pages part (cont.) 499:19,21,22 469:4 541:22 584:1 624:19 437:10 512:22 573:8 621:5 497:9,22 499:20 502:9 organic overcome paid 511:18512:14513:11 431:8 453:17461:11,16,22 429:5 581:18 515:4 546:14 547:5 553:20 462:2 475:16 483:8,11 overflow paint 553:22 554:8 557:4 558:21 494:11,13,16 539:9 558:7 538:21 557:15 421:22 563:3,16 566:3 569:3 596:18 613:17 631:6 overlapping paints 572:22 585:5 589:1,14 organics 547:1 562:15,18 591:18 593:22 596:20 418:1 520:5,14 overload paired 597:10,11 601:7 603:3 organism 428:21 447:15 437:4 611:6 617:2 620:2 636:11 613:21 overpressure pallets 636:16 organisms 440:22 547:12 partial 539:4,8,8 613:19 614:1,3 oversight pan 436:2 organized 589:9,17 563:5 partially 497:14 owned pap 483:7 orient 496:19 499:8,18 510:7 537:18 particle 584:14 owner paper 529:11 origin 501:6,6 532:6 533:20,22 534:1,4 particles 459:5 503:4 oxides 582:21 428:2,18,20 429:9,19 495:9 original 632:18 paragraph 527:21,22 528:3 529:1 413:3 426:6,17 431:22 oxidized 414:3,6,8418:11,18421:14 564:8 434:6 435:4 437:3 465:20 614:2 424:15 431:22 443:22 particular 484:8 491:17 501:5,6,6 oxidizing 449:1 458:7 481:15 507:7 410:10417:9 426:15 511:22 582:14 588:9 613:21 507:13 509:2,9 535:5,16 453:16 457:4 462:1 463:1 originally oxygen 545:18 553:2 567:5 568:1 481:11 498:2 503:4 508:22 452:9 512:1 554:21 484:9 613:15,16,20,20,22 600:9 604:15,22 605:15 518:18519:16539:2 originate 614:2,10 609:14610:9 611:12 549:10 552:10 583:12 415:10 445:6 oxygenate 616:12 637:6,8 640:17 586:4,8 591:18 595:3 600:3 originated 492:6,13 paranitrochlorobenzene 605:1 611:19612:5 619:12 536:15 577:8,14 578:5 605:8 originates p2o5 P 622:15 636:11 paranitrophenate 418:9 445:9,11,14 459:10 635:7 particularly 428:21 429:11 508:3 511:2 414:22 originating 444:2 p2s5 475 20 476 1 2 3 4 10 5165 460:6 519:22 524:5 530:5 539:6 paranitrophenol 611:22612:17613:13 445:13 458:8 463:14 464:1 parties ortho package 464:4,7 405:21 453:5 orthonitrochlorobenzene 622:15 otto 426:11 5232 packing 476:7 588:17 641:12 pad 565:5,7 paraterphenyl 453:6 parathion 418:7 438:21 439:10 442:19 443:1 444:22 partition 485:16 partly 581:19622:12 partner outfall 498:12,17 514:19 515:1 516:20 535:13 540:7 outlet 475:9,10,11,12 479:2 page 409 22 41613 21 41918 419:19 427:7 431:20,21 436:12,12 438:19 445:21 446:15 449:4 457:22 457:20 458:8 459:3,16 471:17631:14 460:8,13 463:13,18 511:15 parts 511:19513:1 515:6,6,16 415:7 424:19431:16448:8 516:13,16 522:8 571:11 448:9,10 518:3 539:12 573:3 577:8 578:1 589:10 587:1 591:15 524:14,16,17 463:15 469:20 470:16,17 604:11 610:12 612:20,22 party outline 585:5 586:6 475:1 478:10 483:7 485:6 491:9 506:15 507:15 612:22 613:1 parentheses 421:17 pass outside 414:16 422:4 436:7 439:13 516:13 548:3 556:16 508:18 534:18 540:18 543 14 15 550 18 566 19 573:13 577:5 583:8 584:11 443:9 paronitrochlorobenzene 626:22 563:8 passage 467:10 564:17 565:3 ovals 604-15 61T12 6181 62T7 621:13,13622:18639:20 part 410:11 427:18431:19 patent 571:14,17572:1,2 631:13 513:8 640:16,17641:16 449:18,21,22 456:9,14 path 469:3,4 491:7,17 495:19 467:8 557:15 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMON0010319 [paved - plants] paved personnel pipelines plant (cont.) 454:20 564:16,18 537:3 607:6 587:16 425:16 426:2,5,12 427:9 paving ph pipes 430:22 431:4,6,12 432:15 510:7 445:13,17 538:13 580:5,8 424:9 477:17 432:17,19 433:1 434:5,21 pc 581:7 piping 438:17 442:16 443:14 436:20,21 phase 511:2,4 567:1,7,14,17 444:3 447:3,7,10,13,16 pcb 495:11 573:12,14 574:2 587:13 449:1,11,16,18,22 450:11 410:1,13 467:4,14 468:14 phases pit 450:13,16,18,20 451:1,6,7 468:22 469:4 562:3 432:3 457:3 458:4 479:1,12,22 451:15,22 452:15 453:1 pcbs Philadelphia 481:18 482:4 483:16 454:4 455:5,16,20 457:17 410:2,8,17 411:3 467:22 406:12 491:11 511:19512:18 459:2 461:14,20 462:12 468:4,17 469:7,9 535:12 philosophy 513:2,10,11,13,19514:3,7 464:22 465:1 466:20 468:2 536:22 540:22 559:10 432:1,16 514:17515:1,7 516:17,19 468:9 469:3,8 471:14,15,20 pet phone 516:21 517:2,4,8 518:9,15 472:9,19,21 473:11,13 442:9 445:9 526:9,9,13 420:22,22 421:4,6,9 518:21,22 527:21 528:9,14 474:1 475:5 477:15 483:15 596:2 phosphoric 528:17 529:16,21 530:10 484:18,20 485:3 489:3,21 pets 428:5,6,8,22 536:12,16 579:5,11,14 490:1,2,5,10,13,17,22 536:22 phosphorus 580:6 584:15 591:1 592:17 491:15,20 492:1,22 493:21 peculiar 428:3 459:11,14 460:2 605:20,20 606:5,11 610:11 493:22 494:4,18 495:4,8,15 435:19 501:10 610:14,17,18 497:3,6,9,12,14,15,22 pen phrase pits 498:12,22 499:20 501:3,13 585:20,20 609:6 509:1 551:10579:16611:2 499:19 500:1,2,3,15 501:2 501:17 502:9 503:11 pending phraseology 517:13 527:20 535:8,11,13 505:10,21,21 506:8,10,11 547:22 611:1 579:14 589:6 592:11 606:3 507:8,20,21 508:4,6,9 Pennsylvania physically Pittsburgh 510:5,14,19 514:15,16 406:12,25,28 503:19,20 554:7 605:19 406:28 516:5,13 518:13 521:8 pentoxide pick place 523:5 526:5,6 527:8,11 428:3 531:8,10 418:19421:3 432:18 530:17531:17534:11 people pickup 433:12 451:9 465:1 476:15 537:3 538:8 539:2,14 540:5 418:19421:15422:18 548:1 480:9 481:9 504:1,9 524:13 540:12 541:1 543:22 544:3 462:1 497:17 555:1 558:12 picturing 524:17 525:5 545:10 544:5,7,22 546:6 547:5 562:16 596:18 631:6,8 547:17 560:18 566:1 592:12 606:7 549:7 560:10,16,21 561:3,7 642:1 piece 608:5,11 612:8,11,13 561:9,18,21 562:18 566:18 percent 436:21 449:15 582:21 642:18 567:21 568:8,16 570:1,3,4 437:9 438:10 444:19 445:9 588:16,16 631:9 644:12 placed 570:11 572:20 577:3,11,17 460:5 519:19 520:10 pieces 502:11 504:21 505:1 577:20 578:8 580:15,17,20 554:17 577:7 613:2 450:2 522:3 533:21 555:12 529:16 532:8 533:22 552:7 581:1,5,13,14,14,17,20 percents pilot 590:8 592:5 582:13,15,17 583:2,19 634:2 411:22 412:6,11 413:1,10 places 584:3 587:20 589:3,20 perfect 413:12 419:20 420:1 426:2 524:13 561:17 574:8 591:1,14,16,17 592:17,21 633:7 484:1 494:22 561:21 placing 595:8,10 597:12,13,16 performed 597:12,13,16 598:11,13,17 564:1 598:11,13,17,21 601:15,19 413:17 556:13 598:21 plaintiff 602:6 603:22 604:9,11,16 period pinned 405:6 406:6 605:1,8 606:14 607:5,10,14 424:2 429:13 436:4 447:4 549:8 plan 607:19,22 608:16 609:19 484:3,16,22 510:13 520:10 pinpoint 536:13 541:22 598:14 609:21 610:7 612:20 521:12 522:16 523:22 477:15 planned 616:19 624:18 625:2,20 545:3 546:2 555:17 559:19 pint 507:8 627:11,19,21 630:13,16,19 569:15 571:13 584:2 522:19,21 plans 631:21 636:6,9,21 637:14 permanent pipe 566:8 637:15,19,20 638:8,16 484:15 423:10,17,22 477:15 478:8 plant 639:1 640:8,22 642:2,20 person 567:19 588:4,4,16,17 410:2 411:3412:11,17,19 643:22 644:6,9 645:10 471:12 603:13 635:16 piped 412:20,22 413:6,21 415:22 plants personal 435:5 417:6,12,16418:17419:16 496:22 560:12 561:13,13 589:21 pipeline 419:20 420:20 421:2,16 638:8 619:1 422:3,5,9 424:5,7,16 425:6 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMONO010320 [platen - problems] platen polyphenyls practice (cont.) presume 533:21 453:8 587:19 594:4 596:20 612:3 416:7 458:8 500:5 569:18 platform pond 612:7 623:19,21 624:2,10 599:16 548:3 411:17,22 412:7,12,13 643:15 644:15 pretreatment plausible 413:1,10,12,14,14414:1 practices 538:12 557:15 626:17 420:2 484:1,3,12 492:8,8 570:18 pretty please 492:16 583:11,18 585:7,11 precaution 502:8 510:17 515:8 583:5 412:8 490:6 505:14 515:21 585:12 556:6 595:3 640:10 535:1 578:11 613:10 ponds precautions prevent plug 481:19 575:7,13 635:17 455:22 460:18 526:18 portion precipitation prevented pluggage 597:19 632:17 463:4 480:7 436:2 527:3 posing precise previous plugged 630:1 430:5 642:20 424:17 432:15 466:18 435:21 436:1 position preclude 492:11 496:16 629:16 plumbing 474:14 546:5 560:7 587:12 489:14 644:7 510:18 possibility predated previously plume 417:19 446:17 466:22 607:1 408:4 427:5 434:6 441:21 425:18 429:22 430:6,7 562:15 594:3 628:19 predates 443:13 488:4 506:8 619:4 477:19 possible 455:15 price pna 440:9,16 515:4 536:22 predominantly 522:11 523:3 618:19 537:2 565:8 582:22 586:3 458:21 primarily pncb 588:2 594:11 595:11 preference 587:14 591:21 618:18 607:18 616:19 630:2 570:2,21 primary pnp possibly preferred 428:1 538:9 580:22 581:4 412:21 415:6,6 417:20,22 459:19 466:3 523:21 528:2 570:5 571:1,5 primitive 418:14,16,16,17419:11 534:9 538:12 prematurely 500:11 524:3 553:11 444:2 445:6,13,15,15,17,19 post 570:15 principle 451:18 490:8,9,10 508:10 644:16 premised 426:3 580:13 515:5,10 516:10 538:2 pot 518:6 prior 539:10,11,12 604:19 605:8 532:15 preparation 490:2 492:5 494:7 496:11 614:12,16,19,19 potash 550:22 503:9,17 507:6 546:11 pohl 602:1 prepare 583:10610:19619:22 541:20 552:20 potassium 408:20 priority point 602:8 prepared 584:17 429:4 430:5 435:10 443:12 potent 462:4 489:3 probably 455:2 474:8 484:11,13,14 519:18 presence 410:1 414:22 443:11 451:9 485:16 489:14 515:10,20 potential 445:15 613:19 635:2 454:14466:10471:16 517:5 522:6 535:6 545:1 447:14 present 475:6 478:8 486:21 493:15 546:10,13 553:10 558:19 potter 405:20 428:7 438:3 444:9 508:11 510:3,15 512:19 563:3 567:6 571:3 578:1 406:2 445:19 453:7 458:20 459:8 514:7 521:10 522:10 527:3 581:6 589:17 600:1 602:18 poulenc 488:17 490:4,7 518:1 552:12 568:12 572:16 613:3 624:19 629:20 572:12 526:12 539:9 570:13 573:22 606:13 607:4 points pound 632:16,19 634:14 635:22 611:10624:1 634:14 574:2 551:3,11 presentation 635:16 policy pounds 603:5 problem 559:21 561:9 445:5 522:20 523:2 526:11 presenting 418:2,3 419:3 421:8 424:7 pollutants 551:5,6,6,16 635:3 424:7 425:18 426:16 495:6 poured presents 427:14,17 447:6 482:8 pollution 553:3 634:18 636:1 512:15 527:3 562:3 573:8 437:11,14438:1,4 481:8 pouring press 575:12 576:16,20 579:18 507:9 617:13 555:8 533:21 534:4 613:5 617:21 621:1 627:12 polychlorinated practice pressure 634:18 635:3,7,13 639:16 572:6 413:6 455:13517:10 429:2,5,6 444:18 476:16 problems polyester 518:12,19 560:20 567:10 presumably 421:12422:13,15,15 427:1 567:13 569:22 578:7 471:22 623:1 638:9 424:19425:1,1 437:12,15 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMONO010321 [problems - ramification] problems (cont.) profusion proposed q 437:22 438:4 447:6 467:14 543:9 478:2,22 479:2 quality 581:16 614:6 630:1 program proposing 519:13,15 532:20 542:8 procedure 477:22 506:19,20,21 480:15 571:4 584:10 506:3 552:5 507:11 529:20 557:5 protect quantitative procedures 558:20 560:18 566:16,17 461:6 556:2,6 568:14 624:19 625:3 protecting quantities process programs 571:14 526:7 527:16 551:1 569:4 407:18 432:9 434:22 507:1 prove quantity 436:18 439:21 440:1,9 progress 426:3 414:21 415:10520:13,13 443:18 444:7,15 462:3 407:10,12,15,17,19,26 proved 521:6 538:17 554:12 602:4 483:2 491:7 493:15 515:10 415:17,18419:19425:5 570:11 quart 531:22 533:11 538:5 426:15 442:14 447:19 provide 523:1 545:11,20 554:20 562:8 473:22 505:7 565:14 566:5 440:18 480:11 481:6 quaterphenyl 563:3,11 566:16,22 569:4 574:8 584:7 602:12 513:16 530:14 606:2 453:8,10 572:2 573:12 574:13 progressed provided queeny 580:11 583:15 612:6 530:6 426:5 480:13 561:15 601:6 426:12 433:1 544:7 636:9 619:10 631:19 632:19,20 progressing 602:4 637:14,15,19 643:22 632:22 634:11,15 637:11 416:9,15 providing quenched 637:12 project 436:14 471:6 509:18 518:14 processes 411:14,18412:3,6,10,10,18 561:10 quenching 471:1,10 413:1,18 420:1,3 425:21 provision 512:14 produce 426:14 431:7 432:3 434:9 440:4 600:16 question 521:5 572:6,9 434:17,17 436:14 442:18 pump 411:2 428:9 437:21 496:4,8 produced 443:5 463:11 466:6,9,11 476:7,12 524:18 600:14,15 510:17 571:20 573:1 452:7 516:5 521:8,9,21 474:20,22 505:22 510:16 pumped 576:17,19 577:18 593:10 526:6 543:2 554:16 568:19 588:10 610:2 440:20 441:10 501:22 605:12614:15615:7,8 product 624:19 631:1,4 538:17 539:3 600:18,19 621:1 438:6 439:4 444:12 452:8,9 projects pumps questioning 452:10 502:22 503:5 420:4 431:3,5 463:8 466:2 495:10 587:10 488:8,10,10,12 489:13,15 526:10 531:16 532:18 471:19 481:9 506:16 507:1 puncture 579:22 533:3 554:13 558:15,22 507:9 510:20 511:2 621:21 592:14 questions 559:11 562:2,9 576:7 595:9 627:10,22 628:2 631:5,6,7 purchase 410:5 488:21 615:11 610:4 622:11 626:11 636:10 639:3 529:12 570:1 quickly production prolonged purchased 423:19 518:5 438:14 443:3 462:22 595:20 595:12 quinquephenyl 470:22 471:7,9 497:15,20 promote pure 453:12 497:21 498:3 504:11,15 558:20 527:1,3,6 536:16 quite 518:14 522:14 523:4,8 prone purpose 424:2,4 435:6 449:19 459:9 525:13 526:3 530:20 533:2 423:12 414:10 423:21 428:2 467:2 468:14 495:4 605:2 546:7 547:5,11 553:6,13,14 pronounce 456:11 458:18 476:18 608:6,17 623:11 635:17 560:3 561:7,21 568:18 460:6 510:1 532:6 550:5,21 559:1 quote 604:10610:5 611:3 617:11 pronounced 559:18 574:5 594:19 612:5 549:1____________________ 617:20 644:11,22 416:22 purposes products properly 413:16 480:16 558:16 r 444:8 446:12 459:11 440:12 479:13 480:2,4,8 pursuant railroad 502:19 559:14,22 634:13 properties 405:17 608:12 609:5 professional 532:19 562:7 put rain 632:9,10 property 423:18 429:16 461:5,5 605:5 professor 449:13,15,16 450:6 498:22 481:9,12 484:21 492:14 rains 416:10,16 499:18 501:7 607:14 493:4 528:19 529:6 548:10 409:22 410:7 profit 506:19,22 507:10 proportion 438:13 452:13 548:22 573:4 588:10,17 rainwater 590:13 613:6 617:2 624:22 410:3,14,16 profitable proposal 635:16 ramification 571:7,9,10 478:11 481:17 625:19,22 putting 509:12 626:3 630:5 638:22 453:10 466:12,15 485:16 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMONO010322 [ran - reference] ran reads recall (cont.) recollection (cont.) 433:11 440:22 484:22 626:6 634:17 547:11 549:13,21 552:5 503:12,21 513:4 519:1,13 random ready 553:13 555:16,22 556:6,18 520:8 525:17 537:13 529:1 484:21 489:12 543:10 558:7 559:7 560:9 561:4 545:22 552:9,12 553:7 range real 562:4,13,16,17 564:10 555:6 558:2 563:15 564:20 456:6,10,15 566:8 449:21 565:15 565:9 566:14 567:2,9 569:5 583:18 593:2 620:17 rapid realize 568:19 569:15,21 570:5 621:20 633:12,21 642:16 597:1 489:20 589:9 578:22 579:1,2 580:14 reconstruction rate realizing 581:8,22 582:12 587:9,20 441:20 429:1 433:12 449:21 584:19 588:14 589:4,10 590:12 reconvene 452:18513:12613:17 really 591:4,12 593:4,19,22 645:17 rated 423:20 447:14 496:8 529:3 594:14 595:14,18 596:1,3 reconvened 560:22 529:9 555:7 574:7 598:19 596:16 597:4,7 599:8 487:2 rates 631:8 600:12,17 602:12,16,19 recooling 522:4 rearranged 603:12 604:8 605:2 606:14 612:4 rating 620:3 606:17 607:13,19,22 608:4 record 561:2 reason 608:19 609:7,13 611:6,9,15 409:16 411:8 420:9 430:11 raw 437:7 456:2 485:5 519:1 611:19612:17617:16 434:1,2 442:12 488:19 407:29 418:12 452:20,21 563:18 602:9 628:9 619:13 622:3,7 623:10 489:21 505:9 507:15 514:6 453:2,11 595:1 618:14,18 reasonable 625:8,11 627:4,17 629:1 542:8 562:10,11 578:15 618:21 626:16 636:11 507:12 517:16 630:20 635:2,13 636:19 583:7 586:1,7 603:16 609:9 reach reasonably 637:1 639:3,7,15 640:21 615:12,13,17 616:6 629:4,5 500:5 533:7 605:14 618:16 414:2 415:5 439:6 529:3 642:1,5,18 643:2 644:3,8 629:9,15 645:15 618:22 637:20 reasons 644:22 recover reached 484:4 614:4 recalled 524:1,6 429:15 547:2 600:1 rebuilt 539:19 590:2 606:3 609:1 recovered react 536:12 583:22 receive 433:20 434:11,20 525:8 458:20 518:4 recall 571:5 581:15 rectangular reacted 410:9,21 411:1 413:13,17 received 585:9 458:22 414:4,12415:1,13,13,20 424:18 434:7 505:11 518:9 recurrence reaction 416:3,18 417:5 418:2,13,21 545:5 566:9 570:10 636:16 442:2 417:20 418:8,11 419:10 420:22 421:5,19 422:8,14 receiving recycle 435:5,19 440:15 444:9,12 422:16,18,20 423:3 424:22 415:13 495:21 496:2,3,6 444:18 444:21 445:8,11 459:17 425:11,20 426:21 427:5,14 recess recycled 460:9 476:15 526:8 527:5 429:7 430:1 431:11 435:13 448:20 473:17 541:12 435:1 495:9 512:4 536:19 437:7,14438:11,15441:13 578:13 603:15 redistilled reactions 441:15 442:6,18 443:5 recessed 452:5 418:5,11 419:2 446:2,20 447:8 449:16 487:2 reduce reactive 450:20 453:5 454:17 455:3 recipient 412:14 419:7 483:11 507:4 536:18 456:8,15 457:3 468:4,10,12 415:17 544:9 604:2 625:15 535:12 reactor 469:9 470:6,10,19 471:6,19 638:19 reduced 432:11 453:17 476:14,17 472:2,10,12,17 473:12 recognition 419:12428:13483:9 476:19,20,21 573:3,4 474:3 475:17 476:8,10,22 438:2 reducing reactors 477:4,11,13,17478:19 recognize 419:10 428:19 446:1 584:1 432:6,8,8 441:1 453:17 479:2,3 481:8,14 482:3 431:10 448:16,16 508:1 594:6 599:16 483:2,5,6 484:5 485:13 510:9,10 544:10 597:18,21 reduction read 492:7,9,21 493:14,18,20 618:1 621:10 484:19 449:3,9 535:16 640:16 494:6 499:17 500:15 503:2 recognized refer 644:17 503:5 504:2,20 505:19 426:16 414:5 417:2 418:6 420:1 readily 506:4,9 508:11 510:5,18 recollect 475:3,6 512:21 549:4 603:10 614:2 511:6 512:17 515:22 516:3 434:16 448:17 452:1 530:1 635:10 637:11 reading 519:4,8 523:3,7 525:3 recollection reference 507:5 535:5,8 601:1 605:9 529:14,19 531:21 532:10 434:13 455:5 466:4 479:20 418:5 421:14,21 427:7 615:2 535:14,17 536:11 537:3,10 480:6 481:11 482:8 484:2 434:20 435:2 440:3 446:17 readout 537:16 538:6 539:2 540:1 484:17,21 490:19 491:16 446:22 447:18,19 448:2 580:12 544:8,17 545:2 546:1 492:20 494:5,15 498:7 451:11 469:7 475:16 478:5 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMONO010323 [reference - require] reference (cont.) registration remember (cont.) repack 480:4 490:10 491:6,9 632:10 447:17 449:19 454:6,14,15 429:17 430:3 506:18 509:10 531:16 regular 457:2,5,9 460:20 461:1 repair 548:21 573:11,19,20 585:11 597:10 462:9 463:7,11,20 464:15 463:8 510:12 576:10,12 582:8,8 583:10 regularly 466:8 467:12,18 468:6 repairs 598:2 602:16 616:12 619:3 596:19 470:5,9 471:12 472:5,13,14 641:11 619:8 620:15 621:14 reinforced 473:6 475:12 476:12,16 repeat 622:18 628:18 634:16,20 427:1 477:3,9 478:18 480:10 412:8 634:21 637:5,10 638:1 relabeled 481:22 482:6,12 484:4,8,12 repetitive 639:20 559:16 484:13 485:1 486:8 491:8 488:10 referenced relate 497:5 499:10,15,21 500:21 repiping 451:3 482:11 507:7 579:6 412:2 414:18 501:14 504:19 505:3,3 568:20 references related 506:21 508:2,8 510:16 replace 448:8 482:21 484:1 412:18,20 468:1 522:4 515:15 517:7 519:6,7,16,20 434:19 466:3,7 558:15 referred 540:10 541:1,3 550:6 520:15 523:12 524:4,7,10 562:1 628:1,16 423:16 432:13 445:14 599:13614:9 615:11 525:9,12 526:1 528:15 replaced 448:3 449:15 478:7 494:4 618:10,13631:5 531:19 535:18 537:20 443:8 478:2 517:4 530:11 499:7 502:17 520:12 relates 546:4 547:16 548:5 549:15 587:22 588:19 627:14 551:15 566:1 573:22 447:6 552:1 549:15,16 553:9 555:21 628:11,13 629:2 589:12 597:5 relating 556:2,3,15,20,21,22 557:3 replacement referring 488:21 542:14 580:16 557:4 558:12 559:5 560:19 426:6 510:12 529:21 628:8 420:2 449:7 466:1 534:6 582:1 561:2,12,18,22 563:21 replacements 560:3 629:15,16 643:21 relation 564:9,18 565:8 568:2,2,3 628:4 refers 521:6 568:12,13 569:6 570:9 replacing 412:21 414:17 434:8 relationship 574:19,20 575:14 579:18 423:14 445:21 469:11 536:15,21 421:9 521:20,21 582:4 583:21 584:4 585:12 report 541:5 599:15 609:16 618:9 relationships 585:12 588:2 589:7 590:10 407:10,12,15,17,19,26 622:20 623:1,9 626:15 601:5 590:14 592:8 594:3,4 415:17,18419:19425:5 634:22 637:13 relative 595:13,17 596:6 597:9 426:15 434:18 437:18,19 refined 418:15 452:13 527:11 600:8,14 603:1,6 604:13 442:14 443:10 447:19 452:19 502:21 relatively 606:1,19 607:18 609:4 473:22 479:7 505:8 565:14 refining 538:3 611:21 612:1 617:7,19 566:5,20 568:7 584:7 620:4 relatives 619:12 622:2,6 623:11,16 602:12 603:2 640:5 641:3 reflect 408:14,16 625:1 626:19 627:13,22 641:13 642:9 583:7 586:1,7 597:12 609:9 released 628:21 630:18,21 634:11 reported reflected 429:19 599:22 634:15 635:7,8 640:14 497:18 537:20 483:6 503:4 releases 641:3,15 642:10 644:11 reporter reflecting 436:8 remembered 405:20 617:3 635:22 reliability 504:6 reporting reflects 426:8 571:3 reminded 632:7 578:6 relieved 610:16 reports refresh 600:2 remote 644:16 620:17 621:20 remainder 432:1 612:10,13,14 represented refrigerant 415:4 remotely 435:7 539:4 568:19 595:1 476:18 remained 432:12 representing refuse 528:17 removal 634:13 607:13 remarkable 433:20 634:18 635:4,9 represents regard 575:13 remove 414:21 466:18 412:6,11 517:10 643:7 remarkably 458:16,18 520:5 601:3 reprocessing regarding 423:11 619:16 634:1 635:15,19 560:9 411:22 414:13415:21 remember 637:2 request 425:5 430:22 470:22 409:6411:4,12,15415:11 removed 411:13 430:17 625:20 593:14 630:22 631:17 415:15416:2,8,17419:15 458:22 563:1 633:9 634:2 requests registered 421:7 422:10 424:3,11 636:20 430:22 431:3 632:9 425:3 430:4 431:14 435:16 removing require 437:17 443:16 446:14 429:9 635:9,10 575:13 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMONO010324 [required - savage] required 426:7 432:7 512:7 529:20 574:13 611:20 612:8 requirement 617:3 requirements 620:11 requiring 624:12 rereviewing 489:15 research 558:8,8 562:5 625:21 reside 408:10 495:10 resides 645:8 residue 432:10 433:5,7,10,13,15 434:21 440:21 453:10 502:8,9 525:20 526:12,15 541:16 543:16 544:15,18 551:2,9 552:16 576:10 638:9 residues 438:10,16 452:2 503:16 542:6 637:7,11 638:1 resistant 559:3,16 resolved 576:21 622:13 respect 414:5 431:11 433:2 437:15 463:9 466:22 540:11 573:13 577:3 respective 405:21 response 479:7 594:14,17 responsibilities 430:21 433:2 464:1 527:12 589:9,18 591:9 611:4 617:14 630:22 631:17 responsibility 431:3 455:19 462:17,21,21 469:3 506:11 546:11,12,14 589:19 607:6,7 640:5 responsible 493:12 497:7,22 530:17 531:1 546:19 548:14 556:8 591:21 rest 572:8 612:15 restricting 468:8 472:20 result ring 417:19,21 436:9 459:15 585:15 639:10 569:4 570:14 634:3 641:1 rings 642:2 453:13 resulted rinsed 422:22 434:17 435:19 526:20 575:11 rise resulting 429:3 644:10 rises results 440:15 614:4 626:5 632:16 risk resumed 571:2 407:3 408:4 488:4 river retired 470:7 473:2 495:14,15,16 550:13 645:7,11 road retrieved 498:22 499:8,19 549:19 547:13 553:8 550:2 606:12 retrieving rodell 525:15 631:11 return roedel 488:8 559:22 560:18 631:12 returned role 560:8,17 525:14 625:22 626:2 review rolling 409:1 469:19 489:12 538:20 505:15 543:18 room reviewed 475:20,22 476:1,3,3,4,4,11 430:15 470:1 482:19 476:13 563:17,19 612:16 489:18 505:17 535:2 613:6 543:12 566:11 578:19 root 593:16 596:12 599:5 604:5 565:16 629:13 640:19 rosenberg reviewing 462:2,6 489:10 rotate revisions 563:5 478:1 rotated rhone 563:7,8 572:12 rotating ridge 563:4,4 456:8 roughly rifle 483:16 587:11 456:6,10,15 500:11 round right 454:16 411:19 425:9 443:4 447:3 routine 459:13 475:6 481:20 416:6 423:6 437:21 547:21 483:20 490:14 492:15 595:3 644:15 495:8 496:10 498:19 512:8 routinely 512:16 514:3,6 516:9,11,14 461:12 467:3 518:16521:1,11,19530:5 rubber 551:8 554:5,14,18 569:2 426:18 574:15 582:11 587:1 592:7 rubbish 598:3,16601:17607:4 607:15 609:12 614:18,22 615:10 rule 617:11,15621:15625:16 546:21 626:13 636:9 638:4,19 run 645:15 439:3,4,7,9,12 454:8,10 run (cont.) 552:6 569:13 584:22 607:3 615:9 runaway 440:4,7 441:13 442:5 running 460:16 564:16 581:2 597:15 600:7 602:6 runs 599:15 rupture 600:2 russ 474:12 rusting 624:7 s 559:10 salt 459:9 602:1 salts 632:18 sample 557:5 580:9 samples 416:6 426:8 427:13 sampling 556:21 557:1,7 580:16 sand 592:13 sanitary 471:3 494:11,14 508:15 509:1 565:13 602:18,22 603:8,13 santotar 504:18,19 450:11,15,21 451:4,7,8 452 2 6 8 11 14 19 21 453:3,3 454:8 455:11,14,17 455:20 502:1,10,11,13,20 502 21 22 503 1 504 8 21 505:4 553:22 554:4,11 558:11 575:4 611:2,4 satisfaction 4RQ-11 satisfactorily 576:21 saturated 634:17,20 savage 405 13 16 407 3 6 408 3 8 409:14J 7 411:5*10 418:2 420:7,11 422:12 424:16 430:9,13 442:10,14 448:21 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMONO010325 [savage - side] savage (cont.) secondhand 449:3 469:12,18 471:2 470:8,10 473:16,21 482:13,17 488:3 section 488:21 489:5,20 505:12 437:17 508:10 590:17 541:18 542:1,7,16,21 543:6 sediments 543:8 566:10 578:18 468:1,5,17 540:22 593:15 596:10 599:4 604:4 seeing 615:14,21 629:6,10 639:20 460:20 461:2 470:5 486:8 645:20 500:15 505:3 547:12 saving 549:13 573:13 590:2,14 507:2 593:4 605:3 606:3 saw seeks 448:1 454:22 456:14 493:7 540:11 577:2 500:16 516:16 540:10 seen 557:17 576:12 584:15 470:3 538:19,19 603:19 590:8 593:5 598:15 605:6 622:16 641:3 saying segregated 618:17 504:5 says sell 409:22 415:5 421:15 610:3 424:20 451:18 458:7 selling 467:22 477:2 478:10 559:14,15 609:22 480:20 605:15 619:3 semantics 620:22 626:11 634:20 447:11 635:9 semiliquid scavenger 526:14 532:17 semisolid schramm 523:19 542:19 send scrap 433:15 560:2 612:4 547:9 sending scrape 596:16 563:9 sense scribbled 478:16 517:18 581:18 566:6 608:22 618:12 scrubber sensitive 425:6,15,21 426:4,17 427:2 539:11 427:8 428:4 512:1,2,3,5,9 sent 512:13513:1,9,11,13 409:18 420:16 429:10 516:16 520:4,7 526:19 430:18 458:16 464:8 564:7 579:11 584:15 485:17 518:20,22 525:10 589:13 592:16 610:16 526:15 527:16 539:19 seal 577:12 596:9 616:10 588:17 sentence second 415:4 431:22 506:15 414:2,6,8 416:13 419:18 545:22 579:19 626:6 424:15 431:20,22 436:18 634:16 641:17 443:22 457:22 463:15 separate 467:19 475:1 484:14 485:6 420:4 422:2 476:3 491:12 506:15 507:7 509:9 540:18 565:5 613:5,5 618:20 545:18 571:2,3 589:11,15 626:20 633:6 604:15611:12621:13 separated 640:16 641:16 422:6 444:12 640:7 secondary separating 538:6,7,10,22 539:1 581:4 641:7 581:9 586:9 separation sewers 613:1 620:12 633:5,7 412:16413:5 441:10445:4 September 507:19,22 508:7,15 510:12 409:22 410:7 415:16,21 565:13,14 634:6 469:14 505:9 535:19 shaped 552:17 454:17 sequence shed 466:11 485:19 506:19 541:2 545:8 549:2 sequential 551:1,12 557:12 577:11 558:4 590:19 591:20 593:7 598:4 sequentially 610:22613:10 541:7 sheds series 576:19 511:10 542:22 559:11 sheet 565:19 407:29 439:22 448:2,4,5 serious 620:3 575:12 ship served 570:3 498:14 509:21 612:5 shipped service 457:20 465:18 531:17 484:21 544:2 560:15 577:8 612:21 627:8 services 638:7 505:8 509:19 shipping session 525:15,20 531:5,6 537:13 488:1 537:16,19 547:13 548:1,15 setting 548:18 559:8 611:13 500:12 556:8 577:19 638:12 settle shooting 539:1 500:9,10,12,12 549:20 settled 550:6 606:4,12 495:9 587:15 shop settler 450:22 451:1,3,17 495:9 538:6,9,11,22 539:1 short 586:9,12 426:20 settles show 632:20 417:22 543:4 565:15 settling 586:16 536:13 showed seven 460:21 421:16 showing seventh 590:3 406:10 shown severe 451:19472:15505:11 426:16 479:12 480:1 516:20 545:5 551:1 566:9 severson 590:15,18 542:13,19 546:12 shows sewage 514:14,22 515:3 420:19 421:2 478:1 613:13 shuffling sewer 453:19 419:11 423:10,16,22 shut 445:20 465:11 475:14 429:16 508:2,4,5,6,8,10,11,12 sick 511:4 557:20,21 558:1 642:17 564:11,13 565:11,13,13,17 side 581:3 587:18,22 600:19,20 413:16,21 417:20 418:5,11 600:21,22 419:2,9 435:19 454:15 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMONO010326 [side - sources] side (cont.) sir (cont.) slash sold (cont.) 456:8 464:22 465:2 485:17 546:18 547:11 548:6,20 425:13 551:12 559:20 485:18 498:13 514:15,16 549:2,18 550:1,16,22 sledgehammer solid 527:12 538:14 582:15,15 551:22 552:5,18,22 553:2 553:5,9 554:20 555:14 436:10 444:11 449:4 585:22 589:20 609:8 553:16 555:13,17 556:17 sledgehammers 452:20 504:14 508:19 sides 557:6 558:5,6 559:19 555:2 509:9 526:7,16,18 532:3 565:1 560:21 561:19 562:13,20 slope 539:3 542:14,20 545:9 signature 563:13 564:10,16,20 565:9 456:7,10 546:10 548:21 553:3,7,17 621:7 565:14,19 566:14,19 567:1 slovensky 553:17 554:3,3,4,7,9,13,16 significance 567:5,10,12,21 568:4,10,14 422:12,14 424:17 554:19,22 562:20,22 563:6 629:20 569:15,21 571:6 572:18 slow 563:12 564:1,8 567:7,8 significant 573:7,11,19 576:10 577:1,3 433:12 436:3 577:6 600:16 433:10 480:21 610:2 577:5,10 578:9,9,22 579:5 sludge solidify 619:10 580:5,5,14,20 582:7,12,21 495:8,9,11,12 539:6 598:18 454:9 553:4 significantly 583:4,10 584:5,9 585:19 616:14,20 617:4,17 620:14 solids 605:22 586:3,19 587:5,13,20 588:3 620:18 622:19 632:21 454:1 536:7,13,14,14,15,20 silica 588:21 589:1,4,8,22 592:2 634:22 635:3,9 636:19 536:21 537:1 539:1,4 536:17 593:19,22 595:18 596:3,15 637:2,6 587:15 601:3 619:4,9 similar 597:4,18 598:4 599:8,12,19 slump 621:21 622:22 630:1 639:4 411:14 429:20 496:22 600:12,17601:1,18602:11 530:5 soluble 572:14 579:22 593:4 602:14,21 604:8,14,18,22 small 418:1 428:7 444:11,22 642:14 605:2,7,17 606:14 607:10 423:18 426:2 428:2,5 431:5 solution simple 608:3,18 609:10,12 610:9 484:17,17 485:7,11 524:6 594:2 484:9 551:19 564:2 580:8 610:22 611:12,15612:3 526:14,22 539:7 607:5 solutions 583:5 628:4 613:9 615:10 612:10 630:2 simpler site smaller solve 613:22 461:11 495:14 499:1 522:3 631:7 421:7,12 simply 501:12 549:7 591:18 smell solvent 410:12 413:15 437:6 605:18 417:8,13 444:16 438:13 447:16 450:5 situated smith somebody 458:22 467:7 518:20 495:15 405:18 439:13470:15510:10 528:22 574:9 592:13 situation smull 626:4 637:1 639:12 599:22 613:7 620:6 629:22 419:14 428:3 429:20,21 542:4 somewhat 633:5,22 636:20 469:5 482:4 546:22 616:19 snow 428:11 518:1 537:1 546:22 single 619:12 620:18 639:12 413:17,20 414:5,9,13 415:2 605:5 612:14 613:22 614:4 508:8 569:16 570:21 situations 464:14 467:5,6,10,16,20 618:10631:3 sir 480:22 468:1,5,15,17 469:1 473:9 soon 408:10 489:8,22 490:17 six 473:10 495:17 496:2 588:19 643:12 491:9,15,19 492:21 494:7,9 430:4 498:11,13,18 514:19 537:5 sorry 494:18 495:13 497:2,11 size 539:21 540:4,18,22 541:2 433:22 448:9 477:8 541:11 498:11 499:6,17 500:8 431:4 461:4 495:21 496:6 557:7,10,13610:10 574:15 501:11,21 503:9,19 504:2 529:11 snow's sort 504:10,20 505:14,19 506:4 sized 515:1 516:20 414:5 590:12601:10 506:14 507:5,14,16,20 411:17 426:5,17 494:21 soda 626:10 637:3 508:17,22 509:9 510:5,12 skeet 433:19 434:4,7 476:2 sorting 511:9,14 512:17,21 513:7 500:10 sodium 637:17 513:13 514:10 515:4,16,20 skeptical 418:9 444:9 445:9,10,14,15 sound 515:22 516:15,19 518:8 477:16 445:17 459:9,10,10 460:6 423:12 520:17 522:7,12,16 523:7 skiffs 593:14 594:19,22 595:7,9 sounds 524:8 525:13 527:7,19 531:8 595:15 596:4 602:8 634:12 635:6 528:8 529:14 531:6,21 skim 634:12 source 532:10 533:10,14 534:17 524:22 soil 442:20 446:1 526:16 534:20 535:4,8,10,14 536:6 skimmed 463:5 467:1,7,15 557:10 570:21 571:2,3 536:11 537:8,22 539:18 525:4 sold sources 540:9,17 543:13,19,21 skip 502:7,19,21,22 503:1 448:3,4 475:2 477:5,9,12 544:8,11,17 545:4,8 546:1 525:18,20 552:13 522:11 533:3 551:4 559:18 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMONO010327 [south - streams] south splitting start steps (cont.) 406:18 422:3 451:2 584:16 555:13 408:8 417:14,15,16 424:4,6 455:21 460:17 482:3 509:5 southern spoken 426:16 434:4 459:7 473:21 509:6 515:9 641:6 501:5 409:8 489:13 528:8 588:19 Stewart's soviet spontaneously started 410:11 572:14 525:6 493:22 521:17 558:19 sticking space spot 569:7 570:8 457:7 544:20 451:9 557:5 586:17 starting sticks spaces sprague 543:15 592:14 534:1 474:10,12 starts stills spare spray 431:22 632:15 432:10 433:9 437:4 442:7 480:16 608:5 478:22 481:17 482:11 state 515:13 531:22 532:1 spargers sprayed 405:2 406:23,24 498:21 stone 538:16 642:14 statement 480:7 588:5,13 speaks spraying 414:20 415:8 416:9 417:18 stones 594:6 594:1 419:19 424:15 433:17 592:14 spec square 438:5 443:22 463:12 stoneware 533:6,8 406:9 454:16 475:19 476:6 479:16 478:2,5,8 special St 567:12 577:6 592:6 605:10 stop 432:7 575:6 461:17,22 494:12 556:10 statements 447:16 476:11 588:10 specialist 596:22 603:3 631:14 477:16 stopping 426:11,13 stack states 489:15 specialized 409:5 425:19 429:22 422:11 438:8,20 470:22 stops 631:22 632:2 435:11 478:1,22 616:13 516:12 specialty staff static storage 443:13 618:7 497:15 441:4 432:11 433:5 478:12,13,16 specific stage stationary 481:17482:10513:20 411:12417:9419:17 515:12 517:6 597:16 495:11 514:2616:15617:2 619:6 425:10 432:7 437:17 450:5 stages stations 620:19 622:3,9 623:1,2,16 453:6,6 467:12 477:9 617:8 623:18 624:5 623:18 624:14,15,20 625:7 506:21 510:16 518:7 stagnant statistical 626:6,18,20 627:2,5,12,13 531:18 545:3 571:14 441:7 410:18443:11,19 628:1,10,14,17,19,20 630:6 595:14 625:8 628:21 633:6 staley statistics 631:1,18,22 632:4,21 634:4 specifically 519:9,11 520:12 443:12 635:11 636:20 416:5 423:3 443:16 446:4 stamp status stored 474:21 477:2 511:11 537:4 508:18511:11 534:19 421:15 547:22 608:6,7 612:20 544:14 550:18 557:7 584:11 stay storm 562:14 566:20 604:15 stand 553:18 508:2 565:13 631:19 639:15 644:21 408:4 488:4 626:8 steam story specification standard 477:21,21 574:3,3,4,9,9,11 564:21 570:9 519:17 520:16 439:21 506:3 555:18,22 steel strange speculating 556:6,9 559:2 573:12 592:7 531:18 555:1 575:2,10,21 499:12 572:1 410:12418:18 592:10 597:2 612:3 623:17 623:7 627:9 stream speculation 624:21 625:19 step 413:16414:15,17452:8 410:11 418:22 566:3 standards 413:11 417:21 418:6,7,8,17 453:14 458:13 460:5 speeds 624:11 625:5,5,8,12 419:6,8,9 432:9 434:10 475:14 483:8,12 495:22 469:19 standing 435:5,9 436:18,19,20 444:8 496:3,3 512:4 595:9 604:15 spend 569:22 444:12,17,17 459:18,19 605:1,3 609:14,15611:13 481:7 489:9 standpoint 460:10 484:14 512:13 612:10613:18614:22 spent 493:15 497:17 571:4 532:20 533:18 563:2,11 619:12,13,18620:1,11 445:1,3 532:7 560:1 633:6 standridge 581:10620:4,4,6,10631:15 633:14,16,20 633:11,17,19 634:5,9 420:19 421:1,10 422:12 633:9,10,13,18 streams spigot stands Stephen 442:19 446:16 447:9 588:15 613:14 406:7 453:19 603:21 632:20,22 split stapled steps 633:18 555:7 616:3 419:1,4 431:17 440:8 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMONO010328 [street - taffee] street subject (cont.) 405:19 406:4,11,17 408:12 422:21 442:22 470:20 strengths 474:7 486:19 505:19 519:21 507:18 529:4 541:16,21 strike 542:5,19 566:7,14,18 446:21 483:14 558:5 576:12 579:2 593:20 593:10 603:21 612:22 629:18 stripper 640:21 634:2 subjects stripping 413:20 422:19 619:16,21 submission strong 449:1 475:16 subparagraph stronger 544:14 551:2 566:20 520:1,2 subsequent strongly 412:16 459:18 587:5 568:2 610:15 structure subsequently 416:2 570:13 582:9 583:12 460:10 472:8 583:14 585:9 substance stuck 502:4 504:18 528:14,21 447:11 538:3 574:22 studied substantial 441:22 461:12 500:5 524:2 444:10 452:7,10 496:14 529:5 571:20 substantially studies 454:1 455:15 483:8 521:9 416:9,15 419:20 426:8 539:16 443:17 467:14 486:18 successful 589:2 598:17 483:7 520:10 study successfully 410:19411:1 415:20416:2 447:13 416:4 443:10,16 445:21 suffer 446:3 461:13 467:18 550:20 505:15 529:11 534:22 suffered 543:9 558:12 589:12 637:2 studying suffering 437:21 640:22 642:2 studz sufficient 471:3 574:10 stuff sufficiently 527:5 603:17 554:7 stutz suffix 411:21 415:21 479:11 503:2 480:11 481:15 493:14 suggest 494:9,16 496:10,13 578:17 589:1 596:9,16 601:11 603:10 suggesting stutz's 480:14 630:2 479:6 481:13 suggestion style 481:13 535:10 482:2 suggests subcategories 414:10 546:17 551:9 suing subdivision 421:17 497:19 suitable subject 478:14 414:3 416:1,19,21 420:18 suite sure 406:18 428:14 447:22 449:14 suits 455:6 467:2 486:14 494:2 421:17 500:21 504:16 514:5 520:9 sulfate 540:12 545:2 546:15 634:12 553:15 560:14 571:19 sulfide 585:6 587:18 619:2 633:13 435:7 475:16 surety sulfur 405:9 417:3 435:20,20 436:6,8,10 surface 526:7,9,11,13,17,18 527:1 460:22 484:10 492:13 527:2,4,4,16 594:7 505:1 517:20 524:20 sulfuric surprised 633:3 644:20 578:3 summary surprising 444:1 506:15 507:8 548:20 611:22 summer surrounded 432:20 565:7 sump suspect 515:18 516:2 581:21 superintendent suspended 474:13 497:16,16,18 527:21,22 528:2 604:10,12 606:20 sustained superior 644:12 405:1 swan supervising 501:8,10 571:17 572:1 546:22 sweet supervision 606:15 609:15 497:10 sweets supervisor 606:19,20 607:3,16 608:4,4 443:3 462:22,22 497:21,22 609:1,8 498:2 501:16,18 520:2 switching 522:14 523:4,8 524:1 535:11 525:13 526:2 530:20,21 sworn 537:16 546:7,9,18 547:5 408:4 488:4 553:13,14 559:7 560:4 symbol 568:18 604:11 617:12 513:8 551:3,6,12 644:12,22 synonymous supervisory 427:6 591:9 synthesized supplemental 562:6 407:13 system supplied 426:4 436:5,15,16,16 437:2 453:18 437:6 442:2 459:20 490:16 supply 495:2 496:19 508:2,8 571:4 526:20 557:20,21 558:1 support 561:2 564:5,7 567:22 568:5 598:19 601:6 641:12 573:21,21 574:6,7 601:16 suppose 609:17 619:5,9 637:7,10 467:7 535:18 578:6 623:12 systems 638:13 437:8 440:11 559:6 637:20 supposed 520:5 570:14 suppress 419:2 table 448 1 taffee t 506:6,7 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMONO010329 [tail - time] tail telexing testing think (cont.) 424:18 596:21 413:17414:5 439:10 637:13639:14641:22 taken tell 517:19 537:4 582:2,4 643:1,15 645:5,7,12 414:2 419:4,14 428:10 436:16 448:18 483:5,13 598:12 thio 441:9,22 453:15 454:7 493:20 510:21 532:13 tests 432:8 435:4 476:6,7 576:8 455:21 457:13 460:17 539:13 543:21 550:12 439:3,4,7,12 485:7 576:9 595:19 596:2 509:6 550:14 555:11 575:7 572:11 623:3 text third 595:4 606:8 638:11 telling 534:18 597:5 599:15 421:14427:7 436:19437:6 talk 499:17 thank 543:15 423:7 temperature 417:2 540:15 573:7 609:10 thirty talked 440:13,15 476:16 574:3 thereabouts 406:10 458:4,6 473:1 637:14,14 temperatures 457:11 thoroughly 639:18 440:11 thermally 579:20 talking temporary 440:9 thought 417:16418:10451:10 483:20 485:13,14 588:18 therminol 409:2 441:12 473:7,9 454:11 472:13 558:12 tend 558:14,21 559:1,2,8,11,15 514:13 606:22 626:5 566:2 580:4 526:18 560:15,16 567:22 568:4 631:16633:16638:6 talks tended 573:20 574:6 639:11 414:15 436:14 477:22 529:2 thickener thousand tank tends 586:13 551:20,21 434:8 440:21 478:12,16,19 517:22 thing thread 483:17 524:18 597:4,8,10 tenure 417:11 420:6 442:2 452:1 567:20 597:11 624:6 625:7 626:6 450:17 451:6,15,22 454:4 461:3 473:5 482:6 483:21 threaded 626:18 627:9 628:8 632:1,4 459:2 488:22 515:22 550:1 484:2 488:11 516:4 547:21 567:19 634:19 635:4,10,11,16,20 552:11 556:17 569:16 585:10,14 610:6 three tanks 592:21 605:3 things 411:8 413:9 437:8 521:18 475:6,13 479:12 480:1 term 408:9 451:19 470:8 481:1 521:22 551:9 564:21 587:9 482:5 491:14,16 513:20 418:15 427:2,5 465:12 525:8 528:6,6 536:3 547:2 615:16629:8 514:2 585:13,16,21,22 501:14 504:19 509:3 547:3,4 561:15 562:1,2 threshold 586:6,15 587:8 616:14,15 512:11 536:14 538:15 567:13 607:6,7 620:8 427:20 428:12 616:20 617:2,4,18 619:6 545:10,17 562:5 634:14 643:16 thrown 620:14,19 621:17,22 622:4 terms think 543:10 549:1 622:9,17,19,20 623:1,2,7,9 445:4,5 459:5,5 495:22 409:7 410:12,18413:14 thursday 623:10,11,12,19624:12,14 549:4 561:22 565:10 615:8 415:5 418:17 420:3,6 422:5 405:15 543:1 624:15,20,22 625:2 626:20 625:6 425:13 441:17 446:4 time 627:2,5,12,14 628:1,10,14 terphenyl 451:18 455:12 462:12 411:2 412:13413:6415:21 628:17,17,19,20 629:1 452:10,19 453:4,7,16 480:15 481:1,5,5 483:21 416:2,5 417:6,14 419:3,13 630:7 631:2,18 632:21 553:21 485:4,4,19,22 486:1,3 419:15421:2,3 422:15 634:4 636:20 637:2 639:8 test 491:13 496:8,20,21 498:10 429:7,13 433:1 434:13 639:13 413:16 583:19 585:12 500:16 502:11 504:12,16 436:4 437:2 438:17 439:2 target 613:22 614:3 615:9 641:17 504:16 506:11,13 509:3,22 440:20 442:20,21,22 443:8 500:12 tested 511:21 512:20 513:20 445:18,19 447:4 449:12,19 task 483:3 595:15 514:4 515:8 521:15 522:2 450:20 451:1 452:4,15,16 616:13 testified 522:22 525:5 527:9 529:18 455:3,4,15 456:16,17 460:5 technical 408:5 488:5 500:9 539:18 530:19 531:5,11 534:2 460:13,15,16461:12,19 419:16421:7,10,11 423:1 549:6 588:3 590:22 604:18 546:10 549:10 550:3 557:1 466:1,19,20 467:3 468:7,8 443:1,2 505:8 529:11 544:2 testifying 557:12 559:18 563:16 468:16471:13472:3,21 601:6 499:1 511:14 564:12,22 570:3,11 571:19 474:8 475:5,15 479:17 telegram testimony 573:16,19,22 576:11 484:3,16,22 485:2 486:10 596:9,16 464:15 492:11 499:6 579:17 580:3 583:17 585:5 486:21 489:10 490:4,8,12 telephone 516:19 521:16 527:15 589:8,10 590:19 600:22 490:16,20 492:3,4,7 493:21 420:18 540:4 554:10 575:6 583:10 603:16 604:11 605:14 496:16 497:8,11 499:19 telex 588:21 590:2 592:3 599:18 606:3 607:4,7 608:12 610:2 500:20 501:1,16,17 504:20 597:1,5,19 600:4601:18610:11,19 613:14 616:22 617:3 504:20 505:15 506:1,2,9,22 telexed 626:14 622:10 624:1,11,21 626:8 506:22 507:3,3,20 510:2 596:18 632:14 635:21 636:16 517:6 521:12 522:16 524:5 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMONO010330 [time - understanding] time (cont.) top (cont.) treat tsd 525:1,1 526:5 527:10 597:18 621:15 625:15 412:14 484:18 578:1 431:2 442:14 443:7,9 530:13,13,15,15,20 531:7,7 626:11 638:19 treating 447:19 473:21 479:7 531:10,10,16 533:2 535:6 topic 419:20 583:21 627:20 628:5,7 631:22 535:22 536:3 545:3 546:2,7 437:18 treatment 636:6 642:22 546:12 547:13,13 549:19 tops 410:2 412:13,16,16413:5 tubes 551:14,15 552:10,13 548:10 420:20 421:2,16 422:3,13 556:21 557:1 553:12 555:17 556:7,13,13 torch 422:15 424:16,20 425:1,2 turn 558:13,18 559:6,13,19 573:21 432:7 444:3 447:7,13,15,16 427:7 431:20 437:10 560:3,6 561:17 567:3 568:8 torches 465:18471:1,7,10475:5 446:15 448:1 488:8 511:9 568:11 569:12,13 570:2 567:9 479:13 480:1,12 482:21 550:16 560:2 578:9 621:5 571:17 576:21 578:7,12 torn 484:20 485:3 489:3 490:1 639:17 579:13,17 580:3 581:1,6,12 608:13 490:16 491:4,20 494:3,19 turned 582:12 587:2 592:12 597:3 tort 495:4,19 496:1,14,16,22 419:9 426:17 452:3 538:2 598:12 601:13 603:1 604:2 567:17 497:4,7,9 533:18 538:1,4,8 555:9 604:12 606:21 608:15 total 539:5,7,14 578:3 579:7 turning 609:18610:1,5 611:10,10 438:8 580:18,22 581:3,3,10,11 610:9 616:18,22 617:9,12 618:3,5 tower 582:3,14 583:1,3 584:3 twentieth 618:8 619:15,16 620:2,4,8 423:18 491:1 568:11 612:4 588:8 589:4 597:7,15 406:17 622:4 623:17 624:13,16 town 598:14 599:11,14 601:7,13 type 626:1 627:18,20 628:15 510:10 534:13 603:11 611:16612:12 462:7 483:2 488:11,12 630:10,13,15,20 631:4,13 toxic 633:22 500:12 504:3 505:4 528:21 631:16,18 632:13 635:17 438:7,20 439:11,15,18 tree 577:12 580:10 625:22 636:17 639:4 640:8 641:9 538:2 560:22 561:4,5,14 558:3 typed 642:19,21 643:7,13,20,21 614:8,17616:14,20 617:17 trench 425:10 644:1 635:15 636:3,14 641:18 441:1,3,5 460:22 564:11,13 typical times 642:3 643:8 644:9 565:9 572:18,21 573:5 566:18 435:13 441:2 450:6 452:22 toxicity 599:15,17,19,22 600:3,4,10 typically 453:1,14 454:5 456:11 437:12,15 438:1,4,19 614:6 600:11,12 601:3 514:3 472:17 480:13 500:8,14 614:9 636:13 644:4 trickled u 517:4 550:4 605:2 620:3 toxicology 495:12 i illmpr timing 431:14 629:21 tin 500:12 556:11 traces 515:5 tracing trickling 494:20 495:1,3,10 598:12 598:18 triggered 599:2,8,13 unacceptable 429:16 uncommon tiny 574:3,9 474:5 624:6 428:6 title 474:17 505:9 566:16 622:22 today track 509:17 522:17 533:8 546:19 547:6,8 tracks 608:12 609:5 trivial 533:12 trouble 522:11 troublesome underground 587:17616:14,20 617:18 621:17,22 622:3 623:9,10 623:11,13,16,18 624:12,15 624:20,22 625:1 627:13 408:9 483:22 499:2,7 trade 624:10 501:11 511:14520:17 502:7,13,15 534:16 612:21 truck 521:16 551:18,19 572:19 transfer 525:19 547:14 583:10 584:15 588:3,22 484:10 558:18,20 559:10 true 590:2 598:15 600:5 603:20 559:17 567:7,22 619:1 498:5,8 518:8,12 521:14 628:1,10,13,17,20 631:18 631:22 632:5 634:19 635:4 635:10 understand 428:14,15 489:16 501:15 604:18 610:12,20 transferred 569:12 571:15,16,18 575:9 521:11 533:10 536:1 told 424:16 477:13 494:20 544:6 610:5 transporting 575:15 591:2 599:22 602:2 604:20 549:17614:11 understanding tolerable 430:6 tomorrow 587:14 trust trappings 406:3 542:15,20 545:9,15 548:22 try 410:6 439:1 446:6 455:7 458:11,15488:6,14,18 495:1 496:15 504:7 521:12 488:16 top 565:22 trash 442:2 443:20 525:8 570:21 trying 522:19 523:20 570:20 571:5,21 577:20 581:12 435:11 461:6 505:1 528:1,7 549:21 428:15 574:18 601:9 601:19 611:22 622:20 530:8 585:1 592:5,13 629:19 639:12 623:22 634:22 636:2 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMONO010331 [understanding - wastewater] understanding (cont.) urgent ventilating warm 643:11 421:8 423:8 588:10 552:7 612:16613:6 understood usage ventilation warmed 439:5 583:1 642:9 522:17 543:15 551:2 613:7 undertake use version warned 624:18 453:10 456:16,19 465:12 465:21 549:5 446:17 undertaken 518:19 551:19 558:9,20 versus warnings 412:11 415:20 558:21 562:18 571:21 595:16 429:12 504:4 554:11 602:8 447:8 undertaking 601:16 612:9 630:6 636:10 vessel wash 412:6,10 421:5 424:22 useful 419:6 418:1 436:6 445:1,3,13,17 425:20 442:18 484:19 553:8 619:18 vigorously 460:4,10,15611:1 633:9,11 uniformly uses 538:18 633:17,18,19 634:5,9 529:3 538:15 534:15 561:20 Virginia washed union usual 494:19 460:10 611:8 406:27 572:15 502:22 visible washer unique usually 415:7 429:22 430:6 456:15 459:20 518:1 442:1 453:8 498:4 516:22 457:3,6 477:20,21 539:13 washing unit 519:1 613:18 585:17 444:2,6,13,21 445:7,12 426:2,5,6,9 432:15 437:5 467:22 468:4 479:13 480:2 V visit 450:3 550:2 632:16 633:9,10 Washington 496:11 522:21 530:3 583:19 units 426:6 432:2,5,13 485:16 643:15 unnecessarily 481:7 unreacted 417:22 418:14,16,17 445:10 619:17 634:3 unsoluble 454:2 unstable 440:9 570:11,12 unsurmountable 635:3 unusual 410:14 472:15 632:8 upgraded 433:18 upgrading 574:9 uphill 512:20 upper 610:16 upsets 480:5 upside 555:9 upstream 515:9 520:8 538:9 540:7 583:17 urgency 423:7 444:19 477:20 633:22 vaguely visited 424:16 450:4 545:1,2 406:19 waste 556:21 593:21 641:3 valley visiting 455:4 527:11 410:1 412:14,15,21 413:4,5 413:11,22 415:22 416:19 422:4 606:15,19 607:16 608:4,4,10 609:1,8,15 valuable visits 549:18 550:5 visualized 418:16 423:6,9 442:19 444:1,14 445:4 446:2,7,16 446:21 447:7,9,13 448:3,4 452:3 453:2 value 548:7 vitrified 449:4 452:22 459:9 471:1,7 471:9 475:2,4,7 478:11 453:21 423:10,16 478:7 588:4 479:12 480:1,21 481:4,4,8 valve 552:8 vapor 427:8,15,16,22 476:17,19 505:2 volume 405:13 517:20 w wait 542:11 484:20 485:2 489:3,22 490:10,15 491:4,20 492:6 494:3,19 495:11,19 496:14 496:16,17 497:4,7,8 509:10 512:10,14 517:20,22 526:7 vapors walk 528:3 530:1,2 538:8,12,15 429:9 variability 447:12 variable 581:21 417:12 606:8 walked 449:12 walking 450:5 606:7 539:13 577:6,7,12 578:4 579:7 580:18,21 581:2,10 581:14 582:10,14 583:1,3 583:19 584:3 587:2,14 588:8 589:4 594:1 596:5 variety 539:7 various 431:16 439:4 450:6 452:1 452:22 453:14 507:6,19 walls 624:12,16 want 418:1 481:7 506:14615:11 wanted 597:7,14 599:11,14 601:7 601:13603:11 604:19 610:12,16611:15613:12 613:13,21 wastes 539:9 543:18 566:1 584:6,9 483:11 516:15 527:19 412:19413:2 415:2 416:10 614:4 620:7 631:4 velocities 534:17,18 540:17 550:16 552:18 558:5 565:19 419:21 438:9 445:6,18 457:13,20 458:16 464:7,18 528:5 vendor 601:9 566:19 582:7 588:21 594:10 601:18 wanting 464:20,21 465:3 482:22 484:18491:3 508:19517:9 525:15 535:6 578:2 581:15 vent 476:14,20,20,20 477:6 520:13 warehouse 614:3 wastewater 564:5 563:14,18611:13612:19 459:3,16,22 460:3,7,13 613:7 464:16 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMONO010332 [wastewaters - zero] wastewaters we've work (cont.) years (cont.) 460:19 458:4,6 483:17 507:3 443:3 472:2 474:6 510:21 558:13,15 561:6 570:7 water 586:21 599:16 603:19 547:1,11 556:11,21 593:8 582:16 589:8 598:5 608:13 415:6,8 418:1 419:7,8 619:3 625:1 597:12 625:19,20,22 625:2 632:14 644:1 428:7 436:11 441:1,3,5,9 wgk 631:20 638:22 641:8 yellow 444:11,22 445:1,3,13 454:2 615:18 616:7 629:9 643:12,17 645:6 539:13,15,15 605:2 456:1 463:6 465:5 467:4,5 whatsoever worked yellowish 468:15 484:11 496:6 589:19 408:16411:14423:11 604:19 499:13 507:18 512:3 522:9 wheeler 427:22 442:15,22 443:17 yesterday 537:6 557:15 563:4 574:17 594:15,16,21 443:18 447:3 482:7 496:11 410:6418:10441:18 574:18 589:14 599:15,19 whichever 496:16 510:20 561:12,17 483:17 595:22 600:15 609:16 611:1,20,21 608:21 583:2 610:1,2 618:2,8,8 yield 612:4,13 632:18 633:9,11 wide 625:2 628:2 636:10 419:2,4,10 633:17,19 634:1,5,9,10 514:8 561:3 586:17 588:15 worker yields waters width 555:18,22 643:2 644:8 447:5 495:21 waxy 498:19 wildlife workers 561:10,15 595:15 640:22 z 454:1 ways 472:20 473:13 william working 6152 416:1 422:18 424:17 443:5 424:18 453:15,20 547:2,4 640:13 443:7 447:16 462:5 471:19 619:6,18 636:1 Wilmington 472:16 494:11 510:13 wear 405:14 406:5 539:14 596:19 618:6 588:6,14 wind 631:13636:17639:15,18 weather 440:22 445:1 533:13 world 540:7 613:1,4 wish 572:8 weeks 578:10 worth 569:13 wished 522:10 weighed 569:22 wound 522:20 witness 418:16 526:12 weir 407:2 430:15 462:20 write 414:9,10 475:9,10 479:2 468:20 470:1 482:19 480:18 481:21 585:22 538:21 489:18 500:4 505:11,17 writer weirs 529:9 535:2 541:10 543:12 473:8 538:14 566:9,11,12 576:18 578:16 writes welders 578:19,20 583:6,8 586:1,7 479:11 480:11 511:3 591:18 593:13,16,17 596:9 writing welge 596:12,13 599:2,5,6 604:1 479:10 482:1 597:21 609:8 406:8 604:5,6 605:14 609:9 630:1 641:15 wellwater 629:13 640:19 written 612:9 witnesses 434:14 481:22 501:3 642:8 welter 543:9 606:22 wondering X went 444:21 456:10 464:16,19 464:21 465:3,15 500:8,14 489:22 507:20 535:14 544:17 550:22 567:1 573:11 596:15 605:2 6132 4 y 503:5 504:8,9 521:18 wood yard 557:18 565:9 578:4 603:20 597:4,8,10,11 464:13 498:14 610:13,16 613:9 622:9 word yards 633:21 634:4 637:2,16 598:7613:15 607:7 644:12 words year west 476:13 504:4 641:16,21 430:4 529:17 544:6 550:3 422:5 450:21 451:17 work 551:3,5,12,17 629:18 494:19512:20 611:13 408:14411:13413:8 years wet 419:16421:7,10,11 423:1,5 439:11 489:21 503:13 428:4 555:9 575:2,3 588:9 423:7,8 424:22 425:20 510:16512:18514:14 633:12 426:1 431:15 437:15 443:1 522:15 549:17 557:6 Savage, James (Aroclor Dept employee) in AETNA (3) HARTOLDMONO010333