Document VJEqRBpMzokB2eewjG8zKGmVp

In The Matter Of: NEVADA POWER COMPANY VS MONSANTO COMPANY Theodore Lee W hisler Thursday, Septem ber 17, 1992 A ssociated Reporters o f N evada 411 East B onneville Avenue Las Vegas, N V 89101 O 02) 382-8778 Original File WHISLER. VI, 94 Pages Word Index included w ith this Min-U-Scripta NEVADA POWER COMPANY Y&S MONSANTO COMPANY T heodore Lee W hisler T hursday, Septem ber 17, 1992 Page 71 j Page 73 tn th e n u m b er fo r th a t transform er; that num ber isn't [i] mean? 12] going to be assigned to an o th er type o f equipm ent, [21 M R .T A T L O C K : Yes. [3] like a capacitor or capacitor bank? [3] M R . C LA Y S O N : Because looking M A: T h a t's correct. [4] through, m ost of th e num bers do ap p ear to be 15] Q: And th e higher the num ber the m ore [s] consistent. It's just those tw o blaring ones on [6] rec e n t th e purchase date? [6] th e first page. P] A: T h a t's correct. [7] M R . M cC R E A : Yeah. is] Q: Well, take a look a little bit [8] M R . T A TL O C K : Well, I'd prefer to [9j fu rth er dow n on page one, at com pany num ber 513, [9j have either an understanding of w hy the num bers [10] w h ich show s a February 17th, 1954 purchase date. [10] w ere ou t o f sequence like th at o r get a [11] It's approxim ately eight years after com pany num ber pi] clarification o n all of them . [12] 877, w hich was purchased in 1946. Ii?] Q: (BY MR.TATLOCK) Let me just direct [is] A: I d o n 't know how that could be, [i3j your attendon to page five. Seventh transform er [i4] w h e th e r it's a typographical erro r or -- I d o n 't [i4] down, 12/10/50 som ething. Looks like it's been cut iis] know. [is] off in th e copying process. W ould you be able to lie] Q: Well, let's take an o th er exam ple, [16] go back to th e original w arehouse cards and [17] then, a little bit further dow n o n th e page. [17] determ ine w hat th e missing date is? tie] F ourth one from the bottom , com pany num ber 1666, [is] A: Yes. [18] w h ich w as purchased o n Ju n e 23rd, 1948, and com pany [is] M R . M cC R E A : And 1just wanted to [20] n u m b er -- strike that. Excuse m e, right above it, [20] call your attention, th ere are a num ber o f cutoff [21] 994, N ovem ber 30,1950. [21] purchase date entries on page five and th e [22] A: 1 have no explanation for that. [22] succeeding pages as well. So I'd req u est that w e 123] Q: W ho w ould k now w hy th e com pany [23] get a com plete set. [24] num bers and th e purchase dates d o n 't m atch u p the [24] M R . M cC R E A : Off the record. [25] w ay you describe them? [25] M R . C LA Y S O N : Let's go off the Page 72 [1] A: I'm thinking to try to -- [2] M R . M cC R E A : It would be my [3] suggestion, because I think y o u 've pointed o u t an [4] obvious erro r here, that w e see if w e can go back [5] through these docum ents fo r any typographical j [6] errors. It could be as sim ple as a typographical P] error.B ut I agree w ith you, and I think you w ould [8] agree, w o u ld n 't you? [9] T H E W IT N E S S : Yes. [10] M R . M cC R E A : That those should be in [11] sequence. So w hy d o n 't w e m ake th at com m itm ent to [121 see if th ese are typographical errors. In o th er [is] w ords, 513, if th at had a one in it, I'm trying to [i4] think, w ould th at m ake any sense, or maybe if it [is] had a tw o in front of it. [16] T H E W IT N E S S : Or if it was a 4,44 [17] instead o f 54. [is] M R . M cC R E A : Or if there was a 44 [is] instead o f 54. But -- [20] M R .T A T L O C K ; Can you do liiis for die [21] entire list? [22j M R . M cC R E A : Yeah, we'll try and go [231 th ro u g h and just double check at least obvious 124] errors in th e sequence. Maybe w e could even [25] com puterize it by nu m b er an d date. See w h at I Page 74 [t] record. [2] (Discussion o ff the record.) P I Q: (BY MR. TATLOCK) Earlier, W Mr. W hisler, you testified th at Dennis Schw ehr in [5] the environm ental affairs departm ent asked you to [6] prepare this series o f m em os that w e 've identified m as Exhibit A; is th at correct? [bj A: T h a t's correct. [9] Q: W hat inform adon did you use to [10] identify transform ers that are contained in this mi list th a t w e 've m arked as Exhibit A? [121 A: From inform ation w e 'd received from [is] th e safety departm ent. [u] Q: Now, did th e safety departm ent [is] identify these p ardcular pieces o f equipm ent as [16] th e ones th at you w ere supposed to gather li7] inform adon for? [is] A: It w orked in reverse. T hey told us [19] w hich ones w ere disposed of as being PCD [20] contam inated.T hey m onitored d ie w hole program . [21] Q: How did th e safety dep artm en t know [22] th at these w ere PCB transformers? [23j A: O f m y ow n know ledge, I d o n 't know. [24] Q: Did Mr. Fabbi o r Mr. Reddaway ever [25] tell you th at th ese w ere all th e PCB transformers? A ssociated R eporters o f N evada Min-U-Script Page 71 - Page 74