Document YrVnDoqYa1w18oBKrRBxGv8d0

BRUCE LARSON Page 1 1 CAUSE NO. 02-CV-l169 2 EDWARD CARR, ET AL. , 3 PLAINTIFFS, 4 VS . 5 ABLE SUPPLY CO., ET AL., 6 ) IN THE DISTRICT COURT ) ) ) GALVESTON COUNTY, TEXAS ) ) ) 7) DEFENDANTS. ) 10TH JUDICIAL DISTRICT 8) 9 krkrkrkrkrkrkrkrkrkrkrkrkrkr-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k 10 ORAL DEPOSITION OF 11 BRUCE LARSON 12 SEPTEMBER 3, 2004 13 Volume 1 14 krkrkrkrkrkr-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-kkr-k-k-k-k-k 15 16 17 18 ORAL DEPOSITION OF BRUCE LARSON, produced as a witness at 19 the instance of the PLAINTIFF, and duly sworn, was taken in the 20 above-styled and numbered cause on the 3rd of September, 2004, 21 from 10:02 a.m. to 12:46 p.m., before Leanna Lynch, CSR in and 22 for the State of Texas, reported by machine shorthand, at the 23 Intercontinental Stephen F. Austin Hotel, 701 Congress Avenue, 24 Austin, Texas, pursuant to the Texas Rules of Civil Procedure 25 and the provisions stated on the record. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003862 BRUCE LARSON 1 APPEARANCES 2 3 FOR THE PLAINTIFFS: MR. JAKE SKAGGS 4 HEARD, ROBINS, CLOUD, LUBEL & GREENWOOD, L.L.P. 110 W. Southmore 5 Pasadena, Texas 77502 6 FOR THE DEFENDANT: MOBIL 7 MR. CHRISTOPHER P. MANNING DEHAY & ELLISTON, L.L.P. 8 3500 Bank of America Plaza 901 Main Street 9 Dallas, Texas 75202 10 FOR THE DEFENDANT: NOOTER CORPORATION 11 MS. KELLY W. IRVIN BEAN, BEAN & BROTHERS, L.L.P. 12 Two Memorial City Plaza 820 Gessner, Suite 1500 13 Houston, Texas 77024 14 FOR THE DEFENDANT: GARLOCK 15 MR. STEPHEN LEVAY SEGAL McCAMBRIDGE SINGER & MAHONEY 16 100 Congress Avenue, Suite 700 Austin, Texas 78701 17 18 19 20 21 22 23 24 25 Page 2 Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003863 BRUCE LARSON Page 3 1 INDEX PAGE 2 Appearances........................................................................................................................................ 2 3 Stipulations..................................................................................................................................... 4 4 BRUCE LARSON 5 Examination by Mr. Skaggs....................................... 4 Examination by Mr. Manning.................................... Ill 6 7 Signature and Changes........................................................................................................ 115 8 Reporter's Certificate..................................................................................................... 117 9 10 EXHIBITS NO. DESCRIPTION PAGE 11 1 Packet of Information concerning Cause No. 02-CV-1269, 12 Cause No. 02-CV-1169, Cause No. 00CV1111...................................... 113 13 14 15 16 17 18 19 20 21 22 23 24 25 Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003864 BRUCE LARSON Page 4 1 BRUCE LARSON, 2 having been first duly sworn, testified as follows: 3 EXAMINATION 4 BY MR. SKAGGS: 5 MR . SKAGGS: By the rules? 6 MR . MANNING: Yes. 7 Q. Good morning, Mr. Larson. 8 A. Good morning. 9 Q. My name is Jake Skaggs. We have been chitchatting 10 here for about half an hour. I'm the latest attorney that 11 works for the firm of Heard, Robins, Cloud, Lubel & Greenwood. 12 We change names all the time. That's why I can't keep up with 13 it. 14 I represent a plaintiff in the Carr case, which 15 is what you are going to testify about today. 16 Do you understand that? 17 A. Yes, I do. 18 Q. I'm not as skilled as Denman Heard was when he talked 19 to you last time. or as Troy Chandler is, so kind of bear with 20 me. If you don't understand one of my questions, just tell me. 21 Just say. Jake, I don't understand what you are trying to get 22 at, and we'll try to figure out a better way to ask you the 23 question. Okay? 24 A. Okay. 25 Q. Kind of going over some of your previous depositions. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003865 BRUCE LARSON Page 5 1 I think you have given four prior depositions; is that right? 2 A. I think that's correct. Somewhere between three and 3 five, I think. 4 Q. In '96 you told Denman you gave one in Washington 5 dealing with Mobil benzene, asbestos exposure? 6 A. Yes . 7 Q. That was with Hershell Hobson as best you remember? 8 A. Correct. 9 Q. Did you ever give that deposition to Denman or give 10 to your attorneys? 11 MR. MANNING: A copy of it? 12 MR. SKAGGS: Yes. 13 A. I don't know. 14 Q. (BY MR. SKAGGS) And then 2003, you gave one about -15 dealing with Mobil Beaumont. 16 A. I believe that's correct. Back in November, I 17 believe 18 Q. And then around the Super Bowl you gave another one 19 in Houston. You couldn't recall the law firm at that time. 20 Do you recall who that was? 21 A. No, I can't. 22 Q. That testimony dealt with the Mobil facility in 23 Temple, Texas. 24 A. I believe that's correct. That was the Mills case? 25 MR. MANNING: I believe it was the Mills case. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003866 BRUCE LARSON Page 6 1 and the plaintiff lawyer was Russ Close (phonetic) -- their 2 firm. 3 MR. SKAGGS: Did Russ take that deposition? 4 MR. MANNING: No. 5 Q. (BY MR. SKAGGS) Then Denman Heard, from my firm. 6 took a deposition in the Altmore case. I think that was in 7 April of this year; is that right? 8 A. I believe so. 9 Q. Did you testify in the Altmore case? 10 A. I believe I did. 11 Q. That was in Galveston? 12 A. It was in Galveston. That's correct. 13 Q. Did you ever find out the results of the Altmore 14 case? 15 A. No. 16 Q. No one from DeHay or J.D. Bashline's firm told you 17 about who was victorious in that case? 18 A. No. 19 Q. Can you think of any other deposition testimony or 20 trial testimony you have given other than what we have just 21 covered? 22 A. Let's see. Not that I recall. 23 MR. MANNING: Jake, he did testify in the Melvin 24 case down in Beaumont. 25 THE WITNESS: Right. I think I had mentioned Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003867 BRUCE LARSON 1 that before. Page 7 2 Q. (BY MR. SKAGGS) Was that the 2003 case dealing with 3 Provost & Umphrey, the plaintiff attorneys? 4 MR. MANNING: It was 2004, and it was with 5 Provost. 6 Q. (BY MR. SKAGGS) Did you testify live or at trial or 7 was it by deposition? 8 A. I did testify. 9 Q. Do you know what court that was? 10 MR. MANNING: Sanderson's court. 11 Q. (BY MR. SKAGGS) Do you have the Russ Cook 12 deposition, by any chance, the one dealing with Temple -- the 13 Mobil facility in Temple, Texas? 14 A. I don't have it with me. I may have it at home. 15 Q. Is it easy for you to get it if I request it -- copy 16 it and send it to DeHay & Elliston? 17 A. I assume so, yes. 18 Q. My understanding is you have never testified on 19 behalf of plaintiffs in an asbestos-related exposure; is that 20 correct ? 21 A. No, I haven't. 22 Q. Have you ever been asked to? 23 A. No. 24 Q. Then you are currently self-employed as a consultant? 25 A. I am actually retired. I do some consulting Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003868 BRUCE LARSON 1 part-time Page 8 2 Q. About how much consulting do you do? 3 A. It probably works out to be maybe three or four days 4 a month. 5 Q. Who do you do consulting for? 6 A. For Exxon Mobil. 7 Q. Do you still do any for BP Petroleum? 8 A. I never have. 9 Q. I must have misread that somewhere. So you solely 10 provide service to Exxon Mobil? 11 A. Yes . 12 Q. Is that purely for litigation purposes? 13 A. It is basically for anything they ask, but it has 14 been for litigation, yes. 15 Q. Anything they have asked you, not dealing with 16 litigation? 17 A. Well, I think the vast majority has been related in 18 some way to litigation. 19 Q. Is that primarily asbestos litigation? 20 A. Primarily asbestos, a couple of issues have come up 21 involving benzene, but I don't think I have ever actually ever 22 testified about benzene. 23 Q. Would you be the type of consultant Exxon Mobil would 24 come to when they are building a new facility in, say, LaMond 25 and ask you your opinion? Is that the type of work they would Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003869 BRUCE LARSON 1 have you do? Page 9 2 A. I could. They haven't asked me to. 3 Q. Do you still charge Exxon Mobil $300 an hour for your 4 services ? 5 A. Correct. 6 Q. That hasn't increased or decreased lately? 7 A. No. 8 Q. How much have you made for your consulting services 9 this year ? 10 A. I am not sure, but if you take the number of days per 11 month that I gave you and do the math, we could come up with a 12 figure. 13 Q. Do you have an estimate for 2003? That's a full 14 year . 15 A. 2003, I do know that because I had to file it for my 16 income tax. I think it came out like $36,000. 17 Q. We are in beautiful Austin, Texas today, but where do 18 you live. sir? 19 A. I live in Edinburgh, Virginia. 20 Q. You've got a small farm up there? 21 A. Yes . 22 Q. My grandfather told me there is no such thing as a 23 small farm. 24 A. That's true, absolutely. 25 Q. I want to thank you for coming down to Austin and Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003870 BRUCE LARSON Page 10 1 meeting us and hopefully we can come up to your home there in 2 Virginia and talk to you some other time. 3 A. Fine . 4 Q. Are you married, sir? 5 A. Yes . 6 Q. Do you have children? 7 A. I have a daughter. 8 Q. She is a lawyer in New York, right? 9 A. Yes . 10 Q. You must be proud. 11 A. Yeah. 12 Q. My understanding is that you were born and raised in 13 Houston? 14 A. Correct. 15 Q. Where did you go to school in Houston? 16 A. High school went to Spring Branch High School. 17 Q. And then you later on attended UT Austin; is that 18 correct ? 19 A. One year at Austin College, then finished up at the 20 University of Texas at Austin. 21 Q. And received a Bachelor of Science in natural science 22 at UT Austin? 23 A. That's right. 24 Q. What is it that the discipline in natural sciences 25 encompass ? Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003871 BRUCE LARSON Page 11 1 A. It is life science. Most people would simplify it by 2 calling it biology. It is basically things like zoology. 3 chemistry, physics, that type of thing. 4 Q. Would the types of courses that you took be a sample 5 of all the different science discipline? 6 A. I would say so, generally. 7 Q. Meteorology, pharmacology, zoology, that type of 8 thing? 9 A. That type of thing, uh-huh. 10 Q. Any specific course work that you took when you were 11 getting a degree in natural sciences that you recall? 12 A. I can give you a list of -- evolutionary ecology. 13 human anatomy, genetics, inorganic chemistry, organic 14 chemistry, biochemistry, botany. 15 Q. Was there any specific area that you took more 16 classes of than another area or did you sample it all? 17 A. I'd say it was a general course of study. I did 18 begin in chemical engineering, so I consider myself having a 19 minor in that. I was in engineering for a couple of years and 20 switched to biology. 21 Q. When you say that you consider you have a minor, do 22 you have a minor in chemical engineering from UT Austin? 23 A. Not officially. It's just that I have some of the 24 basic course work. 25 Q. Some of the basic math- and calculus-type classes? Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003872 BRUCE LARSON 1 A. Calculus and that type of thing. Page 12 2 Q. Any reason why you switched out of chemical 3 engineering into natural sciences? 4 A. I wanted to work for either EPA or OSHA. The 5 legislation for both those was enacted in 1970, and I felt that 6 that course work would help me prepare for that. 7 Q. I read that you told them that you had an interest in 8 OSHA at that time. Any particular reason why OSHA interested 9 you? 10 A. It involved industrial hygiene, in particular 11 involved a lot of the areas that I had an interest in -- human 12 health. that type of thing, and it just seemed like -- I feel 13 it was really starting to open up and that it would provide a 14 good career for me. 15 Q. You graduated in 1972, correct? 16 A. Correct. 17 Q. At that time, were you informed of any classes about 18 OSHA's emergency standards dealing with asbestos? 19 A. I believe I recall something about that. 20 Q. Could you tell us what you recall? 21 A. Actually, most of that I learned later when I was in 22 graduate school, but I think I just read in the paper at some 23 point. 24 Q. Where did you do your post graduate work at? 25 A. Still with the University of Texas but it was at Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003873 BRUCE LARSON 1 their school of public health in Houston. Page 13 2 Q. How long did that take? 3 A. I think it took about two and a half years. I think 4 I graduated in '76. 5 Q. You received your master's degree in public health? 6 A. Correct. 7 Q. Can you give me a sampling of some of the course 8 work -- I apologize. I'm a finance major and I don't really 9 know much about sciences. 10 A. First of all, I can tell you that my professor was 11 Marcus Key, who was the original director of NIOSH. And after 12 he retired from NIOSH, he was employed as a professor at the 13 University of Texas school of public health. A lot of what we 14 studied involved things like biometry, which is statistics; 15 epidemiology, which is the study of the currents of disease in 16 a population of humans; industrial hygiene, which is the 17 evaluation and control of potential occupational health 18 hazards; health physics, which is the study of radiation and 19 its potential affects on human beings and how to control that. 20 I'm sure there is others, but I don't recall right off the top 21 of my head -- ventilation. 22 Q. Let me ask you about those industrial hygiene 23 classes. Those dealt with all sorts of hazardous substances - 24 the controlling and monitoring of all sorts of hazardous 25 substances, right? Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003874 BRUCE LARSON 1 A. Correct. Page 14 2 Q. Not merely just dust, but we're talking chemical -- 3 benzene. that type of thing? 4 A. Vapors, noise, radiation. The entire range of 5 potential occupation health hazards. 6 Q. Was there any specific classes that you took dealing 7 with industrial hygiene that dealt with dust or the hazards of 8 dust ? 9 A. I wouldn't say specifically. It did deal with dust. 10 obviously . But again, it dealt with other things like vapors. 11 and so forth, but there was not a specific course in dust, per 12 se. 13 Q. When you -- let me jump back a little bit. And I 14 believe you were a research biochemist at M.D. Anderson? 15 A. Yes, before I did go to work for OSHA. 16 Q. That was the time that Nixon had his hiring freeze as 17 you stated, so that's why you had to go to work for M.D. 18 Anderson? 19 A. Right. 20 Q. Tell me what you did as a research biochemist. 21 A. I worked for PhD researcher there that did basic 22 research on cancer. His name was Dr. Hurlbert, 23 H-U-R-L-B -E-R-T, and they were studying the metabolism of how 24 RNA and DNA were formed, which were the nucleic acids, and I 25 was basically a research biochemist that was assisting him in Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003875 BRUCE LARSON Page 15 1 doing his research at his direction, and what this -- as I 2 recall, we used radio labeled molecules that we injected into 3 livers of experimental rats and were able to follow how these 4 radioactive molecules were metabolized within the liver, and 5 that was to help us try to understand how it would also occur 6 in human beings. 7 Q. Was this study published? 8 A. I know his were published. I didn't personally 9 publish any papers. I was there for only about a year. 10 Q. Your job duties was limited to this studies of the 11 radio isotopes that you injected into rats and things like 12 that? 13 A. For the most part. 14 Q. Any studies about mesothelioma at M.D. Anderson? 15 A. No. 16 Q. Did that discussion ever come up when you were there 17 at M.D. Anderson? 18 A. I don't recall that it did. 19 Q. Then you finally succeeded in your college dream and 20 you went to go work for OSHA; is that right? 21 A. Correct. 22 Q. Can you just kind of educate me on what an industrial 23 hygienist or what you consider an industrial hygienist is? 24 A. Industrial hygiene is, again, involved in protecting 25 employees from occupational health hazards. And again, that is Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003876 BRUCE LARSON Page 16 1 a very broad spectrum of possible risk factors. It can involve 2 noise exposure, exposure to radiation, exposure to temperature 3 extremes. In some cases even exposure to biological agents, 4 exposure to chemicals, whether it be gases or vapors, exposures 5 to dust and other particulates, i.e., asbestos or silica. 6 I think that covers most of the potential 7 hazards. And it is basically the recognition, the evaluation 8 and control of any of those factors. 9 Q. When you went to go work for OSHA, they didn't hire 10 an industrial hygienist, you were a compliance officer; is that 11 right? 12 A. They did hire industrial hygienists, but my title was 13 actually compliance safety and health officer. All their 14 employees that do compliance work have that title, but then 15 they have a specialty that is either being typically a safety 16 engineer or an industrial hygienist. 17 Q. And you worked for OSHA between 1973 and 1976; is 18 that right? 19 A. Correct. 20 Q. Tell me which area was your -- 21 A. It was -- well, geographically I worked in the 22 Houston area office of OSHA, and we had responsibility at that 23 time probably for about a third of Texas. Our territory 24 extended over to the golden triangle -- Beaumont, Port Arthur, 25 down to Corpus Christi, and then up to Austin. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003877 BRUCE LARSON Page 17 1 Q. When I read your last deposition you told me the 2 Houston ship channel -- Houston Metro, the facilities located 3 there -- like Nabisco or somebody like that -- Golden Triangle, 4 Austin - - how about Texas City, did you work down there? 5 A. Correct. 6 Q. How about Freeport? 7 A. Yes . 8 Q. And also down to Corpus Christi? 9 A. Correct. 10 Q. Part of your job was to visit these facilities in 11 these different cities? 12 A. Yes . 13 Q. Some petrochemical facilities? 14 A. Right. The entire broad mix of industry went 15 anywhere from bakeries to refineries to -- 16 Q. Steel mills? 17 A. Steel mills, even one case a discotheque. 18 Q. That gets me into this area. I believe you stated 19 there were four types of inspections that you performed at 20 OSHA. One was for complaints; second, fatalities; third. 21 generally scheduled inspections; and lastly, the special 22 emphasis inspections. Does that cover the type of inspections? 23 A. Yes . 24 Q. Those are the labels that you guys put on it? 25 A. Yes . Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003878 BRUCE LARSON 1 Q. What is a special emphasis inspection? Page 18 2 A. I think I mentioned it was the target health hazards 3 program. THHP. OSHA established that to go out and look at 4 hazards that were considered to be fairly widespread that they 5 felt between the potential degree of the hazards and the number 6 of employees that were exposed, that by targeting those 7 particular exposures, we'd be more effective with our 8 compliance resources. That involved things like asbestos. 9 silica. lead and cotton dust. 10 Q. Out of those four particulates -- 11 A. I think noise was the other one. 12 Q. Oh, noise. 13 A. Yeah, I don't think I included that before, but I 14 believe it was. 15 Q. Then I'll strike my question. Because noise isn't a 16 particulate. 17 Out of those categories, was there special 18 emphasis put on any particular one more than the other? 19 A. No. 20 Q. Now, at that time, I guess OSHA had an appreciation 21 that a majority of people were exposed to asbestos, cotton. 22 silica. lead and noise; is that right? 23 A. Repeat that question. 24 Q. Yeah. That was probably a bad question. 25 You told me the special emphasis program was Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003879 BRUCE LARSON Page 19 1 created because at that time OSHA appreciated that there were a 2 certain amount of people exposed to these types of matters as 3 well as noise pollution; is that right? 4 A. I'd say that's generally correct, yes. 5 Q. It was such of a concern that they had to create a 6 special program for it, right? 7 A. I don't know if I would put it quite that way, but 8 yes, they felt that it was important that exposures be 9 controlled to those materials, and there were regulations that 10 were in place for those materials, so that was one of our 11 priorities to make sure that employers were meeting those 12 regulations as it related to those materials. 13 Q. Sometimes I hear some opinions -- I'm not saying that 14 it's yours -- is that not many people are exposed to asbestos. 15 Have you ever heard any opinions about that, of that nature? 16 MR. MANNING: Objection; form. 17 A. I don't think I would say not many people. I'm not 18 quite sure what that means, but I don't think I would agree 19 with it. And it depends on what period of time you are 20 speaking of also. 21 Q. (BY MR. SKAGGS) Was there ever a complaint filed 22 against the Mobil facility in Beaumont when you were at OSHA? 23 A. Not that I'm aware of. 24 Q. Did you ever perform any special emphasis studies or 25 investigations out at the Beaumont facility in Beaumont? Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003880 BRUCE LARSON 1 A. No. Page 20 2 Q. Why not? 3 A. There were never -- there never was -- that I'm aware 4 of -- was a complaint ever filed while I was at OSHA -- and 5 because of the territory that we had to cover, basically at 6 that time there were only two industrial hygienists that 7 covered that entire area. The likelihood of us being in any 8 particular facility that -- where we didn't receive a complaint 9 was fairly low. You generally took, at that time, two to three 10 years for us to get around to each facility in our area of 11 coverage. Eventually we did get to virtually every facility, 12 but it did take some time. 13 Q. Let me ask you this: Did it require a complaint to 14 institute a special emphasis investigation? 15 A. No. 16 Q. That was just something that was regularly scheduled? 17 A. I didn't understand that. 18 Q. Maybe you should explain to me. How did you go about 19 performing that? 20 A. When we did the special emphasis of the target health 21 hazardous program, we went primarily to people that were 22 directly involved in using those substances. For example, for 23 asbestos, we would go to people that were actually using 24 asbestos in a manufacturing process, and I think I might have 25 included this in my prior deposition. We went to a company Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003881 BRUCE LARSON Page 21 1 called Stanco that made the brake locks for the oil rigs. We 2 felt that the potential for exposure for that type of 3 establishment would have been probably the highest to people 4 that were actually handling asbestos fibers in their process. 5 So those were our first priority in doing our inspections. 6 Q. At that time, did you feel that employees or working 7 gentlemen at petro chemical facilities were or had a potential 8 for exposure to asbestos? 9 A. Yes. 10 Q. It just wasn't in your words a priority compared to a 11 company like Stanco? 12 MR. MANNING: Objection; form. 13 A. We knew that people that worked in a manufacturing 14 process handling asbestos were exposed virtually during their 15 full work shift, and so we felt that we needed to take a look 16 at the people that we knew were at highest potential exposure, 17 so we concentrated our resources on that type of operation. 18 Q. (BY MR. SKAGGS) You listed Stanco, what other types 19 of facilities had the highest priority while you at -- 20 A. Vinyl tile manufacturing, GAF, for example -21 Q. That was in Texas City; is that correct? 22 A. That was in Houston. 23 Q. Houston. 2 4 A. That was our primary priority. People that we knew 25 were actually handling asbestos as a raw material. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003882 BRUCE LARSON Page 22 1 Q. Do you know of ever a special emphasis investigation. 2 although not performed by you, somebody else at OSHA at the 3 Beaumont Mobil facility? 4 A. Not that I'm aware of. 5 Q. In 1976 OSHA opened up a regional office in Beaumont? 6 A. They have a field office there, yes. 7 Q. Can you name me any of those officers that worked out 8 there in 1976? 9 A. Harold Davis. Let's see, there was another fellow 10 that worked with him, but I don't recall his name. 11 Q. Harold Davis is also an industrial hygienist? 12 A. No, safety. 13 Q. He was working there in '76? 14 A. Correct. 15 Q. Do you know where Harold is these days? 16 A. I don't know. I know he lived in the Beaumont area. 17 but I haven't been in contact with him recently. 18 Q. Then you left the government work and went to private 19 sector? 20 A. Correct, yes. 21 Q. You went to go work for Exxon Chemicals? 22 A. That's correct. 23 Q. Why did you leave your dream and go to work for the 24 private sector? 25 A. Well, I was in an organization in Houston area -- the Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003883 BRUCE LARSON Page 23 1 greater Houston Industrial Hygiene Counsel -- and had an 2 opportunity to meet with some of the local professional 3 industrial hygienist, and I was able to see what type of level 4 of professionalism that some of the various companies in the 5 Houston area displayed, and I got to know a lot of people that 6 worked for some of the corporations, and I was particularly 7 impressed with Exxon's program and the level of expertise that 8 they had. And I felt it would be a way to advance my career by 9 going to work for an organization like that. 10 Q. What about Exxon's program piqued your interest or 11 made you appreciate it? 12 A. The fact that they seemed to place employee health as 13 a priority and they backed that up with good programs and with 14 good people. 15 Q. Did you meet other industrial hygienists from other 16 facilities in the greater Houston area? 17 A. Yes. 18 Q. At that time did you think that Exxon had a better 19 program than the other facilities in the greater Houston area? 20 A. No, I just thought they had a good program. For 21 example, during that same period, I met people with Mobil, I 22 was impressed with them, DuPont, Dow, I thought all those 23 companies had excellent program. 24 Q. How about Stanco, were you impressed with them? 25 A. I was actually -- after I made my inspection, I was Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003884 BRUCE LARSON 1 impressed with the efforts they made to comply. Page 24 2 Q. Did you ever hear that the plant manager at Stanco 3 died from mesothelioma? 4 A. No, but quite frankly, I'm not really surprised. 5 Q. What was your position when you went to your 6 employment with Exxon Chemical? 7 A. My position was initially an industrial hygienist for 8 Exxon, and I eventually -- for one facility, and that was 9 eventually expanded to include three plants. 10 Q. What first was the one facility that you worked at? 11 A. The Houston chemical plant. 12 Q. That's on the ship channel? 13 A. On the ship channel. 14 Q. That is not there any longer, is it? 15 A. It was either sold or shut down, I think. 16 Q. What did it expand to? What three facilities? 17 A. It expanded to the Bayport high temperature film 18 plant in Bayport, and the Baytown's Olefins plant in Baytown. 19 Q. A lot of Bays in that, I know. 20 A. Right. 21 Q. You are one of probably many industrial hygienists 22 employed by Exxon at that time? 23 A. Yes . 24 Q. How many? 25 A. Well, it depends on how you look at it. Are you Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003885 BRUCE LARSON 1 talking about in the U.S. only or worldwide? Page 25 2 Q. No. In those three facilities or just at that one 3 Houston chemical facility? 4 A. I was the only one. 5 Q. How about for the three facilities? 6 A. I was the only one. 7 Q. What were your job duties since you were the only 8 industrial hygienist for this company? 9 A. Well, it depended. For example, the Baytown's 10 Olefins plant was in the designing stage at the time I was at 11 Exxon. So I was helping the engineers some come up with 12 industrial hygiene controls and the design itself to minimize 13 employee exposures to the various products and raw materials 14 that were to be involved in that process. 15 At the Houston chemical plant, which was already 16 in operation, I was involved in air sampling, noise exposure 17 monitoring, setting up medical surveillance programs for 18 chemicals that were being handled at that site, employee 19 training, record keeping, and OSHA compliance. 20 Q. When you say "employee training," you mean Exxon 21 employees specific? 22 A. No, both employees and contractors. We assisted the 23 contractors. I didn't physically do one-on-one training of 24 contractors, but we worked with the contract employer. 25 Q. Is that Floor Daniels that was building that Exxon Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003886 BRUCE LARSON 1 Olefins unit ? Page 26 2 A. I don't actually recall. I think it could have been. 3 Q. When you were working for Exxon at this time starting 4 in -- I think you said July of '76 -- you were limited to the 5 Houston chemical facility, the Bayport facility, or the 6 brand-new Olefins facility; is that right? 7 A. When you say "limited," in terms of what my direct 8 area of responsibility? 9 Q. That's correct. 10 A. I would agree with that, although I spent time at 11 other Exxon facilities during my orientation so I was familiar 12 with their approach in their programs in general. 13 Q. What other facilities? 14 A. The Baytown refinery, the Baton Rouge refinery. and 15 the Bayway refinery. 16 Q. Excuse me. I didn't hear that last one. 17 A. Bayway. It's the New Jersey... 18 Q. Not the love canal refinery, was it? 19 A. No. 20 Q. From there you moved on and started working for 21 Mobil? 22 A. Later on, yes. I believe that was 1978. 23 Q. I'm interested in Mobil today. I just wanted to get 24 a little background with Exxon. 25 Now, let's talk about your employment with Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003887 BRUCE LARSON 1 Mobil. Okay? Page 27 2 A. Okay. 3 Q. What I read before -- you started working for Mobil 4 Chemical facility in Houston; however, you were located at the 5 Greenway Plaza facility. 6 A. That's correct. 7 Q. And that employment lasted from 1978 to 1981? 8 A. Actually, I was with Mobil -- that particular job. 9 Q. That particular job? 10 A. Job, right. Yes, that's correct. And I was a 11 regional industrial hygienist. 12 Q. And regional meant that you were responsible for 13 everything west of the Mississippi; is that right? 14 A. Correct. 15 Q. I'm using your words from the last deposition. 16 A. Right, right. 17 Q. That was what you approximated to be 18 facilities? 18 A. Correct. 19 Q. Your CV lists 14. Is it 18 or 14? 20 A. It could be 14. It could be 18. I'm just 21 estimating. It depends on what you call facilities. Some 22 there were -- there was a polyethylene plant next to a 23 polystyrene plant. Some people would consider that one 24 facility ; some would consider it two. So it depended on how 25 you -- Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003888 BRUCE LARSON Page 28 1 Q. Many of my clients have the same difficulty. DeHay 2 and Elliston seems to just ask a whole bunch of questions about 3 that, too. 4 A. Okay. 5 MR. MANNING: Objection; form. 6 Q. (BY MR. SKAGGS) What does regional responsibilities 7 mean? 8 A. It means that I was responsible for the facilities in 9 my particular region. In other words, anything west of the 10 Mississippi. There was another industrial hygienist that had 11 responsibilities for all the facilities east of the 12 Mississippi. And I would work with personnel at each of those 13 facilities to make sure they had industrial hygiene programs in 14 place that were appropriate for their operation. 15 In each facility we had at least one, what we 16 called "industrial hygiene monitor," which was either a safety 17 professional or it could be a chemist out of the quality 18 control lab for that facility that had been to a one-week 19 certification training program in which they were taught the 20 basic fundamentals of industrial hygiene and how to collect 21 exposure measurements to determine compliance with occupational 22 health standards. 23 Q. Is one week sufficient to train a person in all that? 24 A. We would also spend time after that one-on-one with 25 them at their facility setting up a program and working with Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003889 BRUCE LARSON Page 29 1 them directly to make sure they understood their work, plus at 2 the end of that training course they were required to take an 3 exam and pass that exam. If they did not pass the exam, they 4 would have to retake the program. 5 Q. So you were responsible for each one of these -- was 6 there a corporate term for these gentlemen? 7 A. Certified industrial hygiene monitor. 8 Q. And they would be the ones that actually would go 9 collect samples of the particular matter that was in the air? 10 A. The routine samples. That's how we extended the 11 industrial hygiene resources. We obviously couldn't be on site 12 at all 14 or 18 plants, so we had these people that were there 13 that could handle the day-to-day measurements and training, and 14 then we would advise them -- I would advise them, say, for my 15 office at Greenway Plaza. 16 Q. Did all of those reports get followed up to you from 17 each one of those facilities dealing with the -- 18 A. Things like air sampling or noise monitoring, yes. 19 The results would be supplied to us. 20 Q. If you exceeded the TLV at the time at any one of 21 those facilities, would that be reported to you? 22 A. Yes. 23 Q. Did that ever happen? 24 A. Not that I recall. 25 Q. Do you know if Mobil still has those documents that Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003890 BRUCE LARSON 1 you reviewed during this '78 to '81 period? Page 30 2 A. I think probably, yes. I think they probably do. 3 Q. Do you know where they were kept when you were there? 4 A. They were kept -- I think we went into this -- the 5 hard copy was kept at each facility, and then I would have 6 retained a copy in my office in Houston. And in turn, that 7 data was entered into a computer system and it could be 8 accessed that way as well. 9 Q. A database? 10 A. Yes . 11 Q. Kind of like a keyword database? 12 A. Similar. 13 Q. Can you just -- in 18 facilities -- a lot of 14 facilities -- can you tell me some of the facilities that you 15 were responsible for? 16 A. Okay. At that time we had three facilities in 17 Beaumont. The Beaumont Olefins and Aromatics plant. 18 Q. That's also known as Mobil Chemical. 19 A. Yes. Mobil Chemical Olefins and Aromatics plant. We 20 had a polyethylene facility and we had what we call a chemical 21 specialties plant that made Mobil One. And those were three 22 facilities there. 23 We had plants in Temple. We had a polystyrene 24 and polyethylene plant there. We had a plant in Bakersfield, 25 California; a plant in Woodland, California; a plant in Santa Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003891 BRUCE LARSON Page 31 1 Anna, California; a plant in Shawnee, Oklahoma; and a plant in 2 Juliet, Illinois; and there were probably several others that I 3 can't recall. 4 Q. In the three years that you were in this position, 5 did you visit every one of these plants? 6 A. Yes. I take that back. The one I don't think I 7 visited was Woodland, California 8 Q. You went to Bakersfield instead of Woodland, that was 9 a mistake. 10 Any one particular plant that needed more of 11 your attention than any other one? 12 A. Yes, I would say primarily the one that required the 13 most attention would have been the Beaumont Olefins and 14 Aromatics plant from the nature of its operation. 15 Q. What about its operation that required more 16 attention? 17 A. One of the products -- well, actually there were two 18 products that we were primarily concerned about and one was 19 benzene, the other was one-three butadiene, B-U-T-A-D-I-E-N-E. 20 So of all the facilities, I would say that one probably took up 21 more of my time and effort. 22 Q. These are both known carcinogenics; is that right? 23 A. I would agree with that, yes. 24 Q. You told me beforehand between '78 and'81 that these 25 18 facilities that you are responsible for, you don't recall at Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003892 BRUCE LARSON Page 32 1 any time that asbestos exposure exceeding the TLV at the time? 2 A. From all the data I saw in my time with Mobil 3 Chemical, I didn't see any exposure monitoring data for either 4 employees or contractors that exceeded the exposure limit at 5 that time 6 Q. What was the dust monitoring program established 7 between '78 and '81 for these facilities? 8 A. I'm sorry? 9 Q. What was the dust monitoring program that you guys 10 had established between '78 and '81 for these facilities? How 11 often and where was it taking place? 12 A. Well, we tried to get a baseline on employee groups 13 that had potential exposure to asbestos. We tried to get 14 initial monitoring and then we tried to get additional samples 15 at least every year or two. 16 Q. Was more of your concern at this time dealing with 17 maintenance and shutdowns -- strike that. 18 Do you know what I mean by maintenance or 19 shutdowns in a plant? 20 A. Well, maintenance is one activity; shutdown is a 21 distinctly different -22 Q. What is a shutdown? 23 A. Shutdown would be when a particular unit within a 24 plant is basically refurbished, and that generally occurs on a 25 two- to three-year basis and lasts from a week to three weeks. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003893 BRUCE LARSON 1 Q. And maintenance would be - Page 33 2 A. Maintenance is just ongoing preventative maintenance. 3 Q. Between '78 to '81 would your concern dealing with 4 asbestos exposure be primarily toward maintenance and shutdown 5 rather than new construction projects? 6 A. I wouldn't say one was of any more priority over 7 another. We tried to monitor all three activities, basically. 8 Q. Where I'm coming from, is obviously between '78 and 9 '81 any new thermal insulation -- strike that -- let me start 10 over. 11 Between '78 and '81 any new thermal insulation 12 was asbestos free, presumably? 13 A. I'd say that's correct. We had a program in place to 14 make sure that any new insulation was asbestos free, yes. 15 Q. However, any kind of maintenance or shutdown work -- 16 two separate activities -- there is potential for asbestos 17 exposure to old thermal pipe insulation; is that right? 18 MR. MANNING: Objection; form. 19 A. There could be a potential, yes. 20 Q. (BY MR. SKAGGS) If an insulator that you have hired 21 is removing old pipe insulation that contains asbestos, he is 22 being exposed to asbestos between '78 and '81? 23 A. I wouldn't agree with that, no. 24 Q. Why wouldn't you agree with that? 25 A. Because we had programs in place to essentially Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003894 BRUCE LARSON 1 eliminate exposure. Page 34 2 Q. What were those programs? 3 A. There were engineering and administrative controls. 4 and in addition to that, there were personal protective 5 equipment programs in place. 6 Q. What kind of personal protective equipment? 7 A. Respiratory protection. 8 Q. How about wetting down the area? 9 A. That would have been part of the administrative and 10 engineering controls to minimize exposure. That as well as 11 isolation 12 Q. What type of isolation programs did you do between 13 this time? 14 A. Well, as specified -- well, even prior to OSHA, Mobil 15 had a program in place, but certainly after OSHA, we would have 16 followed the requirements of the asbestos regulations that were 17 in effect at the time which required tape and signs that would 18 prevent unauthorized personnel from entering an area where 19 asbestos was being handled -- and I'm sorry. What else did you 20 want to know? 21 Q. That's what I wanted to know. 22 A. Okay. 23 Q. This would occur, by your testimony and your belief. 24 at the Mobil facilities in Beaumont, right? 25 A. It would have happened at any Mobil facility where Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003895 BRUCE LARSON 1 asbestos was being handled. Page 35 2 Q. Is there a Mobil facility in a place called Johnson 3 Bayou, Louisiana? 4 A. I read that in a deposition, and I'm not familiar 5 with it. I'm not saying that at one time there may not have 6 been, but I'm not familiar with the facility there. If there 7 was, I would suspect it was probably a gas plant, but I'm not 8 familiar with that particular facility. 9 Q. Then you wouldn't be responsible for gas plants? 10 A. Not in the '78 to '81 time frame. Later on in my 11 Mobil career, I was manager of industrial hygiene. So in that 12 sense, I would have had some direct or indirect responsibility 13 for Mobil facilities. 14 Q. If it is a gas plant -- and I don't know -- what's 15 the difference in a gas plant and a refining facility? 16 A. Actually, a gas plant is typically about -- I don't 17 know -- I'd say probably -- just relative terms -- probably 18 about a tenth of the size of a refinery, products are entirely 19 different. Gas plant basically processes natural gas from the 20 wellhead to make it usable as a fuel, whereas, of course, a 21 refinery primarily makes gasoline products, lube oil, that type 22 of thing. It is a much less complex and smaller facility than 23 a refinery, and it typically handles products that are 24 cryogenic. In other words, very cold as compared to hot 25 streams. And when you apply that to the types of insulation. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003896 BRUCE LARSON 1 say, that would be involved, you would find very little Page 36 2 asbestos -containing insulation at a gas plant as compared to a 3 refinery 4 Q. We just don't know what this is in Johnson Bayou? 5 A. No. 6 Q. It could be a booster station for all we know? 7 A. Could be. 8 Q. So you weren't necessarily responsible for all the 9 facilities west of the Mississippi, just the big industrial 10 refineries and chemical plants? 11 A. Well, it depends on what time during my career. 12 During the '78 to '81, no, it was chemical west of the 13 Mississippi. Later on, I became supervisor of industrial 14 hygiene for Mobile chemical, and I had some responsibility for 15 all our facilities. And then later as part of Mobil, I had 16 responsibilities for everything, basically. 17 Q. And I was just thinking of just '78 to '81 right now. 18 That's the way I think right now. Sorry about that. 19 A. Okay. 20 Q. So we don't know what was going on in Johnson Bayou, 21 and you can't provide any testimony that there wasn't asbestos 22 or there was asbestos at Johnson Bayou? 23 A. I agree. 24 Q. To quote you in your last deposition that you did 25 between '78 and '81, you did quite a bit of field work? Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003897 BRUCE LARSON 1 A. Right. Page 37 2 Q. You told me you went to every one of these 3 facilities . How often were you out in the field? 4 A. I'd say I was in the field probably 60 to 80 percent 5 of my time 6 Q. That's quite a bit of time away from your family? 7 A. Yes, it is. 8 Q. Was there a regular schedule or was there -- strike 9 that. 10 Did you have a regular schedule to visit all 11 these plants? 12 A. We tried to get to our facilities at least once every 13 two to three years. 14 Q. Who did you meet when you went to each facility? 15 A. We'd meet with the full-time safety supervisor and 16 the certified industrial hygiene monitors. 17 Q. Who was the safety supervisor at Mobil at this time 18 period in Beaumont ? 19 A. Well, there is several, but at the Olefins Aromatics 20 plant, it would have been, D.A. Bruce -- Dennis Bruce. 21 Q. He's still working for Mobil, isn't he? 22 A. I don't think so. I think he is retired. 23 Q. Who is the certified -- 24 A. Industrial hygiene monitor? 25 Q. Yes, sir. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003898 BRUCE LARSON Page 38 1 A. Roscoe Compton, and then there was also another 2 gentleman by the name of Glenn Sanders. 3 Q. 4 know? Is Mr. Compton or Mr. Sanderson still alive, do you 5 A. I would assume so, but I don't know. 6 Q. Were these gentlemen that were operators before they 7 became certified industrial hygienists or what position did 8 they have before -- 9 A. No, they were both in the safety department. 10 Q. Let's talk a little bit about the Mobil Beaumont 11 facility. My understanding is I thought there were only two 12 facilities out there, but you told me there was three 13 facilities out there. 14 A. Three, and at one time there was fourth, actually. 15 Q. Correct me if I'm wrong, there is an oil refinery out 16 there ? 17 A. Correct. 18 Q. Next door to it is the chemical? 19 A. Next door to it are two of the three chemical plants. 20 There is a third polyethylene plant out on Highway 90. 21 Q. When was that facility built on Highway 90? 22 A. I believe it was built -- originally built in about 23 1974 . 24 Q. How about the oil refinery, when was that built? 25 A. That dates back to at least the 1930s. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003899 BRUCE LARSON 1 Q. About how the aromatics -- Page 39 2 A. Olefins Aromatics? That was built in 1960. I 3 believe it actually began operation in 1961. 4 Q. And the other side of the chemical, when was that 5 one? 6 A. The chemical specialties plant. It was actually part 7 of the refinery before Mobil Chemical was formed in 1960 so it 8 was probably -- I can't tell you. 9 Q. How is the aromatics and the oil refinery separated? 10 A. Basically by a fence. 11 Q. Chain-link fence? 12 A. But they have pipelines that interconnect it. 13 Q. You have to take off certain by-products from the 14 gasoline process to make the aromatics -- 15 A. Right, uh-huh. 16 Q. Aromatics and what else would produce a chemical -- 17 A. Olefins, which is like ethylene and propylene. 18 Q. How about the refinery? What's produced there? 19 A. Broad mix of products. Anything from solvents and 20 gasoline to lube oil to asphalt, petroleum, ether. 21 Q. The refinery sounds like it was a bigger square 22 footage or square miles than the -- 23 A. Certainly, yeah. 24 Q. Can you give me an estimate how big the refinery was? 25 A. It is hard to -- very big. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003900 BRUCE LARSON Page 40 1 Q. Okay. I understand. Proportionately to the chemical 2 site, can you give me a proportion? 3 A. I would say it was larger by a factor of, say, 7 to 4 1. 5 Q. Do you know who built the refinery? 6 A. I don't. 7 Q. Army Corps of Engineers or something like that? 8 A. I have no idea. 9 Q. How about the Olefins Aromatic unit? 10 A. I don't recall. I think I probably knew at one time. 11 but I don' t recall now. 12 Q. Would it be important to know who built this unit or 13 this facility? 14 MR. MANNING: Objection; form. 15 A. I guess it could be in some circumstances, but I have 16 to say not necessarily. I would have to know why we would want 17 to know who build it. 18 Q. (BY MR. SKAGGS) In the sense of a large corporation 19 that has their own safety department or industrial hygiene 20 department compared to a small corporation, would it be 21 important to know who built one to determine if they did have a 22 safety corporation? 23 MR. MANNING: Objection; form. 24 A. I'm sorry. If they had a what? 25 Q. (BY MR. SKAGGS) Strike that question. Let me try to Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003901 BRUCE LARSON 1 do that again. Page 41 2 Would it be important to know who built the 3 facility when you were considering a large corporation that had 4 a safety or hygiene department compared to a smaller 5 corporation that didn't have that type of department? 6 MR. MANNING: Objection; form. 7 A. I would say it would be important in terms of not 8 only the quality of the work that was to be done, but also the 9 safety of the contract employees during the construction of the 10 facility , so from that standpoint, yes. 11 Q. (BY MR. SKAGGS) How about what you think their level 12 of knowledge concerning asbestos dust, would it be important to 13 know who built that facility? 14 MR. MANNING: Objection; form. 15 A. I guess that could be considered part of it. 16 Q. (BY MR. SKAGGS) The refinery, do you remember when 17 you were there between '78 and '81, how many employees Mobil 18 had out there? 19 A. At the refinery? 20 Q. At the refinery. 21 A. I could just estimate. I would say probably on the 22 order of 7- to 900. 23 Q. How about on the chemical side? 24 A. Chemical side, probably about 180. 25 Q. Did each facility -- refinery and the chemical Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003902 BRUCE LARSON Page 42 1 side -- have operators as well as a maintenance department? 2 A. Yes. 3 Q. Did you hire outside contractors for the chemical 4 side to do their maintenance? 5 A. There were some, yes. 6 Q. Do you know who any of those corporations were? 7 A. Rosendahl, R-O-S-E-N-D-A-H-L. 8 Q. How about on the refinery side? Did you hire or did 9 Mobil hire outside contractors? 10 A. I know they did. I'm not familiar with the actual 11 companies. 12 Q. Would you say you had a limited amount of discussions 13 with these maintenance contractors? 14 A. No, I would say there was quite a bit. There was 15 typically a preselection process where the safety department 16 would meet with the contractors, review their safety records - 17 their safety statistics, we had a criteria that we wanted to 18 select someone with at least below average -- when I say "below 19 average," I'm talking about an incidence rate for accidents -- 20 so that was one of the criteria. They were generally selected 21 based on their competency and their past records. 22 Q. I imagine price had something to do with who was 23 selected as well; is that right? 2 4 A. That was part of the equation. 25 Q. Between '78 and '81, was there any new construction Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003903 BRUCE LARSON 1 projects performed at the refinery or the chemical site? Page 43 2 A. I would say, yes. I'm sure there was. 3 Q.Do you recall any of those? 4 A. I know at one point when I was there they added some 5 furnaces to the Olefins Aromatics plant. That's the one that I 6 can recall specifically. 7 Q. When did the remediation -- did a remediation for 8 asbestos-containing products begin at the refinery in Beaumont? 9 A. I think you said when did remediation for asbestos - 10 Q. Isaid "when," but I didn't lay the foundation right. 11 Did a remediation program begin at the refinery 12 in Beaumont -- an asbestos remediation program? 13 A. I'd say there was probably one ongoing depending on 14 when equipment was shut down and maintained. We had a policy 15 that any time asbestos-containing insulation was removed, it 16 was replaced with nonasbestos-containing. 17 Q. When did that policy begin? 18 A. Early '70s. 19 Q. ' 72? 20 A. Approximately. 21 Q. Who started that policy? 22 A. It was a policy that basically the corporation 23 adopted. and it was contained in the engineering standards. 24 Q. Princeton, New Jersey? 25 A. Right. That's where central engineering was, yes Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003904 BRUCE LARSON Page 44 1 Q. What about other asbestos-containing products at the 2 time? I mean, asbestos-containing pipe or gaskets? Were they 3 replaced? 4 A. We had a policy of substituting -- as asbestos-free 5 substitutes became available, that we would replace those as 6 well. That included things like welding blankets, gaskets, any 7 asbestos-containing material. Some became available sooner 8 than later. In fact, there is probably some insulation or 9 products somewhere that still contains asbestos. 10 Q. I want to talk about something called 11 asbestos-containing pipe or sewage pipe. Do you know if that 12 was installed over there at the refinery? 13 A. I don't know. 14 Q. Also known by Certainteed or Capco. Have you ever 15 hear those names? 16 A. I have heard of Certainteed, yes. 17 Q. Do you know if that was installed out there? 18 A. I really don't know if it is or not. 19 Q. How about on the chemical side, caustic pipe called 20 Haveg pipe. Do you know if that's installed out there? 21 A. I am not aware one way or the other. 22 Q. Do you know of any asbestos-containing pipe that 23 carried caustics or acid was being used at the chemical site? 2 4 A. I don't think there is, but then I can't say that 25 with complete certainty. I'm not aware of it. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003905 BRUCE LARSON Page 45 1 Q. But your testimony is, if it was out there and they 2 knew itwas asbestos, they would have been replaced after 1972 3 when they broke down? 4 A. It would have been replaced when the equipment was 5 either maintained or shut down. 6 Q. Let me jump back for a second here. 7 When you were an OSHA compliance officer, you 8 told Denman that you would rank the facilities -- I believe you 9 told me that you ranked the facilities -- where you felt the 10 risk would be more prevalent. Can you explain that to me a 11 little bit more? 12 A. In terms of exposure monitoring, we wanted to select 13 the people that we thought were at the highest risk of actually 14 being exposed. So for example, if we went out into the 15 facility to do exposure monitoring, we would wait until we had 16 an operation to say where asbestos was either being removed or 17 installed because typically in a chemical plant or refinery, 18 unless asbestos-containing insulation is disturbed, you are 19 going to essentially get no exposure. So we wanted to try to 20 identify people when they had the highest potential of exposure 21 and monitor that exposure. We felt then if we could assure 22 ourselves that those people were not being exposed, then the 23 other people that weren't handling the material would not be 24 exposed. So that was the strategy we took when we evaluated 25 exposure. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003906 BRUCE LARSON Page 46 1 Q. Was the only asbestos-containing product that you 2 took into this equation thermal pipe insulation? 3 A. It was one of those. It was probably the one that 4 was the most prevalent, but certainly there is other materials 5 such as gaskets. But the insulation was the one that was 6 probably the most obvious. 7 Q. Like, did you have the Flexitallic facility that is 8 out on 225 on your list? 9 A. Flexitallic? 10 Q. Yes, there is a Flexitallic facility out on -- 11 A. Oh, you are talking about for OSHA? 12 Q. For OSHA, yes. 13 A. Yeah, when I was with OSHA, I did do industrial 14 hygiene surveys of gasket makers. In fact, I think I was 15 actually at that plant. 16 Q. What you told me is you would prioritize certain 17 facilities based on the potential for asbestos exposure or 18 other particular exposures when you were at OSHA. 19 A. Yes . 20 Q. Stanco would be at the top? 21 A. I would say of the facilities that I was actually 22 involved with, yes. 23 Q. Where would Exxon be? 24 A. I would say that would be probably near the bottom. 25 Q. How about Mobil? Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003907 BRUCE LARSON 1 A. Same place. Page 47 2 Q. Why would they be at the bottom, in your opinion? 3 A. Because in the case of a refinery or chemical plant 4 especially in the case of Exxon and Mobil, asbestos insulation 5 is really not something that they are manufacturing. It is 6 something that once it is installed, it generally stays 7 installed unless it is disturbed. So you wouldn't have an 8 eight-hour full shift exposure to asbestos from insulation in a 9 refinery. Whereas, a company that's making asbestos-containing 10 gaskets or making asbestos containing brake blocks, like 11 Stanco, you would have essentially a continuous exposure to 12 high levels. So there is a tremendous difference in the 13 exposure potential between that type of an operation and a 14 refinery. 15 Q. Did fiber type ever come into the equation? Was that 16 ever considered in the equation? 17 A. For OSHA compliance we considered at that time, at 18 least, any fiber type was considered to be asbestos, whether it 19 was crocidolite, amosite, so and so forth, chrysotile. A fiber 20 was a fiber. 21 Q. At that time, did you consider all those fibers 22 carcinogenic? 23 A. When the initial OSHA asbestos regulations were 24 established, the emergency temporary standard in '71 and then 25 the permanent in '72, I think it was still an issue as to Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003908 BRUCE LARSON Page 48 1 whether or not asbestos was a carcinogen. Certainly at that 2 time OSHA considered it to be a pulmonary hazard, in terms of 3 asbestosis. But I think NIOSH and OSHA at that time had not 4 equivocally decided at that point that asbestos was a 5 carcinogen. It was certainly a suspect, but I don't think, at 6 least in terms of the rule making and the preamble to those 7 regulations, they said at that point it was still uncertain as 8 to the carcinogenicity. 9 Q. Why were you concerned about asbestos exposure then? 10 A. Well, we were concerned about it in terms of the 11 potential pulmonary hazards and the fact that even then it was 12 sought that there was -- could be a potential carcinogen. 13 Q. So the more concern was the disease of asbestosis 14 rather than some kind of cancer related to asbestos? 15 A. Well, there is no doubt at that point that, yes, it 16 could cause asbestosis. So certainly, yeah, that was the 17 concern. 18 Q. So if you had a facility that had a large amount of 19 crocidolite -- strike that. 20 If you had a facility that had a small amount of 21 crocidolite that was friable and another facility that had a 22 large amount of chrysotile, that chrysotile facility would be 23 more priority than the facility that just had a small amount of 24 chrysotile -- crocidolite -- sorry. 25 MR. MANNING: Objection; form. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003909 BRUCE LARSON Page 49 1 A. It would depend on the actual -- the exposure 2 potential because you can have these materials -- if they're 3 not friable versus friable, that would make a large difference 4 in how we would evaluate it. Certainly, like once -- for 5 example, floor tile, once it is fabricated and made, you really 6 don't have friable asbestos fibers, but during the 7 manufacturing process you do. It would depend on whether or 8 not the fibers were friable when they were being handled. 9 Q. More of my question is related to is that, at the 10 time that you were at OSHA you just told me that, yes, OSHA was 11 concerned with asbestos because of the pulmonary hazards; 12 however, there was still some question in your mind about the 13 carcinogenic effects of asbestos fibers? 14 A. Correct. 15 Q. And you know that there were studies out there that 16 connected crocidolite exposure to mesothelioma? 17 A. I personally at that time was not familiar with that, 18 but I know looking back now, I know that during the rule making 19 that OSHA considered, that they took that into account. But as 20 a person directly out of college at the time, I don't know that 21 I was personally aware of that. 22 Q. You were just concerned about what exposure level was 23 at the time? 24 A. There was 5 fibers per cc, and it was a time-weighted 25 average, and it's kind of like a cop with the radar gun. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003910 BRUCE LARSON 1 That's what I was checking for. Page 50 2 MR. SKAGGS: Do you mind if I take a real short 3 break? 4 MR. MANNING: No. 5 (A break was taken from 11:02 to 11:10) 6 Q. (BY MR. SKAGGS) We are back on the record. Thank 7 you for letting me have that short break. Let's get this going 8 so we can get out of here. 9 When you joined Mobil, can you tell me what kind 10 of trade associations they belonged to? 11 A. It would have been the Chemical Manufacturer's 12 Association, and we also were a member of an Organization 13 Resource Counselors, ORC, strictly from a professional safety 14 and health standpoint. 15 Q. I imagine you are a member of the API, right? 16 A. Not with Mobil Chemical. Later I became a member of 17 API when I moved over to Mobil Oil. 18 Q. American Industrial Hygiene Association? 19 A. Correct. 20 MR. MANNING: Objection. Just to clarify, are 21 you talking about what he was a member of? 22 MR. SKAGGS: No, Mobil. 23 MR. MANNING: He's talking about what Mobil was 24 a member of, not what you personally were a member of. 25 A. Okay. Mobile would have been a member of the API at Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003911 BRUCE LARSON 1 that time as well. Page 51 2 Q. Mobil would have been a member of the Chemical 3 Manufacturer's Association? 4 A. Correct. 5 Q. National Safety Counsel? 6 A. Correct. 7 Q. Texas Chemical Counsel? 8 A. Correct. And National Association of Manufacturers, 9 Business Roundtable. 10 Q. That didn't seem very burdensome to answer that 11 question, did it? 12 A. No. 13 MR. MANNING: Objection; form. 14 Q. (BY MR. SKAGGS) He knows where I'm going with that. 15 What was the purpose of Mobil belonging to these 16 trade associations, do you know? 17 A. There were many reasons, I suppose. For example, 18 with the American Petroleum Institute, that was an industry 19 association that developed industry standards, some involving 20 safety, some involving product specification. It also involved 21 industry advocacy with state, local and federal government, 22 products research, a variety of functions. 23 Q. It is also a medium or forum for information for you 2 4 to disseminate amongst its members; is that right? 25 A. To some extent, yes. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003912 BRUCE LARSON Page 52 1 Q. Would the organization disseminate state regulations 2 dealing with asbestos exposure? 3 A. I'm not familiar with that happening, but I'm sure 4 that it could have. 5 Q. How about medical literature relating to mesothelioma 6 or any kind of asbestos-related cancers? 7 A. I guess my answer would be the same. I'm not 8 personally familiar with that, but it could have happened. 9 Q. Did each individual facility get their own copy of 10 the monthly trade journal that Mobil belonged to? 11 A. I don't think so. I guess it depended on what it 12 was . For example, some may have -- for example, like the Texas 13 Chemical Counsel, if -- our plants in Beaumont I think probably 14 did get copies of that because they were themselves members. 15 When it relates to, like. Chemical Manufacturer's Association, 16 I think that was primarily handled at the headquarters level -17 the correspondence. I don't know if the individual facilities 18 would be receiving anything directly. So it just depended on 19 the trade association. 20 Q. How about the Journal of Industrial Medicine, would 21 that have been disseminated to each individual plant? 22 A. No. 23 Q. From 1981 you got promoted to supervisor and 24 transferred to New Jersey. 25 A. That's correct. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003913 BRUCE LARSON Page 53 1 Q. You had to go live up there in the Yankee part of the 2 world, huh? 3 A. I guess that's correct. 4 Q. How did your job duties change when you became a 5 supervisor ? 6 A. At that time I was basically responsible for 7 coordinating the work within Mobil Chemical as a company and 8 not necessarily just by a single region. We did have also, at 9 that time , we added several industrial hygiene positions, and I 10 was the supervisor of those individuals. 11 Q. You were setting policy instead of implementing 12 policy. Would that be a fair -- 13 A. I would do both. I would help establish policies. 14 obviously then I would be involved with implementing them in 15 our facilities. 16 Q. You were responsible for 46 manufacturing plants and 17 two research facilities in the continental United States; is 18 that right? 19 A. 46 sounds a little high. I think it was more like 20 26 . 21 Q. 26? Is that the sum total of Mobil's plant and 22 research facilities in the United States? 23 A. Correct. 24 Q. Did you also have field work at the time? 25 A. I did some. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003914 BRUCE LARSON Page 54 1 Q. Much less than when you were a regional supervisor? 2 A. Correct. It was less. 3 Q. How much less? 4 A. I would say probably -- probably about 20 percent. 5 Q. Who was your boss? 6 A. Initially my boss was the manager of safety and 7 health for Mobil Chemical Company. 8 Q. His name was? 9 A. Walter Sweeny. 10 Q. It changed when you were still in that position? 11 A. Later I believe I reported to the manager of employee 12 relations. 13 Q. I read in your CV when you were in this position -14 and I believe you were in this position from 1981 to '84; is 15 that right ? 16 A. Correct. 17 Q. That you reviewed -- or your review of capital 18 projects for environmental impact? 19 A. Correct. 20 Q. Capital projects meaning new construction of 21 facilities ; is that correct? 22 A. Correct. 23 Q. What types of information would you review? 24 A. Well, we would review the materials that would be 25 handled in the process -- the raw materials, the intermediates. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003915 BRUCE LARSON Page 55 1 the products, we would review the process equipment and the 2 process flow diagrams to determine how those materials would be 3 processed, at what points in the process you might have an open 4 system as compared to a closed system. And where there were 5 open systems, ways to control and minimize exposure in terms of 6 ventilation, enclosure, isolation, determine what training 7 programs would be appropriate for employees that were operating 8 the process, what protective equipment would be appropriate, 9 what medical surveillance programs would be appropriate. I 10 think that sums it up fairly well. 11 Q. Would it be part of your job to make recommendations 12 and changes to the capital project? 13 A. In terms of employee protection, yes. 14 Q. Did Mobil generally follow your recommendations? 15 A. I would say yes. 16 Q. Do you remember a time that Mobile Corporation said, 17 Mr. Larson, I don't think we are going to follow that 18 recommendation? 19 A. I don't recall any. 20 Q. Was asbestos exposure a concern at this time? 21 A. It was in terms of maintenance and shutdowns. 22 Q. I want to stick strictly to capital projects. 23 A. Capital projects? Again, like I said in the 24 beginning, in about 1972 any new construction we tried to 25 eliminate the use of any asbestos-containing materials to the Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003916 BRUCE LARSON Page 56 1 extent that we had substitutes available. That was our policy. 2 So yes . 3 Q. So was it a concern or was it a concern on capital 4 projects ? 5 A. I would say at that time it was. 6 Q. Would you still be performing dust monitoring for 7 asbestos fibers between this time period '81 to '84 on these 8 capital projects? 9 A. Yes. I don't know if I mentioned it in my prior 10 deposition, but we had a way of evaluating any existing 11 insulation to determine if it contained asbestos or not. And I 12 guess it was the insulation that did not contain asbestos was 13 marked with a blue banding. 14 Q. Okay. 15 A. And anything that didn't have a blue banding we 16 assumed contained asbestos. And over time as we maintained or 17 shut down equipment that contained asbestos -- in other words. 18 the material that was not marked with a blue band, we put 19 nonasbestos-containing materials back on that equipment and 20 marked it with a blue band. 21 Q. When did this program begin? 22 A. This was in -- I think somewhere between 1972 and 23 1974 . 24 Q. At all the Mobil facilities? 25 A. I believe that was true, yes. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003917 BRUCE LARSON Page 57 1 Q. So any shutdown, my client should have seen a blue 2 band on asbestos-containing projects? 3 MR. MANNING: Objection; form. 4 A. Nonasbestos-containing. 5 Q. (BY MR. SKAGGS) Nonasbestos-containing. Any Mobil 6 facility between -- starting in '72, my clients who were 7 working for contractors should have been told if you don 't know 8 what it is -- 9 A. Right. It could have been '74. Somewhere in that 10 time frame. 11 Q. Either '72 or '74, somewhere in that time frame, my 12 clients who worked for contractors should have been told that 13 if you don't know what it is, assume it is asbestos? 14 MR. MANNING: Objection; form. 15 A. I believe that would be the case. 16 Q. (BY MR. SKAGGS) That would have been told to them by 17 Mobil Corporation? 18 A. Yes . 19 Q. Did you file environmental impact statements and 20 those types of things for these capital projects? 21 A. I wouldn't have done that. The environmental 22 engineers would have done that. 23 Q. You -- we were talking a little bit -- we have been 24 going in and out between capital projects and maintenance 25 projects . Would you say you had the same duties related to Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003918 BRUCE LARSON 1 maintenance projects as you did with capital projects? Page 58 2 A. Typically the site people were responsible for that. 3 When I was -- 4 Q. I'm just specifically talking between '81 and '84 5 A. Right. It would have been the individual plants -- 6 their safety departments. They would have served the same role 7 on a plant-specific basis. They review their maintenance 8 practices and the smaller capital projects. For instance. they 9 decide to add a cooling tower or something like that, that 10 wouldn't rise to the corporate level. That would be handled 11 locally. but they would still involve a safety and health 12 review. 13 Q. On the maintenance projects at this time between ' 81 14 and '84, if an air monitoring device recorded an exposure of 15 higher than 2 million particles per cubic foot, would that be 16 reported to you? 17 MR. MANNING: Objection; form. 18 A. It would eventually. 19 Q. (BY MR. SKAGGS) Do you recall any of those instances 20 happening ? 21 A. No, as I said earlier, the entire time that I was 22 employed at Mobil, I didn't -- I wasn't aware of any asbestos 23 exposures that exceeded the applicable limit. 24 Q. I didn't hear you say that for anytime you were with 25 Mobil. So that kind of shortcuts me in a lot of those Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003919 BRUCE LARSON 1 questions. Page 59 2 A. Okay. 3 Q. Let me talk about air monitoring reports. 4 How many different people reviewed those 5 reports? 6 A. I'd say at a minimum two. The person who collected 7 the sample, and ultimately the people in the industrial hygiene 8 group, such as myself, would see it. In some cases, there 9 would be three or four people that would review it. The person 10 that collected the sample, possibly their supervisors. Roscoe 11 Compton in Beaumont collected a sample, he would pass that 12 through his supervisor, which would have been Dennis Bruce, and 13 that would have been sent to Edison, New Jersey for our review, 14 and we would actually put that then into the computer system, 15 the database. So minimum of two and could be as many as three 16 or four. 17 Q. When you were promoted in '84, you were promoted as 18 manager of the industrial hygiene program and transferred to 19 Princeton, New Jersey; is that right? 20 A. Initially, I was -- my title was manager of 21 regulatory affairs. 22 Q. Okay. 23 A. And I held that position for about a year, and then 24 ultimately I became -- my title was manager of industrial 25 hygiene for Mobil Corporation. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003920 BRUCE LARSON Page 60 1 Q. When you were manager of regulatory affairs, is that 2 dealing with legislation and rules of OSHA? 3 A. Right. OSHA regulations and legislation in terms of 4 OSHA reform, and that type of thing. That was primarily it. 5 Q. Did you ever have to testify to any congressional 6 committee or senate dealing with OSHA? 7 A. No. We submitted comments to OSHA, but in that 8 particular job, I didn't; later on in my career I did, but not 9 at that time. 10 Q. Remind me to talk about that. It sounds very 11 interesting. 12 Let me ask you this: What types of comments did 13 Mobil submit dealing with OSHA reform or industrial 14 regulations? 15 A. I'm trying to think. During that period, I think we 16 submitted comments on their benzene regulations that were being 17 revised. 18 Q. Was the TLV being reduced at that time? 19 A. Right. That was in 1987 when OSHA proposed to revise 20 their benzene regulations, and we submitted comments on that, 21 we submitted comments on the OSHA hazard communication 22 standard. I remember submitting comments on that. I think 23 they also amended their noise standard -- the hearing 24 conservation standard, and we submitted comments on that. 25 Q. Was your comments dealing with benzene saying that Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003921 BRUCE LARSON Page 61 1 the standard was acceptable as it was or that you agreed with 2 their reduction? 3 A. As I recall, we didn't oppose the exposure limit, but 4 I think at some point later on the Supreme Court overturned 5 their standard. But I don't think Mobil opposed the... 6 Q. The decrease in the limit? 7 A. The decrease in the limit. 8 Q. Part of your CV says that at this time between '84 9 and '90, you had worldwide responsibilities. What does that 10 mean? 11 A. Well, worldwide in a sense that the group that I was 12 with was responsible for developing and implementing industrial 13 hygiene programs for the corporation, so that would have 14 included not just facilities in the U.S. but overseas 15 facilities as well. It also involved periodically auditing the 16 health and safety programs of our facilities. 17 Q. Worldwide? 18 A. Worldwide. 19 Q. Did part of your job include corresponding with 20 different countries threshold limit values if they had them or 21 their equivalent? 22 A. In Mobil, we established what we came to be known as 23 Mobil acceptable exposure standards. And basically what it 24 did, we reviewed the ACGIH -- American Conference of 25 Governmental Industrial Hygienists -- threshold limit values or Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003922 BRUCE LARSON Page 62 1 TLVs, and we looked at that in comparison to the country or 2 locality where the facilities were located, and we would adopt 3 the lower of the governmental standards or the threshold limit 4 values for any facility within Mobil's organization. And that 5 became the acceptable exposure standard. 6 Q. Was that a published report or just something that 7 you guys -- 8 A. It was published internally. 9 Q. Was this threshold limit value for all different 10 types of particulate matter or just dealing with one specific 11 thing? 12 A. It was for all, basically. 13 Q. Including noise -- 14 A. Right. Noise, vapors, gases. 15 Q. How about asbestos? 16 A. Yes . 17 Q. Was Mobil still using thermal -- asbestos-containing 18 thermal insulation in their overseas production? 19 A. We had basically the same policy, that as equipment 20 was maintained or shut down that we would replace any 21 asbestos- containing insulation with non. 22 Q. Do you recall any new construction projects in '84 or 23 '90, where any asbestos-containing thermal insulation was 24 installed worldwide? 25 A. Between what dates? Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003923 BRUCE LARSON Page 63 1 Q. '84 and '90, when you were in charge of the worldwide 2 production. 3 A. No. 4 Q. So if you had a country like Chile that completely 5 banned asbestos and had no TLVs, you would 6 A. It would be likewise banned within any Mobil facility 7 Q. And that was Mobil's corporate philosophy? 8 A. Yes. 9 Q. All right. Normally -- this is a difficulty 10 normally, when a company like Mobil tells me who their experts 11 are, they make a designation as to what kind of opinions they 12 are offering in this case, and it is a little paragraph 13 underneath your name. Unfortunately, yours doesn't have a 14 paragraph underneath there. So that kind of leaves you open to 15 a whole bunch of opinions that you may offer. 16 So what I want to ask you is in the Carr case - 17 the case we are here for today. What is your understanding of 18 the opinions that you will be offering in this case? 19 A. My opinions would relate to the safety and health 20 procedures and regarding safety and health that were in place 21 within Mobil for protecting employee and contractors' safety. 22 Q. We are going to have to limit this to the Mobil 23 Beaumont facility because you just don't know anything about 24 that Johnson Bayou facility in Louisiana; is that correct? 25 MR. MANNING: Objection; form. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003924 BRUCE LARSON Page 64 1 A. As I said, I am not specifically familiar with that 2 facility, but I can address it from the standpoint of Mobil 3 policies and procedures because Mobil policies and procedures 4 apply company-wide. 5 Q. (BY MR. SKAGGS) But you don't know the 6 implementation of it or any kind of information regarding that 7 at the Johnson Bayou facility? 8 MR. MANNING: Objection; form. 9 A. That particular facility, I just know about it in a 10 general sense but not on a site-specific basis. 11 Q. (BY MR. SKAGGS) When you say you know about it in a 12 general sense, what do you mean? 13 A. Well, for example, I know that Mobil has specific 14 procedures for, like, the use of respiratory protection, and I 15 know those were implemented on a company-wide basis. So if it 16 was a gas plant oil refinery, it is basically the same program 17 would be in effect. And even if it was a pumping station, 18 whatever safety and health programs and policies we had in 19 effect within Mobile would have applied to that facility. 20 Q. And that's based on your knowledge of acorporate 21 environment at Mobil; is that right? 22 A. Yes. 23 Q. There could be some guy out there as the plant 24 manager at Johnson Bayou not implementing any process and you 25 would have no idea about that? Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003925 BRUCE LARSON Page 65 1 MR. MANNING: Objection; form. 2 A. That would be unlikely, but I can agree with you that 3 without me being specifically familiar with that plant, or the 4 people, it would be hard for me to. 5 Q. (BY MR. SKAGGS) We would have to rely on the people 6 who worked at that facility? 7 MR. MANNING: Objection; form. 8 A. Well, I don't know how to answer that. Like I say. 9 policies and procedures were applied company-wide , so it would 10 be very unlikely that anything would be done differently. 11 Q. (BY MR. SKAGGS) Do you have knowledge regarding 12 Mobil's document retention program? 13 A. Generally, I would. 14 Q. What is it? 15 A. I think essentially it is to -- I believe they kept 16 information -- well, it depended. When it comes to safety and 17 health records, there is a requirement for keeping that 18 information for, like, 20 years, and Mobil was in compliance 19 with that. It is actually an OSHA requirement. When it came 20 to just other information, business and operating information. 21 I believe the policy was to retain that for a period of eight 22 years. 23 Q. Tax records and those types of things? 24 A. Right. 25 Q. Where is the database located? Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003926 BRUCE LARSON Page 66 1 A. I believe Mobil had a record retention facility in 2 Pennsylvania. 3 Q. Do you know where in Pennsylvania? 4 A. I think West Chester. 5 Q. Is that where you believe the database would be 6 located? 7 A. That's where our central record storage was 8 maintained until 1997. 9 Q. What happened? 10 A. When it was destroyed by fire. 11 Q. Is the database, to your knowledge, destroyed by 12 fire? 13 A. When you say "database," are you talking about a 14 computer system? 15 Q. Yes, where you told me you put it all -- 16 A. No, I think that information was not destroyed. I 17 think it was available and probably could be available today. 18 I don't know. 19 Q. Where would I have to go to access it to find out all 20 the air monitoring results -21 A. I don't know currently how you do that, but I know 22 that at the time I retired, the system was still in operation. 23 Q. Where, when you retired? 24 A. The actual database would have been -- the computer 25 center was in Dallas. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003927 BRUCE LARSON Page 67 1 Q. Basically, I can't go down to the Mobile facility in 2 Beaumont and plug in and get all that information, can I? 3 MR. MANNING: Objection; form. 4 A. I don't know. You might be able to. 5 Q. (BY MR. SKAGGS) But if I went to Dallas, I could 6 access all the air monitoring information that's been 7 programmed into that database? 8 A. I don't know what -- at that time it was in Dallas. 9 Now that the merger has occurred, they probably have a 10 different computer center. I have no idea. 11 Q. Do you know who I should ask at Exxon Mobil? 12 A. Yes . 13 Q. Who is that? 14 A. I don't know. I don't know who that would be. I'm 15 sure someone in their safety and health department. 16 Q. Are you an epidemiologist, sir? 17 A. I'm not. It is not my degree, but I do have courses 18 in it as we discussed earlier from my masters program. I am 19 familiar. in general terms, with epidemiology. 20 Q. Are you planning to be providing any testimony 21 related to epidemiology of asbestos and cancers? 22 A. I am familiar with the epidemiology studies that have 23 been undertaken within Mobil. I didn't actually do the 24 studies, but I am familiar with them and their findings. 25 Q. When did Mobil start conducting epidemiology studies Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003928 BRUCE LARSON 1 of asbestos and cancer? Page 68 2 A. I believe they started studies in the 1970s -- 3 probably in the mid 1970s. 4 Q. What type of cancers were they correlating with 5 asbestos ? 6 A. They were looking with any disease within Mobil 7 employee population. So they looked for -- essentially any 8 disease. whether it be lung cancer or liver cancer or pulmonary 9 fibrosis or leukemia, they looked for any disease among 10 Mobile's employee population. 11 Q. Do you remember the results of those first studies? 12 A. I can tell you in general terms that Mobil's findings 13 showed in the broadest possible terms that the mortality rate 14 for Mobil employees was well below that of the general 15 population, and specifically as it relates to lung cancer. 16 mesothelioma, and pulmonary fibrosis, that it was also below 17 what would be expected in the general population. 18 Q. How about esophageal cancer? 19 A. I don't recall that particular type. I don't 20 think -- I don't recall that, but all the cancers that were 21 studied - - and that would have included esophageal -- were 22 below that expected in the general population. 23 Q. Do you know where these studies are located? 24 A. They have been published in the General Occupation of 25 Medicine. There were, I think, three or four at least that Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003929 BRUCE LARSON 1 have been published. Page 69 2 Q. Were these studies of all Mobil employees in the 3 continental United States? 4 MR. MANNING: Objection; form. 5 A. I think at least some were, yes. 6 Q. (BY MR. SKAGGS) Was there any epidemiological 7 studies specific to the Mobil Beaumont facility? 8 A. Yes . 9 Q. Was that also published in the General Occupation of 10 Medicine ? 11 A. I believe that's the -- it might have been a 12 different one, but I know it was published. 13 Q. Do you know when that study was taken? 14 A. It was updated -- it was initially begun in the mid 15 1970s, and it was updated periodically, I think, through the -- 16 at least through the 1980s and possibly through the 1990s. 17 Q. Was it updated because of the latency period of 18 certain diseases ? 19 A. That's the primary reason, yes. And not just 20 latency. but as you have a larger number of employees in the 21 population the study becomes much more accurate. 22 Q. In general, a larger population -- 23 A. A larger population base. 24 Q. It is trending downward, or has it been standing 25 constant through all the updates dealing with asbestos? Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003930 BRUCE LARSON Page 70 1 MR. MANNING: Objection; form. 2 A. It is my understanding it is pretty much constant. 3 That's my impression just from looking at these studies. 4 Q. (BY MR. SKAGGS) There is nothing in there that gives 5 a scientific significant number to the number of mesothelioma 6 cases in Mobil employees? 7 MR. MANNING: Objection; form. 8 A. I don't think so, but I think we do have 9 epidemiologist that can probably better answer that question 10 than I could. 11 Q. (BY MR. SKAGGS) Are you going to render any opinions 12 related to the toxicology of asbestos in this case? 13 MR. MANNING: Objection; form. 14 A. In a general sense, yes. In terms of I'm 15 knowledgeable of different fiber types and their potential for 16 causing various types of cancer. I don't purport to be a 17 toxicologist, but I do have general knowledge of asbestos and 18 its potential hazards. 19 Q. (BY MR. SKAGGS) Do you believe or do you have 20 knowledge that exposure to asbestos can contribute to 21 esophageal cancer? 22 A. I would defer to a medical doctor on that. 23 Q. You won't be offering us any opinions one way or 24 another on that topic? 25 A. No. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003931 BRUCE LARSON 1 Q. Does chrysotile cause mesothelioma, sir? Page 71 2 MR. MANNING: Objection; form. 3 A. It is my general understanding that there is very 4 little, if any, linkage between exposure to chrysotile and 5 mesothelioma. It is my understanding that forms of asbestos 6 that have been most linked to mesothelioma would be amosite and 7 crocidolite. 8 Q. (BY MR. SKAGGS) What type of fiber was most used at 9 the Mobil facility in Beaumont? 10 A. Based on the information that I've seen, the sampling 11 that was done, chrysotile was the predominant form of asbestos 12 used there 13 Q. This is the air monitoring that we have talked about 14 before ? 15 A. Both samples of the asbestos-containing materials -- 16 insulation , gasket materials, that type of thing. 17 Q. You looked at it through an electron microscope or 18 some type of device? 19 A. We had laboratories that did that for us. 20 Q. Do remember any ratios between the chrysotile. 21 crocidolite, amosite asbestos at Mobil facility in Beaumont? 22 A. I can only generalize for you, and I would say that 23 based on the data that I have seen that about 80 percent of the 24 bulk samples that we collected were predominantly chrysotile. 25 In some of the samples we did see lower amounts of amosite. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003932 BRUCE LARSON Page 72 1 Generally that would be in the range of -- where we did find 2 it, it was in the rang of 5 to 15 percent. And very few, if 3 any, that I recall contained crocidolite. 4 Q. Is this the refinery or chemical or both? 5 A. I am just looking at it in general terms. 6 Q. When this -- and this started sometime early 1970 -- 7 A. Early '70s, uh-huh. 8 Q. Is that data still available for us to look at? 9 A. I'm sure. 10 Q. What is the need or why -- strike that. 11 Why did Mobil use asbestos-containing thermal 12 pipe insulation? 13 A. Well, I think historically asbestos-containing 14 insulation was used in applications where you had high 15 temperatures where other insulating materials would not 16 withstand the heat. And basically at one time 17 asbestos-containing insulation was the only type of insulation 18 that could be used. Now, in lower temperatures, there is a 19 variety of other types of insulation that can be used, and they 20 were, in fact, used, like mineral wool, ceramic fiber, 21 fiberglass. But some of the most high temperature 22 applications -- temperatures exceeding like 800 degrees 23 Fahrenheit, and even about 1200 degrees Fahrenheit, the only 2 4 insulation that could be used were the insulations that 25 contained asbestos. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003933 BRUCE LARSON Page 73 1 Q. And temperatures above 1200 degrees required amosite 2 fibers as opposed to chrysotile fibers? 3 A. I really can't answer that. I'm not sure. 4 Q. Were there temperature processes at the Mobile 5 Beaumont facility that required -- that ran into higher than 6 1200 degrees? 7 A. I don't think so. 8 Q. There was no cracking unit or anything like that out 9 there? 10 A. Yes, there was, but I'm not sure it was above 1200. 11 I guess my answer would be, I don't know specifically. 12 Q. Do you know or have you heard data sheets or 13 requirements that require the insulation of amosite asbestos in 14 a Mobil facility out in Beaumont? 15 A. I think in one of the engineering specifications that 16 I have seen that amosite was listed as one option. 17 Q. What was that specification for? 18 A. It was one of the engineering standards. I can't 19 tell you exactly which one it was, but it's one I have seen at 20 one point in my review of records. 21 Q. Do you know what the project was for? 22 A. No, I don't recall. 23 Q. Was this called for -- Unibestos as a brand name or 24 the insulation? 25 A. I don't recall if a brand name was specified. I Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003934 BRUCE LARSON Page 74 1 think the way the engineering standards were written, they were 2 written in terms of the actual composition of the insulation 3 and not necessarily by brand name, but I'm not saying that some 4 document wouldn't actually have a brand name. 5 Q. You can't think of any others that required amosite 6 fibers for its insulation? 7 A. Not that I recall. 8 Q. You don't recall any engineering specifications that 9 required the use of asbestos-containing pipe? 10 A. No. 11 Q. Or caustic pipe that contained asbestos? 12 A. No. 13 Q. Let me ask you a general question: When do you think 14 it was common knowledge that -- petrochemical industry that 15 asbestos could be harmful? 16 MR. MANNING: Objection; form. 17 A. Harmful in the sense of any effect? 18 Q. (BY MR. SKAGGS) Any effect. 19 A. I would say probably as early as the late 1930s. 20 There was some concern about the potential for causing 21 pulmonary fibrosis. 22 Q. Was that after the Merriweather report came out? 23 MR. MANNING: Objection; form. 24 A. I think that's probably correct. 25 Q. (BY MR. SKAGGS) Would it be your opinion that as Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003935 BRUCE LARSON Page 75 1 early as the 1930s a company like Mobil should have known that 2 high levels of exposure to asbestos can cause pulmonary 3 fibrosis ? 4 MR. MANNING: Objection; form. 5 A. High levels of exposure? I think high levels of 6 exposure with a sufficient duration. I would agree with that. 7 Q. (BY MR. SKAGGS) Should a company like Mobil in 1930 8 been interested in their employees' exposure to asbestos? 9 A. Interested? 10 Q. Yes. 11 MR. MANNING: Objection; form. 12 A. I'm not sure I understand the question. 13 Q. (BY MR. SKAGGS) From a safety personnel standpoint. 14 should a company like Mobil have been concerned about asbestos 15 exposure in the 1930s? 16 MR. MANNING: Objection; form. 17 A. I'd say if there was -- I don't know how exactly I 18 would respond to that. I don't think that -- from what I know 19 and from what I've read that asbestos exposure was thought to 20 be a hazard because of the fact that the exposures were 21 considered to be fairly intermittent and that asbestos was 22 contained in materials that for the most part were bonded 23 unless they were disturbed. 24 Q. (BY MR. SKAGGS) Would you agree with me that -- or 25 would you base your opinion that Mobil didn't have a concern in Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003936 BRUCE LARSON Page 76 1 the 1930s because most of the studies were dealing with textile 2 industries or shipyards? 3 MR. MANNING: Objection; form. 4 A. I'd say that I generally agree with this and just go 5 on to say that it is my understanding that asbestos-containing 6 material, such as insulation -- asbestos-containing insulation, 7 were not really thought to be a concern even in the scientific 8 community until the mid 1960s when Irving Selikoff did his 9 work. 10 Q. (BY MR. SKAGGS) In the mid 1960s when Dr. Selikoff 11 spoke at his convention, he was correlating the disease of 12 mesothelioma with asbestos exposure; is that right? 13 MR. MANNING: Objection; form. 14 A. I don't think at that time it was mesothelioma. I 15 think it was lung cancer. 16 Q. (BY MR. SKAGGS) But specifically dealing with 17 pulmonary fibrosis, Mobil wouldn't have had a concern in the 18 1930s of their employees developing Mobil -- pulmonary 19 fibrosis? 20 MR. MANNING: Objection; form. 21 A. Let me answer it this way. Since the 1930s, Mobil 22 conducted yearly chest X-rays basically on its employees. And 23 through that period of time, at least until the 1960s, and even 24 1970s, there was not to be -- there was not thought to be an 25 incidence of pulmonary fibrosis in the employees that were Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003937 BRUCE LARSON Page 77 1 handling insulation. So through medical surveillance, there 2 was no - - there was not thought to be any health effect. 3 Q. (BY MR. SKAGGS) Do you recall any report of a severe 4 asbestosis or pulmonary fibrosis when you were employed at 5 Mobil by one of its employees? 6 MR. MANNING: Objection; form. 7 A. I don't recall any cases like that. 8 Q. (BY MR. SKAGGS) Did that question make sense? I 9 might have flubbed it a little bit. 10 Did any employee from Mobil, that you know of. 11 make a claim to Mobil or report to Mobil about pulmonary 12 fibrosis or acute asbestosis? 13 MR. MANNING: Objection; form. 14 A. Not that I'm aware of. 15 Q. (BY MR. SKAGGS) Is there a level to asbestos 16 exposure that you would consider safe? 17 A. Yes . 18 Q. What level is that? 19 A. It depends on the level as well as the duration of 20 exposure . And I think right now the level that is in place 21 that the government has established is .1 fibers per cc for a 22 40-hour work week for a 40-year lifetime. 23 Q. Do you think that is safe? 24 A. The government has essentially established that as 25 the regulatory limit, so I'll defer to the government on that. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003938 BRUCE LARSON Page 78 1 Q. But I mean, in your own personal opinion, do you 2 think -- 3 A. I would think so. If I had a son or daughter that 4 was working in a workplace where the exposures were maintained 5 below .1, I'd feel perfectly comfortable with that. 6 Q. How about 5 million particles per cubic foot; is that 7 at a safe level? 8 MR. MANNING: Objection; form. 9 A. That's not the standard that is in effect now. At 10 one time it was and it was thought to be safe. 11 Q. (BY MR. SKAGGS) But it obviously wasn't a safe 12 level? 13 A. I guess I can't answer that because I didn't 14 establish that level, but I guess in today's environment you 15 would say , no, that is not adequate. 16 Q. Do you have an opinion that 5 million particles per 17 cubic foot is not at a safe level or is at a safe level? 18 MR. MANNING: Objection; form. 19 A. I think at the time it was established it was 20 believed to be safe, but I think today we would have to say it 21 is not. 22 Q. (BY MR. SKAGGS) Do you say it is not? 23 MR. MANNING: Objection; form. Do you mean 24 today? 25 MR. SKAGGS: Yes. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003939 BRUCE LARSON Page 79 1 A. Like I said, I didn't establish the limit. The 2 people that are responsible for establishing limits, obviously, 3 believe that the level is lower now. It's been set lower. And 4 obviously, you know, it is a much lower standard today than it 5 was then, so there is a reason for concern. So I'd say, yeah, 6 I would say that it was lowered for a reason. 7 Q. (BY MR. SKAGGS) In your mind, what was that reason 8 why it was lowered? 9 MR. MANNING: Objection; form. 10 A. I think over time as more information was known of 11 asbestos and the types of health effects that it could cause 12 that people gained enough information from studies -- both 13 clinical studies and epidemiology studies to justify lowering 14 the level. 15 Q. (BY MR. SKAGGS) In your opinion was the level 16 lowered to protect against or to safeguard against diseases 17 like mesothelioma and lung cancer? 18 A. I think ultimately that was considered, yes. 19 Q. In your opinion, would a 5 million particles per 20 cubic foot still be a safe level to protect against a disease 21 of pulmonary fibrosis or acute asbestosis? 22 A. Actually, again, I think it relates back to the type 23 of fiber. I think some people would say that if it was 24 strictly chrysotile, that that limit could be protected. Now, 25 when you consider other types of asbestos, like amosite and Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003940 BRUCE LARSON Page 80 1 crocidolite, I think most people would say, no, that would not 2 be sufficient to -- 3 Q. Is that because chrysotile is -- for lack of a better 4 term -- cleared from the lungs more easily that the other 5 fibers ? 6 A. I think that's a generally yes. 7 Q. Have you read that before? 8 A. Yes . 9 Q. Was that Mobil's knowledge at the time? 10 A. I can't say. 11 Q. Did Mobil always follow the ACGIH standard or the 12 OSHA standard, TLV standard? 13 A. Correct. 14 Q. Was there ever a time when you guys had a meeting and 15 the topic discussed was, I think we need to lower the standard. 16 the government is wrong? 17 MR. MANNING: Objection; form. 18 A. Not that I'm aware of. 19 Q. (BY MR. SKAGGS) Did that ever come across in your 20 memory or anybody's memory that you should question the 21 standards set up by the government? 22 MR. MANNING: Objection; form. 23 A. We relied on the government as primary source of -24 we also --- and this applies not only to asbestos but for other 25 materials that we used -- we relied on either the government or Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003941 BRUCE LARSON Page 81 1 the manufacturer to make recommendations, just as we did for 2 our products. We would publish material, safety data sheets 3 that recommend limits. So we relied on the government or the 4 manufacturer, and we would follow the lowest recommended level, 5 whether it be from the manufacturer or the government. 6 Q. (BY MR. SKAGGS) Do you remember any manufacturer of 7 asbestos-containing material recommending a lower TLV than the 8 government standard? 9 A. Not that I recall. 10 Q. Do you remember any kind of recommendation regarding 11 TLV levels from the product manufacturer? 12 A. By the time I was with Mobil, OSHA was in effect and 13 we relied primarily on OSHA. 14 Q. How about before OSHA, any kind of recommendations 15 from the product manufacturer for the TLV? 16 A. I can't speak personally to that, but it would be my 17 understanding that Mobil would have followed, again, either the 18 manufacturer's recommendation or the government's, whichever 19 was lower. 20 Q. But you just don't remember them recommending a 21 certain level -- a product manufacturer recommending a certain 22 level? 23 A. Not personally, no. 24 Q. Did a product manufacturer ever warn you that their 25 product -- or tell you that their product contained asbestos? Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003942 BRUCE LARSON Page 82 1 MR. MANNING: Objection; form. 2 A. I would say, yes. 3 Q. (BY MR. SKAGGS) Do you remember who that product 4 manufacturer was? 5 A. Certainly after about -- I think in 19 -- I've seen 6 material safety data sheets that were published by 7 Johns-Manville as early as 1968 that warned their customers 8 about asbestos. That's just from looking at historical 9 documents. So that's really all I'm familiar with is what I've 10 seen there. 11 Q. Do you have an understanding that these material 12 safety data sheets were ever disseminated to the employees of 13 Mobil? 14 A. I would say if Mobil received -- yes, absolutely. 15 Q. Do you have personal knowledge that the material 16 safety data sheets were disseminated to Mobil employees? 17 A. Yes, I do. But you need to establish a time frame, 18 too. 19 Q. In 1968, when you remember Johns-Manville, or you saw 20 something that Johns-Manville material safety data sheet from 21 Johns-Manville, do you have personal knowledge that sheet was 22 disseminated to Mobil employees? 23 A. I don't -- the document I saw was a generic material 24 safety data bulletin that was -- that I had seen, had just 25 general background information on the asbestos that I reviewed. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003943 BRUCE LARSON Page 83 1 I don't know that Mobil even specifically received that data 2 sheet. So I really can't answer that. 3 Q. When did Mobil establish safety guidelines for 4 handling asbestos-containing material? You might have answered 5 me already, but if you could repeat it for me I would 6 appreciate it. 7 A. The earliest programs I have seen just from reviewing 8 historical documents is that Mobil had procedures in place for 9 handling insulation materials at least as early as 1952. 10 Q. Did you say "handling asbestos -containing materials" 11 or just "materials"? 12 A. Handling insulation materials including 13 asbestos -containing insulation. 14 Q. Do you recall if these safety procedures said 15 "asbestos" or just said "materials"? 16 A. Well, they refer to insulation and they refer to 17 various types of insulation. I don't know if they specifically 18 mention asbestos. I think they mentioned mineral insulations 19 which generically could encompass asbestos-containing 20 insulation. 21 Q. Where did you see these documents? 22 A. It was in the Beaumont safety manual -- Beaumont 23 refinery 24 Q. Did the Beaumont refinery have a library out there? 25 A. I believe they did, yes. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003944 BRUCE LARSON 1 Q. Do they still have one? Page 84 2 A. I would believe they do, yes. 3 Q. Does this have all their safety sheets as early as 4 1952 located at this library? 5 A. I don't know if the refinery itself still maintains 6 those various documents. It may just -- it may have just the 7 more current ones, I don't know. I have reviewed a copy of the 8 1952 manual. 9 Q. When you were employed by Mobil or lately? 10 A. Later. In the last 18 months. 11 Q. Why? 12 A. To review Mobil's past safety and health practices. 13 Q. Did a lawyer from DeHay & Elliston give that to you? 14 A. Probably. 15 Q. Do you still have it? 16 A. I don't know if I have a copy or not. I may. I may. 17 It is possible. 18 Q. Did Mobil have the knowledge of the hazards 19 associated with asbestos exposure starting in 1952? 20 MR. MANNING: Objection; form. 21 A. I think that there was some recognition of the 22 hazards of asbestos as early as -- actually, even before 1952 . 23 Q. (BY MR. SKAGGS) How early would you say? 24 A. I would think probably there was scientific 25 literature available as early as the 1930s, but again, we Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003945 BRUCE LARSON Page 85 1 already talked about that. That was primarily for the textile 2 and asbestos mining industries, and we really didn ' t associate 3 that with asbestos-containing insulating materials until the 4 mid 1960s when the Selikoff studies came out. 5 Q. Did Mobil ever produce anything similar to the Bonsib 6 Report ? 7 A. Did Mobil? No, not Mobil. That was an Exxon 8 document. 9 Q. Did Mobil produce anything similar to that as early 10 as the Bonsib Report? 11 MR. MANNING: Objection; form. 12 A. I'm not familiar with anything. 13 Q. So Exxon was ahead of its times compared to Mobil? 14 MR. MANNING: Objection; form. 15 A. No, I wouldn't say that. 16 Q. (BY MR. SKAGGS) Why wouldn't you say that? 17 A. I would say that historically from what I've seen and 18 from what I've read that Mobil and Exxon's health and safety 19 programs have pretty well tracked each other in terms of their 20 degree of sophistication through the years. I mean. they were 21 initially part of the standard oil group and many of the 22 policies and procedures as it relates to safety and health were 23 very similar between the two companies. 24 Q. Was the Bonsib Report ever disseminated to the Mobil 25 Corporation? Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003946 BRUCE LARSON Page 86 1 MR. MANNING: Objection; form. 2 A. I don't know. It may have. It may not be. I know 3 that there is a paper from one of Mobil's first industrial 4 hygienist that was published in the '50s that acknowledges 5 asbestos as a potential hazard. So certainly in the ' 50s there 6 was at least some appreciation. 7 Q. (BY MR. SKAGGS) Who was that first industrial 8 hygienist ? 9 A. Arthur Pabst, P-A-B-S-T. 10 Q. Like the beer? 11 A. Right. 12 Q. And what kind of hazards did it relate to -- cancer 13 or just general hazards? 14 A. Asbestosis. 15 Q. When did the Bonsib Report come out -- Exxon 's Bonsib 16 Report ? 17 A. I believe it was 1937. 18 Q. Fifteen years before Mobil produced anything ? 19 A. Well, I'm just saying from the documents that I' ve 20 reviewed there was a 1937 Bonsib Report and a 1950 era Art 21 Pabst report. That doesn't mean that something couldn 't have 22 been published prior to that within Mobil. 23 Q. But from what you reviewed, there was 15 years 24 between the Bonsib Report and what -- the earliest you ' ve seen 25 in Mobil? Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003947 BRUCE LARSON Page 87 1 A. From the documents I have reviewed, that's correct. 2 Q. But you don't consider Exxon ahead of its times 3 compared to Mobil? 4 A. No. 5 Q. The Mobil procedure that you referred to that began 6 in 1952 -- I'm just using that date. I don't know if we 7 established exactly that day. 8 A. Okay. 9 Q. What did it say about handling asbestos? 10 A. Well, it required that respiratory protection be worn 11 whenever the insulation was being handled or cut, and then when 12 cutting in it in the pipe shop at the refinery, that local 13 exhaust ventilation was required. I have seen other 14 references, and I think at least one other deposition that I 15 have read that they also required wet methods. 16 Q. For the removal of the insulation? 17 A. For the removal. And they specify the types of 18 respiratory equipment to be worn. Specifically, the MSA 19 COMFO-II respirator, C-O-M-F-O, Roman Numeral 2. 20 Q. Was this specific to insulators or was it for all 21 crafts ? 22 A. It was specific to -- I think I would have to say it 23 was probably specific to insulators. 24 Q. So if an insulator worked for Mobil and was removing 25 asbestos as early as 1952, he should been wearing an MS COMFO Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003948 BRUCE LARSON 1 mask? Page 88 2 A. Correct. 3 Q. How about contractor insulators? Was this 4 information given to them? 5 A. As far as I can determine from reading the historical 6 documents and from people that I have talked to, Mobil has 7 consistently had a policy that contractors followed the same 8 safety and health rule that Mobil employees have. Typically, 9 Mobil would meet with the contractors prior to them beginning a 10 job and review Mobil safety and health procedures with them, 11 and of course, later when OSHA came along -- and even back in 12 the 50s, there was Walsh-Healy in place. That was forerunner 13 to OSHA. 14 Mobil's police was that you would follow 15 applicable government regulations or the company safety and 16 health procedures. So that would be reviewed with the 17 contractor, and typically there would be a company contact 18 assigned to each contractor that was on Mobil premises and they 19 would be responsible for making sure the contractor knew his 20 obligations under our procedures and any applicable 21 regulations, and he would periodically audit their work to make 22 sure that they were complying. 23 Q. When I read your last deposition with Denman Heard, 24 he said that some of the larger contractors Exxon would just 25 kind of leave alone. Was that the same policy that Mobil had? Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003949 BRUCE LARSON Page 89 1 A. Well, Brown & Root, specifically, I think I mentioned 2 that they had their own full-time safety and industrial hygiene 3 personnel. and once we were comfortable with the way that they 4 were managing their projects, in many cases we would let them 5 basically handle their own program. 6 Q. But Brown & Root never worked out in Mobil Beaumont? 7 A. They did. 8 Q. They did? 9 A. Yes . 10 Q. Not in the '50s and '60s. 11 A. I don't know about that. They may have. 12 Q. I say that jokingly because you know Brown & Root is 13 a nonunior shop? 14 A. Well, they have a union side, though. 15 Q. Yes. Mid valley. Did Mid Valley work out at Mobil? 16 A. I don't know. I really can't say. 17 Q. So Mobil, if it was a large industrial contractor. 18 like Browr & Root, that worked at their facilities, they would 19 not monitor them as closely as a smaller contractor? 20 A. Well, in practical terms that is true, but we would 21 have to feel comfortable with the way they were handling their 22 project. 23 Q. Mobil always followed -- you told me Mobil always 24 follows the lower of either the ACGIH standard or the product 25 manufacturer standard or some country standard; is that what Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003950 BRUCE LARSON 1 you told me? Page 90 2 A. Correct. 3 Q. How about the state's TLV? 4 A. Yes. That would come into consideration if it 5 existed. 6 Q. Do you know if Texas ever had a threshold limit value 7 for asbestos? 8 A. I believe they did. 9 Q. Do you know when that came into effect? 10 A. I think it was sometime either in the late 1950s or 11 early 1960s. 12 Q. That would require some kind of air monitoring to 13 determine the threshold limit value of the workers being 14 exposed to asbestos; is that correct? 15 MR. MANNING: I'm just going to object. I'm not 16 sure what threshold limit value may have been or PEL, but just 17 so we are clear that you are talking about whatever limit it 18 is . 19 Q. (BY MR. SKAGGS) It would require some kind of air 20 monitoring at whatever limit it was? 21 A. I would think that is probably true, yes. 22 Q. If it was 5 million particles per cubic foot back in 23 1957, that would require some kind of air monitoring to make 24 sure Mobil was following that standard? 25 A. I think so. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003951 BRUCE LARSON Page 91 1 Q. Did Mobil begin air monitoring back in 1957? 2 MR. MANNING: Objection; form. 3 A. I'm not sure what data they collected back then. 4 though I have seen air monitoring data in the early 1960s that 5 was done at the Beaumont refinery. But to answer -- that's the 6 data that I have seen. I don't know what, if any, data was 7 collected prior to that. 8 Q. (BY MR. SKAGGS) The earliest data that you have seen 9 is the early 1960s? 10 A. That's correct. 11 Q. You haven't seen anything from '57 to early 1960s? 12 A. No, I haven't personally seen that. 13 Q. You don't know plaintiff Mr. Benoit, do you? 14 A. No. 15 Q. Did you read his deposition? 16 A. This is what, the Carr case? 17 Q. Yes, sir. 18 A. I believe I did. 19 Q. He was the sandblaster/painter that worked at Mobil? 20 A. Correct. 21 Q. Did you ever read his medical diagnosis? 22 A. I saw something from -- just one-page reports from 23 two different doctors but nothing more extensive than that. 24 Q. Do you have an understanding that he was diagnosed 25 with esophageal cancer? Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003952 BRUCE LARSON Page 92 1 A. It was referred to as throat cancer in the document 2 that I saw. 3 Q. You say potato (pronouncing) and I say potato 4 (pronouncing). 5 A. Okay. 6 Q. Do you have an opinion if -- you personally have an 7 opinion if asbestos can contribute to throat cancer? 8 MR. MANNING: Objection; form. 9 A. Do I have an opinion? Yes. 10 Q. (BY MR. SKAGGS) What is that? 11 A. It would be no. 12 Q. Can you point me to any literature that would provide 13 the basi s for your opinion? 14 A. Well, I think there is quite a bit of established 15 literature that would relate to the cause of his cancer. 16 Q. No. I'm sorry. I might have phrased my question 17 wrong. 18 Can you point me to any literature that says 19 asbestos does not contribute or is not significant in the 20 contribution to throat cancer? 21 A. I personally could not, but I think a medical doctor 22 or epidemiologist could better answer that question. 23 Q. Besides reading Mr. Benoit's deposition -- that's 24 B-E-N-O- I-T -- what else did you review to prepare for today? 25 A. Well, I have -- historically, I have seen many Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003953 BRUCE LARSON Page 93 1 documents. For example, this 1952 Beaumont refinery safety 2 manual, I have reviewed depositions from many of Mobil's 3 industrial hygiene safety personnel, I have reviewed asbestos 4 exposure monitoring data, I have reviewed studies that OSHA and 5 NIOSH have conducted in Mobil's refineries, specifically for 6 asbestos. It is fairly extensive. I have reviewed the 7 literature in terms of the chronology of asbestos regulation, I 8 have reviewed epidemiology studies. 9 Q. Just kind of an ongoing thing to keep updated? 10 A. Right. I have reviewed studies such as Selikoff's, I 11 have reviewed the Bonsib Report from -- that was generated 12 within Staterol (phonetic). New Jersey. So quite a bit. 13 Q. Is a sandblaster a craft that you would consider has 14 potential for asbestos exposure? 15 A. I would say generally, no. 16 Q. Did you read the part of Mr. Benoit's deposition 17 where he said he was exposed to asbestos by blasting pipe 18 insulation off of pipes? 19 A. Yes, I did. 20 Q. Does that disturb you as an industrial hygienist - 21 that behavior at that job? 22 MR. MANNING: Objection; form. 23 A. Well, first of all, that's generally not a practice 24 that happens in the industry, and quite frankly I know because 25 I have been sandblaster. But generally, insulation is shielded Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003954 BRUCE LARSON Page 94 1 with sheet metal covering, and in some cases it may not be. 2 But as a practice as a sandblaster, you would want to protect 3 that insulation by using a shield to keep the abrasive from 4 contacting the insulation because essentially you are ruining 5 perfectly good insulation by blasting it. 6 Q. But if a pipe was being removed and taken to the drop 7 yard -- the sandblasting yard to be painted and still had some 8 insulation on it, it is not uncommon for a blaster to blast 9 that off. 10 A. If it had insulation on it, it wouldn't be painted. 11 So from a practical standpoint, I wouldn't see that happening. 12 Q. You don't have any I instances of a sandblaster 13 blasting off pipe insulation? 14 A. Not in my experience. It would -- first of all, you 15 would not intentionally ever want to do that. Secondly, as I 16 mentioned previously, most insulation is shielded with a metal 17 jacket. If for some reason it wasn't shielded, you would 18 then -- standard practice would be to use a shield to keep the 19 abrasive blasting from destroying the insulation. I mean, it 20 is just the way it is done. 21 Q. Well, let's assume it happened. Let's assume 22 Mr. Benoit blasted pipe insulation off pipe insulation. Would 23 that behavior disturb you as an industrial hygienist? 24 MR. MANNING: Objection; form. 25 A. It is hypothetical, but as an industrial hygienist, I Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003955 BRUCE LARSON Page 95 1 don't know if it would be a major concern because dating back 2 to the 1950s, when you sandblast you use a type C air supply 3 hood -- so from the silica hazard. And obviously Mr. Benoit 4 must have used his protective equipment because, as far as I 5 know, he has no indication of silicosis. So he hasn't had any 6 sufficient exposure to dust in his work environment. 7 Q. (BY MR. SKAGGS) Is it your testimony that a 8 sandblaster always wore some kind of air-tight hood while 9 blasting at a Mobil facility? 10 A. 11 Q. 12 Let's say he just barely has a hood on and he's 13 blasting 14 industri 15 MR. MANNING: Objection; form. 16 A. Can you repeat that? 17 Q. (BY MR. SKAGGS) Sure. Assume Mr. Benoit doesn't 18 have an 19 hood. 20 A. You are talking about a desert hood? 21 Q. Desert hood. I forgot I'm talking to a sandblaster. 22 A. Yeah. 23 Q. Let's assume Mr. Benoit is wearing a desert hood, and 24 he is bl 25 insulati Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003956 BRUCE LARSON 1 as an industrial hygienist? Page 96 2 MR. MANNING: Objection; form. 3 A. Well, first of all, he wouldn't be permitted to use a 4 desert hood in a Mobil facility. So that's the first point I 5 would make. And secondly, again, I don't think he would be 6 permitted to blast perfectly good insulation. And thirdly, if 7 there was insulation, there was probably at least a 90 percent 8 chance that it would be jacketed with metal. So throw all 9 three factors in there, and it just simply wouldn't happen. 10 Q. But you're adding factors to my hypothetical. Just 11 use my hypothetical. 12 A. You are talking hypothetical, and I'm talking 13 reality. 14 Q. I want to use what Mr. Benoit testified to. He 15 testifies to blasting pipe insulation off of pipe. That was 16 not a very safe practice, is it? 17 MR. MANNING: Objection; form. 18 A. Well, again, obviously, it wouldn't be a good 19 practice from either a safety standpoint or from a craft 20 standpoint. That's essentially all I can say about it. 21 Q. (BY MR. SKAGGS) You would imagine if he was blasting 22 pipe insulation off a pipe, there would be a large amount of 23 friable asbestos in the air? 24 MR. MANNING: Objection; form. 25 A. Not necessarily. I mean, asbestos-containing Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003957 BRUCE LARSON Page 97 1 insulation is one of many types of insulation. Again, you have 2 fiberglass, you have mineral wool, you have ceramic fiber. In 3 general terms, in our refineries asbestos-containing insulation 4 during that time frame would be probably less than 30 percent 5 of the insulation that was even present. So you can't assume 6 you would have friable asbestos even if he had sandblasted 7 insulation. Is it a possibility? It is a possibility, but it 8 is not even a probability. 9 Q. (BY MR. SKAGGS) If he was one of the unlucky few 10 that fell into the 30 percent, he found a pipe insulation that 11 was one of the 30 percent that contained asbestos at a Mobil 12 facility? 13 A. Again, you have that factor, you have the factor that 14 it was most likely covered with a metal jacket, you have 15 another factor that he was instructed not to blast exposed 16 insulation, and you have the fact that he would be required to 17 wear an air-supplied hood. That's reality. 18 Q. So Mobil never did -- assume for me he performed this 19 behavior on a Mobil facility, and Mobil never told him to stop. 20 Mobil would be somewhat negligent if they didn't tell him to 21 stop; is that right? 22 MR. MANNING: Objection; form. 23 A. I see the likelihood of that happening as essentially 24 being zero. 25 Q. (BY MR. SKAGGS) Assume for me it was happening and Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003958 BRUCE LARSON 1 Mobil didn't do anything to stop him. Page 98 2 MR. MANNING: Objection; form. 3 A. I guess you can take your hypothetical to whatever 4 extreme you want to, and I don't know how to answer. I mean. 5 that would be extremely unlikely is all I can say. 6 Q. And extremely unreasonable on Mobil's behalf. right ? 7 MR. MANNING: Objection; form. 8 A. I suppose. 9 Q. (BY MR. SKAGGS) What crafts did Mobil deem to have a 10 potential for asbestos exposure? 11 MR. MANNING: Objection; form. 12 A. Well, basically we automatically assumed back in 13 those days that if you were an insulator, no doubt about it. 14 Now, obviously, other crafts from time to time could come into 15 contact with asbestos-containing materials, and that could 16 include people that were in the labor pool, it could include 17 people that were pipefitters, and even boilermakers. So that 18 would be the obvious job classifications. We would not 19 typically include sandblasting in that category for the reasons 20 I have just outlined. 21 Q. And those reasons were he was required to wear an 22 air-vented hood -- 23 A. Right 24 Q. -- and he would not be blasting pipe insulation -- 25 A. Exposed asbestos-containing insulation. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003959 BRUCE LARSON Page 99 1 Q. Did Mobil perform air monitoring on laborers. 2 pipefitters and boilermakers? 3 A. I'm sure at some point they did, yes. 4 Q. When you say you're sure, it sounds like you don't 5 remember -- 6 A. I know that I've seen data. I've seen data. 7 Q. Was it more common to air monitor insulator's work 8 environment than a boilermaker's work environment? 9 A. In general, yes. 10 Q. Did Mobil hire insulators out at the asbestos local 11 number 22? 12 A. I think they did. I know they had, for at least some 13 time frame, they had their own insulators on site. But from 14 time to time they would. 15 Q. As a former employee of OSHA, you know about asbestos 16 workers' union local number 22? 17 A. Right. 18 Q. And their area covered the Golden Triangle, Houston, 19 and Texas City. 20 A. Right. 21 Q. Did Mobil ever appreciate the hazards -- strike that 22 question 23 Do you remember ever reading any literature 24 about potential asbestos exposure that an insulator would have 25 brought home to his wife and children? Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003960 BRUCE LARSON Page 100 1 MR. MANNING: Objection; form. 2 A. I have seen some literature, yes. 3 Q. (BY MR. SKAGGS) What does that literature say? Do 4 you remember? 5 A. What I take away from that is that it is a potential 6 source of exposure in the home. 7 Q. And, in fact, most of the studies about how home 8 exposure or household exposure were insulators or shipyard 9 workers; is that not true? 10 A. I think that's true. 11 Q. Did Mobil ever tell the wives of their insulators 12 that there is potential for asbestos exposure? 13 MR. MANNING: Objection; form. 14 A. I think they did. I'm not exactly sure when that may 15 have started, but I know at the time that I was there, that 16 that information was conveyed. 17 Q. (BY MR. SKAGGS) How was it conveyed? 18 A. In training materials and safety meetings. That type 19 of thing 20 Q. To the spouses or to the insulators themselves. 21 A. Let me back up and little bit. Beginning in the -- 22 actually , before I even came to work for Mobil, the OSHA 23 asbestos regulations were in effect, and virtually 100 percent 24 of all i nsulating work beginning in the 1970s was done through 25 outside contractors because they were really the ones that had Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003961 BRUCE LARSON Page 101 1 the expertise and the training to handle asbestos. So I don't 2 know that we really had any employees, at least in the time 3 that I was there, that were doing insulating work. 4 Q. But there were some Mobil insulators before you got 5 there; is that your understanding? 6 A. This is my understanding. 7 Q. I believe my question was: How did you -- or you 8 answered how -- but did you disseminate the information of 9 potential asbestos exposure to the spouses of insulators to the 10 spouses themselves or to the insulators to take home? 11 A. Like I say, the time that I was there, virtually all 12 the insulating work was done by contractors. At that point in 13 time these people -- the companies were fully aware of the 14 hazards, and that's why we actually contracted with them 15 because they were the professionals at remediation and 16 abatement. So we would not have really had a direct role in 17 training those employees except to say. This is what we need to 18 have done. It contains asbestos. Follow appropriate safety 19 precautions. 20 Q. You are testifying to as when you were employed by 21 Mobil? 22 A. Correct. 23 Q. Before you were employed by Mobil, did Mobil take 24 efforts to warn any Outside-contractor insulator spouses about 25 the potential harm of asbestos exposure? Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003962 BRUCE LARSON 1 A. I don't know. Page 102 2 Q. Let me see if I can make sense of some of these notes 3 and I think I'm going to wrap up very quickly. Okay? 4 Would you like a break? 5 A. I'm okay for now. 6 Q. Mobil would control or take responsibility for the 7 safety procedures of certain smaller contractors that worked at 8 their facility; is that right? 9 A. Direct control, no. But we would make sure that they 10 were aware of the potential hazards that they might encounter 11 in their work, and we'd also make sure they were aware of our 12 internal safety and health procedures and any applicable 13 government regulations. So we would make sure that their 14 supervisors were thoroughly aware of those requirements. And 15 from time to time, again, we would audit what they were doing. 16 Q. Did Mobil employees have the power to kick a smaller 17 contractor off if they weren't following the safety procedures? 18 A. Well, if the problem was observed, they would be 19 warned. If they corrected it, fine; if they didn't correct the 20 situation, then yes, they could be terminated. 21 Q. Do you recall any instances of that happening when 22 you were employed at Mobil? 23 A. I think on several occasions we did actually warn a 24 contractor, as I recall, but I'm not familiar with anytime that 25 we had to actually ask a contractor to leave the site. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003963 BRUCE LARSON Page 103 1 Q. Do these warnings have anything to do with asbestos 2 exposure or was it something else? 3 A. I don't think it was asbestos. I think it was 4 something else . 5 Q. So Mobil had nothing personally to do with the 6 training of some of the smaller contractors out there in their 7 safety standards or anything like that? 8 A. I think, as I recall, occasionally we helped the 9 contractor develop a training program, but they actually 10 presented it to the employees. So from time to time, yes, we 11 would have some input into the training program but not 12 actually the hands-on training. 13 Q. Where would the cutoff be between a corporation that 14 you would assist and one that you wouldn't assist? 15 A. Obviously, larger contractors, like Brown & Root, 16 there is no question of that at all. It would depend on 17 case-by-case review of the sophistication of the contractor. 18 We'd review their safety and health procedures. we would review 19 ours with them, and if there was any type of a discrepancy 20 between what we felt they had and what our program was, then 21 that's where we would try to fill in the gap. 22 Q. Was a sandblaster contractor a type of corporation 23 that Mobil would assist in their safety policies and 24 procedures ? 25 A. Again, it would be a case-by-case review. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003964 BRUCE LARSON Page 104 1 Q. Do you recall any large industrial sandblaster that 2 you guys didn't have help or assist? 3 A. I'm sorry? 4 Q. That was a bad question. Let me ask you this way: 5 Was there any a time where a large industrial sandblasting 6 contractor came with their own safety personnel and procedures. 7 that you recall? 8 A. I think I recall from a couple of shutdowns where 9 Brown & Root did have a sandblasting crew on site, so the 10 answer would be yes. 11 Q. Did you ever have any interactions with Mr. Benoit's 12 employer when he was out at Mobil? 13 A. Can you refresh my memory who his employer was? 14 Q. I believe he said it was Gary's Sandblasting. 15 A. Gary's? Not specifically, no. 16 Q. Would that be a type of corporation that you would 17 consider unsophisticated? 18 MR. MANNING: Objection; form. 19 A. I can't really give you an opinion sitting here. I'd 20 have to sit down with the personnel and take a look at their 21 safety and health procedures and make a decision based on that 22 information. 23 Q. (BY MR. SKAGGS) And you might disagree with me. I 24 have been doing this for a while now and I presented many 25 sandblasters and most -- would you agree with me that most Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003965 BRUCE LARSON Page 105 1 sandblasting contracting companies that purely did sandblasting 2 were of the smaller-type corporations? 3 A. I think there are small contractors and there is 4 large contractors and there is medium contractors, and 5 certainly, there is probably quite a few of each. Now, how 6 much gets done, I would imagine that Brown & Root probably does 7 as much sandblasting as 80 percent of the companies that have 8 10 employees or less, but I'm sure there is various types and 9 sizes. And I don't know necessarily that the size determines 10 the sophistication, especially when it comes to a specialty 11 like sandblasting. I mean, you have had ANSI standards as 12 early as the 1950s that required air-supplied hoods. You have 13 had -- for even a small company to get workman's comp insurance 14 coverage, they would be subject to insurance company reviews 15 that would insure that they were wearing the proper equipment 16 for the job, and even small employers are typically members of 17 trade associations. So I can make no distinction based on size 18 of the sophistication of the company. 19 Q. It is your opinion that a sandblasting corporation 20 would have always used air-vent hoods beginning in the 1950s? 21 A. It is my understanding that -- yes. 22 Q. But that's merely in the sandblasting operation 23 itself. It has nothing to do with blowdown or anything like 24 that, right? 25 MR. MANNING: Objection; form. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003966 BRUCE LARSON Page 106 1 A. Based on my experience and everything I believe to be 2 true is what typically would happen is, during the actual 3 blasting operation they would wear the air -- the Type-C 4 air-supplied hood, and after that, they would either wear a 5 dust respirator like the MSA COMFO II or possibly a 3M 8710 for 6 cleanup and blowdown. 7 Q. Remind me, Mobil required blasters to wear the MSA 8 COMFO II; is that right? 9 MR. MANNING: Objection; form. 10 A. Mobil's own employees, yes. But I can't say that we 11 required our contractors to use that specific type. But 12 certainly we would want one that was NIOSH approved for 13 pneumoconiosis-producing dust. 14 Q. (BY MR. SKAGGS) That would be required of all 15 contractors out there -- sandblasting contractors? 16 A. Correct. 17 Q. Would a sandblaster have a potential for bystander 18 exposure to asbestos? 19 A. Highly unlikely. When a sandblaster is in a unit 20 blasting or painting, that area would be basically cordoned off 21 just for contamination purposes. And also, you don't want 22 bystander exposure to the silica sand that's produced when he 23 is blasting. 24 So in my experience, all those operations were 25 isolated. I guess you are implying there might be some Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003967 BRUCE LARSON Page 107 1 insulators working with the sandblasters, but in my experience 2 that would never be the case. 3 Q. Mr. Benoit testified as to insulators working around 4 him somewhere between the range of 50 to 100 to 150 feet. Is 5 that something that you remember occurring or is that something 6 different than you remember? 7 A. That seems like it would be a little bit close, but 8 I'm sure it is possible that at some point they could be 9 possibly that close, say, when he was finished blasting and he 10 was in the area cleaning up or blowing down, it's possible that 11 they might then come in and do some work; however, again, it 12 would be a requirement that he wear a dust respirator during 13 cleanup or blowdown. So I don't think that presents a risk. 14 Again, it is medical fact that he does not display any systems 15 of silicosis and it is pretty obvious to me that he did follow 16 protective measures or he would display symptoms -- if he did 17 this for an entire career. 18 Q. And you are basing your belief that he followed all 19 the OSHA regulations and always wore an air hood solely on the 20 fact that he doesn't have silicosis? 21 A. Well, it is also on his deposition. Because he 22 states that he wore a hood and he wore a respirator. 23 Q. Just some final thoughts here and then I think we 24 will be done. 25 When is it your belief that an acceptable Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003968 BRUCE LARSON Page 108 1 substitute for asbestos thermal insulation became available for 2 Mobil's use? 3 A. I think there were some asbestos-free insulating 4 materials available I think beginning around 1972, and over 5 time more and more materials became available. For example, 6 like welding blankets, eventually fiberglass was used in place 7 of asbestos-containing fire blankets. I think even today, 8 though, there are some gaskets that still require asbestos for 9 the temperature range they are used in. 10 So over time various substitutes have become 11 available but not for every single application. 12 Q. But for thermal insulation you believe that an 13 acceptable substitute began in 1972? 14 A. For some temperature ranges, not all. In fact, I'm 15 not sure -- I may be wrong -- but I'm not sure that there are 16 some temperature ranges even today that asbestos-containing 17 insulation is still being used. 18 Q. Was that -- have you ever heard the brand name Carry 19 Free ? 20 A. Yes. That was one of the earliest ones. I think 21 that became available in the early 1970s. 22 Q. Or late 1960s. 23 A. Possibly. That was the pinkish-colored insulation? 2 4 Q. That's correct. 25 A. Right. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003969 BRUCE LARSON Page 109 1 Q. What goes through a corporation like Mobil -2 actually , what goes through Mobil's thought process to 3 determine if a substitute is feasible for asbestos-containing 4 products 7 5 MR. MANNING: Objection; form. 6 A. Is essentially a review of the temperature range of 7 the process and if the asbestos-free insulation can meet that 8 temperature range, then it would be used. That's the bottom 9 line. 10 Q. (BY MR. SKAGGS) That's it? 11 A. Yes . 12 Q. Nothing had to do with cost of the substitute 13 compared to the insulation? 14 A. Not for that program, no. You had to consider the 15 cost of complying with the OSHA regulations and not only OSHA, 16 but EPA regulations of a facility that contained asbestos 17 products because that added cost. So generally cost of the 18 substitute was not a consideration. 19 Q. Let me go through a couple of things here, and I 20 think we will be done. Okay? 21 A. Good. 22 Q. I know I've been unbearable, haven't I? 23 A. No, no. It is just a long day. 24 Q. I understand. 25 Mr. Larson, do you have any evidence or can you Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003970 BRUCE LARSON Page 110 1 provide any testimony that Mr. Benoit contributed to his own 2 injuries? 3 MR. MANNING: Objection; form. 4 A. I have read in his medical report that he was a 5 three-pack-a-day smoker for 50 years, and so I would just make 6 that statement. 7 Q. Anything else? 8 MR. MANNING: Objection; form. 9 A. I guess not. 10 Q. (BY MR. SKAGGS) If Mr. Benoit was exposed to 11 asbestos- containing materials at Mobil facility, was his 12 exposure considered an unavoidable accident or something that 13 just came a part of the normal work process? 14 MR. MANNING: Objection; form. 15 A. I don't know if I really understand that question. 16 If he was exposed to asbestos? 17 Q. (BY MR. SKAGGS) In the manner that he testified to 18 in his deposition. 19 MR. MANNING: Objection; form. 20 A. You said it was an unavoidable accident or what was 21 the other part ? 22 Q. Just a normal work occurrence? 23 A. Well, it definitely wouldn't be a normal work 24 occurrence. So you are asking me a hypothetical? 25 Q. (BY MR. SKAGGS) Yes. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003971 BRUCE LARSON Page 111 1 A. Again, we have gone through this a lot, but if I had 2 to choose , which really doesn't make a lot of sense to me, but 3 it I had to choose I would say it was -- would definitely have 4 to be an accident. 5 Q. Mr. Larson, I think I'm going to be finished with 6 you . I hope I wasn't too unbearable for you, and I appreciate 7 your time and I hope you enjoy the game tomorrow and you enjoy 8 your time here in Austin. 9 A. I appreciate that. 10 Q. Thank you. 11 A. Thank you. 12 13 questions ? MR. MANNING: Does anybody else have any 14 EXAMINATION 15 BY MR. MANNING: 16 Q. Mr. Larson, are you a certified industrial hygienist? 17 A. Yes, I am -- retired. 18 Q. Are you a certified safety professional? 19 A. Yes . 20 Q. Are you familiar with the industrial hygiene 21 practices for Mobil? 22 A. Yes, I am. 23 Q. Are you prepared to offer testimony and opinions 24 today concerning industrial hygiene practices? 25 A. Yes, I am. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003972 BRUCE LARSON Page 112 1 Q. In review of your -- of the epidemiological studies, 2 have you ever seen any epidemiological study that would 3 indicate there is an increased risk for any type of 4 asbestos-related condition for a sandblaster? 5 A. No. 6 Q. In your review of epidemiological studies, have you 7 ever seen in any study that there is an increased risk for any 8 asbestos-related disease for a painter? 9 A. No. 10 Q. What year did you actually work as a sandblaster? 11 A. Would have been either 1969 or 1970 when I was going 12 to college. 13 Q. There is a certain number of hazards related to 14 sandblasting. 15 A. Yes. 16 Q. Could you tell us what those hazards are? 17 A. Well, there are several types of hazards. The most 18 obvious health hazard is ventilation of silica-containing sand, 19 which can lead to pulmonary fibrosis or silicosis. You also 20 have to be concerned about physical hazards such as getting 21 sand inside your clothing or causing injury to your skin. 22 Q. If somebody got in the path of the sand that was 23 being blasted that you were blasting, it could kill them, 24 couldn't it? 25 A. It possibly could. Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003973 BRUCE LARSON Page 113 1 Q. So one of the things that -- when you were 2 sandblasting, you want to make sure that nobody is around you 3 while you are sandblasting -- just to physically keep them out 4 of the path of the sand? 5 A. Correct. 6 Q. You would also want the keep people away from you 7 while you were sandblasting because you wouldn't want them to 8 be exposed to silica dust? 9 A. That's correct. 10 Q. While you were sandblasting in 1969 or 1970, what 11 type of respiratory protection did you wear? 12 A. I wore the Type-C air-supply hood. 13 Q. Who were you working for as a sandblaster? 14 A. A company called Plastic Applicators in Houston. 15 Q. How many employees did they have? 16 A. They had -- I would estimate about 30. 17 MR. MANNING: I'm going to ask the court 18 reporter to mark this -- we don't have any exhibits, do we ? 19 MR. SKAGGS: I didn't present any. 20 MR. MANNING: -- as Exhibit 1. 21 (Exhibit 1 marked.) 22 Q. (BY MR. MANNING) Mr. Larson, when we originally 23 contacted you about giving your deposition this week, was it 24 your understanding that we were going to go forward in the 25 Husband case, correct -- Husband case and the Moss case as well Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003974 BRUCE LARSON 1 as the Carr case? Page 114 2 A. That was my understanding. 3 Q. And you were available to give your deposition 4 yesterday here in Austin? 5 A. That's correct. 6 Q. You were available for the rest of the day today to 7 give your deposition? 8 A. Correct. 9 Q. Did you review -- did we provide you materials to 10 review in the Husband case? 11 A. Yes . 12 Q. Are you prepared today to give your opinions and 13 testimony concerning the Husband case? 14 A. I am. 15 Q. And did we provide you with materials in the Moss 16 case to review? 17 A. Yes . 18 Q. And are you prepared today to give your opinions and 19 your testimony concerning the Moss case? 20 A. I am. 21 MR. MANNING: Pass the witness 22 MR. SKAGGS: Anybody else? I don't have any 23 questions 24 (END OF PROCEEDINGS) 25 Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003975 BRUCE LARSON Page 115 1 CHANGES AND SIGNATURE 2 WITNESS NAME: BRUCE LARSON DATE OF DEPOSITION: 3 PAGE LINE CHANGE REASON 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003976 BRUCE LARSON Page 116 1 I, BRUCE LARSON, have read the foregoing deposition and hereby affix my signature that same is true and correct, 2 except as noted above. 3 4 5 6 7 THE STATE OF ) COUNTY OF ) BRUCE LARSON Before me, , on this day 9 personally appeared BRUCE LARSON, known to me (or proved to me under oath or through ) (description 10 of identity card or other document)) to be the person whose name is subscribed to the foregoing instrument and acknowledged 11 to me that they executed the same for the purposes and consideration therein expressed. 12 Given under my hand and seal of office this day of , . 13 14 15 NOTARY PUBLIC IN AND FOR 16 THE STATE OF ________________ COMMISSION EXPIRES: ______ 17 18 19 20 21 22 23 24 25 Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003977 BRUCE LARSON Page 117 1 CAUSE NO. 02-CV-1169 2 EDWARD CARR, ET AL. , 3 PLAINTIFFS, 4 VS . 5 ABLE SUPPLY CO., ET AL., 6 7 DEFENDANTS. 8 9 ) IN THE DISTRICT COURT ) ) ) ) ) GALVESTON COUNTY, TEXAS ) ) ) ) ) ) 10TH JUDICIAL DISTRICT ) ) 10 REPORTER'S CERTIFICATION 11 DEPOSITION OF BRUCE LARSON SEPTEMBER 3, 2004 12 13 I, Leanna Lynch, Certified Shorthand Reporter in and for 14 the State of Texas, hereby certify to the following: 15 That the witness, BRUCE LARSON, was duly sworn by the 16 officer and that the transcript of the oral deposition is a 17 true record of the testimony given by the witness; 18 That the deposition transcript was submitted on 19 to the witness or to the attorney for the 20 witness for examination, signature and return to me by 21 22 That the amount of time used by each party at the 23 deposition is as follows: 2 4 MR. SKAGGS..............02 HOURS:31 MINUTE(S) 25 MR. MANNING........... 0 0 HOURS:06 MINUTE(S) Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003978 BRUCE LARSON Page 118 1 That pursuant to information given to the deposition 2 officer at the time said testimony was taken. the following 3 includes counsel for all parties of record: 4 FOR THE PLAINTIFFS: 5 MR. JAKE SKAGGS HEARD, ROBINS, CLOUD, LUBEL & GREENWOOD, L.L.P. 6 110 W. Southmore Pasadena, Texas 77502 7 8 FOR THE DEFENDANT: MOBIL MR. CHRISTOPHER P. MANNING 9 DEHAY & ELLISTON, L.L.P. 3500 Bank of America Plaza 10 901 Main Street Dallas, Texas 75202 11 12 FOR THE DEFENDANT: NOOTER CORPORATION MS. KELLY W. IRVIN 13 BEAN, BEAN & BROTHERS, L.L.P. Two Memorial City Plaza 14 820 Gessner, Suite 1500 Houston, Texas 77024 15 16 FOR THE DEFENDANT: GARLOCK MR. STEPHEN LEVAY 17 SEGAL McCAMBRIDGE SINGER & MAHONEY 100 Congress Avenue, Suite 700 18 Austin, Texas 78701 19 20 I further certify that I am neither counsel for, related 21 to. nor employed by any of the parties or attorneys in the 22 action in which this proceeding was taken, and further that I 23 am not financially or otherwise interested in the outcome of 24 the action. 25 Further certification requirements pursuant to Rule 203 of Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003979 BRUCE LARSON 1 TRCP will be certified to after they have occurred. Page 119 2 Certified to by me this 17th of September, 2004. 3 4 5 ______________________________________________________ Leanna Lynch, RPR 6 Texas CSR No. 7187 Expiration Date: 12-31-04 7 HENJUM GOUCHER REPORTING SERVICES, L.P. 2501 Oak Lawn Avenue, Suite 435 8 Dallas, Texas 75219 Dallas Firm No . 69 9 (214) 521-1188 Work (214) 521-1034 Fax 10 (888) 656-DEPO Toll 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003980 BRUCE LARSON Page 120 1 FURTHER CERTIFICATION UNDER RULE 203 TRCP 2 3 The original deposition was/was not returned to the 4 deposition officer on ; 5 If returned, the attached Changes and Signature page 6 contains any changes and the reasons therefor; 7 If returned, the original deposition was delivered to 8 , Custodial Attorney; 9 That $ is the deposition officer's charges to 10 the Plaintiff for preparing the original deposition transcript 11 and any copies of exhibits; 12 That the deposition was delivered in accordance with Rule 13 203.3, and that a copy of this certificate was served on all 14 parties shown herein on and filed with the Clerk. 15 Certified to by me this day of 16 , 200 4. 17 18 19 Leanna Lynch, RPR 20 Texas CSR No. 7187 Expiration Date: 12-31-04 21 HENJUM GOUCHER REPORTING SERVICES, L.P. 2501 Oak Lawn Avenue, Suite 435 22 Dallas, Texas 75219 Dallas Firm No. 69 23 (214) 521-1188 Work (214) 521-1034 Fax 2 4 (888) 656-DEPO Toll Free 25 Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003981 BRUCE LARSON A abatement 101:16 able 1:5 15:3 23:3 67:4 117:5 above-styled 1:20 abrasive 94:3,19 absolutely 9:24 82:14 95:10 acceptable 61:1,23 62:5 107:25 108:13 access 66:19 67:6 accessed 30:8 accident 110:12,20 111:4 accidents 42:19 account 49:19 accurate 69:21 ACGIH 61:24 80:11 89:24 acid 44:23 acids 14:24 acknowledged 116:10 acknowledges 86:4 action 118:22,24 activities 33:7,16 activity 32:20 actual 42:10 49:1 66:24 74:2 106:2 acute 77:12 79:21 add 58:9 added 43:4 53:9 109:17 adding 96:10 addition 34:4 additional 32:14 address 64:2 adequate 78:15 administrative 34:3,9 adopt 62:2 adopted 43:23 advance 23:8 advise 29:14,14 advocacy 51:21 affairs 59:21 60:1 affix 116:1 agents 16:3 agree 19:18 26:10 "31:23 33:23,24 36:23 65:2 75:6,24 76:4 104:25 agreed 61:1 ahead 85:13 87:2 air 25:16 29:9,18 58:14 59:3 66:20 67:6 71:13 90:12,19,23 91:1,4 95:2,18 96:23 99:1,7 106:3 107:19 air-supplied 97:17 105:12 106:4 air-supply 113:12 air-tight 95:8 air-vent 105:20 air-vented 98:22 AL 1:2,5 117:2,5 alive 38:3 Altmore 6:6,9,13 amended 60:23 America 2:8 118:9 American 50:18 51:18 61:24 amosite 47:19 71:6,21 71:25 73:1,13,16 74:5 79:25 amount 19:2 42:12 48:18,20,22,23 96:22 117:22 amounts 71:25 anatomy 11:13 Anderson 14:14,18 15:14,17 Anna 31:1 ANSI 105:11 answer 51:10 52:7 65:8 70:9 73:3,11 76:21 78:13 83:2 91:5 92:22 98:4 104:10 answered 83:4 101:8 anybody 111:12 114:22 anybody's 80:20 anytime 58:24 102:24 API 50:15,17,25 apologize 13:8 Appearances 3:2 appeared 116:9 applicable 58:23 88:15 88:20 102:12 application 108:11 applications 72:14,22 Applicators 113:14 applied 64:19 65:9 applies 80:24 apply 35:25 64:4 appreciate 23:11 83:6 99:21 111:6,9 appreciated 19:1 appreciation 18:20 86:6 approach 26:12 appropriate 28:14 55:7 55:8,9 101:18 approved 106:12 approximated 27:17 Approximately 43:20 April 6:7 area 11:15,16 16:20,22 17:18 20:7,10 22:16 22:25 23:5,16,19 26:8 34:8,18 99:18 106:20 107:10 areas 12:11 Army 40:7 Aromatic 40:9 aromatics 30:17,19 31:14 37:19 39:1,2,9 39:14,16 43:5 Art 86:20 Arthur 16:24 86:9 asbestos 5:5 8:19,20 12:18 16:5 18:8,21 19:14 20:23,24 21:4 21:8,14,25 32:1,13 33:4,12,14,16,21,22 34:16,19 35:1 36:21 36:22 41:12 43:9,12 44:9 45:2,16 46:17 47:4,8,10,18,23 48:1 48:4,9,14 49:6,11,13 52:2 55:20 56:7,11 56:12,16,17 57:13 58:22 62:15 63:5 67:21 68:1,5 69:25 70:12,17,20 71:5,11 71:21 72:25 73:13 74:11,15 75:2,8,14 75:19,21 76:12 77:15 79:11,25 80:24 81:25 82:8,25 83:15,18 84:19,22 85:2 86:5 87:9,25 90:7,14 92:7 92:19 93:3,6,7,14,17 96:23 97:6,11 98:10 99:10,15,24 100:12 100:23 101:1,9,18,25 103:1,3 106:18 108:1 108:8 109:16 110:16 asbestosis 48:3,13,16 77:4,12 79:21 86:14 asbestos-containing 36:2 43:8,15 44:1,2,7 44:11,22 45:18 46:1 47:9 55:25 57:2 62:17,21,23 71:15 72:11,13,17 74:9 76:5,6 81:7 83:4,10 83:13,19 85:3 95:24 96:25 97:3 98:15,25 108:7,16 109:3 110:11 asbestos-free 44:4 108:3 109:7 asbestos-related 7:19 52:6 112:4,8 asked 7:22 8:15 9:2 asking 110:24 asphalt 39:20 assigned 88:18 assist 103:14,14,23 104:2 assisted 25:22 assisting 14:25 associate 85:2 associated 84:19 association 50:12,18 51:3,8,19 52:15,19 associations 50:10 51:16 105:17 assume 7:17 38:5 57:13 94:21,21 95:17,23 97:5,18,25 assumed 56:16 98:12 assumption 95:11 assure 45:21 attached 120:5 attended 10:17 attention 31:11,13,16 attorney 4:10 117:19 120:8 attorneys 5:10 7:3 118:21 audit 88:21 102:15 auditing 61:15 Austin 1:23,24 2:16 9:17,25 10:17,19,20 10:22 11:22 16:25 17:4 111:8 114:4 118:18 automatically 98:12 available 44:5,7 56:1 66:17,17 72:8 84:25 108:1,4,5,11,21 114:3,6 Avenue 1:23 2:16 118:17 119:7 120:21 average 42:18,19 49:25 aware 19:23 20:3 22:4 44:21,25 49:21 58:22 77:14 80:18 101:13 102:10,11,14 a.m 1:21 B Bachelor 10:21 back 5:16 14:13 31:6 38:25 45:6 49:18 50:6 56:19 79:22 Page 88:11 90:22 91:1,3 95:1 98:12 100:21 backed 23:13 background 26:24 82:25 bad 18:24 104:4 bakeries 17:15 Bakersfield 30:24 31:8 band 56:18,20 57:2 banding 56:13,15 Bank 2:8 118:9 banned 63:5,6 barely 95:12 base 69:23 75:25 based 42:21 46:17 64:20 71:10,23 104:21 105:17 106:1 baseline 32:12 Bashline's 6:16 basic 11:24,25 14:21 28:20 basically 8:13 11:2 14:25 16:7 20:5 32:24 33:7 35:19 36:16 39:10 43:22 53:6 61:23 62:12,19 64:16 67:1 72:16 76:22 89:5 98:12 106:20 basing 107:18 basis 32:25 58:7 64:10 64:15 92:13 Baton 26:14 Bayou 35:3 36:4,20,22 63:24 64:7,24 Bayport 24:17,18 26:5 Bays 24:19 Baytown 24:18 26:14 Baytown's 24:18 25:9 Bayway 26:15,17 BEAN 2:11,11 118:13 118:13 bear 4:19 Beaumont 5:15 6:24 16:24 19:22,25,25 22:3,5,16 30:17,17 31:13 34:24 37:18 38:10 43:8,12 52:13 59:11 63:23 67:2 69:7 71:9,21 73:5,14 83:22,22,24 89:6 91:5 93:1 beautiful 9:17 beer 86:10 began 39:3 87:5 108:13 beginning 55:24 88:9 Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003982 BRUCE LARSON 100:21,24 105:20 108:4 begun 69:14 behalf 7:19 98:6 behavior 93:21 94:23 95:13,25 97:19 beings 13:19 15:6 belief 34:23 107:18,25 believe 5:16,17,24,25 6:8,10 12:19 14:14 17:18 18:14 26:22 38:22 39:3 45:8 54:11,14 56:25 57:15 65:15,21 66:1,5 68:2 69:1170:19 79:3 83:25 84:2 86:17 90:8 91:18 101:7 104:14 106:1 108:12 believed 78:20 belonged 50:10 52:10 belonging 51:15 Benoit 91:13 94:22 95:3,17,23 96:14 107:3 110:1,10 Benoit's 92:23 93:16 104:11 benzene 5:5 8:21,22 14:3 31:19 60:16,20 60:25 best 5:7 better 4:22 23:18 70:9 80:3 92:22 big 36:9 39:24,25 bigger 39:21 biochemist 14:14,20,25 biochemistry 11:14 biological 16:3 biology 11:2,20 biometry 13:14 bit 14:13 36:25 37:6 38:1042:1445:11 57:23 77:9 92:14 93:12 100:21 107:7 blankets 44:6 108:6,7 blast 94:8 96:6 97:15 blasted 94:22 112:23 blaster 94:8 blasters 106:7 blasting 93:17 94:5,13 94:19 95:9,13,18,24 96:15,21 98:24 106:3 106:20,23 107:9 112:23 blocks 47:10 blowdown 105:23 106:6 107:13 blowing 107:10 blue 56:13,15,18,20 57:1 boilermakers 98:17 99:2 boilermaker's 99:8 bonded 75:22 Bonsib 85:5,10,24 86:15,15,20,24 93:11 booster 36:6 born 10:12 boss 54:5,6 botany 11:14 bottom 46:24 47:2 109:8 Bowl 5:18 BP 8:7 brake 21:1 47:10 Branch 10:16 brand 73:23,25 74:3,4 108:18 brand-new 26:6 break 50:3,5,7 102:4 broad 16:1 17:14 39:19 broadest 68:13 broke 45:3 BROTHERS 2:11 118:13 brought 99:25 Brown 89:1,6,12,18 103:15 104:9 105:6 Bruce 1:11,18 3:4 4:1 37:20,20 59:12 115:2 116:1,5,9 117:11,15 build 40:17 building 8:24 25:25 built 38:21,22,22,24 39:2 40:5,12,2141:2 41:13 bulk 71:24 bulletin 82:24 bunch 28:2 63:15 burdensome 51:10 business 51:9 65:20 butadiene 31:19 bystander 106:17,22 by-products 39:13 B-E-N-O-I-T 92:24 B-U-T-A-D-I-E-N-E 31:19 __________C C 2:1 95:2 Calculus 12:1 calculus-type 11:25 California 30:25,25 31:1,7 call 27:21 30:20 called 21:1 28:16 35:2 44:10,19 73:23 113:14 calling 11:2 canal 26:18 cancer 14:22 48:14 68:1,8,8,15,18 70:16 70:21 76:15 79:17 86:12 91:25 92:1,7 92:15,20 cancers 52:6 67:21 68:4,20 Capco 44:14 capital 54:17,20 55:12 55:22,23 56:3,8 57:20,24 58:1,8 carcinogen 48:1,5,12 carcinogenic 47:22 49:13 carcinogenicity 48:8 carcinogenics 31:22 card 116:10 career 12:14 23:8 35:11 36:11 60:8 107:17 Carr 1:2 4:14 63:16 91:16 114:1 117:2 carried 44:23 Carry 108:18 case 4:14 5:24,25 6:6,9 6:14,17,24 7:2 17:17 47:3,4 57:15 63:12 63:16,17,18 70:12 91:16 107:2 113:25 113:25,25 114:1,10 114:13,16,19 cases 16:3 59:8 70:6 77:7 89:4 94:1 case-by-case 103:17,25 categories 18:17 category 98:19 cause 1:1,20 3:11,12,12 48:1671:1 75:2 79:11 92:15 117:1 causing 70:16 74:20 112:21 caustic 44:19 74:11 caustics 44:23 cc 49:24 77:21 center 66:25 67:10 central 43:25 66:7 ceramic 72:20 97:2 certain 19:2 39:13 46:16 69:18 81:21,21 102:7 112:13 certainly 34:15 39:23 46:4 48:1,5,16 49:4 82:5 86:5 105:5 106:12 Certainteed 44:14,16 certainty 44:25 certificate 3:8 120:13 certification 28:19 117:10 118:25 120:1 certified 29:7 37:16,23 38:7 111:16,18 117:13 119:1,2 120:15 certify 117:14 118:20 Chain-link 39:11 chance 7:12 96:8 Chandler 4:19 change 4:12 53:4 115:3 changed 54:10 changes 3:7 55:12 115:1 120:5,6 channel 17:2 24:12,13 charge 9:3 63:1 charges 120:9 checking 50:1 chemical 11:18,22 12:2 14:2 21:7 24:6,11 25:3,15 26:5 27:4 30:18,19,20 32:3 36:10,12,14 38:18,19 39:4,6,7,16 40:1 41:23,24,25 42:3 43:1 44:19,23 45:17 47:3 50:11,16 51:2,7 52:13,15 53:7 54:7 72:4 chemicals 16:4 22:21 25:18 chemist 28:17 chemistry 11:3,13,14 chest 76:22 Chester 66:4 children 10:6 99:25 Chile 63:4 chitchatting 4:9 choose 111:2,3 Christi 16:25 17:8 CHRISTOPHER 2:7 118:8 chronology 93:7 chrysotile 47:19 48:22 48:22,24 71:1,4,11 71:20,24 73:2 79:24 80:3 circumstances 40:15 Page 2 cities 17:11 City 2:12 17:4 21:21 99:19 118:13 Civil 1:24 claim 77:11 clarify 50:20 classes 11:16,25 12:17 13:23 14:6 classifications 98:18 cleaning 107:10 cleanup 106:6 107:13 clear 90:17 cleared 80:4 Clerk 120:14 client 57:1 clients 28:1 57:6,12 clinical 79:13 close 6:1 107:7,9 closed 55:4 closely 89:19 clothing 112:21 Cloud 2:4 4:11 118:5 cold 35:24 collect 28:20 29:9 collected 59:6,10,11 71:24 91:3,7 college 10:19 15:19 49:20 112:12 come 8:20,24 9:11 10:1 15:16 25:11 47:15 80:19 86:15 90:4 98:14 107:11 comes 65:16 105:10 COMFO 87:25 106:5,8 comfortable 78:5 89:3 89:21 COMFO-II 87:19 coming 9:25 33:8 comments 60:7,12,16 60:20,21,22,24,25 COMMISSION 116:16 committee 60:6 common 74:14 99:7 communication 60:21 community 76:8 comp 105:13 companies 23:4,23 42:11 85:23 101:13 105:1,7 company 20:25 21:11 25:8 47:9 53:7 54:7 63:10 75:1,7,14 88:15,17 105:13,14 105:18 113:14 company-wide 64:4,15 Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003983 BRUCE LARSON 65:9 compared 21:10 35:24 36:2 40:20 41:4 55:4 85:13 87:3 109:13 comparison 62:1 competency 42:21 complaint 19:21 20:4,8 20:13 complaints 17:20 complete 44:25 completely 63:4 complex 35:22 compliance 16:10,13 16:14 18:8 25:19 28:2145:7 47:17 65:18 comply 24:1 complying 88:22 109:15 composition 74:2 Compton 38:1,3 59:11 computer 30:7 59:14 66:14,24 67:10 concentrated 21:17 concern 19:5 32:16 33:3 48:13,17 55:20 56:3,3 74:20 75:25 76:7,17 79:5 95:1 concerned 31:18 48:9 48:10 49:11,22 75:14 112:20 concerning3:1141:12 111:24 114:13,19 condition 112:4 conducted 76:22 93:5 conducting 67:25 Conference 61:24 Congress 1:23 2:16 118:17 congressional 60:5 connected 49:16 conservation 60:24 consider 11:18,21 15:23 27:23,24 47:21 77:16 79:25 87:2 93:13 104:17 109:14 consideration 90:4 109:18 116:11 considered 18:4 41:15 47:16,17,18 48:2 49:19 75:21 79:18 110:12 considering 41:3 consistently 88:7 constant 69:25 70:2 construction 33:5 41:9 42:25 54:20 55:24 62:22 consultant 7:24 8:23 consulting 7:25 8:2,5 9:8 contact 22:17 88:17 98:15 contacted 113:23 contacting 94:4 contain 56:12 contained 43:23 56:11 56:16,17 72:3,25 74:11 75:22 81:25 97:11 109:16 containing 47:10 contains 33:21 44:9 101:18 120:6 contamination 106:21 continental 53:17 69:3 continuous 47:11 contract 25:24 41:9 contracted 101:14 contracting 105:1 contractor 88:3,17,18 88:19 89:17,19 102:17,24,25 103:9 103:17,22 104:6 contractors 25:22,23 25:24 32:4 42:3,9,13 42:16 57:7,12 63:21 88:7,9,24 100:25 101:12 102:7 103:6 103:15 105:3,4,4 106:11,15,15 contribute 70:20 92:7 92:19 contributed 110:1 contribution 92:20 control 13:17,19 16:8 28:18 55:5 102:6,9 controlled 19:9 controlling 13:24 controls 25:12 34:3,10 convention 76:11 conveyed 100:16,17 Cook 7:11 cooling 58:9 coordinating 53:7 cop 49:25 copies 52:14 120:11 copy 5:11 7:15 30:5,6 52:9 84:7,16 120:13 cordoned 106:20 corporate 29:6 58:10 63:7 64:20 corporation 2:10 40:18 40:20,22 41:3,5 43:22 55:16 57:17 59:25 61:13 85:25 103:13,22 104:16 105:19 109:1 118:12 corporations 23:6 42:6 105:2 Corps 40:7 Corpus 16:25 17:8 correct 5:2,8,16,24 6:12 7:20 9:5 10:14 10:18 12:15,16 13:6 14:1 15:21 16:19 17:5,9 19:4 21:21 22:14,20,22 26:9 27:6,10,14,18 33:13 38:15,17 49:14 50:19 51:4,6,8 52:25 53:3 53:23 54:2,16,19,21 54:22 63:24 74:24 80:13 87:1 88:2 90:2 90:14 91:10,20 101:22 102:19 106:16 108:24 113:5 113:9,25 114:5,8 116:1 corrected 102:19 correlating 68:4 76:11 correspondence 52:17 corresponding 61:19 cost 109:12,15,17,17 cotton 18:9,21 counsel 23:1 51:5,7 52:13 118:3,20 Counselors 50:13 countries 61:20 country 62:1 63:4 89:25 COUNTY 1:4 116:7 117:4 couple 8:20 11:19 104:8 109:19 course 11:10,17,24 12:6 13:7 14:11 29:2 35:20 88:11 courses 11:4 67:17 court 1:2 7:9,10 61:4 113:17 117:2 cover 17:22 20:5 coverage 20:11 105:14 covered 6:21 20:7 97:14 99:18 covering 94:1 covers 16:6 cracking 73:8 craft 93:13 96:19 crafts 87:21 98:9,14 create 19:5 created 19:1 crew 104:9 criteria 42:17,20 crocidolite 47:19 48:19 48:21,24 49:16 71:7 71:21 72:3 80:1 cryogenic 35:24 CSR 1:21 119:6 120:20 cubic 58:15 78:6,17 79:20 90:22 current 84:7 currently 7:24 66:21 currents 13:15 Custodial 120:8 customers 82:7 cut 87:11 cutoff 103:13 cutting 87:12 CV 27:19 54:13 61:8 C-O-M-F-O 87:19 D Dallas 2:9 66:25 67:5,8 118:10 119:8,8 120:22,22 Daniels 25:25 data 30:7 32:2,3 71:23 72:8 73:12 81:2 82:6 82:12,16,20,24 83:1 91:3,4,6,6,8 93:4 99:6,6 database 30:9,11 59:15 65:25 66:5,11,13,24 67:7 date 87:6 115:2 119:6 120:20 dates 38:25 62:25 dating 95:1 daughter 10:7 78:3 Davis 22:9,11 day 87:7 109:23 114:6 116:8,12 120:15 days 8:3 9:10 22:15 98:13 day-to-day 29:13 deal 14:9 dealing 5:5,15 7:2,12 8:15 12:18 14:6 29:17 32:16 33:3 52:2 60:2,6,13,25 62:10 69:25 76:1,16 dealt 5:22 13:23 14:7 14:10 decide 58:9 Page 3 decided 48:4 decision 104:21 decrease 61:6,7 decreased 9:6 deem 98:9 DEFENDANT 2:6,10 2:14 118:8,12,16 DEFENDANTS 1:7 117:7 defer 70:22 77:25 definitely 110:23 111:3 degree 11:11 13:5 18:5 67:17 85:20 degrees 72:22,23 73:1 73:6 DeHay 2:7 6:16 7:16 28:1 84:13 118:9 delivered 120:7,12 Denman 4:18 5:4,9 6:5 45:8 88:23 Dennis 37:20 59:12 department 38:9 40:19 40:20 41:4,5 42:1,15 67:15 departments 58:6 depend 49:1,7 103:16 depended 25:9 27:24 52:11,18 65:16 depending 43:13 depends 19:19 24:25 27:21 36:11 77:19 deposition 1:10,18 5:9 6:3,6,19 7:7,12 17:1 20:25 27:15 35:4 36:24 56:10 87:14 88:23 91:15 92:23 93:16 107:21 110:18 113:23 114:3,7 115:2 116:1 117:11,16,18 117:23 118:1 120:3,4 120:7,9,10,12 depositions 4:25 5:1 93:2 description 3:10 116:9 desert 95:20,21,23 96:4 design 25:12 designation 63:11 designing 25:10 destroyed 66:10,11,16 destroying 94:19 determine 28:21 40:21 55:2,6 56:11 88:5 90:13 109:3 determines 105:9 develop 103:9 developed 51:19 Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003984 BRUCE LARSON Page 4 developing 61:12 76:18 device 58:14 71:18 diagnosed 91:24 diagnosis 91:21 diagrams 55:2 died 24:3 difference 35:15 47:12 49:3 different 11:5 17:11 32:21 35:19 59:4 61:20 62:9 67:10 69:12 70:15 91:23 107:6 differently 65:10 difficulty 28:1 63:9 direct 26:7 35:12 101:16 102:9 direction 15:1 directly 20:22 29:1 49:20 52:18 director 13:11 disagree 104:23 discipline 10:24 11:5 discotheque 17:17 discrepancy 103:19 discussed 67:18 80:15 discussion 15:16 discussions 42:12 disease 13:15 48:13 68:6,8,9 76:11 79:20 112:8 diseases 69:18 79:16 display 107:14,16 displayed 23:5 disseminate 51:24 52:1 101:8 disseminated 52:21 82:12,16,22 85:24 distinction 105:17 distinctly 32:21 DISTRICT 1:2,7 117:2 117:7 disturb 93:20 94:23 95:13,25 disturbed 45:18 47:7 75:23 DNA 14:24 doctor 70:22 92:21 doctors 91:23 document 65:12 74:4 82:23 85:8 92:1 116:10 documents 29:25 82:9 83:8,21 84:6 86:19 87:1 88:6 93:1 doing 15:1 21:5 101:3 102:15 104:24 door 38:18,19 doubt 48:15 98:13 Dow 23:22 downward 69:24 Dr 14:22 76:10 dream 15:19 22:23 drop 94:6 duly 1:19 4:2 117:15 DuPont 23:22 duration 75:6 77:19 dust 14:2,7,8,9,11 16:5 18:9 32:6,9 41:12 56:6 95:6 106:5,13 107:12 113:8 duties 15:10 25:7 53:4 57:25 D.A 37:20 E E 2:1,1 earlier 58:21 67:18 earliest 83:7 86:24 91:8 108:20 early 43:18 72:6,7 74:19 75:1 82:7 83:9 84:3,22,23,25 85:9 87:25 90:11 91:4,9 91:11 105:12 108:21 easily 80:4 east 28:11 easy 7:15 ecology 11:12 Edinburgh 9:19 Edison 59:13 educate 15:22 EDWARD 1:2 117:2 effect 34:17 64:17,19 74:17,18 77:2 78:9 81:12 90:9 100:23 effective 18:7 effects 49:13 79:11 effort 31:21 efforts 24:1 101:24 eight 65:21 eight-hour 47:8 either 12:4 16:15 24:15 28:16 32:3 45:5,16 57:11 80:25 81:17 89:24 90:10 96:19 106:4 112:11 electron 71:17 eliminate 34:1 55:25 Elliston2:7 7:16 28:2 84:13 118:9 emergency 12:18 47:24 emphasis 17:22 18:1,18 18:25 19:24 20:14,20 22:1 employed 13:12 24:22 58:22 77:4 84:9 101:20,23 102:22 118:21 employee 23:12 25:13 25:18,20 32:12 54:11 55:13 63:21 68:7,10 77:10 99:15 employees 15:25 16:14 18:6 21:6 25:21,22 32:4 41:9,17 55:7 68:14 69:2,20 70:6 75:8 76:18,22,25 77:5 82:12,16,22 88:8 101:2,17 102:16 103:10 105:8 106:10 113:15 employer 25:24 104:12 104:13 employers 19:11 105:16 employment 24:6 26:25 27:7 enacted 12:5 enclosure 55:6 encompass 10:25 83:19 encounter 102:10 engineer 16:16 engineering 11:18,19 11:22 12:3 34:3,10 43:23,25 73:15,18 74:1,8 engineers 25:11 40:7 57:22 enjoy 111:7,7 entered 30:7 entering 34:18 entire 14:4 17:14 20:7 58:21 107:17 entirely 35:18 environment 64:21 78:14 95:6 99:8,8 environmental 54:18 57:19,21 EPA 12:4 109:16 epidemiological 69:6 112:1,2,6 epidemiologist 67:16 70:9 92:22 epidemiology 13:15 67:19,21,22,25 79:13 93:8 equation 42:24 46:2 47:15,16 equipment 34:5,6 43:14 45:4 55:1,8 56:17,19 62:19 87:18 95:4 105:15 equivalent 61:21 equivocally 48:4 era 86:20 esophageal 68:18,21 70:21 91:25 especially 47:4 105:10 essentially 33:25 45:19 47:11 65:15 68:7 77:24 94:4 96:20 97:23 109:6 establish 53:13 78:14 79:1 82:17 83:3 established 18:3 32:6 32:10 47:24 61:22 77:21,24 78:19 87:7 92:14 establishing 79:2 establishment 21:3 estimate 9:13 39:24 41:21 113:16 estimating 27:21 ET 1:2,5 117:2,5 ether 39:20 ethylene 39:17 evaluate 49:4 evaluated 45:24 evaluating 56:10 evaluation 13:17 16:7 eventually 20:11 24:8,9 58:18 108:6 evidence 109:25 evolutionary 11:12 exactly 73:19 75:17 87:7 100:14 exam 29:3,3,3 examination 3:5,5 4:3 111:14 117:20 example 20:22 21:20 23:21 25:9 45:14 49:5 51:17 52:12,12 64:13 93:1 108:5 exceeded 29:20 32:4 58:23 exceeding 32:1 72:22 excellent 23:23 Excuse 26:16 executed 116:11 exhaust 87:13 Exhibit 113:20,21 exhibits 3:10 113:18 120:11 existed 90:5 existing 56:10 expand 24:16 expanded 24:9,17 expected 68:17,22 experience 94:14 106:1 106:24 107:1 experimental 15:3 expertise 23:7 101:1 experts 63:10 Expiration 119:6 120:20 EXPIRES 116:16 explain 20:18 45:10 exposed 18:6,21 19:2 19:14 21:14 33:22 45:14,22,24 90:14 93:17 97:15 98:25 110:10,16 113:8 exposure 5:5 7:19 16:2 16:2,2,3,4 21:2,8,16 25:16 28:21 32:1,3,4 32:13 33:4,17 34:1 34:10 45:12,15,19,20 45:21,25 46:17 47:8 47:11,13 48:9 49:1 49:16,22 52:2 55:5 55:20 58:14 61:3,23 62:5 70:20 71:4 75:2 75:5,6,8,15,19 76:12 77:16,20 84:19 93:4 93:14 95:6 98:10 99:24 100:6,8,8,12 101:9,25 103:2 106:18,22 110:12 exposures 16:4 18:7 19:8 25:13 46:18 58:23 75:20 78:4 expressed 116:11 extended 16:24 29:10 extensive 91:23 93:6 extent 51:25 56:1 extreme 98:4 extremely 98:5,6 extremes 16:3 Exxon 8:6,10,23 9:3 22:21 23:18 24:6,8 24:22 25:11,20,25 26:3,11,24 46:23 47:4 67:11 85:7,13 87:2 88:24 Exxon's 23:7,10 85:18 86:15 F 1:23 F Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003985 BRUCE LARSON fabricated 49:5 facilities 17:2,10,13 21:7,19 23:16,19 24:16 25:2,5 26:11 26:13 27:17,21 28:8 28:11,13 29:17,21 30:13,14,14,16,22 31:20,25 32:7,10 34:24 35:13 36:9,15 37:3,12 38:12,13 45:8,9 46:17,21 52:17 53:15,17,22 54:21 56:24 61:14,15 61:1662:2 89:18 facility 5:22 7:13 8:24 19:22,25 20:8,10,11 22:3 24:8,10 25:3 26:5,5,6 27:4,5,24 28:15,18,25 30:5,20 34:25 35:2,6,8,15,22 37:14 38:11,21 40:13 41:3,10,13,25 45:15 46:7,10 48:18,20,21 48:22,23 52:9 57:6 62:4 63:6,23,24 64:2 64:7,9,19 65:6 66:1 67:1 69:7 71:9,21 73:5,14 95:9 96:4 97:12,19 102:8 109:16 110:11 fact 23:12 44:8 46:14 48:1172:20 75:20 97:16 100:7 107:14 107:20 108:14 factor 40:3 97:13,13,15 factors 16:1,8 96:9,10 Fahrenheit 72:23,23 fair 53:12 fairly 18:4 20:9 55:10 75:21 93:6 familiar 26:11 35:4,6,8 42:10 49:17 52:3,8 64:1 65:3 67:19,22 67:24 82:9 85:12 102:24 111:20 family 37:6 far 88:5 95:4 farm 9:20,23 fatalities 17:20 Fax 119:9 120:23 feasible 109:3 federal 51:21 feel 12:12 21:6 78:5 89:21 feet 107:4 fell 97:10 fellow 22:9 felt 12:5 18:5 19:8 21:2 21:15 23:8 45:9,21 103:20 fence 39:10,11 fiber 47:15,18,19,20 70:15 71:8 72:20 79:23 97:2 fiberglass 72:21 97:2 108:6 fibers 21:4 47:21 49:6 49:8,13,24 56:7 73:2 73:2 74:6 77:21 80:5 fibrosis 68:9,16 74:21 75:3 76:17,19,25 77:4,12 79:21 112:19 field 22:6 36:25 37:3,4 53:24 Fifteen 86:18 figure 4:22 9:12 file 9:15 57:19 filed 19:21 20:4 120:14 fill 103:21 film 24:17 final 107:23 finally 15:19 finance 13:8 financially 118:23 find 6:13 36:1 66:19 72:1 findings 67:24 68:12 fine 10:3 102:19 finished 10:19 107:9 111:5 fire 66:10,12 108:7 firm 4:11 5:19 6:2,5,16 119:8 120:22 first 4:2 13:10 21:5 24:10 68:11 86:3,7 93:23 94:14 96:3,4 five 5:3 Flexitallic 46:7,9,10 floor 25:25 49:5 flow 55:2 flubbed 77:9 follow 15:3 55:14,17 80:11 81:4 88:14 101:18 107:15 followed 29:16 34:16 81:17 88:7 89:23 107:18 following 90:24 102:17 117:14 118:2 follows 4:2 89:24 117:23 foot 58:15 78:6,17 79:20 90:22 footage 39:22 foregoing 116:1,10 forerunner 88:12 forgot 95:21 form 19:16 21:12 28:5 33:18 40:14,23 41:6 41:14 48:25 51:13 57:3,14 58:17 63:25 64:8 65:1,7 67:3 69:4 70:1,7,13 71:2,11 74:16,23 75:4,11,16 76:3,13,20 77:6,13 78:8,18,23 79:9 80:17,22 82:1 84:20 85:11,14 86:1 91:2 92:8 93:22 94:24 95:15 96:2,17,24 97:22 98:2,7,11 100:1,13 104:18 105:25 106:9 109:5 110:3,8,14,19 formed 14:24 39:7 former 99:15 forms 71:5 forth 14:11 47:19 forum 51:23 forward 113:24 found 97:10 foundation 43:10 four 5:1 8:3 17:19 18:10 59:9,16 68:25 fourth 38:14 frame 35:10 57:10,11 82:17 97:4 99:13 frankly 24:4 93:24 free 33:12,14 108:19 119:10 120:24 Freeport 17:6 freeze 14:16 friable 48:21 49:3,3,6,8 96:23 97:6 fuel 35:20 full 9:13 21:15 47:8 fully 101:13 full-time 37:15 89:2 functions 51:22 fundamentals 28:20 furnaces 43:5 further 118:20,22,25 120:1 G GAF 21:20 gained 79:12 Galveston 1:4 6:11,12 117:4 game 111:7 gap 103:21 GARLOCK 2:14 118:16 Gary's 104:14,15 gas 35:7,9,14,15,16,19 35:19 36:2 64:16 gases 16:4 62:14 gasket 46:14 71:16 gaskets 44:2,6 46:5 47:10 108:8 gasoline 35:21 39:14 39:20 general 11:17 26:12 64:10,12 67:19 68:12 68:14,17,22,24 69:9 69:22 70:14,17 71:3 72:5 74:13 82:25 86:13 97:3 99:9 generalize 71:22 generally 11:6 17:21 19:4 20:9 32:24 42:20 47:6 55:14 65:13 72:1 76:4 80:6 93:15,23,25 109:17 generated 93:11 generic 82:23 generically 83:19 genetics 11:13 gentleman 38:2 gentlemen 21:7 29:6 38:6 geographically 16:21 Gessner 2:12 118:14 getting 11:11 112:20 give 5:9,9 11:12 13:7 39:24 40:2 84:13 104:19 114:3,7,12,18 given 5:1 6:20 88:4 116:12 117:17 118:1 gives 70:4 giving 113:23 Glenn 38:2 go 10:15 14:15,17 15:20 16:9 18:3 20:18,23 22:21,23 29:8 53:1 66:19 67:1 76:4 109:19 113:24 goes 109:1,2 going 4:15,25 23:9 36:20 45:19 50:7 51:14 55:17 57:24 63:22 70:11 90:15 102:3 111:5 112:11 113:17,24 Page 5 golden 16:24 17:3 99:18 good 4:7,8 12:14 23:13 23:14,20 94:5 96:6 96:18 109:21 GOUCHER 119:7 120:21 government 22:18 51:21 77:21,24,25 80:16,21,23,25 81:3 81:5,8 88:15 102:13 governmental 61:25 62:3 government's 81:18 graduate 12:22,24 graduated 12:15 13:4 grandfather 9:22 greater 23:1,16,19 Greenway 27:5 29:15 Greenwood 2:4 4:11 118:5 group 59:8 61:11 85:21 groups 32:12 guess 18:20 40:15 41:15 52:7,11 53:3 56:12 73:11 78:13,14 98:3 106:25 110:9 guidelines 83:3 gun 49:25 guy 64:23 guys 17:24 32:9 62:7 80:14 104:2 H half 4:10 13:3 hand 116:12 handle 29:13 89:5 101:1 handled 25:18 34:19 35:1 49:8 52:16 54:25 58:10 87:11 handles 35:23 handling 21:4,14,25 45:23 77:1 83:4,9,10 83:12 87:9 89:21 hands-on 103:12 happen 29:23 96:9 106:2 happened 34:25 52:8 66:9 94:21 happening 52:3 58:20 94:11 97:23,25 102:21 happens 93:24 hard 30:5 39:25 65:4 harm 101:25 Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003986 BRUCE LARSON harmful 74:15,17 Harold 22:9,11,15 Haveg 44:20 hazard 48:2 60:21 75:20 86:5 95:3 112:18 hazardous 13:23,24 20:21 hazards 13:18 14:5,7 15:25 16:7 18:2,4,5 48:11 49:11 70:18 84:18,22 86:12,13 99:21 101:14 102:10 112:13,16,17,20 head 13:21 headquarters 52:16 health 12:12 13:1,5,13 13:17,18 14:5 15:25 16:13 18:2 20:20 23:12 28:22 50:14 54:7 58:11 61:16 63:19,20 64:18 65:17 67:15 77:2 79:11 84:12 85:18,22 88:8 88:10,16 102:12 103:18 104:21 112:18 hear 19:13 24:2 26:16 44:15 58:24 heard 2:4 4:11,18 6:5 19:15 44:16 73:12 88:23 108:18 118:5 hearing 60:23 heat 72:16 held 59:23 help 12:6 15:5 53:13 104:2 helped 103:8 helping 25:11 HENJUM 119:7 120:21 Hershell 5:7 high 10:16,16 24:17 47:12 53:19 72:14,21 75:2,5,5 higher 58:15 73:5 highest21:3,16,19 45:13,20 Highly 106:19 Highway 38:20,21 hire 16:9,12 42:3,8,9 99:10 hired 33:20 hiring 14:16 historical 82:8 83:8 88:5 historically 72:13 85:17 92:25 Hobson 5:7 home 7:14 10:1 99:25 100:6,7 101:10 hood 95:3,8,12,18,18 95:19,20,21,23 96:4 97:17 98:22 106:4 107:19,22 113:12 hoods 105:12,20 hope 111:6,7 hopefully 10:1 hot 35:24 Hotel 1:23 hour 4:10 9:3 HOURS: 06 117:25 HOURS:31 117:24 household 100:8 Houston 2:13 5:19 10:13,15 13:1 16:22 17:2,2 21:22,23 22:25 23:1,5,16,19 24:11 25:3,15 26:5 27:4 30:6 99:18 113:14 118:14 huh 53:2 human 11:13 12:11 13:19 15:6 humans 13:16 Hurlbert 14:22 Husband 113:25,25 114:10,13 hygiene 12:10 13:16,22 14:7 15:24 23:1 25:12 28:13,16,20 29:7,11 35:11 36:14 37:16,24 40:19 41:4 46:14 50:18 53:9 59:7,18,25 61:13 89:2 93:3 111:20,24 hygienist 15:23,23 16:10,16 22:11 23:3 24:7 25:8 27:11 28:10 86:4,8 93:20 94:23,25 95:14 96:1 111:16 hygienists 16:12 20:6 23:15 24:21 38:7 61:25 hypothetical 94:25 96:10,11,12 98:3 110:24 H-U-R-L-B-E-R-T 14:23 I idea 40:8 64:25 67:10 identify 45:20 identity 116:10 II 106:5,8 Illinois 31:2 imagine 42:22 50:15 96:21 105:6 impact 54:18 57:19 implementation 64:6 implemented 64:15 implementing 53:11,14 61:12 64:24 implying 106:25 important 19:8 40:12 40:21 41:2,7,12 impressed 23:7,22,24 24:1 impression 70:3 incidence 42:19 76:25 include 24:9 61:19 98:16,16,19 included 18:13 20:25 44:6 61:14 68:21 includes 118:3 including 62:13 83:12 income 9:16 increased 9:6 112:3,7 INDEX 3:1 indicate 112:3 indication 95:5 indirect 35:12 individual 52:9,17,21 58:5 individuals 53:10 industrial 12:10 13:16 13:22 14:7 15:22,23 15:24 16:10,12,16 20:6 22:11 23:1,3,15 24:7,21 25:8,12 27:11 28:10,13,16,20 29:7,11 35:11 36:9 36:13 37:16,24 38:7 40:19 46:13 50:18 52:20 53:9 59:7,18 59:24 60:13 61:12,25 86:3,7 89:2,17 93:3 93:20 94:23,25 95:14 96:1 104:1,5 111:16 111:20,24 industries 76:2 85:2 industry 17:14 51:18 51:19,21 74:14 93:24 information 3:11 51:23 54:23 64:6 65:16,18 65:20,20 66:16 67:2 67:6 71:10 79:10,12 Page 6 82:25 88:4 100:16 101:8 104:22 118:1 informed 12:17 initial 32:14 47:23 initially 24:7 54:6 59:20 69:14 85:21 injected 15:2,11 injuries 110:2 injury 112:21 inorganic 11:13 input 103:11 inside 112:21 inspection 18:1 23:25 inspections 17:19,21,22 17:22 21:5 installed 44:12,17,20 45:17 47:6,7 62:24 instance 1:19 58:8 instances 58:19 94:12 102:21 institute 20:1451:18 instructed 97:15 instrument 116:10 insulating 72:15 85:3 100:24 101:3,12 108:3 insulation 33:9,11,14 33:17,21 35:25 36:2 43:15 44:8 45:18 46:2,5 47:4,8 56:11 56:12 62:18,21,23 71:16 72:12,14,17,17 72:19,24 73:13,24 74:2,6 76:6,6 77:1 83:9,12,13,16,17,20 87:11,16 93:18,25 94:3,4,5,8,10,13,16 94:19,22,22 95:13,24 95:25 96:6,7,15,22 97:1,1,3,5,7,10,16 98:24,25 108:1,12,17 108:23 109:7,13 insulations 72:24 83:18 insulator 33:20 87:24 98:13 99:24 101:24 insulators 87:20,23 88:3 99:10,13 100:8 100:11,20 101:4,9,10 107:1,3 insulator's 99:7 insurance 105:13,14 insure 105:15 intentionally 94:15 interactions 104:11 interconnect 39:12 Intercontinental 1:23 interest 12:7,11 23:10 interested 12:8 26:23 75:8,9 118:23 interesting 60:11 intermediates 54:25 intermittent 75:21 internal 102:12 internally 62:8 investigation 20:14 22:1 investigations 19:25 involve 16:1 58:11 involved 12:10,11 13:14 15:24 18:8 20:22 25:14,16 36:1 46:22 51:20 53:14 61:15 involving 8:21 51:19 51:20 IRVIN 2:11 118:12 Irving 76:8 isolated 106:25 isolation 34:11,12 55:6 isotopes 15:11 issue 47:25 issues 8:20 i.e 16:5 J jacket 94:17 97:14 jacketed 96:8 Jake 2:3 4:9,21 6:23 118:5 Jersey 26:17 43:24 52:24 59:13,19 93:12 job 15:10 17:10 25:7 27:8,9,10 53:4 55:11 60:8 61:19 88:10 93:21 98:18 105:16 Johnson 35:2 36:4,20 36:22 63:24 64:7,24 Johns-Manville 82:7 82:19,20,21 joined 50:9 jokingly 89:12 journal 52:10,20 JUDICIAL 1:7 117:7 Juliet 31:2 July 26:4 jump 14:13 45:6 justify 79:13 J.D 6:16 K keep 4:12 93:9 94:3,18 113:3,6 Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003987 BRUCE LARSON keeping 25:19 65:17 KELLY 2:11 118:12 kept 30:3,4,5 65:15 Key 13:11 keyword 30:11 kick 102:16 kill 112:23 kind 4:19,25 15:22 30:11 33:15 34:6 48:14 49:25 50:9 52:6 58:25 63:11,14 64:6 81:10,14 86:12 88:25 90:12,19,23 93:9 95:8 knew 21:13,16,24 40:10 45:2 88:19 know 5:13 7:9 9:15 13:9 15:8 19:7 22:1 22:15,16,16 23:5 24:19 29:25 30:3 32:18 34:20,21 35:14 35:17 36:4,6,20 38:4 38:5 40:5,12,16,17 40:21 41:2,13 42:6 42:10 43:4 44:11,13 44:17,18,20,22 49:15 49:18,18,20 51:16 52:17 56:9 57:7,13 63:23 64:5,9,11,13 64:15 65:8 66:3,18 66:21,21 67:4,8,11 67:14,14 68:23 69:12 69:13 73:11,12,21 75:17,18 77:10 79:4 83:1,17 84:5,7,16 86:2,2 87:6 89:11,12 89:16 90:6,9 91:6,13 93:24 95:1,5 98:4 99:6,12,15 100:15 101:2 102:1 105:9 109:22 110:15 knowledge 41:12 64:20 65:1166:11 70:17,20 74:14 80:9 82:15,21 84:18 knowledgeable 70:15 known 30:18 31:22 44:14 61:22 75:1 79:10 116:9 knows 51:14 __________L lab 28:18 labeled 15:2 labels 17:24 labor 98:16 laboratories 71:19 laborers 99:1 lack 80:3 LaMond 8:24 large 40:18 41:3 48:18 48:22 49:3 89:17 96:22 104:1,5 105:4 larger 40:3 69:20,22,23 88:24 103:15 Larson 1:11,18 3:4 4:1 4:7 55:17 109:25 111:5,16 113:22 115:2 116:1,5,9 117:11,15 lasted 27:7 lastly 17:21 lasts 32:25 late 74:19 90:10 108:22 lately 9:6 84:9 latency 69:17,20 latest 4:10 law 5:19 Lawn 119:7 120:21 lawyer 6:1 10:8 84:13 lay 43:10 lead 18:9,22 112:19 Leanna 1:21 117:13 119:5 120:19 learned 12:21 leave 22:23 88:25 102:25 leaves 63:14 left 22:18 legislation 12:5 60:2,3 letting 50:7 let's 6:22 22:9 26:25 38:10 50:7 94:21,21 95:12,23 leukemia 68:9 LEVAY 2:15 118:16 level 23:3,7 41:11 49:22 52:16 58:10 77:15,18,19,20 78:7 78:12,14,17,17 79:3 79:14,15,20 81:4,21 81:22 levels 47:12 75:2,5,5 81:11 library 83:24 84:4 life 11:1 lifetime 77:22 likelihood 20:7 97:23 likewise 63:6 limit 32:4 58:23 61:3,6 61:7,20,25 62:3,9 63:22 77:25 79:1,24 90:6,13,16,17,20 limited 15:10 26:4,7 42:12 limits 79:2 81:3 line 109:9 115:3 linkage 71:4 linked 71:6 list 11:12 46:8 listed 21:18 73:16 lists 27:19 literature 52:5 84:25 92:12,15,18 93:7 99:23 100:2,3 litigation 8:12,14,16,18 8:19 little 14:13 26:24 36:1 38:1045:11 53:19 57:23 63:12 71:4 77:9 100:21 107:7 live 7:6 9:18,19 53:1 lived 22:16 liver 15:4 68:8 livers 15:3 local 23:2 51:21 87:12 99:10,16 locality 62:2 locally 58:11 located 17:2 27:4 62:2 65:25 66:6 68:23 84:4 locks 21:1 long 13:2 109:23 longer 24:14 look 18:3 21:15 24:25 72:8 104:20 looked 62:1 68:7,9 71:17 looking 49:18 68:6 70:3 72:5 82:8 lot 12:11 13:13 23:5 24:19 30:13 58:25 111:1,2 Louisiana 35:3 63:24 love 26:18 low 20:9 lower 62:3 71:25 72:18 79:3,3,4 80:15 81:7 81:19 89:24 lowered 79:6,8,16 lowering 79:13 lowest 81:4 lube 35:21 39:20 Lubel2:4 4:11 118:5 lung 68:8,15 76:15 79:17 lungs 80:4 Lynch 1:21 117:13 119:5 120:19 L.L.P 2:4,7,11 118:5,9 118:13 L.P 119:7 120:21 _________ M_________ machine 1:22 MAHONEY 2:15 118:17 Main 2:8 118:10 maintained 43:14 45:5 56:16 62:20 66:8 78:4 maintains 84:5 maintenance 32:17,18 32:20 33:1,2,2,4,15 42:1,4,13 55:21 57:24 58:1,7,13 major 13:8 95:1 majority 8:17 18:21 makers 46:14 making 47:9,10 48:6 49:18 88:19 manager 24:2 35:11 54:6,11 59:18,20,24 60:1 64:24 managing 89:4 manner 110:17 Manning 2:7 3:5 4:6 5:11,25 6:4,23 7:4,10 19:16 21:12 28:5 33:18 40:14,23 41:6 41:14 48:25 50:4,20 50:23 51:13 57:3,14 58:17 63:25 64:8 65:1,7 67:3 69:4 70:1 70:7,13 71:2 74:16 74:23 75:4,11,16 76:3,13,20 77:6,13 78:8,18,23 79:9 80:17,22 82:1 84:20 85:11,14 86:1 90:15 91:2 92:8 93:22 94:24 95:15 96:2,17 96:24 97:22 98:2,7 98:11 100:1,13 104:18 105:25 106:9 109:5 110:3,8,14,19 111:12,15 113:17,20 113:22 114:21 117:25 118:8 manual 83:22 84:8 93:2 manufacturer 81:1,4,5 81:6,11,15,21,24 Page 7 82:4 89:25 Manufacturers 51:8 manufacturer's 50:11 51:3 52:15 81:18 manufacturing 20:24 21:13,20 47:5 49:7 53:16 Marcus 13:11 mark 113:18 marked 56:13,18,20 113:21 married 10:4 mask 88:1 masters 67:18 master's 13:5 material 21:25 44:7 45:23 56:18 76:6 81:2,7 82:6,11,15,20 82:23 83:4 materials 19:9,10,12 25:13 46:4 49:2 54:24,25 55:2,25 56:19 71:15,16 72:15 75:22 80:25 83:9,10 83:11,12,15 85:3 98:15 100:18 108:4,5 110:11 114:9,15 math 9:11 11:25 matter 29:9 62:10 matters 19:2 McCAMBRIDGE 2:15 118:17 mean 25:20 28:7 32:18 44:2 61:10 64:12 78:1,23 85:20 86:21 94:19 96:25 98:4 105:11 meaning 54:20 means 19:18 28:8 meant 27:12 measurements 28:21 29:13 measures 107:16 medical 25:17 52:5 55:9 70:22 77:1 91:21 92:21 107:14 110:4 Medicine 52:20 68:25 69:10 medium 51:23 105:4 meet 23:2,15 37:14,15 42:16 88:9 109:7 meeting 10:1 19:11 80:14 meetings 100:18 Melvin 6:23 Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003988 BRUCE LARSON member 50:12,15,16 50:21,24,24,25 51:2 members 51:24 52:14 105:16 Memorial 2:12 118:13 memory 80:20,20 104:13 mention 83:18 mentioned 6:25 18:2 56:9 83:18 89:1 94:16 merely 14:2 105:22 merger 67:9 Merriweather 74:22 mesothelioma 15:14 24:3 49:16 52:5 68:16 70:5 71:1,5,6 76:12,14 79:17 met 23:21 metabolism 14:23 metabolized 15:4 metal 94:1,16 96:8 97:14 Meteorology 11:7 methods 87:15 Metro 17:2 microscope 71:17 mid 68:3 69:14 76:8,10 85:4 89:15,15 miles 39:22 million 58:15 78:6,16 79:19 90:22 mills 5:24,25 17:16,17 mind 49:12 50:2 79:7 mineral 72:20 83:18 97:2 minimize 25:12 34:10 55:5 minimum 59:6,15 mining 85:2 minor 11:19,21,22 MINUTE(S) 117:24,25 misread 8:9 Mississippi 27:13 28:10,12 36:9,13 mistake 31:9 mix 17:14 39:19 Mobil 2:6 5:5,15,22 7:13 8:6,10,23 9:3 19:22 22:3 23:21 26:21,23 27:1,3,8 29:25 30:18,19,21 32:2 34:14,24,25 35:2,11,13 36:15 37:17,21 38:10 39:7 41:17 42:9 46:25 47:4 50:9,16,17,22 50:23 51:2,15 52:10 53:7 54:7 55:14 56:24 57:5,17 58:22 58:25 59:25 60:13 61:5,22,23 62:17 63:6,10,21,22 64:2,3 64:13,21 65:18 66:1 67:11,23,25 68:6,14 69:2,7 70:6 71:9,21 72:11 73:14 75:1,7 75:14,25 76:17,18,21 77:5,10,11,11 80:11 81:12,17 82:13,14,16 82:22 83:1,3,8 84:9 84:18 85:5,7,7,9,13 85:18,24 86:18,22,25 87:3,5,24 88:6,8,9,10 88:18,25 89:6,15,17 89:23,23 90:24 91:1 91:19 95:9 96:4 97:11,18,19,19,20 98:1,9 99:1,10,21 100:11,22 101:4,21 101:23,23 102:6,16 102:22 103:5,23 104:12 106:7 109:1 110:11 111:21 118:8 Mobile 36:14 50:25 55:16 64:19 67:1 73:4 Mobile's 68:10 Mobil's 53:21 62:4 63:7 65:12 68:12 80:9 84:12 86:3 88:14 93:2,5 98:6 106:10 108:2 109:2 molecules 15:2,4 monitor 28:16 29:7 33:7 37:24 45:21 89:19 99:7 monitoring 13:24 25:17 29:18 32:3,6,9 32:14 45:12,15 56:6 58:14 59:3 66:20 67:6 71:13 90:12,20 90:23 91:1,4 93:4 99:1 monitors 37:16 month 8:4 9:11 monthly 52:10 months 84:10 morning 4:7,8 mortality 68:13 Moss 113:25 114:15,19 moved 26:20 50:17 MSA 87:18 106:5,7 M.D 14:14,17 15:14,17 N N 2:1 Nabisco 17:3 name 4:9 14:22 22:7,10 38:2 54:8 63:13 73:23,25 74:3,4 108:18 115:2 116:10 names 4:12 44:15 National 51:5,8 natural 10:21,24 11:11 12:3 35:19 nature 19:15 31:14 near 46:24 necessarily 36:8 40:16 53:8 74:3 96:25 105:9 need 72:10 80:15 82:17 101:17 needed 21:15 31:10 negligent 97:20 neither 118:20 never 7:18 8:8 20:3,3 89:6 97:18,19 107:2 new 8:24 10:8 26:17 33:5,9,11,14 42:25 43:24 52:24 54:20 55:24 59:13,19 62:22 93:12 NIOSH 13:11,12 48:3 93:5 106:12 Nixon 14:16 noise 14:4 16:2 18:11 18:12,15,22 19:3 25:16 29:18 60:23 62:13,14 non 62:21 nonasbestos-containi... 43:16 56:19 57:4,5 nonunion 89:13 NOOTER 2:10 118:12 normal 110:13,22,23 normally 63:9,10 NOTARY 116:15 noted 116:2 notes 102:2 November 5:16 nucleic 14:24 number 9:10 18:5 69:20 70:5,5 99:11 99:16 112:13 numbered 1:20 Numeral 87:19 O Oak 119:7 120:21 oath 116:9 object 90:15 Objection 19:16 21:12 28:5 33:18 40:14,23 41:6,14 48:25 50:20 51:13 57:3,14 58:17 63:25 64:8 65:1,7 67:3 69:4 70:1,7,13 71:2 74:16,23 75:4 75:11,16 76:3,13,20 77:6,13 78:8,18,23 79:9 80:17,22 82:1 84:20 85:11,14 86:1 91:2 92:8 93:22 94:24 95:15 96:2,17 96:24 97:22 98:2,7 98:11 100:1,13 104:18 105:25 106:9 109:5 110:3,8,14,19 obligations 88:20 observed 102:18 obvious 46:6 98:18 107:15 112:18 obviously 14:10 29:11 33:8 53:14 78:11 79:2,4 95:3 96:18 98:14 103:15 occasionally 103:8 occasions 102:23 occupation 14:5 68:24 69:9 occupational 13:17 15*25 28:21 occur 15:5 34:23 occurred 67:9 119:1 occurrence 110:22,24 occurring 107:5 occurs 32:24 offer 63:15 111:23 offering 63:12,18 70:23 office 16:22 22:5,6 29:15 30:6 116:12 officer 16:10,13 45:7 117:16 118:2 120:4 officers 22:7 officer's 120:9 officially 11:23 Oh 18:12 46:11 oil 21:1 35:21 38:15,24 39:9,20 50:17 64:16 85:21 okay 4:23,24 27:1,2 28:4 30:16 34:22 36:19 40:1 50:25 Page 8 56:14 59:2,22 87:8 92:5 102:3,5 109:20 Oklahoma 31:1 old 33:17,21 Olefins 24:18 25:10 26:1,6 30:17,19 31:13 37:19 39:2,17 40:9 43:5 once 37:12 47:6 49:4,5 89:3 ones 29:8 84:7 100:25 108:20 one-on-one 25:23 28:24 one-page 91:22 one-three 31:19 one-week 28:18 ongoing 33:2 43:13 93:9 open 12:13 55:3,5 63:14 opened 22:5 operating 55:7 65:20 operation 21:1725:16 28:14 31:14,15 39:3 45:16 47:13 66:22 105:22 106:3 operations 106:24 operators 38:6 42:1 opinion 8:25 47:2 74:25 75:25 78:1,16 79:15,19 92:6,7,9,13 104:19 105:19 opinions 19:13,15 63:11,15,18,19 70:11 70:23 111:23 114:12 114:18 opportunity 23:2 oppose 61:3 opposed 61:5 73:2 option 73:16 oral 1:10,18 117:16 ORC 50:13 order 41:22 organic 11:13 organization 22:25 23:9 50:12 52:1 62:4 orientation 26:11 original 13:11 120:3,7 120:10 originally 38:22 113:22 OSHA 12:4,8,8 14:15 15:20 16:9,17,22 17:20 18:3,20 19:1 19:22 20:4 22:2,5 25:19 34:14,15 45:7 Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003989 BRUCE LARSON Page 9 46:11,12,13,18 47:17 47:23 48:2,3 49:10 49:10,19 60:2,3,4,6,7 60:13,19,21 65:19 80:1281:12,13,14 88:11,13 93:4 99:15 100:22 107:19 109:15,15 OSHA's 12:18 outcome 118:23 outlined 98:20 outside 42:3,9 100:25 Outside-contractor 101:24 overseas 61:14 62:18 overturned 61:4 P P 2:1,1,7 118:8 Pabst 86:9,21 Packet 3:11 page 3:1,10 115:3 120:5 painted 94:7,10 painter 112:8 painting 106:20 paper 12:22 86:3 papers 15:9 paragraph 63:12,14 part 15:13 17:10 34:9 36:15 39:6 41:15 42:24 53:1 55:11 61:8,19 75:22 85:21 93:16 110:13,21 particles 58:15 78:6,16 79:19 90:22 particular 12:8,10 18:7 18:18 20:8 27:8,9 28:9 29:9 31:10 32:23 35:8 46:18 60:8 64:9 68:19 particularly 23:6 particulate 18:16 62:10 particulates 16:5 18:10 parties 118:3,21 120:14 party 117:22 part-time 8:1 Pasadena 2:5 118:6 pass 29:3,3 59:11 114:21 path 112:22 113:4 PEL 90:16 Pennsylvania 66:2,3 people 11:1 18:21 19:2 19:14,17 20:21,23 21:3,13,16,24 23:5 23:14,21 27:23 29:12 45:13,20,22,23 58:2 59:4,7,9 65:4,5 79:2 79:12,23 80:1 88:6 98:16,17 101:13 113:6 percent 37:4 54:4 71:23 72:2 96:7 97:4 97:10,11 100:23 105:7 perfectly 78:5 94:5 96:6 perform 19:24 99:1 performed 17:19 22:2 43:1 97:18 performing 20:19 56:6 period 19:19 23:21 30:1 37:18 56:7 60:15 65:21 69:17 76:23 periodically 61:15 69:15 88:21 permanent 47:25 permitted 96:3,6 person 28:23 49:20 59:6,9 116:10 personal 34:4,6 78:1 82:15,21 personally 15:8 49:17 49:21 50:24 52:8 81:16,23 91:12 92:6 92:21 103:5 116:9 personnel 28:12 34:18 75:13 89:3 93:3 104:6,20 petro 21:7 petrochemical 17:13 74:14 petroleum 8:7 39:20 51:18 pharmacology 11:7 PhD 14:21 philosophy 63:7 phonetic 6:1 93:12 phrased 92:16 physical 112:20 physically 25:23 113:3 physics 11:3 13:18 pinkish-colored 108:23 pipe 33:17,21 44:2,11 44:11,19,20,22 46:2 72:12 74:9,11 87:12 93:17 94:6,13,22,22 95:13,24,24,25 96:15 96:15,22,22 97:10 98:24 pipefitters 98:17 99:2 pipelines 39:12 pipes 93:18 piqued 23:10 place 19:10 23:12 28:14 32:11 33:13,25 34:5,15 35:2 47:1 63:20 77:20 83:8 88:12 108:6 plaintiff 1:19 4:146:1 7:3 91:13 120:10 plaintiffs 1:3 2:3 7:19 117:3 118:4 planning 67:20 plant 24:2,11,18,18 25:10,15 27:22,23 30:17,19,21,24,24,25 30:25 31:1,1,10,14 32:19,24 35:7,14,15 35:16,19 36:2 37:20 38:20 39:6 43:5 45:17 46:15 47:3 52:21 53:21 64:16,23 65:3 plants 24:9 29:12 30:23 31:5 35:9 36:10 37:11 38:19 52:13 53:16 58:5 plant-specific 58:7 Plastic 113:14 Plaza 2:8,12 27:5 29:15 118:9,13 plug 67:2 plus 29:1 pneumoconiosis-pro... 106:13 point 12:23 43:4 48:4,7 48:15 61:4 73:20 92:12,18 96:4 99:3 101:12 107:8 points 55:3 police 88:14 policies 53:13 64:3,3,18 65:9 85:22 103:23 policy 43:14,17,21,22 44:4 53:11,12 56:1 62:19 65:21 88:7,25 pollution 19:3 polyethylene 27:22 30:20,24 38:20 polystyrene 27:23 30:23 pool 98:16 population 13:16 68:7 68:10,15,17,22 69:21 69:22,23 Port 16:24 position 24:5,7 31:4 38:7 54:10,13,14 59:23 positions 53:9 possibility 97:7,7 possible 16:1 68:13 84:17 107:8,10 possibly 59:10 69:16 106:5 107:9 108:23 112:25 post 12:24 potato 92:3,3 potential 13:17,19 14:5 16:6 18:5 21:2,7,16 32:13 33:16,19 45:20 46:17 47:13 48:11,12 49:2 70:15,18 74:20 86:5 93:14 98:10 99:24 100:5,12 101:9 101:25 102:10 106:17 power 102:16 practical 89:20 94:11 practice 93:23 94:2,18 96:16,19 practices 58:8 84:12 111:21,24 preamble 48:6 precautions 101:19 predominant 71:11 predominantly 71:24 premises 88:18 prepare 12:6 92:24 prepared 111:23 114:12,18 preparing 120:10 preselection 42:15 present 97:5 113:19 presented 103:10 104:24 presents 107:13 presumably 33:12 pretty 70:2 85:19 107:15 prevalent 45:10 46:4 prevent 34:18 preventative 33:2 previous 4:25 previously 94:16 price 42:22 primarily 8:19,20 20:21 31:12,18 33:4 35:21 52:16 60:4 81:13 85:1 primary 21:24 69:19 80:23 Princeton 43:24 59:19 prior 5:1 20:25 34:14 56:9 86:22 88:9 91:7 priorities 19:11 prioritize 46:16 priority 21:5,10,19,24 23:13 33:6 48:23 private 22:18,24 probability 97:8 probably 8:3 16:23 18:24 21:3 24:21 30:2,2 31:2,20 35:7 35:17,17 37:4 39:8 40:10 41:21,24 43:13 44:8 46:3,6,24 52:13 54:4,4 66:17 67:9 68:3 70:9 74:19,24 84:14,24 87:23 90:21 96:7 97:4 105:5,6 problem 102:18 procedure 1:24 87:5 procedures 63:20 64:3 64:3,14 65:9 83:8,14 85:22 88:10,16,20 102:7,12,17 103:18 103:24 104:6,21 proceeding 118:22 PROCEEDINGS 114:24 process 20:24 21:4,14 25:14 39:14 42:15 49:7 54:25 55:1,2,3,8 64:24 109:2,7 110:13 processed 55:3 processes 35:19 73:4 produce 39:16 85:5,9 produced 1:18 39:18 86:18 106:22 product 46:1 51:20 81:11,15,21,24,25,25 82:3 89:24 production 62:18 63:2 products 25:13 31:17 31:18 35:18,21,23 39:19 43:8 44:1,9 51:22 55:1 81:2 109:4,17 professional 23:2 28:17 50:13 111:18 professionalism 23:4 professionals 101:15 professor 13:10,12 program 18:3,25 19:6 20:21 23:7,10,19,20 Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003990 BRUCE LARSON Page 10 23:23 28:19,25 29:4 32:6,9 33:13 34:15 43:11,12 56:21 59:18 64:16 65:12 67:18 89:5 103:9,11,20 109:14 programmed 67:7 programs 23:13 25:17 26:12 28:13 33:25 34:2,5,12 55:7,9 61:13,16 64:18 83:7 85:19 project 55:12 73:21 89:22 projects 33:5 43:1 54:18,20 55:22,23 56:4,8 57:2,20,24,25 58:1,1,8,13 62:22 89:4 promoted 52:23 59:17 59:17 pronouncing 92:3,4 proper 105:15 proportion 40:2 Proportionately 40:1 proposed 60:19 propylene 39:17 protect 79:16,20 94:2 protected 79:24 protecting 15:24 63:21 protection 34:7 55:13 64:14 87:10 113:11 protective 34:4,6 55:8 95:4 107:16 proud 10:10 proved 116:9 provide 8:10 12:13 36:21 92:12 110:1 114:9,15 providing 67:20 provisions 1:25 Provost 7:3,5 public 13:1,5,13 116:15 publish 15:9 81:2 published 15:7,8 62:6,8 68:24 69:1,9,12 82:6 86:4,22 pulmonary 48:2,11 49:11 68:8,16 74:21 75:2 76:17,18,25 77:4,11 79:21 112:19 pumping 64:17 purely 8:12 105:1 purport 70:16 purpose 51:15 purposes 8:12 106:21 116:11 pursuant 1:24 118:1,25 put 17:24 18:18 19:7 56:18 59:14 66:15 P-A-B-S-T 86:9 p.m 1:21 O quality 28:17 41:8 question 4:23 18:15,23 18:24 40:25 49:9,12 51:11 70:9 74:13 75:12 77:8 80:20 92:16,22 99:22 101:7 103:16 104:4 110:15 questions 4:20 28:2 59:1 111:13 114:23 quickly 102:3 quite 19:7,18 24:4 36:25 37:6 42:14 92:14 93:12,24 105:5 quote 36:24 R R 2:1 radar 49:25 radiation 13:18 14:4 16:2 radio 15:2,11 radioactive 15:4 raised 10:12 ran 73:5 rang 72:2 range 14:4 72:1 107:4 108:9 109:6,8 ranges 108:14,16 rank 45:8 ranked 45:9 rate 42:19 68:13 ratios 71:20 rats 15:3,11 raw 21:25 25:13 54:25 read 12:7,22 17:1 27:3 35:4 54:13 75:19 80:7 85:18 87:15 88:23 91:15,21 93:16 110:4 116:1 reading 88:5 92:23 99:23 real 50:2 reality 96:13 97:17 really 12:13 13:8 24:4 44:18 47:5 49:5 73:3 76:7 82:9 83:2 85:2 89:16 100:25 101:2 101:16 104:19 110:15 111:2 reason 12:2,8 69:19 79:5,6,7 94:17 115:3 reasons 51:17 98:19,21 120:6 recall 5:19,20 6:22 11:11 12:19,20 13:20 15:2,18 22:10 26:2 29:24 31:3,25 40:10 40:11 43:3,6 55:19 58:19 61:3 62:22 68:19,20 72:3 73:22 73:25 74:7,8 77:3,7 81:9 83:14 102:21,24 103:8 104:1,7,8 receive 20:8 received 10:21 13:5 82:14 83:1 receiving 52:18 recognition 16:7 84:21 recommend 81:3 recommendation 55:18 81:10,18 recommendations 55:11,14 81:1,14 recommended 81:4 recommending 81:7,20 81:21 record 1:25 25:19 50:6 66:1,7 117:17 118:3 recorded 58:14 records 42:16,21 65:17 65:23 73:20 reduced 60:18 reduction 61:2 refer 83:16,16 references 87:14 referred 87:5 92:1 refineries 17:15 36:10 93:5 97:3 refinery 26:14,14,15,18 35:18,21,23 36:3 38:15,24 39:7,9,18 39:21,24 40:5 41:16 41:19,20,25 42:8 43:1,8,11 44:12 45:17 47:3,9,14 64:16 72:4 83:23,24 84:5 87:12 91:5 93:1 refining 35:15 reform 60:4,13 refresh 104:13 refurbished 32:24 regarding 63:20 64:6 65:11 81:10 region 28:9 53:8 regional 22:5 27:11,12 28:6 54:1 regular 37:8,10 regularly 20:16 regulation 93:7 regulations 19:9,12 34:16 47:23 48:7 52:1 60:3,14,16,20 88:15,21 100:23 102:13 107:19 109:15,16 regulatory 59:21 60:1 77:25 relate 63:19 86:12 92:15 related 8:17 19:12 48:14 49:9 57:25 67:21 70:12 112:13 118:20 relates 52:15 68:15 79:22 85:22 relating 52:5 relations 54:12 relative 35:17 relied 80:23,25 81:3,13 rely 65:5 remediation 43:7,7,9 43:11,12 101:15 remember 5:7 41:16 55:16 60:22 68:11 71:20 81:6,10,20 82:3,19 99:5,23 100:4 107:5,6 Remind 60:10 106:7 removal 87:16,17 removed 43:1545:16 94:6 removing 33:21 87:24 render 70:11 repeat 18:23 83:5 95:16 replace 44:5 62:20 replaced 43:16 44:3 45:2,4 report 62:6 74:22 77:3 77:11 85:6,10,24 86:15,16,20,21,24 93:11 110:4 reported 1:22 29:21 54:11 58:16 reporter 113:18 117:13 Reporter's 3:8 117:10 REPORTING 119:7 120:21 reports 29:16 59:3,5 91:22 represent 4:14 request 7:15 require 20:13 73:13 90:12,19,23 108:8 required 29:2 31:12,15 34:17 73:1,5 74:5,9 87:10,13,15 97:16 98:21 105:12 106:7 106:11,14 requirement 65:17,19 107:12 requirements 34:16 73:13 102:14 118:25 research 14:14,20,22 14:25 15:1 51:22 53:17,22 researcher 14:21 Resource 50:13 resources 18:8 21:17 29:11 respirator 87:19 106:5 107:12,22 respiratory 34:7 64:14 87:10,18 113:11 respond 75:18 responsibilities 28:6,11 36:16 61:9 responsibility 16:22 26:8 35:12 36:14 102:6 responsible 27:12 28:8 29:5 30:15 31:25 35:9 36:8 53:6,16 58:2 61:12 79:2 88:19 rest 114:6 results 6:13 29:19 66:20 68:11 retain 65:21 retained 30:6 retake 29:4 retention 65:12 66:1 retired 7:25 13:12 37:22 66:22,23 111:17 return 117:20 returned 120:3,5,7 review 42:16 54:17,23 54:24 55:1 58:7,12 59:9,13 73:20 84:12 88:10 92:24 103:17 103:18,18,25 109:6 112:1,6 114:9,10,16 reviewed 30:1 54:17 59:4 61:24 82:25 84:7 86:20,23 87:1 Henjum Goucher Reporting Services, LP 888-656-DEPO EXX-MOR-003991 BRUCE LARSON Page 1 88:16 93:2,3,4,6,8,10 93:11 reviewing 83:7 reviews 105:14 revise 60:19 revised 60:17 right 5:1 6:7,25 10:8,23 13:20,25 14:19 15:20 16:11,18 17:14 18:22 19:3,6 24:20 26:6 27:10,13,16,16 31:22 33:17 34:24 36:17,18 37:1 39:15 42:23 43:10,25 50:15 51:24 53:18 54:15 57:9 58:5 59:19 60:3,19 62:14 63:9 64:21 65:24 76:12 77:20 86:1193:10 97:21 98:6,23 99:17,20 102:8 105:24 106:8 108:25 rigs 21:1 rise 58:10 risk 16:1 45:10,13 107:13 112:3,7 RNA 14:24 Robins 2:4 4:11 118:5 role 58:6 101:16 Roman 87:19 Root 89:1,6,12,18 103:15 104:9 105:6 Roscoe38:l 59:10 Rosendahl 42:7 Rouge 26:14 Roundtable 51:9 routine 29:10 RPR 119:5 120:19 ruining 94:4 rule 48:6 49:18 88:8 118:25 120:1,12 rules 1:24 4:5 60:2 Russ6:l,3 7:11 R-O-S-E-N-D-A-H-L 42:7 S S 2:1 safe 77:16,23 78:7,10 78:11,17,17,20 79:20 96:16 safeguard 79:16 safety 16:13,15 22:12 28:16 37:15,17 38:9 40:19,22 41:4,9 42:15,16,17 50:13 51:5,20 54:6 58:6,11 61:16 63:19,20,21 64:18 65:16 67:15 75:13 81:2 82:6,12 82:16,20,24 83:3,14 83:22 84:3,12 85:18 85:22 88:8,10,15 89:2 93:1,3 96:19 100:18 101:18 102:7 102:12,17 103:7,18 103:23 104:6,21 111:18 sample 11:4,16 59:7,10 59:11 samples 29:9,10 32:14 71:15,24,25 sampling 13:7 25:16 29:18 71:10 sand 106:22 112:18,21 112:22 113:4 sandblast 95:2 sandblasted 97:6 sandblaster 93:13,25 94:2,12 95:8,21 103:22 104:1 106:17 106:19 112:4,10 113:13 sandblasters 104:25 107:1 sandblaster/painter 91:19 sandblasting 94:7 98:19 104:5,9,14 105:1,1,7,11,19,22 106:15 112:14 113:2 113:3,7,10 Sanders 38:2 Sanderson 38:3 Sanderson's 7:10 Santa 30:25 saw 32:2 82:19,23 91:22 92:2 saying 19:13 35:5 60:25 74:3 86:19 says 61:8 92:18 schedule 37:8,10 scheduled 17:21 20:16 school 10:15,16,16 12:22 13:1,13 science 10:21,21 11:1,5 sciences 10:24 11:11 12:3 13:9 scientific 70:5 76:7 84:24 se 14:12 seal 116:12 second 17:20 45:6 secondly 94:15 96:5 sector 22:19,24 see 6:22 22:9 23:3 32:3 59:8 71:25 83:21 94:11 97:23 102:2 seen 57:1 71:10,23 73:16,19 82:5,10,24 83:7 85:17 86:24 87:13 91:4,6,8,11,12 92:25 99:6,6 100:2 112:2,7 SEGAL 2:15 118:17 select 42:18 45:12 selected 42:20,23 self-employed 7:24 Selikoff 76:8,10 85:4 Selikoff s 93:10 senate 60:6 send 7:16 sense 35:12 40:18 61:11 64:10,12 70:14 74:17 77:8 102:2 111:2 sent 59:13 separate 33:16 separated 39:9 September 1:12,20 117:11 119:2 served 58:6 120:13 service 8:10 services 9:4,8 119:7 120:21 set 79:3 80:21 setting 25:17 28:25 53:11 severe 77:3 sewage 44:11 Shawnee 31:1 sheet 82:20,21 83:2 94:1 sheets 73:12 81:2 82:6 82:12,16 84:3 shield 94:3,18 shielded 93:25 94:16 94:17 shift 21:15 47:8 ship 17:2 24:12,13 shipyard 100:8 shipyards 76:2 shop 87:12 89:13 short 50:2,7 shortcuts 58:25 shorthand 1:22 117:13 showed 68:13 shown 120:14 shut 24:15 43:14 45:5 56:17 62:20 shutdown 32:20,22,23 33:4,15 57:1 shutdowns 32:17,19 55:21 104:8 side 39:4 41:23,24 42:1 42:4,8 44:19 89:14 signature 3:7 115:1 116:1 117:20 120:5 significant 70:5 92:19 signs 34:17 silica 16:5 18:9,22 95:3 106:22 113:8 silica-containing 112:18 silicosis 95:5 107:15,20 112:19 similar 30:12 85:5,9,23 simplify 11:1 simply 96:9 SINGER 2:15 118:17 single 53:8 108:11 sir 9:18 10:4 37:25 67:16 71:1 91:17 sit 104:20 site 25:18 29:11 40:2 43:1 44:23 58:2 99:13 102:25 104:9 site-specific 64:10 sitting 104:19 situation 102:20 size 35:18 105:9,17 sizes 105:9 Skaggs 2:3 3:5 4:4,5,9 5:12,14 6:3,5 7:2,6 7:11 19:21 21:18 28:6 33:20 40:18,25 41:11,16 50:2,6,22 51:14 57:5,16 58:19 64:5,11 65:5,11 67:5 69:6 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strike 18:15 32:17 33:9 37:8 40:25 48:19 72:10 99:21 studied 13:14 68:21 studies 15:10,14 19:24 49:15 67:22,24,25 68:2,11,23 69:2,7 70:3 76:1 79:12,13 79:13 85:4 93:4,8,10 100:7 112:1,6 study 11:17 13:15,18 15:7 69:13,21 112:2 112:7 studying 14:23 subject 105:14 submit 60:13 submitted 60:7,16,20 60:21,24 117:18 submitting 60:22 subscribed 116:10 substances 13:23,25 20:22 substitute 108:1,13 109:3,12,18 substitutes 44:5 56:1 108:10 substituting 44:4 succeeded 15:19 sufficient 28:23 75:6 80:2 95:6 Suite 2:12,16 118:14,17 119:7 120:21 sum 53:21 sums 55:10 Super 5:18 supervisor 36:1337:15 37:17 52:23 53:5,10 54:1 59:12 supervisors 59:10 102:14 supplied 29:19 supply 1:5 95:2 117:5 suppose 51:17 98:8 Supreme 61:4 sure 9:10 13:20 19:11 19:18 28:13 29:1 33:14 43:2 52:3 67:15 72:9 73:3,10 75:12 88:19,22 90:16 90:24 91:3 95:17 99:3,4 100:14 102:9 102:11,13 105:8 107:8 108:15,15 113:2 surprised 24:4 surveillance 25:17 55:9 77:1 surveys 46:14 suspect 35:7 48:5 Sweeny 54:9 switched 11:20 12:2 sworn 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