Document ba6a0NLN2w7OGnbzXD03vk5vZ

1 In Re: 2 Solutia, et al., 3 4 Vs. Case No. CV-03-PWG-134-E. 6 McWane, et al., 7 9 10 11 12 September 1, 2004 13 14 Videotaped Deposition of WILLIAM B. PAPAGEORGE, 15 Volume III 16 17 18 19 20 21 22 23 24 244 Papageorge, William; McWane (3) (Former Monsanto Employee; WATER PCB-SD0000051383 1 In the United States District Court 2 For the Northern District of Alabama 3 Magistrate Judge Green 4 5 Solutia, et al., 6 .............................. Plaintiffs 7 8 Vs.................................Case No. CV-03-PWG-134-E. 9 10 McWane, et al. , 11 .............................. Defendants. 12 13 14 15 16 17 18 Videotaped Deposition of WILLIAM B. PAPAGEORGE, Volume 19 III, taken on behalf of the Defendants, at the offices 20 of Husch & Eppenberger, LLC, 190 Carondelet Plaza, 21 Suite 600, in the County of St. Louis, State of 22 Missouri, between the hours of 8:09 A.M. and 3:29 P.M. 23 on the 1st day of September, 2004, before J. Bryan 24 Jordan, Certified Court Reporter and Notary Public. 245 Papageorge, William; McWane (3) (Former Monsanto Employee; WATER PCB-SD0000051384 1 APPEARANCES OF COUNSEL: 2 FOR THE PLAINTIFF: 3 Michael H. Wetmore Esq. 4 HUSCH & EPPENBERGER, LLC 5 190 Carondelet Plaza, Suite 600 6 St. Louis, MO 63105-3441 7 Telephone: 314-480-1500 8 Direct (314) 480-1818 9 Fax 314-480-1505 10 michael.wetmore@husch.com 11 12 FOR MEAD WESTVACO: 13 Wendlene M. Lavey, Esq. 14 SQUIRE, SANDERS & DEMPSEY, L.L.P. 15 4900 Key Tower 16 127 Public Square 17 Cleveland, OH 44114-1304 18 Direct (216) 479-8545 19 Fax: (216) 479-8780 20 wlavey@ssd.com 21 22 23 24 246 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051385 1 FOR SCIENTIFIC-ATLANTA, INC.: 2 Lynette Eaddy Smith, Esq. 3 TROUTMAN SANDERS LLP 4 NationsBank Plaza, Suite 5200 5 600 Peachtree Street, Northeast 6 Atlanta, GA 30308-2216 7 (885-3489 8 Fax (404) 962-6688 9 lynette.smith@troutmansanders.com 10 11 FOR PHELPS DODGE: 12 Lynne Stephens O'Neal, Esq. 13 LEITMAN, SIEGAL & PAYNE, P.C. 14 600 North 20th Street 15 Suite 400 16 Birmingham, AL 85203 17 (205-251-5900 18 Direct (202) 986-5023 19 Fax (205) 323-2197 20 sls@lsppc.com 21 22 23 24 247 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051386 FOR LEE BRASS: Julie Ehinger, Esq. HUCKABY, SCOTT & DUKES 2100 Third Avenue North Birmingham, AL 35203 (205) 251-2300 FOR HURON VALLEY STEEL: Karen Pilat, Esq. BUTZEL LONG 100 Bloomfield Parkway, Suite 200 Bloomfield Hills, MI 48304-2949 (248) 258-1616 Fax (248) 258-1439 pilat@butzel.com FOR GII INDUSTRIES: Raakhee Biswas, Esq. BAKER BOTTS L.L.P. The Warner, 1299 Pennsylvania Avenue, N.W. Washington, District of Columbia 20004-2400 Telephone: 202-639-7707 Fax: 202-639-7832 raakhee.biswas@bakerbotts.com 248 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051387 1 FOR SOUTHERN TOOL: 2 Ms. Stacey H. Myers, Esq. 3 RESOLUTION LAW GROUP, P.C. 4 5335 Wisconsin avenue, N.W, Suite 305 5 Washington, DC 20015 6 (202) 686-4844 7 Fax 9202) 686-4843 8 shm@reslawgrp.com 9 10 FOR McWANE, FMC, AND UNITED DEFENSE: 11 Jarred O. Taylor, II, Esq. 12 MAYNARD, COOPER & GALE, P.C. 13 1901 Sixth Avenue North 14 Suite 2400 AmSouth/Harbert Plaza 15 Birmingham, AL 35203-2618 16 (205) 254-1061 17 Fax 9205) 254-1999 18 j taylor@mcglaw.com 19 20 21 22 23 24 249 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051388 1 FOR WALTER INDUSTRIES AND U.S. PIPE AND FOUNDRY 2 COMPANY: 3 James A Langlais, Esq. 4 ALSTON & BIRD, LLP 5 One Atlantic Center 6 1201 West Peachtree Street 7 Atlanta, GA 30309-3424 8 (404) 881-7000 9 Fax (404) 253-8695 10 jlanglais@alston.com 11 12 FOR DATRON AND ANCHOR METALS: 13 Suzanne Wiery, Esq. 14 McMAHON, DeGULIS, HOFFMANN & LOMBARDI, LLP 15 The Caxton Building - Suite 650, 812 Huron Road 16 Cleveland, OH 44115-1126 17 (Cuyahoga Co.) 18 Telephone: 216-621-1312 19 Telecopier: 216-621-0577 20 wiery@mdhl.net 21 22 THE VIDEOGRAPHER: 23 Curt Shaw, Legal Videographer 24 GORE PERRY GATEWAY & LIPA REPORTING COMPANY 250 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051389 1 INDEX 2 Examination by Ms. Lavey (Cont' d.) . . . . . . . 253 3 Examination by Ms. O'Neal .............. . . . . 362 4 Examination by Mr. Taylor .............. . . . . 410 5 Examination by Ms. Myers ................. .... 432 CL 7 EXHIBITS 8 Defendant's Deposition Exhibit 17 . . . . .... 253 9 Defendant's Deposition Exhibit 21 .... .... 265 10 Defendant's Deposition Exhibit 22 . . . . .... 272 11 Defendant's Deposition Exhibit 23 . . . . .... 273 12 Defendant's Deposition Exhibit 24 . . . . .... 280 13 Defendant's Deposition Exhibit 25 . . . . .... 282 14 Defendant's Deposition Exhibit 26 .... .... 285 15 Defendant's Deposition Exhibit 27 . . . . .... 288 16 Defendant's Deposition Exhibit 28 . . . . .... 295 17 Defendant's Deposition Exhibit 29 .... .... 301 18 Defendant's Deposition Exhibit 30 . . . . . . . . 319 19 Defendant's Deposition Exhibit 31 . . . . . . . . 322 20 Defendant's Deposition Exhibit 32 . . . . . . . . 343 21 Defendant's Deposition Exhibit 33 . . . . . . . . 356 22 Defendant's Deposition Exhibit 4 . . . . . . . . 359 23 Defendant's Deposition Exhibit 5 . . . . . . . . 359 24 Defendant's Deposition Exhibit 9 . . . . . . . . 373 251 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051390 1 THE VIDEOGRAPHER: We're on the record at 2 8:09 A.M. Today's date is September 1st, 2004. We're 3 at the offices of Husch Eppenberger. The address is 4 190 Carondelet Plaza, Clayton, Missouri. My name is 5 Curt Shaw, legal videographer, along with Jerry 6 Jordan, Certified Court Reporter, here today to 7 continue to deposition of William B. Papageorge, taken 8 in the case of Solutia, et al., vs. McWane, et al., 9 currently pending in the Northern District of Alabama, 10 Cause Number CV-03-BWG-1345-E. At this time, would 11 counsel please re-identify themselves for the record. 12 MS. LAVEY: Wendy Lavey, with Squire, 13 Sanders & Dempsey, representing Mead Westvaco. 14 MR. LANGLAIS: Jim Langlais, with Alston & 15 Bird, representing Walter Industries and United States 16 Pipe & Foundry. 17 MS. O'NEAL: Lynne O'Neal, Leitman, Siegal & 18 Payne, representing Phelps Dodge. 19 MS. MYERS: Stacey Myers, Resolution Law 20 Group, representing Southern Tool, Inc. 21 MS. SMITH: Lynette Smith, Troutman & 22 Sanders, representing Scientific-Atlanta, Inc. 23 MR. TAYLOR: Jarred Taylor, with Maynard, 24 Cooper & Gale, representing McWane, FMC, and United 25 Defense. 252 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051391 1 MR. WETMORE: Mike Wetmore of Husch 2 Eppenberger. We represent the Plaintiffs. 3 MS. LAVEY: Would the people on the phone, 4 please, introduce themselves? 5 MS. PILAT: Karen Pilat, here on behalf of 6 Valley Steel. 7 MS. EHINGER: Julie Ehinger, Ampass 8 Industries and Lee Brass. 9 MS. BISWAS: Raakhee Biswas, DII Industries. 10 MS. WEARY: Suzanne Wiery, for Datron. 11 EXAMINATION (CONTINUED) 12 BY MS. LAVEY: 13 Q. Good morning, Mr. Papageorge. 14 A. Good morning. 15 Q. I want to pick up where we left off 16 yesterday. We were talking about an expansion project 17 at Anniston in 1969. I'm going to hand you what we 18 marked yesterday as Exhibit Number 19. No, I'm sorry, 19 Exhibit 17. Thank you. Before talking specifically 20 about this document, do you recall new loading docks 21 being put in as a part of that project in 1969? 22 A. Yes. 23 Q. Okay, do you recall if the new loading docks 24 were covered, they were under roof? 25 A. As best as I can recall, some of them were 253 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051392 1 covered, and yet there were extensions without any 2 roof covering. 3 Q. Before the new loading dock was put in with 4 some roof covering, was the prior method of loading 5 not undercover? 6 A. That is correct. 7 Q. So the rainwater could directly hit that 8 area and run off wherever the water would run off; 9 correct? 10 A. Correct. 11 Q. Do you remember, as part of this expansion 12 project in 1969, the reguest to pave Parkwin Street? 13 A. I do not. 14 Q. Do you remember whether Parkwin Street was 15 paved at the time you were a plant manager? 16 A. I do not. I--(Shakes head in negative 17 manner. ) 18 Q. We were talking about the chlorination units 19 as part of the Aroclor facility some yesterday. Do 20 you remember the installation of demisters on the 21 chlorinator units as part of the 1969 project? 22 A. I remember discussions in which demisters 23 were reviewed and explained. I personally do not 24 remember seeing the installation, itself. 25 Q. You don't know whether demisters were put 254 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051393 1 in? 2 A. Oh, demisters were there when I'd visit the 3 site. I don't remember the procedure used to install 4 them and when they started using them. 5 Q. Do you know what the purpose was for the 6 demisters? 7 A. Well, the idea of a demister is to capture 8 any vapor or droplets of moisture which, in this case, 9 might contain chlorine or hydrogen chloride. 10 Q. Is that what's meant by entrainment? 11 MR. WETMORE: I'm sorry, is what is meant by 12 entrainment? 13 BY MS. LAVEY: 14 Q. (Continuing) The description of vapor or 15 moisture that you are trying to remove. Let me 16 rephrase the question. What do you--what is 17 entrainment in the--in that context? 18 A. It's the presence of moisture in a gas 19 stream. I don't know what else to say. 20 Q. Can entrainment also be the presence of 21 solid particles in a, in a gas stream? 22 A. I've never personally been aware of the use 23 of the expression "entrainment" as it applied to 24 particulate matter. 25 Q. Do you know how the removal of vapor or 255 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051394 moisture from a gas stream was handled prior to the installation of demisters at the chlorinator units? A. I don't remember. Q. Do you remember if any portion of the Aroclor facility was dismantled as part of the 1969 proj ect? A. I associate dismantling with the removal of pieces of equipment and the associated piping. There, there was some alteration, particularly of piping, to accommodate the existence of an addition Q. Can you describe that alteration a little bit more? A. I don't recall the detail. It's a matter of combining the, the pipelines from the new unit and pipelines from the old to enter the storage tanks and the drumming facilities. I don't know how else to explain it. Q. You had said yesterday that as far as you recalled, the existing units were still in place but there was also the new units along next to it? A. That is correct. Q. Is that correct? Okay. If you could turn to what is in Exhibit 17 on page--let's see, page 9 of 12, which will have a DSW marking of 577140, and I would like to direct your attention down to 135, 256 Papageorge, William; McWane (3) (Former Monsanto Employee WATER PCB-SD0000051395 1 "Physical appearance at Anniston," the first paragraph 2 states, "Consolidation of chlorination and 3 distillation controls in a new control room will allow 4 us to dismantle the existing control rooms. The west 5 section of Building 27 will be dismantled to provide 6 space for the new solid still." 7 Reviewing that paragraph, do you know if the 8 dismantling that they are referring to is limited to 9 the control rooms? 10 A. That's what this, this paragraph pertains 11 to. 12 Q. What was Building 27, if you recall? 13 A. I don't remember. 14 Q. Do you know if the old, what we refer to as 15 the old part of the Aroclor facility and the new part, 16 did they continue to operate together until Aroclor 17 production ceased? 18 A. Yes. 19 Q. Do you recall the names of any individuals 20 who were responsible for the expansion project in 21 installations in 1969? 22 A. I do not. 23 Q. When you said that there was some alteration 24 of the piping in order to have the old and the new 25 running together, was any of that piping removed? Any 257 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051396 1 segments of piping removed? 2 A. When the piping is altered, what this 3 implies is that when it used to go from point A to 4 point B, we wanted now to go to point A to point C, 5 and if that piece fits, it's just moved as is. If 6 there is a problem with the fit, a new piece of pipe 7 will be, in essence, cut to size to fit and accomplish 8 the new end point. 9 Q. Do you recall there being any, any piping or 10 other type of equipment that was taken down and needed 11 to be disposed in some manner? 12 A. I do not remember that. 13 Q. Do you remember if the control room was, in 14 fact, dismantled? 15 A. Yes, the old control room, yes. 16 Q. And do you know where that debris from that 17 demolition was taken? 18 A. I do not. 19 Q. Did the addition of the new tank farm that 20 was put in in 1969 change the way in which the Aroclor 21 product was stored or prepared for shipment? 22 A. It did not change the way, other than the, 23 the location changed and there were new tanks compared 24 old tanks. Other than those changes, the handling of 25 the material remained very similar. 258 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051397 1 Q. Were the--when the new tank farm was put in, 2 were the old tanks taken out of service? 3 A. I don't remember that detail. 4 Q. Do you have any recollection of tanks being 5 crossed or taken, removed from the site? 6 A. I don't recall any such activity. 7 Q. One of the items we discussed yesterday as 8 part of the work in 1969 was a new warehouse. Do you 9 recall that? 10 A. Yes. 11 Q. What was being stored in the new warehouse? 12 A. Oh, I do not recall specific items that were 13 warehoused, but it served as a general, let's call it 14 gathering point for incoming materials used in the 15 manufacturing process, and it was also a place to 16 distribute that material to the user as needed, so it 17 was, it was an active operation, an in-and-out type of 18 thing. 19 Q. What became--was there previously--there was 20 an old warehouse prior to that; correct? 21 A. Yes. 22 Q. What became of the old warehouse? 23 A. It was still in use. It's just that the 24 expanded production program required more material to 25 be available, so it required more storage space; 259 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051398 1 therefore, it resulted in an additional warehouse. 2 Q. Do you recall the approximate annual 3 production levels after the expansion program was 4 instituted in 1969 of Aroclor product? 5 A. Whew, I, I don't remember the numbers, no. 6 Q. Do you remember any annual production 7 numbers, roughly, over the time that you were there as 8 plant manager? 9 A. Extremely roughly. As I--the numbers in my 10 mind at the moment that--are not based on solid 11 information. I recall numbers like 30 million pounds, 12 as an example, compared to potential capacity to 13 produce 50 million. Those kinds of numbers I do 14 recall, but I don't remember if they actually were 15 achieved or whether they are truly as accurate as I 16 recall them. 17 Q. So the Aroclor expansion in 1969, much of 18 that, as you recall, was producing more up to the full 19 capacity of the existing Aroclor facility to a large 20 extent? 21 A. I don't know if it's a large extent, but to 22 a reasonable extent, some of the activity was 23 attributed to that, yes. 24 Q. Was the overall capacity of the Aroclor 25 facility increased as a result of what's referred to 260 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051399 1 as the expansion project? 2 A. The ability to produce more was made 3 available. I don't recall if we ever achieved that 4 point. 5 Q. Can you describe the new flaking and bagging 6 equipment that was installed in 1969? 7 A. I don't know how to describe it. It's -- 8 Q. What piece of equipment does that entail? 9 A. Well, there were several pieces. There was 10 the unit, for example, that, as I recall, it amounted 11 to a, a rolling metal device that was immersed in the 12 liquid and that liquid would solidify because that 13 device was cooled, and then on--at some point on its 14 rotation, there would be a device to shave off the 15 flakes. That flake material was then conveyed to a 16 device that was used to fill bags, or fill fiber drums 17 of material. 18 Q. The, the new flaking equipment was inside 19 the new warehouse; correct? 20 A. Yes. 21 Q. Where was it located prior to that? The 22 flaking operation, I should say, not the new flaking 23 equipment. 24 A. I don't know how to describe it. There was 25 a sheltered area near the older facility, and as I 261 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051400 1 recall, the equipment at that time occupied less 2 space, also. It was a smaller facility. 3 Q. When you say it was a sheltered area, what 4 do you mean by "sheltered"? 5 A. A roof, and something like, maybe, three 6 sides with an open area to allow-- 7 Q. Sort of like a lean-to? 8 A. I'm sorry. 9 Q. Kind of like a lean-to? 10 A. Well, if--yeah, if we use the word "lean-to" 11 to describe the same kind of facility, yes. 12 Q. A three-sided enclosure and a roof? 13 A. Yes. 14 Q. And the flaking operations would take place 15 entirely inside that three-sided enclosure? 16 A. Yes. 17 Q. Were there conveyors associated with the 18 flaking equipment prior to the new installation? 19 A. There was, there was a conveyor that 20 conveyed the flakes from the solid material former 21 over to a point where it could be introduced into bags 22 or drums; packages, in other words. 23 Q. Was the packaging in the same three-sided 24 enclosure, with the drums and the bags? 25 A. Yes, as best I remember, mm-hmm. 262 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051401 Q. So the conveyor system did not exit the three-sided enclosure and go elsewhere? A. No . Q. What products were flaked? A. They were the Aroclors, which includes some biphenyls and most of the terphenyls, chlorinated terphenyls, so for the biphenyls, it would be a material like Aroclor 1268, and to a very small degree, Aroclor 1262, and as best I recall, it included just about all of the chlorinated terphenyls, 5460, and so on. Q. Is that because the chlorinated terphenyls are, are solid at room temperature, and not all the biphenyls are? A. That's correct. Q. So any of the biphenyls that would be solid at room temperature would be flaked, as well? A. That's right. Q. And sold in that, that flaked constituent-- that's not the right word. The solid Aroclors were sold in that flaked state; is that correct? A. Yes. Q. Is there any other way to package solid Aroclors ? A. I don't understand that. You package it by 263 Papageorge, William; McWane (3) (Former Monsanto Employee WATER PCB-SD0000051402 1 putting it in a container that will withstand the 2 shipping process. 3 Q. But solid Aroclors don't come in another 4 form other than as flaked? 5 A. I hesitate because some of the forms were 6 not flaked so much as almost little beads, as though 7 they were crushed, but my memory doesn't help me 8 recall how that form was achieved. 9 Q. But it would not have been done through the 10 flaking process, as you recall? 11 A. It would have to follow the flaking process. 12 You flake it and then break up the flakes into little 13 beads or particles. 14 Q. But you don't recall what that operation 15 was? 16 A. I don't recall the--I don't visualize, 17 today, the system that existed to do that. It wasn't 18 used very much. It was sort of a, an afterthought 19 that some customers wanted a different form and they 20 would prepare that material. 21 Q. Was there a dust collection system of any 22 kind associated with the flaking process? 23 A. I don't recall any, no. 24 Q. With the new flaking system, is that--in the 25 warehouse, is that all taking place on one level? Is 264 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051403 1 this a multi-story building? 2 A. What was the beginning? 3 Q. The flaking, the new flaking system, was 4 that taking place on one level in a warehouse, or is 5 that a multi-floored process area? 6 A. As best as I can recall, it was a, a 7 single-level activity. 8 Q. You were describing the piece of equipment 9 that goes around, causing the flaking. Is that called 10 a flaker drum? 11 A. That is an appropriate description. 12 Q. What would--was there anything below the 13 flaker drum, beneath it, or did the conveyor run right 14 under the drum? 15 A. The conveyor ran under the drum, would catch 16 the flakes as they came off the drum. 17 Q. Do you know what the flaker drum was made 18 out of? 19 A. I, I do not. It's a metal drum is all I 20 know. 21 MS. LAVEY: I'll ask the court reporter to 22 mark this document as Exhibit 20? 21. Sorry. 23 (Defendant's Exhibit 21 24 marked for 25 identification.) 265 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051404 1 MS. LAVEY: 2 Q. After he's marked it, Mr. Papageorge, I'll 3 ask you to take a look at it and ask you a few 4 questions. For the record, this is Bates stamped 5 number DSW 392464 through DSW 392465. 6 (Witness peruses said 7 document.) 8 A. I have read it. 9 Q. Okay, do you recall generally, as plant 10 manager, receiving these progress reports from Central 11 Engineering Department during the course of the 12 Aroclor expansion project? 13 A. I'm sorry-- 14 Q. Do you recall receiving these progress 15 reports from Central Engineering Department during the 16 Aroclor expansion project? 17 A. I recall receiving reports of this type. 18 Q. Okay. 19 A. I don't, I don't personally remember the 20 individual reports and the details described in them. 21 Q. Did you recognize this particular progress 22 report dated March 17, 1969? 23 A. Do I recognize it at this moment? 24 Q. Yes, sir. 25 A. Not specifically, no. 266 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051405 1 Q. But your name is on the first page as being 2 a recipient; is that correct? 3 A. That is correct. 4 Q. The person who signed this document's name 5 at the last--second page is R. C. Herman. Who is 6 that? 7 A. I don't remember him. 8 Q. I want to direct your attention just above 9 the signature line where it says, "Number 1, dust 10 collection system." 11 A. I see it. 12 Q. Okay. When you review that paragraph, does 13 that refresh your recollection as to a dust collection 14 system or where the system is located? 15 A. I do not remember that. 16 Q. You don't recall any problems associated 17 with a dust collection system? 18 A. No, I do not. 19 Q. Under number 2, "Biphenyl temperature 20 control," you'll see the first sentence states that 21 "The steam and water control system in the flaking 22 area will be replaced by a therminal" (sic) "system." 23 A. I see it. 24 Q. Do you know what the steam and water control 25 system is referring to? In other words, what is--what 267 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051406 was the steam and water control system in the flaking area? A. I don't know the specifics of the flaking area for the biphenyl, as distinguished from the Aroclors that we talked about. That's a different operation. Q. The flaking of the biphenyls is separate from flaking of the Aroclors? A. Correct. Q. Why was biphenyl being flaked? A. Because at room temperature, it's a solid, and that was the form that the customers wanted to see it, rather than in blocks or chunks. Q. So biphenyl that wasn't being used in Anniston s own Aroclor facility was --could be flaked and sold to others? A. Correct. Q. And was it shipped to other Monsanto plants in that form, as well? A. I'm under an impression it was, but I don't recall the specifics in terms of amounts, plants, and uses . Q. Was the flaking system in place for the biphenyl facility different in any way from the flaking system in place for the Aroclor? 268 Papageorge, William; McWane (3) (Former Monsanto Employee WATER PCB-SD0000051407 A. Owe, I'm--every system has its own characteristics, but in principle, it was similar Q. It still had a flaking drum that went around and the flakes came off onto a conveyor? A. Yes. Q. Where was the flaking taking place for the biphenyls? A. Ooh, I don't remember the specific spot, no. Q. Do you remember if it was inside a building? A. Not vividly, no, I don't remember it. Q. Was that flaking area for biphenyls being altered or modified as part of the 1969 expansion project, do you know? A. Well, it's modified as described in this paragraph 2 we are looking at. Q. But you are not familiar with the steam and water control system specifically in connection with that biphenyl flaking system; correct? A. When you ask me if I'm familiar with that system, you mean physically, or purpose of the system, or- Q. Those would both be my next questions, so I suppose I should ask to be clear, do you remember there being a steam and water control system at the flaking area for biphenyls? 269 Papageorge, William; McWane (3) (Former Monsanto Employee WATER PCB-SD0000051408 1 A. Not in detail, no, but many processes have 2 those kinds of systems because they need cooling by 3 the water and heating by the steam. 4 Q. The sentence indicates that the steam and 5 water control system was going to be replaced by a 6 therminal system. Do you know what the therminal 7 system was? 8 A. First of all, that Therminol is misspelled. 9 It should be capital "T" and an -o-l. 10 Q. I wasn't sure if it was just a different 11 word, I didn't know, or if it was supposed to be 12 Monsanto's Therminol. 13 A. Yes. 14 Q. Okay. 15 A. This is the fire-resistant heat transfer 16 fluid that contains chlorinated biphenyls. 17 Q. So how was the Therminol system, then, 18 controlling the temperature for the flaking unit? 19 A. Instead of creating steam by exposing it to, 20 let's say, a gas flame or an electric coil, the steam 21 is generated by heating water using coils that contain 22 heated Therminol. The Therminol is available some 23 distance away, not too far, because it will cool too 24 much by the time it gets to where you need it, and 25 that's the way heat is transferred, from a gas flame 270 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051409 1 with a fire-resistant fluid over to a, a water source 2 that can be made into steam. 3 Q. Was Therminol used in a similar fashion for 4 heat transfer elsewhere in the plant? 5 A. Well, it's a very common procedure where you 6 are trying to avoid the presence of a flame that could 7 cause fire and explosion in undesirable places, you, 8 you tolerate it over in a, what is perceived to be a 9 safer place, transfer its heat using the Therminol. 10 Q. Do you recall specifically the areas of 11 plant or the operations within the plant where 12 Therminol was being used as a heat transfer fluid? 13 A. Not specifically, no. 14 Q. Do you remember there being a heat transfer 15 unit with a PCB-containing fluid at the HB-40 16 manufacturing area? 17 A. I do not. 18 Q. The document that we were looking at states 19 that "This system"--meaning the new Therminol system-- 20 "is being designed and scheduled for completion on 21 March 26, 1969." Do you see that? Still under number 22 2 . 23 A. Yes, I see that. 24 Q. Do you know if, in fact, the system was 25 completed and put into operation? 271 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051410 1 A. No, I don't remember that specific. It was 2 completed in '69, but I don't know about March-- 3 Q. Not whether--I wasn't asking so much about 4 the date, but at some point in time, it was completed? 5 A. Yes. 6 Q. In 1969? 7 A. Yes. 8 Q. I'm going to hand you another document. 9 I'll ask the court reporter to mark that as Exhibit 10 22 -- 11 (Defendant's Exhibit 22 12 marked for 13 identification.) 14 BY MS. LAVEY: 15 Q. --and ask you to review that for a moment, 16 Mr. Papageorge. 17 (Witness peruses said 18 document.) 19 A. I have read the exhibit. 20 Q. I don't see your name anywhere on this 21 document, Mr. Papageorge, but do you have any 22 recollection of receiving it? 23 A. I do not. 24 Q. Do you know what near-miss accident is being 25 referred to on this memorandum? 272 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051411 1 A. I do not. 2 Q. Before we go back to Exhibit 22, I'm going 3 to mark another Exhibit as Exhibit 23 and ask you to 4 review this document. 5 (Defendant's Exhibit 23 6 marked for 7 identification.) 8 MS. LAVEY: For the record, Exhibit 23 is 9 Bates number DSW 577633 through DSW 5777642, and while 10 Mr Papageorge is reviewing that, I'll also note that 11 Exhibit 22 was DSW 577631 through DSW 577632. 12 (Witness continues to 13 peruse said documents.) 14 A. I have scanned the exhibit. 15 BY MS. LAVEY: 16 Q. Do you recall ever receiving a copy of this 17 near-miss accident investigation report? 18 A. I do not. 19 Q. Do you recall the events that are described 20 in this report? 21 A. I do not recall. 22 Q. In April of 1969, you were still plant 23 manager , were you not? 24 A. I was. 25 Q. Having reviewed this document, does that 273 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051412 1 refresh your recollection as to what the flaker 2 processing equipment looked like in the new warehouse? 3 A. Well, I was under the impression, definite 4 impression, that there was a conveyor involved. I do 5 not see any reference, here, to a conveyor. There are 6 the units referred to as hoppers and chutes that 7 direct the flake material to some end point. I, I 8 don't know what happens after the hopper, the final 9 hopper. 10 Q. And you are looking, as I can tell from over 11 here, you are looking at the sketch of Appendix A 12 sketch, or--yeah, sketch number 1? 13 A. I'm sorry? 14 Q. I was just trying to identify which sketch 15 you were looking at in the document. 16 A. Oh, sketch number 1. You are right. 17 Q. Sketch number 1? Okay. 18 A. Yes. 19 Q. And on sketch number 1, you see that both 20 the biphenyl and Aroclor hoppers are listed there? 21 A. Yes. 22 Q. So both the flakers for Aroclor and biphenyl 23 were relocated and put into the new warehouse,-24 A. Yes. 25 Q. --correct? And also the flaker system 274 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051413 1 covered at least two levels, if not three levels 2 within this building, did it not? 3 A. Yeah, the system, previously, you asked 4 where is the flaker; it's on one level. 5 Q. The system took place over several floors, 6 two or three floors? 7 A. Yes. 8 Q. If I could direct your attention on page 5, 9 which is DSW 577637-10 A. I have page 5. 11 Q. Okay. Under "Committee Observations," I 12 want to direct you to paragraph number 4. 13 A. At the bottom of the page? 14 Q. Yes, sir. 15 A. Mm-hmm. 16 Q. Okay. Paragraph 4 begins with a statement 17 that says, "Housekeeping in the area is, at best, 18 poor." Would you agree with that opinion as of 1969? 19 A. I don't recall ever being asked that 20 question then. I don't know how, how to add to that. 21 That is presumably the opinion of the investigating 22 committee. 23 Q. Well, do you recall the interior of this 24 structure, either while you were plant manager or 25 during your return visit? 275 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051414 1 A. I, I recall that in a, in a vague sort of 2 way. I don't recall ever being there where I saw 3 something that deserved the word "poor" in my 4 observation. I don't recall that. 5 Q. The next sentence says, "Contributing to 6 this problem are: Number 1, an ineffective dust 7 collection system which continuously spills product on 8 the second-level piping and the ground-level floor." 9 Do you recall ever seeing product spilled on the 10 second-level piping and the ground-level floor? 11 A. I do not. 12 Q. Having reviewed this document somewhat, do 13 you now recall the dust collection system associated 14 with this process? 15 A. I do not. 16 Q. Under the same paragraph, it goes on to 17 refer to "flaker doors which have become broken, 18 allowing product to spill on the floor and vapors to 19 escape and cover all process equipment on the third 20 floor." Do you have any recollection, then, of seeing 21 product spilled on the third floor and covering 22 process equipment? 23 A. I do not. 24 Q. Do you know what is being referred to when 25 it says "vapors to escape"? 276 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051415 1 A. I have to guess as to which particular piece 2 of equipment they're referring to. 3 Q. What vapors could possibly be escaping in 4 connection with the flaker process in the warehouse? 5 A. It would have to be the material they are 6 flaking, and it would involve a source of heat, 7 whether a flake fell on a hot pipe, or the vapor came 8 from the molten material headed for the flaker, it 9 could be different sources of vapor that might not 10 have been captured. 11 Q. When it states that "Vapors escape and cover 12 all process equipment," would you read that to mean 13 solid particles? 14 MR. WETMORE: Object to the form. I mean, 15 it says what it says. 16 A. I, I have difficulty describing--there are 17 many surfaces in an area of this type. Some of them 18 are room temperature, let's call it. If the vapors 19 hit that room temperature surface, they could start 20 forming a deposit, a solid deposit that may look like 21 a dust or eventually, it becomes a coating. The dust 22 particles gather into a coating. If that surface on 23 which the vapor is exposed is hot, at best, that vapor 24 will show up as a, as a film of liquid, and stay a 25 liquid as long as that surface is hot, so I don't 277 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051416 1 quite know how to answer your question. 2 Q. Okay. Well, I realize you didn't write it, 3 and that's all right. Do you know--do you recall ever 4 seeing any air emissions coming from this building? 5 A. No. 6 Q. Do you recall emissions into the atmosphere 7 from the previous flaker operations before the new 8 warehouse was built? 9 A. I do not. 10 Q. For either biphenyl or Aroclor? 11 A. That is correct. 12 Q. At the top of this page that we've been 13 looking at, the very first--actually, I want to direct 14 you to the second sentence and ask you a question. 15 The second sentence states, "This material was 16 insulated from the chute by a layer of biphenyl dust." 17 Do you see that sentence? 18 A. I do. 19 Q. Do you know what is meant by "biphenyl 20 dust"? 21 A. I can't tell you what the authors meant, but 22 I can tell you that when I hear, when I am told 23 biphenyl dust, it tells me that this is the solid 24 biphenyl at room temperature that is--that has ended 25 up as a dust, which means very fine little particles, 278 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051417 1 and one observing a surface sees this dust like you 2 might see talcum powder sprinkled or in different 3 concentration at different locations throughout the 4 area. 5 Q. Did you ever see what you are describing as 6 biphenyl dust inside this structure? 7 A. I don't remember seeing that type of 8 situation. I do recall little, small spots that were 9 part of the operation that the operators would 10 eventually sweep up and collect, but the impression I 11 get from reading this document, it was more widespread 12 than that. I didn't--I'd never seen that. 13 Q. When you refer to small spots that the 14 operators would sweep up, where would the sweepings be 15 taken? 16 A. Oh, I don't know. Again, it depends on what 17 activity took place on that shift. Did a bag break on 18 them as, as they were handling it? Did the stuff 19 spill in a spot? Did something go wrong with the 20 whole conveying system where some of the material got 21 off the conveyor and started spilling in another spot? 22 But they were incidences that occurred that were 23 observed as being abnormal. That's not normal, but 24 eventually, they get around to cleaning it up. 25 Q. Do you recall any incidence where the 279 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051418 1 conveyor system broke down and the material was 2 directed elsewhere? 3 A. No, I don't. 4 MS. LAVEY: We've been going about an hour. 5 Why don't we take a quick break? 6 MR. WETMORE: That would be fine. 7 THE VIDEOGRAPHER: We're off the record at 8 9:08 A.M. 9 (Recess.) 10 THE VIDEOGRAPHER: We're back on the record 11 at 9:16 A.M. 12 BY MS. LAVEY: 13 Q. Okay, Mr. Papageorge, I'm going to hand you 14 a document that we will mark as Exhibit 24. 15 MS. LAVEY: I'm not going to ask you 16 questions about this particular document other than 17 whether it was in place at the time indicated as far 18 as you can tell, at least that changes how long you 19 want to look through it, but-20 (Defendant's Exhibit 24 21 marked for 22 identification.) 23 BY MS. LAVEY: 24 Q. The document that we've handed you is titled 25 "Standard Operating Instruction for Drumming and 280 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051419 1 Flaking," dated October 1969. The only question I 2 want to ask you, sir, is whether or not this document 3 would be an accurate description of the drumming and 4 flaking operation as of October 1969. 5 (Witness peruses said 6 document.) 7 MR. WETMORE: Well, I think to answer the 8 question, he's going to have to look through it. 9 BY MS. LAVEY: 10 Q. (Continuing) Go ahead and look through it. 11 (Witness peruses 12 said document.) 13 A. I have difficulty on how to determine 14 accuracy. 15 Q. Let me rephrase the question. 16 A. Mm-hmm. 17 Q. You see that this document is dated October 18 1969; correct? 19 A. Correct. 20 Q. On the first page? 21 A. Yes. 22 Q. Are the standard operating instructions in 23 place to allow the operators to run their particular 24 piece of equipment on--in a consistent manner? 25 A. That's the intent. 281 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051420 1 Q. So the idea of a standard operating 2 instruction is that they should be utilized and 3 followed by the particular operating unit to which it 4 applies; correct? 5 A. By the units, yes. 6 Q. Is there any reason to believe that the 7 operators would not have followed the standard 8 operating instruction for drumming and flaking? 9 A. I have no reason to believe they would not 10 follow. 11 Q. You can put that one aside. Another 12 operating instruction, Pyranol, which we'll mark as 13 Exhibit 25. 14 (Defendant's Exhibit 25 15 marked for 16 identification.) 17 BY MS. LAVEY: 18 Q. Exhibit 25 is DSW 543057 through DSW 543105, 19 and while Mr. Papageorge George is looking that over, 20 the previous exhibit, Exhibit 24, was DSW 542924 21 through DSW 542975. 22 (Witness peruses said 23 document.) 24 A. In scanning this exhibit, I find it very 25 typical of the kinds of instructions available to the 282 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051421 1 operating personnel in the Anniston plant for all of 2 the plant processes. This is a typical example. 3 Q. Okay, and is there any reason to believe 4 that the process as described in this document would 5 not accurately reflect the process as it, in fact, 6 existed in 1967? 7 A. No, but there is no reason to believe that 8 it does not. 9 Q. You can put that one aside, Mr. Papageorge. 10 Thank you. 11 When did Aroclor production terminate at 12 Anniston?l 13 A. 1970. 14 Q. Was that all Aroclors, or did they phase out 15 different products at different times? 16 A. There was a phasing out. The chlorinated 17 biphenyls were amongst the early products 18 discontinued, and eventually, it applied also to the 19 chlorinated terphenyl Aroclors. 20 Q. Did they phase out the liquid Aroclors 21 before the solid Aroclors? 22 A. The solid Aroclors were chlorinated 23 biphenyls, were phased out very early, and then there 24 was a phaseout of some of the liquid-type 25 polychlorinated biphenyls, and eventually, the phasing 283 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051422 1 out included the chlorinated terphenyls. 2 Q. Did you have any involvement in the 3 dismantling of the Aroclor facility? 4 A. The only involvement that I was informed of, 5 really, was one of the status of things, and on their 6 completion, they might be, that kind of thing. 7 Q. Can you identify any personnel who were--who 8 would be involved and knowledgeable about the 9 dismantling? 10 A. No, I cannot. 11 Q. Was Mr. Jesse the plant manager at the time 12 the Aroclor facility was dismantled? 13 A. Yes. 14 Q. Do you recall the chlorine plant being 15 dismantled earlier? I think 1969, perhaps? 16 A. Yes. 17 Q. Okay, who was involved in the dismantling of 18 the chlorine plant? 19 A. When you say "who, " you mean-- 20 Q. Can you name any individuals who -- 21 A. Monsanto people, or -- 22 Q. Yes, sir. 23 A. Ooh: I can't recall specific individuals, 24 but they were part of the operating group that was 25 involved with the processes in the plant other than 284 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051423 1 the parathion-malathion team. 2 Q. Okay. Was an outside contractor used, as 3 well, as part of the dismantling of the chlorine 4 plant? 5 A. Yes. 6 Q. Do you recall who that contractor was? 7 A. No. 8 Q. Do you know if an outside contractor was 9 used for dismantling the Aroclor facility? 10 A. I do not. 11 (Defendant's Exhibit 26 12 marked for 13 identification.) 14 BY MS. LAVEY: 15 Q. We're handing you a document that we've 16 marked as Exhibit 26, Bates number DSW 150415, ask you 17 to take a moment to review it. 18 (Witness peruses said 19 document.) 20 A. I have read it. 21 Q. And your name is listed on this document as 22 a recipient, is it not? 23 A. It is. 24 Q. Do you recall receiving it? 25 A. Not really. 285 Papageorge, William; McWane (3) (Former Monsanto Employee; WATER PCB-SD0000051424 1 Q. Who is J. R. Savage? 2 A. Mr. Savage was located in St. Louis as a 3 member of the manu--group that followed manufacturing 4 operations. 5 Q. Did he have responsibility for the 6 dismantling of the Aroclor facility in Anniston, do 7 you know? 8 A. He was involved. I don't know the extent of 9 his involvement or responsibilities. 10 Q. What was his first name? 11 A. James. 12 Q. Do you know if Mr. Savage is still living? 13 A. I do not. 14 Q. This memo refers to, quote, "Plan to bury 15 all of--all the equipment." Do you know if equipment 16 was buried, in fact? 17 A. I do not. 18 Q. Do you know if demolished equipment was 19 sold? 20 A. I do not. 21 Q. How often was the equipment used in the 22 manufacturing of Aroclors cleaned? 23 A. I don't ever remember a frequency that was 24 established or programmed. The cleaning occurred at 25 the--based on the judgment of the supervisors of that 286 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051425 1 operation, and that judgment usually was based on 2 difficulties encountered in producing the amount of 3 product they had scheduled and the quality of that 4 product, so it varied as far as timing was concerned, 5 and the frequency was not great. It was rather 6 infrequent. 7 Q. How would the need to clean relate to the 8 supervisor's ability to produce the quantity of 9 product? 10 A. Well, I--there are situations in which there 11 is a cleanliness problem that results in the 12 contamination of the finished product. Instead of a, 13 let's say, a water-clear solution, you've got one 14 that's tan or brownish that's caused by a, let's call 15 it an unclean situation back somewhere in that 16 process. The supervisor then determines that he is 17 losing the ability to produce an acceptable product. 18 He's got to find the problem, shut down, clean out, 19 and get back on stream. 20 Q. Does--would his, would his personnel do that 21 clean-out, then, rather than bring in someone from 22 Maintenance or wherever? 23 A. It depends, again, on what activities are 24 involved in getting to the source. If it involves 25 using wrenches to disconnect a pipeline, you ask the 287 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051426 1 maintenance department to supply the pipefitter. If, 2 on the other hand, it doesn't require tools to work on 3 equipment, the operators, themselves, do what is 4 necessary, turning on the heat, or turning off the 5 heat, or flushing with water, or steam, whatever is 6 available to them. 7 Q. Since we're on day three, today, do you 8 recall the name of the superintendent for the 9 Maintenance Department? 10 A. I still can't remember. 11 Q. I thought maybe you slept on it and it came 12 to you in the middle of the night. 13 A. No. 14 Q. Okay. 15 A. Didn't work for me this time. 16 (Defendant's Exhibit 27 17 marked for 18 identification.) 19 BY MS. LAVEY: 20 Q. The court reporter is handing you what we've 21 marked as Exhibit 27. Do you recall generally, before 22 we focus on this particular document, do you recall 23 generally receiving monthly reports from the Technical 24 Services Department while you were plant manager? 25 A. Yes, that was a--the normal routine, yes. 288 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051427 1 Q. So whether or not you recall the specific 2 document, there's no reason to believe you would not 3 have seen this June 1968 monthly report? 4 A. That is correct. 5 Q. I'd like to direct your attention to page 11 6 of this document, and for the record, the entire 7 document is DSW 165426 through DSW 165443, and I have 8 directed Mr. Papageorge to page 11, which is DSW 9 165438. 10 (Witness peruses said 11 document.) 12 Q. (Continuing) Under the heading "Pollution 13 Control," it's up toward the top, there is a "TSD," 14 which I assume stands for Technical Services 15 Department, "Objective F-4," entitled "Develop a plan 16 for reporting spills and other non-routine emissions 17 in the plant." Do you see where I am? 18 A. Yes. 19 Q. Okay. Do you recall, when you first arrived 20 in 1965, whether there was a written plan on reporting 21 of spills or non-routine emissions? 22 A. There was no written plan. It was 23 understood-- 24 Q. How was it under -- 25 A. --that that was to be done. 289 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051428 1 Q. --stood? I'm sorry. 2 A. Oral communication between the bosses and 3 the team members. 4 Q. Why was there a need in 1967 to develop a 5 plan for reporting spills and other non-routine 6 emissions in the plant? 7 A. I don't remember specifically, but it 8 touches on the need to improve communications, not 9 only amongst the two or three people that are close to 10 the situation, but to the rest of the plant personnel, 11 as well as the individuals located in the St. Louis 12 area, so it was really an attempt to improve 13 communications regarding this kind of situation. 14 Q. Do you recall if the manner for reporting 15 spills and other non-routine emissions changed as a 16 result of development that this is referring to, that 17 this document is referring to? 18 A. You say the manner in which it was 19 reporting? It was established, I mean it was adopted. 20 Q. Was it any different than what had been in 21 place previously? 22 A. Previously, was an oral communication. 23 Q. Okay, so this is referring to a written 24 plan? 25 A. Written plan, yes. 290 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051429 Q. Okay. What is meant by the phrase "non-routine emissions"? A. Well, that's a way to describe the release of material into the atmosphere, analogous to the release of material through a spill. Q. So is it fair to say that non-routine emissions did occur from time to time at the Anniston plant? A. Yes. Q. Were those--were spills in the non-routine emissions reported to you as plant manager as part of this plan? A. Yes. Q. Do you have a general recollection of approximately how many spills or non-routine emissions occurred on an annual basis while you were plant manager? A. I have no, no number. It was, it was a rare situation when the incident occurred that warranted this kind of attention. Q. As part of the plan, was it the--who was responsible for preparing a written report about the spill or the non-routine emission? A. The individual was designated in the plan as developed I don't want to guess. 291 Papageorge, William; McWane (3) (Former Monsanto Employee WATER PCB-SD0000051430 1 Q. Okay. Well, if I had the plan, I wouldn't 2 have to ask you these questions, but I don't have the 3 plan. We haven't seen the written plan, so I'm trying 4 to sort out who generated the reports, whether it came 5 out of the Maintenance Department, Technical Services 6 Department, the operating unit, if you recall. 7 A. It had to come out of the operating unit, 8 and according to the way the operations are managed, 9 the report would have to be--would have to involve the 10 supervisor of that operation, so it's conceivable that 11 the person who reports the incident, spill or 12 emission, very likely was the supervisor of that 13 activity. 14 Q. When the written report was prepared, who 15 was it sent to, then? 16 A. Ooh: To the management personnel in the 17 plant, like the superintendent of that operation, to 18 the maintenance person, all the representatives of the 19 activities at the plant. In the meantime, depending 20 on the perception that supervisor or individual had, 21 it could conceivably have been sent to St. Louis to 22 either an engineering person or a manufacturing 23 individual. It's the judgment of the author that 24 helped determine who should be tuned in. 25 THE VIDEOGRAPHER: Counsel, may I change 292 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051431 1 tape? This end tape number 1 of the deposition of 2 William B. Papageorge. We're off the record at 9:40 3 A.M. 4 MR. WETMORE: We'll take a short break. 5 (Recess.) 6 THE VIDEOGRAPHER: We're back on the record 7 at 9:44 A.M. This begins tape number 2 of the 8 deposition of William B. Papageorge. 9 BY MS. LAVEY: 10 Q. Mr. Papageorge, the plan that we referred to 11 that was developed for reporting of spills and 12 non-routine emissions, who was involved in the 13 preparation of that, the development of that plan? 14 A. The leadership in this development was with 15 the Technical Services Department. I do not recall 16 the individuals involved, but there were 17 representatives of the Safety Group, this 18 Manufacturing Production Group-- 19 Q. By "Manufacturing Production Group," you 20 mean within the Technical Services Department -- 21 A. No, the Production-- 22 Q. --or separate? 23 A. --Group stands alone. 24 Q. Okay. 25 A. Technical Services -- 293 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051432 1 Q. But the Safety Group is within Technical 2 Services, isn't it? 3 A. No, it's, it's a little group -- 4 Q. Oh. 5 A. --that's off by itself. 6 Q. Do you remember any specific personnel 7 involved in the development of the plan? 8 A. I do not. 9 Q. Do you know if the written plan defined what 10 would constitute a reportable spill, or what would 11 constitute a non-routine emission? 12 A. I do not recall the, the wording, no. 13 Q. Do you think it was defined in the plan, 14 though? Was that guidance provided to the employees? 15 A. There again, normally, it would be. Whether 16 it is, it was in this case, I do not know. 17 Q. In your mind, as plant manager, how would 18 you distinguish between a non-routine emission and a 19 routine emission? 20 A. I can give an example of a non--a routine 21 emission would be the venting of steam from a, an 22 operation. That's routine. It's designed to do so. 23 The non-routine emission would result from a 24 situation, for example, where the pressure in the, in 25 the system got too high and the safety devices to keep 294 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051433 1 that pressure under control function and release the 2 material that's causing the high pressure. Those 3 would be the non-routine ones. 4 (Defendant's Exhibit 28 5 marked for 6 identification.) 7 BY MS. LAVEY: 8 Q. Handing you what has been marked as Exhibit 9 Number 28, Mr. Papageorge, you'll see it's another 10 Technical Services Department monthly report with a 11 date of September 1968. This is Bates range DSW 12 165476 through DSW 165495. Again, as we discussed 13 before, in September 1968, this is the type of monthly 14 report you would routinely receive as plant manager; 15 correct? 16 A. That is correct. 17 Q. Direct your attention to page 11 of this 18 document, Exhibit 28, which is Page DSW 165488. At 19 the bottom of that page, under the heading "Pollution 20 control, 21 A. I see it. 22 Q. --it states "20 air emission and spill 23 reports were filed by maintenance and operating 24 personnel during September. 10 were non-routine 25 liquid spills and 10 were unusual air emissions." Do 295 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051434 1 you see that? 2 A. I do. 3 Q. Would that be a typical number of reportable 4 events on a monthly basis? 5 A. I have no way of determining what is typical 6 and what isn't. There's no basis for me to make that 7 type of evaluation. 8 Q. Is there any reason to believe, at least for 9 the month of September 1968, that this is an untrue 10 statement? Too many negatives in that question. Let 11 me try again. 12 Is there any reason to doubt that, in fact, 13 ten non-routine liquid spills and ten unusual air 14 emissions occurred in September of 1968 as reported in 15 this document? 16 A. No. No, there is no reason to doubt it. 17 Q. When we talked about spills yesterday, you 18 described the use of sand and the use of rags as a 19 means for cleaning up those spills. Do you recall 20 that yesterday? 21 A. I do. 22 Q. Was sawdust used on occasion, as well? 23 A. Yes. 24 Q. How was--where did the sawdust come from? 25 A. It was purchased, delivered to the plant. 296 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051435 1 Q. Did it arrive by dump truck? 2 A. Yes. 3 Q. Was there a place within the plant that 4 the--that there were piles of sawdust? 5 A. I recall more than one spot. 6 Q. Where do you recall the piles were? 7 A. I associated the location with the periphery 8 of the active part of the plant. 9 Q. The overall Anniston plant or specific to 10 the biphenyl and Aroclor area? 11 A. The overall plant. 12 Q. Okay. Inside the fence line or outside the 13 fence? 14 A. Oh, inside the fence line. 15 Q. Was--were the piles of sawdust in the same 16 place as the piles of sand that were used for the 17 spills ? 18 A. Not identical, but the general areas could 19 contain a pile of each, for example. 20 Q. Do you recall specifically seeing where 21 piles of sand were kept? 22 A. Yes. 23 Q. Where were they? 24 A. I don't remember the exact spot, but it was 25 kind of removed from the active area so they didn't 297 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051436 1 get in the way of any vehicle movements, and so on, 2 and yet reasonably close where they could be quickly 3 used for a spill, example. 4 Q. Do you remember if those piles were near the 5 entrant entrance? 6 A. The entrance was more--well, you have 7 to--there are two entrances, primarily. 8 Q. Okay. 9 A. One entrance involved the office personnel. 10 Another entrance involved the op, the opera--the work 11 force of all groups. 12 Q. Are those--what roads are those entrances 13 off? 14 A. What roads? 15 Q. You had indicated earlier, in earlier 16 testimony, that your entrance was through Clydesdale. 17 Is that one of the two entrances you are speaking of 18 now? 19 A. They both came off of Clydesdale and they're 20 parallel, entering the plant. 21 Q. And were piles located at either one of 22 those entrance areas? 23 A. No, they were closer to the operations than 24 to the parking lots and the gates where employees and 25 personnel entered. 298 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051437 1 Q. Were they up against the fence line? 2 A. I don't remember any that were that close to 3 the fence line, no. 4 Q. Were they near 202? 5 A. 202? No. No, 202 wasn't present when I was 6 there that I recall. At least, we didn't refer to it 7 as 202. 8 Q. Was crushed rock used on occasion to cover 9 spills on the soil? 10 A. I'm sorry? 11 Q. Crushed rock, was that used on occasion to 12 cover spills in the soil? 13 A. There was crushed limestone, if you include 14 that in your description of rock, and this was placed 15 deliberately into a--I'm going to call it a catch 16 basin, an excavation at the low end of the plant, at 17 the low end of the normal flow of strong water flow, 18 so that crushed limestone was placed to scroll, to 19 neutralize -- 20 Q. You are speaking of the limestone pit, 21 correct? 22 A. Yes. That's another description of it. 23 Q. But not for purposes of taking crushed rock 24 and covering soil. That's not the kind of-- 25 A. Oh, no. 299 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051438 1 Q. --use you are talking of? 2 A. No. 3 Q. PCBs are a very sticky substance, aren't 4 they? 5 A. The stickiness varies with the amount of 6 chlorine in the PCBs. 7 Q. Which way does it go? The higher 8 chlorinated are stickier? 9 A. Yes. 10 Q. So did handrails and stairs, steps, often 11 get sticky? 12 A. Yes, they--since it is a nuisance, it's 13 perceived to be often, but that is difficult to 14 measure also, but it's present, it was present. 15 Q. Did the handrails, and steps, and so forth, 16 need to be washed down on-- 17 A. On occasion, it would be cleaned off as 18 best, without scraping down to bare metal. 19 Q. Was that a Maintenance Department 20 responsibility? 21 A. No, that's a responsibility of the operating 22 unit. 23 Q. And would detergents be used, or solvents of 24 some sort be used in order to clean off the handrails? 25 A. There were attempts at trying detergent and 300 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051439 1 trying different solvents, and the best device to 2 control the amount that got on stairwells, for 3 example, was a box of sand at the bottom of the stairs 4 that would in many ways take care of a good bit of the 5 contamination on the boots or shoes that the employees 6 wore. The handrail part was due primarily to the, the 7 use of dirty gloves, and the employees were encouraged 8 to once those gloves got to that point, get a new 9 pair, because they'd go up with those dirty gloves, 10 grabbing the handrail, and dirtying it and extending 11 this unwelcome situation. 12 Q. So the sandboxes that were at the base of 13 the stairs were intended for the workers to step into 14 so that their shoes would be covered in the sand and 15 they would not then track PCB material? 16 A. That was the intent, yes. 17 Q. And that was a longstanding practice, wasn't 18 it, to have both sandboxes at the stairs? 19 A. Well, it was there when I arrived. I don't 20 know when they started it. 21 (Defendant's Exhibit 29 22 marked for 23 identification.) 24 BY MS. LAVEY: 25 Q. The court reporter is handing you a document 301 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051440 1 is that we have marked as Exhibit Number 29, DSW 2 348567 through DSW 348568. Take a moment to review 3 it, please. 4 (Witness peruses said 5 DOCUMENT.) 6 A. I have read it. 7 Q. Do you recall preparing this memorandum, 8 Mr. Papageorge? 9 A. I recall the visit that I made to the plant 10 which resulted in this memorandum. 11 Q. This was a visit that you made on July 31st, 12 1970? 13 A. Yes. 14 Q. What was the purpose of that visit? 15 A. The purpose for it was primarily, from my 16 vantage point, was to get an idea of how active the 17 plant personnel was in controlling loss of PCBs to the 18 environment, and it was also an opportunity for the 19 plant personnel to share with me their activities, 20 both successes and frustrations, and to seek help for 21 me to get involved in influencing other management, 22 higher management, to provide the resources that the 23 plant needed, whether it be money, or people, or 24 eguipment, so it was an opportunity for both the plant 25 and, and me to communicate and be brought up-to-date. 302 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051441 1 Q. Do you recall any specific frustrations, to 2 use your term, that the plant communicated to you? 3 A. I do remember some frustrations, but not the 4 specifics. At that point in time, I just don't 5 remember specifics any longer. 6 Q. Do you remember generally what the 7 frustrations were? 8 A. Well, in a general way, for example, there 9 were some frustrations initially on getting the 10 analytical equipment for the laboratory, and there 11 were frustrations on getting quick approval for those 12 facilities to be separated from the existing 13 laboratory so that cross-contamination would not 14 occur. All of those were eventually resolved, but 15 they, they would express those, how hard they were 16 working at certain activities of that nature. 17 Q. Was it the frustration about the lab 18 equipment because they didn't have the type of 19 equipment that allowed them to do the level of 20 analytical analysis that they needed to do? 21 A. They did not have the equipment required in 22 the extremely sophisticated analysis which was also 23 evolving, of PCBs in different samples, all kinds of 24 samples, and that equipment, in many ways, had the 25 virtually be special ordered, and the initial versions 303 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051442 1 of that equipment came from Europe. 2 Q. Was there an outside lab that was used on 3 occasion for PCB analysis that you recall? 4 A. Not an outside lab. There was a lab in 5 St. Louis that had acquired this equipment and 6 expertise that would be doing what amounts to routine 7 sampling, which research departments don't normally do 8 for plants, but in this case, they had to until the 9 plant was capable of doing it. 10 Q. Turning back to Exhibit 29, in the second 11 paragraph, it states or you state, "I was, however, 12 disappointed that we are still using considerable 13 quantities of sand to keep the floors in the 14 department partially dry." Why were you disappointed? 15 A. My emphasis was one on don't let it get away 16 from you in the first place. The fact that you are 17 using this sand to pick it up means you don't really 18 have a good program for controlling it, not correcting 19 it. There's a difference. Once it gets away from 20 you, it creates a very difficult approach to cleanup 21 than preventing it from existing in the first place in 22 areas where it doesn't belong. 23 Q. Had you previously instructed the plant to 24 make some progress on having less of a need for these 25 sandboxes? 304 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051443 1 A. Yes. 2 Q. Okay, so when you arrived in July 1970, you 3 didn't see that progress being made? 4 A. As I recall, the intent to control these 5 spillages was instituted while I was still there in 6 late '69, and I had hoped that by six months later in 7 the following year, that it would be further along 8 than they were. 9 Q. By "further along," do you mean in terms of 10 the amount of spill material on the floors? 11 A. Yes, that they controlled it much better 12 than, than it appeared to be. 13 Q. Was any action taken in response to your 14 disappointment? 15 A. There was action taken. I don't know if 16 it's in response to my letter or not, but that was 17 part of the overall plan to start with. For example, 18 the installation of sampling points that lended 19 themselves to capturing any spills that dripped out of 20 the, the valve that you used to get the sample, or 21 there were also attempts made to put areas with 22 curbing so if any spills did occur, the curbing would 23 control the extent of that spillage, where did it go 24 and how difficult was it to clean up. 25 Q. The drip pans below the spigots and such, 305 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051444 1 those didn't come into place until sometime during 2 your tenure as plant manager; correct? 3 A. In some places, and I wanted to extend it. 4 That was the purpose of the program. 5 Q. And the curbing, there were areas during 6 your tenure as plant manager that did not have curbing 7 to contain spills; is that correct? 8 A. That is correct. 9 Q. Where were the areas that did not have 10 curbing while you were plant manager? Or maybe it's 11 easier to ask it the other way: Areas that did have 12 curbing. 13 A. Curbing was not the common feature in the 14 Sixties. I have forgotten just when in the Seventies 15 there was curbing installed in the manufacturing area, 16 for example, so that the--any spillage that occurred 17 didn't flow down this storm water flow pattern. In 18 fact, underneath the major PCB-producing facility, 19 eventually, a sump was installed and the curbing was 20 also in place so that if any hosing of the floor took 21 place for other kinds of dirt, and dust, and what have 22 you, that that water will not mingle with the liquid 23 loss that occurred during manufacturing, and that 24 liquid loss in that sump would be salvaged to pump it 25 out, put it in drums, and eventually reintroduce it 306 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051445 into the process to recover the useful or acceptable part Q. Do you recall when the sump was put in? A. As best I can tell, it was in the Seventies. Q. After you left as plant manager? A. After I left, yes. Q. Was there curbing in the biphenyl production area when you left in 1969? A. Not when I left, no. Q. I'm still a little confused about the sandboxes at the bottoms of the stairs. Was the sand in those boxes also used to spread around the floor on spills to dry them up or to cover them? A. In some cases, yes, if the spill was more than just a stain on the floor. Q. Do those sandboxes at the base of the stairs have to be emptied periodically? A. Yes. Q. Whose job is it, was it to empty the sandboxes? A. It was usually the junior member in the production unit who was given the task of tidying things up and-- Q. So the general housekeeping that included things like the sandboxes fell within the production 307 Papageorge, William; McWane (3) (Former Monsanto Employee WATER PCB-SD0000051446 1 responsibility, again not the Maintenance Department? 2 A. Correct. 3 Q. And the sand that was put in those boxes 4 came from the same pile of sand that we talked about 5 yesterday? 6 A. Yes. 7 Q. On Exhibit 29, the document that you have in 8 front of me, the last paragraph on the first page 9 states, "I have concerns regarding the containment of 10 Aroclors from the vault storage, drumming, tank car, 11 and tank truck loading areas." Do you see that-12 A. I do. 13 Q. --sentence? 14 A. Mm-hmm. (Nods head in affirmative manner). 15 Q. What concerns did you have? 16 A. As best I recall is the fact that I could 17 see areas in these particular activities that looked 18 like there were some spills, and that went against our 19 intent, to prevent escape into the environment even 20 though the environment was right under your feet. 21 Q. The next sentence states that "The crushed 22 rock areas should be replaced the concrete pavement." 23 That's the first part of that sentence. What areas 24 were crushed rock that you were asking, suggesting 25 should be replaced with concrete pavement? 308 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051447 1 A. Some of the areas were--an example, where 2 tank cars were located, were away from the areas that 3 had poured concrete pavements on each side of the 4 track. Further down the track, there would be some 5 loading done, and the tracks in that area did not have 6 the concrete pavement. They just put some crushed 7 rock on each side of the rails, and that's the area 8 where any spillage would show in that crushed rock, 9 and is difficult to clean up. 10 Q. Where would the drainage be from that 11 location if it were to rain on any spills in that 12 crushed rock area? 13 A. It would, it would follow the natural storm 14 water, the existing natural storm water flow, which 15 was really at the, what I call the bottom of the 16 plant, instead of up the hillside. 17 Q. Was that a--was that the 11th Street ditch? 18 A. I'm sorry? 19 Q. The area that received in a storm water 20 flow, was that, was that a ditch? 21 A. It included areas that I would call 22 naturally formed drainage ditches. 23 Q. Where did those ditches lead, ultimately? 24 A. Ultimately, they flowed into a creek called 25 Snow, Snow Creek. 309 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051448 1 Q. On Exhibit 29, when we--the sentence we were 2 looking at, "The crushed rock area should be replaced 3 with concrete pavement, curbing and drainage to the 4 interceptor basin," the complete sentence we were 5 looking at previously. Do you know whether those 6 steps were, in fact, taken at some later point in 7 time? 8 A. Yes. Eventually, yes. 9 Q. Do you know when? 10 A. Late '70, early '71 era, somewhere in there. 11 Q. The next sentence reads, "The amount of 12 Aroclor on the drumming area floor appeared excessive 13 and could overload the small sump which is in the 14 present drainage channel from this area." Do you 15 recall when that--is this a different sump than the 16 one we were talking about earlier? 17 A. We talked earlier, limestone pit. 18 BY MS. LAVEY: 19 Q. I was talking, we were talking about a sump 20 that was put in, and I just wanted to be clear what we 21 were talking about earlier about with the sump was in 22 the production area, I believe. 23 A. Yes. 24 Q. Correct? So now we're in the drumming area, 25 and there's also a small sump, apparently, in the 310 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051449 1 drumming area, according to this statement? 2 A. No, a small sump is in the present drainage 3 channel, which, to me, means this is the limestone 4 pit. 5 Q. Okay. Do you know if any steps were taken 6 to address what you are identifying in this sentence? 7 The excessive amount of Aroclor on the drumming area 8 floor and overloading of the sump? 9 A. Yes, they did take some steps to be more 10 careful, make sure that the hoses are drained before 11 they're thrown, thrown aside, that kind of activity 12 did take place. 13 Q. So there was a period of time when the hoses 14 that were taken off were not drained and they were 15 just thrown aside? 16 A. No, not completely. The operator would say 17 "I filled the tank car," and he might let a little bit 18 more pour out and then set the hose aside. In the 19 meantime, what's in that hose dribbles out onto the 20 surrounding area. 21 Q. On the second page of this memo, you 22 conclude with "We should strive for an operation in 23 which no Aroclor is visible and one that we would not 24 hesitate showing to a severe critic such as 25 Congressman Ryan." Was that goal ever achieved? 311 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051450 1 A. I think so, yes. 2 Q. There was a point in time where you did not 3 believe any Aroclor was visible? 4 A. I can't say any Aroclor. The type that 5 would get into the environment was diminished. You 6 could still see strain marks here and there, but they 7 were perceived to be of such a nature that the, the 8 general environment would not be affected by that 9 stain. 10 Q. After you made this visit on July 31st and 11 prepared your August 17th memo, did you return for a 12 follow-up to see if progress was being made? 13 A. Yeah, it seems to me I was there a couple of 14 more times. I don't remember -- 15 Q. Was that 1970, or-- 16 A. I don't remember the exact dates. I just, I 17 know I was there more than once. 18 Q. The memo that you wrote that we're looking 19 at here, Exhibit 29, lists some individuals, here, as 20 also receiving a copy of your memo in addition to Gene 21 Jesse, the plant manager. The first name, there, is 22 H. S. Bergin? Who is that? 23 A. Howard Bergin was the director of the 24 functional fluids marketing and manufacturing part of 25 Monsanto. 312 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051451 1 Q. And that included the Aroclor group? 2 A. Yes. 3 Q. And he was located in St. Louis? 4 A. Yes. He was my boss. 5 Q. When you moved to St. Louis,-6 A. Yes. 7 Q. --he was your boss? 8 A. Yes. 9 Q. I think we already did P. B. Hodges. 10 are nodding, so --F. J. Holz--oh, boy. 11 A. Holzapfel. 12 Q. Thank you. 13 A. Fred Holzapfel. 14 Q. Who is Fred Holzapfel? 15 A. He was part of the group that was located in 16 St. Louis that concerned itself with manufacturing in 17 the division at Monsanto referred to as the Organic 18 Division. 19 Q. The Organic Division included the Functional 20 Fluids -- 21 A. Yes. 22 Q. --Group? 23 A. Yes. 24 Q. This memo makes a reference in the second 25 paragraph toward the bottom, where you say, "I 313 Papageorge, William; McWane (3) (Former Monsanto Employee; WATER PCB-SD0000051452 1 recognize that this poses a very challenging 2 objective, but it can be achieved as demonstrated by 3 both the Newport and Sauget operations." So Aroclor 4 operations were going on at both Newport and Sauget? 5 A. Yes. 6 Q. Is that correct? 7 A. (Nods head in affirmative manner). 8 Q. Any other Monsanto plantsmanufacturing 9 Aroclors at any time? 10 A. That's it. Those two. 11 Q. Were you involved in efforts at Newport and 12 Sauget to improve the spill situation similar to 13 Anniston? 14 A. Yes. 15 Q. That's within your job duties at Monsanto 16 when you were in St. Louis? 17 A. Yes. 18 Q. You went on to state, same paragraph, "I 19 believe it would help psychologically if the sandboxes 20 at the bases of all stairs were removed." Why did you 21 believe that? 22 A. Oh, just a personal, very subjective 23 approach where it occurred to me that perhaps, 24 individuals with dirty overshoes or work shoes were 25 relying too much on that little sandbox of correcting 314 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051453 1 a situation where they, instead of getting a new pair 2 of boots--I had no real basis for arriving at that. 3 It's just a subjective opinion that I offered. 4 Q. How big were these sandboxes? 5 A. I would say they were a yard by a yard, 6 three-by-three, or about that, and about four inches 7 deep in sand. 8 Q. Were they at the base of any staircase 9 within the Aroclor production area? 10 A. Yes. 11 Q. Where were--where were stairs located for 12 the Aroclor production area? Are they all over the 13 area, or is, is there only one -- 14 A. Each platform-- 15 Q. --or two stairwells? 16 A. --had at least two stairwells. Some had 17 three or four, depending on the activity involved and 18 the need to get to certain parts of the platform. 19 Q. I'll set that aside, and one more question 20 on that document. In that second paragraph, you 21 previously talked about the first sentence of that 22 paragraph when you were--the second sentence says 23 "This longstanding practice creates sand disposal 24 problems as well as a difficult floor scraping and 25 cleaning problem." What did you mean by that? 315 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051454 1 A. By which part of that? The -- 2 Q. Let's start with the sand disposal problem 3 part, first. 4 A. Well, it's--it required that the sand that 5 was used for this purpose be placed in a suitable 6 steel container which was eventually sealed and taken 7 to the plant landfill. That was perceived as a 8 disposal problem, sending it up there, making sure 9 it's handled properly when you do so, and burying it 10 properly when you do finish placing it, these kinds of 11 things had to be monitored, and I was trying to reduce 12 that need as much as I could. 13 Q. And the part of the sentence that refers to 14 a difficult floor scraping and cleaning problem, what 15 are you referring to there? 16 A. This referred to gritty floors stuck to 17 gooey Aroclors that have to be scraped up and--to 18 remove. 19 Q. Okay, now you can put that one aside. 20 Was sand used for any other purpose at the 21 Anniston plant other than with respect to spills and 22 the sandboxes that we've talked about? 23 A. The only other use I could recall--and it 24 was a small use --is the use of sand in mixing with 25 concrete to pour a concrete pad or something similar 316 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051455 1 to place a pump on, for example, that kind of use was 2 made with sand and concrete, of course, and water. I 3 cannot think of any other use at the moment. 4 Q. Were any of the storage tanks or other 5 equipment placed on a, a sand base? Only sand, not 6 sand and concrete, but just the sand? 7 A. No. To my memory, they were all on a 8 concrete platform. 9 Q. Do you know if that was true prior to your 10 arrival as a plant manager? 11 A. I do not. 12 Q. You referred to PCB losses earlier. Would 13 that include PCB losses to the atmosphere? 14 A. Would that what? 15 Q. You referred to PCB losses earlier today. 16 Would that include PCB losses into the atmosphere? 17 A. Can you help me recall what I said about the 18 losses earlier? 19 Q. It was a-20 A. What kind-21 Q. --phrase-22 A. --of losses? 23 Q. --you used, you were referring to to reduce 24 the amount of Aroclor losses or PCB losses. 25 A. Oh. 317 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051456 1 Q. I -- 2 A. For environmental control purposes? 3 Q. Yes. 4 A. When I refer to that type of loss, I was 5 really referring to the physical movement on the 6 ground. The losses to the atmosphere, the 7 characteristics of PCBs are such that the minute a 8 little bit of PCBs get up into the vapor, they're so 9 heavy, they sink, so if anything was released near a 10 tank into the atmosphere, it would generally end up in 11 that area; it doesn't go very far. Unless you have a 12 tornado driving it, it's just not going to move. 13 Q. So were there PCB vapors in the air 14 immediately around various pieces of equipment in the 15 Aroclor facility? 16 A. On occasion, when the operator, for example, 17 would open a tank and put this lye that they had near 18 the end of the process, some fumes would come up, and 19 as soon as he finished, he would seal that. 20 Q. Do you recall occasions when the workers 21 would wear ventilator equipment around the equipment? 22 A. I don't remember a specific occasion, but I 23 do know that they were issued, respirators, and of 24 course, other protective equipment, in the event the 25 vapors became greater than that bit that escapes while 318 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051457 1 they are adding an ingredient. 2 Q. Do you recall testing being done for PCBs in 3 the atmosphere in and around a Monsanto plant? 4 A. I don't recall any specific, but I do know 5 that there was an interest in the presence of PCBs in 6 the atmosphere, and I also recall samples being taken, 7 and I remember that the answer came that the quantity 8 found, if any, was extremely low, and at that time, 9 the ability of the analytical method to even measure 10 that low amount was dependable. 11 Q. Was not dependable? Is that what you meant? 12 A. Whether the ability to detect the PCBs at 13 such a small quantity was giving us a realistic 14 answer. It could have even been zero, but the method 15 says it's 1 part per billion kind of number. 16 (Defendant's Exhibit 30 17 marked for 18 identification.) 19 BY MS. LAVEY: 20 Q. The court reporter is handing you what we've 21 marked as Exhibit Number 30, which is entitled "The 22 Determination of Aroclor Concentrations in the 23 Atmosphere at Monsanto Chemical Company's Anniston, 24 Alabama, plant," Bates number MONS 058072 through MONS 25 058089. I'll ask you to take a few minutes, 319 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051458 1 Mr. Papageorge, and then let me know whether you 2 recognize this document. 3 (Witness peruses said 4 document.) 5 A. I have -- 6 Q. Have you ever seen this document? 7 A. As I read it just now, I was reminded that 8 this kind of study had been made, but it was perceived 9 to be inadequate in terms of methods of analysis. As 10 I understand, this was back in the Forties. 11 Q. I was going to ask you if you know when this 12 was prepared or if there was something in the document 13 that told you when it was prepared, because I don't 14 see a date. 15 MR. WETMORE: There is something at page 18, 16 the last page, there are some initials, with what 17 looks to be a date. It looks like June 26. I can't 18 tell what the other--it looks like 1953. 19 A. '53. The initials are Paul Benignus'. 20 Q. Paul who? 21 A. Benignus, B-e-g-n-i-g-n-u-s. 22 Q. B-e-n-i -- 23 A. B-e-n-i-g-n-u-s. 24 Q. Who is Paul Benig--Benignus? I'm not going 25 to be able to say that. 320 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051459 1 A. He was a Monsanto employee located in--at 2 the time I met him, he was located in St. Louis. I 3 don't know where he was in '53. I think he was in 4 Research Department; I'm not sure. Anyway, 5 Mr. Benignus was the, I'm going to call him a 6 technical advisor to the marketing people regarding 7 PCBs . 8 Q. What time frame are you referring to? 9 A. These are not exact dates, but from my 10 perspective, they refer to the time that I was at the 11 Anniston plant, '65-ish, and through '75 type 12 of--about ten-year period or so. 13 Q. Did you say you had seen this specific 14 report before? 15 A. I don't remember it as a specific report, 16 but the, the information it contained was relayed 17 verbally at discussions, and this was--this is the 18 memory that I recalled after reading this, was that 19 this is not totally new news, but it had been 20 considered. 21 Q. Do you know if subsequent studies similar to 22 this were done? 23 A. I don't remember the specifics, but I do 24 know that with modern analytical technology, sampling 25 of air in the plant was made, and the results of that 321 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051460 1 study show that PCBs were found at this tank opening I 2 mentioned earlier but not found at the plant fence; 3 that kind of logic was evolved as a result of the 4 study. 5 Q. You recall there was sampling at the plant 6 fence? 7 A. I used that as the end--that they took 8 samples away from the origin, and see how far they 9 could detect it. 10 Q. Did the sampling go off site? 11 A. I have a faint recollection that some were 12 taken out in the neighborhood, so to speak, but the 13 results, there, was zero detectable. 14 Q. What personnel would be more familiar with 15 the, any of the air sampling that was done that might 16 know this information more than you? 17 A. Ooh: I would personally start with 18 Mr. Wright. 19 Q. That's Eugene Wright? 20 A. Eugene Wright, yeah. 21 (Defendant's Exhibit 31 22 marked for 23 identification.) 24 BY MS. LAVEY: 25 Q. Handing you what's been marked Exhibit 322 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051461 1 1 --i 1 --i 1 CD IS Number 31, Bates range DSW 175777 through DSW 175786, which, for the record, is a collection of several different documents, so I'll give Mr. Papageorge a chance to look through them. (Witness peruses exhibit.) BY MS. LAVEY: Q. Although, Mr. Papageorge, these are all stapled together, I' m going to refer to them separately. I'm not. quite sure why this collection all in one -- A. All right. Q. --stapled set, so we'll-A. All right. I've read it. Q. A. I have scanned through it. Q. Okay. In reviewing, in reviewing these pages, has the identity of R. Thomas come back to you at all, Mr. R. Thomas? Previously, you indicated you weren't sure who that was. A. R. Thomas, no, I still don't recall him. Q. I think the easier page to read is on the last page, DSW 175786, a June 1st, 1970, memorandum which you prepared; correct? A. Yes. Q. And directed it to Mr. Savage. You state in 323 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051462 1 the first paragraph that "We should not neglect to 2 consider losses to the atmosphere through jet exhaust, 3 vents, stacks, et cetera. " Do you see that? 4 A. I do. 5 Q. So would you agree with me that there were 6 losses to the atmosphere through jet exhaust, vents, 7 stacks, et cetera? 8 A. No, that's-9 Q. Okay. 10 A. That doesn't say that. It says "consider 11 losses," which means look to see if there are any, and 12 how much if you do find them. 13 Q. Why was it important not to neglect to 14 consider that potential loss? 15 A. Well, the atmosphere is part of the 16 environment, and we had limited, if almost no data 17 regarding PCBs in the atmosphere, and we needed that 18 to assure ourselves that the atmosphere was considered 19 as part of the overall environment. 20 Q. And do you believe there were PCB losses to 21 the atmosphere from the Monsanto plant in Anniston? 22 MR. WETMORE: Did you just ask him that 23 earlier, 15 minutes ago? 24 A. I -- 25 MR. WETMORE: You can answer it again. I 324 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051463 1 think you did. 2 A. (Continuing) I believe there were losses to 3 the atmosphere at the site of the source. I had no 4 data at all to support the thought that those PCBs 5 would find themselves in the distance of any signature 6 enough cans. 7 BY MS. LAVEY: 8 Q. And you said earlier that PC--what you did 9 say earlier was that you believed the PCBs were such 10 that if they did emit into the atmosphere, they were 11 such that they would just drop right back down again. 12 A. Correct. 13 Q. So it's your belief that PCBs that are 14 released from a vent or whatever piece of equipment 15 would not move far from that facility? 16 A. That is correct. The movement will depend 17 on the wind velocity and direction. 18 Q. Wouldn't those, wouldn't those losses, even 19 if they didn't move far and they just dropped down, 20 doesn't that mean they dropped down on surfaces or on 21 to the ground in and around that equipment? 22 A. Yes. 23 Q. And then it would get washed away by storm 24 water, or washing off floors, or some activity like 25 that in that location? 325 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051464 A. And would be detected by analysis of those streams. Q. Of the water? A. Yes. Q. In your memo that we were looking at on the last page of this collection, DSW 175786, in the last paragraph, you ask, "Will you have each plant develop a program for auditing the present situation, monitoring on a plan basis and taking corrective action to achieve targeted losses to the atmosphere?" Do you see that at the end of the memo? A. I do. Q. Do you see if such a program for auditing was, in fact, put into place? A. I am left with an impression, yes, but I don't recall all the details. Q. Do you know who would be familiar with that program if it was put in place? A. Well, Mr. Savage for sure. That's the person I would start with. Q. If there weren't significant losses to the atmosphere going on, why would it be important, why would it be necessary to develop a program for auditing losses to the atmosphere? I'm having trouble understanding why we're going to the trouble of 326 Papageorge, William; McWane (3) (Former Monsanto Employee WATER PCB-SD0000051465 1 creating a program if losses to the atmosphere, to 2 your belief, aren't really going on. 3 A. Well, first of all, we had to confirm that 4 suspicion, and the suspicion is based on the 5 properties, the physical properties of the materials 6 called PCBs. In order to develop a program for 7 controlling the escape of PCBs into the environment, 8 you have to know, first of all, which PCBs, where are 9 they coming from, how do they get into the 10 environment, and with the information you accumulate, 11 you, you take action, whatever seems appropriate for 12 the--based on the information you get. This is just 13 one area that we wanted to become more familiar with 14 at that time. 15 Q. Did you, in fact, set targeted losses to the 16 atmosphere that's referred to, here, at the end of the 17 question I read? 18 A. Targeted loss is an expression--is an 19 attempt to set a goal for the participants in this 20 controlled program to meet and eventually, Monsanto 21 proposed, as I remember, eventually a one-part-per22 billion target, and that's the kind of targeted loss 23 that I had in mind. 24 Q. A one-point or one-part-per-billion loss in 25 total to wherever, whether atmosphere or, or-- 327 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051466 1 A. In the sample. 2 Q. In any sample, whether taken from water or 3 air? 4 A. Correct. 5 Q. And was that target achieved, to your 6 knowledge? 7 A. Yes. The EPA adopted it. 8 Q. Was there a time period where the sample 9 data came back and that target had not yet been 10 achieved? 11 A. The only occasion--are you talking about all 12 environmental samples or just atmospheric,-13 Q. Urn-- 14 A. --vapors. 15 Q. We'll go with atmospheric. 16 A. Atmospheric? Ooh, that was achieved almost 17 instantly. They never did find evidence that such a, 18 a number existed. 19 MR. WETMORE: How you doing, Bill? All 20 right? 21 MS. LAVEY: Why don't we take a five-minute 22 break? 23 MR. WETMORE: Good idea. 24 MS. LAVEY: This will end tape number 2, 25 deposition of William B. Papageorge. We're off the 328 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051467 1 record at 10:54 A.M. 2 (Recess.) 3 THE VIDEOGRAPHER: We're back on the record 4 at 11:05 A.M. This will begin tape number 3 of the 5 deposition of William B. Papageorge. 6 BY MS. LAVEY: 7 Q. Mr. Papageorge, while you were plant 8 manager-- 9 THE VIDEOGRAPHER: Excuse me a second. 10 We'll have to go off the record. We're off the record 11 at 11:05. 12 (Discussion off the record.) 13 THE VIDEOGRAPHER: We're back on the record 14 at 11:07 A.M. 15 BY MS. LAVEY: 16 Q. Mr. Papageorge, to your knowledge, was any 17 incineration done at the Monsanto plant in Anniston? 18 A. Help me; with incineration of what? 19 Q. Were PCBs or PCB waste material ever 20 incinerated at the Monsanto plant in Anniston? 21 A. No. 22 Q. Was any burning of waste taking place of any 23 kind at the Anniston plant? 24 A. Yes. 25 Q. Where would that take place? 329 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051468 1 A. In the general area of the--that we've 2 referred to as the plant dump that is a form of 3 landfill, there was at one time when I arrived a 4 location at which the burnable material of the plant, 5 which included waste lumber, office trash, broken 6 pallets, these kinds of things, were burned. When the 7 amount that accumulated reached a reasonable 8 lever--level, the decision would be made to ignite it 9 and let it burn. 10 Q. So this was at a set location within the 11 plant dump area? 12 A. Correct. 13 Q. Who had responsibility for that burn area? 14 A. The individual in charge of warehousing, 15 shipping, and I still cannot remember his name. 16 Q. You knew I was going to ask that next, 17 didn't you? 18 Over what period of time, if you know, was 19 the burning done out on the plant dump? You said it 20 was there when you arrived? 21 A. It was there when I arrived, yes. 22 Q. Had that been a practice that had been going 23 on, to your knowledge, for some time prior to your 24 arrival? 25 A. Yes. 330 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051469 1 Q. And was it still going on when you left? 2 A. I don't recall when it was discontinued. It 3 was my intent to discontinue it, and I don't know if I 4 instituted it before I left or whether it was followed 5 up later. 6 Q. Why was it your intent to discontinue that 7 practice? 8 A. Well, one of the principal reasons was that 9 there were services becoming available to haul such 10 kind of waste away from the plant to a commercial 11 disposal site, and the amount of material that 12 accumulated there at times became a burden on the 13 people to get set, go out and manage the burning 14 process, so it struck me that a more efficient way to 15 do it is to have commercial waste haulers arrive and 16 pick up that kind of waste. 17 Q. Were distillate bottoms ever burned at that 18 location? 19 A. No. 20 Q. Any PCB-containing waste material at all? 21 A. No. 22 Q. Did everybody in the plant have access to 23 the plant dump, or was access restricted? 24 A. The, the transfer of chemical waste was to 25 the dump was conducted by the group that had the 331 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051470 1 warehousing, shipping material movement 2 responsibility. That group would be the ones to man 3 the forklifts and the trucks, whatever it took to get 4 wastes up there, so it was monitored and handled 5 properly by a group that was instructed on how to 6 handle that kind of waste. 7 Q. Was the entrance to the dump area gated and 8 locked? 9 A. No. 10 Q. So orthopedics could get into that dump area 11 if they chose to; correct? Other than this 12 warehousing group of people charged with the 13 responsibility? 14 A. You mean people could walk up there? 15 Q. Sure. 16 A. Yeah, there was nothing to stop any walkers, 17 but the use of equipment would have attracted 18 attention, trucks, and forklifts, and that kind of 19 activity, and to my--that was never done in my era 20 there. 21 Q. Was there a roadway leading up to the top of 22 the dump area? 23 A. Yes, there was a--it's a dirt road. It was 24 not a paved road. 25 Q. Was the paved road also leading to the area 332 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051471 1 that the burning was done? 2 A. No. It was a gravel road. 3 Q. Okay. To your knowledge, did Monsanto ever 4 test emissions at the Anniston plant for heavy metals? 5 A. Not to my knowledge. 6 Q. Do you know if Monsanto ever studied 7 emissions from any of its other plants for heavy 8 metals ? 9 A. I do not know. 10 Q. Could you see dust in the air at the 11 landfill? 12 A. Dust in the air? Never. 13 Q. Could you see plumes in the sky originating 14 from the Monsanto Anniston plant? 15 A. When you--when I used to drive up close to 16 the plant, I could see the expected steam plumes, but 17 I don't recall any situation that resulted in a, a 18 cloud of some strange material. 19 Q. What about when there were these non-routine 20 emissions that we spoke about earlier that were 21 covered in the plan that was put into place for 22 reporting spills and such? Would those unusual air 23 emissions cause a cloud of material into the 24 atmosphere? 25 A. When such an emission occurred, the, the 333 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051472 1 plume would only be, at most, six feet, right above 2 the tank, so you wouldn't see anything out surrounding 3 the facility or its neighboring facility. 4 Q. When you refer to the plant dump, do you 5 know if that is what is referred to today as the 6 south landfill? Is that term familiar to you? 7 A. I have never used the expression 8 "south landfill," so I don't know what it refers to. 9 Q. Are you aware that there was a second dump 10 location that had been utilized by the plant prior to 11 your arrival as plant manager in 1965? 12 A. I was not aware of a previous landfill. 13 Q. So you are only familiar with one location 14 that you are calling the plant dump? 15 A. Correct. 16 Q. Where was the plant dump located? 17 A. Again, I'm not oriented east, west, north or 18 south. All I know is it was uphill from the general 19 plant area. 20 Q. Wasn't it--was it located across the road 21 from the manufacturing area, as well? 22 A. I'm hesitating because I'm confused with the 23 installation of that new roadway, and since I wasn't 24 there when that road was constructed, I have a hard 25 time visual--I don't remember crossing a road to get 334 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051473 1 high up on that landfill. 2 Q. Do you remember that, that landfill being up 3 against a clay or dirt wall? 4 A. I suppose you could call that a clay or dirt 5 wall, yes. There was a, there was a, a geographical 6 feature that we used to cut into to make an opening to 7 hold the drums that we wanted to cover the excavation 8 that occurred during the making of that hole was set 9 aside and was eventually used to replace on top of the 10 disposal containers, and that was intended to keep 11 them from contaminating the whole area. 12 Q. So you didn't have to bring in fill from 13 elsewhere? You were able to use the excavated 14 material? 15 A. Correct. 16 Q. And was the responsibility for the landfill 17 again with the same individual or group of folks who 18 were the warehousing--!'ve forgotten the title, but 19 the warehousing area? They also had responsibility 20 for the entire operation at the landfill? 21 A. Yes. 22 Q. Okay, not just I know we talked about it 23 before, but we were speaking of the burn area before, 24 but for the landfill, same group of people; correct? 25 A. Correct. 335 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051474 1 Q. Do you know when that dump first began to be 2 used? 3 A. I do not. 4 Q. Do you know when they stopped dumping 5 material in that landfill? 6 A. I do not. 7 Q. Do you know how the dump area was 8 constructed initially? In other words, did it 9 have --are you familiar with its, its features in terms 10 of a bottom liner, perhaps, if there was such a thing, 11 or any divisions between cells? I mean physical 12 features of the landfill. 13 A. I do not know what occurred when they 14 started using it. 15 Q. Was there any run-on, runoff controls in 16 place at the landfill to direct storm water flow one 17 way or the other at the landfill? 18 A. At what point in time? 19 Q. When you arrived in 1965. 20 A. No, the water flow was left up to the--to 21 Nature, in a way. It went its own way. 22 Q. So it could flow across the landfill? 23 A. I find it difficult to perceive water going 24 across unless it was coming from a higher level to a 25 lower level. Generally, the height started at the 336 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051475 1 rear and flowed right down toward the plant. 2 Q. Is there any specific individual you can 3 think of who had responsibility for that landfill? 4 A. I think of the plant manager. I don't think 5 that's the person you are looking for. It's this 6 person--I wish I could remember his name--the 7 warehousing superintendent and his team. 8 Q. Did there come a point in time where regular 9 inspections of the landfill began? 10 A. While I was there, or later, you mean? 11 Q. At any point, to your knowledge. 12 A. At any point? There were occasions when 13 individuals would go up that landfill to see if it was 14 creating any kind of problems; in other words, to 15 determine whether the waste material was placed 16 properly, was it covered properly, are there any 17 visible problems. That was done when I was there and 18 the trips that I made thereafter. 19 Q. Were any liquid waste materials placed in 20 the landfill? 21 A. Yes. I'm trying to remember specific 22 examples. There were some containers containing 23 material that was not recoverable for resale and had 24 to be disposed of that were placed in drums, steel 25 drums, liquid drums, not the open top, but the drums 337 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051476 1 with the two openings, they were placed up there. I'm 2 trying to remember the specific chemicals involved. I 3 can't think of it now. 4 Q. Were any bulk liquids placed in the--that 5 were not containerized placed in the landfill? 6 A. No. 7 Q. Do you know prior to 1965 whether liquids 8 were placed in the landfill that were not 9 containerized? 10 A. '65? 11 Q. When you arrived in '65,-12 A. Oh. 13 Q. --do you know if, before that time, whether 14 liquids were placed in that landfill that were not 15 containerized? 16 A. I do not know. 17 Q. Were there security guards in place at the 18 landfill while you were there as plant manager? Was 19 there any security guards stationed over at the 20 landfill area? 21 A. Not at the landfill area. 22 Q. The liquid wastes that you were --or liquid 23 material you are describing that would have gone to 24 the landfill in the drums, would that be 25 PCB-containing liquid material? 338 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051477 1 A. It's possible, but I don't know for sure, 2 for sure, hmm-mm. 3 Q. Were there specific staging areas within the 4 plant to collect drums, and so forth, before being 5 transferred over to the plant dump? 6 A. There were areas set aside by the department 7 supervisor of each operation where this kind of 8 material would be kept until the warehousing team 9 could come by and put it on pallets and carry it up to 10 the landfill, and this varied, of course, with the 11 type of activity that that production unit had 12 undergone, and the material they were producing, so 13 the frequency, the material, and amount would vary. 14 Q. Was there a staging location at the Aroclor 15 facility for drums of waste material? 16 A. Yes. 17 Q. Do you recall where that was located? 18 A. All I remember was on the edge, out of the 19 way of the operation, so it didn't hamper any 20 movements. 21 Q. So that was out in the open, not undercover? 22 A. That's right, yes. 23 Q. Was that area on the dirt ground, or was 24 there some gravel surface or paved area for the 25 staging location? 339 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051478 1 A. I recall, it could be either a plain old 2 natural dirt environment or it could be crushed rock 3 that had been poured there. I don't recall any 4 deliberately poured concrete pavement for this kind of 5 activity, no. 6 Q. Do you remember any other location for 7 on-site for disposal on site on property owned by 8 Monsanto other than the dump, the plant dump that 9 we've been speaking of? 10 A. For disposal purposes? No. Hmm-mm. 11 Q. Was there ever, to your knowledge, any 12 injection of waste, deep well injection on site of 13 waste material? 14 A. No. 15 Q. Were there dumpsters located throughout the 16 facility? 17 A. I'm sorry? 18 Q. Were there dumpsters located throughout the 19 plant, for trash and such? 20 A. By "dumpsters," you mean containers? 21 Q. My use of the word "dumpster" is generally 22 envisioning kind of a rectangular-shaped large box 23 without a lid, into which you can throw trash. 24 A. I don't recall any such container. 25 Q. Do you recall any type of receptacle for 340 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051479 waste material generated in any of the production areas other than the drums that you've talked about, either the open drum or the closed one with the hole in it? A. That's the only kind I recall. Q. Are you aware of any location offsite that was used by the Monsanto Anniston plant for disposal of waste? A. No, I'm not. Q. Was trash checked by the, by the city from the plant? A. Not to my knowledge. Q. We talked, probably on the first day, about montars, and as I understand it, some of the montars were sold, some of the montars were disposed. Do you remember talking about the that on the first day? A. That is correct. Q. And would that montar that was not sold go to the, to the plant dump that we've been talking about? A. Yes. Q. How is it determined which montars could be sold and which would need to be disposed? A. The montars that were sold were prepared in anticipation of receiving an order, so a modest 341 Papageorge, William; McWane (3) (Former Monsanto Employee WATER PCB-SD0000051480 1 inventory was kept. Once that inventory was 2 fulfilled, any montars that were still being created 3 would go straight to the landfill until the inventory 4 of the salable material reduced to a low point and 5 then they'd make some more of it. 6 Q. What's the--the montars that went to the 7 landfill, what was its consistency? Is this a liquid? 8 Semi-solid? I'm not--I have trouble picturing montar. 9 A. When it went to the landfill, it, it looked 10 an awful lot like road asphalt. It was a solid; black 11 solid. 12 Q. Are you aware of any testing that was done 13 to determine the content of montars? 14 A. I'm not. 15 Q. What was in a montar pit? Are you familiar 16 with that term? 17 A. No, I can't place that expression. 18 Q. When you said there was an inventory of 19 montars built up for anticipated customers, where 20 would that inventory be stored? 21 A. It'll be in, excuse me, metal containers, 22 the open-top type, with a label on it, in with the 23 finished product, warehousing facility. 24 Q. Was it kept heated in order to keep it in 25 more of a tarry consistency? 342 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051481 1 A. No, it was allowed to reach the solid state. 2 It's a round, solid chunk of black material. 3 Q. Okay, and then you indicated that if you had 4 enough of an inventory built up, then any further 5 montars that were generated would go straight to the 6 landfill. 7 A. Correct. 8 Q. Would they--are they taken from the 9 production process and hauled immediately off to the 10 landfill, or is there an intermediary step where they 11 are stored? 12 A. No--well, they were temporarily stored until 13 you got enough to, to make the trip worthwhile. 14 Q. And how were they temporarily stored? 15 A. Out in the open, in these steel containers, 16 and when, when time permitted the warehousing team to 17 come by, they would put these drums on pallets, and 18 then when the next opportunity came, they'd take those 19 pallets and take them up the hill to the landfill. 20 MS. LAVEY: Okay. 21 (Defendant's Exhibit 32 22 marked for 23 identification.) 24 BY MS. LAVEY: 25 Q. The court reporter has handed you what--a 343 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051482 1 document we've marked as Exhibit Number 32, which is 2 DSW 090928 through DSW 090932. The top of the 3 document says, "Tier 1 Waste Handling Summary 4 Document," and I'll direct you generally to some of 5 the last pages, which would suggest this document was 6 prepared in the 1988 vintage. 7 (Witness peruses 8 said document.) 9 Q. I know this is only a 1988 document or 10 thereabouts. I only have a couple of questions for 11 you and recognize it's past your time as an employee 12 at Monsanto, but I did want to ask you just to clarify 13 for me this--the first page refers to production of 14 polyphenyls. Would that include--would that be a term 15 that would encompass biphenyl production and 16 terphenyl? 17 A. Correct. 18 Q. Under number 3, it describes current waste 19 handling and land disposal practice, stating the 20 molten material is currently pumped into open pits in 21 the ground where it is allowed to harden by cooling. 22 Do you recall whether such a practice was in place 23 while you were at the Anniston plant? 24 A. That is news to me. 25 Q. When you arrived at the Anniston plant in 344 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051483 1 1965, there was a waste water treatment plant at the 2 facility, wasn't there? 3 A. Yes. 4 Q. Was that associated with the Aroclor 5 production area or the insecticide production? 6 A. Insecticide production. 7 Q. So--and that was separate, then, from the 8 Aroclor area? 9 A. Correct. 10 Q. Did there come a point in time when a waste 11 water treatment plant was put into place specific to 12 the Aroclor-producing area? 13 A. No. 14 Q. Who had the responsibility for the waste 15 water treatment plant in the parathion area? 16 A. At what point in time? 17 Q. When you arrived in 1965. 18 A. Arthur Liese. 19 Q. He was the manufacturing superintendent for 20 that production area, correct? 21 A. Correct. 22 Q. Was he still the person responsible for that 23 waste water treatment facility in 1969, when you left? 24 A. No. 25 Q. Was there a subsequent superintendent of 345 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051484 1 manufacturing at that point? 2 A. Yes. 3 Q. Who was that individual? 4 A. Lloyd Bosch, B-o-s-c-h. 5 Q. Was his area of responsibility limited to 6 parathion and the intermediate products that were 7 made--used to produce parathion? 8 A. Correct. 9 Q. Was he also responsible for the HB-40 10 production? 11 A. No. 12 Q. That would lie within Robert Moody's area of 13 responsibility when he was production superintendent? 14 A. When he, when he was--yes. 15 Q. And his successor? 16 A. Right. 17 Q. Okay. Did that waste water treatment plant 18 receive process waste water from the parathion 19 production process? 20 A. Yes. 21 Q. Did it also handle storm water in any way? 22 A. Some of the storm water ended up in that 23 treatment basin. That did not take care of all the 24 storm water that was possible from all directions. 25 Q. So that treatment plant system included an 346 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051485 1 open settling pond of some kind? 2 A. Yes, it was, it was a rectangular-shaped 3 basin. 4 Q. This is prior to treatment in the plant, or 5 after going through treatment? 6 A. That was part of the treatment. 7 Q. The first step before any further treatment? 8 I'm just trying to get the order of things. What did 9 the treatment plant psychiatrist of? 10 A. It included this basin, to which they would 11 add some --I forget the detail-some materials to help 12 partially treat that waste. 13 Q. Was--was sanitary waste water tied into 14 public sewer system, do you recall? 15 A. Yes. Yes. 16 Q. Throughout the period that you were there? 17 A. Yes. 18 Q. Do you know at what point in time the 19 sanitary system tied into the public sewers? 20 A. No, I don't. 21 Q. Switching over to the biphenyl and Aroclor 22 facility area, you've talked a number of times about 23 the natural flow of storm water. Was there also a 24 process waste water generated at the Aroclor facility? 25 A. You say was there a process waste water 347 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051486 1 generated? 2 Q. Yes. 3 A. Yes. 4 Q. Where would that--what, what production 5 process would create that waste water stream? 6 A. The chlorination of the bi- and tribiphenyls 7 (sic) would result in a waste acid stream that, on 8 occasion, would contain some of the chlorinated 9 products, and that's the stream that went into the 10 limestone pit. 11 Q. Do you recall when the limestone pit was put 12 in? 13 A. It was there when I arrived. I do not know 14 when it was erected, when it was constructed. 15 Q. Do you know--could you describe how big the 16 limestone pit was? 17 A. I don't remember the definitions: About 18 double this room or something like that. I'm 19 guessing, now. 20 Q. What was it made out of? Is it just a pit 21 dug in the ground, or is there a wall of some sort? 22 A. It was a hole in the ground, and they put in 23 some clay, and I don't know where the clay came from, 24 but it was brought in and lined with this clay which 25 was supposed to reduce the water absorbency, and that, 348 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051487 1 in turn, the clay was covered with crushed limestone, 2 and the process water from the chlorination process 3 would flow into that facility. 4 Q. And at some point in time, it then is 5 allowed to flow from that pit, I assume? It exits 6 that pit eventually; correct? 7 A. Oh, yes. Yes. 8 Q. And where does it go at that point? 9 A. It would follow the natural flow of storm 10 water from the area into a--I personally call it a 11 drainage ditch. 12 Q. So is it--was the pit designed to allow a 13 certain amount of retention time before the flow would 14 follow the storm water direction? 15 A. It was, it was sized to accomplish that, 16 depending on the expected flow, the size of the 17 stream, and there was some attempt made to allow for 18 severe storms that would come up, but that's a 19 difficult estimate to make, but the whole intent was 20 to release to this ditch a material that was reduced 21 in acidity and in PCB content. 22 Q. How would the PCB content be affected by the 23 presence of limestone in the pit? 24 A. Gravity would take over. The PCBs, being 25 heavier than water, sink once they're allowed to 349 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051488 1 settle down instead of being churned through the 2 system, and those PCBs would end up down with the 3 limestone which, in turn, was reacting with the acid 4 to neutralize the acid. 5 Q. Would the, the limestone pit need to be 6 periodically cleaned out? 7 A. Yes. 8 Q. How frequently would that occur? 9 A. Oh, I don't have a recollection of the 10 frequency. 11 Q. Who would know that type of information? 12 A. It would have to be the supervisor of the 13 operation. 14 Q. The Aroclor operation? 15 A. The Aroclor operation, based on the amount 16 of products they produced for a period of time, and 17 some products produce more acid, some products produce 18 heavier PCBs, settle and sort of affect this acid 19 reduction process, so it's up to the manufacturing 20 supervisor to tell his team, "Hey, we've got to clean 21 it out." 22 Q. Would you say that's a once-a-year event, or 23 more or less frequent than that, during the time that 24 you were plant manager? 25 A. I, I, personally, did not keep score, but it 350 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051489 1 seems to me it was a matter of twice a year, maybe. 2 Q. And was the Aroclor Department, itself, 3 then, responsible for doing that clean-out? 4 A. They were responsible for seeing that it was 5 done. They did not have any of the equipment 6 necessary, like the bulldozers and that kind of thing, 7 so they would arrange for it to be done. 8 Q. And then who, who did have the 9 responsibility of actually doing the cleanout? 10 A. It would fall on the Maintenance Department 11 to help them. 12 Q. Do you know where the cleanout material 13 would be taken after it was removed from the pit? 14 A. To this landfill. 15 Q. So it would be hauled over there in dump 16 trucks ? 17 A. Yeah. 18 Q. Would it be allowed to drain? The material 19 that's removed from this pit, is it allowed to drain 20 prior to being moved over to the landfill? 21 A. Mm, that, I don't know how they did that, 22 no. 23 Q. Do you recall ever seeing the material piled 24 up alongside the pit after having been removed? 25 A. I do not recall that. 351 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051490 1 Q. And the, the general setup was such that the 2 water is going to exit the pit dependent upon the 3 level of the water within the pit; correct? It's 4 essentially an overflow-- 5 A. Yes. 6 Q. --situation? 7 A. Yes. 8 Q. So if you had a heavy rain event, it would 9 overflow-- 10 A. Yes. 11 Q. --out of that pit, whether or not it had had 12 the desired retention at that point in time? 13 A. That is correct. 14 Q. Somewhat subject to the whim of the weather? 15 A. Correct. 16 Q. The ditch to which this flowed, you've not 17 heard a name associated with that ditch? Just the 18 plant ditch? 19 A. I've heard a name. The plant personnel 20 referred to it as Snow Creek. 21 Q. Okay. 22 A. But really, it's not Snow Creek, it's a 23 ditch leading to Snow Creek, but since it had no name, 24 the plant personnel adopted Snow Creek as the 25 reference because the material, the liquid, eventually 352 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051491 1 ends up in Snow Creek, so -- 2 Q. Do you know if people called it the Monsanto 3 ditch? 4 A. I've never heard that expression. 5 Q. Do you know if it's the same as the 11th 6 Street ditch? 7 A. 11th Street ditch? I've never heard that. 8 Q. Were there cooling waters used in connection 9 with the--with compressors at the plant? Is there any 10 non-contact cooling water? I'll break the question 11 up. Was there non-contact cooling water used at the 12 plant? 13 A. Yes, there were. 14 Q. In what connection was the non-contact 15 cooling water used? 16 A. Well, we made reference to it earlier in 17 relationship to the flaking-- 18 Q. Right. 19 A. --and using cooling water to cool down the 20 liquid to make a flake? That kind of water. And of 21 course, that was recycled, and reused, and-- 22 Q. That's what I was going to ask. That was 23 not a once-through cooling, that was a recirculating 24 system? 25 A. Recirculating, yes. 353 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051492 1 Q. Was there a holding tank,-- 2 A. Yes. 3 Q. --then, that fed the water to that system? 4 A. The water, mm-hmm. 5 Q. Can you think of any other system that was 6 using a non-contact cooling water? 7 A. Not at the moment, but it's not a, an 8 uncommon usage. 9 Q. Do you recall whether non-contact cooling 10 water was directed to the limestone pit? 11 A. To my knowledge, it never was. 12 Q. When you referred earlier to occasionally 13 hosing down the floors in the Aroclor area,-14 A. Mm-hmm? 15 Q. --that water would flow to the limestone 16 pit; is that correct? 17 A. Correct. 18 Q. I believe you said that the water you were 19 using was all city water? Is that--am I remembering 20 that correctly? 21 A. That's my understanding, yes. 22 Q. Do you know if there was a point in time 23 when well water was being used? 24 A. I don't remember any mentioning of wells. 25 Q. Were there fire protection systems, water 354 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051493 1 systems on--at the plant? 2 A. Yes. 3 Q. And was that water also city water? 4 A. Yes. 5 Q. Do you remember when the scrubber was put in 6 at the Aroclor facility? 7 A. The scrub-- 8 Q. The scrubber? There's a scrubber associated 9 with the off gases, with the HC1, I believe we were 10 describing the other day? 11 A. Yes, I remember a reference to "scrubber." 12 Q. Do you remember when the scrubbers were put 13 in? 14 A. I do not. 15 Q. Do you know where the--was water generated 16 off of those scrubbers? Water was used in the 17 scrubber, correct? 18 A. Water was used to scrub. 19 Q. And where would that water go? 20 A. It would end up in the muriatic acid that 21 was formed. 22 Q. Okay. Did the limestone pit receive any 23 waste water streams from any location other than the 24 Aroclor production facility? 25 A. Not to my knowledge. 355 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051494 1 Q. Do you know if the--any waters from cleaning 2 or something from the warehouse would end up at the 3 limestone pit? The new, the new warehouse? 4 A. I believe, yeah, the, the topography is such 5 that even from the warehouse, the flow, the natural 6 flow of that whole area was such that it would end up 7 at that limestone pit area. 8 Q. Were there floor drains throughout the 9 Aroclor facility? 10 A. Not while I was there. 11 Q. Were there sewer--were there actual storm 12 drains located throughout the, the area around the 13 Aroclor facility? 14 A. Storm drains? No. 15 Q. So the water is not flowing through hard 16 piping, it's just flowing over land; right? 17 A. That's right. 18 Q. And were there storm sewers located 19 elsewhere at the plant that you recall? 20 A. I don't remember any reference to storm 21 sewers, hmm-mm. 22 (Defendant's Exhibit 33 23 marked for 24 identification.) 25 BY MS. LAVEY: 356 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051495 1 Q. I'm handing you what's been marked as 2 Exhibit Number 33, Bates range DSW 106999 through DSW 3 107002. I'll give you a few moments, here, to take a 4 look at it before I ask a question. 5 (Witness peruses said 6 document.) 7 A. I have reviewed the exhibit. 8 Q. Although I don't see your name on this 9 anywhere, do you have any recollection of seeing this 10 memo previously? 11 A. First time I've seen it. 12 Q. The document refers to--is titled "Analysis 13 of Anniston Plant Waste Streams For Metals." Do you 14 have--do you know why the Anniston plant waste streams 15 were being analyzed for metals? 16 A. I do not. 17 Q. Did you have any involvement in waste 18 analysis if it didn't deal with PCBs at this time 19 frame? 20 A. No. 21 Q. At the end, the bottom of the page, it 22 states "Possible problem areas in meeting the 23 standards for public water supplies exists with lead, 24 mercury, selenium and phenyls." Reading that sentence 25 as you sit today, do you have--do you know what--why 357 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051496 1 there would be possible problem areas in meeting those 2 standards? 3 A. No, I don't. 4 Q. Waived based on your understanding of the 5 production processes while you were plant manager, why 6 would there--why, why would any of these heavy metals 7 be present, in your mind? Is there reason to believe 8 any of these heavy metals would be present in the 9 waste streams, based on your understanding of the 10 manufacturing processes? 11 A. For the Anniston plant? 12 Q. Yes , sir. 13 A. I have no basis for that. 14 Q. Who is M. E. Webb? 15 A. Don 't know. 16 Q. Up at the top, do you notice who T. Bell 17 A. I do not know or remember him. 18 Q. At any other time when you were employed 19 with Monsanto, do you recall an analysis being done of 20 heavy metals in waste streams? 21 A. No. 22 Q. Hopefully, in your pile, there is exhibits 23 from the first day. If you can go back in there and 24 find Exhibit- 25 MR. WETMORE: That's my copy, but I'm happy 358 Papageorge, William; McWane (3) (Former Monsanto Employee; WATER PCB-SD0000051497 1 to let him do it. 2 MS. LAVEY: Oh, we have the originals right 3 here. That's right, we pulled those out before. I'm 4 going to pull out what were marked as 4 and 5 on the 5 first day, I'll ask a few questions, and then I think 6 we'll do our lunch break. 7 MR. WETMORE: Okay. 8 BY MS. LAVEY: 9 Q. Starting--I'11 talk a little bit about what 10 was going on in 1973 that these letters relate to, 11 Exhibit 4 and 5. In 1973, you were in St. Louis, 12 correct? 13 A. Correct. 14 Q. With the "Product Acceptability" title or 15 something like that? 16 A. That's correct. 17 Q. And was one of those responsibilities, then, 18 to respond to inquiries from customers as to the 19 content of different Monsanto products? 20 A. Yes. 21 Q. Do you recall the time period that is being 22 referenced here in your 1973 letter talking about 23 newly promulgated OSHA standards? 24 A. Well, both of these are dated '73, so -- 25 Q. Do you remember a period of time when in 359 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051498 1 your position as with product acceptability, you had 2 to respond to a series of inquiries from different 3 customers about the possible content of chemicals of 4 concern under the OSHA regulation? 5 A. Yes. 6 Q. Okay. Looking at Exhibit 4, which talks 7 about lampblacks, which you have testified to on 8 Monday as a Monsanto product you don't recall, now 9 that we're on day three, do you have any recollection 10 today of lampblack number 2 or lampblack generally? 11 A. I do not. 12 Q. Do you recall specific communications with 13 Worcester Coatings and Chemicals, to whom you 14 addressed this letter? 15 A. I do not. 16 Q. Do you know, when you are looking at Exhibit 17 4, recognizing this is back in 1973, when your letter 18 says, "Lead less than 10 parts per million," do you 19 know, sitting here, is that an indication that there 20 is some amount less than 10, or is that a detection 21 limit? Do you have any recollection today? 22 A. I do not. 23 Q. Do you remember whether there were further 24 communications back and forth relating to the 25 potential heavy metal content of various Monsanto 360 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051499 1 products ? 2 A. I do not. 3 Q. Was one of your responsibilities in the 4 1970's in the product acceptability role to 5 communicate with customers on the proper use and 6 handling of PCB products? 7 A. That was part of my product group, and when 8 a request would come in about --or a question would 9 arrive about, concerning PCBs, I tried to respond. 10 Q. Were you tasked with affirmatively going out 11 to customers to discuss with them the appropriate use 12 of PCB material, whether or not they wrote to you 13 first? 14 A. Yes. 15 Q. Do you recall what customers you made those 16 approaches to? 17 A. No, I didn't. 18 Q. Would it be to the big customers like 19 Westinghouse and General Electric, as examples? 20 A. That's unlikely, because they were so 21 familiar with those materials and had established 22 their own guidelines that they used for their 23 operations, they'd be the least apt to request 24 additional information. 25 Q. Did you have any dealings with any of the 361 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051500 1 foundry operations in Anniston after you left as plant 2 manager of the Anniston plant? 3 A. I did not. 4 MS. LAVEY: Why don't we break? 5 MR. WETMORE: Okay. 6 THE VIDEOGRAPHER: This will end tape number 7 3 in the deposition of William B. Papageorge. We are 8 off the record at 12:08 P.M. 9 (Luncheon recess.) 10 THE VIDEOGRAPHER: We're back on the record 11 at 1:29 P.M. This will begin tape number 4 in the 12 deposition of William B. Papageorge. 13 EXAMINATION 14 QUESTIONS BY MS. O'NEAL: 15 Q. Good afternoon, Mr. Papageorge. 16 A. Good afternoon. 17 Q. My name is Lynne O'Neal, and I represent 18 Phelps Dodge, and I want to ask some questions that 19 are follow-ups, primarily, of what you've been asked 20 over the past three days, nothing that would be 21 duplicative, hopefully, but just to fill in some gaps. 22 You testified on our first day that you 23 served as a consultant to a law firm involved with 24 Monsanto/Solutia litigation. What was the name of 25 that law firm? 362 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051501 1 A. Smith Moore, LLP. 2 Q. And they are located where? 3 A. Greensboro, North Carolina. 4 Q. And how long have you had that consultancy 5 relationship with the Smith Moore firm? 6 A. Help me with the relationships. Initially, 7 I first met members of that firm in 1970 or 8 thereabouts, '71. Later, the relationship became more 9 formal in terms of I signed an agreement with them 10 that I would participate in issues involving PCBs and 11 Monsanto at that time, so--and this was roughly 12 1972-ish. These dates are not exact, but it's that 13 period. 14 Q. Has the relationship that you have with the 15 Smith Moore firm changed any since you signed the 16 agreement with them for the more formal arrangement in 17 the 1972 time period? 18 A. The relationship hasn't changed. My--the 19 role I play is roughly the same except that it becomes 20 now one--it has become through the years a case of 21 discussing with new attorneys that come on board, the 22 preparation of some TV video tapes that are used by 23 the firm whenever I am not available, and that's 24 about--it continues that way. 25 Q. Now, you mentioned some videos you had made 363 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051502 1 for when you are not available, are those basically 2 provided as a educational materials where you provide 3 your knowledge and information concerning the PCBs and 4 the Monsanto processes to these other lawyers? Is 5 that what the purpose is? 6 A. That's one type. 7 Q. Okay, what other types are there? 8 A. The other type is similar to the tape now 9 being taken. Portions of those tapes that are 10 available are used; I don't know how, but I know 11 they're used somewhere. 12 Q. Okay. How long have you been on a retainer 13 basis as a consultant with the Smith Moore firm? 14 A. About 1972-ish. 15 Q. About the time the relationship was 16 formalized? 17 A. Yes. 18 Q. And has the amount of the retainer, the 19 thousand dollars that you mentioned the first day, 20 remained, per month remained constant during that 21 period of time or has it changed? 22 A. At one time, it increased. 23 Q. Above the thousand or -- 24 A. Above. 25 Q. Okay, and do you receive that retainer each 364 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051503 1 month from that firm, regardless of whether any 2 services are required for that month? 3 A. Yes. 4 Q. You also testified on the first day that you 5 had spent approximately eight to ten hours with 6 Mr. Nassif and Mr. Mike Kelly from the Smith Moore 7 firm in preparation for your deposition. Do you 8 recall that? 9 A. Correct. 10 Q. Did you have the opportunity or did you 11 actually review the Complaint in this lawsuit in 12 connection with your preparation? 13 A. I don' t remember any review of the 14 Complaints . 15 Q. Okay. Have you ever seen the Complaint or 16 read the Complaint-17 A. No . 18 Q. --that we're deposing you about in this 19 case? 20 A. No . 21 Q. Okay. Have you assisted anyone in 22 connection with answering interrogatories or providing 23 information to be disclosed to the parties in this 24 case? 25 A. No . 365 Papageorge, William; McWane (3) (Former Monsanto Employee; WATER PCB-SD0000051504 1 Q. What is your understanding, Mr. Papageorge, 2 with regard to the nature of this lawsuit that we're 3 deposing you about today? 4 A. My understanding is that the presence of, 5 I'm going to call them chemicals, materials in the 6 Anniston area are such that representatives of 7 Solutia-Monsanto find it puzzling as to where these 8 materials got to where they are, first of all, what 9 are they and how did they get there, and that seems to 10 be the, the major issue. 11 Q. And what was the source from which you 12 derived that understanding? 13 A. Mr. Nassif and Mr. Kelly. 14 Q. And you mentioned that some representatives 15 of Monsanto/Solutia find it puzzling as to the 16 materials that have been found and how they got to 17 where they are. What representatives of 18 Monsanto/Solutia were you referring to? 19 A. I'm referring to these attorneys who, in my 20 mind, represent Monsanto and Solutia. 21 Q. You also indicated that during your 22 employment at the Queeny plant, you were involved with 23 the making of production that contained PCBs; is that 24 correct? 25 A. Yes. 366 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051505 1 Q. What were the names of the products that you 2 were involved with? 3 A. Pydraul, P-y-d-r-a-u-1. 4 MR. WETMORE: Who's ever typing on phone, 5 could you hit your mute button? Thanks. 6 BY MS. O'NEAL: 7 Q. Go ahead, Mr. Papageorge. You mentioned 8 Pydraul. 9 A. Some of the Therminols. I believe some of 10 the Skydrols, which are aircraft hydraulic fluids. 11 That's all that comes to mind now. 12 Q. Now, you indicated that you became plant 13 manager in Anniston in 1965; is that correct? 14 A. That is correct. 15 Q. Prior to becoming plant manager, did you 16 have an understanding as to the reasons that your 17 predecessor was being replaced as the plant manager in 18 Anniston? 19 A. I can share with you my understanding at the 20 time. 21 Q. And that's what I'd like to have, sir. 22 A. The individual was being promoted. He was 23 perceived to have done a good job and deserved a 24 higher level position as a reward. 25 Q. Is that Mr. McClain? 367 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051506 1 A. Yes. 2 Q. And do you know what position he was 3 promoted to? 4 A. Plant manager, I think, of the Nitro, West 5 Virginia, plant. 6 Q. Now, you said that was your understanding 7 that you came to have before you came to Anniston. 8 Did that understanding change in any way as time 9 passed as to the reason he was leaving the Anniston 10 facility? 11 A. No. 12 Q. What is your understanding, Mr. Papageorge, 13 as to the reason you were selected to be the Anniston 14 plant manager in 1965? 15 A. I can only share with you my--I was never 16 given an official reason. I was just told by 17 Mr. Robert Soden, who became the Director of 18 Manufacturing that's involved with all these plants in 19 the Organic Division, that he had to replace 20 Mr. McClain, and he decided I was the one to do so. 21 Q. Now, you described in some detail the 22 organizational structure at the Anniston plant with 23 regard to direct reports, and there were two 24 manufacturing superintendents, a personnel 25 superintendent, a superintendent of Technical 368 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051507 1 Services, a maintenance superintendent, a 2 superintendent of warehousing, shipping, and waste 3 hauling, and a part-time plant physician; is that 4 correct? 5 A. Yes. 6 Q. Those were your direct reports? 7 A. And I added two further positions, as I 8 remember. 9 Q. What were those? 10 A. The purchasing agent. The second one 11 escapes me. It'll come later, I hope. 12 Q. And when did you create the position of a 13 direct report of a purchasing agent? 14 A. When did I-- 15 Q. When did you add the direct report of the 16 purchasing agent? You said you added that sometime 17 after you came. 18 A. Oh. When did I? 19 Q. Yes, sir. 20 A. It was in existence when Iarrived. 21 Q. You added that in yourearlier testimony to 22 your initial-- 23 A. To the,-- 24 Q. --structure. Okay. 25 A. --to the--and I'd like to add the other one 369 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051508 1 that avoided me earlier, the safety director. 2 Q. And all of these direct reports were in 3 place when you came to the facility in 1965 as plant 4 manager; is that correct? 5 A. That is correct. 6 Q. Now, did that organizational structure 7 change during your tenure as plant manager? 8 A. No. 9 Q. When you left Anniston in the end of 1969 to 10 take the new position at headquarters, Gene Jesse 11 became the plant manager; is that correct? 12 A. That is correct. 13 Q. What is your understanding as to the reason 14 that Mr. Jesse was named as your replacement? 15 A. My understanding is based only on an 16 assumption of my own. 17 Q. What is that assumption? 18 A. It's that Mr. Jesse was selected by 19 Mr. Soden to the replace me because Mr. Soden felt 20 Mr. Jesse was the best qualified of all the other 21 potential candidates that he reviewed. 22 Q. Prior to coming to Anniston as the plant 23 manager, where was Mr. Jesse employed? 24 A. I believe it was the J. F. Queeny Plant in 25 St. Louis. 370 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051509 Q. Do you have any recollection of what position he was in at Queeny before he came to Anniston? A. No, I don't. Q. Did Mr. Jesse serve some time at the Anniston plant, getting his feet wet, so to speak, while you were still officially plant manager? A. No . Q. You also testified that there was an increase in personnel at the Anniston plant during your tenure from approximately 150 to 350; is that correct? A. I did. Q. And you also indicated that that increase was the result of several factors, one being an increase in production of existing products, one being an increase in technical personnel, and one being the introduction of new products; is that correct? A. That is correct. Q. Okay. What existing products had increased production that resulted in more personnel being added? A. The insecticide team increased their production, there was a new P2S5-producing unit added, phosphorus pentasulfide, there was an increase in 371 Papageorge, William; McWane (3) (Former Monsanto Employee WATER PCB-SD0000051510 1 production in the Paranitrophenol Department, which is 2 a raw material for the Insecticide Group, and as we 3 indicated earlier, the Aroclor line of products 4 increased in capability, requiring more labor. 5 Q. What was the reason for the increase in 6 technical personnel? 7 A. I don't know that there's any one reason. 8 There are several. 9 Q. What are they, sir? 10 A. There was an increased need, of course, in 11 the gathering of knowledge, information relating to 12 the PCB issue which was evolving in the latter part of 13 that '68-'69 period. There was--hmm: There was a 14 need for technical people to help the plant introduce 15 some of the information and design that we talked 16 about earlier for the expansion, and for these 17 individuals at the plant to work with the Corporate 18 Engineering Department, to coordinate the plant 19 efforts with the corporate efforts. That is all that 20 comes to mind at present. 21 Q. Now, you indicated that with regard to the 22 biphenyl production, there was a change in the process 23 during your tenure. I think one description has been 24 from a one-pot to a cascading-pot process; is that 25 correct? 372 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051511 1 A. That's the chlorinated biphenyl, not just 2 the biphenyl. 3 Q. So the chlorinated biphenyl process changed 4 from a one-pot to a cascading-pot process while you 5 were there; is that correct? 6 A. Well, the cascading was added to the 7 original--the original one-pot process stayed in 8 place, and the cascading was added to increase the 9 amount of material produced via a different approach. 10 Q. So in connection with the change in adding 11 the cascading process, additional pots were added; is 12 that correct? 13 A. Yes. 14 Q. Okay, and the old pots remained in place and 15 in use, as well; is that correct? 16 A. Yes. 17 Q. You were asked by Miss Lavey about what she 18 marked as Defendant's Exhibit Number 9 to your 19 deposition, and I'll hand it back to you. I just have 20 a couple of quick questions. This document, which 21 purports to be the standard manufacturing process for 22 biphenyl, describes in some detail what is called the 23 lead pot process. Do you recall that having been in 24 this document earlier, Mr. Papageorge, when we looked 25 at it? 373 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051512 1 A. Yes. 2 Q. Okay. Now, you also testified that you 3 didn't know anything about a lead process at Anniston. 4 Is that right? 5 A. It just, in my memory, doesn't ring any 6 bells. I-- 7 Q. But you have no reason to, to question the 8 fact that document Defendant's Exhibit 9 was the 9 standard manufacturing process in place at Anniston at 10 some point in time at least by September 17, 1957, the 11 date of the document; is that correct? 12 A. That is correct. 13 Q. And is it your testimony that during the 14 course of your tenure at Anniston, you didn't learn 15 anything about the historical use of lead at the 16 Anniston facility? 17 A. True. 18 Q. Now, during your employment at Anniston, 19 which plants, through which plants was Monsanto 20 manufacturing or producing PCB-related products? 21 A. In addition to Anniston? 22 Q. In addition to Anniston, yes, sir. 23 A. There was a W. G. Krummrich Plant located in 24 Sauget, Illinois, and the John F. Queeny Plant located 25 in St. Louis. 374 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051513 1 Q. Did Monsanto operate a plant in Newport, 2 Wales, at that time? 3 A. Yes. 4 Q. And did they make products containing PCBs? 5 A. Yes. 6 Q. Also during the time that you were the plant 7 manager at Anniston, was Monsanto involved in a joint 8 venture with Mitsubishi Corporation in Japan for the 9 manufacture of PCB-containing products? 10 A. Yes. 11 Q. Now, in connection with your duties as a 12 plant manager in Anniston, did you talk with the plant 13 managers at any of these other facilities that 14 produced PCB-containing products? 15 A. I talked with all but Mitsubishi people. 16 Q. Who was your counterpart at the Newport 17 Wales facility? 18 A. Oh, I don't remember his name. 19 Q. Do you recall anyone that was involved in 20 the manufacturing process at the Newport, Wales 21 facility? 22 A. No, I don't. 23 Q. At Sauget, do you recall who your 24 counterpart was? 25 A. Sauget at that time? Jerry Bratsch, 375 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051514 1 B-r-a-t-s-c-h. 2 Q. Do you recall anyone else at Krummrich or 3 Sauget that was involved in the production process of 4 PCB-related products? 5 A. There was a Jack Malloy. I can't recall any 6 others. 7 Q. Is Mr. Bratsch still alive or is he 8 deceased, to your knowledge? 9 A. I, I don't know. 10 Q. How about Mr. Malloy? 11 A. I don't know. 12 Q. If you would, Mr. Papageorge, would you 13 please describe for us the equipment that was used in 14 the production of biphenyls at Anniston? 15 A. When you say biphenyls 16 about-- 17 Q. Chlorinated biphenyls? 18 A. Chlorinated? 19 Q. Yes, sir. 20 A. It consisted, really, 21 whatever is the best word to use. These are vessels 22 that are designed to heat the contents, and in these 23 vessels, the biphenyl, itself, would be introduced. 24 There was a provision made for chlorine gas to be, I'm 25 going to use the word "bubbled" through, and the 376 Papageorge, William; McWane (3) (Former Monsanto Employee; WATER PCB-SD0000051515 intent, there, being for the chlorine to replace the hydrogen to make chlorobiphenyls and to activate that process, there was a container of iron filings introduced, and that would be slowly consumed, so that container would last for months. Q. What was the size of that container? A. As best I remember, about the size of that wastebasket, there, five-gallon pail, about that size Q. And was one of those five-gallon-pail-sized baskets in each of the pots that was used in the biphenyl-producing process? A. Each of the pots that were chlorinators. Q. Chlorinators. A. Yes. Q. And how many of those chlorinators were there? A. At Anniston? Q. Yes, sir. A. Three of them, as I remember. Q. And did that change any during the time you were at Anniston? Were there more added or some taken away? A. The three chlorinators that were designed to operate in series were added. Q. Okay. So three were added. How many were 377 Papageorge, William; McWane (3) (Former Monsanto Employee WATER PCB-SD0000051516 there when you got there? A. Three. Q. Okay. A. Three were added, making a total of six. Q. Of six? Now, you answered those questions with regard to the equipment used in creating the chlorinated biphenyls. A. Yes. Q. Was there a process first by which the biphenyls were created from benzene? A. Were what? I didn't hear that one word. Q. I'm sorry. You were describing the equipment used in the process creating chlorinated biphenyls A. Correct. Q. Now, was different equipment used in a stage earlier? Is there an earlier stage of the process where you actually created the biphenyls from the benzene? A. Oh. To me, that's a different process. That the process of making biphenyl. Q. What equipment was used in the process creating biphenyl? A. Again, it's a, a tank or a pot that is used to take benzene and remove hydrogen, which allows the 378 Papageorge, William; McWane (3) (Former Monsanto Employee WATER PCB-SD0000051517 1 two benzene rings, which are represented chemically as 2 a--hexagons, to make the biphenyl. 3 Q. Now, in addition to the pots that are used 4 in the biphenyl production process, what other 5 equipment is used? Is there piping involved? 6 A. Piping, and pumps, and a source of heat. 7 Q. What was the source of heat? 8 A. Steam, in this case. 9 Q. And how was the steam generated? 10 A. Over in the power plant that we had. 11 Q. And that steam was piped into the biphenyl 12 production facility? 13 A. Correct. 14 Q. And then there were pipes also that brought 15 the benzene from the benzene tanks into the facility, 16 as well; is that correct? 17 A. That is correct. 18 Q. Then the benzene, how was it delivered--the 19 biphenyl, how was it delivered into the facility for 20 making the Araclors? 21 A. For making which? 22 Q. The Araclors. 23 MR. WETMORE: Araclors. 24 A. Oh, the Araclors? Oh, no, it's kept heated, 25 so it stays a liquid and is pumped from the collection 379 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051518 1 tank or storage tank over to these chlorinating pots 2 in the chlorinated biphenyl setup. 3 BY MS. O'NEAL: 4 Q. So it was piped from the biphenyl facility 5 to the chlorinating facility; is that correct? 6 A. Yes. 7 Q. Okay, and there was a storage tank for the 8 biphenyls; is that correct? Once they were created? 9 A. Yes. 10 Q. What was the size of that tank? 11 A. Oh, I don't, I don't have any idea. 12 Q. Do you have any understanding or 13 recollection as to the quantity that that tank would 14 hold? 15 A. No, I don't anymore. 16 Q. Was there one tank or more than one tanks 17 for biphenyl storage? 18 A. I don't remember. 19 Q. Do you recall where in relation to the 20 biphenyl production facility the storage tank was 21 located? 22 A. All I can recall is it was nearby. That's 23 it. 24 Q. In connection with the creation of the 25 biphenyls, I think you testified that hydrogen had to 380 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051519 1 be removed from that-2 A. I did. 3 Q. And how was the hydrogen removed? 4 A. I don't recall the chemistry involved, at 5 this point. 6 Q. Was it a function of a catalyst causing a 7 reaction, or was it a heat-induced reaction, or was it 8 a combination of a number of factors, if you recall? 9 A. Chemically speaking, I would suspect that a 10 catalyst and heat both were involved. 11 Q. And that would be just based on your 12 chemistry background; correct? 13 A. Correct. 14 Q. But not a direct recollection of the-15 A. Correct. 16 Q. --process. Now, in connection with the 17 manufacturing processes for both the biphenyls and the 18 chlorinated biphenyls, were the pipes involved in 19 those processes cleaned out on occasion? 20 A. On occasion, yes. 21 Q. And were those done at stated frequencies or 22 whenever there was an apparent need to do so, based on 23 the judgment of the operator? 24 A. It's based on the need as perceived by those 25 people who are familiar with the normal situation and 381 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051520 1 an abnormal situation. 2 Q. Now, did the cleaning out of the pipes 3 require, on occasion, the dismantling of some of the 4 production equipment? 5 A. Occasionally. 6 Q. And when a dismantling was required, that 7 would be a function given to the Maintenance 8 Department; is that correct? 9 A. The disconnection or disassembly of the pipe 10 system is given to the Maintenance Department. The 11 actual cleaning effort was done by the operating 12 personnel. 13 Q. And how would they effect the cleaning? How 14 would they clean? Would they clean under air 15 pressure? Would they use water? Would they use 16 solvent? What, what type of process would be used to 17 clean out these pipes? 18 A. That will vary with the cause for the 19 stoppage or blockage. Sometimes, just air pressure 20 will push the material forward and open up the line. 21 Other times, they had to prod it with rods and at 22 least start an opening, and other times, it required 23 just the presence of steam to melt the material to get 24 it to flow out and out of the way, so it would vary, 25 depending on the cause of the stoppage. 382 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051521 1 Q. And what causes were there for stoppages in 2 those pipes? 3 A. Well, many times, it's the presence of a 4 material that is intended to stay in the distillation 5 system but unwantingly goes on up with the purified 6 product and ends up in the pipelines. 7 Q. Such as? What type of, of material that was 8 supposed to stay in the distillation process? 9 A. Well, we've talked earlier about montars. 10 Those chemicals that make up montar will sometimes 11 get, because of a temperature change or something, 12 would be distilled over with the finished product 13 instead of staying at the bottom of the pot, and once 14 they get up the distillation system, they go on 15 following the path of the--that's intended for the 16 finished product, and that's where they create the 17 blockages. 18 Q. So what other substances other than 19 montar-type substances would create blockages? 20 A. I can't think of any other. That's the only 21 type that could possibly be present. 22 Q. Do you recall a gentleman by the name of Jay 23 Johnson serving as a purchasing agent while you 24 were --Jay Johnson? 25 A. Jay Johnson. I do not. 383 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051522 1 Q. Was there a point in time in which the 2 purchasing for the plant was conducted or handled out 3 of St. Louis, as opposed to the plant, itself? 4 A. I'm not aware of that happening. 5 Q. It didn't happen during your watch as plant 6 manager; is that correct? 7 A. At least no one told me. 8 Q. Okay. 9 (Laughter.) 10 Q. (Continuing) Now, you testified that iron 11 turnings were used in the chlorinator, and I think we 12 talked about the fact earlier that those were 13 basically iron filings; is that right? 14 A. That's my understanding. 15 Q. Okay. Were there written specifications for 16 those turnings? 17 A. I didn't see any. 18 Q. I think you mentioned that those turnings 19 were purchased in the form in which they were used; is 20 that correct? 21 A. That's my understanding. 22 Q. Okay, and would it have been the practice 23 when you were at Monsanto as plant manager for there 24 to have been written specifications for material such 25 as the iron turnings? 384 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051523 1 A. That was the ongoing practice. 2 Q. And who would have been responsible for 3 creating those specifications if there were written 4 specifications? 5 A. The information would have to come out of 6 the Research Department and conveyed to a group of 7 individuals that write up the manufacturing process, 8 which would include a production person, a research 9 person, a safety person, and so on, and those 10 specifications for that kind of material would then be 11 conveyed to the Purchasing Department, who would then 12 work to find out a supplier who is willing to meet 13 that specification and can meet the needs or demands 14 for so many pounds a year, or so many pounds a month, 15 whatever is required. 16 Q. Now, you testified that when the iron 17 turnings were depleted, they would be replenished, the 18 baskets would be refilled as the levels dropped; is 19 that correct? 20 A. Yes. 21 Q. What caused the filings or the turnings to 22 diminish or be depleted? 23 A. The iron reacts with the chlorine, with the 24 was acid, hydrogen chloride, to make ferric chloride. 25 This is not a rapid process, it's a slow process, but 385 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051524 1 it does happen. 2 Q. You testified, Mr. Papageorge, that you 3 couldn't say how the manufacturing process for the 4 chlorinated biphenyls changed from 1957 until 1966. 5 We had looked at two separate standard manufacturing 6 processes; one predated you, one came after you. Who 7 would know, who would have a understanding as to the 8 changes in that process at this Anniston facility? 9 A. Are you referring to the step-wise 10 chlorination process or the single-pot process? 11 Q. What I'm referring to, Mr. Papageorge, is 12 the lead pot process that we looked at marked as 13 Defendant's Exhibit 9, which was the SMP in place in 14 1957 versus the process in place in 1966, which was in 15 place when you were there that has been marked 16 previously as Exhibit 13, and all I'm asking you is, 17 you said that you couldn't--you didn't know how the 18 process had changed between the 57 marked as 19 Defendant's Exhibit 9 and the process that was in 20 place while you were there that is marked as 21 Defendant's Exhibit 13, and my question was very 22 simply, who would know? Who would know how that 23 process had changed? 24 MR. WETMORE: If anyone. 25 A. Well, the management of the production team 386 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051525 1 that is assigned the responsibility for that process, 2 is the group that would be responsible for being aware 3 of any changes and to document those changes, train 4 their production team, so it's not just one person, 5 it's really the supervisor, and his foremen, with 6 advice coming from Research, and Engineering, and 7 wherever else they feel they need it. 8 BY MS. O'NEAL: 9 Q. So someone in Mr. Moody's department, 10 perhaps, would have known about the changes in the 11 process; would that be correct? I think you testified 12 that Robert Moody was the superintendent for 13 manufacturing of everything other than insecticides. 14 A. That's true, but I'm looking at the year,-- 15 Q. Right. 16 A. --and this document I'm looking at, here, as 17 Exhibit 13, lists Mr. Moody as the superintendent. 18 Q. Right. 19 A. So if he was in place in 1966, he's the top 20 individual on the production team. 21 Q. And he was in place when you came in 1965; 22 is that right? 23 A. Yes. 24 Q. You testified, Mr. Papageorge, about 25 material being drummed, various types of material 387 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051526 1 being drummed to take into what was called the dump. 2 Do you recall that? 3 A. I do. 4 Q. Okay, and I think that, that we narrowed 5 down this morning that there was only one dump that 6 was used, to your knowledge, while you were plant 7 manager; is that correct? 8 A. That is correct. 9 Q. And that was at, basically at the base of a 10 hill; is that correct? 11 A. That is correct. 12 Q. Outside the fenced area of the plant. 13 A. Yes. 14 Q. Okay, and you don't recall that that was 15 across the street from Old Birmingham Highway which we 16 us used to call Old Highway 202 from the plant, do 17 you? 18 A. I recall there was a roadway across. What I 19 was surprised to see later that there is a second 20 road. 21 Q. There are now two roads between the plant 22 and the landfill? 23 A. Parallel to each other. 24 Q. Correct. 25 A. But I was not aware at that time, back in 388 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051527 1 when I was plant manager, of that second, newly2 constructed roadway. 3 Q. It wasn't there when you were plant manager. 4 A. That is true. 5 Q. But when you were plant manager, there was 6 one road between the production facilities of the 7 plant, the fenced part of the plant, and the landfill 8 that was referred to as the dump during your tenure; 9 is that right? 10 A. That is correct. 11 Q. Okay. Are you aware of any occasions during 12 your tenure, Mr. Papageorge, where material was taken 13 to the Anniston City Landfill from the plant? 14 A. I am not aware of any site referred to as 15 the Anniston City Landfill. 16 Q. Are you aware of any waste material being 17 taken from the plant facility to the Catlin County 18 Landfill? 19 A. I am not. 20 Q. Are you aware of any offsite disposal of 21 materials from the Anniston facility? 22 A. The only offsite disposal that I am aware 23 of, and not knowing in detail, is the disposal of 24 dismantled, old equipment by outside contractors who 25 would haul it away. That's the only material. I'm 389 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051528 1 not aware of any material created during manufacturing 2 and accumulating and then disposed by an outsider. 3 Q. What equipment do you recall being 4 dismantled and eventually taken away by an outside 5 contractor? 6 A. I don't recall any specifics. We mentioned 7 earlier about shed space or a little office space kind 8 of construction that was dismantled during this 9 warehouse expansion, that kind of thing. 10 Q. Do you recall any production equipment being 11 dismantled? 12 A. No. 13 Q. You indicated, I believe it was yesterday, 14 that the drum material would be taken to the dump and 15 would eventually be covered with soil. Was all of the 16 soil that was used as cover retained on the landfill, 17 itself? 18 A. Yes. 19 Q. Okay, and was all of the soil used as cover 20 soil that had been excavated when the landfill had 21 been created? 22 A. Each, I'm going to call it each using 23 facility would create a place for the waste by digging 24 into the hillside, setting that soil aside and saving 25 it for later, depositing the waste, and then using 390 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051529 1 that same soil to cover up. 2 Q. How frequently was the cover placed on the 3 landfill? Because your testimony had been that 4 eventually, it was covered. 5 A. Yes. There is no set time period. It 6 really depended on how fast the drums containing waste 7 material accumulated, and when they reached the point 8 where they covered the old hole, so to speak, that 9 deposit of material would be covered by soil and 10 another hole dug, waiting for the next batch of 11 discarded material. 12 Q. And do I understand correctly, 13 Mr. Papageorge, that the responsibility for delivering 14 the waste to the landfill, as well as responsibility 15 for covering the waste in the landfill, was not the 16 Maintenance Department but was rather under the 17 direction of the superintendent of warehousing and 18 waste disposal? 19 A. Yes. 20 Q. You also indicated that there were lots of 21 possible sources for Aroclors on the floor in the 22 manufacturing facility. Do you recall that? 23 A. Yes, there are possible sources, yes. 24 Q. Tell me all the possible sources that you 25 can think of. 391 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051530 1 A. I don't think I can remember all of them, 2 but activities such as sampling; the equipment used in 3 sampling can fail. A hose can have a leak, and while 4 you are using that hose to fill your sample bottle, 5 the leak is occurring back in the hose. The, the 6 valves that are used to shut off the, the flow of 7 sample material, an example, would leak, just like my 8 faucet at home leaks, so --and then there is the 9 connection, say, to a pump that's working, vibrating 10 and so on, the flange between the metal, the gasket 11 between the metal flange could fail and it could start 12 dripping from a pipe fitting. It's possible, too, for 13 the tank, itself, developing a leak after years of 14 service, the wall gets in this and starts oozing 15 through and then there's a leak observable on the 16 floor below it, and in every piping system where 17 connections are made for different parts of the 18 system, the potential for leakage is always there. 19 Q. From time to time, were pipes replaced? 20 A. Oh, yes. That's, that's normal. It doesn't 21 happen often, but it does happen. 22 Q. And how were those pipes disposed of? 23 A. The best I recall is that they would sell 24 them to a scrap dealer. 25 Q. Do you recall what scrap dealer was the 392 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051531 1 scrap dealer of choice with regard to disposing of the 2 pipe? 3 A. No, I never did get that detail. 4 Q. Who would have been responsible for handling 5 that type of transaction at the plant? 6 A. Well, the maintenance superintendent would 7 have to communicate with this individual in charge of 8 warehousing, shipping, movement, and tell him that he 9 had a need to ship so many tons of steel that used to 10 be pipe and when they get rid of it, and it would be 11 up to the, really, the purchasing man to negotiate how 12 much the receiver of this scrap iron was willing to 13 pay for it. 14 Q. What were the causes, Mr. Papageorge, for 15 pipes having to be replaced? 16 A. The general cause --and it's not a frequent 17 one--is just what I would call plain rusty old pipes. 18 Now, many of these heated pipes are covered with 19 insulation, and sometimes the, the space between the 20 insulation and the pipe, itself, accumulates, let's 21 say, some acidic water, and that acid is kind of 22 slowly eating into the wall of the pipe until the wall 23 gets so thin, it springs a leak, which initially is 24 just an ooze, you don't notice it because the 25 insulation is absorbing it, and eventually, it starts 393 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051532 1 dripping and becomes observable. 2 Q. Were periodic inspections done by the 3 Maintenance Department or the Production Departments 4 of their equipment to look for possible leaks, pipes 5 that needed replacing, things like that? 6 A. Well, I'm not aware of any inspection 7 program that will lead to any discovery any better 8 than the leak, itself, and if it does, if that leak 9 does occur, it's obvious there's a problem. You don't 10 have to have a formal inspection with a check sheet to 11 say it's okay or it's not okay. 12 Q. So there wasn't a formal inspection program 13 where every month, somebody from Maintenance walked 14 through and checked out the pipes? 15 A. No. 16 Q. It was just when they became observable, the 17 issue was addressed as to whether replacement was 18 needed or not needed. Is that-- 19 A. Correct. 20 Q. --correct? What was the location of the 21 biphenyl production facility to that road that you and 22 I talked about that later became two roads, that was 23 known as the Old Birmingham Highway? 24 A. My best description of that is downhill from 25 it, down where the mostly level area occurred, 394 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051533 1 although it still sloped, but not as dramatically as 2 the upper level. 3 Q. Before it turns into Clydesdale? 4 A. I think that's a correct description, yes, 5 mm-hmm. 6 Q. Was there anything, plant-wise, between the 7 biphenyl production facility and that roadway? 8 A. I'm trying to recall where the office 9 building was located. It sounds like it might have 10 been in that area between. 11 Q. I thought the office building was more on 12 the Clydesdale entrance area than at the foot. 13 A. You mentioned Clydesdale. That's what-- 14 Q. No, I was talking about before we curbed 15 onto Clydesdale. 16 A. Oh, the upper part of it? No, there's, 17 there's nothing there. 18 Q. There's nothing between that facility and 19 the highway? 20 A. Correct. 21 Q. Okay. 22 A. At that point. 23 Q. At that point in time. Do you recall during 24 your tenure, Mr. Papageorge, there being any thefts or 25 losses of raw materials from the facility? 395 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051534 1 A. Losses of raw material? 2 Q. Or thefts of raw materials. 3 A. I don't recall any. 4 Q. Do you recall any thefts of mercury from the 5 facility? 6 A. No . 7 Q. Was mercury used at the facility? 8 A. Yes. 9 Q. And what application was mercury used for? 10 A. It was used in the facility that created 11 chlorine gas . 12 Q. And was that true at the time you were the 13 plant manager? 14 A. Yes. 15 Q. As plant manager, did you have a role in the 16 budgeting process for the plant operations? 17 A. In which-- 18 Q. Budgeting process. Budgeting. 19 A. Budgeting process? 20 Q. Yes, sir. 21 A. Oh, yes. I-- 22 Q. Were budgets prepared at the plant level and 23 then sent to St. Louis? 24 A. Yes. 25 Q. And did you budget for your plant to acquire 396 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051535 1 raw materials? 2 A. Yes. 3 Q. Now, we talked earlier this morning about 4 the use of sand to clean up spills, Aroclors from the 5 floor. Do you recall that? 6 A. Yes. 7 Q. How was the sand transferred from the piles 8 in which it was maintained to the spill? 9 A. Well, I saw sand transferred in these steel 10 containers with the full open top. 11 Q. And were those carried by forklift? 12 A. Yes. 13 Q. And who was responsible for transporting the 14 sand from the piles to the operating facility? Was 15 that Maintenance, or was that-16 A. The warehousing team. 17 Q. The warehousing folks. Are you aware, 18 Mr. Papageorge, of any maps or plats that showed the 19 facility as it existed at the time that you were 20 there? 21 A. I have seen such maps or plats. 22 Q. Have you seen any maps or plats of the 23 facility that predated your tenure, to give historical 24 perspective? 25 A. I've seen the older ones, yes. 397 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051536 1 Q. Okay. Do you recall references on those 2 older plats or maps to lead pots? 3 A. I do not. 4 Q. Where were those mats --excuse me, maps or 5 plats maintained, if you recall, Mr. Papageorge? 6 A. The best I recall, they were under the 7 custodianship of the Technical Services Department. 8 Q. At the plant, itself? 9 A. At the plant, itself, and that does not mean 10 that Monsanto's home office didn't have copies of 11 that. 12 Q. In fact, you would expect that they would, 13 wouldn't you? 14 A. That would make sense, yes. 15 Q. When is the last time you recall seeing any 16 of those facility maps, Mr. Papageorge? When is the 17 last time you recall having seen-- 18 A. Seen? Hmm: I just don't remember a purpose 19 or a reason for seeing any for several months. 20 Q. You've seen them before in connection with 21 lawsuits that were brought against the company? 22 A. I believe that's when it happened, but 23 this --it's been many months since I've seen it. 24 Q. But you had access to them when you were at 25 the plant as plant manager; correct? 398 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051537 1 A. Yes, but being at the plant, I didn't need 2 the map. I-- 3 (Laughter.) 4 Q. Tell me where--I know your office was in an 5 office building. Was your--did your office have 6 windows? 7 A. Well, in the beginning, we were in an old 8 building, and I had a, a piece of it, and it had a 9 window, and then a new office was constructed, and my 10 office did not have a window. 11 Q. In your old office that had the window, what 12 did the window look out on? 13 A. As I remember, it just looked out on the 14 parking area for the office employees. 15 Q. Now, approximately what portion of your day, 16 on average, was spent inside the office, as opposed to 17 out in the manufacturing facility? 18 A. What portion of my time? 19 Q. Yes, sir. 20 A. Oh, I don't know that I ever measured it or 21 knew how to measure it. Hmm: I would try to spend, 22 say, a couple of hours in the plant, just making 23 myself familiar in what's going on and all, and I 24 would suggest that I, I might have put in a couple of 25 hours meeting with individuals who had certain 399 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051538 1 information to share with me, and the rest of the 2 eight-hour day would be filled with memo writing, and 3 telephoning, and that kind of thing. 4 Q. So you tried to spend a couple of hours in 5 the day out in the manufacturing facilities, 6 themselves; is that correct? 7 A. Yes. 8 Q. Okay. 9 A. I'm going to correct that, because there are 10 times when I'd spend these couple of hours during the 11 day and then I might come in for the middle shift. 12 Q. Well, that was my next question. What were 13 your normal working hours? And then we'll get to 14 other visits. 15 A. Okay. All right. 16 Q. What were your normal working hours? 17 A. 8:00 to 5:00 or some such. 18 Q. First shift, roughly? 19 A. For the day shift, 8:00 in the morning, 5:00 20 in the evening. 21 Q. And then periodically, you would come in 22 during second shift to just have a feel for what was 23 going on and also in the event that you had heard any 24 rumblings about potential problems? Is that right? 25 A. Yes. I wanted employees who didn't get to 400 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051539 1 see much of me -- 2 Q. To know you were there. 3 A. Well, I would arrive unannounced, and this 4 kind of disturbed some of them. They'd start sweeping 5 up quickly. 6 (Witness laughs.) 7 Q. Do you recall, Mr. Papageorge, the names of 8 any of the chief operators or operators who were in 9 the production units? 10 A. Whew: No, I don't. 11 Q. Now, we talked a little bit about the 12 cleanup of the equipment that was required from time 13 to time. Were there any general housekeeping chores 14 done with regard to the manufacturing facilities, 15 themselves? Were the facilities washed down? Were 16 they swept out? How were they maintained? 17 A. When you say how were they maintained, you 18 mean what level -19 Q. How-- 20 A. --or -- 21 Q. --how, how, how was housekeeping done? What 22 house --let's strike that and do it this way. Was 23 housekeeping done in the manufacturing facilities? 24 A. Well, the, the whole objective was to 25 maintain a housekeeping level that, first of all, 401 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051540 1 ensured safe working conditions. That's primary, and 2 by "safe working conditions," it isn't only the, the 3 type of hazard that exists when a person slips on 4 something but also cutting down on unnecessary 5 exposure to odors, and fumes, and, and the like. We 6 did not underestimate the value of just the presence 7 of cleanliness being important for morale, and by 8 that, I'm thinking of such things as an instrument 9 room about this size, all the instruments around, that 10 is filthy, it just wasn't acceptable. It's up to the 11 supervisor to make sure that somebody sweeps the 12 floor, and washes the glass on the instrument panels, 13 and so on. 14 Q. Were the supervisors or superintendents 15 responsible for the housekeeping within their 16 respective departments? 17 A. Yes. 18 Q. Okay, and they would charge, probably, the 19 most junior members of their staff with those cleaning 20 chores, that-- 21 A. That is the normal arrangement. 22 Q. And those cleaning chores would include 23 things like washing down the floors or swiping 24 sweeping the floors, cleaning the windows, those type 25 of activities; is that correct? 402 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051541 1 A. And cleaning the rest room, and, and so on. 2 Q. You testified this morning about the 3 sandboxes that were at the base of the stairs. 4 A. Right. 5 Q. Do you recall that? Whose job was it to 6 fill those sandboxes? Who put the sand in there? 7 A. Some member of the operating team who the 8 chief operator or foreman would designate, "Your job 9 includes this duty." 10 Q. So would there be these steel drums 11 containing the sand close to the production facility 12 and they would replenish the boxes from those drums? 13 A. Yes. 14 Q. Okay. Were the sandboxes still at the foot 15 of the stairs when you returned to the plant on your 16 subsequent visits after leaving as plant manager, or 17 do you recall them having been removed at some point? 18 A. I recall they were eventually removed, but I 19 think in the first trip or two, they were still there. 20 Q. Okay. 21 A. I remember making some remark about "Hey, 22 let's get rid of these and give the fellas new boots 23 or work shoes to wear." 24 Q. The temptation to use them will be 25 diminished if they're not there to be used; is that 403 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051542 1 accurate? 2 A. Correct. Correct. 3 Q. Now, you testified that the sand that had 4 been swept up off the floor or otherwise discarded 5 would eventually be sealed in drums and taken to the 6 dump; is that correct? 7 A. Yes. 8 Q. What was the need for sealing? Why were 9 those drums sealed? 10 A. Well, we decided that since they contained 11 chlorinated biphenyls, we didn't want to risk any 12 escape into the environment. This is why they were 13 sent to this landfill to start with, and by putting 14 them in a steel container, we felt more comfortable 15 that they would stay under control longer and in a 16 better way. 17 Q. Now, was the practice with regard to sealing 18 those drums the same throughout your tenure? Did you 19 change that practice in any way with regard to sealing 20 the drums during your tenure? 21 A. No. 22 Q. That was a practice in place at the time you 23 came on as plant manager? 24 A. Yes. 25 Q. Now, you testified that the disposal of 404 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051543 1 those drums had to be monitored, that placing items 2 like that in the landfill had to be monitored. 3 A. Yeah. 4 Q. And that's why it was a problem with regard 5 to the use of so much sand; is that right? 6 A. Right. 7 Q. Who monitored the disposal of those drums? 8 A. The--if the drums were on the disposal site, 9 that became the responsibility of the superintendent 10 of the warehousing team. 11 Q. If they were actually still at the 12 production facility and not yet sealed, they were the 13 responsibility of whom? 14 A. Of the manufacturing management. 15 Q. Were any records kept with regard to the 16 disposal of these drums during your tenure? 17 A. I've never seen any. 18 Q. Were there any records kept of what was 19 transported from the plant to the dump? 20 A. No. 21 Q. Okay. Was sand used at the landfill as any 22 type of cover? 23 A. No. 24 Q. You indicated that the folks in Warehouse 25 and Shipping and Waste Disposal had to have some 405 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051544 1 training with regard to the handling of chemical 2 waste. Do you recall that? 3 A. Yes. 4 Q. Who provided that training to the warehouse 5 waste group? 6 A. Well, each of the groups were expected to 7 hold regular so-called safety meetings, at which all 8 kinds of safety matters were discussed, not all at one 9 sitting, but different subject with each meeting. 10 These meetings would take place at a minimum of once a 11 month, and most of the time, every couple of weeks. 12 The subject to be discussed would determine who the 13 speaker was, and if it involved a chemical-producing 14 unit's waste, we would have the supervisor or the 15 superintendent from that group speak to the warehouse 16 group about "This is the material you'll find, this is 17 the kind of container it's in, and these are the kind 18 of things that can happen," that type of discussion 19 would take place. 20 Q. Did the Maintenance Department have any 21 responsibilities with regard to the landfill? 22 A. I'm not aware of any assigned 23 responsibility. 24 Q. Do you recall there being issues with regard 25 to the limestone pit that required it to be upgraded? 406 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051545 1 A second pit to be added? 2 A. Yes. I recall the discussions. 3 Q. And one of the issues that was raised was 4 the fact that PCBs were migrating from the limestone 5 pit, despite the anticipated effects of the gravity; 6 is that correct? 7 A. Yes. 8 Q. Was there a scrap yard at the plant during 9 your tenure? 10 A. I'm not aware of any area that carried that 11 designation. 12 Q. Where were the used and replaced pipes 13 stored until they were shipped off to a scrap yard? 14 A. Oh, the location was not a fixed one. It 15 depended on the convenience of the moment as long as 16 it was orderly done, and this varied, of course, where 17 the major pipe replacement was taking place, they 18 wouldn't want to haul it all over the plant to get it 19 somewhere, they'd pick a spot fairly convenient and 20 yet not get in the way of any other important 21 activity. 22 Q. So would they stack those pipes on the 23 ground, outside the production facility from which 24 they were being taken? 25 A. It's outside of that, and, and like I said, 407 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051546 1 in a place that won't interfere with their activities. 2 Q. Do you recall whether there were any usages 3 of montars within the City of Anniston? Not at the 4 plant, itself, but whether there were any customers 5 who made application of the montar in the City of 6 Anniston. 7 A. I don't remember any of that. 8 Q. Prior to the replaced pipes being sold as 9 scrap, were they decontaminated? 10 A. Yes, if they contain a material that was 11 perceived to be easily released to the handlers of 12 this scrap pipe. 13 Q. Were PCB-related products deemed to be an 14 easily released material that would need--require 15 decontamination? 16 A. Depending on the amount. If it's just a 17 black stain midway through a six-foot pipe and the 18 workers can handle the piece of pipe with a crane or 19 something, it wouldn't be considered a problem. 20 Q. Who handled the decontamination? 21 A. The production people from which that piece 22 of pipe was removed. 23 Q. And how would pipes that were contaminated 24 with sufficient quantities of PCBs to require 25 decontamination, what process was used to 408 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051547 1 decontaminate them? 2 A. Well, as we said earlier, depending on what 3 the material was, you can use a rod to poke it 4 through, you can use steam, or just high water 5 pressure. It depended on the consistency of the 6 ingredient, what the material was, and what would it 7 respond to. 8 Q. Are you familiar with the substance known as 9 chat? Chat, c-h-a-t? 10 A. Chat? 11 Q. Yes. 12 A. I've heard that expression. I don't use it 13 personally, but-- 14 Q. What--do you have an understanding as to 15 what that expression means? 16 A. I have an understanding. It may not be 17 accurate. 18 Q. What is your understanding? 19 A. I'm trying to find the right words to 20 explain. It's just chips of things. I don't know how 21 else to describe it. 22 Q. Did Monsanto use chat as a cleanup agent 23 like it used sawdust, or dirt, or sand? 24 A. I'm not aware of any such use. 25 Q. Was slag used at the Monsanto facility to 409 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051548 cover PCB spills in the tank car area? A. No . Q. Do you recall there being any slag on the facility, itself? A. Never. Q. Do you recall whether, in your subsequent visits or in connection with your continued interaction with the Anniston facility, you subsequently learned that slag was used to cover PCB spills following your tenure as plant manager? A. I don't recall that at all. MS. O'NEAL: Mr. Papageorge, thank you, very much. MR. WETMORE: Could we go off the record to talk about where we are? THE VIDEOGRAPHER: This will end tape number 4 of the deposition of William B. Papageorge. We are off the record at 2:44 P.M. (Recess.) THE VIDEOGRAPHER: We're back on the record at 2:50 P M. This begins tape number 5 in the deposition of William B. Papageorge EXAMINATION QUESTIONS BY MR. TAYLOR: Q. Mr. Papageorge, I'm Jerry Taylor, and we met 410 Papageorge, William; McWane (3) (Former Monsanto Employee WATER PCB-SD0000051549 1 a couple of days ago now. It may seem longer to you, 2 but I represent several of the defendants that Solutia 3 is suing in this case, and I also will try not to 4 duplicate any of the questions you've already been 5 asked, and my goal is to seek a little bit of 6 clarification, if not for the record, then in my own 7 mind, about things you've already talked about. 8 In discussing your role for the Smith firm 9 and your retainer, I don't want to beat a dead horse, 10 but you said that you haven't been as active as you 11 once were; at least, your fee has gone down. Is that 12 in relationship to the amount of time you have been 13 spending lately? 14 A. Yes. 15 Q. All right, and over the last three or four 16 years, there has been a number of lawsuits involving 17 the company with EPA, with the state environmental 18 agency, with other citizens in Anniston. Have you 19 also been involved in assisting the lawyers in those 20 matters? 21 A. I am assisting lawyers during that period of 22 time. Of course, I'm not privy to all of the cases 23 they're involved in and the details, so all I can say 24 is that when they feel they need something from me in 25 the way of information, they'll contact me. 411 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051550 1 Q. For example, there has been a good bit of 2 work that the company has done recently in 3 investigating and doing some cleanup work in the 4 Anniston area. Have you been involved with the 5 company or the lawyers in that particular work? 6 A. To a degree. 7 Q. What role have you served in that aspect? 8 A. I don't know quite how to describe it except 9 that I was in a position where I could bring 10 up-to-date some attorneys from another firm out of 11 Birmingham who were involved to a degree, but I don't 12 know how much, so these new attorneys, I had to, in a 13 way, tutor them, regarding primarily by background and 14 what I knew of the situation at the plant. 15 Q. Is that the Lightfoot, Franklin firm? 16 A. Yes. 17 Q. And following up a little bit on that, your 18 understanding of this suit the way you were describing 19 it to Ms. O'Neal was that Monsanto or the lawyers 20 found it puzzling how certain chemicals got to where 21 they had been found or located. Can you tell me what 22 your understanding is of the chemicals that are 23 puzzling? 24 A. That was not discussed with Lightfoot 25 people. What sketchy information I got came from my 412 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051551 discussion with Mr. Kelly and Mr. Nassif, and they were talking about--and I have to confess I forgot the chemical specifically, but they were concerned not only about the identity of the material found but the locations described as to where they found it and then comes the question of how in the world did it get there. Q. And "it," was it PCBs? A. Yes, some of them were PCB examples. Q. Okay, what other materials or chemicals do you recall, or what is your understanding of other than PCBs that were the subject of your--of the conversations you've had? And I'm not going to spend a lot of time on this, I just want to know your understanding. A. My understanding. All I remember is there were other chemicals mentioned. Q. Do you recall any? A. I wish I--I don't recall them. I didn't write them down, so I don't recall them Q. More than one? A. Yes. Q. Metals ? A. Metals. Q. Lead? 413 Papageorge, William; McWane (3) (Former Monsanto Employee WATER PCB-SD0000051552 1 A. I think lead was in there, but I wouldn't 2 swear to it, no. 3 Q. You were also asked, I think, by Ms. Lavey 4 earlier whether you had had any interactions with or 5 had learned about foundries in the Anniston area after 6 you left Anniston. You said no, as I recall your 7 testimony. 8 A. That is true. 9 Q. When you were in Anniston, did you have 10 occasion to become familiar with the foundries in the 11 area, and what they did and how they did things? 12 A. The only observation I could make of the 13 foundries was as I drove down the roads, I could see 14 the flames at night and the fumes during the day, and 15 that's as close as I ever got to the foundry 16 activities. 17 Q. Never went in a foundry? 18 A. I never went in a foundry. 19 Q. Have you ever been in a foundry-20 A. No. 21 Q. --to today, in your life? 22 A. No. 23 Q. So you are not familiar with how they 24 operated, their procedures? 25 A. That is true. 414 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051553 1 Q. Their waste streams? 2 A. That's true. 3 Q. How they handled spills? 4 A. No. 5 Q. Anything like that, you would not have any 6 of that? 7 A. I don't even know the management of those 8 places. They didn't--they were not approachable. 9 Q. Do you have any knowledge about if any of 10 the foundries in Anniston had PCBs in their operations 11 or facilities? Do you have any personal knowledge 12 yourself? 13 A. Personal knowledge? No. 14 Q. And as an example, do you know whether, in 15 fact, the Monsanto Anniston facility supplied their 16 products to any of the foundries in the Anniston area? 17 Do you know that yourself? 18 A. The Anniston plant shipped these Aroclors on 19 orders based from the Marketing Department, and some 20 of those shipments could have gone to these foundries 21 but indirectly. There's no way for the Anniston plant 22 to know exactly where those shipments end up. 23 Q. And I take it from your testimony you, in 24 the five, four and a half or five years that you were 25 in Anniston, you did not have interactions with the 415 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051554 1 foundries such that those folks would call you and say 2 "Hey, I need some more Aroclor at our facility"? You 3 did not have that setup? 4 A. We did not. 5 Q. One of the exhibits that you were shown, 6 perhaps on your first day, was an old Sanborn map that 7 depicted the Monsanto facility, and you couldn't 8 orient yourself on it, but I also recall that there 9 was a--and we can pull it out, if you'd like to see it 10 again--a depiction, an identification of an Anniston 11 soil pipe foundry on the map not too far from the 12 Monsanto facility. Do you recall that on the map? 13 A. I recall it on the map. 14 Q. Do you recall that from your, from your 15 presence in Anniston, that there was a foundry there? 16 A. They ever knew about it until I saw that the 17 other day. 18 Q. I believe there's an indication on there 19 that it says, "Not in operation." Was there a 20 physical foundry located where it's depicted on the 21 map when you were in Anniston? 22 A. No. 23 Q. What was the, if you can recall, what was 24 the closest foundry to the Monsanto operation? 25 A. I don't know. 416 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051555 1 Q. I'm going to make an observation, and I want 2 you to tell me if it's accurate or not. In listening 3 to you talk about the biphenyl process and then the 4 chlorinated biphenyl process, I got the impression 5 that you were a lot more familiar or remembered a lot 6 more about the chlorinated biphenyl process than you 7 did about the biphenyl process. Is that--is my 8 impression accurate? 9 A. Yes. 10 Q. Now, is that because that was true 35 years 11 ago that you paid more attention to or knew more about 12 that part of the facility, or is it just time, and the 13 time you've spent with lawyers and other people has 14 been more on the chlorinated biphenyl part of the 15 product, process? 16 A. The chlorinated line of products was 17 perceived to be the booming activity at this plant. 18 The biphenyl was just a backup, a supply unit, and 19 rather in a secondary position. Without a biphenyl, 20 you wouldn't have the, the very active and profitable 21 chlorinated biphenyl business. 22 Q. The money maker was the chlorinated biphenyl 23 business ? 24 A. That's the one that was--it was a money 25 maker because it was a, a product much in demand, more 417 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051556 1 so than the biphenyl, itself. 2 Q. And so in your five years at the facility, 3 I'm not suggesting that you ignored the biphenyl part 4 of the process, but it would be accurate to say that 5 you spent more time at and kept up more with the 6 chlorinated biphenyl part of the business. Is that 7 correct? Would that be correct to say? 8 A. Yes, because it was the most active and the 9 one that was growing. 10 Q. I went back through my notes to try and look 11 at what your positions were within the company before 12 you came to Anniston, and I wanted to make sure I 13 noted this correctly. Before you became the plant 14 manager in Anniston, you had not been a plant manager 15 overseeing an entire plant before, had you? 16 A. No. You are correct on that. 17 Q. You had been at a superintendent or 18 supervisor level, so I assumed you would have 19 considered this a promotion. 20 A. It was, yes. 21 Q. All right, but had you ever had 22 responsibility before to oversee biphenyl production? 23 A. No. 24 Q. Before you came to Anniston? 25 A. No. 418 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051557 1 Q. Had you ever had the responsibility to see, 2 or to oversee chlorinated biphenyl production before -- 3 A. No. 4 Q. --Anniston? 5 A. No. 6 Q. I believe you testified--and I'm jumping 7 around a little bit to just cover some different 8 areas, so that's why my questions may not be a 9 consistent train of thought, but I'm trying to move, 10 move ahead. I believe you testified that you visited 11 the facility about three years ago? And I was--if I 12 recall that correctly, I was going to ask what that 13 occasion was. 14 A. The three years is too short a period. It 15 might have been-- 16 Q. You may have said three to five years ago. 17 A. Yeah, three to five, somewhere in there. 18 Q. What was that--I assume it was under your 19 contract with the law firm? 20 A. Yes. 21 Q. And was it--what was it regarding? Was it 22 lawsuits, or was it the EPA ADEM matter, if you 23 recall? 24 A. Lawsuits were involved, because attorneys 25 from the Lightfoot organization were involved and the 419 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051558 1 objective from my viewpoint was to bring me up-to-date 2 on what had been done to the Anniston site to change 3 the condition of the landfill and to answer some of 4 the questions regarding are they properly designing 5 this landfill? Is it properly controlled? 6 Q. And why would they, why would need to be 7 brought up to speed on that particular issue? 8 A. You'll have to ask the attorneys that. I 9 don't know. 10 Q. You received the invitation, and you are 11 under contract, and so you came. 12 A. Yes. 13 Q. When you make trips like that or come to 14 depositions like you are here, are you paid any more 15 than your thousand dollars a month? I assume your 16 expenses are covered, but I mean beyond that, do you 17 receive any additional compensation? 18 A. I receive additional compensation for those 19 activities in which I am not under oath. 20 Q. So you are receiving no additional 21 compensation for your testimony this week? 22 A. That is correct. 23 Q. But for trips to Anniston, you receive 24 additional compensation beyond the thousand dollars? 25 A. Yes. 420 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051559 1 Q. A month? 2 A. Yes. 3 Q. You get paid by the hour? 4 A. Yes. 5 Q. What's your hourly rate? 6 A. It's been awhile since I had--it's about--a 7 little over $200 an hour, two-ten, two-twenty, 8 something like that. 9 Q. Mr. McClain, whom you replaced, was he--this 10 may not be the best word--was he a transplant to 11 Anniston like you were? You came from St. Louis or 12 another facility, or was he a local Alabama fellow 13 that was the plant manager there? 14 A. I understand he came from somewhere other 15 than Alabama. 16 Q. How about Mr. Hosmer before Mr. McClain? 17 Was he also a company man who came from another 18 location or was he an Alabama fellow? 19 A. No, he's also an outsider. 20 Q. And Mr. Jesse? The same? 21 A. Same. 22 Q. When you came to Anniston in 1965, the folks 23 who reported directly to you, and you've gone through 24 those names for us, were they all similarly 25 transplants coming from other Monsanto facilities or 421 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051560 1 outside the state, or were any of those local people 2 or Alabama people? 3 A. There were no local people. 4 Q. The inorganic processes that had ceased by 5 the time you came to Anniston, you testified you 6 didn't know the exact dates that those situations had 7 ceased. My question, though, is do you have any sort 8 of judgment about how long they had been ceased--had 9 not occurred at the facility when you arrived in 1965. 10 Was it a year or two? Was it five years? Was it 11 fifty years? Do you have any judgment at all that you 12 could give me? A guesstimate? 13 A. I have no judgment. It's never come up for 14 discussion in my presence. 15 Q. You were asked a question about hydraulic 16 equipment, and I believe your testimony was that the 17 only hydraulic equipment you could remember being 18 there that might have had hydraulic oil that contained 19 PCBs were the air compressors. 20 A. I did, yes. 21 Q. Did you have forklifts at the facility? 22 A. Yes. 23 Q. And that would be hydraulic equipment; 24 correct? 25 A. Yes. 422 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051561 1 Q. Okay. Any other hydraulic equipment at the 2 facility other than the air compressors and the 3 forklifts--now that I've given you another 4 category--that you can think of? 5 A. I can't think of any, and of course, the, 6 the tractors you mentioned. 7 MR. WETMORE: Forklifts. 8 A. Forklift, I'm sorry, does not use the 9 fire-resistant Aroclor type of hydraulic fluid. 10 BY MR. TAYLOR: 11 Q. They do not? 12 A. No. Those are regular petroleum products. 13 Q. All right, and did I understand you 14 correctly that in your four and a half or five years 15 at the facility, you never saw any leaks of any 16 hydraulic fluids? 17 A. That's true. 18 Q. Did you hear of any or did you see the 19 evidence of any? 20 A. No. 21 Q. The sand that was brought to the facility, I 22 believe you said, was brought in a dump truck. 23 A. Yes. 24 Q. Can you give me your best judgment about how 25 often you would get a dump truckload of sand to the 423 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051562 1 facility? 2 A. Well, to give you a number, it's a pure 3 guess. 4 Q. That's fine. I'll take your best guess, at 5 this point. 6 A. I never kept score. 7 Q. You may be the only person we talk to, so 8 I'm just going to ask you to give me you best judgment 9 and-- 10 MR. WETMORE: Well-- 11 BY MR. TAYLOR: 12 Q. --give me your best guess. 13 MR. WETMORE: I'm going to object, because a 14 guess doesn't help anybody. If he has a best 15 judgment, that's okay, but a best guess, you might as 16 well let me or Mr. Jordan testify. 17 MR. TAYLOR: Well, his guess is better than 18 yours, since he was there, so -- 19 MR. WETMORE: It's still a guess. 20 MR. TAYLOR: I understand. Your objection 21 is noted. 22 A. Guess, guess -- 23 MR. WETMORE: I'll tell you, Mr. Papageorge, 24 if you have a reasonable estimate, you can give it. 25 If you are just --if it's just a guess, a wild guess, 424 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051563 1 I'm not--you don't have to give it. 2 A. I don't know how to define "reasonable." I 3 remember seeing trucks of sand coming in, and the 4 reason I remember that happening is it was unusual to 5 see a truckload of sand coming in, and it doesn't 6 happen every day or anything like that. This is why I 7 remember seeing truckloads of sand, but I didn't keep 8 score as to how many months since the last time I saw 9 it. 10 BY MR. TAYLOR: 11 Q. No, sir, and I'm not asking you to do that. 12 I, I understand there were no records kept, and that 13 wasn't your job to keep up with truckloads of sand. 14 I'm just trying to get some sense, some sense of what, 15 what kind of volume, whether it was once a month, once 16 a year, just your best judgment. 17 MR. WETMORE: You keep asking him for his 18 best judgment and he keeps saying he doesn't know, 19 he'd have to guess, so Jerry, we're at a conflict, 20 here. 21 A. If I'm forced to come up with a number, the 22 closest I could possibly come to is once in eight or 23 nine months. 24 BY MR. TAYLOR: 25 Q. What about the sawdust? Same question. You 425 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051564 1 said that was delivered in dump trucks. 2 A. Yes, see, that's even more rare, as the sand 3 became more used than the sawdust. The sawdust phased 4 out after awhile, so it's a very--it became a very 5 rare occasion when a need for sawdust came up. 6 Q. You were asked, I think, by Ms. Lavey 7 whether or not any of the sand that was used at the 8 facility or brought into the facility was foundry 9 sand, and I believe you said you didn't think so or 10 no. Are you familiar with the term "foundry sand"? 11 A. I have heard the term. I understand it's-- 12 looks different than the material that I saw. 13 Q. How did you come to that understanding? 14 A. Somebody implied that the tan-colored sand 15 like you find generally was not the type that one saw 16 in a foundry, and this sand, as I said earlier, was 17 not white beach sand, either, but it was a little more 18 toward the brown, tan side. 19 Q. And your understanding about the color or 20 appearance of foundry sand, can you tell me where that 21 came from? Your understanding? 22 A. The attorneys mentioned a very dark-colored 23 sand. 24 Q. The iron filings that you've been asked 25 about that were used to make the catalyst? 426 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051565 1 A. Yes. 2 Q. What makes up iron chemically? As a 3 chemical engineer, what makes up iron? 4 A. Well, the word "iron," itself, is the name 5 of an element, but my experience has been that when 6 people speak of iron, they're really talking about a 7 mixture of iron with other ingredients, some of which 8 add up to the definition of steel. Other mixtures end 9 up as stainless steel, or chrome steel, so iron is a 10 very common element. 11 Q. Do you have any knowledge about the makeup 12 of the iron filings that was used in the process at 13 the facility? 14 A. I do not. 15 Q. Do you know whether lead composed any 16 component or part of the iron filings? 17 A. I do not. 18 Q. When you were at the facility, were there 19 any odor issues or odor problems? 20 A. I don't know what is meant by the word "odor 21 problems." 22 Q. Let me give you an example. 23 A. Mm-hmm. 24 Q. In your time there, was there ever a 25 complaint received, from the community or neighbors, 427 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051566 1 about odor emanating from the facility? 2 A. Not while I was there, no. 3 Q. Would those complaints have come to you, or 4 was there a person that the operator would have 5 directed such a call to? 6 A. It could happen either way. It could come 7 directly to my phone, or it could go out into the 8 plant and the plant person would tell me. Eventually, 9 I'd hear about it. 10 Q. What about from employees or the union? 11 Were there ever any grievances filed or any issues 12 associated with odor? 13 A. No. 14 Q. How about with the environmental agencies or 15 departments of health? Were there any issues in your 16 time there involving odor? 17 A. No. 18 Q. There is plenty of documentation, and I know 19 you've been involved in some of these issues about 20 PCBs being released from the Monsanto facility; 21 correct? 22 A. Well, there's been reference to that 23 happening, yes. 24 Q. Yes, sir. You are aware, are you not, that 25 PCBs continued to leave the Monsanto facility after 428 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051567 1 the PC production ceased? 2 A. I'm not sure of that. In terms of-- 3 Q. Let me be more specific. 4 A. Yeah. 5 Q. You are aware, are you not, that PCBs 6 continued to leave the Monsanto facility after the PCB 7 production ceased through the PCB's being in soil that 8 continued to migrate offsite or being in the sewer 9 system that continued to have discharges into the 10 environment? 11 A. I'm not aware of any sewer system that's 12 involved with PCB. 13 Q. All right, how about the storm water runoff? 14 Are you aware that PCBs continued to migrate off the 15 facility even after the PCB production ceased? 16 A. I'm aware of PCBs downstream from these 17 limestone pits, but I don't recall exactly when that 18 presence was detected downstream from those pits since 19 the termination of production. I don't have a time 20 frame in there. 21 Q. How much time elapsed, Mr. Papageorge, if 22 you know, from the, the plant expansion that you've 23 given testimony about, from that time until the time 24 that Monsanto stopped manufacturing PCBs at its 25 facility? 429 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051568 1 A. About three years. 2 Q. And is it your understanding that Monsanto's 3 decision to cease production of PCBs at its Anniston 4 facility was not voluntary? 5 A. Was not involuntary? 6 Q. No, was not voluntary. 7 A. Monsanto is the one decided to supply the 8 PCBs still in use out of the Krummrich plant in 9 Sauget, Illinois. That was not enforced by any agency 10 anywhere; it was a Monsanto decision. 11 Q. Is your understanding that Monsanto's 12 decision to stop PCB manufacture at the Anniston 13 facility had nothing to do with the ongoing PCB 14 environmental and health issues that were circulating 15 at the time and was a business reason other than that? 16 A. The reason for terminating at Anniston was 17 the fact that first of all, the decreasing use of PCBs 18 to customers under very restrictive conditions, and 19 the fact that the Krummrich plant had a facility that 20 was newer and could produce the material more 21 economically, and was able to offer, because of its 22 plant size, more services to customers who wanted to 23 return PCBs for incineration and that kind of service 24 that they could provide which the Anniston plan was 25 not capable of doing. 430 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051569 1 Q. How new was that facility? You said it was 2 newer. 3 A. The facility I'm talking about, there's two 4 facilities. One is the incineration facility, which 5 was installed about 1972-ish, and then there's the 6 production facility, which was in place in 1965 or so, 7 so that-- 8 Q. '65 is when it was built? 9 A. No, it was in place when I went to Anniston. 10 The Krummrich plant had its own PCB unit. 11 Q. I'm only asking this because you said one of 12 the reasons was that the Krummrich plant was newer. 13 A. Yes. 14 Q. But the Anniston facility three years had 15 just been expanded and a lot of money spent, and I'm 16 just wondering, you are saying that the other facility 17 was newer. Was, in fact, Anniston more updated and 18 newer at that point? 19 A. A piece of the Anniston plant was newer, but 20 the whole complex, including the original chlorination 21 vessels, and the downstream--the continuous flow units 22 which were the new ones, the combination was a plant 23 that dated back, gosh, to the 1930's. 24 MR. TAYLOR: That's all I have. 25 MR. WETMORE: I think we have one more 431 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051570 1 lawyer. She said five minutes. 2 EXAMINATION 3 QUESTIONS BY MS. MYERS: 4 Q. Good afternoon, Mr. Papageorge. 5 A. Good afternoon. 6 Q. My name is Stacey Myers, and I represent 7 Southern Tool. I appreciate your patience through 8 what's been a long day of questioning. I promise 9 these will be very quick. First, I'm-- 10 A. Thank you. 11 Q. First, I'm wondering, you said that at some 12 point when you were the plant manager at Anniston, you 13 moved into a new office space that had no windows. Do 14 you remember what year that was? 15 A. The best I can come up with, 1966. 16 Q. Do you remember what time of the year? 17 A. Hmm: Not really. The Fall is the closest I 18 can come to. 19 Q. That's perfectly fine. Moving on to when 20 you left the Anniston plant and moved back to 21 St. Louis, I believe you testified that you left in 22 1969, due to the need to assign someone to follow the 23 PCB issue for the company; is that correct? 24 A. To a degree. In 1969, I was informed that I 25 was appointed to fulfill a position which was finally 432 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051571 1 approved by the Corporate Development Committee, I 2 think it was called. This is a group of high-level 3 officers in Monsanto. They approved the appointment 4 of an individual to pursue the PCB evolving issue. I 5 was appointed that, and as best I remember, around the 6 Christmas holidays in 1969. 7 Q. And in that position, you had knowledge of 8 the time periods during which Monsanto stopped 9 producing PCB products; is that correct? 10 A. In that position, eventually, yes, mm-hmm. 11 Q. When did the Anniston plant stop 12 manufacturing PCB products? What year? 13 A. 1970 is as close as I can come. 14 Q. And the Queeny Plant, what year did the 15 Queeny Plant stop producing PCB products? 16 A. About the same time, as best as I can 17 recall. 18 Q. For Sauget, what--when did the Sauget plant 19 stop producing PCB products? 20 A. '12. 21 Q. Were there any other plants in the United 22 States owned by Monsanto that produced PCB products? 23 A. No. 24 Q. So as of 1972, Monsanto had ceased its 25 domestic production of PCBs entirely; is that correct? 433 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051572 1 A. Yes. 2 Q. In your position following PCB issues for 3 Monsanto, were you aware of what Monsanto's 4 competitors were doing in terms of withdrawing PCB 5 products from the market? 6 A. I was aware of a few competitors' activities 7 but not all of them. 8 Q. To your knowledge, did there become a time 9 period after which PCB products were no longer 10 available commercially in the United States? 11 A. There was a date that EPA issued, I think, 12 as best I recall, 19977. 13 Q. Are you aware of any company in the United 14 States offering PCB products to customers after 1977? 15 A. There are none. 16 Q. None after 1987? 17 A. To my knowledge-18 Q. Excuse me, 1977. 19 A. Correct. 20 Q. As far as foreign corporations or 21 corporations manufacturing in foreign countries, are 22 you aware of any companies that continued to 23 manufacture PCB products after 1977? 24 A. I had heard that the Russian--the country of 25 Russia is still producing PCBs. All other producers 434 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051573 1 have terminated production. 2 Q. As far as Monsanto goes, was it producing 3 any PCBs outside of the United States after 1972? 4 A. They were not. 5 Q. My last questions have to do with Exhibits 4 6 and 5. I believe that you testified that when these 7 documents were written, that you regularly received 8 inquiries about the kinds of products that Monsanto 9 was manufacturing and the makeup of those products; is 10 that right? 11 A. Yes. 12 Q. Was there someone on your staff that would 13 provide you with the information necessary to respond 14 to these inquiries? 15 A. There's nobody--I was the single, one-party 16 staff. The way I would get my information to 17 questions regarding Monsanto products produced by the 18 entire Organic Division was to contact the individuals 19 within the Organic Division who were responsible for 20 those products, then they would give me the 21 information and I would forward it. 22 Q. Do you remember the names of any of those 23 individuals that you would contact? 24 A. I don't remember specific individuals, no. 25 MS. MYERS: Let me take one last look at 435 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051574 1 those documents. 2 (Pause.) 3 MS. MYERS: Thank you. I have no further 4 questions. 5 MR. WETMORE: Thank you. Are we done? 6 MS. LAVEY: Unless you have something, Mike. 7 MR. WETMORE: I have none, and I think we 8 will read the deposition, Jerry. 9 THE VIDEOGRAPHER: This concludes the 10 deposition of William B. Papageorge. We are off the 11 record at 3:29 P.M. 12 (Whereupon, at 3:29 P.M., 13 the deposition was concluded.) 14 15 16 17 18 19 20 21 22 23 24 25 436 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051575 COMES NOW THE WITNESS, WILLIAM B. PAPAGEORGE, and having read the foregoing transcript of the deposition taken on the 1st day of September, 2004, acknowledges by signature hereto that it is a true and accurate transcript of the testimony given on the date hereinabove mentioned. 437 WILLIAM B. PAPAGEORGE Subscribed and sworn to me before this day of , 2004. My Commission expires: . Notary Public DD Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051576 1 State of Missouri 2 ) ) SS. 3 City of St. Louis ) 4 I, J. Bryan Jordan, a Notary Public in 5 and for the State of Missouri, duly commissioned, 6 qualified and authorized to administer oaths and to 7 certify to depositions, do hereby certify that 8 pursuant to Notice in the civil cause now pending and 9 undetermined in the In the United States District 10 Court For the Northern District of Alabama, to be used 11 in the trial of said cause in said court, I was 12 attended at the offices of Husch & Eppenberger, LLC, 13 in the County of St. Louis, State of Missouri, by the 14 aforesaid witness and by the aforesaid attorneys, on 15 the 1st day of September, 2004. 16 The said witness, being of sound mind 17 and being by me first carefully examined and duly 18 cautioned and sworn to testify the truth, the whole 19 truth, and nothing but the truth in the case 20 aforesaid, thereupon testified as is shown in the 21 foregoing transcript, said testimony being by me 22 reported in shorthand and caused to be transcribed 23 into typewriting, and that the foregoing pages 24 correctly set forth the testimony of the 25 aforementioned witness, together with the questions 438 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051577 1 propounded by counsel and remarks and objections of 2 counsel thereto, and is in all respects a full, true, 3 correct and complete transcript of the questions 4 propounded to and the answers given by said witness; 5 that signature of the deponent was not waived by 6 agreement of counsel. 7 I further certify that I am not of 8 counsel or attorney for either of the parties to said 9 suit, not related to nor interested in any of the 10 parties or their attorneys. 11 Witness my hand and notarial seal at 12 St. Louis, Missouri, this 15th day of September, 2004. 13 14 15 J. Bryan Jordan 16 Certified Court Reporter No. 00532 17 State of Missouri 18 My License expires: January 1, 2005 19 20 21 22 23 24 439 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051578 1 COURT MEMO 2 IN THE UNITED STATES DISTRICT COURT 3 FOR THE NORTHERN DISTRICT OF ALABAMA 4 MAGISTRATE JUDGE GREEN 5 6 Solutia, et al. , 7 ................................... Plaintiffs vs Case No. CV-03-PWG-134-E. 9 McWane, et al. , 10 ................................... Defendants. 11 12 CERTIFICATE OF OFFICER AND 13 STATEMENT OF DEPOSITION CHARGES 14 Rule 57.03 (g) (2) (a) & Sec. 492.590 RSMO 1985) 15 16 VIDEOTAPED DEPOSITION OF WILLIAM B. PAPAGEORGE, VOLUME 17 3, TAKEN ON BEHALF OF DEFENDANTS, SEPTEMBER 1, 2004 18 19 Name and address of person or firm having custody of 20 the original transcript: 21 SQUIRE, SANDERS & DEMPSEY, L.L.P. 22 4900 Key Tower 23 127 Public Square 24 Cleveland, OH 44114-1304 440 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051579 1 TAXED IN FAVOR OF: 2 SQUIRE, SANDERS & DEMPSEY, L.L.P. 3 4900 Key Tower 4 127 Public Square 5 Cleveland, OH 44114-1304 6 199 of orig. & copy @$3.75 ............................... $746.25 7 Attendance ofreporter &Jurat ............................ $165.00 8 Delivery ........................................................................................................... $ 9 Total ...................................................................................................................... $ 10 11 TAXED IN FAVOR OF: 12 HUSCH & EPPENBERGER, LLC 13 190 Carondelet Plaza, Suite 600 14 St. Louis, MO 63105-3441 15 199 pages of copy @ $1.55 ........................................ $308.45 16 Delivery ........................................................................................................... $ 17 Total ...................................................................................................................... $ 18 19 20 21 22 23 24 441 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051580 1 TAXED IN FAVOR OF: 2 TROUTMAN SANDERS LLP 3 NationsBank Plaza, Suite 5200 4 600 Peachtree Street, Northeast 5 Atlanta, GA 30308-2216 6 199 pages of copy @ $1.55 ......................................... $308.45 7 Delivery ........................................................................................................... $ 8 Total ...................................................................................................................... $ 9 10 Upon delivery of transcripts, the above charges had 11 not yet been paid. It is anticipated that all charges 12 will be paid in the normal course of business. 13 14 GORE & PERRY REPORTING CO. 15 515 Olive Street, Suite 700 16 St. Louis, MO 63101 17 18 IN WITNESS WHEREOF, I have hereunto set my hand and 19 seal this 15th day of September, 2004. 20 21 22 J. Bryan Jordan 23 Notary Public State of Missouri 24 (St. Louis City) 25 My Commission expires January 14, 2007 442 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051581 [& - 2400] Transcript Word Index & 1262 1901 2 & 263:9 249:13 2 245:20 246:4,14 247:13 1268 1930's 267:19 269:15 271:22 248:3 249:12 250:4,14,24 263:8 431:23 293:7 328:24 360:10 252:13,14,16,17,21,24 127 1953 440:14 438:12 440:14,21 441:2,6,7 246:16 440:23 441:4 320:18 2:44 441:12 442:14____________ 1299 1957 410:18 248:20 0 13 00532 386:16,21 387:17 439:16 134 03 244:4 245:8 440:8 244:4 245:8 252:10 440:8 1345 058072 252:10 319:24 135 058089 256:25 319:25 14 090928 442:25 344:2 15 090932 324:23 344:2____________________ 150 374:10 386:4,14 2:50 1965 410:21 289:20 334:11 336:19 20 338:7 345:1,17 367:13 265:22 295:22 368:14 370:3 387:21 200 421:22 422:9 431:6 248:11 421:7 1966 20004-2400 386:4,14 387:19 432:15 248:21 1967 20015 283:6 290:4 249:5 1968 2004 289:3 295:11,13 296:9,14 244:12 245:23 252:2 437:3 1969 437:13438:15439:12 253:17,21 254:12,21 256:5 440:17 442:19 1 371:11 257:21 258:20 259:8 260:4 2005 1 150415 260:17 261:6 266:22 439:18 244:12 267:9 274:12,16,17 285:16 269:12 271:21 272:6 2007 274:19 276:6 283:12 293:1 15th 273:22 275:18 281:1,4,18 442:25 319:15 344:3 439:18 439:12 442:19 284:15 307:8 345:23 370:9 202 440:17 165.00 432:22,24 433:6 247:18 249:6 299:4,5,5,7 1.55 441:7 1970 388:16 441:15 442:6 165426 283:13 302:12 305:2 202-639-7707 1:29 289:7 312:15 323:22 363:7 248:22 362:11 165438 433:13 202-639-7832 10 289:9 1970's 248:23 295:24,25 360:18,20 165443 361:4 205 10:54 289:7 1972 247:19 248:6 249:16 329:1 165476 363:12,17 364:14 431:5 205-251-5900 100 295:12 433:24 435:3 247:17 248:11 165488 1973 20th 106999 295:18 359:10,11,22 360:17 247:14 357:2 165495 1977 21 107002 295:12 434:14,18,23 251:9 265:22,23 357:3 17 1985 2100 11 251:8 253:19 256:23 440:14 248:4 289:5,8 295:17 266:22 374:10 1987 216 11:05 175777 434:16 246:18,19 329:4,11 323:1 1988 216-621-0577 11:07 175786 344:6,9 250:19 329:14 323:1,22 326:6 199 216-621-1312 11th 17th 441:6,15 442:6 250 18 309:17 353:5,7 312:11 19977 22 12 18 434:12 251 10 272:10,11 273:2,11 256:24 320:15 1st 23 12:08 19 245:23 252:2 323:22 437:3 251 11 273:3,5,8 362:8 253:18 438:15 24 1201 190 251 12 280:14,20 282:20 250:6 245:20 246:5 252:4 441:13 2400 249 14 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051582 [248 - 75] 248 30308-2216 248:13,14 247:6 442:5 25 30309-3424 251:13282:13,14,18 250:7 251-2300 305 248:6 249:4 253 308.45 251:2,8 441:15 442:6 253-8695 31 250:9 251:19 322:21 323:1 254-1061 314 249:16 246:8 254-1999 314-480-1500 249:17 246:7 258-1439 314-480-1505 248:14 246:9 258-1616 319 248:13 251:18 26 31st 251:14271:21 285:11,16 302:11 312:10 320:17 32 265 251:20 343:21 344:1 251:9 322 27 251:19 251:15 257:5,12 288:16,21 323-2197 272 247:19 251:10 33 273 251:21 356:22 357:2 251:11 343 28 251:20 251:16 295:4,9,18 348567 280 302:2 251:12 348568 282 302:2 251:13 35 285 417:10 251:14 350 288 371:11 251:15 35203 29 248:5 251:17 301:21 302:1 35203-2618 304:10 308:7 310:1 312:19 249:15 295 356 251:16 251:21 3 359 3 329:4 344:18 362:7 440:17 3.75 441:6 251:22,23 362 251:3 373 3:29 251:24 245:22 436:11,12 30 392464 266:5 251:18260:11 319:16,21 301 392465 266:5 251:17 4 4 251:22 275:12,16 289:15 359:4,11 360:6,17 362:11 410:17 435:5 40 271:15 346:9 400 247:15 404 247:8 250:8,9 410 251:4 432 251:5 44114-1304 246:17 440:24 441:5 44115-1126 250:16 479-8545 246:18 479- 8780 246:19 480- 1818 246:8 48304-2949 248:12 4900 246:15 440:22 441:3 492.590 440:14_____________ 5 5 251:23 275:8,10 359:4,11 410:21 435:6 5:00 400:17,19 50 260:13 515 442:15 5200 247:4 442:3 53 320:19 321:3 5335 249:4 542924 282:20 542975 282:21 543057 282:18 543105 282:18 5460 263:11 57 386:18 57.03 440:14 577140 256:24 577631 273:11 577632 273:11 577633 273:9 577637 275:9 5777642 273:9_________________ 6 600 245:21 246:5 247:5,14 441:13 442:4 63101 442:16 63105-3441 246:6 441:14 65 321:11 338:10,11 431:8 650 250:15 68 372:13 686-4843 249:7 686-4844 249:6 69 272:2 305:6 372:13 7 70 310:10 700 442:15 71 310:10 363:8 72 433:20 73 359:24 746.25 441:6 75 321:11 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051583 [8:00 - amsouth] 8 8:00 400:17,19 8'09 245 22 252 2 812 250:15 85203 247 16 881-7000 250 8 885-3489 247:7 9 9 251:24 256:23 373:18 374:8 386:13,19 9:08 280:8 9:16 280:11 9:40 293:2 9:44 293:7 9202 249:7 9205 249:17 962-6688 247:8 986-5023 247:18 a a.m. 245:22 252:2 280:8,11 293:3,7 329:1,4,14 ability 261:2 287:8,17 319:9,12 able 320:25 335:13 430:21 abnormal 279:23 382:1 absorbency 348:25 absorbing 393:25 acceptability 359:14 360:1 361:4 acceptable 287:17 307:1 402:10 access 331:22,23 398:24 accident 272:24 273:17 accommodate add 256:10 275:20 347:11 369:15,25 accomplish 427:8 258:7 349:15 added accumulate 369:7,16,21 371:22,24 327:10 373:6,8,11 377:21,24,25 accumulated 378:4 407:1 330:7 331:12 391:7 adding accumulates 319:1 373:10 393:20 addition accumulating 256:10 258:19 312:20 390:2 374:21,22 379:3 accuracy additional 281:14 260:1 361:24 373:11 accurate 420:17,18,20,24 260:15 281:3 404:1 409:17 address 417:2,8 418:4 437:5 252:3 311:6 440:19 accurately addressed 283:5 360:14 394:17 achieve adem 326:10 419:22 achieved administer 260:15 261:3 264:8 311:25 438:6 314:2 328:5,10,16 adopted acid 290:19 328:7 352:24 348:7 350:3,4,17,18 355:20 advice 385:24 393:21 387:6 acidic advisor 393:21 321:6 acidity affect 349:21 350:18 acknowledges affirmative 437:4 308:14 314:7 acquire affirmatively 396:25 361:10 acquired aforementioned 304:5 438:25 action aforesaid 305:13,15 326:10 327:11 438:14,14,20 activate afternoon 377:2 362:15,16 432:4,5 active afterthought 259:17 297:8,25 302:16 264:18 411:10417:20418:8 agencies activities 428:14 287:23 292:19 302:19 agency 303:16 308:17 392:2 411:18430:9 402:25 408:1 414:16 agent 420:19 434:6 369:10,13,16 383:23 activity 409:22 259:6 260:22 265:7 279:17 ago 292:13311:11 315:17 324:23 411:1 417:11 325:24 332:19 339:11 419:11,16 340:5 407:21 417:17 agree actual 275:18 324:5 356:11 382:11 agreement 363:9,16 439:6 ahead 281:10367:7 419:10 air 278:4 295:22,25 296:13 318:13 321:25 322:15 328:3 333:10,12,22 382:14 382:19 422:19 423:2 aircraft 367:10 al 244:2,6 245:5,10 247:16 248:5 249:15 252:8,8 440:6 440:9 alabama 245:2 252:9 319:24 421:12 421:15,18 422:2 438:10 440:3 alive 376:7 allow 257:3 262:6 281:23 349:12 349:17 allowed 303:19 343:1 344:21 349:5 349:25 351:18,19 allowing 276:18 allows 378:25 alongside 351:24 alston 250:4 252:14 alston.com 250:10 alteration 256:9,11 257:23 altered 258:2 269:12 amount 287:2 300:5 301:2 305:10 310:11 311:7317:24 319:10330:7 331:11 339:13 349:13 350:15 360:20 364:18 373:9 408:16411:12 amounted 261:10 amounts 268:21 304:6 ampass 253:7 amsouth 249:14 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051584 [analogous - attention] analogous apparently area (cont.) asked (cont.) 291:4 310:25 338:21 339:23,24 345:5,8 426:24 analysis appearance 345:12,15,20 346:5,12 asking 303:20,22 304:3 320:9 257:1 426:20 347:22 349:10 354:13 272:3 308:24 386:16 326:1 357:12,18 358:19 appearances 356:6,7,12 366:6 388:12 425:11,17431:11 analytical 246:1 394:25 395:10,12 399:14 aspect 303:10,20 319:9 321:24 appeared 407:10 410:1 412:4 414:5 412:7 analyzed 305:12 310:12 414:11 415:16 asphalt 357:15 appendix areas 342:10 anchor 274:11 271:10 297:18 298:22 assign 250:12 application 304:22 305:21 306:5,9,11 432:22 anniston 396:9 408:5 308:11,17,22,23 309:1,2,21 assigned 253:17 257:1 283:1,12 applied 339:3,6 341:2 357:22 358:1 387:1 406:22 286:6 291:7 297:9 314:13 255:23 283:18 419:8 assisted 316:21 319:23 321:11 applies aroclor 365:21 324:21 329:17,20,23 333:4 282:4 254:19 256:5 257:15,16 assisting 333:14 341:7 344:23,25 appointed 258:20 260:4,17,19,24 411:19,21 357:13,14 358:11 362:1,2 432:25 433:5 263:8,9 266:12,16 268:15 associate 366:6 367:13,18 368:7,9,13 appointment 268:25 274:20,22 278:10 256:7 368:22 370:9,22 371:3,6,10 433:3 283:11 284:3,12 285:9 associated 374:3,9,14,16,18,21,22 appreciate 286:6 297:10310:12311:7 256:8 262:17 264:22 375:7,12 376:14 377:17,21 432:7 311:23 312:3,4 313:1 314:3 267:16 276:13 297:7 345:4 386:8 389:13,15,21 408:3,6 approach 315:9,12 317:24 318:15 352:17 355:8 428:12 410:8411:18412:4414:5,6 304:20 314:23 373:9 319:22 339:14 345:4,8,12 assume 414:9415:10,15,16,18,21 approachable 347:21,24 350:14,15 351:2 289:14 349:5 419:18 415:25 416:10,15,21 415:8 354:13 355:6,24 356:9,13 420:15 418:12,14,24 419:4 420:2 approaches 372:3 416:2 423:9 assumed 420:23 421:11,22 422:5 361:16 aroclors 418:18 430:3,12,16,24 431:9,14,17 appropriate 263:5,20,24 264:3 268:5,8 assumption 431:19 432:12,20 433:11 265:11 327:11 361:11 283:14,19,20,21,22 286:22 370:16,17 anniston's approval 308:10 314:9 316:17 assure 268:15 303:11 391:21 397:4 415:18 324:18 annual approved arrange atlanta 260:2,6 291:16 433:1,3 351:7 247:1,6 250:7 252:22 442:5 answer approximate arrangement atlantic 278:1 281:7 319:7,14 260:2 363:16 402:21 250:5 324:25 420:3 approximately arrival atmosphere answered 291:15 365:5 371:11 317:10 330:24 334:11 278:6 291:4 317:13,16 378:5 399:15 arrive 318:6,10 319:3,6,23 324:2 answering april 297:1 331:15 361:9 401:3 324:6,15,17,18,21 325:3,10 365:22 273:22 arrived 326:10,22,24 327:1,16,25 answers apt 289:19 301:19 305:2 330:3 333:24 439:4 361:23 330:20,21 336:19 338:11 atmospheric anticipated araclors 344:25 345:17 348:13 328:12,15,16 342:19 407:5 442:11 379:20,22,23,24 369:20 422:9 attempt anticipation area arriving 290:12 327:19 349:17 341:25 254:8 261:25 262:3,6 265:5 315:2 attempts anybody 267:22 268:2,4 269:11,25 arthur 300:25 305:21 424:14 271:16 275:17 277:17 345:18 attendance anymore 279:4 290:12 297:10,25 aside 441:7 380:15 306:15 307:8 309:5,7,12,19 282:11 283:9 311:11,15,18 attended anyway 310:2,12,14,22,24 311:1,7 315:19 316:19 335:9 339:6 438:12 321:4 311:20 315:9,12,13318:11 390:24 attention apparent 327:13 330:1,11,13 332:7 asked 256:25 267:8 275:8 289:5 381:22 332:10,22,25 334:19,21 275:3,19 362:19 373:17 291:20 295:17 332:18 335:11,19,23 336:7 338:20 411:5 414:3 422:15 426:6 417:11 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051585 [attorney - bottoms] attorney backup belief biphenyl (cont.) 439:8 417:18 325:13 327:2 297:10 307:7 344:15 attorneys bag believe 347:21 372:22 373:1,2,3,22 363:21 366:19 412:10,12 279:17 282:6,9 283:3,7 289:2 376:23 377:11 378:21,23 419:24 420:8 426:22 bagging 296:8 310:22 312:3 314:19 379:2,4,11,19 380:2,4,17 438:14 439:10 261:5 314:21 324:20 325:2 380:20 394:21 395:7 417:3 attracted bags 354:18 355:9 356:4 358:7 417:4,6,7,14,18,19,21,22 332:17 261:16 262:21,24 367:9 370:24 390:13 418:1,3,6,22 419:2 attributed baker 398:22 416:18 419:6,10 biphenyls 260:23 248:19 422:16 423:22 426:9 263:6,7,14,16 268:7 269:7 auditing bakerbotts.com 432:21 435:6 269:11,25 270:16 283:17 326:8,13,24 248:24 believed 283:23,25 376:14,15,17 august bare 325:9 378:7,10,14,18 380:8,25 312:11 300:18 bell 381:17,18 386:4 404:11 author base 358:16 bird 292:23 301:12 307:16 315:8 317:5 bells 250:4 252:15 authorized 388:9 403:3 374:6 birmingham 438:6 based belong 247:16 248:5 249:15 authors 260:10 286:25 287:1 327:4 304:22 388:15 394:23 412:11 278:21 327:12 350:15 358:4,9 beneath biswas available 370:15 381:11,22,24 265:13 248:18 253:9,9 259:25 261:3 270:22 415:19 benig bit 282:25 288:6 331:9 363:23 bases 320:24 256:12301:4311:17318:8 364:1,10 434:10 314:20 benignus 318:25 359:9 401:11 411:5 avenue basically 320:19,21,24 321:5 412:1,17419:7 248:4,20 249:4,13 364:1 384:13 388:9 benzene black average basin 378:10,19,25 379:1,15,15 342:10 343:2 408:17 399:16 299:16 310:4 346:23 347:3 379:18 blockage avoid 347:10 bergin 382:19 271:6 basis 312:22,23 blockages avoided 291:16 296:4,6 315:2 326:9 best 383:17,19 370:1 358:13 364:13 253:25 262:25 263:9 265:6 blocks aware baskets 275:17 277:23 300:18 268:13 255:22 334:9,12 341:6 377:10 385:18 301:1 307:4 308:16 370:20 bloomfield 342:12 384:4 387:2 388:25 batch 376:21 377:7 392:23 248:11,12 389:11,14,16,20,22 390:1 391:10 394:24 398:6 421:10 board 394:6 397:17 406:22 bates 423:24 424:4,8,12,14,15 363:21 407:10 409:24 428:24 266:4 273:9 285:16 295:11 425:16,18 432:15 433:5,16 booming 429:5,11,14,16 434:3,6,13 319:24 323:1 357:2 434:12 417:17 434:22 beach better boots awful 426:17 305:11 394:7 404:16 301:5 315:2 403:22 342:10 beads 424:17 bosch awhile 264:6,13 beyond 346:4 421:6 426:4 beat 420:16,24 boss b 411:9 back 273:2 280:10 287:15,19 293:6 304:10 320:10 323:17 325:11 328:9 329:3 becoming 331:9 367:15 began 336:1 337:9 329:13 358:23 360:17,24 beginning 362:10 373:19 388:25 392:5 410:20 418:10 265:2 399:7 begins 431:23 432:20 background 275:16 293:7 410:21 behalf 381:12412:13 245:19 253:5 440:17 bi 348:6 big 315:4 348:15 361:18 bill 328:19 billion 319:15 327:22,24 biphenyl 267:19 268:4,10,14,24 269:18 274:20,22 278:10 278:16,19,23,24 279:6 313:4,7 bosses 290:2 bottle 392:4 bottom 275:13 295:19 301:3 309:15 313:25 336:10 357:21 383:13 bottoms 307:11 331:17 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051586 [botts - chief] botts burnable careful certain 248:19 330:4 311:10 303:16315:18349:13 box burned carefully 399:25 412:20 301:3 340:22 330:6 331:17 438:17 certificate boxes burning Carolina 440:12 307:12 308:3 403:12 329:22 330:19 331:13 363:3 certified boy 333:1 carondelet 245:24 252:6 439:16 313:10 bury 245:20 246:5 252:4 441:13 certify brass 286:14 carried 438:7,7 439:7 248:1 253:8 burying 397:11 407:10 cetera bratsch 316:9 carry 324:3,7 375:25 376:7 business 339:9 challenging break 417:21,23 418:6 430:15 cars 314:1 264:12 279:17 280:5 293:4 442:12 309:2 chance 328:22 353:10 359:6 362:4 button cascading 323:4 bring 367:5 372:24 373:4,6,8,11 change 287:21 335:12 412:9 420:1 butzel case 258:20,22 292:25 368:8 broke 248:10 244:4 245:8 252:8 255:8 370:7 372:22 373:10 280:1 butzel.com 294:16 304:8 363:20 377:20 383:11 404:19 broken 248:15 365:19,24 379:8 411:3 420:2 276:17 330:5 bwg 438:19 440:8 changed brought 252:10 cases 258:23 290:15 363:15,18 302:25 348:24 379:14 398:21 420:7 423:21,22 c 307:14 411:22 364:21 373:3 386:4,18,23 catalyst changes 426:8 brown 426:18 brownish 287:14 bryan 245:23 438:4 439:15 442:22 bubbled 259:13 277:18 287:14 299:15 309:15,21 321:5 335:4 349:10 366:5 388:16 390:22 393:17 416:1 428:5 called 265:9 309:24 327:6 353:2 373:22 388:1 406:7 433:2 calling 334 14 376:25 budget 396:25 budgeting 396:16,18,18,19 budgets candidates 37021 cans 3256 capability 3724 396:22 capable building 250:15 257:5,12 265:1 269:9 275:2 278:4 395:9,11 399:5,8 304:9 430:25 capacity 260 12 19 24 capital built 270:9 278:8 342:19 343:4 431:8 bulk 338:4 bulldozers capture 255:7 captured 277:10 351:6 capturing burden 331:12 305:19 car buried 286:16 308:10 311:17 410:1 care burn 330:9,13 335:23 301:4 346:23 381:6,10 426:25 catch 265:15 299:15 category 423:4 catlin 389:17 cause 252:10 271:7 333:23 382:18,25 393:16 438:8,11 caused 287:14 385:21 438:22 causes 383:1 393:14 causing 265:9 295:2 381:6 cautioned 438:18 caxton 250:15 cease 430:3 ceased 257:17 422:4,7,8 429:1,7 429:15 433:24 cells 336:11 center 250:5 central 266:10,15 258:24 280:18 386:8 387:3 387:3,10 channel 310:14311:3 characteristics 269:2 318:7 charge 330:14 393:7 402:18 charged 332:12 charges 440:13 442:10,11 chat 409:9,9,10,22 check 394:10 checked 341:10394:14 chemical 319:23 331:24 406:1,13 413:3 427:3 chemically 379:1 381:9 427:2 chemicals 338:2 360:3,13 366:5 383:10 412:20,22 413:10 413:17 chemistry 381:4,12 chief 401:8 403:8 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051587 [chips - confirm] chips clarification collection complaint 409:20 411:6 264:21 267:10,13,17 276:7 365:11,15,16 427:25 chloride clarify 276:13 323:2,9 326:6 complaints 255:9 385:24,24 344:12 379:25 365:14 428:3 chlorinated clay color complete 263:6,10,12 270:16 283:16 335:3,4 348:23,23,24 349:1 426:19 310:4 439:3 283:19,22 284:1 300:8 clayton colored completed 348:8 373:1,3 376:17,18 252:4 426:14,22 271:25 272:2,4 378:7,13 380:2 381:18 clean Columbia completely 386:4 404:11 417:4,6,14,16 287:7,18,21 300:24 305:24 248:21 311:16 417:21,22 418:6 419:2 309:9 350:20 351:3 382:14 combination completion chlorinating 382:14,17 397:4 381:8 431:22 271:20 284:6 380:1,5 cleaned combining complex chlorination 286:22 300:17 350:6 256:14 431:20 254:18 257:2 348:6 349:2 381:19 comfortable component 386:10 431:20 cleaning 404:14 427:16 chlorinator 279:24 286:24 296:19 coming composed 254:21 256:2 384:11 315:25 316:14 356:1 382:2 278:4 327:9 336:24 370:22 427:15 chlorinators 382:11,13 402:19,22,24 387:6 421:25 425:3,5 compressors 377:12,13,15,23 403:1 commercial 353:9 422:19 423:2 chlorine cleanliness 331:10,15 conceivable 255:9 284:14,18 285:3 287:11 402:7 commercially 292:10 300:6 376:24 377:1 385:23 cleanout 434:10 conceivably 396:11 351:9,12 commission 292:21 chlorobiphenyls cleanup 437:15 442:25 concentration 377:2 304:20 401:12 409:22 commissioned 279:3 choice 412:3 438:5 concentrations 393:1 clear committee 319:22 chores 269:23 287:13 310:20 275:11,22 433:1 concern 401:13 402:20,22 Cleveland common 360:4 chose 246:17 250:16 440:24 271:5 306:13 427:10 concerned 332:11 441:5 communicate 287:4 313:16413:3 Christmas close 302:25 361:5 393:7 concerning 433:6 290:9 298:2 299:2 333:15 communicated 361:9 364:3 chrome 403:11 414:15 433:13 303:2 concerns 427:9 closed communication 308:9,15 chunk 341:3 290:2,22 conclude 343:2 closer communications 311:22 chunks 298:23 290:8,13 360:12,24 concluded 268:13 closest community 436:13 churned 416:24 425:22 432:17 427:25 concludes 350:1 cloud companies 436:9 chute 333:18,23 434:22 concrete 278:16 Clydesdale company 308:22,25 309:3,6 310:3 chutes 298:16,19 395:3,12,13,15 250:2,24 398:21 411:17 316:25,25 317:2,6,8 340:4 274:6 coating 412:2,5 418:11 421:17 condition circulating 277:21,22 432:23 434:13 420:3 430:14 coatings company's conditions citizens 360:13 319:23 402:1,2 430:18 411:18 coil compared conducted city 270:20 258:23 260:12 331:25 384:2 341:10 354:19 355:3 coils compensation confess 389:13,15 408:3,5 438:3 270:21 420:17,18,21,24 413:2 442:24 collect competitors confirm civil 279:10 339:4 434:4,6 327:3 438:8 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051588 [conflict - cover] conflict container (cont.) control (cont.) correct (cont.) 425:19 377:6 404:14 406:17 301:2 305:4,23 318:2 332:11 334:15 335:15,24 confused containerized 404:15 335:25 341:17 343:7 307:10 334:22 338:5,9,15 controlled 344:17 345:9,20,21 346:8 congressman containers 305:11 327:20 420:5 349:6 352:3,13,15 354:16 311:25 335:10 337:22 340:20 controlling 354:17 355:17 359:12,13 connection 342:21 343:15 397:10 270:18 302:17 304:18 359:16 365:9 366:24 269:17 277:4 353:8,14 containing 327:7 367:13,14 369:4 370:4,5,11 365:12,22 373:10 375:11 271:15 331:20 337:22 controls 370:12371:12,18,19 380:24 381:16 392:9 338:25 375:4,9,14 391:6 257:3 336:15 372:25 373:5,12,15 374:11 398:20 410:7 403:11 convenience 374:12 378:15 379:13,16 connections containment 407:15 379:17 380:5,8 381:12,13 392:17 308:9 convenient 381:15 382:8 384:6,20 consider contains 407:19 385:19 387:11 388:7,8,10 324:2,10,14 270:16 conversations 388:11,24 389:10 394:19 considerable contaminated 413:13 394:20 395:4,20 398:25 304:12 408:23 conveyed 400:6,9 402:25 404:2,2,6 considered contaminating 261:15 262:20 385:6,11 407:6 418:7,7,16 420:22 321:20 324:18 408:19 335:11 conveying 422:24 428:21 432:23 418:19 contamination 279:20 433:9,25 434:19 439:3 consisted 287:12 301:5 303:13 conveyor correcting 376:20 cont'd 262:19 263:1 265:13,15 304:18 314:25 consistency 251:2 269:4 274:4,5 279:21 280:1 corrective 342:7,25 409:5 content conveyors 326:9 consistent 342:13 349:21,22 359:19 262:17 correctly 281:24 419:9 360:3,25 cool 354:20 391:12418:13 consolidation contents 270:23 353:19 419:12 423:14 438:24 257:2 376:22 cooled counsel constant context 261:13 246:1 252:11 292:25 439:1 364:20 255:17 cooling 439:2,6,8 constituent continue 270:2 344:21 353:8,10,11 counterpart 263:19 252:7 257:16 353:15,19,23 354:6,9 375:16,24 constitute continued cooper countries 294:10,11 253:11 410:7 428:25 429:6 249:12 252:24 434:21 constructed 429:8,9,14 434:22 coordinate country 334:24 336:8 348:14 389:2 continues 372:18 434:24 399:9 273:12 363:24 copies county construction continuing 398:10 245:21 389:17 438:13 390:8 255:14 281:10 289:12 copy couple consultancy 325:2 384:10 273:16 312:20 358:25 312:13 344:10 373:20 363:4 continuous 441:6,15 442:6 399:22,24 400:4,10 406:11 consultant 431:21 corporate 411:1 362:23 364:13 continuously 372:17,19 433:1 course consumed 276:7 corporation 266:11 317:2 318:24 377:4 contract 375:8 339:10 353:21 372:10 contact 419:19420:11 corporations 374:14 407:16 411:22 353:10,11,14 354:6,9 contractor 434:20,21 423:5 442:12 411:25 435:18,23 285:2,6,8 390:5 correct court contain contractors 254:6,9,10 256:21,22 245:1,24 252:6 265:21 255:9 270:21 297:19 306:7 389:24 259:20 261:19 263:15,21 272:9 288:20 301:25 348:8 408:10 contributing 267:2,3 268:9,17 269:18 319:20 343:25 438:10,11 contained 276:5 274:25 278:11 281:18,19 439:16 440:1,2 321:16 366:23 404:10 control 282:4 289:4 295:15,16 cover 422:18 257:3,4,9 258:13,15 267:20 299:21 306:2,7,8 308:2 276:19 277:11 299:8,12 container 267:21,24 268:1 269:17,24 310:24 314:6 323:23 307:13 335:7 390:16,19 264:1 316:6 340:24 377:3,5 270:5 289:13 295:1,20 325:12,16 328:4 330:12 391:1,2 405:22 410:1,9 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051589 [cover - deposition] cover (cont.) customers decision demisters 419:7 264:19 268:12 342:19 330:8 430:3,10,12 254:20,22,25 255:2,6 256:2 covered 359:18 360:3 361:5,11,15 decontaminate demolished 253:24 254:1 275:1 301:14 361:18 408:4 430:18,22 409:1 286:18 333:21 337:16 349:1 434:14 decontaminated demolition 390:15 391:4,8,9 393:18 cut 408:9 258:17 420:16 258:7 335:6 decontamination demonstrated covering cutting 408:15,20,25 314:2 254:2,4 276:21 299:24 402:4 decreasing dempsey 391:15 cuyahoga 430:17 246:14 252:13 440:21 crane 250:17 deemed 441:2 408:18 cv 408:13 department create 244:4 245:8 252:10 440:8 deep 266:11,15 288:1,9,24 348:5 369:12 383:16,19 d 315:7 340:12 289:15 292:5,6 293:15,20 390:23 dark defendants 295:10 300:19 304:14 created 342:2 378:10,18 380:8 426:22 data 245:11,19411:2 440:10,17 308:1 321:4 339:6 351:2,10 defendant's 372:1,18 382:8,10 385:6,11 390:1,21 396:10 creates 324:16 325:4 328:9 date 251:8,9,10,11,12,13,14,15 251:16,17,18,19,20,21,22 387:9 391:16 394:3 398:7 406:20 415:19 304:20 315:23 creating 270:19 327:1 337:14 378:6 252:2 272:4 295:11 302:25 320:14,17 374:11 412:10 420:1 434:11 437:5 251:23,24 265:23 272:11 273:5 280:20 282:14 285:11 288:16 295:4 departments 304:7 394:3 402:16 428:15 depend 378:13,23 385:3 creation dated 266:22 281:1,17 359:24 301:21 319:16 322:21 343:21 356:22 373:18 325:16 dependable 380:24 creek 309:24,25 352:20,22,23,24 431:23 dates 312:16 321:9 363:12 422:6 374:8 386:13,19,21 defense 249:10 252:25 319:10,11 depended 391:6 407:15 409:5 353:1 critic datron 250:12 253:10 define 425:2 dependent 352:2 311:24 cross 303:13 day 245:23 288:7 341:13,16 355:10 358:23 359:5 360:9 defined 294:9,13 definite depending 292:19 315:17 349:16 382:25 408:16 409:2 crossed 259:5 362:22 364:19 365:4 399:15 400:2,5,11,19 274:3 definition depends 279:16 287:23 crossing 334:25 414:14 416:6,17 425:6 432:8 437:3,13 438:15 427:8 definitions depicted 416:7,20 crushed 439:12 442:19 348:17 depiction 264:7 299:8,11,13,18,23 308:21,24 309:6,8,12 310:2 340:2 349:1 days 362:20 dc 411:1 degree 263:9 412:6,11 432:24 degulis 416:10 depleted 385:17,22 curbed 395:14 curbing 305:22,22 306:5,6,10,12,13 249:5 dead 411:9 deal 250:14 deliberately 299:15 340:4 delivered deponent 439:5 deposing 365:18 366:3 306:15,19 307:7 310:3 357:18 296:25 379:18,19 426:1 deposit current 344:18 currently 252:9 344:20 dealer 392:24,25 393:1 dealings 361:25 delivering 391:13 delivery 441:8,16 442:7,10 277:20,20 391:9 depositing 390:25 deposition curt debris demand 244:14 245:18 251:8,9,10 250:23 252:5 custodianship 258:16 deceased 417:25 demands 251:11,12,13,14,15,16,17 251:18,19,20,21,22,23,24 398:7 custody 376:8 decided 385:13 demister 252:7 293:1,8 328:25 329:5 362:7,12 365:7 373:19 440:19 368:20 404:10 430:7 255:7 410:17,22 436:8,10,13 437:3 440:13,16 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051590 [depositions - document] depositions detergents direct (cont.) dismantle 420:14 438:7 300:23 336:16 344:4 368:23 369:6 257:4 derived determination 369:13,15 370:2 381:14 dismantled 366:12 319:22 directed 256:5 257:5 258:14 284:12 describe determine 280:2 289:8 323:25 354:10 284:15 389:24 390:4,8,11 256:11 261:5,7,24 262:11 281:13 292:24 337:15 428:5 dismantling 291:3 348:15 376:13 342:13 406:12 direction 256:7 257:8 284:3,9,17 409:21 412:8 determined 325:17 349:14 391:17 285:3,9 286:6 382:3,6 described 341:22 directions disposal 266:20 269:14 273:19 determines 346:24 315:23 316:2,8 331:11 283:4 296:18 368:21 413:5 287:16 directly 335:10 340:7,10 341:7 describes determining 254:7 421:23 428:7 344:19 389:20,22,23 344:18 373:22 296:5 director 391:18404:25 405:7,8,16 describing develop 312:23 368:17 370:1 405:25 265:8 277:16 279:5 338:23 289:15 290:4 326:7,23 dirt disposed 355:10 378:12 412:18 327:6 306:21 332:23 335:3,4 258:11 337:24 341:15,23 description developed 339:23 340:2 409:23 390:2 392:22 255:14 265:11 281:3 291:25 293:11 dirty disposing 299:14,22 372:23 394:24 developing 301:7,9 314:24 393:1 395:4 392:13 dirtying distance deserved development 301:10 270:23 325:5 276:3 367:23 290:16 293:13,14 294:7 disappointed distillate design 433:1 304:12,14 331:17 372:15 device disappointment distillation designate 261:11,13,14,16301:1 305:14 257:3 383:4,8,14 403:8 devices disassembly distilled designated 294:25 382:9 383:12 291:24 difference discarded distinguish designation 304:19 391:11 404:4 294:18 407:11 different discharges distinguished designed 264:19 268:5,24 270:10 429:9 268:4 271:20 294:22 349:12 277:9 279:2,3 283:15,15 disclosed distribute 376:22 377:23 290:20 301:1 303:23 365:23 259:16 designing 310:15 323:3 359:19 360:2 disconnect district 420:4 373:9 378:16,20 392:17 287:25 245:1,2 248:21 252:9 438:9 desired 406:9 419:7 426:12 disconnection 438:10 440:2,3 352:12 difficult 382:9 disturbed despite 300:13 304:20 305:24 discontinue 401:4 407:5 309:9 315:24 316:14 331:3,6 ditch detail 336:23 349:19 discontinued 309:17,20 349:11,20 256:13 259:3 270:1 347:11 difficulties 283:18 331:2 352:16,17,18,23 353:3,6,7 368:21 373:22 389:23 287:2 discovery ditches 393:3 difficulty 394:7 309:22,23 details 277:16281:13 discuss division 266:20 326:16 411:23 digging 361:11 313:17,18,19 368:19 detect 390:23 discussed 435:18,19 319:12 322:9 dii 259:7 295:12 406:8,12 divisions detectable 253:9 412:24 336:11 322:13 diminish discussing dock detected 385:22 363:21 411:8 254:3 326:1 429:18 diminished discussion docks detection 312:5 403:25 329:12 406:18 413:1 253:20,23 360:20 direct 422:14 document detergent 246:8,18 247:18 256:25 discussions 253:20 265:22 266:7 300:25 267:8 274:7 275:8,12 254:22 321:17 407:2 271:18272:8,18,21 273:4 278:13 289:5 295:17 273:25 274:15 276:12 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051591 [document - engineering] document (cont.) driving duplicative either (cont.) 279:11 280:14,16,24 281:2 318:12 362:21 428:6 439:8 281:6,12,17 282:23 283:4 drop dust elapsed 285:15,19,21 288:22 289:2 325:11 264:21 267:9,13,17 276:6 429:21 289:6,7,11 290:17 295:18 droplets 276:13 277:21,21 278:16 electric 296:15 301:25 302:5 308:7 255:8 278:20,23,25 279:1,6 270:20 361:19 315:20 320:2,4,6,12 344:1 dropped 306:21 333:10,12 element 344:3,4,5,8,9 357:6,12 325:19,20 385:18 duties 427:5,10 373:20,24 374:8,11 387:3 drove 314:15 375:11 emanating 387:16 414:13 duty 428:1 documentation drum 403:9____________________ emission 428:18 documents 273:13 323:3 435:7 436:1 document's 267:4 dodge 247:11 252:18 362:18 doing 304:6,9 328:19 351:3,9 412:3 430:25 434:4 dollars 364:19 420:15,24 domestic 433:25 doors 276:17 double 348:18 doubt 296:12,16 downhill 394:24 downstream 429:16,18 431:21 drain 351:18,19 drainage 309:10,22 310:3,14 311:2 349:11 drained 311:10,14 drains 356:8,12,14 dramatically 395:1 dribbles 311:19 drip 305:25 dripped 305:19 dripping 392:12 394:1 drive 333:15 265:10,13,14,15,16,17,19 e 291:23 292:12294:11,18 269:3 341:3 390:14 drummed eaddy 247:2 294:19,21,23 295:22 333:25 387:25 388:1 earlier emissions drumming 256:16 280:25 281:3 282:8 284:15 298:15,15 310:16 310:17,21 317:12,15,18 278:4,6 289:16,21 290:6,15 291:2,7,11,15293:12 308:10 310:12,24 311:1,7 drums 322:2 324:23 325:8,9 333:20 353:16 354:12 295:25 296:14 333:4,7,20 333:23 261:16 262:22,24 306:25 335:7 337:24,25,25,25 338:24 339:4,15 341:2 369:21 370:1 372:3,16 373:24 378:17,17 383:9 384:12 390:7 397:3 409:2 emit 325:10 emphasis 343:17 391:6 403:10,12 404:5,9,18,20 405:1,7,8,16 414:4 426:16 early 304:15 employed dry 304:14 307:13 dsw 283:17,23 310:10 easier 306:11 323:21 358:18 370:23 employee 321:1 344:11 256:24 266:5,5 273:9,9,11 273:11 275:9 282:18,18,20 easily 408:11,14 employees 294:14 298:24 301:5,7 282:21 285:16 289:7,7,8 295:11,12,18 302:1,2 323:1 323:1,22 326:6 344:2,2 east 334:17 eating 399:14 400:25 428:10 employment 366:22 374:18 357:2,2 due 393:22 economically emptied 307:17 301:6 432:22 dug 430:21 edge empty 307:19 348:21 391:10 339:18 enclosure dukes 248:3 duly educational 364:2 effect 262:12,15,24 263:2 encompass 344:15 438:5,17 dump 297:1 330:2,11,19 331:23 331:25 332:7,10,22 334:4,9 382:13 effects 407:5 efficient encountered 287:2 encouraged 301:7 334:14,16 336:1,7 339:5 331:14 ended 340:8,8 341:19 351:15 388:1,5 389:8 390:14 404:6 405:19 423:22,25 426:1 dumping effort 382:11 efforts 314:11 372:19,19 278:24 346:22 ends 353:1 383:6 enforced 336:4 ehinger 430:9 dumpster 340:21 248:2 253:7,7 eight engineer 427:3 dumpsters 340:15,18,20 365:5 400:2 425:22 either engineering 266:11,15 292:22 372:18 duplicate 411:4 275:24 278:10 292:22 298:21 340:1 341:3 426:17 387:6 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051592 [ensured - facility] ensured erected examination expanded 402:1 348:14 251:2,3,4,5 253:11 362:13 259:24 431:15 entail escape 410:23 432:2 expansion 261:8 276:19,25 277:11 308:19 examined 253:16 254:11 257:20 enter 327:7 404:12 438:17 260:3,17 261:1 266:12,16 256:15 escapes example 269:12 372:16 390:9 entered 318:25 369:11 260:12 261:10 283:2 429:22 298:25 escaping 294:20,24 297:19 298:3 expect entering 277:3 301:3 303:8 305:17 306:16 398:12 298:20 esq 309:1 317:1 318:16 392:7 expected entire 246:3,13 247:2,12 248:2,9 412:1 415:14 427:22 333:16 349:16 406:6 289:6 335:20 418:15 248:18 249:2,11 250:3,13 examples expenses 435:18 essence 337:22 361:19 413:9 420:16 entirely 258:7 excavated experience 262:15 433:25 essentially 335:13 390:20 427:5 entitled 352:4 excavation expertise 289:15 319:21 established 299:16 335:7 304:6 entrainment 286:24 290:19 361:21 excessive expires 255:10,12,17,20,23 estimate 310:12311:7 437:15 439:18 442:25 entrance 349:19 424:24 excuse explain 298:5,6,9,10,16,22 332:7 et 329:9 342:21 398:4 434:18 256:17 409:20 395:12 244:2,6 245:5,10 252:8,8 exhaust explained entrances 324:3,7 440:6,9 324:2,6 254:23 298:7,12,17 eugene exhibit explosion entrant 322:19,20 251:8,9,10,11,12,13,14,15 271:7 298:5 europe 251:16,17,18,19,20,21,22 exposed environment 304:1 251:23,24 253:18,19 277:23 302:18 308:19,20 312:5,8 evaluation 256:23 265:22,23 272:9,11 exposing 324:16,19 327:7,10 340:2 296:7 272:19 273:2,3,3,5,8,11,14 270:19 404:12 429:10 evening 280:14,20 282:13,14,18,20 exposure environmental 400:20 282:20,24 285:11,16 402:5 318:2 328:12411:17 event 288:16,21 295:4,8,18 express 428:14 430:14 318:24 350:22 352:8 301:21 302:1 304:10 308:7 303:15 envisioning 400:23 310:1 312:19 319:16,21 expression 340:22 events 322:21,25 323:5 343:21 255:23 327:18 334:7 epa 273:19 296:4 344:1 356:22 357:2,7 342:17 353:4 409:12,15 328:7 411:17 419:22 eventually 358:24 359:11 360:6,16 extend 434:11 277:21 279:10,24 283:18 373:18 374:8 386:13,16,19 306:3 eppenberger 283:25 303:14 306:19,25 386:21 387:17 extending 245:20 246:4 252:3 253:2 310:8 316:6 327:20,21 exhibits 301:10 438:12 441:12 335:9 349:6 352:25 390:4 251:7 358:22 416:5 435:5 extensions equipment 390:15 391:4 393:25 existed 254:1 256:8 258:10 261:6,8,18,23 403:18 404:5 428:8 433:10 264:17 283:6 328:18 extent 262:1,18 265:8 274:2 everybody 397:19 260:20,21,22 286:8 305:23 276:19,22 277:2,12 281:24 331:22 existence extremely 286:15,15,18,21 288:3 evidence 256:10 369:20 260:9 303:22 319:8 302:24 303:10,18,19,21,24 328:17 423:19 304:1,5 317:5 318:14,21,21 evolved 318:24 325:14,21 332:17 322:3 351:5 376:13 378:6,13,16 evolving 378:22 379:5 382:4 389:24 303:23 372:12 433:4 390:3,10 392:2 394:4 exact 401:12 422:16,17,23 423:1 297:24 312:16 321:9 era 363:12 422:6 310:10 332:19 exactly 415:22 429:17 existing 256:19 257:4 260:19 303:12 304:21 309:14 371:16,20 exists 357:23 402:3 exit 263:1 352:2 exits 349:5 f facilities 256:16 303:12 375:13 389:6 400:5 401:14,15,23 415:11 421:25 431:4 facility 254:19 256:5 257:15 260:19,25 261:25 262:2,11 268:15,24 284:3,12 285:9 286:6 306:18 318:15 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051593 [facility - followed] facility (cont.) faucet find flakes (cont.) 325:15 334:3,3 339:15 392:8 282:24 287:18 324:12 265:16 269:4 340:16 342:23 345:2,23 favor 325:5 328:17 336:23 flaking 347:22,24 349:3 355:6,24 441:1,11 442:1 358:24 366:7,15 385:12 261:5,18,22,22 262:14,18 356:9,13 368:10 370:3 fax 406:16 409:19 426:15 264:10,11,22,24 265:3,3,9 374:16 375:17,21 379:12 246:9,19 247:8,19 248:14 fine 267:21 268:1,3,7,8,23,25 379:15,19 380:4,5,20 386:8 248:23 249:7,17 250:9 278:25 280:6 424:4 432:19 269:3,6,11,18,25 270:18 389:17,21 390:23 391:22 feature finish 277:6 281:1,4 282:8 353:17 394:21 395:7,18,25 396:5,7 306:13 335:6 316:10 flame 396:10 397:14,19,23 features finished 270:20,25 271:6 398:16 399:17 403:11 336:9,12 287:12 318:19 342:23 flames 405:12 407:23 409:25 fed 383:12,16 414:14 410:4,8 415:15 416:2,7,12 354:3 fire flange 417:12418:2 419:11 fee 270:15 271:1,7 354:25 392:10,11 421:12 422:9,21 423:2,15 411:11 423:9 floor 423:21 424:1 426:8,8 feel firm 276:8,10,18,20,21 306:20 427:13,18 428:1,20,25 387:7 400:22 411:24 362:23,25 363:5,7,15,23 307:12,15310:12311:8 429:6,15,25 430:4,13,19 feet 364:13 365:1,7 411:8 315:24 316:14 356:8 431:1,3,4,6,14,16 308:20 334:1 371:6 412:10,15419:19440:19 391:21 392:16 397:5 fact fell first 402:12 404:4 258:14 271:24 283:5 277:7 307:25 257:1 267:1,20 270:8 floored 286:16 296:12 304:16 fellas 278:13 281:20 286:10 265:5 306:18 308:16 310:6 403:22 289:19 304:16,21 308:8,23 floors 326:14 327:15 374:8 fellow 312:21 315:21 316:3 324:1 275:5,6 304:13 305:10 384:12 398:12 407:4 421:12,18 327:3,8 336:1 341:13,16 316:16 325:24 354:13 415:15430:17,19431:17 felt 344:13 347:7 357:11 402:23,24 factors 370:19 404:14 358:23 359:5 361:13 flow 371:15381:8 fence 362:22 363:7 364:19 365:4 299:17,17 306:17,17 fail 297:12,13,14 299:1,3 322:2 366:8 378:9 400:18 401:25 309:14,20 336:16,20,22 392:3,11 322:6 403:19 416:6 430:17 432:9 347:23 349:3,5,9,13,16 faint fenced 432:11 438:17 354:15 356:5,6 382:24 322:11 388:12 389:7 fit 392:6 431:21 fair ferric 258:6,7 flowed 291:6 385:24 fits 309:24 337:1 352:16 fairly fiber 258:5 flowing 407:19 261:16 fitting 356:15,16 fall fifty 392:12 fluid 351:10432:17 422:11 five 270:16271:1,12,15423:9 familiar filed 328:21 377:8,9 415:24,24 fluids 269:16,19 322:14 326:17 295:23 428:11 418:2 419:16,17 422:10 312:24 313:20 367:10 327:13 334:6,13 336:9 filings 423:14 432:1 423:16 342:15 361:21 381:25 377:3 384:13 385:21 fixed flushing 399:23 409:8 414:10,23 426:24 427:12,16 407:14 288:5 417:5 426:10 fill flake fmc far 261:16,16 335:12 362:21 261:15 264:12 274:7 277:7 249:10 252:24 256:18 270:23 280:17 392:4 403:6 353:20 focus 287:4 318:11 322:8 325:15 filled flaked 288:22 325:19 416:11 434:20 311:17400:2 263:4,17,19,21 264:4,6 folks 435:2 film 268:10,15 335:17 397:17 405:24 farm 277:24 flaker 416:1 421:22 258:19 259:1 filthy 265:10,13,17 274:1,25 follow fashion 402:10 275:4 276:17 277:4,8 278:7 264:11 282:10 309:13 271:3 final flake rs 312:12 349:9,14 362:19 fast 274:8 274:22 432:22 391:6 finally flakes followed 432:25 261:15 262:20 264:12 282:3,7 286:3 331:4 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051594 [following - group] following 305:7 383:15 410:10 412:17 434:2 foot 395:12 403:14 408:17 force 298:11 forced 425:21 foregoing 437:2 438:21,23 foreign 434:20,21 foreman 403:8 foremen 387:5 forget 347:11 forgot 413:2 forgotten 306:14 335:18 forklift 397:11 423:8 forklifts 332:3,18 422:21 423:3,7 form 264:4,8,19 268:12,19 277:14 330:2 384:19 formal 363:9,16 394:10,12 formalized 364:16 formed 309:22 355:21 former 262:20 forming 277:20 forms 264:5 forth 300:15 339:4 360:24 438:24 forties 320:10 forward 382:20 435:21 found 319:8 322:1,2 366:16 412:20,21 413:4,5 foundries 414:5,10,13 415:10,16,20 416:1 foundry gases go (cont.) 250:1 252:16 362:1 414:15 355:9 318:11 322:10328:15 414:17,18,19416:11,15,20 gasket 329:10331:13337:13 416:24 426:8,10,16,20 392:10 341:18 342:3 343:5 349:8 four gated 355:19 358:23 367:7 315:6,17411:15415:24 332:7 383:14410:14428:7 423:14 gates goal frame 298:24 311:25 327:19 411:5 321:8 357:19 429:20 gateway goes franklin 250:24 265:9 276:16 383:5 435:2 412:15 gather going fred 277:22 253:17 270:5 272:8 273:2 313:13,14 gathering 280:4,13,15 281:8 299:15 frequencies 259:14 372:11 314:4318:12320:11,24 381:21 gene 321:5 323:8 326:22,25 frequency 312:20 370:10 327:2 330:16,22 331:1 286:23 287:5 339:13 general 336:23 347:5 352:2 353:22 350:10 259:13 291:14 297:18 359:4,10 361:10 366:5 frequent 303:8 307:24 312:8 330:1 376:25 390:22 399:23 350:23 393:16 334:18 352:1 361:19 400:9,23 413:13 417:1 frequently 393:16 401:13 419:12424:8,13 350:8 391:2 generally good front 266:9 288:21,23 303:6 253:13,14 301:4 304:18 308:8 318:10 336:25 340:21 328:23 362:15,16 367:23 frustration 344:4 360:10 426:15 412:1 432:4,5 303:17 generated gooey frustrations 270:21 292:4 341:1 343:5 316:17 302:20 303:1,3,7,9,11 347:24 348:1 355:15 379:9 gore fulfill gentleman 250:24 442:14 432:25 383:22 gosh fulfilled geographical 431:23 342:2 335:5 grabbing full george 301:10 260:18 397:10 439:2 282:19 gravel fumes getting 333:2 339:24 318:18 402:5 414:14 287:24 303:9,11 315:1 gravity function 371:6 349:24 407:5 295:1 381:6 382:7 functional gii 248:17 great 287:5 312:24 313:19 give greater further 294:20 323:3 357:3 397:23 318:25 305:7,9 309:4 343:4 347:7 403:22 422:12 423:24 green 360:23 369:7 436:3 439:7 424:2,8,12,24 425:1 427:22 245:3 440:4 g 435:20 greensboro ga given 363:3 247:6 250:7 442:5 gale 249:12 252:24 gallon 307:22 368:16 382:7,10 423:3 429:23 437:5 439:4 giving 319:13 grievances 428:11 gritty 316:16 377:8,9 glass ground gaps 362:21 402:12 gloves 276:8,10 318:6 325:21 339:23 344:21 348:21,22 gas 301:7,8,9 255:18,21 256:1 270:20,25 go 407:23 group 376:24 396:11 258:3,4 263:2 273:2 279:19 249:3 252:20 284:24 286:3 281:10 300:7 301:9 305:23 293:17,18,19,23 294:1,3 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051595 [group - husch] group (cont.) happening height holding 313:1,15,22 331:25 332:2,5 384:4 425:4 428:23 336:25 354:1 332:12 335:17,24 361:7 happens help hole 372:2 385:6 387:2 406:5,15 274:8 264:7 302:20 314:19 335:8 341:3 348:22 391:8 406:16 433:2 happy 317:17 329:18 347:11 391:10 groups 358:25 351:11 363:6 372:14 holidays 298:11 406:6 harbert 424:14 433:6 growing 249:14 helped holz 418:9 hard 292:24 313:10 guards 303:15 334:24 356:15 hereinabove holzapfel 338:17,19 harden 437:6 313:11,13,14 guess 344:21 hereto home 277:1 291:25 424:3,4,12,14 haul 437:4 392:8 398:10 424:15,17,19,22,22,25,25 331:9 389:25 407:18 hereunto hope 425:19 hauled 442:18 369:11 guessing 343:9 351:15 herman hoped 348:19 haulers 267:5 305:6 guesstimate 331:15 hesitate hopefully 422:12 hauling 264:5 311:24 358:22 362:21 guidance 369:3 hesitating hopper 294:14 hazard 334:22 274:8,9 guidelines 402:3 hexagons hoppers 361:22 hb 379:2 274:6,20 h 271:15 346:9 hey horse half hcl 415:24 423:14 355:9 hamper head 339 19 hand 254:16 308:14 314:7 headed 253:17 272:8 280:13 288:2 277:8 373:19 439:11 442:18 heading hanrlprl 289:12 295:19 350:20 403:21 416:2 high 294:25 295:2 335:1 409:4 433:2 higher 300:7 302:22 336:24 367:24 highway 411:9 hose 311:18,19 392:3,4,5 hoses 311:10,13 hosing 306:20 354:13 hosmer 280:24 343:25 handing 285:15 288:20 295:8 301:25 319:20 322:25 357:1 handle 332:6 346:21 408:18 handled 256:1 316:9 332:4 384:2 408:20 415:3 handlers 408:11 handling 258:24 279:18 344:3,19 361:6 393:4 406:1 handrail 301:6,10 handrails 300:10,15,24 happen 384:5 386:1 392:21,21 406:18 425:6 428:6 happened 398:22 headquarters 388:15,16 394:23 395:19 421:16 370:10 hill hot health 343:19 388:10 277:7,23,25 428:15 430:14 hills hour hear 248:12 280:4 400:2 421:3,7 278:22 378:11 423:18 hillside hourly 428:9 309:16 390:24 421:5 heard historical hours 352:17,19 353:4,7 400:23 374:15 397:23 245:22 365:5 399:22,25 409:12 426:11 434:24 hit 400:4,10,13,16 heat 254:7 277:19 367:5 house 270:15,25 271:4,9,12,14 hmm 401:22 277:6 288:4,5 376:22 379:6 262:25 275:15 281:16 housekeeping 379:7 381:7,10 308:14 339:2 340:10 354:4 275:17 307:24 401:13,21 heated 354:14 356:21 372:13 401:23,25 402:15 270:22 342:24 379:24 395:5 398:18 399:21 howard 393:18 427:23 432:17 433:10 312:23 heating hodges huckaby 270:3,21 313:9 248:3 heavier hoffmann huron 349:25 350:18 250:14 248:8 250:15 heavy hold husch 318:9 333:4,7 352:8 358:6 335:7 380:14 406:7 245:20 246:4 252:3 253:1 358:8,20 360:25 438:12441:12 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051596 [husch.com - involve] husch.com incidence ineffective instruction 246:10 279:25 276:6 280:25 282:2,8,12 hydraulic incidences influencing instructions 367:10 422:15,17,18,23 279:22 302:21 281:22 282:25 423:1,9,16 incident information instrument hydrogen 291:19292:11 260:11 321:16 322:16 402:8,12 255:9 377:2 378:25 380:25 incinerated 327:10,12 350:11 361:24 instruments 381:3 385:24 329:20 364:3 365:23 372:11,15 402:9 incineration 385:5 400:1 411:25 412:25 insulated idea 329:17,18 430:23 431:4 435:13,16,21 278:16 255:7 282:1 302:16 328:23 380:11 identical 297:18 include 299:13 317:13,16 344:14 385:8 402:22 included informed 284:4 432:24 infrequent 287:6 insulation 393:19,20,25 intended 301:13 335:10 383:4,15 identification 263:10 284:1 307:24 ingredient intent 265:25 272:13 273:7 280:22 282:16 285:13 309:21 313:1,19 330:5 346:25 347:10 319:1 409:6 ingredients 281:25 301:16 305:4 308:19 331:3,6 349:19 288:18 295:6 301:23 319:18 322:23 343:23 includes 263:5 403:9 427:7 initial 377:1 interaction 356:24 416:10 identify 252:11 274:14 284:7 including 431:20 incoming 303:25 369:22 initially 303:9 336:8 363:6 393:23 410:8 interactions 414:4 415:25 identifying 311:6 259:14 increase initials 320:16,19 interceptor 310:4 identity 323:17 413:4 ignite 371:10,14,16,17,25 372:5 373:8 increased injection 340:12,12 inorganic interest 319:5 interested 330:8 ignored 260:25 364:22 371:20,23 422:4 372:4,10 inquiries 439:9 interfere 418:3 ii 249:11 index 251:1 indicated 359:18 360:2 435:8,14 insecticide 345:5,6 371:23 372:2 408:1 interior 275:23 iii 244:15 245:19 280:17 298:15 323:18 343:3 366:21 367:12 insecticides 387:13 intermediary 343:10 illinois 374:24 430:9 371:14 372:3,21 390:13 391:20 405:24 inside intermediate 261:18 262:15 269:9 279:6 346:6 immediately indicates 297:12,14 399:16 interrogatories 318:14 343:9 immersed 261:11 270:4 indication 360:19 416:18 inspection 394:6,10,12 inspections 365:22 introduce 253:4 372:14 implied 426:14 implies 258:3 indirectly 415:21 individual 266:20 291:24 292:20,23 337:9 394:2 install 255:3 installation introduced 262:21 376:23 377:4 introduction 371:18 important 330:14 335:17 337:2 346:3 254:20,24 256:2 262:18 inventory 324:13 326:22 402:7 407:20 impression 268:20 274:3,4 279:10 367:22 387:20 393:7 433:4 305:18 334:23 individuals installations 257:19 284:20,23 290:11 257:21 293:16 312:19 314:24 installed 342:1,1,3,18,20 343:4 investigating 275:21 412:3 investigation 326:15 417:4,8 337:13 372:17 385:7 261:6 306:15,19 431:5 273:17 improve 290:8,12 314:12 399:25 435:18,23,24 induced instantly 328:17 invitation 420:10 inadequate 320:9 381:7 industries instituted 260:4 305:5 331:4 involuntary 430:5 inches 315:6 248:17 250:1 252:15 253:8 instructed 253:9 304:23 332:5 involve 277:6 292:9 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051597 [involved - lavey] involved jet kind knowledgeable 274:4 284:8,17,25 286:8 324:2,6 262:9,11 264:22 284:6 284:8 287:24 293:12,16 294:7 jim 290:13 291:20 297:25 known 298:9,10 302:21 314:11 252:14 299:24 311:11 317:1,20 387:10 394:23 409:8 315:17 338:2 362:23 jj 366:22 367:2 368:18 375:7 437:23 319:15 320:8 322:3 327:22 krummrich 329:23 331:10,16 332:6,18 374:23 376:2 430:8,19 375:19 376:3 379:5 381:4 jlanglais 337:14 339:7 340:4,22 431:10,12________________ 381:10,18406:13411:19 250:10 341:5 347:1 351:6 353:20 I 411:23 412:4,11 419:24,25 job 385:10 390:7,9 393:21 ll-P- 428:19 429:12 307:19 314:15 367:23 400:3 401:4 406:17,17 246:14 248:19 440:21 involvement 403:5,8 425:13 425:15 430:23 441:2 284:2,4 286:9 357:17 john kinds lab involves 287:24 374:24 johnson 260:13 270:2 282:25 303:23 306:21 316:10 303:17 304:2,4,4 label involving 383:23,24,25 330:6 406:8 435:8 342:22 363:10411:16428:16 joint knew labor iron 375:7 330:16 399:21 412:14 372:4 377:3 384:10,13,25 385:16 jordan 416:16417:11 385:23 393:12 426:24 245:24 252:6 424:16 438:4 know laboratory 303:10,13 427:2,3,4,6,7,9,12,16 439:15 442:22 254:25 255:5,19,25 256:16 lampblack ish jtaylor 257:7,14 258:16 260:21 360:10,10 321:11 363:12 364:14 249:18 261:7,24 265:17,20 267:24 lampblacks 431:5 issue judge 245:3 440:4 268:3 269:13 270:6,11 271:24 272:2,24 274:8 360:7 land 366:10 372:12 394:17 judgment 275:20 276:24 278:1,3,19 344:19 356:16 420:7 432:23 433:4 286:25 287:1 292:23 279:16 285:8 286:7,8,12,15 landfill issued 381:23 422:8,11,13 423:24 286:18 294:9,16 301:20 316:7 330:3 333:11 334:6,8 318:23 434:11 issues 424:8,15 425:16,18 julie 305:15 310:5,9 311:5 312:17 317:9 318:23 319:4 334:12 335:1,2,16,20,24 336:5,12,16,17,22 337:3,9 363:10 406:24 407:3 248:2 253:7 320:1,11 321:3,21,24 337:13,20 338:5,8,14,18,20 427:19428:11,15,19 july 322:16 326:17 327:8 338:21,24 339:10 342:3,7,9 430:14 434:2 302:11 305:2 312:10 330:18 331:3 333:6,9 334:5 343:6,10,19 351:14,20 items jumping 334:8,18 335:22 336:1,4,7 388:22 389:7,13,15,18 259:7,12 405:1 419:6 336:13 338:7,13,16 339:1 390:16,20 391:3,14,15 it'll june 344:9 347:18 348:13,15,23 404:13 405:2,21 406:21 342:21 369:11 289:3 320:17 323:22 350:11 351:12,21 353:2,5 420:3,5 j junior 354:22 355:15 356:1 langlais jack 307:21 402:19 357:14,25 358:15,17 250:3 252:14,14 376 5 jurat 360:16,19 364:10,10 368:2 large james 441:7 372:7 374:3 376:9,11 386:7 260:19,21 340:22 250:3 286:11 k 386:17,22,22 399:4,20 late january karen 401:2 409:20 412:8,12 305:6 310:10 439:18 442:25 248:9 253:5 413:14 415:7,14,17,22 lately japan keep 416:25 420:9 422:6 425:2 411:13 375:8 294:25 304:13 335:10 425:18 427:15,20 428:18 laughs jarred 342:24 350:25 425:7,13,17 429:22 401:6 249:11 252:23 keeps knowing laughter jay 425:18 38923 384:9 399:3 383:22,24,25 kelly knowledge lavey jerry 365:6 366:13 413:1 328:6 329:16 330:23 333:3 246:13251:2 252:12,12 252:5 375:25 410:25 kept 333:5 337:11 340:11 253:3,12 255:13 265:21 425:19 436:8 297:21 339:8 342:1,24 341:12 354:11 355:25 266:1 272:14 273:8,15 jesse 379:24 405:15,18 418:5 364:3 372:11 376:8 388:6 280:4,12,15,23 281:9 284:11 312:21 370:10,14 424:6 425:12 415:9,11,13427:11 433:7 282:17285:14288:19 370:18,20,23 371:5 421:20 key 434:8,17 293:9 295:7 301:24 310:18 246:15 440:22 441:3 319:19 322:24 323:6 325:7 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051598 [lavey - lynette] lavey (cont.) tended listed longstanding 328:21,24 329:6,15 343:20 305:18 274:20 285:21 301:17315:23 343:24 356:25 359:2,8 letter listening look 362:4 373:17 414:3 426:6 305:16 359:22 360:14,17 417:2 266:3 277:20 280:19 281:8 436:6 letters lists 281:10 323:4 324:11 357:4 law 359:10 312:19 387:17 394:4 399:12 418:10 249:3 252:19 362:23,25 level litigation 435:25 419:19 264:25 265:4,7 275:4 276:8 362:24 looked lawsuit 276:8,10,10 303:19 330:8 little 274:2 308:17 342:9 373:24 365:11 366:2 336:24,25 352:3 367:24 256:11 264:6,12 278:25 386:5,12 399:13 lawsuits 394:25 395:2 396:22 279:8 294:3 307:10 311:17 looking 398:21 411:16 419:22,24 401:18,25418:18433:2 314:25 318:8 359:9 390:7 269:15271:18274:10,11 lawyer levels 401:11 411:5412:17419:7 274:15 278:13 282:19 432:1 260:3 275:1,1 385:18 421:7 426:17 310:2,5 312:18 326:5 337:5 lawyers lever living 360:6,16 387:14,16 364:4 411:19,21 412:5,19 330:8 286:12 looks 417:13 license lie 320:17,17,18 426:12 layer 439:18 245:20 246:4 438:12 losing 278:16 lid 441:12 287:17 lead 340:23 lloyd loss 309:23 357:23 360:18 lie 346:4 302:17 306:23,24 318:4 373:23 374:3,15 386:12 346:12 394:7 398:2 413:25 414:1 liese Up 324:14 327:18,22,24 247:3 250:4,14 363:1 442:2 losses 427:15 345:18 loading 317:12,13,15,16,18,22,24 leadership life 253:20,23 254:3,4 308:11 317:24 318:6 324:2,6,11,20 293:14 414:21 309:5 325:2,18 326:10,21,24 leading lightfoot local 327:1,15 395:25 396:1 332:21,25 352:23 412:15,24 419:25 421:12 422:1,3 lot leak limestone located 342:10413:14417:5,5 392:3,5,7,13,15 393:23 299:13,18,20 310:17 311:3 261:21 267:14 286:2 431:15 394:8,8 348:10,11,16 349:1,23 290:11 298:21 309:2 313:3 lots leakage 350:3,5 354:10,15 355:22 313:15315:11 321:1,2 298:24 391:20 392:18 356:3,7 406:25 407:4 334:16,20 339:17 340:15 louis leaks 429:17 340:18 356:12,18 363:2 245:21 246:6 286:2 290:11 392:8 394:4 423:15 limit 374:23,24 380:21 395:9 292:21 304:5 313:3,5,16 lean 360:21 412:21 416:20 314:16321:2 359:11 262:7,9,10 limited location 370:25 374:25 384:3 learn 257:8 324:16 346:5 258:23 297:7 309:11 396:23 421:11 432:21 374:14 line 325:25 330:4,10 331:18 438:3,13 439:12 441:14 learned 267:9 297:12,14 299:1,3 334:10,13 339:14,25 340:6 442:16,24 410:9 414:5 372:3 382:20 417:16 341:6 355:23 394:20 low leave lined 407:14 421:18 299:16,17 319:8,10 342:4 428:25 429:6 348:24 locations lower leaving liner 279:3 413:5 336:25 368:9 403:16 336:10 locked lsppc.com lee lipa 332:8 247:20 248:1 253:8 250:24 logic lumber left liquid 322:3 330:5 253:15 307:5,6,8,9 326:15 261:12,12 277:24,25 lombardi lunch 331:1,4 336:20 345:23 283:20,24 295:25 296:13 250:14 359:6 362:1 370:9 414:6 432:20 306:22,24 337:19,25 long luncheon 432:21 338:22,22,25 342:7 352:25 248:10 277:25 280:18 362:9 legal 353:20 379:25 363:4 364:12 407:15 422:8 lye 250:23 252:5 liquids 432:8 318:17 leitman 338:4,7,14 longer lynette 247:13 252:17 303:5 404:15 411:1 434:9 247:2 252:21 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051599 [lynette.smith - migrating] lynette.smith manner material (cont.) meet 247:9 254:17 258:11 281:24 349:20 351:12,18,23 327:20 385:12,13 lynne 290:14,18 308:14 314:7 352:25 361:12 372:2 373:9 meeting 247:12 252:17 362:17 manu 382:20,23 383:4,7 384:24 357:22 358:1 399:25 406:9 m 286:3 385:10 387:25,25 389:12 meetings magistrate manufacture 389:16,25 390:1,14 391:7,9 406:7,10 245:3 440:4 375:9 430:12 434:23 391:11 392:7 396:1 406:16 melt maintain 401:25 maintained manufacturing 259:15 271:16 286:3,22 292:22 293:18,19 306:15 408:10,14 409:3,6 413:4 426:12 430:20 materials 382:23 member 286:3 307:21 403:7 397:8 398:5 401:16,17 maintenance 287:22 288:1,9 292:5,18 295:23 300:19 308:1 306:23 312:24 313:16 314:8 334:21 345:19 346:1 350:19 358:10 368:18,24 373:21 374:9,20 375:20 259:14 327:5 337:19 members 347:11 361:21 364:2 366:5 290:3 363:7 402:19 366:8,16 389:21 395:25 memo 396:2 397:1 413:10 286:14311:21 312:11,18 351:10 369:1 382:7,10 381:17 385:7 386:3,5 mats 312:20 313:24 326:5,11 391:16 393:6 394:3,13 397:15 406:20 387:13 390:1 391:22 399:17 400:5 401:14,23 398:4 matter 357:10 400:2 440:1 memorandum major 306:18 366:10 407:17 405:14 429:24 433:12 434:21 435:9 255:24 256:13 351:1 419:22 272:25 302:7,10 323:22 memory maker 417:22,25 makeup map 399:2 416:6,11,12,13,21 maps matters 406:8 411:20 maynard 264:7 317:7 321:18 374:5 mentioned 322:2 363:25 364:19 427:11 435:9 making 397:18,21,22 398:2,4,16 249:12 252:23 march mcclain 366:14 367:7 384:18 390:6 395:13413:17423:6 316:8 335:8 366:23 378:4 378:21 379:20,21 399:22 403:21 266:22 271:21 272:2 367:25 368:20 421:9,16 mark mcglaw.com 265:22 272:9 273:3 280:14 249:18 426:22 437:6 mentioning 354:24 malathion 285:1 282:12 marked mcmahon 250:14 mercury 357:24 396:4,7,9 malloy 376:5,10 man 253:18 265:24 266:2 272:12 273:6 280:21 282:15 285:12,16 288:17 mcwane met 244:6 245:10 249:10 252:8 321:2 363:7 410:25 252:24 440:9 metal 332:2 393:11 421:17 manage 288:21 295:5,8 301:22 mdhl.net 302:1 319:17,21 322:22,25 250:20 261:11 265:19300:18 342:21 360:25 392:10,11 331:13 managed 343:22 344:1 356:23 357:1 mead 359:4 373:18 386:12,15,18 246:12 252:13 metals 250:12 333:4,8 357:13,15 292:8 386:20 mean 358:6,8,20 413:23,24 management 292:16 302:21,22 386:25 405:14 415:7 market 434:5 marketing 262:4 269:20 277:12,14 284:19 290:19 293:20 305:9 315:25 325:20 method 254:4 319:9,14 methods manager 254:15 260:8 266:10 273:23 275:24 284:11 288:24 291:11,17 294:17 312:24 321:6 415:19 marking 256:24 marks 332:14 336:11 337:10 340:20 398:9 401:18 420:16 meaning 320:9 mi 248:12 michael 295:14 306:2,6,10 307:5 312:6 271:19 246:3 312:21 317:10 329:8 334:11 337:4 338:18 350:24 358:5 362:2 367:13 367:15,17 368:4,14 370:4,7 material 258:25 261:17 264:20 259:16,24 261:15 262:20 263:8 274:7 277:5,8 means 278:25 296:19 304:17 311:3 324:11 409:15 meant michael.wetmore 246:10 middle 288:12 400:11 370:11,23 371:7 375:7,12 278:15 279:20 280:1 291:4 255:10,11 278:19,21 291:1 midway 384:6,23 388:7 389:1,3,5 396:13,15 398:25 403:16 291:5 295:2 301:15 305:10 319:11 427:20 329:19 330:4 331:11,20 measure 408:17 migrate 404:23 410:10 418:14,14 421:13 432:12 332:1 333:18,23 335:14 300:14 319:9 399:21 336:5 337:15,23 338:23,25 measured 429:8,14 migrating managers 375:13 339:8,12,13,15 340:13 341:1 342:4 343:2 344:20 399:20 407:4 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051600 [mike - nods] mike 253:1 365:6 436:6 million 260:11,13 360:18 mind 260:10 294:17 327:23 358:7 366:20 367:11 372:20 411:7 438:16 mingle 306:22 minimum 406:10 minute 318:7 328:21 minutes 319:25 324:23 432:1 missouri 245:22 252:4 438:1,5,13 439:12,17 442:23 misspelled 270:8 mitsubishi 375:8,15 mixing 316:24 mixture 427:7 mixtures 427:8 mm 262:25 275:15 281:16 308:14 339:2 340:10 351:21 354:4,14 356:21 395:5 427:23 433:10 mo 246:6 441:14 442:16 modern 321:24 modest 341:25 modified 269:12,14 moisture 255:8,15,18 256:1 molten 277:8 344:20 moment 260:10 266:23 272:15 285:17 302:2 317:3 354:7 407:15 moments 357:3 monday 360:8 money 302:23 417:22,24 431:15 monitored movement need (cont.) 316:11 332:4 405:1,2,7 318:5 325:16 332:1 393:8 372:10,14 381:22,24 387:7 monitoring movements 393:9 399:1 404:8 408:14 326:9 298:1 339:20 411:24 416:2 420:6 426:5 mons moving 432:22 319:24,24 432:19 needed monsanto multi 258:10 259:16 302:23 268:18 284:21 312:25 265:1,5 303:20 324:17 394:5,18,18 313:17 314:8,15 319:3,23 muriatic needs 321:1 324:21 327:20 355:20 385:13 329:17,20 333:3,6,14 340:8 mute negative 341:7 344:12 353:2 358:19 367:5 254:16 359:19 360:8,25 362:24 myers negatives 363:11 364:4 366:7,15,18 249:2 251:5 252:19,19 296:10 366:20 374:19 375:1,7 432:3,6 435:25 436:3 neglect 384:23 409:22,25 412:19 n 324:1,13 415:15 416:7,12,24 421:25 n.w negotiate 428:20,25 429:6,24 430:7 430:10 433:3,8,22,24 434:3 2494 n.w. 393:11 neighborhood 435:2,8,17 24820 322:12 monsanto's name neighboring 270:12 398:10 430:2,11 252:4 267:1,4 272:20 334:3 434:3 montar 284:20 285:21 286:10 288:8 312:21 330:15 337:6 neighbors 427:25 341:18 342:8,15 383:10,19 352:17,19,23 357:8 362:17 neutralize 408:5 362:24 375:18 383:22 299:19 350:4 montars 427:4 432:6 440:19 new 341:14,14,15,22,24 342:2,6 342:13,19 343:5 383:9 named 370:14 253:20,23 254:3 256:14,20 257:3,6,15,24 258:6,8,19 408:3 names 258:23 259:1,8,11 261:5,18 month 257:19 367:1 401:7 421:24 261:19,22 262:18 264:24 296:9 364:20 365:1,2 435:22 265:3 271:19 274:2,23 385:14 394:13 406:11 narrowed 278:7 301:8 315:1 321:19 420:15 421:1 425:15 388:4 334:23 356:3,3 363:21 monthly naccif 370:10 371:18,24 399:9 288:23 289:3 295:10,13 365:6 366:13 413:1 403:22 412:12 431:1,22 296:4 nationsbank 432:13 months 305:6 377:5 398:19,23 425:8,23 247 4 442 3 natural 309:13,14 340:2 347:23 newer 430:20 431:2,12,17,18,19 newly moody 387:12,17 moody's 346:12 387:9 349:9 356:5 naturally 30922 nature 359:23 389:1 newport 314:3,4,11 375:1,16,20 news moore 303:16 312:7 336:21 366:2 321:19 344:24 363:1,5,15 364:13 365:6 morale 402:7 morning near 261:25 272:24 273:17 298:4 299:4 318:9,17 nearby night 288:12414:14 nine 425:23 253:13,14 388:5 397:3 380:22 nitro 400:19 403:2 move necessary 288:4 326:23 351:6 435:13 368:4 nodding 318:12325:15,19419:9,10 313:10 moved 258:5 313:5 351:20 432:13 432:20 270:2,24 287:7 290:4,8 300:16 304:24 315:18 316:12 341:23 350:5 nods 308:14 314:7 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051601 [non - operators] non objection officer once (cont.) 289:16,21 290:5,15 291:2,6 424:20 440:12 380:8 383:13 406:10 291:10,15,23 293:12 objections officers 411:11 425:15,15,22 294:11,18,20,23 295:3,24 439:1 433:3 o'neal 296:13 333:19 353:10,11 objective offices 247:12251:3 252:17,17 353:14 354:6,9 289:15 314:2 401:24 420:1 245:19 252:3 438:12 362:14,17 367:6 380:3 normal observable official 387:8410:12412:19 279:23 288:25 299:17 392:15 394:1,16 368:16 ones 381:25 392:20 400:13,16 observation officially 295:3 332:2 397:25 431:22 402:21 442:12 276:4 414:12 417:1 371:7 ongoing normally observations offsite 385:1 430:13 294:15 304:7 275:11 341:6 389:20,22 429:8 ooh north observed oh 269:8 284:23 292:16 247:14 248:4 249:13 279:23 246:17 250:16 255:2 322:17 328:16 334:17 363:3 observing 259:12 274:16 279:16 ooze northeast 279:1 294:4 297:14 299:25 393:24 247:5 442:4 obvious 313:10 314:22 317:25 oozing northern 394:9 338:12 349:7 350:9 359:2 392:14 245:2 252:9 438:10 440:3 occasion 369:18 375:18 378:20 op notarial 296:22 299:8,11 300:17 379:24,24 380:11 392:20 298:10 439:11 304:3 318:16,22 328:11 395:16 396:21 399:20 open notary 348:8 381:19,20 382:3 407:14 440:24 441:5 262:6 318:17 337:25 245:24 437:19 438:4 414:10 419:13 426:5 oil 339:21 341:3 342:22 442:23 occasionally 422:18 343:15 344:20 347:1 note 354:12 382:5 okay 382:20 397:10 273:10 occasions 253:23 256:22 266:9,18 opening noted 318:20 337:12 389:11 267:12 270:14 274:17 322:1 335:6 382:22 418:13 424:21 occupied 275:11,16 278:2 280:13 openings notes 262:1 283:3 284:17 285:2 288:14 338:1 418:10 occur 289:19 290:23 291:1 292:1 opera notice 291:7 303:14 305:22 350:8 293:24 297:12 298:8 305:2 298:10 358:16 393:24 438:8 394:9 311:5 316:19 323:16 324:9 operate nuisance occurred 333:3 335:22 343:3,20 257:16 375:1 377:24 300:12 279:22 286:24 291:16,19 346:17 352:21 355:22 operated number 296:14 306:16,23 314:23 359:7 360:6 362:5 364:7,12 414:24 252:10 253:18 266:5 267:9 333:25 335:8 336:13 364:25 365:15,21 369:24 operating 267:19 271:21 273:9 394:25 422:9 371:20 373:14 374:2 280:25 281:22 282:1,3,8,12 274:12,16,17,19 275:12 occurring 377:25 378:3 380:7 384:8 283:1 284:24 292:6,7 276:6 285:16 291:18 293:1 392:5 384:15,22 388:4,14 389:11 295:23 300:21 382:11 293:7 295:9 296:3 302:1 October 390:19 394:11,11 395:21 397:14 403:7 319:15,21,24 323:1 328:18 281:1,4,17 398:1 400:8,15 402:18 operation 328:24 329:4 344:1,18 odor 403:14,20 405:21 413:10 259:17261:22 264:14 347:22 357:2 360:10 362:6 427:19,19,20 428:1,12,16 423:1 424:15 268:6 271:25 279:9 281:4 362:11 373:18 381:8 odors old 287:1 292:10,17 294:22 410:16,21 411:16424:2 402:5 256:15 257:14,15,24 311:22 335:20 339:7,19 425:21 offer 258:15,24 259:2,20,22 350:13,14,15 416:19,24 numbers 430:21 340:1 373:14 388:15,16 operations 260:5,7,9,11,13 offered 389:24 391:8 393:17 262:14 271:11 278:7 286:4 o oath 420:19 oaths 4386 object 277:14 424:13 315:3 394:23 399:7,11 416:6 offering older 434:14 261:25 397:25 398:2 office olive 298:9 330:5 390:7 395:8,11 442:15 398:10 399:4,5,5,9,10,11 once 399:14,16 432:13 301:8 304:19 312:17 342:1 349:25 350:22 353:23 292:8 298:23 314:3,4 361:23 362:1 396:16 415:10 operator 311:16318:16381:23 403:8 428:4 operators 279:9,14 281:23 282:7 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051602 [operators - pcbs] operators (cont.) 288:3 401:8,8 opinion 275:18,21 315:3 opportunity 302:18,24 343:18 365:10 opposed 384:3 399:16 oral 290:2,22 order 257:24 300:24 327:6 341:25 342:24 347:8 ordered 303:25 orderly 407:16 orders 415:19 organic 313:17,19 368:19 435:18 435:19 organization 419:25 organizational 368:22 370:6 orient 416:8 oriented 334:17 orig 441:6 origin 322:8 original 373:7,7 431:20 440:20 originals 359:2 originating 333:13 orthopedics 332:10 osha 359:23 360:4 outside 285:2,8 297:12 304:2,4 388:12 389:24 390:4 407:23,25 422:1 435:3 outsider 390:2 421:19 overall 260:24 297:9,11 305:17 324:19 overflow 352:4,9 overload papageorge (cont.) particulate 310:13 273:10 280:13 282:19 255:24 overloading 283:9 289:8 293:2,8,10 parties 311:8 295:9 302:8 320:1 323:3,7 365:23 439:8,10 oversee 328:25 329:5,7,16 362:7,12 parts 418:22 419:2 362:15 366:1 367:7 368:12 315:18360:18392:17 overseeing 373:24 376:12 386:2,11 party 418:15 387:24 389:12 391:13 435:15 overshoes 393:14 395:24 397:18 passed 314:24 398:5,16 401:7 410:12,17 368:9 owe 410:22,25 424:23 429:21 path 269:1 432:4 436:10 437:1,10 383:15 owned 440:16 patience 340:7 433:22_____________ paragraph 432:7 257:1,7,10 267:12 269:15 pattern P p.c. 275:12,16 276:16 304:11 306:17 247:13 249:3,12 308:8 313:25 314:18 paul p.m. 245:22 362:8,11 410:18,21 315:20,22 324:1 326:7 parallel 320:19,20,24 pause 436:11,12 298:20 388:23 436:2 p2s5 paranitrophenol pave 371:24 372:1 254:12 package 263:23,25 parathion paved 285:1 345:15 346:6,7,18 254:15 332:24,25 339:24 packages parking pavement 262:22 298:24 399:14 308:22,25 309:6 310:3 packaging parkway 340:4 262:23 pad 248:11 parkwin pavements 309:3 316:25 254:12,14 pay page part 393:13 256:23,23 267:1,5 275:8,10 253:21 254:11,19,21 256:5 payne 275:13 278:12 281:20 257:15,15 259:8 269:12 247:13 252:18 289:5,8 295:17,18,19 308:8 279:9 284:24 285:3 291:11 pc 311:21 320:15,16 323:21 291:21 297:8 301:6 305:17 325:8 429:1 323:22 326:6 344:13 307:2 308:23 312:24 pcb 357:21 313:15316:1,3,13319:15 271:15301:15304:3 pages 324:15,19 327:21,24 347:6 306:18 317:12,13,15,16,24 323:17 344:5 438:23 361:7 369:3 372:12 389:7 318:13 324:20 329:19 441:15 442:6 395:16 417:12,14 418:3,6 331:20 338:25 349:21,22 paid 427:16 361:6,12 372:12 374:20 417:11 420:14421:3 partially 375:9,14 376:4 408:13 442:11,12 304:14 347:12 410:1,9 413:9 429:6,12,15 pail participants 430:12,13 431:10 432:23 377:8,9 327:19 433:4,9,12,15,19,22 434:2 pair participate 434:4,9,14,23 301:9 315:1 363:10 pcbs pallets particles 300:3,6 302:17 303:23 330:6 339:9 343:17,19 255:21 264:13 277:13,22 318:7,8 319:2,5,12 321:7 panels 278:25 322:1 324:17 325:4,9,13 402:12 particular 327:6,7,8 329:19 349:24 pans 266:21 277:1 280:16 350:2,18 357:18 361:9 305:25 281:23 282:3 288:22 363:10 364:3 366:23 375:4 papageorge 308:17 412:5 420:7 407:4 408:24 413:8,12 244:14 245:18 252:7 particularly 415:10 422:19 428:20,25 253:13 266:2 272:16,21 256:9 429:5,14,16,24 430:3,8,17 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051603 [pcbs - plant] pcbs (cont.) personally piece (cont.) place (cont.) 430:23 433:25 434:25 254:23 255:22 266:19 408:18,21 431:19 390:23 404:22 406:10,19 435:3 322:17 349:10 350:25 pieces 407:17 408:1 431:6,9 pcb's 409:13 256:8 261:9 318:14 placed 429:7 personnel pilat 299:14,18 316:5 317:5 peachtree 283:1 284:7 287:20 290:10 248:9,15 253:5,5 337:15,19,24 338:1,4,5,8 247:5 250:6 442:4 292:16 294:6 295:24 298:9 pile 338:14 391:2 pending 298:25 302:17,19 322:14 297:19 308:4 358:22 places 252:9 438:8 352:19,24 368:24 371:10 piled 271:7 306:3 415:8 Pennsylvania 371:17,21 372:6 382:12 351:23 placing 248:20 perspective piles 316:10405:1 pentasulfide 321:10 397:24 297:4,6,15,16,21 298:4,21 plain 371:25 pertains 397:7,14 340:1 393:17 people 257:10 pipe plaintiff 253:3 284:21 290:9 302:23 peruse 250:1 252:16 258:6 277:7 246:2 321:6 331:13 332:12,14 273:13 382:9 392:12 393:2,10,20 plaintiffs 335:24 353:2 372:14 peruses 393:22 407:17 408:12,17 245:6 253:2 440:7 375:15 381:25 408:21 266:6 272:17 281:5,11 408:18,22 416:11 plan 412:25 417:13 422:1,2,3 282:22 285:18 289:10 piped 286:14 289:15,20,22 290:5 427:6 302:4 320:3 323:5 344:7 379:11 380:4 290:24,25 291:12,21,24 perceive 357:5 pipefitter 292:1,3,3 293:10,13 294:7 336:23 petroleum 288:1 294:9,13 305:17 326:9 perceived 423:12 pipeline 333:21 430:24 271:8 300:13 312:7 316:7 phase 287:25 plant 320:8 367:23 381:24 283:14,20 pipelines 254:15 260:8 266:9 271:4 408:11 417:17 phased 256:14,15 383:6 271:11,11 273:22 275:24 perception 283:23 426:3 pipes 283:1,2 284:11,14,18,25 292:20 phaseout 379:14 381:18 382:2,17 285:4 288:24 289:17 290:6 perfectly 283:24 383:2 392:19,22 393:15,17 290:10291:8,11,16292:17 432:19 phasing 393:18 394:4,14 407:12,22 292:19 294:17 295:14 period 283:16,25 408:8,23 296:25 297:3,8,9,11 298:20 311:13 321:12 328:8 phelps piping 299:16 302:9,17,19,23,24 330:18 347:16 350:16 247:11 252:18 362:18 256:8,9 257:24,25 258:1,2 303:2 304:9,23 306:2,6,10 359:21,25 363:13,17 phenyls 258:9 276:8,10 356:16 307:5 309:16 312:21 316:7 364:21 372:13 391:5 357:24 379:5,6 392:16 316:21 317:10 319:3,24 411:21 419:14434:9 phone pit 321:11,25 322:2,5 324:21 periodic 253:3 367:4 428:7 299:20 310:17 311:4 326:7 329:7,17,20,23 330:2 394:2 phosphorus 342:15 348:10,11,16,20 330:4,11,19 331:10,22,23 periodically 371:25 349:5,6,12,23 350:5 351:13 333:4,14,16 334:4,10,11,14 307:17 350:6 400:21 phrase 351:19,24 352:2,3,11 334:16,19 337:1,4 338:18 periods 291:1 317:21 354:10,16 355:22 356:3,7 339:4,5 340:8,19 341:7,11 433:8 physical 406:25 407:1,5 341:19 344:23,25 345:1,11 periphery 257:1 318:5 327:5 336:11 pits 345:15 346:17,25 347:4,9 297:7 416:20 344:20 429:17,18 350:24 352:18,19,24 353:9 permitted physically place 353:12 355:1 356:19 343:16 269:20 256:19 259:15 262:14 357:13,14 358:5,11 362:1,2 perry physician 264:25 265:4 268:23,25 366:22 367:12,15,17 368:4 250:24 442:14 369:3 269:6 271:9 275:5 279:17 368:5,14,22 369:3 370:3,7 person pick 280:17 281:23 290:21 370:11,22,24 371:6,7,10 267:4 292:11,18,22 326:20 253:15 304:17 331:16 297:3,16 304:16,21 306:1 372:14,17,18 374:23,24 337:5,6 345:22 385:8,9,9 407:19 306:20,21 311:12 317:1 375:1,6,12,12 379:10 384:2 387:4 402:3 424:7 428:4,8 picturing 326:14,18 329:22,25 384:3,5,23 388:6,12,16,21 440:19 342:8 333:21 336:16 338:17 389:1,3,5,7,7,13,17 393:5 personal piece 342:17 344:22 345:11 395:6 396:13,15,16,22,25 314:22 415:11,13 258:5,6 261:8 265:8 277:1 370:3 373:8,14 374:9 398:8,9,25,25 399:1,22 281:24 325:14 399:8 386:13,14,15,20 387:19,21 403:15,16 404:23 405:19 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051604 [plant - products] plant (cont.) portions presence (cont.) process (cont.) 407:8,18 408:4 410:10 364:9 402:6 416:15 422:14 346:18,19 347:24,25 348:5 412:14415:18,21 417:17 poses 429:18 349:2,2 350:19 372:22,24 418:13,14,15421:13428:8 314:1 present 373:3,4,7,11,21,23 374:3,9 428:8 429:22 430:8,19,22 position 299:5 300:14,14 310:14 375:20 376:3 377:3,11 431:10,12,19,22 432:12,20 360:1 367:24 368:2 369:12 311:2 326:8 358:7,8 372:20 378:9,13,17,20,21,22 379:4 433:11,14,15,18 370:10 371:2 412:9 417:19 383:21 381:16 382:16 383:8 385:7 plants 432:25 433:7,10 434:2 pressure 385:25,25 386:3,8,10,10,12 268:18,21 304:8 314:8 positions 294:24 295:1,2 382:15,19 386:14,18,19,23 387:1,11 333:7 368:18 374:19,19 369:7 418:11 409:5 396:16,18,19 408:25 417:3 433:21 possible presumably 417:4,6,7,15 418:4 427:12 platform 339:1 346:24 357:22 358:1 275:21 processes 315:14,18 317:8 360:3 391:21,23,24 392:12 prevent 270:1 283:2 284:25 358:5 plats 394:4 308:19 358:10 364:4 381:17,19 397:18,21,22 398:2,5 possibly preventing 386:6 422:4 play 277:3 383:21 425:22 304:21 processing 363:19 pot previous 274:2 plaza 372:24,24 373:4,4,7,23 278:7 282:20 334:12 prod 245:20 246:5 247:4 249:14 378:24 383:13 386:10,12 previously 382:21 252:4 441:13 442:3 potential 259:19 275:3 290:21,22 produce please 260:12 324:14 360:25 304:23 310:5 315:21 260:13261:2 287:8,17 252:11 253:4 302:3 376:13 370:21 392:18 400:24 323:18 357:10 386:16 346:7 350:17,17 430:20 plenty pots primarily produced 428:18 373:11,14 376:20 377:10 298:7 301:6 302:15 362:19 350:16 373:9 375:14 plume 377:12 379:3 380:1 398:2 412:13 433:22 435:17 334:1 pounds primary producers plumes 260:11 385:14,14 402:1 434:25 333:13,16 pour principal producing point 311:18316:25 331:8 260:18 287:2 306:18 258:3,4,4,4,8 259:14 261:4 poured principle 339:12 345:12 371:24 261:13 262:21 272:4 274:7 309:3 340:3,4 269:2 374:20 377:11 406:13 301:8 302:16 303:4 310:6 powder prior 433:9,15,19 434:25 435:2 312:2 327:24 336:18 337:8 279:2 254:4 256:1 259:20 261:21 product 337:11,12 342:4 345:10,16 power 262:18 317:9 330:23 258:21 260:4 276:7,9,18,21 346:1 347:18 349:4,8 379:10 334:10 338:7 347:4 351:20 287:3,4,9,12,17 342:23 352:12 354:22 374:10 practice 367:15 370:22 408:8 359:14 360:1,8 361:4,7 381:5 384:1 391:7 395:22 301:17 315:23 330:22 privy 383:6,12,16 417:15,25 395:23 403:17 424:5 331:7 344:19,22 384:22 411:22 production 431:18 432:12 385:1 404:17,19,22 probably 257:17 259:24 260:3,6 points predated 341:13 402:18 283:11 293:18,19,21 307:7 305:18 386:6 397:23 problem 307:22,25 310:22 315:9,12 poke predecessor 258:6 276:6 287:11,18 339:11 341:1 343:9 344:13 409:3 367:17 315:25 316:2,8,14 357:22 344:15 345:5,5,6,20 346:10 pollution preparation 358:1 394:9 405:4 408:19 346:13,19 348:4 355:24 289:12 295:19 293:13 363:22 365:7,12 problems 358:5 366:23 371:16,21,24 polychlorinated prepare 267:16 315:24 337:14,17 372:1,22 376:3,14 379:4,12 283:25 264:20 400:24 427:19,21 380:20 382:4 385:8 386:25 polyphenyls prepared procedure 387:4,20 389:6 390:10 344:14 258:21 292:14 312:11 255:3 271:5 394:3,21 395:7 401:9 pond 320:12,13 323:23 341:24 procedures 403:11 405:12 407:23 347:1 344:6 396:22 414:24 408:21 418:22 419:2 429:1 poor preparing process 429:7,15,19 430:3 431:6 275:18 276:3 291:22 302:7 259:15 264:2,10,11,22 433:25 435:1 portion presence 265:5 276:14,19,22 277:4 products 256:4 399:15,18 255:18,20 271:6 319:5 277:12 283:4,5 287:16 263:4 283:15,17 346:6 349:23 366:4 382:23 383:3 307:1 318:18 331:14 343:9 348:9 350:16,17,17 359:19 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051605 [products - recall] products (cont.) psychiatrist pydraul range 361:1,6 367:1 371:16,18,20 347:9 367:3,8 295:11 323:1 357:2 372:3 374:20 375:4,9,14 psychologically pyranol rapid 376:4 408:13 415:16 314:19 282:12 385:25 417:16 423:12 433:9,12,15 public rare 433:19,22 434:5,9,14,23 245:24 246:16 347:14,19 qualified 291:18 426:2,5 435:8,9,17,20 357:23 437:19 438:4 370:20 438:6 rate profitable 417:20 program 440:23 441:4 442:23 pull 359:4 416:9 quality 287:3 quantities 421:5 raw 372:2 395:25 396:1,2 397:1 259:24 260:3 304:18 306:4 pulled 326:8,13,18,23 327:1,6,20 359:3 394:7,12 pump programmed 306:24 317:1 392:9 304:13 408:24 quantity 287:8 319:7,13 380:13 queeny reach 343:1 reached 330:7 391:7 286:24 pumped 366:22 370:24 371:2 reacting progress 344:20 379:25 266:10,14,21 304:24 305:3 pumps 374:24 433:14,15 question 350:3 reaction 312:12 project 379:6 purchased 255:16 275:20 278:1,14 281:1,8,15296:10315:19 381:7,7 reacts 253:16,21 254:12,21 256:6 296:25 384:19 257:20 261:1 266:12,16 purchasing 269:13 369:10,13,16 383:23 384:2 327:17 353:10 357:4 361:8 374:7 386:21 400:12 413:6 422:7,15 425:25 385:23 read 266:8 272:19 277:12 promise 432:8 385:11 393:11 pure questioning 432:8 285:20 302:6 320:7 323:13 323:21 327:17 365:16 promoted 367:22 368:3 promotion 424:2 purified 383:5 questions 266:4 269:22 280:16 292:2 344:10 359:5 362:14,18 436:8 437:2 reading 279:11 321:18 357:24 418:19 promulgated purports 373:21 373:20 378:5 410:24 411:4 419:8 420:4 432:3 435:5,17 reads 310:11 359:23 proper 361:5 purpose 255:5 269:20 302:14,15 306:4 316:5,20 364:5 436:4 438:25 439:3 quick 280:5 303:11 373:20 432:9 real 315:2 realistic properly 398:18 316:9,10 332:5 337:16,16 purposes quickly 298:2 401:5 319:13 realize 420:4,5 properties 299:23 318:2 340:10 pursuant quite 278:1 323:9 412:8 278:2 really 327:5,5 438:8 quote 284:5 285:25 290:12 property 340:7 pursue 433:4 286:14 304:17 309:15 318:5 327:2 352:22 376:20 387:5 391:6 proposed push 393:11 427:6 432:17 327:21 382:20 raakhee rear propounded put 248:18 253:9 337:1 439:1,4 253:21 254:3,25 258:20 raakhee.biswas reason protection 259:1 271:25 274:23 248:24 282:6,9 283:3,7 289:2 354:25 282:11 283:9 305:21 rags 296:8,12,16 358:7 368:9,13 protective 306:25 307:3 308:3 309:6 296:18 368:16 370:13 372:5,7 318:24 310:20 316:19 318:17 rails 374:7 398:19 425:4 430:15 provide 326:14,18 333:21 339:9 309:7 430:16 257:5 302:22 364:2 430:24 343:17 345:11 348:11,22 rain reasonable 435:13 355:5,12 399:24 403:6 309:11 352:8 260:22 330:7 424:24 425:2 provided putting rainwater reasonably 294:14 364:2 406:4 264:1 404:13 254:7 298:2 providing puzzling raised reasons 365:22 366:7,15 412:20,23 407:3 331:8 367:16431:12 provision pwg ran recall 376:24 244:4 245:8 440:8 265:15 253:20,23,25 256:13 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051606 [recall - report] recall (cont.) recognize refers remarks 257:12,19 258:9 259:6,9,12 266:21,23 314:1 320:2 286:14 316:13 334:8 439:1 260:2,11,14,16,18 261:3,10 344:11 344:13 357:12 remember 262:1 263:9 264:8,10,14,16 recognizing refilled 254:11,14,20,22,24 255:3 264:23 265:6 266:9,14,17 360:17 385:18 256:3,4 257:13 258:12,13 267:16 268:21 271:10 recollection reflect 259:3 260:5,6,14 262:25 273:16,19,21 275:19,23 259:4 267:13 272:22 274:1 283:5 266:19 267:7,15 269:8,9,10 276:1,2,4,9,13 278:3,6 276:20 291:14 322:11 refresh 269:23 271:14 272:1 279:7 279:8,25 284:14,23 285:6 350:9 357:9 360:9,21 371:1 267:13 274:1 286:23 288:10 290:7 294:6 285:24 288:8,21,22 289:1 380:13 381:14 regard 297:24 298:4 299:2 303:3,5 289:19 290:14 292:6 record 366:2 368:23 372:21 378:6 303:6 312:14,16 318:22 293:15 294:12 296:19 252:1,11 266:4 273:8 280:7 393:1 401:14 404:17,19 319:7 321:15,23 327:21 297:5,6,20 299:6 302:7,9 280:10 289:6 293:2,6 323:2 405:4,15 406:1,21,24 330:15 334:25 335:2 337:6 303:1 304:3 305:4 307:3 329:1,3,10,10,12,13 362:8 regarding 337:21 338:2 339:18 340:6 308:16 310:15 316:23 362:10410:14,18,20411:6 290:13 308:9 321:6 324:17 341:16 348:17 354:24 317:17 318:20 319:2,4,6 436:11 412:13 419:21 420:4 355:5,11,12 356:20 358:17 322:5 323:20 326:16 331:2 records 435:17 359:25 360:23 365:13 333:17 339:17 340:1,3,24 405:15,18 425:12 regardless 369:8 375:18 377:7,19 340:25 341:5 344:22 recover 365:1 380:18 392:1 398:18 347:14 348:11 351:23,25 307:1 regular 399:13 403:21 408:7 354:9 356:19 358:19 recoverable 337:8 406:7 423:12 413:16 422:17 425:3,4,7 359:21 360:8,12 361:15 337:23 regularly 432:14,16 433:5 435:22,24 365:8 373:23 375:19,23 rectangular 435:7 remembered 376:2,5 380:19,22 381:4,8 340:22 347:2 regulation 417:5 383:22 388:2,14,18 390:3,6 recycled 360:4 remembering 390:10 391:22 392:23,25 353:21 reintroduce 354:19 395:8,23 396:3,4 397:5 reduce 306:25 reminded 398:1,5,6,15,17 401:7 316:11 317:23 348:25 relate 320:7 403:5,17,18 406:2,24 407:2 reduced 287:7 359:10 removal 408:2 410:3,6,11 413:11,18 342:4 349:20 related 255:25 256:7 413:19,20 414:6 416:8,12 reduction 374:20 376:4 408:13 439:9 remove 416:13,14,23 419:12,23 350:19 relating 255:15 316:18 378:25 429:17 433:17 434:12 refer 360:24 372:11 removed recalled 257:14 276:17 279:13 relation 257:25 258:1 259:5 297:25 256:19 321:18 299:6 318:4 321:10 323:8 380:19 314:20 351:13,19,24 381:1 receive 334:4 relationship 381:3 403:17,18 408:22 295:14 346:18 355:22 reference 353:17 363:5,8,14,18 rephrase 364:25 420:17,18,23 274:5 313:24 352:25 364:15411:12 255:16281:15 received 353:16 355:11 356:20 relationships replace 309:19 420:10 427:25 428:22 363:6 335:9 368:19 370:19 377:1 435:7 referenced relayed replaced receiver 359:22 321:16 267:22 270:5 308:22,25 393:12 references release 310:2 367:17 392:19 receiving 398:1 291:3,5 295:1 349:20 393:15407:12408:8 421:9 266:10,14,17 272:22 referred released replacement 273:16 285:24 288:23 260:25 272:25 274:6 318:9 325:14408:11,14 370:14394:17407:17 312:20 341:25 420:20 276:24 293:10 313:17 428:20 replacing receptacle 316:16 317:12,15 327:16 relocated 394:5 340:25 330:2 334:5 352:20 354:12 274:23 replenish recess 389:8,14 relying 403:12 280:9 293:5 329:2 362:9 referring 314:25 replenished 410:19 257:8 267:25 277:2 290:16 remained 385:17 recipient 290:17,23 316:15 317:23 258:25 364:20,20 373:14 report 267:2 285:22 318:5 321:8 366:18,19 remark 266:22 273:17,20 289:3 recirculating 386:9,11 403:21 291:22 292:9,14 295:10,14 353:23,25 321:14,15 369:13,15 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051607 [reportable - sand] reportable respirators reward round 294:10 296:3 318:23 367:24 343:2 reported respond rid routine 291:11 296:14 421:23 359:18 360:2 361:9 409:7 393:10 403:22 288:25 289:16,21 290:5,15 438:22 435:13 right 291:2,6,10,15,23 293:12 reporter response 263:18,20 265:13 274:16 294:11,18,19,20,22,23 245:24 252:6 265:21 272:9 305:13,16 278:3 308:20 323:11,13 295:3,24 296:13 304:6 288:20 301:25 319:20 responsibilities 325:11 328:20 334:1 337:1 333:19 343:25 439:16 441:7 286:9 359:17 361:3 406:21 339:22 346:16 353:18 routinely reporting responsibility 356:16,17 359:2,3 374:4 295:14 250:24 289:16,20 290:5,14 286:5 300:20,21 308:1 384:13 387:15,18,22 389:9 rsmo 290:19 293:11 333:22 330:13 332:2,13 335:16,19 400:15,24 403:4 405:5,6 440:14 442:14 337:3 345:14 346:5,13 409:19411:15418:21 rule reports 351:9 387:1 391:13,14 423:13 429:13 435:10 440:14 266:10,15,17,20 288:23 405:9,13 406:23 418:22 ring rumblings 292:4,11 295:23 368:23 419:1 374:5 400:24 369:6 370:2 responsible rings run represent 257:20 291:22 345:22 379:1 254:8,8 265:13 281:23 253:2 362:17 366:20 411:2 346:9 351:3,4 385:2 387:2 risk 336:15 432:6 393:4 397:13 402:15 404:11 running representatives 435:19 road 257:25 292:18 293:17 366:6,14,17 rest 250:15 332:23,24,25 333:2 runoff represented 290:10 400:1 403:1 334:20,24,25 342:10 336:15 429:13 379:1 restricted 388:20 389:6 394:21 russia representing 331:23 roads 434:25 252:13,15,18,20,22,24 restrictive 298:12,14 388:21 394:22 russian request 430:18 414:13 434:24 254:12 361:8,23 result roadway rusty require 260:25 290:16 294:23 332:21 334:23 388:18 393:17 288:2 382:3 408:14,24 322:3 348:7 371:15 389:2 395:7 ryan required resulted robert 311:25 259:24,25 303:21 316:4 365:2 382:6,22 385:15 401:12 406:25 requiring 372:4 resale 337:23 research 304:7 321:4 385:6,8 387:6 resistant 270:15 271:1 423:9 reslawgrp.com 249:8 resolution 249:3 252:19 resolved 303:14 resources 302:22 respect 316:21 respective 402:16 respects 439:2 260:1 302:10 333:17 371:21 results 287:11 321:25 322:13 retained 390:16 retainer 364:12,18,25 411:9 retention 349:13 352:12 return 275:25 312:11 430:23 returned 403:15 reused 353:21 review 267:12 272:15 273:4 285:17 302:2 365:11,13 reviewed 254:23 273:25 276:12 357:7 370:21 reviewing 257:7 273:10 323:16,16 346:12 368:17 387:12 s rock 299:8,11,14,23 308:22,24 safe 402:1,2 309:7,8,12 310:2 340:2 rod safer 271:9 409:3 safety rods 382:21 role 293-17 294 1 25 370 1 385:9 406:7,8 salable 361:4 363:19 396:15 411:8 412:7 rolling 261:11 342:4 salvaged 30624 sample roof 305:20 328:1,2,8 392:4,7 253:24 254:2,4 262:5,12 room 257:3 258:13,15 263:13,17 268:11 277:18,19 278:24 samples 303:23,24 319:6 322:8 328 12 sampling 348:18 402:9 403:1 304:7 305:18 321:24 322:5 rooms 257:4,9 322:10,15 392:2,3 sanborn rotation 261:14 4166 s?tnd roughly 260:7,9 363:11,19 400:18 296:18 297:16,21 301:3,14 304:13,17 307:11 308:3,4 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051608 [sand - siegal] sand (cont.) scraping sent shaped 315:7,23 316:2,4,20,24 300:18 315:24 316:14 292:15,21 396:23 404:13 340:22 347:2 317:2,5,5,6,6 397:4,7,9,14 scroll sentence share 403:6,11 404:3 405:5,21 299:18 267:20 270:4 276:5 278:14 302:19 367:19 368:15 409:23 423:21,25 425:3,5,7 scrub 278:15,17 308:13,21,23 400:1 425:13 426:2,7,9,10,14,16 355:7,18 310:1,4,11 311:6 315:21,22 shave 426:17,20,23 scrubber 316:13 357:24 261:14 sandbox 355:5,8,8,11,17 separate shaw 314:25 scrubbers 268:7 293:22 345:7 386:5 250:23 252:5 sandboxes 355:12,16 separated shed 301:12,18 304:25 307:11 seal 303:12 390:7 307:16,20,25 314:19 315:4 318:19 439:11 442:19 separately sheet 316:22 403:3,6,14 sealed 323:9 394:10 sanders 316:6 404:5,9 405:12 September sheltered 246:14 247:3 252:13,22 sealing 244:12 245:23 252:2 261:25 262:3,4 440:21 441:2 442:2 404:8,17,19 295:11,13,24 296:9,14 shift sanitary sec 374:10 437:3 438:15 279:17400:11,18,19,22 347:13,19 440:14 439:12 440:17 442:19 ship sauget second series 393:9 314:3,4,12 374:24 375:23 267:5 276:8,10 278:14,15 360:2 377:24 shipment 375:25 376:3 430:9 433:18 304:10 311:21 313:24 serve 258:21 433:18 315:20,22 329:9 334:9 371:5 shipments savage 369:10 388:19 389:1 served 415:20,22 286:1,2,12 323:25 326:19 400:22 407:1 259:13 362:23 412:7 shipped saving secondary service 268:18407:13415:18 390:24 417:19 259:2 392:14 430:23 shipping saw section services 264:2 330:15 332:1 369:2 276:2 397:9 416:16 423:15 257:5 288:24 289:14 292:5 393:8 405:25 425:8 426:12,15 security 293:15,20,25 294:2 295:10 shm sawdust 338:17,19 331:9 365:2 369:1 398:7 249:8 296:22,24 297:4,15 409:23 seeing 430:22 shoes 425:25 426:3,3,5 254:24 276:9,20 278:4 serving 301:5,14 314:24 403:23 saying 279:7 297:20 351:4,23 383:23 short 425:18 431:16 357:9 398:15,19 425:3,7 set 293:4 419:14 says seek 311:18315:19323:12 shorthand 267:9 275:17 276:5,25 302:20 411:5 327:15,19 330:10 331:13 438:22 277:15,15 315:22 319:15 seen 335:8 339:6 391:5 438:24 show 324:10 344:3 360:18 279:12 289:3 292:3 320:6 442:18 277:24 309:8 322:1 416:19 321:13 357:11 365:15 setting showed scanned 397:21,22,25 398:17,18,20 390:24 397:18 273:14 323:15 398:23 405:17 settle showing scanning segments 350:1,18 311:24 282:24 258:1 settling shown scheduled selected 347:1 416:5 438:20 271:20 287:3 368:13 370:18 setup shut scientific selenium 352:1 380:2 416:3 287:18 392:6 247:1 252:22 357:24 seventies sic score sell 306:14 307:4 267:22 348:7 350:25 424:6 425:8 392:23 severe side scott semi 311:24 349:18 309:3,7 426:18 248:3 342:8 sewer sided scrap sending 347:14 356:11 429:8,11 262:12,15,23 263:2 392:24,25 393:1,12 407:8 316:8 sewers sides 407:13 408:9,12 sense 347:19 356:18,21 262:6 scraped 398:14 425:14,14 shakes siegal 316:17 254:16 247:13 252:17 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051609 [signature - squire] signature skydrols somebody specifications 267:9 325:5 437:4 439:5 367:10 394:13 402:11 426:14 384:15,24 385:3,4,10 signed slag somewhat specifics 267:4 363:9,15 409:25 410:3,9 276:12 352:14 268:3,21 303:4,5 321:23 significant slept soon 390:6 326:21 288:11 318:19 speed similar slips sophisticated 420:7 258:25 269:2 271:3 314:12 402:3 303:22 spend 316:25 321:21 364:8 sloped sorry 399:21 400:4,10 413:13 similarly 395:1 253:18 255:11 262:8 spending 421:24 slow 265:22 266:13 274:13 411:13 simply 385:25 290:1 299:10 309:18 spent 386:22 slowly 340:17 378:12 423:8 365:5 399:16417:13418:5 single 377:4 393:22 sort 431:15 265:7 386:10 435:15 sis 262:7 264:18 276:1 292:4 spigots sink 247:20 300:24 348:21 350:18 305:25 318:9 349:25 small 422:7 spill sir 263:8 279:8,13 310:13,25 sound 276:18 279:19 291:5,23 266:24 275:14 281:2 311:2 316:24 319:13 438:16 292:11 294:10 295:22 284:22 358:12 367:21 smaller sounds 298:3 305:10 307:14 369:19 372:9 374:22 262:2 395:9 314:12 397:8 376:19 377:18 396:20 smith source spillage 399:19 425:11 428:24 247:2 252:21,21 363:1,5,15 271:1 277:6 287:24 325:3 305:23 306:16 309:8 sit 364:13 365:6 411:8 366:11 379:6,7 spillages 357:25 smp sources 305:5 site 386:13 277:9 391:21,23,24 spilled 255:3 259:5 322:10 325:3 snow south 276:9,21 331:11 340:7,7,12 389:14 309:25,25 352:20,22,23,24 334:6,8,18 spilling 405:8 420:2 353:1 southern 279:21 sitting soden 249:1 252:20 432:7 spills 360:19 406:9 368:17 370:19,19 space 276:7 289:16,21 290:5,15 situation soil 257:6 259:25 262:2 390:7,7 291:10,15 293:11 295:25 279:8 287:15 290:10,13 299:9,12,24 390:15,16,19 393:19 432:13 296:13,17,19297:17299:9 291:19 294:24 301:11 390:20,24 391:1,9 416:11 speak 299:12 305:19,22 306:7 314:12 315:1 326:8 333:17 429:7 322:12 371:6 391:8 406:15 307:13 308:18 309:11 352:6 381:25 382:1 412:14 sold 427:6 316:21 333:22 397:4 410:1 situations 263:19,21 268:16 286:19 speaker 410:10415:3 287:10 422:6 341:15,18,23,24 408:8 406:13 spoke six solid speaking 333:20 305:6 334:1 378:4,5 408:17 255:21 257:6 260:10 298:17 299:20 335:23 spot sixth 262:20 263:13,16,20,23 340:9 381:9 269:8 279:19,21 297:5,24 249:13 264:3 268:11 277:13,20 special 407:19 sixties 278:23 283:21,22 342:8,10 303:25 spots 306:14 342:11 343:1,2 specific 279:8,13 size solidify 259:12 269:8 272:1 284:23 spread 258:7 349:16 377:6,7,8 261:12 289:1 294:6 297:9 303:1 307:12 380:10 402:9 430:22 solutia 318:22 319:4 321:13,15 springs sized 244:2 245:5 252:8 362:24 337:2,21 338:2 339:3 393:23 349:15 377:9 366:7,15,18,20 411:2 440:6 345:11 360:12 429:3 sprinkled sketch solution 435:24 279:2 274:11,12,12,14,16,17,19 287:13 specifically square sketchy solvent 253:19 266:25 269:17 246:16 440:23 441:4 412:25 382:16 271:10,13 290:7 297:20 squire sky solvents 413:3 246:14 252:12 440:21 333:13 300:23 301:1 specification 441:2 385:13 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051610 [ss - supervisor] ss starts stop 438:2 392:14 393:25 332:16 430:12 433:11,15 ssd.com state 433:19 246:20 245:21 263:21 304:11 stoppage St 314:18 323:25 343:1 382:19,25 245:21 246:6 286:2 290:11 411:17422:1 438:1,5,13 stoppages 292:21 304:5 313:3,5,16 439:17 442:23 383:1 314:16 321:2 359:11 stated stopped 370:25 374:25 384:3 381:21 336:4 429:24 433:8 396:23 421:11 432:21 statement storage 438:3,13 439:12 441:14 275:16296:10311:1 256:15 259:25 308:10 442:16,24 440:13 317:4 380:1,7,17,20 stacey states stored 249:2 252:19 432:6 245:1 252:15 257:2 267:20 258:21 259:11 342:20 stack 271:18277:11 278:15 343:11,12,14407:13 407:22 295:22 304:11 308:9,21 storm stacks 357:22 433:22 434:10,14 306:17 309:13,14,19 324:3,7 435:3 438:9 440:2 325:23 336:16 346:21,22 staff stating 346:24 347:23 349:9,14 402:19 435:12,16 344:19 356:11,14,18,20 429:13 stage stationed storms 378:16,17 338:19 349:18 staging status story 339:3,14,25 284:5 265:1 stain stay straight 307:15 312:9 408:17 277:24 383:4,8 404:15 342:3 343:5 stainless stayed strain 427:9 373:7 312:6 staircase staying strange 315:8 383:13 333:18 stairs stays stream 300:10 301:3,13,18 307:11 379:25 255:19,21 256:1 287:19 307:16 314:20 315:11 steam 348:5,7,9 349:17 403:3,15 267:21,24 268:1 269:16,24 streams stairwells 270:3,4,19,20 271:2 288:5 326:2 355:23 357:13,14 301:2 315:15,16 294:21 333:16 379:8,9,11 358:9,20 415:1 stamped 382:23 409:4 street 266:4 steel 247:5,14 250:6 254:12,14 standard 248:8 253:6 316:6 337:24 309:17 353:6,7 388:15 280:25 281:22 282:1,7 343:15 393:9 397:9 403:10 442:4,15 373:21 374:9 386:5 404:14 427:8,9,9 strike standards step 401:22 357:23 358:2 359:23 301:13 343:10 347:7 386:9 strive stands Stephens 311:22 289:14 293:23 247:12 strong stapled steps 299:17 323:8,12 300:10,15 310:6 311:5,9 struck start stickier 331:14 277:19 305:17 316:2 300:8 structure 322:17 326:20 382:22 stickiness 275:24 279:6 368:22 392:11 401:4 404:13 300:5 369:24 370:6 started sticky stuck 255:4 279:21 301:20 300:3,11 316:16 336:14,25 stood studied starting 290:1 333:6 359:9 studies 321:21 study 320:8 322:1,4 stuff 279:18 subject 352:14406:9,12 413:12 subjective 314:22 315:3 subscribed 437:12 subsequent 321:21 345:25 403:16 410:6 subsequently 410:9 substance 300:3 409:8 substances 383:18,19 successes 302:20 successor 346:15 sufficient 408:24 suggest 344:5 399:24 suggesting 308:24 418:3 suing 411:3 suit 412:18439:9 suitable 316:5 suite 245:21 246:5 247:4,15 248:11 249:4,14 250:15 441:13442:3,15 summary 344:3 sump 306:19,24 307:3 310:13,15 310:19,21,25 311:2,8 superintendent 288:8 292:17 337:7 345:19 345:25 346:13 368:25,25 369:1,2 387:12,17 391:17 393:6 405:9 406:15 418:17 superintendents 368:24 402:14 supervisor 287:16 292:10,12,20 339:7 350:12,20 387:5 402:11 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051611 [supervisor - therminal] supervisor (cont.) sworn tape (cont.) ten (cont.) 406:14 418:18 437:12 438:18 362:6,11 364:8 410:16,21 421:7 supervisors system tapes tenure 286:25 402:14 263:1 264:17,21,24 265:3 363:22 364:9 306:2,6 370:7 371:11 supervisor's 267:10,14,14,17,21,22,25 target 372:23 374:14 389:8,12 287:8 268:1,23,25 269:1,17,18,20 327:22 328:5,9 395:24 397:23 404:18,20 supplied 269:20,24 270:5,6,7,17 targeted 405:16407:9410:10 415:15 271:19,19,24 274:25 275:3 326:10 327:15,18,22 term supplier 275:5 276:7,13 279:20 tarry 303:2 334:6 342:16 344:14 385:12 280:1 294:25 346:25 342:25 426:10,11 supplies 347:14,19 350:2 353:24 task terminate 357:23 354:3,5 382:10 383:5,14 307:22 283:11 suoolv 392:16,18 429:9,11 tasked terminated 288:1 417:18 430:7 systems 361:10 435:1 support 270:2 354:25 355:1________ taxed terminating 325:4 t 441:1,11 442:1 430:16 suppose taken taylor termination 269:23 335:4 supposed 245:19 252:7 258:10,17 259:2,5 279:15 305:13,15 249:11 251:4 252:23,23 429:19 410:24,25 423:10 424:11 terms 270:11 348:25 383:8 sure 270:10 311:10 316:8 321:4 310:6 311:5,14 316:6 319:6 322:12 328:2 343:8 351:13 364:9 377:21 389:12,17 424:17,20 431:24 team 425:10,24 268:21 305:9 320:9 336:9 363:9 429:2 434:4 terphenyl 323:9,19 326:19 332:15 339:1,2 402:11 418:12 390:4,14 404:5 407:24 437:3 440:17 285:1 290:3 337:7 339:8 283:19 344:16 343:16 350:20 371:23 terphenyls 429:2 surface 277:19,22,25 279:1 339:24 talcum 279:2 talk 386:25 387:4,20 397:16 403:7 405:10 technical 263:6,7,10,12 284:1 test 333:4 surfaces 277:17 325:20 359:9 375:12 410:15 417:3 424:7 288:23 289:14 292:5 testified 293:15,20,25 294:1 295:10 360:7 362:22 365:4 371:9 surprised 388:19 surrounding talked 268:5 296:17 308:4 310:17 315:21 316:22 335:22 321:6 368:25 371:17 372:6 372:14 398:7 technology 374:2 380:25 384:10 385:16 386:2 387:11,24 403:2 404:3,25 419:6,10 311:20 334:2 suspect 341:2,13 347:22 372:15 375:15 383:9 384:12 321:24 telecopier 422:5 432:21 435:6 438:20 testify 381:9 suspicion 394:22 397:3 401:11 411:7 talking 250:19 telephone 424:16 438:18 testimony 327:4,4 253:16,19 254:18 300:1 246:7 248:22 250:18 298:16 369:21 374:13 suzanne 250:13 253:10 swear 310:16,19,19,21 328:11 341:16,19 359:22 376:15 395:14 413:2 427:6 431:3 telephoning 400:3 tell 391:3 414:7 415:23 420:21 422:16 429:23 437:5 438:21,24 414:2 sweep 279:10,14 sweeping talks 360:6 tan 287:14 426:14,18 274:10 278:21,22 280:18 testing 307:4 320:18 350:20 319:2 342:12 391:24 393:8 399:4 412:21 thank 417:2 424:23 426:20 428:8 253:19283:10313:12 401:4 402:24 tank tells 410:12 432:10 436:3,5 sweepings 279:14 sweeps 402:11 258:19 259:1 308:10,11 309:2311:17318:10,17 322:1 334:2 354:1 378:24 380:1,1,7,10,13,16,20 278:23 temperature 263:13,17 267:19 268:11 270:18 277:18,19 278:24 thanks 367:5 thefts 395:24 396:2,4 swept 392:13 410:1 383:11 thereabouts 401:16 404:4 swiping tanks 256:15 258:23,24 259:2,4 temporarily 343:12,14 344:10 363:8 thereto 402:23 switching 317:4 376:20 379:15 380:16 temptation 403:24 439:2 therminal 347:21 tape 293:1,1,7 328:24 329:4 ten 296:13,13 321:12 365:5 267:22 270:6,6 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051612 [therminol - twice] therminol time (cont.) tornado 270:8,12,17,22,22 271:3,9 303:4 310:7 311:13 312:2 318:12 271:12,19 314:9 319:8 321:2,8,10 total therminols 327:14 328:8 330:3,18,23 327:25 378:4 441:9,17 367:9 334:25 336:18 337:8 442:8 thin 338:13 343:16 344:11 totally 393:23 345:10,16 347:18 349:4,13 321:19 thing 350:16,23 352:12 354:22 touches 259:18 284:6 336:10 351:6 357:11,18 358:18 359:21 290:8 390:9 400:3 359:25 363:11,17 364:15 tower things 364:21,22 367:20 368:8 246:15 440:22 441:3 284:5 307:23,25 316:11 369:3 371:5 374:10 375:2,6 track 330:6 347:8 394:5 402:8,23 375:25 377:20 384:1 301:15 309:4,4 406:18 409:20 411:7 388:25 391:5 392:19,19 tracks 414:11 395:23 396:12 397:19 309:5 think 398:15,17 399:18401:12 tractors 281:7 284:15 294:13 312:1 401:13 404:22 406:11 423:6 313:9 317:3 321:3 323:21 411:12,22 413:14417:12 train 325:1 337:3,4,4 338:3 417:13 418:5 422:5 425:8 387:3 419:9 354:5 359:5 368:4 372:23 427:24 428:16 429:19,21 training 380:25 383:20 384:11,18 429:23,23 430:15 432:16 406:1,4 387:11 388:4 391:25 392:1 433:8,16 434:8 transaction 395:4 403:19 414:1,3 423:4 times 393:5 423:5 426:6,9 431:25 433:2 283:15 312:14 331:12 transcribed 434:11 436:7 347:22 382:21,22 383:3 438:22 thinking 400:10 transcript 402:8 timing 437:2,5 438:21 439:3 third 287:4 440:20 248:4 276:19,21 title transcripts thomas 335:18 359:14 442:10 323:17,18,20 titled transfer thought 280:24 357:12 270:15 271:4,9,12,14 288:11 325:4 395:11 419:9 today 331:24 thousand 252:6 264:17 288:7 317:15 transferred 364:19,23 420:15,24 334:5 357:25 360:10,21 270:25 339:5 397:7,9 three 366:3 414:21 transplant 262:5,12,15,23 263:2 275:1 today's 421:10 275:6 288:7 290:9 315:6,6 252:2 transplants 315:17 360:9 362:20 told 421:25 377:19,23,25 378:2,4 278:22 320:13 368:16 transported 411:15419:11,14,16,17 384:7 405:19 430:1 431:14 tolerate transporting throw 271:8 397:13 340:23 tons trash thrown 393:9 330:5 340:19,23 341:10 311:11,11,15 tool treat tidying 249:1 252:20 432:7 347:12 307:22 tools treatment tied 288:2 345:1,11,15,23 346:17,23 347:13,19 top 346:25 347:4,5,6,7,9 tier 278:12 289:13 332:21 trial 344:3 335:9 337:25 342:22 344:2 438:11 time 358:16 387:19 397:10 tribiphenyls 252:10 254:15 260:7 262:1 topography 348:6 270:24 272:4 280:17 356:4 tried 284:11 288:15 291:7,7 361:9 400:4 trip 343:13 403:19 trips 337:18 420:13,23 trouble 326:24,25 342:8 troutman 247:3 252:21 442:2 troutmansanders.com 247:9 truck 297:1 308:11 423:22 truckload 423:25 425:5 truckloads 425:7,13 trucks 332:3,18 351:16 425:3 426:1 true 317:9 374:17 387:14 389:4 396:12 414:8,25 415:2 417:10 423:17 437:4 439:2 truly 260:15 truth 438:18,19,19 try 296:11 399:21 411:3 418:10 trying 255:15271:6 274:14292:3 300:25 301:1 316:11 337:21 338:2 347:8 395:8 409:19419:9 425:14 tsd 289:13 tuned 292:24 turn 256:22 349:1 350:3 turning 288:4,4 304:10 turnings 384:11,16,18,25 385:17,21 turns 395:3 tutor 412:13 tv 363:22 twenty 421:7 twice 351:1 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051613 [type - walkers] type union usually 258:10 259:17 266:17 428:10 287:1 307:21 277:17 279:7 283:24 unit utilized 295:13 296:7 303:18 312:4 256:14 261:10 270:18 282:2 334:10____________ 318:4 321:11 339:11 271:15 282:3 292:6,7 v 340:25 342:22 350:11 300:22 307:22 339:11 vague 364:6,8 382:16 383:7,19,21 371:24417:18431:10 276:1 393:5 402:3,24 405:22 406:18 423:9 426:15 types united 245:1 249:10 252:15,24 433:21 434:10,13 435:3 valley 248:8 253:6 value 364:7 387:25 typewriting 438:23 typical 438:9 440:2 units 254:18,21 256:2,19,20 274:6 282:5 401:9 431:21 402:6 valve 305:20 valves 282:25 283:2 296:3,5 unit's 392:6 typing 406:14 367:4____________________ unnecessary vantage 302:16 u u.s. 402:4 untrue vapor 255:8,14,25 277:7,9,23,23 250:1 ultimately 309:23,24 296:9 unusual 295:25 296:13 333:22 318:8 vapors 276:18,25 277:3,11,18 um 328:13 425:4 unwantingly 318:13,25 328:14 varied unannounced 401:3 unclean 383:5 unwelcome 301:11 287:4 339:10 407:16 varies 300:5 287:15 uncommon updated 431:17 various 318:14 360:25 387:25 354:8 undercover 254:5 339:21 upgraded 406:25 uphill vary 339:13 382:18,24 vault underestimate 402:6 334:18 upper 308:10 vehicle undergone 339:12 395:2,16 ups 298:1 velocity underneath 362:19 325:17 306:18 understand 263:25 320:10 341:14 usage 354:8 usages vent 325:14 ventilator 391:12421:14423:13 424:20 425:12 426:11 understanding 326:25 354:21 358:4,9 408:2 use 255:22 259:23 262:10 296:18,18 300:1 301:7 318:21 venting 294:21 vents 366:1,4,12 367:16,19 368:6 303:2 316:23,24,24 317:1,3 324:3,6 368:8,12 370:13,15 380:12 384:14,21 386:7 409:14,16 409:18 412:18,22 413:11 413:15,16 426:13,19,21 332:17 335:13 340:21 361:5,11 373:15 374:15 376:21,25 382:15,15 397:4 403:24 405:5 409:3,4,12,22 venture 375:8 verbally 321:17 430:2,11 409:24 423:8 430:8,17 versions understood 289:23 useful 307:1 303:25 versus undesirable 271:7 user 259:16 386:14 vessels undetermined 438:9 uses 268:22 376:21,23 431:21 vibrating 392:9 video 363:22 videographer 250:22,23 252:1,5 280:7,10 292:25 293:6 329:3,9,13 362:6,10 410:16,20 436:9 videos 363:25 videotaped 244:14 245:18 440:16 viewpoint 420:1 vintage 344:6 Virginia 368:5 virtually 303:25 visible 311:23312:3 337:17 visit 255:2 275:25 302:9,11,14 312:10 visited 419:10 visits 400:14403:16410:7 visual 334:25 visualize 264:16 vividly 269:10 volume 244:15 245:18 425:15 440:16 voluntary 430:4,6 vs 244:4 245:8 252:8 440:8 w waiting 391:10 waived 358:4 439:5 wales 375:2,17,20 walk 332:14 walked 394:13 walkers 332:16 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051614 [wall - year] wall watch wetmore (cont.) wondering 335:3,5 348:21 392:14 384:5 367:4 379:23 386:24 431:16432:11 393:22,22 water 410:14 423:7 424:10,13,19 Worcester waiter 254:8 267:21,24 268:1 424:23 425:17 431:25 360:13 250:1 252:15 269:17,24 270:3,5,21 271:1 436:5,7 word want 287:13 288:5 299:17 we've 262:10 263:20 270:11 253:15 267:8 275:12 306:17,22 309:14,14,19 278:12 280:4,24 285:15 276:3 340:21 376:21,25 278:13 280:19 281:2 317:2 325:24 326:3 328:2 288:20 316:22 319:20 378:11 421:10 427:4,20 291:25 344:12 362:18 336:16,20,23 345:1,11,15 330:1 340:9 341:19 344:1 wording 404:11 407:18 411:9 345:23 346:17,18,21,22,24 350:20 383:9 294:12 413:14417:1 347:13,23,24,25 348:5,25 whereof words wanted 349:2,10,14,25 352:2,3 442:18 262:22 267:25 336:8 258:4 264:19 268:12 306:3 353:10,11,15,19,20 354:3,4 whew 337:14 409:19 310:20 327:13 335:7 354:6,10,15,18,19,23,25 260:5 401:10 wore 400:25 418:12 430:22 355:3,3,15,16,18,19,23 whim 301:6 warehouse 356:15 357:23 382:15 352:14 work 259:8,11,20,22 260:1 393:21 409:4 429:13 white 259:8 288:2,15 298:10 261:19 264:25 265:4 274:2 waters 426:17 314:24 372:17 385:12 274:23 277:4 278:8 356:2,3 353:8 356:1 widespread 403:23 412:2,3,5 356:5 390:9 405:24 406:4 ways 279:11 workers 406:15 301:4 303:24 wiery 301:13318:20 408:18 warehoused wear 250:13,20 253:10 working 259:13 318:21 403:23 wild 303:16 392:9 400:13,16 warehousing weary 424:25 402:1,2 330:14 332:1,12 335:18,19 253:10 william world 337:7 339:8 342:23 343:16 weather 244:14 245:18 252:7 293:2 413:6 369:2 391:17 393:8 397:16 352:14 293:8 328:25 329:5 362:7 worthwhile 397:17 405:10 webb 362:12 410:17,22 436:10 343:13 warner 358:14 437:1,10 440:16 wrenches 248:20 week willing 287:25 warranted 420:21 385:12 393:12 wright 291:19 weeks wind 322:18,19,20 washed 406:11 325:17 write 300:16 325:23 401:15 wells window 278:2 385:7 413:20 washes 354:24 399:9,10,11,12 writing 402:12 wendlene windows 400:2 washing 246:13 399:6 402:24 432:13 written 325:24 402:23 wendy Wisconsin 289:20,22 290:23,25 Washington 252:12 249:4 291:22 292:3,14 294:9 248:21 249:5 went wise 384:15,24 385:3 435:7 waste 269:3 308:18 314:18 386:9 395:6 wrong 329:19,22 330:5 331:10,15 336:21 342:6,9 348:9 wish 279:19 331:16,20,24 332:6 337:15 414:17,18418:10431:9 337:6 413:19 wrote 337:19 339:15 340:12,13 west withdrawing 312:18361:12 341:1,8 344:3,18 345:1,10 250:6 257:4 334:17 368:4 345:14,23 346:17,18 westinghouse 347:12,13,24,25 348:5,7 361:19 355:23 357:13,14,17 358:9 westvaco 358:20 369:2 389:16 246:12 252:13 390:23,25 391:6,14,15,18 wet 405:25 406:2,5,14 415:1 371:6 wastebasket wetmore 377:8 246:3 253:1,1 255:11 434:4 y withstand 264:1 witness 266:6 272:17 273:12 281:5 yard 315:5,5 407:8,13 yeah 262:10 274:12 275:3 281:11 282:22 285:18 312:13 322:20 332:16 289:10 302:4 320:3 323:5 344:7 357:5 401:6 437:1 351:17 356:4 405:3 419:17 429:4 438:14,16,25 439:4,11 wastes 332:4 338:22 277:14 280:6 281:7 293:4 442:18 320:15 324:22,25 328:19 wlavey 328:23 358:25 359:7 362:5 246:20 305:7 321:12 350:22 351:1 385:14 387:14 422:10 425:16 432:14,16 433:12 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051615 [year - zero] year (cont.) 433:14 years 363:20 392:13 411:16 415:24 417:10 418:2 419:11,14,16 422:10,11 423:14 430:1 431:14 yesterday 253:16,18 254:19 256:18 259:7 296:17,20 308:5 390:13 z zero 319:14 322:13 Papageorge, William; McWane (3) (Former Monsanto Employee) WATER PCB-SD0000051616