Document dQY3zVnJe0j74LxwYekLj65qR

1 Wm. Papageorge - Glenn Brown Trial Testimony 10/31/91 A.M. THE COURT: All right, Mr. Carney. You may continue, sir. Q. (By Mr. Carney) Mr. Pap pageorge, a couple days ago -- I'm losing track of days, but I think it's a couple days ago -- Mr. Kotoske asked you questions about the testing that Monsanto did, and I think you brought out that Monsanto did some tests in the '30s called the Drinker studies, correct? A. I remember that, yes. Q. 1971? And then he mentioned the IBT studies in A. Yes, I remember that. Q. p Did Monsanto do other toxicity studies, and I'm talking about animal toxicity studies, other than those two? A. For PCBs? Q. Yes. A. Oh, yes. Q. I'd like to hand you a book, and which was supplied to Mr. Kotoske yesterday. And, Judge, you have one on your desk. THE COURT: Thank you. Q- (By Mr. Carney) And, first of all, I'd like p to read into the record the deposition exhibits that are contained in this book. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3 WATER PCB-SD0000015643 2 1 THE COURT: Just a minute, Tom. What 2 (inaudible)? 3 MR. CARNEY: I think it's called "Toxicity 4 Testing, 1938 to 1966." 5 THE COURT: Got it. 6 Q. (By Mr. Carney)Just for the record, 7 these -- the exhibits, defendant's exhibits in this book 8 are Defendant's Exhibit 192, 19]p 3, 196, 197, 198, 199, 9 Exhibits 200 through 209. That's nine exhibits. Exhibit 10 211, and Exhibits 216 through 220, that's four exhibits. 11 And a few days ago did I ask you, Mr. Papageorge, to 12 review the documents in that book? 13 A. Yes. 14 Q. And could you generally describe what's in 15 those documents? 16 A. These documents describe studies of PCBs with 17 test animals and reports the results of thosjo e tests. 18 Q. There are several groupings, and I'd like to 19 just go through the groupings. The first documents in 20 that book are two studies by Dr. Drinker dated September 21 15, 1938, and that's Exhibit 192 and 193? 22 A. They are. 23 Q. And Dr. Drinker was from Harvard University? 24 A. Yes, sir. 25 Q. And he did some studies, animal studies of Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015644 3 PCBs at that time]p ? A Yes . Q And were those studies published in journals? A Yes. Q And were copies of those studies furnished to the United States government? A Yes. Q And then the next group of studies are Defendant's Exhibit 196 and 197. Are those studies by a company called Scientific Asociates? A They are. Q Oh, by the wayjo , the Drinker studies, did Monsanto have anything to do with those Drinker studies? Did they authorize them to be done? A No. The only role Monsanto played was supply samples. Q Okay. Now, what about the Scientific Associates studies? That's Defendant's Exhibit 196 and 197 . A Yes. Those were authorized or sponsored by Monsanto Q And the one Scientific Associajo tes study, Defendant's Exhibit 196, is dated November 1953? A It is. Q And the other study is dated February 1955? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3 WATER PCB-SD0000015645 4 1 A. Yes. 2 Q. And these were animal studies done on PCBs? 3 A. Yes. 4 Q. And then go to Exhibits 198 and 199. Are 5 those studies that Monsanto sponsored and asked that 6 Dr. Treon do? 7 A. Yes. 8 Q]p . And those studies are titled "The Toxicity of 9 a Vapor of Aroclors 1242 and 1254." 10 A. Yes. 11 Q. And both of those studies are dated different 12 dates in June of 1955? 13 A. Yes. 14 Q. And these were animal studies done on PCBs 15 1242 and 1254? 16 A. Yes. 17 Q. And do these reports by Treon mention among 18 other effects, liver effects from the animals? 19 ]p A. Yes. 20 Q. And I thinkyou've already indicated that 21 those Treon studies were sent to Westinghouse? 22 A. Yes. 23 Q. And they were also sent to the U.S. 24 government? 25 A. Yes. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015646 5 1 Q. Now, let's look at the next group of 2 exhibits, Exhibits 200 through 209, 211 and Exhibits 216 3 through 220. Are these all animal studies that Monsanto p4 had done by the Younger Laboratories? 5 A,. They are. 6 Q.. And I'd like you to just give -- or maybe I 7 can just give the dates and you can follow along.. I'll 8 just go through each report and give the dates. These 9 were all animal studies, weren't they? 10 A,. They were. 11 Q.. Using PCBs? 12 A,. Yes. 13 Q.. And the first one is dated February 22, 195 14 A,. Yes. 15 Q. The next one is October 22, 1958? 16 A,. Exhibit 201, sir? 17 Q.. Well, let me check. I may have the wrong 18 document,. Okay. Yeah. Exhibit 201, is that -- 19 A,. It's October 20th. 20 Q.. October 20th. I'm sorry. 21 A,. Yes. 22 Q.. And then Exhibit 202 is December 8, 1958? 23 A,. Yes. I see the date, yes. 24 Q.. And then Exhibit 203 is June 6, 1962? 25 A,. Yes. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015647 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 p 22 23 24 25 6 Q. And here, just for example, they are not all rat studies, are they? A. No, different animals. Rats, rabbits. Q. There is a skin absorption on rabbits included in Exhibit 203, for example? A. Yes. Q. And then Exhibit 204 is dated June 13, 1962? A. It is. Q. And they were fed PCBs -- PCBs were fedjo to rats? A. Yes. Q. And some of the studies on that exhibit were skin absorpt ion studies on rabbits? A. Yes. Q. And then Exhibit 205 is dated June 19, 1962? A. It is. Q. Exhibit 206 is dated June 25, 1962? A. Yes. Q. And Exhibit 207 is dated June 25, 1962? A. Yes. Q. A. Q. 208, the same date? Yes. 209 is July 9, 1962? A. Yes. Q. Exhibit 211 is dated March 4, 1963? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3] WATER PCB-SD0000015648 7 A. It is. Q. And this study I noticed just has feeding of rat (inaudible) feeding rats? A. Yes, sir. Q. Then it has skin absorption for rabbits? A. Yes. Q. Skin irritation with rabbits? p A. Yes. Q. Eye irritation with rabbits? A. Yes. Q. And vapor inhilation with rabbits? A. Yes. Q. And then what about 216? Is that dated December 19, 1963? A. It is. Q. Then Exhibit 217 is dated June 12th -- January 12, 1966? A. It is. Q. Exhibit 218 is the Younger Laboratory test report datedjp October 17, 1966? A. Yes. Q. And some of these studies I noticed they tested both sexes of the various types of animals? A. Yes. Q. Exhibit 219 is dated November 9, 1966? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3 WATER PCB-SD0000015649 8 1 A. It is. 2 Q. And so is theExhibit 220? 3 A. Yes. 4 MR. CARNEY: Your Honor, I'd like to offer 5 into evidence these test reports that Mons]p anto had done or 6 were done. 7 MR. KOTOSKE: I have no problem if the 8 witness can identify for me the PCBs that were tested in 9 Exhibit 200, 201 and 202. 10 THE COURT: All right. You want to cover 11 that, Mr. Carney? 12 Q. (By Mr. Carney)Yeah. I think -- Why don't 13 we take 201. Let me ask you this, just so we can cover 14 these generally. Were these animal tests done on various 15 ty]p pes of PCBs? 16 A. They were. 17 Q. And 201, I believe is -- Can you - 18 THE COURT: Let me ask you a question -19 Q. (By Mr. Carney) Let me ask you this - 20 THE COURT: Were you moving for 192 through 21 202 or just the one you're referring to of the Younger 22 Labs? In other words, are you moving - 23 MR. CARNEY: I'm moving -- I think the 24 Drinker studies may ha]p ve already been in. 25 MR. KOTOSKE: That is right. Exhibit 11, I Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015650 9 1 have no objection to that. 2 THE COURT: So it's the late ones that we 3 need to look through. 4 MR. CARNEY: All the other exhibits I 5 mentioned I'm offering that are in this book that I've 6 read into the record. And I believe, Judge, since 7 Dr. Kelly's deposition is going to be played, he p8 identifies all these studies as PCB studies. And he was 9 the one that actually asked for the studies to be done. 10 So I think he covers this point. Maybe we can wait until 11 then. 12 THE COURT: I'll withhold my ruling, if 13 that's the way you two want to do it. 14 MR. CARNEY: That's fine. He identifies them 15 very clearly. He's more familiar with the tests since he 16 was the one that led the (inaudible). p17 THE COURT: Counsel, give me those numbers 18 again that you mentioned. 19 MR. KOTOSKE: Again, Your Honor, there is no 20 product described in 200, 201 and 202. To speed things 21 along, all the rest of these exhibits can go in evidence, 22 but I want you to reserve your ruling on those three until 23 we find out if it was a PCB product, and if it was, which 24 one . 25 THE COURT: For the record, 192, 193, 196, Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015651 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 1) 18 19 20 21 22 23 24 25 10 197, 198, 199, skipping to 203 through 209, 211, 216 and 220 are admitted into evidence. No ruling on 200, 201 and 202 until they are connected up. MR. CARNEY: I'll have that done (inaudible) with Dr. Kelly. Q. (By Mr. Carney) You can put that book aside now, Mr. Papageorge. I want to -- You were also examined by Mr. Kotoske about a document in Plaintiff's Exhibit 11 at page^) s 80 through 82, and in particular, this is a - page 81 is where the focus of the question was. And do we have copies for Mr. Papageorge? I'll give you a copy so you can take a look at that exhibit. THE COURT: Have we left this volume now? MR. CARNEY: Yes. We're finished with that volume. Q. (By Mr. Carney) Do you remember the questions about that bottom paragraph? What I'd like to do just for the record, for the jury, Mr. Kotoske read a couple of sentences out of this paragraph, and I'd like to read what he didn't have you read. THE COURT: Where is this from? MR. CARNEY: This is page 81 of Plaintiff's Exhibit 11. THE COURT: Okay. MR. KOTOSKE: This is the letter by Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015652 11 1 Dr. Wheeler. p2 THE COURT: Thank you. 3 MR. KOTOSKE: It's dated March 3, 1969. 4 MR. CARNEY: That's correct. 5 MR. KOTOSKE: That I recall. 6 MR. CARNEY: Your recollection is accurate. 7 Q. (By Mr. Carney) Mr. Kotoske read this 8 sentence -- or I don't know if he read it or had you read 9 it. I can't remember -- "The Swedish and American 10 scientists also imply that polychlorinated biphenyls are 11 ']p highly toxic' chemicals. This is simply not true." Now, 12 that was read, but what wasn't read was the next sentence, 13 the next couple. "The toxicity of any material, whether 14 it be chemicals, drugs, natural plants or even foods, is 15 relative. Compared to the thousands of industrial 16 chemicals and home products, PCBs are not toxic unless 17 they are mishandled or misused." That was not read, was 18 it? 19 20 p A. That is true. Q. And then Mr. Kotoske did read the next - 21 part of the next sentence. "During more than thirty years 22 of U.S. production and use, cases of any toxic effect have 23 been extremely rare." He read that, but didn't read the 24 rest, "And then only where the simple precautions 25 recommended for use were not followed." Did I read now Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015653 12 1 the entire paragraph? 2 A. You did. 3 Q. Now, I'd l]p ike to look at the group Exhibit - 4 and I think this is where we kind of broke off yesterday. 5 This is group exhibit, letters to the government, the 6 scientists. 7 MR. CARNEY: Your Honor, I think you have a 8 copy. 9 MR. KOTOSKE: Does this start with Exhibit 10 16? 11 MR. CARNEY: It starts with Exhibit 16, and I 12 think I read the exhibits into the record. p13 THE COURT: You did. 14 MR. CARNEY: I'm pretty sure I did. So I 15 won't have to read those again because there are a lot of 16 them. 17 THE COURT: I think it's 16 through 115. 18 MR. CARNEY: Yeah, not all the exhibits, but 19 they do run 16 through 115. 20 Q. (By Mr. Carney) And I think you've already 21 indicated you have reviewed those letters. Are these 22 representative examples of letters that y]p ou or someone 23 else at Monsanto sent providing information and PCB 24 samples to the United States government and to researchers 25 at universities who were studying the PCB environmental Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015654 13 1 issue? 2 A. They are. 3 Q. And these letters are organized by page? I 4 think the first letter is February 15, 1968? 5 A. It is. 6 Q. And it runs through April 13, 1977? 7 A. Yes. 8 Q. And is this stack of letters that's in this 9 book, are these the only letters that Monsanto sent where 10 they sent samples to people who were investigating PCBs? 11 A. No. This is just -- this represents some of 12 the group of letters that were sent. 13 Q. And are these, in addition to sending samples 14 of PCBs to researchers and universities and the U.S. 15 government, did these letters also incl]p ude information 16 about how -- what Monsanto's procedures were for the 17 proper identification of PCBs in the environment? 18 A. Some of them do, yes. 19 Q. Did they also indicate in these letters to 20 the universities and to the government agencies that 21 Monsanto would be happy to answer any further questions? 22 A. Yes, they do. 23 MR. CARNEY: Your Honor, I'd like to offer 24 these exhibits ini) evidence. 25 THE COURT: Which ones? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015655 14 MR. CARNEY: The ones that are in this book that I've read. THE COURT: Just the ones you've read? MR. CARNEY: No, the ones -- the exhibits numbers that I read into the record at the end of yesterday. THE COURT: 16, 18, 52 and 101. MR. CARNEY: No, the entire group of them. p MR. KOTOSKE: My specific objection is some of these exhibits have notations in handwriting on them. I think we can -- and I'll identify them for you. I'll have no objection if those notations are blacked out. THE COURT: All right. MR. KOTOSKE: And those exhibits are 66, 73, 76, 78 and 79, 82, 83, 85, 90, 96, 99. Now, I ask you to reserve your ruling on 101. When you read that exhibit p you will immediately know why. THE COURT: Are we talking about the same one? It's the one page, October 8, 1975. MR. KOTOSKE: It is. THE COURT: Do you want to go over? MR. KOTOSKE: I think we should. This will just take a minute THE COURT: Sure. MR. KOTOSKE: We don't need the reporter. Papageorge, William P.E,. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015656 15 1 (A ben]p ch conference was held.) 2 MR. KOTOSKE: So, Your Honor, in summary 3 (inaudible). 4 THE COURT: State, Mr. Carney, what 5 (inaudible). 6 MR. CARNEY: Yeah, I'm withdrawing Exhibit 7 101. 8 THE COURT: So continue, Mr. Kotoske, please. 9 MR. KOTOSKE: That's it. So if we withdraw 10 the Exhibit 101 from this group and erase all those p11 notations -- They can't be erased, just black them out, 12 they can go in. 13 THE COURT: The ones you named, the ones with 14 the notations which you would like obliteratd, which I 15 think is understandable. 16 MR. KOTOSKE: Precisely. 17 THE COURT: Except for that, I will admit 18 Exhibit 16 through 115 which were referred to. And why 19 don't I go through them to make sure. That includes 20 Defendant's Exhibit -- p21 MR. CARNEY: Well, okay. Judge, I just 22 looked at some of the notations, and I think they just 23 identify which type of PCB it is. I don't see a problem 24 with it, but for now let's just leave them out, and then 25 we can -- I think they ought to be in (inaudible). Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015657 16 THE COURT: So far they are out. And then I'll listen to you. So it's Defendant's 16, 18, 52, 60, 62, 63, 64, 65 through 69, 72 thrjo ough 80, 82 through 90, 95, 96, 97, 98, 99, 100, delete 101, then continuing with 102, 103, 104, 105, 114 and 115 are admitted into evidence except for the deletions which we've talked about in the exhibits noted by Mr. Kotoske. Proceed. Q. (By Mr. Carney) I'm going to try to get some dates in sequence, Mr. Papageorge. And first is the date when the U.S. government task force told Monsanto that they should continujo e to make PCBs for capacitors because it was necessary because of the risks of fires and explosions. What date was that? A. That's May 1972. Q. Okay. If I can find a piece of chalk that works. Okay. Now, at some point in time did you make a recommendation to management that Monsanto should announce to the government and to the customers that Monsanto (inaudible) stop making PCBs altogether? p A. I did, yes. Q. And what was that date? A. September 1975. Q. And then Monsanto agreed with your recommendation and made an announcement to the government that they were going to stop making PCBs as soon as a Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3 WATER PCB-SD0000015658 17 1 substitute was found. What was that date? 2 A. That was in January 1976. 3 Q. And then in October 1976 the TSCA law was 4 passed; is t]p hat correct? 5 A. That is correct, yes. 6 Q. And the effective date of that law was 7 January 1977? 8 A. Yes. 9 Q. And was it January of 1978 that there was a 10 ban on the manufacture of PCBs for all open uses? 11 A. 1978, yes, one year later. 12 Q. One year after the effective date? 13 A. Yes. 14 Q. I want to stop you there. So the ban on all 15 ]o open uses of PCBs was on January 1978? 16 A. Yes, sir. 17 Q. Now, Monsanto -- when did Monsanto stop 18 manufacturing for open uses? 19 A. August 30, 1970. 20 Q. So it was up here about almost seven years 21 before? 22 A. Yes. 23 Q. And then finally when was the ban on the 24 manufacture of PCBs for closed uses? 25 A. 1979. Another year went by. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015659 18 Q. And this law that was passed in 1976 with an effective date of January '77 banned the manufacture of PCBs for open uses in 1978? A. Yes. Q. And banned manufacture of PCBs in 1979? A. Yes MR. CARNEY: Can we get a stipulation on that, Mr. Kotoske? MR. KOTOSKE: Yes, we can stipulate that the EPA pursuant to -- Excuse me for not standing g -- pursuant to the Toxic Substance Control Act enacted regulations banning the use, manufacture of PCBs generally as counsel has stated, so the jury knows and everybody knows. THE COURT: I think we have agreed we may put it in an instruction. MR. KOTOSKE: In a jury instruction. MR. CARNEY: That would be fine, Judge, so we eliminate all this confusion. Q. (By Mr. C]p arney) So, Mr. Papageorge, prior to the law being enacted in October of 1976, this is when the law was enacted, Monsanto announced -- you had already recommended that Monsanto get out of the PCB business altogether? A. I did Q. And Monsanto had announced to the government Papageorge, William P.E,. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015660 19 1 that it was getting out of the PCB business just as soon 2 as a substitute would be found? 3 A. Y]p es. 4 Q. And Monsanto, when did it actually stop the 5 manufacture of PCBs? 6 A. In July of 1977. 7 Q. For closed uses? 8 MR. KOTOSKE: Well -- 9 A. That was all that was remaining then, yes. 10 Q. (By Mr. Carney) So that's right in here. 11 That would be a year and a half before the government ban 12 went into effect; is that correct? 13 A. That is correct.]p 14 MR. CARNEY: Judge, here's the statute, a 15 copy of. 16 Q. (By Mr. Carney)Now, I believe two of the 17 plaintiffs, Mr. Papageorge, testified that they saw 18 Monsanto labels on some drums, but they didn't read the 19 labels. Do you think by putting more information on the 20 labels that the -- it would help people read the labels? 21 MR. KOTOSKE: Well, that calls for 22 speculation, but I would like]p to have the answer as a 23 (inaudible) summary. 24 THE COURT: I'll sustain it as to the form of 25 the question. Mr. Carney? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015661 p7 ]p 20 MR. CARNEY: Sir, I -- THE COURT: Rephrase it. I sustained the objection as to form. Calling for what (inaudible). MR. CARNEY: I thought he wanted to hear the answer. MR. KOTOSKE: No. (Inaudible) objection. THE COURT: It's noted. Q. (By Mr. Carney) You think putting more information on a label than Monsanto put on the labels would encourage people to read the label? A. Not necessarily. It's been my experience in 40 years in the chemical industry that - MR. KOTOSKE: You know, I don't mind - THE COURT: (inaudible). MR. KOTOSKE: Absolutely. THE COURT: Sustained. You can have him (inaudible). Q. (By Mr. Carney) What has been your experience in the chemical industry with regard to putting more and more information on the label? A. The typical worker handling a material day after day after day, seeing the same kind of label doesn't stop to read that label. And in Monsanto we pointed out, of course, when he was first assignejo d to the job what was on the label, not only Monsanto's products, but other Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015662 21 1 products we purchased from others, and a worker that 2 handles materials day after day tends to accept it and 3 doesn't read any further. Even though a change has been 4 made, the chances are very, very slim that he will read 5 that new piece of information. The best information in my 6 experience is one where action to prevent harm is 7 de]p scribed. Symptoms are sometimes not understood by the 8 worker, and it doesn't make the impact that the action 9 word does. 10 Q. "Avoid skin contact," that kind - 11 A. Avoiding skin contact has a lot of meaning to 12 most of us, but to talk about medical symptoms may not 13 have the same urgency about them because they are not 14 understood. 15 Q. It's important in your 40 years of experience 16 that you sup]p plement the labels with meetings, safety 17 meetings describing how to safely handle the product? 18 A. Oh, yes. The meetings are more important 19 than the label in my opinion. 20 Q. Let's look at some of the labels, and we've 21 got a book -- For the record, I've supplied these 22 documents to Mr. Kotoske after court yesterday. Did I ask 23 you, again, a few days ago to review the exhibits in this 24 booklet so that we could s]p ave some time and not have to go 25 through each one? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015663 22 1 A. Yes, you did. 2 Q. And are these -- There are 39 exhibits here. 3 Are they representative examples of warning labels that 4 were placed on Monsanto PCB products? 5 A. They are. 6 Q. And I'd like to just read into the record the 7 exhibits that are covered, Defendant's Exhibit 147 through 8 149, 153, 154, 157, 160, 17p 0 through 187. 9 MR. KOTOSKE: Wait, wait. What about 161? 10 Did I miss something here? 11 THE COURT: Just 160, right? 12 MR. CARNEY: Yeah, I do get back to those in 13 order. Let me just do them. I do include 161. But 173 14 through 187. 15 THE COURT: 170? 16 MR. CARNEY: 173. 17 THE COURT: I'm sorry. 18 Q. (By Mr. Carney) Through 187. l]p 50 through 19 152, 155, 156, 163, 164, 166 through 172, 161, 162 and 20 165. I think that's the order they appear in the 21 notebook. 22 MR. CARNEY: At this time I'd like to move 23 for the admission of these exhibits. 24 THE COURT: Any objections? 25 MR. KOTOSKE: Yes. On the following exhibits Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015664 23 1 no product is even identified. And they are 155, 162, p2 165, 166, 168, 171, 172 and 173, 179 and 180 and 186. On 3 the following exhibits the second page is illegible. They 4 are 181, 182, 183, 184, 185 and 187. The following 5 exhibits don't even relate to PCBs sold to Bloomington. 6 They are 156 and 161. Additionally, none of these labels 7 are dated. 8 THE COURT: Of all the ones you've mentioned? 9 MR. KOTOSKE: That's right, all the ones in p10 this book. At least I can't find the date, I will tell 11 you that if you look at Exhibit 63 and 64, it appears that 12 those labels may have the date of 1954 to 1958 or 1954 to 13 1953, but I can't be sure. Those are my objections to 14 this group of exhibits. 15 THE COURT: Do you want to respond to those 16 objections or do you want to lay a foundation pursuant to 17 the objections? 18 MR. CARNEY: Well, again, Your Honor, I think 19 these documents are c]p overed in part in Dr. Kelly's 20 deposition. 21 MR. KOTOSKE: Let's reserve it, then. 22 MR. CARNEY: But I would like to ask a couple 23 questions real quick with regard to dates. 24 THE COURT: I'll reserve ruling. You 25 (inaudible) lay a partial foundation here and then with Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015665 24 1 Mr. Kelly. Proceed. 2 MR. CARNEY: Let me go through a couple of 3 them. I don't thin]p k there is any objection to -- I'm not 4 going to go through all of them. Some that you didn't 5 have an objection to that I haven't (inaudible). 6 THE COURT: (inaudible) 7 MR. KOTOSKE: Yes, there is. There is a 8 foundational matter, unless I can be shown how these are 9 dated. None of them are dated, and we don't know when 10 they were used and at what time. 11 THE COURT: You have a right to know. ]p Let's 12 proceed. 13 MR. CARNEY: I will (inaudible). 14 THE COURT: Sure. 15 Q. (By Mr. Carney) Take a look at Exhibit 151. 16 A. I have it. 17 Q. Now, is this a label that was used for 18 Aroclor 1242? 19 A. Yes. 20 Q. Is that the type of PCB that was sent to 21 Bloomington? 22 A. Yes. 23 Q. In fact, that was the vast majorijo ty of PCBs 24 sent to Bloomington? 25 A. Yes. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015666 25 1 Q. And can you tell was this label -- Let me ask 2 you this. Was there an environmental warning put on the 3 labels after a certain date? 4 A. Yes, there were. 5 Q. Can you give me that date? 6 A. May of 19 -- Sorry. Let methink. Yes, May 7 of 1970. 8 Q. And would the labels in this book that havejo 9 the environmental warning be labels that were used during 10 the period 1970 through 1977? 11 A. Yes. 12 Q. May of 1970 through 1977 when PCBs were - 13 you stopped manufacture? 14 A. Yes. 15 Q. The labels in this book that don't have that 16 environmental warning, were they all used prior to May 17 1970? 18 A. Yes, but some of those labels were used 19 during 1970 with an ad]p ditional label with the 20 environmental statement until new labels could be printed 21 containing the entire message. 22 Q. Before you could get the environmental label 23 printed, you had a stick-on that you would put on the 24 labels with the environmental warning? 25 A. Yes. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015667 26 1 MR. CARNEY: Your Honor, at this point I 2 would like to move just for the admission of Exhibit 151. 3 ]p THE COURT: All right. Any further 4 obj ections? 5 MR. KOTOSKE: No date. 6 THE COURT: And what's your response to that? 7 MR. CARNEY: Well, Your Honor, it's clearly 8 used prior to May 1970. It's the 1242 that was shipped to 9 the plant. I think in some of these instances Kelly can 10 give a more refined date. I don't think this witness can, 11 and so I'm -- but it was clearly a label usedjo during the 12 time that these plaintiffs worked at the Bloomington 13 plant. 14 MR. KOTOSKE: Let me urge my objection that 15 (inaudible) I'll save a lot of time. 16 THE COURT: Sure. 17 MR. KOTOSKE: It is very crucial in this case 18 to know the exact date of warnings with respect to when 19 these people were exposed. It is crucial. 20 THE COURT: I understand. I'll hold my 21 ru]o ling also on this one for now. 22 Q. (By Mr. Carney) Well, Your Honor, let me ask 23 this question. Mr. Papageorge, was this warning that's 24 Exhibit 151 used and placed on the drums of PCBs that were 25 sent to the Bloomington plant prior to May of 1970? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015668 27 1 MR. KOTOSKE: Pardon me. I must object. 2 Speculation. He does not know the date of this label, and 3 he cannot tell us with any certainty. p4 A. I think I can answer the question. 5 THE COURT: Overruled. You may answer, sir. 6 A. This wording appeared on all labels of the 7 PCB type shipped to Bloomington. MR. KOTOSKE: I move to strike. He doesn't 9 know that. 10 MR. CARNEY: Your Honor, he does. He was in 11 the plant. He was in charge of the labeling, and he 12 described how it was put on. 13 THE ]p COURT: Overruled. Overruled. 14 MR. CARNEY: Your Honor, at this point - 15 THE COURT: Can you lay any further 16 foundation as to how he knows? 17 Q. (By Mr. Carney) How do you know that, 18 Mr. Papageorge? 19 A. I saw it with my own eyes and watched the 20 shipments leave the plant. 21 THE COURT: What is the date again? You said 22 it was used on PCBs prior to May of '71. 23 Q. (By Mr. Carney) Let me ask you this, 24 Mr. Papageorge. The Westinghouse plant opened in 1958, 25 approximately? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015669 28 1 A. Yes, sir. 2 Q.The Westinghouse Bloomington. Was thislabel 3 used on PCB drumsthat were sent toBloomington before - 4 between 1958 -- Let me ask you this, was the language 5 that's on this label used from 1958 when the Bloomington 6 plant was opened until May of]p 1970 when the environmental 7 warning was added? 8 A. Yes, it was. 9 (Ms. Wann replaced Ms. Carter.) 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015670 29 1 MR. KOTOSKE: Note my objection. That's pure 2 speculation. The label was not dated -- a number of these 3 labels were not dated. We don't know when they came to 4 the factory, but as a practical matter the system -- if he is telling us this label was being used prior to the 6 environmental warning which we now know is May of '70, 7 I'll allow this one exhibit in, and I'll ask you to 8 reserve on the others. 9 THE COURT: It will be so admitted. 150 is 10 admitted into evidence. 11 MR. CARNEY: Your Honor, this is a blowup of 12 Exhibit 151. 13 MR. KOTOSKE: Would you give me just a chance 14 to look at my 151 ?]p 15 MR. CARNEY: Are you prepared? 16 MR. KOTOSKE: Oh, yeah. 17 THE COURT: Proceed. 18 Q. (By Mr. Carney) Is this a blowup of 19 Defendant Trial Exhibit 151? 20 A. It is. 21 Q. It's got the same (inaudible), 22 826.12.240.04/53? 23 A. It does. 24 MR. KOTOSKE: I'd like the jury -- they all 25 can't see it. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015671 1p 30 MR. CARNEY: This one I think they -- did 2 everybody see it? 3 Okay. Would you just read the language under 4 the (inaudible) through the line where it starts with 5 "Avoid"? 6 A. "Avoid prolonged breathing of vapors on 7 mists. Avoid contact with eyes or prolonged contact with 8 skin. If skin contact occurs, remove by washing with soap 9 and water. Following eye contact, flush with water. If p10 clothing becomes soaked with fluid, launder before wearing 11 again. 12 Q. (By Mr. Carney) Okay. Now, does this - 13 MR. KOTOSKE: Can the jury just have a chance 14 to absorb this exhibit, please? 15 MR. CARNEY: All right. 16 THE COURT: Has everybody seen it, looked at 17 it? 18 MR. CARNEY: They can look at it as long as 19 they need. 20 Is this -- Mr.j Papageorge, is this the 21 language that appeared on all of the labels that were put 22 on drums that were sent to the Bloomington plant between 23 the time the Bloomington plant opened and about 1958 until 24 May of 1970 when the environmental warnings were added? 25 A. It is. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015672 31 1 MR. KOTOSKE: That's on all PCBs that went to 2 that plant up to May of '70 had that warning? 3 MR. CARNEY: We]p 11, I -- I think it's my turn 4 to ask questions. I will ask them just - 5 THE COURT: If you want something clarified, 6 that's fine. 7 MR. KOTOSKE: That's all I want to know. 8 Q. (By Mr. Carney) This was on every drum of 9 PCBs; isn't that correct? 10 A. That's right. Every drum of material that 11 left the plant that contained PCBs. 12 Q. Now, with regard to the tank cars, ]p and that's 13 how most of the PCBs were shipped, the tank cars did not 14 go into the plants? 15 A. Yeah, they -16 Q. The customers? 17 THE COURT: The railroad tank cars. 18 Q. (By Mr. Carney) The railroad tank cars and 19 any other tank cars that delivered PCBs? 20 A. The railroad tank cars stayed outside on the 21 railroad (inaudible), yes. 22 Q. And was that true of t]p he Bloomington plant 23 when you watched -- when you toured, the tracks went up to 24 the outside of the plant? 25 A. Yes, sir. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015673 32 1 Q. And you saw where they pumped fluid in from 2 outside the plant? 3 A. Yes. 4 Q. And then it was piped in to the plant? 5 A. Yes. 6 Q. And at some point in time were there labels 7 put on tank cars? 8 A. ]p Yes. 9 Q. Was there a decision made to put labels on 10 all tanks cars, or was it just PCB tank cars? 11 A. This was all tank cars of chemicals. 12 Q. Chemicals of Monsanto or - 13 A. Well, those that left Monsanto plants were 14 Monsanto's chemicals, yes. 15 Q. And when was that done? 16 A. Well, the program started in1972. p17 Q. And this was a program where Monsanto had put 18 labels on tank cars? 19 A. Yes. 20 Q. Was it the idea to put the labels on tank 21 cars so that workers in plants would see the labels? 22 A. Well, certainly those workers that climbed up 23 on top and made the connections of pipe lines, those were 24 very few. The principal reason for that kind of labeling 25 was -- Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3] WATER PCB-SD0000015674 33 1 MR. KOTOSKE: Move to strike. p2 THE COURT: Sustained. 3 Q. (By Mr. Carney) Well, I'd like -- whatwas 4 the purpose of Monsanto's putting labels on tank cars? 5 A. To provide information about the material in 6 the tank cars should that tank car be involved in an 7 accident on its way to the customer's plant. 8 Q. So that would give information if there was 9 an accident of what was in the tank? 10 A. Yes. 11 Q. ]p Is that - 12 A. Yes. 13 Q. Now, just for the record, and maybe I can do 14 this. This might take -- there are certain exhibits in 15 this book that have the environmental warnings. I'd like 16 you to just read those and then I'll ask the witness to go 17 through them at this time if I made a mistake. 18 MR. KOTOSKE: You cannot read them. They're 19 not in evidence. 20 MR. CARNEY: I'm not goi]p ng to read them, just 21 read the exhibit numbers to (inaudible). 22 MR. KOTOSKE: Oh, no problem. 23 Q. (By Mr. Carney) Those are Exhibits D47 24 through 149, 153, 154, 157, 160 and 173 through 187. And 25 I -- you don't need to check that because we'll take a Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015675 34 1 little too much time. If I made a mistake on that that 2 will be pointed out (inaudible). p3 On those exhibits, assuming those all have 4 the environmental label on them, would those labels all 5 have been used between 19 -- after May, 1970 through 1977? 6 MR. KOTOSKE: Objection. Pure speculation. 7 THE COURT: Overruled. As long as you show 8 how he (inaudible). What were the dates again? 9 MR. CARNEY: It would be May, 1970 through 10 1977. I think it would be summer, '77 (inaudible). 11 THE COURT: You may an]p swer. 12 A. That environmental statement was started - 13 we started using that in May of 1970 and by the time in 14 1977 there were additional statements added to that 15 environmental statement. 16 Q. (By Mr. Carney) Who made therecommendation 17 to put the environmental warning on PCB contaminants? 18 A. I did. 19 MR. CARNEY: Then we have some internal memos 20 where this is confirmed, Judge, a]p nd I don't think we need 21 to go into that level of detail. 22 Were there also labels that Monsanto prepared 23 for use on PCB products bearing the Westinghouse trade 24 name for PCBs, and that is Inerteen? 25 A. Yes, there were. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015676 p5 35 Q. (By Mr. Carney) Take a look at Exhibit 157 in the 'label' book. A. I have it. Q. And that's a label -- that's a label word Inerteen in big bold letters? A. It is. Q. And it contains the standard warnings that was on Exhibit 151? A. It does. Q. And it indicates on there that this was May of -MR. KOTOSKE: Judge, please. MR. CARNEY: Oh, I'm sorry. THE COURT: You can lay a foundation if you want. MR. KOTOSKE: But he cp an't read from the exhibit. It's not in evidence THE COURT: I agree. But as far as laying a foundation (inaudible). Q. (By Mr. Carney) Did -- are you familiar with this particular label? A. Yes, I am. Q. And this was a Monsanto label or Monsanto prepared the label for Westinghouse, and it was used between the dates 19 -- May of 1970 and the summer of Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3 WATER PCB-SD0000015677 36 1 1977? 2 A. Yes. 3 MR. CARNEY: Your Honor, I'd like to offer 4 into evidence Defendant's Exhibit 157. 5 THE COURT: Any objections, sir? 6 MR. KOTOSKE: Look, it's not dated. None of 7 these labels are dated. If we have to rely on this man's 8 testimony (inaudible), I guess that's my objection. I - 9 Judge, I don't want to take up time on how important dates 10 are in th]p is case, but if you want to use that as an 11 example of what was after a certain date, it's up to you. 12 I think it's improper. 13 THE COURT: It will be admitted over the 14 objection, and it will speak for itself. It will stand 15 for itself based on the foundation. Proceed. 16 Q. (By Mr. Carney) And this label as well as 17 having in gold print Inerteen, it also says made for 18 Westinghouse Electric Corporation? 19 p A. It does. 20 Q. What was this -- was this a label that 21 Monsanto prepared for Westinghouse or so that Westinghouse 22 could put on their products when they shipped it out from 23 Bloomington and other plants of Westinghouse? 24 A. No. 25 Q. Okay. Tell me how this label was used. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015678 37 1 A. This was the label that was placed on drums 2 of material prepared for Westinghouse Co]p rporation 3 according to their specifications, and that material did 4 contain the PCBs and other ingredients. It was a mixture. 5 Q. Okay. Take a look at Exhibit 185. Can you 6 identify Exhibit 185? 7 A. This is a Monsanto label for the product 8 Aroclor 1016. This was used on the yellow drums. 9 MR. KOTOSKE: Move to strike. Judge, can you 10 read the second page of your volume? 11 TH]p E COURT: No. 12 MR. CARNEY: I can't either, but I think the 13 witness testified what it generally concerns. 14 THE COURT: As long as we -- could we get a 15 replacement copy? And I don't know what - 16 MR. KOTOSKE: I'd like to read what it says 17 is my problem. 18 MR. CARNEY: What -- your Honor, this is - 19 THE COURT: Why don't we have the witness 20 generally explainjo what the second page is -- 21 Q. (By Mr. Carney) Do you know what the second 22 page is? Maybe we can clarify this. 23 A. I do. 24 Q. Okay. What is it? 25 A. The second page is a copy of the wording that Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015679 38 appeared on the yellow drum in seven languages. The message is the same except that it's in different languages. MR. CARNEY: And as far as I'm concernp ed, I don't really care to - THE COURT: I will say this. Some of the words are readable, but the smaller words are not readable. Q. (By Mr. Carney) And I'm not interested in showing the jury these labels except in their languages. I don't speak any of them, Portuguese, Italian, Spanish, et cetera, and as far as I'm concerned we can either leave it the way it is, or we can take it out. I hap ve no preference THE COURT: The English, at least my copy, is somewhat readable, but I agree it's hard to read What is your pleasure, Mr. Kotoske? MR. KOTOSKE: I think my clients would fire me if they let me put into evidence things that I can't read. THE COURT: Fine. I'm willing to admit the first page and then - MR. CARNEY: That's fip ne. THE COURT: -- and let you look further at it. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3 WATER PCB-SD0000015680 39 MR. CARNEY: You know, I don't have any interest in (inaudible) other languages. The other thing I'm interested is the label (inaudible) that's in clear writing. THE COURT: The first page of Exhibit 185 is admitted The second page is not. Q. (By Mr. Carney) Exhibit 185, what Aroclor p did that concern? A. This is the Aroclor 1016. Q. And I think the jury has heard what 1016 is. That was the replacement for 'Aroclor 2'? A. It was. Q. Did this -- when did this label first start to be used? A. 1971. Q. And for what period of time would this label have been used on the drums of PCBs sent to -- A. Until the sales were stopjo ped in 1977. Q. Your Honor, I may try to get a better copy of this. Does this label contain the seven -- safe handling information in the seven languages on the second page? A. Yes. Q. The same kind of safe handling information Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3 WATER PCB-SD0000015681 40 that we've already shown the jury? A. The same kind, yes, sir. Q. Did all of the Aroclor 1016 labjo els contain an environmental warning? A. Yes. MR. CARNEY: Okay. Next I'd like to -- I think this is my final group exhibit. And it's -- this is two volumes. I think you have it. It's labeled brochures, your Honor. Here's Volume II, Judge, your copy. Maybe -- okay. Here's Volume I. THE COURT: All right. MR. CARNEY: And I have a skinny version .(inaudijo ble That first page. Mr. Papageorge, did you again review these documents at my request a few days ago? A. Yes, I did. Q. (By Mr. Carney) Can you generally describe what's in these two volumes? A. These are brochures or bulletins that describe Monsanto's Aroclors, and they -- this collection includes the various editions that came out through the years. p Q. So these are PCB brochures? A. Yes, they are. Q. And first -- and in the first volume I Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3 WATER PCB-SD0000015682 41 1 believe are Exhibits 134 through Exhibit 146. Do these 2 brochures contain any information about product toxicology 3 and safe handling? 4 A. They do. 5 Q. Who prepared the section on toxicology and 6 safe handling of these PCB brochures? 7 A. Monsanto's Medical De]p partment. 8 Q. To whom were these brochures given? 9 A. To customers of course and anyone that was 10 interested in this material with the idea that they might 11 want to buy it and use it. 12 Q. Were these brochures given to Westinghouse? 13 A. Yes. 14 Q. Were they -- let's talk about -- let's go to 15 one of the brochures, Exhibit 141. Can you identify this 16 brochure? 17 A.p My tab is torn. I think I have 141. 18 Q. Is it - 19 A. I'm not certain. 20 Q. Let me check to make sure. It should be on 21 the bottom. That's '440'. I guess it's the next line. 22 I've got it. 23 A. I have it. 24 Q. Read the title of this brochure. Or first of 25 all, when was the date? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015683 42 1 A. This is dated January, 1960. p2 Q. And it has on the bottom (inaudible) 3 Monsanto employee? 4 A. Yes. 5 Q. And it says "Revised January, 1960"? 6 A. Yes. 7 Q. This is a Monsanto brochure? 8 A. Yes. 9 Q. And what's the title of the brochure? 10 A. The problem - 11 MR. KOTOSKE: Just to speed things along, I 12 want all of these in evidence. lp13 THE COURT: 134 through 46. 14 MR. CARNEY: That would speed things along. 15 I would move for the admission of all of them. 16 MR. KOTOSKE: All of them. 17 THE COURT: So admitted as to Exhibits 134 18 through Exhibit 146. 19 MR. KOTOSKE: How about 257? I'd like to 20 have that in evidence also, at least one of these Monsanto 21 (inaudible). 22 MR. CARNEY: Well, your Honor I'll take a 23 loo]o k at that one. 24 THE COURT: Yeah, let me know later. 25 MR. CARNEY: It may be a -- I have a Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015684 43 1 suspicion I know what it is. 2 THE COURT: Just proceed. 3 MR. KOTOSKE: So these are all in evidence. 4 THE COURT: 134 through 146 is so admitted. 5 MR. KOTOSKE: Thank you. He can read 6 anything he wants from them. 7 MR. CARNJo EY: Okay, good. I'm not going to 8 read too much, but I am going to read a few things. This 9 is the final subject. 10 Take a look at Exhibit 141, page 98, and I'm 11 going to have a blowup of that. Now, I've got here 12 Exhibit 141-A, and before I show that to the jury, can you 13 tell, is that -- can you identify that as the same as 14 Exhibit 141 (inaudible) handwriting on it? 15 MR. KOTOSKE: Stipulate. p16 THE COURT: Okay. 17 Q. (By Mr. Carney) And can you identify, does 18 that handwriting indicate that that's a brochure that came 19 out of Westinghouse's files? 20 A. Yes. 21 Q. It has a Dakin, a handwritten name Dakin on 22 it. Do you know who that is? 23 A. Dr. Dakin, yes. 24 Q. He's a Westinghouseresearcher? 25 A. Yes, sir. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015685 44 p1 MR. CARNEY: Any objections to showing this 2 Exhibit 141-A? 3 MR. KOTOSKE: No. I want them to see it 4 MR. CARNEY: Okay. Good. 5 Would you take a look at page 98, and I'd 6 like to -- I'll just read, and you go along, and this is 7 with the sentence under skin exposure. 8 Can everybody see that and read it? 9 THE COURT: Please show the alternates. 10 ]o MR. CARNEY: The problem is, if I get too 11 close then the alternates have problems. How about here? 12 Is this -- okay. 13 It says on page 98 under skin exposure, 14 "Prolonged skin contact should be avoided. If work 15 clothes become impregnated with these fluids, they should 16 be removed and washed. When sampling tank cars, canvass 17 gloves and safety glasses or goggles should be worn. No 18 special clothing is required, but t]p he workers' garments 19 should be laundered at least weekly and changed if 20 Aroclors or Askarels are still on the clothes." 21 Did I read it correctly? 22 MR. KOTOSKE: We'll stipulate that you read 23 it correctly. 24 Q. (By Mr. Carney) It then says, "Exposure to 25 vapors". Do you see that section? And I think it's page Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015686 45 1 99? 2 A. I found it. 3 Q. Va]p pors from hot Aroclor or Askarel have a 4 degree of toxicity and shouldn't be inhaled over a 5 prolonged period of time. Capacitor impregnations may be 6 done at temperatures as high as 260 degrees Fahrenheit 7 (130 degrees centigrade). 8 Let me just stop there for just a second. 9 There's been testimony about how hot these ovens got in 10 the Bloomington plant, and I think the testimony was in p11 the 130 or 140 degree centigrade range. This is -- is 130 12 degrees since this country doesn't -- we use Fahrenheit 13 most of the time -- is 130 degrees centigrade the same as 14 266 degrees Fahrenheit? 15 A. It is. 16 Q. All right."Followingimpregnation and 17 draining, the chamber, exhaust ventilation should be 18 applied to the chamber to prevent Askarel vapors entering 19 the work room. Also when opening a heated capacitor 20 impregnating chambejo r the workmen should wear a respirator 21 during this short interval of exposure." 22 Did I read that correctly? 23 A. You did. 24 Q. Now, again this -- we've got Aroclar or 25 Askarel. What's Askarel? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015687 46 1 A. Askarel was the generic word to describe fire 2 resistant capacitor fluids. 3 Q. But Aro- - 4 A. But Aroclar is a Monsanto trademark for the 5 ]p same kind of term when in that use. 6 Q. Okay. I guess at the end of the -- the last 7 two paragraphs of this Monsanto brochure are the words 8 "For many years of satisfactory and safe use of Aroclors 9 or Askarels I would like to (inaudible) the industry for 10 impregnating capacitors and filling transformers has 11 demonstrateed the industry's ability to handle these 12 fluids without hazard to workmen. It is both simple and 13 in]p line with good housekeeping and personal cleanliness to 14 exercise the suggested precautions in all cases." 15 Did I read that correctly? 16 A. You did. 17 Q. And this wasa brochure that was in 18 Westinghouse's files and dated January, 1960? 19 A. That is correct. 20 MR. KOTOSKE: Objection. He doesn't know if 21 it's in Westinghouse files or not. 22 MR. CARNEY: Well, I]p think he already 23 testified that handwriting - 24 MR. KOTOSKE: He can't be a handwriting 25 expert. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015688 47 1 THE COURT: Lay a foundation. 2 Q. (By Mr. Carney) Okay. I think you've 3 already testified this was in Westinghouse's files. And 4 how do you know that? 5 A. Well, I know Dr. Dakin personally, and his 6 name does appear on that document. 7 Q. W]p here? 8 A. It's shown on the blowup there in the upper 9 right-hand corner of the title page. 10 MR. KOTOSKE: Now, do you see what he's 11 looking at, Judge? 12 THE COURT: Let him finish his -- are you 13 finished with your foundation as far as how he knows it 14 was in Westinghouse files? 15 Q. (By Mr. Carney) And you know Dr. Dakin to be 16 a Westinghouse employee? 17 A. I d]p o . 18 MR. CARNEY: And, your Honor, just so we 19 don't have any confusion, we have a Westinghouse 20 deposition that indicates that this came out of the 21 Westinghouse files. 22 THE COURT: I'll -- I'll say so far that it 23 hasn't been connected up as far as his knowledge that it 24 is absolutely in the file, but certainly the jury can 25 consider the fact that Dakin is shown thereof and Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015689 1 (i]p naudible) . 48 2 MR. CARNEY: We have that. 3 THE COURT: (Inaudible), so I'll strike maybe 4 just that part of the question. You may proceed. 5 Q. (By Mr. Carney) Take a look at Exhibit No. 6 146. Is this another Monsanto brochure? 7 A. It is. 8 Q. Is there anything in this brochure where he 9 refers to the -- refers to assistance from Westinghouse in 10 the preparation of the doc]p uments? 11 A. There is. 12 Q. And where is that found? 13 A. On page 1 of the document in the introduction 14 portion. 15 Q. Would you read that portion of this Monsanto 16 brochure where it talks about the contributions of 17 Westinghouse? 18 A. "Monsanto greatfully acknowledges the 19 assistance, guidance and contributions of certain data by 20 the following", and it lists Dr. T. K. ' S]p lope', 21 Westinghouse Electric. 22 Q. And you've mentioned Mr. Slope's name? You 23 knew him personally from Westinghouse? 24 A. Yes, I did. 25 Q. Personally. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015690 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24p 25 49 Now, I believe I asked you probably three or four days ago, you may have forgotten this, but to look at this document to give a best estimate of the date of this brochure? A. Yes, you did. Q. And are you able to give an estimate by looking at the warnings as to the date of this brochure? MR. KOTOSKE: That's speculation. This document is not dated. We don't know when it was prepared. THE COURT: Well -- MR. KOTOSKE: He's not (inaudible). MR. CARNEY: What I'd like to do is, I think he can give an estimated date. THE]o COURT: I will let him -- I'll let him answer. I don't know if that's going to be enough - MR. CARNEY: Okay. THE COURT: -- but I'll let him answer. A. There is a reference in this document to the ANSI C-107 standard. And since that standard was available in January of 1974, this brochure certainly was prepared after that date. Q. (By Mr. Carney) Do pages four and five of this brochure contain safe handling information? MR. KOTOSKE: Stipulated they do -- that it Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015691 1 does. 50 2 A. They do. 3 Q. (By Mr. Carney) It says to avoid skin 4 contact and exposures to heat and vapors? 5 A. It does. 6 Q. Mr. Papageorge, does the toxicity and safe 7 handling section of the Monsanto customer brochures that 8 are marked D-134, 135 and 13]p 6 contain a warning that 9 repeated bodily contact with PCBs may lead to an acneform 10 skin eruption? 11 A. They do. 12 Q. Do these three - 13 MR. KOTOSKE: Excuse me. Could I have that 14 read back again? Just the question. 15 MR. CARNEY: I think I can probably -- go 16 ahead. 17 THE REPORTER: Mr. Papageorge, does the 18 toxicity and safe handling section in Monsanto cus]p tomer 19 brochures that are marked D-134, 135 and 136 contain a 20 warning that repeated bodily contact with PCBs may lead to 21 an acne eruption - 22 MR. CARNEY: Form. 23 THE REPORTER: -- an acneform eruption? 24 MR. CARNEY: Skin. 25 THE REPORTER: -- skin eruption? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015692 51 1 THE COURT: And your answer was? 2 A. They do. 3 Q. (By ]p Mr.Carney) Do thesesame brochures 4 contain a warning that PCB vapors evolved at high 5 temperatures or by repeated oral ingestion will lead to 6 systemic toxic effects? 7 A. Yes. Q. Now I'm goingto just switch toExhibits 144 9 and 145. 10 A. I have them. 11 Q. Do these two exhibits bothwarn of the 12 possibility of Chloracne if there's excessive exposure to 13 PCBs ? 14 ]o A. Yes, they do. 15 Q. Did Westinghouse receive copies of these 16 brochures, 134, 135, 136, 144 and 145? 17 A. Yes. 18 MR. KOTOSKE: Your Honor -- 19 Excuse me, Mr. Papageorge. 20 Objection. Lack of foundation. 21 THE COURT: (Inaudible). 22 Q. (By Mr. Carney) And how did do you know 23 that? 24 25 A. The practice withinMonsanto whenthese bulletins are printed is to make certain that the users of Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015693 52 1 the material get copies, and that is done two ways: One 2 by mail and the other by the salesman personally 3 delivering copies to make certain that the representatives 4 of Westinghouse actually receive them. 5 Q. Turn to Exhibit -- and this is in your - 6 this isn't in the brochure (inaudible) -- Exhibit 250 - 7 it's 257. 8 T]p HE COURT: (Inaudible) . 9 MR. CARNEY: It would probably be in about 10 the third book I gave you. It's the last exhibit other 11 than group exhibits. 12 MR. CARNEY: I have a copy here - 13 THE COURT: Well -- 14 MR. CARNEY: -- I can probably give you. 15 THE COURT: I'll listen to you. 16 MR, CARNEY: Okay. 17 MR. KOTOSKE: Are we going to admit 2 5]p 7? 18 MR. CARNEY: They've already been admitted, I 19 think all of the brochures. 20 MR. KOTOSKE: Well, we don't have a ruling. 21 I want Exhibit 257 in evidence, Judge. 22 THE COURT: Are you moving -- 257, I might be 23 wrong, I don't show in evidence. 24 MR. KOTOSKE: It's a 'Monsanto document' 25 dated 1976. It's the last publication. I want it in. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015694 p2 53 It's not. THE COURT: its admission? Mr. Carney, are you moving for MR. CARNEY: Your Honor, this is a Westinghouse document, not a Monsanto document, but I don't have it -- that's fine with me - THE COURT: All right. MR. CARNEY: -- to put it in. THE COURT: Exhibit 257 is admitted into evidence. MR. KOTOSKE: Thank you. ]p MR. CARNEY: Does -- is that the document you referred to earlier? MR. KOTOSKE: Might have been, yes. Q. (By Mr. Carney) Okay. Can you identify Exhibit 257? A. This was a Westinghouse Electric Corporation bulletin entitled Instructions for Handling Inerteen insulating fluid, PBS 54 201 CM, and installation and maintenance of Inerteen transformers. pQ. I know this is a Westinghouse document. I really don't know what the answer is to the question, but I'm just going to ask you, do you know how this document was used? A. I have an understanding that this is the kind Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015695 54 1 of document that Westinghouse Company gave to its 2 customers of transformers or potential customers of 3 transformers. 4 Q. And take a look at the Bates Stamp No. 3189. 5 I think it's]o about the third -- third or fourth page. 6 A. I have it. 7 Q. Are there anyWestinghouse brochure safety 8 precautions for the handling of PCBs? 9 A. Yes. 10 Q. It said not to breathe the Inerteen fumes in 11 excess of 'a maximum of volatile' concentrations? 12 A. Yes. 13 Q. Says that the Inerteen can be absorbed 14 through skin and skin contact should be avoided? 15 ]p A. Yes. 16 Q. And it suggests (inaudiable) this equipment? 17 A. Yes. 18 MR. KOTOSKE: Can we have the (inaudible) - 19 MR. CARNEY: That's Bates Numbers 3189. It's 20 the second page of the brochure after the index. 21 MR. KOTOSKE: Thank you. 22 MR. CARNEY: I've got one last question, Mr. 23 Papageorge, and I'm finished asking questions. On a scale 24 of 1 to 10]p , one being the worse and 10 being the best, 25 what grade would you give Monsanto with regard to Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015696 1 informing Westinghouse about PCBs? 55 2 A. Well, sir, comparing what was done in this 3 case, I'd have to call it a 10. 4 MR. CARNEY: I have no further questions. 5 MR. KOTOSKE: Can we take a little break? 6 THE COURT: Certainly. 7 MR. KOTOSKE: Of less than -- THE COURT: Certainly. (Inaudible.) 9 Do not discuss the case among yourselves or 10 others. 11 [Ms. Wann was replaced by Ms. Olliges. ] 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015697 56 1 THE COURT: All right. Mr. Kotoske, you may 2 proceed sir. And ladies and gentlemen, we'll go to 3 approximately ten or five to 12:00. You may proceed. 4 MR. KOTOSKE:]o Thank you, Your Honor. Your 5 Honor, will you cut me off then? 6 THE COURT: I'll let you know. 7 Q. All right. Now, Mr. Papageorge, if you'll 8 listen to my questions and just answer those questions, 9 we'll try to get you out of here. All right? 10 A. Yes, sir. 11 Q. First, PCB, we're talking about as a 12 substitute 1016, Aroclor 1016. I want to ask you a very 13 simple question. That' s]p PCB; isn't it? 14 A. Yes, sir. 15 Q. 100 percent 1016 ispolychlorinated biphenyl? 16 A. Yes. 17 Q. You're not trying to tell the jury it wasn't 18 PCB; you're trying to convey the idea it was, according to 19 you, more biodegradable? 20 A. That's correct. 21 Q. Next subject. Wetalked aboutprofitability 22 from PCB sales on your examination by Mr. Carney. In 1969 23 the PC]o B sales were $22 million. Did you think that was a 24 significant or an insignificant amount of money on the 25 overall of Monsanto sales? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015698 57 A. Since I don't recall the overall sales, sir, that is significant, but I don't know how else to describe it. It was a respected product in Monsanto's listing of products that they sold to their customers. Q. However, 1969 was not your peak year. Peak p year for sales of PCBs Monsanto was 1968. How much money did you make in 1968 on the sales of PCB, if you know? A. I do not know. Q. You do know that 1969, which is Exhibit 11, page 87, you made 22 million? MR. CARNEY: I'm not sure by the question if he's talking about sales or profits. MR. KOTOSKE: Sales. MR. CARNEY: His question asked about if he made p that, which would imply there's a profit. Q. Sales. MR. CARNEY: It's misleading. I would object to the question. THE COURT: He's amended it to sales. You may answer, sir. A. I forgot the question now. Q. Very simple. Sales of PCB, 1969, $22 million? A. I don't remember the number, sir. I'd like to see a document to help me Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3 WATER PCB-SD0000015699 58 Q. Turn to page 87, Exhibit 11. I'll try to turn to it, too, and be sure we're on the right track. Reading from the bottom of the page, this is already in evidence. "Monsanto's world-wide Aroclor business amounts to 104 million pounds a year, 70 million used in functional fluids, 34 million in plasticizers. This represents 22 million in sales." Correct? A. That is correct. Q. p Let's move on to another subject. You told this jury that PCBs won't burn; is that true? A. I didn't mean to say they won't burn. They resist burning is a more correct term. Q. Well, of course. Have you heard of transformer fires in this country? A. Certainly I have. Q. Have you heard of capacitor fires in this country? A. Certainly. Q. Let mp e ask you a question. There's a famous PCB incident in Binghamton, New York MR. CARNEY: Your Honor, could we approach the bench? (A bench conference was held.) THE COURT: Proceed, sir. Q. All right. How many transformer fires have Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3 WATER PCB-SD0000015700 59 1 you heard of in this country? Just roughly. 2 THE COURT: Without any details. 3 Q. Just a np umber. 4 A. About three. 5 Q. How about capacitors? 6 A. None. 7 Q. Do you still use IBT as a laboratory? 8 A. No, sir. 9 Q. Why not? 10 A. They're out of business. 11 Q. A Cadillac -- That Cadillac ran out of gas; 12 is that right? 13 MR. CARNEY: Your Honor, objection, and I 14 think you know what my objection relates to. 15 ]p THE COURT: Well, he's covered it. The 16 witness stayed away from it, so I think you can move on. 17 Q. When did they go out of business? Do you 18 know? 19 MR. CARNEY: Objection, Your Honor. 20 THE COURT: Again, I don't think that's -- I 21 don't see the relevance. I'll sustain the objection. 22 Q. You identified a lot of toxicological reports 23 in some of these group exhibits from p Drinker, Scientific 24 Associates, the Treon reports, a whole batch from Younger 25 Labs. I was curious, in all these animal studies that Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015701 60 you've taken, how come you didn't include the IBT study? A At what point in time, sir? Q Anytime. MR. CARNEY: Well, Your Honor, I think he's asking the witness to speculate on why I didn't include them in the notebook and that was because p it's already in evidence That's the only reason I didn't. He doesn't know the reason. MR. KOTOSKE: Let me back up. Q You brought these toxicological animal studies that Monsanto has done over the years into court, put them in evidence; didn't you? A I personally? I don't understand, sir. Q Monsanto's lawyers showed you a lot of toxicological animal studies; didn't th]p ey? A They did. Q How come they didn't show you any IBT studies ? MR. CARNEY: Your Honor -- THE COURT: Sustained as to form. MR. CARNEY: Calls for speculation. They were already evidence at the time THE COURT: Yeah. That's the only reason I didn't. He doesn't know the reason.. Q Does Monsanto still rely on those IBT p studies Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3 WATER PCB-SD0000015702 1 talking about PCBs? 61 2 MR. CARNEY: Your Honor, I'm going to object. 3 He's been retired since '86. 4 Q. Up through '86 - 5 THE COURT: Sustained. 6 Q. Up through 1986 did Monsanto rely on those 7 IBT studies? 8 MR. CARNEY: Can we approach the bench, Your 9 Honor? 10 (A bench conference was held.) 11 THE]p COURT: Proceed, sir. 12 MR. KOTOSKE: Thank you. 13 Q. After Congress passed the the statute in '76, 14 there was a period of time when the implementation of the 15 regulations as apart from the statute followed. Do you 16 remember that? 17 A. I do. 18 Q. Okay. And that's when EPA was having its 19 hearings; was it not? 20 A. Yes. 21 Q. On how to ban and when to ban and ]p so forth? 22 A. Yes, sir. 23 Q. Did you participate in those hearings? 24 A. I did not. 25 Q. The electric industry, principally General Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015703 62 Electric and Westinghouse, fought EPA on those regulations; did they not? A. That I don't know, sir. Q. You don't know that? A. No, sir. Q. You don't know what happened in those p hearings that went for two or three years before PCBs were finally banned? A. I was not involved in any of those hearings I only read an occasional newspaper article or magazine article on that. Q. You were not involved? A. That is correct. Q. Was Paul Wright from Monsanto, the manager of toxicology, involved? A. I do not know. Q. You have nop knowledge? A. That is correct. Q. Did Monsanto participate on behalf of the electrical industry to forestall the implementation of those regulations? A. Sir, I know nothing about that activity. I can't help you. Q. I'm going to read to you from an exhibit about Paul Wright -- Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3 WATER PCB-SD0000015704 63 MR. CARNEY: Your Honor, can we approach the bench? p Q. -- where he receives a cash award. THE COURT: You want to approach? MR. CARNEY: Yes. THE COURT: All right. (A bench conference was held.) Q. Did Paul Wright participate in hearings with EPA to regulate PCBs in effluents? A. I believe he did, yes. Q. And he sought to forestall the implementation of those regulation^ s; did he not? A. That's not my understanding, sir. Q. And he was a Monsanto employee when he executed those efforts; was he not? A. He was. He was involved in Monsanto's efforts to help the EPA arrive at what we thought were scientifically-based standards. MR. KOTOSKE: At this time, Your Honor, I'm going to read from page 522 of Exhibit 12, particularly - This is about P]p aul Wright when he was getting cash from Monsanto. It says, "Achievement Award. Particularly noteworthy were his efforts on polychlorinated biphenyls, Aroclors, and chlorinated" -- I can't pronounce that word. It's spelled I-s-o-c-y-a-r-a-t-e-s. What is that? ACL Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015705 1 2 3 4 5 6 7 9 10 11 lp 2 13 14 15 16 17 18 19 20 21 22 23 24 25 64 products? A. ACL. Those are swimming pool chemicals. Q. "Particularly noteworthy were his efforts on polychlorinated bi]p phenyls, Aroclors, and 'chlorinated pool products'. In the former instance, his excellent analysis and synthesis of widely-scattered observations played a prominent role in forestalling EPA's promulgation of unrealistic regulation to limit discharges of PCBs. EPA's proposed regulations would have precluded the use of these materials by Monsanto's customers." By that time you had very few customers. They were electrical customers; weren't they? A. Yes, sir. Q. Now, are you telling us that Monsanto was a good neighbor, corporate responsible, when it sought to deter the implementation of EPA's regulations? A. Yes, sir. You could be both. Q. Now, I want to go to a different subject matter. You first learned of -- According to your testimony, in 1966 you first became aware of environmental damage c]p aused by your products -- excuse me -- by PCBs? A. That's not -- I would not describe it as environmental damage. I would describe it as environmental presence. Q. It caused you some concern? Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015706 65 A. Yes. Q. Why did you increase production of PCBs in 1969? A. Because the customers wanted more material. Q. Why in 1970 did you seek to increasjp e production of PCB? A. I don't recall that there was increased production of PCBs there. You're talking about chlorinated terphenyls, I believe. Q. Between 1966 and when the first concern first arises at Monsanto's headquarters here in town, it wasn't until 1970 that they set up this job for you, this environmental concern program; is that right? A. That is accurate. That's true. p Q And in the intervening four years when a concern first popped into Monsanto's head, it kept increasing sales of PCBs; did it not? MR. CARNEY: I'm going to object to the use of the four years because it's at the end of '66. I think it was December 28th - THE COURT: Well, I'm going to let him answer the question. MR. CARNEY: -- the letter was sent. P THE COURT: Overruled. A. Sir, the interval of three years from '66 to Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3 WATER PCB-SD0000015707 <o Ft 66 early '70, Monsanto had an unusual effort regarding this kind of activity in getting the necessary equipment and technology and whatever it took to understand whether or not the information they heard in '66 was truly connected somehow with their product. Q. You could have choked the flow of PCBs off in 1966; c]p ouldn't you? A. That's easy to say, sir. Q. The question is could you? A. We -- I don't know quite how to interpret your word "choke off". We were not in control of all of the PCBs in the world. Q. I didn't ask you that question. I asked you, you at Monsanto could have stopped in 1966 when the concern about the environmental problem first came to your attention? ]o A. There was no concern at that time. There was an indication that there might be PCBs in the environment. You don't choke off a supply of a valuable chemical based on somebody's suspicion. Q. In fact, you increased your sales in 1969 despite the fact that you had a concern because you wanted to make the $22 million; isn't that right? MR. CARNEY: Your Honor, he's talking about making a profit of]p 22 million again, and the profit wasn't 'B 6 Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015708 67 1 anywhere close to that, so that it's very misleading to 2 the jury that they were making that kind of money. 3 THE COURT: If the witness disagrees with the 4 question, he can say so. He can explain it. You may 5 answer. 6 MR. CARNEY: I'm going to object to the form 7 of the question. He puts about four sentences together. 8 It's compound. And I dop n't know which question he wants 9 to have answered. So I object to the form. 10 THE COURT: Overruled. You may answer the 11 question. 12 A. While the studies relating to determining 13 whether or not PCBs were a problem in the environment were 14 going on, yes, the material was sold to the uses to which 15 it had been sold to for 40 years, during which no problems 16 were made known. 17 MR. KOTOSKE: Yoa ur Honor, could we stop here 18 and we'll pick it up with Monsanto's action plan when we 19 come back? 20 THE COURT: That's fine. Step down. Ladies 21 and gentlemen, why don't we take a lunch break, let's say 22 until about 1:10, and then we'll continue. Again, do not 23 discuss the case among yourselves or with others, and I'll 24 have an announcement for you as to what we're going to do 25 tomorrow. Okay. Papageorge, William P.E. (fmr Mons Mgr Occ Hlth) in G. BROWN (3) WATER PCB-SD0000015709 [0 - 202] Transcript Word Index 0 135 o 22:8 1 50:8,19 51:16 136 50:1951:16 13th 1 50:8 48:13 54:24 140 1:10 45:11 67:22 141 10 41:15,1743:10,12,1444:2 54:24 55:3 144 10/31/91 51:8,16 1:1 145 100 51:9,16 16:4 56:15 146 101 41:1 42:18 43:4 48:6 14:7,16 15:7,10 16:4 147 1016 22:7 37:8 39:9,10 40:3 56:12,12 149 56:15 22:8 33:24 102 15 16:5 2:21 13:4 103 150 16:5 29:9 104 151 16:5 58:5 24:15 26:2,24 29:12,14,19 105 35:8 16:5 152 107 22:19 49:20 153 10th 22:8 33:24 54:24 154 11 22:8 33:24 8:25 10:8,23 57:9 58:1 155 114 22:19 23:1 16:5 156 115 22:19 23:6 12:17,19 15:18 16:5 157 12 22:8 33:24 35:1 36:4 7:17 63:20 16 12:00 12:10,11,17,19 14:7 15:18 56:3 16:2 1242 160 4:9,15 24:18 26:8 22:8,11 33:24 1254 161 4:9,15 22:9,13,19 23:6 12th 162 7:16 22:19 23:1 13 163 6:7 13:6 22:19 130 164 45:7,11,11,13 22:19 134 165 41:1 42:13,17 43:4 50:8,19 22:20 23:2 51:16 166 22:19 23:2 168 23:2 17 7:20 170 22:15 171 23:2 172 22:19 23:2 173 22:13,16 23:2 33:24 179 23:2 17th 22:8 18 10:17 14:7 16:2 180 23:2 181 23:4 182 23:4 183 23:4 184 23:4 185 23:4 37:5,6 39:5,7 186 23:2 187 22:8,14,18 23:4 33:24 19 6:15 7:14 25:6 34:5 35:25 192 2:8,21 8:20 9:25 193 2:21 9:25 1938 2:4,21 1953 3:23 23:13 1954 23:12,12 1955 3:25 4:12 1958 5:13,15,22 23:12 27:24 28:4,5 30:23 196 2:8 3:9,18,23 9:25 1960 42:1,5 46:18 1962 5:24 6:7,15,17,19,23 1963 6:25 7:14 1966 2:4 7:17,20,25 64:20 65:10 66:7,14 1968 13:4 57:6,7 1969 11:3 56:22 57:5,9,22 65:3 66:21 197 2:8 3:9,19 10:1 1970 17:1925:7,10,12,17,19 26:8,25 28:6 30:24 34:5,9 34:13 35:25 65:5,12 1971 1:11 39:15 1972 16:14 32:16 1974 49:21 1975 14:19 16:22 1976 17:2,3 18:1,20 52:25 1977 13:6 17:7 19:6 25:10,12 34:5,10,14 36:1 39:18 1978 17:9,11,15 18:3 1979 17:25 18:5 198 2:8 4:4 10:1 1986 61:6 199 2:8 4:4 10:1 19th 2:8 IP 22:18 42:13 64:11 2 o 39:11 53:1 64:11 200 2:9 5:2 8:9 9:20 10:2 201 5:16,18 8:9,13,17 9:20 10:2 53:19 202 5:22 8:9,21 9:20 10:3 Papageorge, William P.E. (fmr Mons MgrOcc Hlth) in G. BROWN (3) WATER PCB-SD0000015710 [203 - alternates] 203 5:24 6:5 10:1 204 6:7 205 6:15 206 6:17 207 6:19 208 6:21 209 2:9 5:2 6:23 10:1 20th 5:19,20 211 2:10 5:2 6:25 10:1 216 2:10 5:2 7:13 10:1 217 7:16 218 7:19 219 7:25 22 5:13,15 6:21 56:23 57:10 57:22 58:7 66:23,25 220 2:10 5:3 8:2 10:2 24th 49:23 25 6:17,19 51:24 250 52:6 257 42:19 52:7,21,22 53:9,16 25th 52:17 260 45:6 266 45:14 28th 65:20__________________ 3 3 2:8 11:3 30 17:19 30s 1:7 3189 54:4,19 34 58:6 39 22:2 4 A 6:25 40 20:1221:1567:15 440 41:21 46 42:13 5 5 29:4 35:4 50 22:18 52 14:7 16:2 522 63:20 54 53:19 6 6 5:24 50:8 60 16:2 62 16:3 63 16:3 23:11 64 16:3 23:11 65 16:3 66 14:14 65:19,25 66:4 69 16:3 7 7 20:6 52:17 70 29:6 31:2 58:5 66:1 71 27:22 72 16:3 73 14:14 76 14:1561:13 77 18:2 34:10 78 14:15 79 14:15 8 8 5:22 14:19 55:7 80 10:9 16:3 81 10:10,22 82 10:9 14:15 16:3 826.12.240.04/53 29:22 83 14:15 85 14:15 86 61:3,4 87 57:10 58:1 g 9 6:23 7:25 90 14:15 16:3 95 16:4 96 14:15 16:4 97 16:4 98 16:4 43:10 44:5,13 99 14:15 16:445:1 a a.m. 1:1 a.fj 41:17 ability 46:11 able 49:6 absolutely 20:15 47:24 absorb 30:14 absorbed 54:13 absorption 6:4,13 7:5 accept 21:2 accident 33:7,9 accurate 11:6 65:14 achievement 63:22 acknowledges 48:18 acl 63:25 64:2 acne 50:21 acneform 50:9,23 act 18:11 action 21:6,8 67:18 activity 62:22 66:2 added 28:7 30:24 34:14 addition 13:13 additional 34:14 additionally 23:6 admission 22:23 26:2 42:15 53:3 admit 15:17 38:21 52:17 admitted 10:2 16:5 29:9,10 36:13 39:6 42:17 43:4 52:18 53:9 ad|) 25:19 agencies 13:20 ago 1:4,5 2:11 21:23 40:15 49:2 agree 35:18 38:16 agreed 16:23 18:14 ahead 50:16 allow 29:7 alternates 44:9,11 Papageorge, William P.E. (fmr Mons MgrOcc Hlth) in G. BROWN (3) WATER PCB-SD0000015711 [altogether - buy] altogether arises available black 16:19 18:23 65:11 49:21 15:11 amended arney ave blacked 57:19 18:19 21:24 14:12 american aro avoid ble 11:9 46:3 21:10 30:5,6,7 50:3 40:13 amount 56:24 aroclar 45:24 46:4 avoided 44:14 54:14 bloomington 23:5 24:21,24 26:12,25 amounts aroclor avoiding 27:7 28:2,3,5 30:22,23 58:4 24:18 37:8 39:7,9,11 40:3 21:11 31:22 36:23 45:10 analysis 45:3 56:12 58:4 award blowup 64:5 aroclors 63:3,22 29:11,1843:11 47:8 animal 4:9 40:20 44:20 46:8 63:24 aware bodily 1:14 2:25 4:2,14 5:3,9 8:14 64:4 64:20____________________ 50:9,20 59:25 60:10,15 animals 2:17 4:18 6:3 7:23 announce 16:17 announced 18:21,25 announcement 16:24 67:24 ansi 49:20 answer 13:21 19:22 20:5 27:4,5 49:16,18 51:1 53:22 56:8 57:20 65:21 67:5,10 answered 67:9 an't 35:16 an|) 34:11 anto 8:5 anytime 60:3 apart 61:15 appear 22:20 47:6 appeared 27:6 30:21 38:1 appears 23:11 applied 45:18 approach 58:21 61:8 63:1,4 approximately 27:25 56:3 april 13:6 arrive 63:17 article 62:10,11 aside 10:6 askarel 45:3,18,25,25 46:1 askarels 44:20 46:9 asked 1:5 4:5 9:9 49:1 57:14 66:13 asking 54:23 60:5 asociates 3:10 assigneb 20:24 assistance 48:9,19 associates 3:18 59:24 associa|) 3:22 assuming 34:3 afj 34:20 attention 66:16 august 17:19 aul 63:21 aused 64:21 authorize 3:14 authorized 3:20 b bold back 22:12 50:14 60:9 67:19 35:4 book ban 17:10,14,23 19:11 61:21,21 1:19,25 2:7,12,20 9:5 10:6 13:9 14:1 21:21 23:10 25:8 banned 18:2,5 62:8 banning 25:15 33:15 35:2 52:10 booklet 21:24 18:12 based bottom 10:17 41:21 42:2 58:3 36:15 63:18 66:19 batch 59:24 break 55:5 67:21 breathe bates 54:4,19 54:10 breathing bearing 34:23 behalf 30:6 brochure 41:16,24 42:7,9 43:18 46:7 62:19 believe 46:17 48:6,8,16 49:4,7,21 49:23 52:6 54:7,20 8:179:6 19:1641:1 49:1 63:10 65:9 brochures 40:9,19,23 41:2,6,8,12,15 bench 50:7,19 51:3,16 52:19 58:22,23 61:8,10 63:2,7 benfi 15:1 broke 12:4 brought best 21:5 49:3 54:24 1:6 60:10 brown better 39:19 1:1 bulletin big 35:4 binghamton 58:20 biodegradable 53:18 bulletins 40:19 51:24 burn 58:10,11 56:19 burning biphenyl 56:15 58:12 business biphenyls 11:1063:23 18:22 19:1 58:4 59:10,17 buy bip 41:11 64:4 Papageorge, William P.E. (fmr Mons MgrOcc Hlth) in G. BROWN (3) WATER PCB-SD0000015712 [Cadillac - court] c cash Cadillac 63:3,21 59:11,11 caused call 64:25 55:3 centigrade called 45:7,11,13 1:7 2:3 3:10 certain calling 25:3 33:14 36:11 41:19 20:3 48:19 51:24 52:3 calls certainly 19:21 60:21 32:22 47:24 49:21 55:6,7 canvass 58:15,18 44:16 certainty capacitor 27:3 45:5,19 46:2 58:16 cetera capacitors 38:12 16:11 46:10 59:5 ch car 15:1 33:6 chalk care 16:15 38:5 chamber carney 45:17,18 1:1,3,23 2:3,6 8:4,11,12,19 chamber 8:23 9:4,14 10:4,6,14,16,22 45:20 11:4,6,7 12:7,11,14,18,20 chance 13:23 14:1,4,8 15:4,6,21 29:13 30:13 16:8 18:7,17 19:10,14,16 chances 19:25 20:1,4,8,18 22:12,16 21:4 22:18,22 23:18,22 24:2,13 change 24:15 26:1,7,22 27:10,14 21:3 27:17,23 29:11,15,18 30:1 changed 30:12,15,18 31:3,8,18 33:3 44:19 33:20,23 34:9,16,19 35:1 charge 35:13,20 36:3,16 37:12,18 27:11 37:21 38:4,9,23 39:1,7 40:6 check 40:12,17 42:14,22,25 43:17 5:17 33:25 41:20 44:1,4,10,24 46:22 47:2,15 chemical 47:18 48:2,5 49:13,17,23 20:12,19 66:19 50:3,15,22,24 51:3,22 52:9 chemicals 52:12,14,16,18 53:1,4,8,12 11:11,14,1632:11,12,14 53:15 54:19,22 55:4 56:22 64:2 57:11,14,17 58:21 59:13,19 chloracne 60:4,19,21 61:2,8 63:1,5 51:12 65:18,23 66:24 67:6 chlorinated carn|) 63:24 64:4 65:9 43:7 choke cars 66:11,19 31:12,13,17,18,19,20 32:7 choked 32:10,10,11,18,21 33:4,6 66:6 44:16 clarified carter 31:5 28:9 clarify case 37:22 26:17 36:10 55:3,9 67:23 cleanliness cases 46:13 11:22 46:14 clear 39:3 clearly 9:1526:7,11 clients 38:18 climbed 32:22 close 44:11 67:1 closed 17:24 19:7 clothes 44:15,20 clothing 30:10 44:18 cm 53:19 collection 40:20 company 3:10 54:1 compared 11:15 comparing 55:2 compound 67:8 concentrations 54:11 concern 39:8 64:25 65:10,13,16 66:15,17,22 concerned 38:12 concerns 37:13 concern^ 38:4 conference 15:1 58:23 61:10 63:7 confirmed 34:20 confusion 18:1847:19 congress 61:13 connected 10:3 47:23 66:4 connections 32:23 consider 47:25 contact 21:10,11 30:7,7,8,9 44:14 50:4,9,20 54:14 contain 37:4 39:21 40:3 41:2 49:23 50:8,19 51:4 contained 1:25 31:11 containing 25:21 contains 35:7 contaminants 34:17 continue 1:2 15:8 67:22 continuing 16:4 continue 16:11 contributions 48:16,19 control 18:11 66:11 convey 56:18 copies 3:5 10:11 51:1552:1,3 copy 10:11 12:8 19:15 37:15,25 38:15 39:19 40:10 52:12 corner 47:9 corporate 64:15 corporation 36:18 53:17 correct 1:8 11:4 17:4,5 19:1231:9 46:19 56:20 58:7,8,12 62:13,18 correct.fi 19:13 correctly 44:21,23 45:22 46:15 cofi 37:2 counsel 9:17 18:12 country 45:12 58:14,17 59:1 couple 1:3,5 10:19 11:1323:22 24:2 course 20:24 41:9 58:13 court 1:1,22 2:1,58:10,18,20 9:2 9:12,17,25 10:13,21,24 Papageorge, William P.E. (fmr Mons MgrOcc Hlth) in G. BROWN (3) WATER PCB-SD0000015713 [court - eruption] court (cont.) dated deter effect 11:2 12:13,17 13:25 14:3,7 2:20 3:23,25 4:11 5:13 6:7 64:16 11:22 19:12 14:13,18,21,24 15:4,8,13 6:15,17,19,25 7:13,16,25 determining effective 15:17 16:1 18:14 19:24 11:3 23:7 24:9,9 29:2,3 67:12 17:6,12 18:2 20:2,6,14,16 21:22 22:11 36:6,7 42:1 46:18 49:9 de|) effects 22:15,17,24 23:8,15,24 52:25 21:7 41:7 4:18,1851:6 24:6,11,14 26:3,6,16,20 dated [j different effluents 27:5,13,15,21 29:9,17 7:20 4:11 6:3 38:2 64:18 63:9 30:16 31:5,17 33:2 34:7,11 dates disagrees effort 35:14,18 36:5,13 37:11,14 4:12 5:7,8 16:9 23:23 34:8 67:3 66:1 37:19 38:6,15,21,24 39:5 35:25 36:9 discharges efforts 40:11 42:13,17,24 43:2,4 day 64:8 63:15,17,23 64:3 43:16 44:9 47:1,12,22 48:3 20:21,22,22 21:2,2 discuss either 49:11,15,18 51:1,21 52:8 days 55:9 67:23 37:12 38:12 52:13,15,22 53:1,7,9 55:6,7 1:4,4,5 2:11 21:23 40:15 ditional electric 56:1,6 57:19 58:24 59:2,15 49:2 25:19 36:18 48:21 53:17 61:25 59:20 60:11,20,23 61:5,11 december docfi 62:1 63:4,6 65:21,24 67:3,10,20 5:22 7:14 65:20 48:10 electrical cover decision document 62:20 64:11 8:10,13 32:9 5:18 10:8 47:6 48:13 49:3,9 eliminate covered defendant 49:19 52:24 53:5,5,12,21 18:18 22:7 59:15 29:19 53:23 54:1 57:25 els covers defendant's documents 40:3 9:10 2:7,8 3:9,18,23 15:20 16:2 2:12,15,16,19 21:22 23:19 employee crucial 22:7 36:4 40:15 42:3 47:16 63:14 26:17,19 degree do|) enacted C[J 45:4,11 67:8 18:11,20,21 18:19 23:19 35:16 64:21 degrees dr encourage 66:7 45:6,7,12,13,14 2:20,23 4:6 9:7 10:5 11:1 20:10 curious delete 23:19 43:23 47:5,15 48:20 english 59:25 16:4 draining 38:15 CUSfl deletions 45:17 entering 50:18 16:6 drinker 45:18 customer delivered 1:8 2:20,23 3:12,13 8:24 entire 50:7 31:19 59:23 12:1 14:8 25:21 customers delivering drugs entitled 16:1831:1641:9 54:2,2 52:3 11:14 53:18 57:4 64:10,11,11 65:4 demonstrateed drum environment customer's 46:11 31:8,10 38:1 13:1766:1867:13 33:7 deposition drums environmental cut 1:24 9:7 23:20 47:20 19:18 26:24 28:3 30:22 12:25 25:2,9,16,20,22,24 56:5 describe 37:1,8 39:17 28:6 29:6 30:24 33:15 34:4 d 2:14,16 40:17,20 46:1 57:2 df> d47 64:22,23 33:23 described dakin 43:21,21,23 47:5,15,25 damage 64:21,23 9:20 27:12 describing 21:17 desk data 1:21 48:19 date despite 66:22 5:23 6:21 16:9,13,21 17:1,6 17:12 18:2 23:10,12 25:3,5 detail 34:21 26:5,10,18 27:2,21 36:11 41:25 49:3,7,14,22 details 59:2 47:17 earlier 53:13 early 66:1 easy 66:8 ed 38:4 editions 40:21 e 34:12,15,17 40:4 64:20,23 64:24 65:13 66:15 epa 18:1061:1862:1 63:9,17 epa's 64:7,8,16 equipment 54:16 66:2 erase 15:10 erased 15:11 eruption 50:10,21,23,25 Papageorge, William P.E. (fmr Mons MgrOcc Hlth) in G. BROWN (3) WATER PCB-SD0000015714 [es - given] es exhibits files forgot 19:3 1:24 2:7,7,9,9,10,10 4:4 5:2 43:19 46:18,21 47:3,14,21 57:21 estimate 5:2,2 9:4,21 12:12,18 13:24 filling forgotten 49:3,6 14:4,10,14 16:7 21:23 22:2 46:10 49:2 estimated 22:7,23,25 23:3,5,14 33:14 final form 49:14 33:23 34:3 41:1 42:17 51:8 40:7 43:9 19:24 20:3 50:22 60:20 et 51:11 52:11 59:23 finally 67:6,9 38:12 experience 17:23 62:8 former everybody 20:11,1921:6,15 find 64:5 18:13 30:2,16 44:8 expert 9:23 16:15 23:10 forth evidence 46:25 fine 61:21 8:5 9:21 10:2 13:24 16:5 explain 9:14 18:17 31:6 38:21 53:6 fought 29:10 33:19 35:17 36:4 67:4 67:20 62:1 38:19 42:12,20 43:3 52:21 explain^ finish found 52:23 53:10 58:4 60:7,12 37:20 47:12 17:1 19:2 45:2 48:12 60:22 explosions finished foundation evolved 16:13 10:14 47:13 54:23 23:16,25 27:16 35:14,19 51:4 exposed fire 36:1547:1,1351:20 exact 26:19 38:18 46:1 foundational 26:18 exposure fires 24:8 examination 44:7,13,24 45:21 51:12 16:12 58:14,16,25 four 56:22 exposures first 2:10 49:2,23 65:15,19 67:7 examined 50:4 1:23 2:195:13 13:4 16:9 fourth 10:7 extremely 20:24 38:22 39:5,13 40:14 54:5 example 11:23 40:25,25 41:24 56:11 64:19 fumes 6:1,5 36:11 ey 64:20 65:10,10,16 66:15 54:10 examples 12:22 22:3 43:7 60:15 eye fit* 38:23 functional 58:6 excellent 7:9 30:9 five furnished 64:5 eyes 49:23 56:3 3:5 excess 27:19 30:7 flow further 54:11 f excessive 51:12 fact 24:23 47:25 66:21,22 excuse 18:1050:1351:1964:21 factory 29:4 executed fahrenheit 63:15 exercise 46:14 45:6,12,14 familiar 9:15 35:20 exhaust 45:17 exhibit 2:8,9,21 3:9,18,23 5:16,18 famous 58:19 far 16:1 35:18 38:4,12 47:13 5:22,24 6:5,7,12,15,17,19 47:22,23 6:25 7:16,19,25 8:2,9,25 10:8,12,23 12:3,5,9,11 14:16 15:6,10,18,20 22:7 23:11 24:15 26:2,24 29:7 february 3:25 5:13 13:4 fed 6:9 29:12,19 30:14 33:21 35:1 fedfi 35:8,17 36:4 37:5,6 39:5,7 40:7 41:1,1542:1843:10 6:9 feeding 43:12,14 44:2 48:5 52:5,6 52:10,21 53:9,16 57:9 58:1 7:2,3 file 62:24 63:20 47:24 66:6 fluid 30:10 32:1 53:19 fluids 44:15 46:2,12 58:6 flush 30:9 focus 10:10 follow 5:7 followed 11:25 61:15 following 22:25 23:3,4 30:9 45:16 48:20 foods 11:14 force 16:10 forestall 62:20 63:11 forestalling 64:7 13:21 21:3 26:3 27:15 38:24 55:4 g garments 44:18 gas 59:11 general 61:25 generally 2:14 8:14 18:12 37:13,20 40:17 generic 46:1 gentlemen 56:2 67:21 getting 19:1 63:21 66:2 5:6,7,8 9:17 10:11 25:5 26:10 29:13 33:8 49:3,6,14 52:14 54:25 given 41:8,12 Papageorge, William P.E. (fmr Mons MgrOcc Hlth) in G. BROWN (3) WATER PCB-SD0000015715 [glasses - installation] glasses 44:17 glenn 1:1 gloves 44:17 go 2:19 4:4 5:8 9:21 14:21 15:12,19 21:24 24:2,4 31:14 33:16 34:21 41:14 44:6 50:15 56:2 59:17 64:18 goggles 44:17 going 9:7 16:8,25 24:4 43:7,8,11 49:16 51:8 52:17 53:23 61:2 62:24 63:20 65:18,21 67:6,14,24 goifj 33:20 gold 36:17 good 43:7 44:4 46:13 64:15 government 3:6 4:24 12:5,24 13:15,20 16:10,18,24 18:25 19:11 grade 54:25 greatfully 48:18 group 3:8 5:1 12:3,5 13:12 14:8 15:1023:1440:7 52:11 59:23 groupings 2:18,19 guess 36:8 41:21 46:6 guidance 48:19___________________ h half 19:11 hand 1:19 47:9 handle 21:1746:11 handles 21:2 handling 20:21 39:22,25 41:3,6 49:23 50:7,18 53:18 54:8 handwriting 14:10 43:14,18 46:23,24 handwritten housekeeping incident 43:21 46:13 58:20 happened inclfi 62:6 ibt 13:15 happy 13:21 1:1059:760:1,17,25 61:7 idea include 22:13 60:1,5 hard 32:20 41:10 56:18 included 38:16 harm 21:6 identification 13:17 identified 6:5 includes 15:19 40:21 harvard 2:23 hat 17:4 23:1 59:22 identifies 9:8,14 identify increase 65:2 increased 65:7 66:21 ha|) 8:8 14:11 15:23 37:6 41:15 increasing 8:24 38:13 have|) 43:13,17 53:15 ii 65:17 increase 25:8 hazard 40:9 ike 65:5 index 46:12 head 65:16 12:3 illegible 23:3 54:20 indicate 13:1943:18 headquarters 65:11 immediately 14:17 indicated 4:20 12:21 hear 20:4 heard impact 21:8 implementation indicates 35:10 47:20 indication 39:10 58:13,16 59:1 66:4 hearings 61:14 62:20 63:11 64:16 imply 66:18 industrial 61:19,23 62:7,9 63:8 heat 50:4 11:1057:15 important 21:15,18 36:9 11:15 industry 20:12,19 46:9 61:25 62:20 heated 45:19 impregnated 44:15 industry's 46:11 held 15:1 58:23 61:10 63:7 impregnating 45:20 46:10 inerteen 34:24 35:4 36:17 53:18,20 help impregnation 54:10,13 19:20 57:25 62:23 63:17 high 45:6 51:4 45:16 impregnations 45:5 information 12:23 13:15 19:19 20:9,20 21:5,5 33:5,8 39:22,25 41:2 highly 11:11 hold 26:20 improper 36:12 inaudiable 54:16 49:23 66:4 informing 55:1 ingestion home inaudible 51:5 11:16 honor 8:4 9:19 12:7 13:23 15:2 23:18 26:1,7,22 27:10,14 2:2 7:3 9:16 10:4 15:3,5,25 16:19 19:23 20:3,6,14,17 23:25 24:5,6,13 26:15 29:21 30:4 31:21 33:21 ingredients 37:4 inhaled 45:4 29:11 36:3 37:18 39:19 34:2,8,10 35:19 36:8 39:2,3 inhilation 40:9 42:22 47:18 51:18 53:4 56:4,5 58:21 59:13,19 42:2,21 43:14 46:9 48:3 49:12 51:21 52:6,8 54:18 7:11 insignificant 60:4,19 61:2,9 63:1,19 66:24 67:17 55:7 inaudi|) 56:24 installation hot 45:3,9 40:13 53:19 Papageorge, William P.E. (fmr Mons MgrOcc Hlth) in G. BROWN (3) WATER PCB-SD0000015716 [instance - maintenance] instance jury label (cont.) letters (cont.) 64:5 10:17 18:13,1629:24 30:13 36:25 37:1,7 39:3,13,16,21 13:19 35:4 instances 38:10 39:10 40:1 43:12 labeled level 26:9 47:24 56:17 58:10 67:2 40:8 34:21 instruction k labeling like)) 18:15,16 kelly 27:11 32:24 19:22 instructions 10:5 24:1 26:9 labels limit 53:18 insulating 53:19 kelly's 9:7 23:19 kept 19:18,19,20,20 20:9 21:16 64:8 21:20 22:3 23:6,12 25:3,8,9 line 25:15,18,20,24 27:6 29:3 30:4 41:21 46:13 interest 39:2 interested 38:9 39:3 41:10 65:16 kind 12:4 20:22 21:10 32:24 39:25 40:2 46:5 53:25 66:2 30:21 32:6,9,18,20,21 33:4 34:4,22 36:7 38:10 laboratories 5:4 lines 32:23 ling 26:21 internal 67:2 laboratory listen 34:19 interpret knew 48:23 7:19 59:7 labs 16:2 52:15 56:8 listing 66:10 interval know 11:8 14:1720:1324:9,11 8:22 59:25 lab|) 57:3 lists 45:21 65:25 intervening 65:15 26:18 27:2,9,17 29:3,6 31:7 37:15,21 39:1 42:24 43:1 43:22 46:20 47:4,5,15 49:9 40:3 lack 51:20 48:20 little 34:1 55:5 in|) 13:24 46:13 49:16 51:22 53:21,22,23 56:6 57:2,7,8,9 59:14,18 ladies 56:2 67:20 liver 4:18 introduction 48:13 investigating 60:8,24 62:3,4,6,16,22 66:10 67:8 knowledge language 28:4 30:3,21 languages long 30:18 34:7 37:14 look 13:10 involved 47:23 62:17 known 38:1,3,10 39:2,22 late 5:1 9:3 10:12 12:3 21:20 23:11 24:15 29:14 30:18 33:6 62:9,12,15 63:16 irritation 7:7,9 67:16 knows 18:13,1327:1647:13 9:2 launder 30:10 35:1 36:6 37:5 38:24 43:10 44:5 48:5 49:2 54:4 looked issue 13:1 kotos ke 1:5,20 8:7,25 9:19 10:8,17 laundered 44:19 15:22 30:16 looking italian 38:11 10:25 11:3,5,7,20 12:9 14:9 14:14,20,22,25 15:2,8,9,16 law 17:3,6 18:1,20,21 47:11 49:7 loo|) 16:7 18:8,9,16 19:8,21 20:6 lawyers 42:23 46:22 48:1 it's|3 54:5________________ 20:13,15 21:22 22:9,25 23:9,21 24:7 26:5,14,17 27:1,8 29:1,13,16,24 30:13 60:14 lay 23:16,25 27:15 35:14 47:1 lope 48:20 losing _____________ j________ january 7:17 17:2,7,9,15 18:2 42:1 42:5 46:18 49:21 31:1,7 33:1,18,22 34:6 35:12,16 36:6 37:9,16 38:17,1842:11,16,1943:3 43:5,15 44:3,22 46:20,24 laying 35:18 lead 50:9,20 51:5 1:4 lot 12:1521:11 26:1559:22 60:14 job 47:10 49:8,12,25 50:13 learned 20:24 65:12 journals 3:3 judge 51:18 52:17,20,24 53:11,14 54:18,21 55:5,7 56:1,4 57:1360:9 61:1263:19 67:17____________________ 64:19 leave 15:24 led 27:20 38:12 12:3 lunch 67:21 m 1:20 9:6 15:21 18:17 19:14 I 34:20 35:12 36:9 37:9 40:9 label 47:11 52:21 july 6:23 19:6 june 20:9,10,20,22,23,25 21:19 24:17 25:1,19,22 26:11 27:2 28:2,5 29:2,4 34:4 35:2,4,4,21,23,24 36:16,20 4:12 5:246:7,15,17,197:16 9:16 left 10:1331:11 32:13 letter 10:25 13:4 65:23 letters 12:5,21,22 13:3,8,9,12,15 magazine 62:10 mail 52:2 maintenance 53:20 Papageorge, William P.E. (fmr Mons MgrOcc Hlth) in G. BROWN (3) WATER PCB-SD0000015717 [majorip - overall] majorip 24:23 making 16:19,25 66:25 67:2 management 16:17 manager 62:14 man's 36:7 manufacture 17:10,24 18:2,5,12 19:5 25:13 manufacturing 17:18 march 6:25 11:3 marked 50:8,19 material 11:1320:21 31:1033:5 37:2,3 41:10 52:1 65:4 67:14 materials 21:2 64:10 matter 24:8 29:4 64:19 maximum 54:11 mean 58:11 meaning 21:11 medical 21:1241:7 meetings 21:16,17,18 memos 3419 mention 4:17 mentioned 1:10 9:5,18 23:8 48:22 message 25:21 38:2 million 56:23 57:10,23 58:5,5,6,7 66:23,25 mind 20:13 minute 2:1 14:23 mishandled 11:17 misleading 57:17 67:1 mistake need (cont.) occasional 33:17 34:1 34:20 62:10 mists neighbor occurs 30:7 64:15 30:8 misused new October 11:17 21:5 25:20 58:20 5:15,19,20 7:20 14:19 17:3 mixture newspaper 18:20 37:4 62:10 offer money ng 8:4 13:23 36:3 56:24 57:6 67:2 33:20 offering monsanto nine 9:5 1:6,7,13 3:13,15,21 4:5 5:3 2:9 ofp 12:23 13:9,21 16:10,17,18 notations 28:6 66:25 16:23 17:17,17 18:21,22,25 14:10,12 15:11,14,22 oh 19:4,18 20:9,23 22:4 32:12 note 1:183:1221:1829:16 32:13,17 34:22 35:23,23 29:1 33:22 35:13 36:21 37:7 42:3,7,20 46:4,7 notebook okay 48:6,15,18 50:7,18 51:24 22:21 60:6 3:17 5:18 10:24 15:21 52:24 53:5 54:25 56:25 noted 16:15,16 30:3,12 36:25 57:6 60:11,25 61:6 62:14 16:7 20:6 37:5,24 40:6,10 43:7,16 62:19 63:14,22 64:14 66:1 noteworthy 44:4,12 46:6 47:2 49:17 66:14 63:23 64:3 52:16 53:15 61:18 67:25 monsanto's noth olliges 13:16 20:25 32:14 33:4 62:17 55:11 40:20 41:7 57:3 58:4 60:14 noticed ones 63:1664:1065:11,1667:18 7:2,22 9:2 13:25 14:1,3,4 15:13,13 monsp november 23:8,9 8:5 3:23 7:25 open move n't 17:10,15,18 18:3 22:22 26:2 27:8 33:1 37:9 67:8 opened 42:15 58:9 59:16 nth 27:24 28:6 30:23 moving 59:3 opening 8:20,22,23 52:22 53:1 number 45:19 mr.p 29:2 57:24 opinion 30:20 numbers 21:19 mp 9:17 14:5 33:21 54:19 oral 58:19 n name 34:24 43:21 47:6 48:22 named 15:13 natural 1114 naudible 48:1 nd 34:20 ne 38:23 necessarily 20:11 necessary 1612 66 2 need 6 6 65:25 66:25 51:5 order 2213 20 organized 13:3 object ou 27:1 57:17 61:2 65:18 67:6 12:22 67:9 ough objection 16:3 9:1 14:9,12 20:3,6 24:3,5 ought 26:14 29:1 34:6 36:8,14 15:25 46:20 51:20 59:13,14,19,21 ouldn't objections 66:7 22:24 23:13,16,17 26:4 outside 36:5 44:1 31:20,24 32:2 obliteratd ovens 15:14 45:9 observations overall 64:6 56:25 57:1 9:3 14:25 30:19 33:25 Papageorge, William P.E. (fmr Mons MgrOcc Hlth) in G. BROWN (3) WATER PCB-SD0000015718 [overed - pfj] overed pcbs played principally 23:19 1:162:163:1 4:2,145:11 3:15 9:7 64:6 61:25 overruled 6:9,98:8,15 11:16 13:10,14 please print 27:5,13,13 34:7 65:24 13:17 16:11,19,25 17:10,15 15:8 30:14 35:12 44:9 36:17 67:10 17:24 18:3,5,12 19:5 23:5 pleasure printed P 24:23 25:12 26:24 27:22 38:17 25:20,23 51:24 page 31:1,9,11,13,19 34:24 37:4 plement prior 10:10,22 13:3 14:19 23:3 37:10,20,22,25 38:22 39:5 39:17 50:9,20 51:13 54:8 21:16 55:1 57:6 58:10 61:1 62:7 point 18:19 25:16 26:8,25 27:22 29:4 39:6,23 40:14 43:10 44:5 44:13,25 47:9 48:13 54:5 63:9 64:8,21 65:2,8,17 66:6 9:10 16:16 26:1 27:14 32:6 probably 66:12,18 67:13 60:2 49:1 50:15 52:9,14 54:20 57:10 58:1,3 63:20 pcfj pointed problem pageorge 1:3 56:23 peak 20:23 34:2 polychlorinated 8:7 15:23 33:22 37:17 42:10 44:10 66:15 67:13 pages 57:5,5 11:10 56:15 63:23 64:4 problems 49:23 ped pool 44:11 67:15 pagefj 39:18 64:2,4 procedures 10:9 people popped 13:16 papageorge 13:10 19:20 20:1026:19 65:16 proceed 1:1 2:11 10:7,11 16:9 18:19 percent pors 16:7 24:1,1229:17 36:15 19:17 26:23 27:18,24 30:20 56:15 45:3 43:2 48:4 56:2,3 58:24 40:14 50:6,17 51:19 54:23 period portion 61:11 56:7 25:1039:1645:5 61:14 48:14,15 product paragraph personal Portuguese 9:20,23 21:17 23:1 37:7 10:17,19 12:1 46:13 38:11 41:2 57:3 66:5 paragraphs personally possibility production 46:7 47:5 48:23,25 52:2 60:13 51:12 11:22 65:2,6,8 pardon 27:1 pes 8:15 potential 54:2 products 11:16 20:25 21:1 22:4 part phenyls pounds 34:23 36:22 57:4 64:1,5,21 11:21 23:19 48:4 partial 64:4 pick 58:5 practical profit 57:15 66:25,25 23:25 participate 61:23 62:19 63:8 67:18 piece 16:1521:5 29:4 practice 51:24 profitability 56:21 profits particular pipe precautions 57:12 10:9 35:21 32:23 11:24 46:14 54:8 program particularly 63:20,22 64:3 piped 32:4 precisely 15:16 32:16,1765:13 prolonged partment placed precluded 30:6,7 44:14 45:5 41:7 22:4 26:24 37:1 64:9 prominent passed plaintiffs preference 64:7 17:4 18:1 61:13 path 19:1726:12 plaintiff's 38:14 preparation promulgation 64:7 1:3 10:8,22 48:10 pronounce paul 62:14,25 63:8 plan 67:18 prepared 29:15 34:22 35:24 36:21 63:24 proper pbs 53:19 pcb plant 26:9,13,25 27:11,20,24 28:6 30:22,23 31:2,11,22 37:2 41:5 49:10,22 presence 64:24 13:17 proposed 64:9 9:8,23 12:23,25 15:23 18:22 19:1 22:4 24:20 27:7 31:24 32:2,4 33:7 45:10 plants pretty 12:14 provide 33:5 28:3 32:10 34:17,23 40:23 41:6 51:4 56:11,13,18,22 57:7,22 58:20 65:6 11:14 31:14 32:13,21 36:23 prevent plasticizers 21:6 45:18 58:6 principal providing 12:23 32:24 63:21 Papageorge, William P.E. (fmr Mons MgrOcc Hlth) in G. BROWN (3) WATER PCB-SD0000015719 [publication - safe] publication read regulation^ 52:25 1:24 9:6 10:17,20,20 11:7,8 63:12 published 11:8,12,12,17,20,23,23,25 relate 3:3 12:12,15 14:2,3,5,16 19:18 23:5 pumped 19:20 20:10,23 21:3,4 22:6 relates 32:1 30:3 33:16,18,20,21 35:16 59:14 purchased 37:10,16 38:16,20 41:24 relating 21:1 43:5,8,8 44:6,8,21,22 45:22 67:12 pure 46:15 48:15 50:14 62:10,24 relative 29:1 34:6 63:20 11:15 purpose readable relevance 33:4 38:7,8,16 59:21 pursuant reading rely 18:10,1023:16 58:3 36:7 60:25 61:6 put real remaining 10:6 18:14 20:9 25:2,23 23:23 19:9 27:12 30:21 32:7,9,17,20 really remember 34:17 36:22 38:19 53:8 38:5 53:22 1:9,12 10:16 11:9 57:24 60:12 reason 61:16 puts 32:24 60:7,8,23,24 remove 67:7 recall 30:8 putting 11:5 57:1 65:7 removed 19:19 20:8,19 33:4 receive 44:16 q 51:15 52:4 receives repeated 50:9,20 51:5 4'8 question 63:3 recollection rephrase 20:2 818 1010 19 25 26 23 27:4 48:4 50:14 53:22 11:6 recommendation replaced 28:9 55:11 54:22 56:13 57:11,14,18,21 58:19 65:22 66:9,13 67:4,7 67:8,11 16:17,24 34:16 recommended 11:25 18:22 replacement 37:15 39:11 report questions 1:5 10:17 13:21 23:23 31:4 record 5:8 7:20 1:24 2:6 9:6,25 10:17 12:12 reporter 54:23 55:4 56:8,8 quick 14:5 21:21 22:6 33:13 reference 14:25 50:17,23,25 reports 23:23 49:19 2:17 4:17 8:5 59:22,24 quite 66:10 referred 15:1853:13 referring representative 12:22 22:3 representatives r 8:21 52:3 rabbits refers represents 6:3,4,13 7:5,7,9,11 48:9,9 13:11 58:7 railroad refined request 31:17,18,20,21 26:10 40:15 ran regard required 59:11 20:19 23:23 31:12 54:25 44:18 range regarding researcher 45:11 66:1 43:24 rare regulate researchers 11:23 63:9 12:24 13:14 rat regulation reserve 6:2 7:3 64:8 9:22 14:16 23:21,24 29:8 rats regulations resist 6:3,10 7:3 18:11 61:15 62:2,21 64:9 58:12 64:16 resistant 46:2 respect 26:18 respected 57:3 respirator 45:20 respond 23:15 response 26:6 responsible 64:15 rest 9:21 11:24 results 2:17 retired 61:3 review 2:1221:23 40:15 reviewed 12:21 revised 42:5 right 1:1 8:10,25 14:13 19:10 22:11 23:9 24:11 26:3 30:1531:1040:11 45:16 47:9 53:7 56:1,7,9 58:2,25 59:12 63:6 65:13 66:23 risks 16:12 role 3:15 64:7 room 45:19 roughly 59:1 rporation 37:2 ruling 9:12,22 10:2 14:16 23:24 52:20 run 12:19 runs 13:6 ruth 26:21 s safe 39:21,25 41:3,6 46:8 49:23 50:6,18 Papageorge, William P.E. (fmr Mons MgrOcc Hlth) in G. BROWN (3) WATER PCB-SD0000015720 [safely - summer] safely September sold 21:17 2:20 16:22 23:5 57:4 67:14,15 safety sequence somebody's 21:16 44:17 54:7 16:9 66:20 sales set somewhat 39:18 56:22,23,25 57:1,6,7 65:12 38:16 57:12,13,16,19,22 58:7 seven soon 65:17 66:21 17:20 38:1 39:21,22 16:25 19:1 salesman sexes sorry 52:2 7:23 5:20 22:17 25:6 35:13 samples shipments sought 3:16 12:24 13:10,13 27:20 63:11 64:15 sampling shipped Spanish 44:16 26:8 27:7 31:13 36:22 38:11 satisfactory short speak 46:8 45:21 36:14 38:11 save show special 26:15 34:7 43:12 44:9 52:23 44:18 saw 60:17 specific 19:1727:1932:1 showed 14:9 says 60:14 specifications 36:17 37:16 42:5 44:13,24 showing 37:3 50:3 54:13 63:22 38:10 44:1 speculate scale shown 60:5 54:23 24:8 40:1 47:8,25 speculation scattered significant 19:22 27:2 29:2 34:6 49:8 64:6 56:24 57:2 60:21 scientific simple speed 3:10,17,22 59:23 11:24 46:12 56:13 57:22 9:20 42:11,14 scientifically simply spelled 63:18 11:11 63:25 scientists sir sponsored 11:10 12:6 1:2 2:24 5:16 7:4 17:16 3:20 4:5 scribed 20:1 27:5 28:1 31:25 36:5 stack 21:7 40:2 43:25 55:2 56:2,10,14 13:8 second 57:1,20,24 58:24 59:8 60:2 stamp 23:3 37:10,20,21,25 39:6 60:13 61:11,22 62:3,5,22 54:4 39:22 45:8 54:20 63:13 64:13,17 65:25 66:8 stand section skin 36:14 41:5 44:25 50:7,18 6:4,13 7:5,7 21:10,11 30:8 standard seeing 30:8 44:7,13,14 50:3,10,24 35:7 49:20,20 20:22 50:25 54:14,14 standards seek skinny 63:18 65:5 40:12 standing seen skipping 18:10 30:16 10:1 start sending slim 12:9 39:13 13:13 21:4 started sent slope's 32:16 34:12,13 4:21,23 12:23 13:9,10,12 48:22 starts 24:20,24 26:25 28:3 30:22 smaller 12:11 30:4 39:17 65:23 38:7 state sentence soaked 15:4 11:8,12,21 44:7 30:10 stated sentences soap 18:13 10:1967:7 30:8 statement 25:20 34:12,15 statements 34:14 states 3:6 12:24 statute 19:1461:13,15 stayed 31:20 59:16 step 67:20 S[J 21:24 48:20 stick 25:23 stipulate 18:9 43:15 44:22 stipulated 49:25 stipulation 18:7 stop 16:19,25 17:14,17 19:4 20:23 45:8 67:17 stopped 25:13 66:14 stop|) 39:18 strike 27:8 33:1 37:9 48:3 studies 1:8,10,13,14 2:16,20,25,25 3:3,5,8,9,12,13,18 4:2,5,8 4:11,14,21 5:3,9 6:2,12,13 7:22 8:24 9:8,8,9 59:25 60:11,15,18,25 61:7 67:12 study 3:22,25 7:2 60:1 studying 12:25 subject 43:9 56:21 58:9 64:18 substance 18:11 substitute 17:1 19:2 56:12 suggested 46:14 suggests 54:16 summary 15:2 19:23 summer 34:10 35:25 Papageorge, William P.E. (fmr Mons MgrOcc Hlth) in G. BROWN (3) WATER PCB-SD0000015721 [supplied - ty|a] supplied 1:20 21:21 supply 3:15 66:19 supfi 21:16 sure 12:14 14:24 15:1923:13 24:14 26:16 41:20 57:11 58:2 suspicion 43:1 66:20 sustain 19:24 59:21 sustained 20:2,16 33:2 60:20 61:5 Swedish 11:9 swer 34:11 swimming 64:2 switch 51:8 symptoms 21:7,12 synthesis 64:6 system 29:4 systemic 51:6 t tab 41:17 taken 60:1 talk 21:1241:14 talked 16:6 56:21 talking 1:14 14:18 56:11 57:12 61:1 65:8 66:24 talks 4R-1 fi tank 31:12,13,17,18,19,20 32:7 32:10,11,18,20 33:4,6,6,9 4416 tanks 3210 1610 technology 66:3 tell things toured 23:10 25:1 27:3 36:25 9:20 38:19 42:11,14 43:8 31:23 43:13 56:17 think town telling 1:4,6 2:3 4:20 8:12,23 9:10 65:11 29:4 64:14 12:4,7,12,17,20 13:4 14:11 toxic temperatures 14:22 15:15,22,25 18:14 11:11,16,22 18:11 51:6 45:6 51:5 19:19 20:8 22:20 23:18 toxicity ten 25:6 26:9,10 27:4 30:1 31:3 1:13,142:34:8 11:1345:4 56:3 34:10,20 36:12 37:12 38:18 50:6,18 tends 39:10 40:7,8 41:17 44:25 toxicological 21:2 45:10 46:22 47:2 49:13 59:22 60:10,15 term 50:15 52:19 54:5 56:23 toxicology 46:5 58:12 59:14,16,20 60:4 65:19 41:2,5 62:15 terphenyls thinfi track 65:9 24:3 1:4 58:2 tes third tracks 3:22 52:10 54:5,5 31:23 test thirty trade 2:17 7:19 8:5 11:21 34:23 tested thos|) trademark 7:23 8:8 2:17 46:4 testified thought transformer 19:17 37:13 46:23 47:3 20:4 63:17 58:14,25 testimony thousands transformers 1:1 36:8 45:9,10 64:20 11:15 46:10 53:20 54:2,3 testing three treon 1:6 2:4 9:22 49:1 50:12 59:4 62:7 4:6,17,21 59:24 tests 65:25 trial 1:72:178:149:15 thrfj 1:1 29:19 th 16:3 true 1:13,24 4:19 5:4,15 6:21 thfi 11:11,1931:22 58:1065:14 7:8 9:8,17 10:17 11:2,11,20 36:10 37:11 60:15 truly 12:13 13:7 14:9,17 15:11 time 66:4 15:21 16:20 17:15 20:6,16 16:16 21:24 22:22 24:10 try 23:2,10 24:11 26:3 27:4,13 26:12,15 30:23 32:6 33:17 16:8 39:19 56:9 58:1 27:23 29:4,14 30:1,10 34:1,13 36:9 39:16 45:5,13 trying 31:12 32:8,17 33:2,11 34:3 60:2,22 61:14 63:19 64:10 56:17,18 35:4 36:19 39:8 40:23 42:2 66:17 tsca 43:16 44:1,10 45:11 46:5 time|) 17:3 51:3,14,24 53:1,12,21 54:15 55:7 56:4 57:6,15 3:1 title tj> 17:4 31:22 44:18 52:8 58:9 59:15,23 60:6,25 41:24 42:9 47:9 turn 61:21 62:7 63:3 65:15,24 titled 31:3 52:5 58:1,2 66:17 4:8 ty thank told 24:23 1:22 11:2 43:5 53:11 54:21 16:10 58:9 type 56:4 61:12 tom 15:23 24:20 27:7 that's|) 2:1 types 56:13 tomer 7:23 thereof 50:18 typical 47:25 tomorrow 20:21 thefi 67:25 tyfj 49:1561:11 top 8:15 thing 32:23 39:2 torn 41:17 Papageorge, William P.E. (fmr Mons MgrOcc Hlth) in G. BROWN (3) WATER PCB-SD0000015722 [u.s. - yfj] u vast u.s. 4:23 11:22 13:14 16:10 ude 13:15 umber 59:3 uments 48:10 understand 26:20 60:13 66:3 understandable 15:15 understanding 53:25 63:13 24:23 vap 45:3 ventilation 45:17 version 40:12 volatile 54:11 volume 10:13,15 37:10 40:9,10,25 volumes 40:8,18 w understood wait 21:7,14 9:10 22:9,9 united wann 3:6 12:24 28:9 55:11 universities want 12:25 13:14,20 8:10 9:13,22 10:7 14:21 university 17:1423:15,1631:5,7 2:23 35:1536:9,1041:11 42:12 unrealistic 44:3 52:21,25 56:12 63:4 64:8 64:18 unusual wanted 66:1 20:4 65:4 66:22 upper wants 47:8 43:6 67:8 ur warn 67:17 51:11 urge warning 26:14 22:3 25:2,9,16,24 26:23 urgency 28:7 29:6 31:2 34:17 40:4 21:13 50:8,20 51:4 use warnings 11:22,25 18:12 34:23 36:10 26:18 30:24 33:15 35:7 41:11 45:12 46:5,8 59:7 49:7 64:9 65:18 washed usedp 44:16 26:11 washing users 30:8 51:24 watched uses 27:19 31:23 17:10,15,18,24 18:3 19:7 water 67:14 30:9,9 V ways valuable 52:1 66:19 wayp vapor 3:12 4:9 7:11 wear vapors 45:20 30:6 44:25 45:18 50:4 51:4 wearing various 30:10 7:23 8:14 40:21 weekly 44:19 went worse 17:25 19:12 31:1,23 62:7 54:24 westinghouse wright 4:21 27:24 28:2 34:23 62:14,25 63:8,21 35:24 36:18,21,21,23 37:2 writing 41:12 43:24 46:21 47:14,16 39:4 47:19,21 48:9,17,21,23 wrong 51:15 52:4 53:5,17,21 54:1 5:17 52:23 54:7 55:1 62:1 wp westinghouse's 47:7 43:19 46:18 47:3 wep 31:3 we've 16:6 21:20 40:1 45:24 wheeler 11:1 wide 58:4 widely 64:6 willing 38:21 withdraw 15:9 withdrawing 15:6 withhold 9:12 witness 8:8 26:10 33:16 37:13,19 59:16 60:5 67:3 y yeah 5:188:12 12:18 15:6 22:12 29:16 31:15 42:24 60:23 year 17:11,12,25 19:11 57:5,6 58:5 years 11:21 17:20 20:1221:15 40:22 46:8 60:11 62:7 65:15,19,25 67:15 yellow 37:8 38:1 yesterday 1:20 12:4 14:6 21:22 yoa 67:17 york 58:20 younger 5:4 7:19 8:21 59:24 wm 1:1 12:22 19:3 word 21:9 35:4 46:1 63:24 66:11 wording 27:6 37:25 words 8:22 38:7,7 46:7 work 44:14 45:19 worked 26:12 worker 20:21 21:1,8 workers 32:21,22 44:18 workmen 45:20 46:12 works 16:16 world 58:4 66:12 worn 44:17 Papageorge, William P.E. (fmr Mons MgrOcc Hlth) in G. BROWN (3) WATER PCB-SD0000015723