Document g27wmkBxngeo2ZOeYXNYpR3Ke
6 m.<: i
IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
THE UNITED STATES OF AMERICA,
Plaintiff,
vs.
No. 78 C 1004
OUTBOARD MARINE CORPORATION AND MONSANTO COMPANY,
Defendants.
)
The deposition of WILLIAM B. PAPAGEORGE,
called by the Defendant Outboard Marine Corporation for
examination, pursuant to notice and agreement of counsel
and pursuant to the Rules of Civil Procedure for the
United States District Courts pertaining to the taking
of depositions, taken before Thea L. Urban, a Notary
Public in and for the County of Cook, State of Illinois,
and a Certified Shorthand Reporter of said State, at
the offices of Kirkland & Ellis, 200 East Randolph
Drive, 58th Floor Conference Room, Chicago, Illinois
60601, on the 27th day of August, A.D. 1981, commencing
at 9:00 o'clock a.m.
PRESENT:
MR. JAMES T. HYNES,
Deputy Chief, Civil Division;
MR. KEVIN E. SHARKEY,
Assistant United States Attorney,
(United States Attorney's Office
219 South Dearborn Street, Room 1486
Chicago, Illinois 60604),
"Thee !_ Urban
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PRESENT: (Continued)
MS. ELIZABETH STEIN,
(Pollution Control Section
Land & Natural Resources Division
Department of Justice
Washington, D.C. 20530),
'
appeared for the United States of America;
MR. MICHAEL A. POPE, (Phelan, Pope & John, Ltd.
30 North LaSalle Street Chicago, Illinois 60602),
and
MR. RICHARD J. KISSEL, (Martin, Craig, Chester & Sonnenschein
115 South LaSalle Street Chicago, Illinois 60603),
appeared for Outboard Marine Corporation;
MR. JAMES (Kirkland
200 East Chicago,
H. SCHINK, & Ellis Randolph Drive Illinois 60601),
appeared for Monsanto Company.
ALSO PRESENT:
MR. HUGH THOMAS, (Outboard Marine Corporation).
Cei't-ified
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INDEX
WITNESS ; WILLIAM B. PAPAGEORGE
By Mr. Pope
Direct Cross Redirect Recross 4
EXHI_BI_TS
Papageorge-OMC Deposition Exhibit
No . 1 No. 2 NO. 3 NO. 4 No. 5
Marked for ID 91
170 187 199 202
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WILLIAM
(Witness sworn.) B. PAPAGEORGE,
called as a witness herein, having been first duly
sworn, was examined and testified as follows:
DIRECT EXAMINATION
BY MR. POPE:
Q Would you state your name and spell your last
name for the court reporter, please.
A William B. Papageorge, P-a-p-a-g-e-o-r-g-e.
Q Mr. Papageorge, I'm going to be asking you some
questions. I want to make sure you understand all the
questions that I ask you, so if there is any uncertainty
in your mind, please feel free to have a question re
read or clarified.
A Thank you.
Q Why don't you tell us where you currently
reside .
A St. Louis, Missouri, the suburbs.
Q What is your homeaddress?
A 321 Pebble Valley Drive, St. Louis, Missouri
63141.
Q You are in the City proper then?
A No, sir.
Q This is a suburb? _____ _________ ________________________ _________________ _____
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A Suburb, County.
Q How long have you lived at that address?
A About 11 years, 12 years.
Q Where did you reside before
that?
A Anniston, Alabama.
Q What is your current occupation, Mr. Papageorge?
A I am employed with the Monsanto Company in
St. Louis and I currently am Director, Environmental
Operations for Monsanto Chemical Intermediates Company,
an operating unit of Monsanto.
Q Monsanto Chemical --
A Intermediates Company.
Q Is that a division or is that a separate
corporation?
A No, it is a division.
Q It is an operating division of the overall
company ?
A Yes, sir.
Q What does the Monsanto Chemical Intermediates
Company do?
A That part of Monsanto manufactures basic
chemicals. We call them building block chemicals for
use by other units within Monsanto for sale to the
marketplace.
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Q Has that division or operating company been
in effect under other names prior to it being called
Chemical Intermediates Company?
A Could you repeat the question?
Q Sure.
How long hjas that division been in
existence?
A It was formed as a unit in the Fall of 1976 .
Q Prior to the Fall of 1976, there was no
similar operating unit or was there?
.
A There was no similar unit, no.
Q Was there a significance to the term Inter
mediates Company?
A Yes. This refers to, it is Chemical Inter
mediates. In other words, they are not finished products.
They are intermediate chemicals in the process of
arriving at end products.
Q Is one of the basic purposes of the company
basic research, chemical research?
A NO.
Q Is it the formulation of new products or new
chemicals for other operating companies, divisions of
Monsanto?
A To me formulation implies blending, a mixing
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and the like. This is more actual manufacture.
Q And the products or substances that are manu
factured are all manufactured for other divisions of
Monsanto, is that correct?
A Correct.
r
Q Mr. Papageorge, would you describe for us what
you have done by way of, preparation for this deposition?
A In the past few weeks I have refreshed my
memory by looking over some old reports that I still have
in my possession, but more recently I have worked with
attorneys in reviewing documents which I am told were
already submitted as exhibits relating to this issue.
Q Referring to deposition exhibits?
A I believe that's it, yes.
.
Q Anything else?
A That's all.
Q These reports that you have in your possession,
would you describe them forme,please?
A They were really duplicates of much of what
I saw here the past few days; material that I mentioned
were offered as deposition exhibits, that type of material.
MR. POPE:
Mr. Schink, may we feel confident that
these reports that Mr. Papageorge has told me he has
reviewed in preparation for the deposition are duplicates
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of Monsanto documents that have already been produced?;
MR. SCHINK:
Yes.
BY MR. POPE:
Q The reports that you reviewed that you have in
your possession, do they relate to time periods?
.
A Yes.
d;
Q Beginning in 1970 or what time periods do they
relate to?
A Yes. I don't remember anything before 19 -
there might have been a very few before 1970, but most
of them were 1970 through 1975; the majority of them,
'70, '71.
Q Can you give me an approximation of the volume
that we are talking about?
A About three inches high or so, a stack of
paper about three inches deep. That is an estimate.
(Indicating.)
Q Would these reports be ones that you authored
as well as ones that other people authored?
A Yes.
Q Would they all have been, to the best of your
recollection, internal Monsanto documents?
A No. There were some documents that were not
Monsanto.
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Q Such as what? A I'm trying to remember. For example, I recall
there were some letters from governmental agencies, some
reports from meetings that were held on the subject of
PCBs . Q A
Are those meetings that you attended? Yes.
Q Any other? A I can't remember anything specific, but they
were not all Monsanto.
Q Did they also include technical papers? A Yes, there were some technical papers.
Q Papers that had been published? A I don't think any of them were published in
technical journals, no. I don't recall anything like
that.
Q Can you give me your best recollection of which are the technical papers, the subject matter or the
author or identify them in some fashion that you reviewed?
A Let me think here. I recall a paper referring
to the studies being made in attempting to find whether
PCBs degrade. I cannot recall any other specific ones
at the moment.
Q In your preparation for this deposition, did
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you review any reports of toxicity tests? A I reviewed summaries, summary-type reports,
yes, not full-fledged technical documents. Q Who were those summaries prepared by?
i
A One was prepared by Monsanto's Medical Depart
ment personnel. There was another, I recall, prepared
or at least the transmittal letter was signed by Dr.
Calandra from a private animal testing laboratory. Industrial Bio-Test Laboratories.
I cannot recall any other reports. Q The summary you have just referred to from
someone in the Monsanto Medical Department, was that a
summary that was prepared roughly contemporaneously
with the receipt of that report which it was summarizing? A Yes.
Q Was that a post 1970 report? A Yes.
Q Who prepared that report or what service,
what laboratory?
A IndustrialBio-TestLaboratories.
Q You are well familiar with Dr. Calandra, aren't
you?
A Yes.
Q I do not want to take a great deal of time on
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this. I want to know that we are talking about the same
reports.
I will tender to you, a copy of a report
to Monsanto Company from Industrial Bio-Test Laboratories,
Inc., identified as IBT No. A7204, which has been pro
duced by Monsanto in this litigation.
I do not propose to mark it now. I want
to know if that is one of the reports you reviewed for
this deposition or a summary of this report?
MS. STEIN:
If you are not going to produce docu
ments given by Monsanto, would you be kind enough to
indicate the numbers that appear on the bottom.
MR. POPE:
I was going to do that at the time of
marking the document, but the number is 0001008, the
first page.
BY THE WITNESS:
A I did not review this report.
BY MR. POPE:
Q I show you a 1972 report from Industrial Bio
Test Laboratories, Inc. to Monsanto Company, IBT A8570,
which the production process of Monsanto numbered as
003421, and ask you if that is one of the reports that
you reviewed or a summary which you reviewed?
A '
No, I did not review this report.
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Q The reports from Industrial Bio-Test that you
did review, what animals did they relate to?
A Rat.
^
Q Bothof them?
A It was the rat and the beagle dogs and chickens
on the one report and the other report, as I remember,
referred only to rats.
Q Are there any other technical articles or
reports that you reviewed in preparation for this depo
sition?
,
A I need a clarification oftechnical.
Q I am trying to include both published articles
that would relate to the science of PCBs or the presence
of PCBs in the environment as well as studies done on
animals dealing with the effects. Does that assist you?
A I am a little, somewhatconfused.
- In my definition, a technical report is
a rather formal sort of document covering the results
of the study.
Q Such as the two reports I just showed you,
is that right?
A Yes, or extending it further, summaries of such
reports that might be capsulized on a few pages.
Q I will be happy to accept your definition.
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With that definition, Mr. Papageorge, have you reviewed any other technical reports in prepara tion for the deposition other than the two Bio-Test reports you just referred to?
A I reviewed some reports that came out of the Research Analytical Laboratory that summarized the results of analyses for PCBs.
Q Research Analytical Laboratory? A Yes. Q Where is that? A St. Louis. Q Is that your in-house -- A Yes, sir. Q Anything else? A I cannot recall any more, no. Q And the Research Analytical Laboratory reports, what animals was that work dealing with? A I don't recall any. Q Is it not an animal at all? A I don't recall animals mentioned. Q It was a report that was summarizing some chemical experiments with respect to the effect of PCBs, is that correct? A No, sir. These were reports in which they
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attempted to detect whether PCBs were present in the
water or sediment and all kinds of samples, and if
>
they were present, to determine how much.
Q When approximately was that report prepared,
do you remember?
A 1970, 1971.
Q Was that a report that was analyzing samples
that were taken from Outboard Marine Corporation?
A I believe one of the units of Outboard Marine
Corporation is listed in at least one or two or some
of these reports, yes.
Q Johnson Motors?
A Johnson Motors, yes, sir.
Q Let me clarify one thing; we are not as formal
as Monsanto is. For purposes of this deposition, I want
you to understand that references to Outboard Marine
Corporation, I mean to include Johnson Motors and use
the term virtually interchangeably, and that is to the
extent of various documents. I think we should under
stand each other today.
A Ok ay.
Q Beyond the review of the two Bio-Test labor
atory reports or summaries that you have told me about
and the analyses of samples taken in the water and
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sediment which included references to Johnson Motors, were there any other technical reports that you re
viewed in preparation for the deposition today? A I believe I had mentioned earlier a report
on the degradation of PCBs.
\
Q Would that be a 1970, '71 report?
A In that period of time, yes. Q Any others? A I can't recall any others. Q Would it be a fair summary to say that the balance of materials that you reviewed consisted of
correspondence and minutes of meetings?
A Predominantly so, yes. Q Was there anything else besides those two categories?
A As I remember there was at least one document
that was sort of a memo to the file type rather than
correspondence to any particular person. Q What was the subject matter of that memo?
A I can't recall.
Q File?
A
That was an interoffice memo to Monsanto's Yes.
Q Was that one you authored?
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A No.
Q Was there anything else that you can recall
that you reviewed in preparation for the deposition?
A No.
Q Did you review any transcript?
A I am sorry.
Q Did you review any transcript of testimony?
A No, sir.
Q Did you review any summary oftranscripts of
testimony?
A No .
Q Approximately how long did you devote to the
preparation for the deposition in terms of hours?
A I didn't really keep a record, but I would
say about 15 to 18 hours total.
Q Does your current job include as one of its
duties the following of Monsanto litigation involving
PCBs?
A No, not any more than I have to.
Q Specifically with regard to this case, have
you been kept up to date all along on a regular basis
as to the developments in this litigation?
A No.
Q Have you talked to other witnesses who have
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given depositions in this case regarding the case?
A No.
Q Or their testimony?
A No.
Q You have, I take it, given other testimony
related to the subject matter of PCBs, have you not?
A Yes.
Q Could you tell me what that other testimony has
been?
MR. SCHINK:
You are talking now about court-type
proceedings, Mike?
MR. POPE:
I understand he has also testified
before agencies, either Congress or maybe States and
I will be happy to break it out if you prefer.
MR. SCHINK:
No, are you talking about -- apparently
he has made some presentation over time to various bodies,
but in my mind, there is a distinction between them and
testimony.
You are talking about statements he made
under oath?
MR. POPE:
Yes.
BY MR. POPE:
Q Where you testified under oath.
A Under oath, all right.
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I testified under oath before a sub
committee of Congress. As I recall, it was about 1974,
*75. Q
Do you remember which committee it was or what
subject?
A No, I don't. It had something to do with the
Merchant Marine. I don't recall the committee title.
I was involved in depositions, as I
remember, about five or six, and I have been involved --
Q Depositions in five or six cases,generally?
A Yes.
Q Were those cases all cases in which Monsanto
was named a party?
A Yes. And I was involved in two trials in
volving PCBs.
Q Where were the two trials?
A One was in New Hampshire, the other in Tennessee.
Q Was there a specific Monsanto product line
involved in each of those two cases?
A Yes, yes.
Q What was that for the New Hampshire case?
A The New Hampshirecase involvedPCBs, either
of the heat transfer-type application or of the printing
ink/adhesive/miscellaneous-type application.
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Q As in packaging? A Yes, yes.
Q How about in Tennessee? A Tennessee, it involved fluidcontaining PCBs
used in a transformer.
Q I presume that the five or six depositions
included depositions in those two cases, is that right,
or are those separate?
A Yes, yes.
Q So that leaves us with three or fouradditional
cases where you testified.
Can you recall where those cases were
pending?
A Where they were pending?
Q Yes.
A Are you referring to the locality?
Q The courthouse. A I don't know the specific courthouse.
MR. SCHINK:
Do you remember where you were deposed?
BY MR. POPE:
Q The state.
MR. SCHINK:
The state location of your deposition.
BY THE WITNESS:
A I was deposed in Ohio and in Indiana and New
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York. I believe that's it.
BY MR. POPE:
Q I take it those locations weren't chosen at
random.
To the best of your knowledge, was the
Ohio deposition taken in that case involving a case
pending in Ohio?
A Yes.
Q And similarly with the others?
A Yes, yes.
Q Can you tell me the product line, if any,
that was involved in the Ohio case?
A This involved one of Monsanto's PCB mixtures,
Aroclor 1254.
Q What was the product that was involved?
A That was Monsanto's product.
Q What was the use or application that it was
placed?
A It was alleged that this material was used in
a formulation, used to coat concrete silos.
Q And the allegation was that the PCBs had gotten
into food or food products?
A PCBs got into milk, yes.
Q To the best of your knowledge, hasthat case
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been settled or is it still pending? A That was settled.
Q The case in Indiana, what product was involved
there?
A It is the same, the same situation.
Q Same incident?
A Different incidents.
Q Aroclor 1254 was involved in the coating of
silos?
A In the coating of silos, yes.
Q Also in the milk?
A And cattle, present in the cattle.
Q To the best of your knowledge, what is the
current status of that litigation? A That is still pending.
Q How long ago were you deposed in that case?
A The first week of this month.
Q First week of August '81?
A August '81.
Q I take it you spent some time preparing for
that deposition? A Yes.
Q What product was involved in that case?
A It was never established, but it was either
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the heat transfer fluid or a packaging-related applica
tion.
-
Q What was the allegation, that PCB had gotten
into some food product?
A It got into poultry feed and involved poultry
and eggs.
Q Is that in Upstate New York or New York City?
A "Upstate New York.
Q What city?
A Middletown, New York, as I remember.
Q The best of your knowledge, is that case still
pending or has it been settled?
A I don't know the status of that case.
Q How long ago did you give your testimony in
that case?
A I believe it was 1977, approximately.
Q Have we exhausted the number of times that you
have given testimony under oath in the general subject
matter of PCBs?
A I believe we have, yes. I can't recall any
more at the moment.
Q Are there other times that you submitted
testimony to the Committees of Congress or State
regulators in the form of affidavits or written testimony
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other than this one Subcommittee of Congress on Merchant
Marine?
A This is to Congress or
States?
Q Right, either one.
A I don`t recall any written material submitted,
no.
Q Have you ever orallypresented testimony to
any Federal agency or Subcommittee of Congress where
you were not under oath?
A Yes.
Q Could you tell me when that was and how often
that has been?
A Oh, numerous times. I have never kept a record,
really. I have spoken before many groups within the
United States Environmental Protection Agency, both
informally and semi-formally.
I spoke many times before a group con
sisting of representatives of regulatory agencies and
within the Federal Government, which included not only
regulatory but I guess policy-setting and counsel-setting
in the Office of Science and Technology, the Executive
Offices of the President, the Food and Drug Administration,
the United States Department of Agriculture.
Q Is that the Interdepartmental Task Force?
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A Yes.
Q A group entitled Interdepartmental Task Force
on PCBs in Washington, D.C.?
A Yes.
I spoke before Wisconsin Department of
Natural Resources. I spoke before a group of repre-
sentatives -- I forget the exact title, the Five-State
Governors Meeting, Council on PCBs.
I spoke before the New York State
i
Attorney General.
I'm sure I missed some. I cannot remember
them all.
Q You recall no other appearances before Com-
mittees of Congress?
A No.
Q Mr. Papageorge, would you summarize for us, :
please, your educational background and training?
:
A I have a Bachelor of Science Degree in Chemical
Engineering and a Master of Science in Chemical Engineer
ing, both from Washington University located in St.
Louis, Missouri.
Q When were those degrees granted? A The Bachelor's Degree was granted in 1943,
and the Master's of Science Degree was granted in 1947.
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Q Have you taken any postgraduate courses or
additional courses since then?
A Oh, yes. I have taken courses at what was
at that time called Oklahoma A&M. Now X think it is
called Oklahoma State, courses in chemical engineering.
Q When was that?
A The period 1948 through 1950.
Q Are there any courses you have taken since
then?
A I'm sorry?
Q Have you taken any formal courses since
Oklahoma State, the 1950 period?
A I need help on the word formal. Is it leading
to credits for a degree?
Q Okay.
A NO.
Q Have you taken courses that do not qualify to
that degree of formality?
A Yes.
Q What types of courses were these that you took?
A Courses at the University; courses, for example,
the American Management Association.
Of course, Monsanto has courses, courses
that are offered by the company, by many groups.
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Q Professional groups?
A Professional groups or companies that are in
the business of offering courses. Q Are these all in the chemical area?
A No.
Q Similar to the American Management Association?
A No, these are primarily in the management area.
Q That includes the ones you took at universi-
ties, is that right?
A Yes.
Q What universities are those?
A Washington University.
Q Any others?
.
A What?
>
Q Any others?
A No.
Q Can you tell us whatprofessional societies
you belong to?
A The American Chemical Societyand the American
Institute of Chemical Engineers.
Q Have you published any papers in your field?
A No.
Q When did you hold your first jobafter getting
your B.S.?
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A 1947. Q What was the nature of the employment and
who were you employed by?
A I was employed by Phillips Petroleum Company
in Bartlesville,Oklahoma, working in their Research
Department.
Q That is when you began taking the courses at
Oklahoma State?
A Yes.
Q Was that leading to your degree?
A That was the intent.
Q The Ph.D. in Chemical Engineering?
A Yes.
Q That was not completed?
A That is right.
Q How long did you work for Phillips?
A From 1947 through most of 1951, November of
1951.
Q What was your final job with Phillips before
you left?
A I was Process Designer in the Refining
Department.
Q You changed jobs at that point?
A Yes.
............................................................................................................................. ..................
L- LU*n
C'.eftifieJ Sh ortkcmd f^eporteT'
134 |_a Salle Street a icogo, | I linois 60603 312 - 782-3332
WATER PCB-SD0000038546
Papageorge - direct
28
Q Where did you go then?
A I joined Monsanto Company in St. Louis.
Q What was your initial function or job title
with Monsanto?
A I forger the exact words, but I was again
Process Designer.
.
Q In a larger department?
A This was at the plant in Monsanto.
Q Which plant?
A The John F. Queeny Plant located in St. Louis.
Q What was being manufactured by the John F.
Queeny Plant?
A Oh, hundreds of different products.
Q You started working for Monsanto in what year
was that?
A 1951.
Q Was the John F. Queeny. Plant manufacturing
PCBs in 1951?
A No.
Q As Process Engineer, were you designing?
A Yes.
Q What types of things were you designing when
you started working for Monsanto?
A Distillation equipment, heat transfer units,
~j~hea [_. U^bem
(Certified ^R'rtlitind Reporter 134 Routk |_o Rolle Sjtreet
' a ICOf^O , Illinois- 60603 31? - 787-333?
WATER PCB-SD0000038547
Papageorge - direct
29
pumping circulating systems. Q How long did your job remain basically the
same? A
I believe it was about three or four years.
Q So approximately in 1954?
A Somewhere in there, yes.
Q What took place then?
A I then became the Production Supervisor.
Q At this point in time in the early 1950s,
were you a registered professional engineer?
A No.
Q Are you today?
A Yes.
Q When did you become so registered?
A I believe it was the early 1960s.
Q What body issued that registration?
A State of Missouri.
Q Going back to 1954, you were promoted to
Production Supervisor?
A Yes.
Q What did your job entail at that point?
A I was responsible for the management of a
group of people who were involved in the manufacture of
some of the chemicals.
TU L- UrUm Certified ortRnel Reporter
154 Sout!"i 1_a R^lle Street o \cano, | lime, 60603 312 - 782-3332
WATER PCB-SD0000038548
Papageorge - direct
30
Q Were you still at Queeney?
A Yes.
Q What type of chemicals or what type of products
were being manufactured by these people that you were
in charge of? A Over the period of time it covered, I will
mention chemicals if that will help: Phthalic anhydride.
Q What is that^used for?
A I am sorry?
Q What is that used for?
A It is an ingredient that is used in making
paints, making plasticizers, making plastics, and I
also was involved in making these plasticizers from
phthalic anhydride.
Then I was given the assignment to making
another group of intermediate chemicals called nitro-
chloroben zenes.
Q What were those chemicals to be used for?
,
A They were used in rubber chemicals and in
making of dyes; some were used in pharmaceuticals.
Q By dye, you mean color?
A Colors, yes.
Those are the principal uses.
Q Any other substances that come to mind that
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TU L Urban
Certified Sti ortRnd Reporter ------------------------------------
134 Roulk 1_o Rralle Rtreet
a icoqo, |llinoi? 60603
.
312.782-3332
WATER PCB-SD0000038549
Papageorge - direct
31
your people were manufacturing at that time?
A That's it.
Q How long were you Production Supervisor on
this team?
A I think about four years, roughly.
Q Was the nature of your job such that you were
regularly on the floor as opposed to being in an office
in management?
A Well, the office was right in the operating
unit so I was there.
Q You were involved in the day-to-day manufacture?
A Yes.
Q Approximately how many people were working
under you at that stage?
A I don't recall the exact number, but I'm going
to estimate 30 to 50.
Q Whatwas the nextpromotion?
A I then was asked to become a Maintenance
Supervisor.
Q This would be about 1959, 1958?
A Do I have too many years -- about '57, '58,
somewhere in there.
Q What is a Maintenance Supervisor or what was
it at that time?
-------------------------------- ,------------------------------------------------------------------------------------
. .
Bea 1_. Urban
Certified ortkiine! [Reporter--------
i34 ^~iouth |_a ^alle 5^'ree^ a IC&O'C, Illinois 60603 312 - 782-3332
WATER PCB-SD0000038550
Papageorge - direct
32
A At that time I was responsible for a crew of
craftsmen who would perform primarily repair on equip
ment and occasionally we would erect new equipment on
a small scale.
Q Was this still at Queeny? .
A Yes.
Q Was the general subject matter of discharges
from the Queeny Plant under your care as Maintenance
Supervisor?
A No.
Q The repair and erection of new equipment you
were dealing with at that period of time related to
in-house Monsanto manufacturing processes, is that
correct?
A Manufacturing orfacilities to support manu
facturing .
Q Would this be a period of time when the Queeny,
Plant was expanding?
A Yes.
Q Approximately how many peopleworked under
you during this period of time as Maintenance Supervisor?
A Again, it would vary with the work at hand:
3 0 to 5 0.
Q Would this similarly be a position where you
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~]""beo! 1__- Urban
Certifie
ortRnel Reporter
134 South l_o
Street
a icogo, 111 moi? 60603
312 - 782-3332
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WATER PCB-SD0000038551
Papageorge
direct
33
ii
were actually yourself involved in overseeing the repair --
A Yes.
Q -- or erection ofequipment?
A Yes.
Q How long a period of time were you Maintenance
Supervisor at the Queeny: Plant?
A A couple of years, I believe.
Q Would your next promotion or change of job be
1960 or so?
A Somewhere in there I became Maintenance Super
intendent.
Q I take it that was a promotion?
A Yes, sir.
Q How did your job change?
A I was nowresponsible for all the maintenance
in the entire plant.
Q At this point in time did your job include the
disposal or cleaning of substances that were manufactured
or discharged from the plant?
A Not directly.
Q How do you mean that?
A My function did not include involvement with,
as an example, hiring of trucks to haul off wastes. We
were indirectly involved in that we maintained the
~|~he<3 |_. t_Jrban
Certified ortCnd Reporter 134 Routli |_o Cdle Street a ! co^o, Illinois 60603 312 - 782-3332
--------------
WATER PCB-SD0000038552
Papageorge
direct
34
facilities that would store material or the sewer
\ system that carried the water effluent from the City
system and this is what I meant by indirect involvement.
Q So for example, did you have oil interceptors
at that plant?
A No.
Q What form of treatment did the discharges have
before they went to the City sewer?
A At that point in time, each department in its
process equipment would make certain they separated the
water from the non-water phases and the water would go
into the sewer collecting system and end up in a main
sewer which tied into the City, the municipal treating
plant.
Q So your function did not include any treatment
of discharge?
A No.
Q When you say your department was responsible
for maintaining the equipment or the lines or the sewers
that went to the City sewer, what do you mean by main
taining? What would you maintain?
A For example, if there would be a break in the
sewer, our team would be called in to do whatever was
necessary to perform the repair work.
* TU L- I_Irbem
_____________________________________________
134 Routli 1_a
5tTeet
CTiccago, Illinois 60603
J3I2 - 782-3332
WATER PCB-SD0000038553
Papageorge
direct
35
Q Was it part of your function at that point to observe or monitor whether the individual departments
were effectively separating out the process water from
the regular water?
A That was not my responsibility. Q Was there someone else at the plant that had
overall charge of that responsibility at that time?
A Yes, there was an individual assigned at that
time.
Q Who was that?
A Joseph -- gosh, I forgot his name, Joe Nemeth,
N-e-m-e-t-h.
Q To the best of your knowledge, is he still
alive? A
Yes.
Q How many people were working under your super
vision as Maintenance Superintendent?
A About 400.
Q I take it included in that group would be the
kinds of craftsmen you referred to earlier that were
involved in repair and erection of new equipment?
A Yes.
Q How long did you have the job of Maintenance
Superintendent?
I nea
Utoan
C^tifieJSliortRnd Reporter
134 S outli |_a 5^1 le Street
Ckictfga, Illinois 60603
312 - 782-3332
WATER PCB-SD0000038554
Papageorge - direct
36
A About three years, I believe. Q What was your next position?
A Pardon? Q What was your next position?
MR. SCHINK:
You have to speak up, Mike. It is
awfully hard to hear you.
BY THE WITNESS:
A I was then assigned a Superintendent in our
Plant Technical Services Department.
Q Is this still at Queeny?
A Yes. Q What was the Plant Technical Services Depart
ment?
A This is the Plant Engineering Design Group.
Q What did this group design?
A They would design new systems, new equipment,
new facilities to help the plant improve its performance.
Q When you refer to new systems, are you talking
about manufacturing systems?
A Yes.
Q This group would not concern themselves with
the development of new products, would it?
A No.
Approximately how" many people were in the
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Theo |_. Urton Certified Sfortkand Reporter
!34 Sut^ |_o, 5^1 le Street a iccgo, Illinois 60605 512 - 782-5552
WATER PCB-SD0000038555
Papageorge - direct
37
Plant Technical Services Department in 1963 when you
became Superintendent?
A Ab ou t 15 0 to 2 0 0 .
Q Were those basically technical people, pro
fessionals?
A Yes, basically.
Q Were you in charge of the entire department or
were you just one of the Superintendents?
A One of the Superintendents.
Q Did you have a specific role as Superintendent
or series of projects?
A Yes. I was assigned the group professionals
and paraprofessionals and was given the responsibility
for conducting the necessary studies, engineering, re
design for a specific group of products and processes.
Q Engineering for the design of specific manu
facturing systems for particular products?
A Yes.
Q For what products?
A
Phthalicanhydride which
I mentionedearlier,
maleic anhydride which is somewhat similar to phthalic
anhydride, a little different chemistry, same kind of
applications; some plasticizers. Again, that about
covers it.
Tkea L-
an
C^eT'tifiecJ
oTtkonJ Repo-pter
134 Routk L_c Ralle Street Rkicooo, 111 mois 60603 312 - 782-3332
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38
Q You were designing equipment to manufacture
chemicals for those types of uses, is that right?
A To manufacture those chemicals, yes.
Q From the time you first started for Monsanto
up to this 1963 period, were you within the same division,
the same operating area of Monsanto?
A Yes.
Q What was that called at that time?
A At that time, the Organic Chemicals Division.
Q As of 1963, were you aware of PCB as a product
that was being manufactured at Monsanto?
A Yes, I had heard of it.
Q Go ahead.
A Not only heard of it, we used it.
Q Did you use it in the plasticizers?
A No.
Q What uses had you come in contact with it at
that time?
A It was primarily in the functional fluids
uses such as compressors and heat exchange systems and
electrical transformers.
Q You had used it in the manufacturing process
and you had come in contact with it that way, is that
right?
T^ea L- UrLn
Certified Sh orthond Reporter 134 5uth 1_a Celle Ctreet Chicago, Illinois 60603 31? - 782-333?
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WATER PCB-SD0000038557
Papageorge - direct
39
A Yes, but to assist the process, not as an
ingredient in the process.
Q The manufacturing process of making the
various chemicals?
A Yes, right.
Q Did you include hydraulic fluids as one of the
fluids you had experience with?
A Yes, this was in the air compressor use.
Q Was that one of the Pydrauls or was that
different?
A Pydrauls, yes.
Q As of 1963, had you attended any Monsanto
seminars where its various employees were acquainted
with fluids that were being manufactured by Monsanto?
A If seminars in a broad sense means group to
discuss a subject, yes.
Q Was a meeting such as you have just mentioned,
were they held on a regular basis?
A Yes. It is part of the Safety Program.
Q Describe for me how it affected safety, what
you mean by that.
A Part of the continuing education or training
of employees is the education or teaching of people of
the chemicals they are handling and how to best handle
_Certified ortliand Reporter _
e& L- Uln
154 Soutk 1_a 5He 5^reet (^Ticc^cjo, Illinois 60605 312 - 782-3332
WATER PCB-SD0000038558
Papageorge - direct
40
them. And this is done not only for the new employees
who first enter a particular producing unit, but it is
also repeated at some frequency depending on the types
of materials handled in that department.
So it is every quarter, sometimes every
six months, sometimes once a year. It is variable.
Q Would that include both the types of chemicals
that were being manufactured by these employees as well
as other types they are using in the process?
A The answer is yes, anything they might be
exposed to.
Q I take it then as Maintenance Supervisor, as
Maintenance Superintendent and as Superintendent in the
Plant Technical Services Department, it was one of your
jobs to see that the employees were educated to the
use of these various -
A Yes.
Q -- chemicals.
Did part of that educational process
include some description of the safe handling of PCB
products as far as you recall?
A Yes.
Q Would you give a lecture to the employees on
that subject or would you bring in someone else, as you
TU L. t>Ln
------------------------------------------------------------------------------------------------Certified ortliond Reporter 134 I_& o 10-230, Illinois 60603 _ 3l2^782-3332
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WATER PCB-SD0000038559
Papageorge
direct
41
recall? A
It could be either way. In fact it is usually
a combination. Q Do you have specific recollection of having
such meetings in the early 1960s and late '50s with
respect to the safe handling of PCB products?
A Yes, I remember we had meetings with our
electricians who might be involved or potentially could
be involved with dielectric applications. We did hold
that, I remember that specifically.
Q What were they advised with respect to the
safe handling of that fluid?
A Don't get it on your skin, if you do, wash it
off fairly quickly. If it gets in your eyes, rinse it
out because it is an irritant.
Repeated exposure to skin, we were told
to relate to them because a chapped hands appearance,
reddening of the skin and when they are handling the
hot material, avoid breathing those vapors because they
irritate the respiratory system.
They were also told that if they got it
on their work clothes to go back, take a shower and
replace the work clothes.
Q Why is that?
Tb ea
Urban
----------------------------------------------------------------------------------------------- Certified Sf ortlianel Reporter --
134 Sout^ |_a
5treet
(3^ict3go, Illinois* 60603
3(2 - 782-3332
WATER PCB-SD0000038560
Papageorge - direct
42
A To avoid continuous skin contact.
That was the information given to the
employees.
Q How was it likely that electricians would
come in contact with this fluid?
A 0h# it might be when they are working on a
motor starter or a transformer or when they are replacing
a leaking capacitor.
Q Who gave this information to these employees?
A Generally it was the foreman, who in turn was ;
coached by a supervisor or a Medical Department repre
sentative .
Q Do you recall Dr. Kelly or one of his associates
coming in to give a discussion on that subject to your
employees in the late '50s or early 1960s?
A Yes, they would be involved frequently enough
that, yes, I do remember.
Q Was it Dr. Kelly himself?
A Not to the electricians, no.
;
Q Who was it, do you remember?
A A member of Dr. Kelly'sstaff. Jack Garrett.
Q Were you present?
A Yes.
Q
On other occasions didyouyourself
advise
, "j~kee< |__.
___ __________________________________ _____________ _______ ____
Certified ffTorthond Reporter
134 Couth 1_a
Street
a ictfr'O, 11 lino is 60603
31? - 782-333?
------
WATER PCB-SD0000038561
Papageorge - direct
43
the foremen, the supervisors what they should say to
the employees on this subject?
A Yes, on occasion, yes. I would conduct my own
safety meetings with the supervisors and foremen.
Q Where did you acquire this knowledge with res
pect to the nature of PCB products in the late '50s and
early '60s?
A From at least two places: One is my personal
conversations with Dr. Kelly and Elmer Wheeler and Jack
Garrett who were members of the Medical Department at
the time, as well as documented reference books that
we had at the time.
Q A reference book?
A A reference book where the chemicals in the
plant were listed and what we knew about them in terms
of effect on people. That was available in the plant
Medical Library.
Q Was that the source by which you determined
who should be talked to about what types of chemicals?
A That was one of the principal sources, yes.
Q During this same period of time, were there
any educational programs conducted on a regular basis
for management people with respect to the various
products that Monsanto was making or was introducing
eo L. Urtcn
Certified ortliond Reporter 134 ^outh L_a 5 I le Street a icogo, Illinois 60603 312 - 782-3332
_
WATER PCB-SD0000038562
Papageorge - direct
44
and their characteristics?
A Yes.
Q Were those conducted on a regular basis?
A Yes.
Q Could you describe for me the format or the
regularity, how they would be held, that type of thing?
A Well, as I remember, there would be a struc
tured meeting conducted by members of the Plant Safety
Department to which the salaried, as we call the super
visor level, would be invited to attend. This would be
held in a most convenient meeting room that would hold
the size of the anticipated audience.
It could take several forms: It would
either be presentations by members of the Safety Depart
ment, presentations by those in the plant who had many
years of experience with the product and could share
that experience with the group.
It could be by invitation to people like
the Dr. Kellys and Jack Garretts and Elmer Wheelers.
Occasionally they would even bring in outsiders from
the universities and the like, and it was a very varied
forum.
I think that describes it pretty well.
Q The focus of the meetings was again on safety
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(Rertifie
ortkand Reporter
134 Soutk |_a
2tTeet
| llinois 60603
312 - 782-3332
-
WATER PCB-SD0000038563
Papageorge - direct
45
of employees in the handling of substances?
A Yes, that is what we are talking about.
MR. SCHINK:
You are talking now about products
made in the plant as opposed to those products -
MR. POPE:
That is what Mr. Papageorge has talked
about. I am just trying to poke along and try to find
out what was going on.
BY MR. POPE:
Q Were these meetings held monthly?
A Not that frequently, no. Generally they were
twice a year, sometimes annually. It depended on the
changeover in personnel and if in someone's opinion
it was> time to get reeducated.
Q At any of these meetings that you can recall,
was the handling of PCB-bearing fluids discussed?
A Not as a subject.
Q Not as a subject, you mean if it was discussed
it was only discussed in passing, or how do you mean
that?
A The topic of PCBs did not appear on an agenda
for thatlarge an audience, many of whom would not even
have the potential of even being involved with it.
It would be reserved for the more spe
cific groups working with that equipment that might have
""["beo 1__ l_Jrt>an
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Certified 5^orthond Reporter 134 5uth l_a Sialle Litreet a icogo, | I llnot? 60603 31? - 782-333?
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WATER PCB-SD0000038564
Papageorge - direct
46
had PCBs in them.
Q I see. The discussions that you referred to
earlier that you had with Dr. Kelly and members of his
staff that acquainted you with the properties, the
effects of PCBs, can you tell me when those took place
and what you remember about what they told you?
I take it you don't remember the spe
cifics of each one of these meetings.
A No, I don't. I can recall the essence of
these discussions.
Q This is all around the 1963 or early '60s
period?
A The early 1960s.
Q Could you tell us, please, what you remember
about those discussions?
A I do remember asking Dr. Kelly and his staff
what they could tell me, not only about PCBs, but other
materials and where could I go to get more detailed
information if I needed it.
Q Other materials that you were using in the
manufacturing process, is that right?
A Right. And as best I recall of the informa
tion regarding the PCBs, it was like I indicated earlier,
the effect on skin, drying out process, the eye irritant
__: Certified 0k ortkand Reporter .--
eo> |__. Urban
154 Routk |_a Salle Street Ck Ic&qo, Illinois 60603 312 - 782-3332
WATER PCB-SD0000038565
Papageorge - direct
47
capability, the respiratory irritant. Those were the
three principal areas and he did indicate that there
/
was some evidence many years before that point in time
of the skin problems resulting from overexposure which
was referred to as chloracne and we would relay this
information to individuals.
Q Anything else?
A I cannot recall anything else.
Q Were there any discussions that you recall of
effects on the liver?
.
A At that point in time, no. Q Did they refer you to other sources with res
pect to your questions regarding PCBs?
A They referred me to some written material
which was a summary of what they told me verbally.
Q Where was that written material?
A That was in the Plant Safety Department's
library, which is part of our Medical Group.
Q You went and examined that?
A Yes.
Q Was there somebody at the plant that prepares
some kind of analysis of each of the chemicals that is
coming in?
A This would have been Dr. Kelly's group that
""["liea L Uftan ____________________ ________ _______ __ _____ _Certified Chorthond Reporter ------------------------------- ------
134 Couth \_e> Solle Ctreet Ch icogo, Illinois 60603 312 - 782-3332
WATER PCB-SD0000038566
Papageorge - direct
48
would have prepared the summaries and sent it to the
:
plant for reference.
Q Setting aside the questions of safety to
employees and the handling of products, was there in
place an educational system within Monsanto that a
person such as you in the early '60s working in the
Queeney Plant could learn or be kept abreast of Monsanto's
other products being manufactured at another plant?
A Not any formal way.
Q Was there an informal system of communication? .
A I don't know. It was so informal, I don't
know I'd call it a system. It was just the need may
arise, the need to know. Someone working with future
designs may wish to know something about the materials.
They would because of that need seek out information and
that information would come, depending on the type of
information, from any one of several sources.
If it was of a chemical technical nature,
they would go to a Research Group somewhere. If it was
a health-medical type thing, they would go to Dr. Kelly's
group, and if that knowledge was not within Monsanto,
they would ask Dr. Kelly to seek it out from somewhere
to see if there was anything.
If not. Dr. Kelly's group
would propose some studies to get it, and the same thing
TI-.ea L-
an
------------------------------------------------------------------------------------------------Rertiplod orthond Reporter
134 ^ou-tk \_a
Street
a icago, Illinois 60603
_ 312-782-333-2
WATER PCB-SD0000038567
Papageorge - direct
49
with a chemical. If the chemical data, if it wasn't
available within Monsanto, we would certainly conduct
searches in the literature.
MR. SCHINK:
The question was finding out about
products of other plants.
BY THE WITNESS:
A Yes .
BY MR. POPE:
Q Would it be fair to say that the only way this information would be generated for a person such
as yourself in the early 1960s would be by you initiating
a request to somebody else for additional material?
A Yes.
Q How long did you hold that position of Superintendent in the Technical Services Department?
A I believe until 1963, late '62; somewhere
around there.
Q Why don't you tell me approximately how long you were there.
A A couple of years; two, three years, two years.
Q A Plant.
What was your next position? I became General Superintendent at the Queeny
Q Would this be 1964?
Certified Ch orlhand Reporter
134 Couth |_a Colle Ctreet Chicooo, Illinois 60603 31? - 782-333?
WATER PCB-SD0000038568
Papageorge - direct
50
A About 1962 or '63, as I remember.
Q General Superintendent?
A General Superintendent and I was responsible
for Warehousing, Distribution -- which is shipping of
tbe products -- and the Utilities.
Q You would be in charge of shipping the final
product that was manufactured there at Queeny?
A Shipping out or involved with receiving raw
materials.
Q And utilities means the power for the plant?
A Yes, electrical power, steam, water.
Q In this position were you partly responsible
for the plant's discharges to the sewer or anywhere
else?
A Only for those discharges that the utilities
operation might create, like boiler water, blowdowns,
cooling water tower treatment.
Q Was there any treatment given to those waters
before they were discharged when you were General Super
intendent?
A The treatment was given to make them more
suitable for their use.
Q What treatment was given?
A For example, boiler water is treated to prevent
ea L U-U
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134 Routk |_a
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a icogo, jilinoi? 60603
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it from corroding the water or depositing material into
the boiler.
Q It is treated before it goes into the boiler?
A Yes, the same thing with cooling water, treated
to make it more suitable for the cooling service.
Q How about when it was discharged from the plant?
Was there treatment then?
A There was no treatment.
Q It just went to the City sewer?
A Yes.
Q In your position or that aspect of your posi
tion related to receiving of products, would you be in
charge of receiving materials from other Monsanto plants?
A Yes.
Q I take it then you would be in charge of re
ceiving the PCB-bearing fluids we discussed earlier
that were used at Queeny?
A Yes.
Q Would they come to your dock in the same
packaging that an outside customer would receive from
Monsanto?
A Yes.
MR. SCHINK:
Give him a chance to finish the
question.
~|~bea [_. turban
Certified ortkond ['Reporter
134 Sou^ L
Street
Skiccjgo, | I linois 60603
31? - 782-333?
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WATER PCB-SD0000038570
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MR. POPE:
We are doing just fine, Mr. Schink.
MR. SCHINK:
Because for just a second, he paused
on his question. Wait until he is finished asking the
question.
.
THE WITNESS:
Okay.
BY MR. POPE:
Q Do you recall what quantities you received the
heat transfer fluid in at Queeny?
A I don't think I understand the question.
Q Do you mean tank cars full, barrels, buckets,
pints, thimbles?
A All I recall was that we received it in steel
containers, not in tank cars or drums.
Q You do not remember the quantity that was used
there?
A No.
Q Would the same be true for the Pydraul or do
you recall?
MR. SCHINK:
You are talking now about the air
compressor fluid, Mr. Pope?
MR. POPE:
Whatever Pydraul they used at Queeny?
MR. SCHINK:
He has already answered that.
MR. POPE:
Excuse me?
MR. SCHINK:
The Pydraul, just because the term
""["kea |__. Urban
------------------------------------------------------------------------------------------------ Certified Sk ortkand Reporter --
134 S outk I a
Street
(Rliicogo, Illinois 60603
_ 312 - 782-3332
WATER PCB-SD0000038571
ll j
i
(i
Papageorge - direct
53
Pydraul has been used interchangeably in several depo
sitions, it applies to several different types of
fluids.
MR. POPE:
I do not want to misstate it. We are
talking here of using Pydraul only for the air compressors,
is that correct, Mr. Papageorge?
THE WITNESS:
That is my recollection, yes.
BY MR. POPE:
Q The question is what containers did they come
in, the same type of steel containers?
A Yes, steel drum.
Q It is a different substance, isn't it?
A Yes, it is different.
(The witness conferred with
his counsel.)
MR. POPE:
Do you want to take a break?
MR. SCHINK:
Let's take a brief recess.
(Brief recess had.)
BY MR. POPE:
Q With respect to the Pydraul that was used at
Queeny, did it come with any labels on it, to your
recollection?
A Yes.
Q Did the labels contain anywarnings, to your
TU L. U^n
--------------------------------------------------------------------------------------------------- --------
134 Soutk [_<a Sdle Street a iCC*C*0, Illinois 60603 312 - 782-3332
WATER PCB-SD0000038572
Papageorge - direct
54
recollection?
A Yes.
Q To the best of your recollection, what did
they say?
A I don't recall the exact words, but there were
references to the eye irritation potential, the effect
on skin and to avoid breathing the vapors. I believe
that is the message.
Q Was there a description of what the product
was in terms of containing PCBs?
MR. SCHINK:
Was there any description as to the
content?
BY THE WITNESS:
A Yes. I remember it had reference to chlorinated
hydrocarbons which is the broad classification.
BY MR. POPE:
.
Q This is in the early '60s, is that right --
A Yes.
Q -- you are talking about?
A Yes.
Q Did the material for the heat exchanger fluid
contain similar labels?
A Yes.
Q Did that also identify the product as containing
________________________________________________
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Certified ortfand Reporter
134 5olJth 1_a S^lle Street
a icago, Illinois 60603
312 - 782-3332
'
--------
WATER PCB-SD0000038573
Papageorge - direct
55
chlorinated hydrocarbons?
A Yes.
Q Was there any other PCB-bearing fluid that
was used at Queeny during this period of time other
than those two?
>
A We had mentioned the electric transformer
application for use.
Q Was that received as a fluid at Queeny?.
A Yes.
Q Did that come in steel containers as well?
A Yes.
Q Are these roughly the size of drums?
A Itwas possible to have three different size
containers at that time: The 5-gallon barrel, the 30-
gallon drum and the 55-gallon drum. It was one of
those or all three.
Q Was the fluid for the electrical use, was that
similarly labeled as the other two?
A Yes.
Q You referredearlier to employees coming in
contact with these fluids in repair or when there were
leaks in the air compressors and whatnot. Was one of
your duties to be in charge of disposal of such substances?
MR. SCHINK:
I am not sure he said they did. I
____ Certified
ortho nd Reporter
XUa
Urban
----------------------------------------------------------------------------------------------------
134 COL|th L_o Celle Ctreet
a)'lCOOO. Illinois 60603
312 - 782-3332
WATER PCB-SD0000038574
Papageorge - direct
56
think he said they could, so I object to the form of the
question insofar as it is not properly characterizing
his prior testimony.
MR. POPE:
I will withdraw the question, Mr.
Schink .
BY MR. POPE:
.
Q Did there ever come a point in time at Queeny
when it was necessary to dispose of fluids that contained
PCBs?
A Yes.
Q How did that occur?
A We had individuals whose responsibility it was
to first of all collect this spillage and put it in a
steel container.
Q My first question was how did it occur. Was
that a necessity, to have people like that -
A I am sorry, I misunderstood.
Q How would the Pydraul or how wouldany PCB-
bearing fluid come to the point where it would need to
be cleaned up?
A It might be a situation where a leak would
develop in the system.
Q That did occur, did it not?
A Yes, occasionally.
Tbea L Urban Certified orthand Reporter
134 South |_a S^lle Street a iccgo, 111 ino*s* 60603
_ 31? : 782-3332
--------------.
WATER PCB-SD0000038575
Papageorge - direct
57
Q What type of system are we talking about now?
A It would be heat transfer or even a compressor.
Q From time to time there would be leaks that
would cause the PCB-bearing fluid to come out of place,
where it --
A Yes.
Q When that happened, what was the practice with
respect to cleaning it up and disposing of it?
A The practice was to contain the leakage, keep
it from getting out of control. Of course, you take
any steps you can to shut down the system so that it is
not under pressure.
Q Not spurting all over the floor?
A Correct, and anything that did get on the
floor would be collected or absorbed in some absorbing
medium, whether it be sawdust or commercial products
like Oil-Dri and the idea was to convert it into a form
that could be swept up and collected and put into a
container.
Q That was in fact done when these leaks occurred?
A Yes, that was.
The container would then be accumulated
with other chemical wastes and would be then hauled out
to an approved landfill. -- Certified Shorthund Reporter
,
TU |_. Urban
134 Couth 1_a CcHe Ctreet a icavo, Illinois 60603 31? - 782-333?
WATER PCB-SD0000038576
Papageorge - direct
58
Q Approved by whom?
A By the State authorities and County authori
ties, whoever was responsible at that point in time
for approving landfills.
Q To the best of your recollection, was that
approving agency advised or was anyone advised there
were PCBs in the substances being hauled to thelandfill?
A No.
Q Following the sweeping up of fluid and the
absorbent material, was it the practice then to wash
down the floor?
A No need to. The PCBs are not water soluble
anyway, so washing the floor doesn't --' it was not the
practice.
Q Was there anything further done other than
just sweeping up this material?
A
That's
it.
Q How many people were charged with that res
ponsibility?
MR. SCHINK:
Is your question was there this
exclusive responsibility or did they have a maintenance
responsibility which would have included this in the
event it occurred?
MR. POPE:
I don't know whether there was anybody
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Certified ortliand Reporter
134 Soutti |_a
2treet
a tccigo, Illinois 60603
312 - 782-3332
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WATER PCB-SD0000038577
Papageorge - direct
59
who had the exclusive responsibility of cleaning up
spills.
MR. SCHINK:
Your question is ambiguous and that
is why I asked for clarification.
I will object to the form of the question.
BY THE WITNESS:
A I don't know that I can come up with a number.
It is the person responsible for operating the equipment
would be the first to see the spillage and would take
action on his part. He has that responsibility and he
does all he can to contain that leakage until the Main
tenance people come along now to repair the problem, so
that is another group. And this would happen, this could
involve different groups of people depending on the loca
tion of that system, that piece of equipment.
BY MR. POPE:
Q Is there a third person that is called to
sweep up the absorbent material and haul it away?
A No. Either the person operating the equipment
will sweep it up or the Maintenance people would clean
up after.
Q So the repair person, after he finishes repair
ing the leak, his responsibility would be to clean up
whatever fluid had come loose, is that correct?
--......................... ..................................................................................
~["hea 1_. UrLcm
Certified STortloonel Reporter
!34 Soutlo |_a
Street
o icago, Illinois 60603
312 - 782-3332
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WATER PCB-SD0000038578
Papageorge - direct
60
A I think this would vary. One of the two
would clean up depending on, I suppose, when most of
the material would have accumulated, either during the
repair procedure or during the early stages.
Q When earlier we referred to repair people in
the Maintenance Department that you were overseeing,
they would be the people that would share the responsi
bility for cleaning up any leaks and disposing of
material along with the personnel responsible for
operating the machine, is that correct?
A That is correct.
Q Getting back to your position as General Super
intendent, was it within your area of responsibility to
see to the ultimate disposal of these various containers
of chemical wastes?
A Yes.
Q Was the practice already in place and you
simply followed it as you became General Superintendent
with regard to disposal?
A Yes.
Q The practice wassimply to
take thesecontainers
to a landfill, is that right?
A Correct.
Q Was it always thesame landfill whenyou were
------------------------:-- ------------ -- ----- -------------------------- --
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--------
WATER PCB-SD0000038579
Papageorge - direct
61
General Superintendent?
A The best of my knowledge, it was, yes.
q Was there any segregation among the various
chemical wastes that were being disposed of?
A Yes.
Q How would that work?
A Those chemical wastes thatwere notconsidered
to have a potential for creating any problems were
segregated from those that we perceived as having
potential for creating some health problems.
Q Human health problems?
A Primarily human, yes.
Q Into which category did thePCB-bearing
fluids fall during the mid-'60s?
A They went in with the chemical, what we call
chemicals, the potential terminology as distinguished
from trash.
Q They went into the category that you described
as the potential for human health problems, is that
correct?
A Correct, correct.
Q They would be hauled together, all those types
of chemical wastes, is that correct?
A Yes, correct.
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L- U^ban
Certifie ortiicinj [Reporter 134 |_o Solle Street a icago, Illinois 60603 312 - 782-3332
--
WATER PCB-SD0000038580
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62
Q That would be different from those wastes
that were considered to be trash and not having any
potential effect on human health?
A That is right.
Q Who would make a determination as to any
particular wastes, into which category it fell?
A The supervisor responsible for that producing
unit, guided by the Plant Safety medical staff, would
determine which containers would be used for which
wastes.
Q Was this practice you have just been describing
in place when you became General Superintendent?
A Yes.
Q To your knowledge, how long had it been in
practice?
A I don't remember. I have no way of knowing.
It was there in the '50s when I arrived and appeared to
have been there before World War II, to the best of my
information.
Q These containersthatwere used in disposal,
did they have any labeling on them?
A No.
Q Were arrangements madeso that these containers
would be taken to a place that was used exclusively for
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Certified SI-icrthflnd Reporter 134 South |_ Sfdle Street o \cooc, Illinois 60603 31? - 782-333?
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WATER PCB-SD0000038581
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63
chemical wastes?
A Yes.
Q Who arranged that, the landfill people.
Monsanto?
A Monsanto, yes, it was our people that arranged
it.
Actually it was our landfill we were using.
Q I see.
A That we were using.
Q Where was this landfill?
A In Illinois.
Q Where? A Across the river from the Queeney Plant.
Q Adjacent to the Sauget Plant?
A Yes.
Q That landfill was, I take it, registered with
the State of Illinois as an approved landfill for
chemical wastes?
A Yes, that is right.
Q Did I understand correctly that there were
PCBs in the heat exchanger fluid that you were using at
Queeney at this period of time?
A Some of the heat exchanger fluids.
Q Was there occasion when there would be leaks
~Tliec 1__ l_Jrb<an
CeT-tified orthand Reporter
134 <~'!outh [_*
Street
a icago, 111 inotS' 60603
31? - 782-333?
WATER PCB-SD0000038582
Papageorge - direct
64
of that heat exchanger fluid?
A Occasionally, yes.
Q Upon the occurrence of such a leak, would the
fluid come in contact with water?
A No.
Q Was there any water usedfor cooling water or
other purposes in connection with the machines that
used the heat exchanger fluid, to the best of your
knowledge?
A No, no.
Q
Were there any PCB-bearingfluids
at Queeny;
during this period of time which if they came about ( s\
the leak would come in contact with water, to the best
of your recollection?
A They shouldn't, no.
Q During this period of time that youwere
General Superintendent, did you have occasion to have
any interaction with the Sauget Plant?
A Yes.
Q That is called, what is the name of that plant?
A The W. G. Krummrich Plant.
Q That is simply acrossthe river from the Queeny
Plant, is that correct?
A Correct. ______ __ ______________________________________________________
,
"Uea l_. Urban Certified ortlujnd Reporter
134 Lo Salle Street a Ic&ao, | 11 incus 60603 - 31? - 78?-333?
-----
WATER PCB-SD0000038583
Papageorge - direct
65
Q Although it was a wide river, as I understand.
What was the nature of contact you would
have with the Krumrarich Plant during that period of time?
A It would vary the full spectrum for comparing
notes on how they do things, how we do things, the
routine where, "I'm coming over with a load to dump, put
in your landfill, is the gate open?" to "I'm going to
conduct a certain training course, do you have anybody
that wants to attend?"
Just about any topic imaginable could
have and did exchange between the two plants.
Q Were there any other Monsanto plants that you
had such contact with on a regular basis?
A Not to that degree, much more limited.
Q Because of the physical proximity?
A Correct, plus the types of materials handled
were similar.
Q Were you using in Queeny, products that were
being manufactured at the Krummrich Plant?
A Yes.
Q What type of products?
A The PCBs, for one.
Q Is it fair to say that all the PCB-bearing
fluids you were using in the manufacturing process at
ea L-
an
____________________________________________________________________ _________________
154 South 1_a Solle Street Chicago, Illinois 60605 312 - 782-3332
WATER PCB-SD0000038584
1
(
Papageorge - direct
66
Queeny were being manufactured across the river at Krummrich?
A Not necessarily. Q What was the breakdown? A What was the breakdown? Q You said not necessarily. I am asking you to explain that. A Some PCBs used by the Queeny Plant were manu factured at the Anniston, Alabama Plant of Monsanto. Q Of the fluids we discussed, which ones were manufactured at Krummrich and which ones at the Anniston, Alabama Plant, do you know? A Both. Q I see. They are interchangeable? A Yes. Q Beyond the PCB-bearing fluids, what other substances were you using that would be manufactured at Krummrich? A Acid and caustic, chlorine and nitrochlorobenzene.
I cannot recall any others. Q Was one of the subjects that was discussed in your regular contact with the Krummrich Plant the handling of PCB-bearing fluids, safe handling? A Yes, yes.
Theca 1_ L-JTan
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134 Couth l_o 5c|lie Street Chicogo, Illinois 60603 31? - 782-333?
WATER PCB-SD0000038585
Papageorge - direct
67
Q With whom would you deal on that subject at
the Krummrich Plant? A It would be my counterpart at the Krummrich
Plant who had the responsibility for that producing
unit. Q A
Who was that? I believe at that time it was Mr. Paul
Heisler, H-e-i-s-l-e-r. Q Was Mr. Heisler ever invited to come over and
address the employees on the subject of safe handling
of PCB products? A I don't recall him being invited.
Q He was the person at Krummrich who was basically in charge of manufacturing of these particular
PCB fluids that you --
A Best of my knowledge, yes. Q In your position as General Superintendent, Queeny --
MR. SCHINK:
You are not talking about General
Superintendent of the Warehousing, Distribution and
Utilities? You mean the entire plant?
BY MR. POPE:
Q Your title was General Superintendent of --
A Warehousing.
Certified
L- Urban
ortliand Reporter
134 Sutli La Salle Street a icago, Illinois' 60603
_.... _J5)2s. 782:3332
WATER PCB-SD0000038586
Papageorge - direct
68
Q Is it a division or -- A It should be commas, I didn't indicate, I
don't think. It is General Superintendent comma -- I don't know what that means.
Q I know it is important in that corporate
structure.
A Warehousing, Distribution and Utilities.
I believe that is the name. I may have missed a comma
or two there. Q In your position as General Superintendent,
Warehousing, Distribution and Utilities at Queeny, did
you have occasion to consider the likelihood of PCB-
bearing fluid persisting in the landfill for a long
period of time?
A No .
Q Were you aware as a chemical engineer that
PCB fluid would basically last virtually forever at
the place where it was disposed?
A No.
Q Is that not a true statement?
A What, was your statement true ormine?
Q Is it your understanding that PCB --
MR. SCHINK:
Now you are asking him as of today?
MR. POPE:
As of today.
_____ _____________________________________________________________________ ______________
~j""bea |_. Urban
Certified Sk ortkand Reporter
134 ^outk |_n Salle Street a lC0C*O, Illinois 60603 312 - 782-3332
WATER PCB-SD0000038587
Papageorge - direct
69
BY MR. POPE:
Q As of today, that PCBs disposed of in a land
fill will basically persist for a long period of time.
Is that a true statement as you understand it today?
A No, I would have to know the conditions of
burial and what PCBs were present and. which PCBs you
are talking of.
Q We know what we are talking about. We are
talking about the PCBs you disposed of from the Queeny,
Plant, whichever ones those were. Whichever PCBs you
disposed of at the Queeny Plant and the conditions I
am discussing are the ones you are aware of that were
being implemented in the late '50s and early '60s at
the landfill in Sauget.
,
MR. SCHINK:
You are talking about several dif
ferent PCBs, Mr. Pope. That is the problem with your
question. That is why I object to the form of it.
The witness has testified there are
differences depending on conditions involved and the
conditions of burial.
BY MR. POPE:
Q Is it your understanding that some of those
PCBs disposed of under the conditions you disposed of
will last for a great deal of time?
ea L. LWan
Certify Sk ortkand Reporter
134 Soutk 1_a
Street
a ic^go, Illinois 60603
3I2_- 782-3332
WATER PCB-SD0000038588
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70
A Yes.
Q 1963?
Is that a fact you were aware of in 1962 and
A I was not aware of that then.
Q As a chemical engineer, were you aware of the basic formula that goes into making PCBs in 1962 and
1963?
A In a general way I was aware of chlorinated
biphenyls, but since I did not manufacture them, I did
not pursue the chemistry in depth.
Q Were you aware of their general characteristics
with respect to persistence?
A No.
Q Were you aware of the general effect of
pouring on a substance like that making it last longer
and making it more inert?
A No.
Q During the period of time that you were General Superintendent, Warehousing, Distribution and
Utilities, did anyone in your presence raise the ques
tion of whether the disposal of these wastes at the
landfill across the river would be a safe process?
A No .
Q I presume you understood me when I said in your
L-Jbea
Urban
Certified
ortktand Reporter
134 Soutk \_o
Street
(Rl-ucc^o, | 1I inois 60603
31? - 782-333?
WATER PCB-SD0000038589
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71
presence, I also include by written memoranda. You
understood that as well?
A Yes.
Q In your review of the files of the company,
had you uncovered any prior question being raised about
the safe disposal of these substances at Sauget?
A I would like a clarification of what you mean
by question raised. Does this imply that someone was
concerned that it was improper?
Q No, sir. You have already told me as far as
you knew no one in your presence or during the period
of time you were General Superintendent, Warehousing,
Distribution and Utilities, raised a question about that.
My question to you is when you came into
the office, did you have access to the files, was there
any past correspondence relating in the files that
somebody had questioned it?
MR. SCHINK:
Prior to '62?
MR. POPE:
Yes.
BY THE WITNESS:
A No.
BY MR. POPE:
Q
No,
there was not?
A
No,
there was nothing in the file.
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Certified Ch ortho nd [Reporter
T^ea L- l_Ipbem
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134 Couth 1_a C^lle Ctreet
om cetqo. 111 inoi? 60603 312 - 782-3332
WATER PCB-SD0000038590
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72
Q Did you at any time when you were in this
position personally check the approval from the State
of Illinois with respect to this landfill?
A No.
Q Did you have access to any files relating to
that approval or seeking of that approval or representa
tions made by Monsanto with respect to that landfill,
per se?
A The files were not in my possession, but I
had access if I desired to look.
Q But you never did?
A That's right.
Q What steps were taken to your knowledge at
the Sauget landfill to give any added safety to disposal
of these chemicals?
v A I don't know.
Q Did you ever yourself during the period of
time you were General Superintendent of Warehousing,
Distribution and Utilities go to the landfill site?
A No.
Q Did you ever during that period of time have
meetings with people to determine what was being done
toensure that this disposal was being
safe?
A Not formal meetings, justdiscussions.
___ CertiM SUrtUJ Reporter -
TKea L. LWan
134 |_o 5^11 5^'ree'k a icago, Illinois 60603 312 - 782-3332
WATER PCB-SD0000038591
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73
Q Who did you have such discussions with?
A I have forgotten the individual at the moment.
It was my counterpart at the Krummrich Plant.
Q You do not recall his name?
A No, I don't. I don't remember.
Q Did you ask him what was being done with respect
to the safe disposal of these chemical wastes?
A I forget the exact words, but the discussion
was somewhat of along the lines of is this landfill
used for chemicals or is it a sanitary or office wastes
going into it; just how do you handle it and do you
cover the material; this type of discussion.
Q What did he tell you as best you recall?
A As best I recall, he informed me that it was
used exclusively for chemical wastes; that they did
cover and I was left with the impression things were
well done. I don't remember any details.
Q Do you remember this gentleman's name?
A I think it might have been Paul Gatans; but
I'm not positive of the timing.
Q Paul who?
A Paul Gatans.
Q
If I understand youcorrectly,
as far as you
know, the substances were taken fromQueeny.and basically
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Certified
ortliane) Reporter
134 ^noutii |_a
5^:T'eet
a icogo, Illinois 60603
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WATER PCB-SD0000038592
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74
put in the ground in the same containers they were
stored there at Queeny ?
A Yes.
Q And covered over with some soil?
A Yes.
Q I may have asked you thisbefore and I am /
sorry if I have, but you never had any concern during
this period of time as to whether this was a safe way
to dispose of these fluids, did you?
A I had no reason to be concerned, no.
Q In your discussions with Dr. Kelly and his
staff, had they ever indicated any tests that had been
done on PCBss with respect to whether there was any long
term health problems as opposed to acute toxicity tests?
A At what point in time?
Q Prior to this mid-early '60s.
A No.
Q You had not had any such discussions?
A No discussions.
Q The discussions you had with Dr. Kelly didn't
relate to that subject at all, one way or the other?
A That is true.
Q How long were you General Superintendent, Ware-
housing.
Distribution and Utilities at Queeny:?
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Certified ortliond Reporter
134 Routli \_ct 5aHe Ctreet Cfficogo, Illinois' 60603 31? - 782-333?
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75
A I think a couple of years, as best I recall,
from about '62-163 to "64.
Q Did that position include negotiating with
unions?
A In what respect, dealing with the union and
the shop stewards and the like?
.
Q Yes.
A Yes, sir.
Q But not in the generalnegotiation contracts?
A The positiondidn't, but I wasinvolved.
Q That was in addition to your other functions?
A Yes.
Q How long a period of time had you taken on
that function as well?
A Oh, I was involved in, let me -- correction.
MR. SCHINK: I think you are talking about nego
tiating with the union for their plant agreement, is
that right?
MR. POPE:
Right.
BY THE WITNESS:
A -- which happens every so many years. I was
involved with the Queeny Plant negotiations from the
time I was Maintenance Superintendent through the period
when I was General Superintendent, Warehousing, Distribution
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orthond Reporter
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76
and Utilities.
BY MR. POPE:
'
Q Were there any other jobs that you performed
beyond those that you have described for us as of the
' 62- ' 63 period?
A NO.
Q What took place in 1964?
A I was transferred to the W. G. Krummrich Plant
as General Superintendent, Manufacturing.
Q What did that position entail?
A I was responsible for several units involved
in the manufacture of chemical products.
Q Were you General Superintendent of all the
manufacturing taking place at that point?
A No, there were three General Superintendents
in Manufacturing so I had roughly a third of the manu
facturing capability under my supervision.
Q Approximately how many employees reported to
or worked under you in that position?
A Two to three hundred.
Q
Was there a breakdownof products
amongst the
three General Superintendents?
A Yes.
Q Which products were you in charge of?
~Pkee< |_. Urban
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A I had rubber adhesives, phenol, sodium sulfite, chlorophenols. I believe that's it.
Q Were these substances being manufactured by other plants as well within Monsanto?
A No, those were manufactured for Monsanto only at the Krummrich Plant.
Q Just briefly, the rubber adhesives, what was being manufactured and what was its intended use?
A We made a material we called a 4NDPA. I don't remember the chemical name. It is a chemical that is added to rubber products such as automobile tires.
Q That is its principal use? A Yes. Q And the phenols that you were manufacturing? A Yes. Q Is that p-h-e-n-o-1? A P-h-e-n-o-1, has a wide variety of uses. It is used in making agricultural chemicals as a starting point. It is used in making plastics and resins; used in making glues, adhesives and also in making dyes, coloring chemicals. It is also used as a pharmaceutical. Q Is that a representative sample? A Yes. Q How about sodium sulfite?
Tbea 1_. Urban
---------------------------------------------------------------------------------------------------------------------------------------- Certified Ch orthand [Reporter .--,--
134 Couth l_a Celle Ctreet
a icago, Illinois' 60603 312 - 782-3332
WATER PCB-SD0000038596
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78
A Its principal use is it is added to water used in industry to remove or tie up the oxygen that is
present in water to make water less corrosive.
Q Such as you described earlier with the boilers?
A Correct.
Q And the chlorophenols, what are they used for?
A Chlorophenols are again starting chemicals for
pesticides. They are also used as slimacides and also
wood treating.
Q Is that achlorinatedhydrocarbon?
A Yes.
Q Do any of the four of these contain PCBs?
A Not to my knowledge, no.
Q If you don't know, nobody knows.
Did Monsanto manufacture pesticides in
1964?
A Yes.
Q The chlorophenols that you were manufacturing
at Krummrich would then be shipped to another plant to
be turned into pesticides, or were you manufacturing
them right there?
A I don't believe --Monsanto pesticides did not
start with chlorophenols. Ours were a different type of
pesticide. ----------- --------- ----------------------------------------------------------------------------- -
ea L. Ut'U
Citified Rhortho nd Reporter 134 Routh |_a Ralle Street a icapo, Illinois 60603 31? - 782-333?
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WATER PCB-SD0000038597
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79
Q So these materials you would manufacture then would be sold to some other formulator who would put
together a pesticide?
A Correct.
Q As one of the three General Superintendents,
Manufacturing, were you responsible for discharges with
respect to your machines that you were using for the
manufacture of these products?
A Yes, that was part of the job.
Q Was there a treating system set up with respect
to discharges?
A You are talking discharges as sewer waste?
Q Yes.
A The sewer waste at Krummrich Plant would go
to the Sauget Treatment Plant.
Q Is that a municipal --
A Municipal system, yes.
Q Treating plant?
A Yes, so there was no treatment, per se, of
the wastes from the manufacturing units.
Q There was no discharge directly to the
Mississippi River or any other body of water?
A No.
Q In the process and manufacture of these four
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substances, were your people still coming in contact
with PCB-bearing fluids in the manufacturing process
as you described earlier with regard to Queeny?
A No, not that particular group.
Q You did not use heat transfer fluids or
Pydrauls, is that right?
A That is right, to my knowledge.
Q They were manufacturing PCBs at Krummrich at
that period of time, were they not?
A Ye s.
Q That was one of the other Superintendents
who was in charge of that?
A Yes.
Q Who was that?
A Mr. Heisler, Paul Heisler.
Q How long did you hold this position at
Krummrich?
A Until April or May of *65.
Q During that period of time were similar prac
tices employed at Krummrich as you described earlier
with regard to Sauget by the employees in the handling
of chemical products?
'
A Yes.
Q You gave periodic lectures to them?
______________________________________________________________________________________ ___
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orthand Reporter
134 South |_a
Street
a \cooo. | ! I inois 60603
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A Yes. Q And had management meetings as well, is that
right? A
Yes.
Q Of the salaried employees?
A Yes. Q During any of these meetings, was the dis
cussion held with respect to PCB-bearing fluids or PCBs
generally? A I don't specifically recall that very topic,
no. Q Were there any special safety practices
employed at that plant as far as you were aware with
respect to the employees who were manufacturing PCBs?
A I think you used the word special?
Q Yes. A No. We were following, the best of my knowledge,
the good industrial hygiene practices which involve
cleanliness, good housekeeping. I don't know of anything
special or unique that was followed.
Q The same practices were followed with regard
to manufacture of all products at Krummrich?
A Not necessarily all. There were some materials
manufactured at the plant that required special attention.
"Thea |_. l^Jrlscin
Certified
134 L
Street
o icago, Illinois 60603
312 - 782-3332
WATER PCB-SD0000038600
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82
For example, chlorine. Q What special attention was given?
A They had to have special respirators to pre
vent exposure to any chlorine leaks, so that is just
one example and I'm sure, I don't recall specifically
at the moment. Each chemical has to be looked at on
its own, but you start with a basic line of good practices
and then take care of special.
Q We have now come full circle, that is why I
was asking if there were any special practices employed
with the manufacture of PCBs as it would impact on the
safety of employees who engaged in that manufacture.
A Nothing unique.
Q Would your answer be the same with respect to
disposal of the waste involving PCB manufacture, was
there any special handling techniques you were aware
of at Sauget in 1964, '65?
A Keep in mind I was not intimately involved,
but to the best of my knowledge, we treated those wastes
just like we did other chemical wastes.
Q In the treatment of chemical wastes in that
period of time of Krummrich, was the Waste Treatment
Plant advised of the nature of the wastes that were
being submitted to them?
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Tkea L. LWan
Certified Ck orthtind [-^eporteT'
134 |_a 5*3 He S^Teet a icocjo, Illinois 60603 31? - 78?-333?
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A You're talking now of the water wastes?
Q Yes.
A Yes, they were advised by the usual parameters
which were used at the time to describe wastes.
MR. SCHINK:
The acid, the dissolved solids, the
oxygen demand?
BY THE WITNESS:
A
(Continuing.)
The usual parameters, the
typical parameters.
They were aware of all of that and in
fact, they would analyze and we would analyze, compare
notes.
BY MR. POPE:
Q With respect to chemical wastes, were the
practices at Krummrich the same as you have described
them for Queeny; with respect to sweeping up of sub
stances, putting them in containers and having containers
taken out to the landfill?
A Yes, generally, yes.
Q As far as you know, was there a period of time
at Krummrich when anyone was checking the wastewater
for PCB presence during this '64-'65 period?
A No, the methodology did notexist.
Q No one was checking?
~|~hea |_. Urban
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A That is right.
Q And in fact, your answer would be the same
for Queeny?
A That is right.
Q You said the methodology did not exist. What
methodology would have been required that didn't exist
in '64, '65?
A As it turns out from what we know today, it
requires the use of some sophisticated analytical equip
ment, a gas chromatograph, mass spectrometer and a
method for processing the sample to get it ready to be
introduced into the present machinery to get the results.
All of that was not known at the time we are discussing.
Q '64, '65?
A Right.
Q Is it your testimony that without those sub
stances or those processes or equipment that had not
yet been invented or knowledge about them had not been
circulated, it was impossible to check wastewater for
the presence of PCBs?
A Yes. Now we aretalkingdissolved PCBs.
Q
What is thedifference from
anyother kind?
I don't understand your clarification.
A If water and PCB are present together and
Tkea L. can
Certified
ortRnol Reporter -------------------
134 5outh |_a Ralle Street CTicrago, Illinois 60603 312 - 782-3332
WATER PCB-SD0000038603
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there are a lot of PCBs present, the PCBs will sink
to the bottom, a separate layer.
Q It is heavier than water?
A Correct. Under those conditions, it is very
easy whereby to make a separation and prevent that
bottom layer from going on to the treatment plant.
. That doesn't need analytical methodology,
but to determine the PCBs in that water at that point
in time, no one knew how to do that.
Q Just to clarify or help me understand that,
is it your testimony then in 1964 or 1965 if you took
a sample to one of your Monsanto chemists of a substance
and said, "Can you tell me if there are PCBs or not,"
he would not have been able or she would not have been
able to answer you. Is that true or is that false?
MR. SCHINK:
I object to your question unless
you clarify.
Are you talking about a sample of water
with PCBs dissolved in it?
MR. POPE:
No, just a --
MR. SCHINK:
What kind of sample?
MR. POPE:
Just a liquid material of PCBs.
MR. SCHINK:
That was a liquid PCB?
MR. POPE:
Yes.
Thea L- Uftwin
Certify S^ ortliand Reporter
134 Soutk \_a Salle Street
CSiccgo, llllnoi? 60603 312 - 782-3332
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WATER PCB-SD0000038604
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86
BY THE WITNESS:
A This is all PCBs?
BY MR. POPE:
Q Yes, sir.
MR. SCHINK:
The question is could the laboratory
in 1965 have told Mr. Papageorge what that was?
BY MR. POPE:
Q Would that fall in the same category as being
unable to determine?
A If the PCBs are present and as you say all
PCBs, the answer is yes, they would be able to determine
that it is PCBs.
Q Would your answer be the same with respect to
a cup of Pydraul, for example? If I had taken that out
and you had given that to one of your chemists, could
they have determined that that was PCB-bearing fluid?
A Yes.
Q What methodology as far as you understand
would have been employed in those days or what would
have been the proper methodology to use in 1964-'65 to
make a determination?
A I am not really conversant with all, but I
know they determine total chlorine content.
Q Was that by infrared?
T^iea [__ U^bem
Certified Sh ortho nd Reporter
134 South L_o Solle Street Ch icogo, Illinois 60603 312 - 782-3332
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A No, this was in those days by using a high
pressure bomb-type of arrangement and burning --
q B-o-m-b, not b-a-l-m? A Right, and burning the material and ending up
with the chlorine and analyzing for the chlorine and then working back, very crude by today's standards, but
that was rather typical at that time. 0 That was the state of the art at that time,
to make those samples?
A Yes. There are other tests they apply to
confirm that it was PCB and not some other hydrochlori-
nated chlorine. Q Were they at that stage, after doing those
tests, able to determine the percentage of weight by
chlorine? A That is the way the chlorine was determined,
yes.
Q From that they would know what type of PCB
it was, ' 6 4- ' 6 5?
A Correct, correct.
Q May of 1965, you gotpromoted?
A Yes.
Q What was your promotion to?
A I was assigned a Plant Manager with the
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~|~bea |_. Urban
Certified Ch orthond Reporter
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134 Couth [_a Cdle Ctreet a icctgo, Illinois 60603 312 - 782-3332
WATER PCB-SD0000038606
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Anniston, Alabama Plant. Q Does Anniston have a name? A No. Q That plant hasn't been blessed with a name? A They stopped the practice. Q I take it in the scheme of things, a plant
Manager is somebody who is above a General Superintendent? A Yes. Q What were your duties as Plant Manager in
Anniston in 1965? A I was responsible for everything that took
place in that plant, manufacture -Q Could you tell us what did take place in the
plant and that will tell us what you were responsible for.
A Manufacture of chemicals, of course. I guess there were two principal product lines, really. It was the chlorinated biphenyls/terphenyls and insecticides and we produced some of the chemicals that went into the manufacture of these two main product lines .
Q You made the finished product and also made some of the ingredients for those products?
A Some -- well, yes, yes. Q What was the makeup of insecticides that were
Thee L- LUen
Certified Ch orthond Reporter .----------
154 1_o Celle Ctreet Chicago, | I linois 60605 51? - 782-555?
WATER PCB-SD0000038607
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manufactured or were there multiple ones? A It was the phosphonates we call parathion.
I don't know if it is a trade name or a generic name; basically parathion and the methyl-ethyl versions, but parathion is the common designation.
Q In addition to those insecticides, you also manufactured chlorinated biphenyls and terphenyls, is that right?
A Yes. Q How many forms of chlorinated biphenyls were manufactured at the time you became Plant Manager in 1965, do you recall? A How many forms? Q How many products? A Liquid and solid. Q How many types of products fall within that general category of chlorinated biphenyls that were manufactured at Anniston? A By types, I would refer to the liquid type and the solid type and within. Q Okay. A Those two major categories. We had mixtures that were marketed under trade names. The trade names we applied were the Aroclor followed by the four-digit
L.ea LWan
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134 South La Salle Street
a IC&tfO, | 11 i not ^ 60603
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designation. Then we made the Aroclor 1221, '32, '42 -- these are the last two digits of the 1200 series -- 48, '54. I think we made a little of the '62 and '68.
That represents the PCB line when I arrived.
Q Were others added afterwards while you were there?
A Not at Anniston, no. Q How about the terphenyls? A The terphenyls, the terphenyls were designated by the 5000 series, so we made some 5445 and 5460. And then we had a blend of PCBs/PCTs which we called Aroclor 4560. Q Is that it? A I believe that's it. Q Is that really the sum total of what was being manufactured at Anniston: The insecticide, basically parathion, the Aroclors you have listed and the terphenyls and this one blend of PCB and PCT? A Right. We had in the PCB line, we also blended transformer fluids which were referred to by the elec trical equipment manufacturers' trade name of Pyranol, P-y--r--a-n-o-1, and Inerteen, I believe I-n-e-r-t-e-e-n. Q Any other products that were being manufactured
Tkea L- cm
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at that time? A Yes. Then we also sold or shipped out of
the plant three other materials that I recall. One
series we called Santowax.
Q W-a-x?
A S-a-n-t-o-w-a-x, which was the unchlorinated
terphenyl mixture.
We also shipped out of the plant a
material we called HB-40, which was a hydrogenated
biphenyl.
We also sold biphenyl itself.
Q Unchlorinated, unhydrogenated?
A Unchlorinated, unhydrogenated.
Then we sold some of the residues from
the PCB/PCT mixture under the trade name Montar,
M-o-n-t-a-r. I believe that's it.
Q
During the years thatyouwere
Plant Manager,
did this product line basically stay the same?
A Yes.
MR. POPE:
Let me have this document marked, please,
as Papageorge Exhibit No. 1.
(Papageorge-OMC Deposition
Exhibit No. 1 marked for
identification, 8/27/81, TLU.)
Tb e<? |__ . Urban Certified Si ortfand Reporter ---------------------
134 Coutii La Cnlle Street a icago, | llinoir 60603
. 312 - 782-3332
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BY MR. POPE:
Q Mr. Papageorge, let me hand you what has been
marked as Exhibit 1 for identification. Can you tell
me what Montar consisted of and what its purpose was?
A Montar was that fraction of the liquid stream
that remains after the Aroclors were distilled off or
where the biphenyl was distilled off. It looks like
road asphalt, black, tarry-type material.
Q What is it used for?
A I never did pursue it personally. I was led
to believe it was used for many applications that
asphalt and tar was used for.
Q I take it that was not a major product from
the plant?
A NO .
\
Q How about the biphenyl itself? What was that
used for?
A It was used by industry as a starting material
for their dyes. It is used by the citrus industry to
impregnate inner layers in the packages of citrus fruit
and also the tissue to prevent the molding of the fruit,
the spoilage. I don't recall any other.
Q Biphenyl is a substance you would use yourself
as a raw material at Anniston, is that right? Tbea 1_. Urban
Certified Sh orthand Reporter -
134 Cuth La Calle Ctreet a icago, Illinois 60603 312 - 782-3332
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A Yes, that is right. Q Would these sales be sporadic that were
selling excess amounts left over?
A They would be steady by low volume, relatively
low volume.
Q How about the HB-40? What was that used for?
A That was used in proprietary products as a
solvent and in some cases at that time was used as a
heat transfer fluid at temperatures lower than the PCB
use. It cannot take the extremely high temperatures
but it is a good heat transfer fluid.
The big heat transfer use for HB-40 was
by the Canadian Government in their atomic energy units
as a heat transfer medium.
Q Was that a large volume item relative to the
rest of the plant?
A No, small unit, very small.
Q How about Santowax, the unchlorinated ter-
phenyl mixture?
A I was told that that was also used as a start
ing point for many chemicals by many customers.
Q Outside interests?
A Outside Monsanto, yes.
One of the uses was a wax extender.
BO. L. Ut-U
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Q What type of wax? A I don't know where the word extender comes
from, but I was told because I am not the authority, this helps make candles dripless, for example.
Q I detect that was a low volume item as well?
A Yes.
Q How about Pyranol and Inerteen?
A Yes.
Q What were they used for?
A They were used in transformers in the
electrical equipment industry.
Q Were they different from the Aroclors that
were used in that sense,in that application?
A Some of them. Most of them were blends,
blended with tri- and tetrachlorobenzene.
Q Would they have any different use in the
transformer electrical industry that would call for
Pyranol as opposed to one of the Aroclors?
A Yes. It depended, and I am no electrical
engineer, but I am told it depended on the design of
the unit, the work load, the stress that the fluid would
be expected to undertake, the location in the country --
for example, a unit up near the Arctic Circle would
contain one; for up near the Tropics would contain
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another, and variations in between. Q How about Inerteen? What was that used for,
the same thing? A Same thing. For clarification, the Pyranol
is a General Electric trademark, and Inerteen is a
Westinghouse trademark, and they were competitive in
the marketplace.
Q Were those two companies the principal users?
* A Yes.
Q This is not a low volume item, I take it?
A I'm sorry?
Q This is not alow volume item as we were dis
cussing some of the other products? A That is correct.
.
Q The PCB/PCT blend, Aroclor 4560, what was its
basic use in the marketplace?
A I don't know if there is any basic use. It
had a lot of small volume miscellaneous uses: Adhesives,
coatings, sealants.
I understand it was also used in the wax,
used in the casting industry, metal casting, the lost
wax process.
I can't recall any other at the moment.
Q Is this a major product line for Anniston?
"ftea L. LUan
Certified orth^nd [Reporter
134 |_a Street a tcago, Illinois 60603 312 - 782-3332
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A No. Q The terphenyls, 5445, what was that basically
used for?
A About the same kinds of things that this 4560
and the same for the other terphenyl.
Q 5460?
A 5460, 5445.
Q None of the three of those were used as a
pesticide extender, were they?
A No.
Q That was one of the Aroclor --
A Wait a minute, let me think about it.
I vaguely recall some reference to the
use of 5460 as a pesticide extender similar to the PCB-
type extender purposes.
Q That was 5445?
A I think it was '60.
Q Could we go in through the Aroclors in any
fashion that would be convenient for you and similarly
tell me what their basic use was?
A You mean the biphenyls, the PCB Aroclors?
Q Yes.
A I will try.
The principal use, let me turn that around.
Tkea L-
an
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. a iCOOO, Illinois 60603
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Capacitor fluids, electrical capacitors would principally
use Aroclor 1221 and Aroclor 1242. Transformer fluids --
Q Excuse me. With capacitors, what would dictate
use of one as opposed to the other, generally speaking?
A Each customer felt that he had strong scientific
data to indicate that he needed a unique mixture.
Q Stronger data thanMonsanto had?
A That's right.
The '42 was referred -- the 1221 was used
in colder climates. That is generally what happened.
Q Okay.
A The transformer industry used Aroclor 1242,
1248, 1254 and 1260.
Q Similarly was there a rationale for customers
using one over the other based on its physical charac
teristics?
A The preferredone was Aroclor 1254. For
colder applications they would go to the 1242 and
occasionally on a much smaller scale 1260.
Q For colder uses or uses in colder places?
A No, warmer, it would be more viscous material.
Hydraulic fluids would principally be
1242 and 1248. 1242 predominated.
Q What would distinguish between the two?
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A I think they were striving for different viscosity ranges.
Q The higher number being more viscous? A More viscous, yes.
Q As far as you know, those are the only two
that would be used in hydraulic fluids?
A To my recollection, yes. We are still talking
now in 1965, middle '60s?
Q Right.
A The heat transfer applications ranged from
1242 and 1248, 1254 and the selection would be based
on what temperature was desired.
Q The highest temperature that the product would be used in?
A Yes, the higher the number, the higher the
temperature at which it could be used for the breakdown.
The plasticizer application,which is
more correctly in my opinion should be called miscellaneous
application, used all of the Aroclors in a variety of
uses.
It covered paints and lacquers, wax ex
tenders, caustic materials, adhesives of all kinds, the
hot melt and the so-called cold adhesives; as an ingre
dient in some special plastic materials like chlorinated
~j~hee> !_ LJ^bian
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rubbers to make them pliable, flexible. That is the only true plasticizer appli
cation. Does that help, that rundown?
Q Were there any other uses or have we gone
through the entire use of Aroclors?
A I may have missed a few. I am trying to recall
all of them. Q Were Aroclors used in paper products, packaging?
A Okay, I have forgotten to mention the use in
ink. Aroclor 1242 was an ingredient in many ink formu
lations.
Now, your question regarding use of paper
products, to my knowledge, PCBs were never used directly
with paper products. They were used in the inks that
were applied to the paper. They were used in the ad
hesives. They were used in making the various products,
whether they be boxes, envelopes and so on.
Q Carbonless carbon paper, did that use Aroclors?
A Yes, carbonless carbon paper is in my thinking
included under the ink application.
Q The 1242?
A The 1242 would be solvent along with other
materials used in the microcapsules that are on the
paper surface.
TUa L- LMan
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Q In that particular application, was the Aroclor 1242 sold to many distributors, many users of carbonless carbon paper or was it one principal pur chaser?
A There was one principal purchaser and I have forgotten the details. There may have been a licensee or two, but very few customers received our paper.
Q What company was that? A NCR. Q They basically manufacture all of the carbon less carbon paper that contained Aroclors through them selves or licensees, as far as you understand? A That is my thinking. Q Any other applications that come to mind other than the ones we have gone through that are users of Aroclors that were manufactured in Anniston in the '65 period? A I can't recall any. Q How about soaps? Were soap manufacturers the purchasers of Aroclors for use in their products? A Not to my knowledge, no, not in their products. Q As far as you know, Aroclors were not used to formulate or manufacture soap, is that right? A That is right.
L Urban
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Q Mr. Papageorge, I'm going to hand you a docu
ment that I believe was produced in the records of
Monsanto, first page which contains the number 0004361,
and to be doubly safe we have marked it as Papageorge
Deposition Exhibit No. 1 for identification.
Would you take a look at that and tell
me whether you have seen that basic brochure before.
It appears to be a brochure entitled The Aroclor Compounds.
Is that a copy of the document with
which you are familiar?
A First time I've seen this one.
Q Are you able to determine when that was pub
lished?
A I looked but I could not tell, I cannot tell.
Q Does that document refresh your recollection
as to any further uses or applications of Aroclors
that were being made during the 1960s other than the
ones you have described for us?
MR. SCHINK:
You are asking him about PCB as well
as PCT Aroclors or just PCB Aroclors, Mr. Pope, because
the document relates to both types.
MR. POPE:
I was actually asking him about the
uses of products that were manufactured at Anniston
so I meant it in a broad sense rather than the limited
. Tbea 1 . Urban '
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sense. MR. SCHINK:
You are asking him now whether this
document refreshes his recollection as to any further
use?
MR. POPE:
Yes, as to any further ones he hasn't
discussed so we can complete this area.
BY THE WITNESS:
A Looking through this brochure I see some
references that in my description of the uses I would
have included, for example --
MR. SCHINK: His question is can you think of any
other uses that you haven't described.
He's clarifying -
BY MR. POPE:
Q You are saying some are there you are not
sure were included in the category, is that right?
A I am including it in my thoughts.
Q For example, when I use hydraulic fluids, I
am using the vacuum diffusion pump oil very definitely
here or liquid sealant for furnace roofs.
A I had referred to the plasticizer use in
rubber. The brochure reminds me that it was proposed
as a plasticizer in many kinds of plastic materials.
I don't see any other, I don't recall any other uses.
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Q So our list should be just about complete.
These uses we have been discussing were
basically the products and the uses of products that
were being manufactured when you took over as Plant
Manager of Anniston, is that right?
A Right.
Q Were you able to determine whether this basic
product mix had been manufactured at Anniston prior to
your taking over?
A Yes.
Q It had?
A Yes.
Q Can you tell mefor approximatelyhow long
Anniston had been manufacturing PCBs generally and if
you are able to with these various types of products,
how long specifically with them?
.
A The Anniston, Alabama site had been manufacturing
PCBs since late 1929.
I personally never knew exactly when each
of the types was added to the product list.
Q The Aroclors andthe numbers wehave been
discussing from 1221 to 1260, were you able to determine
how long they had been under manufacture at Anniston?
A No, I never did make that study.
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Q When you became Plant Manager, did you under
take to increase your knowledge with respect to PCBs
over what it had been previously?
A Oh, yes.
Q How did you go about doing that?
A Two ways: One is the reference to all the
existing material available in the plant library, plant
records,which was my first approach. That was my initial
approach, and then this was followed up by my personal
discussions with the individuals at the site and else
where who had been involved with PCBs for many years
and I was able to learn from them on an informal one-on-
one type of discussion.
Q Anything else?
A That's it.
Q Did you have an Assistant Plant Manager who
had already been there before you took over?
A Not that title.
Q Did you have somebody that basically was your
assistant with a different title?
A No, we don't have that kind of an organization.
We have a General Superintendent of Manufacturing at
.
the site .
Q Had he been there at Anniston before you got
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there?
A Yes.
Q What was his name?
A Robert Moody, M-o-o-d-y.
Q Was Mr. Moody a source of information to you
on the general subject of PCBs?
A One of many, yes.
Q Was he a knowledgeable source?
A Yes.
Q Is he still with Monsanto?
A Yes .
Q Tell me about the Plant Library. What kind
of library did Anniston have at that time when you
became Plant Manager?
A I don't know how to describe it. It consisted
of the usual types of reference books that a chemical
laboratory might have. In addition, it has what we
refer to as the Standard Manufacturing Process.
Q What is that?
A It is a volume which contains the procedure
followed in the manufacture of any product, in this case
PCBs.
Q This is a Monsanto document?
A Yes, and in addition to describing the conditions,
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temperatures and procedures and times, ingredients, it
also has other informative sections including a des
cription of physical properties of the material such
as -
MR. SCHINK:
They have them. They have been
marked as an exhibit in other depositions.
MR. POPE:
I would like to know what the witness
recalls of it though.
BY MR. POPE:
Q You may continue with the description.
A There is a safety section in there, references
to the toxicity of the material, if any; how it should
be handled, whether it is explosive, whether it requires
any special kind of attention. That about covers it.
Q Did your review of the Standard Manufacturing
Process at least in sections related to safety and
toxicity, did that increase your knowledge over what
you had at least been aware of from your past knowledge
and experience with Monsanto?
A No, it reinforced it.
Q Do you recall reviewing any other text in the
Plant Library with respect to PCBs with regard to the
manufacturing process, the chemical makeup or the possible
toxic effects?
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A I don't remember any specific book or pamphlet. Of course, eventually I got around to seeing the brochures similar to the one we just saw.
Q How many brochures were published dealing with Aroclors that you recall during the period of time that you were Plant Manager?
A I recall three, personally. Q Those are all different ones other than the one we have marked as Exhibit No. 1? A Yes. Q Were they the same type of brochure, a dif ferent edition or were they different products altogether? A Well, one was similar to the one we just saw here in that it addressed many of the miscellaneous uses I earlier referred to as plasticizer-type appli cations . Q Was it confined to that discussion? A Yes. The other I recall was directed to the electric application and the third one dealt with heat transfer applications.
I don't recall any of the other. Q Were those brochures made available to you prior to being published or sent to the customers? A Those brochures were printed and available
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when I arrived on the scene. Q They had already beenthere? A Yes. Q Did the Plant Library at Anniston have sub
scriptions to any scientific and medical journals that you recall in 1965 when you became Plant Manager?
A I don't recall. Q Have we exhausted your recollection with regard to anything you did in review of the Plant Library in checking out on PCBs or learning more about PCBs generally? A Yes. Q I think you also referred to having access to
the plant records with respect to that same subject matter.
A Yes. Q What records did you have access to and what did you do in terms of increasing your knowledge on PCBs? A There were records summarizing that unit's activities by month and by year. Q The sales volumes, production levels? A Production volumes, sales amounts or movement amounts. Some of them were transfers to Monsanto and
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reference to changes in personnel, reference to the
safety record, references to meetings held; sort of a
summary of activities by month and then summarized by
year.
That was available. Then I had access
because I had access to medical records, I would sit
down with the plant physician and become familiar, not
to the extent he was, but to get a feel for what was
going on in the plant.
Q Medical records of -
A Of employees.
Q Any ill effects they had encountered or reported?
A And this is not unique to PCBs. This is the
whole plant.
Q Is that a standard technique in any chemical
manufacturing plant?
A I cannot speak for any other plant managers
but I did it.
Q All right.
A Then there are logs kept in the operating unit
by the operators and not that I could read everything,
but I got a good understanding by scanning to see what
kind of notes they were making, remarks, problems they
had during the night shifts and what maintenance was
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taking place.
Q Those logs are limited to the maintenance
area?
A No, just any non-routine event that takes
place on a shift is normally recorded, if it is of
significance.
Q Would a spillage of chemicals be reported on
a log?
A Or a leaking gasket or a pump that is leaking
and had to be repaired, notes would be made.
Q And you reviewed that?
A Yes.
Q Anything else?
A I can't think of anything else.
Q The production records that you reviewed, how
far back did they go, approximately?
.
-A
I don't know.
Q As you took over in 1965, how long had the
plant basically had the same configuration, same size,
same capacity?
A About 10 years.
Q From your review of themedical records, records
of your employees, did you determine that your employees
basically had been with the company some time?
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A It varied. There were some new employees and some were long years of service.
Q Did you detect anything unusual in the medical records that caused you any concern?
A No. Q Were they in your opinion being adequately kept? A Yes. Q Who was on the medical staff at the Anniston Plant then? A Dr. James Francis. Q Had he been there for some time? A Oh, yes, yes. Q How old was he? A I'm going to have to guess. At that time I believe he was in his early 50s and had been associated with the plant for about 20 years. Q Is he still alive, as far as you know? A Yes. Q Does he reside in Alabama? A Yes. Q What kind of a safety staff was in place at Anniston when you took over? A We had the one individual who served the role
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Safety Supervisor or Safety Engineer and he was con sidered to be adequate for the size of the plant. Of
course, he didn't do the job alone. Q Who assisted? A His name escapes me, I can't remember his
name . Q
Did you have a laboratory at Anniston in 1965?
A Yes.
Q What was the size of it? A Are you talking about physical dimensions or
people? Q Either one, I don't know. Some describe
hospitals by the number of beds it has. I don't know
if you describe a laboratory by the number of chemists
it has or not.
-
A I think it is more appropriate to refer to the
staff that worked in the laboratory. As I remember,
we had three professional chemists, a good half dozen technicians.
Q Were the three chemists graduate scientists?
A Graduate degrees, yes.
Q There were six technicians besides that?
A About that. I don't recall the exact number.
Q What was the basic function at the Anniston
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laboratory? What did they do? A They analyzed, of course, the finished product
to see that it met specifications. They analyzed the
raw material to see that it, too, met the purchase
specifications and they analyzed the intermediate
chemicals that we produced to see that they were pro
duced properly for use later in another process.
They analyzed Water samples which included
boiler waters, cooling waters and also wastewaters.
I believe that covers the area of their
activity.
Q They weren't doing any original research?
A No.
Q That function was all centralized in St.
Louis?
A Let me back off a bit. On occasion the
chemists would take on a very small, little special
study related to the plant and its current processes.
There was no research for new products, new processes,
anything like that.
Q Can you give me an example of what type of
study they would do or they did do?
A The one that comes to mind, for example, I had
mentioned earlier the product tiB-40.
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As I remember, we were having difficulty
in getting a catalyst from the original supplier and
we had an alternative source, so our laboratory was
asked to determine if this new source was as effective
as the old, so they were able to set up their test unit
and then to study that for a short period of time.
That is the typical example.
Q Kind of occasional basis when the need arose?
A When we wanted a quick answer to help ourselves
rather than go to someone else.
Q During the period of time that you were Plant
Manager, did the size of this laboratory stay relatively
the same?
A Yes.
Q By that I mean the number of people, the staff?
A Yes.
Q Their functions remained relatively the same?
A Yes.
Q You mentioned that one of their tasks was to
analyze the water samples from wastewater.
A Yes.
Q Were they testing for presence of PCBs in
wastewater?
A No, not at that time. ---------------------------------------------------------------------------------
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Q Why were they not?
A Primarily because there was no methodology to
detect PCBs in water. Q Were there any procedures in place when you
became Plant Manager to see that PCB products or by
products were not coming in contact with wastewater?
A 0hf yes.
Q What procedures were in place?
A The process itself was what I call a dry process.
There is no water there, it doesn't use any water. The
only water that gets into the area would be rainwater
and this particular installation at Anniston was an
indoor facility. It was housed in a brick building,
stone or block, concrete building so even the rainwater
problem was not even a problem.
So PCBs getting associated with water
is very remote and then spillages and the like would
be as we discussed earlier, contained, absorbed, swept
up, shoveled up and taken to the Anniston operated
landfill that we had.
Q The procedures were roughly the same as you
had described at Queeny and Krummrich?
A Yes, identical. The intent was identical.
Q Were there other manufacturing processes that
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did have the product come in contact with water?
A Well, sure.
Q At Anniston? A Yes.
Q Which ones werethose?
A The chlorine unit that made the chlorine, I
don't know that we discussed that. We made chlorine to
use in the chlorinated biphenyls. That was water in it.
The insecticide operation has water in it.
Q
Were your laboratory people analyzing
the
wastewater for residues from those contexts?
A Yes.
Q
And to your knowledge, what processes
did
they use to determine the presence, for example, of
chlorine in them? A I am not familiar with the analytical method
ology used.
Q With respect to the boiler water and the
cooling water, what were they analyzing for?
A The typical characteristics such as the solids,
dissolved solids, acids. It is referred to as pH, the
presence of oxygen,and in the case of boiler water, the
amount of calcium that is present. That's about it.
Q Were there procedures in place when you
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became Plant Manager at Anniston to see that PCBs did
not escape into the environment in the manufacturing
process? A That's right.
Q Were those procedures other than the one you
described already with respect to the water?
MR. SCHINK:
Arid with respect to spills, contain
ment? He has discussed that as well.
MR. POPE:
Taking out to the landfill, I don't
count that, Jim.
BY THE WITNESS:
A The thrust of the whole program was one of an
individual getting PCBs and any industrial chemical out
in the environment. I explained earlier how we contained
spills. Keeping water away from PCBs is a must. Any
solid material such as the Oil-Dri and sweepings and
rags and contaminated coveralls, all of that, burying
it properly -- that's about all there is to it, control
your spills, dispose properly. They are really not
complicated.
BY MR. POPE:
Q Were these procedures, for want of a better
word, written in the plant records at Anniston?
A At that point in time?
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I don't recall. There is a section in that operating procedure on housekeeping or there
usually is. I don't remember.
Q The principle of keeping water away from PCBs
as a means of PCBs getting into the environment, was
that'something you had already been familiar with from
your past work at Monsanto?
MR. SCHINK:
You are not talking about the fact
that it was a dry process to manufacture it? You are
characterizing some discussions of his earlier testimony
as I understand it about the fact that water was not
used in the process to manufacture PCBs.
MR. POPE:
No, that is not what I am talking about
at all, Jim.
Read the question.
MR. SCHINK:
I object to the form of the question.
I don't believe it accurately characterizes his prior
testimony.
MR. POPE:
Read the question, please.
(Question read.)
BY THE WITNESS:
A Yes.
BY MR. POPE:
Q When did you determine that?
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A I don't remember any specific point in time or place. I think this is one of the bits of informa
tion that is associated with PCBs in our normal com
munications regarding PCBs.
Q Were you during your period of time as Plant
Manager successful in keeping PCBs out of your waste
water discharges?
A Yes.
Q Was this viewed as a goal by Monsanto, at
least as applied to the Anniston Plant?
A That was a must.
Q Why was that?
A I think it is our desire to keep that kind of
material out of our wastewater which went to the City
system and since there is no water to start with, there
was no need to add water anywhere back in that unit to
create a situation which would complicate things. It
just seems very natural results of kinds of processes (' ' f
and our desire not to get it out of control.
Q Was there a feeling that there was a potential
health hazard with PCBs getting out into the environment
or into the wastewater?
A No, there is no -- no.
Q As of the time you became Plant Manager, had
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you ever heard anyone make that suggestion?
A No.
Q Had you ever read it in anydocument?
A No.
Q As a reason for the goal of keeping PCBs out
of your wastewater?
A No.
Q I have since read of reports that there are
PCBs that have been found outside of a discharge from
Anniston. Have you similarly read such reports?
A Yes, I saw some reports after I left the plant
when analytical methodology was available. The reports
I saw referred to low levels. I don't remember the
numbers of PCBs in the water, yes.
Q Is ityouropinion that those PCBs got there
through the wastewater discharge or some other fashion
from Anniston?
A I can only speculate. I don't know.
Q As you sit here today, you do know more about
the subject than when you were Plant Manager, right?
A Yes.
Q A great deal more?
A Yes.
Q Is ityourtestimony that it is at least as
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probable that the PCBs that had been discovered got
out through the wastewater discharge as they got there
some other way?
MR. SCHINK:
He said he doesn't know how they got
there and you are asking him to speculate about that.
MR. POPE:
I asked him if one way of getting things
there is more probable than another way and I just have.
MR. SCHINK:
Answer the question if you can, if
you have a basis for that kind of speculation.
BY THE WITNESS:
A If I were to speculate, I would suggest -
MR. SCHINK:
You don't have to speculate.
BY THE WITNESS:
A I don't have to -- well, I don't know how to
answer the question.
MR. POPE:
Read it back.
BY THE WITNESS:
A Nothing that I know now, I would suggest the
more likely source of those PCBs could well be the
soil in the general area of that plant after 30 or 40
years of manufacturing PCBs and rainwater runoff would
be the most likely source of that PCB.
BY MR. POPE:
Q When you refer to the plant, are you including
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the landfill within that?
A No, the landfill is across the highway,
physically different.
Q In your initial review of information available
to you with respect to PCBs and their characteristics,
did you review any published scientific articles regard
ing tests or studies that had been done on the subject
prior to 1965?
MR. SCHINK:
The subject of what?
MR. POPE:
The subject of PCBs.
THE WITNESS:
What is the early part of your
question?
MR. POPE:
Why don't you read it.
(Question read.)
BY THE WITNESS:
A This review then is after I arrived at
Anniston, the Anniston Plant?
BY MR. POPE:
Q As part of your process that you already
testified to to gain more knowledge about PCBs.
A I did not review any published documents.
Q Was the main thrust of your search for addi
tional information, did it relate principally to the
manufacturing process?
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A I couldn't call it principally. My main
thrust was to find out what was available to Monsanto
regarding the product properties, its safety, anything
available to Monsanto, and I relied on the Medical
Department to read the outside literature, capsulize
and send it to the plant.
Q So in fact upon becoming Plant Manager or in
that general time period when you became Plant Manager,
you inquired of the Medical Department regarding the
safety of PCBs, is that right?
A Yes, in addition to reading things that had
already been submitted to the plant in writing.
Q What was that?
A That was part of that paragraph on safety
and toxicity.
Q In the Standard Manufacturing Process?
A Standard Manufacturing Process, yes, right.
The Medical Department, I guess, is generally author of
that section or if not the author, at least the final
reviewing authority.
Q But in addition to reading Standard Manufacturing
Process, you also made inquiry of Dr. Kelly's office?
A Dr. Kelly's office and Dr. Francis at the
plant.
l_. Urban
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Q Did you ask Dr. Kelly's office what he had
accumulated with respect to the safety of PCBs?
A Yes, not in those words.
Q What did he tell you?
A He reviewed for me the history as he recalled,
what he knew about the material, the studies that Monsanto
had done, the results of skin irritation and lung irri
tation, respiratory irritation, eye irritation.
These were based on animal studies plus
his personal experience.
Q Did he tell you anything about liver damage?
A No.
Q What tests had Monsanto done as far as you
know prior to 1965 that you were referring to?
A They had done a battery of tests commonly
called in industry as the Acute Toxicity Test which
includes the one referred to as the LD50, which is a
test that determines at what level of exposure to have
the test animals succumb.
Then there is the eye irritation test
with rabbits and there is a skin patch test with rabbits,
and as I remember they had inhalation studies, I believe
with the rat, and these were all designed to gather data
on how to handle material in the work place, how to label
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it, how to package it. That is what was available then.
Q Did you ask Dr. Kelly if there had ever been
a chronic test done with respect to PCBs? A No.
Q Why didn't you?
A That would have been at that point intime a
very unusual question for anyone to ask. It just
wasn't normal --
Q In 19 -- go ahead.
A
-- for industrialchemicals,
itwas not normal
for anybody to conduct chronic testing.
Q In 1965 is it your testimony it would be
abnormal for a chemical company to conduct chronic
animal tests with respect to a chlorine product? Is
that right?
MR. SCHINK:
He said with respect to an industrial
chemical.
BY MR. POPE:
Q Industrial chemical containing chlorine.
A Industrial chemical of any kind.
Q I understand, but you are specifically dealing
here with PCB which contains chlorine, right?
A Right, yes.
Q Were chronic tests being done by anybody in
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1965? A
Yes.
Q By whom were they being done?
A Manufacturers of pharmaceuticals, manufac
turers of registered pesticides were conducting these
kinds of studies.
Q And the basic difference between a chronic
study and an acute study is what?
A The chronic study is longer term period of
exposure at lower levels of exposure.
Q Lower levels for a longer period of time and
the focus of inquiry is not necessarily what the dose
is, but rather what effect it has on a test animal,
correct?
A Correct, and may I add I forgot to mention
those companies petitioning the Food and Drug Administra
tion for food applications or food packaging applications.
Q On what do you base your statement that it
would have been abnormal for an industrial chemical
company to have initiated such tests in 1965?
MR. SCHINK:
On industrial chemicals?
MR. POPE:
That's what we're talking about, the
industrial chemicals such as PCBs.
BY THE WITNESS:
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A It is based on my personal experience at that point in time, 1965, and I had been involved in in
dustry then at that point in time for about 18 years.
I had never heard such a test conducted
for any industrial chemical as well as later when I
became more intimately involved with the testing of
chemicals because of subsequent assignments.
The information I was able to obtain then
reinforced that understanding that industry did not
conduct chronic testing for industrial chemicals.
BY MR. POPE:
Q Had you in 1965 attended any trade meetings
where that statement had been made?
A No.
Q Did you inquire of officials in other chemical
manufacturing companies in or before 1965 whether they
conducted any chronic tests?
A No.
Q Did anyone prior to 1965 at Monsanto do a
literature search or monitor current literature to
determine whether anyone else was doing chronictesting?
A I don't know.
Q The standard battery of acute toxicity tests
that you referred to earlier, when were they done?
L- \Jv\xn
----------------------------------------------------------------------------------------------------------------------------------------- CerlifiedS^ orthond Reporter
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134 S outli [_fj 5alle Street
a icoqo, | Hinois 60603
31? - 782-333?
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A I believe there was a battery run in the
'30s and repeated in the '50s, as I recall.
Q In 1950 who did the test?
A Younger Laboratory.
Q In Ohio?
A No, St. Louis. I believe it is Younger
Laboratory. There is another laboratory, it starts {
with a "S." My memory fails me. That is the best I
can recall.
Q Why were the tests redone in 19 --
A The '50s, I don't know.
Q Subsequently you have not learned any reason?
A I was told but I don't remember. I believe
it was a case of enough years had gone by, techniques
had improved, let's repeat them, see if there is any
{
thing different.
That is the implication I was left with.
( t Q Would that fall within the area of Dr. Kelly's jurisdiction?
A Yes.
Q The decision to do such a test as well as
seeing that it wascarried out?
A Yes.
Q This laboratory that you had at Anniston in
"T"heo |_. l_Jrban
. Certified Sk orthand [Reporter -- 134 Soutf> l_c Salle Street a icopo, | I linoir 60603 312 - 782-3332
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1965, what kind of analytical equipment did it have,
do you know?
A I don't quite know how to answer that. It
had the typical pH meters, equipment to conduct titra
tions, a lot of what we called in those days involved
wet chemistry which involved water solutions of materials.
I don't have a list of all the equipment.
Q Did you have a gas chromatograph?
A No.
Q Mass spectrometer?
A No.
Q How about infrared?
A It may have had an early version of infrared,
but I don't know, I just don't remember. It didn't have
anything sophisticated.
Q Were your people in the laboratory analyzing
the wastewater for the presence of pesticides?
A Yes, one of the streams.
Q How were they analyzing for that?
A I don't know, I don't know.
Q Did you ever talk over with any of the chemists
that process?
A In a general way. I was more interested in
the results rather than the details of how they got them.
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Tkeei L. ITU
Certified Sh ortho nd Reporter ------------
154 Couth |_a C<dle C^reet Cfhicor^o, |liinoi9 60605 51? - 782-555?
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Q And they were able to show you by their results they were able to analyze for pesticides, is
that right? A Yes, yes.
Q Would they prepare reports for you of these analyses?
A Yes. There would be summary reports each (
month, yes.
Q What were they summarizing for in the waste
water?
A Which stream are we talking about? Are we
still on the insecticide? t Q I didn't understand your reference to streams.
Is that a technical term or are you talkingabout coming
from various places in the plant?
A I didn't mean to confuse. There are, as best
I recall, three possible streams coming out of that
plant. If memory serves me right, two of the three
eventually end up in this Anniston Municipal Waste
Treatment Plant.
The third one which consists of rainwater
runoff would run into a nearby creek and on down to the
water, the natural water system.
Q Is there a river there?
ea |_,
Certified Sforthand Reporter -- 134 Couth j_a 5aHe Ctreet a \caao, 11 linois 60603 312 - 782-3332
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A Sorry? Q Is there a river there?
A There is a river near KansasCity.
Q Would it run into, eventually end up at
Logan Reservoir?
A That is the Cusa River and there are some
creeks, two streams that end up in the City system.
One came out of the insecticide unit which received
pre-treatment with oxygen or air and bacteria and that
is the stream we referred to earlier, checking for
insecticides.
The other stream, a smaller stream,
would get what little water there was from the rest
of the plant which included the sanitary, the rest
rooms and so on.
Q They would analyze for those two streams?
A They would analyze specifically for the
insecticide stream and they would then analyze for the
composite stream that went to the City system.
Q They would not take any sample at all from
the third stream which was just the rainwater?
A Unless something unusual showed up they might
want to back trace, that would not be a routine.
Q
_Certified
Did that take place while you were there?
Thea |_. tertian
ortkand Reporter
134 South |_a Salle Street a \cono, Illinois 60603 312 - 782-3332
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A Obviously, yes. I don't remember the spe
cifics.
Q So on the one stream they were analyzing for
the presence of insecticides?
A Yes.
Q And in the composite, what were they analyzing
for?
A These are the traditional parameters: Total
solids, biological chemical demands, pH, turbidity;
these kinds of things. I believe that's about it.
Q And they would conduct those analyses at least
once a month and provide you with a report, is that
right?
A It's more frequently than that.
Q Both the sampling and the reporting?
A Thereporting would be once a month. The
sampling would be, if I remember correctly, daily.
Q Would those reports have been turned over to
a local governmental agency?
A Yes, they were also turned in -- the copy I
saw would be the material that was transferred to the
Alabama Water Agency.
Q Did this practice we have just been describing
continue virtually unchanged during the entire period of
Tinea [_. LJTan
Certified ortlionJ Reporter
134 Routh |_a
Street
a icaga, Illinois 60603
31? - 782-333?
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time you were Plant Manager?
A Yes.
Q Did the capacity of the laboratory to conduct
these tests remain basically unchanged during that
period of time?
A About the same, yes.
Q Didn't purchase any sophisticated equipment?
A No.
Q At any time did the levels of pesticides
exceed what was required or expected by you?
A Yes, we had some occasionalupset.
Q What is that upset?
A Well, when the system didn't perform as ex
pected, this would happen primarily in the winter when
the bacteria during an extremely cold day would stop
functioning and we would notice this rise and we would
have to go back and take corrective action.
Q I take it those reports would be brought to
your attention immediately without waiting for the
monthly to -
A True, yes.
Q Is there anything else during this period of
time that was disclosed by these reports that were
called to your attention immediately?
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Ttiea |_. Urban
Certified RliortCnd Reporter 134 *~noutli \_a Grille Ctreet
a \cooto, Illinois 60603 312 - 782-3332
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134
MR. SCHINK:
Do you mean actually disclosed by
the sampling analysis?
BY THE WITNESS:
A I fcannot recall of any other situations of
that type. I don't remember.
BY MR. POPE:
Q Those occasions where your reports were able
to detect insecticide in your wastewater, what levels
are we talking about that were detectable?
A Oh, I don't remember.
Q Is this parts per billion area?
A Did you say billion?
Q Yes.
A No, parts per billion was not common terminology
in '65, so it would have to be more than that.
Q On those occasions where it was detectable,
can you give us your best recollection of what was the
amount detected?
A I just don't remember. I don't remember.
Q As far as you know, did they have the capacity
to detect the presence of pesticide in amounts less than
10 percent per million?
MR. SCHINK:
They, you are talking about his
laboratory in Anniston? '
~Ttiec! I_ Urban
Certified
ortkond Reporter
134 Soutk La S^lle Street o icago, (llinoi? 60603
312 - 782-3332
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135
MR. POPE:
His laboratory in Anniston.
BY THE WITNESS:
A I don't recall.
MR. POPE:
Why don't we take a break for lunch,
Jim.
MR. SCHINK:
Fine.
(At 1:00 o'clock p.m., a lunch
recess was taken to 1:45
o'clock p.m. this same day.)
Tbeo |_. Urban
C-tiM Sf ortliand Reporter 134 Coutn |_<3 fClle Ctreet a icorto, Illinois 60603 312 - 782-3332
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